Here's the wrongful death lawsuit against Scientology by the family of Whitney Mills

In December 2022 we first broke the news of the tragic death of 40-year-old Whitney Mills, a troubled Scientologist who ended her life with violence.

We reported that story from police reports that left a lot of questions unanswered.

Today, Tracey McManus at the Tampa Bay Times describes a wrongful death lawsuit filed in May by Whitney’s mother, Leila, and we encourage you to read Tracey’s description of it and the way she puts in context with another famous death associated with Scientology’s Flag Land Base in Clearwater, Florida, the 1995 demise of Lisa McPherson.

And we’re posting the lawsuit itself here for you to go over. This is going to be a very interesting case to watch develop in the coming months.

COMPLAINT FOR WRONGFUL DEATH

Plaintiff, LEILA MILLS, the duly appointed Personal Representative of the Estate of Whitney Mills, deceased, on behalf of herself and all other potential beneficiaries, brings this action against the Defendants, CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC., a Florida not for profit corporation, CHURCH OF SCIENTOLOGY FLAG SHIP SERVICE ORGANIZATION, INC., a Delaware not for profit corporation, CHURCH OF SCIENTOLOGY MISSION OF BELLEAIR, INC., a Florida not for profit corporation, CHURCH OF SCIENTOLOGY OF TAMPA, INC., a Florida not for profit corporation, CHURCH OF SCIENTOLOGY INTERNATIONAL, a California not for profit corporation, INTERNATIONAL ASSOCIATION OF SCIENTOLOGISTS ADMINISTRATIONS, INC., a Delaware corporation (collectively, the “Scientology1 Defendants”).

JURISDICTION, VENUE AND PARTIES

1. This is an action under the Florida Wrongful Death Act and/or any other law this Court may deem applicable for damages in excess of fifty thousand dollars ($50,000), excluding interest, costs, and attorneys’ fees.

2. Venue is proper in this Court pursuant to section 47.011, Florida Statutes, because the cause of action accrued in Pinellas County, Florida, and Plaintiff and at least three of the Defendants are residents of Pinellas County, Florida

3. Whitney Mills, the Decedent, passed away on May 13, 2022. At all times material, Mills was a resident of Pinellas County, Florida, residing at 1100 Cleveland Street, Apartment 202 Clearwater, Florida 33755.

4. Plaintiff Leila Mills is Whitney Mills’ mother, the personal representative of the Estate of Whitney Mills, and at all times material was and is a resident of Pinellas County, Florida, and otherwise is sui juris.

5. Plaintiff Leila Mills bring this action for the decedent’s wrongful death in a representative capacity on behalf of all potential survivors and/or beneficiaries, including but not limited to the following: a. Leila Mills; b. The Estate of Whitney Mills; and c. Any other survivors or individuals entitled to recover as a matter of law.

6. At all times material, Defendant Church of Scientology Flag Service Organization Inc. (“FSO”), was and is an active Florida not for profit corporation with a principal place of business at 503 Cleveland Street Clearwater, Florida 33755. Mills was a member of FSO. FSO’s operations include two primary functions: management and administration of Scientology’s auditing process (described in detail below), and ownership, management and operation of Scientology’s substantial real property holdings in Clearwater, Florida (“Flag Base”). Flag Base is Scientology’s global hub of operations and its largest source of revenues, providing (among other things) temporary quarters for visiting Scientologists, facilities for classes and auditing sessions, dining and meeting facilities, and the center where the Scientology Defendants host large gatherings. As with the other Defendant entities, Flag Base is staffed by members of Sea Org, who live in dormitories at Flag Base.

7. At all times material, Defendant Church of Scientology Flag Ship Service Organization Inc. (“Flag Ship”), was and is an active Delaware not for profit corporation with a principal place of business at 118 N. FT. Harrison Ave. Clearwater, Florida 33755. Flag Ship operates the Freewinds, a Scientology ship, and recruits and employs Sea Org members to work on its crew, and it collects fees from members of the International Association of Scientologists for courses, services, and programs they participate in on the ship. Mills paid for and participated in the Freewinds cruise in May 2019 and attested to the highest level of OT 8 aboard the ship.

8. At all times material, Defendant Church of Scientology Mission of Belleair, Inc. (“Belleair”), was and is an active Florida not for profit corporation with a principal place of business at 1601 West Bay Drive, Belleair Bluffs, Florida 33770. Upon information and belief, Mills was a member of Belleair.

9. At all times material, Defendant Church of Scientology of Tampa, Inc. (“Tampa”), was and is an active Florida not for profit corporation with a principal place of business at 1300 East 8th Avenue, Tampa, Florida 33605. Tampa was and is a Class V organization within Scientology, owned and controlled by FSO. Unlike Sea Org members, Tampa staff members have two-year contracts and do not have to live on base.

10. At all times material, Defendant Church of Scientology International (“CSI”), was and is a California nonprofit corporation, with headquarters in Los Angeles, California. CSI licenses Scientology’s IP to numerous Scientology-affiliated entities and organizations, which pay CSI licensing. CSI conducted substantial business at its “spiritual headquarters” in Clearwater, Florida, known as Flag Base, which includes the 172,000 square foot Oak Cove, the 267,000 square foot Fort Harrison, and the centerpiece of Flag Base, the 377,000 square foot Flag Building, the largest building in Clearwater. CSI oversees and controls FSO. Mills was a member of CSI.

11. At all times material, Defendant International Association of Scientologists Administrations, Inc. (“IASA”), was and is a Delaware corporation headquartered in Los Angeles, California, with offices and operations in Clearwater, Florida, at 210 S. Fort Harrison Avenue Clearwater, FL 33756. IASA is the fundraising arm. It is the operating entity for the International Association of Scientologists (“IAS”), an unincorporated membership association that all persons who participate in Scientology are required to join. All Scientologists are members of IAS and are required to pay annual dues to IASA, which administers and transfers those funds (and other payments solicited by IAS) for the benefit of Defendants Flag, Flag Ship, CSI, and other Scientology-affiliated entities, organizations, properties, and enterprises. Mills was a member of IAS and IASA.

12. All conditions precedent to the filing of this action have occurred, are deemed waived, excused, or are otherwise satisfied.

GENERAL ALLEGATIONS APPLICABLE TO ALL COUNTS

13. This action arises out of the tragic death of Whitney Mills, a 40-year-old Clearwater resident who took her own life. On May 12, 2022, Mills attempted to set herself on fire before inflicting herself with a gunshot wound.

14. Mills was a high-ranking member of Scientology, having paid IASA and the other Scientology Defendants hundreds of thousands of dollars to attain here status. The Scientology Defendants brainwashed her into believing that mental health professionals, including psychologists and psychiatrists, and related medical treatments, such as antidepressants and other prescription drugs, were unnecessary and abhorrent. Upon learning of her problems, the Scientology Defendants took control of Mills’ medical care, thus foreclosing her from obtaining the exact treatment she needed, and sending her to an alternative medicine doctor who misdiagnosed her with cancer and Lyme Disease and extorted her for a series of alternative treatments of little to no utility for a person suffering from severe depression and anxiety. Everything foisted upon Mills by these Defendants was outside the field of mental health treatment, and everything failed. She was at her wit’s end. Precluded from seeking the appropriate help, she felt she had no other choice. But for the fact that the Scientology Defendants, including their agents and employees, co-opted her care, her life, her monitoring and supervision, Mills would not have self-harmed. Not only did they not properly care for her, contrary to the duty they undertook, they actually suggested that she “drop the body.”

15. More specifically, while undergoing an urgent mental health crisis that commenced with two visits to the emergency room in December 2021 and January 2022, FSO members of the Sea Org ordered that Mills be “quarantined” starting in February 2022, not allowing her to step foot on their massive Clearwater Flag Base and put her on a 24/7 “watch,” or a Type 3 watch, pursuant to which she was assigned at least three caretakers who lived with her and handled her medical needs, while at all times reporting back to FSO.

16. Mills was told by her handlers that there was a Scientology assist where she could “drop the body,” where her spirit or “operating thetan” would leave her body to inhabit another, causing the original body to die. Mills’ text messages show that she “asked for that assist.” The Clearwater Police Department report says that, at the suggestion of one of her Scientology caretakers, she spoke to the “D of P” for an “assist reference suicide.” Her handlers and the Scientology Defendants were aware she had suicidal ideation and failed to prevent it, contrary to the duty they assumed to care for her, supervise her and protect her from herself.

17. Worse yet, if they actually assisted in the suicide, if they actually gave her the “drop the body” assist that was discussed, then they are guilty of homicide. See Fla. Stat. § 782.08 (“Every person deliberately assisting another in the commission of self-murder shall be guilty of manslaughter”). Unfortunately, the Clearwater Police Department’s investigation of this incident was inadequate to say the least, creating more questions than answers. They failed even to ascertain where Mills obtained the gun, saying only “A pawn check came back negative for Mills buying any weapons.” In addition, the caretaker who suggested the “drop the body” assist to Mills, Albertina Mejias-Harvey, was not properly interrogated by the police. A Spanish speaker with enough English to communicate with Mills (a non-Spanish speaker), the police said they could not interrogate her due the “language barrier.” Based on the police report, it also appears the police did not interrogate the “D of P,” whom they reference in the report as having been the recipient of the assist request.

18. While understanding the inner workings and teachings of Scientology are instrumental to understanding the events leading up to Mills’ tragic death, clear liability exists in law for those who assumed a duty to protect Mills from herself. Mills’ medical treatment was thoroughly documented by the Scientology Defendants in her auditing files, and her caretakers lived with her around the clock and were intimately involved in her medical treatment.

19. After her two visits to the emergency room at Morton Plant in December and January, on January 27, 2022, a Sea Org member at FSO named Tristan wrote to Sue Minkoff at Lifeworks Wellness Center seeking “Assistance with Whitney Mills – New OT VIII,” specifically requesting her assistance in getting Mills in to see Dr. David Minkoff (“Minkoff”), owner and founder of Lifeworks. For the last three months of her life, Minkoff was Mills’ treating physician. He is also a high-ranking Scientologist whose Florida license was suspended for a year due to his treatment of Lisa MacPherson. Among many other things, Minkoff misinformed and misdiagnosed Mills with Lyme disease and a cancerous ovarian cyst, while largely ignoring her very real psychosis and mental health crisis. Instead of properly treating her, over the three months, Minkoff charged her over $20,000 for highly questionable, “alternative” treatments, not one of which was covered by insurance or was of any use whatsoever to Mills. Minkoff failed to perform a differential diagnosis on Mills. Had he done so, he would have learned that she did not have Lyme Disease and did not have a cancerous, life-threatening cyst, but rather a benign one (as later revealed by her autopsy). Minkoff also failed to refer Mills to a mental health care professional or prescribe appropriate medication to Mills. Minkoff put his beliefs in Scientology above his Hippocratic oath and above his duties as a licensed physician in Florida.

20. Medical experts hired by Mills’ estate have opined that Mills was actually suffering from a bout of severe depression rather than any specific ailment, and Minkoff had a duty of care to refer Mills to a mental health professional, even if his religious beliefs forbade it.

21. The Scientology Defendants, in particular FSO Sea Org members and Tampa staff members, who interacted with Mills on a regular basis, undertook the duty to care for Mills, reviewing and administrating her medical care and providing three around-the-clock caretakers for Mills. These caretakers not only failed to prevent Mills’ suicide but also encouraged it. Their names are Nieves Lopez, Albertina Mejias-Harvey (an OT 8 field auditor) and Carissa Hart. The caretakers were either Sea Org members at FSO, staff members at Tampa or members of Belleair, or they were members of all three or a combination thereof. 22. Lopez lived with Mills in her one-bedroom apartment, occupying the bedroom while Mills slept on her sofa. When Lopez was not available, Mejias or Hart would fill in, accompanying her or staying with her. On the date of Mills’ death, Lopez had woken up in Mills’ bed and was with her most of the day. 23. Prior to that, on April 20, 2022, Mills sends Lopez the following text messages: I feel horrific, I can’t take it anymore!

[I]t’s too brutal. I need relief.

I don’t understand why I’m not getting any relief in my brain.

My brain is so inflamed. I’m so annoyed, I just want this to go away.

I just can’t take it anymore, it’s beyond brutal! I have it the worst.

I literally can’t take it anymore, this is beyond brutal!

I wish I had a time machine.

24. Mills’ increasing desperation is palpable, as additional texts from April 20, 2022, demonstrate. Referring to what she believed to be the onset of Lyme disease, Mills continues: “I wish it wasn't in my brain. It's so annoying that I have it so bad, and so bad mentally. The d of p wants me to come in for an interview.” The “d of p” refers to the director of processing, a Sea Org member at FSO.

25. Lopez responded, “A d of p is good,” to which Mills replies, “I said something really dumb on the phone.” Lopez responds, “Oh oh. What did you say.” Mills responds by revealing to Lopez a conversation she had with another one of the Scientology caretakers assigned to her, Albertina Mejias-Harvey, “Albertina told me there’s an assist for someone that is really sick and to drop the body. I asked for that assist.” Lopez responds, “Oops..” Mills replies, “I think I’m in trouble now.” Lopez, referring to FSO and possibly some of the other Scientology Defendants replies, “They know you’re desperate with this ongoing situation.”

26. Mills asked for an assist to kill herself, and Lopez responds “Oops.” She does not persuade her not to do it, to the contrary. Mills worries she might be in trouble for asking for that type of assist, and Lopez’s response is, not to worry, they “know you’re desperate.” Mills’ other caretaker, Mejias, an OT 8 who would have been privy to information about a “drop the body” assist, actually suggests it to Mills.

27. Prior to this exchange with Lopez, on April 17, 2022, Mejias asks Mills to call her, after which Mills sends to Mejias the v-card for “Alex D of P Super Power.” The next morning, Mills writes to Mejias, “Please done [sic] give those write ups to the CS she’s not gonna give me the assists for that.” Mills wanted Mejias to speak to the D of P, not the CS, because apparently the CS would not approve certain types of assists, presumably the “drop the body” assist.

28. On April 20, 2022, the same day Mills told Lopez about Albertina’s suggestion of a “drop the body” assist, Mills had sent the following texts directly to Albertina: “I’m super strong for anything but this. I can do ANYTHING but live with mental illness that I can’t control. I’m at the top of the bridge and dealing with serious mental problems. This is not right!! I literally can’t take it anymore. I don’t think anyone could lol.” Mills was expressing her desperation to her caretakers, and Mejias responded by suggesting the “drop the body” assist.

29. According to Scientology leaders, the “drop the body” assist was created by L. Ron Hubbard, Scientology’s messianic founder. Following his 1986 death, Scientology leaders announced that his body had become an impediment to his work and that he had decided to “drop his body” to continue his research on another plane of existence. They further announced that Hubbard deliberately caused his spirit to discard his body, of which a side effect was his body’s death. In other words, Hubbard willfully dropped his body, ending his own corporeal life.

30. At the L. Ron Hubbard death briefing, Pat Broeker, a high-ranking Scientologist, stated, “We also by the way have the OT level that is going to be done immediately after every thetan discards his or her body. He wrote that up before he went. Now don’t take that as an invitation, because you don’t get it until you’re through with the OT level before it, but know that when its time, the tech is there…. That will be written up right away . . . word for word…. [A]nd people will be allowed to come in . . . before they discard it, read the materials, check out on them, be word cleared, demo [long pause], so you know it, now you know it.”

31. Broeker was describing the drop the body assist. Such an assist was only available to the highest levels of Scientology, and Mills had attained that level, OT 8 (operating thetan 8), as had Mejias. And reportedly it was and is only to be used by Scientologists who were terminally ill. Hubbard was said to have suffered from heart problems including a stroke; he paved the way for his followers to “drop the body.” The only difference, of course, is that Mills’ body was perfectly healthy. She was not terminally ill. She was mentally ill. She incorrectly thought she was terminally ill, misguided and misdiagnosed as she was by the Scientology Defendants, her handlers and Dr. Minkoff, and she was foreclosed at every turn from proper mental health treatment. That desperation, evident in her text messages, led her to ask Scientology for the drop the body assist.

32. This action seeks damages for the wrongful death of Mills, who inflicted serious physical harm upon herself eventually resulting in death, as a result of being brainwashed by the Scientology Defendants that she could drop her body, in direct contravention of the Scientology Defendants’ voluntarily undertaken duty to “watch” her 24/7 and prevent self-harm. As further detailed below, these actions by the Scientology Defendants were made contrary to the express assurances and undertakings of the Scientology Defendants to protect Mills and despite innumerable warnings and cries for help from Mills that she was in an especially vulnerable mental and psychological condition.

33. In fact, the Scientology Defendants had actual knowledge and were well aware that Mills was suffering from key acute mental health risk factors, evidenced in her text messages and medical records, over a sustained period, including: significant immediate stressors (misdiagnosed cancerous cyst, significant mental torment, anxiety, depression, and multiple health anxieties), interpersonal problems (grief and sadness from misdiagnosed cancerous cyst and sustained periods of interpersonal withdrawal and the inability to leave her home), hyperarousal (verbalized mental torment and headaches, agitation, restlessness, ongoing physical pain, intermittent and severely reduced sleep, ruminative worry, and anxiety), and suicide-related negative thoughts (hopelessness, statements that she was “suffering and going to die,” that she was “getting intrusive bad thoughts,” that she “literally” felt like she was “dying every day.” feeling like a failure despite her high-level OT 8 status, and having the mental state of unbearable pain).

34. The Scientology Defendants not only expressly undertook a duty to protect Mills, but they also went a step further and undertook the administration of Mills’ medical care, including requesting (from Mills) and receiving authorization to review and obtain copies of her medical records (for Lopez and Mejias specifically), approving Mills’ medical treatments and regularly speaking and corresponding with her physician, Minkoff, whom was treating Mills on a regular basis and to whom Mills had often disclosed her depressive thoughts. In reviewing Mills’ medical information, the Scientology Defendants knew Mills was in crisis, that she had twice been to the emergency room, that she was suffering from severe anxiety, depression, brain fog, brain inflammation and a host of other problems. As a result, in February 2022, she was placed in quarantine, not being allowed to enter the Flag Base, not being allowed to conduct auditing sessions there, and was placed on a 24/7 watch with the three caretakers monitoring her every move and living with her.

Background of Scientology

35. Scientology is organized and operates through a global network of corporations, trusts, and unincorporated associations and organizations. This structure creates the appearance of a group of affiliated but decentralized and independently managed establishments operating pursuant to general authority bestowed upon them by the “Mother Church,” CSI. Among these corporations are the Scientology Defendants.

36. Scientology was created by L. Ron Hubbard (“LRH”) in 1952 following the publication of “Dianetics: The Modern Science of Mental Health.” Its practices are mandated by the writings, thoughts, and teaching of LRH.

37. The basic theory of Dianetics is that the human mind can be separated into two spheres: an emotionally reactive mind and an unemotional, analytic mind. Dianetics teaches that the analytic mind is a computer, incapable of error. Human misjudgments, on the other hand, which create social problems and much individual suffering, are attributed to the emotionally reactive mind, which is made up of patterns imprinted on the nervous system in moments of pain or stress. These imprinted patterns may be triggered by stimuli associated by the emotional mind with the original imprinting, which may, in turn, produce unconscious or conditioned behavior which is harmful or irrational.

38. This psychological theory, which is unquestioningly accepted and applied in Scientology, is not considered to be limited to a description of the mind, but to also offer a basis for a practical science which purportedly can cure many individual and societal problems. Scientology labels ordinary persons, encumbered by their reactive minds, “preclears,” whose mental computers contain errant code that needs to be deleted. The goal of Dianetics is to render people “clear” of this errant, emotional code, thereby permitting their unemotional, analytical minds to govern their behavior. Among other things, Dianetics teaches that all mental disorders are caused by these imprinted patterns in the reactive mind, which can be erased, curing the mental illness. This concept is extremely broad and permits Scientology to consider every behavior, feeling or thought that an individual may have, and which is deemed by Scientology to be aberrant or deviant, to have been a result of some error in their reactive mind that can be erased.

39. For Scientologists, the writings of LRH and Dianetics must be strictly practiced and followed in a fundamentalist, orthodox manner with strict adherence to the policies, procedures, and practices as written and dictated by LRH.

40. The human spirit is referred to by Scientologists as the “thetan,” which continues to exist long after the body dies.

41. Thus, when a Scientologist “drops the body” it is believed that their thetan will continue to exist and can potentially occupy a new physical body in the future.

42. Scientology teaches that a person can achieve consciousness of their thetan after investing a significant amount of time and money, typically hundreds of thousands of dollars, into the practice.

43. Members are organized into levels called Operating Thetan, which is used to describe how much control the individual has over their inner thetan. An increase in level grants the person superhuman, God-like abilities, including increased IQ and total recall and immunity from disease.

44. According to Scientology, the highest level someone can achieve is called Operating Thetan 8 (“OT 8”). OT 8 individuals gain “cause over matter, energy, space, and time,” which is interpreted as a range of superhuman abilities. These may include heightened intelligence, exceptional memory, excellent eyesight, and the ability to project oneself as a thetan with full perception. Additionally, Scientologists believe that they will become immune to illness once they achieve OT 8 status, including mental illness. The fact that Mills’ was an OT 8 exhibiting signs of severe mental illness caused FSO to order her isolation and quarantine and the Type 3 watch conducted by the three caretakers, who were at all times working within the course and scope of their employment agreements with the Scientology Defendants.

45. Scientology is known to demonize the mental health field and view psychiatry as evil. Scientology attempts to position itself as a rival profession to psychiatry and teaches that there must be a complete rejection of prescription drugs that treat mental health issues including depression.2 The Practice of Auditing

46. A Scientologist’s salvation is premised on completing the “Bridge of Total Freedom,” which requires reading LRH’s extensive materials and completing a series of courses and “auditing sessions.” These courses and auditing sessions are the only way to achieve the coveted status of “Clear” and, beyond that, “Operating Thetan.”

47. During an “auditing session,” a member meets with an “auditor,” who is generally a higher-ranking Scientologist and often a Sea Org member. The “auditor” has the member hold two metal rods commonly referred to as “cans” of an “electropsychometer” or “e-meter.” An emeter, is designed to “measure[] the mental state or change of state of a person and thus is of benefit to the auditor . . . [to] locate areas to be handled.”3 As LRH said and Defendants maintain, “an e-meter is better known as a ‘lie detector’ and is used to ascertain truth of background and conduct.”4

48. Members are audited repeatedly. Auditing sessions may occur daily and involve several hours of being forced to reveal explicit, personal details regarding daily thoughts and activities. During these sessions, the auditor takes copious notes on what the member reports. All audit sessions are thoroughly documented in auditors’ notes and audio or video recordings of the sessions, which are compiled in permanent dossiers for each member known as Pre Clear or “PC folders that are maintained in the ordinary course of the Scientology Defendants’ operations and maintained permanently. FSO has extensive auditing files on Mills which should have been kept in the ordinary course of its operations, and those files would clearly show Mills’ deteriorating mental state and suicidal ideation, as well as her request for an assist to “drop the body.”

49. Nothing is out-of-bounds in an auditing session. Every memory of past experiences, and each thought and aspect of the subject’s behavior is explored in minute detail as the auditor repeatedly questions the subject until the auditor is satisfied with the subject’s answers.

50. In an auditing session, the auditor seeks to establish a relationship of trust with the subject. The auditor has absolute authority to guide the questioning, extract desired responses, and decide when the session may be concluded. Subjects are not permitted to leave the room until the auditor declares the session over. To reduce subjects’ resistance and lower their guards, auditors are trained to remain low-key in their questioning and to avoid reacting to what subjects disclose. Subjects are required to fully answer all their auditors’ questions, including deeply personal and compromising information that, if disclosed to others, would embarrass, humiliate, and inflict personal costs on the subject (and, often, the subject’s family). Through repeated interrogations of subjects, auditors identify and document vulnerabilities that are used to manipulate, pressure, and coerce members. Subjects are instructed to suppress feelings and emotions connected to the information they are conveying, even when recounting details of past traumas, which they are repeatedly told by their auditors are the subjects’ own fault.

51. The person responsible for overseeing and administering auditing sessions is the director of processing, referred to by members as the “D of P” which is also used interchangeably to describe a director of processing interview. A director of processing interview is used to determine what auditing sessions a particular member should be given.

Assist in Scientology

52. An “assist” is a term in scientology that has a very specific meaning. Generally speaking, Scientologists believe that assists can be used to help a person recover more rapidly from an accident, illness or upset by harnessing the power of the mind. Types of assists include locational assists, nerve assists, touch assists, and body comp.

53. In 1986, at an event announcing Hubbard’s death, Pat Broeker, a high-ranking member of Scientology, announced to members that shortly before his death Hubbard had a breakthrough and thus created an assist to help members “drop the body.”5

54. As Broeker remarked, the assist would be documented and archived by Scientology and was thenceforth available to high-level members at all Scientology locations.

55. The assist to drop the body is performed during an auditing session and is intended for someone who knows they are going to die.

56. The reason for this assist is because Scientology teaches that at the time of death there is an over-stimulation of the thetan, and the assist facilitates the thetan to leave the body and occupy a new body.

57. Given her apparent and well-documented distress, Mills’ Scientology caretakers suggested to her that she “drop the body.”

Dr. David Minkoff M.D. and LifeWorks

58. Dr. Minkoff graduated from the University of Wisconsin Medical school in 1974. He is board certified in pediatrics and completed a fellowship in Infectious Diseases.6 In addition to his traditional medical training, Dr. Minkoff also practices alternative medicine. Dr. Minkoff holds himself out to be an expert in infection diseases, Lyme Disease and in cancer.7

59. Dr. Minkoff is a high-ranking member of Scientology.

60. Dr. Minkoff has a history of treating fellow Scientologists, and at least in one instance, his treatment may have contributed to the death of his patient.

61. In 1995, Lisa McPherson was a 36-year-old woman and Clearwater resident who suffered from a psychotic episode after a minor traffic accident. In order to avoid psychiatric intervention, fellow Scientologists convinced her to leave Morton Plant Hospital in Clearwater and seek care at Flag Base. They did not want her to be sent to a mental hospital or institution. At Flag Base, she was held against her will for 17 days without appropriate medical care until she died.

62. An administrative law Judge concluded that even though Dr. Minkoff had never actually met Ms. McPherson, he prescribed sedative medication by telephone to Scientology staff members who had called on her behalf. See Department of Health, Board of Medicine v. David Minkoff, M.D., Case No. 00-0023, State of Florida Division of Administrative Hearings.

63. Although admitting no guilt, Dr. Minkoff reached a $100,000 settlement in 1997 in a wrongful death lawsuit filed by McPherson’s estate.

64. Also in 1997, Dr. Minkoff co-founded LifeWorks as an alternative medicine medical clinic in Clearwater, Florida.

65. In 2001, the Florida Board of Medicine fined Dr. Minkoff $10,000 and suspended his license for one year followed by two years of probation for his involvement in McPherson’s care.

Mills’ childhood and early twenties

66. Mills was born on December 7, 1981, in Clearwater, Florida to Leila and Donald Mills. Mills’ father passed away in 2000 when Mills was 18, and she is survived by her mother, brother, and sister.

67. Mills received an Associate’s Degree and completed her real estate license. She established a very successful real estate practice working for brokerage MavRealty, LLC. Mills joins Scientology

68. In 2007, at the age of 26, Mills joined Scientology at the invitation of her friend Laura.

69. Mills quickly rose the ranks of Scientology and in 2019 at the age of 37 years old Mills was ultimately certified at the highest level of Scientology, OT 8. Her graduation ceremony was aboard the Freewinds.

70. Mills continued receiving auditing sessions and learning about Scientology including in the weeks and days leading up to her death such as in May 2022 when she completed certifications such as the “Super Power Rundown,” where she was taught that she can cause herself to have infinite power, including immunity from illnesses and disease. Mills gets an interview from the Director of Processing

71. In late 2021, Mills began to complain she was experiencing severe anxiety episodes to the point where it was very difficult for her to sleep. She had an elevated heart rate and had loss of appetite. Her symptoms were so severe, causing lack of sleep and elevated heart rate (Tachychardia), that she ended up in the emergency room of Morton Plant Hospital in December 2021 and again in January 2022.

72. Mills went in to get an interview by the Director of Processing who was responsible for creating a plan to treat her. The Director of Processing had Mills go to two clinics, LifeWorks (more fully described below) and Root Cause Medical Clinic (“Root Cause”) located in Clearwater. At Root Cause she was treated by Drs. Vikki and Rick Petersen. The Petersens are not medical doctors but instead, according to their website, hold doctorates in Physical Medicine through their degree in Chiropractic.8 The Petersens are also Scientologists.9

Mills is treated by Dr. Minkoff

73. Dr. Minkoff had been seeing Whitney Mills as a patient since 2015 and was acting as her primary care physician. Since at least October 2017, Dr. Minkoff noted that Whitney Mills had a large ovarian cyst. See Bates MILLS000279.

74. On November 2, 2021, at the behest of the Scientology Defendants, Mills received a medical authorization from Minkoff to attend a “perception rundown.”

75. Then on January 11, 2022, Mills returned to Lifeworks and began complaining to Minkoff and his advanced registered nurse, Sue Morgan, that she had anxiety, trouble sleeping, and loss of appetite.

76. Later on February 17, 2022, filling out a questionnaire provided by Minkoff and Morgan, she rated on the scale of 0-4 (with 0 being almost never and 4 described the effect as severe), that her depression, anxiety, mood swings, and irritability were each at a score of 5 (more than the maximum score allowed). She further stated she was suffering from headaches, was underweight, lethargic, fatigued, and had poor memory.

77. Mills began suffering chronic daily debilitating headaches, hallucinations, depression, lethargy, and even reported that her skin felt like it was on fire. Mills’ condition was so severe that she often found it difficult to leave the home or do regular daily activities such as bathing.

78. By late February, Mills texts Minkoff stating, “the pressure in my head is so intense, won’t seem to go away no matter what I did. Is there anything that can help relieve it … Can I take steroids? The pressure is so bad, I can’t get out of bed. Or is there something else that would help?”

79. Minkoff responds, “Are you taking anything for pain? We could try a diuretic. Does caffeine help? Have you ever used migraine meds?” Mills texts back, “I’ve taken advil but it doesn’t relieve the pressure. I tried coffee too and it didn’t help. I would be willing to try a diuretic and no I haven’t taken migraine meds but willing to at this point. Will this go away when the Lyme is gone?” Minkoff responds, “Yes. Did you start the ivermectin…” Ivermectin is an anti-parasitic and is not used to treat Lyme Disease. Minkoff had also diagnosed Mills with Babesia, a type of parasite, and the Ivermectin was purportedly treating that issue.

80. Over the course of the next several months, Mills would text Minkoff constantly begging for Minkoff to help her with her mental illness stating, “Is there anything else for the mental part? I’m seriously experiencing some mental illness. This is my biggest symptom is the mental part.”

81. The level of quackery in Dr. Minkoff’s response is nothing short of astounding: “Got it. Got it. Drugs could numb you but you are OT. Put TR O in. It’s a sensation. It’s noise. It has no power over YOU. That’s the truth. Eye of the tiger. You are loved. You have friends and LRH. Duplicate it. Dissolve it. That is your power. You can be tone 40 with your TR O. That’s you as cause. I know you can. ML, dm.”

82. Weeks later, on April 13, 2022, just under a month before her death, Mills texts Minkoff again stating, “Ok, is there anything else for the mental problems? I’m REALLY struggling with that part. This is the hardest part to be acting insane when I’m not.” Minkoff does not reply directly to this message.

83. Instead of dealing with Mills’ mental health crisis, Minkoff diagnosed and began treating Mills for Lyme Disease, including potential neurological Lyme Disease. Lyme Disease is a common diagnosis among Scientologists, as a catch-all to explain a host of symptoms that would otherwise be attributed to a mental health issue.

84. Neurological Lyme Disease occurs when the Lyme disease bacteria affects the peripheral or central nervous system. The symptoms for neurological Lyme Disease include numbness, pain, weakness, facial palsy/droop (paralysis of the facial muscles), visual disturbances, and meningitis symptoms such as fever, stiff neck, and severe headache. Treatment for neurological Lyme Disease consists of administrating either oral antibiotics such as doxycycline, amoxicillin, cefuroxime, and azithromycin, or intravenous antibiotics such as ceftriaxone.

85. Despite his diagnosis of Lyme Disease or neurological Lyme Disease, Minkoff did not prescribe any of the above antibiotics, or any antibiotic at all to Mills. Instead, Dr. Minkoff prescribed Mills Ketorolac, a NSAID used to relieve moderately severe pain after an operation or painful procedure, and Furosemide, a diuretic used to treat fluid retention and swelling. In addition, one of the most common symptoms of neurological Lyme Disease is facial droop/palsy. Mills did not have that symptom.

86. Minkoff also diagnosed Mills with babesia, a parasite transmitted by the same tick that causes Lyme Disease. However, babesia is less likely to affect the neurological system, and only a spinal tap would confirm whether it is affecting neurological function, something Minkoff did not do. For the babesia, Minkoff prescribed Mills Ivermectin, an anti-parasite drug. Prior to her death, Mills somehow found out she did not have babesia, but still believed she had Lyme.

87. Despite having knowledge of Mills’ cyst since 2017, Minkoff also diagnosed Mills with a cancerous cyst in one of her ovaries, stating on March 26, 2022, “Whitney came for a consult a few weeks ago. On her exam I found a large mass in her pelvis. It is a very large ovarian cancer born out by MRI and PET scan.” 88. There was no evidence in the records that Minkoff took a biopsy of the mass or was otherwise able to diagnose the cyst as cancerous or malignant. That cyst was later proved not to be cancerous during Mills’ autopsy, which clearly shows that it was benign.

Mills was put under “watch” by Scientology

89. At this point, Mills faced compounding stresses. She had a misdiagnosed cancerous cyst, misdiagnosed Lyme Disease, significant mental torment, severe anxiety, depression, and brain inflammation.

90. The Scientology Defendants understood that Mills was undergoing a mental health crisis having access to her medical records, control of her care and through her regular auditing sessions, her own reports and her caretakers’ reports.

91. On January 30, 2022, Mills sent an email to elyss.w@fso.org, stating “Here is the data on my health situation: Extreme lethargy, can’t get out of bed. No appetite. Pressure in head that won’t go away, worse when standing. Headaches everyday. Extreme brain fog. Some anxiety. Tachychardia.”

92. On March 11, 2022, Mills receives an email from flagdofphgc13@fso.org, one of the Directors of Processing at FSO or Flag Base, with a subject of “from Alex – Super Power D of P,” stating, “Please write me back here on what handlings you plan on doing.” Mills responds with two websites describing alternative treatments and therapies, asking “Let me know what the CS says.” CS is case supervisor, a Sea Org member at FSO, who had to approve Mills’ medical treatments. The D of P responds, “I got Brandon all the data and he was OK. But my C/S really really needs worksheets from Nieves [Lopez]. Plus then we can give the direction.” Mills later follows up with another email requesting approval for a Transcranial Magnetic Stimulation (TMS) therapy, a “drug-free, non-invasive treatment therapy that uses magnetic pulses to stimulate activity in neurons.”

93. On March 12, 2022, Mills sent an email to an @fso.org domain name, a man with the initials ET, describing her symptoms stating, “It’s causing me to feel like I’m dying and causing me psychosis, anxiety, panicking… I’m getting intrusive bad thoughts…I literally feel I’m dying every day. I don’t know what to do at this point.” She described her anxiety and elevated heart rate requiring her to go to the ER in December 2021. She then states, “I got quarantined so I couldn’t go back to the Org for session.” She further stated that, “I went to Dr. Minkoff and he said it’s Lyme and I’m on a treatment program. It’s only in my brain, everything else feels fine. . . . Dr. Minkoff said that when you have brain inflammation the neurons are not connecting well and cause all these things, but I feel mine is very extreme.”

94. On March 20, 2022, Mills receives an email from dchiefaomaa@fso.org, which stands for Deputy Chief, Advanced Organization, Master-at-Arms at FSO. He (Jarrod) states, “Ok, I am doing the research. Meanwhile, you need to speak to/with Dr. Minkoff, live comm.” On April 10, 2022, Mills send him another email asking him to call her, and he responds: “Yes! We spoke! I’ll talk to the Dr. and you and Nieves [Lopez] need to tackle that book! Do LOTS of processes and assists! As an example of LOTS; when an SO member goes to Isolation, he is required to do AT LEAST 10 assists a day – BOTH WAYS!” Because Mills was not allowed on the Flag Base, she too was in isolation.

95. On April 9, 2022, Mills writes to Alex, the D of P (flagdofphgc13@fso.org), stating, “I finished all of the assist program. The brain inflammation has gone down a lot and seems to be gone or almost gone. I’m feeling better and would like to go in session to see about handling the other part of the mental affects I’m getting from this.”

96. On April 15, 2022, caretaker Nieves Lopez introduces Mills to Carissa Hart, whose boss had purportedly had Lyme Disease which, according to Hart, resolved by going to Minkoff’s program for a month plus a program called Hippocrates in Miami. Hart became directly involved in Mills’ medical care and treatment, drove her, took her for walks and was constantly at her apartment, including on May 12, 2022, when Hart identified herself to Clearwater Police as one of Mills’ caretakers.

97. On April 17, 2022, Alex writes back to Mills saying, “I got brand new assist program approved by the SNR C/S to you and sent it to nieves [Lopez].” Mills responds, “Thank you! Nieves left, can you send it to me? I have someone else to do the assists,” referring to Mejias or Hart, her other caretakers. Alex responds, “Dear Nievez, This is the next approved by the SNR C/S assist pgm,” listing the following numerical assists: “289, 21, 22, 23, 24, 25, 46, 70, 139 (on the lime disease), 293 (find out which body part she feels is affected and run on each one), 295, 299, 309, 150 (as an assist), 314.”

98. On April 26, 2022, the D of P once again writes, “Did you get a surgery?” to which Mills responds, “Not yet, Thursday.” Dr. Minkoff and every Scientologist involved in her care were pushing Mills to have a surgery to remove the ovarian cyst, but Mills did not want to do the surgery, unconscious and under general anesthesia, until she resolved her “brain” issues, including her brain fog and inflammation. In any event, she did not need the surgery.

99. On May 1, 2022, Mills tells her caretaker Hart, “I literally can’t take another day of this horrific horror movie I’m living.” That same day she asks Hart, “Can you find the ACC that you were talking about? When I said my brain is controlling me.” Hart provides the information. On May 6, 2022, Mills tells Hart, “I feel like there’s an SP inside me. Suppressing the shit out of me.” An SP is a suppressive person, someone who does not agree with Scientology or advocates against it. On May 9, 2022, Mills tells Hart, “Are you available? I’m on constant panic mode.” Later that day, Mills tells Hart, “It doesn’t appear that I have the Lyme strains that make you crazy,” Hart asks which “ones do you have,” and Mills responds, “Borrella and burgdorferi. Babesia and bartonella are the ones that make you crazy.” Dr. Minkoff’s diagnosis of babesia was wrong, meaning there was no reason for her to have been taking ivermectin.

100. On May 10, 2022, Mills asks Hart, “Were you having a lot of destructive thoughts? I am and I don’t understand it, I can’t control it. It’s so frustrating.” On May 11, 2022, Mills is asking Hart about how to get rid of her “intrusive thoughts,” saying “Okay damn this thing is a beast. That’s the one thing that is killing me is the intrusive thoughts.” Hart responds, “Such a beast” and “Yes it’s the worst.”

101. All three caretakers, Hart, Mejias and Lopez, knew Mills was suicidal, and they were monitoring her and helping her for that very reason. They either failed to prevent Mills’ suicide, by undertaking a duty to monitor, supervise, live with her, care for her, or alternatively they assisted the suicide. Either way, they were all high-ranking Scientologist members of FSO, Tampa or some combination of the Scientology Defendants, and they were reporting Mills’ destructive, intrusive and suicidal condition to their superiors. And Mills herself was reporting her suicidal ideation to FSO and its Sea Org staff members.

102. The Scientology Defendants knew that Mills was a risk to herself, and thus assigned several Sea Org members or staff members to constantly check on her, intervene in her medical care and assigned the three Sea Org or staff members to serve as her caretakers and provide around the clock supervision at Mills’ apartment. They were trying to prevent another event like the death of Lisa MacPherson, only they needed to do it off campus, in Mills’ apartment rather than at Flag Base.

103. These caretakers, FSO members and Sea Org members did not have the requisite training to handle an acute mental health crisis, and this action did not represent an appropriate effort to seek an escalated level of crisis care or self-harm prevention.

104. The Scientology Defendants continued to monitor Mills closely including by having the D of P speak with Mills twice a day and speaking with Minkoff. Meanwhile, Lopez continued living with Mills, performing dozens of assists on her at the direction of the Scientology Defendants.

105. As stated above, on April 20, 2022, Mills messaged Lopez stating, “I wish it wasn’t in my brain. It’s so annoying that I have it so bad, and so bad mentally. The d of p wants me to come in for an interview.” Presumably, Mills was referring to Alex, the Super Power D of P at FSO. Lopez responded, “A d of p is good.” Mills replies, “I said something really dumb on the phone.” Lopez responds, “Oh oh. What did you say?” Mills replies, “Albertina told me there’s an assist for someone that is really sick and to drop the body. I asked for that assist.” Lopez responds, “Oops..” Mills replies, “I think I’m in trouble now.” Lopez, referring to the Scientology Defendants replies, “They know you’re desperate with this ongoing situation.”

Mills commits suicide

106. On May 8, 2022, Sabine from the Chaplain’s office at FSO texted Mills that the case supervisor, “CS gave us an interview to do with you.” Sabine had previously texted Mills in February that she wanted to find out if Mills “was able to find an auditor for assists.” Mills replied to the May 8th text that she was aware of the interview because, “the d of p told me. I haven’t been feeling good.” Sabine responded, “Am not sure when you are available to do this. We are out and about. Yes so I hear. It is not on the meter.” Saying the interview, “is not on the meter” refers to the e-meter, where auditing sessions are typically conducted. Sabine further states that “It would take max 10 min. Let me know. We can be there in 2 min.” Mills did not want Sabine, along with whomever else accompanied Sabine, to come over at that time because Mills’ mother was on her way to see Mills.

107. The exchange is quite suspect because an OT 8 scientologist like Mills should not be dealing with the Chaplain’s office, which is relegated to dealing with new members, and auditing sessions are never so short. 108. Days after that exchange, on the evening of May 12, 2022, Mills was either intentionally or negligently left alone by her caretakers for several hours, despite their responsibility to supervise and monitor her 24/7. Indeed, Lopez had woken up that morning in the apartment and Lopez and Hart had spent the day watching Mills. Taking advantage of the sudden lack of supervision, Mills attempted to set herself on fire by lighting her hair but was unsuccessful in doing so. Instead, she used a .38 special revolver to shoot herself in the head. She believed the only option left for her was to “drop the body.” 109. Mills was found by her family and rushed to Morton Plant Hospital, where she experienced great pain and suffering and passed the next day, on May 13, 2022.

COUNT I: NEGLIGENT UNDERTAKING (Against the Scientology Defendants)

110. Plaintiff realleges and incorporates all of the preceding paragraphs as if fully set forth herein.

111. At all times material, the Scientology Defendants, through their agents, employees, and/or representatives, agreed to take care of Mills and protect her from self-harm.

112. From the inception of the special relationship, Mills made it clear that she was extremely anxious, depressed, and was a threat to herself. Accordingly, the Scientology Defendants had actual knowledge that she was suicidal and actively committed to taking care of Mills and protecting her from self-harm. The Scientology Defendants voluntarily and expressly assumed and undertook this duty, including through their agents and employees, the three caretakers and various FSO members.

113. The Scientology Defendants repeatedly were reminded of this duty through Mills’ complaints of her ongoing and worsening depression and thoughts of self-harm, and the Scientology Defendants repeatedly acknowledged that they would continue to undertake and would fulfill this duty and repeatedly reassumed this duty, as the communications above demonstrate, in light of the Scientology Defendants’ clear and informed awareness of Mills mental and psychological condition and medical history.

114. Due to the Scientology Defendants’ voluntary assumption of these duties, the Scientology Defendants owed a duty of reasonable care to Mills to communicate with mental health professionals and prevent Mills from inflicting self-harm onto herself. It was clearly foreseeable to all involved that Mills was suicidal; she asked for the “drop the body” assist in an interview with the D of P and told her caretakers about it, expressing repeatedly her suicidal ideation. Mills’ self-harm was clearly within the foreseeable zone of risk, and the round-the-clock watch ordered by FSO was intended to prevent such a scenario, similar to the MacPherson matter.

115. The Scientology Defendants, through their own actions and by and through their agents, employees and/or representatives, including but not limited to the three caretakers, who at all times were acting within the course and scope of their employment as FSO Sea Org members or staff members of Tampa or one or all of the Defendants, undertook to provide round-the-clock monitoring, supervision and care and were thus responsible for ensuring Mills safety and that her ongoing supervision and care was handled only by properly informed, trained, competent and capable individuals.

116. The Scientology Defendants are vicariously liable for the negligent and wrongful acts of their members, including the three caretakers, the D of P, the C/S, the Deputy Chief Master at Arms and others involved in Mills’ care and supervision.

117. At all times material, the Scientology Defendants, by and through their agents, employees and/or representatives, breached their expressly undertaken duty of care in many ways, including, but not limited to:

a. failing to properly supervise, oversee, and/or protect Mills;

b. failing to ensure that Mills’ care was handled by properly informed trained, competent and capable individuals;

c. failing to inform and comply with basic suicide prevention protocols including ensuring a safe environment, using validated suicide screening tools, moving to validated assessment methods when indicated, implementing safety planning and linkage to mental health services;

d. leaving Mills alone and unsupervised when they knew she was a danger to herself;

e. recklessly and repeatedly refusing to comply with Mills’ requests for prescription medication to alleviate her depression and suicidal thoughts, and instead telling Mills to use her “superpowers” to control her brain in order to alleviate her symptoms;

f. recklessly and repeatedly telling Mills to “drop the body” with the knowledge that it would most certainly cause Mills, who was suffering from severe emotional stress, depression, and anxiety and with the knowledge that Mills might inflict harm upon herself, to commit suicide; and/or

g. recommending an assist to “drop the body” and allowing for that assist to take place.

118. The subject incident which occurred on May 12, 2022, and which resulted a day later in the death of Mills, was a direct and proximate result of the negligent undertaking and other misconduct herein alleged of the Scientology Defendants, by and through their agents, employees and/or representatives. But for their actions, which prevented Mills from obtaining the appropriate help, Mills would not have engaged in self-harm. But for their actions, Mills would not have had to even consider dropping her body.

119. Furthermore, the Scientology Defendants are legally, vicariously and/or otherwise liable for Mills’ death due to the negligent undertaking of their agents, employees and/or representatives, including but not limited to Lopez, Mejias, and Hart, who undertook the responsibility to care for Mills, and thus were under a duty to exercise reasonable care.

120. As a direct and proximate cause of the Scientology Defendants’ negligent undertaking of its voluntarily assumed duties (and breach thereof) Mills suffered severe emotional trauma, anguish, distress and physical harm on May 12, 2022, which caused her death.

121. As a further direct and proximate result of the Scientology Defendants’ negligent undertaking and the consequent death of Mills, PLAINTIFF has been damaged and claims all damages to which she and the Estate, survivors and/or beneficiaries are entitled, including, as applicable law may provide, but not limited to:

a. pain and suffering of decedent prior to death;

b. pain and suffering of Plaintiff, survivors, beneficiaries and/or heirs of decedent, including but not limited to, the mental anguish suffered by said individuals as a result of the hospitalization and subsequent death of the decedent;

c. lost society, companionship, comfort, instruction, guidance, counsel, training and services of the decedent to Plaintiff, survivors, beneficiaries and/or heirs;

d. pecuniary losses including loss of support in money or in kind;

e. loss of inheritance and/or net accumulations;

f. lost value of life;

g. funeral expenses; and/or

h. any and all other damages to which the decedent, the Plaintiff, the Estate, the survivors, beneficiaries and/or heirs of the decedent may be entitled under applicable law.

WHEREFORE, LEILA MILLS, as Personal Representative of the Estate of Whitney Mills, deceased, on behalf of herself and all potential beneficiaries and heirs, demands judgment against the Scientology Defendants for compensatory damages, costs and such other relief this Court deems appropriate. Plaintiff further demands trial by jury of all issues triable as of right by jury.

COUNT II: NEGLIGENT SUPERVISION (Against the Scientology Defendants)

122. Plaintiff realleges and incorporates all of the preceding paragraphs as if fully set forth herein.

123. At all times material, the Scientology Defendants, through their agents, employees, and/or representatives, agreed to take care of Mills, supervise her and protect her from self-harm, including by living with her, monitoring her treatment, overseeing and approving her medical care and supervising her on a 24/7 basis.

124. Mills made it clear that she was extremely anxious, depressed, and was a threat to herself. Accordingly, the Scientology Defendants committed to taking care of Mills and protecting her from self-harm. The Scientology Defendants voluntarily and expressly assumed and undertook this duty.

125. The Scientology Defendants repeatedly were reminded of this duty through Mills’ complaints of her ongoing and worsening depression, destructive and intrusive thoughts of selfharm and the Scientology Defendants’ repeatedly acknowledged that they would continue to supervise and monitor Mills and would fulfill this duty and repeatedly reassumed this duty, as the communications above demonstrate, in light of the Scientology Defendants’ clear and informed awareness of Mills’ mental and psychological condition and medical history. Mills’ three caretakers identified themselves as such to the Clearwater Police, lived with Mills and constantly supervised her. The three caretakers were likely members and working for Defendants FSO or Tampa, or alternatively one or all of the other Defendants, and Defendants are vicariously liable for their actions and omissions, including the failure to supervise Mills on the evening of May 12, 2022, whether such failure was intentional or negligent.

126. Due to the Scientology Defendants’ voluntary assumption of these duties, the Scientology Defendants owed a duty of reasonable care to Mills to communicate with mental health professionals and prevent Mills from inflicting self-harm onto herself. All involved had actual knowledge of the potential for self-harm, and given Mills’ repeated pleas and cries for help (only a few of which are quoted above), self-harm was within the foreseeable zone of risk. The Scientology Defendants, including but not limited to their agents and employees and the three caretakers, who were at all times acting within the course and scope of their employment, had actual knowledge of Mills’ suicidal ideation.

127. The Scientology Defendants, by and through their agents, employees and/or representatives, undertook to provide supervision and were thus responsible for ensuring Mills’ safety and that her ongoing supervision and care was handled only by properly informed, trained, competent and capable individuals.

128. At all times material, the Scientology Defendants, through their own actions and by and through their agents, employees and/or representatives, breached their expressly undertaken duty of care in many ways, including, but not limited to:

a. failing to properly supervise, oversee, investigate, discharge, or reassign their agents, employees and/or representatives that were in charge of looking after Mills including but not limited to Lopez, Mejias, and Hart.

b. failing to ensure that Mills’ care was handled by properly informed trained, competent and capable individuals;

c. failing to supervise that their agents, employees and/or representatives were following basic suicide prevention protocols including ensuring a safe environment, using validated suicide screening tools, moving to validated assessment methods when indicated, implementing safety planning and linkage to mental health services.

d. failure to supervise their agents, employees and/or representatives whom refused to comply with Mills’ requests for prescription medication to alleviate her depression and suicidal thoughts, and instead telling Mills to use her “superpowers” to control her brain in order to alleviate her symptoms;

e. recklessly and repeatedly telling Mills to “drop the body” with the knowledge that it would most certainly cause Mills, who was suffering from severe emotional stress, depression, and anxiety and with the knowledge that Mills might inflict harm upon herself, to commit suicide; and/or

f. recommending an assist to “drop the body” and allowing for that assist to take place, despite their decision to care for, supervise and watch Mills.

129. The subject incident which occurred on May 12, 2022, and which resulted a day later in the death of Mills, was a direct and proximate result of the negligent undertaking and other misconduct herein alleged of the Scientology Defendants, by and through their agents, employees and/or representatives. But for their actions, which prevented Mills from obtaining the appropriate help, Mills would not have engaged in self-harm. But for their actions, Mills would not have had to even consider dropping her body. But for their actions, Mills would not have been left alone, as they knew she could not be left alone given her suicidal proclivities.

130. Furthermore, the Scientology Defendants are legally, vicariously and/or otherwise liable for the Mills’ death due to the negligence of their agents, employees and/or representatives, including but not limited to Lopez, Mejias and Hart, who undertook the responsibility to care for Mills, and thus were under a duty to exercise reasonably care.

131. As a direct and proximate cause of the Scientology Defendants’ negligent supervision of their voluntarily assumed duties (and breach thereof) Mills suffered severe emotional trauma, anguish, distress and physical harm on May 12, 2022, which caused her death.

132. As a further direct and proximate result of the Scientology Defendants’ negligent supervision and the consequent death of Mills, PLAINTIFF has been damaged and claims all damages to which she and the Estate, survivors and/or beneficiaries are entitled, including, as applicable law may provide, but not limited to:

a. pain and suffering of decedent prior to death;

b. pain and suffering of Plaintiff, survivors, beneficiaries and/or heirs of decedent, including but not limited to, the mental anguish suffered by said individuals as a result of the hospitalization and subsequent death of the decedent;

c. lost society, companionship, comfort, instruction, guidance, counsel, training and services of the decedent to Plaintiff, survivors, beneficiaries and/or heirs;

d. pecuniary losses including loss of support in money or in kind;

e. loss of inheritance and/or net accumulations;

f. lost value of life; g. funeral expenses; and/or h. any and all other damages to which the decedent, the Plaintiff, the Estate, the survivors, beneficiaries and/or heirs of the decedent may be entitled under applicable law.

WHEREFORE, LEILA MILLS, as Personal Representative of the Estate of Whitney Mills, deceased, on behalf of herself and all potential beneficiaries and heirs, demands judgment against the Scientology Defendants for compensatory damages, costs and such other relief this Court deems appropriate. Plaintiff further demands trial by jury of all issues triable as of right by jury.

COUNT III: NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS (Against the Scientology Defendants)

133. Plaintiff realleges and incorporates all of the preceding paragraphs as if fully set forth herein.

134. At all times material, the Scientology Defendants knew or should have known that Mills was severely emotionally depressed and distressed, and the Scientology Defendants knew or should have known that additional emotional trauma and distress was likely to cause Mills to inflict harm upon herself.

135. At all times material, the Scientology Defendants knew or should have known Mills presented with key acute mental health risk factors, evidenced in her text messages and medical records, over a sustained period, including:

a. significant immediate stressors (misdiagnosed cancerous cyst, financial problems, significant mental torment, anxiety, depression, and multiple health anxieties),

b. interpersonal problems (grief and sadness from misdiagnosed cancerous cyst and sustained periods of interpersonal withdrawal and the inability to leave her home),

c. hyperarousal (verbalized mental torment and headaches, agitation, restlessness, ongoing physical pain, intermittent and severely reduced sleep, ruminative worry, and anxiety), and

d. suicide-related negative thoughts (hopelessness, statements that she was “suffering and going to die,” that she had “intrusive” and “destructive” thoughts, that she could not take it anymore, the she had lost control of her brain, that she was ostracized from Flag Base despite being OT 8 and thus feeling like a failure, and having the mental state of unbearable pain, brain inflammation and brain fog).

136. At all times material, the Scientology Defendants knew or should have known that Mills would be susceptible to further emotional trauma or distress upon being informed on April 20, 2022, that there was an assist to “drop the body,” and that such information could cause serious psychological or physical harm to Mills, including self-inflicted harm.

137. The Scientology Defendants, including but not limited to the three caretakers, for whom Defendants are vicariously liable, owed Mills a duty to act with reasonable regard for Mills’ emotional well-being, and they voluntarily and expressly assumed that duty on repeated occasions.

138. Despite this duty, and the knowledge of Mills’ fragile emotional and behavioral state, the Scientology Defendants displayed a reckless disregard for her condition, with actual awareness of the likelihood and high probability of causing her severe emotional distress and selfharm, encouraged her to “drop the body,” a euphemism for death, to cure her ailments.

139. At all times material, the Scientology Defendants through their own actions and by and through their agents, employees and representatives, breached the duty of care owed to Plaintiff and/or Plaintiff’s decedent in some or all of, but not limited to, the following ways:

a. failing to properly supervise, oversee, and/or protect Mills;

b. failing to ensure that Mills’ care was handled by properly informed trained, competent and capable individuals;

c. failing to inform and comply with basic suicide prevention protocols including ensuring a safe environment, using validated suicide screening tools, moving to validated assessment methods when indicated, implementing safety planning and linkage to mental health services.

d. recklessly and repeatedly refusing to comply with Mills’ requests for prescription medication to alleviate her depression and suicidal thoughts, and instead telling Mills to use her “superpowers” to control her brain in order to alleviate her symptoms;

e. recklessly and repeatedly telling Mills to “drop the body” with the knowledge that it would most certainly cause Mills, who was suffering from severe emotional stress, depression, and anxiety and with the knowledge that Mills might inflict harm upon herself, to commit suicide; and/or a. recommending an assist to “drop the body” and allowing for that assist to take place, despite the responsibility they had undertaken to protect and supervise Mills.

140. The subject incident which occurred on May 12, 2022, and which resulted a day later in the death of Mills, was a direct and proximate result of the negligent infliction of emotional distress and other misconduct herein alleged of the Scientology Defendants, by and through their agents, employees and/or representatives. But for their actions, which prevented Mills from obtaining the appropriate help, Mills would not have engaged in self-harm. But for their actions, Mills would not have had to even consider dropping her body. But for their actions, Mills would not have been left alone, or alternatively Mills was not alone and was given an assist.

141. The Scientology Defendants also breached their duty by engaging in extremely outrageous behavior contrary to all acceptable standards of conduct in society because they knew or should have known that Mills was peculiarly susceptible to severe emotional distress, by reason of her mental and psychological condition. The Scientology Defendants proceeded despite such knowledge repeatedly and outrageously disregarding her condition and preventing her from receiving the appropriate help while at the same time recommending she drop the body.

142. As a direct and proximate cause of the reckless conduct and negligence of the Scientology Defendants, Mills undoubtedly suffered severe emotional distress that fatally affected her mental well-being and emotional tranquility. Furthermore, the Scientology Defendants are legally, vicariously and/or otherwise liable for the decedent’s death due to the negligent infliction of emotional distress of its agents, employees and/or representatives, including but not limited to Lopez, Mejias and Hart that encouraged Mills to “drop the body” while under a duty to exercise reasonably care.

143. As a further direct and proximate cause of the reckless conduct and negligence of the Scientology Defendants and the consequent death of Mills, PLAINTIFF has been damaged and claims all damages to which she and the Estate, survivors and/or beneficiaries are entitled, including, as applicable law may provide, but not limited to:

a. pain and suffering of decedent prior to death;

b. pain and suffering of Plaintiff, survivors, beneficiaries and/or heirs of decedent, including but not limited to, the mental anguish suffered by said individuals as a result of the hospitalization and death of the decedent;

c. lost society, companionship, comfort, instruction, guidance, counsel, training and services of the decedent to Plaintiff, survivors, beneficiaries and/or heirs;

d. pecuniary losses including loss of support in money or in kind;

e. loss of inheritance and/or net accumulations;

f. lost value of life; g. funeral expenses; and/or h. any and all other damages to which the decedent, the Plaintiff, the Estate, the survivors, beneficiaries and/or heirs of the decedent may be entitled under applicable law.

WHEREFORE, LEILA MILLS, as Personal Representative of the Estate of Whitney Mills, deceased, on behalf of herself and all potential beneficiaries and heirs, demands judgment against the Scientology Defendants for compensatory damages, costs and such other relief this Court deems appropriate. Plaintiff further demands trial by jury of all issues triable as of right by jury.

DATED this 11th day of May, 2024.

Respectfully submitted,

PODHURST ORSECK, P.A. SunTrust International Center One SE 3rd Ave, Suite 2300 Miami, Florida 33131 (305) 358-2800 / Fax (305) 358-2382 Email: rrasco@podhurst.com

By: /s/ Ramon A. Rasco RAMON A. RASCO Florida Bar No. 617334

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