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:

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IN THE STATE COURT OF DEKALB COUKTY
STATE OF GEORGIA
PATRICK ·c. DESMOND AND MARY )
C. DESMOND, INDIVIDUALLY, AND)
MARY C. DESMOND, AS )
ADMINISTRATRIX OF THE ESTATE )
OF PATRICK C. DESMOND, )
Plaintiffs, )
) CIVIL ACTION FILE
vs. )
) NO. 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 I NTERNATIONAL, )
Defendants. )
Video deposition of MARIA DELGADO, .
taken on behalf of the Plaintiffs, pursuant
to the stipulations contained herein, before
Jo Torno££ Fischer, RMR, CCR No. B-924, at
288 Washington Avenue, Mariet ta, Georgia,
on October 24, 2011, commencing at the
hour of 10:00 a.m.
Q&A REPORTING SERVICES, INC.
Certified Court Reporters
2165 Fairhaven Circle, NE
Atlanta, GA 30305 c , ~ 1
404.233.3300 ** (Fax) 404. -233\.-15301
1
-'. [.\ .
2t\\2 ,\IJG 2ll ~ : ' \0: 49
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Page 2 Page
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1 APPEARANCES OF COUNSEL 1
INDEX TO EXAMINATION
2 . ON BEHALF OF THE PLAINTIFFS: 2 I
3 JEFFREY R HARRlS, ESQ. 3
By :Mr. Harris . . .... . ............ . 7 I
Harris Penn Lowty Delcampo, LLP 4

4 400 Colony Square, Suite 900 5
1201 Peachtree Street, NE
6

5 Atlanta, GA 30361

- --
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(404) 961-7650
7
6
8
j
- and -
9
INDEX TO EXHlBITS
7
1 0 PLAINTIFFS'
ij
REBECCA FRANKLIN, ESQ,
EXHIBIT DESCRIPTION PAGE
8 Franklin Law, LLC
11

400 Colony Square, Suite 900
1 Delgado Development

l
9 1201 Peachtree Street
12 Articles oflncorporation 16
I
Atlanta, GA 30361
13
2 Delgado Organizational Chart 21
10 (404) 961-5333
14
3 Copies of Checks to

11
Sovereign Place 46
12
15
ON BEHALF OF mE DEFENDANTS NARCONON OF GEORGIA
Lease- Apartment Z2 48
<
13
4
1 6
14 KAlliRYN S. WHITLOCK, ESQ.
5 Lease- Apartment Zl 51
D:ew, Eckl & Farnham, IJ..P
17
15 880 West Peachtree Street
6 Lease - Apartment Z3 52
.
P.O. Box 7600

16 Atlanta, GA 30357
lB

(404) 885-1400
7 Lease- Apartment Z4 52
'-
17
19

18 8 Lease- Apartment Z5 53
j
19 ON BEHALF OF 1HE DEFENDANT DELGADO DEVELOPMENT:
20
20 SEAN L. HYNES, ESQ. 9 Lease - Apartment Z6 54

Downey & ClevelaJld, LLP
21
}
21 288 Washington Avenue 10 Rent Roll - Sovereign Place

Marietta, GA 30060
22 as of6-15-2008 54
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22 (770) 422-3233 23 11 Payroll Check toP. Desmond 66

23 24
12 Packet of .Materials from

24
Delgado DcveloprneJJtto
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25 (Continue-d) 25
P. Desmond 85

Page 3 Page 5


ON BEHALF OF Tiffi DEFENDANTS USA CAROLINA ROBBINS,
1
P. Desmond Preliminary

1
13
MD. and 11IE ROBBINS GROUP, INC.:
Treatment Plan, 9-25-07 90
2
2
ROBERT G. TANNER, ESQ.
14 Interrogatory Responses 98
i 3 Weinberg, Wheeler, Hudgins, Guon & Dial, LLC
3

Suite 2400
15 Monitors' Duties and
!!
4 3344 Peachtree Rl:lad
4 Responsibilities 104
'

Atlanta, GA 30326 5
16 Medical Examiner's Report,
i 5 (404) 876-2700
P.Desmond 139
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6
6
7
17 Knowledge Reports 147
B
7
I
ALSO PRESENT: BLIZABEIH KEMP, Legal Technology 8
9 Services, 770-5 54-1633
9

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1 (Tiffi FOLLOWING TRANSCRIPT CONTAINS QUOTED 1 we can break and you can go get some water or do


MATERIAL; SUCH MATERIAL IS REPRODUCED AS

2 whatever you need to do.
,
2 READ OR SPOKEN.)
'

3 3
A. Okay.

4
4
Q. If I ask you a question and you don't

5
- --

6
5 understand 1he question, please tell me that you don't
i
7
6 understand the question and I'll do my best to rephrase

(INTIIEFOLLOWINGTRANSCRIPT, A DASH { --]
7
it for you, okay?
i
8 IS USED TO INDICATE AN UNINTENTIONAL OR
PURPOSEFUL INTERRUPTION OF A SENTENCE;
8 A. Okay.


9 AN ELLIPSIS[ ... ] IS USED TO ll\1DICATE
9
Q. Have you ever had a -- had your deposition
' 'i
HALTING SPEECH OR AN UNFINISHED
10 SENTENCE IN DIALOGUE, ORAN OMISSION
10
taken before?

OF WORD[S] WHEN READING WRITTEN 11 A. No.


11 MATERIAL.)
12
Q. All right What did you do in order to
.

12

13 -- -
13
prepare for your deposition here today?
!
14
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A. I had a meeting with him (indicating). TI1at
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15 (Thereupon, the court reporter disclosed that she was

there on behalf of Q & A Reporting Services, Tnc.
15 was all.

16 In compliance with Article lO.B of the Rules and 16
Q. Anybody else present in the meeting?

Regulations of the Board of Court Reporting of the
17
A. No. I
17
Judicial Council of Georgia and O.C.GA 15-14-37(a)

and (b), the court reporter discloses that she was
18
Q. Did you have any discussions with any other

1 8 retained by Jeffrey R Harris, Esq., to take doVvll
19 witnesses, J\.1r. Delgado or anybody else involved in this
I
the proceedings. Q & A Reporting Services, Inc.
i 19 will charge the attorneys the usual and custollllliY
20 case, to prepare for your deposition?
rate for the transcript, and 'l'iill be paid by the 21
A. He told me that he had a deposition today --


2 0 attorneys upon their receipt of the transcript)
22
Q. Okay. l
2 l
22 23 A. --at 2:00, but that was it

23
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Q. Did you talk about the deposition with him at

24

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all?
>
---


Page 7 Page 9 I
.
1 THE VIDEOGRAPHER: We're now on the
1 A. No.


2 video record. This is the beginning of tape
2
Q. All right. What are you doing now? What is

i 3 number 1; the time is 10:00 a.m.
3 your oc- current occupation?
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4 MR. HARRIS: If you'd go ahead and swear
4 A. I work 'vith an attorney. •

5 witness.
5
Q. What attorney?
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6 (Thereupon, the witness was sworn.)
6
A. Matt Hines.

7 MR. HARRIS: This will be the deposition
7
Q. And where is :Mr. Hines?
8 of Maria Delgado, taken for all purposes
8 A. Austell, Georgia.
9 allowed by the Georgia Civil Practice Act
9
Q. What kind of work does he do?
10 Objections are reserved and made in
10
A. He does criminal, PI, divorces, a little bit
11 accordance with the Civil Practice Act and
11
of immigration.

12 the court's standing discovery order.
12
Q. Where did you grow up?

13 MARIA DELGADO,
13 A. In Bolivia.
I
14 having been first duly sworn, was examined and
:.4
Q. Okay. And when did you first come to the
15 testified as follows:
15
United States?

1 6 EXAMINATION
16 A. 2000 --I mean, 1999.
'
17 BYMR. HARRJS:
17
Q. And what- and what brought you to the U.S.?

18 Q. Good morning. How--
18
A. My husband. Ex-husband.


19 A. Good morning.
19 Q. And -- and tell me about that; how did you

'
20 Q. --are you, Miss Delgado?
20 come to be here? How did he bring you here?

g
21 A I'm all right
21
A. He's American, he was --his father had a
1

22 Q. My name is Jeff Harris; I'll be asking you
22
heart attack, so he had to go to Bolivia to replace his
i
23 some questions today. We're going to cover probably a
23 dad in Iris business. His dad was Bolivian. And then he
ii

24 good bit of ground, and so if at any point in time you
24
met me, and then we got married over there, and we
.
25 need to take a break, feel free to let me know that and
25
stayed there for two years and then we moved here.
• • • ·w· •· •n"·'·>?"'' '"M • ..,....... ....,,,._,, .. • ........ .....
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1 Q. And tell me about yom work history when you 1 school affiliated with the Church of Scientology, ~
2 arrived in the United States; what did you do? 2 cotTect? i
3 A I was --I had - I was a mom for -- I mean, a 3 A. No. ~
4 housewife for a long time, because I had t\.vins, there 4 Q. Okay. Well, the- the tech-- the Study Tech i
5 were two. And then I had a baby; I was pregnant when I 5 that Mr. Hubbard created is taught to the students I
~ ~
6 came here. And then I started working at the Church of 6 there, is it not? I
7 Scientology. And then, after that, I wotked at a 7 A. It's used. TI1e -- the works that he --that ~
8 clinic -- well, not a clinic, naturopathic - 8 he did, yes. ~
9 naturopathic healthcare. And then-- let's see. -- at 9 Q. In fact, that's the --that's the primary J
1 0 a chiropractor office. 1 0 cunicuhnn, is it not? -- ~
a
11 Q. When--the--sothefustjobwhenyoucame 11 A. No. ~
12 to the United States that you've had, as I understand 12 Q. -- The Study Tech? I
13 your recitation of your history there, was with the 13 A. No.
14 Church of Scientology? 14 Q. Okay. What was your occupation at the !
15 A. Yeah. 15 LafayetteAcademy? I
16 Q. What did you do with the Church of 16 A. Enrolling students. ~
17 Scientology? 17 Q. And-- and by the way, Lafayette, that's I
18 A I worked -- worked .in the accounting part of 18 actually Mr. Hubbard's fu"St name? ~
19 the church. 1 9 A. It is. ~
2 0 Q. Which church? 2 0 Q. And that's what the school is named for? ~
2 1 A. OfScientology. 21 A. Yeah. ]
2 2 Q. No, I mean whe -- rm sony, geographically 2 2 Q. I'm sony, what VI'8S your job, again, at ~
2 3 where was it? Was it -- 2 3 Lafayette Academy? ~
2 4 A. Was here. 2 4 A. I enrolled students. ~
~ 2 _ s ___ Q_. _-_-_in_A_t_lan_ta,_o_r _so_m_e_w_h_et_·e_e_Is_e_? _____ -;_2_5 ___ Q_._An_d_w_h_at_h_a_pp_e_n_ed_w_t't_h_th_e_L_a_fa_y_ett_e_A_cad_ei_n_y?_. -1i
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A Yes.
Q. Okay. rm sorry I interrupted you. You said
the accounting department?
A Yes.
Q. What did you do? Just give me an overview of
your duties.
A Just kept track of the money.
Q. All right. And then did you leave the Church
of Scientology, in terms of employment, after that?
A I did; I was pregnant. Yeah.
Q. Okay. And then you-- you told me then the
naturopathic-- the office; what was the other one?
A The chiropractor?
Q. Chiropractor. What did you do after that?
A. I worked at Narconon.
Q. All right. Do you ~ o w approximatelyvvhenyou
started working at Narconon?
A 2003.
Q.
A.
Q.
A.
And what about the Lafayette Academy?
Oh, yeah, that too.
Okay. When- when did you work there?
2001.
Q. And how long were you there?
A Until 2003.
Q. And the Lafayette Academy is a-- is a-- is a
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A. It closed down in 2003.
Q. Why did it close down?
Page 1 3 ~
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A. I guess finances. ~
Q. All right. Any other jobs that we haven't hl
covered? Up until the present. You left -- well, you ~
got us to Narconon, which I think you said you started
inWOO? I
A. Right.
Q. And then you-- you told me where you work
now,--
A Right.
Q. -- so between the two, any other jobs?
A. It was Delgado Development.
Q. Delgado Development?
A Yes.
Q. And when did you first begin working for
Delgado Development?
A. In2006.
Q. Prior to --
A.
Q.
A.
Q.
A.
My husband was-- was the owner, so ...
He was the ovmer of Delgado Development?
Uh-huh (affirmative).
Was --was he an officer in that company?
He was.
Q. Was --was he the majority shareholder?
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1
A. Yes.
1
A. I don't remember the name of-- the specific
I
2
Q. In Delgado Development?
2 name of the Delgado Development or Corporation or

3
A. Yes.
3 whatever.
4
Q. All right. What about Delgado Business
4
Q. Well, as we sit here today:- well, Delgado

5 Corporation?
5 Development Corporation was I believe dissolved in 2009?
t
6 A. I don't know.
6
A Okay. So that's -- okay. Yeah. I guess.
I
7
Q. Are you familiar with that company?
7
Q. Do you know whether it was dissolved or not?
I
8
A. I thought it was Delgado Development.
8
A. There was the company that - that I was the
9
Q. All right. Prior to Delgado Development's
9
president of, that -- it was dissolved. I don't
f
10 fonnation in I believe 2006, was there a company called
10
remember the exact name. I thought it was Delgado
11
Delgado Business Corporation?
11
Development. I
12
A I don't know.
12 (Thereupon, marked for identification

13
Q. You-- you're not -- you don't know whether
13
purposes, Plaintiffs' Exhibit No.1.)
1
1 4 that existed or not?
14
BY MR. HARRIS:

15
A. Huh-uh (negative). 15 Q. All right. rm going to show you what rve
I
1 6
Q. When did you first file bankruptcy?
1 6 marked as Plaintiffs' Exhibit 1 after-

17 A. In-in2006.
17
A. Oh. l
18
Q. Okay. And you- you actually filed
18
Q. --your attorney --
i
1 9
bankruptcy in September of '06, as I recall, right? Is
19 MR. HYNES: Look at it at the --
20 that correct?
20 BY MR. HARRIS:


2 1 A. Iihinkso.
21
Q. -- takes a look at it.
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Q. And you - and you formed Delgado Development
22
MR. HYNES: -- same time as me.
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23 Corporation a year before you filed bankruptcy, did you
23
MS. WHITLOCK: Sean, if you don't mind

ll

24 not?
24
passing that around so we can all see it


25 A. Me, no.
25
before he asks questions, that'd be great.

"
Page 1 5 Pa g e
17 i
1
Q. Okay. Well, did you list Delgado Development
1
(Discussion off the record.)
I
2 Corporation in your bankruptcy petition?
2 BY MR. HARRIS:
3 A. Huh-uh (negative).
3
Q. All right. On Exhibit l, on the third page of
I
4
Q. Youdidnot?
4
it, the articles of incorporation of Delgado Development
5
A. No.
5 indicate that you were the registered agent for that
I

6 Q. Okay.
6 company.
i
7 A. I don't think so.
7 A. · Uh-huh (affirmative).
8
Q. Did you have any ownership interest in Delgado 8· Q. Was that correct?
!
j
9 Development Corporation at all? 9 A. Uh-huh (affirmative).
•l
10
A. No.
10 Q. All right. And you were also listed as the



11
Q. When did you first --
11 CEO of that company?
.
'J

12 :MR. HYNES: Object to the fonn ofthe
12
A. Uh-huh (affinnative).
I
13 question just in terms of time.
1 3
Q. Were you tbe CEO when it was incorporated?


14 MR HARRIS: Good question. Thank you.
14 A. Uh-huh (a:ffumative).
I
15 BY MR. HARRIS:
15
Q. So rm confused. I thought you told me


1 6
Q. At some point did you later acquire an
1 6
earlier in your deposition that it was your husband's

17
intere.-."1. in Delgado Development?
17
company when it was incorporated?
1 8 A. When I divorced, -
1 8 A. The first time.

1 9 Q. When--
19
Q. Okay. "The first time" meaning what?
I
2 0
A. --yes.
20
The -- the document that I'm handing you right
2 1
Q. - did you divorce?
21 now indicates that this company was incorporated in
i
22 A. 2006-2007. Oh, my goodness. 2007.
22
2006;. the articles of incorporation show you as the only
23
Q. So when you divorced, you actually at that
23
person involved in that company other than the CPA,
24 time acquired an interest in Delgado Development
2 4 Mr., I think, Ronk, who incorporated it.
25 Corporation?
2 5
A. Okay. So he was the one --founder of-- of
• . -· .... .,.,...
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1 Delgado Development. My husband. At the time.
1
Q. What was the business of Delgado Development
2 Q. Okay. 2 Corporation?
I
3 A. In 2003. When v.-e divorced, I took over and I
3 A. We had housing for-- for people that use '•
4 incorporated the -the same business.
4
drugs.
~
!
5 Q. Okay. Was --what was the plior business 5 Q. All right, let's talk about Delgado
!
6 called? 6 Development for just a second.
;
.7 A. I think it was Delgado Development. I - I
7
A. Okay. I
8 thought it was Delgado Development.
8 Q. From2006 to 2009, you're -- you're both the I
9 Q. Well, could it have been Delgado Business 9 CEO and the president of Delgado Development, right?
i
10 Corporation? · 10 A. Uh-huh (a.ffinna±ive).
11
A. It could have been.
11
Q. And were you at the same time working at
~
~
~
12 Q. Okay. So 2006 you're the CEO of Delgado 12 Narconon?
~
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Development?
13 A I think at the beginning, yes.
~
14 A Uh-huh(affirmative).
14
Q. When did you -- excuse me, when did you stop
~
~
15
Q. And you don't know whether or not there was a
1 5
working at Nar -- Narconon?

~
16 prior Delgado Development Corporation that was in
1 6
A February of2007. Or '08.
~
.
17
existence at that time?
17 Q. Why did you leave Narconon?
I
18
A. Tell me again?
18
A. Because I was staying at the apartments really i
I!
19 Q. You don't know whether or not some other
19
late, like 3:00 in the morning, 4:00 in the morning, so ~
~
20 company called Delgado Development was incorporated 20 I couldn't-- like my schedule was just too bad.
~
~

21
prior to 2006?
21 Q. So vvhen you were working at Narconon you were
~
~
22
A. I know that my husband owned Delgado
22
staying at the apartments at Delgado Development?
'
·'
23 Development. I don't know what-- what was the correct
23
A. Yes.
24 name, but ... 24 Q. And that's the reason you left?
.
25 Q. Do you know whether his company was
25 A. Yes. ~
.
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Page 19 Page
21 ~
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1 incorporated? 1 Q. What were you doing at the apartments?
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2 A. !twas. 2 A. I was supervising.
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3 Q. And were you involved in that company? 3 Q. Supervising what?
~
4
A. No. 4 A The students.
~
5 Q. All right. So 2006, Delgado Development 5 (1hereupo.n, marked for identification
~
6 Corporation is fJISt incorporated, you're the CEO, 6 purposes, Plaintiffs' Exhibit No. 2.)
~
7 right? 7 BY MR HARRIS:
8
A. Uh-huh (affirmative). 8 Q. Let me show what I've marked as Plaintiffs'
I
9 Q. You're the only shareholder? 9 Exhibit 2 to your deposition.
~
10
A. Uh-huh. (affirmative). 10 MR. HARRIS: This one I actually have
~
11 Q. There's no board of directors? 11 copies of.
~
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12
A. Right. 12 MR. HYNES: Okay, gt·eat.
1 3
Q. No officers other than yourself, and you were 13 BY MR. HARRIS: ~
~
14 in fact both the president and the CEO of this company, 14 Q. On this organizational chart you're listed as ~
15 correct? 15
1he "Senior director of administration."
I
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A. Uh.-huh (a:ffumative). 16 A Uh-huh (affumative).
I
17
Q. And the company is in existence from 2006 17 Q. Was that the title that you bad at the time
18 unti12009, when it is-- there's an attempt to ::..s
when you were staying at these apartments and
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19 administratively dissolve it, right? 19 supervising?
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20
A. Uh-huh (affumative). 2 0 A. I don't know. I don't remember if I was-- if ~
21 Q. Why did you administratively dissolve Delgado 21 overlaps.
~
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22 Development Corporation? 22 Q. What - what job titles did you have at
23
A I didn't want to do it anymore. 23 Narconon when you were there?
I
24 Q. Whynot? 24 A. Senior director of administration.
25 A. Because my health was really in bad shape. 25 Q. Okay. So that was the only job that you had?
6 (Pages 18 to 21 )
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Page 22
1 A. Uh-huh (affirmative).
2 Q. So if you were working at Narconon and you
3 were staying at the apartments, then you would have been
4
the senior director of administration, would you not?
5 'Cause that's the only job you had at Narconon.
6 A. Right. What -- okay.
7
Q. I just-- lefs go back to why you said you --
8 you lefl:. You were staying at the apartments late?
9 A. Uh-huh (affirmative).
10 Q. And what were you doing?
11 A. Supervising.
12 Q. Supervising who?
13
A. The students.
14
Q. Okay. "The students"; what students?
15 A. The students that were at the housing.
16
Q. And where did those students come from?
17
A. From Narconon, and sometimes -- a few times,
18
from other places that they wanted help.
19
Q. Where -- name the other places that sent you
20 students, besides Narconon.
21
A. Just the --the web site, I guess, brought me
22 one or two that I -- that needed help.
23 Q. What web site?
24 . A. Don bad created a web site. And -- from that
25
web site. And then there were friends that will --
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A. (Pronouncing) Ehren. Byres. Yes.
Q. Who's paying for Mr. Hynes?
A. I don't know.
Are - are you paying for him?
No.
Page 24
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Q.
A.
Q. Do you know whether Narconon is paying for
him?
A. No.
Q. You don't know?
A. I don't know.
Q. All right.
MR. HYNES: Jeff, --
THE WI1NESS: My husband-
MR. HYNES: -- I can tell you too
that - that no bill has been submitted yet.
MR. HARRIS: Okay.
BY MR. HARRIS:


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Q. Delgado Development Corporation; in the three
years between 2006 and 2009, did-- did you ever have
any Jdnd of board meeting?
A. We had- we had a staff meeting every week,
:q
actually.
Q. "Staff meeting" meaning you-- with your
. - tJtmailve .
empAloyeUhes?buh (af:t:: . )

25 Pa ge 23
1 that -- I tlrink that I had two other students.
2
Q. Okay.
3 A. That carne.
4
Q. All right We'll get into that in a little
5 bit more detail later on.
6
A Okay.
7
Q. Before -- before -- it's my understanding that
8 Delgado Development Corporation does not have any
9 insmance coverage; is that correct?
10
A. Correct.
11
Q. Who is paying for your attorney?
12
A. My husband, ex-husband, did.
13
Q. Okay. Anybody else?
14
A. I don't know.
15
Q. So Mr. Hynes is representing you?
16
A. Yes.
17
Q: And he's representing Delgado Development
1 8
Corporations?
19
A. Yes.
20
Q. And Mr. Delgado is paying his fees?
21
A. He paid - what is the otber one. The other
22 attorney.
23
Q. What other attorney?
24
A. Miss ...
25
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page
Q.
A.
Q.
And your employees were monitors? --
Uh-huh (affirmative).
-- Who worked at the housing?
A. Yes, sir.
Q. And any other employees, other than monitors?
A. A driver.
Q. All right. Did you have any corporate minutes
for Delgado Development?
A. I did. We did. Like we would write weekly
things that came up.
Q. I've asked for those; where -- why haven't I
gotten them?
A. Because we -- when I was-- in 2007, I was at
a house on Abernathy, and there was boxes and boxes
that, when I moved, I didn't bring from the attic. And
the house got demolished.
Q. It got demolished?
A. Uh-huh (affirmative).
Q. What- what address was it?
A. 60 Abernathy.
Q. And when was that -- when did that happen?
A. When I moved to the new house, so it would
have been April of2007.
Q. Okay. So that would have been records up to
2007?

I

i


I
I
I
J

I

i

:
;



1

i

I
i
I
i

.,



Q. Eyre? Miss Eyre?
' " '
, ... .
• •
. .. ,, ;,"- . . . .... ... .. '
7 (Pages 22 to 25)
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Page 26 Page 28 ~
;,
--this-
~
1 A. Right. 1 Q. ~
2 Q. And then --but you had tvv·o more years of 2 A. -yeah.
I
3 opemtion? 3 Q. Tax ret1J111S; did Delgado Development
~
~
4
A. Uh-huh (affinnative).
4
Corporation file tax returns?
I
5 Q. What about those records, where are they? 5 A. Yes.
'1';
6 A. Everything that I have I have given out to 6 Q. Did Delgado Development Corporation have a
~
7
the -- to you guys.
7
business license?
i
8 Q. Well, that's-- well, I'm --let --let's back 8 A. I don't know.
§
~
~
9 up. Did you have -- did you have minutes of the 9 Q. Who would know?
~
~
10 corporation after 2007 when you say all the previous 10 A. Accountant
~
11
minutes were destroyed?
11
Q. All right. But you're the --you're the CEO
~
~
~
12 A. I don't know.
12
and the president of the company, and you don't know
~
13 Q. Did you have a checking account? 13 whether you had a business license?
~
~
14
A. Delgado Development did. 14
A. Yes. 1f
15 Q. I'm sorry, I should have been more precise. 15 Q .. "Yes," you don
1
t know whether you had a
M
~
16 Did Delgado Development Corporation have a checking 16 business license?
I
17
account?
17
A. Correct.
~
~
18
A. Yes, it did. 18
Q. Distributions to yourself; how did you make a
~
~
19 Q. Did Delgado Development Corporation have 19 decision when you were going to distlibit -- distribute
~
~
20 QuickBooks or accounting records? 20 profits to yourself :fi:om Delgado Development •
~
21 A. Yes, it did. 21 Corporation?
"
~
22
Q. Do you have those still?
22
A. I just had a paycheck.
~
i
j
23 A. I can check with tl1e accountant that was doing 23 Q. All light. What was your paycheck?
~
i
24 that 24 JVlR. HYNES: You mean the -the amount
~
25 Q. WelL have you done that up to now? 25 of her paycheck? Is that --
~ ~
~
•J
Page 27 Page 29 ~
~
1 A. I think I -- like I said, I mean, all the 1
BY :MR. HARRIS:
~
);
2 papers that I have I have provided to the questions that 2 Q. Did you understand my question?
~
§
3 were asked of me. 3
A The amount of the paycheck? ~
4
Q. Well-- 4
Q. Yeah.
I
5 A. If I didn't give them, then I don't have them. 5
A Yeah.

id
6 Q. Well, you- you have-- do you have checks, 6 MR. HYNES: Well, no, she's-- that
1
s i
7 canceled checks, from Delgado Development? 7 her--
i
8 A. I don't know. I have like three boxes, but 8
MR. HARRIS: Do you --
i
9 mostly it's the student files. 9 MR. HYNES: -- worldly--
10 Q. You have three boxes of what? 10 MR. HARRIS: --have an objection?
11 A. Of student files. For Delgado. 11 1v1R. HYNES: Yeah, I do. I
?
12 Q. All right. 12
MR. HARRIS: All right. Well, then just •
13 MS. WHITLOCK: I'm sorry, you said of 13 object, and don't-- don
1
t do speaking
t
14 what file? 14 objections, 'cause we've been around and
~
~

15 THE WITNESS: Student :files, - 15 around on those before.
~
~
16 MS. WHITLOCK: Student files, -- 16 1v1R. HYNES: Okay. I -- what I was
.
~
%
17 THE WITNESS: --like, you know, -- 17 asking you was to clarity, --
~
~
~
18 MS. WHITLOCK: -- okay. 18 MR. HARRIS: Well--
~
~
19 TIIE WITNESS: -- just the forms that 19
MR. HYNES: -- either how she got the
~
20 they fill out. 20 check or the amount. I don't care if you ask
(
21 BY :MR. HARRIS: 21 her how she got it, -- ~
,,
22 Q. How far do those go back? 22
1v1R. HARRIS: I'm not going to put up --
i
23 . A. 2007. 23 MR HYNES: -- but--
w
24 Q. So everything before 2007 was destroyed in -- 24 MR. HARRIS: -- with speaking
25 A. 2008, -- 25
objections. I'm just not. --
8 {Pages 26 to 29)
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Page 30 Page 32 •
1 l\1R. HYNES: I --
1 Q. And how much was the salary?
2 l\1R. HARRIS: -- If the witness doesn't
2 MR. HYNES: I'm going to instruct you
3 understand -- 3 not to answer, based on the fact that they're
t
4 MR. HYNES: But I -- but I'm not
4
not entitled to discover your worldly or
m
5 . objecting, rm trying to --
5 financial circumstances.
I
6 l\1R. HARRIS: Well, I don't know--
6 MR. HARRIS: Do you want to have a 6.4
I 7 MR. HYNES: -- have a conversation -- 7 about this right now? Do you have any
8 MR. HARRIS: -- what you're doing,
8 authority for it?
9 you're just talking.
9 MR. HYNES: Sure. In what circumstances
-
10 l\1R. HYNES: -- with you, J efi. 10 are you entitled -- I thought you didn't want
11 l\1R. HARRIS: I don't want to have a
11 to have the conversation, but I'm inclined


12 conversation; I want to talk to the witness.
12 to.
!,
a
13 MR. HYNES: Okay. All right. Well,
13 MR. HARRIS: No, I'm at a 6.4 now.
1

14 what I'm go:ing to instruct her is, she can
14
THE WITNESS: Wow.


15 answer any questions about how she was paid,
15 MR. HARRIS: Because I'm going to-- I


16 but the amount would be protected as a
1 6 mean, we're going to call the judge. I mean,

"
17 financial circumstance of hers --
17 the fact that she receives distributions from •
i
18 MR. HARRIS: Well, --
18 a c.orporation is clearly discoverable in the
i

19 MR. HYNES: --and that's not subject to 1 9 context of this case.

·'
20 discovery.
20 :ym_ HYNES: In-

21 MR. HARRIS: Well, I -- I disagree with
21 MR. HARRIS: It clearly is.
;

22 you, and if you're going to instruct her not 22 MR. HYNES: On-- on what basis? She is
23 to tell me how much she was distributed by
23 a -- she's not a party to this case; you're
I
24 Delgado Develop -- Development Corporation,
24 not entitled to conduct discovery about what
25 then -- and then -- go ahead and tell her to
25 financial assets or resources she has.
.
Page 31 Page 33
-
1 do that. I'm --that's the question I'm
1 BYMR. HARRIS:

2 going to ask, but let's get it on the record.
2 Q. Miss Delgado, I've asked you a question about
I
3 BY :MR. HARRIS:
3 how much you were going to --how much you received in


4 Q. First of all, Delgado Development Corporation,
4 distributions or in the fonn of a salary from Delgado
I
5 you were the president and the CEO of that company, were
5 Development Corporation; your attomey has instructed I
6 you not, ma'am?
6 you not to answer that question. Do you intend to abide !
7 A. Uh-huh (affirmative).
7 by your attorney's instructions?


8 Q. And the company raised money--
8 A. Yeah.


9 A. Uh-huh (affirmative).
9 Q. All r ight. The only compensation that you
M

10
Q-
--through its housing operations? 1 0 reform-- that you received from Delgado Development
ll
11 A. Uh-huh (affirmative).
11 Corporation was --


12
Q.
You were compensated by that company, were you
12 (Discussion off the record.)

I
13 not?
13 BY MR. HARRIS:
14 A. Uh-huh (affirmative). 14 Q. The only compensation that you received was --
15 Q. And you were provided compensation in the form 15 was the salary that your attomey has instructed you not
16 of a salary?
16 to tell me how much that was?

17 A. Uh-huh (afflrDlative). 17 A. Uh-huh (affirmative).
·'
18 Q. Were you- were you provided any other 18 Q. You did not have any distributions of any
19 compensation, in terms ofbonuses or stock dividends or
19 other kind?
20 distributions?
20 A No. I don't think so.
21 A. No.
21 Q. Are you okay?
22
Q.
So it was all in the form of a salary?
22 A. No. My heart is --
23 A. Right.
23
Q. Do you need to take a break?
24
Q.
How often did you receive the salary?
24 A. It -- it -- it has been like this. 1-- I
25 A. Weekly. 25 have - can't -- oh. It makes me nervous, you guys
• •
9 (Pages 30 to 33)
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Page 34 Page
36

1 arguing.
1
BY MR. HARRIS:


2
Q. All right. Any other corporate paperwork in
2
Q. And I'm not asldng for the substance of the
!i

:;
3 your possession? Do you have any articles of 3 conversations, but at any point in time did Delgado


4
incorporation. any amendments to the mticles of
4 Development Corporation retain an attorney to consult &

5 incorporation?
5
with related to obtaining licensing from the DBR or any
"

6
A. These things?
6
other governmental agency?

7
Q. That came from the secretary of state. I'm
7 A. No. We--no.
i
8 asking if you have any of that information.
8
Q. You were looking up, thinking of something,
9
A I - I think I do. I dorrt -- I'm not sure. 9 and ...
I
10
Q. Where would that be?
10 A No, no. No, we went to -- I went to a lot of

11 A. In the three boxes that I told you about.
11 meetings with the --with a- another company that does

i
12
Q. All right. Were- were the articles of
12
hoitsing, to learn about all the fue stuff and rules on
j
13
incorporation amended?
13
how to make it better.
14
A. No. I-- no.
14 Q. What -what company vvas that?
I
15
Q. They were not?
15 A. I know you were going to ...
I
16 A. Huh-uh (negative).
16
Q. Discovery Path?


17 Okay. Payments to your employees, in terms of
17
A. No. Oh, my goodness. No, it's-- it's not--
l
Q.
18 howmuc.h you paid the monitors and the supervisors and 18 it's like a company that has a lot of different houses,


19 the van drivers; do you have any records in that regard,
19
that they talk about the fire extinguishers in the
A
20 how much you paid those folks and when you paid them?
20
apartments, and, you know, how many beds you can have,

'
21 A I-- weekly, just like me. Everybody got paid 21 and all that stuff. But I don't remember the name.

22
at the same time.
22
Q. And I'm going to get into the details of what

23 Q. How did you detennine what your salary was
23
Delgado did and how they did it and all that sort of
24 going to be?
24
stuff in a little bit; but-- but in order to form the


25
A. By the hours that I was working there.
25
company did you obtain -- if you need to take a break,

1

Page 35 Page 37
§

1 Q. Did you keep a log of your hours?
1 I--


2 A No. But it was a set salazy.
2
A. It's-- it's all right. We m·e going to be

3 Q. But how did you deterrillne how you were going
3
like this. It has been like this. Ifs my heart.
4 to set it?
4
Q. Okay. I mean, I don't want to ...


5 A. Because I ·was there for a gazillion hours, so
5
A. I know. It's fme. I won't have a heart i

6 I decided from there.
6
attack here. I hope.
' 7 Q. And when you would make a distribution to
7
Q. If- did-- did you go anywhere and obtain

8 yourself, tell me how you would do that.
B
documentation, the fonns and the intake fonns and the
i
9 A. I didn't; the accountant did the QuickBooks,
9 assessment fonns and all that sort of stuff that Delgado

10 and then he did the payroll on the weekend. On Fridays.
1 0
Development uses, did you get those forms from anybody?
11 Q. And is that the same accountant who I believe
11
A. Yeah. Don. I
12 was the incorporator?
12
Q. From Don?


13
A. No, sir.
13 A. My husband. Yeah.
! 14 Q. Who was it-who was that?
14
Q. And where did Don get them?
15 A. James Wagner.
15
A. I don't know.
i

16 Q. Wagner?
16
Q. Before 2006 when you formed Delgado
!
iii
17
A. Uh-huh (affirmative).
17 Development Corporation, there was some company before


18 Q. Where is Mr. Wagner located?
18
that; do you know whether or not that company was

19 A. Sandy Springs.
19 involved in pmviding housing for people who were in

20 . Q. At any point in time did Delgado Development
20 rehab?
I
21 Corporation attempt to obtain any kind of license from
21
A. Before me?

22 the DHR relative to its housing?
22
Q. Yeah.

23 (Thereupon, :Ms. Franklin exited the
23 A. Yeah.

24 deposition room.)
24
Q. Is that what Don was doing?
r;


25 THE WI1NESS: No.
25
A. Yes.

.. ....,...,_. ., ..... ..... . ,.. .. <-·---· .... --.;;.... ....... ..,-.::..:...r.\·S .. E
10 (Pages 34 to 37)
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Page 38 Page 40
I
1
Q. Do you know where he was providing the
1 THE WTINESS: I'm sorry?
2 housing?
2 BY MR. HARRIS:

3 A. On Roswell Road.
3 Q. Was there any kind of agreement between
I
4
Q. And -- was that - do you know whether --
4 Narconon and Delgado Development Corporation to provide
5 A. Sovereign Apartments.
5 housing?
i
6
Q. - that was called Discovery Path?
6 A. No; I opened up Delgado Development.
7
A. Yes.
7 Q. Okay. Did you have any kind of agreement at


8
Q. So the company before Delgado Development you 8 all between then, between Narconon and Delgado
I
9 think may have been called Discovery Path?
9 Development, to provide housing for Narconon?

10
A. Yes.
10 MR. HYNES: Object to the form.
I
11
Q. It was operated by Don? 11 1HE WITNESS: No. As in, I opened up a

12 A. I don't know -- I -- I remember seeing some
12 different company.

13 paperwork Discovery Path, but I know that Don called it
13 BY MR. HARRIS:
I
1 4 Delgado Development. I don't think it was Discovery
14 Q. All right. And let's talk about that What

I
15 Path. I know that the company before Don was Discovery
15 caused you to open up that company?

16
Path.
16 A. When I divorced, I took over the company that

17 Q. Was -- well, in-- but --do you believe that
17 my ex-husband was running.

((
18
Q. Did you bave any conversations with anyone at
.,
18 Don had an ownership interest in Discovery Path? ,,
19
A. I don't lmow. fm sorry.
19 Narconon about the fact that you were going to be
l


20
Q. Do you know whether or not you put that on
20 opening up this company?

21 your - your joint bankruptcy petition? Discovery Path?
21 A. I had a conversation with my bus band that I
1
I
22
A. No. That was a personal bankruptcy.
22 wanted the company.
.

23
Q. Did you have any interest in Discovery Path at
23 Q. And at the time your husband was employed as
'
24 all?
24 the senior director for expansion at Narconon?

25 A. (Witness shakes head negatively.)
25 A. No. ll

Page 39 Page
41 1
1 Q. All right. Documentation -- 1 Q. What was he employed as then?
I
2 (Discussion offtbe record.) 2 A. He wasn't at the time of the divorce, no.

3 MR. HARRIS: I'm sorry. 3 Q. He wasn't employed by Narconon at that time?


4 1HE WI'INESS: No. 4 A. I don't think so.
I
5 BY JYIR. HARRIS: 5 Q. All right. Where was he employed?
6 Q. You have to answer that out loud or she can't 6 A. I think. I don't - I don't know. I don't
I
7 write it down. 7 remember if he was or not at that time. We both worked

8 A. Sorry. B at Narconon at some point.


9 No, sony. 9 Q. I believe I -- I just V.'Rnt to be clear, and I
1 0 Q. Okay. 1 0 don't remember what your answer was. Did-- did Delgado

1
11 A. I didn't. 1 1 Development Corporation file corporate income tax

12 (Thereupon, Ms. Franklin entered the 12 returns?

.
13 deposition room.) 13 A. Yes. J.

14 BY MR. HARRIS:
14
Q. Both state and federal?

15 Q. I have asked for any documentation between 15 A. Yes.
I
16 Delgado Development Corporation or any -- strike that. 1 6 Q. All right. Tell me about what yon did at
17 rve asked for any contracts between Delgado 17 Delgado Development Corporation. What was your job,


1 8 Development Corporation and Narconon, and have been told 18 what did you do every day?

I
19 that there aren't any. 1 9 A. I made sure that the students got to the

2 0 A. Huh-uh (negative). 20 apartments, and 1hen that they had food, that they
I
21 Q. Do you have -- was there any kind of agreement 21 cleaned up their room, that they were not using drugs or

22 between Narconon and Delgado to provide housing of any 22 alcohol. Pretty much that. And then take them grocery
1j

23 kind? 23 shopping.
*
" 24 MR. HYNES: Can you claruy, "Mitten 24
Q. And -- and did you-- when yon took them
'
25 or ... 25 grocery shopping, did you use a van?

• • • • • • • ..
11 (Pages 38 to 41)
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Page 42 Page 44
I
1
A. Uh-huh (affirmative). 1 A. Uh-huh (affinnative). §
2
Q. Who owned the van?
2
Q. You did not receive any kind of stock dividend


3 A. Narconon. 3 or--
I
4 Q. And the driver of the van, who employed the 4 A. No.
I
5
driver of the van? 5 Q. -any kind of bonus?

6
A. We both did. 6 A. I don't think so.
I
i!
7
Q. Who was that? I mean, give me -- I think 7 Q. All right.

i
8 you've identified a couple of different drivers, and I 8 A. I think it was just a salary.
I
9 want to sort of pin down which ones were working when. 9 Q. And - and what was the amount of that salary?
10
A. Johnny- Johnny -- Johnny ... Johnny. 10 A. 800.

11
Q. Okay. Any -- we can go through your discovery 11
Q. 800what?

.,
12 responses in just a second; how many drivers, during the 12
A. Dollars.
!.


13 time period betv.reen 2006 and 2009, did you employ? 13
Q. How often?
I H A. Two, I think. Johnny and Patchy. 14 A. Weekly.
15
Q. What about Charles Tucker, was he a driver? 15 Q. Okay. Now, the·-- the -- the apartments that
I
16 A No.
16 Delgado Development Corporation leased at Sovereign
I
17
Q. Just two?
17 Place; do you know how many apartments Delgado
18 A Uh-huh (affirmative). 18 Development Corporation leased?
i
19
Q. Now, you say you both employed them, meaning 19 A. 12.
I
20 both you and-- both Delgado Development and 20 Q. And what were those apartments used fo'r?
21
Narconon; -- 21 A. Housing.
22 A. (Witness nods head affirmatively.) 22 Q. Housi11g for who?
I
23
Q. - how did you work that out, how did you 23 A. For students. •

24
determine who was paid --
24 Q. Did Delgado Development Corporation actually
I
25
A Their how-s. 25 sign the lease for the apartments?
l

N
Page 43
Page
1
Q. So -· explain that to me. 1 A. Yes.
I
2
A. He worked at nights with me. And he would 2
Q. Okay. In the discovery questions that we sent

3 take people to grocery shopping, or whatever they 3 over in this case, in interrogatories Nos. 1 and 2 we
I
4 needed. We took them to Walmart sometimes to get stuff 4 asked you to identify the apartments that Delgado
I
5 Toothpaste, deodorants. Can I - can we- 5 Development leased or that you or Don leased, and you

6
Q. Take a break? 6 gave me a list of those apartments.
I 7 A Yes, please. 7 MR. HARRIS: And I don't need to mark
1J
8 Q. Sure. 8 that.

"'
9 A. I've got to use the rest room. 9 MR. HYNES: Okay. r11 just show it to

1 0 MR. HYNES: Yeah, sure. 10 her.
"
11 THE VIDEOGRAPHER: Going off the video 1 1 MR. HARRIS: Yeah, that's fme.

12 record at 10:35. 1 2 BY MR. HARRIS:
I
1 3 (Recess at 10:35, resumed at 11:03.) 1 3
Q. I just -- I'm confused; it says 2-1, does
;.3

14 TIIE VIDEOGRAPHER: Stand by. We're back 14 that -- did you all mean Z?
3
!i
1 5 on the video record at 11:03. 15 A. Yeah. I
16 BY :MR. HARRIS: 16 Q. That's just a typo?
i
1 7
Q. All right, Ms. Delgado, we took a little 17 A. Zl, Z2, Z3, yeah.

.
18 break. And I had asked you a question earlier in your 18 Q. Got you. That's what I thought you meant.
I
1 9 deposition about distributions to you from Delgado 19 So-- so-- so basically it's -- it's Zl , Z2, Z3, Z5,
i
20 Development Corporation. And you told me that the only 20
Z6,Z7 --
21 distributions that you received from Delgado Development 21 A. No, no. 06. That was an 0.
i
22 Corporation--and by "distributions" Imeanmoneythat 22 Q. An 0, okay. --
23 Delgado paid you-- 23 A. 07--

2 4 A. Uh-huh (affirmative). 24 Q. -- Thank you.
25 Q. -- was in the form of a salary? 25 A. -- andB3.
• •. .. .,..-.,.., .-. • • • • -} 9:'
.. ., ....
12 (Pages 42 to 45)
http://ReachingForTheTippingPoint.net
Page 46
1 Q. Okay. So it's Z -- 1
2 A. AndZ6. 2
3 Q. -- Zl, -2, -3, -5, and then 06 and -7, and 3
4 then B3, and then Z6? 4
5 A. Yes, sir. 5
6 · Q. Is that what that meant? 6
7 A. Yes, sir. 7
8 Q. Okay. And this was in the time period between B
9 2007 and 2008? 9
10 A. Uh-huh(affmnative). 10
11 Q. Before 2007, back-- going back to the 2006 11
12 time frame, did you lease these same apartments? 12
13 A Not-- not me. No. 13
14 Q. rm sorry, Delgado Development? 14
15 A. No. No. 15
16 Q. You leased different apruiments? 16
17 A. Yes. 17
18 Q. All right. I'm going to show you whatl'm 18
1 9 going to mark as Plaintiffs' Exhibit 3. 19
2 0 (Thereupon, marked for identification 2 0
21 purposes, Plaintiffs' Exhibit No.3.) 21
2 2 MR HYNES: Okay. 2 2
2 3 BY MR. HARRIS: 2 3
2 4 Q. Now, these are copies of some of the checks 2 4
2 5 that were paid to Sovereign Place. If you tum to 2 5
Page 47
Page 48
page from Delgado Development, Inc. to One Sovereign
Place; tum - do you see that one? i
i
A Uh-huh (affirmative).
Q. All right And it lists the apartments as B3,
07, V9, W6, and then the Z apartments that we discussed
earlier.
A. Uh-huh (affirmative).
Q. You didn't -- you didn't indicate in your
discovery responses this V apartment and this W I
apartment. Why not?
A I didn't remember, I guess.
Q. So in fact-- but -- but Delgado was in fact
leasing two other aprutments you just forgot about on 1
your discovery response? Is that correct?
J
A. Yes.
(Discussion off the record.)
(Thereupon, marked for identification !
purposes, Plamtifrs' Exhibit No. 4.)
BYMR. HARRIS:
Q. All right I'm going to show you what's been
marked as Plaintiffs' Exhibit 4, and this is a lease for
apartment Z2, is it not?
A. Yes.
Q. Now, the person who's -or, it says here that
you, Maria Delgado, are leasing -- is ]easing the
Page 49
J

1

!
il

1 the -- well, the frrst check here on Exhibit 1 -- or, 1 apartment, and not Delgado Development Corporation.
2
3
4
5
6
7
B
9
10
11
12
13
1 4
1 5
1 6
17
excuse me, the -- the third check down on the first page
and the fourth check down on the first page both show
payments that were made by you --
A. TI1at's not me.
Q. Okay. It's not you?
A. No.
Q. Who --who is- who is Maria Elena Delgado
Morales?
A. My name is Maria Eugenia.
Q. Okay. That-- that's not you?
A. No.
Q. All right. The sec -- this check down here on
the bottom is not -- is not you as well?
A. No.
2 A. Okay.
3 Q. You didn't sign it on behalf of Delgado
4 Development Corporation?
s A. I -- I sigried it in behalf of Delgado
6 Development.
Q. AU right. Show me in the lease where you
8 signed it on behalf of Delgado Development Corp -- where
i
9 it says that you're doing that for Delgado Development.
1 0 MR. HYNES: Take your time to look
11 through it.
12 THE WITNESS: I guess this made me, you
13 know, the president of Delgado
14 Development, --
15 BYMR. HARRIS:

7
is very --I know that you know, but, you know,
18 common. 1 B that was the thing. J
19 Q. All right. 19 Q. Okay. But I'm just asking you, nowhere in the
2 0 MR. HYNES: Could I ask you to spell · 2 0 lease that you signed for this apartment did you

21
22
23
your middle name too, 'cause I - 21 indicate that you were doing it on behalf of Delgado
THE WI'INESS: E-U-G-E-N-1-A. 22 DevelopmentCorporation,right?
MR. HYNES: Okay. 23 A. Right.
2 4 BY MR. HARRIS: 2 4 Q. Now, this lease contains a section that says
2 5 Q. The -- the ch -- there's a check on the second 2 5 that the premises are not to be used for commercial J
• ..... .. ...
13 (Pages 46 to 49)
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Page 50 Page 52 l!
1 purposes, which is section 14 of the lease. Do you see 1 A. No.
I

2
that?
2 Q. And, again, you don't know what Discovery Path

3 A. Uh-huh (affirmative).
3
is?

4 Q. rn fact, you were using them for commercial
4
A. I know that it's my -- I -- I think it was


5 purposes, tight? You were making money from these 5 my-- before my- my ex-husband's company.
I
6 apartments?
6 (Thereupon, marked for identification

7
A. Yes.
7
purposes, Plaintiffs' Exhibit No. 6.)
§

8
Q. So you ignored that provision of the lease? 8 BY MR. HARRIS:


9 A. They knew that.
9
Q. Under Plaintiffs' Exhibit 6, which is

jj
10
Q. Okay. Do you have any documentation that they
10
apartment Z3, this one you rented again in your name,
;a

11 knew that?
11 Maria Delgado, and not in the name of Delgado

12
A. No,--
12 Development Corporation; is that correct, ma'am?

m
13 Q. Did they--
13 A. Uh-huh (affll1lliltive). [!
14 A. --I don't.
14 Q. So once again you- there's nothing that


15
Q. Did they specifically give you any 15 indicates that Delgado Development Corporation was

16 authorization to do that? In --
16 renting that apartment?
i
17 A. When I --
17
A. Okay.

i
18
Q. --writing?
18 Q. Is that correct?
I
19 A. --talked -- when I talked to the lady, yes.
19
A. Yes.
20 Who was the lady? .
20 l'v1S. WHI1LOCK: I'm sony, which one?

Q.
i
21 A. Her name was... She was the office manager
21 Which apartment was that?

22 for the apartments; I don't remember her name.
22
THE WITNESS: Z3.
'


23
Q. Zl, the lease for apartment Zl --
23 MR. TANNER: Z3.
I 24 A. Allison.
24
(Thereupon, marked for identification
25 Q. I'm sorry, did I interrupt-
25
purposes, Plaintiffs' Exhibit No.7.)
I
Page 51 Page 53

1 A. Allison. 1 BY :MR. HARRIS:
2 (Thereupon, marked for identification 2 Q. Plaintiffs' Exhibit 7 is the lease for !
3 purposes, Plaintiffs' Rxhibit No. 5.) 3 apartment Z4. Once again you were rent --you rented I
4 BY :MR. HARRlS: 4 that apartment in your name, Maria Delgado?
5 Q. Allison? Okay. .5 A Uh-huh (affirmative). · I
6 Zl is the lease reflected I believe on 6 Q. And you did not rent it -- or, there's nothing i

7 Plaintiffs' Exhibit 5. And in this case you -- you 7 on the lease that indicates that you're renting it on
8 indicated that the lease was being made, or the lease 8 behalf of Delgado Development Corporation, correct?
9 itself indicates it's being made, to some company called 9 A I rented it as the president of Delgado i
1 0 Discovety Path and Maria Delgado? l 0 Development, yes.
11 A. Uh-huh (affumative). 11 Q. Okay. But you didn't put that anywhere on the
1 2 Q. Again,nowhereinthisleaseforapartmentZl 12 lease?
13 did you indicate that Delgado Development Corporation 13 A. No.
1 4 was leasing this apartment, did you? 14 (Thereupon, marked for identification

15 A. Right 15 purposes, Plaintiffs' Exhibit No.8.)
16 Q. Youdidn't,right? 16 BYMR.HARRIS:
17 A. Right. 17 Q. ZS, which is Plaintiffs' Exhibit 8; once
18 Q. Instead you said something called Discovery 18 again, in this lease you rented it Maria Delgado and
19 Path? 19 Discovery Path, correct? '
20 A. Idicln't;shejustputitthere. 2 0 A. Uh-huh(affirmative).
21 Q. All right. She-- 21 Q. Nowhere in the lease do you indicate that i
2 2 A. I did sign the paper, but, no. 2 2 you're renting that on behalf of Delgado Development
2 3 Q. So you 1hink she just put that in there? 2 3 Corporation?
2 4 A. Uh-huh (affmnative). 2 4 A. Right. Again, I did it as the president of 1
2.5 Q. Do you know why? 2 5 Delgado Development.
.....,__ • .. • • • •
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Page 54 Page

here,--
l
1 (TI1ereupon, marked for identification 1


2 purposes, Plaintiffs' Exhibit No. 9 .) 2 A. Okay.

;:

3 BY 1\tlR. HARRIS:
3 Q. -- B3; was Delgado Development Corporation,

Exhibit 9, which is for apru.tment Z6; !"don't 4 was ·it renting B3 in June?
.
4 Q.
5 think we've done that one yet. Again, that's on-- 5 A. I-- I don't know. I mean, it has a check

6 that's rented by Maria Delgado, and not by Delgado 6 here, so obviously we were.
I

7 Development Corporation, right?
7 Q. Okay.

8 A. Yes. As the president of Delgado Development. 8 A. In June -- in Ju -- in May, but I don't
i
9 (Thereupon, marked for identification 9 know - I don't know why is that.

I
10 purposes, Plaintiffs' Exhibit No. 10.) 10 Q. Do you -- do you know -- I mean, can you just

11 BYl\tlR. HARRIS:
11 tell me one way or the other whether you remember

12 Q. I'm going to hand you what I've marked as 12 whether you were doing it in June or not, whether you

13 Plaintiffs' Exhibit 10, --
13 were renting that apartment?

14 A. Uh-huh (affirmative).
14 A. I don't remember. I'm sorry. I don't even
I
15
Q. -- which is the list of people who were
1 5 know where that is. I don't -- I can't picture.


?i
16 renting the apartments provided to us by Sovereign
16 Q. All right. C 1 is listed as Nmma Delgado; is
17 Place. We've already talked about the Z apartments. 1 7 that a person affiliated with you in any way? Do you



18 A. Uh-huh (affinnative). 18 know who that is?



If you look at apartment B3 on the rent roll,
19
A. Huh-uh (negative).

-19 Q.

20 it's listed as vacant? 20 Q. And then C3, we've got that listed as Maria 1
li
21
A. Uh-huh (affinnative). 21 Delgado; that's not you?

I
22 Q. But yet you're paying for it, it looks like,
22 A. Which one?
23 in your check of May. Do you know who lived in B3?
23
Q. C3. •
24 MR. HYNES: Can-- let me -- I can 24 A. I think so. I think it's me, yes.
I
25 either object to the form or ask you to 25 Q. All right. So you were renting C3 as well?
Page 55 Page 57

1 clarify; it says the date of the rent roll, 1
A. Uh-huh (affirmative).
i
;
2
is that the date - 2 Q. Under your oVvn name?

3 MR. HARRIS: It's-- it's-- 3 A. In the name ofDelgado Development, yes. I

\5
4 MR. HYNES: Just a reference? 4 mean, in my name, but... I
i
5
MR. HARRIS: -- as of June, yeah. 5 Q. Who was -- were you living there, in C3? •

6 MR. HYNES: Okay. 6 A. Huh-uh (negative).

'I
1
7 MR. HARRIS: I'm asking her- 7 Q. Who was living there?
.
8 THE \VITNESS: June 15th. 8 A. I don'tlmow. ·3
9 BY MR. HARRIS: 9 Q. Was that one of the apartments you were using

i
10 Q. Yeah; this is the rent roll as of June 15th, 10 to house students?
I
11 okay? 11 A. Yes.
I
12
A. Uh-huh (affirmative). 12 Q. On this first page, if you would, just take a
13 Q. And -- and in your - in this check that you 13 look at these -- these names here; do you know any of


14 sent to Delgado Development, you -- you list B3 as being 14 these peopie on the first page? Besides yourself, C3.

15 one of your apartments. I'm just trying to confirm 15 A No.


that. I mean, it's listed as being vacant in June, but 16 Q. You don't know any of those folks?

16

.

17 you paid for it; dq you know who was living there? 17
A. No. I mean, I know me. But that's not me

m
18 A. In May I paid for it. 18 either. You mean C3 as in Charlie?

19
Q. Okay. In May? Well, you actually also -- 19 Q. That's -- that's what I'm asking.
!I
20 there's another check whtlre you're paying in-- which 20
A. Son-y. I'm sorry, I thought it was Z.

21 we'll get to in just a second, and I don't know whiu 21 Q. I'm sorry. C3 on the first page, that says

22 this is for. In July, on the next page, it just says 22 Maria Delgado --
I
23 "One Sovereign Place, $1500"; what is that for? 23 A. That's not me.
24 A. I don't remember.
24
Q. It's not you?
25 Q. All right. But just going back to -- to June 25 A. That'snotme. No.
d?:ii·'' • • •
15 (Pages 54 to 57)
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Page 5 8 Page 60
'
.
1
Q. Okay. Anybody else, then? I mean, anybody on
1
Q. If this is--
I
2 that page you know?
2
A. - we moved from apartment to apartment
I
3 A. No. 3 sometimes. Like we - we move --
i 4
Q. Same question with respect to the second page; 4 (Thereupon, Ms. Franklin exited the
5 do you know any of those people?
5
deposition room.) I
6 Well, let me -- let me back up. On the first 6 THE WITNESS: --to -- I wanted to get
I
7 page? 7 them closer together, so that it was easier



8
A. Uh-huh (affirmative).
8
to supervise. So sometimes we would move

9
Q. Were any ofthe apartments on the ftrst page 9 from 06 to C3. Close 06.

10 here, other than the B3 one that -- that we've talke.d 10 BY MR. HARRIS:
I

11 about, were any of those being rented in the May, June 11
Q. Do you have any documentation from which we
I
12 time frame by yourself, Mr. Delgado, or anyone on behalf
12
could detennine what apartments that you were renting at
I
13 of Delgado Development Corporation? 13 Delgado Development Corporation in the 2007 and 2008
I
1 4
A. I'm sorry, tell me again. 14 time frame? Is there any -- how would we know that?

15
Q. These apartments on this first page, okay? 15 A. Did I not give the contracts for the -- from
I
16
A. Uh-huh (affirmative).
16 the apartments?


17 Q. Any of these apartments in the May, J1.me time
17
Q. No, maam.

i
1 8 frame of2008, were any of these apartments being rented 18 A. Oh.


19 by anyone on behalf of yourself, --
19
Q. Sovereign Place did. You- you-- I think

j
20 A. Huh-uh (negative).
20
your response is you didn't have any of that. Do you

21 Q. - ·Mr. Delgado, or Delgado Development? 21 have that?

:si
22
A No, sir. 22 A. I don't know; I got to check on the three


23
Q. All right. Same question with respect to the 23
boxes that I have, but -

24 next page; any of the apartments on the second page here
24
Q. Where -- where is -
25 of the rent roll on Exhibit -- whatever it is. 25 A. -- ifl were to have it, then I would have
Page 59 Page 61
1
A. 10.
'
1 given it to you.


2
Q. 10, thanks. Were any of those being rented by 2
Q. Where are the three box -- the three boxes at?


3 Delgado Development Corporation or on behalf of Delgado 3 Have you given those to your attorney? i
4 Development Corporation? 4 A. No; the -- I have at my house. I have them at
i
5 A. No. 5 my house.
6
Q. Cl, the Nonna Delgado, you don't- you don't 6 Q, Have you given- diq you give those to
i
7
know her? 7 Mr. Hynes or Ms. Eyre?

B A. Huh-uh (negative). 8 A. Eyre.
l
..
'l
9
Q. K3, Jose Delgado? 9 Q. You gave her the three boxes of materials?

i
10
A No, sir. 10 A. No, no, I just gave the questiorts --I mean.


11
Q. Don't know him? What about H5, do you know 11 the answers.



12 that person? 12 Q. Did you -- but the -- the three boxes of


1 3
A No. 13 materials that you have at your house, did you provide

"
14
Q. Okay. Let's go to the neJ\.1: page. 14 those to Ms. Eyre or to Mr. Hynes?

15 A. Oh. 15 A. No.
I

1 6 (Discussion off the record.) 16 Q. All right. Wlll you do that for me?

17
BY MR. HARRIS: 17 A. Sure.
I
18
Q. You indicate in your discovery responses that 18 Q. 07 -- excuse me, 06. It's listed --listed on
!
19 you're renting apartment 06, do you not? 19 this rental roll as - as being someone named Issac
;
20
A. I don't know what the question was. If it 2 0 Castillo. Do you know who that is?
21 said like, okay, during this period of time? You know 21 A. No, sir.
22 whatrm-- 22
Q. But you're paying for that apartment,
23
Q. Right Well, rm --I'm just- that's what 23 according to your discovery responses, at some point in
24 Ym trying to figure out. Okay? 24 2006,2007?
25 A. Right. Because like -- · 25 .A. Like I said, if-- if it was that we moved,

... , .. ,
.. •

16 (Pages 58 to 61)
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Page 62 Page
64

1 you lmow, I don't know the time frames that each
1
Q. Who else lived there with Mr. Tucker?


2 apartment were, but we would close apartments and move
2
A. I don't remember his names. The names of the
m

3
to -- closer. Like we got the Z building.
3
people that were -- that lived with him.
i
4
Q. 07? Apartment 07?
4
Q. Go down to W2 on that same page. Another '•

5
A Yes.
5
Delgado. Any relation to you at all?
!<
i
6
Q. Ifs listed as vacant. The check, at least
6
A. No. So that you know, we can go over it
7
for May, indicates that you paid for it. And, by the
7
but the only Delgado I know is my husband and my kids.

8 way, there is no June check. There's a May check, and
8
Q. Okay. I understand; I've just got to ask. --


9
there's a July check.
9
A Okay.


' .:!:
10 A Okay.
10
Q. -- Justto -- just to clear it up. So you
;
11 Q. So did you pay rent in June to Sovereign
11
don't know the guy in W2, you have no idea who that is?
I
12 Place?
12
A. No.
13
A I would guess so; I mean, they would kick us
13 Q. W6; once again it's listed as being rented by
I
1 4
out.
14
Discovery Path. Was that one that you were -- that
I
15 Q. Well, it looks to me like maybe this -- this
15
someone affiliated with Delgado Development was renting?
"
16 May check was -- was doubled up?
16
A Okay.
17
A. Okay.
17
Q. I'm asking you.
18
Q. Is that right?
1 8
(Thereupon, Ms. Franklin entered the

1 9 A. I don't know, sir. Probably.
1 9
deposition room.) I
20
Q. So 07, you don't lmow whether or not Delgado
20
THE WITNESS: I-- I guess, yes. I


21
Development was renting
21 don't remember the W6, but could be.

22 A. We--
22
BY MR. HARRIS:

23 Q. -- apartment unit?
23
Q. Ail right. And then let's go to the Z

24 A. -- rented it at one point, but then we moved.
24
apartments.
I
25 Q. Okay. 82.
25
A. Okay.
!



Page 63 Page
65 f

1
A. No. Never. 1
Q. Zl through Z6 is listed all -
I
2
Q. Never? 2
A. What page?
3 A. No. 3 Q. I'm sorry, on Page 5, that last page there.
'
4
Q. Go down to the next page; V9? 4 A. Oh. Right.

5 MR HYNES: Will you tell her the page 5
Q. Zl through Z6; now, those are all listed as


6
number in the top right comer, so we can- 6 Discovery Path.
j
7
BY MR. HARRIS: 7
A Oh.
!
8
Q. Page4. 8 MR. HYNES: You might want to --
9 MR. HYNES: See that up there? 9
THE WITNESS: (Indecipherable.)
I
10 Tiffi WITNESS: Yes. 10
MR. HYNES: No, clo -- let's close it,
11 :MR. HYNES: Okay. 11
and then -- 'cause the staple's at the
12 BY MR. HARRIS: 12
bottom, so... That last page. There you go.
13
Q. Now, you were-- you were renting V9, were you 13
THE WITNESS: Oh.
14 not? 14
MR. HYNES: See in this part, see the
15 A. I was. 15
top comer there.
-
16
Q. And in fact Charles - it was listed as being 1 6
THE WTINESS: Yes.
I
17 leased by Charles Tucker. 17
BYMR. HARRIS:
18 A. Okay. 18
Q. Do you have any leases at all, that you're

19 Q. Is that right? 19
aware of as you sit here right now, where any of the
;r,
1!
20
A. TI1at' s right. 20 apartments that were being rented over at Sovereign


21 Q. All right So why were you paying for Charles 21
Place, where the lease says that the apartment is being
l
22 Tucker's apartment? 22
rented by Delgado Development Corporation?

5
23
A. For the staff. 2 3 A. As in says Discovery? No.


24
Q. Okay. 24
Q. rm sony, what was your clarification?
l,l
25 A. To live there. 25
A. Like -like it says Discovery Path, like
• ......... .. •
17 (Pages 62 t o 65)
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Page 66 Page 68

1 Delgado Development, no.
1 A Right.

2
Q. Right. And that's exactly what I'm asking.
2 Q. - Patrick Delgado's check, right?


3 We've gone through some leases here, and I don't-- and 3 A Patrick Desmond, right.
,.
4 when I -- I don't want to go through a btmch of them 4 Q. rm --I'm sorry, --

5 with you, but-- but are you aware of any of them where
5 A. That's fine.
3
6 it says that the apartment was actually being leased by 6 Q. -Patrick Desmond- Patrick Desmond's check?
.
7 Delgado Development Corporation?
7
A. Right.
t
8
A. Like I said, yes, me as the president. 8 Q. So you've got other financial information -
i
9 Q. That's not my question.
9 A. Employees.

10 A. Okay.
10 Q. --about--

11 Q. Are you aware of any leases for any of the 11 A. Yes, sir.
I
12 Sovereign Place apartments where the lease is actually
12 Q. 'Nhat else is in -- what else is in these

13 made in the name specifically of Delgado Development
13
boxes, that you can remember? Tell me everything that
i
14 Corp --
1 4
you think might be in these boxes.

15 A. No.
15 A The Georgia Power bills, the Georgia gas
'
16
Q. -- oration? "No"?
1 6 bills, the IRS papers, I think. The students. Staff, l
i
17 A. No.
17
maybe, staff folders.

18 (Thereupon, marked for identification :.a Q. What's --, "stuff' being?
I
19
purposes, Plaintiffs' Exhibit No. 11.)
19 A. S-T-A-F-F.
20 BY :MR. HARRIS:
20 Q. Okay. Give me a little bit of clarity on
j
21 Q. One of the things that we asked for in 21 "stuff." I mean, what does that mean? What- what-
l
22 discovery was checks that had been made out to 22 MR. HYNES: It's "staff."

1
23 :Mr. Desmond, or any evidence of compensation to
23 MS. FRANKLIN: It's "staff."
I
24
Mr. Desmond. Let me show you what's Plaintiffs'
24
MR. TANNER: "Staff."

25 Exhibit 11.
25 MS. WHITLOCK: "Staff."

Page 67 Page 69 I

1 A. Okay. 1 BY MR. HARRIS:

I
2
Q. What is that? 2 Q. Oh, I'm sorry, I apologize. I thought you
3 A. A payroll check. 3 just meant stuff. Okay. Staff folders, like fol -- •

4 Q. But is it from a QuickBooks printout? 4 personnel folders, maybe, for each --
'!

5
A. Uh-huh (affirmative). 5
A. Yes.
I
6
Q. Where did you get it? 6 Q. -- person who worked there?
!
7
A. From James Wagner. 7 What else?

8 Q. Okay. So you-- you asked Mr. Wagner to give 8 A. I think that's it. I-- I don't- I think.
I.
9 you the journal printout from Mr.- 9
Q. And some financial stuff, like what we talked
l

10
A. Oh-- 10 about?


- for-- for Mr. Delgado?
13
11 Q. 11
A. Right.


12 · A. Where did I get it to give it -- no. These 12 Q. All right. 1l1e apartments that you were

13 ones I had in the boxes. 13 leasing, as a -- as a -- as a general matter, you would


14
Q. Okay. The bo -- the three boxes that 14 put four students in each of those apartments; is that


15 you've-- 15 correct?

1 6 A. Uh-huh (affirmative). 16 A Sometimes.
17
Q. -- got at your house? 17 Q. Well, I mean, was that your intent, if you had
<
18 A. Yes. 18 enough -

19
Q. Do -- does - does the - do the three boxes 19 A Right.
20'
at your house have other QuickBooks or journal entries 20 Q. - students, would you put four in there?
'
1
22.
.in terms of the monies that were being spent by Delgado 2 1 A Yes, sir.
g
l
22 Development Corporation? 22 Q. Just sometin1es you might not have enough to
23
A. Probably, yes. 23 fill them up?


24
Q. Well, I mean, the -the only QuickBooks in 2 4 A Right
;
25 your box is not just -- 25 Q. Right?


' ,..,, . .,.. .. 6 •... • .. .,. ,;;f,:'
18 (Pa ges 66 to 69)
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Page 70 Page
A. Uh-huh (affirmative). 1 Q. --of that per apartment, right?
· Q. And you would charge those students $1700 2 A. Yeah.
apiece? 3 Q. Who was responsible for paying for the vvater
A. I think it was 15- each person. I think. 4 bill at the apartment? At ea -- at --
Q. · Okay. Well, I-- I've got some documentation 5 A. Delgado Development
that says 17-, and I guess that's one of the questions I 6 Q. Okay. Gas?
was going to ask you; did it -- did it go up at some 7 A. Same thing.
point? 8 Q. Now, you said food; tell me how that worked.
A. I don't think so, but if you have a 9 How did the students pay for food?
documentation, probably. 10 A. They got I think it was - I don't remember
Q. Well, at the time that Mr. Desmond checked in, 11 how much it was per student, but they will go to Kroger
the paperwork that I've got says 1700. 12 and they will get certain amount of money.
A. Okay. Which-- which apart-- which time? 13 Q. Did you tell the people at Sovereign Place
Q. Well, this was signed in November of '07. 14 that you were going to be re-letting the apartments for
A. Okay. 15 $1700 apiece?
Q. So 1700 bucks, you think that was about the 16 A. They knew. They -they knew.
rent you were charging the students? 17 Q. So you told this Allison lady --
A. If it says that, then that what it was. That 18 A. Yes. i
is what it was. 19 Q. - that you were going to be running a 1
Q. Okay. Did it go up? 2 0 commercial operation? ~
~
A. No. 21 A. I told them that I was going to help the j
Q Stayed -- stayed 1700 the whole time you 2 2 people that- yeah. That I wanted to -- to get people ~
had - ~ . 2 3 in there to help them with the drug addiction. i
A. I thought it was 1500, but-- 2 4 Q. Okay. But did you tell her that -- that ~
Q. All right. I mean, it is w·hat it is, right? 2 5 Delgado Development Corporation, and you on its behal.f; ~
r-----------------------------------------;------------------------------------------4!
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Page 71 Page 73 I
A. Right.
Q. And the apartments themselves, it looked like
they ranged anywhere from about 850 to $950 per unit; is
that correct?
A. Yes.
Q. And so basicaJ.lyyou were netting, on each of
these proper - you- you were netting. once you
received the money from the students, about anywhere
from 5500 to S6,000 per unit?
A. Well,--
:MR. HYNES: Object to the form. You can
ans\:Verit.
TilE WITNESS: No; because then the
electricity and the food and the going --
the- the s ~ S-T-A-F-F.
BY MR. HARRIS:
Q. Yes.
A. That I have to pay. So, yeah.
Q. But--
A. The taxes and stuff like that.
Q. I understand your clarification, and I
appreciate that. So the gross for each apartment was
about- v,ras between 5500 and 6,000, but then you had
expenses that you took out -
A. Right.
1
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8
9
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25
would be running a business from these apartments?
A. Uh-huh (a:ffumative). They knew that.
Q. Okay, I'm asking you -I'm asking you a
different question. Did you specifically tell them
that?
A. Yes, sir.
Q. And that - and you told Allison?
A. Yes.
Q. And same question with respect to the amount
that you were going to charge these folks who were
there; did you tell the apartment complex, "I'm going
to-- I'm going to re-let or re-rent these apartments to
individual students for $1700 apiece"?
A. I-- I can't remember that. I don't remember
that.
Q. Did you get --
A. I don't know whether I would go as specific
like that, but... I don't know.
Q. Did you get any authorization from the
apmiment complex to subl et the apartments back out to
other folks?
A. Yes. In a sense. Talking to Allison.
Q. Okay. So Allison would be the one who gave
you that authorization?
A. I would -- yes.
~
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1 9 (Pages 70 to 73)
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Page 74 Page 76

1 Anything in writing?
1
Q. And the entire --
;;
Q.

2 ' A. Huh-uh (negative).
2
A. I remember it Feb-- it was February.
i

3
Q. Did you have any signs on the property,
3
Q. rm sorry. The entire time that- that
ii
'
4 anywhere, that indicated that it was Delgado Development
4 Delgado Development was -- was in existence, Don worked %
5 Corporation?
5
for Narconon?
I
6
A. No.
6
A Say it -- I'm sorry?
l
I
7 Q. Any - any sign that would indicate that
7
Q. The entire time that Delgado Development

8 any -- any sort of housing for rehabilitation was going
8
Corporation was in existence, from 2006 to 2009, Don

I
9
on there?
9
Delgado worked for Narconon, did he not?


10 A. Huh-uh (negative).
10 A. I don't know, because we divorce in 2007.


11
Q. Why not?
11
Q. Well, you continued--
i
12
A. It's confidential. I didn't want the students
12
A I think that he did in 2007.

I
13
to be known as drug addicts.
13
Q. You continued to have conversations with-

14
Q. All right Let's talk about sort of the--
14 A. Yeah.

15 the operation. We touched on this a little bit earlier.
15
Q. - Mr. Delgado about--

I
16
And - and rm talking about the 2007 and 2008 time
16
A. It's just the timing.
frame. The vans, I think you indicaied to me, were
17
Okay. You continued, after your divorce, to ' 17 Q.


18 owned by Narconon?
18 have conversations with Mr. Delgado about the business,

19
A. Uh-huh (affirmative).
19
did you not?
I
20
Q. Was the insurance on the vans maintained by
20
A. Yes.

1
2::..
Narconon?
21
Q. And- and what was his role in Delgado


22
A. Uh-huh (affirmative).
22 Development? What did he do?
j

'
23
Q. At any point did Narconon ever suggest to you
23
.\ffi. HYNES: Object to the form. You can
24 or. tell you that you should get insurance for Delgado
24
answer it.


25
Development?
25 THE WITNESS: He- he worked for me for

"
Page 75 Page 77 I
1
A. We didn't-- they didn't tell me what to do.
1
a few months, and then he left. He didn't
I

" 2
Q. I'm -- I -- I'm -
2
work for me anymore after that.
ii
3
A. No.
3 BY MR. HARRIS:

4
Q. My question was very specific.
4
Q. Well, there's --there's a document here that
j
5
A. I understand.
5
we'll get to in a little bit, and-- and we'll come back

6
Q. Related to insurance. Did they ever say 6 to it if we need to, but this indicates that Patrick
I
7
anything to you about it?
7 Desmond spoke with Don Delgado about working housing.

8
MS. WHI'ILOCK: Object to the form.
8
And I'm just curious about that; why would Patrick speak

9 BY MR. HARJUS:
9
to Don Delgado about working housing?
10 Q. And by "they" I mean anybody atNarconon; did 10 A. Because the first time Patrick came, he was --
I 11
anyone at Narconon have a conversation with you about .
11 Don was working there,

12
insurance coverage for Delgado Development Corporation?
12
Q. The first -- the first six-month stay when
13 MS. WHITLOCK: Object to the form.
13
Patrick was there?

i
14 THE WITNESS: We can say that Don did,
14
A. Yes, sir.
i
15 but Don worked for Narconon at the time, if
15
Q. Okay. And tl1en you think Don left at some


16 you want to call him Narconon, but he was my
16
point after that?
I
17 ex-husband. We are very good friends, so he
17
A. Yes.

18
wanted to protect me, yes. He - he told me
18
Q. When Patrick came back the second time, was


19 that. That I should get insurance. But not
19
Don affiliated with Delgado Development at that point?


20 as Narconon. As my ex-husband.
20
A. Could have been.
I
21
BY MR HARRIS:
21
Q. Was -- was Don Delgado paid by Delgado
i
22
Q. As close as we can get to when you actually
22 Development?
23 left Narconon -- I think you told me it was 2007, 2008?
23
A. Yes.


2 4
A. I... It- it could have been February of
24
Q. And how much was he paid?


25
either year; I don't remember. 2007 or -8.
25 A $10 an hour.


,,, . ...... : .. . .,. ··.:.· • • • •
20 (Pa ges 74 to 77)
http://ReachingForTheTippingPoint.net
Page 78 Page
80
1 Q. And- okay, just an hourly- 1
students would leave the facility in the morning, if
2 A. Uh-huh (afiirmative). -- 2 they needed to go to the sauna, how did that work?

3 Q. And did he keep track of his hours -- 3 A. They would be dropped at the sauna, and then


4 A. -- I think. If not, a salary of $500 a week, 4 the rest of the people would go to Narconon.
I
5 maybe. I don't know. I don't know. 5
Q. So the van would -- would pick up folks at the
I
6
Q. Well, did he keep track of his hours? 6 apartment, take them to the sauna, if they were stiJI in

7 A. Y eab; everybody tmn in hours. 7 sauna,--


8
Q. All right. And we touched on this earlier; at 8 A. Uh-huh (affirmative).

1
9 no point did -- did you or anyone on behalf of Delgado 9 Q. -right?
1
10 Development attempt to get any kind of license from the 10 A. Right.
i 11 mug-- from-- fromDHR for nmning any kind of drug 11 Q. And then if they weren't still in sauna, they
l
12 and alcohol rehabilitation facility? 12 would -- they would go over to Narconon --
i


13 MR. HYNES: Object to the form. You can 13 A. Yes.
14 answer it. 14 Q. -- for the classes?
15 THE WITNESS: I think that we -- I was 1 5 A. Yes.
i 16 going to classes to - where was that place? 16 Q. And in the evening, how would that -- how

17 Something housing. Oh, what it was? I was 17 would -- how would getting them back work?
.
18 going to this place that gave classes to 18 A. They only were in sauna for five hours, so

19 different housings that - to prepare -- I 19
they would be picked up earlier than the other students


t
20 think to prepare to get a license. But I 20
that were in Narconon. So then they will -- the -- the
;!
21
don't -I don't remember, to tell you the 21 van will go back and pick them up from Narconon.
22 truth. I don't remember. 22 Q. The monitors that you-- and -- well, first of

l
23 BY MR. HARRIS: 23 all, you -- you employed monitors? -
0
I
24
Q. How do you describe Delgado Development? 24 A. Uh-huh (affirmative).

25 What - in terms of, what kind of facility was it? 25 Q. -- Meaning Delgado Development?

Page 79 Page 81
-
1
A. It housed the students. 1
A. Right
2
Q. For- for what?
2
-
Q. And just to be clear, these monitors, were
3 A. To help them stay clean, I guess.
3
they paid by you personally, or were they paid by
j

4 Q. Okay. Did - did you ever talk to anybody 4
Delgado Development?
i
5
in - in the state govenunent or DHR or any other sort
5
A. Develop --Delgado Development.

6 of governmental agency to try to determine whether or
6
Q. Were any of the monitors also employed by I

7 not what -- what you were doing out there needed a
7
Narconon at the same time they were working as monitors?
'
8
license?
8
A. Sometimes.
9
A. When I took over, Don had done everything, so
9
Q. "Sometimes"? Okay. And how did --how did
I
10 I thought that everything was good.
10
that work? How did you decide who was going to pay them

11
Q. So you basically just kept doing whatever it 11 for what'?
$

12
was Don was doing?
12
A. The hours.
i
13
A. Yes.
13
Q. All right. Did you keep a log of when folks

;
14
Q. And did you have any conversations with
14
were worlring for Delgado and when they were working for
!
15 anybody at Narconon of Georgia or Narconon International
15
Narconon?
,
16
about whether or not you needed any kind of a license
16
A. We had different times, so it didn't-
I
17
from the state to operate the facility you were
17
Q. Any of--
18 operating?
18
A. -cross.



19 A. No.
19 Q. You and I talked earlier about the $1700
20
Q. Did that ever come up in any way?
20
charge that you - that Delgado charged each student. I
!
21
A. No.
21
have not seen any record for where Patrick Desmond wrote
I
22
Q. Going back to-- to the daily operations; you
22
a check, Patrick, Sr. or Mrs. Desmond wrote a check to i

23
said, I think, there were three van drivers?
23
Delgado Development Corporation for Patrick's housing.
I
24
A. Ub-huh (affirmative).
24
A. You haven't seen it?
I
25
Q. And we talked about the van. When the
25
Q. I haven't seen it.
--....-..
··-
. ' > ...
21 (Pages 78 to 81)
http://ReachingForTheTippingPoint.net
Page 82 Page 84
1
A. Okay.
1
A. Delgado Development checking.
I
2 ' Q. Does it exist?
2
Q. And is - was that the case during the day
3 A. Yeah. I mean, did you see the refund that was 3 when the students were over at Narconon?
l
.

4 sent to him?
4 A. Huh-uh (negative).

5
Q. Well, the -- I haven't seen the checks; that's
5
Q. How-- how did they pay for food then?


6 what I'm asking you for. Do you have those?
6
A. Their parents would put money in an account to
I
7
A No. I don't think so. But I can-- again, 7 go to lunch.
8 I'll look in the three boxes.
8
Q. Who held --
9
Q. You think they might be in those boxes?
9
A. I--
I
10
A. (No response.) 10
Q. - the account with the -- 'With the money that

11 Q. Okay.
11 the parents had deposited?

'
12 A. Well, I don't know if the bank returns those.
12
A. I don't know.
.
i
13 Q. So the - so the check - the students would 13 Q. Well, in thee-
!
14
write you a check, and then you would take that check
14 A. The- the--
i
15
and do what with it?
15
Q. In the evenings, if the kids-- if the
I
16 A. De - deposit them into Delgado Development
16
students wanted food when they were at Delgado
'l
17 checking account. 17 Development, how did they get food, since they didn't
18
Q. All right. And would - did you refund any
18
have any money?
19 proceeds or did you give any money to Narconon in any
19
A. Like I said, I would take them to -- to
I
20 way?
20
grocery shop.
21
A. Huh-uh (negative).
21
Q. Okay. And then you paid for their groceries?
i
22 Q. What about for how-- for clothing? Or, 22 A. On the --yeah; from Delgado Development

23
excuse me, for these Walmart trips?
23 checking account.

I
24
A. What?
24
Q. How did you make sure that everybody was even?

25 Q. Well, if the students wanted to go to 25 A. Because they had certain amount of money,



Page 83 Page 85

1 Walmart --first of all, one of the rules was they bad
1 whatever it was, for each apartment.
2 to give up all their cash if they were at your facility?
2 Q. And the students --


3 A. ColTect.
3
A. Per person.

4 Q. So they didn't have any cash?
4
Q. The students' parents paid Delgado Development
l
5 A. Right.
5 these funds?

I
6
Q. So if they wanted to buy something. they had
6 A. Huh-uh (negative).
I 7 to either depend upon Narconon or Delgado, right?
7
Q. Who did they pay?
8 A. Their parents.
8
A. I mean, of course they did, but it was from
i


9 Q. Well-
9
the 1700. Or 1500. That covered the food and the
j
10
A. Their parents would get Walmart cards.
10
housing.
I
11
Q. Okay. All right. And who kept the Walmrut
11
Q. Okay. All right. So the food came out of the


12 cards?
12
1700 that the parents paid?

i
13
A. Johnny.
13 A. Uh-huh (affirmative).
'

14
Q. Johnny is who?
1 4
Q. And the parents were required, or the


"
15 A. The driver.
15
students, I guess, if they could pay themselves, they


16
Q. And he worked for who?
16
were required to pay every month?

.,

17 A Delgado.
17
A. Uh-huh (affirmative).
18
Q. Is he one of the guys that worked for both?
18
Q. Can you identify any other drug and alcohol


19 A Yes.
19
rehabilitation facility of any kind, by name, that sent

20 Q. Same thing with food; how did you pay for food
20
students to Delgado Development Corporation for housing?
I
21 for students?
21
A. Can I identify another drug rehabilitation
22 A With checks.
22
that send students to Delgado? Is that what you said?
5

23 Q. And who wrote the checks?
23
Q. Yes.


24 A. I did.
24
A. No.

25 Q. From what account?
25
(Thereupon, marked for identification
II
.... ..... •
22 82 to 85)
http://ReachingForTheTipppi ppppp ngPoint.net
1
2
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1 4
15
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19
20
21
22
23
pmposes, Plaintiffs' Exhibit No. 12.)
BY l\1R. HARRIS:
Q. Let me show you what I've marked as
Pa-ge 86
Plaintiffs' Exhibit 12. Do you recognize this document?
A. Uh-huh (affirmative).
Q. Did you produce this docmuent to us in this
litigation?
A. Uh-huh (affirmative).
Q. Where did you get this document from?
A. The boxes. ·
Q. Now, this is a - a packet of information or a
packet of materials provided by Delgado Development
Recovery Residence to Patrick Desmond, is it not?
A. Uh-huh(affumative).
Q. Now, on the first page it says, "Delgado ·
Development is residential housing for cheminally --
chemically dependent persons." Right?
A. Uh-huh (affirmative).
Q. Is that - is that-- does that accurately
describe the Delgado Development facility?
A. Yes.
Q. Didyouwritethat?
A. No; like I told you, Don had all the paperwork
1
2
3
4
5
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7
8
9
10
11
12
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14
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Page 88 I
BY MR. HARRIS:
Q. So - well, I guess my question is, did you do '
any independent research on this, did you say, "Okay,
I'm running this facility over here, we're doing X. I )
need to find out whether or not we need to get these
people to sign confidentiality agreements"? Or did you i
just do-- 1
A. Oh, no, no, no. I -- the confidentiality I

agreement, I knew that.
®
Q. How-- how did you know that?
A. Like I told you, I was going to these classes 1
for housing to a very independent place, nothing to do
with Narconon. But they would tell us that it's
confidential. Their name and everything else.
Q. And you don't remember who that was, that
facility?
A. No. (Pronouncing) GAH-cah? (Pronouncing)
GAH-hah?
MR. HARRIS: I realize it's a common
tactic, but it's hot in here.
1HE WITNESS: Yes, it is.
l'VIR HARRIS: Even though it's torturing

the lawyers, it's hurting the witness. '

2 4 done. 2 4 MR HYNES: Well, I asked a few minutes
2 5 Q. This --this document itself, the whole thing, 2 5 ago, I thought, if you all needed to tum--

Page 87 , Page 89
1 you got from Don Delgado? 1 wanted me to turn it down, -- i
2 A. Yes. 2 THE WfiNESS:
3 Q. Do you know where he got it? 3 MR. HYNES: -- and I thought everybody
4 A. No. 4 said no. But I'll ask right now.
5 Q. Do you know whether or not it's exactly the 5 BY MR. HARRIS:
6 same as the one that's provided by Narconon to their 6 Q. Is this the same form that you gave to every 1
7 students? 7 student who went into Delgado Development Corporation?
8 A. I do not lmow. 8 A. Yes.
9 Q. Do you know whether Narconon had any 9 Q. Exactly the same? _
1 0 involvement in drafting this thing? 1 0 A. Yes. I think.
11 A. I don't Imow. 11 Q. WelL I want-- I want to know. Do you have I
12 Q. Doyouknowwhetherornotyourfacilityis 12 anotherform?
13 required to have a-- a release like this? 13 A. Every -- everybody signed up the same I
ans:.: HYNES: Object to the form. You can this paperwork says --it refers to, in
16 THE WITNESS: He had the form, so I just 1 6 the first paragraph, " .. . outside of the housing that a I
17 follow what he did. 1 7 student attends the Narconon of Georgia program," right? j
18 BY 1v1R. HARRIS: 1 8 A. "The housing may not say to a person
19 Q. Okay, I'm asking you; I mean, do you know 19 outside ... " Right. Right.
2 0 whether or not you were requiTed to maintain or to have 2 0 Q. Okay. And that's because every oue of your
21 students sign a release like this one? 21 students was attending Narconon?
2 2 MR. HYNES: Object to the fonn. You can 2 2 A. Most of them, yeah. I had two students that
23 answer. 23 didn't.
2 4 THE WITNESS: Yes. I guess. Since I 2 4 Q. Where did they attend?
2 5 did the form. 2 5 A. They were just in housing, trying to get help.
0 • • • ... ...
23 (Pages 86 to 89)
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Page 90 Page
92 ~
~
1 Some of the -- I don't remember their name; I remember
1
6. 5, 6 or7. Or it could have been "The Way to ~
2 that one of my students got them to come. To -- because 2 Happiness."
~
3 they trusted.
3
Q. So the -- the ones that you actually helped
0
~
4 Q. Okay. Were they attending any drug and
4
:Mr. - y o ~ think you might have helped Mr. Desmond on
%
~
5 alcohol counseling? 5 were books 5, 6 or 7, or book 8, which is "The Way to
~
~
6 A. Oh. my God. That was such a long time ago.
6 Happiness"?
~ ~
II
7 I-- I don't remember.
7
A. Uh-huh (affmnative ).
~ 8 MR. HYNES: I asked her to turn down the
8
Q. Do you remember what book 5 is?
~
9 rur.
9 A. "The Ups and Do\lins," I think it's called.
~
<
10
THE WITNESS: Thank you.
10
Q. "Ups and Downs in Life"?
~
i
11 (Thereupon, marked for identification
11
A. I don't know. I think it's called that; I'm
,
12 purposes, Plaintiffs' Exhibit No. 13.) 12 not sure.
I
13
BY MR. HARRIS:
13
Q. What about number 6?
~
w
14 Q. All right. Let me show you what rve marked
14
A. "Conditions," but I don't remember what the
~
~
15 as Plaintiffs' Exhibit 13. Is this a -- is this a
15
exact name is.
~ .
16 Delgado Development document, or is it aNarconon 16 Q. And7? i
~
17 document, or do you know?
17 A. Y eesh. Okay. I don't remember. I think it
~
18 A. Ifs not a Delgado Development, no.
18 was about their responsibility.
~
~
19
Q. All right. Down at the bottom it says, 19 Q. What specific training did you receive in --
~
,
~
20
"Identification of staff persons who will provide
20 in training :t\.1r. Desmond and other students in the books \1
21 treatment or coordinate treatment," and you are listed
21 that you've outlined for me?
~
22 as one of those folks, are you not?
22 MS. WHI1LOCK: Object to the form.
~
23 A. Yes.
23
TIIE WITNESS: Did courses at Narconon.
~
~
24 Q. And you-- down at the bottom here you've 24 BY :tvfR. HARRIS: •
~
25 actually signed it?
25
Q. Do you know what those courses were called?
1
.
.~
Page 91 Page 93 ~
i
1 A No.
1
A. I - I did those courses.
~
~
2 Q. All right. You didn't sign it?
2 Q. You did the actual courses that the students
; ~
J
~
3
A. Huh-uh (negative).
3 were going to do?
~
~
4 Q. Do you know why you're listed as someone who
4
A. Right.
~
:i
5 is providing treatment or coordinating treatment for
5 Q. Tell me what you did; you just went through
I
~
6 Mr. Desmond at Narconon?
6 the books themselves?
~
.
7 A. Probably because I was working in Narconon at
7
A. Right.
i
8 the1ime.
8
Q. Who graded it?
.
j
9 Q. So at the same time that Mr. Desmond was --
9 A. I studied the courses; it wasn't a grading
~
.
~
10 was attending, or at least wheri he signed-- or, this
10 thing.
I
11 document was created 9-25-07, you were-- you were
11
Q. Okay. Was that part of a Scientology training
12
working at Narconon?
12 program?
~
13 A. So that would determine that Februruy of'08
13 A No.
14 I -- I ended my contract with Narconon.
14
Q. And the books that -- really, books 1 through
I
15 Q. What were-- what did you do to coordinate or
15
8 are all very similar to books that are provided in
~
16 provide treatment to Mr. Desmond? 16 Scientology, are they not?
17 A I was trained on getting them to take
17 A No.
18 responsibility for whatever they did. So just to look
18 Q. Okay. You don't -- you don't believe that
19 at how can they get better on that. 19 books 1 through 8 have ve1y similar components that are
20 Q. What specific --was it a specific workbook
20
used by the Church of Scientology? ·
21 that you helped them with?
21 A I know that they -- they are from the works of
22 A. Yes.
22
L. Ron Hubbard, but they are not Scientology.
23 Q. Which book?
23
Q. All right. Well, then, let's talk about
24 A It was the -- depending wha -- it could have
24 L. Ron Hubbard, then. The --the books that you were --
25 been book 7, or it could have been book 5, I think, or
25
you were training on, those books were written or based
24 (Pages 90 to 93)
http://ReachingForTheTippingPoint.nettt
Page 94 Page 96 "
1 on technology created by L. Ron Hubbard? 1 Q. Where? i

2 A. They were based on L. Ron Hubbard's, yes. 2 A. I don't know.


3 Q. And -- and the same is true with the sauna, is 3 Q. You don't-know the city or anything like that?


i
4 it not? 4 A. Huh-uh (negative).
'
5 A. Yes. 5 Q. Do you know what he's doing?
6 Q. The sauna is based on L. Ron Hubbard's 6 A. He is going to school, and he is working as an

7 Purification Rundown, colTect? 7 air cemditionerlheater guy.
1
1
8 A. It's based on the works ofL. Ron Hubbard, 8 Q. When was the last time you talked to him?
'

9 yes. 9 A. Last weekend.

1
10 Q. Okay. But there-- but there is a similar . 1 0 Q. Do you all remain on good terms?


11 detoxification process in the Church of Scientology 11 A. Uh-huh (affirmative).


12 called the Purification Rundown, is there not? 12 Q. Why did he leave your company?
i
1 3 A. Yes, sir, there is. 13 A. 'Cause I ended it.
i
14 Q. Have you been trained on that? 14
Q. Oh, I'm sorry. That's a good point. But I
15 A. No. 15 mean, at some point did he work for Narconon after he

16 Q. Are you still a member of the Church of 16 left Delgado?
I
17 Scientology? 17 A. I don't know.

I
18 A. lam.
18 Q. Okay. Anything else about-- llo you have his
19 Q. Other than doing the books yourself, what 19 phone number?
20 other training did you receive in training in 20 A. Yeah.
21 these books to Mr. Desmond or other students? 21 Q. Do you have it with you?

i
22 A. There were people that carne to train us to do 22 A. Yes.

23 CPR, there were - there were classes that we had to do 23 Q. Can I have it?
I
2 4 on drugs and where \'\'ere they -- the different sing - 24 A. Uh-huh (affirmative). $10. No, I'm kidding.
25 signs of somebody doing certain drug. 25 Q. Do you need a break?
I
Page 95 Page 97

1
Q. That it?
1 A. No. I want to finish. i
2
A. Yep. 2
334-318-7899.

3
Q. Was there· anybody else in the governing 3 Q. 7899?


4 structure of Delgado Development Corporation, other than 4 A. Yes, sir.

I
5
yourself, dwing the 2006 to 2009 time period? 5 Q. In your discovery responses you listed a

6 A. That what? 6 number of monitors who had worked at Delgado

I
7
Q. Any -- anybody other than you? In the 7
Development. Do you have any contact inf01mation for
8 governing structure, the governing - 8
any of those folks, other than Mr. Tucker? And it says
l
¥
9
A Oh, the governing structure, sorry. 9
"Christopher Thcker"; same guy?

i
10 Q. You understand my question? 10 A. Uh-huh (affirmative).


11 A. Like the people that 11
Can you show me?

12
Q. Ran the-
12
Q. Sure. On 7 ifs housing monitors, and then
,
13
A. -- gave orders?
13
all employees are listed on the other side, and they
14
Q. Ran the company. Or made upper-level 14 appear to pretty much overlap.
I
15 decisions. 15 A. And your question was do I have information
I
16
A 2007. Charles.
16
forthem? -
17
Q. Charles ... ?
17 Q. Yes.
I

18 A. Tucker. 18 A. -Yes. Yep.
I
19 Q. Tucker. Do youknowwheJe Chades Tucker is 19
Q. Do you have -- you have contact information

2 0
now? 20 for those folks?
I
21
A. Yes. 21 A. I do.

22
Q. Where?
22
Q. Where is that?

l
23
A. In Alabama
23
A. They're on my Facebook or my phone.

Q. In Alabama? 24 Q. Do you have any other phone numbers with you


2 5 A. Uh-huh (affirmative). 25 now?
I

...... '
25 (Pages 94 to 97)
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Page 98 Page 100
'

1
A. Uh-huh (affirmative). You want them?
1
A. No.
2
- Q.
Yes.
2 Q. All right. Which ones didn't?


3 Yeah, why don't we let you do that, take a
3 MS. WHITLOCK: Object to the f01m.

4 little break, and then you can just write them on the
4 THE WITNESS: Laura Lee Rainey, Mark
I
5 legal pad.
5 Webb, Damaso Delgado, Kimberly Stinson, Deja
6 :MR. INNES: Do you need a copy of that,
6 Nichols, James Wegener.
I
7 and she can write them right next to them?
7 BYMR. HARRIS:
8 :MR. HARRIS: Yeah, that would be
8
Q. So all of the rest of the ones, other than the·


9 wonderful.
9 ones that you just identified for me, to your knowledge,
!
10 THE VIDEOGRAPHER: Going off the video
10 all of them attended the Narconon chug and alcohol
l.
11 record at 12:03.
11
training program?



12 (Lunch recess at 12:03, resumed at 1:01.) 12 A. Yes.
I
1 3 (Thereupon, .M:s. Franklin is not present
13 MS. WHI1LOCK: Object to the fonn.
l.
14 in the deposition room.)
1 4 BY MR. HARRIS: ]
15 (Thereupon, marked for identification
15
Q. All right. Flip it over.

16 purposes, Plaintiffs' Exhibit No. 14.)
16
A. (Witness complies with request of counsel.)

I
17 1HE VIDEOGRAPHER: We are back on the
17
Q. Let me see it, if you don't mind.
1 8 video ree-ord. This is the beginning of tape
18 A. (Witness complies with request of counsel.)

19 number 2; the time is 1:01 p.m.
19
Q. And it's the same question for No. 13, and I
20 MR. HARRIS: All right, we're back on.
20
think there's a good bit of overlap, but I just want to
I
'
21 BY :MR. HARRIS:
21 be clear for the record. It says, "Identify all
1

22 Q. Ms. Delgado, over the break you got some phone
22 employees and independent contractors for Delgado

23 munbers for me; I appreciate you doing that
23
Development between 2007 and 2008." Which of those '
24 A. Uh-hul1 (affinnative).
24
people were both Narconon of Georgia employees and

I'm going to go ahead and mark as Plaintiffs'
25 Delgado Development employees?

25 Q.

Page 99 Page 101 l
i
1 Exhibit 14 that interrogatory. There-- there's 1
A. Debra Toth, same-- same people that I told

2 actually tvm interrogatories I want to talk about;
2
yolL


3 No.7, which is "Identify every housing Stlpervisor,
3
Q. The same people that you identified in
!

4 housing intern and housing monitor employed by 4
a
response --
I
5 Narconon - " excuse me, "by Delgado Development between 5
A Yeah.
i
6 2007 and 2008." Let's talk about that one first. 6
Q. -to my previous question?

ij
7 There's a list of people that you have 7 A. Uh-huh(affirmative). Yes.
8 identified in response to that question? 8
Q. Anybody else?
9 A. Uh-buh (affinnative). 9
A. Sorry. No.

10 Q. Which of those people were employed by both 10
Q. And same question about attending the Narconon
q

11 you and Narconon? By "you" I mean Delgado Development 11 of Georgia chug and alcohol rehabilitation training


12 Corporation. 12 program.

13 MS. WHI1LOCK: Object to the fciim. 13
MS. WHITLOCK: Same objection.
i
14 BY l\1R. HARRIS:
1 4
THE WITNESS: Tell me again?
g
15 Q. And by-- by "Narconon" I mean Narconon of 15 BYMR. HARRIS: :r-;
16 Q. Same question. Did all of those folks, to

16 Georgia.

i!
17 A. Debra Toth, Jolmny Carter, Anthony Arnold,
17
your knowledge, attend the Narconon of Georgia drug and


1 8 Brad Taylor. 18 alcohol training? I

19 Q. And the list of folks in response to No. 7 19 MS. WHITLOCK: Same objection.
a

20 that we've been talking about, do -- were every
20
Tiffi "'W1TNESS: Except that I -the ones

21 single-- did every single one of those people, at some 21 that I told you.

22 point, to ymrr knowledge, attend the Narconon drug and 22
BY :MR. HARRIS:
J
23 alcohol rehabilitation program?
23
Q. The same list?

;!
24 A. Did everyone? 24
A. Uh-huh (affinnative).


25 Q. Uh·huh (affinnative). 25 Q. Okay.

ij
•. • ....
26 (Pages 98 to 101)
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Page 102
1 A. It's the same list 1
2 Q. Anybody else? 2
3 A. It is the same list. 3
4 Q. Got you. All right. 4
5 Did you have, in 2 -- between 2006 to 2009, 5
6 did you have an E-mail account that you used for Delgado 6
7 Development Corporation? 7
8 A. I don't know. B
9 Q. Did you have an E-mail account? 9
10 A. Yeah. 10
11 Q. Did you use that E-mail account that you bad 11
12 for any work-related purposes? 12
13 . A. Probably not. 13
14 Q. Why do you say "probably not"? 14
15 A. Because I would talk on the phone with people. 15
16 Q. And -- and that's really my ne:x.1: question. 16
1 7 Did you -- did you ever E-mail back and forth between 1 7
18 yourself and anyone at Narconon of Georgia about any of 18
19 the issues related to housing? 19
2 0 A. I don't think so. 2 0
21 Q. Doyouknow- 21
2 2 A. I think that I wrote reports. 2 2
2 3 Q. What kind of reports? 2 3
2 4 A. Like whatever infonnation, I would just write 2 4
2 5 it to them and then send it with the driver or take it 2 5
Page 103
1 myself. 1
2 Q. Was that something different from a knowledge 2
3 report? 3
4 A. Yeah. I mean, just conununication, whatever I 4
5 wanted to say about whatever. 5
6 Q. So tell me about these reports; what kinds of 6
7 reports would you write? 7
8 A. Like if- if it was that somebody at Narconon 8
9 needed to help me to get the students up on time. You 9
10 know. This guy, I have tried, and it's like all of the 10
11 students getting late because he's not getting up. So I 11
12 would write a report on that. 12
13 Q. Did those reports have any sort oftitle, do 13
14 they have a -- did you call them something? 14
15 A. · Sometimes knowledge reports, sometimes just 15
1 6 dispatch. 1 6
17 Q. "Dispatch"? 17
18 A. Uh-huh (affilmative). Like a- yeah, a note. 18
19 Q. Called-- okay, dispatch reports? -- 19
2 0 A. Uh-huh (affirmative). 2 0
21 Q. --Is that how you referred to them? 2 1
22 A. Dispatch, yeah. . 22
2 3 Q. Got you. Any-- any other similar types of 2 3
2 4 reports that went back and forth between you and 2 4
2 5 Narconon? 2 5
A. Not that I know of.
Q. Where are these dispatch reports?
A. Probably at Narconon.
Q. Did you keep a copy of them?
A Maybe.
Q. "Maybe" meaning ... ?
A Maybe meaning maybe.
Q. Where would they be?
Page
A. Ifl gave it to you for you to know about it,
then you have it. You know, so it would be in Narconon.
Q. Well, I have not seen any-- any report like
the ones that you've described for me, so --
A. Okay.
Q. --do you know-- as you sit here today, do
you know whether or not you retained copies of any of
these dispatch or similar kinds of reports?
A. No.
Q. Have you looked for them?
A. I don't know if-- if- if they were in the
questionnaire, I did. Or in the interrogatory.
Q. Allright
(Thereupon, marked for identification
purposes, Plaintiffs' Exhibit No. 15.)
(Discussion off the record.)
BY MR. HARRIS:
Page
Q. Okay. I'm going to hand you what I've marked
as Plaintiffs' Exhibit 15. And I want to talk about
Exhibit 15, and in-- in addition, the student
confidentiality, it's -- begins --I can't remember what
number it is, but it's in the stack in front of you,
it's the student confidentiality packet that was given
to Mr. Desmond?
MR. HYNES: 12.
MR. HARRIS: There you go. 12, thank
you.
MR. HYNES: You want her to have both of
these right there?
MR. HARRIS: Yeah, just-- 'cause I'm --
we're going to go back and forth. I just
want them easily accessible to her.
BY MR. HARRIS:
Q. All right. In 2009, did you stop running a
recovery residence or whatever you want to call it?
A. Yes.
Q. Vvby did you -- why did you do that?
A. Myheart.
Q. Okay. You weren't capable of doing it anymore
because of your physical condition?
A. Right.
Q. Did it-- did you-- did anyone from Narconon
2 7 (Pages 102 to 105)
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Page 106
of Georgia or Narconon International ever discuss with
you Patlick Desmond's case in any way?
A. Yes.
Q. Who?
A. Mary.
Q. All right. Mary Rieser?
Yes. A.
Q.
A.
Q.
Anybody else?
Mostly her.
Well--
A. And Tracy Stepler.
Q. Tracy Stepler?
A. Uh-huh(affinnative).
Q. Anyone else?
A. No.
Q. After Mr. Desmond's death, there were a couple
of ladies who came in fi·om Narconon Intemational and
did some reviews of the program. Did you speak with
either one of those ladies?
A. Huh-uh (negative). No.
Q. Do you know who they are?
A. No.
Q. Barbara Dunn?
A. No, I don't know her.
Q. Okay. Did you provide any documentation of
Page 107
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it at that time, then it was stored in a safe at
Delgado?
A Yes.
Pa ge
Q. And then when the student went back to
Narconon in the morning, the medicines were given to the J
van driver, correct? 1
A. Well, they will -- like they would have -

yes. They will be -- I think that there was -- they
would take the bottle to Narconon. i
Q. Okay. Well, the bottle itself: they-- was I
there a process where it was checked out of the safe at
Delgado? I
A. He was the only one that did that, so -
Q. Okay. Was--

A. -he would know.
Q. -there any kind oflog?
A I think so. I think so, yes; because they --
they needed to count the pills to make sure that nobody
was taking it except the student.
Q. And then the van driver would take the pills
to Narconon, right?
A Uh-huh (affirmative).
Q: And then release them to someone at Narconon?
A. Yes.
Q. And then at the end of the day you would do
Pa ge 10 9 I
l
your facility or anything that - any records that you 1 the reverse?
had, did you provide any of that to --hold on, let me 2 A. Yes.
finish my question. --to Narconon of Georgia in 3 Q. And do you know what kinds of medications
4 connection with any kind of investigation of Patrick's 4 we're talking about? Can you give me some names of any
.
5 death? 5 of the medicines that were handled that v.;ay?
A. No. 6 A Subutex. I
7 Q. Okay. We talked about the van, and talk 7 Q. Subutex?
l
i- B about a few other things related to housing. If a 8 A I think Su --
9 student had medication that the student needed, was 9 Q. Or Suboxone?
10 there someplace that the medication was stored on the 1 0 A. Subox --No. Suboxone. I
11 Delgado Development property? 11 Q. Suboxone? I
12 A. There was. 1 2 A Yes.
13 Q. Tell me about that. What was the process for 1 3 Q. Which is a methadone derivative? "

14 doing that? 14 A. I don't know if it was Suboxone. Subutex? 1
15 A. They will be sent to Delgado from Narconon, 15 Subutex, I think it was. 1
16 from the doctor, and they would be given to the --to 16 Q. Okay. i
17 the driver, Johnny-- Jolnmy something. Whatever his 17 A. I think it was.
1 8 name was. And then he would put it in the safe. 18 Q. Could it l1ave been Suboxone?
Q. Okay. 19 A. It could have been. i
A. And then he will deliver-- or-- or, see that 2 0 Q. Is there a log somewhere that will identify
21 the student took his medication on time and didn't abuse 21 what sorts of medicines were kept in that safe? i
2 2 it 2 2 A. I can check in the box, again. Sorry.
!
2 3 Q. So if a student had medication that was 2 3 Q. Please. That's v.here it would be, is in the
2 4 prescribed to that student, then while the student was 2 4 box?
2 5 at the Delgado facility and if the student wasn't taking 2 5 A If-- if -- if I have it, yeah, it would be in
6
19
20
· · ··-t. •·,.. ' . • • .....
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Page 110
those three boxes. I don't have anything else anywhere 1
~ ~ 2
Q. And then the medicines would be given to the 3
individual students at the premises as needed? 4
A. As prescribed. 5
Q. As prescribed? 6
A. (Witness nods head affirmatively.) 7
Q. And only the amotmt that was prescribed? 8
A. Uh-huh (affinnative). 9
Q. And that was done by Mr. Taylor? 1 0
A. No; Mr. Johnny Carter. 11
Q. Mr. Carter? 12
A. Uh-huh (affirmative). 13
Q. And Mr. Carter was the van driver? 14
A. Yes. 15
Q. And he was employed by who? 1 6
A. By me and by Narconon. 1 7
Q. By both you and Narconon? 18 ·
A. Uh-huh (affirmative). 19
Q. Did you have any kind oflicense from the 2 0
Georgia Bureau of Narc.otics to store any of these 21
pharmaceutical products at Delgado Development? 2 2
A. Huh-uh (negative). 23
Q. Did you petition for one? 2 4
A. Huh-uh(negative). 25
Page 111
Q. Did you have any kind of license from the 1
Georgia Department of Human Resources to store these 2
products? 3
A. No. · 4
Q. What training did -I'm sorry, I keep 5
forgetting his name. Taylor? 6
A. No, it's-- me too. Johnny Carter. 7
Q. Johnny Carter. Okay. And be's the only one 8
that dispensed the medicines? 9
A. I think so, yeah. 1 0
Q. What training did he have in that regard? 11
A. He had -- somebody came and gave us classes 12
on, you know, you had to put the pill on the thing, and 13
then the student would take it. You know, it wasn't -- 14
it wasn't that we were giving it, putting it in their 15
mouth or whatever, you know, like they had to take it. 16
Q. I understand. But you- but Johnny Carter-- 1 7
were you at tbis training? 18
A I was, yeah. 19
Q. So -- so basically the \vay that it worked was 2 0
you would take the pill out of whatever package it was 21
in and put it out, and make sure that only that amount 2 2
was taken? 23
A. Right. 24
Q. And then the person had to ingest the 2 5
Page 112 ~
medicine?
A. Right.
Q. Do you know where that training -- who gave
you that trailling or where you took it?
A. I don't know. I don't know what the person
was.
Q. Any other -
A. I think it was a nurse. I think. But l'm not
sure.
Q. As part of the -- the sauna program, ·
they're --the -- the students receive vitamins and
niacin, do they not?
A. Uh-huh (affirmative).
Q. Was any of the-- were any of the vitamins and
the niacin dispensed while the students were at Delgado
Development?
A. Huh-uh (negative). No; they would take it at
the sauna.
Q. Did you have any kind of nurse or anyone with
any sort of a medical license that worked for Delgado
Development?
A. No.
Q.
A.
Q.
No nurses, no doctors?
Huh-ul1 (negative).
Do you know whether or not Johnny Carter had
anything like that, --
A Huh-uh(negative).
Q. -- any kind of medical training or license?
A. I don't know. We didn't provide a treatment,
so we didn't. ..
Q. All right. And Delgado provided monitors?
A Uh-huh (affirmative).
Q. It provided certain types of security?
A. Uh-huh (affirmative). Yes.
Q. Now, what's the difference between a monitor
and security?
A. At one time I had security, a-- a- an
outside security company ou the top of the monitors.
Which it was the monitors were trained about the
symptoms or the- the looks of somebody using or trying
to do something. And the security company was more just
outside the buildings, just walking the buildings.
Q. Do you know what time period you employed the
security folks?
A. I think it was from 12:00 till4:00, 6:00.
Q. And I -- I meant -- thank you for answering
that question, but I really meant something else. Which
is, when between 2006 and 2009 did you have security
folks on -- on the premises?
A. I don't remember.
I
I
29 (Pages 110 to 113)
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Page 114
1 Q. Do you remember who they were? I mean, what 1
2 company you employed? 2
Page 116 ~
~
policy where people were not allowed to leave the ~
premises unless they had permission to do so; is that !
3 A. Lagniappe. 3 correct?
4 Q. Say that again? 4 A. Uh-huh (affirmative).
5 A. L-A-G-N-1-E-A-P-E, I think. 5 Q. So in order to -to leave the premises, you
6 Q. All right. Do you have any idea when it would 6 had to get authorization to do that?
7 have been, -6, -7, -8, -9? No idea? 7 A. If you wanted to continue to be in the
8 A. I have no idea. 8 housing, yes.
9 Q. Was that in response to anything? 9 Q. If you wanted to continue to be in the
1 0 A. No; I think that we just were expanding and I 1 0 housing. And the authorization to leave V.'liS actually
11 wanted to have better security. I mean, as a -- as an 11 given by Larry Chorvas?
12 example, I think. .. There was one student that wanted 12 A. Uh-huh (affirmative).
13 to leave, and he told me that- that-- I was by myself 13 Q. Who works for Narconon?
14 outside in the -- in the parking lot, so anything could 14 A. Right. ~
15 happen to me. Whatever. So I wanted security there. 15 Q. He was the ethics officer for Narconon? ~
16 Q. Soyouhadsortofa- 16 A Yes I
17 A. Kind of like a threat, I guess, to my --to 1 7 Q: And so if a student wanted to leave Delgado ~
1 B me. 18 Development's housing, in order to do so the student had ~
~
19 Q. Okay. So you-- one of the students 19 to receive permission from the Narconon ethics officer? ~
2 0 threatened you and you got concemed, so you hired 2 0 A. Uh-huh (affinnative). ~
21 security in response to that? 21 Q. In Plaintiffs' Exhibit 12, on-- just the i
2 2 A. Uh-huh (affirmative). 2 2 Bates number down at the bottom, which is 0005, there's ~
2 3 Q. What about any overdoses that occurred on the. 2 3 a consent form for treatment. You see that, it says · ~
2 4 · propetty, do you recal1 anyone overdosing on the 2 4 "Student consent folUl"? ~
25 propetty? 2 5 A. Out. Yes. Uh-huh (affmnative). ~
~ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 4 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 4 ~
Page 115 Page 117 ~
!
1 A. No. I don't. 1 Q. And in that consentform. again it's typed in, j
2 Q. No recollection of anyone having a drug 2 it says that this consent form is for "review and. . .in "
~
3 overdose between 2006 and -- or, actually, excluding 3 further treatment and care, verification oftreatment ~
~
4 Mr. Desmond, but between 2006 and 2009? 4 and care at Narconon of Georgia, or other"? 1
5 A. Ml·. Desmond didn't overdose at the apartments. 5 A. Uh-huh (affirmative). Yes. 1
6 But, no. 6 Q. All right. So Narconon of Georgia was already ~
7 Q. Okay. That's it? 7 typed into the consent fonn? ~
8 A. Uh-huh (affinnative). B A. Yes. •
9 Q. In the packet that you provided to 9
1 0 Mr. Desmond, on the second page it says that "Delgado 1 0
11 Development provides a var --variety of 11
12 activities, --
11
- - 12
13 A. Uh-huh (affirmative). 13
14 Q. -- "sporting activities and recreational 14
15 activities"? 15
16 A. Uh-huh (affirmative). 16
17 MS. WHITLOCK: You're b ~ k to No. 12? 1 7
18 MR. HARRIS: Yes, I'm sony. 18
19 MS. WHITLOCK: Okay. All right. 19
2 0 .MR. HARRIS: No. 12. 2 0
21 MS. WlllTLOCK: Uh-huh (affirmative). 21
22 BYMRHARRIS: 22
2 3 Q. Is that correct? 2 3
24 A. Yes. 24
2 5 Q. And in addition, Delgado Development had a 2 5
Q. And this was -- this consent was - it - if
Delgado Development had administered a drug test or a
drug screen, the student was consenting to allow that
drug screen to be provided to Narconon?
A. Uh-huh (affirmative).
Q. And Delgado Development administered drug
testing on the premises?
A. Uh-huh (affirmative).
Q. Drug screening?
A. It's the same thing.
Q. Well, it-- it may or may not be. Do you know
the difference between drug screening and drug testing?
A. Wejustdiddrugtesting.
Q. Okay. The next page, it says, breathalyzers
and consent to - to urine drug screening?
A. Uh-huh (affirmative).
Q. Did Delgado Development or employees of
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Delgado Development actually administer ~ - 1
· A. Breathalyzers. 2
Q. -- Breathalyzers? 3
A. Uh-huh (affirmative). 4
Q. And-- 5
A. Yes. 6
Q. --urine testing-- 7
A. Yes. 8
Q. -- for drugs? Where did you get the testing, 9
where did you get the samples tested? i 0
A. We got the drug tests from a company. 11
Q. Who administered the drug tests? 12
A. The-- the monitors. 13
. Q. What training did the monitors have in how to 14
properly conduct a drug test? 1 5
A. We were trained, again, by someone, on looking 1 6
for, you know, if they had anything on their bodies, and 1 7
make sure that they pee, that it was their pee, that it 1 8
was the right temperature and everything else. 1 9
Q. All right. Whe --again, where did this 2 0
training take place and who -- who did it? 2 1
A. Don will teach people how to do that. 2 2
Q. So Don was the guy who trained the monitors in 2 3
how to administer drug tests? 2 4
A. Mo --most of the people worked before with 2 5
Page 119
Don, so they knew, yeah. And if-- if not, thenlwould 1
train them. 2
Q. Well, and what training do you have in how to 3
administer drug tests? 4
A. Don tmined me. 5
Q. Do you know where Don trained? 6
A. No. 7
Q. And go-- just walking through this same 8
docwnent-you and I talked about this earlier--the -- 9
the payment amount that-- that's listed here is 1700. 1 0
I promised you I'd show you the document that said that, 1 1
and I just wanted to show that to you. 12
A. Okay. 13
Q. You're :... you're comfortable that jf it says 14
that, that's the amount that was charged? 15
A. I thought it was 1500, like I said, but... 1 6
Q. All right. Going through this document, it 17
says "Delgado Development Recove1y Residence," the title 1 8
is "Philosophy." Looks like a Bates 10 down at the 1 9
bottom-- 2 0
MR. HYNES: I'm sony, I didn't know I 2 1
was going to -- let's see. I was going to 2 2
show her the page -- 2 3
MR HARRIS: Oh, yeah, sure. Go back. 2 4
MR. HYNES: --that has the number on 2 5
Pa ge
it, if you want.
MR. HARRIS: I don't think it was
numbered--
MR HYNES: Yeah, it looks like it's 9.
TilE WITNESS: The policy, or the
~
philosophy, or the payment? Which one? a
BY MR. HARRIS: ~
Q. Well, I'm-- I'm past the payment, unless ~
~ - I
J m
A. Oh. ~
Q. --want to look at it. I
A. Okay, fine. ~
~
Q. Next page is "Philosophy." ~
A. Okay. ~
Q. It says, in the second paragraph, "We make it ij
~
a point to become familiar with the rehab programs , ~
attended by our residents in order to intellectually ' ~
provide support" -- or ''t11is support." Again, you I
can't, as you sit here today, you can't think of any i
other program that the students were attending, other ~

than Narconon? "
i
A. Right. Yes, like I said, two people. ~
Q. So-- I
A. Two other people. ~
Q. So you expected your --your monitors to be ~
familiar with the Narconon program?
Pa ge 121 ~
~
A. Not necessarily. I wanted them to do their
job, which was to provide a safe, clean environment for
the students.
Q. All right. Well, I'm just reading what it
says. I mean, why does it say you expect them to be
familiar with the rehab program if that wasn't your
expectation?
A. Like as in the writing notes or whatever about
the students, and, you know, send it to whatever place
it was appropriate.
Q. And we'll get to that. Are you talking about
KRs?
A. Uh-huh (affirmative).
Q. The desc --the ne:x.1 page, it says,
"Descdption. The recovery residence is located in an
apartment complex in Sandy Springs, Georgia." That's
the next page.
A. Uh-huh (af:fim1ative).
Q. That's not accurate, is it?
A. It is in Sandy Springs.
Q. No, well, the -- I mean, this-- this
~
~
i
~
§
~
~
~
j
C]
I
'J
!
'i
~
~
.
~
~
~
I
~
~
~
~
~
~ ­
~
:t
document, is that refel1'ing to wbere the facility was at ~
the time that it was the previous company? I mean, did ~
this just get cani.ed over from the documentation, is ~
31 (Pages 118 to 121)
http://ReachingForTheTippingPoint.net
Page 122 Page 124
1 what I'm asking? 1 Or when they came in.
!

2 A. Yes. 2
Q. They weren't allowed to have any personal

3 Q. Okay. So this isn't referring to Sovereign
3
vehicles on - Oil the residence site, correct?
I

4 Place. It's referring to the housing that you all had
4
A Right.
I
5 been doing before, or Mr. Delgado had been doing before? 5 Q. They weren't allowed to have- or, they
I
6 A No. That is in Sandy Springs.
6
weren't supposed to have, until at least some point when

7 Q. Okay. Is that- is that what that's
7
they got permission, cell phones; is that correct? I
8 referring to? 8 A. Right.


9 A. One Sovereign-- I think so. Roswell Road,
9
Q. And when -- when did they start using cell
I
10 yeah. In Sandy Springs.
10
phones?
l
11 Q. All right. 11 A Mostly Larry will -- since they were doing the
12 In order to take a field trip and leave the 12
treatment, he would know when they were prepared to do
13 premises, mi.ce again that had to be approved by
13
it.
i
14 Mr. Chorvas?
1 4
Q. So in order to use a cell phone on the Delgado
I
15 A Uh-huh (affirmative). 15 premises, they bad to get permission from Larry Chorvas,
I
16
Q. The ethics officer forNarconon, right? 16 the Narconon ethics officer?
I
1 7
A Yes.
17
A The treatment place, yes.
i
18
Q. It all says - on the next page it says
18
Q. Well, but from Mr. Chorvas specifically?
19 that -- that - that Delgado "provides monitors, 19 A Right Or whoever he was that-
§

.
20 security teams ... " You see where I'm reading, in the 20 Q. Was- was there some other ethics officer
i

21 middle there? It's on-- it says 3 down at the bottom.
21
there during the time that you -- that Delgado
f.
i
22 A Uh-huh (affirmative). Yes.
22 Development was operational?
:5
23
Q. The security teams, is that -- is that the 23 A. I don't know.

24 same thing that you told me about before, or is there 24
Q. If you look at "Residence Rules"?

25 something different?
25
A. Okay.

i
Page 123 Page
12s 1

1 A No, it would be that.
1
Q. Paragraph number 3? l

2
Q. So you got monitors, you got the security
2
A. Uh-huh ( affinnative ).
!

3 company that you hired at some point? 3 Q. It says, "For everyone's protection, the

4 A. Uh-huh(affirmative). Yes.
4 following items are not allowed: Personal cell phones," I

5
Q. What's the difference between the -- the
5
and then in paren it says, "This privilege may be j
6 supervisors or - and monitors, if there is any?
6
requested upon written approval after sauna."
i
7 A. Well, the supervisor was Charles Tucker. He 7 A. Uh-huh (affirmative).
8 was in charge of the monitors. So he would decide who
8
Q. Were there any other rehab programs that you •
I
9 was working that day, or how to set up which student
9
folks were affiliated with that were using saunas, other


10 with which. .. 10 than Narconon of Georgia?


11 Q. And the-- the res-- it says "searches" here; 11 A No.
i
12 did-- was it a practice to search the rooms of the
12 Q. So sauna is already embedded here in Delgado

>

13 students?
13 Development's rules?
i
14 A. Yes. 1 4 A. Right.
t
15 Q. So the staff was administering drug testing?
15 Q. Delgado had a curfew that it enforced?
I
1 6 A. Yes.
16 A. Uh-huh (affirmative).
17
Q. And it would- the staff would from time to
1 7 Q. How did it enforce the cwfew?

18 time do Breathalyzers? 18 A. The aprut - the students have to be in their
i
l
19
A. Yes.
19 apartments at the time that the cwfew was done.
I
2 0
Q. And search the rooms of the residents?
2 0 Q. And you informed tbe students that they were
21
A. Yes.
21 not allowed to disclose to anyone else the fact tbat
22
Q. What about their persons, did the monitors
22 there was some other student there at Delgado
23 search their persons?
23 Development?


2 4 A. Uh-huh (affirmative). Yes. When they came
24
A Uh-buh (affinnative).
I
2 5 back ft·om outings or, you know, their leave of absences. 25 Q. Why did you do that?

-
.... •
, _ ..
,,, .. •' ·
32 (Pages 122 to 125 )
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Page 126 Page 128
1 A. Because it was confidential.
1 Narconon requires?
2
Q. And who told you it was confidential?
2 A Uh-huh (affirmative).
3 A. Like you see --I think it was here.
3
Q. So if there were people staying here who
I 4
Q. That-
4 weren't students in Narconon, why in the world would you

5 A. This.
5 be writing up a knowledge report?

6 Q. - that form that you just got carried over
6 A Say that again?

1
7
from--
7 MR. HYNES: Object to the fonn.

8 BY MR. HARRIS:
:>
8
A. Yes. i!
9 Q. -before? That was your basis for believing
9
Q. If you had somebody-- Nar --the knowledge


10 that -- that one student at Delgado could not tell
10 report is something that Narconon requires?


anyone about the existence or the fact that another
11 A (Witness nods head affirmatively.)
•J.
11

12
student was -- was staying there?
12 Q. And it's a te1m a Nar -- actually, it's a term

!
13 A. No. Also GARR Remember the name ofthe
13 of art for Scientology, isn't it?
I
14
place that I was getting training? GARRis the place.
14 A rmsony?

i
15
Q. GARR?
15 Q. "KRs," that's- that's a Scientology term?
i
16
A. 0-A-R-R.
16 A It's -- it is too, yes.
I
17
Q. Georgia Assisted Recovery Residence, -
17
Q. Okay. And- and-- and so why would you
18 A. Uh-huh (affirmative).
18 write up a KR if that's a doclllnent that's required by
19
Q. -- or something like that?
19 Narconon unless the only people staying at your

20 A. Yes, sir.
20 residence were - were students from Narconon? !
X
21
Q. That's where you got training?
21 A. I would expect the place that was treating


m
22 A. Yes.
22
them to help them, so I need to -- them to know, because

23
Q. Keep --keep going through these rules. At
23 they are the ones treating them.
· 24
nwnber 26 --it says "Resident Rules"?
24 Q. But nevertheless, in-- in Delgado
25 A. Uh-huh (affirmative).
25 Development's rules you refer specifically to doing KR.s?
I

Page 127 Page 129 1

1
Q. "No overnight leave of absence will be 1 A. Uh-huh (affinnative).
1
2 approved while in the sauna"? 2
Q. And those KRs in fact were submitted to
i
3
A. Uh-huh (affirmative).
3
Mr. Chorvas?
I
4
Q. Again. sauna is referred to in the Delgado 4 A Yes. 1
5 recovery rules, the residence rules? 5
Q. And - who worked for Narconon?
I
6
A. Uh-huh {affirmative). Just like when you go 6
A Yes.

7
to McDonald's you want a munber 1 with Coke. You know.
7
Q. And also a Mrs. (Pronouncing) Tawth? Or Toth?
i1


8
So it was just for Narconon. 8 A Uh-huh (affirmative).
.

9
Q. Well, any other programs that you guys had 9
Q. Is it a Mrs.? Is that right?

10 people staying there that use the sauna, other than 10 A Miss.
I
!
11
Narconon'?
11
Q. Miss? Okay, I'm sony.


12
A. Huh-uh (negative).
12
A. That' s fine.
I
13
Q. All right And then going down to 32, it 13 Q. What- what was her job duty?
14 says, "All residents are to report any occwTences 14 A I don't know. I don't know why will it go to
I
15
that -- that are not appropriate for a drug rehab
15 her.
I
16
program to the supervi- supervisor"?
16
Q. Well, who did she \Vork for?
I
17
A. Uh-lroh (affirmative). 17 A. She was my driver at one point, and then she
18
Q. And then it says, "That means writing up a
18
also vrorked for Narconon.
;
19
knowledge report."
19
(Discussion off the record.)
I
A. Uh-huh (affirmative). 20 BYMR HARRIS:
21
Q. And "knowledge report" is a -
21
Q. All right And then I want to talk to you
!
22 (Thereupon, Ms. Franklin entered the
22
about the "Monitors' Duties and Responsibilities,"
I
23 deposition room.)
23
the -- the second document that I marked.
l
24
BY :MR. HARRIS:
24 A Oh.
25
Q. -- is a term that refers to docwnents that
25
Q. What's the exhibit number on that, ma'am?

.. ·-- • • • • • .. ... ,.., •. , .. ..
33 (Pages 126 to 129)
http://ReachingForTheTippingPoint.net
Page 130 Page 132 kl
1 A.
15 . . 1
wifi dr . d' . bee ~
your e, you op m a con 1t10n ause you are not i
2
Q. 15, thank you.
2 being faithful. So we try to correct that, yes.
~
3 A. Uh-huh (affirmative).
3
Q. And- and "dropping conditions" is a
~
4 Q. Who wrote Exhibit 15?
4 Scientology term of art? It's a term used in
i
(i
5 A. Oh. Don.
5 Scientology, "dropping conditions"?
~
6 Q. Was this something that he gave you also?
6
MS. WIDTLOCK: Object to the form.

~
7 A. Yes. Wait. I don't know. One second.
7 BYMR. HARRIS:
"
8 Yes. It would have been him.
8
Q. Right?

~
9 Q. All right. Let's go to -- I think this looks
9
A. Yes, it's also used in Scientology.
I
10 like the fourth page in, here. One, two, three, fom.
10
Q. Number 11, it says, "Always ask about the
~
11 Now, these are rules that apply to the
11 program. If you have done the program, always tell them
~
•l
12 monitors who work at Delgado Development, right?
12 your wins in it"?
~
13
A. Uh-huh (affirmative).
13
A. Uh-huh ( affinnative ).
I
14 Q. And this is what you, or Delgado Development,
14
Q. What does "your wins in it" mean?
~
15 expected the monitors to do in connection with their
15
A. It means when somebody gains something.
j
1 6 job, right?
16
Q. Right. And that's a - and that's a term of i
17 A. Yes.
1 7
art that Mr. L. Ron Hubbard frequently used in his
I
18 Q. And I'm not going to talk about all of them,
18
writings, "your wins," correct?
I
19 but I want to talk about a few of them. Number 8, it
19
A Correct.
~
20 says, "Don't discuss other residents' programs with
20
Q. Number 12, it says, "Apply the attributes in
~
21 other residents. We're bound by confidentiality laws,
21
chapter 20 of'The Way to Happiness.' Know them and
i
22 and it is a fonn of invalidation when we discuss their
22
apply them evei'Y day." TI1afs number I 2, correct? ~
;;
23 problems or ethics situations."
23
A. Uh-huh (affirmative).
~
24 A. Uh-huh (affirmative).
24
Q. And number -- and "The Way to Happiness" is a
I
I
25 Q. What is an "ethics situation"?
25
book that was written by L. Ron Hubbard, right?
~
Page 131 Page 133
~
I
1
A. That they relapse or that they were breaking
1 A. Okay. Yeah.
~
2 the rules.
2
Q. And is actually one of the training books
~
3
Q. And - and ethics situations are being out -
3 provided to the students at Narconon, conect?
~

4 ethics is a -- is a Scientology term, isn't it?
4 A. Yes. ~
5
A. It is a tenn that I use at Delgado
5 Q. Number 13, it says, "Investigate. It is our
~
~
6 Development.
6 job to save people's lives." ·so that was one of the ~
:!
7
Q. Right. And -- and -- and Narconon also uses
7 policies in effect by Delgado Development at the time,
*
~
8 thatte1m?
8 and you expected the monitors to follow that policy? ~
9 A. Okay.
9 A Yes. ~
3
10
Q. You know that, don't you?
10
Q. Number 14; it says, "Don't miss withholds."
~
11
A. I work there; yes.
1 1 What's "withhold" mean?
~
~
12
Q. Yes. So you knowthatthat's a term that's
12 A. Something bad that you have done and you know
I
13 used by Narconon?
13
that you did it and then don't say it.
~
14 A. Okay.
14 Q. Right. And a "withhold" is a -- is again a
i
~
15
Q. And if-- if a student violates the rules,
15 term of art that's used in Scientology?
i
16 it's considered an ethics violation, right?
16 A. It's also used in the books ofNarconon.
1 7 A. Correct.
17
Q. Okay. But it's used in-- in Scientology?
}
1
1 8 Q. And the student might be -have - have his
18 A. What that has to do with anything? Sorry.
~
19 condition dropped as a result of that?
19 MR. HYNES: Just -
I
20 A. Could.
20 BY MR. HARRIS:
21
Q. Is that tight?
21 Q. Just answer my question.
~
22
A. That's right.
22 A Okay. Yes.
23 Q. And -- and the conditions are dropped by the
23
MR. HYNES: Ifyou lmow.
24 ethics officer?
24 BY MR. HARRIS:
25
A. By the person that --like ifyou cheat on
25 Q. Yes.
3 4 (Pages 130 to 1 33}
http://ReachingForTheTippingPoint.net
Page 134 Page 136
1 A. I do; I'm a Scientologist.
1 had with Mr. Desmond. MeaningPatrick Desmond.


2 · Q.
Number 27; it says, "Never forget that you
2 A. He was very helpful, and he was an awesome

I
3 have the residents' lives in your hands, as well as the 3 student, so he will help me. At one time he was helping
4 lives they live after they leave here, and the lives of 4 me to furnish one of the apartments. Then about the
!
5 their families." Right?
5 games, he was very into basketball, so... And his
!
6 A. Right. 6 future, he wanted to go and be a fuefighter.


7 -
Q. What does-- what does that mean? I mean, 7 Q. Any other interaction that you remember with

I
8 what - what were you trying to tell the monitors to do? 8 him?

9 A. To clean up their rooiii, to make sure that they
9
A. Just daily things. Like just going and
I
10 cleaned up their rooiii, that they're brush their teeth,
10
talking with everybody else, you know.

11 you know, things that drug addicts sometimes forget out 11 Q. Do you remember whether or not he had any
12 there. When they are using.
12 rules violations or ethics violations?


13 Q. All right. Let's talk about Mr. Desmond
13
A. No. He was good.
14 specifically. 14 Q. Was he -- did you consider him to be a good
l
!
15
A. Okay. 15 student?
I
16
Q. Did you meet Patrick Desmond?
16 A. I did.

I
17 A. I did
17
Q. Did he do what you asked him to do?


18
Q. Did you meet his parents? 18 A. Yes.
19
A. I did
19 Q. Do you recall at the time that he was first
f
20 Q. When did you first meet his parents?
20 admitted what apartment he was in?
I
21 A. I tlUnk: tl1e first time that they came. 21 A. No.
22 Q. When they first came to the Narconon faci lity? 22 Q. Okay. Do you remember who v.ras with him,

23
A Yes.
23 what - who lived in that apartment?
I
24 Q. And you were at the Narconon facility?
24 A. No; because the first time that he would came
25 A. At the time, yes. The first time that they
25 in, he -Don was in charge of housing.
1
135

Page Page 137
"
1 1 Q. Any other -- any other things that you

came.
2
Q. And my understanding is that either Mr. or
2 remember about Patrick, or exchanges with him, anything
I
3 Mrs. Desmond ack -- asked to see housing? Were you
3
like that?
I
4 involved in that, -
4 A. Huh-uh (negative).


5 A. Yeah.
5
Q. When did you first leam of his death?

6 Q. -- did you hear that?
6
A. As soon as it happened. i
i
7 A. I wasn't.
7
Q. And how did you learn about that?

j
8 Q. Tell me about tl1e conversations that you had
8 A. Somebody called me.
I
9 with the Desmonds.
9
Q. Who is this -- who --who called you?
10 A. Don more than anybody. I-- I had- I met
10 A. I have no idea. I

11 her once, and then Patrick's sister and brother-in-law.
11 Q. And what was the conversation?
12 So, "How are you doing," you know. That was all .
12
A. That the mom bad decided to pull the plug.

t.
13 Q. Did you give them any kind of tour of the
13
Q. Okay. So you --the first- the first you

14 housing--
14
learned about Patrick, the situation where he had
I 15 A. No.
15
overdosed, was when be was actually in the hospital and
16 Q. -- facility? Did you have any conversations
16
they had decided to take him off life support?
I
17 \'l'ith them in any way about housing?
17 A. You said about the death. When I learn about

18 A. No.
18
the death.
1 9 Q. About their treatment?
19
Q. rm sorry, I- and I should have asked you a

20 A. No.
20 better question. I mean, when did you first learn that
21 Q. Just--
21 Patrick had overdosed?
22 A. I didn't.
22
A. At 3:00 in the morning.
23 Q. - "Hey, how you doing," that sort of thing?
23 Q. And who told you about that?
I
24 A. That's right.
24 A. Tracy.
i
25 Q. Tell me about any other interactions that you
25
Q. Tracy Stepler?
i
.. . • •
35 (Pages 134 to 137)
http://ReachingForTheTippingPoint.net
1
2
3
4
5
6
7
8
9
Page 13B Page
A. Yes. 1 administrator of the halfway house." Take a look at
Q. What did she tell you? 2 that, and let's talk about it for a second.
A. She said that she got a call from Northside 3 A. Okay.
Hospital saying that Patrick was there. 4 Q. Who is Marie Verges?
Q. What else? 5 A. I have no idea.
A. So I told her, I said, "Okay, I'm going to go 6 Q. Well, did you talk to anyone from the medical
and pick you up right now." So I went to pick her up 7 examiner's office?
and then we went by the apartment, so we were like 8 A. No. That I know of -- no.
"What --what happened?" So then we just went to the 9 Q. Do you have an administrator? or
hospital. 1 0 A. Huh-uh (negative).
Q. So you went and picked up Miss Stepler? 11 Q. It says in here that this person reported that
A. Yes. 12 he'd been a patient at the halfway house, and he'd been

Q. Miss Stepler works for Narconon? 1 3 there for one month, and he'd been suffering from heroin
A. Yes. 14 addiction.
Q. And Miss Stepler was the one that informed you 15 A. Yeah; I don't -- I don't know who that is.
that Pabickhad overdosed? 16 Q. So you don't have anybody that works for you
A. Yes. 17 named Marie Verges? ;
Q. And then you went and picked her up? 18 A. No, sir.
!
A. Yes. 19 Q. You -- did you -- and did you talk to -- ,
Q. And then you went to the apartment-- 2 0 A. Huh-uh (negative). (
A. Yes. 21 Q. - anyone from the ME's office?
Q. -- where Patrick was staying? 2 2 A. No. I
A. Yes. 2 3 Q. So you didn't say that?
Q. Did you talk to somebody there? 2 4 A. No.
A. Yes. 2 5 Q. After hls death, did you -- did you yourself

10
11
12
13
14
1 5
16
17
18
19
2C
21
22
23
24
25
1
2
3
4
5
6
7
8
9
10
11
12
13
1 4
15
16
17
18
Page
Q. Who?
A. There were -- Charles Tucker was there. I --
I -- you know, I-- I don't remember. I think it was
139
just hlm and somebody else, but I don't know who. And
then we just raced to the hospital.
Q. Did you ask them what bad happened?
A. I did. But then I just --like I said, I just
rushed to the hospital.
Q. Did you- did you say anything to them along
the lines of ''Don't talk to anybody about this"?
A. Huh-uh (negative).
MR. HARRIS: I don't know what I've done
with them.
(Discussion off the record.)
(Thereupon, marked for identification
purposes, Plaintiffs' Exhibit No. 16.)
BY MR. HARRIS:
1
2
3
4
5
6
7
8
.9
10
Page 141
look into the circumstances of why he died, interview :
people, do any kind of investigation at all? i
A. I did.
Q. Whatdidyoudo?
A. I went and checked with the monitors, what I
happened, to - for them to tell me what happened.
Q. And what did- who did you talk to, and what I
did they tell you? I
A. I talked to Charles, and he said that -- that 1
he v...as told that he walked out Of the - the I
11 apartments.
J
I
i

I
12 Q. All right. Anything else that you ·learned
13 when you looked into what happened?
14 A. Same thing from everybody; that he just left
15 the -- the apartments.
16 Q. Did you look to - did you ask anypne \vhether
1 7 or not there had been the consumption of alcohol on the '

Q. This is a copy of the medical examiner's 18 premises at -- at the Delgado re -residences that --

2
1
0
9 rreport. I've markedpit as.Plaintiffs' 16, d
2
19
0
AQ. An i didd. h d'd th ll ?
ve put two -- two ost-1t notes on ere, JUSt to . w at 1 ey te you.
21 of direct you where I want-- 21 A. That -no.
2 2 A. Okay. 2 2 Q. So everyone told you that no one was drinking?
2 3 Q. -want you to go. 2 3 A. Right
2 4 On Bates 00520, there's a- a portion in the 2 4 Q. Did you administer any sort of test to any of
2 5 ME repmt that says "Phone contact with Marie Verges, 2 5 the folks who were his roommates?
• •
36 (Pages 1 38 to 141)
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Page 142 Page
144 ~
1 A. I couldn't tell you. 1
Q. --tight? Making sure that they didn't leave
'
~
2
Q. Going back to that report, I meant to ask you 2 the premises without permission? ~
3 this. Trisbaw Buice, B-U-I-C-E; do you know who that 3 A. We couldn't hold them physically, so if ~
4 is? 4 they - they were grown adults, they could walk out,
..
.,
~
5 MR. HYNES: Is that the second tab? 5
so--
>.
6 Here?
6
Q. What--
~
t 7 MR: HARRIS: No, it's later, it's a 7 A. -- we had to talk to them about not leaving,
8 name, it says -- I'll show it to you. 8 but that's about it that we could do. I
~
9 THE WITNESS: Where? 9
Q. Okay. Well, so you had a-- you had a-- a ~
.,
10 BY MR. HARRIS: 10 curfew, though, that was in place, right?
j
1
11
Q. Right here; it says Trish -- Trishaw Buice? 11 A. Yes.
i
12
A. I don't know who that is. 12
Q. And the monitors were supposed to make sure
'
13
Q. Okay, that's my question. Do you have any 13 that people didn't leave the premises, and if they did,
~
14 idea who that is? 14 we'll talk about that in a minute, but that was one of ~
15 A. (Witness shakes head negatively.) 15 their jobs?
I
16
Q. That's not somebody who works for you? 16
A. Right.
17 A. No, sir. 1 7
Q. And if they did leave the premise, it would be
£
18 Q. The Georgia Addiction-- GACA, G-A-C-A, is 18 a violation of the rules?
~
19 that what you were refen ing to earlier? 19 A. Yes.
l
20 A. No; it was GARR.
20
Q. And the rule violation would be reported to
I
21 Q. Georgia Association of Recovery Residences; is 21 Narconon?
I
22 that right? 22 A. Yes.
~
23
A. I think.
23
Q. And then Narconon could enforce the mles
I 24 Q. Did you ever get any certification from GARR? 24 however it wanted, right?
25 A. No. I wa -- I had to put -- I was worldng on
2 5
A. No.
~
~
~
Page 143 Page
145 ~
a checklist that they tra --was training -- were
1 Well, let me ask it a different way. You had
1
1 Q.
~
2 training us on.
2 the ability to enforce rules if the rules were broken at
5
~
~
3
Q. After Mr. Desmond's death, was there any
3 Delgado?
3.
'
4
change or -- any kind of change to the policies or
4
A. Yes.
5 procedures at Delgado Development?
5 Q. And Narconon also had the ability to impose
6 MR. HYNES: Object to the form. You can
6 conditions or do whatever it wanted to do if the rules
I
7
answer it.
7 were broken at Delgado?
~
8 Tiffi WITNESS: Yes; more monitorS.
8
A. Yes.
I
9 BYMR. HARRIS:
9 Q. Why did you feel like you needed more monitors
10 Q. Tell me about it; what did-- what did you do?
10 after Mr. Desmond's death?
11
A. We just put more monitors during the night.
11
A. Patrick and -- and a lot of other students ~
~
12 Q. And just so I'm clear about that, the - the
12
were like my kids. So just like I would do with my
"
J
1 3 monitor's job was basically to go arm.md to each
1 3 kids, if they trip I try to remove the stuff that would
I
1 4 apartment, right?
14 trip them so that it won't happen again, so.. . It was
~
15 A. Right.
15
very emotional for me. And physically, yes, it kill me,
~
16 Q. Make sure everybody was in there?
16 almost, for a whole year. So I wanted to do the best
17 A. Right.
17
that I could. And better. For them.
18
Q. Make sure nobody was drinking?
18 Q. And how many more monitors did you hire?
19 A Right.
19 A. We didn't hire more, we j ust put more in
~
$
20 Q. Doing drugs, right?
20 the -- of the ones that we had.
~ .
~
21
A. Yes. Yes.
21 Q. Okay. When Patrick came back in the month or
I
22 Q. Having visitors of the opposite sex?
22
so before his death, was -- was he working at Delgado
~
!
23 A. Right.
23 Development as a monitor?
~
24 Q. Which was forbidden, -
24 A. When?
25
A. Right
25
Q. When he came back the second time.
37 (Pages 1 42 to 145)
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Page 146
1 A. No. 1
2 · Q. He didn't have any kind of job 2
3 responsibilities at all? 3
4 A. No. 4
5 Q. Do you recall when he came back the second 5
6 time, what apartment he was in? 6
7 A. Z -- no; I know where it is, but I don't know 7
8 the name -- the munber. 8
9 Q. It was in one of the Z units? 9
10 A. Yes. 10
1 1 Q. Do you-- was he paid in any wayby Delgado 11
12 Development for that month period or so that -- that he 12
13 was there before his death? 13
14 A. No. 14
15 Q. TI1e flies for the students at Narconon, does 15
16 Delgado Development get copies of any portions of the 16
17 files? 17
1 8 A. No. 18
1 9 Q. The intake forms, anything like that? 19
2 0 A. Huh-uh (negative). 2 0
21 Q. So there's nothing in the file ofNarconon of 21
2 2 Georgia for the students who -- who are treating there 2 2
2 3 who go over and stay at Delgado, there is nothing that's 2 3
2 4 in that file that is given to De1gado Development? 2 4
2 5 :tviR. HYNES: Object to the form. 2 5
Page 147
1 THE WITNESS: No.
2 BY :MR. HARRIS:
3 Q. Well, let's talk about the presCiiption stuff
4 that you and I talked about earlier. If there's a
5 student who needs prescriptions over at Narconon and he
6 needs to take them while he's also at Delgado, wasn't
7 there some documentation that went back and forth
8 between the two entities?
9 A. Johnny would get it.
1 0 Q. The van driver?
:).1 A. Uh-huh (affinnative).
1 2 Q. And he just --how did he learn what the
13 students' requirements were?
14 A. Because the doctor will give hin1 the pills,
15 and, you know, the prescription would be on the--
16 the-- on the bottle.
17 (Discussion off the record.)
18 THE VIDEOGRAPHER: Do you want to go off
:. 9 the video?
2 0 MR. HARRIS: Yeah, let's go off the
21 video for just a second.
2 2 1HE VIDEOGRAPHER: We're going off the
2 3 video record at 1:54.
24 (Recess at 1:54, resumed at 2:04.)
2 5 (Thereupon, marked for identification
1
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Page 148 s

purposes, Plaintiffs' Exhibit No. 17.)
THE VIDEOGRAPHER: Stand by. We're back
on the record at 2:04.
BY MR. HARRIS:
Q. Just so you know, the end is near. I just
wanted you to -- I mean. l've got --
A. It will be all right.
Q. -- one more topic, so ...
A. Okay.
Q. All right.
MR. HYNES: Wait. One more topic can
mean lots of questions, --
MR. HARRIS: Yeah, topics.
MR. HYNES: - so don't...
MR. HARRIS: I may bounce around, just
clean up a few things.
BY MR HARRIS:
I
I
I
I

I

I
I
i
I

Q. After the death ofPatric.k, did you - did you
speak with anyone from Narconon International about what

happened?
A. Huh-uh (negative). No. I
Q. Did you speak with anyone from Narconon of
Georgia?
A. Idid.
Q. You talked to Mary Rieser?
A. Uh-huh (affirmative).
Q. And what did you tell Mary?
A. What has hap -- what bad I called
her that night Of the -- of her -- of-- of him being
in the hospital. And told him that -- told her that he
was in the hospital. You mean after?
Q. Well, let's -- let's focus on that
conversation; what else did you tell her?
A. Just that
Q. All right. Any-- did-- any -- any other
conversations that you had with Mary about Patrick's
death?
A. No. I was more at the apartments, because I
wanted the other students to be okay. You know, so I
didn't... That was like, okay. I couldn't do anything
about it anymore.
Q. Well, so you told me that you were upset about
this for a year? ..
A. Yes, I have.
Q. And you talked to Mary Rieser at Narconon on
the phone the night of Patrick's death?
A. Yes.
Q. And you never talked to her again about it?
A. I -- we did, probably, yeah.
Q. Okay. Well, that' s what I want to know; I
I



38 (Pages 1 46 to 149)
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Page 150
1 mean. what did you talk about?
2 · A.
About what happened, and... I mean, we did a
3 service at Narconon for him. Tiurt's what I remember.
4
Q. So you did a service for Patrick?
5 A. Yes.
6
Q. Any other conversations that you can recall
...,
'
between yourself and Ms. Rieser?
B A. Not really.
9 Q. Have you met \Vi.th anyone from Narconon in
10 connection v,•ith your deposition here today?
11
A. No.
12
Q. Have you met with any - anyone from Narconon
13 after the lawsuit in this case was filed?
14
A. No. I called Mary, I was like, "What the
15
heck?"
16 Q. And -- and tell me about that; what did --
17 what was the conversation?
18
A. Just -when I got the papers, or got - I got
19 service, I was like, "Ob, my God. What is this? I
20 didn't kill him."
2:.. Q. And what did you-- do you remember anything
22
about that conversation?
23 A. What I just said
24 Q. You just said "What the heck," and that's all
25 you can recall?
1
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Page 152
Q. What -- what- do you remember which students
we're talking about? I

A. I - I don't lmow who -- they're the ones that l
depose, but some of the students that were in the I
program.
Q. Any conversations with Narconon's lawyers? i
Either Narconon of Georgia or Narconon International? i
A. No. Her, right?
Q. Well, she's one of them; Ms. Whitlock?
A. No. I don't lmowher.
Q Well, have you - have you had a conversation
with who was legal counsel of any kind for either
Narconon of Georgia or --
A. No. t

Q. -- Narconon International?
A. No.
Q. All right. I'm going to band you what I've
marked as Plaintiffs' Exhibit No. 17.
A. Okay. I
MR HARRIS: I think I've only got one,
sorry.
MS. WHI1LOCK: We can share.
THE WITNESS: Ob, here. You can have
your 0\'1/D.
MR. HYNES: Looks like there's 1:\vo.
3




3

Page 151
1 A. Well, I -I told her, I said, "What the heck?
2 I didn't kill the guy," is what I said.
3 Q. And what did she say?
4 A. She said, "I know." I don't know if she got
5 service before me or not, but she said ... I don't even
6 remember what she said. I was freaking out.
7 Q. That's all you can remember about that one?
8 A. Yeah.
9 Q. Any other conversations with anyone from
10 Narconon of Georgia or Narconon af -- International
11 after the one you j ust told me about? Either in person
12 or on the phone.
13 A. One time I think that the attorneys needed
14 phone numbers for the -- for some of the students, so I
15 told Mazy the numbers of the students that I had on my
16 phone.
17 Q. So Mary called you--
16 A. (Witness nods head affirmatively.)
19 Q. -- and asked for phone numbers --
20 A. Yes.
21 Q. -- for some ofthe students?
22 A. Yes.
2 3 Q. Are those the same phone numbers that you've
2 4 given me today?
25 A. No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
MR. HARRIS: Oh, is there? Okay.
MR. HYNES: I'll --I'll look on with
her. Oh, yeah, that's fme.
Page
I can see it from back here; you make it
so you can see it -
THE WITNESS: Okay.
MR. HYNES: --comfortably.
BY MR. HARRIS:
Q. Do you recognize these documents?
A. Uh-huh (affirmative).
Q. What are they?
A. Knowledge reports.
Q. What's a knowledge report?
A. It's a violation of some rules, a rule.
Q. Why did you do knowledge reports?
A So that they - the students can get
corrected.
Q. "Corrected" meaning what?
153 i
A. Educated or whatever; like this one, caught on
I don't know what, I guess they went to the girls'
apartment, so ...
Q. Okay. You're talking about the first one? --
A. Yes.
Q. - 1-7-08?
39 (Pages 150 to 153)
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Page 154 Page
156 i
'
1 Q. And Aaron Anderson, who is he? 1
A. Uh-huh (affirmative).
t


2 A. He's one of the super-- monitors. 2 Q. The second KR, on 1-8-08, says that Charles

3
Q. And who does he work for? 3 found some -- I guess it was a 24-pack of beer in
4
A. Me. 4
somebody's room?


5 Q. And did he attend Narconon of Georgia at some 5 MR. HYNES: Can you give us the page I
6 point? 6 number? She's looking --
I
· 7
A. He did. 7 THE WITNESS: This one?
Jl

8
Q. Did he work for Narconon of Georgia at some 8
MR. HYNES: Is that it?
i
9 point? 9 MR. HARRIS: It's the second --
::1
I
10 MS. WHI1LOCK: Objecttothe form. 10 THE WITNESS: Yeah.
I
11 THE WI1NESS: At some point. 11
MR. HARRIS: - one; it's dated 1-8 --
12 BY MR. HARRIS: 12
THE WITNESS: Yeah.
i
13
Q. Do you know when? 1 3
MR. HARRIS: ---08.
i
14
A. No. 14
THE WITNESS: This.
1

15 Q. All right. And I'm not going to go through 15
MR. HYNES: Okay. You started at that,
.•
16 eve1y one of these, but I j ust want to kind of go 16 I got you.
i
17 through the process. Basically, if somebody violates 17
MR. HARRIS: Yeah.


18 the rules, then Delgado Development wrote a knowledge 18 MR. HYNES: Second sentence.
i
I
19 report? 19 MR. HARRIS: Yeah.
J
20 A. Yes. 20
THE WITNESS: Oh. What did you say?
21
Q. Sent it over to Narconon of Georgia? . 21 BY MR. HARRIS:
l
22
A. Yes. 22
Q. And I just -the second --
' !
23 Q. And actually on the - I think on the third 23
MR. HYNES: He started there, at the i
}
24 one, third one here, it says "E/0"; that's--
' 24
second sentence.
,,
25 A. Yes. 25 THE WI'INESS: Oh, all right. Okay.


Page 155 Page
1571
1 Q. -- ethics officer, correct?
1 BY MR. HARRIS:
2 A. Yes.
2
Q. All right. So this is a knowledge report that
l

3 Q. And then it was also given to other people;
3
talks about beer on the premises?

4 "Transport"? In this case, I guess the van driver got
4 A. Uh-huh (affirmative).

5 it?
5 Q. What was done by Delgado Development in
'
6 A. He was the one that wrote it.
6
response to this knowledge report?
7 Q. Right. Well, then why would he give it to
7 A. We of course took the beer away, and I don't
8 himself?
8
know what was on to this exact report, but then we would
g

9 A. He didn't give it to himself. He wrote it.
9
make sure that -- probably they searched the apartment
I
10 Q. Is that -- is that -
io
to make sure that there was no more beer, and then watch

11
A. I--
11 the guy so that he could be corrected at N arconon.
l 12 Q. -- what that means?
12
Q. All right.
,
13 A. Yes.
13
A. Or taught, or whatever.


1 4 Q. Okay. So-- so every one of these, then, goes
14
Q. All right. And then let's go to the one

f
15 to the ethics officer?
15
that's on 2-7-08.
I
16 A. Yes.
16
MS. WHITLOCK: That's the date, not the
17 Q. And then the pe.rson underneath that line is
17
Bates number, right?
I
18 the person who wrote it?
18
MR. HARRIS: Right.

19 A. Yes.
19 BYMR HARRIS:
20 Q. So in this case we know tbat Anthony Arnold
20
Q. 2-7-08; it's the top right comer of the KR.
1

21 then would have been the van driver?
21 You see that one?
i
i
22 A. Yes.
22
A. Yes.

23 Q. And he wrote a knowledge repmt?
23
Q. All right. And tlUrt's a report that someone

l
2 4 A. Yes.
24
had come in last night drinking at 3:30 a.m.?


Got you. All right, thank you.
25
Uh-huh ( affinnative ).
.
25
Q.
A
i
.. .. . ' . -' •
40 (Pages 154 to 157)
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Page 158 Page
160
1 Q. And- and then missed the van pickup at 9:00? 1 answer.
I
2 A. Yes.
2 THE WITNESS: Sometimes, like that KR, I

3 Q. And then Ms. Toth generates a report?
3
don't know if it was \vhen the guy came back
I
4 A. Yes.
4
from an LOA, right? And then we drug test
5
Q. And, I'm sorry, who was Ms. Toth, again? 5 him and he failed.
I
6 A. She drove for me.
6
BY :MR. HARRIS:
7
Q. So she was an employee of Delgado Development? 7
Q. Okay.
8 A. Yes.
8 A. So he could have done it at home, you know?
9 Q. And once again, she sends this to the ethics 9
Q. Right, l understand.

10 officer, up here in the top left comer?
10
A. So -- the beer, yes; we -- we would find it.

i
11 A. Yes. 11 They were drug addicts, we're trying to get them out of
I
12
Q. What was done in connection with that? Was 12 addiction, you know, by trying to not be so easy to get

13 the student suspended or punished in any way by Delgado 13
beer.
i
14 Development?·
14
Q. I understand, but my question was just, you-

1 5 A. I don't know. But-- I don't know. 15 you guys knew that students were doing drugs and alcohol
I
16 Q. Next page, 2-7-08, says, "Failed for benzos"? 16 on the premises in the year or so before Patrick's

17 A. Uh-huh (affirmative).
17
death?
I
1 8 Q. Who wrote that one?
18 MR. HYNES: Object to form. You can

1 9 A. I think that's my ex-husband.
19
answer.

:
20

20 Q. All right. So he sends - a student TilE WITNESS: Okay.
21 apparently failed their drug test because they'd been
21
MS. WHITLOCK: Object to the form. I
22 taking benzos?
22
Tiffi WTINESS: Okay. Yes.
I
23 A. Uh-huh (affirmative).
23
BY MR. HARRIS:
i
24 Q. And. that was sent to the ethics officer at 24
Q. "Yes." So what did Delgado Development do, if
}

25 Narconon?
25
anything, in order to try to address that issue?

Page 159 Page l61
1 A. Uh-huh (affirmative). 1 A. You know, make sw·e that the monitors were
I
2 (Discussion off the record.) 2
going, putting more policies in, or - or going more
I 3 BY MR. HARRIS: 3 rounds. Like it says on the -- on the monitors'
4
Q. All right. rm not going to - I don't want 4 write -- write-up.
i
5 to go through every one of these things with you, but 5
Q. Okay. So you-- you -- you made the monitors
I
i
6 there -- there are a number of reports, KRs, here, that 6 do more rounds?

7 were generated by staff employed by Delgado Development, 7 A. Uh-huh (affirmative).
8 that indicate that students are either drinking or using 3 Q. Were you -- did -- I tb.hlk I asked you this I

9 drugs on the premise, right? 9
before, but Mr. Onnsby's heroin overdose; do you recall

'
1 0
A. Uh-huh (affirmative). 10 that?
I
1 1 Q. And so you -- in the year or so, or the time 11
A. No.


12 before Patrick's death, folks at Delgado Development 12 Q. Do you recall any other overdose at all? f
13 certainly were on notice from these KRs that students 13 A. No. I
1 4 were doing that. Fair?
14
Q. So you increased the -- the rounds of the


15 MR. HYNES: Object to the form. You c.an 15 monitors; what else?

16 answer it. 16 A. We also increased the - the Breathalyzers and
i

17 THE WITNESS: I didn't understand the 1 7 the drug testing.
I
18 question.
18
Q. All right. And if someone was drug tested and

1 9 BY MR. HARRIS: 19 failed the drug test, would there have been a KR written


20 Q. Well, I mean, you- the folks at Delgado 20 on that?
E
§
21 Development certainly knew that in the -- in the year 21
A. Yes. I
22 before Patrick's death, 'cause this starts on 1-7-08, 22 Q. Or would --
I 23 that-- that students at the housing division were using 23 A. And the drug test would be sent to Narconon.
24
drugs and alcohol?
24 Q. Is there -- excuse me, is there a KR also, or I
..
25 MR. HYNES: Object to the fonn; you can 25
do you just send the drug test? I mean, that's -- is

• • • ... • ..
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Page 162
that the way you let them know?
A. Yeah, pretty much.
Q. Okay. So if someone fails a drug test, then
you don't necessarily do a KR, you just send the test
over?
A. Right.
Q. So there may well be instances where people
were failing dtug tests at Delgado Development that
aren't reflected in the KRs?
A. Yes.
Q. Do you lmow how many times that happened?
A. No.
Q. The drug tests that -- let's assume in the
1
2
3
4
5
6
7
8
9
10
11
12
13
year before Patrick's death there were people who failed 14
drug tests.
A. Uh-huh (affirmative).
Q. You would send the chug test repott , I assume,
over to Narconon?
A. Right.
Q. You actually -- when I say "report," when you
did the dtug test you actually were doing-- were you
doing ones that had to be sent off to a lab?
A. No.
Q. So you were doing just kits on site?
A. Yes.
Page 163
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Page 164
I
flunked dtug tests?
A. I don't know.

¥.
Q. And then-I'm almost done--just a couple
questions about Patrick. !
The -- did Narconon infonn you that Patrick l
had been ordered by the drug court in Florida to attend I
drug and alcohol rehabilitation? !
§
A. At some point, yes.
Q. How did they do that?

A. Actually, they didn't tell me. I found out
from hearsay, because, like I told you, Patrick, first j
time, was with Don. Don was the one in charge of
h_ousing the first time.
Q. Well, when he returned the second time, were
you aware of the fact that he had been ordered to return
to Narconon by the drug colU't?
A. I don't remember.
Q. Did you know that he'd been ordered by the i
drug comt to attend residential rehabilitation --
A. I know now, -- I
Q. - counseling?
A. -- but I don't know at what point I learn
about that
Q. Okay. And-- and that's what I'm trying to I
get to. Before he died, do you know whether or not !
Page 165 i

:.. Q. And then you'd send the kit over? 1 anybody from Narconon told you that Patrick Desmond had 1
2 A. Yes. 2 been ordere_d by the drug court in Florida to attend !
3 Q. To - to the ethics officer? 3 residential rehab drug and alcohol counseling? 1
4 A. Yes. To Larry. 4 A. I don't know. I don't know the timing.
5 Q. And do you have any record of that? 5 Q. How many -- do -- do you lmow how many of the
6 A No. 6 students who were housed over at Delgado Development I
7 Q. So if we want to know how many people failed 7 were actually there pursuant to some kind of court I
8 drug tests at Delgado Development in the year before 8 order? i
9 Patrick's death. how would we find that out? 9 A. How many? j
10 A. You will ask Narconon, I guess. 1 0 Q. Yeah.
of Development didn't keep any record did __ did Narconon give you I
13 A. No. 1 3 any kind of records that let you know that, ''Hey, this ,I
14 Q. You didn't try to compile the nwnber of people 1 4. guy is ordered to be here by a court, and this guy is ·
15 who were flunking drug tests so you can decide whethe.r 1 5 here voluntarily"? I
16 or not you might need to do something about it? 1 6 A. We talked to the parents. So Narconon had I
17 A. I-- I --I just knew, I guess. I -- I didn't 1 7 nothing to do with us and their parents signing the
1
1
9
8 keep it, though. No, I didn't.
1
18
9
contract, you know?
Q. Youjustknewwhat? Q. No-- •
2 0 A. I knew- like -- like I told you, I -- they 2 0 A. So it was like "This is the housing part of
21 were like my kids. You know. So I knowthatmykids 21 where he's going to stay." Sol -- Narconon didt1'thave

2 2 are going to do this or not. So I would keep an eye on 2 2 to tell me anything. lt was the parents that will
2 3 the students that weren't doing so good or not. 2 3 enroll them. Like you said, 1vfrs. Desmond wanted to tour
2 4 Q. Well, in the year before Patrick Desmond's 2 4 the place, so was dealing with Don at the time. I
2 5 death, how many students over at Delgado Development 2 5 Q. Okay. Well, so -- and that's my question, !
• . •. . • •
42 (Pages 162 to 165)
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Page 166
1 then. Do you -- did the -- did the Dcsmonds tell you
2 tl1at Mr. Patrick Desmond had been ordered to go there by
3 a court order?
4 A. Again, like not - Don was the one that was
5 the first time.
6 Q. Just ask Don, is what you're telling me,
7 right?
8 A. Yes.
9 Q. Got it. All right. Have you received any
1 0 documentation, or does Delgado have any documentation,
11 that says that - that pursuant to the drug court's
12 order in Florida, Delgado Development was allowed to
13 charge Patrick Desmond for residential rehabilitation
14 counseling of any kind?
15 MR. HYNES: Object to the form. You can
16 answer.
1 7 MS. WHITLOCK: Object to the form.
16 THE WITNESS: No.
19 BY MR. HARRIS:
2 0 Q. Any docwnentations that say, "The drug court
21 has ordered Patrick Desmond to go to Delgado Development
2 2 and be in residence there for drug and alcohol
2 3 counseling"?
2 4 A. rugbt, no. I didn't get anything from the
25 court--
Page 167
1 Q. You didn't get anything -
2 A. --the court date-- the court thing, no.
3 Q. All right. I think that's all I have; I
4 appreciate your time.
5 A. All right, sir.
6 Q. Thank you.
7 MR. TANNER: I don't have any questions.
8 MR.HYNES: Okay.
9 Tiffi VIDEOGRAPHER: Going off the video
1 o record at 2:23.
11 (Deposition concluded at 2:23 p.m.)
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168 ~
ERRATA SHEET
~
$
I, the undersigned, MARIA DELGADO, do
I
hereby certify that I have read the foregoing
j
deposition and that, to the best of my knowledge, said
I
deposition is true and accurate (with the exception of
the following corrections listed below.)
l
I
PAGE/LINE CORRECTION (and reason for correction)
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Notary Public Signature
Date i
My Commission Expires: I
~
~
~
Page 169 I
~
CERTIFICATE
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GEORGIA:
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FULTON COUNTY:
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I hereby certify that the foregoing I
deposition was taken down, as stated in the
I
caption. and the questions and the answers ij
thereto were reduced to printing under my
~
direction; that the preceding pages represent
~
a 1rue and correct transcript, to the best ~
of my ability, of the evidence given by said
I
witness upon said hearing. And I :further
I
certify that I am not of kin or counsel to
the patties to the case; am not in the regular
~
~
§
employ of cooosel for any of said parties; ~

nor am I in anywise interested in the result
~
of said case.
I
This, the 4th day ofNovember, 2011.
;;
~
~
I
I
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~
Jo TomoffFischer, RMR
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CCR No. B-924
~
~
Notary Commission Expires 8-25-2012
2
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