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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APPEARANCES CONTINUED
FOR PLAINTIFFS:
FRANKLIN LAW LLC
BY: REBECCA FRANKLIN, ATTORNEY AT LAW
400 COLONY SQUARE
1201 PEACHTREE STREET
SUITE 900
ATLANTA, GEORGIA 30361
FOR DEFENDANT NARCONON INTERNATIONAL:
CARLOCK, COPELAND & STAIR, LLP
BY: DAVID F. ROOT, ESQ.
191 PEACHTREE STREET, NE
SUITE 3600
ATLANTA, GEORGIA 30303
MOXON & KOBRIN
BY: HELENA K. KOBRIN, ATTORNEY AT LAW
3500 W. OLIVE
SUITE 300
BURBANK, CALIFORNIA 91302
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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
ATLANTA, GEORGIA 30357
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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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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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
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188
175
172
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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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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
INTERNATIONAL, CORRECT?
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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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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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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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.
Q BY MR. HARRIS: ALL RIGHT.
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.
Q BY MR. HARRIS: ALL RIGHT.
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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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
NARCONON INTERNATIONAL?
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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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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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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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
Q
A
Q
A
Q
A
Q
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.
DO YOU SEE WHERE I'M READING?
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
NARCONON INTERNATIONAL.
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
INTERNATIONAL, CORRECT?
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."
DO YOU SEE WHERE I'M READING?
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?
MR. ROOT: OBJECT TO THE FORM.
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.
Q BY MR. HARRIS: ALL RIGHT.
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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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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Q
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.
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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
VIDEOTAPE DEPOSITION OF CLARK CARR.
Q BY MR. HARRIS: JUST FOR THE RECORD, I'VE
MARKED YOUR DEPOSITION NOTICE, THE 30 (B) (6) DEPOSITION
NOTICE, AS EXHIBIT 26.
(WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS
MARKED FOR IDENTIFICATION BY THE SHORTHAND REPORTER AND
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?
MR. ROOT: OBJECT TO THE FORM.
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.
Q BY MR. HARRIS: ALL RIGHT.
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."
DO YOU SEE WHERE I'M READING?
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.
Q BY MR. HARRIS: ALL RIGHT.
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
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
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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
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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.
MR. ROOT: OBJECT TO THE FORM.
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.
MR. ROOT: OBJECT TO THE FORM.
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.
MR. ROOT: 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?
MS. RICHARDSON: OBJECT TO THE FORM.
MR. ROOT: OBJECT TO THE FORM.
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?
MR. ROOT: OBJECT TO THE FORM.
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"?
MR. ROOT: OBJECT TO THE FORM.
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?
MR. ROOT: OBJECT TO THE FORM.
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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MR. ROOT: OBJECT TO THE FORM.
MS. RICHARDSON: OBJECT TO THE FORM.
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?
MR. ROOT: OBJECT TO THE FORM.
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?
MS. RICHARDSON: OBJECT TO THE FORM.
MR. ROOT: OBJECT TO THE FORM.
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?
MR. ROOT: OBJECT TO THE FORM.
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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MR. ROOT: OBJECT TO THE FORM.
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.
MS. RICHARDSON: OBJECT TO THE FORM.
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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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) .
THE VIDEOGRAPHER: WE ARE BACK ON THE RECORD AT
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.
(WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS
MARKED FOR IDENTIFICATION BY THE SHORTHAND REPORTER AND
ATTACHED HERETO) .
Q BY MR. HARRIS: ALL RIGHT.
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
NARCONON INTERNATIONAL?
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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
NARCONON OF GEORGIA?
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?
MR. ROOT: OBJECT TO THE FORM.
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
NARCONON INTERNATIONAL?
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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1 A IT IS DONE ON A ROTATING BASIS OF LOOKING AT
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?
MR. ROOT: OBJECT TO THE FORM.
MS. RICHARDSON: OBJECT TO THE FORM.
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.
Q BY MR. HARRIS: ALL RIGHT.
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?
MS. RICHARDSON: OBJECT TO THE FORM.
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.
Q BY MR. HARRIS: ALL RIGHT.
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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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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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.
DO YOU SEE WHERE I'M READING?
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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A
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.
Q BY MR. HARRIS: OKAY.
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.
MR. ROOT: OBJECT TO FORM.
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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(WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS
MARKED FOR IDENTIFICATION BY THE SHORTHAND REPORTER AND
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
NARCONON OF GEORGIA?
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.
(WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS
MARKED FOR IDENTIFICATION BY THE SHORTHAND REPORTER AND
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.
MR. ROOT: OBJECT TO FORM.
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.
MR. ROOT: OBJECT TO FORM.
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) .
THE VIDEOGRAPHER: WE ARE BACK ON THE RECORD AT
APPROXIMATELY 1:11 P.M.
THIS IS THE BEGINNING OF DISK NO. 3 OF THE
VIDEOTAPE DEPOSITION OF CLARK CARR.
Q BY MR. HARRIS: ALL RIGHT.
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.
(WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS
MARKED FOR IDENTIFICATION BY THE SHORTHAND REPORTER AND
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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(WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS
MARKED FOR IDENTIFICATION BY THE SHORTHAND REPORTER AND
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.
(WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS
MARKED FOR IDENTIFICATION BY THE SHORTHAND REPORTER AND
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
NARCONON INTERNATIONAL.
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.
(WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS
MARKED FOR IDENTIFICATION BY THE SHORTHAND REPORTER AND
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.
Q BY MR. HARRIS: OKAY.
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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MR. ROOT: OBJECT TO THE FORM.
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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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
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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.
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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.
(WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS
MARKED FOR IDENTIFICATION BY THE SHORTHAND REPORTER AND
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.
THE VIDEOGRAPHER: OKAY.
WE'RE GOING TO GO OFF THE RECORD AT
APPROXIMATELY 1:32 P.M.
(RECESS HELD) .
THE VIDEOGRAPHER: OKAY.
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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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?
13:45:47 9
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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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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
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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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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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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.
THE VIDEOGRAPHER: OKAY.
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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