10A28641 2 2012-03-06 DepositionOfJamesJerryMcLaughlin Ocr

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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 )
PATRICK C. DESMOND, )
Plaintiffs, )
vs.
\
OF. GEORGIA , INC . ,
i; ' DELGADO DEVELOPMENT , INC . ,
\{ SOVEREIGN PLACE , LLC,
) CIVIL ACTION FILE
NO. 10A28641-2
* SOVEREIGN PLACE. APARTMENT
.... \.;.,MANAGEMENT, INC . , LISA
. ':.CAROLINA ROBBINS, M. D . , THE
.,, ROBBINS GROUP, INC. , AND
INTERNATIONAL,
Defendants .
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Video deposition of JAMES JERRY MCLAUGHLIN,
taken on behalf of the Plaintiffs, pu rsuant
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to the stipulations contained herei n , before
Jo Tomoff Fischer , RMR, CCR No . B- 924, at
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880 West Peachtree Street, Atlanta ,
o n Ma r ch 6, 2012, commencing at the hour of
10 : 14 a . m.
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Q&A REPORTING SERVICES, INC.
Certified Court Reporters
2165 Fairhaven Circle, NE
Atlanta, Georgia 30305
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..=:
(404) 233-3_300

Fax (404) 233-1530
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Desmond, et al. vs. Narconon, et al.
Multi-Page TM
James Jerry McLaughlin, 3-6-12
Page 2 Page 4
COlJNS:EL INDEX 70 E.XA.l-tiNATI ON
ON BEHALF OE' THE '!J\1Nl'!FFS : 2
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400 Colony Squa:::-e, suite .900
17.01 P.ftn..cht.ree. St.!:eet, Nl1
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GA 30361
(40!) 9Gi-76oo
OK BEJ!ALJ\' OF T!B DEFENDANTS l!ARCONON OF GEORGI!\
and KARCONON INTERNA't'!ONA! .. :
BARBARA A. 1-tAP..SCHM:K, ESQ.
Ore;.., 3ckl ' Fa,:nh.urn, l if-.1?
880 s;est Peachtree 5-ti.:eet
P .0. Box 7600
Atlanta, GA 30357
(404) 885-1400
OK BE.HALP' OI!' T.l:ill. DELGA:.x>
CAINTN P. YAEGERr BSQ.
DO','Il.ley & "LLP
269 WaRh:1.ngton Avenue
1-la.r:ie tta , GA 30060
(7'10) 422-3233
ON BEHALB, OF THE DEFENDANTS LISA CAAOJ,INh ROBRllTS,
M. D. and. '::'HE R03BIYS GROU!?, INC.;
G. T}\NNER., ESQ .
Yleinberq, l'lbEIEil.er, & OiaL LLC
Suite 2400
334<i Peachtree Road
Atlanta, Gl\ 30326
(404) 876-2700
1 ALSO PRESEU'I'; l?A?RlCT:< KP.NNEDY 1 Legal Technolog y
se.tvices, 770- 554--1633
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EXHIBIT
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!!:mail from ,J. McLaoghlin
to B. Mar:1chalk
Web Si::.e Into !:cr Ftith Drug

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CV I J. life Laughlin.
Web Site :>:.n.ro r.or Haa.rt1a.nd Drug
Reh3b I J , }tr.Laughlin
J . :'1c:I1ilnghlin I . D. Card. I Certified
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J. Mc.:..auqhlin l. D, C-ard I OK
Boar d of l.d<:!ensgd tt.nd
Dru'i
J . ML!Laughl.I. ..JI X:, D. card I Ma:. ter
Ada.ictiO!l9 CO\L-'l.Selo.t
National AS!Jocia.tion of Forens:I.G
counsel ors I Ccrtir.ica tion
Roqui.J.:arw.nts
Web si tc r n fo from Drug
Rehab
.Narconon or Georq.ia.f s First
Supplemental Objcac tions ;u1.d
Response a
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9-11-03 fro::a Dr. Paredes
to G. Smith
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(Origina l Exhibits Nos . 4 through 6
rgtaiDQd by ttlQ witness; cop.tes ttttachAd to t ho
or.:l.g:1,nal transcript and t ransc:t-ipt copie s.
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Page 2 - Page 5

Page 6 Page 8
Q. My name is Jeff Harris; we just met about 30
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l.l.tto.t".aey o U:;>On thei:t: l:'QC01pt Of
THE VIDEOGRAPHER: We'renow on video
record. The date is March 6th, 2012; the
time is approximately 10:14 a.m. This is
tape number 1.
MR. HARRIS: All right. TI1is will be
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the deposition of Reverend James McLaughlin,
taken for all purposes allowed by the Oeorgia
Civil Practice Act. All objections are
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reserved in accordance with the CPA, and in
accordance with the stort -- with the court's
standing order relative to discovery.
Jo, if you would swear in the Reverend,
pleas e.
(Thereupon, the witness was swom.)
MS. MARSCHALK.: Jeff, if we could have
an agreement that the Reverend could read and
sign his deposition.
MR. HARRIS: sure.
JAMES JERRY MCLAUGHLIN,
20 having been ftrst duly .sworn, was examined and
21 testified as follows:
22 EXAMINATION
23 BY MR. HARRIS:
24 Q. Good moming, Reverend.
25 A. Good morning, sir.
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is
seconds ago. ,
A. Yes , sir.
Q. It's my understanding that you have been
designated as an expert witness in this case; is that
correct?
A. Yes.
Q. All right. And you -- you paused for a
while--
A. Yeah; because that word "expert" always mean
different things to different people. Somebody told me
once that the person if you don' t understand the
definition can mean different things. So when you said
."expert," I paused.
Q. Well, do you consider yourself an expe1t in
ai+Y field, sir?
A. Yes, sir.
Q. What fields?
A. Theology.
Q. Okay. And in addition to theology, any other .
fields?
A. Yeah, there are other fields.
Q. If you would, just tell me all the fields that
you consider yourself --
A. All the fields?
Page 9
1 Q. And -- and one thing that' s going to be
2 important in the deposition -- well , let ine back up.
3 Have you ever had your deposition taken before?
4 A. No, sir.
5 Q. Have you ever been designated as an expert
6 witness in any court before?
7 A. No, sir.
8 Q. Have you ever testified at trial?
9 A. Yes, sir.
10 Q. Okay . And what - what trial? Tell me about
11 that.
12 A. Oh. Orlando, Florida, 197-. .. I think it' s
l3 1974, 1975. Trial was dealing with Glenn W. TUt ner
14 versus U.S.A. , United States of America.
15 Q. And what was the nature of your testimony?
16 A. J was president of a corporation, and went on
11 the stand, and-- my memory now. I was asked to -- I
18 answered some questions that was asked. I was the
19 president of a corporation at the time.
20 Q. What-- what was the nature of the case?
21 A. My understanding, it had to do with the
22 chairman of the board of the company. And the nature
23 was that it was a trial that dealt with pyramiding.
24 Which we call multi-level marketing today.
25 Q. Pyramid scheme?
http://Reach cccc ingFor orTheTippingPoint.net
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A. Yeah.
2 Q. Was it a criminal trial?
3 A. He didn't go to prison, so I-- I --I don't
4 know the details.
5 Q. Well, do you know whether it was a criminal
6 trial or a civil trial?
7 A. What's the difference?
8 Q. You go to jail in criminal trials, or there's
Page 12
1 Q. And what I'm trying to do is to determine all
2 of the opinions that you may have as an expert, and what
3 you base those opinions on; do you w1derstand that?
4 A. Yes, sir.
5 Q. Okay. And the purpose is just fairness, so I
6 won't be surprised if we go to trial. You understand
7 that?
8 A. Yes, sir.
9 a threat of you going to jail, and in a civil case it
10 typically deals with money damages or perhaps --
A. Civil. 11
9 Q. Okay. And I'm -- I'm going to assume, when I
10 ask you a question, that you understand my question.
11 Fair enough?
12 Q. Okay. All right. And were you testifying 12 A. Yes, sir .
13 against the individual who had been accused of running
14 some kind of pyramid scheme?
13 Q. If you don't understand my question, please
15 A. No.
16 Q. Do you remember anything else about the case?
14 tell me and I'll rephrase it in such a way that maybe
15 you and I can come to an understanding of what I'm
16 asking. Okay?
17 A. It's vague. 17 A. Yes, sir .
18 Q. All right. 18 Q. When were you -- when were you first contacted
19 A. I'd have to look at it. 19 in this case about potentially being an expert witness?
20 9- And-- and what was the name of it, again? 20 A. February, the-- late January, early February.
21 I'm sorry. 21 Q. Who contacted you?
22 A. It was Glenn W. Turner versus United States of 22 A. Gary Smith.
23 An1erica. I remember that. 23 Q. And who is Gary Smith?
24 Q. Any other testimony that you have given in any 24 A. He' s the executive director of Narconon
25 court proceeding? 25 Arrowhead.
Page 11 Page 13
1 A. No, sir. 1 Q. And I have an E-mail that was provided to me
2 Q. Now, I -- before we started talking about 2 by counsel yesterday. And it ' s on February the 3rd,
3 that, I was sort of cautioning you. This will be a -- a 3 2012; it's from Gary Smith to you.
4 deposition; this lady here, who is very patient, will 4 A. (Witness nods head affirmatively.)
5 take down our exchanges. lt's really important that you 5 Q. Would that E-mail have been around the time
6 l f ~ t me finish my question before you answer. 6 that you were initially contacted about being an expert?
7 A. I'm sorry. 7 A. Yes, sir.
8 Q. That's okay. Just__:_ just s o ~ - she's going 8 Q. Okay.
9 to get frustrated with us if we talk over each -- 9 MR. HARRIS: Let me have a copy of that.
10 A. Okay. 10 MS. MARSCHALK: My secretary just put it
11 .Q. --other. It's-- it's common in conversation . 11 by the door, Jeff. The clean copy.
12 to do that ; -- 12 MR. HARRIS: Yeah.
13 A. Okay. 13 (Discussion Off the record.)
14 Q. --you -- you know what I'm about to say, but 14 THE WITNESS: There you go, sir.
15 for purposes of the record it' s real important for-- 15 MR. HARRIS: r hank you,
16 A. Okay, sir. I apologize. 16 BY MR. HARRIS:
17 Q. My purpose here today is to understand what 17 Q. All right. I'm going to mark this as
18 opinions you may have at the trial of this case; do you 18 Plaintiffs' Exhibit 1.
19 understand that? 19 (Thereupon, marked for identification
20 A. Yes, sir. 20 purposes, Plaintiffs' Exhibit No. 1.)
21 Q. And you have been designated, regardless of 21 BY MR. HARRIS:
22 whether or not you feel comfortable with the term, you 22 Q. Is that the E-mail that- well, let me ask
23 have been designated as an expert witness by the 23 you this. Did that E-mail begin the conversation about
24 attorneys in this case; were you aware of that? 24 you potentially being an expert, or was the.re sud--
25 A. Yes , sir. 25 some other E-mail exchange before that?
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1 A. No, sir.
2 Q. Tell me what Mr. Splith asked you to do; tell
3 me about that conversation.
4 A. Okay. He called me and said that Phil Hart is
5 trying to reach me.
6 Q. And who is PhH Hart?
7 A. Phil Hart is the executive director of
8 Narconon International.
9 Q. And what else did Mr. Smith tell you?
10 A. That was basically it.
11 Q. So he says, "Phil Hart is trying to reach
12 you"?
13 A. (Witness nods head affirmatively.)
14 Q. Anything else?
15 A. "Phil Har t's trying to reach you; they need
16 your help.''
17 Q. Okay. That's tl1e sum total of that--
18 A. Yes. ..
19 Q. -- conversation? All right. Did you at some
20 point talk to Mr. Hart?
21 A. I called -- he gave me the number, I called
22 Mr. Hart, and... I called him. Yes, sir.
23 Q. Okay. And tell me about that conversation,
24 the conversation that you had with Mr. Hart.
25 A. Okay. "Reverend, how you doing: There's
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1 somebody I want you lO talk to. We believe you can help
2 us. "
3 Phil is not a guy of a lot of words, and so I
4 said okay. And I believe at that time he said - no.
5 He said., "Somebody will be calling you. An attorney. "
6 And that was it.
7 Q. He said, "We believe that you can help us"?
8 D1d he explain what it was that he believed you could
9 help with?
10 A. No, sir .
11 Q. So the conversation consisted of "Reverend, we
12 believe you can help us; --" --
13 A. Well --
Page 16
1 A. He may have. He may have. But T -- T - it
2 d i d n ~ t stick wifu me.
3 Q. Okay. So that's the sum total of everything
4 you recall about the conversation with Mr. Hart?
5 A. Yes, sir.
6 Q. Did you discuss your testimony or your-- or
7 your potential expert review of the case; did you
8 discuss that in any more detail with Mr. Hart after
9 that?
10 A. No, sir.
11 Q. Who called you? Or did someone call you after
12 that? --
13 A. Yes.
14 Q. --I assume somebody did 'cause you' re here.
15 A. Yes, sir.
16 Q. Ok.ay. Who called you?
17 A. Barbara.
18 Q. Okay. And tell me about that conversation;
19 what did Ms. Marschalk ask you to do?
20 A. She basically appraised [sic] me, as I
21 remember, of what was -- what was happening. And she
22 said she would be sending -- well, we talked for
23 about -- I guess about two hours. That conversation was
24 about two hours. And so she appraised [sic) me on
25 what-- bow I could help. What I was needed for.
Page 17
Q. Okay.
2 A. And about Narconon of Georgia. And we ta,lked
3 about two hours , iliat was about two hours.
Q. What did you talk about? 4
5 A. What was happening. I can't remember all the
6 things we talked about, but we --
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Q. Tell me -- tell me what you can remember.
A. Okay. As I remember, she told me about the
9 case. And my experience. And my knowledge of -- of
10 materials. And she said she would send me information,
11 and we talked about my background and some of my
12 experiences. And I gave her information where she could
13 get i nformation about me on the Internet. And we talked
14 Q. -- "someone will be calling you"? 14 about the case.
15 A. There -- there was -- there was some . 15 Q. What specifically did you talk about the case?
16 pleasantries, ' cause we hadn' t-- I hadn't talked to 16 Or did you discuss about lhe case?
17 Phil Hart probably in a year. So, I mean ... I'm trying 17
18 to think when the last time I saw him or talked to him. 18
A. Well, the Complaint, I remember that, 'cause
l:!be senl me information on that. But we talked about
19 that. And course material, the eight books that 19
But, yo1,1 know, "How you doing, H "Pine," "How's the wife
20 doing," "Fine, H "I have somebody, attorney, who wants to
21 get up with you," and that was basically it. It wasn' t
22 a long conversation.
23 Q. Did he give you any indication whatsoever,
24 sir, regarding what it was that he believed that you
25 could help with?
Page 14 - Page 17
20 L. Ron -- by L. Ron Hubbanl. And my experience with --
21 with the information. How did I get involved.
22 Q. Anything else?
23 A. Well, there are other things. The main thing
24 was that she said that she would send me information for
25 me to read, and ...
. Desmond, et al. vs. Narconon, et al. Multi-Page
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1 Q. And what were the other things? 1 quite a few rehabs across the country. So as we moved
2 A. The other things? 2 around. So specifically, after the conference, Sunshine
3 Q. I asked you what other topics you discussed, 3 came, picked us up,' and took us out to a farm and showed
4 and you said there were other things. And r was asking 4 us two or three buildings on the farm, and brought us
5 you, sir, what those other things were. 5 back to the -- brought us back to the-- the conference.
6 A. Okay. To be candid with you, it all kind of 6 Q. And you said it was a chmch conference. Was
7 comes together, because in the last-- okay. Let me- 7 it an AME --
8 Jet me see if I can put this. My experience in 8 A. Yes, sir.
9 training. My experience with -- with Narconon. Had I 9 Q. -- conference?
10 ever visited Narconon Georgia. 10 A. Yes, sir.
11 Q. Had you? 11 Q. All right. And at that point in time was your
12 A. Yes, sir . 12 wife the director of Narconon Arrowhead?
13 Q. When? 13 A. No, sir. We-- we were-- we were just
14 A. In March of 2003 . 14 looking-- we were looking for a ministry for my church.
15 Q. Okay. I didn't mean to interrupt you; you 15 And I was impressed about what I had seen.
16 were giving me a list of the other things, which I very 16 Q. At what point in time did your wife become the
17 much appreciate. 17 director of Narconon Arrowhead?
18 A. Okay. What kind of training did I acquire,. 18 A. Let's see. Let's see. This May-- I'm ..
19 what was my experience with Narconon, how did that 19 just -- I've got to backtrack.
20 relate to what I was-- what I'm doing now. 20 Q. Sure. . .
21 Q. Did she specifically tell you what she wanted 21 A. Okay. May of this -- of 200- -- May of 20il
22 you to do for her or to do for her client in this case? 22 was the fifth year, so if we go back five years, 2011
23 A. I believe she did. And-- and -- and -- and , 23 minus five, that would probably-- 2006. I'd say 2000
24 the thing that I remember was the fact that what had 24 [sic]. ..
25 transpired, what had -- what had happened, and why she 25 Q. So it's your recollection as you sit here
Page 19 . . Page 21
1 felt I could be of help. 1 today that your wife became the director of Narconon
2 Q. And I - I'm just trying to understand what 2 Arrowhead in 2006 or thereabouts?
3 she specifically told you that she needed you to do as 3 A. Not the director, now. She was brought in as
4 an expert witness, or a potential expert witness, on 4 vice president of Narconon Arrowhead witha emphasis on
5 behalf of either her or her client. 5 government affairs. Community and government affairs.
6 A. Okay. Orie thing I-- I definitely remember 6 Q. All right; well, then, let' s do it that way.
7 was the fact that I would be utilized to, in a limited 7 If you would, tell me all of the positions and titles
8 way, to deal with course information, and specifically 8 that your wife haS held in any Narconon-af:filiated
9 eight training manuals by L. Ron Hubbard, my experience 9 entity.
10 with the training that I acquired, and how would the 10 A. The only one I know is vice president of-- of
11 training relate to my ministry. 11 Narconon Arrowhead with a emphasis on cornrnunity and
12 Q. All right. Now, when you visited Narconon of 12 governmental affairs.
13 Georgia in 2003, tell me about what you saw; what did 13 Q. Okay. So she was-- 2006, she becomes
14 you do, and what was the purpose of yom visit? 14 vice president at Narconon Arrowhead with the emphasis
15 A. Okay. 2003, there was a church conference 15 that you've described fm me?
16 here in Atlanta. And.there was an employee by the name 16 A. Yes, sir.
17 of Sunshine. Black African-American. And wherever we 17 Q. Is she still in that position?
18 had a church program and wherever there was aNarconon ts A. No, sir.
19 there, we took the opportunity -- when I say "we," my 19 Q. When did she leave?
20 wife and I, took the opportunity of going to see the 20 A. May of last year. May of 2011.
21 facility. We were taken to a fann. And it had 21 Q. What does she do now?
22 connection with the Protestant church, and I think at 22 A. She's retired. She's home with the grandkids,
23 the time we were deciding ... And we just were just 23 and she works -- our son opened a -- a restaurant. And
she's helping her children. 24 investigati.ng and seeing what the Narconons were doing 24
25 in different areas. We understood at that time they had 25 Q. Is that the ref1,Son that she retired, just to
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James Jerry McLaughlin, 3-6-12 Desmond, et al. vs. N a r c o n o n ~ et al.
1 do other things with life?
2 A. In essence, yes, sir.
Page 22
3 Q. What -- which part of it does not fall within
4 that? I mean, just tell me why she left.
5 A. Oh, okay. She made a commitment to them for
6 five years.
7
8
Q. Did she have a five-year contract?
A. Yes.
9 Q. And her contract expired, and so she--
10 A. WeJI, no -- well, let me say this. She signed
11 a two-and-a-half-year contract, and they wanted her
12 to -to stay. And she stayed, but she didn't sign a
13 contract.
14 Q. Is she still on the board or does she have any
15 kind of advisory role at Narconon Arrowhead's?
16 A. No, sir.
Page 24
1 and I'm going from my memory. Sunshine wanted us to see
2 what was going on, and she took us to this location.
3 And what I remember were three -- there were two
4 buildings that I was taken to. And it took about 30 -
5 it took about 45 minutes to a hour to .get there, and so
6 we just saw it and then we had to come back to the
7 conference. So I didn't see anything else but the farm.
8 That was it.
9 Q. All right. What-- what were the buildings
10 used for that you saw?
11 A. One building I saw had bunk beds in it, and I
12 think I -- I know I met two students in that facility.
13 Another building had a sauna in it. And I saw at least
14 one person in the sauna.
15 Q. Was it your understanding that the students
16 were living there at the farm?
17 Q. What about yourself, are you on the board? 17 A. That was my tmderstanding.
18 A. No, sir. 18 Q. And that's consistent with most Narconon
19 Q. Have you at some point in the past been on the 19 programs, is it not?
20' . board of Narconon Arrowhead? 20 A. The -- the programs and the facilities that I
21 A. No, sir. 21 have been to, yes, sir.
22 Q. Any kind-- and by "board," I mean any kind of 22 Q. And you've toned-- you've toured a number of
23 board; any advisory board? 23 Narconon facilities?
24 A. I've been asked for advice, but I don't recall 24 A. Yes, sir.
25 legally written down on any advisory board of -- of 25 Q. And the Narcononprogram, you're-- you're
Page 23 Page 25
1 Narconon. 1 familiar with, obviously, right?
2 Q. And you -- you would agree with me that you 2 A. Yes, sir.
3 have spoken on behalf of Narconon Arrowhead on a number 3 Q. And it's generally designed to be a
4 of different-- 4 residential program, correct?
5 A. Yes, sir. 5 A. Generally.
6 Q. -- occasions? And you have -- 6 Q. Okay. Are you aware of-- tell -- tell me the
7 A. Excuse me, I'm sorry. 7 locations that you know of where N arconon runs a program
8 Q. You-- you have allow Narconon Arrowhead to 8 in the United States where there is not a residential
9 put your-- your image and some of your quotations on 9 component to it, where it's strictly outpatient.
10 their web site from Lime to time, have you not, sir? 10 A. Yes, sir. St. Petersburg, Florida. The
11 A. Yes, sir. 11 executive director' s name is Alderman. (Pronouncing)
12 Q. Okay. And you-- you've spoken at public 12 Alterman. I visited-- we had a church conference in
13 events on a number of occasions about your belief that 13 Orlando, Florida, and I visited that facility. It's the
14 the Narconon program is effective, have you not? 14 first outpatient facility that I had heard of at the
15 A. Yes, sir. 15 time that I visited.
16 Q. Okay. And you've done that for a number of 16 Q. When did you visit that?
17 years? 17 A. Let me think. Let me give you a window,
18 A. Number of years, about ten. 18 'cause I --
19 Q. All right. Now, backing up to this 2003 visit 19 Q. That's fine.
20 to Narconon of Georgia, do you recall whether or not 20 A. -- can't specifically answer your question,
21 there were -- was there a residential component? 21 but I'll -- I'll come to it.
22 A. Excuse me. 22 Q. Okay.
23 Q. Are you okay? 23 A. It had to be between 2004 and 2006. It had to
24 A. Yeah, I'm fine. [just-- no, just belch. 24 be between 2004 and 2005. It's-- it's corning closer,
25 At the time, a lot of things were going on, 25 but. ..
Page 22 - Page 25 Q&A REPORTING SERVICES, INC.
Multi-Page
1
'M
Page 26 Page 28
Q. All right. And any other Narconon programs, 1 other thing that was different was --for me, that
2 other than the St. Petersburg one that you've told me 2 caught my attention, was the cost. And --
3 about, that are outpatient? 3 Q. Cheaper?
4
5
6
7
8
9
A. At the time-- 4 A. Yes, sir.
Q. I'm -- 5 Q. Because there wasn' t a residential component?
A. --that-- 6 A. Yes, sir. Now, when-- when-- when you say
Q. --talking about-- 7 "because there wasn't a residential," yes, sir. It was
A. Throughout the system? 8 more tailored to the students, and the student was not
Q. --your --your-- your total knowledge of-- 9 in a con -- confined environment.
10 of Narconon programs at any point in time, and we'll 10 Q. And when you say "confined envirornnent," are
11 drill down on the date. 11 there other Narconons where the student is in a more
12 A. Okay. 12 confined environment?
13 Q. But other than the St. Petersburg one that you 13 A. Yes, sir.
14 told me about, are there any other Narconon programs 14 Q. Give me some examples of programs where the
15 that you're familiar with that are outpatient prognuns? 15 students are in a more confined environment.
16 A. No, sir. 16 A. Up until200- --the date that I gave you, I
17 Q. Was there. something in particular about the 17 had never been exposed to an outpatient facility like
18 St. Petersburg program that was different or sort of 18 the one I told you about. And in an outpatient facilily
19 triggered your memory be-- because of this outpatient 19 that I was e:x.posed to, the students stayed where they
20 aspect of it? 20 lived or somewhere else; it was -- I never saw a
21 A. Yes, sir . 21 facility for them to stay in in an outpatient program.
22 Q. Did they -- did they have to do something 22 The whole definition that I understand outpatient would
23 different, I guess is my question, in terms of the 23 be is so the person could receive services and still
24 curriculum? 24 function in society.
25 A. Yes, sir. When I say "Yes, sir," I'm saying 25 Q. Well, are you familiar with the Narconon of
Page 27 Page 29
1 yes, sir, they had to do something different. 1 Georgia program?
2 Q. If it was a compound-- t h a t - ~ that's a 2 A. Yes, sir.
3 perfect e:x.ample of a compound question that you were 3 Q. Is it an outpatient or a residential program?
4 asking -- you were answering part of it. So what did 4 A. To my knowledge and what I've acquired and
5 they have to do different? 5 what I've heard since I've -- since I've been involved,
6 A. Okay. What I visited was a facility that was 6 from the initial phone call that I receive, I understand
7 set up differently than the residential facility that 7 what I've read, that it's a outpatient program.
8 I'm familiar with, i.e., Narconon Arrowhead. That was 8 Q. And who told you that?
9 the first time I had seen and actually visited a 9 A. Attorney, Barbara. And what I read.
10 outpatient facility, and it was first class. 10 Q. And what have you read?
l1
12
Q. Tell me about it. How was it run? 11 A. The Complaint, the-- Dr. Kent's deposition.
A. They met the requirements of the State. It -- 12 Q. Do you believe that Dr. Kent's deposition
13 persons came .in to receive the service, and they did not 13 discusses the issue of whether or not Narconon of
14 stay on the facility. Is that more... 14 Georgia is an outpatient versus a residential facility?
15
Q. Yeah. 15 A. Rephrase that. Would you give me that again,
16 A. Okay. It had a-- it had the books, the eight 16 please?
17 books. It was a curriculum set up for persons to come 17 Q. Well , I mean, is it your-- is it your belief
18 and leave. 18 that Dr. Kent's deposition discusses the issue regarding
19 Q. Was there something different about the way
20 the curriculum was set up to allow people to come and do
21 the curriculum and leave?
22 A. Yes, sir. In the sense that you had students,
23 or you had people to come to be served, who were in
24 school, who had a job, and they were serviced at
25 different times doing the -- doing their program. The
19 whether or not Narconon of Georgia is nm as a
20 residential versus outpatient facility? Is that where
21 you're getting that from?
22 A. No, no. I got that from the attomey.
23 Q. Okay. And -- and then you went on to say that
24 you relied in part on Dr. Kent's deposition?
25 A. Well, you-- you asked me what I read. And
Page 26 - Page 29
James Jerry McLaughlin, 3-6-12 Multi-Page TM
Page 30
1 I've -- I recall -- I recall that. The main thing I 1
2 remember about Dr. Kent is dealing wi th the course 2
3 material. 3
4 Q. Yeah; we --we' ll get to that-- , 4
5 A. Okay. 5
6 Q. -- and I - ~ I want to be clear. It's your 6
7 belief that Narconon of Georgia is --is nm as an 7
8 outpatient facility; is that correct, sir? 8
9 A. That's my understanding, sir. 9
10 Q. Okay. And I was asking you where you got that 10
11 understanding from. 11
12 A. I got that understanding clearly from the 12
13 attorney. 13
14 Q. All right. And then you I think referenced 14
15 Dr. Kent's deposition, and I just wanted to be clear; is 15
16 there something in Dr. Kent's deposition that made you 16
17 believe that it'was an outpatient facility? 17
18 A. Let me -- let me -- and -:- I remember reading 18
19 the Complaint. It was in the Complaint. So I might 19
20 have said that, but let me change that and say I know it 20
21 was in the Complaint, and I knew I heard it from the 21
22 attorney. Now, I focused -- and I mentionedhim because 22
23 that's the only other thing -- only three documents I'ye 23
24 read, and 1 thought that it could have been in there. 24
25 But l'm certain about the attorney and the Complaint. 25
Page 31
Q. That's - that's what you've reviewed?
A. Yes, sir.
Q. Did you ask for anything else?
A. Not from-- from-- from who?
Page 32
Q. From -- from the attorneys that retained --
A. No, sir.
Q. --you. Were you aware that there were more
file materials other than that?
A. J was told and I was informed that my opinions
and experience would be very limited, and so I felt
comfortable in terms of -- of -- of what I felt
comfort -- well, I felt comfortable in terms of what I
knew I could share. My experience, what I knew about
the course work.
Q. So you let the lawyers p i ~ k the materials that
you reviewed?
A. Yes, sir .
Q. And you relied on the lawyers to pick the
materials that you were going to review in connection
with your testimony?
A. Yes, sir.
Q. And you haven't asked for anything else?
A. No, sir.
Q. Has anybody told you what other depositions
are available?
Page 33
1 Q. Okay. So then you're-- you're relying for 1 . A. I was told, sir, that there's a preponderance
2 your opinion that it's an outpatient facility, then, on
3 the Complaint and the conversations -
4
5
6
A. Yes, sir.
Q. -- that you've had with the attorney?
A. Yes, sir.
.7 Q. So it's your belief, then, that the Complaint
8 in this case indicates that Narconon of Georgia was nm
9 as an outpatient facility?
10 A. That 's my understanding, sir.
11 Q. Ok11.y. Have you done any independent
12 investigation to determine whether or not it is in fact
13 an outpatient facility?
14 A .. No, sir.
15 Q. Have you looked at any of the depositions of
16 the students?
17 A. No, sir; I've only looked at what was given to
18 me.
19 Q. Okay. Let me-- and let me back up: I think
20 you were very clear about that. The only thing that you
21 have looked at, as l understand it, in connection with
22 your opinions here today is the Complaint, the
23 workbooks, the smdent workbooks, and the deposition of
24 Dr. Kent?
25 A. Yes, sir.
Page 30- Page 33
2 of material. And I just -- I surmised and I was told
3 the length of this whole process, and so I surmise that
4 . there are materials that I wasn't -- that I wasn't
5 privileged to or mentioned because it wasn't necessary.
6 I felt. I '1eeded it.
_7 Q. Yqu've said several times in your deposition
8 thus far that you believe that your testimony is going
9 to he limited. Do you recall using that word?
10 A. Yes, sir.
11 Q. What did you mean when you said --
12 A. Okay.
13 Q. -- "limited"?
14 A. Limited in the sense that if you say the word
15 "expertise," that my expe1tise that I feel would be in
16 the area of L. Ron Hubbard's material, how that material
17 is used in my ministry, and can other persons use the
18 material in their ministry.
19 Q. All right. So you believe your testimony,
20 then, is limited to those tbJ:ee categories that you've
21 outlined for me?
22
23
24
25
A. Yes, sir.
Q. Do you have a CV?
A. A C . .. ?
Q. A cv, a resume?
Multi-Page TM
Page 34
1 A. Yes, sir.
2 Q. Okay. Were -- were you asked to provide that?
3 A. It's on - it's on the -- it's on the
4 Internet.
5 Q. Okay. I mean, were you asked to provide that
6 by your attorneys?
7 A. No.
B Q. Okay. I found-- I'm going to go ahead and
9 mark --
10 . (Thereupon, marked for identification
11 purposes, Plaintiffs' Exhibit Nos. 2
12 through 4.)
13 BY MR. HARRIS:
14' Q. -- Plaintiffs' Exhibits 2, 3 and 4.
15 A. This is for me, sir?
16 Q. Yes, that's for you.
11 A. Okay.
18 MS. MARSCHALK: which one is this, Jeff?
19 This is 3?
20 MR. HARRIS: I think that's 3, yeah.
21 .BY .MR. HARRIS:
22 Q. I've handed you 2 --
23 MR. HARRIS: Did I give you the other
24 one?
25 MS. MARSCRALK: No.
Page 36
1 A. That's No. 2. "Doctoral candidate, degree
2 expected 2009." That's not accurate.
3 Q. Yeah, and I saw that. You've moved it up to
4 2012, your expectation of your- of yom doctorate?
5 A. Yes, sir.
6 Q. Okay. And I think one of your cvs has that on
7 there, it just says "Expected 2012"?
8 A. Yes, sir.
9 Q. Didn't-- didn't get your Ph.D. when you
10 thought you were going to, it took a little bit longer?
11 A. Yes, sir.
12 Q. Fair enough.
13 A. And it's still taking longer; it started out.
14 at 2004.
15 Q. How far along are you on it?
16 A. I'm writing my dissertation now. Finally.
17 Q. Have you completed all your course work?
18 A. I have two -- I have one more elective to
19 take.
20 Q. And what is your Ph.D. going to be in, sir?
21 A. Sir, it' s not a Ph.D., it's a doctor of
22 ministries in professional ministry. It's a -- what you
23 call a doctor of ministries at Perkins School of
24 Theology.
25 Q. How is it described on your resume?
Page 35 Page 37
1 MR. HARRIS: I'm sorry. 1 A. I'm looking at 3. On 2 it says "Doctoral
2 THE WITNESS: Here's. .. 2 candidate."
3 BYMR. HARRIS: 3 On 3, "Doctoral candidate. "
4 Q. 2 is in there. 4 Q. And -- and what is the degree in, again, I'm
5 A. Yeah. 5 sorry?
6 Q. They're consolidated in. .. 6 A. Yes, sir. It's a-- i t' s a degree-- the
7 A. Okay. 7 emphasis is in evangelism. And the degree is what --
8 Q. All right. I've handed you Plaintiffs' 8 it's a tenninal degree, but it's called doctor of
9 Exhibits 2, 3 and 4, which are cvs or bios -- 9 mini stries .
10 A. Uh-huh (affirmative). 10 Q. Which of the three exhibits that I've given
11 Q. -- that -- that we have obtained off of your 11 you that reflect your various bios and your cvs, which
12 web sites? 12 would you describe as the most current?
13 A. Yes , sir. 13 A. Okay. I would say No.4 would be the most
14 . Q. Do you recognize Exhibits 2, 3 and 4? 14 current one, sir.
15 A. Yes, sir. 15 Q. Can I see No. 4? --
16 Q. Are those the cvs or resumes that you just 16 A. Yes, sir.
17 told me about that are available on the Intemet? 17 Q. -- Just which one you're looking at?
18 A. Yes, sir. 18 MR. HARRIS: Barbara, can you hand me
19 Q. I want you to take a look at Plaintiffs ' 19 that? It's No. -never mind. I got it
20 Exhibits 2, 3 and 4 and tell me whether or not you 20 right here. I thought l gave you my only ...
21 believe that the information contained in those bios and 21 BY MR. HARRIS:
22 reswnes are accurate. 22 Q. There we go.
23 A. On Page 2 of 5, "Postgraduate Studies," that's 23 A. Okay.
24 not accurate. 24 Q. All right . So No. 4, in your opinion, then,
25 Q. Which exhibit is that, sir? 25 is the most current bio and CV?
James Jerry McLaughlin, 3-6-12 Multi-Page TM Desmond, et al. vs. Narconon, et al.
Page 38 Page 40
1 any -- any other courses that -- I'm talking about your
2 academic work, where you're dealing with the issue of
3 drug and alcohol counseling. Or drug and alcohol
A. Yes, sir.
2 Q. All right. Let's -- let's walk through. some
3 of the stuff on yom cv. Your -- what was your
4 undergraduate degree in?
5 A. Business administration, with a minor in
6 economics.
7
8
9
10
Q. And what was yam master's in?
A. Master's of theological study.
Q. And your doctotal work is in evangelism?
A. Yes, sir.
11 Q. Do you have any academic degrees in -- that
12 relate to drug and alcohol counseling or counseling in
13 general?
14 A. License and cer -- that would not fall under
15 the category of what you're asking.
16
17
Q. Right.
A. No.
18 Q. So none of yom academic training is in the
19 area of counseling and specifically in drug and alcohol
20 counseling?
21 A. Excuse me, sir. In-- in-- in master's of
22 theological studies c;ourse work, we do what you call
23 pastoral cotmseling, yes, sir. Lay counseling, yes,
24 sir. That's a part of the theological training.
25 Q. Sure; I understand that, and I was going to
Page 39
1 ask you about that. I mean, is-- being a minister,
2 . you're routinely required to counsel --
3 A. Yes, sir.
4 Q. -- your parishimiers for various things?
5 A. Yes, sir.
6 Q. And you receive training in that?
7 A. Yes, sir.
8 Q. And you receive some training in that for
9 your-- both your master's and did you receive any
10 additional training for your doctoral work?
11 A. Yes, siT.
12 Q. Of tl.il;t counseling training that you
13 receive--I'm talking about academic counseling
14 training--
15 A. Uh-huh (affirmative).
16 Q. --did any of that training specifically deal
17 with people who are suffering from addictions?
18 A. Yes, sir.
19 Q. All right. Can you-- can you identify the
20 courses for me that you've taken that deal with the
21 issl!e of addiction.
22 A. In-- there's a course in psychotherapy.
23 Q. In your master's work?
24 A. This is -- yes, sir. Uh-huh (affumative).
25 Q. Okay. So there's a course in psychotherapy;
Page 38 - Page 41
4 treatment, or any -- any issue whatsoever academically
5 that deals with drug and alcohol issues, as broad as I
6 can make it.
7 A. The --the whole -- the-- the whole reason I
8 went into the doctoral program, sir , under evangelism is
9 because I wanted to focus on substance abuse and
10 addiction. And the closest thing academically that I
11 . could get to that was in the area working on my
(2 master's. You-- we had said earlier, I seem to be
13 dates; I had a problem in terms of getting my
14 academic advisor to approve my title on my dissertation,
15 which is "Introduction to Biblical and Theological
16 Ministry." And that should say for caregivers "in the
17 context of addiction." And --
18 Q. You're referring to your mas-- your-- your
19 dissertation for your master's degree?
20 A. No, sir. This is -- this is for - this --
21 no. I already got a master' s degree. This --this --
22 that title is for the dissertation for my doctorate.
23 Q. Are you talking about the first page of
24 Exhibit 4 tmder "Education," the first bullet point?
25 A. Yes, sir.
Page 41
1 Q. Okay. Then --
2 A. That -- that shoUld -- that should not be
3 there.
4 Q. Okay. So, I mean, it is under your master's
5 bullet point, so you understand my confusion?
6 A. Yes, sir. I see. I see. In fact, I didn' t
7 realize that until you asked that question, you pushed
8 that question. And -- and really that does not apply to
9 my master's. I've already secured that and I've already
10 satisfied that. But this title is related -- this is
11 the dissertation title for my doctorate. Master's --my
12 doctorate degree, doctor of ministries. And that's
13 my --that's my dissertation. And that 's what
14 stmggle --the snuggle was for me, that took so long.
15 From 2004 now to 2012.
16 Q. And you said you had some issue with your
17 academic advisor approving your dissertation title; tell
18 me what that issue was.
19 A. When I -- the issue was that the advisor
20 didn't feel qualified to help me in the area that I had
21 selected. And in order for me to start writing the
22 dissertation I had to have an advisor, and the advisor
23 had to come from the school in which I was matriculating
24 in. And so I missed a year trying to get_ the advisor .
25 And I asked the advisor to reconsider , and they stayed
. -...

Page 42
1 fast to that. - However, this past June, in 2011, I did
2 find an advisor who -- at the -- at the seminary, or
3 school of theology, that accepted. And once that was--
4 once I got an advisor and the advisor approved the
5 title, then I could start writing.
6 Q. All right. Well, let's back up. We were
Page 44
1 this course in psychology, was it a required couise, or
2 was it something that was a graduate-level course that
3 you had input into what you were studying?
4
5
6
A. I had input to what I was studying.
Q. Okay. Do you know what the course was called?
A. I can't pull it up right now, but there's--
7 talking about your master's, and what I was asking you 7 I'm trying to think of the book. I know the author's
name. It was in the area of pastoral counseling. I'll
have to get you that information. I don't have it.
8 about was academic course work, whether it comes from 8
9 your undergraduate, master's or doctoral work, that 9
10 focused specifically on the areas of drug and alcohol 10 Q_ Okay, now I'm confused_ Was this a pastoral
counseling course, or was it a course dedicated to
psychology?
11 rehabilitation. 11
12 Thus far you have identified for me a course 12
13 that you took in psychotherapy related to your master's 13 A. It was a pastoral counseling course. And in
14 work. Are there any additional courses beyond the one 14 the pastoral counseling course there was cliapters on
psychotherapy, because it was dealing all with substance
abuse. The whole reason for my professional training
was to get courses as close to substance abuse,
addictiop, as possible.
15 that you have identified for me? 15
16 A. No, sir. 16
11 Q. Now, the course that you've identified for me, 17
18 I assume that one part of the course was related to drug 18
19 and alcohol counseling, because the course itself was in
20 psychotherapy?
21 A. Yes, sir.
22 Q. Is that fair?
23 A. Yes, sir.
24 Q. What -- how long -- how long in this course on
25 psychotherapy, how long was that course devoted to the
Page 43
1 specific issues of drug and alcohol counseling or
2 rehabilitation?
3 A. I'd say most of it, because my-- my whole
19 Q. Right. Other than that course, any other
20 courses that -- that specifically academically dealt
21 with substance abuse, drug and alcohol reha --drug and
22 alcohol rehabilitation center?
23 A. No, sir.
24 Q. Okay. Do you consider yourself an expert in
25 drug and alcohol rehabilitation?
1
Page 45
A. Based on the things that I've experienced with
2 the training that I've received, I feel comfortable in
3 saying I'm an expert.
4 focus was in the area of my interest, and my focus was 4 Q. In what regard? Describe for me what you
5 believe your expertise is in drug and alcohol 5 in the area of substance abuse.
6 Q. Well , was this a self-directed graduate-level
7 course where you identified the curriculum that you
8 wanted to focus on?
9
10
11
Do you understand my question?
A. Give me -- give it to me again.
Q. Well, there are certain required courses in
12 order--
13 A: Yes, sir.
14 Q. -- to obtain your --your master's of
15 theology?
16 A_ Yes. Yes, sir.
17 Q. And then there are certain graduate-level
18 courses that you presumably have some input in what the
19 course is about?
20 A. Yes, sir.
21 Q. That's what I'm trying to get at.
22 A. sir. Okay. I w1derstand you. --
23 Q. Was--
24 A. -- Okay.
25 Q. -- the course that you're talking about here,
6 rehabilitation.
7 A. Counseling, coaching, basic --basic
8 withdrawal from substance abuse program.
9
10
Q. All right. That it?
A. Yes, sir.
11 Q. And what-- what specific-- what specifically
12 in your cv can you point me to that will direct me to
13 where either received training or education in
14 those three areas that you just identified for me?
A. Other than academically? 15
16 Q. Well, anywhere. We've talked about
17 academically.
18
19
20
21
22
23
A. Okay. Okay. The license ...
MS. MARSCHALK: I think your license was
on the first page.
THE WITNESS: Oh, okay.
. MS. MARSCHALK: Underneath the ...
THE WITNESS: Oh, okay. Okay, here they
24 are, sir.
25 BY MR. HARRIS:
Page 42 - Page 45
http://Rea eachingForTheTippingPoint.net
Multi-PageTM
Page 46 Page 48
1 the way, is it James Jerry or Jerry James McLaughlin? 1 Q. I'm sorry, Reverend, where are you reading
2 from?
3 A. On No.4.
4 Q. 4. Thank you.
5 A. Just-- what I'd like to do, sir, is give a
6 little information leading up to this question, if I
7 may.
8 Q. Sure. I'm going to --just-- I don't want--
9 you can do -- you can explainbowever you want to
10 explain it; I'm going to walk you through each one of
11 your licenses --
A. Okay. 12
13 Q. --and we're going to talk about those
14 individually, if that gives you some comfort.
2 A. JaJ?es Jerry.
3 Q. Okay. I've seen it both ways.
4 A. Yeah. Well, it's James Jerry.
5 Q. All right. There is a paragraph here that
6 identifies what it is that you're being disclosed as an
7 expert in.
8 A. Yes; sir.
9 Q. Did you have any involvement in writing that
10 paragraph?
11 A. Yes, sir. I believe I did.
12 Q. Tell me what your involvement was.
13 A. When -- on the phone, during the two-hour
14 discussion, when we were dealing with Narconon of
15 A. Okay. Okay. Well-- okay. One of the things 15 Georgia, Narconon lntemational and Narconon Arrowhead,
16 when I started the doctoral program back in 2004, I 16 I receive experience training at Narconon Arrowhead.
17 realized that I was acquiring book knowledge, but the 17 I've never received any tTaining at Georgia. I'm
18 experience part was what I needed too. So the dates on
19 these licenses was after and around the same time I
20 started my doctoral program because, as I looked
21 academically at the material in the schools that was
22 available, I didn't see all that I needed. And so what
23 I attempted to do was to go through the process and get
24 additional training and information in the area of
2.5 counseling, the licensed counselor in the State of
18 familiar with the procedures because I speiJ.t the time
19 there, volunteered there, was trained there, in the
20 area, and that' s what I felt comfortable in.
21 Q. Okay. And what I want to focus in on here --
22 we're going to talk about all these various opinions
23 that you have, but I want to start, if I can, here at
24 the end. One of your opinions is that the N arconon
25 materials are effective -- quote, "effective in
Page 47 Page 49
1 Oklahoma and Texas, the certified pastor, and the master 1 educating and rehabilitating people who are addicted to
2 addiction. Now, basically, these were supplied based on 2 drugs' and alcohol''?
3 what I brought to the t ~ b l e ; the training that I had 3 A. In my experience, yes, sir.
4 received gave me certain titles that are here. But the 4 Q. Okay. So you -- you have the expert opinion
5 license was --required training. The -- I had a 5 that the Narcouon program is effective at educating and
6 master's degree, so it entitled me for the diplomat of 6 rehabilitating people who are addicted to drugs and
7 the board. I had a master's degree academically, so 7 alcohol?
8 that entitled me to the master addiction counseling. 8 A. Those people I've been exposed to, yes, sir.
9 The certified pastoral also was a result of I was in 9 Q. Now I want to focus on your -- your training
10 theology and I had a master's degree. 10 and your education that allows you, in your opinion, to
11 Q. All right. Well, let's back up and do it this 11 give the opinion that something is effective at
12 way. Your -- you have been disclosed as an expert in 12 educating and rehabilitating people who are addicted to
13 this case, and there is a document that I'm given that's 13 drugs.
14 called an expert disclosure. Are you familiar with 14 A. Uh-huh (affirmative).
15 that? Have you seen the expert disclosure? 15 Q. Now, we have -- we have gone through your
16
17
18
19
20
A. No, sir.
MS. MARSCHALK: Yes, yes, he has.
got it right ill front of him.
THE WITNESS: Oh, J'm sorry.
MS. MARSCHALK: It's this.
21 THE WITNESS: Oh. Okay. Yes, sir.
22 BY MR. HARRIS:
He's
23
24
25
Q. All right. And if you'lllook at Page 4, --
A. Uh-huh (affirmative).
Q. -- B, Reverend Jerry James McLaughlin-- by
Page 46 - Page 49
16 academic credentials.
A. Yes, sir. 17
18 Q. And you liave identified for me the one course
19 in your master's program that dealt with drug and
20 alcohol issues, have you not?
21 A. Yes, sir.
22 Q. And there are no other courses that you have
23 identified for me that deal specifically with .drug and
24 alcohol rehabilitation and education, correct? .
25 A. Yes, sir.
http:///R //// eachingForTheTippingPoint.net
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2
3
4
5
Page 50
Q. Correct as in, the way I said it was right?
A. Yes, you were right.
Q. Okay.
A. Based on what you said.
Q. All right. So is there anything else in your
Q. Thank you.
2 A. Yes, sir. Licensed alcohol and drug
3 counselor, Oklahoma Board of License.
4 Q. And that's the LADC, -
' 5 A. Yes, sir . .
Page 52
Q. -- I believe it's called? 6 academic training that you can point me to specifically 6
7 where you were educated in some way about the 7 A. Yes, sir.
8 effectiveness of drug and alcohol rehabilitation
9 programs?
10
11
12 .
13
A. Yes, sir.
Q. Tell me what that is.
A. Okay. Prior to going to seminary, getting a
master's degree, I pastored ten years before going to
14 seminary.
15 Q. And -- and I appreciate that, sir, but that' s
16 just --.that's real-world experience. Which may be very
17 important, but I wanted to focus on the academic.
. t8 A. Okay. Well, other-- other-- other than
19 that. That -- that -- that's it, academically.
20 Q. And my question I think was very specific.
21 With respect to your academic training, --
22 A. Yes.
23 Q. -- can you point me to anything other than
24 what we've talked about, other than that one course,
8 Certified pastoral counselor.
9 I'm also certified withdrawal specialist.
10 Q. A certified withdrawal specialist?
11 A. Specialist.
12 Q. Is that on your cv anywhere? --
13 A. No.
14 Q. -- Or your resume?
15 A. It' s on one of them, but I -- I haven't seen
16 it, but that's a --
17 Q. Take a look there and tell me if you see it on
18 any of those --
19 A. Okay.
20 Q. -- three cvs I've given you.
21 A. Okay.
22 No, it's not on here. It's not on.
23 Q. All right. What's it called, again?
24 Certified -
25 where you have academically studied drug and alcohol 25 A. Certified withdrawal specialist. That's
Page 51
1 rehabilitation. Education. Rehabilitation education
2 issues.
3 A. No, I can't point you academically to any.
4 Q. All right. And we'll talk about your
5 real-woild experience --
6
7
A. Okay.
Q. -- in a little bit.
A. Okay. 8
9 Q. The next thing I would like to move to is, you
10 do have, do you not, sir, some certifications related to
1 1 drug and alcohol rehabilitation?
12
13
A. Yes, sir.
Q. All right. And I'd like to walk through
14 those.
15 A. Okay.
16 Q. Tell me all of the certifications that you
17 have that you believe qualify you to give an opinion
18 about the effectiveness of a drug and alcohol
19 rehabilitation progran1.
20 A. License.
21 Q. And l appreciate the clarification. I said
22 certifications, but I really meant any licenses--
A. Ucense, yes, sir. 23
24 Q. -- or certifications.
25 A. Yes, sir.
Page 53
1 training that Narconon provided.
2 Q. All right. But just-- just so the record's
3 dear, I' ve given you three different cvs and three
4 different bios, and certified withdrawal specialist is
5 referenced nowhere in any of those three?
6
7
8
A. No, it's not.
Q. Why not? Why didn' t you put it on there?
A. Well, let me say this; I'm not that proficient
9 in -- in putting these things together. Somebody does
10 it for me. And I can tell you that, just looking at it,
11 some of it's outdated. You asked me which one is the
12 most current one, and I told you which is the most
13 current. But they --they need to be-- they need to be
14 updated.
15 Q. All right. LADC is number one, the CPC is
16 number two, the certified withdrawal specialist is
17 number three; tell me any other certifications or
18 licenses that you believe allow you to give the opinion
19 that a drug and alcohol rehabilitation program is
20 effective.
21 A. That's all the certifications that I -- that I
22 have, sir.
23 Q. All right. I'm going to go through each of
24 these. Let's take a little break.
25 UIE VIDEOGRAPRER: Going off video
Page 50 - Page 53
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1
2
3
record at 11:31 a.m.
(Recess at 11:31, resumed at 11:44.)
THE VIDEOGRAPHER: We're now back on
4 video record, 11:44 a.m.
5 BY MR. HARRIS:
Page 54
6 Q. All right, Reverend, we're back on the record.
7 What I'd like to do now is walk thr.ough your
8 certifications and licenses.
9 A. Okay.
10 Q. I believe when we broke you had identified
11 three of them for me?
12 A. Yes, sir.
13
Q . .AJ:e there-- are there any other
14 certifications or licenses, whether they be on your--
15 your cv or not, that you believe have educated you or
16 provided you with knowledge that helps you give the
17 opinion what -- that a drug and alcohol program is or is
18 not effective?
19 A. That's it, sir.
20 Q. All right. Let's start with the first one.
21 The LADC. And I believe that stands for licensed
22 alcohol and dmg counselor?
23 A. Yes, sir.
24
25
Q. Now, that is a-- that is a Narcononlicense?
A. No, sir.
Page 55
1 Q. It is not?
A. (Wimess shakes head negatively.) 2
3
Q. Okay. Tell me-- tell me what the certifying
4 agency is for that, for the LADC.
5 A. The -- the State of Texas and the State of
6 Oklahoma. You -- in order to be licensed, you must meet
7 certain requirements of the State of Texas and of the
8 State of Oklahoma. In this particular case, the State
9 of-- well , those-- yeah, those two states. And you
10 must, eve1y -- every year, you must upgrade yourself in
11 continuing education; you must attend workshops that
12 they have in order to keep it current. So every year I
13 have to have additional 20 CEUs , continuing education
14 units, to be recertified for the following year. That's
15 required in both the state. When I applied for non--
2
3
4
5
6
7
Q. Well, some-- some statute --
A. Yes.
Q. -- or some legal requirement?
A. Yes. Yes; --
Q. Which I don't know what it -
A. --it's a legal requirement, yes, sir.
Q. All right. But is that -- is that license
Page 56
8 dependent upon one of these other two certifications
9 that you've got?
A. No, sir. It's independent of that. 10
11 Q. All right. So tell me again specifically what
12 you have to do in terms of academic credentials or
13 training or testing in order to receive the LADC.
14 A. Okay. You must-- number one, you must have
15 academic credentials. If you have a bachelor's degree,
16 if you llave a master's degree, that counts, and then you
17 must take additional training that they require that you
18 take. And you're recognized by the State. You cannot
19 practice, counsel, if you d o n ~ t -- if you're not -- if
20 you're not licensed.
21 Q. Well, the fact that you have a master's in
22 theology, what does that get you in terms of the
23 license?
24 A. Well, in theology, one of our major tools
25 in -- in -- in theology, or when I say theologian, as a
Page 57
1 theologian, is training that has to do with counseling.
2 One of the major tools in what we call the profession or
3 the craft is listening, interpreting. Let me say tllis.
4 Listening, counseling and coaching.
5 Q. I - that was a bad question, and you're --
6 you're obviously interpreting it differently than I
7 meant it. What I was trying to ask is, the -- the
8 requirements in order to get your license, your LADC, --
9 A. Uh-huh (affitmative).
10 Q. -- under Oklahoma or Texas law, one of the
11 things I think you told me was that you. had to have some
12 academic backgrmmd?
13 A. Yes, sir.
14 Q. Correct?
15 A. Yes, sir.
Q. And so one of the things that you relied on 16 I'm sorry. In Texas when I applied for faith base, the 16
17 State of Texas said you cam1ot practice unless you -- 17 was your master's of theology?
18 unless you have that kind of certification. And also in 18
19 Oklahoma. That's the license, and that' s by the State. 19
20 Q. All right. So you're a licensed alcohol and 20
21 drug counselor by the States of Oldahoma and Texas? . 21
A. Yes, sir. 22
Q. And that is under some scheme under Oklahoma 23
24 or Texas law that allows you to be licensed as such?
22
23
24
A. Yes, sir.
Q. ln order to receive this LADC?
A. In order to qualify, yes, sir, for the
license, yes, sir.
Q. All right. In order to qualify?
A. Yes , sir.
Q. All right. In addition to the master's
25 A. When you say "scheme" ... 25 degree, which I think we've talked about, what
Multi-Page-rM
Page 58
1 additional -- specifically what additional training or
2 testing did you undergo --
3 A. I understand.
4 Q. -- in order to get the LADC?
5 A. Yes, sir. There was a curriculum, there was
6 reading material and there was testing.
7 Q. And who administers the curriculum?
s A. The State, and who they designate to do the-
9 the training.
10 Q. Well, do you know whether or not it was the
11 National Association of Forensic Counselors?
12 A. That's - that's separate than the State.
13 Q. Okay, Separate how? Is that a separate
14 license that --
15 A. Yes, sir.
16 Q. -- is regulated --
17 A. Yes, sir.
18 Q. Which of your licenses, then, is regulated by
19 the National Association of Forensic Counselors?
20 A. I got my card on me, I got-- it may not be on
21 there.
22 That's a -- that's a separate-- this is what
23 you're referring to. That's a separate certification.
24 This is the certification for the State.
25 . Well, I won't take it out there. You can look
Page 59
1 at it. That's the State.
2 Q. All right.
3 MR. HARRIS: For the record, I want to
4 get a copy of this.
5 THE WITNESS: Let me take it out of
6 there for you, then. I was -- I was trying
7 not to. I'll take it out.
8 BY MR. HARRIS:
9 Q. That's all right. You don't have to take it
10 out.
11 A. Okay.
12 Q. What I'd like to do is -- is mark your
13 certified pastoral addictions counselor as
14 Exhibit No. 5?
15 MS. MARSCHALK: Why don' t we do this,
Page 60
1 purposes, Plaintiffs ' Exhibit No. 5 . )
2 THE WITNESS: Okay.
3 BY MR. HARRIS:
4
5
6
7 have a copy of this made to attach to ihe transcript.
8 Is it okay that I deface your -- your card here with ru:i
9 exhibit sticker? --
10
11
12
13 .
A. Okay.
Q. -- Are you okay with that?
A. I'm fine with that.
Q. It'll just help us when we get to trial.
A. Okay. 14
15 Q. And then- -- and you -- you retain the
16 originals, okay?
. A. Okay. All right . 17
18 Q. And then I'm going to do the same thing here
19 with your --
20 A. License.
21 Q. Yeah. Your license,--
22 A. State.
23 Q. -- your Oldahoma board license.
24 A. Yes, sir.
25 Q. Do you mind if I put that sticker on there?
Page 61
1 A. That's all right.
2 (Thereupon, marked for identification
3 purposes, Plaintiffs' Exhibit No. 6.)
4 BYMR. HARRIS:
5 Q. And then Ms. Marschalk, she's going to be kind
6 enough, I hope, to make us some copies of these--
7 A. Okay.
8 Q. -- at a break later on.
9 MS. MARSCHAI..K: sure.
10 BY MR. HARRIS:
11 Q. And now you get to walk around with t rial
12 exhibits in your pocket.
13 All right. So there's testing - then you--
14 you pulled out the Oklahoma one_; do you have one for
15 Texas?
16 Jeff. Why don't you just say that for the 16 A. I don't think 1 have. But.I do -- I do have
17 record, okay? Or -- all right.
18 BY MR. HARRIS:
19 Q. And what I'm going to do is I'm going to let
20 you retain the original, but I'm going to put this
21 sticker on the --
22 A. Okay.
23 Q. - ~ b a c k of it so when you show up at trial we
24 can k'Tlow what we' re talking about?
17 it, but I don't think I have it with me. This thing is
18 so bulky. I' m looking. Okay?
19 Q. Sure. Thank you.
20 A. This isn't what you asked for, but this is
2 1 the-- you mentioned national; that's -- that comes
22 from -- from lhal.
23 Q. Well, is this something different than one
24 through three that we've been talking about?
25 A. Yes, si r.
Page 58 - Page 61
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Page 62
1 Q. All right. So we need to add this to the
2 list, then, don't we?
Page 64
Q. Now, we-- we were talking about the LADC, and
2 this is my understanding of how that works, and you tell
3 A. Well, we -- it' s on one of the-- it's on one 3 me where I'm wrong, --
4 of-- we talked about it. On Exhibit 4, it says -- we 4 A. Okay.
5 talked about that, and you said we'd go back at it. -- 5 Q. --if I am.
A. Okay. 6 Q. Yeah. And-- 6
7 A. -- On Exhibit 4? Master's adcliction? But see 7 Q. It's my understanding that in order to-- to
8 you mentioned national -- what was it? 8 get a license, a license for alcohol and drug counseling
under the Oklahoma or Texas statutes that you've been
talking about, .you're actually relying on your academic
training and one of these other counseling
9 Q. National Association of Forensic Counselors? 9
10 A. Okay. That comes under that association. And 10
11 the certified pastoral counseling, counselor, falls 11
12 under that national. 12 certifications that you've got. You submit that-- you
see what I mean, you submit
13 Q. All right , now I'm thoroughly confused. 13
14 A. Okay. Well -- 14 A. Yes, sir, yes, sir . I follow you.
15 Q. Let's do it tllis way. Now, What I-- what I 15 Q. --your training; --
16 was trying to do was to get you to give me a complete 16
17 list, whether it came from your cv or, as we-- we saw 17
A. Yes, sir.
Q. -- is that how that happens?
A. Yes, sir. 18 for the certified withdrawal specialist, there may be 18
19 certain things that aren't on the CV'l 19 Q. Okay. So, in reality, the training, the
20 A. Right. 20 academic training, that you use to get your LADC and the
licensures and certifications are really based on these
other three that you've identified for me?
21 Q. And I wanted a complete list -- 21
22 A. Okay. 22
23
24
Q. -- of all of your certifications -- 23 A. Yes, sir.
A. Yes, sir. 24 Q. You don' t do anything in addition to that; is
that fair?
25 Q. -- and licenses that deal with drug and 25
Page 63
1 alcohol counseling or rehabilitation.
2 A. Yes, sir.
3 Q. So you-- now we have the master's --master
4 addictions counselor?
5
6
7
8
9
10
11
A. Yes, sir.
Q. Certified withdrawal specialist, right?
A. Yes, sir.
Q. And the certified pastoral counselor, right?
A. Yes, sir.
Q. And then the LADC'!
A. Yes, sir.
12
13
(Thereupon, marlced for identification
. purposes, Plaintiffs ' Exhibit No . 7.)
14 BY MR. HARRIS:
15 Q. All right . I'm going to mark this one, your
16 master's addiction counselor, as Exhibit 7, and again
17 let you retain the original, if you would?
18
19
20
21
22
23
24
A. All right. Okay.
Q. And get a copy of that.
A. Okay.
MS. MARSCHALK: Don' t put those licenses
up yet, Reverend. We' ll-- I'll talce them at
the break and get a copy.
THE WITNESS: Okay. All right.
25 BY MR. HARRIS:
Page 62 - Page 65
Page 65
1 A. Well, the only thing I do in addition to that
2 is the additional requirements in order to maintain it.
3 Q. Got it. But -- but in terms of you
4 don't-- you doi1' t have any training or
5 education in order to be licensed; you get the training
6 and the education from these other three certifications
7 that you and I have been talking --
8 A. Basically, yes, sir.
9 Q. Okay. Anything -- I mt::an, just so the
10 record's very clear about that, --
11 A. Sure.
12 Q. -- is that-- is that accurate?
13 A. That's accurate.
14 Q. Okay. So -- so -- so you would agree with me,
15 then, that the license given to you by Oklahoma and
16 Texas doesn't really -entail any additional training
17 beyond the training that you received for certifications
18 two, three and four that you and I have been talking
19 about?
20 A. Two--
21 Q. The --the certified pastoral counselor, the
22 certified withdrawal specialist, and the MAC?
23 A. The -- the acadenlic qualifies you at that
24 level, bul you must meet the requirements at that level.
25 .If you're saying just the academic gives you the
Desmond, et al. vs. Narconon, et al. MuJtl
.
- b
1 license, no.
2
3
4
Q. That -- that's not what I said.
A. Okay.
Q. And I want to be real clear about it. --
A. Okay. 5
6 Q. --I didn't mean to interrupt you, but if I
7 said something wrong, I want to restate it.
8 A. Okay.
Page 66
9 Q. My understanding is you get the license, and
10 in order to get the license you have the academic
11 credentials which you've talked about, and then in
12 addition you have some certification in drug and alcohol
Page 68
1 A. Yes, sir .
2 Q. And let's -- let's zero in on the certified
3 pastonil counselor. What specific training or education
4 do you receive in drug and alcohol rehabilitation in
5 order to get that CPC designation'?
6
7
A. Having a -- having a academic credentials.
Q. The master's that you and I have been
8 talking--
9
10
11
12
A. Yes, sir.
Q. -- about? Anything else?
A. That's basically --that's basically it.
Q. So if you have a master's degree, and you did,
13 rehabilitation, you put those things together, and then 13
14 whatever the, you know, application requirements are, 14
you're able to apply for and get the CPC designation?
A. Yes, sir.
15 all that sort of stuff, you do that, and then you get
16 licensed by Oklahoma and Texas?
17
18
19
A. Yes, sir.
Q. That's -- that's fair?
A. Yes, sir.
20 Q. So really in order to understand your training
21 in drug and alcohol counseling and rehabilitation, we
22 need to look at these other three certifications?
23 A. Yes, sir.
24 Q. Okay. All right. Let's take number two,
25 then, the certified pastoral counselor.
Page 67
1 A. Uh-huh (affirmative) .
2 Q. Tell me what you had to do in order to receive
3 that certification.
4 A .. That falls under what you established.
5 Q. The National Association of Forensic
6 Counselors?
7 A. Yes, sir.
8 Q. All right. I'm going to mark this as
9 Exhibit 8.
11 pmposes, Plaintiffs' Exhibit No. 8.)
12 BY MR. HARRIS:
13 Q. This appears to me to be the requirements in
14 order to obtain certifications or memberships in the
15 National Association of Forensic Cow1selors, but -- am I
16 right? Is that -- is that what it is? I mean, do you
17 know whether these are accurate?
18 A. You mean what I'm reading?
19 Q. Yeah, uh-huh (affirmative).
20 A. Yes, sir, --
21 Q. That' s accurate?
22 A. --they're accurate. Yes, sir.
23 Q. So Exhibit No. 8 outlines what you got to do
24 in order to get this certification tluough the National
25 Association of Forensic Counselors?
15
16
Q. Which in turn allows you to get the LADC?
A. No, sir. It's separate.
17 Q. All right. Okay. Let's -- then let's move
18 on. Any other -- anything else that you did in terms of
19 training or education in order to obtain the CPC
20 certification that you and I have been discussing?
21 A. I provide -- well, the academic training.
22 That's -- that' s basically it.
23 Q. So if you've completed your master's work, you
24 can get a CPC if you apply and fill out the forms --
25 . A. Yes.
Page 69
1 Q. and pay the fee; -
3 Q. -- fair?
4 A. Yes, sir.
5 Q. All right. Number three. Certified
6 withdrawal specialist; I believe you told me that that
7 was a Narconon designation?
8 A. Yes, sir. Yes, sir.
9 Q. Were you relying on-- were you relying on
10 that certification in order to get your license as a
11 drug and alcohol counselor in Oklahoma and Texas?
12 A. No, sir.
13 Q. Were you relying on your certified pastoral
14 counseling certification in order to get your license as
15 a drug and alcohol counselor in Texas and Oklahoma?
16 A. Excuse me. Say that again?
17 Q. Did you rely on your-- your certified
18 pastoral counseling
19 A. Uh-huh (affirmative) .
20 Q. -- to get your LADC?
21 A. No, sir.
22 Q. And you didn't rely on your certified
23 withdrawal specialist certification?
24 A. No, sir.
25 . Q. So that means you must have relied on the
Page 66.- Page 69
http://ReachingForTheTippingPoin innnnt. t net
James Jerry McLaughlin, 3-6-12 Desmond, et al. vs. Narconon, et al.
Page 70 Page 72
1 fourth and final one, the MAC?
2 A. Well, the MAC is a result-- that's a
3 provision that's provided by the organization you
4 mentioned. Under the national that you mentioned,
5 brought up first?
6 Q. Uh-huh (affirmative).
A. There are three certifications that I get from
8 them. Under that, certified pastoral counseling,
9 master's addiction counseling, and diplomat of the board
1 o addiction examiners. Those fall under that
1 chmch conference, we drove to Canadian, Oklahoma, where
2 Narconon Arrowhead is. Got in on a Thursday. We toured
3 the facility, we met some of the students there, we
4 spent the night and attended a graduation, and -- at
5 Narconon Arrowhead. First time I'd ever seen it, first
6. time I was ever there.
7 The graduates, there was about 50 or 60
8 graduates, the room was full, and I saw people who were
9 excited and motivated about what they had been through.
10 And I said that if that 's for real, there's something to
11 certification that you brought up, the National 11 the program. A week later we were invited to come to a
12 Forensic-- the National Forensic that you brought up. 12 trainh1g program on how to get people off drugs. We
13 Q. National Association of-- 13 came from 9:00 in the morning till 9:00 at night, cost
14
15
A. National-- 14 us $500, we paid a thousand dollars. And it began a
16
17
18
19
Q. --Forensic--
A. -- Association. Those three fall under that.
Q. She's going to kill us in a minute, but ... Jo.
A. I'm sorry. I'm --
Q. No, it's not your fault, it's me, it's --
20 it's --
21 A. That ...
15 process of being trained with the technology and the
16 principles of L. Ron Hubbard.
17 After the graduation, after the program, after
18 the training, we were given a certificate as withdrawal
19 specialists. That's where I started the journey of
20 information. And that's where that certification came
21 from.
22 Q. Okay, I thjnk we're-- we're making progress, 22 Q. So your training was-- was given to you by
Narconon? 23 then, so... What I'm trying to understand, then, is 23
24 your license as a drug and alcohol counselor seems to be 24 A. Yes, sir.
25 dependent upon these other three ce11ifications that you 25 Q. What number am I on?
Page 71
1 and I have been discussing, right?
2 Or at least in part. Strike that. Strike
3 that.
4 Tell me what specific certification you relied
5 on in order to get the licensed alcohol and drug
6 counselor designation from the. State of Texas and/or
7 Oklahoma.
8 A. Okay. Other than my academic training, I
9 didn't rely on anything else for the licensed counselor
10 certification.
11 Q. All right. And we've established, then, that
1
2
3
Page 73
A. I think 8 - 9. I think you -- wait a minute.
(Thereupon, marked for identification
purposes, Plaintiffs' Exhibit No. 9. )
4 BY MR. HARRIS:
5 Q. Let me hand you what I've marked as Exhibit 9.
6 Do you recognize that?
7 ?viR. HARRIS: r don't know if I have
8 another copy. Sorry.
9 MS. MARSCHALK: I'll get copies at --
10 THE WITNESS: Yes, sir.
11 BY MR. HARRIS:
12 your-- your academic training consisted of one course 12 Q. And what is that?
13 that dealt with drug and alcohol rehabilitation?
14 A. Yes, sir.
15 Q. So 'there's nothing in addition to yow
16 academic training that you and I have talked about that
17 you did in terms of education or training in order to
18 get the LADC, fair?
19 A. Yes.
20 Q. Tell me about your -- your training as a
21 certified withdrawal specialist.
22 A. In 2002 I was at a church conference, and--
23 my wife and I. And she had heard about a program that
24 was different than what was existing. And she said it
25 would be on the way back home. So when we left the
Page 70 - Page 73
13 A. This comes off a web site. And-the web site
14 is Heartland Drug Rehab.
15 Q. And that's a organization that you were
16 affiliated with?
17 A. Yes, sir.
18 Q. On the last page of that document, it
19 describes you as Narconon-trained?
20
21
22
23
A. Yes, sir.
Q. Do you agree with that?
A. Yes, sir.
Q. All right. In fact , all of the training that
24 you have received in drug and alcohol counseling, apart
25 from the one course that you described for me in your
Multi-Page TM
1 master's work, all of that has come from
2 Narconon-affiliated institutions?
3 MS. MARSCHALK: Object to the form.
4 BY MR. HARRIS:
5 Q. Right?
6 A. Give me that again, please.
Page 74
7 Q. All of the training and education -- and I'm
8 not --let's put aside real-world experience for a
9 second,--
10 A. Okay. All right.
11 Q. -- for purposes of my question.
13 Q. But ail of the training and education that you
14 have received in drug and alcohol rehabilitation, apart
15 from the cine master's course that you and I discussed,
16 all of that has come from Narconon-related institutions?
18 THE WITNESS: Not-- not all of it, sir .
19 BY MR. HARRIS:
20 Q. Well, tell --
21 A. A rna--
22 Q. --me where I'm wrong.
23 A. A major part of it, but it's not-- it's not
24 all. I've been exposed to other programs and other
25 experiences. So it's not all.
Page 75
1 Q. You're using the word "exposed to." And--
2 and I was ask --
3 A. Exper -- well, experience?
4 Q. I understand.
5 A. Okay.
6 Q. And we'll talk about that in a minute.
7 A. Okay.
8 Q. And what you're -- what you're disagreeing
9
with me about is that you feel like you've bad some --
10 some experience, some real-world experience looking at
11 programs that aren't Narconon, fair?
12 A. Yes, sir.
13 Q. What I want to know is -- and it seems to me
14 'cause we've s01t of methodically gone through all this;
15 what I want to know is, have you- have you attended
16 any courses or been subj_ected to any kind of educational
17 programs or received any certifications or licenses or
18 anything like that that are not Narconon -- that are---
19
or , that did not come from Narconon-affiliated
20 institutjons?
21 MS. MARSCHALK: Outside of what you 'vc
22 marked as exhibits?
23 MR. HARRIS: .Are you going to -- are you
24 going to start talking, 'causer--
Page 76
l BY MR. HARRIS:
2 Q. Do you understand my question? 'Cause we'll
3 start all over again 'if --
4 A. No, here's --here's --here's what -- here's
5 what I-- I' m having a problem with. It sounds like all
6 of the training other than what I've shared with you
7 have only come from my experience with Narconon
8 training. And it's broader than that. It's broader
9 than that.
10 Q. Let's --let's -- let's try it this way.
11 A. Okay.
12 Q. You identified for me -- and what I'm trying
13 to do is put aside real-world experience for just a
14 second, and focus on academic training and licensing and
15 certifications.
16 A. I'm clear.
11 Q. You with me?
18 A. I'm clear.
19 Q. All right. And I think you have told me about
20 your academic training?
21 A. Yes, sir.
22 Q. And you have told me about all of your
23 licenses and' certifications?
24 A. Yes , sir.
25 Q. That -- that pertain to drug and alcohol
l
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
2.1
22
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24
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Page 77
rehabilitation and counseling, fair?
A. Yes, sir.
Q. And the list is all-inclusive, there aren't
any other licenses or certifications or academic
training that you -- that -- that you're aware of that
pertain to drug and alcohol rehabilitation and
counseling.
A. Yes, sir .
Q. Fair?
A. Yes, sir.
Q. Now, the -- the licenses that we tallced about,
the only license that_ you have -- and correct me if I'm
wrong; the only license that you have is this LADC from
Oklahoma and Texas?
A. Yes, sir.
Q. And that license is based exclusively, as you
told me, on the receipt of your master's degree?
MS. MARSCHALK: Object to fonn.
BY MR. HARRIS:
Q. Tell me where I'm wrong.
A. You said "only," and I said to you that the
academic part put me a t the level in which I could
qualify to be a licensed addiction counselor for the
State of Oklahoma, which includes additional reading
cuniculum in order to get it and maintain it. Case in
Page 74- Page 77
Multi-Paoe T ~
e
Page 78 Page 80
1 point, example; there are certified licensed persons in 1 A. Yes, sir.
2 the state right now that are not privileged-- because 2 Q. All right. You are relying on your master's
3 they don't haye a degree, they are not privileged to -- 3 degree, correct? In order to get the license from Texas
4 to have a license without a master's degree. So it -- 4 and Oldahoma.
5 it -- it requires more -- it entitles me to be at that 5 A. In addition to the requirements that they set
6 level, but it doesn't --that alone does not qualify me 6 on me.
1 to be a licensed addiction counselor. 7 Q. Okay.
s Q. AU right. And that's-- that's what I 8 A. I had to read material, and. I had to be
9 thought we went through fairly methodically, but we'll 9 tested.
10 do it again. You -- you have this license from Oklahoma 10 Q. All right. So in order to sit for the test,
11 and Texas as an addiction counselor? 11 did you have to have any other certifications, beyond
12 A. Yes, sir. 12 the master's degree-- or, excuse me, any other--
13 Q. You did not rely on your certified pastoral 13 A. No.
14 counseling designation in order to obtain that license? 14 Q. --- credentials?
15 A. No, sir. 15 A. No, sir.
16 Q. You did not rely on your certified withdrawal 16 Q. And so you had to take a test?
11 specialist certification in order to obtain the license? 17 A. Yes, sir.
18 A. No, sir. 18 Q. Do you know how long the test was, or how
19 Q. You did not rely upon your MAC certification 19 - extensive it was?
20 in order to obtain the license? 20 A. It was a couple hours.
21 A. No, sir. 21 Q. All right. And-- and let's take another shot
22 Q. You relied on your master's in theology, 22 at this, then. All of your certifications, then--
23 correct? 23 putting aside the license for just a second.
24 A. That was their reqrurement, yes, sir. Yes, -- 24 A. Uh-huh (affirmative).
25 Q. What-- 25 Q. Is there any certification that you have
Page 79
A. --sir. 1
2 Q. What other certification did'you rely on in
3 order to get that license, besides your master's degree,
4 if there is one?
5 MS. MARSCHALK: Object to form.
6 TI-IE WITNESS: "Master's degree, if there
7 is one"?
8 BY MR. HARRIS:
9 Q. No. Other than your master's degree, --
11 Q. -- in order to get this license from Oldahoma
12 and Texas, --
13 A. Yes , sir.
14 Q. -- what other certifications did you rely on?
15 A. There is none.
16 Q. Okay. So we can put that aside; --
17 A. Yes, sir.
18 Q. -- you and I agree?
19 A. We agree on that.
20 Q. So in order to obtain your license as an
21 alcohol and drug counselor from Texas and Oklahoma, you
22 did not rely on any of your drug and alcohol
23 certifications?
24 A. No, sir.
25 Q. You-- you're agreeing with me?
Page 78 - Page 81
Page 81
1 received, or training or education in drug and alcohol
2 counseling, that has not come from a Narconon-affiliated
3 institution?
4 A. No, sir.
5 THil VIDEOGRAPHER: Sir. _ .
6 MR. HARRIS: Why don't you go ahead and
7 switch it right now, 'cause I'm about to
8 change gears here.
9 THE VIDEOGRAPHER: All right. Going off
10 video record at 12:19 p.m.
11 (Lunch recess at 12:19, resumed at 1: 13.)
12 THE VIDEOGRAPHER: Now back on video
13 record. The time is approximately 1: 13 p.m.;
14 this i ~ tape number 2.
15 BY MR. HARRIS:
16 Q. All right, Reverend, we're back on.
17 A. Okay.
18 Q. You had a nice lunch?
19 A. Yes, sir.
20 Q. A couple of housekeeping matters. What-
21 what arc you getting paid, in terms of hourly rate, for
22 your work in this case?
23 A. $125 per hour.
24 Q. And do you lmow how much you' ve billed thus
25 far?

Page 82
1 A. 26 -- 2600. 1
2 Q. 26 -- so 26 -- roughly 2600, is that what you 2
3 said? 3
4 A. Yes, sir. 4
5 Q. I'm sorry. $2600, not hours? 5
6 A. Dollars. I'm sorry, sir. 6
7 Q. Who's paying you? 7
8 A. I don't know. 8
9 Q. Have you sent a bill yet? 9
10 A. No; but I've been talking with Attorney 10
11 Barbara, and -- 11
12 Q. You're just assuming she's going to pay you? 12
13 A. Well, she said -- no, I'm not assuming 13
14 she's -- well, she's here . . No, I'm sorry, sir. I'm L4
15 assuming she'll pay me. 15
16 Q. And I thi11k I asked you this at the beginning, 16
17 but I just want to be clear about it. Have you ever 17
18 done any kind of legal consulting work before? 18
19 A. No, sir. 19
20 Q. Have you ever been retained by any 20
21 Narconon-related institution in a consulting capacity 21
22 and been paid for it? 22
23 A. No, sir. 23
24 Q. All right .. We talked a little bit about your 24
25 expert disclosure; I'm going to go ahead and mark that 25
Page 83
Page 84
persons, I've gotten-- they have received results. And
so when I say "effective," at the end of the day,
applying principles and techniques makes or defines what
I mean by when I say "effective." At the end of the
day, somebody that I'm working with is helped.
Q. And is there any way to - to quantify that?
A. Quantify it in what way?
Q. Well, you -- you believe, as I understand it,
that the Narconon technology is effecti'_'e at
rehabilitating people who have drug and alcohol
problems, fair?
A. Yes, sir.
Q. All right. And that's your opinion?
A. Yes, sir.
Q. What do you -- is any -- is there
anything you can point me to or direct me to and -- to
show me what the bases of that opinion is, in terms of
recisi -- recidivism rates, or the number of people who
go back into the program? Anything other than your
opinion itself. Does that make sense?
A. Yes, sir.
Q. Okay. Help me there.
A. You said "quantitatively." Would it be ...
Okay. I know persons with names who have been helped by
the program, and I've seen results in their lives.
Page 85
1 as EXhibit 10. 1 Q. Okay. Who are these people?
2 A. Okay. 2 MS. MARSCHALK.: object to form. I
3 (Thereupon, marked for idtmtification 3 don't-- I don't know that he's allowed to
4 purposes, Plaintiffs' Exhibit No. 10.) 4 tell you that unless they've waived.
5 BY MR. HARRIS: 5 BY MR. HARRIS:
6 Q. And I think you have a copy, maybe, in front 6 Q. Is that a bases of your opinion? These people
7 of you, but you're .welcome to look at the one I just 7 that you know have been helped?
8 marked. 8 A. No, sir; that deals with results.
9 A. Yes, sir. 9 . Q. Okay. Well, one of your opinions is that the
10 Q. Let's go to Page 4. 10 Narconon prograrri is effective, correct?
11 A. Uh-huh (affirmative). 11 A. Yes, sir.
12 Q. And again, -- 12 Q. And I asked you to point to me to some
13 A. Okay. 13 specific evidence that supports your opinion, fair?
14 Q. -- I want to stay on this topic that we've 14 A. Yes, sir.
15 been 15 Q. And one of the things I believe you told me
16 A. Okay. 16 was that you know some people who the program has
17 Q. --your -- your contention, or your opinion, 17 helped?
18 that you believe that the Narconon program is effective 18 A. Yes, sir.
19 at educating and rehabilitating people who are addicted 19 Q. And so you are relying on these people that
20 to drugs and alcohoL 20 the program have helped, at least in part, for your
21 A. Yes, sir. 21 opinion that the program is effective, correct?
22 Q. Tell me what you mean when you say 22 A. Yes. Yes, sir.
23 "effective." 23 Q. Who are ,these people?
24 A. Based on my training with the Narconon 24 MS. MARSCHALK: object to form.
25 material , and based on my experience of applying that to 25 THE WITNESS: I'm -- I'm not in a
http ppppp://Rea ea eee chingFor orTheTippingPoinnt. t net
Multi-PageTM
Page 86 Page 88
1 position to answer you. I understand the 1 to try to be able to answer me before your deposition
- 2 question, but I'm not in a position to 2 here today?
3 answer. 3 MS. MARSCHALK: object to the form.
4 BYMR. HARRIS: 4 THE WITNESS: Sir, I didn't know what
5 Q. And, sir, you understand that-- that one of 5 the questions would be.
6 the things l get to-- to know is wbat the bases for 6 BY MR. HARRIS:
7 your opinion is, right? 7 Q. Understood.
8 A. Yes, sir. 8 A. So I'm not prepared to answer that question.
9 Q. And you would agree that that's fair, right? 9 Q. Are-- are you making the decision to not
10 A. Yes, sir. 10 disclose these individuals because you believe that
11 Q. And so if you're going to come into court and . 11 there' s some protection over their identity?
12 'you're going to say that a program is effective, and 12 A. Yes, sir. There's a ethical -- as a
13 you're going to rely on some information, then in 13 counselor, there is an ethical issue that I'm dealing
14 fairness to me and my client, I'm entitled to know what 14 with, that you're asking me for.
15 you' re relying on. 15 Q. Understood. So, but I'm not able to learn the
16 A. Yes, sir. 16 identity of these folks, as a result of your decision to
17 Q. Fair enough? 17 not tell me?
18 A. Yes, sir. 18 MS. MARSCHALK: Object to form.
19 Q. And one of the things you've told me that 19 THE WITNESS:. Not today.
20 you're relying on is some specific examples of people 2o BYMR. HARRIS:
21 that you think benefited from the program? 21 Q. Okay. When are you going to be able to --to
22 A. Yes, sir. 22 give me that information?
23 Q. But you' re not willing to tell me who they 23 A. When I get permission from them to provide
24 are? 24 that informatio,n.
25 A. I have to get approval from them in order to 25 Q. Okay. Let's make a good list, then. In terms
Page 87 Page 89
1 do that, sir.
2 Q. Qkay. Aud you understand that the purpose of
3 the here today is for me to understand your
4 opinions and what you're basing those on?
5 A. Yes, sir.
6 Q. Did you do anything in order to attempt to get
7 permission from these folks prior to your deposition
8 here today?
9 A. I didn't know what the questions would be,
10 sir.
11 Q. Okay. But, as we sit here today, you are not
12 willing to tell me the names of these individuals?
13 A. I'm not --
14
15
MS. MARSCHALK: Object to form.
THE WITNESS: --able to tell you.
16 BYMR. HARRIS:
17 Q. I'm sorry?
18 A. I'm sorry.
19 MS. MARSCHALK: Go ahead.
20 THE WITNESS: I'm sorry. Wait till you
21 finish. The ques -- to answer your question,
22 I --I understand what you're asking, and I'm
23 not able to answer you at this point.
24 BY MR. HARRIS:
25 Q. All right. Well, what have you done in order
Page 86 - Page 89
1 of your opinion that the program is effective, I'll put
2 number 1 here, your experience with certain individuals,
3 fair?
4 A. Yes, sir.
5 Q. And those are the individuals that you're not
6 in a position to identify for me?
A. At this tin1e, sir. 7
8 Q. All right. What's -- what's number 2? Or is
9 there a number 2?
10 A. 2 ...
11
12
13
Q. Reasons why you think the program's effective.
A. Oh. Based on follow-up, follow with those
persons, follow-up on their status and how they are
14 progressing.
15 Q. So -- so number 2 on your list is follow-up
16 with the people who, in number 1, you aren't willing to
17 identify?
18 A. I'm not able to at this time.
19 Q. Not able to identify?
20 A. Yes , sir.
21 Q. Can you give me any more insight into what you
22 mean by "follow-up"?
23 A. In the -- specifically. One of the things in
24 training, that there are three phases of -- -of working
25 with substance abusers or addicts; withdrawal, early
Desmond, et aJ. vs. Narconon, et al.
Multi-Page TM
Page 90
1 intervention and treatment. The major focus ofmy
2 training is prevention, which is education and
3 withdrawal. The students that I work with, the program
4 is not over because they have withdrawn from their
5 addiction. Early intervention, a person who experiments
6 with a substance, and caught early enough with education
7 and assessment, I help them. When it gets to treatment,
8 that's not in my lane. And what I mean by "my lane" is,
9 I use a phrase, and someone said to me, "Stay in your
10 l<me." And so when something is out of m.y experience or
11 training, it's not in my lane. So when I say to you--
12 you said where do you go from there; is, you follow up
13 on the persons. One unique thing about what I do is, in
14 the ministry, people become a part of my parish or a
Page 92
Q. All right. Well, let's just continue down our
2 list, then. Again, I want to know every reason or bases
3 for your opinion that the program is effective. at
4 educating and rehabilitating people who are addicted to
5 drugs and alcohol. You have thus far identified,
6 number 1, your experience with certain unidentified
7 people?
9
10
Q. Correct?
A. Yes, sir.
11 Q. Number 2, follow-up with these same
12 unidentified people?
13 A. (Witness nods bead affirmatively.)
Q. Right? 14
15 part of my congregation. They have certain privileges 15
16 ethically that I cannot share. When they give me 16
A. Yes, sir.
Q. All right. What else?
17 permission to do that, I'll be happy to give you number
18 1. And we -- when we go to trial, they could actually
19 speak for themselves, if that's necessary.
20 Q. Okay. But you -- you -- you put yourself out
21 as an expe11 in this case. Voluntarily. Right?
22 A. Expert, a limited area of-- the limited area
23 of material that is used to train persons. --
24 Q. I understand that.
25 A. -- That's my expertise.
Page 91
Q. Well, that's not what your disclosure says,
2 though, is it, Reverend? Your rev- Reverend, it says
3 that you -- in addition to that, you're going to .talk
4 about the fact that you believe that this program is
5 effective. Right?
6 A. That's in the area of my experience and rny
7 area of my training, and my opinion stands on my
8 experience and my training.
9 Q. Okay. And -- and I have a right to know why
10 you think the program is effective. And you would agree
11 with that, right, you think. that's fair?
12 A. Yeal1, that's fair, a right to know.
l3 Q. Sure. And-- and I have a legal right to
14 know, too; did you know that?
15 . A. Well, that's why we're here.
16 Q. Okay. And that's what I'm trying to
17 A. Their -- their testimonies, and changes in
18 behavior in their lives.
19 Q. And you're referring again to the same group
20 of people that you're not willing to identify, --
A. Yes, sir. 21
22 Q. -- or you can't -- don't feel like you can
23 identify?
24 A. Yes, sir.
25 Q. All right. Testimony and experiences; how is
Page 93
1 that any different than nwnber 1, which is your
2 experience with these people?
3 A. No. I'm sorry. When we were talking about
4 effectiveness and you asked me to define effectiveness,
5 and I said -- or, J added to it, that it's based on
6 results. And then the question was, "Well, who are--
7 who are they?" And we started with 1, and then you
8 said, "What follows next?" .2. Then you want to know
9 what else follows. So personal testimonies from the
10 individual , that's a part of them giving me feedback
11 that the -- the ministry, the program, the principles
12 and techniques that are used-- what's the next nuinber,
13 number 4?
14 Q. I --
15
16
A. W11at follows after the --
Q. Well, I have 3.
17 determine. 17 A. Okay. Okay. Let's put number 4.
Q. Okay. What's number 42 18 A. Okay. 18
19 Q. And so I need to know what you' re basing your 19 A. Okay. Number4 is, my church affiliation has
20 officially adopted techniques and principles that is . 20 opinion on. Now, if it's just your opinion, just tell
21 me that.
22 . A. It's based -- sir, it's based on my training
23 and my experience with the information concerning L. Ron
24 Hubbard, concerning the techniques and technology that
25 I'm lalking to you. That -- why I'm here.
21 clothed in Scripture as a substance abuse program that
22 we can offer to other faiths or religion who have
23 addiction problems in their congregation.
24 Q. So one of the things that you believe supports
25 your opinion that the Narconon technology is effective
Page 90 - Page 93
http://RRea e chingForTheTippingPoint.net
James Jerry McLaughlin, 3-6-12 Desmond, et al. vs. Narconon, et al.
Page 94 Page 96
A. Yes, sir. 1 at educating and rehabilitating people who are addicted 1
2 to drugs and alcohol is because your church affiliation 2 Q. And it sounds to me like what you're telling
3 has adopted techniques and principles that are clothed
4 in Scripture as a substance abuse program to offer to
5 other faiths or religions?
6 A. Based on l, 2 and 3.
7 Q. "Based on 1, 2 and 3." l'm sorry, I don't
8 understand that at all.
9 A. Well, you asked me, sir, you said, "Tell me
3 me--which is fine, if that's your opinion--that it's
4 effective because your denomination is willing to accept
5 it?
6 A. It's effective because .it reduce -- it
7 produces results, number one, and there are people, once
8 we get approval for thein, that will come forth and --
9 and -- and -- and -- and share. And there '11 be a nan1e
10 what you mean by 'effectiveness', define 10 to those people that you're talking about._ It's
11 ' effectiveness,"' and I attempted to --you said, "Let's 11 effective because not only those people that you're
12 go down the list." So I attempted to tell you my 12 talking about, is that the principles and techniques
13 definition of what's effective. And that's results. At 13 that is in this --what I said, my experience and my
14 the end of the day, whatever you do, are those lives 14 training shows-- using this shows results. And
15 changed? And so I went down, began to tell you. And 15 that's -- that's the only way that I know at this
16 you said, "Well, tell me what else. What else, why you 16 juncture that I can define in my understanding what
17 feel it's effective." Well, I think it's significant 17 effectiveness is and to try to answer your question.
18 that a -- my denomination would embrace the technology 18 Q. All right. I understand, and that' s kind of
19 and principles that is used, we use, to help people get 19 what I was actually trying to get to. Is what -- what
20 off of drugs. 20 are the results that you're talking about? If you're --
21 Q. Al11ight. I think I understand what you're 21 if you're basiCally saying that this program is
22 saying. So you're saying that you believe that it's 22 effective-- I think your exact quote was, "It 's based
23 effective because of the fact that your -- your 23 on the results"?
24 is willing to accept it as a program to 24 A. And the results is that people are no longer
25 treat folks who have drug and alcohol problems? 25 using drugs; they have withdrawn from-- if they're on
Page 95
A. Yes, sir.
Page 97
1 marijuana, they.'ve drawn [sic] from marijuana; if
2 Q. So it's effective because your denomination 2 they' re on crack, they have withdrawn from crack. And
3 has accepted it? 3. that's what I defme.as the withdrawal phase of-- of
4
5
A. In my -- yes, sir. 4 the ministry.
Q. All right. But what I was trying -- and I 5 Q. So it' s effective for the people for which
6 want to be clear about this; I was trying to get to 6 it's effective?
7 things that-- and that's fine, that's your opinion. 7 A. It's effective for the people that which I
8 But I was trying to get to things that -- that we could . 8 help to get off of dmgs.
9 look at objectively to try to determine whether or not 9 Q. Is .it effective for the people who don't get
10 it's effective or not. Do you understand the 10 off drugs?
11 distinction I'm trying to-- 11 A. Well, the logical answer for that would be no.
12 A. You-- but -- 12 Q. All right. What percentage of the people in
13 Q. --draw?
14 A. You-- sir-- okay, excuse me. What you need
15 to do is give me some examples, because 'for me it's kind
16 of ambiguity. To -- I -- I want to answer yom
17 questions, but I want to know specifically, exactly what
18 you're looking for.
19 Q. Well, and I'm-- I'm trying to understand what
20 you meant when you gave the opinion that it was
2 1 effective in educating --
22 A. Okay.
23
24
25
Q. -- and rehabilitating people.
A. Okay.
Q. Okay?
Page 94 - Page 97
13 the programs that you have been involved in handling
14 that administer the Narconon technology has it been
15 effective in the way that you've defined it for me?
16 A. I can't give you -- I can't give you an exact
17 answer at tllis juncture, but I'd safely say that we're
18 talldng, say, over a hundred people.
19 Q. All right. So in your estimation there have
20 been a hundred people who the program has effectively
2l gotten off drugs, which I think is what you described as
22 effective, fair?
23 A. Yes, sir.
24 Q. All right. How many people does that
25 represent in terms of a percentage of people who went
Multi-Page 'I'M James Jerry McLaughlin, 3-6-12
Page 98
1 through the program? 1
2 A. That 's -- that's-- that' s hard to say. 2
3 Q. Well , don't you need to lmow that in order to 3
4 determine whether or not it' s effective? 4
5 A. Well, it's based on what-- I'm trying to 5
6 answer your question -- 6
7 Q. And I appreciate that. I think you are. 7
8 A. -- about effectiveness. But then when you ask 8
9 me, "Don't you think ... ", I -- I have a-- I have a-- 9
10 personally, a major problem with your definition of 10
11 effectiveness and my definition of effectiveness. 11
12 Q. I was using yours, I thought. 12
13 A. Okay. Well, -- 13
14 Q. Which was -- Uhought. I thought. 14
15 A. -- that's -- and that's --and that's what 15
16 we're -- that's what we're-- that's what we're talking 16
17 about. 17
18 Q. Well, why don't you tell me again, then, 18
19 'cause in your opinion you use this word, do you not? 19
20 A. What's the word? 20
21 Q. "Effective." 21
22 A. Yes . 22
23 Q. All right. And I thought you told me that 23
24 when you -- 24
25 A. When something's effective -- I'm sorry, I -- 25
Page 99
1 Q. Go ahead, I don't want to interrupt you. 1
2 A. No, I interrupted you, I apologize. 2
3 Q. I'm not -- my opinion is irrelevant, doesn't 3
4 matter ; I'm trying to learn yours. 4
5 A. Okay. 5
6 Q. And you -- you've said in this -- in this 6
1 disclosure here that you think that this program is 7
s effective, and I'm just trying to -- to kind of 8
9 understand why you believe that to be so. Are-- are 9
10 you with me so far? 10
11 A. Yes, sir. 11
12 Q. Okay. And you said that one of the reasons 12
13 that you believe it was effective--and if I'm misquoting 13
14 you, you tell me-- 14
15 A. Uh-huh (affirmative). 15
16 Q. -- is that there have been approximately a 16
17 hundred people who you could safely say as a result of 17
18 going through the program have gotten off chu gs and 18
19 a]cohol? 19
20 A. Yes, sir. The withdrawal--let --let me be 20
21 specific in terms of that . The only thing I would 21
22 change is the wHhdrawal phase, the part in which I 22
23 measure effectiveness, and that is to get people off of 23
24 drugs. A simple question would be how do you get people 24
25 off drugs, and using the principle and technology, who 25
Page 100
are they, where do they live.
Q. But so what you're basically saying is that as
a -- as a: minister , you think the program is effective
if it works for anybody. Fair? I mean, if it gets one
person off drugs and alcohol, as a minister , in your
view, it' s an effective program because it's helped that
person?
A. Yes, sir.
Q. You agree with me on that?
A. Yes, sir, I agree. Helped that person, yes,
sir.
Q. Okay. So -- and that really is --.it sounds
to me like-- and, again, I don't want to put words in
your mouth, but that sounds to me like that' s your
fundamental opinion?
A. That's my fundamental opinion.
Q. All God's children are special?
A. Amen.
Q. And so if the program works for one of them
and -- and gets that one member of the flock off dmgs
and alcohol, it's effective?
A. For that person.
Q. For that person, --
A. Yes, sir.
Q. - - fair enough. All right. But -- but from
Page 101
an objective -- from a more scientific standpoint, you
would agree with me that there are other ways of
measuring effectiveness?
A. Many ways, sir.
Q. Okay. And what I was trying to get to is -
and, again, you would agree with me, let's say that
there are a hundred folks who this program helps in the
way that you've defined it, but 50,000 people go through
the program, hypothetically. Well, 100 out of 50,000 is
a pretty lousy return, fair?
A. Yes, sir.
Q. So in order to really determine whether or not
this thing is effective under a. more objective analysis,
you've got to know how many people went through the
program to compare that hundred to?
A. I understand, sir.
Q. You agree with me on that?
A. Yes, sir.
Q. So how many people?
A. I'm going back to, you -- you want to -- you
want an answer I wish I could give you, but I can' t.
Because I don't know specifically. Now, then the
question becomes why.
Q. "Why" what?
A. Why can I not give you a specific question
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Page 102 Page 104
1 [sic). 1 Q. The 7G percent success rate.
2 Q. And why can you not give me that? 2 A. For example, you --you said, well, based
3 A. Glad you asked the question.
4 Q. Okay.
3 on-- based on what I said to you, you said, "Hey, that
4 hundred is so insignificant it doesn't even -- " -- and
5 A. AU right. If the principle and teclmiques
6 work for one individual, it does not necessarily mean
7 that it works for all individuals, as you mentioned, .all
8 of God's children. And in my experience working with
5 I'm --I'm expanding this. "--it doesn't even show up
6 on the radar screen." Well, it could be possible, too,
7 that whatever statistics that they have, their 70
8 percent might be on 500 people, on a thousand people, on
9 addicts, we cookie-cut them. And when you cook--
10 and -- and every person with a problem has a story, and
9 2,000 people, on 3,000. So 70 percent sounds large, but
11 you have to listen to their story and they' ll tell you
10 when you put that up against t11e national statistics and
11 the scientific information that you alluded to, it
12 what the problem is. Now, know I-- here's the point.
13 I provide training, not only for people who have a
12 doesn't even show up. Ooesn't even register, so when
13 they say 70 percent success rate, that might be 70
14 problem, but I also provide training for ministers who 14 percent of t h ~ people that is exposed to their training.
15 are in communities that have problems in their community 15
16 with addiction. And I train them .. When we communicate, 16
17 I ask them what are the results. It' s n:ot a hundred 17
18 percent. What are the results. For example, you asked 18
19 me the question of effectiveness, and we should know 19
20 numbers. One of the reasons why I'm involved in what 20
21 I'm involved in, and this is my passion, we got 54 21
22 million people, users and abusers and addicts. We have 22
23 22 million people who admit they got a drug problem. 23
24 And we only treat four million of them. So that's 18 24
25 million people who want help who can't get help. So 25
Page 103
1 when we talk about effectiveness, my passion, and what 1
2 I'm dealing with, is whatever we are presently doing 2
3 with all of the Ph.D.s and the master's and the... It's 3
4 not working. Because statistics-wise there is a major 4
5 problem when you spend the kind of money that you do and 5
6 get the kind of results. What are the results? Less 6
7 than ten percent of all the people we treat in the 7
8 nation relapse. And so-- 8
9 Q. Less than ten percent relapse? Or more than 9
10 ten percent? 10
11 A. More than. I'm sony. Thank you. Ten 11
12 percent, after two years, remain-- ten to 20 percent 12
13 remain drug-free; it doesn't matter what the problem-- 13
14 what the program is. 80 percent relapse. And I might 14
15 add, it doesn't matter what the program is. 15
16 Q. Well, I don't understand that, because 16
Q. Right. So that statistic is meaningless?
A. Well, then the other point, sir, is that most
of the statistics that we have, based on what you said,
is meaningless.
Q. All right. Well , really, I just want to make
sure I understand -"
A. Okay.
Q. --why you believe what you believe.
A. Okay. And I'm trying--
Q. No, you are.
A. -- I'm trying to tell you that.
Page 105
Q. And I.-- I appreciate that. And so we're--
we're making progress.
A. Okay. Thank you.
Q. So we' re just going to leave it at, in terms
of this decision or determination that this program is
effective, you would agree with me that you can't tell
me what percentage of people who have gone through the
program relapsed or successfully dropped drugs and
alcohol; you just don' t lmow?
A. Of the people -- of the people that I have
been exposed to and I've trained, and-- and I gave you
a figure, safely, of a hundred, I can' t give you that
information right now . . But I can --I can supply that
information.
Q. Well , again, I mean, that's why I'm here. And
I--
17 Narconon says that it has a 76 percent success rate. So 17 A. But-- but I didn' t know your questions, sir.
18 m1der your math that can' t be accurate, can it? 18 Q. Okay.
19 A. Well -- well, let's look at that another way, 19 A. I didn't know the kind of questions you were
20 sir. I gave you national statistics. Do we know what 20 going to ask.
21 Narconon total number people that they treat? 2 1 Q. What is it that you're g a i n ~ to supply me
22
23
24
25
Q. No. 22 with?
A. Okay .
Q. So where'd the number come from?
A. Where-- where's the number come from?
23 A. Well, you-- number one, you said, "Who are
24 these people?" I said to you that 1 can get approval
25 from them to use their name, and that's an ethical
Page 106
1 thing.
2 Q. I don't mean to cut you off, but I think we're
3 talking about something different. I was talking about
4 numbers, percentages. And what I want to know is,
5 you've told that there are a hundred people who you can
6 identify who you believe the program has helpeq, right?
1 A. Yes.
8 Q. And what I want to know is, that hundred
9 people comes out of how many people, though, went
10 through the program?
11 A. And I can't give you that answer.
12 Q. Well, will you-- will you be able to?
13 A. Yes.
14 Q. All right. So you're telling me that you're
15 going to tell me the total number of people who went
16 through the program from which a hundred successful
17 folks--
18 A. Yes, sir.
19 Q. -- came out? When can I expect to receive
20 that information?
21 A. (No response.)
22 Q. Well, let me ask you this. You don't know the
23 answer, so it clearly doesn't have anything to do with
24 your opinion, right?
25 A. Well, if-- if you ask --if we started the
Page 107
1 question process at those names, identify to you what
2 the effectiveness in how I define effectiveness, it
3 makes --yes, sir, it does matter. But at this
4 juncture, and what you're asking me for to deliver right
5 now, l cannot. And so therefore I. ..
6 Q. Well, let me take one-- one --one other shot
7 at it, then.
8 A. Okay.
9 Q. You-- you' re-- you're comfortable sitting
Page 108
1 Q. Are you pla:nrllng on giving me specific sort of
2 anecdotal examples of people?
3 A. Well, I'm -- I'm giving you what I understand
4 to be as I understand being effective. And -- and here
5 again, I'm struggling with trying to answer the
6 questions that you ask me. And we seem to -- I just
7 want to be clear in understanding what you're saying.
8 T h a t ' s ~ - that's what I'm struggling for. And I don't
9 seem- I don't seem to-- I mean, I'm numbering things
10 and-- well, you're numbering things, and, I niean, that
11 list could be endless.
12 Q. Why could it be endless?
13 A. 'Cause when you talk about experience on
14 effectiveness, I've been involved with this technology
15 and these principles and what I do specifically relating
16 to this for the last ten years.
17 Q. Well, I-- I am simply trying to determine why
18 you're saying what you're saying. And if you're saying
19 that you believe it's effective because in your opinion
20 as a pastor, having seen it work in the real world, it's
21 effective, then I'm comfortable leaving it at that.
22 A. Okay. And just add to it that I've applied it
23 and used it in my congregation, and that's what the
24 point I'm- I'm also making. Because I was trained by
25 it, I use it, and it's effective.
1
2
3
4
5
6
Q. All right. So --
A. But--
Q. I didn't mean to interrupt you.
A. No, that's okay.
Q. So can we leave it at that, then?
A. Yes, sir.
Page 109
7 Q. Your _contention or your opinion that - that
8 this program is effective is based exclusively on your
9 experience seeing the program help some people in the
10 here now and testifying that in your opinion the program 10 real world, fair?
11 is effective, even though you don't know the total 1i A. Yes, sir.
12 number of people who have gone through the program from 12 Q. Okay. And -- and you view effective as
13 which a hundred have been successful? 13 helping anybody overcome their drug and alcohol problem?
14 A. Yes, sir. 14 A. Effective is helping the people that I'm
15 Q. All right. Any other bases for your opinion 15 working with overcome their drug problem.
16 or contention that the program is effective at educating 16 Q. Got it. And you don't have any statistical
17 and rehabilitating people who are addicted to drugs and 17 support for your opinion? --
18 alcohol? 18 A. No, sir. --
19
20
21
22
A. Yes, sir.
Q. All right. What is it?
A. How many examples you need?
Q. I need every example that you intend to use to
23 support your opinion in the event that you're sitting in
24 front of some jury in DeKalb County, Georgia.
25 A. Okay. All right. All right.
19 Q. --You can't--
A. -- Not at this time. 20
21 Q. Okay. And you don't have any-- you can't
22 point me to any -- any sctentific study or analyses
23 where this program is compared to some other program and
24 controls are put into place and there's some
25 determination scientifically about what is or isn't
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1 successful? You can' t do that? 1 that-- that I-- I want you to look at."
2 A. No, sir, I cannot. 2 Q. All right. And so he-- he sends you
3 Q. All right. Is there any -- is there any other 3 Exhibit 11 attached to the E-mail which is Exhibit 1,
4 data or science or anything that you can direct me to 4 correct? Right here.
5 for your contention that the program is effective, other 5 A. Yes, sir.
6 than what we've discussed, or in some cases not 6 Q. And by ''he" I mean Gary --
7 discussed? 7 A. Yes, sir, Gary.
8 A. No, sir, I can't. 8 Q. -- Gary at Narconon International.
9 Q. Now, in your-- in your I guess attempt to 9 A. Yes, sir.
10 determine whether or not the program is effective or in 10 Q. All right. So the guy at Narconon
11 your work up here, did you contact somebody at the -- at 11 International, Gary, E-mails you --
12 Narconon International and ask them to try to give you 12 A. No. Sir, I'm sorry. Gary is at Narconon
13 some -- some literature to support whether or not the 13 Arrowhead, not Narconon International.
14 Narconon program is effective at rehabilitating people? 14 Q. Got it. All right. So-- so Gary at Narconon
15 A. No, sir. 15 International E-mails you-- I'm sorry, strike that.
16 Q. Well, and the reason I'm asking, let me hand 16 Gary at Narconon Arrowhead--
17 you what's marked as Plaintiffs' Exhibit ll.. Have you 17 A. Yes, sir.
18 seen that before? 18 Q. -- E-mails you a copy of Plaintiffs'
19 (Thereupon, marked for identification 19 Exhibit 11?
20 purposes, Plaintiffs' Exhibit No. 11.) 20 A. Yes, sir.
21 THE WITNESS: Yes, sir. 21 Q. Now, what was it that Gary was suggesting that
22 BY I:vlR. HARRIS: 22 you do with 11? I mean, was there any further
23 Q. What is that? 23 instruction with it?
24 A. This is from Gary Smith. 24 A. Oh, he just -- he just said, "I want you to
25 Q. And I believe there's an E-mail in that pile 25 have heads-up o n ~ - on this."
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1 there in front of you; do you see that, Reverend? 1 Q. Well, this will short-circuit things; are you
2 That -- and I think --
3
4
A. What number is that, sir?
2 intending to rely on Plaintiffs' Exhibit 11 in any way
3 for your opinions?
4 A. No, sir. Q. I don' t know that we've marked it, but it was
5 the E-mail that came with the -- Exhibit 11. 5 Q. Are you intending to use it in anyway as a
6 A. I thought that was it. 6 demonstrative exhibit --
7
8
Q. No, that' s the--
MS. MARSCHALK: This "is the attachment
7
8
A. No, sir.
Q. -- when you testify?
9
10
1l
12
13
14
15
that came with the E-mail. 9 A. No, sir.
THE 'vVITNESS: Yeah.
!vffi.. HARRIS: Right.
10 Q. It has nothing to do with anything tbat you're
11 going to talk about?
THE WITNESS: so the E-mail, you gave me
the E-maiL
12 A. No, sir.
13 Q. So I don't need to talk about it?
MS. MARSCHALK: That's No. 1.
THE WITNESS: Okay. All right. Yes,
14
15
16 sir. I have -- 16
17 BY MR. HARRIS: 17
18 Q. Can you pull out No. 1? 18
19 A. Yes, sir. 19
20 Q. Thank you, sir. 20
21 All right. You were telling me what 21
22 Plaintiffs' Exhibit 11 is. What is it? 22
23 A. Yes , sir. This was what was E-mailed to me 23
24 after Gary Smith contacted me to call Ken Hart, and he 24
25 said that "I'm going to E-mail you some information 25
Page 110- Page 113
A. No, sir.
Q. All right. Well, that helps that out a lot.
A. Yes, sir.
Q. So why did you produce it to me?
MS. MARSCHALK: We can--
THE WITNESS: Well --
MS. MARSCHALK: -- go off the record, I
can tell you.
MR. HARRIS: Yeah.
MS. :MARSCHALK: That's fine.
THE VIDEOGRAPHER: Going off video
record.
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1 (Discussion off the record.) 1 Connection.
2 THE VIDEOGRAPHER: Back on video n:cord 2 Q. And, if you would, just give me an overview of
3 at 2:01 p.m. 3 the various programs that you've been affiliated with or
4 BY MR. HARRlS: 4 had some control over that use the Narconon technology,
5 Q. All r ight. So Plaintiffs' Exhibit 11 , then, 5 starting with that first program in 2003 and going to
6 we've discussed that, -- 6 the present .
7 A. Yes, sir. 7 A. Okay.
8 Q. --Reverend, you're not going to rely on 8 Q. Do you understand my question?
9 it, -- 9 A. Yes, sir.
10 A. No, sir. 10 Q. Okay.
11 Q. -- so we're not going to discuss it. 11 A. In -- I'm just trying to get my dates down.
12 A. No, sir, not at all. 12 In 2004, 2004,200- -- yeah, okay. 2004, I opened up a
13 Q. Okay. Now, you've said -- you've mentioned 13 First Step Withdrawal Program at my church. In the
14 several times during your testimony that you're familiar 14 community. And --
15 with the technology. And by that I assume you mean 15 Q. And that was called ... ?
16 the- the Hubbard technology that's used to address 16 A. That .was called (Pronouncing) COTA-gold and
17 drug and alcohol issues that' s embodied in the Narconon 17 the Narconon Connection.
18 course books? 18 Q. What is that fhst word you're saying?
19 A. Yes, sir. 19 A. (Pronouncing) Cota, C-0 --they don't
20 Q. And you've been trained by Narconon Arrowhead 20 pronounce it like that. But C-0-T-E-R. That stands for
21 in the Naiconon technology? 21 Communities--
22 A. Yes, sh. 22 Q. C-0 -- got it, got it, got it.
23 Q. If you would, explain to me how the technology 23 A. C-0-T-E-R. Stands for Communities of Tomorrow
24 is designed to address drug and alcohol problems or 24 Economic Redevelopment. That's a non-profit S01(c)3.
25 to -- to address drug and alcohol rehabilitation needs. 25 Q. All right. Co-- C-0-T-E-R, COTER, and
Page 115 Page 117
1 A. Okay. From - from my perspective, sir? 1 Narconon what?
2 Q. Well, you - you've-- you've-- well, that's 2 A. Connection.
3 a good question. Let me back up and take a stab at it 3 Q. Narconon Connection. And that's your first
4 this way. You have run a number of drug and alcohol 4 foray into using the Narconon technology?
5 programs in your career? 5 A. Yes, sh.
6 A. Yes, sir. 6 Q. Okay. And then after that tell me about the
7 Q. And at some point you, I asstime, were running 7 other organizations.
8 drug and alcohol rehabilitation programs that didn't 8 A. I started training ministers, people in the
9 rely on the Narconon technology? 9 community, on how to -- to do ministry using the
10 A. Yes, sir. 10 technologies and principles that I was exposed to. It
11 Q. And at some point, I think you told me in 11 also -- I was also -- also got qualified as a faith-base
12 2003, you-- you got a glimpse of the teclmology or you 12 initiative. And the requirement for faith base from the
13 learned about it and you thought, "Hey, this stuff might 13 State of Texas is that ~ - no treatment. All you could
14 be effective." -- 14 do is teach Bible, Bible Scriptures, and ethic or moral
15 A. Yes, sir. 15 issues as relate to substance abuse.
16 Q. --Is that fair? 16 Q. And this trainirig program, was it something
11 A. Yes, sir. 17 that was independent from the COTERand Narconon
18 Q. And then you began running progran1s or -- or 18 Connection?
19 operating programs that-- that utilize the technology? 19 A. No, sir; that was it. I -
20 A. Yes, sir. 20 Q. Same thing?
21 Q. What was the name of the -- the first program 21 A. 1 combined --1 combined the secular, which is
22 that you began to run that used the technology? 22 the technolo -- the teclmiques and principles, with the
23 A. That used the technology? 23 theological, which is Scriptures.
24 Q. Yes, sir. 24 Q. All right. So were you-- were you both, in
25 A. (Pronouncing) COTA-go and the Narconon 25 the COTER/Narconon Connection program, were you both
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Page 118 Page 120
1 treating people with addiction issues and training other 1 Q. --and I've seen a couple other churches that
2 ministers regarding -- 2 you've been affiliateq_ with, the Faith and something,
3 A. Yes. 3 The Heartland Drug Rehab, ~ n d I'm just trying to get an
4 Q. -- the use 4 understanding --
5 A. The same thing, -- 5 A. Yes, sir.
6 Q. -- of the -- 6 Q. -- of how that all comes together.
7 . A. -yes, sir. 7 A. Okay.
8 Q. How long did that go on? 8 Q. Your different churches where you've been
9 A. It started in 2004; it's still going on. 9 pa -- where you have been a pastor, --
10 Q. Still going on? 10 A. Yes, sir.
11 A. Yes, sir. 11 Q. -- it sounds like in each of those churches
12 Q. And what I was asking is, did you transition 12 there bas-- there has been some dmg program that --
13 to some other organization, is what I was trying to 13 that you have overseen that used the Narconoo
14 figure out. 14 technology? _
15 A. No, sir . They -- I didn't transition. But 15 A. Yes, sir.
16 they have. What I'm saying, with t h ~ information that 16 Q. Is that-- is that accurate?
17 was imparted to them, they took it back and made it fit 17 A. Yes, sir.
18 their situation. 18 Q. And what are those congregations?
19 Q. Okay. Now, that - that program; any other 19 A. You want to know their names?
20 programs that you've been involved with, if you could 20 Q. Yes.
21 give me the names of those programs that -- that use the 21 A. Okay. Connor Chapel, Arkansas.
22 Narconon technology? - 22 Q. And-- and what-- what time period were you
23 A. My-- my hes -- my hesitat --hesitation is 23 there?
24 that I have a list of ministers who were trained with 24- A. The start -- okay. All right. I gotta --
25 that technology, their locations and everything; I 25 okay, I' ll put it in a time frame here. My exposure to
Page 119 Page 121
1 didn' t bring that with me. 1 the L. Ron Hubbard technology and principles started
2 Q. Okay. So there -- there are other 2 with me in early 2000, 2001, 2002. Prior to that, I
3 ministers --what you're telling me, it sounds like, 3 pastored in churches that I utilized other ministries.
4. there are other ministers Who go through this COTER 4 12-step program. Any program that had or shared any
5 progro -- progratn, and they go off. and start their 5 kind of success in the community. That I knew of. So I
6 own -- 6 started pastoring in these churches in '84. So it
7 A. Yes, sir. 7 wasn't until around 2000 that I started jmplementing the
8 Q. -- Narconon-related programs? 8 training that I had along with what was existing. So
9 A. Well, not --not necessarily-- well, not -9 from 2000, Ward Chapel, Houston, Texas; Wayman Chapel,
10 necessarily Narconon, as opposed to they have ministries 10 Houston; Avery Chapel, Oklahoma City; St. Paul, Tulsa,
11 in their church we call ~ - what you might call a para -- 11 Oklahoma. I'm presently at Tulsa right now. So those
12 para-ministry. They're looking for-- there's-- you 12 are the four churches tliat, wherever I went, I was
13 won't fmd a church congregation that don't have some 13 looking for solution-oriented to help the people with
14 kind of drug problem in their parish or in their church. 14 drug problems.
15 And so one of the things that we were attempting to do 15 Q. And those four, those four churches, did those
16 was to fmd something that was accessible and 16 four churches thal you' ve identified for me, did they
17 affordable,_ and provide them a tool to use it if they so 17 have a drug and alcohol rehabilitation pro gram that
18 choose. So part of what I did was train ministers who. 18 relied on the Na.rconon technology7
19 came in to a location for two days, train them on what I 19 A. When I went there, they didn't have.
20 was exposed to. They saw what was being done, and they 20 Q. All right. But I'm --
21 took it back to their areas to implement it in_ their 21 A. Well -- oh, I'm sony, I missed the question.
22 ministry, in their church. 22 Q. That's what l'in trying to get at;--
23 Q. When you-- but when you were running this -- 23 A. Okay.
24 I'm just going to calllt Narconon Connection, -- 24 Q. -- obviously, you -- you started --
25 A. Okay. 25 A. Yes, sir, yes, sir.
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Page 122
1 Q. --these programs, I assume?
2 A. Yes, sir, I did.
3 Q. Okay.
4 A. And-- and when I say "start," I implemented
5 the principles and technology. Okay.
6 Q. And tell me how you did that.
7 A. Okay.
8 Q. Well, first of all, did you have to pay a
9 license fee in order to use the technology?
10 A. When I first -- yes, sir. When I first
11 started.
12 Q. Do you-- who did you pay the license fee to?
13 A. Narconon International.
14 Q. Did you ever--
15 A. That's --
16 Q. Did you ever pay it to ABLE?
17 A. Let me back up. Let me make a correction; my
18 memory came back to me. I signed a contract, but I
19 never paid anything.
20 Q. And what did you get in exchange for this
21 contract?
22 A. I got the right to use their marks, the sign
23 of the person, the Narconon ...
24 MS. MARSCHALK: The man jumping.
25 BY MR. HARRIS:
1
2
Q. Right;-
A. Yeah.
Page 123
Page 124
1 A. Yes, sir.
2 Q. What was the name of that treatment center?
3 A. I never opened it.
4 Q. All right . Why?
5 A. Number one, you had to-- number one, looking
6 at what I thought was success was, first of all, I had
7 to. find property in a rural area. I had to buy the
8 property. There was a budget. They said, "Don't start
9 anything unless you have about six to eight months to --
10 to --to 1un without getting a dime, " and I discovered
11 that that was not [sic] easier said than done. --
12 Q. Where ~ -
13 A -- They never --
14 Q. Where was it going to be, Reverend?
15 A. In Houston, Texas.
16 Q. Is there not a Narconon treatment facility in
17 Houston?
18 A. At the time, no, sir.
19 Q. Is there one now?
20 A. At the time, no, sir.
21 Q. Okay, I'm asking you right now. Do you know
22 if there's one now?
23 A. No, there's n o ~ - there's-- there's none now.
24 Q. So you decided not to -- not to open the
25 facility for --
Page 125
1 A. Financial reasons.
2 Q. -- monetary --
3 Q. -- you got to use -- 3 A. Yes, sir.
4
5
6
7
8
9
10
A. Okay. 4 Q .. -- reasons? Okay, fine.
Q. --the little logo thing. 5 All right. Let's look at some other stuff in
A. Righl. And-- 6 your disclosure. With respect to this L. Ron Hubbard
Q. The books? 7 stuff, first of all, it's your belief that-- that
A. And-- and-- no, I had to buy the books. 8 L. Ron Hubbard is a genius?
Q. All right. All right. All right. I got you. 9 A. He's a human being. And-- and there's some
A. I bought -- I bought those books. But the 10 genius in him, I will admit.
11 only thing I got was the privilege of using their marks 11 Q. Well, let me ask you tllis ; you were quoted in
12 if I put up anything, and -- and my originaL -- my 12 this article I'm about to hand you as saying that
13 original goal back in 2002 was to open up a Narconon -- 13 Hubbard is a genius. Did you say that, or not?
14 a Narconon-type treatment center in my community. That 14 A. At the moment at the time, I probably did. I
15 was the original-- that was the original goal. And so 15 did. I'm sorry, sir. Yes,--
16 when I applied for a license to do that, and that's 16 Q. You did?
17 how-- so you asked me the question, so I-- it was 17 A. -- sir, I did.
18 between Narconon International and-- you asked me the 18 Q. Okay. And you also said, quote, "I admire
19 question about ABlE; I understand from my experience, 19 hin1, I respect him, I consider him to be an angel that
20 sir, that ABLE handles all the rights of all the 20 came to help humankind to work out its problems"; is
21 material for L. Ron Hubbard. 21 that an accurate quote?
22 Q. All right. So you applied for a license for a 22 A. Yes, sir.
23 treatment center?
24
25
A. Yes, sir.
Q. Did you get the license?
23 Q. Now, tell me-- tell me why you believe he's
24 both a genius and an angel who came to help out
25 humankind.
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A. Okay. Here's why. I was exposed to some 1 Bul1ba1ting. You always going to be. And it takes the
edge off. So it helped me. 2 techniques and technologies that resignated [sic] within 2
3 myself, that I didn't realize, through the training. 3
4 Number one, what regs-- resignated [sic] in me was the 4
5 fact tbat most people, in my opinion, who are involved 5
6 in substances that they should not be taking--and let me 6
7 just call them poison, shouldn't be in their 7
8 system--come up against something in thei.J lives that 8
9 they can't handle, and they need some kind of assistance 9
10 to get them through. Now, when I was in the training, 10
11 most of the training that I received that week was from 11
12 persons who had been on dmgs, who had gotten off of 12
13 dmgs and decided that they would stay and help other 13
14 people get off drugs because of what it did to them, for 14
15 them, and it impressed me. The other thing that 15
16 resignated [sic] in me was, there were things that came 16
17 outside of me that if I was not exposed to some of the 17
18 techniques I would miss. Case in point; when I was 18
19 three years old--and J dwell on this--J saw something in 19
20 my past that is part of a template on who I am today. I 20
21 saw my father abuse my mother. And I promised God I 21
22 never wanted to be like hlm. He died an alcoholic, and 22
23 his father was an alcoholic. And according to the 23
24 stats, scientific information, that I was going to end 24
25 up being an alcoholic, 'cause it was just in my DNA. 25
So when I went out in the community, in my
connnunity, and I sat down and talked to people about
their situation and their condition, he call it
bullbaiting, they understand it as playing the dozen.
Any black person in the south, when you say "playing the
dozen," they know what that is. Case in point.
The other case in point is -counseling.
Counseling is taking a moment in time, bringing it up
and confronting it. All of the other programs I was
on--the 12 steps, the others--did not provide that kind
of information for me practical so I could take back to
my community and impact them because it impact me. And
apply it and it worked. Nobody pays attention to what's
going on in my community. So my passion has been, s.ir,
I don't c a r e ~ - there's a saying, ."Don' t care how much
you know until I know how much you care." And once I
know how much you care, I'll listen to what most of
[sic} you have to say, and once I listen to most of what
you have to say, I'll answer most of your questions.
And treatment of addiction deals with talk therapy.
It' s contradictory, but it works. The answer to an
individual problem lies in the indiVidual.
So all I'm saying to you is that the tech --
Page 127
And so that had an impact on me. That was
Page 129
1 that the technology that was shared to me and I paid
2 resignated [sic] by some of the training that I
3 received, and it has to do with counseling.
4
5
6
Q. Training that you received from Narconon?
A. Yes. I was--
Q. Okay.
7 A. -- exposed to -- here I went to learn how to
8 deal wilh addicts, and they're teaching me on
9 communications. On confronting, on assists, on light
10 objectives. What did that have to do with me? Well, in
11 my tradition, case in point, bullbaiting. Where I come
12 from in the south, it was called playing the dozen.
13 What was the nature of that? Growing up in a segregated
14 community, they useci. theN word, nigger. So among
15 ourselves we would bullbait, we would play the dozen on
16 each other, so when it actually happened out in the
17 community, you wasn't sharp to respond to it. So when T
18 saw them bullbaiting, I saw, in my tradition, playing
19 the dozen. And what it does is, you hear something for
20 the first time, and you overreact on it. But if you
21 hear it over and over and over and over again, it take
2 $500 for, I was able to bring it in my community and
3 tailor it and help people to get off of drugs. So
4 that's --I'm just giving you some examples.
5 The example about the-- the assists, well, in
6 my community, when somebody fell down, the mother o.r the
7 auntie or the cousins, they come in, "Where did you
8 fall? Let me kiss it. Does it feel better?" "No."
9 "Let me ldss it again. Does it feel better?" "Yeah."
10 So what I'm saying to you is that I was exposed to
11 things that I was able to use. I didn't know it, but I
12 didn't understand the grid. And so, when we talk about
13 those things that people say ls mess, I apply it in the
14 community. And it works.
15 And so that's how when I say that L. Ron --
16 L. Ron Hubbard was a genius or he was an angel, he
17 shared stuff with me, things with me, principles with
18 me, through his reading, that resignated [sic] in me,
19 that I applied in my community, and it helped the
20 person. Because anything a person cannot confront, they
21 don't deal with.
22 the edge off you. So when you're out there when you 22 Case in point. I've counseled people who were
23 hear it-- example. "You're a drug head, you always 23 molested, and when they think about it today, because it
24 going to be a drug head. Your daddy was a drug head, 24 has never been dealt with, they have to get out of their
25 and you going to end up being a drug head. '' 25 head, get out of themselves. In the training, they use
http://ReachingForTheTippingPoint.nett
Multi-Page TM
Page 130
1 examples. For me, it was stimulating, because I took 1
2 what I saw and said I'd never be like that. For other 2
3 people, who have been molested, they tell no one, and 3
4 they grow up, and that's some of the pain that they have 4
5 and they share. 5
6 So my point is that my training with the 6
7 technologies and techniques afforded me the opportunity 7
8 to go in my community, and it helped get people off 8
9 dtugs. Was that all that I use, no, sir. Because the 9
10 requirement was that I had to teach-- to be faith-base, 10
11 I had to teach Bible and Scriptures. So what I did was, 11
12 I met with Narconon InternationaJ and I said, "I no 1 ~
13 longer want to be your liability. I no longer want to 13
14 use your marks. Because what I'd like to do is make i 14
15 faith-base , and you got secular stuff. And I believe 15
16 that that principle that you're using, anybody can use 16
17 it tailor-made, and I'd like to be the model to it. " 17
18 Q. Okay. 18
19 A. So that' s what I learned from that exposure. 19
20 So when you hear me use those ex -- those examples, I 20
21 was-- the context of where I was, I was around about, 21
22 my God, 800 or a thousand people that-- they sitting in 22
23 the room -- the rooms, but I was in that context, and I 23
24 probably -- I did say it. But in the context of where I 24
25 was. And the genius? Yes. I did say it. 25
Page 131
A. Compound question.
Q. Well , okay, let's break it up.
A. Please.
Page 132
Q. You have, on a number of occasions, publicly
stated that you believe that the Narconpn program was an
effective program?
A. Yes, sir.
Q. Your wife used to work for Narconon?
A. Yes, sir.
Q. And you have also, on at least one occasion,
spoken out on behalf of Scientology, have you not , sir?
A. Yes, sir.
Q. In fact , you spoke -- you were one of the
featured speakers when the Church of Scientology I guess
opened-- I guess it's a church, --
A. Yes, sir, it was a church.
Q. -- in Dallas?
A. Yes, sir.
Q. So it's fair to say that you have publicly
gone on record supporting both, fair?
A. Yes, sir, that's fair.
Q. And you -- and you have I think explained to
us your-- your feelings and why you have them regarding
admiration, at least to s o m ~ extent, for Mr. Hubbard.
A. Okay. I -- I have admiration for L. Ron
Page 133
1
2
3
Q. Okay. All right. 1 Hubbard because, number one, he' s smar t. And smart in
MR. HARRIS: Let's take a little break.
I need --
4 THE VrDEOG;RAPHER: Going off video
5 record.
6 (Recess at 2:30, resumed at 2:39.)
7 THE VIDEOGRAPHER: NOW back on video
8 record at 2:39p.m.
2 the sense that he took a -- a -- a person in prison who
3 wrote him, who read the book "Fundamentals of Thought,"
4 and William Benitez was a loser. In fact, the story is
5 that they told him get -- the best thing he can do is go
6 get a gun and go and bla -- blow his brains out. He
7 chose to read. He went in the library, and he read the
8 book "Fundamentals of Thought ." And wrote L. Ron
9 BY MR. HARRIS: 9 Hubbard. And for me that's where the story starts. For
10 Q. Okay, Reverend, when we broke we were talking 10 me. That's where my story starts.
11 a little bit about your experience with -- with learning 11 Q. When you utilize the Narconon teclmology in
12 the Narconon technology. 12 the programs that you've been involved in, with, have
13 A. Yes , sir. 13 you been -- have you been forthright and honest with
14 Q. And it 's fair to say you gave me a -- a fairly 14 folks who went through the program about the fact that
15 lengthy response to my question about why you believe 15 the program was based orr the writings of L. Ron Hubbard?
16 L. Ron Hubbard was a-- was a genius. The bottom line 16 A. State that again.
17 is, you-- you have a great deal of respect for his 17 Q. Have you been -- when-- when people go
18 writings; is that a fair summary? And some of what 18 through this program, the programs tha.t you've been
19 you've learned resonated with you personally and you 19 involved in, --
20 felt like it was important?
21 A. As it relates to the material that I've been
22
23
exposed to through Narconon Arrowhead, yes.
Q. And you have, on a number of different
24 occasions, publicly supported both Narconon and the
25 Church of Scientology?
20
21
22
A. Yes, sir .
Q. -- that have used the Narconon teclmology, --
A. Yes, sir.
23 Q. --have you always been honest and forthright
24 with those folks about the fact that --
25 A. Yes, sir.
Page 130 - Page 133
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Page 134 Page 136
1
2
3
Q. -- the program's relying on--
A. Yes, sir.
Q. -- Hubbard technology?
4 A. Yes, sir.
5 Q. Did you disclose to those people that L. Ron
6 Hubbard, in addition to writing the technology used in
7 the program, was also the founder of the Church of
8 Scientology?
9
10
11
A. Yes, sir.
Q. Okay. And why did you do that?
A. Because when I was fos -- first exposed to
12 Narconon Arrowhead, my wife picked up a book called
13 "Freedom" that wasn't addressed to her, she started
A. How many people do you thinlc know that Martin
2 Luther King got a principle out of Hinduism,
3 non-violence, Mahatma Ghandi, and used it to change
4 attitudes and behavior around the world? Most people
s don't lmow that. They just talk about the results.
6 Q. Are you drawing some comparison between
7 Hinduism and Scientology?
8 A. It's a religion. It's one of the 10,000
9 distinct religions on the planet.
10 Q. All right. Well, let's talk about that for a
11 second. Your-- one of your opinions, or your second, l
12 guess, opinion is that the techniques and principles
14 readening [sic] it, and she saw Narconon Arrowhead 14
15 Crimanon, and a program out of Philadelphia, and she 15
16 called me and she said, "I found something that you
13 embodied in the Narconon technology do not rely upon
Scientology.
A. In my opinion -- well, let me think about
16 that. State that again?
17 could use in your ministry. And she said, "How would
18 you feel if Scientology was involved in it?"
19 At the time, I was teaching Introduction to
20 World Religion and Philosophy at a junior college. And
21 we were studying religions. And so I included
22 Scientology into the curriculum and did some research on
23 iL And my response to her was that, based on my
24 tradition and my faith, that the Creator is fust and
25 the creation is second. And most religions are
Page 135
17
18
MS. MARSCHALK: Hang on a second. It's
in this -- it's in here, if you want to look
19 at it. Are you talking about the very
20 first ...
21 BY MR. HARRIS:
22 Q. Yeah; look at-- look at number-- Page 4.
23 A. Okay.
24 Q. It says, "However; those principles and
25 techniques do not rely upon --" --
Page 137
A. Okay.
Q. -- "or require a belief in Scientology." And
I want to talk about the first part of that sentence,
if -- if you're okay with that. If I'm reading it
incorrectly, you tell me, but.it looks to me like you've
got two different things you're saying there. Number
one, the principles and techniques do not rely upon
1 philosophical that comes out of the mind of man. And 1
2 so, according to my feelings , my tradition and my faith, 2
3 I can embrace a philosophical principle or thought that 3
4 doesn't affect my belief. And so I was able to embrace 4
5 it, and therefore when I went to my community, that' s 5
6 one of the first things I shared with them, because that 6
7 was one of the first things they shared with me, and 7
8 guess what. They didn't care. If results were there, 8 Scientology. And secondly, they do not require a belief
9 and the techniques, they didn't basically care who it
10 came from. But I -- but to answer your question, I made
11 sure.
12 Q. All right. 'Cause it' s only --it's only fair
13 to let people know --
14 A. I'-- I understand.
15 Q. Right, you agree with that?
16 A. Yes, sir. Yes, sir, I do.
17 Q. It's only fair to let people know what the
18 technology that they're being exposed to is based on?
20 BY MR. HARRlS:
21 Q. You agree with that?
22 A. I really don't,
23 Q. You don't agree?
24 A. Here's why. Here's why.
25 Q. Okay.
Page 134- Page 137
9 in Scientology. Is that a fair way of reading what you
10 intended there?
11 . A. Yes , sir.
12 Q. All right. So let's take -- let's - let's
13 talk about the first one first. Do -- do you have the
14 opinion that the principles and techniques embodied in
15 the Narconon program do not rely upon Scientology?
16 A. Yeah, I agree with that.
17 Q. Okay.
18 A. That's my opinion, yes.
19 Q. All right. Tell me every bases for that
20 opinion.
21 A. To rely on something, . I define as it depends;
22 that if you don't rely upon it, it won't work. And I'm
23 saying that, based on my experience working with persons
24 and addiction, that they knew nothing of Scientology,
25 didn't care about Scientology. And when I shared it
http p:/ ://ReachingForTheTippingPoint.net
Multi-Page TM
Page 138
1 with them, the bottom line is, can you help 1
2 me?" 2
3 Q. Yeah, and that was really the third pa1t, 3
4 and I was trying to ask a different question; let me 4
5 take another shot at it. 5
6 A. Okay. All right. 6
7 Q. It sounds to me like you're saying that what 7
8 is in this technology, the principles and techniques 8
Page 140
book and principles of Scientology.
Q. Well, it goes beyond that, doesn't it,
Reverend? There -- there are actually eight levels or
eight modules in the Narconon program, and there are
corresponding books and programs from basic Scientology
that equate to each one of those eight levels?
A. Yes, sir.
Q. You agree with that?
9 that are in the technology themselves do not rely upon 9 A. Yes, sir.
10 the principles and techniques of Scientology; do you-- 10 Q. Okay. So your opinion that-- that the
11 do you understand my distinction? I'm not talking about
12 whether you believe in Scientology or not; --
11 p1inciples and techniques don't rely upon Scientology
12 isn't accurate, is it?
13 A. Okay.
14
15
Q. --I don't care about that right now.
A. All right. Okay.
16 Q. You seem to be having the opinion that the
17 stuff in books 1 through 8 of this program, these
18 principles and techniques, do not rely upon the
13
14
15
16
17
18
19
A. No, it's not inaccurate.
Q. Okay. to me--
A. Let me -- I'll tell --
Q. -- bow that -
A. Let me -- let me explain to you --
Q. All right.
A. -- from -- from my observation. My first 19 principles and techniques of Scientology; is that your
20 opinion?
21 A. Yeah, that's my opinion.
20 client with withdrawal was _Scientologist. Even though
21 there're correspondents, they could not make the
22 Q. And you-- you have reviewed Dr. Kent's
23 deposition, .have you not?
22 connection between Scientology and the principles of
23 withdrawal from drugs .. That's my experience. My first
24 A. Yes, sir:
25 Q. And you've seen where Dr. Kent has gone
24 client was Scientologist. They they could not make
25 the connection.
Page 139
1 through the books and he basically has opined that each 1
2 of those books has a corresponding course that's 2
3 essentially basic Scientology? 3
4
5
6
7
8
A. Yes, sir. 4
Q. You've read that? 5
A. Yes, sir. 6
Q. You don't agree with that? 7
A. I agree with the corresponding -- I -- J agree 8
9 with what he said. 9
10 Q. So -- so there are eight steps in the Narconon 10
11 program, and you agree that each one of those eight 11
12 steps, each -- each one of those modules, which you're 12
13 familiar with, -- 13
14 A. Uh-huh (affirmative), 14
15 Q. --has a corresponding module that is found 15
16 in-- in Scientology? 16
17
18
19
A. Which I discovered, yes, sir. 17
Q. What do you mean, you "discovered" it? 18
A. See, what came first for me? What came first 19
20 for me was the technology and -- and - and techniques. 20
21
Page 141
Q. And is that someone you're unwilling to
identify?
A. Get approval from the man, I'll give you all
the information ...
Q. Well, I mean, are you relying on that person
that you just described?
A. No. But that' s --but -- but all I'm saying
is, you said -- you said, "How did you come up with what
you said?" And that is one of reasons why I made
that statement. And I stand by it. That's my opinion.
Q. Yeah, and I'm-:- and again, I'm doing what I
did before on this effectiveness issue; -
A. Okay. I got you.
Q. -- I'm trying-- I'm trying to understand
where you -- what you're basing it on .
A. I understand. I understand.
Q. All right. And your opinion is that the
principles and techniques embodied in these eight levels
don't rely upon Scientology? That's your opinion?
A. In my opinion.
Q. And the reality is, though, that there are 21 I've never gone through and -- as a theologian, I've
22 never gone through a Scientology Bible or book or -- but
23 I've gone through the principles and materials in the
24 eight books and- the eight books. And I've dlscovered
25 that there arc corresponding associations between the
22 eight levels of the Narconon program, and you agree with
23 me that all eight levels have a corresponding level in
24 basic Scientology?
25 A. Well, let me say this to you. Based upon my
James Jerry McLaughlin, 3-6-12 Multi-Page Desmond, et al. vs. Narconon, et al.
Page 142 Page 1 ~ 4
1 knowledge, there are some things in Scientology that's
2 not in the eight books for the training for Narconon
1 Scripture and things of that nature?
2 A. Yeah.
3 Arrowhead or Narconon Georgia or any of the books that 3 Q. Tell me what they told you.
4 is sent out. 4 A. Well , let me say what the results were.
5 Q. And you under-- you know that wasn' t my 5 Q. Well , tell me what they told you first, and
6 question. My question was not whether or not the eight 6 then you can tell me what the results were.
7 levels embody everything in Scientology. 7 A. Well, what-- what they mentioned was that, as
8 A. Okay. 8 you mentioned, that "We don't want to compromise the
9 Q. That's not what I asked you. 9 technology.
11
And my question to them was, "You market
10 A. Yeah, I-- but -- but -- I -- then I didn't 10 your withdrawal product, yon export it, and you have a
11 understand, because what-- what it sound like for me, 11 disclaimer. So what's the difference between what I do
12 and then-- okay, well, work with me on that. 12 and your disclaimer? You're disclaiming." And so they
13 Q. Okay. Let's --let's muddle through it. 13 agreed. And so when they agreed, we discontinued the
14 A. Okay. 14 Narconon International contract.
15 Q. First of all, you've seen the program at 15 Q. But are you still -- or, did you continue to
16 Narconon Arrowhead, and the books that they use, and 16 use the technology?
17 the -- and the training materials , etcetera? 17 A. I use it in a different-- a different mam1er.
18 A. Yes, sir. 18 Q. But you don't use their books?
19 Q. And you've seen the training materials at-- 19 A. No. -
20 at a bunch of other Narconon facilities, have you not? 20 Q. And that's because they-- they told you that
21 A. Yes, sir. 21 if you're going to deviate and you're going to add
22 Q. And all of those training materials are 22 faith-based stuff to the technology, that that's not
23 virtually identical? 23 what they wanted you to do?
24 A. Yes, sir. 24 A. No, they didn't say that. They just said,
25 Q. Because that's part of the technology? 25 "You're on your own."
Page 143
1 A. Yes, sir.
2 Q. You can't-- you can't deviate from it?
3 A. That's correct, sir.
4 Q. Because that's one of the main Hubbard
5 principles, is, you follow the technology as written if
6 you want it to be effective?
7 A. Yes, sir.
8 Q. Otherwise, you -- you steer into verbal tech,
9 which is forbidden, right? Right?
10 A. Verbal tech, I -- well, in principle I agree
11 with you.
12 Q. Well, I mean, is that something that you've
13 been trained, as someone who's trained in how to
14 administer the Narconon program?
15 A. There are things that I've been trained in,
16 give me knowledge, but l don't necessarily use it. lf
17 you recall, I said I met with Narconon International
18 where there was a -- there was a -- a transition from a
19 contract that is no -- that no longer exists between us.
20 And what changed it was the fact that I was injecting
21 Bible with practical techniques. And that is
22 faith-based, and their material is not faith-base .
23 Q. Well, did someone from International express
24 any concern about you doing that, about you sort of
25 commingling both the -- the technology as written and
Page 142- Page 145
Page 145
l Q. Olcay. How's --
2 A. Yeah. And--
3 Q. --that any different than what I just said?
4 A. Yeah, okay. Well, "You're on your own.
11
And
5 what I'm saying is that they made it clear that the
6 information was secular, <md I was introducing another
7 phase of it in order to get the technology, the
8 technical principles which I gave you example of, that I
9 put Scripture to some of it and came up wi th a faith
1 o step, which is not a pmt of them, first step, and the
11 first step deals with the technology, and the faith step
12 deals with the theology.
13 Q. Of those hundred people that you told me
14 earlier you were relying on for your opinion that it was
15 effective, what percentage of those p e o p l ~ did you use
16 pure Narconon technology and what percentage did you use
.17 a hybrid combining Narconon technology with Scripture?
18 A. All of the training that I ever gave after my
19 training was hybrid.
20 Q. So all hundred folks that you're relying on
21 for your opinion that the Narconon technology is
22 effective, all hundred of those, you didn't really use
23 pure Narconon technology, you used a combo of N arconon
24 technology coupled with ScriptuTe?
25 A. Always have.
Desmond, et al. vs. Narconon, et al. Multi-Page James Jerry McLaughlin, 3-6-12
Page 146 Page 148
Q. So you don't have any experience in-- in 1. believe --
2 determining the effectivenes.s of Narconon technology 2 Q. Thetans?
3 independent from cou - coupling it together with some 3 A. Pardon me?
4 sort of Scripture, -- 4 Q. Do you believe in thetans?
5 A. And-- 5 A. Well, no, I don't. They consider me to be a
6 Q. -- fair? 6 thetan, but I-- I don't know what-- you know, I mean,
7 A. And-- yes, sir; and it defines -- it defines 7 here again, it's the person who makes the definition
8 faith-base. It defmes for me that the technology and 8 decides the outcome. And that's one of the problems I
9 principles can be used by any other religion who wants 9 have about trying to understand. We change words and
10 to use it to improve their program, if needed. 10 definitions , and we want it to fit what we want it to
11 Everybody won't respond to it. Everybody is not 11 fit. So it works both ways, and et cetera.
12 necessarily -- 12 Q. Did -- did you have a ethics ot1icer in your
13 Q. Well, but-- 13 programs?
14 A. -- into it. 14 A. A ethics offi cer in my program?
15 Q. --when you started using it in that way, or 15 Q. Yeah. Do you know what that means?
16 at some point when you were using it that way, I think 16 A. Yes, sir.
17 in your. words they told you, "You're on your own"? 17 Q. Okay. Did you have that? I mean, you--
18 A. Well -- well, on my own in the sense that I 18 A. I am the ethic officer.
19 had used it to the point that I felt it was time for us 19 Q. Okay. Well , and did you-- did you assign
20 to meet and just sit down and talk about it, because I 20 conditions for any ethics breach?
21 was heading in that direction. And I knew that all of 21 A. Yes , sir. --
22 my Jmowledge and my experience with them, that it was 22 Q. And --
23 not faith-base. I mean, we also know that the focus 23 A. --Yes, sir.
24 of -- well, I just knew it -- it -- I just wanted them 24 Q. And how did you determine -- and you
25 to be clear. And the fact that the technology would 25 understand that in -- in Scientology those conditions,
Page 147 Page 149
1 not-- the -- what I would be using wasn't 1 when someone is out ethics, those conditions, and how
2 contradictory. 2 you're supposed to get back in ethics, those ar e
3 Q. that was your opinion, that, "Hey, I can 3 conditions that are typically outlined in-- in
4 reconcile these two things, " but you would agree with me 4 Hubbard's other writings, other than the Narconon
5 that they didn't agree with you? 5 program?
6 A. Well, the bottom line, just like we trying to 6 A. I didn't tell you I believe everything--
7 understand each other, I think they had to be clear on 7 Q. No, I didn't --
8 what I was trying to accomplish. 8 A. -- he said.
9 Q. And I understand that, Reverend, but you 9 Q. -- ask you that.. I asked you how did you
10 understand my question, which is, at the end of the day 10 decide --
11 you said, "Look, what I'm going to do is, I'm going-- 11 A. Okay. Here's how to -- I decided. In my
12 I'm going to merge these things together. I'm going to 12 training, w1der license by the State, you have to take
13 use my faith-bates - my faith-based pmgram, my 13 so many hours of ethics. And I applied, in the program
14 teachings of Scripture, and I'm going to add some 14 that I was offering, Biblical principles--that's what
15 elements from the Narconon program; I'm going to cobble
16 those together I Lhink that's effective," and
15 faith- base meant--and ethics based on my training by the
16 State.
17 they said, "Well, we don't want you to do that; you're 17 Q. Do you- do you understand the-- the use of
18 on your.own"? 18 the term "ethics" in Scientology-related institutions
19 A. No, they didn't say that. They didn't say, 19 and how that term is defined?
20 "We don't want you to do it." They said, "It's been 20 A. My limited knowledge, yes.
21 working for you. You have shown us that we can export 21 Q. Okay. And. it didn't-- it sounded to me, what
22 the technology." And really, really, that's one of the 22
23 advantages that being a non-Scientologist have had for 23
24 me. I'm a Protestant who believes in my faith, and 24
25 that -- I don't believe in the eight dynamics. I 25
I heard you saying is that's not the way you were using.
it; you were using it more in the context of moral
and --
A. That-- and that's what faith-base mean. I
Page 146- Page 149
Multi-PageTM
1 had to --
2 Q. Got it.
A. Okay.
Page 150
3
4
5
6
Q. No, I didn't mean to interrupt you, I just--
A. Okay.
Q. I lmderstand. I mean--
7 A. If you got it, I'm finished. If you got it.
8 Q. You-- you were-- you were not behav --you
9 were not, nor did you consider yourself, an ethics
10 officer in your program who was assigning conditions
11 that were defmed by Scientology principles; is that
12 fair?
13 A. That's fair. That's perfect
14 Q. ' Cause you don't even know what those
15 principles are?
16 A. I've been exposed to ethic officers. I've sat
17 in practically every position they have there, learning.
18 And there are certain judgments and decisions that I
19 made that has to do with that. But I .use --I explained
20 that to you.
21 Q. Yeah. You did. Did you all have a sauna at
22 your program?
23 A. Yes, sir.
24 Q. And how did-- how did that work? Did you
25 have it on site, or did you have it off site?
Page 151
A. I had it on site. 1
2 Q. All light. Now, going back to what we-- we
Page 152
1 through 8, and those program modules, have corresponding
2 Scientology teachings and levels that are almost exactly
3 the same?
4 A. Yes, sir.
5 Q. All right. So I guess I don't understand how
6 you can come to the opinion that the principles and
7 techniques don' t rely on Scientology.
8 I mean, if you don't-- if you want to reuact
9 that, that's fine.
10 A. Let me think about it.
11 Q. What do you want to think about?
12 A. The -- the question.
13 Q. Oh, you want to thinlc about it right now, or
14 do you want --
15 A. Well, as we --
16 Q. -- to go home and think about it?
17 A. -- go -- as we go -- would you allow me to go
18 home and think about it?
19 Q. I' ll allow you to do whatever you want. --
20 A. Okay.
21 Q. --But as you sit here today, you're--
22 you're-- you would agree with me that-- that these
23 books seem to be exactly the same, so it sure does seem
24 like that books 1 through 8 rely upon the basic tenets
25 and principles of Scientology. We can at least have
Page 153
1 that agreement --
2
3 were trying to sort of focus on, and I think you and I. 3
A. They -- yes, basically, yes.
Q. All right.
4 got a little far afield there, but-- 4 A. And -- and here's the-- here's -- is -- is --
5
6
A. Okay. 5 is -- example. Just like you asked about Exhibit 11.
Q. - ~ I ' m just simply trying to understand your 6 You said, "I don't want you getting in trial and jury,
7 contention that the prindples and techniques embodied 7 and facing the jury and bringing this up. Are you going
8 in the Narconon books, the books 1 through 8 -- which I 8 to bring this up?" No. We're finished with that. That
9 think you would agree with me that at least in the 9 question that you're asking me, I do know that there are
10 traditional Narconon program are meant to be followed 10 things in Scientology that I have not seen in the book,
11 specifk:ally, without adding anything to them? 11 so there are possibly corresponding things that is in
12 A. Yes, sir.
13 Q. It sounds like you were doing something
14 different, fair?
15 A. Yes, sir.
16 Q. But the traditional program, and in -- in .
17 particular the one used by Narconon of Georgia, that
18 program was-- was supposed to follow the Narconon
19 technology as written, without deviating from it?
20 A. Yes, sir.
21 Q. You -- you agree with that?
22 A. Yes, sir.
23 Q. Okay. And so what I wru1t to know is, books 1
24 through 8 of the Narconon of Georgia program, I think at
25 the end of the day you agree with me that those books 1
Page 150 - Page 153
12 Scientology that may not be in those eight books.
13 Q. And I don't disagree with you, 'cause, as we
14 lrnow, there -- there are different levels --
15 A. Okay. So --
16 Q. -- of Scientology.
17 A. -- so -- so when I'm -- my experience here is
18 just with the information that I've been exposed to and
19 my experienc;e that I've used. Now. Okay. So I'm
20 finished with that.
21 Q. Well, so what you're saying is there may be
22 things in Scientology that are not in the 1 through 8
23 modules of N arconon?
24 A. Yes.
25 Q. And --
Desmond, et al. vs. Narconon, et al. Multi-Page TM
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A. The E-meter, --
Q. Yeah.
Page 154
1 referenced --
2 A. Nowhere.
3 A. -- the E-meter. -- 3 Q. -- in books --
Page 156
4 Q. Exact -- 4 A. OT, as you mentioned, is nowhere referenced
5 A. -- I don't even lmow what that is, -- 5 in-- in --in-- in the eight books .
6 Q. And OT- 6 Q. All right. And Lhat --and that's exactly my
7 A. --never seen it, don' t-- you lmow. 7 point, is that these-- these 1 through-- these books 1
8 Q. OT 1 through 7 and all that sort of stuff, 8 through 8, they don't mention theE-meter?
9 that's not in books 1 through 8? 9 A. No, sir.
10 A. No. 10 Q. And we know that the E-meter is important in
11 Q. But -- but -- so you and I have an 11 Scientology?
12 understanding and agreement that there may well be 12 A. Yes, sir.
13 things in Scientology teaching that are not found -- 13 Q. They don't mention auditing?
14 A. Yes, sir. 14 A. True.
15 Q. -- in books 1 through 8? 15 Q. But we know auditing is --
16 A. Yes, sjr. 16 A. Yes, sir. Yes, sir.
17 Q. 1;1ut you understand that'-s not what I was 17 Q. They don't mention a nwnber of other things in
18 asking you. I was asking you simply this; that books 118 Scientology?
19 through 8, those books, those levels, - 19 A. Right.
20 A. Yes, sir. 20 . Q. But-- but what they do do--that's a good--
21 Q. --have corresponding levelsin Scientology 21 bad way to put it-is they do have levels 1 through 8
22 that are virtually identical? 22 which correspond to basically level s 1 through 8 of
23 A. "Virtually identical." The thing that I'm 23 basic Scientology?
24 concerned about, sir, is I don't want somebody to bring 24 A. Okay. You put it like that, l agree with,
25 up some books of Scientology and said, "This is what you 25 that. I agree with you, sir.
Page 155 Page 157
1 said, Reverend. This is what you said. E-meter's in
2 here."
1 Q. Fair enough.
2 A. Okay?
3 Q. Well-- 3 Q. All right. And so then we -- then we can move
4 A. "This is in here. This is what you said." 4 on from that.
5 And that's not what I'm saying. And so that's what I'm
6 struggling with.
5 A. Yes, sir.
6 . Q. You're going-- you're going to think about
7 Q. Well, we can go through each one of these 7 whether or not this statement that these --
8 books if you want to. 8 A. No, I'm finished with it. You made it clear.
9 A. Well-- 9 You--
10 Q. But I'm -- I'm -- I'm comfortable leaving 10
11 it -- 11
12 A. I'm more concerned about the comparison, 12
13 because I haven't looked at what you say in terms of tl1e 13
14 Scientology part. I haven't- I haven't reflected and 14
15 saw that like I know about what I've reviewed. 15
16 Q. Well, then, if you haven't done that, then how 16
17 in the world do you have the ability to say that-- that 17
18 those principles don't'rely on Scientology? What's the 18
19 basis for your -- 19
20 A. That's my opinion. 20
21 Q. Okay. What's it based on? 21
22 A. My-- based on what I've read, my experience, 22
23 and I -- and I -- and -- and I know that the E-meter is 23
24 involved in the Church of Scientology.
25 Q. Right; but the E-meter is nowhere
24
25
Q. You agree with me?
A. Yeah.
Q. So you--
A. No, no, no.
Q. -- withdraw that opinion?
A. I with -- I'm saying that I agree with what
you said. As long as those -- those what you mentioned
does not come back and say, Well, Reverend, that's what
you agreed to. You said --" --
Q. All right. Well, let's modify your opinion,
then. Those principles and techniques by -- embodied in
books 1 through 8 of the Narconon program rely upon
corresponding basic Scientology principles?
MS. MARSCHALK: Hang on, let me -- can I
listen to you -- can you have the court
reporter read that back one more time, Jeff.
Page 154 - Page 157
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Page 158 Page 160
1 Or say it again.
2 BY lv1R. HARRIS:
3 Q. Did you understand it?
4 A. Read it -- read it again.
5 Q. Okay.
6 MR. HARRIS: can-- can you read it
7 back, Jo?
8 (Thereupon, the record was read by the
9 court reporter.)
11 THE WITNESS: And now -- but what about
12 "or require a belief in Scientology"?
13 BY MR. HARRIS:
14 Q. We haven't gotten there yet.
15 A. Are we getting ready to work on tbat?
16 Q. We're getting ready to work on that.
17 A. Okay . .
18 Q. But tbat won' t take very long.
19 A. All right.
20 Q. Do you agree with my description of your
21 modified opinion, yes or no, sir?
22 A. I don't feel comfortable with that.
23 Q. Well, what-- what part of it do you not feel
24 comfortable with?
25 A. Let me think about it.
1
Page 159
Q. You mean after your deposition? Or as you sit
2 right here?
3 A. Let's -- let's go ahead and -- and deal with
4 the other part and come back to that part.
1 record at 3:16p.m.
2 (Recess at3:16, resumedat3:20.)
3 THE VIDEOGRAPHER: Now back on video
4 record. The time is approximately 3:20p.m.;
5 this is tape number 3.
6 BY lv1R. HARRIS:
7 Q. All right, Reverend, we had a little break .. I
s don't remember whether there was a specific question
9 pending when we broke or not, but if there was, then
10 I'll withdraw it.
11 You and I have had a discussion about the
12 first eight lev -- or, the eight levels of the Narconon
13 progran1?
14 A. Yes, sir.
15 Q. And in light of that discussion, do you wish
16 to change any of the language of the disclosure or the
17 opinion that has been provided to me in advance of yom
18 deposition?
19 A. Yes, sir. I'd like to offer a change in that
20 sentence. In here what I'd like to say, "However, those
21 principles and techniques do not require a belief in
22 Scientology, and are effective in educating and
23 rehabilitating people who are addicted to drugs and
24 alcohol regardless of their belief and spiritual
25 black background." I struck out "rely upon."
Page 161
Q. All right. So you-- you no longer have the
2 opinion, then, that those first eight books, those
3 principles and techniques, do not rely upon principles
4 of Scientology?
A. I struck out --that's- that's what I'm
going to say.
5 Q. Well, sir, that's-- I want finality here. 5
6 If-- if you're telling me that you want to go home and 6
7 think about this, that' s fine, that's certainly your 7 Q. You don't have any opinion about it at all,
8 other than-- you're-- you're -- 8 right. If you're telling me you want to mull it over as
9 we sit here, that's certainly your right, and if you're
10 telling me that you don't agree with me, that's
11 certainly your right. I just need -- I just need a
12 direct answer.
13 I have modified your opinion based on our
14 discussions. And I need to lmow whether, sir, you agree
15 with the opinion that I --that I've modified.
16 A. Okay. Let me --let me-- just give me a
17 minute here.
18 Q. Sure.
19 A. Okay.
20
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THE VIDEOGRAPHER: Sir ...
MR. HARRIS: Actually, we can go off the
record and give you a little bit of time
while he changes tapes.
THE WITNESS: Okay:
Page 158 - Page 161
9 A. I gave opinion. I -,
Q.No,l-- 10
11 A. -- struck it out.
12 Q. Okay, but there's-- just to be clear, I need
13 to know whether or notyou' re going to come into court
14 and you're going to say, "Hey, those eight books rely
15 upon Scientology," or "don't rely upon it"; you're
16 withdrawing--
17
18
19
A. I'm with --
Q. -- your opinion?
A. --drawing "rely upon." I will not use that
20 anywhere, anyhow. It's out of the sentence, it's out of
21 my vocabulary.
22 Q. And you are not going to come into court and
23 testify either way, that the books, the eight levels of
24 Scien --or, the eight levels of Narconon, that they
25 rely upon principles of Scientology, or don't, you're
Multi-Page TM
Page 162
1 withdrawing that, so I don't-- 1
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A. I'm withdrawing that. 2
Q. --need to talk to you about it? 3
A. Yes, sir. 4
Q. All right . We have that understanding? 5
A. Yes, sir. 6
7 Q. All right. And then so -- then your opinion, 7
8 we've talked about the principles and techniques are 8
9 effective, and you and I spent a long time talking about 9
10 what that means? 10
Page 164
A. It proves the principle. I do not believe in
Scientology. Straight up. Everybody know that. I
believe in Jesus Christ and him crucified.
Q. Understood, Reverend.
A. I'll defend that.
Q. Understood, Rev --.I'm uoL going to make you
defend it.
A. All right.
Q. I'm not going to go there.
A. All right.
11
12
A. Now, that's not all of that; it' s --
Q. No, I lmow, I know, we're going to get to the
11 Q. But you-- you are comfortable that you can
12 reconcile the two things?
. 13 part you want to talk about. I didn't mean to intenupt 13 A. Yes, sir.
14 you, but I -- I promise you I'm not trying to cut you 14 Q. All right, fair enough.
15 off, we're going to get to the question at-- 15 All right. Now, we're getting towards the end
16 A. I understand. No. 16 here, I-- I promise. Now, you-- you read Dr. Kent's
deposition, did you not? 17 Q. Does it require a belief in Scientology; 17
18 that's what you want to talk abOut? 18
19 A. Well, that's not-- that's a -- that's the 19
20 rest of what I. .. We dealt with the "rely upon" and the 20
21 rest of it, so that's next. Why can't we just deal with 21
22 that next? 22
A. Yes, sir, I reviewed it.
Q. Was there anything in there specifically that
you quarrel with? Anything that he said in his
deposition which you have a disagreement with?
A. Basically, no. He -- that' s his lane.
23
24
25
Q. We're gonna.
A. Right now.
23 He's-- as we all know, is credentialed and bred, and
24 etcetera. So I -- no. That's -- that's not my lane.
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Page 163 Page 165
have been.
A. Okay. Fine.
Q. So we've talked about your belief about the
effectiveness. The effectiveness of the program; you
and I spent a long time discussing that?
A. Yes, sir.
Q. And now you -- we -- you -- your -- your
second and final opinion, then, at least globally, is
that these principles don't require a belief in
Scientology?
A. Yes, sir.
Q. Tell me why you don't think that-- that they
require a belief in Scientology.
A. Okay. Had an opportunity to be a part of a
global alliance, on interfaith, dealing with addiction.
And all that simply means is people of other faith
coming to the table and sitting down, and the question
is, "Can these techniques and principles be used in your
religion," and the answer was, "Yes, it can." And so
based on that, and my study and my inquiry, I believe --
and part of my faith, that I believe that Scientology,
that the principles and techniques does not require a
belief in Scientology.
Q. Okay. Fair enough. And that's because you
don't believe in Scientology and you use this stuff?
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whether or not the principles and techniques require a
belief in Scientology, does he? He doesn't really have
an opinion on it one way --
A. No, sir. No.
Q. -- one way or the other. So you're not really
disagreeing with him in that regard?
A. No, sir.
Q. Now, he certainly addressed with ~ - he -- he
certainly ~ ? p e n t a lot of time and addressed the opinion
that you've.withdrawn, right?
A. Yes , sir.
Q. But, as you sit here right now, you can' t
point me to any specific contention or conclusion that
Dr. Kent had in his deposition that you're prepared to
disagree with?
A. No, sir.
Q. Do you plan on doing any additional work in
this case?
A. Well, that depends upon-- well , yes, sir.
Q. Tell me what that is.
A. I understand that once this comes together,
that I'm going to read it and then sign it.
MS. MARS CHALK: Yes, sir.
BY MR. HARRlS:
Q. And I understand that some of that may be
ht ht hhttp://ReachingForTheTippingPoint.net
Page 166
1 dependent upon what your lawyers ask you to do, and Q. Okay.
Page 168
2 that's not really what I'm asking you. I mean, if your 2 A. What happened? Did 1 flunk?
3 lawyers come to you and say, "We would like for you to
4 look into this, or to have an opinion about that," you
5 and I have an agreement that you will let me k.11ow if you
6 have any new opinions or if your opinions change in
7 any--
8
9
A. Yes, sir.
Q. --substantive way?
10 A. Yes , sir .
11 Q. And you'll let Ms. Marschalk know that, and
12 she' 11 let me know that?
3 Q. Some people get the vid --you-- never mind.
4 One of the things that you talked abo).lt was
5 the effectiveness of the program. Do you have any
6 opinions about the effectiveness of the vitamin regjmen
7 or the niacin regimen or any of that sor t of stuff?
8 A. The vitamins?
9 Q. Yeah.
10 A. In the-- well, to answer your questi on, yes,
11 sir.
12 Q. Do you -- is that part of your opinion that
13 A. Yes, sir. 13 the program is effective? Do you mtend to talk about
14 Q. ' Cause that would only be fair? 14 the vitamin regimen and how that's effective?
15
16
A. Yes, sir. 15 A. It's a part of the techniques that I use in
Q. And it wouldn't be fair to me if you show up 16 the withdrawal program.
17 at trial and you have a bunch of new opinions that we 17 Q. Okay. And do you think it's effective?
18 don' t get to talk about. Right? 18 A. Yes, sir.
19 A. Yes, sir. 19 Q. Effective at doing what?
20
21
Q. Okay. And that's really what I was asking. 20 A. Effective in the sense that, in talking with
A. Okay. 21 those who are users and abusers, that the vitamins help
22 Q. Apart from her asking you to do some 22 subside the cravings. And the explanation was that
23 additional work, is there anything that you can tiiinlc 23 dmgs deplete the body of vitamins, and when you put
24 of, "You know what, I-- this deposition's triggered in 24 vitamins in the body, it does help in reducing the
25 my brain, I want to go back and relook at this or review 25 cravings. Now, that's not all that's done, because the
Page 167
1 this or examine something else"; as you sit here today,
2 anything like that crossing your mind?
3 A. No, sk
4 Q. Let me just take a quick look at my notes and
s I think we'll be fmished, Reverend.
6 A. Okay, sir.
7 Q. Prior to your deposition here today, did
8 you -- did you have any meetings with counsel to discuss
9 your deposition?
10
11
12
13
A. Prior to ten o'clock?
Q. Yeah.
A. Yes, sir; we met about 8:35.
Q. And you met with Ms. Marschalk?
14 A. Yes, sir.
15 Q. Did you meet with anybody else?
16 A.. And Steve.
17 Q. Steve was there? Okay.
18 A. Yes, sir.
19 Q. Did you watch a video?
20 A. No, sir.
21 Q. A deposition video, how you' re supposed to
22 conduct yourself?
23 A. No, Si!.'.
24 Q. You didn't see anything like that?
25 A. No, sir.
Page 166- Page 169
Page 169
1 whole issue is that the person is really-- they're
2 there, but they're out of touch with themselves. And
3 the-- and they've depleted the body of vitamins. --
4 Q. Well, are you --
5 A. --And--
6 Q. --are you basing your belief that the vit --
7 and I'm just going to call the vitamin program just
8 generally the vitamin regimen, the niacin regimen, all
9 of that together; do you understand --
10 A. Yes, sir.
11 Q. --how I'm grouping it?
12 A. Yes, sir, I do.
13 Q. Do -- your opinion is that that is -- that
14 that regimen is effective at treating ctnig and alcohol
15 issues?
16 A. The pt:ople that I have come in contact with.
17 Q. And that's based on your personal experience?
18 A. Yes, sir.
19 _Q. Presumably with the same group of people that
20 you and J'talked about before?
21 A. Yes, sir.
22 Q. The same group of people who you don't feel
23 comfortable identifying for me?
24 A. Yes, sir.
25 Q. Other than your experience. \vith t hese
'
i .
Desmondt et al. vs. Narconon, et al.
Multi-Page nl
Page 170
1 individuals, what-- what other bases do you have for
2 yow- contention or your opinion that the vitamin. regimen
3 is effective at treating drug and alcohol issues?
4 A. As I mentioned, I volunteer my services at
5 Narconon Arrowhead, and was on the facilities on an
6 ongoing basis, and had an opportunity to listen to those
7 in the program. And without exception, their
8 testimonies shared with me in a counseling, a coaching
9 environment, t h e y - ~ tbeh testimony was how
10 effective --
11 Q. So--
12 A. -- the regimen helped them.
13 Q. So some of the -- some of the students would
14 self-report, "Hey, this is working for me"?
15 A. Self-report, yes, sir.
16 Q. Okay . . Any --.any medical kind of study or
17 anything like that that you're relying on, other than
18 students saying, "Hey, this is working for ine"?
19 A. Well, they have a physician on staff there.
20 Q. Well, and I -- you're not -- you're not going
21 to be testifying, I assume, about what some other
22 physician might say, right?
23 A. That's-- that's out of my lane. I'm sorry, I
24 withdraw that.
25 Q. And you -- if that physician wanted to show up
Page 171
1 at court and --
2 A. I'm sorry.
3 Q. So you're riot-- you're not going to be--
4 you're not going to be talking about that, are you?
5 A. No. You asked the question -- and what was
6 the question?
7 Q. My question is, other than these students who
8 have told you, "Hey, this is working for me, this sauna
9 program works for me," is there any other bases for your
10 opinion that tl1e vitamin regimen is effective at
11 treating drug and alcohol issues?
12 A. No, sir.
13 Q. So exclusively based on the reports --
14 A. Yes.
15 Q. --of the students--
16 A. Yes, sir.
17 Q. -- who you haven't identified?
18 A Yes, sir ..
19 No. Now, students I identjfied. I said that
20 these are students that i::; in the Narconon Arrowhead
21 program. They're different than the hundred people that
22 I'm talking about.
23 Q. Okay. Well, if-- if they're different, how
24 am I supposed to go to them and say, "Hey, student A,
25 the Reverend says this vitamin program works great for
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Page 172
you; do you agree or disagree?" I can't do that, can I?
A. No; and I don't want you to do that. The--
the question was other !han the people there, were there
other persons that can attest concerning the regimen
program. And I said those that's in the program, that
are students at the rehab facility in Arrowhead,
volunteered information to me how effective the vitamin
regimen has been.
Q. How many students?
A Oh, my God. rna year, or ten years, or what?
Q. I don't know; you're the one that has the
opinion. I'm asking you what it's based on.
A. Okay. Well, over ten year -- let me just say,
over --over a -- in the hnndreds. Low hundreds.
Q. So hundreds of students nave come to you and
said, "The vitamin program works for me, it's effective
for me"?
A. Yes.
Q. And there's no-- you would agree with me
there's no way for me to know who these students are?
A. I understand, sir.
Q. Right?
A. And I couldn't even tell you who they are.
Q. And you' re -- you're guessing about the
number?
Page 173
A Yes, I am making a-- a-- a guess. So I
guess -- do you want me to r eframe that, and -- let me
just say, sir, I can't answer that question at this
time.
Q. The question being?
A. How many --
Q. Okay. So you don't know-- you don't know how
many students --
A. No, sir.
Q. -- self-reported that?
A No, sir.
Q. So, at the end of the day, what we can agree
on, then, is, the sum total for your opinion that the
vitamin program is effective at dealing with drug and
alcohol rehabilitation is because you have had personal
experience and discussions with some unknown number of
students who have so self-reported?
A. Yes, sir.
Q. I think that' s all I have for you; thank you,
Reverend. I'm--
A. Thank you, --
Q. -- sure they--
A. --Mr. Harris.
Q. -- have some questions for you.
MR. TANNER: I don't have any questions.
Page 170 - Page 173
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THE WITNESS: Oh. There's more
questions?
MS. MARSCHALK: No. There's no more
questions.
record at 3:37p.m.
(Deposition concluded at 3:37p.m.)
Multi-Page Desmond, et al. vs. Narconon, et al.
Page 174
1 CERTIFICATE
2 GEORGI A:
3 PULTOKCOUN'TY:
4
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l hereby certify that the foregQing
deposition was talcen down, as stated in the
caption, and the questions and lhe answers
thereto were reduced r.o printing under my
direction; that the preceding pages represelll
a true and correct transcript, to lhe best
of my abilily, of lhe evidence givcu \Jy
witness upon said hearing, And I
certify tl1at I am not of kin or counsel to
tlte parties to the case; om not in the regular
employ of coun5el for any of said parties;
nor 3I1l 1 in anywise interested in tlte result
of said case.
This, the 19tl1 day of Marcil, 2012.
JilTOmoff fltscher, RMR
CCR No. B-924
Notary Commission 8-25-2012
Page 176
BR R ATA SHEET
Page 175
2 !, the undersigned, I AMES JHRRY MCLAUGiillN, do
hereby certiJY lhat I have read the foregoing
3 depos1tion and that, to the best of Dly knowledge, said
deposition is true and accurate (with the exception of
4 the following corrections !istod below.)
5
6
7 PAG!lll.INR CORRECTION (and reason fur correction)
8
9 '------------------
t O / ____________ _ _ _
ll '---------------'-
12 ____ , ______ ___ _ _ __;_ _ _
13
14
15
16
) 7
18
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2J
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-----'----------------------
_ __ ,/ _______ _ _ _ __ _
____ ,/ _____________ _

----'-
==....-:=,....------'Signalili'e------ ---.. --.-----
Notary Pll611c
Dale
-
24 My Cnmmissi!ln Expires:
25
r
1
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Index Page 1
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against - based
1:129:9 l :133:16 1:107: 18 1:109:13 1: 108:5 1:128:21 1:21:4 1:21:11 attention [2J
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1:131:22 1;134:12
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1:27:4
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1:30:25 1:31:5
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1:71:5 1:71:13
answer [241
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1:137:23 .1:141:25
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1:97:11 1:97: 17 aiTowhead [26]
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1:171:13 1:172:12 1:25:23 1:25:24 bottom [31 1:2: 16 1:92:6 1:150:18
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1:19: 17 1:128:7
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1:133:6
1:20:4 1:20:5
1:8:5 1:9:20
1:47: 1 1:47:9
1:2:8 1:2:15 board [14]
1:21:3 1:47:3
1:10:9 1:10:16
1:52:8 1:52:9
1:2:21 1:6:14 1:4:21 1:6:15
1:70:5 1:70:11
1:11:18 1:11:24
1:52:10 1:52:24
1:19:5 1:23:3 1:9:22 1:22:14
1:70:12
1:12:19 1:16:7
1:52:25 1:53:4
1:132:11 1:22:17 1:22:20
budget [1]
1:17:9 1:17:14
1:53:16 1:59:13
behav [1]
1:22:22 1:22:23
1:124:8
1:17:15 1:17:16
1:62:11 1:62:18
1:150:8
1:22:23 1:22:25
building [2]
1:18:22 1:31:8
1:63:6 1:63:8
behavior [2]
1:47:7 1:52:3
1:24: 13
1:47:13 1:55:8
1:65:21 1:65:22
1:60:23 1:70:9
1:24:11
1:77:25 1:81:22
1:66:25 1:68:2
1:92:18 1:136:4
body [3]
buildings [3] 1:90:21 1:126: 18
1:69:5 1:69:13
belch (11
1:168:23 1:168:24
1:20:4 1:24:4 1:127:11 1: 128:8
1:69:17 1:69:22
1:23:24
1:169:3
1:24:9 1:128:9 1:129:22
1:70:8 1:71:21
belief [18]
book[8J
bulky [1]
1:165:18 1:176: 13
1:78:1 1:78:13
1:23:13 1:29:17
1:44:7 1:46: 17
1:61:1 8
1:176:16
1:78: 16
1:30:7 1:31:7
1:133:3 1:133:8 bullbait [1]
cases [1]
certify [31
1:125:7 1:135:4
1:134:12 1:139:22 1:127:15
1: 110:6
1:175:2 1:176:4
1:137:2 1:137:8
1:140:1 1:153:10
bullbaiting [4]
categories [1] 1:176:12
1:158:12 1:160:21
1:160:24 1:162:17
bool's {37] 1:127:11 1:127:18
1:33:20
certifying [1J
1:163:3 1:163:9
1:17:19 1:27:16 1:128:1 1:128:6 category [1) 1:55:3
1:163:13
. 1:163:23
1:27:17 1:114:18
bullet [21
1:38:15
cetera [3]
1:165:2 1:169:6
1:123:7 1:123:8
1:40:24 1:41:5 caught [2J 1:142:17 1:148: 11
believes [11
1:123:10 1:138:17
bunch [21
1:28:2 1:90:6 1:164:24
1:139:1 1:139:2
1:147:24
1:139:24 1:139:24
1:142:20 1:166:17 cautioning [1] ceus [1]
below [1]
1:140:5 1:142:2
bunk [1]
1:11:3 1:55:13
1:175:4
1:142:3 1: 142:16
1:24:11 ccr [21
charrman t1J
benefited [1] 1:144:18 1:151:8 business [11
1:1:0 1:176:23 1:9:22
1:86:21 1: 151:8 1:151:23 1:38:5 center [4) change [8]
benitez [IJ
1:151:25 1:152:23
buy [2]
1:44:22 1:123:14 1:30:20 1:81:8
1:133:4
1:152:24 1:153: 12
1:123:8 1:124:7
1:123:23 1:124:2 1:99:22 1:136:3
best [3J
1:154:9 1:154: 15
c-o [2J
cer [1]
1: 148:9 1: 160: 16
1:133:5 1:175:3
1:154:18 1:154:19
1:116:19 1:116:22
1:38:14
1:160:19 1:166:6
1:176:9
1:154:25 1':155:8
c-o-t-e-r [3J
certain [10]
changed [2]
1:156:3 1:156:5
1:30:25 1:43:11
1:94:15 1:143:20
better [2]
1:156:7 1:157:21
1:116:20 1:116:23
1: [29:8 1:129:9
1: 161:2 1:161:14
1:116:25
1:43:17 1:47:4 changes [2]
between [81 1:161:23 calvin [11
1:55:7 1:62:19 1:92:17 1:159:23
1:89:2 1:90:15
chru11tin!! rt 1
nk:page:line 1 :mclaugh. txt
Q&A REPORTING SERVICES, INC. Page 3
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chapel - counseling
Desmond et al vs Narconon et al
'
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'
.
1:40:13 1:44:17 comparison [2] 1:32:19 1:116:1 1:61:6 1:73:9
chapel [4] closer [11
1:136:6 1:155:12 1:116:17' 1:117:2
copy [9]
1:120:21 1:121:9 1.:25:24
complaint [9)
1:117:3 1:117:18
1:13:9 1:13: 11
1:121:9 1:121: 10
closest [lJ
1:17:17 1:29:11
1:117:25 1: 119:24
1:59:4 1:60:7
chapters [1] 1:40:10
1:30:19 1:30:19
1:140:22 1:140:25
1:63:19 1:63:23
1:44: 14
clothed [2]
1:30:21 1:30:25 connor [1J 1:73:8 1:83:6
charge [1] 1:93:21 1:94:3
1:31:3 1:31:7 ' 1:120:21 1:112:18
1:6:18
coaching [31
1:31:22
consider [6] corporation [2]
cheaper [!] 1:45:7 1:57:4
complete [2] 1:8:15 1:8:24 1:9:16 1:9:19
1:28:3 1:170:8
1:62:16 1:62:21 1:44:24 1:125:19
correct [15]
children [31 cobble [1J
completed 12:1
1:148:5 1:150:9
1:8:6 1:25:4
1:21:24 1:100:17 1:147:15
1:36:17 1:68:23 consisted [21 1:30:8 1:49:24
1:102:8
college [1)
compliance [11
1:15:11 1:71:12 1:50:1 1:57:14
choose [1]
1:6:15 consistent [11
1:77:12 1:n:23
1:134:20
1:24:18
1:80:3 1:85:10
1:119: 18
colony [1)
component [3]
chose [tJ
1:23:21 ' 1:25:9 consolidated [ll
1:85:21 1:92:9
1:2:4
1:112:4 1:143:3
1:133:7
combined [2J
1:28:5 1:35:6
1:176:9
cluist [lJ 1:117:21 ):117:21
compound [3J consulting [2]
correction [3]
1:164:3
combining (lJ
1:27:2 1:27:3 1:82:18 1:82:21
1:122:17 1:175:7
1:132:1
contact [21
church (21] 1:145:17
compromise [lJ
1:175:7
1:19:15 1:19:18
combo[ll
1:110:11 1:169:16
cor1ections [1J
1:19:22 1:20:6
1:145:23
1:144:8
contacted [4]
1:175:4
1:20:14 1:25:12
comfort [2]
con [11 1:12:18 1:12:21
correspond (ll
1:71:22 1:72:1
1:28:9 1:13:6 1:111:24
1:93: 19 1:94:2
1:32:12 1:46:14
contained [21
1:156:22
comfortable [12]
concern [lJ
correspondents [1]
1:116: 13 1:119:11
1:143:24 1:1:0 1:35:21
1:119: 13 1:119:14
1:11:22 1:32: 11
concerned [2] contains [lJ
1:140:21
1:119:22 1:131:25
1:32:12 1:45:2
1:154:24 1:155:12 1:6:1
corresponding [lOJ
1:132:14 1:132:15
1:48:20 1:107:9
1: 139:2 f:t39:8
1:132:16 1:134:7
1: 108:21 1:155:10
concerning [3] contention [7]
1:139:15 1:139:25
1:155:24
1:158:22 1:158:24
1:91:23 1:91:24 1:83:17 1:107:16
1:140:5 1:141:23
churches [8]
1:164:11 1:169:23
1:172:4 1:109:7 1:110:5
1:152:1 1:153:11
1:120:1 1:120:8
comingr21
concluded [1J
1:151:7 1:165:1.3
1:154:21 1:157:22
1; 120: 11 1:121:3
1:25:24 1:163:17
1:174:7
1:170:2
cost [2]
1: 121:6 1:121:12 conunencing [1]
conclusion [1]
context [SJ
1:28:2 ] :72:13
1: 121:15 1:121: 16 1:1:0
1:165:13
1:40:17 1:130:21
cota [lJ
condition [l]
1:130:23 1:130:24
circle [1] commingling [JJ
1:149:23
1:116:19
1:1:0 1:143:25
1:128:5'
cota-go [11
city [1] commission [2]
conditions [5]
continue [2]
1:115:25
1:92:1 1:144:15
1:121:10 1:175:24 1:176:23
1:148:20 1:148:25
continuing [2J
cota-gold [ll
civil [5J
commitment [1J
1:149:1 1:149:3
1:116:16
1: 150: 10
1:55:11 1.:55:13
1:1:0 1:7:8 1:22:5
conduct [1]
contract [8]
coter [3]
1:10:6 1:10:9
common [lJ
1:116:25 1:117: 17
1:10:11
1:11:11
1: 167:22
1:22:7 1:22:9
1:119:4
conference [9J
1:22: 11 1:22:13
clarification t1J
communicate [lJ
1:122:18 1:122:21
coter/narconon [11
1:51:21
1:102:16
1: 19:15 1:20:2
1:143:19 1:144: 14
1:117:25
1:20:5 1:20:6
class [11 conununications [1)
1:20:9 1:24:7
contradictory f.2J
cou [1]
1:27:10
1:127:9
1:25:12 1:71:22
1:128:23 1:147:2
1:146:3
clean [ll
communities [3J 1:72: 1 control [1)
council [ 1]
1:13:11
1:102:15 1:116:21
confined [4)
1:116:4
1:6:16
clear D6l
1:116:23
1:28:9 1:28:10 conbols [11
counsel [7J
1:30:6 1:30:15
community [19] 1:28:12 1:28:15 ' 1:109:24
I :2:1 1: 13:2
1:31:20 1:53:3
1:21:5 1:21:1 1
confront [1] conversation [111
1:39:2 1:56:19
1:65:10 1:66:4
1:102:15 1:116:14
1:167:8 1:176:12
1:76:16 1:76: 18
1:129:20 1:11:11 1:13:23
1:176:14
1:117:9 1:121:5
confronting [2)
1:14:3 1:14:19
1:82:17 1:95:6
1:123: 14 1:127:14
1:14:23 1:14:24
counseled [lJ
1:108:7 1:145:5
1:127:17 1:128:3
1:127:9 1:128:11
1:15:11 1:15:22
1: 129:22
1:146:25 1:147:7
1:128:4 1:128:14
confused [2J
1:16:4 1:16:18 counseling [38]
1:157:8 1:161:12
1:128:16 1:129:2
1:44:10 1:62:13
clearly [2] 1:129:6 1:129:14 confusion [11
1:16:23 1:38:12 1:38:12
conve1sations [1]
1:38:19 1:38:20
1:30:12 1:106:23 1:129:19 1:130:8 1:41:5
1:31:3
1:38:23 1:38:23
cleveland [ll
1:!35:5
congregation [41
cook [lJ
1:39:12 1:39:13
1:2: 16 company [11 1 1:93:23 1:40:3 1:42: 19
client [SJ
1:9:22 1:108:23 1:119:13
1:102:9
1:43:1 1:44:8
1:18:22 1:19:5 compare[1J congregations [lJ
cookie-cut LlJ
1:44:11 1:44:13
1:86:14 1:140:20 1:101:15 1:120:18
1:102:9
1:44: 14 1:45:7 '
1:140:24
compared [11 connection [121
copies [4] 1:46:25 1:47:8
close [Jl
1: 109:23 1:19:22 1:31:21
1:5:8 1:5:9 1:57:1 1:57:4
file: pilge:line 1:n1cJaugh.txt
Index Page 4
Desmond, et al. vs. Narconon, et al. Multi-Page counselor - diplomat
1:62:11 1:63:1 1:10:25 1:86:11 date [4] 1:98:11 1:148:7 1:4: 12 1:158:20
1:64:8 1:64:11 1:157:24 1:158:9 1:7:2 1:26:11
definitions [1] designate [lJ
1:66:21 1:69:14 1:161:13 1:161:22 1:28:16 1:175:23
1:148:10 1:58:8
I :69:18 1:70:8 1:171:1
dates [3]
degree [25] designated [4]
1:70:9 1:73:24
court's [1] 1:40:13 1:46:18
1:36:1 1:37:4 1:8:5 1:9:5
1:77: 1 1:77:7
1:7: 10 1:116:11
1:37:6 1:37:7 1:11:21 1:11:23
1:78:14 1:81:2
cousins [lJ days (11 1:37:8 1:38:4
designation (5]
1:127:3 1:128:9
1:128:10 1:170:8
1:129:7 1:119:19 1:40:19 1:40:21
1:68:5 1:68:13
counselor [25]
cpa [lJ deal [10]
1:41: 12 1:47:6
1:69:7 1:71:6
1:7:9 1:19:8 1:39:16
1:47:7 1:47:10
1:78:14
1:4:19 1:4:23
1:39:20 1:49:23
1:50:13 1:56:15
designed [2J
1:46:25 1:52:3
cpc [5J
1:62:25 1:127:8
1:56:16 1:57: 25
1:52:8 1:54:22
1:53:15 1:68:5 1:25:3 1:114:24
1:68:13 1:68:19
1:129:21 1:131:17
1:68:12 1:77:17
desmond [4] 1:55:21 1:59:13
1:159:3 1:162:21
1:78:3 1:78:4
1:62:11 1:63:4
1:68:24
1:79:3 1:79:6
1:1:0 1:1:0
1:63:8 1:63:16 cracls: [2]
dealing [9J
1:79:9 1:80:3
1:1:0 1:1:0
1:65:21 1:66:25 1:97:2 1:97:2
1:9: 13 1:30:2
1:80:12 detail [1]
1:68:3 1:69:11
craft [1J
1:40:2 1:44:15
degrees [1]
1:16:8
1:48:14 1:88:13
1:69:15 1:70:24
1:57:3
1:38:11 details tiJ
1:71:6 1:71:9
1:103:2 1:163: 15
1:77:23 1:78:7
cravings [2)
1:173:14" dekalb [21
1:10:4
1:78:11 1:79:21
1:168:22 1:168:25
deals [6.1
1:1:0 1:107:24 determination [2)
1:88:13
creation [1]
1: 10:10 1:40:5 delcampo (11
1:105:5 1:109-:25
counselors [81
1:134:25
1:85:8 1:128:22 1:2:3 determine [9]
1:4:21 1:4:24
creator [1] 1:145:11 1:145:12
delgado [21
1:12:1 1:31:12
1:58:11 1:58:19
1:134:24
dealt [6] 1:1:0 1:2:15
1:91:17 1:95:9
1:62:9 1:67:6 credentialed [1} 1:9:23 1:44:20
deliver 111
1:98:4 1:101:12
1:67:15 1:67:25 1:164:23 1:49:19 1:71:13
1:107:4
1:108:17 1:110:10
count:Ly [1] credentials [6J
1:129:24 1:162:20
demonstrative rtl
1:148:24
1:20:1 1:49:16 1:56:12 decide [lJ
1:113:6
determining [1)
counts [1]
1:56:15 1:66:11 1:149:10
denomination [4]
1:146:2
1:56:16
1:68:6 1:80:14
decided [3]
1:94:18 1:94:24
development [2]
county[3J
crimanon [IJ 1: 124:24 1: 126:13
1:95:2 1:96:4
1:1:0 1:2:15
1:1:0 1:107:24
1:134:15 1:149:11
dependent [3)
deviate [2J
1:176:3 criminal (3) decides [11
1:56:8 1:70:25
1:143:2 1:144:21
couple [3J
1:10:2 1:10:5 1:148:8
1:166:1
deviating (1]
1:80:20 1:81:20
1:10:8
deciding [1J
deplete [1J
1:151:19
1:120:1 crossing [1] 1:19:23
1:168:23
devoted [!J
coupled [1]
1:167:2
decision [3]
depleted [1]
1:42:25
1:145:24 crucified [1] 1:88:9 1:88:16
1:169:3
dial [11
coupling [1]
1:164:3 1:105:5
deposition (301
1:2:23
1:146:3 current [6] decisions, [lJ
1:1:0 1:7:6
dialogue [IJ
course [34)
1:37:12 1:37: 14 1:150:18
1:7:17 1:9:2
1:6:10
1:17:19 1:19:8
1:37:25 1:53: 12
dedicated [1] 1:9:3 1:11:4 died [1]
1:30:2 1:32:14
1:53:13 1:55:12
1:44:11 1:29:11 1:29: 12 1:126:22
1:36:17 1:38:22 curriculum [9]
deface (1J
1:29:18 1:29:24
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1:39:22 1:39:25 P6.:24 1:27:17
1:60:8
1:30:15 1:30: 16
1:10:7 . 11
1:42:8 1:42:12 1:27:20 1:27:21
defend [2J
1:31:23 1:33:7
different [29J
1:42:17 1:42:18 1:43:7 1:58:5 1:87:3 1:87:7
1:42:19 1:42:24 1:58:7 1:77:25
1:164:5 1:164:7
1:88:1 1:138:23
1:8:11 1:8:11
1:42:25 1:43:7 1:134:22
defendant [lJ
1:159:1 1: 160:18
1:8:13 1:19:25
1:43:19 1:43:25
customary UJ
1:2:15
1:164: 17 1:164:21
1:23:4 1:26:18
1:44:1 1:44:1 [JJ 1: 165:14 1:167:7
1:26:23 1:27:1
1:6:18
1:27:5 1:27:19
1:44:2 1:44:5
cut [21
1:1:0 1:2:8 1:167:9 1:167:21
1:27:25 1:28:1
1:44:11 1:44:11 1:2:21 1: 174:7 1:175:3
1:44:13 1:44:14
1:106:2 1:162:14
define [6J
1:175:3 1:176:5
1:53:3 1:53:4
1:44:19
cvs (6]
1:61:23 1:71:24
1:49:18
1:93:4 1:94:10 deposition's [!J
1:93:1 1:106:3
1:50:24 1:71:12
1:35:9 1:35:16
1:96:16 1:97:3 1:166:24
1:120:8 1:131:23
1:73:25 1:74:15
1:36:6 1:37:11
1:107:2 1:137:21
depositions [2]
1:114:18 1:139:2
1:52:20 1:53:3
1:137:6 1:138:4
daddy [1]
defined [41 1:31:15 1:32:24 1:144:17 1:144:17
courses [91
1:97:15 1:101:8
describe [2]
1:145:3 1:151:14
1:39:20 1:40: 1
1:127:24
1: 149:19 1:150:11 1:153:14 1:171:21
1:37:12 1:45:4
1:42:14 1:43:11 dallas [ 1)
defines [4]
desctibed [5]
1:171:23
1:43:18 . 1:44:17 1:132:17
1:84:3 1:146:7 differently [2]
1:44:20 1:49:22
damages [1]
1:21:15 1:36:25
1:75:16
1:146:7 1:146:8
1:73:25 1:97:21
1:27:7 1:57:6
1:10:10
definitely [1] 1:141:6 dime (lJ
court (131
dash [1]
1: 19:6
describes [11
1:124:10
1:1:0 1:1:0
1:6:7
1:6:14 1:6:15
data [ll
definition [6J 1:73:19 diplomat [21
1:6:16 1:9:6
1:8:13 1:28:22
description (2]
1:47:6 1:70:9
1:110:4
1:94:13 1:98:10
ule:page:Jinc 1 :me laugh .txt
Q&A REPORTING SERVICES, INC. Index Page 5
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direct- end
Multi-Page T ~ Desmond, et al. vs. Narconon, et al.
direct [4J distinction [2J 1:38:12 1:38: 19 1:154:1 1:154:3 . 1:132:6 1:143:6
1:45:12 1:84: 16 1:95:11 1:138:11 1:40:3 1:40:3 1:155:23 1:155:25 1:145:15 1:145:22
1:110:4 1: 159:12
dna [1]
1:40:5 1:42:10 1:156:8 '1: 156:10 1:147:16 1:160:22
direction 121 1:126:25
1:42:18 1:43:1
c-metcr's [IJ
1:162:9 1:168:13
1:146:21 1 : 1 7 6 : ~
doctor [4J
1:44:21 1:44:21
1:155:1
1:168:14 1:168:17
director [6] 1:36:21 1:36:23
1:44:25 1:45:5
early [51
1:168:19 1:168:20
1:49:19 1:49:23 1:169:14 1:170:3
1:ll:24 1:14:7 1:37:8 1:41:12
1:50:8 1:50:25
1:12:20 1:89:25
1:170:10 1:171:10
1:20:12 1:20:17
doctoral [9J
1:90:5 1:90:6
1:21:1 1:21:3
l :51:11 1:51:18
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1: 130:15 1:143:22
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1:121:12 1:121: 15
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1:94:19 1:97:8 . 1:133:9 1:133:15
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1:25:7 1:118:25
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1:65:5 1:66: 16
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1:119:14 1:121:5
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1:126:9 1:128:12
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1:51:22 1:53:18
1:36: 10 1:36:13
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1:58: 18 1:62:25
1:130:13 1:143:19
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1:3:1 1:56:3
1:63:21 1:75:17
1:161:1
1:97: 1 1:97:1
file:pnge:Jine l:mclaugh.txt
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mark[6] 1:80:12 1:103:3 1:162:10 1:163:16 1:119:10 1:121:3 1:157:3
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material [161 meant [5] ministry 1121 moved [2]
1:59:12 1:63:15
1:6:1 1:6:1 1:51:22 1:57:7 1:19:11 1:20:14 1:20: 1 1: 36:3
1:67:8 1:82:25
1: 17:19 1:30:3 1:95:20 1:149:15 1:33:17 1:33:18
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1:90:14 1:93:11
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1:59:25 1:61:2 1:46:21 1:58:6
1:99:23
1:97:4 1:117:9
1:63:12 1:67:10 1:80:8 1:83:25
measuring [11
1:119:22 1:134:17
1:159:8
1:73:2 1:73:5 1:90:23 1:123:21
minor [1]
multi-level [1]
1:75:22 1:83:3 1:131:21 1:143:22
1:101:3
1:9:24
1:38:5
1:83:8 1:110:17
materials [10]
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minus [ 1]
must [9]
1:110: 19 1:111:4
1:17:10 1:32:8
1:170:16
1:55:6 1:55:10
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meet [4J
1:20:23
1:55: 10 1:55:11
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1:139:23 1:142:17
1:146:20 1:167:15
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1:9:24
1:142:19 1:142:22 meetings 111
1:75:6 1:159:17
1:69:25
marks [3]
math [1]
1:167:8
minutes [ 1]
name [91
1:122:22 1:123:11
1:103:18 member[ll
1:24:5
1:8: 1 1:10:20
1:130:14 matriculating [11
1: 100:20
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1:99:13 1:44:8 1:96:9
1:2:10 1:4:14 matter [4]
1:67:14
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1:105:25 1:1]5:21
1:7:15 1:13:10 1:99:4 1:103:13 memory [4]
1:126:18
1: 124:2
1:16:19 1:34:18 1:103:15 1: 107:3 1:9:17 1:24:1
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names [51
1:34:25 . 1:45:19
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1:26:19 1:122:18
1:41:24 1:121:21
1:84:24 1:87:12
1:45:22 1:47:17
1:81:20 mention[3J
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1:107:1 1:118:21
1:120:19
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1:156:8 1:156:13
1:130:17
1:61:5 1:61:9
1:11:1B 1:12:2
1:156:17 modified [3]
muconon [133]
1:63:21 1:73:9
1:16:1 1:16:1 mentioned [131
1:158:21 . 1: 159:13
1:1:0 1:1:0
1:74:3 1:74:17
1:2:8 1:2:9
1: 75:21 1:75:25
1:20:18 1:20:21 1:30:22 1:33:5
1:159:15
1:5:2 1:12:24
1:77:18 1:79:5
1:20:21 1:21:20 1:61:21 1:62:8 modify [1]
1:14:8 1:17:2
1:85:2 1:85:24
1:21:20 1:46:7 1:70:4 1:70:4 1: 157:19
1:18:9 1:18:10
1:87:14 1:87:19
1:50: 16 1:58:20 1:102:7 1:114:13
module [11 1:18:19 1:19:12
1:88:3 1:88:18
1:62:18 1: 153:12 1:144:7 1:144:8
1:139:15 1:19:18 1:20:12
1:111:8 1:111:14
1:153:21 1:154:12 1:156:4 1:157:16
modules [4]
1:20:17 1:21:1
1:165:25 1: 170:4
1:113:18 1:113:20
mclaughlin [13]
1:139:12 1:140:4
1:21:4 1:21:11
1:113:23 1:122:24
merge[l]
1:152: 1 1:153:23
1:21:14 1:22:15
1:135:19 1:136:17
1:1:0 1:4:13 1:147:12
molested (21
1:22:20 1:23:1
1:157:23 1:158:10
1:4:15 1:4:16
mess [11
1:23:3 1:23:8
1:165:23 1:166:11
1:4:18 1:4:19
1:129:13
1:129:23 1:130:3
1:23:14 1:23:20
1:167:13 1:174:3
1:4:20 1:4:22
met[SJ
moment[2J
1:24:18 1:24:23
martin [11
1:7:6 1:7:19
1:125:14 1:128:10
1:24:25 1:25:7
1:8:1 1:24:12
1:136:1
1:47:25 1:48: 1
1:27:12 1:72:3
monetary [1] 1:26:1 1:26:10
1:175:2
1:130:12 1:143:17
1:125:2 1:26:14 1:27:8
mary [21
1:1:0 1:1:0
mean [44]
1:167:12 1:167:13
money [21
1:28:25 1:29:13
1:8:10 1:8:13
methodically [2]
1:10:10 1:103:5
1:29:19 1:30:7
mas [11
1:15:17 1:18:15
months [11
1:31:8 1:48:14
1:40:18
1:22:4 1:22:22
1:75:14 1:78:9
1:48:15 1:48:15
migbtr?J
1:124:9
master [4] 1:29:17 1:33:11
moral [2]
1:48:16 1:48:24
1:4:22 1:47:1 1:34:5 1:39:1
1:30:19 1:103:14 1:49:5 1:53:1
1:47:8 1:63:3 1:41:4 1:64:13
1:104:8 1:104:13
1:117:14 1:149:23
1:54:24 1:69:7
master's [42]
1:65:9 1:66:6
1:115:13 1:119:11 morning [31 1:72:2 1:72:5
1:38:7 1:38:8
1:67:16 1:67:18
1:170:22 1:7:24 1:7:25 1:72:23 1:75:11
1:38:21 1:39:9
1:83:22 1:84:4 million [4]
1:72:13 "1:75:18 1:76:7
1:39:23 1:40:12
1:89:22 1:90:8 1:102:22 1:102:23 most [15J
1:83:18 1:83:24
1:40:19 1:40:21
1:94:10 1: 100:4 1:102:24 1:102:25 1:24:18 1:37:12
1:84:9 1:85:10
1:41:4 1:41:9
1:102:6 1:105:15
mind[5]
1:37:13 1:37:25
1 :93":25 1:97:14
1:41:11 1:42:7
1:106:2 1:108:9
1:37:19 1:60:25
1:43:3 1:53:12
1:103:17 1:103:21
1:42:9 1:42:13
1:108:10 1:109:3
1:135:1 1:167:2
1:53:12 1:104:16
1:110:12 1:110:14
1:43:14 1:47:6
1:112:6 1:112:22
1:168:3
1:126:5 1:126:11
1:112:8 1:112:10
1:47:7 1:47:10
1:114:15 1:139:18
minister r3l
1:128:19 1:128:20
1:112:12 1:1-12:13
1:49:19 1:50:13
1:141:5 1: 143:12
1:39:1 1:100:3
1: 128:21 1:134:25
1:112:14 1:112:16
1:56:16 1:56:21
1: 146:23 1:148:6
1:100:5
1:136:4
1:114:17 1:114:20
1:57:17 1:57:24
1: 148:17 1:149:25
ministers [7]
mother [21
1:114:21 1:115:9
1:62:7 1:63:3
1: 150:4 1:150:6
1:126:21 1:129:6
1:115:25 1:116:4
1:63:16 1:68:7
1:152:8 1:159:1
1:102:14 1:117:8
motivated [lJ
1:116:17 1:117:1
1:68:12 1:68:23
1:162:13 1:166:2
1:118:2 1:118:24 1:117:3 1:117:4
1:70:9 I :74:1 meaningless [21
1:119:3 1:119:4
1:72:9
1:117:17 1; 118:22
1:74:15 1:77:17 1:104:15 1:104:18
1:119:18 mouth [1] 1:119:10 1:119:24
1:78:4 1:78:22
means [41
ministties [61
1:100:14 1:120:13 1:121:18
1:79:3 1:79:6
1:69:25 1:148:15
1:36:22 1:36:23 move [3J
1:122:13 1: 122:23
1:79:9 1:80:2
1:37:9 1:41:12 1:51:9 1:68:17
1:123:13 1:123:18
fi le:page :line 1 :mclaugh. txt
narconon-affiliated opinion
1: 124:16 1:127:4 needs ro
1:81:7 1:81:12 1:140:19 1:24:14 1:26:2
1:130:12 1:131:12 1:114:25 1:91:20 1: 101:22
obtain [71
1:26:13 1:28:18
1:131:22 1:131:24
negatively [lJ
1:102:12 1:105:13
1:43:14 1:67:14
1:34:18 1:34:24
1:132:5 1:132:8
1:55:2
1:107:5 1:107:10
1:68: 19 1:78:14
1:36:6 1:36:18
1:133:11 1:133:21
never [141
1:110:9 1:112:21
1:78: 17 1:78:20
1:37:14 1:37:17
1:134: 12 1: 134:14
1:28:17 1:28:20
1:114:13 1:118:19
1:79:20
1:42:14 1:42:18
1:136:13 1: 137:15
1:37:19 1:48: 17
1: 121: 11 1:124:19
obtained [lJ
1:46:10 1:46: 15
1:139:10 1: 140:4
1:122:19 1:124:3
1:124:21 1:124:22
1:35:11
1: 48:24 1:49:18
1:141:22 1:142:2
1:124:13 1:126:22
1:124:23 1: 125:23
obviously [3]
1:50:24 1:52:15
1:142:3 1:142:16 1:126:10 1: 131:7 1:53:11 1:53:12
1:142:20 1:143:14
1:129:24 1:130:2
1:138:14 1:151:2
1:25:1 1:57:6
1:53:15 1:54:20
1.:143:17 1:144:14
1:139:21 1:139:22
1:152:13 1:153:19
1:121:24
1:56:8 1:56:14
1:145:16 1:145:17
1:154:7 1:168:3
1:158:11 1:160:3 occasion [1] 1:56:24 1:57:2
1:145:21 l :145:23
neW[2J
1:162:11 1:162:24 1:132:10 1:57:10 1:57:16
1 : 1 4 5 : 2 ~ 1:146:2
1:166:6 1:166:17
1:163:7 1:164:15
occasions [4J
1:61:14 1:61:14
1:147:15 1:149:4 next [51 1: 164:16 1:165:8
1:23:6 1:23:13
1:61:23 1:62:3
1:151:8 1:.151:10 1:51:9 1:93:8 1: 165:12 1:168:25
1:131:24 1:132:4
1:62:3 1:63:15
1:151:17 1:151:18 I :93:12 1:162:21 1:171:19
off [32]
1:64:11 1:70: 1
1:151:24 1:153:23 1:162:22
nowhere[4J
1:13:13 1:35:11
1:71:12 1:73:25
1:157:21 1:160:12
niacin [2J 1:53:5 1:155:25
1:53:25 1:72:12
1:74: 15 1:79:4
1:161:24 1:170:5
1:168:7 1:169:8 1:156:2 1:156:4
1:73:13 1:81:9
.1:79:7 1:83:7
1:171:20
nice [ll number [51J 1:94:20 1:97:8
1:85:9 1:85:15
narconon-affiliated [4]
1:81:18 1:7:4 1:14:21 1:97: 10 1:97:21
1:86:5 1:86:19
1:21:8 1:74:2
nigger [IJ
1:23:3 1:23:13 1:99:18 1:99:23
1:89:23 1:90:13
1:75:19 1:81:2
1:23:16 1:23: 18 1:99:25 1:100:5
1:93:24 1:96:7
1:127:14
1:99:12 1:100:4
narconon-related [3]
night [2]
1:24:22 1:53:15 1:100:20 1:106:2
1: 100:19 1:100:20
1:74:16 1:82:21 1:53:16 1:53:17 1:113:20 1:113:24
1:119:8
1:72:4 1:72:13
1:56:14 1:66:24 1:114:1 1:119:5
1:102:6 1:102:20
narconon-trained [ll
nobody [lJ
1:69:5 1:72:25 1: 126:12 1: 126:14
1:105:23 1:107:6
1:128:15
1:81:14 1:84:18 1: 127:22 1:128:2
1:107:6 1:107:6
1:73:19
nods [3] 1:89:2 1:89:8 1:129:3 1:130:8
1:119:15 1:124:5
narconon-type [1]
1:13:4 1: 14: 13 1:89:9 1:89:15 1:131:4 1:150:25
1:124:5 1:124:19
1:123:14
1:92:13 1:89: 16 1:90:17 1:159:21 1:15.9:25
1:124:22 1:126:4
narconons [ZJ
1:92:6 1:92:11 1:162:15 1:174:5
1:130:3 1:132:10
1:19:24 1:28:11
non [11
1:93:1 1:93: 12
1:132:13 1:133:1
1:55:15 offer [31
1:135:6 1:135:7
nation (1]
non-profit [lJ
1:93:13
.1:93:17
1:93:22 1:94:4
1:136:8 1:136:11
1:103:8
1:116:24
1:93:18 1:93:19
1:160:19
1:137:7 1:137:13
national [17]
non-scientologist Ill
1:96:7 1:103:21
offering [ll 1:139:11 . 1:139:12
1:4:24 1:58:11
1:103:24 1:103:25
1:149:14 1:140:6 1:141:9
1: 147:23
1:105:23 1:106:15
1:58:19 1 :61:21
officer [4]
1: 143:4 1: 147:22
1:62:8 1:62:9 .
non-violence [1] 1:107:12 1:111:3
1:148:8 1:151:17
1:136:3 1:115:4 1:124:5
1:148: 12 1:148:14
1:62:12 1:67:5
1:148:18 1:150:10
1: 155:7 1:157:25
1:67:15 1:67:24 none[3J
1:124:5 1:126:4
1:165:3 1:165:5
1:70:4 1:70:11 1:38: 18 1:79:15
1:131:23 1:132:4 officers [1]
1:168:4. 1:172:11
1:70:12 1:70:13 1:124:23
1:133: 1 1:136:22 . 1:150:16
ongoing[lJ
1:70: 14 1:103:20
nor [21
1:137:6 1:156:17
officially [lJ
1:104:10
1:160:5 1:172:25
1:93:20
1: 170:6
1:150:9 1:176:15
nature [51
1:173:16
oklahoma [25]
open [2]
nos [2J
numbering [2]
1:123:13 1:124:24
1:9:15 1:9:20
1:5:8 1:34:11
1:47: 1 1:52:3
opened [4]
1:9:22 1:127:13
notary t:tJ
1:108:9 1:108: 10
1:55:6 1:55:8
1: 144:1
numbers [21 1:55:19 1:55:21
1:21:23 1:116:12
necessarily [51
1:175:22 1:176:23
1:102:20 1:106:4 1:55:23 1:57:10
1:124:3 1:132:15
1:102:6 1:119:9
notes [ll
o'clock [tJ
1:60:23 1:61:14 operating (1]
1:119:10 1:143:16
1:167:4
1:167:10
1:64:9
1:65:15 .
1:115:19
1:146:12
nothing [31
object [12]
1:66:16 1:69:11
opined [11
necessary [2]
1:71:15 1:113:10
1:74:3 1:74: 17
1:69:15 1:71:7
1:139:1
1: 137:24
1:72:1 1:77:14
1:33:5 1:90:19 1:75:25 1:77:18
1:77:24 1:78:10
opinion [761
need [JSJ
now [63)
1:79:5 1:85:2
1:79:11 1:79:21
1:31:2 1:37:24
1:7:1 1:9:17
1:85:24 1:87:14 1:49:4 1:49:10
1:14:15 1:53:13 '
1:80:4 1:121:10
1:53:13 1:62:1
1:11:2 1:18:20
1:88:3 1:88: 18 1:49:11 1:51:17
1:19:12 1:21:3
1:135:19 1:158: 10
1:121:11
1:53:18 1:54:17
1:66:22 1:91:19
1:95: 14 1:98:3
1:21:21 1:23:19
objections [21
old [tJ
1:83:17 1:84:13
] :107:21 1:107:22
1:28:6 1:30:22
1:5:3 1:7:8
1:126: 19
1:84:17 1:84:20
1:113:13 1:126:9
1:36:16 1:41:15
objective [21
once [7] 1:85:6 1:85:13
1:131:3 1:159:11
1:42:17 1:44:6
1:8:12 1:42:3 1:85:21 1:86:7
1:44:10 1:47:2
1: 101:1 1: 101:13
1:42:4 1:96:7 1:89:1 1:91:7
1:159:11 1: 159:14
1:161:12 1:162:3
1:49:9 1:49:15 objectively fll
1:128:18 1:128:20 1:91:20 1:91:20
lieeded [6]
1:54:3 1:54:7 1:95:9
1:165:21 1:92:3 1:93:25
1:54:24 1:61:11
objectives [1]
one [94]
1:95:7 1:95:20
J :16:25 1:19:3
1:62:13 1:62:15
1:127:10
1:9:1 1:19:6
1:96:3 1:98:19
1:33:6 1:46:18
1:63:3 1:64:1
1:46:22 1:146:10
observation [ll 1:21:10 1:24:11
1:99:3 1:100:15
1:77:11 1:78:2
1: 100:16 1:106:24
filc:pagc:line l:mclaugh.txt
Index Page 12
Desmond et al vs Nar conon et al
'
.
'
.
Multi-Page 'I'M
opinions - pile
1:107:10 1:107:15 1:60: 16 parishionel'S [1] penn [lJ perhaps [l]
1:107:23 1:108:19
odando [2]
1:39:4 1:2:3 1:10:10
1:109:7 1:109:17
1:9:12 1:25:13 part [29] people [99] peliod[J]
1:126:5 1:136:12
otherwise [1]
1:22:3 1:27:4 1:8:1l 1:27;20 1:120:22
1:136:15 1:137:14
1:143:8
1:29:24 1:38:24 1:27:23 1:39:17
perkins [1]
1:137: 18 1:137:20
omselves [l ]
1:42:18 1:46:18 1:49: 1 1:49:6
1:36:23
1:138:16 1:138:20
1:71:2 1:74:23 1:49:8 1:49:12
permission [3]
1:138:21 1: 140:10
1:127:15
1:77:22 1:85:20 1:72:8 1:72: 12
1:141:10 1:141:17 outcome (1]
1:90: 14 1:90:15 1:83:19 1:84:10
1:87:7 1:88:23
1:141:19 1:141:20 1:148:8
1:93:10 1:99:22 1:84:18 J:85: 1
1:90:17
f:145:14 1:145:21
outdated [ll 1:119:18 1:126:20 1:85:6 1:85:16
person [18]
1:147:3 1:152:6
1:53:11 1:137:3 1:138:3 1:85:19 1:85:23
1:8:12 1:24:14
1:155:20 1:157:14
outlined [2J
1:142:25 1:145: 10 1:86:20 1:89:16
1:28:23 1:90:5
1:157:19. 1:158:21
1:155:14 1:158:23 1:90:14 1:92:4
1:100:5 1:100:7
1:159:13 1:159:15
1:33:21 1:149:3
1:159:4 1:159:4 1:92:7 1:92:12
1:100: 10 1:100:22
1:160:17 1: 161:2
outlines (lJ
1:162:13 1:163:14 1:92:20 1:93:2
1: 100:23 1:102:10
1:161:7 1:161:9
1:67:23
1:163:21 1:168:12 1:94:1 1:94:19
1:122:23 1:128:7
1:161:18 1:162:7 outpatient [19]
1:168:15 1:95:23 1:96:7
1:129:20 1:129:20
1:163:8 1:165:3 1:25:9 1:25:14
particulru. [3]
1:96:10 1:96:11
1:133:2 1:141:5
1:165:9 1:166:4 1:26:3 1:26: 15
1:26:17 1:55:8
1:96:24 1:97:5
1:148:7 1:169:1
1: 168:12 1:169:13 1:26:19 1:27:10
1:151:17
1:97:7 1:97:9 personal [3]
1:170:2 1:171:10 1:28:17 1:28: 18
parties t2J
1:97:12 1:97:18 . 1:93:9 1: 169:17
1:172:12 1:173:13 1:28:21 1:28:22
1:97:20 1:97:24 1:173:15
opinions [15]
1:29:3 1:29:7
1:176:13 1:176:14
1:97:25 1:99:17
personally [2]
1:11: 18 1:12:2
1:29:14 1:29:20 passion [3]
1:99:23 1:99:24
1:98:10 1:131:19
1:12:3 1:31:22
1:30:8 1:30:17 1:102:21 1:103:1
1:101:8 1: 101: 14
1:32:9 1:48:22
1:31:2 1:31:9 1:128:16
1:101:19 1:102: 13
persons (121
1:27:13 1:27:17
1:48:24 1:85:9
1:31:13
past [3J 1:102:22 1:102:23
1:33:17 . 1:78:1
1:87:4 1:113:3 outside [2] 1:22: 19 1:42: 1 1:102:25 1:103:7
1:84:1 1:84:24
1: 136:11 1:166:6 1:75:21 1:126:17 1:126:20 1:103:21 1:104:8
1:89:13 1:90:13
1:166:6 1:166:17
overcome [2] }>astor [3]
1: 104:8 1:104:9
1:90:23 1:126:12
1:168:6
1:109:13 1:109:15 1:47:1 1:108:20
1:104:14 1:105:7
1:137:23 1:172:4
opportunity [51
overreact [l J
1:120:9
1:105:10 1:105:10
perspective [1J
1: 105:24 1:106:5
1:19:19 1: 19:20
1:127:20 pastoral [181
1: 106:9 1:106:9
1:115: I
1:130:7 1:163:14
overseen [1]
1:4:19 1:38:23
1:106:15 1:107: 12 pertain [21
1:170:6
1:120:13
1:44:8 1:44:10
1:107:17 1:108:2 1:76:25 1:77:6
opposed [1]
ovel'View [1]
1:44:13 1:44:14
1:109:9 1:109: 14
petersburg [4]
1:119:10 1:47:9 1:52:8
1:116:2
1:59: 13 1:62:11
1:110:14 1: 11 7:8
1:25:10 1:26:2
order [411
own (6]
1:63:8 1:65:21
1:118:1 1:121:13
1:26:13 1:26:18
1:7:11 1:41:21
1:119:6 1:144:2S
1:66:25 1:68:3
1:126:5 1:126:14
phase [3]
1:43: 12 1:55:6
1:145:4 1:146:17
1:69:13 1:69:18
1:128:4 1:129:3
1:97:3 1:99:22
1:55: 12 1:56:13
1:146:18 1:147:18
1:70:8 1:78:13
1:129:13 1:129:22
1:145:7
1:57:8 1:57:19
1:130:3 1:130:8
. 1:57:20 1:57:22
page [8]
pastored [21
1:130:22 1:133:17
phases [11
1:58:4 1:64:7
1:4:12 1:35:23
1:50:13 1:121:3
1:134:5 1:135:13
1:89:24
1:65:2 1:65:5
1:40:23 1:45:20
pastoring [11 1:135:17 1:136:1 phil [7]
1:66:10 1:66:20
1:47:23 1:73:18
1:121:6 1:136:4 1:145:13 1: 14:4 1:14:6
1:67:2 1:67: 14
1:83:10 1:136:22
patient [1]
1:145:15 1:160:23 1: 14:7 1:14:1 1
1:67:24 1:68:5 page/line [1]
1:11:4
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1:35:23
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proves 111
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potential (2)
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qualify [5]
1: 16:7 1:19:4 1:78:3
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1:51:17 1:57:20
potentially 121
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1:12:19 1:13:24 I :90:15
1:110: 10 1:110:14
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practical [2] problem f13l
1: 115:21 1: 116:5
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1:119:17 1:128: 12
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fil c:puge:line 1 :mclough.txt
.Index Page J 4
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quantitatively - respect
quantitatively [lJ 1:41:7 l :126:3 1:114:2 1:131:5 1:42:11 1:43:2 1:145:20 1:170:17
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realized [11
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remain [2]
quarrel [lJ 1:46:17
1:158:8 1:159:22 1:45:6 1:49:24
1:103:12 1:103:13
1:164:20
really [20]
1:160:1 1:160:4 1:50:8 1:51:1
remember [131
1:174:6 1:51:1 1:51:11
ques [11 1: 11 :5 1:41:8
record's [21
1:51:19 1:53: 19
1:10:16 1: 10:23
1:87:21 1:51:22 1:64:21
1:63:1 1:66:13
1:16:21 1:17:5
questions [131
1:65:16 1:66:20
1:53:2 1:65:10
1:17:7 1:17:8
1:100:12 1:101:12 redevelopment [lJ
1:66:21 1:68:4
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1:88:5 1:95:17
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1:77:1 1:77:6
1:19:6 1:24:3
1:105:17 1:105:19
1:138:3 1:145:22
reduce [11
1:114:25 1:115:8
1:30:2 1:30:18
1:108:6 1:128:21
1:147:22 1:147:22
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1:121:17 1:173:15
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1:173:24 1:173:25
1:164:25 1:165:2
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1:174:2 1:174:4
1:165:5 1:166:2
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1:12:14 1:29:15
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1: 176:6
reducing [1]
relapse l3J
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reason [6]
1:168:24
1:6:14 1:6:16
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1:103:8 1:103:9
1: 157:25 1:158:9
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1:44:16 1:92:2
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reporters [l J
1:20:1
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1:89:11 1:99:12
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reporting [4]
1:23:9
1:102:20 1:125:1
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quote [4]
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1:92:19
1:38:12 1:117:15
1:6:15 1:6:17
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1:6:1 1:125:11
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1:155:14
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1:97:25 1:176:8
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1:6:1
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1:56:17 l :137:2
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1:104:13
1:56:13 1:57:19
1:15:24 1:29:18
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1:160:21 1:162: 17
rates Ul 1:67:2 1:68:4
1:118:2 I:i32:23
1:163:9 1:163: 13
1:84:18 1:106:19
1:29:24 1: 32:18
1:163:22 1:165:1
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1:11:21 1:160:24 1:71:4 . 1:78:22
1:14:5 1:14:11 1:45:2 1:45:13
regimen [11]
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1:14:15 1:47:4 1:48:17
religion [5]
1:44:1 1:47:5
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1:65:17 1:73:24
1:168:6 1:168:7
1:55:15
1:74:14 1:75:17
1:168:14 1:169:8 1:93:22 I :134:20
requirement [51
1:6:2 1:7:16
1:169:8 1:169:14 1:136:8 1:146:9
1:17:25 1:29:7
1:81:1 1:84:1
1:170:2 1:170:12 . 1:163:19
1:56:3 1:56:6
1:29:9 1:29:10
1:126:11 1:127:3
1:171:10 1:172:4
religions [4]
1:78:24 1:117:12
1:29:25 1:30:24
1:127:4
1:172:8
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1:80:8 1:133:3 recertified [1]
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requirements -[91
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relook (lJ
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regs [1J 1:166:25
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1 ~ 1 3 1 :6 1:160:2
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1:158:8 1:164:16
recidivism [11
regular [lJ 1:69:17 1:69:22 1:80:5
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1:79:2 1:79:14
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1:84:18
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1:79:22 1:86:13
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1:58:6 1:67:18
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1:136:25 1:137:7
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1:77:24 1:129: 18
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1:137:15 1:137:21 residential [9]
1:137:4 1:137:9
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rehab [SJ 1:137:22 1:138:9 1:23:21 1:25:4
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1: 158:15 1:158:16
1:20:25
1:73:14 1:120:3 1:141:19 1:152:7 1:28:5 1:28:7
real [5]
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1:172:6 1:152:24 1:155:18 1:29:3 1:29:14
1:11: 15 1:66:4
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1:109:10 1:41:25
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1:161:15 1: 161: 19
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r e a l ~ world [51 record [23]
1:49:1 1:49:6
1:161:25 1: 162:20
1:126:16 1:127:2
1:50:16 1:51:5 1:7:2 1:11: 15
1:49:12 1:83:19
relying [14] 1:129:18
1:74:8 1:75:10 1:13:13 1:54:1
1:84:10 1:92:4
1:31:1 1:64:10
resonated [ 1]
1:76:13 1:54:4 1:54:6
1:94:1 . 1:95:23
1:69:9 1:69:9
1:131:19
reality [2J
1:59:3 1:59:17
1:107: 17 1:110:14
1:69:13 1:80:2
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1:64:19 1:141:21
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1:160:23
1:85:19 1:86:15.
1:50:21 1:125:6
realize [21
1:81:13 1:1:13:20
rehabilitation [24]
1:86:20 1:134:1
1:125:19 1:131:17
1:113:25 1:114:1 1: 141:5 1: 145:14
file :page: line 1 :me laugh. txt
respond - sends
respond [2J 1:32: 1 1:32:16 1:124:21 1:125:5 1:105:12 1:162:17 1:163:10
1:127:17 1:146:11 1:138:22 1:155:15 1:131:1 1:135:12
sat [2]
1:1.63:13 1:163:21
response [3]
1:164:18 1:135:15 1:136:10
1:128:4 1:150:16
1: 163 :23 1:163:25
1:106:21 1:131:15 dgbt [181]
1:137:12 1:137:19
satisfied UJ
1:164:2 1:165:2
1:134:23 1:7:5 1:8:8
1:138:6 1:138:14
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scientology-related [lJ
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1:10:12 1:10:18
1:138:15 1:140:18
1:149:18
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1:141:17 1:143:9
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1:5:3
1:143:9 1:151:2
1:24:13 . 1:24:14
screen [11
rest [2]
1:19:12 1:20:11
1:150:21 1:171:8
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1:21:6 1:23:19
1:152:5 1:152:13
1:162:20 1:162:21
1:24:9 1:25:1
1:153:3 1:155:25 saw [18]
scripture [8]
restate [lJ
1:26:1 1:30:14
1:156:6 1:156:19 1:15:18 1:19:13
1:93:21 1:94:4
1:66:7
1:33:19 1:35:8
1:157:3 1:157:19 1:24:6 1:24:10
1:144:1 1: 145:9
restaurant 1:11 1:37:20 1:37:24
1:158:19 1:159:2 1:24:11 1:24:13
1:145:17 1:145:24
1:21:23 1:38:2 1:38: 16
1:159:8 1:159:9 1:28:20 1:36:3
1:146:4 1:147:14
result [5]
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through [50]
1:139:21
suite [2]
1:127:8 1:134:19
1:103:7 1: 103:9
theological [5]
1:5:8 1:34:12
1:2:4 1:2:23
1:154:13
1:103: 10 1:103: 11 1:38:2 1:46:10
sum [3]
teachings [2]
1:103: 12 1:108: 16
1:38:8 1:38:22
1:46:23 1:49:15
1: 167: 10 1:172:10
1:38:24 1:40: 15
1:51 :13 1:53:23
1:14:17 1:16:3
1:147:14 1: 152:2
1:173:13
1:172:13
1:117:23
1:54:7 1:61:24
tech [3]
tenets [11
theology (12] 1:67:24 1:72:9
sunmuuy [1]
1:128:25 1:143:8
1:152:24
1:8: 19 1:8:20 1:75:14 1:78:9
1:131:18
1:143:10
1:36:24 1:42:3 1:98: 1 1:99:18
sunshine [31
technical [1J
term (31
1:43:15 1:47:10 1:101:8 1:101:14
1:19:17 1:20:2
1:145:8
1:11:22 1:149:18
1:56:22 1:56:24 1:105:7 1:106:10
1:24:1
techniques [34]
1:149:19
1:56:25 1:57: 17 1:106:16 1:107:12
supplemental [JJ
1:84:3 1:91:24
terminal [1]
1:78:22 1:145: 12 1:119:4 1:126:3
1:5:3
1:93:12 1:93:20
1:37:8
therapy (1]
1:126:10 1: 129: 18
supplied [IJ
1:94:3 1:96: 12
terms [161
1:128:22
1:131:22 1:133: 14
1:47:2 1:102:5 1:117:22
1:26:23 1:32:11
there'll [11
1:133:18 1: 13lU7
supply 1'21
1:126:2 1:126:1!!
1:32: 12 1:40:13
1:96:9
1:139:1 1:139:21
1:56:12 1:56:22 1:139:22 1: 139:23
nlc:page:line l :mdaugh.txt
Index Page 18
Q&A REPORTING SERVICES, INC . .

throughout w video
1:142:13 1:151:8 1:24:22 1:72:2 transpired [1J 1:103:12 1:119:19 1:6:8
1:151:24 1:152:1
towards [t]
1:18:25 1:137:6 1:147:4
unique [11
1:152:24 1:153:22
1:164:15 tJ.eat [41
1:164:12
1:90:13
1:154:8 1: 154:9
tradition [4]
1:94:25 1:102:24 two-and-a-half-year [1
J united [3J
1:154:15 1:154:19
I :127:11 1:127:18
1:103:7 1:103:21 1:22:11
1:9: 14 1:10:22
1:155:7 1:156:7
1:134:24 1:135:2 treating [41 two-hour [11 1:25:8
1:156:!! 1:156:21
1: 156:22 1:157:21
traditional [2]
1:118:1 1:169:14 1:48:13
units [lJ
throughout [11
1:151:10 1:151:16
1:170:3 1:171:11
typically [2] 1:55:14
1:26:8
train [41
treatment [9] 1:10:10 1:149:3
unknown [I J
thursday [1]
1:90:23 1: 102:16
1: 40:4 1:90:1
under [20] 1:173:16
1:119:18 1:119:19
1:90:7 1:117:13
1:38:14 1: 40:8
unless [41
1:72:2
trained [9]
1:123:14 1:123:23
1:40:24 1:41:4
1:55:17 1:55:18
times [31
1:48:19 1:72: 15
1:124:2 1:124:16
1:55:23 1:55:23
1:85:4 1:124:9
1:27:25 1:33:7
1:105:11 1:108:24
1: 128:22
1:57:10 1:62: 10
unwilling 1:11
1:114:14
1:114:20 1:118:24
trial [151 1:62:12 1:64:9
title [6]
1:143:13 1:143: 13
1:9:8 1:9:10 1:67:4 1:70:4
1:141: 1
1:40:14 1:40:22
1:143:15
1:9:13 1:9:23 1:70:8 1:70:10
updated [lJ
1:41:10 1:41:11
training [891
1: 10:2 1:10: 6 1:70:16 1:101: 13
1:53:14
1:41: 17 1:42:5 1:10:6 1:11: 18 1:103: 18 1:142:5 upgrade [1]
titles [2J
1:18:9 1:18:18
1:12:6 1:59:23 1: 149: 12 1:176:7 1:55:10
1:19:9 1: 19:10
1:21:7 1:47:4
1:19:11 1:38:18
1:60: 13 1:61:11
undergo [1] used [23]
today [141 1:38:24 1:39:6
1:90:18 1:153:6
1:58:2 1:6:8 1:6:9
1:9:24 1:11:17 1:39:8 1:39:10
1:166:17
undergraduate [21
1:24:10 1:33:17
1:21:1 1:31:22 1:39:12 1:39:14
trials [lJ
1:38:4 1:42:9
1:90:23 1:93:12
1:87:3 1:87:8 1:39:16 1:44:16
1:10:8
underneath [1]
1:94:19 1:108:23
1:87: 11 1:88:2 1:45:2 1:45:13 triggered [2J
1:45:22
1:114:16 1:115:22
1:88:19 1:126:20 1:46:24 1:47:3 1:26: 19 1:166:24
undersigned [ 1]
1: 115:23 I :120:13
1:129:23 . 1:152:21 1:47:5 1:48:16
true [31
. 1:127:14 1: 132:8
1:167: 1 1:167:7 1:48: 17 1:49:9
1:175:2
1: 133:21 1:134:6
1:156:14 1:175:3
together [91
1:50:6 1:50:21
1:176:9
understand [641 1:136:3 1:145:23
1:18:7 1:53:9
1:53:1 1:56:13
try [5]
1:8:12 1: 11: 17 1:146:9 1:146:19
1:66:13 1:120:6
1:56:17 1:57:1
1:11:19 1:12:3 1:151:17 1:153: 19
1:58: 1 1:58:9
1:76: 10 1:88:1
1:12:6 1:12:10 1: 163:18
1:14-6:3 1:147:12
1:95:9' 1:96: 17
1:14-7:16 1:165:21
1:64:11 1:64: 15
1:12:13 1:19:2
users [2]
1:110:12
1:28:22 1:29:6
1:169:9
1:64:19 1:64:20 1:102:22 1: 168:21
tomofl' [2]
1:65:4 1:65:5
trying [421 1:31:21 1:38:25
using [15]
1:65:16 1:65:17
1:12:1 1:14:5 1:41:5 1:43:9
1:1:0 1:176:22
1:66:20 1:68:3
1:14:11 1:14:15 1:43:22 1:58:3
1:33:9 1:75:1
tomorrow (11
1:68:19 1:68:21
1:15:17 1:19:2 1:66:20 1:70:23
1:96:14 1:96:25
1:116:23
1:71:8 1:71:12
1:41:24 1:43:21 1:75:4 1:76:2
1:98:12 1:99:25
1:117:4 1:117:9
.toned [11 1:71:16 1:71:17
1:44:7 1:57:7 1:84:8 1:86:1
1:123:11 1:130:16
1:24:22 1:71:20 1:72:12
1:59:6 1:62:16 1:86:5 1:87:2
1:146:15 1:146:16
too [3]
1:72:18 1:72:22
1:70:23 1:76: 12 1:87:3 1:87:22
1:147: 1 1: 149:22
1:46: 18 1:91:14
1:73:23 1:74:7
1:91:16 1:95:5 1:90:24 1:94:8
1:149:23
1:104:6
1:74: 13 1:76:6
1:95:6 1:95:8 1:94:21 1:95: 10
took [1'3]
1:76:8 1:76: 14
1:95: 11 1:95:19 1:95: 19 1:96:18
usual [11
1:76:20 1:77:5
1:96:19 1:98:5 1:99:9 1:101:16
1:6:18
1:19: 19 1:19:20
1:81: 1 1:!!3.:24
1:99:4 1:99:8 1:103:16 1: 104:20 . . utiUze [2]
1:20:3 1:24:2
1:89:24 1:90:2
1:101:5 1:104:23 1:108:3 1:108:4 1:115:19 1:133:11
1:24:4 1:24:5
1:90: 11 1:91:7
1:104:25 1:108:5 1:116:8 1:123:19
utilized [2J
1:36:10 1:41:14
1:91:8 1:91:22
1: 108: 17 1:116:11 1: 128:6 1:129:12
1:19:7 1:121:3
1:42:13 1:118:17
1:96:14 1:102:13
1: ll8:13 1:120:3 1:135: 14 1:138: 11
1:119:21 1:130:1
1:102:14 1:104: 14
1: 121:22 1:138:4 1:141: 14 1: 141:16
vague [1J
1:133:2
1:117:8 1:117: 16
1:141:14 1: 141:14 1:141: 16 1:142:11
1:10: 17
tool [11
1:118: 1 1:121:8
1:147:6 1: 147:8 1:147:7 1:147:9
various [41
1:119:17
1:126:3 1:U6:10
1:148:9 1:151:3 1:147: 10 1:148:9
1:37:11 1:39:4
tools [2] 1:126: 11 1:127:2
1:151:6 1:162:14 1:148:25 1: 149:17
1:48:22 1:116:3
1:56:24 1:57:2 1:127:4 1: 129:25 tulsar21
I :150:6 1:151:6 verbal[2J
topic [1]
1:130:6 1: 142:2 1:121:10 1:121:11
1:152:5 1:154:17 1:143:8 1:143:10
1:83:14
1:142:17 1:142:19
turn [11
1: 158:3 1;162:16
versus [4]
topics [1]
1:142:22 1:145:18
1:68: 15
1:165:21 1:165:25
1:9:14 1:10:22
1:145:19 1: 149:12
twner [2]
1:169:9 1:172:21
1:29:14 1:29:20
1:18:3
1:149: 15 understood [5J
total [7]
1:9:13 1:10:22
vice [3J
transcript [ BJ
1:19:25 1:88:7
1:21:4 1:21: 10
1:14:17 1: 16:3
1:5:9 1:5:9
two [19]
1:88: 15 1: 164:4
1:21:14
1:26:9 1: 103:21
1:6: 1 1:6:7
1:16:23 1:16:24
1:164:6 .
1:106: 15 1: 107:11
1:6: 18 1:6:19
1:17:3 1:17:3
unfinished [1]
vid [lJ
1:173:13 1:20:4 1:24:3
1:168:3
touch Ill
1:60:7 1:176:9
1:24:12 1:36:18
1:6:9
video (15]
1:169:2
transition [3]
J :53:16 1:55:9
unidentified [2]
1:1:0 1:7:1
toured (21
1:118:12 . 1:118: 15
1:56:8 1:65:18
1:92:6 1:92: 12
1:53:25 1:54:4
1:143:18
1:65:20 1:66:24 unintentional [1] 1:81:10 1:81: 12
flle: page: line 1 :rnclaugh.IJ<.t
videographer - zero
1:113:24 1:114:2 1:101:4 1:148:11 without [5] 1:21:20 1 ;41:24
1:131:4 1:131:7
web r/1
1:78:4 1:124:10 1:55:10 1:55:12
1:159:25 1:160:3
1:4:15 1:4:17
1:151:11 1:151:19 1: 55:14 1:172:10
1:167:19 1: 167:21
1:5:1 1:23:10
1:170:7 1:172:13
1:174:5
1:35:12 1:73:13 witness [381 years [91
Yi.deographer [141 1:73:13 1:5:8 1:7:14 1:20:22 1:22:6
1:7:1 1.:53:25
week[2J
1:8:5 1:9:6 1:23:17 1:23: 18
1:54:3 1:81:5
1:72:11 1:126:11
1:11:23 1:12:19 1:50:13 1:103:12
1:81:9 1:81:12
weinberg [l]
1:13:4 1:13:14 1:108:16 1:126:19
1:113:24 1:114:2 1:14:13 1:19:4 1:172:10
1:131:4 1:131:7
1:2:23
1:19:4 1:35:2
yesterday [11
1:159:20 1:159:25
welcome [1]
1:45:21 1:45:23
1:13:2
1:160:3 1:174:5
1:83:7
1:47:19 1:47:21
yet [3)
view [21
west [2] 1:55:2 1:59:5
1:63:22 1:82:9
1:100:6 1:109:12
1:1:0 1:2:11 1:60:2 1:63:24
1:158:14
vii1ually [31
whatsoever [21
1:73:10 1:74:18
yourself [SJ
1:142:23 1:154:22 .
1: 15:23 1:40:4
1:79:6 1:85:25
1:87:15 1:87:20
1:8: 15 1:8:24
1:154:23 wheeler [11
1:88:4 1:88: 19
1:22:17 1:44:24
visit [31
1:2:23
1:92:13 1:110:21
1:55:10 1:90:20
1:19:14 1:23:19 where'd [1)
1:111:10 1:111:12
1: 150:9 1:167:22
1:25:16 1:103:24
1:111:15 1:113:19 zero [1)
visited [7] wherever [31 1:158:11 1: 159:24 1:68:2
1:18:10 1:19:12 1:19:1-7 1:19:18 1:174:1 1:176:11
1:25:12 1:25:13 1:121:12
word[SJ
1:25:15 1:27:6
whole [7] 1:8:10 1:33:9
1:27:9
1:28:22 1:33:3 1:33:14 1:75:1
vit [1) 1:40:7 1:40:7 1:98:19 1:98:20
1:169:6 1:43:3 1:44:16 1:116:18 1: 127:14
vitamin [lOJ
1:169:1
words [41
1:168:6 1:168:14 wife [9] 1:15:3 1:100:13
1:169:7 1:169:8 1:15:19 1:19:20 1:146:17 1:148:9
1:170:2 1:171:10 1:20:12 1:20:16
workbooks [2]
1:171:25 1:172:7 1:21:1 1:21:8
1:31:23 1:31:23
1:172:16 1:173:14 1:71:23 1:132:8
worked[IJ
vitamins [51
1:134:12
1:128:15
1:168:8 1:168:21 william [1]
works [11]
1:168:23 1:168:24 1:133:4
1:169:3
willing [6]
1:21:23 1:64:2
1:100:4 1:100:19
vocabulary [11 ' 1:86:23 1:87:12
1:102:7 1:128:23
1:161:21 1:89:16 1:92:20
1:129:14 1:148:11
voluntalily [ 1]
1:94:24 1:96:4
1:171:9 1:171:25
1:90:21 window [IJ 1:172:16
volunteer 11:1
1:25:17
workshops [lJ
1:170:4 wish [2J 1:55:11
volunteered [21
1:101:21 1:160:15
worldrsJ
1:48:19 1:172:7 withdraw [3] 1:108:20 1:109:10
wait [21
1:157:14 1:160:10 1:134:20 1:136:4
1:73:1 1:87:20
1: 170:24 1:155:17
waived [lJ
withdrawal [241
writing [51 -
1:85:4
1:45:8 1:52:9 1:36: 16 1:41:21
walk.rsJ
1:52:10 1:52:25 1:42:5 1:48:9
1:53:4 1:53:16 1:134:6
1:38:2 1:46:10
1:62:18 1:63:6
writings [3]
1:51:13 1:54:7
1:61:11
1:65:22 1:69:6
1:131:18 1:133: 15
wallet [LJ
1:69:23 1:71:21
1:149:4
1:72:18 1:78:16
Wlitten [4)
1:60:4
1:89:25 1:90:3
wants [21 1:97:3 1:99:20
1:22:25 1:143:5
1:15:20 1:146:9 1:99:22 1:116:13
1:143:25 1:151:19
ward [1]
1:140:20 1:140:23
wrongrsJ
1: 121:9
1:144:10 1:168:16
1:64:3 1:66:7
washington [1]
withdrawing [3]
1:74:22 1:77:13
1:77:20
1:2:17
1:161:16 1:162:1
wrote [2]
watrh [1]
1:162:2
withdrawn L41
1:133:3 1:133:8
1:167: 19
yaeger [11
wayman [1]
1:90:4 1:96:25
1:97:2 1:165:10
1:2:16
1:121:9
within [21
year [91
ways [4]
1:22:3 1:126:2
1:15:17 1:20:22
1:48:3 1:101:2
file: page: line 1 :mclaugb. txt
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