1. Plaintiff Donna Burke is the mother of the plaintiffs David Burke and
Scott Burke, who are minors, and appears for both herself and for her minor
sons as their Guardian Ad Litem.  David Burke and Scott Burke were enrolled in
Tranquility Bay from 1997 to 1998.  The Plaintiffs were, at all times
material, and are currently, all citizens of the State of Texas.

2. The Worldwide Association of Specialty Programs is a non-profit
corporation organized under the laws of the State of Utah with its principal
place of business in St. George, Utah, of which Karr Farnsworth is the
Executive Director.  It is an umbrella organization controlling and regulating
all Teen Help programs.  It is the alter ego of each and every other named
entity defendant, being under the control of and responsible to a centralized
governing group of the named individual defendants, among others.

3. Teen Help is a partnership organized under the laws of the State of Utah
and doing business in the State of Utah, nationally, and internationally.  It
is the alter ego of each and every other named defendant, Robert B. Lichfield
being its general partner, and answers to a centralized governing group of the
named individual defendants.  It purports to help the parents of troubled
adolescents find placement in appropriate treatment centers, but, in practice,
only refers such parents to its own stable of youth camps.  It is the
defendants' marketing arm to recruit adolescent inmates for Tranquility Bay,
Paradise Cove, Casa By The Sea, and other off-shore cult camps run by some of
the other defendants.

4. Tranquility Bay is a corporation organized under the laws of the State of
Utah and is doing business within in the State of Utah, nationally, and
internationally.   It sometimes goes by the name of The Caribbean Center For
Change.  It is the alter ego of each and every other named defendant, being
under the control of and responsible to a centralized governing group of the
named individual defendants, among others.  It is one of many closed and
secret cult centers owned and operated by the defendants where adolescents are
impounded, tortured, berated, brainwashed, and otherwise abused by the defendants.

5. Brightway Hospital was at all times material a corporation organized and
licensed under the laws of the State of Utah and was doing business within the
State of Utah.   It is the alter ego of each and every other named defendant,
being under the control of and responsible to a centralized governing group of
the named individual defendants.  It purported to be an adolescent treatment
center which, among other things, conducted psychological evaluations.  In
reality, Brightway was a lock-down facility to which kidnapped adolescents
were transported and held before being placed in and transported to various
cult centers owned and operated by the defendants, among others.  Its
operation was so incompetent that the State of Utah has revoked its hospital license.

6. Dixie Contract Services is a corporation organized under the laws of the
State of Utah and is doing business within in the State of Utah, nationally,
and internationally.   It is the alter ego of each and every other named
defendant, being under the control of and responsible to a centralized
governing group of the named individual defendants, among others.  It hires
and directs so-called escort services to kidnap adolescent candidates from
their homes, often in the middle of the night, and take them by force to
Brightway hospital for psychological screening and passport procurement before
being transported abroad.

7. R & D Billing is a corporation organized under the laws of the State of
Utah and is doing business within in the State of Utah, nationally, and
internationally.   It is the alter ego of each and every other named
defendant, being under the control of and responsible to a centralized
governing group of the named individual defendants, among others.  It bills
and collects exorbitant fees charged by the various Teen Help cult centers by
misrepresenting to insurance companies that the Teen Help programs are either
therapeutic or educational depending on the coverage available.

8. Resource Realizations is a corporation organized under the laws of the
State of Utah and is doing business within in the State of Utah, nationally,
and internationally.  It is the alter ego of each and every other named
defendant, being under the control of and responsible to a centralized
governing group of the named individual defendants, among others.  It plans
and conducts the behavior modification seminars for inductees and their
parents, which modifies the values and impairs the psychological health of
both groups.

9. Robert B. Lichfield is an owner, partner, shareholder, or otherwise
directs the conduct and activities of each and every named corporate or
partnership defendant.

10. Karr Farnsworth was, at all times material, an owner, partner,
shareholder, or otherwise directed the conduct and activities of each and
every named corporate or partnership defendant.

11. Brent M. Facer was, at all times material, an owner, partner,
shareholder, or otherwise directed the conduct and activities of each and
every named corporate or partnership defendant.

12. Jay Kay was, at all times material, the director of Jamaica Bay, and an
owner, partner, shareholder, or otherwise directed the conduct and activities
of each and every named corporate or partnership defendant.

13. Jean Davis, a citizen of Jamaica, was, at all times material, an employee
of some or all of the other defendants, and the director of Jamaica Bay III.

14. Lorraine Black, a citizen of Jamaica, was, at all times material, an
employee of some or all of the other defendants, and the case worker assigned
to Scott Burke.

15. Delbert Goates, M.D. was, at all times material, a citizen of the State
of Utah, and a psychiatrist attached to Brightway Hospital.  He purported to
screen enrollees into the Teen Help programs, but routinely rendered services
of no value for which he separately billed the parents abandoning their
children to Teen Help amounts in addition to the exorbitant fees they were
already paying.  Furthermore, he routinely allowed into the program young
people who either were ineligible under any standard to be incarcerated by the
defendants or who were so mentally ill that they should have been hospitalized
someplace clinically sound.

16. David Gilcrease was, at all times material, a citizen of the State of
Utah, and the director of Resource Realizations, Inc.  He is an owner,
partner, shareholder, or otherwise directed the conduct and activities of each
and every other named corporate or partnership defendant.  He runs
introductory secret TASK seminars designed to brain wash the child and use him
to recruit the parents into the program.  If the parents refuse to participate
in the seminars, they are not allowed to talk to their children who have
participated.  Due to the seminars, the children become co-dependent upon the
defendants, and so do the parents once they attend.  If the parents do not
attend, their children, due to the dogmas taught, perceive themselves as elite
and isolated from their parents, and come to belong to the defendants more
than they belong to their parents.

17. Doe defendants I through X are persons unknown to the plaintiffs but who
will be added to the complaint when their identity is ascertained.

18. In all things herein alleged and at all times material, all defendants
were acting as agents for or joint venturers with the other defendants.

JURISDICTION

19. Jurisdiction of this Court is invoked pursuant to 28 U.S.C. §§ 1331 and
1332(a)(1).  The matter in controversy exceeds the sum of Seventy Five
Thousand Dollars, exclusive of interest and costs.

VENUE

20. Venue is appropriate in this Court pursuant to the provisions of 28
U.S.C. § 1391(a) and (c).

FACTS

21.  Donna Burke was, in 1997, a single mother of two sons, David, aged 16
years, and Scott, aged 14 years.  She had been previously divorced from her
wealthy husband, David Burke, who goes by the name "Stoney".   His new wife,
Lynda, was, at all times material, a family law judge in Houston, Texas. 
Defendants have exploited her judicial position by retaining her as one of
their recruiters. 

22. Shortly before August, 1997, Scott Burke, then living with his mother,
had begun to experiment with marijuana and engage in minor truancies.  Donna
informed Stoney of this behavior, and encouraged him to take greater part in
their son's life.  In response, Stoney, without telling Donna, obtained a
custody order from family court which he delivered to defendants, directing
them to abduct Scott by force from his middle school while it was in session
into the Teen Help program.

23.  In August, 1997, they did so, and took Scott to Brightway Hospital,
where they forcibly detained him on the pretext of psychological evaluation
while they speedily got his passport.  Dr. Goates, meanwhile, administered
medications to keep Scott from fighting back. 

24.  Donna was frantic that her son Scott had suddenly disappeared from
school and was nowhere to be found.  She eventually learned that he had been
abducted into Teen Help.  When she finally discovered that he had been taken
out of the country to Jamaica, she tried by telephone to contact him, but was
told by defendants, both in Utah and Jamaica, that she would not be allowed
any contact.  She then resorted to writing letters, but later learned that not
one of them had been delivered to Scott.

25. Donna then began to fear that the same fate awaited her older son, David.
 In contrast to Scott, David was a model son, obedient to all rules,
respectful of authority, an "A" student, and a star soccer player at his high
school.  David, however, had been ill as a result of an Epstein-Barr virus
which had sidelined him for a year. 

26. In November, 1997, Defendants, at Stoney's behest and again, without
notice to Donna, abducted David by force from his high school while it was in
session and took him to Brightway Hospital.  There, Dr. Goates could plainly
see that David had no behavioral or psychological problems that would warrant
his being in the Teen Help program.  Defendants, however, once in possession
of David's passport and his father's money, shipped him off to Jamaica as
well.  

27. Both David and Scott had already suffered from years of their father's
abuse caused by alcohol.  David's response had been to become totally obedient
and to achieve the highest standards, with which he father was never
satisfied.  Scott rebelled, and had begun to act out his frustrations over his
father's abandonment. 

28. As if these two fine young men had not suffered enough, Defendants began
to heap upon them the most sadistic and unwarranted physical and psychological
abuse.   Defendants subjected them to a steaming squalid jungle camp infested
with flies, mosquitoes, scorpions, and vermin.  The food was primitive,
filthy, and meager.  The so-called case workers were untrained, unlettered,
and uncredentialed natives.  Hygiene consisted of bathing by garden hose
without soap.  There was no ventilation in the buildings.  There was no
protection outdoors from the sun.  Scott and David, both fair skinned, were so
burned that their skin was cracking.   Defendants deprived David of his ulcer
medication and Scott's of his Attention Deficit Disorder medicine.  The boys
slept upon mattresses with no sheets with no protection from the swarms of
insects.  They were covered with bites.

29.  Worse still was the psychological abuse, by which punishment was meted
out for infractions so minor as to sink to the level of dementia.  The merest
glance away from one's paper in class, or moving without permission could
result in severe punishment such as being forced to lie on the floor for 24
hours without bathroom privileges and without letting one's chin touch the
floor.  Monitors were everywhere, and there was never any privacy.  Donna was
not allowed to telephone.  Her mail never reached the boys, and their's to her
reflected predictable nothingness. 

30. Whereas, from Defendants' video advertisement, Donna initially thought
that there might be some merit in Scott's being at Tranquility Bay, David's
abduction made no sense whatsoever, and finally woke her to the fact that
something was wrong.  David's friends held a car wash to raise money for her
airfare to Jamaica.

31. She went with her brother in March, 1998.  There, she saw first hand the
terrible condition of her sons, their surroundings, food, and the prison
environment in which they were subsisting.   After traveling several hours by
plane and five hours by taxi, she arrived to a most stilted visit.  A staff
member lurked within five feet so that there was no privacy.  After only four
hours, when she was forced to leave, her sons clinged to her, begging her not
to go.

32. Her custody fight with Stoney proceeded in the Houston courts.  Walter
Mahoney, the court-appointed counsel for Scott and David, went to visit them
in Jamaica, but spent no time with them and did nothing to get them out of the
program.  The court-appointed psychologist, Richard Austin, Ph.D., was no more
effective. 

33. About this time, David Van Blarrigan's attempt to free himself from
Tranquility Bay hit the news.  Donna was galvanized by the plight of other
captives.  She became militant and determined to rescue her sons.   In August,
1998, she returned unannounced to Jamaica with a female colleague.  They got
by the guard at the barbed wire compound called Tranquility Bay III, in a
valley 45 minutes from the seaside compound.  She saw the bedraggled young men without shoes and covered with bites, rashes, and chemical burns.  Being away from the coast the heat was stifling, even for a Houston resident.  The smell
of raw sewage was overpowering.  Donna reprimanded the director, Jean Davis,
for allowing such conditions.  The behavior of some captives showed should
have been hospitalized in mental institutions.  Others, like David, should not
have been there at all. 

34.  At the hotel, Donna met a woman who was taking her son out.  Donna
returned and demanded that her sons be released to her.  Tranquility Bay
personnel telephoned Stoney, who refused.  Lorraine Black, Scott's case
worker, who was uneducated, told Donna, who is highly educated, that she was
crazy and was the reason that her sons were in the program.  The entire
compound, and especially her sons, were punished for Donna's disruption as a
warning to parents who show up without permission and unannounced. 

35.  The boys were allowed telephone communication with their father, but not
with their mother.  Defendants further breached the biological family unit by
appointing among the native staff "fathers" and "mothers" and organizing
groups of captives into "families".  These surrogate parents, by demanding the
strictest obedience to their every whim, engendered the co-dependence upon
which the program thrives, further breaking the will and spirit of Donna's two
sons.  When she left this time, Scott slipped a note in her pocket asking to
come home.   When this note got to the family law judge, and then, through
counsel, to Stoney, he notified Tranquility Bay, and Scott was punished.

36. David was released on November 30, 1998, and Scott on December 23, 1998. Both are changed from the wonderful, spontaneous young men that they were before Tranquility Bay into robotic victims, afraid of any authority figure.
They have lost their individuality, their spirits are broken, and their
characters ruined.  Instead of independent men, they are afraid, haunted by
nightmares, subject to panic attacks, and refuse to go anywhere near a beach.
If a voice is raised, they dissolve in fear.  They never voice an opinion of
their own, fearful that it might not find approval.   Even if they are
troubled or sad, they mask it by saying that everything is fine.  They no
longer feel.  If Defendants broke an occasional bad habit, they did it by
breaking the lad himself.

37. Whereas Donna had raised these young men with no help from an absent,
alcoholic father, and was their mainstay throughout their adolescent years,
they now regard her as powerless.  Defendants took them from her and she could
not get them back.  They became dependent on Defendants instead of their
mother, and Defendants destroyed Donna's relationship with her sons.  Now,
they trust no one, not even God.

FIRST CAUSE OF ACTION
(Negligence)

38. Defendants owed Plaintiffs a duty to screen David and Scott in order to
protect them from induction into a boorish and brutal program whose rigors
might foreseeably injure them.  Defendants breached their duty by failing to
screen the boys  out of their program and, to the contrary, by admitting them
into a program which they knew, or should have known, would be detrimental to them.

39. Defendants owed Plaintiffs a duty to consult some reputable psychiatrist
to see whether or not the boys should even be in a sadistic program of this
nature. 

40. Defendants owed Plaintiffs a duty not to induct the boys into their
program unless and until they had the informed consent of both parents having
legal custody of the boys.

41. Defendants owed Plaintiffs a duty to employ, or at least engage,
professionals qualified to address any specific needs which legitimately
justified the boys' induction and retention into such a program.

42. Defendants breached their duty by inducting the boys into their demented
program, by failing to engage quality professional help, and by punishing the
boys as criminals instead of addressing any specific need justifying their
presence at Tranquility Bay.

43. Defendants' conduct proximately caused the boys personal injury and
emotional distress from and after their 1998 induction to date.  Defendants
conduct foreseeably and proximately caused Donna Burke grievous emotional
distress over the welfare and safety of her sons and cost her many thousands
of dollars to fund the benighted treatment they received, the emotional scars
from which will probably last a life time.

44. Defendants' conduct was malicious, wanton, and in reckless disregard of
the boys' health, safety and welfare, by reason of which they are entitled to
recover punitive damages against them.
WHEREFORE, Plaintiffs pray for judgment as hereafter stated.

SECOND CAUSE OF ACTION
(Negligent Child Abuse)

45. Plaintiffs incorporate by this reference paragraphs 1 through 37 as if
stated in full.

46. Defendants, while having the care, custody and control of the boys  as a
surrogates for their mother, had a duty to promote their health, safety, and
welfare.  Instead, Defendants breached their duty to the boys by isolating
them  and keeping them  prisoner in Jamaica where:

a. they negligently removed them  from the United States without mother's consent,

b. they negligently subjected them  to conditions and circumstances likely to produce great bodily harm,

c. they negligently inflicted upon them unjustifiable physical pain and
mental suffering.

d. They negligently caused them  to suffer pain, thirst, fatigue, and
confinement.

e. they negligently caused or permitted them  to be injured and infected,
and

f. they negligently caused and permitted them  to be placed in such a
situation that their emotional and physical health was endangered and impaired.

47. Defendants conduct proximately caused Plaintiffs personal injury and
emotional distress.

48.  Defendants conduct was malicious, wanton and in reckless disregard of
the boys' health, safety and welfare, by reason of which they are entitled to
recover punitive damages.

WHEREFORE, Plaintiffs pray for judgment as hereafter stated.

THIRD CAUSE OF ACTION
(False Imprisonment)

49. Plaintiffs incorporate by this reference paragraphs 1 through 37 as if
stated in full.

50. The boys learned upon arrival at Tranquility Bay that their mother was
unaware of its purpose and program.  They sought at that time to communicate
with her and to leave the program, but Tranquility Bay censored their mail,
restrained them  from any contact with the outside world, and refused to
permit their return home.

51.Tranquility Bays imprisonment of the boys without adjudication  caused
them serious and permanent emotional distress, and psychological injury.

52. Tranquility Bay's conduct was malicious, wanton and in reckless disregar
of the boys' health, safety and welfare, by reason of which they are entitled
to recover punitive damages.

WHEREFORE, Scott and David pray for judgment against Defendants as hereafter
stated.

FOURTH CAUSE OF ACTION
(Intentional Infliction of Emotional Distress)

53. Plaintiffs incorporate by this reference paragraphs 1 through 37 as if
stated in full.

54. Tranquility Bay's philosophy of tormenting and intimidating the boys,
invading their privacy, depriving them  of nutritious and wholesome food,
proper sanitation, educational opportunities, exposing them to denigrating
immoral and filthy conditions, subjecting them to imprisonment, attempting to
break their will, inflicting unjust punishment, depriving them of legal
rights, keeping them in isolation, depriving them of the care, comfort,
support, and sustenance of their mother, and other demented conduct, caused
the boys  personal injury and mental and emotional distress.

55. Defendants' conduct in depriving the boys of their mother's society,
companionship, and communication caused them grief, anxiety and worry.

56. Defendants' conduct was in reckless disregard of Plaintiffs' health,
safety and welfare, by reason of which Plaintiffs are entitled to recover
punitive damages.

WHEREFORE, Plaintiffs pray for judgment as hereafter stated.

FIFTH CAUSE OF ACTION
(Breach of Fiduciary Duty)

57. Plaintiffs incorporate by this reference paragraphs 1 through 37 as if
stated in full.

58. By seeking, and obtaining physical custody of the boys   from their
mother, and thereafter, by placing them and retaining them in a captive and
abusive environment of their own making, Defendants undertook a fiduciary duty
toward the boys to protect and promote their health, safety and welfare.

59. Defendants, in the manner described above, breached their fiduciary duty
as a parental surrogates, which proximately caused the boys to sustain pain,
suffering, bodily injury and mental and emotional distress, and caused the
boys great mental and emotional anxiety.

60. Defendants' conduct was malicious, wanton and in reckless disregard of
Plaintiffs trust and of the boys' health, safety and welfare, by reason of
which Plaintiffs are entitled to recover punitive damages.
WHEREFORE, Plaintiffs pray for judgment against Defendants as hereafter stated.

SIXTH CAUSE OF ACTION
(RICO)

61. Plaintiffs incorporate by this reference paragraphs 1 through 37 as if
stated in full.

62. As part of a scheme and artifice to defraud, and as a means by which
Defendants could obtain money from families having sons about whose
associations, values, study habits, or good citizenship they were concerned,
Defendants falsely represented to the boys' mother that they were adept in
behavioral modification for teenagers; that inductees would have one-on-one
support and guidance by trained and caring counselors; and that the program
was safe, wholesome, positive, and beneficial.  Defendants concealed that the
program was cultist, coercive, and criminal.

63. Defendants further made these misrepresentations and indulged in these
concealments not only to Donna, but to the boys, and the parents of numerous
other young men inducted into Tranquility Bay. 

64. None of the above stated representations was true, but instead all of
the above stated representations were false, and were made to the parents of
the young men inducted or kidnapped into the Tranquility Bay program with the
intent and for the purpose of causing the parents to pay Defendants large
amounts of money per month per boy enrolled, even though the cost for the
services rendered was negligible and the services themselves were demented,
dangerous, and detrimental.

65. The excessive amount charged by Defendants for the privilege of abusing
David and Scott Burke,  and other young men, was fraudulent in that it was
both far in excess of the actual costs incurred for the abuse meted out, but
was fraudulent as well in advancing the ruse that Defendants were providing a
therapeutic, social, and educational experience approximating in value the
monthly amount charged, including normal operating and overhead expenses.

66. Tranquility Bay always reported to Donna Burke and other parents over
telephone lines that her sons were enjoying the program when in reality,
Defendants knew that the respective parents' sons were being tormented and
abused by Tranquility Bay so as to become no better than obedient dogs, and
worse off than when they came into the program.  Notwithstanding such
knowledge, Defendants continued to market Tranquility Bay as a positive and
wholesome experience, and paid  returning survivors of the program to recruit
other parents and their sons to Tranquility Bay by misrepresenting the nature
and benefits of the program.  Defendants made all of the above-referenced
fraudulent and untrue statements knowing them to be untrue or knowing that
they had no information to support the truth of their statements.  This, they
did for the purpose and toward the end that the parents of the enrolled and
captive children would not withdraw their children from the program, but
instead, would continue to pay the excessive fees charged by Tranquility Bay
for keeping their children in the program.  

67. All of Defendants' concealment, propounded falsities, and
misrepresentations of true facts were made by telephone or by letters sent
through the United States mails.  All of Tranquility Bay's remittances and
payments obtained by Defendants' fraudulent representations were received
through the United States mails across state lines. 

68. Defendants' knowing and intentional failure to disclose material facts
and their deliberate misrepresentation of material facts in conjunction with
the telephone conversations and letters, checks and other remittances sent
through the United States mails described above constitute repeated violations
of 18 USC §1342 relating to wire fraud and 18 USC §1341 relating to mail
fraud, and further constitute acts of racketeering activity as that term is
defined in 18 USC §1961(1)(b).

69. Defendants are capable of holding a legal or beneficial interest in
property and are persons subject to the Racketeer Influenced and Corrupt
Organizations Act pursuant to 18 USC §1961(3).

70. The individual defendants were associated in fact through their
management and operation of Tranquility Bay and its alter ego entities, which
association in fact constituted an enterprise as the term enterprise is
defined in 18 USC §1961(4).

71. During all relevant time, Tranquility Bay was an enterprise as the term
enterprise is defined in 18 USC §1961(4).

72. During all relevant time, the individual defendants constituted an
enterprise as the term enterprise is defined in 18 USC §1961(4).

73. The wire frauds and mail frauds perpetrated by the defendants upon the
plaintiffs constituted a pattern of racketeering activity consisting of more
than two acts of racketeering activity, all of which occurred after the
effective date of 18 USC §1961 et seq.

74. Defendants used income derived from the above-described pattern of
racketeering in the operation of their enterprises, the activities of which
affected interstate commerce, in violation of 18 USC §1962(b).

75. The individual defendants acquired and maintained control of the
enterprise, the activities of which affected interstate commerce, in violation
of 18 USC §1962(b).

76. Defendants conducted or participated in the conduct of the enterprise
through the above-described pattern of racketeering activity which
enterprise's activities affected interstate commerce in violation of 18 USC §1961(c).

77. Defendants conspired with each other to violate 18 USC §1962 (a), (b),
and (c) in violation of §1962(d).

78. As a direct and proximate result of the foregoing violation of 18 USC
§1962 by Defendants, the Plaintiffs have sustained injury to their family and
property in an undetermined amount believed to be in excess of $500,000, plus interest.

WHEREFORE, Plaintiffs pray for judgment against Defendants as hereafter stated.

SEVENTH CAUSE OF ACTION
(Negligent Infliction of Emotional Distress)

79. Plaintiffs incorporate by this reference paragraphs 1 through 37 as if
stated in full.

80. Defendant parental surrogates had a duty not to injure the boys , either
physically or psychologically, but to instruct, educate, and promote their
physical and psychological well-being consistent with Defendants
representations to their mother and their statutory surrogate duties.
Defendants, however, negligently placed the boys  in their own confined
environment peopled by sadistic, controlling, untrained persons of low
intelligence posing as counselors who, without cause, berated, tormented,
ridiculed, belittled, scolded, deprived, and demeaned the boys  so as to make
them  a compliant supplicant of Tranquility Bay, and thereby either capture
their loyalty or coerce them  by fear and threats into supporting Tranquility
Bays fraudulent scheme to profit from the misery it inflicted upon the boys
and other minors within its control.

81. Defendants' conduct was malicious, wanton, and in reckless disregard of
the boys' health, safety and welfare, by reason of which Plaintiffs are
entitled to recover punitive damages.
WHEREFORE, Plaintiffs pray for judgment as follows:

FIRST CAUSE OF ACTION FOR NEGLIGENCE:
a. Special damages according to proof.
b. General damages according to proof
c.  Punitive damages according to proof

SECOND CAUSE OF ACTION FOR NEGLIGENT CHILD ABUSE:
a. Special damages according to proof.
b. General damages according to proof
c. Punitive damages according to proof

THIRD CAUSE OF ACTION FOR FALSE IMPRISONMENT:
a. Special damages according to proof.
b. General damages according to proof.
c. Punitive damages according to proof.

FOURTH CAUSE OF ACTION FOR INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS:
a. Special damages according to proof.
b. General damages according to proof.
c. Punitive damages according to proof.

FIFTH CAUSE OF ACTION FOR BREACH OF FIDUCIARY DUTY:
a. Special damages according to proof.
b. General damages according to proof.
c. Punitive damages according to proof.

SIXTH CAUSE OF ACTION FOR RICO VIOLATIONS:
a. Special damages according to proof.
b. General damages according to proof trebled.
c. Punitive damages according to proof.
d. Attorneys fees according to proof.

SEVENTH CAUSE OF ACTION FOR NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS
a. Special damages according to proof.
b. General damages according to proof.
c. Punitive damages according to proof.
Dated: April 29, 1999
____________________

REFERRALS: CAICA is not a referral agency. CAICA does not refer to or promote facilities or transport companies for children or teens. CAICA warns parents that the parent pay / parent choice programs ie. Residential Treatment Centers, Therapeutic Boarding Schools, Behavior Modification Programs, Christian Programs, Positive Peer Culture Programs, etc., are not regulated by the Federal Government and that it is a "Buyer Beware" industry. CAICA provides the following for parents: Message to Parents, Help for Distraught and Desperate Parents, and Questions to Ask and Warning Signs.

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