Defendant, NI, is a corporate sham and illusion, is merely
adjunct, subsidiary,licensee and/or alter ego
Defendant, ABLE, and is heavily controlled by Defendant, ABLE.
Defendant, Wootan, is the Medical Director
NO. As the medical director,Wootan approves all treatments, and has the responsibility to monitor and educate NO
recognize when a patient needs medical attention.
Defendants, NO, NI and ABLE, all rely exclusively upon the written "technology"
L. Ron Hubbard ("Hubbard"), the founder
address the drugand alcohol rehabilitation needs
students enrolled in Nmconon programs.
This misplaced reliance is despite the fact that Hubbmd had no !mown training oreducation in the field
drug and alcohol rehabilitation.
implement what they advertise as drug preventionand education progr8JI1s, based upon the texts
Hubbard, and are forbidden to deviate fromthese texts. However, none
incorporate !mown acceptable treahnent for drugand/or alcohol addiction.16.
order to use the Hubbmd teclmology, NO must pay a license fee to NI
agree to use the Hubbmd technology in a manner that is heavily regulated by NI.17. Part oftl1e Hubbard teclmology, as regulated by NI, includes the course materialsand purification component used
to "rehabilitate" students. However, neitl1er the materialsnor the purification component are designed to advance alcohol and/or drug rehabilitation.Instead, the materials are comprised
eight different levels tlmt me virtually identical to
course materials promoted by ABLE, none
which specifically address treatment for drugand/or alcohol addiction.3