10a28641 2 2012-07-11 depositionofclarkcarr ocr

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Deposition of Clark Robert Nixdorf Carr Desmond vs. Narconon

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R. Leonard CSR, Inc.

IN THE STATE COURT OF DEKALB COUNTY

STATE OF GEORGIA

PATRICK C. DESMOND AND MARY C. DESMOND, INDIVIDUALLY, AND MARY C. DESMOND, AS ADMINISTRATRIXOF THE ESTATE OF PATRICK W. DESMOND,

PLAINTIFFS,

vs.

NARCONON OF GEORGIA, INC., DELGADO DEVELOPMENT, INC., SOVEREIGN PLACE LLC, SOVEREIGN PLACE APARTMENT MANAGEMENT, INC., LISA CAROLINA ROBBINS, M.D., THE ROBBINS GROUP, INC., AND NARCONON INTERNATIONAL,

DEFENDANTS.

CIVIL ACTION NO. 10A28641-2

DEPOSITION OF CLARK ROBERT NIXDORF CARR WEDNESDAY, JULY 11, 2012

REPORTED BY: ROBIN LEONARD CSR No: 3334 '·

10: 1:,

R. LEONARD, C.S.R., INC. CERTIFIED SHORTHAND REPORTERS 4142 MEADOW RIDGE PLACE ENCINO, CALIFORNIA 91436 (818) 995-2449 FILE NO.: 37159

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THE DEPOSITION OF CLARK ROBERT NIXDORF CARR,

WITNESS, TAKEN ON BEHALF OF PLAINTIFFS,

AT 7000 HOLLYWOOD BOULEVARD, BARCELONA ROOM,

HOLLYWOOD, CALIFORNIA 90028,

AT 9:02A.M., WEDNESDAY, JULY 11, 2012,

BEFORE ROBIN LEONARD, CSR NO. 3334, A

CERTIFIED SHORTHAND REPORTER WITHIN AND FOR

THE COUNTY OF LOS ANGELES AND

STATE OF CALIFORNIA, PURSUANT TO NOTICE.

APPEARANCES OF COUNSEL:

FOR PLAINTIFFS:

HARRIS PENN LOWRY DELCAMPO, LLP

BY: JEFFREY R. HARRIS, ESQ.

400 COLONY SQUARE

1201 PEACHTREE STREET

SUITE 900

ATLANTA, GEORGIA 30361

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R. Leonard CSR Inc.

APPEARANCES CONTINUED

FOR PLAINTIFFS:

FRANKLIN LAW LLC

BY: REBECCA FRANKLIN, ATTORNEY AT LAW

400 COLONY SQUARE

1201 PEACHTREE STREET

SUITE 900


FOR DEFENDANT NARCONON INTERNATIONAL:

CARLOCK, COPELAND & STAIR, LLP

BY: DAVID F. ROOT, ESQ.

191 PEACHTREE STREET, NE

SUITE 3600


MOXON & KOBRIN

BY: HELENA K. KOBRIN, ATTORNEY AT LAW

3500 W. OLIVE

SUITE 300

BURBANK, CALIFORNIA 91302

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Deposition of Clark Robert Nixdorf Can Desmond vs. Narconon

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APPEARANCES CONTINUED

FOR DEFENDANT NARCONON OF GEORGIA, INC.:

DREW, ECKLE & FARNHAM, LLP

BY: LISA RICHARDSON, ATTORNEY AT LAW

880 W. PEACHTREE STREET

P.O. BOX 7600


FOR DEFENDANT DELGADO DEVELOPMENT, INC.:

DOWNEY & CLEVELAND, LLP

BY: KAREN ST. AMAND, ATTORNEY AT LAW

288 WASHINGTON AVENUE

MARIETTA, GEORGIA 30060

(APPEARING TELEPHONICALLY)

ALSO PRESENT: DENNIS DAVIS (VIDEOGRAPHER)

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Deposition of Clark Robert Nixdorf Carr

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I N D E X

WITNESS EXAMINATION

CLARK ROBERT NIXDORF CARR

BY MR. HARRIS

BY MR. ROOT

FURTHER EXAMINATION

BY MR. HARRIS

E X H I B I T S

MARKED

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PLAINTIFFS' NOTICE OF RULE 30(B) (6)

VIDEO DEPOSITION AND NOTICE TO

PRODUCE DEFENDANT NARCONON

INTERNATIONAL

RUNNING AN EFFECTIVE NARCONON CENTER

MANUAL

COMPOSITE OF PAPERS DONE ON THE

HUBBARD DETOXIFICATION PROGRAM

Desmond vs. Narconon

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188

197

PAGE

77

28

129

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Deposition of Clark Robert Nixdmf Can

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INDEX CONTINUED

SEPTEMBER, 2008 COMMENDATION TO

NARCONON OF GEORGIA

AUGUST, 2008 COMMENDATION TO

MARY RIESER

SCREEN SHOT FROM ATLANTA RECOVERY

CENTER WEBSITE

NARCONON OF GEORGIA PR REPORT

NARCONON OF GEORGIA LEGAL REPORTS

NARCONON OF GEORGIA WEEKLY STATISTICS

REPORT

NARCONON OF GEORGIA ITEMIZATION OF

INCOME

Desmond vs. Narconon

164

165

188

175

172

175

178

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HOLLYWOOD, CALIFORNIA; WEDNESDAY, JULY 11, 2012

9:02 A.M.

-000-

THE VIDEOGRAPHER: GOOD MORNING. MY NAME IS

DENNIS DAVIS. I'M A CERTIFIED LEGAL VIDEO SPECIALIST

AND I REPRESENT R. LEONARD CSR. I AM NOT FINANCIALLY

INTERESTED IN THIS ACTION NOR AM I A RELATIVE OR

EMPLOYEE OF ANY ATTORNEY OR ANY OF THE PARTIES.

TODAY'S DATE IS WEDNESDAY, JULY 11TH, 2012.

THE TIME IS APPROXIMATELY 9:02 A.M. THIS DEPOSITION IS

TAKING PLACE AT THE HOLLYWOOD ROOSEVELT HOTEL, 7000

HOLLYWOOD BOULEVARD IN HOLLYWOOD, CALIFORNIA. THE CASE

NUMBER IS 10A28641-2, ENTITLED PATRICK C. DESMOND VS.

NARCONON OF GEORGIA, ET AL.

THIS DEPOSITION IS BEING TAKEN ON BEHALF OF THE

PLAINTIFF. OUR DEPONENT TODAY IS CLARK CARR. OUR COURT

REPORTER IS ROBIN LEONARD.

COULD WE HAVE APPEARANCES FOR THE RECORD.

MR. HARRIS: JEFF HARRIS ON BEHALF OF THE

PLAINTIFF.

MS. FRANKLIN: REBECCA FRANKLIN ON BEHALF OF THE

PLAINTIFF.

MR. ROOT: DAVE ROOT ON BEHALF OF NARCONON

INTERNATIONAL.

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MS. KOBRIN: HELENA KOBRIN ON BEHALF OF NARCONON

INTERNATIONAL AND THE WITNESS.

MS. RICHARDSON: LISA RICHARDSON ON BEHALF OF

NARCONON OF GEORGIA.

MS. ST. AMAND: KAREN ST. AMAND ON BEHALF OF

DELGADO DEVELOPMENT, INC.

THE VIDEOGRAPHER: WOULD THE COURT REPORTER PLEASE

SWEAR IN THE WITNESS.

CLARK ROBERT NIXDORF CARR,

A WITNESS HEREIN, HAVING BEEN DULY AFFIRMED,

WAS EXAMINED AND TESTIFIED AS FOLLOWS:

EXAMINATION

BY MR. HARRIS:

Q ALL RIGHT.

THIS WILL BE THE DEPOSITION OF THE DEFENDANT

NARCONON INTERNATIONAL TAKEN PURSUANT TO NOTICE AND BY

AGREEMENT OF COUNSEL. IT'S TAKEN FOR ALL PURPOSES

ALLOWED BY THE GEORGIA CIVIL PRACTICE ACT INCLUDING

CROSS-EXAMINATION AND PRESERVATION OF EVIDENCE FOR USE

AT TRIAL. THE DEPOSITION IS TAKEN IN ACCORDANCE WITH

THE CIVIL PRACTICE ACT AND IN ACCORDANCE WITH THE

COURT'S STANDING ORDER REGARDING DISCOVERY CONDUCT.

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GOOD MORNING, MR. CARR. HOW ARE YOU?

A GOOD MORNING.

Q WE'RE TAKING YOUR DEPOSITION HERE TODAY IN

HOLLYWOOD, CALIFORNIA, CORRECT?

A YES.

Q AND HOLLYWOOD IS WHERE NARCONON INTERNATIONAL

IS LOCATED?

A YES.

Q WHAT IS THE LOCATION OR WHAT IS THE ADDRESS OF

NARCONON INTERNATIONAL?

A 4652 HOLLYWOOD BOULEVARD, LOS ANGELES, 90027.

IT'S IN THE EAST SECTION OF HOLLYWOOD.

Q ALL RIGHT.

AND YOUR DEPOSITION TODAY IS BEING, YOU ARE

APPEARING HERE TODAY ON BEHALF OF NARCONON

INTERNATIONAL, CORRECT?

A THE CORPORATION, YES.

Q NOW, UNDER GEORGIA LAW THERE IS A PROCESS WHERE

A PARTY CAN REQUEST THAT A CORPORATE DEFENDANT PRODUCE A

WITNESS TO TALK ABOUT CERTAIN TOPICS AND IT IS MY

UNDERSTANDING THAT THAT IS THE CAPACITY THAT YOU'VE BEEN

PRODUCED HERE TODAY.

A YES.

Q AND YOU HAVE ACTUALLY BEEN A CORPORATE

REPRESENTATIVE ON BEHALF OF NARCONON BEFORE IN OTHER

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R Leonard CSR, Inc.

CASES, HAVE YOU NOT, SIR?

A NO. THIS IS THE FIRST CASE THAT I'VE ACTUALLY

HAD TO DO A DEPOSITION IN OR I HAVE NOT HAD TO APPEAR IN

COURT.

Q SO YOU'VE NEVER BEEN THE CORPORATE

REPRESENTATIVE IN ANY CASE BEFORE?

A IF YOU'RE REFERRING TO THIS CLAUSE 30(B) (6),

THIS IS THE FIRST TIME I'VE DONE THAT.

Q OKAY.

WELL, THERE'S DIFFERENT WAYS OF DOING IT IN

DIFFERENT STATES. SOMETIMES IT'S THE PERSON MOST

KNOWLEDGEABLE. HAVE YOU EVER APPEARED IN THAT CAPACITY

BEFORE ON BEHALF OF NARCONON INTERNATIONAL?

A NO.

Q YOU ARE THE PRESIDENT OF NARCONON


A YES.

Q WHAT DOES THE PRESIDENT OF NARCONON

INTERNATIONAL DO?

A WELL, I'M THE CORPORATE OFFICER, THE PRESIDENT,

AND I LOOK AT BOARD MINUTES, HOLD BOARD MEETINGS AND SO

FORTH. THOSE THINGS AS ARE REQUIRED BY LAW. AND

APPROVE LARGE EXPENDITURES.

AND THEN AS THE, SEPARATE FROM THAT MY FUNCTION

IS I'M EXTERNALLY FACING. IN OTHER WORDS, I DON'T RUN

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THE NARCONON, YOU KNOW, RUN THE NETWORK THROUGH OUR

PROGRAM. I -- I INTRODUCE THE PROGRAM IN NEW AREAS, TO

GOVERNMENTS, SPEAK AT SCIENCE CONFERENCES, AND SO FORTH.

Q ONE OF YOUR MAJOR ROLES IS ACTUALLY HANDLING

PUBLIC RELATIONS FOR NARCONON INTERNATIONAL; FAIR?

A I DO COMMUNITY RELATIONS AND PUBLIC RELATIONS.

Q NOW, ONE OF THE REQUIREMENTS UNDER GEORGIA LAW

IS THAT IF YOU DON'T KNOW SOMETHING ABOUT THE TOPICS

THAT WE HAVE IDENTIFIED IN OUR NOTICE YOU ARE REQUIRED

TO EDUCATE YOURSELF ABOUT THOSE TOPICS.

HAVE YOU DONE THAT?

A I'VE DONE THAT TO THE BEST OF MY ABILITY, YES.

Q AND THERE ARE A NUMBER OF TOPICS HERE IN THIS

NOTICE AND WE'VE ASKED YOU TO LOOK UP OR TO LOOK INTO

CERTAIN THINGS.

HAVE YOU DONE THAT?

A YES, I HAVE.

Q ARE THERE ANY TOPICS THAT WE'VE ASKED YOU TO

LOOK INTO AND TO SPEAK ON BEHALF OF NARCONON

INTERNATIONAL THAT YOU'RE NOT READY TO TALK ABOUT TODAY?

A NO.

Q SO YOU'RE COMFORTABLE THAT ALL THE TOPICS THAT

I'VE IDENTIFIED HERE ON THIS 30 (B) (6) DEPOSITION NOTICE,

THAT YOU'RE READY TO TALK TO ME AND TO THE JURY ABOUT

THOSE TOPICS?

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A YES. TO THE EXTENT THAT NARCONON INTERNATIONAL

KNOWS ANYTHING ABOUT THEM. IN OTHER WORDS, THERE ARE

SOME THINGS THAT I WAS NOT FAMILIAR WITH BUT I

FAMILIARIZED MYSELF WITH THEM IN ORDER TO ANSWER YOUR

QUESTIONS.

Q UNDERSTOOD.

AND YOU UNDERSTAND THAT WHEN YOU'RE SPEAKING

HERE TODAY IN THIS DEPOSITION, YOU ARE SPEAKING AS THE

CORPORATE REPRESENTATIVE OF NARCONON INTERNATIONAL AND

NOT SIMPLY AS CLARK CARR?

A YES.

Q EVEN THOUGH YOU MAY BE THE PRESIDENT?

A YES.

Q WHAT'S THE DIFFERENCE BETWEEN THE PRESIDENT AND

THE EXECUTIVE DIRECTOR?

A AS I SAID, I'M EXTERNALLY FACING. I TRAVEL A

GREAT DEAL, VISITED ABOUT 20 COUNTRIES AND WILL DO,

SPEAK AT CONFERENCES AND SO FORTH.

THE EXECUTIVE DIRECTOR WORKS ON A WEEK-TO-WEEK

BASIS, WORKING WITH THE STAFF OF NARCONON INTERNATIONAL

ON THE FUNCTIONS THAT HAVE TO DO WITH THE EXISTING

NARCONON NETWORK.

Q ON THE NARCONON INTERNATIONAL ORG BOARD, IS THE

EXECUTIVE DIRECTOR EQUIVALENT, SUPERIOR OR INFERIOR TO

THE PRESIDENT?

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Deposition of Clark Robert Nixdorf Carr Desmond vs. N arconon

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R. Leonard CSR. Inc.

A WELL, AS THE CORPORATE OFFICER, I AM THAT. IN

OTHER WORDS, HE IS NOT SUPERIOR TO THAT. ON THE

ORGANIZATION BOARD OF NARCONON HE IS, HE IS MY SUPERIOR

ALTHOUGH WE WORK PRETTY MUCH AS EQUIVALENT ENTITIES. HE

DOESN'T DO MY JOB, I DON'T HAVE DO HIS JOB, BUT WE

CONSULT REGULARLY.

Q ALL RIGHT.

WELL, LET'S BACK UP.

NARCONON INTERNATIONAL IS AN ORGANIZATION THAT

LICENSES THE USE OF CERTAIN MATERIALS TO NARCONON

CENTERS LOCATED THROUGHOUT THE WORLD, CORRECT?

A YES.

Q AND WHAT NARCONON IS OR WHAT THE INDIVIDUAL

CENTERS ARE ARE DRUG ALCOHOL OR -- EXCUSE ME -- DRUG AND

ALCOHOL REHABILITATION PROGRAMS, CORRECT?

A WE HAVE TWO ASPECTS. ONE IS DRUG AND ALCOHOL

REHABILITATION AND THE OTHER IS DRUG PREVENTION AND

EDUCATION.

Q FAIR ENOUGH.

ALL RIGHT. SO INDIVIDUAL CENTERS ARE LOCATED

THROUGHOUT THE WORLD, RIGHT?

A YES.

Q AND THOSE INDIVIDUAL CENTERS ARE BOTH IN THE

UNITED STATES AND MANY OTHER COUNTRIES THROUGHOUT THE

WORLD, CORRECT?

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R. Leonard C SR, Inc.

A YES.

Q HOW MANY INDIVIDUAL NARCONON CENTERS ARE THERE?

A I -- ABOUT 150 INCLUDING DRUG EDUCATION AND

REHABILITATION. ABOUT 57, I THINK, REHABILITATION

CENTERS.

Q ALL RIGHT.

SO 57 REHAB CENTERS. THE REST WE CAN SAFELY

SAY ARE EDUCATION PROGRAMS?

A DEDICATED TO EDUCATION, YEAH.

Q HOW MANY OF THE 57 REHAB CENTERS, HOW MANY OF

THOSE ARE LOCATED IN THE UNITED STATES?

A I THINK WE HAVE 12 IN THE UNITED STATES.

Q AND HOW MANY OF THOSE ARE LOCATED IN GEORGIA?

A ONE.

Q ALL RIGHT.

NOW, THE WAY THAT IT WORKS IS THERE ARE

MATERIALS THAT THE INDIVIDUAL CENTERS UTILIZE IN THEIR

REHAB PROGRAMS TO ADDRESS THE REHABILITATION NEEDS OF

STUDENTS, CORRECT?

A THAT'S WHAT THEY HAVE A LICENSE TO USE OR

THE THE MATERIALS THAT WE HAVE THROUGH OUR TRADEMARK

LICENSE.

Q AND THE MATERIALS ARE LICENSED TO THE

INDIVIDUAL CENTERS BY NARCONON INTERNATIONAL?

A RIGHT.

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Q AND IN TURN, ABLE, WHICH IS THE ASSOCIATION OF

BETTER LIVING AND EDUCATION, LICENSES THOSE MATERIALS TO

NARCONON INTERNATIONAL, CORRECT?

A THEY -- YES.

Q NOW, MATERIALS THAT ARE USED IN THE TREATMENT

OF DRUG AND ALCOHOL OR PROVIDING DRUG AND ALCOHOL

TREATMENT SERVICES TO INDIVIDUAL STUDENTS, THOSE

MATERIALS ARE BASED ON THE WRITINGS OF L. RON HUBBARD,

CORRECT?

A YES, THEY ARE.

Q AND L. RON HUBBARD IS THE FOUNDER OF THE CHURCH

OF SCIENTOLOGY, CORRECT?

A HE IS THE FOUNDER OF THE APPLIED RELIGIOUS

PHILOSOPHY OF SCIENTOLOGY. HE ACTUALLY DID NOT FOUND

THE CHURCH.

Q OKAY. ALL RIGHT.

WELL, L. RON HUBBARD HAD NO TRAINING IN DRUG

AND ALCOHOL REHABILITATION, DID HE?

A WELL, L. RON HUBBARD DID RESEARCH IN MANY AREAS

DURING HIS LIFE. ONE OF THEM WAS THE EFFECT OF DRUGS

AND ALCOHOL ON THE INDIVIDUAL.

Q DID L. RON HUBBARD HAVE ANY FORMAL TRAINING IN

THE TREATMENT OF INDIVIDUALS WHO NEEDED TO HAVE DRUG AND

ALCOHOL REHABILITATION?

A I DON'T KNOW.

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Q YOU DON'T KNOW?

A NO, I DON'T KNOW WHAT WAS THE, ALL THE TRAINING

MR. HUBBARD HAD.

Q ALL RIGHT.

NEVERTHELESS, THE COURSE, THE COURSES THAT

INDIVIDUALS GO THROUGH AT THE INDIVIDUAL CENTERS ARE

COMPRISED OF EIGHT DIFFERENT BOOKS, RIGHT?

A YES. STANDARDIZED MANUALS.

Q THEY'RE STANDARDIZED MANUALS, AND THE

STANDARDIZED MANUALS ARE PROVIDED TO EVERY ONE OF THE 57

DRUG AND ALCOHOL TREATMENT CENTERS IN THE SAME WAY,

CORRECT?

A IN DIFFERENT LANGUAGES; YES.

Q FAIR ENOUGH.

DIFFERENT LANGUAGES BUT IT'S ALL THE SAME

MATERIAL?

A THOSE ARE THE MATERIALS THAT WERE LICENSED TO

USE, YES.

Q BUT THE COURSE BOOKS ARE ALL THE SAME, ALL 57

CENTERS GET THE SAME COURSE BOOKS WITH THE EXCEPTION OF

THEM BEING TRANSLATED INTO WHATEVER LANGUAGE IS NEEDED?

A THERE MAY BE CHANGES IN ILLUSTRATIONS DEPENDING

UPON THE CULTURE OF THE COUNTRY AND SO FORTH, BUT

OTHERWISE THEY'RE THE SAME, THE WRITTEN MATERIALS ARE

THE SAME.

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Q AND THEY'RE INTENDED TO BE THE SAME?

A YES, IT'S A STANDARD PROGRAM,

Q RIGHT. AND WHAT NARCONON INTERNATIONAL IS

TRYING TO DO IS TO ENSURE THE USE OF WHAT IS CALLED

STANDARD TECH; FAIR?

A YES. A MODEL THAT WE COULD SAY THE MODEL WILL

BE DELIVERED THE SAME HERE AS THERE.

Q OKAY.

NOW, THERE ARE EIGHT, EIGHT MODULES, EIGHT

COURSE BOOKS. THOSE EIGHT COURSE BOOKS, AS WE HAVE

DISCUSSED, ARE BASED ON THE TEACHINGS OF L. RON HUBBARD

OR THE WRITINGS OF L. RON HUBBARD?

A YES.

Q AND IN ADDITION TO THE EIGHT COURSE BOOKS AT

THE BEGINNING OF THE PROGRAM THERE'S WHAT'S REFERRED TO

AS THE SAUNA PROGRAM, CORRECT?

A IT'S ONE OF THE STEPS; YES.

Q WELL, IS IT SUPPOSED TO BE THE FIRST STEP?

A NO, IT'S NOT THE FIRST STEP.

Q ALL RIGHT.

WELL, THERE'S A COURSE BOOK BEFORE THE SAUNA

PROGRAM BEGINS, I THINK, RIGHT?

A YES.

Q ALL RIGHT.

AND THEN THE SAUNA PROGRAM IS THE SECOND STEP,

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I GUESS, IS WHAT --

A IT'S CALLED THE NARCONON NEW LIFE

DETOXIFICATION PROGRAM. THAT'S THE PRECISE NAME.

Q DO YOU KNOW WHAT I'M TALKING ABOUT WHEN I USE

THE TERM "SAUNA PROGRAM"?

A YES, I DO.

Q AND, IN FACT, I DON'T WANT TO HAVE TO DIG THEM

OUT BUT THERE ARE LITERALLY HUNDREDS OF DOCUMENTS THAT

HAVE BEEN PRODUCED BY NARCONON INTERNATIONAL REFERRED TO

AS THE SAUNA PROGRAM?

A YES. THAT'S THE COMMON ABBREVIATION.

Q ALL RIGHT.

AND WHAT THE INTENT OF THE PROGRAM IS IS THAT A

STUDENT WILL COME IN AND GO THROUGH THE SAUNA PROGRAM;

THAT THAT SOMEHOW PROVIDES SOME DETOXIFICATION BENEFITS?

A DEFINING THE TERM DETOXIFICATION IS ACTUALLY

REMOVING TOXIC RESIDUALS FROM THE BODY, YES.

Q EXPLAIN TO THE JURY, IF YOU WOULD,

SCIENTIFICALLY HOW THE USE OF THE SAUNA PROGRAM PROVIDES

ANY DETOXIFICATION BENEFITS TO STUDENTS.

A WELL, THERE HAVE BEEN QUITE A FEW STUDIES OF

THE USE OF THIS PROGRAM CONSIDERING DIFFERENT TOXIC

RESIDUALS IN THE BODY.

THE FACT IS THAT IT IS KNOWN THAT THE HUMAN

BODY THROUGH THE AIR, THROUGH FOOD, THROUGH WATER,

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ABSORPTION THROUGH THE SKIN CAN ABSORB TOXINS. WITH

REGARD TO DRUGS, A PERSON SMOKES, INHALES, EATS, DRINKS

DRUGS OR ALCOHOL THAT ARE METABOLIZED IN THE BODY AND

BROKEN DOWN INTO DIFFERENT COMPONENTS. THESE -- BECAUSE

THEY HAVE TOXIC DIRECT EFFECTS OR TOXIC SIDE EFFECTS AND

THAT'S THE FUNCTION OF THE LIVER, THE KIDNEYS AND SO

FORTH.

IT WAS LONG THOUGHT THAT THESE WERE ENTIRELY

ELIMINATED FROM THE BODY BECAUSE AFTER A PERIOD OF WEEKS

OR MONTHS YOU WILL FIND IN THE URINE AND IN THE BLOOD NO

EVIDENCE OF THESE. HOWEVER, MR. HUBBARD POSTULATED BACK

IN THE LATE '70S BECAUSE THERE WERE LONG-TERM EFFECTS,

CONTINUING EFFECTS OF DRUGS EVEN AFTER THE PERSON'S BODY

WAS SUPPOSEDLY CLEAN, THAT RESIDUALS MIGHT BE PERSISTING

IN THE TISSUE AFTER THE LIVER AND KIDNEYS HAD CLEANED

THE BLOOD AS BEST THEY COULD.

AND THE TRUTH IS, ALL DRUGS AND ALCOHOL HAVE AN

AFFINITY FOR FATTY TISSUE BECAUSE THAT'S THEIR, THEY'RE

SIMILAR CHEMICALS THAT HAVE AN AFFINITY FOR LIPOFILIC

OR -- THEY'RE CALLED LIPOFILIC, MEANING FAT LOVING.

AND SO MR. HUBBARD DEVELOPED A, PILOTED A

PROGRAM FIRST AS A RUNNING PROGRAM AND LATER AS A

PROGRAM USING LOW HEAT DRY SAUNAS TO, WITH A REGIMEN OF

VITAMINS, EXERCISE AND REPEATED PERIODS OF SWEATING IN A

SAUNA TO TRY TO REMOVE OR REDUCE THE BODY BURDEN OF

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THESE TOXIC RESIDUALS.

AND IT WAS CAREFULLY PILOTED AND RESEARCHED AND

THEN IT WAS ADOPTED BY NARCONON BECAUSE NARCONON HAD

BEEN OPERATING FOR SOME YEARS BEFORE THAT. THIS WAS

AROUND 1979. AND THE EFFECT IS, OVER A PERIOD OF A FEW

WEEKS THE PERSON SWEATING, EXERCISING, TAKING VITAMINS

TO CAUSE AN INCREASED METABOLIZATION OF THE FATTY ACIDS

IN THE BODY AND THEN REPEATED PERIODS OF SWEATING DURING

THE DAY, COOLING OFF, REPLACING THE CELL SALTS AND

CALCIUM AND MAGNESIUM AND POTASSIUM AND SO FORTH, THE

PERSON GOES THROUGH A PERIOD OF EXPERIENCING SOME, SOME

OF THESE, THE EFFECTS OF EARLIER TOXINS THAT HAVE BEEN

TAKEN AND THOSE ARE THE EFFECTS THAT HE EXPERIENCES.

OVER A PERIOD OF TIME THIS REDUCES TO A POINT TO WHERE

HE FEELS NO LONGER THE EFFECTS OF PAST DRUGS THAT HE HAS

TAKEN.

WHAT THE ADDICT COMMONLY SAYS IS THE DRUGS ARE

TALKING TO ME AND THIS WAS LONG THOUGHT TO BE JUST A

PSYCHOLOGICAL PHENOMENA BUT OUR POSTULATE IS THAT

CHEMICALLY SPEAKING THEY WERE. THERE WAS AN EFFECT

THEREOF.

WE CAN'T --

Q ARE YOU A MEDICAL DOCTOR?

A NO, I'M NOT A MEDICAL DR.

Q AND WAS MR. HUBBARD A MEDICAL DOCTOR?

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A NOT TO MY KNOWLEDGE.

Q IS IT THE POSITION OF NARCONON INTERNATIONAL

THAT THE SAUNA PROGRAM DETOXIFIES STUDENTS?

A IT IS OUR POSITION THAT A PERSON DOING THIS

PROGRAM WILL HAVE BENEFITS THAT AID IN HIS BEING ABLE TO

LIVE STABLY OFF DRUGS AND WITH LESS URGE, LESS CRAVING

OF DRUGS AND URGE TO RELAPSE AFTERWARD.

WE DO NOT CLAIM ANY DIRECT HEALTH BENEFIT.

THAT'S NOT OUR JOB IN DOING IT. WE'RE DOING IT AS PART

OF OUR OVERALL PROGRAM OF HELPING THE PERSON RECOVER

FROM DRUGS.

Q IS THE WORD DETOXIFICATION USED IN NARCONON

INTERNATIONAL'S LITERATURE?

A YES.

Q IS IT THE POSITION OF NARCONON INTERNATIONAL

THAT THE SAUNA PROGRAM DETOXIFIES STUDENTS WHO ARE IN

THE NARCONON PROGRAMS?

A THAT IT DETOXIFIES THEM TO SOME EXTENT. IT

REDUCES THE TOXIC BODY BURDEN OF THEIR BODY TO SOME

EXTENT, YES.

Q SO YOUR POSITION, THE, INTERNATIONAL'S POSITION

IS THERE IS A DETOXIFICATION BENEFIT TO THE USE OF THE

SAUNA PROGRAM?

A NOW, I AM -- THERE ARE TWO DEFINITIONS OF THE

WORD DETOXIFICATION. ONE IS WITHDRAWING FROM DRUGS AND

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THE OTHER IS REMOVING TOXINS FROM THE BODY.

WE SEE THAT BOTH OF THESE BENEFITS ARE AIDED BY

THE USE OF THE SAUNA PROGRAM.

Q YOU SAID --

A AS HAS BEEN DEMONSTRATED IN MULTIPLE STUDIES

THAT HAVE BEEN DONE ON THIS PROGRAM.

Q TELL ME THE STUDIES.

A IN 1981 WAS THE FIRST STUDY CALLED XENO -- YOU

KNOW, REDUCTION OF XENOBIOTICS OR SOMETHING LIKE THAT.

I DON'T REMEMBER THE EXACT TITLE. AND IT WAS A

CONTROLLED STUDY THAT DEMONSTRATED AN ACTUAL REDUCTION

IN VARIOUS TOXINS THAT COME FROM THE BODY. THERE HAVE

BEEN EXTENSIVE STUDIES REGARDING DIFFERENT KINDS OF

HERBICIDES, PESTICIDES, INDUSTRIAL CHEMICALS.

Q I DON'T MEAN TO INTERRUPT YOU, BUT I DON'T WANT

GENERIC RESPONSES LIKE "THERE HAVE BEEN NUMEROUS

STUDIES."

A UH-HUH.

Q ONE OF THE THINGS WE ASKED YOU TO TELL US ABOUT

IS THE ACTUAL STUDIES THAT SUPPORT THE CONTENTION THAT

YOU'VE MADE THAT THERE IS SOME SCIENTIFIC BASIS FOR

BELIEVING THAT THE SAUNA PROGRAM PROVIDES DETOXIFICATION

BENEFITS AND I WANT YOU TO IDENTIFY, AS THE

REPRESENTATIVE FOR NARCONON INTERNATIONAL, THE NAMES OF

THOSE STUDIES SO THAT WE CAN PROVIDE THEM TO THE JURY.

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A OKAY. I DON'T HAVE THE PRECISE NAMES. I CAN

GET THOSE FOR YOU BEFORE THE END OF THE DAY.

Q WELL, I ASKED YOU TO DO THAT AS PART OF THIS

DEPOSITION.

WHAT HAVE YOU DONE TO EDUCATE YOURSELF ON THE

SPECIFIC STUDIES THAT WE'VE ASKED YOU TO COME IN HERE

AND TALK ABOUT?

A WELL, I CAN DESCRIBE THE STUDIES AND WHERE THEY

WERE DONE AND THERE IS -- THE -- THERE WAS A PAPER ON,

PRESENTED AT WASHINGTON DC IN 1998 BY A NUMBER OF

RUSSIAN, UKRAINIAN DOCTORS.

Q WHAT'S THE NAME OF THE PAPER?

A IT'S -- I BELIEVE IT'S THE REDUCTION OF

RADIOACTIVE TOXINS AND AFTER THE CHERNOBYL INCIDENT. I

MAY NOT HAVE THE EXACT, THE EXACT TITLE.

Q OKAY.

WELL, LET ME ASK YOU IT THIS WAY.

CAN YOU GIVE ME THE TITLE AND PUBLICATION OF

ANY OF THE STUDIES THAT YOU'RE ALLUDING TO RIGHT NOW IN

THIS DEPOSITION?

A IMMEDIATELY AT THIS MOMENT I DON'T HAVE THE

EXACT TITLES. I ACTUALLY DID NOT UNDERSTAND THAT I

NEEDED TO HAVE THE EXACT TITLES. I CAN DESCRIBE THEM IN

SOME DETAIL. I CAN LATER TODAY VERY EASILY GET THE LIST

OF ALL OF THESE BECAUSE I HAVE KNOWLEDGE OF THEM. I

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DON'T HAVE THEM WITH ME. I WAS ALSO TOLD NOT TO BRING

NOTES AND SO FORTH BUT JUST TO SPEAK TO YOU, SO --

Q WELL --

A --AS THERE'S QUITE A LIST. I WOULD BE HAPPY

TO PROVIDE THEM TO YOU TODAY.

Q WELL, WE'VE ASKED THAT QUESTION IN DISCOVERY

AND THERE HAVE BEEN ONE OR TWO STUDIES THAT HAVE BEEN

IDENTIFIED. AND I'M JUST TRYING TO GET TO THE BOTTOM OF

ARE THERE MORE AND IF THERE ARE --

A THERE ARE AND I CAN GIVE YOU VERY EASILY A LIST

LATER TODAY AFTER -- WHICH I CAN GET DURING THE LUNCH

BREAK.

Q ALL RIGHT.

NOW, IN ADDITION TO THE SAUNA PROGRAM THAT

WE'VE BEEN DISCUSSING, STUDENTS ARE SUBJECTED TO A

REGIMEN OF VITAMINS AND NIACIN THAT ARE GIVEN TO THE

STUDENTS AS PART OF THE PROGRAM, CORRECT?

A THE NIACIN IS ONLY DURING THE SAUNA

DETOXIFICATION.

Q WELL, I THOUGHT THE VITAMINS WERE ONLY DURING

THE SAUNA PROGRAM. AM I WRONG ABOUT THAT?

A YES. IN THE OUTPATIENT PROGRAM THEY'RE ONLY

DURING THE SAUNA. IN THE RESIDENTIAL PROGRAM WE ALSO

USE VITAMINS DURING WITHDRAWAL.

Q OKAY.

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R. Leonard CSR, lnc.

DURING THE WITHDRAWAL PHASE AND THE SAUNA

PHASE, BUT THERE'S NO VITAMIN REGIMEN THAT GOES ON

THROUGHOUT THE PROGRAM ONCE SOMEONE GRADUATES FROM

SAUNA?

A YES. NO.

Q THAT'S CORRECT, RIGHT, THAT YOU DON'T GET -

THE WAY YOU ANSWERED THAT I'M NOT SURE THE RECORD IS

VERY CLEAR.

A NO. THE VITAMIN REGIMEN IS DURING THE SAcillA

AND DURING WITHDRAWAL AND ONLY DURING THOSE PHASES.

Q IS IT NARCONON INTERNATIONAL'S POSITION THAT

THE USE OF VITAMINS AND NIACIN PROVIDES SOME

DETOXIFICATION BENEFIT TO STUDENTS ENROLLED IN NARCONON

PROGRAMS?

A YES.

Q CAN YOU IDENTIFY FOR ME ANY SCIENTIFIC STUDIES

OR PAPERS THAT SUPPORT THAT CONTENTION?

A THESE WOULD BE PART OF THE, PART OF THE STUDY

OF THE SAUNA DETOXIFICATION PROGRAM.

Q AS YOU SIT HERE IN YOUR 30(B) (6) DEPOSITION,

CAN YOU IDENTIFY FOR ME SPECIFICALLY ANY SCIENTIFIC

PAPERS OR STUDIES THAT SUPPORT NARCONON INTERNATIONAL'S

CONTENTION THAT THE USE OF VITAMINS AND NIACIN PROVIDE

DETOXIFICATION BENEFITS TO STUDENTS?

A WELL, NIACIN IS ONE OF THE VITAMINS AND SO IT'S

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NOT A SEPARATE, IT'S NOT A STRAIGHT VITAMIN AND, AS I

SAID, I CAN, I CAN PROVIDE THAT FOR YOU BY NAME LATER.

I DIDN'T -- I DON'T HAVE THE MEMORIZED LIST. THERE IS

AN EXTENSIVE BODY OF LITERATURE ON THE USE OF B

VITAMINS, CALCIUM, MAGNESIUM, YOU KNOW, MINERALS, IN

ADDITION TO VITAMINS AND THEIR BENEFIT AND SO IT'S PART

OF THE BROAD LITERATURE.

Q MOVE TO STRIKE AS UNRESPONSIVE.

COULD YOU PLEASE READ THAT QUESTION BACK TO THE

WITNESS.

(QUESTION READ) .

THE WITNESS: NOT RIGHT -- NOT BY NAME AND DATE OF

THE PAPER AT THIS TIME. AS I SAY, I CAN PROVIDE IT TO

YOU. I HAVE KNOWLEDGE OF IT AND IT IS PART OF THE

GENERAL LITERATURE AND WE'LL PROVIDE IT LATER TODAY.

Q BY MR. HARRIS: ALL RIGHT.

SO AFTER THE STUDENT GRADUATES FROM THE OR

MOVES OUT OF THE SAUNA PHASE, THE STUDENT MOVES INTO THE

VARIOUS BOOKS THAT FOLLOW THE SAUNA PHASE, CORRECT?

A UH-HUH.

Q AND THOSE BOOKS, AGAIN, ARE BASED ON THE

WRITINGS OF L. RON HUBBARD, RIGHT?

A YES.

Q NOW, THE WAY THAT STUDENTS FIRST OR THE WAY

THAT STUDENTS GET INTO THE PROGRAMS OR LOCATE THE

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NARCONON PROGRAMS, IN PART, IS THROUGH A WEB-BASED

ADVERTISING CAMPAIGN THAT NARCONON INTERNATIONAL FUNDS,

CORRECT?

A I DON'T THINK I WOULD DESCRIBE IT THAT WAY.

Q WELL, DOES NARCONON INTERNATIONAL, DOES IT HAVE

WEBSITES THAT DIRECT STUDENTS TO NARCONON PROGRAMS?

A WE HAVE INFORMATIONAL WEBSITES AND WE HAVE

WEBSITES THAT DESCRIBE WHAT THE NARCONON PROGRAM DOES

AND PEOPLE WHO THEN ARE REACHING AND ARE INTERESTED IN

WHAT THE NARCONON PROGRAM CAN OFFER CAN THEN CONTACT

EITHER NARCONON INTERNATIONAL DIRECTLY OR SOMETIMES CAN

REACH TO OTHER NARCONON CENTERS.

Q AND ONE OF THE THINGS THAT NARCONON

INTERNATIONAL PROVIDES TO PEOPLE WHO ARE INTERESTED IN

OPENING UP A NARCONON CENTER IS CERTAIN TRAINING,

CORRECT?

A I'M SORRY?

Q NARCONON INTERNATIONAL PROVIDES CERTAIN

TRAINING MATERIALS TO INDIVIDUALS WHO ARE INTERESTED IN

OPENING NARCONON CENTERS, RIGHT?

A YES. WE PROVIDE A CHECKLIST OF THINGS THAT WE

RECOMMEND THAT THEY GO THROUGH AND IT'S BASICALLY A

SEQUENCE OF ACTIONS THAT A PERSON SHOULD TAKE BECAUSE

IT'S GOING TO BE DIFFERENT IN DIFFERENT STATES AND IN

DIFFERENT COUNTRIES AND SO FORTH. IT'S THE PEOPLE WHO

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ARE OPENING THE CENTER, IT'S THEIR JOB TO COMPLY WITH

AND TO KNOW WHAT THE LAWS ARE.

Q MR. CARR --

A WE PROVIDE THEM A GUIDELINE INTO WAYS TO

EFFECTIVELY DO THAT.

Q MR. CARR, MY QUESTION WAS VERY SIMPLE AND IT

WAS SIMPLY THIS.

NARCONON INTERNATIONAL PROVIDES TRAINING

MATERIALS TO INDIVIDUALS WHO ARE INTERESTED IN OPENING

NARCONON CENTERS, CORRECT?

A I WOULDN'T CALL THEM TRAINING MATERIALS. WE

PROVIDE A PACK THAT HELPS THE PERSON TO BE ABLE TO

FOLLOW THE PROCEDURES THAT THEY'RE GOING TO HAVE TO DO

TO OPEN A CENTER. WE CAN'T TRAIN THEM TO DO IT BECAUSE

IT WILL BE VERY DIFFERENT IN EACH COUNTRY SO IT'S A

SEQUENCE OF ACTIONS THAT WE RECOMMEND THAT THEY DO.

Q LET ME HAND YOU WHAT'S BEEN MARKED AS EXHIBIT

27.

I DON'T HAVE MULTIPLE COPIES OF THIS, DAVE. I

SURE YOU UNDERSTAND.

MR. ROOT: YEAH. WE DISCUSSED THAT YESTERDAY.

(WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS

MARKED FOR IDENTIFICATION BY THE SHORTHAND REPORTER AND

ATTACHED HERETO) .

Q BY MR. HARRIS: IF YOU WOULD, I'M GOING TO HAND

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YOU EXHIBIT 27.

A UH-HUH.

Q THE FIRST OR THE SECOND PAGE OF IT SAYS "THIS

COURSE MATERIAL IS WRITTEN SOLELY FOR THE PURPOSE OF

TRAINING THE STAFF OF LICENSED NARCONON CENTERS ONLY."

A YES.

Q DID I READ THAT CORRECTLY?

A UH-HUH.

Q WHAT'S THE NAME OF THAT EXHIBIT?

A "RUNNING AN EFFECTIVE NARCONON CENTER."

Q IS THAT A TRAINING MATERIAL?

A YES. THIS WAS -- YOU WERE TALKING ABOUT

OPENING A CENTER, NOT RUNNING A CENTER. I'M SORRY.

Q OKAY.

A THIS IS TO TRAIN. THIS IS TO TRAIN PEOPLE WHO

HAVE A CENTER AND ARE RUNNING IT. THERE'S A SEPARATE

PACK WHICH IS TO HELP PEOPLE WHO DON'T HAVE A CENTER AND

ARE TRYING TO OPEN ONE AND WE RECOMMEND WHAT ARE THE

SEQUENCES THEY NEED TO GO THROUGH IN TERMS OF CHECKING

WITH THE STATE TO FIND OUT WHAT REGULATIONS ARE AND SO

FORTH. ONCE THEY HAVE A CENTER, YOU'RE CORRECT, THIS IS

THE PACK THAT IS USED TO TRAIN PEOPLE OR PART ONE OF THE

PACKS THAT ARE USED TO HELP TRAIN PEOPLE.

Q THIS IS THE DOCUMENT THAT YOU HAVE IN FRONT OF

YOU, EXHIBIT 27, CALLED "RUNNING AN EFFECTIVE NARCONON

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CENTER," IS ONE OF THE THINGS THAT NARCONON

INTERNATIONAL PROVIDES TO INDIVIDUAL CENTERS FOR THE

PURPOSE OF TRAINING EMPLOYEES IN HOW TO OPERATE THAT

CENTER?

A YES, IT'S ONE OF THE PACKS. THERE ARE A NUMBER

OF OTHER SPECIFIC TRAINING MANUALS FOR SPECIFIC POSTS

WITHIN A NARCONON. THIS IS THE GENERAL ONE.

Q NOW, IN THAT PARTICULAR BOOK, AND I'M NOT GOING

TO GO THROUGH IT PAGE -- ARE YOU FAMILIAR WITH THE BOOK?

A YES, I AM.

Q ONE OF THE THINGS THAT NARCONON INTERNATIONAL

TRAINS INDIVIDUAL CENTERS IS HOW TO GET PEOPLE ENROLLED

IN THE NARCONON PROGRAM, RIGHT?

A UH-HUH.

Q HAND THAT BACK TO ME, IF YOU WOULD.

A (INDICATING) .

Q AND WHAT NARCONON INTERNATIONAL TELLS

INDIVIDUAL CENTERS IS THAT IN ORDER TO GET PEOPLE INTO

THE PROGRAM OR ONE OF THE THINGS THAT THEY NEED TO DO IN

ORDER TO GET PEOPLE INTO THE PROGRAM IS TO UTILIZE THE

HARD SELL, CORRECT?

A THEY USE, THAT TERM IS IN THERE, YES. IT'S

FULLY DEFINED.

Q AND THE OTHER THING THAT NARCONON INTERNATIONAL

TELLS THE INDIVIDUAL CENTERS TO DO IS TO USE A PROCESS

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WHERE THERE IS SOMEONE CALLED THE REGISTRAR, RIGHT?

A THIS IS THE COMMON NARCONON TERM FOR AN INTAKE

COUNSELOR.

Q RIGHT. A REGISTRAR IS SOMEONE WHOSE JOB IT IS

IS TO GET PEOPLE ENROLLED IN NARCONON CENTERS, RIGHT?

A THEIR JOB IS TO ANSWER THE QUESTIONS OF SOMEONE

WHO IS CALLED IN AND IS INTERESTED IN THE NARCONON

PROGRAM, TO FIND OUT IF THIS PERSON QUALIFIES AND IS

CORRECT FOR THE PROGRAM AND THEN TO ANSWER ALL QUESTIONS

AND HELP THEM SUCCESSFULLY GO THROUGH THE ENROLLMENT

PROCESS, WHICH IS A CONSIDERABLE THING TO DO, GIVEN THE

SITUATION OF THE KINDS OF PEOPLE THAT WE'RE TRYING TO

TALK TO. OFTEN THERE'S LEGAL ISSUES THAT ARE INVOLVED

AND MEDICAL ISSUES, YOU KNOW, AND SO FORTH.

Q AND THE REGISTRARS ARE TO BE PAID IN CASH IN

FULL FOR THE PROGRAM AT THE TIME OF CLOSING, CORRECT?

A EVERY CENTER WORKS THIS OUT FOR THEMSELVES.

Q WELL, THE MATERIALS THAT NARCONON INTERNATIONAL

PROVIDES TO INDIVIDUAL CENTERS, IN THIS CASE RUNNING AN

EFFECTIVE NARCONON, SPECIFICALLY SAY THAT EACH INTAKE

AND REGISTRATION REGISTRAR IS TO GET PAID IN CASH IN

HAND IN FULL WHEN THE PROGRAM WHEN THE STUDENT

CLOSES, RIGHT?

A I WOULD HAVE TO SEE THAT IF, IN FACT, IT SAYS

THAT THAT'S WHAT IT SAYS. IN REALITY, EVERY -- EVERY

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NARCONON HAS -- YES, I SEE THAT THAT SAYS THAT HERE.

AS I SAY, IN REALITY THERE

VARIOUS PAYMENT PLANS AND THERE ARE

THEY WORK OUT

Q MOVE TO STRIKE AS UNRESPONSIVE.

THE QUESTION WAS SIMPLY THIS. THE MATERIALS

THAT YOU, THAT NARCONON INTERNATIONAL PROVIDES TO THE

STUDENTS AND IN THIS CASE SPECIFICALLY HOW TO RUN AN

EFFECTIVE NARCONON CENTER, THE REGISTRARS ARE SUPPOSED

TO GET, IT SAYS RIGHT HERE "EACH INTAKE AND REGISTRATION

REGISTRAR IS TO GET PAID IN CASH IN FULL AT THE CLOSE OF

THE PROGRAM. "

A THAT'S WHAT THE MATERIALS STATE.

Q THANK YOU.

IN ADDITION, THE REGISTRARS ARE TO, QUOTE, "GET

COPIES OF 'BIG LEAGUE SALES' AND 'THE LANGUAGE OF

SALESMANSHIP' BY LES DANE FROM THEIR LOCAL BOOK STORE.

CORRECT?

A THAT'S WHAT THE MATERIALS STATE.

Q AND THE MATERIALS STATE THAT "THE REGISTRARS

ARE TO GET ALL INTAKE PERSONNEL INDOCTRINATED WITH THE

SLOGAN 'SELL THE INDIVIDUAL IN FRONT OF YOU,'" CLOSE

QUOTE.

CORRECT?

A I WOULD HAVE TO SEE THAT.

Q ARE YOU FAMILIAR WITH THIS MATERIAL?

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A I'M FAMILIAR BUT QUOTING THE SENTENCES OUT OF

CONTEXT MISDEFINES THEM AS IN WHEN YOU SAID "HARD SELL."

HARD SELL IS DEFINED AS CARING FOR THE INDIVIDUAL AND

SEEING THAT HE GETS THE FULL SERVICE THAT HE NEEDS.

THAT'S WHAT HARD SELL MEANS, NOT WHAT IT'S COMMONLY

UNDERSTOOD AS OUTSIDE.

Q SHOW ME IN THAT BOOK THERE WHERE IT SAYS THAT

THE HARD SELL IS DESIGNED FOR OR INTENDED TO MEAN CARING

FOR THE INDIVIDUAL.

A I WOULD HAVE TO HAVE THE PACK. I BELIEVE IT'S

DEFINED MORE FULLY IN THE PROMOTION SECTION.

Q IN THE PROMOTION SECTION OF THIS BOOK?

A YES. (INDICATING).

Q IS THAT NARCONON INTERNATIONAL'S POSITION AS

THE CORPORATE REP THAT HARD SELL MEANS CARING FOR THE

INDIVIDUAL AND MAKING SURE THAT THE INDIVIDUAL GETS WHAT

HE NEEDS?

A YEAH. THE DEFINITION OF HARD SELL IS NOT

ACCEPTING REASONS WHY YOU CANNOT HELP THIS INDIVIDUAL TO

GET THROUGH TO RECEIVE THE FULL SERVICE THAT HE WANTS TO

DO.

SPECIFICALLY WITH REGARD TO NARCONON IT IS

THIS. AN INDIVIDUAL COMES IN TO THE -- OR THE FAMILY

COMES AND THEY HAVE SOMEONE WHO IS IN EXTREME DIFFICULTY

AND AT RISK OF FURTHER DIFFICULTY IF WE DON'T ENROLL

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THIS INDIVIDUAL AND SO VERY OFTEN THE FAMILY IS VERY

UPSET AND IN DISAGREEMENT AND CARING FOR THEM MEANS

GOING -- PERSISTING THROUGH ALL OF THESE CHALLENGES AND

UPSETS AND THEY'RE ARGUING AMONGST THEMSELVES TO GET

THROUGH TO THE POINT WHERE SERVICE CAN ACTUALLY BE

DELIVERED.

Q YOUR

A AND THE DEFINITION HERE

Q HOLD ON A SECOND. HOLD ON A SECOND. I DON'T

EVEN KNOW WHAT THE QUESTION IS ANYMORE.

BUT FIRST OF ALL, I ASKED YOU ABOUT THE

TRAINING MATERIALS FOR NARCONON.

A YES.

Q AND

A YOU ASKED ME ABOUT HARD SELL AND WHERE IT WAS

IN THE BOOK. AND WHAT IT SAYS HERE

Q I WITHDRAW THE QUESTION.

A BUT NO. YOU ASKED ME --

Q I'M NOT GOING TO ARGUE WITH YOU.

A ALLOW ME --

Q I'M NOT GOING TO ARGUE WITH YOU.

A ALLOW ME TO ANSWER.

Q I'LL WITHDRAW THE QUESTION BECAUSE I DON'T KNOW

WHAT THE -- I DON'T EVEN KNOW WHAT WE'RE TALKING ABOUT

AT THIS POINT.

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MR. ROOT: WELL, WE WERE TALKING ABOUT

MR. HARRIS: I'LL ASK IT CLEARLY.

THE WITNESS: WE WERE TALKING ABOUT HARD SELL AND I

WAS WANTING TO ANSWER YOUR QUESTION, SIR.


LET ME ASK IT AGAIN.

MR. ROOT: YOU WERE ASKING HIM WHERE, TO POINT OUT

IN THE BOOK --

MR. HARRIS: I'VE WITHDRAWN THE QUESTION. THERE IS

NO POINT FOR ANYBODY TO BE TALKING RIGHT NOW. LET'S

START OVER.

OKAY?

MR. ROOT: I THINK HE'S ENTITLED TO ANSWER THAT

QUESTION.

THE WITNESS: IT MEANS CARING ABOUT THE PERSON AND

NOT BEING REASONABLE ABOUT STOPS OR BARRIERS.

MR. HARRIS: I'LL ASK HIM A QUESTION THAT I HAVEN'T

WITHDRAWN.

ALL RIGHT.

THE WITNESS: ANYWAY, THIS IS WHERE IT IS DEFINED,

so

Q BY MR. HARRIS: OKAY. THAT'S FINE. I'M GOING

TO LET YOU TALK ABOUT IT.

OKAY?

A I WANTED TO LET YOU KNOW THAT I WASN'T MAKING

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THAT UP.

Q THAT'S FINE.

A ALL RIGHT, SIR.

Q ALL RIGHT.

WE WERE TALKING ABOUT HARD SELL. I'VE

WITHDRAWN THE QUESTION.

A ALL RIGHT.

Q I BELIEVE WHAT YOU TOLD ME WAS THAT YOU DIDN'T

BELIEVE THAT THE TERM HARD SELL IS USED IN THE SORT OF

COMMON VERNACULAR THAT I MAY HAVE BEEN USING IT; FAIR?

A WELL, AS IT IS COMMONLY UNDERSTOOD, YES.

Q OKAY.

A IT MEANS SOMETHING DIFFERENT.

Q AND THEN I ASKED YOU TO POINT IN THE BOOK TO

WHERE THAT DEFINITION WAS FOUND, THE ONE THAT YOU WERE

USING; FAIR?

A YES. WHICH IS HERE.

Q AND YOU COULDN'T FIND IT?

A NO. I WAS -- SAT THE BOOK DOWN AND -- IT'S IN

A SEPARATE SECTION OF THE BOOK.

Q AND THEN YOUR COUNSEL FOUND IT FOR YOU AND

POINTED IT OUT TO YOU, CORRECT?

A NO. WE WERE TALKING ABOUT SOMETHING ELSE. HE

TOOK THE BOOK FROM ME. I WOULD HAVE FOUND IT. AS I

TOLD YOU, IT'S IN A DIFFERENT SECTION OF THE BOOK AND SO

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I KNEW WHERE IT WAS BUT I DIDN'T HAVE THE OPPORTUNITY TO

DO IT.

Q OKAY.

FOR THE RECORD, WHAT PAGE ARE YOU TALKING

ABOUT?

A IT'S PAGE 237.

WHERE WAS THAT?

MR. ROOT: (INDICATING) .

THE WITNESS: NO, THIS IS NOT THE -

MR. ROOT: 237.

THE WITNESS: NO. BUT WHERE -- YEAH. IT'S ON PAGE

237 WHICH IS IN THE DIVISION TWO, THE DISSEMINATION

DIVISION WHICH IS ABOUT HOW YOU PROMOTE THE PROGRAM AND

IT'S UNDER THE FULLER DEFINITION OF HARD SELL.


A AND THEN IT IS LATER REFERRED TO JUST IN

QUOTES.

Q OKAY.

SO WHEN THE TERM HARD SELL IS USED IN THIS

MANUAL, NARCONON INTERNATIONAL'S POSITION IS THAT

DEFINITION ON THAT PAGE 237 DEFINES THAT TERM?

A YES.

Q OKAY.

NOW, WHY ARE REGISTRARS WHO ARE ATTEMPTING TO

ENROLL PEOPLE IN DRUG AND ALCOHOL REHAB PROGRAMS, WHY

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ARE THOSE REGISTRARS ENCOURAGED TO READ "BIG LEAGUE

SALES"?

A AGAIN, DESCRIBING THE OVERALL CONTEXT IN WHICH

THIS IS DONE, WHEN PEOPLE COME IN TO ENROLL IN THE

PROGRAM, THERE ARE MANY, MANY BARRIERS THAT THEY HAVE TO

GET THROUGH IN ORDER TO ACTUALLY ENROLL SOMEONE AND THIS

WOULD BE TRUE AT ANY OTHER PROGRAM, AS WELL AS NARCONON.

THERE OFTEN ARE UPSETS WITHIN THE FAMILY AND BREAKDOWNS

IN COMMUNICATION AND SO IN DEALING WITH THESE, THESE

APPARENT BARRIERS THE REGISTRAR NEEDS TO LEARN THE

SKILLS TO CONTINUE TO KEEP THE PERSON IN COMMUNICATION,

HELPING THEM SOLVE THEIR OWN PROBLEMS SO THAT THEY GET

TO THE POINT TO WHERE THEY -- THEY CAN FIGURE THIS OUT,

AS OPPOSED TO SIT IN A BROKEN-DOWN COMMUNICATION AND

FAIL TO ACTUALLY GET THE PERSON ENROLLED IN

REHABILITATION. THAT'S WHAT WE'RE LOOKING FOR IS TO GET

THE PERSON ENROLLED WHERE THEY CAN NOW START THEIR

RECOVERY PROCESS.

SO IT'S -- IT CAN BE -- IT CAN TAKE -- IT CAN

TAKE HOURS WORKING WITH SOMEBODY. WHEN THEY COME IN

THEY'RE THE FAMILY IS FRACTURED AND OFTEN WITH GOOD

REASON. THE ADDICT HAS STOLEN FROM THEM, THE ADDICT,

YOU KNOW, THEY HAVE SPENT MONEY EARLIER AND THE IDEA

THAT REHABILITATION WOULD COST SOMETHING BECAUSE, OF

COURSE, IT DOES IS AN UPSET. YOU HAVE TO COMMUNICATE

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WITH PATIENTS AND DILIGENCE TO HELP THE PEOPLE GET

THROUGH TO THE OTHER SIDE. AND THAT'S WHAT THIS IS,

THAT'S WHAT THIS IS ABOUT.

Q THAT'S THE POSITION OF NARCONON INTERNATIONAL,

WHAT YOU'VE JUST EXPLAINED TO US, THAT'S THE POSITION OF

NARCONON INTERNATIONAL AS TO WHY NARCONON INTERNATIONAL

TRAINING MATERIALS ENCOURAGE PEOPLE WHO ARE ENROLLING

STUDENTS INTO THE PROGRAM TO READ "IG LEAGUE SALES"?

YOUR ANSWER IS COMPLETE, RIGHT?

A YES. TO HELP, TO HELP, HELP THE FAMILY SOLVE

ALL THE PROBLEMS THAT THEY NEED TO DO IN ORDER TO

SUCCESSFULLY GET THEIR STUDENT ENROLLED AND STARTED IN

HIS RECOVERY PROCESS.

Q ALL RIGHT.

WHAT IS IT ABOUT "BIG LEAGUE SALES" THAT TALKS

ABOUT RECOVERY?

A IT DOESN'T TALK ABOUT RECOVERY. IT TALKS ABOUT

IN ANYTHING WHERE YOU'RE DISCUSSING MONEY THE BARRIERS

THAT COME UP AND THE REASONS, THE REASONS WHY AND

IT'S -- IT IS -- IT'S JUST GIVING THEM AN UNDERSTANDING

OF HOW TO MAINTAIN COMMUNICATION WITH THE, WITH THE

SPONSOR OR THE PERSON HIMSELF, TO RECOGNIZE THAT SAVING

HIS LIFE OR SAVING YOUR SON'S LIFE IS WORTH THE EFFORT.

Q ALL RIGHT.

SAME QUESTION WITH RESPECT TO "THE LANGUAGE OF

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SALESMANSHIP." WHAT IS NARCONON INTERNATIONAL'S

POSITION AS TO WHY REGISTRARS ARE ENCOURAGED TO READ

"THE LANGUAGE OF SALESMANSHIP"?

A IT'S A SIMILAR, IT'S A SIMILAR THING. PEOPLE

COME IN, ONE OF THE PRINCIPAL BARRIERS THAT COMES UP,

ONCE THE PEOPLE DECIDE THEY WANT TO DO THE NARCONON

PROGRAM, THEN WE NEED TO FIGURE OUT HOW TO DO IT AND

THEN MONEY ISSUES COME UP AND IT IS AN ISSUE AND

IT'S AND I UNDERSTAND. AND SO IN ORDER TO SOLVE THIS

PROBLEM YOU HAVE TO, YOU HAVE TO STAY IN COMMUNICATION

WITH THE PEOPLE, AND THIS IS A SALES PROCESS.

Q WHAT OTHER TRAINING MATERIALS BESIDES HOW TO

RUN AN EFFECTIVE NARCONON DOES NARCONON INTERNATIONAL

PROVIDE TO INDIVIDUAL CENTERS?

A WELL, THERE ARE INDIVIDUAL TRAINING MANUALS FOR

SPECIFIC POSTS IN THE PROGRAM SUCH AS THE CASE

SUPERVISOR, THE COURSE SUPERVISOR, THE ETHICS OFFICER,

THE CRAMMING OFFICER WHICH IS A, SOMEONE WHO CORRECTS

STAFF AND HELPS STUDENTS WHO ARE NOT DOING WELL ON THEIR

COURSE, AND WITHDRAWAL SPECIALIST.

Q IS THAT REFERRED TO AS THE BASIC STAFF HAT?

A AND ALSO THE BASIC STAFF HAT WHICH IS THE

INITIAL, AFTER THIS, WHICH IS THE GENERAL HOW A PROGRAM

IS RUN, THE BASIC STAFF HAT ARE THE RESPONSIBILITIES OF

EVERY STAFF MEMBER; YES.

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Q ALL RIGHT.

AND ONE OF THE TOPICS THAT, AGAIN, YOU'VE BEEN

DESIGNATED TO TALK ABOUT IS EXACTLY THAT THE TRAINING

THAT INDIVIDUAL CENTERS ARE PROVIDED BY NARCONON

INTERNATIONAL.

A UH-HUH.

Q I HAVE A COPY OF RUNNING AN EFFECTIVE NARCONON

CENTER.

A UH-HUH.

Q AND WE'VE TALKED ABOUT THAT A LITTLE BIT.

WHAT I WANT TO KNOW IS THE SPECIFIC NAMES, IF

YOU CAN TELL ME, OF ALL THE TRAINING MATERIALS THAT

INTERNATIONAL PROVIDES TO THE INDIVIDUAL CENTERS SO THAT

I CAN GET A LIST OF THOSE AND MAKE SURE THAT WE HAVE

THEM IN DISCOVERY.

A OKAY. NOW, AGAIN, I DID NOT KNOW I WAS GOING

TO NEED THE EXACT LIST BUT I CAN GIVE YOU HERE WHAT I

RECALL AND I THINK IT WILL BE COMPLETE.

THERE IS THE COURSE SUPERVISOR'S TRAINING

MANUAL, AND THIS IS THE PERSON WHO IS ACTUALLY

SUPERVISING STUDENTS THAT ARE STUDYING THE MANUALS IN

THE COURSE ROOM.

Q IS THAT REFERRED TO AS A CS?

A NO. THE CS IS THE CASE SUPERVISOR AND THIS IS

THE SENIOR TECHNICAL PERSON. THAT'S A SEPARATE COURSE.

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THE PERSON WHO SUPERVISORS THE PROGRAM THROUGH EVERY

STEP OF THE PROGRAM AND MAINTAINS, MAINTAINS A FOLDER ON

HIM. THERE IS THE -- AND THAT PERSON ALSO SUPERVISES

THE DELIVERY OF THE SAUNA.

THERE IS THE SAUNA PROGRAM OR SAUNA DELIVERY IN

CHARGE. THIS IS THE PERSON WHO MONITORS THE STUDENTS,

YOU KNOW, DURING THEIR -- DURING WHEN THEY'RE SWEATING

IN THE SAUNA, AND THAT'S A SEPARATE HAT.

LET ME WRITE THEM DOWN HERE AS I DO.

Q ALL RIGHT.

YOU'VE GOT COURSE SUPERVISOR. AND JUST FOR

CLARITY

A UH-HUH.

Q -- IS THERE AN INDIVIDUAL BOOK THAT'S REFERRED

TO AS THE COURSE SUPERVISOR BOOK?

A COURSE SUPERVISOR TRAINING MANUAL, YES.

THERE'S A TRAINING PACK FOR THE COURSE SUPERVISOR.

THE SAUNA IN CHARGE.

THERE IS THE ETHICS OFFICER. TRAINING IN THE

ETHICS OFFICER IS THE PERSON WHO DEALS WITH STUDENTS

THAT ARE BREAKING RULES, BEING INFRACTUOUS, BEING

TROUBLED. THERE IS A SPECIFIC PACK FOR THAT.

THERE IS ONE CALLED THE CRAMMING OFFICER AND

THIS IS DEALING WITH STUDENTS AND/OR STAFF WHO HAVE

MISUNDERSTOODS AND NEED HELP IN FINDING THEIR

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R. Leonard CSR Inc.

MISUNDERSTOODS AND RETRAINING.

LET ME LOOK-- I'M TRYING TO THINK AS WE GO

THROUGH. THESE, I BELIEVE, ARE THE, ARE THE KEY

TRAINING MANUALS.

THEN THERE ARE -- THERE MAY BE, EACH NARCONON

MAY PREPARE OTHER MATERIALS, SMALLER, WHAT WE CALL HAT

PACKS, THE HAT BEING THE RESPONSIBILITIES OF YOUR POST,

WHAT IS THE HAT THAT YOU'RE WEARING.

BUT IN TERMS OF NARCONON INTERNATIONAL'S

TRAINING, OVERALL TRAINING MATERIALS, I BELIEVE THESE

ARE THE KEY ONES. I CAN, AGAIN, FIND OUT AND GET THE

EXACT LIST FOR YOU.

Q WELL, I'M LOOKING THROUGH THIS 30(B) (6) NOTICE.

THERE'S AT LEAST FIVE DIFFERENT TIMES WHERE WE SAY IN

HERE THAT WE WANT TO KNOW ABOUT THE EDUCATION AND

TRAINING PROVIDED TO INDIVIDUAL FACILITIES.

A YES. AND I'M CAPABLE OF ANSWERING QUESTIONS

ABOUT THAT IN SOME DETAIL TO YOU.

Q ALL RIGHT.

WELL, I JUST DON'T UNDERSTAND WHY YOU WOULDN'T

HAVE DETERMINED WHAT TRAINING MATERIALS ARE PROVIDED

PRIOR TO YOUR DEPOSITION.

A I DID NOT -- IT DID NOT SAY A LIST OF, SO, I'M

SORRY. AS I SAY, I ACTUALLY CAN ANSWER ANY QUESTIONS

THAT YOU HAVE ON THIS. THE EXACT LIST OF THEM I'M NOT

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SURE RIGHT HERE BUT I CAN GET THAT FOR YOU. BUT I CAN

ANSWER ANY QUESTIONS THAT YOU HAVE.

Q ALL RIGHT.

WE'VE IDENTIFIED RUNNING AN EFFECTIVE NARCONON,

THE COURSE SUPERVISOR PACKET, SAUNA DELIVERY PACKET,

ETHICS OFFICER PACKET AND CRAMMING OFFICER PACKET.

A AND THE CASE SUPERVISOR.

Q CASE SUPERVISOR PACKET.

A WE DON'T CALL THEM PACKETS. WE CALL THEM

TRAINING MANUALS.

Q ALL RIGHT. MANUALS.

SO THERE ARE FIVE MANUALS HERE THAT YOU'VE

IDENTIFIED.

A UH-HUH.

Q WHAT IS THE DIFFERENCE BETWEEN THE MANUALS THAT

YOU'VE IDENTIFIED AND THE BASIC STAFF HAT?

A THE BASIC STAFF HAT ARE THE OVERALL

RESPONSIBILITIES OF A STAFF MEMBER, WHETHER THEY'RE AN

EXECUTIVE OR, YOU KNOW, JUST THE RECEPTIONIST, HAVING TO

DO WITH THE, HOW TO HANDLE COMMUNICATIONS WITHIN AN

ORGANIZATION, RESPONSIBILITIES OF MAINTAINING, YOU KNOW,

HOW TO HANDLE REPORTS AND SO FORTH.

Q IS THAT A MANUAL?

A IT'S A MANUAL. IT'S A TRAINING MANUAL LIKE

THIS, YES (INDICATING).

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Q ALL RIGHT.

SO THERE'S SIX MANUALS AND "RUNNING AN

EFFECTIVE NARCONON"?

A YES.

Q ANY OTHER TRAINING MATERIALS, WRITTEN MATERIALS

THAT ARE PROVIDED TO INDIVIDUAL NARCONON CENTERS BY


A NOT TO MY MEMORY RIGHT NOW. I CAN CHECK FOR

THAT AND GET A FULLER ANSWER FOR YOU LATER SO THAT WE

HAVE THE EXACT LIST. I THINK THESE ARE THE, THESE ARE

THE KEY ONES.

Q ALL RIGHT.

LET'S TALK ABOUT NARCONON OF GEORGIA FOR A

SECOND. NARCONON INTERNATIONAL HAS A LICENSE AGREEMENT

OR -- EXCUSE ME -- HAD, IN 2007 AND 2008 HAD A LICENSE

AGREEMENT WITH NARCONON OF GEORGIA, CORRECT?

A THEY SIGNED OUR TRADEMARK LICENSE; YES.

Q OKAY.

AND IN ADDITION TO THE LICENSE AGREEMENT THERE

WAS ANOTHER AGREEMENT BETWEEN NARCONON INTERNATIONAL AND

NARCONON OF GEORGIA CALLED A BUSINESS ASSOCIATION

AGREEMENT?

A BUSINESS ASSOCIATES AGREEMENT.

Q EXCUSE ME. BUSINESS ASSOCIATE AGREEMENT.

A YES.

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Q SO THERE'S A LICENSE AGREEMENT WHICH BASICALLY

DEALS WITH THE LICENSING OR THE USE OF THE WRITTEN

MATERIALS BY GEORGIA, RIGHT?

A YES, UH-HUH.

Q AND THEN THERE'S THE BUSINESS ASSOCIATE

AGREEMENT WHICH IS A SEPARATE AGREEMENT?

A YES.

Q ARE THERE ANY OTHER WRITTEN CONTRACTUAL

AGREEMENTS -- WELL, LET ME BROADEN IT UP.

ARE THERE ANY OTHER AGREEMENTS BETWEEN NARCONON

INTERNATIONAL AND NARCONON OF GEORGIA THAT WERE IN

EFFECT IN 2007 AND 2008?

A NOT TO MY KNOWLEDGE. THESE ARE THE ONLY ONES I

KNOW OF.

Q WELL, AS A GENERAL RULE, WHEN NARCONON

INTERNATIONAL HAS A RELATIONSHIP WITH ANY OF THE

CENTERS, ARE THERE ANY OTHER THINGS THAT NARCONON

INTERNATIONAL DOES?

A NOT THAT ARE CONTRACTUAL RELATIONSHIPS LIKE

THIS, NO.

Q EXHIBIT 14, WHICH WAS THE EXHIBIT TO THE

DEPOSITIONS YESTERDAY.

A UH-HUH.

Q I'M GOING TO HAND THAT TO YOU.

IT'S MY UNDERSTANDING THAT THIS, THIS PACKET,

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EXHIBIT 14, INCLUDES ALL OF THE LICENSE

AGREEMENT -- AGREEMENTS AND BUSINESS ASSOCIATE

AGREEMENTS BETWEEN NARCONON INTERNATIONAL AND NARCONON

OF GEORGIA.

IS THAT CORRECT?

A YES.

Q THE AGREEMENT AT THE END, BEGINNING AT, IF YOU

LOOK DOWN AT THE BOTTOM IT SAYS DESMOND INTERNATIONAL

1238. THAT'S THE BATES NUMBER.

A UH-HUH.

Q AND IT SAYS THE AGREEMENT IS MADE THE 21ST DAY

OF JUNE, 2006

A YES.

Q AT THE TOP PARAGRAPH.

DO YOU SEE WHERE I'M READING?

A YES.

Q IS THIS THE BUSINESS ASSOCIATE AGREEMENT THAT

WAS IN EFFECT AT THE TIME OF PATRICK DESMOND'S DEATH?

A TO MY KNOWLEDGE, YES.

Q WELL, IT'S NOT TO YOUR KNOWLEDGE. YOU'RE THE

CORPORATE REPRESENTATIVE OF NARCONON INTERNATIONAL AND

THE QUESTION IS, IS THIS

A THIS IS THE ONLY ONE THAT I KNOW OF, YES.

Q ALL RIGHT.

NOW, IF YOU, FIRST OF ALL, THE PARAGRAPH, THE

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SECOND PARAGRAPH OF THE BUSINESS ASSOCIATE WELL,

WE'RE JUST GOING TO HAVE AN AGREEMENT THAT THIS IS THE

ONE THAT WAS IN EFFECT.

A YES.

Q ALL RIGHT.

THE, AT THE TIME OF PATRICK'S DEATH.

THE SECOND PARAGRAPH PROVIDES THAT THE FACILITY

IS A RESIDENTIAL DRUG AND ALCOHOL REHABILITATION CENTER.

DO YOU SEE WHERE I'M READING THAT?

A YES.

Q THAT IS NOT ACCURATE, IS IT?

A NO. THAT WAS A -- THIS IS A STANDARD AGREEMENT

THAT WE HAD ALL OF THE CENTERS SIGN, AND AS THE DIRECTOR

OF LEGAL AFFAIRS STATED, SHE DID NOT PREPARE -- DID NOT

SEE THIS AND DID NOT PREPARE A SEPARATE ONE STATING

OUTPATIENT FOR THE TWO OUTPATIENT CENTERS THAT WE HAVE,

SO IT WAS EQUIVALENTLY A TYPO.

Q ALL RIGHT.

WELL, IT SAYS WHAT IT SAYS AND THAT IS NOT

CORRECT, RIGHT?

A YEAH. THIS IS NOT CORRECT. IT IS AN

OUTPATIENT DRUG AND ALCOHOL REHABILITATION CENTER.

Q NARCONON OF GEORGIA IS NOT A RESIDENTIAL

FACILITY?

A NO, IT IS NOT.

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Q SO THIS WAS A MISTAKE?

A THIS WAS A MISTAKE, THAT WORD. EVERYTHING ELSE

IN THE AGREEMENT STANDS.

Q NOW, WHAT THIS AGREEMENT OUTLINES IS CERTAIN

DUTIES AND OBLIGATIONS OF NARCONON INTERNATIONAL AND

NARCONON OF GEORGIA, RIGHT?

A PRINCIPALLY, WITH REGARD TO MAINTAINING

CONFIDENTIALITY OF THE STUDENTS AND COMMUNICATION ABOUT

THEM, YES.

Q WELL, ATTACHMENT A -

A IS THAT THE LAST PAGE?

Q UH-HUH.

A 124 8?

Q UH-HUH.

"BUSINESS -- "YOU SEE WHERE I'M READING-

A UH-HUH.

Q -- 1248?

ALL RIGHT. IT SAYS "BUSINESS ASSOCIATE," WHICH

IS NARCONON INTERNATIONAL, RIGHT?

A UH-HUH.

Q "SHALL PROVIDE PERIODIC ONSITE REVIEWS OF

FACILITY'S DRUG REHABILITATION SERVICES IN ORDER TO

ASSESS AND IMPROVE THE QUALITY OF CARE PROVIDED TO ITS

CLIENTS. THESE REVIEW ACTIVITIES INCLUDE, BUT ARE NOT

LIMITED TO," AND THEN IT LISTS FIVE DIFFERENT THINGS

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THAT NARCONON INTERNATIONAL PURSUANT TO THIS AGREEMENT

ARE SUPPOSED TO DO, RIGHT?

A YES. THESE ALL ARE WITHIN THE TRADEMARK

LICENSE.

Q I'M NOT ASKING YOU, SIR, ABOUT THE TRADEMARK

LICENSE. I'M ASKING YOU ABOUT THIS AGREEMENT.

A YES.

Q AND THIS AGREEMENT PROVIDES AN ATTACHMENT A,

CERTAIN RESPONSIBILITIES THAT NARCONON INTERNATIONAL

AGREES CONTRACTUALLY TO PROVIDE, DOES IT NOT?

A YES.

Q AND NARCONON INTERNATIONAL WITH RESPECT TO

NARCONON OF GEORGIA HAS AGREED TO, FIRST, CONDUCT ONSITE

HEALTH AND SAFETY INSPECTIONS, CORRECT?

A UH-HUH.

Q IT HAS AGREED TO REVIEW NARCONON OF GEORGIA'S

CASE FOLDERS OF ITS CLIENTS TO VERIFY STANDARDS OF

TECHNOLOGY AND THE APPLICATION THEREOF, CORRECT?

A YES.

Q IT'S AGREED TO REVIEW THE PERSONNEL FILES OF

THE FACILITY'S PERSONNEL AND TRAINEES TO VERIFY ALL THE

REQUIRED TRAINING HAS BEEN COMPLETED AND OTHER LEGAL

REQUIREMENTS, CORRECT?

A YES.

Q AND IT HAS AGREED TO CORRECT FACILITY PERSONNEL

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REGARDING ANY, QUOTE, "NONOPTIMUM SITUATIONS THAT ARE

DETERMINED TO EXIST," CORRECT?

A YES.

Q AND THEN IT HAS AGREED TO IMPLEMENT PROGRAMS TO

INCREASE PROGRAM DELIVERY AND THE QUALITY OF CARE,

CORRECT?

A UH-HUH.

Q AND THIS AGREEMENT WAS IN EFFECT AT THE TIME OF

PATRICK DESMOND'S DEATH, WAS IT NOT, SIR?

A YES, IT WAS.

Q WERE THERE ANY NONOPTIMUM SITUATIONS PRESENT AT

NARCONON OF GEORGIA?

A NARCONON EASTERN US WAS IN COMMUNICATION WITH

THEM AND I BELIEVE AT TIMES VISITING THEIR CENTER, AND I

HAVE SEEN DOCUMENTS THAT HAVE BEEN GIVEN TO YOU THAT

WHEN THERE WERE INSPECTIONS DONE THERE WERE SOME

NONOPTIMUM SITUATIONS THAT WERE, IN TERMS OF STAFF

PERFORMANCE, THAT WERE, YOU KNOW, AND DELIVERY TO THE

STUDENTS THAT WERE CORRECTED.

Q ALL RIGHT.

THERE WAS A BOARD OF INVESTIGATION WHICH WAS

CONDUCTED BY NARCONON OF GEORGIA THAT NARCONON

INTERNATIONAL WAS AWARE OF, RIGHT?

A TO MY KNOWLEDGE, THAT BOARD OF

INVESTIGATION -- WE WERE AWARE THAT ONE WAS BEING HELD.

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TO MY KNOWLEDGE, THE ACTUAL RESULTS OF THAT BOARD OF

INVESTIGATION WERE NOT SEEN UNTIL AFTER THE FACT OF

MR. DESMOND'S DEMISE.

Q IS IT YOUR POSITION AS THE CORPORATE

REPRESENTATIVE OF NARCONON INTERNATIONAL THAT NARCONON

INTERNATIONAL WAS UNAWARE OF THE FINDINGS OF THE BOARD

OF INVESTIGATION UNTIL AFTER PATRICK DESMOND'S DEATH?

A THAT I BELIEVE IS THE, IS THE TRUTH.

Q OKAY.

WHAT DO YOU BASE THAT ON AS THE CORPORATE

REPRESENTATIVE FOR INTERNATIONAL?

A THAT IN THE RESEARCH THAT I WAS DOING, I DID

NOT SEE THIS BOARD OF INVESTIGATION UNTIL LOOKING

THROUGH THESE, LOOKING THROUGH ALL OF THE DOCUMENTS THAT

WERE PROVIDED. THE BOARD OF INVESTIGATION HAD BEEN

FILED IN THE LEGAL AREA AND APPARENTLY -- WELL, I DON'T

KNOW -- I BELIEVE IT CAME BACK WITH THE PERSON WHO DID

THE LEGAL, THE LEGAL RUDS CHECK AFTER MR. DESMOND'S

DEATH AND SHE BROUGHT BACK A NUMBER OF DOCUMENTS AND

THEN IT WAS FILED THERE. I DID NOT SEE IT UNTIL, YOU

KNOW, MUCH LATER.

Q I'M NOT ASKING WHETHER YOU SAW IT. YOU'RE HERE

AS A CORPORATE REPRESENTATIVE.

A YEAH.

Q AND I WANT YOU TO STATE ON THE RECORD WHAT

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NARCONON INTERNATIONAL'S POSITION IS ABOUT WHETHER OR

NOT NARCONON INTERNATIONAL WAS AWARE OF THE BOARD OF

INVESTIGATION THAT WAS BEING CONDUCTED BY NARCONON OF

GEORGIA PRIOR TO PATRICK DESMOND'S DEATH.

A WE HAD BEEN INFORMED THAT A BOARD OF

INVESTIGATION WAS ONGOING.

Q ALL RIGHT.

so --

A AND THEN REPORTS FROM THE EXECUTIVE DIRECTOR

THAT CORRECTIONS WERE BEING MADE AS A RESULT OF THAT.

Q WHAT DID NARCONON INTERNATIONAL DO IN ORDER TO

DETERMINE WHETHER OR NOT THOSE CORRECTIONS WERE ACTUALLY

IMPLEMENTED?

A THERE WAS A TECHNICAL INSPECTION THAT WE DID

PER OUR TRADEMARK LICENSE AND THERE WAS A LEGAL RUDS

INSPECTION THAT WAS DONE FOLLOWING AND THEN THERE WAS

THE CONTINUING COMMUNICATIONS BETWEEN EASTERN US AND

NARCONON OF GEORGIA PURSUANT TO THAT FOLLOWING IT UP.

Q PRIOR TO PATRICK DESMOND'S DEATH, NARCONON

INTERNATIONAL WAS AWARE OF THE FACT THAT NARCONON OF

GEORGIA WAS HAVING CERTAIN ISSUES IN THE DELGADO

HOUSING, RIGHT?

A THE EXECUTIVE DIRECTOR REPORTED THAT THERE WERE

ISSUES, AS I REMEMBER, YES.

Q SO THE ANSWER TO MY QUESTION IS YES, NARCONON

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INTERNATIONAL WAS AWARE OF THE FACT PRIOR TO PATRICK

DESMOND'S DEATH THAT NARCONON OF GEORGIA WAS HAVING

ISSUES WITH THE DELGADO HOUSING?

A WELL, YOU WOULD HAVE TO DEFINE WHAT ISSUES,

WHAT ISSUES ARE, BUT THERE -- THE SAME REPORTS THAT

YOU'VE SEEN I'VE SEEN WHERE MARY WROTE REPORTS SAYING

THAT THERE WERE ISSUES AND THAT SHE WAS ADDRESSING THEM.

Q AND THERE WERE REPORTS THAT WERE PROVIDED TO

NARCONON INTERNATIONAL PRIOR TO PATRICK'S DEATH THAT

STUDENTS WERE USING DRUGS AND ALCOHOL AT THE DELGADO

PREMISES?

A I DON'T REMEMBER EXACTLY THE DOCUMENT. I --

Q WELL, WHAT HAVE YOU DONE TO EDUCATE YOURSELF ON

THAT TOPIC WHICH IS ONE OF THE TOPICS THAT YOU'VE BEEN

DESIGNATED HERE AS A WITNESS?

A WELL, THERE ARE MANY, MANY DOCUMENTS THAT I'VE

LOOKED AT. IF I COULD SEE THE SAME DOCUMENTS THAT

YOU'VE LOOKED AT I COULD REFRESH EXACTLY WHAT WE SAW.

Q WELL, I'LL BE GLAD TO GIVE YOU DOCUMENTS BUT

YOU'RE HERE, AGAIN, AS A CORPORATE REPRESENTATIVE,

RIGHT?

A YES.

Q AND YOU CHOSE NOT TO BRING ANY DOCUMENTS WITH

YOU TO THE DEPOSITION?

A MY UNDERSTANDING WAS THAT I WAS JUST TO BRING

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MYSELF. OTHERWISE, I COULD HAVE BROUGHT A WHOLE BIG

STACK.

Q BUT YOU ELECTED NOT TO?

A NO. WHAT I OBSERVED WAS THAT DOCUMENTS WERE

BEING PROVIDED AS THEY WERE, AS THEY WERE COMING UP.

Q I'M ASKING YOU AS THE CORPORATE REPRESENTATIVE

OF NARCONON INTERNATIONAL

A UH-HUH.

Q -- PRIOR TO PATRICK DESMOND'S DEATH, WAS

NARCONON INTERNATIONAL AWARE OF COMPLAINTS THAT STUDENTS

AT DELGADO HOUSING WERE USING DRUGS AND ALCOHOL?

A I BELIEVE THAT WAS REPORTED BY MARY RIESER THAT

THAT, THAT THERE WERE -- THAT THAT WAS ONGOING.

Q AND --

A I MEAN, THAT THAT HAD HAPPENED, THAT THERE WERE

REPORTS AND THAT SHE WAS DOING WHAT SHE COULD TO ADDRESS

THAT.

Q AND NARCONON INTERNATIONAL WAS AWARE OF THE

FACT PRIOR TO PATRICK DESMOND'S DEATH THAT THERE HAD

BEEN ISSUES AT DELGADO HOUSING WHERE EMPLOYEES WERE NOT

SHOWING UP FOR WORK?

MR. ROOT: EMPLOYEES OF WHOM?

MR. HARRIS: DELGADO.

THE WITNESS: I WOULD HAVE TO LOOK AT THE DOCUMENT

ON THAT PARTICULAR POINT.

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Q BY MR. HARRIS: WHAT DID YOU DO TO DETERMINE

WHETHER OR NOT THAT WAS TRUE IN PREPARATION FOR YOUR

DEPOSITION HERE TODAY?

A I DON'T UNDERSTAND THE QUESTION.

Q DID YOU LOOK AT THE DOCUMENTS THAT

A YES. I LOOKED AT MANY, MANY DIFFERENT

DOCUMENTS.

Q ALL RIGHT.

AND I'M ASKING YOU, AND JUST TELL ME WHETHER

YOU CAN ANSWER THIS OR NOT.

A UH-HUH.

Q WAS NARCONON INTERNATIONAL, PRIOR TO PATRICK

DESMOND'S DEATH, WAS NARCONON INTERNATIONAL AWARE OF

COMPLAINTS OR CONTENTIONS THAT EMPLOYEES OF DELGADO

DEVELOPMENT WERE NOT SHOWING UP FOR WORK AT THE DELGADO

HOUSING?

A THAT -- THAT -- I DON'T REMEMBER THAT EXACTLY

BUT THAT MAY HAVE BEEN IN ONE OF MARY'S REPORTS.

MR. ROOT: JEFF, AM I ALLOWED TO ASK A QUESTION?

IS THAT A SPECIFIC AREA OF INQUIRY ON 30(B) (6) ABOUT

EMPLOYEES SHOWING UP FOR WORK?

MR. HARRIS: I MEAN, I THINK IT'S MORE -- I MEAN,

IF YOU DON'T THINK THAT WAS A TOPIC I'LL GO BACK AND

LOOK AT IT. I TELL YOU, I TRIED MY BEST TO ASK IT ABOUT

FIVE DIFFERENT WAYS.

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MR. ROOT: I'M NOT TRYING TO FUSS ABOUT IT BUT I

HOPE HE'S PREPARED TO ANSWER IT IF IT'S A SPECIFIC

QUESTION AND IF, YOU KNOW, I KNOW YOU'RE FUSSING AT HIM

A LITTLE BIT ABOUT HIM NOT KNOWING CERTAIN THINGS BUT I

KNOW HE WAS TRYING TO PREPARE FOR SPECIFIC QUESTIONS

HERE AND EMPLOYEES NOT SHOWING UP IS NOT SPECIFICALLY ON

HERE. HE MAY NOT HAVE RESEARCHED THAT. I DON'T KNOW.

THAT'S MY ONLY THOUGHT.

AND YOU DON'T HAVE TO COMMENT ON THAT.

THE WITNESS: RIGHT.

MR. ROOT: I'M JUST TRYING TO --

THE WITNESS: I MEAN, I CAN, YOU KNOW, GET THESE

DOCUMENTS. I DID NOT BRING -- I DO NOT HAVE THEM IN MY

HAND RIGHT HERE. I DO NOT HAVE THEM ALL MEMORIZED. BUT

I'M PREPARED TO RESPOND TO THEM.

MR. ROOT: JUST WAIT FOR A QUESTION.

Q BY MR. HARRIS: I THINK THAT NARCONON

INTERNATIONAL'S KNOWLEDGE OF ANY AND ALL COMPLAINTS OR

ALLEGATIONS RELATED TO HOUSING CONDITIONS AT NARCONON OF

GEORGIA WOULD CERTAINLY CALL THIS INTO QUESTION.

A WE WERE AWARE OF --

MR. ROOT: WAIT FOR A QUESTION.

AND I UNDERSTAND THAT, JEFF, AND I JUST -- I

MEAN, WE MAY NOT HAVE BEEN AWARE OF THE POINT --

MR. HARRIS: THE PURPOSE --

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MR. ROOT: -- ABOUT PEOPLE SHOWING UP. I JUST

DON'T KNOW.

MR. HARRIS: THE PURPOSE OF ANY BOARD OF,

BASICALLY, THE KNOWLEDGE OF THE BOARD OF INVESTIGATION

AND THE URGENT DIRECTIVES THAT WERE ALL CONDUCTED BY

NARCONON OF GEORGIA. THAT'S ASKED THREE DIFFERENT

TIMES.

THE WITNESS: NO, YOU DIDN'T MENTION URGENT

DIRECTIVES.

Q BY MR. HARRIS: WELL, OKAY. LET'S TALK -

MR. ROOT: LET'S WAIT FOR A QUESTION, MR. CARR.

HE'LL ASK YOU A QUESTION. WE'LL TRY TO MOVE FORWARD.

Q BY MR. HARRIS: EXHIBIT NO. 17 TO THE PREVIOUS

DEPOSITION. NARCONON INTERNATIONAL HAD EXHIBIT 17

BEFORE PATRICK DESMOND'S DEATH, CORRECT?

A WELL, THE DATE'S -- THE -- WHAT NARCONON

INTERNATIONAL WOULD HAVE HAD WOULD HAVE BEEN THIS TOP

DOCUMENT. THERE IS ONE UNDERNEATH WHICH HAS THE URGENT

DIRECTIVES WHICH WAS ONLY TO NARCONON EASTERN US AND WE

DID NOT HAVE THAT.

Q ALL RIGHT.

WELL, LOOK AT THE BOTTOM OF THE SECOND PAGE OF

THE URGENT DIRECTIVE WHERE IT SAYS "CC HCO NN INT."

A YES.

Q AND THAT'S NARCONON INTERNATIONAL.

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A YES. IT SAYS HERE THAT IT IS CC'D. I DON'T

HAVE KNOWLEDGE THAT WE ACTUALLY RECEIVED THAT URGENT

DIRECTIVE.

Q SO IS IT YOUR POSITION THAT YOU NEVER GOT THIS?

A NOT AT THIS TIME. IT MAY HAVE BEEN --

Q IT WAS PRODUCED BY NARCONON INTERNATIONAL.

A YES. AND THEN IT GOT IN THE FILES. I DON'T

KNOW WHETHER IT WAS -- WHEN IT WAS SEEN.

Q IS IT NARCONON INTERNATIONAL'S POSITION THAT IT

WAS UNAWARE OF THE URGENT DIRECTIVE THAT WAS IMPLEMENTED

BY NARCONON OF GEORGIA ON MARCH THE 2ND, 2008 BEFORE

PATRICK DESMOND'S DEATH?

A FROM WHAT I HAVE BEEN TOLD BY THE OTHER STAFF

MEMBERS, WE DID NOT SEE THIS AT THAT TIME.

Q LOOK AT THE FIRST PAGE OF EXHIBIT 17.

A UH-HUH.

Q THERE IS AN E-MAIL --

A UH-HUH.

Q -- DOWN HERE THAT GOES TO CLAUDIA, RIGHT? DO

YOU SEE THAT?

A "DEAR CLAUDIA. OKAY. I WILL READ THE POLICY

LETTER."

Q IT SAYS "WE HAVE TO LET THE BOARD OF

INVESTIGATION DEVELOP AS MARIA IS STAFF AT THE ORG."

DID I READ THAT CORRECTLY?

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A YES.

Q "THE PURPOSE OF THE," ABOVE THAT IT SAYS "THE

PURPOSE OF THE CURRENT BOARD OF INVESTIGATION IS TO GET

RID OF MARIA. "

DID I READ THAT CORRECTLY?

A WHERE IS THIS?

Q RIGHT ABOVE THE SENTENCE THAT I JUST READ.

A OKAY. YES.

Q THE E-MAIL IS DATED MARCH 7TH, 2008, RIGHT?

A UH-HUH.

Q SO NARCONON INTERNATIONAL WAS AWARE OF THE

BOARD OF INVESTIGATION PRIOR TO PATRICK'S DEATH,

CORRECT?

A WE WERE AWARE OF THE BOARD OF INVESTIGATION,

THAT ONE WAS BEING HELD, YES.

Q WHAT DID NARCONON INTERNATIONAL DO TO

INVESTIGATE THE PURPOSE OF THE BOARD OF INVESTIGATION?

A WELL, WE WERE NOT HOLDING THAT. THAT WAS

NARCONON OF GEORGIA'S RESPONSIBILITY. THEY WERE -- THEY

CALLED IT, THEY WERE HOLDING IT.

Q OKAY.

WELL, IS THAT BOARD OF INVESTIGATION, DOES IT

PERTAIN TO A NONOPTIMUM SITUATION, SIR?

A THAT'S WHAT THEY WERE -- THAT'S WHY THEY WERE

HOLDING IT, YES, AND THAT'S CORRECT THAT THEY WOULD HOLD

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IT BECAUSE THEY'RE RESPONSIBLE FOR THEIR OWN CENTER.

Q WHAT DID NARCONON INTERNATIONAL DO TO CORRECT

NARCONON OF GEORGIA'S NONOPTIMUM SITUATION THAT EXISTED

PRIOR TO PATRICK DESMOND'S DEATH?

MR. ROOT: OBJECT TO THE FORM.

THE WITNESS: THERE ARE THE COMMUNICATIONS FROM

NARCONON EASTERN US OF WHAT THEY WERE, STAFF THERE WERE

AWARE OF AND WORKING ON AND CLAUDIA'S, THE DIRECTOR OF

LEGAL AFFAIRS CONSULTING REGARDING HELPING MARY TO

CONTINUE TO RESOLVE THAT SITUATION.

OUR WORK WAS WITHIN THE TRADEMARK LICENSE

AUTHORITY OF HELPING -- WHICH OUR PRIME CONCERN IS THE

DELIVERY OF THE NARCONON PROGRAM AND WHAT IS HAPPENING

WITH THE DELIVERY OF THE PROGRAM. IF THERE'S SOMETHING

THAT IS OUTSIDE THE BOUNDS OF THAT WE MAY DELIVER ADVICE

BUT IT IS NOT PART OF OUR TRADEMARK LICENSE

RESPONSIBILITY.

Q BY MR. HARRIS: I DIDN'T ASK YOU ABOUT THE

TRADEMARK LICENSE AGREEMENT.

A YES.

Q AND I ACTUALLY SPECIFICALLY DIRECTED YOU TO THE

PARAGRAPH NO. 4 OF THE BUSINESS ASSOCIATE AGREEMENT.

RIGHT?

A UH-HUH.

Q DOES NARCONON EAST US, DOES IT HAVE A BUSINESS

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R Leonard CSR, Inc.

ASSOCIATE AGREEMENT WITH NARCONON OF GEORGIA?

A I ACTUALLY DON'T KNOW IF NARCONON EASTERN US

DOES.

Q OKAY.

BUT THE ONE THAT WE'VE BEEN TALKING ABOUT THAT

IS IN EXHIBIT 14

A UH-HUH.

Q -- IS AN AGREEMENT BETWEEN NARCONON

INTERNATIONAL AND NARCONON OF GEORGIA, CORRECT?

A UH-HUH.

Q YOU WOULD AGREE WITH ME -- I THINK YOU ALREADY

HAVE THAT THE BOARD OF INVESTIGATION AND THE

SITUATION THAT WAS GOING ON AT NARCONON OF GEORGIA PRIOR

TO PATRICK'S DEATH

A UH-HUH.

Q -- RELATED TO THE BOARD OF INVESTIGATION WAS A

NONOPTIMUM SITUATION?

A WAS ABOUT NONOPTIMUM SITUATIONS, YES.

Q AND MY QUESTION WAS NOT WHAT EAST US DID. WHAT

DID NARCONON INTERNATIONAL DO TO ATTEMPT TO CORRECT THAT

NONOPTIMUM SITUATION?

A THOSE ACTIONS THAT WE COULD TAKE THAT WERE ALSO

WITHIN OUR TRADEMARK LICENSE.

Q AGAIN, I'M ASKING YOU A SIMPLE QUESTION ABOUT

WHAT YOU DID, NOT YOUR TRADEMARK LICENSE. I JUST NEED

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TO KNOW WHAT NARCONON INTERNATIONAL DID, IF ANYTHING, TO

CORRECT THE NONOPTIMUM SITUATION.

A IN THE CONTINUING CONSULTATION WITH MARY, BOTH

FROM VIA NARCONON EASTERN US AND FROM NARCONON

INTERNATIONAL, WE ENCOURAGED MARY TO RESOLVE THE

CHALLENGES THAT SHE WAS HAVING WITH HOUSING.

Q AND HOW DID NARCONON INTERNATIONAL ENCOURAGE

MARY TO RESOLVE THE SITUATION?

A AS MARY HAD EARLIER SAID THAT SHE WAS WISHING

TO CHANGE HOUSING, WE ENCOURAGED HER AS PER CLAUDIA'S

COMMUNICATION HERE TO FOLLOW THROUGH WITH PHASING OUT

THAT HOUSING AND FINDING ALTERNATIVE HOUSING. AGAIN,

THIS, THE RESPONSIBILITY WAS HERS, NOT OURS BECAUSE WE

HAVE -- WE HAVE A LIMITATION OF WHAT WE DO. REGARDLESS

OF WHAT IS WRITTEN IN THE BUSINESS ASSOCIATE AGREEMENT,

OUR CONTRACTUAL SENIOR RESPONSIBILITY IS WHAT IS IN THE

TRADEMARK LICENSE SO THAT IS WHAT OUR ATTENTION GOES TO.

OUTSIDE OF THAT, WE CAN ONLY MAKE RECOMMENDATIONS.

Q YOU SAID REGARDLESS OF WHAT'S IN THE BUSINESS

ASSOCIATE AGREEMENT. IS IT NARCONON INTERNATIONAL'S

POSITION THAT THIS AGREEMENT IS MEANINGLESS AND HAS NO

PURPOSE WHATSOEVER?

A NO, THAT'S NOT WHAT I SAID AT ALL.

Q OKAY.

I HAVEN'T BEEN ASKING YOU ABOUT THE LICENSE

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1 AGREEMENT AND YET YOU KEEP GOING BACK TO IT. LET'S STAY

2 FOCUSED ON THE BUSINESS ASSOCIATE AGREEMENT, SHALL WE?

A

Q

BUT THEY BOTH EXIST AT THE SAME TIME.

OKAY.

10:11:53 3

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10:11:59 5 A AND THEREFORE THAT IS OUR, YOU KNOW, WE HAVE TO

6 COMPLY WITH BOTH.

10:12:02 7

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Q ALL RIGHT.

NOW, TURN TO THE SECOND PAGE OF, I THINK IT'S

9 1967 IS THE BATES NUMBER OF EXHIBIT 17.

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A

Q

A

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A

Q

A

Q

A

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OKAY.

THIS IS AN E-MAIL FROM CLAUDIA -

UH-HUH.

-- TO ISAAC, CORRECT?

UH-HUH.

ISAAC IS AT EAST US?

YES.

AND CLAUDIA'S AT INTERNATIONAL, CORRECT?

YES.

SHE SAYS, QUOTE, "I WILL RUN THE PROGRAM FROM

MY POST HERE.


A UH-HUH.

Q AND THEN SHE LISTS A NUMBER OF THINGS THAT

24 SHE'S ENCOURAGING MARY TO DO.

10:12:41 25 A UH-HUH.

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Q "FIND HOUSING."

DO YOU SEE THAT, NO. 1?

A UH-HUH. UH-HUH.

Q AND THEN NO. 3 IS "GET RID OF THE DELGADOS."

DO YOU SEE THAT?

A UH-HUH. UH-HUH.

Q SHE SAYS "I WILL RUN THE PROGRAM FROM MY POST

HERE."

WHAT DOES THAT, WHAT IS RUNNING THE PROGRAM

FROM MY POST HERE MEAN AS A REPRESENTATIVE OF NARCONON

INTERNATIONAL?

A IT MEANS THAT THE, PER THE TRADEMARK LICENSE,

WHICH IS WHAT ALL OF OUR ACTIONS ARE GUIDED BY, SHE WILL

MONITOR THE, YOU KNOW, THE DELIVERY OF THOSE PROGRAM

ACTIONS THAT ARE IMPORTANT TO DELIVERY. SO AS THIS IS

SOMETHING THAT'S GOING TO HELP BENEFIT THE STUDENTS, SHE

WOULD SEE THAT MARY WAS IN COMPLIANCE WITH HER, YOU

KNOW, WITH THOSE THINGS THAT NEEDED TO BE DONE FOR THE

BENEFIT OF HER OWN STUDENTS.

Q ALL RIGHT.

WELL, WHAT THE E-MAIL SAYS IS THAT THE POINTS

THAT NEED HANDLING ARE NO. 1, FIND HOUSING; NO. 2, GET

UNDER THE GARR AND THEN; NO. 3, GET RID OF THE DELGADOS,

CORRECT?

A UH-HUH. UH-HUH.

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Q AND THEN THE E-MAIL FROM CLAUDIA WHO IS AT

INTERNATIONAL SAYS "I'LL RUN THE PROGRAM FROM HERE."

YOU SEE WHERE I'M READING?

A YES. BUT WHAT FOLLOWS IS "WHAT IS NEEDED NOW

IS FOR MARY TO WRITE UP A SHORT PROGRAM." SO THIS WOULD

BE A PROGRAM THAT MARY WOULD BE WRITING UP AND THEN

CLAUDIA WOULD SEE THAT MARY, IN FACT, COMPLIED WITH HER

OWN PROGRAM AND DID NOT GET DISTRACTED BY OTHER AFFAIRS.

IT WAS MARY'S PROGRAM.

Q WHAT DID NARCONON INTERNATIONAL DO TO SEE THAT

MARY DIDN'T GET DISTRACTED AND THAT SHE ACTUALLY

FOLLOWED UP WITH THE PROGRAM THAT'S REFERRED TO IN THIS

E-MAIL?

A I DON'T HAVE DOCUMENTATION ON THAT BUT THERE

WOULD BE THE CONTINUING COMMUNICATIONS BETWEEN, YOU

KNOW, AS TIME MOVED FORWARD BETWEEN NARCONON

INTERNATIONAL AND EASTERN US --

Q OKAY.

A -- AND NARCONON OF GEORGIA.

Q AND AGAIN, YOU'RE HERE AS A REPRESENTATIVE OF

NARCONON INTERNATIONAL.

A WHAT WE HAD, AS I RECALL, WERE CONTINUING

REPORTS FROM MARY THAT THE SITUATION WAS BEING WORKED ON

AND SHE WAS RESOLVING IT.

Q WHERE ARE THOSE REPORTS?

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A I DON'T HAVE WRITTEN COPIES OF THOSE REPORTS.

Q HAVE YOU SEEN REPORTS FROM MARY ABOUT THESE,

ABOUT THIS SITUATION? I CAN TELL YOU THEY HAVEN'T BEEN

PRODUCED TO US IN THIS CASE.

A NO, I HAVEN'T SEEN ANY WRITTEN REPORTS.

Q WELL, THEN HOW DO YOU KNOW THAT THAT'S WHAT

HAPPENED?

A BECAUSE WE HAD THE CONTINUING RELATIONSHIP AND

THE STATISTICS WOULD HAVE BEEN COMING UP ON A WEEKLY

BASIS AND THERE WOULD HAVE BEEN COMMUNICATION AND IT'S

PART OF THE NARCONON EASTERN US HAS REGULAR

COMMUNICATION WITH MARY'S CENTER AND THIS, THIS WOULD

HAVE BEEN CERTAINLY ONE OF THE MATTERS TAKEN UP, HOW IS

THAT GOING, HOW ARE YOU DOING ON YOUR PROGRAM. AGAIN,

IT WAS MARY'S RESPONSIBILITY AND IT WOULD HAVE BEEN

SIMPLY CONSULTING WITH HER.

Q MR. CARR, YOU'RE, AGAIN, I HATE TO KEEP SAYING

THIS BUT YOU ARE HERE AS A CORPORATE REPRESENTATIVE OF


A UH-HUH.

Q NUMEROUS TIMES THROUGHOUT THESE TOPICS WE'VE

ASKED ABOUT NARCONON'S KNOWLEDGE OF ANY ISSUES RELATED

TO HOUSING OR PROBLEMS AT NARCONON OF GEORGIA, RIGHT?

A UH-HUH.

Q THAT'S CLEARLY A TOPIC THAT YOU'RE HERE TO TALK

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ABOUT.

A UH-HUH.

Q NARCONON INTERNATIONAL WAS AWARE OF THE FACT

THAT THERE WERE ISSUES PRIOR TO PATRICK'S DEATH AND, IN

FACT, EVEN SAID, ONE OF THE EMPLOYEES SAID "I WILL RUN

THE PROGRAM FROM HERE," RIGHT?

A MARY'S PROGRAM, YES. SHE WILL, YOU KNOW, WHAT

THAT ACTUALLY MEANS IS THAT MARY, HAVING WRITTEN THE

PROGRAM, YOU KNOW, SHE WILL, YOU KNOW, FOLLOW UP TO SEE

THAT MARY COMPLETES THAT PROGRAM.

Q AND NARCONON INTERNATIONAL WAS AWARE OF THE

FACT THAT GEORGIA HAD EVEN PUT THE DELGADOS ON

PROBATION?

A THAT SPECIFIC DOCUMENT, I DON'T KNOW IF WE SAW

THAT. I WOULD HAVE TO SEE THAT DOCUMENT. I --

Q I'M ASKING YOU AS THE CORPORATE REPRESENTATIVE

OF NARCONON INTERNATIONAL, WAS NARCONON INTERNATIONAL

AWARE OF THE FACT THAT NARCONON OF GEORGIA HAD PUT THE

DELGADO HOUSING ON PROBATION PRIOR TO PATRICK DESMOND'S

DEATH?

A I DON'T BELIEVE THAT SPECIFIC PHRASE PER THE

DOCUMENT WHICH I SAW AS PART OF THIS, THAT WE WERE AWARE

OF THAT SPECIFIC PHRASE.

Q EXHIBIT NO. 20.

A UH-HUH.

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Q BATES NO. 1479.

A UH-HUH.

Q THIS IS A DOCUMENT PRODUCED BY NARCONON


A YES.

Q MIDDLE PARAGRAPH, IT SAYS "IN LIGHT OF THE

RECENT DRUG INCIDENT ON A NIGHT SPECIFICALLY THAT

NARCONON WAS ON HIGH ALERT, WE ARE PLACING YOUR COMPANY

ON PROBATION FOR A MONTH."


A YES.

Q THIS DOCUMENT CLEARLY SAYS THAT NARCONON OF

GEORGIA IS PUTTING NARCONON -- OR EXCUSE ME -- PUTTING

DELGADO ON PROBATION EFFECTIVE MARCH 23RD, RIGHT?

A YES.

Q AND THIS IS A DOCUMENT THAT WAS PRODUCED BY

INTERNATIONAL?

A YES. THIS IS THE ONE THAT, AS I SAY, WAS FILED

AND THAT THE GENERAL STAFF DID NOT HAVE KNOWLEDGE OF THE

SPECIFICS OF THIS DOCUMENT UNTIL LATER.

FACT?

Q IS THAT THE POSITION OF NARCONON INTERNATIONAL?

A YES.

Q NARCONON INTERNATIONAL WAS UNAWARE OF THAT

A OF THE SPECIFIC FACT, YES.

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Q EVEN THOUGH CLAUDIA HAD SAID THAT SHE WILL BE

RUNNING THE PROGRAM FROM HERE ABOUT GETTING RID OF THE

DELGADOS?


THE WITNESS: THE FACT OF WHETHER THEY HAD BEEN PUT

ON PROBATION AND WHAT, YOU KNOW, I DON'T KNOW THAT WE

KNEW THAT. I SAW ANOTHER DOCUMENT WHERE MARY WROTE A

SPECIFIC LETTER TO THE DELGADO DEVELOPMENT ALONG WITH

HER BOARD OF DIRECTORS. THAT'S WHAT I WAS THINKING OF.

IN TERMS OF THIS, WE DID NOT SEE THIS BOARD OF

INVESTIGATION UNTIL LATER SO WE KNEW THERE WAS A

SITUATION AND MARY WAS WRITING A PROGRAM TO HANDLE IT

WHICH IS HER RESPONSIBILITY AND NARCONON INTERNATIONAL

WAS CONSULTING WITH HER REGARDING HER RESPONSIBILITY FOR

HER OWN CENTER AND THIS PROGRAM.


THEN LET'S DO IT THIS WAY.

PRIOR TO PATRICK DESMOND'S DEATH, WAS NARCONON

INTERNATIONAL AWARE OF THE URGENT DIRECTIVES THAT HAD

BEEN IMPLEMENTED BY NARCONON OF GEORGIA?

A TO MY KNOWLEDGE, WE DID NOT SEE THOSE IN

WRITING UNTIL LATER.

Q SO YOUR CONTENTION IS THAT YOU HAD NO KNOWLEDGE

UNTIL AFTER PATRICK'S DEATH OF THE URGENT DIRECTIVES?

A TO THE BEST OF MY KNOWLEDGE.

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Q WHAT DOES THAT MEAN?

A NOT HAVING THE, ALL OF THE DOCUMENTS HERE WITH

ME TO REVIEW, THAT'S WHAT I REMEMBER IS THAT THE I'M

NOT SURE THE URGENT DIRECTIVES WERE EVEN SENT TO US

UNTIL AFTER THE FACT. THE BOARD OF INVESTIGATION WAS

FOUND IN LEGAL FILES, NOT IN OUR REGULAR PRODUCTION

FILES AND, THEREFORE, WAS NOT, WAS NOT SEEN. THE URGENT

DIRECTIVE WOULD HAVE COME BEFORE THE BOARD OF

INVESTIGATION. IT WOULD NOT NECESSARILY HAVE EVEN BEEN

SENT TO US.

Q ALL RIGHT.

EVEN THOUGH

A WE KNEW THAT IT WAS REPORTED BY MARY THAT SHE

WAS DOING A BOARD OF INVESTIGATION, SO THIS IS NOT AN

UNUSUAL THING. A CENTER CAN DO THAT WHEN THERE'S

SOMETHING THAT NEEDS TO BE DONE AND --

Q YOU HAVE, YOU HAVE THE DOCUMENT OR NARCONON

INTERNATIONAL HAS THE DOCUMENT IN ITS FILES, THE URGENT

DIRECTIVE DOCUMENT, CORRECT?

A YEAH. IT WAS IN LEGAL FILING, NOT IN OUR

REGULAR PRODUCTION FILING.

Q WHAT DOES THAT MEAN? YOU KEEP MAKING SOME

DISTINCTION BETWEEN YOUR LEGAL FILING AND YOUR REGULAR

PRODUCTION FILING.

A LEGAL FILING HAS TO DO WITH LEGAL ISSUES,

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R. Leonard CSR, inc.

PRODUCTION FILING HAS TO DO WITH THE COMMUNICATION BACK

AND FORTH BETWEEN THE CENTER AND SO FORTH, SO IT WAS

ESSENTIALLY MISFILED.

Q BUT THE LEGAL FILING IS SOMETHING THAT IS

MAINTAINED BY NARCONON INTERNATIONAL?

A YES. BY A SEPARATE DEPARTMENT. SO THE FACT IS

THIS WAS NOT IN THE FILES WHERE WE WOULD ORDINARILY SEE

IT AND THEREFORE IT GOT MISSED.

Q WHAT DO YOU MEAN IT GOT MISSED?

A IT -- YOU KNOW, IT -- TO MY KNOWLEDGE, THIS

CAME TO US AFTER THE, THE ACTUAL DOCUMENT CAME TO US

AFTER THE FACT OF MR. DESMOND'S DEATH WITH DOCUMENTS

THAT WERE PICKED UP DURING THE LEGAL RUDIMENTS

INSPECTION AND THEN IT WAS BROUGHT BACK. IT WAS,

BECAUSE IT WAS A LEGAL RUDIMENTS INSPECTION IT WAS FILED

IN THE LEGAL DEPARTMENT. SO WE HAVE NO COPY OF THIS

PRIOR TO MR. DESMOND'S DEATH. WE -- A COPY WAS BROUGHT

BACK TO US AFTER THE LEGAL RUDIMENTS INSPECTION AND

THAT'S WHEN WE BECAME AWARE OF IT.

Q ALL RIGHT.

SO, AND I'M JUST TRYING TO GET A CLEAN ANSWER

TO THESE QUESTIONS ON THE RECORD.

NARCONON INTERNATIONAL'S POSITION IS, AND BY

NARCONON INTERNATIONAL I MEAN THE LEGAL FILING AND THE

PRODUCTION FILING.

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Q

A

Q

UH-HUH.

I'M MAKING NO DISTINCTION.

UH-HUH.

NARCONON INTERNATIONAL'S POSITION IS, PRIOR TO

5 PATRICK'S DEATH IT DID NOT HAVE A COPY OF THE URGENT

6 DIRECTIVE?

10:22:57 7 A THE URGENT DIRECTIVE IS NOT INCLUDED HERE. I

8 WOULD ACTUALLY HAVE TO SEE THAT. I DON'T BELIEVE SO.

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A

Q

A

Q

I JUST NEED AN ANSWER.

OKAY. TO THE BEST OF MY KNOWLEDGE, NO.

THE BEST OF THE CORPORATION'S KNOWLEDGE?

YES.

EVEN THOUGH NARCONON INTERNATIONAL WAS CC'D ON

14 THE URGENT DIRECTIVE?

10:23:13 15

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A

Q

A

IT STATES THAT.

THAT'S WRONG?

WELL, IT STATES THAT. THAT DOES NOT MEAN IT

18 WAS RECEIVED.

Q

A

Q

OKAY. ALL RIGHT.

IT WAS SENT AND RECEIVED.

ALL RIGHT.

10:23:19 19

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SO NARCONON INTERNATIONAL DIDN'T GET A COPY OF

THE URGENT DIRECTIVE UNTIL AFTER THE DEATH, ACCORDING TO

YOU AS THE CORPORATE REPRESENTATIVE?

A YES.

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Q SAME QUESTION WITH RESPECT TO THE BOARD OF

INVESTIGATION.

A YES. IT ALL CAME AS PART OF ONE PACKAGE AFTER

THE FACT.

Q ALL RIGHT.

SO NARCONON INTERNATIONAL'S CONTENTION AND YOU

AS THE CORPORATE REPRESENTATIVE ARE GOING TO TESTIFY TO

THIS FACT THAT NARCONON INTERNATIONAL WAS UNAWARE OF THE

BOARD OF INVESTIGATION UNTIL AFTER PATRICK DESMOND'S

DEATH?

A NO. WE WERE AWARE THAT THE BOARD OF

INVESTIGATION WAS BEING HELD. WE DIDN'T GET THE, THE

WRITTEN, THE WRITTEN ISSUE ON THAT UNTIL AFTER THE FACT.

Q SO YOU'RE MAKING A DISTINCTION BETWEEN THE

ACTUAL BOARD OF INVESTIGATION DOCUMENTS?

A WELL, WE WERE AWARE THAT A BOARD OF

INVESTIGATION WAS BEING HELD AND THAT -- WE WOULD NOT

NECESSARILY ALWAYS HAVE A BOARD OF INVESTIGATION BEING

SENT TO US. IN OTHER WORDS, MARY REPORTED THAT THIS WAS

BEING DONE, IT WAS KNOWN, AND THAT'S WHAT WAS KNOWN IS

THAT SHE WAS DOING IT.

Q OKAY.

AND I, MY QUESTION WAS DIFFERENT.

YOU'RE TALKING ABOUT THE -- YOU'VE ALREADY TOLD

US SEVERAL TIMES THAT YOU WERE AWARE OF THE FACT OF A

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BOARD OF INVESTIGATION,

A BEING HELD, YES.

Q CORRECT.

A UH-HUH.

Q WHAT I WAS ASKING YOU WAS A DIFFERENT QUESTION

WHICH IS, THE ACTUAL BOARD OF INVESTIGATION DOCUMENTS

THEMSELVES --

A UH-HUH.

Q -- IS IT YOUR POSITION OR NARCONON

INTERNATIONAL'S POSITION THAT IT DID NOT HAVE IN ITS

POSSESSION ANY OF THE BOARD OF INVESTIGATION DOCUMENTS

PRIOR TO PATRICK'S DEATH?

A YES.

Q ALL RIGHT.

EXHIBIT 20.

A UH-HUH. YES.

Q BATES 1482 AT THE BOTTOM.

A UH-HUH.

Q LOOK UP AT THE TOP. IT SAYS "NARCONON

INTERNATIONAL."

A UH-HUH.

Q DO YOU SEE WHERE I'M READING?

A YES.

Q SO ONCE AGAIN, EVEN THOUGH NARCONON

INTERNATIONAL APPEARS TO HAVE BEEN COPIED ON THE

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FINDINGS AND RECOMMENDATIONS OF THE BOARD OF

INVESTIGATION, YOU DIDN'T GET IT UNTIL AFTER THE DEATH?

A NO. THIS WHOLE PACKAGE WAS, WAS BROUGHT AT ONE

TIME.

Q IF YOU'LL LISTEN TO MY QUESTION IT WILL MAKE

THINGS GO SO MUCH SMOOTHER.

A OKAY. I'M SORRY.

Q THE DOCUMENT 1482

A UH-HUH.

Q -- IS THE BOARD OF INVESTIGATION FINDINGS AND

RECOMMENDATIONS.

A YES.

Q NARCONON INTERNATIONAL IS COPIED ON THE TOP

LEFT CORNER OF THAT DOCUMENT, IS IT NOT, SIR?

A IT'S INDICATED AS PART OF THE DISTRIBUTION,

YES.

Q SO YOUR POSITION AS A REPRESENTATIVE OF

NARCONON INTERNATIONAL IS, JUST LIKE THE URGENT

DIRECTIVE THAT YOU WERE COPIED ON, YOU DIDN'T GET THAT

ONE, EITHER?

A YES. NOT UNTIL AFTER THE FACT.

Q OKAY.

MR. ROOT: JEFF, AT THE APPROPRIATE TIME IF YOU'RE

AT A GOOD SPOT FOR A BREAK.

MR. HARRIS: SURE. NOW IS FINE.

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MR. ROOT: THAT'S ALL RIGHT?

THE VIDEOGRAPHER: WE'RE GOING TO GO OFF THE

RECORD, THEN, AT 10:27 A.M.

THIS WILL BE THE END OF DISK NO. 1 OF THE

VIDEOTAPE DEPOSITION OF CLARK CARR.

(RECESS HELD) .

THE VIDEOGRAPHER: WE ARE BACK ON THE RECORD AT

APPROXIMATELY 10:38 A.M.

THIS IS THE BEGINNING OF DISK NO. 2 OF THE


Q BY MR. HARRIS: JUST FOR THE RECORD, I'VE

MARKED YOUR DEPOSITION NOTICE, THE 30 (B) (6) DEPOSITION

NOTICE, AS EXHIBIT 26.



ATTACHED HERETO) .

Q BY MR. HARRIS: NOW, LET'S GO BACK TO THIS

BOARD OF INVESTIGATION THING THAT WE WERE DISCUSSING

BEFORE THE BREAK. A BOARD OF INVESTIGATION IS A

SPECIFIC PROCEDURE THAT IS ACTUALLY DEFINED AND

DISCUSSED IN THE HOW TO RUN AN EFFECTIVE NARCONON

A YES.

Q -- CORRECT?

A UH-HUH.

Q AND IT IS IMPLEMENTED OR DONE WHEN THERE IS A

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CONFLICT, POOR PERFORMANCE OR DOWN STATISTIC; IS THAT

RIGHT?

A YES. IT CAN ALSO BE DONE IF THERE'S A VERY

STRONG UP STATISTIC, YOU KNOW. IT'S BASICALLY WHERE YOU

WANT TO FIND OUT WHAT'S GOING ON.

Q OKAY.

WELL, IT DOESN'T SAY ANYTHING ABOUT THAT IN THE

MANUAL.

A OKAY.

Q IT SAYS CONFLICT, POOR PERFORMANCE OR DOWN

STATISTIC.

A ALL RIGHT.

Q RIGHT?

A YES.

Q WELL, YOU JUST SAID IT COULD BE DONE IF THERE

WAS SOMETHING, IT SOUNDS LIKE SOMETHING GOOD GOING ON.

A YES. IF THERE'S AN EXTRAORDINARILY UP, YOU

KNOW, UPTICK IN SOMETHING AND YOU WANT TO FIND OUT WHY

IS THIS GOOD THING HAPPENING, YOU COULD ALSO DO A BOARD

OF INVESTIGATION THERE.

Q THAT'S NOT WHY THE BOARD OF INVESTIGATION WAS

DONE AT NARCONON OF GEORGIA, IS IT?

A NO.

Q AND WE CAN AGREE THAT THE REASON IT WAS DONE IS

BECAUSE THERE WAS AN ISSUE OF POOR PERFORMANCE GOING ON,

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RIGHT?

A WHAT I UNDERSTAND IS THAT THERE WERE, THERE

WERE CONFLICTS WITH HOUSING AND PROBLEMS AND THERE ALSO

MAY HAVE BEEN INTERNAL ISSUES WITH PRODUCTION THAT MARY

RIESER WAS LOOKING AT.

Q THE BOARD OF INVESTIGATION INTO THE DELGADO

HOUSING WAS CONDUCTED BY NARCONON OF GEORGIA?

A YES.

Q NOW, WHAT THE MANUAL SAYS, HOW TO RUN AN

EFFECTIVE NARCONON, WHAT IT SAYS IS THAT A BOARD OF

INVESTIGATION HAS TO BE COMPLETED IN ONE WEEK, RIGHT?

A UH-HUH.

Q AND THEN THE FINDINGS OF THE BOARD OF

INVESTIGATION HAVE TO BE PUT INTO SOME USABLE FORM.

A UH-HUH.

Q AND CONVEYED TO THE GOVERNING AUTHORITY.

A UH-HUH.

Q AND A BOARD OF INVESTIGATION ALWAYS CULMINATES

IN WRITTEN FINDINGS THAT CAN BE IMPLEMENTED TO ADDRESS

WHATEVER THE ISSUE IS THAT CALL FOR IT TO BE DONE IN THE

FIRST PLACE, RIGHT?

A THEY RESULT IN WHAT WE CALL FINDINGS AND

RECOMMENDATIONS.

Q AND THOSE ARE ALWAYS WRITTEN?

A YES, THEY'RE SUPPOSED TO BE.

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Q ALL RIGHT.

YOUR POSITION IS OR NARCONON INTERNATIONAL'S IS

THAT IT WAS AWARE OF THE BOARD OF INVESTIGATION BUT IT

DIDN'T HAVE A COPY OF ANY OF THE WRITTEN DOCUMENTS. I

BELIEVE THAT'S WHAT YOU'VE TOLD ME THIS MORNING.

A YES. NOT UNTIL AFTER THE FACT. AND AGAIN, IT

WAS NOT OUR BOARD OF INVESTIGATION, IT WAS MARY

RIESER'S.

Q I DON'T BELIEVE I SAID IT'S YOUR BOARD OF

INVESTIGATION BUT IF I DID I DIDN'T MEAN TO.

A OKAY.

Q BUT NARCONON INTERNATIONAL WAS AWARE OF THE

FACT THAT THE BOARD OF INVESTIGATION WAS BEING CONDUCTED

BEFORE PATRICK'S DEATH, RIGHT?

A YES.

Q YOUR CONTENTION IS YOU DIDN'T HAVE ANY OF THE

WRITTEN DOCUMENTS, RIGHT?

A YES.

Q BUT UNDER YOUR OWN MANUAL, THERE ARE WRITTEN

DOCUMENTS AND NARCONON INTERNATIONAL WAS AWARE OF THE

FACT THAT THERE ARE SUPPOSED TO BE WRITTEN DOCUMENTS,

RIGHT?

A YES.

Q DID ANYBODY FROM NARCONON INTERNATIONAL EVER

SAY HEY, SEND ME THE BOARD OF INVESTIGATION DOCUMENTS,

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SEND THEM UP HERE SO WE CAN SEE WHAT'S GOING ON DOWN

THERE?

A I HAVE NO RECORD OF THAT.

WHAT I DO HAVE IS THAT MARY REPORTED SHE WAS

TAKING ACTIONS TO IMPROVE THINGS AND ALSO WORKING ON THE

HOUSING AND I'VE SEEN DOCUMENTS TO THAT EFFECT.

Q ALL RIGHT.

AND NARCONON INTERNATIONAL WAS COPIED ON THE

FINDINGS AND RECOMMENDATIONS OF THE BOARD OF

INVESTIGATION AS WE'VE, AS WE'VE DISCUSSED, BUT YOUR

CONTENTION IS FOR SOME REASON THAT DOCUMENT NEVER MADE

ITS WAY TO NARCONON INTERNATIONAL?

A TO THE KNOWLEDGE OF ALL OF THE STAFF THAT I'VE

SPOKEN WITH, WE DID NOT SEE IT UNTIL AFTER, AFTER THE

FACT, SPECIFICALLY, WHEN THERE WAS A LEGAL RUDIMENTS

INSPECTION AFTER MR. DESMOND'S DEATH.

Q AND THAT'S EXACTLY WHERE I WANT TO SORT OF GO

NEXT.

TELL ME EXACTLY HOW IT IS THAT NARCONON

INTERNATIONAL CAME TO BE IN POSSESSION OF THESE

DOCUMENTS THAT YOU CONTEND YOU DIDN'T HAVE BEFORE

PATRICK'S DEATH.

A AFTER THE -- MR. DESMOND'S DEATH THE DIRECTOR

OF PRODUCTION, OUR DEPUTY ED FOR PRODUCTION, AT THAT

TIME MAY HAVE BEEN OPERATIONS SUPERVISOR, YARKO

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MANZANARES, ASKED FOR A TECHNICAL INSPECTION TO BE DONE,

TRADEMARK LICENSE INSPECTION, AND CLAUDIA ASKED THAT A

LEGAL RUDIMENTS INSPECTION BE DONE WHICH WAS DONE BY

BARBARA DUNN.

Q OKAY.

A AND WHEN SHE WENT THERE SHE BROUGHT BACK SOME

DOCUMENTS WITH HER, AS I UNDERSTAND, AND THAT'S HOW

THESE WERE INCLUDED IN THAT (INDICATING) AND THEY WERE

THEN FILED AT THAT TIME.

Q IS IT NARCONON INTERNATIONAL'S POSITION, THEN,

THAT WHEN BARBARA DUNN WENT TO NARCONON OF GEORGIA TO DO

THIS INSPECTION THAT SHE REMOVED CERTAIN DOCUMENTS AND

BROUGHT THEM BACK TO INTERNATIONAL?

A I DON'T KNOW IF SHE REMOVED THEM OR MADE COPIES

OF THEM.

Q WELL, SHE BROUGHT COPIES OF THE DOCUMENTS BACK,

IS THAT WHAT YOU'RE CONTENDING?

A THAT'S WHAT I UNDERSTAND, YES. THAT IT WAS AT

THAT TIME THAT WE FOUND OUT ABOUT IT.

Q WELL, IT WAS AT THAT TIME YOU GOT THE ACTUAL

DOCUMENTS BUT YOU'D ALREADY KNOWN ABOUT IT?

A WE HAD KNOWN THAT THE BOARD OF INVESTIGATION

HAD BEEN HELD, YES.

Q NOW, TELL ME ABOUT BARBARA DUNN. WHAT WAS HER

JOB?

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A SHE WAS THE ASSISTANT OF CLAUDIA. I THINK SHE

ALSO IN ONE COMMUNICATION LABELS HERSELF THE DEPUTY

DIRECTOR OF LEGAL AFFAIRS. ESSENTIALLY, SHE WAS AN

ASSISTANT AND PERFORMED FUNCTIONS FOR CLAUDIA

ARCABASCIO.

Q ALL RIGHT.

LET ME HAND YOU 24.

A UH-HUH.

Q IS THIS THE LEGAL RUDIMENTS INSPECTION THAT YOU

WERE REFERRING TO?

A THIS IS THE REPORT -- LET ME SEE HERE UP FRONT.

THERE IS A REPORT FROM CLAUDIA REGARDING IT AND THEN,

AND THEN A RESPONSE TO THAT AND THEN A DIRECTION TO THE

EXECUTIVE DIRECTOR ON CORRECTIONS THAT NEEDED TO BE DONE

OR FURTHER ACTIONS THAT NEEDED TO BE TAKEN AFTER THAT

LEGAL RUDIMENTS INSPECTION. SO THE INSPECTION ITSELF IS

NOT HERE BUT THERE IS A REPORT ON POINTS THAT WERE FOUND

TO BE OUT AND NEEDED TO BE, FURTHER ACTIONS NEEDED TO BE

TAKEN OR CORRECTED.

Q WHAT DO YOU MEAN THE INSPECTION ITSELF IS NOT

THERE? IS THERE SOME OTHER DOCUMENT THAT WE DON'T HAVE

RELATED TO THE INSPECTION?

A I BELIEVE THERE MAY BE A DOCUMENT WHERE BARBARA

DUNN DID THE INSPECTION AND THEN MARKED -- THERE'S THE

LEGAL RUDIMENTS CHECKLIST.

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Q UH-HUH.

A MARKED THINGS IN OR OUT. THAT'S NOT HERE.

THIS IS AFTER THE FACT OF IT.

Q HAVE YOU SEEN THAT DOCUMENT?

A I BELIEVE THAT WAS PRESENTED, YEAH.

Q ALL RIGHT.

I'VE LOOKED THROUGH THIS, THIS LEGAL RUDIMENTS

INSPECTION, AND I CAN'T FIND ANY MENTION ANYWHERE IN ANY

OF THE DOCUMENTS THAT HAVE BEEN PRODUCED OF MISS DUNN

TALKING ABOUT THE FACT THAT SHE UNEARTHED BOARD OF

INVESTIGATION DOCUMENTS AND BRINGS THEM BACK.

AM I WRONG ABOUT THAT?

A THAT'S -- THAT WOULD NOT BE PART OF THIS. WHAT

THERE IS HERE IS, YOU KNOW, WHAT WERE THE POINTS THAT

WERE FOUND OUT, SO THIS IS NOT A REPORT ON THE

INSPECTION. IT'S A REPORT ON THE HANDLINGS AFTER THE

FACT OF THE INSPECTION AND IT'S WRITTEN BY CLAUDIA,

BARBARA DUNN'S SENIOR.

Q IS THERE ANY DOCUMENT THAT YOU CAN DIRECT ME TO

THAT YOU'VE SEEN, WHETHER I'VE GOT IT OR NOT, THAT

DOCUMENTS WHAT YOU'RE CONTENDING, THAT THE FIRST TIME

THE BOARD OF INVESTIGATION DOCUMENTS ARE EVER UNEARTHED

WAS WHEN BARBARA DUNN GOES DOWN TO NARCONON OF GEORGIA?

A NO, I DON'T HAVE A DOCUMENT.

Q WELL, IS THERE A DOCUMENT?

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A NO DOCUMENT THAT I'VE SEEN, SO I -- I CANNOT

SAY THERE IS NOT. LOOKING THROUGH ALL OUR FILES WE

FOUND NO SUCH DOCUMENT AND SO I BELIEVE THERE IS NO

DOCUMENT.

Q ALL RIGHT.

SO THERE'S NOTHING IN WRITING WHERE SHE SAYS

HEY, I WENT DOWN TO GEORGIA AND FOUND THESE BOARD OF

INVESTIGATION AND URGENT DIRECTIVE DOCUMENTS THAT WE

DIDN'T HAVE BEFORE THIS TIME?

A NO.

Q THE ONLY THING THAT IS IN WRITING, THEN, ARE

TWO CC'S WHERE THOSE DOCUMENTS APPEAR TO HAVE BEEN SENT

TO INTERNATIONAL?

A YEAH. WHERE THAT WAS INDICATED, YES.

Q NOW, GOING BACK TO EXHIBIT 17.

A UH-HUH.

Q NARCONON INTERNATIONAL WAS AWARE OF THE FACT

THAT PRIOR TO PATRICK DESMOND'S DEATH THERE WAS AN

ONGOING BOARD OF INVESTIGATION AND THE PURPOSE OF THAT

BOARD OF INVESTIGATION WAS TO, QUOTE, "GET RID OF

MARIA, " CORRECT?


THE WITNESS: WELL, THIS IS WHAT -- IT'S ONE

STATEMENT BY THE OPERATIONS SUPERVISOR IN EASTERN US

WRITTEN TO CLAUDIA. CLEARLY, THERE WAS FURTHER PURPOSES

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FOR THE BOARD OF INVESTIGATION THAN JUST THAT AND THIS

IS, THIS IS ISAAC'S -- ISAAC'S OPINION AND STATEMENT,

NOT WHAT MARY WROTE, YOU KNOW.


AND THEN EXHIBIT 9.

A THANK YOU.

Q THIS IS ANOTHER DOCUMENT THAT WAS GENERATED

BEFORE PATRICK DESMOND'S DEATH AND DOWN AT THE BOTTOM OF

THIS DOCUMENT, WHICH WAS DRAFTED BY MARY, MARY IS

TELLING CLAUDIA WHO WORKS FOR INTERNATIONAL DOWN, YOU

SEE THE SECOND PARAGRAPH FROM THE BOTTOM?

A YES.

Q QUOTE, "ONCE MARIA IS CONFRONTED WITH THE BOARD

OF INVESTIGATION FINDINGS, SHE WILL BE TOLD THAT THE

HOUSING IS GOING TO MOVE UNDER NARCONON."


A YES.

Q ALL RIGHT.

SO NARCONON INTERNATIONAL WAS AWARE OF THE FACT

THAT MARY INTENDED TO MOVE HOUSING UNDER NARCONON AFTER

MARIA IS CONFRONTED WITH THE BOARD OF INVESTIGATION

FINDINGS?

A THAT THAT WAS THE INTENTION TO ACCOMPLISH THAT

AT SOME POINT, YES.

Q OKAY.

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EXHIBIT 18.

THIS IS ALSO BEFORE PATRICK DESMOND'S DEATH.

THIS IS AN E-MAIL, AGAIN, TO NARCONON INTERNATIONAL

WHERE MARY IS TALKING ABOUT THE INTENSIVE INTERVIEWS AND

INVESTIGATION THAT SHE HAD DONE AT NARCONON OF GEORGIA

AND AT HOUSING, AND NARCONON INTERNATIONAL CERTAINLY WAS

AWARE OF THAT, RIGHT, PRIOR TO PATRICK'S DEATH?

A YES.

Q AND WHAT MARY --

A YEAH. IT STATES THAT IT'S CC'D HERE. I

BELIEVE -- IT'S FROM ISAAC OR FROM MARY TO EASTERN US,

ISAAC AT EASTERN US AND --

Q IS THIS ANOTHER CC THAT DIDN'T MAKE ITS WAY

THROUGH, IS THAT WHAT YOU'RE TELLING ME?

A NO, I DON'T BELIEVE THAT'S TRUE. I BELIEVE

THIS, YOU KNOW, THIS DIRECT E-MAIL -- IT'S NOT JUST

PRINTED ON SOME COPY. IT'S ACTUALLY IN AN E-MAIL -- I

BELIEVE THIS WAS SEEN, YES.

Q ALL RIGHT.

BUT THIS, YES OR NO, DID NARCONON INTERNATIONAL

HAVE THIS DOCUMENT, EXHIBIT 18, PRIOR TO PATRICK

DESMOND'S DEATH?

A TO MY KNOWLEDGE, YES.

Q AND THEN THE OTHER THING THAT MARY SAYS IN THIS

DOCUMENT, LOOK AT BATES 1035.

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A UH-HUH.

Q SHE SAYS, QUOTE, "IT IS ONLY ON A BYPASS THAT I

DIVE INTO HOUSING."

A WHERE IS THAT?

Q DOWN AT THE, 1035 DOWN AT THE BOTTOM.

A UH-HUH.

Q IT'S FOUR LINES UP.

A OH. YES. I SEE THERE, UH-HUH.

Q OKAY?

A UH-HUH.

Q SO MARY WAS TELLING INTERNATIONAL THAT SHE WAS

GOING TO CONFRONT MARIA WITH THE FINDINGS AND THEN SHE

WAS GOING TO DIVE INTO HOUSING?

A WELL, SHE WROTE THIS TO ISAAC AT EASTERN US AND

AMONGST OTHER STATEMENTS OF TALKING ABOUT SOLVING THIS

PROBLEM SHE TALKS ABOUT, YEAH, SHE WRITES THAT SENTENCE.

Q SO THE ANSWER IS YES?

A WELL, IT'S YES THAT SHE WROTE THAT SENTENCE.

WHAT IT MEANS, WE WOULD HAVE TO ASK, WE'D HAVE TO ASK

MARY WHAT DOES THAT SPECIFICALLY MEAN.

Q WELL, NARCONON INTERNATIONAL, BEFORE PATRICK'S

DEATH, WAS AWARE OF THE FACT THAT MISS RIESER WAS

TELLING INTERNATIONAL THAT SHE WAS GOING TO CONFRONT

MARIA WITH THE FINDINGS THAT HOUSING WOULD GO UNDER

NARCONON AND THEN SHE ALSO SAYS SHE'S GOING TO DO THAT

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ON A BYPASS.

MS. RICHARDSON: OBJECT TO FORM.

MR. ROOT: SAME.

THE WITNESS: WELL, SHE MAKES A NUMBER OF

STATEMENTS HERE AND INDICATES THAT -- I UNDERSTAND WHAT

THIS SENTENCE IS SAYING THAT SHE IS GOING TO DIRECTLY

DEAL, YOU KNOW, WITH THIS ISSUE WHICH WOULD BE

APPROPRIATE FOR HER TO DO IN TERMS OF NOT THAT SHE CAN

RUN THE HOUSING BUT THAT IT IS AN ISSUE THAT

INTERRELATES WITH THE STUDENTS IN HER PROGRAM, YOU KNOW,

SO IT'S SOMETHING THAT SHE WOULD BE CONCERNED ABOUT AND

WANT TO TAKE UP. I UNDERSTAND.


AND I UNDERSTAND THAT THERE ARE OTHER TOPICS

DISCUSSED IN THE E-MAIL BUT I WAS ASKING YOU ABOUT A

SPECIFIC PORTION OF IT.

A WELL, I SEE WHAT SHE'S WRITTEN.

Q OKAY.

A UH-HUH.

Q AND NARCONON INTERNATIONAL HAD THIS E-MAIL

BEFORE PATRICK DESMOND'S DEATH, RIGHT?

A YES, UH-HUH.

Q NOW, ONE OF THE OTHER TOPICS THAT YOU'RE

SUPPOSED TO BE HERE TO TALK ABOUT IS ISSUES RELATED TO

LICENSING.

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A

Q

A

Q

UH-HUH.

AND NARCONON OF GEORGIA'S LICENSES WITH THE

UH-HUH.

NARCONON OF GEORGIA HAD ORIGINALLY OPERATED

6 SOMETHING THAT THEY CALLED THE FARM, CORRECT?

10:54:05 7 A YES. IT WAS ACTUALLY A SEPARATE INSTITUTION

8 THAT WAS HER FIRST MOVE, FIRST LICENSE WITH NARCONON WAS

9 A SMALL INPATIENT CENTER CALLED THE FARM.

10:54:14 10

10:54:17 11

Q

A

IT WAS AN INPATIENT CENTER?

TO MY KNOWLEDGE, IT WAS A RESIDENTIAL CENTER.

12 WHETHER IT -- WHETHER THE FACILITIES WERE DIRECTLY

13 THERE, I KNOW IT DEALT WITH INMATE RELEASE.

WELL, WAS IT LICENSED BY INTERNATIONAL TO --10:54:26 14

10:54:29 15

10:54:32 16

Q

A

Q

I BELIEVE THAT CENTER WAS A RESIDENTIAL CENTER.

DO YOU REMEMBER WHAT THE NAME -- I DON'T

17 BELIEVE IT WAS CALLED NARCONON OF GEORGIA. IT WAS

18 CALLED SOMETHING ELSE. NARCONON OF THE SOUTH, MAYBE; IS

19 THAT RIGHT?

10:54:40 20 A THAT MIGHT BE CORRECT, YES. IT ONLY OPERATED

21 FOR A SHORT PERIOD OF TIME.

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Q RIGHT.

THE REASON IT ONLY OPERATED FOR A SHORT PERIOD

OF TIME IS BECAUSE IT WAS ILLEGALLY OPERATING AND THE

DHR SHUT IT DOWN, RIGHT?

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A I DON'T RECALL THAT.


MS. RICHARDSON: OBJECT.

THE WITNESS: I DON'T RECALL THAT.

Q BY MR. HARRIS: WELL, YOU DON'T RECALL THE FACT

THAT THE FARM WAS BEING OPERATED AS A RESIDENTIAL

FACILITY WITHOUT A DHR LICENSE FOR A RESIDENTIAL

FACILITY?

A I KNOW THEY HAD A LICENSE FROM US. WHAT, YOU

KNOW, WHAT WERE MARY'S CIRCUMSTANCES WITH THE LICENSE IN

THE STATE WITH THAT I DON'T RECALL. I KNOW THAT IT WAS

A VERY POPULAR THING BUT THAT IT -- THAT SHE WOUND THAT

DOWN AND WORKED WITH THE STATE AND THEN OPENED UP

SEPARATELY AN OUTPATIENT CENTER IN OTHER, IN OTHER

QUARTERS.

Q WHEN SO DO YOU KNOW ANYTHING ABOUT THE

CIRCUMSTANCES OF WHY THE FARM WAS SHUT DOWN?

A NO.

Q DO YOU KNOW WHETHER OR NOT NARCONON

INTERNATIONAL PROVIDED A LICENSE TO -- I THINK AT THAT

POINT IN TIME WHAT BECAME NARCONON OF GEORGIA WAS AT

THAT POINT IN TIME CALLED NARCONON OF THE SOUTH -- DO

YOU KNOW WHETHER OR NOT THAT LICENSE BETWEEN

INTERNATIONAL AND NARCONON OF THE SOUTH WAS FOR A

RESIDENTIAL FACILITY?

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A NO.


THE WITNESS: I DON'T. I DON'T RECALL ON THAT. I

BELIEVE IT WAS A SMALL RESIDENTIAL FACILITY.

Q BY MR. HARRIS: BUT YOU DON'T RECALL WHAT

NARCONON INTERNATIONAL LICENSED IT AS?

A IT WOULD HAVE BEEN LICENSED AS A RESIDENTIAL

FACILITY. THAT'S WHAT IT WAS. WE CLEARLY UNDERSTOOD

WHEN SHE CHANGED HER LICENSE THAT IT WAS AN OUTPATIENT

LICENSE. THIS FIRST ONE, I UNDERSTOOD, AS I SAY IT, SHE

WAS DOING IT IN ASSOCIATION WITH ANOTHER GROUP CALLED

THE FARM. SO WHETHER THERE WAS A SEPARATE GROUP THAT

HAD THAT RESIDENCE OR NOT, I BELIEVED SHE WAS LICENSED

AS A RESIDENTIAL FACILITY, BUT I'M NOT SURE ON THAT

FIRST ONE WHICH IS ABOUT TEN YEARS AGO AS I BELIEVE.

Q ALL RIGHT.

IF NARCONON OF GEORGIA WAS OPERATING A

RESIDENTIAL FACILITY UNDER GEORGIA'S DHR REGULATIONS

THAT WOULD BE ILLEGAL, CORRECT?

MS. RICHARDSON: OBJECT TO THE FORM.


THE WITNESS: I DON'T UNDERSTAND THE QUESTION. CAN

YOU REPEAT IT?

Q BY MR. HARRIS: ARE YOU, DO YOU HAVE ANY

INFORMATION RELATED TO NARCONON OF GEORGIA'S LICENSURE

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AS AN OUTPATIENT AMBULATORY DETOXIFICATION AND/OR

RESIDENTIAL FACILITY WHICH IS --

A WE UNDERSTOOD THAT THEY WERE, IN FACT, LICENSED

AS AN OUTPATIENT FACILITY.

Q OKAY.

SO NARCONON INTERNATIONAL UNDERSTOOD THAT

NARCONON OF GEORGIA WAS LICENSED AS AN OUTPATIENT

FACILITY?

A YES. THAT WAS OUR TRADEMARK LICENSE WITH THEM

AND THAT'S WHAT WE UNDERSTAND THEY WERE ALSO LICENSED AS

IN GEORGIA.

Q AND IT WOULD BE ILLEGAL IF NARCONON OF GEORGIA

WAS OPERATING A RESIDENTIAL FACILITY UNDER GEORGIA'S DHR

REGIME?



THE WITNESS: I PRESUME THAT WOULD BE THE CASE.

Q BY MR. HARRIS: WELL, DO YOU KNOW AS A

REPRESENTATIVE OF NARCONON INTERNATIONAL?

A WELL, THAT'S BETWEEN THE STATE OF GEORGIA AND

MARY'S CENTER. WE LICENSED HER CENTER AS AN OUTPATIENT.

WE UNDERSTOOD, AND I BELIEVE THERE ARE DOCUMENTS SHOWING

THAT THAT'S WHAT, YOU KNOW, SHE WAS LICENSED AS SO

IT'S -- SHE WAS NOT OPERATING A RESIDENTIAL CENTER. SHE

WAS OPERATING AN OUTPATIENT CENTER.

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Q OKAY.

SO NARCONON INTERNATIONAL CLEARLY KNOWS THAT

SHE DOESN'T HAVE A LICENSE, SHE BEING MARY, DOES NOT

HAVE A LICENSE TO OPERATE ANY KIND OF RESIDENTIAL

FACILITY; FAIR?

A SHE NEVER APPLIED FOR SUCH A LICENSE NOR DID WE

LICENSE HER.

Q IS THAT WHAT I ASKED YOU?

A WELL, I DON'T UNDERSTAND THE QUESTION. IT'S

SPECULATING ABOUT SOMETHING ELSE THAT SHE DIDN'T DO AND

SO I ACTUALLY DON'T UNDERSTAND THE QUESTION.

Q AT THE TIME IN 2008 AT THE TIME OF PATRICK

DESMOND'S DEATH

A UH-HUH.

Q -- NARCONON INTERNATIONAL WAS AWARE OF THE FACT

THAT NARCONON OF GEORGIA ONLY HAD AN OUTPATIENT LICENSE

FOR DHR?

A EXACTLY. EXACTLY. THAT IS TRUE.

Q NARCONON INTERNATIONAL ACTUALLY HAD A COPY OF

THE LICENSE IN ITS FILES?

A I BELIEVE SO.

Q ALL RIGHT.

IS THAT COMMON PRACTICE FOR YOUR CENTERS, THE

INDIVIDUAL CENTERS TO ACTUALLY FORWARD THEIR LICENSE TO

INTERNATIONAL?

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A I BELIEVE IT IS A COMMON PRACTICE; THAT WE, WE

WANT TO KNOW -- IT'S PART OF THE COMPLIANCE THAT WE WANT

TO HAVE THE FACT OF THE LICENSURE.

Q ALL RIGHT.

A SO IT'S NOT A MATTER OF OPINION.

Q WHEN YOU SAY IT'S PART OF THE COMPLIANCE, WHAT

DO YOU MEAN BY THAT?

A IN THE LEGAL RUDIMENTS INSPECTION WE'RE LOOKING

TO SEE DO ALL OF THESE DOCUMENTS EXIST.

Q SO ONE OF THE THINGS THAT NARCONON

INTERNATIONAL DOES IS IT MAKES SURE THAT THE INDIVIDUAL

CENTERS HAVE THE APPROPRIATE LICENSE FOR DOING WHATEVER

IT IS THEY'RE DOING?

A IT MAKES SURE THAT THEY FOLLOW, CONTINUE THOSE

PROCEDURES TO GET TO THAT POINT WHERE THAT OCCURS. IT'S

THEIR RESPONSIBILITY TO DO. WE'RE INTERESTED IN KNOWING

IT WAS DONE.

Q OKAY.

WHETHER IT'S THEIR RESPONSIBILITY OR NOT IS A

DIFFERENT QUESTION FROM WHAT I ASKED YOU.

A OKAY.

Q AS PART OF NARCONON INTERNATIONAL'S LEGAL

RUDIMENTS CHECKLIST

A UH-HUH.

Q -- NARCONON INTERNATIONAL DETERMINES WHETHER OR

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NOT THE INDIVIDUAL CENTERS HAVE THE APPROPRIATE LICENSE

FOR DOING WHATEVER IT IS THEY'RE HOLDING THEMSELVES OUT

TO DO?

A YEAH. WHAT I UNDERSTAND IS DONE IS THAT THE,

WHEN WE GO -- WE'RE LOOKING AT THE CENTER'S RECORDS AND

WE LOOK AT THE DOCUMENTS AND THEN WE DETERMINE TO THE

BEST OF OUR ABILITY ARE THEY IN, YOU KNOW, ARE THESE

SHOWING THAT THEY'RE IN COMPLIANCE.

Q AND HOW DO YOU DO THAT?

A WELL, I PERSONALLY AM NOT FULLY SKILLED IN THIS

BUT THIS IS WHY WE HAVE A LEGAL DEPARTMENT AND THAT THEY

WOULD LOOK AND BEING FAMILIAR WITH THIS WOULD DETERMINE

PER THE REGULATIONS THAT EXIST ARE ALL OF THE THINGS IN

THAT NEED TO BE IN. IT'S THE RESPONSIBILITY OF THE

CENTER TO DO AND THIS IS SIMPLY A MONITORING IT AS IT

STATES IN OUR TRADEMARK LICENSE, MONITORING THEIR

COMPLIANCE WITH LOCAL LAWS. WE CAN'T ENFORCE IT.

THAT'S THEIR RESPONSIBILITY. WE CAN MONITOR IS THIS,

ARE THEY IN FACT IN COMPLIANCE.

AS YOU UNDERSTAND, WE DON'T JUST HAVE CENTERS

IN GEORGIA. WE HAVE CENTERS AROUND THE WORLD. SO

SOMETIMES IT'S EASIER AND SOMETIMES IT'S HARDER TO

DETERMINE THIS.

Q ALL RIGHT.

TOPIC NO. 39, NARCONON OF GEORGIA'S COMPLIANCE

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OR NONCOMPLIANCE WITH GEORGIA'S REQUIREMENTS FOR

OPERATING A DRUG AND ALCOHOL TREATMENT FACILITY.

A UH-HUH.

Q WHAT HAVE YOU DONE TO EDUCATE YOURSELF ON TOPIC

NO. 39?

A I LOOKED AT THE DOCUMENTS THAT CLAUDIA HAD IN

HER FILES, THAT OUR DIRECTOR OF LEGAL AFFAIRS HAD IN HER

FILES WITH REGARD TO THIS.

Q EARLIER YOU RESPONDED TO ONE OF MY QUESTIONS BY

SAYING THAT YOU PERSONALLY WERE NOT SKILLED IN THIS

PARTICULAR AREA.

A YEAH. SO I'M DIFFERENTIATING MYSELF FROM

SPEAKING AS THIS CORPORATE ENTITY WHO KNOWS ALL THAT

YOU'RE SUPPOSED TO KNOW ALL.

Q AND I'M ASKING YOU A QUESTION AS THE PERSON WHO

IS THE CORPORATE, REPRESENTING THE CORPORATE ENTITY.

OKAY?

A UH-HUH.

Q NARCONON INTERNATIONAL HAS A LEGAL DEPARTMENT,

CORRECT?

A UH-HUH. YES.

Q AND ONE OF THE THINGS THAT NARCONON

INTERNATIONAL'S LEGAL DEPARTMENT DOES IS LOOK AT THE

LICENSE OF INDIVIDUAL CENTERS TO DETERMINE WHETHER OR

NOT THE APPROPRIATE LICENSE IS HELD BY THOSE CENTERS FOR

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DOING WHATEVER THE CENTER IS HOLDING ITSELF OUT TO THE

PUBLIC AS DOING?

A THERE THE CENTERS ARE RESPONSIBLE TO REPORT

THIS TO US AND THEY LOOK AT THE -- THEY LOOK AT ALL OF

THE DATA AND THEN DETERMINE TO THE BEST OF THEIR ABILITY

IS THE CENTER IN COMPLIANCE. IT'S A REVIEW PROCEDURE.

IT'S NOT DOING THE PROCEDURE. IT'S A REVIEW PROCEDURE

OF WHAT THE CENTER ITSELF IS DOING.

Q OKAY.

BUT NARCONON INTERNATIONAL ENDEAVORS TO

DETERMINE WHETHER OR NOT THE LICENSE IS APPROPRIATE FOR

WHATEVER THE CENTER IS DOING?

A EXACTLY.

Q AND THAT'S DONE PURSUANT TO YOUR LICENSE

AGREEMENT?

A YES.

Q AND I THINK YOU TOLD ME THAT YOU, "YOU" BEING

NARCONON INTERNATIONAL, TO THE BEST OF ITS ABILITY,

DETERMINES WHETHER OR NOT THE LICENSE IS APPROPRIATE?

A YES.

Q DOES THE, DOES NARCONON INTERNATIONAL ACTUALLY

LOOK AT OR PULL THE DHR REGULATIONS OR WHATEVER THE

COMPARATOR IS FOR OTHER STATES AND LOOK AT THOSE TO

DETERMINE WHETHER OR NOT THE FACILITY IS COMPLYING WITH

THE REGULATIONS OF THAT STATE?

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A IN THIS CASE I DO KNOW THAT WE HAD A COPY OF

THE DHR REGULATIONS RELATIVE TO AN OUTPATIENT FACILITY.

Q SO IN THIS CASE, THIS CASE BEING NARCONON OF

GEORGIA, NARCONON INTERNATIONAL ACTUALLY HAD A COPY OF

THE DHR REGULATIONS?

A YES.

Q AND LOOKED AT THOSE REGULATIONS TO DETERMINE

WHETHER OR NOT NARCONON OF GEORGIA WAS ACTING IN

CONFORMITY WITH WHATEVER THE DHR REGS WERE?

A YES.

Q WAS IT?

A YES. IT WAS OPERATING AS AN OUTPATIENT AND

LICENSED AS AN OUTPATIENT.

Q EVEN THOUGH ONE OF THE EARLIER E-MAILS THAT YOU

AND I DISCUSSED TALKS ABOUT THE FACT THAT MARY IS

INTENDING TO DIVE INTO HOUSING ON A BYPASS?

A THAT DOES NOT MEAN THAT SHE'S INTENDING TO OPEN

AN INPATIENT FACILITY. IT MEANS THAT SHE'S ADDRESSING

THE ISSUE OF THE HOUSING OF HER STUDENTS. THAT'S ALL

THAT IT MEANS. IN OTHER WORDS, THE SENTENCE MEANS THE

SAME THING TO ME THAT IT WOULD MEAN TO YOU. SHE'S GOING

TO LOOK INTO IT.

Q WHAT DOES "BYPASS" MEAN?


MS. RICHARDSON: I'LL OBJECT TO IT, AS WELL.

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Q BY MR. HARRIS: I MEAN, I'M ASKING YOU, IS IT

SOME TERM OF ART, FRANKLY, BECAUSE I'VE SEEN IT USED IN

A BUNCH OF THESE DOCUMENTS AND I DON'T KNOW WHETHER IT

HAS SOME TERM, YOU ALL HAVE SOME TERM OF ART FOR BYPASS

THAT'S DIFFERENT THAN THE COMMON

A POSSIBLY. POSSIBLY. HERE I THINK IT, HERE I

THINK IT, IT HAS THE COMMON ENGLISH MEANING THAT THERE'S

SOMEONE ELSE WHO IS RESPONSIBLE FOR DOING SOMETHING, THE

HEAD OF HOUSING, AND THAT SHE IS WANTING TO LOOK INTO

ISSUES OF HOUSING BECAUSE IT'S AFFECTING THE STUDENTS

THAT ARE IN HER PROGRAM AND THIS COULD INVOLVE CHANGING

THE HOUSING TO WORK WITH A DIFFERENT ENTITY. YOU KNOW,

SHE'S RESPONSIBLE FOR HER STUDENTS. IT'S NOT, IT WOULD

NOT BE INAPPROPRIATE FOR HER TO BE -- TO WONDER WHAT'S

GOING ON WITH HOUSING AND TO LOOK INTO IT DIRECTLY.

Q AND I DON'T THINK I'M DISAGREEING WITH YOU. I

WAS ASKING A DIFFERENT QUESTION.

WHAT DID NARCONON INTERNATIONAL, WHAT DID IT

THINK MARY RIESER WAS DOING WHEN SHE SAID "IT IS ONLY ON

A BYPASS THAT I DIVE INTO HOUSING"?


THE WITNESS: THAT SHE WAS CONSIDERING CHANGING

HOUSING, IMPROVING, YOU KNOW, RELATIONS WITH THE

HOUSING. HER ENROLLMENT AND HER -- WAS THAT SHE WAS NOT

RUNNING HOUSING HERSELF, SO SHE HAD -- THIS IS WHY SHE'S

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HAVING TO REACH, YOU KNOW, SHE'S HAVING -- BUT BECAUSE

HER STUDENTS ARE, IN FACT, LIVING ELSEWHERE AND THERE

ARE PROBLEMS THERE, SHE'S HAVING TO LOOK INTO IT. SHE

WOULD BE SOMEWHAT CONSTRAINED IN TERMS OF WHAT SHE COULD

LEGALLY DO BUT WHAT SHE COULD CERTAINLY DO IS IF THERE

IS ONE LARGE FACILITY SHE COULD CHANGE TO ANOTHER IF

THEY WOULD BE ABLE TO AND RECOMMEND ANOTHER IF THEY

WOULD BE ABLE TO PROVIDE BETTER SERVICE.

SO THERE'S LOOKING INTO IT AND ONE DOING

SOMETHING ABOUT IT IS APPROPRIATE. IT DOES NOT

MEAN -- OR SHE COULD EVENTUALLY APPLY FOR A RESIDENTIAL

LICENSE AND FIND ANOTHER FACILITY WHERE THEY WOULD ALL

LIVE TOGETHER IN ONE PLACE. BUT, YOU KNOW, THAT WOULD

REQUIRE A MOVING OF BOTH ENTITIES.

Q BY MR. HARRIS: IN EXHIBIT NO. 9 WHEN MISS

RIESER IS INFORMING INTERNATIONAL THAT ONCE SHE

CONFRONTS MARIA WITH THE BOARD OF INVESTIGATION FINDINGS

THAT SHE'S GOING TO TELL MARIA THAT HOUSING IS GOING TO

MOVE UNDER NARCONON

A UH-HUH.

Q -- IF, IN FACT, MISS RIESER MOVED HOUSING UNDER

NARCONON, THAT WOULD VIOLATE THE TERMS OF THE DHR

LICENSE THAT YOU AND I HAVE BEEN DISCUSSING, WOULDN'T

IT?

A NO.

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Q REALLY?

A ONLY, YOU KNOW, IF SHE WERE TO OPEN A

RESIDENTIAL FACILITY SHE WOULD THEN NEED TO APPLY FOR

IT. SHE WOULD HAVE TO HAVE SEPARATE, SHE WOULD HAVE TO

HAVE ONE PLACE IF THAT'S WHAT SHE WAS GOING TO DO AND SO

IF THAT WOULD -- I DON'T KNOW IF MARIA WAS LOOKING FOR A

RESIDENTIAL FACILITY AT THAT TIME. I BELIEVE RATHER

CONTINUOUSLY SHE'S BEEN HOPING TO FIND A RESIDENTIAL

FACILITY WHERE IT ALL COULD BE IN ONE, IN ONE PLACE

BECAUSE THAT'S HOW WE RUN RESIDENTIAL FACILITIES. SO

WHAT SHE SPECIFICALLY MEANT BY "UNDER NARCONON" I DON'T

KNOW. YOU WOULD HAVE TO ASK HER. I COULD SEE HER

WANTING TO TAKE FURTHER RESPONSIBILITY FOR IT, YOU KNOW.

IT WOULD HAVE TO BE DONE ACCORDING TO THE LAWS OF THE

STATE, OF COURSE.

Q RIGHT.

AND I CAN ASK HER AND HAVE, BUT I'M TALKING

ABOUT NARCONON INTERNATIONAL'S INVOLVEMENT HERE. YOU'VE

ALREADY TOLD ME THAT ONE OF THE LEGAL RUDIMENTS THAT ARE

LOOKED INTO IS WHETHER OR NOT THE CENTERS ARE WORKING IN

COMPLIANCE WITH THEIR DHR LICENSE.

A RIGHT.

Q AGREED?

A UH-HUH.

Q AND MARY IS TELLING OR SAYING IN THIS E-MAIL

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THAT SHE'S PLANNING ON CONFRONTING MARIA AND THAT THE

HOUSING IS GOING TO MOVE UNDER NARCONON. DID NARCONON

INTERNATIONAL DO ANYTHING TO LOOK INTO WHETHER THAT WAS

THE CASE AND WHETHER THAT MIGHT VIOLATE THE GEORGIA DHR

LICENSE?

A NO, WE DID NOT UNDERSTAND THAT SHE WAS GOING TO

BE RUNNING THE HOUSING AS PART OF HER CORPORATION. WE

UNDERSTOOD THAT SHE WAS GOING TO BE LOOKING FOR AN

IMPROVED HOUSING CIRCUMSTANCE FOR THE STUDENTS.

Q EXHIBIT NO. 16.

A IN OTHER WORDS, CONTINUE TO BE OUTPATIENT.

Q EXHIBIT NO. 16.

A UH-HUH. UH-HUH.

Q IS THIS YOUR HANDWRITING?

A NO. THIS IS ACTUALLY WRITTEN BY MY ASSISTANT

ON MY BEHALF.

Q WERE YOU DICTATING IT OR SOMETHING?

A NO. I THINK I ASKED HER -- IT'S -- THE

SUBSTANCE OF IT IS THE LAST SENTENCE, "PLEASE GET THE

GOVERNMENT DOCUMENTATION THAT GRANTS THE LICENSE."

THIS WAS ONE OF THE THINGS I LIKE TO HAVE FOR

MY OFFICE IS ACTUAL DOCUMENTATION OF CERTAIN THINGS, AND

THERE WAS THERE HAD BEEN CONTINUING NEGOTIATIONS

BETWEEN MARY RIESER AND THE DEPARTMENT OF HEALTH

REGARDING THE SAUNA FACILITY, I BELIEVE, SO I WAS

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INTERESTED IN -- SOMETHING HAD BEEN FINALLY WORKED OUT

ON THAT AND I WANTED THE NEW, THE NEW DOCUMENTATION.

Q WELL, THIS IS ALL, THIS DOCUMENT THAT I'VE

HANDED YOU IS RIGHT IN THE SAME TIME FRAME WHERE THIS

DISCUSSION IS GOING ON ABOUT THE BOARD OF INVESTIGATION,

RIGHT?

A UH-HUH.

Q AND YOU'RE WRITING SOMETHING HERE THAT SAYS, IT

SAYS "RUSH." WE "REALLY NEED THIS. NARCONON OF GEORGIA

GETS ITS STATE LICENSE ON MAY 4TH, 2007."

WHY WERE YOU INTERESTED IN THIS ISSUE AND WHAT

WAS IT THAT YOU BELIEVED WAS A RUSH?

A I DON'T KNOW. AT THE TIME I BELIEVE -- THERE

ARE TIMES WHERE SOMEONE ASKS ME FOR DOCUMENTS, YOU KNOW,

WHERE SOMEONE ELSE IS SAYING WHAT LICENSES DO YOU HAVE

OR DO NARCONONS HAVE. SO I WAS MISSING THE EARLIER, THE

EARLIER DOCUMENTATION AND I -- MY ASSISTANT SIMPLY ASKED

THE DIRECTOR OF LEGAL AFFAIRS FOR THAT DOCUMENTATION

THAT ALREADY EXISTED. THAT'S ALL THIS IS ABOUT.

Q IS THIS SOMETHING YOU TYPICALLY GET INTO AS THE

PRESIDENT OF NARCONON, THE LICENSING OF INDIVIDUAL

CENTERS?

A NO.

Q I THINK YOU TOLD ME EARLIER YOU WERE OUTWARD

FACING.

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A YES. PEOPLE WILL AT TIMES ASK ME SO WHAT

CENTERS ARE LICENSED, WHAT ACCREDITATIONS DO YOU HAVE,

CERTIFICATIONS AND SO FORTH, SO I LIKE TO HAVE SPECIFIC

DOCUMENTS.

Q WELL, WHAT PRECIPITATED THIS DOCUMENT, EXHIBIT

16? WHY ARE YOU IN A RUSH ON MARCH THE 17TH OF 2008 TO

FIGURE OUT WHAT'S GOING ON WITH THE LICENSE OF AN

INDIVIDUAL CENTER LOCATED DOWN IN GEORGIA?

A WELL, I BELIEVE WE WERE GOING TO HAVE AN

EXECUTIVE DIRECTORS CONFERENCE COMING UP AND I WANTED TO

BE ABLE TO PRESENT VARIOUS, FOR THE YEAR BEFORE, VARIOUS

DOCUMENTS, YOU KNOW, LICENSES AND ACCREDITATIONS THAT

HAD BEEN HAPPENING AROUND THE WORLD AND THIS IS ONE OF

THEM, SO I SIMPLY WANTED THE DOCUMENT.

Q THAT'S THE REASON YOU DRAFTED EXHIBIT NO. 16?

A MY ASSISTANT, YEAH. I SIMPLY WANTED, WANTED

THE DOCUMENT. I DON'T LIKE -- IF -- I DON'T LIKE TO SAY

SOMETHING IS SOMETHING UNLESS I HAVE THE DOCUMENT FOR

IT, SO THAT'S WHAT I BELIEVE THIS WAS FOR. IT WAS

SLIGHTLY BEFORE WE HAVE OUR EXECUTIVE DIRECTORS

CONFERENCE.

2008?

Q WHEN WAS THE EXECUTIVE DIRECTORS CONFERENCE IN

A IT WOULD HAVE BEEN IN EARLY APRIL.

Q WHERE WAS IT?

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A I DON'T KNOW FOR THAT YEAR.

Q YOU VIDEOTAPE THOSE, A LOT OF THOSE

CONFERENCES, DON'T YOU?

A NOT THE WHOLE CONFERENCES. WE --

Q YOU VIDEOTAPE A LARGE PORTION OF IT AND PUT IT

TOGETHER ON CD'S THAT ARE DISTRIBUTED?

A NOT A LARGE POSITION OF IT. THERE MAY

BE -- THERE MAY BE -- WE USUALLY TAKE IT'S A

FRIENDLY, FRIENDLY GATHERING AND WE TAKE PICTURES OF ONE

ANOTHER AND THERE ARE AWARDS THAT ARE GIVEN AND WE

DISCUSS ISSUES AND THERE'S SOME, YOU KNOW, TRAINING

SEMINARS. SO AS PART OF MY PRESENTATION OF WHAT

HAPPENED WITH NARCONON AROUND THE WORLD I MAY HAVE

WANTED THIS DOCUMENT.

Q SO YOU WRITE THIS LETTER ON MARCH THE 17TH,

2008 AND IN IT YOU'RE TELLING THE DIRECTOR OF LEGAL

AFFAIRS RUSH. WE REALLY NEED THIS. NARCONON OF GEORGIA

GETS ITS STATE LICENSE ON MAY 4TH, 2007. THERE'S AN

INSPECTION IN APRIL OF 2007 WHERE THERE ARE DEFICIENCIES

CITED. AND THEN YOU REFER TO HEARING DOCUMENTS RELATED

TO THE STATE OF GEORGIA GRANTING NARCONON A CERTAIN KIND

OF LICENSE. AND THEN YOU'RE TELLING ME THAT THIS

DOCUMENT WAS GENERATED BECAUSE YOU WERE PLANNING ON

DISCUSSING THAT AT THE EXECUTIVE DIRECTORS CONFERENCE?

A NO. IT'S THAT THERE WERE THESE OTHER ISSUES

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AND I WANTED TO SEE THE DOCUMENT THAT SHOWS THAT THIS

WAS, YOU KNOW, FINALLY HANDLED. THERE'S THE -- WE HAD

HEARD THE THING AND SO IT'S IMPORTANT TO HAVE THIS FINAL

THING. I DON'T REMEMBER EXACTLY BUT THAT'S WHAT I

CAN -- THAT'S WHAT I BELIEVE. IN OTHER WORDS, IT'S NOT

INCORRECT THAT I WOULD WANT TO SEE A DOCUMENT.

Q THERE'S

A IT'S PART OF MY FILES.

Q OKAY.

BUT YOU

A THIS WOULD HAVE BEEN SOMETHING THAT WOULD HAVE

BEEN DONE IN THE LAST YEAR, SO IT WOULD HAVE BEEN

SOMETHING, YOU KNOW, DEVELOPED IN THE LAST YEAR, A

CERTIFICATION OR LICENSING.

Q WHAT WERE YOU PLANNING ON DOING AT THE

EXECUTIVE DIRECTORS CONFERENCE RELATED TO NARCONON OF

GEORGIA THAT WOULD REQUIRE THAT YOU GET THE INFORMATION

THAT YOU'VE REQUESTED HERE IN EXHIBIT 16?

A OH. HERE'S A LICENSE THAT WAS GRANTED OR

HERE'S A CERTIFICATION. IN OTHER WORDS, THEY'RE FACTUAL

DOCUMENTATION OF VARIOUS ACCOMPLISHMENTS BY DIFFERENT

NARCONONS THROUGHOUT THE, YOU KNOW, THROUGHOUT THE YEAR.

THAT'S ALL.

Q IT DIDN'T HAVE ANYTHING TO DO WITH THE BOARD OF

INVESTIGATION THAT WAS ONGOING AT THAT EXACT SAME TIME?

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A NOT TO MY KNOWLEDGE. I'M INTERESTED IN JUST

THE FINAL DOCUMENT WHICH HAS TO DO WITH THE -- THIS,

BECAUSE THIS HAS TO DO WITH THE EARLIER YEAR, YOU KNOW,

2007.

Q DID YOU DO THAT WITH THE OTHER 57 OR SO

RESIDENTIAL FACILITIES, DID YOU GENERATE A HANDWRITTEN

DOCUMENT ASKING ABOUT THE STATUS OF THEIR LICENSE PRIOR

TO THE EXECUTIVE DIRECTORS CONFERENCE?

A NO. I WOULD HAVE HAD IN MY, IN MY, YOU KNOW,

IN MY FILES THESE ARE THINGS THAT WERE DONE IN THE LAST

YEAR AND THIS WAS ONE THAT I DIDN'T HAVE THIS DOCUMENT

SO THIS WAS TO GET THIS DOCUMENT.

Q SO DID YOU GO THROUGH THE FILES OF EACH ONE OF

THE OTHER FACILITIES PRIOR TO THE EXECUTIVE DIRECTORS

CONFERENCE AND DETERMINE WHETHER OR NOT THERE HAD BEEN

ANY CHANGES IN THEIR LICENSE OR STATUS AND GENERATE A

SIMILAR NOTE TO YOUR ASSISTANT TO GO DIG THAT UP SO

YOU'D BE PREPARED FOR A SPEECH AT THE EXECUTIVE

DIRECTORS CONFERENCE?

A USUALLY ON A REGULAR BASIS THESE COME TO MY

FILES. THIS ONE I DIDN'T HAVE AND SO MY ASSISTANT ASKED

FOR IT AND I'M SURE THAT I JUST SAID TO HER CHERYL, GET

THIS DOCUMENT. SHE WROTE THE DOCUMENT ON MY BEHALF.

Q TELL ME THE NAME OF THE PERSON WHO WROTE THAT.

A CHERYL CRAWFORD.

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Q HOW DO YOU SPELL THAT?

A C-H-E-R-Y-L.

Q CRAWFORD?

A CRAWFORD, C-A-R-W -- I MEAN, C-R-A-W-F-0-R-D,

CRAWFORD.

Q WHERE DID, WHERE DOES SHE WORK? SHE WORK HERE?

A SHE WORKS, SHE'S MY ASSISTANT AT NARCONON

INTERNATIONAL.

Q OKAY.

AFTER PATRICK DESMOND'S DEATH, YOU'VE TOLD ME A

LITTLE BIT ABOUT THE TECH REVIEW THAT WAS ORDERED BY

YARKO.

A UH-HUH.

Q AND THEN THERE WAS ALSO A LEGAL RUDIMENTS

REVIEW.

A UH-HUH.

Q CORRECT?

A UH-HUH.

Q WAS THERE ANY OTHER REVIEW OR SORT OF ANALYSIS

OF THE PROGRAM THAT WAS CONDUCTED BY NARCONON

INTERNATIONAL AFTER PATRICK DIED?

A NO. THOSE ARE THE ONLY TWO THAT I KNOW OF.

Q INVESTIGATION, ANY INVESTIGATION?

A NO.

Q NO INVESTIGATION OF THE CIRCUMSTANCES OF

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PATRICK DESMOND'S DEATH BY NARCONON INTERNATIONAL AFTER

HE DIED?

A NO.

Q HAVE YOU LOOKED AT THE DOCUMENTS THAT HAVE BEEN

PRODUCED IN THIS CASE THAT TALK ABOUT PATRICK'S DEATH

AND

A YES. YES. TO MY KNOWLEDGE, WHAT WE DID IS WE

HAD A TECHNICAL INSPECTION DONE AND WE HAD A LEGAL

RUDIMENTS INSPECTION DONE, AND THEN MARY WAS SENDING

REPORTS WITH REGARD TO OTHER, YOU KNOW, OTHER THINGS

THAT WERE ONGOING AND WE WERE INFORMED BY MARY USUALLY

VIA NARCONON EASTERN US.

Q BEFORE PATRICK DESMOND'S DEATH THERE HAD BEEN

SOME REPORTS TO NARCONON INTERNATIONAL FROM FAMILY

MEMBERS OF STUDENTS THAT NARCONON INTERNATIONAL

WAS -- I'M SORRY. THERE HAD BEEN SOME REPORTS TO

NARCONON INTERNATIONAL THAT NARCONON OF GEORGIA WAS

HOLDING ITSELF OUT AS A RESIDENTIAL FACILITY, CORRECT?

A I BELIEVE THERE WAS ONE PERSON THAT, IT WAS A

REPORT FROM NARCONON SAN DIEGO THAT STATED THIS, IF I'M

NOT MISTAKEN, IT WAS THEIR OPINION THAT THIS WAS THE

CASE.

Q AND IT WOULD BE --

A PERHAPS ANOTHER. I DON'T REMEMBER. BUT I

THINK THERE WERE ONE OR TWO.

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Q ALL RIGHT.

BUT THERE HAD BEEN -- NARCONON INTERNATIONAL

WAS AWARE OF THE FACT THAT AT LEAST SOME PEOPLE WERE

CLAIMING THAT GEORGIA WAS HOLDING ITSELF OUT AS A

RESIDENTIAL FACILITY?


THE WITNESS: WE SAW A REPORT THAT THIS, THAT THIS

HAD OCCURRED, YES, THAT THERE WAS THIS CLAIM.

Q BY MR. HARRIS: WHAT DID NARCONON INTERNATIONAL

DO TO INVESTIGATE WHETHER THAT WAS THE CASE?

A I BELIEVE YARKO ASKED THE OPERATIONS SUPERVISOR

AT NARCONON EASTERN US TO LOOK INTO EACH SPECIFIC

REPORT.

Q ANYTHING ELSE?

A NO.

Q THE CIRCUMSTANCES OF PATRICK DESMOND'S

ENROLLMENT IN NARCONON OF GEORGIA IS ALSO ONE OF THE

TOPICS THAT WE'VE ASKED YOU TO COME TALK TO US ABOUT.

DO YOU KNOW, AS A REPRESENTATIVE OF NARCONON

INTERNATIONAL, HOW PATRICK DESMOND CAME TO BE ENROLLED

IN THE NARCONON OF GEORGIA FACILITY?

A NO. ONLY AFTER THE FACT THAT I'VE SEEN THE

DOCUMENTS. AT THE TIME WE DID NOT KNOW OF PATRICK

DESMOND OR ANYTHING.

Q WELL, DO YOU

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A I'VE SEEN THE, YOU KNOW, THE ENROLLMENT FORM

THAT WAS USED. WE KNEW NOTHING ABOUT MR. DESMOND OR THE

ENROLLMENT PROCEDURE.

Q YOU CERTAINLY KNOW ABOUT IT NOW.

A UH-HUH.

Q AND YOU'RE THE PRESIDENT OF NARCONON

INTERNATIONAL, RIGHT?

A UH-HUH.

Q AND YOU KNOW THAT IN THIS PARTICULAR LAWSUIT

THERE IS A CONTENTION THAT NARCONON OF GEORGIA HELD

ITSELF OUT TO THE FLORIDA DRUG COURTS AS BEING OR AS

OPERATING A RESIDENTIAL FACILITY, RIGHT?

MS. RICHARDSON: OBJECTION TO THE FORM.

THE WITNESS: I HEARD YOU CLAIM THAT.

Q BY MR. HARRIS: YOU'VE HEARD ME CLAIM THAT?

A YES. AT THE --

Q AND YOU'VE ACTUALLY SEEN IT IN THE COMPLAINT,

RIGHT?

A YES.

Q HAVE YOU REVIEWED THE TESTIMONY OF ANY OF THE

FOLKS AT THE FLORIDA DRUG COURT?

A NO.

Q ARE YOU AWARE OF THE FACT THAT THE DHR DID AN

INSPECTION OF NARCONON OF GEORGIA RECENTLY AND

DOCUMENTED A SIMILAR ISSUE?

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THE WITNESS: I UNDERSTAND THERE HAVE BEEN A COUPLE

OF INSPECTIONS, WHICH IS NOT UNUSUAL, FROM THE CENTER.

I'M NOT PRECISELY AWARE OF WHAT, WHAT OCCURRED AT THOSE.

THAT WOULD BE BETWEEN THEM AND THE NARCONON OF GEORGIA.

Q BY MR. HARRIS: WELL, YOU'RE AWARE OF THE FACT

THAT AT LEAST ONCE BEFORE PATRICK DESMOND DIES THAT

SOMEONE IS SAYING NARCONON OF GEORGIA IS OPERATING A

RESIDENTIAL FACILITY. YOU AGREE WITH ME THERE, RIGHT?


THE WITNESS: I KNOW THAT WE RECEIVED A COMPLAINT

TO THAT EFFECT BY SOMEONE AND THAT NARCONON, THAT YARKO

ASKED THAT THAT BE LOOKED INTO BY NARCONON, A STAFF

MEMBER AT NARCONON EASTERN US.

Q BY MR. HARRIS: OKAY.

AND SO YES, NARCONON INTERNATIONAL, BEFORE

PATRICK'S DEATH, IS AWARE OF AT LEAST ONE PERSON,

ACCORDING TO YOUR OWN TESTIMONY, WHO IS CONTENDING THAT;

TRUE?

A YEAH. WHO WROTE A COMPLAINT.

Q AND YOU'RE AWARE OF THE FACT THAT THAT IS A

CONTENTION IN THE DESMOND LAWSUIT, CORRECT?

A YES.

Q YOU'RE AWARE OF THE FACT THAT WE'RE CONTENDING

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IN THIS LAWSUIT THAT NARCONON OF GEORGIA WAS HOLDING

ITSELF OUT AS OPERATING A RESIDENTIAL FACILITY?

A I'M AWARE THAT THAT'S WHAT YOU'RE CONTENDING,

YES.

Q OKAY.

AND YOU, ARE YOU OR ARE YOU NOT AWARE OF THE

MOST RECENT DHR INSPECTION OF NARCONON OF GEORGIA WHERE

A SIMILAR CONTENTION WAS MADE BY THE DHR INSPECTOR?

A NO, I'M NOT AWARE OF THAT.

Q WHY NOT?

A IT WAS -- THEY WERE -- THAT WAS BETWEEN

NARCONON OF GEORGIA AND THEM.

Q WELL, YOU HAVE THE DHR INVESTIGATION OF

NARCONON OF GEORGIA IN 2007. IN FACT, YOU EVEN WROTE A

HANDWRITTEN NOTE ABOUT IT.

A THIS WAS AT A TIME WHEN THERE WERE SEVERAL

THINGS THAT WERE GOING ON AND THEN IT HAD BEEN CONCLUDED

WITH A, SOME KIND OF NEW LICENSING, AND SO I WAS

INTERESTED THERE WITH THIS DOCUMENT BECAUSE THEY WERE

LOOKING AT SOME KIND OF NEW THING WITH REGARD TO AN

UNDERSTANDING OF THE USE OF THE SAUNA.

SO HERE I'M-- NARCONON INTERNATIONAL IS NOT

NECESSARILY INFORMED ABOUT EVERY INSPECTION. OFTEN WHAT

WE'LL GET IS AN INSPECTION HAS OCCURRED, A FEW

DEFICIENCIES WERE OUTLINED, THESE WERE CORRECTED. EVERY

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CENTER IN THE UNITED STATES RECEIVES INSPECTIONS. IT'S

NOT UNUSUAL THAT THEY WOULD HAVE A FEW DEFICIENCIES.

THOSE ARE CORRECTED AND THEN THAT CYCLE IS ENDED, SO

THAT'S

Q I'M NOT TALKING ABOUT OTHER CENTERS. I'M

TALKING ABOUT NARCONON OF GEORGIA. AND YOU UNDERSTAND

THAT THE CONTENTION IN THIS LAWSUIT IS THAT THESE FOLKS

DOWN IN GEORGIA ARE HOLDING THEMSELVES OUT AS A

RESIDENTIAL FACILITY AND DHR HAS COME IN AND RECENTLY

INSPECTED THEM AND SAID THAT THEY CONTINUE TO DO THAT.

A OKAY. I'M --

Q IS THAT SOMETHING THAT INTERNATIONAL IS LOOKING

INTO?



THE WITNESS: I HEAR WHAT YOUR CONTENTION IS AND I,

YOU KNOW, THERE MAY WELL HAVE BEEN ONE OR MORE

INSPECTIONS BY THE DEPARTMENT OF HEALTH. THAT'S NOT

UNUSUAL. I'M NOT AWARE OF WHAT THEY FOUND.

Q BY MR. HARRIS: NARCONON INTERNATIONAL

CERTAINLY WOULD NOT CONDONE NARCONON OF GEORGIA HOLDING

ITSELF OUT AS OPERATING A RESIDENTIAL FACILITY IF, IN

FACT, IT DID THAT?

A NO, WE WOULD NOT CONDONE THAT. THAT WAS NOT

THEIR LICENSE, THEIR TRADEMARK LICENSE.

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Q AND IF NARCONON INTERNATIONAL DETERMINED THAT

NARCONON OF GEORGIA WAS, IN FACT, HOLDING ITSELF OUT AS

A RESIDENTIAL FACILITY WHAT, IF ANYTHING, WOULD NARCONON

INTERNATIONAL DO ABOUT THAT?


THE WITNESS: DEPENDING UPON THE CIRCUMSTANCES

THERE ARE A NUMBER OF OPTIONS. THE LICENSE CAN BE

WITHDRAWN OR THEY CAN BE ASKED TO FULLY, FULLY CORRECT

AND CEASE, CEASE THAT ACTIVITY IF WE HAD ACTUAL EVIDENCE

OF THAT HAVING OCCURRED.

NEED?

Q BY MR. HARRIS: WHAT SORT OF EVIDENCE WOULD YOU

A FACTUAL EVIDENCE.

Q OKAY.

WHAT SORT OF FACTUAL EVIDENCE?

A I WOULD PRESUME THAT IN A LEGAL RUDIMENTS

INSPECTION THERE WOULD BE SOMETHING SHOWING THAT IN THE

DOCUMENTS, IN THE, YOU KNOW, ANY ACTUAL EVIDENCE THAT

THERE WAS SOME KIND OF MISREPRESENTATION, EVIDENCE, YOU

KNOW, WHICH IS THE SAME FOR YOU AS IT WOULD BE FOR US.

NOT SOMEBODY'S MEMORY OF SOMETHING BUT ACTUAL EVIDENCE.

Q DO YOU INTEND AS THE PRESIDENT OF NARCONON TO

LOOK INTO THIS ISSUE THAT I BROUGHT UP HERE AT THE

DEPOSITION TODAY ABOUT THE DHR INSPECTION OF NARCONON OF

GEORGIA?

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THE WITNESS: WE ARE SATISFIED WITH THE, WITH THE

FLOW OF INFORMATION BETWEEN NARCONON OF GEORGIA AND

NARCONON EASTERN US AND US AND, TO MY UNDERSTANDING,

NARCONON OF GEORGIA HAS CONTINUED TO BE LICENSED AND HAS

A GOOD WORKING RELATIONSHIP WITH THE STATE AND IF THEY

HAVE INSPECTIONS AND THEY CORRECT THE DEFICIENCIES WE

DON'T NEED TO, WE DON'T NEED TO HAVE AN ITEMIZED OUTLINE

OF THAT.

Q BY MR. HARRIS: WELL, THAT'S NOT WHAT I ASKED

YOU.

I'M REPRESENTING TO YOU, SIR, THAT THERE WAS A

DHR INSPECTION OF NARCONON OF GEORGIA WHERE THIS ISSUE

CAME UP AND I WANT YOU TO LOOK IN THE CAMERA THERE AND

TELL THE JURY WHETHER OR NOT AS PRESIDENT OF NARCONON

INTERNATIONAL YOU INTEND TO LOOK INTO THAT TO DETERMINE

WHETHER OR NOT THERE'S ANY FACTUAL BASIS FOR THAT

ALLEGATION.


MR. ROOT: SAME.

THE WITNESS: IF THERE IS IF THERE IS THE

POSSIBILITY OF A FACTUAL BASIS OF THAT THEN I WOULD ASK

OUR DEPARTMENT OF LEGAL AFFAIRS TO LOOK INTO THAT, FOR

SURE, CERTAINLY.

Q BY MR. HARRIS: ARE YOU?

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A HAVING MENTIONED THIS TO ME TODAY, I WILL ASK

OUR DIRECTOR OF LEGAL AFFAIRS WHAT ARE THE FACTS WITH

REGARD TO THIS.

Q SO YOU'RE GOING TO LOOK INTO THIS TO DETERMINE

WHETHER OR NOT THERE'S ANY FACTUAL BASIS FOR IT?

A BASED ON WHAT YOU SAID I WOULD BE INTERESTED TO

KNOW THAT, YES.

Q OKAY.

NOW, YOU WOULD ALSO AGREE WITH ME THAT IF

NARCONON OF GEORGIA IS HOLDING ITSELF OUT AS A

RESIDENTIAL FACILITY WHEN IT DOESN'T HAVE A DHR LICENSE

TO DO THAT, THAT THAT WOULD BE A NONOPTIMUM SITUATION?

A WELL, IT WOULD BE A VIOLATION OF THE LAW.

Q WHICH IS

A THAT WOULD BE A NONOPTIMUM SITUATION, YES.

Q SORT OF THE BIGGEST OF THE NONOPTIMUM

SITUATIONS, RIGHT?

A YES.

Q PRIOR TO PATRICK DESMOND'S DEATH, HOW MANY

ONSITE HEALTH AND SAFETY INSPECTIONS DID NARCONON

INTERNATIONAL CONDUCT OF THE NARCONON OF GEORGIA

FACILITY?

A I KNOW WE DID ONE AND THEN I'M NOT -- I DON'T

KNOW HOW MANY NARCONON EASTERN US DID.

Q SO YOU'RE SAYING THAT NARCONON INTERNATIONAL

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ONLY DID ONE INSPECTION OF NARCONON OF GEORGIA BEFORE

PATRICK DIED?

A FULL TECHNICAL INSPECTION, YES.

Q AND WHEN WAS THAT?

A I DON'T RECALL THE DATE.

Q WHY NOT?

A I'M SORRY. I DON'T RECALL. I THINK IT WAS

2007. I'M NOT SURE. THERE MAY HAVE BEEN A LEGAL

RUDIMENTS INSPECTION THAT WE DID BEFORE.

Q WELL, NO. 22, "SITE VISITS, AND THE RESULTS

OBTAINED THEREFROM, BY PERSONS FROM NARCONON

INTERNATIONAL OR SENT ON BEHALF OF NARCONON

INTERNATIONAL TO NARCONON OF GEORGIA."

DID YOU DO, DID NARCONON INTERNATIONAL DO ANY

SITE VISITS TO NARCONON OF GEORGIA?

A AS I RECALL NOW, AGAIN, HAVING JUST REMEMBERED,

THERE WAS A LEGAL RUDIMENTS INSPECTION THAT CLAUDIA DID

PRIOR TO A FINAL LICENSING INSPECTION THAT WAS GOING TO

BE DONE BY THE DEPARTMENT OF HEALTH AND -- OR DHR.

Q ALL RIGHT.

SO THERE WAS A LEGAL RUDIMENTS INSPECTION.

THERE WAS A TECH INSPECTION, AS WELL?

A I'M NOT SURE IF THERE WAS A TECH INSPECTION. I

KNOW THERE WAS ONE AFTER MR. DESMOND'S DEATH. I DON'T

KNOW ABOUT BEFORE. I KNOW THAT THERE WAS THE CONTINUING

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R. Leonard CSR, inc.

FLOW OF COMMUNICATION AND STATISTICS AND REPORTS FROM

MARY VIA NARCONON EASTERN UNITED STATES TO NARCONON

INTERNATIONAL.

Q EXHIBIT NO. 15.

A UH-HUH.

Q SORRY.

IS EXHIBIT NO. 15, IS THAT THE INSPECTION THAT

YOU WERE REFERRING TO?

A YES.

Q ALL RIGHT.

SO NARCONON INTERNATIONAL DID AN ONSITE

INSPECTION OF NARCONON OF GEORGIA BEFORE PATRICK

DESMOND'S DEATH, CORRECT?

A YES.

Q AND THE PURPOSE OF THAT INSPECTION WAS TO DO A

THOROUGH INSPECTION OF NARCONON OF GEORGIA PRIOR TO

FINAL LICENSURE TO THE LICENSURE INSPECTION BY THE

GEORGIA DHR --

A UH-HUH.

Q -- TO ENSURE THAT ALL INSPECTION, PRIOR

INSPECTION DEFICIENCIES HAVE BEEN ADDRESSED AND TO

ENSURE THAT THE CENTER IS IN 100 PERCENT COMPLIANCE WITH

ALL DHR STANDARDS.

A YES.

Q AND THAT WOULD INCLUDE THE ISSUE THAT YOU AND I

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TALKED ABOUT EARLIER OF WHETHER OR NOT IT WAS ACTING IN

ACCORDANCE WITH ITS DHR LICENSE?

A YES.

Q EXHIBIT NO. -- EXHIBIT NO. 15. LOOK AT NO. 13.

A UH-HUH.

Q NARCONON INTERNATIONAL ALSO, PRIOR TO PATRICK

DESMOND'S DEATH, INSPECTED THE, QUOTE, "STUDENT BERTHING

.AREA."

A UH-HUH.

Q IS THAT CORRECT?

A IT'S STATED HERE AS A PROJECT TARGET.

Q WELL, DID IT HAPPEN?

A I DON'T KNOW.

Q WELL, THAT'S ONE OF THE THINGS THAT WE'VE ASKED

YOU TO COME TELL US ABOUT.

A OKAY. WELL, WHAT I SEE IN THE, WHAT'S LISTED

AS DONE ARE OTHER TARGETS. THAT ONE'S NOT LISTED AS

DONE. I DON'T KNOW IF, IN FACT, IT WAS DONE.

Q WELL, IT'S ON THE LIST HERE OF THINGS THAT NEED

TO BE DONE IN ORDER TO ENSURE 100 PERCENT COMPLIANCE

WITH ALL DHR STANDARDS, RIGHT?

A UH-HUH. SO THE, FOR NARCONON, THE NARCONON

TRADEMARK LICENSE, IT WOULD BE THE DELIVERY CENTER THAT

WOULD BE THE, YOU KNOW, OUR RESPONSIBILITY TO, TO LOOK

AT BECAUSE THAT'S WHAT WE'RE LICENSING. TO OUR




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UNDERSTANDING IN THE ENROLLMENT FORM THAT NARCONON OF

GEORGIA HAD THEY, HOUSING WAS A SEPARATE ISSUE AND

ENROLLEES SEPARATELY CONTRACTED FOR OR WHEREVER THEY

WERE GOING TO LIVE. SO THIS WOULD BE NOT SOMETHING THAT

WE COULD, WE COULD, YOU KNOW, WE COULD ADDRESS AS PART

OF OUR TRADEMARK LICENSE.

Q OH. REALLY? I MEAN, I DIDN'T ASK YOU ABOUT

THE LICENSE AGREEMENT AT ALL.

I ASKED YOU ABOUT THIS PARTICULAR DOCUMENT AND

THIS DOCUMENT SAYS THAT NARCONON OF GEORGIA INTENDS TO

DO AN INSPECTION OF -- OR EXCUSE ME -- THAT NARCONON

INTERNATIONAL INTENDS TO DO AN INSPECTION OF NARCONON OF

GEORGIA, RIGHT?

A UH-HUH.

Q AND ON THE LIST THAT NARCONON INTERNATIONAL

MADE IT SAYS IT'S GOING TO INSPECT THE STUDENT BERTHING

AREA.

A YES.

Q DID THAT HAPPEN OR NOT?

A I DON'T -- I DO NOT KNOW AND IT IS NOT MARKED

AS DONE HERE SO I CANNOT, I CANNOT ANSWER THAT QUESTION.

I'M SORRY.

Q WHAT DID YOU DO TO DETERMINE WHETHER OR NOT IT

WAS DONE IN CONNECTION WITH GETTING PREPARED FOR THIS

DEPOSITION THAT WE'RE TAKING HERE TODAY?

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A I DID NOT LOOK AT THAT PARTICULAR POINT.

Q YOU WOULD AGREE WITH ME THAT IT FALLS UNDER

CATEGORY NO. 22 HERE WHERE WE'RE ASKING YOU ABOUT SITE

VISITS BY NARCONON INTERNATIONAL OF NARCONON OF GEORGIA?

A YES.

Q WHY DIDN'T YOU LOOK INTO WHETHER OR NOT THERE

WERE SITE VISITS AND --

A WELL, THE SITE VISITS WOULD BE PER OUR

TRADEMARK LICENSE WHICH WOULD BE THE CENTER ITSELF. I

SEE THAT IT IS WRITTEN ON THIS THING HERE.

Q RIGHT. IT SAYS

A ON THIS. I DID NOT SEE THAT PARTICULAR POINT

AND I SEE YOU'RE OUTLINING IT TO ME. I DON'T KNOW, IN

FACT, WHETHER THERE WAS A --

Q AND YOU KEEP TALKING ABOUT YOUR LICENSE

AGREEMENT BUT, MR. CARR, IT SAYS NO. 1 ON YOUR BUSINESS

ASSOCIATE DUTIES AND RESPONSIBILITIES FOR THE BUSINESS

ASSOCIATE AGREEMENT THAT NARCONON INTERNATIONAL IS GOING

TO CONDUCT ONSITE HEALTH AND SAFETY INSPECTIONS, DOES IT

NOT, SIR?

A YES. AND THAT WOULD BE OF THE PURVIEW WHERE

NARCONON INTERNATIONAL HAS AUTHORITY WHICH WAS OVER THE

ACTUAL DELIVERY PROGRAM WHICH ARE THE OFFICES OF

NARCONON OF GEORGIA ITSELF.

Q ALL RIGHT.

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AND IT SAYS IN THE BUSINESS ASSOCIATE

AGREEMENT, THOUGH, THAT YOU'RE GOING TO DO THIS IN ORDER

TO ASSESS AND IMPROVE THE QUALITY OF CARE PROVIDED TO

CLIENTS, DOES IT NOT?

A YES.

Q AND NO. 1, IN ORDER TO ASSESS AND IMPROVE THE

QUALITY OF CARE TO CLIENTS IS CONDUCT ONSITE HEALTH AND

SAFETY INSPECTIONS, RIGHT?

A YES.

Q AND AS YOU SIT HERE TODAY, YOU CAN'T TELL ME

WHETHER OR NOT NARCONON INTERNATIONAL INSPECTED THE

STUDENT BERTHING AREA THAT'S DESCRIBED HERE IN PARAGRAPH

13 OF THIS INSPECTION?

A AT THAT PARTICULAR TIME, I DON'T KNOW. WHAT I

DO KNOW IS THAT OUR LICENSE AUTHORITY AND WHAT WE HAVE

THE MEANS OF CORRECTING IS WHAT IS IN NARCONON OF

GEORGIA DELIVERY, YOU KNOW, THE CENTER ITSELF AND THAT

IS WHAT WE LICENSE AND THAT IS WHAT WE INSPECT.

Q AGAIN, I --

A I SEE THAT IT IS -- I SEE WHAT YOU'VE SAID THAT

IT'S WRITTEN HERE. I DO NOT HAVE AN ANSWER TO THAT.

Q I UNDERSTAND THAT YOU WANT TO REFER TO THE

LICENSE AGREEMENT EVERY TIME I ASK YOU A QUESTION BUT I

HAVEN'T ONCE ASKED YOU ABOUT THAT.

I'M ASKING YOU ABOUT THIS. AND WHAT I WANT TO

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KNOW IS, ATTACHMENT A TO THIS BUSINESS ASSOCIATE

~GREEMENT TALKS ABOUT ONSITE HEALTH AND SAFETY

INSPECTIONS DESIGNED TO ASSESS AND IMPROVE THE QUALITY

OF CARE TO CLIENTS.

A YES.

Q I WANT TO KNOW HOW MANY TIMES THOSE KINDS OF

INSPECTIONS THAT ARE DESCRIBED ON ATTACHMENT A OCCURRED,

WHEN THEY OCCURRED AND WHAT WAS INSPECTED. CAN YOU TELL

ME? CAN YOU ANSWER THAT QUESTION?

A THERE MAY BE ADDITIONAL ONES THAT NARCONON

EASTERN US DID. WHAT I KNOW OF IS THIS LEGAL RUDIMENTS

INSPECTION THAT WAS OF THE DELIVERY FACILITY ITSELF,

THAT'S WHAT I -- THAT'S WHAT I KNOW OF.

Q AND AGAIN, I DIDN'T ASK YOU ANYTHING ABOUT

NARCONON EAST US.

A OKAY. SO THERE MAY HAVE BEEN ADDITIONAL THERE.

AS FAR AS NARCONON INTERNATIONAL, THIS IS THE ONE THAT I

KNOW WHERE A TWO-PERSON TEAM WENT THERE AND DID WHAT IS

OUTLINED HERE.

Q OKAY.

WHEN NARCONON EAST US DOES AN INSPECTION, IS

THAT FORWARDED TO NARCONON INTERNATIONAL?

A NOT ALWAYS.

Q IS IT SUPPOSED TO BE?

A NOT NECESSARILY.

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Q WHAT'S THE PURPOSE OF NARCONON EAST US?

A NARCONON INTERNATIONAL IS OVER ALL OF THE

CENTERS AROUND THE WORLD AND OUR PRINCIPAL INTEREST IS

IN LONG TERM TRENDS OF WHAT'S GOING ON AND SO FORTH. WE

HAVE CONTINENTAL OFFICES THAT HAVE FEWER CENTERS UNDER

THEIR PURVIEW AND THEY BASICALLY PERFORM THE SAME

EXTERNAL FUNCTION OF MONITORING THE TRADEMARK DELIVERY

BUT AT A CLOSER LEVEL. BECAUSE THERE ARE TOO MANY

CENTERS FOR JUST NARCONON INTERNATIONAL SO NARCONON

EASTERN US ESSENTIALLY PERFORMS THE SAME AND HAS THE

SAME RELATION TO NARCONON OF GEORGIA THAT WE DO. IT'S

TO MONITOR THE QUALITY AND DELIVERY OF THE NARCONON

MATERIALS.

Q IT SAYS IN THIS ATTACHMENT A THAT WE'VE BEEN

TALKING ABOUT THAT NARCONON INTERNATIONAL SHALL PROVIDE

PERIODIC ONSITE INSPECTIONS OF THE FACILITY'S DRUG REHAB

SERVICES.

A UH-HUH.

Q OKAY.

YOU'VE TOLD ME ABOUT ONE, ONE INSPECTION.

A RIGHT.

Q WHAT OTHER PERIODIC INSPECTIONS, IF ANY,

PURSUANT TO THIS AGREEMENT WERE CONDUCTED BY

INTERNATIONAL?

A BY NARCONON INTERNATIONAL? I'M AWARE OF THE

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TECHNICAL INSPECTION AND THE LEGAL RUDIMENTS INSPECTION

AFTER THE FACT OF MR. DESMOND'S DEATH.

Q SO THERE WAS A TECH INSPECTION AND A LEGAL

RUDIMENTS INSPECTION THAT OCCURRED AFTER HIS DEATH, AND

THEN I BELIEVE THERE WAS THIS COMPLIANCE INSPECTION THAT

YOU AND I TALKED ABOUT EARLIER WHICH OCCURRED BEFORE HIS

DEATH.

A YES.

Q ANY OTHERS, ANY OTHER INSPECTIONS?

A BY NARCONON INTERNATIONAL NOT THAT I KNOW OF,

NO.

Q WELL, YOU KEEP SAYING BY NARCONON

INTERNATIONAL. DID YOU DELEGATE THIS PERIODIC ONSITE

REVIEW OF THE FACILITY, DID YOU DELEGATE, DID

INTERNATIONAL DELEGATE THAT TO EAST US?

A IT IS PART OF THEIR FUNCTION.

Q OKAY.

A AND SO THEY MAY ON THEIR OWN GO AND HAVE GONE

TO MANY OF THE CENTERS THAT ARE IN THE EASTERN UNITED

STATES AND DO VARIOUS KINDS OF INSPECTIONS AND WITH

CORRECTIONS AND SO FORTH, THE SAME AS WE DO, AND SO IT'S

QUITE POSSIBLE THAT THEY DID ADDITIONAL INSPECTIONS WITH

NARCONON OF GEORGIA BECAUSE I KNOW THEY'VE DONE IT WITH

OTHER CENTERS THROUGHOUT THE EASTERN US.

Q BUT YOU CAN'T TELL ME ONE WAY OR THE OTHER

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WHETHER THAT WAS THE CASE?

A NO, I CAN'T

Q ALL RIGHT.

A -- SPECIFICALLY.

MR. HARRIS: LET'S TAKE A BREAK.

THE VIDEOGRAPHER: WE'RE GOING TO GO OFF THE RECORD

AT 11:41 A.M.

(LUNCH RECESS) .


APPROXIMATELY 12:11 P.M.

MR. HARRIS: OKAY.

Q MR. CARR, DURING THE BREAK YOUR COUNSEL HANDED

ME A COUPLE OF ARTICLES THAT I BELIEVE WERE SOME OF THE

ONES THAT YOU WERE ALLUDING TO EARLIER THAT YOU COULD

PULL FOR ME. TELL ME IF THAT'S, IF MY UNDERSTANDING IS

CORRECT.

A YES, THESE ARE, THIS OUTLINES SOME OF THE

PAPERS, PRINCIPAL PAPERS THAT HAVE BEEN DONE ON STUDIES

ON THE SAUNA DETOXIFICATION AND THE SCIENCE RELATED

THERETO, INCLUDING ANSWERS ON QUESTIONS REGARDING THE

USE OF NIACIN IN THE HUBBARD DETOXIFICATION PROGRAM.

MR. HARRIS: WHERE WERE WE? EXHIBIT WHAT?

THE REPORTER: 28.

MR. HARRIS: ALL RIGHT.

Q I'M GOING TO MARK THAT JUST AS A COMPOSITE.

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A (INDICATING) .

Q THANK YOU, SIR.



ATTACHED HERETO) .


YOU SAID SOME OF THEM. ARE THERE OTHER

ARTICLES, NOW THAT YOU'VE HAD A CHANCE TO LOOK THROUGH

THAT COMPOSITE EXHIBIT? AND REALLY, ALL I'M TRYING TO

DO IS, BEFORE TRIAL OF THIS CASE I WANT TO KNOW EVERY

ARTICLE THAT YOU FOLKS RELY ON FOR THE CONTENTIONS·THAT

YOU'RE MAKING ABOUT THE EFFECTIVENESS OF THE VITAMINS

AND THE SAUNA PROGRAM.

A YES, THESE ARE THE PRINCIPAL PAPERS. THERE ARE

TWO OTHERS THAT ARE NOT HERE, ONE OF WHICH IS PUBLISHED

IN THE TOWNSEND LETTER THAT'S ON THE USE OF THE SAUNA

DETOXIFICATION PROGRAM TO HELP RESCUE WORKERS AFTER THE

WORLD TRADE CENTER DISASTER, PUBLISHED IN THE TOWNSEND

LETTER.

THERE'S ANOTHER RECENT STUDY THAT WAS DONE IN

UTAH WITH POLICE WHO WERE EXPOSED TO METHAMPHETAMINE

WHERE IT WAS THROWN IN THEIR FACE OR WHEN LABORATORIES

EXPLODED WHEN THEY RAIDED THEM AND THEY THEN GOT ILL OR

PUT ON DISABILITY BECAUSE OF APPARENTLY TOXIC ISSUES

REGARDING EXPOSURE TO METHAMPHETAMINE AND USE OF THE

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SAUNA DETOXIFICATION PROCEDURE TO HELP THESE POLICE

OFFICERS, AND THAT'S ALSO, THAT'S A PUBLISHED PAPER, AS

WELL.

SO THOSE ARE THE ONLY TWO THAT ARE NOT IN HERE,

BUT THESE ARE THE PRINCIPAL DOCUMENTS.

Q YOU SAID PUBLISHED IN UTAH. CAN YOU GIVE ME

ANY MORE INFORMATION THAT WOULD HELP ME FIND THAT?

A AGAIN, BY THE END OF THE DAY.

Q YOU HAVE IT?

A YES, I HAVE IT.

Q YOU'LL GET ME A COPY?

A YES, I'LL GET YOU A COPY OF THAT AND ALSO THE

TOWNSEND LETTER, PAPER.

Q THE FOUNDATION FOR ADVANCEMENT IN SCIENCE AND

EDUCATION, WHAT IS THE RELATIONSHIP, IF ANY, BETWEEN THE

FOUNDATION FOR ADVANCEMENT IN SCIENCE AND EDUCATION AND

THE CHURCH OF SCIENTOLOGY, ABLE OR NARCONON

INTERNATIONAL?

A THEY ARE AN INDEPENDENT ORGANIZATION.

Q ARE THEY COMPLETELY INDEPENDENT OF ANY OF THE

THREE ENTITIES THAT I'VE JUST NAMED?

A YES.

Q DO THEY RECEIVE FUNDING FROM ANY OF THOSE

ENTITIES?

A THEY HAVE NOT RECEIVED FUNDING FROM NARCONON

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INTERNATIONAL. I CANNOT SPEAK FOR ABLE OR THE CHURCH OF

SCIENTOLOGY.

Q WELL, YOU RIGHT BEFORE I ASKED YOU THAT

QUESTION SAID THAT THEY WERE COMPLETELY INDEPENDENT.

A TO MY KNOWLEDGE. SO I WOULD --

Q WELL, IF THEY RECEIVED FUNDING FROM THE CHURCH

OF SCIENTOLOGY OR FROM ABLE, YOU WOULD AGREE WITH ME

THAT THEY'RE NOT COMPLETELY INDEPENDENT?

A YES. YES.

MS. RICHARDSON. OBJECTION.

MR. ROOT: SAME OBJECTION.

THE WITNESS: I'M CERTAIN-- SO MY-- I'M NOT

ALWAYS SCHOOLED IN HOW TO ANSWER A LEGAL QUESTION SO

I --

Q BY MR. HARRIS: ME NEITHER.

A YEAH. I SOMETIMES ANSWER WITH AN EXPLANATION

THAT I SHOULD NOT.

I KNOW THEY HAVE, THEY'RE COMPLETELY SEPARATE

FROM NARCONON INTERNATIONAL AND DO NOT RECEIVE FUNDING,

YOU KNOW, WITH REGARD TO ANY OF THESE STUDIES OR PAPERS

THAT THEY'VE PARTICIPATED IN FROM NARCONON

INTERNATIONAL.

Q AND THE SAME QUESTION WITH RESPECT TO THE FASE.

DO YOU KNOW WHAT THAT IS?

A THAT'S ALSO -- FOUNDATION FOR THE -- THAT'S THE

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SAME. YEAH. THAT PAPER WAS ORIGINATED BY FASE.

Q ALL RIGHT.

LET'S TALK ABOUT THE SUCCESS RATE. WHAT IS THE

SUCCESS RATE FOR NARCONON PROGRAMS?

A IT IS APPROXIMATELY THREE OUT OF FOUR AND 75

PERCENT. WE'RE TALKING ABOUT ONE TO TWO YEARS TRACKING

PEOPLE THAT ARE DRUG FREE AND THEN THERE ARE MANY

INDICATIONS OF A HIGHER SUCCESS RATE WITH REGARD TO SOME

OF THE INDICATORS, FREE FROM CRIMINAL RECIDIVISM, ALSO

DOING WELL IN SCHOOL, FAMILY AND SO FORTH.

Q OKAY.

SO THE POSITION OF NARCONON INTERNATIONAL,

THEN, IS THAT THE NUMBER AND I'VE SEEN, THE REASON

I'M ASKING YOU THIS IS I'VE SEEN VARIOUS NUMBERS THAT

FLOAT AROUND, 70 PERCENT, ANYWHERE FROM 70 PERCENT UP TO

I THINK 76 PERCENT.

A AS I SAY, MORE OR LESS. IN OTHER WORDS, THERE

ARE DIFFERENT REVIEWS AND STUDIES AND CASE STUDIES AND

EVALUATIONS THAT HAVE BEEN DONE BUT THEY CIRCLE AROUND

70 TO 75 PERCENT, THREE OUT OF FOUR.

Q IDENTIFY FOR ME THE SPECIFIC STUDIES THAT HAVE

BEEN DONE THAT VERIFY THAT 75 PERCENT SUCCESS RATE THAT

YOU HAVE REFERRED TO.

A THERE HAVE BEEN MANY WHAT WOULD BE CONSIDERED

INFORMAL EVALUATIONS OR CASE, CASE STUDIES OF THE

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PROGRAM FROM ITS VERY FIRST PROGRAM IN ARIZONA STATE

PRISON WHEN A YEAR LATER THE, THE PRISON ADMINISTRATION

CONTACTED THE PEOPLE WHO HAD GRADUATED AND FOUND THAT

THEY WERE DRUG FREE.

AND THEN EARLY ON IN NARCONON'S HISTORY,

BECAUSE IT WAS FOUNDED IN PRISON, THERE WERE MANY

PROGRAMS IN DIFFERENT PRISONS AND THERE ARE

VARIOUS -- THESE WERE NOT FORMAL STUDIES BUT THEY'RE

CASE, CASE STUDIES OR EVALUATIONS OF IMPROVEMENT EITHER

DURING THE PRISON OR AFTER THE PRISON, AND THE ONE YEAR

FOLLOWING CIRCLES AROUND THIS SAME AMOUNT, 70 TO 75

PERCENT, SOMETIMES A LITTLE LESS.

AROUND 1981 THERE WAS A STUDY DONE IN SWEDEN BY

AN INDEPENDENT AUTHORITY ON THE NARCONON THAT WE HAD

THERE AT THAT TIME THAT WAS NOT A CONTROLLED STUDY BUT

IT WAS WITH A CONTROL OF THE, OF RECIDIVISM IN GENERAL

DRUG REHABILITATION POPULATION. IT FOUND, I BELIEVE IT

WAS A 78.6 PERCENT OR SOMETHING. AGAIN, AROUND THE SAME

AMOUNT.

Q ALL RIGHT.

WELL, YOU'VE TOLD ME THAT THERE WERE A NUMBER

OF STUDIES THAT WERE NOT FORMAL, THAT THERE WAS A STUDY

IN SWEDEN THAT WASN'T CONTROLLED.

IF I WANT TO ACTUALLY SIT AND READ THESE STUDIES OR

LOOK AT THEM, WHERE CAN I FIND THEM AND CAN YOU IDENTIFY

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THEM WITH ANY SPECIFICITY THAT WOULD ALLOW ME TO FIND

THEM AND READ THEM?

A I CAN CERTAINLY PROVIDE YOU WITH THE ACTUAL

DOCUMENTATION ON THEM. THERE'S AN ADDITIONAL CASE STUDY

THAT WAS DONE IN UTAH WITH A FOURTH DISTRICT JUVENILE

COURT AND THIS WAS WITH A POPULATION OF CRIMINALLY

OFFENDING DRUG-ADDICTED JUVENILES AND THEY CONTRACTED

WITH NARCONON TO DELIVER THEIR SOCIAL EDUCATION MODEL

AND THIS WAS A CONTROLLED STUDY AND IT WAS FOUND THAT

THE GRADUATES OF THIS PROGRAM -- AND THIS IS A

PARTICULARLY SEVERE GROUP BECAUSE THEY WERE HIGHLY

CRIMINALLY OFFENDING -- 63.5 PERCENT OF THESE TWO YEARS

FOLLOWING THE PROGRAM WERE FOUND TO HAVE BEEN 100

PERCENT CRIME FREE WHICH ALSO MEANS DRUG FREE BECAUSE

THEY WERE CONSTANTLY BEING TESTED DURING THAT TIME TWO

YEARS FOLLOWING THE COMPLETION OF THE NARCONON PROGRAM

AS OPPOSED TO THE CONTROL GROUP WHICH WAS, I THINK,

ABOUT 30 PERCENT WHICH HAD DONE ANOTHER PROGRAM. AND

THIS PAPER WAS PRESENTED AT THE WESTERN ATTORNEYS

GENERAL CONFERENCE IN 2005 IN THE STATE OF HAWAII.

Q ALL RIGHT.

WILL YOU GET ME THE STUDIES THAT YOU HAVE

COPIES OF?

A CERTAINLY.

Q PROVIDE THEM TO ME?

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A CERTAINLY, I WILL DO THAT.

Q NARCONON INTERNATIONAL IN ITS LITERATURE AND ON

ITS WEBSITE AND IN VARIOUS PLACES USES THIS SPECIFIC

NUMBER. THE STUDIES THAT YOU'RE GOING TO PROVIDE FOR

ME, ARE THOSE STUDIES THE BASES FOR NARCONON

INTERNATIONAL'S STATEMENTS IN ITS DOCUMENTS REGARDING

THE NUMBER, THE SUCCESS RATE NUMBER? DOES THAT MAKE

SENSE?

A YES.

Q OKAY.

A THAT, AS WELL AS A STANDARD PROCEDURE IN

NARCONON WHICH IS TO FOLLOW UP, TO FOLLOW UP GRADUATES

AFTER THEY GRADUATE. WE CALL IT ROUTINE OUTCOME

MONITORING. AND NARCONON ARROWHEAD, WHICH IS OUR

INTERNATIONAL TRAINING CENTER IN OKLAHOMA, WAS ACTUALLY

COMMENDED BY THE REHABILITATION ACCREDITATION

COMMISSION, CARF, FOR THEIR ROUTINE OUTCOME MONITORING

PROCEDURE. AND WITH THIS WE'RE ALSO, THE CENTERS ARE

INDIVIDUALLY TRACKING HOW THEIR GRADUATES ARE DOING AND

WE HAVE MANY CENTERS THAT ARE DOING THAT.

THOSE ALSO PARALLEL THE SAME APPROXIMATE NUMBER

OF 3 OUT OF 4 PERCENT AND THEREFORE WE BELIEVE IT'S A

VALID PERCENTAGE TO PRESENT.

Q IS THAT INFORMATION COMPILED AND SENT TO


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A NO, WE DON'T REQUIRE THAT.

Q WELL, THEN HOW DO YOU GET IT?

A PERIODICALLY WE REQUEST IT BUT IT'S NOT SENT ON

A REGULAR BASIS.

Q THAT'S -- I DON'T THINK I ASKED YOU THAT.

I ASKED YOU IF IT WAS COMPILED BY NARCONON

INTERNATIONAL AND BY WHATEVER WAY YOU DO IT. I DIDN'T

SAY THAT THEY WERE FORCED TO SEND IT TO YOU.

A OKAY. I'M SORRY. I MISUNDERSTOOD. I HAVE TO

LISTEN CAREFULLY TO YOUR QUESTION.

THERE HAVE BEEN A NUMBER OF INSTANCES WHERE WE

HAVE SPECIFICALLY ASKED FOR THE DATA FOR A PARTICULAR

PERIOD, COMPILED IT AND BEEN ABLE TO HAVE IT AS A

DOCUMENT.

Q WHEN, AS A DOCUMENT, I MEAN, WHEN WAS THE LAST

TIME YOU COMPILED THE DATA FROM THESE VARIOUS CENTERS?

A I THINK IT WAS A FEW YEARS AGO.

Q IS THERE SOME DOCUMENT THAT WAS GENERATED FROM

THAT COMPILATION?

A YES. I CAN PRESENT THAT AS WELL AS THESE

OTHERS. AGAIN, THIS IS THE ACTION OF THE, WHAT WE CALL

THE ROUTINE OUTCOME MONITORING THAT THE CENTERS DO.

Q HOW DO YOU GET THE DATA? IS THERE, AND BY THAT

I MEAN IS THERE SOME ELECTRONIC SYSTEM IN PLACE BETWEEN

NARCONON INTERNATIONAL AND THE VARIOUS CENTERS WHERE YOU

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CAN GATHER DATA LIKE THAT OR DO THEY HAVE TO PUT IT ALL

TOGETHER AND SEND IT OFF TO YOU?

A IT DEPENDS UPON WHICH DATA YOU'RE REFERRING TO.

Q WELL, I WAS SPECIFICALLY TALKING ABOUT THE

SUCCESS RATE DATA BUT WE'LL GET INTO SOME MORE DETAILS

ON THE OTHER DATA IN JUST A SECOND.

A THAT THE CENTERS THEMSELVES COLLECT THE DATA

AND ON SOME OF THESE THEY SEND US THE DATA, SOME THEY

COMPILE THEMSELVES AND THEN SEND US THE COMPLETION, YOU

KNOW, THE COMPILED, THE COMPILED DATA IN WRITING.

Q HOW MUCH DOES THE NARCONON PROGRAM COST?

A IT VARIES AROUND THE WORLD DEPENDING UPON THE

ECONOMY OF THAT COUNTRY. IT IS PARALLEL TO WHAT OTHER

PROGRAMS CHARGE.

Q IS IT --

A IT'S BETWEEN 20- AND $30,000, I BELIEVE.

Q IS IT STANDARDIZED IN THE UNITED STATES?

A WITH THE RESIDENTIAL CENTERS THERE IS

BASICALLY, I BELIEVE, A STANDARD, STANDARD PRICE WHICH

IS SOMEWHERE AROUND $25,000. I'M NOT SURE EXACTLY BUT

IT'S ABOUT THAT.

Q IS THAT SOMETHING THAT IS REQUIRED BY NARCONON

INTERNATIONAL?

A NO.

Q SO THE INDIVIDUAL CENTERS ARE FREE TO SET

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WHATEVER RATE THEY WANT TO SET?

A YES, THEY ARE. WE DO COORDINATE WITH THEM TO

NOT GET INVOLVED IN, YOU KNOW, UNNECESSARY COMPETITION

BECAUSE IT'S A STANDARD PROGRAM MODEL THAT'S BEING

DELIVERED.

I BELIEVE MARY RIESER CHARGES LESS BECAUSE HERS

WAS AN OUTPATIENT PROGRAM.

Q OKAY. ALL RIGHT.

GOING BACK TO EXHIBIT -- DID YOU FIND THAT?

WHO IS MEGAN SHIELDS?

A DR. MEGAN SHIELDS USED TO BE OUR, THE MEDICAL

DIRECTOR OF NARCONON INTERNATIONAL. SHE'S A FAMILY

PRACTICE PHYSICIAN, PRACTICING HERE IN LOS ANGELES.

Q IS MEGAN SHIELDS THE MEDICAL DIRECTOR OF


A I DON'T KNOW WHO IS THE MEDICAL DIRECTOR OF

NARCONON OF GEORGIA.

Q WELL, DO YOU KNOW WHETHER MEGAN SHIELDS IS?

A NO, I DON'T KNOW.

Q SO YOU THINK -- MEGAN SHIELDS COULD BE THE

MEDICAL DIRECTOR OF NARCONON OF GEORGIA?


THE WITNESS: I DON'T KNOW. I WOULDN'T THINK SO

BECAUSE SHE'S HERE.

Q BY MR. HARRIS: RIGHT.

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A AND NARCONON OF GEORGIA IS IN GEORGIA BUT I

DON'T KNOW TO ANSWER THAT.

Q IN ORDER TO HAVE COPY UP ON A WEBSITE, DO THE

INDIVIDUAL CENTERS HAVE TO HAVE THAT COPY APPROVED BY


A NOT NECESSARILY ALL THE COPY. WHAT NARCONON

INTERNATIONAL IS INTERESTED IN IS THE PRESENTATION OF

THE TRADEMARK. WE DON'T NECESSARILY REVIEW. THERE ARE

LOTS OF WEBSITES. WE DON'T REVIEW ALL OF THEM AND ALL

OF THE COPY.

Q WELL, I'M ASKING YOU ABOUT THE INDIVIDUAL

CENTERS.

OKAY?

A UH-HUH.

Q SPECIFICALLY, THE INDIVIDUAL CENTERS IN THE

UNITED STATES. DO THE INDIVIDUAL CENTERS FOR NARCONON

HAVE THE AUTHORITY TO PUT UNAPPROVED TEXT ON THEIR

WEBSITE?

A THEY HAVE THE RIGHT TO CREATE THEIR OWN TEXT,

YES. WE DON'T NECESSARILY REVIEW ALL OF IT.

Q HAVE YOU REVIEWED THE WEBSITE FOR NARCONON OF

GEORGIA?

A I DON'T KNOW WHEN IS THE LAST TIME THAT SOMEONE

AT NARCONON INTERNATIONAL MAY HAVE DONE THAT.

Q WELL, IS THAT SOMETHING THAT'S ROUTINELY DONE?

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2 THE DIFFERENT WEBSITES.

12:25:40 3 Q AND I'M PULLING THIS UP BECAUSE IT'S --AND

4 THERE IS REALLY NO WAY TO PARTICULARLY MARK IT BUT WE'RE

5 DOING IT LIVE SO I'LL SHOW IT TO YOU.

12:25:46 6 A OKAY. UH-HUH.

12:25:48 7 Q THIS IS THE WEBSITE FOR THE ATLANTA RECOVERY

8 CENTER WHICH IS THE GEORGIA FACILITY.

12:25:51 9 A UH-HUH.

12:25:57 10 Q AND DOWN HERE IT SAYS "HOUSING IN A RESIDENTIAL

11 SETTING IS PROVIDED."

12:26:07 12 DO YOU SEE THAT?

12:26:27 13 A YES, I DO SEE THAT.

12:26:31 14 Q AND WE'LL CAPTURE A SCREEN SHOT OF THAT AND

15 WE'LL ATTACH IT TO THE RECORD SO THERE WILL BE SOME .

16 CLEAN RECORD OF WHAT YOU'VE BEEN REVIEWING THERE.

12:26:40 17 DOES THAT CONCERN YOU THAT THE WEBSITE FOR

18 NARCONON OF GEORGIA SUGGESTS THAT IT HAS RESIDENTIAL

19 HOUSING?

12:26:44 20 A THE WORDING --

12:26:45 21 MR. ROOT: OBJECT TO THE FORM.

12:26:46 22 MS. RICHARDSON: OBJECT TO THE FORM.

12:26:48 23 THE WITNESS: THE WORDING IS NOT CLEAR.

12:26:50 24 Q BY MR. HARRIS: WELL, DOES THAT CONCERN YOU,

25 THE FACT THAT THE WORDING IS NOT CLEAR?




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A NOW THAT YOU'VE PRESENTED IT TO ME, YES.

Q WELL, CAN'T YOU SEE HOW A PERSON WHO WOULD BE

LOOKING AT THAT MIGHT BE CONFUSED INTO BELIEVING THAT

THIS IS A RESIDENTIAL FACILITY?



THE WITNESS: LOOKING AT THAT SPECIFIC WEBSITE AND

NOT HAVING REVIEWED THE REST OF IT AND HOW IT IS PERHAPS

LATER IN THE WEBSITE DESCRIBED WHAT THE HOUSING IS, THAT

PARTICULAR PHRASE, I COULD SEE, YES.


WHAT ARE YOU GOING TO DO ABOUT IT?

A NOW THAT IT'S BEEN POINTED OUT TO ME I WILL ASK

MY DIRECTOR OF LEGAL AFFAIRS TO LOOK INTO IT.

Q WHY ARE YOU GOING TO DO THAT?

A I HAD NOT SEEN THAT.

Q NO. I MEAN, BUT WHAT IS IT ABOUT THIS WHAT

I'VE JUST SHOWED YOU THAT'S GOING TO PROMPT YOU TO ASK

YOUR DIRECTOR OF LEGAL AFFAIRS TO LOOK INTO IT?

A BECAUSE THAT'S PART OF NARCONON INTERNATIONAL'S

TRADEMARK LICENSE AUTHORITY WHICH IS THAT HOW THE

TRADEMARK IS PRESENTED IS, SHOULD BE CLEAR AND

PRESENTING -- NOT CREATING A CONFUSION OR NOT CREATING,

POSSIBLY GENERATING ANY PROBLEM.

Q WELL, YOU AND I EARLIER IN YOUR DEPOSITION

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TALKED ABOUT A COMPLAINT THAT AT LEAST SOMEONE HAD MADE

TO INTERNATIONAL ABOUT GEORGIA HOLDING ITSELF OUT AS A

RESIDENTIAL FACILITY.

DO YOU RECALL THAT CONVERSATION?

A YES, I DO.

Q DID ANYBODY FROM INTERNATIONAL LOOK AT THE

WEBSITE AFTER THAT COMPLAINT CAME IN TO SEE WHETHER OR

NOT THEY WERE DOING THAT?

A I DON'T KNOW.

Q SAME QUESTION WITH RESPECT TO THIS LAWSUIT.

OBVIOUSLY, YOU UNDERSTAND THAT THAT'S ONE OF OUR

CONTENTIONS. WE'VE DISCUSSED THAT IN SOME DETAIL.

A UH-HUH.

Q HAS ANYBODY FROM NARCONON INTERNATIONAL LOOKED

AT GEORGIA'S WEBSITE TO SEE WHETHER OR NOT THEY'RE

SUGGESTING THEY HAVE RESIDENTIAL HOUSING?


MR. ROOT: SAME.

THE WITNESS: I DON'T KNOW WHAT OUR DIRECTOR OF

LEGAL AFFAIRS MAY OR MAY NOT HAVE DONE AND THIS WOULD BE

WITH HER REGARD ON THAT. I KNOW THAT WE LOOKED AT THE

ENROLLMENT FORMS AND SO FORTH. I DON'T KNOW ABOUT THE

WEBSITE.


BUT YOU'RE GOING TO GO BACK TO THE OFFICE AND

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LOOK INTO THIS?

A THAT PARTICULAR LINE THAT YOU OUTLINED COULD BE

CLEAR, SHOULD BE CLEAR, I THINK.

Q EXHIBIT NO. 17 THAT YOU AND I TALKED ABOUT

EARLIER. I WANT TO -- IS IT IN FRONT OF YOU?

A (INDICATING). HERE YOU GO.

Q THAT'S YOUR COPY, SIR.

A OKAY.

Q THIS URGENT DIRECTIVE THAT WE SPENT SOME TIME

ON EARLIER, I'VE JUST GOT A FEW MORE QUESTIONS ON IT AND

THEN WE'LL MOVE ON TO SOMETHING ELSE. IT'S BATES NO.

1970.

A UH-HUH.

Q THIS IS THE COPY THAT YOU'RE CONTENDING THAT

INTERNATIONAL DIDN'T RECEIVE OR THIS IS ONE OF THE

DOCUMENTS YOU'RE CONTENDING THAT INTERNATIONAL DIDN'T

RECEIVE BEFORE PATRICK'S DEATH, RIGHT?

A YES.

Q THE SECOND PARAGRAPH INDICATES THAT "IN THE

LAST MONTH THERE HAVE BEEN SERVICE ISSUES AT NARCONON

AND HOUSING EVIDENCED BY PHYSICAL EPISODES -- "

A EXCUSE ME. I DON'T KNOW IF I'M LOOKING AT THE

SAME PAGE.

Q I'M SORRY. I GAVE YOU THE BATES NO. 1970.

A RIGHT.

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R Leonard CSR, Inc.

Q THE URGENT DIRECTIVE.

A YES. OKAY. AND WHERE, THE SECOND PARAGRAPH?

Q SECOND PARAGRAPH.

A OKAY. "IN THE LAST MONTH."

Q ALL RIGHT.

"THERE HAVE BEEN EPISODES OF -- " OR EXCUSE ME.

A PARDON. OH. I SEE "EVIDENCED. "CONCURRENT

WITH THE ATTACKS" IS THE ONE I SEE.

Q RIGHT. THAT'S THE ONE I'M READING FROM.

A RIGHT. OKAY. GOOD. I'M SORRY. OKAY.

Q RIGHT.

"THERE HAVE BEEN SERVICE ISSUES AT NARCONON AND

HOUSING."

A UH-HUH.

Q DO YOU SEE THAT?

A YES.

Q "EVIDENCED BY PHYSICAL EPISODES (RESULTING IN

TWO POLICE REPORTS), REPORTS OF RECENT DRUG USE, DIRTY

QUARTERS, ABSENCE FROM POST IN THE ORIENTATION AREA,

SAUNA AND HOUSING AND LEAVE OF ABSENCE GRANTED TO

STUDENTS NEW TO THE PROGRAM."

NOW, YOU WOULD AGREE WITH ME THAT ALL OF THOSE

THINGS THAT ARE LISTED THERE ARE NONOPTIMUM CONDITIONS,

CORRECT?

A YES.

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Q NOW, YOU INDICATE SEVERAL TIMES THAT YOU DIDN'T

GET THESE OR NARCONON INTERNATIONAL DIDN'T GET THESE

SPECIFIC DOCUMENTS. WHAT, IF ANYTHING, WOULD YOU HAVE

DONE DIFFERENTLY IF YOU HAD GOTTEN THE ACTUAL DOCUMENTS?

MR. ROOT: OBJECT TO THE FORM OF THE QUESTION.

THE WITNESS: I AM SURE THAT THE DIRECTOR OF

PRODUCTION WOULD HAVE WANTED TO KNOW WHAT CAME UP AND

HOW THESE DIFFERENT POINTS WERE BEING ACTUALLY CORRECTED

BY THE CENTER, BASED ON WHATEVER VALIDITY THERE WAS TO

THEM. IT IS, AGAIN, THE CENTER'S RESPONSIBILITY AND PER

OUR TRADEMARK LICENSE WE WOULD BE INTERESTED TO SEE THAT

THE CENTER WAS CORRECTING ANY INFRACTIONS OR

DEFICIENCIES THAT WERE THERE.

Q BY MR. HARRIS: EXHIBIT NO. 21.

DO YOU HAVE THAT?

A NO, I DON ' T .

Q OH. HERE IT IS. I'M SORRY. WE GOT THE

ORIGINAL.

THE SECOND PAGE OF EXHIBIT NO. 21, BATES NO.

1101

A UH-HUH.

Q IS A REPORT GENERATED BY THE EXECUTIVE

DIRECTOR OF NARCONON OF GEORGIA ON JUNE 12TH, 2008.

MS. FRANKLIN: EXHIBIT 22.

Q BY MR. HARRIS: I'M SORRY. IT'S EXHIBIT 22.

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Deposition of Clark Rob eli Nixdorf Carr Desmond vs. Narconon

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A OKAY.

Q DO YOU SEE WHERE I'M READING?

A YES.

Q ALL RIGHT.

THE EXECUTIVE DIRECTOR OF NARCONON OF GEORGIA

SENDS OR INDICATES THAT SHE IS SENDING THIS DOCUMENT TO

FOUR DIFFERENT ENTITIES. TELL ME WHAT THOSE ENTITIES

ARE.

A THE LEGAL DIRECTOR AT NARCONON INTERNATIONAL IS

OUR CLAUDIA ARCABASCIO. THE ED, THE EXECUTIVE DIRECTOR

OF ABLE US WOULD BE THE CONTINENTAL OFFICE UNDER ABLE

INTERNATIONAL. THE DSA IS THE DIRECTOR OF SPECIAL

AFFAIRS. I DON'T KNOW WHICH ORGANIZATION SHE WOULD BE

REFERRING TO. THE OFFICE, OS STANDS FOR THE OFFICE OF

SPECIAL AFFAIRS. THAT'S WITH THE CHURCH OF SCIENTOLOGY

AND IT HAS MANY, MANY, IT'S A LARGE ORGANIZATION. THERE

IS NO -- THIS ROUTING DOESN'T MAKE ANY SENSE SO THE LAST

TWO ITEMS I DON'T KNOW WHERE OR WHY MARY WOULD HAVE,

WOULD HAVE DONE THAT OR TO WHOM SHE SPECIFICALLY

REFERRED IT. THAT'S THE BEST I COULD EXPLAIN.

Q SO YOU DON'T HAVE ANY EXPLANATION FOR WHY THIS

REPORT WAS SENT TO THE OFFICE OF SPECIAL AFFAIRS AT THE

CHURCH OF SCIENTOLOGY?

A YOU WOULD HAVE TO ASK MARY ON THAT. I DON'T

KNOW.

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THIS.

Q WELL, I'M ASKING YOU.

A NO, I DON'T KNOW.

Q ARE ANY OF THE DOCUMENTS -- LET ME ASK YOU

ARE YOU AWARE OF ANY DOCUMENTS IN THIS CASE

THAT HAVE BEEN SENT TO ANY INSTITUTION WITHIN THE CHURCH

OF SCIENTOLOGY?

A NO.

Q NOTHING?

A NO.

Q ALL RIGHT.

WHAT ABOUT ABLE?

A I'M AWARE OF THE, OF GWENDA'S OR THE REPORT ON

THE LEGAL RUDIMENTS INSPECTION AFTER PATRICK DESMOND'S

DEATH, A REPORT OF WHICH WAS SENT BY OUR DIRECTOR OF

LEGAL AFFAIRS TO THE DIRECTOR OF CORPORATE AFFAIRS AT

ABLE, AND GWENDA RESPONDED WITH SOME REMARKS ON THAT.

Q WHY WOULD -- WHY DOES WHY DO

DOCUMENTS -- WHY ARE THEY SENT TO ABLE, I GUESS, IS WHAT

I'M TRYING TO ASK YOU. WHAT'S THE RELATIONSHIP BETWEEN

ABLE AND INTERNATIONAL AND WHAT DOES ABLE DO AS OPPOSED

TO INTERNATIONAL?

A ABLE INTERNATIONAL LICENSES NARCONON

INTERNATIONAL SO THEY OWN THE TRADEMARKS AND THEN THEY

LICENSE US SO THEY ARE RESPONSIBLE FOR OUR PROPER USE OF

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THE TRADEMARKS. THEY ALSO HAVE SEVERAL OTHER

ORGANIZATIONS THAT ARE USING SECULAR USES OF

MR. HUBBARD'S METHODOLOGY. APPLIED SCHOLASTICS REFERS

TO LEARNING AND STUDY METHODOLOGY, CRIMINON IS AN

ORGANIZATION THAT DEALS WITH INMATES IN PRISON AND

INMATES RELEASED FROM PRISON AND AN ORGANIZATION CALLED

THE WAY TO HAPPINESS FOUNDATION. SO THEY LICENSE EACH

OF THOSE.

AS REGARDS THEIR LICENSING NARCONON, THEIR

RELATIONSHIP WITH US IS THE SAME AS OURS TO THE CENTERS.

THEY'RE INTERESTED IN OUR CORRECT USE OF THE TRADEMARK

AND PROTECTION OF IT AND SO FORTH. THEREFORE, IF THERE

IS A SERIOUS LEGAL SITUATION IT WOULD BE APPROPRIATE TO

INFORM THEM THAT SOMETHING HAD COME UP, YOU KNOW, AND TO

INFORM THEM ABOUT IT LIKE THE FACTUAL -- AFTER A LEGAL

RUDIMENTS INSPECTION WHAT WERE THE FACTS THAT WERE

OBSERVED AND THAT WAS SO CLAUDIA WAS COMMUNICATING IN

THIS CASE TO HER COUNTERPART IN ABLE INTERNATIONAL, THE

DIRECTOR OF CORPORATE AFFAIRS.

Q 23. DO YOU HAVE 23 IN FRONT OF YOU THERE? I

THINK IT'S WITHIN THAT GROUP OF DOCUMENTS.

A YES.

Q THAT'S THE LETTER YOU WERE REFERRING TO, TO

GWENDA?

A I KNOW THERE WAS ALSO A -- CLAUDIA SENT A

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LETTER OR I'M NOT SURE IF IT WAS CLAUDIA OR BARBARA BUT

THERE'S ANOTHER DOCUMENT THAT SHOWS THE LEGAL RUDIMENTS

INSPECTION AND THE HANDLINGS THEREOF WERE SENT TO

GWENDA. THIS LETTER WOULD ALSO -- THIS WAS WRITTEN BY

THE DEPUTY DIRECTOR ASSISTANT.

Q HOW DO YOU KNOW THAT?

A HOW DO I KNOW WHAT?

Q THAT THIS WAS WRITTEN BY THE DEPUTY DIRECTOR?

IT DOESN'T SAY ANYTHING ON HERE ABOUT IT.

A ON THE TOP LEFT, THE NORMAL ROUTING, THE PERSON

THAT SOMETHING IS BEING SENT TO IS ON THE TOP.

Q GOT IT.

A THE PERSON ON THE BOTTOM IS THE PERSON SENDING

IT.

Q ALL RIGHT.

IN THIS LETTER BARBARA DUNN TELLS GWENDA THAT

SHE HAD INFORMED MARY THAT SHE NEEDS TO GO SPEAK TO THE

DBA AT THE ORG TO GET A HIGH PROFILE LAWYER.


A I'M NOT SURE WHERE.

Q THIRD

A THIRD PARAGRAPH FROM THE BOTTOM?

Q RIGHT.

A YES.

Q BARBARA DUNN WORKS FOR NARCONON INTERNATIONAL,

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CORRECT?

A YES.

Q AND SHE GOES AND INVESTIGATES THE DEATH OF

PATRICK DESMOND OR SHE GOES DOWN -- WELL, SHE GOES TO

INVESTIGATE, IN PART, THE DEATH OF PATRICK DESMOND,

DOESN'T SHE?

A THE LEGAL RUDIMENTS INSPECTION WAS SPECIFICALLY

CALLED FOR AFTER THAT TO, TO VERIFY WHAT WAS THE STATUS

OF THE ORGANIZATION AT THAT TIME.

Q ALL RIGHT.

WELL, SHE WRITES

A IT'S NOT OUR PLACE TO INVESTIGATE IT BUT IT IS

OUR PLACE TO SEE ARE THE LEGAL RUDIMENTS, IN FACT, IN.

Q SHE GENERATES A LETTER THAT CERTAINLY APPEARS

TO BE A SUMMARY OF WHAT SHE HAS LEARNED WHEN SHE GOES

DOWN AND TALKS TO MISS RIESER, RIGHT?

A YES, UH-HUH.

Q WHETHER YOU WANT TO CALL IT AN INVESTIGATION OR

NOT, SHE'S DOING A NARRATIVE HERE ABOUT THE FACTUAL

EVENTS SURROUNDING PATRICK'S DEATH.

A YES.

Q I DON'T SEE ANYTHING IN HERE ABOUT BEING A

LEGAL RUDIMENTS CHECK. IS THAT, YOU WOULD AGREE WITH ME

THAT'S SOMETHING DIFFERENT FROM WHAT THIS IS?

A YES. I BELIEVE, CONCURRENT WITH THIS, I'M NOT

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SURE THE TIMING OF THIS LETTER AND HER LEGAL RUDIMENTS

INSPECTION. I PRESUME IT WAS WHILE SHE WAS DOING THE

LEGAL RUDIMENTS INSPECTION THAT SHE GATHERED THIS DATA.

Q OKAY.

WELL, SHE SENDS THIS LETTER ON JUNE 12, 2008,

SEVERAL DAYS AFTER PATRICK'S DEATH OR A DAY AFTER HIS

DEATH, RIGHT?

A YES. SO I BELIEVE THAT A LEGAL RUDIMENTS

INSPECTION WAS PROBABLY ONGOING AT THAT TIME.

Q AND THEN SHE REFERS MARY TO THE DSA AT THE ORG

WHICH IS THE DEPARTMENT OF SPECIAL AFFAIRS AT PRESUMABLY

THE ATLANTA ORG.

A WHAT I SEE IT SAYS HERE IS THAT MARY TOLD HER

THAT SHE WAS ON HER WAY TO SPEAK TO THE DSA.

Q OKAY.

A SHE ACTUALLY ASKS MARY TO CONTACT HER ATTORNEY.

Q OKAY.

SO SHE, MARY, IS SAYING I'M GOING TO GO TO THE

ORG TO GET A REFERRAL FOR SOMEONE WHO CAN HANDLE THIS

MATTER, RIGHT?

A YEAH. TO GET A REFERRAL TO A COMPETENT

ATTORNEY, IT SOUNDS LIKE. SHE SAYS THAT THE ATTORNEY

THAT SHE HAD AT THE TIME WAS A LICENSING SPECIALIST SO

IT WOULD BE APPROPRIATE TO LOOK FOR AN ATTORNEY

COMPETENT IN THIS AREA.

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Q ALL RIGHT.

BARBARA DUNN COMES IN AND DOES THE LEGAL

RUDIMENTS THAT YOU'VE BEEN TALKING ABOUT. THE TECH

INSPECTION IS DONE BY -- HELP ME.

A JETTE MAC GREGOR.

Q JETTE MAC GREGOR. AND THEN THERE'S REFERENCE

TO MIKE ST. AMAND.

A YES.

Q DID MR. ST. AMAND COME TO GEORGIA AND DO ANY

KIND OF INSPECTION OR REVIEW OF THE FACILITY?

A I ACTUALLY DON'T KNOW IF THAT -- I DON'T HAVE

ANY KNOWLEDGE OF THAT, THAT I REMEMBER. IF IT'S IN A

DOCUMENT AND I'M FORGETTING IT. I DON'T BELIEVE SO.

Q AND THEN MR. ST. AMAND APPARENTLY GIVES

SOMETHING CALLED A HAT ON HOW TO HANDLE THE DEATH OF A

STUDENT TO MARY.

A PER THIS I UNDERSTAND THAT THAT OCCURRED, YES.

Q DO YOU HAVE THAT DOCUMENT OR DOES INTERNATIONAL

HAVE THAT DOCUMENT?

A I DON'T HAVE THAT DOCUMENT. I HEARD CLAUDIA -

Q "I" BEING INTERNATIONAL?

A OKAY. AGAIN, I KEEP FORGETTING. I PERSONALLY

DON'T HAVE KNOWLEDGE OF IT AND HAVE NOT SEEN IT. I

UNDERSTAND THAT CLAUDIA SAID THAT SHE HAD SEEN THIS.

THIS WOULD BE AN ADVICE WRITTEN UP BY MR. ST. AMAND WHO

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IS THE DIRECTOR OF LEGAL AFFAIRS OF NARCONON ARROWHEAD

ON, ADVICE ON PROTOCOL TO TAKE IN SUCH AN EVENT AS THIS.

Q WELL, DOES NARCONON INTERNATIONAL HAVE THAT

DOCUMENT?

A I DON'T KNOW IF CLAUDIA HAS IT IN HER FILES OR

NOT.

Q WELL, SHE'S AT LEAST REVIEWED IT. I THINK

THAT'S WHAT SHE SAID.

A I THINK SHE SAID THAT SHE HAD REVIEWED IT SO IT

MAY HAVE BEEN AN E-MAIL. I DON'T KNOW IF IT'S A COUPLE

PARAGRAPHS OR WHAT.

Q ALL RIGHT.

A IT'S JUST ADVICE.

Q ANY OTHER PERSON ON BEHALF OF NARCONON

INTERNATIONAL DO, HAS ANY OTHER PERSON OTHER THAN THE

ONES THAT YOU AND I HAVE TALKED ABOUT, BARBARA DUNN,

JETTE MAC GREGOR AND POSSIBLY MR. ST. AMAND, IS THERE

ANY OTHER PERSON THAT CAME IN AND LOOKED INTO THE

CIRCUMSTANCES OF PATRICK'S DEATH IN ANY WAY?

A FROM NARCONON INTERNATIONAL?

Q WELL, ANYBODY THAT YOU'RE AWARE OF.

A I, AS I SAY, NARCONON EASTERN US WHICH IS THE

CONTINENTAL OFFICE ABOVE THEM HAS TAKEN A MORE ACTIVE

ROLE BECAUSE IT'S ONE OF THE SPECIFIC CENTERS UNDER

THEIR PURVIEW. I DON'T KNOW ABOUT INVESTIGATING BUT I

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KNOW THAT THEY WOULD BE INTERESTED IN MAINTAINING

BECAUSE THE PROGRAM CONTINUES. THERE ARE OTHER STUDENTS

THERE AND SO FORTH. THEY'D BE INTERESTED IN SEEING THAT

THE HIGHEST QUALITY DELIVERY IS BEING DONE AND THAT THE,

THAT THESE, ALL OF THESE ISSUES ARE BEING ADDRESSED.

Q I UNDERSTAND ALL THAT.

I WAS ASKING YOU JUST SPECIFICALLY, ARE YOU

AWARE OF ANY PERSON WHO CAME IN AND DID AN INVESTIGATION

OTHER THAN THE ONES THAT WE'VE TALKED ABOUT?

A NO. POSSIBLY ISAAC FROM NARCONON EASTERN US.

Q AND YOU'RE JUST SAYING THAT BECAUSE YOU THINK

THAT'S SOMETHING HE WOULD WANT TO BE INVOLVED IN, NOT

BECAUSE YOU HAVE ANY PARTICULAR KNOWLEDGE ABOUT THAT

HAPPENING?

A IT WOULD FALL UNDER HIS FUNCTION AT NARCONON

EASTERN US WHICH IS THE VERY SAME AS YARKO'S AT NARCONON

INTERNATIONAL.

Q DID YOU LOOK INTO THAT BEFORE YOUR DEPOSITION

HERE TODAY?

A I SAW THAT THERE WERE MANY LETTERS OR E-MAILS

FROM ISAAC WHO WAS COMMUNICATING THAT HE WAS

KNOWLEDGEABLE IN WORKING WITH MARY ON MANY, MANY POINTS.

WHETHER HE PHYSICALLY VISITED THERE OR NOT, I DON'T

KNOW. I KNOW HE WAS DOING, HE WAS WORKING WITH HER AS

WELL AS SOMETIMES EARLIER RESPONDING TO YARKO, THE

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NARCONON INTERNATIONAL'S DIRECTOR OF PRODUCTION REQUEST

TO LOOK INTO THINGS LIKE A COMPLAINT OR SOMETHING,

so ....

Q I BELIEVE YESTERDAY YARKO TESTIFIED THAT THERE

WERE ANNUAL REVIEWS OF THE INDIVIDUAL FACILITIES.

A I THINK HE SAID NOT NECESSARILY.

Q OKAY.

WELL, THAT'S WHAT I'M TRYING TO GET TO.

A UH-HUH.

Q IS THAT THE GENERAL PRACTICE?

A NO, NOT TO DO AN ANNUAL REVIEW. IT DEPENDS

UPON THE SIZE OF THE FACILITY AND THE CIRCUMSTANCES.

Q IN TERMS OF GEORGIA, I THINK YOU AND I HAVE

TALKED ABOUT THOSE. YOU TALKED ABOUT THE TECH

INSPECTION AND THE LEGAL RUDIMENTS INSPECTION.

A THERE WERE TWO LEGAL RUDIMENTS INSPECTIONS.

Q ALL RIGHT.

GOING BACK TO EXHIBIT ATTACHMENT A ON THE

BUSINESS ASSOCIATE DOCUMENT.

A WHICH IS -

MR. ROOT: 14.

THE WITNESS: UH-HUH.

Q BY MR. HARRIS: ARE THERE ANY ONSITE HEALTH AND

SAFETY INSPECTIONS THAT WERE CONDUCTED BY NARCONON

INTERNATIONAL OR ANYONE ON NARCONON INTERNATIONAL'S

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BEHALF THAT YOU AND I HAVE NOT TALKED ABOUT?

A NOT SPECIFICALLY BY NARCONON INTERNATIONAL

PERSONNEL.

Q WHEN YOU --

A AS I SAY, NARCONON EASTERN US ALSO IS

PERFORMING THIS FUNCTION, SO THERE MAY HAVE BEEN THERE.

THIS WOULD HAVE BEEN ALSO PART OF TRADEMARK INSPECTION

AND PRESERVING THE INTEGRITY OF THE TRADEMARK. FOR

NARCONON INTERNATIONAL, OUR ORGANIZATION, I HAVE TOLD

YOU THE ONES THAT I KNOW ABOUT AND WE HAVE A RECORD OF.

Q AND THAT'S WHY I ASKED YOU IF IT WAS DONE ON

NARCONON INTERNATIONAL'S BEHALF AND I THINK YOU'VE TOLD

ME NUMEROUS TIMES THAT EAST US MAY HAVE DONE AN

INSPECTION AND I THINK YOU'VE TOLD ME YOU'D BE

SPECULATING ON THAT BECAUSE YOU DON'T KNOW.

A NO. BUT WHAT I DO KNOW IS THAT THERE ARE A

NUMBER OF PLACES WHERE YARKO HAS ASKED ISAAC IN

PARTICULAR WHO IS HIS COUNTER PART IN NARCONON EASTERN

US TO LOOK INTO DIFFERENT THINGS.

Q ALL RIGHT.

A SO WHETHER HE WOULD DO IT FROM A DISTANCE, I

COULD NOT SAY IF HE HAD DONE IT DIRECTLY.

Q NO. 2, "REVIEW OF CASE FOLDERS OF THE

FACILITY'S CLIENTS TO VERIFY STANDARDS OF TECHNOLOGY AND

APPLICATION THEREOF."

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A UH-HUH.

Q HAVE YOU IDENTIFIED FOR ME ALL OF THE

INSPECTIONS THAT WERE DONE RELATED TO NO. 2?

A THE ONES THAT I'M AWARE OF ARE THE ONES THAT

JETTE MAC GREGOR DID WHEN SHE WENT. SHE MENTIONS IT IN

HER REPORT. THERE MAY HAVE BEEN EARLIER FOLDERS THAT

WERE SENT TO NARCONON INTERNATIONAL IF THERE WAS A

QUESTION ABOUT THEM. WE WOULDN'T KEEP A RECORD OF A

SPECIFIC FOLDER BEING REVIEWED. THEY CAN SOMETIMES

PER -- BE SENT TO NARCONON INTERNATIONAL AND THEN ARE

RETURNED.

Q DOES THAT HAPPEN? I MEAN, THE FOLDERS, IS THAT

HOW A TECH REVIEW CAN ACTUALLY TAKE PLACE THAT THE

INTERNATIONAL WILL REQUEST THE INDIVIDUAL CENTER TO SEND

UP SOME FOLDERS FOR SOME KIND OF AUDIT OF THE FOLDERS?

A THEY CAN REQUEST A SPECIFIC PERSON'S FOLDER IF

THEY'VE HEARD SOMETHING OR -- WE DON'T ASK FOR A RANDOM

SET. IT'S USUALLY A SPECIFIC PERSON IF THERE'S BEEN

SOME KIND OF A REPORT.

Q NO. 3, THE REVIEW OF PERSONNEL FILES OF THE

PERSONNEL AND TRAINEES AT NARCONON OF GEORGIA.

WHEN DID THAT TAKE PLACE?

A WITH THE LEGAL RUDIMENTS INSPECTION THAT

CLAUDIA DID.

Q ALL RIGHT.

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AND THEN NO. 4, "CORRECTION OF THE FACILITY'S

PERSONNEL REGARDING ANY NONOPTIMUM SITUATIONS THAT ARE

DETERMINED TO EXIST."

ANYTHING THAT WE HAVEN'T DISCUSSED WHERE

NARCONON INTERNATIONAL HAS COME IN AND CORRECTED

FACILITY PERSONNEL REGARDING NONOPTIMUM SITUATIONS THAT

ARE DETERMINED TO EXIST?

A THERE HAVE BEEN A NUMBER OF INSTANCES OF, WHERE

THERE HAVE BEEN COMPLAINTS OR LETTERS THAT WERE RECEIVED

WHERE YARKO ASKED ISAAC TO LOOK INTO THIS AND THERE MAY

HAVE BEEN SOME DIRECT REQUESTS, AS I REMEMBER, TO MARY

ASKING ABOUT SOMETHING. SO THERE WOULD HAVE ON A LONG

DISTANCE COMMUNICATION LINE THERE WOULD HAVE BEEN A

REPORT AND POSSIBLE CORRECTION.

Q IS NARCONON OF GEORGIA ONE OF YOUR BEST

NARCONON CENTERS?

A WELL, WE TRY TO HAVE THEM ALL BE THE BEST.

Q THAT'S NOT WHAT I ASKED.

A WELL, IT'S LIKE WHICH IS YOUR FAVORITE CHILD.

Q WELL, I MEAN, IS NARCONON OF GEORGIA A PROBLEM

CHILD, SINCE YOU USED THE WORD "CHILD"?

A NO, I WOULD NOT SAY SO.

Q YOU'VE HAD, THERE ARE A NUMBER OF DOCUMENTS

HERE WHERE NARCONON OF GEORGIA HAS REPEATEDLY FALLEN

BEHIND ON ITS LICENSE PAYMENTS TO INTERNATIONAL, RIGHT?

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A YES.

Q AND THAT IS A PROBLEM THAT'S BEEN GOING ON WITH

NARCONON OF GEORGIA FOR A NUMBER OF YEARS, RIGHT?

A IT HAS IMPROVED AND THEN FALLEN BACK. IT HAS

TO DO WITH THEIR FINANCES AND SO FORTH. THEY'VE

MAINTAINED GOOD RELATIONS AND HAVE MADE PAYMENTS. IT'S

NOT OUR SENIOR, OUR SENIOR CONCERN, AND SO NARCONON OF

GEORGIA HAS TAKEN RESPONSIBILITY FOR THAT. IT'S SIMPLY

ONE, ONE POINT. HAS TO DO WITH THE COSTS OF HER PROGRAM

AND, YOU KNOW, DOES SHE HAVE THE MONEY TO SEND HER

LICENSE FEES IN.

Q WELL, SO DO YOU PUT IT UP THERE IN A CATEGORY

OF ONE OF YOUR TOP PROGRAMS?

A WE HAVE BEEN SATISFIED WITH NARCONON OF

GEORGIA'S DELIVERY TO THEIR STUDENTS AND SAVING OF LIVES

AND DELIVERING EFFECTIVE DRUG REHABILITATION SERVICES

AND WHERE THEY HAD TROUBLES WE'VE BEEN HAPPY TO WORK

WITH THEM, HELP THEM TO SOLVE THEIR OWN, THEIR OWN

PROBLEMS. THE CENTER IS AN INDEPENDENT CENTER. THERE

ARE MANY EXAMPLES OF STELLAR PERSONAL RESULTS THAT

NARCONON OF GEORGIA HAS GOTTEN AND THAT'S, THAT'S OUR

SENIOR STATISTIC IS DRUG-FREE LIVES SO NARCONON OF

GEORGIA HAS BEEN PRODUCING THOSE ON A REGULAR BASIS AND

WE'RE HAPPY WITH THAT.

Q EXHIBIT NO. 18, IF YOU COULD PULL THAT ONE OUT.

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Q

A

Q

A

UH-HUH.

SECOND PAGE OF THAT DOCUMENT.

UH-HUH.

THAT WAS COPIED TO INTERNATIONAL, CORRECT?

WHICH ONE ARE YOU LOOKING AT HERE? I GUESS

6 BOTH OF THEM WERE.

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Q ALL RIGHT.

IT SAYS "95 PERCENT OF ALL PARENTS, FAMILIES

AND 2-D COMPLAINTS CONCERN HOUSING AND ARE DIRECTED TO

GEORGIA EAST US AND INTERNATIONAL."

DO YOU SEE THAT?

A YES.

Q SO IT'S FAIR TO SAY THAT THERE HAD BEEN A

14 NUMBER OF COMPLAINTS TO INTERNATIONAL ABOUT GEORGIA'S

15 HOUSING SITUATION?

A UH-HUH. 12:51:09 16

12:51:12 17 Q IN FACT, 95 PERCENT OF IT APPARENTLY RELATES TO

18 HOUSING, THE COMPLAINTS THAT INTERNATIONAL IS GETTING.

MR. ROOT: OBJECT TO THE FORM. 12:51:15 19

12:51:18 20 THE WITNESS: AND IT SAYS AND GEORGIA AND NARCONON

21 EASTERN US ARE GETTING SOME OF THEM.

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Q BY MR. HARRIS: I SEE WHAT YOU MEAN. OKAY.

BUT 95, WHAT HE'S SAYING HERE IS THAT 95

PERCENT OF THESE COMPLAINTS RELATE TO HOUSING.

A THAT'S WHAT ISAAC IS SAYING, YES.

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Q OKAY.

THERE HAVE CLEARLY BEEN A NUMBER OF PROBLEMS

WITH THE HOUSING SITUATION AT NARCONON OF GEORGIA.

A YES.

Q THAT NARCONON INTERNATIONAL IS FULLY AWARE OF.

A UH-HUH.

Q AND THERE CONTINUE TO BE ISSUES WITH THE

HOUSING, RIGHT?

MR. ROOT: OBJECT TO FORM.

THE WITNESS: I BELIEVE THOSE ISSUES HAVE REDUCED

CONSIDERABLY.


BUT THERE CONTINUE TO BE ISSUES?

A I DON'T THINK THEY ARE SUBSTANTIAL.

Q ARE YOU STILL SATISFIED WITH THEIR PERFORMANCE?

A THAT WITH THE EFFORTS THAT MARY RIESER AND HER

STAFF HAVE TAKEN TO, YOU KNOW, FIND ALTERNATE HOUSING

THAT IS WHERE THESE ISSUES ARE NOT COMING UP AND

THEY'RE CONTINUING, YOU KNOW, GOOD DELIVERY TO THEIR

STUDENTS, YES.

Q AND THERE WERE, THERE WAS A BOARD OF

INVESTIGATION THAT YOU AND I HAVE TALKED ABOUT

EXTENSIVELY, LOOKING INTO THE PROBLEMS IN HOUSING,

RIGHT?

A AND OTHER PROBLEMS, YES.

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Q AND OTHER PROBLEMS.

AND THERE WAS PATRICK DESMOND'S DEATH, RIGHT?

A YES.

Q AND AFTER ALL THAT, RATHER THAN PULL THE

LICENSE FOR NARCONON OF GEORGIA, NARCONON INTERNATIONAL

ACTUALLY COMMENDED THEM, RIGHT?

A I WOULD HAVE TO SEE WHEN AND FOR WHAT THEY WERE

COMMENDED.

Q (INDICATING) .

MR. ROOT: CAN I TAKE A LOOK AT THAT?

MR. HARRIS: SURE. I'VE ONLY GOT ONE OF THOSE,

DAVE. I'M SORRY.

THE WITNESS: LET ME READ IT.

SO THIS WAS A RECOGNITION AND A PRODUCTION GAME

THAT ALL OF THE CENTERS PLAY AND IN THE RECOGNITION OF

THEIR DOING WELL IN THIS GAME OF PRODUCTION AND DELIVERY

WHICH WAS IN SEPTEMBER OF 2008.

Q BY MR. HARRIS: RIGHT.

A IT'S NOT INAPPROPRIATE THAT THE PERSON WHO IS

MONITORING THAT GAME WOULD SEND A COMMENDATION TO THE

PERSON THAT RECEIVED IT, THE CENTER THAT ACHIEVED THAT.

Q THIS IS EXHIBIT NO. 28 THAT I JUST MARKED.

I'M JUST SAYING AFTER THE BOARD OF

INVESTIGATION, AFTER ALL THE EVENTS THAT YOU AND I HAVE

BEEN DISCUSSING IN SOME DETAIL AND AFTER, ULTIMATELY,

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PATRICK DESMOND'S DEATH, NARCONON INTERNATIONAL DIDN'T

PULL THE LICENSE OF NARCONON OF GEORGIA; IN FACT, WHAT

IT DID WAS COMMEND THEM FOR THEIR PRODUCTION.


THE WITNESS: BECAUSE THERE WAS PRODUCTION, THERE

WAS PRODUCTION IN THE SAVING OF LIVES AND THAT'S WHAT

WE'RE INTERESTED IN IS CONTINUING TO SAVE LIVES.

Q BY MR. HARRIS: I THINK MY QUESTION WAS VERY

SIMPLE.

AFTER THE THINGS THAT YOU AND I HAVE BEEN

TALKING ABOUT, ABOUT HOUSING --

A UH-HUH.

Q -- AND AFTER MR. DESMOND'S DEATH, NARCONON

INTERNATIONAL DIDN'T COME IN AND PULL THE LICENSE OF

NARCONON OF GEORGIA, IT COMMENDED THE FACILITY AND ISSUE

ON PAGE OR EXHIBIT 28, FOR THEIR PRODUCTION.

A THE STAFF MEMBER DID FOR THE SPECIFIC GAME OF

PRODUCTION AND EXPANSION GAME THAT THEY WERE PLAYING AT

THE TIME.

(REPORTER CLARIFICATION) .

MR. ROOT: SO WHAT WE JUST REFERRED TO AS 28 IS

BEING REMARKED AS 29?

Ill

Ill

MR. HARRIS: CORRECT.

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ATTACHED HERETO) .

Q BY MR. HARRIS: AND SIMILARLY, IN AUGUST OF

2008, JUST SEVERAL MONTHS AFTER PATRICK'S DEATH,

NARCONON OF GEORGIA WAS COMMENDED FOR ITS WORK IN

RECRUITING PEOPLE ON THE INTERNET?

A NOT RECRUITING PEOPLE BUT PRODUCING

DOCUMENTATION OF THE PROGRAM ON THE INTERNET WHICH WAS

SOMETHING THAT WE WERE ASKING ALL OF THE CENTERS AROUND

THE WORLD TO DO BECAUSE THE INTERNET IS THE WORLD OF,

THAT'S THE WORLD OF COMMUNICATION NOW, SO THE PERSON IN

NARCONON INTERNATIONAL IS RESPONSIBLE THAT, FOR OUR

CENTER, THEN COMMENDED MARY FOR HER ACTION SHE WAS

TAKING IN THIS REGARD FOR HER CENTER FOR THAT SPECIFIC

DELIVERY.

Q WELL, I'M CONFUSED BECAUSE I THOUGHT EARLIER

YOU TOLD ME THAT THE INTERNET COPY OF THE WEBSITES

WASN'T ROUTINELY REVIEWED BY INTERNATIONAL.

A I DON'T KNOW ABOUT THE SPECIFIC TEXT. WHAT

PATRICK IS REFERRING TO HERE IS YOUTUBE VIDEOS, BLOGS;

IN OTHER WORDS, YOU KNOW, THE WORLD WHICH I'M NOT WELL

APPRISED OF BUT THE WORLD OF SOCIAL MEDIA AND USING THE

INTERNET TO COMMUNICATE. THAT'S WHAT IS BEING REFERRED

TO HERE. IT SAYS "BLOGS, YOUTUBES, ETC." ONLINE SOCIAL

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NETWORKS.

Q DO YOU KNOW HOW PATRICK DESMOND'S PARENTS FOUND


A NO, I DON'T.

MS. RICHARDSON: JEFF, WHAT WAS THAT LAST EXHIBIT?

I GOT CONFUSED WITH THE RENUMBERING. IS THAT 29?

MR. ROOT: 30.

THE WITNESS: THIS LAST ONE IS 30.

MS. RICHARDSON: 30. OKAY. I DON'T KNOW IF I EVER

HEARD IT. THANK YOU. SORRY.



ATTACHED HERETO) .

Q BY MR. HARRIS: LET'S TALK ABOUT SOME REPORTS.

THERE ARE WEEKLY STATISTICAL REPORTS THAT ARE GENERATED

BY THE INDIVIDUAL CENTERS AND SENT TO NARCONON OF

GEORGIA, CORRECT?

A STATISTICAL REPORTS, YES.

Q AND THOSE ARE GENERATED AND SENT TO

THE WELL, THEY'RE GENERATED AND THEY'RE, I BELIEVE,

TURNED IN EVERY THURSDAY AFTERNOON?

A UH-HUH. THAT'S WHEN WE CONCLUDE OUR

STATISTICAL WEEK.

Q OKAY.

AND THEN THE STATISTICS ARE COMPILED AND THE

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CENTER IS INFORMED WHETHER THEY ARE EITHER UP STAT OR

DOWN STAT?

A NO. THAT'S SOMETHING FOR THEM TO DETERMINE FOR

THEMSELVES. YOU DON'T LOOK AT A PARTICULAR STAT, YOU

LOOK AT A TREND OF A STAT. SO THEY USE IT FOR THEIR OWN

MANAGEMENT AND WE USE IT TO ADD IN TO ALL THE STATISTICS

OF THE CENTERS AROUND THE WORLD TO SEE WHAT IS THE

OVERALL DELIVERY OF THE NARCONON PROGRAM, DIFFERENT

CONTINENTS AND ON A WORLDWIDE BASIS.

Q ALL RIGHT.

WELL, THEY COMPILE THEIR STATISTICS AND THEY

SEND THEM IN TO INTERNATIONAL AND INTERNATIONAL DOES

WHATEVER IT IS IT DOES WITH THEM THAT YOU'VE EXPLAINED,

RIGHT?

A UH-HUH.

Q IN ADDITION, THERE ARE EXECUTIVE DIRECTOR

WEEKLY REPORTS THAT ARE SUBMITTED TO INTERNATIONAL FROM

THE INDIVIDUAL CENTERS?

A SOMETIMES.

Q WHAT DO YOU MEAN "SOMETIMES"?

A IT'S NOT A REQUIREMENT THAT THEY COME IN EACH

WEEK. SOMETIMES A CENTER SENDS THEM, SOMETIMES THEY

DON'T.

Q AND HOW MANY TIMES DID NARCONON OF GEORGIA FAIL

TO SEND IN ITS WEEKLY REPORT TO NARCONON INTERNATIONAL?

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A IT WOULDN'T BE A MATTER OF FAILING TO SEND IT

IN. IT WOULD BE A MATTER OF SHE SENT IT WHEN SHE FELT

IT WAS APPROPRIATE.

Q HOW MANY TIMES DID THEY NOT SEND IT IN, SIR?

A I DON'T KNOW. I HAVEN'T COUNTED THEM UP.

PROBABLY 50 PERCENT OF THE TIME.

Q ALL RIGHT.

AND SAME QUESTION WITH RESPECT TO THEIR

STATISTICS.

A THE STATISTICS ARE ACTUALLY REQUIRED ON A

WEEKLY BASIS.

Q WHY ARE THEY REQUIRED?

A BECAUSE THIS IS WHAT NARCONON INTERNATIONAL

USES TO EVALUATE THE EVOLVING PRODUCTION AND DEVELOPMENT

OF THE NARCONON PROGRAM EVERYWHERE IN THE WORLD. WE

OPERATE ACCORDING TO STATISTICS FIRST.

Q WHAT IS A WEEKLY BATTLE PLAN?

A THAT IS WHEN A STAFF MEMBER -- IT'S IN THE

BASIC STAFF HAT. IT'S WHEN A STAFF MEMBER WRITES UP

THIS IS WHAT I'M GOING TO DO NEXT WEEK OR NEXT MONTH.

USUALLY, IT'S ON A WEEKLY BASIS.

Q AND THERE ARE WEEKLY BATTLE PLANS THAT ARE SENT

FROM THE INDIVIDUAL CENTERS TO INTERNATIONAL?

A NOT ALWAYS SENT. AGAIN, THESE --AGAIN, IT

WOULD BE A MATTER OF SOMETIMES THE EXECUTIVE DIRECTOR

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WOULD DO IT, THE EXECUTIVE DIRECTOR WOULD REQUIRE THESE

OF THEIR JUNIOR STAFF MEMBERS, SO WE WOULD SOMETIMES

RECEIVE THAT, SOMETIMES NOT.

Q YOU SAID NARCONON OF GEORGIA -- WELL, IS THE

EXPECTATION THAT THE REPORT IS SENT IN BY THE EXECUTIVE

DIRECTOR TO NARCONON INTERNATIONAL EVERY WEEK?

A NO, NOT NECESSARILY EVERY WEEK. THE

STATISTICS, YES. THOSE WE MUST HAVE.

Q WHY DO THEY CALL IT A WEEKLY REPORT, THEN, SIR?

A BECAUSE THAT WOULD BE A REPORT OF WHAT OCCURRED

THAT WEEK.

Q OKAY.

SO THERE'S NO EXPECTATION, EVEN THOUGH THIS

DOCUMENT THAT I'VE GOT HERE IN FRONT OF ME IS CALLED A

WEEKLY REPORT, THAT THE EXECUTIVE DIRECTOR REPORT EACH

WEEK?

A THAT THEY HAVE TO SEND IT IN? NO.

Q WHAT DO THEY DO WITH IT IF THEY DON'T SEND IT

IN? THEY JUST DO A WEEKLY REPORT AND KEEP IT FOR

THEMSELVES?

A THEY MIGHT DO THAT OR NOT WRITE IT. THE POINT

IS, IF THERE'S SOMETHING IMPORTANT THAT THE EXECUTIVE

DIRECTOR WISHES TO REPORT THAT WEEK THEN THEY'LL WRITE

IT UP. OBVIOUSLY, THERE'S A CONTINUING FLOW OF

COMMUNICATION AT OTHER TIMES BUT THIS IS AT SOME TIME,

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YOU KNOW, AN EXECUTIVE DIRECTOR WILL WRITE HERE'S THE

WEEKLY REPORT, THESE AND THIS AND THIS AND THIS

OCCURRED.

Q THE WEEKLY REPORTS THAT WERE SENT FROM NARCONON

OF GEORGIA TO NARCONON INTERNATIONAL BEGINNING IN

JANUARY OF 2008, HAVE YOU REVIEWED THOSE REPORTS?

A I DID REVIEW THEM CASUALLY, NOT STUDYING THEM

INTIMATELY, BUT I SAW ALL OF THOSE THAT WERE PULLED FROM

OUR FILES.

Q AND THOSE WEEKLY REPORTS AT A NUMBER OF

DIFFERENT TIMES MENTION ISSUES THAT MISS RIESER IS

HAVING WITH HOUSING, CORRECT?

A I REMEMBER THAT SHE MENTIONED IT A NUMBER OF

TIMES, YES.


Q BY MR. HARRIS: SO IN THE YEAR STARTING JANUARY

BEFORE PATRICK'S DEATH, THE WEEKLY REPORTS THAT ARE

COMING IN, YOU AGREE WITH ME THAT MISS RIESER IS TELLING

INTERNATIONAL THAT SHE'S HAVING CONCERNS OR ISSUES WITH

HOUSING.


THE WITNESS: SHE ALSO MENTIONS AT THE SAME TIME

WHAT SHE'S DOING ABOUT IT.

Q BY MR. HARRIS: WELL, THAT'S NOT WHAT I ASKED

BUT WE CAN TALK ABOUT THAT.

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A BUT THAT WOULD RELATE. IN OTHER WORDS, SHE

WOULD SAY THIS IS THE PROBLEM AND THIS IS WHAT I'M DOING

ABOUT IT. THAT WOULD BE PART OF THE FORMAT OF A WEEKLY

REPORT.

Q EXHIBIT NO. 1.

THE VIDEOGRAPHER: EXCUSE ME, COUNSELOR. I'D LIKE

TWO MINUTES TO CHANGE THE DISK.

MR. HARRIS: WE CAN GO AHEAD AND DO IT NOW WHILE

HE'S LOOKING.

THE VIDEOGRAPHER: OKAY.

WE'RE GOING TO GO OFF THE RECORD AT 1:03 P.M.

THIS IS THE END OF DISK NO. 2 OF THE VIDEO

DEPOSITION OF CLARK CARR.

(RECESS HELD) .



THIS IS THE BEGINNING OF DISK NO. 3 OF THE



WE WERE TALKING BEFORE THE BREAK ABOUT THE

VARIOUS KINDS OF REPORTS THAT NARCONON OF GEORGIA SENT

TO NARCONON INTERNATIONAL. THERE IS SOMETHING CALLED A

WEEKLY REPORT --

A UH-HUH.

Q -- WHICH WE TALKED ABOUT.

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IN ADDITION TO THE WEEKLY REPORT THERE IS THE

WEEKLY STATISTICAL REPORT --

A UH-HUH.

Q WHICH IS EXHIBIT 2. IS THAT CORRECT?

THAT'S JUST AN ILLUSTRATIVE

A IT'S ACTUALLY IN A DIFFERENT, IN A DIFFERENT

FORM THAN THIS AND THIS IS NOT FULLY BUT IT IS THE

REPORT OF THESE NUMBERS FOR ONE WEEK (INDICATING), SO

THIS IS SOME KIND OF COMPILATION OF IT, BUT --

Q WELL, THAT WAS PRODUCED TO US BY YOU.

A YEAH.

Q SO WHAT IS IT?

A IT IS A STATISTICAL REPORT. IT'S THESE NUMBERS

(INDICATING), YOU KNOW, AND THAT'S WHAT WE WOULD GET IN

THE REPORT WOULD JUST BE THAT (INDICATING) . THEN WE

MIGHT DO SOMETHING TO WHERE WE'RE COMPARING IT, YOU

KNOW.

MR. ROOT: JEFF, DID YOU SAY, WHAT DID YOU SAY,

THAT YOU PRODUCED THEM TO US OR

MR. HARRIS: NO. THAT YOU ALL PRODUCED THEM TO US.

IS THAT NOT RIGHT?

MR. ROOT: IT LOOKS LIKE GEORGIA BATES LABEL.

MR. HARRIS: ALL RIGHT. I'M SORRY.

THE WITNESS: THAT'S WHAT -- CLARIFY BECAUSE IT

LOOKS LIKE SOMETHING GEORGIA WOULD USE INTERNALLY.

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Q BY MR. HARRIS: WHAT THEY SEND US. DOES THAT

LOOK LIKE THAT?

A THAT'S WHAT THE REPORT COMING TO US LOOKS LIKE.

Q ALL RIGHT.

SO EXHIBIT 2 THAT'S ALREADY IN THE RECORD IS

SOMETHING THAT PRESUMABLY GEORGIA DOES, RIGHT?

A YES.

Q IS THAT WHAT YOU'RE TELL ME?

A UH-HUH.

Q I'M GOING TO MARK, I KNOW THIS IS GOING TO

SOUND CRAZY. GOING TO HAVE ANOTHER ONE THAT COMES

BEFORE IT. I'LL COME BACK TO THAT.

IN ADDITION, I'VE SEEN SOMETHING CALLED LEGAL

REPORTS WHICH I'VE MARKED AS EXHIBIT 33 JUST SORT OF

CUMULATIVELY.



ATTACHED HERETO) .

MR. ROOT: THAT'S JUST ONE. HAVE AN EXTRA COPY?

MR. HARRIS: NO. I'M JUST USING THESE AS AN

EXAMPLE.

Q IS THERE SOMETHING CALLED A LEGAL REPORT?

A I'VE SEEN THAT AND IT APPEARS THAT THE LEGAL

DEPARTMENT USES THAT TO GET REPORTS ON CHANGING

CONDITIONS WITH REGARD TO LEGAL.

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Q WHAT'S YOUR UNDERSTANDING OF WHEN THOSE REPORTS

ARE SUPPOSED TO BE GENERATED?

A CAN I SEE THAT?

Q SURE.

MS. KOBRIN: JEFF, CAN I INTERRUPT FOR ONE SECOND?

THE LAST DOCUMENT IN THERE HAS NOTHING TO DO WITH

NARCONON OF GEORGIA. IT WAS PRODUCED IN ERROR. IT'S A

COMPLETELY DIFFERENT CENTER.

THE WITNESS: THIS ONE (INDICATING)?

MR. HARRIS: THE ONE THAT I'M ABOUT TO MARK?

MS. KOBRIN: THE LAST PAGE. THE LAST PAGE OF IT.

MR. ROOT: TAKE A LOOK AT THE LAST PAGE OF THE

DOCUMENT.

MR. HARRIS: I SEE WHAT YOU'RE SAYING.

Q ALL RIGHT.

THE LAST PAGE OF EXHIBIT 33 APPEARS TO DEAL

WITH NARCONON GULF COAST. AND I GUESS WHAT I WAS

GETTING AT, THIS LOOKS LIKE A FORM DOCUMENT.

A I'D HAVE TO LOOK AT THEM TO SEE.

Q YOU'RE WELCOME TO LOOK AT THEM. ALL I'M REALLY

TRYING TO GET AT, IS THIS A FORM OF REPORTING THAT'S

DONE FROM INDIVIDUAL CENTERS TO NARCONON INTERNATIONAL

AND, IF SO, WHEN IS IT DONE?

A I ACTUALLY DON'T HAVE THE SPECIFICS ON IT. I

SEE THAT ONE STATES WEEKLY LEGAL REPORT. THE OTHERS

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HAVE WEEK ENDING. SO WHETHER THEY'RE DONE ON A WEEKLY

BASIS OR PERIODICALLY I DON'T KNOW, BUT IT'S A FORMAT TO

SHOW IF THERE ARE ANY LEGAL COMPLAINTS THAT HAVE COME

UP, LEGAL ACTIONS THAT HAVE BEEN TAKEN, ACTIONS ON LEGAL

RUDIMENTS BEING IMPROVED OR GOING OUT.

Q WELL, THERE IS A REPORT CALLED A WEEKLY LEGAL

REPORT, IS THERE NOT?

A HERE THERE IS AND THIS ONE IS NOT WRITTEN THE

SAME (INDICATING) .

Q AND IT SAYS WEEK ENDING?

A YEAH, THIS ONE SAYS WEEK ENDING, SO I WOULD

PRESUME THESE WOULD BE WEEKLY BUT I DON'T KNOW FOR SURE.

Q WELL, AGAIN, THAT'S ONE OF YOUR TOPICS IS

REPORTING BETWEEN THE CENTERS AND INTERNATIONAL. IS

THERE OR IS THERE NOT A WEEKLY REPORT?

A I SEE THAT THERE IS. WHETHER IT'S REQUIRED ON

A WEEKLY BASIS, I'M SORRY, I CANNOT ANSWER THAT

QUESTION.

Q AND THEN I'VE ALSO GOT SOMETHING HERE THAT WAS

GENERATED BY GEORGIA THAT'S CALLED A PR REPORT.

Ill

MS. RICHARDSON: IS THIS AN EXHIBIT?

MR. HARRIS: YES. IT'S EXHIBIT -

MR. ROOT: 32.

MR. HARRIS: 32.

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ATTACHED HERETO) .

THE WITNESS: UH-HUH. YES.

Q BY MR. HARRIS: THERE IS APR REPORT?

A YES.

Q WHEN IS THAT SUPPOSED TO BE SENT UP TO

INTERNATIONAL?

A INFREQUENTLY. IF THERE'S A PARTICULARLY LARGE

POSITIVE PR CIRCUMSTANCE WHERE SOME EVENT HAS BEEN HELD

OR SOME HUMANITARIAN ACTION HAS BEEN TAKEN OR SOMETIMES

LIKE THEY SAY A KIND OF CUMULATIVE REPORT, SO WE WILL

GET THESE FROM DIFFERENT CENTERS AROUND THE WORLD AT

DIFFERENT TIMES. IT'S NOT REQUIRED WEEKLY.

Q THE EXHIBIT NO. 34 I BELIEVE IS CLARIFYING WHAT

WE TALKED ABOUT EARLIER.



ATTACHED HERETO) .

Q BY MR. HARRIS: EXHIBIT 34 IS WHAT YOU ACTUALLY

GET FROM THE CENTERS?

A YEAH. THIS IS SOMETHING THAT IS PRECISELY

REQUIRED EVERY WEEK BECAUSE IT'S WHAT WE ACTUALLY

OPERATE OFF OF IN ORDER TO EVALUATE THE NARCONONS AROUND

THE WORLD.

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Q AND I'M NOT ASKING YOU WHETHER OR NOT THESE

REPORTS ARE REQUIRED TO BE GENERATED EVERY WEEK. I'M

ASKING YOU WHETHER OR NOT THESE ARE THE KINDS OF REPORTS

THAT NARCONON CENTERS AROUND THE WORLD PROVIDE TO


A YES.

Q AND SO WE HAVE THE STATISTICAL REPORT WHICH IS,

IN FACT, REQUIRED EVERY WEEK?

A YES.

Q WE'VE GOT THE, WHAT'S REFERRED TO AS THE WEEKLY

EXECUTIVE DIRECTOR REPORT, CORRECT?

A UH-HUH.

Q WE'VE GOT THESE BATTLE PLANS, CORRECT?

A YES. THOSE ARE NOT A REPORT. THEY'RE JUST

THE

Q THEY'RE BATTLE PLANS?

A BATTLE PLANS. THEY MAY OR MAY NOT BE SENT BUT

WE SOMETIMES RECEIVE THEM FROM THE EXECUTIVE DIRECTOR.

Q THE LEGAL REPORTS THAT WE'VE TALKED ABOUT?

A YES.

Q THE PR REPORTS THAT WE HAVE TALKED ABOUT?

A YEAH. THAT COULD ALSO JUST BEEN SENT AS A, YOU

KNOW, "DEAR CLARK" OR SOMETHING.

Q OKAY.

A IT'S NOT NECESSARILY A REPORT. IN THIS CASE IT

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WAS CALLED A PR REPORT.

Q WELL, IS THERE SUCH A THING AS A PR REPORT?

A NO.

Q DID MARY RIESER JUST MAKE THAT TERM UP AND SEND

THAT OFF TO YOU?

A YEAH. IT WAS LIKE REGARDING PUBLIC RELATIONS

IT COULD HAVE BEEN, YOU KNOW, SHE INVITED THE TERM.

THERE IS NOT A PR REPORT.

Q IS THERE AN ANNUAL REPORT OF ANY KIND?

A NO.

Q ALL RIGHT.

ANY OTHER REPORTS THAT I DON'T KNOW ABOUT THAT

WE DON'T, THAT WE HAVEN'T TALKED ABOUT OTHER THAN THE

ONES THAT WE'VE GONE THROUGH HERE?

A NOT THAT I KNOW OF, NO.

Q FEES. HOW MUCH -- WHAT IS THE FEE STRUCTURE IN

TERMS OF WHAT, WHAT DOES NARCONON INTERNATIONAL RECEIVE

FROM NARCONON OF GEORGIA IN TERMS OF FEES?

A WE RECEIVE 10 PERCENT OF THEIR ADJUSTED GROSS

INCOME.

Q AND HOW IS THAT DEFINED?

A SOME THINGS WOULD BE TAKEN OFF OF THE TOP, IF

THERE ARE REFUNDS OR REPAYMENTS MADE, IF THERE ARE

COMMISSIONS PAID TO SOMEONE WHO IS REFERRING SOMEONE TO

THE CENTER AND WHO HAS DONE THAT WORK, AND THERE MAY BE

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SOME OTHER MONIES THAT WOULD COME OFF THE TOP.

SOMETIMES MONEY'S HELD IN WHAT WE CALL SPECIAL INCOME.

IF IT'S UNCERTAIN THAT THEY'RE GOING TO BE ABLE TO KEEP

A STUDENT, THEN THEY JUST HOLD THE MONEY ASIDE.

OTHERWISE, WE GET 10 PERCENT OF THE REST.

Q EXHIBIT 35. IT'S BATES NO. 0460.



ATTACHED HERETO) .

Q BY MR. HARRIS: WHAT IS THAT?

MR . ROOT : 4 6 0 .

MS. RICHARDSON: THANK YOU.

MR. ROOT: THROUGH 462. 460, -1 AND -2.

THE WITNESS: THIS APPEARS TO BE AN ITEMIZATION OF

THE INCOME THAT CAME IN AT NARCONON OF GEORGIA FOR

DIFFERENT WEEKS.


IS THAT SOMETHING THAT THE INDIVIDUAL CENTERS

ARE REQUIRED TO REPORT?

A I DON'T BELIEVE THEY'RE ALL REQUIRED TO REPORT

THEM. I'M NOT SURE WHY NARCONON OF GEORGIA IS.

Q WELL, THEN YOU'VE PRODUCED TO ME A ZILLION OF

THEM FOR VARIOUS WEEKS AND I'M JUST CURIOUS AS TO WHY IF

THEY'RE NOT REQUIRED TO REPORT IT WHY THEY SEND YOU ONE

EVERY WEEK.

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THE WITNESS: I WOULD HAVE TO SPEAK TO THE TREASURY

DEPARTMENT. MUST BE SOME AGREEMENT BETWEEN THE TREASURY

DEPARTMENT AND NARCONON INTERNATIONAL AND NARCONON OF

GEORGIA. I DON'T KNOW.

Q BY MR. HARRIS: ARE YOU TELLING ME THAT THAT

DOCUMENT RIGHT THERE THAT YOU'RE HOLDING IN YOUR HAND IS

SOMETHING THAT'S UNIQUE TO NARCONON OF GEORGIA AND ISN'T

A REPORT THAT'S GENERATED BY INDIVIDUAL CENTERS TO

INTERNATIONAL?

A I -- NO. THIS FORM I HAVE SEEN. THE FACT THAT

NARCONON INTERNATIONAL WOULD HAVE COPIES OF NARCONON OF

GEORGIA AND THAT THESE WERE PRESENTED HERE DOESN'T MEAN

THAT WE MAY NOT HAVE COPIES FROM OTHER, FROM OTHER

CENTERS WHICH WOULD HAVE NOT BEEN RELEVANT TO THIS, TO

THIS DISCOVERY. I'M NOT EXACTLY SURE WHEN IT'S REQUIRED

AND WHY IT'S REQUIRED.

WHAT I AM -- SEE, WHAT IT IS, IS IT'S AN

ITEMIZATION OF HOW THEY'RE BREAKING DOWN THE INCOME THAT

CAME IN THAT WEEK.

Q THAT'S WHY YOU'RE HERE. I DON'T KNOW WHY THAT

IS DONE, EITHER, AND THAT'S WHY I ASKED FOR SOMEBODY TO

TELL ME ABOUT REPORTS THAT ARE GENERATED FROM THE

INDIVIDUAL CENTERS UP TO INTERNATIONAL. SO I NEED TO

KNOW WHAT THAT THING IS, WHEN IT'S REQUIRED AND WHY IT'S

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REQUIRED.

A I WOULD HAVE TO SPEAK TO OUR TREASURY

DEPARTMENT IN TERMS OF WHY IT'S REQUIRED. WHAT IT IS IS

AN ITEMIZATION OF THE BREAK DOWN OF THE INCOME. FROM

THIS WE WOULD THEN BE ABLE TO DETERMINE IF THE 10

PERCENT LICENSE FEE THAT'S COMING TO NARCONON

INTERNATIONAL IS CORRECT. SO THAT WOULD SEEM TO ME -- I

DON'T KNOW WHAT ELSE.

Q WELL, AT LEAST WITH RESPECT TO GEORGIA THE

DOCUMENTS THAT YOU'VE PRODUCED IN THIS CASE INDICATE

THAT THE FINANCIALS OF GEORGIA, ALL OF THEIR INCOME AND

EVERYTHING THAT THEY'RE SPENDING THEIR MONEY ON ARE

PROVIDED TO INTERNATIONAL.

A PER THESE REPORTS, HOW THEY'RE, HOW THEY'RE

HANDLING THEIR INCOME. IF THEY WERE HAVING TROUBLE WITH

THEIR INCOME WE WOULD WANT TO KNOW ARE THEY ALLOCATING

THEIR INCOME CORRECTLY IN ORDER TO GET OUT OF THE FIX.

Q IS THAT TRUE OR NOT?

A I'M SORRY. ASK YOUR QUESTION AGAIN.

Q DOES NARCONON OF GEORGIA HAVE TO REPORT TO

NARCONON INTERNATIONAL ALL OF ITS FINANCIAL

EXPENDITURES?

A NO.

Q DOES IT HAVE TO PROVIDE THE DOCUMENT THERE THAT

YOU'VE GOT IN FRONT OF YOU? I CAN'T REMEMBER THE

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EXHIBIT NUMBER. GETTING TIRED.

MR. ROOT: 35.

MR. HARRIS: THANK YOU.

Q 35.

MR. ROOT: ANY TIME I CAN HELP YOU.

THE WITNESS: FOR A PERIOD OF TIME IT MAY HAVE. I

DON'T KNOW IF THIS IS AN ONGOING REQUIREMENT.

Q BY MR. HARRIS: SO YOU DON'T KNOW?

A NO, I DON'T KNOW.

Q EXHIBIT NO. 3. WHAT'S THAT?

A THAT IS SIMPLY A REVISED FORM OF -- THIS IS A

CONDENSED FORM OF THIS (INDICATING) . THIS IS CALLED THE

ALLOCATION FORM AND IT'S HOW THE GROSS INCOME THAT'S

COME IN IS BEING BROKEN DOWN AND WHAT PERCENTAGE IS

GOING TO GO TO WHAT AREA. THEY'RE THE SAME. THIS IS

JUST WRITTEN OUT IN LARGER FORMAT.

Q SO EXHIBIT 3 AND EXHIBIT 35 ARE THE SAME?

A YES. JUST IN A DIFFERENT FORMAT BUT THE SAME

DATA.

Q THESE ARE REPORTS THAT ARE GENERATED BY

NARCONON OF GEORGIA AND SENT TO NARCONON INTERNATIONAL

EVERY WEEK OUTLINING THEIR FINANCIAL CONDITION, THE

EXPENDITURES THEY'RE MAKING AND HOW MUCH MONEY THEY'RE

BRINGING IN, AREN'T THEY, SIR?

A I DON'T KNOW IF THEY COME EVERY WEEK. I KNOW

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THAT THEY'RE ATTACHED TO THE WEEKLY REPORT WHICH COMES

TO THE DATA FILES AT NARCONON INTERNATIONAL AND JUST

GETS FILED, SO I DON'T KNOW IF THESE JUST COME IN AND

ARE JUST FILED BUT THIS IS WHAT THE DATA IS ABOUT, YES.

Q WELL, IT SAYS WEEK ENDING 1-24-2008, DOES IT

NOT?

A UH-HUH. SO IT'S FOR THAT WEEK.

Q AND I'LL JUST REPRESENT TO YOU THAT YOU ALL

HAVE PRODUCED TO US ZILLIONS OF THESE THINGS FOR EACH

WEEK AND I JUST WANT TO KNOW WHY. WHAT'S THE PURPOSE OF

THEM?

A WELL, I KNOW THAT NARCONON OF GEORGIA FELL

BEHIND ON THEIR LICENSE FEES AND THE -- AND WE WERE

INTERESTED IN THEIR IMPROVING THEIR FINANCIAL STATUS.

IF THEY SEND A REPORT OF HOW THEY'RE USING THEIR MONEY,

WHICH IS THEIR CHOICE, THEN WE HAVE A REPORT OF HOW THE

MONIES ARE BEING ALLOCATED TO, TO SURVIVE BETTER.

THAT'S HOW WE WOULD USE IT.

Q ARE YOU SUGGESTING THAT THIS FORM, THIS EXHIBIT

3 THAT WE'VE BEEN TALKING ABOUT, IS SOMETHING THAT'S

UNIQUE TO NARCONON OF GEORGIA?

A THE FORM IS A FORM THAT MOST CENTERS USE. THIS

OR SOMETHING SIMILAR. ALTHOUGH THEY'RE, THE PARTICULAR

CAN CENTER'S ALLOCATIONS MAY VARY BASED ON THEIR NEEDS,

BUT THE SUBSTANCE OF THE FORM IS --

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Q THIS DOCUMENT, AT THE BOTTOM IT SAYS "THIS

ALLOCATION MUST BE SENT ALONG WITH YOUR STATS ON

THURSDAY TO YOUR CONT OFFICE OR NARCONON INT."

A OKAY.

Q SO THAT MEANS YOU'VE GOT TO SEND EXHIBIT 3 IN

EVERY WEEK.

A GOOD. THEN, YEAH, THIS GOES IN TO THE CONT

OFFICE, NOT NECESSARILY TO US, AND

Q WELL, YOU PRODUCED IT.

A GOOD. THEN THIS MEANT IN THIS CASE THESE CAME

TO OUR DATA FILES.

Q WHAT'S YOUR DATA FILES?

A THESE ARE FILES THAT ARE NOT NECESSARILY WHERE

THINGS ARE REVIEWED BUT THERE'S DATA THAT IS PUT, JUST

PUT IN THERE SO THAT IF YOU WANT TO GO BACK AND YOU LOOK

AT WHAT IS HAPPENING WITH THAT CENTER IN THAT MONTH YOU

WILL HAVE ALL OF THE DATA REGARDING THAT MONTH SO THAT

ALL OF THE DATA IS THERE.

Q SO NARCONON INTERNATIONAL KEEPS SOMETHING

CALLED A DATA FILE ON EACH INDIVIDUAL CENTER?

A DEPENDING UPON THE SOPHISTICATION OF THE

CENTER, YES. WHAT WE DO IS WE KEEP WEEKLY FILES OF

EVERYTHING THAT COMES IN THAT WEEK AND THEN THERE'S SOME

THINGS THAT JUST GO STRAIGHT TO FILING. SO IN TERMS OF

THE DISCOVERY, I KNOW WHAT WAS DONE WHEN YOU ASKED ABOUT

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CERTAIN THINGS, EVERYTHING THAT WAS IN OUR DATA FILES

REGARDING NARCONON OF GEORGIA WAS PRESENTED FOR YOU, I

BELIEVE, PERTINENT TO -- I'M NOT SURE, NOT EXACTLY SURE

WHAT THE QUESTION WAS BUT PER WHAT YOUR REQUESTS WERE.

Q YOU REFER TO SOMETHING CALLED DATA FILES. I

JUST ASKED YOU WHAT THOSE WERE.

A THEY'RE JUST FILES WHERE DATA IS KEPT. IN

OTHER WORDS, ALL OF THE REPORTS THAT WE'RE TALKING ABOUT

GO INTO DATA FILES.

Q EXHIBIT A TO YOUR DEPOSITION NOTICE CONTAINED A

DEFINITION SHEET FOR THE NARCONON STATISTICS CABLE.

A YES.

Q DO YOU RECALL LOOKING AT THAT?

A YES.

Q IS THAT ACCURATE? IS THAT DESCRIPTION AN

ACCURATE DESCRIPTION OF THE INDIVIDUAL STATISTICS THAT

EACH CENTER IS REQUIRED TO REPORT?

A I WOULD HAVE TO LOOK AT IT. AS I REMEMBER,

THIS ONE WAS NOT DATED. IT'S POSSIBLE THERE MAY BE A

SLIGHT VARIATION IN SOME OF THEM BUT IT IS MORE OR LESS

ACCURATE, YES, AS I READ THROUGH IT.

Q THIS EXHIBIT A JUST DEFINED EACH ONE OF THE

TERMS --

A YES.

Q -- THAT ARE USED IN THAT STATISTICS CABLE?

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A

Q

UH-HUH.

AND YOUR BELIEF IS THAT EXHIBIT A GENERALLY

3 ACCURATELY REFLECTS THOSE TERMS AND WHAT THEY'RE

4 DESIGNED TO ADDRESS?

13:27:42 5 A YES. YOU KNOW, YOU'D HAVE TO ASK ME ABOUT ANY

6 ONE IN SPECIFIC. I READ THROUGH IT AND IT SEEMED TO

13:27:45 7 BE

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Q

A

I REALLY DON'T WANT TO DO THAT.

IT SEEMED APPROPRIATE.

MR. ROOT: DON'T ENCOURAGE HIM.

THE WITNESS: IT SEEMED CORRECT TO ME IN DEFINING

12 WHAT THE STATISTIC MEANS AND WHAT IT IS ACTUALLY

13 MEASURING .

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Q BY MR. HARRIS: OKAY. ALL RIGHT. MAKE SURE

THERE'S NOTHING ELSE.

WHAT PERCENTAGE OF THE INCOME THAT NARCONON

INTERNATIONAL RECEIVES EACH YEAR DOES IT GIVE TO

CHARITY?

A IT VARIES. WE GIVE GRANTS TO OUR NARCONON

20 CENTERS, SOMETIMES HELPING THEM PURCHASE BUILDINGS, DO

21 THINGS, AND WE DO EXTERNAL CHARITY WORK. THERE'S NOT A

22 SET PERCENTAGE AS WE OURSELVES ARE A CHARITABLE

23 ORGANIZATION.

13:28:56 24

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Q WHAT PERCENTAGE OF YOUR INCOME IN 2008 DID YOU

GIVE TO CHARITY?

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MR. ROOT: OBJECT TO THE FORM. OUTSIDE THE SCOPE

OF THE NOTICE.

THE WITNESS: I ACTUALLY DON'T KNOW --

MR. ROOT: EXCUSE ME, MR. CARR. LET ME FINISH THE

OBJECTION.

OUTSIDE THE SCOPE OF THE NOTICE.

MR. HARRIS: ARE YOU TELLING HIM NOT TO ANSWER THAT

QUESTION?

MR. ROOT: JUST MADE MY OBJECTION. NOT YET.

BUT NO; GO AHEAD AND ANSWER.

THE WITNESS: I CAN LOOK FOR THAT DATA OF WHAT

GRANTS WE GAVE TO OTHER ORGANIZATIONS OUTSIDE OF

NARCONON.

Q BY MR. HARRIS: SO OKAY. OTHER THAN THE GRANTS

THAT YOU GIVE TO INDIVIDUAL CENTERS, CAN YOU IDENTIFY

FOR ME ANY OTHER CHARITABLE ORGANIZATIONS THAT NARCONON

INTERNATIONAL PROVIDES GRANTS TO?

A YES. WE DO, WE DO A LOT OF, NARCONON

INTERNATIONAL AND OTHERS WE HELP FUND DRUG EDUCATION

AROUND THE WORLD, DISTRIBUTION OF COPIES OF THE WAY TO

HAPPINESS" WHICH IS ONE PART OF THE NARCONON PROGRAM.

IT'S SOMETHING THAT WE DO PUBLIC DISTRIBUTION OF.

DISTRIBUTION OF DRUG EDUCATION BOOKLETS. WE HAVE ONE

CALLED "TEN THINGS YOUR FRIENDS MAY NOT KNOW ABOUT

DRUGS." THIS IS DISTRIBUTED AROUND THE WORLD, IN NEPAL,

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IN PAKISTAN AND SO FORTH.

OVER THE LAST THREE YEARS IN MEXICO WE HAVE

GIVEN VITAMINS AND WAY TO HAPPINESS MATERIALS AND DRUG

EDUCATION BOOKLETS, AS WELL AS WORKSHOPS, FUNDED

WORKSHOPS FOR OVER 200 CHARITABLE REHAB CENTERS IN

MEXICO, THINGS LIKE THAT. THOSE ARE ONES THAT

IMMEDIATELY COME TO MIND.

Q ARE THOSE REFLECTED IN YOUR INCOME OR -- EXCUSE

ME -- YOUR TAX DOCUMENTS THAT ARE FILED EVERY YEAR?

A I BELIEVE THEY -- I DON'T KNOW EXACTLY HOW THEY

WOULD BE ITEMIZED BUT THEY SHOULD BE. IT SHOULD BE

ITEMIZED IN THAT KIND OF A WAY, YES.

Q SO THOSE CHARITABLE GRANTS OR CHARITABLE

DONATIONS THAT YOU'VE JUST DESCRIBED FOR ME, THOSE WOULD

BE REFLECTED IN SOME CAPACITY?

A YES.

Q ON INCOME TAX RETURNS?

A OR, I BELIEVE, 990'S.

Q 990'S.

A FOR THE COMPANY. EXACTLY.

Q EXHIBIT 31 IS THE SCREEN CAPTURE FROM THE

WEBSITE. WHAT WE'VE DONE IS CAPTURED IT AND E-MAILED IT

TO EVERYBODY. WE'RE ABOUT TO. INCLUDING THE COURT

REPORTER. AND IT WILL BE MARKED AS EXHIBIT 31 AND

YOU'LL HAVE A COPY OF IT ELECTRONICALLY IN JUST A

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SECOND.



ATTACHED HERETO) .

MR. ROOT: OKAY.

MR. HARRIS: THAT'S ALL WE HAVE.

MS. KOBRIN: IS THIS A NEW EXHIBIT?

MR. ROOT: THIS IS A SCREEN SHOT.

MS. RICHARDSON: WHERE SHE TALKS ABOUT HER -

THE WITNESS: OF THE WEB'S PAGE FROM THE WEBSITE

THAT WAS SUPPOSED TO BE NARCONON OF GEORGIA'S.

MR. ROOT: WHY DON'T YOU GIVE US A COUPLE MINUTES,

SEE IF WE HAVE ANY QUESTIONS.

MR. HARRIS: SURE.


WE'RE GOING TO GO OFF THE RECORD AT


(RECESS HELD) .


WE ARE BACK ON THE RECORD AT 1:45.

EXAMINATION

BY MR. ROOT:

Q MR. CARR, GOOD AFTERNOON.

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AS YOU KNOW, I'M DAVE ROOT AND I'VE BEEN

REPRESENTING NARCONON INTERNATIONAL. I'VE GOT JUST A

COUPLE OF QUESTIONS FOR YOU, IF YOU DON'T MIND.

A ALL RIGHT.

Q WE'VE TALKED A LOT ABOUT NARCONON OF GEORGIA

WHICH IS LOCATED NEAR ATLANTA, SEVERAL THOUSAND MILES

AWAY FROM WHERE WE ARE; IS THAT WHAT -- WE'VE BEEN

TALKING ABOUT THAT TODAY, RIGHT?

A YES.

Q NOW, THE COMPANY THAT YOU WORK FOR IS NARCONON

INTERNATIONAL; IS THAT CORRECT?

A YES.

Q AND IS NARCONON OF GEORGIA A SEPARATE

CORPORATION FROM THE COMPANY THAT YOU WORK FOR?

A YES.

Q AND WHEN NARCONON OF GEORGIA GOES OUT TO HIRE

PEOPLE, DOES YOUR ORGANIZATION NARCONON INTERNATIONAL

HAVE ANYTHING TO DO OR SAY ABOUT THAT?

A NO.

Q DOES ANYBODY AT INTERNATIONAL MAKE ANY

DECISIONS TO HIRE OR FIRE THE FOLKS AT NARCONON OF

GEORGIA?

A NO.

Q DO YOU DO ANY REVIEWS OF THEIR, YOU KNOW,

PERSONNEL REVIEWS AND THAT SORT OF THING OF THE FOLKS

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1 THERE?

13:45:24 2 A IF THERE IS A LEGAL RUDIMENTS INSPECTION, THE

3 TRAINING OF THE STAFF, ARE THEY TRAINED FOR THEIR POST

4 OR DO THEY REQUIRE MORE TRAINING, IS LOOKED AT.

13:45:32 5 Q NOW, YOU'RE SITTING HERE IN LOS ANGELES,

6 CALIFORNIA, SEVERAL THOUSAND MILES AWAY. IS

7 INTERNATIONAL INVOLVED IN THE DAY-TO-DAY OPERATION OF

8 THIS CENTER NEAR ATLANTA, GEORGIA?

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A

Q

NEITHER OF THAT CENTER NOR ANY OTHER CENTER.

AND YOU'VE ALREADY TOLD US YOU HAVE A NUMBER OF

11 CENTERS BOTH THAT YOU LICENSE BOTH HERE IN THE UNITED

12 STATES AND AROUND THE WORLD?

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A

Q

MORE THAN 50; YES.

NOW, AS YOU UNDERSTOOD IT AS PRESIDENT OF

15 NARCONON INTERNATIONAL, THIS CENTER OVER IN ATLANTA OR

16 NEAR ATLANTA WAS LICENSED BY THE STATE OF GEORGIA AS AN

17 OUTPATIENT FACILITY; IS THAT CORRECT?

13:46:10 18

13:46:13 19

A

Q

YES.

DID YOU EVER HAVE ANY UNDERSTANDING THAT IN

20 2007 OR 2008 AT THE TIME THAT PATRICK DESMOND DIED THAT

21 THIS CENTER WAS LICENSED AS A RESIDENTIAL FACILITY?

13:46:26 22

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A

Q

NO.

AND BY RESIDENTIAL FACILITY I MEAN A FACILITY

24 THAT HAS BEDS AND DORMITORY ROOMS ONSITE.

13:46:38 25 A YES. NO. THAT'S WHAT WE UNDERSTAND AS A




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RESIDENTIAL FACILITY.

Q WAS YOUR UNDERSTANDING THAT THIS HOUSING THAT

WE'VE BEEN REFERRING TO WAS OPERATED BY A COMPANY

SEPARATE FROM NARCONON OF GEORGIA?

A YES.

Q AND WAS IT YOUR UNDERSTANDING THAT STUDENTS

SUCH AS MR. DESMOND WERE, BECAUSE IT WAS AN OUTPATIENT

FACILITY, WERE FREE TO LIVE THERE OR ANY OTHER PLACE OF

THEIR CHOOSING?

A YES. THAT'S WHAT THE ENROLLMENT FORMS OF

NARCONON OF GEORGIA STATED.

Q OKAY.

AND YOU HAVE REVIEWED THOSE FORMS?

A YES.

Q AND WHAT DO YOU RECALL THAT THEY SAID ABOUT

THAT ISSUE OF OUTPATIENT VERSUS RESIDENTIAL VERSUS WHERE

A PERSON COULD LIVE?

A THAT WHEN THE STUDENT AND/OR FAMILIES WERE

ENROLLING IT WAS STATED THAT HOUSING WAS A SEPARATE,

SEPARATE FROM NARCONON AND THAT, YOU KNOW, THEY COULD

MAKE THEIR OWN CHOICE.

Q OKAY.

A WITH THAT REGARD.

Q YOU'VE I'M SORRY.

A I ALSO BELIEF THAT WHEN CHECKS WERE WRITTEN

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THEY WERE WRITTEN SEPARATELY. IN OTHER WORDS, FUNDING

FOR HOUSING WAS SEPARATE FROM FUNDING FOR NARCONON OF

GEORGIA.

Q YOU HAVE SAID, YOU HAVE IDENTIFIED PREVIOUSLY

EXHIBIT 14 WHICH CONTAINS THE LICENSE AGREEMENT BETWEEN

NARCONON INTERNATIONAL AND NARCONON OF GEORGIA?

A YES.

Q IS THAT CORRECT?

AND IS IT THAT LICENSE AGREEMENT WHICH ALLOWS A

CENTER SUCH AS NARCONON OF GEORGIA TO USE THE

TRADEMARKED NARCONON NAME?

A YES.

Q AND IS IT THAT AGREEMENT THAT ALSO ALLOWS THE

CENTER SUCH AS NARCONON OF GEORGIA TO USE THE PROGRAM

MATERIALS THAT ARE PART OF THE DRUG REHABILITATION

PROGRAM CONDUCTED BY PARTICULAR CENTERS?

A YES. THAT LICENSE AGREEMENT SPECIFICALLY.

Q AND WHEN YOU KEPT COMING BACK AND SAYING THAT

YOU WERE PROTECTING YOUR TRADEMARK OR WHEN YOU WERE

REFERRING TO THE LICENSING AGREEMENT, WERE YOU REFERRING

TO NARCONON INTERNATIONAL TRYING TO MAKE SURE THAT ITS

TRADEMARK STILL HAD INTEGRITY AND SO FORTH, CORRECT,

FIRST OF ALL?

A YES.

Q AND WERE YOU ALSO TRYING TO, AS NARCONON

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INTERNATIONAL, ASSURE THAT THESE DRUG REHABILITATION

MATERIALS ARE DELIVERED CONSISTENTLY IN THE MANNER THAT

THEY'RE INTENDED TO BE DELIVERED?

A THAT'S OUR SOLE, SOLE PURPOSE.

Q NOW, IN TRYING TO DETERMINE THAT, YOU DON'T

HAVE ANYBODY FROM INTERNATIONAL THERE ONSITE AT THESE

CENTERS ON A DAY-TO-DAY BASIS; IS THAT CORRECT?

A NO.

Q DO YOU TRY TO DETERMINE WHETHER THE MATERIALS

ARE IMPLEMENTED CORRECTLY BY GETTING SOME OF THESE

REPORTS THAT MR. HARRIS REFERRED TO?

A YES. WE RECEIVE A NUMBER OF DIFFERENT REPORTS

AND STATISTICS AND USING ALL OF THAT WE CAN HAVE A

PRETTY GOOD IDEA OF WHAT'S GOING ON.

Q IN A BRIEF WAY, HOW DOES THE STATISTICAL REPORT

HELP YOU TO DETERMINE WHETHER OR NOT THE PROGRAM

MATERIALS ARE BEING IMPLEMENTED AT A PARTICULAR CENTER

IN THE WAY THAT YOU WANT THEM TO BE UNDER YOUR LICENSE

AGREEMENT?

A WELL, IF WE CAN SEE ONE STATISTIC GOING UP

WHICH ANOTHER STATISTIC SHOULD BE PARALLELING IT GOING

UP BUT IT'S NOT, THIS WOULD MEAN THERE WOULD BE A

PROBLEM.

FOR EXAMPLE, IF STUDENTS WERE LEAVING THE

PROGRAM EARLY, TOO MANY OF THEM WERE LEAVING INCOMPLETE,

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YOU WILL SEE THE STATISTICS OF THE LATER DELIVERY

DROPPING DOWN. IF YOU SEE THE, THE -- A LOT OF PEOPLE

THAT ARE SHOWING THE STATISTICS, THE STATISTICS ARE

SHOWING A LOT OF PEOPLE ARE COMPLETING THE SAUNA PROGRAM

BUT WE DON'T SEE THE STUDENT POINTS IN THE COURSE ROOM

GOING UP, IT MEANS WHAT HAPPENED AFTER THE SAUNA? THESE

PERSONS SHOULD BE CONTINUING. AND SO FORTH. THERE ARE

VARIOUS STATISTICS. YOU CAN COMPARE ONE TO THE OTHER,

AS WELL AS REGARDING SOLVENCY ISSUES AND EXPANSION OR

CONTRACTION OF THE PROGRAM YOU CAN PREDICT.

WE'RE INTERESTED ACTUALLY USUALLY NOT IN ONE

CENTER BUT WE'RE INTERESTED IN A BROAD SPAN BECAUSE

WE'RE LOOKING AT THE USE OF THE PROGRAM MATERIALS ACROSS

A LARGE AREA.

Q LET ME TALK BRIEFLY ABOUT THESE INSPECTIONS

THAT ARE EITHER, I GUESS YOU'VE GOT A COUPLE KIND OF

INSPECTIONS, A TECHNICAL INSPECTION AND A LEGAL

RUDIMENTS INSPECTION; IS THAT CORRECT?

A YES. AND THE TECHNICAL INSPECTION CAN BE

COMPOSED OF A NUMBER OF SPECIFIC PARTS. WE HAVE RATHER

STANDARD METHODS OF DOING THIS SO THAT WE'RE MONITORING

ALL THE CENTERS IN THE SAME WAY ACCORDING TO STANDARD

PROCEDURES.

Q ALL RIGHT.

WHEN YOU DO A LEGAL RUDIMENTS INSPECTION OF AN

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R Leonard CSR, Inc.

OUTPATIENT FACILITY, DO YOU DO ANY INSPECTION OF THE

PLACES WHERE STUDENTS ELECT TO LIVE?

A NOT TO MY KNOWLEDGE.

Q ALL RIGHT.

WHEN YOU DO A TECHNICAL INSPECTION OF AN

OUTPATIENT FACILITY, DO THE PEOPLE WHO GO TO THE CENTER

DO ANY INSPECTION OF THE VARIOUS PLACES WHERE STUDENTS

MAY ELECT TO LIVE AS OUTPATIENTS OF THAT FACILITY?

A NO. IT'S OUTSIDE THEIR PURVIEW OF OUR LICENSE

WITH THAT CENTER.

Q THE STUDIES THAT YOU REFERRED TO, AND I BELIEVE

THERE'S AN EXHIBIT SOMEWHERE THAT WE DIDN'T HAVE AN

EXTRA COPY OF WHICH I CAN'T TELL YOU THE EXHIBIT NUMBER.

COULD YOU PASS ME THAT STACK?

A YEAH. WE ACTUALLY DIDN'T HAVE THE STUDIES

I'M GOING TO HAVE TO GET COPIES OF BUT THE SAUNA

DETOXIFICATION STUDIES WE HAVE HERE SOMEWHERE IN THIS

PACK.

Q DON'T HURT YOURSELF.

A BE TOWARD THE END THERE, YEAH.

Q LOOKS LIKE THEY WERE MARKED AS COLLECTIVE

EXHIBIT 28. IS THAT CORRECT?

A UH-HUH.

Q AND IN ADDITION TO THE VARIOUS DOCUMENTS THERE

IS AN APPENDIX OF REFERENCES WHICH HAS, REFERS TO 62

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OTHER STUDIES; IS THAT CORRECT?

A YES. IT REFERS TO THE USE OF VITAMINS AND

MINERALS AND SO FORTH AND DOCUMENTATION OF THIS BEING

USED AT THE CENTERS.

Q HOW LONG HAVE YOU BEEN IN THE DRUG

REHABILITATION FIELD?

A MYSELF?

Q YES, SIR. DRUG AND ALCOHOL REHABILITATION.

A 24 YEARS.

Q WHY ARE YOU IN IT? WHY DID YOU GET IN IT AND

WHY DO YOU STAY IN IT?

A CAME IN BECAUSE I WAS ASKED TO HELP AND

ALTHOUGH IT WAS A LITTLE BIT FRIGHTENING AT THE

BEGINNING, JUST WHEN CRACK COCAINE WAS BEING INTRODUCED

IN THE UNITED STATES, THE AMOUNT OF CHAOS AND

DESTRUCTION IT CAN BRING INTO AN INDIVIDUAL'S LIFE AND A

FAMILY'S LIFE WAS PROFOUNDLY UPSETTING TO ME AND I HAD

VOLUNTEERED AT THE BEGINNING FOR JUST A SHORT TIME TO

HELP OUT A CENTER THAT WAS HAVING SOME DIFFICULTIES, BUT

LITERALLY WITHIN A PERIOD OF A COUPLE OF MONTHS I

RECOGNIZED THAT THIS WAS A CRISIS COMING UP FOR THE

COUNTRY AND DESPITE THE REAL PERSONAL FEAR THAT I HAD

THAT I WOULD NOT BE ABLE TO HANDLE THIS, THAT I WOULD

NOT BE ABLE TO DO ANYTHING EFFECTIVE, I DECIDED TO STAY

OUT OF RESPECT TO THE OTHER PEOPLE THAT WERE WORKING IN

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NARCONON.

Q YOU'VE SAID KIND OF HOW YOU GOT INTO IT. WHY

DO YOU STAY IN IT UP TO THIS DAY?

A MANY PEOPLE WANT TO BE A HERO, YOU KNOW, AND IF

THERE'S A BURNING BUILDING THEY'LL RUSH IN AND SAVE THAT

PERSON AND PULL THEM OUT AND IT TAKES A MATTER OF

MINUTES.

MY RESPECT FOR NARCONON STAFF WHO ARE DOING

THIS WORK SEVEN DAYS AND NIGHTS A WEEK UNDER VERY

DIFFICULT CIRCUMSTANCES HAS JUST GROWN OVER THE YEARS,

SO I'M PROUD TO HELP SAVE LIVES.

MR. ROOT: THESE ARE ALL MY QUESTIONS.

THANK YOU.

MR. HARRIS: JUST ONE OR TWO FOLLOWUPS.

FURTHER EXAMINATION

BY MR. HARRIS:

Q THE BUSINESS ASSOCIATE LICENSE IS A SEPARATE

CONTRACT BETWEEN NARCONON INTERNATIONAL AND NARCONON OF

GEORGIA FROM THE LICENSE AGREEMENT, IS IT NOT?

A YES, IT'S SEPARATE.

MR. ROOT: OBJECTION AS TO FORM.

Q BY MR. HARRIS: WELL, THEY'RE TWO DIFFERENT

CONTRACTS, RIGHT?

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A YES. BUT I --MY UNDERSTANDING IS THAT THE ONE

DOES NOT INVALIDATE THE OTHER.

Q I DIDN'T ASK YOU THAT.

A OKAY.

Q THEY'RE TWO SEPARATE CONTRACTS, CORRECT?

A PATENTLY, YES.

Q THERE'S A LICENSE AGREEMENT WHICH LICENSES HOW

THE MARKS CAN BE USED BY NARCONON OF GEORGIA?

A UH-HUH.

Q AND THERE IS A BUSINESS ASSOCIATE AGREEMENT,

CORRECT?

A UH-HUH. UH-HUH.

Q AND THERE ARE CERTAIN DUTIES AND OBLIGATIONS

THAT ARE SPELLED OUT IN THE BUSINESS ASSOCIATE

AGREEMENT, RIGHT?

A I DON'T KNOW IF THEY'RE STATED AS DUTIES AND

OBLIGATIONS. I BELIEVE THERE WAS AN ITEMIZATION OF

THESE ARE THE THINGS THAT WILL BE DONE.

Q AND THAT AGREEMENT WAS IN EFFECT AT THE TIME OF

PATRICK DESMOND'S DEATH, CORRECT?

A YES, IT WAS.

Q AT ANY POINT IN TIME DID NARCONON INTERNATIONAL

SEND A LETTER TO NARCONON OF GEORGIA AND SAY "YOU KNOW,

YOU GUYS ARE ALL THE WAY ACROSS THE COUNTRY. WE'RE HERE

IN CALIFORNIA AND YOU'RE IN GEORGIA, SO WE CAN'T DO

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THOSE THINGS ON EXHIBIT A OF THE BUSINESS ASSOCIATION

AGREEMENT BECAUSE YOU'RE JUST TOO FAR AWAY"?

IT?

A WE WERE IN REGULAR COMMUNICATION WITH GEORGIA.

Q SO THE ANSWER IS NO, THAT NEVER HAPPENED, DID

A NO, WE DIDN'T WRITE THAT LETTER. WE

WROTE WE HAD MANY OTHER COMMUNICATIONS ON A WEEKLY

BASIS WITH THEM.

Q INTERNATIONAL HAS NEVER CONTENDED THAT IT

COULDN'T DO THE THINGS IN THE BUSINESS ASSOCIATION

AGREEMENT, HAS IT?

A NO.

MR. HARRIS: THANK YOU.

MR. ROOT: THANK YOU.


WITH THAT, THEN, WE'RE GOING TO GO OFF THE

RECORD AT 1:57 P.M.

THIS IS THE END OF DISK NO. 3 AND THE END OF THE

DEPO. WE'RE OFF THE RECORD.

(WHEREUPON, THE DEPOSITION WAS ADJOURNED AT

1:57 P.M.)

-000-

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STATE OF CALIFORNIA

COUNTY OF LOS ANGELES ss.

I DO SOLEMNLY DECLARE UNDER PENALTY OF PERJURY

THAT THE FOREGOING IS MY DEPOSITION UNDER OATH; THAT

THESE ARE THE QUESTIONS ASKED OF ME AND MY ANSWERS

THERETO; THAT I HAVE READ SAME AND HAVE MADE THE

NECESSARY CORRECTIONS, ADDITIONS OR CHANGES TO MY

ANSWERS THAT I DEEM NECESSARY.

EXECUTED AT

CALIFORNIA, ON 20

CLARK ROBERT NIXDORF CARR

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STATE OF CALIFORNIA

COUNTY OF LOS ANGELES ss.

I, ROBIN LEONARD, A CERTIFIED SHORTHAND

REPORTER LICENSED BY THE STATE OF CALIFORNIA, CERTIFY:

THAT THE FOREGOING DEPOSITION OF CLARK ROBERT

NIXDORF CARR WAS TAKEN BEFORE ME PURSUANT TO NOTICE AT

THE TIME AND PLACE THEREIN SET FORTH, AT WHICH TIME THE

WITNESS WAS PUT UNDER OATH BY ME;

THAT THE TESTIMONY OF THE WITNESS AND ALL

OBJECTIONS MADE AT THE TIME OF THE EXAMINATION WERE

RECORDED STENOGRAPHICALLY BY ME AND WERE THEREAFTER

TRANSCRIBED;

THAT THE FOREGOING IS A TRUE RECORD OF THE

TESTIMONY AND OF ALL OBJECTIONS AT THE TIME OF THE

EXAMINATION.

IN WITNESS THEREOF, I HAVE SUBSCRIBED MY NAME

THIS 19TH DAY OF JULY, 2012.

LICENSE NUMBER 3334

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