In the third lawsuit filed against the Church of Scientology and its leader, David Miscavige, in three months, a 25-year-old woman alleges she was repeatedly sexually assaulted as a child in Scientology’s care, including at the church’s Clearwater Academy.

On top of the abuse, the lawsuit explains how church officials allegedly knew it was occurring and did nothing to stop it or alert law enforcement, actions rooted in policy written by Scientology founder L. Ron Hubbard.

When the woman spoke of her alleged abuse after leaving Scientology in 2018, the church deployed a campaign of harassment against her, a tactic also based on Hubbard’s Fair Game policy aimed to destroy those labeled as enemies.

According to the complaint filed in Miami-Dade Circuit Court on Wednesday, Scientology operatives cut the brake lines on the woman’s car, vandalized her property, followed and surveilled her, and harassed her with hundreds of spam calls.

The woman is referred to in the complaint only as Jane Doe for fear of more retaliation by the church.

The lawsuit names Miscavige, Scientology’s Flag Service Organization, its Religious Technology Center, Church of Scientology International and Clearwater Academy as defendants against allegations from sexual battery to racketeering and negligence.

With no criminal charges brought upon Scientology despite years of allegations of criminal activity, a team of a dozen victims’ rights attorneys are using civil court to expose the church’s alleged institutional abuses. The team, which filed its first complaint in June, includes a constitutional scholar and a lawyer who successfully prosecuted Bill Cosby on sexual assault charges.

“Scientology may be a religious organization, and they can believe whatever they want to believe, but they can’t do whatever they want to do,” the team’s lead attorney, Brian Kent, told the Tampa Bay Times on Thursday. “They will be subject to the law just as any other organization would be subject to the law.”

Late Thursday, a Los Angeles attorney for the church issued a statement dismissing the claims as a “false, vile complaint” while directly attacking the woman.

“This complaint is just the latest example of anti-religious falsehoods wielded to destroy lives,” stated William H. Forman, litigation counsel for the Church of Scientology International. “The Church will expose this complaint for the disgusting sham and bigotry that it is.”

The statement accused the Jane Doe, without any evidence, of being a “convicted liar who has pled guilty to making a false police report.” The Times is aware of the alleged victim’s identity and has been unable to corroborate any such claim in public records.

The first time Doe was sexually abused in Scientology’s care, the lawsuit states, was during her two kindergarten years at Clearwater Academy on Drew Street in downtown Clearwater.

The lawsuit states that on multiple occasions an employee: forced Jane Doe and other young girls to perform sexual acts on each other; masturbated in front of and ejaculated on Doe; and, on at least one occasion, forced his penis into her mouth.

Doe reported this to adults at the school, but no action was taken to remove the employee or stop the abuse, according to the lawsuit.

The only answer to crimes committed by church members, including sexual assault, is Hubbard’s policy and technology, not law enforcement or the courts, the lawsuit states.

Hubbard’s policies, rolled out following the formation of the Church of Scientology in 1953, teach it is a “high crime” to report a Scientologist to law enforcement. Phones within certain church facilities are incapable of dialing 911, according to the lawsuit.

At age 11, Doe was sent by Scientology to live in Caracas, Venezuela without her parents. The next year she was assaulted by the son of a high-ranking Scientologist at the Caracas Org, a church facility, according to the complaint.

Doe immediately disclosed the assault to her auditor, a person who conducts spiritual counseling sessions. Instead of reporting the assault to law enforcement, the lawsuit alleges church officials “sentenced” Doe to three months of physical labor and issued her a “non-enturbulation” order, which warned she was at risk of losing standing in the church for “bringing in” the sexual assault.

“One who suffers sexual abuse, whether an adult or a child, is assumed to have done something to incite or invite such abuse,” as the lawsuit describes Scientology practices.

After her labor sentence, she was sent back to Clearwater at age 14 to join the Sea Org, the church’s clergy-like workforce where members sign billion-year contracts and work an average of 100 hours a week for little to no wages.

Sea Org children are separated from their parents and assigned a guardian. Doe’s guardian, then a 24-year old woman, “groomed Jane Doe to enter into a sexual relationship with her,” according to the lawsuit.

As a child, Doe could not understand the consequences of her actions and could not consent to a sexual relationship, the lawsuit states. The complaint states church officials should have known the guardian was abusing and prevented the abuse from occurring. But they did not.

Once she escaped Scientology in 2018, Jane Doe was stalked, harassed and followed by church officials – tactics that “went beyond all bounds of decency and the conduct was shocking, atrocious, and utterly intolerable in a civilized community.”

The lawsuit stresses the alleged culpability of Miscavige, Scientology’s leader who took over the organization following Hubbard’s death in 1986.

It describes the Sea Org structure as a human trafficking scheme that benefits Miscavige financially.

Church officials “have made billions off the backs of men, women and children who are trafficked and forced to work 100 hour weeks for far below the minimum wage with little to no free time or vacation under the threat of severe punishment for failure to perform their work duties,” the lawsuit states.

The complaint alleges child Sea Org members like Doe have their food rationed and are subjected to hard labor like asbestos removal and construction. Children are deprived of proper education. And any child or adult who flees or speaks negatively about the church is subject to shunning by parents, relatives and friends through Scientology’s disconnection policy.

“Personal freedoms are restricted, families are separated, and severe punishments are utilized to maintain complete control over the forced workers, including children, in the Sea Org,” the lawsuit states.

Along with Miscavige’s and the
church’s liability for Doe’s abuse, the lawsuit states Clearwater Academy failed in its legal duty to protect students.

The legal team’s first lawsuit filed in June on behalf of another Jane Doe accuses the church of: child abuse related to auditing, where children are interrogated for hours about sexual questions; human trafficking the woman was a part of in the Sea Org; and Fair Game tactics she endured after escaping, including, the church publishing “a hate website” falsely stating she was an alcoholic dismissed from the sect for promiscuity.

The second lawsuit was filed in August against Scientology, Miscavige and actor Danny Masterson on behalf of four women who allege they were raped by Masterson, a parishioner. After they reported the rapes to Los Angeles Police in 2016 and 2017, the lawsuit states Scientology unleashed a campaign of terror to intimidate the accusers.

Kent said he expects his team to file “numerous” complaints this year against Scientology relating to alleged victims of child abuse, human trafficking and harassment.

“Obviously this is a very secretive organization that has policies that you are not to speak publicly about any of the abuses that are occurring,” Kent told the Times. “We want transparency and we want to expose the abuses that are happening.”