IN THE COURT OF COMMON PLEAS

SHELBY COUNTY, OHIO

PARTIES

1. Plaintiffs Mr. Allen and Mrs. Allen are husband and wife and from 1978 and 1981 respectively were, agents, employees of The Way International.

2. Defendant The Way, International ("The Way") is an Ohio corporation with its principal place of business in New Knoxville, Shelby County, Ohio.

3. At all times pertinent hereto, Defendants LOY C. MARTINDALE ("Martindale"), ROSALIE F. RIVENBANK ("Rivenbank"), JOHN R. REYNOLDS, ("Reynolds"), DONALD E. WIERVILLE ("Wierville"), HOWARD R. ALLEN ("Allen"), RAMONA BIDON ("Bidon") (Collectively "Way Leadership") and JOHN DOES 1-50 are or were officers, directors, employees, agents or trustees of The Way and their acts as described hereinbelow were undertaken and done within the course and scope of their agency for or employment by, and were ratified by, The Way.

BACKGROUND

4. The Way purports to be a religious organization which inculcates a dependent state of mind among its adherents. The Way demands and receives income from its adherents as contributions or from direct employment by the adherents on behalf of The Way.

5. The Way Leadership conducts the business of The Way in such a manner that adherents are encouraged to become economically and psychologically dependent on The Way and the Way Leadership. As a result, the Way Leadership occupies positions of trust in relation to adherents of The Way and each member of The Way Leadership owes adherents of The Way a fiduciary duty.

COUNT ONE

(Breach of Contract)

6. Beginning at the inception of their affiliation with The Way, and continuing throughout, The Way and Way Leadership represented and promised to Plaintiffs Mrs. Allen and Mr. Allen that if they adhered to the principles of The Way, they would be provided with specific financial and material benefits.

7. In reliance on the representations and promises of The Way and Way Leadership, Plaintiffs abandoned their family, friends and employment, underwent training in the "Way Corps" at their own expense, declared bankruptcy, agreed to become full-time employees of The Way and agreed to defer compensation for their services.

8. The Way Leadership and The Way breached their contract with Plaintiffs by creating impossible working conditions including requiring Plaintiffs to submit to sexual assault as a condition of continued employment.

9. As a direct and proximate result of Defendants' breach of their contract, Plaintiffs have been injured and damaged in an amount exceeding Two Million Dollars each.

COUNT TWO

(Assault and Intentional Infliction of Emotional Distress)

10. Plaintiffs incorporate and reallege each allegation contained hereinabove as if fully set forth herein and further state that the Way Leadership Defendants understood that, as a result of the extreme and torturous methods used to control adherents to The Way, (which included fraud, coercive persuasion, sleep deprivation and other forms of physical and psychological abuse), they occupied a position of trust and confidence with respect to Plaintiffs.

11. Beginning in 1996 and continuing thereafter until March 1999, Defendant Martindale, and Defendant Bidon, acting as procuress for Defendant Martindale, wilfully and with malice, began a campaign to coerce Plaintiff Mrs. Allen into engaging in sexual activity with Defendant Martindale. Through the undue influence and psychological control referred to hereinabove, Defendants Martindale, Bidon and others eventually succeeded in sexually victimizing Plaintiff Mrs. Allen.

12. Because of the control which Defendants Martindale, Bidon and the other members of The Way leadership exerted over Plaintiffs, Plaintiff Mrs. Allen was incapable of consenting to such sexual activities.

13. During these times. the Way Leadership Defendants were acting within the course and scope of their agency for The Way and attempted, in their capacity as leaders of The Way, to excuse, justify or conceal their outrageous behavior.

14. As a direct and proximate result of the outrageous conduct of The Way and its Way Leadership, Plaintiffs suffered humiliation, embarrassment, opprobrium and other severe emotional distress.

15. As a direct and proximate result of Defendants' tortious acts as aforesaid, Plaintiffs have been damaged in an amount in excess of Five Million Dollars each.

COUNT THREE

(Fraud in a Fiduciary Capacity; Breach of a Fiduciary Duty)

16. Plaintiffs incorporate and reallege each allegation contained hereinabove as if fully set forth herein and further state that Defendants The Way and the Way Leadership have misused their fiduciary relationship with Plaintiffs to defraud Plaintiffs of money and other things of value.

17. Defendants The Way and the Way Leadership have misused their fiduciary relationship with Plaintiffs to subject Plaintiffs to humiliation for their own personal amusement and gratification.

18. As a direct and proximate result of Defendants' tortious acts as aforesaid, Plaintiffs have been damaged in an amount in excess of Five Million Dollars each.

COUNT FOUR

(Defamation)

19. Plaintiffs incorporate and reallege each allegation contained hereinabove as if fully set forth herein and further state that on March 24, 1999, Rev. Linder, informed Paul that he and his wife had been designated as "mark and avoid" by The Way Leadership.

20. A 'follower' tabbed as mark and avoid is debased, denigrated, accused of being lower than low, untrustworthy, dishonest, dangerous to himself and others, disparaged and all associations with other followers (whether business or personal) terminate by direction of Defendants Way Leadership.

21. The Way Leadership Defendants published to other members of the Way community that Plaintiffs had been designated to be marked and avoided.

22. The statements made were false, Defendants knew them to be false before they were made and Defendants made the statements with the intention to damage Plaintiffs' good name and reputation.

23. As a direct and proximate result of the defamatory statements made, Plaintiffs have been damaged in an amount in excess of Five Million Dollars each.

COUNT FIVE

(Civil Conspiracy)

24. Plaintiffs incorporate and reallege each allegation contained hereinabove as if fully set forth herein and further state that at all times pertinent hereto, Defendants The Way, the Way Leadership and John Does 1 - 50 were acting in concert to achieve an unlawful purpose which would have been impossible for any single defendant to accomplish alone.

25. Defendants' actions were in support and furtherance of this conspiracy

26. As a result of Defendants conspiracy, Plaintiffs have been defrauded of money and other things of value, assaulted, tortured and defamed.

27. Each Defendant knew that his or her wrongful acts were in furtherance of a common purpose or conspiracy.

28. As a direct and proximate result of the civil conspiracy accomplished by Defendants, Plaintiffs have been damaged in an amount in excess of Five Million Dollars each.

COUNT SIX

(Racketeer Influenced and Corrupt Organization)

29. Plaintiffs incorporate and reallege each allegation contained hereinabove as if fully set forth herein and further state that at all times pertinent hereto, Defendants The Way was an "enterprise" as defined in Revised Code §2923.31.

30. Defendants The Way, through the Way Leadership and John Does 1-50 engaged in a "Pattern of corrupt activity" as defined in Revised Code §2923.31.including, but not limited to acts of theft, fraud, coercion, assault and rape.

31. As a direct and proximate result of the pattern of corrupt activity of Defendants, Plaintiffs have been damaged and injured in an amount exceeding Five Million Dollars.

WHEREFORE , Plaintiffs The Allens demand judgment against Defendants, jointly and individually:

in the amount of Two Million Dollars on the First Count of their Complaint;

in an amount to be determined at trial on the remaining counts of their Complaint;

punitive Damages;

attorneys' fees;

and such other and further relief as this Court shall deem just or equitable

JURY DEMAND

Plaintiffs demand trial by jury on all issues.

OF COUNSEL

LAWRENCE LEVY (Cal. Bar. 055845)
Law Offices of Lawrence Levy
14724 Ventura Blvd.
Suite 520
Sherman Oaks, California 91403

JAMES E. BURNS (0037330)
McCarthy, Lebit, Crystal & Haiman Co. LPA
101 West Prospect Ave.
Suite 1800
Cleveland, Ohio 44115