10A28641 2 2012-01-05 DepositionOfStephenAlanKent Ocr

Documents courtesy of:
http://ReachingForTheTippingPoint.net
In The Matter Of:
Desmond, et al. v.
N arconon, et al.
Stephen Alan Kent
January 5, 2012
Q&A Reporting Services, Inc.
Certified Court Reporters
2165 Fair haven Circle, NE
Atlanta, GA 30305
404.233.3300 ** JFischer@QAReporting.com
Original File kents.txt , C;
Min-U-Script with WonrinO.et. . r: '-
Atll0: 4:
Desmond, et al. v.
Narconon, et al.
IN THE STATE COURT OF DEKALB COUNTY
STATE OF GEORGIA
PATRICK C. DESMOND AND MARY )
C. DESMOND, INDIVIDUALLY, AND)
MARY C. DESMOND, AS )
ADMINISTRATRIX OF THE ESTATE )
OF PATRICK C. DESMOND, )
Plaintiffs, )
) CIVIL ACTION PILE
vs. )
) NO. 10A28641-2
NARCONON OF GEORGIA, INC., )
DELGADO DEVELOPMENT, INC., )
SOVEREIGN PLACE, LLC, )
SOVEREIGN PLACE APARTMENT )
MANAGEMENT, INC. , LISA )
CAROLINA ROBBINS, M.D., THE )
ROBBINS GROUP, INC., AND )
NARCONON INTERNATIONAL, )
Defendants. )
Deposition of STEPHEN ALAN KENT, taken
on behalf of the Defendants Narconon, pursuant
to the stipulations contained herein, before
Jo Tornoff Fischer, RMR, CCR No. B- 924, at
1201 Peachtree Street, 400 Colony Square,
Suite 900, Atlanta, Georgia, on January 5,
2012, commencing at the hour of 10:10 a.m.
Q&A REPORTING SERVICES, INC.
Certified Court Reporters
2165 Fairhaven Circle, NE
Atlanta, GA 30305
404.233.3300 ** (Fax) 404.233 . 1530
Page2
1 APPEARANCES OF COUNSEL
2 ON BEHALF OF THE PLAINTIFFS:
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REBECCA FRANKLIN, ESQ.
Franklin Law, LLC
400 Colony Square, Suite 900
1201 Peacht ree Street, NE
Atlanta, GA 30361
(404) 961-5333
ON BEHALF OF THE DEFENDANTS NARCONON OF GEORGIA
and NARCONON INTERNATIONAL:
STBVAN A. MILLER, ESQ.
BARBARA A. MARSCHALK, ESQ.
Drew, Eckl & Farnham, LLP
880 West Peachtree Street
P.O. Box 7600
Atlanta, GA 30357
(404) 885-1400
ON BEHALF OF THB DEFENDANT NARCONON INTERNATIONAL:
HELENA K. KOBRIN, ESQ.
Moxon & Kobrin
Suite 900
3055 Wilshire Blvd.
Los Angeles, CA 90010
(2 13) 487-4468
ON BEHALF OF THE DEFENDANT DELGADO DEVELOPMENT:
SEAN L. HYNES, ESQ.
Downey & Cleveland, LLP
288 Washington Avenue
Marietta, GA 30060
(770) 422-3233
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Stephen Alan Kent
January 5, 2012
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ON BEHALF OF THE DBFBNDANTS LISA CAROLINA ROBBINS,
M.D. and THE ROBBINS GROUP, INC.:
JEFFREY N. AMASON, ESQ.
Weinberg, Wheeler, Hudgins, Gunn & Dial, LLC
Suite 2400
3344 Peachtree Road
Atlanta, GA 30326
(404) 876 - 2700
INDEX TO EXAMINATION
Page4
2 By Mr. Miller.
3 By Mr. Hynes
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.190
.211
4 By Ms. Franklin.
5 By Mr. Miller.
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DEFENDANTS'
EXHIBIT
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INDEX TO EXHIBITS
DESCRIPTION PAGE
S. Kent CV 8

re Work in Desmond Case
(NP-Kent-0737 - 0907) 8
Composite Exhibit - Kent File
Materials Not Reviewed:
Document Productions/Depositions/
Discovery Responses 8
12-12- 11 Letter from R. Franklin
to K. Whitlock I Supplemental
Expert Disclosures 8
Plaintiffs' Expert Disclosures 8
Chart of Lawsui ts Involving
Narconon
IRS/Sci entology Settlement
Agreement
(NP- Kent - 0838 - 0896)
Photocopies I Front Covers of
Books Used in Narconon Courses
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1\lin-U-Script Q&A Reporting Services, Inc.
JFischer@QAReporting.com
(1) Pages 2 - 4
Desmond, et al. v.
Narconon, et al.
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Photocopy I "The Scientology
Handbook"
{NP-Kent-0759 - 0767)
nNarconon News
{NP-Kent-0835 - 0837)
"Purification: An Illustrated
Answer to Drugs
{NP-Kent - 0768 - 0773)
Book 6 I "Personal Values and
Integrity Course
Marburg Journal Art icle I
"Alternative Therapy,
Dianetics, and Scientology"
{NP-Kent-0737 - 0758)
Composite Exhibit Narconon Info
{NP-Kent-0774 - 0797)
"The Narconon Rehabilitation
Program - Article by
W. Benitez
{NP-Kent-0798 - 0801)
"Celebrity Article I How
the Purificat i on Rundown
Works
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{NP-Kent - 0802 - 0808)
Scientol ogy Submission to
IRS
{NP-Kent-0809 - 0820)
Composite Exhibit re
NarcononiScientology
{NP-Kent-0821 - 0834)
Narconon Drug Rehabilitation
Program Information
{NP-Kent-0901 - 0907)
USA vs. M.S. Hubbard I
; : ~ ~ l ~ ~ l : r ; ~ Informal Bill of
{NP-Kent-0897 - 0900)
Book l I "Therapeutic TR Course
Book 3 I "Learning Improvement
Course
Book 4a I "Communication and
Perception Course"
Book 5 I "Ups & Downs in
Life Course"
Book 7 I changing Conditions
in Life Cour se
Book 8 I "The Way to Happiness
Course"
Listing of Scientology Articles
from Kent Web Site
N. Williams vs . T. Lowery I
Deposition of S. Kent
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{Original Defendants Exhibits 12 and 21 - 26 were
retained by Ms. Franklin.)
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Stephen Alan Kent
January 5, 2012
{THE FOLLOWING TRANSCRIPT CONTAINS QUOTED
MATERIAL; SUCH MATERIAL I S REPRODUCED AS
READ OR SPOKEN.)
Page 7
{IN THE FOLLOWING TRANSCRIPT, A DASH [ -- )
IS USED TO INDICATE AN UNINTENTIONAL OR
PURPOSEFUL INTERRUPTION OF A SENTENCE;
AN ELLIPSIS [ . ) IS USED TO INDICATE
HALTING SPEECH OR AN UNFINISHED
SENTENCE IN DIALOGUE, OR AN OMISSION
OF WORD[S) WHEN READING WRITTEN
MATERIAL.)
(Thereupon, the court reporter disclosed that she was
there on behalf of Q & A Reporting Services, Inc.
In compliance with Article lO.B of the Rules and
Regul ations of the Board of Court Reporting of the
Judi cial Council of Georgia and O.C. G. A. l5-l4-37{a)
and {b), the court reporter d iscloses that she was
retained by StevanA. Miller, Esq. , t o take down
the proceedings . Q & A Reporting Services, Inc.
will charge the attorneys t he usual and customary
rate for the transcript, and will be paid by the
attorneys upon their receipt of the transcript.)
Page 8
(Thereupon, marked for identification
purposes, Defendants' Exhibit Nos. 1
through 6.)
MR. MILLER: This will be the deposition
of Dr. Stephen Kent, taken by the defendants
for purposes of discovery only. I realize
that you may -- well, I'm j ust going to say
we want to take this for purposes of
discovery only. It's being taken at this
time and place pursuant to agreement of
counsel, with waiver of all formalities with
respect to the time and place of taking the
deposition. And we can agree, 1 believe, to
reserve all objections except as to the fonn
of the question until such time as the
deposition might be used for some purpose.
MS. FRANKLIN: We can agree to that. We
don't agree to the deposition being taken
just for purpose of discovery; we would ask
the deposition be taken for all purposes
allowed under the Georgia Civil Practice Act.
But with that, everything else we can agree
to.
MR. MILLER: Okay. And how about
signature?
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Desmond, ct al. v.
Narcooon, et al.
Page9
1 MS. FRANKLIN: He's going to read and
2 sign.
3 MR. MILLER: And we'll stipulate he can
4 do that in front of any notary public.
5 MS. FRANKLIN: Yes.
6 MR. MILLER: Dr. Kent, my name is Steve
7 Miller, and here in a moment the court
8 rep01ter is going to swear you in and we'll
9 ask you some questions.
10 (Discussion off the record.)
11 STEPHEN ALAN KENT,
12 having first duly affirmed, was examined and
13 testified as follows:
14 EXAMINATION
15 BY MR. MILLER:
16 Q. Dr. Kent, my name is Steve Miller; I represent
17 Narconon of Georgia and Narconon International in a
18 lawsuit that's been filed here in Georgia. And my
19 understanding is that you've been designated as an
20 expert witness in this lawsuit; is that your
21 understanding?
22 A. That's my understanding, yes.
23 Q. And my purpose here today is to find out all
24 of the opinions that you might come to court to testify
25 about. Do you understand that?
Page 10
1 A. I do.
2 Q. And I also want to fmd out the basis for all
3 those opinions.
4 A. I understand.
5 Q. And if I ask you a question in an inartful
6 way, I would appreciate it if you would let me know.
7 A. I understand.
8 Q. So if you answer my question, I'm going to
9 assume that you've understood my question; is that fair?
10 A. That's fair.
11 Q. And we can take a break anytime you would
12 like.
13 Why don't we go ahead and have you just tell
14 us your full name, where you live, and how old you are.
15 A. Okay. My name is Stephen, S-T-E-P-H-E-N,
16 Alan, A-L-A-N, Kent, K-E-N-T. And I live in Edmonton,
17 Alberta, Canada, and I'm 60 years old.
18 Q. And are you a Canadian citizen?
19 A. Dual citizen.
20 Q. With Canada and ... ?
21 A. And U.S. Canada and U.S.
22 Q. We've marked as Exhibit 1 to your deposition
23 what's been provided to us as your CV. Could you
24 confirm that for us?
25 A. Yes, sir, that's my CV.
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Q.
A.
Stephen Alan Kent
January 5, 2012
Page 11
And is it current and up to date?
Yes. I don't believe any articles have come
out since the last one I' ve got listed, number 43. I
don't think anything else has come out in print since
then, so, as far as I know, it's up to date.
Q. And we've been provided with Exhibit 2, which
l S --
A. All right.
Q. --my understanding of your file materials
conceming your work on this case?
A. Yes. These are some initial submissions that
I -- that I made. Right.
Uh-huh (affirmative). Everything looks ...
I'm just astonished how much paper court cases
take. Yeah, this looks like -- this is certainly what I
submitted. I haven't seen anything omitted so far.
Q. Well, I will represent to you that I tried to
print out everything --
A. Sure. I understand.
Q. --that was E-mailed to us.
A. Sure.
Q. But let me know ifthere's any reason--
A. Okay.
Q. -- you think that's not your complete file
materials on this case.
Page 12
A. Hmrn. Uh-huh (affirmative).
Almost at the end. It looks -- it looks fine
so far.
Looks fine. And, sir, what's "NP" mean, down
at the bottom?
Q. I'll explain that right now. Exhibit 2 has
been marked with what we call Bates numbers?
A. Uh-huh (affirmative).
Q. And so it's Kent-0737 through Kent-0907.
That's just a way for us --
A. Sure.
Q. --to, in--
A. Sure.
Q. -- effect, you know, reference certain pages
in here.
A. Sure.
Q. So Exhibit 2 is your complete file materials
on this matter?
A. lt looks like it. And "NP," what does that
mean? I'm just curious; I don't know.
Q. Non-party.
A. Okay. Thank you. Sorry to ...
Q. No. No problem. You said that was your
"initial submission." Would that have been an initial
submission of information that you sent to the
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(3) Pages 9 - 12
http://ReachingForTheT Tip ii pingPoint.net
Desmond, et al. v.
Narconon, et at.
Page 13
1 plaintiffs' lawyers in this case?
2 A. That's right, yes.
3 Q. Have you sent them anything else?
4 A. No.
5 Q. Any other file materials that you've generated
6 on this case?
7 A. No.
B Q. Have you consulted any documents that are not
9 contained in Exhibit 2 in order to reach your opinions?
10 A. I've looked at all of the Narconon course pack
11 materials that plaintiffs have.
12 And then I've done, you know, background
13 research material on different aspects ofNarconon, back
14 in files that are at the university. But in terms of
15 this particular -- this particular case, it's those
16 Narconon books. That-- I think copyright 2004.
17 Q. Okay. So let me be clear. In terms of
18 specific documents that you've referenced to reach your
19 opinions in this case, it would be Exhibit 2 and what
20 you describe as the course pack materials for Narconon?
21 A. That's right. And then reference from the
22 course pack material back to Scientology documents.
23 Q. What Scientology documents are you talking
24 about?
25 A. Well, the simple way is to look at Scientology
Page 14
1 web sites. So I would find documents and mentions of
2 terms, for example, say, "suppressant person," and then
3 go to the Scientology web site and see if on the
4 Scientology web site a term like that exists. And in
5 all the instances of the terms that I identified as
6 crucial in this case, I found them all on Scientology
7 web sites, and then previously, when I've looked at
B another Narconon case, or-- or earlier pack, not this
9 one, in documents back at the University.
10 So, for example, there's a course pack on the
11 TRs that I've looked at. But the TRs are mentioned--at
12 least, TR 1 through 4 is mentioned--on the Scientology
13 web page. So that's the sin1plest place to go. And I
14 cettainly went there to verify these terms. That these
15 terms are from Scientology.
16 Q. Do you have any notes from your review of the
17 course pack materials?
18 A. No.
19 Q. Nothing on a computer someplace about --
20 A. No.
21 Q. -- you made --
22 A. No.
23 Q. Okay. Give me the complete list of the terms
24 that you found in the course pack materials that you
25 thought were significant.
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Stephen Alan Kent
January 5, 2012
Page 15
A. I can do my best by memory. Now, it would be
useful if I had the course packs here. I don't know if
that's appropriate. If I do it by memory, I'm certainly
going to forget some things.
Q. Well, we're here, as you !mow, to find out all
of your opinions, --
A. Sure.
Q. -- and the basis for all of your opinions, so
I want for you to be as complete as you possibly can be.
Q. But give me that .list as completely as you can
right now.
A. Okay. And I'll do so with the understanding
that I may forget something.
MS. FRANKLIN: Did you bring the course
packs?
THE WITNESS: The course pack's here.
BY MR. MILLER:
Q. Okay.
A. Do you want to -- if we can get them, it would
certainly reduce the mistakes I might make or the
omissions I might make.
Q. Okay. Have you tabbed them in some way?
A. No. I think I've put in two tabs in the
course packs. But it's pretty easy to look at them and
Page 16
know what's in them.
Q. Well, let's do this. Let me get your list off
the top of your head now, and then we'll come back to
the course pack materials a little bit later in the
deposition.
A. If that's -- as long as we come back to them,
that's -- that's fine.
An initial course pack has to do with training
routines. And in this case it's TR, for training
routines, 1 through 4, and then 8 through -- I'm sorry,
there's no TR5, as near as I can tell. And then TR6 to
9, although 9 seems to be repetition ofTR6. So in
essence there are -- the pack has nine TRs, but there's
actually only eight -- eight ones. Number 2 is --
refers to the "Purification Rundown." And that book
isn't here, so I had to look at other PUiification
Rundown materials. But I've known about the
Purification Rundown for years, so ...
Number 3 I believe is a pack about learning
how to learn. So banicrs to learning, attitudes that a
student might have that he or she knows everything ahead
of time. Three banicrs to leaming, one involving
doing modeling. Often clay modeling, but even using
items--paper clips and pencils and so on-- erasers--to
give mass -- well, it's to give mass --mass to an
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Desmond, et al. v.
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1 object, as it's called.
2 Second problems to learning involves what's
3 called too steep a gradient. So a person gets exposed
4 to infonnation too -- that's above his or her learning
5 level. So information is too complicated for the
6 person. "Too steep a gradient" is the term.
7 Then third is what's called "misunderstood
8 word." And "misunderstood word" is a cmcial concept in
9 Scientology. The argument is that if a person reacts
10 badly to a course, doesn't like the course, gets bored,
ll gets angry, it's almost certainly because be or she went
12 past a word that he or she did not understand. So it's
13 a misunderstood. So it's emphasis about always looking
14 up misunderstood words in a dictionary.
15 Now, 4, if I remember correctly, is-- there
16 are two books, there's 4a and 4b. 4a, if I'm not
17 mistaken, is essentially a repeat of the TR course. And
18 then 4b is an examination or a use of things called
19 "objectives." Objectives, at least as I see them,
20 are -- well, they're similar to some things that come up
21 in the TRs, but they're also similar to what's called
22 "locationals," Hubbard's -- L. Ron Hubbard's assumption
23 was that people can get focused on events, negative
24 events, in their past. And these locational -- or,
25 these objectives, bring a person up into what's called
Page 18
1 present time. So they'll be corrunands to a person, you
2 know, to look at a wall and touch a wall, look at a
3 comer, on -- and touch a desk, and so on.
4 Q. Let me stop you just a minute. Who is L. Ron
5 Hubbard?
6 A. Oh. L. Ron Hubbard is the founder of both
7 Dianetics and Scientology, and he's the inspiration for
8 the materials in these -- all the course packs are based
9 upon the works of L. Ron Hubbard.
10 Q. And is that fairly common knowledge, tl1at
11 L. Ron Hubbard was the founder of the Church of
12 Scientology?
13 A. You know, I'm always surprised how many people
14 don't know that. You know, because I've worked in it
15 through the years so much I assume it's widely known,
16 but I just run into people who don't know. So I
17 can't-- you'd think with the amount of publicity that
18 it would be widely known, but I can't say that it is. I
19 think a lot of people really don't know.
20 Q. But certainly it's out in the general body of
21 knowledge that people might have?
22 A. People might have it. I just don't know if
23 they do.
24 Q. Have you done any sort of studies in terms of
25 name recognition to see what percentage of people--you
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Stephen Alan Kent
January 5, 2012
Page 19
know, adults--would recognize that L. Ron Hubbard was
the founder of the Church --
A. No.
Q. -- of Scientology?
A. No, I'm talking about any name recognition.
So--
Q. Certainly easy to determine in this Internet
age, if you wanted to?
A. If you typed in "L. Ron Hubbard," you'd get
"Scientology" at some point.
Q. Okay. I intcnupted you; go ahead.
A. No, that's all right. 5 --I could get 5 and
6, the books, mixed up. One is the "Ups & Downs of Life
Course," and that's a straight recitation of Scientology
concepts about social personalities, antisocial
personalities and potential trouble sources. And these
are standard Scientology terms you can find many places.
There's even a course that Scientologists can take.
Next is -- and again, knowing that I could be
switching 5 and 6, next is a course on values. And this
is a Narconon course, really based upon -- I think it's
called the "Personal Integrity and Values Course" in
Scientology. And it gives forward to a person a number
of precepts or values that L. Ron Hubbard thought were
important.
Page 20
6, let me see what 6 is. I'm blanking on 6.
7 is "The Way to Happiness." Which is a 21 --21
numbered set of precepts about what Hubbard thought were
important. Similar to, you know, do not kill, do not...
You know, honor governments if they respect people, and
so on and so on. And these are straight out of"The Way
to Happiness" book, published by Scientology for
Hubbard.
Now, the one that I'm missing, it's a
person -- let's see, the values... I'd have to -- if
I -- oh, oh, oh, oh, oh, oh. No, it's not the
objectives.
Ifl saw the -- if I saw the... Oh, um ...
It'll come. I j ust can't remember. There's one that
I'm missing. And if I saw the book I could tell you.
It may in fact -- if it comes to me, I'll come back and
correct this.
Q. Okay. Well, we'll come back to the books, but
what I'm unclear on is, did you have to go and do
research in connection with reaching your opinions in
this case, to look at these books and say that there arc
Scientology type concepts in the books?
A. Well, I knew from previous research on
Narconon and Narconon cases that these are Scientology
books. So when I actually got ahold of this particular
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Desmond, et al. v.
Narconon, et al.
Stephen Alan Kent
January 5, 2012
Page 21
1 case it was very easy go through them again and say,
2 "Oh, yeah. Oh, yeah, I recognize this. This is where
3 it comes from." So that was-- that was simple.
4 Q. Did you have a set of the books in Canada?
5 A. Not of-- not from this program, no.
6 Q. So I assume that the set of books you looked
7 at were provided to you by plaintiffs' counsel?
8 A. The set of books for this -- for this program,
9 for Georgia, yes.
10 Q. And when did you receive that set of books?
11 A. Yesterday.
Page 23
1 A. Jeff Harris.
2 Q. Anybody else on the call?
3 A. I'm not sure; I know at some -- at some point
4 I had spoken to Rebecca. I'm not sure whether it was a
5 conference call or not.
6 Q. Have you talked to anybody in reaching your
7 opinions in this case other than Jeff Harris or Rebecca?
8 A. No.
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Q. You haven't talked to any of the witnesses in
this case?
A. No. No.
12 Q. Other than looking at that set ofbooks 12 Q. You mentioned that you had worked on a another
13 yesterday and just confmning on the Internet some l3 Narconon case.
14 things, -- 14 A. No, there's -- well, it wasn't a case, no; it
15 A. Uh-huh (affim1ative). 15 was just the course-- the course pack. I mean,
16 Q. --anything else you've consulted, outside of 16 Narconon's been an interest, well, for a l ong time,
17 your Exhibit 2? 17 'cause it's part of Scientology.
18 A. As I say, I consulted a previous Narconon pack 18 Q. So you have not had any other claim where you
19 from Chilocco, Oklahoma. If you'll notice, these books 19 did any sort of legal consulting involving Narconon?
20 are copyright I think 1991 and 2004. The course pack 20 A. As far as I can recall, no.
21 that I had looked through was 2001. And it didn't have 21 Q. Let me show you Exhibit 3, which was a
22 the-- you know, the one booklet that the 2001 didn't 22 document that was--
23 have was "The Way to Happiness." 23 A. Yes.
24 Q. And when did you consult that Oklahoma course 24 Q. --supplied to us. And based on the
25 pack? 25 discussion we had at the beginning of the deposition, my
Page 22 Page 24
1 A. When I was back in Canada. And I've had -- 1 understanding is that, whether you were or were not
2 you know, I've looked at it on and off for years, 'cause 2 provided with any of the documents on Exhibit 3, you
3 the university's had it for a long time. 3 have not consulted them in order to reach your opinions
4 Q. Did you specifically go and pull it out for 4 in this case?
5 this case? 5 A. That's right. I've not consulted -- I've not
6 A. Yes. 6 formed my opinion based upon any of -- any material
7 Q. When were you first contacted about this case? 7 here. And I-- I didn't even think I've seen the
a A. Geez. I'm --I can't tell you exactly. I'm 8 depositions here. As 1 say, I've got a CD-ROM which I
9 going to say probably November. 9 just assumed was repeats of Mary Rieser's, and I never
10 Q. Of 2011? 10 opened it. And then when I got my instructions, I
11 A. Of -- that's right, yes. 11 thought it really didn't matter what other people said
12 Q. Do you remember what part of the month? 12 in the depositions. This was just going to be exha,
l3 A. Oh, I can't -- I can't tell you. I really 13 unnecessmy work. So I didn't use anything on here to
14 can't tell you. 14 form my opinion.
15 Q. Do you have billing records? 15 Q. Prior to yesterday, when I assume you came to
16 A. Back in Canada I've got-- I've got some. We 16 Atlanta and met with the plaintiffs' lawyers, --
17 could look at the dates of when I got served that-- 17 A. Uh-huh (affirmative).
18 that document about what I was going to testify. 18 Q. --is that correct?
19 Q. How would we be able to tell from that 19 A. That's right. I was in the night before, but,
20 document when you were contacted? 20 yes, came -- we met yesterday.
21 A. Well, that-- that would give you at least one 21 Q. How long did you meet yesterday?
22 figure. I was contacted before then, I guess is what 22 A. 10:00 to about 3:30.
23 I'm saying. But I don't know that 1 can tell you in any 23 Q. And that's when you looked at the course pack
24 way when I first got the phone call. 24 materials for Narconon of Georgia?
25 Q. And who called you? 25 A. I took them home last night.
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1 Q. So it wasn't until last night that you looked
2 at the course pack material?
3 A. I started about 4:30.
4 Q. And how long did it take for you to go through
5 them?
6 A. Went up to-- I took a break for dinner, but
7 went up to about 11:00, and then fmished up one this
8
9
10
ll
12
1 3
morning.
Q. How much time did you spend this morning?
A. 20 minutes, half hour.
Q. And it was during the course of doing that
that you went onto the Internet to just double-check
that some of these were Scientology type principles?
A. Well, I knew they were. They're such basic
15 principles of Scientology that they're really everywhere
16 in the literature. I just got curious in tenns -- for
availability, to see if they were on the Internet, and
there they were.
14
1 7
18
19
20
21
Q. Before yesterday when you were --
A. Yes.
Q. --reviewing these materials, how much time
22 had you spent on this case?
Stephen Alan Kent
January 5, 2012
Page 27
1 two hours, because, again, I had to make the nip tvvice.
2 Going through the documents, the Chilocco,
3 Oklahoma, it's at least six hours.
4 Q. Okay. So approximately eight hours prior to
5 yesterday?
6 A. More like ten. At least.
7
8
Q. Did anybody else help you do any of this work?
A. I don't think so. 1 think I did all the
9 collections. I think I pulled all the documents myself,
10 as far as I can remember.
11 Q. Would that approximately ten hours also
12 include the time you spent talking on the telephone to
13 the plaintiffs' lawyers?
14 A. No. I didn't-- no, 1 didn't factor that in
15 at all.
1 6 Q. Have you provided them wi th any summa1y of
17 your opinions in writing, E-mails, anything like that?
18 A. No.
19 Q. Let me show you what's been marked as
22
20 Exhibit 4, which is the Jetter we received disclosing
21 the areas where you're going to offer expert opinion,
and ask you to look at that letter and tell me if that
is a fair statement of all of the areas that you're
going to offer expert opinions in in this case.
23 A. A-- well, I can't-- I haven't added up 23
24 hours, but I-- I spent enough time going -- collecting 24
2 5 materials from files, which would have been a couple of 2 5 A. " .. . provide testimony at nial outlining the
Page 26
1 hours. Getting -- going through those files and pulling
2 out the materials that I sent down. And that took a bit
3 longer, because I drove to FedEx and FedEx was closed
4 that day, so I had to go back a second day. It's the
5 holidays, and things are a bit screwed up. Then I spent
6 several nights going through the -- the Narconon
7 Chilocco booklets, and just to see, you know, to see
8 where that material came from.
9 Q. Okay. I'm just trying to find out the total
10 number of hours you've spent working on this--
11 A. Yeah. 1 have--
12 Q. --before yesterday.
13 A. I haven't even added them up, sir; I couldn't
14 tell you.
1 5 Q. Can you give me your best estimate?
16 Actually, don't write on the back of that.
Page 28
1 beliefs and practices of members ... Scientology"; if I
2 get asked, yes. Number 2, " ... the vast majority of
3 Narconon of Georgia's training materials and course
4 exercises are based prima1ily on the principles of the
5 Church of Scientology." Yes. " ... testify ... Narconon
6 International's corporate structure and explain how
7 Narconon International and Narconon of Georgia are
a connected to the Church of Scientology." I can't say
9 much about number 3, I can say, you know, a little.
10 But ...
ll
12
13
Q. Okay. And I' ll come back and ask you some
specific questions.
A. Sure.
14 Q. Is there anything else you're going to offer
1 5 an opinion on, that's not set out here in Exhibit 4?
16 A. I don't intend to.
1 7 I'll give you a blank piece of paper. 17 Q. Going back to your CV for just a minute, let
1 8 A. Okay, thanks. 18 me ask you a few questions about your background.
1 9 I'm going to -- again, this is from-- from 19 I'll tell you, before I do that, Dr. Kent, let
20 memory, but two in terms of collecting files-- 20 me ask you to look at Exhibit 5, which was an earlier
21 Q. And that would be the Exhibit 2 materials? 21 disclosure we got about your opinions. And I believe
22 A. More than that. And I had a large amount of 22 there's nothing in there that' s not consistent with what
23 material-- probably-- that I had to go through and 23 you have identified to us as your expert opinions that
24 weed out. And so the weeding out -- and I'll include 24 you're going to testify about in Exhibit No.2? Or,
2 5 that with sending. And this will be lowball, I'll say 25 excuse me, Exhibit No. 4? But I just want to make sure.
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1 A. Uh-huh (affirmative). Well, it's a bit 1
2 different. I hadn't planned to talk about student and 2
3 staff interactions, and that's mentioned in here. 3
4 Q. Okay. I just wanted to confirm-- 4
5 A. Sure. 5
6 Q. --you're not going to talk about student and 6
7 staff interactions -- 7
a A. Yeah. 8
9 Q. --in the Narconon of Georgia program. 9
10 A. Yeah. That-- you know, I'd rather stick to 10
11 the December 12th. And then "Narconon International's 11
12 oversight," as much as 1 can say, I'll say number 3 12
13 here, it's not a-- that's not a major focus of my -- of 13
14 my intentions. 14
15 Q. Maybe I can speed this up. Can we rely upon 15
16 what's in Exhibit 4 as -- 16
17 A. Oh, yes. 17
18 Q. --the complete universe of the opinions 18
19 you're going to give in this case? 19
20 A. Yes, sir. 20
21 Q. And to the extent Exhibit No.5 may have 21
22 anything in it that's not in Exhibit No.4, we can 22
23 ignore that? 23
24 A. Yes. 24
25 Q. Okay. Going back to your CV. It looks like 25
Page 30
1 you got your undergraduate degree at the University of 1
2 Maryland in sociology? 2
3 A. That's correct. 3
4 Q. And then it looks like you were out of school 4
5 for a couple years? 5
6 A. Two years. 6
7 Q. What did you do during that period of time? 7
8 A. Looked for jobs, worked as a cook, was a 8
9 counselor for handicapped. So I think those three 9
10 things. 10
11 Q. And then in 1975 you went back to graduate 11
12 school in religion? 12
13 A. That's right. I -- it was the department of I 13
14 think philosophy and religion, but my -- I was in the 14
15 religion side ofthe department. 15
16 Q. It looks like you've got two master's degrees 16
17 in r eligion, and then a Ph.D. in religion? 17
18 A. Yes, sir. Two master's is just bad planning 18
19 on my part, but it's true. 19
20 Q. Why two master's? 20
21 A. Changed schools, changed area of focus. 21
22 You'll notice the first M.A., the focus was "Histmy of 22
23 religions--Hinduism," and in order to go on to Hinduism 23
24 I would have had to do ex -- I'd studied Hindi for two 24
25 years, and I' d've had to go into San -- and study 25
Stephen Alan Kent
January 5, 2012
Page 31
Sanskrit. And I started it, but just wasn't-- not
enjoying it, so I changed from that program. And the
program had a-- I think it was a social sciences of
religion focus that I then shifted into, but I bad to do
a second M.A. So it was a different school.
Q. And so all of your graduate work and your
Ph.D., your doctorate, is in the area of religion?
A. Yes; but it's -- especially at McMaster, the
religion department at McMaster was in the social
sciences faculty. Some religious studies programs are
in humanities, and McMaster's was in social sciences.
So it was a Ph.D. in religion, but in the social
sciences. I remember, for example, I was a teaching
assistant for a sociologist. So -- so it was the social
sciences of religion program, if that helps clarify its
location.
Q. Okay. But your advanced degrees are in the
area of religion?
A. That's right, yeah.
Q. How did you support yourself from 1975 to
1983?
A. At first, at American University, I was a dorm
counselor. For I think three -- three long and arduous
and painful semesters. It was an awful job. And then I
got a job as a teaching assistant, for the final
Page 32
semester.
At McMaster, one of the reasons I went to
McMaster is it had good funding for graduate students.
It was one of the best-funded programs I think in North
America, and I happened to get into it. So there was
funding there, but it also involved us doing teaching
assistantships. And then at some point at McMaster I
sta1ted getting some student's fellowships and
scholarships and so on.
And I'm sure, you know, I -- I'm sure my
parents helped me out at various times.
Q. From 1983 on, how have you been employed?
A. I finished the dissertation -- I remember
interrupting people's Christmas parties to give them --
to try to give them my dissertation. Got in the car in
Ontario and then drove out to Edmonton, Alberta, so I
got there in January 1984, and I was a-- it's called a
postdoctoral fellow. It's -- it was a two-year
position, doctoral in -- the teclmical term was Izaak
Walton Killam postdoctoral fellow. And it's a--
postdocs, as they're called, usually go to recent Ph.D.s
who haven't gotten jobs yet but who have shown a lot of
promise in scholarship. And I'd published a fair amount
as a graduate student. So I was at University of
Alberta for two years as a postdoctoral fellow and then
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for one semester as a sessional instructor.
And after that I got a job--I don't think it
was-- it wasn't tenure stream, it was the dangling
carrot of possible tenure stream--back at -- oh,
University-- back at University of Waterloo. I was
there for one year. And while I was there, a position
7 opened up back at the University of Alberta which was
8 tenure stream, in sociology of religion. So when I went
9 from McMaster and Ph.D., I went into a sociology
Stephen Alan Kent
January 5, 2012
Page 35
1 affidavit or a deposition, you would have copies of
2 those?
3 A. I should.
4 Q. On Exhibit 1, could you check for us the legal
5 matters where you've offered some sort of opinion that
touched upon Scientology? 6
7
8
9
A. Sure.
Q. And just check on the exhibit for us, if you
would.
10 department as the Killam. And when I left the sociology 10
11 department in Alberta, I went to Waterloo, into a
sociology department, and during my year there a
position -- tenure stream position opened up back in 13
sociology at the University of Alberta, and I applied 14
and got the job. And it was a tenure stream job, and I 15
eventually got tenure, and I've remained there since. 16
12
13
14
1 5
16
11
12
A. Okay. In 1984, the Midtdal versus Midtdal
civil case in Edmonton, Alberta.
Q. Maybe you could give us the numbers.
A. Oh, that's the first one, in 1984, under
"Legal Consultations and Testimonies."
Q. Okay. Just tick off the ones that touched on
Scientology.
Q. And in addition to teaching at the university, 17 1 7
18 it sounds like you've also done some consulting work? 18
A. Okay. And then 1997, the Ken Montgomery
versus Allan Anthony Buttnor.
19 A. I've done some, yes. 19
20
21
Q. What percentage of your time would you say is 20
Q. And I'll tell you, Let's go back to Midtdal,
and--
spent consulting? 21 A. Midtdal?
A. Geez. I mean, it's a tiny amount. I've gone 22 22
23
24
25
for a couple years and done nothing. So it's just the 23
odd case. And the cases will take up ... When they 24
happen, they'll take up... I'd have to make a wild 25
Q. Yeah. And j ust tell us very briefly what the
nature of the issue --
A. Boy.
Q. -- was in the case.
Page 34
1 guess, but just a small amount of time.
2 Q. Have you listed all of the legal consulting or
3 legal type work you've done on Exhibit No. 1?
4 A. As far as I know, I have. 1 don't-- if I've
5 left anything out, it's certainly not been intentional.
6 Q. I don't see this case on your list.
7 A. Oh, no; I wouldn't -- I wouldn't have put it
8 on there.
9 Q. Okay. But other than this case, is there
10 anything else that you can think of where you've offered
11 opinions or testimony involving matters of legal
12 dispute, that's not on Exhibit 1?
13 A. As far as I know, sir, all the submissions I
14 made in legal matters are listed on here, except for
15 this case.
16 Q. And do you keep copies of all the submissions
1 7 that you've made?
18 A. I do.
1 9 Q. 1 know some of them are posted on your web
2 o site, 1 believe.
22 Q. But not all of them?
23 A. That's true. There arc some ... Well, some
24 there aren't even written reports for.
25 Q. But if there was a written report, or an
Page 36
1 A. That's a long time ago. As I can best recall
2 at this time, it was a custody dispute, if I'm not
3 mistaken. I know it involved children. So I'm saying
4 custody; it could have been visitation.
5 Q. Okay. How about Ken Montgomery?
6 A. Ken Montgomery was an Edmonton city pol ice
7 officer at that time, and Allan Anthony Buttnor was a
8 prominent local Scientologist. Background for that
9 case, Ken Montgomery worked in an intelligence unit in
10 the police, the Edmonton h1tegrated Intelligence Unit,
11 EIIU. He was city police, and there was an RCMP
12 partnered with him. They had -- Scientology thought the
1 3 intelligence unit was investigating Scientology. And so
14 Scientology called a meeting with the two police
15 officers. I wasn't at the meeting. I was working a lot
16 with the police at this time, so I wasn't at the meeting
1 7 but 1 was cettainly in touch with the cops. I think the
18 meeting didn't go terribly well. And then a few days
1 9 later, Mr. Buttnor -- well, a few days later, very short
20 time later, Mr. Buttnor got arrested in the city. And
21 initially he was charged with something involving child
22 interference. There was a person who had left the
2 3 group, and she had a number of kids and this is one of
24 her children, and Mr. Buttnor got charged.
25 Eventually-- and I'll spare you all the
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Stephen Alan Kent
January 5, 2012
Page 39
1 details about how the case unfolded, but eventually the
2 charges against Mr. Buttnor got dropped.
3
4
Q. Yeah. I--
1 Q. Okay. Well, I'm going to ask you-- would you
2 have any objection to me getting copies of these various
submissions? 3
A. And at some point-- at some point Mr. Buttnor
lay charges, probably-- involving-- something
involving harassment of some sort, against the two
7 police officers. And Ken Montgomery countersued. So
5
6
8 this was Ken Montgomery's countersuit against
Mr. Buttnor in this whole mess of a series of
allegations.
9
10
4
5
6
7
8
9
10
11
12
Q. Okay. What's the next thing that had anything 11
to do with Scientology? 12
13 A. This would be the 1998 "Bonnie Louis Woods 13
14 versus Sheila Chaleff, Graeme Wilson, Cathy Sproule, and 14
15 Church of Scientology Religious Education Inc." This -- 15
I didn't testify in this case; I submitted a witness 16
statement. I'd have to go back and check what's in it. 17
I believe it discussed some dimensions of fair game. 18
But I can't tell you anything else about what's in it.
16
17
18
19
20
19
I'm just not entirely clear, and I don't want to guess. 20
21 Q. Okay. What's the next thing? 21
2 2 A. 1998, "Religious Technology Center and Bridge 22
23 2 3 Publications versus Dennis Erlich." There were several
cases in this period, so 1998, there's a 1999 court
submission about "Scientology's perception of Dennis 25
24
25
24
Page 38
1 1
A. I don't have any objection. If--
Q. Well, I'm going to ask you, then, to, you
know, through your lawyer--
A. Yeah.
Q. -- to provide that to me. So I'm really
looking for just a brief nutshell --
A. Yeah.
Q. --on what the issue was.
A. Yeah, I mean, I don't mind. I don't know how
these processes work, because it doesn't -- none of
these have direct bearing upon this case. I didn't
consult any of them.
Q. I understand.
A. So, you know, ifl -- again, I don't know
how-- what the law is. A lot of them are on the
Internet; if I say --just ifl say no, what are the
consequences?
Q. Well, I would ask you what objection you would
have to me having them.
MS. FRANKLIN: l'd make an objection to
the question, but you can answer.
Page 40
BY MR. MILLER:
2
3
4
5
2 Q. Dr. Kent, is there any reason that you would
3 object to me seeing what you've said about Scientology
in the past? 4
5
Erlich as a 'suppressive person,' and its aggressive
actions against him,'' then there's 1999, "Bridge
Publications versus F.A.C.T.NET, Lawrence
Wallersheim ... " This was a period where a number of
Scientology critics--I think in most cases former
members--were putting Scientology documents on the
Internet. Some of the documents may have been upper
level, so-called secret documents, but some of the --
were just ordinary ones, and Scientology in various
cases sued for copytight violations and so on. Now, I 10
can't tell you exactly what I said in each one of these 11
cases. In part because they were so, in some ways,
6
7
8
9
10
11
12
13
14
15
16
similar. So I can't tell you exactly what the
6
7
8
9
12
13
submissions were. I know in one of the submissions I 14
think I had gone back through a lot of the early --
earliest Scientology publications, and found that there
15
16
A. Well, the only issue is 1 don't know-- it
doesn't have any bearing on this patticular case, as
near as I can tell; I didn't consult any of them. And
so I just am trying to make sure I don't have things
used against me that didn't have any bearing upon my
particular decision. That's the only reason.
Q. Okay. So, having articulated your reason, do
you have an objection to providing me with copies?
MS. FRANKLIN: The ...
17 were I think 19 or 20 or so early publications that had 17
18 been written by someone other than Mr. Hubbard. And 18
19 that Mr. Hubbard subsequently attached his name to. And 19
THE WITNESS: I think I'll check with
counsel and see what the best thing is. But,
again, you can get a lot of them tight off
the Internet.
Q. Okay.
A. The expert-- now, 1999, I don't-- I don't
20
21
22
23
24
25
1--
Q. But this was all in the context of copyright
infringement litigation?
A. I'll say yes, as long as we take that
copyright litigation broadly. 'Cause there was a lot
going on in this period.
20 have that one written down, and I'll tell you why. This
21 was a child visitation case in London, England. And
there were two experts, me and another person, I'll say
on -- I'll use this l anguage, but I'll clarify it in a
second. -- on one -- on one side, and Scientology had
22
23
24
25 gotten an expert on its side. But it became immediately
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Page 41
clear to us that the court said, "You can't take sides,"
that "The expert witnesses have to be on the side of the
best interests of the child." So the judge instructed
us to sit in a room and come up with an agreed-upon
5 statement. So we sat in a room for, I don't know, a
6 good day, maybe longer, and I thought we had hammered
out a pretty good statement. But none of us had-- this
is really before laptops, particularly. So none of us
had a computer, and I typed it up later, and the other
7
8
9
10 expert on, I'll say, my side signed it. The person who
11 was representing Scientology, although also representing
the interests of the child, then backed away from
signing it. So in essence our consultation fell apart.
So there's no written document for that one at all.
12
13
14
15
16
Q. Okay. Well, I also notice on here that you
say the ones that concern Scientology, for the most
part, but we'll run through the list quickly.
Stephen Alan Kent
January 5, 2012
Page 43
1 telephone. And this was also a -- if I'm not mistaken,
2 it was a divorce. And I think it was a custody case.
3 And Tom Padgett had left the group, and be was claiming,
4 among other things, he had been fair-gamed. And I'm not
5 sure what else I discussed in that. I'm pretty sure I
6 discussed issues about fair gan1e, which is a policy that
7 Scientology now denies exists but critics are insistent
8 that it continues, of-- of various kinds of harassments
9 against critics. So I'm pretty sure that was -- I
10 remembered something about Tom Padgett saying he had
11 some slogans sprayed on his garage door and so on. So I
12 think there was something about fair game in there.
13 Q. Okay. Up until this point in time, had you
14 been deposed in any of these other matters, other than
15 the Padgett case?
16 A. I'll look, but I don't think so.
17 Not in Midtdal versus Midtdal. Not in Ken 17
18
19
20
21
22
23
24
25
A. Sme. 18
Q. Are we up to "EEOC versus I-20 Animal Medical 19
Montgomery, as far as I can ... Not in Bonnie Woods.
Dennis Erlich, I don't think so. Certainly not in the
case in London in '99. Dennis Erlich, suppressant
person, don't think so. Bridge, no. EEOC, no; it
never -- it got settled out of court. Lisa McPherson,
wasn't deposed in that. So as far as I can recall here,
the Padgett one was the first instance.
1
2
3
4
Center"?
A. That's right. And that one I think is on the
net.
Q. What was the issue there, very briefly?
A. This was a case involving what's called the
World Institute of Scientology Enterprises. It's the
Page 42
application of Scientology practice management or
business management programs into work -- into the
workplace. And this was a veterinary hospital, if you
can call it, and the head -- the head veterinarian had
20
21
22
23
24
25
1
2
3
Q. Okay. How about Johnston versus Church of
Page44
Scientology?
A. This was a case in Ireland. And Mary Johnston
5 taken these practice management courses and was bringing
6 them into her workplace. And I can't remember how many
7 employees objected. They -- they were clainllng that
a Scientology was a religion, and it violated their
had been receiving Dianetics auditing. And she was
4 about to join the Sea Org when she had an interaction
5 with members of her family, and she suddenly decided not
6 to go in. And then made some critical comments about
7
8
9
Scientology publicly, ifi remember the scenario. And
after she made these critical comments, she claimed that
she was fair-gamed. That somebody was coming to her
workplace and -- and the other incidents I really can't
9 religious principles. And so they went to the EEOC, and
1 o the EEOC picked up that case. Now, that one is on the
11 Internet.
10
11 remember that she claimed had happened. So she launched
12 a lawsuit against Scientology, and I was a witness on
her behalf. I was on the witness stand for a long time,
but twice. I flew over there. And at the time I
believe I was associate chair graduate, so I was --
associate chair for graduate students in the sociology
depattment, so I had a reduced cour -- I think I had a
reduced course load. So I had some flexibility with
time, and I was -- I flew there once and they didn't
finish the deposition, so I had to fly back again. And
that case settled out of court.
12 Q. Okay. What's ilie next one?
13 A. "Estate of Lisa McPherson versus Church of 13
14
15
16
17
18
19
20
21
22
23
24
25
Scientology Flag Service Organization." l think that's 14
on the net too. I'm pretty sure that is. And this was 15
a -- geez, I'm not even sure what's in it. I think it 16
had a discussion, among other things, about what in 17
Scientology is called the "Introspection Rundown." It's 18
a program that L. Ron Hubbard developed, he said to 19
handle psychoses. As be defined it. But there are 20
other-- some other issues in there, and, again, I just 21
can't remember what's there. And I think that one's on 22
the net. 23
Q. How about Padgett versus Padgett? 24
A. Now, I was deposed in that case, but over the 25
Q. Were you deposed, or did you just testify in
some sort of court proceeding?
A. I just testified in a court proceeding. And,
to my recollection, there isn't a fmmal-- there isn't
1\lin-U-St:ript Q&A Reporting Services, Inc.
(11) Pages 41 - 44
Desmond, et al. v.
Narconon, et al.
Page 45
1 a formal court record of what happened.
2 Scientology -- if I'm not mistaken,
3 Scientology bad hired its own court rcpmter. But Mary
4 Johnston's had not hired anyone, so -- so the only
5 formal notes were the court reporter that Scientology
6 had hired. But, as far as 1 know, there is no
7 objective, neutral record of what the testimonies were
8 in that case.
9 Q. What's the next one?
10 A. Okay. Oh, the "Diana Kostelny ... conceming
11 Scientology and WISE." You know, I can't remember
12 anything in detail about what that case was. So I
13 just -- I can't help you there.
l4 2003, "Front Sight Management..."; he was a
15 gun instructor in Nevada, I think Las V cgas. And, if I
16 remember correctly, he had started using WISE in his
17 company, and there was --I'm not going to say-- I know
18 there was a big objection by one person who had been an
19 employee. And I think I submitted a statement on -- on
20 her behalf. I don't recall what happened to the case.
21 I think it settled out of court, but I'm not sure. As
22 far as I know, 1 was never deposed there.
23 The last one was 2000 ... I hesitate at 2010;
24 I'll have to check the date, 'cause it feels like it was
2 5 just 2011. So I want to check the year on that one.
Page 46
1 But I -- maybe time does fly that fast. But this was a
WISE case, and I was deposed in this case. This was a
case in Denver, and this was -- Nakishia Williams was
a -- I believe a dental hygienist, and her employ --
employer, Dr. Lowery, started using practice --
Scientology-based practice management programs in the
business. And Nakishia objected on several grounds.
And, you know, got -- it was a civil case that settled
out of court. But I was deposed for a few hours in that
case.
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Q. Okay. Any other Scientology-related matters
on here?
A. I don't think so.
Q. I think we established earlier, none of these
involve Narconon or Narconon Intemational; --
A. None.
Q. -- is that--
A. No, sir.
Q. -- conect? And I counted 22 matters; I guess
if we count this one it would be 23.
A. 22, and this would be 23.
Q. Right. And of those, if we include this one,
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Stephen Alan Kent
January 5, 2012
Page47
eight, nine, ten, 11, 12, 13, 14, 15; this would be 16?
Is that conect?
Q. I'll take your count, 16 of the 23. And on
all of those occasions, Dr. Kent, I assume that you have
testified in opposition to something having to do with
Scientology?
A. I've always been on -- I've never testified on
behalf of Scientology. Scientology's never contacted me
to testify, so ...
Q. And you've always been critical of Scientology
in some regard with respect to these legal matters?
A. Critical about some aspect of Scientology's
behavior, yeah.
Q. Let me ask you about that. Would it be fair
for me to assume that you're not going to offer
criticism of Scientology as a religious belief system?
A. That's not my intention here, no, sir. You
know ...
Q. But my understanding is that in these cases
that you've identified, there was some specific practice
or set of practices that you were critical of?
A. Certainly in the ones I can think of of fhand.
Again, with the understanding that I can't remember
clearly what I said in some of these cases, it would be
the case that I'd be clitical of some aspects of
Page48
Scientology behavior.
Q. Right. And that's what I'm getting at, just
broadly speaking; you're not going to be critical of
anyone's religious beliefs, it would just be if there
was some practice or behavior that you found
objectionable?
A. In this case I'm not even talking about being
critical of people's r eligious beliefs. My attitude
9 about religion is that people can believe whatever they
10 want. Religion only becomes an issue if practices
ll associated with religion are arguably hannful. But in
12 terms of belief, what goes on in a person's head, that's
13 entirely up to the individual. It's always behavior
14 that becomes crucial.
15 Q. Right. And so if there was ham1ful behavior,
1 6 you would be critical of it?
A. I would be critical of harmful behavior. 17
18 Q. Based on your CV and what you've told us, my
19 understanding is that you don't have any background or
20 experience with regard to drug and alcohol addiction
21 programs?
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15 of the 23 times you' ve consulted on any type of a 2 3
legal matter it's been with regard to Scientology? 24
A. That' s true; I have no experience in drug or
alcohol addiction programs.
Q. And you--
A. One, two, three, four, fi ve, six, seven, 25 A. So I have no plans to make any comments about
(12) Pages 45 - 48
Desmond, et al. v.
N arconon, et al.
1 them.
2 Q. You're not going to have any opinions
Page 49
3 whatsoever with regard to how effective or not effective
4 the Narconon drug and alcohol treatment program is?
5 A. I have no intention of making any -- offering
6 any opinions about how effective the Narconon program is
7 or may be.
8 Q. And you also do not appear to have any
9 background as a medical doctor or a psychiatrist or a
10 psychologist?
1
Stephen Alan Kent
Januaty 5, 2012
Page 51
effective than any other kinds of programs.
Q. And so if people come in and testify in this
case that they've gone tluough the Narconon course and
it's gotten them off a drug or it's gotten them off of
5 alcohol dependency, you would have no reason to dispute
that?
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3
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7
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A. I wouldn't have an opinion on it.
Q. Have you finished your work in the case? Is
there anything else that you plan to do?
A. I don't -- let me think. I think I've done --
11 A. That's true; I'm not a medical-- on one of 11 as far as I know, I've done everything that -- that I
12 the initial fonns I got identified as an M.D. But it 12 plan to, other than remember the name of that one book
13 looks like it's got conected. No, I'm not an M.D., I'm 13 I'm forgetting. You know, 1--1 think I've done all
14 not a psych -- I'm not a psychologist. 14 that I need to.
15 Q. Okay. And, again, I just want to try to make 15 Q. The reason I'm asking, of course, is because
16 sure we're clear on this. You're not going to offer any 16 we want to know what you might testify to in the trial
17 opinions in this case about what Dr. Robbins may or may 17 of the case, so if there was something else --
18 not have done as a medical doctor; is that conect? 18 A. Yeah, if there was something else.
19 A. No, I have no-- I have no intention of making 19 Q. --you were planning to do or that you've
2 o any comments about anything Dr. Robbins may or may not
have done. 21
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Q. And you're not going to offer any opinions
about whether sauna programs are healthful or not
healthful for people?
A. I'm going to stay away from-- I intend to
Page 50
stay away from any discussions about, say, physiology,
which I would include in the sauna.
Q. And same with the vitamin therapy?
A. That's true.
Q. Okay. So, in other words --
(Discussion off the record.)
(Recess at 11:16, resumed at 11:17.)
BY MR. MILLER:
Q. Dr. Kent, I appreciate you clarifying the
areas you are not going to give opinions. But in
addition to not planning to give opinions in those areas
we've just discussed, it sounds like you would not feel
that you would be qualified as an expert to give
opinions in those areas.
A. No; I'm not-- anything involving medicine I
don't feel qualified to talk about. So physiology or
drug rehab benefits or whatnot, that's just -- they're
not my area of training, so ...
Q. Okay. And I think I know the answer to this,
but you're not going to offer any opinions about whether
the Narconon program is more or less effective than any
other type of drug and alcohol addiction --
A. I'm not going to offer any opinions --
Q. --program?
A. --as to whether Narconon is more or less
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suggested be done, we need to know that. But what [
understand your answer to be is that you've done
everything that you can think you need to do, and that
you haven't asked to do anything additional?
A. As far as I know, that's true. I don't have
any plans. I've got -- I've been putting off preparing
Page 52
my courses for next semester, so that's what I'm going
to do next.
Q. And let's go to Exhibit 4 for a minute, which
is the statements about the opinions --
Q. --that you anticipate giving in this case.
And I'm going to ask you quite a few questions about
numbers 1 and 2, since you indicate those are areas
where you're going to give opinions?
A. Yes.
Q. Okay. But you indicated that there would be
something very limited that you might say about
number 3, and I thought I would just start there and try
to find out what, if anything, you're going to say
about--
A. Yeah.
Q. -- Narconon International's corporate
structure, and how Narconon International and Narconon
of Georgia are connected to the Church of Scientology.
A. Okay. That's fair enough, and that's fairly
short. Narconon uses materials written by L. Ron
Hubbard. And in order to -- and as part of the right to
use that materials, Narconon pays I believe it's a ten
percent fee back into... 1'11 say the Scientology
organization, for this right.
'fin-U-Script@ Q&A Reporting Services, Inc.
(13) Pages 49 - 52
Desmond, et al. v.
Narconon, et al.
Page 53
Now, I'm not clear whether the ten percent fee
goes to a Narconon regional organization, whether it
3 goes to Narconon national , or whether it goes to
1
2
4 Narconon International, or whether it goes into ABLE,
Association for Better Living and Education. So I'm
not-- so I know that there's money that goes out of
Narconon, but I don't quite know where it goes and how
it gets into the larger Scientology organization. And
then I also don't know what happens to it once it gets
5
6
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8
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10 into Scientology.
Stephen Alan Kent
January 5, 2012
Page 55
1 percent is paid for?
2 A. My understanding is -- I call it a licensing
3 fee. It's a fee for use ofL. Ron Hubbard's materials.
4 As I understand it.
5 Q. Okay. But in tetms of the interaction between
6 Narconon International and Narconon of Georgia, you
don't have any information about that? 7
8
9
A. No, sir.
Q. And you're not going to offer any opinions
about that?
11
12
13
14
15
10
11 I tried at some length to determine who the
current leader, president ofNarconon International, is. 12
I'm not even-- I had a great trouble even determining 13
that. It looked like it's a gentleman named Clark Carr, 14
A. No, sir, I'm not.
Q. And are you going to offer any opinions about
interactions between Narconon International and any
other organization that you would associate with the
Church of Scientology?
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C-A-R-R, but I'm not even sure of that. 15
So beyond those very general comments, there's 16
not a whole lot I can say of any substance.
Q. Okay.
A. And I defer to other people for their insights
on this one.
Q. And you're not a lawyer or a legal expert, as
I understand it?
A. No, I'm not.
Q. And you're not an expert on regulations and
licensing and types of things like that?
Page 54
A. I'm not an expe1t --
Q. And I--
A. -- in licensing or anything like that, no.
Q. Okay. And so in terms of how a drug and
alcohol program might be licensed or regulated, you're
not going to offer any opinions about that?
A. I have no opinions on that, no.
Q. And same with any sort of housing that might
be associated with the program?
A. No opinion on housing issues.
Q. Okay. Or how housing should be run, or how
people should be supervised, or anything like that?
A. No, that's all-- you know, l wasn't asked to
comment on the daily runnings of the program, and, you
know, I'm not going to.
Q. As far as nwnber 3 is concerned, then, it
sounds like -- I'm going to try to summarize but be
fair; is that you believe that Narconon of Georgia pays
a ten percent licensing type fee that goes to somebody,
and you're not sure where it goes, and whoever it goes
to, you're not sure where it might go, if anyplace,
after that ?
A. That's correct.
Q. And is it your understanding it is a licensing
fee, or do you have an understanding of what that ten
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A. Beyond what I've said already, I'm not going
to make any comments about relationships between
Narconon International and Scientology.
Q. And your understanding is Narconon
lntemational is a nonprofit organization?
A. Well, in the documents I submitted, there are
certain-- in one of the initial submissions to the IRS,
ifl remember correctly, that Narconon said that it was
a tax-- I believe it said it was a tax-exempt
organization. Before -- this is befor e the IRS ruling.
Page 56
Q. Maybe I can approach it this way.
A. Okay.
Q. I will tell you that my understanding is that
Narconon International is a nonprofit organization. Do
you have any reason to believe that that's not true, as
we sit here today?
A. I would want to look at, again, very
carefully, the IRS decision. Because it looks to me
like Narconon International-- it was one ofl think it
was 136 Scientology satellite organizations, ancillary
organizations, that received charitable status. Through
the IRS decision. That's my understanding now. But I
do remember that Narconon had claimed that it was a
tax-exempt prior to that IRS decision. So however the
IRS decision -- we'd have to look at that -- that
carefully. But... And we'd have to fmd it-- see, I
think this -- all right, let me see.
It might take a few minutes for us -- and feel
free to help me on this. The mentions ofNarconon in
the IRS decision. That's my only concern with agreeing
with your statement, is that it's -- I've got a certain
level of ambiguity about the impact of this IRS decision
upon Narconon.
Q. My recollection, Dr. Kent, was that Narconon
International is not in that list of organizations
1\1 in-U-St:ript Q&A Reporting Services, Inc.
(14) Pages 53 - 56
Desmond, et at. v.
Narconon, et al.
Page 57
1 that's in the IRS, and so... But 1 think we both need
2 to look at the document.
3 A. Yeah, 1...
4 MR. MILLER: Swap with me. You have my
5 copy where I've got them stapled separately.
6 MS. FRANKLIN: Yeah. I've got a copy of
7 his file, but it's not Bates numbered, and
8 you're going to --
9 MR. MILLER: Yeah, I've got one that's
10 Bates numbered. And I'm--
11 THE WITNESS: Yeah, it looks like this
12 is --
13 MS. FRANKLIN: That's fme. That's
14 fine.
15 THE WITNESS: It is -- A Narconon is ...
16 MR. MILLER: Would you mark this as the
17 next.
18 THE WITNESS: Tbjs could take us a few
19 minutes to find, but I agree with -- well,
20 it's an important point; now, whether we want
21 to spend time here sitting ... Association
22 for Better Living and Education, ABLE, is
23 here. It's on Page Bates 870.
24 (Thereupon, marked for identification
25 purposes, Defendants' Exhibit No.7.)
Page 58
1 THE WITNESS: I don't think it's back
2 beyond that.
3 Page Bates 885, number 4. "The social
4 benefit and other public benefit entities
5 di scussed at pages 1-28 through 1-42 of the
6 June submission along with the subsidiaries,
7 subordinate chapters, subordinate
8 organizations, or sublicenses thereof, e.g.,
9 organizations that are permitted to use
10 particular names, copyrights, service marks,
11 and/or technologies, are Scientology-relatcd
12 entities. Thus, for example, Citizens
13 Commission on Human Rights, National
14 Commission on Law Enforcement and Social
15 Justice, Scientology Defense Fund Trust,
16 Association for Better Living and Education,
17 Applied Scholastics Incorporated, Narconon
18 International, The Way to Happiness
19 Foundation, and the Foundation for Religious
20 Freedom are Scientology-related entities."
21 Attach-- " ... entities Pages 1-28 through
22 1-42 are attached as exhibit Roman numeral
23 V ill-2 to this agreement." So it is
24 mentioned in here.
25 BY MR. MILLER:
Stephen Alan Kent
January 5, 2012
Page 59
1 Q. Well, maybe l can get to it this way. First
2 of all, I've marked the document you're looking at I
3 believe as Exhibit 7 --
4 A. Okay.
5 Q. --to your deposition?
6 MS. FRANKLIN: That's just--
7 THE WITNESS: Just the IRS --
8 MS. FRANKLIN: -- 838 through --
9 BY MR. MILLER:
10 Q. And, Dr. Kent, as I understand it, this is an
11 agreement by the United States government in 1993 that
12 found that the -- well, I want to be careful about the
13 date, but this was an agreement that resolved some
14 disputes with some of the Scientology entities and the
15 Internal Revenue Service about whether or not the Church
16 of Scientology would be tax-exempt?
17 A. That's true. l'd say -- I'd go a bit further;
18 I'd say it settled all disputes. This was a blanket
19 settlement.
20 Q. And the upshot of this was that at least
21 sometime in the 1990s there was an agreement by the
22 government that these entities were all tax-exempt?
23 A. There was an agreement by the IRS. It
24 wasn't-- there had been an earlier court decision that
2 5 was -- that was different, but this is an IRS agreement.
Page 60
1 Q. I'm treating the Internal Revenue Service as
2 part of the United States government.
3 A. Sure. Sure. But the United States government
4 is multifaceted. And so the court system was not party
5 to this particular decision.
6 Q. Okay. Well, as far as the United States
7 government is concerned for tax purposes, all the
8 Scientology organizations are considered to be
9 tax-exempt?
10 A. That's my -- 1 wouldn't say all ofthem. So,
11 for example, there's no mention in the IRS decision of
12 the Scientology Rehabilitation Project Force program.
13 And this is an -- well, I've called it an internal
14 reeducation -- well, reindocttination, reeducation,
15 penal system. That's not mentioned anywhere in here.
16 So I wouldn't say that all Scientology organizations,
1 7 and there may be some others. But certainly I believe,
18 as I said earlier, I think it covered 136
19 Scientology-related organizations.
20 Q. Okay. What was the page you were looking at
21 earlier? Never mind, I found it.
22 A. Okay.
23 Q. But going back to my original question; --
24 A. Uh-huh (affitmative).
25 Q. -- do you have any reason to think that
(15) Pages 57 - 60
Desmond, et al. v.
Narconon, et al.
Page 61
1 Narconon International is not a nonprofit organization?
2 A. It's -- I'm unclear as to whether it's a
3 nonprofit or-- or a charity. So ...
4 Q. What's the distinction that you're drawing
5 there?
6 A. I think it might have to do with paying a
7 pmticular kind of taxes. Again, I'm not a -- so it's
8 either one or the other.
9 Q. Well, I'm not ruling out that it's a
10 charitable nonprofit; --
ll A. Yeah.
12 Q. -- in fact, I believe it is a charitable
13 nonprofit.
14 A. Okay.
15 Q. You would have no reason to disagree with
16 that, would you?
17 A. Not necessarily, no.
18 Q. And same with Narconon of Georgia; if there's
19 evidence that that's a charitable nonprofit
20 organization, would you have any reason to disagree with
21 that?
22 A. Wouldn't surprise me. Let's put it that way.
23 Q. Okay. I just want to make sure that you're
24 not going to offer some opinion that Narconon of Georgia
25 or Narconon International are not charitable nonprofit
Page 62
1 organizations.
2 A. I don't intend to.
3 Q. And this IRS agreement that we've marked as
4 Exhibit 7, this had to do with a dispute about the
5 religious status of some of these organizations, as I
6 understand it?
7 A. In various -- this is -- the final IRS
8 agreement is secret. So both Scientology and the IRS
9 have not released the fmal agreement. This was, as
10 near as 1 can -- near as I recall, the -- the
11 next-to-last agreement, that the Wall Street Journal got
12 ahold of and released. And then it's been reproduced in
13 various web sites. So there could be differences in the
14 final agreement. I think there is even a tax case that
15 demanded the IRS release the agreement, and it -- it
16 refused to do so. So there conceivably could be some
17 differences in the final agreement. I don't think there
18 are. I'd be very surprised.
19 Q. But in terms of those negotiations, the
20 drafting of these agreements, that type of thing, you
21 don't have any personal knowledge about that, do you?
22 A. I was not involved in any of it, so ...
23 Q. And you're not a tax expert or anything like
24 that?
25 A. Oh, l'm far from a tax expert.
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Q.
Stephen Alan Kent
January 5, 2012
Page 63
Okay. So going back to Narconon
lntemational, it sounds like you don't have any
opinions that you're going to offer in tenus of how
Narconon International with any other
organization that you would consider to be a
Scientology-related organization?
A. No, sir, I have no plans to talk about how
Narconon lntemational interacts with any other Narconon
organizations.
Q. And 1 think you already answered this, but
you're not going to talk about how Narconon
International may interact with Narconon of Georgia?
Other--
A. I'm not going to talk about interactions
between Narconon International and Narconon of Georgia.
Q. And I think I know the answer to this,
Dr. Kent, but let me just make sure; have you spoken to
anybody who has ever gone through a Narconon program?
A. I have, actually.
Q. Who is that?
A. I understand why you ask the question, but
according to the university ethics that I have to
follow, we have to guarantee anonymity and
confidentiality of our sources. So by the requirements
that I have to follow for research, unless the person's
Page 64
given me permission to use his or her name, 1 can't.
Q. Well, are you going to rely upon any
infonnation --
A. No.
Q. -- that you were provided?
A. No, sir, I'm not going to rely upon anything
anybody's told me.
Q. About going through the Narconon program, or
what the Narconon program is like, or anything like
that?
A. I'm not going to rely on any of that, no, sir.
Q. Or recount or offer that information at trial?
A. No, sir, I'm not going to recount anything
from any-- any account.
Q. Would your billing records indicate when you
were first contacted about this matter?
A. Oh, I doubt it.
Q. What sort ofbilling records do you keep?
A. When I start reading, I scribble down the
time, and when I stop, I scribble down the time.
Q. Would those scribbles also have a date?
A. They'd have a date, yeah.
Q. So wouldn't that tell us when you first were
contacted, or at least when you first did some work on
it that you were going to bill for?
Nlin-U-Script Q&A Reporting Services, Inc.
(16) Pages 61 - 64
Desmond, et al. v.
Narconon, et al.
Page65
1 A. Yeah, they would. It's just that I don't --
2 with phone calls, I -- I'm an academic, I talk to people
3 all the time for free. And so when I talk to lawyers, I
4 almost never bill them. It's just part of what I do as
5 a researcher. It's very different organization behavior
6 for lawyers, and you can understand why.
7 Q. Well, ifl understand what you're saying,
8 though, is that when Jeff Harris called you up on the
9 phone, you would not have made a note on that for
10 billing purposes?
11 A. That's very true.
12 Q. But when somebody decided to hire you, and you
13 started, for example, pulling these materials out of
14 your files, --
15 A. Yeah.
16 Q. -- then you would make a notation of the date
17 that you started to pull those materials out and some
18 record of the time you spent?
19 A. That's true.
20 Q. Is that piece of paper still in existence?
21 A. The -- it would be back in Edmonton.
2:;1 Q. Okay. Can we have an agreement that you will
23 provide that to Rebecca, and --
24 A. Oh, yeah; I've got to provide that at some
25 point. Sure.
Page 66
1 Q. Have you billed them anything to date?
2 A. Nothing.
3 MS. FRANKLIN: I can't agree that he's
4 going to provide that to me. If he does,
5 I'll provide it to you.
6 BY MR. MILLER:
7 Q. Well, so you'll provide her with the record of
8 when you first started doing work?
9 A. Yes, sir.
10 Q. And then she'll provide that to us; --
11 A. Yes, sir.
12 Q. -- is that fair?
13 The course pack that you looked at last
14 night --
15 A. Yes, sir.
16 Q. -- from the Narconon of Georgia course, was
1 7 there anything in that course pack that you're going to
18 offer the opinion was harmful to the students going
19 through the Narconon of Georgia program?
20 A. I'm not -- I don't plan to get into i ssues
21 about hatm or potential hann. Again, because those
22 issues primarily would be medical. But even if they
23 would be social, they're not what I was, you might say,
24 contracted to talk about. So I have no plans to do
25 anything like that.
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Stephen Alan Kent
January 5, 2012
Page 67
So whether they were helpful, harmful , you're
just not going to offer any opinion about that one way
or the other?
A. That's correct.
Q. And the same with regard to any of the course
pack materials that you've reviewed from Oklahoma;
you're not going to offer any opinions about whether
those are helpful or hannful?
A. No; and they don' t-- they're not this case
anyway, but same-- same thing.
Q. And, again, I'm not trying to beat a dead
horse, --
A. Uh-huh (affinnative).
Q. -- but my understanding of what you're telling
me is that you're not going to come into court in this
case and say that there was something that was going on
in this course pack of materials from Narconon of
Georgia that you consider to be harmful to any of the
students like Patrick Desmond?
A. That's not my hired intention, so I plan to
stay away from any of those areas.
MR. MILLER: Why don't we go ahead and
take a short break, Rebecca?
MS. FRANKLIN: That' s fine.
MR. MILLER: I think Barbara is going to
Page 68
have to leave here in a minute.
(Recess at ll:41, resumed at 11:58.)
(Thereupon, Ms. Marschalk is not present
in the deposition room.)
BY MR. MILLER:
Q. Dr. Kent, let me go back and clean up j ust a
couple things.
I think you've already testifi ed that you're
not relying upon any of the documents or depositions
that we've identified in this Exhibit 3?
A. That's conect.
Q. But you had also mentioned that you might have
glanced at some portion of something in there, a
deposition or something, --
A. Uh-huh (affmnative).
Q. --but I take it you're not relying upon
anything you may have, you know, read in the
depositions?
A. I'm not relying upon anything in the
depositions. I figured in terms of what I was asked to
do, outlining the beliefs and practices of Scientology
and also any connection between course materials of
Narconon and Scientology, it didn't matter what any of
these testimony -- any of these depositions may have
said.
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(17) Pages 65 - 68
Desmond, et al. v.
Narconon, et al.
Page 69
1 Q. Okay.
2 A. So I'm just not getting anywhere near them.
3 Q. And in terms of what the events may have been
4 on the day that Patrick Desmond died, you're not going
5 to offer any opinions about what happened that night,
6 are you?
7 A. No, sir.
8 Q. And you're not going to offer any opinions
9 about the cause of his death, are you?
10 A. No, sir.
11 Q. You're not going to offer any opinions
12 critical of the defendant Delgado in this case?
13 A. No, sir.
14 Q. Or, specifically, you're not going to offer
15 any opinions critical ofNarconon of Georgia or Narconon
16 International, as I understand it?
17 A. I don't see it as my obligation here.
18 Q. Okay.
19 A. So I don't intend to.
20 Q. And basically it's going to be 1 and 2 on
21 Exhibit 4, will be the limit of your opinions in this
22 case?
23 A. That's true.
24 Q. And those opinions are based, as I understand
25 it, on your general familiarity with Scientology and
Page 70
1 with documents that you have pulled to refer to in
2 Exhibit No.2, and your review of the course pack
3 materials?
4 A. That's correct.
5 Q. And the ten percent number, is that just
6 something that you've heard from somebody?
7 A. Oh, I'm -- no, I'm sure I read it in some
8 materials over the years. I mean, I've been studying
9 Scientology and other groups for at least a quarter of a
10 century. And it's a fairly standard practice in
11 Scientology for these satellite groups to pay a
12 percentage back to the organization. So that's fairly
13 standard procedure.
14 Q. Is it fairly standard, though, in lots of
15 organizations to have people pay some sort oflicensing
16 or royalty fee if they're using copyrighted or
17 trademarked materials?
18 A. I can't say.
19 Q. So whether this is the same or different than
20 practices in groups like Alcoholics Anonymous or the Boy
21 Scouts or anything, you just don't know?
22 A. I'm not an organizational sociologist, so I
23 can't say.
24 Q. I think you've told us this already, but am I
25 conect that you don't have any notes whatsoever on any
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Stephen Alan Kent
January 5, 2012
Page 71
of the subjects that we're talking about today?
A. No.
Q. Did you review Exhibit 4 before it was sent to
the lawyers in this case? That's the letter that
outlines your opinions.
A. I got I think a draft of it, but I hadn't seen
the actual letter until I got here.
Q. Okay. But as far as Exhibit No. 4 is
concerned, as far as your opinions are concerned, they
did run this language by you for opinions 1 and 2?
A. I believe so. I do recall getting a draft and
approving the draft.
Q. And let me work kind of up backwards on this
list, as we've done already. We talked about 3 already
on your list, and I think you've told me all the
opinions you have connected to number 3 --
A. Uh-huh (affim1ative).
Q. -- on Exhibit 4. Let's talk about your
opinion number 2 on Exhibit No. 4. And that opinion is
that " ... the vast majority ofNarconon of Georgia's
training materials and course exercises are based
primarily on the principles of the Church of
Scientology"?
A. Yes.
Q. And the "training materials and course
Page 72
exercises"; are you referring to the course pack that
you looked at?
A. Really referring to all of the books that I
looked at.
So let's put it this way; I didn't see
anything, any-- any of the major concepts, even any of
the minor concepts, in any of the books I looked at that
did not come from Scientology.
There was one term I wasn't familiar with, I
think it was called "Checkout." But everything else has
a direct Scientology connection.
MR. MILLER: Mark this as the next
exhibit.
purposes, Defendants' Exhibit No. 8.)
BY MR. MILLER:
Q. Let me show you what's been marked as
Defendants' Exhibit 8.
A. Uh-huh (affirmative). Okay. Good. Good.
Q. I'll represent to you that I believe this is
the front cover of the books that have been produced in
this case as the books used in what I think you would
describe as the course pack for Narconon of Georgia,
Inc.?
A. That's right.
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(18) Pages 69 - 72
Desmond, et af. v.
N arconon, et al.
Page 73
1 Q. And does this look like the books that you've
2 looked at in terms of reaching your opinion number 2?
3 A. Yes. That's the one I forgot. "Changing
4 Conditions in Life Course." That's the one I couldn't
5 remember.
6 Q. Okay.
7 A. Now, I don't-- the attomeys here didn't have
8 a copy of the book number 2, the detoxification program,
9 but I looked-- well, for years I've been, you know,
10 familiar with the "Clear Body, Clear Mind" material.
11 And I think they were also missing 4b, the
12 "Communication & Perception Course"; that would have
13 been the -- I believe that's primarily objectives. And
14 I have seen that, the earlier version, the 1991 version;
15 I just haven't seen the 2004 version.
16 Q. Okay. So you did not look at the course book
17 number 2, "New Life Detoxification Program," or 4b?
18 A. If-- in terms of the 2004 documents, no, I
19 haven't seen those.
20 MR. MILLER: Rebecca, I'll just tell
21 you, my understanding is we've produced
22 those, so ifthere's any question in your
23 mind whether we produced those to you or
24 not--
25 MS. FRANKLIN: Produced the entire set
Page 74
1 of books?
2 MR. MILLER: I believe so.
3 MS. FRANKLIN: Okay. We've got the set
4 here without those two. I thought we
5 produced them to you all. But--
6 MR. MILLER: You may have. You may
7 have.
8 MS. FRANKLIN: Okay. I mean, he's
9 looked at an older version, so ...
10 MR. MILLER: I just didn't want there to
11 be any misunderstanding that we hadn't
12 produced these to you.
13 MS. FRANKLlN: Okay.
14 THE WITNESS: Uh-huh (affinnative).
15 MR. MILLER: But what he looked at--
16 BY MR. MILLER:
17 Q. Did the books you looked at look like they
18 were used books, that somebody had initialed and written
19 in?
20 A. Oh, yes. Yes. The ones last night for sure.
21 Q. And these looked like books that Patrick
22 Desmond had read through?
23 A. I don't know that he had read through them.
24 I'm not -- I don't know whose books they were. I don't
25 think they were his.
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Stephen Alan Kent
January 5, 2012
Page 75
MS. FRANKLIN: Just for clarification,
they were Nick Parsons' books, who has been
deposed in this case.
MR. MILLER: Okay.
MS. FRANKLIN: 1 think they were used
during his deposition.
BY MR. MILLER:
Q. Dr. Kent, we were provided with a chart of
some lawsuits involving Narconon.
A. That's right, yes.
Q. And my understanding is that was a chmt that
was prepared by the plaintiffs' counsel?
A. It's my understanding.
Q. That's not a document you prepared or --
A. Oh, no. No, no, no.
Q. Do you have any personal knowledge of any of
those lawsuits?
A. I haven't been involved in any of them.
Q. So that's one question. You haven't been
involved in any of them. But do you have any personal
knowledge? You know, know any of the people involved,
do any investigation in any of them, anything like that?
A. I've -- the university has documents on some
of the cases. I've not worked with any of the documents
extensively; I've certainly looked through them over the
Page 76
years. On some of them.
Q. Well, my question is, are you going to rely
upon any of these lawsuits in reaching any of your
opinions?
A. Oh, no, sir; not at all.
Q. And are you going to come to court and testify
about any knowledge that you have about any of these
lawsuits?
A. No, sir; it's not my intention at all.
Q. And so it's just a document that was provided
to you, but it's not a document you're going to use,
rely upon or testify about?
A. That's correct.
Q. Or the subject matter of the document?
A. That's coiTect.
Q. You're not going to come to court and testify,
"Well, Narconon has been sued" in some other place for
doing something?
A. That's not my intention.
Q. Okay.
A. And you see that -- that list had lawsuits,
but I've no idea about the fmal history of what
happened, whether they got settled out of court, whether
there was a ... You know, it's one thing to sue, it's
another thing to have a court settlement. And I just
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(19) Pages 73 - 76
Desmond, et al. v.
Narconon, et al.
Page 77
Stephen Alan Kent
January 5, 2012
Page 79
1 can't tell fi-om that list how the cases got resolved. 1 A. As far as I can recall, and I was looking for
2 Q. And some of them are things like Wikipedia 2 any mentions of, for example, the term Thetan,
3 entries or newspaper articles, that type of thing? 3 T-H-E-T-A-N. I don't recall seeing any mention of
4 A. Yeah. You've got to be careful about 4 something like that in the -- in the course packs.
5 Wikipedia. 5 Q. So as far as you can tell from the review
6 Q. And the document we're talking about has been 6 you've done to date, it looks like the materials in this
7 marked to your deposition as Exhibit 6; is that correct? 7 course pack, while they embrace principles that would
8 A. This looks -- this looks right. I think the 8 come from L. Ron Hubbard and principles that are used in
9 one I have has some color-- color things on it, but 9 the Church of Scientology, these are not religious
10 this looks right. 10 documents, as far as you can tell?
11 Q. Okay. I think maybe some of the shading 11 A. I didn't see any reference to a supernatural
12 didn't come out-- 12 element--
13 A. Sure. 13 Q. Right.
14 Q. --on the printer. Okay. So that's just not 14 A. --in any of them, as far as I can recall.
15 anything we need to talk about;-- 15 Q. Okay. So would it be fair to characterize
16 A. No. 16 this as a secular program based on L. Ron Hubbard's
17 Q. --is that correct? 17 principles?
18 A. That's correct. We do not have to talk about 18 A. I'd say a secular program based upon L. Ron
19 that. 19 Hubbard's principles that the IRS has deemed to be
20 (Discussion off the record.) 20 charitable based upon religious claims.
21 BY MR. MILLER: 21 Q. Well, let's take the IRS out of it. Let's
22 Q. And based upon the books that you've looked at 22 just talk about Dr. Kent's opinions here.
23 that are similar to what's in Exhibit 8, there are 23 A. Okay.
24 concepts in there that would be similar to concepts that 24 Q. From what you're telling me, it sounds like
2 5 you would understand the Church of Scientology might 2 5 there's nothing in these course pack materials that you
Page 78 Page 80
1 use? 1 would characterize as religious under the definition
2 A. Yes, sir. And I'd probably be a bit stronger. 2 you've given us?
3 That in many cases the botTowings are direct. 3 A. There's nothing involving the supernatural.
4 Q. And the Church of Scientology, as I understand 4 Q. And so would it be fair, under your opinion,
5 it, in your opinion, is a mixture of religious 5 to say that this is a set of secular materials that are
6 organizations and secular organizations? 6 based on L. Ron Hubbard's principles?
7 A. What I've said in academic circles, willch 7 A. Again, I -- I always come back to the IRS
8 might be what you're referring to, is that Scientology 8 decision. That it-- it provides a context, I think, in
9 is a multifaceted transnational organization, only part 9 the American legal system. And if organizations -- for
10 or parts of willch are religious. That in addition there 10 example, The Way to Happiness International has
11 are a number of secular-related activities. 11 charitable status under tills blanket IRS decision. And
12 It's difficult, however, in the legal setting 12 there's a course pack, the number 7 course pack, that
13 in America to make that claim, because of the IRS 13 borrows directly from The Way to Happiness. Then it
14 decision. So the IRS decision, as far as I'm concerned, 14 becomes complicated for me to say it's just secular.
15 trumps here any academic opinion about -- about how I 15 Because of that IRS decision.
16 see Scientology's structure. 16 Q. Well, first of all, you don't know what the
17 Q. Well, how would you define something that's 17 final IRS decision says, correct?
18 religious? How would you defme religion? 18 A. No.
19 A. Well, there's different definitions, but the 19 Q. So we don't know, sitting here today, you
20 standard one, really, has to do with belief in 20 don't know what the IRS decision ultimately said?
21 supernatural forces or beings. That's a very basic one. 21 A. Well, the only reason I-- I'd hesitate that
22 There's a lot of debate about it. 22 in terms of actually what's happened, what's unfolded in
23 Q. Is there anytillng in the Narconon course 23 society is that, as far as I know, all of these
24 materials that talks about a belief in a supernatural 24 organizations that got identified in the version we have
25 being or force? 25 all got charitable status. So as near as I can tell, we
Min-D-Script Q&A Reporting Services, Inc.
J Fischer@QAReporting.com
(20) Pages 77 - 80
Desmond, et al. v.
Narconon, et al.
Page 81
1 have the document, the last document before, then we
2 have the settled document -- the settled behavior about
3 the IRS decision, so I think it's clear to infer that
4 the docwnent we have is pretty close, if not exact, to
5 the final decision.
6 Q. Well, let me explore that with you for just a
7 minute. You can have nonprofit charitable status and
8 not be a religious organization?
9 A. That's true.
10 Q. I mean, the Red Cross is a nonprofit
11 organization, but it's not religious?
12 A. That's ttue.
13 Q. Boy Scouts are a nonprofit organization that's
14 not religious?
15 A. Uh-huh (affnmative).
16 Q. Correct?
17 A. That's -- I'll take your word for it.
18 Q. Okay. So you can have a charitable nonprofit
19 type organization --
20 A. Yeah. That's my understanding.
21 Q. -- that is not religious?
22 A. That's my understanding.
23 Q. So the nonprofit status ofNarconon, or the
24 IRS's choice to treat Narconon as a nonprofit for tax
25 purposes, does not necessarily mean that they're
Page 82
1 treating them as a nonprofit for religious reasons?
2 A. Doesn't necessarily; but I know I've gone
3 through the IRS decision and looked for mentions about
4 religion. Involving the overall Scientology tax
5 exemption. And words about religion or religious do
6 appear in various places in the settlement.
7 Q. I think--
8 A. So-- so it would take, as you would say, I
9 guess a tax expert to sort this out. But I'm just being
10 vety cautious because, you know, there's this blanket
11 agreement, and Narconon's included in it, and, you know,
12 the major push for the Church of Scientology was its
13 religious claims.
14 Q. Well, the Church of Scientology, as far as you
15 know, does have a religious element to it, correct?
16 A. That's true.
17 Q. And there was some dispute about that, that
18 presumably got resolved by this agreement, the final
19 agreement which none of us have seen?
20 A. That's correct. And to say "got resolved,"
21 but it got resolved for tax purposes.
22 Q. Okay. So going back, you know, in fairness,
23 since you don't see anything in the Narconon course pack
24 that you would characterize as religious, and since we
25 don't know for sure if the government ever took a
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Stephen Alan Kent
January 5, 2012
Page 83
position one way or another about this specific
organization, Narconon, would it be fair to say you have
no basis to say that this Narconon course pack or the
Narconon program is a religious program?
A. It's based-- the Narconon course packs are
based upon principles and concepts that are central to
Scientology. Scientology beliefs and practices. And
those beliefs and practices are part of which have
received nonprofit status -- or, charitable status from
the IRS, based in part upon religious claims.
Q. Well, Dr. Kent, my question, though, is, do
you have any basis for saying that the Narconon of
Georgia materials that you've reviewed or that the
Narconon of Georgia program was a religious program?
A. Only to the extent that all the concepts in it
are based upon Scientology. Which, as I said, has the
non-- has the charitable status from the IRS.
Q. But other than the IRS possibly thinking that
Narconon of Georgia is religious, that would be the only
basis for your opinion that there's anything religious
in the Narconon of Georgia program?
A. To go back to your earlier question, I didn't
see any mention of anything supernatural in anyplace in
the Narconon materials that I reviewed.
Q. Right. So if all we had, if all you had, were
Page 84
the Narconon materials to look at, and you didn't know
anything about the IRS, you would be comfortable saying
that this is a secular program based upon L. Ron
Hubbard's principles?
A. With respect, sir, it's speculative. 'Cause
I -- I can't answer it, 'cause I'm not, and at this
point can never be, in that head space. You know,
because I know other things about...
Q. The other things being that there was some
agreement that was reached between the Church of
Scientology and the Internal Revenue Service?
A. Yes.
Q. Okay. Other than what you speculate might be
in that agreement between the IRS and the Church of
Scientology, is there any other basis for you to offer
the opinion that the Narconon of Georgia program is
religious in any way?
A. I have not seen any mentions of the
supernatural in this program.
Q. And I appreciate what you just said, but I'm
going to have her read back my last question and ask
you--
A. Okay.
Q. --if you can answer it.
MS. FRANKLIN: Well, I think he did, but
Min -ll-Script Q&A Reporting Services, Inc.
(21) Pages 81 - 84
Desmond, et al. v.
Narconon, et al.
Page 85
1 go ahead.
2 MR. MILLER: He may have, but I want to
3 be sure.
4 (Thereupon, the record was read by the
5 court reporter .)
6 THE WITNESS: First, I'd say this one's
7 not speculation. We have a very clear sense
8 about the IRS's decision, even if we don't
9 have the final documents. And it's that
10 connection between the concepts and
11 terminology in the Narconon course pack
12 related back to Scientology that's -- makes
13 me hesitate to just simply write this off as
14 a secular program. I've always -- so that's
15 about as good as I can answer it.
16 BY MR. MILLER:
17 Q. Well, what I'm trying to find out is whether
18 you're going to come to court and tell people on the
19 jury that you think N arconon of Georgia is a religious
20 program.
21 A. What I would intend to say is that-- that
22 Scientology has --in the United States has charitable
23 status, based in part upon its religious claims, and all
24 of the concepts in Narconon come from Scientology.
25 Q. Okay. My question's different, though. Are
Page 86
1 you going to say to the people on the jury that you can
2 offer an expert opinion, based upon reasonable science,
3 that this Narconon of Georgia program is religious?
4 A. I'd have to give the same answer, sir; that
5 it's-- you know, that's the connection between-- you
6 know, if Scientology has charitable status based upon
7 religious claims, and then people wind up using central,
8 core concepts, many of them, in a program, then I'm not
9 going to simply say that that program's secular.
10 Q. Well, I think maybe we're having a little bit
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January 5, 2012
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Q. Let me ask this question. IfNarconon of
Georgia's tax-exempt status from the IRS is based upon
its charitable status and not religious status, would
you have any reason to disagree with that?
A. That's why I'd want to look at the IRS
decision, see exactly what it says.
Q. But on an annual basis Narconon of Georgia
probably files taxes and claims a particular status
for--
Q. --not having to pay taxes?
A. Yes; but it's still -- still the problem is
the content of the courses that it-- the content of the
material that it uses --
Q. But, Dr. Kent--
A. --in its courses.
Q. But, Dr. Kent, you're--
MS. FRANKLIN: Just let him finish.
BY MR. MILLER:
Q. Have you finished?
A. I think so.
Q. Okay. Dr. Kent, you're saying the hesitancy
you have about agreeing that N arconon of Georgia is a
purely secular program is because of your belief about
what's in this IRS agreement that was reached in the
Page 88
1990s?
A That's largely true, yes.
Q. Well, if we have documents from the 2000s and,
4 the, you know, 2008 time frame where Narconon of Georgia
s has filed for tax-exempt status based upon something
other than religious grounds, and the IRS has accepted
that, then wouldn't that be evidence that Narconon of
6
7
8 Georgia is claiming nonprofit status on some basis other
9 than as a religious organization?
10
11 of problems with semantics here. But I understand that 11
12 you are hesitant to just flat out say it's absolutely, 12
A. Even if that is the case, N arconon of Georgia
is still using central concepts from Scientology, which
has charitable status based upon largely its religious
claims.
Q. Well--
13 positively not religious. That's what I'm hearing you 13
14 say. Because of your belief in what the IRS has done. 14
15 A. That's correct. 15 A. Now, these ancillary organizations may--
16 you're suggesting may have charitable status based upon
other claims. That may or may not be hue. But the
16 Q. But there's a difference, I think, between
17 being hesitant to agree that it's 100 percent secular 17
18 based upon your belief about what the IRS has done 18
19 versus corning in and affirmatively testifying that you 19
2 o think it is religious. 20
21 A. Well, once again, Scientology has the
22 charitable status, and that charitable status is a real
23 privilege because of the tax benefits it gives. It's
24 always appeared to me that in-- that Scientology's
25 tried to have it both ways in some cases.
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central Scientology claims, you know, appear throughout
the Scientology organization, and that's what has
charitable status based in part upon its religious
claims.
Q. Do you think that Scientology would have been
able to get religious status if they did not claim
belief in the supematural?
A. I think it would have -- there are such things
(22) Pages 85 - 88
Desmond, et al. v.
Narconon, et al.
Page 89
1 as functional religions, but I'm not sure they get
2 charitable status based upon those actions. I mean, I'm
3 not sure what the requirements are in the U.S.
4 government to get religious status. And that's a --
5 it's an interesting constitutional question.
6 Q. But I think bottom line is you're not an
7 expert on taxes, tax-exempt status, nonprofit status, or
8 what the IRS does or does not do in tenns of treating
9 people as tax-exempt?
10 A. All that's true.
11 Q. And you don't have personal knowledge, or any
12 knowledge, really, other than, you know, an earlier
13 draft of what you believe was an agreement that was
14 entered into between the IRS and the Church of
15 Scientology?
16 A. I'd say it's not-- I don't think it's an
17 earlier draft; 1 think it's the last draft before the
18 decision.
19 Q. And what's the basis of that belief?
20 A. The Wall Street Journal got ahold of a copy
21 and released it to the public.
22 Q. But there was a subsequent agreement, and you
23 have not seen that?
24 A. I haven't seen the final agreement, no.
25 Q. And you don't know what changes were made
Page 90
1 between the draft that the Wall Street Journal released
2 and the final agreement?
3 MS. FRANKLIN: Object to the form.
4 THE WITNESS: I don't know, other than
5 the con -- the reality in consequence is that
6 all the ancillary organizations to
7 Scientology have charitable status. So ...
8 BY MR. MILLER:
9 Q. Well, but the basis for that charitable-- I
10 mean, you don't know what the ultimate decision was
11 about why some of these organizations were given
12 charitable status, do you?
13 A. No, I don't.
14 Q. And you haven't talked to an IRS lawyer or a
15 lawyer for the Church of Scientology who negotiated
16 these agreements, or anybody who had personal knowledge
17 of what the final agreement looked like?
18 A. I did talk to someone.
19 Q. And who was that?
20 A. I -- a IRS agent.
21 Q. What's that person's name?
22 A. I have no idea. It's been quite a number of
23 years ago.
24 Q. When did you talk to him?
25 A. God. Late -- it could even go as far back as
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Stephen Alan Kent
January 5, 2012
Page 91
the late 1990s.
Q. Okay.
A. I mean, I can't even begin to give you an
exact date.
Q. Was this before or after a final agreement had
been reached?
A. It was after.
Q. And what did the IRS agent tell you?
A. I asked him a number of questions. He did not
reveal any secrets. Did not reveal anything about the
final agreement.
Q. Because the final agreement was confidential?
A. That's true.
Q. So he did not reveal any detai Is about the
fmal agreement?
A. That's true.
Q. So what did he tell you?
A. He said a number of things. He said, for
example, that, I'll say it, one or more IRS agents had
been harassed, been followed, by either Scientologists
or Scientology-hircd Pis, and I said, "Well, bow did you
know they were Scientologist?"
He said, "Well, we got their license plates
and we relayed it to the FBI." And he said, "This kind
of thing happens to us all the time."
Page 92
Q. Maybe I should be more focused on my question.
Did he tell you anything having to do with the
tax-exempt status ofNarconon of Georgia--
A. No.
Q. -- or Narconon Intemational?
A. Not at all. No.
Q. And no details about the confidential
agreement that was ultimately reached?
A. He did not breach any issues of
confidentiality, as near as I can recall.
Q. Where was the IRS agent from?
A. Washington.
Q. Was he in a Washington office?
A. Yes.
Q. And do you know if he had anything to do with
the negotiations of the agreement?
A. I thought so, but I couldn't tell you exactly
what role, if any, he played. I mean, he certainly was
knowledgeable about it, so ...
Q. Well, knowledgeable in the sense that he may
have known information but he didn't share it with you
about what the final agreement looked like?
A. Oh, he did not share that with me.
Q. Okay. Looking at Exhibit 8, based upon either
your review of Nick Parsons' books or your review of an
'lin-U-ScriptC!lJ Q&A Reporting Services, Inc.
(23) Pages 89 - 92
Desmond, ct al. v.
Narconon, et al.
Page 93
1 earlier version, can you very briefly tell me what in
2 each of these books are principles that you would relate
3 back to L. Ron Hubbard?
4 A. Okay. And I'll stick really to the-- as much
5 as I can, to the 2004 books here.
6 Book 1 involves, you see, a "TR Course";
7 they're short for training routines. And they're very
8 basic routines that people go into often in their first
9 moments in Scientology. There are TRs 1 through 4; I
1 0 think, as I said earlier, I don't believe I've ever seen
11 a TR5; and there's 6 to 8. Now, in this book there's
12 also a 9. But I think the ninth training routine is
13 just a repeat of 6b. So the training routines, they go
14 back decades in Scientology.
15 Q. These training routines, as I understand it in
16 this first book, have to do with helping people
17 communicate with each other?
18 A. That's what Scientology says.
19 Q. Okay. Anything else about book number I that
20 you would relate back to Scientology, other than the
21 fact that it has what are called training routines in
22 it?
23 MS. FRANKLIN: Before you answer, I'm
24 just noting for the record that the books are
25 not in front of Dr. Kent, and we have those
Page 94
1 available; if you choose to question him
2 about it and if he needs those, then he can
3 indicate that.
4 THE WITNESS: Okay. Each one of those
5 training routines bas an exact parallel in
6 Scientology materials. An exact parallel.
7 And the wording of the routines is the same.
8 So it's impossible to make -- come to any
9 other conclusion than the training routines
10 in the Narconon program come from
1l Scientology.
12 BY MR. MILLER:
13 Q. Well, and Scientology comes from the mind of
14 L. Ron Hubbard?
15 A. That's hue.
16 Q. And so the Narconon book number 1 is based on
17 the works of L. Ron Hubbard is what you concluded?
18 A. That's hlle. Yes.
19 Q. And the same for the other books where the
20 front covers are identified by Exhibit 8?
21 A. Yes; all of them have direct bases in existing
22 Scientology courses that drew directly -- that Narconon
23 drew directly from.
24 Q. You know the hist01y ofNarconon, where it
25 came from?
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Stephen Alan Kent
January 5, 2012
Page 95
A. Came, at least the Scientology story goes, in
1966 in tlte Arizona state prison. A gentleman named
William Benitez found a Scientology book in the library
and read it, was impressed by it, started doing some
processes with other prisoners. They felt it benefited
them. He eventually got some permission to do some
other prisoners. And I think from that contact-- it
was '66. By about '72 -- not -- but the early --
early-- what's now called Narconon didn't -- it only
involved -- it didn't involve the purification program.
It only involved different sorts of training routines
and so on. So the Narconon program now is different in
content.
Then by the early '70s, 1 think in '72, there
was a Narconon program that opened up in California, and
then also, fairly soon afterwards, a Narconon program
statted doing the Purification Rundown.
Now, the-- but to go back earlier, for
history, you really have to go back to the 1950s. To
look at Hubbard's writings about radiation. I mean, as
we all know, tlte '50s was a time of great concern about
atomic radiation. In this country there were
aboveground testings that were going on, and a number of
people were in communities where the wind changed and
they got doses of radiation from the tests. So back in
Page 96
the '50s Hubbard was claiming that he had developed
techniques that could 1id the body of radiation
residues. And those claims eventually migrated into the
Purification Rundown. So the Pur -- claims that it is
able to expel from the body drug and radiation residues.
Although the one drug it omits is, of course, nicotine,
and I always assumed it omitted nicotine because L. Ron
Hubbard smoked.
The Crirninon program started later, and, in my
estimation, I don't believe the Criminon program
routinely now runs the Purif. It does a number of
exercises for criminals, but 1 don't think it runs the
Purification Rundown. I think that's limited primarily
now to Narconon. So it's --now Narconon has most --
well, a great number of the services are outside of
prisons. I can't say whether it still has any active
. . .
m-pnson servtces.
Q. Would it be fair to say that the Narconon
program, since it started in 1966 with the man who was
in prison who organized some prisoners and they got off
drugs and alcohol using L. Ron Hubbard's principles,
that it's evolved over the years?
A. Well, the figures I've seen in those early
days claim that the success rate of getting people off
was somewhere between 60 and 70 percent plus. The
1\ I in-U-Script@ Q&A Reporting Services, Inc.
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Desmond, et al. v.
Narconon, et al.
Page 97
1 trouble is their claims and the documentation,
2 throughout the whole Narconon programs, to back up those
3 percentages is in dispute. Now, I'm not going to cover
4 those issues in my -- in my expett statement. I think
5 that' s up to a drug expert. So -- so I think
6 Scientology would agree with your repr esentation;
7 historians might raise some questions about it.
8 Q. Well, I'm not sure if that's the question I
9 asked; let me approach it this way. First, clearly,
10 you're not going to offer an opinion about what the
ll success rate ofNarconon is --
12 A. No.
13 Q. --or is not?
14 A. I'm not going to offer an opinion about the
15 success rate ofNarconon.
16 Q. Or its success rate compared to any other
17 program?
18 A. Nor its success rat e to any other program; I'm
19 not going to offer any opinion on it.
20 Q. Right. My question I was going to ask was, as
21 you've already mentioned that pmification got added in
22 at a later time, that the program materials, and the
23 program itself, have changed somewhat in tem1s of the
24 materials being used and things like that?
25 A. Yes, sir, that's true.
Page 98
1 Q. And matelials that you've looked at for the
2 most part would have been mate1ials that were in use in
3 2008?
4 A. Well, my star-- the records go back farther
5 than that in some of the matelials I'd submitted.
6 Q. That's not a very good question. You l ooked
7 at Nick Parsons' books, which would have been I believe
8 books that would have been used around the 2008 time
9 frame?
10 A. That's correct, yes.
l1 Q. And where you had some gaps, you may have gone
12 back and looked at books that go back to 2004 or
13 something like that?
14 A. Yeah. The-- the two copyrights, ifl'm not
15 mistaken, in the Narconon books is 1991 and 2004.
1 6 Q. Okay. But for the most part, in terms of
17 evaluating the course pack materials, you're looking at
18 what I'll call kind of modem N arconon materials,
19 compared to something that might have been used back in
20 the 1960s or 1970s or even the 1980s?
2 1 A. I' ve got-- I submitted some materials back
22 from the early period, but in terms of the training
23 materials and course exercises, I'm basing them upon
24 modem-- modem Narconon.
25 Q. Okay.
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Stephen Alan Kent
January 5, 2012
Page 99
I think there's some interesting historical
materials that may provide some light about Narconon,
but that's what l'm basing, primarily, my discussion on.
Q. Going back to the discussion we had a few
minutes ago about whether or not there was any religious
element t o the Narconon of Georgia --
Q. -- materials; do you have any opinion about
whether Narconon of Georgia was trying to recruit people
to the Church of Scientology?
A. I don't intend to give a specific answer on
that question. I can speak generally about Narconon and
possible recruitment. But in tenns of actually what
went on on the day-to-day basis in Narconon Georgia, I'd
rather defer to others.
Q. Okay. So you're not going to offer the
opinion that Narconon of Georgia was trying to recruit
people to the Church of Scientology?
A. I don't plan to offer the opinion. I would
say that if -- generally in Narconon, if a person
graduates from the program having done the purification,
a number of people do enter Scientology. But that' s as
far as I go. I'm not going t o say that -- that there
was an active recruitment program in Georgia.
Q. Do you know of anybody in Georgia who went
Page 100
through the Narconon of Georgia program who claims that
they were recruited in any way for the Church of
Scientology?
A. No, sir, I don't.
Q. Do you know anybody who went through any other
Narconon program that you have personal knowledge of who
says that they were recruited for the Church of
Scientology?
A. I know there's a Canadian, for example, and I
can speak about him because he's been very public. 1
think his name is David Love. He claims to have been --
to have gone through Narconon and through the program.
Q. Other than David Love, is there any other
person that you've heard who went through the Narconon
program who claimed there was any effort made to recruit
them to Scientology?
A. I'd have to think about it, because I've
talked to people who have been to the Narconon program,
I've talked about -- talked to people who have been
Seientologists who went through the Purification
Rundown, and it's easier for me to jumble what their
stories are. So I'm not going to base any of my claims
on any of these stoties. If that allays your concerns.
Q. Are you going to go in and testify in this
case that Narconon of Georgia or Narconon International
1\lin-U-Script Q&A Reporting Services, Inc.
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Desmond, et al. v.
Narconon, et al.
Stephen Alan Kent
January 5, 2012
Page 103 Page 101
1 are organizations that recruit for the Church of
2 Scientology?
1 that case here, but I don't want to retreat from the
2 general position.
3 A. The -- I offered two documents in my 3 MR. MILLER: Let me mark a couple
4 submissions. And these are old documents. One shows 4 exhibits.
5 people going into the Purification Rundown, and at the 5
6 end they leave the Purification Rundown and enter into 6
7 an archway that says "Scientology." 7
8 Q. Right. B
9 A. And the other is a pamphlet, I'm not even sure 9
10 what year it was, that says, "Narconon is the bridge to 10
11 the bridge." 11
12 Q. Okay. I think I'm familiar with those 12
13 documents. 13
14 A. Yeah. And so they're -- that's why I'm-- I 14
15 won't say that Narconon Georgia was doing that, but I 15
16 would-- if pressed, I would say that-- that people do 16
17 move from one to the other. 17
18 Q. Well, I think it's different to say that 18
19 people might move from, -- 19
20 A. Uh-huh (affirmative). 20
21 Q. --you know, Narconon, to decide to join the 21
22 Church of Scientology, and trying to contend that this 2 2
23 drug and alcohol progran1 is somehow trying to recruit 23
24 for the church. 24
25 A. Well-- 25
Page 102
1 Q. I mean, if you help change my flat tire and I 1
2 find out that you're Methodist, I might be attracted to 2
3 go to the Methodist church, -- 3
4 A. U11-huh (affinnative). 4
5 Q. -- I suppose, right? 5
6 A. Well, again, these are all-- the Narconon 6
7 courses are all based upon the low-level Scientology 7
8 courses. And 1 seem to recall--and 1 can't tell you 8
9 where 1 read this, and I could be wrong about this, but 9
10 I'll offer it with that caveat--that when -- part of the 10
11 assessment people go through when they enter Narconon is 11
12 they go through-- they get an Oxford Capacity Analysis 12
13 test on them. If my memory-- if that's in fact true, 13
14 then the Oxford Capacity Analysis is often a recruitment 14
15 tool for Scientology. So -- 15
16 Q. It's the Oxford -- 16
17 A. OCA, it's called; Oxford Capacity Analysis. 17
18 Now, again, I'm-- I'm not going --because I'm not 18
19 going to argue about-- talk about the daily routines of 19
20 Narconon Georgia, so I'm not going to say it was 20
21 actively recruiting. But I'm also -- I know in general 21
22 Sci -- people can and sometimes do move from Narconon 22
23 into Scientology. 23
24 Now, whether that var -- that probably varies 24
25 from organization to organization. I don't plan to make 25
purposes, Defendants' Exhibit Nos. 9
through 11.)
BY MR. MILLER:
Q. I think I've located the two documents that
you've talked about.
MR. MILLER: Do you have a stapler in
here, Rebecca?
MS. FRANKLIN: I can grab one.
(Brief recess.)
BY MR. MILLER:
Q. Dr. Kent, Exhibit 11 I believe is the
document--
A. Yes.
Q. --that has the ...
A. Yes, this is the one that has the -- published
by Bridge Publications, which I believe also is the
publisher for the Narconon course pack. It has a
picture of people going into the -- I'll call it a
gate -- a gateway called "Purification Rundown," and
then later on in the book it -- a person claims to be --
Page 104
regained his life and is then marching in to
Scientology.
Q. And Exhibit 10 is the other document that you
referred to?
A. That's right. This is an earlier, '74,
"Narconon helps ... people up Ron's bridge to freedom,"
and it's-- "Nareonon is the bridge to the bridge."
And, see, it's often the case that Narconon's staffed by
a number of Scientologists. Now, it's an open question
the extent to which they may or may not talk about their
practice of Scientology, but-- so that' s why I'm not
going to comment on what may have happened in the
Georgia case, but I don't want to back away from the
general concept that people often move from one to the
other, and that Scientology has aspirations that people
would move in that direction.
Q. Okay. Well, let me break that down and ask
you some questions. First of all, in your stack of
materials, your file materials that we've marked as
Exhibit 2, do you have any reason to beli eve that any of
those documents were used by anybody at Narconon of
Georgia?
A. No. No.
Q. Or that these were seen by any students who
went through the Narconon of Georgia program in the
Min-U-Scrit>< Q&A Reporting Services, Inc.
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Desmond, et al. v.
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Page 105
1 2000s and later?
2 A. I don't recall -- I'm trying to remember the
3 "Clear Body, Clear Mind" more recent documents, but I
4 don't trunk anything like what we're talking about is in
5 the more recent documents.
6 Q. Right. And the Exhibit No. 10 is a document
7 from 1974?
B A. Uh-huh (affirmative).
9 Q. Is that correct?
10 A. Yes, sir.
11 Q. And do you know when Exhibit No. 11 was
12 published?
13 A. I thought I had-- it looks --it's a bit bard
14 to read here. It looks like, and I'll defer to your
15 judg -- it looks like that says 1984? Does that seem
16 true to you?
17 Q. It certainly looks possible, so based on what
18 we can see here, it looks like this may be from around
19 1984?
20 A. Wouldn't surprise me.
21 Q. Do you have any documents that are less than
22 20 years old that would suggest to you in any way that
23 there is any expectation that people who go through the
24 Narconon drug and alcohol program are going to later
25 become Scientologists?
Page 106
1 A. Yeah. I don't think I -- I cannot recall
2 having any documents that make that case. But the
3 absence of documents shouldn't be taken as an absence of
4 intent or aspiration or satisfaction. If that move
5 indeed occurs.
6 Q. Do you have any basis to offer an expert
7 opinion that within the last ten years that there is any
8 effmt to get people who go into the Narconon programs
9 to become members ofthe Church of Scientology?
10 A. Well, there isn't evidence that I'm going to
11 introduce in this case. If that --
12 Q. So there is no evidence that --
13 A. That I'm going to introduce in this case,
14 along those lines.
15 Q. And if you have no evidence that you're going
16 to introduce in this case, can I fairly assume that
17 you're not going to offer the opinion in this case that
18 within the modem, last ten years, let's say, that the
19 Narconon programs are intended to recruit people for the
20 Church of Scientology?
21 A. I had intended to be neutral on the point.
22 Q. I'm comfortable with you just not offering
23 that opinion; --
24 A. Uh-hub (affirmative).
25 Q. -- I just want to make sure you're not going
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Stephen Alan Kent
January 5, 2012
Page 107
to offer that opinion.
A. Yeah. Again, I had not planned to get into
the daily operations of what's gone on in the Narconon
Georgia program, --
Q. Right.
A. -- 'cause I think that takes a different kind
of expertise. That requires talking to people, looking
at their affidavits, you know, and that just isn't what
I was required to do here,--
Q. Right.
A. --so ...
Q. And I appreciate that fact. But I'm asking a
little broader question. Which is, 1 want to make sure
that you're not going to come to court in this case and
say that in the modem era, in the 2008 time frame, that
Narconon programs were being used to somehow recruit for
the Church of Scientology?
A. I hadn't planned to make any statements along
those lines.
Q. Okay. And the reason I'm asking is because if
you were going to offer that opinion at trial, I would
need to spend a lot of time asking you what the basis of
that--
A. Sure.
Q. -- opinion would be.
Page 108
A. 1 understand.
Q. But as long as we have an agreement you're not
going to offer that opinion at trial, then I can move
on.
A. That's flne, you can move on.
Q. Okay. And Exhibits 10 and 11 I think we can
agree are probably going to be irrelevant in terms of
anything that you're going to point to or rely upon in
reaching your opinions in this case?
A. I--
MS. FRANKLIN: Object to the form.
THE WITNESS: I -- at thi s point I
cannot see bow I would use them.
BY MR. MILLER:
Q. Some of these documents that you've produced
are incomplete, you know, they're missing pages, --
A. Sure.
Q. -- they're just excerpts. Have you given us
evetything you have from any of these particular
documents, or did you pick and choose from a larger
document that's sitting in Canada?
A. Oh, I --just to save on photo -- on
photocopying, l didn't photocopy, for example, the whole
purification book.
Q. Okay.
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Page 109
A. I was even surprised that so much of the IRS
agreement is -- I don't recall photocopying all of that;
now, maybe I did. But -- and some of these are just
short excerpts, and they would be part of larger
5 documents. But in terms of what 1 was using, if there
6 were a magazine, for example, I wouldn't photocopy all
six pages ifl was only using one small section. 7
8
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Q. So where we have incomplete documents, the
complete documents may exist back in your file?
A. That's uue.
Stephen Alan Kent
January 5, 2012
Page 111
1 So I've read it somewhere; whether it applies
2 to Narconon Georgia I'm not entirely sure. I may have
3 seen it when I was looking through the Mary Rieser
4 material, but --
5 Q. Okay. But if there's evidence in the case
6 that Patrick Desmond and other students were not
7 . receiving an Oxford Capacity Analysis, you're not going
to dispute that? B
9 A. No, I wouldn't dispute that at all.
10 Q. I think we talked about on Exhibit 8 the first
11 book What is it about the second book that is an
12 Oxford Capacity Analysis, but do you know one way or the 12 L. Ron Hubbard principle?
Q. And I think you mentioned something called the 11
13 other whether the Oxford Capacity Analysis was being 13 A. "Clear Body, Clear Mind." The Purification
14 used at Narconon of Georgia? 14 Rundown is a program -- the detoxification program in
15
16
A. Well, I have-- I'm not sure. 15 Narconon is the same as the Purification Rundown in
Q. What is the Oxford Capacity Analysis? 16 Scientology. And the Purification Rundown in
17
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A. Oxford Capacity Analysis is a 200-item 17 Scientology was developed by L. Ron Hubbard. In its
19
questionnaire that Scientologists claim identifies areas 18 various dimensions. It involves claims about the value,
in a person's life that need improvement. I've seen it 19 first, of running; second, fairly long periods--up to
2 o used in variations as a recruitment tool so people can 2 o five hours, if possible--of saunas; it involves taking a
come in off the street. There'll be an advertisement, 21 particular-- the-- Hubbard's claim was that -- that
"Get your personality-- free personality test." And 22 drugs absorbed vitamins from the body. Hence he had a
21
22
23 they'll be given an Oxford Capacity Analysis test. 23 drink called Cal-Mag, which is calcium and magnesium.
24 There are-- I've seen it used as an initial 24 He also had a particular increasing vitamin dosage that
25 IQ test, I've seen it used in a variation as a work-- 25 people are supposed to take, including niacin. That
Page 110
1 work analy -- hiring document. So it's got variations.
2 As far as I know, and I know this fairly well,
3 it doesn't have any standing in the psychological
4 community. It's a straight Scientology program. And
5 the Scientology documents that I have talk about how
6 it's --how it's marked. And the way that it's marked
7 is always for the --for Scicntologists to mark it and
8 identify some apparent weak spots on the chart and say,
9 "We can handle this. We can help you improve this."
10 Q. Okay. My understanding is you have not
11 reviewed Patrick Desmond's file from Narconon of
12 Georgia?
13 A. I don't think so.
14 Q. And you don't know whether his file contains
15 an Oxford Capacity Analysis or not?
16 A. I'm not sme. You know, I say I had those two
17 depositions from ... Oh, the head ofNarconon Georgia,
18 is it Mary Rider? Rieser, Mary Rieser. And there are
19 some documents attached to the back. But, again, I
20 looked at them a long time ago and very quickly. So
21 that's why I'm being hesitant, because I'm not-- I'm
22 not speaking definitively, and I've said I'm not using
23 those documents in my--
24 Q. Okay.
25 A. --in my-- analysis.
Page 112
1 he -- he claimed that drug and radiation residues were
2 stored in the fatty tissues of the body and the niacin
3 helped open up pores that would expel these drug and
4 radiation residues from the body in sauna.
5 Q. And the medical effect or the physiological
6 effect of detoxification, you're not going to offer
7 opinions about that?
8 A. I'm not going to talk about it, no.
9 Q. What about book number 3, "Learning
10 Improvement Course"?
11 A. I think earlier I talked about what's in it,
12 and the content is straight Scientology assumptions
13 about learning how to learn and barriers to learning.
14 Q. Helping people to be better students, not
15 stumbling over-- you know, not ignoring a word they
16 don't understand but look it up in the dictionary, that
17 type of thing?
18 A. Some other factors. Yes.
19 Q. How about book 4a, "Communication & Perception
20 Comse"?
21 A. If I remember correctly, 4a is a-- more or
22 less a repetition of the TRs. And it's in preparation
23 for 4b, which is an analysis of the objectives. Now, it
24 seems to me Hubbard made a statement, maybe in the late
25 '60s, that the objectives were very useful to someone
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Page 115
1 who had been on drugs. Because it-- maybe-- his 1 Q. How about number 7?
2 assumption was that people who had been on drugs were 2 A. "Changing Condition ... " You know, the
3 not oriented to the present time. They were often 3 conditions are principles that-- or, concepts that
4 oriented toward past events, often negative events. And 4 Scientology uses in order to identify either where one
5 the objectives were ways he thought would bring them up 5 is in relation to patiicular work assignments or where
6 into present time. Similar in many ways to some of the 6 the particular organizational operation is in relation
7 TRs and what's often called "locationals" in 7 to work assignments. So it has to do with, on the top
8
9
Scientology. 8 end, people in a position of power who are really
Q. Book 5? 9 blasting ahead with their -- with their success.
10 A. "Ups and Downs in Life Course" is a straight 10 There's a level about people's ability to write down
11
12
rendition of Scientology's concepts about social 11 what they're doing in a power position so they can pass
personality, antisocial personality and a potential 12 it on to a person who may fulfill the job later.
13 trouble source. 13 Then it goes down into various levels about
14 Q. "Avoid people who are negative influences on 14
15
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your life," that smi of thing?
A. That's a -- not to disparage what you say,
that's a simple version of what an antisocial
personality is. I think there's 12 or 14
characteristics that are -- that are listed in there.
And 12 or 14 parallel characteristi cs of the social
15
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20
21 personality. And a PTS is somebody who's associated 21
22 with an antisocial personality. But through that 22
association, the person's being brought down by, you 23
24 might say, the negative energy of the PTS. The person
23
24
25 2 5 finds him- or herself on a roller coaster and so on.
Page 114
1 Q. It looks like you're married? 1
2 A. I am. 2
3 Q. Do you have children? 3
4 A. Don't. 4
5 Q. I was going to ask because it's like telling 5
6 your kids not to associate with people that you think 6
7 ar e going to lead them in a bad direction? 7
8 A. Well, I'm not going to get into the ways that 8
9 these contents are used. 9
10 Q. Okay. How about book number 6? 10
11 A. "Personal Values and Integrity --" -- there's 11
12 actually a whole Scientology course, I think it's called 12
13 "Personal Integrity and Values." I could have the order 13
14 of the terms switched. But these are I believe moral 14
1 5 of-- I'm trying to remember when Hubbard talked about 1 5
16 morals. But these are--I'll use this term; it's not one 16
17 that Scientology used--the principles that Hubbard felt 17
1 8 were important for people to follow. And they're in 1 8
1 9 some ways similar to what happens on The Way to 19
20 Happiness. 20
21 Q. Things like being honest and things like that? 21
22 A. I'm not sure where the being honest-- whether 22
23 it shows up in that "Personal Values and Integrity 23
24 Course" or The Way to Happiness. But those kind of 24
25 principles show up in one or the other. 25
normal -- normal, which is a person or an operation
that's moving ahead, having -- having constant but low
increases. Then it keeps going down into -- it gets
down --lower and lower into, you know, negative
conditions. And I -- I forget the order. I think, you
know, the bottom one talks about a chaos a person's life
may be in. There's a person who is -- who's labeled as
being treasonous, or condition is treasonous. And
there's one with enemy, and one with doubt, and so on.
There's quite a, you know, a number of them. And one is
supposed to be able to locate one's own behav -- in an
organization, really in a relationship, one's supposed
Page 116
to be able to locate one's self in one of those
conditions. And try to raise up to the next one.
Q. And what is book number 8, "The Way to
Happiness"?
A. "Way to Happiness." If you look at the back
of the Nar conon course pack, you'll see The Way to
Happiness booklet is a smaller booklet. lt was a
paperback. There's actually a hardback version of The
Way to Happiness that's produced, and it -- I'm not sure
when it came out. It might have been as late as the
early 1980s. But my understanding is that Mr. Hubbard
wanted to produce a document that he said was secular in
nature. So there's no mention about anything religious
in here, about fates or whatnot.
Q. And no mention of anything religious in any of
these books that we've talked about?
A. There are some mentions of religion in terms
of -- in one of these upper-level courses, it -- I'm not
even sure which one it would be. It's what's called the
dynamics. The dynamics arc eight levels of existence
for Scientologists. And, again, fearing that I may omit
some, it starts with self, and then the second level's
currently called creativity; before it used to be family
and sex. Third was -- they use the term "mankind"; I'd
say "humankind." Fourth would be I think-- I think
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Stephen Alan Kent
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1 it's all species. Fifth I think is the -- the universe. 1 Concepts," and the desire to survive through these. The
2 Six is spirit, and seven is infmity. I thought there 2 seventh dynamic is life source; this is separate from
3 were eight, so I may be forgetting one. But the upper 3 the physical universe and that's the source of life
4 two involve spirit and infinity. And they're mentioned, 4 itself. Best there are some efforts for the survival of
5 if I'm not mistaken, in the-- in the Narconon course 5 life source.
6 that deals with them. 6 And then there's some cartoons, and then --
7 Q. Which book do you think it's in? 7 and when I say "cartoons" I don't mean to disparage
8 A. Oh, goodness. 8 these cartoons. Some of these are very talented
9 MS. FRANKLIN: Do you need the books in 9 illustrations. You know, for lack of a better term, I
10 front of you? 10 use the word "cattoon," but I'm really quite impressed
11 THE WITNESS: Well, it might take a few 11 with whoever the artists were.
12 minutes, but it'd be easy to -- it'd pin it 12 And then there's -- on Page 69 there's a clay
13 down exactly. 13 demo; "Demonstrate what the seventh dynamic is. Get a
14 MS. FRANKLIN: Are they in your bag? 14 pass on this from the supervisor." Then there's the
15 THE WITNESS: I brought them in that 15 eighth dynamic. The eighth dynamic is the urge toward
16 roller thing today. This morning. 16 existence as infinity. The eighth dynamic is commonly
17 MS. FRANKLIN: Want to take a break and 17 supposed to be a supreme being or creator. It is
18 get them? 18 correctly defined as infinity, it actually embraces the
19 MR. MILLER: Yes. 19 allness of all.
20 THE WITNESS: Okay. 20 Page 72, "Demonstrate what the eighth dynamic
21 (Recess at 1:08, resumed at 1:25.) 21 is. Get a pass on this from the supervisor."
22 BY MR. MILLER: 22 "An individual who seeks survival on one or
23 Q. Dr. Kent, while we were on the break you went 23 all of these dynamics fails when he abandons a dynamic
24 and retrieved the books that you've reviewed last night 24 as a survival route." So a person is supposed to work
25 and then I guess partially this morning, and in terms of 25 on all those levels. And the reason I had this marked
Page 118
1 that last series of questions I was asking you, you've
2 identified book number 6, entitled "Personal Values and
3 Integrity Course," and the seventh dynamic talks about
4 that people are urged to be spiritual, in effect, and
5 then the eighth dynamic talks about the possibility of
6 the supreme being or creator?
7 A. That's right.
s Q. And so these would be the two things you would
9 point to in this book number 6, along with... It looks
10 like on Page 595 there is a space where somebody can
11 talk about what their spiritual beliefs might be or what
12 their belief in the supreme being might be?
13 A. Would you mind -- I want to check-- if you
14 don't mind, Mr. Miller, 1 want to check through
15 something else.
16 Yeah, just to get -- the -- it's on 65, it's
17 called the seventh dynamic. The seventh dynamic is the
18 spiritual dynamic, the urge to survive as spiritual
19 beings, or the urge for life itself to survive.
20 Anything spiritual, with or without identity, would come
21 under the heading of the seventh dynamic. It includes
22 one's beingness, the ability to create, the ability to
23 cause survival or survive, the ability to destroy or
24 pretend to be destroyed.
25 A subheading in this dynamic is "Ideas and
Page 120
1 in the back. .. And this is, as you indicated on 595,
2 "Write--" --okay. This is what I was looking for.
3 "Write up your overts and withholds on your seventh
4 dynamic. Do this until you are satisfied that they are
5 complete and you feel good about it and have experienced
6 relief." Now, "overts and withholds" is another classic
7 Scientology term.
8 And then -- let me see. Page 607, "You may
9 use this space to write down any wins or gains you had
10 while writing up your overts and withholds on the
11 seventh dynamic."
12 "Write up your ovetts and withholds on your
13 eighth dynamic. Do this until you are satisfied they
14 are complete, and you feel good about it and have
15 experienced relief." So they were asking people to
16 identify any issues they may have not brought forward
17 about these dynamics. And the withholds and -- the
18 withholds eventually become an overt act. TI1e process
19 of withholding. To write these up. So, llmow we
20 talked earlier about whether I had seen anything
21 spiritual in these books; I had forgotten all about that
22 section, but--
23 Q. Okay. Well, that's fair. I had told you we'd
24 come back to the books, --
25 A. Sure.
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Q. -- and I appreciate you getting the books.
With the benefit of having the books in front of you,
Dr. Kent, other than the materials we've j ust talked
about in book 6, anything else in here that you would
identify as spiritual or religious?
A. lfl may?
Q. Sure.
A. There's more -- "Demonstrate to supervisor
using a demo kit an example of a survival action on each
dynamic and why that action would be a survival action."
And it lists the eighth dynamics, including the seventh
and the eighth dynamic. It's on Page 79.
Q. Well, again, I'm not asking you to identify
every page in book 6 --
A. Uh-bub (affirmative).
Q. -- that may discuss the seventh or eighth
dynamics. But I think what you've told me now is that
the seventh and eighth dynamics have a spiritual
dimension to them?
A. That's my understanding.
Q. Okay. What I want to do is just find out,
other than what we're talking about here in book 6, now,
is there anything else that you would identify as being
spiritual or religious in the Narconon course materials?
A. Let me look through this for a second.
Page 122
For what it's worth, this is on Page 120.
"When one thinks of survival, one is apt to make the
error of thinking in terms of barest necessity," in
quotation marks. "That is not survival. Survival is a
graduated scale with infmity or immortality at the top,
and death and pain at the bottom." So 1 don't recall
any other issues, but it...
I just am afraid if I close it up 1 might miss
something that could be important. So if! could
indulge you just for another minute or two.
Q. Sure . That's fme. Although, again, I'm
going to mark book 6 as an exhibit to the deposition, --
A. Sure.
Q. --and I think to the extent it touches on
that seventh or eighth dynamic, we will have already
discussed it, so ...
A. Okay. Ethics and morals ... I' ll let that--
let it go from there and ...
MR. MILLER: Let's mark book 6 that
Dr. Kent' s been looking at as the next
exhibit.
Want to just put it on the front cover?
MS. FRANKLIN: Yeah, shecan putiton
the front cover.
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Stephen Alan Kent
January 5, 2012
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purposes, Defendants' Exl1ibit No. 12.)
BY MR. MILLER:
Q. Okay, that's now marked as Exhibit 12 to the
deposition.
So, Dr. Kent, with the exception of what we've
talked about in book 6, you would still agree that
there's nothing else in these materials that you would
identify as being religious?
A. Not that 1 can recall at this time.
Q. And what's in book 6 about spir ituality or the
possibility of a supreme being, it's not advocating any
particular spiritual belief, is it?
A. I didn't get that impression.
Q. It could encompass Christianity or Judaism or
Buddhist philos -- I mean, religion?
A. I didn't see it specific to any one
particular.
Q. And just from your common knowledge of things,
not as an expert but just commonly, are you familiar
with the fact that Alcoholics Anonymous, for example,
talks about spiritual things and the belief in a higher
being or a higher power?
A. I've heard that about Alcoholics Anonymous.
12-step program.
Q. Right. So it's not uncommon for a drug or
Page 124
1 addiction program to encourage people to get in touch
2 with some sort of a spiritual dimension?
3 A. I do know there's controversy about the
4 12-step program precisely for that reason.
5 Q. But, again, you're not going to offer opinions
6 about Alcoholics Anonymous and their 12-step program any
7 more than you're going to offer opinions about Narconon
8 and its program?
9 A. That's true; I'm not going to talk about the
10 12-step program at all.
11 Q. Okay. So going back to your opinions that
12 you're going to offer in this case, I think on your
1 3 opinion number 2 1 can fairly summarize it in this way,
14 but I want you to let me know if this is not a fair--
15 A. Okay.
16 Q. -- summary of your opinion number 2.
17 L. Ron Hubbard had a series of principles that
1 8 were incorporated into what we now know to be the Church
19 of Scientology, and those similar principles, at least
2 o with regard to the matters that are touched upon in
21 these books, were also incorporated into Narconon's
22 materials?
23 A. I'd be a bit stronger. I'd say that L. Ron
2 4 Hubbard included in Scientology techniques, principles,
25 morals, etcetera, that transferred it directly into the
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1 Narconon program.
2 Q. The Narconon books are based on the works of
3 L. Ron Hubbard, correct?
4 A. That's -- that's very true, yes.
5 Q. Okay.
6 A. Says so right on the front cover.
7 Q. Right. In other words, the book themselves
8 all state on the front cover they're based on the works
9 ofL. Ron Hubbard?
10 A. That's right.
11 Q. And you would agree with that?
12 A. Yes.
13 Q. And your analysis of those books and your
14 knowledge of L. Ron Hubbard's writings is consistent
15 with that?
16 A. That's true, yes, sir.
17 Q. In other words, your expert opinion basically
18 on number 2 is that these Narconon materials are based
19 on the works of L. Ron Hubbrud?
20 A. That's true.
21 Q. As far as number 2 is concerned, is there
22 anything beyond what we just talked about, that these
23 books are based on the works ofL. Ron Hubbard, that you
24 concluded?
25 A. If we had the time, I could go through each
Page 126
1 one and I'm sure there's many more examples. But I
2 don't want to, you know, tie us up all day doing that.
3 But -- so, you know, concepts, terms, techniques come
4 straight from Scientology.
5 Q. Okay. So your opinion on number 2 is, it
6 sounds like, bottom line, what we just talked about,
7 which is that these books incorporate L. Ron Hubbard's
8 works and principles. Not just the specific examples
9 we've talked about, but other examples as well?
10 A. Well, L. Ron Hubbard's, but al so, more
11 specifically, Scientology's opinions-- or, doctrines,
12 opinions, techniques that Scientology uses.
13 Q. But Scientology is in effect based on L. Ron
14 Hubbard's works as well?
15 A. That's true. Scientology is based upon the
16 works. But a lot of these tenns predate Narconon. And
17 a lot of these terms go back to the very early -- early
18 days in Scientology, so ...
19 Q. But the early days of L. Ron Hubbard as well?
20 A. Uh-huh (affirmative).
21 Q. Right?
22 A. That's true, yes.
23 Q. Let me ask you what your opinion number 1 is.
24 It says you intend to "provide testimony at trial
25 outlining the beliefs and practices of the members of
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Stephen Alan Kent
January 5, 2012
Page 127
the Church of Scientology."
A. Well, it depends upon what somebody would ask
me about -- about them.
Q. Let me divide it up for a minute.
A. Sure.
Q. Whatever the beliefs are in Scientology, you
would respect people's right in a religious context to
enjoy whatever beliefs they want?
A. In the abstract, separating beliefs from any
kind of action, people can hold in their consciences
whatever they want.
Q. And in terms of practices, would I be correct
in assuming that as long as a practice is not harmful to
other people, you would be of the opinion that you can
practice whatever you want in connection with your
religion as long as you're not harming other people?
A. That's true. Now, it may be of academic
interest to study what the practices are, and even study
what the beliefs are. But in terms of any kind of
intervention to limit beliefs or practices, it has to be
based upon -- intervention has to be based upon harm.
Q. So you have been a critic of the Church of
Scientology over the years, as I understand it?
A. I've been a critic of what I think are some
hannful behaviors in Scientology.
Page 128
Q. Right. But it's the harmful behaviors you're
critical of, not the fact that peopl e might have this
particular belief system, or even a series of practices,
as long as it's not resulting in some harmful effect?
A. That's true. I do -- I do study, and I think
a lot of academics study, unusual belief systems. So in
that regard Scientology is interesting, but in terms of
a lot -- areas where I' ve had concerns, it's on issues
of harm.
Q. Are you aware of anything that you would
consider to be a harmful practice of the Church of
Scientology that was occwTing in the Narconon of
Georgia program?
A. There's nothing I'm going to speak about, but
I do have some -- I do have concerns about some
practices.
Q. Well, this is important, because, you know,
you' re going to come testify at cowt.
Q. Are you going to come and testify at court
that there is some harmful practice of the Church of
Scientology that you will contend was occurring in the
Narconon of Georgia program at any time that's relevant
to this lawsuit?
A. I don't intend to talk about the issues of
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1 harm. It doesn't mean I don't believe that those issues
2 exist.
3 Q. Well--
4 A. Of the issues of harm, I would-- you know,
5 I'd want to look at issues involving the purification
6 program in its different dimensions, but I'm not going
7 there. I don't have medical or physiological training.
8 So I'll tell you that, but it's nothing I'm going to
9 bring up in court.
10 Q. Okay. So for purposes of this lawsuit, you're
11 not going to offer the opinion in court, as an expert,
12 that there was anything that you would consider to be a
13 hannful practice of the Church of Scientology that was
14 being practiced or followed in the Narconon of Georgia
15 program?
16 A. As far as I could foresee, Mr. Miller, I have
17 no intention of talking about issues of harm, period.
18 Q. Well, and when you say like as far as you can
19 foresee and that type of thing, --
20 A. Yeah.
21 Q. -- I mean, can we agree that you're just not
22 going to offer an opinion that there was any harmful
23 practice going on in the Narconon --
24 A. Yeah, I don't intend to, 1 just -- I have to
25 have the caveat, 'cause I don't know what kind of
Page 130
1 question somebody might ask me.
2 Q. Well, that's the problem, Dr. Kent.
3 A. Yeah.
4 Q. I can't leave this deposition and have you
5 say, "Oh, I'm going to--"-- you know, have you testify
6 to something in the courtroom --
7 A. Uh-huh (affirmative).
8 Q. -- because some lawyer has decided to ask you
9 that question. I mean, the purpose of this --
10 A. Well--
11 Q. -- deposition is for me to understand what
12 your opinions are going to be in court.
13 A. Sure.
14 Q. And 1 appreciate what you're saying, that
15 there might be something that you would say, you know,
16 "Gee, I don't know if the sauna should be run at 160
17 degrees, but I'm not an expert on that."
18 A. Yeah. See, I want to avoid any question of
19 hann because I think they involve issues of medical
20 analysis, physiology, and areas that I'm just not
2 ~ trained in. I could make a case that there may or may
22 not be issues of social harm that would come through
23 these practices, but I wasn't hired to look at any
24 issues of social harm. I haven't done so. So I'd say
25 even as a sociologist, in this particular case, I'm not
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Stephen Alan Kent
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going there.
Q. Okay.
A. I'm not going to the issue of hatm. I want to
limit myself to identifying coru1ections, which I do
believe are very strong, between the Narconon content
and Scientology content. That's it.
Q. Okay. And so in terms of the beliefs and
practices of the Church of Scientology with respect to
this particular case, --
Q. -- it sounds like the only significance there
is that you've identified things in these Narconon
materials that are common principles from L. Ron Hubbard
that you see between the Church of Scientology and the
Narconon written materials?
A. I think. that's true. I mean, one could talk
about Scientology -- part of Scientology involves -- its
tenn is "Making the able more able." And in that
general practice, it tries to help people identify
issues that have occurred in this life that may be
hindering them. That general practice certainly appears
in the Scientology programs. And, for example, it
claims that people who have been involved in drugs have
mental images of their drug involvement, and that the
Narconon program-- the purification program, excuse me,
Page 132
greatly reduces those mental images. They still exist,
and the Narconon program doesn' t talk about any further
way to remove them. You know, which one conceivably--
a Scientologist would argue one could do through
Scientology. But-- you know, so there is a sense
about-- one aspect of Scientology is -- is, you know,
what it believes to be identifying issues in people's
lives and getting them-- getting them handled. Now, I
don't know how relevant that general perspective is with
the Narconon program, because I think it finally comes
down to what's been botTowed. But there is a larger
context to Narconon that I'm aware of in the context of,
you know, beliefs and practices and so on.
Q. Okay. What I'm trying to nail down, and I
think you're helping me do this, but --
Q. --is that the Narconon materials which
incorporate works and principles ofL. Ron Hubbard are
similar to works and principles ofL. Ron Hubbard that
have been incorporated into the Church of Scientology?
A. Again, I'd be stronger. Might say "are
exactly," but...
Q. Closely aligned. Would you say that?
A. In many cases, exact.
Q. Okay. But in tenns of what you might testify
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1 to at trial about the beliefs and practices of the
2 Church of Scientology, it would seem like it's going to
3 be limited to there are certain beliefs in the Church of
4 Scientology which are very similar or identical, in your
5 opinion, to beliefs that are in these Narconon books?
6 A. That's very true. You know, I-- 1 could
7 envision saying that Mr. Hubbard identified, probably by
8 the early '70s, or -- that people's ability to do
9 Scientology courses was severely damaged if they had
10 unresolved drug issues. Consequently, there's a big
11 push to get Scientologists to do the Purification
12 Rundown. People in the Narconon program have now done
13 it. So-- so I leave it at that. You know, it goes
14 back to the question about whether Narconon is actively
15 recruiting, and I can't say that's true. But I can say
16 that the-- that people have gone through the Narconon
17 program and hence met Mr. Hubbard's requirement that--
18 that people who want to advance in Scientology have
19 already gone through the Purif.
20 Q. Now, 1 know you have --let me back up.
21 The general goal of the Narconon materials, as
2 2 you've read them, is to help people get off of dmgs and
2 3 alcohol and somehow become better, more complete people?
24 Would that be a fair assessment?
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Page 134
BY MR. MILLER:
Q. In light of the objection, let me ask a
different question.
Do you have any reason to-- I'm going to
strike that one too.
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Let me ask your opinion number 1, Dr. Kent, in
this way. What is it about the beliefs and practices of
8 the Church of Scientology that you would suggest to us
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is relevant to this case, that you might testifY about?
A. Well--
Q. I mean, I--
A. No, I-- that's a good question. I can start
13 an initial answer, and l'm sure we can go back and forth
14 on it.
Stephen Alan Kent
January 5, 2012
Page 135
1 own techniques. So Scientology has a global vision
2 about its importance and its value. Consequently it
3 markets itself to different aspects of society, with the
4 hope of getting Scientology's ethics in, to use a phrase
5 from Hubbard. And getting ethics in, it would take a
6 while to fmd, but it's actually in one of these course
7 books; I was really -- I was a bit startled to see it.
8 So in addition to whatever benefits people may
9 feel-- Scientologists may feel, or Narconon people who
10 are not Scientologists may feel, about the value of the
11 program, getting people off drugs, there's also the
12 consequence that Narconon is trying to get Scientology
13 ethics into the drug rehabilitation realm in a way that
14 knocks out psychiatiy. There's a couple of mentions
15 against psychiatry that appear in these books. You
16 know, the sense is that-- and Narconon is quite proud
17 of the fact that it says it gets people off drugs
18 without using additional drugs to addict them. And
19 that, you know, psychiatry makes billions of dollars off
20 its vm;ous kinds of drug treatments, and so on. So
21 Narconon, in one way, fits into the larger
22 anti-psychiatry effmt of Scientology. On the other,
23 it's an attempt to get ethics in, into this aspect of
24 society.
25 And, you know, I'm not in a position to accept
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Page 136
or question Narconon participants, indeed, or
Scientologists or non-Scientologists, who may genuinely
believe that this program helps people get off drugs.
Q. When you say that it's ttying to inte1ject
ethics, what ethics are you talking about?
A. Scientology ethics.
Q. That's what I'm trying to understand; what are
Scientology ethics? 8
9 A. Well, the final, foundational ethic is to keep
10 Scientology working. Is to keep Scientology working and
11 expanding in all realms of society. And that's really
12 the bottom line. And what you see in these courses, for
13 example, is the emphasis on practicing the Narconon
14 techniques exactly according to Scientology principles.
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The initial-- an early goal ofL. Ron Hubbard 15 Hence the need for the so-called ethics officer. The
17
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was to clear the planet. And that tenn "clear the 16 ethics officer receives a person's individual reports
planet" I think meant a couple of things. One was to 17 and analyzes them to make sure that they are-- they're
help everybody on the planet get rid of the hindrances 18 following proper Scientology procedures, doctrines and
19 that held them back :fiom reaching their full potential. 19 so on. So, you know, there's just a larger context for
The second was to clear the planet of opposition, of 20 ethics. And if one were to, you know-- and, see, this 20
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what Scientology would call counter-intention. 21 is what I wasn't required to do. I wasn't required to
Now, at some point, a11d I forget the exact 22 go through the "Personal Values and Integrity Course"
date, Hubbard's anger grew so much against psychiatry 23 and say, "Well, let's look at this particular
that he said the goal of Scientology now is to destroy 24 statement," and I'm not going to do it in comt. But
psychiauy, essentially to replace psychiatry with its 25 one could do that kind of thing. Or go through the TRs,
:\-lin-U-Script Q&A Reporting Services, Inc.
(34) Pages 133 - 136
Desmond, et at. v.
Narconon, ct al.
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Page 137
you know, and say, "Well, what's the pwpose of
bullbaiting?" You know, and, "What's the purpose of
yelling at an ashtray, telling it to stand up, sit down,
and so on." According to number 2 here, I just was
required to identify whether the vast majority of
N arconon of Georgia's training materials and course
exercises are based primarily on the principles of the
Church of Scientology. That's definite. So... So
there's a whole other dimension, but I haven't been
hired nor have I prepped to address those larger issues.
Q. What were you asked to do?
A. Well, what's here.
Q. You were specifically asked to say can you
talk about the beliefs and practices of members of the
Church of Scientology, and can you offer the opinion
that these materials are primarily based on L. Ron
Hubbard's works?
A. Yeah.
Q. Okay.
A. And this third issue about Narconon, but I--
as I said, I really -- 1 don't think I've got any really
definitive evidence one way or the other on those. --
Q. Okay.
A. -- Those points.
Q. And the way that the Narconon program, as 1
Page 138
understand it, that you say gets into the larger scheme
of Church of Scientology would be that in general it's a
non-drug program to get people off drugs and alcohol, so
it's therefore contrary to what a psychiatrist might be
doing?
A. That's true.
Q. That's number one. Then number two is that in
stressing ethics, it uses some of the same principles
that L. Ron Hubbard uses to try to encourage people
towards more ethical behavior?
A. Hubbard outlined --well, there's a whole
series of statements in the upper levels of these
13 Narconon courses that involve morals, ethics, The Way To
14 Happiness, and so on. And one could go through and
identity them as different moral and ethical statements,
codes and so on. Talks about moral codes in here.
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Q. Okay. In other words, it is a program that is
stressing, through principles that Hubbard laid out,
moral and ethical behavior?
A. They are Hubbard's visions of moral and
ethical behavior. Not a complete statement by any
means.
Q. Right. But, for example, The Way to Happiness
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Stephen Alan Kent
January 5, 2012
Page 139
Q. And so the way it fits into the larger
Scientology schemes would be that that -- it's sort of a
systematic structure for trying to encourage things like
the ways of happiness?
A. The reason 1 hesitate, and the reason I hope
we don't go too far this direction, is that the
Scientology organization is multiple levels.
Q. Okay.
A. And--
Q. But--
A. And some of the multiple levels-- some people
in some of those multiple levels have engaged in
behaviors that would seem to me to be contrary, directly
contrary, to the ethical and moral behaviors that are
laid out in the book. So --just as a basic example,
the whole fair game issue.
Q. Let me use that as an example.
Q. Again, you're not going to come to court and
testify that there was something going on at Narconon of
Georgia that was similar to your criticism of Church of
Scientology's fair game?
A. That's not my -- no. I don't intend to do
that at all.
Q. Right. In other words, what l'm struggling
Page 140
1 with a little bit is -- you may have already answered
2 this question, but in terms of talking about the Church
3 of Scientology's beliefs and practices, I just want to
4 know what you're going to say that you would then say
5 is, you know, relevant to this case, and what I'm
6 hearing you say is that these materials are L. Ron
7 Hubbard type materials, and they are consistent with
8 L. Ron Hubbard's belief that people shouldn't be, you
9 know, taking dmgs, for example, to help get off dmgs,
10 and that they should engage in ethical behavior?
11 A. I wouldn't even go that far. I would say that
12 these-- the statements that appear in the Narconon
13 books come from existing Scientology programs, courses,
doctrines and so on, and just leave it at that. 14
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Q. Okay. And that's where I was thin.lcing you
were gomg, --
A. Yeah.
Q. --which is that basically yow- opinion
number 1 is to substantiate your opinion number 2?
A. Yes.
23
24 bas a number of moral and ethical statements in there? 24
Q. So that your anticipated testimony which you
plan to present would be enough of the Church of
Scientology's beliefs and-practices to illustrate bow it
is that the Narconon materials are consistent with the
Hubbard stuff that's in the Church of Scientology? 25 A. That's true.
l\1in-U-Script
25
(35) Pages 137 - 140
Desmond, ct al. v.
Narconon, et al.
Page 141
1 A. I think that's a fair representation. I mean,
2 I can see how someone would ask a question, "What is a
3 suppressive person," or "What is a PTS." You know,
4 "What's a rule in Scientology, does it appear in the
5 Narconon." Or even go the other direction. But those
6 kind of questions. And not go beyond the implications
7 about how Scientology may respond to a suppressant
8 person; that's a different -- that's not relevant to
9 this particular case here.
10 Q. Okay. I think that's fair enough. So what 1
11 wanted to make sure was that you weren't going to come
12 and offer expert testimony in this case about practices
13 of the Church of Scientology that you're critical of and
14 then to sort of, you know, make the Narconon program
15 seem bad because there's some connection through these
16 L. Ron Hubbard works?
17 A. I didn't intend to talk about issues of harm.
18 I thought it was just enough to say, "These documents
19 exist." Or, "These concepts exist here, they exist
20 there." And if it's a jury trial, let the jury make
21 conclusions.
22 Q. Are there any opinions about the Church of
23 Scientology's practice or beliefs that you intend to
24 offer at the trial of this case that we haven't talked
25 about?
Page 142
2 THE WITNESS: I can't think of any at
3 this time. Again, I've tried to be as clear
4 as possible about what I see my role is, and
5 which is to -- and I do agree that the vast
6 majority ofNarconon Georgia's training
7 materials and course exercises are based
8 primarily on the principles of the Church of
9 Scientology. That I agree with. And I'm
10 happy to stop right there.
11 I wouldn't even say principles. I think
12 direct bon-owings, but -- but more or less I
13 can stop right there.
14 BY MR. MILLER:
15 Q. Well, we have the documents that you've
16 produced to us in Exhibit 2, and we've talked about a
17 few of them. Are any of those documents ones that you
18 would need to specifically point to in order to support
19 your opinions 1 and 2, or -- and I realize that
20 sometimes you pull documents and --
21 A. Yeah.
22 Q. --they aren't necessarily doctUnents you're
23 going to specifically rely upon. I have those separated
24 out. If you want to flip through the ones that you --
25 in their separated-out fonn, I just want to talk to you
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Stephen Alan Kent
January 5, 2012
Page 143
about the ones that you would point to to support the
opinions you're going to give in this case.
Q. But if there're ones that are just general
background, that you're not going to point to to support
your opinions, then I don't need to talk to you about
them. But I would like to identify them.
A. Sure.
MS. FRANKLIN: And if you want to take a
minute to go through them. Take a little
break and --
THE WITNESS: Sure.
MR. MILLER: Let me do this. I will
mark the rest of them as separate documents.
MS. FRANKLIN: Okay.
MR. MILLER: And that may -- we've
already talked about a few of them, but...
purposes, Defendants' Exhibit Nos . 13
through 18.)
(Recess at 2:05, resumed at 2: 15.)
BY MR. MILLER:
Q. Dr. Kent, during the break you were going to
look through the exhibits -- or, the documents that arc
encompassed within Exhibit 2, and identifY any documents
Page 144
in there that you might use to support your opinions in
this case, and I think you've now gotten to the point
where we can do it. And if you wouldn't mind, just
identify by exhibit number and then tell me.
And, for the record, too, what I've done is
I've taken Exhibit 2 and I've broken it down into
individual documents. So maybe what we can do is the
exhibit number and the Bates range of the pages.
A. Forgive me for being slow here; I just ran
across a section I thought I should pay a bit more
attention to.
Okay. And again, I apologize, I just wanted
to check that one document.
I will jump around, unfortunately, with some
of the exhibits, but if we can start with No.--
Exhibit 18. Again, as I got the charge and started
thinking about it, there's nothing in 18 that
specifically relates to this -- to the possibility of
Scientology courses influencing or being part of the
Narconon program.
MR. AMASON: Excuse me, can we get the
Bates numbers when we look at these?
THE WITNESS: Oh, I-- sure. This is
Exhibit 18, Bates number starts at 0821.
MR. AMASON: Thank you.
1\Iin-U-Script Q&A Reporting Services, Inc.
(36) Pages 141 - 144
Desmond, et al. v. Stephen Alan Kent
January 5, 2012 Narconon, et al.
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THE WITNESS: And it goes to 0834.
There's a section in there about
Chilocco, Oklahoma, but this isn't Chilocco,
Oklahoma. So I think we can dispense -- with
what I've seen, we can dispense with anything
in there.
BY MR. MILLER:
Q. Okay. So Exhibit 18 is not going to be --
A. Sure.
Q. -- something you rely upon.
A. Okay. Exhibit 17, which is Bates number 0809
through 0820, is Scientology's submission to the IRS, I
believe, about Narconon's status. And beyond what I--
the vague things I said about it having charitable --
or, nonprofit status, certainly before the IRS decision,
I'm not going to make any big deal out of that one.
Q. Is this just a portion of the submission?
A. Oh, the submission was -- you can see on the
table of contents there was quite a number of other
items included. I just photocopied the ABLE section and
the Narconon section. But I'm not-- I'm not going to
push any issues about the relationship between Narconon
International and this particular program. You know, I
talked a little bit about it in the vaguest terms for
number 3, and that's about as good as I can go right
Page 146
now.
Q. Okay.
A. So part of my comments are based upon this
section, but...
Q. But, again, you're not going to say anything
more about the relationship between N arconon
International and Narconon of Georgia, beyond what
you've already testified to?
A. I'm not going to say anything beyond what I've
testified already.
Q. So that Exhibit 17, then, is simply consistent
with your belief that as part of this dialogue with the
IRS, the Church of Scientology discussed Narconon?
A. That's true. And I believe even before the
IRS decision Narconon had nonprofit status.
Q. And, again, whether that nonprofit status was
based on it just being a charity versus religion you
don't know?
A. I'll leave that open.
Q. Okay.
A. Exhibit 16, which is Bates number 0802 to
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realized if it's got medical issues or medical claims,
I'm just going to stay away from that area. So I don't
plan to raise anything that's right now in Defendants'
Exhibit 16.
Q. Okay. So you're not going to rely on
Exhibit 16?
A. No.
Q. That's conect, right?
A. And we already talked --
Q. I'm sorry. I asked my question poorly.
You're not going to rely upon Exhibit 16 in your
opinions in this case?
A. That's correct.
Now, Exhibit 15 does have a-- this is Bates
0798 through 0801. This is an early Narconon program
that does discuss Scientology's portrayal of the history
ofNarconon. That's a question that came up between us,
so maybe this would be of some value. 1f the history --
if a history ofNarconon comes up in court. So-- I
mean, it came up here, and ...
Q. But it would be fair to say, I think,
Dr. Kent, that your knowledge of the history --
BY MR. MILLER:
Q. Your knowledge about the history ofNarconon
Page 148
1 is based simply on documents you may have read?
2 A. Yes. I don't think, again, with the specifics
3 of what I'm addressed to speak with, I'm not sure it's
4 going to have any real bearing on the case here.
5 Q. And Exhibit 15, it looks like, is an article
6 written by William Benitez as the founder ofNarconon?
7 A. That's right.
8 Q. And he's the prisoner who started a program to
9 help get people off dmgs and alcohol when he was in
10 prison?
11 A. That's true. He was in Arizona state prison,
12 I believe.
13 We've already --1 don't have a Bates number
14 on this, Exhibit No. 3, but this is the-- "Dr. Kent's
15 File Materials" for Desmond, and it lists all those
16 depositions, the ones that I haven't looked at and may
17 or may not even have. And all discovery responses from
18 all parties.
~ 9 Q. Well--
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A. 1 don't have those, so ...
Q. I think that inadvertently got in your
0808, I had copied a section from Celebrity Magazine 22
about how the Purification Rundown works. This has 2 3
stack;--
A. Okay.
24 discussions about drugs in it and so on. And I'm-- you 24
know, again, once I got going on my directions, I 25 25
Q. --we've already--
A. Okay.
(37) Pages 145 - 148
Desmond, et al. v.
Narconon, et al.
Page 149
1 Q. -- talked about that.
2 A. Now ... What is this? Yeah, the reason I
3 included Exhibit 13, which is Bates number 0737 to 0758,
4 was there were some -- if issues came up -- well,
5 nothing's come up about Narconon and the larger
6 scholarship. So as long as I'm not going to get asked
7 about Narconon and the larger scholarship, I won't have
8 to refer to this article. Ifi get asked, there's a
9 question about Narconon and the larger scholarship, then
10 I will refer to this article. But it's not come up in
11 the deposition today, so ...
12 Q. What do you mean by "Narconon and the larger
13 scholarship"?
14 A. This is an article entitled "Alternative
15 therapy, Dianctics, and Scientology." And it looks at
1 6 the sub-social world of Scientology as an alternative
17 medical practice.
18 Q. Okay. But--
19 A. And in that context there are a couple
20 mentions ofNarconon. So just-- I'm not going to refer
21 to it unless somebody were to challenge me and say, "You
22 have no -- no academic basis for talking about your
23 subject," then I would say, "Oh, yes, I do." Hasn't
24 come up, so if it doesn't come up in trial, I won't
25 mention the article. If someone challenges me in hial,
Page 150
1 then I'll mention it.
2 Q. But in terms of an academic basis for your
3 opinions, it doesn't sound like that's necessary for
4 your opinion that these materials are coming from L. Ron
5 Hubbard's writings?
6 A. This atticle doesn't talk about Narconon
7 Georgia, so ...
8 Q. Right. And it doesn't sound to me like you're
9 going to talk about the Narconon of Georgia program one
10 way or the other in terms of its efficacy, or whether
11 it's pseudo medicine or not pseudo medicine, or
12 whether--
13 A. That's -- that's fair enough.
14 Q. As I understood that article, that has to do
15 with -- I think it would be fair to say that Exhibit 13
16 is not going to be something you would need to rely upon
17 to offer any of the opinions that you've identified here
18 today that you're going to give at trial?
19 A. That's true. That's true.
20 Now, Exhibit 14. And this is Bates number
21 0774 through 0797. If the issue were to come up, as it
22 has in the deposition here, about the antipathy that
23 Scientology feels toward psychiatry, on Bates
24 number 0776 there's a discussion about what's called
25 "The Crisis: Drugs; The Solution: Narconon; The Plan:
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Chilocco."
Stephen Alan Kent
January 5, 2012
Page 151
"In mistreating dmg addiction, psychiatry
makes billions, destroying millions of lives in the
process. For the first time in American history, a
social matter--dmgs--is a major concern for the
population. " And it goes on to talk about -- well, "The
Narconon Chilocco New Life Center--an 80-building,
167-acre residential facility--is the biggest project in
our history to create overwhelming public popularity for
Drug Rehabilitation Technology developed by LRH." I
only mark that section because if the issue comes up
about how Scientology sees the value of its program as a
drug-free solution to a drug problem, here's the
statement that helps solidify Scientology's antipathy to
psychiatry.
I included in Bates 0780 -- this is a
statement from-- in a Narconon publication about L. Ron
Hubbard. And I was interested in the fourth paragraph
down. '"Recent research has demonstrated that the
single most destructive element in these societies today
is drugs,' he said in 1979. Always concerned with the
well-being of his fellow man, he engaged in extensive
research in this subject. His years of research and the
success of the drug rehabilitation technology resulting
from it led to the fonnation of a network of centers
Page 152
called Narconon, which exclusively uses his methods."
Now, you know, "exclusively uses his methods"
is pretty much what I'm saying in my submissions. But I
was also interested in the statement about his years of
research. One of the things that comes out about
Narconon is, there's a tremendous number of claims but
there's no production of any kind of research notes or
research protocol or tests or whatnot. So that issue
could come up. Is it in terms of what Narconon's based
upon, there hasn't been the presentation of research
documents, in a naditional scientific sense, that one
might expect when there's so much talk about research.
So that's why I marked that particular number.
And then finally, just on Bates Page 0793,
just to make sure that radiation gets included in a
discussion about purification, there's a picture of an
atomic explosion. So that's why I included these.
Oh, and you've broken down No. 2, so I needn't
go through -- unless I'm mistaken, that's -- unless I've
gotten some papers mixed up, I believe that's all of the
breakdown there is of the No.2 fatter exhibit.
Q. Okay. So going back to Exhibit 14 for a
minute, which is Bates range 0774 to 797?
A. Okay. I don' t have a copy-- oh, I see, I
might in this large pack. I'm sorry, what is the
}lin-U-Script Q&A Reporting Services, Inc.
(38) Pages 149 - 152
Desmond, et al. v.
Narconon, et al.
Stephen Alan Kent
January 5, 2012
Page 153 Page 155
1 number, 07 ... ? 1 A. -- because there isn't the production of
2 Q. 774. You said this would have some connection 2 documents to back up the claims.
3 to your opinions in that Narconon is supportive of a 3 Q. Whether those documents exist or don't exist
4 non-drug, non-psychiatrist smt of solution to drug 4 you just don't know?
5 problems . 5 A. Oh, they don't exist.
6 A. That's how it portrays itself. There's a 6 Q. How do you know that?
7 real -- again, in Scientology there's a very strong 7 A. 'Cause I've talked to so many people who were
8 anti-psychiatry strain. 8 with Hubbard. I'm-- and he never, ever had any kind of
9 Q. And that's a document that looks like it was 9 scientific tests. He never conducted any kind of
10 generated in 1989? If you flip back a couple pages. 10 scientific tests.
11 A. Yeah, there's an ABLE ... 1989 October is 11 Q. So based upon conversations you've had with
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what's written on mine.
Q. And then the document that talks about the
research looks like it's also a 1989 document?
A. Probably so.
Q. I think you said 1979 earlier, but it looks
like Page 779, Bates number 779?
A. Yeah, and 0780.
Q. Right.
A. Yeah.
Q. And it looks like--flip back one page--that's
a 1989 document?
12 other people --
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A. Biographies about Hubbard, reading his --
reading, I mean, hundreds and hundreds of pages of--
there just isn't any of the kind of research and sci --
it's not -- nothing's been published anywhere about--
from Hubbard, to show what his findings were.
Q. Okay, we're talking about two different things
here. You're saying that you're not aware of any
published research by L. Ron Hubbard. That's one--
A. That's very true.
Q. Okay.
A. Yeah; on the bottom of that page it says 1989, 23 A. And I'm not aware of any private -- depends
upon what you mean by "research." yeah. 24
Q. Okay. And you haven't tried to research, I 25 Q. I was going to ask you that question.
Page 154
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Page 156
A. Yeah.
2 there to support the effectiveness of the Narconon Drug
3 and Alcohol Rehabilitation program, have you? 3
Q. 'Cause in your field, for example, your
research can consist of talking to people, right?
4 A. It's nothing that I'm going to bring up in the 4 A. Well, it's a -- yes, but it's -- it's got to
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trial. 5 be done in a systematic way. Now, especially in the
Q. I mean, really, it's not your area of 6 early days, there were a lot of people doing Dianetics
expertise to try to evaluate the effectiveness of a 7 and Scientology. But in terms of doing it
program like this? 8 systematically, you know, keeping records, testing
A. That's correct. 9 hypotheses and so on, none of that was done. And I've
Q. Or any of the medical or physiological issues 10 never seen anything-- it was years ago -- oh, what was
11 that might be concerned with, you know, whether the 11 it called. There were attempts from Scientology to
sauna program or the vitamins assist people in helping 12 enter the field of science. I think there are even one
them to get off drugs? 13 or two very early journals of Journal of Scientology
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A. Yeah. In this context, I had no intention of 14 that were really hying to portray itself as systematic.
discussing any of those issues. So it was more the 15 But in this kind of-- in the Narconon books, there's no
issue about the research claims. But the research 16 citation to any research that Hubbard actually did.
claims, ifl may, you know, in the back of each one of 17 There's constant statements about it, but there's just
these books there's a short biography of Mr. Hubbard, 18 no evidence that he-- to produce the basis for the
and there's always claims about-- about his research. 19 claims.
This is Page 396 of book 1, "Therapeutic TR Course." 20 MR. MILLER: Let me see that blue book,
"His research proved that not only is a 21 if you would please, Rebecca.
person's health hannfully affected by drugs ... " It's 22 MS. FRANKLIN: Sure.
more the issue about research. That one has to take 23 MR. MILLER: Thank you.
these claims of research on faith, --
Q. Okay.
24
25
BY MR. MILLER:
Q. I'm trying to find the biography of...
(39) Pages 153 - 156
http://ReachingForTheTipping ngPoint.net
Desmond, et al. v.
Narconon, et al.
Page 157
Stephen Alan Kent
January 5, 2012
Page 159
1 But, bottom line, Dr. Kent, it sounds like you 1 Q. And that document would be from the 1990s?
2 are not going to offer opinions in tllis case about what 2 A. The 1993.
3 does or does not work in tenns of getting people off 3 Q. The draft settlement agreement, which was not
4 drugs? 4 the final settlement agreement?
5 A. I don't want to go there. 5 A. That's correct.
6 Q. Okay. And you have not made an attempt to try 6 Q. But you haven't done anything to research the
7 to research that issue yourself, nor is that within your 7 basis ofNarconon of Georgia's charitable status?
8 field of expertise? 8 A. No. No.
9 A. I've certainly not done any kind of studies to 9 Q. Or Narconon International's charitable -- or,
10 measure success rates. In this Narconon program or any 10 nonprofit status at the current time?
11 others. 11 A. I have not done any research on it.
12 Q. And then on Exhibit 14, Page 793, the mushroom 12 Q. Nor would that be within your expertise, to
13 cloud, that just relates to the fact that there was a 13 determine what basis either Narconon of Georgia or
14 belief that part of this detoxification could assist in 14 Narconon Intemational might have for nonprofit status?
15 getting radiation out of somebody's body? 15 A. Yeah, 1 don't really foresee going in that
16 A. That's correct. 16 direction. I mean, I've told you what little I know,
17 Q. Okay. Which you talked about earlier? 17 and --about the relational issues. And they're just
18 A. That's true. 18 not clear enough for me to say anything definitive.
19 Q. Have we now talked about all the documents in 19 Q. In the course of this deposition, is there
20 your file that you would point to to support any of your 20 anything else, other than possibly going back and
21 opinions in this case? 21 looking at Exhibit 7 some more, that you would do to get
22 A. "All the documents ... " Now, ifl were to go 22 ready for trial?
23 through these Narconon booklets point by point, there'd 23 A. I'd want to have another run-through of these
24 be a lot more cormections I'd make with Scientology. 24 books. But, other than that, I can't tlllnk of anything.
2 5 Q. I appreciate that. I'm trying to -- 2 5 Q. But if there was no dispute in this case that
Page 158 Page 160
1 A. Yeah. I don't have documents right now, 1 the books that you've reviewed are based on the works of
2 but-- but I'm not planning on going home and fmding 2 L. Ron Hubbard, would there be anything else you would
3 more documents, if that's part of what you're asking. 3 do?
4 Q. It is. 4
5 A. Yeah. 5
6 Q. What I wanted to do is to make sure that, of 6
7 that collection of documents that we've marked as 7
8 Exhibit 2, that we've talked about any documents or 8
9 portions of documents in there that you would point to 9
10 to support any of your opinions. 10
11 A. Yeah, I-- the only other outlier might be 11
12 this IRS agreement. I've read it several times; I 'm 12
13 going to go back and do it. But, again, I can-- you 13
14 know the sum total of what I can say about this 14
15 charitable status issue. 1 think it's an interesting 15
16 one, an important one. I'm not sure finally it has 16
17 bearing upon -- well. So... That's the only thing I'm 17
18 going to go back and look at. Whether or not I use or 18
19 even figure out what it says is another question. I 19
20 don't want to necessarily throw that out, though. 20
21 Q. And your purpose of going back and looking at 21
22 it would be to determine what? 22
23 A. If it's-- if I can figure out if it's a 23
24 charitable status. How its charitable status relates to 24
25 Scientology's charitable status. 25
MS. FRANKLIN: Object to the form.
THE WITNESS: Well, the only concem is
exactly what that agreement -- agreement
would mean. It's hard -- it's put right on
the cover, "Based on the works of L. Ron
Hubbard." I think the question is, well ,
what does that mean in the context of
Scientology being a religion, these documents
bon-owing from a religion, these being
secular. So there's still some areas of
discussion. But I could agree with you that
the Narconon books are based upon the works
ofL. Ron Hubbard.
BY MR. MILLER:
Q. Right. And with the exception of the two
dynanlics that you've discussed in book 6, there's
notl1ing that you've identified in there that would be
religious?
A. At this point I can't recall anything else.
Again, if-- I don't want to waste your time going
through all these books, you know.
Q. Okay. But even if there was something else in
\1in-ll-Scri)Jt@ Q&A Reporting Services, Inc.
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Desmond, et at. v.
Narconon, et at.
Page 161
1 one of these books that would be religious in nature of 1
2 any type, it would be neutral; it would be something 2
3 probably talking about, you know, spirituality or 3
4 getting in touch with a higher being? 4
5 A. Again, I don't want to -- I want to be very 5
6 careful not to get into issues about discussing moral or 6
7 ethical issues about Scientology. Because there's a lot 7
8 of moral and ethical statements. You know, I simply 8
9 want to point out that, you know, the dynamics contain 9
10 two issues that arguably directly mention, you know, 10
11 realms beyond the secular one, and there's some 11
12 discussion of it there. And leave it at that, if... 12
13 Q. Have we talked about all the opinions that 13
14 you're going to offer in this case? 14
15 MS. FRANKLIN: Object to the fonn. 15
16 THE WITNESS: Certainly in the broad 16
17 sense. Again, there's a lot more in the 17
18 books that I could pull out and identifY, but 18
19 it would be more of the same along the lines 19
20 of what we've discussed. 20
21 BY MR. MILLER: 21
22 Q. Well, I want to explore that with you for a 22
23 minute. I mean, when you say "there's ... more in the 23
24 books," I'm assuming that what you mean is that there 24
25 are more things in the books that you could point to and 25
Page 162
1 say, "This is something that I can also find a parallel 1
2 to in the Church of Scientology"? 2
3 A. That's correct. 3
4 Q. But other than that, is there anything else in 4
5 these books, other than specific examples you might find 5
6 to support your second opinion here, which is that the 6
7 majority of these-- 7
8 A. Uh-huh (affirmative). 8
9 Q. --books are based on the principles of the 9
10 Church of Scientology? 10
11 A. I think that's -- you've summarized it very 11
12 well. That I'd find more specific examples, but 12
13 nothing --no new bombshells, you might say. 13
14 Q. Okay. So, with that understanding, have we 14
15 talked about all the opinions that you're going to offer 15
16 at the trial of the case? 16
17 MS. FRANKLIN: Object to the fmm. 11
18 THE WITNESS: With that understanding, 18
19 knowing there's a lot more specifics, I can 19
20 say yes. 20
21 BY MR. MILLER: 21
Stephen Alan Kent
January 5, 2012
Page 163
again and--
A. Sure.
Q. --talk to you about those. You understand
that--
A. I understand, yeah.
Q. I want to make sure that we've covered
everything that's in Exhibit 2.
MR. MILLER: Let's take a short break
and just look at what we've already marked.
I'll tell you what we can do... Go off the
record.
purposes, Defendants' Exhibit Nos. 19 and
20.)
THE WITNESS: The only items I came
across that might be of use is Bates
number 0760 through 0767. These have to do
with assists. I mentioned locational assists
a couple times . May or may not come up.
They're similar to some other kinds of
processes that appear in these -- in these
books.
BY MR. MILLER:
Q. The Narconon books?
Page 164
A. In the Narconon books, yes, sir.
Other than that... And, again, I'll -- other
than what we've discussed, I think we've covered this
Exhibit No. 2 fairly well.
Q. There were two other documents in
Exhibit No.2 that, in my effort to mark them
separately, that I haven't asked you about. Let me ask
you first, Exhibit 19, --
A. Okay.
Q. --if that's anything you're going to be
relying upon?
A. Again, this is from the old historical record,
and since I -- the historical record really doesn't come
to bear in this particular case, so I see no reason to
include it.
Q. So you're not going to rely on Exhibit 19; --
A. No.
Q. --how about Exhibit 20? Is that anything
that you're going to rely upon?
A. I don't think it's any need to, no.
Q. Okay. So just to be clear, I think we have an
2 2 Q. And if you have any additional opinions, will 2 2 agreement that if you come up with any new or additional
23 you let your lawyer know right away? 23 opinions, you'll let your lawyers know right away, and
24 A. Sure. 24 then we have an agreement we can come back and depose
25 Q. And we'll need to come back and depose you 25 you on it.
(41) Pages 161 -164
Desmond, et al. v.
Narconon, et al.
Page 165
1 A. Yes, sir. Yes, sir.
2 Q. And if we don't hear anything between now and
3 the time of trial, it's fair for us to assume you're not
4 going to offer any opinions other than what you've
5 already talked about today?
6 A. Yes, sir, that's --
7 MS. FRANKLIN: Object to--
a THE WITNESS: -- tme.
9 MS. FRANKLIN:-- the form.
10 BY MR. MILLER:
11 Q. And you've completed your work?
12 A. Other than going back through the books.
13 Q. And if you went back through the books to find
14 more specific examples, my understanding would be you'd
15 say, "Okay, there's the word--" --I mean, give me an
16 example of something else that's in there that's ...
17 A. Overt withholds.
1a Q. Okay. And then you would explain what that
19 means in the context of Hubbard's writings and the
20 Church of Scientology?
21 A. Yes, sir.
22 Q. But you would not offer the opinion that
23 because that's in the book, that makes the book a bad
24 book or this a bad program or anything like that?
25 A. That's correct.
Page 166
1 Q. It would just be more examples to support your
2 opinion number 2? --
3 A. Right.
4 Q. --On Exhibit 4.
5 A. And, again, I don't want to get into questions
6 of goodness or badness.
7 Q. Let me ask you about the financial aspects of
a all this. What are you charging for your time in this
9 case?
10 A. 250 an hour.
11 Q. 250 an hour?
12 A. Yes. Yes, sir.
13 Q. Is that for all of the time you've spent on
14 the case?
15 A. Yes.
16 Q. Will that be the same for depositions, trials,
17 everything?
1a A. Yes, sir.
19 Q. And that would mean you've put in about $2500
20 of work before you came to Atlanta, assuming you've
21 spent about --
22 A. About ten hours, okay. Yeah.
23 Q. And then since you've been in Atlanta you bad
24 the meeting yesterday with -- was it Rebecca or Jeff
25 Harris?
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Stephen Alan Kent
January 5, 2012
Page 167
A. That's correct, yeah.
Q. Was there anything they asked you to offer an
opinion about that we haven't talked about today?
A. I'm not sure. I think counsel would know
better than me. And I understand after -- at the end of
a deposition counsel may get a few minutes to ask me
questions, so I don't want to answer for counsel.
Q. No. The--
A. We've had-- I think we've covered a lot.
There's nothing that 1 can think of at this point, but
counsel may have some other-- some related questions.
Q. Well, I just don't want to be surprised at
trial, --
A. Yeah, I understand.
Q. --so if there's something that, based on your
conversations yesterday, or any time, that you think,
"Ah, I think they're going to ask me this question at
trial," I need to know of any --
Q. -- opinions that you--
A. Uh-huh (affirmative). No,--
Q. --reasonably--
A. --yeah.
Q. --anticipate you might be asked.
A. Yeah, no, I understand. I can't think of any
Page 168
questions offhand. Again, we may learn in a couple
minutes.
Q. Well, you've made reference to the books that
you reviewed last night. Let's go ahead-- we marked
one of those, book number 6, as Exhibit 12; let's just
mark the remainder of the books, because I think that' s
something that we wanted to do.
MR. MILLER: I'll get the court reporter
to mark those.
And then, Rebecca, you said these have
been scanned in in some fashion that we can
get these from you?
MS. FRANKLIN: Well, can we agree to use
the scanned-in versions that you've produced
in discovery?
MR. MILLER: Well, the only hesitancy I
have to that would be that these are the
books that he's reviewed.
MS. FRANKLIN: Okay.
MR. MILLER: What we could do is maybe
look at the publication dates or something
and just determine whether it's necessary
to--
MS. FRANKLIN: Right.
MR. MILLER: As long as we have the
:Vlin-U-Scri1>t Q&A Reporting Services, Inc.
(42) Pages 165 -168
Desmond, et al. v.
Narconon, et al.
Page 169
1 agreement that you' ll keep these books.
2 MS. FRANKLIN: Sure, sure, --
3 MR. MILLER: -- and we'll have access to
4 them.
5 MS. FRANKLIN: --of course.
6 THE WITNESS: Uh-huh (affirmative).
7 MR. MILLER: So let's go ahead and mark
8 these as the next series of exhibits.
9 (Recess at 2:54, resumed at 3:00.)
11 purposes, Defendants' Exhibit Nos. 21
12 through 26.)
13 (Thereupon, Mr. Hynes is not present in
14 the deposition room.)
15 BY MR. MILLER:
16 Q. Dr. Kent, during the short break we have
17 marked as exhibits 21, which is book number 1 that you
18 reviewed; Exhibit 23, which is book 4a; Exhibit 24,
19 which is book 5; Exhibit 25, which is book 7, and
20 Exhibit 26, which is book 8, for purposes of
21 identification. And what we've agreed to do is, with
22 these exhibits, including the book we marked earlier as
23 Exhibit 12, which is book number 6, that Rebecca's going
24 to keep those books, we'll all have access to them as
25 necessary, --
Page 170
1 (Thereupon, Mr. Hynes entered the
2 deposition room.)
3 BY MR. MILLER:
4 Q. -- and we can compare these books to the ones
5 that have already been produced in litigation and decide
6 whether there's any need for any of us to get copies of
7 the books.
8 A. Okay.
9 MR. MILLER: Is that agreeable with
10 everybody?
11 MS. FRANKLIN: Sure.
12 BY MR. MILLER:
13 Q. So, for the record, Exhibits 12, 21, 23, 24,
14 25 and 26 will stay with Rebecca.
16 BY MR. MILLER:
17 Q. I think I may have omitted Exhibit 22, which
18 is book number 3 that got marked.
19 Dr. Kent, do you have any idea how Jeff Harris
20 and the plaintiffs' lawyers found you?
21 A. I asked Jeff that. I think he -- I'm not
22 entirely sure. I think he saw a reference to me in a
23 newspaper article.
24 Q. What newspaper article is that?
25 A. It was one-- it was a New York Times article,
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Stephen Alan Kent
January 5, 2012
Page 171
and I'm not -- I know I was quoted in one New York Times
article about Scientology; 1 can't recall if I've been
quoted in any more. But other than that, I'm not sure.
Q. What was the thrust of the article?
A. Let's see, there were -- there were two
ruiicles, and I'm not sure which one I was in, or both.
One was about the IRS agreement, and the other was about
the Lisa McPherson case. This is a case in Florida
where a Scientologist died who was in Scientology's
care. And I'm not sure ifi was in one article or both
articles, and even ifl were, which article Jeffhad
seen. So, I'm sony, I can't give any more specifics
than that.
Q. Okay.
MR. MILLER: Will you mark another
document?
purposes, Defendants' Exhibit No. 27.)
BY MR. MILLER:
Q. I show you what's been marked as Exhibit 27,
which is a list of --
Q. -- Scientology articles from your web site, I
believe?
A. That's true. Okay, this is ... I'd say the CV
Page 172
may be more up to date than the web site, so ...
Q. Between the CV and Exhibit 27 would we have
all of the articles that you've ever written on
Scientology identified?
A. You should. Let me check on one here.
As far as I !mow, everything's listed in the
resume that I published on Scientology. I'm not sure
everything's on the web site yet.
Q. But between Exhibit 1 and Exhibit 27 we have
all of the articles you've written about Scientology or
L. Ron Hubbard or any --
Q. -- organization related to Scientology and --
A. As far as 1 know, that's true, yes, sir.
Q. And all of the written or deposition testimony
you've given would be identified on Exhibit 1, and it
sounds like you've given two depositions before this
case having to do with Scientology; the--
A. I believe that's true, uh-huh (affirmative).
Q. --Williams case in Colorado, and the--
A. Padgett case in Kentucky, l believe it was.
Q. Okay. And you have copies of both those
depositions?
A. I don't have copies of either one of them.
Q. Okay.
(43) Pages 169 - 172
Desmond, et al. v.
Narconon, et al.
Page 173
1 A. At least l -- l surely don't have one from
2 Colorado, and I'm pretty sure I don't have one from--
3 I'm almost entirely sure I don't have one from Padgett.
4 Q. I may have the Colorado one.
5 A. lfyou do, I have to chuckle, because I'd be
6 the one hoping that you give me a copy of my deposition.
7 'Cause I don't have one.
8 Q. Let me just hand you a document. Does that
9 appear to be the deposition you gave in the Colorado
10 case?
11 A. It was taken by Stuart Mann, so ... But I'm
12 certain I don't have this. And unless I'm drawing a
13 brain -- brain blank here, I don't think I ever got a
14 copy.
15 Q. Okay.
16 MR. MILLER: Let's mark this as the next
17 exhibit.
18 THE WITNESS: And I'll get a copy
19 eventually through the... Good, good. Thank
20 you.
22 purposes, Defendants' Exhibit No. 28.)
23 BY MR. MILLER:
24 Q. Exhibit 28 now is -- and I want you to satisfy
25 yourself that that appears to be a true and accurate
Page 174
1 copy of the deposition testimony you gave in that
2 Williams case?
3 A. 2010. I -- it's the right attomeys. I'm
4 sure.
5 Yeah, he's over -- I'm sure that's accurate.
6 For the deposition.
7 Q. Have you spoken to Dr. Roy, who's --
8 A. No.
9 Q. -- another expert in this case?
10 A. No, I haven't.
11 Q. And you haven't seen any repmts or writings
12 from him, have you?
13 A. No.
14 Q. And 1 take it you don't have any plans to get
15 together with Dr. Roy and talk about the case or any --
16 A. No, I don't.
17 Q. Okay. Would you characterize Scientology as a
18 cult?
19 A. Generally speaking, I try to avoid the word.
20 I've used it sometimes. There's a number of different
21 meanings to the word "cult." If one can avoid the term,
22 it just -- you sidestep a whole series of issues. I do
23 think there are a couple times when I thought it was
24 appropriate and I've used it, but, generally speaking, I
25 try not to.
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Stephen Alan Kent
January 5, 2012
Page 175
Okay. But you have in the past sometimes
refened to Scientology as a cult?
A. I'm fairly sure. Now, I'm not sure in what
publication it may have been. I mean, generally
speaking, I avoid it; I'm not going to say I' ve never
used the term "cult," because I just have a little
inkling that somewhere I have.
Q. What, if any, connection or knowledge do you
have about the Cult Awareness Network?
A. And ... ?
Q. Just, what is the Cult Awareness Network?
A. It's outside of what I was asked to talk about
here, so... That's the only reason I'm hesitating. I
don't know that it has any bearing on the case.
Q. I'm not going to ask you very many questions
about it, --
A. Ub-huh (affirmative).
Q. -- but I understand you know or knew Cynthia
Kisser, who was the principal at the Cult Awareness
Network?
A. Yeah. I mean, in this case she's a public
figure, so I can say I did know her.
Q. And I'm just trying to find out, did you ever
work with the Cult Awareness Network in any way, as an
expert, or giving them advice, or providing them with
Page 176
materials, or anything like that?
A. Never as an expert, never as-- in any court
cases. I wrote about a Cult Awareness Network core
case, but it was a year or two after it happened. Maybe
longer. But at the time, no.
Q. What was the case that you wrote about?
A. This was a case brought against the Cult
Awareness Network by a person named Jason Scott.
Q. Was that the gentleman who claimed that he had
been kidnapped and deprogrammed from a Pentecostal
church?
A. Yes, sir, that's the one.
Q. And that was his claim, was the Cult Awareness
Network had kidnapped him and deprogrammed him to try to
persuade him not to be a Pentecostal?
A. Yes, sir.
Q. Okay. And I believe you have described
yourself at some point as "the most vocal academic in
the world" when it comes to discussing what you perceive
as human rights abuses by Scientology? Would that be
the way you've characterized yourself?
A. 1 can't remember saying it, but it certainly
is something I could say. Ifl --so I can't tell you
if I said it at a particular time. There is a-- "the
most vocal academic --"-- I don't know, there's --
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Desmond, et al. v.
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Page 177
1 there's an academic who's not really in the field of
2 studying religious groups who in many ways is I think
3 much more aggressive about Scientology than I am. And
4 that's David Touretzky. There was a very strong article
5 written against Scientology, using words I have never
6 used, and phrases, by an Israeli academic named Benjamin
7 Beit-Hallahmi. His last-- so it's B-E-1-T, hyphen,
8 H-A-L-A-H-H-M-1 [sic], I think? Beit-Hallahmi. Who's
9 at Tel Aviv. Tel Aviv University. And he published an
10 article in Marburg Journal of Religion. And I think his
11 statements were much, shall we say, stronger than
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Q. Watch the staple.
A. -- this is not --
Q. Watch the staple.
Stepben Alan Kent
January 5, 2012
Page 179
12 anything I've written. You know, I try to keep a fairly 12
13 low-key and balanced tone, and he was really blasting. 13
A. Okay, sure, thanks. This is not the copy that
got pub -- there' s an article that he published in the
book. Now, this may be -- so we don't know which
edition this is, if any. But what I'm looking for here
is footnotes. And the footnotes -- see, this is -- this
is just an article. It doesn't-- it has no indication
that it's ever been published, and, in essence, anybody
can write an article. Now, he did write an article
attempting to refute me in a book. The reason I'm
looking at this article--and the published version is
14 Q. Would it be fair to say, though, that your
15 views you've written about Scientology have been
16 somewhat controversial in the academic community?
17 A. It's raised some contToversy with some people.
18 Q. There are people who have published things
19 being critical of your methodology and the manner in
20 which you've reached your conclusions?
21 A. Do you have a specific?
22 Q. I think Dr. Lome Dawson, for example,
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A. Yeah; but if you can provide me with the
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Page 178
Q. Do you know Dr. Lorne Dawson?
A. I do.
Q. And who is he?
A. He's a sociologist at University of Waterloo
in Waterloo, Ontario.
Q. Was he a colleague of yours when you were at
the University of Waterloo?
A. No; we were colleagues in graduate school. I
was a year or two ahead of him, so was a slight bit
older.
Q. He makes the statement in a paper that, "To
the surprise of many, Stephen Kent and Benjamin--"--
A. Beit-Hallahmi.
Q. Well, it's Z-A-B --
A. Oh, I'm sorry.
Q. Z-A-B-L-0-C-K-1?
A. Zablocki.
Q. " ... are seeking to reconceptualize and
reestablish brainwashing or coercive persuasion as a
legitimate social scientific concept, reversing the
results of 20 years of academic and legal struggle
between sociologists, religion, and others in the
anti -cult movement."
A. Would you mind if I had that copy of that
paper, just-- first, --
14 different, because I didn't see any footnotes or end
15 notes here--is in the published aliicle he identified--
self-identified that when he wrote this he was doing
consulting work for Scientology.
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Q. Well--
A. He did not mention in here whether he got paid
or how much he got paid. So, you know, the ar -- and
then I responded to these criticisms in the same
publication.
Q. I guess my question is just a little more
24 basic, Dr. Kent, which is, is it fair to say that there
25 has been some controversy in the academic community
Page 180
1 about some of the conclusions that you've drawn about
2 Scientology?
3 A. Well, if you can cite any more about the RPF,
4 I'd be happy to see them in published accounts. And,
5 again, you know, we have to keep in mind the source
6 here.
7 Q. Well, just so we all know what we're talking
8 about, this is a paper by Lorne Dawson, who's an
9 associate professor of sociology and religious studies
10 at the University of Waterloo, entitled "A
11 Methodological Critique of Stephen Kent's 'Brainwashing
12 and Scientology Rehabilitation Project Force.m Which I
13 guess refers to some paper that you'd written earlier?
14 A. In the book I've got an article for this --
15 before Lome Dawson's that talks about what I called
16 brainwashing in two different groups. One was in the
17 Rehabilitation Project Force in Scientology, which I had
18 mentioned earlier, which is, at least as I portrayed it,
19 the reeducation program in Scientology that's equivalent
20 to a penal system. And there was another group,
21 Children of God, that had a program especially against
22 teens. Lome wrote this response, but, again, citing a
23 paper isn't good enough, because it doesn't have the
24 cmcial information that I need in it to respond
25 appropriately. And then there was my response to his
J Fischcr@QAReporting.com
(45) Pages 177 - 180
Desmond, et al. v.
Narconon, et al.
Page 181
1 that specifically addresses some of the methodological
2 critiques he made. So this is not a good -- that's not
3 going to get us too far in understanding what that
4 particular debate is.
1
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Stephen Alan Kent
January 5, 2012
Page 183
a Ph.D." And I said, "What? He signed Ph.D. on this.
I've got it here in writing, Ph.D." So I made phone
calls around, and it turned out he had had his Ph.D.
revoked. I think it was the University of-- I think he
5 Q. Okay. Well, again, I'm not trying to ask you
6 to agree or respond to what Dr. Dawson said. I'm just
7 trying to determine if there has been academic debate
s about some of yow- theories about Scientology?
5 was at Syracuse and then University of North Carolina.
6 I don't know; one of them had revoked his Ph.D. So
Lewis committed academic fraud there. 7
B
9 A. That's the one that I know of, in terms of the 9
10 RPF work. Now, there was a response, I wrote an a1iicle 10
11 in the Marburg Journal of Religion, and a Scientologist 11
12 responded to that article, and I responded to her
13
14
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17
response.
Q. How about--
A. But she's not an academic, really.
Q. How about James R. Lewis; are you aware of any
criticism that Mr. Lewis has?
12
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15
16
17
Q. Okay.
A. And he was running his own organization.
Subsequently, he now claims to be a Ph.D. I think he
says he got it in a school in Wales someplace. And the
last I heard he bad some kind of appointment in ...
Scandinavia? Norway, perhaps?
Q. How about Dr. Anson Shupe?
A. He's a sociologist at Indiana.
Q. Has he had criticisms of some of your work?
A. He got ahold of-- when the Cult Awareness
18
19
A. James Lewis. I knew him years ago. I
probably first met him back in the late '80s. We're 19
18 Network collapsed and got bought by Scientology and
Scientology interests, he inherited all the -- all the
Cult Awareness files. Now, I ctiticized Shupe-- these
are long stories. These are kind of the academic
debates that go on, though. I criticized Shupe for his
expert testimony in the Jason Scott Cult Awareness
Network case. So--
20 about the same age. The crucial issues with James Lewis 20
21 and me came up in 1993 when I had written at the time, 21
22 along with a student, an article on a group called the 22
23
24
25
Children of God. This is an article that was scheduled 2 3
to be published in the Review of Research and the 24
Sociology ofReligion --I'm probably not getting the 25 Q. That's the deprogramming of the Pentecostal?
Page 182 Page 184
1 A. That's right. That's right. So I criticized 1
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title correct. It was an annual publication. And the
article was -- initially was called "Lustful God." And
it was an article about David Berg, who was a leader of
the Children of God. The publishers sent out a copy of
the table of contents as an advertisement. And an
academic in Britain got it, contacted the Children of
God, and said, "This a11icle's about to appear."
Apparently the Children of God-- either the academic or
the Children of God contacted James R. Lewis.
2 him, be responded, and then, you know, we responded. So
3 we had this series of unpleasant exchanges. He then
4 published a book, I think it's called The Agents of
5 Discord, which is about the Cult Awareness Network. And
there's a whole -- there's a section in there tl1at 6
10
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a
9
Q. Who is James R. Lewis? 10
A. Well, that's kind of where I'm going with 11
12 this. And James Lewis included a one-page letter, along 12
13 with I think a seven-page letter that the Children-- 13
that the Children of God wrote, and a one-page letter 14
the attorneys wrote for the Children of God, and at the 15
time he had no academic appointment. So he signed it 16
James R. Lewis, Ph.D. Okay, fme. A couple years 17
passed, and I got sufficiently frustrated with what I 1B
14
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19 thought were inappropriate interventions against my work 19
that I wrote, along with a graduate student at the time, 20
an article that documented some of these activities. 21
And in the reviews I mentioned that Dr. Lewis had 22
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written a letter. And two of the peer review letters 2 3
24 came back and said, "That's Mr. Lewis." And another one 24
said, "We might as well get it straight; he doesn't have 25
23
25
has -- I don't know, I can't remember how long it is,
I'm going to say a couple paragraphs, no more than a
page, against me. And when I read it, he got fact after
fact after fact wrong. A lot of it was about my trips
to Germany and talks before a German Bundestag, a
parliamentary committee, about-- about sex cults, and
they called them psycho groups. And he just got-- he
got -- he didn't have the book -- he didn't have the
final report from the Gem1an government in front of him,
and he made assumptions about what I said. He didn't
know that the Gem1an report quoted me in one section,
actually about the RPF. So-- so Shupe-- and I've
responded to Shupe in this last item that came out on
Scientology in a German festschrift, a series of essays
in honor of a particular person. These festschrift was
in honor of a person named Thomas Gandow, G-A-N-D-0-W,
who's the initial person who brought me over to Germany.
He retired, they asked for essays in his honor, I wrote
something, and then I thought, "I might as well try to
(46) Pages 181- 184
Desmond, et al. v.
Narconon, et al.
Stephen Alan Kent
January 5, 2012
Page 185 Page 187
1 at least get in print my response to Shupe." So... 1 my work. So there's a bias there.
2 Q. How about Dr. Gordon Melton? 2 Q. Okay. Of cowse, you would say that he's
3 A. Gordon Melton is not a-- a tenured faculty 3 biased because he brings a religious perspective to the
4 member. As far as I know, Gordon Melton is a Ph.D., I 4 work, I suppose?
5 think in something like church history or religious 5 A. I've seen it in various aspects of his work,
6 history, something. He's an ordained minister. He is 6 yes.
7 the director of the Institute for the Study of American 1 Q. Are there other academics that you're aware of
8 Religion that's based out of-- his collection is in the 8 who have been critical of any of your work or opinions?
9 University of California at Santa Barbara, but as far as 9 A. Well, there's an article that came out in a
10 I know he's not a faculty member. So he's not-- he's 10 journal called Religious Studies and Theology, by Susan
11 done a lot of consulting work for both Scientology and a 11 Rain, that looked at surveillance in Scientology, and
12 number of other groups. You know, we could get into 12 she quotes favorably my RPF work. So it would be
13 reasons why. In part, he doesn't get an academic 13 misrepresenting to believe that it is all, you know, me
14 paycheck, so he's got to get income from somewhere, and 14 against the world.
15 he gets it from books. He's published a number of 15 Q. Well, I guess all I'm trying to establish,
16 books. And-- but he's done consulting for a lot of 16 which I think is true, is that among academics there are
17 groups too. 1 7 different points of view and disagreements, and that's
18 Q. Going back to my original question, what I'm 18 normal in the academic world, and you have a point of
19 really trying to determine is whether there has been 19 view, and there are people who oppose your point of view
2 o some dispute in the academic community about some of 2 o on a number of points and you oppose their point of
21 your opinions about the Church of Scientology? 21 view. I mean, would that be fair?
22 A. Yes; but you have to identify what the 22 A. Yeah, but they're on different issues. I
23 academic community consists of. See, Gordon Melton, you 23 don't know that anyone else in an academic peer-reviewed
24 know, is a player, but he's not-- he's not an academic, 24 joumal has criticized the RPF work. Now, Dawson, you
25 in the sense that he doesn't have a-- he's not 25 know, they're collections of book essays, and the peer
1
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Page 186
university-appointed.
Q. Okay. He's not doing academic work at this
Institute of--
A. He does a range of work. I mean, he's
Page 188
1 review process gets a bit murky in books. Sometimes
2 book articles get sent out to outside reviewers. I
3 don't think this one did. I think it was just the
5 certainly published some in academic journals, but he's
6 done some-- a number of apologetic pieces. --
4 judgment of the two editors. So Lome Dawson's article
5 was in there; does it have the weight of the peer-review
6 article, probably not.
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Q. Well, it sounds -- 1 MR. MILLER: Let me do this. I'm almost
A. -- Including some for Scientology. 8 done. Sean has to go in a minute.
Q. Well, it sounds like you would question James 9 I don't know, Sean, did you want to ask
Lewis's credentials for the reasons you've -- 10 any questions before you go?
A. Uh-huh (affinnative). 11 MR. HYNES: I just have a couple.
Q. --stated, but do you question Anson Shupe's
credentials or Gordon Melton's credentials in tenus of
12 MR. MILLER: I mean, if it's okay --
13 MS. FRANKLIN: That's fine.
being well-educated and having expertise -- 14
A. I don't-- 15
Q. --in religion-- 1 6
A. -- question Shupe's educational background; I 17
question his use of facts and his -- his judgment. At 18
least with regard to responding to my publications. 19
Gordon Melton seems to have a religious bias 20
in his work. And in scholarship, it seems to me that 21
some people believe that bad theology is one thing, but 22
a secular approach is even worse. And my impression 23
about Gordon Melton is that he is not supportive of all 24
secular interpretations, which is what I try to bring to 25
MR. MILLER: -- with you, Rebecca, I'd
let him.
THE WITNESS: Sure.
EXAMINATION
BY MR. HYNES:
Q. I represent Delgado Development. As I
understand what you said earlier, you don't have any
opinions or criticism regarding the housing in this
particular case; is that correct?
A. I'm not going to discuss the housing issue at
all.
Q. And you don't have any opinions, criticisms
M in-U-Script Q&A Reporting Services, Inc.
(47) Pages 185 -188
Desmond, et al. v.
Narconon, et at.
Page 189
1 that you're going to express in this case regarding
2 Delgado Development; is that also true?
3 A. I'm not going to express any criticisms or
4 anythjng about Delgado Development.
5 Q. Okay. Thanks.
6 A. Sure.
7 MR. MILLER: I need to ask Helena a
8 question, and I think I may be done.
9 MS. FRANKLIN: Okay.
10 MR. MILLER: Do you have -- are you
11 going to ask him some questions?
12 MS. FRANKLIN: Yes, I'm going to have
13 follow-up.
15 (Recess at 3:3 1, resumed at 3:33.)
16 MS. FRANKLIN: Before I begin asking
17 Dr. Kent some questions, l'd like for
18 everybody to put on the record who they are
19 and who they are here representing or here on
20 behalf of.
21 MR. AMASON: Jeff Amason; I'm
22 representing Dr. Robbins.
23 MR. HYNES: Sean Hynes, Delgado
24 Development.
25 MR. MILLER: Steve Miller and Helena
Page 190
1 Kobrin here on behalf of Narconon of Georgia.
2 MS. KOBRIN: Narconon International.
3 MR. MILLER: I'm sorry, I'm sorry,
4 Nar--
5 MS. KOBRIN: Narconon International.
6 MR. MILLER: I'm sorry, 1 miss poke.
7 EXAMINATION
8 BY MS. FRANKLIN:
9 Q. Dr. Kent, I just have some follow-up questions
10 for you. First of all, you just heard that Ms. Korbin
11 is here apparently on behalf ofNarconon International;
12 do you know Ms. Korbin?
13 MS. KOBRIN: I'm sony, my name is not
14 Korbin.
15 MS. FRANKLIN: I'm sorry, how do you
16 pronounce it?
17 MS. KOBRIN: It's Kobrin.
18 MS. FRANKLIN: Kobrin, I apologize.
19 BY MS. FRANKLIN:
20 Q. Do you know Ms. Kobrin?
21 A. We've never met.
22 Q. Okay. Do you know of her?
23 A. I do.
24 Q. Do you know what she does for a living?
25 A. She's an attorney, I beli eve in partnership
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Stephen Alan Kent
January 5, 2012
Page 191
with Kendrick -- Kendrick Moxon.
Q. Okay.
A. She did give me a card, and it says Moxon &
Kobrin, so ...
Q. Okay. And do you know what her practice area
is?
MR. MILLER: Object to the form of the
question.
THE WITNESS: I know she handles a
number of -- has handled in the past a number
of Scientology-related cases. I can't tell
you which areas of law.
BY MS. FRANKLIN:
Q. Do you know where her practice is located?
A. I' ve always assumed that it's through
Los Angeles.
Q. Okay. Dr. Kent, you were asked a nwnber of
questions generally about the course materials which are
Defendants' Exhibits 21, 22, 23, 24, 25, 26, and 12, and
you said you reviewed these materials yesterday or last
night, correct?
A. That's right.
Q. What were you looking for?
A. I was looking for connections between what was
in these documents and Scientology concepts, procedures,
Page 192
techniques, defmitions, et cetera.
Q. And in your review did you see anything within
these materials that is not based on the teachings of
Scientology?
A. Every major concept in these books seemed to
be based upon Scientology.
Q. Okay. And you weren't asked many specifics
about all of the books, and I'm not going to ask you to
go through, page by page, each of them, but you did
mention that you saw a number of l think you said
"classic Scientology terms"; is that right?
A. Oh, sure.
Q. And if at trial you're asked to discuss those
terms, Scientology terms, and how they fit into the
beliefs and practices of the Church of Scientology,
you're prepared and able to do that, conect?
A. Yes.
Q. And same thing with the different teachings
within these books; you're prepared to, you know, talk
about any one that you're asked about and how that
particular teaching or lesson fits into the beliefs and
practices of the Church of Scientology, right?
A. Let me trunk. Yes, as long as they don't
drift-- as long as they don't have to drift into
discussions about morals or ethics or whatnot.
(48) Pages 189 - 192
Desmond, et al. v.
Narconon, ct al.
Page 193
1 Q. Okay. 1 understand that.
2 A. Yeah.
3 Q. I'm just going to flip through some of these
4 and just ask you a couple questions about each one.
5 Let's start with book number 1. First of all,
6 it's titled "Therapeutic TR Course." Is there a course
7 in the Church of Scientology called "Therapeutic TR
8 Course," or something similar?
9 A. I think it's called "The Communications
10 Course.''
11 Q. Okay.
12 A. lt includes the TRs.
13 Q. And just tell me generally, what are TRs?
14 A. They're training routines. They're exchanges
15 that go on between a client and what's called a coach.
16 Q. And the Church of Scientology uses the term
17 "TR," correct?
19 Q. All right. And I'm just looking at tills one,
20 it's TR 8, on Page 333, and some of the depositions,
21 which I understand you haven't read, talk about a TR
22 where the students are asked to sort of shout at an
23 ashtray. Are you familiar with that?
24 A. Oh, sure; that's a well-known TR in
25 Scientology.
Page 194
1 Q. Okay. And if you can just generally tell us
2 how that particular TR fits into the beliefs and
3 practices of Scientology?
4 A. Well, Scientology sees the TRs--well,
5 especially this TR--as trying to get a person to project
6 intention into a particular target. And in this case
7 the target, for practicing purposes, is supposed to be
8 an ashtray. The person is supposed to project his or
9 her intention in a very firm, clear, loud manner. You
10 know, tell the ashtray to stand up and fix it up, and
11 tell the ashtray to sit down, and so on. What it means
12 in a larger case of Scientology, well, on the one hand
13 in Scientology one - especially as one moves up -- up
14 the bridge, one gives and receives a Jot of orders and
15 commands and directives. And that one interpretation,
16 at least, is that the TRs are preliminary training for
17 those processes. You know, how to give direct orders,
18 how not to be dissuaded from them, how not to be
19 djssuaded from the path if one starts bullbaiting or
20 making criticisms about a person's appearance, or -- or
21 distractions or so on. So it helps prepare the person
22 for the kinds of exchanges one will experience later on.
23 There's even courses about -- in the TRs about moving
24 people around. You know --
25 Q. Explain that to me.
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Stephen Alan Kent
January 5, 2012
Page 195
BY MS. FRANKLIN:
Q. Doctor, do you remember where you were in the
process of answering that question?
A. Yeah, we were talking about TRs and what their
signjficance is in Scientology. Scientology also
believes that people who have had traumatic events are
not oriented into what is called present time. So some
of the TRs are supposed to get a person oriented towards
the here and now. And they're important-- Narconon
offici als or somebody--Scicntology officials, Narconon
officials--must think the TRs are important, because
they reappear in the Narconon program. So people go
through the TRs a second time later on.
Q. Based on your understanding, are the TRs in
the Narconon materials any different than the TRs in the
Scientology course books?
A. The only difference 1 saw is that in the
Narconon booklet it talks about TR9. But TR9 is
actually just a repeat ofTR6b, if I'm not mistaken.
Now, I've never seen a mention ofTR9. But because it's
a repetition ofTR6b, I don't put a whole Jot of weight
on its existence.
Q. Okay. And on Page 368, and it's discussing
TR8, the direction is, "The student now does TR8 with
Page 196
ills twin." Is the tenn "twin" a Scientology term?
A. Oh, sure; it's an assigned person to go
through the -- with whom one goes through the courses.
Q. Okay. Now, Defendants' Exhibit 22, which is
the "Learning Improvement Course 3," is that a course
that members of the Church of Scientology go through?
A. I -- they wouldn't -- I don't think they go
under it in that name, but certainly the content they go
through.
Q. Okay. And on Page 114 of Defendants'
Exhibit 22, there's a discussion of "working things out
in clay." Are you familiar with this sort of drill?
A. Oh, sure, yes.
Q. And is that a principle or a drill practiced
by the members of the Church of Scientology?
A. It is. The concept behind it is that one
should bring mass, or something physical, to ideas. The
example used in the book is that you can talk about a
tractor, but until you actually see and touch a tractor
you really don't know what it is. The working with clay
is one form of bringing a mass to ideas.
Now, other forms involve doing demonstrations
with whatever items one has. Sticky notes, a pencil,
paper clips, a rubber band, or so on. But it's still
the same basic principle.
( 49) Pages 193 - 196
Desmond, et al. v.
Narconon, et al.
Page 197
Stephen Alan Kent
January 5, 2012
Page 199
1 Q. Exhibit 23, which is 4a, the "Communication 1 negative ones. The person subverts an environment which
2 and Perception Course." Is that a course that members 2 he or she is in. Addresses a wrong target. You know,
3 of Scientology may go through? 3 if something goes wrong, he or she blames the wrong
4 A. Let me look at this, because this is-- if I'm 4 person. Speaks in generalities. Will say, you know,
5 not mistaken, this is for all the-- okay. The 5 "they say" as opposed to a social personality, who he
6 objectives are here, and objectives are standard 6 specifically identifies by name that Joe Blow said.
7 Scientology practices; again, these are ones that 7 Person is opposed to any beneficial social action, and
B Hubbard said would be useful for people who have been on a it goes on and.on like this. And the parallels in the
9 drugs to bring them up to present time. Now, I 9 social personality are the opposite. People who work
10 thought-- yeah. I thought this was the one-- yeah, 10 for the betterment of society; who speak in specifics;
11 you're back -- but also you're back to the training 11 who, when transmitting communications, don't make it
12 routines in this book. 12 worse, but make it a bit easier for the person to hear
13 Q. Okay. And training routine number 6 describes 13 who is going to receive the communication. So it's
14 a dtill where it sounds like the students look at a wall 14 things like that.
15 and then go touch a wall and then look at a wall. Are 15 Q. And so is it fair to say that in Scientology
16 you familiar with that training routine? 16 people may be declared an SP, a suppressive person?
17 A. It's a-- it's done in Scientology. 17 MR. MILLER: Object to the form.
18 Q. Okay. What's sort of the purpose, or-- 18 THE WITNESS: Well, in Scientology
19 relating to the beliefs and practices of Scientology of 19 people do get declared to be SPs, or
20 that drill? 20 suppressive persons, and Hubbard made an
21 A. Well, it seems like it's a variation on the 21 association, which actually appears in the
22 location. It's again to make sure a person gets brought 22 Narconon books, between being an SP and being
23 into present time. 23 psychotic. Now, it's not necessarily the
24 Q. Okay. 24 case that a psychotic means the same for
2 5 A. Some variations on that drill involve a 2 5 Hubbard that it might mean in a psychiatric
Page 198 Page 200
1 person, one's twin, walking around with one. So to 1 context. But he does use the term. So an SP
2 physically take one up to a wall and get the person to 2 is an enemy of all things good.
3 touch it. I think some of the walking is not 3 BY MS. FRANKLIN:
4 necessarily involved in touching, but some of it is, so 4 Q. Okay. Now, on Page 269 under the title
5 gently taking hold of a person's arm and walking the 5 "Handling the potential trouble source," there's a tenet
6 person up to the wall. 6 or a ptinciple that discusses illnesses and what they
7 Q. But it's a Scientology concept? 7 stem from. And I'm just going to read from it. Says
8 A. Oh, sure. Sure. 8 that "All illnesses, in greater or lesser degree, and
9 Q. All right. And then Defendants' Exhibit 24, 9 all foul- ups, stem directly and only from a PTS
10 "The Ups & Downs in Life Course." Book number 5. Is 10 condition." Is that a Scientology principle?
11 that a course that members of the Church of Scientology 11 A. Yes.
12 would go through? 12 Q. And just generally if you can explain that
13 A. Well, the -- what you get in here is the -- if 13 principle to us.
14 I'm not mistaken, this is the booklet that discusses the 14 A. People who are not antisocial personalities
15 social personality, the antisocial personality and the 15 but who are associated with them get a lot of the
1 6 potential trouble source. They're standard -- they're 16 negativity from the suppressive people. And the problem
17 Scientology te1ms; there's actually a Scientology course 17 becomes when a -- that potential trouble source is
18 called "SP/PTS." 18 associated with a Scientologist or a person in a
19 Q. Just explain to us generally what an SP and 19 particular group and has to receive the criticisms,
20 PTS is, and how that fits into the beliefs and practices 20 through the PTS, of that particular program or
21 of the Church of Scientology. 21 activities or behaviors or belief and so on. And so, in
22 A. The booklet identifies at least 12 22 order-- in Scientology you can't progress in courses if
23 characteristics for an SP, and then 12 mirror 23 you have-- if you're associated with a PTS. You've got
24 characteristics for a social personality. And the 12 24 to deal with the PTS in some way. You've got to get the
25 characteristics for an antisocial personality are all 25 PTS to realize what he or she is doing and then stop.
(50) Pages 197 - 200
Desmond, et al. v.
Narconon, et al.
Page 201
1 You've got to handle the PTS in some way, and if those
2 techniques fai l, then you're allowed to disconnect from
3 the PTS.
4 Q. Okay. This may be a little out of order, but
5 is there any principle or tenet in Scientology relating
6 to the discussion of the Scientology tech among its
7 members, or externally?
8 A. Uh-huh (affirmative). You'll notice in the
9 course pack that if one's having trouble, then there
10 are -- then the course pack gives three explanations as
11 to why. The big issue is the misunderstood word. The
12 claim is that a person has gone past a word that he or
l3 she didn't understand, and in doing so bas disrupted the
14 ability to engage in the material.
15 At no time can a person who has questions go
16 to, say, a case supervisor and get the case supervisor
17 to explain with a for-example. The only discussions in
18 Scientology involve a case supervisor either helping a
19 person find a misunderstood word or pointing the
20 individual to the exact Hubbard policy letter which
21 outlines the doctrines. This kind of explanation that
22 would go on in a classroom, where one might try to draw
23 analogies outside of the particular example, cannot go
24 on in Scientology.
25 Q. Okay. What about criticisms of Scientology?
Page 202
1 Is there some sort of principle or guideline relating to
2 members' criticisms of the church?
3 A. If someone hears you criticizing Scientology,
4 the person is supposed to do a knowledge report on you.
5 To write you up. You know, it's out -- it's out ethics.
6 Q. Okay. And just explain to us generally what
7 "out ethics" means.
8 A. You know, ethics is, you know, to keep
9 Scientology working, and even if there are problems, to
10 keep the problems internal. Out ethics is doing
11 something that has the potential for hmting, damaging
12 Scientology's ability to progress and develop and so on.
13 And these knowledge reports are write-ups of a person
14 who knows about some out ethics phenomenon that's going
15 on, hence the term "knowledge report."
16 Q. And ifNarconon bas a policy against
17 criticizing the Narconon program, meaning that a person
18 may be out ethics if they criticize the program
19 internally or externally, would that be consistent with
2 0 the teachings of the Church of Scientology?
21 MR. MILLER: Object to the fotm of the
22 question.
23 THE WITNESS: Well, yeah, you can't --
24 you know, you can't object to Hubbard's
25 writings. There's -- there's no movement
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Stephen Alan Kent
January 5, 2012
Page 203
inside Scientology that allows for discussion
or an augmentation of Hubbard's writings, a
variation. What's written is true, according
to Scientologists. So there can' t be any
criticism or any kind of-- any kind of
variation from them.
BY MS. FRANKLIN:
Q. And is that why there's little variation
between these course books and the courses in
Scientology?
question.
THE WITNESS: Well, that certainly makes
sense to me. I mean, you can't have -- you
couldn't have course books that are -- that
are based upon L. Ron Hubbard without
actually using L. Ron Hubbard. You know,
Scientology is very careful about how groups
use Hubbard technology. You know, the
perspective is that it's the road to total
freedom. It's not a road, it's the road. So
it's got to be followed precisely as Hubbard
laid it out.
BY MS. FRANKLIN:
Q. Defendants' Exhibit 25 is comse book
Page 204
number 7, which is "Changing Conditions in Life Course."
Is there a similar or exactly same course that members
of the Church of Scientology may go through?
A. Yeah, I j ust want to make sure this is all the
conditions -- oh, yeah, these are the conditions -- the
conditions are standard doctrines in Scientology. I
mean, they're fairly basic to the organization.
Q. Well, just explain what conditions -- you
don' t have to list the conditions, but what does the
term "condition" mean in the context or the beliefs and
practices of Scientology?
A. Yeah, I have to use my own words. It's always
best to use Hubbard's, but in this case I'll have to use
my own. The conditions are descriptions of one's
relationship to, you might say, one's responsibilities.
This relationship can be on the straight organizational
level, but it also involves bow an individual relates to
his or her, say, job assignment. Or even his or her
relationship with, you know, family and so on. So the
conditions lay out how one is performing what one should
be perfonning, or how an organization is performing and
what it should be performing.
Q. And are those also found in the Narconon
comse --
A. Oh, --
(51) Pages 201 - 204
http://ReachingForTheTippiing n Point.net
Desmond, et al. v.
Narconon, et al.
1 Q. --materials?
Page 205
2 A. --yes. The-- it seems to me theNar --
3 well, the Narconon --the conditions laid out in
4 Narconon are exactly the same as I found-- as I know
5 exist in Scientology.
6 Q. What does the term "technology" mean in
7 Scientology and/or Narconon materials?
8 A. It's probably --I guess, again, using not
9 Hubbard's term but my own, it's probably the sum total
10 of the techniques, methods, definitions, the
11 applications of Scientology beliefs and principles into
12 a particular situation.
13 Q. And did you see that term used similarly in
14 the Narconon materials?
15 A. "Technology"? I don't recall, just because
16 it's so common.
1 7 Q. That's fme, if you don't recall.
18 A. Yeah, I don't... I could very quickly check
19 some other books, but it's sometimes just referred to as
20 "the tech."
21 Q. "The tech"?
22 A. T-E --T-E-C-H.
23 Q. Okay.
24 A. I'm just looking in the indexes. Well,
25 here--
Page 206
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A. No.
Q. But you mentioned indexes. Is there a
glossruy or an index at the end of each of these course
material books?
A. There is. I believe it literally is at the
end of each one.
Hand me those two. Thank you.
There's "technical." "Having to do with a
learned procedure or skill."
Q. Uh-huh (affmative).
A. Not quite the same, but it's close. No.
Q. All right. Defendants' Exhibit 26 is book
Stephen Alan Kent
January 5, 2012
Page 207
1 A. Well, they -- they can pay to take it, but
2 it's also-- "The Way to Happiness" booklet is a
3 dissemination booklet for Scientology.
4 Q. Okay. And what do you mean by that?
5 A. It's another one of these long academic
6 explanations. Back in the early part of the 20th
1 century there was an author not related to L. Ron
8 Hubbard, his name was Elbert Hubbard. Well-known for
9 popularizing of writings and so on. And earliest years
1 o of the -- I'm thinking around 1902, but I could be off
11 about the date, he wrote a pamphlet called "A Message to
12 Garcia." This was supposedly a message that a military
13 commander of some sort gave to an underling to take to a
14 person named Garcia, who happened to be a rebel fighting
15 in the jungles. Without question, the individual took
16 the command, and spent two years, found Garcia, gave him
17 the message, and Elbert Hubbard's "Message to Garcia"
18 booklet got reproduced by many, many companies. These
19 companies wanted to convey to their employees that if
2 o you get a command, a directive, you should do it. You
21 know, even if it's hard to do, "Look what this soldier
22 went through to find Garcia."
23 Now, Hubbard knew about Elbert Hubbard.
24 He's-- I think it's in one of the early Dianetics --
25 one of the earliest Dianetics books, the books dedicated
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Page 208
to Elbert Hubbard. So he certainly knew about Elbert
Hubbard. And L. Ron Hubbard wanted some sort of
document he could portray to the public that was secular
in nature that would spur their interest in what
5 Scientology was. So it's a booklet, and the hope
6 was--and it has happened, I believe, in some cases--that
companies would then reproduce it and give it to their
employees and so on.
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Q. So it's a ...
A. Yeah, it's a statement of a -- of morals and
ethics. Just for what it is, you know, on the surface.
I think the behind-the-scenes story, it's a way of
getting Hubbard's name into a secular environment.
14 number 8, and it's "The Way to Happiness Course." Is 14
15 this a course that members of the Church of Scientology 1 5
16 are offered? 16
Q. Okay. So we just discussed a couple of just
different things in each of these course books, but as
you said before, you're prepared to discuss other
principles or tenets of the Church of Scientology and
how they're evidenced in these books, and explain the
beliefs and practices of Scientology at tJial if you're
asked about those, correct?
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A. There's an entire book called "The Way to
Happiness," and there's a "Way to Happiness Course"
that's related to it.
Q. That members of the church can pay for that
course to--
form.
BY MS. FRANKLIN:
Q. --or the course material?
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A. If I'm asked.
MR. HYNES: Sorry to inteiTupt you, but
I have a 4 o'clock meeting in Marietta; is it
possible for me to call in?
MS. FRANKLIN: Sure. I' ve got like
f\lin-U-Script Q&A Repor ting Services, Inc.
(52) Pages 205 - 208
Desmond, et al. v.
Narconon, et al.
Page 209
three more questions, though. But, I mean ... 1
2
compare them point by point.
Stephen Alan Kent
January 5, 2012
Page 211
Q. Okay. And last point, Dr. Kent. You
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MR. HYNES: You're going to .. .
MR. MILLER: A few. 3 mentioned earlier your understanding that Ms. Kobrin --
MR. HYNES: What if I just get the
number, but you all keep going, and then I'll
call in. Just keep going.
4 MS. FRANKLIN: Did I pronounce it right?
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(Thereupon, Mr. Hynes exited the
deposition room.)
BY MS. FRANKLIN:
Q. Just a couple more questions, Dr. Kent. At
least for me. In your review of these materials, did
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you see any mention or discussion or analysis of drugs 13
and alcohol as they relate to the treatment of
addiction?
A. I can't tell you where in the booklets, but
there are occasional mentions.
Q. Okay.
A. Actually, I can tell you one.
Q. All right.
A. In the course number 8, "The Way to
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Page 210
1 people from taking harmful drugs." Page 31, "Defme 1
2 excess," Page 32, "What is meant by 'Do not take alcohol 2
3 in excess."' Page 33, "Give an example you've seen of 3
4 the effects of drinking too much alcohol. " 34, "Write 4
5 down five real examples of how you could prevent someone 5
6 from drinking alcohol to excess." So there -- there're 6
7 occasional mentions. 7
8 Q. Are those also included in the regular "Way to 8
9 Happiness Course" in Scientology? 9
10 A. Yes, they're included in the regular -- 10
11 Q. Okay. So the reference-- 11
12 A. --"Way to Happiness" course in Scientology, 12
13 yes. 13
14 Q. The references to drugs and alcohol that 14
15 you've seen in these materials are not specific to the 15
16 Narconon program? 16
17 A. I'd have to go back very carefully through the 17
18 booklets. There are occasional mentions about drugs. 18
19 You know, "Don't take, don't use," and so on. And I'm 19
20 not going to say that -- other than this one instance 20
21 where I'm sure they appear in Scientology, I'm not going 21
22 to say that they appear in the Scientology documents. 22
23 Occasions, the Scientology documents do discourage drug 23
24 and alcohol use. But that's where you have to actually 24
25 sit down with these books, go to the courses, and 25
MS. KOBRIN: Uh-huh (affirmative).
BY MS. FRANKLIN:
Q. --represents the Church of Scientology in a
number oflegal matters; did you notice whether
Ms. Kobrin was passing Mr. Miller notes during this
deposition?
A. Oh, I did notice she passed quite a number of
notes; I can't tell you how many.
Q. Okay. Thank you, Dr. Kent.
A. Sure. Thank you.
FURTHER EXAMINATION
BY MR. MILLER:
Q. Dr. Kent, just a few more questions.
You checked on the word "teclmology," which is
a Scientology term that's in fairly common use in the
Church of Scientology, to see ifthere's any mention of
that word in the Narconon books, and I think as far as
you can tell that that word is not being used in the
Narconon books?
A. I'd have to go-- it's not in any of the
glossaries that I looked at.
Page 212
Q. Right. And you don't recall, from your review
of the books last night, seeing that term?
A. I don't recall one way or the other. I wasn't
looking for it, so I can't really say.
Q. And the word "Scientology" also does not
appear in these books; is that correct?
A. As far as I know, it doesn't.
Q. And there's no suggestion in these books that
to the extent people have a spiritual aspect to their
lives, that it has to be Scientology versus any other
spiritual aspect?
A. No-- would you mind, sir, ifl saw that green
book for a second?
Thank you. I just want to check, there's
some ...
No, I think we're okay. I was-- let me see.
No, I just remembered, they were in the back
of "The Way to Happiness." There were references to
the -- it looks like the booklet, but I didn't see any
references in the booklet to anything involving
Scientology.
Now, "The Way to Happiness Foundation
International, 201 East Broadway, Glendale, California";
I'm not sure if there's any other Scientology org --if
there's a Scientology organization also at that address.
:Vlin-U-Script Q&A Reporting Services, Inc.
(53) Pages 209- 212
Desmond, et al. v.
Narconon, et al.
Page 213
1 I know there have been -- Glendale's been a popular
2 location for Scientology organizations, but...
3 Q. Bottom line is, there's no reference to
4 Scientology in these books that you --
5 A. Not that I' ve seen.
6 Q. Okay. You have never been a Scientologist?
7 A. I-- no.
8 Q. Have you ever gone through any training from
9 the Church of Scientology?
10 A. Any formal training, no. I've been to a
11 number of Scientology meetings.
12 Q. But you've never --
13 A. No.
14 Q. -- trained as a Scientologist?
15 A. I've never trained as a Scientologist.
1 6 Q. Have you practiced any religious discipline in
17 your life?
18 A. I have. I'd like to keep those issues
19 private.
20 Q. Let me just ask if at the present time you
21 practice any religious discipline?
22 A. No.
23 Q. Can you tell me approximately how many years
24 ago that you ceased having practiced any religious
25 discipline?
Page 214
1 A. I'm trying to locate... In and around the
2 year 2000, probably a bit earlier.
3 Q. But in terms of any formal study ofthe Church
4 of Scientology provided by Scientologists, it sounds
5 like you have not engaged in a formal course of study
6 with anyone from the Church of Scientology?
7 A. I've not been through any of the courses. As
8 I said, I' ve been through events and interviewed
9 Scientologists, but no courses.
10 Q. Okay. But basically your knowledge of
11 Scientology comes from reading materials and then your
12 own interpretation of those materials, and maybe a
13 conversation or two with people who are Scientologists?
14 A. Yes. I'd say more than -- more than a
1 5 conversation or two. Certainly I've talked a lot to
16 former members. And I talked, indeed, to Scientologists
1 7 as well.
18 And then there's a lot of material written
1 9 about Scientology. Both primary and second-- secondary
20 materiaL
2 1 Q. Okay. But basically you've read about it and
22 talked to people who may have practiced it?
23 A. That's right.
24 Q. The "misunderstood word" issue; am I correct
25 that the books, the Narconon books, provide, in effect,
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Stephen Alan Kent
January 5, 2012
Page 215
an encyclopedia, or a glossary of terms, and students
are encouraged, if they come across a word they don't
understand, to go look in the dictionary to determine
the meaning?
MS. FRANKLIN: I don't mean to interrupt
you, but I j ust think for purposes of the
record we need to -- is this Sean?
MR. HYNES: It's me.
MS. FRANKLIN: Okay. We just want to
put on the record that you're back.
(Thereupon, Mr. Hynes is present via
telephone.)
MR. MILLER: So is --
MR. HYNES: I'm back, and my car got
booted, so I'm still in the garage, but I
can't come back up there.
THE WITNESS: Oh, my God.
MR. MILLER: Holy smokes. --
MR. HYNES: So --
MR. MILLER: -- What happened?
MR. HYNES: -- carry on.
MR. MILLER: Sorry.
THE WITNESS: He's awfully calm about
that, I...
MS. FRANKLIN: Do you want to go off the
Page 216
record?
BY MR. MILLER:
Q. So students are encouraged to go look up the
word or figure it out for themselves?
A. Yes, sir; there's a very -- I think usually,
if not always, at least in books, a glossary of words
that people might have trouble with. And also they're
encouraged to look in various dictionaries. And there
are -- there are specific Scientology dictionaries in
addition to ordinary English language ones.
Q. And, generally speaking, the training routines
are to help people become better communicators?
A. That's what Scientology claims.
Q. Have you evaluated professionally -- I mean,
can you offer expertise on communication skills?
A. I can't.
Q. Or on what can assist people in the
interpersonal relationships?
A. No.
Q. Or what can help people's self image or make
them feel better about themselves?
A. No, sir, I can't.
Q. I mean, those are not areas that you're going
to ...
:.\lin-U-Script Q&A Reporting Services, Inc.
(54) Pages 213- 216
Desmond, et al. v.
Narconon, et al.
Page 217
1 A. No.
2 Q. So whether the training routines help people
3 become better communicators or confront life situations
4 in a more positive way, you don't have an opinion one
5 way or the other?
6 A. I don't have an opinion one way or the other.
7 Q. And dealing with life's ups and downs, that
8 type of issue, you're not an expert on how people deal
9 with emotional distress or stressful situations in their
10 life?
11 A. I'm not a -- I don't study the sociology of
12 emotions, so ...
13 Q. Okay. And whether the "Ups & Downs" book, for
14 example, helps students deal with stressful life
15 situations, you don't have an opinion one way or the
16 other?
17 A. I don't have an opinion.
18 Q. And the "Conditions" book that discusses
19 students' responsibilities to, say, family, or
20 responsibility to friends, or the responsibility to
21 themselves, perhaps, I mean, again, you wouldn't have
22 any expertise about whether that's effective in
23 encouraging people to become more responsible; is that
24 fair to say?
25 A. I have no opinion.
Page 218
1 Q. Right. And "The Way to Happiness," as I
2 understand it, was generated by the Church of
3 Scientology at one time as a purely secular document
4 that would just be of use to people in dealing with
5 moral and ethical issues?
6 A. That's my understanding.
7 Q. Right. In other words, it was -- "Respect the
8 religious beliefs of others" --
9 A. Yeah.
10 Q. -- is a principle in that book. "Try not to
1 1 do things to others that you would not like them to do
12 to you" is another principle?
13 A. Uh-hub (affirmative).
14 Q. Correct?
15 A. That's true.
16 Q. These would be ...
17 And I may have misspoken. "The Way to
18 Happiness Course," do you know who developed that book?
19 A. I've always assumed it was Mr. Hubbard.
20 There's certainly a Way to Happiness Foundation fixed
21 around it, but I've always -- everything I know is that
22 Mr. Hubbard wrote it.
23 Q. Okay. Would it be fair to say that that is
24 something of an assumption on your pa1t?
25 A. I don't think so.
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Stephen Alan Kent
January 5, 2012
Page 219
Q. Do you know if Mr. Hubbard wrote things that
were unrelated to the Church of Scientology?
A. Early on he did, and later in his career there
is a big science fiction book. One was a ten-- a
decalogue, a ten-volume book. Now, to say it's
unrelated to Scientology is generally true, but if one
knows how to read it and one reads certain sections, one
can see some references, some allusions to Scientology,
in there. There's also I think a later single-volume
science fiction book be wrote.
Q. Okay. Going back to these books, there's one
book about learning improvement. You're not an expert
in bow to improve people's ability to learn or --
A. No, sir, I'm not.
Q. --remember things? So, again, whether the
materials in here in the "Learning Improvement Course,"
which is book number 3, whether those are effective or
not in terms of helping people leam, you don't know one
way or the other?
A. I'm not going to make comments one way or the
other.
Q. And same with communications and perception;
you're not an expert in communications or perception,
are you?
A. I'm not, no.
Page 220
Q. Or in teaching people personal values and
integrity?
A. I'm going to do my best to stay away from
moral issues if I can.
Q. Okay. So in terms of the substance of these
books -- you can say the opinions you have about that
they parallel things that you see in the Church of
Scientology very closely, or in some cases you think may
be even identical, but in terms of the substance of
whether they are effective or valid, you're not going to
offer opinions one way or the other about that.
A. I'm not going to offer opinions on whether
they're effective or valid.
Q. Right. And I think would you agree that, in
general terms, that any organization that promotes good
moral values, good ethics, people's ability to
communicate effectively, to deal with life's stresses,
those types of things, is generally a positive thing?
A. It's a complicated question. I mean, my ...
Q. Well, let me withdraw the question, because I
think it's probably beyond the scope of what--
A. Fair enough.
Q. --you've come here to testify about.
I think we're done. Dr. Kent, I appreciate
your time. --
(55) Pages 217- 220
Desmond, et al. v.
Narconon, et al.
1 A. Thank you very much.
Page 221
2 Q. --Again, you know, we don't want to be
3 surprised; if there's anything else that you come up
4 with that you're going to ever testify about in this
5 case, we need to hear about it.
6 A. Okay. Sure enough.
7 Q. Thankyou.
8 A. Thank you.
9 MS. FRANKLIN: Thanks.
10 (Deposition concluded at 4:21 p.m.)
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E R R A T A S HE E T
I, the undersigned, STEPHEN ALAN KENT, do
hereby certify that I have read the foregoing
deposition and that, to the best of my knowledge, said
deposition is true and accurate (with the exception of
the following corrections listed below.)
PAGE/LINE CORRECTION (and reason for correction)
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Notary PublJ.c SJ.gnat ure
Date. ________________ __
My Commission Expires:
Stephen Alan Kent
January 5, 2012
Page 223
1 CERTIFICATE
2 G E 0 R G I A:
3 FULTON COUNTY:
4 I hereby certify that the foregoing
5 deposi t ion was taken down, as stated in the
6 caption, and the questions and the answers
7 thereto were reduced to printing under my
B direction; that the preceding pages represent
9 a true and correct t ranscript , to the best
10 of my ability, of the evidence given by said
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witness upon said hearing. And I further
certify that I am not of kin or counsel to
the parties to the case; am not in the regular
employ of counsel for any of said parties;
nor am I in anywise interested in the result
of said case .
This, the 17th day of January, 2012.
Jo Tomoff F1scher, RMR
CCR No. B- 924
Notary Commission Expires B-25-2012
(56) Pages 221 - 223
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127:9
abuses (1)
176:20
academic (29)
65:2;78:7, 15;127: 17;
149:22; 150:2;176: 18,25;
177: 1,6,16;178:21;
179:25; 181 :7, 15; 182:6,8,
16; 183:7 ,21; 185:13,20,
23,24;186:2,5; 187:18,23;
207:5
academics (3)
128:6;187:7, 16
accept (1)
135:25
accepted (1)
88:6
access (2)
169:3,24
according ( 4)
63:22; 136: 14; 137:4;
203:3
account (1)
64:14
accounts (1)
180:4
accurate (2)
173:25;174:5
Min-U-Script
across (3) 11:13;12:1,8;15:10; 169:21
144: 10; 163:17;215:2 21: 15;24: 17;29: 1;39:23; agreed-upon (1)
Act (2) 52:5;60:24;67:13;68: 15; 41:4
8:21;120:18 71: 17;72: 19;74: 14; agreeing (2)
action (5) 81: 15;87:1 0;99:7; 56:20;87:23
121:9,10, 10;127: 10; 101 :20;102:4;105:8; agreement (44)
199:7 106:24; 121: 15;126:20; 8: 10;58:23;59: 11,13,
actions (2) 128: 19;130:7;131 :10; 21 ,23,25;62:3,8,9,11,14,
38:2;89:2 132: 16;139: 18; 143:3; 15,17;65:22;82:11, 18,19;
active (2) 162:8; 167:19,21; 169:6; 84: 10, 14;87:25 ;89: 13,22,
96: 16;99:24 171 :22; 172: 12,19; 24;90:2,17;91 :5,11,12,
actively (2) 175: 17;186: 11;201:8; 15;92:8,16,22;108:2;
102:21;133:14 206:11 ;211 :5;218: 13 109:2;158:12; 159:3,4;
activities (3) affirmatively (1) 160:6,6; 164:22,24; 169: I;
78:11 ;182:21 ;200:21 86:19 171:7
actual (1) affirmed (1) ageements (2)
71:7 9:12 62:20;90: 16
actually (19) afraid (1) Ah (1)
16: 14;20:25 ;26: 16; 122:8 167:17
63:19;80:22;99:13; afterwards (1) ahead (10)
114: 12; 116:8; 119:18; 95:16 10:13;16:21;19:11;
135:6; 156: 16;184:18; again (52) 67:22;85: 1; 115:9, 15;
195:20; 196:1 9; 198: 17; 19: 19;21: 1;26: 19;27:1; 168:4; 169:7; 178:9
199:21 ;203:17;209: 19; 39: 17;40:16;42:21; ahold (4)
210:24 44:20;47:23;49: 15;56:7; 20:25;62: 12;89:20;
added (3) 61 :7;66:21;67:11 ;80:7; 183:17
25:23;26: 13;97:21 86:21; 102:6,18; 107:2; ALAN (2)
addict (1) 110: 19; 116:21; 121:13; 9:11;10:16
135:18 122: 11;124:5;132:21; A-L-A-N (1)
addiction (6) 139: 19;142:3;144:12,16; 10:16
48:20,23;50:22; 124: 1; 146:5, 16,25; 148:2; 153:7; Alberta (7)
151:2;209:15 158: 13;160:23;161 :5,17; 10: 17;32: 16,25;33:7,
addition (5) 163: 1; 164:2,12;166:5; 11, 14;35:11
33: 17;50: 11 ;78: 1 0; 168:1; 180:5,22;181 :5; alcohol (19)
135:8;216:11 197:7,22;205:8;217:21; 48:20,23;49:4;50:22;
additional (4) 219:15;221:2 51 :5;54:5;96:21; 10 I :23;
51:23;135:18;162:22; against (16) 105:24;133:23; 138:3;
164:22 37:2,6,8;38:2;40:9; 148:9;154:3;209: 14;
address (2) 43:9;44: 12; 134:23; 210:2,4,6,14,24
137: 10;212:25 135: 15;176:7;177:5; Alcoholics (4)
addressed (1) 180:21 ;182:19;184:9; 70:20; 123:20,23;124:6
148:3 187: 14;202: 16 aligned (1)
addresses (2) age (2) 132:23
181:1;199:2 19:8; 181:20 Allan (2)
adults-would (1) agent (3) 35:18;36:7
19:1 90:20;91:8;92:11 allays (1)
advance (1) agents (2) 100:23
133:18 91:19;184:4 allegations (1)
advanced (1) aggressive (2) 37:10
31:17 38:1;177:3 allness (1)
advertisement (2) ago (7) 119:19
109:21;182:5 36:1 ;90:23;99:5; allowed (2)
advice (1) 110:20; 156: 10;181: 18; 8:21;201:2
175:25 213:24 allows (1)
advocating (1) agree (18) 203:1
123:11 8:13,17,18,22;57: 19; allusions (1)
affected (1) 66:3;86: 17;97:6;1 08:7; 219:8
154:22 123:6; 125:11 ;129:21; Almost (5)
affidavit (1) 142:5,9;160: 14; 168: 13; 12:2; 17:11 ;65:4; 173:3;
35:1 181 :6;220:14 188:7
affidavits (1) agreeable (1) along (8)
107:8 170:9 58:6;1 06:14;107: 18;
affirmative (43) agreed (1) 118:9; 161:19; 181 :22;
Stephen Alan Kent
January 5 2012
'
182:12,20
Alternative (2)
149:14,16
although (4)
16: 12;41: 11;96:6;
122:11
always (17)
17: 13; 18: 13;47:7,10;
48: 13;80:7;85: 14;86:24;
96:7;110:7;151 :21;
154: 19; 191: 15;204: 12;
216:7;218: 19,21
AMASON (4)
144:21,25;189:21 ,21
ambiguity (1)
56:22
America (2)
32:5;78:13
American (4)
31:22;80:9; 151 :4;
185:7
among (4)
42: 17;43:4; 187: 16;
201:6
amount (5)
18: 17;26:22;32:23;
33:22;34:1
analogies (1)
201:23
analy (1)
110:1
Analysis (15)
102:12,14, 17;109: 12,
13,16,17 ,23; 110: 15,25;
Ill :7;112:23;125: 13;
130:20;209: 13
analyzes (1)
136:17
ancillary (3)
56: 10;88: 15;90:6
and/or (2)
58:11;205:7
Angeles (1)
191 :16
anger (1)
134:23
angry (1)
17:11
Animal (1)
41:19
annual (2)
87:7;182:1
anonymity (1)
63:23
Anonymous (4)
70:20; 123 :20,23; 124:6
Anson (2)
183:14;186:12
answered (2)
63: 10; 140:1
Anthony (2)
35:18;36:7
anticipate (2)
(1) $2500 - anticipate
Desmond, et al. v.
Narconon, et al.
52:6;167:24
anticipated (1)
140:21
anti-cult (1)
178:23
antipathy (2)
150:22;151:14
anti-psychiatry (2)
135:22; 153:8
antisocial (7)
19: 15;113: 12, 17,22;
198: 15,25;200: 14
anyplace (2)
54:21 ;83:23
apart (1)
41:13
apologetic (1)
186:6
apologize (2)
144:12;190:18
apparent (1)
110:8
Apparently (2)
182:8; 190:11
appear (12)
49:8;82:6;88: 18;
135: 15;}40: 12; 141 :4;
163:22;173:9;182:7;
210:21,22;212:6
appearance (1)
194:20
appeared (1)
86:24
appears (3)
131:21; 173:25;199:21
application (1)
42:1
applications (1)
205:11
applied (2)
33:14;58:17
applies (1)
111: 1
appointment (2)
182: 16;183:12
appreciate (8)
10:6;50:9;84:20;
107: 12;121 :1;130: 14;
157:25;220:24
approach (3)
56: 1;97:9; 186:23
appropriate (2)
15:3;174:24
appropriately (1)
180:25
approving (1)
71:12
approximately (3)
27:4,11;213:23
apt (1)
122:2
ar (1)
179:20
Min-U-Script@
archway (1) assigned (1) auditing (1)
101:7 196:2 44:3
arduous (1) assignment (1) augmentation (1)
31:23 204:18 203:2
area (7) assignments (2) author (1)
30:21;31:7,18;50: 18; 115:5,7 207:7
147:2; 154:6;191:5 assist (3) availability (1)
areas (13) 154: 12;157: 14;216: 18 25:17
27:21 ,23;50:10, 11,14; assistant (2) available (1)
52:8;67:21; 109:18; 31 :14,25 94:1
128:8; 130:20;160: 13; assistantships (1) Aviv (2)
191:12;216:24 32:7 177:9,9
are-I'U (1) assists (2) Avoid (5)
114:16 163:19,19 113: 14; 130: 18;174: 19,
arguably (2) associate (5) 21;175:5
48:11;161:10 44: 15, 16;55: 14;114:6; aware (6)
argue (2) 180:9 128: 10;132:12;155: 19,
102:19;132:4 associated ( 6) 23;181:16;187:7
argument (1) 48: 11;54:9; 113:21; Awareness (11)
17:9 200:15,18,23 175:9,11,19,24;176:3,
Arizona (2) Association (5) 8, 13;183: 17,20,23;184:5
95:2;148:11 53:5;57:21 ;58: 16; away (9)
arm (1) 113:23;199:21 41 : 12;49:25;50: 1;
198:5 assume (8) 67:21; 104: 13;147:2;
around (9) 10:9; 18: 15;21 :6;24: 15; 162:23; 164:23;220:3
98:8; 105: 18; 144:14; 47:4,15;106: 16;165:3 awful (1)
183:3; 194:24;198:1; assumed(4) 31:24
207: 10;214: 1;218:21 24:9;96:7;191:15; awfully (1)
arrested (1) 218:19 215:23
36:20 assuming (3)
article (32) 127: 13;161 :24;166:20 B
148:5; 149:8, 10,14,25; assumption (3)
150:6,14;170:23,24,25; 17:22;113:2;218:24 back (85)
171:2,4,1 0,11; 177:4, I 0; assumptions (2) 13: 13,22; 14:9;16:3,6;
179:5,9, 11,11,15;180:14; 112:12;184:16 20:16, 18;22: 1, 16;26:4,
181: 10,12,22,23;182:2,3, astonished (1) 16;28: 11, 17;29:25;30: II;
21; 187:9;188:4,6 11:14 33:5,7,13;35:19;37: 17;
article-and (1) Atlanta (3) 38: 15;44:20;52:24;58: 1;
179:13 24: 16; 166:20,23 60:23;63: 1;65:21 ;68:6;
articles (8) atomic (2) 70: 12;80:7;82:22;83:22;
11 :2;77:3;171 :6, 11,23; 95:22; 152:17 84:21;85: 12;90:25;93:3,
172:3,10;188:2 Attach (1) 14,20;95:18, 19,25;97:2;
article's (1) 58:21 98:4,12,12, 19,21;99:4;
182:7 attached (3) 104: 13;109:9;110: 19;
articulated (1) 38:19;58:22;1 10:19 116:5;120: 1,24; 124:11;
40:11 attempt (2) 126: 17;133: 14,20;
artists (1) 135:23;157:6 134: 13,19;152:22;
119:11 attempting (1) 153:10,21; 154: 17; 155:2;
ashtray (5) 179:12 158: 13,18,21;159:20;
137:3; 193:23;194:8, I 0, attempts (1) 162:25; 164:24;165: 12,
11 156:11 13;181: 19; 182:24;
aspect (5) attention (1) 185:18;197:11,11;207:6;
47: 12; 132:6; 135:23; 144:11 210: 17;212: 17;215: 10,
212:9, 11 attitude (1) 14,16;219:11
aspects (5) 48:8 backed (1)
13: 13;47:25; 135:3; attitudes (1) 41:12
166:7;187:5 16:20 background (7)
aspiration (1) attorney (1) 13:12;28: 18;36:8;
106:4 190:25 48: 19;49:9;143:5;186: 17
aspirations (1) attorneys (3) backwards (l)
104:15 73:7;174:3; 182:15 71:13
assessment (2) attracted (1) bad (6)
102: I I ;133:24 102:2 30: 18;114:7;141 :15;
Stephen Alan Kent
Januar y 5, 2012
165:23,24; 186:22
badly (1)
17:10
badness (1)
166:6
bag (1)
117:14
balanced (1)
177:13
band (1)
196:24
Barbara (2)
67:25;185:9
barest (1)
122:3
barriers (3)
16:20,22; 112:13
base (1)
100:22
based (58)
18:8;19:21;23:24;24:6;
28:4;48: 18;69:24;71 :21;
77:22;79: 16, 18,20;80:6;
83:5,6,1 0, 16;84:3;85:23;
86:2,6, 18;87:2;88:5, 12,
16,20;89:2;92:24;94: 16;
I 02:7; 105: 17; 125:2,8,18,
23; 126: 13,15; 127:21,21;
137:7,16; 142:7;146:3,17;
148:1; 152:9;155:11;
160: 1,8,15;162:9; 167: 15;
185:8; 192:3,6; 195:15;
203:16
bases (1)
94:21
basic (7)
25: 14;78:21;93:8;
139: 15; 179:24; 196:25;
204:7
basically (5)
69:20;125: 17;140:18;
214:10,21
basing (2)
98:23;99:3
basis (18)
1 0:2;15:8;83:3,12,20;
84: 15;87:7;88:8;89: 19;
90:9;99: 14; 106:6;
107:22; 149:22; 150:2;
156:18;159:7, 13
Bates (20)
12:7;57:7,1 0,23;58:3;
144:8,22, 24; 145:11;
146:21; 147: 14; 148: 13;
149:3; 150:20,23;151:16;
152: 14,23; 153: 17;163: 17
bear (1)
164:14
bearing (6)
39: 14;40:6,9; 148:4;
158:17;175:14
beat (1)
67:11
(2) anticipated - beat
Desmond, et al. v.
Narconon, et al.
became (1)
40:25
become (7)
1 05:25; 106:9;120: 18;
133:23;216: 13;217:3,23
becomes (4)
48:10, 14;80: 14;200: 17
begin (2)
91 :3;189:16
beginning (1)
23:25
behalf (6)
44: 13;45:20;47:8;
189:20;190:1,11
behav (1)
115:24
behavior (12)
47: 13;48: 1,5, 13, 15,17;
65:5;81 :2;138:1 0,19,21;
140:10
behaviors (5)
127:25; 128: 1;139: 13,
14;200:21
behind (1)
196:16
behind-the-scenes (1)
208:12
beingness (1)
118:22
beings (2)
78:21;118:19
B-E-1-T (1)
177:7
Beit-Hallahmi (3)
177:7,8;178:13
belief (18)
47: 16;48: 12;78:20,24;
86:14, 18;87:24;88:24;
89: 19;11 8:12; 123:12,21;
128:3,6;140:8;146: 12;
157: 14;200:21
beliefs (32)
28:1 ;48:4,8;68:21;
83:7,8;118:11;126:25;
127:6,8,9, 19,20; 131 :7;
132:13; 133: I ,3,5; 134:7;
137:14; 140:3,23;141 :23;
192: 15,21; 194:2; 197: 19;
198 :20;204: 1 0;205: 11;
208:19;218: 8
believes (2)
132:7; 195:7
beneficial (1)
199:7
benefit (3)
58:4,4; 121:2
benefited (1)
95:5
benefits (3)
50: 17;86:23; 135:8
Benitez (2)
95:3; 148:6
Benjamin (2)
!\lin-U-Script\'ID
177:6; 178:12 157:15 78:3;142:12
Berg (1) bombshells (1) borrows (1)
182:3 162:13 80:13
best (8) Bonnie (2) both (9)
15:1 ;26: 15;36: 1;40: 15; 37:13;43:18 18:6;57: 1 ;62: 8;86:25;
41 :3; 11 9:4;204: 13;220:3 book (72) 171:6, I 0;172:22;185:11;
best-funded (1) 16:15;20:7,15;51 :12; 214:19
32:4 73:8,16;93:6,1 1,16, 19; bottom (9)
Better (10) 94: 16;95:3;103:25; 12:5;89:6; 115: 19;
53:5;57:22;58: 16; 108:24; 111 :11,11 ;112:9, 122:6;126:6;136: 12;
112: 14;119:9;133:23; 19;113:9; 114: 10;116:3; 153:23; 157:1 ;213:3
167:5;216: 13,22;217:3 117:7; 118:2,9; 121:4,14, bought (1)
betterment (1) 22; 122:12, 19; 123:6,1 0; 183:18
199:10 125:7;139: 15;154:20; Boy (3)
beyond (10) 156:20;160: 19; 165:23, 35:24;70:20;81: 13
53:16;55: 16;58:2; 23,24;168:5;169: 17, 18, brain (2)
125:22;141 :6; 145: 13; 19,19,20,22,23; 170: 18; 173:13, 13
146:7,9;161: 11;220:21 179:6,12;180: 14;184:4, brainwashing (3)
bias (2) 14; 187:25; 188:2;193:5; 178: 19;180:11 ,16
186:20;187:1 196: 18; 197: 12; 198:1 0; breach (1)
biased (1) 203:25;206:13,17; 92:9
187:3 212: 13;217: 13,18; break (10)
big (5) 218: 10,18;219:4,5, 10,12, 10:11;25:6;67:23;
45: 18; 133:1 0; 145: 16; 17 104: 17; 117:17,23;
201:11;219:4 booklet (12) 143: II ,23; 163:8;169: 16
biggest (1) 21:22;116:7,7;195:19; breakdown (1)
151:8 198: 14,22;207:2,3,18; 152:21
bill (2) 208:5;212:19,20 Bridge (10)
64:25;65:4 booklets (4) 37:22;38:2;43 :21;
billed (1) 26:7; 157:23;209: 16; 101: 10,11;1 03:21; 104:6,
66:1 210:18 7,7;194:14
billing (4) books (102) brief (2)
22: 15;64: 15, 18;65: 10 13: 16; 17: 16;19: 13; 39:9;103: 14
billions (2) 20: 18,21,22,25;21 :4,6,8, briefly (3)
135:19; 151:3 10,12,19;72:3,7,21,22; 35:22;41 :23;93: 1
Biographies (1) 73:1 ;74: 1 '17' 18,21 ,24; bring (8)
155:13 75:2;77:22;92:25;93:2,5, 15: 15; 17:25; 113:5;
biography (2) 24;94: 19;98: 7,8, 12, 15; 129:9; 154:4; 186:25;
154:18;156:25 116:16;117:9,24;120:21, 196: 17;197:9
bit (17) 24;121 :1 ,2;124:21; 125:2, bringing (2)
16:4;26:2,5;29: 1; 13,23;126:7;133:5;135:7, 42:5; 196:21
59: 17;78:2;86:10; 15; 140: 13; 154: 18; brings (1)
105: 13;124:23;135:7; 156:15; 159:24;160: I ,15, 187:3
140: I; 144:1 0;145:24; 24; 161 :1 ,18,24,25; 162:5, Britain (1)
178:9; 188: 1;199:12; 9; 163:23, 25;164: 1; 182:6
214:2 165:12, 13;168:3,6,18; broad (1)
blames (1) 169: 1,24; 170:4,7; 185:15, 161:16
199:3 16; 188:1; 192:5,8, 19; broader (1)
blank (2) 195: 17; 199:22;203:9,15; 107:13
26:17;173:13 205: 19;206:5;207:25,25; broadly (2)
blanket (3) 208: 15,18;210:25; 38:24;48:3
59: 18;80: 11;82:10 211 :21,23;212:2,6,8; Broadway (1)
blanking (1) 213:4;214:25,25;216:7; 212:23
20:1 219:11;220:6 broken (2)
blasting (2) booted (1) 144:6;152:18
115:9;177:13 215:15 brought (6)
Blow (1) bored (1) 113:23;117: 15; 120: 16;
199:6 17:10 176:7; 184:23;197:22
blue (1) borrowed (1) Buddhist (1)
156:20 132:11 123:15
body (10) bon-owing (1) bullbaiting (2)
18:20;73: 1 0;96:2, 5; 160:12 137:2;194:19
105:3;111:13,22;112:2,4; borrowings (2) Bundestag (1)
Stephen Alan Kent
January 5, 2012
184: 11
business (2)
42:2;46:7
Buttnor (8)
35: 18;36:7 ,19,20,24;
37:2,4,9
c
calcium (1)
111 :23
California (3)
95: 15;185:9;212:23
call (11)
12:7;22:24;23:2,5;
42:4;55:2;98: 18;1 03:23;
134:21;208:24;209:6
called (43)
17: 1,3,7,18,21,25;
19:22;22:25;32: 17,21 ;
36: 14;41:24;42:18;
60:13;65:8;72:1 0;93:21;
95:9;102:17;103:24;
109: 11;111 :23;113:7;
114:12;116:19,23;
118:17;150:24; 152:1;
156: 11; 180: 15; 181:22;
182:2;184:4, 13; 187: 10;
193:7,9,15;195:8;198: 18;
206: 17;207: 11
calls (2)
65:2;183:3
calm (1)
215:23
Cal-Mag (1)
111:23
came (15)
24: 15,20;26:8;94:25;
95:1;116:10;147:17,20;
149:4; 163: 16;166:20;
181 :21; 182:24; 184: 19;
187:9
can (124)
8:13,17 ,22;9:3; 10:11 ;
15: I ,9, 11 ,20; 16:11 ;
17:23;19:17,18;22:23;
23:20;26: 15;27: 10;28:9;
29: 12,15,15,22;34: 10;
36: 1;39:25;40:7,1 6;42:4;
43: 18,23;47:22;48:9;
51 :22;53: 17;56: 1 ;59: 1;
62: 10;65:6,22;79:1 ,5,10,
14;80:25;81 :7,18;84:7,
24;85: 15;86: 1 ;92: 1 0;
93: 1,5;94:2;99: 12;
100: 10;102:22;103: 13;
105: 18;1 06: 16;108:3,5,6;
109:20;110:9,9;115:11;
118: 10;122:23; 123:9;
124: 13;127:10,14;
129:18,21 ;133: 15;
134:12, 13; 137: 13,15;
141 :2; 142: 13;144:3,7, 15,
(3) became - can
Desmond, et al. v.
Narconon, et al.
21; 145:4,5, 18,25;156:3;
158: 13, 14,23;162: 1, 19;
163: 10;164:24; 167: 10;
168:11,13;170:4; 174:21;
175:22; 177:24;179: 11;
180:3; 194:1 ;196: 18;
200: 12;201 :15;204:16;
206: 1,20;207: 1;209: 19;
211 :22;213:23;216: 16,
18,21 ;219:8;220:4,6
Canada (7)
10: 17,20,21;21 :4;22: 1,
16;108:21
Canadian (2)
10: 18; 100:9
Capacity (10)
102: 12,14, 17;1 09:12,
13,16, 17,23; 110: 15;
11 1:7
car (2)
32:15;215: 14
card (I)
191:3
care (I)
171: 10
career (1)
219:3
careful (4)
59: 12;77:4; 161 :6;
203: 18
cuefully (3)
56:8,16;210:17
Carolina (1)
183:5
Carr (1)
53: 14
C-A-R-R (1}
53: 15
carrot(1)
33:4
carry (1)
215:21
cartoon (1)
119:10
cartoons (3)
119:6,7,8
case (123)
11: 10,25;13:1,6,15,19;
14:6,8;16:9;20:21;21: I ;
22:5,7;23:7,10, 13, 14;
24:4;25:22;27:24;29: 19;
33:24;34:6,9, 15;35: 11,
25;36:9;37: 1 ,16;39: 14;
40:6,21 ;41 :24;42: 10,25;
43:2, 15,20;44:2,21;45:8,
12,20;46:2,2,3,8, 1 0;
47:25;48:7;49: 17;51 :3,8,
17;52:6;62:14;67:9,16;
69: 12,22;71 :4;72:22;
75:3;88: 10; I 00:25;
103: 1 ;104: 8, 13; I 06:2,11,
13,16,17; 107: 14; I 08:9;
111 :5; 124: 12; 130:21,25;
Min-U-Scr ipt
131 :9;134:9; 140:5;141 :9, 44: 15,16 21: 19;26:7;27:2; 145:3,
12,24;143:2; 144:2; Chaleff(1) 3; 151: 1,7
147: 12;148:4; 157:2,21; 37:14 choice (1)
159:25;161: 14;162: 16; challenge (1) 81:24
164:14;166:9,14; 171 :8,8; 149:21 choose (2)
172: 18,20,21; 173: 10; challenges (1) 94: 1;108:20
174:2,9, 15; 175: 14,21; 149:25 Christianity (I)
176:4,6,7;183:24; 188:22; change (1) 123: 14
189: 1; 194:6,12; 199:24; 102:1 Christmas (1)
201:16, 16,18;204: 13; Changed (5) 32:14
221:5 30:21,21;31 :2;95:24; chuckle (1)
cases (I7) 97:23 173:5
11:14;20:24;33:24; changes (1) Church (82)
37:24;38:5,10, 12;47: 19, 89:25 18: 11; 19:2;28:5,8;
24;75:24;77: 1 ;78:3; Changing (3) 37: 15;42:13;43:25;
86:25; 132:24; 176:3; 73:3;115:2;204:1 52: 19;55:15;59:15;
191:11 ;220:8 chaos (1) 7 1 :22;77:25;78:4;79:9;
cases-that (1) 115:19 82: 12, 14;84: 10,14;89:14;
208:6 chapters (1) 90: 15;99: I 0, 18; 100:2,7;
Cathy (1) 58:7 I 01: I ,22,24; 102:3;106:9,
37:14 characteristics (5) 20; 107: 17; 124: 18; 127:1,
cause (13) 113: 19,20; 198:23,24, 22; 128: 11,21;129:13;
22:2;23: 17;38:24; 25 131 :8,14;132:20;133:2,3;
45:24;69:9;84:5,6; I 07:6; characterize ( 4) 134:8; 137:8,15;138:2;
118:23; 129:25;155:7; 79: 15;80: I ;82:24; 139:21;140:2,22,25;
156:2;173:7 174:17 141 :1 3,22; 142:8;146:13;
cautious (1) characterized (1) 162:2, I 0;165:20; 176: 11;
82:10 176:21 185:5,21; 192: 15,22;
caveat (1) charge (1) 193:7,16; 196:6, 15;
129:25 144:16 198:11,21 ;202:2,20;
caveat-that (1) charged (2) 204:3;206: 15,20;208: 17;
102:10 36:21,24 211 :7,20;213:9;214:3,6;
CD-ROM (1) charges (2) 218:2;219:2;220:7
24:8 37:2,5 circ.les (1)
ceased (1) charging (1) 78:7
213:24 166:8 citation (1)
Celebrity (1) char itable (31) 156:16
146:22 56: 11;61:10, 12,19,25; cite (1)
Center (2) 79:20;80: 11,25;81 :7 , 18; 180:3
37:22;41 :20 83:9,17;85: 22;86:6,22, citing (1)
Center-an (1) 22;87:3;88: 12,16,20; 180:22
151:7 89:2;90:7,9, 12;145: 14; citizen (2)
centers (1) 158: 15,24,24,25;159:7,9 10: 18, 19
151:25 charity (2) Citizens (1)
central (4) 61:3;146: 17 58: 12
83:6;86:7;88:11,18 chart (3) city (3)
century (2) 75: 8,1 1; 110:8 36:6, 11,20
70: 10;207 :7 check (12) Civil (3)
certain (6) 35:4,8;37: 17;40: 14; 8:21 ;35: 11 ;46: 8
12: 14;55:22;56:21; 45:24,25;1 18:13, 14; claim (8)
133:3;173: 12;219:7 144: 13;172:5;205: 18; 23: 18;78: 13;88:23;
certainly (26) 212: 14 96:24; 109: 18; 111 :21;
11: 15; 14: 14; 15:3,2 1; checked (1) 176:13;201:12
17:11;18:20; 19:7;34:5; 211 :18 claimed (6)
36: 17;43:19;47:22; Checkout (1) 44:8,11;56: 13; 100: 15;
60:17;75:25;92: 18; 72:10 112:1;176:9
105: 17; 131:21; 145:15; child (4) claiming (4)
157:9;161 :16;176:22; 36:21;40:21 ;41:3, 12 42:7;43:3;88:8;96: 1
186:5; 196:8;203: 13; children (12) claims (29)
208:1;214: 15;218:20 36:3,24; 114:3;180:21; 79:20;82: 13;83:1 0;
cetera (2) 181 :23;182:4,6,8,9,13,14, 85:23;86:7;87:8;88: 13,
124:25; 192: 1 15 17, 18,21 ;96:3,4;97: 1;
chair (2) Chilocco (7) 100:1, 11,22;103:25;
Stephen Alan Kent
January 5, 2012
111: 18; 131 :23;147: 1;
152:6; 154: 16,17, 19,24;
155:2; 156: 19;183: 10;
216:14
clarification (1)
75: 1
clarify (2)
3 1:15;40:23
clarifying (I)
50:9
Clar k (I)
53: 14
classic (2)
120:6; 192:11
classroom (1)
201:22
clay (4)
16:23;119: 12;196: 12,
20
clean (1)
68:6
clear (20)
13: 17;37:20;41:1;
49: 16;53: 1 ;73: 10,10;
81 :3;85:7; I 05:3,3;
111: 13,13;134: 16,16,20;
142:3; 159: 18; 164:21;
194:9
clearly (2)
47:24;97:9
client (1)
193:15
clips (2)
16:24; 196:24
close (3)
81:4;122:8;206:1 2
closed (1)
26:3
Closely (2)
132:23;220:8
cloud {1)
157:13
coach (1)
193:15
coaster (1)
113:25
codes (2)
138:16,16
coercive (1)
178:19
collapsed (1)
183:18
colleague (1)
178:6
colleagues (1)
178:8
collecting (2)
25:24;26:20
collection (2)
158:7;185:8
collections (2)
27:9;187:25
color (2)
(4) Canada- color
Desmond, et al. v.
Narconon, et al.
77:9,9
Colorado (4)
172:20;173:2,4,9
comfortable (2)
84:2;106:22
coming (3)
44:9;86: 19; 150:4
command (2)
207:16,20
commander (1)
207:13
commands (2)
18:1;194:15
comment (2)
54:14;104:12
comments (8)
44:6,8;48:25;49:20;
53: 16;55: 17;146:3;
219:20
Commission (2)
58:13,14
committed (1)
183:7
committee (1)
184:12
common (5)
18: 10;123:18; 131: 13;
205:16;211:19
commonly (2)
119:16;123:19
communicate (2)
93: 17;220: 17
Communication (5)
73: 12; 112: 19;197: I ;
199:13;216:16
Communications (4)
193:9; 199: II ;219:22,
23
communicators (2)
216: 13;217:3
communities (1)
95:24
community (5)
11 0:4; 177:16; 179:25;
185:20,23
companies (3)
207:18,19;208:7
company (1)
45:17
compare (2)
170:4;211: I
compared (2)
97:16;98:19
complete (10)
11:24; 12: 17;14:23;
15:9;29:18; 109:9; 120:5,
14; 133:23;138:21
completed (1)
165:11
completely (1)
15:11
complicated (3)
17:5;80: 14;220:19
Min-L"-Script
computer (2) consequence (2) controversial (1)
14:19;41:9 90:5;135:12 177:16
con (1) consequences (1) controversy (3)
90:5 39:20 124:3; 177: 17;179:25
conceivably (2) Consequently (2) conversation (2)
62:16;132:3 133:10;135:2 214:13,15
concept (6) consider (4) conversations (2)
17:8;1 04:14;178:20; 63:5;67: 18; 128:11; 155:11;167:16
192:5; 196: 16; 198:7 129:12 convey (1)
concepts (18) considered (1) 207:19
19: 15;20:22;72:6,7; 60:8 cook (1)
77:24,24;83:6,15;85: 10, consist (1) 30:8
24;86:8;88: 11 ;113: 11; 156:3 copied (1)
115:3; 119:1;126:3; consistent (6) 146:22
141:19;191:25 28:22; 125: 14; 140:7, copies (7)
concern (5) 24; 146:11 ;202: 19 34: 16;35: 1;39:2;40: 12;
41: 16;56:20;95:21; consists {1) 170:6; 172:22,24
151:5;160:5 185:23 cops (1)
concerned (8) constant (2) 36:17
54: 16;60:7;71:9,9; 115:15;156:17 copy (12)
78: 14;125:21;151 :21; constitutional (1) 57:5,6;73 :8;89:20;
154:11 89:5 152:24;173 :6,14,18;
concerning (1) consult (3) 174: 1; 178:24; 179:4;
11:10 21:24;39: 15;40:7 182:4
concerns (3) consultation (1) copyright (5)
100:23;128:8,15 41:13 13: 16;21:20;38: 10,21'
concluded (3) Consultations (1) 24
94: 17;125:24;221: 10 35:14 copyrighted (1)
conclusion (1) consulted (6) 70:16
94:9 13:8;21: 16,18;24:3,5; copyrights (2)
conclusions (3) 46:23 58:10;98:14
141:21;177:20;180: I consulting (7) core (2)
Condition (4) 23:19;33: 18,21 ;34:2; 86:8;176:3
115:2,21;200:10; 179:17;185:11,16 corner (1)
204:10 contact (1) 18:3
Conditions (14) 95:7 corporate (2)
73:4;115:3,18;116:2; contacted (8) 28:6;52:17
204: 1,5,5,6,8,9, 14,20; 22:7,20,22;47:8;64: 16, corrected (1)
205:3;217: 18 24;182:6,9 49:13
conducted (1) contain (1) correctly (5)
155:9 161:9 17: 15;45: 16;55:23;
conference (1) contained (1) 112:21;119:18
23:5 13:9 counsel (8)
confidential (2) contains (1) 8: 11;21 :7;40: 15;75: 12;
91:12;92:7 110:14 167:4,6,7, 11
confidentiality (2) contend (2) counselor (2)
63:24;92: 10 101:22;128:22 30:9;31:23
confirm (2) content (7) count (2)
10:24;29:4 87:13,13;95:13; 46:20;47:3
confirming (1) 112:12;131:5,6;196:8 counted (1)
21:13 contents (3) 46:19
confront (1) 114:9; 145: 19; 182:5 counter-intention (1)
217:3 context (12) 134:21
connected (3) 38:21;80:8; 127:7; countersued (1)
28:8;52: 19;71:16 132: 12,12;136: 19; 37:7
connection (9) 149: 19;154: 14;160: 10; countersuit (1)
20:20;68:22;72: 1 1; 165:19;200:1 ;204: 10 37:8
85: 10;86:5; 127: 15; continues (1) country (1)
141: 15;153:2;175:8 43:8 95:22
connections (3) contracted (1) couple (18)
131:4; 157:24;191 :24 66:24 25:25;30:5;33:23;68:7;
consciences (1) contrary (3) 103:3; 134: 17; 135: 14;
127:10 138:4;139:13,14 149: 19; 153: 10;163:20;
Stephen Alan Kent
January 5, 2012
168:1 ;174:23;182: 17;
184:8;188:11;193:4;
208:14;209:1 1
cour (1)
44:17
course (112)
13: I 0,20,22;14:1 0, 17,
24; 15:2, 15,17,25; 16:4,8;
17: 10,10,17; 18:8;19: 14,
18,20,21 ,22;21 :20,24;
23:15, 15;24:23;25:2,11;
28:3;44: 18;51 :3,15;
66: 13,16,17;67:5,17;
68:22;70:2;71:21,25;
72: 1,23;73:4,12,16;
78:23;79:4,7,25;80: 12,
12;82:23;83 :3,5;85: 11;
93:6;96:6;98:17,23;
103:22; 112: 10,20;
113:10;114:12,24;116:6;
117:5; 118:3;121 :24;
135:6; 136:22; 137:6;
142:7;154:20;159: 19;
169:5;187:2;191:18;
193:6,6,8, 10;195: 17;
196:5,5; 197:2,2; 198:10,
11,17;201:9,10;203:9,15,
25;204: I ,2,24;206:4, 14,
15, 18,21 ,25;208: 15;
209:21;210:9, 12;214:5;
218:18;219:16
courses (20)
42:5;52: 1;87: 13,16;
94:22; 102:7,8;116: 18;
133:9;136: 12; 138: 13;
140: 13;144: 19;194:23;
196:3;200:22;203 :9;
210:25;214:7,9
court (34)
9:7,24;1 1:14;37:24;
41: 1;43:22;44:21,23,24;
45:1,3,5,21 ;46:9;59:24;
60:4;67: 15;76:6,16,23,
25;85:5, 18;107: 14;
128: 18, 20;129:9,11;
130: 12; 136:24;139: 19;
147: 19; 168:8;176:2
courtroom (1)
130:6
cover (7)
72:21 ;97:3; 122:22,24;
125:6,8;160:8
covered (4)
60: 18;163:6;164:3;
167:9
covers (1)
94:20
create (2)
118:22;151:9
creativity (1)
116:23
creator (2)
118:6;1 19:17
(5) Colorado -creator
Desmond, et al. v.
Narconon, et al.
credentials (3)
186:10, 13,13
criminals (1)
96:12
Criminon (2)
96:9,10
Crisis (1)
150:25
critic (2)
127:22,24
critical (16)
44:6,8;47:10, 12,21,25;
48:3,8,16, 17;69: 12, 15;
128:2; 141: 13;177:19;
187:8
criticism (5)
47: 16; 139:21 ;181:17;
188:21;203:5
.criticisms (8)
179:21; 183:16; 188:25;
189:3; 194:20;200: 19;
20 I :25 ;202 :2
criticize (1)
202:18
criticized ( 4)
183:20,22;184:1;
187:24
criticizing (2)
202:3,17
critics (2)
43:7,9
critics-I (1)
38:5
Critique (1)
180:11
critiques (1)
181:2
Cross (1)
81:10
crucial (5)
14:6; 17:8;48: 14;
180:24;181:20
cult (15)
174:18,21 ;175:2,6,9,
11,19,24;176:3, 7,13;
183:17 ,20,23; 184:5
cults (1)
184:12
curious (2)
12:20;25:16
current (3)
11:1 ;53: 12; 159:10
currently (1)
116:23
custody (3)
36:2,4;43:2
CV(7)
10:23,25;28: 17;29:25;
48: 18; 171 :25;172:2
Cynthia (1)
175:18
l\1in-U-Script@
145: 15;146:15 11,12;44:17
D
declared (2) dependency (1)
199:16,19 51:5
daily (3)
dedicated (1) depends (2)
54: 14; 102: 19; 107:3
207:25 127:2; 155:23
damaged (1)
deemed (1) depose (2)
133:9
79:19 162:25;164:24
damaging (1)
defendant (1) deposed (8)
202:11
69:12 42:25;43: 14,23;44:22;
dangling (1)
defendants (1) 45:22;46:2,9;75:3
33:3
8:5 deposition (33)
date (13)
Defendants' (18) 8:4,13, 16, 18,20; I 0:22;
11:1 ,5;45:24;59: 13;
8:2;57:25;72: 15,18; 16:5;23:25;35:1 ;44:20;
64:21,22;65: 16;66:1;
1 03:6;123:1 ;143:19; 59:5;68:4,14;75:6;77:7;
79:6;91 :4;134:23;172:1;
147:3;163:14;169:11; 122: 12;123:4;130:4,11;
207:11
171: 18; 173:22; 191: 19; 149:11; 150:22;159: 19;
dates (2)
196:4,1 0;198:9;203:25; 167:6; 169: 14;170:2;
22:17;168:21
206:13 172: 15;173:6,9;174:1,6;
David (4)
Defense (1) 209:9;211: 10;221: 10
100:11,13;177:4;182:3
58:15 depositions (12)
Dawson (5)
defer (3) 24:8,12;68:9, 18,20,24;
177:22; 178: 1; 180:8;
53: 19;99: 15; 105:14 110: 17; 148: 16; 166: 16;
181:6;187:24
detine (3) 172:17 ,23; 193:20
Dawson's (2)
78:17,18;210:1 dcprogrammcd (2)
180: 15; 188:4
defined (2) 176:10,14
day (5)
42:20;119:18 deprogramming (1)
26:4,4;41 :6;69:4; 126:2
definite (1) 183:25
days (6)
137:8 describe (2)
36:18, 19;96:24; 126:18,
definition (1) 13:20;72:23
19;156:6
80:1 described (1)
day-to-day (1)
definitions (3) 176:17
99:14
78: 19; 192:1 ;205: 10 describes (1)
dead (1)
definitive (2) 197:13
67:11
137:22; 159:18 descriptions (1)
deal (5)
definitively (1) 204:14
145: 16;200:24;21 7:8,
110:22 designated (1)
14;220:17
degree (2) 9:19
dealing (2)
30:1;200:8 desire (1)
217:7;218:4
degrees (3) 119:1
deals (1)
30: 16;31 :1 7;130: 17 desk (1)
117:6
Delgado (5) 18:3
death (2)
69: 12; 188: 19; 189:2,4, Desmond (5)
69:9;122:6
23 67: 19;69:4;74:22;
debate (3)
demanded (1) 111:6;148:15
78:22;1 81:4,7
62:15 Desmond's (1)
debates (1)
demo (2) 110: l1
183:22
119:13;121:9 destroy (2)
decades (1)
Demonstrate (3) 118:23;134:24
93:14
119: 13,20;121:8 destroyed (1)
decalogue (1)
demonstrated (1) 118:24
219:5
151:19 destroying (1)
December (1)
demonstrations (1) 151:3
29:11
196:22 destructive (1)
decide (2)
denies (1) 151:20
101:21;170:5
43:7 detail (1)
decided (3)
Dennis (4) 45:12
44:5;65: 12;130:8
37:23,25;43: 19,20 details (3)
decision (26)
dental (1) 37:1 ;91:14;92:7
40: 10;56:8,12,14,15,
46:4 determine (8)
20,22;59:24;60:5,11;
Denver (1) 19:7;53: II; 158:22;
78:14,14;80:8, 11, 15, 17,
46:3 159: 13; 168:22; 181:7;
20;81:3,5;82:3;85:8;
department (7) 185:19;215:3
87:6;89:18;90:10;
30: 13,15;31 :9;33:10, determining (1)
Stephen Alan Kent
January 5, 2012
53:13
detoxification (5)
73:8,17;111 :14;112:6;
157: 14
develop (1)
202:12
developed (5)
42: 19;96: 1 ;111:17;
151:10;218:18
Development (4)
188: 19;189:2,4,24
dialogue (1)
146:12
Diana (1)
45:10
Dianetics (6)
18:7;44:3; 149: 15;
156:6;207:24,25
dictionaries (2)
216:9,10
dictionary (3)
17:14;112:16;215:3
died (2)
69:4;171:9
difference (2)
86:16; 195:18
differences (2)
62:13,17
different (26)
13: 13;29:2;31 :5;59:25;
65:5;70:19;78: 19;85:25;
95:11, 12; 101:18;107:6;
129:6; 134:3; 135:3;
138: 15; 141:8;155: 18;
174:20; 179: 14; 180: 16;
187: 17,22;192: 18;
195:16;208:15
difficult (1)
78:12
dimension (3)
121: 19;124:2; 137:9
dimensions (3)
37: 18;111: 18;129:6
dinner (1)
25:6
direct (6)
39: 14;72: II ;78:3;
94:21;142: 12;194: 17
direction (6)
104: 16; 114:7;139:6;
141 :5;159: 16; 195:25
directions (1)
146:25
directive (1)
207:20
directives (1)
194:15
directly (7)
80: 13;94:22,23;
124:25;139: 13;161:10;
200:9
director (1)
185:7
(6) cr edentials- director
Desmond, et al. v.
Narconon, et al.
disagree (3)
61:15,20;87:4
disagreements (1)
187:17
discipline (3)
213:16,21,25
disclosing (1)
27:20
disclosure (1)
28:21
disconnect (1)
201:2
Discord (1)
184:5
discourage (2)
209:25;210:23
discovery (5)
8:6,9,19; 148: 17; 168:15
discuss (5)
121: 16; 147: 16;188:23;
192: 13;208: 16
discussed (11)
37: 18;43:5,6;50: 12;
58:5;122: 16; 146: 13;
160: 19;161 :20; 164:3;
208:14
discusses (3)
198:14;200:6;217:18
discussing ( 4)
154: 15;161 :6;176:19;
195:24
Discussion (22)
9: 10;23:25;42: 17;50:6;
77:20;99:3,4;147:23;
150:24;152: 16;160: 14;
161: 12;163: 12; 170: 15;
189: 14; 195:1;196: 11;
201 :6;203: 1;209:7, 13;
216:2
discussions (4)
50:1; 146:24;192:25;
201:17
disparage (2)
113:16;119:7
dispense (2)
145:4, 5
dispute (10)
34: 12;36:2;51 :5;62:4;
82: 17;97:3; 111 :8,9;
159:25; 185:20
disputes (2)
59: 14,18
disrupted (1)
201: 13
dissemination (1)
207:3
dissertation (2)
32:13,1 5
dissuaded (2)
194:18,19
distinction (1)
61:4
distractions (1)
Min-D-Script
194:21 25: 12 151:13
distress (1) doubt (2) drugs (24)
217:9 64:17;1 15:22 96:21; 111:22;1 13:1,2;
divide (1) down (22) 131 :23;133:22;135: 11,
127:4 12:4;26:2;40:20;64: 19, 17, 18;136:3; 138:3;140:9,
divorce (1) 20; 104: 17;113 :23; 9; 146:24; 148:9; 150:25;
43:2 115:10,13,16, 17;117: 13; 154: 13,22; 157:4; 197:9;
doctor (3) 120:9;132:11,14;137:3; 209: 13;210: 1,14,18
49:9,18; 195:3 144:6; 151: 19;152: 18; drugs' (2)
doctoral (1) 194:11 ;210:5, 25 151:21;209:24
32:19 Downs (5) Dual (1)
doctorate (1) 19:13;113:10; 198:10; 10:19
31:7 217:7,13 duly (1)
doctrines (5) Dr (52) 9:12
126:11; 136: 18; 140: 14; 8:5;9:6,16;28: 19;40:2; during (7)
201:21 ;204:6 46:5;47:4;49:17,20;50:9; 25: 11;30:7;33: 12;75:6;
document (31) 56:24;59: 1 0;63: 17;68:6; 143:23; 169:16;211 :9
22: 18,20;23:22;41: 14; 75:8;79:22;83: 11 ;87:15, dynamic (20)
57 :2;59:2;75: 14;76: 10, 17,22;93:25;103: 16; 118:3,5,17,17,18,21,25;
11, 14;77:6;81 :1, 1,2,4; 117:23;121 :3;122:20; 119:2,13,15,15,16,20,23;
1 03:17;104:3;1 05:6; 123:5; 130:2;134:6; 120:4,11,13;121:10, 12;
108:21; 110: 1;116: 12; 143:23; 147:22;148: 14; 122:15
144: 13; 153:9, 13, 14,22; 157: 1; 169: 16; 170: 19; dynamics (9)
159: 1; 171: 16;173:8; 174:7,15;177:22;178:1; 116:20,20; 119:23;
208:3;218:3 179:24; 181 :6;182:22; 120: 17; 121 : 11 , 17, 18;
documentation (1) 183: 14; 185:2;189: 17,22; 160:19;161:9
97:1 190:9; 191: 17;209: 11;
documented (1) 21 1:2,13,17;220:24 E
182:21 draft (8)
documents (64) 7 1:6, 11, 12;89: 13, 17, earlier (24)
13:8,18,22,23; 14: 1,9; 17;90: 1; 159:3 14:8;28:20;46: 14;
24:2;27:2,9;38:6,7,8; drafting (1) 59:24;60:18,21 ;73: 14;
55:21;68:9;70: 1;73: 18; 62:20 83:22;89: 12, 17;93:1, 10;
75:23,24;79: 1 0;85 :9; draw (1) 95:18;104:5;112: 11;
88:3;101:3,4,13;103 :9; 201:22 120:20; 153: 16;157: 17;
104:21; I 05:3,5,21 ;106:2, drawing (2) 169:22;180: 13,18;
3;108: 15,20;109:5,8,9; 61:4;173:12 188:20;211:3;214:2
110:5, 19,23;141: 18; drawn (1) earliest (3)
142:15, 17,20,22;143: 14, 180: I 38: 16;207:9,25
24,25;144:7; 148: 1; drew (2) early (19)
152:1 1 ;155:2,3;157: 19, 94:22,23 38:1 5,1 7;95:8,9,14;
22;158: 1,3,7,8,9;160: 11; drift (2) 96:23;98:22;116: 11;
164:5;191 :25;210:22,23 192:24,24 126: 17,17, 19;133:8;
dollars (1) drill (5) 134: 15; 147: 15;156:6,13;
135:19 196:12,14; 197:14,20, 207:6,24;219:3
done (33) 25 easier (2)
13: 12; 18:24;33: 18, 19, drink (1) 100:21;199: 12
23;34:3;49: 18,21;5 1: 10, 111:23 East (1)
11,13,20,21;71:14;79:6; drinking (2) 212:23
86: 14,18;99:21 ;130:24; 210:4,6 easy (4)
133: 12; 144:5; 156:5,9; dropped (1) 15:25;19:7;21: 1;
157:9;159:6,11;185: 11, 37:2 117:12
16; 186:6; 188:8; 189:8; drove (2) edition (1)
197:17;220:24 26:3;32:16 179:7
door (1) drug (26) editors (1)
43:11 48:20,22;49:4;50: 17' 188:4
dorm (1) 22;51 :4;54:4;96:5,6; Edmonton (6)
31:22 97:5; 101 :23; 105:24; 10:16;32:1 6;35:11;
dosage (1) 112: 1,3; 123:25; 131:24; 36:6,10;65:21
111:24 133: 10; 135: 13,20; 151:2, Education (4)
doses (1) 10,13,24; 153:4;154:2; 37: 15;53:5;57:22;
95:25 210:23 58:16
double-check (1) drug-free (1) educational (1)
Stephen Alan Kent
January 5, 2012
186: 17
EEOC (4)
41: 19;42:9,10;43:21
effect (7)
12: 14; 112:5,6; 11 8:4;
126: 13;128:4;214:25
effective (9)
49:3,3, 6;50:21;51: 1;
217:22;219:17;220: 10,13
effectively (1)
220:17
effectiveness (2)
154:2,7
effects (1)
210:4
efficacy (1)
150:10
effort (4)
100: 15; 1 06:8;135:22;
164:6
efforts (1)
119:4
eg (1)
58:8
eight (6)
16: 14,14;27:4;47: 1;
116:20;117:3
eighth (11)
118:5;119: 15, 15, 16,20;
120: 13;121 : II ,12, 16,18;
122:15
EIIU (1)
36:11
either (8)
61:8;91:20;92:24;
115:4;159:13; 172:24;
182:8;201:18
Elbert (5)
207:8, 17,23;208: 1 ,1
element (4)
79: 12;82: 15;99:6;
151:20
else (27)
8:22;11:4;13:3;21:16;
23:2;27:7;28: 14;34: 10;
37: 19;43:5;51:9,17, 18;
72: 10;93: 19;118:15;
121:4,23;123 :7;159:20;
160:2,22,25; 162:4;
165: 16;187:23;221 :3
E-mailed (1)
11:20
E-mails (1)
27:17
embrace (1)
79:7
embraces (1)
119: 18
emotional (1)
217:9
emotions (1)
217:12
emphasis (2)
(7) disagree - emphasis
Desmond, et al. v.
Narconon, et al.
17:13;136:13
employ (1)
46:4
employed (1)
32:12
employee (1)
45:19
employees (3)
42:7;207:19;208:8
employer (1)
46:5
encompass (1)
123:14
encompassed (1)
143:25
encourage (3)
124: 1; 138:9; 139:3
encouraged (3)
215:2;216:4,9
encouraging (I)
217:23
encyclopedia (1)
215:1
end (7)
12:2; 101:6;115:8;
167:5; 179: 14;206:4, 7
enemy(2)
115:22;200:2
energy (1)
113:24
Enforcement (1)
58:14
engage (2)
140: 10;201:14
engaged (3)
139: 12; 151:22;214:5
England (1)
40:21
English (1)
216: 11
enjoy (1)
127:8
enjoying (1)
31:2
enough (10)
25:24;52:20; 140:22;
141:1 0, 18;150: 13;
159: 18;180:23;220:22;
221:6
enter (4)
99:22;101 :6;102:11;
156:12
entered (2)
89:14;170:1
Enterprises (1)
41:25
entire (2)
73:25;206: 17
entirely (5)
37:20;48: 13; 111:2;
170:22;173:3
entities ( 6)
58:4,12,20,21 ;59: 14,22
Min-L'-Script
entitled (3) 116: 19;127: 18;128:3; exchanges (3)
118:2; 149: 14;180: 10 130:25;140:11;141 :5; 184:3; 193: 14;194:22
entries (1) 142:11 ;146: 14; 148:17; exclusively (2)
77:3 156: 12; 158: 19;160:25; 152:1,2
environment (2) 171:11; 186:23; 194:23; excuse (3)
199:1;208:13 202:9;204: 18;207:21; 28:25; 131 :25;144:21
envision (1) 220:9 exemption (1)
133:7 events (7) 82:5
equivalent (1) 17:23,24;69:3;113:4,4; exercises (7)
180:19 195:7;214:8 28:4;71 :21;72: 1 ;96: 12;
era (1) eventually (7) 98:23;137:7;142:7
107:15 33:16;36:25;37: 1;95:6; Exhibit (110)
erasers-to (1) 96:3;120: 18; 173:19 8:2;10:22;11:6;12:6,
16:24 everybody (3) 17; 13:9, 19;21: 17;23:21;
Erlich (4) 134: 18;170:10; 189:18 24:2;26:21 ;27:20;28: 15,
37:23;38:1 ;43:19,20 everything's (2) 20,24,25;29:16,21,22;
error (I) 172:6,8 34:3, 12;35:4,8;52:3;
122:3 everywhere (I) 57:25;58:22;59:3;62:4;
especially (5) 25:15 68:1 0;69:21; 70:2;71; 3,8,
31 :8; 156:5; 180:21; evidence (8) 18, 19;72: 13,15,18;77:7'
194:5,13 61: 19;88:7;106: 10,12, 23;92:24;94:20; 103:6, 16;
essays (3) 15;11 1:5;137:22;156:18 104:3,20; 105:6,11;
184:20,24;187:25 evidenced (1) 111:10;122:12,21;123:1,
essence (3) 208:18 3; 142:16;143: 19,25;
16: 13;41:13;179: 10 evolved (I) 144:4,6,8,16,24; 145:8, II;
essentially (2) 96:22 146:11,21;147:4,6,11,14;
17:17;134:25 ex (1) 148:5,14;149:3;150: 15,
cstablislt (I) 30:24 20; 152:21,22; 157:12;
187:15 exact (7) 158:8; 159:21 ;163 :7, 14;
established (1) 81 :4;91 :4;94:5,6; 164:4,6,8, 16,18; 166:4;
46:14 132:24; 134:22;20 1:20 168:5;169:11, 18, 18, 19,
Estatt; (1) exactly (11) 20,23; 170: 17; 171: 18,20;
42:13 22:8;38: 11 ,13;87:6; 172:2,9,9,16; 173:17,22,
estimate (1) 92:17;117:13;132:22; 24;196:4,11;197:1;198:9;
26:15 136: 14; 160:6;204:2; 203:25;206:13
estimation (1) 205:4 exhibits (9)
96:10 EXAMINATION (5) 103:4; 108:6; 143:24;
et (2) 9: 14; 17: 18; 188: 17; 144: 15; 169:8,17,22;
124:25;192:1 190:7;211: 15 170:13;191: 19
ethic (1) examined (1) exist (11)
136:9 9:12 109:9; 129:2; 132:1;
ethical (10) example (27) 141: 19' 19' 19; 154: 1;
138:10,15, 19,21,24; 14:2,1 0;31: 13;58: 12; 155:3,3,5;205:5
139: 14;140:10;161 :7,8; 60:11 ;65: 13;79:2;80: 1 0; existence (4)
218:5 91: 19; 100:9;108:23; 65:20; 116:20;119: 16;
etltics (24) 109:6;121 :9;123:20; 195:23
63:22;122: 17;135:4,5, 131 :22; 136: 13; 138:23; existing (2)
13,23; 136:5,5,6,8,15, 16, 139:15, 17; 140:9;156:2; 94:21;140:13
20; 138:8,13;192:25; 165: 16;177:22; 196: 18; exists (2)
202:5,7,8,10,14,18; 201 :23;210:3;217: 14 14:4;43:7
208: 11;220:16 examples (8) exited (1)
evaluate (1) 126: 1,8,9; 162:5,12; 209:8
154:7 165: 14;166:1 ;21 0:5 expanding (1)
evaluated (1) except (2) 136:11
216:15 8:14;34:14 expect (1)
evaluating (1) exception (2) 152:12
98:17 123:5; 160:18 expectation (1)
even (39) excerpts (2) 105:23
16:23;19: 18;24:7; 108:18;109:4 expel (2)
26: 13;34:24;42: 16;48:7; excess (2) 96:5; 112:3
53:13,13, 15;62: 14;66:22; 210:2,6 experience (3)
72:6;85:8;88: 1 0;90:25; excess' (1) 48:20,22; 194:22
91 :3;98:20;101:9; I 09: 1; 210:3 experienced (2)
Stephen Alan Kent
January 5, 2012
120:5, 15
expert (32)
9:20;27:21,24;28:23;
40:19,25;41:2, 10;50: 13;
53:21 ,24;54: 1 ;62:23,25;
82:9;86:2;89:7;97:4,5;
106:6; 123:19;125: 17;
129: 11;130: 17; 141: 12;
174:9; 175:25;176:2;
183:23;217:8;219:12,23
expertise (7)
107:7; 154:7;157:8;
159: 12;186: 14;216: 16;
217:22
experts (1)
40:22
explain (11)
12:6;28:6; 165:18;
194:25; 198: 19;200: 12;
20 I: 17;202:6;204:8;
208: 18;209:25
explanation (I)
201:21
explanations (2)
201:10;207:6
explore (2)
81 :6; 161:22
explosion (1)
152:17
exposed (1)
17:3
express (2)
189:1,3
extensive (1)
151:22
extensively (1)
75:25
extent (5)
29:21;83: 15;104: 10;
122:14;212:9
externally (2)
201 :7;202: 19
extra (1)
24:12
F
facility-is (1)
151:8
fact (12)
20: 16;61: 12;93:21;
102: 13;107: 12; 123:20;
128:2; 135:17;157: 13;
184:9, 10,10
FACTNET(1)
38:3
factor (1)
27:14
factors (1)
112:18
facts (1)
186:18
faculty (3)
(8) employ - faculty
Desmond, et al. v.
Narconon, et al.
31: 10; 185:3,10
fail (1)
201:2
fails (1)
119:23
fair (33)
10:9,1 0;27:23;32:23;
37: 18;43:6,12;47: 14;
52:20;54: 18;66: 12;
79: 15;80:4;83 :2;96: 18;
120:23;124:14;133:24;
139: 16,22; 141: 1, 10;
147:21; 150:13,15;165:3;
177: 14; 179:24;187:21;
199: 15;217:24;218:23;
220:22
fair-gamed (2)
43:4;44:9
fairly (15)
18:1 0;52:20;70: 10, 12,
14;95:16; 106:16;110:2;
Ill : 19;124: 13;164:4;
175:3; 177: 12;204:7;
21 1:19
fairness (1)
82:22
faith (1)
154:24
familiar (7)
72:9;73: 10; I 01: 12;
123: 19; 193:23; 196: 12;
197:16
familiarity (1)
69:25
family (4)
44:5;1 16:23;204: 19;
217:19
far (40)
11 :5,16; 12:3;23:20;
27: 10;34:4,13;43: 18,23;
45:6,22;51:11,24;54: 16;
60:6;62:25;71 :8,9;78: 14;
79: 1,5, 10, 14;80:23;
82: 14;90:25;99:23;
110:2;125:21;129:16,18;
139:6;140: II ; 172:6, 14;
181 :3; 185:4,9;211 :21;
212:7
farther (1)
98:4
fashion (1)
168:11
fast (1)
46:1
fates (1)
116: 14
fatter (1)
152:21
fatty (1)
112:2
favorably (1)
187:12
FBI (1)
1\tin-L'-Script
91:24 9:23; 10:2; 14: 1;15:5; following (1)
fearing (1) 19:17 ;26:9;52: 14;56: 16; 136:18
116:21 57: 19;85: 17; 102:2; follows (1)
FedEx (2) 121 :21; 135:6;156:25; 9:13
26:3,3 162: 1,5, 12;165: 13; follow-up (2)
fee (7) 175:23;201 :19;207:22 189:13;190:9
52:24;53: I ;54: 19,25; finding (1) footnotes (3)
55:3,3;70:16 158:2 179:8,8,14
feel (9) findings (1) Force (3)
50:12, 16;56: 18;120:5, 155: I 7 60: 12;78:25; 180:17
14; 135:9,9, 10;216:22 finds (1) Force' (1)
feels (2) 113:25 180: 12
45:24; 150:23 fine (11) forces (1)
fell (1) 12:2,4; 16:7;57: 13, 14; 78:21
41:13 67:24; 108:5; 122: 11; foresee (3)
fellow (4) 182:17;188: 13;205: I 7 129: 16,19; 159:15
32: 18,20,25;151 :22 finish (2) for-example (1)
fellowships (1) 44:20;87: 18 201:17
32:8 finished (4) forget (4)
felt (2) 25:7;32: 13;51 :8;87:20 I 5:4,14;115: 18;134:22
95:5;114:17 firm (1) forgetting (2)
festscbrift (2) 194:9 51:13;117:3
184:20,21 first (26) Forgive (1)
few (14) 9:12;22:7,24;30:22; 144:9
28: 18;36: 18, 19;46:9; 31 :22;35: 13;43:24;59: 1; forgot (1)
52:7;56:18;57: 18;99:4; 64: 16,23,24;66:8;80: 16; 73:3
117: 11;142: 17;143: 17; 85:6;93:8, 16;97:9; forgotten (1)
167:6;209:3;211:17 104: 18; Ill: 1 0,19; 151 :4; 120:21
fiction (2) 164:8; 178:25;181 :19; form (18)
219:4,10 190:10;193:5 8: 14;24: 14;90:3;
field (4) fit (1) 108: 11; 133:25;142: 1 ,25;
156:2,12;157:8;177: 1 192:14 160:4; 161: 15; 162: 17;
Fifth (1) fits (5) 165:9;191 :7; 196:21;
117: 1 135:21; 139:1; 192:21; 199:17;202:21;203:11;
fighting (1) 194:2; 198:20 206:22,23
207:14 five (3) formal (6)
figure (5) 46:25; 1 I 1 :20;210:5 44:25;45: 1,5;213: 10;
22:22; 158: 19,23; fiX (1) 214:3,5
175:22;216:5 194:10 formalities (1)
figured (1) fixed (1) 8: I I
68:20 218:20 formation (1)
figures (1) Flag (1) 151:25
96:23 42:14 formed (1)
file (11) flat (2) 24:6
11 :9,24;12: 17;13:5; 86:12;102:1 former (2)
57:7; 104: I 9; 109:9; flew (2) 38:5;214:16
110:11,14;148:15;157:20 44:14,19 forms (2)
filed (2) flexibility (1) 49: 12; 196:22
9:18;88:5 44:18 forth (1)
flies (7) flip (3) 134:13
13: 14;25:25;26: 1,20; 142:24;153:10;193:3 forward (2)
65: 14;87:8; 183:20 Florida (I) 19:23;120:16
final (21) 171:8 foul-ups (1)
31:25;62:7,9, 14, 17; fly (2) 200:9
76:22;80: 17;81 :5;82: 18; 44:20;46:1 found (11)
85:9;89:24;90:2,17;91 :5, focus (4) 14:6,24;38: 16;48:5;
11,12,15;92:22;136:9; 29: 13;30:2 I ,22;31 :4 59: 12;60:21;95:3;
159:4;184: 15 focused (2) 170:20;204:23 ;205:4;
fmally (3) 17:23;92: 1 207:16
132: 10;152: 14; 158: 16 follow (3) Foundation (4)
financial {I) 63:23,25;114:18 58: 19,19;212:22;
166:7 followed (3) 218:20
find (21) 91 :20; 129: 14;203:22 foundational (1)
JFiseber@QAReporting.com
Stephen Alan Kent
January 5, 2012
136:9
founder (4)
18:6,11;19:2; 148:6
four (1)
46:25
Fourth (2)
116:25;151:18
frame (3)
88: 4;98:9; 107:15
FRANKLIN (66)
8: 17;9: 1,5; 15: 15;
39:24;40: 13 ;57:6, 13;
59:6,8;66:3 ;67 :24;73 :25;
74:3,8,13;75: I ,5;84:25;
87: 18;90:3;93:23;
103: 13; I 08:11; 117:9,1 4,
17; 122:23; 133:25; 142: 1;
143:9,15;156:22;160:4;
161: 15;162:17; 165:7,9;
168: 13,19,24;169:2,5;
170: 11;188: 13;189:9,12,
16; 190:8,15,18, 19;
191: 13; 195:2;200:3;
203:7,24 ;206:24 ;208 :25;
209:10;211:4,6;215:5,9,
25;221:9
fraud (1)
183:7
free (3)
56: 19;65:3; 109:22
Freedom (3)
58 :20; 1 04:6;203 :21
friends (1)
217:20
front (12)
9:4;45:14;72:21;93:25;
94:20;117: 10;121 :2;
122:22,24; 125:6,8;
184:15
frustrated (I)
182:18
fulfill (1)
115: 12
full (2)
10:14;134:19
functional (1)
89:1
Fund (1)
58:15
funding (2)
32:3,6
further (3)
59: 17; 132:2;211: 15
G
gains (1)
120:9
game (5)
37: 18;43:6, 12; 139: 16,
22
Gandow (1)
184:22
(9) fail - Gandow
Desmond, et al. v.
Narconon, et al.
G-A-N-D-0-W (1)
184:22
gaps (1)
98:11
garage (2)
43: 11;215:15
Garcia (5)
207:12,14, 16,17,22
gate (1)
103:24
gateway (1)
103:24
gave (4)
173:9;174: 1;207: 13,16
Gee (1)
130:16
Geez (3)
22:8;33:22;42:16
general (13)
18:20;53: 16;69:25;
102:21; 1 03:2;104: 14;
131:19,21; 132:9;133:21;
138:2; 143:4;220:15
genemlities (1)
199:4
generally (14)
99: 12,20; 174:19, 24;
175:4;191 :18;193: 13;
194: 1; 198:19;200:12;
202:6;216:12;219:6;
220:18
generated (3)
13:5;153: 10;218:2
gentleman (3)
53: 14;95:2; 176:9
gently (1)
198:5
genuinely (1)
136:2
Georgia (59)
8:21 ;9: 17,18;21 :9;
24:24;28:7;29:9;52: 19;
54: 18;55:6;61: 18,24;
63: 12,15;66:16,1 9;67: 18;
69: 15;72:23;83: 13,14, 19,
21 ;84: 16;85:19;86:3;
87:7,23 ;88 :4,8, I 0;92 :3;
99:6,9, 14,17,24,25;100:1,
25;101 :15;102:20;
I 04: 13,22,25; 107:4;
109: 14;110:12, 17; 111 :2;
128: 13,23;129: 14;
139:21 ;146:7;150:7,9;
159:13;190:1
Georgia's (6)
28:3;71 :20;87:2;137:6;
142:6;159:7
German (4)
184:11, 15,17, 20
Germany (2)
184:11,23
gets (12)
17:3,10, 11;53:8,9;
1\'lin- U-Script
115: 16;135: 17;138:1; great (3)
152: 15;185: 15; 188: 1; 53: 13;95:21 ;96: 15
197:22 greater (1)
given (7) 200:8
64: I ;80:2;90: 11; greatly (1)
108: 18;1 09:23; 172:16,17 132:1
gives (4) green (1)
19:23;86:23; 194: 14; 212:12
201 : I 0 grew (1)
giving (2) 134:23
52:6;175:25 grounds (2)
glanced (1) 46:7;88:6
68:13 group (5)
Glendale (1) 36:23;43:3; 180:20;
212:23 181:22;200:19
Glendale's (1) groups (9)
213:1 70:9,11,20;177:2;
global (1) 180: 16; 184: 13;185: 12,
135:1 17;203: 18
glossaries (1) guarantee (1)
211:25 63:23
glossary (3) guess (10)
206:4;215: 1 ;216:7 22:22;34:1 ;37:20;
goal (3) 46:19;82:9;117:25;
133:21 ;134: 15,24 179:23; 180: 13;187: 15;
God (11) 205:8
90:25; 180:21 ;181:23; guideline (1)
182:2,4,7 ,8,9, 14,15; 202:1
215:17 gun (1)
goes (18) 45:15
48: 12;53:2,3,3,4,6,7;
54: 19,20,20;95: I ;115: 13; H
133: 13; 145:1; 151 :6;
196:3; 199:3,8 H-A-L-A-H-H-M-1 (1)
good (18) 177:8
32:3;41 :6,7;72: 19, 19; half (1)
85: 15;98:6; 120:5,14; 25:10
134:12;145:25;173:19, hammered {1)
19;180:23;181 :2;200:2; 41:6
220:15,16 hand (3)
goodness (2) 173 :8;194: 12;206:8
117:8;166:6 handicapped (1)
Gordon (7) 30:9
185:2, 3,4,23; 186:13, handle (3)
20,24 42:20;110:9;201 :1
government (8) handled (2)
59: 11,22;60:2,3,7; 132:8;191:10
82:25;89:4; 184:15 handles (1)
governments (1) 191:9
20:5 Handling (1)
grab (1) 200:5
103:13 happen (1)
gradient (2) 33:25
17:3,6 happened (12)
graduate (8) 32:5;44: 11 ;45: 1,20;
30:11 ;31:6;32:3,24; 69:5;76:23;80:22;
44: 15,16; 178:8;182:20 104: 12;176:4;207: 14;
graduated (1) 208:6;215:20
122:5 happens (3)
graduates (1) 53:9;91:25; 114:19
99:21 Happiness (27)
Graeme (1) 20:2,7;21 :23;58: 18;
37:14 80: 10,13;114:20,24;
116:4,5, 7,9;138: 14,23;
139:4;206: 14,18,18;
207:2;209:22;210:9, 12;
212: 18,22;218: I, 18,20
happy (2)
142:10;180:4
harassed (1)
91:20
harassment (1)
37:6
harassments (1)
43:8
bard (3)
105:13; 160:7;207:21
hardback (1)
116:8
harm (12)
66:21,21; 127:21;
128:9;129: 1,4,17;130: 19,
22,24; 131 :3; 141:17
harmful (17)
48:11,15, 17;66: 18;
67: 1,8,18; 127: 13,25;
128:1,4,11,21;129:13,22;
209:24;210:1
harmfully (1)
154:22
harming (1)
127:16
Harris (5)
23: 1,7;65:8;166:25;
170:19
head (6)
16:3;42:4,4;48: 12;
84:7;110:17
heading (1)
118:21
health (1)
154:22
healthful (2)
49:23,24
hear (3)
165:2; 199: 12;221:5
beard (5)
70:6;100: 14; 123:23;
183: 12; 190:10
bearing (2)
86:13;140:6
hears (1)
202:3
held (1)
134:19
Helena (2)
189:7,25
help (13)
27:7;45: 13;56: 19;
102:1 ;110:9;131 :19;
133:22; 134: 18;140:9;
148:9;216: 13,21 ;217:2
helped (2)
32: 11;112:3
helpful (2)
67:1,8
Stephen Alan Kent
January 5, 2012
helping (6)
93: 16; 112: 14;132: 15;
154: 12;201: 18;219: 18
helps (5)
31: 15; 136:3; 151: 14;
194:21;217:14
helpspeople (1)
104:6
Hence (4)
11 1:22;133:17;136:15;
202:15
here-is (1)
179:15
here's (1)
151:13
herself (1)
113:25
hesitancy (2)
87:22;168:16
hesitant (3)
86:12,17;110:21
hesitate ( 4)
45:23;80:21 ;85: 13;
139:5
hesitating (1)
175:13
higher (3)
123:21,22;161 :4
him- (1)
113:25
hindering (1)
131:21
Hindi (1)
30:24
hindrances (1)
134:18
Hinduism (1)
30:23
hire (1)
65:12
hired (6)
45:3,4,6;67:20;130:23;
137:10
hiring (1)
110:1
historians (1)
97:7
historical (3)
99:1;164:12,13
History (13)
30:22;76:22;94:24;
95: 19;147: 16,18,19,22,
25; 151 :4,9; 185:5,6
Hmm(1)
12:1
bold (2)
127:10;198:5
holidays (1)
26:5
Holy (1)
215:18
home (2)
24:25; 158:2
(10) G-A-N-D-0-W- home
Desmond, et at. v.
Narconon, et at.
honest (2)
114:21,22
honor (4)
20:5;184:21,22,24
hope (3)
135:4; 139:5;208:5
hoping (1)
173:6
horse (1)
67: 12
hospital (1)
42:3
hour (3)
25:10;166:10,11
hours (10)
25:24;26: I , I 0;27: I ,3,4,
11 ;46:9; Ill :20; 166:22
housing (5)
54:8,10, 11 ;188:21,23
Hubbard (73)
18:5,6,9,1 1;19: 1,9,24;
20:3,8;38: 18,19;42: 19;
52:22;79:8;93:3;94: 14,
17;96: 1,8;111: 12, 17;
1 12:24; 114:15, 17;
116:11; 124: 17,24;125:3,
9, 19,23; 126: 19; 131:13;
132: 18, 19; 133:7; 134: 15;
135:5; 138:9, 11, 18;140:7,
25; 141: 16; 151: 18;
154: 18;155:8, 13, 17,20;
156: 16;160:2,9, 16;
172: 11;197:8;199:20,25;
201 :20;203:16, 17, 19,22;
207:8,8,23,23;208: 1,2,2;
218: 19,22;219:1
Hubbard's (27)
17:22,22;55:3;79:16,
19;80:6;84:4;95:20;
96:21; 111:21 ;125: 14;
126:7,10,14; 133: 17;
134:23;137: 17;138:20;
140:8; 150:5; 165: 19;
202:24;203 :2;204: 13;
205:9;207: 17;208: 13
Human (2)
58: 13; 176:20
humanities (1)
31:1 1
humankind (1)
116:25
hundreds (2)
155: 14, 14
hurting (1)
202:1 I
hygienist (1)
46:4
Hynes (15)
169:13;170:1;188:11,
18;189:23,23;208:22;
209:2,4,8;215:8, 11 , 14, 19,
21
hyphen (1)
Min-D-Script
177:7 19:25;20:4;57:20; individual (7)
hypotheses (1) 114: 18; 122:9;128: 17; 48:13;119:22; 136:16;
156:9 158:16; 195: 10,12 144:7;20 I :20;204: 17;
impossible (1) 207: 15
I 94:8 indulge (1)
impressed (2) 122: 10
1-20 (1) 95:4;1 19: 10 infer (1)
41:19 impression (2) 81:3
idea (3) 123: 13; 186:23 infinity (5)
76:22;90:22;170: 19 improve (2) 117:2,4; 119:16,18;
Ideas (3) 110:9;219:13 122:5
118:25;196: 17,21 improvement (5) influences (1)
identical (2) 109: 19; 112: I 0;196:5; 113: 14
133:4;220:9 219: 12,16 influencing (1)
identification (11) inadvertently (1) 144:19
8: 1;57:24;72:14; I 03:5; 148:21 information (8)
122:25; 143: 18;163: 13; inappropriate (1) 12:25; 17:4,5;55:7;
169:10,21; 171 :17; 173:21 182:19 64:3,12;92:21; 180:24
identified (15) inartfu1 (1) infringement (1)
14:5;28:23;47:20; 10:5 38:22
49: 12;68: 10;80:24; Inc (2) inherited (1)
94:20;118:2;131 :12; 37: 15;72:24 183: 19
133:7;150: J 7; 160:20; incidents (1) initial (1 0)
172:4,16;179:15 44: 10 11: 11;12:24,24; 16:8;
identifies (3) include (5) 49: 12;55:22;109:24;
109: 18; 198:22;199:6 26:24;27: 12;46:22; 134: 13, 15;184:23
identify (15) 50:2; 164: 15 initialed (1)
110:8; 11 5:4;120: 16; included (10) 74: 18
121:5,13,23; 123:8; 82: 11; 124:24; 145:20; initially (2)
131: 19;137:5;138: 15; 149:3;151: 16;152: 15,17; 36:21; 182:2
143:7,25;144:4; 161: 18; 182:12;210:8,10 inkling (1)
185:22 includes (2) 175:7
identifying (2) 118:21;193:12 in-prison (1)
131:4; 132:7 including (4) 96:17
identity (1) 111 :25; 121: 11;169:22; inside (1)
118:20 186:8 203: 1
l'd've (1) income (1) insights (1)
30:25 185:14 53:19
ignore (1) incomplete (2) insistent (1)
29:23 108:16;109:8 43:7
ignoring (1) incorporate (2) inspiration (1)
112: 15 126:7; 132:18 18:7
illnesses (2) Incorporated (4) instance (2)
200:6,8 58: 17; 124: 18,21; 43:24;210:20
illustrate (1) 132:20 instances (1)
140:23 increases (1) 14:5
illustrations (1) 115: 16 Institute (3)
119:9 increasing (1) 41 :25; 185:7; 186:3
image (1) 111:24 instructed (1)
216:21 indeed (3) 41:3
images (2) 106:5; 136: I ;214: 16 instructions (1)
131:24;132:1 index (1) 24:10
immediately (1) 206:4 instructor (2)
40:25 indexes (2) 33:1;45:15
immortality (1) 205:24;206:3 Integrated (1)
122:5 Indiana (1) 36: 10
impact (1) 183:15 Integrity (7)
56:22 indicate (3) 19:22; 114:1 1,13,23;
implications (1) 52:8;64: 15;94:3 11 8:3;136:22;220:2
141:6 indicated (2) intelligence (3)
importance (1) 52: II ; 120: I 36:9,10,13
135:2 indication (l) intend (12)
important (9) I 79:9 28: 16;49:25;62:2;
Stephen Alan Kent
January 5, 2012
69: 19;85:21 ;99: 11;
126:24;128:25;129:24;
139:23;141:17,23
intended (2)
106:19,21
intent (1)
106:4
intention (10)
47: 17;49:5,19;67:20;
76:9, 19; 129: 17; 154:14;
194:6,9
intentional (1)
34:5
intentions (1)
29:14
interact (1)
63:12
interaction (2)
44:4;55:5
interactions ( 4)
29:3,7;55: 13;63: 14
interacts (2)
63:4,8
interest (3)
23: 16; 127:18;208:4
interested (2)
151:18;152:4
interesting ( 4)
89:5;99:1; 128:7;
158: 15
interests (3)
41:3,12;183:19
interference (1)
36:22
interject (1)
136:4
Internal (5)
59: 15;60: 1,13;84:11;
202:10
internally (1)
202: 19
International (32)
9: 17;28:7;46: 15;52: 18;
53:4,12;55:6, 13, 18,20;
56:4,9,25;58: 18;61: 1,25;
63:2,4,8, 12, 15;69: 16;
80: 1 0;92:5; 1 00:25;
145:23; I46:7; 159: 14;
190: 2,5, 11 ;212:23
International's (4)
28:6;29:11;52: 17;
159:9
Internet (8)
19:7;21: 13;25:12,17;
38:7;39: 19;40: 17;42: I I
interpersonal ( l)
216:19
interpretation (2)
194:15;214:12
interpretations (1)
186:25
interrupt (2)
208:22;215:5
(11) honest- interrupt
Desmond, et al. v.
Narconon, et al.
interrupted (1)
19:11
interrupting (1)
32: 14
intervention (2)
127:20,21
interventions (1)
182:19
interviewed (1)
214: 8
into (53)
17:25; 18: 16;30:25;
31 :4;32:5;33:9,11;42:2,2,
6;52:24;53:4,8,10;66:20;
67: 15;89: 14;93:8;96:3;
10 1:5,6;102:23; 1 03:23;
106:8;107:2;113:6;
114:8; 115:13, 16, 17;
124:18,21 ,25; 132:20;
135: 13,21,23; 138: 1;
139: 1; 144:6; 161:6;
166:5;185: 12;192: 14,21,
24; 194:2,6; 195:8; 197:23;
198:20;205: 11;208:13
introduce (3)
106:11,13, 16
Introspection (1)
42:18
investigating (1)
36:13
investigation (1)
75:22
involve (8)
46: I 5;95: 10;117:4;
130: 19;138: 13; 196:22;
197:25;201:18
involved (10)
32:6;36:3;62:22;75: 18,
20,2 1 ;95:10, 11;131 :23;
198:4
involvement (1)
131:24
involves (6)
17:2;93:6; 111: 18,20;
131:17;204:17
involving (13)
16:22;23: 19;34:11;
36:21 ;37:5,6;41 :24;
50: 15;75:9;80:3;82:4;
129:5;212:20
IQ (1)
109:25
Ireland (1)
44:2
irrelevant (1)
108:7
IRS (53)
55:22,25;56:8,12, 14,
15,20,22;57: 1 ;59:7,23,
25;60: 11;62:3,7,8,15;
78: 13,14;79: 19,21 ;80:7,
11, 15, 17,20;81:3;82:3;
83:1 0,17,18;84:2,14;
Min-U-Script
86: 14,I8;87:2,5,25;88:6; Journal (8) Kentucky (1)
89:8,14;90: 14,20;9I :8, 62:1 1 ;89:20;90: I ; 172:21
I9;92: II; I09: I; I45: I2, 156: 13; 177: 10; 181:11; kidnapped (2)
15;146: 13, 15;158: 12; 187:10,24 176:10,14
171:7 journals (2) kids (2)
IRS's (2) 156:13; 186:5 36:23; 114:6
81:24;85:8 Judaism (1) kill (1)
Israeli (1) 123:14 20:4
177:6 judg (1) Killam (2)
issue (19) 105:15 32:20;33:10
35:23;39:11;40:5; judge (1) kind (23)
41 :23;48: 1 0;131 :3; 41:3 61 :7;71: 13;91 :24;
13 7:20; 139: 16; 150:21; judgment (2) 98: 18; 107:6; 114:24;
151:I1;152:8;154:16,23; 186:18;188:4 127:10, 19; 129:25;
157:7; 158: 15;188:23; jumble (1) 136:25; 141 :6; 152:7;
201:11 ;214:24;217:8 100:21 155:8,9, 15; 156: 15; 157:9;
issues (38) jump (1) 182:11 ;183: 12,21;
42:21;43:6;54:10; 144:14 201:21 ;203:5,5
66:20,22;92:9;97:4; June (1) kinds (5)
120: 16; 122:7; 128:8,25; 58:6 43:8;51: 1; 135:20;
129: 1,4,5,17; 130: 19,22, jungles (1) 163:21 ;194:22
24; 131 :20; 132:7; 133: I 0; 207: 15 Kisser {1)
137: 10; 141 : 17; 145:22; jury (4) 175:19
147: I; 149:4; 154:10, 15; 85: 19;86: 1; 141:20,20 kit (1)
159: 17; 161 :6, 7,10; Justice (1) 121:9
174:22;181 :20;187:22; 58:15 knew (6)
213:18;218:5;220:4 20:23;25: 14;175: 18;
item (1) K 181: 18;207:23;208: 1
184:19 knocks (1)
items (3) keep (13) 135:14
145:20;163: 16; 196:23 34:16;64:18; 136:9,10; knowing (2)
items-paper (1) 169: I ,24; 177: 12; 180:5; 19:19;162: 19
16:24 202:8,1 0;209:5,6;213: 18 knowledge (19)
lzaak (1) keeping (1) 18: 10,21 ;62:21 ;75: 16,
32:19 156:8 21 ;76:7;89: II ,12;90: 16;
keeps (1) 100:6; 123: I 8; 125: 14;
J 115:16 147:22,25; 175:8;202:4,
Ken (7) 13,15;214:10
James (8) 35: 17;36:5,6,9;37:7,8; knowledgeable (2)
181: 16, 18,20;182:9, 10, 43: 17 92: 19,20
12,17;186:9 Kendrick (2) known (4)
January (1) 191: 1, 1 16: 17; 18: 15,18;92:21
32: 17 Kent (40) knows (3)
Jason (2) 8:5;9:6, 11, 16;10:16; 16:21;202: 14;219:7
176:8; 183:23 28: 19;40:2;47:4;50:9; Kobrin (12)
Jeff (8) 56:24;59: 1 0;63: 17;68:6; 190: 1,2,5,13, 17, 17, 18,
23: 1,7;65:8; 166:24; 75:8;83: 11 ;87: 15,17 ,22; 20;191 :4;211 :3,5,9
170:1 9,21 ;171 :11 ;189:21 93:25; 103: 16; 11 7:23; Korbin (3)
job (6) 121 :3; 123:5;130:2; 190:10,12, 14
31 :24,25;33: 15, 15; 134:6; 143:23; 147:22; Kostelnyconcerning (1)
115:12;204:18 157: 1; 169: 16;170: 19; 45:10
job-1 (1) 178: 12; 179:24;189: 17;
33:2 190:9; 191:17;209: 11; L
jobs (2) 211 :2,13, 17;220:24
30:8;32:22 K-E-N-T (1) labeled (1)
Joe (1) 10:16 115:20
199:6 Kent-0737 (1) lack (1)
Johnston (2) 12:9 119:9
43:25;44: 2 Kent-0907 (1) laid (4)
Johnston's (1) 12:9 138: 18;139: 15;203:23;
45:4 Kent's (4) 205:3
join (2) 79:22; 122:20; 148: 14; language (3)
44:4; 101:21 180: 11 40:23;71:10;216: 11
Stephen Alan Kent
January 5, 2012
laptops (1)
4I: 8
large (2)
26:22; 152:25
largely (2)
88:2, 12
larger (14)
53:8; 108:20;109:4;
132:11; 135:21; 136: 19;
137: 10; 138: 1; 139: 1;
149:5,7,9, 12; 194: 12
Las (1)
45:15
last (20)
II :3;24:25;25: 1;45:23;
66: 13;74:20;81: 1;84:21;
89: 17; I 06:7,18; I I7:24;
118: 1; 168:4;177:7;
183: 12;184: 19; 191:20;
211:2;212:2
Late (5)
90:25;91:1; 112:24;
116: 10;181:19
later (15)
16:4;36: 19,19,20;41 :9;
96:9;97:22;1 03:25;105: I,
24;1 15: 12;194:22;
195: 14;219:3,9
launched (1)
44:11
law (3)
39: 18;58: 14; 191:12
Lawrence (1)
38:3
lawsuit (5)
9: 18,20;44: 12; 128:24;
129:10
lawsuits (5)
75:9,17;76:3,8,21
lawyer (6)
39:6;53:21 ;90:14, 15;
130:8; 162:23
lawyers (8)
13:1;24: 16;27: 13;65:3,
6;71 :4; 164:23; 170:20
lay (2)
37:5;204:20
lead (1)
114:7
leader (2)
53: 12;182:3
learn (5)
16:20;1 12: 13;168: 1;
219: 13,18
learned (1)
206:10
learning (1 1)
16: 19,20,22; 17:2,4;
112:9, 13, 13;196:5;
219: 12,16
least (18)
14: 12; 17: 19;22:21;
27:3,6;59:20;64:24;70: 9;
(12) interrupted - least
Desmond, et al. v.
Narconon, et al.
95: 1; 124:19; 173:1;
180: 18; 185: I ;186: 19;
194: 16; 198:22;209: 12;
216:7
leave (7)
68: 1; 10I :6; 130:4;
133: 13; 140: I4; 146: 19;
161:12
led (1)
151:25
left (4)
33: 10;34:5;36:22;43:3
legal {14)
23:19;34:2,3,11, 14;
35:4,14;46:24;47: 11 ;
53:21;78:12;80:9;
178:21 ;211 :8
legitimate (1)
178:20
length (1)
53: 11
less (5)
50:21 ,25;1 05:21;
112:22;142:12
lesser (1)
200:8
lesson (1)
192:21
letter (9)
27:20,22;71:4,7;
182: 12, 13, 14,23;20 I :20
letters (1)
182:23
level (5)
17:5;38:8;56:22;
115: 10;204: 17
levels (7)
115: 13;116:20; 119:25;
138: 12; 139:7,1 1, 12
level's (1)
116:22
Lewis (11)
181:16,17,1 8,20; 182:9,
10, 12, 17,22,24;183:7
Lewis's (1)
186:10
library (1)
95:3
license (1)
91:23
licensed (1)
54:5
licensing (6)
53 :25;54:3, 19,24;55:2;
70:15
Life (20)
19: 13;73:4,17;1 04:1;
109: 19;113: 10, 15;
115: 19;118: 19; l I 9:2,3,5;
131 :20; 151 :7;198:1 0;
204:1 ;213: 17;217:3,10,
14
life' s (2)
Min-L-Script
217:7;220:17 111: 19;127:13, 16;128:4; lowball (1)
light (2) 149:6;168:25;183:21; 26:25
99:2;134:2 184:7; 192:23,24;207:5 lower (2)
like-flip (1) longer (3) 115:17,17
153:21 26:3;41:6; 176:5 Lowery (1)
limit (3) look (37) 46:5
69:2I; I 27:20; 131:4 13:25; 15:25; I6:I6; low-key (1)
limited (3) 18:2,2;20:21;22: 17; 177:13
52: 12;96: 13;133:3 27:22;28:20;43: 16;56:7, low-level (1)
line (5) 15;57:2;73: 1,16;74: 17; 102:7
89:6; 126:6; 136:12; 84: 1;87:5;95:20; 112: 16; LRH (1)
157:1;213:3 116:5; 121 :25;129:5; 151:10
lines (3) 130:23; 136:23;143:24; Lustful (1)
106: 14; I 07: 19;161: l9 144:22; 158: 18;163:9; 182:2
Lisa (3) 168:21; 197:4, 14,15;
42: 13;43:22;171:8 207:21 ;215:3;216:4,9 M
list (12) looked (32)
14:23; 15: 11; 16:2;34:6; 13:10; 14:7,1I ;2I:6,21; MA(2)
41: 17;56:25;71 :14,15; 22:2;24:23;25:1;30:8; 30:22;31:5
76: 21;77: 1;171 :21;204:9 53: 14;66: 13;72:2,4,7; magazine (2)
listed (5) 73:2,9;74:9, 15,17,21; I09:6;146:22
11 :3;34:2, 14; 113:19; 75:25;77:22;82:3;90: 17; magnesium (1)
172:6 92:22;98: 1,6,1 2;110:20; 111:23
lists (2) 148: 16; 187:11 ;211:25 major (5)
121: 11; 148:15 looking (21) 29: 13;72:6;82: I2;
literally (1) 17: 13;21: 12;39:9;59:2; 151:5; 192:5
206:6 60:20;79: 1 ;92:24;98: 17; majority (5)
literature (1) 107:7; 111 :3; 120:2; 28:2;71:20; 137:5;
25: I 6 122:20;158:21; 159:21; 142:6;162:7
litigation (3) I79: 7, 13;191 :23,24; makes (6)
38:22,24;170:5 193: 19;205:24;212:4 85: 12; 135: 19; 151 :3;
littl e (12) looks (30) 165:23;178:1 1;203:13
16:4;28:9;86: 1 0; 11:13,15; 12:2,2,4,19; making (4)
107: 13; 140:1; 143: 10; 29:25;30:4, 16;49: 13; 49:5, 19;131: 18; 194:20
145:24;159: 16;175:6; 56:8;57: 11;77:8,8,10; man (2)
179:23;201 :4;203:8 79:6;1 05:13,14,15,17, 18; 96:19;151:22
live (2) 114: 1; 118:9; 148:5; management (5)
10:14,I 6 149: 15; 153:9,14, 16,21; 42:1 ,2,5;45: 14;46:6
lives (3) 212:19 mankind (1)
132:8;151 :3;212: 10 Lorne (6) 116:24
Living (4) 177:22; 178:1; 180:8,15, Mann (1)
53:5;57:22;58: 16; 22; 188:4 173:11
190:24 Los (1) manner (2)
load (1) 191: 16 177:19;194:9
44:18 lot (28) many (17)
local (1) 18: 19;32:22;36:15; 18:13; 19:17;42:6;78:3;
36:8 38: 15,24;39: 18;40: 16; 86:8; 1 13:6; 126:1;
locate (3) 53: 17;78:22; 107:22; 132:24;155:7; 175: 15;
115:24;116:1;214:1 126:16, 17; 128:6,8;156:6; 177:2; 178: 12; 192:7;
located (2) 157:24; 161:7 ,17;162: 19; 207:18,18;211 :12;213:23
103:9; 191:14 167:9;184: 1 0; 185: 11,16; Marburg(2)
location (3) 194: 14; 195:22;200: 15; 177:10;181:11
31: 16; 197:22;213:2 214:15,1 8 marching (1)
1ocational (2) lots (1) 104:1
17:24;163:19 70:14 Marietta (1)
locationals (2) loud (1) 208:23
17:22;113:7 194:9 mark (14)
London (2) Louis (1) 57:16;72:12; 103 :3;
40:21 ;43:20 37:13 I I 0:7;122: 12,19; 143: 14;
long (22) Love (2) 151: 11;1 64:6;1 68:6,9;
16:6;22:3;23: 16;24:21; 100:11,13 169:7; 171: 15;173: 16
25:4;31 :23;36: 1 ;38:23; low (1) marked (30)
44: 13; 108:2; 110:20; 115:15 8: 1;10:22; 12:7;27: 19;
Stephen Alan Kent
January 5, 2012
57:24;59:2;62:3;72: 14,
17;77:7; 103:5; 104: 19;
II 0:6,6;119:25; 122:25;
I23:3; 143: 18; I52: 13;
I58:7; I63:9,13; I68:4;
169: 10, I7,22;170: 18;
17I :17 ,20;173:2I
markets (1)
135:3
marks (2)
58:10;122:4
married (1)
114:1
Marschalk (1)
68:3
Mary (6)
24:9;44:2;45:3; 110:18,
18;111:3
Maryland (1)
30:2
mass (5)
I6:25,25,25;I96: 17,21
master's (3)
30: 16,18,20
material (14)
13: 13,22;24:6;25:2;
26:8,23;73: 1 0;87: 14;
Ill :4;201: 14;206:5,25;
214:18,20
materials (81)
11:9,25; 12:17;13:5,11,
20;14: 17,24;16:4, 17;
18:8;24:24;25:21,25;
26:2,21 ;28:3;52:21 ,23;
55:3;65: 13, 17;67:6,17;
68:22;70:3,8,17;71:21,
25;78:24;79:6,25;80:5;
83: 13,24;84:1;94:6;
97:22,24;98: I ,2,5, 17 ,18,
21,23;99:2,8;104: 19, 19;
121 :3,24;123:7; 124:22;
125: 18; 131:13, 15;
132: 17;133:21 ;137:6, 16;
140:6, 7,24;142:7; 148: 15;
150:4; 176:1; 191: 18,20;
192:3;195: 16; 205: 1,7,14;
209:12;210: 15;214: 11'
12;219:16
matter (6)
12: 18;24: 11 ;46:24;
64: 16;68:23;76: 14
matter-drugs-is (1)
151:5
matters (9)
34:1 1,14;35:5;43:14;
46: 11,19;47:11;124:20;
2 11:8
may (74)
8:7; 15: 14;20: 16;29:21;
38:7;49:7,17, 17,20,20;
60: 17;63: 12;68: 17,24;
69:3;74:6,6;85:2;88: 15,
16, I 7,17;92:20;98: 11;
(13) leave - may
Desmond, et al. v.
Narconon, et al.
99:2;1 04:10,10, 12;
105:18;109:9;111:2;
115: 12,20; 116:21; 117:3;
120:8, 16; 121:6, 16;
127: 17; 130:21,21;
131 :20;135:8,9, 1 0;136:2;
140:1 ;141 :7;143: 16;
148: 1,16,17; 154: 1,17;
163:20,20;167:6, 11;
168: I ;170:17;172:1;
173:4;175:4;179:6;
189:8; 197:3;199:16;
20 1:4;202: 18;204:3;
214:22;218: 17;220:8
Maybe (17)
29: 15;35: 12;41 :6;46: 1;
56:1;59:1;77:11;86:10;
92: 1;109:3;112:24;
113:1 ;144:7; 147: 18;
168:20;176:4;214: 12
McMaster (6)
31 :8,9;32:2,3,7;33:9
McMaster's (1)
31:1 1
McPherson (3)
42: 13;43:22;171 :8
MD(2)
49:12,13
mean (52)
12:4,20;23 : 15;33:22;
39:12;70:8;74:8;81:10,
25;89:2;90:10;91:3;
92: 18;95:20; 102:1;
119:7;123:15;129:1,21;
130:9; 131: 16;134: 11;
141 :1; 147:20;149: 12;
154:6;155: 14,24; 159: 16;
160:7,1 0; 161 :23,24;
165: 15; 166: 19;175:4,21;
186:4; 187:21 ;188: 12;
199:25;203: 14;204:7,10;
205:6;207:4;209: 1;
215:5;216: 15,24;217:21;
220:19
meaning (2)
202:17;215:4
meanings (1)
174:21
means (5)
138:22;165: 19;194: 11;
199:24;202:7
meant (3)
134: 17;209:24;210:2
measure (1)
157:10
Medical (12)
41: 19;49:9,11,18;
66:22;1 12:5;129:7;
130: 19; 147:1,1; 149: 17;
154:10
medicine (3)
50:15;150:11,11
meet (1)
Min-D-Script@
24:21 17 99:5;117:12;167:6;168:2
meeting (6) might (52) mirror (I)
36:14, 15, 16,18;166:24; 8:16;9:24; 15:21 ,22; 198:23
208:23 16:21; 18:21 ,22;51: 16; misrepresenting (1)
meetings (1) 52:12;54:5,8,21 ;56: 18; 187:13
213:11 61 :6;66:23;68:12;77:25; miss (1)
Melton (6) 78:8;84: 13;97:7;98: 19; 122:8
185:2,3,4,23; 186:20,24 101: 19; 102:2;113:24; missing (4)
Melton's (1) 116:10;117:11;118:11, 20:9,15;73: 11 ;108: 16
186:13 12; 122:8; 128:2; 130:1 '15; misspoke (1)
member (2) 132:21 ,25; 134:9; 138:4; 190:6
185:4,10 144: 1;152: I2,25;I 54: I 1; misspoken (1)
members (13) I 58: I 1; 159: 14;162:5,13; 218:17
44:5;106:9;126:25; 163: 17;167:24;182:25; mistaken (10)
137: 14;196:6, 15;197:2; 184:25; 199:25;201 :22; 17:17;36:3;43: 1;45:2;
198:11 ;201 :7;204:2; 204:15;216:8 98: 15; 117:5;152: 19;
206: 15,20;214: 16 migrated (I) 195:20; 197:5; 198:14
members' (1) 96:3 mistakes (1)
202:2 military (1) 15:21
membersScientology (1) 207:12 mistreating (1)
28:1 MILLER(99) 151:2
members-were (1) 8:4,24;9:3,6,7,15,16; misunderstanding (1)
38:6 15:18;40: 1;50:8;57:4,9, 74:11
memory (4) 16;58:25;59:9;66:6; misunderstood (7)
15: 1,3;26:20; 102:13 67:22,25;68:5;72: 12,1 6; 17:7 ,8,13,14;20 1:11,
mental (2) 73:20;74:2,6,10,15, 16; 19;214:24
131:24;132:1 75:4,7;77:21 ;85:2,16; mixed (2)
mention (13) 87: 19;90:8;94: 12;1 03:3, 19:13;152:20
60:11;79:3;83:23; 8,11,15;108:14;117:19, mixture (1)
11 6:13,15;149:25;150:1; 22;118: 14; 122: 19;123:2; 78:5
161:10;179:19; 192:10; 129: 16; 134:1; 142:14; modeling (2)
195:21;209:13;211:20 143: 13,16,22;145:7; 16:23,23
mentioned (13) 147:24; 156:20,23,24; modern (5)
23: 12;29:3;58:24; 160: 17; 161 :21; 162:21; 98: 18,24,24;106:18;
60:15;68: 12;97:21; 163:8,24;165: 10;168:8, 107:15
109:11;117:4;163:19; 16,20,25; 169:3,7, 15; moment (1)
180: 18;182:22;206:3; 170:3,9, 12,16; 171:15, 19; 9:7
211:3 173: 16,23; 188:7, 12,14; moments (I)
mentioned-at (1) 189:7 , I 0,25,25; 190:3,6; 93:9
14:11 191 :7; 199:17;202:21; money (1)
mentioned-on (1) 203: 11;206:22;209:3; 53:6
14:12 21 1:9, 16;215: 13,18,20, Montgomery (6)
mentions (11) 22;216:3 35: 17;36:5,6,9;37:7;
14:1 ;56: 19;79:2;82:3; millions (1) 43:18
84:18;116:17;135:14; 151:3 Montgomery's (1)
149:20;209:17;210:7,18 mind (13) 37:8
mess (1) 39: 12;60:21;73: 10,23; month (1)
37:9 94:13;105:3;111:13; 22:12
Message (4) 118:13, 14;144:3; 178:24; moral (12)
207:11,12, 17,17 180:5;212:12 114:14;138:15,16,19,
met (5) mine (1) 20,24; 139: 14;161 :6,8;
24: 16,20; 133: 17; 153:12 218:5;220:4,16
181: 19; 190:21 minister (1) morals (6)
Methodist (2) 185:6 114: 16;122: 17; 124:25;
102:2,3 minor (1) 138:13; 192:25;208: 10
Methodological (2) 72:7 More (45)
180:11;181:1 minute (11) 26:22;27:6;50:21,25;
methodology (1) 18:4;28: 17;52:3;68: 1; 91: 19;92: 1; 105:3,5;
177:19 81 :7; 122:1 0; 127:4; 112:21; 121:8; 124:7;
methods (3) 143: 10; 152:23;161:23; 126: I ,10;131: 18; 133:23;
152:1,2;205:10 188:8 138: 10;142: 12;144: 10;
Midtdal (6) minutes (7) 146:6;154: 15,23;157:24;
35:10, 10, 19,21;43: 17, 25: 10;56: 18;57: 19; 158:3;159:21 ;161: 17, 19,
.JFischer@QAReporting.com
Stephen Alan Kent
January 5, 2012
25;162: 12,19;165: 14;
166: 1; 171 :3,12; 172:1;
177:3; 179:23; 180:3;
184:8;209:1,11;211:17;
214: 14,14;217:4,23
morning (4)
25:8,9; 117:16,25
most (8)
38:5;41: 16;96: 14;98:2,
16;151 :20;176: 18,25
move (9)
101: 17,19;102:22;
104: 14,16; 1 06:4;108:3,5;
206:1
movement (2)
178:23;202:25
moves (1)
194:13
moving (2)
115: 15;194:23
Moxon (2)
191:1,3
much (16)
11:14; 18:15;25:9,21;
28:9;29:12;93:4; 109:1;
134:23;152:3,12; 177:3,
11 ;179:20;210:4;221:1
multifaceted (2)
60:4;78:9
multiple (3)
139:7,11,12
murky (1)
188:1
mushroom (1)
157:12
myse1f(2)
27:9;131:4
N
nail (1)
132:14
Nakishia (2)
46:3,7
name (16)
9:6, 16;10: 14,15; 18:25;
19:5;38: 19;51:12;64: 1;
90:21; 100:11 ;190: 13;
196:8; 199:6;207:8;
208:13
named (6)
53: 14;95:2; 176:8;
177:6;184:22;207:14
names (1)
58:10
Nar (2)
190:4;205:2
Narconon (255)
9: 17,17;13: 10,13, 16,
20; 14:8; 19:21;20:24,24;
21: 18;23: 13,19;24:24;
26:6;28:3,7,7;29:9,11;
46: 15,15;49:4,6;50:21,
(14) Maybe- Narconon
Desmond, et al. v.
Narconon, et al.
25;51 :3;52: 17' 18,18,21'
23;53:2,3,4,7, 12;54:18;
55:6,6,13,18,19,23;56:4,
9,13,19, 23,24;57: 15;
58: 17;61: 1,18,24,25;
63: 1,4,8,8, 11 ,12,15,15,
18;64:8,9;66: 16,19;
67:17;68:23;69: 15,15;
71 :20;72:23;75:9;76: 17;
78:23;81 :23,24;82:23;
83:2,3,4,5,12,14,19,21,
24;84: 1, 16;85: 11 '19,24;
86:3;87: 1 ,7,23;88:4,7, I 0;
92:3,5;94: 10, 16,22,24;
95:9,12, 15,16;96:14, 14,
18;97:2, 11,15;98: 15,18,
24;99:2,6,9, 12,14,17,20;
100:1,6, 12,14,18,25,25;
101:10,15,21;102:6,11,
20,22; 103:22;104:6,7,21,
25;105:24; 106:8,19;
107:3, 16;109: 14; 110: II ,
17;111:2,15;116:6;117:5;
121 :24;124:7; 125:1,2, 18;
126: 16;128: 12,23;
129:14,23;131 :5,12, 15,
25;132:2,10,12, 17;133:5,
12, 14,16,21; 135:9,12,16,
21 ;136: 1,13; 137:6,20,25;
138: 13; 139:20;140: 12,
24; 141 :5,14;142:6;
144:20; 145:21 ,22;146:6,
7,13, 15;147:15, 17, 19,25;
148:6; 149:5,7,9,12,20;
150:6,9,25;151:7,17;
152: 1,6;153:3;154:2;
156: 15; 157: 10,23;159:7,
9,13,14;160: 15; 163:25;
164:1;190:1,2,5,11;
195:10,11,13,16, 19;
199:22;202: 16,17;
204:23;205:3,4,7, 14;
21 0:16;211 :21 ,23;214:25
Narconon's (6)
23: 16;82:11;104:8;
124:21 ;145: 13; 152:9
national (2)
53:3;58:13
nature (4)
35:23; 116: 13; 161: 1;
208: 4
near (7)
16: 11;40:7;62: 10,10;
69:2;80:25;92: 10
necessarily (7)
61: 17;81 :25;82:2;
142:22;158:20; 198:4;
199:23
necessary (3)
150:3; 168:22; 169:25
necessity (1)
122:3
need (20)
Min-U-Script@
51: 14,20,22;57:1; 39:13;41 :7,8;46: 14, 16; 153: 1,17; 163:18; 166:2;
77: 15; 107:22; 109: 19; 82: 19; 156:9 168:5;169: 17,23;170:18;
117:9; 136:15;142: 18; Non-party (1) 174:20; 185:12, 15; 186:6;
143:6; 150: 16;162:25; 12:21 187:20;191 :10,10, 17;
164:20; 167: 18;170:6; nonprofit (23) 192:1 0;193:5;197: 13;
180:24;189:7;215:7; 55:20;56:4;61: 1,3,10, 198: 10;204:1;206:14;
221:5 13,19,25;81 :7, 10, 13,18, 209:5,21;211:8,11;
needn't (1) 23,24;82: 1 ;83:9;88:8; 213: 11;219: 17
152:18 89:7;145: 15; 146: 15,16; numbered (3)
needs (1) 159:10,14 20:3;57:7,10
94:2 non-psychiatrist (1) numbers (4)
negative (6) 153:4 12:7;35: 12;52:8;
17:23;113:4, 14,24; non-Scientologists (1) 144:22
115:17;199:1 136:2 numeral (1)
negativity (1) Nor (4) 58:22
200:16 97: 18; 137: 10;157:7; nutshell (1)
negotiated (1) 159:12 39:9
90:15 normal (3)
negotiations (2) 115: 14,14;187:18 0
62:19;92:16 North (2)
net (3) 32:4;183:5 object (16)
41:22;42:15,23 Norway (1) 17:1 ;40:3;90:3;1 08: 11;
network (11) 183:13 133:25; 142: I ; 160:4;
151:25; 175:9,11,20,24; Nos (5) 161 : 15; 162: 1 7; 165:7;
176:3,8,14;183: 18,24; 8:2;103:6; 143: 19; 191 :7; 199:17;202:21,24;
184:5 163:14;169:11 203:11 ;206:22
neutral (3) notary (1) objected (2)
45:7;1 06:21;161:2 9:4 42:7;46:7
Nevada (1) notation (1) objection (7)
45:15 65:16 39:2,4,21,24;40: 12;
New (6) note (1) 45:18;134:2
73: 17; 151:7;162: 13; 65:9 objectionable (1)
164:22;170:25;171: 1 notes (8) 48:6
newspaper (3) 14: 16;45:5;70:25; objections (1)
77:3; 170:23,24 152:7; 179:15; 196:23; 8:14
Next (14) 211:9,12 objective (1)
19: 19,20;37: 11,21; nothing's (2) 45:7
42: 12;45:9;52: 1,2;57: 17; 149:5;155:16 objectives (10)
72:12;116:2;122:20; notice (6) 17: 19, 19,25;20:12;
169:8;173:16 21: 19;30:22;41 :15; 73:13;112:23,25;113:5;
next-to-last (1) 201 :8;211 :8,11 197:6,6
62:11 noting (1) obligation (1)
niacin (2) 93:24 69:17
111 :25; 112:2 November (1) OCA (1)
Nick (3) 22:9 102:17
75:2;92:25;98:7 NP(2) occasional (3)
nicotine (2) 12:4,19 209: 17;210:7,18
96:6,7 number (92) occasions (2)
night (10) 11:3;16:14,19;19:23; 47:4;210:23
24: 19,25;25: 1;66: 14; 26: 10;28:2,9;29: 12; occurred (1)
69:5;74:20; 117:24; 36:23;38:4;52: 13;54: 16; 131:20
168:4; 191:21 ;212:2 58:3;70:5;71: 16,19;73:2, occurring (2)
nights (1) 8,17;78: I I ;80: 12;90:22; 128:12,22
26:6 91:9,18;93: 19;94: 16; occurs (1)
nine (2) 95:23;96:11,15;99:22; 106:5
16: 13;47: 1 104:9;112:9;114:10; o'clock (1)
ninth (1) 115: I ,23; 116:3; 118:2,9; 208:23
93:12 124: 13, 16; 125: 18,21; October (1)
non (1) 126:5,23; 134:6; 137:4; 153:11
83: 17 138:7,7 ,24;140: 19, 19; odd (1)
non-drug (2) 144:4,8,24;145: 11,19,25; 33:24
138:3;153:4 146:21 ;148: 13;149:3; off (34)
none (7) 150:20,24;152:6,13; 9: 10;16:2;22:2;35: 15;
Stephen Alan Kent
January 5, 2012
40: 16;50:6;51 :4,4,25;
77:20;85: 13;96:20,24;
109:21;133:22;135: 11,
17, 19; 136:3;138:3;140:9;
147:23;148:9; 154:13;
157:3;163: 1 0,12; 170: 15;
189: 14;195: I ;207:10;
209:7;215:25;216:2
otler (53)
27:21,24;28:14;47: 15;
49: 16,22;50:20,23;54:6;
55:9,12;61 :24;63:3;
64:12;66: 18;67:2,7;69:5,
8, 11,14;84: 15;86:2;
97:1 0,14,19;99:16, 19;
102: 10;106:6,17;107: 1,
21; 108:3;112:6; 124:5,7,
12;129:11,22;137:15;
141: 12,24; 150:17;157:2;
161: 14; 162:15;165:4,22;
167:2;216: 16;220: II, 12
offered (4)
34: 10;35:5; 101:3;
206:16
offering (2)
49:5; 106:22
offhand (2)
47:22;168:1
office (1)
92:13
officer (3)
36:7;136:15,16
officers (2)
36:15;37:7
officials (2)
195: 11,11
officials-must (1)
195:12
Often (8)
16:23;93:8; 102: 14;
104:8,14;113:3,4,7
Oklahoma (6)
21:19,24;27:3;67:6;
145:3,4
old (5)
10:14,17;101:4;
105:22;164:12
older (2)
74:9;178:10
omissions (1)
15:22
omit (1)
116:21
omits (1)
96:6
omitted (3)
11: 16;96:7; 170:17
once (4)
44: 19;53:9;86:21;
146:25
one (165)
11 :3; 14:9; 16:22;19: 13;
20:9,14;21 :22;22:21;
(15) Narconon's - one
Desmond, et al. v.
Narconon, et al.
25:7;32:2,4;33: 1,6;35: 13;
36:23;38: 11, 14;40:20,24,
24;41: 14,21 ;42:10, 12;
43:24;45:9,18,23,25;
46:20,22,25;49:11;51: 12;
53 :20;55:22;56:9;57:9;
61 :8;67:2;72:9;73:3,4;
75: 19;76:24;77:9;78:20,
21;83: 1;91:19;94:4;96:6;
I 01:4, 17;103:13,20;
I 04: 14; 1 09:7,12; 114:16,
25; 115:4, 19,22,22,23;
116:1,2,18,19;117:3;
119:22; 122:2,2;123: 16;
126:1; 131; 16; 132:3,4,6;
134:5, 17;135:6,21;
136:20,25;137:22; 138:7,
14; 144: 13;145:16;150:9;
152:5,11 ;153:21 ;154: 17,
23;155:20;156: 12;
158:16, 16; 161: 1,11;
168:5; 170:25; 171; 1,6, 7'
10;172:5,24;173:1,2,3,4,
6,7; 174:21; 176: 12;
180: 16;181 :9; 182:24;
183:6; 184:17; 186:22;
188:3; 192:20;193:4,19;
194:12, 13,13, 14,15,19,
22; 196:3, 16,21,23;
197: 10; 198: I ,2;201:22;
204:20,20;206:7 ;207: 5,
24,25 ;209: 19 ;21 0:20;
212:3;217:4,6,15;218:3;
219:4,6,7,7, 11,18,20;
220:11
one-page (2)
182:12,14
ones (15)
16: 14;35: 15;38:9;
41: 16;47:22;74:20;
142:17,24; 143:1,4;
148: 16;170:4;197:7;
199:1;216:11
one's (10)
42:22;85:6;115:24,25;
116:1;118:22;198:1;
201:9;204: 14,15
only (27)
8:6,9; 16: 14;40:5, 10;
45:4;48:10;56:20;78:9;
80:21 ;83: 15,19;95:9, 11;
109:7;131 :11 ;151 :11;
154:21;158:11,17;160:5;
163: 16; 168:16;175: 13;
195: 18;200:9;201:17
Ontario (2)
32: 16;178:5
onto (1)
25:12
open (3)
1 04:9;112:3;146: 19
opened (4)
24: 10;33:7,13;95: 15
J\Iin-U-Script@
operation (2) 183:9;204:7,21 ;212:25; own (8)
115:6,14 220:15 45:3;115:24;135: 1;
operations (1) organizational (3) 183:9;204: 12, 14;205:9;
107:3 70:22; 115:6;204: 16 214:12
opinion (55) organizations (21) Oxford (11)
24:6,14;27:21 ;28: 15; 56: 10,11,25;58:8,9; 102:12,14, 16, 17;
35:5;51 :7;54: 10;61 :24; 60:8,16, 19;62: 1 ,5;63:9; 109: 12,13,16,17,23;
66: 18;67:2;71: 19,19; 70: 15;78:6,6;80:9,24; 110:15;111:7
73:2;78:5, 15;80:4;83:20; 88: 15;90:6, 11; 101:1;
84: 16;86:2;97: I 0, 14,19; 213:2
p
99:8,17, 19; 106:7, 17,23; organized (1)
107: 1,21,25;108:3; 96:20 pack (37)
124: 13, 16; 125: 17; 126:5, oriented (4) 13: 10,20,22;14:8,1 0,
23;127: 14; I29: 1 I,22; 113:3,4; 195:8,9 17,24;16:4,8, 13, 19;21: 18,
133:5; 134:6; 13 7: 15; original (2) 20,25;23: 15;24:23;25:2;
140: 18,19;150:4;162:6; 60:23;185:18 66:13, I 7;67:6, 17;70:2;
165:22; 166:2; 167:3; others (6) 72:1,23;79:7,25;80: 12,
217:4,6,15,17,25 60: 17;99: 15; 157:11; 12;82:23;83:3;85: 11;
opinions (77) 178:22;218:8, 1 I 98: 17;103:22;116:6;
9:24; 10:3;13:9,19; out (69) 152:25;201 :9,10
15:6,8;20:20;23 :7;24:3; 9:23; 10:2; I 1:3,4, 18; packs (6)
27: 17,24;28:21 ,23;29: I 8; 15:5; 18:20;20:6;22:4; 15:2, 16,25; 18:8;79:4;
34:11;49:2,6, 17,22; 26:2,9,24,24;28: 15;30:4; 83:5
50:10,11 ' 14,20,23;52:4,9; 32: 11,16;34:5;41:7; pack's (1)
54:6,7;55:9,12;63:3;67:7; 43:22;44:21 ;45:21 ;46:9; 15:17
69:5,8,11,15,21,24;71:5, 52:14;53:6;61 :9;65: 13, Padgett (8)
9,1 0, 16;76:4;79:22; 17;76:23;77: 12;79:21; 42:24,24;43:3,10, 15,
108:9;112:7;124:5,7 ,11; 82:9;85: 17;86: 12;102:2; 24;172:21;173:3
126: 11' 12; 130: 12; 116: 10;121 :21;135: 14; page (28)
141:22; 142: 19; 143:2,6; 138: 18; 139: 15; 142:24; 14: 13;57:23;58:3;
144:1 ;147:12;150:3, 17; 145: 16;152:5;154:1; 60:20;118: 10;119: 12,20;
153:3; 157:2,21; 158:1 0; 157: 15;158: 19,20,23; 120:8; 121:12, 14; 122:1;
161: 13; 162: 15,22; 161 :9,18;175:23;182:4; 152: 14; 153: 17,23;
164:23; 165:4; 167:20; 183:3; 184:19;185:8; 154:20; 157: 12; 184:9;
185:21; 187:8;188:21,25; 187:9; 188:2;196: 11; 192:9,9;193:20; 195:24;
220:6, 11,12 201 :4;202:5,5,7, I 0, 14, 18; 196:1 0;200:4;209:25,25;
oppose (2) 203:23;204:20;205:3; 210:1,2,3
187:19,20 216:5 pages (8)
opposed (2) outlier (1) 12:14;58:5,21 ;108:16;
199:5,7 158:11 109:7; 144:8;153: 10;
opposite (1) outlined (1) 155:14
199:9 138: 11 page-that's (1)
opposition (2) outlines (2) 153:21
47:5;134:20 71:5;201:21 paid (3)
ordained (1) outlining (3) 55:1 ;179:19,20
185:6 27:25;68:21 ;126:25 pain (1)
order (10) outside (5) 122:6
13:9;24:3;30:23;52:22; 21:16;96: 15;175: 12; painful (1)
114:13; 115:4,18;142:18; 188:2;201:23 31:24
200:22;20 I :4 over (9) pamphlet (2)
or ders (2) 42:25;44: 14;70:8; 101:9;207:11
194:14,17 75:25;96:22;112: 15; paper (9)
ordinary (2) 127:23; 174:5; 184:23 11 :14; 26:17;65:20;
38:9;216:11 overall (1) 178: 11,25;180:8, 13,23;
Org (2) 82:4 196:24
44:4;212:24 oversight (1) paperback (1)
Organization (32) 29:12 116:8
42:14;52:25;53:2,8; overt (2) paper s (I)
55: 14,20,25;56:4;61: 1, 120:18;165:17 152:20
20;63:5,6;65:5;70: 12; overts (4) paragraph (1)
78:9;81 :8, 11, 13,19;83:2; 120:3,6,10,12 151:18
88:9, 19; 102:25,25; overwhelming (1) paragraphs (1)
115:25;139:7;172:13; 151:9 184:8
J Fischer@QAReporting.eom
Stephen Alan Kent
January 5, 2012
parallel (5)
94:5,6; 113:20;162: 1;
220:7
parallels (1)
199:8
parents (1)
32:11
parliamentary (1)
184:12
Parsons' (3)
75:2;92:25;98:7
part (26)
22: 12;23: 17;30:19;
38:12;41; 17;52:22;60:2;
65 :4;78:9 ;83 :8,1 0;85 :23;
88:20;98:2, 16;102: I 0;
1 09:4;131:17;144: 19;
146:3, 12; 157: 14; 158:3;
185: 13;207:6;218:24
partially (1)
117:25
participants (1)
136:1
particular (35)
13: 15,15;20:25;40:6,
1 0;58: 1 0;60:5;61 :7;87:8;
108: 19; Ill :21,24;115:5,
6;123: 12,17;128:3;
130:25;131:9; 136:23;
141:9; 145:23;152:13;
164: 14;176:24;181 :4;
184:21; 188:22; 192:21;
194:2,6;200: 19,20;
201 :23;205: 12
particularly (1)
41 :8
parties (2)
32:14;148:18
partnered (1)
36:12
partnership (1)
190:25
parts (1)
78:10
party (1)
60:4
pass (3)
115:11 ;119: 14,21
passed (2)
182:18;211:11
passing (1)
211:9
past (7)
17: 12,24;40:4; 113:4;
175: 1; 191:1 0;201: 12
path (1)
194:19
Patrick (5)
67: 19;69:4;74:21;
110:11;111:6
pay (6)
70:1 1,15;87:11;
144: 10;206:20;207: 1
(16) one-page- pay
Desmond, et al. v.
Narconon, et al.
paycheck (1)
185:14
paying (1)
61:6
pays (2)
52:23;54:18
peer (2)
182:23;187:25
peer-review (1)
188:5
peer-reviewed (1)
187:23
penal (2)
60: 15; 180:20
pencil (1)
196:23
pencils (1)
16:24
Pentecostal (3)
176:10, 15;183:25
people (105)
17:23;18: 13,16,19,21,
22;20:5;24: 11;48:9;
49:24;51 :2;53: 19;54: 12;
65:2;70: 15;75:21 ;85: 18;
86: 1,7;89:9;93:8, 16;
95:24;96:24;99:9, 18,22;
100: 18,19; 101:5, 16, 19;
102: 11,22;103:23;
I 04: 14, 15;105:23; 106:8,
19;107:7;109:20; 111 :25;
112:14;113:2,14;114:6,
18;115:8;118:4;120: 15;
124: I ;127:10,14,16;
128:2;131 :19,23; 133:12,
16,18,22,23;135:8,9,11,
17; 136:3; 138:3,9; 139: II;
140:8; 148:9; 154: 12;
155:7 ,12; 156:3,6; 157:3;
177: 17,1 8;186:22;
187: 19;194:24; 195:7,13;
197:8; 199:9,16, 19;
200: 14, 16;210: 1;212:9;
214: 13,22;216:8,13, 18;
217:2,8,23;218:4;219: 18;
220: 1
people's (9)
32: 14;48:8; 115:10;
127:7;132:7; 133:8;
216:21;219: 13;220: 16
people-you (1)
18:25
perceive (1)
176:19
percent (7)
52:24;53: 1 ;54: 19;55: 1;
70:5;86: 17;96:25
percentage (3)
18:25;33:20;70: 12
percentages (1)
97:3
perception (6)
37:25;73:12;112:19;
Min-U-Script
197:2;219:22,23 philosophy (1) played (1)
performing (4) 30:14 92:18
204:20,21,21,22 phone (4) player (1)
perhaps (2) 22:24;65:2,9;183:2 185:24
183: 13;217:21 photo (1) please (1)
period (6) 108:22 156:21
30:7;37:24;38:4,25; photocopied (1) plus (1)
98:22; 129:17 145:20 96:25
periods-up (1) photocopy (2) pm (1)
111:19 108:23;109:6 221:10
permission (2) photocopying (2) point (33)
64:1;95:6 108:23;109:2 19:1 0;23:3;32:7;37:4,
permitted (1) phrase (1) 4;43: 13;57:20;65:25;
58:9 135:4 84:7; 106:21 ;108:8,12;
person (49) phrases (1) 118:9; 134:22;142: 18;
14:2;17:3,6,9,25;18: 1; 177:6 143: 1,5; 144:2; 157:20,23,
19:23;20: 10;36:22; physical (2) 23;158:9; 160:22;161 :9,
40:22;41: 10;43 :21; 119:3; 196:17 25; 167: 10; 176:18;
45: 18;99:20; 100: 14; physically (1) 187:18,19,20;211: 1, 1,2
103:25;113 :24;115: 12, 198:2 pointing (1)
14,20; 119:24;141 :3,8; physiological (3) 201:19
176:8; 184:21 ,22,23; 112:5; 129:7; 154:10 points (3)
194:5,8,21 ;195:9;196:2; physiology (3) 137:24;187: 17,20
197:22; 198: I ,2,6; 199: I, 50: 1,16; 130:20 police (6)
4,7, 12,16;200:18;201: 12, pick (1) 36:6,10,11, 14,16;37:7
15,19;202:4, 13,17; 108:20 policy (3)
207:14 picked (1) 43:6;201 :20;202: 16
person' (1) 42:10 poorly (1)
38: 1 picture (2) 147:10
Personal (13) 103:23;152:16 popular (1)
19:22;62:21 ;75: 16,20; piece (2) 213:1
89:11;90:16;100:6; 26: 17;65:20 popularity (1)
114: 11, 13,23; 118:2; pieces (1) 151:9
136:22;220: 1 186:6 popularizing (1)
personalities (3) pin (1) 207:9
19:15,16;200:14 117:12 population (1)
personality (13) Pis (1) 151:6
109:22,22;113: 12, 12, 91:21 pores (1)
18,21,22; 198:15,15,24, place (4) 112:3
25;199:5, 9 8:10,12; 14: 13;76: 17 portion (2)
persons (1) places (2) 68:13; 145:17
199:20 19:17;82:6 portions (1)
person's (10) plaintiffs (1) 158:9
48: 12;63:25;90:21; 13:11 portray (2)
109: 19; 113:23;115: 19; plaintiffs' ( 6) 156:14;208:3
136: 16;154:22;194:20; 13: 1;21 :7;24: 16;27: 13; portrayal (1)
198:5 75: 12; 170:20 147:16
perspective (3) plan (9) portrayed (1)
132:9; 187:3;203 :20 51 :9,12;66:20;67:20; 180:18
persuade (1) 99: 19; 102:25;140:22; portrays (1)
176:15 147:3; 150:25 153:6
persuasion (1) planet (4) position (9)
178:19 134:16,17, 18,20 32:19;33:6, 13,13;83: 1;
PhD (12) planned (3) 103:2;115:8,11;135:25
30: 17;31:7,12;33:9; 29:2;107:2,18 positive (2)
182: 17; 183: 1,1,2,3,6, 10; planning ( 4) 217:4;220:1 8
185:4 30: 18;50: 11;51: 19; positively (1)
PhDs (1) 158:2 86:13
32:21 plans (5) possibility (3)
phenomenon (1) 48:25;5 1 :25;63:7; 118:5; 123: II ;144: 18
202:14 66:24;174:14 possible (5)
philos (1) plates (1) 33:4;99: 13; 105:17;
123:15 91:23 142:4;208:24
Stephen Alan Kent
January 5, 2012
possible-of (1)
111:20
possibly (3)
15:9;83: 18; 159:20
postdocs (1)
32:21
postdoctoral (3)
32:18,20,25
posted (1)
34:19
potential (8)
19:16;66:21; 113:12;
134: 19; 198: 16;200:5, 17;
202:11
power (3)
115:8,11;123:22
Practice (22)
8:21 ;42: 1,5;46:5,6;
47:20;48:5;70:10;
104:11;127:13,15;
128: 11,21;129: 13,23;
131:19,21;141:23;
149: 17; 191 :5, 14;213:21
practiced (5)
129: 14; 196: 14;213: 16,
24;214:22
practices (30)
28:1;47:21 ;48:10;
68:21 ;70:20;83:7 ,8;
126:25; 127:12, 18,20;
128:3,16; 130:23;131 :8;
132: 13;133: I ;134:7;
137: 14; 140:3,23; 141: 12;
192: 15,22;194:3;197:7,
19; 198:20;204: II ;208: 19
practicing (2)
136:13;194:7
precepts (2)
19:24;20:3
precisely (2)
124:4;203:22
predate (1)
126:16
preliminary (1)
194:16
preparation (1)
112:22
prepare (1)
194:21
prepared (5)
75: 12,14;192:16,19;
208:16
preparing (1)
51:25
prepped (1)
137:10
present (11)
18: 1;68:3; 113:3,6;
140:22;169: 13;195:8;
197:9,23;213:20;215: 11
presentation (1)
152:10
president (1)
(17) paycheck - president
Desmond, et al. v.
Narconon, et al.
53:1 2
pressed (1)
101 : 16
presumably {1)
82: 18
pretend (1)
118:24
pretty (8)
15:25;41 :7;42: 15;43:5,
9;81 :4;152:3;173:2
prevent (1)
210:5
previous (2)
20:23;21 :18
previously (1)
14:7
primarily (9)
28:4;66:22;71 :22;
73: 13;96: 13;99:3; 137:7,
16; 142:8
primary (1)
214:19
principal (1)
175: 19
principle (10)
111 : 12; 196: 14,25;
200:6, 10,13;201:5;202: I ;
218: 10, 12
principles (33)
25: 13, 15;28:4;42:9;
71:22;79:7,8, 17, 19;80:6;
83:6;84:4;93: 2;96:21 ;
114:17,25;11 5:3; 124:17,
19,24; 126:8; 131: 13;
132: 18, 1 9; 136: 14;137:7;
138:8, 18; 142:8,11;162:9;
205: 11 ;208: 17
print (3)
11 :4,18; 185: 1
printer {1)
77: 14
Prior (3)
24: 15;27:4;56: 14
prison (4)
95:2;96:20; 148: 10,11
prisoner (1)
148:8
prisoner s (3)
95:5,7;96:20
prisons (1)
96: 16
private (2)
155:23;213: 19
privilege (1)
86:23
probably (17)
22:9;26:23;37:5;78:2;
87:8; 102:24; 108:7;
133:7; 153: 15;161 :3;
181: 19,25; 188:6;205:8,9;
214:2;220:21
problem (5)
12:23;87: 12; 130:2;

151:13;200:16 17; 194:5,8 37:23;38:3, 16, 17;
problems (5) prominent (1) 103:21;186:19
17:2;86: 11 ;153:5; 36:8 publicity {1)
202:9,10 promise {1) 18: 17
procedure (2) 32:23 publicly (1)
70:13;206:10 promotes (1) 44:7
procedures (2) 220:15 published (18)
136:18; 191:25 pronounce (2) 20:7;32:23; 103:20;
proceeding (2) 190:16;211:4 105: 12; 155: 16,20; 172:7;
44:23,24 proper (1) 177:9, 18; 179:5,1 0,13, 15;
process (4) 136:18 180:4; 181 :24; 184:4;
120: 18; 151 :4; 188:1; protocol (1) 185:15;186:5
195:4 152:8 publisher (1)
processes (4) proud (1) 103:22
39: 13;95:5; 163:22; 135:16 publishers (1)
194:17 proved (1) 182:4
produce (2) 154:21 pull (4)
116: 12;156: 18 provide (12) 22:4;65: 17; 142:20;
produced (11) 27:25;39:8;65:23,24; 161:18
72:21 ;73:21 ,23,25; 66:4,5,7 ,1 0;99:2; 126:24; pulled (2)
74:5,12;108: 15; 116:9; 177:24;214:25 27:9;70: I
142: 16;168: 14;170:5 provided (9) pulling (2)
production (2) 1 0:23; 11 :6;21 :7;24:2; 26:1;65:13
152:7;155:1 27: 16;64:5;75:8;76:10; Pur (1)
professionally (1) 214:4 96:4
216:15 provides (1) purely (2)
professor (1) 80:8 87:24;218:3
180:9 providing (2) Purif(2)
program (103) 40:12; 175:25 96: 11; 133:19
21 :5,8;29:9;31 :2,3,15; pseudo (2) Purification (22)
42: 19;49:4, 6;50:21 ,24; 150:11, 11 16: 15,16,18;95: 10, 17;
54:5, 9, 14;60: 12;63: 18; psych (1) 96:4,13;97:21;99:21;
64:8,9;66: 19;73:8, 17; 49:14 100:20; 10 I :5,6; I 03:24;
79: 16,18;83:4,4,14, 14,2 1; psychiatric (1) 108:24;111 : 13,15,16;
84:3, 16, 19;85: 14,20; 199:25 129:5; 131 :25; 133: I I ;
86:3,8;87:24;94: 10; psychiatrist (2) 146:23; 152: 16
95:10, 12, 15, 16;96:9,1 0, 49:9;138:4 purpose (8)
19;97: 17,18,22,23;99:21, psychiatry (9) 8: 16,19;9:23; 130:9;
24;100: 1,6, 12, 15,18; 134:23,25,25; 135: 14, 137: 1,2;158:21;197: 18
10 1:23; 104:25; 105:24; 15,19; 150:23;151:2, 15 purposes (21)
107 :4; 11 0:4; 111: 14, 14; psycho (1) 8:2,6,8,20;57:25;60:7;
123:24; 124: I ,4,6,8,1 0; 184:13 65: 10;72: 15;81 :25;
125: 1; 128: 13,23; 129:6, psychological (1) 82:21; 103:6;123: 1;
15; 131 :25,25; 132:2, 1 0; 110:3 129: 10; 143: 19;163: 14;
133: 12, 17; 135: 11 ;136:3; psychologist (2) 169: 11,20; 171: 18;
137:25; I 38:3, 17; 141 :14; 49:10,14 173:22; 194:7;215:6
144:20;145:23; 147: 15; psychoses (1) pursuant (1)
148:8; 150:9;151 :12; 42:20 8: 10
154:3,8,12; 157: 10; psychotic (2) push (3)
165:24;180:19,21; 199:23,24 82: 12; 133: 11 ;145:22
195: 13;200:20;202: 17, PTS (11) put (11)
18;210:16 113:21,24;141:3; 15:24;34:7;61 :22;72:5;
programs (14) 198 :20;200:9,20,23,24, 122:22,23; 160:7; 166: 19;
31:1 0;32:4;42:2;46:6; 25;201: 1,3 189: 18; 195:22;215: I 0
48:21,23;49:23;51: 1; pub (1) putting (2)
97:2; 106:8, 19; 107: 16; 179:5 38:6;51:25
131 :22; 140: 13 public (7)
program's (1) 9:4;58:4;89:21; 100: 1 0; Q
86:9 151:9; 175:21;208:3
progress (2) publication (5) qualified (2)
200: 22;202: 12 151: 17; 168:21; 175:4; 50:13, 16
Project (6) 179:22; 182: 1 quarter (1)
60: 12; 151 :8; 180:12, Publications (6) 70:9
Q&A Repor t ing Services, Inc.
JFischer @QAReporting.com
Stephen Alan Kent
January 5, 2012
questionnaire (1)
109: 18
question's (1)
85:25
quickly (3)
41 : 17; 110:20;205: 18
quite (9)
52:7;53:7;90:22;
115:23;119: 10;135: 16;
145: 19;206: 12;211 :11
quotation (1)
122:4
quoted (3)
171:1,3;184:17
quotes (1)
187: 12
R
r adiation (9)
95:20,22,25;96:2,5;
112: 1,4; 152: 15; 157: 15
Rain (1)
187:1 1
raise (3)
97:7;116:2;147:3
raised (1)
177: 17
ran (1)
144:9
range (3)
144:8; 152:23; 186:4
rate (5)
96:24;97: 11,15,16, 18
rates (1)
157: 10
rather (2)
29: 10;99: 15
RCMP(1)
36: 11
reach (3)
13:9,18;24:3
reached (5)
84: 10;87:25;91 :6;92:8;
177:20
reaching (6)
20:20;23 :6;73 :2;76: 3;
108: 9;134:19
reacts (1)
17:9
r ead (19)
9: 1 ;68:17;70:7;74: 22,
23;84:21;85:4;95:4;
102:9; 105:14;1 11:1;
133:22; 148: I ;158: 12;
184:9; 193:21 ;200:7;
214:21;219:7
reading (4)
64: 19; 155: 13,14;
214:1 1
reads (1)
219:7
ready (1)
(18) pressed - ready
Desmond, et al. v.
Narconon, et al.
159:22
real (4)
86:22; 148:4;153:7;
210:5
reality (1)
90: 5
realize (3)
8:6; 142: 19;200:25
realized (1)
147:1
really (30)
18: 19; 19:21 ;22: 13;
24:11;25:15;39:8;41:8;
44: I 0;72:3;78:20;89: 12;
93:4;95: 19; 115:8,25;
119:10;135:7; 136: 11;
137:21,21;154:6; 156: 14;
159: 15; 164: 13;177: 1,13;
181: 15; 185: 19; 196:20;
212:4
realm (1)
135:13
realms (2)
136: 11;161:11
reappear (1)
195: 13
reason (23)
11 :22;40:2,10, 11;5 1 :5,
15;56:5;60:25;61: 15,20;
80:21 ;87:4; 1 04:20;
107:20;119:25;124:4;
134:4; 139:5,5;149:2;
164: 14;175:13; 179:12
reasonable (1)
86:2
reasonably (1)
167:22
reasons (4)
32:2;82: I ;185: 13;
186: 10
Rebecca (11)
23:4,7;65:23;67:23;
73:20;103: 12; 156:21;
166:24; 168: 10; 170: 14;
188: 14
Rebecca's (1)
169:23
rebel (1)
207: 14
recall (21)
23:20;36: 1;43:23;
45:20;62: 10;71: ll ;79: I,
3, 14;92: I 0;1 05:2; 106: 1;
109:2; 122:6; 123:9;
160:22; 171 :2;205: 15,17;
2 12: 1,3
recall-and (1)
102:8
receive (3)
21: 10; 199: 13;200: 19
received (3)
27:20;56: 11;83:9
receives (2)
1\fin-L-Script
136: 16; 194:14 70: 1;149:8,10,20 91:24
receiving (2) reference (7) release (1)
44:3;111:7 12:14;13:21;79:1 1; 62: 15
recent (3) 168:3; 170:22;210: 11; released ( 4)
32:21; 105:3,5 213:3 62:9,12;89:21 ;90: 1
referenced (I) relevant (5)
I
13:18 128:23; 132:9;134:9;
references (4) 140:5; 141 :8
'Recent (1) 210: 14;212: 18,20; relief (2)
151:19 219:8 120:6,15
referred (3) religion (31)
R 104:4; 175:2;205: 19 30:12,14,15,17, 17;
referring (3) 31 :4,7,9,12, 15, 18;33 :8;
Recess (7) 72:1,3;78:8 42:8;48:9,10,11 ;78: 18;
50:7;68: 2;103: 14; refers (2) 82:4,5; 116: 17; 123: 15;
117:21;143:21;169:9; 16:15;180:13 127:16; 146: 17;160:1 1,
189:15 refused (1) 12; 177: 10;178:22;
recitation (1) 62:16 181:11,25;185:8;186:16
19:14 refute (1) religions (1)
recognition (2) 179:12 89:1
18:25; 19:5 regained (1) religions-Hinduism (1)
recognize (2) 104:1 30:23
19: 1;21 :2 regard (8) religious (62)
recollection (2) 46:24;47: 11;48:20; 31: 10;37: 15,22;42:9;
44:25;56:24 49:3;67:5; 124:20; 128:7; 47: 16;48:4,8;58: 19;62:5;
reconceptualize (1) 186: 19 78:5, 10,18;79:9,20;80: 1;
178:18 regarding (2) 81: 8,1 1, 14,21;82: 1,5,1 3,
record (25) 188:21;189:1 15,24;83:4,1 0, 14, 19,20;
9:10;45:1,7;50:6; regional (1) 84:17;85: 19,23;86:3,7,
65: 18;66:7;77:20;85 :4; 53:2 13,20;87:3 ;88:6,9, 12,20,
93:24; 144:5; 147:23; regular (2) 23;89:4;99:5;1 16: 13,15;
163:11,12;164:12,13; 210: 8,10 121 :5,24;123: 8; 127:7;
170:13, 15; 189: 14, 18; regulated (1) 160:21 ;161: I ;177:2;
195:1 ;209:7;215:7, 10; 54:5 180:9;185:5; 186:20;
216: 1,2 regulations (1) 187:3,10;213: 16,21,24;
records (5) 53:24 2 18:8
22: 15;64: 15,18;98:4; rehab (1) rely (14)
156:8 50:17 29: 15;64:2,6,1 1 ;76:2,
recount (2) Rehabilitation (7) 12;108:8; 142:23;145: 10;
64: 12,13 60: 12; 135: 13; 151 : 10, 147:5,11;150:16; 164: 16,
recruit (7) 24;154:3; 180: 12,17 19
99:9, 17; 100: 15;101 :1, reindoctrination (1) relying (4)
23; 106: 19;107: 16 60:14 68:9,16,19; 164: 11
recruited (2) relate (3) remainder (1)
100:2,7 93:2,20;209: 14 168:6
recruiting (2) related (5) remained (1)
102:21;133:15 85: 12; 167:11 ;172: 13; 33: 16
recruitment (4) 206: 19;207:7 remember (24)
99: 13,24; 102:14; relates (4) 17: 15;20: 14;22: 12;
109:20 144: 18;157: 13;158:24; 27: 10;3 1: 13;32: 13;42:6,
Red (1) 204:17 22;44:7, 11 ;45: 11, 16;
81:10 relating (3) 47:23;51:12;55:23;
reduce (1) 197: 19;201 :5;202: I 56: 13;73:5;105:2;
15:21 relation (2) 112:21; 114:15; 176:22;
reduced (2) 115:5,6 184:7; 195:3;219: 15
44:17,18 r elational (1) r emembered (2)
reduces (1) 159:17 43: 10;212:17
132: 1 relationship (6) r emove(l)
reeducation (3) 115:25; 145:22; 146:6; 132:3
60:14, 14; 180: 19 204:15, 16,19 rendition (1)
reestablish (1) relationships (2) 113:1 1
178: 19 55: 17;216:19 repeat (3)
refer (4) relayed (1) 17: 17;93: 13;195:20
J Fischer@QARcporting.com
Stephen Alan Kent
January 5, 2012
repeats (1)
24:9
repetition (3)
16: 12;112:22; 195:22
replace (1)
134:25
report (5)
34:25;184: 15, 17;202:4,
15
reporter (5)
9:8;45:3,5;85:5; 168:8
reports (4)
34:24; 136: 16; 174:11;
202:13
represent (4)
9: 16; 11: 17;72:20;
188: 19
representation (2)
97:6;141: 1
representing (4)
41:1 1,1 1;189:19,22
represents (1)
211:7
reproduce (1)
208:7
reproduced (2)
62: 12;207: 18
required (4)
107:9;136:21,21; 137:5
requirement (1)
133: 17
requirements (2)
63:24;89:3
requires (1)
107: 7
research (30)
13: 13;20:20,23;63:25;
151:19,23,23; 152:5,7,8,
10, 12; 153: 14,25;154: 1,
16,16, 19,21 ,23,24;
155: 15,20,24; 156:3, 16;
157:7;159:6,11;181:24
researcher (1)
65:5
reserve (1)
8: 14
residential (1)
151:8
residues (4)
96:3,5; 112: 1,4
resolved (5)
59: 13;77: 1;82: 18,20,21
respect (7)
8: 12;20:5;47: 11;84:5;
127:7; 131 :8;218:7
respond (3)
141:7; 180:24;181:6
responded (6)
179:21; 181: 12, 12;
184:2,2, 19
responding (1)
186: 19
response (5)
(19) real- r esponse
Desmond, et al. v.
Narconon, et al.
180:22,25; 181 :10,13;
185:1
responses (1)
148:17
responsibilities (2)
204:15;217: 19
responsibility (2)
217:20,20
responsible (1)
217:23
rest (1)
143:14
resulting (2)
128:4;151:24
results (1)
178:21
resume (1)
172:7
resumed (6)
50:7;68:2; 117:21;
143:21 ;169:9; 189:15
retired (1)
184:24
retreat (1)
103:1
retrieved (1)
117:24
reveal (3)
91:10,10, 14
Revenue (3)
59: 15;60: 1;84: 11
reversing (1)
178:20
review (12)
14: 16;70:2;71 :3;79:5;
92:25,25; 181 :24; 182:23;
188:1 ;192:2;209:12;
212:1
reviewed (10)
67:6;83: 13,24;110:11;
117:24; 160:1; 168:4, 18;
169:18;191:20
reviewers (1)
188:2
reviewing (1)
25:21
reviews (1)
182:22
revoked (2)
183:4,6
rid (2)
96:2;134:18
Rider (1)
110:18
Rieser (3)
110: 18,18;111:3
Rieser's (1)
24:9
right (77)
11:8,12;12:6;13:2,21;
15:12;19:12;22:11;24:5,
19;30: 13;31: 19;34:21;
40: I 6;41 :21 ;46:22;48:2,
1\lin-U-Script
15;52:22,25;56:17;72:25; 187:12, 24 130: 14; 133:7; 152:3;
75:1 0;77:8,10;79: 13; rubber (1) 155:19;176:22
83:25;97:20; I 01 :8; 196:24 scale (1)
102:5;104:5; 105:6;1 07:5, rule (1) 122:5
10;118:7; 123:25;125:6,7, 141:4 Scandinavia (1)
I 0; 126:21 ; 127:7; 128: I; ruling (2) 183:13
138:23; 139:25; 142:10, 55:25;61:9 scanned (1)
13; 145:25; 147:3,8;148:7; run (5) 168: 11
150:8; 153: 19;156:3; 18: 16;41: 17;54: 11; scanned-in (I)
158: 1; 160:7,18; 162:23; 71:10;130:16 168:14
164:23; 166:3;168:24; Rundown (16) scenario (1)
174:3; 184: 1, 1;191 :22; 16: 15,17,18;42: 18; 44:7
192: 11,22; 193: 18,19; 95: 17;96:4, 13; 100:21; scheduled (1)
198:9;206: 13;209:20; 101 :5,6; 103:24; Ill: 14, 181:23
211 :4;212: 1 ;214:23; 15, 16; 133: 12;146:23 scheme (1)
218:1,7;220:14 running (2) 138:1
Rights (2) 111:19;183:9 schemes (1)
58:13;176:20 runnings (1) 139:2
road (3) 54:14 scholarship (6)
203:20,21,21 runs (2) 32:23; 149:6,7,9,13;
Robbins (3) 96:11,12 186:21
49:17,20;189:22 run-through (1) scholarships (1)
role (2) 159:23 32:9
92:18;142:4 Scholastics (1)
roller (2) s 58:17
113:25; 117:16 school (5)
Roman (1) same (23) 30:4, 12;31 :5; 178:8;
58:22 50:3;54:8;61: 18;67:5, 183:11
Ron (54) 10,1 0;70: 19;86:4;94:7, schools (1)
17:22; 18:4,6,9,11; 19:1, 19;111: 15; 138:8;161: 19; 30:21
9,24;42: 19;52:21;55:3; 166: 16; 179:21; 181 :20; Sci (2)
79:8,16, 18;80:6;84:3; 192: 18; 196:25; 199:24; 102:22;155:15
93:3;94: 14,17;96:7,21; 204:2;205:4;206: 12; science (4)
111:12,17;124:17,23; 219:22 86:2;156: 12;219:4,10
125:3,9, 14,19,23; 126:7, San (1) sciences (5)
1 0,13,19; 13 1: 13;132: 18, 30:25 31:3,10,11,13,15
19;134: 15;137: 16;138:9; Sanskrit (1) scientific (4)
140:6,8; 141: 16;150:4; 31:1 152:11;155:9,10;
151: 17; 155:20;160:2,8, Santa (1) 178:20
16;172: 11;203: 16, 17; 185:9 Scientologist (9)
207:7;208:2 sat (1) 36:8;91:22; 132:4;
Ron's (1) 41:5 171 :9;181: 11;200: 18;
104:6 satellite (2) 213:6,14,15
room (6) 56:10;70:11 Sci en tologists (17)
41 :4,5;68:4; 169: 14; satisfaction (1) 19: 18;91:20;100:20;
170:2;209:9 106:4 1 04:9;105:25;109: 18;
route (1) satisfied (2) 110:7;116:21;133:11;
119:24 120:4, 13 135:9,1 0;136:2;203:4;
routine (3) satisfy (1) 214:4,9,13,16
93:12;197:13,16 173:24 Scientology (319)
routinely (1) sauna (5) 13:22,23,25; 14:3,4,6,
96:11 49:23;50:2; 1 I 2:4; 12,15; 17:9;18:7,12;19:4,
routines (16) 130:16;154:12 I 0, 14, I 7 ,23;20:7,22,24;
16:9,10;93:7,8,13,15, saunas (1) 23:17;25:13,15;28:5,8;
21 ;94:5,7,9;95:11; 111:20 35:6,16;36:12,13,14;
102: 19; 193: 14;197: 12; save (1) 37:12, 15;38:5,6,9, 16;
216:12;217:2 108:22 40:3,24;41 :11 ,16,25;
Roy (2) saw (7) 42:1 ,8,14, 18;43:7;44: I ,7,
174:7,15 20: 13,13,15;170:22; 12;45:2,3,5,11 ;46:24;
royalty (1) 192: 10;195: 18;212: 12 47:6,8, 10,16;48:1 ;52: 19,
70:16 saying (12) 24;53:8, 10;55: 15,18;
RPF (5) 22:23;36:3;43: 10;65:7; 56: 10;58:15;59: 14,16;
180:3;181: 10;184: 18; 83: 12;84:2;87:22; 60:8,12, 16;62:8;68:21,
Stephen Alan Kent
January 5, 2012
23;69:25;70:9,11;71:23;
72:8,11 ;77:25;78:4,8;
79:9;82:4, 12, 14;83:7, 7,
16;84:11,15;85:12,22,24;
86:6,21 ;88: 11,18, 19,22;
89:15;90:7, 15;93:9,14,
18,20;94:6,11,13,22;95:1,
3;97:6;99: 10, 18,22;
100:3,8,16;101 :2,7,22;
1 02:7,15,23;104:2,11,15;
106:9,20;107:17;110:4,5;
Ill: 16,17;112: 12;113:8;
114: 12,17; 115:4;120:7;
124:19,24; 126:4, 12,13,
15,18;127: 1,6,23,25;
128:7,12,22; 129: 13;
131:6,8, 14,17, 17,22;
132:5,6,20; 133:2,4,9,18;
134:8,21,24;135: 1, 12,22;
136:6,8,10,10, 14,18;
137:8,15; 138:2; 139:2,7;
140:13,25;141 :4,7, 13;
142:9; 144: 19;146:13;
149:15, 16;150:23;
151: 12; 153:7;156:7, 11,
13;157:24;160:11; 161 :7;
162:2,10;165:20;171 :2,
23;172:4,7 ,10,13, 18;
174: 17; 175:2; 176:20;
177:3,5,15; 179: 17;180:2,
12,17,19; 181 :8; 183:18,
19; 184:20;185: 11,21;
186:8;187:11;191:25;
192:4,6, II, 14, 15,22;
193:7 ,16,25; 194:3,4,12,
13;195:6,6,17; 196: 1,6,
15;197:3,7' 17, 19; 198:7,
11,17, 17,21; 199:15, 18;
200:1 0,22;20 1 :5,6, 18,24,
25;202:3,9,20;203: I, 10,
18;204:3,6, 11;205:5,7,
11 ;206: 15;207:3;208:5,
17,19;210:9,12,21 ,22,23;
211 :7,19,20;212:5,10,21,
24,25;213:2,4,9,11 ;214:4,
6,11, 19;216: 10,14;218:3;
219:2,6,8;220:8
Scientology-based (1)
46:6
Scientology-hired (1)
91:21
Scientology-related (6)
46: I 1;58:11,20;60: 19;
63:6;191:11
Scientology's (18)
37:25;47:8,12;78: 16;
86:24;113:11 ;126: 11;
135:4; 139:22;140:3,23;
141:23; 145:12;147: 16;
151 : 14; 15 8 :25; 171 :9;
202:12
scope (1)
220:21
(20) responses - scope
Desmond, et al. v.
Narconon, et al.
Scott (2)
176:8;183:23
Scouts (2)
70:21;81:13
screwed (1)
26:5
scribble (2)
64:19,20
scribbles (1)
64:21
Sea (1)
44:4
Sean (4)
188:8,9; 189:23;2 15:7
Second (13)
17:2;26:4;3 1:5;40:24;
111:11,19; 116:22;
121:25;134:20; 162:6;
195: 14;212:13;214: 19
secondary (1)
214:19
secret (2)
38:8;62:8
secrets (1)
91:10
section (11)
109:7; 120:22; 144: 10;
145:2,20,21 ;146:4,22;
151:11;184:6,17
sections (1)
219:7
secular (18)
78:6;79: 16, 18;80:5,14;
84:3;85: 14;86:9,17;
87:24; 116: 12; 160: 13;
161:11 ;186:23,25;208:3,
13;218:3
secular-related (1)
78:11
seeing (3)
40:3;79:3;212:2
seeking (1)
178:18
seeks (1)
119:22
seem (5)
102: 8;105: 15;133:2;
139:13;141:15
seemed (1)
192:5
seems (6)
16: 12;112:24;186:20,
21;197:21;205:2
sees (2)
151:12;194:4
self (3)
116:1,22;216:21
self-identified (1)
179:16
semantics (1)
86:11
semester (3)
32:1 ;33: 1;52: 1
Min-U-Script
semesters (1) shall (1) single-volume (1)
31:24 177:11 219:9
sending (1) share (2) sit (5)
26:25 92:21,23 41:4;56:6;137:3;
sense (8) Sheila (1) 194:11;210:25
85:7;92:20; 132:5; 37:14 site (6)
135: 16; 152: 11; 161: 17; shifted (1) 14:3,4;34:20; 171:23;
185:25;203: 14 31:4 172: 1,8
sent (6) short (8) sites (3)
12:25; 13:3;26:2;71 :3; 36: 19;52:21;67:23; 14: 1,7;62: 13
182:4;188:2 93:7;109:4; 154: 18; sitting (3)
separate (2) 163:8;169:16 57:21;80: 19; 108:21
119:2;143:14 shout (1) situation (1)
separ ated (1) 193:22 205: 12
142:23 show (6) situations (3)
separated-out (1) 23:21;27: 19;72: 17; 217:3,9, 15
142:25 114:25; 155: 17; 171 :20 six (4)
separately (2) shown (1) 27:3;46:25; 109:7;
57:5;164:7 32:22 117:2
separating (1) shows (2) skill (1)
127: 9 101 :4; 114:23 206:10
series (9) Shupe (6) skills (1)
37:9; 118:1 ;124: 17; 183: 14,20,22;184: 18, 216:16
128:3;138: 12; 169:8; 19;185:1 slight (1)
174:22; 184:3,20 Shupe's (2) 178:9
served (1) 186:12,17 slogans (1)
22:17 side (5) 43:11
Service (5) 30: 15;40:24,25;41 :2, I 0 slow {1)
42: 14;58:1 0;59: 15; sides (1) 144:9
60:1;84:11 41:1 small (2)
services (2) sidestep (1) 34:1;109:7
96:15,17 174:22 smaller (1)
sessional (1) Sight (1) 116:7
33:1 45:14 smoked (1)
set(ll) sign (1) 96:8
20:3;21:4,6,8, 10,12; 9:2 smokes (1)
28: 15;47:21 ;73:25;74:3; signature (1) 215:18
80:5 8:25 so-called (2)
setting (1) signed (3) 38:8;136:15
78: 12 41:1 0; 182: 16; 183:1 social (20)
settled (8) significance (2) 19:15;31:3,9,1 1, 12, 14;
43:22;44: 21 ;45:21; 131: 11;195:6 58:3,14;66:23;113:11,20;
46:8;59: 18;76:23;81 :2,2 significant (1) 130:22,24;151 :5; 178:20;
settlement (5) 14:25 198: 15,24; 199:5,7,9
59: 19;76:25 ;82:6; signing (1) societies (1)
159:3,4 41:13 151:20
seven (2) similar (15) society (5)
46:25; 117:2 17:20,21;20:4;38: 13; 80:23;135:3,24;
seven-page (1) 77:23,24; 113:6; 114:19; 136:11;199:10
182:13 124: 19;132:19;133 :4; sociologist (5)
seventh (12) 139:21 ;163:21;193 :8; 31:14;70:22;130:25;
118:3,17, 17,21; 119:2, 204:2 178:4;183:15
13;120:3, 11;121:11,16, similarly (1) sociologists (1)
18; 122:15 205:13 178:22
several (4) simple (3) sociology (10)
26:6;37:23;46:7; 13:25;21 :3; 113 :] 7 30:2;33 :8, 9, 1 0,12,14;
158:12 simplest (1) 44: 16; 180:9;18 I :25;
severely (1) 14:13 217:11
133:9 simply (5) soldier (1)
sex (2) 85:13;86:9;146:11 ; 207:21
116:24;184:12 148:1;161:8 solidify (1)
shading (1) single (1) 151:14
77:11 151:20 Solution (3)
Stephen Alan Kent
January 5, 2012
150:25;151: 13; 153:4
somebody (10)
44:9;54:19;65: 12;70:6;
74: 18; 113:21; 118: 10;
127:2; 130:1; 149:21
somebody's (1)
157:15
somebody-Scientology (1)
195:11
somehow (3)
101 :23;107:16;133:23
someone (7)
38: 18;90: 18;112:25;
141:2; 149:25;202:3;
210:5
someplace (2)
14:19;183:11
sometime (1)
59:21
sometimes (6)
1 02:22; 142 :20; 17 4:20;
175: 1; 188: I ;205: 19
somewhat (2)
97:23;177:16
somewhere (4)
96:25;111:1;175:7;
185:14
soon (1)
95:16
Sorry (13)
12:22;16: 10;147: 10;
152:25; 171: 12; 178: 15;
190:3,3,6, 13, 15;208 :22;
215:22
sort (20)
18:24;23: 19;35:5;37:6;
44:23;54:8;64: 18;70: 15;
82:9; 113:15; 124:2;
139:2; 141: 14;153:4;
193:22;196: 12;197:18;
202:1 ;207: 13;208:2
sorts (1)
95:11
sound (2)
150:3,8
sounds (13)
33: 18;50:12;54:17;
63:2;79:24; 126:6;
131:11 ;157:1;172:17;
186:7,9;197: 14;214:4
source (8)
113:13;119:2,3,5;
180:5;198: 16;200:5,17
sources (2)
19:16;63:24
SP (5)
198: 19,23; 199: 16,22;
200:1
SP/PTS (1)
198:18
space (3)
84: 7; 118: 10;120:9
spare (1)
(21) Scott- spare
Desmond, et al. v.
Narconon, et al.
36:25
speak (5)
99: 12;100: 10; 128: 14;
148:3; 199:10
speaking (6)
48: 3; 11 0:22;174:19,
24;175:5;216:12
Speaks {1)
199:4
species (1)
117:1
specific (13)
13: 18;28: 12;47:20;
83: 1;99: 11; 123: 16;
126:8;162:5,12; 165:14;
177:21;210: 15;216:1 0
specifically (9)
22:4;69: 14; 126:11;
137:13;142: 18,23;
144: 18; 181: 1;199:6
specifics (5)
148:2;162: 19; 171: 12;
192:7;199:10
speculate (1)
84:13
speculation {1)
85:7
speculative (1)
84:5
speed (1)
29:15
spend (3)
25:9;57:21;107:22
spent (10)
25:22,24;26:5, 1 0;
27: 12;33:21;65:18;
166:13,21 ;207: 16
spirit (2)
117:2,4
spiritual (14)
118:4,11, 18,18,20;
120:21 ;121:5,18,24;
123:12,21 ;124:2;212:9,
11
spirituality (2)
123:10;161:3
spoken (3)
23:4;63: 17; 174:7
spots (1)
110:8
sprayed (1)
43:11
Sproule (1)
37:14
SPs (I)
199:19
spur (1)
208:4
stack (2)
104:18;148:22
staff (2)
29:3,7
staffed (1)
1\fin-U-Script
104:8 S-T-E-P-H-E-N (1) 67:19;104:24;111:6;
stand (3) 10:15 112: 14; 193:22; 197: 14;
44: 13; 137:3;194: 10 Steve (3) 215: 1;216:4;217: 14
standard (8) 9:6,16;189:25 student's (1)
19: 17;70: 10,13, 14; stick (2) 32:8
78:20; 197:6; 198: 16; 29:10;93:4 students' (1)
204:6 Sticky (1) 217:19
standing (1) 196:23 studied (1)
110:3 still (10) 30:24
staple (2) 65:20;87:12,12;88: 11; studies (5)
179:1,3 96: 16; 123 :6; 132:1; 18:24;31: 10; 157:9;
stapled (1) 160: 13;196:24;215:15 180:9;187:10
57:5 stipulate (1) study (9)
stapler (1) 9:3 30:25; 127: 18,18; 128:5,
1 03: 11 stop (5) 6;185:7;214:3,5;217: 11
star (1) 18:4;64:20; 142:10,13; studying (2)
98:4 200:25 70:8;177:2
start (5) stored (1) stuff (1)
52: 13;64:19; 134: 12; 112:2 140:25
144:15;193:5 stories (3) stumbling (1)
started (14) 100:22,23; 183:21 112:15
25:3;31: 1 ;32:8;45: 16; story (2) subheading (1)
46:5;65: 13, 17;66:8;95:4, 95:1;208:12 118:25
17;96:9,19;144:16;148:8 straight (8) subject (3)
startled (1) 19: 14;20:6; 110:4; 76: 14; 149:23; 151:23
135:7 112: 12; 113:1 0; 126:4; subjects (1)
starts (3) 182:25;204: 16 71:1
116:22; 144:24; 194:19 strain (1) sublicenses (1)
state (3) 153:8 58:8
95:2;125:8;148:11 stream (4) submission (7)
stated (1) 33:3,8,13,15 12:24,25 ;3 7:25 ;58: 6;
186:12 stream-back (1) 145:12,17,18
statement (16) 33:4 submissions (9)
27:23;37: 17;41 :5,7; Street (4) 11: II ;34: 13,16;38: 14,
45: 19;56:21 ;97:4; 62: 11;89:20;90: 1; 14;39:3;55:22; 101 :4;
112:24;136:24; 138:21; 109:21 152:3
151: 14,17;152:4;177:25; stresses (1) submitted (6)
178: 11;208:10 220:17 11: 16;37: 16;45: 19;
statements (9) stressful (2) 55:21;98:5,21
52:4; 107: 18; 138:12, 15, 217:9,14 subordinate (2)
24;140: 12; 156:17;161 :8; stressing (2) 58:7,7
177:11 138:8,18 subsequent (1)
States (5) strike (1) 89:22
59:11 ;60:2,3,6;85:22 134:5 subsequently (2)
status (41) strong (3) 38:19;183:10
56:11;62:5;80:11,25; 131 :5; 153:7; 177:4 subsidiaries (1)
81:7,23;83:9,9,17;85:23; stronger (4) 58:6
86:6,22, 22;87 :2,3 ,3 ,8; 78:2; 124:23; 132:21; sub-social (1)
88:5,8, 12, 16,20,23;89:2, 177:11 149:16
4,7,7;90:7, 12;92:3; structure (4) substance (3)
145:13, 15;146: 15,16; 28:6;52: 18;78: 16; 53:17;220:5,9
158:15,24,24,25;159:7, 139:3 substantiate (1)
10,14 struggle (1) 140:19
stay (6) 178:21 subverts (1)
49:25;50:1;67:21; struggling (1) 199: I
147:2; 170: 14;220:3 139:25 success (8)
steep (2) Stuart (1) 96:24;97: 11, 15,16, 18;
17:3,6 173:11 115:9; 151 :24;157: 10
stem {2) student (7) suddenly (1)
200:7,9 16:21;29:2,6;32:24; 44:5
Stephen (5) 181 :22; 182:20; 195:25 sue (1)
8:5;9:11;10:15;178:12; students (12) 76:24
180:11 32:3;44: 16;66: 18; sued (2)
Stephen Alan Kent
January 5, 2012
38:10;76: 17
sufficiently (1)
182:18
suggest (2)
105:22; 134:8
suggested (1)
51:20
suggesting (1)
88:16
suggestion (1)
212:8
sum (2)
158:14;205:9
summarize (2)
54:17;124:13
summarized (1)
162:1 1
summary (2)
27:16;124:16
supernatural (7)
78:21,24;79: 11 ;80:3;
83:23;84: 19;88:24
supervised (1)
54:12
supervisor (6)
119:14,21 ;121:8;
201:16,16,18
supplied (1)
23:24
support (10)
31:20; 142: 18; 143: I ,5;
144: 1;154:2;157:20;
158: I 0; 162:6; 166:1
supportive (2)
153 :3; 186:24
suppose (2)
102:5; 187:4
supposed (9)
111:25;115:24,25;
119: 17,24; 194:7,8; 195:9;
202:4
supposedly (1)
207:12
suppressant (3)
14:2;43:20; 141:7
suppressive (5)
38: I; 141 :3; 199:16,20;
200:16
supreme (4)
1 I8:6, 12;119:17;
123:11
Sure (103)
1 I: I 9,21 ;12: 11, 13, 16;
15:7;23:3,4;28: 13,25;
29:5 ;32: 10,1 0;35:7 ;40: 8;
41: 18;42:15,16;43:5,5,9;
45:21 ;49: 16;53: 15;54:20,
21 ;60:3,3;61:23;63: 17;
65:25;70:7;74:20;77: 13;
82:25;85:3;89: 1,3;97:8;
101:9;106:25;1 07: 13,24;
108:17;109:15;110:16;
111 :2;114:22; 116:9, 19;
(22) speak - Sure
Desmond, et al. v.
Narconon, et al.
120:25; 121 :7; 122: II ,13;
126: I ; 127:5; 130: 13;
134: 13; 136: 17;141:11;
143:8, 12;144:23;145:9;
148:3; 152:15;156:22;
158:6, 16; 162:24; 163 :2,6;
167:4; 169:2,2; 170:11 ,22;
171:3,6, 10;172:7; 173:2,
3;174:4,5;175:3,3; 179:4;
188: 16; 189:6;192:12;
193:24; 196:2, 13;197:22;
198:8,8;204:4;208:25;
210:21;211 :14;212:24;
221:6
surely (1)
173:1
surface (1)
208:11
surprise (3)
61:22; 105:20;178: 12
surprised (5)
18:13 ;62: 18; 109:1;
167:12;221:3
surveillance (1)
187:11
survival (9)
118:23;119:4,22,24;
121 :9,10;122:2,4,4
survive (4)
118:18,19,23;119:1
Susan (I)
187:10
Swap (I)
57:4
swear (1)
9:8
switched (1)
114: 14
switching (1)
19:20
Syracuse (1)
183:5
system ( 6)
4 7: 16;60:4, 15 ;80:9;
128:3;180:20
systematic (3)
139:3;156:5,14
systematically (1)
156:8
systems (1)
128:6
T
tabbed (1)
15:23
table (2)
145:19;182:5
tabs (1)
15:24
talented (I)
119:8
talk (38)
1\[ in-t.:-Script
29:2,6;50:16;63:7,11, 37:22; 151 :10,24; 16;76:6,12,16; 100:24;
14;65:2,3;66:24;71: 18; 203:19;205:6,-1 5;211:18 128: 18,20; 130:5; 132:25;
77:15, 18;79:22;90: 18,24; teens (I) 134:9;139:20;220:23;
102: 19;104: 10;110:5; 180:22 221:4
112:8;118:11;124:9; Tel (2) testifying (1)
128:25; 131: 16; 132:2; 177:9,9 86:19
137: 14;141: 17;142:25; telephone (3) testifyN arconon (1)
143:6;150:6,9; 151 :6; 27: 12;43: 1;215: 12 28:5
152: 12;163:3; 174: 15; telling (4) Testimonies (2)
175: 12;192: 19;193:21; 67: 14;79:24;114:5; 35:14;45:7
196:18 137:3 testimony (9)
talked (35) temperate (2) 27:25;34: 11;68:24;
23:6,9;71: 14;90:14; 209:22,23 126:24;140:21; 141: 12;
100:18, 19,19; 103: 10; ten (I2) 172: 15;174:1;183 :23
111:10;112:11;114:15; 27:6,11;47:1;52:23; testing (1)
116: 16;120:20;121 :3; 53:1 ;54: 19,25;70:5; 156:8
123:6; 125:22; 126:6,9; 106:7, 18;166:22;219:4 testings (1)
141 :24; 142: 16;143: 17; tenet (2) 95:23
145:24;147:9; 149:1; 200:5;201 :5 tests (4)
155:7; 157: 17,19;158:8; tenets (1) 95:25; 152:8;155:9, 10
161: 13;162: 15;165:5; 208:17 thanks (4)
167:3;214: 15,16,22 tenure (6) 26: 18;179:4;189:5;
talking (18) 33:3,4,8,13,15,16 . 221:9
13:23;19:5;27: 12;48:7; tenured (1) theology (2)
71: 1 ;77:6; 105:4; 107:7; 185:3 186:22;187:10
121 :22;129: 17;136:5; ten-volume (1) theories (1)
140:2; 149:22;155: 18; 219:5 181:8
156:3;161 :3;180:7;195:5 term (24) Therapeutic (3)
talks (10) 14:4; 17:6;32:19;72:9; 154:20;193:6, 7
78:24;115: 19;118:3,5; 79:2;114:16; 116:24; therapy {2)
123:21 ;138: 16;153: 13; 119:9;120:7;131 :18; 50:3; 149:15
180:15;184:11;195:19 134: 16;174:21 ;175:6; there'd (1)
target (3) 193: 16;196: 1,1;200: I ; 157:23
194:6,7;199:2 202: 15;204:1 0;205:6,9, therefore (1)
tax (10) 13;211: 19;212:2 138:4
55:24;60:7;62: 14,23, terminology (I) There'll (1)
25;81 :24;82:4,9,21 ;86:23 85: 11 109:21
taxes (4) terms (59) thereof (1)
61:7;87:8, 11;89:7 13: 14,17;14:2,5,14, 15, 58:8
tax-exempt (10) 23; 18:24;19: 17;25: 16; there're (2)
55:24;56: 14;59: 16,22; 26:20;48: 12;54:4;55:5; 143:4;210:6
60:9;87:2;88:5;89:7,9; 62: 19;63:3;68:20;69:3; there'smore (1)
92:3 73:2,18;80:22;89:8; 161:23
T-E (1) 97:23;98: 16,22;99: 13; Thereupon (16)
205:22 108:7; 109:5;114: 14; 8:1;57:24;68:3;72: 14;
teaching (6) 116:17;117:25;122:3; 85:4; 103:5; 122:25;
31: 13,25;32:6;33: 17; 126:3,16, 17; 127: 12, 19; 143: 18; 163: 13; 169:10,
192:21;220:1 128:7; 131 :7;132:25; 13;170: 1;171:17;173:21;
teachings (3) 140:2;145:24;150:2,10; 209:8;215: 11
192:3,18;202:20 152:9; 156:7; 157:3; Thetan (1)
tech (3) 181 :9;186: 13;192: 11,14, 79:2
201: 6;205 :20,21 14;198:17;214:3;215: 1; T-H-E-T-A-N (1)
T-E-C-H (1) 219:18;220:5, 9, 15 79:3
205:22 terribly (1) thinking (5)
technical (2) 36:18 83: 18; 122:3;140: 15;
32: 19;206:9 test (4) 144:17;207:10
techniques (9) 102: 13; 109:22,23,25 third (3)
96:2; 124:24; 126:3, 12; testified (7) 17:7; 116:24; 137:20
135: 1;136: 14;192:1; 9: 13;44:24;47:5,7; Thomas (1)
201:2;205:10 68:8;146:8,10 184:22
technologies (1) testify (20) though (8)
58:11 9:24;22: 18;28:24; 65:8;70: 14;83: 11;
Technology (7) 37:16;44:22;47:9;51 :2, 85:25; 158:20; 177: 14;
Stephen Alan Kent
January 5, 2012
183:22;209:1
thought (19)
14: 25; 19:24;20:3;
24:11 ;36: 12;41 :6;52: 13;
74:4;92: 17; 105: 13;
113:5;117:2;141:18;
144:1 0;174:23;182: 19;
184:25;197:10,10
Three (7)
16:22;30:9;31 :23,23;
46:25;201: 10;209: I
throughout (2)
88:18;97:2
throw (1)
158:20
thrust (1)
171:4
Thus (1)
58:12
tick (1)
35:15
tie (1)
126:2
times (7)
32: 11;46:23; 158: 12;
163:20;170:25;171:1;
174:23
tiny (I)
33:22
tire (I)
102:1
tissues (1)
112:2
title (2)
182:1;200:4
titled (1)
193:6
today (10)
9:23;56:6;71: 1 ;80: 19;
117: 16; 149: 11;150: 18;
151:20;165:5; 167:3
together (1)
174:15
told (7)
48: 18;64:7;70:24;
71 : 15; 120:23;121: 17;
159:16
Tom (2)
43:3,10
tone (1)
177:13
took (5)
24:25;25:6;26:2;82:25;
207:15
tool (2)
102:15;109:20
top (3)
16:3;115:7;122:5
total (4)
26:9;158: 14;203:20;
205:9
touch (8)
18:2,3;36: 17; 124:1;
(23) surely - touch
Desmond, et al. v.
Narconon, et al.
161:4; 196: 19;197:15;
198:3
touched (3)
35:6, 15;124:20
touches (1)
122:14
touching (1)
198:4
Touretzky (1)
I77:4
toward (3)
113:4;119:15;150:23
towards (2)
138:10;195:9
TR (12)
14:12; 16:9;17: 17;93:6;
154:20;193:6,7,17,20,21'
24;194:2
TR5 (2)
I6:11;93:11
TR6(2)
16:1 1, 12
TR6b (2)
195:20,22
TR8 (2)
I95:25,25
TR9 (3)
I95:19, 19,21
tractor (2)
196:I9, 19
trademarked (I)
70:17
traditional (1)
152:11
trained (3)
130:21 ;213: 14,15
training (27)
I6:8,9;28:3;50: I8;
71:21 ,25;93:7,12,13,15,
21 ;94:5,9;95: 11;98:22;
129:7; 137:6;142:6;
193:14;194:16;197:11,
13,I6;213:8,10;216: 12;
217:2
transferred (1)
I24:25
transmitting (1)
199:11
transnational (1)
78:9
TR-as (1)
194:5
traumatic (1)
195:7
treasonous (2)
115:21, 21
treat (1)
81:24
treating (3)
60:1;82:1;89:8
treatment (2)
49:4;209: 14
treatments (1)
!\Ti n-U-Scr ipt
135:20 136:4,7;139:3; 156:14,25; 59: 11;60:2,3,6;85:22
tremendous (1) 157:25;175:23; 181 :5,7; universe (3)
152:6 185: 19;187: 15; 194:5; 29:18;117:1;119:3
trial (20) 2I4: 1 university (19)
27:25;51: 16;64: 12; turned (1) 13: 14;14:9;30: I ;31 :22;
107:21; 108:3;126:24; 183:3 32:24;33:5,5,7, 14,17;
133: 1;141:20,24; 149:24, twice (2) 63:22;75:23;177:9;178:4,
25; 150: 18; 154:5; 159:22; 27:1;44:14 7;180: 10; 183:4,5; 185:9
162: 16; 165:3; 167: 13,18; twin (3) university-appointed (1)
192: 13;208: 19 196:1, 1;198:1 I86: 1
trials (1) two (39) university's (1)
166:16 15:24;I7:16;26:20; 22:3
tried (5) 27:1 ;30:6, 16,18,20,24; unless (6)
Il:I7;53:1I;86:25; 32:25 ;36: 14;3 7:6;40:22; 63:25; I49:21 ;152: 19,
142:3;I53:25 46:25;74:4;98: 14; 101 :3; 19;173: 12;206: I
tries (1) I 03 :9;110: 16;117:4; unnecessary (1)
131:19 118:8;122: 10; 138:7; 24:13
trip (1) 155: 18; 156: 13; 160: 18; unpleasant (1)
27:1 161:10; 164:5;171:5; 184:3
trips (1) 172: 17; 176:4;178:9; unrelated (2)
184:10 I80: 16; 182:23; 188:4; 2I9:2,6
trouble (9) 206:8;207: 16;214:13,15 unresolved (1)
I9:I6;53:13;97:I; two-year (1) 133:10
113: 13; 198:16;200:5,17; 32:18 unusual (1)
20 1:9;216:8 type (14) 128:6
TRs (18) 20:22;25: 13;34:3; up (76)
14:II , l1;16: 13;17:21; 46:23;50:22;54: 19; 11: I,5; 17: 14,20,25;
93:9;112:22;113:7; 62:20;77:3;81 :I9; 19: 13;25:6,7,7,23;26:5,
136:25; 193: 12,13; 112: I7; 129: 19;I40:7; 13;29: 15;33:7, 13,24,25;
194: 16,23;195:5,9,12,14, 161:2;2I7:8 41 :4,9,19;42: 10;43: 13;
I5,16 typed (2) 48: 13;65:8;68:6;71: 13;
TRs-well (1) 19:9;41:9 86:7;95: 15;97:2,5;1 04:6;
194:4 types (2) I12:3, 16;113:5; 114:23,
true (54) 53:25;220:18 25;116:2; 120:3,10,12, 19;
30: 19;34:23;48:22; I22:8; I26:2; 127:4;
49: 11;50:4;51:24;56:5; u 129:9; 133:20; I37: 3;
59: 17;65: 11, 19;69:23; 147: 17, 19,20; 149:4,5,10,
81:9, 12;82: 16;88:2,17; ultimate (1) 24,24;150:21 ;151: 11;
89:10;91 :13, 16;94: 15, 18; 90:10 152:9,20; 154:4;I55:2;
97:25; 102: 13;105: 16; ultimately (2) 163 :20; 164:22; 172:1;
109: I0;124:9; 125:4,16, 80:20;92:8 181 :2I ;I94: 10,10, 13,13;
20; 126: 15,22; 127: 17; um(1) 197:9; 198:2, 6;202:5;
128:5;13 1 :16;133:6, 15; 20:13 215: I6;216:4;221 :3
138:6,25; 146: 14; 148: 11; unclear (2) upon (55)
150:19,19;155:21; 20:19;6I:2 18:9;19:21 ;24:6;29: 15;
157: 18; 165:8;171 :25; uncommon (1) 35:6;39: 14;40:9;56:23;
172: 14,19; 173:25; 123:25 64:2,6;68:9, 16,19;76:3,
187: 16;189:2;203:3; under (8) 12; 77 :22;79: 18,20;83 :6,
218:15;219:6 8:21;35:13;80:1,4,I1; 10, 16;84:3;85:23;86:2,6,
trumps (1) 118:21 ;196:8;200:4 18;87:2;88:5,12, 16,20;
78:15 undergraduate (1) 89:2;92:24;98:23;102:7;
Trust (1) 30:1 108:8; 124:20; 126: 15;
58:15 underling (1) 127:2,21,21 ;142:23;
try (16) 207:13 145: 10; 146:3; 147:I1;
32: 15;49: 15;52:13; understood (2) 150:16;152:10;155:11,
54:17;116:2;138:9; 10:9;150:14 24; 158: 17; 160: 15;
154:7; 157:6; 174: 19,25; unfolded (2) 164: 11, 19;192:6;203:16
176: 14; 177: 12; 184:25; 37:1;80:22 upper (3)
186:25;201 :22;218:10 unfortunately (1) 38:7; 117:3;138: 12
trying (25) 144:14 upper-level (1)
26:9;40:8;67: 11 ;85: 17; unit (3) 116:18
99:9,17; 101 :22,23;105:2; 36:9,10,13 Ups (5)
114: 15; 132: 14; 135: 12; United (5) 19: 13;I13: 1 0; 198: I 0;
Stephen Alan Kent
January 5, 2012
217:7,13
upshot (1)
59:20
urge (3)
118: 18, 19;119:I5
urged (1)
118:4
use (31)
17: 18;24:13;40:23;
52:23;55:3;58:9;64: 1;
76:11 ;78: 1 ;98:2; 108: 13;
114: 16; 116:24;119: 10;
120:9;135:4; 139:17;
144: I ; 15 8: 18; 163: I7;
168: I3; I86: I8;200:1;
203: 19;204: I2,13, 13;
210:19,24;211:19;21 8:4
used (24)
8: 16;40:9;72:22;74: 18;
75:5;79:8;97:24;98:8,19;
104:21 ;107: 16;109: 14,
20,24,25;114:9;116:23;
174:20,24; 175:6; 177:6;
196:18;205:13;211:22
used-the (1)
I14: 17
useful (3)
15:2;1I2:25;197:8
uses (9)
52:21;87:14;115:4;
126: 12; 138:8,9; 152:1 ,2;
193:16
using (15)
16:23;45: 16;46:5;
70:16;86:7;88:11;96:21;
I 09:5,7; 110:22; 121:9;
I35: 18; 177:5;203: 17;
205:8
usually (2)
32:21;216:6
v
vague (1)
145:14
vaguest (1)
145:24
valid (2)
220:10,13
value (5)
111:18;135:2,1 0;
147:18;151:12
values (11)
19:20,22,24;20: 1 0;
114:11 ,13,23;118:2;
136:22;220: 1 '16
var (1)
102:24
variation (5)
109:25; 197:21;203:3,6,
8
variations (3)
109:20;1 1 0: 1; 197:25
(24) touched- variations
Desmond, et al. v.
Narconon, et al.
varies (I)
102:24
various (12)
32:11;38:9;39:2;43:8;
62:7,13;82:6;111:18;
115: 13;135:20;187:5;
216:9
vast (4)
28:2;71:20;137:5;
142:5
Vegas (1)
45:15
verify (1)
14: 14
version (9)
73:14, 14, 15;74:9;
80:24;93: 1; 113: 17;
116:8;179:13
versions (1)
168:14
versus (13)
35: 10, 18;37: I4)23;
38:3;4 I: 19;42: 13,24;
43:17,25;86: 19; 146: 17;
212: l 0
veterinarian (1)
42:4
veterinary (1)
42:3
via (1)
215:11
view (4)
187:17,19, 19,21
views (1)
177:15
VIII-2 (1)
58:23
violated (1)
42:8
violations (1)
38: 10
vision (1)
135:1
visions (1)
138:20
visitation (2)
36:4;40:21
vitamin (2)
50:3;111:24
vitamins (2)
111:22;154:12
vocal(2)
176:18,25
w
waiver (1)
8:11
Wales (1)
183:11
walking (3)
198:1,3,5
wall (10)
l\:lin-C -Script@
18:2,2;62: 11 ;89:20; 72: 17;77:23;80:22,22; Wollersheim (1)
90:1 ;197: 14, 15, 15; 198:2, 87:25;89: 19;90:2 1 ;95:9; 38:4
6 107:3; 112:1 1 ;113:7; Woods (2)
Walton (1) 116:19;123:10;132:11; 37: 13;43:18
32:20 137:1,2, 12; 141 :4;150:24; word (19)
was-and (1) 153: 12;171 :20; 193: 15; 17:8, 8,12;81:17;
208:6 197:18;203:3 112:15;119:10;165:15;
Washington (2) whatsoever (2) 174:19,21 ;201:11, 12,19;
92:12, 13 49:3;70:25 211: 18, 21,22;212:5;
waste (1) whole (11) 214:24;215:2;216:5
160:23 37:9;53: 17;97:2; wording (1)
Watch (2) 108:23; 114: 12; 137:9; 94:7
179:1,3 138:11; 139: 16; 174:22; words (11)
Waterloo (6) 184:6; 195:22 17: 14;50:5;82:5; 125:7,
33:5,11 ; 178:4,5, 7; who's (7) 17;138: 17; 139:25; 177:5;
180:10 113 :21; 115:20; 174:7; 204: 12;216:7;218:7
way (66) 177: 1,8; 180:8; 184:23 work (36)
10:6;12: 10; 13:25; whose (1) 11:10;24: 13;27:7;31:6;
15:23 ;20:2,6;21 :23; 74:24 33: 18;34:3;39: 13;42:2;
22:24;56: 1;58: 18;59: l; widely (2) 51 :8;64:24;66:8;71: 13;
61 :22;67:2;72:5;80: 10, 18:15,18 109:25;110:1;115:5,7;
l3;83:I ;84: 17;97:9; Wikipedia (2) 119:24; 157:3;165: I 1;
100:2; I05:22;109: 12; 77:2,5 166:20;175:24;179: 17;
110:6;114:19,24; 116:3,5, wild (1) 181:10;182: 19;183: 16;
6,9;124: 13;132:3; 134:7; 33:25 185: 11;186:2,4,21;187: I ,
135: 13,21; 137:22,25; William (2) 4,5,8,12,24; 199:9
138: 13,23; 139: 1; 150: 10; 95:3;148:6 worked (5)
156:5;175:24;176:21; Williams (3) 18:14;23: 12;30:8;36:9;
200:24;20 1: 1 ;206: 14,17' 46:3;172:20;174:2 75:24
18;207:2;208: 12;209:21; Wilson (1) working (7)
210:8,12;212:3,18,22; 37:14 26: 10;36: 15;136: 10,
217:4,5,6, 15;218: I, 17,20; wind (2) l 0; 196: 11,20;202:9
219:19,20;220:11 86:7;95:24 workplace (3)
ways (8) wins (1) 42:3,6;44: 10
38: 12;86:25; 113:5,6; 120:9 works (17)
114:8,19;139:4;177:2 WISE (3) 18:9;94:17; 125:2,8, 19,
weak (1) 45: 11,16;46:2 23;126:8, 14,16; 132:18,
110:8 'vithdraw (1) 19; 137: 17; 141:16;
we!J (10) 220:20 146:23;160: I ,8, 15
14:1 ,3,4 ,7, 13;34: 19; withholding (1) World (5)
62: 13;17I :23; 172:1,8 120:19 4 1 :25; 149: 16; 176: 19;
weed (1) withholds (7) 187: 14,1 8
26:24 120:3,6, 10,12,17,18; worse (2)
weeding (1) 165:17 186:23;199:12
26:24 within (7) worth (1)
weight (2) 106:7, 18;143:25; 122:1
188:5;195:22 157:7;159: 12;192:2,19 write {12)
well-being (1) without (5) 26: 16;85: 13; 115: I 0;
151:22 74:4;118:20;135: 18; 120:2,3,9, 12, 19; 179:11,
well-educated (1) 203: 16;207: 15 ll ;202:5;210:4
186:14 witness (37) write-ups (1)
well-known (2) 9:20; 15: 17;37: 16; 202:13
193:24;207:8 40:14;44:1 2,13;57: 11, 15, writing (3)
weren't (2) 18;58: 1;59:7;74: 14;85:6; 27: 17;120: 10;183:2
141:11;192:7 90:4;94:4;108: 12; 117:11' writings (8)
whatnot (4) 15,20; 142:2;143: 12; 95:20;125: 14;150:5;
50: 17; 116: 14;152: 8; 144:23; 145:1 ;160:5; 165:19;174: 11;202:25;
192:25 161: 16;162: 18; 163: 16; 203:2;207:9
what's (43) 165:8; 169:6; 173: 18; written (21)
10:23; 12:4; 16: l ;17:2, 188: 16; 191:9; 199: 18; 34:24,25;38: 18;40:20;
7,21,25;27: 19;29: 16; 202:23;203:13;215:17,23 41: 14;52:21;74: 18;
37:11, 17, 19,2I ;41 :24; witnesses (2) 131: 15;148:6;153: 12;
42: 12, 16,22;45:9;61 :4; 23:9;41:2 172:3,10,15; 177: 5,12,15;
Stephen Alan Kent
January 5, 2012
180: 13; 181:21; 182:23;
203:3;214: 18
wrong (5)
102:9; 184: 10; 199:2,3,3
wrote (14)
176:3,6; 177:23;
179: 16;180:22; 181: 10;
182: 14, 15,20; 184:24;
207: 11;21 8:22;219: 1, 10
y
year (7)
33:6, 12;45:25; 101: 10;
176:4; 178:9;214:2
years (27)
l 0: 17; 16: 18; 18: 15;
22:2;30:5,6,25;32:25;
33:23;70:8;73:9;76: 1;
90:23;96:22;105:22;
I 06:7, 18;127:23; ! 51 :23;
152:4;156: 10;178:21;
181: 18; 182: 17;207:9,16;
213:23
yelling (1)
137:3
Yesterday (11)
21:11, 13;24: 15,20,21;
25: 19;26: 12;27:5;
166:24;167: 16; 191:20
York (2)
170:25;171:1
z
Z-A-B (1)
178:14
Zablocki (1)
178:17
Z-A-B-L-0-C-K-1 {1)
178:16
0
07 (1)
153: I
0737 (1)
149:3
0758 (1)
149:3
0760 (1)
163:18
0767 (1)
163:18
0774 (2)
150:21;152:23
0776 (1)
150:24
0780 (2)
151:16;153:18
0793 (1)
152:14
0797 (1)
(25) varies - 0797
Desmond, et al. v.
Narconon, et al.
150:2I
0798 (1)
147: 15
0801 (1)
147: 15
0802 (1)
146:21
0808 (1)
I46:22
0809 (1)
I45:11
0820 (1)
I45:12
0821 (1)
144:24
0834 (1)
145: 1
1
1 (23)
8:2; 10:22; 14:12;16: 10;
34:3, 12;35:4;52:8;69:20;
71 :10;93:6,9, 19;94: 16;
126:23; 134:6; 140: I9;
142:19; 154:20;169:17;
I72:9, I6;I93:5
1:08 (1)
Il7: 21
1:25 (1)
117:2 1
10 (3)
I 04:3;105:6;1 08:6
10:00 (1)
24:22
100 (1)
86:17
11 (5)
47: I ;103:7, 16; 105: 11;
108:6
11:00 (1)
25:7
11:16 (1)
50:7
11:17 (1)
50:7
11:41 (1)
68:2
11:58 (1)
68:2
114 (1)
196: 10
12 (12)
47: I ;113: 18,20; 123: 1,
3; 168:5; 169:23; 170: 13;
I 91: I 9;198:22,23,24
120 (1)
122: 1
1-28 (2)
58:5,2I
12-step (4)
123:24;124:4,6, 10
12th (1)
t\'lin-t:-Script
29:I1 1999 (3) 203:25
13 (4) 37:24;38:2;40: 19 250 (2)
47: I ; 143: 19;149:3; 166:10,11
150:15 2 26 (5)
136 (2) 169: 12,20; 170: 14;
56:10;60:18 2 (37) 191:19;206:13
14 (6) 11:6; 12:6, 17;13:9, 19; 269 (1)
47: 1;113:18,20; 16: 14;21: 17;26:21 ;28:2, 200:4
150:20; I52:22;157: 12 24;52:8;69:20;70:2; 27 (4)
1-42 (2) 71: 10,19;73:2,8,17; 171: 18,20; 172:2,9
58:5,22 104:20;124: 13,16; 28 (2)
15 (4) 125: 18,21; 126:5; 137:4; 173:22,24
46:23;47:1;147: 14; I40: I9;I42:16,19; 29 (1)
148:5 143:25;144:6;152:18,21; 209:25
16 (6) I 58:8; 163:7; I64:4,6;
47:1 ,3;146:21 ;147:4,6, 166:2 3
I1 2:05 (1)
160 (1) I43:21 3 (16)
130:16 2:15 (1) 16: 19;23:21 ;24:2;28:9;
167-acre (1) 143:21 29: 12;52: 13;54:16;
151:8 2:54 (1) 68: 10;71: 14,16;1I2:9;
17 (2) I 69:9 145:25; 148: 14;170: 18;
145:11;146: 11 20(6) 196:5;2I9: 17
18 (5) 25: I 0;38: 17; I 05:22; 3:00 (1)
143:20; 144: 16, 17,24; 163: 15; 164: 18; 178:21 169:9
145:8 2000 (2) 3:30 (1)
19 (4) 45:23;214:2 24:22
38: 17; 163: 14; 164:8, 16 2000s (2) 3:31 (1)
1902 (1) 88:3; 105: 1 I 89:I5
207:10 2001 (2) 3:33 (1)
1950s (1) 21:21,22 I 89: I5
95:19 2003 (1) 30 (1)
1960s (1) 45: 14 209:25
98:20 2004 (7) 31 (1)
1966 (2) 13: 16;21 :20;73: 15, 18; 2I0:1
95:2;96: 19 93:5;98: 12, 15 32 (1)
1970s (1) 2008 (4) 210:2
98:20 88:4;98:3,8;107: I5 33 (1)
1974 (1) 200-item (1) 210:3
105:7 109: 17 333 (1)
1975 (2) 201 (1) 193:20
30:1 1;3 1:20 212:23 34 (1)
1979 (2) 2010 (2) 210:4
151:21; 153: 16 45:23; 174:3 368 (1)
1980s (2) 2011 (2) 195:24
98:20;1 16: 11 22: I0;45:25 396 (1)
1983 (2) 20th (1) 154:20
31:2I;32:12 207:6
1984 (5) 21 (6) 4
32: I7;35: 10,13; I 05: I 5, 20:2,2; 169:I1,17;
19 170:13;191:19 4 (18)
1989 (5) 22 (6) 14: 12; 16: 10; 17: 15;
153:10, 11, 14,22,23 46:19,21 ;170: 17; 27 :20;28: 15,25 ;29: 16,22;
1990s (4) 191:19; 196:4,11 52:3;58:3;69:21 ;71 :3,8,
59:21;88: 1 ;91: 1 ;159: 1 23 (8) 18, 19;93 :9; 166:4;208:23
1991 (3) 46:20,2 1,23;47:3; 4:21 (1)
21 :20;73:14;98: 15 169: 18;170: 13; 191: 19; 221:10
1993 (3) I 97: 1 4:30 (1)
59: 11; 159:2; 181 :2 1 24 (4) 25:3
1997 (l) 169: 18; 170: 13; 191:19; 43 (1)
35: 17 198:9 11:3
1998 (3) 25 (4) 4a (6)
37: 13,22,24 169: 19; 170: 14; 191: 19; 17: 16,16;112: 19,21;
J Fischer @QAReporting.com
Stephen Alan Kent
January 5, 2012
169:18;I97: 1
4b (5)
17: 16,18;73:1 1, 17;
112:23
5
5 (8)
I9: 12,12,20;28:20;
29:21; 113:9; 169: 19;
198:10
50s (2)
95:21;96:1
595 (2)
II 8: 10;120: 1
6
6 (22)
8:3;19: 13,20;20:1,1, 1;
77:7;93:11;114:10;118:2,
9; 121:4, 14,22;122:12, 19;
123:6,1 O; I60: 19;168:5;
169:23; 197:13
60 (2)
10: 17;96:25
607 (1)
120:8
60s (1)
I 12:25
65 (1)
118:I6
66 (1)
95:8
69 (1)
119:12
6b (1)
93:13
7
7 (9)
20:2;57:25;59:3;62:4;
80: I2; 115: 1;159:21;
169: 19;204: 1
70 (1)
96:25
70s (2)
95: 14;133:8
72 (3)
95:8, 14;1 19:20
74 (1)
104:5
774 (1)
153:2
779 (2)
153:17,17
79 (1)
121:12
793 (1)
157:12
797 (1)
152:23
(26) 0798 - 797
Desmond, ct al. v.
Narconon, et al.
8
8 (13)
16: 10;72: 15, 18;77:23;
92:24;93: 11 ;94:20;
11 1:10;116:3;169:20;
193:20;206: 14;209:21
SO-building (1)
151 :7
80s (1)
181:19
838 (1)
59:8
870 (1)
57:23
885 (I)
58:3
9
9 (4)
16:12, 12;93: 12; 103:6
99 (1)
43:20
1\lin-U-Scri]lt Q&A Reporting Services, Inc.
Stephen Alan Kent
January 5, 2012
(27) 8 - 99

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