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Chapter 3-(Russian citizens)  
     
  [GERMAN/US/] COURT  
  [STATE AND LOCALITY]  
  [Plaintiff 01], [Plaintiff 02], [Plaintiff 03], [Plaintiff 04], [Plaintiff 05] and [Plaintiff 06] on behalf of themselves and all other persons similarly situated; [Organization Plaintiff 01], [Organization Plaintiff 02], [Organization Plaintiff 03] and [Organization Plaintiff 04], on behalf of themselves and all others similarly situated,
  
  Plaintiffs,  
  v.  
  STATE OF THE VATICAN CITY a/k/a “STATUS CIVITATIS VATICANAE” and its successors,
 
  HOLY SEE a/k/a “SANCTA SEDES” a/k/a ROMAN CURIA a/k/a ROMAN CATHOLIC CHURCH a/k/a CATHOLIC CHURCH and its successors,  
  BISHOP OF ROME a/k/a HIS HOLINESS a/k/a SUPREME PONTIFF a/k/a POPE BENEDICT XVI a/k/a JOSEPH ALOIS RATZINGER and his successors,  
  JESUITS a/k/a SOCIETY OF JESUS a/k/a “SOCIETAS IESU”, SUPERIOR GENERAL a/k/a PETER HANS KOLVENBACH and his successors,
  
  VATICAN BANK, a/k/a "INSTITUTE OF RELIGIOUS WORKS" or "ISTITUTO PER LE OPERE DI RELIGIONE" (IOR) and their successors;
 
  UNKNOWN CATHOLIC RELIGIOUS ORDERS and their successors,  
  UNKNOWN MERCHANT BANK, INSTITUTIONS and their successors,
  
  Defendants.  
  NO. [##########]  
  CLASS ACTION COMPLAINT FOR:  
1. HUMAN RIGHTS VIOLATIONS  
2. VIOLATIONS OF INTERNATIONAL LAW  
3. UNJUST ENRICHMENT  
4. ACCOUNTING  
5. RESTITUTION  
     
  JURY TRIAL DEMANDED  
  INTRODUCTORY STATEMENT: NATURE OF ACTION
  
1.
 This is a civil action arising under customary international law and the laws of Russia on behalf of named persons and organisations (“Plaintiffs”) and a class of all Russian citizens (and their heirs and beneficiaries) who suffered:
  
 
(i)
 Fixed, moveable and/or monetary losses arising from the Soviet Empire from 1917 to 1990.
(ii)
 Enslavement of individuals and their ancestors by agents for an on behalf of the Defendant, sponsored and directed by the Defendant, while claiming to be against the Soviet Empire.
(iii)
 Sustained psychological trauma and damage as a result of the brutal dictatorial regime of the Soviet Union and its ensuing effect in subsequent relationships including but not restricted to family, friends, authority, community and in general;
(iv)
 Additional trauma and ongoing pain as a result of the suppression of such events, including but not restricted to school/church officials, family and persistent denial by the Defendant of their clear involvement in the formation and operation of the Soviet Regime during its key years under Fr. Joseph Stalin S.J.
(v)
 Financial incapacitation due to resulting mental illness, debilitation attributable to the lack of closure and resolution to such acts of abuse;
(vi)
 Direct financial loss due to the churches unwillingness to acknowledge, nor compensate those clearly abused by its own clergy, nor offer any form of respectful nor spiritual courage in the form of a proper apology.
 
2.
 The Plaintiffs allege in this claim that the Defendant with full knowledge of their actions and with clear intention did:
  
 
(i)
 Finance the development of the Communist Party and in particular the installment of Joseph Stalin, a fully ordained Jesuit priest to the Premiership of the Soviet Union.
(ii)
 Finance the development of the Nazi Party including the appointment of Adolf Hitler, the development of the SS including the clear instructions to invade Russia.
(iii)
 Ignored, suppressed and openly sought to discredit those individuals brave enough to disclose the truth of the involvement of the Defendant in events causing and leading up to the hostilities of World War II as well as World War I.
(iv)
 Openly supported, protected and destroyed evidence against clergy accused of involvement in the establishment of the Communist party and Fr Joseph Stalin S.J.
(v)
 Deliberate tactics of stalling, delaying appeals and other methods to try and drain the limited financial resources of individual plaintiffs seeking justice for years of pain, anguish as a result of the evil acts of the Defendant so that such civil cases ultimately are withdrawn through lack of funds.
(vi)
 Ongoing use of political and social influence to use its own charitable resources as hostage by threatening the closure of key resources and withdrawal of support to political leaders unless such cases against the church are dropped, in spite of failing to disclose its true wealth, nor providing any accurate accounting for its assets.
 
3.
 That the actions of the Defendant as outlined constitute numerous counts of criminal behaviour under the laws of Russia and do further represent gross breaches of international laws and treaties in regards to human rights and crimes against humanity.
  
4.
 That the complicity of the Defendant in a number of these alleged illegal acts has been well known and in the public domain for a substantial period of time, while some of these allegations have never been fully put.
  
5.
 That the reasons why a successful action has not yet been brought against the Defendant given such serious allegations are varied, but include:  
 
(i)
The persistent claims by the Defendant to Sovereign immunity, citing the Lateran Treaty of 1929 with Fascist Dictator Mussolini and subsequent acknowledgments in other memberships to international bodies and treaties;
(ii)
The persistent claims by the Defendant to being a religious organisation representing the highest moral and spiritual codes of behaviour;
(iii)
The persistent claims by the Defendant to have no control, nor authority over the actions of subordinates and/or subsidiaries, in spite of clear evidence to the contrary;
(iv)
The use of tactics designed to stall, squash, intimidate and financial bankrupt Plaintiffs into dropping any cases;
(v)
The use of bribes, grants and other means of financial inducement to ensure there are always at least some individuals in authority loyal to ensuring action against the Defendant never occurs;
(vi)
The occasional use of force including but not limited to kidnap, assault, torture and murder to eliminate witnesses and possible action against the Defendant.
 
6.
 The Plaintiffs allege in regards to supporting evidence as to the historical and contemporary motives and behaviour of the Defendant towards Russia that:  
 
(i)
 The Defendant has a long history of collusion,
(ii)
  
(iii)
  
(iv)
  
(v)
  
(vi)
  
(vii)
  
(viii)
  
(ix)
  
 
7.
 The Plaintiffs further allege in regards to supporting evidence as to the general historical and contemporary status, purpose and operational behaviour of the Defendant that:  
 
(i)
 The founders were Paul of Tarsus, Josephus ben Matthias and the Jewish Sadducee High Priests of the House of Ananus, not Jesus and the Apostles;
(ii)
 That the purpose of the foundation of the Defendants was always for the sole purpose of an organized criminal enterprise, including but not limited to: subversion, fraud, murder, extortion, kidnapping, terrorism and subversion of public morals by:
(a)
 Render the Gnostic teachings of Jesus and the Nazarenes ineffective by producing a counter religion claiming to be the only true faith that focuses on simplistic symbolism, conformity and a hatred of knowledge.
(b)
 Perpetuate the strength and credibility of canonical Jewish sacred texts created by Jeremiah, Baruch, Nehemiah and Ezra by incorporating these texts as a key part of the liturgy of the religion.
(c)
 Destroy all texts, references to Gnosticism and any evidence to history that threatens objective (a) or (b).
(d)
 Where is not possible to destroy, re-write the evidence that contradicts claims.
(e)
 Usurp all members of Jesus’s family and disciples and where possible ensure their death.
(f)
 Use the cover of charity, religion, morality and holiness to hide ongoing criminal activity.
(g)
 Structure the church so that the House of Ananus, the former Jewish High Priests and its descendents along with other selected Sadducee Jewish families maintain effective control over the church.
(iii)
 That there exists an inventory of over 2,000 separate verifiable criminal allegations spanning the entire existence of the Defendant for the past two thousand years which shows clearly a consistent and unbroken history of criminality ranging from murder and torture to historic and unprecedented genocide and other crimes against humanity.
 
8.
 Plaintiffs (their heirs and beneficiaries) seek an accounting and abeyance of the total assets of the Defendant and to recover damages arising out of the primary allegations against the Defendant, specifically:
 
 
(i)
  
(ii)
  
(iii)
  
(iv)
  
(v)
  
(vi)
  
(vii)
  
(viii)
  
(ix)
  
 
  JURISDICTION AND VENUE  
9.
 This Court has jurisdiction pursuant to [Legal Code] as:
  
 
(i)
 Certain Plaintiffs of Russia and [State] assert claims for torts in violation of the law of Russia and accepted international laws concerning human rights and crimes against humanity;
(ii)
 The Defendant may be considered to be under the jurisdiction of the Court pursuant to [Legal Codes] as:
 
(a)
 some of the acts and transactions complained of herein occurred within this [State] and Russia;
(b)
 some of the Plaintiff Class members are residents of this [State];
(c)
 the Defendant is listed as both owning property and conducting business in [State] and Russia;
(d)
 the Defendant is registered as having a subsidiary office in [State] and Russia and;
(e)
 for the purpose of this claim, the Defendant is considered a Religious Organisation having no legal remedy for any claims of immunity, sovereign immunity, or special consideration;
(iii)
 The material allegations of the complaint relate to events and actions that are considered by national and international law not to be subject to limitations in that they concern violations of human rights and crimes against humanity;
(iv)
 Furthermore, in relation to the treatment of the Defendant in regards to material allegations of violations of human rights and crimes against humanity, the Defendant separately and joined are considered a criminal enterprise for the purpose of perpetuating and profiting from crime, therefore not entitled to rights of remedy, sovereignty, nor immunity under national and international law.
 
10.
 In respect to jurisdiction and any persistent claims by the Defendant for motions to dismiss and/or remedy from this action on the basis of sovereign immunity and/or other special exemption from law:
  
 
(i)
 International laws and conventions preclude organisations from claiming immunity where they can be found to be criminal enterprises founded for the purpose of pursuing and profiting from crime;
(ii)
 International and national laws preclude organizations from claiming immunity in clear cases of violations of human rights and crimes against humanity that are without statute of limitations;
(iii)
 Actions and events cited as material allegations against the Defendants occurring prior to any formal recognition of the diplomatic sovereignty of the co-defendant The Vatican and Russia cannot therefore be retrospectively considered subject to any claim of immunity;
(iv)
 That the Lateran Treaty of 1929 between Dictator Mussolini and The Vatican granting it sovereign status is effectively null and void due to several verifiable and repeated breaches of its conditions in relation to the condition and pledge by the Papacy to perpetual neutrality in international relations;
 
11.
 In respect to jurisdiction and any claims by the Defendant for motions to dismiss and/or remedy from this action on the basis of separateness, independence of subsidiary organisations and/or incomplete naming of Defendants:
  
 
(i)
 The by-laws, procedures and practices of the Defendant clearly indicate a highly centralized and authoritarian control over all its subsidiary branches, regardless of their status as individual entities;
(ii)
 Standing by-laws of the Defendant since the February 25, 1296 by Pope Boniface VIII through his Papal Bull preventing subsidiaries from disposing of substantial assets in any way without central approval from The Vatican, effectively rendering any argument of separateness invalid;
(iii)
 The deliberate lack of accounting and disclosure standards of the Defendant concerning its full financial position globally prevents the accurate naming of all Defendants. Therefore any motion to dismiss on incompleteness of defendants should be subject firstly to an order of full and frank disclosure of the complete financial position of the Defendant to allow for a resubmission of the claim.
 
12.
 In respect to jurisdiction and any claims by the Defendant for motions to strike down any and all material allegations falling prior to the proclamation as law of certain current laws of Russia and the recognized sovereignty of Russia:
  
 
(i)
 That the claim of apostolic succession of the Defendant in regards to its religious authority effectively means the Catholic Church today proclaims itself to be the same continuous organization with unbroken leadership as it was at the time of any ancient material allegation;
(ii)
 This means that any material allegation falling before the sovereignty of Russia and/or proclamation of a particular law can be brought forward retrospectively and included in this claim given it is the same Defendant;
(iii)
 This also means that the Defendant remains liable for all actions of previous employees, officials and third parties in its employ without limitation;
(iv)
 That the only possible way an ancient material allegation may be struck down from this claim is for the Defendant to repudiate its claim of apostolic succession, thereby admitting the Catholic Church at some ancient period is a wholly different and non-associated organisation to the present day. However, if this is admitted, then the status of the Defendant in this claim shall change from a religious organisation to merely a criminal enterprise.
 
13.
 Subject to [Legal Code], the Plaintiffs make claims against Defendants under the laws of Russia as they incorporate customary international law and international treaties recognizing the sovereignty of Russia.
 
14.
 [Legal Code] is cited in that the amount in controversy to each claim asserted and sought to be asserted herein by certain Plaintiffs exceeds the sum of US $100,000 (2006 dollars), exclusive of interest and costs.
  
15.
 [Legal Code] is cited for any claims not otherwise covered by the aforementioned jurisdictional bases.
 
  DISTRICT ASSIGNMENT  
16.
 Venue is proper in this Court pursuant to [Legal Code] as:
  
 
(i)
 some of the acts and transactions complained of herein occurred within this [State] and Russia;
(ii)
 some of the Class members are residents of this [State];
(iii)
 the Defendant is listed as both owning property and conducting business in [State] and Russia; and
(iv)
 the Defendant is registered as having a subsidiary office in [State] and Russia.
 
  PARTIES  
17.
 [Plaintiff 01], (date of birth), (background details that indicate them to be a relevant plaintiff).
  
18.
 [Plaintiff 02], (date of birth), (background details that indicate them to be a relevant plaintiff).
  
19.
 [Plaintiff 03], (date of birth), (background details that indicate them to be a relevant plaintiff).
  
20.
 [Plaintiff 04], (date of birth), (background details that indicate them to be a relevant plaintiff).
  
21.
 [Plaintiff 05], (date of birth), (background details that indicate them to be a relevant plaintiff).
  
22.
 [Plaintiff 06], (date of birth), (background details that indicate them to be a relevant plaintiff).
  
23.
 Defendant Vatican City, also known by its official title State Of The Vatican City or “Status Civitatis Vaticanae” is an organization claiming sovereignty status under several international treaties and is located in Rome, Italy with total state assets believed to be between US $5 Billion and US $10 Billion (2006 dollars).
  
24.
 Defendant Holy See also known as Roman Catholic Church and Catholic Church has its principal place of business in Vatican City Rome, Italy but has subsidiary branches in every country and virtually every state in the world with total visible assets believed to be around US $400 Billion and hidden assets of between US $3,000 Billion and US $ 6,000 Billion (2006 dollars) as the single largest and most wealthy organisation in the world.
  
25.
 Defendant Jesuits also known as Society Of Jesus or “Societas Iesu” has its principal place of business at the Jesuit Headquarters in Vatican City Rome, with total visible assets of around $3 Billion and hidden assets of between US $2,000 Billion and US $5,000 Billion (2006 dollars) as the second wealthiest organisation in the world, behind the Holy See.
  
26.
 Defendant Vatican Bank, also known by its official title "Istituto per le Opere di Religione" or Institute of Religious Works ("IOR") has its principal place of business in Vatican City Rome, Italy but conducts business and financial transactions worldwide on behalf of the Roman Catholic Church, including the Russia and [State] with total global assets believed to be between US $3 Billion and US $7 Billion (2006 dollars).
  
27.
 Defendant Catholic Church has been recognized for over 1,600 years until the beginning of the 20th century as the single largest, wealthiest organization in human history, dominating virtually all asset classes of ownership including (but not limited to) property, gold, silver, diamonds, shares and priceless artifacts.
  
28.
 Defendant Jesuits, has been in effective control of the asset management of the Roman Catholic Church as well as its own asset base since 1814 and its restoration as an Order. The Jesuits engage in for-profit business transactions through a highly complex arrangement of trusts, deeds front companies and merchant banks utilizing non disclosure laws to hide the true wealth of the Roman Catholic Church and its subsidiaries.
  
29.
 Defendants unknown are those private banking corporations who conduct business in, and who are also responsible for the acts complained of herein. Plaintiffs are unaware of the true names or capacities of the Defendants sued herein under the unknown classification, after ascertaining the true identity of a Defendant, Plaintiffs will amend the Complaint accordingly.
 
  DEFINITIONS  
30.
 “Church By-Laws” is defined as all official statements, rules, policies and procedures acknowledged as the official rules of the Holy See, the Roman Catholic Church.
  
31.
    
32.
    
33.
    
34.
    
35.
    
  FACTUAL ALLEGATIONS  
36.
 The following factual allegations are made:  
 
(i)
  
(ii)
  
(iii)
  
(iv)
  
(v)
  
(vi)
  
(vii)
  
(viii)
  
(ix)
  
(x)
  
(xi)
  
(xii)
  
(xiii)
  
(xiv)
  
(xv)
  
(xvi)
  
(xvii)
  
(xviii)
  
(xix)
  
(xx)
  
(xxi)
  
(xxii)
  
(xxiii)
  
(xxiv)
  
(xxv)
  
(xxvi)
  
(xxvii)
  
(xxviii)
  
(xxix)
  
(xxx)
  
(xxxi)
  
(xxxii)
  
 
  CLASS ALLEGATIONS  
37.
 This action is brought and may properly be maintained as a class action pursuant to the provisions of [Legal Code]. Plaintiffs bring this action on behalf of themselves and:
 
 
(i)
  
(ii)
  
(iii)
  
(iv)
  
(v)
  
(vi)
  
(vii)
  
(viii)
  
(ix)
  
 
38.
 The exact number of the members of the class, as identified above, is not known to Plaintiffs, but it is estimated that members of the class number in the tens or hundreds of thousands and are so numerous that joinder of individual members herein is impracticable.
 
39.
 Questions of fact and law common to the class predominate over any questions affecting only individual members. Common questions of fact and law include:
  
 
(i)
 Whether the IOR, Franciscan Order and Unknown Catholic Religious Orders and/or Defendant Banks improperly retained or converted looted assets of the Plaintiffs.
(ii)
 Whether Defendants were unjustly enriched by their wrongful conduct.
(iii)
 Whether Plaintiffs experienced irreparable harm by Defendants’ wrongful taking of Plaintiffs’ property and goods, supporting a claim for restitution.
(iv)
 Whether Defendants have failed to account for the Ustasha Treasury.
(v)
 Whether Defendants were directly and/or indirectly involved with the torture, plundering and/or conversion of Plaintiffs and their property and Plaintiffs’ labor in violation of international law.
(vi)
  
(vii)
  
(viii)
  
(ix)
  
 
40.
 Plaintiffs’ claims are typical of the claims of the other members of the Class, since all such claims arise out of Defendants’ actions or the actions of its agents, which resulted in the deaths, torture, assault, plunder and the loss of Plaintiffs’ and their ancestors’ rightful property, which gives Plaintiffs the right to the relief sought.
 
41.
 There is no conflict as between the named Plaintiffs and the members of the class which they represent with respect to this action, or with respect to the claims for relief set forth herein.
  
42.
 Plaintiffs are committed to the vigorous prosecution of this action and will retain competent counsel experienced in the prosecution of class actions. Accordingly, Plaintiffs are adequate representatives of the Class and will fairly and adequately protect the interests of the Class.
  
43.
 The prosecution of separate actions by individual members of the Class would create a risk of inconsistent or varying adjudications, which would establish incompatible standards of conduct for the defendants in this action.
  
44.
 Plaintiffs anticipate that there will be no difficulty in the management of this litigation. A class action is superior to other available methods for fair and efficient adjudication of the controversy. Accordingly, Certification of the Plaintiff class is appropriate under [Legal Code].
  
  LEGAL AND EQUITABLE TOLLING  
45.
 Plaintiffs’ legal right to seek compensation for the alleged war crimes and crimes against humanity actions of the Defendents is preserved by the following international laws:
 
 
(i)
 Convention on the Non-Applicability of Statutory Limitations to War Crimes and Crimes Against Humanity (26 November 1968). Accordingly, there are no statutory limitations on claims of war crimes, crimes against humanity, or genocide.
(ii)
  
(iii)
  
(iv)
  
(v)
  
(vi)
  
(vii)
  
(viii)
  
(ix)
  
 
46.
 Furthermore, Plaintiffs’ legal right to seek compensation for alleged actions of the Defendants is preserved in the following legal statutes:
 
 
(i)
  
(ii)
  
(iii)
  
(iv)
  
(v)
  
(vi)
  
(vii)
  
(viii)
  
(ix)
  
 
47.
 The Plaintiff's believe that no statute of limitations has begun to run on the cause of action stated herein, nor can be rightly claimed by the Defendant as:
 
 
(i)
 The Plaintiff's have been denied access to vital information essential to pursue the stated claims as a result of Defendants' fraudulent concealment of their misconduct, without any fault or want of diligence or due care on the part of Plaintiffs or Defendants' victims.
(ii)
 At no time have Defendants made any reasonable attempt to compensate Plaintiffs and members of the Class for their injuries and losses. Such failure should estop Defendants from interposing any time bar defense to these claims.
(iii)
 Evidence of the extent of the Defendants’ participation in wrongdoing has more fully come to light in recent years as a result of the disclosure of archived and declassified documents.
(iv)
 Defendants' misconduct is continuing. Defendants are therefore estopped from interposing any type of time bar defense to these claims.
 
  CAUSES OF ACTION  
  FIRST CAUSE OF ACTION  
48.
 HUMAN RIGHTS VIOLATIONS. Plaintiffs reallege and incorporate herein, as though fully set forth, the allegations of all preceding paragraphs of the Complaint:  
 
(i)
  
(ii)
  
(iii)
  
(iv)
  
(v)
  
(vi)
  
(vii)
  
(viii)
  
(ix)
  
 
  SECOND CAUSE OF ACTION  
49.
 VIOLATIONS OF INTERNATIONAL LAW. Plaintiffs reallege and incorporate herein, as though fully set forth, the allegations of all preceding paragraphs of the Complaint.
  
 
(i)
  
(ii)
  
(iii)
  
(iv)
  
(v)
  
(vi)
  
(vii)
  
(viii)
  
(ix)
  
 
  THIRD CAUSE OF ACTION  
50.
 UNJUST ENRICHMENT. Plaintiffs reallege and incorporate herein, as though fully set forth, the allegations of all preceding paragraphs of the Complaint.
  
 
(i)
  
(ii)
  
(iii)
  
(iv)
  
(v)
  
(vi)
  
(vii)
  
(viii)
  
(ix)
  
 
  FOURTH CAUSE OF ACTION  
51.
 ACCOUNTING. Plaintiffs reallege and incorporate herein, as though fully set forth, the allegations of all preceding paragraphs of the Complaint.
  
 
(i)
  
(ii)
  
(iii)
  
(iv)
  
(v)
  
(vi)
  
(vii)
  
(viii)
  
(ix)
  
 
  FIFTH CAUSE OF ACTION  
52.
 RESTITUTION. Plaintiffs reallege and incorporate herein, as though fully set forth, the allegations of all preceding paragraphs of the Complaint.  
 
(i)
  
(ii)
  
(iii)
  
(iv)
  
(v)
  
(vi)
  
(vii)
  
(viii)
  
(ix)
  
 
  WHEREFORE, Plaintiffs plead that the Court:
  
1.
 Certify this action as a class action pursuant to [Legal Code], and designating named Plaintiffs as the class representatives and counsel for Plaintiffs as Class counsel.
 
2.
 
3.
    
4.
    
5.
    
6.
    
7.
    
8.
    
9.
    
10.
    
  DATED: [DATE]  
  [LEGAL FIRM]  
  [ADDRESS]  

 
 
 

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