Jonina Dourif vs. F.M. Bonsall (a 2nd lawsuit)
June 19, 2001
PSI TECH INTERNATIONAL, INC.
Re: Jonina Dourif vs. F.M. Bonsall (a 2nd lawsuit)
This is a second lawsuit regarding the theft which occurred last year at Joni Dourif's Beverly Hills residence and PSI TECH's training office. This lawsuit was recently served on F.M. Bonsall, a former PSI TECH employee who was responsible for the unauthorized entry into her home while she was out of town. Bonsall was the individual who personally removed 30 boxes of PSI TECH files along with numerous other personal property items.
This latest lawsuit is seeking both general and punitive damages not only for the theft but also for defamation and fraud committed by Bonsall and his co-defendants for their outrageous behavior committed against Joni personally.
I should comment that our adversaries would like the public to believe PSI TECH is heavy handed and lawsuit happy, but this is really not the case. It is not PSI TECH's policy nor mine personally to file lawsuits to resolve disputes. In my business career spanning the last 25 years I have found it necessary to file only one lawsuit. Litigation is costly in both time and money, and is usually not worth the hassle. However this situation (the theft of PSI TECH's and Joni's personal property) is so outrageous that we really had no other way to right the wrong. The public has not been made aware of all the facts in this case, and only gets deceptive spin from the defendants. I have made many appeals over the last year to the defendants to avoid litigation by simply returning the property, and at each attempt I have been rebuffed with arrogant disdain.
It seems Mr Bonsall and his co-defendant do not wish to do the right thing and so the only way to get their attention is with a lawsuit. O.K. Mr. Bonsall, and Mr. Dames, the ball is in your court again!
As always, PSI TECH remains vigorous in its quest to promote its mission and will do whatever is necessary to protect its intellectual property and business interests.
Text of suit:
Link K. Schwarz, A Law Corporation
1925 Century Park East,
Los Angeles, California 90067
Telephone: (310) 553-LINK 
Telecopier: (310) 553-5430
Attorneys for Plaintiff, Jonina Dourif
1. Plaintiff, Jonina Dourif (hereinafter "DOURIF"), is an individual, living in the County of Los Angeles, State of California. At all times relevant herein, PLAINTIFF was co-owner of Psi Tech, International and currently is an owner of Psi Tech, International.
2. Defendant Frederic M. Bonsall (hereinafter "BONSALL"), is and at all times herein mentioned, is and was an individual, living in the County of Los Angeles, State of California. At all times relevant herein, Bonsall was employed by Psi Tech.
3. Plaintiff is informed and believes and on that basis alleges that Defendant Bonsall was the agent of Defendant Does 1-100, inclusive and that he acted within the course and scope of such agency and joint venture relationship.
4. Plaintiff is unaware of the true names and capacities of Does 1 through 100, inclusive, and for that reason sues such Defendants under such fictitious names. When Plaintiff ascertains the true names and capacities of such Defendants, Plaintiff wil seek leave of course to amend this complaint to assert their true names and capacities. Plaintiff is informed and believes and based thereon alleges that all of the Defendants are responsible in some manner for the occurences herein alleged, and that Plaintiff's damages herein alleged were proximately caused by their conduct.
5. Plaintiff is informed and believes and based thereon alleges that all of the Defendants were the agents and servants of one another as hereinafter alleged.
6. Plaintiff is informed and believes and thereon allege, that each Defendant was the employee, agent and joint venturer of each of the other Defendants and each acted within the course and scope of such agency, employment and joint venture relationship, and with the full knowledge and authorization of the Defendants in committing the wrongful acts alleged herein and below.
7. In or about July 2000, Bonsall removed from Plaintiff Dourif's resident without her consent, Thirty boxes of Psi Tech's corporate documents, business records and proprietary information. On or about that time, Bonsall removed from Plaintiff's residence and business without her consent and removed and original oil painting; a printer; a valuable photograph; guns; statues; antiques; collectors books; all proprietary files of Psi Tech, and it's mail. Despite repeated requests by Plaintiff for the return of it's property Defendant BONSALL refused and continues to refuse to return such goods.
8. Defendant Bonsall has made numerous statements that he wanted to close a deal to share Psi Tech's proprietary files for public dissemination, which would completely ruin Plaintiff's business.
9. On numerous occasions in the year 2000 and continuing until the present, Defendants made numerous false statements about Plaintiff communicated and published through the internet, in print and on radio stations, including but not limited to: (1). Psi Tech's training and video courses are ineffective and are of poor quality; (2). Psi Tech engages in false advertising; (3). that Defendant and Plaintiff had a romantic relationship; (4). Disparaging comments related to Plaintiff and her background; and that (5). Defendant was forced to engage in deceitful practices under the direction of Plaintiff.
10. Plaintiff repeats and realleges Paragraphs 1 through 9, inclusive, of the Complaint and by this reference, makes them a part hereof as though fully set forth at length herein.
11. Defendant worked for Plaintiff for approximately three (3) years and was the Chief Operating Officer of Psi Tech's Distribution Department.
12. At all times relevant herein Defendant Bonsall represented that he was a trusted employee of Psi Tech and that he would cause no harm to the business and/or to Plaintiff Dourif. When Defendant Bonsall and Does 1-100, inclusive made the promises and representations to Plaintiff, Defendants and each of them has no intention of performing.
13. Defendant Bonsall made the representation to Plaintiff that he would make some repairs and paint her condominium, while Plaintiff was out of town.
14. Defendants and each of them purposely supressed the fact that its secret intent however was and is to destroy Plaintiff Dourif's business and ally himself with the former owner of Psi Tech, Edward Dames for their own monetary gain.
15. The suppression of facts herein alleged to have been made by Defendant was done with the intent to induce Plaintiff to give Defendant her key so that he could remove the proprietary information from Plaintiff's residence.
16. But for the representations made by Defendant to Plaintiff, Plaintiff would not have relied on Defendant Bonsall nor would she have maintained him in her employ nor allowed him to have the keys to her residence.
17. In making the representations to Plaintiff and by suppressing Defendants' secret intent to defraud Plaintiff, Plaintiff sustained injuries. This conduct was despicable conduct that subjected Plaintiffs to unjust hardship in conscious disregard for Plaintiff's rights, so as to justify an award of exemplary and punitive damages.
18.Plaintiff repeats and realleges Paragraphs 1 through 17, inclusive, of the Complaint and by this reference, makes them a part hereof as though fully set forth at length herein.
19. Based upon the facts herein alleged, and the acts of Defendant, and each of them, Defendant has received benefits without paying the fair value of said benefits and money from Plaintiff, including but not limited to: trade secrets, work product and proprietary information of Psi Tech; personal property of Plaintiff, including but not limited to: Oil painting, photographs, printer, Statue, Antique Sword, Guns, Collectors Books, etc.
20. Plaintiff detrimentally relied on the performance of Defendants, but Plaintiff has still not received fair and just compensation or return of their company documents, books, records, tapes and personal property.
21. Plaintiff has been damaged and Defendants and each of them, has been unjustly enriched as a result thereof. Defendants, and each of them, are and should be obligated to pay Plaintiff a sum of money to be determined together with interest thereon at the maximum rate of interest allowable by law from and after a date to be ascertained and according to proof at the time of trial.
22. Plaintiff repeats and realleges Paragraphs 1 through 21, inclusive, of the Complaint and by this reference, makes them a part hereof as though fully set forth at length herein.
23. At all times herein mentioned, Plaintiff was and still is the true owner of the items mentioned hereinabove; to wit: business documents, records, trade secrets, proprietary information, master tapes, personal properties such as painting, a photograph, guns, a statue, etc. Plaintiff is still entitled to ownership and/or possession of the aforementioned items.
24. Since in or about July 2000 and continuing through the present, Defendants, and each of them, took Plaintiff's property as mentioned hereinabove and converted same to its use.
25. Plaintiff has demanded the return of these items but Defendants failed and refused and continue to fail and refuse to tender the property to Plaintiff.
26. As a proximate result of Defendant's conversion, Plaintiff has suffered losses in an amount ti be determined at the time of trial.
27. The aforementioned acts of Defendants and each of them, and Does 1-100, inclusive, was willful, wanton, malicious and opressive, and was undertaken with the intent to defraud Plaintiff and to justify and award of exemplary and punitive damaged to be determined at the time of trial.
28. Plaintiff repeats and realleges Paragraphs 1 through 27, inclusive, of the Complaint and by this reference, makes them a part hereof as though fully set forth at length herein.
29. On or about July 2000 and continuing thereafter, Defendants spoke the following words of and concerning Plaintiff: (1). That Plaintiff and Defendant were involved in a romantic relationship; (2). That Defendant acted under Plaintiff's direction to engage in deceitful conduct; (3). Plaintiff lacks analytical skills relative to remote viewing; (4). Plaintiff lacks honesty and integrity; (5). Psi Tech engages in false advertising; (6). Disparaging comments about Plaintiff; and that (6). Psi Tech offers ineffective training and video courses.
30. The words were published on the Internet and Emailed to Psi Tech's customers. Statements made on the radio by Defendants were also heard by other persons whose names are not known to Plaintiff.
31. The words were slanderous per se because they acuse Plaintiff of bad business practices, disparage Plaintiff's business and impugn her character, morals and integrity.
32. The words uttered were false statements and carried a defamatory meaning.
33. As a result of the above-described words, Plaintiff has suffered general damages to her reputation in an amount to be proven at the time of trial.
34. As a further proximate result of the above-described words, Plaintiff has suffered damages to her business and property, all to her injury in an amount to be proven at the time of trial.
35. The above-described words were spoken by the Defendant with malice and oppression and were fraudulent in that his intent has been and continues to be to destroy Plaintiff; her reputation and her career. Such actions and conduct necessitate that an award of exemplary and punitive damages is justified.
36. Plaintiff repeats and realleges Paragraphs 1 through 35, inclusive, of the Complaint and by this reference, makes them a part hereof as though fully set forth at length herein.
37. On or about July 2000 and continuing thereafter, Defendant Bonsall published written material on the internet which stated that: (1). That Plaintiff and Defendant were involved in a romantic relationship; (2). That Defendant acted under Plaintiff's direction to engage in deceitful conduct; (3). Plaintiff lacks analytical skills relative to remote viewing; (4). Plaintiff lacks honesty and integrity; (5). Psi Tech engages in false advertising; (6). Psi Tech offers ineffective training and video courses.
38. The entire publication(s) are false as it pertains to Plaintiff.
39. These publications are libelous on its face. It clearly exposes Plaintiff to hatred, contempt, ridicult, and obloquy.
40. These publications were seen and read by numerous persons all over the world.
41. As a proximate result of the above-described publication(s), Plaintiff has suffered loss of her reputation, shame, mortification, and hurt feelings all to her general damage in an amount according to proof at the time of trial.
42. The above-described publication was published by Defendant with malice and oppression and Plaintiff therefore seeks an award of punitive damages.
WHEREFORE, Plaintiff prays Judgment against Defendant(s) and each of them as follows:
1. For general damages in an amount to be proven at the time of trial;
2. For special damages in an amount to be proven at the time of trial;
3. For punitive damages in an amount according to proof at the time of trial;
4. For prejudgment interest;
5. For costs of suit herein;
6. For such other and further relief as the court may deem proper.
June 6, 2001 Link K. Schwartz, A Law Corporation
By: Link K. Schwartz, Attorney for Plaintiff, Jonina Dourif