IN THE COURT OF COMMON PLEAS
FRANKLIN COUNTY, OHIO
Case No: 77CV-11-4706
THE CHILDREN OF GOD, DAVID BRANDT, AKA DAVID BERG, AKA MOSES DAVID, et al.
Plaintiff for her cause of action herein says that Plaintiff and John Patrick Krounapple are husband and wife. That in 1972 when Plaintiff was 16 years of age Plaintiff became a member of the Defendant organization known as the Children of God.
In the summer of 1975 while in a pregnant condition the leaders of the Children of God organization informed Plaintiff that she and her husband should not live together. That it would be for the best interest of the Children of God organization that they live separately.
That upon being so informed The Children of God organization separated Plaintiff and Plaintiff's husband by sending each to a different country.
Subsequently, Defendant, The Children of God caused Plaintiff and Plaintiff's husband to live together once more. But Plaintiff's husband always remained under the influence of the Defendants.
In 1976 Defendant David Berg, aka David Brandt, aka David Moses began to prescribe certain conduct for the female members and taught them in the art of sex seduction and to be "Fishers of Men" and "Happy Hookers for Jesus." that being under the influence of the Defendant, Plaintiff was persuaded to be in accord with such activity but reasoned that this was truly contrary to the teachings in the Christian religion and so informed her husband and left the organization, and that her husband also promised to leave.
That upon arrival in America Plaintiff learned that the Defendant, The Children of God were not only in control of Plaintiff's husband but were also in control of the parties two children, to wit: (omitted to protect the innocent).
That Plaintiff attempted to reconcile with her husband but that Defendant refused Plaintiff the right to come into the headquarters of the Defendants to see her husband and children, and are depriving Plaintiff of the marriage contract.
That Defendants are the agents of the Defendant, The Children of God and are in control of Plaintiff's husband.
That they have alienated his affection and love for Plaintiff through their concerted conduct. That as a result of their influence over Plaintiff's husband, Plaintiff has been damaged in the sum of one million dollars for which Plaintiff asks for judgment in the sum of one million dollars ($1,000,000.00).
That as a result of their influence over Plaintiff's husband the Defendants have deprived Plaintiff of Plaintiff's security as a wife and mother and that Defendants have deprived their children of their parent.
That Defendants have made a beggar of Plaintiff's husband by reducing him to a street seller of filthy literature and made a beguiler of Plaintiff's husband in the name of religion all to her damage in the sum of $500,000.00 (five hundred thousand dollars) for which Plaintiff asks for judgment in the sum of five hundred thousand dollars.
WHEREFORE Plaintiff asks for judgment in the sum of $1,500,000.00 together with other and further relief to which Plaintiff may be entitled to in the premises.
 JOURNAL ENTRY
This 21st day of June 1979 plaintiff's cause came on to be heard and the court from the evidence adduced finds that plaintiff is entitled to a Judgment in the sum of One Million Dollars ($1,000,000.00) for damages.
It is therefore ordered adjudged and decreed that plaintiff be and she is hereby granted One Million Dollars. Cost taxed against Defendant.
Signed: William T. Gillie, Judge