10A28641 2 2012-07-10 DepositionOfYarkoManzanares Ocr

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R. Leonard, C.S.R., me.
Certified Shorthand Reporters
818.995.2449
:rN THE STATE COURT OF DEKALB COUNTY'
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STATE OF GEORGIA 2
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APPEARANCES CONTr NUED
4 FOR DEFENDANT NARCONON INTERNATIONAL:
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PATRICK C . DESMOND AND NARY C.
DESMOND, INDIVIDUALLY, AND
MARY C. DESMOND, AS
ADMXNXSTRATRIXOF THE ESTATE
OF PATRICK W. DESMOND,
PLAINTIFFS,
vs.
NARCONON OF GEORGIA, INC. ,
DELGADO DEVELOPMENT, INC . ,
SOVEREIGN PLACE LLC, SOVEREIGN
PLACE ARAR.TMENT MANAGEMENT, INC.,
LISA CAROLINA ROBBINS, M.D.,
THE ROBBINS GROUP, INC, , AND
NARCONON rNTERNATIONAL,
DEFEND:ANTS.
CIVIL ACTION
NO. 10A28641- 2
DEPOSITION OF YARKO MANZANARES
TUESDAY, JULY 10, 2012
REPORTED BY:
ROBIN LEONARD
CSR NO . 3 3 34
R. LEONARD, C . S . R . , TNC .
CERTIFIED SHORTHAND REPORTERS
4142 MEADOW RIDGE P LACE
ENCINO, CALIFORN1A 91436
(818) 995-24 49
FILE NO. : 37158-l.
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THE DEPOSITION OF YARKO MANZANARES,
WITNESS , TAKEN ON BEHALF OF PLAINTIFFS,
AT 7000 HOLLYWOOD BOULEVARD, BARCELONA
HOLI..YWOOD, CALIFORNIA 90028,
AT 1 0:20 A.M. , TUESDAY, JULY 2012,
BEFORE ROBrN CSR NO. 3334 , A
CERTIFIED SHORTHAND REPORTER WiTHrN AND FOR
THE COUNTY OF LOS ANGELES AND
STATE OF CALIFORNIA, PURSUANT TO NOTICE .
15 APPEARANCES OF COUNSEL:
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FOR PLA:tNT:IFFS:
FRANKLIN LAW LLC
BY: REBECCA FBANKLIN, ATTORNEY AT LAW
400 COLONY SQUARE
1201 PEACHTREE STREET
SUITE 900
ATLANTA, GEORGIA 30361
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CARLOCKr COPELAND & STAIR, LLP
BY: DAVID F . ROOT, ESQ.
191 PEACHTREE STREET, NE
SUITE 3600
MOXON & KOBRIN
BY: HELENA K. K OBRIN, ATTORNEY AT LAW
3500 W. OLIW
SUITE 300
BURBANK, CALIFO.RN:IA 91302
FOR DEFENDANT NARCONON OF GEORGIA, INC.:
DREW, ECKLE l.:i FARNHAM, LLP
BY: LISA RICHARDSON, ATTORNEY AT LAW
880 W. PEACHTREE STREET
P . O . BOX 7600
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FOR DEFENDANT DELGADO DEVELOPMENT, INC.:
DOWNEY & CLEVELAND, LLP
BY: CALVIN P . ESQ.
288 WASHINGTON AVENUE
MARIETTA, GEORGIA 300 60
(APPEARING TELEPHONICALLY)
ALSO PRESENT: DENNIS DAVIS (VIDEOGRAPHER)
CLARK CARR
Desmond vs. Narconon
Deposition of Yarko Manzanares
July 10, 2012
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1 I N D E X
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WITNESS EXAMINATION
YARKO MANZANARES BY MS. FRANKLIN
BY MR. ROOT
E X H : B I T S
MARKED
1 NARCONON OF GEORGIA EXECUTIVE
DIRECTOR WEEKLY REPORT
2 INFORMATION CENTER REPORT
NARCONON OF GEORGIA
3 NARCONON OF G0RGIA ALLOCATION
FORM
R. Leonard, C.S.R., Inc.
818.995.2449
PAGE
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90
PAGE
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11 E-MAIL FROM PHIL HART, EXECUTIVE
DIRECTOR OF NARCONON INTERNATIONAL,
TO MARY RIESER
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1 INDEX CONTINUED
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3 4 MAY 29, 2007 REQUEST FOR HELP IN
OBTAINING A REFUND FROM NARCONON OF
5 GEORGIA
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9 /12 /07 E-MAIL REGARDING A REFUND
FROM NARCONON OF GEORGIA
FEBRUARY; 2008 E-MAILS REGARDING
11 A REFUND CYCLE FROM NARCONON OF
12 GEORGIA
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:14 7 MARCH 12, 2008 E-MAIL REGARDING A
15 REFUND FROM NARCONON OF GEORGIA
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17 MARCH 12, 2008 E-MAIL REGARDING
18 A REFUND FROM NARCONON OF
19 GEORGIA
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21 E- MAIL STREAM DISCUSSION REGARDING
22 THE PHASE OUT OF DELGADO
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24 10 JETTE MAC CARTHY' S DEBRIEF ON THE
25 NARCONON OF GEORGIA rNSPECTION
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HOLLYWOOD, CALIFORNIA; TUESDAY, JULY 10, 2012
10:20 A.M.
-000-
THE VIDEOGRAPHER: GOOD MORNING. MY NAME IS DENNIS
DAVIS. I 'M A CERTIFIED LEGAL VIDEO SPECIALIST
REPRESENTING LEONARD, R. LEONARD CSR. I AM NOT
FINANCIALLY INTERZSTED IN THIS ACTION NOR AM 1 A
RELATIVE OR EMPLOYEE OF ANY ATTORNEY OR ANY OF THE
PARTIES .
TODAY ' S DATE IS lUESDAY, JULY lOTH, 2012. THE
TIME IS APPil.OXIMATELY 10 :20 AM. THIS DEPOSITION IS
TAKING PLACE AT THE HOLLYWOOD ROOSEVELT HOTEL, BARCELONA
ROOM, AT 7000 HOLLYWOOD BOULEVARD IN HOLLYWOOD,
CALIFORNIA. THE CASE NO. IS10A 28641-2, ENTITLED
PATRICK C. DESMOND VS . OF GEORGIA, ET AL.
THIS DEPOSITION IS BEING TAKEN ON BEHALF OF THE
PLAINTIFF. OUR DEPONENT IS YARKO MANZANARES . THE COURT
REPORTER IS ROBIN LEONARD.
COULD WE HAVE APPEARANCES FOR THE RECORD .
MS. FRANKLIN: REBECCA FRJ]KLIN ON BEHALF OF THE
DESMOND FAMILY.
MR. ROOT : DAVE ROOT ON BEHALF OF NARCONON
INTERNATIONAL.
Deposition of Y arko Manzanares
July 10, 2012
818.995.2449
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1 MS. KOBRIN: HELENA KOBRIN ON BEHALF OF NARCONON 1 A THAT MEANS THAT NARCONON CENTERS PRODUCE, THEY
2 INTERNATIONAL AND THE WITNESS. 2 DELIVER THE PROGRAM CORRECTLY AND THAT'S ALL .
3 MR. CARR: CLARK CARR ON BEHALF OF NARCONON 3 Q HOW LONG HAVE YOU BEEN DEPUTY EXECUTIVE
4 INTERNATIONAL. 4 DIRECTOR OF PRODUCTION?
5 MS . RICHARDSON : LISA RICHARDSON ON BEHALF OF 5 A FOR A YEAR NOW.
6 NARCONON OF GEORGIA. 6 Q OKAY.
7 MR. YAEGER: CALVIN YAEGER FOR DELGADO DEVELOPMENT. 7 WHAT DID DID YOU WORK FOR NARCONON
8 MS. FRANKLIN: ROBIN, WILL YOU PLEASE SWEAR IN THE 8 INTERNATIONAL BEFORE THAT?
9 WITNESS . 9 A YES .
10 10 Q WHAT WAS YOUR TITLE THEN?
11 YARKO MANZANARES, 11 A IT OPERATIONS SUPERVISOR.
12 A WITNESS HEREIN, HAVING BEEN DULY 12 Q HOW LONG WERE YOU OPERATIONS SUPERVISOR?
13 WAS EXAMINED AND TESTIFIED AS FOLLOWS : 13 A FOR ABOUT FOUR YEARS .
14 14 Q SO YOU STARTED AS OPERATIONS SUPERVISOR
15 EXAMINATION 15 SOMETIME AROUND 2007?
16 16 A PROBABLY EARLIER. 2005, I WOULD SAY.
17 BY MS. FRANKLIN: 17 Q AND DID YOU ilORK FOR NARCONON INTERNATIONAL
18 Q MANZANARES, NILL YOU PLEASE STATE YOUR NAME 18 BEFORE THAT?
19 FOR THE RECORD . 19 A YES .
20 A YARKO MANZANARES . 20 Q WHAT DID YOU DO?
21 Q HAVE YOU EVER GIVEN A DEPOSITION BEFORE? 21 A I WAS CONSULTING THE SPANISH SPEAKING AREAS.
22 A NO. 22 Q I FORGOT TO NENTION. WE ' RE HERE IN HOLLYWOOD,
23 Q I' M SURE YOUR LAWYERS HAVE EXPLAINED THE 23 CALIFORNIA TO TAKE YOUR DEPOSITI ON TODAY, CORRECT?
24 PROCESS TO YOU BUT JUST TO BE SURE, I ' H GOING TO BE 24 A (NITNESS NODS HEAD IN THE AFFIRMATIVE) .
25 ASKING YOU SOME QUESTIONS . AS YOU KNOW, I REPlESENT THE 25 Q AND THAT ' S WHERE YOU LIVE?
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1 FAMILY OF PATRICK DESMOND IN A LAY/SUIT Pt:NDING IN DEKALB 1 A YES .
2 COUNTY, GEORGIA, AND THROUGHOUT THE DAY I' LL BE ASKING 2 Q THAT ' S WHERE YOU WORK?
3 YOU SOHE QUESTIONS
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AND IF YOU DON ' T UNDERSTAND MY 3 A YES.
4 QUESTION PLEASE ASK ME TO CLARIFY IT. 4 Q THAT ' S WHERE THE NARCONON INTERNATIONAL IS
5 YOU MAY OR MAY NOT KNOW THAT THE COURT HAS 5 HEADQUARTERED, CORRECT?
6 INSTRUCTED THE PARTIES AND THE LAWYERS, WITNESSES IN 6 A YES .
7 THIS CASE NOT TO CONFER WITH THEIR LAWYERS DURING ANY 7 Q ALL RIGHT .
8 BREAKS , SO IF YOU HAVE QUESTIONS FOR ME AEOUT ANY 8 AND YOU SAY BEFORE 2005 YOU NERE CONSULTING
9 DOCUMENTS THAT'S FINE, WE CAN GO THROUGH IT, BUT IT ' S 9 SPANISH SPEAKING
10 GOING TO BE SORT OF A QUESTION-AND-ANSWER SESSION 10 A AREAS .
11 BETWEEN THE BOTH OF US . 11 Q -- AREAS . WHAT DOES THAT MEAN?
12 OKAY? 12 A THE LATIN AMERICA AREA, SPAIN.
13 A OKAY. 13 Q OKAY.
14 Q ALL RIGHT. 14 SO YOU WORKED IN CALIFORNIA CONSULTING WITH
15 LET'S START WITH WHERE YOU WORK. WHAT DO YOU 15 NARCONON CENTERS IN OTHER COUNTRIES?
16 DO FOR A LIVING, MR. MANZANARES? 16 A YES.
17 A I WORK FOR NARCONON INTERNATIONAL. 17 Q OKAY.
18 Q OKAY . 18 HOW LONG DID YOU DO THAT?
19 AND WHAT IS YOUR JOB TITLE? 19 A FROM 2002 .
20 A IT ' S DEPUTY EXECUTIVE DIRECTOR FOR PRODUCTION . 20 Q WHAT DID YOU DO BEFORE THAT JOB?
21 Q OKAY . 21 A BEFORE THAT JOB I WAS NOT \mH NARCONON,
22 AND WHAT DO YOU DO AS DEPUTY EXECUTIVE DIRECTOR 22 Q ALL RIGHT.
23 FOR PRODUCTION? 23 WHAT WERE YOU DOING BEFORE YOU STARTED WORKING
24 A
25 Q
YEAH. I OVERSEE THAT PRODUCTION HAPPENS . 24 FOR NARCONON?
WHAT DOES THAT MEAN? 25 A I WAS DESIGNING LABELS FOR \lATER COMPANY.
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1 Q FOR A WATER COMPANY? 1 A UH-HUH.
2 A YES . 2 Q OKAY.
3 Q GRAPHICS DESIGNER? 3 SO IN 2008 OR 2007/2008 TIME FRAME YOU WERE THE
4 A YES. 4 SUPERVISOR FOR NARCONON INTERNATIONAL?
5 Q OKAY. 5 A YES .
6 HOW DID YOU BECOME INVOLVED WITH NARCOKON 6 Q AND EXPLAIN TO ME WHAT YOUR JOB DUTIES WERE AS
7 INTERNATIONAL? 7 THAT, IN THAT POSITION.
8 A BECAUSE BEFORE THAT I NORKED WITH NARCONON OF 8 A IT ' S ENSURING THAT THE PROGRAM IS DELIVERED AS
9 LOS ANGELES AT THE REHAB CENTER. 9 IS GIVEN THROUGH OUR LICENSE TO THE DIFFERENT CENTERS.
10 Q OKAY. 10 Q OKAY.
11 WHAT DID YOU FOR NARCONON LOS ANGELES? 11 DO YOU HAVE A CERTAIN NUMBER OF CENTERS THAT
12 A LET ME SEE. BECAUSE I HAD TWO OR THREE THINGS 12 YOU ARE IN CHARGE OF OR DO YOU OVERSEE THAT ALL THE
13 GOING ON THERE . I HAD TO DEAL DIRECTLY NITH SUPERVISION 13 NARCONON PROGRAMS -- DO YOU ENSURE THAT ALL THE NARCONON
14 OF STUDENTS, DELIVERING OF THE PROGRAH, ETC. 14 PROGRAHS ARE DELIVERED CORRECTLY? DOES THAT N.AKE SENSE?
15 Q OKAY, 15 A NO.
16 HOW LONG HAVE YOU BEEN INVOLVED WITH ANY 16 Q LET REPHRASE THAT QUESTION.
17 NARCONON PROGJW.l? 17 A ALL RIGHT .
18 A SINCE 1994. 18 Q DO YOU HAVE NARCONON CENTERS THAT YOU
19 Q OKAY, 19 WERE IN CHARGE OF IN 2007/2008?
20 AND HOW DID YOU BECOME INVOLVED WITH Nl\J\CONON 20 A CERTAIN? NO. IT
1
S NOT LIKE SPECIFIC.
21 IN 1994? 21 Q OKAY.
22 A I MET WITH A FRIEND OF MINE. SHE \lAS WORKING 22 A YEAH .
23 THERE. SHE INVITED ME THERE AND THEN SHE ASKED ME TO 23 Q SO OKAY.
24 STAY WI TH THEM AND I DID. 24 LET HE ASK YOU A LITTLE BIT ABOUT THE DAI LY
25 Q ALL RIGHT. 25 OPERATIONS BETWEEN NARCONON INTERNATIONAL AND NARCONON,
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1 DO YOU HAVE ANY TRAINING IN DRUG OR ALCOHOL 1 LEI'S SAY, OF GEORGIA OR ANY SPECIFIC NARCONON CENTER.
2 REHABILITATION? 2 OKAY?
3 A YES. 3 WHAT ARE THE REPOKTING REQUIR3MENTS FOR -- WHAT
4 Q TELL ME ABOUT THAT . 4 WERE THE REPORTING REQUIREMENTS FOR NARCONON OF GEORGIA
5 A THAT ' S THE CHEMICAL DEPENDENCY COUNSELOR. 5 AS IT RELATES TO NARCONON INTERNATIONAL IN 2008?
6 THAT
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S THE ONE I HAVE . 6 A REQUIREMENTS? I DON'T GET IT.
7 Q ALL RIGHT. 7 Q OK.IIY,
8 A AND THE NARCONON TRAINING . 8 WERE, WAS NARCONON 0? GEORGIA REQUIRED TO
9 Q OKAY. 9 REPORT ANYTHING TO NARCONON INTERNATIONAL AT ANY TIME IN
10 SO NARCONON ITSELF HAS SOME TRAINING FOR FOLKS 10 2008?
11 WHO DELIVER THE PROGRAM, RIGHT? 11 A OH. NO.
12 A RIGHT. 12 Q THEY WEREN ' T REQUIRED TO REPORT ANYTHING?
13 Q YOU'VE DONE THAT AND YOU'VE GOT YOUR CHEMICAL 13 A NO.
14 DEPEHDENCY COUNSELOR CERTIFICATION SEPARATE l>.ND APART 14 Q OKAY.
15 FROM THE NARCONON PROGRAM? 15 THEY DIDN ' T HAVE TO SEND IN ANY \YEEKLY REPORTS?
16 A YEAH . 16 A THEY SEND THEM BUT IT'S NOT REQUIRED FROM THEM.
17 Q OKAY. 17 Q OKAY.
18 WHEN DID YOU GET THAT? 18 WHY WOULD NARCONON OF GEORGIA OR ANY NARCONON
19 A THAT WAS IN 2002 . 19 CENTER SEND IN A WEEKLY REPORT IF THEY WEREN
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T REQUIRED
20 Q DO YOU HAVE TO BE RECERTIFIED TO KEEP THAT 20 TO DO SO?
21 LICENSE CURRENT? 21 A IT'S LIKE INFORMATION POINT. THAT
1
S HOW IT
22 A JUST UPDATING EVERY YEAR. 22
23 Q AND DO YGU DO THAT? 23 Q OKJIY.
24 A YEAH. 24 DO YOU UNDERSTAND HY QUESTION?
25 Q YOU'RE CURRENT WITH THAT LICENSE NOW? 25 A WELL, IF YOU CAN SAY IT DIFFERENTLY.
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Desmond vs. N arconon
July 10, 2012
R. Leonard, C.S.R., fuc.
818.995.2449
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1 Q OKAY. 1 THAT'S THE ANSWER TO MY QUESTION?
2 DO YOU KNOW NHY NARCONON OF GEORGIA WOULD HAVE 2 A WHAT WAS THE QUESTION AGAIN?
3 REPORTED, SENT IN ANY WEEKLY REPORTS TO NARCONON 3 Q WHAT WAS THE -- DO YOU SEE I
1
M LOOKING AT
4 INTERNATIONAL IF THEY WEREN ' T REQUIRED TO DO SO? 4 THE TOP OF THIS DOCUMENT?
5 A IT'S AN INFORMATION LINE THAT THEY CAN 5 A YEAH. YEAH.
6 ORIGINATE AND SEND IT . 6 Q IT SAYS DATA FILES NN INT, RIGHT?
7 Q OKAY. 7 A OH-HUH . YES .
8 SO IT ' S JUST GRATUITOUS? THEY'RE DOING IT TO 8 Q DO YOU KNOW WHAT THAT MEANS?
9 GIVE YOU INFORMATION, NARCONON INTERNATIONAL INFORHATION 9 A YEAH. THAT'S JUST FILES.
10 FOR NO OTHER REASON EXCEPT TO PROVIDE YOU INFORMATION? 10 Q OKAY.
11 HS. RICHARDSON: OBJECT TO THE FORM OF THE 11 A THAT MEANS IT GETS FILED.
12 QUESTION . 12 Q OKAY.
13 Q BY MS . FRANKLIN: YOU CAN GO AHEAD AND ANSWER. 13 SO THIS DOCUMENT THAT ' S TITLED NARCONON OF
14 THERE MAY BE S0!1E DISCUSSION OR OBJECTIONS MADE BUT 14 GEORGIA EXECUTIVE DIRECTOR WEEKLY REPORT --
15 UNLESS, UNLESS I TELL YOU NOT TO OR TO STOP YOU 15 A UH-HUH.
16 CAN GO AP.EAD AND ANSWER A QUESTION. 16 Q -- GETS SENT TO NARCONON INTERNATIONAL AND IT
17 A WHAT'S THE QUESTION AGAIN? 17 GETS FILED THERE, CORRECT?
18 MS. FRANKLIN: CAN YOU READ THAT BACK, ROBIN, 18 A YES.
19 PLEASE. 19 Q AND IS THERE A REQUIREMENT THAT NARCONON
20 (QUESTION READ). 20 INTERNATIONAL SEND A WEEKLY REPORT SUCH AS THIS TO
21 THE \HTNESS : YEAH. PROVIDE INFORMATION. 21 NARCONON -- I 'M SORRY -- NARCONON OF GEORGIA SEND A
22 Q BY MS. FRANKLIN: DOES NARCONON INTERNATIONAL 22 WEEKLY REPORT LIKE THIS TO NARCONON INTERNATIONAL?
23 REVIEW THE INFORMATION PROVIDED BY NARCONON OF GEORGIA? 23 MR. ROOT: COULD YOU GIVE THAI QUESTION AGAIN,
24 A SOMETIMES. IT'S NOT SOMETHING THAT ' S LIKE 24 REBECCA? I' M SORRY.
25 WRITTEN TO OR AGREED TO LIKE LOOK AT IT EVERY Tlt1E IT 25 MS. FRANKLIN: SURE.
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1 ARRIVES. 1 Q IS THERE A REQUIREMENT THAT NARCONON OF GEORGIA
2 Q OKAY. 2 PROVIDE A WEEKLY REPORT SUCH AS THIS TO NARCONON
3 DO YOU HAVE EXHIBIT STICKERS? THANKS. 3 INTERNATIONAL?
4 MR . MANZANARES, I'M GOING TO HAND YOU WHAT I'M 4 A SAY THE CENTER GETS THIS AND THEY MAY SEND
5 MARKING AS EXHIBIT 1 TO YOUR DEPOSITION. 5 IT, THEY MAY NOT SEND IT.
6 (WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS 6 Q OKAY .
7 MARKED FOR IDENTIFICATION BY SHORTHAND REPORTER AND 7 COMPLETELY UP TO THE INDIVIDUAL CENTER?
8 ATTACHED HERETO). 3 A YEAH.
9 Q BY HS. FRANKLIN: AND I 'D LIKE YOU TO TAKE A 9 Q OKAY.
10 MOMENT -- THERE SHOULD BE COPIES FOR EVERYONE -- TO LOOK 10 AND THE TOP OF THIS IS COPIED ED NARCONON
11 AT THAT AND TELL ME IF YOU RECOGNIZE THESE TViO DOCUMENTS 11 EASTERN U.S.
1
CORRECT?
12 THAT ARE TITLED "EXECUTIVE DIRECTOR WEEKLY REPORT." 12 A RIGHT.
13 A YES . 13 Q ALL RIGHT .
14 Q OKAY. 14 AND THEN WHAT IS OPS SUP NN EASTERN U.S.?
15 HOW DO YOU RECOGNIZE THOSE? 15 A THAT'S OPERATIONS SUPERVISOR NARCONON EASTERN
16 A I SAW THIS DOCUMENT WHEN I WAS GETTING READY 16 UNITED STATES.
17 FOR THE DEPOSITION. 17 Q OKAY .
18 Q OKAY. 18 SO THERE
1
S AN OPERATIONS SUPERVISOR BOTH AT
19 AND HAD YOU SEEN THE DOCUMENT BEFORE THAT? 19 NARCONON INTERNATIONAL AND THEN THE REGIONAL NARCONON,
20 A NO. 20 IN THIS CASE IT'S EASTERN U.S., CORRECT?
21 Q ARE YOU-- WAS YOUR TITLE OPS -- I'M SORRY. 21 A RIGHT .
22 WHAT DOES IT MEAN AT THE TOP IIHEN IT SAYS DATA 22 Q AND IN 2008, WHO WAS THAT?
23 FILES NN INT? 23 A IT WAS PROBABLY ISAAC.
24 A THAT MEANS IT ' S A FILING. 24 Q ISAAC . HIS LAST NAME?
25 Q THAT ' S THE ANSWER TO YOUR QUESTION? I MEAN, 25 A ZRIHEN.
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818.995.2449
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Q ALL RIGHT.
SO DO YOU -- WELL, WHEN YOU OPERATIONS
SUPERVISOR AT INTERNATIONAL , DID YOU EVER REVIEW THESE
WEEKLY REPORTS?
A I DON' T REMEMBER .
Q OKAY.
DID YOU -- RON THESE WEEKLY REPORTS FILED?
A IT' S JUST, IT ' S A HARD COPY THAT GETS FILED IN
THE FOLDER.
Q OKAY.
IN A FILING CABINET?
A YEAH.
Q YOU DON ' T HAVE ANY ELECTRONIC VERSIONS OF THESE
REPORTS?
A NO.
Q NO DATA BASE SYSTEM WHERE THESE THINGS
STORED?
A NO.
Q OKAY.
WERE THESE REPORTS, TO YOUR KNOWLEDGE, SENT
ELECTRONICALLY OR WERE THEY MAILED OR FAXED?
A I DON'T KNOW.
Q ALL RIGHT.
AND DO YOU KNOW WHETHER ANYONE AT NARCONON
INTERNATIONAL EVER REVIEWED THESE WEEKLY REPORTS?
PAGE 22
A NO, I DON'T KNOW.
Q OKAY .
AND IT ' S YOUR TESTIHONY HERE TODAY THAT THERE
21
IS NO PROCEDURE DR REQUIREMENT FOR A CENTER TO SEND IN A
REPORT TO NARCONON INTERNATIONAL?
A UH-HUH.
Q ALL RIGHT .
WHAT ABOUT WEEKLY STATISTICS, ARE NARCONON
CENTERS REQUIRED TO SEND THOSE IN?
A THEY SEND THEM, YES .
Q OKAY .
ARE THEY REQUIF.ED TO?
A YES.
Q ALL RIGHT.
AND TELL ME ABOUT THOSE REQUIREMENTS .
A JUST THEY NEED TO SEND THE NUMBERS.
Q OKAY.
AND IS THAT WRITTEN DOWN SOMEWHERE?
A vJHAT ' S WRITTEN DOWN
Q THE REQUIREMENT THAT LOCAL CENTERS SEND IN
THEIR WEEKLY STATISTICS.
A SPECIFICALLY NOT. THEY ' RE JUST GIVEN A FORM.
Q OKAY.
A AND THEY FOLLOW THAT FORM.
Q AND HOW DO THEY KNOW THAT THEY HAVE TO SEND IT
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IN WEEKLY?
A i3ECAUSE IT' S THERE, I THINK.
Q OKAY.
SO THERE IS SOME SORT OF WRITTEN REQUIREMENT
FOR A NARCONON CENTER TO SEND IN A WEEKLY REPORT ON
STATI STICS?
A I \vOOLD HAVE TO SEE IT BECAUSE I DON'T REMEMBER
IF THERE ' S SPECIFIC THINGS REQUIRED.
Q OKAY.
BUT THEY DO IT, RIGHT?
A OR-HUH. TREY SEND IT.
Q AND NARCONON INTERNATIONAL REVI EWS THOSE
NUMBERS, CORRECT?
A IF NEEDED, YEAH .
Q AND THAT ' S PART OF YOUR J03, RIGHT? IT WAS
PART OF YOUR JOB AS THE OPERATIONS SUPERVISOR?
A NOT NECESSARILY BUT COULD BE.
Q WELL, DID YOU REVIEW THEM OR NOT AS OPERATIONS
SUPERVISOR?
A AT THAT TIME?
Q YES . 2008 .
A I REALLY DON' T REMEMBER IF I WAS LIKE . .. .
Q SO YOU DON' T REMEMBER ONE WAY OR THE OTHER
WHETHER YOU REVIEWED WEEKLY STATISTICS OR REPORTS?
A OF LIKE INDIVIDUAL CENTERS? NO.
PAGE 24
Q WHAT ABOUT NARCDNON OF GEORGIA, DO YOU EVER
REVMBER REVIEWING ANY WEEKLY STATISTICS THEM?
A PROBABLY DID.
Q OKAY.
DO YOU EVER REMEMBER DOING IT?
A DO I EVER REMEMBER? BECAUSE IT'S NOT LIKE
HAVING A SPECIFIC CENTER AND TO SEE IT. I DON'T
DO THAT .
Q OKAY.
DO YOU EVER REMEMBER REVIE'IIING WEEKLY
STATISTICS FROM NARCONON OF GEORGIA AS OPERATIONS
SUPERVISOR?
A LIKE LOOKING AT THEM? YEAH.
Q OKAY.
I ' M GOING TO HAND YOU WHAT I'M MARKING AS
EXHIBIT 2.
A UH-JiUH.
{WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS
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MARKED FOR BY THE SHORTHAND REPORTER AND
ATTACHED HERETO) .
Q BY MS . FRANKLIN: TELL ME IF YOU RECOGNIZE
THAT .
MS. RICHARDSON: DID YOU SAY THIS IS EXHIBIT 2?
MS . FRANKLIN : YES.
MS . RICHARDSON: THANKS.
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July 10, 2012
Ce1tified Sho1thand Reporters
818.995.2449
,..-- SHEET 7 PAGE 25 -------------, r-- PAGE 27 - ----------------,
1 THE WITNESS : NO, NOT THIS PARTICULAR DOCUMENT. 1 HR. MANZANARES, I'M HANDING YOU WHAT I'M
2 Q BY MS. FRANKLIN: OKAY. 2 MARKING AS EXHIBIT 3 TO YOUR DEPOSITION.
3 DO YOU RECOGNIZE THIS AS A FORM THAT NARCOIION 3 (WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS
4 CENTERS WOULD SEND IN WEEKLY? 4 MARKED FOR IDENTIFICATION BY THE SHORTHAND REPORTER AKD
5 A NO. 5 ATTACHED HERETO).
6 Q NO. OKAY. 6 Q BY MS. FRANKLIN: IF YOU ' LL TAKE A MINUTE TO
7 HAVE YOU EVER SEEN THIS DOCUMENT? 7 LOOK AT THAT.
8 A THIS, NO . 8 A UH-HUH.
9 Q ALL RIGHT. 9 Q TELL ME WHETHER YOU RECOGNIZE THAT AND I
10 DO YOU KNOW WHAT ANY OF THE INFORMATION 10 REALIZE THAT THERE'S FOUR PAGES HERE AND I'M JUST GOING
11 CONTAINED IN THIS DOCUMENT MEANS? 11 TO ASK YOU RIGHT NOW TO LOOK AT THE ONES WITH THE NUMBER
12 A BECAUSE THIS IS NOT THE FORM I RECEIVZ THE OR I 12 0999 AND 1000 AT THE BOTTOM, SO IT' S THE FIRST TriO
13 SEE THIS THING AND I GET IT. IT 'S INCOMPLETE. 13 PAGES.
14 Q HOW SO? 14 A UH-HUH. OKAY. YEAH .
15 A I JUST COUNTED THE ITEMS. 15 Q OKAY .
16 Q OKAY. 16 HOW DO YOU RECOGNIZE THAT?
17 HOW MANY ITEMS SHOULD BE THERE? 17 A HOW?
18 A 60. 18 Q YES .
19 Q 60. ALL RIGHT. 19 A MEANING IF I RECOGNIZE IT OR NOT?
20 WHAT ITEMS ARE HISSING? 20 Q RIGHT.
21 A I DON 'T KNOW. I WOULD HAVE TO LIKE SEE AN 21 YOU JUST TOLD ME YOU DO RECOGNIZE THESE TWO
22 ACTUAL FORM. 22 FORMS, RIGHT?
23 Q OKAY. 23 A UH-HlJH.
24 SO THIS IS A FORM THAT YOU BELIEVE IS 24 Q HOW DO YOU RECOGNIZE THEM?
25 INCOMPLETE BUT YOU ' VE SEEN SIMILAR TYPE FORMS THAT ARE 25 A BECAUSE I KNOW 1lHAT THIS DOCUMENT IS.
25 27
,-- PAGE 26 -----------------, PAGE
1 SUBMITTED BY NARCONON CENTERS? 1
28 ------------------------------,
2 A NOT LIKE THIS FORMAT . 2
3 Q OKAY. 3
4 WELL, TELL KE, DO YOU KNOW WHAT -- WELL, THE 4
5 TOP OF IT SAYS ' INFORMATION CENTER REPORT,' CORRECT? 5
6 A YEAH. ON THE VERY TOP . 6
7 Q ALL RIGHT. 7
8 AND ON THE FORMS THAT YOU ' VE SEEN BEFORE, DID 8
9 THEY HAVE CATEGORIES SUCH AS BILLS PAID? IF YOU LOOK 9
10 THAT'S THE THIRD ONE DOWN. 10
11 A UH-HUH . 11
12 WHERE DOES THIS FORM COME FROM? 12
13 Q ACTUALLY, IF YOU WILL LOOK DOWN AT THE BOTTOM 13
14 IT SAYS "DESMOND-D-GA.n 14
15 OKAY? 15
16 A UH-HUH. 16
17 Q AND SO I ' LL REPRESENT TO YOU THIS WAS PRODUCED 17
18 DURING THIS LITIGATION. 18
19 A I SEE. 19
20 Q BUT THIS IS NOT SOMETHING THAT YOU ARE FAMILIAR 20
21 WITH? 21
22 A UH-HUH. THE FORMAT OF THIS I'M NOT FAMILIAR 22
23 WITH. 23
24 Q OKAY. 24
25 ARE YOU WITH --STRIKE THAT. 25
26
Q WHAT --
A YEAH. IT ' S ALLOCATION FORM.
Q AND DO YOU REVIEW THESE ALLOCATION FORMS FROM
THE NARCONON CENTERS OR DID YOU WHEN YOU WERE OPERATIONS
SUPERVISOR?
A NO . THIS GETS FILED. IT' S JUST LIKE AN
ACCOUNT OF HOW THEY ALLOCATE THEIR FINANCES.
Q OKAY.
BOT THAT'S NOT SOMETHING YOU EVER REVIEWED AT
NARCONON INTERNATIONAL?
A NO.
Q DID ANYONE EVER REVIEW THOSE AT NARCONON
INTERNATIONAL?
A NO.
Q NO . OKAY.
A UN-HUH.
Q SO DO YOU KNOW HOw THESE THINGS WERE SENT IN
FROM THE CENTERS?
A HOW --
Q DO YOU KNOW ROW THESE FORMS, A FORM SOCH AS
THIS ONE ON THE TOP HERE, HOW IT WAS SENT TO NARCOKON
INTERNATIONAL IN 2000? WAS IT SOMETHING THAT WAS FAXED
OR E-HAILED OR MAILED?
A OH . IN THAT SENSE, I DON ' T KNOW.
Q OKAY .
28
July 10, 2012
818.995.2449
,----- SHEET 8 PAGE 29
,-- PAGE 31 ------------------.,
1
2
3
4
5
6
7
8
9
A COULD BE EITHER.
Q \\JELL, IF YOU NEVER REVIETIIED THESE, HOW DO YOU
KNOW WHAT IT IS? HOW DO YOU RECOGNIZE IT?
A BECAUSE I 'M FAMILIAR WITH THE FORM.
Q OKAY.
HOW ARE YOU FAMILIAR WITH THE FORM?
A BECAUSE --
Q
A
Q
DID YOU DRAFT IT?
NO. 3UT I' VE SEEN IT.
JUST SEEN IT IN PASSING?
A YEAH.
Q OKAY.
IT 'S NOT SOMETHING THAT YOU EVER REVIEW OR
ANALYZE OR EVALUATE?
A NO.
Q AND IS YOUR TESTIMONY TODAY THAT NO ONE AT
NARCONON INTERNATIONAL EVER REVIEWS OR ANALYZES THESE
FORMS?
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A REVIEWS OR ANALYZES? NO . I COULD SAY TREASURY
BUT THAT WOULD BE A GUESS BECAUSE THERE IS NO NEED FOR
THAT.
Q OKAY .
MR . MANZANARES, YOU PERSONALLY, WHEN YOU WERE
OPERATIONS SUPERVISOR, YOU WERE INVOLVED IN THE
DAY-TO-DAY OPERATIONS OF NARCONON GEORGIA, NEREN'T YOU?
29
_ PAGE 30
1 A NO.
2 Q YOU WERE NOT?
3 A NO.
4 Q OKAY.
5 YOU DEALT WITH CUSTOMERS WHO WERE UNHAPPY
1
6 DIDN'T YOU ?
7 A DEALT WITH CUSTOHERS? MEANING?
8 Q WELL, WHAT DO YOU CALL THRM? I CAN ' T RECALL.
9 TERMI NALS, PATRONS, WHATEVER THE SCIENTOLOGY TERM IS,
10 NARCONON TERM.
11 MR. ROOT : OBJECT TO THE FIRM.
12 Q BY MS. FRANKLIN: WHAT DOES NARCONON
13 INTERNATIONAL CALL THE PEOPLE WHO COME TO NARCONON
14 CENTERS TO GET HELP?
15 A STUDENTS .
16 Q STUDENTS . OKAY .
17 A UH-HUH.
18 Q AND SOMETIMES THE STUDENTS HAVE FAMILY MEMBERS
19 THAT PAY FOR THEIR REHAB, RIGHT?
20 A UH-HUH.
21 Q AND WHAT WOULD YOU CALL THOSE? YOU DON ' T CALL
22 THOSE CUSTOMERS?
23 A SPONSORS WOULD BE .
24 Q OKAY.
25 SO IN 2008, YOU RECEIVED A NUMBER OF COMPLAINTS
30
1 FROM SPONSORS OR STUDENTS ABOUT ISSUES AT NARCONON OF
2 GEORGIA, DIDN'T YOU?
3 A '.\HAT DO YOU MEAN BY "A NUMBER"?
4 Q LET'S JUST SAY, DID YOU RECEIVE ANY?
5 A ANY? PROBABLY ONE.
6 Q OKAY.
7 TELL ME ABOUT THAT.
8 A I DON ' T REMEMBER EXACTLY WHAT IT WAS.
9 Q OKAY.
10 SO YOU JUST REMEMBER THAT YOU RECEIVED ONE
11 COMPLAINT, CORRECT? IS THAT YOUR TESTIMONY?
12 A YES.
13 Q OKAY.
14 I'LL HAND YOU WHAT I' M MARKING AS EXHIBIT, I
15 BELIEVE WE'RE ON FOUR.
16 (viHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS
17 MARKED FOR IDENT:FICATION BY THE SHORTHAND REPORTER AND
18 ATTACHED HERETO).
19 Q BY MS. FRANKLIN: I'LL ASK YOU TO TAKE A LOOK
20 AT THAT DOCUMENT.
21 A UH-HUH.
22 Q TELL ME IF YOU RECOGNIZE THAT.
23 A OKAY . I READ IT.
24 Q OKAY.
25 DO YOU RECOGNIZE THAT?
31
_ PAGE 32 ------------------,
1 MR. ROOT : YOU 'RE TALKING ABOUT THE WHOLE THING,
2 REBECCA, OR JUST THE FIRST PAGE?
3 MS. FRANKLIN: THAT'S A GOOD QUESTION.
4 Q LET 'S START WITH THE TOP PAGE, THE ONE THAT'S
5 TITLED 0560.
6 DO YOU RECOGNIZE THAT?
7 A YEP.
8 Q WHAT IS IT?
9 A IT 'S A PERSON WRITING ASKING FOR HELP ON
10 REFUND.
11 Q ALL RIGHT .
12 AND DO YOU REMEMB3R THIS PERSON CONTACTING YOU
13 ABOUT ISSUES OR CONCERNS ABOUT A REFUND FROM NARCONON OF
14 GEORGIA?
15 A WHO WAS THIS? I DON'T REMEMBER THE NAME. I
16 REALLY --
17 Q DO YOU REMEMBER THIS PARTICULAR LETTER?
18 A NOT EXACTLY BECAUSE IT ' S A
19 Q OKAY.
20 WELL --
21 A IS THI S THE ONLY DOCUMENT BECAUSE USUALLY THERE
22 MUST BE LIKE A SEQUENCE OF LIKE WHAT'S
23 Q I'M JUST ASKING YOU ABOUT THIS ONE RIGHT NO\v.
24 OKAY?
25 A UH-HUH.
32
July 10, 2012
818.995.2449
.-- SHEET 9 PAGE 33 ------------,
1 Q AND IT, CORRECT HE IF I' H 1\lRONG, BUT IT APPEARS
2 TO BE A SPONSOR OR A STUDENT WHO IS ASKING FOR A REFUND
3 FOR PART OF WHAT THEY PAID FOR NARCONON OF GEORGIA' S
4 SERVICES.
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
IS THAT FAIR?
A IT'S ASKING FOR HELP --
Q RIGHT.
A -- ON OBTAINING THE REFUND.
Q DID YOU HELP THIS PERSON OBTAIN A REFUND?
A I WOULD HAVE TO SEE ANOTHER DOCUHENTS BECAUSE
THERE HUST BE -- USUALLY THE-- I'M SENDING THESE TYPE
OF THINGS BACK TO THE CENTER SO THEY HANDLE IT.
Q OKAY.
SO YOU DON ' T KNOW ONE WAY OR ANOTHER WHETHER
YOU HELPED THIS PERSON OBTAIN A REFUND?
A RIGHT NOW I DON'T REMEMBER. I WOULD HAVE TO
SEE LIKE IF THERE WAS A SEQUENCE OF DOCUMENTS AFTER
THIS.
Q OKAY.
BUT IT DOES APPEAR TO BE THAT THERE WAS, THAT
NARCONON OF GEORGIA REQUIRED -- WELL, NARCONON
INTERNATIONAL AND NARCONON OF GEORGIA REQUIRED THIS
SPONSOR OR FORMER STUDENT TO SIGN A RELEASE, CORRECT?
MR. ROOT : OBJECT TO THE FORM.
MS. RICHARDSON: I'LL JOIN IN THE OBJECTION.
.-----PAGE 35 -----------------,
1 Q OKAY .
2 ARE YOU FAMILIAR THIS, THE LANGUAGE IN
3 THIS RELEASE?
4 A NO .
5 Q HAVE YOU EVSR SEEN A SIMILAR TYPE RELEASE
6
7
8
9
BEFORE?
A NO.
Q ALL RIGHT.
I'M HANDING YOU I'VE MARKED AS EXHIBIT NO.
10 5.
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
(WHEREUPON, THE A60VE-MENTIONED DOCUMENT WAS
MARKED FOR IDENTIFICAT10N 3Y THE SHORTHAND REPORTER AND
ATTACHED HERETO) .
Q BY MS. FRANKLIN: TELL HE IF YOU RECOGNIZE THIS
DOCUMENT.
A OKAY.
Q DO YOU RECOGNI ZE THAT DOCUMENT?
A YEAH.
Q WHAT IS IT?
A IT' S A PARENT TEAT 'S ASKING FOR REPAYMENT AND
REFUND.
Q OKAY .
A YEAH .
Q AND IT'S A LETTER DIRECTED TOWARDS YOU,
CORRECT?
33 35

,--- PAGE 34 ,.- PAGE 36 ------------------.,
1 Q BY HS. FRANKLIN: AND I 'M SPECIFICALLY 1 A UH-HUH.
2 REFERENCING NO. 0562. 2 Q AND IT'S A PARENT IS EXPRESSING HI S OR HER
3 A UH-HUH . AND jOW IS THIS RELATED TO, TO THIS 3 CONCERNS OVER THE SERVICE OR LACK OF RELATING TO
4 THING? 4 NARCONON OF GEORGIAi IS THAT RIGHT?
5 Q WELL, YOU TELL ME . IF YOU DON'T KNOW, THEN, 5 A YEAH.
6 YOU KNOW, THAT'S A PERFECTLY FINE ANSWER . BUT I'M 6 Q OKAY .
7 ASKING YOU QUESTIONS ABOUT THIS DOCUMENT, AND THE 7 AND I'M SORRY IF YOU ALREADY ANSWERED THIS . DO
8 QUESTION WAS, THERE APPEARS TO BE A RELEASE 8 YOU SPECIFICALLY REMEMBER RECEIVING THIS LETTER?
9 NARCONON OF GEORGIA, NARCONON INTERNATIONAL AND THIS 9 A YEAH. BECAUSE I ALSO REMEMBER THE EXECUTIVE
10 FORMER STUDENT OR SPONSOR, CORRECT? 10 DIRECTOR DOWN THERE HANDLED THIS THING.
11 MR. ROOT : OBJECT TO JHE FORM. 11 Q OKAY.
12 THE WITNESS: IS THERE ANY DOCUMENT THAT FOLLOWS 12 BUT YOU SPECIFICALLY DO REMEMBER RECEIVING THIS
13 THIS BECAUSE I REALLY DON'T REMEMBER BECAUSE IT'S BEEN A 13 LETTER?
14 \VAILE. 14 A YEAH.
15 Q BY MS . FRANKLIN: I JUST NEED YOU TO HY 15 Q OKAY.
16 QUESTION IF YOU CAN. 16 I'M GOING TO, HANDING YOU WHAT I ' VE MARKED AS
17 A WHAT WAS IT? 17 EXHIBIT 6.
18 Q THERE APPEARS TO BE A RELEASE ATTACHED TO THIS 18 A UH-HUH.
19 DOCUMENT, 19 (WHEREUPON, THE ABOVE-MENTIONED DOCUHENT WAS
20 A YEAH. 20 MARKED FOR IDENTIFICATION BY THE SHORTHAND REPORTER AND
21 Q OKAY. 21 ATTACHED HERETO).
22 AND IT APPEARS TO BE A RELEASE BET\VEEN NARCONON 22 Q BY MS. FRANKLIN : AND ASK YOU WHETHER YOU
23 OF GEORGIA AND NARCONON INTERNATIONAL AND A FORMER 23 REMEMBER OR YOU RECOGNIZE THIS DOCUMENT.
24 STUDENT OR SPONSOR, CORRECT? 24 A YEAH . BUT THIS, THIS IS SEPARATE FROM THIS ONE
25 A YEAH, I SEE THE RELEASE. 25 (INDICATING} I RIGHT?
34 36
July 10, 2012
http://ReacchingForTheTippingPoint.net
818.995.2449
,.- SHEET 10 PAGE 37 -------------., ,.- PAGE 39
1 Q EXCUSE ME? 1 A YEAH.
2 A THESE TWO ARE SEPARATE? 2 Q AND WHAT DOES THAT MEAN?
3 Q RIGHT, RIGHT. 3 A THAT MEANS RECEPTION RECEIVED A CALL.
4 A OKAY. BECAUSE I KNOW THERE IS A SEQUENCE OF 4 Q OKAY .
5 THIS ONE WHERE THE EXECUTIVE DIRECTOR ACTUALLY FIX IT. 5 A YEAH. NOT ME.
6 Q OH-HUH . 6 Q ALL RIGHT .
7 JUST ASKING WHETHER YOU RECOGNIZE EXHIBIT 6. 7 SO RECEPTION RECEIVED A CALL?
8 A UH-HUH . YES . 8 A UH-HUH.
9 Q om. 9 Q ALL RIGHT .
10 AND IT APPEARS TO BE, AT LEAST THE BOTTOM 10 AND WHO IS RECEPTION?
11 PORTION, AN E-MAIL FROM YOU. YOUR E-MAI L ADDRESS AT THE 11 A SITS IN RECEPTI ON AND GETS THE CALLS .
12 TIME WAS PRODOCTION@NARCONON.ORG; IS THAT RIGHT? 12 Q AT NARCONON INTERNATIONAL?
13 A UH- HUH. 13 A YEAH .
14 Q OKAY. 14 Q OKAY .
15 AND IT' S FROI1 YOU TO CLAUDIA -- HOW DO YOU 15 SO IS IT FAIR TO SAY THAT IN 2008 AND 2009
16 PRONOUNCE HER LAST NAME? 16 NARCONON INTERNATIONAL RECEIVED SOME COMPLAINTS DIRECTLY
17 A ARCABASCIO. 17 FROI1 SPONSORS OR FORMER STUDENTS ABOUT ISSUES AT
18 Q ARCABASCIO? 18 NARCONON OF GEORGIA?
19 A UH-HUH . 19 A WHAT YEARS WAS THAT YOU SAID?
20 Q OKAY. 20 Q 2007 TO 2008.
21 AND SHE AT THE TIME WAS DIRECTOR OF LEGAL 21 A YEAH. YOU SAID 2009 EARLIER.
22 AFFAIRS? 22 Q EXCUSE ME?
23 A YES . 23 A YOU SJl.ID 2009.
24 Q ALL RIGHT . 24 Q OKAY.
25 AND IT'S AN E-MAIL FROM YOU TO CLAUDIA SAYING 25 A BOT, YEAH , I HAVE ' 07, ' 07 AND ' 08. SO TWO
f 37 39
,- PAGE 38
,-PAGE 40 - ----------------.
1 THAT SOMEONE CALLED YOU REGARDING A REFUND CYCLE FROM 1 I 07 AND ONE I OB .
2 NARCONON OF GEORGIA, RIGHT? 2 Q OKAY .
3 A NO. 3 IS IT YOUR TESTIMONY THAT -- STRIKE THAT .
4 Q ALL RIGHT . 4 SO THE ANSWER TO MY QUESTION IS YES, DURING
5 I' M GOING TO READ TO YOU YOUR E-MAIL THAT SAYS 5 2007/2008 NARCONDN INTERNATIONAL RECEIVED SOME NUMBER OF
6 'DEAR YVONNE. " I 'M SORRY. IT' S TO YVONNE. 6 COMPLAINTS DR INQUIRIES FROM SPONSORS OR FORMER STUDENTS
7 WHO IS YVONNE? 7 ABOUT ISSUES AT NARCONON OF GEORGIA, CORRECT?
B A THAT ' S THE EXECUTIVE OF THE EASTERN B MR . ROOT: OBJECT TO THE FORM.
9 UNITED STATES OFFICE. 9 THE lnTNESS : THREE,
10 Q OKAY. 10 Q BY 11S . FRANKLIN: IT' S YOUR TESTIMONY THAT IT'S
11 AND CLAUDIA IS COPIED ON IT, CORRECT? 11 ONLY THREE?
12 A YEAH . 12 A YEAH.
13 Q ALL RIGHT . 13 Q AND YOU ' RE SURE OF THAT?
14 AND SO YOU ARE E-MAILING THE EXECUTIVE DIRECTOR 14 A THAT 'S WHAT I HAVE IN MY HAND RIGHT NOll .
15 OF EASTERN U. S. SAYING THAT YOU GOT A CALL ABOUT A 15 Q OKAY.
16 REFUND CYCLE FROM NARCONON OF GEORGIA, RIGHT? 16 WE CAN GO THROUGH THEM ALL IF YOU ' D LIKE TO DO
17 A NO . NO, IT DOESN'T SAY THAT. 17 THAT. BUT MY QUESTION IS, AT LEAST THREE, RIGHT?
18 Q OKAY . 18 MR . ROOT: OBJECT TO THE FOR!1.
19 I ' H JUST GOING TO READ IT TO YOU, JUST TELL HE 19 THE lnTNESS : THAT ' S WHAT I HAVE IN MY HAND RIGHT
20 IF I READ IT CORRECTLY AND THEN YOU CAN EXPLAIN YOUR 20 NOW.
21 UNDERSTANDING. 21 Q BY MS . FRANKLIN: DO YOU BELIEVE THERE WERE ANY
22 IT SAYS "DEAR YVONNE, TODAY DIVISION ONE 22 110RE?
23 RECEIVED A CALL FROM -- ' SOMEONE . IT' S REDACTED 23 A I DON ' T REMEMBER .
24 " --REGARDING A REFUND CYCLE FROM NARCONON OF GEORGIA ." 24 Q OKAY.
25 DID I READ THAT CORRECTLY? 25 I' M GOING TO HAND YOU wHAT I' M MARKING AS
38 40
July 10, 2012
_R. Leonard, C.S.R., Inc.
818.995.2449
- SHEET 11 PAGE 41 ------ ------, ,.- PAGE 43 --- --------- ----,
1 EXHIBIT 7. 1 A YEAH. AND IT SEEMS LIK3 IT WENT TO ISAAC AND
2 A UH-HUH. 2 THEN HE FORWARDED IT TO MARY OR SOMETHIKG.
3 (WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS MARKED 3 Q RIGHT .
4 FOR IDENTIFICATION BY THE SHORTHAND REPORTER AND 4 AND IT CC ' D YOU, CORRECT?
5 ATTACHED HERETO) . 5 A YEAH .
6 Q BY MS. FRANKLIN: TELL ME IF YOU RECOGNIZE 6 Q ALL RIGHT.
7 THAT. 7 AND IT APPEARS TO BE AN E-MAIL TO NARCONON
8 A UH-HUH . 8 PUBLIC INFORMATION OFFICER WHERE IT LOOKS LIKE A FORMER
9 Q OKAY . 9 STUDENT OR A SPONSOR SAYS "I BELIEVE NARCONON
10 AND IT APPEARS TO BE, AT LEAST INITIALLY, AN 10 INTERNATIONAL CONDONES OR SUPPORTS THE NONPROFESSIONAL,
11 E-MAIL FROM YOU TO YVONNE, CORRECT? 11 NEGLIGENT OPERATIONS AND UNHEALTHY ENVIRONMENT THAT
12 A YES. 12 EXISTS AT THE NARCONON OF GEORGIA FACILITY."
13 Q IT SAYS THAT NARCONON, "THE DIVISION SIX NNI 13 DID I READ THAT CORRECTLY?
14 RECEIVED A CALL FROM' SOMEONE
1
REGARDING," QUOTE, 'A 14 A YEAR.
15 PROBLEM SHE BAS WITH NARCONON OF GEORGIA," RIG3T? 15 Q SO THIS IS A PERSON COMPLAINING TO NARCONON
16 A YES. 16 INTERNATIONAL ABOUT NARCONON OF GEORGIA, RIGHT? IS THAT
17 Q AND WHAT IS DIVISION SIX? 17 RIGHT?
18 A THAT ' S PUBLIC CONTACT. 18 A OH . EXCUSE ME?
19 Q PUBLIC CONTACT? 19 MS. FRANKLIN: COULD YOU READ THE QUESTION BACK,
20 A YEAH. 20 PLEASE, ROBIN.
21 Q OKAY. 21 (QOESTJON READ).
22 SO THERE ' S A, SOME NUMBER OR SOME WAY TO 22 THE WITNESS: YEAH.
23 CONTACT NARCONON INTERNATI ONAL FOR THE PUBLIC TO MAKE 23 Q BY MS . FRANKLIN: SO IS IT FAIR TO SAY THAT
24 ANY COMPLAINTS ABOUT A LOCAL CENTER, CORRECT? 24 DURING 2008, 2007/2008 NARCONON INTERNATIONAL WAS AWARE
25 A WHAT IS THE QUESTION AGAIN? 25 OF HULTIPLE COMPLAINTS ABOUT ISSUES AT NARCONON OF
41 43
,.- PAGE 42 -----------:------, ;-- PAGE 44 ----------------,
1 Q EXPLAIN WHAT DIVISION SIX IS . WHAT IS PUBLIC 1 GEORGIA?
2 CONTACT? 2 MR. ROOT : OBJECT TO THE FORI-I.
3 A OH . THAT ' S A NUMBER OR E-MAIL THAT PEOPLE 3 THE WITNESS: WELL, I SEE HERE THREE FROM 2007 AND
4 REACH THAT ARE INTERESTED IN THE PROGRAM. 4 TWO FROM 2008 .
5 Q OKAY. 5 Q BY MS. FRANKLIN: SO IS THE ANSWER YES?
6 SO THERE WERE -- THERE WAS AT LEAST ONE OTHER 6 MR. ROOT: DO YOU HAVE AN ANSWER?
7 CO.PLAINT DIRECTLY TO NARCONON INTERNATIONAL? 7 THE WITNESS : YEAH. BECAUSE MULTIPLE, YOU SAY
8 A YES. 8 MULTIPLE . IT'S JUST LIKE MULTIPLE SOUNDS LIKE 20 .
9 Q ALL RIGHT. 9 Q BY MS . FRANKLIN: YOU DON 'T THERE WERE
10 DO YOU REMEMBER ANY OTHERS? 10
11 A NO . 11
12 Q OKAY. 12
13 I ' LL HAND YOU WHAT I'l1 MARKING AS EXHIBIT 8. 13
14 (WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS 14
15 MARKED FOR IDENTIFICATION BY THE SHORTHAND REPORTER AND 15
16 ATTACHED HERETO). 16
17 Q BY MS. FRANKLIN: TELL ME IF YOU RECOGNIZE 17
18 THOSE E-MAILS . 18
19 DO YOU RECOGNIZE THOSE E-MAILS? 19
20 A NO, NOT THIS ONE. 20
21 Q OKAY. 21
22 YOU ' VE A CHANCE TO READ THROUGH THEM, 22
23 CORRECTLY? 23
24 A YEAH. 24
25 Q I MEAN , IS THAT CORRECT? 25
42
20?
A I SEE THREE TWO .
Q AND I' VE ASKED YOU THIS QUESTION EVERY TIME.
I'VE SAID DO YOU BELIEVE THOSE ARE THE ONLY ONES
AND YOU 'VE SAID YES , CORRECT?
A UH-HUH .
Q AND EVERY TIME ! SHOW YOO ANOTHbR ONE, RIGHT?
A SO FAR.
Q DO YOU KNOW HOW MANY I HAVE?
A NO .
Q OKAY .
I' LL YOU WHAT I ' M MARKING AS EXHIBIT 9.
(WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS
MARKED FOR IDENTIFICATION BY THE SHORTP.AND REPORTER AND
ATTACHED HERETO).
Q BY MS. FRANKLIN: TELL ME IF YOU RECOGNIZE THIS
44
July 10, 2012
818.995.2449
_ SHEET 12 PAGE 45
47
1 STREAM OF E-MAILS . 1 A UH-HUH.
2 DO YOU RECOGNIZE THOSE E-MAILS? 2 MR. ROOT: EXCUSE ME . I'M SORRY, REBECCA . ARE YOO
3 A THI S ONE, YES. 3 TALKING ABOUT THE MONDAY, MARCH 10?
4 Q OKAY. 4 MS . FRANKLIN: YES.
5 YOU IVERE COPIED, AND LET ' S JUST , IF YOU ' LL TURN 5 MR . ROOT : I SEE A CARBON COPY TO --
6 TO THE SECOND PAGE IT'S BATES NO. 1039. IT APPEARS TO 6 MS. FRANKLIN: RIGHT . AND IT' S FORWARDED, IF YOU
7 BE AN E-MAIL FROM ISAAC -- EXCUSE ME -- TO ISAAC FROM 7 LOOK UP IT' S FORWARDED FROM CLAUDIA TO --
8 CLAUDIA AND YOU WERE COPIED ON THIS E-MAIL, RIGHT? 8 MR. ROOT : RIGHT.
9 A YEAH. 9 MS. FRANKLIN: -- MR . MANZANARES .
10 Q OKAY. 10 Q I'M JUST ASKING WHETHER-- IT APPEARS THAT YOU
11 AND IT' S A DISCUSS ION REGARDING THE, QUOTE, 11 WERE THIS E-HAIL, RIGHT?
12 "PHASE OUT OF DELGADO," RIGHT? 12 A UH-HUH. YEAH.
13 A UH-HUH. 13 Q SO THERE ' S A DISCUSSION ABOUT DELGADO IN THESE
14 Q DO YOU REMEMBER THAT DISCUSSION? 14 E-MAILS, RIGHT, ABOUT PHASING THEM OUT, CORRECT?
15 A NO. 15 A UH-HUH.
16 Q DO YOU KNOW WHO CLAUDIA IS REFERRING TO WHEN 16 Q BETWEEN NARCONON INTERNATIONAL AND NARCONON OF
17 SHE SAID DELGADO? 17 GEORGIA?
18 A NO. 18 A WHERE IS THE PHASING OUT THING?
19 Q OKAY . 19 Q IT'S THE FIRST E-MAIL ON BATES NO. 1039 . IT
20 YOU 'RE NOT AWARE OF-- STRIKE THAT . 20 SAYS "DEAR ISAAC, THANK YOU. PLEASE SUGGEST TO
21 DO YOU KNOW THE DELGADO DEVELOPMENT 21 THAT SHE INCLUDE IN THE PROGRAM TARGETS THE PHASE OUT OF
22 CORPORATION? ARE YOU FM1ILIAR WITH THAT? 22 DELGADO."
23 A YEAH. THAT, YEAH, UH-HUH. 23 A VIELL, I DON ' T KNOW WHAT THAT MEANS . WHAT IS
24 Q HOW ARE YOU FANILIAR WITH THAT? 24 IT?
25 A THAT'S THE HOUSING. 25 Q DO YOO SEE wHERE I'M--
45 47
.--- PAGE 46 -------------------------------. ,-- PAGE 4 8 ------------------------------,
1 Q RIGHT. 1 A YEAH. I FOUND IT .
2 THE HOUSING FOR NARCONON OF GEORGIA AT THIS 2 Q BUT IT ' S YOUR TESTIMONY YOU DON ' T KNOW WHAT
3 TIME. 3 THAT MEANS?
4 A UH- HUH. 4 A NO.
5 Q AND THIS E-NAIL FROM ISAAC TO CLAUDIA APPEARS 5 Q OKAY.
6 TO BE, AT LEAST IN PART, A DISCUSSION ABOUT THE PHASE 6 DO YOU HAVE ANY INDEPENDENT RECOLLECTION OF
7 OUT OF DELGADO, RIGHT? 7 RECEIVING OR BEING COPIED ON THESE E-MAILS?
8 MR . ROOT: OBJECT TO THE FORM. 8 A NO.
9 THE WITNESS: I HAVEN'T SEEN THIS E-MAIL. I 9 Q OKAY.
10 REMEMBER THIS ONE (INDICATING) BUT I SAW THIS ONE LIKE 10 DO YOU ANYTHING IN MARCH OF 2008 ABOUT
11 WHEN I \VAS GETTING READY FOR THE DEPOSITION. I DIDN'T 11 ISSUES WITH DELGADO DEVELOPMENT OR HOUSING IN GENERAL AT
12 READ THIS AT THAT TIME, THIS, THE FIRST PAGE. 12 NARCONON OF GEORGIA?
13 Q BY MS . FRANKLIN: UH-HUH. OKAY. 13 A NO.
14 BUT YOU WERE COPIED -- 14 Q OKAY.
15 A AND THIS OTHER ONE IS PRIOR. OKAY. 15 DO YOU REMEMBER ANYTHING AT THAT TIME ABOUT
16 Q YOU WERE COPIED ON THAT INITIAL E-MAIL FROM 16 NARCONON OF GEORGIA' S FINANCIAL STATUS?
17 ISAAC, FROM CLAUDIA TO ISAAC, RIGHT? 17 A NO.
18 A YEAH. 18 Q OKAY .
19 Q AND YOU WERE FORWARDED THE E-MAIL THAT'S TO 19 YOU DON ' T WHETHER NARCONON OF GEORGIA
20 CLAUDIA AND ISAAC FROM MARY RIESER, CORRECT? 20 WAS OWED ANY LICENSING FEES OR ANYTHING LIKE THAT?
21 MR. ROOT : OBJECT TO THE FORM. 21 A WAS OWED?
22 THE WITNESS : WHICH ONE IS THAT? 22 Q I ' M SORRY.
23 Q BY MS. FRANKLIN: THE FIRST PAGE . THERE ' S AN 23 THAT NARCONON OWED LICENS ING FEES, THAT
24 E-MAIL FROM MARY TO CLAUDIA AND ISAAC. 24 OWED INTERNATIONAL LICENSING FEES.
25 DO YOU SEE THAT? 25 A NOT EXACTLY BY THE DATE BUT THAT COULD BE THAT
46
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IT WAS NOT CURRENT OR SOMETHING . 1 (RECESS HELD).
Q DO YOU REMEMBER ONE WAY OR THE OTHER? 2 THE VIDEOGRAPHER: WE ARE BACK ON THE RECORD AT
A ' 08, RIGHT? 3 APPROXIMATELY 11:36 A.M.
Q UH-HUH. 4 Q BY MS . FRANKLI N: MR. SWITCH GEARS
A EXACT EXACTLY, I DON'T REMEMBER. 5 FROM WE WERE DISCUSSING BEFORE THE BREAK.
Q OKAY. 6 TELL ME HOW YOU LEARNED -- WELL, LET ME BACK
DO YOU REMEMBER THERE BEING EVER ANY ISSUES 7 UP . YOU REALIZE WE'RE HERE, THIS LAWSUIT INVOLVES THE
WITH GEORGIA OWING LICENSING FEES OR NOT PAYING THEIR 8 DEATH OF A STUDENT AT THE NARCONON OF CENTER,
LICENSING FEES ON TIME? 9 CORRECT?
A YEAH. THERE WAS SOME TIME THEY WERE BEHIND. 10 A (WITNESS NODS HEAD IN THE AFFIRMATIVE) ,
Q OKAY. 11 Q YOU JUST HAVE TO VERBALLY ANSWER FOR THE COURT
YOU JUST DON ' T REMEMBER WHEN THAT WAS? 12 REPORTER.
A EXACTLY. 13 A OH. YES.
Q WAS THAT SOMETHING THAT vlAS PART OF YOUR JOB, 14 Q
AND Ti!AT STUDENT 'S NAME WAS PATRICK DESMOND.
WAS TO MAKE SURE THAT THE LICENSING FEES WERE PAID ON 15 YOU UNDERSTAND THAT, CORRECT?
TIME? 16 A YES.
A NO. 17 Q OKAY.
Q OKAY. 18 HOW DID YOU PERSONALLY BECOME A\vARE OF
HOW WOULD YOU BE VillDE AWARE OF THAT ISSUE? 19 MR. DESMOND'S DEATH?
A EXACTLY I DON'T REMEMBER. 20 A IT WAS VERB JiLL Y . I LEARN THAT FROM THE
Q WERE YOU A\'/ARE THAT THERE WAS A BOARD OF 21 DIRECTOR OF LEGAL AFFAIRS .
INVESTIGATION THAT lvAS OPENED IN MARCH OF 2008 REGARDING 22 Q AND THAT ' S CLAUDIA?
HOUSING AT NARCONON OF GEORGIA? 23 A CLAUDIA, YEAH.
A NO. 24 Q OKAY.
Q OKAY. 25 WHAT DID CLAUDIA TELL YOU?
49 51
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ARE YOU AVIARE OF THAT NOW? I MEAN, YOU
REVIEWED SOME DOCUHENTS FOR YOUR DEPOSITION.
A YEAH. THIS IS THE ONLY ONE THAT GAVE ME THAT
BUT I DON'T KNOW IF IT HAPPENED OR NOT .
Q OKAY .
AND YOU ' RE AWARE OF THAT BECAUSE OF
DISCUSSIONS, LIKE IN THE FIRST, ON THE FIRST PAGE A
LITTLE MORE THAN HALniAY DOWN WHERE HARY RIESER SAYS TO
CLAUDIA AND ISAAC, "MY REASONING BEHIND THE B OF I viAS
TO GET A THIRD PARTY OBSERVATION AND DOCUHENTATION OF
THE SITUATION."
RIGHT?
A RIGHT.
Q BUT YOU DON ' T REMEMBER ANYTHING INDEPENDENT
ABOUT A BOARD OF INVESTIGATION REGARDING HOUSING?
A NO.
1 A THAT A STUDENT OD ' D.
2 Q WHEN DID SHE TELL YOO THAT?
3 A
4 Q UH-HUH.
5 A EXACTLY I DON'T KNOW. PROBABLY AROUND THAT
6 DATE.
7 Q OKAY.
8 AND THAT'S ALL SHE TOLD YOU ABOUT THE
9 CIRCUMSTANCES?
10 A YEAH.
11 Q ALL RIGHT.
12 AND DID YOU -- DID SHE ASK YOU TO DO ANYTHING
13 IN RESPONSE?
14 A SHE SUGGESTED, YEAH , AN INSPECTION TO BE SENT
15 THERE .
16 Q OKAY.
Q ALL RIGHT . 17 AND AS OPERATIONS SUPERVISOR, IS THAT SOl1ETHING
SWITCH GEARS HERE UNLESS YOU NEED TO TAKE A
BREAK.
A OKAY.
MS . RICHARDSON: I'D LIKE TO TAKE A SHORT TIME
BREAK IF THIS IS A GOOD TIME.
MS . FRANKLIN: OKAY.
THE VIDEOGRAPHER: WE ' RE GOING TO GO OFF THE RECORD
AT 11 :22 A.M.
50
18 THAT YOU WOULD BE IN CHARGE OF DOING IS SETTING UP AN
19 INSPECTION?
20 A YES.
21 Q OKAY.
22 AND YOU DID THAT IN THIS CASE, CORRECT?
23 A DH-HUH.
24 Q OKAY .
25 DID YOU PERSONALLY COME INSPECT THE FACILITY?
July 10, 2012
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A NO . 1 SO YOU WERE TOO BUSY TO GO SO YOU ASKED SOMEONE
Q OKAY. 2 FROM NARCONON ARROWHEAD TO GO PERFORM A TECH INSPECTION?
II'HO DID THAT? 3 A YEAH.
A I ASKED TO HAVE THIS LADY, SHE USED TO 4 Q ALL RIGHT.
WORK -- SHE USED TO WORK AT NARCONON ARROWHEAD, JETTE. 5 AND I'M JUST GOING TO BACK UP AND ASK A LITTLE
Q JETTE MAC GREGOR? 6 BIT ABOUT -- EXCUSE ME -- INSPECTIONS IN GENERAL. AND
A YES. 7 IF A PERSON WHO IS CONDUCTING A TECH INSPECTION FIND
Q AND YOU ASKED HER TO GO TO GEORGIA TO DO A TECH 8 SOHETHING WRONG, WHAT HAPPENS?
INSPECTION, CORRECT? 9 A THIS ?ERSON ISSUES A CORRECTION --
A TO NARCONON; YES. 10 Q UH-HUH.
Q OKAY . 11 A -- TO THE PERSON THAT ' S DELIVERING THAT PART OF
AND WHY DID YOU DO THAT? 12 THE PROGRAM.
A TO SEE HDVI THE PROGRAM WAS BEING DELIVERED. 13 Q A MEMO?
YEAH . 14 A YES .
Q AND ANY OTHER REASON? 15 Q SOME WRITTEN FORM?
A NO. 16 A EXACTLY.
Q WHAT IS f.. TECH INSPECTION? 17 Q BECAUSE THE TECHNOLOGY HAS TO BE DELIVERED
A IT'S AN INSPECTION OF THE DELIVERY OF THE 18 EXACTLY AS PRESCRIBED OR SET OUT IN THE NARCONON PROGRAM
NARCONON PROGRAM. 19 BOOKS, CORRECT?
Q OKAY . 20 A WHAT'S IN THE BOOKS , YEAH.
WHAT DOES IT INVOLVE? 21 Q OKAY.
A THAT INVOLVES THE EIGHT BOOKS THAT THE NARCONON 22 AND HOW OFTEN ARE TECH INSPECTIONS TO BE
PROGRAM CONSISTS OF. 23 PERFORMED FOR ANY GIVEN NARCONON CENTER?
Q WHAT ELSE? 24 A ONCE A YEAR.
A JUST THAT. 25 Q OKAY.
53 55
PAGE 54
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Q OKAY. 1 SO THEY HAVE ANNUAL INSPECTIONS?
SO THAT'S AN INSPECTION OF THE EIGHT BOOKS? 2 A YEAH.
A YEAH. THE DELIVERY OF THE EIGHT BOOKS. 3 Q ALL RIGHT.
Q OKAY. 4 AND THAT'S A REQUIREMENT FROM NARCONON
AND IS THE PERSON WHO IS PERFORMING THE 5 INTERNATIONAL, CORRECT?
INSPECTION, WHAT DO THEY INSPECT? 6 A I DON'T GET IT.
A THEY INSPECT THE AREAS, LIKE FOR INSTANCE THE 7 Q OKAY.
BOOKS ARE DELIVERED IN WHAT'S CALLED COURSE ROOM. 8 DOES NARCONON INTERNATIONAL REQUIRE A TECH
Q RIGHT. 9 INSPECTION FOR EACH OF ITS CENTERS ANNUALLY?
A SO THEY INSPECT THE COURSE ROOM, THEY LOOK AT 10 A NOT NECESSARILY.
DETAILS TO SEE IF THE PEOPLE ARE DOING THE BOOKS LIKE 11 Q OKAY.
COMPLETELY, NOT SKIPPING CHAPTERS OR WHATEVER. 12 HOW DO YOU DECIDE WHEN TO DO ONE?
Q OKAY. 13 A BECAUSE THEY ARE DONE LIKE RANDOMLY .
AND WHAT HAPPENS IF STUDENTS AREN'T DOING THE 14 Q OKAY.
EXERCISES OR THE BOOKS EXACTLY AS PRESCRIBED? 15 SO NARCONON INTERNATI ONAL CAN RANDOMLY COME
A LIKE WHAT? I DON 'T GET IT. 16 INTO A NARCONON CENTER AND DO AN INSPECTION?
Q OKAY. 17 A YEAH.
IF THERE'S A TECH INSPECTION -- FIRST OF 18 Q OKAY.
ALL, DO YOU EVER DO TECH INSPECTIONS YOURSELF? 19 AND THE NARCONON CENTERS ACTUALLY HAVE TO PAY
A m.H. 20 FOR THE HOUSING AND THE TRAVEL ARRANGEMENTS FOR THE
Q AND DID YOU ASK JETTE MAC GREGOR TO DO ONE 21 NARCONON INTERNATIONAL INSPECTORS, CORRECT?
IN THIS CASE? 22 A NO.
A I DON'T REMEMBER EXACTLY. I WAS NOT GOING TO 23 Q THEY DON'T?
GO . I WAS PROBABLY BUSY. 24 A NO.
Q OKAY. 25 Q WHO PAYS FOR IT?
54 56
July 10, 2012
R. Leonard, C.S .R., Inc.
818.995.2449
- SHEET 15 PAGE 57 -------------, ,--- PAGE 59 - ----------------,
1 A NARCONON INTERNATI ONAL. 1 INVESTIGATION, \vOULD YOU HAVE ASKED JETTE MAC GREGOR TO
2 Q OKAY . 2 INSPECT THE HOUSING?
3 CAN THE NARCONON CENTER REFUSE AN INSPECTION? - 3 MR. ROOT: OBJECT TO THE FORM.
4 A IT CAN. 4 THE viiTNESS: NO. BECAUSE THAT ' S NOT MY-- I MEAN,
5 Q OKAY . 5 THAT'S OUTSIDE MY-- MY JOB. THAT'S-- I CANNOT SEND AN
6 AND WHAT WOULD HAPPEN IF THEY REFUSED IT? 6 INSPECTION TO A HOUSING.
7 COULD THEY CONTINUE TO OPERATE UNDER THE NARCONON 7 Q BY MS. FRANKLIN: WELL, OTHER NARCONON CENTERS
8 INTERNATIONAL, UNDER ITS, YOU KNOW, BUSINESS AGREEMENT, 8 HAVE RESIDENTIAL FACILITIES, RIGHT? NARCONON ARROWHEAD
9 BUSINE-SS ASSOCIATE AGREEHENT? 9 IS A RESIDENTIAL INPATIENT FACILI TY, ISN' T IT?
10 A THAT I DON ' T KNOW BECAUSE THAT WOULD BE LIKE A 10 A YEAH. BUT IT' S ALL IN ONE.
11 LEGAL DECISION. 11 Q OKAY.
12 Q OKAY, 12 WELL, YOU CAN ASK YOUR INSPECTORS TO INSPECT
13 LET'S GET BACK TO THIS CASE. 13 HOUSING THERE, CAN ' T YOU?
14 SO YOU ASKED JETTE MAC GREGOR TO PERFORt4 AN 14 A BECAUSE IT'S UNDER NARCONON; YEAH.
15 INSPECTION AFTER THE DEATH OF PATRICK DESMOND, RIGHT? 15 Q OKAY .
16 A (WITNESS NODS HEAD IN THE AFFIRMATIVE). 16 AND YOU DO?
17 Q AND THAT WAS, IT WAS BECAUSE OF HIS DEATH, 17 A NO.
18 RIGHT? IN OTHER WORDS, THIS WASN 'T JUST THE ANNUAL 18 Q YOU DON ' T? THEY DON 'T INSPECT ANY OF THE
19 INSPECTION. 19 HOUSING AREA?
20 A YEAH. IT WAS NOT RANDOM. 20 A NO.
21 Q AND DO YOU REMEMBER, DID JETTE MAC GREGOR 21 Q THEY DON'T?
22 REPORT TO YOU OR TO ANYONE HER FINDINGS FROM THE 22 A NO.
23 INSPECTION? 23 Q OKAY.
24 A YEAH. SHE SENT THEM TO ME . 24 WHAT DID-- AKD I ' H SORRY I' M JUMPING AROUND
25 Q OKAY. 25 HERE A LITTLE BIT, BUT iJHAT DID -- ELSE DID YOU
57 59
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_PAGE 60
1 DO YOU REMEMBER WHAT THEY WERE? 1 LEARN ABOUT PATRICK' S DEATH? YOU TOLD ME THAT CLAUDIA
2 A IT WAS SOMETHING ABOUT THE SEQUENCE OF THE 2 TOLD YOU ABOUT HIS DEATH. DIDN 'T TELL YOU ANYTHING ELSE
3 BOOKS . 3 MORE BESI DES THAT THERE WAS AN OVERDOSE, RIGHT?
4 Q ANYTHING 3LSE? 4 A UH-HUH. YES.
5 A I DON'T RZMEMBER . 5 Q DID SHE TELL YOU THAT HE HAD DRINKING AT
6 Q DID YOU ASK HER TO LOOK AT ISSUES RELATING TO 6 HIS HOUSING FACILITY?
7 NARCONON OF GEORGIA'S HOUSING? 7 A NO .
8 A NO. 8 Q DID YOU REVIEW ANY MEMOS THAT WERE AUTHORED BY,
9 Q WHY NOT? 9 FIRST, MARY RIESER RELATING TO PATRICK'S DEATH?
10 A BECAUSE, I MEAN, THAT'S NOT NARCONON. THAT ' S 10 A YES .
11 LIKE, THAT ' S THE OTHER COMPANY, THE DELGADO COMPANY. 11 Q OKAY.
12 Q OKAY, 12 A DORING THIS PREPARATION.
13 AND DID YOU KNOW THAT AT THE TIME THAT YOU SENT 13 Q OKAY.
i4 JETTE MAC GREGOR TO DO AN INSPECTION? 14 A I GOT HOLD OF THAT .
15 A IF I KNEW WHAT? 15 Q BUT NOT, YOU DIDN' T REVIEW THEM AT THE TIME
16 Q DID YOU BELIEVE THAT NARCONON 16 THAT THEY WERE SUBMITTED, RIGHT?
17 INTZRNATIONAL -- I MEAN, NARCONON OF GEORGIA HAD A 17 A NO .
18 SEPARATE HOUSI NG -- EXCUSE -- FACILITY? 18 Q ALL RIGHT.
H A YEAH. 19 DID YOU REVIEW ANY MEMOS FROM GWENDA?
20 Q BUT YOU TOLD ME EARLIER YOU DIDN' T KNOW 20 A NO.
21 ANYTHING ABOUT THE BOARD OF INVESTIGATION THAT lvAS GOING 21 Q ALL RIGHT.
22 ON ABOUT THAT HOUSING FACILITY? 22 DID YOU TALK TO MARY RIESER?
23 A RIGHT, 23 A NO .
24 Q RIGHT. 24 Q DID YOU TALK TO ANYBODY AT NARCDNON OF GEORGIA
25 OKAY. SO HAD YOU KNOWN ABOUT THE BOARD OF 25 ABOUT PATRICK'S DEATH?
58 60
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A NO, 1 (WHEREUPON, THE DOCUMENT WAS
Q DID YOU TALK TO ANYONE AT NARCONON EASTERN U.S. 2 MARKED FOR IDENTIFICATION BY THE SHORTHAND REPORTER AND
ABOUT PATRI CK ' S DEATH? 3 ATTACHED HERETO) .
A NO. 4 Q BY MS. FRANKLIN: YOU TO TAKE A LOOK AT
Q AND ISAAC WAS THE OPERATIONS SUPERVISOR AT 5 THAT DOCUMENT. TELL ME WHETHER YOU RECOGNIZE IT .
NARCONON EASTERN U.S., RIGHT? 6 A OKAY.
A RIGHT . 7
Q YOU RECOGNIZE THIS DOCUMENT?
Q AND IS HE STILL WI TH NARCONON EASTERN U.S.? 8 A YEAH.
A NOT THAT I KNOW, 9 Q WHAT IS IT?
Q DO YOU KNOW WHERE BE WORKS? 10 A THAT 'S JETTE 'S DEBRIEF ON THE NARCONON OF
A NO. 11 GEORGIA INSPECTION,
Q
IS HE WITH -- DOES HE STILL WORK WITH THE 12 Q OKAY .
NARCONON PROGRAM? 13 AND IT'S ADDRESSED TO YOU, CORRECT?
A NO. 14 A YES.
Q OKAY. 15 Q ALL RIGHT.
WHEN WAS THE LAST TIME YOU REMEMBER HIM WORKING 16 AND COPIED ON IT IS THE EXECUTIVE DIRECTOR OF
FOR NARCONON? 17 NARCONON INTERNATIONAL, RIGHT?
A I DON'T KNOW EXACTLY. 18 A YEAH.
Q OKAY. 19 Q WHO WAS THAT AT THE TIME?
GENERJ..LLY, 20 A PHIL HART,
A I COULD SAY '09. 21 Q AND DO YOU REMEMBER RECEIVING THIS DEBRIEF?
Q ALL RIGHT, 22 A YEAH.
DO YOU KNOW WHY HE LEFT? 23 Q ALL RIGHT.
A YES . 24 AND ON THE LAST PAGE, IT' S BATES NO. 009831,
Q TELL ME ABOUT THAT . 25 MISS MAC GREGOR SAYS THAT "THE FACT THAT THE STUDENTS
61 63
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1 A HAD FAMILY ISSUE . HIS MOTHER VERY OLD,
2 SO HE HAD TO RETIRE FROH WORK TO TAKE CARE OF HER,
3 Q OKAY .
4 AND WHERE DID HE LIVE WHEN HE RETIRED? WHAT
5 PART OF THE COUNTRY?
6 A FLORIDA.
7 Q ALL RIGHT .
8 DO YOU KNOW WHETHER HE STILL LIVES IN FLORIDA?
9 A NO.
10 Q ALL RIGHT .
11 SO DID YOU TALK TO JETTE MAC GREGOR SHE
12 WAS AT GEORGIA DOING THE INSPECTION?
13 A I THINK SHE CP.LLED ME AFTERWARDS \vHEN SHE WAS
14 DONE .
15 Q OKAY .
16 AND WHAT DID SHE TELL YOU?
17 A GOD. I DON'T REMEHBER.
18 Q YOU DON'T REMEMBER ANYTHING ABOUT WHAT SHE
19
20
21
22
23
24
25
SAID?
A NO.
Q DID YOU TALK ABOUT, ABOUT, ANYTHING ABOUT
PATRICK'S DEATH?
A NO.
Q OKAY.
I
1
LL P.AND YOU WRAT I'M MARKING AS EXHIBIT 10,
62
1 HAVE NOT BEEN UNDER CONTROL AFTER THEY ARE DONE WITH
2 THEIR SERVICES IS A MAJGR FACTOR.
3 CORRECT?
4 A YES.
5 Q AND SHE SAYS THAT "THE FOLDERS SHOW THAT MANY
6
7
8
9
STUDENTS REVERT DURING THE NIGHT ."
RIGHT?
A YES.
Q AND THEN SHE SAYS "I OBSERVED UA
1
S TODAY AND
TWO TESTED POSITIVE FOR DRUGS."
WHAT WERE UA
1
S?
A URI NE ANALYSIS .
Q OKAY.
10
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18
19
20
21
22
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24
25
AND THEN SHE SAYS "THE ED IS WORKING ON GETTING
THIS CHANG:O:D AND GETTING NEW HOUSING SET UP .
11
RIGHT?
A UH-HUH. RIGHT.
Q I THOUGHT YOU TOLD ME EARLIER THAT THEY DIDN
1
T
1
THAT YOU DIDN'T REQUEST THAT SHE INSPECT HOUSING.
MR . ROOT: OBJECT TO THE FORM.
THE WITNESS: WELL, SEE DIDN'T IT . SHE'S
JUST REPORTING HERE WHAT TEE ED IS WORKING ON.
Q BY MS. FRANKLIN: OKAY.
AND THEN SHE SAYS 'MARY SAYS A LOT OF THE
TROUBLE HAS COME WITH HOUSING BEING OUT OF CONTROL,
64
Deposition of Y ark:o Manzanares
July 10, 2012
818.995.2449
_ SHEET 17 PAGE 65
1 \IHICH IS UNDERSTANDABLE ."
_ PAGE 67 -------------- ---,
1 WOULD ORDER TECH INSPECTIONS FOR CENTERS, RIGHT?
2 CORRECT? 2 A OR-HUH .
3 A YES. 3 Q WHAT ELSE COULD YOU DO IN THAT ROLE?
4 Q OKAY. 4 A ORDER THE INSPECTIONS AND ORDER CORRECTIONS
5 SO DID YOU DISCUSS THIS , THESE ISSUES WITH 5 BASED ON THE INSPECTIONS OF THE PROGRAM.
6 HOUSING AND THE TROUBLES THAT, QUOTE, COME WITH THE 6 Q OKAY. ALL RIGHT .
7 HOUSI NG BEING OUT OF CONTROL WITH ANYONE AT NARCONON 7 BUT YOU JUST TOLD ME YOU COULDN'T ORDER ANY
8 INTERNATIONAL? 8 CORRECTIONS RELATING TO HOUS ING, RIGHT?
9 A NO. 9 A UH-HUH.
10 Q DID YOU DISCUSS IT WITH JETTE? 10 Q OKAY.
11 A NO. 11 DID YOU KNOW THAT?
12 Q DID YOU DISCUSS IT WITH MARY? 12 A BECAUSE IT' S LIKE, SAY THE STUDENTS ARE LIVING
13 A NO. 13 IN MOTEL 8. I CANNOT SAY HOTEL 8 TO DO THIS OR THAT.
14 Q OKAY. 14 Q Hml DID YOU KNOW THAT YOU COULDN'T OR THAT YOU
15 AS THE OPERATIONS SUPERVISOR, DID YOU CARE 15 BELIEVED YOU COULDN ' T DO ANYTHING ABOUT HOUSING AT
16 WHETHER A HOUSING WAS OUT OF CONTROL? 16 GEORGIA? WHO TOLD YOU THAT?
17 A I MEAN -- 17 A NOBODY.
18 MR. ROOT: OBJECT TO THE FORM. 18 Q OKAY.
19 THE IHTNESS: YEAH . WELL, SEEING THIS , BUT THE 19 A I MEAN, I DON'T HAVE LICENSE WITH THEM OR
20 THING IS I CAN ' T -- I DON'T HAVE ANYTHING TO SAY ABOUT 20 ANYTHING.
21 THE HOUSING . I CANNOT HOVE THEM OUT OR DO ANYTHING. 21 Q YOU DO HAVE A LICENSE WITH GEORGIA, RIGHT?
22 Q BY MS . FRANKLIN: MY QUESTION -- 22 A lmH THE NARCONON .
23 A UH-HUH. 23 Q RIGHT.
24 Q -- NAS, AS OPERATIONS SUPERVISOR OF NARCONON 24 NARCONON INTERNATIONAL HAS A LICENSE WITH
25 INTERNATIONAL, WHEN YOU GOT THIS REPORT, DID YOU CARE 25 GEORGIA.
65 67
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1 THAT JETTE SAID THAT MARY REPORTED THAT HOUSING WAS OUT 1 A UH-HUH.
2 OF CONTROL? 2 Q RIGi!T?
3 ROOT: OBJECT TO THE FORM. 3 AND DO YOU KNOW
NARCONON OF GEORGIA \vAS

4 THE WITNESS : CAN YOU REPHRASE IT DIFFERENTLY, 4 LICENSED BY TEE STATE OF GEORGIA?
5 THEN? 5 A IT' S LICENSED. YEAH.
6 Q BY MS. FRANKLIN: CAN YOU ANSWER THE QUESTION 6 Q OKAY.
7 AS I ASKED IT? 7 AND HOW DID YOU KNOW THAT?
8 A IF I CARED? 8 A FROM THE DIRECTOR OF LEGAL AFFAIRS .
9 Q UH-HUH . 9 Q OKAY.
10 A WELL, OF COURSE, IT' S A POINT OF CONCERN. 10 BUT DID YOU HAVE ANYTHING TO DO WITH NARCONON,
11 Q OKAY . 11 WITH ANY LICENSING REQUIREMENTS FOR NARCONON OF GEORGIA?
12 A I HEAN, IT ' S NOT LI KE TO IGNORE IT. 12 AND WHEN I SAY LICENSING I MEAN STATE LICENSING
13 Q OKAY. 13 REQUIREMENTS .
14 SO DID YOU DO ANYTHING ABOUT IT? 14 A NO.
15 A NO . 15 Q THAT ' S SOMETHING I CAN TALK TO CLAUDIA ABOUT,
16 Q SO YOU DID IGNORE IT? 16 RIGHT?
17 A BECAUSE I CANNOT DO ANYTHING ABOUT THE HOUSING. 17 A YEAH. NO. I DON 'T.
18 Q OKAY. 18 Q SO YOU CAN ORDER AS, BACK TO MY QUESTION ABOUT
19 SO IT' S YOUR POSITION THAT --WELL, IS IT YOUR 19 OPERATIONS SUPERVISOR, YOU CAN ORDER TECH INSPECTIONS
20 POSITION THAT-- STRIKE THAT . 20 AND CORRECTIONS, RIGHT?
21 YOU SAY YOU CAN ' T -- COULDN' T DO ANYTHING ABOUT 21 A UH-HUH,
22 HOUSING, RIGHT? 22 Q WHAT ELSE DID YOU DO AS OPERATIONS SUPERVISOR?
23 A UH-HUH. 23 AND I'M TALKING ABOUT GENERALLY NOW.
24 Q OKAY . 24 A UH-HUH.
25 AS OPERATIONS SUPERVISOR, YOU TOLD !1E THAT YOU 25 IT GOES TO THAT POINT. I MEAN, THAT' S -- IT' S
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JUST THAT BECAUSE WHAT ELSE, UN-HUH. 1 Q OKAY.
Q IT THOUGHT THAT NAS ALL YOUR ROLE WAS AT THAT 2 ARE THEY REQUIRED TO DO ANYTHING, LET'S JUST
TIME? 3 SAY, ON THURSDAY AFTERNOONS AS FAR AS REPORTING
A YEAH. 4 ANYTHING?
Q OKAY. 5 A THEY REPORT THE NUMBERS. THEY -- THOSE THAT
DID YOU EVER VISIT NARCONON OF GEORGIA? 6 YOU SHOWED ME .
A NO. 7 Q OKAY.
Q HAVE YOU TO DATE VISITED NARCONON OF GEORGIA? 8 ANYTHING ELSE?
A NO. 9 A SOME WRITE THE WEEKLY REPORTS AND THEY GO TO
Q HAVE YOU EVER MET HARY RIESER? 10 THE LOCAL OFFICE AND THE LOCAL OFFICE USUALLY FORWARDS
A YES. 11 THEM LIKE DURING THAT WlEK .
Q WHEN? 12 Q OKAY.
A LIKE MOST RECENTLY AT THE ANNUAL CONFERENCE 13 AND WHAT ELSE? YOU SAY THE STATISTICS, THE
THAT WAS APRIL THIS YEAR . 14 WEEKLY REPORTS.
Q OHY. 15 A AND THAT'S IT.
YOU HAD NOT MET HER BEFORE THAT? 16 Q NOW, MANZANARES, YOU 'RE A MEHRER OF THE
A YEAH. 17 CHURCH OF SCIENTOLOGY, RIGHT?
Q YOU HAD? 18 A REMEMBER IT? YEAH.
A UH-HUH. 19 Q YOU ARE A MEMBER OF IT, CORRECT?
Q WERE YOU IN SEA ORG TOGETHER? 20 A YEAH.
A NO. 21 Q AND THE CHURCH ' S HEADQUARTERS ARE HERE IN
Q WERE YOU A OF THE SEA ORG? 22 HOLLYWOOD, RIGHT?
A NO. 23 A UH-EUH.
Q DID YOU MEET HER, DID YOU EVER -- YOU SAID YOU 24 Q AND NARCONON INTERNATIONAL IS HERE IN
NEVER VISITED THE GEORGIA FACILITY, CORRECT? 25 HOLLYWOOD,
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1 A YES. 1 A YES .
2 Q ALL RIGHT. 2 Q ARE THEY IN THE SAME BUILDING?
3 SO DID YOU FIRST MEET RIESER? 3 A NO.
4 A THE FIRST, FIRST, FIRST. THERE WAS ANOTHER 4 Q WHERE IS HEADQUARTERS? CAN YOU
5 NARCONON THAT SHE HAD BEFORE. 5 GIVE ME THAT ADDRESS?
6 Q RIGHT . IN GEORGIA. 6 A I DON ' T KNOW THE NUMBER BUT IT'S ON HOLLYWOOD
7 A IN 2002. YES . AND I WENT THERE TO SEE HER. 7 AN) VERMONT.
8 Q AND THEY CALLED THAT THE FARM? 8 Q OKAY.
9 A EXACTLY. 9 ABOUT HOW FAR AWAY IS THAT FROM HERE?
10 Q YOU \VENT TO VISIT THE FARM? 10 A THREE MILES .
11 A YEAH . 11 Q THREE MILES?
12 Q WAS THAT AN INPATIENT FACILITY? 12 A UH-HUH.
13 A I CAN ' T TELL . I DON ' T REMEMBER. 13 Q OKAY.
14 Q WELL, DO YOU REMEMBER STUDENTS LIVING THERE? 14 AND AGAIN SWITCHING GEARS HERE, WHAT DID YOU DO
15 A THERE WAS A BUILDING WHERE THEY LIVED BUT I 15 TO PREPARE FOR YOUR DEPOSITION TODAY?
16 DON'T REMEMBER IF IT WAS UNDER THE NARCONON. 16 A TODAY?
17 Q OKAY. 17 Q UH-HUH. WELL, WHAT DID YOU -- LET REPHRASE
18 HAD YOU MET MARY BEFORE THAT? 18 THAT .
19 A NO. 19 WHAT DID YOU DO TO PREPARE FOR THIS DEPOSITION
20 Q NOW, .I ASKED YOU EARLIER A LITTLE BIT ABOUT 20 WHETHER IT WAS TODAY OR LAST
1
NEEK?
21 REPORTING REQUIREMENTS AND SAID THAT YOU DIDN' T 21 A JUST SAW SOME DOCUMENTS.
22 BELIEVE THAT NARCONON CENTERS WERE REQUIRED TO SEND ANY 22 Q OKAY.
23 SORT OF WEEKLY REPORTS. 23 THAT'S IT?
24 IS THAT RIGHT? 24 A YEAH.
25 A YEAH. 25 Q DID YOU SPEAK WITH YOUR LAWYERS? I'M NOT
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1 ASKING \vHAT YOU TALKED ABOUT .
2 A UH-HUH .
3 Q BUT JUST WHETHER YOU --
4 A YEAH.
5 Q YOU DID. OKAY .
6 AND WHO ARE YOUR LAWYERS IN THIS CASE?
7 A EXCUSE ME?
8 Q vJHO DID YOU MEET WITH?
9 A WITH ROOT AND MISS KOBRIN AND MR . MOXON .
10 Q OKAY.
11 AND DID YOU MEET WITH ANYBODY FROM THE CHURCH
12 OF SCIENTOLOGY?
13 A NO .
14 Q NO. OKAY .
15 WHO ALL HAVE YOU TO ABOUT THIS CASE?
16 A NOBODY.
17 Q YOU JUST TOLD ME YOU SPOKE TO YOUR LAWYERS .
18 A WELL, THE ATTORNEYS, YEAH .
19 Q OKAY.
20 A OUTSIDE OF THAT, NO.
21 Q NOBODY SLSE WITHIN TliE -- WITHIN INTERNATIONAL?
22 MR. CARR IS HERE . HAVE YOU SPOKEN WITH --
23 A YEAH. JUST CLAUDIA, CLARK, MY EXECUTIVE
24 DIRECTOR. BUT IT' S NOT LIKE TALKING ABOUT IT. IT' S
25 JUST MENTIONING THAT, YOU KNOW, WE HAVE THIS.
73
1 A YES .
2 Q DO YOU KNOW WHY YOU WERE COPIED?
3 A BECAUSE HE USUALLY COPIES ME ON STUFF HE
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WRITES.
Q
A
Q
ON WHAT? EVERYTHING HE WRITES?
SOME STUFF, YEAH .
OKAY.
SO MY QUESTION WAS , EVERYTHING HE WRITES?
A NO.
Q OKAY .
WHAT STUFF DO YOU GET COPIED ON?
A THAT ' S TOO BROAD. I CAN'T TELL .
Q OKAY.
YOU JUST -- BUT YOU DON ' T KNOW HOW MR . HART
DECIDES TO COPY YOU ON AN E-MAIL?
A EXACTLY.
Q ALL RIGHT.
BUT DO YOU KNOW WHY HE SPECIFICALLY COPIED YOU
ON THIS E-MAIL?
A NO .
Q OKAY .
WELL, HE SAYS ' MARY , IT viAS GOOD TO TALK TO
YOU' TODAY. "THE RECENT FLAP SEEMS TO BE COMING ONDER
CONTROL . "
DO YOU KNOW WHAT HE MEANT BY THAT?
75
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1 Q THAT REMINDS ME. 1 A NO .
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YOU SAID YOU -- WHO WAS EXECUTIVE DIRECTOR IN
2008?
A WHERE?
Q WHO WAS THE EXECUTIVE DIRECTOR OF INTERNATIONAL
IN 2008?
A MR. HART .
Q OKAY.
I 'M TO HAND YOU --ARE WE ON 11 -- WHAT
I'M MARKING AS EXHIBIT 11.
(WHEREUPON, THE ABOVE-MENTIONED DOCUMENT WAS
MARKED FOR IDENTIFICATION BY THE SHORTHAND REPORTER AND
ATTACHED HERETO) .
Q BY MS. FRANKLIN: AND ASK YOU IF YOU RECOGNIZE
THAT DOCUMENT .
A UH-HUH.
Q YOU DO RECOGNIZE IT?
A YEAH. I READ THIS ONE AS PART OF THE
Pi\EPARATION.
Q OKAY.
IT APPEARS TO BE AN E-MAIL FROM PHIL HART, THE
EXECUTIVE DIRECTOR OF INTERNATIONAL, TO MARY RIESER,
CORRECT?
A YES.
Q AND YOU WERE COPIED ON THIS E-11AIL?
74
2 Q AND THIS IS DATED JUNE 17TH, 2008, RIGHT?
3 A UH-HUH.
4 Q THAT ' S A WEEK AFTER PATRICK DIED .
5 A UH-HUH .
6 Q AND YOU WERE, WHEN YOU READ THIS, DID YOU KNOW
7 WHAT HE BY THE 'RECENT FLAP ' ?
8 A I COULD ASSUMZ BUT I' M NOT SURE IF THAT'S --
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YEAH.
Q v/ELL, WHEN YOU READ IT, DID YOU KNOW?
A YEAH.
Q OKAY.
AND WHAT DID YOU BELIEVE iE MEANT BY THE
NRECENT FLAP' ?
MR. ROOT : OBJECT TO THE
THE WITNESS : THE INCIDENT WITH THE STUDENT .
Q BY MS . FRANKLIN: OKAY.
PATRICK ' S DEATH?
A UH-HUH.
Q ALL RIGHT.
AND HE SAYS "I WOULD PULL DOT THE FIVE
CONDITIONS TAPE AND GET THE GUYS A?PLYING EMERGENCY
23 NOW.
24
25
WHAT DOES TEAT MEAN?
MR. ROO! : OBJECT TO THE FORM.
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THE WITNESS : 'APPLY EMERGENCY." I DON 'T KNOW.
Q BY HS . FRANKLIN: YOU DON 'T KNOW WHAT "APPLY
EMERGENCY' MEANS?
A APPLYING-- IT DOESN' T SAY.
Q DO YOU KNOW WHAT THE TERMS --AND I'M SORRY .
IF YOU
1
RE NOT FINISHED WITH YOUR
A NO.
Q DO YOU KNOW THE TERMS ' APPLY EMERGENCY NOW'?
AND YOU WOULD -- EXCUSE ME -- 'GET THE GUYS APPLYING
EMERGENCY Nmi . '
A COULD BE THE CONDITION BECAUSE HE'S MENTIONING
HERE CONDITIONS.
Q OKAY.
WHAT ARE THE FIVE CONDITIONS TAPE HE MENTIONS?
WHAT DOES THAT
A THAT'S A LECTURE THAT TALKS ABOUT EMERGENCY.
Q OKAY.
WHEN, IT ' S A LECTURE THAT TALKS ABOUT WHEN
THINGS HAPPEN, HOW TO HANDLE THEM?
A NO.
Q OKAY.
WHAT IS IT?
A IT' S ABOUT THAT CONDITION.
Q WHAT CONDITION?
A THE EMERGENCY CONDITION.
77
1 A THAT'S THE CONCEPT OF THAT CONDITION.
2 Q YOU UNDERSTAND THAT THE JURY IN THIS CASE
3 LIKELY DOES NOT UNDERSTAND THE TERMS "I WOULD PULL OUT
4 THE FIVE CONDITIONS TAPE AND GET THE GUYS APPLYING
5 EMERGENCY NOW ."
6 DO YOU UNDERSTAND THAT?
7 14R. ROOT: I 'H GOING TO OBJECT TO THE FORM OF THE
B QUESTION.
9 MS . OKAY.
10 THE WITNESS : YEAH. I REALLY DON'T KNOW
11 WHAT -- THIS IS JUST LIKE SOMETHING PHIL WROTE .
12 Q BY MS. FRANKLIN: OKAY .
13 SO YOU DIDN ' T UNDERS TAND --
14 A NO.
15 Q -- WHEN YOU READ IT, YOU DIDN'T WHAT HE
16 WAS TALKING ABOUT?
17 A NO . AND THEN HE'S TALKING ABOUT CATS OR
18 SOMETHING. I DON ' T GET IT.
19 Q SO WHEN YOU READ THIS YOU DIDN' T UNDERSTAND.
20 WE ' LL JUST HAVE TO ASK PHIL WHAT HE MEANT, RIGHT, IS
21 THAT WHAT YOU'RE SAYING?
22 A I GUESS .
23 Q OKAY.
24 SO YOU ' RE SAYING WHEN YOU READ THIS YOU DIDN'T
25 UNDERSTAND WHAT IT MEANT.
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1 Q WHAT ' S THE EMERGENCY CONDITION? 1 A YES .
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A WHAT IS IT?
Q WHAT DOES IT MEAN?
A A CONDITION.
Q THAT ' S ALL YOU CAN SAY, A CONDITION?
A UH-HUH .
Q OKAY.
AND IN YOUR MIND, WHAT IS AN EMERGENCY
CONDITION? HAYBE A DEATH OF A STUDENT? WOULD THAT BE
AN EMERGENCY CONDITION?
MR. ROOT: OBJECT TO FORM.
THE WITNESS: NO. BECAUSE THIS IS DIFFERENT. THIS
IS NOT LIKE AN EMERGENCY LIKE THE BUILDING IS ON FIRE.
Q BY MS. FRANKLIN: UH-HUH .
A IT'S A DIFFERENT CONCEPT.
Q WHAT CONCEPT IS IT?
A IT
1
S ABOUT LIKE IT SAYS HERE. WHERE IS
IT? PROMOTE AND PRODUCE. IT KEEPS TALKING THERE.
THAT ' S WHAT THE CONDITION -- THAT PARTICULAR CONDITION
TALKS ABOUT PROMOTING AND PRODUCING.
Q WHERE ARE YOU REFERRING?
A IT' S SECOND TO LAST PARAGRAPH-- I MEAN, LINE.
Q OKAY .
WHAT DOES THAT MEAN, PROMOTE AND PRODUCE ? HOW
DOES THAT APPLY TO EMERGENCY CONDITION?
78
2 Q OKAY .
3 AND THEN EE SAYS "AS THE DANGER SIT.
11
4 CAN WE ASSUME THAT MEANS THE DANGER SITUATION?
5 MR. ROOT: OBJECT TO THE FORM.
6 THE WITNESS : CAN ASSUME.
7 Q BY MS . FRANKLIN: OKAY.
8 IS THAT HOW YOU READ IT?
9 A YEAH.
10 Q 'SEEHS TO BE PASSING AND WE HAVE THE OUT ETHICS
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lB
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CATS."
DO YOU KNOW WHAT THAT l-1EANS?
A SOMEBODY MISBEHAVING.
Q OKAY.
SO THE DANGER SITUATION SEEMS TO BE PASSING AND
WE HAVE THE PEOPLE MISBEHAVING ISOLATED.
DO YOU KNOW WHO HE WAS TALKING ABOUT?
A NO.
Q ALL RIGHT.
"AND GETTING PUT OFF THE LINES. HARIE AND
BRAD."
YOU THINK THOSE ARE THE OUT ETHICS CATS?
A COULD BE. I DON ' T KNOW.
Q DO YOU KNOW WHO MARIE AND BRAD ARE?
A NO .
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1 Q DID YOU KNOW WHEN YOU RECEIVED THIS E-MAIL IN 1
2 JUNE, 2008? 2
3 A HHM? 3
SO IT' S YOUR UNDERSTANDING THAT PHIL WAS
CONGRATULATING MARY THE DAY AFTER THAT INSPECTION REPORT
PRODUCED OR WAS SUBMITTED, CORRECT?
4 Q DID YOU WHAT MR. HART WAS TALKING ABOUT? 4
5 DID YOU KNOW -- 5
6 A NO. 6
7 Q -- WHO MARIE OR BRAD WERE? 7
8 A NO. 8
9 Q DIDN'T HAVE ANY IDEA? 9
10 A NO. 10
11 Q DID YOU ASK HIM "HEY, I RECEIVED THIS E-MAIL. 11
12 I DON ' T KNOW WHO YOU'RE TALKING ABOUT'? 12
13 A NO. 13
14 Q 'I DON'T KNOW WHAT OUT ETHICS CATS MEANS .' 14
15 YOU DIDN'T SAY ANYTHING LIKE THAT? 15
16 A NO. 16
17 Q ALL RIGHT. 17
18 AND THEN HE SAYS PROMOTES -- "PROMOTE PRODUCE, 18
19 PRODUCE AND COME OUT BIGGER. " 19
20 WHAT DOES THAT MEAN TO YOU? 20
21 MR. ROOT: OBJECT TO THE ?ORM. 21
A (WITNESS NODS HEAD IN THE AFFIRMATIVE).
MR. ROOT : OBJECT TO THE FORM.
I BELIEVE THOSE ARE ALL THE QUESTIONS I HAVE.
LET'S TAKE A QUICK BREAK AND I WILL LOOK
THROUGH MY NOTES.
A o:m.
THE VIDEOGRAPHER: GOING OFF THE RECORD AT 12:13
P.M.
(RECESS HELD) .
THE VIDEOGRAPHER: WE 'RE BACK ON THE RECORD AT
12 :21 P.M.
REMEMBER AT THE BEGINNING OF THIS DEPOSITION I
TOLD YOU THAT THE COURT HAD INSTRUCTED THE PARTIES NOT
TO DISCUSS THE SUBSTANCE OF YOUR TESTIMONY DURING THE
DEPOSITION?
A YES .
22 THE WITNESS : I DON ' T KNOW. 22
23 Q BY MS . FRANKLIN: OKAY . 23
24 "GREAT JOB YOU AND THE GEORGIA GUYS ARE DOING 24
Q WE JUST TOOK A BREAK. DID YOU DISCUSS WITH
YOUR ATTORNEYS ANYTHING THAT WE HAD TALKED ABOUT OR WHAT
WE 'RE ABOUT TO TALK ABOUT?
25 DESPITE THE RECENT ENTHETA. " 25 A NO .
81 83
_ PAGE 82 -------- ---- -----, _ PAGE 84 -----------------,
1 WHAT DOES THAT MEAN? 1 MR. ROOT : I WOULD MAKE A BELATED OBJECTION TO
2 MR. ROOT : OBJECT TO THE FORM. 2 PRIVILEGE BUT SINCE THE ANSWER IS NO I DID NOT MAKE AN
3 THE WITNESS: THAT, I MEAN, HE'S CONGRATULATING HER 3 OBJECTION.
4 FOR HER -- 4 MS. fRANKLIN: OKAY .
5 Q BY MS. OKAY. 5 BUT YOU' RE AWARE OF THE STAYING ORDER IN THE
6 A -- DOING I GUESS. 6 CASE, CORRECT?
7 Q 'DESPITE RECENT,' QUOTE, "ENTHETA." 7 MR . ROOT: YOU ' VE TOLD ME AND I'VE READ IT.
8 WHAT IS ENTHETA? 8 Q BY MS . DO YOU KNOW WHAT A KNOWLEDGE
9 A THAT ' S A TERM THAT MEANS LIKE DISTURBANCE. 9 REPORT IS?
10 Q OKAY. 10 A YEAH.
11 SO YOU UNDERSTOOD THE LAST SENTENCE? 11 Q WHAT IS IT?
12 A UH-HUH. 12 A IT'S A REPORT THAT ' S WRITTEN WHEN SOI1ETHING IS
13 Q GREAT JOB YOU AND THE GUYS ARE DOING DESPITE 13 KNOWN AND WANTS TO BE REFERRED TO SOMEBODY WHO IS
14 RECENT DISTURBANCE? 14 SUPPOSED TO FIX IT .
15 A UH- HUH . 15 Q OKAY.
16 Q OKAY. 16 AND DO YOU RECEIVE KNOWLEDGE REPORTS ABOUT
17 AND DID YOU ASSUME WBZN HE SAID 'DESPITE R3CENT 17 THINGS GOING ON IN INDIVIDUAL CENTERS? AND LET ME
18 ENTHETA" THAT MEANT PATRICK'S DEATH? 18 REPHRASE THAT . DOES NARCOKON INTERNATIONAL EVER RECEIVE
19 A ASSUMING? YEAH. 19 ANY REPORTS ABOUT ON IN INDIVIDUAL CENTERS?
20 Q OKAY . 20 A YEAH.
21 AND THIS WAS DATED JONE 17TH. DO YOU REMEMBER 21 Q OKAY .
22 WHAT DATE THE INSPECTION REPORT, JETTE'S REPORT WAS 22 DO THEY, IS THERE ANY SORT OF PROCEDURE FOR
23 DATED? 23 SUBMITTING KNOWLEDGE REPORTS?
24 A THE 16TH. 24 A NO.
25 Q THE 16TH. OKAY. 25 Q OKAY.
82
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,- PAGE 87 ---------- ------,
1 FROM 2007 TO 2008? 1 IS THERE ANY GUIDELINES ABOUT SUBMITTING
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KNOWLEDGE REPORTS?
A NO.
Q OKAY.
DOES NARCONON INTERNATIONAL RECEIVE -- AND 'liE
CAN CALL THEM ]'S, RIGHT?
A COULD, YEAH.
Q DO YOU?
A NO . KNOWLEDGE REPORT.
Q OKAY.
I'LL CALL THEM KNOWLEDGE REPORTS, THEN.
DO YOU, DOES NARCONON INTERNATIONAL EVER
KNOWLEDGE REPORTS? AND I THINK -- THIS IS A
DIFFERENT QUESTION . BUT KNOWLEDGE REPORTS ABOUT ISSUES
GOING ON AT INDIVIDUAL CENTERS.
A YEAH, WE COULD.
Q OKAY .
AND WHO REVI EWS THOSE?
A AT NARCONON INTERNATIONAL?
Q UH-HUH.
A DEPENDING WHERE THEY ARRIVE. IF THEY ARRIVE TO
I REVIEW THEM .
Q OKAY .
AND WHAT DO YOU DO WITH THOSE?
A SHOULD SEND THEM DOWN TO WHOMEVER WAS
85
PAGE 86
REPORTED OR NEEDED TO HANDLE SOMETHING. I SEND IT DOWN
TO THAT PERSON SAYING PLEASE FIX THIS.
Q OKAY .
DO YOU IS THERE ANY SORT OF DATA BASE OR
SYSTEM WHERE YOU KEEP OR COLLECT KNOWLEDGE REPORTS ABOUT
INDIVI DUAL CENTERS?
A NO.
Q ALL RIGHT.
DO YOU KEEP HARD COPIES OF THEM?
A YEAH.
Q WHERE?
A I THINK IT' S THE SAME FILE WHERE THE OTHER
THINGS WE WENT THROUGH GO.
Q OKAY.
SO THE STATISTICS?
A UH-HUH.
Q AND ANY WEEKLY REPORTS THAT ARE SUBMITTED?
A YEAH.
Q IN THAT SAME FILE YOU WOULD COLLECT ANY
KNOWLEDGE REPORTS THAT ARE SUBMITTED ABOUT A PARTICULAR
CENTER?
A EXACTLY.
Q ALL RIGHT.
DO YOU REMEMBER RECEI VING ANY KNOWLEDGE REPORTS
ABOUT, ANY KNOWLEDGE REPORTS FROM NARCONON OF GEORGIA
86
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A SPECIFICALLY, I DON ' T REMEMBER BUT THERE MUST
BE SOMETHING.
Q WHY MUST THERE BE SOMETHI NG?
A BECAUSE IT'S YEARS .
Q OH. YOU MEAN, JUST FROM THE TIME FRAHE BECAUSE
IT WAS TWO YEARS YOU WOULD EXPECT THERE TO BE SOME?
A NO.
Q WHAT DO YOU BY THAT?
A THERE COULD BE
Q THERE COULD BE?
A UH-HUB.
Q BUT YOU DON ' T KNOW ONE WAY OR THE OTHER?
A (WITNESS SHAKES HEAD IN THE NEGATIVE) .
Q DO YOU RECEIVING ANY KNOWLEDGE REPORTS
ABOUT ISSUES AT HOUSI NG AT GEORGIA?
A I THINK THERE WAS ONE.
Q WHY DO YOU THINK THERE WAS ONE?
A YEAH, I THINK THERE WAS ONE .
Q WHY DO YOU THINK THERE WAS ONE? DO YOU
REMEMBER IT?
A NOT EXACTLY, NO .
Q OKAY.
ANYTHI NG ABOUT IT YOU REHEMBER? WHEN DID YOU
SEE IT? WHEN YOU WERE PREPARING FOR THIS DEPOSITION?
PAGE 88
A THERE WAS ONE, YEAH.
Q OKAY.
YOU SAW ONE KNOWLEDGE REPORT WHEN YOU WERE
PREPARING FOR THIS DEPOSITION --
A UH-HUH.
Q -- IS THAT YOUR TESTIMONY?
A YEAH.
Q WHAT DID IT SAY?
A I DON ' T REMEMBER EXACTLY.
Q WHAT DO YOU REMEMBER ABOUT IT?
A THAT IT WAS BY SOHEBODY OUTSIDE FROM
THE GEORGIA CEKTER AND THEN THERE WAS SOME BACK AND
FORTH OR AN E-MAIL OR COMMUNICATION . I THINK THAT'S
WHAT IT IS.
Q OKAY.
WHAT WAS IT ABOUT?
A I DON'T REMEMBER EXACTLY.
Q WHEN DID YOU READ IT?
A LIKE A WEEK AGO.
Q UH-HUH. OKAY.
AND YOU DON ' T REMEMBER WHAT --ANYTHING ABOUT
THE SUBSTANCE OF IT?
87
A YEAH. IT WAS SOMEBODY FROM, I THINK, SAN DIEGO
THAT WROTE THAT THING.
Q OKAY.
88
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,.--SHEET 23 PAGE 89 -------------, _ PAGE 91 -----------------,
1 SO YOU REMEMBER IT WAS SOMEONE FROM SAN DIEGO? 1 Q YES, SIR.
2 A YEAH, 2 I CAN SHOW THE EXHIBITS TO YOU IF THAT viOULD BE
3 Q ANYTHING ELSE? 3 HELPFUL TO YOU.
4 A NO . 4 YOO WERE ASKED BY MISS FRANKLIN ABOUT VARIOUS
5 Q YOU DON ' T REHEMBER THEY WERE -- WERE 5 COMPLAINTS REFERENCED IN THESE EXHIBITS. DO YOU RECALL
6 THEY COMPLAINING ABOUT SOMETHING ABOUT GEORGIA? 6 THAT? FOR REQUEST FOR REFUNDS.
7 A NO. I WOULD HAVE TO READ IT TO REMEMBER . 7 A UH-HUH.
B Q OKAY. 8 Q DO YOU RECALL THOSE QUESTIONS, MR. MANZANARES?
9 I ' H GOING TO HAND YOU A SET OF DOCUMENTS, HAVE 9 A FROM THIS PARTICULAR REPORT?
10 YOU LOOK THROUGH THOSE AND SEE WHETHER THEY REFRESH YOUR 10 Q FROM VARIOUS SOURCES .
11 RECOLLECTION -- 11 A YES ,
12 A UH-HUH, 12 Q YOU WERE ASKED THOSE QUESTIONS EARLIER.
13 Q -- ABOUT ANY KNOWLEDGE REPORTS REGARDING 13 A YEAH.
14 NARCOKON OF GEORGIA FROM 2007 TO 2008 . 14 Q DO YOU RECALL THAT?
15 TAKE YODR TIHE. 15 A YEAH.
16 MR . ROOT: DO YOU HAVE AN EXTRA SET OF THOSE, 16 Q I DON ' T MEAN FOR YOU TO HAVE TO GO THROUGH ALL
17 REBECCA? 17 THESE EXHIBITS .
18 MS . FRANKLIN: NO, I DON ' T. I ' M NOT GOING TO MARK 18 A OKAY.
19 THEM F.S AN EXHIBIT. 19 Q BUT INTERNATIONAL WOULD GET SOME
20 ACTUALLY, I DON ' T BELIEVE THAT -- JUST 20 COMMUNICATION FROM A CUSTOMER OR CLIENT ABOUT VARIOUS
21 REFRESHING HIS RECOLLECTION SO I DON ' T BELIEVE YOU HAVE 21 ISSUES INCLUDING, PERHAPS , A REQUEST FOR A REFUND AT
22 AN OPPORTUNITY TO REVIEW THEM BEFOREHAND ALTHOUGH I 22 CERTAIN TUlliS; IS THAT CORRECT?
23 WON ' T OBJECT TO YOUR REVIEWING THEM NITH HIM. 23 A YES .
24 Q YOU ' VE HAD A CHANCE TO REVIEW THOSE MATERIALS? 24 Q IN THOSE INSTANCES , DOES NARCONON INTERNATIONAL
25 A I JUST LOOK IF ANY OF THIS WAS DIRECTED 25 TYPICALLY REFER THAT COMPLAINT BACK TO THE PARTICULAR
89 91
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1 TO -- IT'S LIKE LOCAL REPORTS, RIGHT? 1 CENTER WHERE THE PERSON iiAS ENROLLED?
2 Q MY QUESTION FOR YOU IS, DID THOSE DOCUMENTS 2 A YES .
3 REFRESH YOUR RECOLLECTION ABOUT ANY REPORTS 3 Q ALL RIGHT.
4 RELATING TO NARCONON OF GEORGIA? 4 AND IN THE EVENT THAT NARCONON INTERNATIONAL
5 A NO . 5 WOULD A COMPLAINT CONCERNING NARCONON OF GEORGIA,
6 Q OKAY. PARTICULARLY, A REQUEST FOR A REFUND, WOULD YOU; THAT
7 THOSE ARE ALL THE QUESTIONS I HAVE FOR YOU . 7 IS, NARCONON INTERNATIONAL, REFER THAT COMPLAINT BACK TO
8 A OKAY , 8 THE LOCAL CENTER, NARCONON OF GEORGIA?
9 Q I APPRECIATE YOUR TIME. 9 MS. FRANKLI N: OBJECT AS TO FORM.
10 UNLESS ANY OF THESE OTHER DEFENDANTS HAVE ANY 10 THE WITNESS: YES, DEFINI!ELY.
11 QUESTIONS. 11 Q BY MR. ROOT: AND DID, TO YOUR KNOwLEDGE,
12 12 NARCONON INTERNATIONAL OR DOES IT GIVE REFUNDS OUT OF
13 EXAMINATION 13 ITS OWN FUNDS IN THE EVENT THERE 'S A COMPLAINT FROM A
14 LOCAL
15 BY MR. ROOT: 15 A NO,
16 Q MR . MANZANARES, I JUST A COUPLE OF 16 Q OKAY.
17 QUESTIONS. 17 IS THAT SOMETHING THAT IF THERE IS A REFUND,
18 AS YOD KNOW, I' M DAVE ROOT AND I REPRESENT YOUR 18 WOULD THOSE FUNDS COME FROM THE LOCAL CENTER?
19 EMPLOYER, NARCONON INTERNATIONAL. 19 A RIGHT .
20 YOU WERE SHOIVN SEVERAL EXHIBITS, SPECIFICALLY 20 Q OKAY.
21 EXHIBITS 5, 6, 7 AND 8 vll!ICH INVOLVED CERTAIN COMPLAINTS 21 WAS IT YOUR UNDERSTANDING BACK IN THE 2007/2008
22 ABOUT VARIOUS ISSUES THAT HAD BEEN BROUGHT TO THE 22 TIME FRAME THAT THIS SO-CALLED HOUSING AT NARCONON OF
23 ATTENTION OF NARCONON INTERNATIONAL,
24 DO YOU RECALL THAT, SIR?
25 A- FIVE, SIX, SEVEN AND EIGHT?
23 GEORGIA WAS SEPARATE FROM IHE NARCONON OF GEORGIA
24 CENTER?
25 "A. YES,
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1 MS . FRANKLIN: OBJECT TO FORM.
2 Q BY MR. ROOT : WAS IT YOUR UNDERSTANDING--
3 WELL, LET ME ASK YOU THIS.
4 DID YOU UNDERSTAND THAT THE LOCAL NARCONON OF
5 GEORGIA WAS A RESIDENTIAL CENTER OR AN OUTPATIENT
6 CENTER?
7 MS. FRANKLIN : OBJECT TO FORM.
8 MR . ROOT : REBECCA, LET ME GET THE QUESTION OUT .
9 Q BACK IN THE 2007/2008 TIME FRAME, DID YOU
10 UNDERSTAND THAT THE NARCONON OF GEORGIA CENTER WAS
11 RESIDENTIAL OR OUTPAT IENT?
12 A OUTPATIENT.
13 Q AND BY OUTPATIENT, WHAT DID YOU MEAN? WHAT DO
14 YOU MEAN BY THAT?
15 A THAT THZ CLIENT OR STUDENTS , THEY GO TO THE
16 NARCONON TO RECEIVE THE PROGRAM, THAT THEY DON 'T LIVE
17 THERE. THERE IS NO SET UP FOR THEM TO LIVE IN THE SAME
18 BUILDING.
19 Q WHAT DID YOU UNDERSTAND ABOUT WHAT OPTIONS
20 STUDENTS OR CLIENTS AT THE NARCONON OF GEORGIA CENTER
21 HAD ABOUT THEY COULD LIVE?
22 A ANYWHERE .
23 Q ANYWHERE THAT THEY WANTED TO?
24 MS . FRANKLIN : OBJECT TO
25 THE viiTNESS: I NOBODY FORCES THEM TO GO TO
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1 THAT SPECIFIC HOUSING.
2 Q BY MR. ROOT : OKAY .
3 WAS THAT YOUR UNDERSTANDING OF THE SET UP AT
4 NARCONON OF GEORGIA BACK IN 2007 AND 2008?
5 A YES .
6 Q OKAY.
7 YOU WERE ASKED SOME QUESTIONS ABOUT WHETHER YOU
8 INSPECTED HOUSING AND SORT OF THING.
9 IS THAT THE REASON THAT YOU DID NOT
10 SPECI FICALLY DIRECT ANY INSPECTIONS OF ANY HOUSING
11 SITUATION OF STUDENTS AT NARCONON OF GEORGIA?
12 MS . FRANKLIN: OBJECTION .
13 Q BY MR . ROOT : BECAUSE IT WAS AN OUTPATIENT
14 FACILITY?
15 A YES , EXACTLY.
16 Q OKAY.
17
18
19
20
21
22
23
24
25
LET ME REPHRASE THE QUESTION.
WHY DID YOU NOT DIRECT ANY INSPECTIONS ON ANY
HOUSING FACILITY CONNECTED TO OR THAT MAY HAVE BEEN
LIVED IN BY NARCONON OF GEORGIA STUDENTS BACK IN THE
2007/2008 TIME FRAME? WHY WOULD YOU HAVE NOT INSPECTED
ANY PLACES WHERE STUDENTS LIVED?
A BECAUSE THAT'S NOT OF MY CONCERN . THAT ' S NOT
PART OF THE NARCONON PROGRAM .
Q OKAY. THANK YOU. THAT ' S ALL I HAVE .
94
r-- PAGE
95 ------ ------------,
1
2
3
4
5
6
7
MS . FRANKLIN: CALVIN, DO YOU HAVE ANY QUEST IONS?
MR . YAEGER: I DON ' T HAVE ANYTHING ELSE.
MS. FRANKLIN: OKAY.
MR . ROOT : LISA?
MS . RICHARDSON : I HAVE NOTHING .
THE WITNESS : ARE THESE YOURS?
MS. FRANKLIN: YEAH. WE'LL KEEP THOSE. YEAH .
8 WE ' LL KEEP THEM HERE. THE COURT REPORTER WILL KEEP
9 THEM.
ROOT: ARE WE DONE?
MS. FRANKLI N: YEAH.
MR. ROOT: OKAY. OFF THE RECORD.
10
11
12
13
14
15
16
THE VIDEOGRAPHER: WITH THAT, THEN, THIS WILL
CONCLUDE THE DEPOSITION. WE ARE OFF THE RECORD AT 12:37
P.M.
17
18
19
20
21
22
23
24
25
THIS IS THE END OF DISK NO. 1.
(DISCUSSION HELD OFF THE RECORD) .
MS. FRANKLIN: I '!1 FINE HAVING A BREAK AS LONG AS
YOU ALL NEED TO BUT I WOULD INVOKE THE RULE OF
SEQUESTRATION FOR THE DEPOSITION AND, JUST AS AT TRIAL,
I WOULD ASK THAT THE NEXT WITNESS NOT BE, NOT, COUNSEL
NOT DISCUSS THE TESTIMONY OF MR . MANZANARES WITH THE
FOLLOWING WITNESS .
SO vHTH THAT, THEN, HOW LONG DO YOU NEED?
MR. ROOT: IS IT GOING TO UPSET YOU IF WE HAVE
_ PAGE 96
1 LUNCH vliTH HIM?
2 MS. FRANKLIN: IT'S NOT GOING TO UPSET HE AT ALL
3 BUT, I YOU KNOW, WITH THE RULE INVOKED I THINK WE
4 HAVE A RIGHT TO KNOW WHAT YOU DISCUSS .
5 WITH THAT , HOW LONG DO YOU NEED?
6 MR . ROOT : AS SOON AS WE GET DONE.
7 MS. FRANKLIN: WELL, LET'S SAY --
8 MR. ROOT : I MEAN , I DON'T KNOW HOi/ FAST THEY WORK
95
9 DOWN AT THAT PLACE. AS FAST AS THEY WORK WE'LL BE BACK.
10 MS. FRANKLIN: LET ' S SET A TIME JUST SO WE KNOW.
11 ROOT: WELL, WHAT ' S YOUR CELL PHONE? I CAN
12 JUST TELL YOU WHEN WE ' RE --
13 MS . FRANKLIN: I MEAN, THE NEXT DEPO IS NOTICED AT
14 2:00 . DO YOU NEED AN HOUR AND A HALF?
15 MR. ROOT : NO.
16 MS . FRANKLIN : 45 MINUTES?
17 MS . KOBRIN: 45 MINUTES.
18 !IJ\. ROOT : CAN DO IT IN 20 MINUTES IF WE CAN GET
19 FED AND GET BACK UP HERE.
20 MS. FRANKLIN: LET ' S TRY TO HEET BACK AT 1:30.
21 MR . ROOT : OKAY.
22
23
24
25
(WHEREUPON, THE DEPOSITION WAS ADJOURNED AT
12:38-P.M.)
-000-
96
July 10, 2012
818.995.2449
SHEET 25 PAGE 97
l. STATE OF CALXFORN:tA
ss.
2 COUNTlt OF LOS ANGELES
3
4
5 :I DO SOLEMNLY DECLARE UNDER PENALTY OF PERJURY
6 THAT TRE FOREGO.I.NG IS MY DEPOS:tT:ION UNDER OATH; THAT
7 TRESE: ARE THE QUESTXONS ASKED OF ME AND M:i ANSWEP.S
8 THERETO; THAT I HAVE READ SAME .AND HAVE MADE THE
9 NECESSARY CORRECTIONS, ADDITIONS OR CHANG.ES TO MY
l.O ANSWERS THAT X D&l!:M NECESSARY.
11 EXECOTED AT
12
l.3
14
15
16
17
18
19
20
21
22
23
24
2.5
CALIFORNXA, ON
PAGE 98
1 STATE OF CALIFORNIA
2 COUNTY OF LOS ANGELES
3
4
ss.
5 X, ROB :IN LEONARD, A CERTIFIED SHORTHAND
20
6 REPORTER LICENSED BY THE STATE OF CALIFORNiA, CERTIFY:
7 TRAT THE FOREGOiNG OF YAR.KO
97
B MANZANARES WAS T7-KEN B&FORE ME PURSUANT TO NOTXCE AT THE
9 TXME AND PLACE THEREIN SET FORTH, AT WHICH "ri.HE TJU!:
1. 0 WXT'NESS w:A.S PUT UNDER OATH BY ME;
11 THAT THE TESTIMONY OF THE WITNESS AND ALL
12 OBJECTIONS MADE AT THE TIME OF EXAMINATION WERE
13 RECORDED STENOGRAPHICALLY BY ME AND WERE THEREAFTER
14
1.5 THAT T'HE FOREGOING IS A TRUE RECORD OF TBE
16 XEST1MONY AND OF ALL OBJECTIONS AT TH.E TIME og XHE
17 EXAM1NATZON.
l.B 7N WITNESS THEREOF, I HAVE SDBSCJU..BED MY NAME
19 THIS 17TH DAY OF JULY, 2012.
20
21
22
23
24
25
LXCENSE NUMBER 3334
98
July 10, 2012
0
009831 [1]63:24
0560 [1]32:5
0562 [1134:2
07 [31 39:25,25 40:1
08 [3) 39:25 40:1 49:3
09 (1161 :21
0999 [1127:12
1
1 (31 5:1618:5 95:16
1:30 (11 96:20
10 (611:18 2:6 6:24 8:1 47:3 62:25
10:20 [3)2:6 8:2,13
1000 [1] 27:12
1039 (2] 45:6 47:1 9
10TH 1118:12
11 [31 7:3 74:9,10
11 :22 [11 50:25
11:36 [1151 :3
12 [216:14,17
12:13 [1183:11
12:21 [11 83:1 5
12:37 (11 95: 14
12:38 [1] 96:24
1201 [1] 2:23
16TH !2182:24,25
17TH 131 76:2 82:21 98:1 9
18 [115:16
191 [1] 3:8
1994 [2] 13:18,21
2
2 (31 5:19 24:16,23
2:00 [1196:14
20 [31 44:8,1 0 96:18
2000 [1] 28:22
2002 [3] 12:1914:19 70:7
2005 [21 11:1 6 12:8
2007 [7) 6:3 11:15 39:20 44:3 87:1
89:14 94:4
2007/ 2008 [7115:3,19 40:5 43:24
92:21 93:9 94:21
2008 [22] 6:10,14,1715:316:5,10
20:22 23:21 30:25 39:15,20 43:24
44:4 48: 10 49:22 74:3,6 76:2 81:2
87:1 89:14 94:4
2009 [3] 39:15,21,23
2012 [5]1:18 2:6 8:1,12 98:19
24 [1] 5:19
27 [1] 5:22
28641-2 [1) 8:16
288 [114:7
29 [1]6:3
3
3 [215:22 27:2
300 [11 3: 15
30060 [11 4:8
Sheet 1
818 995 2449
30303 (11 3:10 AFFAIRS !3137:22 51:21 68:8
30357 (113:24 AFFIRMATIVE 14111 :24 51 :10 57:
30361 (112:25
16 83:4
31 [11 6:3
AFFIRMED !119:12
3334 [311 :24 2:7 98:23 AFTERNOONS 11111 :3
35 [116:7
AFTERWARDS !1162:13
3500 (113:14 AGO 11188:19
36 [116:10 AGREED !1117:25
3600 [1] 3:9
AGREEMENT !2157:8,9
4
AHEAD 12117:13,16
AL !118:17
4 [116:3
ALCOHOL !11 14:1
400 (112:22
ALLOCATE !1128:7
41 [116:14
ALLOCATION !31 5:22 28:2,3
41421111:23
ALREADY 11136:7
421116:17
ALTHOUGH 111 89:22
44 [1[6:21
AMERICA 11112:12
45 (2196:16,17
ANALYSIS 111 64: 12
5
ANALYZE 11129:14
5 [3] 6:7 35: 10 90:21
ANALYZES 121 29:17, 19
6
ANGELES [5) 2:913:9, 11 97:2 98:
2
6 (416:10 36: 17 37:7 90:21 ANNUAL !3156:1 57: 18 69: 13
60 [2]25:18,19 ANNUALLY 111 56:9
63 [1]6:24 ANOTHER !41 33:10,14 44:16 70:
7
4
ANSWER !14117:13,15,1618:25
7 [31 6:14 41 :1 90:21
19:1 34:6,15 40:4 44:5,6 51:11 66:
7000 [212:4 8:15
6 77:6 84:2
74 !117:3
ANSWERED 11136:7
7600 [113:23
ANSWERS 12197:7,1 o
8
ANYBODY 12160:24 73:11
APART 111 14:14
8 [5] 6:17 42:13 67:13,13 90:21
APPEAR !11 33:20
818 111 1:24
880 [1] 3:22
APPEARANCES I3J 2:15 3:1 8:
21
9 APPEARING 111 4:9
9 [31 5:4 6:21 44:21
APPEARS 111133:1 34:8,18,22 37:
9/12107 [116:7
10 41 :10 43:7 45:6 46:5 47:10 74:
90!115:5
21
900 [1] 2:24 APPLY 141 77:1,2,8 78:25
90028 [112:5
APPLYING !41 76:22 77:4,9 79:4
91302 [113:16
APPRECIATE 111 90:9
995-2449 [111 :24
APPROXIMATELY 1218:13 51:3
A
APRIL 111 69:14
ARCABASCIO 12137:17,18
A.M 141 2:6 8:2 50:25 51 :3
AREA 121 12:12 59:19
ABOVE-MENTIONED !11118:6
AREAS !4111 :21 12:1 0,11 54:7
24:18 27:3 31:16 35:11 36:19 41:
AREN'T !1154:14
3 42: 14 44:22 63:1 74:11
AROUND 1311 1:15 52:5 59:24
ACCOUNT [1128:7
ARRANGEMENTS 11156:20
ACTION !118:9
ARRIVE 21 85:21,21
ACTUAL 11 25:22
ARRIVES 121 16:22 18:1
ACTUALLY 14126:13 37:5 56:19
ARROWHEAD !3J 53:5 55:2 59:8
89:20
ASSOCIATE 11157:9
ADDITIONS 11197:9
ASSUME 4176:8 80:4,6 82:17
ADDRESS 121 37:11 72:5
ASSUMING (1182:19
ADDRESSED 111 63:13
ATLANTA 31 2:25 3:10,24
ADJOURNED 111 96:23
ATTACHED 112118:8 24:20 27:5
July 10, 2012
31:1834:1835:1336:2141:542:
16 44:24 63:3 74:13
ATIENTION 111 90:23
ATIORNEY !41 2:21 3:13,21 8: 10
ATIORNEYS !2173:18 83:23
AUTHORED 11160:8
AVENUE !114:7
AWARE [8143:24 45:20 49:19,21
50:1,6 51 :18 84:5
AWAY !11 72:9
8
BACK !191 17:18 33: 12 43:19 51:2,
6 55:5 57: 13 68:18 83:14 88:12
91:25 92:7,21 93:9 94:4,20 96:9,
19,20
BARCELONA 121 2:4 8:14
BASE 12121 :1 6 86:4
BASED 111 67:5
BATES 13145:6 47:19 63:24
BECOME 13113:6,20 51:18
BEFOREHAND !11 89:22
BEGINNING 11183:17
BEHALF 17J 2:3 8: 18,22,24 9:1,3,5
BEHIND 121 49: 10 50:9
BELATED !1184:1
BELIEVE 1121 25:24 31:15 40:21
43:9 44:9,13 58: 16 70:22 76:13
83:7 89:20,21
BELIEVED 111 67:15
BESIDES 11160:3
BETWEEN !5J 10:1115:25 34:8,
2247:16
BIGGER !1181:19
BILLS !1126:9
BIT 14115:24 55:6 59:25 70:20
BOARD 141 49:21 50:15 58:21 ,25
BOOKS (91 53:22 54:2,3,8,11,15
55:19,20 58:3
BOTH 121 10:11 20:18
BOTIOM 13126:13 27:12 37:10
BOULEVARD [212:4 8: 15
BOX I113:23
BRAD 131 80:21,24 81 :7
BREAK 161 50:19,22 51 :5 83:8,22
95:18
BREAKS 11110:8
BROAD 111 75:12
BROUGHT 11190:22
BUILDING 41 70:15 72:2 78:13
93:18
BURBANK 11 3:16
BUSINESS 121 57:8,9
BUSY 12154:24 55:1
c
C.S.R 1111 :22
CABINET 111 21:11
CALIFORNIA 1111 2:5,10 3:16 8:1,
009831 CALIFORNIA
1611 :23 12:14 97:1 ,12 98:1,6
CALL [11130:8,13,21 ,21 38:15,23
39:3,7 41 :14 85:6,11
CALLED 14138:1 54:8 62:13 70:8
CALLS 11139:11
CALVIN 1314:6 9:7 95:1
CANNOT 15143:9 59:5 65:21 66:
17 67:13
CARBON 11147:5
CARE 13162:2 65:15,25
CARED 11166:8
CARLOCK 1113:6
CAROLINA 1111:12
CARR 1414:12 9:3,3 73:22
CARTHY'S 1116:24
CASE 11018:1610:7 20:20 52:22
54:22 57:13 73:6,15 79:2 84:6
CATEGORIES 11126:9
CATS 14179:1780:11,2281:14
CC'D !1143:4
CELL 11196:11
CENTERS [221 11 :112:1515:9,11,
18 22:9,20 23:25 25:4 26:1 28:4,
18 30:14 56:9,19 59:7 67:1 70:22
84:17,19 85:15 86:6
CERTAIN 15115:11,18,20 90:21
91:22
CERTIFICATION !1114:14
CERTIFIED [312:8 8:7 98:5
CERTIFY 11198:6
CHANCE 121 42:22 89:24
CHANGED [1164:15
CHANGES 11197:9
CHAPTERS 11154:12
CHARGE 13115:12,19 52:18
CHEMICAL [2114:5, 13
CHURCH 121 71 :17 73: 11
CHURCH'S !11 71:21
CIRCUMSTANCES !1152:9
CLARIFY 11110:4
CLARK [314:12 9:3 73:23
CLAUDIA !17J 37:15,25 38:11 45:
8,16 46:5,17,20,24 47:7 50:9 51:
22,23,25 60:1 68:15 73:23
CLEVELAND 1114:5
CLIENT 121 91 :20 93:15
CLIENTS 11193:20
COLLECT 121 86:5,19
COLONY 1112:22
COME IBI26:12 30:13 52:25 56:15
64:25 65:6 81 :19 92:1 B
COMING 11175:23
COMMUNICATION 12188:13 91:
20
COMPANY 14112:2513:1 58:11,
11
COMPLAINING [2143:15 89:6
COMPLAINT 161 31 :11 42:7 91 :25
92:5,7,1 3
Sheet 2
R. Leonard, C.S.R. , Inc.
818 995 2449
COMPLAINTS [7130:25 39:16 40: DAILY 11115:24
6 41 :24 43:25 90:21 91 :5 DANGER 13180:3,4,15
COMPLETELY 12120:1 54:12 DATA 14118:22 19:6 21 : 16 86:4
CONCEPT 131 78:15,16 79:1 DATE 1518:12 48:25 52:6 69:8 82:
CONCERN l2166:1o 94:23 22
CONCERNING 11192:5 DATED 131 76:2 82:21,23
CONCERNS 12132:13 36:3 DAVE 1218:24 90:18
CONCLUDE 11195:14 DAVID 11 13:7
CONDITION [13177:11 ,23,24,25 DAVIS 1214:11 8:7
78:1 ,4,5,9, 10, 19,19,25 79:1 DAY 13110:2 83:2 98:19
CONDITIONS 14176:22 77:12,14 DAYTO DAY 11129:25
79:4 DEAL 11113:13
CONDONES 111 43:1 o DEALT 121 30:5,7
CONDUCTING 11155:7 DEAR 13138:6,22 47:20
CONFER 11110:7 DEATH [13151 :8,19 57:15,17 60:1,
CONFERENCE 11169: 13 2,9,25 61:3 62:22 76:18 78:9 82:
CONGRATULATING 12182:3 83: 18
2 DEBRIEF 131 6:24 63:10,21
CONNECTED [1194:19 DECIDE 11156:12
CONSISTS [1153:23 DECIDES 111 75:15
CONSULTING rs111 :2112:8, 14 DECISION 11157:11
CONTACT (4141:18,19,23 42:2 DECLARE 11197:5
CONTACTING 11132:12 DEEM 11197:10
CONTAINED 11125:1 1 DEFENDANT (313:4, 18 4:3
CONTINUE 11157:7 DEFENDANTS 1211:14 90:10
CONTINUED 1413:1 4:1 6:1 7:1 DEFINITELY 11192:10
CONTROL rsJ 64:1 ,25 65:7,16 66: DEKALB 1211:1 10:1
2 75:24 DELGADO [1 114:3 6:22 9:7 45:12,
COPELAND 1113:6 17,21 46:7 47:13,22 48:11 58:11
COPIED 112120:10 38:11 45:5,8 DELIVER 12111 :2 14: 11
46:14,16 48:7 63:16 74:25 75:2, DELIVERED f5J 15:8, 14 53:13 54:
11,18 8 55:17
COPIES [31 18:10 75:3 86:9 DELIVERING 12113:14 55:11
COPY 31 21 :8 47:5 75:15 DELIVERY 12153:18 54:3
CORPORATION 11145:22 DENNIS 1214:11 8:6
CORRECTION 11155:9 DEPENDENCY 12114:5,14
CORRECTIONS 141 67:4,8 68:20 DEPENDING 11185:21
97:9 DEPO 11196:13
CORRECTLY rs1 11 :215:14 38: DEPONENT 1118:19
20,25 42:23 43:13 DEPOSITION 12112:2 8:13,1 8 9:
COULDN'Tt4166:21 67:7,14,15 2111:23 18:5,17 27:2 46:11 50:2
COUNSEL 1212:15 95:21 72:15,19 83:17,20 87:25 88:4 95:
COUNSELOR 12114:5,14 14,20 96:23 97:6 98:7
COUNTED [1125:15 DEPUTY 131 10:20,22 11 :3
COUNTRIES 11112:15 DESIGNER 11113:3
COUNTRY 11162:5 DESIGNING [1112:25
COUNTY 151 1 :1 2:9 10:2 97:2 98: DESMOND 1811:5,6,7 8:17,23 10:
2 1 51 :14 57:15
COUPLE 111 90:16 DESMONDDGA 1126:1 4
COURSE 13154:8,10 66:10 DESMOND'S 11151: 19
COURT !611 :1 8:1910:5 51:11 83: DESPITE [4181 :25 82:7,13,17
18 95:8 DETAILS 11154:11
CSR 131 1:24 2:7 8:8 DEVELOPMENT 1414:3 9:7 45:
CURRENT 13114:21 ,25 49:1 21 48:11
CUSTOMER 111 91 :20 DIED 11176:4
CUSTOMERS [3130:5,7,22 DIEGO 121 88:23 89:1
CYCLE 416:11 38: 1,16,24 DIFFERENT 14115:9 78:12,15 85:
D
14
DIFFERENTLY [2116:25 66:4
July 10, 2012
DIRECT [21 94:10,18
DIRECTED 12135:24 89:25
DIRECTLY [31 13:13 39: 16 42:7
DIRECTOR [1915:17 7:410:20,22
11 :4 18:12 19:14 36: 10 37:5,21
38:8, 14 51:21 63:16 68:8 73:24
74:2,5,22
DISCUSS 17J65:5,10, 12 83:19,22
95:22 96:4
DISCUSSING 111 51:5
DISCUSSION [7) 6:2117: 14 45:
11 ,14 46:6 47:1395:17
DISCUSSIONS [1150:7
DISK [1195:16
DISTURBANCE 12182:9,14
DIVISION 14138:22 41:13,17 42:1
DOCUMENTATION 11150:10
DOCUMENTS IBI 10:918:11 33:
10,17 50:2 72:21 89:9 90:2
DOING [10112:2317:8 24:5 52:18
54:11 '14 62:12 81 :24 82:6,13
DONE 16114:1356:13 62:1464:1
95:10 96:6
DOWN [10122:18,19 26: 10,10,13
36:10 50:8 85:25 86: 1 96:9
DOWNEY 111 4:5
DRAFT !1129:8
DREW [113:20
DRINKING 111 60:5
DRUG [1114:1
DRUGS 11164: 10
DULY 1119:12
DURING 181 10:7 26:18 40:4 43:24
60:12 64:6 71:11 83:19
DUTIES (1115:6
E
EACH 11156:9
EARLIER 16111:16 39:21 58:20
64:18 70:20 91 :12
EASTERN [9120:11, 14,15,20 38:8,
15 61:2,6,8
ECKLE 111 3:20
EIGHT 14153:22 54:2,3 90:25
EITHER [1129:1
ELECTRONIC 111 21 :13
ELECTRONICALLY 11121 :21
E-MAILED !1128:23
E-MAILING !1 138:14
EMAILS 1716:10 42:18,19 45:1,2
47:14 48:7
ED 13120:10 64:14,22
EMERGENCY [13176:22 77:1 ,3,8,
10, 16,25 78:1 ,8,10, 13,25 79:5
EMPLOYEE !1 18: 10
EMPLOYER 11190:19
END 111 95:16
ENROLLED 11192:1
ENSURE 11115:13
CALIFORNIA ENSURE
http t ://ReachingForTheTippingPoint.net
ENSURING 1115:8
ENTHETA 4181 :25 82:7,8,18
ENTITLED 118:16
ENVIRONMENT 1143:11
ESQ 1213:7 4:6
ET 11 8:17
ETC 2113:14 62:1
ETHICS 31 80:10,22 81 :14
EVALUATE 1129:14
EVENT 2192:4,13
EVERYONE 1118:10
EVERYTHING 21 75:5,8
EXACT 1149:5
EXACTLY 19J 31:8 32:18 48:25
49:5,13,20 52:5 54:15,23 55:16,
18 61:18 70:9 75:16 86:22 87:22
88:9,17 94:15
EXAMINATION 5J 5:3 9:15 90:13
98:12,17
EXAMINED 119:13
EXAMPLE [1191 :6
EXCEPT 1117:1 o
EXCUSE 9137:1 39:22 43:18 45:
7 47:2 55:6 58:18 73:7 77:9
EXECUTED 1197:11
EXECUTIVE [161 5:16 7:3 10:20,
22 11:3 18:12 19:14 36:9 37:5 38:
8,14 63:16 73:23 74:2,5,22
EXERCISES 11 54:15
EXHIBIT [15118:3,5 24:16,23 27:2
31:14 35:9 36:17 37:7 41:1 42:13
44:21 62:25 74:10 89:19
EXHIBITS 5190:20,21 91 :2,5,17
EXISTS 1 143:12
EXPECT l1l87:7
EXPLAIN 3115:6 38:20 42:1
EXPLAINED 119:23
EXPRESSING 1136:2
EXTRA 1189:16
F
FACILITIES 1159:8
FACILITY 10143:12 52:25 58:18,
22 59:9 60:6 69:25 70:12 94:14,
19
FACT 1163:25
FACTOR 11 64:2
FAIR 3133:5 39:15 43:23
FAMILIAR !BI26:20,22,25 29:4,6
35:2 45:22,24
FAMILY 4J 8:2310:1 30:18 62 :1
FAR [3144:17 71:3 72:9
FARM 2170:8,10
FARNHAM 113:20
FAST 2196:8,9
FAXED !2121 :21 28:22
FEBRUARY [116:10
FED [11 96:19
FEES 6! 48:20,23,24 49:8,9, 15
Sheet3
818 995 2449
FILE 2186:12,19 GRATUITOUS 1117:8
FILED 5119:11,17 21:7,8 28:6 GREAT 2181 :24 82:13
FILES 3J 18:2319:6,9 GREGOR 81 53:6 54:21 57:14,21
FILING l2J 18:24 21:11 58:14 59:1 62:11 63:25
FINANCES 11128:7 GUESS l3J 29:20 79:22 82:6
FINANCIAL 1148:16 GUIDELINES 1185:1
FINANCIALLY 118:9 GUYS 51 76:22 77:9 79:4 81 :24
FIND 11 55:7 82:13
FINDINGS 11 57:22 GWENDA 1160:19
FINE 3110:9 34:6 95:18
H
FINISHED 111 77:6
FIRE 1178:13
HALF 11196:14
FIRM 1130:11
HALFWAY 11150:8
FIRST [13127:12 32:2 46:12,23 47:
HAND 11118:4 24:15 31 :14 40:14,
19 50:7,7 54:18 60:9 70:3,4,4,4
19,25 42:13 44:21 62:25 74:9 89:
FIVE [4176:21 77:14 79:4 90:25
9
FIX 31 37:5 84:14 86:2
HANDING 31 27:1 35:9 36:16
FLAP 3175:23 76:7,14
HANDLE 3133:12 77:19 86:1
FLORIDA 2162:6,8
HANDLED [1136:10
FOLDER 11121 :9
HAPPEN 2157:6 77:19
FOLDERS 1164:5
HAPPENED l1J 50:4
FOLKS 11 14:10
HAPPENS 3110:24 54:14 55:8
FOLLOW 1122:24
HARD l2J 21 :8 86:9
FOLLOWING 1195:23
HART 617:3 63:20 74:7,21 75:14
FOLLOWS 21 9:13 34:12
81:4
FORCES 1193:25
HEAD rsJ 11:24 51 :1 o 57:16 83:4
FOREGOING [3197:6 98:7,15
87:14
FORGOT 11111 :22
HEADQUARTERED 1112:5
FORMAT 2126:2,22
HEADQUARTERS l2J 71:21 72:4
FORMER 6133:23 34:10,23 39:17
HELD 3151:183:13 95:17
40:6 43:8
HELENA 213:13 9:1
FORMS 6125:25 26:8 27:22 28:3,
HELP 516:3 30:14 32:9 33:6,9
20 29:18
HELPED 1133:15
FORTH 2188:13 98:9
HELPFUL 11 91 :3
FORWARDED 5143:2 46:19 47:
HEREIN 11 9:12
6,7,11
HERETO 111 18:8 24:20 27:5 31:
FORWARDS 1 171:10
18 35:13 36:21 41 :5 42:16 44:24
FOUND 1 148:1
63:3 74:13
FOUR [3111:13 27:10 31:15
HMM 1181 :3
FRAME 51 15:3 87:6 92:22 93:9
HOLD 1160:14
94:21
HOLLYWOOD 1012:4,5 8:1,14,
FRIEND 1113:22
15,15 11 :22 71 :22,25 72:6
FUNDS 2192:13,18
HOTEL 11 8:14
G
HOUR 1196:14
I
GAVE 1150:3
GEARS 3!50:18 51:4 72:14
IDEA [11 81 :9
GENERAL 2148: 11 55:6
IDENTIFICATION 111118:7 24:19
GENERALLY 2161:20 66:23
27:4 31:17 35:12 36:20 41 :4 42:
GEORGIA'S 31 33:3 48:16 58:7
15 44:23 63:2 74:12
GETS 7119:11,16,17 20:4 21:8 28:
IGNORE 2166:12,16
6 39:11
INC 41 1 :10,22 3:18 4:3
GETTING 5118:16 46:11 64:14,
INCIDENT [1176:1 6
15 80:20
INCLUDE 1147:21
GIVE 4117:919:23 72:5 92:12
INCLUDING l1J91 :21
GIVEN 419:21 15:9 22:22 55:23
INCOMPLETE 2125:13,25
GOD Pl 62:17
INDEPENDENT 2148:6 50:14
GOT 41 14:13 38:15 60:14 65:25
INDEX 314:1 6:1 7:1
GRAPHICS 11 13:3
INDICATING 21 36:25 46:1 o
July 10, 2012
INDIVIDUAL [sJ 20:7 23:25 84:17,
19 85:15 86:6
INFORMATION 111 5:1916:21
17:5,9,9, 10,21,23 25:10 26:5 43:8
INinAL 11 46:16
INITIALLY l11 41 : 10
INPATIENT 2159:9 70:12
INQUIRIES 11140:6
INSPECT [9152:25 54:6,7,10 59:2,
12,18 64:19,21
INSPECTED 2194:8,21
INSPECTION 231 6:25 52: 14,19
53:9,17,18 54:2,6,18 55:2,7 56:9,
16 57:3,15, 19,23 58:14 59:6 62:
12 63:11 82:22 83:2
INSPECTIONS [1oJ 54:19 55:6,22
56:1 67:1,4,5 68:19 94:10,18
INSPECTORS l2J 56:21 59:12
INSTANCE l1l 54:7
INSTANCES 1191 :24
INSTRUCTED 211 0:6 83:18
INT 2118:23 19:6
INTERESTED l2J 8:9 42:4
INTERNATIONAL'S 1172:4
INVESTIGATION 4149:22 50:15
58:21 59:1
INVITED 1 113:23
INVOKE 1195:19
INVOKED 11 96:3
INVOLVE 1153:21
INVOLVED 51 13:6,1 6,20 29:24
90:21
INVOLVES 21 51 :7 53:22
IS10A 118: 16
ISAAC 1 3J 20:23,24 43:1 45:7,7
46:5,17,17,20,24 47:20 50:9 61 :5
ISN'T 11159:9
ISOLATED 1180:16
ISSUE 2149:19 62:1
ISSUES 14J 31:1 32:13 39:17 40:
7 43:25 48:11 49:7 55:9 58:6 65:5
85:14 87:16 90:22 91 :21
ITEMS 31 25:15,17,20
ITSELF 1114:10
J
JETTE 1116:2453:5,6 54:21 57:
14,21 58:14 59:1 62:11 65:10 66:
1
JETTE'S 21 63:10 82:22
JOB l10J 10:1912:20,2115:6 23:
15,16 49:14 59:5 81 :24 82:13
JOIN [1133:25
JULY l5J 1:18 2:6 8:1,12 98: 19
JUMPING Pl59:24
JUNE 3176:2 81:2 82:21
JURY 11 79:2
K
ENSURING- JURY
KEEP 16114:20 86:5,9 95:7,8,8
KEEPS 1178:18
KNOWLEDGE !18121 :20 84:8,16,
23 85:2,9, 11 ' 13, 14 86:5,20,24,25
87:15 88:3 89:13 90:3 92:11
KNOWN 12158:25 84:13
KOBRIN 161 3:12,1 3 9: 1,1 73:9 96:
17
KR'S 1185:6
L
LABELS 1112:25
LACK 11136:3
LADY 1153:4
LANGUAGE 11135:2
LAST [7] 20:24 37:16 61:16 63:24
72:20 78:22 82:11
LATIN 11112:12
LAW !412:20,21 3:1 3,21
LAWSUIT 21 10:1 51 :7
LAWYERS !61 9:23 10:6,7 72:25
73:6,17
LEARN 21 51:20 60:1
LEARNED 111 51 :6
LEAST 15J 37:10 40:17 41 :10 42:6
46:6
LECTURE 121 77:16, 18
LEFT 111 61 :23
LEGAL 51 8:7 37:21 51 :21 57:11
68:8
LEONARD rsJ 1:22 2:7 8:8,8,20
98:5
LETTER !41 32:17 35:24 36:8, 13
LICENSE f71 14:21 ,25 15:9 67:19,
21,24 98:23
LICENSED !3168:4,5 98:6
LICENSING !9148:20,23,24 49:8,
9,15 68: 11,12,1 2
LIKELY 11179:3
LINE 21 17:5 78:22
LINES 11180:20
LISA 141 1 :1 2 3:21 9:5 95:4
LITIGATION !1126:18
LITTLE 15115:24 50:8 55:5 59:25
70:20
LIVE !5J 11 :25 62:4 93:16,17,21
LIVED 31 70:1 5 94:20,22
LIVES 111 62:8
LIVING 13110:16 67:1 2 70:14
LLC [211 :11 2:20
LLP 31 3:6,20 4:5
LOCAL L9J22:20 41 :24 71:1 o, 1 o
90:1 92:8,1 4,18 93:4
LONG [71 11:3,12 12:18 13:16 95:
18,24 96:5
LOOK 14J 17:25 18:10 26:9,13 27:
7,11 31:19 47:7 54:10 58:6 63:4
83:8 89:10,25
LOOKING 21 19:3 24: 13
Sheet 4
818 995 2449
LOOKS 1143:8 MOST 111 69:13
LOS !51 2:9 13:9,11 97:2 98:2 MOTEL !21 67:13,13
LOT 11164:24 MOTHER 1162:1
LUNCH 1196:1 MOVE !1165:21
M
MOXON 213:12 73:9
MULTIPLE !4143:25 44:7,8,8
M. D111:12
MUST 41 32:22 33:11 87:2,4
MAC 916:24 53:6 54:21 57:14,21
N
58:14 59:1 62:11 63:25
MADE 4117:14 49:19 97:8 98:12 NAME [7] 8 :6 9:18 20:24 32:15 37:
MAILED 12121:21 28:23 16 51:14 98:18
MAJOR 11164:2 NE 11 3:8
MANY 31 25:17 44:18 64:5 NECESSARILY !21 23:17 56:10
MANZANARES !1812:2 5:4 8:19 NECESSARY 21 97:9,10
9:11,18,2010:16 18:4 27:1 29:23 NEED 16122:16 29:20 34:1 5 50:18
47:9 51 :4 71 :16 90:16 91 :8 95:22 95:19,24 96:5,14
97:18 98:8 NEEDED 12123:14 86:1
MARCH 15J 6:14,17 47:3 48:10 49: NEGATIVE 11187:14
22 NEGLIGENT 11 43:11
MARl E 131 80:20,24 81 :7 NEVER !2129:2 69:25
MARlETT A !114:8 NEW !1164:15
MARK 11189:18 NEXT 2195:21 96:13
MARKED (141 5:14 18:7 24:19 27: NIGHT 11164:6
4 31:17 35:9,12 36:16,20 41:3 42: NN !3118:23 19:6 20: 14
15 44:23 63:2 74:1 2 NNI !1141 :13
MARKING 9118:5 24 :1 5 27:2 31 : NOBODY 41 67:17 73:16,21 93:
14 40:25 42:1 3 44:21 62:25 74:10 25
MARY !191 1 :5,6 7:5 43:2 46:20,24 NODS 41 11:24 51:10 57:16 83:4
47:20 50:8 60:9,22 64:24 65:12 NONPROFESSIONAL 111 43:10
66:1 69:10 70:3,18 74:22 75:22 NOR 118:9
83:2 NOTES [1183:9
MATERIALS [1189:24 NOTHING !11 95:5
MEADOW 111 1:23 NOTICE 1212:10 98:8
MEANING 2127:19 30:7 NOTICED 11196:13
MEANS 13J 11 :118:2419:8,11 25: NUMBER 9115:1 1 27:11 30:25
11 39:3 47:23 48:3 77:3 80:4,1 2 31 :3 40:5 41 :22 42:3 72:6 98:23
81:14 82:9 NUMBERS 31 22:1 6 23:13 71:5
MEANT 61 75:25 76: 7,13 79:20,25
0
82:18
MEET !SJ 69:24 70:3 73:8,11 96:20
OATH !2197:6 98:10
MEMBER !3169:22 71 :16,19
OBJECTION !4133:25 84:1 ,3 94:
MEMBERS !1130:18
12
MEM0 1155:13
OBJECTIONS 31 17:14 98:12,16
MEMOS !2160:8,19
OBSERVATION 1150:1 o
MENTION 1111 :22
OBSERVED 1164:9
MENTIONING 21 73:25 77:11
OBTAIN 21 33:9,15
MENTIONS 11177:14
OBTAINING 1316:4,18 33:8
MET 141 13:22 69:1 0, 16 70:18
OCCASIONALLY 11191:1 9
MILES 21 72:10,11
OD'D 11 152:1
MIND [1J 78:8
OFFICE l31 38:9 71 :1 o, 10
MINE 11113:22
OFFICER [1143:8
MINUTE !11 27:6
OFTEN !11 55:22
MINUTES !31 96:16,17,18
OLD !1162:1
MISBEHAVING !2180:13,16
OLIVE 111 3:14
MISS 131 63:25 73:9 91 :4
ONCE 111 55:24
MISSING [11 25:20
ONES !2J 27:11 44:13
MOMENT 11118:10
ONLY 41 32:21 40:11 44:13 50:3
MONDAY [1147:3
000 (218:3 96:25
MORNING 11 8:6
OPENED 111 49:22
July 10, 2012
OPERATE 11 57:7
OPERATIONS 122111 :11 ,1 2,14
15:4,25 20:15,18 21:2 23:16,18
24:11 28:4 29:24,25 43:11 52:17
61:5 65:1 5,24 66:25 68:19,22
OPPORTUNITY 111 89:22
OPS 121 18:21 20:14
OPTIONS 111 93:19
ORDER [7] 67:1 ,4,4,7 68:18, 19 84:
5
ORG 12169:20,22
ORIGINATE 111 17:6
OTHER (13J 12:15 17:10 23:23 42:
6 46:15 49:2 53:15 57:18 58:11
59:7 86:12 87:13 90:10
OTHERS [1142:1 0
OUT 12o16:22 45:1 2 46:7 47:14,18,
21 55:1 8 64:25 65:7,16, 21 66:1
76:21 79:3 80:1 0,22 81:14,19 92:
12 93:8
OUTPATIENT !SJ 93:5,11 ,12,13
94:13
OUTSIDE 13159:5 73:20 88:11
OVER 11 136:3
OVERDOSE 11160:3
OVERSEE 12110:2415:1 2
OWED 14148:20,21,23,24
OWING 111 49:8
OWN !1192:13
p
P.M !41 83:1 2, 15 95:15 96:24
P.O 111 3:23
PAGE 91 5:3,14 32:2,4 45:6 46:1 2,
23 50:7 63:24
PAGES 12127:1 0,1 3
PAID 131 26:9 33:3 49:15
PARAGRAPH 11178:22
PARENT !2135:20 36:2
PART 9123:15,16 33:3 46:6 49:14
55:11 62:5 74:18 94:24
PARTICULAR rsJ 25:1 32:1 7 78:
19 86:20 91 :9,25
PARTICULARLY !1192:6
PARTIES !318:1110:6 83:18
PARTY !1150:10
PASSING 3129:1 o 80:10,15
PATRICK [71 1:5,7 8:17 10:1 51:
14 57:15 76:4
PATRICK' S !7J 60:1,9,25 61:3 62:
22 76:18 82: 18
PATRONS [1J 30:9
PAY [2130:1 9 56:19
PAYING !1149:8
PAYS 11156:25
PEACHTREE !312:23 3:8,22
PENALTY 11197:5
PENDING 111 10:1
PEOPLE [4J 30:13 42:3 54:11 80:
KEEP - PEOPLE
Certified Shorthand Repmters
818 99 5.2449
16 PURSUANT 1212:1 0 98:8 REFUSED PI 57:6
PERFECTLY 11134:6 PUT 121 80:20 98:1 o
PERFORM 121 55:2 57:14
Q
REGARDING 1216:7,10,14,17,21
PERFORMED 111 55:23
38:1 ,24 41:14 45: 11 49:22 50:15
PERFORMING 111 54:5
QUESTION-AND-ANSWER 111
89:13
REGIONAL 11120:19
PERHAPS 111 91 :21
10:10
PERJURY 11197:5
QUESTIONS 1319:2510:3,8 34:7
REHAB 121 13:9 30:19
PERSON 1
1
1132:9,12 33:9, 15 43:
83:7 90:7,11 ' 17 91:8,12 94:7 95:1
REHABILITATION 111 14:2
97:7
RELATED 11134:3
15 54:5 55:7,9,11 86:2 92:1
PERSONALLY 131 29:23 51 :18 5
2: QUICK 111 83:8
RELATES 11116:5
RELATING 15136:3 58:6 60:9 67:
25
PHASE 1
4
16:22 45:12 46:6 47:21
PHASING 12147:14,18
PHIL 1
6
17:3 63:20 74:21 79:11,20
83:1
PHONE 111 96:11
PLACE [51 1 :11 ,23 8:14 96:9 98:9
PLACES 111 94:22
PLAINTIFF 1118:19
PLAINTIFFS 1311:8 2:3, 18
PLEASE l7J 9:8,18 10:417:19 43:
20 47:20 86:2
POINT I3J 16:21 66:10 68:25
PORTION 111 37:11
POSITION 13115:7 66:19,20
POSITIVE 11164:10
PREPARATION 2160:12 74:19
PREPARE (21 72:15,19
PREPARING 12187:25 88:4
PRESCRIBED 121 54:15 55:18
PRESENT 1114:11
PRIOR 1146:15
PRIVILEGE 11184:2
PROBABLY 161 11:16 20:23 24:3
31 :5 52:5 54:24
PROBLEM 11141 :15
PROCEDURE 12122:4 84:22
PROCESS 1119:24
PRODUCE 5111:1 78:18,24 81 :
18,19
PRODUCED 2126:17 83:3
PRODUCING 11178:20
PRODUCTION 14110:20,23,24 11:
4
PRODUCTION@NARCONON.
ORG 11137:12
PROGRAM 1111 11:2 13:14,1714:
11,1515:842:447:2153:13,19,
23 55:1 2,18 61:13 67:5 93:16 94:
24
PROGRAMS 121 15:13,14
PROMOTE 3178:18,24 81 :18
PROMOTES 11181:18
PROMOTING 11178:20
PRONOUNCE 1137:16
PROVIDE l3J 17:10,21 20:2
PROVIDED 111 17:23
PUBLIC [5141 :18,19,23 42:1 43:8
PULL 2176:21 79:3
Sheet 5
QUOTE 41 41 :14 45:11 65:6 82:7
8 90:4
R
RELATIVE 1118:10
RANDOM 11157:20
RELEASE [7J 33:23 34:8,18,22,25
RANDOMLY 12156:13,15
35:3,5
REACH 111 42:4
REMINDS 111 74:1
READ 1231 17:18,20 31:23 38:5,19,
REPAYMENT 11135:20
20,25 42:22 43:13,19,21 46:12 74:
REPHRASE 15J 15:16 66:4 72:17
18 76:6,10 79:1 5, 19,24 80:8 84:7
84:18 94:17
88:18 89:7 97:8
REPORT [241 5:1 7,19 16:9,12,19
READY 121 18:16 46:11
18:12 19:14,20,22 20:2 22:5 23:5
REALIZE 121 27:1 o .51 :7
26:5 57:22 65:25 71:5 82:22,22
REALLY 1
4
123:22 32:16 34:13 79:
83:2 84:9,12 85:9 88:3 91 :9
10
REPORTED 141 1:23 17:3 66:1 86:
REASON (3J 17:10 53:15 94:9
1
REASONING 111 50:9
REPORTER 161 2:8 8:2018:7 24:
REBECCA 1712:21 8:22 19:24 32:
19 27:4 31:17 35:1 2 36:20 41:4
2 47:2 89:17 93:8
42:15 44:23 51:12 63:2 74:12 95:
RECALL 151 30:8 90:24 91:5,8,14
8 98:6
RECEIVE l71 25:1 2 31:4 84:1 6,18
REPORTING [5J 16:3,4 64:22 70:
85:5,13 93:16
21 71 :3
RECEIVED [101 30:25 31 :1 o 38:23
REPRESENT 31 9:25 26:17 90:
39:3,7, 16 40:5 41:14 81:1 '1 1
18
RECEIVING 61 36:8,12 48:7 63:
REPRESENTING 111 8:8
21 86:24 87:15
REQUEST 1
5
16:3 64:1 9 91 :6,21
RECENT l7J 75:23 76:7,14 81 :25
92:6
82:7, 14,17
REQUIRE 11156:8
RECENTLY 11169:1 3
REQUIRED 112116:8,12, 16,1917:
RECEPTION 141 39:3,7,1 o, 11
4 22:9,12 23:8 33:21 ,22 70:22 71:
RECERTIFIED 111 14:20
2
RECESS 12151:1 83: 13
REQUIREMENT 16119:19 20:1
RECOLLECTION 141 48:6 89:11 ,
22:4,20 23:4 56:4
21 90:3
REQUIREMENTS I7J 16:3,4,6 22:
RECORD [101 8:21 9:19 50:24 51:
15 68:1 1,13 70:21
2 83:11 , 14 95:12,14, 17 98:15
RESIDENTIAL 14159:8,9 93:5, 11
RECORDED 111 98:13
RESPONSE 11 152:13
REDACTED 1138:23
RETIRE [1162:2
REFER 12191 :25 92:7
RETIRED 111 62:4
REFERENCED 1 191:5
REVERT 11164:6
REFERENCING 11134:2
REVIEW 112117:23 21 :3 23:1 8 28:
REFERRED !11 84:13
3,12 29:13 60:8,15, 19 85:22 89:
REFERRING 12145:16 78:21
22,24
REFRESH 121 89:1 o 90:3
REVIEWED 15121:25 23:24 28:9
REFRESHING 11 1 89:21
29:2 50:2
REFUND [1816:4,7,11,15, 1 a 32:10,
REVIEWING 13124:2,10 89:23
13 33:2,8,9,15 35:21 38:1,16,24
REVIEWS [41 23:1 2 29:17,19 85:
91:21 92:6,17
18
REFUNDS !21 91 :6 92:12
RICHARDSON 913:21 9:5,5 17:
REFUSE 11157:3
11 24:23,25 33:25 50:21 95:5
RIDGE 111 1:23
Desm ond vs. Narconon
July 10, 2012
RIESER [BJ 7:5 46:20 50:8 60:9,22
69:10 70:3 74:22
ROBBINS 1111 :12
ROBIN [6J 2:7 8:20 9:8 17:18 43:
20 98:5
ROLE 121 67:3 69:2
ROOM 412:4 8:1 5 54:8,1 0
ROOSEVELT 111 8:14
RULE 12195:19 96:3
s
SAME l5172:2 86:12,19 93:17 97:
8
SAN 121 88:23 89:1
SAW 1
4
1 18:16 46:1 o 72:21 88:3
SAYING [51 37:25 38:15 79:21 24
86:2 '
SAYS 1
21
118:2219:6 26:5,14 38:5,
22 41:13 43:9 47:20 50:8 63:25
64:5,9,14,24,24 75:22 76:21 78:
17 80:3 81:18
SCIENTOLOGY 3130 :9 71:17 73:
12
SEA 121 69:20,22
SECOND 12145:6 78:22
SEE 12ll113:1219:3 23:7 24:7 25:
13,21 26:1 9 33:10,17 34:25 44:3,
11 46:25 47:5,25 53:13 54:11 70:
7 87:25 89:10
SEEING 11165:1 9
SEEMS 1
4
143:1 75:23 80:10,15
SEEN 1
8
118:19 25:7,25 26:8 29:9,
10 35:5 46:9
SEND 1
21
116:15,16,19 17:6 19:20,
21 20:4,5 22:4,9,1 0, 16,20,25 23:5,
11 25:4 59:5 70:22 85:25 86:1
SENDING 11133:11
SENSE 21 15:14 28:24
SENT 1
9
1 17:3 19:16 21 :20 28:1 7
21 32:22 52:14 57:24 58:13 '
SENTENCE 11182: 11
SEPARATE !51 14:14 36:24 37:2
58:18 92:23
SEQUENCE 141 32:22 33:17 37:4
58:2
SEQUESTRATION 11195:20
SERVICE 11 36:3
SERVICES 121 33:4 64:2
SESSION 111 10:10
SET 1
8
155:18 64:15 89:9, 16 93:17
94:3 96:10 98:9
SETTING [1152:18
SEVEN 11190:25
SEVERAL 111 90:20
SHAKES 11187:14
SHE'S 111 64:21
SHORT 11150:21
SHORTHAND 1131 2:8 18:7 24:19
27:4 31:17 35:12 36:20 41:4 42:
PEOPLE-SHORTHAND
15 44:23 63:2 74:12 98:5
SHOW !3144:16 64:5 91:2
SHOWED 111 71 :6
SHOWN !1190:20
SIGN !11 33:23
SIMILAR !2125:25 35:5
SINCE 12113:18 84:2
SIR !2190:24 91:1
SIT!1180:3
SITS !1139: 11
SITUATION !4150:11 80:4,15 94:
11
SIX !4141:13,17 42:1 90:25
SKIPPING !1154:12
SO-CALLED !11 92:22
SOLEMNLY !1197:5
SOMEBODY !4180:13 84:13 88:
11 ,23
SOMEONE !5138:1 ,23 41 : 14 55:1
89:1
SOMETIME !1111:15
SOMETIMES 12117:24 30:18
SOMEWHERE !2122:18,19
SOON !1196:6
SORRY !9118:21 19:21,24 36:7
38:6 47:2 48:22 59:24 77:5
SORT !61 10:10 23:4 70:23 84:22
86:4 94:8
SOUNDS 11144:8
SOURCES !1191:10
SOVEREIGN 121 1 :11,11
SPAIN 11112:12
SPANISH 12111:2112:9
SPEAKING 12111:2112:9
SPECIALIST !118:7
SPECIFIC !5115:20 16:1 23:8 24:
7 94:1
SPECIFICALLY !8122:22 34:1 36:
8,12 75:18 87:2 90:20 94:10
SPOKE !1173:17
SPOKEN !2173:15,22
SPONSOR !5133:2,23 34:10,24
43:9
SPONSORS !4130:23 31:1 39:17
40:6
SQUARE !112:22
STAIR !113:6
START !2110:15 32:4
STARTED !2111:1412:23
STATE !911 :1,2 2:10 9:18 68:4,12
97:1 98:1,6
STATES !21 20:16 38:9
STATISTICS raJ22:8,21 23:6,24
24:2,11 71:13 86:15
STATUS [1148:16
STAY !1113:24
STAYING [1184:5
STENOGRAPHICALLY !1198:13
STICKERS !11 18:3
Sheet 6
818 995 2449
STILL !31 61:8,12 62:8 THERETO 11197:8
STOP 11117:15 THIRD 12126:10 50:10
STORED !1121:17 THREE !8113:12 40:9,11,17 44:3,
STREAM 121 6:21 45:1 11 72:10,11
STREET !31 2:23 3:_8,22 THROUGHOUT 11110:2
STRIKE !4126:25 40:3 45:20 66: THURSDAY l1171:3
20 TITLE !31 10:1911:10 18:21
STUDENT !91 33:2,23 34: 10,24 43: TITLED [3118:121 9:1 332:5
9 51:8 52:1 76:16 78:9 TODAY !91 11:23 22:3 29:16 38:22
STUDENT'S !1151:14 64:9 72:15,16,20 75:23
STUDENTS (17J13:1430:15,16, TODAY'S !118:12
18 31:1 39:17 40:6 54:14 63:25 TOGETHER !1169:20
64:6 67:12 70:14 93:15,20 94: 11' TOOK !1183:22
20,22 TOP !7118:2219:4 20:10 26:5,6
STUFF !31 75:3,6,11 28:21 32:4
SUBMITTED !5126:1 60:16 83:3 TOWARDS 111 35:24
86:17,20 TRAINING !3114:1,8,10
SUBMITTING 12184:23 85:1 TRANSCRIBED !1198:14
SUBSCRIBED !1198:1 8 TRAVEL !1156:20
SUBSTANCE 121 83:19 88:22 TREASURY 111 29:19
SUGGEST !1147:20 TRIAL !1195:20
SUGGESTED 111 52:14 TROUBLE 11164:25
SUITE [312:24 3:9,15 TROUBLES !11 65:6
SUP !i120:14 TRUE !1198:15
SUPERVISION 11113:13 TRY 111 96:20
SUPERVISOR !191 11:11,12,14 TUESDAY !411:18 2:6 8:1,12
15:4 20:15,18 21:3 23:16,19 24: TURN 111 45:5
12 28:5 29:24 52:17 61 :5 65:15, TWO 110113:12 18:11 27:12,21 37:
24 66:25 68:19,22 2 39:25 44:4,11 64:10 87:7
SUPPORTS !1143: 1 o TYPE !31 25:25 33:11 35:5
SUPPOSED !1184:14 TYPICALLY !11 91 :25
SWEAR [119:8
u
SWITCH !21 50:18 51 :4
SWITCHING !1172:14
u.s [7] 20:11 '14,20 38:15 61:2,6,8
SYSTEM 121 21 :16 86:5
UA'S 121 64:9,11
T
UNDER !9157:7,8 59:14 64:1 70:
16 75:23 97:5,6 98: 10
TALKED 12173:1 83:23 UNDERSTAND 112110:3 16:24
TALKS !3177:16,18 78:20 51:15 79:2,3,6, 13,19,25 93:4,10,
TAPE !3176:22 77:14 79:4 19
TARGETS !1147:21 UNDERSTANDABLE [1165:1
TECH 110153:8, 17 54:18,19 55:2,7, UNDERSTANDING l5J38:21 83:
22 56:8 67:1 68:1 9 1 92:21 93:2 94:3
TECHNOLOGY 111 55:17 UNDERSTOOD !1182:11
TELEPHONICALLY !114:9 UNHAPPY !1130:5
TERM !3130:9,10 82:9 UN HEAL THY 111 43:11
TERMINALS !11 30:9 UN-HUH !2128:16 69:1
TERMS !3177:5,8 79:3 UNITED !21 20:16 38:9
TESTED !1164:10 UNLESS !4117:15, 15 50: 18 90:1 o
TESTIFIED !119:13 UP !9120:7 47:7 51:7 52:18 55:5
TESTIMONY !11122:3 29:16 31: 64:15 93:17 94:3 96:19
11 40:3, 10 48:2 83:19 88:6 95:22 UPDATING !11 14:22
98:11,16 UPSET !21 95:25 96:2
THANKS [21 18:3 24:25 URINE !11 64:12
THEREAFTER 11198:13
v
THEREIN !1198:9
THEREOF !1198:18
VARIOUS [4190:22 91 :4,10,20
THERE'S !81 20:18 23:8 27:1 o 41:
VERBALLY !21 51:11,20
22 46:23 47:13 54:18 92:13
VERMONT !1172:7
July 10, 2012
VERSIONS !1121:13
VIDEO 1118:7
VIDEOGRAPHER !714:11 8:6 50:
24 51:2 83:11,14 95:13
VISIT 12169:6 70:10
VISITED !2169:8,25
vs [21 1:9 8:17
w
WANTED !1193:23
WANTS !1184:13
WASHINGTON !114:7
WATER !2112:25 13:1
WAY (51 23:23 33:14 41:22 49:2
87:13
WEEK (4171 :11 72:20 76:4 88:19
WEEKLY !2515:1716:15,19 17:3
18:12 19:14,20,22 20:2 21 :4,7,25
22:5,8,21 23:1 ,5,24 24:2,10 25:4
70:23 71:9,14 86:17
WHATEVER !2130:9 54:12
WHEREUPON !12118:6 24:18 27:
331:1635:1136:1941:342:14
44:22 63:1 74:11 96:23
WHETHER l17J 21:24 23:24 27:9
33:14 36:22 37:7 47:10 48:19 62:
8 63:5 65:16 68:3 72:20 73:3 89:5,
10 94:7
WHOLE !1132:1
WHOMEVER !2139:11 85:25
WILL !61 9:8,18 26:13 83:8 95:8,13
WITHIN !312:8 73:21,21
WITNESSES 11110:6
WORDS !1157:18
WORK !11110:15,1711 :7,1712:2
53:5,5 61:12 62:2 96:8,9
WORKED !2112:1413:8 _
WORKING l5J 12:23 13:22 61:16
64:14,22
WORKS !1161:10
WRITE !1171 :9
WRITES !3175:4,5,8
WRITING 111 32:9
WRITTEN !81 17:25 22:18,19 23:2,
4 55:15 84:12 88:11
WROTE 121 79:11 88:24
y
YAEGER !414:6 9:7,7 95:2
YARKO !712:2 5:48:19 9:11,20
97:18 98:7
YEAR !4111 :5 14:22 55:24 69:14
YEARS [41 11 :13 39:19 87:5,7
YEP !1132:7
YOURSELF [1154: 19
YVONNE l5J 38:6,6,7,22 41 :11
z
ZRIHEN [1120:25
SHORTHAND - ZRIHEN
Sheet 7
818.995.2449
July 10, 2012
SHORTHAND ZRIHEN

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