Professional Documents
Culture Documents
FILED
SEP 29 87
4 53 PM
U.S. DISTRICT COURT
NEW HAVEN, CONN
Plaintiff
v.
WERNER ERHARD, ET AL
Defendants.
STATE OF CALIFORNIA
CITY OF BERKKELEY
SS
I, Margaret T. Singer, Ph.D., being duly sworn according to law do hereby state as
follows:
Counsel for plaintiff in the above case, Gerald F. Ragland, Jr., has requested
that I briefly outline my opinions as to the foreseeability of harm from the est
training, the role of emotional distress in the marketing of the trainings and the
question of the cause of Jack Slee�s death. It is my opinion that the defendants
in this case either knew of or should have known that the est training caused
emotional distress on the part of most individuals taking the training and that
this emotional distress created the high probability of psychological and
physiological harm. While it was not the highest probability, the range of
foreseeable physiological harm included death. It is further my opinion that the
defendants intentionally inflict emotional distress as part of their system of
marketing the training. While his death was not predictable, harm of that general
nature was foreseeable and, in retrospect, his death was the product of a well
known harm produced by the defendants, emotional distress.
[signature]
Margaret T. Singer, Ph.D.
Subscribed and sworn to before me the undersigned notary public this 16th day of
September, 1987.
[signature]
My commission expires: Jan. 14, 1991
OFFICIAL SEAL
LISBETH A. HIBBARD
NOTARY PUBLIC CALIFORNIA
COUNTY OF ALAMEDA
My Commission Expires Jan. 14, 1991
This is to certify that a copy of the foregoing was mailed postage prepaid to John
R. McGrail, Esq., P.O. Box 1111, New Haven, Connecticut 06505 and Michael M.
Futterman, Bower & Gardner, 110 East 59th Street, New York, NY 10022 this 24th day
of September, 1987.
[signature]
Gerald F. Ragland, Jr.