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Scientology Flag Service Organization, Inc., an active Florida
Corporation, (herein after referred to as CSFSO), did unlawfully and feloniously engage in or attempt to engage in the illegal, unlicensed practice of medicine,, to-wit: the diagnosis, treatment, operation or prescription for any human disease, pain, injury, deformity or other physical or mentalcondition or did act in this state as a medical doctor in violation of Florida Statute, Section 458.327 (1995). Your Affiant further has reasonable grounds to believe that the CSFSO, an active Florida Corporation, from approximately November 18, 1995 to December 5, 1995 did knowingly, willfully or by culpable negligence abuse or neglect Lisa McPherson, a disabled adult and in doing so caused great bodily harm.
Your Affiant learned through the above-mentioned
investigation that Lisa McPherson was a long-term member of the organization known generally as the “Church of Scientology.” She had initially become involved many years ago in her home state of Texas and had moved to Clearwater in late 1993 when her employers, who are also Scientologists, moved their business there. During the two years preceding her death, Lisa spent more than $70,000 for courses, services or auditing at the ’CSFSO, located at the Ft. Harrison Hotel in downtown Clearwater, and in various other buildings in the immediate Clearwater area. Your Affiant states that at approximately 5:50 p.m., on November 18, 1995 Lisa was involved in a minor traffic accident in Clearwater, |
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