10A28641 2 2012-02-17 DepositionOfNinaEdidin Ocr

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In The Matter Of:
Desmond, et al. v.
Narconon, et al.
Nina Edidin
February 17, 2012
Q&A Reporting Services, Inc.
Certified Court Reporters
2165 Fair haven Circle, NE
Atlanta, GA 30305
4 04.2 3 3. 3 3 00 * * JFischer@QAReporting. com
Original File edidin.txt
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Desmond, et al. v.
Narconon, et at.
IN THE STATE COURT OF DEKALB 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 FILE
vs. )
) NO. 10A2864l -2
NARCONON OF GEORGIA, INC., )
DELGADO DEVELOPMENT, INC. , )
SOVEREIGN PLACE, LLC, )
SOVEREIGN PLACE APARTMENT )
MANAGEMENT, INC., LISA )
CAROLINA ROBBINS, M.D., THE )
ROBBINS GROUP, INC., AND )
NARCONON INTERNATIONAL, )
Defendants. )
Video deposition of NINA EDIDIN,
taken on behalf of the Plaintiffs, pursuant
to the stipulations contained herein, before
Jo Tomoff Fischer, RMR, CCR No. B-924, at
1201 Peachtree Street, 400 Colony Square,
Suite 900, Atlanta, Georgia, on February 17,
2012, commencing at the hour of 10:05 a.m.
Q&A REPORTING SERVICES, INC.
Certified Court Reporters
2165 Fairhaven Circle, NE
Atlanta, GA 30305
404.233.3300 ** (Fax) 404.233.1530
Page 2
l APPEARANCES OF COUNSEL
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ON BEHALF OF THE PLAINTIFFS:
JEFFREY R. HARRIS, ESQ.
Harris Penn Lowry DelCampo, LLP
400 Colony Square, Suite 900
1201 Peachtree Street, NE
Atlanta, GA 30361
(404) 961-7650
ON BEHALF OF THE DEFENDANTS NARCONON OF GEORGIA
and NARCONON INTERNATIONAL:
BARBARA A. MARSCHALK, ESQ.
Drew, Eckl & Farnham, LLP
880 West Peachtree Street
P.O. Box 7600
Atlanta, GA 30357
(404) 885- 1400
ON BEHALF OF THE DEFENDANT DELGADO DEVELOPMENT:
CALVIN P. YAEGER, ESQ.
Downey & Cleveland, LLP
288 Washington Avenue
Marietta, GA 30060
(770) 422-3233
ON BBHALF OF THE DEFENDANTS LISA CAROLINA ROBBINS,
M.D. and THE ROBBINS GROUP, I NC.:
JEFFREY N. AMASON, ESQ.
Weinberg, Wheeler, Hudgins, Gunn & Dial, LLC
Suite 2400
3344 Peachtree Road
Atlanta, GA 30326
(404) 876-2700
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ALSO PRESENT:
Nina Edidin
February 17, 2012
Page3
GABRIELLE ESQUIVEL, Legal Technology
Services, 770 - 554-1633
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INDEX TO EXAMINATION
3 By Mr. Harris. .6
. 40 4 By Ms. Marschalk
5 By Mr. Harris. . 82
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INDEX TO EXHIBITS
PLAINTIFFS '
EXHIBIT DESCRIPTION PAGE
1 Narconon License Application to
ORS w/ Attachments 13
2 ORS Report of Survey of Narconon,
w/ Narconon Response 28
3 12- 7 - 06 Memo to M. Cornett from
N. Edidin re Narconon Settlement
Conference 29
4 10-5- 06 Letter to C. Roberts and
M. Rieser from DHR re Denial of
License 33
5 March 2007 Settlement Agreement
between DHR and Narconon 34
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Survey Results - January 2 009
Complaint re Housing wl Initial
Comment Letter
Internal Narconon Memo I
Urgent Directive
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Desmond, et al. v.
Narconon, et al.
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(THE FOLLOWING TRANSCRIPT CONTAINS QUOTED
MATERIAL; SUCH MATERIAL IS REPRODUCED AS
READ OR SPOKEN. )
(IN THE FOLLOWING TRANSCRIPT, A DASH [ -- ]
IS USED TO INDICATE AN UNINTENTIONAL OR
PURPOSEFUL INTERRUPTION OF A SENTENCE;
AN ELLIPSIS [ ... ] IS USED TO INDICATE
HALTING SPEECH OR AN UNFINISHED
SENTENCE IN DIALOGUE, OR AN OMISSION
OF WORD[S] WHEN READING WRITTEN
MATERIAL.)
{Thereupon, the court reporter disclosed that she was
there on behalf of Q & A Reporting Services, Inc.
In compliance with Article lO.B of the Rules and
Regulations of the Board of Court Reporting of the
Judicial Council of Georgia and O.C. G.A. 15-14-37(a)
and {b), the court reporter discloses that she was
retained by Jeffrey R. Harris, Esq., to take down
the Q & A Reporting Services, Inc.
will charge the attorneys the usual and customary
rate for the transcript, and will be paid by the
attorneys upon their receipt of the transcript.)
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THE VlDEOGRAPHER: We're now on video
record on February 17th, 2012; the time is
approximately 10:03 a.m.
MR. HARRIS: All right. This will be
the deposition of Nina Edidin, taken for all
purposes allowed by the Georgia Civil
Practice Act. Objections are reserved and
made in accordance with the court's standing
order regarding depositions and in accordance
with the Civil Practice Act.
If you would please, Jo, swear the
12 witness.
13 NINA EDIDIN,
14 having been first duly sworn, was examined and
15 testified as follows:
16 EXAMINATION
11 BY MR. HARRIS:
1B Q. Good morning, Ms. Edidin.
19 A. Good morning.
2 o Q. Am I pronouncing your name correctly, first --
21 A. You--
22 Q. -- of all?
23 A. You are.
2 4 Q. Okay, good. If you would tell the jury who
25 you are and what you do for a living.
Nina Edidin
February 17, 2012
Page 7
1 A. 1 am Nina Edidin, and I am an attorney; at
2 present I work for Legal Aid in Yuma, Arizona.
3 Q. And when did you graduate from law school?
4 A. 1996.
5 Q. And tell-- tell the jury a little bit about
6 your work history, what you did before you went out to
7 Yuma.
8 A. I started out as an assistant DA, doing child
9 support, and then went to the State of Georgia as the
10 legal services officer in child support. Sort of
11 transitioned over to the attorney general's office.
12 Then went to work for one of the clients, which was
13 Department of Juvenile Justice. And then, after that,
14 went to work for the Office of Regulatory Services,
15 which at that time was part of the Department of Human
16 Resources. And I was the manager of the legal unit for
17 the Office of Regulatory Services. And officially was
18 considered a legal services officer.
19 Q. Okay. And when did you grad- when did you
20 graduate from law school?
21 A. 1996.
22 Q. And what was your -- where did you go to law
23 school?
24 A. Georgia State University.
25 Q. And where did you do your undergraduate work?
Page8
1 A. University of Illinois.
2 Q. Let's back up and talk a little bit about the
3 AG's office. What did you do, specifically, at the
4 attorney general's office?
5 A. I represented the Office of Child Support
6 Enforcement, I represented the Department of Juvenile
7 Justice, I did some work with Community Health, and
8 so -- for child support 1 did mostly appellate work,
9 because they were -- there were special assistants that
10 would do the actual child support enforcement trials.
11 But with the other -- with the other clients, I
12 basically represented them in court or represented them
13 with-- in settlement agreements, with various -- in
14 various lawsuits or various instances.
15 Q. All right. And you-- and you spoke about a
16 couple of different governmental agencies that the jury
17 may not be familiar with, but at some point you -- you
18 began to work at the Department of Human Resources? Is
19 tl1at --
20 A. Yes.
21 Q. That's what it was called at the time?
22 A. Yes.
23 Q. And now it's called what?
24 A. The Department of Human Services.
25 Q. Okay. And it-- and has the-- has the job of
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Desmond, et al. v.
Narconon, et al.
Nina Edidin
February 17, 2012
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those two divisions, has it changed? Do they regulate
different areas now?
A. Yes; I believe the Office of Regulatory
Services, and most of the components, have gone over to
the Department of Conununity Health.
Q. All right. But, nevertheless, at the time
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license. Upon application, you would go -- the -- the
Office of Regulatory Services would send a surveyor out
to do an inspection, to see if it meets all of the
requirements oflicensure. Ordinarily, licenses are
originally given with a dead-- with a date that they
expire. And it's usually within two years. And then
7 that you were at the Department of Human Resources, the 7 within those two years they're recertified. They have
8 Office of Regulatory Services was under DHR? 8 to reapply, they have to have a surveyor come out. At
9 A. Yes. 9 some point you can -- you can have what's considered
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Q. And what does the Office of Regulatory 10 more of a permanent license, but they're still subject
Services do? 11 to -- to surveys every-- approximately every two years.
A. It regulates everything from child caring 12 Q. All right. If you-- and if someone wants to
institutions, basically group homes, all the way through 13 run, or if someone wanted to tun, back in 2005 to 2008,
hospitals. There are various departments within the 14 the time period that you were there, if they wanted to
Office of Regulatory Services. Health services; nursing 15 run a drug and alcohol rehabilitation program, were they
homes, which they regulated and did surveys for the 16 required, pursuant to Georgia law, to have a license to
federal govenm1ent; group homes, things like that. Drug 17 do that?
treatment programs. 18 A. Yes, they were.
Q. Okay. And so when did you statt at the Office 19 Q. Okay. And what was the process in order to
ofRegulatory Services? 20 obtain such a license?
A. November of2005. 21 A. You had to basically prove that you complied
Q. And when did you leave? 22 with all of the regulations. All of the requirements of
A. June of 2008. 23 that program. You would present yourself to the
24 Q. All right. I want to talk about that time 24 surveyor, who would do an inspection, inspect the --
25 period where you were at ORS. You said that you were a 25 inspect the records, inspect all of the licenses and
Page 10 Page 12
1 legal services officer? 1 certifications of your employees.
2 A. Yes. 2 Q. Is it a crime under Georgia law to operate a
3 Q. Tell the jury what that is; what-- what does 3 drug and alcohol rehabilitation facility without a
4 a legal services officer do? 4 license?
5 A. You're very similar to an in-house attorney. 5 A. Yes, it is. It's actually a misdemeanor.
6 You counsel, you work on -- I was on the management 6 Q. All right. And similarly, are there different
7 team, on the legislative team. But one of the things 7 categories of licenses that are available for drug and
B that you don't do is represent the agency in a comt of 8 alcohol facilities?
9 record. You can represent them in administrative 9 A. Yes; there is an in-house -- you can -- you
10 hearings, but not in a court of record. That would go 10 can have -- you can have a-- just a education program,
11 to the attorney general's office. So there's no 11 you can have an ambulatory detoxification program, or
12 attorney-client privilege. 12 you can have a residential program.
13 Q. Okay. And you-- and you said that the -- 13 Q. All right. We'll talk a little bit more about
14 that the Office of Regulatory Services regulated a bunch 14 the -- the -- the differences in just a second. Are you
15 of different things, but -- 15 familiar with a organization called Narconon of Georgia?
16 A. Uh-huh (affirmative). 16 A. Yes, I am.
17 Q. -- was one of the things that was regulated 17 Q. Now, during your time period at ORS, did you
18 drug and alcohol rehabilitation programs? 18 at any time run into regulatory issues with Narconon of
19 A. Yes. 19 Georgia?
20 Q. And explain how that operates, and how -- 20 A. Yes, we did.
21 explain to the jury the regulatory process in general, 21 MS. MARSCHALK: Object to the fonn.
22 just-- just as an overview, if you would. 22 BY MR. HARRIS:
23 A. Okay. Pursuant to statute, in order to 23 Q. Okay. And you-- you in-- you investigated
24 regu -- in order to provide a service that requires a 24 Narconon of Georgia in connection with your job at ORS?
25 license, you would have to apply to the State for that 25 A. I didn't, the surveyors did.
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Desmond, et aJ. v.
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1 Q. All right. Let's back up and talk about
2 Narconon of Georgia for just a second.
3 (Thereupon, marked for identification
4 purposes, Plaintiffs' Exhibit No. 1.)
5 BY MR. HARRIS:
6 Q. I'm going to hand you what I've marked as
7 Plaintiffs' Exhibit 1. And the first page of
8 Plaintiffs' Exhibit 1 indicates that-- well, first of
9 all, what -- what is -- what is this document that I've
10 just handed you, the first one?
11 A. This is the application to provide a
12 licensed -- operate a licensed drug abuse treatment and
13 education program.
14 Q. Okay. And you'll see that the application,
15 the first page that I've handed you there, is for April
16 of 2002; is that correct?
17 A. Yes, it is.
18 Q. And then towards the end here, I've got an
19 application back in 2007; do you see that?
20 A. Yes.
21 Q. Okay. And I-- and I just want to run through
22 these, and we'll talk in detail about some of them, but
23 the application, or, excuse me, the license that
24 Narconon of Georgia had starting in 2002 --well, first
25 of all, how do we know that this is the first license
Page 14
1 that Narconon of Georgia received by DHR? Can we tell
2 that from this document?
3 A. Yes, you can. Under "Type of application," it
4 says "Initial."
5 Q. All right. And so does that mean that this
6 was the first drug and alcohol rehabilitation license,
7 at least for this facility as it's named here?
8 A. Yes.
9 Q. All right. And -- and it -- and it describes
10 on the -- on the next -- on the third page there's a
11 license; do you see that?
12 A. Yes, I do.
13 Q. Okay. And it says "Drug abuse treatment and
14 education program," right?
15 A. Yes.
16 Q. All right. SoNar-- Narconon was licensed
17 back in 2002 to mn a drug abuse treatment and education
18 program?
19 A. That's correct.
20 Q. How long do the licenses generally last?
21 A. This license lasted two years. Actually, a
22 little less than two years; looks like it's more like a
23 year and a half.
24 Q. Now, this license that the State gave to
25 Narconon, the one that we're talking about between 2002
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Nina Edidin
February 17, 2012
Page 15
and 2004, did it allow Narconon to operate any kind of
residential drug and alcohol treatment facility?
A. No, it did not.
Q. Did it allow Narconon to have control over any
kind of residential component?
A. No, it did not.
Q. Now let's go to the next li cense. Which I
believe is dated February of2004?
A. Yes.
Q. Okay. Again, what is this license for?
A. This license is again for an outpatient drug
treatment program.
Q. Same question with respect to this license,
the -- the 2004 license; did it allow Narconon to
operate any kind of residential drug treatment facility?
A. No, it did not.
Q. Did it allow Narconon to exercise control over
a residential component of a drug treatment facility?
A. No, it did not.
Q. All right. The third license, which is
dated -- I believe it's -- well, first of all, there's
one here for Febmruy of'04, and then I see another one
ofMay the 20th of'04?
A. Uh-huh (affirmative).
Q. I was confused by that. Do you -- do you know
Page 16
why there would have been two granted in the same year?
A. I don't know specifically unless I can look at
the survey and --
Q. Sure. I mean, you -- if--
A. But I believe --
Q. -- you can answer the question.
A. Probably it had to do with some deficiencies,
and so the li --
MS. MARSCHALK: 1 can clear it up. It's
different suite numbers. They moved.
MR. HARRIS: Oh, they moved? Okay. And
this is --
MS. MARSCHALK: If you look, it's
different suite numbers.
BY MR. HARRIS:
Q. And--
A. It wouldn't--
Q. -- I think that's actually on one of the --
A. Okay.
Q. -- applications, where they changed their
address, so they issue them another license?
A. It-- it wouldn't be that, 'cause if they
continued to operate, they bad to be under some
licensure or in the process of renewing the license.
So it wouldn't have to do with just the change
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Desmond, et at. v.
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1 of address, it would have to do with something that was
2 going on, they would have... 'Cause they would have
3 done the ...
4 Q. Well, I think what Ms. Marschalk's talking
5 about here, if you tum back on this other page, after
6 February of'04?
7 A. Uh-huh (affirmative).
8 Q. You'll see an application, and it just says
9 "Change of address"?
10 A. Okay.
11 Q. But it's not important. I mean, it's --
12 A. Okay.
13 Q. TI1is -- this was before you got there, anyway,
14 right?
15 A. Yes, it was.
16 Q. Okay. But the drug and alcohol-- at any
17 rate, there is a drug abuse and treatment license given
18 to Narconon, and they're not allowed to operate a
19 residential component?
21 Q. Nor are they allowed to control one?
22 A. No. They--
23 Q. Okay.
24 A. -- were not allowed.
25 Q. All right. Now, moving through this packet,
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1 you'll see an application for September of '06, I
2 believe?
3 A. Yes.
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Q. Now, I want to pause on this one for just a
second. The two licenses that we've talked about,
the -- the -- the '02 and the '04 license, those are for
dmg abuse and treatment programs?
A. Yes.
9 Q. Was Narconon required to have a medical
10 director to operate a dmg abuse treatment program
11 defmed by the two licenses we've been talking about?
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A. No; not at that time.
Q. All right. Look at the '05; there's a
September 23rd, '05 license.
A. '05, or '06?
Q. Flip through there; you'll see a pennit
effective September 23rd, '05.
A. Yes.
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Nina Edidin
February 17, 2012
Page 19
regulations, is there -- is there a -- is there a
prohibition against a licensed facility controlling a
subsidiary facility that offers residential services?
MS. MARSCHALK: Object to form.
THE WITNESS: There's no prohibition as
long as they're li censed to do so.
BY MR. HARRIS:
Q. And--
A. If they're not, then they cannot control --
exercise control over a residential component or another
component.
Q. Okay. Without -- without that component being
licensed?
A. Yes.
Q. All right. Now, let's turn to the
January 24th, 2007 application.
A. (Witness complies with request of counsel.)
Q. Which is I think the last one--
A. Yes.
Q. --in your packet. Now, this says that it's a
renewal for the outpatient r ehabilitation license?
A. Yes.
Q. And that-- those are the licenses that we've
been talking about, --
A. Yes.
Page 20
1 Q. --correct? All right. And then it's an
2 initial for an ambulatory detoxification?
3 A. That's right.
4 Q. All right. What is the difference between an
5 ambulatory detoxification faci lity and a outpatient drug
6 and alcohol education facility?
7 A. Outpatient dmg and alcohol education fa --
8 program is basically an educational program, a
9 counseling program; there's no either medical or any
10 kind of treatment involved in it. When you get into
11 ambulatory detoxification, you're talking about some
12 component where they're under some -- some form of
13 treatment, and there's a requirement for a medical
14 director at that time.
15 Q. And did Narconon at that point in time, when
16 it applied in January of2007, did it indicate in its
17 application to the State of Georgia for a license for
18 ambulatory detoxification that it had a medical 18
19 Q. Okay. What does this license allow Narconon 19 director?
20 to do? 20 A. Yes, they did.
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A. An outpatient dmg treatment center. 21
Q. Same question; can they operate a residential 22
Q. Who did it indicate the medical director was?
A. Dr. Lisa Robbins.
component or control a residential component?
A. No, they cannot.
Q. And let's talk about that briefly. Under the
23 Q. Now, the medical director-- are the duties of
24 the medical director spelled out or called out in any
2 5 way under the regulations?
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Desmond, eta!. v.
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Page 21
1 A. Yes, they are. They're -- the medical
2 director is responsible for all medical-- any kind of
3 treatment, any kind of-- any kind of program, any kind
4 of drugs, anything that they're given; they're
5 ultimately responsible for the entire program.
6 Q. Okay.
7 A. And there's a requirement they also be on call
8 for 24 hours a day.
9 Q. Now, was this license issued to Narconon on
10 the basis of representations that are made in the
11 application?
12 A. Yes.
13 Q. Okay. Does the State rely on the license
14 applic -- appli -- the person who applies for the
15 license, does the State rely on that person to be
16 truthful and accurate in describing the facilities?
17 A. Yes.
18 Q. And does the State rely on the people applying
19 for the license to identify the individuals who will
20 comply with the statutory requirements?
21 A. Yes.
22 Q. Now, let's back up. All ofthe licenses that
23 you and I have been talking about, do all of those
24 licenses require that Narconon have a clinical director?
25 A. Yes, I believe that they do.
Page22
1 Q. And if-- you-- you've got a copy of the
2 regulations there --
3 A. Yes.
4 Q. -- in front of you; if you need to consult
5 them, feel free to do it, but...
6 A. I may need to.
7 I am blanking on whether or not they must
8 provide a clinical director. But I would assume they
9 would have to have some smi of requirement --
10 Q. Well, at any -- at any rate, --
11 A. --that--
12 Q. -- the applications that you have in front of
13 you there, all ofthose identify a clinical director, --
14 A. Yes.
15 Q. -- COlTect?
16 A. Yes.
17 Q. All right. Now, let's talk about the
18 regulations. If you'll pull up 290-4-2 subsection 05,
19 it says "Licenses"?
20 A. Yes.
21 Q. All right. You have that in front of you?
22 A. Yes, I do.
23 Q. Okay. And this is the regulation that-- that
24 requires the licenses that you and I have been talking
25 about, is it not?
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Nina Edidin
February 17, 2012
Page 23
A. Yes, it does.
Q. As part of your duties and responsibilities as
the legal services officer at ORS between 2005 and 2008,
were you responsible for being familiar with the
regulatory framework?
A. Yes, I was.
Q. And were you responsible for handling appeals
related to these regulations?
A. Yes, I was.
Q. Now, I realize it's been a couple of years
since you were digging into these, but I want to talk a
little bit about a few of the regulations.
Subsection 5 down at the end of that; do you
see that?
A. Yes.
Q. It says, "Organizations or persons that
provide supportive services, i.e. residence,
transpmiation and et cetera, to dmg dependent persons
but do not offer or purpoti to offer 'Drug Abuse
Treatment and Education Programs.' Or support services
under the direct control oflicensed programs must be
part of a licensed program"; do you see that?
A. Yes, I do.
Q. All right. What-- what does that mean?
A. It means that if you have control over any
Page 24
other supportive services, they either have to be
licensed or you have to be licensed to operate that kind
of service.
Q. Okay.
A. So they either have to be independently
licensed, or they have to be under your license.
MS. MARSCHALK: I'm sony Did-- we're
talking about subsection E, par -- number 5?
THE WITNESS: Yes.
MS. MARSCHALK: Doesn't it say that
these -- that those are excluded from these
rules?
MR. HARRIS: No; it says --well, I
mean, you can cross-examine her if you want
to, but the --
MS. MARSCHALK: Okay.
MR. HARRIS: You know, but that-- it
says--
MS. MARSCHALK: I will.
MR. HARRIS: --you have to have a
license if you control them. But, I mean,
that's what --
MS. MARSCHALK: No, I--
MR. HARRIS: Well, you can ar --I mean,
do what you want --
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Desmond, et al. v.
Narconon, et al.
Page 25
1 MS. MARSCHALK: I--
2 MR. HARRIS:-- to do--
3 MS. MARSCHALK: I will.
4 MR. HARRIS: -- on your cross.
5 BY MR. HARRIS:
6 Q. Do you understand --
7 A. 1 do. 1 do. And I understand your question,
8 and I have a --
9 Q. All right.
10 A. -- a response to it.
11 Q. Okay. Well, explain it to the jury, if you
12 would.
13 A. Okay. What they're saying is, if it's not
14 under the direct control, and they don't purport to
15 offer any kind of these services, then it is excluded;
16 however, if they are-- the last sentence says,
17 " ... under the direct control ofliccnsed programs must
18 be part of the licensed program."
19 So it's under the exclusions; however, that
20 last sentence basically is saying that if you're under
21 the control and you purport to offer some sort of
22 service that needs to be licensed, you have to be
23 licensed.
24 Q. Okay. Now, next page, 290-4-2-.06 --I'm
25 sorry, -07; it says "Applications"?
Page 26
1 A. Yes.
2 Q. Subsection 2, talking about "False or
3 Misleading Information"?
4 A. Yes.
5 Q. "An application for a license must be
6 truthfully and fully completed. In the event that the
7 department has reason to believe that an application has
6 not been completed truthfully, the department may
9 require additional verification of the facts alleged.
10 The department may refuse to issue a license where false
11 statements have been made in connection with the
12 application or any other documents required by the
13 department." Do you see that?
14 A. Yes, I do.
15 Q. All right. What does that mean?
16 A. It means that if we-- if the department were
17 to find out that something was not truthful, they can
16 revoke any license that had been issued. It also
19 assumes -- in order to be compliant with the
20 regulations -- you must be compliant with the
21 regulations, which say you must be truthful. If you're
22 not compliant, then it's also a crime.
23 Q. Okay. Now, during your time period at ORS,
24 were you involved in any appeals related to Narconon
25 licenses?
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Yes, I was.
Nina Edidin
February 17, 2012
Page 27
And tell us how you came to be involved and
what you recall about that.
A. I believe that because of their sur --
pursuant to their surveys, and because it was found that
there were -- was some detoxification action going on,
they -- their license -- they had reapplied and their
license was not afforded. In other words, they were
told that they were not going to allow them to be a
licensed facility.
Q. Now, do--
A. And it had been denied.
Q. -- do you recall how that first came up?
A. I believe, and I'm -- I'm -- subject to my
memory, they found out that they were operating a sauna
program, a detoxification sauna program. And they were
not licensed to do so.
Q. How -- and j ust kind of as a -- in a general
sense, when a surveyor goes out to a facility, and if
the surveyor discovers something that the facility's
doing that they're not licensed for, what is the
procedure for addressing that? Just kind of walk us
through that, if you would.
A. They would go out, they would -- if-- if
they're operating without a license--in other words,
Page 28
they haven't applied for the license before they began
operating--then they would-- they would be found to
have deficiencies. They would either have a -- some
sort of a civil penalty, which would be either a denial
of a license or revocation of a license, or a monetary
fine. And I believe in thi s case they were told to
cease and desist operations.
Q. Is there something called a plan of
correction?
A. Yes; but they're not always afforded the plan
of correction. If they were, it might be to facilitate
an application for the license.
Q. Okay.
(Thereupon, marked for identification
purposes, Plaintiffs' Exhibit No. 2.)
BY MR. HARRIS:
Q. Let me show you what I've marked as
Plaintiffs' Exhibit No. 2.
A. Thank you.
MS. MARSCHALK: Thank you.
BY MR. HARRIS:
Q. Ask you if you recognize that document?
A. Yes, I do.
Q. And what is it?
A. This is a copy of the survey with their
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Desmond, ct al. v.
Narconon, et al.
Page 29
1 response, which is also called a plan of correction.
2 Q. Uh-huh (affirmative).
3 A. It may not be accepted as a plan of
4 correction, but they have the -- the ability to respond
5 to whatever the survey said.
6 So this is something that was not necessarily
7 accepted, it was just their response.
10 BY MR. HARRIS:
11 Q. All right. I'm going to band you what I've
12 marked as Plaintiffs' Exhibit 3.
13 A. Okay.
14 MS. MARSCHALK: Tell me what it is,
15 Jeff; I can --
16 MR. HARRIS: It's the--
17 MS. MARSCHALK: -- probably fmd it.
18 MR. HARRIS: It's her memo. Do you have
19 that?
20 MS. MARSCHALK: I don't have that.
21 MR. HARRIS: It's from the DHR file.
22 MS. MARSCHALK: We can have somebody
23 make a copy of it at-- at the break.
24 MR. HARRIS: Okay.
25 BY MR. HARRIS:
Page 30
1 Q. All right. I've handed you Plaintiffs'
2 Exhibit 3, I believe?
3 A. Yes.
4 Q. Tell us what that is.
5 A. This was a memo that I wrote to Marion
6 Cornett, who was the assistant director of legal
7 services, about some of the concerns that I had about
8 Narconon.
9 Q. All right. And-- and if you would, walk the
10 jury through the memo and tell us what-- what concems
11 you had and how the -- how the State was going to
12 address those concerns.
13 A. Okay. Told them what it was licensed as, and
14 what--
15 Q. And--
1 6 A. Which was a treatment and education program,
17 which did not afford a detoxification program. I
18 said ...
19 Q. And--
20 A. Said that--
21 Q. --and who is Marion Cornett, first of all?
22 A. Marion Comett was the deputy or assistant
23 director oflegal services. He was someone who had been
24 with the agency in some form for many, many years, and
25 was someone - I believe -- I don't know if the director
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Nina Edidin
February 17, 2012
Page 31
was present at the time; she might have been on
maternity leave. So I would have gone to Marion for
both advice and rec -- and to talk things over with him.
Q. Okay. And so you --you were telling Marion
some of the issues that had come up with Narconon?
A. Yes.
Q. And then you were proposing a resolution for
those issues?
A. Let me read through this and --
Q. Sure,--
A. -- refresh my --
Q. -- take your time.
A. --memory.
MS. MARSCHALK: Jeff, can I look at it
real quick?
MR. HARRJS: Yeah, sure.
MS. MARSCHALK: Thanks.
THE WITNESS: I apologize, it's not that
well written. It's probably something that
I...
I'm saying that they weren't licensed
for a detoxification program, that originally
they said that they had recommended it and
recommended them to another program, but that
wasn't true, they were in control. That they
Page 32
had plan of correction that was approved, but
they weren't meeting the requirements of the
plan of correction. That -- if I had said
something about a medical issue, which was
that they were spending so much time in a
sauna and taking 100 times the RDA of certain
vitamins, it was -- I was getting that
information from the medical people that I
worked with. And there was no ongoing
medical oversight. Non-medical personnel
checked the vital signs. It was -- the
participants would take a vitamin regimen
that was recommended by a non-medical person.
That our main concem was medical oversight.
And that they could uti-- they could
alleviate the -- that concern by having an
M.D. oversee the process.
BY MR. HARRIS:
Q. Let's just back up and do it this way for a
second.
A. Yeah.
Q. Okay. In 2006, DHR investigates Narconon for
certain things?
A. Yes.
Q. What is your recollection of the problems or
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Page 33
issues that came up in 2006 related to Narconon?
A. When they did the inspection, they found that
there was a detoxification program going on for which
they were not licensed.
Q. And -- and what detoxification program was
that?
A.
Q.
It was their sauna and a vitamin program.
And what did the State do when it determined
that they were running this sauna program?
A. They denied their license.
BY MR. HARRIS:
1
Nina Edidin
February 17, 2012
Page 35
Q. All right. Tell us about the settlement
2 agreement; what-- what was Narconon agreeing to do, and
3 how did it come about?
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A. Came agout -- about through lengthy
negotiations in which various people within the office
were involved. It -- they agreed to provide oversight
for Pur-0-Cleanse, which was a separate entity that was
created; they agreed to have a medical director who was
also available 24 hours a day. They agreed to ensure
that Pur-0-Cleanse, which was supposed to be a separate
entity, met all of the requirements, and they -- they
were responsible for everything that Pur-0-Cleanse did.
That they would employ a registered nurse to do -- and
have under that registered nurse an LPN to do all of
the-- they would check blood pressure, and make certain
that the people that were in the sauna for those hours
and taking those vitamins were okay. Physically. They
would check their vitals and make sure that they weren't
dehydrated, all the different things that can happen.
Especially through-- I think there was a concern about
the hundred times RDA.
Exhibit No 4, then, and ask you if you know what that 15
~ - 16
A. Yes, I do. 17
Q. What is it? 18
A. This is the denial oflicense letter that was 19
2 o sent to Narconon in-- in 2006. And they were told that 20
21 if they wanted to appeal it, they would need to contact 21
22 me within ten days. 22 Q. Okay. Anything--
23 Q. Did they do that?
A. Yes, they did. 24
25 Q. All right. And what happened as a result of
Page 34
1 that appeal?
2 A. As a result of the appeal, there -- we
3 ultimately entered into a settlement agreement.
5 purposes, Plaintiffs' Exhibit No 5.)
6 BY MR. HARRIS:
1 Q. All right. So the license was --was
8 denied,--
9 A. Yes.
10 Q. --and then Narconon appealed that, and then
11 you began to negotiate with Narconon and its counsel?
12 A. Yes.
13 Q. And ultimately arrived at a settlement
14 agreement?
15 A. Yes, I did.
16 Q. All right. And I'm going to hand you a copy
11 of Plaintiffs' Exhibit 5, which is the settlement
18 agreement.
19 MR. HARRIS: Have you got a copy?
20 MS. MARSCHALK: I have that one.
21 MR. HARRIS: Actually, I have a copy of
22 that.
23 MS. MARSCHALK: Okay. Then I'll take
24 it.
25 BY MR. HARRIS:
23 A. So--
24 Q. --else that they agreed that they would do
25 as ...
Page 36
1 A. Again, to have a medical director.
2 Docwnentation, that they would keep the records
3 properly. That they would provide correct information
4 about what some of the side effects of the vitamins
5 were. I think at one point they were just signing a
6 waiver saying that-- that they would re --they would
1 release an-- Narconon of any liability for any result
8 from taking such high dosages of vitamins. But they had
9 to be informed ofwhat some of the side effects were.
10 Q. All right. And was the license that was
11 issued to Narconon in 2007, was it contingent upon
12 Narconon's compliance with the terms and conditions of
13 the settlement agreement?
14 A. Yes. And that-- one ofthe terms was that
15 they -- that they maintain compliance with the rules and
16 regulations.
17 Q. Okay. And ultimately they were in fact issued
18 a license, were they not?
19 A. Yes, they were.
20 Q. And that is back at Plaintiffs' Exhibit 1 that
21 you and I talked about. A license was issued to
22 Narconon in 2007 contingent upon compliance with the
2 3 settlement agreement?
24 A. Yes.
25 Q. And from the perspective of the State of
(9) Pages 33 - 36
Desmond, et al. v.
Narconon, et al.
Nina Edidin
February 17, 2012
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Page 37
Georgia, Narconon's ability to operate legally at that
point in time was contingent upon that license itself?
A. Yes.
Q. Now, at any point in time-- we've talked
about the sauna issue; at any point in time did DHR have
a belief or have suspicions that Narconon might be
operating a residential facility?
A. We did have suspicion that they were.
Q. Okay. And tell the jury about that; what did
you sus --what did you have suspicions that they might
be doing, and what did the State do to try to look into
that issue?
A. Well, understand, first of all, that we're not
investigators. The -- there are medical people that go
Page 39
1 program, or just tell them they can't -- they don't
2 necessarily have to refer as much as tell them they
3 cannot provide that service for them.
4 Q. And the residential services or the
5 residential treatment facility; give -- give us an
6 overview of what kind of services a residential facility
7 can offer.
8 A. Well, a residential facility has to provide
9 ongoing, 24-hour oversight of the individual. I mean,
10 they're in there, the reason they're there and staying
11 there is so someone can provide services and watch over
12 them 24 hours a day.
13 Q. Now, I want you to assume for purposes of my
14 question thatNarconon of Georgia represented to drug
15 court personnel in Florida that Narconon could provide
16 residential services to Patrick Desmond. Would that
out and do surveys. But we were -- we bad the
understanding and we looked -- even on the web site they
talked about residential programs. But there was no way 17
that we could prove that there was a residential program 18
that was fully under the control of the State. We 19
didn't have subpoena powers at that point, and we relied 2 o
on their truthfulness in their application. 21
have been allowed under Georgia law? Would -- does
Nar --does Narconon have the authority under Georgia
law in 2007 to hold themselves out as being able to
offer residential treatment --
MS. MARSCHALK: Ob --
BY MR. HARRIS: Q. Would-- would Narconon have been able to--
after 2007 -- in the time period that you were there
22
23 Q. -- facilities?
24 between 2007 and 2008, would Narconon have been able to 24
legally hold themselves out as offering residential 25 25
THE WITNESS: No. No, they cannot hold
Page 38 Page40
1 treatment facilities? 1 themselves out to offer a residential -- a
2 A. No; that would a violation of the reg -- of 2 residential program. 'Cause they were not
3 the regs. And they would be superseding -- they 3 licensed for that.
4 would -- they would be providing a service for which 4 BY MR. HARRIS:
5 they were not licensed. 5 Q. And would it have been illegal to operate an
6 Q. And-- 6 unlicensed residential facility?
7 A. And, again, that would be a crime. 7 A. Yes, it would.
8 Q. And, by the way, under the regulations, if you 8 Q. That's all I have. Thank you.
9 look at subsection .13, "Client Referral, Intake, 9 MS. MARSCHALK: You done?
10 Assessment and Admission"? 10 MR. HARRIS: Yeah.
11 A. Yes. One moment. Yes. 11 MS. MARSCHALK: Okay.
12 Q. Does the regulations place the responsibility 12 EXAMINATION
13 on the drug and alcohol rehabilitation facility to 13 BY MS. MARSCHALK:
14 itself determine whether or not it can meet the 14 Q. Ms.--
15 patient's needs? 15 A. Call me Nina.
16 A. Yes. 16 Q. Ms. Nina.
17 Q. Explain that to the jury; what does that mean? 17 A. Just Nina.
18 A. Well, they're -- they're under obligation to 18 Q. I'm sorry. My name is Barbara Marschall<-; I
19 assess the needs of any person coming into their 19 introduced myself to you a couple of minutes ago. My
20 program, and if they cannot meet those needs, then they 20 law finn is Drew, Eckl & Farnham, and we actually
21 have to refer them somewhere else. If-- so if 21 represent Narconon of Georgia and Narconon International
22 someone's coming in and needs more medical oversight 22 in this lawsuit that has been brought by Patrick
23 than they're capable of giving, they have to refer them 23 Desmond. One of my first questions is that I see that
24 somewhere else. If they need a residential program, 24 you have with you a file?
25 they have to refer them to a licensed residential 25 A. Ub-huh (affirmative).
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Desmond, et al. v.
Narconon, et al.
Page 41
1 Q. Is that your personal file?
2 A. It's-- yes, it is; it's some of-- it's just
3 some of the papers that I was looking through to try to
4 refresh my memory. It's been almost four years.
5 Q. Sure. Did you actually have those in your
6 possession?
7 A. No; I was given them when I came here, just to
8 refresh my memory. And I asked for some of them.
9 Q. Okay. And when you say that you were given
10 them, you were given them by Mr. Harris?
11 A. Yes.
12 Q. All right. Were you given any documents by
13 anybody else?
14 A. No.
15 Q. Did you go to DHR and ask for documents from
16 them?
17 A. No.
18 Q. So the sum total of the documents that you
19 have that you reviewed in preparation for your
20 deposition to refresh your recollection of some of these
21 events are documents that Mr. Harris provided to you?
22 A. No; actually, the-- the memorandum was
23 something that I had in my possession. --
24 Q. Okay. So --
25 A. --Now that I think about it.
Page 42
1 Q. Other than the memorandum, the other documents
2 that you have reviewed in preparation for testifYing
3 here today were provided by Mr. Harris or somebody in
4 his firm?
5 A. Yes.
6 Q. Okay. When did they provide you with those
7 documents?
8 A. Yesterday.
9 Q. Are there -- are all of the documents that you
10 were provided with related to the Department of Human
11 Resources?
12 A. Yes, l believe so.
13 Q. Were -- did -- were you provided with any
14 deposition testimony?
15 A. No, I was not.
16 Q. What about a copy of the lawsuit?
17 A. No, I was not.
18 Q. Were you provided with any pleadings in the
19 lawsuit?
20 A. No, l was not.
21 Q. So everything that's contained within that
22 file is related to the Depattment of Human Resources
23 with respect to the Narconon of Georgia--
24 A. Yes, it is.
25 Q. --drug treatment program?
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Nina Edidin
February 17, 2012
Page 43
A. Yes.
Q. Okay. Now, if! read the documents conectly,
I think your official title was director of the legal
unit of the Office ofRegulatory Services?
A. Actually, no; 1 think that was a misnomer
that -- because there were the various departments
within ORS, the person in charge was considered the
director. That's why they put that in that letter. I
was actually the manager of the legal unit.
Q. And as the manager of the legal unit, you were
an -- you were an attorney?
A. Yes.
Q. Licensed in Georgia?
A. Yes, I was.
Q. By the way, I-- I graduated from Georgia
State in '98, so you and I were there together.
A. Oh, okay.
Q. Are you licensed in any other states?
A. I'm licensed in Arizona now, but was not then.
Q. And were you licensed consistently in the
State of Georgia from 1996 until 2008?
A. Yes, I was.
Q. All right. Was your authority as manager--
Q. --for the legal unit within the Office of
Page 44
Regulatory Services, was that authority extended over
all areas that were regulated by the Department of Human
Resources?
A. That -- all areas that were covered by the
Office of Regulatory Services. There were other--
there were other programs that were regulated that were
part of another department.
Q. Okay. Give me an example of those. And I --
we talked about -- for example, Bright from the Start; I
know Bright from the --
A. Yes.
Q. -- Start is --
A. Originally that had been -- that had been
overseen and licensed by the Office of Regulatory
Services. However, at some point before I came on
board, they were put -- they were changed -- the reg --
the authority to regulate them was given to another
department. Now, I'm not even sure which department it
was. l think it was perhaps the Department of
Education? Or Bright from the Start.
Q. It's -- I think it's actually just Bright from
the Sta1i, is now the department.
A. Oh, okay. Okay.
Q. Which used to fall under the DHR umbrella, --
A. Right.
(11) Pages 41 - 44
Desmond, ct al. v.
Narconon, et al.
Page 45
1 Q. -- if I'm not mistaken.
2 A. But they split it off so child care facilities
3 weren't regulated by the same people that-- that
4 regulated child caring facilities, which are really
5 group homes.
6 Q. Okay. With respect to your-- the types of
7 facilities that you were responsible, --
9 Q. -- did that include the nursing homes?
10 A. No.
11 Q. All right. Nursing homes fall under the
12 umbrella of. .. ?
13 A. The feds. In other words, the State of
14 Georgia was under contract with the feds to survey the
15 nursing homes. And then if there was -- if there was a
16 civil penalty, they would appeal to the federal
17 government.
18 Q. Would you be involved at all in representing
19 ORS or DHR with respect to any appeal or civil monetary
20 fines levied on nursing homes at all?
21 A. If it was something that was purely a state
22 regulation, then I would be.
23 Q. Right. Because there are federal regs that
24 apply to nursing--
25 A. Uh-huh ( affinnative ).
Page 46
1 Q. -- homes, for example, right?
2 A. Yes.
3 Q. And there's also state regs?
4 A. Yes.
5 Q. And a lot of them mimic one another?
6 A. Yes.
7 Q. All right. So you were involved with nursing
B homes to-- with-- with respect to if they-- if it
9 involved an allegation of a failure to meet a state
10 regulation?
11 A. Yes. And there wasn't a corr-esponding federal
12 regulation.
13 Q. What--
14 A. But that was fair-- that was relatively rare.
15 Q. What other types of organizations were you
16 responsible for?
17 A. Let's see. Dialysis centers. Let me try to
18 think. It was a -- it was a fair number of
19 organizations. Child -- again, child caring
20 institutions; we were responsible for regulating
21. organizations that provided foster care; we were
22 responsible for regulating personal care homes. Which
23 their department was -- included the nursing homes; the
24 nursing home department included personal care homes.
25 Q. Sure. This -- you've subacute, ALS and
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A. Uh-huh (affinnative).
Q. Okay. What else?
Nina Edidin
February 17,2012
Page 47
A. I -- I'm trying to think. Anything that would
be regulated and licensed by that depmiment.
Q. So you ce1iainly were not limited to drug
treatment and rehab facilities?
A. No, I was not.
Q. Would it be fair to say that that was a fairly
small component of the types of companies that you were
responsible for overseeing? As far as regulatory.
A. There were quite a number of treatment
centers, so -- and I recall that I had a number of cases
involving drug and treatment -- education treat -- and
treatment centers. So it was probably not such a small
component, if I -- if I was involved in more than one
case.
Q. How many cases-- do you remember about how
many cases you would be involved with per year? Total.
A. For drug and alcohol, or--
Q. No.
A. --just in general?
Q. In general.
A. In general. A lot. It could be as much as
over a hundred.
Page 48
Another thing I recalled is when a CNA --
there was a complaint against a CNA and they lost their
certification, I would go into-- into administrative
court.
Q. You're talking about certified nursing
assistants?
A. Yes.
Q. All right. And with respect to the
hundred-plus cases that you worked on as the manager for
ORS, how many of those typically would involve a drug
rehab facility?
A. 1 think I did a number of them. TI1ree or
four.
Q. Okay. So three or four out of a hundred-plus
cases--
A. Yes.
Q. -- per year? All right. And the other 97,
98, whatever, were these other types of entities that --
A. Yes.
Q. -- we've been talking about?
A. And I also -- there was another attorney who I
supervised.
Q. Who was that?
A. Oh, dear. She's changed her name; she's
manied. Her name's Pam. And I believe she's still
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Desmond, et al. v.
Narconon, et al.
Page 49
1 with ORS and doing the child caring institution.
2 Q. Okay.
3 A. And I don't know her cunent -- I can't
4 remember her cunent name.
5 Q. And we were talking earlier, I know Mr. Hanis
6 asked you about you, as you, Nina, did an inves -- you
7 did investigations of drug rehab facilities, and I think
8 you pointed out you didn't do the actual investigations?
9 A. That's conect.
10 Q. Right. You're not a surveyor, --
11 A. No.
12 Q. -- right? So you didn't actually go to the
13 physical plant of the drug rehab facilities?
15 Q. Do you know, sitting here today, how many
16 licensed drug rehab programs there are in the State of
17 Georgia?
18 A. I do not.
19 Q. Do you have an educated guess?
20 A. No. I wouldn't even venture a guess at this
21 point.
22 Q. Do you know how many surveyors, in the time
23 frame that you were with ORS, how many surveyors were
24 ded -- dedicated to drug rehab facilities?
25 A. Again, I'd hate to venture a guess; I don't
Page 50
1 know.
2 Q. All right. And basically when you were
3 representing the Office of Regulatory Services with
4 respect to any appeals made by entities such as
5 Narconon --
6 A. Uh-huh (affinnative).
7 Q. --or these dialysis centers or CNAs or
8 whatever it was that you happened to be working on that
9 day, you relied on the surveyors' information as far as
10 how you proceeded, right? --
11 A. Yes.
12 Q. -- You didn't do any personal investigation?
13 A. Oh, I would talk to the surveyors. I would
14 ask them questions, and I would make certain that
15 they -- that their survey, that their -- their
16 investigation was properly conducted, and I would also
17 talk to the director and assistant director of the
18 programs.
19 Q. Of the programs themselves?
20 A. The programs in-- within ORS. --
21 Q. Right. Not the--
22 A. --Yes.
23 Q. -- actual dmg rehab programs?
24 A. Yes.
25 Q. Conect?
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Nina Edidin
February 17, 2012
Page 51
Initially.
Right. Of course. Once you get --
When it came time to negotiate --
-- to negotiate -- sure. Times -- times --
Uh-huh (affinnative).
-- change then. But as far as gathering of
the information, your role is really limited to what
other people provide you with?
A. Yes.
Q. Okay. You left DHR in June of 2008?
A. That's conect.
Q. Before Patrick Desmond passed away?
A. Yes.
Q. And did you leave DHR voluntarily?
A. Yes.
Q. Okay. So you resigned under good
circumstances?
A. Oh, yes.
Q. All right. I saw some allegations, something
about some juvenile detention--
A. I was a whistle blower --
Q. Okay.
A. -- in 2005 for the Department -- I was the
director of legal services for the Department of
Juvenile Justice. And then with the attorney general's
Page 52
office, I became a whistle blower.
Q. And that's why you left the DJJ?
A. Yes.
Q. All right. And the DJJ is the Department of
Juvenile Justice?
A. Yes. But I didn't-- I resigned, I was not
tenninated.
Q. All right. And just so the jury is clear, you
are not here today as an authorized agent of the
Department of Human Resources?
A. That's conect.
Q. Okay. You're here today as Nina Edidin?
A. That's correct.
Q. All right. Now, you-- because you had
already left DHR as of the time ofMr. Desmond's death,
you had not heard anything about that death outside of
this particular lawsuit?
A. No, I had not.
Q. Okay. And in order to prepare for your
deposition -- is it -- is it your understanding that
Mr. Hanis wanted your deposition in this lawsuit?
A. Yes.
Q. Okay. And he provided you with certain
documentation from the Department of Human Resources?
A. Yesterday, yes.
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Desmond, et al. v.
Narconon, et at.
Page 53
1 Q. Right. So that you could get-- 1 Q. Sure.
Nina Edidin
February 17, 2012
Page 55
2 A. Familiar with it, that's all. 2 A. And I had the experienced people giving me
3 Q. Sure. Did you actually meet with Mr. Harris 3 opinions on whether or not it was appropriate.
4 in preparation for being here today? 4 Q. Right. And I'm not asking what, quote,
5 A. Briefly. 5 experienced people may have told you; I'm asking about
6 Q. How long is -- is briefly? 6 you personally. You personally, given your background
7 A. We met for about an hour and a half, and then, 7 and history and training and experience, cannot offer
8 you know, I wanted to look over some things, and I -- 8 any expe1t opinion as t o the program itself. Fair?
9 I'm staying with a friend way out in the suburbs, so I 9 A. Somewhat. I -- I would say fair, but I'd like
10 kind of stayed downtown and-- 10 to explain my answer.
11 Q. Okay. 11 Q. Sure.
12 A. -- and had some Chick-Fil-A, 'cause I miss 12 A. I went to law school relatively late in life,
13 that. 13 and even though I have a bachelor's degree in social
14 Q. Sweet tea and Chick-Fil-A are two things -- 14 work, I have a master's degree in urban planning, and I
15 A. Sweet tea -- 15 did social assessments for close to 30 years, and was
16 Q. --you can't get. 16 involved in-- in-- in doing assessments for a long
17 A. Yes. Sweet tea and Chick-Fil-A. More likely 17 time doing home studies before I was an attorney, after
18 to get sweet tea than Chick-Fil-A. 18 I was an attorney, and so I have some experience with
19 Q. All right. With respect to you personally, 19 counseling in general, yes.
20 you're not a nurse? 20 Q. Okay. You're not planning on offering any
21 A. No. 21 testimony about the counseling or the rehabilitation or
22 Q. You're not a physician? 22 the treatment components--
23 A. No. 23 A. Only --
24 Q. You are not a licensed clinical counselor? 24 Q. -- offered by Narconon of Georgia?
25 A. No, I'm not. 25 A. Only in the-- only if they weren't providing
Page 54 Page 56
1 Q. And you're not a-- 1 an individualized program, which is one of the
2 A. But I do have a degree in social work. 2 requirements of the regulations.
3 Q. All right. Are you a licensed social worker? 3 Q. Right. But you'd be coming at it as far as
4 A. No, I'm not. 4 whether or not they were in compliance with the-- with
5 Q. Would it be fair to say, Ms. Edidin, that you 5 the --
6 are-- you do not have any expetience with respect to 6 A. Yes.
7 running a drug education and rehabilitation program? 7 Q. --state regs?
8 A. No, I do not. 8 A. Yes.
9 Q. All right. And you cannot offer any 9 Q. Okay. Were you given anything by Mr. Harris
10 testimony, any opinion testimony, about the Narconon 10 or his finn to testify here today? In other words, were
11 program itself; fair to say? 11 you compensated for your time to be here today?
12 A. I can offer testimony about what I personally 12 A. No.
13 experienced in terms of whether or not 1 felt that all 13 Q. Okay. Did they provide you with any-- a
14 infmmation that was provided in applications turned out 14 hotel, money for a hotel or airfare, fee, or anything
15 to be truthful or not truthful, provided or not 15 like that?
16 provided. 16 A. They provided me with some airfare.
17 Q. Sure. And I'm --you're talking about the 17 Q. Okay.
1B application process with the Department of Human 18 A. Airfare. That was it.
19 Resources? 19 Q. Do you remember what the sum total of that
20 A. Yes. 20 was?
21 Q. And what I'm talking about are the course 21 A. I really don't. It was-- it-- I really
22 materials . You can't offer any opinion as to whether or 22 don't remember; I think it was ... Because they
23 not the-- the course materials provided to students at 23 provided-- we worked together to get the ticket.
24 Narconon were appropriate? 24 Q. Okay. We talked a little bit earlier--you
25 A. I was -- we reviewed all the course material. 25 talked a little bit earlier with Mr. Harris--with
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Desmond, et al. v.
Narconon, et al.
Page 57
1 respect to the survey process in general, --
2 A. Uh-hub (affinnative).
3 Q. -- and I'm going to ask you a couple of
4 questions about that. First of all, were there-- were
5 there certain surveyors who were dedicated to drug rehab
6 programs?
7 A. Yes, I believe so.
8 Q. Right. In other words, somebody wasn't going
9 out one day to inspect a day care and then the next
10 day --
11 A. No.
12 Q. --to Narconon?
13 A. They were not.
14 Q. Okay. And my understanding is that these
15 programs are inspected on -- randomly?
16 A. I believe they're pretty much re -- inspected
17 within two years.
18 Q. Right. But, in other words, the --
19 A. Unless there's a complaint.
20 Q. -- the facility doesn't know when they're
21 coming?
23 Q. They're unannounced?
25 Q. All right. I -- I -- I misworded that.
Page 58
1 A. Okay.
2 Q. Okay. So they-- the-- basically the program
3 is just running, going about its day, and all of a
4 sudden the State shows up?
6 Q. And when the State shows up to conduct its
7 survey, it's -- it's looking at a number of components?
B A. That's correct.
9 Q. It is looking at the physical plant, --
10 A. Uh-huh (affitmative).
11 Q. --right?
12 A. Yes.
13 Q. It's looking at the treatment records of the
14 students?
15 A. Yes.
16 Q. It may be looking at course materials?
17 A. Yes.
18 Q. It can interview employees of the program,
19 right?
20 A. It always interviews employees.
21 Q. Sure. And it can also interview students
22 within the program as well?
23 A. Yes.
24 Q. And they're doing this is as fact-finding and
25 gathering information?
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Nina Edidin
February 17, 2012
Page 59
Q. So that they can then make a determination as
to whether or not that particular program is in
compliance with the state regulations?
A. Yes.
Q. Okay. Do you know -- you said that they're
typically surveyed once every two years or if there's a
complaint?
A. Yes.
Q. Okay. And those-- those are called complaint
surveys,--
A. Yes.
Q. --right? That's different from smt of a
general survey?
A. Yes.
Q. And the focus of a complaint survey is
typically to go out, investigate the allegations of the
complaint, and then make a determination as to whether
or not the complaint -- I think the -- the tenn of art
is whether it's substantiated or unsubstantiated?
A. Yes.
Q. Okay. Do you know of a percentage of
facilities that receive 100 percent perfectly clean
surveys every single time they're surveyed?
A. There's usually -- very few get a hundred
Page 60
percent.
Q. Right. In other words, the surveyors who are
coming out to these different facilities, I mean, their
job is to really try to -- try to bring the facility up
within the regs?
A. Yes.
Q. And if there's something that the facility's
doing that may be not perfect with respect to the regs,
they'll cite them in order to bring them into
compliance?
A. That's correct.
Q. All right. So it's not uncommon for drug
rehab programs to receive citations under the state
regs?
A. It's not uncommon, but it's uncommon for a
civil penalty to be issued.
Q. Okay. So it is uncommon for a civil penalty
to be issued?
A. Yes.
Q. Was a civil penalty issued against Narconon of
Georgia?
A. Yes; the civil penalty was denial of the
license.
Q. All right. As far as civil monetary penalty,
there was never any monetary penalty levied against
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Desmond, et al. v.
N arconon, et al.
Page61
1 Narconon?
2 A. Well, the-- the highest civil penalty is
3 denial of the license. If it was something that was
4 felt at that time that they -- that their -- they could
5 get into compliance, or they are in compliance, then a
6 civil penalty up to -- I believe at the time it was
7 25,000 could have been issued.
8 Q. Okay. Let's --let's take these one at a
9 time, okay?
10 A. Okay.
11 Q. So my question, my original question to you
12 was, is it uncommon for facilities to receive citations
13 under the state regs?
14 A. No.
15 Q. All right. You said it's -- it-- it is
16 uncommon for them to receive civil penalties?
17 A. Yes.
18 Q. All right. And the civil penalties that are
19 available to the State include the levying of monetary
20 penalties?
21 A. Yes.
22 Q. And that can be up to, I think you told me,
23 $25,000?
24 A. Yes.
25 Q. Is it $25,000 total, or $25,000 a day?
Page 62
1 A. It's $25,000 total for the civil penalty, but
2 if they're told that they have to get in compliance and
3 if they're not in compliance by X date, there can be a
4 daily fine --
5 Q. Right.
6 A. -- that could -- I forget what the amount is,
7 but it could be several-- at least $100 a day, but it
8 could be more than that.
9 Q. And all of this is contained within the
10 regulations themselves?
11 A. Yes .
12 Q. All right. And then, as you've pointed out,
13 the highest civil penalty would be yanking somebody's
14 license?
15 A. Yes.
16 Q. All right. And that's what happened as a
17 result -- I think that -- that one of the exhibits
18 Mr. Harris showed you was a letter dated in October of
19 2006--
20 A. Yes.
21 Q. All right. --to the facility, which
22 basically put them on notice of the State's intention to
23 not renew their license?
24 A. I think it put them more on notice that they
25 didn't comply in that... That they didn't correct --
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Nina Edidin
February 17, 2012
Page 63
they were given a plan of correction, or they provided a
plan of correction, and they did not comply. So, yes, I
think it-- but then they were told that if they
continued to operate... Let's see. That they could not
continue to operate.
Q. Right. But according to O.C.G.A. 31-2-6 and
50-13-18, they had the rightto appeal those?
A. Yes.
Q. Right. And they had -- they had a certain
amount oftime -- a certain time frame to do that in?
A. Yes.
Q. And in fact they did appeal those?
A. Yes, they did.
Q. Okay.
A. And that's when I would have gotten
involved--
Q. All right.
A. -- initially.
Or I might have given some advice during the
process, when they were talking about taking-- denying
their license. I would probably have been involved at
that point, because it was -- it was a very drastic
step.
Q. Right. And my understanding is that Narconon
did appeal this letter, and requested a hearing in front
Page 64
of a -- an -- an ALJ?
A. Yes.
Q. Which is, for the jury, it's not a trial judge
like the one that's here in this case, it's what's --
what we call an administrative law judge.
A. That's correct.
Q. And that person basically deals with matters
involving administrative law, such as state regulations?
A. Yes.
Q. Okay. And so Narconon asked for a hearing in
front of the ALJ?
A. Yes.
Q. Which, my understanding was, that's when
you-- you get involved?
A. Yes.
Q. And when you get involved, you in fact then --
my understanding--correct me if I'm wrong--is that there
is a series of conversations with Narconon and its
representatives?
A. Yes.
Q. Including attorneys?
A. Yes.
Q. And that there are also a couple of
face-to-face meetings?
A. Yes.
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(16) Pages 61 - 64
Desmond, et al. v.
N arconon, et al.
1
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Q. Between DHR and Narconon and its
representatives?
A. Yes.
Page 65
4 Q. Okay. And that these meetings took place,
5 if-- if I'm reading my file correctly, between November
6 of 2006, which would have been about a month or so after
7 this letter, --
9 Q. --and about February of 2007; --
10 A. Yes.
11 Q. - ~ d o e s that time frame sound right?
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Nina Edidin
February 17,2012
Page 67
Q. Right. And for-- for purposes of the jury,
"RDA" is recommended daily allowance.
A. Yes.
Q. Okay. --and the sauna program?
A. Yes.
Q. Okay. Those were the two things that really
caught the State's eye; is that fair to say?
A. It caught the State's eye in the fact that
9 it -- not only -- not only were they not monitored by a
10 medical personnel, but also because there were a
11 detoxification program for which they were not licensed.
12 A. Yes. And there were a number of meetings, as 12 Q. Was it your understanding that Narconon was
actually providing this stuff on its premises? 13 I recall. 13
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between the State and Narconon; would that be fair to 15
say? 1 6
A. Uh-huh (affirmative). Uh-huh (affinnative). 17
A. I can't recall whether it was on the premises
or whether it was outside of the premises, but I do know
that they were in control of it at the time.
Q. Right. And you know that there was --as a
Q. "Yes"?
A. Yes, there were. Sorry.
Q. I caught you as you were trying to take a
drink; I'm tricking you.
18 result of your meeting with-- you know who Mary Rieser
is, right? 19
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A. Yes, I do.
Q. Okay. Mary Rieser is the executive director
And there was also an in-- a fairly intensive
investigation by the State into Nar --into the Narconon 23
program-- 24
22 of the Narconon of Georgia program. You understood her
to have believed that she had pem1ission from somebody
with the State to have -- to run the sauna program?
A. Yes.
Page 66
Q. --around this time frame?
A. There was an extensive investigation
initially --
Q. Yes, ma'am.
A. -- because of the surveying, so once -- at
this point, the investigation phase wasn't as strong as
the negotiation phase.
Q. There had been very intensive investigation
into Narconon's program that resulted in the denial --
A. Yes.
Q. --of its license? Okay. And that's because
the State had some pretty significant concerns --
A. Yes.
Q. --about the program, right?
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Q.
A.
Q.
All right.
-- any understanding of that.
You -- she never --
Page 68
3
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A. There was never any permission to run the
sauna program as a detox -- that I'm aware of.
6 Q. Whether or not there was, did she ever show
7 you any correspondence from anybody at DHR which she
a believed gave her pem1ission to run the sauna program?
9 A. No.
10 Q. Okay.
11 A. Not that I recall.
12 Q. All right. The concems -- these concerns
13 about the vitamin -- the -- the vitamins and the sauna,
14 these were really kind of the primaty focus of your
15 A. And they were operating at that point, they 15 investigation-- sony, of your discussion with Narconon
and its attomeys; is that fair? 16 were operating the detoxification program for which they 16
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were not licensed.
Q. Right. And I'm going to-- I'm going to talk
17
19 to you about those concerns, but my understanding from
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the documents that we've reviewed and from your
testimony, Ms. Edidin, is that the primary concerns, if 21
I'm reading the documents conectly, the primary 22
concems related to the administration of vitamins,
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24 and--
A. At 100 times the RDA, yes. 25
A. Yes. But again, you know, I want to make it
clear that not just the concern over the-- the actual
providing doc -- vitamins and the sauna --
Q. Was the amount?
A. The amount, but also the fact that it was
detoxi -- it was a detoxification program.
Q. Okay.
A. And they were not licensed to provide that.
Q. Right. And my-- according to my records, it
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Desmond, et aJ. v.
Narconon, et al.
Page 69
1 looks like you guys either met or spoke with the
2 Narconon folks 11 times over this three- to four-month
3 period oftime. Would that be a fair recall?
4 A. No. I don't think so. I don't think it was
5 11. I cetiainly wasn't involved in 11 times.
6 Q. All right. And when I say -- I'm not talking
7 necessarily face-to-face for this; I'm also talking
8 about telephone records.
9 A. Okay. I might have met with-- might have
10 talked to the attorneys.
11 Q. Right.
12 A. And we might have been working out the
13 settlement agreement.
14 Q. Yes, ma'run.
15 A. But we'd go back and forth. They'd go to
16 their client, I'd go to my client, or-- "client" in
17 quotations, because I didn't represent them --
18 Q. Yes, ma'am.
19 A. --legally.
20 Q. Okay. And the-- at the end of the day,
21 this -- these extensive discussions and negotiations --
23 Q. --resulted in the State and Narconon
24 hammering out an agreement?
25 A. Yes.
Page 70
1 Q. All right. And that agreement is Exhibit
2 what, in front of you?
3 A. Let me find it. Exhibit No 5, Plaintiffs'
4 Exhibit No 5.
5 Q. All right. And can you tell me what the date
6 of Exhibit No. 5 is?
7 A. I believe the final date was the 26th of
8 March, 2007.
9 Q. Do you remember who actually --
10 A. The 27th.
11 Q. I'm sony, I didn't mean to cut you off
12 A. Oh, it looked like one was signed on the 26th
13 and one part of it was signed on the 27th.
14 Q. And do you remember who actually drafted this
15 agreement?
16 A. I believe the initial agreement-- which is
17 what I often did; I would have the attorney on the other
18 side draft the settlement, and then it would be -- we
19 would work on it as a team.
20 Q. Sure. It's negotiated by the parties?
21 A. Yes.
22 Q. Okay. And the end result of this agreement,
23 which is marked as Exhibit No ....
24 A. Yes.
25 Q. 5. --
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Nina Edidin
February 17, 2012
Page 71
--is-- is that Narconon was granted a
license?
A. Yes .
Q. And that license was not only an outpatient
license, conect?
A. Yes.
Q. But also included an ambulatory detox
component?
A. Yes, it did.
Q. Okay. And in cons -- in -- at least in
partial consideration for the State granting Narconon
this license, this more expansive license, in March of
2007, --
Q. -- Narconon agreed to release any potential
claims that it may have had against the Department of
Human Resources. You see that, in the first couple
paragraphs?
A. I do, I do; and that was just more or less
boilerplate language, because they had no claims at that
time except the appeal.
Q. Okay.
A. And it would have been -- the appeal would be
unnecessary if they were granted a license.
Page 72
Q. Sure. At the end of the day, regardless of
whether or not it's boilerplate, that's part oftl1e
agreement? --
A. Yes.
Q. --That Narconon agreed to release any claims
it may have had --
A. Yes; and as we agreed to the same thing in the
next paragraph.
Q. Sure. It's a mutual release, --
A. Yes.
Q. -- so to speak?
A. But it also included a mutual release for
those particular claims, but it, as any agreement that
the State would enter into where regulations really
oversee and are -- are impotiant, it also said that
anything is over -- let me -- let me stop a. second. The
regulations override anything, including this agreement.
Q. Oh, of course. I mean, of course the progrrun
still has to comply with the state regs?
A. Yes. Yes.
Q. Right. You're not going to enter an agreement
that says, "You can function outside of the
regulations"?
A. That's conect.
Q. Right. So they've got an agreement, they've
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Desmond, et al. v.
Narconon, et al.
Page 73
1 got a license, but they still have to comply with the
2 state regs?
4 Q. Okay. To your knowledge, Nina, has Narconon
5 been fully licensed and maintained its-- this license
6 since March of 2007?
7 A. I believe it has.
8 Q. All right. Were you aware that the survey
9 that was conducted in April of2007 found Narconon to be
10 in substantial compliance with the regulations?
11 A. I don't know ifl have that survey, but if
12 you're telling me that it was found to be in substantial
13 compliance, I would believe that.
14 Q. Okay. With respect to housing; let's talk
15 about housing. There's a lot to talk about housing.
16 A. Yes.
17 Q. And you told me that the State had some
18 suspicions?
19 A. Yes.
20 Q. Okay. Were those suspicions ever raised with
21 Narconon?
22 A. Yes.
23 Q. Okay. Was Narconon ever cited for any
24 suspicions that anybody with the State had that it may
25 have been operating outside of the regs?
Page 74
1 A. I don't recall whether or not any of the
2 surveys cited them for the possibility. I don't know if
3 we could cite them for the possibility, but I do know --
4 now, again, I didn't do the investigation, but I do know
5 that -- that there was suspicion that there -- we knew
6 that there was some sort of housing.
7 Q. Uh-huh (affirmative).
8 A. And we were told that it was separate, but
9 there was a great deal of suspicion that it was not.
10 Including-- including the web site.
11 Q. Let me back up a little bit. You said that
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Nina Edidin
February 17, 2012
Page 75
respect to the reg, I think it was number 13, that dealt
with -- let me pull up --
A. No, it wouldn't be 13; it would have been ...
Q. Hang on. I may have-- 05 --
MR. HARRIS: 05.
THE WITNESS: 05, thank you.
BY MS. MARSCHALK:
Q. Yeah. Let's take a peek at number 5, because
I don't know that this was entirely clear for the jury.
A. Okay.
Q. Okay.
Okay. If-- ifl'm reading this right, and
this is -- I mean, I -- the whole state regs thing,
could there be any more numbers? It's 290-4-2-.05.
A. That's correct.
Q. Okay. And we're going to look specifically at
subparagraph E.
A. Yes.
Q. All right. And under sub --basically this --
this reg --
A. Yes.
Q. -- deals with the licenses that facilities
have to get?
A. Yes.
Q. Okay. And subsection E --
A. Yes.
Q. --deals with exclusions?
A. That is correct.
Page 76
Q. Meaning, there are certain entities that are
excluded fi"om this requirement that they obtain a
license?
A. Yes.
Q. Okay. And one of the entities that is
excluded from having to get a state license is an
organization or person that provides "supportive
services," parentheses, "for example, residence, --" --
Q. -- "transportation, etcetera, to
drug-dependent persons but do not offer or purport to 14
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by a separate entity,-- 15 offer 'Drug Abuse Treatment and Educational Programs"'?
A. Yes.
Q. --correct?
A. Yes.
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Q. Okay. And if in fact housing was provided by 19
a separate entity, all right, that's perfectly
legitimate?
A. As long as it wasn't under the control of
Narconon.
Q. Right. I think at the end of the day, and
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what Mr. Harris was questioning you about earlier with 2 5
A. That's correct.
Q. Okay. But those support services that are
under the direct control of licensed programs must be
part of that licensed program?
A. Yes.
Q. Okay. So the --the key issue is control; --
A. Yes.
Q. -- fair? Okay. Do you know whether or not
there's ever been a complaint against Narconon about
housing where the State found that in fact there were
.JFischer@QAReporting.com
(19) Pages 73- 76
Desmond, et al. v.
Narconon, et al.
Page 77
1 two separate entities and that the housing component was
2 not required to have a license?
3 A. I'm not sure if I'm aware of anything. Was it
4 recent, or. ..
5 Q. Well, let me -- it may have been after you
6 left.
7 MR. HARRIS: It was.
B MS. MARSCHALK: Hang on.
9 BY MS. MARSCHALK:
10 Q. In the documents that you were provided by
11 Mr. Harris and his firm, if you wouldn't mind taking a
12 look at Exhibit No. --
13 MS. MARS CHALK: What exhibit are we up
14 to?
15 BY MS. MARSCHALK:
16 Q. -- whatever the next exhibit is, and tell me
17 if you were provided with this particular document.
18 Sony, I don't mean to throw that at you.
19 A. That's okay. Oh, yes, I think I was.
20 Q. And--
21 A. Oh, okay. But they would have relied on
22 whatever they were to -- they would rely on whatever
23 they were told by the licensee.
24 Q. By not only the licensee, but also the housing
25 component, correct?
Page 78
1 A. Yes.
2 Q. Right.
3 A. So they interviewed the -- yes.
4 Q. Right. So basically what happened is, a
5 student-- ifl'm reading that conectly, a student at
6 Narconon complained about housing, all right?
8 Q. And-- and filed a complaint with the
9 State, --
11 Q. --who came out to Narconon --
13 Q. -- and did a complaint --
14 A. Investigation.
15 Q. -- complaint investigation?
16 A. Yes.
17 Q. That's what we were talking about earlier.
18 And as pmt of that complaint investigation, the
19 surveyor met with both Narconon and Delgado Development?
20 A. Yes.
21 Q. All right. And it was the State
22 investigator's determination, as a result of those
23 meetings--
24 A. Surveyor.
25 Q. Sony, did I say "investigator"?
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Yes.
Nina Edidin
February 17,2012
Page 79
Okay. It's the State surveyor's
determination, as a result of that investigation, that
housing was a separate entity?
A. Yes.
Q. Okay. And that the complaint was
unsubstantiated?
A. Yes. But, again ...
MR. HARRIS: What's the date on that?
BY MS. MARSCHALK:
Q. As of June of2008 --
A. It's dated --
MR. HARRIS: What's the date on that?
MS. MARSCHALK: February 2009.
THE WITNESS: January.
MS. MARSCHALK: January 2009. Sony.
THE WITNESS: The actual survey was
dated February of2009.
BY MS. MARSCHALK:
Q. Right. The complaint 1 think --
Q. --was dated in January.
MR. HARRIS: Is that -- is that an
exhibit? Did you put that in?
MS. MARSCHALK: It is an exhibit. I
Page 80
don't know what the number is, 'cause I'm--
I didn't give Jo time to mark it. Let's do
that.
MR. HARRIS: I just want to be clear for
the record. That's all I'm asking.
MS. MARSCHALK: Sure.
(Discussion off the record.)
BY MS. MARSCHALK:
Q. All right. As of June of 2008, Ms. Edidin --
and that's when you left DHR, right?
A. Yes.
Q. As of June of2008, Narconon was licensed by
the State of Georgia as a drug abuse treatment and
education program with approval to provide, quote,
"Narconon New Life ambulatory detoxification program"?
A. Yes.
Q. Okay.
A. So they were licensed as a detoxification ...
Q. And any official involvement that you would
have had with Narconon ended when you left in -- in
June-- sony, June of2008?
A. Yes.
Q. I think that's all the questions -- well, hold
(20) Pages 77 - 80
Desmond, et at. v.
N arconon, et al.
Page 81
1 on, let me just check my notes.
2 I think that's all the questions that I have.
3 A. Okay.
4 Q. Thank you. I'm sorry to take up your vacation
5 time here.
6 A. That's okay.
7 MR. AMASON: Can we take a break --
8 MR. HARRIS: Sure.
9 MR. AMASON: -- for a couple minutes?
10 MR. HARRIS: Sure.
11 THE VIDEOGRAPHER: Going off video at
12 11:18 a.m.
13 (Recess at 11:18, resumed at 11 :25.)
14 THE VIDEOGRAPHER: We're back on the
15 video record.
16 BY MS. MARSCHALK:
17 Q. All right, Nina, I'm sorry, I-- I think I may
18 have let you go a little soon. I have a couple of more
19 questions for you.
20 A. Okay.
21 Q. But it won't take long and it won't be
22 painful. With respect to the-- the civil penalty of
23 revoking Narconon's license, --
24 A. Uh-huh (affinnative).
25 Q. -- 1 want to make sure that the jury
Page 82
1 understands that because Narconon appealed that penalty,
2 that Narconon's license was never revoked officially?
3 A. It was never revoked officially.
4 Q. Right. And it was never shut down and
5 prohibited from operations while you guys were in
6 negotiations?
7 A. That's conect.
8 Q. Okay. And as an outpatient drug and alcohol
9 rehabilitation program, the students are allowed to
10 voluntarily leave that program at any time; --
11 A. Yes.
12 Q. -- is that fair? Okay. That's all the
13 questions that I have for you.
14 A. Okay.
15 FURTHER EXAMINATION
16 BY MR. HARRIS:
17 Q. The license applications that you and I talked
18 about earlier, if you'll pull those out; I think it's
19 Exhibit No 1.
20 A. Yes.
21 Q. At any -- at any point in those license
22 applications, does -- does Narconon tell the State of
23 Georgia, "We're operating a sauna program that we use
24 for purposes of detoxification"?
25 A. No.
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Nina Edidin
February 17, 2012
Page83
And how did the state find that out?
I think the surveyor found it out when they
came -- went to the -- a facility or spoke to the
students. I don't remember exactly how they found it
out, but it was not revealed by Narconon.
Q. But have you reviewed the Mar -- the Narconon
materials, the course materials?
A. Yes.
Q. And you're aware of the fact that the sauna
program is actually one of the main components of the
program?
A. Yes.
Q. And so Narconon repeatedly submitted
applications, before the State figured this out, where
they didn't tell the State they were running a sauna
detoxification program, right?
A. That is correct.
BY MR. HARRIS:
Q. They just didn' t come in and confess, right?
A. That's correct.
Q. You-- you guys had to figure it out?
A. Yes.
Q. All right. And similarly, they've never come
in and confessed that they're running a residential
Page 84
facility, have they?
MS. MARSCHALK: Object to the form.
THE WITNESS: That's conect.
BY MR. HARRIS:
Q. She gave you a document from 2009, right? You
remember that?
A. Yes.
Q. I showed you that document, didn't I?
A. Yes.
Q. And we talked about it, but --but we -- you
weren't there in 2009?
A. No, I was not.
Q. So you don't have a clue what happened in
2009?
A. No.
Q. All right. But since she brought it up and
since you weren't there, let's talk about it anyway.
What -- what does the surveyor typically do when he does
a survey? I mean, how does the process generally work?
I -- I know you're speculating about what happened
there, but tell us how it generally works.
A. Well, they receive a complaint, they go out
and do a -- and -- the surveyor will go out and visit
the facility. They'll talk to the people at the
facility and do a cursory-- you know, they'll do an
JFiscbcr@QAReporting.com
(21) Pages 81 - 84
Desmond, et al. v.
Narconon, ct al.
Page 85
1 investigation, but in essence they're relying on
2 whatever the licensee says to them. Unless they have
3 some sort of evidence to the contrary.
4 Q. All right. So they're -- they're basically
5 relying on the truthfulness of the people that they
6 interview?
7 A Yes.
8 Q. They don't have grand jury subpoena power?
9 A. No, they do not.
10 Q. They don't have subpoena power at all?
11 A. Not at all.
12 Q. Okay. They don't have any criminal
13 enforcement ability?
14 A. No, they do not.
15 Q. They can't serve warrants and seize documents?
1 6 A. No, they cannot.
17 Q. Okay. Do you know whether or not the surveyor
18 in Exhibit -- what is that? 8?
19 A. Exhibit No. 6.
22 BY MR. HARRIS:
23 Q. 6. Do you know --let me show you what's
24 Exhibit No 7. Do you know whether or not the surveyor
25 was provided with Exhibit No. 1?
Page 86
1 A. I don't know; but it looks like it's a private
2 memo within Narconon.
3 Q. You don't have any idea whether or not the
4 surveyor that -- that was investigating this residential
5 component, whether or not that surveyor ever got
6 Exhibit No. 7, do you?
7 A. I don't know.
8 Q. And you' ve never --
9 A. But I would imag -- 1 can speculate, if--
10 Q. Well, you don't have to speculate.
11 A Okay.
12 Q. You just don't know?
13 A. I don't know.
14 Q. Okay. And you don't know whether or not the
15 surveyor knew anything about Delgado Development?
16 A. I'm sure they didn't.
17 Q. Well, you just don't know?
18 A. Huh-uh (negative), I don't know.
19 Q. Okay. You don't know --
20 A. I don't know.
21 Q. -- whether or not the surveyor who did that
22 survey in Exhibi t No 6, whether or not they knew how
23 the Delgados were disciplined, right?
24 A. I don't know.
25 MS. MARSCHALK: Object to form.
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Nina Edidin
February 17,2012
Page 87
BY MR. HARRIS:
Q. You don't know anything about-- or, you don't
know whether or not the surveyor knew anything about how
Delgado and Narconon were compensated for residential
services, if they were?
A I don' t know.
BY MR. HARRIS:
Q. So all of your opinions about that survey are
just complete speculation, 'cause you weren't there?
A. I was not there, that's --
Q. Okay.
A -- COtTect.
Q. What is -- what is clear is that at no point
in time when you were at DHR -- or, when you were at
ORS, at no point in time did Narconon have any legal
authority under the State of Geor -- Georgia's licensing
regime to hold itself out to anybody as offering a
residential drug and alcohol treatment services?
A That's correct; at no time were they licensed
to provide residential treatment.
Q. And if they did that, it would be illegal?
A Yes.
Q. Criminal?
A Criminal.
Page 88
Q. Thank you.
MS. MARSCHALK: I have no further
questions. Thank you so much.
THE WITNESS: Thank you.
THE VIDEOGRAPHER: Okay; going off video
record at 11:29 a.m.
(Off video record.)
MS. MARSCHALK: We may need to keep this
on the record, Jo.
Jeff, because Exhibit No 1 was produced
pursuant to the confidentiality agreement and
protective order, I would ask that that
portion -- that this exhibit, if you file --
if we have to file this deposition, that it
be filed under seal.
MR. HARRJS: Yeah. And we'll deal with
that with all of them, because I think
there're a number of exhibits to depositions
that probably you all are going to contend
they're protected, so... I mean, without
agreeing with you, I understand that we've
got to deal with that, so 1 won't file it
until we deal with it one way or the other.
MS. MARSCHALK: Okay. Thank you.
MR. HARRIS: Oh. Can we go back on?
(22) Pages 85 - 88
Desmond, ct al. v.
Narconon, et at.
Page 89
1 THE VIDEOGRAPHER: Back on video?
2 MR. HARRlS: I'm sorry; I forgot one
3 other thing I wanted to add.
4 MS. MARSCHALK: Hold on.
5 THE VIDEOGRAPHER: Okay; we're back on
6 video.
7 (On video record.)
8 BY MR. HARRIS:
9 Q. I'm sorry, I had a brain lapse there for just
10 a second. Exhibit 1, the ambulatory detoxification
11 license application--
12 A. Yes.
13 Q. --of January 24th, 2007?
14 A. Let me go back to that. One moment.
15 Q. Now, you --
16 A. Yes.
17 Q. -- you were -- excuse me. You were at ORS
18 when this application was submitted, correct?
19 A. Yes, I was.
20 Q. And this application was actually part of
21 something that you were involved in in connection with
22 your work on the settlement agreement?
23 A. Yes.
24 Q. The second page, the medical director is
25 identified as Dr. Lisa Robbins, --
Page 90
1 A. Yes.
2 Q. -- correct?
3 A. That is --
4 Q. And--
5 A. -- correct.
6 Q. And the State was relying on that assertion as
7 part of its licensure decision?
B A. Yes.
9 Q. Did you know that in this litigation, in a
10 sworn interrogatory response, that Dr. Robbins denies
11 being the medical director ofNarconon of Georgia?
12 A. She denied it at this time, or denied it --
13 Q. No; did you know that in this case, in a sworn
14 intenogatory response, that Dr. Robbins, the medical
15 director here on the exhibit you're looking at, denied
1 6 being the medical director?
17 A. No, I did not know that before.
1 8 Q. Thank you. That's alii have.
19 THE VIDEOGRAPHER: Going off video
20 recordat ll :31a.m.
21 (Discussion off the record.)
22 (Deposition concluded at 11:33 a.m.)
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G E 0 R G I A:
FULTON COUNTY:
Nina Edidin
February 17,2012
Page 91
C E R T I P I C A T B
I hereby certify that the foregoing
deposition was t aken down, as stated in the
caption, and the questions and the answers
thereto were reduced to printing under my
direction; that the preceding pages represent
a true and correct transcript, to t he best
of my ability, of the evidence given by said
witness upon said hearing. And I further
certify that I am not of kin or counsel to
the parties to t he case; am not in the regular
employ of counsel for any of said parties;
nor am I in anywise interested in the result
of said case.
This, the 27 th day of February, 2012.
Jo Tomoff F1scher, RMR
CCR No. B-924
Notary Commission Expires 8- 25- 2012
l\1in-U-Scdpt Q&A Reporting Services, Inc.
(23) Pages 89 - 91
Desmond, et al. v.
Narconon, et al.
$
$100 (1)
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Q&A Reporting Ser vices, Inc.
Nina Edidin
February 17, 2012
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brain (1)
89: 9
break (2)
29:23;8 1:7
briefly (3)
18:25;53:5,6
Bright (4)
44:9, 10,20,21
bring (2)
60:4,9
brought (2)
40:22;84: 16
bunch (1)
10: 14
c
call (3)
21 :7;40: 15;64:5
called (7)
8:21 ,23; 12: 15;20:24;
28:8;29: 1 ;59: I 0
came (9)
27:2,13;33: 1;35:4;
41 :7;44:15;51:3;78: II ;
83:3
can (35)
10:9;11 :9,9; 12:9, 10, 10,
11, 12; 14: 1,3; 16:2,6,9;
18:22;24: 14,24;26: 17;
29: 15, 22;31 : 14;35: 19;
38: 14;39:7, 11 ;54: 12;
58:18,21 ;59:2;61 :22;
62:3;70:5;72:22;81:7;
86:9;88:25
capable (1)
38:23
care (6)
45:2;46:21 ,22,24;47:1;
57:9
caring (4)
9: 12;45:4;46: 19;49: 1
case (4)
28:6;47: 17;64:4;90: 13
cases (5)
4 7:13, 18,19;48:9,15
categories (1)
12:7
caught (3)
(1) $100- caught
Desmond, et al. v.
Narconon, et al.
65:20;67:7,8
cause (6)
16:22; 17:2;40:2;53: 12;
80: 1;87: I 0
cease (1)
28:7
center (1)
18:21
centers (4)
46: 17;47: 13,15;50:7
certain (9)
32:6,23;35: 15;50: 14;
52:23;57:5;63:9, I 0;76:4
certainly (2)
47:6;69:5
certification (1)
48:3
certifications (1)
12:1
certified (1)
48:5
cetera (2)
23:18;76:13
change (3)
16:25;17:9;51:6
changed (4)
9: 1;16:20;44: 16;48:24
charge (1)
43:7
check (3)
35:15,18;81:1
checked (1)
32:1 1
Chick-Fil-A (4)
53: 12, 14, 17,18
child (11)
7:8, 10;8:5,8,10;9: 12;
45:2,4;46: 19, 19;49: l
circumstances (1)
51:17
citations (2)
60:13;61: 12
cite (2)
60:9;74:3
cited (2)
73:23;74:2
Civil (17)
6:6, 1 0;28:4;45: 16,19;
60:16,17 ,20,22,24;61 :2,6,
16, 18;62: 1,13;81:22
claims (4)
71: 17,21;72:5,13
clean (1)
59:23
clear (6)
16:9;52:8;68: 18;75:9;
80:4;87:14
Client (4)
38:9;69: 16, 16, 16
clients (2)
7: 12;8:11
clinical ( 4)
2 1:24;22:8,13;53:24
MinU-Script
close (1) 83:25 couple (8)
55:15 confidentiality (1) 8: 16;23: 10;40: 19;57:3;
clue (1) 88:11 64:23;71: 18;81 :9,18
84:13 confused (1) course (8)
CNA(2) 15:25 51:2;54:21,23,25;
48:1 ,2 connection (3) 58: 16;72: 18, 18;83:7
CNAs (1) 12:24;26: 11 ;89:21 court (5)
50:7 cons (1) 8: 12; 10:8, 10;39: 15;
coming (5) 71:11 48:4
38: 19,22;56:3;57:21; consideration (1) court's (1)
60:3 71:12 6:8
Community (2) considered (3) covered (1)
8:7;9:5 7:18;11:9;43:7 44:4
companies (1) consistently (1) created (1)
47:10 43:20 35:8
compensated (2) consult (1) crime (3)
56: 11;87:4 22:4 12:2;26:22;38:7
complained (1) contact (1) criminal (3)
78:6 33:21 85: 12;87:24,25
complaint (IS) contained (2) cross (1)
48:2;57: 19;59:8, 10,16, 42:21;62:9 25:4
18, 19;76:24;78:8,13, 15, contend (1) cross-examine (1)
18;79:6,20;84:22 88:19 24:14
complete (1) contingent (3) current (2)
87:10 36: 11,22;37:2 49:3,4
completed (2) continue (1) cursory (1)
26:6,8 63:5 84:25
compliance (12) continued (2) cut (1)
36: 12,15,22;56:4;59:4; 16:23;63:4 70:11
60: 10;61 :5,5;62:2,3; contract (1)
73:10,13 45:14 D
compliant (3) contrary (1)
26: 19,20,22 85:3 DA(1)
complied (1) control (18) 7:8
11:21 15:4, 17; 17:21 ;18:23; daily (2)
complies (1) 19:9, 10;23:21,25;24:21; 62:4;67:2
19:17 25: 14,17,21 ;3 1 :25;37:19; date (6)
comply (5) 67: 16;74:22;76: 18,21 11:5;62:3;70:5,7;79:9,
21:20;62:25;63:2; controlling (1) 13
72:19;73:1 19:2 dated (6)
component (15) conversations (1) 15:8,21 ;62: 18;79: 12,
15:5,18;17: 19;18:23, 64:18 18,22
23;19:10,1 1, 12;20:12; copy (7) day (13)
47: 10, 16;71 :9;77: 1,25; 22: 1 ;28:25;29:23; 21 :8;35:9;39: 12;50:9;
86:5 34:16,19,21 ;42: 16 57:9,9,10;58:3;61 :25;
components (4) Cornett (3) 62:7;69:20;72: 1 ;74:24
9:4;55:22;58:7;83: 10 30:6,21,22 days (1)
concern (4) correction (8) 33:22
32: 14,16;35:20;68: 18 28:9,11;29: 1,4;32: 1,3; dead (1)
concerns (9) 63:1,2 11:5
30:7,10, 12;66: 12,19, correctly (5) deal (4)
21,23;68:12, 12 6:20;43:2;65:5;66:22; 74:9;88: 16,22,23
concluded (1) 78:5 deals (3)
90:22 correspondence (1) 64:7;75:22;76:2
conditions (1) 68:7 dealt (1)
36:12 corresponding (1) 75:1
conduct (1) 46:11 dear (1)
58:6 counsel (3) 48:24
conducted (2) 10:6; 19: 17;34:11 death (2)
50:16;73:9 counseling (3) 52:15,16
confess (1) 20:9;55: 19,21 decision (1)
83:20 counselor (1) 90:7
confessed (1) 53:24 ded (1)
J Fischer@QAReporting.com
Nina Edidin
February 17,2012
49:24
dedicated (2)
49:24;57:5
deficiencies (2)
16:7;28:3
defined (1)
18: 11
degree (3)
54:2;55: 13,14
dehydrated (1)
35:19
Delgado (3)
78: 19;86: 15;87:4
Delgados (1)
86:23
denial (5)
28:4;33:19;60:22;61 :3;
66:9
denied (6)
27: 12;33:1 0;34:8;
90:12,12,15
denies (1)
90:10
denying (1)
63:20
Department (30)
7:13,15;8:6,18,24;9:5,
7;26:7,8, 10, 13, 16;42: 10,
22;44:2,7,18, 18, 19,22;
46:23,24;47:5;51 :23,24;
52:4,10,24;54:18;71: 17
departments (2)
9:14;43:6
dependent (1)
23:18
deposition (7)
6:5;41:20;42: 14;52:20,
21;88:14;90:22
depositions (2)
6:9;88:18
deputy (1)
30:22
describes (1)
14:9
describing (1)
2 1:16
desist {1)
28:7
Desmond (3)
39: 16;40:23;51: 12
Desmond's (1)
52:15
detail (1)
13:22
detention (1)
51:20
determination (4)
59:2, 18;78:22;79:3
determine (1)
38:14
determined (1)
33:8
detox (2)
(2) cause- detox
Desmond, et al. v.
Narconon, et al.
68:5;71:8
detoxi (1)
68:22
detoxification (19)
12:11 ;20:2,5, 11, 18;
27:6,16;30:17;31 :22;
33:3,5;66: 16;67: 11;
68:22;80: 17 ,20;82:24;
83:16;89:10
Development (2)
78:19;86:15
DHR(15)
9:8; 14:1 ;29:21;32:22;
37:5;41: 15;44:24;45: 19;
51:10, 14;52:15;65: 1;
68:7;80: 12;87: 15
Dialysis (2)
46:17;50:7
difference (1)
20:4
differences (1)
12:14
different (9)
8: 16;9:2;1 0: 15; 12:6;
I 6:1 0,14;35: 19;59: 13;
60:3
digging (1)
23:11
direct (4)
23:21 ;25:14,17;76: 18
director (25)
18: 10;20:14,19,21 ,23,
24;21:2,24;22:8, 13;30:6,
23,25;35:8;36: I ;43:3,8;
50:17, 17;51 :24;67:21;
89:24;90: 11, 15, 16
disciplined (1)
86:23
discovers (1)
27:20
discussion (3)
68: 15;80:7;90:21
discussions (2)
65: 14;69:21
divisions (1)
9:1
DJJ (2)
52:2,4
doc (1)
68:19
document (6)
13:9; 14:2;28:22;77: 17;
84:5,8
Documentation (2)
36:2;52:24
documents (13)
26: 12;41: 12, 15,18,21;
42:1 '7 ,9;43:2;66:20,22;
77:10;85:15
done (2)
17:3;40:9
dosages (1)
36:8
!\ lin-L-Script
down (2) 69:1 15:17;19:10
23:13;82:4 else (5) Exhibit (36)
downtown (1) 35:24;38:21 ,24;41: 13; 13:4,7,8;28: 15, 18;29:9,
53:10 47:3 12;30:2;33: 12, 15;34:5,
Dr (4) employ (1) 17 ;36:20;70: 1 ,3,4,6,23;
20:22;89:25;90: 10,14 35:13 77: 12,13,16;79:24,25;
draft (1) employees (3) 80:9;82: 19;85: 18,19,21,
70:18 12:1;58:18,20 24,25;86:6,22;88: 10, 13;
drafted (1) end (6) 89: 10;90: 15
70:14 13:18;23:13;69:20; exhibits (2)
drastic (1) 70:22;72: 1 ;74:24 62:17;88:18
63:22 ended (1) expansive (1)
Drew (1) 80:22 71 :13
40:20 Enforcement (3) experience (3)
drink (1) 8:6,1 0;85: 13 54:6;55:7,18
65:21 ensure (1) experienced (3)
Drug (41) 35:9 54: 13;55:2,5
9:17;10:18;11:15;12:3, enter (2) expert (1)
7;13:12; 14:6, 13, 17; 15:2, 72:14,21 55:8
11,15,18; 17:16, 17; 18:7, entered (1) expire (1)
10,21;20:5,7;23: 18, 19; 34:3 11:6
38: 13;39: 14;42:25;47:6, entire (1) explain (5)
14,20;48:1 0;49:7,13, 16, 21:5 10:20,21;25: 11 ;38: 17;
24;50:23;54:7;57:5; entirely (1) 55:10
60: 12;76: 15;80: 15;82:8; 75:9 extended (1)
87:19 entities (5) 44:1
drug-dependent (1) 48:18;50:4;76:4,8;77: l extensive (3)
76:14 entity (5) 65:14;66:2;69:21
drugs (1) 35:7,11 ;74:15,20;79:4 eye (2)
21:4 Especially (1) 67:7,8
duly (1) 35:20
6:14 essence (1) F
during (3) 85:1
12: 17;26:23;63: 19 et (2) fa (1)
duties (2) 23: 18;76: 13 20:7
20:23;23:2 even (4) face-to-face (2)
37: 16;44: 18;49:20; 64:24;69:7
E 55:13 facilitate (1)
event (1) 28:11
earlier (5) 26:6 facilities (15)
49:5;56:25;74:25; events (1) 12:8;21 :16;38: 1;39:23;
78: 17;82: 18 41:21 45:2,4, 7;4 7:7;49:7 ,13,24;
earlier-you (1) evidence (1) 59:23;60:3;61: 12;75:22
56:24 85:3 facility (25)
Eckl (1) exactly (1) 12:3; 14:7; 15:2,15, 18;
40:20 83:4 19:2,3;20:5,6;27:1 0, 19;
Edidin (8) EXAMINATION (3) 3 7:7;38: 13;39:5,6,8;40:6;
6:5, 13, 18;7: 1;52: 12; 6:16;40:12;82: 15 48: II ;57:20;60:4;62:21;
54:5;66:21;80:11 examined (1) 83:3;84: I ,24,25
educated (1) 6:14 facility's (2)
49:19 example (4) 27:20;60:7
education (12) 44:8,9;46:1;76: 11 fact (8)
12:1 0; 13: 13; 14: 14, 17; except (1) 36: 17;63: 12;64: 16;
20:6,7;23:20;30: 16; 71:22 67:8;68:21 ;74: 19;76:25;
44:20;47: 14;54:7;80: 16 excluded ( 4) 83:9
educational (2) 24: 11;25:15;76:5,9 fact-finding (1)
20:8;76:15 exclusions (2) 58:24
effective (1) 25:19;76:2 facts (1)
18:17 excuse (2) 26:9
effects (2) 13:23;89: 17 failure (1)
36:4,9 executive (1) 46:9
either (6) 67:21 fair (13)
20:9;24: 1 ,5;28:3,4; exercise (2) 46:14, 18;47:9;54:5, 11;
Nina Edidi n
February 17,2012
55:8,9;65: 15;67:7;68: 16;
69:3;76:23;82:12
fairly (2)
47:9;65:22
faU (2)
44:24;45: 11
False (2)
26:2,10
familiar (4)
8: 17; 12: 15;23:4;53:2
far (5)
47:11;50:9;51:6;56:3;
60:24
Farnham (1)
40:20
February (7)
6:2;15:8,22;17:6;65:9;
79:14,18
federal (4)
9:17;45:16,23;46:11
feds (2)
45:13,14
fee (1)
56:14
feel (1)
22:5
felt (2)
54:13;61:4
few (2)
23: 12;59:25
figure (1)
83:22
figured (1)
83:14
file (8)
29:21 ;40:24;41: 1;
42:22;65:5;88: 13,14,22
filed (2)
78:8;88:15
final (1)
70:7
fmd (4)
26: 17;29: 17;70:3;83: 1
fine (2)
28:6;62:4
fines (1)
45:20
firm (4)
40:20;42:4;56: 1 0;
77:11
first (16)
6: 14,20;13:7,8,10, 15,
24,25;14:6;15:21 ;27: 13;
30:21 ;37: 13;40:23;57:4;
71:18
Flip (1)
18:16
Florida (1)
39:15
focus (2)
59:16;68:14
folks (1)
69:2
(3) detoxi - folks
Desmond, et al. v.
Narconon, et al.
follows (1)
6:15
forget (1)
62:6
forgot (1)
89:2
form (9)
12:21; 19:4;20: 12;
30:24;39:24;83: 18;84:2;
86:25;87:7
forth (1)
69:15
foster (1)
46:21
found (9)
27:5, 15;28:2;33:2;
73:9, 12;76:25;83:2,4
four (3)
41:4;48: 13,14
four-month (1)
69:2
frame (4)
49:23;63: 10;65:11;
66:1
framework (1)
23:5
free (1)
22:5
friend (1)
53:9
front (6)
22:4,12,21 ;63:25;
64:11;70:2
fully (3)
26:6;3 7: 19;73:5
function (1)
72:22
FURTHER(2)
82:15;88:2
G
gathering (2)
51:6;58:25
gave (3)
14:24;68:8;84:5
general (8)
10:21 ;27: 18;47:22,23,
24;55: 19;57:1 ;59: 14
generally (3)
14:20; 84:19,21
general's (4)
7: 11 ;8:4;10: 11;51 :25
Geor (1)
87: 17
Georgia (29)
6:6;7:9,24;11: 16;12:2,
15,19,24;13:2,24; 14: 1;
20: 17;37:1 ;39:14, 17,18;
40:21;42:23;43: 13,15,21;
45:14;49:17;55:24;
60:21 ;67:22;80: 15;
82:23;90: 11
Min-D-Script
Georgia's (1) 19,21 ,25;39:22;40:4, I 0; 34:4;80:8;85:20
87:17 41:10,21 ;42:3;49:5; identified (1)
given (12) 52:21;53:3;56:9;62: 18; 89:25
11 :5;17: 17;21 :4;41 :7, 74:25;75:5;77:7, II ;79:9, identify (2)
9,10,12;44: 17;55:6;56:9; 13,23;80:4;81 :8,10; 21:19;22:13
63:1,19 82: 16;83: 19;84:4;85:22; ie (1)
giving (2) 87:1,8;88: 16,25;89:2,8 23:17
38:23;55:2 Harris-with (1) illegal (2)
goes (1) 56:25 40:5;87:22
27:19 hate (1) lllinois (1)
Good (4) 49:25 8:1
6: 18,19,24;51: 16 Health (3) imag (1)
government (2) 8:7;9:5, 15 86:9
9:17;45:17 heard (1) important (2)
governmental (1) 52:16 17:11;72:15
8:16 hearing (2) include (2)
grad (1) 63 :25;64: 10 45:9;61:19
7:19 hearings (1) included (4)
graduate (2) 10:10 46:23,24;71 :8;72: 12
7:3,20 high (1) Including (4)
graduated (1) 36:8 64:21;72: 17;74: 10,10
43:15 highest (2) independently (1)
grand (1) 61:2;62:13 24:5
85:8 history (2) indicate (2)
granted (3) 7:6;55:7 20:16,21
16:1 ;7 1 :2,25 hold (6) indicates (1)
granting (1) 37:25;39: 19,25;80:25; 13:8
71:12 87:18;89:4 individual (1)
great (1) home (2) 39:9
74:9 46:24;55: 17 individualized (1)
group (3) homes (14) 56:1
9:13, 17;45:5 9:13,16, 17;45:5,9,11, individuals (1)
guess (3) 15,20;46: I ,8,22,23,24; 21:19
49:19,20,25 47:1 Information (7)
guys (3) hospitals (1) 26:3;32:8;36:3;50:9;
69: I ;82:5;83:22 9:14 51 :7;54: 14;58:25
hotel (2) informed (1)
H 56:14,14 36:9
hour (1) in-house (2)
half(2) 53:7 10:5;12:9
14:23;53:7 hours (4) Initial (3)
hammering (1) 21 :8;35:9,16;39: 12 14:4;20:2;70: 16
69:24 housing (11) Initially (3)
hand (4) 73: 14,15,15;74:6,14, 51: I ;63: 18;66:3
13:6;29: 11;33: 14; 19;76:25;77: 1,24;78:6; inspect (4)
34:16 79:4 11:24,25,25;57:9
handed (3) Huh-uh (1) inspected (2)
13:10,15;30:1 86:18 57:15,16
handling (1) Human (11) inspection (3)
23:7 7: 15;8: 18,24;9:7; 11:3,24;33:2
Hang (2) 42:1 0,22;44:2;52: 1 0,24; instances (1)
75:4;77:8 54: 18;71:18 8:14
happen (1) hundred (3) institution (1)
35:19 35:21;47:25;59:25 49:1
happened (6) hundred-plus (2) institutions (2)
33:25;50:8;62: 16;78:4; 48:9,14 9:13;46:20
84:13,20 Intake (1)
HARRIS (60) I 38:9
6:4, 17;12:22; 13:5; intensive (2)
16: 11 ,15; 19:7;24: 13,17, idea (1) 65:22;66:8
20,24;25:2,4,5;28: 16,21; 86:3 intention (1)
29: I 0, 16,18,21,24,25; identification (7) 62:22
31: 16;32: 18;33: 13;34:6, 13:3;28: 14;29:8;33: 11; International (1)
Nina Edidin
February 17, 2012
40:21
interrogatory (2)
90:10,14
interview (3)
58:18,21;85:6
interviewed (1)
78:3
interviews (1)
58:20
into (14)
12: 18;20: 10;23:11;
34:3;37: 11;38: 19;48:3,3;
60:9;61 :5 ;65:23 ,23;66:9;
72:14
introduced (1)
40:19
inves (1)
49:6
investigate (1)
59:17
investigated (1)
12:23
investigates (1)
32:22
investigating (1)
86:4
investigation (13)
50: 12, 16;65:23;66:2,6,
8;68: 15;74:4;78: 14, 15,
18;79:3;85:1
investigations (2)
49:7,8
investigator (1)
78:25
investigators (1)
37:14
investigator's (1)
78:22
involve (1)
48:10
involved (16)
20: 1 0;26:24;27:2;35:6;
45: 18;46:7, 9;47: 16, 19;
55: 16;63: 16,21 ;64:14, 16;
69:5;89:21
involvement (1)
80:21
involving (2)
47:14;64:8
issue (6)
16:21;26: 10;32:4;37:5,
12;76:21
issued (9)
21 :9;26: 18;36: 11, 17,
2 1;60: 16,18,20;61:7
issues (4)
12: 18;31:5,8;33: 1
J
January (6)
19: 16;20: 16;79: 15, 16,
22;89: 13
(4) follows- January
Desmond, et al. v.
Narconon, et al.
Jeff (3)
29: 15;31: 14;88: 10
Jo (3)
6:11 ;80:2;88:9
job (3)
8:25;12:24;60:4
judge (2)
64:3,5
June (7)
9:23 ;51: 1 0;79: 11;
80:11,14,23,23
jury (15)
6:24;7:5;8: 16;10:3,21;
25:11 ;30:10;37:9;38:17;
52:8;64:3;67: 1;75:9;
81:25;85:8
Justice (4)
7: 13;8:7;51 :25;52:5
Juvenile (5)
7: 13;8:6;51 :20,25;52:5
K
keep (2)
36:2;88:8
key (1)
76:21
kind (15)
15:1 ,5, 15;20: 10;21 :2,3,
3,3;24:2;25: 15;27: 18,22;
39:6;53: 1 0;68: 14
knew (4)
74:5;86: 15,22;87:3
knowledge (1)
73:4
L
language (1)
71:21
lapse (1)
89:9
last (4)
14:20; 19: 18;25: 16,20
lasted (1)
14:21
late (1)
55:12
law (11)
7:3,20,22;11 :16;12:2;
39:17, 19;40:20;55: 12;
64:5,8
lawsuit (5)
40:22;42:16,19;52: 17,
21
lawsuits (1)
8:14
least (3)
14:7;62:7;71:1 1
leave (4)
9:22;31 :2;51:14;82: 10
left (6)
51: 10;52:2, 15;77:6;
1\{in-U-Script
80:12,22 55:12;80:17 12;33: 11 ;34:4;70:23;
Legal (15) likely (1) 80:8;85:20
7:2,10,16, 18;1 0: 1,4; 53:17 married (1)
23 :3;30:6,23;43 :3,9,10, limited (2) 48:25
25;51:24;87:16 47:6;51:7 MARSCHALK (47)
legally (3) Lisa (2) 12:21; 16:9,13;19:4;
37: 1,25;69: 19 20:22;89:25 24:7,10,16, 19,23;25: I ,3;
legislative (1) litigation (1) 28:20;29: 14, 17,20,22;
10:7 90:9 31:14,17;34:20,23;39:21,
legitimate (1) little (9) 24;40:9,11 ,13,18;75:7;
74:21 7:5;8:2;12: 13; 14:22; 77:8,9, 13,15;79:1 0,14, 16,
lengthy (1) 23: 12;56:24,25;74: 11; 19,25;80:6,10;81:16;
35:4 81:18 83: 18;84:2;86:25;87:7;
less (2) living (1) 88:2,8,24;89:4
14:22;71:20 6:25 Marschalk's (1)
letter (5) long (6) 17:4
33:1 9;43 :8;62: 18; 14:20; 19:6;53: 6;55: 16; Mary (2)
63:25;65:7 74:22;81 :21 67:18,21
levied (2) look (9) master's (1)
45:20;60:25 16:2,13;18: 13;31: 14; 55:14
levying (1) 37: 11;38:9;53:8;75: 16; material (1)
61:19 77:12 54:25
li (1) looked (2) materials (5)
16:8 37:16;70:12 54:22,23;58: 16;83:7,7
liability (1) looking (6) maternity (1)
36:7 41 :3;58:7,9,13, 16; 31:2
license (70) 90:15 matters (1)
10:25;11: 1, 10,16,20; looks (3) 64:7
12:4; 13 :23,25; 14:6,11, 14:22;69:1;86:1 may (16)
21,24; 15:7, 10,1 1, 13, 14, lost (1) 8: 17;15:23;22:6;26:8,
20; 16:21 ,24; 17: 17;18:6, 48:2 I 0;29:3;55:5;58: 16;60:8;
14,19;19:21;20: 17;21:9, lot (3) 71 :17;72:6;73:24;75:4;
13,15,19;24:6,21 ;26:5, 10, 46:5;47:24;73: 15 77:5;81: 17;88:8
18;27:7,8;28: 1 ,5,5, 12; LPN (1) MD(1)
33: 10,19;34:7;36: 10,18, 35:14 32:17
21 ;37:2;60:23;61:3; mean (17)
62: 14,23;63:21;66: 11; M 14:5;16:4;17:11 ;23:24;
71 :3,5,6, 13,13,25;73: 1,5; 24:14,21,24;26:15;38:17;
76:6,9;77:2;81 :23;82:2, ma'am (3) 39:9;60:3;70:11;72: 18;
17,21;89:11 66:4;69: 14,18 75: 13;77:18;84: 19;88:20
licensed (42) main (2) Meaning (1)
13:12, 12;14: 16; 19:2,6, 32:14;83:10 76:4
13;23:21 ,22;24:2,2,6; maintain (1) means (2)
25:17,18,22,23;27: 10,17, 36:15 23:25;26: 16
21 ;30: 13;31 :21 ;33:4; maintained (1) medical (22)
38:5,25;40:3;43: 13,18, 73:5 18:9;20:9, 13,18,21 ,23,
19,20;44: 14;47:5;49: 16; management (1) 24;21: 1 ,2;32:4,8,1 0,14;
53:24;54:3;66:17;67:11; 10:6 35:8;36: I ;37: 14;38:22;
68:24;73:5;76: 18,19; manager (5) 67: 1 0;89:24;90: 11, 14,16
80: 14,20;87:20 7:16;43:9,1 0,23;48:9 meet (4)
licensee (3) many (8) 38: 14,20;46:9;53:3
77:23,24;85:2 30:24,24;47: 18, 19; meeting (2)
license-in (1) 48: 10;49: 15,22,23 32:2;67:18
27:25 Mar (1) meetings ( 4)
licenses (13) 83:6 64:24;65 :4,12;78:23
11:4,25;12:7;14:20; March (3) meets (1)
18:5, II; 19:23;2 I :22,24; 70:8;71: 13;73:6 11:3
22: 19,24;26:25;75:22 Marion (5) memo (4)
licensing (1) 30:5,21,22;31 :2,4 29: 18;30:5, 10;86:2
87:17 mark(1) memorandum (2)
licensure (3) 80:2 41:22;42:1
11 :4; 16:24;90:7 marked (11) memory(4)
life (2) 13:3,6;28: 14,17;29:8, 27: 15;31 :13;41 :4,8
Nina Edidin
February 17,2012
met (5)
35: 11;53:7;69: 1,9;
78:19
might (8)
28: 11;31: 1 ;37:6,10;
63:19;69:9,9,12
mimic (1)
46:5
mind (1)
77:11
minutes (2)
40:19;81:9
misdemeanor (1)
12:5
Misleading (1)
26:3
misnomer (1)
43:5
miss (1)
53:12
mistaken (1)
45:1
misworded (1)
57:25
moment (2)
38:1 1;89:14
monetary (5)
28:5;45: 19;60:24,25;
61:19
money (1)
56:14
monitored (1)
67:9
month (1)
65:6
more (12)
11: 10; 12: I 3;14:22;
38:22;47: 16;53: 17;62:8,
24;71:13,20;75:14;81: 18
morning (2)
6:18,19
most (1)
9:4
mostly (1)
8:8
moved (2)
16:10,11
moving (1)
17:25
much (5)
32:5;39:2;47:24;57: 16;
88:3
must(7)
22:7;23:21 ;25: 17;26:5,
20,21;76:18
mutual (2)
72:9,12
myself(1)
40:19
N
name (4)
(5) Jeff- name
Desmond, et al. v.
Narconon, et al.
6:20;40: 18;48:24;49:4
named (1)
14:7
name's (1)
48:25
Nar (3)
14: 16;39:18;65:23
Narconon (82)
12: 15,18,24;13:2,24;
14:1,16,25;15: 1,4,14,17;
17: 18; 18:9,19;20:15;
21 :9,24;26:24;30:8;31 :5;
32:22;33: 1,20;34: I 0, II;
35:2;36:7,11,22;37:6,22,
24;39: 14, 15, 18;40:21,21;
42:23;50:5;54: 10,24;
55:24;57:12;60:20;61: I;
63:24;64: 10, 18;65: 1, 15,
23;67: 12,22;68: 15;69:2,
23;71 :2, 12,16;72:5;73:4,
9, 21,23;74:23;76:24;
78:6,11,19;80:14,17,22;
82: 1,22;83:5,6,13;86:2;
87:4, 16;90: 11
Narconon's (5)
36: 12;37: 1;66:9;81 :23;
82:2
necessarily (3)
29:6;39:2;69:7
need (5)
22:4,6;33:21;38:24;
88:8
needs (5)
25:22;38: 15,19,20,22
negative (1)
86:18
negotiate (3)
34:11;51:3,4
negotiated (1)
70:20
negotiation (1)
66:7
negotiations (3)
35:5;69:21 ;82:6
nevertheless (1)
9:6
New (1)
80:17
next(6)
14:1 0;15:7;25:24;57:9;
72:8;77: 16
Nina (10)
6:5, 13;7: I ;40: 15, 16, 17;
49:6;52: 12;73:4;81: 17
Non-medical (2)
32:10,13
Nor (1)
17:21
notes (1)
81:1
notice (2)
62:22,24
November (2)
Min-U-Script
9:21 ;65:5 46:5;47:16;56:1 ;57:9; override (1)
number (11) 61:8;62:17;64:4;70: 12, 72:17
24:8;46: 18;47: 12, 13; 13;76:8;83: 10;88:23; oversee (2)
48: 12;58:7;65: 12;75: I ,8; 89:2, 14 32:17;72:15
80: 1;88:18 ongoing (2) overseeing (1)
numbe1s (3) 32:9;39:9 47: II
16: 10,14;75: 14 Only (7) overseen (1)
nurse (3) 55:23,25,25;67:9,9; 44:14
35:13, 14;53:20 71:5;77:24 oversight (5)
nursing (10) operate (13) 32: 10,14;35:6;38:22;
9: 15;45:9, 11,15, 20,24; 12:2;13: 12;15: 1 ,15; 39:9
46:7,23,24;48:5 16:23;17: 18; 18: 10,22; overview (2)
24:2;37: 1;40:5;63:4,5 10:22;39:6
0 operates (1)
10:20
p
Ob (1) operating (7)
39:21 27: 15,25;37:7;66: 15, packet (2)
Object (7) 16;73:25;82:23 17:25; 19:20
12:21; 19:4;39:24; operating-then (1) page (6)
83: 18;84:2;86:25;87:7 28:2 13:7 ,15;14: 10;17:5;
Objections (1) operations (2) 25:24;89:24
6:7 28:7;82:5 painful (1)
obligation (1) opinion (3) 81:22
38:18 54: 10,22;55:8 Pam (1)
obtain (2) opinions (2) 48:25
11:20;76:5 55:3;87:9 papers (1)
OCGA (1) order (8) 41:3
63:6 6:9;10:23,24;11 :19; par (1)
October (1) 26:19;52: 19;60:9;88: 12 24:8
62:18 Ordinarily (1) paragmph (1)
off (8) 11:4 72:8
45 :2;70: 11;80:7;81:11; organization (2) paragraphs (1)
88:5,7;90: 19,21 12:15;76:10 71:19
offer (13) Organizations (4) parentheses (1)
23: 19,19;25:15,21; 23: 16;46: 15,19,21 76:1 1
39:7,20;40: I ;54:9, 12,22; original (1) part (11)
55:7;76:14, 15 61:11 7: 15;23:2,22;25: 18;
offered (1) originally (3) 44:7;70:13;72:2;76: 19;
55:24 11:5;31:22;44:13 78: 18;89:20;90:7
offering (3) ORS (13) partial (1)
37:25;55:20;87: 18 9:25;12: 17,24;23:3; 71:12
offers (1) 26:23;43:7;45:19;48: 10; participants (1)
19:3 49:1 ,23;50:20;87: 16; 32:12
office (21) 89:17 particular ( 4)
7:11,14, 17;8:3,4,5;9:3, out (34) 52: 17;59:3;72: 13;
8, 10, 15, 19;10:1 1,14; 7:6,8;1 1 :2,8;20:24,24; 77:17
11 :2;35:5;43:4,25;44:5, 26: 17;27:15,19,24;37: 15, parties (1)
14;50:3;52:1 25;39: 19;40: 1 ;48: 14; 70:20
officer (5) 49:8;53:9;54: 14;57:9; passed (l)
7: 1 0,18; 10: 1,4;23:3 59: 17;60:3;62: 12;69: 12, 51; 12
official (2) 24;78: 11;82: 18;83: 1 ,2,5, patient's (1)
43:3;80:21 14,22;84:22,23;87: 18 38:15
officially (3) outpatient (7) Patrick (3)
7:17;82:2,3 15:11; 18:21; 19:21; 39: 16;40:22;51: 12
often (1) 20:5,7;71 :5;82:8 pause (1)
70:17 outside (4) 18:4
Once (3) 52: 16;67: 15;72:22; peek (1)
51 :2;59:7;66:5 73:25 75:8
one (30) over (14) penalties (3)
7: 12;10:7, 17;13:10; 7: 11;9:4; 15:4, 17; 61; 16, 18,20
14:25; 15:22,22;16: 18; 19:1 0;23:25;31 :3;39: 11; penalty (14)
17:21 ;18:4;19: 18;34:20; 44:1 ;47:25;53:8;68: 18; 28:4;45: 16;60: 16, 17,
36:5,14;38: I 1;40:23; 69:2;72: 16 20,22,24,25;61 :2,6;62: 1,
Nina Edidin
February 17, 2012
13;81:22;82:1
people {11)
21: 18;32:8;35:5, 16;
37: 14;45:3;51:8;55:2,5;
84:24;85:5
per (2)
47:19;48:17
percent (2)
59:23;60:1
per centage (1)
59:22
perfect (1)
60:8
perfectly (2)
59:23;74:20
perhaps (1)
44:19
period (6)
9:25;1 1:14;12:17;
26:23;37:23;69:3
permanent (1)
11:10
permission (3)
67:23;68:4,8
permit (1)
18:16
person (7)
21:14,15;32: 13;38: 19;
43:7;64:7;76: 10
personal (5)
41: 1;46:22;24;47:1;
50:12
personally ( 4)
53: 19;54:12;55:6,6
personnel (3)
32: 10;39:15;67: 10
persons (3)
23:16,18;76:14
perspective (1)
36:25
phase (2)
66:6,7
physical (2)
49:13;58:9
Physically (1)
35:17
physician (1)
53:22
place (2)
38:12;65:4
Plaintiffs' (16)
13:4,7,8;28:15,18;29:9,
12;30: 1 ;33: 12,14;34:5,
17;36:20;70:3;80:9;
85:21
plan (8)
28:8, 10;29: 1,3;32: 1,3;
63:1, 2
planning (2)
55:14,20
plant (2)
49:13;58:9
pleadings (1)
(6) named - pleadings
Desmond, et al. v.
Narconon, et al.
42:18
please (1)
6:11
point (16)
8:17; 11 :9;20: 15;36:5;
37:2,4,5,20;44: 15;49:21;
63:22;66:6, 15;82:21;
87: 14, 16
pointed (2)
49:8;62:12
portion (1)
88:13
possession (2)
41:6,23
possibility (2)
74:2,3
potential (1)
71:16
power (2)
85:8,10
powers (1)
37:20
Practice (2)
6:7,10
premises (3)
67:13,14,15
preparation (3)
41: 19;42:2;53:4
prepare (l)
52:19
present (3)
7:2; 11:23;31 :1
pressure (1)
35:15
pretty (2)
57: 16;66: 12
primary (3)
66:21,22;68:14
private (1)
86:1
privilege (1)
10:12
Probably (6)
16: 7;29: 17;3 1: 19;
47: I5;63 :21 ;88: 19
problems (1)
32:25
procedure (1)
27:22
proceeded (1)
50:10
process (8)
10:21; Il: 19; 16:24;
32: 17;54: 18;57: 1;63:20;
84:19
produced (I)
88:10
program (62)
11: 15,23; 12:10,1 1, 12;
13: 13;14: 14, 18; 15:12;
18: 10;20:8,8,9;21 :3,5;
23:22;25: 18;27: I6, 16;
30: 16,17;31:22,24;33:3,
Min-U-Script@
5,7,9;37: 18;38:20,24; recollection (2)
39:1 ;40:2;42:25;54:7,11;
Q
32:25;41 :20
55:8;56: 1;58:2,18,22; recommended (4)
59:3;65:24;66:9, 14, 16;
quick (1)
31 :23,24;32: 13;67:2
67:4,11,22,24;68:5,8,22;
31:15
record (12)
72: 18;76: 19;80: 16, 17;
quite (1)
6:2; I 0:9,1 0;80:5, 7;
82:9, I 0,23;83: 10, 11, 16
47: 12
81: 15;88:6,7,9;89:7;
programs (16)
quotations (1)
90:20,21
9: 18; 10: I 8; 18:7;23:21;
69:17
records (5)
25: 17;37: 17;44:6;49: 16;
quote (2)
11:25;36:2;58:13;
50:18, 19,20,23;57:6,15;
55:4;80:16
68:25;69:8
60:13;76:18 refer (4)
Programs' (2)
R
38:21 ,23,25;39:2
23:20;76: 15 Referral (1)
prohibited (1)
aised (1)
38:9
82:5
73:20
refresh (4)
prohibition (2)
randomly (1)
31:1 1;41:4,8,20
19:2,5
57:15
refuse (1)
pronouncing (1)
rare (1)
26: 10
6:20
46:14
reg (4)
properly (2)
rate (2)
38:2;44: 16;75: 1,20
36:3;50:16
17:17;22: 10
regarding (1)
proposing (1)
RDA (4)
6:9
31:7
32:6;35:2I ;66:25;67:2
regardless (1)
protected (1)
re (2)
72: I
88:20
36:6;57: 16
regime (1)
protective (l)
read (2)
87:18
88:12
31:9;43:2
regimen (1)
prove (2)
reading (4)
32:12
11:21;37:18
65:5;66:22;75: 12;78:5
registered (2)
provide (16)
real (1)
35: 13,14
10:24;13:11 ;22:8;
3I :15
regs (12)
23: 17;35:6;36:3;39:3,8,
realize (1)
38:3;45:23;46:3;56:7;
11,15;42:6;51 :8;56: 13;
23:10
60:5,8, 14;61:13;72: 19;
68:24;80: I 6;87:2 1
really (8)
73:2,25;75: 13
provided (19)
45:4;51 :7;56:21,21;
regu (1)
41 :21;42:3, 10, 13, 18;
60:4;67:6;68: 14;72: 14
10:24
46:21 ;52:23;54: 14,15,16,
reapplied (1)
regulate (2)
23;56:16,23;63: 1;74: 14,
27:7
9:1;44:17
19;77: 10,17;85:25
reapply (1)
regulated (8)
provides (1)
II:8
9:16;10: I4,17;44:2,6;
76:1 0
reason (2)
45:3,4;47:5
providing (4)
26:7;39: 10
regulates (1)
38:4;55:25;67: 13;
rec (1)
9:I2
68:19
31 :3
regulating (2)
pull (3)
recall (8)
46:20,22
22: 18;75:2;82: 18
27:3,13;47:13;65:13;
regulation (4)
purely (1)
67: I4;68: 11 ;69:3;74: 1
22:23;45:22;46: 10,12
45:2I
recalled (1)
regulations (20)
Pur-0-Cleanse (3)
48:1
1 I :22; I 9: I ;20:25;22:2,
35:7,10,12
receive (5)
I 8;23:8, 12;26:20,2I;
purport (4)
59:23;60: 13;61: 12,16;
36: 16;38:8, 12;56:2;59:4;
23: 19;25: 14,21 ;76: 14
84:22
62: 10;64:8;72: 14,1 7,23;
purposes (11)
received (1)
73:10
6:6;13:4;28: 15;29:9;
14:1
Regulatory (18)
33: 12;34:5;39: 13;67: 1;
recent (1)
7:14, 17;9:3,8, 10, 15,20;
80:9;82: 24;85:21
77:4
10: 14,21 ;1 1 :2; 12: 18;
Pursuant (4)
recertified (1)
23:5;43:4;44: 1,5,14;
10:23;11: 16;27:5;
11:7
47: 1 1;50:3
88: 11
Recess (1)
rehab (9)
put (5)
81:13
47:7;48: 11;49:7,13,I6,
43:8;44: 16;62:22,24;
recognize (1)
24;50:23 ;57 :5 ;60: 13
79:24
28:22
rehabilitation (9)
JFischer @QAReporting.com
Nina Edidin
February 17, 2012
10: 18; 11: 15;12: 3; 14:6;
19:21 ;38: 13;54:7;55:21;
82:9
related (6)
23: 8;26:24;33: 1;42: I 0,
22;66:23
relatively (2)
46: 14;55:12
release (5)
36:7;71: 16;72:5,9, 12
relied (3)
3 7:20;50:9;77:21
rely (4)
21: 13, 15,18;77:22
relying (3)
85:1 ,5;90:6
remember (8)
47: 18;49:4;56: 19,22;
70:9,14;83:4;84:6
renew (1)
62:23
renewal (1)
I9:2I
renewing (1)
I 6:24
repeatedly (1)
83:13
represent (4)
10:8,9;40:21;69: 17
epresentations (1)
21:10
representatives (2)
64:19;65:2
represented (5)
8:5,6, 12, 12;39: 14
representing (2)
45:18;50:3
request (1)
19: 17
requested (1)
63:25
require (2)
2I:24;26:9
required (4)
II : 16; 18: 9; 26: 12;77:2
requirement (4)
20: 13;21 :7;22:9;76:5
requirements (6)
11 :4,22;21 :20;32:2;
35:1 1;56:2
requires (2)
10:24;22:24
reserved (1)
6:7
residence (2)
23: I 7;76: 11
residential (30)
12: 12; 1 5:2,5, I5, 18;
17: 19;18:22,23; 19:3,10;
37:7 ,17,18,25;38:24,25;
39:4,5,6,8, 16,20;40: I ,2,6;
83:25;86:4;87:4, I9,21
resigned (2)
(7) please - resigned
Desmond, et al. v.
Narconon, et al.
51:16;52:6
resolution (1)
31:7
Resources (10)
7: 16;8: 18;9:7;42: 11,
22;44:3;52: I 0,24;54: 19;
71:18
respect (14)
15: 13;42:23;45:6,19;
46:8;48:8;50:4;53: 19;
54:6;57: 1 ;60:8;73: 14;
75:1;81:22
respond (1)
29:4
response (5)
25:1 0;29: I ,7;90: 10,14
responsibilities (1)
23:2
responsibility (1)
38:12
responsible (10)
21 :2,5;23:4,7;35: 12;
45:7;46: 16,20,22;47: 11
result (8)
33 :25;34:2;36:7;62: 17;
67: 18;70:22;78:22;79:3
resulted (2)
66:9;69:23
resumed (1)
81:13
revealed (1)
83:5
reviewed (5)
41: 19;42:2;54:25;
66:20;83:6
revocation (1)
28:5
revoke (1)
26:18
revoked (2)
82:2,3
revoking (1)
81:23
Rieser (2)
67:18,21
right (115)
6:4;8: 15;9:6,24; 11 :12;
12:6, 13; 13: I ;14:5,9,14,
16; 15:20; 17: 14,25; 18: 13;
19: 15;20: 1,3,4;22:17,21;
23:24;25:9;26:15;29:11;
30:1 ,9;33: 14,25;34:7,16;
35: 1;36: 10;41 :12;43:23;
44:25;45: 11,23;46: 1,7;
48:8,17;49: 10,12;50:2,
I 0,21;51 :2,19;52:4,8, 14;
53: I, 19;54:3,9;55:4;56:3;
57:8, 18,25;58:11, 19;
59: 13;60:2,12,24;61: 15,
18;62:5, 12, 16,21;63:6,7,
9,17,24;65:11;66:14,18;
67: I, 17,19;68:1 ,12,25;
69:6,11 ;70: 1,5;72:21,25;
Min-U-Script
73:8;74:20,24;75: 12,19; 24: 1;25:15;30:7,23;39:4, 7:1 0;22:9;25:21;28:4;
78:2,4,6,21 ;79:20;80: 11' 6, 11, 16;43:4;44: I ,5,15; 59: 13;74:6;85:3
12;81 :17;82:4;83:16,20, 50:3;51 :24;76:11,17; sound (1)
24;84:5,16;85:4;86:23 87:5,19 65:11
Robbins (4) settlement (10) speak (1)
20:22;89:25;90: 10,14 8:13;34:3,13, 17;35: 1; 72:11
role (1) 36: 13,23;69:13;70: 18; special (1)
51:7 89:22 8:9
rules (2) several (1) specifically (3)
24:12;36:15 62:7 8:3;16:2;75:16
run (9) show (3) speculate (2)
11:13,13,15;12:18; 28: 17;68:6;85:23 86:9,10
13:21; 14: 17;67:24;68:4,8 showed (2) speculating (1)
running (5) 62:18;84:8 84:20
33:9;54:7;58:3;83: 15, shows (2) speculation (I)
25 58:4,6 87:10
shut (1) spelled (1)
s 82:4 20:24
side (3) spending (1)
Same (5) 36:4,9;70: 18 32:5
15: 13; 16:1; 18:22;45:3; signed (2) split (I)
72:7 70:12,13 45:2
sauna (16) significant (1) spoke (3)
27: 15,16;32:6;33:7 ,9; 66:12 8:15;69:1;83:3
35: 16;37:5;67:4,24;68:5, signing (1) standing (1)
8, 13,19;82:23;83:9, 15 36:5 6:8
saw (1) signs (1) start (5)
51:19 32:11 9:19;44:9,12,20,22
saying (4) similar (1) started (1)
25: 13,20;31:21 ;36:6 10:5 7:8
school (4) similarly (2) starting (1)
7:3,20,23;55:12 12:6;83:24 13:24
seal (1) single (1) State (53)
88:15 59:24 7:9,24;10:25;14:24;
second (7) site (2) 20: 17;21: 13, 15,18;30: 11;
12: 14; 13:2;18:5;32:20; 37:16;74:10 33:8;36:25;37: 11,19;
72: 16;89: 10,24 sitting (1) 43: 16,21;45: 13,21 ;46:3,
seize (1) 49:15 9;49: 16;56:7;58:4,6;
85:15 small (2) 59:4;60: 13;61: 13,19;
send (1) 47:10,15 64:8;65:15,23;66:12;
11:2 social (4) 67:24;69:23;71 :12;72: 14,
sense (1) 54:2,3;55: 13,15 19;73:2, 17,24;74: 14;
27:I9 somebody ( 4) 75: 13;76:9,25;78:9,21;
sent (1) 29:22;42:3;57:8;67:23 79:2;80: 15;82:22;83: 1,
33:20 somebody's (1) 14,15;87: I 7;90:6
sentence (2) 62:13 statements (1)
25:16,20 someone (5) 26:11
separate (8) 11: 12, 13;30:23,25; states (1)
35:7' 1 0;74:8, 12, 15,20; 39:11 43:18
77:I;79:4 someone's (1) State's (3)
September (3) 38:22 62:22;67:7,8
18:1,14,17 Somewhat (1) statute (1)
series (1) 55:9 I0:23
64:18 somewhere (2) statutory (1)
serve (1) 38:21,24 21:20
85:15 soon (1) stayed (1)
service (5) 81:18 53:10
1 0:24;24:3;25:22;38:4; sorry (14) staying (2)
39:3 24:7;25:25;40: 18; 39:10;53:9
services (37) 65: 19;68:15;70: 11; step (1)
7: 10,14,17,18;8:24;9:4, 77: 18;78:25;79:16; 63:23
8,11 ,15,15,20;10:1,4,14; 80:23;81 :4, I 7;89:2,9 still (4)
11:2;19:3;23:3,17,20; Sort (7) 11: 10;48:25;72:19;
Nina Edidin
February 17, 2012
73: l
stop (1)
72:16
strong (1)
66:6
student (2)
78:5,5
students (5)
54:23;58: 14,21 ;82:9;
83:4
studies (1)
55:17
stuff (1)
67:13
sub (1)
75:19
subacute (1)
46:25
subject (2)
11:10;27:14
submitted (2)
83:13;89:18
subparagraph (1)
75:17
subpoena (3)
37:20;85:8,10
subsection (6)
22: 18;23: 13;24:8;26:2;
38:9;75:25
subsidiary (1)
19:3
substantial (2)
73:10, 12
substantiated (1)
59:20
suburbs (1)
53:9
sudden (1)
58:4
suite (2)
16:10, 14
sum (2)
41:I8;56:19
superseding (1)
38:3
supervised (1)
48:22
support (7)
7:9, 10;8:5,8, I 0;23 :20;
76:17
supportive (3)
23: 17;24: 1 ;76: lO
supposed (1)
35:10
sur (1)
27:4
Sure (23)
16:4;31: 10,16;35: 18;
41 :5;44:18;46:25;51 :4;
53:3;54: 17;55:1,1 I;
58:21;65: 14;70:20;72:1'
9;77:3;80:6;81 :8, 10,25;
86:16
(8) resolution -Sure
Desmond, et al. v.
Narconon, et al.
survey (15)
16:3;28:25;29:5;45: 14;
50:15;57: 1;58:7;59: 14,
16;73:8, 11 ;79: 17;84: 19;
86:22;87:9
surveyed (2)
59:7,24
surveying (1)
66:5
surveyor (18)
11 :2,8,24;27: 19,20;
49: 10;78: 19,24;83:2;
84:18,23 ;85: 17 ,24;86:4,
5,15,21;87:3
surveyors (6)
12:25;49:22,23;50:13;
57:5;60:2
surveyor's (1)
79:2
surveyors' (1)
50:9
surveys (7)
9:16;11:11;27:5;37: 15;
59: 11,24;74:2
sus (1)
37:10
suspicion (3)
37:8;74:5,9
suspicions (5)
37:6,10;73: 18,20,24
swear (1)
6:11
Sweet (4)
53:14, 15,17,18
sworn (3)
6:14;90:10,13
T
talk (16)
8:2;9:24;12:13; 13: I,
22;18:25;22: 17;23: 11;
31 :3;50: 13,17;66: 18;
73: 14,15;84: 17,24
talked (10)
18:5;36:21 ;37:4,17;
44:9;56:24,25;69:10;
82: 17;84:10
talking (18)
14:25;17:4;18:11;
19:24;20: 11 ;21 :23;
22:24;24:8;26:2;48:5,20;
49:5;54: 17,21;63:20;
69:6,7;78: 17
tea (4)
53:14,15,17,18
team (3)
10:7, 7;70:19
telephone (1)
69:8
telling (2)
31:4;73:12
ten (1)
Min-U-ScripMl
33:22 47:14 74:22;75: 19;76: 18;
term (1) treatment (31) 87:17;88:15
59:19 9: 18; 13: 12;14: 13, 17; undergtaduate (1)
terminated (1) 15:2,12, 15,18; 17: 17; 7:25
52:7 18:7,10,21 ;20: 10,13; understanding-correct (1)
terms (3) 21:3;23:20;30: 16;38: I; 64:17
36:12,14;54:13 39:5,20;42:25;47:7,12, understands (1)
testified (1) 14, 15;55:22;58: 13;76: 15; 82:1
6:15 80: 15;87: 19,21 understood (1)
testify (1) trial (1) 67:22
56:10 64:3 unit (5)
testifying (1) trials (1) 7:16;43:4,9,10,25
42:2 8:10 University (2)
testimony (6) tricking (1) 7:24;8:1
42: 14;54: 10,10, 12; 65:21 unless (3)
55:21;66:21 true (1) 16:2;57: 19;85:2
Thanks (1) 31:25 unlicensed (l)
31:17 t ruthful (5) 40:6
there're (1) 21: 16;26: 17,21 ;54: 15, unnecessary (1)
88: 18 15 71:25
Thereupon (7) truthfully (2) unsubstantiated (2)
13:3;28: 14;29:8;33: 11; 26:6,8 59:20;79:7
34:4;80:8;85:20 truthfulness (2) up (19)
third (2) 37:21;85:5 8:2;13: 1;16:9;21:22;
14:10;15:20 try (5) 22:18;27:13;3 I :5;32: I 9;
though (1) 37:11;41 :3;46: 17;60:4, 33: I ;58:4,6;60:4;61 :6,22;
55:13 4 74:11;75:2;77:13;81:4;
Three (2) trying (2) 84:16
48:12,14 47:4;65:20 Upon (4)
three- (1) turn (2) 11:1;36:11,22;37:2
69:2 17:5;19: 15 urban (1)
throw (1) turned (1) 55:14
77:18 54:14 use (1)
ticket (1) two (14) 82:23
56:23 9:1 ;11 :6,7, 11; 14:21,22; used (1)
times (7) 16: I ;18:5,11;53: 14; 44:24
32:6;35:21 ;51 :4,4; 57: 17;59:7;67:6;77: 1 usually (2)
66:25;69:2,5 Type (1) 11 :6;59:25
title (1) 14:3 uti (1)
43:3 types (4) 32:15
today (7) 45:6;46:15;47:10;
42:3;49: 15;52:9, 12; 48:18 v
53:4;56: 10,11 typically (4)
together (2) 48: 10;59:7, 17;84: 18 vacation (1)
43:16;56:23 81:4
told (13) u various (6)
27 :9;28 :6;30: 13 ;33 :20; 8: 13,14,14;9:14;35:5;
55:5;61 :22;62:2;63:3; ultimately (4) 43:6
73: 17;74:8,I 2, I 4;77:23 21 :5;34:3,13;36: 17 venture (2)
took (1) umbrella (2) 49:20,25
65:4 44:24;45:12 verification (1)
total (5) unannounced (1) 26:9
41 :18;47: 19;56: 19; 57:23 video (9)
61:25;62: 1 uncommon (6) 6:1;81:1 1,15;88:5,7;
towards (1) 60: 12, 15, 15, 17;61: 12, 89: 1,6,7;90:19
13:18 16 VIDEOGRAPHER (7)
training (1) under (30) 6:1 ;81: 11,14;88:5;
55:7 9:8;12:2; 14:3; 16:23; 89: 1,5;90: 19
transitioned (1) 18:25;20: 12,25;23:21; violation {1)
7:11 24:6;25: 14,17,19,20; 38:2
transportation (2) 35: 14;37:19;38:8,18; visit (1)
23:18;76:13 39: 17,1 8;44:24;45:1 1, 14; 84:23
treat (1) 51: 16;60:13;61: 13; vital (1)
Nina Edidin
February 17,2012
32:11
vitals (1)
35:18
vitamin (3)
32: 12;33:7;68:13
vitamins (7)
32:7;35: 17;36:4,8;
66:23;68:13,19
voluntarily (2)
51:14;82:10
w
waiver (1)
36:6
walk (2)
27:22;30:9
wants (1)
11:12
warrants (1)
85:15
watch (1)
39:11
way (8)
9: 13;20:25;32: 19;
37: 17;38:8;43: 15;53:9;
88:23
web (2)
37: 16;74:10
weren't (8)
31 :21;32:2;35: 18;45:3;
55:25;84: 11, 17;87: 10
what's (5)
11 :9;64:4;79:9,13;
85:23
whistle (2)
51:21;52:1
whole (1)
75:13
within (14)
9: 14; II :6, 7;33:22;
35:5;42:21 ;43:7,25;
50:20;57: I 7;58:22;60:5;
62:9;86:2
without (5)
12:3; 19: 12, 12;27:25;
88:20
witness (11)
6:12;19:5,17;24:9;
31: 18;39:25;75:6;79: 15,
17;84:3;88:4
words (7)
27:8,25;45: 13;56: 10;
57:8,18;60:2
work (14)
7:2,6,12, 14,25;8:7,8,
18; 1 0:6;54:2;55:14;
70: 19;84: 19;89:22
worked (3)
32:9;48:9;56:23
worker (1)
54:3
working (2)
(9) survey - working
Desmond, ct at. v.
Narconon, et al.
50:8;69:12
works (1)
84:21
written (1)
3 1: 19
wrong-is (1)
64:17
wrote (1)
30:5
y
yanking (1)
62:13
year (4)
14:23; 16: 1;47: 19;
48:17
years(ll)
II :6,7, 11 ; 14:21,22;
23: 10;30:24;41:4;55: 15;
57: 17;59:7
Yesterday (2)
42:8;52:25
Yuma (2)
7:2,7
0
02 (1)
18:6
04 (4)
15:22,23;17:6; 18:6
OS (8)
18: 13, 14,15, 17;22: 18;
75:4,5,6
06 (2)
18: 1, 15
07 (1)
25:25
1
17th (1)
6:2
1996 (3)
4
1--7_:4_,2_1_;4_3_:2_1 __ ----i 4 (2)
33: 12,15
2
2 (3)
26:2;28: 15,18
2002 (4)
13: 16,24;14: 17,25
2004 (3)
15:1,8, 14
2005 (4)
9:21;11:13;23:3;51 :23
2006 (5)
32:22;33: 1,20;62: 19;
65:6
2007 (14)
13: 19; 19: 16;20:16;
5
5 (10)
23: 13;24:8;34:5, 17;
70: 3,4, 6,25; 71: 1 ;75:8
50-13-18 (1)
63:7
6
6 (4)
80:9;85: 19,23;86:22
7
36: 11,22;37:23,24;39: 19; 1-----------1
65:9;70:8;71: 14;73:6,9;
89:13
2008 (10)
9:23; 11 :13;23:3;37:24;
7 (5)
85:21,24,25;86:6;88: 10
8
43:21;51:10;79: 11 ;80: 11 , t-------------1
14,23 8 (1)
2009 (6) 85: 18
79:14,16,18;84:5,11, 14 1-----------1
2012 (1)
6:2
20th (1)
15:23
23rd (2)
18: 14, 17
24 (3)
21 :8;35:9;39: 12
24-hour (1)
39:9
24th (2)
19:16;89:13
9
97 (1)
48: 17
98 (2)
43: 16;48: 18
----------i 25,000 (1)
1 (6)
13:4, 7,8;36:20;82: 19;
89: 10
10:03 (I)
6:3
100 (3)
32:6;59:23;66:25
11 (3)
69:2,5,5
11:18(2)
81:12, 13
11:25 (1)
81: 13
11:29 (1)
88:6
11:31 (1)
90:20
11:33 (1)
90:22
13 (3)
38:9;75: 1,3
1\Jin-t:-Script
61:7
26th (2)
70:7,12
27th (2)
70: 10,13
290-4-2 (1)
22: 18
290-4-2-05 (1)
75: 14
290-4-2-06 (1)
25:24
3
3 (3)
29:9,12;30:2
30 (1)
55: 15
31-2-6 (1)
63:6
Nina Edidin
February 17, 2012
(10) works - 98

10A28641 2 2012-02-17 DepositionOfNinaEdidin Ocr

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