10a28641 2 2011-10-24 depositionofdondelgado ocr

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IN THE S~ATE COURT OF D~KALB COUNTY STATE OF GEORGIA

PATRICK C. DESMOND AND MARY ) C. DESMOND, INDIVIDUALLY, AND) MARY C. DESMOND, AS ) ADMINISTRATRIX OF THE ESTATE ) OF PATRICK C. DESMOND , )

Plaintiffs, ) ) CIVIL ACTION FI LE

vs. ) ) NO. 10A28641-2

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

Defendants. )

Video deposition of DON DELGADO,

taken on behalf of the Plaintiffs, pursuant

to the stipulations -contained herein, before

Jo Tomoff Fischer, RMR, CCR No. B-924, at

288 Washington Avenue, Marietta , Georgia,

on October 24, 2011 , commencing at the

hour of 2:48 p.m.

Q&A REPORTING SERVICES, INC. Certified Court Reporter s 2165 Fairhaven Circle, NE

1 r ;:

Atlanta, GA 30305 1 i •• • ,\

404.233.3300 ** (Fax) 404.233.1530 ==:2 1.\.1~4 ,~;;,Q : 4 6


Page 2 Page 4 ~ 1 APPEARANCES OF COUNSEL 1 INDEX TO EXAMINATION 2 ON BEHALF OF TilE PLAINTIFFS: I

2 3 JEFFREYR. HARRIS, ESQ.

3 By~. Harris .... .. .. .... ....... . 7 Harris Penn Lowry Delcampo, LLP 4 400 Colony Square, Suite 900 4 By~. Amason ...............•.... 93 ! 1201 Peachtree Street, NE 5 By~. Harris ....... .... ........ . 94 5 Atlanta, GA 30361 6 {404) 961-7650

7 6 -and · - - -

7 8 '! REBECCA FRANKUN, ESQ, 9 ~ B Franklin Law, LLC 400 Colony Square, Suite 900 10 INDEX TO EXHIBITS

" 9 120 I Peachtree Street 11 PLAINTIFFS' ~ Atlanta, GA 30361 EXHIBIT DESCRIPTION PAGE ~

~ 10 (404) 961-5333 12 ~ 11 12 13 *12 Packet of Materials from I ON BEHALF OF THE DEFENDANTS NARCONON OF GEORGIA Delgado Development to 13 and NARCONON lNlERNATIONAL: 14 P.Desmond 38 ~ 14 KATHRYN S. WIDTLOCK, ESQ.

15 *15 Monitors' Duties and Drew, Ecld & Farnham, ILP 15 880 West Peachtree Street Responsibilities 38 .!

~

~ P.O. Box 7600 16 !i: 1 6 Atlanta, GA 30357 18 P. Desmond Document re ~

(404) 885-1400 ~ 17 17 Working Housing 55 ~ 18 18 t. • 19 ON BEHALF OF THE DEFENDANT DELGADO DEVELOPMENT: 1 9 i 20 SEAN L. HYNES, ESQ.

20 * Marked in a previous deposition. ~ Downey & Cleveland, LLP ~ 21 288 Washington Avenue 21 ~ Marietta, GA 30060 22 ~ 22 (770) 422-3233 23 I 23

24 24 I 25 (Continued) 25 l ~

Page 5

1 ON BEHALF OF THE DEFENDANTS USA CAROLINA ROBBINS, 1 (THE FOllOWING TRANSCRIPT CONTAINS QUOTED MD. and TiiE ROBBINS GROUP, INC.: MATERIAL; SUCH MATERIAL IS REPRODUCED AS

2 2 READ OR SPOKEN.) ROBERT G. TANNER, ESQ. 3

3 JEFFREY N. AMASON, ESQ. 4

Weinberg, Wheeler, Hudgins, Gunn & Dial, LLC 5 - - -6

4 Suitc2400 7 i 3344 Peachtree Road (IN THE FOLLOWING TRANSCRIPT, A DASH [ -- ) i 5 Atlanta, GA 30326 8 IS USED TO lNDICATEAN UNlNIENTIO~AL OR (404) 876-2700 PURPOSEFUL INTERRUPTION OF A SENTENCE;

6 9 AN ELillSIS [ ... ] IS USED TO INDICA IE I 7 HALTING SPEECH ORAN UNFINISHED i 8 10 SENTENCE 1N DIALOGUE.) 9 ALSO PRESENT: EUZABETH KEMP, Legal Technology 11 -~

Services, 770-554-1633 12 - -- ~

I 10 13 14 (Thereupon, the court reporter disclosed that she was ~ 11

there on behalf of Q & A Reporting Services, Inc. 12 15 In compliancewilh.Article IO.B of the Rules and ~

~ 13 - - - Regulatioos of lhe Board of Court Reporting of the j 14 16 Judicial Council of Georgia and O.C.G.A. 15-14-37(a) .. 15 and (b), the court reporter discloses that she was ~

j 16 17 retained by Jeffrey R. Harris, Esq., to take down ~ 1 7 the proceedings. Q & A Reporting Services, Inc. ~ lB 18 Vl~ll charge the attorneys the usual and customary

19 rate for the transcript, and will be paid by the I 20 19 .attorneys upon their receipt of the transcript.) 20

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1 (Thereupon, Mr. Amason is not present in 1 your childhood, I'm just --2 the deposition room.) 2 A. Ob, I mean, --3 TilE VIDEOGRAPHER: Stand by. We're now 3 Q. -- curious. 4 on the video record. This is the beginning 4 A. -- my dad worked for various oil companies, so 5 of tape number 1; the time is 2:48 p.m. 5 I was born in Oklahoma, then we lived in New Mexico, 6 MR. HARRIS: Go ahead and swear him in, 6 Texas, Argentina, Bolivia, Dominican Republic, just 7 if you would. 7 pretty much all over. Pretty much a couple years here 8 (Thereupon, the witness is sworn.) 8 and a couple years there. 9 MR. HARRIS: This will be the deposition 9 Q. Got it. And I understand "'~1y you had trouble

10 of Don Delgado, taken for all purposes 10 with my question. 11 allowed by the Georgia Civil Practice Act" 11 A. Yeah. 12 Objections are reserved in accordance with 1 2 Q. When did you ftrst come to-- to Georgia? 13 the CPA and the court's standing order on 13 A. Oh, gosh, that would have been back in '86, I 14 discovery. 14 guess, 1986? 15 I would I ike to use the same exhibits 15 Q. Give me a little overview of your employment 16 that we used last and just keep the same 16 history, starting from when you, say, graduated from 1 7 sequential numbers, if everyone is cool with 17 high school. 18 that? 1 8 A. Let me see. When I was - when I graduated

l 19 MS. WHITLOCK: That's flne with us. 19 from high school, I was working at a restaurant, when I l

2 0 MR. TANNER: Okay, sure. 2 0 was in college. Then I went -- I worked at the Church ~ 21 MR. HYNES: Sure. No problem. 21 of Scientology for four years in California. Then I ~

22 DONDELGADO, 22 cameback,workedforMCiforacoupleof years, ~

2 3 having been first duly sworn, was examined and 2 3 transferred to Georgia. i 2 4 testified as follows: 2 4 Q. "Georgia"; University of Georgia? ~

~2_s ___ I_I_I __________________________________ ~~2_5 _____ A_. __ N_o_,_n_o;_1_1e_re_m_·_-_- _m_A_t_Ian __ ta_. ____________ --4j

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EXAMINATION BY MR. HARRIS:

Page 7

Q. Good aftemoon, Mr. Delgado. I'm JeffHarris; we just met. I'm going to go out a limb and say you work for Tenninix?

A. Yes. Q. All right. When did you first start working

there? A. January of last year. Q. Okay. Have you ever had your deposition taken

before? A. Huh-uh (negative). Q. I'm going to you ask some questions; I may

have to sort of bounce around a little bit. Ms. Delgado has covered a lot of the stuff, so I don't think we're going to have to go back through mu - much, but --

A. Okay. Q. -- there are some points I want to talk about

with you. A. Okay. Q. Tell me, where did you grow up? A. Depends; give me a -- an age and I'll tell you

where I was Jiving. Q. I just kind of want to know generally where

you're from, your background; I'm not going to pry into

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Q. Oh, transferred. A. Yeah. Q. Gotyou.

Page

A. Then I went to work for my dad in Bolivia for several years; that would have been the early '80s. Then got hired -- he was a representative who imported agricultural equipment, so then I started working for the company that he represented, so I was their service and sales manager for South America.

Then, let's see, then I went to work for another company, called Bluffton Agri, and then they got bought out. I went to work for -- I've had -- I've had several jobs. Then I went to work for :MFS/York, which is another agricultural company.

Then I went to work for a company called Wireless Web Connect here in Atlanta for about a year, a year or two. Then I went back to Chief Tndustries, which is another agricultural company.

Then I was out ofwork for a little bit and I started volunteering with :Mary Rieser at Narconon, and thafs when I opened up --well, te - actually took over 1he housing company that they had. That got turned over to Maria, and then I went to work for - like I said, went to work for Narconon after I finished the housing company, turned over to Maria, then I went to

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1 work for Terminix. 1 2 Q. All right. 2

3 A. So... 3 4 Q. AU right. Thank you for giving me that 4 5 rundown. 5 6 A. Am I going too fast? 6 7 Q. No, no; that -- we'll- we'll dig into 7 8 things-- 8 9 A. Okay. 9

10 Q. -that areimportant,that'sjustgood foran 10 11 overview. 11 1 2 A. Okay. 12 13 Q. The four years that you worked for the Church 13 14 of Scientology in Califomia, what were you doing there? 1 4 1 5 A. I worked as a assistant film editor. 1 5 1 6 Q. Okay. And what did you do? 16 1 7 A. Oh, we would take the film that was shot for 1 7 1 8 the training fllms, and then we would edit it and, you 18 1 9 know, put it together and put the sound and music and 19 2 0 stuff to it 2 0 2 1 Q. Were you a member of the Sea Org? 21 22 A. Uh-huh (affinnative). 22 2 3 Q. And how-- was that --your entire time at the 2 3 2 4 Church of Scientology, were you a member of the Sea Org? 2 4 2 5 A. As far as wo~king, yeah. 2 5

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Q. Okay. Do you remember which division you were 1 ~ 2

A. Oh. It was a Golden Air Productions, so I 3 guess that would have been division 4. 4

Q. Did you sign a billion-year contract? 5 A. Uh-huh (affinnative). 6 Q. Did you have any other jobs with the Church of 7

Scientology, after you left the Sea Org? 8 A. Huh-uh(negative). 9 Q. Until the time that you started -- or - well, 1 0

did you have any other jobs with the Church of 11 Scientology, other than the Sea Orgjob we've been 12 talking about? 13

A. No. 1 4

Q. All right. You said you first started 15 volunteering at Narconon vvith Mary? 16

A. Uh-huh (affirmative). 17 Q. Tell me how you first got to know Ms. Rieser. 18 A. Ob, when I first moved to Atlanta, she worked 19

at the church here in Atlanta. And so I started 2 0 attending church there with her, or when she was there. 21

So I've known her for-- since '86 or so, I guess. It's 2 2 been a. while. 2 3

Q. When you -- when you first started 2 4

volunteering, what were you doing? 2 5

Page 12 ~ ~

A. Just whatever she would ask me to do. You I know, I wouJd drive people to the store, or drive them I here, or just help out with paperwork, stuff like that. J I struied helping her out with the Internet, her web ~

site. It was just odds and ends. ~ Q. Approximately when was this, time-wise? ~

I

A. It probably would have been around... Let me think, around '92, maybe? Or, no, 2002. Yeah.

Q. 2002? A. yeah, yeah, yeah. Q. Okay. Where was Narconon located at that

time?

A. It was in Dunwoody. Q. Did you have any involvement with the facility

that was called, I think, the farm? A. No. No, no. Q. Did Ms. Rieser? A. As far as I know, or from what she told me,

they-- originally it was set up in a farm. But I've never been there.

Q. So 2002 when you first started, it was in Dunwoody?

A . Yes. Q. At the same place that it is now? A. No, no, no.

Page 13

Q. All right Where was it? I haven't been to ~.· the new one, so I -- I don't know where it is. ~

A You mean where the new one is, or where the old one is?

Q. Well, where-- well, that - that's a good point. Where have they been, in tetms of their i locations?

A. As -- well --MS. WIDTLOCK: Object to the form. Go

ahead. THE WITNESS: I'm sorry?

BYMR. HARRIS: Q. That was a terrible question, but -A. I'm sony.

Q. -- I hope you understood it. A. That's okay. They were in Dunwoody; I don't

remember the exact name of the street

Q. Uh-huh (affirmative). A. And then they moved to Norcross. Q. And then currently are they somewhere else? A. They're still in Norcross. Q. At some point you became employed byNarconon? l A. Uh-huh (affirmative). Q. What was your job title at that point? A When I actually started, I was in promotion, I

4 (Pages 10 to 13 )


Page 14 Page 16

1 guess. Like public relations and promotions. Mainly 1 Q. Why did you leave? 2 working on the Internet is what I was working with her. 2 A. I got a better job offer ai Terminix. Friend 3 Q. The job description that I have- there-- 3 of mine was working there and he said, ''We need 4 there's a stack of exhibits right here, Mr. Delgado, - 4 salespeople and you're a good salesman," and, you know. 5 A. Yeah. 5 Q. Did -- did you leave on good terms? 6 Q. -- that have been marked in the previous 6 A. Uh-huh (affirmative). 7 deposition. I may ask you to look at some of those from 7 Q. Have you-8 time to time. 8 A. Far as I know. You'd have to ask Mary. l 9 A. Okay. 9 Q. I understand. Have -- have you had any I 10 Q. They're numbered, there's a little yellow 10 contact with Ms. Rieser since you left?

11 thing down there on the bottom. There's one that says 11 A. Uh-huh (affinnative). 12 2, and it's got an organizational chart on it? 12 Q. All right. We'll talk about that in a little 13 A. 2. Got it. 13 bit more detail later. 14 Q. That's it. It lists you as the "Senior 14 A. Okay. 15 director for expansion." 15 Q. Were you involved in any way in Narconon's

I 16 A. Uh-buh (affirmative). 16 attempts during the early 2000s to obtain a license from 17 Q. When-- when did you attain that title? 17 DHR to allow them to 11lll a residential rehab facility? 18 A. I was there I guess about a year and got moved 18 A. Huh-uh (negative). i 19 up into that position, so that would have been 2006, 19 Q. Were you aware of that? ~ 20 maybe. 2007.· 20 A. Not specifically. I'm sure that it would be I 21 Q. What does the senior director for expansion 21 something logical to do, but not specifically. 22 do? 22 Q. Did - when you were - when you were there, 23 A. That's the person in charge of these three 23 . did you have interaction with -· with people who had 24 divisions at the end here. So basically - what does it 2 4 been sentenced to attend Narconon by drug courts? a 25 say here, "Public contact" So public contact is, you 25 A. When I was at Narconon, or at housing? ~

Page 15 Page "I 1 know, reaching out to new people, you know, letting them 1 Q. When you were at Narconon. 2 lmow about Narconon. "Public registration" would be - 2 A. Yes. 3 excuse me, the people coming in and reg ·- and 3 Q. And tell me about that. Did you •• did you 4 registering them for services, and then the "Field 4 talk to the students, did you talk to the drug courts, 5 control" would be the public relations; you know, we did 5 what was your involvement in that? 6 drug education to kids and stuff. 6 A. Just talking to the students, and they would 7 Q. All right. And, I'm sorry, you told me, when 7 say, "Yes, I've been--"- you know, "The judge said I 8 did you leave Narconon? 8 had to go to a rehab program, and we chose Narconon." ~ 9 A. Well, I actually was working at Narconon until 9 Q. Okay. What -- what sort of facility was ~ 10 I worked ai Terminix, so that would have been in the end 1 0 Narconon? What was it allowed to do?

11 ofl guess December of two years ago. That would be- 11 MS. WHI1LOCK: Object to the form. ' {

12 Q. December 209 [sic]? 12 BY l\1R. HARRIS: I 13 A. Yes, December 209 [sic]... -- 13 Q. She -- the lawyers may from time to time I 14 Q. So you left ·- 14 object. Unless -- unless he tells you you can't answer ~ 15 A. -Yes. 15 the question, then - then you can, okay? So don't let 16 Q. You left in December of209 [sic]? 16 that distract you. 17 A. Yes. 17 A. Okay. If you could just specify a little bit 18 Q. Did you leave - well, it-- it's my 18 more, 'cause that could be ... 19 understanding that Delgado Development \\'as 19 Q. Well, I-20 administratively dissolved, and that they're not -- no 20 A. I •• I don't know how to answer.

I 21 longer involved ·· or, Delgado Development is no longer 21 Q. You were in charge of the- of the intake 22 involved in providing any kind of residential housing, 22 coordinator, right? -- I 23 and that that occurred around 2009. Did -- did that 23 A. Yeah. 24 have anything to do with you leaving? 24 Q. - That was somebody underneath you. So 25 A. No. 25 presumably, then, you would have been in charge of

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Page 18 Page 20 i 1 making sure that if someone came to Narconon deman<ling 1 Q. The- the -- the- specifically the Narconon I 2 certain kinds of rehabilitation services, that -you 2 course materials, have you done those? f 3 made sure or your employees made sure that Narconon 3 A. I've looked through them. I 4 could in fact, pursuant to its license, provide those 4 Q . . Okay. Well, how- how do you know that those 5 services~ fair? 5 materials are specifically designed·to get people off 6 A. Uh-huh (affirmative). 6 drugs? 7 Q. An.d -- and my question is, so therefore you 7 A. Because when you look through them they tell ~ 8 had to know, I assume, in order to do your job, what 8 you not to do drugs, and they're geared towards, you 9 Narconon was licensed to do, right? 9 know, not lying, not doing drugs, not -you know, that

10 A. Pretty much. 10 kind of stuff. 11 Q. All right. So what could they do? 11 Q. Was Narconon allowed to operate a residential 12 A. They could provide rehabilitation services to 12 rehabilitation facility? 13 the clients. 13 :MR. HYNES: Object to fonn. You can '!

~

14 Q. All right. And-- and what sort of 14 answer it if you're able to. ~ 15 rehabilitation services could they provide? 15 MS. WHITLOCK: Join in tl1e objection. I 1 6 A. I mean, do you want me to describe the program 16 Tiffi WITNESS: rm -- what was it, l'm 17 itself, or- 17 sorry? ~

18 Q. No; we've gone over fue program. 1 8 BY MR. HARRIS: I 19 A. You know about the program? Okay. 19 Q. Could Narconon operate a residential 20 Q. Yeah, I do. I do. 20 rehabilitation facility?

J 21 Just-- just the --the program, the-- the 21 MS. WH11LOCK: Same objection. 22 eight steps, that s011 of thing? 22 THE Wl1NESS: "Residential"; in other

~

I 23 A. Yeah. 23 words, where they lived on the premises of 24 Q. Were you involved in-- any in teaching or 24 the Narconon program? 25 training people about the - any of the eight steps? 2 5 BY MR. HARRIS:

Page 19 Page 21 . 1 A. No. 1 Q. Right. When I use that term, what does it ~

2 Q. You didn't have any --you didn't do any -- 2 meantoyou? I 3 any of the sections? Any- any-- any of books 1 3 A It would mean like an inpatient type of I 4 through8? 4 facility. 5 A. Have I personally done them? 5 Q. Okay. So - and, again, part of your job--6 Q. Well-- 6 A. Oh. 7 A. Or did I teach them? 7 Q. -- duties was -- was to oversee the intake i 8 Q. Did you teach them? 8 coordinator, right? .. 9 A. No. 9 A. Right Well, and-- and let me intetject here }

10 Q. Have you personally done them? 10 just a little bit, or clarifY this. Because actually, i 11 A. Pretty much the .majority of them, yeah. 11 even though the intake coordinator was supposed to ~

12 Q. Did you do them in connection with Narconon? 12 report to me, he actually reported over to division 2. I 13 A. No. 13 Q. So this organizational chart is wrong? 14 Q. You did them with the Church of Scientology? 14 A. To my knowledge, yes. 15 A. I did courses that were related or similar to, 1 5 Q. Okay. Well--16 let's put it that way. 16 A. 'Cause this person here actually was in this

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I 17 Q. I understand. But you -- you've basically 17 division over here. 18 done the Scientology equivalent of each of those levels, 18 Q. Well, as the senior director, then, for I 19 each of 1 through 8? 1 9 expansion, --20 A. They have similarities; I mean, these courses 20 A. Uh-huh (affirmative). 21 are designed to get somebody off of drugs, and the 21 Q. -- was -- was Narcouon allowed to operate an

' 22 courses I took were just self-bette1ment courses on, you 22 inpatient, as you've descdbed it, residential rehab ,i

23 know, how to improve relations, how to, you !mow, get 23 facility? 24 along better in life, how to live -- live a moral life, 24 MS. WIDTLOCK: Object to the form.

~ 25 that kind of thing. 25 TIIE WITNESS: I don't know if they were •"' "\''"' ''" ·· .. d··''l,l;·::.'T.L~IIll'::.:tr.tiooliD'l.~-- ;•;.. :-· ... ~ ··~~:·~·~ .... ~-•• ~Ct<i:-... ~c' f<.i•:~c;;~a;-:~:..:.-,~,..~\Sf.:o,~.:,;;a~u:·.~w;.::,;~,'.;•.•~~;~l(;:;;.:,..,·.,•.~:~i:~l;.:'i.ool~~~-~ - - ~;:;.;,-i'c~.'i;;-t~.llll:.~-"""""'l'-=:.o;.'"--'·"" --

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1 allowed to or not, but we didn't. 2 BY MR. HARRIS: 3 Q. Okay. And you say you didn't. At some point 4 was there --was there a-- a relationship developed 5 between Narconon of Georgia and a facility where people 6 would -- would reside? 7 A. Sure. 8 Q. And what was the name of that company when you 9 first came to Narconon?

10 A. Oh. Disc.overy Path. 11 Q. Discovery Path; do you know whether that was 12 incorporated? 'Cause I can't find any in-- any 13 evidence of it existing. H. A. I - I don't know if it was incorporated. Two 15 different guys were running it when I first started 16 volunteering, and then one guy took it over, and then I 17 took it over from him, so ... 18 Q. And who were these guys? 1 9 A. I -- I'd have to -- I don't remember their 20 names. 21 Q. And how did you come to take it over from 22 them? 23 A. Mary had asked me, to see if I would be 24 interested in doing something like that. 25 Q. What did she say to you, what- what was the

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1 opportunity that she presented you? 2 A. She said, "Would you like to--" you know, 3 "Would you like to open up a-- a residential housing 4 and, you know, you could service the students that go to 5 Narconon." 6 Q. Okay. Now, did she tell you that you'd be 7 servicing any other students? 8 A. It was open. 9 Q. Okay. But did you?

10 A. No. No. 11 Q. So -- so all the students, when you were --1 2 when you took over Discovety Path, all those students 13 came from Narconon? 14 A. Yes. 15 Q. And you had a - Discovery Path had residences 16 where? 17 A. In Dunwoody. 11ley had three houses that were 18 about two blocks away from theN arconon facility. 1 9 Q. Did Ms. Rieser ever say anything to you along 20 the lines of, "Hey, you know what. we -- we can't get a 21 residential license, so what we're going to do here is 22 we're going to -- we're going to let you run Discovery 23 Path, and we'll send all of our students to you"? 24 A. No. Not per se. 25 Q. Well, if not per se, tell me about it.

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Anything along those lines, any .conversations related to I M .

A. She told me at one point I guess that ! they'd-- they'd had the farm, and that was a reshi -· if residential center. And then, from what I understand, I · don't know if she actually ]ost the license, or they just decided to actually just do the outpatient facility with a residential thing connected to it; I'm not sure exactly what the details are on that. But she wasn't happy with the guy running the residential housing, so she said, "Would you mind taking it over.''

Q. So how did-- if they're- if they were totally independent, then how in the world could she have any control over him 5taying there or not?

A. She couldn't. MS. WHI1LOCK: Object to the form. 1HB WITNESS: Yeah..

BY MR. HARRIS: Q. Doyou --A. He didn't have to stay there. Q. Well, you said she wasn't happy with him? A. Right. Q. And this was the guy who ran Discovery Path? A. Right. Q. And - and you took over for him?

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A. Right. Q. Well, how did she get rid of him? A. Well, she talked to him, and he talked to me,

and he was -- he was tired of it. Q. Okay. A. And I said, "Okay, fine, rll take it over."

I mean, it- it was -- it's a-- it's a hard job. Q. I understand. A. So, anyways, he was burned out or whatever,

and then he -- you know, he said, "Fine, ril just leave."

Q. Wh -- you don't remember his name? The guy J you directly took over from? ~

A. It's been a long time. Sean, maybe? I could I ask Mary. She would know. ..

Q. All right. Well, we can probably dig it up. A. Yeah. Q. When you took over the Discovety Path- ~~, A. Uh-huh (af:finnative). Q. - I think I asked you this-was it

incorporated under that name? A. I don't know if it was incorporated or not. Q. Well, that's what you called it? --

t A. Yes. ~

Q. --Discovery Path? i - ·-~ , · ' '"'"""~- - -~~c ·..wl'je··......,._. . .• -~~~-:!:io.i::'~ .... -sz---·'9'± -~

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A. Yeah, yeah, yeah. Q. Was it affiliated with-- well, did- at some

point did you form Delgado Business Development? A. Yes. Q. And what was that? A. That was... I formed Delgado Business

Development before then, I believe, and then just merged it -- since it was already an incorporated business, just merged it and -- and made that into housing.

Q. Okay. A. But that was a while back, and that was a

venture that I was going to go into and I don't even remember what it was for, but...

Q. Well, and that's -- that's what rm trying to

figure out, is, --A. Yeah. Q. -- was -- was Delgado Business Development the

company that was in place that - that ran the housing before Delgado Development came into play?

A. Maria formed her own company, and I think that was called Delgado Development. I think my company was Delgado Business Development, but we called it Delgado Development.

Q. Okay. A. If I recall correctly.

Page 27

Q. And-- and just so fm clear, then Delgado Business Development, when you were running the housing, that was the company that you were in charge of?

A. Yes. Q. What happened to it? A. Oh, it closed. I mean, it... Q. Did-- did you do anything with it? Did you

dissolve it or anything like that? A. Not formally. Q. Did you list Delgado - at some point you

filed bankruptcy, did you not, sir? A. Yes. Q. Did you list Delgado Business Development

as -- as an asset in your bankruptcy papers? A. I don't think so. Q. Who were your shareholders for Delgado

Business Development? A. Pretty much just me. Q. But when you say "pretty much" ... A. Well, yeah, then it was me. Q. "Just me"? A. Yeah. Q. Tell me how-- how-- how did it run on a

day-to-day basis? How -- how did-- and I won't call it Delgado Business Development now; you -- you referred to

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it as Discovery Path, right? A. I mean, at first it was Discovery Path, and

then we switched over to Delgado Development, so --Q. Well, what'd you call it on a day-to-day

basis? A. Delgado Development. Q. All right. A. Yeah. Q. Delgado Development. A. Yeah. Q. Which is different from the one that Maria

starts later? A. Different company, yeah, yeah, yeah. Q. Got it. A. I mean, it's same-- same facility, same

people, just different incorporation.

Q. Tell me what you did. How did-- how did Delgad -- how did Delgado Development, when you were in charge of it, how did it run?

A. Well, basically, I-- I mean, I can tell you like the daily routine?

Q. Yeah; just give me an overview. A. Okay. You !mow, we wouJd make sure -- well,

first of all, first thing in the morning, we would just make sure that everybody was up, everybody was getting

Page

ready. And then we would take them in buses to the -to the Narconon facility. And then pretty much that was it until the end of the day. And so at the end of the

29

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~ 1

I t

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;

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day we would pick them up and bring them back to the housiog facility, and then we had a schedule deperu:ling on what-- you lmow, what day of the week it was; we ~ might take them to the grocery store, you know, we might f have an activity, but -- but pretty much it was just

monitoring, making sure that they were fine and that --you know, cooking dinner and not getting in trouble.

Q. And then you-- the monitors that --that checked in on them, who were they employed by?

A Delgado Development. Q. And-- it-- were any of those people-- or,

were - were those people graduates, for the most part, ofNarconon of Georgia?

A. Some of them were and some of them weren't. Q. Do you have any idea what the percentages

were? A. Well, it- I mean, the - the turnover, it

just varied fi:om year to year, or month to month, even, sometimes.

Q. Now, when- when Mru.y Rieser first talked to you about this opportunity, she said she was unhappy with this other guy?

8 (Pages 26 to 29)


Page 30

1 A. Uh-buh (affirmative). 2 Q. And what did she say to you specifically 3 about, "Hey, here's why you ought to do this"? 4 A. I mean, from what I remember, she said, you 5 know, "It would definitely be a big help if we had 6 a-" - see, the -- well, let me backtrack a little 7 bit. The Narconon program has different sections to it. 8 So the -- the - the guy that was running the housing 9 development at the time had not been through any of the

1 0 sections, didn't know anything about the sections, 11 whatever. So he wasn't really able to communicate with 1 2 the residents as far as what they were doing, how they 13 were doing, what the next step was, this and that. And 14 so they would break a rule and he would just kick them 15 out. I mean, he'd just kick them out on the street. So 16 she said, "Since you know, you know, what they're going 17 to be going through, they're going to be going through 18 the sauna, they're going to, you know, have these 19 emotional reactions come up, you can talk them down, 20 you're a good commtmicator, and, you know, you could 21 help me in that way. Because we can't watch them -I 22 mean, we can watch them here at Narconon, but then when 23 they go home, you know, I - I would like somebody that 24 I can trust that would be there to -- you know, to be 25 there for the students."

Page 31

1 Q. And if a student violated a rule, who did you 2 report it to? 3 A. We would write up a report for their file, and 4 then we would send a copy to Narconon to let them know 5 that something was going on with that student. 6 Q. TheKRs?-7 A. Uh-huh (affirmative). 8 Q . . -Is that what you called them? 9 A Uh-huh (affirmative).

10 Q. So you kept a copy of the KRs, and -11 A. Uh-huh (afflflllative}. 12 Q. - then you also sent one to the ethics 13 officer at Narconon? 14 A Yes. 15 Q. Who was the ethics officer back when you were 16 doing it? 17 A. They changed a couple of times. Larry--18 Q. Chorvas? 19 A. Larry Chorvas was one; then they had -- Chip 20 Bullard was another guy. I tlrink they had somebody else 21 in there too. But, anyways, it was a couple different 22 people. 23 Q. And then how-- how did the students pay you? 24 A. Usually the students didn't pay me; it was the 25 parents or-- or the spouses pay.

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Q. Okay, but rm --I'm- that was a terrible

Page 32 g I

question, I'm -A. Sorry. Q. Thank you. I mean, did they write a check to

you, did they write a check to Narconon, or both, or how-

i

A. Delgado Development. They wrote a check to Delgado Development or, you know, gave us a credit card.

Q. Okay. Did you .give any of the proceeds back ~~ to Narconon?

A. Huh-uh (negative). · Q. Was there ever any discussion about that? i A. Huh-uh (negative). I Q. Was there ever any statement by 1\lfs. Rieser i

i that, "Hey, you know, we're going to send all of our

1.

students to you"? A. No. Q. Was that the understanding? I A. That was the hope. ~ Q. Well, was that the understanding, that you ~

were going to get all the students that Narconon had? j·.·

A. She did not say specifically, "rm going to send yon all the students," because when we started we were the only housing c.ompany. So when there was--there \vas another student that graduated that opened up

Pa ge 33

his own housing company, and we started sending - then Narconon started sending students over there also. So that was a little bit of a - an upset, I guess, but that's business. I mean, you know, you can send your business to whoever you want

Q. Well, do you know of any students that Narconon had back when you were nmning the Delgado Development that they sent somewhere else for housing?

A. Uh-huh(affirmative). Q. Who?

~

I I i A. Who -- which students? il ~

Q. Yeal1, which students. ~ A. Oh, I don't know; there was a bunch of them. 1 Q. Okay. ! A I mean, we had two housing facilities; one was ~

run by one of the students, the other one was run by ~ Delgado Development. Or one of the graduates, let me ~

put it that way. His mom came .in and invested money, I 1 and a couple of guys came in. Anyways. So some of them ~

would go to one housing fucility, some would go to the ~ other housing facility. ~

Q. So there was another company? ~

A. Uh-huh (affirmative). ~ Q. And-- and do you think that the bulk of the ~

Na.rconon students were distributed between Delgado ~

9 (Pages 30 to 33)


Page 34 Page 36 j

1 Development and this other company? 1 you to expand, is - I 2 A. Right; and then some of them actually were 2 A. Oh, yeah. I 3 outpatient; they just came in from home. 3 Q. --Mary-- okay. 4 Q. Where-- what was the name of the other 4 A. Oh,yeah. 5 company? 5 Q. Mazy came -- Mary came to you and said, "Hey, 6 A. I'm sorry, my memory-- 6 we need to expand''? 7 Q. No, I understand, it's a long time ago. 7 A. Right 8 A. I'll remember it. Hang on a second. 8 Q. And you did? 9 Tilis guy named (Pronouncing) J ohno started it 9 A. Right.

10 with Brent. I'm sorry. I don't remember right off the 10 Q. And at that point Discovery Path or whatever 11 top of my bead. I can find out for you. 11 it is, Delgado --12 Q. Thafs okay. I can -- if you can't remember, 12 A. Yeah, Del -- well, it was still DL--covery I 13 then we'll - we'll worry about it some other way. 13 Path, 'cause we were still in the transition when we 14 A. Okay. But, yeah, there were -there 14 actually went to One Sovereign Place. I 15 definitely were two housing companies that, for the most 15 Q. And you started leasing out apartments at 16 part, were about equally divided as far as how many 16 One Sovereign Place?

J 17 students each one got. 17 A. Uh-huh (a.ffumative). 18 Q. So you were nmning tllis housing -- this 18 But that was after we talked to many different 19 housing company; did you - did you have a business 19 complexes. I 20 license? 20 Q. So you went around and looked at different 21 A. Uh-huh (affirmative). 21 apartment complexes? 22 Q. Where was the business license? 22 A. Uh-huh (affirmative). 23 A. Where was it located? 23 Q. Did you tell the people at Sovereign Place, 24 Q. No; I mean. but what- what county did you 24 "Hey, we're going to be running this residential--" --25 have a business license in? 25 A. Oh, yeah.

Page 35 Page 37

1 A. We were in-- I think it was in Cobb. 1 Q. -- "facility here"? )

i 2 Q. When you had housing, or when you were running 2 Who -- who did you talk to over there? 3 housing, at some point Discovery Path I believe began to 3 A. It was the leasing manager, whose name is ... 4 obtain apartments at Sovereign Place? Is that right? 4 I'm going to say Mru.y, but I'm not a hundred percent 5 A. Well, here's what happened. The -- we had the 5 sure. It should be on the leases and stuff Do -- do

I 6 three houses. That Discovery Path was -- was - was 6 we have those, or no? 7 doing. And then they -- they got full. Like there were 7 Q. Not -- not that fur back. 8 more students that wanted to come in, more students 8 A. Okay. 9 wanting to come in, so they got full. So one of the 9 Q. There - there are leases from 2008 that are

1 0 first things that Mary said when -- wanted me to do 10 here,-- i 11 as - as part of taking it over is find another place 11 A. Okay. 3 12 for them to actually -- so we can expand. So I went 12 Q. -which you're welcome to look at, but I'll I 13 with this guy to One Sov - well, actually went to 13 just tell you most of those say "Maria Delgado," or they 14 several different apartment complexes, looking for a 14 a1 -- some of them say "Maria Delgado and Discovery 15 place that would accept, you know, rehab, a- a rehab 15 Path," which is what was confusing me. i 16 housing facility. 16 A. Oh, okay. Yeah, 'cause when we fixst went to l 17 Q. So - you said "houses," so you all had three 17 talk to them, it was Discovery Path. l 18 little - I mean, three individual residences? 18 Q. And Discovery Path-19 A. Uh-huh (affinnative). 19 A. Let's see. Well, her name is not here, is it. 1

i 20 Q. Thai were full of students? 20 Allison, Allison, her name's Allison. 21 A. Right. 21 Q. Let me see that for just a second. 22 Q. And then Mary said, "Hey, we need to expand"? 22 A. Yeah, go ahead. Her name was Allison. 23 A. Right; well, we knew that anyways, 'cause we 23 Q. Allison was the leasing coordinator? 24 didn't have anyplace to put them. 24 A Yeah. -- I think -- thought she was the leasing ~ 25 Q. Well, js that what - is that what prompted 25 manager. But anyways, yeah, she vvorked at the complex. ~

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10 (Pages 34 to 37)


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Page 38

Q. Okay. So you- you lease up these apartments, -

A. Uh-huh (affinnative). Q. -- and -- and we don't have those leases, but

do-- do you remember, were those leased under the name Discovery Path?

A. They may have been originally. And then we switched to Delgado when the lease was up.

Q. All right. A. Ifi recall correctly.

(Thereupon, Mr. Ta.nner exited the deposition room.)

BY:rvtR. HARRIS: Q. In front of you there in the stack of stuff

is--A. Uh-huh (affumative). Q. -- two exhibits. Pull out No. 15 and No. 12

for me, if you would. A. Okay.

MR. HYNES: What-- 15 and what? 20? MR. HARRIS: 12. MR. HYNES: 12.

(Thereupon, Mr. Amason entered the deposition room.)

THE WITNESS: Okay, here's 15. And, I'm

sorry, what was the other one? MR.HYNES: 12.

(Discussion off the record.) 1HE WITNESS: 12, here it is, here it

is. Okay, good. BY MR. HARRIS:

Q. You got it? A. Yes, sir. Q. Let's take a look at this fu:st one here.

Pag e 39

Well, before we -- before we take a look at it, let's talk for a second. At some point, you, for some reason, decide you're going to let Maria take over the hoilsing?

A. Uh-buh (affirmative). Q. Why'dyoudothat? A. We were in the middle of a divorce, and, you

know, she said that she wanted to take over the company, and I agreed with her.

Q. Did- at the time when it was Discovety Path, \ll'as she -- was she working with you on the housing?

A. She may have helped out a little bit, but she wdSn't like a staff member or anything. I mean, if she came by once a month it may been a lot, but she didn't -- she -w-asn't really involved in the housing in the beginning.

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Page 40 ~ i

Q. When -- when you had these conversations v.ith • Mary Rieser about -- about doing this, you were - you were at that time an employee ofNarconon of Georgia?

A. Volunteer. Q. No, well, it would have been in 2006, I

believe, or 2007, when Discovery Path was operational be - excuse me, before - before it transitioned to --to the company nm by Maria, which is Delgado Development, --

A. Right, right, right Q. -- before that happened, there was a period of

time where you were running housing where you were employed by Narconon? i_

A. No, not really. ~

Q. So there was no -you were always a volunteer ~ before you -- ~

A. Uh-huh(affumative). ~ Q. - did that -- ~ A. I didn't get paid by N ar -- I mean, I !

volunteered, but I didn~ get paid by Narconon. And I then I started running housing, and then Maria took over j the company, and then - then I started actually working ; as an employee for Narconon. i.~

Q. Okay. So there wasn't a period of time, then, ~

where you were in charge of either Discovery Path or I l

Page 41

Delgado Business Development, where you were also, at the same time, employed by Narconon of Georgia?

A. Huh-uh (negative). Q. And you're certain of that? A. Uh-huh (affirmative). I mean, like I said, I

may have been volunteming or whatever, or-- whatever, ! but I wasn't on the pa)Toll, I didn't get paid, it ~

wasn't something that I was expected to be there or anything like that.

Q. Okay. So -- so when - when Mary presents you • with this opportunity and comes to you and says, "You ~ know, I don't like this other guy, he's -- I want- I :.~ want somebody else to take this over," at that point in ~ time you were a volunteer at Narconon? j

A. Uh-huh (afflfffiative). l ~ Q. Okay, good. All1ight. Thank you. ~

N 1? ~ ~ - I

A. Okay. l Q. Exhibit No. 12 that's in front of you there. !

This is a fmm -- this is actually the fmm that -- that ~ Patrick signs. ~

A. Okay. ~-Q. And you met Patrick? A. Oh, yeah. ~ Q. And you met his parents, right? ~

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11 (Pages 38 to 41 )


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A I1hink so. Q. All right. Now, this fonn says "Delgado

Development Recovery Residence" on it. A· Uh-huh (affirmative).

Page 42

Q. Ms. Delgado has testified that she didn't do this form, so rm trying to figure out who did. Did you -- did you draft tllis form, or did somebody from Narconon?

A. Whlch ones? Q. The first one. A. The confidentiality agreement? Q. Yes. A. Let me see. I believe I did. Some of the

stuff we got were forms already filled out by Discovery Path. So we kind of inherited from them. And then I tweaked them or left them as-is, so... This may have been one that was -- 'cause that doesn't sound like my writing. It may have been one that was inherited from Discovery Path. I just know it was in the packet of files that we got from him.

Q. And that's what I'm trying to figure out. Where did these fonns come from?

A I mean, like I said, I inherited some from Discovery Path. so I'm assuming this one was, you know, sent over from Discovery Path.

Pa ge 43

2 3

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9 10 11 12 13 14 15 1 6 17 18 19 20 21 22 23 24 25

1 Q. Do you know-- well. do you know whether 1

2 Narconon International had any involvement in helping to 2 3 draft this thing to make sure that - 3 4 A. Oh. 4

5 Q. -- ifs HIPAA-compliant? 5 · 6 A. I don't have the faintest - 6 7 Q. · Obvious -- 7

8 A. -- idea. 8 9 Q. Same-- and I don't want to go through all 9

1 0 these in -- in -- 1 0 11 A. Yeah. 11 12 Q. -- great detail, but the same question. was, 12 13 did you specifically draft any of these forms or these 13 1 4 waivers yourself? 14 15 A. Like I said, some of them were just whatever 15 16 was handed to me, and some of them were the same thing 1 6 1 7 but I tweaked the!ll. Like the student checklist, I made 1 7 18 that up. You know, I wrote up the billing infonnation. 18 1 9 The payment policies, I think that was done. The 19 2 0 philosophy I wrote, if this is the one - yeah, I think 2 0 21 this is the one that I wrote. Was pretty much I kind of 21 2 2 cobbled together. Lefs see, the rules were something 22 2 3 that I got and then I -- we had to revise them as - 2 3 2 4 yeah. it says "revised," so they were revised as they 2 4 2 5 were going along. 2 5

Pag e 44 ~

Q. You say you "got" them; do you remember who you got them from?

A. Well, from the files from Discovery Path. Q. Did you get any of the documents from other

Narconon facilities across the country that have residential components, and use any of those to help you draft some of this stuff?

A. No. It probably would have been nice, though . . But, no.

Q. So -- well, let me ask you this. Other than the ones you've-- you've talked about, --

A. Uh-huh (affirmative). Q. -- are there any fonns that you specifically

drafted that you didn't get at least a shell from the -from the people who were running it before?

A. Well, like I said, the checklist, for sure. Let me see here. Let's take a look.

MR. HYNES: Take your time. THE WITNESS: Oh, okay. MR. HYNES: We'renotinarush. You

need to just make sure you're comfortable THE WITNESS: Sorry. :MR. HYNES: --with what you're looking

at. 1HE WITNESS: Sony.

This one was already done. Wel~ I know the checklist, the new

student billing information, I put those together.

The philosophy, rm -- I'm pretty sure I did most of that.

The resident rules, like I said, were --

Pa g e 45

we --we got some of that from Discovery Path and then we added to it.

Lefs see here. Oh, is this the same thing?

(Discussion off the record.) BYMR. HARRIS:

Q. Okay. A. Oh, I'm --the -- the privilege and penalties,

I put that one together. Connnunication, I pretty much did that one. The -- the rules violation one, I think he may

have had something similar to that, but I expanded on

~ ·

' I ~

I i

it. Yeah, the resident responsibilities, I put ~

that one together. I Contacts 'vas already there. The consent form ~

was pretty much already there. Breathalyzer was already J there. Confidentiality I think was there. Sick days,

1

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12 (Pages 42 t o 45)


Page 46

l we got some of it and I added to it. The activity 2 waiver was ah·eady there, the phone release was already 3 there. ~ The -I believe the leave of absence was -5 he may have had a couple of rules on it and we expanded 6 that. 7 Yeah. And the visitor rules was --there were 8 some infonnal visitor rules, but -- but I pretty much 9 put that one together.

10 Q. Okay. Thank you. 11 A. Uh-huh (affirmative). 12 Q .. And I -- rm --should have asked you this at 13 the beginning of your deposition. Who is paying for 14 your attorney? 15 A. Ifs not me. I don't know. 1 6 Q. So--17 A. He just told me to come here. 18 Q. - it's not you? 19 A. Huh-uh (negative). They just told me to come 20 for the deposition. 21 Q. Before your deposition here today, what did 22 you do in order to prepare? 23 A. What did I do in order to prepare? 24 Q. Yeah, what did you do in order to prepare? 25 Did you meet with anybody, look at anything, --

Page 47

1 A. Huh-uh(negative). 2 Q. -that sort of stuff? Just came in cold? 3 A. Huh-uh (negative). Well, my attorney called 4 meup-5 MR. HYNES: Don't-- just don't- you 6 can tell him that we talked, --

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Page 48 1 Q. Melanie Eyre? Or Eyre, I don't know. . A. 1 think-- I think we met and she asked me a

couple of questions. That -- was that Maria's attorney ~

beforehand? ~~ Q. I'm -- I'm asking you whether you met with ·

her. I --I'm not sure whose attorney she was, now. · A. I met with another lady -- ~

Q. Okay. l-A. -- who was Maria's attorney. I -- rm not a

hundred percent sure what her name was. We only met ~ ~ i once.

Q. Do -- did -- have you ever had any meetings with any ofNarconon's lawyers?

A. I've met them, but I -- I mean, rve met them, "How do you do," but never sit down and discuss any legal case or anything like that.

Q. Well, and after-- after the lawsuit was filed in this case, did you receive a copy of it?

A. Huh-uh(negative). Q. You never got a copy of the lawsuit? A. Huh-uh (negative). Q. Well, when did you flrst learn about it? A. It would have been I guess right after the

lawsuit was filed, Maria told me about it. Q. Okay. Go back to Exhibit 15.

Page 49

A Okay. Q. "Monitors' duties and responsibilities." A. Uh-huh (affirmative). Q. And I'm-- I'm going to ask you the same

question that I asked you -A Sure.

~

~

I 7 1HE WITNESS: Yeah, we talked. 7 Q. - about the other documents. Is this 8 MR. HYNES: -- but he doesn't want you 8 something that you wrote and that Delgado Development ' 9 to get into the substance of what we-- 9 inherited, or is it something that-- that-- that

10 THE WITNESS: Oh, yeah, we -we ta1ked. 1 0 Discovery Path inherited from somebody else? 11 BY MR. HARRIS: 11 A. No, no, no. J wrote this. As far as I I 12 Q. Yeah, I don't want to know the conversations, 12 !mow--I haven't read through the whole thing-unless I 13 I just want you to generally tell me what you did, and 1 3 it's been changed, but I wrote the original "Monitors' ! 14 if you -- if-- you talked to your lawyer, right? 14 duties and responsibilities." To train the monitors on 1 15 A. y eab. 15 how they're supposed to deal v,;:ith -- with the residents. I 1 6 Q. And your lawyer being Mr. Hynes here? 16 And it may have been added to - I may have 1 7 A. Yes. Well, - 1 7 added a couple of things to it over the time period, I 18 Q. Have you-- 18 but, yeah, this was mine. 19 A. --yeah. 1 9 Q. There are a number of rules and guidelines 2 0 Q. Have you specifically, have you- have you 2 0 here; it's numbers 1 through 27. t

21 retained Mr. Hynes, have you signed any kind of document 21 A. Okay. ~ 22 retaining his counsel? 22 Q. And there are a number of these that appear to ~ 2 3 A No, I haven't signed any document, no. 2 3 be very specific to Narconon. l 2 4 Q. And Ms. Eyre, did you ever meet with her? 2 4 A. Uh-huh (affirmative). J 2 5 A. Who's that? 2 5 Q. Why is that? i ~~t':_.,.~I(M,Ib;.1l~.iGi<~l~'-t:-'•~~-!!tll.:o:.:..~+~~-., ~-..-...··fti~-(t;..'J!~~"~~"~'~ ~.1M-i.r!'l'::.-.:u~;}•tc~~~.'"'~~ ... '( '. lli.:C..'.~ili~~~~"'~~~~m~....t:r;~WF::t50:;;::~~r.:ot.· .. •Jor:~\I;C"~.;:.¥~.~~i:!i

13 (Pages 46 t o 49)


Page 5 0

1 A. Mainly because we were servicing Narconon 1 Q. You put that in there? 2 stUdents. And the other thing is, is most of the 2 A. Uh-huh (affirmative). 3 monitors were Narconon graduates, if not all of them. 3 Q. And no input-- input from Narconon? 4 Andiftheyweren'tNarconongraduates, theywere 4 A. Huh-uh(negative). 5 . familiar with some of the Narconon program. 5 Q. And then about-- talking about "wins in tl1e 6 Q. Okay. Did-- did Narconon -- did Ms. Rieser 6 program"? 7 have any-- any input on your rules? 7 A. Uh-huh (affirmative). I put it together. 8 A. Huh-uh (negative). 8 Q. Saying that the -- the monitors needed to 9 Q. So she -- she ever- did you ever give her a 9 "know and apply 'The -- The Way to Happiness'"?

10 copyofthem? 10 A. Uh-huh(affinnative). 11 A. Uh-huh (affinnative). I think so. 11 Q. Totally your decision, not-12 Q. All right. And she -- she had no input at all 12 A. Uh-huh (affirmative) 13 on the rules that you were implementing? 13 Q. -- any input fi·om Narconon? 14 A Asfaras"Ithinkyoushouldaddthisruleor 1 4 A Huh-uh(negative).

Page 52 j

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I I I

I ~

15 take out that rule"? 15 Q. "Withholds," number 14, you --16 Q. Well, did she read them and, say, comment on 16 A. Uh-huh (affinnative). 17 them? Say, "Look, I think we need to have a rule that 17 Q. - used the language '\vithholds''? 1 8 deals with this," or not? 18 A. Yeah. 19 A. Huh-uh(negative). Notreally. 19 Q. NoinputfromNarconon? 20 Q. Soyoujust -- youputinallofthesetenns 20 A. Huh-uh(negative). 2 1 that are in here that -- that are specific to the 2 1 Q. The fact that all your knowledge reports are 2 2 Narconon treatment program. you put those in yourself? 2 2 sent to the ethics officer at Narconon; why did you do ~. 2 3 A. Uh-huh (affirmative). 2 3 that? ~ 2 4 Q. Okay. 2 4 A. Drug addicts are very sneaky. Can be vety I

l-2_s ___ A_._L_ik_e_--_w_e_l_~ _an_ywa __ ys_,_Yeall _ _ · ---- ---l-2_s __ s_n_eak:y __ - _An_ d_w_h_a_t I_b_a_d_£_oun_d_o_u_t_w_as_ th_a_t _so_m_e_bo_dy--11

Page 5 1 Page 53 ~ ~. 1 Q. Well, I mean. number 8 talks about "ethics 1 could act up in housing, and then go to Narconon and be 1

2 situations"; you decided to put that in? 2 Mr. or Mrs. Goody Two-Shoes. So we thought it was ~ 3 A. Which number 8 was that? 3 important for Narconon to know that, "Hey, you know, !

4 Q. Nlunber 8. 4 Jim-- Joe Blow ran off last night, so you should be i 5 A. 'Don't discuss other- residents' procn·am 5 aware of that, because, you know, that may be something I 6 with other residents"? Or am I looking at th~ wrong 6 you want to address in your program, because it's -- ~. 7 one? 7 it's-- he's disrupting other people in the program.u ~~ 8 Q. You're on the wrong one. 8 Q. If someone ~vanted to leave the premises, -- I 9 A. Okay. 9 A. Uh-buh (affirmative). ~

1 0 Q. On the -on the monitors. 1 0 Q. -who do they get approval ftom? ~ 1 1 A. Okay. 11 MR HYNES: Just object to the fom1. 12 MS. WlllTLOCK: That's the number 8 I 12 My - the only objection is, you mean 13 have, too. 1 3 Narcononpremises, or Delgado? 14 BY :MR. HARRIS: 1 4 MR. HARRIS: Yeah, tltanks. 15 Q. Yeah, it says "ethics situations" down there; 15 BY MR. HARRIS: 16 it says, ''Don't --don't discuss their problems or 16

1 7 ethics situations." You see that terminology? 1 7 18 MS. WHITLOCK: Oh, it's that same one 18 1 9 that he was reading, it's just further down. 19 2 0 MR. HARRIS: Yeah, it's just the last - 2 o 21 or, towards the end. 21

2 2 THE WI1NESS: Ob, oh, okay, got you. 2 2 2 3 ''When discussing past--" -- oh, yeah, got 2 3

2 4 you, got you. Yeah. 2 4 25 BY MR.. HARRIS: 2 5

Q. The Del-- the Delg~o Development. If you had a student at the - at the Delgado Development property, right? --

A. ill1-huh (affinnative). Q. - You with me? And they want to leave, they

want to go take a field trip with their parents to wherever; who did they have to get permission from?

A. Ifl recall correctly, in the leave form they had to get it -they had to get it approved. We were -- we would have liked to get something from

I !

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Page 54

Narconon saying it was approved from N arconon. 1

Because- same sort of deal; if they're acting up at 2

Narconon and being Mr. Goody Two-Shoes or Miss Goody 3

Two-Shoes at housing, we wanted to know about it So 4

ideally they would get some kind of approval from 5

Narconon, they would send it to us, and then we would 6

have to approve it, and most of the time we would 7

call -- calL the person involved to say, "Are you-- are 8

you reaUy- are they really going to leave with you?" 9

Q. Any of the employees that you had-- that were lO employed by Delgado Development, or whatever it was 11

called when you were there, -- 12

A Yeah. 13

Q. -- any of those folks, at the same tin1e they 14

were employed by your company, also employed by 15

Narconon? 16

A. It's possible. 17

I'm trying to think. 18

There may have been -- well, you know what -- 19

what it may have been is that they may have worked 20

part-time hours with me. They may have been employed at 21

Narconon and then worked -picked up some shifts at 22

Delgado Development. 23

Q. Did you keep records of that? Their hours, 24

when they were working, that sort of thing? 25

Page 55

A. Pretty much. 1 (Thereupon, marked for identification 2

purposes, Plaintiffs' Exhibit No. 18.) 3

BYMR.HARRIS: 4

Q. Do you have any records, any corporate records 5

of any kind, for Discovery Path or Delgado Development? 6

A. I turned all that over to Maria 7

Q. So you gave -- 8

A I may have like the ledger, like the -the 9

checkbook, you know, where you Mite checks on them. 1 0

And the seal, I have the corporate seal, too. 11 Q. The corporate papers, the articles, the little 12

book and all that kind of good stuft? 1 3

A I think I have that. 1 4 Q. Any other corporate documents that you still 15

have? 16

A. Huh-uh (negative). 1 7 (Thereupon, marked for identillcation 18

purposes, Plaintiffs' Exhibit No. 18.) 19

BYMR.HARRIS: 20 Q. Let me show you what I've marked as 21

Exhibit 18. 22 A. Okay. 23

Q. This is from Mr. Pat- from Patrick Desmond's 2 4

file, and it says, "I'm going to contact Don Delgado and 2 5

Page 56~

inform him that I have graduated the program and I want ~ h . •

to work ousmg." 1 A Uh-huh (affirmative). . Q. Did -- did that happen? Did- did Pahick

talk to you about working housing? A I think he did, yeah. Q. It-- at -- when this -I'm not sw-e it says 1

on here when it is, but when --when would you have been ~. in charge of housing when Mr. Desmond was there? ~

A Well. he-- as far as I understand, he came-- I didn't he come -- he came twice, didn't he? Yeah. So ~~ it would have been the first time that he was there.

Q. The first time he's there, I think he's there approximately four months? J

A Uh-huh(affumative). j Q. And then he wants to --well, he's --he's

there -- he's doing the program, -A Right. Q. - takes him like four months? -A Right. Q. - Something like that. And then he- he

wants to -- he's got to stay there for six months pm-suant to his court order,--

A. Okay. Q. - and then he wants to work housing; is that

Page 57 t I your recollection of how this all worked out?

A. Sounds - sounds about right Q. Okay. So he says to you, ''Hey, I want to work

housing," and then you -- did you approve that? A. Uh-hub (affmnative). Q. What do you remember about that? What- what

were Patrick's responsibilities and job duties and so forth at that time?

A. Basically being a monitor. You know, same as the other monitors.

Q. What training did he - did he get? A. Really the - the stuff that he had at

Narconon and then- I don't even know ifrd actually had this written up when he was a monitor. But basically we would-- the new monitors, we walk them around, we show them. you know -- obviously, they know where the apartments are, but, you know, we would tell them, "This is what's going on in this apartment, this is what we do," the schedule, but since -- well, I'm trying to remember if anybody from other housing came by and worked with us. I don't think so. But they already knew the routine, they, you know, knew what monitors were supposed to do and not do. 'Cause they'd lived there.

Q. When you were nmning the housing division, or

I I I

15 (Pages 54 t o 57)


Page 58

1 housing program, -2 ' A. Uh-huh (affirmative). 3 Q. -- did you ever have any conversations or 4 discussions with anyone from N arconon of Georgia about 5 whether or not the operation that you were running would 6 require some smt of license from the DI-IR? 7 A. Hl.lh-uh (negative). 8 Q. Do you know what you can do in terms of 9 running a residential facility that houses people who

10 are in drug treatment ·without running afoul of any of 11 those regulations? 12 .MR. HYNES: Just object to the fol1ll, but 13 you can answer- answer it if you're able 14 to. 15 Tiffi WITNESS: What - when I was 16 first - when I first took over housing and 1 7 did a little research, I mean, the-18 according to, ifl recall con ectly, the 19 American [sic] with Disabilities Act, people 20 that have disabilities have aright to Jive 21 together. And there are many-- I mean, 22 there's dozens of recovery residences in 23 Atlanta Georgia's kind ofpru.ticular in 24 that way. But we went to Alpha Recovery; 25

1

2 3 4

5

6 7

8

9

10 11 12 1 3 14

15 16 17 18 19 20 21 22 23 24 25

Q. Exhibit 12 that you have there in front of you-

A Okay.

Page

Q. --says Delgado Development is "residential housing for chemically dependent persons" in that first paragraph. Do you see that?

A. Okay. Q. What's the difference between recovery -- a

"recovery residence" and "residential housing for chemically dependent persons"?

A. I guess it's the same thing. I -- I don't know exactly, to be honest with you.

Q. Well, do you know what you could do in order to run a recovery residence and be compliant with the DHR regulations? Do you know specifically what you were allowed to do and what you weren't allowed to do?

A. Well -- I answer. ~

:MR. HYNES: Object to form. You can

THE WITNESS: Yeah. The thing is, it ~ was a recovery residence. We weren't 1 allowed - or, let's put it this way, we did J not perform any kind of recovery treatment ~

~i. there. We didn'thaveAAmeetings, like a lot of the recovery residences do; we didn't

r-------------------------------------------,_------------------------------------------~1· MARRis another one where they have their

Page 59

1 housing facility and then they do their 2 treatment somewhere else, but... TI1ere was 3 an organization called - was it MARR? But 4 anyways, you could - the Metro Atlanta 5 Recovery Residence. Anyways, it was one that 6 you could join, but it -- it didn't require 7 any -- there wasn't any requirement from 8 getting a license from DHR. 9 BY MR. HARRIS:

1 0 Q. Well, how do you know that? 11 A. 'Cause that's what they told me. 12 Q. Who told you that? 13 A. The - tllis organization. 1 4 Q. So you talked to this organization related to 15 recovery residences? 1 6 A. Uh-huh (affi.nnative). 17 Q. And they--18 A. And they --19 Q. -said--20 A. Well, they gave me -- you go --you go on 21 their web site and they have a list, "If you want to 22 join tllis organization and be part of the organization 23 of recovery residences, these are the requirements that 24 we need." So they want this, they want that, they want 25 this, that and the other, and. .. So, anyways.

'-":i;;:.-":"lai-:-:N: .. . - •. ·=.-."-- ~:.~~:.I.~A: .. ~~~-~:s-~t.o:r• <:A'o;~~,;,.,-~~~ •

1 2

3 4 5 6 7 8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 - ""'

Page

do a lot of that kind of stuff. It was

basically a residence where they would -- and this was my own thing. It's like, you know, I told them - I would tell them when they would come in, I'm like, "You're learning how to live your life again." And I -- and what I would tell them is like, "You're off to college, you're in a dorm, so you're going to have to learn how to cook, how to clean, how to look after yourseJL be responsible, like this is -- you're doing this part to learn how to go back out in the world and not run armmd and do drugs and stuff."

So, but, no, we didn't have any - we didn't have any meetings, we didn't have any, you know, psychologists on staff or anything like that.

BY MR. HARRIS: Q. Did you store pharmaceutical drugs on the

premises?

61 i

A. On occasion, when -~ when it was prescribed by a doctor, then we had their prescriptions that were locked up.

Q. Well, when you say "we," who -- who locked them up?

16 (Pages 58 to 61)


Page 62 Page 64 ~

1 they cause trouble for everybody. ~

1 A. Oh. The monitor would lock them up, or I • I 2 would lock them up. 2 Q. And - and I'm not -- I'm not interested in I 3 Q. Well, what's - what's the legal authority for 3 any specific conversations you may have had, but did you

4 taking somebody else's prescription drugs and locking 4 at any point -- by "you," meaning you or your company, i 5 them up? 5 when you were in charge of the housing; did you consult I 6 A. I have no idea. 6 with an attorney to determine whether or not you could I 7 J\1R. HYNES: Object-- object to the 7 do certain things and be compliant with the regulations I 8 fonn. 8 in Georgia? ~ 9 BY MR. HARRIS: 9 A. No. ~

~

Well, did-- did you look-- 10 Q. You never did? t.

10 Q. ! 1

11 A. Ob, I'm sorry. 11 A. Huh-uh (negative). j

~ 12 Q. -- into that at all to determine whether or 12 Q. Okay. ~ 1 13 not that was something that you could do as a recovery 13 You said Patrick was "awesome"? ~

~

14 residence? 14 A. Uh-huh (affirmative). ~ 15 A. It never came up. 15 Q. How was he awesome? What did be do? Tell me ~

~ 16 Q. It never came up? 16 a little bit about your interactions with him. ~ 17 A. (Witness shakes bead negatively.) 17 A He was just a nice kid. I mean, he was very I 18 Q. Meaning nobody brought it up to you? 18 friendly, I mean, obviously when - when people first 19 A. Uh-huh (affrrmative). 19 get there they're not in their right mindset, I guess, ~ 20 Q. Did anybody from Narconon ever say to 20 'cause they're still hooked on the drugs and they're t

~

21 you--either Narconon of Georgia or Narconon 21 still thinking about that. But as be stayed and as he ! 22 International--"Hey, you can do the following things 22 progressed through his program, he was just, you know,

I 23 without running afoul of the DHR regs, but you can't do 23 real helpful and real happy. Just he's -- real nice 24 others"? 24 guy. 25 A. . Mary did tell me at one point-- Ms. Rieser 25 Q . Let's back up, then, and talk a little bit i

Page 63 Page 65 1

1 told me at one point, "You're not a-- you're not a 1 about that. Your interactions with Patrick and his I 2 treatment facility." So we weren't - I know that in 2 family. 3 the Narconon program they have different things that 3 A. Uh-huh (affirmative). ~

j 4 · they can do as far as, you know, giving somebody an 4 Q. When he first checked into Narconon, were you I 5 assist, or, you know, taking somebody for ·a walk; we 5 there? 6 weren't - she said, "You can't do that, because you're 6 A. I don't remember specifically.

~ 7 not treating them." 7 Q. Do you recall having any conversations with 8 Q. So -- 8 either Patrick, his -- or his mother or father when he ' 9 A. So we weren't allowed to do that. Or, no, 9 first got to Narconon? .

J 10 let's - lefs put it this way; she said we couldn't do 10 A · I would assume I did. I don't remember

I 11 that. 11 specifically meeting with them. 12 Q. Anything else that she told you that you 12 Q. Do you remember taking them over and giving 13 couldn't do? 13 them a tour of the housing facility? 14 A. There were times when we would have loved to 14 A. I probably did. I don't remember specifically ~

15 kick some students out, - 15 taking them. I mean, we would get- we would get two 16 Q. Uh-huh (affirmative). 16 and three new students a week, sometimes. So it was 17 A. -- and she talked us into keeping them But, 17 kind of like the routine; you take them, you show them I 18 I mean, that's just business. When you're dealing with 18 around, you know, they go back to Narconon; if they 19 a client, you try to do what the client wants you to do, 19 stay, they stay, if they don't, they don't. So l ~

~ 20 even though sometimes it -- it hurts a little bit 20 don't --I don't remember specifically meeting with I 21 Q. Uh-buh (a.ffinna1ive). 21 them, but I'm sure I did. ~

22 A. 'Cause there were, on several occasions, 22 Q. Well, is it your- is it your co1ftention ~ 23 clients that I would have been happy to get rid o£ 23 that -- that Delgado Development is completely t 24 Not Patrick. Patrick was awesome. But I'm 24 independent from Narconon? ' 25 just saying you get some troublemakers come in there and 25 MS. WHITLOCK:. Object to the fonn. ~

~ :A

17 (Pages 62 to 65)


Page 66

1 THE WITNESS: Atthetime, I mean, 1 2 'cause it's no longer existent, but- I'm 2

3 sorry, what was the question, again? 3 4 BYl'vfR. HARRIS: 4 5 Q. Do you contend that - that Delgado 5 6 Development-- and rm talking about the time when you 6 7 were in charge, -- 7

B A. Right. Right, right. 8

9 Q. -- not when Maria took over. But Delgado 9

1 0 Development is completely independent from Narconon? 10 11 MS. WHITLOCK: Object to the form. 11 12 THE WITNESS: I would say no, and -- and 12 13 only in that they were our client. Or 13 1 4 their - their students were our client. 14 15 BYMR.HARRIS: 15 16 Q. Do -do you believe that Narconon has no 16 17 control over any of the activities that take place at 17 18 Delgado Development? 18

1 9 A. When I was control --when I was controlling. 19

2 0 When I was in charge, I mean, I would say no, as far as, 2 0 21 you know, could Mary come and say, or could somebody at 21 2 2 N arconon come and say, "I want you to do this, this and 2 2

2 3 tl:ris." Now, as a -- as a provider to my customers, she 2 3 2 4 might come and make suggestions, and say, "You know, 2 4 2 5 I -- I think maybe a field trip would be good," or 2 5

Page 67

1 something like that, but it wasn't something that we 1 2 were bound, like, you know, "Yes, sir, Mary, we're going 2 3 to do it." I mean, that wasn't the case. But it - you 3 4 !mow, it was basically just customer/client 4 3 conversations. I mean, your customer Vl'llllts a blue and 5

6 you only have green ones, then you paint that one green. 6 7 Q. When Patrick was first checking into Narconon, 7

8 do you know what he was sentenced to do by the drug 8

9 court of Florida? 9 1 0 A. When he first checked in? 1 0 11 Q. Yes. 11 12 A. Huh-uh (negative). 12 13 Q. Do you know what the requirements of his 13 1 <; sentence were? 14 15 A. Huh-uh (negative). 15 16 Q. Did anybody from Narconon tell you? 16 17 A. Huh-uh (negative). No; 'cause it's -- it's 17 1 8 confident - I mean, we don't -- unless they want to 1 B 19 tell us. Like we're- we're basically there to provide 19 2 0 a residence for their recovery. But it's not like we go 2 0 2 1 into their past and figure out, "Okay, are_ you here 21 22 because of your-" -- you know, they'll-- they'll 22 23 volunteer and say, "Well, I'm here on a court sentence," 23 2 4 but as far as giving us the details... You know, as 2 4 2 5 long as they followed the rules and everything like 2 5

Page

that, then they were fine. We didn't delve into their- we weren't supposed to delve into their past, let me put it that way. I don't know if some of the monitors did or didn't.

Q. How did you come to have Patrick as one of the residents?

A. He - well, he came into Narconon, and then came over to Delgado Development.

Q. How did he get there? A How did he get to Narconon? Q. Yeah; I mean, he-- he goes into Narconon, he

ends up at your place; why does he end up at your place when he went into Narconon?

MS. WHITLOCK: Object to the fonD.. Tiffi WITNESS: Don't know.

BY MR. HARRIS:

I I I !

Q. Youdon'tknowhowhcgotthere? J A. Huh-uh (negative). You -- you mean as far 1

as - I mean, the -- the -- the people at Nar --the -- I the registrars at Narconon would -- I mean. they knew -both housing facilities. So they, just based on the J

* personality and-- I -- I suppose based on the ~

personality and some of the -- you know, talking to the ~ parents and to the client, would decide which one may be. i a better fit. And -- and also based on who was already I

Page

in the housing. Q. You're -- you're saying that there was, at the

time that Patrick arrived at -- at Narconon. that there was another housing facility that Narconon was sending people to, other than Delgado?

A. Uh-huh (affirmative). Q. What's the name of it? A. I can call -- I can take two seconds to find

outforyou. Q. Let's do that. Let's take a break. A. Okay.

MR. HYNES: Well, wait-- hold on a minute.

Tiffi \VITNESS: rm sorry. MR. HYNES: How about --THE WITNESS: I don't remember, I'm

sorry. MR. HYNES: We can take a break, but-:MR. HARRIS: He volunteered, and he said

he's going to do it; I don't have any problem with that. Let's take a little break and let him do it

THE VIDEOGRAPHER: Going off the video record at 3:49.

(Recess at 3:49, resumed at 4:02.)

18 (Pages 66 to 69)


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Page 70

THE VIDEOGRAPHER: One moment. We're 1

back on-- hang on. We are back on the 2

record at 4:02. 3 BY MR. HARRIS: 4

Q. I should have asked you this earlier, 5 Mr. Delgado, but what was your rank in the Sea Org? 6

A. As far as? 7

Q. What was the highest rank you attained? 8

A. (No response.) 9 Q. Did you have a naval equivalent rank? 1 o A. Huh-uh (negative). 11

Q. Were you there at the same time as Ms. Rieser 1 2 was there? 13

A. No. 1 4 Q. You didn't meet her there? 15 A. Huh-uh (negative). 16

Q. Web sites-- oh, rm sony, you-- when we 17

broke, you were -- you were going to go see if you could 18 find me a name, and I --your-- 19

A. Oh. 20

Q. - attorney's told me it's West Co., is 21 that -- 22

A. Yes. 23 Q. -- what you remember? 2 4 A. Yeah, yeah. 2 5

Page 71

Q. AU right. Thank you for doing that. I 1 appreciated it. 2

Let's talk about web sites for a minute. Were 3 you in c.harge of the web sites for - or, were you in 4 charge of sort of putting together, for lack of a better 5 way to put it, the web sites for Narconon? 6

A. Uh-buh (affirmative). 7 Q. That was one of your job descriptions? 8 A. Yes. 9 Q. And in connection with that, did Narconon 10

secure a number of different domain names? 11 A. Uh-huh (affirmative). 12 Q. Do yourememberwhatsome ofthose were? 13 A . We worked on AtlantaR.ecoveryCenter.com and a 14

couple other -- couple of other ones, but they 15 weren't-- those are the two main ones, 16 AtlantaR.ecoveryCenter.com and DrugsNo.com. 1 7

MS. WHITLOCK: Excuse me, "DrugsNo"? 18 1HE WITNESS: Yes. 19

BY MR. HARRIS: 2 0 Q. And any of the web sit.es that you were 21

involved ·in helping Narconon put together, did any of 2 2 those web sites mention that Narconon was -- or, had 2 3 in -- any kind of affiliation with the Church of 2 4 Scientology? 2 5

Page 72 J A. I know that they didn't say there was any -- · I

well, depends on how you classify "affiliation." I know 1 that they mentioned -- I know that Atlanta Recovery i mentioned William Benitez, who founded Narconon and had ~ read a book by L. Ron Hubbard, who in tum was connected i to --to the Church of Scientology, so -- but that would ' be the eA.1ent of any kind of... But as far as ~ affiliated. no. ~

Q. Well, did-- did any of the web sites say ~ L. Ron Hubbard, the founder oftbe Church of j Scientology, that the teachings or the -- or the i addiction counseling that you're going to get at the ~ Narconon facility is based on that? i

A. Not to my recollection, no. Q. Were-- well, were you specifically told by

anyone not to put the word "Scientology" anywhere in the

web sites for Narconon? A. Huh-uh (negative). Q. Just decided not to do that on your own? A. I mean, the -- the web sites were already

made. My job was to optimize them. -Q. Uh-huh (affirmative). A. -- To get better search engine results. Q. So who made the --who made the web sites? A. T11e original web sites? I don't have the

faintest idea. Q. Where did you get them from? A. They were already existent when I first

started working there.

Page

Q. Well, when they needed to be updates, did you have to get any code or anything like that?

A. Oh, yeah. Q. Who did you get it from? -A. Well -Q. - To get access to the original sites? A. I would assume Mary gave me the passwords to

get on there. I mean, you have to -- you have to log in to the -- to the server and this and that, to actually get into the -- you lmow, the web site domain to make any changes or add any pages and stuff.

Q. Well, do you know whether or not the Desmond family actually first located Narconon on the web?

A. (No response.) Q. Is that a conversation you had with anybody?

(Discussion off the record.) THE WITNESS: Oh, no. I'm sorry.

BY MR. HARRIS: Q. Did Delgado Development have a web site? A. For a short period, yes. Q. What was it called? Or what was its domain

! I I

I l 1 !

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Page 74 Page 7 61

1 name? 1 that? 2 A Oh, goodness. I -- I would have to guess. I 2 A When I was at N arconon, yes. i .. 3 don't know exactly. 3 Q. Tell me about that; what sort oftrainfug did 4 JviR. HYNES: Don't - don't guess or 4 you receive? I 5 speculate. 5 A. We had a doctor who would come in, at least -6 THE WITNESS: Okay. Sorry. 6 I think it was at least once a month, and give us

' 7 BY :MR. HARRIS: 7 lectures on, you know, drug counseling and drug types,

I 8 Q. Well, I mean, do you have any recollection of 8 drug usage, that sort of thing. 9 what the domain-- domain name was at all? 9 Q. Do you know who that doctor was?

10 A No. 10 A. Dr. Robbins, I believe. 11 Q. You can't give me something that's close, so I 11 Q. You think Dr. Robbins carne once a month? I 12 can try to research it? 12 A. She was a lady that was out in Alabama. I 13 A. DelgadoRecoveryResidence, maybe. 13 Q. What- what did she look like?

i 14 Q. Okay. And do you know who hosted it? 14 A. Older lady. 15 A. No. 15 Q. Caucasian, African-American? 16 Q. You said for a short time; why was it 16 A I believe she was Caucasian. I 17 discontinued? 17 Q. • .<\nd you said "out in Alabama"? J,

18 A. Didn't really have the funds or the 18 A. Uh-huh (affitmative). I 19 wherewithal to keep it up. So -- and it wasn't -- it 19 Q. rm -- rm sorry, what did -- she came over • I 20 wasn't really-- we weren't really advertising on the 20 from Alabama -- I 21 web. I mean, it was j ust something, you know, every 21 A. Uh-huh (affirmative).

I 22 company has their web site they put up, so we put one 22 Q. --to teach you guys? ~ 23 up, and then we just didn't follow through with it, I 23 A. Uh-huh (affirmative). ii ~

24 guess. 2 4 Q. Oh, okay. All right. So she would come once I 25 Q. You -- you weren't advertising on the web why? 25 a month from somewhere in Alabama and give you sort of a -Page 75 Page 77 ~

~ 1 A. Just didn't get into it, I guess. 1 tutorial on something related to drugs and alcohol? ~ 2 Q. Well, is that because you were getting all 2 A. Yeah, uh-huh (affirmative). ~ 3 your clients from Narconon? 3 Q. All right. I

· 4 A. Probably. 4 A. Yeah; 'cause, as a staff member ofNarconon, ~

I 5 Q. The web site for - for Narconon - well, 5 we were required to have continuing education. That was 6 excuse me, the - the -the different web sites that 6 like part of the training that we would receive. You I 7 Narconon has that you've identified for us, or the 7 know, plus there were books and pamphlets and stuff we I 8 different domain- domain names, were you involved in 8 had to read on drug addiction. 9 any way in drafting the language on those web sites 9 Q. Out-- outside of your affiliation with

10 · about what kind of housing Narconon offered? 1 0 Narconon, have you ever run any companies where you 11 A. No. I didn't -- in fact, I don't even know if 11 yourself were involved in capturing domain names that ~~

~ 12 it says anything about housing on the web sites. 12 were designed to try to obtain web traffic for people

~ 1 3 Q. Well, assuming that it does, did you have any 13 searching for drugs and alcohol counseling? 14 involvement in drafting any of that language? 14 MS. WHTILOCK: Object to the form. ~

~

15 A I don't recall anything about housing, or 15 THE W11NESS: No. No. I 16 drafting anything about housing, on the web sites. 16 BY MR HARRIS: ~ 17 Q. Tell me- 17 Q. Have you been affiliated with any of those 18 A. I mean. it may -- I'm sony, excuse me. It 18 companies? 19 may now, but back then, I -- I mean, I don't know now 1 9 A. No. 20 what it -- 20 Q. So you've never had any involvement with any 21 Q. Okay. 21 company that -- that actually registered - rm talking £

~

22 A. - specifically has on it or not. I haven't 22 about independent from Narconon, now. --23 browsed through it in a while. 23 A. Uh-huh (affirmative). 24 Q. Have you received any training in any kind of 24 Q. - You understand my question. And -- and 25 addiction counseling, drug rehabilitation, anything like 25 independent from Delgado Development. Have you ever had

-.,..., ........ "'""'.~ . ~~~·-~·- ~St1r."6;;,o,.'i:;;<..::.?.:i;',;.~t:..'f~:'l""~i;,».).'lb,.'"!l,,of.O.\it=:,~;;~~-•·;~~·,::~~-;_:=,_M~;;.,~r.::,ik;:",i/;f:o.<:J •:(o:c:oo.b.--.~.~~"'\~'.S.'ili.''%i:~S...~.'l~::!~,;_·Jit,: ;.'fl~• ;~\.;&<;·~~~.~~..;i:,-.:;.~~&lii::.~ .. 20 (Pages 74 to 77)


1 2 3

4

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6

7

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9

10 11 12 13 14

15 16 17 18

19 20 21 22 23 24 25

Page 78 Page 80 i any involvement with any other company that was involved 1 A. Not that I'm aware of. I think I would have ~ in-any way in web-based advertising for folks searching 2 known about that. ~ for drug and alcohol rehab counseling? 3 Q. Okay. No recollection of that at all? ~

A. No. 4 (Discussion off the record.) ~

Q. Okay. Just going back to Patrick for a 5 THE WITNESS: Oh, no. Sorry. J second, - 6 BY fv1R. HARRIS: ~

A. Uh-huh (affirmative). 7 Q. I think you mentioned earlier some- some 1 Q. - I just want to recap, and I may have asked 8 training that you'd done about I think it was -- or -- ~

you this already and so I apologize, but you don't 9 or - or some accreditation avenue for -- for ~.-recall any specific conversations that you had with the 1 0 residential -- for rehab residences, I think it was ~

Desmond family about Narconon or housing or anything? 11 called? ; A. Not specifically, no. 12 A. Uh-huh (affrrmative). ~ Q. Do you recall telling them anything about the 13 Q. Is it the Georgia Association of-- •

relationship between Narconon and Delgado Development? 14 A. GARR, yeah. I t

~: ~~o;~~~:~l~~;:~~~~:~~uallytaking ~~ _ ~: ~=ry~:s~;;~:.Association ofwhat? '

either Ms. Desmond or Mr. Desmond over to Delgado? 1 7 Q. Recovery Residences, thank you. I can't get m

A. Not specifically. rm -- I may have, but I 18 that through my head. Did you attempt to get accredited J don't remember exactly. 19 by them? ~-~

Q. Was --was it your practice to- to tell 2 D A. I looked into it. ~ folks who \Yere registered or who were staying at Delgado 21 Q. And -- and what happened? ~ that there was --that-- that it was a completely 2 2 A. Just never followed through. i independent facility from Narconon? 2 3 Q. Why? Why did you decide not to do that? ~

A. That was the practice, yeah. 2 4 A. It-- it was something that was on the back ! Q. And is that what you believe you did with the 2 5 burner, that we were looking at doing, and just -- it ~

~------------------------------------------+-------------------------------------------~~ Page 79 Page 8 1 ·~

1

2 3 4

5 6

7 8

9

10 11

12 13 14 15 16 17 18 19 20 21 22 23

24 25

~ >

Desmonds? 1 didn't seem-- I mean, after a while it did-- it just ~

A. Probably. 2 didn't have a high priority, let's put it that way. ~ Q. What do you mean, "probably''? 3 Q. How did you first learn of Patrick's death? S A. I -I don't remember specifically, but 4 A. I think-- I think Maria told me about it. ~

that-- that's-- we would tell people, "Narconon is the 5 Q. Do you remember what she told you? I ~

rehab recovery, and we are their residential facility. 6 A. I mean, she basic-- if I recall correctly, And we --you know, and so you don't pay Narconon, you 7 she basically said that, you know, Pattick had died, pay us." 8 had-- had overdosed and died. And that she had-- I

Q. And was there ever any discussion about that 9 guess she said she'd gone to the hospital. To try to, with Narconon? "Hey, we've got to do it this way so 1 0 you know, help him, I guess. we'll be compliant with the regs"? 11 Q. Any other conversations -vvith Maria about

A. Mary was very clear that we were a separate 12 what -- what -- the circumstances arolll1d Patrick's company, and that we had to treat it as such. · 13 death?

Q. Did she say why? Why she wanted you to treat 14 A. She said that he had gone off with I guess two

I I I

it that way? 15 other people, I guess were ex-students, or were students ~

A Well, [mean, I guess the main thing is that 16 or something like that, and that he had taken heroin, if ~

we were a residential facility and not a treatment 1 7 I recall cmTectly, and then had started overdosing, and ~

program. 18 they didn't know what to do with him, and she said they ~ Q. At any point in time when you were heading up 19 had called her -- I think she said they had called her

the housing, did a surveyor from the Department of Human 2 0 to figure out what to do, and I don't know how he got to Resources come and talk to you about complaints that had 21 the hospital, but she went there to, you know, see if been received about Narconon running a housing unit? 2 2 she could help him.

A. Not to me. 2 3 Q. So she told her that the students - she told -Q. Okay. Did-- are you aware of anyone talking 2 4 you that the students had called her while they still

to either you or your employees? 2 5 had Patrick in the car, to try to figure out what to do

21 (Pages 78 to 81)


Page 82

1 withhim? 1

2 A. I think that's what she told me, yeah. 2

3 Q. Well, what did she say that she said? 3 4 A I-- well, I don't- I don't recall what she 4 5 told them. but, I mean, I know that he wended up -- 5

6 went - ended up going to the hospital. I don't -- I 6 7 don't know exactly what she told them. 7 8 Q. Did you ever - 8 9 A. I think she said that they called him-- that 9

1 0 they called her. Or they called somebody at housing; 10 1 1 anyways, they were trying to get l1elp, to see what -- 11

12 you know, "What do we do with him?" 12 13 Q. Any other conversations that you.had with 13

1 4 Maria about the circumstances surrounding Patrick's 14 15 death? 15

16 A I mean, she said that at -- at the hospital 16 1 7 she V\ras hoping that he would come to, you know, and I 1 7 18 guess he never dicl But... Anyways, that's about the 18 19 extent of what she said. 1 9 2 0 Q. Did you -- did you talk to any students or 2 0 2 1 monitors yourself to try to find out what happened? 2 1

2 2 A. No. I mean, I was already out of that. -- 2 2

2 3 Q. You were out of housing? 2 3 2 4 A -- Out of housing, so it was just, you know, 2 4 2 5 news that, ''Oh, you know, somebody you !mow has died," 2 5

Page 83

1 and it was just sad. 1 2 Q. Right. And-- and-- and, by the way, it's 2 3 referred to as "housing" at Narconon, right? 3 4 A. Uh-huh(affirmative). 4 5 Q. Okay. That's how people refer to the Delgado 5 6 property, is "housing"? 6 7 A Uh-huh (affirmative). 7 8 Well, the - I guess, yeah. Because-- 8 9 depending on, I guess, which housing they were referring 9

1 0 to at what time. 1 0 11 Q. Okay. 11 12 A. But, yeall. 1 2

13 Q. After Patrick's death, there were -- there 13 11 were several ladies who came from Narconon International 14 15 to --to look into the program. Do you recall that? 15 16 A. Not specifically. 16 1 7 Q. What do you mean, "not specifically"? 17 18 A. There would --there would be people that 18 19 would come by from Narconon International periodically, 19 2 0 to, you know, see how the program was being delivered 2 0 21 and that kind of thing. But I don't remember them 21 2 2 coming specifically for that particular reason, or at 2 2 2 3 least they didn't tell me that's that - that's what 2 3 2 4 they were there for. 2 4 2 5 Q. Okay. Well, what did they tell you they were 2 5

Page

there to do? A. That -I'm -- I'm not sure when it was or

if- in other words, they would come by periodically to check and just make sure everything was running right at the Narconon, or •• or that, you know, the standards were being met. But they didn't tell me, "Oh, we're examining to find out what happened with Patrick." So I don't know when or if they would have come by for that particular reason.

Q. Well, let's -- let's kind of drill down on

~ ~

i ~

that a little bit. Do you - j A. Okay. I Q. - remember having conversations with anyone ~

from Narconon International or from-· from anywhere I else, you know, that may have come in to investigate ~

this? Do you remember anybody sitting down with you and ~

saying, ''Hey, I want to talk to you about this"? ! A. Huh-uh (negative). 1.

Q. Barbara Dunn; do you know who that is? ~

A. Doesn't ring a bell. -~

Q. Did you have a conversation with Ms. Dunn ~

about Patrick's death? I A. Huh-uh (negative). Not that IrecaiJ. I !

mean, just like I said, I was already out of the -- out ~ of the loop, I guess, then. I mean, I -- I-- I wasn't ~

-~

Page 85 ~ ·• i

there, I didn't know what happened, I just heard it ~

secondhand. I Q. All right. Now, you said that there were i

other instances where people from Narconon International i ~ would come and do some sort of inspection? ~

A. Uh-huh (a:ffinnative). ~

Q. Tell me about that; what would they do, what ~ sort of stuff would they look at, and what was your I understanding about why they were there?

MS. WHITLOCK: Object to the form. THE W11NESS: 'It was-- I-· I assume it

was more of like a quality control, just to ~

see, you know, how things were goh1g, how the ~ students were doing. So they, you know, • would go to the course room, go to the sauna, I and just -- you know, just like, you know, ~ any corporation sends people to see how i things are going. ~

BY MR. HARRIS:

Q. Did they go to housing? A. I think I took -- they may have been by there

once or twice, just to see bow the housing looked like. ~ Q. Did they review any documents that you saw? ~

A I never gave them any of my documents. Q. You said they -- they would check on how the ~

22 (Pages 82 to 85)


Page 86 Page 88 ~ 9

1 students were doing? 1 A (Witness shakes head negatively.) I ~

2 A. Uh-huh (affinnative). 2 Q. That never happened? fi 3 Q. How did tl1ey go about doing that? 3 A I never got anything. i 4 A I mean, they would go to the course room -- 4 Q. And-- well, I- I said "memos," but was ~

~ 5 from what I observed, they would go to the course room 5 there any feedback from-- from Ms. Rieser or anybody l 6 and, you know, see how they were -- see how the students 6 else after any of these inspections about perhaps doing it

i 7 were doing, you know, probably talk to some of the 7 things differently? ~ 8 students, see how things were going. 8 A. Not in my area, let's put it that way. ~

~ 9. Q. Did they look at the students' files? 9 Q. Not in your area. And I'm asking you about ~

10 A I -- I never saw them do that, but I'm -- I 1 0 conversationS that you had with any of your coworkers; ~ ~

11 ~sume they would. Wel~ I don't know. 11 did you overhear any water cooler talk along that line? ; 12 MR. HYNES: Don't-- 12 A Not specifically, no. I 13 THE WITNESS: I don't know. 13 Q. What do you mean, "not specifically:? ~

i 14 MR. HYNES: Don't assume. 14 A I mean I don't remember them saying, "Oh, we I 1 5 TilE WITNESS: I don't know. 15 need to do this or we need to change that." 16 BY MR. HARRIS: 16 Q. You said -- I tlrink you were trying to I 17 Q. I'm asking you whether or not you -- you saw 17 remember for me if there was some-- somebody who did ~ ~ 18 them look at students' files, - 18 this on a regular basis. I know you described a guy ~

~ 19 A. Huh-uh (negative). 19 from Narconon East U.S.; anybody else that you saw more .@

~

20 Q. --that's all I'm asking. 20 than once? m ~

21 The -the people who came, how often-- well, 21 A. Uh-huh (affirmative). There was a-- a lady, ~ 22 let me ask you this. Do -- do you know who they were, 2 2 I guess -- let me think her name. I may be getting her ;

~ 23 what their names were? 23 confused with somebody else, but I think her name was j~

24 A. The one in particular that would ccme by was 24 Yvonne? Rogers? ~ . 25 from-- actually, it was more from Narconon East U.S. 25 Q. Yvonne Rogers? ~

~

Page 87 Page 89 i ~

1 But-- 1 A. I think: so. l ~

2 Q. Say that again? "East G West"? 2 (Discussion off the record.) I 3 A. East U.S. 3 BY MR. HARRIS: I 4 Q. Okay. 4 Q. l11ere's - there's a woman named Yetta who's ~

5 A Like they have -- 5 been identified in the discovery responses, and I don't 6 Q. Like regions? 6 want to dig it out; does that ring a bell? 7 A. Yeah. Yeah. 7 A. (Witness shakes head negatively.) . 8 Q. Got you. All right. Well, so somebody from 8 Q. Yvonne Rogers? I 9 Narconon East U.S. would come by, and you saw them come 9 A. I think so. ~

10 by more than one time? 1 0 Q. Okay. What did she look like?

I 11 A. Uh-buh (affirmative). 11 A. Tall, white lady. Medium, middle-aged. 12 Q. And -- do you remember what-- was it a male, 12 Young. 13 or a female? 13 I think that was her name. *

~ 14 A. There was a male that came by, I saw him there 14 Q. Do you know who Discovery Course, Limited is? I 15 a couple oftimes, and then a female that came by a 15 A. No. ~ 16 couple of times. 'JWo or three times. 16 Q. Do you know a guy named Darrell Hall? I 17 Q. And you said they were there, I think you -- 17 A. Yes.

• 1 8 one of your words was-- or, your words were "quality 18 Q. Who is Darrell Hall? ·~ 19 control"? 1 9 A. Darrell Hall was somebody that was working at

~ ~

20 A. I assume, yeah. 20 Narconon at the time that I was working, and, from what ~ 21 Q. Okay. Did-- did -- did -- did anything occur 21 I was told, he opened up a housing facility. ~

m 22 after they left, I mean, did you get any memos that 22 Q. And that's -- do you know anything about his i 23 said, "Narconon International," or Narconon whomever, 23 housing facility? i 24 "has been here to inspect, and we need to be doing the 24 A. (Witness shakes head negatively.) ~

I 25 following things"? 25 Q. Do you know whether that's the housing ~'Sa'•'~ ,o . ;;;:,;:..~~-:y;:;-: · .-.-~--<·.;:1' -s.:..ES ~~~.iW.J::'J~ "-~::. • .:!<,;;!>&."'iO'::;.i>';~--~ •. ·••.:::::i;'~$..~'l:&-"~;;?..i.~~~,~-*~~";:~~-.. ~':'~;:-~;\,"'~'-.;>%~~-->' ... <•-'~)_>;:~x~~-,:_.,,.,y,,t_:;:;~:>.$-';Si';~::;::i;i«YR~M~'-~;,····,,-·.--o-v..,.~~. ~ · bo!.~~~--~\;<··,-...•J.;>>:~' ~"'

23 (Pages 86 to 89)


Page 90 Page 92 ~

1 facility that Narconon is currently using? 1 mean, is.that just sort of they just-- they went to you ~

2 A. (Witness shakes head negatively.) 2 to complain about housing? That -that happened, did I • 3 (Discussion off the record.) 3 it not? ~ 4 BYMR. HARRIS: 4 A. I'm sure. 5 Q. You can't do that to her. 5 Q. And -- and what was your process, I mean, what

~ 6 A. I'm sorry. 6 did you do? What was your procedure if somebody " 7 Q. You need to audibly answer. 7 complained about problems they had with housing? I 8 A. Yeah. 8 A. When I was running housing, or aftenvards? ~

~ 9 Q. You do know who -- 9 Q. No, after - I'm-- I was talking about -- " ~

10 A. I mean-- 1 0 I'm -- I'm-- transition to the time where Maria's ffl

11 Q. Ho1d on, strike all-- strike all pending 11 running it. I 12 questions. 12 A. Oh. With a process? I would, you know, 1

i 13 MR. HYNES: He was saying "yeah" to 13 mention it to Maria. ~ 14 you-- 14 Q. Okay. Did you ev -- did you have a brother j

15 MR HARRIS: I know. 15 who worked as one of the security guards at housing? ~ ~

16 MR. HYNES: -- saying-- 16 A. No. ~ §

17 MR. HARRIS: So I withdraw the question. 17 Q. Did -- do you have any relative at all that I 18 THE WITNESS: I'm sorry. 18 worked as a -- as a security guard? ~ 1 9 BY :MR. HARRIS: 1 9 A. No. I 20 Q. My question is, do you know who Narconon is 20 Q. I think that's all I have for you; I 21 cu!Tently using for housing? 21 appreciate all your time. ~ 22 A. No. 22 A. Okay. I 2 3 Q. Okay. But you do know Mr. Hall? 23 MS. WHITLOCK: I don't have anything. ~ ,, 24 A. Yes. 24 THE WITNESS: I'm paid by thehour; you ~

~ 25 Q. And you think he's opened some kind of 25 can ask me more if you want to. m

Pa ge 91 Page 93 ; .

1 housing? 1 MR. HYNES: Any questions? i 2 A. That's what I was told. 2 MR. AMASON: Yeah; can we take -- can we ~ 3 Q. And do you think that housing is affiliated in 3 take a quick break? ~

~ 4 any way with Narconon? 4 MR. HYNES: Yeah, sure. Sure. ~

1 5 A Other than that it's an alternative for them 5 THE VIDEOGRAPHER: Going off the record I 6 to -- the students can go there. 6 at4:27.

~ 7 Q. After when Maria took over and - took over 7 (Recess at4:27, resumed at4:31.) • 8 Delgado Development and took over the housing component, 8 THE VIDEOGRAPHER.: We are back on the !i

il-i

9 what was yom involvement on a day-to-day basis in 9 record at 4 :31. 10 housing, if any? 1 0 EXAMINATION

I 11 A. I worked for Maria for a little bit. So I 11 BY l\1R. AMASON: 12 would monitor, and-- but that was for a very short 12 Q. Don, my name is Jeff Amason; we met maybe ~

1 3 time. 13 about an hour ago. ~

1 4 Q. And-- and some of the reports that we've-- 14 J\. Yeah. ~

I 1 5 that I think are probably in the stacks around here, I 15 Q. I just have a few quick follow-up questions 16 mean, some of those refer to students going to you when 16 for you based on some comments you made earlier. I 17 they had problems with housing. Did that -- did that 17 A. Okay. ~

~

18 happen from time to time? If a student was unhappy 18 Q. You mentioned a few minutes ago that you ~ ~

19 about something at housing, did they come complain to 19 received some training at Narconon from Dr. Robbins; was ~ 2 0 you about it? 20 that correct? ~ • 21 A. They would come complain to me about lunch. 21 A. Uh-huh (affinnative). ~

22 Q. Okay. I-- 22 Q. Do you remember if Robbins was the ftrst name 23 A. I mean, if they had an ear to listen, they 23 or last name of this person? 2 4 would come and talk. 24 A. Oh. First name. 25 Q. And I guess that's just what I'm asking. I 25 Q. Okay. Do you recall what this person looked

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24 (Pages 90 to 93 )


Page 94

1 like? 2 A I mean, she was a middle-age white lady from 3 Alabama. 4 Q. And you distinctly remember that she was --

1

2

3

5 she was a middle-aged Caucasian from Alabama? 4 6 A Yeah, I'm sorry, her name was Robin Muse. 5 7 Q. Okay. 6

ERRATA SHEET I, the undersigned, DON DELGADO, do

hereby certify that I have read the foregoing deposition and that, to the best of my knowledge, said deposition is true and ac...<rrate (with the exception of the following comctions listed below.)

Page

8 IviR. AMASON: I have no further 7 PAGE/LINE CORRECfiON (and reason for correction) 9 questions. 8 ___ _,/ ______________ _

10 THE WITNESS: Sorry about that. 9 I 11 MR. HARRIS: When-- anybody else? 10 --~---'/ _____ _ _______ _

1 2 MS. WHITLOCK: No. 11 -----'~-------------13 FURTIIEREXAMJNATION ~~ ------'1----------~---

------'1 ______________ _ 14 BYMR. HARRIS: 14 1

----'----- - ---------15 Q. When did you - how did you come to remember 15 1 ------'----------------- I 16 thatname? 16 ' ___ _,1________ _______ . 1 7 A Just when he was talking to me. 17 ___ _.:/_______ _____________ I 18 Q. Did you talk to him out in the hallway about 18 _ _ _ _,:/____ _ _ _______________ ~

1 9 it? 1 9 ___ _,/_______________ 1 20 A Huh-uh(negative). 2 0 ___ _.:! ___________ __ ~

21 Q. Okay. Itj'ust came to you when vou were J'ust 21 ~

22 ' 22 ~ talking about it just novl? Notary Public Signature ~

2 3 A (Witness nods head affirmatively.) < 2 4 Q. You said von were paid by the hour so you'd

22

34 Date______ I

J My Commission Expires: · 2 5 sit here awhile; it seems to me like you would be losing 2 5 i 1---------------------+----------------------I~

Page 95 Page 97 I ~

~ ~

I f ~ ; I ~

1 money sitting here. 1 C E R T IF I C ATE 2 A. I know. I'm - I'm - I was joking. 2 G E 0 R G I A: 3 Q. Okay. All right. ljustwas curious about 3 FULTON COUJ\TTY: 4 that. 4 I hereby certify that the foregoing 5 A. Sorry. 5 deposition was taken down, as stated in the

6 Q You're actually losing money, right? 6 caption, and the questions and the answers 7 · (Discussion off the record.) 7 thereto were reduced to printing under my

8 TI.IE WITNESS: Yes. 8 direction; that the preceding pages represent

9 a true and correct transcript, to the best 9 MR. HARRIS: That's all I have. Thanks. 1 0 of my ability, ofthe evidence given by said

10 MR. HYNES: Okay. 11 witness upon said hearing. And I further 11 THE VIDEOGRAPHER: Going off the video 12 certify that I am not of kin or counsel to I 11

23

record at 4:33. 13 the parties to the case; am not in the regular ~ (Deposition concluded at 4:33 p.m.) 14 employ of counsel for any of said patties; 1~

14 15 nor am I in anywise interested in the result I 15 16 of said case. i 16 1 7 This, the 4th day ofNovember, 2011. I 17 18 ~

19 a 18

20 I 19 ~

21 • 20 22 ~ 21 ~ Jo TomoffFischer, RMR ~ 22 23 CCRNo. B-924 1'

2 3 Notary CommissionExpiTes 8-25-2012 ~ 24 24 ~

:j 25 25 A

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25 (Pages 94 to 97}