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IN THE STATE COURT OF DEKALB COUNTY
STATE OF OKLAHOMA
PATRICK C. DESMOND and MARY )
C. DESMOND, i nd i vi dua 11 y and )
MARY C. DESMOND, as )
administratrix of the Estate )
of Patrick W. Desmond, )
Plaintiffs ,
vs.
NARCONON OF GEORGIA, INC.
DELGADO DEVELOPMENT , INC.,
SOVEREIGN PLACE, LLC,
SOVEREIGN PLACE APARTMENT
MANAGEMENT, INC., LISA
CAROLINA ROBBINS, M.D., THE
ROBBINS GROUP, INC., and
NARCONON INTERNATIONAL,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
__________________________ )
Civil Action No.:
10A28641-2
Condensed &
Word Index
15 VIDEO DEPOSITION OF JETTE McGREGOR,
1
16 taken on behalf of the Plaintiffs, at 9:51 a.m., on
17 Friday, June 8, 2012, at the law offices of Holden
18 & Carr, 15 East 15th Street, Suite 3900, Tulsa,
19 Oklahoma, before Trisha G. Goodman, Certified
20 Shorthand Reporter in and for the State of
21 Oklahoma.
22
23
24
25
-
r
; , 1 r

'
l T , • .....
REPORTING, LLC- 918.749.5000
f.uG t
1
i\

Box 2823, Tulsa, Oklahoma 74101
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1 APPEARANCES:
2 For the Plaintiffs:
3 MR. JEFFREY R. HARRIS
Harris, Penn, Lowry, DelCampo, LLP
400 Colony Square
1201 Peachtree Street, NE, Suite 900
Atlanta, Georgia 30361
6 For the Defendant, Narconon of Georgia, I nc.
and Narconon International :
7
MS. BARBARA A. MARSCHALK
8 Drew, Eckl & Farnham, LLP
880 W. Peachtree Street
9 Atlanta, Georgia 30357
10 For the Defendant, Narconon International and
Jette McGregor:
11
MS. CHERYL H. SHAW
12 Carlock, Copeland & Stair, LLP
191 Peachtree Street, NE, Suite 3600
13 Atlanta, Georgia 30303-1740
14 For the Defendant, Delgado Development, Inc. :
[via telephone]
15
MR. CALVIN P. YAEGER
16 Downey & Cleveland, LLP
288 Washington Avenue NE
11 Marietta, Georgia 30060
18 ALSO PRESENT: Mr. Mike Ballard, Videographer
(918) 749-1661
19
20
21
22
23
24
'r-2f-
INDEX
2
3
1
4
THE VIDEOGRAPHER: We are on the record at
2 9:51. Go ahead.
3 JETTE McGREGOR,
4 having been duly sworn to tell the truth, the whole
5 t ruth and nothing but the truth, testified as
6 follows:
7 DIRECT EXAMINATION
8 BY MR. HARRIS:
9 MR. HARRIS: All right. This is will be
10 the deposition of Jette McGregor taken for all
11 purposes allowed by the Georgia Civil Pr actice Act.
12 All objections are reserved in accordance with the
13 Civil Practice Act and also in accordance with the
14 standing order regarding discovery.
15 Have you talked about reading and signing?
16 MS. SHAW: We' ll read and sign.
17 MR. HARRIS: Okay.
18
19
Q.
A.
20 a.
21 A.
22 Q.
23 before?
24 A.
25 a.
Good morning, Miss McGregor.
Good morning.
How are you?
I'm good.
Have you ever had your deposition taken
No.
All right. What's going to happen is, I'm
1 going to ask you questions, and this lady here is
5
2 WITNESS DIRECT CROSS REDIRECT RECROSS
2 going to type down our conversation. You need to
3 be kind of careful that you don't talk over me, and
4 I'll do the same with you. Otherwise, she's going
5 to get real frustrated and punch us at some point
6 during the deposition.
3 JETTE McGREGOR
4 BY MR. HARRIS 4
5
6
* * ****
7
EXHIBITS
8
NUMBER PAGE
9
16/12/08 report by Jette McGregor------
10
11 * * * * * *
12 Certified Question:
13 Page 18, Lines 15/16
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7 A. All right.
8 Q. And do exactly what you're doing now,
9 which is answer out loud, rather than shaking your
10 head, so we'll have a good, clean record about what
11 we talked about.
12 A. Okay,
13 a. Are you nervous about having your
14 deposition taken?
15 A. A little bit.
16 Q. Okay. Well, don't be. I hope it will go
17 relatively painlessly.
18
19
20
21
Tell me, where do you work?
A. I work at Narconon Arrowhead.
a. And back In 2008, it's my understanding
that you did an investigation into -- or at least
22 you came down and you looked at Narconon of
23 Georgia; is that correct?
24 A. Correct.
25 Q. When you came down and looked at Narconon
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6
1 of Georgia in 2008, who did you work for?
2 A. Narconon Arrowhead.
3 Q, Okay. Have you worked, at some point, for
Narconon International?
• A. Yes.
6 a. If you would, give me a little bit of the
7 background In terms of your employment with any
8 Narconon-related Institution.
9 A. Okay. So I worked with Narconon In Europe
10 from 1983 until 1987, late '87. In December '87, I
11 went to Los Angeles and started up Narconon
12 International, and I was there until1990 as the
13 director of Narconon International.
14 a. And you said you started Narconon
15 International?
16 A. Correct.
17 a. Tell me how you did that. What did you do
18 in order to start Narconon International?
19 A. I, you know, hired some personnel and got
20 the corporate thing going with getting the
21 corporation of Narconon International set up.
22 Q. Well, what was the -- what was the
23 hierarchy of Narconon at that point In time? How
24 was it structured? If there wasn't a Narconon
25 International at that point, how was it structured?
-
7
1 A. Yes. What there was, was an organization
2 called Social Coordination that was overseeing
3 several Social Betterment activities, and it was
4 basically split up to Narconon International and a
5 couple of other organizations.
6 Q. And were those organizations all under the
7 umbrella of ABLE?
8 A. Correct.
9 Q. Okay. And so then it was ABLE at the top,
10 and then Social Betterment below that?
11 A. Exactly.
12 a. And then what were the Social Betterment
13 organizations that were under Social Betterment?
14 Does that make sense?
15 A. Yes. Narconon International is considered
16 like a Social Betterment organization.
17 Q. I guess what I'm asking, was Criminon or
18 any of the other ones, were they under that, or was
19 it under ABLE at the time?
20
,
I
23
A. They were part of Social Coordination at
that time.
a. All right.
A. And then it moved to ABLE. And -- does
24 that make sense?
25 a. Not really.
8
1 But so, originally, it was my
2 understanding that the way that it originally was
3 set up was you had ABLE. Then below that, you had
4 each of the individual, what I think you've
5 referred to --
6
7
8
A.
a.
A.
Correct.
-- as Social Betterment institutions?
Yes.
9 a. Criminon, Applied Scholastics, Narconon,
10 and something else. I think it was the business
11 training entity. Is that not how It was set up?
12 A. Yes.
13 a. That's not how It was set up?
14 A. It is not exactly how it was set up at
15 that time.
16 Q. Explain to me exactly how it was set up at
17 that time.
18 A. At that time, you asked how it was
19 started.
20 a. Uh-huh.
21 A. We had an organization called Social
22 Coordination. That included all of those
23 activities you mentioned, Applied Scholastics,
24 Criminon, Narconon, and This is the Way to
25 Happiness. That organization turned into ABLE, and
9
1 then Narconon International, Applied Scholastics
2 International, Criminon International was set up
3 under ABLE right at that time.
4 Q. Right. Okay. Thank you very much.
5 A. Okay.
6 Q. Now, let's back up a little bit.
7 Are you a scientologist?
8 A. I am.
9 Q. And what level of Scientology have you
10 achieved?
11
12
13
14
A.
Q ,
A.
Q.
I am at a level called OT III.
OT III?
Uh-huh.
Okay. And you're a practicing
15 scientologist now?
16 A. Yes.
17 a. Is your husband Kent McGregor?
18 A. Yes.
19 Q, At some point in time, Kent McGregor was
20 listed as the clinical director for Narconon of
21 Georgia. Were you aware of that?
22 A. No.
23 a. Has Clint -- excuse me, Kent McGregor, has
24 he ever resided In Georgia?
25 A. No.
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MS. MARSCHALK: Hey, Jeff, can we go off
2 the record for a second? We forgot about Delgado's
3 attorney.
MR. HARRIS: That's probably a problem.
" MS. MARSCHALK: They said they're going to
6 call in.
7 THE VIDEOGRAPHER: Stand by, please.
8 We're off the record.
9 (WHEREUPON, a discussion takes place off the
10 record.)
11 THE VIDEOGRAPHER: Back on the record at
12 9:59. Go ahead.
13 By Mr. Harris:
14 Q. We were talking about your husband Kent.
15 A. Yes.
16
17
18
19
20
Q.
A.
Q.
A.
Q.
What is his job title currently?
He doesn't work for Narconon.
When did he leave Narconon?
As an employee, in 1994.
Okay. Was there-- you said as an
21 employee. Did he have some other role, or did he
22 work for Narconon in some other capacity?
23
24
A.
Q.
He's done some consulting for Narconon.
What kind of consulting?
25
f-
A. He's helped with licensing, certification
11
1 of staff, certification of centers, and he's helped
2 on insurance lines with Narconon Arrowhead and
3 still is.
4 Q. Okay. So he still works in some
5 consulting capacity with Arrowhead?
6 A. Correct.
7 Q. The things that you just outlined for me,
8 is that what he's currently doing?
9 A. Currently, he's helping on insurance
10 lines.
11. Q.
Insurance lines?
12 A. Yeah, on doing evaluations and things of
13 the patients for the insurance companies.
14 Q. Okay. And I was asking you, has he ever,
15 at any point, lived in the State of Georgia?
16 A. As far as I know, not. I'll just say.
17 Q. Well, how long have you-all been married?
18
19
A.
Q.
We've been married since 1993.
All right. Since 1993, which -- and I'm
20 assuming you can keep up with him after that point
.
'
in time. Since 1993, has he ever lived in the
2 ~ State of Georgia?
23 A. As far as I know, no. There was a couple
24 of years where I was in Europe and he was here.
25 Q. Okay. Do you know anything about his
12
1 involvement as the clinical director of Narconon of
2 Georgia?
3 A. No, not specifically.
4 Q. What do you mean "not specifically"?
5 A. The only -- I know he was helping Narconon
6 Georgia with their licensing at a certain point. I
7 was not in the United States at the time, I was in
8 Europe.
9 Q. What do you know about that?
10 A. That's all I know.
11 Q. All right. Now, walk me through how you
12 first got involved with Narconon programs.
13 A. I was asked, in 1983, to help with Social
14 Coordination Europe. And there was some
15 reorganization going on, so I was asked to help.
16 And that's how I got started with it. And then I
17 never stopped because I like it, love it.
18 Q. Who asked you to help?
19 A. I'm a scientologist.
20 Q. Uh-huh.
21 A. And it was people who worked at Social
22 Coordination and worked at the church that asked me
23 to help at that time.
24 Q. Who were those people?
25 A. I can't remember their names, exactly who
13
1 they were.
2 Q, Okay. Nobody in particular that you can
3 think of that might have asked you to do that?
4 A. It was people who were in charge of Social
5 Coordination at the time.
6 Q. And I'm just asking you, who were those
7 people?
8 A. I don't understand exactly what you mean.
9 Like who they were?
10 Q. Do you remember a specific individual who
11 asked you to get involved in the Social Betterment
12 programs that ultimately resulted in you working
13 for Narconon?
14 A. I do not remember the name of that person,
15 no.
16 Q. Were you ever a member of Sea Org?
17 A. Yes.
18 Q. When were you there?
19 A. I was in the Sea Org from-- with ABLE
20 International from 1990 until '94.
21
22
23
24
25
Q .
A.
Q.
A.
Q.
And what was your posting at Sea Org?
I was the consultant for Narconon.
And did you have a rank?
No.
You never attained any kind of naval
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1 equivalent rank in Sea Org?
2 A. No.
3 Q. Did you sign a billion year contract?
Yes.
When did you leave the Sea Org?
1994.
14
6
7
A.
Q.
A.
Q. And what did you do after leaving Sea Org?
8 A. I was-- basically, I had some various
9 jobs, two jobs. I worked at the Longs Drug Store
10 for a while. Then I worked for the Pallas Home
11 Association (phonetic).
12 Q. Okay. And what-- how did you end up
13 going from Sea Org in '94 to the European
14 activities of Narconon?
16
1 you.
2 MS. SHAW: Okay. You can answer. I just
3 want to have a standing objection just so we're
4 aware that Miss McGregor Is here in her individual
5 capacity
1
not as any sort of corporate
6 representative on behalf of any Narconon entities.
7 With that
1
go right ahead.
8
9
A.
Q.
Can you ask the question again, please?
Yeah. Do you know -- let me just ask it
10 this way: On a lot of the public filings that I've
11 looked at, it suggests that Narconon Arrowhead is
12 owned and operated by International as opposed to
13 some of the other Narconons that are sort of
14 independent companies. And the reason I'm asking
15 A. I rejoined Narconon International or 15 this question is because I've looked at these
16 rejoined --yeah, I rejoined Narconon International 16 documents, and I'm asking you to try to help me
17 in the beginning of 2000. And then after four 17 understand that.
18 months there was-- they wanted me to go to Europe 18 A. Uh-huh.
19 and help the Narconon Europe office again. 19 Q. Do you know whether Narconon Arrowhead is
20 Q. "They" being the people -- 20 owned and operated and run by International, or
21
22
23
24
25
~
1
2
3
4
5
6
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8
9
A. Narconon International.
Q. All right. And your husband, was he in
Sea Org with you?
A. Yes.
Q. Did he attain any naval equivalent rank in
15
Sea Org?
A. No.
Q. Now, if you would, are you familiar with
how Narconon International was structured in 2007
and 2008?
A. Not exactly.
Q . Explain to me the relationship between
Narconon Arrowhead and Narconon International.
A. As far as I know, there's a weekly report
21 whether it's a separate company that's independent
22 from International?
23 A. It's a separate company.
24 Q. Okay. And the company that employs you or
25 employed you back in 2008 was Narconon Arrowhead?
17
Correct. 1
2
A.
Q. Okay. And that's the company that employs
3 you now?
4 A. Yes.
5 Q. All right. Who did you meet with before
6 the deposition today?
7 A. My attorney.
8 Q. Who is your attorney?
9 A. Cheryl.
10 that goes from the ED of Arrowhead to the 10 Q. Okay. This lady represents Narconon
11 operations secretary at Narconon International. 11 International. Do you believe that she's your
attorney? 12 There's weekly statistics that they report, you 12
13 know, numbers, how much-- how many students we 13 A. Yes.
14 have, how much income we have, things like that.
15
16
17
Q. I don't mean to cut you off, and we'll get
into a little bit more of that sort of detail. But
I was asking, Is Narconon Arrowhead owned by
18 International and run by International, or is
19 Arrowhead a separate entity?
20 MS. SHAW: Object to the form of the
:' question.
2.t: Q. She may do that every now and then. And
23 unless she instructs you not to answer the
24 question, it's for purposes of perfecting the
25 record. So if she does that, don't let it distract
14 Q. Okay. And you work for Narconon
15 Arrowhead?
16 A. I do.
17 Q. Did you meet with any other lawyers prior
18 to your deposition here today?
19 A. No.
20 Q. Tell me what you discussed.
21
22
23
A.
MS. SHAW: I'm going to --
1 can't say.
MS. SHAW: I'm representing this witness
24 for purposes of this deposition.
25 Q. When did this lawyer here first begin to
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1 represent you?
2 A. We talked for the first time a couple of
3 days ago.
, _ Q. Okay. Have you compensated her in any
way?
No. 6
7
A.
Q. When she contacted you, did she offer to
8 represent you?
9 A. Yes.
10 Q. She offered to represent you at this
11 deposition?
12 A. Uh-huh.
13 Q. Did you ask her to represent you?
14 A. No.
15 Q. Okay. I want to know What y'all talked
16 about in your meetings before the deposition today.
17 MS. SHAW: Well, I'm going to Instruct the
18 witness not to answer. I am the attorney for this
19 witness at this deposition, and any communications
20 that we have would be privileged.
21 Q. Okay. This lady has asserted a privilege
22 objection. She's basically instructed you not to
23 answer the question that I just asked you.
24
25
-
A. Uh-huh.
Q. Do you understand that?
1 A. I understand that.
2 Q. Are you going to follow her instruction
19
3 and not tell me what the conversation was that you
4 had with her prior to the deposition today?
5 A. Yes.
6 Q. Okay.
7 MR. HARRIS: Certify it right there, if
8 you would, for me.
9 Q. Did you meet with anybody else, besides
10 this lady? By "this lady," I'm referring to Miss
11 Shaw here.
12 A. Yeah. No.
13 Q, Did you meet with arwone in the
14 International or Arrowhead structure to discuss
15 your testimony here today?
16 A. No.
17 Q.
18 OSA?
19 A.
20 Q.
Anybody -- did you talk with anybody from
OSA?
Uh-huh. Do you know who OSA is?
7 A. No.
2... Q. You don't know who OSA is?
23 A. No.
24 Q. The term "OSA," the Office of Special
25 Affairs, --
20
1 A. Oh.
2 Q. - - your testimony is you do not know what
3 that institution is?
4 A. It's OSA.
5 Q. I ;m sorry. I thought that's what I said.
6 A. You sai d OAS.
7 Q. Okay. Well, just so the record's clear,
8 OSA. Are you familiar with that institution?
9
10
A.
Q.
I am.
And what is that institution?
11 A. It's an institution that's of the Church
12 of Scientology that takes care of the corporate and
13 l egal affairs.
14 Q. Did you meet with anyone from OSA to
15 discuss your testimony here today?
16 A. No.
17 Q. Old you meet with anyone from DSA to
18 discuss your testimony here today?
19 A. No.
20 Q. Do you know what DSA Is?
21
22
23
24
A.
Q.
A.
Q.
Director of Special Affairs.
Okay.
No.
So the only person that you've discussed
25 your testimony here --the testimony that you're
21
1 giving here today, the only person that you've
2 discussed that testimony with is Miss Shaw?
3 A. No.
4 Q. Okay. Who else?
5 A. I've talked to a lady called Helen.
6
7
8
Q.
A.
Q.
Helena?
Helena, yes. And a gentleman called Rick.
All right. Who is Rick?
9 A. Rick is, as far as I understand, an
10 attorney with the Narconon International.
11 Q. All right. Do you know anything more
12 about his name or anything about him that would
13 help me identify who that might be?
14 A. I honestly don't.
15 Q. When did you --
16
17
18
A.
Q.
A.
19 once.
20
21
Q.
A.
It was -- excuse me.
I'm sorry.
I talked to him on the phone, briefly,
Okay. And how did he identify himself?
I had talked to Helena before. She
22 identified herself as an attorney helping Narconon
23 International, and she just introduced Rick on a
24 conference call.
25 Q . How many calls did you have with Helena?
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Maybe four or five. 1
2
A.
Q. Okay. And how many calls did you have
3 with Rick?
' A.. One.
Q. And tell me everything that you discussed
6 with Helena and Rick on the telephone conference.
7 MS. SHAW: I'm also going to instruct the
8 witness not to answer that question.
9 MR. HARRIS: Who's Rick?
10 MS. SHAW: To be honest with you, I'm not
11 sure who Rick is. Obviously, Helena is --
12 THE WITNESS: He works with Helena.
13 MR. HARRIS: Okay.
14 MS. MARSCHALK: It's Helena's partner,
15 Jeff.
16 MR. HARRIS: That's not Rick.
17 MS. MARSCHALK: Rick Moxon, yeah, it is.
18 MR. HARRIS: Oh. Okay. Let's take a
19 little break.
20 THE VIDEOGRAPHER: Stand by, please.
21 We're off the record.
22 (WHEREUPON, a discussion takes place off the
23 record.)
24 THE VIDEOGRAPHER: Hold on. Back on the
25 record at 10:18. Go ahead.
r- ·
23
1 By Mr. Harris:
2 Q, We took a little break to discuss a couple
3 things amongst the lawyers.
4 A. Okay.
5 Q. Let me back up and cover a few things.
6 When you went down and visited Narconon of
7 Georgia in 2008, you were employed by Narconon
8 Arrowhead, correct?
9 A. Correct. Yes.
10 Q. Right.
11 When was the last time you were employed
12 by Narconon International?
13 A. It was in 2000.
14 Q. 2000?
15
16
A.
Q.
Yes.
Okay. So since the year 2000, you have
17 been employed by Narconon Arrowhead?
18 A. I was employed by Narconon Europe from
19 April 2000 until July 2004.
20 Q, Got it. All right. Since 2004 then,
;' you've been employed by Narconon Arrowhead?
2.:. A. Yes.
23 Q. And your salary was paid for by Narconon
24 Arrowhead?
25 A. Yes.
24
1 a. And when you were directed to come down to
2 Georgia to Inspect the facility or do whatever - -
3 we're going to talk about that in a minute, I'm
4 just generically talking about it.
5 A. Uh-huh.
6 Q. Who sent you? Who told you to go down
7 there and inspect the facility?
8 A. Yarko from Narconon International.
9 a. All right. Did Narconon International pay
10 you in any way for doing that inspection?
11 A. No.
12 a. That was just part of your job at Narconon
13 Arrowhead?
14 A. It was a help.
15 a. It was a help? Explain that to me. What
16 does that mean?
17 A. Narconon Arrowhead did not ask Narconon
18 International to compensate me for the three days
19 that I worked or helped Narconon International do
20 this inspection.
21 Q. So did you just do that gratuitously?
22
23
A.
Q.
Yes.
All right. And as we've discussed,
24 Narconon Arrowhead is a separate company from
25 Narconon International?
1
2
A.
a.
Correct.
Narconon Arrowhead is actually
3 incorporated, I think, in Oklahoma, is it not?
4 A. Yes.
25
5 a. And Narconon International is incorporated
6 in California?
7 A. Yes.
8 a. And who is the president of Narconon
9 Arrowhead?
10 A. We don't have a president. We have an
11 executive director.
12 a. All right. Who is the executive director?
13 A. Gary Smith.
14 a. And who is the executive director of
15 Narconon International?
16 A. Phil Hart.
17 a. All right. NoW
1
at some point prior to
18 your deposition here today, it's my understanding
19 that you've had, by my count, five separate
20 conversations with various people.
21 You had a meeting with Miss Shaw, correct?
22 A. Right.
23 Q. And then you had, I think you told me,
24 four conference calls with Helena. I always get
25 her name wrong, Corbin, I think.
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A. Uh-huh.
MS. MARSCHALK: Kobrin.
MR. HARRIS: Kobrin. Thank you, Barbara.
Q. And also, I believe counsel has identified
I
the other person as possibly being Kobrin's,
partner Mr. Moxon, Rick Moxon.
A. I knoW' him as Rick.
Q. Okay. You don't know if that's the person
or not, Rick?
A. I know Rick.
Q. Now, what I want to know is, I want to
know the substance of the conversations that you
had, not with Miss Shaw, we've already discussed
that issue, but I want to know about the telephone
conferences that you've had with Miss Kobrin and
this other fellow identified as Rick. I want you
to tell me what y'all talked about.
A. As far as I know, she's an attorney, and
that would be privileged, wouldn't it?
Q . Are you refusing to answer my question?
A. No, I'm not refusing. I'm trying to
understand.
Q, Well, whether or not something is or isn't
privileged Is a legal question.
A. Correct.
27
Q. And you, as I understand it, don't work
for Narconon International, you work for a separate
3 company called Narconon Arrowhead?
4 A. Correct.
5 Q. And you've already told me that's a
6 separate company and that you did your inspections
7 gratuitously.
8 A. Correct.
9 Q . Okay. And I want to know about-- your
10 testimony here today Is really about your
11 involvement in that inspection in 2008. You
12 understand that?
13
14
A.
Q.
Yes.
All right. I want to know about your
15 conversations with Miss Kobrin and Mr. Moxon on the
16 telephone.
17 A. Okay. Can you ask specific questions
18 or ...
19
20
2'
23
24
25
Q.
A.
Q.
A.
Q.
A.
Q.
Okay.
I don't remember exactly from--
When did they first contact -you?
They contacted me in January.
In January?
Uh-huh.
And what did they first-- what was the
28
1 purpose of first contacting you?
2 A. This deposition was first scheduled in
3 January.
4 Q. You said "they." In every one of these
5 telephone conversations --
6 A. I'm sorry. She.
7 Q. Okay. And I'm not trying to trick you. I
8 just need to know, was she on -- was he on j ust one
9 of the conversations?
10 A. Who?
11 Q, Mr. Rick.
12
13
A.
Q.
Yes.
Okay. And when was the one that Rick
14 talked to you on?
15 A. Three days ago.
16 Q. Is that the only time that you've
17 conversed with him?
18
19
A.
Q.
Yes.
All right. Let's go back to the January
20 conversation. What did Miss Kobrin tell you at
21 that point in time?
22 A. She told me that I had been called for a
23 deposition in this case.
24 Q, And what else?
25 A. As far as I remember, that's all in that
29
1 particular conversation.
2 Q. She just called you up and said, "You've
3 been called for a deposition"?
4 A. Let me correct this. Claudia from
5 Narconon International called me and said I had
6 been called for a deposition. Helena contacted me
7 and said she was --I don't remember what she --
8 how she-- I really don't remember how she-- like
9 I understood that she was Narconon's attorney, that
10 was my understanding. Whether she said that
11 exactly or not, I can't remember.
12 And I really don't remember what else we
13 talked about in that particular conversation. It
14 was short, that I had been called, and what the
15 case was, what it was about, and why I had been
16 called.
17 Q. Well, what did they tell you the case was
18 about?
19 A. That It was about tltis person who had been
20 a student at Narconon Georgia who had died.
21 Q. But you already knew about that because
22 you had come down to inspect the facility right
23
24
25
after his death?
A.
Q.
Yes.
All right. And again, I'm a little bit
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1 confused. The conversation that you're referring
2 to, Is that one that you had with Claudia or Is
3 that one that you had with Helena?
, ~ ~ A. Helena.
Q. What was the conversation that you had
6 with Claudia?
30
7 A. Claudia simply called me and said that I
8 was being called for a deposition.
9 Q. Did she tell you anything about the case?
10 A. Yeah, she said which case it was.
11 Q. Ali right. What else?
12 A. And then she put me in touch with Helena.
13 Q. Did you talk to Helena that same day?
14
15
A.
Q.
I can't remember.
Well, did you talk to -- tell me -- you
16 obviously talked to Helena at some point after
17 that?
Yes. 18
19
A.
Q. Tell me about that conversation. How did
20 it occur, and what did you discuss?
21 A. Not anything else but that-- In that
22 particular conversation, she explained me what a
23 deposition is, she told me what the case was about
24 and why I was called, because of the report that I
25 wrote, and that's all.
f-;-
1 Q. Okay. And this was a January
2 conversation?
3
4
A.
Q.
Yes.
All right. You had three other
5 conversations then with Helena, by my count; is
6 that correct?
7
8
A.
Q.
As far as I remember, yes.
Ali right. Let's talk about those, the
31
9 next one after January. What conversations did you
10 have, and what did you discuss?
11 A. We had one conversation, the deposition
12 was scheduled for some date in January, I don't
13 remember. And she called me the night before and
14 told me that the deposition had been put off, that
15 it was, you know, postponed. So that was one
16 conversation. That was really all. Then I spoke
17 to her about probably --
18 MS. MARSCHALK: Hey, Calvin?
19
20
'l
23
MR. YAGER: Yes?
MS. MARSCHALK: Mute your phone, bud.
MR. YAGER: What's that?
MS. MARSCHALK: Can you MUTE your phone?
MR. YAGER: Oh, yes. I thought it was.
24 All right. Here we go.
25 MS. MARSCHALK: All right.
1
2
3
A.
Q.
A.
32
About six days ago, I spoke to Helena.
All right. And what did she tell you?
She told me I was going to -- she told me
4 I was going to be contacted by Miss Shaw, and that
5 she was going to represent me in this case.
6 Q. So Miss Kobrin said Miss Shaw will be
7 contacting you and she will be representing you?
8 A. Right.
9 Q. All right. What else?
10 A. What else. She asked me If I had seen the
11 report, if I had, you know-- If I was familiar
12 with the report that I wrote, and I told her no.
13 Q. Had you not looked at the report when you
14 originally thought the deposition was going to take
15 place in January?
16
17
18
19
A. No.
Q. She didn't provide it to you then?
A.
Q.
No.
All right. So she asked you if you had
20 seen the report and you said no?
21
22
A. Right.
Q. What else?
23 A. And then she went over a few points In the
24 reports and asked me what -- there was a few things
25 she didn't quite understand in the report, and she
33
1 asked me to clarify them and, you know, asked me
2 how I would respond to a couple of questions about
3 the report.
4 Q. And what were those questions?
5 A. One was she wanted to know if I was -- if
6 I could explain the relationship between Narconon
7 and the Church of Scientology because she thought
8 you guys were going to ask that.
9 Q. Uh-huh.
10 A. And then there's a line in the report that
11 she didn't understand because I had not completed
12 the sentence, so that's understandable. What else.
13 She wanted to know If I understood the relationship
14 between Narconon centers and Narconon
15 International.
16 Q. All right. So the relationship between
17 Narconon and the Church of Scientol.ogy was one
18
19
20
21
22
topic--
A.
Q.
A.
Q.
Correct.
-- of discussion?
Uh-huh.
Another topic of discussion was the
23 relationship between the Individual Narconon
24 centers and Narconon International?
25 A. Correct.
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34
Okay. What else? 1
2
Q.
A. I don't remember anything else that we
3 discussed.
Q. How long did you-all talk?
_ A. Half an hour or so.
6 Q. All right. What did she say about the
7 relationship between the Church of Scientology and
8 Narconon?
9 A. She didn't say anything. She asked me
10 what-- how I would explain that.
11 Q. And what did you say to her?
12 A. I told her what-- you want to-know
13 exactly what I said?
14 Q. Yes, I want to know exactly what you said.
15 A. I said that Narconon was started in 1966
36
1 my understanding of that was, and I guess she
2 wanted • • I don't know, she wanted to-- I don't
3 know what she wanted to do.
4 Q. She wanted to see how you would handle
5 questions like that, correct?
6 A. Right.
7 Q, And she wanted you to be able to explain
8 the relationship between Scientology and Narconon?
9 MS. SHAW: Objection to the form of the
10 question.
11 Q. Is that what she wanted you to do?
12 A. I don't know.
13 Q. Okay. You said -- I interrupted you, I'm
14 sorry. But you were telling me that you explained
15 a little bit more to her about how you would
16 by a gentleman by the name of William Benitez, who 16 respond to that question.
17 was a heroin addict, and he read a book by L. Ron 17 A. Yes.
18 Hubbard, and he felt that it helped him. And then 18 Q. Tell me about that. What else did you
19 he asked Mr. Hubbard and he asked some 19 explain to her?
20 scientologists to help him get a drug treatment 20 A. I said that, you know, scientologists get
21 program going in the prison in Arizona, in the 21 involved with Narconon because of the connection
22 state prison. So then they started-- that's the 22 with L. Ron Hubbard and because they often get
23 birth of Narconon, based on L. Ron Hubbard's book. 23 involved in Social Betterment activities anyway and
24 And then as the. years have gone, it's been 24 they support it.
25 developed into a full, you know, rehab program with 25 Q. Did she encourage you in any way to
- ·
35 37
1 eight books based on the works of L. Ron Hubbard.
2 Q. But Miss Kobrin is intimately familiar
3 with all of that, right, so were you explaining to
4 her the history of Narconon and how it started?
5 A. I was explaining to her how I would answer
6 that question.
7 Q. All right. Did she give you any
8 criticisms, or pointers, or clarifications, or
9 things you ought to emphasize, anything of that
10 nature?
11
12
A.
Q,
No.
She just listened to you discuss the
13 history of
14 A. Yeah. She said, "That' s fine."
15 Q. All right. Okay. Anything else about the
16 relationship between Narconon and the Church of
17 Scientology that you and Miss Kobrin discussed?
18 A. I mean, we also, not discussed, that I
19 told her?
20
{
2 ...
23
24
25
Q.
A.
Q.
A.
Q.
A.
Yes, that you told her.
The scientologists involved with Narconon.
But she--
I'm one.
Right. But she knows that, too, right?
Yes, but I was·· she wanted to see what
1 disassociate Narconon from the Church of
2 Scientology?
3 A. No.
4 Q. All right. Anything else that you
5 discussed about the relationship between
6 scfentology and Narconon?
7 A. No.
8 Q. All right. And then you also --
9 apparently, she wanted to see how you would
10 respond, I think, to this question about the
11 relationship between the individual centers and
12 International?
13
14
A.
Q.
Uh·huh.
Tell me about that. What did she say to
15 you in that regard?
16 A. She didn't say anything again. She wanted
17 to know what my answer would be to that question.
18 Q. Well, you didn't know that that would be a
19 topic; did you?
20 A. No.
21 Q. I mean, before your deposition, you didn't
22 know that we might be asking you questions about
23 the relationship between the individual centers and
24 Narconon International, right?
25 A. I didn't think about it. I didn't think
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38 40
1 about any, what - - 1 with the report that y'all were discussing?
2 Q. But you didn't know that, did you? 2 A. No.
3 A. No. 3 Q. Well, how did you have a copy of it? I
Q. And that conversation occurred well before 4 thought you told me you didn't have a copy of it?
.... you met with Miss Shaw, right? 5 A • Miss Shaw gave it to me yesterday.
6 A. Yes. 6 Q. All right. Well, then how were you
7 Q. What else did she say about that? 7 talking about the report with Miss Kobrin on the
8 A. About what? 8 phone conversation?
9 Q. Miss Kobrin, what else did she say about 9 A. I suppose she had it.
10 questions that you might receive about the 10 Q. She didn't provide you with a copy of it?
11 relationship between Narconon International and the 11 A. No.
12 individual centers? 12 Q,
So she was reading you portions of the
13 A. She didn't say -- she just asked me how I 13 report and asking you how you would respond to it?
14 would respond to that question. She didn't say 14 A. She wasn't reading portions of the report,
15 anything. 15 no.
16
Q, Okay. And how would you respond? 16 Q. I'm confused. I thought you told me that
17 A. I would respond that It's hard for me to 17 there were some questions and clarifications about
18 know today because I haven't worked at Narconon 18 the report that she wanted to discuss with you.
19 International since the year 2000, and it was only 19 A. Is that what she -- yes. Correct.
20 for four months. So exactly how they operate 20 Q. So did she provide you with a copy of the
21 today, I have little knowledge about -- I work at 21 report in order to discuss it with you?
22 intake at Narconon Arrowhead, and I don't know much 22 A. No.
23 about exactly how Narconon operates currently. 23 Q. So was she reading the report to you over
24 Q. And Is that what you told her you would 24 the phone?
25 say?
f-
25 A. Yes. Parts of it.
39 41
1 A. Yes. 1 Q. The first time you've gotten a copy of the
2 Q. And what did she say In response? 2 report is when Miss Shaw gave it to you?
3 A. "Okay." 3 A. Yes.
4 Q. Did she suggest in any way that you should 4 Q. All right. I believe there are two more
5 emphasize or clarify or make any particular points 5 conversations that we haven't talked about with
6 about the relationship between the individual 6 Miss Kobrin, not Miss Shaw.
7 centers and International? 7 A. I --that conversation we just talked
8 A. No, she didn't. 8 about now is the only conversation of any length
9
Q,
Anything else that you discussed -- this 9 and any substance. The other one, there was one
10 was a 30-minute conversation? 10 conversation in January about, you know, where --
11 A. Approximately. I didn't look at the 11 what hotels to stay at, when it was going to be.
12 clock, but that's what I would estimate. 12 As far as discussing anything about the actual
13 Q. All right. Anything else that you 13 deposition, that's the only conversation where we
14 discussed in that conversation? 14 discussed that.
15 A. She explained me just what -- I've never 15 Q. Well, you had a conversation with Rick.
16 done anything like this before, deposition, 16 .A. Yes •
17 witness, nothi ng. So she explained me what a 17 Q. What was that conversation?
18 deposition is, how it would be set up, who would be 18 A. That was the same conversation.
19 there, it will be videoed, that there will be a 19
Q,
I'm sorry. I think you told me earlier in
20 r eporter; just basically, you know, brief me on 20 your deposition that the conversation with Rick
~
what a deposition is, what its purpose Is, and so 21 occurred about six days ago. .
2 ~ on. 22 A. Yes.
23 Q. Okay. Anything else? 23 Q. All right. And is that the same
24 A. No. 24 conversation that you had this 30-minute discussion
25 Q. You said that she -- did she provide you 25 about clarifications In your report?
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2
3
6
7
8
9
A. Yes. That's the same conversation.
a. So Mr. Moxon or Rick was on the
conversation with you when you went through the
report?
I
A. Correct.
a. And you still didn't have a copy of it at
that point In time?
A. No.
a. What did Mr. Rick say?
42
10 A. What did Mr. Rick say. Probably he said
11 SC)me of the things that Helena -- I mean, we were
12 all three talking.
13 a. Uh-huh.
14 A. Those were the topics. He may have asked
15 some of this, and Helena may have asked some of
16 that. It was like we were all in one conversation.
17
18
19
20
21
22
23
24
25
-
1
a. And do you know Rlck and do you know
Helena from past dealings?
A. · No.
a. First time you had ever talked with them
before?
A. Yes.
a. Did Rick suggest that you should respond
in a certain way to any of the questions that you
might be asked?
A. He said I should respond with just
43
2 succinct answers, not, you know, get into a lot of
3 things.
4 a. Was he the one that brought up this topic
5 about the relationship between Narconon and
6 Scientology?
7 A. I don't remember which one of them brought
8 that up.
9 a. Okay. Did they give you any sort of test
10 questions and say, "Okay, here's the question that
11 you're likely to be asked in this way, how would
12 you respond?"
13 A. Well, with those two, yes.
14 a. Those two topics --
15
16
17
18
19
20
?
2 ...
23
24
25
it?
A.
a.
A.
a.
A.
Q.
A.
Q.
A.
a.
Yes.
-- that we've been talking about?
Yes.
All right. Anything else?
No.
Did they record the conversation?
I don't know.
Did they tell you that they had recorded
No.
So other than your meeting with Miss Shaw,
44
1
2
3
did you have any other conversations with Miss
Kobrin or Mr. Rick?
A. Just the only other time I .talked to
4 Rick -- as I said, there's been a few times where I
5 talked to Helena about more like the logistics of
6 this, you know, when we're going to meet, like when
7 Miss Shaw was going to come ahead and meet with me.
8 She kind of coordinated things. So there's been a
9 couple of conversations like that.
10 a. And I'm just trying to figure out exactly
how many conversations took place and who was
involved.
11
12
13 A. I don't remember exactly how many times
14 I've been on the phone with Helena.
15 a. Okay.
16 A. I said about four. That's my guess.
17 Q. Could it have been more?
18 A. Could have been.
19 a. All right. But you only remember one
20 conversation with Rick?
21 A. Yes.
22 a. And that's the one that I think you said
23 was about six days ago?
24 A. Correct.
25 a. Anything else about that particular
1 conversation?
2
3
A.
a.
No.
Going back to something that you and I
4 talked about earlier. Has anybody else-- well,
5 let me ask you this: Has there been anybody who is
6 in -- you talked to me about the two lawyers, who
7 we're assuming is a lawyer, Rick and Helena.
8 A. Yes.
9 Q. Has there been anyone affiliated in any
10 way with the Church of Scientology that has prepped
11 you in any way for this deposition today?
12 A. No.
13 Q. Have you had any practice sessions with
14 anyone from the Church of Scientology or anyone
15 affiliated with the Church of Scientology about how
16 to respond to any of my questions here today?
17 A. No.
18 Q. Okay. You've had no contact wi th anyone
19 from OSA about your deposition?
20 A. No.
45
21 a. And you've had no contact with anyone from
22 DSA about your deposition?
23 A. No.
24 a. All right. Have we thoroughl y covered all
25 of the conversations that you've had with various
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3
6
lawyers prior to your deposition here today?
A. Yes.
Q. All right. Now, Miss Shaw gave you,
ultimately, a copy of the report, did she not?
A. Yes.
Q. All right. And let's talk about that.
7 How did you come to visit Narconon to inspect the
8 facilities?
9 A. I was asked by Yarko of Narconon
46
10 International to go do an inspection of Narconon
11 Georgia.
12 Q. And what is Yarko's last name? The reason
13 I'm asking is I can't ever figure it out.
14 A. It starts with M. I know that much.
15 Manzanares.
That's about as much as I know.
I don't know.
Where is he out of?
Narconon International.
I meant what city. Where is he located?
Los Angeles.
16
17
18
19
20
21
22
Q.
A.
Q.
A.
Q.
A.
Q. Tell me what Yarko told you he wanted you
23 to do.
24 A. He told me that there had been a very
25 traumatic-- a very traumatic thing happened in
1-
47
1 Narconon Georgia, that one of their students passed
2 away, and he wanted me to go and help the ED, help
3 the staff kind of try to, you know, uplift them,
4 and then he wanted me to do a technical inspection
5 of the center and how the program was administered.
6 Q. And did he tell you why he wanted you to
7 do that?
8 A. Not-- no.
9 Q. He just called· you up and said, "I want
10 you to go do a tech Inspection of the center"?
11 A. He said what had happened --
12 Q. Right.
13 A. --and that he wanted me to do an
14 inspection.
15 Q. Okay. And my follow-up question to that
16 would be: Did he tell you why he wanted you to do
17 this inspection?
18 A. Not other than that incident that happened
19 and he wanted me to do an inspection. He didn't
20 say "because."
"' I
Q, Well, did you have some -- did you have
2... some basis for knowing why he wanted you to do
23 that? Is It something that you had done before?
24 A. Inspections?
25 Q. Yes.
1 A.
48
I have done them as the ED of Narconon
2 Europe, the ED of Narconon International. I'm
3 familiar. I know how to do these.
4 Q. All right. So he tells you he wants you
5 to do this tech inspection?
6 A. Correct.
7 Q. Now, as a matter of routine, tech
8 inspections occur at various centers all the time,
9 right?
10 A. Correct.
11 a·. And how many times a year are centers
12 typically tech inspected?
13 A. I don't know currently.
14 Q. Have you ever been involved as one of the
15 tech inspectors for coming in ancj doing an
16 inspection of various centers? Has that ever been
17 yourjob?
18 A. When I was employed by them, yes.
19 Q, Tell me about that. When you were
20 employed by them, what was the procedure that you
21 would utilize for doing tech Inspections?
22 A. Can you clarify that a little bit?
23
24
25
Q.
A.
Q.
When you worked for INT --
Yes.
-- were you at any point charged with the
49
1 responsibility of doing tech inspections of
2 individual centers?
3 A. Yes.
4 Q. And that was part of your job duties at
5 INT?
6
7
A.
Q.
Correct.
Tell me about that. What did you do and
8 what was the process for inspecting the centers?
9 A. We have some checklists that goes over
10 various sections of the program. So we go to the
11 center and we go through the checklist and we check
12 very specific things In relationship to how is the
13 program being administered.
14 Q. What's the purpose of doing that?
15 A. The purpose is Narconon is like -- it's a
16 trademark; we want all the centers to service--
17 deliver the same service the same way, and at
18 certain standards that have to be met. And we
19 always work to get every center up to
1
you know,
20 the best standard possible.
21 Q. How often would you do tech inspections of
22 the various centers when you were at INT?
23 A. There's no exact answer to that. Random.
24 Q. So you would do random tech inspections?
25 A. Yes.
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1 Q. The tech inspection that you did, though,
2 was not -- because you were at Arrowhead, it was
3 not part of the INT program of regularly doing tech
inspections of the center; this was a separate sort
of inspection. Is that fair?
A. I don't know.
Q. You don't know what?
6
7
8 A. The question to your answer-- the answer
9 to your question, or maybe you can rephrase it a
10 little bit.
11 Q. I'll try.
12 A. Okay.
13 Q. When you were at INT, one of the things
14 that you were involved in doing was these random
15 tech inspections ofthe centers, right?
16 A. Yes.
17 Q. Okay. And but you did a tech inspection
18 of the Narconon Georgia center in 2008?
19 A. Correct.
20 Q. At that point in time, you worked for
21 Arrowhead?
22
23
A.
Q.
Yes.
So what I was getting at was the tech
24 inspection that you did in 2008, it was not part of
25 any sort of random tech inspection program that
.....
1 International would do on its centers, it was
2 separate and it was done for a different reason?
3 MS. SHAW: Object to the form of the
4 question.
5 A. I don't know.
6 Q. You don't know?
7 A. I don't know.
51
8 Q. You don't know why you did it? You did it
9 because Yarko called you up and said do it?
10 A. Exactly.
11 Q. Okay. So you don't know whether it was
12 part of some ongoing tech inspection sort of
13 program that INT was involved in?
14 A. No.
15
16
17
Q.
A.
Q.
All right. I understand.
Okay.
The tech inspection that you did in 2008,
18 was it essentially the same kind of inspection that
19 you would do when you were at INT when you were
20 doing these random inspections?
" ,
2 ...
A. Yes.
Q. And you had your inspection checklist?
23 A. Correct.
24 Q. Now, one of the things that-- before we
25 get into the specifics of this 2008 inspection,
52
1 what jobs at Narconon are you hatted in?
2 A. I am hatted in operati ons, which basically
3 means consulting, overseeing Narconon centers from
4 the continental office level and the INT management
5 level.
6 Q. Okay. And what many hats do you have?
1 A. I have -- how many hats do I have. It was
8 so long ago that I was at that level. I did
9 something called - - now the operations I had
10 before, the fall hat, there's many hats that's
11 called problems of work that I've done. And - -
12 Q . Are you hatted In any of the sales
13 techniques for delivering the program and selling
14 the program?
15 A. Yes.
16 Q. Okay. Which ones?
17 A. I have done half of the-- but this is
18 currently?
19 Q. Uh- huh.
20
21
A.
Q.
Now?
Now.
22 A. In my current position. At that time, no.
23 Now, yes, because I have -- I work in intake now.
24 Q, And what is the difference between intake
25 and being a reg?
1
2
3
A.
Q.
Same thing.
Same thing. Okay.
So as being an Intake, though, you're
4 hatted in ali of the sales hats and many hats,
5 right?
53
6 A. The truth is no. I haven't finished them.
7 Q. Are you hatted in something called
8 Overcoming the Brick Overcoat?
9 A. Yes.
10 Q. Tell me about that.
11 A. It's a chapter in a book that's written by
12 Les Dane.
13 Q. Big League Sales?
14
15
A.
Q.
Big League Sales. Yes.
Tell me about that hat. What was your
16 training in that regard?
17 A. I read a chapter.
18 Q . Of Big League Sales?
19
20
A.
Q.
Correct.
And one of the things that you're taught
21 in the mini hat for Overcoming the Brick Overcoat
22 is how to get -- or how to explain to people who
23 are trying to put their loved ones in Narconon
24 programs how to get bank loans to do that, right?
25 MS. SHAW: Object to the form of the
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54
1 question.
2 Q. Is that right?
3 No. A.
Q. Okay. That's not part of the mini hat for
~ Overcoming the Brick Overcoat?
6 A. No, not as far as I remember.
7 Q. All right.
8 A. How to get a bank loan? Is that what you
9 asked? How to get a bank loan?
10 Q. Yeah.
11 A. It may be somewhere in the book, but I
12 don't think it's in that particular •••
13 Q. In the mini hat checklist?
14 A. Yeah.
15 Q. Now, the way that the mini hats work is
16 there is a checklist for each one of those
17 positions, correct?
18 A. I don't know exactly what-- I don't know
19 of any mini hat for the area of intake.
20 Q. All right. Well, let's back up then.
21 A. Okay.
22 Q. In order to be hatted in certain
23 positions, you would agree with me that there is a
24 hatting checklist, correct?
25 A. Correct.
r-
55
1
Q , And the hatting checklist goes through
2 what you need to do in order to be hatted in that
3 position?
4 A. Yes.
5 Q. And those checklists are generic for all
6 centers, right?
7
8
A. Some of them. Not all.
Q. Okay. All right. Do you know which ones
9 are not generic for all of the centers?
10 A. Most of them-- there are certain hatting
56
1 Q. Okay.
2 A. In -- what I was trying to say is, there
3 are certain check sheets that are made up by
4 actually ABLE International and issued to the
5 centers. If I want to train or If we want to train
6 a person in, I don't know, something that's not
7 related to the program, we make up our own check
8 sheet; it doesn't come from anyone.
9 Q. Well, I guess -- and I appreciate the
10 clarification.
11 In terms of the delivery of the standard
12 tech,--
13 A. Yes.
14 Q. -- the delivery of the standard tech,
15 there are a number of generic hatted positions that
16 are called out in how to run an effective Narconon?
17 A. Correct.
18 Q. All of those generic hatted positions, all
19 of them have hatting checklists, do they not?
20 A. Every one of those books, running an
21 effec:tive Narconon, the ethics of the course, they
22 have checklists.
23 Q. So the reg has a checklist?
24 A. There is not a course issued by
25 International for reg.
1 Q. I understand what you're saying. But
2 there are courses that the regs are required to
3 take, particularly related to sales and finances
4 and all that sort of stuff, that there is a hatting
5 checklist for?
6 A. All I can speak for is stage one at
7 Narconon Arrowhead, I know that.
8 Q. Well, but isn't that part of what you're
9 doing when you're doing a tech inspection, is
57
10 making sure that the employees are properly hatted
11 actions, mostly concerned with the technical 11 in whatever their areas of expertise are?
12 delivery that are issued by ABLE International that 12 A. A tech inspection does not get into that
13 are for all the centers. The checklists for the 13 part of the administration. It more concentrates
14 hatting are usually created by each individual 14 on -- it does get into some of the administration,
15 center, at least that's what we do at Arrowhead.
16 Q. Okay. And is there a master template for
17 at least what technical skills you've got to
18 acquire in order to be hatted in something that's
19 provided by International to the individual
20 centers?
i A. Sir, I didn't understand that question.
2' Q. Well, the individual centers are not just
23 making up what you need to do in order to be hatted
24 in some specific area on their own, are they?
25 A. Yes.
15 but it more concentrates on what's actually being
16 done technically with the program.
17 Q. And just so we're all clear on this, by
18 the tech inspection, the technology is really the
19 materials that Mr. Hubbard wrote about how to
20 deliver the surface?
21 A. Mr. Hubbard did not write those materials.
22 Q. They're based on Mr. Husband's writings?
23 A. Correct. Yes.
24 Q. Now, tell me-- let's talk specifically
25 about the tech inspection that you did at··
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1 MS. SHAW: Jeff, before you get into that,
2 could we just take a quick break?
3 MR. HARRIS: Sure. Absolutely. I should
have told you that, If you need a break at any
~ time, just tell me.
6 THE WITNESS: Okay.
7 THE VIDEOGRAPHER: Stand by, please.
8 (WHEREUPON", a recess was taken.)
9 THE VIDEOGRAPHER: Back on the record at
10 11:07. Go ahead, please.
11 (Whereupon, Exhibit 1 was marked for
12 identification.)
13 By Mr. Harris:
14 Q. All right. Miss McGregor, I've put before
15 you what I've marked as Plaintiff's Exhibit No. 1
16 to your deposition.
17 A. Uh-huh. Okay.
18 Q. It's a composite exhibit, and I'm not
19 going to be talking to you, I hope, about a lot of
20 it. But I would like you to turn to the Bates
21
22
23
24
25
labeled page at the bottom. It's 9828. You can
see a little number there.
A. Got It,
Q.
A.
You've got that?
Yes.
-
1 Q. Now, this is a report from June 16th,
2 2008, which I believe was authored by you; is that
3 right?
4 A. Yes.
S Q. This is the report that I thi nk you
6 generated after you did your inspection of the
7 Georgia facility?
8 A. Yes.
59
9 Q. And I may have asked you this before, and
10 if so, I apologize. But had you ever-- had you
11 ever Inspected or visited the Georgia facility
12 before coming down In 2008 to do this report?
13 A. No.
14 Q. Never been there, never set foot in the
15 place?
16 A.
17 Q.
18 A.
19
20 answer.
23
Q.
A.
Q.
No.
Good. That saves us a lot of problems.
Okay.
MS. SHAW: I thought you would like that
Do you know Miss Reasor?
Yes.
Was she in Sea Org at the same time that
24 you were there?
25 A. No.
60
1 Q. All right. How do you know her?
2 A. I have met her at a couple of Narconon
3 conferences.
4
5
Q.
A.
Social friends?
Just -- I knew who she was because we have
6 a conference, and I've seen her and talked to her
7 maybe twice.
8 Q. And I understand there's an executive
9 director's conference, which occurs once a year?
10 A. Correct.
11 Q. Did you go to that, typically?
Sometimes. 12
13
A.
Q. And how did you decide when you got to go?
14 Seems like they're in pretty good locations, like
15 Mexico and places like that.
16 A. I changed my position. I used to go when
17 I was the director for Narconon Europe, and then I
18 went once when I came back here to United States,
19 and then I haven't gone since.
20 Q. Are there any other -- well, there's the
21 annual executive director's conference, correct?
22 A. Correct.
23 Q. Are there any other annual conferences
24 which take place?
25 A. I don't know.
1
2
3
4
5
Q.
A.
Q.
Any that you've attended, --
No.
-- other than t he executive director one?
A. No.
Q. Were there training materials that were
6 disseminated at those conferences?
61
7 A. There would be a folder with something in
8 it, agenda. Training materials? Not as far as I
9
10
remember.
Q. Well, you got a CD at the end of it,
11 right, with a video of what happened at the
12 conference?
13
14
A.
Q.
The last one, yes.
The one that you went to?
15 A. The one-- there was one in Phoenix that I
16 went to In, I don't know, 2005, I think, is the
17 last one.
18 Q. All right. Now, you explained to me that
19 Yarko contacts you and says he wants you to do this
20 tech inspection of the Georgia facility, right?
21 A. Right.
22 Q. And then you generated this debriefing
23 report?
24 A. Yes.
25 Q. At the top of the debriefing report there
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62 64
1 are -- there's some -- and I don't mean this in any 1 A. -- before I left.
2 way to be offensive at all, but I refer to it as 2 Q. Anybody else?
3 gibberish. 3 A. No.
A. I understand. 4 Q. And then I've noticed that you also-- I
~ a. And I've seen a lot of it in these 5 believe there was somebody else that you were
6 documents, and I'm going to have to ask you to 6 conversing with besides Yarko about your report.
7 interpret that for me a little bit. 7 Am I wrong?
8 Who are these people? And I guess the way 8 A. I don't think so.
9 that I understand this is, this -- it's the person 9 Q. Okay. All right. Well, that's fine.
10 who's writing it typically signs down here, and 10 A. Okay.
11 then the person It goes to is above it. 11 Q. So you give a copy to Mary?
12 A. Yes. 12 A. Yeah.
13 Q. Is that how it normally works? 13 Q. Now, teli me what you did when you - -
14 A. Yes. This is the originator; the bottom 14 well, let me back up.
15 line. 15 This copy that I have at 9828, which is
16 Q. And that's you? 16 your debrief, and then there is a follow-up email
17 A. That's me. That's who it goes to, and 17 the next day, which Is at 9832 of Exhibit No. 1.
18 this is who got a copy, cc, carbon copy. 18 Do you see that?
19 Q. All right. Now, you're the director-- 19 A. Yes.
20 and we're referring to 9828. 20 a. And in that document, you're clarifying a
21 You're the director of tech Narconon 21 couple of points in your report, right?
22 Arrowhead. Is that what that means? 22 A. Yes.
23 A. Yes. 23 Q. Are there any other reports of any kind
24 a. And then what is that in parentheses out 24 that you generated in connection with your
25 there next to that? What does that mean? 25 inspection of the Georgia facility?
f--
63 65
1 A. It means I'm in Narconon Georgia. My 1 A. No.
2 position is that -- 2 Q. There are a number of crams that you
3 a. I was over thinking it. 3 reference here that you have sent or that you
4 A. -- but I was actually in Narconon Georgia. 4 provided to Narconon Georgia. I don't have any
5 a. That's just where you were? 5 copies of those. Where did those crams go, and
6 A. Yes. 6 tell me about how that worked out?
7 Q. I thought "IN" meant something. 7 A. I wrote them, printed them out, and gave
8 A. No. 8 them to Mary. And then I sent, at least some of
9 Q. Okay. And then you cc'd it to the ED of 9 them, to Narconon International, together with
10 Narconon International? 10 my-- you know, my report.
11 A. Correct. 11 Q. Which ones did you send to Narconon
12 a. And who is that? 12 International?
13 A. Phil Hart. 13 A. The way I know that is because that's what
14 Q. And then you sent to it the -- looks like 14 I wrote. I don't remember. I may have sent them
15 the operations superintendent of International? 15 all, I may have sent some of them.
16 A. Right. 16 Q. All right. But at any rate, you gave Mary
17 Q. And that's Yarko? 17 some what are called crams?
18 A. Yes. 18 A. Correct.
19 Q. Before we get Into this, did anybody else 19 a. What's a cram?
20 get a copy of this? Did you send anybody else a 20 A. It's a correction order.
#
copy other than the people that you've identified 21 Q. Yeah?
2.:; here at the top? 22 A. It's like a-- you write what you found to
23 A. I gave it to Mary, the ED Narconon 23 be not meeting the standards.
24 Georgia-- 24 Q. Right.
25 Q. All right. 25 A. And then list of the references from the
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66
1 Narconon materials that somebody needs to study to
2 correct it.
3 Q. Is it -- do you -- as part of this
process, do you r.efer the center to specific HCO
policy letters that they're supposed to look at in
6 order to correct whatever the tech deficiency is?
7
8
A. No. We refer to the Narconon training
materials, like the running an effective Narconon
9 supervisor course, case supervisor course, out of
10 the Narconon materials.
11 Q. Okay. So you've got the supervisor
12 course, case supervisor course?
13
14
15
A.
Q.
A.
16 course.
17 Q.
Uh-huh.
Running an effective Narconon?
Uh-huh. There is an ethics service
Okay. What else?
18 A. What else. Let me think. There's how to
19 open a Narconon course, which is kind of irrelevant
20 here.
How to open one?
Uh-huh.
That's different from how to run one?
Yes.
21
22
23
24
25
Q.
A.
Q.
A.
Q. And these are all documents that Narconon
-
1 International has in its possession?
2 MS. SHAW: Object to the form of the
3 question.
4 A. I think.
5 Q. Well, I mean ...
6
7
A.
Q.
I don't know.
Well, where would I get them if I can't
67
8 get them from Narconon International? Where would
I be able to obtain these books? 9
10
11
12
13
14
15
A. I'm sure you can get them from Narconon
International.
Q. Right, because they're printed by Narconon
International?
A. Well, they're actually printed by ABLE.
Q. Okay. But they're -- fair enough. ABLE
16 has them?
17 A. Right.
18 Q. So basically, what you do, you come in,
19 you do the tech Inspection, If you find any
20 technical deficiencies, you write a cram up?
A. Correct.
2 .... Q. And then In order to address the technical
23 deficiencies, you refer the center to various books
24 that you've identified for me?
25 A. Correct.
68
1 Q . And you say, "Okay, in order to get in
2 compliance with the tech, you need to look at this
3 book and do the following." Is that a fair summary
4 of the process?
5 A. Yes.
6 Q. And you did that here with Narconon
7 Georgia?
8 A. Correct.
9 Q. And you referred -- you gave them -- by
10 "them," I mean you gave Mary this list of stuff she
11 was supposed to review and to do in order to become
12 in compliance with the tech? Or that's not a good
13 way to put it. But in order to fix whatever
14 deficiency you found?
15 A. Yes. I wrote various crams. You know, I
16 can't remember now what they were. But I mean,
17 they were not all to Mary. One may have been to
18 the person that operates the sauna. Another one - -
19 so they're --does that make sense?
20 Q. Makes perfect sense. 9832 says, "Attached
21 is a few more crams."
22
23
A.
Q.
Correct.
All right. So the one identified here,
24 Withdrawal, Conditions, Sequence and the
25 inst ruction on the TRs, those are ones that you
1 sent to-- or gave to Mary, in addition to the ones
2 that you had already given to her, right?
69
3 A. I don't totally understand that question,
4 Q. Well, I'm just trying to interpret what
5 you wrote. It looks to me like you're saying,
6 attached are a few more crams?
7
8
9
10
11
12
13
A.
Q.
Correct.
And then you identify four of them?
A. Identify four -- no. No.
Q. Well, you've attached four: Withdrawal,
conditions, sequence, and TRs.
A. Maybe I don't understand.
Q, Let's work through this together. Look at
14 your last --
15 A. Oh, I get it. I get it, yes. Conditions.
16 Yes. Those four, obviously. I didn't understand
17 this before what it was.
18 Q. All right. So you understand my questipn
19
20
21
22
23
24
25
now?
A. If you would just ask it again, please.
Q . Sure. It looks to me like, from your
email, and I'm asking you if this is correct.
A. Yes.
Q, It looks like you are saying in your email
of the 17th of June, here are four more crams.
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1
2
A.
a.
70
Yes.
And the way that I interpret that is that
3 you have already given Miss Reasor some other crams
6
7
8
9
related to deficiencies you found at the center.
A. Yes.
a. Is that correct?
A.
a.
That's correct.
All right. So we know that you gave her
this withdrawal, this conditions, this sequence,
and this TR cram.
A. Yes.
10
11
12 a. Do you know what other crams you gave her,
13 'cause I don't think it says it in your memo of
14 June the 16th.
15 A. No, 1 don't remember.
16 a. Well, can you tell, by looking at the tech
17 deficiencies that you found that you've Identified
18 in your report, what crams you would have given her
19 to address those problems?
20 A. That's what I was trying to do, and I
21 really don't know-- withdrawal. I would guess,
22 not that I remember, but based on a guess, I've
23 written one on the new life detoxification program.
24 a. Well, when you say you're guessing, you
25 don't specifically remember, but you do know what
-
1
2
3
4
5
6
7
8
9
tech you found a deficiency in?
A. Right. Right.
a. And It would be a part of your common
practice, would It not, ma'am, that If you found a
tech deficiency In that area, you would generally
write a cram up for that area. Is that fair?
A. That's fair. I'm just saying, I don't
remember. This is four years ago.
a. Yeah, I understand.
71
10 A. So that's why I'm telling you I probably
11
12
13
14
15
16
17
18
19
20
wrote one on a new life, because based on my report
I probably did.
a. Okay. And again, you use the word
"guess." That's all I'm trying to get to is that
the point of all this is you go in and you figure
out what tech is deficient, and then you try to fix
it?
A.
Q.
A.
Right. Correct. Yes.
And that's the reason you were there?
I was there for the purpose of the
,
,inspection and issuing the corrections. And then
2..:. it was up to Narconon to ...
23 a. You clearly gave Miss Reasor some
24 additional crams besides the four that you've
25 outlined in your email?
1 A. Yes.
2 a. And I think you said some of those you
3 gave to her when you were at the center. Is that
4 your recollection?
72
5 A. 1 gave all of them to her when I was at
6 the center.
7
8
a. All right. And so the one that you've
been able to Identify as perhaps having been given
9 to her so far is the new life detoxification cram?
10
11
A.
Q.
Correct.
Any others that you can tell from your
12 tech inspection that you likely gave her?
13 MR. HARRIS: Let's go off the record.
14 I have none of these.
15 MS. MARSCHALK: Neither do I.
16
17
MS. SHAW: Neither do we.
THE VIDEOGRAPHER: Stand by, please.
18 {WHEREUPON, a discussion takes place off the
19 record.)
20 THE VIDEOGRAPHER: Back on the record. Go
21 ahead.
22 By Mr. Harris:
23 Q. Any others that you can identify that you
24 likely would have given her as a result of your
25 tech inspection?
1 A. No.
2 Q. What's the process? I mean, I assume If
3 you give them a cram, is there. not a checklist that
4 they're supposed to fill out to show that they've
5 gone back through these books that you and I have
73
6 talked about before and have addressed whatever the
7
8
9
10
deficiencies are?
A. I don't know how Narconon International
deals with that currently.
a. All right. Well, do you know how they've
11 dealt with it in the past, or how they've dealt
12 with it with respect to Arrowhead?
13 A. I don't-- I really don't know how they
14 deal with that currently, whether they-- I don't
15 know if they follow up or ...
16 Q. So you go down and you do this inspection
17 and you give them this checklist of things they're
18 supposed to do, and you're not aware of any sort of
19 program that's in place to ensure to actually do
20 what it Is you went down there and told them they
21
22
23
24
25
needed to do?
A. Not personally, I don't know.
Q. Who would know?
A. Somebody from Narconon International would
know.
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74 76
1 Q. Do you know? 1 administered, what are they doing, what are they
2 A. Yarko. 2 writing, and to see what, if anything, needed to be
3 Q. Yarko? 3 improved.
.
A. Yes. He would know what he does with 4 Q. How did you pick the files that you looked
'
that. 5 at?
6 Q. So your involvement was, here's the way 6 A. Completely random.
7 you fix the problem, and you tell Yarko. And if 7 Q. All right. And what did you find when you
8 there's going to be any follow-up, you're assuming 8 did these random reviews?
9 that Yarko would be the guy who would follow up? 9 A. It's pretty much described in the report.
10 A. Yes. 10 There was some things -- it's what it says in the
11 Q. Is that fair? 11 report.
12 A. Yes. 12
Q, One of the things that I know that you
13 Q. Fair. 13 noted several times-- or that you noticed in
14 Now, let's go through this in a little bit 14 several of the folders was that some of the tech
15 of detail. Tell me what you did when you went in 15 was delivered out of sequence; is that right?
16 to inspect the facility. 16 A. Yes.
17 A. The first thing I did, I came in on a 17 Q. And the way that it works is that when the
18 Sunday. I got some of the --we call them folders, 18 student is enrolled in the Narconon program, there
19 which is basically the charts of some of the 19 is a very specific sequence of courses that the
20 patients, and I looked through some charts to see 20 student has to take, right?
21 how the program was administered. 21 A. Yes.
22 Q. And you looked through the patient 22 Q. And you can't deviate from that?
23 records? 23 A. I would say usually you don't.
24 A. Yes. 24 Q, Okay.
25
r-
Q. The patient charts? 25 A. It's not -- it's not never done.
75 77
1 A. Yes. 1 Q. When can you deviate from the sequence of
2 Q. Did you have any kind of HIPM release in 2 the courses?
3 order to do that? 3 A. An example would be, say, a person has
4 A. I don't remember. 4 extreme disciplinary problems, he can't comply to
5 Q. Well, did anybody authorize you, as a 5 the rules, he can't -- he can't stay in the
6 representative of Narconon Arrowhead, to look 6 program, he's always, you know, making noise, doing
7 through student files? 7 things he shouldn't do, we have like Book 5, 6 and
8 A. No. 8 7 addresses ethics, discipline. So sometimes a
9 Q. Well, what was your authority for being 9 person may do that out of sequence.
10 able to go into t his facility and just start 10 Book 3 teaches a person to study, make
11 looking at the patient records? 11 them more able to read, more able to study, So if
12 A. I was representing Narconon 12 they have to do something, whether they have to
13 International, -- 13 read a lot of things, they may do Book 3 before.
14 Q. All right. 14 Q. Okay.
15 A. -- would be my understanding. 15 A. It's a decision of the case supervisor.
16 Q. Okay. Gratuitously, right, as we said 16 The case supervisor is the one who dictates what is
17 before? 17 done with every single patient.
18 A. Right. 18 Q. All right. Well, but you're criticizing
19 Q. You weren't paid? 19 Narconon of Georgia here for doing some of these
20 A. No. 20 courses out of sequence in this report?
,
Q. All right. So you went and you began 21 A. Yes.
I
~ ~ looking around in student files? 22 Q. And you say rater in the report that
23 A. Yes. 23 you're not CS'd?
24 Q. And what was the point of doing all that? 24 A. I say I'm not trained as a case
25 A. The point was to see how the program was 25 supervisor.
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1
Q,
Okay. So if a decision about whether or
2 not you can do something out of sequence is up to
3 the case supervisor and you're not trained as a
case supervisor, how was it that you were able to
I
criticize the fact that books were done out of
6 sequence?
78
7 A. Because it is something that raises like a
8 question.
9 Q. And that's because, as a general rule, the
10 books are done in the sequence that's specified?
11 A. Yes.
12 Q. And that's start at Book 1 and you go to
13 Book8?
14
15
A.
Q.
Yes.
And the Narconon center, the individual
16 centers, do not have the authority to exempt
17 students from individual books, do they?
18 A. The ease supervisor of a Narconon has full
19 responsibility for getting somebody through the
20 program. If someone is going to be a graduate of
21 the program, no, they have to finish every single
22 book.
23 Q. Okay. All right. So I think that was my
24 question. The individual center cannot graduate
25 students from the Narconon program, unless all
f-- .
i
1 eight books that are specified in the Narconon
2 coutse are complete?
3 A. Correct.
4 Q. And the individual center can't graduate
79
5 someone from the Narconon program, unless those --
unless the sauna program is administered, right? 6
7 A. I have to clarify that a little bit. An
8 official graduate of a Narconon program has done
9 everything. There can be a condition where
10 somebody does not have medical okay to do the
11 sauna, they need a doctor's okay to do that. If
12 they can't physically or medically do it, they may
13 complete the program without that being done.
14 Q, So there are Narconon graduates out there
15 who did not do the sauna program?
16 A. I don't know what they call them. I know
17 a graduate is supposed to be somebody who has done
18 all the program. But if somebody can't medically
19 do it, we still give him the acknowledgment that
20 he's done the program.
7 Q. All right. Well, he may have an
2.... acknowledgment that he's done the program, but I
23 guess my question is different. I mean, can you
24 graduate from the Narconon program if you don't do
25 the sauna program?
80
1 A. I'm going to say I --I don't know the
2 rule on that.
3 Q. Where are these -- the books that you and
4 I talked about earlier about running a Narconon
5 center, the supervisor course, there's a case
6 supervisor course book as well, --
7 A. Uh-huh.
8 Q, -- which again, I don't have.
9 Does It specify the things that you and I
10 are talking about here today, about whether or not
11 you can do things out of sequence, or whether or
12 not you can graduate somebody from the program if
13 they don't do the sauna?
14 A. I haven't done the course, so I'm not
15 sure.
16 Q. Right. Well, but I think you told me you
17 write crams up and refer them to the books?
Correct.
So you know what's in the books?
18
19
20
A.
Q.
A. I don't know what's in t h ~ -- everything
21 that's in the case supervisor book.
22 Q. How do you write crams referring people
23 back to books unless you don't know what's In the
24 books?
25 A. I did not cram the case supervisor.
81
1 Q. Oh, okay. Who crams the case supervisor?
2 A. It can be other inspectors that do have
3 that training and they can cram the supervisor. I
4 cannot because I am not-- do not have that
5 training.
6 Q. Why do they pick you to do the tech
7 inspection? Do you know? I don't mean that in any
8 kind of disrespectful way.
9 I'm just curious, if you can't cram the
10 case supervisor, and what if Narconon of Georgia
11 had some problems with its case supervisors, you
12 wouldn't be the tech inspector who could address
13 that, so why do they pick you?
14 A. Because I know-- I've done inspections
15 before, I can write a report on outnesses, and if
16 they felt that they needed to send somebody who is
17 case supervisor trained, they can request folder's
18 to Narconon International to be seen by someone who
19 is trained. I've done this before. That's why
20 they picked me, I suppose.
21 Q. All right. And you said something the
22 court reporter is probably confused by, outnesses.
23 A. That's things that are not to the
24 standards.
25 Q. Right. If you're not in compliance with
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82 84
1 the tech, -- 1 A. I remember I tal ked to her about that she
2 A. Yes. 2 was there to do a legal rudiments inspection.
3 Q. - - you have an outness? 3 Q. What's a legal rudiments inspection?
-
A. Yes. 4 A. It' s a checklist to look at what -- at the
v Q, By the way, Barbara Dunn, did she come 5 legal - - the legalities of the center, you know,
6 down and do the Inspection with you? 6 whether t hey are complying to the laws, basically.
7 A. She was there. She was not doing it with 7 Q. And is that a written checklist?
8 me. She was -- she came to the center while I was 8 A. Yes.
9 there. 9 Q. Okay. And that's what Miss Dunn was there
10 Q. All right. And who does she work for? 10 to do, was to do a legal rudiments checklist to see
11 A. At the time, I really don't know who she 11 whether the center was In compliance with the law?
12 was employed by. 12 A. They told me she was there to do a legal
13 Q. Well, you were looking at documents at the 13 rudiments inspection.
14 same time that Miss Dunn was there, were you not, 14 Q. Okay, What else did she tell you she was
15 ma'am? 15 there to do?
16 A. I don't know what she was looking at. 16 A. That's all.
17 Q. Well, were you there at the same time she 17
Q,
All right. What was she looking at?
18 was at the facility? 18 A. I don't know.
19 A. Yes. 19 Q. Well, you were looking at files. Was she
20 Q. Did you come together? 20 looking at the same files you were looking at, or
21 A. No. 21 was she looking at different files?
22
Q,
Were you ever in the same room together 22 A. I don't know.
23 looking through folders? 23 Q. Do you know who Miss Dunn works for?
24 A. No. 24 A. No.
25 Q. Do you know who Miss Dunn is? 25 Q. Are you personally -- do you personally
-
83 85
1 A. Yes. 1 know her?
2 Q. Who is she? 2 A. I know her from when she was at Narconon
3 A. She is-- I know Miss Dunn from Narconon 3 Arrowhead.
4 Arrowhead. She was there for a while. 4
Q,
And she's actually affiliated with the Los
5 Q. Right. 5 Angeles org, isn't she?
6 A. What -- I don't know who she was employed 6 A. I don't know.
7 by. 7
Q, All right. You don't know anything about
8
Q,
She was there on behalf of the church, 8 this lady who was there doing an inspection at the
9 wasn't she? 9 same time that you were there, other than what
10 A. I don't know. 10 you've told me?
11 Q. Okay. She was there at the same time that 11 A. I know who she is. I don't know who she
12 you were there doing an inspection? 12 was employed by at the time. I really· don't. She
13 A. Yes. 13 came, I think, the last day I was there, and we
14 Q. She didn't work for Narconon Arrowhead, 14 were not there together for very-- for very long.
15 did she? 15 Q. What did you see her doing?
16 A. No. 16 A. What did I see her doing. I mean, I saw
17 Q, What was she doing? 17 her meeting with Mary, and I saw her looking at
18 A. As far as I know, she was doing 'a legal 18 some papers.
19 rudiments inspection. 19
Q, What papers?
20 Q. Okay. And how do you know that? 20 A. I don't know.
~
A. Because I spoke to her. 21
Q,
Where were the papers located?
'
2 ~
Q, Tell me what y'all talked about. 22 A. At the desk she was sitting at.
23 A. I don't remember what we talked about. 23 Q. Well, do you know -- I mean, did you look
24 Q. You don't remember any of your 24 over and see whether it was a file or anything like
25 conversations with Miss Dunn? 25 that?
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No. 1
2
A.
Q. Okay. But you did know that she was doing
3 a legal rudiments check?
A. That's what she told me.
Q. That's what she told you?
Yes. 6
7
A.
Q, Have you ever done a legal rudiments check
8 before?
9 A. No.
10 Q. Who else does legal rudiments checks,
11 besides Miss Dunn?
12
13
A.
Q,
I don't know.
Well, people who do the inspections for
14 Narconon, it sounds like what you're telling me,
15 have different specialties or areas that they're
16 trained in. Is that fair? Because you told me
17 earlier you weren't trained in doing the case
18 supervisor?
19 A. Right.
20 Q. And that if there were some issues in case
21 supervising, they would bring in somebody who would
22 do that, right?
23 A. Yes.
24 Q. Was it your understanding then that was
2!' what Miss Dunn was doing?
-
87
1 A. My understanding. She told me she was
2 doing a legal Inspection.
3 Q, Okay. You said legal inspection. Is that
4 the same--
5 A. Legal rudiments, yes. Legal rudi ments.
6 Q. Okay. In your experience with Narconon,
7 when people do legal rudiments inspections, is
8 there any paperwork generated from such an
9 inspection?
10
11
12
A. As far as I know, the checklist is checked
off on what's in and what's out on the inspection.
Q. Okay. And are there legal crams that are
13 given to the centers?
14
15
A. I don't know.
Q. Okay. Well, I just -- I mean, Miss Dunn
16 was there at the same time that you were there; and
17 there hasn't been a scrap of paper produced In this
18 case about anything she was doing there the day
19 that you were there.
20 And I'm just asking you, do you think, as
~ a person who's familiar with how the process works
2:t: and how these inspections go, do you believe that
23 there would have been a legal rudiments checklist
24 that would have been generated?
25 A. I don't know. I have not worked at
1
2
3
88
Narconon International for many, many years.
Q. Okay.
A. I mean, I can give you a complete guess
4 that, yeah, normally.
5 Q. Normally, there would be some paper?
6 A. Yeah.
7 Q. And normally, you would report to the
8 person who sent you there to do the check, to do
9 the inspection, right?
10 A. I would think.
11 Q. That's what you did, right?
12 A. But I can't talk for them.
13 Q. I know.
14 A. I really can't. I mean, all I can do is
15 give you a complete guess on it because--
16 Q. Well, you're not guessing. You're a
17 scientologist, right? I mean, and again, I'm
18 not - -
19 MS. SHAW: Object to the form.
20 Q. You're a scientologist, right?
21 A. I am.
22 Q. And one of the things in the church that's
23 very Important is documenting things for people in
24 the organization. Is that fair?
25 A. But this is --this is Narconon.
1
2
Q.
A.
89
Okay. Well, let's talk about --
This does not operate exactly on the same
3 -- I work both places. They're not the same --
4 Q. I understand.
5 A. --form.
6 Q. Well, then let's talk about Narconon.
7 A. Okay.
8 Q. In Narconon International, at Narconon
9 Arrowhead and at the individual centers, one of the
10 things that's very important in any of the secular
11 organizations under the Church of Scientology is a
12 chain of command and a reporting requirement?
13 MS. MARSCHALK: Object to the form.
14 MS. SHAW: Object to the form.
15 Q. Fair?
16 A. It's too general of a question, because in
17 my case I can say yes, I was asked by somebody to
18 go and I was asked to report what I found.
19 Q. Do you know who Miss Dunn was-- who had
20 asked Miss Dunn to come down and do the inspection?
21 A. I don't know.
22
23
24
Q.
A.
Q,
Do you know who she was reporting to?
No.
Anythi ng other than what you've told me
25 about that she was there to do a legal rudiments
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1 inspection? Do you know anything else about what
2 she was doing?
3 A. No.
Q. Did you see her -- you saw her leave with
:.. Mary one day?
6 A. I saw her meet with Mary.
7
8
9
10
11
Q.
A.
Q.
A.
Q.
Okay. You saw her looking at something--
Correct.
-- at a desk, right?
Yes.
And did you see her interviewing any
12 witnesses?
13
14
15
16
A.
Q.
A.
Q.
No.
Talking with any students?
No.
All right. You said you knew Miss Dunn
17 from your time at Arrowhead?
18 A. Yes.
19 Q. Tell me what you know about what she was
20 doing when she was at the Arrowhead program.
21 A. She was doing a project for Narconon
22 International. We were -- they wanted to start the
23 training, a training center at Narconon Arrowhead
24 to - - well, not start it, but get it more -- get it
92
1 data is kind of the skeletons in the closet of the
2 students, and she did not feel that they would be
3 protected confidentiality-wise, you know, if they
4 were coming off bad illegal things they had done.
5 And that's what she told me as to why those reports
6 were not in those particular -- in that particular
7 file.
8 Q. And I want to know everything that Miss
9 Reasor told you about that.
10 A. That's what she told me.
11 Q. All right . Ethics data would be, for
12 example, complaints that students might have about
13 other students in part, right?
14 A. When I refer to ethics data, it's things
15 that the students have told.
16 Q. Well, if somebody gets busted for drinking
17 at housing, they get an ethics write-up, right?
18 A. I don't know.
19 Q. Well, that's the typical process, isn't
20 it? I mean, Miss McGregor, if somebody gets busted
21 for--
22
23
24
A.
Q.
A.
No, I'm thinking.
Okay.
I want to answer the question correctly.
25 expand on a component of Narconon Arrowhead to 25 There may be a report. It may be a verbal report.
-
91 93
1 train people from other countries, other areas, to
2 open new centers. And she was then in the capacity
3 of being the course supervisor in that course room.
4 Q. Okay. Have you seen Miss Dunn since you
5 saw her at that Inspection?
6 A. No.
7 Q. Have any phone conversations with her?
8 A. No.
9 Q. All right. I want to talk to you about a
10 couple things in your report.
11 A. Okay.
12 Q. You note that ethics data is not put Into
13 the folder. That's on page 9829. It says, "The
14 EDs does not want it In there so that the state
15 does notes it." What does that mean?
16 A. It's a badly written sentence.
17 Q. No, I wasn't criticizing your sentence.
18 Well, I sort of am criticizing it because I want to
19 make sure I understand it.
20 A. What I meant to say was Mary didn't want
' 1 the ethics information in those particular charts
2 ~ because she didn't want the state to see it.
23 Q. Okay. Why did she not want the state to
24 see It?
25 A. She explained to me that -- the ethics
1 The students are not very good at writing things.
2 Q. I understand.
3 A. They often just tell.
4 Q. I'm not suggesting that every deviation
5 results in a report. I get that.
6 A. Okay.
7 Q. But the general -- the way that the world
8 is supposed to work, generally, Is If the student
9 violates some rules, there is an ethics report
10 that's generated that goes to the ethics officer so
11 that the ethics officer can review that deviation
12 and determine what conditions need to be Imposed on
13 the student to address it.
14 A. Yes.
15 Q. Is that fair?
16 A. That's fair.
17 Q. Okay. So if students are drinking or
18 using drugs or doing that sort of thing, that's the
19 kind of stuff that shows up in ethics reports?
20 A. Correct.
21 Q. I'm not saying every time, but it shows up
22 In ethics reports, right?
23 A. Correct.
24 Q. And so Miss Reasor was telling you that
25 she didn't want those ethics reports put in the
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94
1 file?
2 A. When I was talking to her, what I was
3 looking at was -- what I was asking her about was
' as part of program that certain --they write up
v their transgressions. They do something called
6 conditions. Those are ethics things. Those were
7 the parti cular things I was looking for in those
8 folders because it's part of the delivery of the
9 program.
10 Q. Right. But it's situations where they
11 write up their own transgressions?
12 A. Yes.
13 Q. But it's also when they're written up by
14 somebody else for transgressions
1
right? Those are
15 all ethics reports or KRs?
16 A. What you're talking about is KRs.
17 Q. Okay.
18 A. What I'm talking about is not KRs. Those
19 are the things that the students themselves--
20 Q. Success stories?
21 A. -- come off of them. Success stories and
22 when they -- when they write, they have this thing
23 where they have to write all the bad things they' ve
24 done, and those are ethics data in Book 6.
25
r-
Q. Well, is the ethics data supposed to be In
1 the folder under Narconon's tech rules?
2 A. They are, but there's also a rule that
3 legal rudiments, we have to comply to legal
95
4 rudiments. So if it would --I don't know the laws
5 of Georgia, but if this would violate the HIPAA
6 laws or confidentiality of the student, which is
7 what I understood from Mary this was, then Narconon
8 would not try to correct that because we have to
9 follow the laws, first of all.
10 Q. So you don't know whether or not the State
11 of Georgia requires that this be done one way or
12 the other?
13
14
A.
Q.
No.
You just noted that she said that's the
15 reason that she wasn't putting it in the files?
16 A. Right.
17 Q. Anything else y'all discussed about that
18 topic?
19 A. No.
20 Q. There also was a discussion that you had
7 with her about the withdrawal
1
about-- she called
2.c. It something different from what, I believe, you
23 felt like it should be called. I don't want to put
24 words in your mouth, but do you remember that
25 conversation?
96
1 A. Yes. It says here she called it
2 orientation.
3 Q. Was that something that you noted that you
4 thought was out of the ordinary?
5 A. Yes.
6 Q. Why is that?
7
8
A.
Q.
Because I've never seen that before.
Right. Because it's usually called
9 withdrawal, right?
10
11
A. Yes.
Q. And she told you that she wasn't going to
12 call it withdrawal, she was going to call it
13 orientation, right?
14 A. Yes.
15 Q. And then I believe she discusses the fact
16 that, later in your report
1
that that's because of
17 some legal reason?
18 A. Yes.
19 Q, Tell me what you remember about that.
20 A. She told me that-- and I don't know why,
21 but she told me she couldn't --1 think I clarified
22 it in my email a little bit. She said she couldn't
23 call it withdrawal for -- she had a lot of
24 attention on legal and legal rudiments, and that's
25 what she told me. She said it had a legal reason
97
1 and that she couldn't even remember exactly, when 1
2 talked to her, what that reason was.
3 Q. She didn't say it was because I didn't
4 have a llcense that would allow me to run any kind
5 of a facility that Is having a withdrawal program,
6 did she?
7
8
9
A.
Q.
MS. MARSCHALK: Object to the form.
No.
Had a lot in it.
10 All right. That's all you remember about
11 that, she had some legal reason for calling it
12 orientation, but you don't know what that was?
13 A. Exactly. And she didn't know what it was
14 even.
15
Q,
Okay. It says, "A new person who has been
16 trained as a W/D specialist is coming in next
17 week. "
18 A. That's withdrawal.
19 Q. Okay. Then you looked at every one-- it
20 says you looked at the admission data and everyone
21 had a psych history.
22 A. Uh-huh.
23 Q. Why were you interested in that?
24 A. Because we have -- one of the
25 qualifications of attending the Narconon program,
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98
1 we're not a dual diagnosis program. So if they
2 have too much of a psych history, they would not be
3 qualified to attend.
Q. All right. And you were reviewing their
" psychiatric history?
6 A. It's part of the intake data, yes.
7 Q. Okay. But I mean, you note it in here,
8 and I'm just curious. I mean, what was your reason
9 for noting it?
10 A. It's because it is part of the enrollment
11 policy to not accept peopl e who have, you know, an
12 extreme-- if they're considered more, you know,
13 having mental problems than a drug problem, then
14 they're not our problem.
15 Q. All right. Go back to the first page of
16 your report. I'm sorry, I meant to ask you this,
17 but I skipped over it. It says, "I assume you know
18 the setup here, but I'll summarize it. It's an
19 outpatient center."
20 A. Yes.
21 Q. Tell me why you wrote that.
22 A. Because I always -- what I always hear
23 about Narconon Georgia, I always hear that it's an
24 outpatient center.
25 Q. And who do you always hear that from?
-
99
1 A. Well, we've been at conferences, we
2 actually had a game that's played between all the
3
4
5
Narconon centers, and Narconon Georgia is listed in
that game as an outpatient.
Q . Is that the birthday game?
6 A. Yes.
7 Q. Okay. Did you look into that in any way?
8 Do you know where students were housed and how they
9 came to go to the housing and all of that sort of
10 stuff?
11 A. I know they were housed somewhere. I
12 don't know where, and that Narconon Georgia
13 transported them to and from that housing.
14 Q. All right. And I don't want to get Into a
15 bunch of questions about this if there's no reason
16 to.
17 Was part of your inspection, was it in any
18 way to look into this issue of housing, whether or
19 not there were problems at housing, all that sort
20 of stuff?
A. No.
2" Q. You understood it was an outpatient
23 center, and you had some general understanding
24 about where the patients were housed, but that was
25 it?
1
2
A.
Q.
100
Yes.
And you didn't do any Investigation of
3 that to try to determine what the situation was at
4 housing. Fair?
5 A. Yes.
6 Q. You didn't go look at It?
7
8
A.
Q,
No.
Did you talk to anybody at all during your
9 tech inspection about housing?
10 A. Mary told me she had concerns about the
11 housing.
12 Q. And what did she tell you?
13 A. I really can't remember the specifics, if
14 it was the location or-- I think she wasn't happy
15 with the location.
16 Q. Anything else that you remember about that
17 conversation?
18 A. No.
19 Q. In the documents that you were looking at,
20 though, did you see documents that would refer to
21 housing from time to time?
22 A. No.
23 Q. Okay, And again, I don't want to get into
24 this if there's no reason to. That didn't raise a
25 red flag where you said, hey, wait a minute, I
101
1 thought they were an outpatient center, I'm going
2 to investigate that? You didn't do anything like
3 that?
4 A. I did not look at anything, except the
5 actual center.
6 Q. All right. Now, the sauna program, you
7 indicate in this paragraph here that the sauna
8 program is delivered at another location?
9 A. Yes.
10 Q. Did you know anything about the consent
11 decree that occurred with the State of Georgia
12 about how the sauna was supposed to be delivered
13 and what the legal requirements were for all that
14 sort of stuff?
15 A. There was a word in the beginning of your
16 sentence that I didn't understand. The consent of
17 agree?
18 Q. I'm sorry. There was an agreement between
19 the State of Georgia and Narconon about how to
20 deliver the sauna program. It was called a consent
21 order or consent decree.
22 A. Oh, okay.
23 Q . I shouldn't have used that. It's like
24 this stuff to me.
25 A. Yeah.
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102
1
Q,
There's just an agreement, there's a legal
2 agreement.
3 A. Uh-huh.
Q. Did you know anything about that? Were
you looking into whether or not the delivery of the
6 sauna program complied with any agreement that
7 Narconon of Georgia might have had with the state
8
9
about how to run the sauna?
A. No.
10 Q, You just looked at it from the delivery of
11 standard tech perspective?
12 A. Exactly.
13 Q. And I assume you went over to-- you
14 clearly did. You went over and looked at the sauna
15 delivery program?
16 A. Yes.
17 Q. And noted some deficiencies in that?
18 A. Yes.
19 Q. Tell me, generally, what you noted. I can
20 read it here, but I wanted you to expound on it a
21 little bit.
22 A. What I noted was that there was some
23 outnesses in the way-- just in the admln. There
24 are certain reports that are supposed to be filled
25 in, and they were not as complete as I would have
1-
103
1 liked to see them.
2 There's like a daily report that the
3 student or the patient does, and I would have liked
4 to see more information from the student and from
5 the administrator in those reports.
6 Q. Now, related to the delivery of the sauna
7 program and the delivery of the vitamins, Miss
8 Reasor apparently told you something else about the
9 vitamin regimen and about her concerns that if they
10 did It a certain way, that would require that they
11 have a nurse. Do you recall that conversation?
12 A. I don't recall it, but I see I wrote It
13 somewhere.
14 Q. It says, "Per the ED, they cannot report
15 on vitamins that the person takes as if they did,
16 they would have to have a nurse here as well."
17 A. Right. Exactly.
18 Q . Tell me about that. What does that mean?
19 A. I can't tell you anything else than what I
20 wrote. Normally, in a Narconon, you don't need a
nurse to give vitamins. Mary told me she did.
2.o. That's all I know about lt.
23
Q , But they were giving the vitamins to the
24 students, right? You saw that in the charts?
25 A. No. There were no charts for this
104
1 orientation. There was no -- in the sauna, yes.
2 Q. They kept them over at the sauna?
3 A. Absolutely. Yes. Yes.
4 Q. All right. Got it.
5 And you also noted that the students were
6 In the box almost all the time, except between
7 11:30 and 11:45?
8 A. Right.
9 Q. So the students were there all day long,
10 except for that break, Inside the sauna? Is that
11 what you observed?
12 A. What I meant was the sauna program is a
13 five-hour day thing.
14 Q. Okay.
15 A. And some Narconons are really sloppy about
16 letting them be out of the sauna, you know, for
17 most of the time. And that was actually a plus
18 because they were in the sauna.
19 Q . They were keeping their folks in there the
20 five hours a day?
21 A. They went out for breaks, you know, of
22 course to cool down, and they were out more times
23 than that 30 minutes. But they were not out
24 excessive amount of time, is what I was trying to
25 say.
1
Q,
105
And again, going back to this agreement
2 between the State of Georgia and Narconon of
3 Georgia, do you know whether or not Narconon was
4 allowed to do that, Narconon of Georgia was allowed
5 to keep the students In there for five hours a day?
6 A. I don't know.
7 Q. You don't know?
8 A. No.
9 Q. But that was your observation, that they
10 actually did a good job on that; t hey kept them in
11 there for the five hours or so that's required
12 under the program?
13 A. Yeah, with the appropriate breaks.
14 Q, All right. Now, your next page, 9830,
15 your sentence says, "I talked to the C/ S." That's
16 the case supervisor, correct?
17
18
A.
Q.
19 sauna?
20 A.
21 Q,
22 A.
23 Q.
24 A.
25 Q,
Yes.
And that's the case supervisor of the
Of the whole program.
Who was that?
Her name was Tracy.
Tracy Steppler, right?
I don't remember her last name.
She said she knew that there were
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1 outnesses.
2 A. Yes.
3 Q. All right. Was that conversation about
the whole program in general, or was it about just
-. the sauna, 'cause I'm confused about the way you
6 wrote it?
7 A. This particular conversation is about the
8 sauna.
9 Q. All right. "She said she was going to the
10 org to have cram ruds as she has not been feeling
11 well."
12 . A. Right.
13 Q. I mean, going to the local scientology
14 organization in Atlanta?
15 A. Yes.
16 Q. She was just telling you that she was
17 having some personal issues she felt like she
18 needed to have addressed? Is that the
108
1 Q. And what is "qual f rom above"? She is
2 qualified to do that?
3 A. No. Qual is a division in the org board.
4 Q. Yeah.
5 A. It's for qualification. So she was doing
6 that job and she was holding the division
7 qualification as well.
8 Q. Okay. And then she's also a reg?
9
10
A. Yes.
Q. And tell me, do you know how the regs
11 work, how that-- I mean, you do, because you are
12 one now
1
right?
13 A. Yes, I do.
14 Q. Okay. How are they compensated?
15 A. I can only speak for Arrowhead because
16 that is decided by every individual center.
17 Q. Okay.
18 A. I can tell you I'm compensated with 2
19 conversation? 19 percent of the income that I make for Narconon
20 A. Yes. 20 Arrowhead.
21 Q. All right. I don't want to get Into her 21 Q. Okay. And are you paid In cash when you
22 personal stuff. But what did she say that she had 22 enroll a student?
23 concerns about that might have impacted her job, 23 A. No.
24 that you recall? 24 Q. All right. Do you know whether or not the
25 A. She just -- the only thing she told me was 25 regional -- are there regional registrars that have
-
107 109
1 that she felt she had a little too much on her
2 plate.
3 Q. And "She looked downtone."
4 A. Yes.
5 Q. And what is downtone?
6 A. It's basically unhappy.
7 Q. And then you've got some stuff in here
8 that I just - - "Tracy is posted as the D/ED
9 delivery and exchange and also holds qual from
10 above."
11 A. Uh-huh.
12 Q. What does that mean? You're going to have
13 to interpret that.
14 A. Yeah, it means -- I don't know if you're
15 familiar, we have like an organizing board that is
16 used. There's a director. And then right under
17 that there's a deputy director for the liability
18 exchange whose job it is basically to oversee the
19 whole psych of a person coming in and getting
20 through the program and getting out the door.
Q. Okay. So she was the deputy executive
2 ~ director--
23
24
25
A. Yes.
Q. -- on the org board?
A. Yes.
1 websites and 1-900 [sic] numbers and so forth and
2 people call and end up getting directed to Narconon
3 programs?
4 A. Regional?
5 Q. Let me just back up.
6 A. Yes.
7 Q. Are there regional registrars --are
8 people out there who don't have a specific
9 territory who can have websites and things like
10 that with 1-800 numbers on it, so if someone wants
11 to call and get drug and alcohol treatment
1
they
12 get in contact with such a person?
13 A. Yes.
14 Q. What do you know about that? Explain that
15 process to me.
16 A. We call these people field
17 representatives.
18 Q. Field, that's what I was trying to get to.
19 A. And that's different. Some of them are
20 simply -- they have their own business referral
21 agency.
22 Q. Uh-huh.
23 A. And they have a website that says if you
24 need drug rehab, call me. And then they call, and
25 that person will then decide if the person is good
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1 for Narconon, for process program, for dual 1 A. I may send them to another Narconon --
2 diagnosis, and refer them. 2 Q. All right.
3 Q. So they're independent field 3 A. -- if they don't want to leave California
,
representatives who don't have any affiliation with 4 or -- yeah, sometimes.
-
the Narconon program and they just refer to 5 Q. Okay. And these other field
6 different centers? 6 representatives, that is the sum total that you
7 A. Correct. 7 know, that they're out there, some of them are
8 Q. Okay. Are there field representatives 8 affiliated with Narconon but aren't affiliated with
9 that are affiliated with Narconon, but aren't 9 a specific center?
10 affiliated with a specific center? 10 A. Correct.
11 A. Yes. 11 Q. Do you know how they're compensated?
12 Q. Tell me about that. 12 A. I can only speak for Narconon Arrowhead
13 A. I mean, you can have somebody who has 13 again.
14 completed the program can go out and represent us 14 Q. Okay.
15 in the field and contact people about coming to 15 A. We compensate them with 10 percent of the
16 Narconon. They're not employees. They are -- they 16 income we make on the person who they would refer.
17 are, you know, talking about Narconon. 17 Q. So they get a referral fee?
18 Q. Do you know how many of those sort of 18 A. Correct.
19 field representatives are out there? 19 THE VIDEOGRAPHER: Stand by, please.
20 A. I don't-- I don't know. 20 (WHEREUPON, a recess was taken.)
21 Q. Do you know -- 21 THE VIDEOGRAPHER: We're back on the
22 A. Quite a few. 22 record at 12:34.
23 Q. Do you know any of them by name? 23 Q. Okay. Miss McGregor, a couple things.
24 A. Do I know some by name? 24 I'm going to sort of bounce around here, and then
25 Q. Yeah. Do you know any of these field 25 we'll go back to finishing up on your report.
r-
111 113
1 representatives that are affiliated with Narconon 1 A. Okay.
2 but aren't affiliated with a specific center? 2 Q. First of all, I sent a discovery request,
3 A. Oh, not affiliated with a specific center. 3 which means I ask a question of the defendants in
4 Because the ones I work with are mostly affiliated 4 this case, and I asked them to identify people who
5 with Arrowhead. 5 came in and did any kind of Investigation after
6 Q. And you don't know any of them by name? 6 Patrick's death of the facility.
7 A. That' s not specifically affiliated with 7 A. Okay.
8 Narconon Arrowhead, no. 8 Q. And they have identified you and Barbara
9 Q. Do you know any of the websites that the 9 Dunn.
10 field representatives that are affiliated with 10 A. Uh-huh.
11 Narconon but aren't with a specific center, do you 11 Q. Was there anybody else that came in,
12 know what any of those websites are called? 12 either around the same time that you did or after
13 A. No. 13 or before that you know of, who looked into
14 Q. I mean, are you allowed to, as a reg with 14 anything about either the facility or the
15 Arrowhead --or I shouldn't say "allowed," but do 15 circumstances of his death?
16 you generally send people who call in to a separate 16 A. Not as far as I know.
17 facility other than Arrowhead? 17 Q. Okay. Heard any names, heard any rumors
18 A. I didn't understand the question. 18 about anybody who might have gone and looked at it?
19 Q. Well, you're currently a registrar with 19 A. No.
20 Arrowhead, right? 20 Q. All right. A couple of names that have
,.
A. Yes. 21 come up. And this Is really just so I'll know how
2"'
Q. When somebody calls in and wants to have 22 they fit Into the grand scheme of things here.
23 drug and alcohol counseling, do you generally send 23 We've talked about Yarko --
24 that person to Arrowhead, or do you send them to 24 A. Uh-huh.
25 some other Narconon? 25 Q. -- whose last name you can't remember, and
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1 I can't remember either, but that's fine. 1 I don't really understand.
2 A. Okay. 2 A. Okay.
3 Q. He's the director of production? 3 Q. There is one sup.
,
A. Yes.
I
4 A. That's a supervisor.
~ Q. There's a lady that's been in the 5 Q. And that's Gene Adams?
6 documents -- or there's a gentleman named Isaac 6 A. Uh-huh.
7 Zrihen, Z-R-1-H-E-N. Do you know him? 7 Q. Now, in terms of the counselors or the
8 A. No. 8 people who were actually delivering the tech at the
9 Q. He works at Narconon International. 9 program In Georgia, it looks to me like from the
10 A. I don't know him. 10 org boards, that it's Gene Adams and Abby Bailey.
11 Q. Claudia, you know her? 11 And that seems to be consistent with what you've
12 A. Yes. 12 written here?
13 Q. And what is Claudia's job title? 13 A. Uh-huh.
14 A. She is -- I don't know exactly what title 14 Q. Is that true?
15 they use right now, bu.t she's responsible for legal 15 A. To my recollection, yes.
16 and corporate affairs. 16 Q. Those were the people who were actually
17 Q. For International? 17 teaching the courses to the students?
18 A. Yes. 18 A. They were there for the ones, yes.
19 Q. Another name that's come up a couple 19 Q. Are you aware of anybody else that, in
20 t imes, Yvonne. I believe it's Yvonne Rogers? 20 your tech review, that you could identify for me
21 A. Uh-huh. 21 who was actually teaching the courses to the
22 Q. Do you know her? .22 students?
23 A. Yes. 23 A. No.
24 Q. What does she do? 24 Q. Do you know anything about Gene Adams' or
25 A . She is the executive director of Narconon 25 Abby Bailey's training?
....,
115 117
1 Eastern United States. 1 A. I see here that she's church trained, I
2 Q. And then there may be another lady named 2 can't remember what kind of training, and that
3 Yvette, and it might be just mistyped, but that 3 she's done the Narconon supervisor course, Abby
4 could be Yvonne. But do you know someone named 4 Bailey.
5 Yvette? 5 Q. All right. Well, let's start with Gene.
6 A. No. 6 A. And Gene. It says he's a Class IV
7 Q. All right. Let's go back to your report. 7 auditor, which is church training.
8 We were at the top of page 9830, and you were 8 Q. Right. And that's exactly what I'm
9 talking about -- we got off on the discussion about 9 getting to. The two people you've identified here
10 the field representatives, but we were talking 10 as providing the course itself, teaching the course
11 about your conversations with Tracy Steppler. 11 to the students, --
12 A. Yes. 12 A. Uh-huh.
13 Q. And anything else about that conversation 13 Q. -- you note that the supervisor is a Class
14 you recall that we haven't talked about? 14 IV auditor, right?
15 A. No. 15 A. Correct.
16 Q. She said she had -- I think you said just 16 Q. Which is a Church of Scientology level
17 kind of worn out and needed to take maybe some 17 where you can actually audit people?
18 personal time and do something with the church to 18 A. Yes.
19 get herself back to where she could work. Is that 19 Q. And what is a Class IV auditor from --
20 the basic summary of what was going on? 20 A. It's just a certain level to which you are
,
A. She didn't say she needed to take personal 21 trained to deliver auditing to church parishioners.
~ ... time. She did say she wanted to go to the church 22 Q. And how far-- what's the highest level
23 and get some help. 23 you can get in terms of being an auditor?
24 Q. All right. Now, moving through your 24 A. You can go to Class XII.
25 report, I want to ask you some other questions that 25 Q. All right. And then he's trained in
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co-auditing and a trained co-audit supervisor?
A. Correct.
Q. You don't note anything else about his
training, other than he's a Class IV auditor and
trained at running the TRs and objectives, et
cetera, right?
A. No, that's all I say.
Q. So does he have any training at all in
providing drug and alcohol services, other than
what you've identified here in this paragraph, that
11 you're aware of?
12 A. I don't recall.
13 a. same thing with Abby Bailey, you indicate
14 she also Is church trained?
15 A. Uh-huh.
16 Q. And what did you mean by that?
118
17
18
A. It means she has done some training in the
church. Don't remember what. She's done some
19 church training. That's all I can say.
20 Q. When you' re doing the tech review and
21 looking at these qualifications, are you looking
22 for any particular kinds of qualifications? Is
23 there something that you're trying to make sure
24 that the people are trained to provide or trained
25 to deliver in terms of tech?
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A. Yes. I want to see that they're trained
in what they're doing.
Q. And were they?
A. Yes.
Q. And how so?
A. Well, I don't remember exactly with Gene,
other than what I say here. It says he's a trained
co-audit supervisor, which I assume to mean that he
had done the Narconon supervisor course. And also
Abby, I say she's done the Narconon supervisor
course, which Is what you need to do to teach the
courses.
Q. Okay. But it' s fair to say that the only
training that you note in your tech review here Is
either church training or Narconon training?
A. Correct.
Q, All right. Then you say Abby is an SOP.
What does that mean?
A. It stands for senior director for
production, and it's -- there's three divisi ons
that the SOP oversees, which is the technical, the
qualification and treasury.
Q. And that title is called out and described
in how to run an effective Narconon book?
25 A. Yes.
120
1 Q. All right. Then "The grafts were out of
2 PT." What does that mean?
3 A. It means the students have to - - we have
4 -- they have a point system that they keep during
5 the day on how many pages they read, how many words
6 they clear. And by the end of the day, they have a
1 total. And then they put it on like a graph. It's
8 like a -- I don't know how you call that. We use
9 this language, I know.
10
11
Q.
A.
Uh-huh.
But it's like a graph, you know, where you
12 have lines and numbers, and then they put, like I
13 make 200 points today, and then I made 300 the day
14 after. And they kind of keep a graph like that.
15 a. So the organization keeps up with how many
16 words the individual students clear?
17
18
A.
Q.
19 graph?
And other things.
And other things. And then puts them on a
20 A. Right.
21 Q. And Is that ultimate -- does that
22 ultimately end up on the weekly statistics that are
23 turned in every Thursday afternoon?
24 A. All of that is totaled by the end of the
25 week, yes.
1 Q.
121
And I'm sorry. You said something besides
2 clear words, something else.
3 A. How many pages they read that day.
4 Q. All right. And what's the point of
5 keeping up with how many pages you read and how
6 many words you clear?
7 A. This whole system Is to monitor the
8 student's progress and whether he's getting better.
9 If his points go down, the supervisor wants to pay
10 attention because it means that something-- he's
11 not moving well on his course.
12 Q. All right. Then you've got a flunk on
13 liability as the last paragraph here.
14 A. Uh-huh.
15 Q. What does that mean?
16 A. It means that liability Is when somebody
17 has done something bad, like they say he's stolen
18 money from his parents or something, he's become a
19 liability. And then there's a formal that he needs
20 to do. It's covered in Book 7 to correct his
21 wrong. And a flunk means he didn't do it to our
22 standards, he di dn't do that formally and
23 correctly.
24 Q. All right. And then, "Main point that I
25 see need handling is Book 1." And you've got some
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1 things that you're specifying there. Just
2 summarize for me what that is all about.
122
3 A. It's mostly I would like to have seen them
do Book 1 a little longer, like more - - longer.
That's. the main thing.
Q. What Is Book 1 ag(!in? 6
7 A. It's the -- they do withdrawal and then
8 Book 1 is right after withdrawal. It's the
9 first ...
10 Q. Is that the first book you do before
11 sauna?
12
13
14
15
16
A. Yes.
Q, Does it talk about the purification
rundown or anything like that, or is it totally
separate?
A. No, it's separate. It's called the
17 therapeutic training routines.
18 Q. Oh, the TR?
19 A. Yes.
20 Q. You start doing the TRs then?
21 A. Yes.
22 Q. Okay. Let's turn to this next page, this
23 ethics chapter.
24 A. Uh-huh.
25 Q, This ethics section.
f--
1
2
A.
Q.
Yes.
Now, you note that Larry Chorvas is a
3 scientologist. Now, why did you note that?
123
4 A. It doesn't have much relevance. I just--
5 I noted it.
6 Q, Why?
7 A. Because he is, and it's something he told
8 me, so it's there in the report.
9 Q. "Bur" B-U-R, "has started an ethics
10 course." What does that mean?
11
12
13
14
15
16
17
18
19
20
23
24
25
A.
Q.
Where does it say that?
Next sentence. Oh, "but."
A. "But," yeah.
Q. So he's done an ethics officer course?
A. He has started on the Narconon ethics
officer course. He has not completed it, but he
has started it, the Narconon ethics officer course.
Q. And then you note that he has "outpoints."
A. Right.
Q, Okay. Tell me about that. If you would,
just summarize for me, when you looked at the
ethics portion of the program and you noted the
outpoints, what did you note and what was the
significance of those things?
A. Let's see. Well, there's one here. It
124
1 says Book 6 is where you learn about ethics and how
2 to write up your transgressions, and he had
3 somebody write up his transgression without knowing
4 the exact form that we would like them done in. He
5 had the student do without that study.
6 Q. And you're talking about the ethics
7 reports, and we talked about this a little bit
8 earlier. Is there a difference between the KRs and
9 the ethics reports that you're referencing in this
10 portion of your report?
11 A. Yeah. These are not really reports.
12 These are more. something the student does to put
13 his own ethics in, rather than have somebody say,
14 you know •••
15 Q. Now, the success stories that the students
16 write.
17 A. Uh-huh.
18 Q. All of those success stories are forwarded
19 to Narconon International, are they not?
20 A. Not to my knowledge.
21 Q. Okay. They're not required to be
22 forwarded to Narconon International so that
23 Narconon International can retain them in the
24 success stories' database?
25 A. Not as far as I know, no.
1
Q,
Do you know, one way or the other?
2 A. No.
3 Q. All right. The same thing, you refer to
4 these 0/Ws.
5 A. Yes.
6 Q. Something withholds?
7 A. It's averts and withholds.
8 Q. Overts.
9 A. Yes.
10 Q. And what does that mean?
125
11 A. Overts is basically these transgressions,
12 things that you do that you shouldn't have done.
13 And withholds is when you don't tell somebody about
14 it.
15 Q. And then you actually talk about a
16 different a report here about a student having
17 bought Xanax -- or excuse me, brought Xanax into
18 the housing unit.
19 A. Yes.
20 Q, Tell me about that. What did you --
21 A. I can't remember if it was a written or
22 verbal, but I believe Mary told me that a student
23 had brought Xanax into the housing unit ten days
24 ago.
25 Q. What I'm confused about Is that you pulled
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1 course folders for individual students and looked
2 at those,--
3 A. Yes.
,
Q. -- right?
-
Was there some other-- when you're
6 looking into this question of ethics, was there
7 some other folder that had ethics reports and
8 knowledge reports and all that sort of stuff that
9 was separate from the student folders, or were you
10 just looking at individual student folders?
11 A. I didn't see any other folders than the
12 student folders.
13 Q. So when you're talking about these
14 Individual students In this portion of your report,
15 these are just students that you happen to randomly
16 grab a file on?
17 A. Yes.
18 Q. And then you go on to talk about this last
19 sort of couple paragraphs here of your report.
20 A. Uh-huh.
21 Q. You say that, "The students have not been
22 under good control after they are done with their
23 services."
24 A. Yes.
25 Q. "And that's a major factor in my opinion."
-
127
1 What did you mean by that?
2 A. What I mean by that, this is actually the
3 first time I've ever looked at an outpatient
4 center. I've never encountered that kind of setup
5 before. So at Arrowhead and other Narconons I've
6 worked at, it's 24 hours a day. We have them 24
7 hours a day, and they don't go anywhere when
8 they're done for the day. And, obviously, these
9 students or patients at Georgia were not under
10 their control once they're done for the day, and in
11 my opinion, that created some problems.
12 Q. Okay. And that's basically the summary of
13 what you found during the inspection, according to
14 your report here on the last page?
15 A. No.
16 Q. Well, It says, "This is a summary of what
17 was found on the inspections," does it not?
18 A. The above.
19 a. Right.
20 A. Yes. Here is my summary.
,
a. Oh, I'm sorry. Okay. I understand. But
:.t. ... then you write this paragraph?
23 A. Correct.
24 a. And that's what I'm trying to get to, was
25 that basically sort of your--
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A. It was my opinion. It was my thought
after I finished the inspection and -- you know,
Mary had mentioned something about, you know, she
was not happy with the housing. It's just -- I
never seen this before. And to me, It could be
difficult, because I mean, it wasn't a bona fide
outpatient center, but it could be difficult
because the students leave for the night.
Q. Do you know whether any of the students
were actually required to be there as a condition
of probation or some sort of Court Order that
required that they have 24-hour-a-day supervision
and monitoring?
A. No.
a. Did you look into that at all, that issue?
A. No.
Q, Did you discuss that with Mary?
A. No.
Q. All right. So you note that you don't
think that the students are under good control
after they leave the facility, right? You note
that in your report.
A. Yeah, because as far as I know, they were
out of Narconon's control when they were done for
the day.
129
a. And then you show-- and you say, "The
folders show that many students revert during the
night."
A. Right.
a. What does that mean?
A. It means in some of the folders I looked
at, obviously, I found there are students that
reverted and that it had happened during the night.
Q. What do you mean "reverted"?
A. It means. relapse. It means taking drugs.
Q. Okay. And then you observed UAs today and
two tested positive for drugs. What's a UA?
A. It's a urinalysis.
Q. It's a urinalysis.
A. Yes.
Q. All right. So two of the urinalyses that
you looked at while you were there tested positive
for drugs?
A. Yes.
a. And then It says, "The ED Is working on
getting this changed and getting new housing set
up."
A. Right.
a. All right. What does that mean?
A. That's what she told me. She told me she
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1 was not happy with where the students were staying 1 Q. All right. Now, let's look at your email
2 at night and she wanted to get a different
3 arrangement.
Q. "There must be good control on these
... guys."
6 A. Again, it's my opinion. I think, you
7 know, it's easier if you have an inpatient setting
8 than if you have an outpatient.
9 Q. And finally it says that, "Mary says that
10 a lot of the trouble has come with the housing
11 being out of control, which is understandable. "
12 A. Yes.
13 Q. What does that mean?
14 A. Again, it's out of Narconon's control.
15 It's like when they're gone for the day, it's not
16 like at Arrowhead, we have security, we have
17 cameras, we have, you know, where we can monitor
18 them better and make sure they don't get In
19 trouble.
20 Q. And you reported these concerns that
21 you've outlined for me here in your report, you
22 reported all of those to the director of production
23
24
25
at Narconon International?
A. This is the report.
Q. Right.
-
1
2
A.
Q.
Yes.
Okay. And then you go on to say that
3 you're going to send them a list of other handling
4 steps that you propose?
5 A. Yes.
6 Q. Did you do that?
7 A. No.
8 Q. Why not?
9 A. I didn't come up with anything else.
10 Q. All right. And then you said, "I'll send
11 you the rest of the crams when done."
12 A. Yes.
13 Q. Is that the same ones you and I talked
131
14 about earlier In your deposition, the ones on your
email the following day? 15
16
17
18
19
20
2 ~
23
24
25
A. Yes.
Q. But you never did any other conditions
that you thought that they needed to --
A. No. My follow-up email was kind of the
last -- the last thing.
Q. And then what does "ML" mean?
A. Much love.
Q. That's a new one. I haven't seen that
one.
A. Okay.
2 of the next day.
3 A. Uh-huh.
4 Q. Now, you provided Mary with a copy of your
5 report?
6 A. Yes.
7 Q. And then I assume she had some feedback,
8 and you discussed the report that you were going to
9 send with her?
10 A. I gave her the report, she read it and
11 said --I wanted to see if she had any
12 disagreements with anything that I wrote, and she
13 was like no.
14 Q. All right. So you told her, this is what
15 I'm going to send In, do you have any disagreements
16 with it?
17 A. Yes.
18 Q. But there are a couple things that you did
19 clarify here, after, I guess, your discussion with
20 Mary?
21 A. I don't remember who I talked to. It's
22 just when I went over the report, I got more
23 information and I found my sentence that I hadn't
24 completed.
25 Q. All right. Now, twice in your report you
133
1 refer to PTS interviews?
2 A. Yes.
3 Q. And that's a potential trouble source?
Yes. 4
5
A.
Q. "Mary confirmed that the E/0 now does PTS
6 interviews and handlings."
7 A. Yes.
8 Q. What does that mean?
9 A. It means-- how can I explain this without
10 taking a long time. It's preventive for a
11 potential trouble source. There's a Book 5. It's
12 about-- it's called Ups and Downs in Life. And
13 it's about, you know, people can be brought down by
14 others who don't mean them good. We actually call
15 them suppressive. You know, they're there to
16 squash, keep the person down.
17 So the PTS interview is to locate that
18 person, if there is one like that. You know, if
19 there's a teacher that was beating him over the
20 head all the time and making them feel bad about
21 themselves, they can become potential trouble
22 sources because of that, and so we locate who is it
23 that made you feel bad.
24 Q. But I guess just In the context of your
25 report here, I'm sort of confused about that. You
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1 had asked Larry about-- "I asked him if he did a
2 PTS interview or handling, and he said he did not
3 but he was starting to do it." And so was that
just one of your concerns, that if there are these
" potential trouble sources, they needed to be dealt
6 with? Is that what you're trying to say?
7
8
A.
a.
Yes, they needed to get -- yes.
Okay. And then Mary Is saying that the
9 E/0 Is going to handle that?
10 A. Yes.
11 a. Okay. I just was confused.
134
12 And then you've got this thing down here
13 in some foreign language. What does this mean?
14 A. It says, "Find your new laptop on
15 kelkoo.dk." I use kelkoo.dk, so this is a little
16 Danish advertising.
17 a. Oh, okay. All right. Thank you.
18 All right. And then you sent the crams
19 that we talked about?
Yes. 20
21
A.
a. Were you provided with any of the reports
22 about Patrick's death or any documentation about
23 his death or anything like that before you went
24 down and did your tech inspection?
25 A. No.
f-
1 a. You said you had a conversation with
135
2 Yarko. Did you discuss any of the circumstances of
3 Patrick's death with anybody else before you did
4 your tech inspection?
5 A. No.
6 a. You submitted the report that you and I
7 have been talking about. I think you told me
8 earlier, you provided the crams, but you don't know
9 whether or not they ultimately were done or acted
10 upon or anything like that?
11 A. Correct.
12 a. Did you have any follow-up conversations
13 with anyone about your report?
14 A. No.
15 a. So you just turn in your report, and you
16 turn in your crams and you send the one report and
17 the one email that you and I have been talking
18
19
20
about, and there are no further conversations about
this inspection?
A. No, not until the deposition.
a. Well, Is that-- that just strikes me as
2" odd. And I'm not saying one way or the other, it
23 just seems odd that no one would call you up and
24 talk to you about lt. I mean, is that typically
25 how it would work?
1 A.
136
I had a phone conversation with Yarko
2 before I left. And it's a little unusual because I
3 didn't-- if I had been at Narconon INT, it
4 probably would have been different.
5 a. Oh-huh.
6 A. But I had my job at Arrowhead, so I went
7 and did this, turned it in, and got back to my job
8 at Arrowhead, because It was not my Job or to
9 follow up. My job, what I had agreed to do, do the
10 inspection, issue the corrections, and then I was
11 out of the picture.
12 a. And t hat sort of goes back to what you and
13 I talked about earlier in your deposition. I was
14 just curious as to why they would sort of pick you
15 to go do it when you weren't working for
16 International, you were working for Arrowhead.
17 A. I mean, all I can think about is that they
18 picked me -- I don't know why. They didn't tell me
19 why exactly me. I've done these things before.
20 Sometimes many people from Narconon International
21 are out in the world, so maybe they didn't have
22 somebody to send and they wanted it done, and
23 because I've done it before, that's all I can think
24 of.
25 a. You got tagged to do it in this instance
137
1 because--
2 A. Exactly. And here I am.
3 a. No good deed goes unpunished.
4 A. Exactly.
5 Q. All right. Just a few things. I want to
6 go back to something that -- and I'm almost done,
7 just so you know.
8 A. Okay.
9 a. I want to go back and talk about something
10 that's a little confusing, and I want to make sure
11 it's clear.
12 A. Uh-huh.
13 a. The structure of Arrowhead and
14 International and all of that, when you were there,
15 you left International in 2004?
16 A. Yes.
17 Q, Or was it International you left, or was
18 it Europe that you left In 2004?
19 A. Oh, I left Europe in 2004.
20 Q. 2004.
21 How many Narconon facilities are there
22 around the world?
23 A. Don't know exactly today.
24 a. How many of them are there in Europe? And
25 let me just - - if I'm not-- let's talk about when
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1 you were in either International or in Europe.
2 A. Yes.
3 Q. I'm not asking you about today because I
- realize you're now at Arrowhead.
" A. Uh-huh.
6 Q. But back when you worked at Europe, when
7 you left In 2004, how many individual Narconon
centers were there in Europe? 8
9 A. It would have to be an approximate, and
10 I'll say 20.
11 Q, 20?
About, yes. 12
13
A.
Q. And then when you were at International,
14 do you recall how many individual Narconon centers
15 there were at that time?
16 A. I don't know. I remember there was only
17 two In the United States. There was one in Canada
18 and the ones in Europe that were already there. I
19 think that's it.
20
21
22
23
24
25
Q. When you were at International, were you
familiar with the interactions between the
Individual centers and Narconon International?
A. Excuse me. I wasn't paying attention.
Q. You nodded off in the middle of that
question it was so stimulating?
-
139
I'm sorry. 1
2
3
4
5
6
A.
Q.
A.
Q.
A.
Q.
When you were at Narconon International --
Yes.
-- In the early 2000s, --
Uh-huh.
-- were you familiar with sort of the
7 day-to-day Interactions between individual Narconon
8 centers and International?
9 A. Yes.
10 Q. And the way that I understand it's set up,
11 and I don't know if it was set up that way at the
12 time, but there's Narconon East U.S. and Narconon
13 West U.S.?
14 A. Correct.
15 Q. Was that the way it was when you were at
16 International?
17
18
A. I don't think there was a Narconon
East/West at that time.
19 Q. Well, there wouldn't have been a Narconon
20 just West U.S., I suppose?
7 A. Well, I think at that time there was a
21. West U.S. and there was no East U.S.
23 Q. Because there are no eastern centers?
24 A. There probably wasn't, no, because there
25 was Arrowhead and then the California ones.
1
Q,
140
All right. What Is Narconon -- back when
2 you were there, what did Narconon West U.S. do on a
3 day-to-day basis in terms of interacting with the
4 centers? What was their role In all this?
5 A. They would do the inspections themselves.
6 Narconon West U.S. at the time was-- I almost
7 can't remember who was there. It was very new and
8 just getting set up.
9 Narconon West U.S. has a registration
10 office that does the intake for all the different
11 centers. So that's one of the things they were
12 monitoring, was that office.
13 Q. Okay. So the registrars for all of the
14 centers worked for West U.S. when you were there?
15 A. I don't know if it was corporately part of
16 that, but there's an office that does registration
17 for all of the West U.S. centers.
18 Q. All right. Now, tell me again when you
19 left International, what was your job title at
20 International?
It was operations supervisor. 21
22
23
24
25
A.
Q. So you have the same job that Yarko has
now?
Correct, or -- yes. A.
Q. What does that job entail? What do you do
1 -- or what did you do? It may have changed, I
2 understand that. But what did you do as the
3 director of production when you were at Narconon
4 International?
141
5 A. I would get all the reports on Thursday
6 and look at the statistics, how it was going, and
7 look at the report, and send them a response
8 saying, you know, I think this is good, I think you
9 could look at that, you know, just advice,
10 consultancy. I would -- I did a few inspections
11 myself. I would direct inspections to be done, and
12 sometimes talk and call the centers, talk to the
13 ED, how's it going, need help.
14 Q. And what sort of help would you offer
15 them, If they needed it?
16 A. It would be, you know, if-- you know,
17 sometimes an ED can get, you know, too much and
18 sometimes they can come out to Narconon for the
19 meetings. Sometimes they want to get an
20 inspection, you know, because they feel there's
21 things that are not going well. That kind of
22 stuff.
23 Q. When you were at Narconon International,
24 and I can find the document on here, but there was
25 a document that's been provided to us that refers
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1 to the Narconon INT database. 1 A. When I was there, what we did is we would
2 A. Uh-huh. 2 have the report and the slats, and kind of look at,
3
Q,
Is there a database that exists at 3 okay, how is it going here. And yes, the response
International where all of the weekly battle plans 4 to report, we always want them to get better. So
~ and all that sort of stuff and the weekly 5 you' d say, yeah, you know, it doesn't look like
6 statistics, all that is forwarded by the individual 6 it's going so well in this area, you may want to
7 centers to International? 7 take a look.
8 A. When I was there, it was - - ther e was 8 Q. And I'm glad you brought that up. I was
9 paper, like paper folders. 9 talking about -- I was really talking about the
10 Q. There wasn't any kind of computerized 10 statistical report. But In addition to the
11 database when you were there? 11 statistical report that you have to generate every
12 A. No. 12 Thursday at 2 o'clock, you have a weekly -- the
13 Q. All right. Let's talk about that. In 13 executive director has a weekly report that they
14 terms of when you were there at International, what 14 have to send to International, right?
15 exactly did the Individual centers have to report 15 A. Yes.
16 back up to International? 16 Q. And is that a requirement; you've got to
17 A. The weekly statistics. 17 send your weekly report every week, or the phone
18 Q. And just let's break them down. 18 rings and they say, "Where the heck's your weekly
19 So every Thursday afternoon -- 19 report"?
20 A. Uh-huh. 20 A. It's not -- when I was there, not
21 Q. -- is it 2 o'clock? 21 everybody did it.
22 A. The week ends at 2 o'clock. 22
Q,
Okay. Well ...
23 Q, The week ends at 2 o'clock. 23 A. You asked them, and they may or may not.
24 All right. Every individual center is 24 Q. All right. But was there an expectation
25 required to report their statistics to 25 that they would do a weekly report?
143 145
1 International? 1 A. Yes.
2 A. Correct. 2 Q. Some of them were slack and didn't, is
3 Q. And there's a list of a number of things, 3 what you're telling me?
4 which I won't go Into here with you, but there are 4 A. I'm just saying some of them didn' t.
5 a number of things that have to be reported to 5 Q. You don't like the "slack" part?
6 International? 6 A. No.
7 A. When I was there, yes. 7 Q. All right. Fair enough.
8 Q. Okay. And you know the same thing exists 8 Some of them, for whatever reason, didn't
9 now because you have to do It Arrowhead? 9 do what you expected them to do?
10 A. I don't have to do it. 10 A. Correct.
11
Q,
Okay. Well, thankfully. 11
Q, In addition to the weekly report and the
12 A. Thank God. 12 statistical report, there was also a weekly battle
13
Q, All right. Is it a pain to put all the 13 plan that the individual centers put together. Is
14 statistics together? 14 that fair?
15 A. It's not a big deal. 15 A. Some of them did, yes.
16 Q. And all of the things are reported back up 16
Q,
All right. Was there an expectation that
17 to International on a weekly statistical reporting? 17 they do that?
18 A. Yes. 18 A. It usually came together, the report and
19 Q. And then International determines whether 19 the battle plan, yes.
20 or not you're up stat or down stat, right? 20 Q. And in fact, those things, the weekly
A. They determine - - yes, whether, you know, 21 report, the statistics and the battle plan are all
:c: ... t hings are going better or things are going worse. 22 spelled out in how to run an effective Narconon?
23 Q. And if you're down stat, meaning your 23 A. The battle plan, yes. The statistics,
24 statistics have fallen off from the previous week, 24 yes. I'm not sure about the weekly report that is
25 they let you know about it, right? 25 In there. I don't think it Is.
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1 Q. All right. When you were the -- whose job
2 was it if you got a report or you got statistics or
3 you had an issue about the battle plan, whose job
-
was it at International, when you were there, to
"
respond to any issues that came up In those
6 reports?
7 A. Mine.
8 Q. The director of production?
9 A. Well, at the time I was there, I can't
10 remember if it was anybody else. It is whoever is
11 --I think Narconon is bigger today, so I think
12 there are other people under the CD production who
13 may be over one continent. I don't know who they
14 are, but it's whoever is responsible for, you know,
15 that center or •••
16 Q. Okay. Any other sort of required reports
17 that had to go upstream from the individual centers
18 to International when you were the director of
19 production, other than the ones we've talked about,
20 the battle plans, the weekly reports, and the
21 weekly statistics?
22 A. No.
23 Q. Any annual reports or anything like that
24 that had to be done and sent upstream?
25 A. No.
-
147
1 Q, How else -- was there any other way that
2 International would know what was going on on the
3 ground, so to speak, at the individual centers?
4 A. Only phone calls now and then, the reports
5 and the inspections.
6 Q. All right. Let's talk about the
7 inspections. And I think you told me that those
8 were random?
9 A. Yes.
10
Q, Was there any requirement that a facility
11 had to be Inspected every -- at least every year or
12 every two years or anything of that nature?
13 A. There's nothing -- no, no rule about it.
14 Q. The license agreement -- there's a service
15 agreement and a license agreement, at least in this
16 case. Was that typically how it worked? Was there
17 a service agreement and a license agreement?
18 A. The only one I was aware of at the time
19 was the license agreement. I don't know what a
20 service agreement is.
7 Q, Okay. Now, you said if they needed help,
2 ~ if the center had some Issue, the individual center
23 had some Issue that you were there as a director of
24 production, you would offer help?
25 A. Yeah.
1
2
3
4
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148
Q. And I want you to tell me a little bit
more about that. In what ways did you offer help?
A. It could be as little as talking to
somebody over the phone and trying to give them
advice on whatever they were having difficulty
with, or as I said, send out an inspection would be
a possibility so that we could look more thoroughly
at what was needed.
Q. Okay. So you could send out a team of
inspectors or an inspector like yourself--
A. Yeah.
Q. -- in this case, look at the facility,
tell them where they're deviating from the tech and
give them ways to fix it?
A. Correct.
Q. And that's something that you did when you
were there?
A. Yes.
Q. All right. Was there someone at
International, when you were there, who ensured
that the individual license fees were paid every
week by the centers?
A; I don't know. I was not involved -- I was
only involved in the operations, so I don't know.
Q, Okay. When the Inspectors would go in to
visit the facility to offer whatever assistance
they might offer, who paid for that?
A. I don't know.
Q. When you were the director of production
and you sent an inspector to a facility, you don't
remember whether or not International paid for It
or the individual center did?
A. I think it was --It was different.
149
Sometimes we would ask the center to pay for the --
there was no payment for the inspection, as far as
I remember. Sometimes Narconon International would
just pay for the tickets, the hotel. Sometimes we
would ask the center to do it.
Q. Okay. And then the training that the
individual employees received for the centers, it's
my understanding that most of the training takes
place at Arrowhead, is that correct, or there's an
expectation that centers will send their employees
over to Arrowhead so that they can be trained in
how to provide various services?
A. A lot of the training is done at the
center, some is done at Narconon International,
some is done at Arrowhead.
Q. Is there anything that you have to have --
that you have to receive your training by
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2
3
International in order to operate a center?
A. No.
Q. So you can do it all-- you can do your
150
training however you can do it, I guess is the best
way to put it?
6 A. You have to have a trained --there's a
7 supervisor course. You have to have a person who
8 has done that course, and then you can train your
9 own staff.
10 Q. Do you have to be a scientologist to be an .
11 executive director of a Narconon center?
12 A. No.
13 Q. Can you Identify anyone who Is an
14 executive director of a Narconon center anywhere in
15 the world who is not a scientologist?
16 A. I don't know all the executive directors.
17 Q. That wasn't my question.
1 the director of production when you were at
2 International with anyone on a sort of recurring
3 basis with ABLE?
4 A. None.
5 Q. None?
6 A. None.
7 Q. Ali right. This 9826. It's another
8 document in here.
9 A. Okay.
152
10 Q. The "DCA ABLE !NT," what is that? What's
11 that job title? I know you may not know who that
12 is now. What is a DCA.
13
14
A.
Q.
I can only guess.
Your guess is going to be more accurate
15 than mine is.
16 A. Director of corporate affairs, I believe.
17 Q. Is that an org boarded title?
18 A. I know that was not your question. I have 18 A. I don't know the ABLE org board. This is
19 to think. Give me a moment.
20 Q. Okay.
21 A. I don't know of any.
22 Q. All right. This exhibit that you have in
23 front of you, I 'm going to ask you -- there's a few
24 job titles here. The legal director of Narconon
25 International, would that be Claudia in 2008, or do
-
151
1 you know?
2 A. Yeah, that was Claudia.
3 Q. The executive director of ABLE East U.S.,
4 do you know who that is?
5 A. That's Yvonne.
6 Q. Yvonne. That's the one we talked about
7 earlier, right?
8 A. Yes.
9 Q. What does she do? What's her job?
10 A. She's like the continental director for --
19 ABLE. I don't know.
20 Q. And then "D/DLA Narconon I NT"?
21 A. I don't know.
22 Q, On this first page that you and I just
23 talked about, the DSA and OSA is copied?
24 A. Uh-huh.
25 Q. At any point in time, when you were the
153
1 director or when you were working at Narconon
2 International, did you copy the DSA or OSA on any
3 issues that came up?
4 A. Not as far as I remember.
5 Q. Well, do you know, was there any
6 expectation for certain kinds of things that might
7 come up that the DSA or OSA be copied?
8 A. No. I mean, I dealt with - - you know, my
9 seniors were Narconon International. I was never
10 asked for-- supposed to send copies to anyone
11 oh, ABLE. No, I don't know who that is. 11 outside of Narconon.
12 Q. What was the-- when you were the director 12 Q. Ali right. But I guess what I'm trying to
13 of production when you worked at International, 13 get to is, is there any kind of rule, whether it's
14 what was the relationship between ABLE and 14 written or unwritten, or requirement, or
15 Narconon? 15 expectation, within the Narconon establishment that
16 A. ABLE is the-- they own the trademarks, 16 if certain kinds of events take place that you need
17 and they license Narconon International, who then 17 to copy DSA or OSA on those events?
18 licenses the centers. 18 A. No.
19 Q. Right. But I'm talking about on a 19 Q. And then the one that you and I were just
20 day-to-day basis. Was there any requirement that 20 talking about, there is a lady named Gwenda.
,. you report activities of individual centers to 21 A. Uh-huh.
~ . . . ABLE? 22 Q. Who is that?
23 A. I didn't have anything li ke that, no. 23 A. Gwenda is the person that I know, last
24 Q. As the director of production, did you 24 time I knew, is the director of corporate affairs.
25 have --tell me what interaction did you have as 25 Q. Okay. So you think-- so you're pretty
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1 comfortable that's what that means, the DCA. I
2 thought you said you were taking a guess.
3 A. I am taking a guess.
Q. All right. Well, you know a woman named
• Gwenda whose job was the director of corporate
6 affairs at ABLE?
7 A. Her title has changed. I mean, I'm not
8 trying to not be straight here.
9 Q. I understand.
10 A. It's been called legal affairs. It's been
11 called corporate affairs. It's been called--
12 Q. Got it.
13 A. So whether that's her title today, I don't
14 know for sure and for certain.
15 Q. What's her last name?
16 A. Burns.
17 Q. Burns?
18 A. Yes.
19 Q. Do you know what she does?
20 A. I don't know what she does now.
21 Q. Well, when you knew her and she had some
22 different title, what did she do?
23 A. She was over legal and corporate affairs
24 of ABLE International.
25 MR. HARRIS: I think that's all I have for
155
1 you. I appreciate your time. Give me two minutes
2 to look through my notes real quick, but I don't
3 think I have anything else.
4 THE VIDEOGRAPHER: Stand by, please.
5 (WHEREUPON, a recess was taken.)
6 THE VIDEOGRAPHER: Back on the record. Go
7 ahead.
8 By Mr. Harris:
9 Q. I don't have a copy of this, but it's
10 Bates number International 1018. And this is just
11 a copy of a weekly statistic report that I realize
12 is done after you were at International.
13 A. Uh-huh.
14 Q. But in this particular document, the
15 weekly reports go to the op superintendent of
16 Narconon International, which is Yarko. I think
17 we've established that.
18 A. Uh-huh.
19 Q. But all of the weekly reports are also
20 copied, the ones that have been provided in this
156
1 A. No.
2 Q. All right. So when you were there, they
3 weren't -- ABLE wasn't copied on the weekly stats?
4 A. No.
5 Q. Were they forwarded?
6 A. From Narconon International, it was then
7 summarized and sent to ABLE.
8 Q. Got it. Okay. And when you say
9 summarized --
10 A. I mean we would do totals and stuff, you
11 know, of a continent, yeah.
12 Q. All right. But you didn't send the raw
13 data, you summarized it all and sent it upstream to
14 East U.S.?
15 A. Yes.
16 Q. Did you have to do that every week?
17 A. Yes.
18 Q. Every Thursday at 2 o'clock, International
19 has to report upstream to ABLE the summarized
20 stats?
21 A. Yes.
22 MR. HARRIS: All right. Thank you, ma'am.
23 I appreciate your time.
24 THE WITNESS: All right.
25 THE VIDEOGRAPHER: We're off the record at
157
1 1:29.
2 (Whereupon, the taking of the deposition
3 is concluded at 1:29 p.m.)
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case, to the executive director of ABLE East U.S. 21
2..: A. Uh-huh. 22
23 Q. Was that the practice that took place when 23
24 you were the director of production at
25 International?
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158
JETTE McGREGOR
Subscribed and sworn to before me this ___ _
day of ___ ____ , 2012.
Notary Public
9 My Commission expires:
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159
CORRECTIONS TO THE DEPOSITION OF
JETTE McGREGOR
Civil Action No. : 10A28641-2
Page, line Change Reason therefor
160
1 CERTIFICATE
2 STATE OF OKLAHOMA )
) ss
3 COUNTY OF TULSA )
4
5 I, TRISHA G. GOODMAN, a Certified Shorthand
6 Reporter in and for the State of Oklahoma, do
7 hereby certify that on Friday, June 8, 2012, at the
8 offices of Holden & Carr, 15 East 5th Street,
9 Tulsa, Oklahoma, appeared the above witness, Jette
10 McGregor, who was by me duly sworn to testify the
11 truth, the whole truth and nothing but the truth in
12 the case aforesaid and that the deposition by her
13 was reduced by me in stenography and thereafter
14 transcribed under my supervision, and is fully and
15 accurately set forth in the preceding 159 pages.
16 I do further certify that I am not related to
17 nor attorney for any of the parties hereto or
18 otherwise interested in the event of said action.
19 WITNESS my hand this 21st day of June , 2012.
20
21
TRISHA G. GOODMAN
22 CSR # 1770
Expires: 12/31/12
23
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25
41 of 51 sheets
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Deposition of Jette McGregor - 6/8/12
4 - 3:4
400-2:4
administered- 47:5,
49:13,74:21 , 76:1,79:6
administration- 57:13,
'87- 6:10 5 57:14
136:16, 137:13, 138:4,
139:25, 143:9, 149:17,
149:19, 149:23
'94 -13:20, 14:13 .... - ...... -__::=-------1 admlnlstrator-103:5
...._-----------1 5- 77:7, 133:11 administratrix - 1:4
asserted - 18:21
assistance - 149:1
Association- 14:11
assume- 73:2, 98:17, 1 58- 3:9 admission - 97:20
Sth -160:8 advertising -134:16 102:13, 119:8, 132:7
assuming -11:20, 45:7,
74:8
1-3:9, 58:11, 58:15,
64:17,78:12,121:25, 122:4.
122:6, 122:8
1-800 - 109:10
1-900 -109:1
10-112:15
1018-155:10
10:18 - 22:25
10a28641-2 - 1:6, 159:2
11:07-58:10
11:30 -104:7
11:45-104:7
12/31/12-160:22
1201-2:4
12:34-112:22
15-1:18, 160:8
15/16-3:13
159-160:15
15th -1:18
16th- 59:1, 70:14
1770 -160:22
17th- 69:25
18- 3:13
191 - 2:12
1966-34:15
1983 -6:10, 12:13
1987 - 6:10
1990 ·6:12, 13:20
1993-11:18,11:19,11:21
1994 -10:19, 14:6
1:29-157:1, 157:3
2
2 - 108:18, 142:21 , 142:22,
142:23, 144:12, 156:18
20-138:10, 136:11
200- 120:13
2000-14:17,23:13,23:14,
23:16, 23:19, 38:19
2000s - 139:4
2004-23:19, 23:20,
137:15, 137:16, 137:19,
137:20, 136:7
2005-61:16
2007-15:4
2008- 5:20, 6:1' 15:5,
16:25, 23:7, 27:11, 50:18,
50:24,51:17,51:25,59:2,
59:12, 150:25
2012-1:17,158:5, 160:7,
160:19
21st-160:19
24-127:6
24-hour-a-day -128:12
288-2:16
3
3-77:10, 77:13
30-104:23
30-mlnute- 39:10, 41:24
300-120:13
30060-2:17
30303-1740-2:13
30357-2:9
30361-2:5
3600-2:12
3900-1:18
6
6- 77:7, 94:24, 124:1
6/12/08 - 3:9
advice -141:9, 148:5
affalrt- 20:13, 114:16,
152:16, 153:24, 154:6,
154:10,154:11,154:23
Affalrt- 19:25, 20:21
affiliated- 45:9,45:15,
Atlanta- 2:5, 2:9, 2:13,
106:14
7 85:4, 110:9, 110:10, 111:1,
.... 111:2, 111:3,111:4, 111:7,
Attached- 68:20
attached- 69:6, 69:10
attain - 14:25
attained - 13:25
7-77:8, 121:20 111:10, 112:8
749-1661-2:18 affiliation -110:4
attend - 98:3
8
aforesaid - 160:12
afternoon- 120:23, 142:19
agency- 109:21
agenda - 61:8
attended- 61:1
attending - 97:25
attention- 96:24, 121:10,
138:23
ago -18:3, 28:15,32:1,
1-----------1 41:21,44:23,52:8, 71:8,
125:24
8-1:17, 78:13, 160:7
880-2:8
attomey -10:3, 17:7, 17:8,
17:12, 18:18, 21:10,21:22,
26:18, 29:9, 160:17
audit-117:17, 118:1,
119:8
9
900-2:4
918-2:18
9826- 152:7
9828 - 58:21' 62:20, 64:15
9829-91:13
agree - 54:23, 101:17
agreed- 136:9
agreement -101:18,
102:1,102:2, 102:6, 105:1,
147:14, 147:15, 147:17,
147:19, 147:20
auditing -117:21 , 118:1
auditor -117:7, 117:14,
9830 -105:14, 115:8
9832 - 64:17, 68:20
9:51- 1:16, 4:2
9:59- 10:12
ahead- 4:2, 10:12, 16:7,
22:25,44:7, 58:10,72:21 ,
155:7
alcohol-109:11,111:23,
1----------1 118:9
117:19, 117:23, 118:4
authored - 59:2
authority- 75:9, 78:16
authorize - 75:5
Avenue- 2:16
aware-9:21 , 16:4, 73:18,
116:19, 118:11, 147:18
A
Abby- 116:10,116:25,
117:3, 118:13, 119:10,
119:17
Able- 7:7, 7:9, 7:19, 7:23,
8:3, 8:25, 9:3, 13:19,55:12,
56:4, 67:14, 67:15, 151:3,
151:11, 151:14, 151:16,
151:22, 152:3, 152:10,
152:18, 152:19, 154:6,
154:24, 155:21' 156:3,
156:7, 156:19
able- 36:7, 67:9, 72:8,
75:1 o. 77:11' 78:4
Absolutely- 58:3, 104:3
accept- 98:11
accordance- 4:12, 4:13
according -127:13
accurate- 152:.14
accurately - 160:15
achieved- 9:10
acknowledgment- 79:19,
79:22
acquire - 55:18
Act- 4:11, 4:13
acted - 135:9
action -160:18
Actlon-1:6, 159:2
actions - 55:11
activities- 7:3, 8:23,
14:14, 36:23, 151:21
actual - 41:12, 101:5
Adams- 116:5, 116:10
Adams'-116:24
addict- 34:17
addition- 69:1, 144:10,
145:11
additional - 71 :24
address- 67:22, 70:19,
81:12,93:13
addressed- 73:6, 106:18
allow-97:4
allowed- 4:11, 105:4,
111:14,111:15 background-6:7
almost-104:6, 137:6, bad- 92:4, 94:23, 121:17,
140:6 133:20, 133:23
amount-104:24 badly- 91:16
Angeles- 6:11, 46:21 , 85:5 Bailey-116:10, 117:4,
annual-60:21, 60:23, 118:13
146:23 Balley's-116:25
answer- 5:9, 15:23, 16:2, Ballard- 2:18
18:18, 18:23, 22:8, 26:20, bank- 53:24, 54:8, 54:9
35:5, 37:17, 49:23,50:8, Barbara- 2:7, 26:3,82:5,
59:20, 92:24 113:8
8
answens - 43:2 based - 34:23, 35:1, 57:22,
anyway- 36:23 70:22, 71:11
Apartment- 1 :9 basic - 115:20
apologize- 59:10 basis- 47:22, 140:3,
Appearances- 2:1 151:20, 152:3
appeared -160:9 Bates- 58:20, 155:10
Applied- 8:9, 8:23, 9:1 battle -142:4, 145:12,
appreciate- 56:9, 155:1, 145:19, 145:21, 145:23,
156:23 146:3,
appropriate -105:13 beating- 133:19
approximate- 138:9 become- 68:11 , 121:18,
April- 23:19 133:21
area- 54:19, 55:24, 71 :5, began- 75:21
71 :6, 144:6 begin -17:25
areas- 57:11,86:15, 91 :1 beginning -14:17, 101:15
Arizona - 34:21 behalf- 1:16, 16:6, 83:8
arrangement - 130:3 below - 7:10, 8:3
Arrowhead- 5:19, 6:2, Benitez- 34:16
11:2,11:5, 15:8, 15:10, best-49:20, 150:4
15:17, 15:19,16:11, 16:19, better-121:8, 130:18,
16:25, 17:15, 19:14, 23:8, 143:22, 144:4
23:17, 23:21, 23:24, 24:13, Betterment- 7:3, 7:10,
24:17,24:24,25:2,25:9, 7:12,7:13, 7:16,8:7, 13:11,
27:3, 38:22, 50:2, 50:21, 36:23
55:15, 57:7, 62:22, 73:12, between -15:7, 33:6,
75:6, 83:4, 83:14, 85:3, 89:9, 33:14, 33:16, 33:23, 34:7,
90:17, 90:20, 90:23, 90:25, 35:16,36:8, 37:5, 37:11'
108:15, 108:20, 111:5, 37:23, 38:11' 39:6, 43:5,
111:8, 111:15, 111:17, 52:24, 99:2, 101:18, 104:6,
1
111:20,111:24, 112:12, 105:2, 124:8,138:21 , 139:7,
LLC- 918. 749. 50MJ-. =
14
-.. ___ __.
4 addresses - 77:8
REPORTING
PO Box 2823 , Tu7sa, Ok7ahoma 74101
06/28/2012 05:57:10 PM Page 1 to 1 of 10 42 of 51 sheets
http://ReachingForTheTippingPoint.net
Deposition of Jette McGregor - 6/8/12
Big- 53:13,53:14, 53:18
big -143:15
bigger -146:11
billion -14:3
birth - 34:23
birthday- 99:5
bit -'5:15, 6:6, 9:6, 15:16,
29:25, 36:15, 48:22, 50:10,
62:7, 74:14, 79:7, 96:22,
102:21,124:7,148:1
board -107:15, 107:24,
108:3, 152:18
boarded - 152:17
boards -116:10
bona -128:6
Book-77:7, 77:10, 77:13,
78:12, 78:13, 94:24, 121:20,
121:25, 122:4, 122:6, 122:8,
124:1' 133:11
book- 34:17, 34:23,
53:11,54:11,68:3,78:22,
80:6,80:21, 119:24, 122:10
books- 35:1,56:20, 67:9,
67:23, 73:5, 78:5, 78:10,
78:17,79:1,80:3,80:17,
80:19, 80:23, 80:24
bottom- 58:21, 62:14
bought -125:17
bounce -112:24
box-104:6
break- 22:19, 23:2, 58:2,
58:4, 104:10, 142:18
breaks -104:21, 105:1 3
Brick- 53:8, 53:21, 54:5
brief- 39:20
briefly- 21:18
bring - 86:21
brought - 43:4, 43:7,
125:17, 125:23, 133:13,
144:8
bud- 31:20
bunch- 99:15
Bur- 123:9
Bums-154:16, 154:17
business- 8:10, 109:20
busted· 92:16, 92:20
55:15, 66:4, 67:23, 70:4,
72:3, 72:6, 78:15, 78:24,
79:4,80:5,82:8, 84:5,84:11,
90:23, 98:19, 98:24, 99:23,
101:1, 101:5, 108:16,
110:10,111:2, 111:3,
111:11, 112:9, 127:4, 128:7,
142:24, 146:15, 147:22,
149:7, 149:9, 149:13,
149:22, 150:1' 150:11'
150:14
centers -11:1, 33:14,
33:24, 37:11, 37:23, 38:12,
39:7,48:8,48:11,48:16,
49:2, 49:8, 49:16, 49:22,
50:15, 51:1, 52:3, 55:6, 55:9,
55:13, 55:20, 55:22, 56:5,
78:16, 87:13, 89:9, 91:2,
99:3, 110:6, 138:8, 138:14,
138:22, 139:8, 139:23,
140:4,140:11, 140:14,
140:17, 141:12, 142:7,
142:15, 145:13, 146:17,
147:3, 148:22, 149:15,
149:18, 151:18, 151:21
certain -12:6, 42:24,
49:18, 54:22, 55:10, 56:3,
94:4, 102:24, 103:10,
117:20, 153:6, 153:16,
154:14
Certificate- 160:1
certification -10:25, 11:1
Certifled - 1:19, 3:12,
160:5
Certify-19:7
certify- 160:7, 160:16
cetera - 118:6
chain- 89:12
Change-159:3
changed- 60:16, 129:21,
141:1, 154:7
chapter - 53:11 , 53:17,
122:23
charge- 13:4
charged • 48:25
charts- 74:19,74:20,
1----------t 74:25,91:21,103:24,103:25
C check- 49:11, 56:3, 56:7,
1----------t 86:3, 86:7, 88:8
C/s-105:15 checked- 87:10
CaJHomla- 25:6, 112:3, checklist - 49:11, 51 :22,
139:25 54:13,54:16, 54:24, 55:1 ,
Calvin- 2:15, 31:18 56:23, 57:5, 73:3, 73:17,
cameras -130:17 84:4, 84:7, 84:10,87:10,
Canada-138:17 87:23
cannot- 78:24, 81:4, checklists - 49:9, 55:5,
103:14 55:13,56:19,56:22
capacity -10:22, 11:5, checks- 86:10
16:5, 91:2 Cheryl- 2:11, 17:9
carbon -62:18 Chorvas- 123:2
care- 20:12 Church- 20:11, 33:7,
careful- 5:3 33:17,34:7, 35:16,37:1,
Carlock- 2:12 45:10,45:14,45:15,89:11,
Carolina- 1:10 117:16
Carr-1:18, 160:8 church - 12:22,83:8,
case - 28:23, 29:15,29:17, 88:22, 115:18, 115:22,
30:9, 30:10,30:23,32:5, 117:1, 117:7, 117:21,
66:9, 66:12,77:15,77:16, 118:14, 118:18,118:19,
77:24,78:3,78:4, 78:18, 119:15
80:5, 80:21 , 80:25, 81:1, circumstances- 113:15,
81 :10,81:11, 81:17,86:17, 135:2
86:20, 87:18, 89:17, 105:16, city- 46:20
105:18, 113:4, 147:16, Civil-1:6, 4:11,4:13,
148:12, 155:21, 160:12 159:2
cash -108:21 clarification- 56:10
cc- 62:18 clarifications - 35:8,
cc'd- 63:9 40:17, 41 :25
Cd- 61:10, 146:12 clarified - 96:21
center- 47:5, 47:10, clarify- 33:1, 39:5, 48:22,
clarifying- 64:20 45:21, 109:12, 110:15
Class-117:6, 117:13, contacted -18:7,27:22,
117:19,117:24, 118:4 29:6,32:4
Claudia- 29:4, 30:2, 30:6, contacting- 28:1, 32:7
30:7,114:11,150:25,151:2 contacts -61:19
Claudia's-114:13 context-133:24
clean- 5:10 continent -146:13, 156:11
clear· 20:7,57:17, 120:6, continental· 52:4,151:10
120:16,121:2,121:6,137:11 contract-14:3
clearly· 71:23, 102:14 control-126:22, 127:10,
Cleveland· 2:16 128:20, 128:24, 130:4,
clinical- 9:20, 12:1 130:11, 130:14
Clint- 9:23 conversation • 5:2, 19:3,
clock- 39:12 28:20,29:1,29:13, 30:1 ,
closet- 92:1 30:5,30:19,30:22,31:2,
co -118:1, 119:8 31:11, 31:16, 38:4, 39:10,
co-audit -118:1, 119:8 39:14, 40:8, 41:7, 41:8,
co-auditing -118:1 41:10,41:13,41:15,41:17,
Colony- 2:4 41:18,41:20,41:24,42:1,
comfortable -154:1 42:3, 42:16, 43:20,44:20,
coming -48:15,59:12, 45:1,95:25, 100:17, 103:11,
92:4, 97:16, 107:19, 110:15 106:3, 106:7, 106:19,
command -89:12 115:13, 135:1, 136:1
Commission-158:9 conversations- 25:20,
common· 71:3 26:12, 27:15,28:5, 28:9,
communications -18:19 31:5, 31 :9, 41:5, 44:1, 44:9,
companies -11:13, 16:14 44:11, 45:25, 83:25, 91 :7,
company-16:21, 16:23, 115:11,135:12, 135:18
16:24, 17:2, 24:24,27:3, conversed- 28: 17
27:6 conversing - 64:6
compensate- 24:18, cool-104:22
112:15 coordinated -44:8
compensated -18:4, Coordination- 7:2,7:20,
108:14,108:18,112:11 8:22,12:14,12:22,13:5
complaints- 92:12 Copeland- 2:12
complete- 79:2, 79:13, copied- 152:23, 153:7,
88:3, 88:15, 102:25 155:20, 156:3
completed - 33:11 , copies • 65:5, 153:10
110:14, 123:16, 132:24 copy- 40:3, 40:4,40:10,
Completely-76:6 40:20,41:1,42:6,46:4,
compliance· 68:2,68:12, 62:18,63:20,63:21,64:11,
81:25,84:11 64:15, 132:4, 153:2, 153:17,
complied - 102:6 155:9, 155:11
comply· 77:4,95:3 Corbin- 25:25
complying· 84:6 corporate · 6:20, 16:5,
component- 90:25 20:12, 114:16, 152:16,
composite- 58:18 153:24, 154:5, 154:11,
computerized - 142:10 154:23
concentrates· 57:13, corporately -140:15
57:15 corporation- 6:21
concerned - 55:11 correct- 5:23, 23:8, 25:21,
concerns -100:10, 103:9, 29:4, 31:6,36:5,54:17,
106:23, 130:20, 134:4 54:24,60:21 , 66:2,66:6,
concluded -157:3 69:22, 70:6, 70:7, 95:8,
condition- 79:9, 128:10 105:16, 121:20, 149:17
Conditions- 68:24, 69:15 Correct- 5:24, 6:16, 7:8,
conditions • 69:11, 70:9, 8:6, 11:6, 17:1, 23:9, 25:1,
93:12,94:6,131:17 26:25,27:4,27:8, 33:19,
conference - 21:24, 22:6, 33:25, 40:19, 42:5, 44:24,
25:24, 60:6, 60:9,60:21' 48:6, 48:10, 49:6, 50:19,
61:12 51:23, 53:19, 54:25,56:17,
conferences- 26:15, 60:3, 57:23, 60:10, 60:22, 63:11,
60:23, 61:6, 99:1 65:18, 67:21, 67:25,68:8,
confidentiality· 92:3, 95:6 68:22, 69:7, 71:18,72:10,
confidentiality-wise - 92:3 79:3, 80:18, 90:8, 93:20,
conflnned -133:5 93:23, 110:7, 112:10,
confused· 30:1,40:16, 112:18, 117:15,118:2,
81:22,106:5,125:25, 119:16, 127:23, 135:11,
133:25, 134:11 139:14, 140:24, 143:2,
confusing -137:10 145:10, 148:15
connection- 36:21, 64:24 correction - 65:20
consent ·101:10, 101:16, corrections· 71:21,
101:20, 101:21 136:10
considered - 7:15, 98:12 Corrections-159:1
consistent - 116:11 correctly - 92:24, 121:23
consultancy -141:10 counsel - 26:4
consultant- 13:22 counseling - 111 :23
consulting -10:23, 10:24, counselors -116:7
11:5,52:3 count -25:19, 31:5
2
49:11 49:19 50:4 50:18 GOOD/1AN REPORTING I
LLC- • • •






PO Box 2823, Tulsa, Oklahoma 74101
43 of 51 sheets Page 2 to 2 of 10 06/28/2012 05:57:10 PM
http://ReachingForTheTippingPoint.net
Deposition of Jette McGregor - 6/8/12
County-1 :1, 160:3
couple- 7:5, 11:23, 18:2,
23:2, 33:2, 44:9, 60:2, 64:21,
91:10,112:23,113:20,
114:19, 126:19, 132:18
course- 56:21, 56:24,
66:9,66:12,66:16,66:19,
79:2,80:5, 80:6, 80:14, 91:3,
104:22, 117:3, 117:10,
119:9,119:11,121:11,
123:10, 123:14, 123:16,
123:17, 126:1' 150:7, 150:8
courses - 57:2, 76:19,
n:2, 77:20, 116:17, 116:21'
119:12
Court-1:1,128:11
court- 81 :22
cover- 23:5
covered - 45:24, 121 :20
cram - 65:19, 67:20,70:10,
71:6, 72:9, 73:3, 80:25, 81:3,
81:9, 106:10
crams - 65:2, 65:5, 65:17,
68:15,68:21, 69:6,69:25,
70:3, 70:12,70:18, 71:24,
80:17,80:22, 81:1,87:12,
131:11, 134:18, 135:8,
135:16
created- 55:14, 127:11
Criminon- 7:17, 8:9, 8:24,
9:2
criticisms - 35:8
criticize - 78:5
criticizing -77:18,91:17,
91:18
Cross- 3:2
Cs'd-77:23
Csr- 160:22
curious- 61:9, 98:8,
136:14
current- 52:22
cut-15:15
D
deficiencies -67:20,
67:23, 70:4, 70:17, 73:7,
102:17
deficiency - 66:6,68:14,
71:1,71:5
deficient - 71:16
Oekalb-1:1
Delcampo- 2:3
Delgado -1:8, 2:14
Delgado's-10:2
deliver- 49:17, 57:20,
101:20,117:21,118:25
delivered - 76:15, 1 01 :8,
101:12
delivering- 52:13, 116:8
delivery- 55:12,56:11,
56:14,94:8, 102:5, 102:10,
102:15, 103:6, 103:7, 107:9
deposition -4:10, 4:22,
5:6, 5:14, 17:6, 17:18, 17:24,
18:11, 18:16, 18:19, 19:4,
25:18, 28:2, 28:23, 29:3,
29:6, 30:8,30:23,31:11,
31:14, 32:14, 37:21' 39:16,
39:18,39:21,41:13,41:20,
45:11,45:19,45:22,46:1,
58:16, 131:14, 135:20,
136:13,157:2, 160:12
Deposition -1:15, 159:1
deputy -107:17, 107:21
described - 76:9, 119:23
desk- 85:22, 90:9
Desmond-1:3, 1:4,1:5
detail-15:16, 74:15
determine - 93:12, 100:3,
143:21
determines -143:19
detoxification - 70:23,
72:9
developed - 34:25
Davelopment-1:8, 2:14
deviate- 76:22, 77:1
deviating - 148:13
deviation - 93:4, 93:11
diagnosis- 98:1, 110:2
D/dla-152:20 dictates- 77:16
Died- 107:8 died- 29:20
daily- 103:2 difference- 52:24, 124:8
Dane- 53:12 different- 51:2, 66:23,
Danish-134:16 79:23,84:21,86:15,95:22,
data-91:12, 92:1,92:11, 109:19,110:6,125:16,
92:14, 94:24, 94:25, 97:20, 130:2, 136:4, 140:10, 149:8,
98:6, 156:13 154:22
database - 124:24, 142:1, difficult- 128:6, 128:7
142:3, 142:11 difficulty- 148:5
date- 31:12 Direct- 3:2,4:7
day-to-day -139:7,140:3, direct-141:11
151:20 directed -24:1,109:2
days-16:3, 24:18,28:15, director-6:13,9:20,12:1,
32:1, 41:21' 44:23, 125:23 25:11, 25:12, 25:14, 60:17,
Dca-152:10, 152:12, 61:3,62:19, 62:21, 107:16,
154:1 107:17, 107:22, 114:3,
deal-73:14,143:15 114:25,119:19,130:22,
dealings- 42:18 141:3, 144:13, 146:8,
deals- 73:9 146:18, 147:23, 149:4,
dealt-73:11,134:5,153:8 150:11,150:14,150:24,
death- 29:23, 113:6, 151:3, 151:10, 151:12,
113:15,134:22, 134:23, 151:24, 152:1,153:1,
135:3 153:24, 154:5, 155:21,
debrief- 64:16 155:24
debriefing- 61:22, 61:25 Director- 20:21 , 152:16
December- 6:10 director's- 60:9, 60:21
decide- 60:13, 109:25 directors· 150:16
decided -108:16 disagreements -132:12,
decision- 77:15,78:1 132:15
decree -101:11, 101:21 disassociate- 37:1
deed- 137:3 disciplinary- 77:4
Defendant- 2:6, 2:10, 2:14 discipline- 77:8
20:18, 23:2, 30:20, 31:10,
35:12,40:18,40:21, 128:17,
135:2
discussed - 17:20, 20:24,
21:2, 22:5, 24:23, 26:13,
34:3, 35:17, 35:18, 37:5,
39:9, 39:14, 41:14, 95:17,
132:8
discusses- 96:15
discussing- 40:1,41:12
discussion -10:9, 22:22,
33:20, 33:22, 41:24,72:18,
95:20,115:9, 132:19
disrespectful - 81 :8
disseminated- 61:6
distract - 15:25
division -106:3, 108:6
divisions - 119:20
doctor's - 79:11 _
document- 64:20, 141;24,
141:25, 152:8, 155:14
documentation -134:22
documenting - 88:23
documents- 16:16, 62:6,
66:25, 82:13, 100:19,
100:20, 114:6
done - 1 0:23, 39:16,
47:23, 48:1, 51:2, 52:11,
52:17,57:16, 76:25.77:17,
78:5, 78:10,79:8, 79:13,
79:17, 79:20, 79:22, 80:14,
61:14,61:19,86:7,92:4,
94:24,95:11,117:3,116:17,
118:18, 119:9, 119:10,
121:17, 123:14, 124:4,
125:12, 126:22, 127:8,
127:1 0, 128:24, 131:11'
135:9, 136:19, 136:22,
136:23,137:6,141:11,
146:24, 149:21, 149:22,
149:23, 150:6, 155:12
door- 1 07:20
down - 5:2, 5:22, 5:25,
23:6,24:1, 24:6, 29:22,
59:12, 62:10, 73:16, 73:20,
82:6,89:20, 104:22, 121:9,
133:13, 133:16, 134:12,
134:24, 142:18, 143:20,
143:23
Downey- 2:16
Downs- 133:12
downtone -107:3, 107:5
Drew- 2:8
drinking- 92:16, 93:17
Drug-14:9
drug- 34:20, 98:13,
109:11, 109:24, 111:23,
116:9
drugs- 93:18, 129:10,
129:12, 129:18
Osa- 20:17,20:20,45:22,
152:23, 153:2, 153:7, 153:17
dual- 98;1, 110:1
duly- 4:4, 160:10
Dunn- 82:5, 82:14, 82:25,
83:3, 83:25, 84:9, 84:23,
86:11,86:25,87:15,89:19,
89:20,90:16,91:4,113:9
during- 5:6, 100:8, 120:4,
127:13, 129:2, 129:8
duties -49:4
Eastlwest-139:18
Eastern-115:1
eastern - 139:23
Eckl- 2:8
Ed-15:10, 47:2,48:1,
48:2, 63:9, 63:23, 103:14,
129:20, 141:13, 141:17
Eds- 91:14
effective- 56:16, 56:21,
66:6, 66:14, 119:24, 145:22
eight- 35:1, 79:1
either-113:12,113:14,
114:1,119:15, 138:1
email- 64:16, 69:22,
69:24, 71:25, 96:22, 131:15,
131:19, 132:1, 135:17
emphasize- 35:9, 39:5
employed- 16:25, 23:7,
23:11,23:17,23:16,23:21,
48:18, 48:20, 82:12,83:6,
85:12
employee -10:19, 10:21
employees- 57:10,
110:16, 149:15, 149:18
employment- 6:7
employs -16:24, 17:2
encountered -127:4
encourage - 36:25
end -14:12,61:10,109:2,
120:6, 120:22, 120:24
ends - 142:.22, 142:23
enroll - 1 08:22
enrolled- 76:18
enrollment- 98:10
ensure- 73:19
ensured - 148:20
entail - 140:25
entitles - 16:6
entity-8:11, 15:19
equivalent -14:1, 14:25
essentially- 51:18
established- 155:17
establishment -153:15
Estate-1 :4
estimate - 39:12
et-118:5
Ethics- 92:11
ethics- 56:21, 66:15, 77:8,
91:12,91:21.91:25,92:14,
92:17, 93:9, 93:10, 93:11,
93:19,93:22,93:25, 94:6,
94:15, 94:24, 94:25, 122:23,
122:25, 123:9, 123:14,
123:15, 123:17, 123:22,
124:1, 124:6, 124:9,124:13,
126:6, 126:7
Europe- 6:9, 11:24, 12:8,
12:14, 14:18, 14:19,23:18,
48:2, 60:17, 137:18, 137:19,
137:24, 138:1, 138:6, 138:8,
138:18
European- 14:13
evai uations - 11 :12
event -160:18
events- 153:16, 153:17
exact- 49:23, 124:4
exactly- 5:8, 8:14, 8:16,
12:25, 13:8, 15:6, 27:20,
29:11, 34:13, 34:14, 36:20,
38:23,44:10, 44:13, 54:18,
89:2,97:1,114:14,117:8,
t----------t 119:6,136:19,137:23,
142:15
E
ExacUy-7:11, 51:10,
E/o-133:5, 134:9 97:13, 102:12, 103:17,
early-139:4 137:2, 137:4
easier - 130:7 Examination- 4:7
East-1:18, 139:12, example -77:3,92:12
3
Defendants-1:12 discovery- 4:14, 113:2

REPORTING,
139:22, 151:3, 155:21, except -101:4, 104:6,
LLC - 918. 149. soo?J-=
10
--------
PO Box 2823, Tulsa, Oklahoma 74101
06/28/2012 05:57:10 PM Page 3 to 3 of 10 44 of 51 sheets
http://ReachingForTheTippingPoint.net
45 of 51 sheets
Deposition of Jette McGregor - 6/8/12
excessive -104:24
exchange -107:9, 107:18
excuse- 9:23,21:16,
125:17
Excuse- 138:23
executive- 25:11, 25:12,
25:14,60:8,60:21 , 61:3,
107:21,114:25, 144:13,
150:11,150:14,150:16,
151:3,155:21
exempt- 78:16
Exhibit- 58:11, 58:15,
64:17
exhibit- 58:18, 150:22
Exhibits · 3:7
exists - 142:3, 143:8
expand - 90:25
expectation -144:24,
145:16, 149:18, 153:6,
153:15
expected - 145:9
experience- 87:6
expertise- 57:11
Expires-160:22
expires - 158:9
Explain· 8:16, 15:7,24:15,
109:14
explain- 33:6, 34:10,36:7,
36:19, 53:22, 133:9
explained- 30:22, 36:14,
39:15, 39:17. 61 :18, 91:25
explaining - 35:3, 35:5
expound- 102:20
extreme- 77:4, 98:12
71:15
file - 85:24, 92:7, 94:1,
126:16
files - 75:7, 75:22, 76:4,
84:19,84:20,84:21,95:15
filings - 16:1 o
fill- 73:4
filled - 102:24
finally - 130:9
finances- 57:3
fine- 35:14, 64:9, 114:1
finish - 78:21
finished - 53:6, 128:2
finishing- 112:25
flrst - 12:12, 17:25, 18:2,
27:21' 27:25, 28:1' 28:2.
41:1,74:17, 95:9, 98:15,
122:9, 122:1 0, 127:3, 152:22
First- 42:20, 113:2
frt- 113:22
five- 22:1,25:19, 104:13,
104:20, 105:5, 105:1 1
five-hour -104:13
fix- 68:13, 71:16, 74:7,
148:14
flag -100:25
flunk-121 :12,121:21
folder- 61 :7,91:13,95:1,
126:7
folders· 74:18, 76:14,
81:17,82:23,94:8, 126:1,
126:9, 126:10, 126:11,
126:12, 129:2, 129:6, 142:9
folks- 104:19
follow- 19:2, 47:15, 64:16,
F 73:15, 74:8, 74:9, 95:9,
1--::--=:----:7-':""""':'":"-=-::-:---1 131:19, 135:12, 136:9
facilities· 46:8, 137:21 follow-up - 47:15,64:16,
facility- 24:2, 24:7,29:22, 74:8, 131:19, 135:12
59:7,59:11,61:20,64:25, following- 68:3, 131:15
74:16,75:10, 82:18, 97:5, follows- 4:6
111:17,113:6, 113:14, foot- 59:14
128:21, 147:10, 148:12, foreign -134:13
149:1, 149:5 forgot- 10:2
fact -78:5,96:15, 145:20 form ·15:20, 36:9, 51 :3,
factor- 126:25 53:25, 67:2, 88:19, 89:5,
114:6
Georgia- 1:8, 2:5, 2:6, 2:9,
2:13,2:17,4:11,5:23,6:1,
9:21, 9:24, 11:15, 11:22,
12:2, 12:6, 23:7, 24:2, 29:20,
46: 11,47:1, 50:18, 59:7,
59:11,61:20,63:1,63:4,
63:24, 64:25, 65:4, 68:7,
77:19, 81:10,95:5, 95:11,
98:23,99:3,99:12,101:11,
101:19, 102:7, 105:2, 105:3,
105:4.116:9. 127:9
gibberish - 62:3
given· 69:2, 70:3, 70:18,
72:8,72:24, 87:13
glad -144:8
God-143:12
Goodman-1:19, 160:5,
160:21
grab - 126:16
graduate- 78:20, 78:24,
79:4, 79:8, 79:17. 79:24,
80:12
graduates- 79:14
grafts -120:1
grand -113:22
graph- 120:7, 120:11,
120:14, 120:19
Gratuitously- 75:16
gratuitously- 24:21 , 27:7
ground - 147:3
Group-1:11
guess· 7:17, 36:1, 44:16,
56:9,62:8, 70:21, 70:22,
71:14,79:23,88:3, 88:15,
132:19, 133:24,150:4,
152:13, 152:14, 153:12,
154:2. 154:3
guessing - 70:24, 88:16
guy -74:9
guys - 33:8, 130:5
Gwenda-153:20, 153:23,
154:5
H
Falr-74:13, 89:15, 100:4, 89:13, 89:14,97:7, 124:4 half- 52:17
145:7 formal -121:19 Half- 34:5
fair - 50:5, 67:15, 68:3, formally- 121:22 hand - 160:19
71:6, 71:7, 74:11 , 86:16, forth -109:1, 160:15 handle- 36:4, 134:9
88:24,93:15, 93:16, 119:13, forwarded - 124:18, handling - 121:25, 131:3,
145:14 124:22, 142:6, 156:5 134:2
fall- 52:10 four - 14:17, 22:1, 25:24, handlings - 133:6
fallen- 143:24 38:20, 44:16, 69:8, 69:9, Happiness- 8:25
Helena- 21:6,21:7,21:21,
21 :25,22:6,22:11,22:12,
25:24, 29:6, 30:3, 30:4,
30:12, 30:13, 30:16, 31:5,
32:1.42:11.42:15,42:18,
44:5, 44:14, 45:7
Helena's- 22:14
help ·12:13. 12:15, 12:18,
12:23, 14:19, 16:16, 21: 13,
24:14, 24:15, 34:20, 47:2,
115:23,141:13, 141:14,
147:21, 147:24, 148:2
helped - 10:25, 11 :1,
24:19, 34:18
helping - 11:9, 12:5, 21:22
hereby- 160:7
hereto - 160:17
heroin - 34:17
herself- 21:22, 115:19
hierarchy- 6:23
highest- 117:22
himself- 21:20
Hipaa- 75:2, 95:5
hired- 6:19
history- 35:4, 35:13,
97:21' 98:2, 98:5
Hold-22:24
Holden- 1:17, 160:8
holding- 108:6
holds -107:9
Home- 14:10
honest- 22:10
honestly- 21:14
hope - 5:16, 58:19
hotel - 149:12
hotels- 41:11
hour- 34:5, 104:13
hours- 104:20, 105:5,
105:11 ' 127:6, 127:7
housed - 99:8, 99:11 ,
99:24
housing- 92:17, 99:9.
99:13, 99:18, 99:19, 100:4,
100:9, 100:11,100:21,
125:18, 125:23, 128:4,
129:21, 130:10
Hubbard - 34:18, 34:19,
35:1' 36:22, 57:19, 57:21
Hubbard's- 34:23
husband - 9:17, 10:14,
14:22
Husband's - 57:22
tamillar -15:3, 20:8, 69:10,69:16,69:25,71:8, happy-100:14, 128:4,
32:11,35:2,48:3,87:21, 71:24 130:1 identification- 58:12
107:15, 138:21, 139:6 Frlday-1:17, 160:7 hard - 38:17 Identified- 21:22,26:4,
far- 11 :16, 11:23, 15:9, friends- 60:4 Harris- 2:3, 3:4, 4:8, 4:9, 26:16, 63:21, 67:24, 68:23,
21:9,26:18,28:25,31:7, front-150:23 4:17, 10:4,10:13,19:7,22:9, 70:17,113:8, 117:9, 118:10
41:12, 54:6,61:8,72:9, frustrated- 5:5 22:13, 22:16, 22:18,23:1, ldentlfy- 69:9
83:18,87:10,11 3:16, full- 34:25,78:18 26:3,58:3,58:13,72:13, identify -21:13, 21:20,
117:22, 124:25, 128:23, fully -160:14 72:22, 154:25, 155:8, 156:22 69;8, 72:8,72:23, 113:4,
149:10, 153:4 1----------1 Hart- 25:16,63:13 116:20, 150:13
Farnham- 2:8 G hat- 52:10, 53:15, 53:21, Ill- 9:11, 9:12
fee -112:17 1----_...;;,_ ___ -1 54:4, 54:13, 54:19 Illegal - 92:4
feedback -132:7 game- 99:2, 99:4,99:5 hats - 52:6, 52:7, 52:10, Impacted -106:23
fees -148:21 Gary- 25:13 53:4, 54:15 important- 88:23, 89:10
fellow- 26:16 Gene-116:5, 116:10, hatt&d- 52:1, 52:2, 52:12, imposed · 93:12
felt - 34:18,81:16, 95:23, 116:24, 117:5, 117:6, 119:6 53:4,53:7,54:22,55:2, improved -76:3
106:17,107:1 general-78:9, 89:16, 55:18,55:23,56:15,56:18, Inc - 1:8, 1:10, 1:11,2:6,
few- 23:5, 32:23, 32:24, 93:7, 99:23, 106:4 57:10 2:14
44:4, 68:21, 69:6, 110:22, generally- 71 :5, 93:8, hatting- 54:24, 55:1, Incident- 47:18
137:5, 141:10, 150:23 102:19, 111:16, 111:23 55:10, 55:14, 56:19, 57:4 included- 8:22
fide- 128:6 generate - 144:11 Hco- 66:4 Income- 15:14, 108:19,
field -109:16, 110:3, generated- 59:6,61:22, head- 5:10, 133:20 112:16
110:8, 110:15, 110:19, 64:24, 87:8, 87:24, 93:10 hear- 98:22, 98:23, 98:25 lncorporat&d- 25:3, 25:5
110:25, 111:10, 112:5, generic- 55:5, 55:9, Heard- 113:17 Independent- 16:14,
115:10 56:15,56:18 heard-113:17 16:21,110:3
Field- 109:18 generically - 24:4 heck's- 144:18 Indicate -101:7, 118:13



REPORTING, LLC- 918.


13
:
10
PO Box 2823, Tulsa, Ok7ahoma 74101
4
Page 4 to 4 of 1 o 06/28/2012 05:57:10 PM
http://ReachingForTheTippingPo P int.net
Deposition of Jette McGregor - 6/8/12
16:4, 33:23, 37:11,37:23,
38:12, 39:6, 49:2, 55:14,
55:19, 55:22, 78:15,78:17,
78:24, 79:4, 89:9, 108:16,
120:16, 126:1 ' 126:10,
126:14, 138:7, 138:14,
138:22, 139:7, 142:6,
142:15, 142:24, 145:13,
146:17, 147:3, 147:22,
148:21' 149:7, 149:15,
151:21
Individually - 1 :3
Information - 91 :21,
103:4, 132:23
inpatient- 130:7
Inside- 104:10
inspect- 24:2, 24:7,
29:22,46:7, 74:16
Inspected- 48:12, 59:11,
147:11
inspecting - 49:8
Inspection- 24:10, 24:20,
27:11' 46:10,47:4,47:10,
47:14,47:17,47:19,48:5,
48:16, 50:1' 50:5, 50:17,
50:24,50:25, 51:12, 51:17,
51:18, 51:22, 51:25, 57:9,
57:12, 57:18, 57:25, 59:6,
61:20,64:25,67:19,71:21,
72:12, 72:25, 73:16,81:7,
82:6,83:12, 83:19,84:2,
84:3, 84:13, 85:8, 87:2, 87:3,
87:9, 87:11' 88:9. 89:20,
90:1,91:5,99:17, 100:9,
127:13, 128:2, 134:24,
135:4, 135:19, 136:10,
141:20, 148:6, 149:10
Inspections- 47:24
Inspections- 27:6, 48:8,
48:21, 49:1' 49:21' 49:24,
50:4, 50:15, 51:20, 81 :14,
86:13,87:7, 87:22, 127:17,
140:5, 141:10, 141:11,
147:5, 147:7
Inspector- 81 :12, 148:10,
149:5
inspectors -48:15,81:2,
148:10, 148:25
Instance - 136:25
Institution - 6:8, 20:3,
20:8, 20:10, 20:11
Institutions - 8:7
Instruct- 18:17, 22:7
instructed - 18:22
instruction - 19:2, 68:25
instructs - 15:23
insurance -11:2, 11:9,
11:13
Insurance - 11:11
lnt- 48:23, 49:5, 49:22,
50:3, 50:13, 51:13,51:19,
52:4, 136:3, 142:1, 152:10
intake- 38:22, 52:23,
52:24, 53:3, 54:19, 98:6,
140:10
Interacting -140:3
interaction - 151:25
interactions- 138:21,
139:7
interested- 97:23, 160:18
International - 1:11, 2:6,
2:10,6:4, 6:12,6:13,6:15,
6:18, 6:21' 6:25, 7:4, 7:15,
9:1, 9:2, 13:20, 14:15, 14:16,
14:21' 15:4, 15:8, 15:11'
15:18, 16:12, 16:20, 16:22,
17:11, 19:14,21:10,21:23,
23:12, 24:8, 24:9,24:18,
37:12, 37:24, 38:11' 38:19,
39:7,46:10,46:19,48:2,
51:1, 55:12,55:19,56:4,
56:25, 63:10, 63:15, 65:9,
65:12,67:1,67:8,67:11,
67:13, 73:8,73:24,75:13,
81:18,88:1,89:8, 90:22,
114:9, 114:17, 124:19,
124:22, 124:23, 130:23,
136:16, 136:20, 137:14,
137:15, 137:17, 138:1,
138:13, 138:20, 136:22,
139:2, 139:8, 139:16,
140:19, 140:20, 141:4,
141:23, 142:4, 142:7,
142:14, 142:16,143:1,
143:6, 143:17, 143:19,
144:14, 146:4, 146:18,
147:2, 148:20, 149:6,
149:11,149:22,150:1 ,
150:25, 151:13, 151:17,
152:2, 153:2, 153:9, 154:24,
155:10, 155:12, 155:16,
155:25, 156:6, 156:18
interpret- 62:7, 69:4,
70:2, 107:13
Interrupted - 36:13
Interview -133:17, 134:2
Interviewing- 90:11
Interviews -133:1, 133:6
Intimately - 35:2
introduced - 21 :23
Investigate -101:2
Investigation - 5:21,
100:2, 113:5
Involved -12:12, 13:11,
35:21, 36:21, 36:23,44:12,
48:14, 50: 14, 51:13, 148:23,
148:24
involvement -12:1,27:11,
74:6
Irrelevant - 66:19
Isaac- 114:6
Issue- 26:14, 99:18,
128:15, 136:10,146:3,
147:22, 147:23
Issued - 55:12, 56:4, 56:24
issues- 86:20, 106:17,
146:5, 153:3
Issuing- 71 :21
Itself -117:10
keeping -104:19,121:5
keeps - 120:15
kelkoo.dk -134:15
Kent- 9:17, 9:19, 9:23,
10:14
kept - 104:2, 105:1 0
kind- 5:3, 10:24, 13:25,
44:8,47:3,51:18,64:23,
66:19, 75:2,81:8,92:1'
93:19,97:4, 113:5, 115:17,
117:2, 120:14, 127:4,
131:19,141:21,142:10,
144:2, 153:13
kinds - 118:22, 153:6,
153:16
knowing- 4 7:22, 124:3
knowledge- 38:21,
124:20, 126:8
knows - 35:24
Kobrin- 26:2, 26:3, 26:15,
27:15, 28:20, 32:6, 35:2,
35:17, 38:9,40:7,41:6,44:2
Kobrin's- 26:5
Krs- 94:15, 94:16, 94:18,
124:8
L
labeled - 58:21
lady- 5:1, 17:10,18:21,
19:10, 21:5, 85:8, 114:5,
115:2, 153:20
language -120:9, 134:13
laptop- 134:14
Larry- 123:2, 134:1
last- 23:11, 46:12, 61:13,
61:17, 69:14, 85:13, 105:24,
113:25, 121:13, 126:18,
127:14, 131:20, 153:23,
154:15
late- 6:10
law- 1:17, 84:11
laws - 84:6, 95:4, 95:6,
95:9
lawyer-17:25, 45:7
lawyers -17:17, 23:3,
45:6,46:1
league- 53:13, 53:14,
53:18
learn -124:1
least- 5:21, 55:15, 55:17,
65:8, 147:11' 147:15
licenses -151:18
licensing - 1 0:25, 12:6
life - 70:23, 71:11, 72:9
llfe-133:12
likely- 43:11 , 72:12, 72:24
line- 33:1 o, 62:15, 159:3
Lines- 3:13
lines -11:2,11:10,11:11,
120:12
Llsa-1:10
list- 65:25,68:10, 131:3,
143:3
listed - 9:20, 99:3
listened - 35:12
lived -11:15, 11:21
Llc-1:9
Lip- 2:3, 2:8, 2:12, 2:16
loan - 54:8, 54:9
loans - 53:24
local-106:13
locate -133:17, 133:22
located - 46:20, 85:21
location- 100:14, 100:15,
101:8
locations- 60:14
logistics - 44:5
Longs-14:9
look- 39:11, 66:5, 68:2,
75:6, 84:4, 85:23, 99:7,
99:18, 100:6, 101:4, 128:15,
132:1, 141:6, 141:7, 141:9,
144:2, 144:5, 144:7, 148:7,
148:12, 155:2
Look- 69:13
looked- 5:22, 5:25, 16:11,
16:15, 32:13, 74:20, 74:22,
76:4, 97:19, 97:20, 102:10,
102:14,107:3,113:13,
113:18,123:21,126:1,
127:3, 129:6, 129:17
looking- 70:16,75:11,
75:22, 82:13, 82:16, 82:23,
84:17, 84:19, 84:20, 84:21'
85:17, 90:7, 94:3, 94:7,
100:19, 102:5, 118:21,
126:6, 126:10
looks- 63:14, 69:5, 69:21,
69:24, 116:9
Los- 6:11, 46:21, 85:4
loud- 5:9
lv -117:6, 117:14, 117:19,
118:4 leave -10:18, 14:5,90:4,
1-----------1 112:3,128:8,128:21
leaving - 14:7
love -12:17, 131:22
loved - 53:23
Lowry·2:3
J
January- 27:22, 27:23,
28:3, 2 8 : ~ 9, 31:1' 31:9,
31:12, 32:15,41:10
Jeff- 10:1, 22:15, 58:1
Jeffrey- 2:3
Jette-1:15, 2:10, 3:3,3:9,
4:3,4:10, 158:3, 159:1,
160:9
job -10:16,24:12,48:17,
49:4, 105:10, 106:23,
107:18, 108:6, 114:13,
136:6, 136:7, 136:8, 136:9,
140:19, 140:22, 140:25,
146:1' 146:3, 150:24, 151:9,
152:11, 154:5
jobs- 14:9,52:1
July- 23:19
June· 1:17, 59:1, 69:25,
70:14, 160:7, 160:19
left- 64:1, 136:2, 137:15,
137:17, 137:18, 137:19, ma'am -71:4, 82:15,
138:7, 140:19 156:22
M
legal- 20:13, 26:24, 83:18, Main • 121:24
84:2,84:3,84:5, 84:10, main -122:5
84:12, 86:3, 86:7,86:10, major -126:25
87:2,87:3,87:7, 87:12, Management -1:10
87:23, 89:25, 95:3, 96:17, management- 52:4
96:24,96:25,97:11,101:13, Manzanares -46:15
102:1, 114:15,150:24, Marietta- 2:17
154:10, 154:23 marked- 58:11, 58:15
Legal- 87:5 married -11:17, 11:18
legalities- 84:5 Marscbalk- 2:7, 10:1,
length -41:8 10:5, 22:14,22:17,26:2,
Les- 53:12 31:18, 31:20, 31:22, 31:25,
letters- 66:5 72:15, 89:13, 97:7
letting -104: 16 Mary -1:3, 1:4,63:23,
level- 9:9,9:11,52:4, 64:11,65:8,65:16,68:10,
52:5, 52:8, 117:16, 117:20, 68:17,69:1, 85:17,90:5,
117:22 90:6, 91:20, 95:7, 100:10,
1----------1 llabllity-107:17, 121:13, 103:21,125:22,128:3,
121:16, 121:19 126:17, 130:9, 132:4,
K
24:19,24:25, 25:5,25:15, keep -11:20, 105:5, 120:4,
27
:
2 29
:
5 33
:
15 33
:
24
GOODHAN REPORTING
license- 97:4, 147:14, 132:20, 133:5, 134:8
147:15, 147:17, 147:19, master- 55:16
LLC _ 918. 7 49. 500fJaterials- 57:19. 57:21
PO Box 2823, Tulsa, Oklahoma 74101
5
06/28/2012 05:57:10 PM Page 5 to 5 of 10 46 of 51 sheets
http://ReachingFFor o TheTippingPoint.net
Deposition of Jette McGregor - 6/8/12
61:5, 61 :8, 66:1' 66:8, 66:10
matter- 48:7
Mcgregor - 1:15, 2:10,
3:3, 3:9, 4:3, 4:10, 4:18,
9:17, 9:19,9:23, 16:4, 58:14,
92:20, 112:23, 158:3, 159:1,
160:10
Md -1:10
mean -12:4, 13:8, 15:15,
24:16, 35:18, 37:21, 42:11,
62:1, 62:25, 67:5,68:10,
68:16,73:2,79:23, 81:7,
mostly- 55:11, 111:4,
122:3
mouth- 95:24
moved-7:23
moving -115:24, 121:11
Moxon -22:17, 26:6,
27:15, 42:2
must-130:4
Mute - 31:20, 31 :22
N
85:16,85:23,87:15,88:3, name-13:14, 21 :12,
88:14, 88:17, 91:15, 92:20, 25:25, 34:16, 46:12, 105:22,
98:7, 98:8, 103:18, 106:13, 105:24, 110:23, 110:24,
107:12,108:11,110:13, 111:6,113:25,1 14:19,
111 :14,118:16,119:8. 154:15
119:18,120:2, 121:15, named -114:6, 115:2,
123:10,125:10,127:1, 115:4,153:20, 154:4
127:2, 128:6,129:5, 129:9, names -12:25,113:17,
129:24, 130:13,131:21, 113:20
133:8, 133:14, 134:13, Narconon -1:8, 1:11, 2:6,
135:24, 136:17, 153:8, 2:10, 5:19, 5:2.2, 5:25, 6:2,
154:7, 156:10 6:4,6:8,6:9,6:11,6:13,
meaning -143:23 6:14,6:18,6:21,6:23,6:24.
means- 52:3, 62:22, 63:1, 7:4, 7:1 5, 8:9, 8:24, 9:1,
107:14, 113:3, 118:17, 9:20, 10:17, 10:18, 10:22,
120:3, 121:10, 121:16, 10:23, 11:2, 12:1, 12:5,
121:21, 129:6, 129:10, 12:12, 13:13, 13:22, 14:14,
133:9, 154:1 14:15, 14:16, 14:19, 14:21'
meant- 46:20,63:7,91:20, 15:4, 15:8, 15:11, 15:17,
98:16, 104:12 16:6, 16:11, 16:19, 16:25,
medical-79:10 17:10, 17:14,21:10,21:22,
23:6, 23:7, 23:12, 23:17,
meet-17:5, 17.17, 19.9, 23:18, 23:21,23:23, 24:8,
19:13, 20:14,20:17, 44:6, 24:9, 24:12,24:17, 24:19,
44:7, 90:6 24:24, 24:25, 25:2, 25:5,
meeting- 25:21,43:25, 25:8,25:15,27:2, 27:3,29:5,
65:23, 85:17 29:20,33:6,33:14, 33:17,
meetings -18:16, 141:19 33:23,33:24,34:8, 34:15,
member-13:16 34:23,35:4,35:13, 35:16,
memo- 70:13 35:21, 36:8, 36:21, 37:1,
mental- 98:13 37:6,37:24,38:11,38:18,
mentioned- 8:23, 128:3 38:22, 38:23, 43:5, 46:7,
met- 38:5,49:18, 60:2 46:9, 46:10, 46:19,47:1,
Mexico- 60:15 48:1,48:2, 49:15, 50:18,
mlddle-138:24 52:1, 52:3,53:23, 56:16,
mlght-13:3, 21:13,37:22, 56:21,57:7,60:2,60:17,
38:10,42:25, 92:12, 102:7, 62:21,63:1,63:4, 63:10,
106:23, 113:18, 115:3, 63:23,65:4,65:9,65:11,
149:2, 153:6 66:1,66:7,66:8, 66:10,
Mike- 2:18 66:14,66:19,66:25, 67:8,
mlne-152:15 67:10, 67:12,68:6,71:22,
Mine -146:7 73:8, 73:24,75:6, 75:12,
mini- 53:21,54:4, 54:13, 76:18,77:19,78:15,78:18,
54:15, 54:19 78:25,79:1,79:5, 79:8,
minute- 24:3, 100:25 79:14,79:24, 80:4, 81:10,
minutes - 104:23, 155:1 81:18,83:3,83:14, 85:2,
Miss- 4:18, 16:4, 19:10, 86:14,87:6,88:1, 88:25,
21:2, 25:21' 26:13, 26:15, 89:6, 89:8, 90:21' 90:23,
27:15, 28:20, 32:4, 32:6, 90:25,95:7,97:25, 98:23,
35:2, 35:17, 38:5, 38:9,40:5, 99:3, 99:12, 101:19, 102:7,
40:7,41:2,41:6,43:25,44:1, 103:20, 105:2, 105:3, 105:4,
44:7,46:3,58:14,59:21, 108:19,109:2,110:1,110:5,
70:3, 71:23, 82:14, 82:25, 110:9, 110:16, 110:17,
83:3,83:25,84:9,84:23, 111:1,111:8,111:11,
86:11,86:25,87:15,89:19, 111:25,112:1, 112:8,
89:20,90:16, 91:4, 92:8, 112:12, 114:9, 114:25,
92:20,93:24,103:7, 112:23 117:3, 119:9, 119:10,
mistyped -115:3 119:15, 119:24, 123:15,
Ml -131:21 123:17, 124:19, 124:22,
moment-150:19 124:23, 130:23,136:3,
money-121:18 136:20, 137:21,138:7,
monitor-121:7, 130:17 138:14, 138:22,139:2,
monitoring -128:13, 139:7, 139:12, 139:17,
140:12 139:19. 140:1, 140:2, 140:6,
months -14:18,38:20 140:9, 141:3, 141:18,
morning- 4:18, 4:19 141:23, 142:1, 145:22,
most-104:17, 149:16 146:11,149:11,149:22,

---GOODf1AN REPORTING
151:15, 151:17, 152:20,
153:1, 153:9, 153:11,
153:15, 155:16, 156:6
Narconon's- 29:9, 95:1,
128:24, 130:14
Narconon-related- 6:8
Narconons-16:13,
104:15, 127:5
nature- 35:10, 147:12
naval -13:25, 14:25
Ne- 2:4, 2:12, 2:16
need - 5:2, 28:8, 55:2,
55:23, 58:4, 68:2, 79:11'
93:12, 103:20, 109:24,
119:11, 121:25,141:13,
153:16
needed- 73:21,76:2,
81:16, 106:18, 115:17,
115:21,131:18,134:5,
134:7,141:15, 147:21, 148:8
needs- 66:1, 121:19
nervous- 5:13
Never- 59:14
never-12:17, 13:25,
39:15, 59:14,76:25, 96:7,
127:4, 128:5, 131:17, 153:9
new- 70:23, 71:11, 72:9,
91 :2,97:15, 129:21, 131:23,
134:14, 140:7
Next-123:12
next- 31:9,62:25, 64:17,
97:16, 105:14, 122:22, 132:2
night- 31:13, 128:8,
129:3, 129:8, 130:2
Nobody-13:2
noise-77:6
none- 72:14
None-152:4, 152:5, 152:6
normally- 62:13,88:4,
88:7
Normally- 88:5, 103:20
Notary- 158:8
note- 91:12, 98:7, 117:13,
118:3, 119:14, 123:2, 123:3,
123:18, 123:23, 128:19,
128:21
noted -76:13,95:14, 96:3,
102:17, 102:19, 102:22,
104:5, 123:5, 123:22
notes- 91:15, 155:2
nothing- 4:5, 39:17,
147:13, 160:11
noticed- 64:4, 76:13
noting - 98:9
Nt-152:20
Number-3:8
number- 56:15, 58:22,
65:2,.143:3, 143:5, 155:10
numbers -15:13,109:1,
109:10, 120:12
nurse-103:11, 103:16,
103:21
127:8, 129:7
Obviously- 22:11
occur- 30:20, 48:8
occurred- 38:4, 41:21,
101:11
occurs - 60:9
odd - 135:22, 135:23
offensive - 62:2
offer-18:7, 141:14,
147:24, 148:2, 149:1, 149:2
offered -18:10
office -14:19, 52:4,
140:10, 140:12, 140:16
Office- 19:24
officer- 93:10, 93:11,
123:14, 123:16, 123:17
offices- 1:17, 160:8
official - 79:8
often - 36:22, 49:21, 93:3
Oh-huh -136:5
Oklahoma-1:1, 1:19,
1:21,25:3, 160:2, 160:6,
160:9
once- 21:19, 60:9,60:18,
127:10
one- 28:4, 28:8, 28:13,
30:2, 30:3,31:9,31:11,
31:15,33:17, 35:23,41:9,
42:16,43:4,43:7, 44:19,
44:22, 47:1' 48:14, 50:13,
51:24, 53:20, 54:16, 56:20,
57:6,61:3,61:13,61:14,
61 :15, 61:17, 66:21 ' 66:23,
68:18, 68:23, 70:23, 71:11,
72:7, 77:16,88:22, 89:9,
90:5, 95:11' 97:19, 97:24,
108:12, 116:3, 123:25,
125:1' 131:23, 131:24,
133:18, 134:4, 135:16,
135:17' 135:22, 135:23,
138:17, 140:11, 146:13,
147:18, 151:6, 153:19
One- 22:4, 33:5, 68:17,
76:12
ones - 7:1 8, 52:16, 53:23,
55:8, 65:11, 68:25, 69:1,
111:4, 116:18,131:13,
131:14, 138:18, 139:25,
146:19, 155:20
ongoing- 51:12
op-155:15
open- 66:19,66:21. 91:2
operate • 38:20, 89:2,
150:1
operated -16: 12, 16:20
operates - 38:23, 68:18
operations -15:11, 52:2,
52:9, 63:15, 140:21, 148:24
opinion -126:25,127:11,
128:1, 130:6
opposed- 16:12
Order- 128:11
order - 4:14, 6:18, 40:21,
0 54:22,55:2,55: 18,55:23,
1----......;,-----4 65:20,66:6,67:22,68:1,
o'clock -142:21, 142:22, 68:11, 68:13, 75:3, 101:21,
142:23,144:12,156:18 150:1
0/ws-125:4 ordinary- 96:4
Oas- 20:6 org- 85:5, 106:10, 107:24,
Object-15:20, 51:3, 53:25, 108:3, 116:10,152:17,
67:2, 88:19, 89:13, 89:14, 152:18
97:7 Org- 13:16, 13:19, 13:21,
ObJection- 36:9 14:1, 14:5, 14:7, 14:13,
obtection -16:3, 18:22 14:23, 15:1, 59:23
ObJeCtions - 4:12 organization - 7:1, 7:16,
objectives -118:5 8:21, 8:25, 88:24, 106:14,
observation - 105:9 120:15
observed -104:1 1, 129:11 organizations- 7:5, 7:6,
obtain- 67:9 7:13, 89:11
LLC - 918. 7 49. 500tpanizina "
107
:
15
PO Box 2823, Tulsa, Oklahoma 74101
6
4 7 of 51 sheets Page 6 to 6 of 10 06/28/2012 05:57: 10 PM
http://ReachingForTheTippingPoint.net
Deposition of Jette McGregor - 6/8/12
orientation- 96:2, 96:13,
97:12, 104:1
originally- 8:1, 8:2, 32:14
originator- 62:14
Osa-19:18, 19:19, 19:20,
19:22, 19:24, 20:4, 20:8,
20:14,45:19, 152:23, 153:2,
153:7, 153:17
Ot- 9:11, 9:12
Otherwise- 5:4
otherwise - 160:18
ought- 35:9
outlined -11:7, 71:25,
130:21
outness - 62:3
outnesses- 81:15, 81:22,
102:23, 1 06:1
outpatient- 98:19, 98:24,
99:4, 99:22, 101:1, 127:3,
128:7, 130:8
outpoints - 123:18, 123:23
outside- 153:11
Overcoat- 53:8, 53:21,
54:5
Overcoming- 53:8, 53:21,
54:5
oversee -107:18
overseeing- 7:2, 52:3
oversees- 119:21
overts- 125:7
Overts-125:8, 125:11
own - 55:24, 56:7, 94:11,
109:20, 124:13, 150:9,
151:16
owned -15:17, 16:12,
16:20
p
Patrick's- 113:6, 134:22,
135:3
pay- 24:9, 121:9, 149:9,
149:12
paying - 138:23
payment -149:10
Peachtree- 2:4, 2:8, 2:12
Penn- 2:3
people- 12:21, 12:24,
13:4, 13:7, 14:20, 25:20,
53:22, 62:8, 63:21' 80:22,
86:13, 87:7, 88:23, 91:1,
98:11, 109:2, 109:8, 109:16,
110:15,111:16,113:4,
116:8, 116:16, 117:9,
117:17, 118:24, 133:13,
136:20, 146:12
Per-103:14
percent-108:19,112:15
perfect- 66:20
perfecting -15:24
perhaps - 72:8
person - 13:14. 20:24,
21:1,26:5, 26:8,29:19,56:6,
62:9, 62:11' 68:18, 77:3,
77:9, 77:10, 87:21, 88:8,
97:15, 103:15, 107:19,
109:12, 109:25,111:24,
112:16, 133:16, 133:18,
150:7, 153:23
personal-106:17, 106:22,
115:18, 115:21
personally - 73:22, 84:25
personnel - 6:19
-1.02:11
Phil- 25. 16, 63.13
Phoenlx-61:15
phone - 21:18, 31:20,
31:22,40:8,40:24,44:14,
Page- 3:8, 3:13,159:3 91:7,136:1,144:17,147:4,
page- 56:21, 91:13, 98:15, 148:4
105:14,115:6,122:22, phonetic-14:11
127:14, 152:22 physically- 79:12
pages -120:5, 121:3, pick- 76:4,81:6,81:13,
121:5, 160:15 136:14
paid- 23:23, 75:19, picked- 81:20, 136:18
108:21, 148:21 , 149:2, 149:6 picture- 136:11
pain -143:13 place -10:9, 22:22, 32:15,
painlessly- 5:17 44:11,59:15,60:24, 72:18,
Pallas-14:10 73:19,149:17, 153:16,
paper - 67:17,88:5,142:9 155:23
papers - 85:18, 65:19, Place- 1 :9
85:21 places- 60:15,89:3
paperwork - 87:8 Plaintiffs- 58:15
paragraph -101:7,116:10, Plalntiffs-1:6, 1:16, 2:2
121:13, 127:22 plan -145:13, 145:19,
paragraphs -126:19 145:21, 145:23, 146:3
parentheses- 62:24 plans- 142:4, 146:20
parents -121:18 plate -107:2
parishioners -117:21 played- 99:2
part- 7:20, 24:12, 49:4, plus -104:17
50:3, 50:24, 51:12, 54:4, Pm-157:3
57:8, 57:13,66:3, 71:3, point- 5:5, 6:3, 6:23,6:25,
92:13,94:4,94:8, 98:6, 9:19, 11:15, 11:20, 12:6,
98:10,99:17, 140:15, 145:5 25:17,28:21,30:16,42:7,
particular -13:2, 29:1, 48:25, 50:20, 71:15, 75:24,
29:13,30:22, 39:5,44:25, 75:25, 120:4, 121:4, 121:24,
54:12,91:21, 92:6,94:7, 152:25
106:7, 118:22, 155:14 pointers- 35:8
particularly- 57:3 points- 32:23, 39:5,
parties -160:17 64:21, 120:13, 121:9
partner- 22:14, 26:6 policy- 66:5, 98:11
Parts- 40:25 portion -123:22, 124:10,
passed - 47:1 126:14
past- 42:18, 73:11 portions- 40:12, 40:14
patient - 74:22, 74:25, position- 52:22, 55:3,
75:11, 77:17,103:3 60:16,63:2
patients- 11:13, 74:20, positions- 54:17, 54:23,
99:24, 127:9 56:15,56:18
possession- 67:1
possibility -148:7
possible - 49:20
possibly - 26:5
posted - 107:8
posting - 13:21
postponed - 31:15
potential -133:3, 133:11,
133:21' 134:5
practice - 45:13, 71:4,
155:23
Practice. 4:11, 4:13
practicing - 9:14
preceding- 160:15
prepped - 45:10
Present- 2:18
president- 25:8, 25:10
pretty· 60:14, 76:9,
153:20'
preventive- 133:10
previous -143:24
printed - 65:7, 67:12,
67:14
prison - 34:21, 34:22
privilege- 18:21
privileged -18:20, 26:19,
26:24
probation- 128:11
problem -10:4, 74:7,
96:13, 98:14
problems- 52:11,59:17,
70:19, 77:4, 81:11, 98:13,
99:19,127:11
punch- 5:5
purification - 122:13
purpose- 28:1, 39:21,
49:14, 49:15, 71:20
purposes- 4:11, 15:24,
17:24
put- 30:12, 31:14, 53:23,
58:14, 68:13, 91:12, 93:25,
95:23, 120:7, 120:12,
124:12, 143:13, 145:13,
150:5
puts- 120:18
putting - 95:15
Q
qual- 107:9, 108:1
Qual-108:3
qualification- 108:5,
108:7, 119:22
qualifications- 97:25,
118:21, 118:22
qualified - 98:3, 108:2
questions- 5:1,27:17,
33:2, 33:4, 36:5, 37:22,
38:10, 40:17,42:24, 43:10,
45:16, 99:15, 115:25
quick- 58:2, 155:2
quite - 32:25
Quite- 110:22
R
procedure - 48:20 raise - 1 00:24
process- 49:8, 66:4, 68:4, raises- 76:7
73:2,87:21, 92:19,109:15, Random- 49:23
110:1 random - 49:24, 50:14,
produced- 87:17 50:25, 51:20, 76:6, 76:8,
production- 114:3, 147:8
119:20, 130:22, 141:3, randomly -126:15
146:8, 146:12, 146:19, rank -13:23, 14:1, 14:25
147:24, 149:4, 151:13, rate- 65:16
151:24, 152:1,155:24 rather- 5:9, 124:13
pr09ram- 34:21, 34:25, raw -156:12
47:5,49:10, 49:13, 50:3, read- 4:16, 34:17, 53:17,
50:25,51:13,52:13,52:14, 77:11, 77:13, 102:20, 120:5,
56:7,57:16, 70:23,73:19, 121:3, 121:5, 132:10
74:21, 75:25, 76:18, 77:6, reading - 4:15, 40:12,
78:20,78:21,78:25,79:5, 40:14,40:23
79:6, 79:8, 79:13, 79:15, real- 5:5, 155:2
79:18,79:20, 79:22,79:24, realize -138:4, 155:11
79:25, 80:12, 90:20, 94:4, really- 7:25, 27:10, 29:8,
94:9, 97:5,97:25,98:1, 29:12,31:16, 57:18,70:21,
101:6, 101:8, 101:20, 102:6, 73:13,82:11, 85:12, 86:14,
102:15, 103:7, 104:12, 100:13, 104:15,113:21,
105:12,105:20,106:4, 116:1,124:11 , 144:9
107:20, 110:1, 110:5, reason -16:14, 46:12,
110:14, 116:9, 123:22 51:2, 71:19,95:15,96:17,
programs -12:12,13:12, 96:25,97:2,97:11,98:8,
53:24, 109:3 99:15, 100:24, 145:6
progress -121:8 Reason-159:3
project - 90:21 Reasor- 59:21, 70:3,
properly- 57:10 71:23, 92:9, 93:24, 103:8
propose- 131:4 receive- 38:10, 149:25
protected - 92:3 received - 149:15
8
rovlde- 32:17, 39:25, recess- 58:8,112:20,
4 :1 0, 40:20, 118:24, 149:20 155:5
provided- 55:19,65:4, recollection -72:4, 116:15
132:4, 134:21 ,135:8, record- 4:1,5:10, 10:2,
141:25, 155:20 10:8, 10:10, 10:11, 15:25,
providing -117:10, 118:9 22:21,22:23,22:25,43:20,
psych - 97:21, 98:2, 58:9, 72:13, 72:19, 72:20,
107:19 112:22, 155:6, 156:25
psychiatric- 98:5 record's - 20:7
Pt- 120:2 recorded - 43:22
Pts -133:1, 133:5, 133:17, records- 74:23,75:11
134:2 Recross- 3:2
public -16:10 recurring -152:2
Public -156:8 red -100:25
7

REPORTING,
LLC-




PO Box 2823, Tulsa , Oklahoma 74101
06/28/2012 05:57:10 PM Page 7 to 7 of 10 48 of 51 sheets
http://ReachingForTheTippingPoint.net
Deposition of Jette McGregor - 6/8/12
reduced - 160:13 145:11, 145:12, 145:18,
refer· 62:2, 66:4, 66:7, 145:21, 145:24, 146:2,
67:23, 80:17,92:14, 100:20, 151:21,155:11, 156:19
110:2, 110:5,112:16, 125:3, reported -130:20, 130:22,
133:1 143:5, 143:16
reference-65:3 reporter- 39:20, 81:22
references· 65:25 Reporter-1:20, 160:6
referencing -124:9 reporting· 89:12, 89:22,
referral • 109:20, 112:17 143:17
referred - 8:5, 68:9 reports - 32:24, 64:23,
referring - 19:10, 30:1, 92:5, 93:19, 93:22, 93:25,
62:20, 80:22 94:15, 102:24, 103:5, 124:7,
refers -141:25 124:9, 124:11, 126:7, 126:8,
refusing- 26:20, 26:21 134:21
0
141:5, 146:6,
reg· 52:25, 56:23
0
56:25, 146:16, 146:20o 146:23,
108:80 111:14 147:4, 155:15, 155:19
regard- 37:15, 53:16 represent -18:1, 18:8
0
regarding- 4:14 18:10, 18:13, 32:5, 110:14
regimen -103:9 representative- 16:6, 75:6
reglonal-108:25, 109:7 representatives -109:17,
Reglonal-109:4 110:4,110:80110:19, 111:1,
reglstrar-111 :19 111:10
0
112:6, 115:10
registrars -108:25, 109:7, representing -17:23,
140:13 32:7,75:12
registration- 140:9, represents -17:10
140:16 request - 81:17, 113:2
regs- 57:2, 108:10 require- 103:10
regularly· 50:3 required· 57:2, 105:11,
rehab- 34:25, 109:24 124:21. 128:10, 128:12,
reJoined -14:15
0
14:16 142:25
0
146:16
relapse -129:10 requirement- 89:12,
related · 6:8, 56:7, 57:3
0
144:160 147:10
0
151:20
0
70:40 103:60 160:16 153:14
relationship -15:7,33:6, requirements -101:13
33:13, 33:16o 33:23, 34:7o requires - 95:11
35:16o 36:80 37:5, 37:11, reserved- 4:12
37:23, 38:11 o 39:6, 43:5, resided - 9:24
49:120 151:14 respect- 73:12
relatively - 5:17 respond- 33:2
0
36:16,
release - 75:2 37:10
0
38:14, 38:16,38:17
0
relevance -123:4 40:13,42:23,43:1, 43:12,
remember -12:25, 13:10, 45:16
0
146:5
13:14
0
27:20o 28:25, 29:7o response· 39:2, 141:7,
29:8, 29:11' 29:12, 30:14, 144:3
31:7, 31:13
0
34:2, 43:7
0
responsibility- 49:1 o
44:13,44:19,54:6,61:9, 78:19
65:14, 68:16, 70:15,70:22, responsible -114:15
0
70:25, 71:80 75:4, 83:23, 146:14
83:24
0
84:1,95:24,96:19, rest-131:11
97:1, 97:10, 100:13, 100:16, result- 72:24
105:24,113:25,114:1, resulted -13:12
117:2, 118:18, 119:6, results - 93:5
125:21 , 132:21,138:16, retain -124:23
140:7, 146:10, 149:6, revert-129:2
149:11, 153:4 reverted -129:8, 129:9
reorganization -12:15 review- 68:11 , 93:11 ,
rephrase- 50:9 116:200 118:20, 119:14
report - 3:9
0
15:9, 15:12, reviewing- 98:4
30:24, 32:11, 32:12, 32:13, reviews- 76:8
32:20o 32:25o 33:3, 33:1o; Rick- 21 :7 o 21 :8
0
21:9
0
40:1' 40:7,40:130 40:14, 21:23, 22:3, 22:6,22:9,
40:18,40:21,40:230 41:2, 22:11,22:16,22:170 26:6,
41:25,42:4, 46:4, 59:10 59:5, 26:7,26:9, 26:10,26:160
59:12,61:23,61:25, 64:6, 28:11,28:130 41:150 41:20,
64:21 , 65:10, 70:18, 71:11, 42:2, 42:9, 42:100 42:170
76:90 76:11' 77:20, 77:22, 42:23, 44:2, 44:40 44:20,
81:15, 88:7, 89:18, 91:10, 45:7
92:25,93:5, 93:9,96:16, rings -144:18
98:16, 103:2,103:14, Robbins-1 :10, 1:11
112:25, 115:7,115:25, Rogers-114:20
123:8, 124:10, 125:16, role -10:21, 140:4
126:14, 126:19, 127:14, Ron- 34:17, 34:23, 35:1,
128:22, 130:21, 130:24, 36:22
132:5, 132:8, 132:10, room- 82:22, 91 :3
132:22, 132:25, 133:25, routine . 48:7
135:6, 135:13, 135:15, routines -122:17
135:16, 141:7, 142:15, rudiments - 83:19,84:2,
142:25, 144:2, 144:4, 84:3, 84:10, 84:13, 86:3,
144:10, 144:11, 144:13, 86:7,86:10, 87:5,87:7,









REPORTING,
96:24
ruds- 106:10
rule- 78:9
0
80:2, 95:2,
147:13, 153:13
rules- 77:5, 93:9, 95:1
rumors -113:17
run -15:18, 16:20,56:16,
66:23, 97:4, 102:8, 119:24,
145:22
91 :17, 101:16, 105:15,
123:12, 132:23
separate -15:19,16:21
0
16:23,24:24, 25:19,27:2,
27:6, 50:4,51:2,111:16,
122:15, 122:16, 126:9
Sequence- 68:24
sequence - 69:11 o 70:9,
76:15,76:19, 77:1, 77:9,
77:20, 78:2, 78:6, 78:10,
80:11
rundown- 122:14
Running- 66:14
running - 56:20, 66:8, service- 49:16, 49:17,
66:15, 147:14, 147:17,
1---------1 147:20
80:4, 118:5
S services- 118:9, 126:23,
1----....;.-----1 149:20
salary- 23:23 sessions- 45:13
sales- 52:12o 53:4, 57:3 set- 6:21, 8:3, 8:11 , 8:13,
Sales- 53:13, 53:14, 53:18 8: 14, 8:16, 9:2,39:18, 59:14,
sauna· 68:18,79:6, 79:11, 129:21, 139:10
0
139:11,
79:15,79:25,80:13, 101:60 140:8, 160:15
101:7, 101:12, 101:20, setting -130:7
102:6,102:8, 102:14,103:6, setup -98:18.127:4
104:1, 104:2, 104:10, several- 7:3
0
76:13, 76:14
104:12, 104:16, 104:18, shaking- 5:9
105:19, 106:5,106:8, 122:11 Shaw-2:11,4:16, 15:20,
saves- 59:17 16:2, 17:21, 17:23, 18:17,
saw- 85:16
0
85:170 90:4, 19:11, 21:2, 22:7
0
22:10,
90:60 90:7, 91:5, 103:24 25:21, 26:13, 32:4, 32:6,
scheduled- 28:2,31:12 36:9, 38:5, 40:5
0
41:2, 41 :6,
scheme -113:22 43:25,44:7,46:3, 51:3,
Scholastics- 8:9, 8:23, 53:25, 58:1 o 59:19, 67:2
0
9:1 72:16, 88:19, 89:14
scientologlst- 9:7, 9:15, sheet- 56:8
12:19, 88:17, 88:20o 123:3o sheets- 56:3
150:10, 150:15 short- 29:14
sclentologists - 34:20
0
Shorthand- 1:20
0
160:5
35:21,36:20 show- 73:4
0
129:1
0
129:2
sclentology- 9:9, 36:80 shows- 93:19, 93:21
37:6, 43:6, 106:13 sic -109:1
Scientology- 20:12, 33:7
0
sign- 4:16
0
14:3
33:170 34:7, 35:17, 37:2, significance -123:24
45:10, 45:140 45:15o 89:1 1, signing. 4:15
117:16 signs· 62:10
scrap- 87:17 simply- 30:7, 109:20
Sdp-119:170 119:21 single· 77:17,78:21
Sea-13:16, 13:19, 13:21
0
sitting- 85:22
14:1 o 14:5, 14:7, 14:13, situation- 100:3
14:23, 15:1, 59:23 situations - 94:10
second -10:2 six- 32:1,41:21
0
44:23
secretaJy- 15:11 skeletons - 92:1
section -122:25 skills- 55:17
sections- 49:10 skipped- 98:17
secular- 89:10 slack -145:2
0
145:5
security -130:16 sloppy -104:15
see- 35:25, 36:4, 37:9, Smith- 25:13
58:22o 64:18, 74:200 75:25o Social- 7:2, 7:3, 7:10,
76:20 84:10, 85:15, 85:16, 7:120 7:13, 7:160 7:20, 8:7,
85:240 90:4,90:11,91:22, 8:21012:13,12:21 ,13:4,
91:24o 100:200 103:1, 103:40 13:11,36:23,60:4
103:12, 117:1o 119:10 someone -78:20,79:5
0
121:250 123:250 126:110 81:180 109:10, 115:4, 148:19
132:11 Sometimes- 60:12o
selling- 52:13 136:20, 141:19,149:9
0
send- 63:20, 65:11, 81:16
0
149:11 o 149:12
111:160 111:23, 111:24o sometimes- 77:8, 112:4
0
112:1, 131:3, 131:10, 132:9, 141:12, 141:17,141:18
132:15
0
135:16, 136:22, somewhere -54:11,
141:7,144:14,144:17, 99:11,103:13
148:6. 148:9, 149:18, sorry- 20:5, 21 :17o 28:6,
153:10, 156:12 36:14, 41:190 98:16, 101:18,
senlor-119:19 121:1,127:21 0139:1
seniors -153:9 sort-15:16, 16:5
0
16:13,
sense- 7:14, 7:24, 68:19, 43:9, 50:4, 50:25, 51 :12,
68:20 57:4,73:18, 91:18o 93:180
sent- 24:60 63:14,65:30 99:9,99:19, 101:14,110:18
0
65:80 65:14,65:15,69:1. 112:24, 126:80 126:19,
88:80 113:2, 134:18, 146:24, 127:25, 128:1 1, 133:25,
149:5, 156:7, 156:13 136:12, 136:14, 139:6,
LLC _
918
. l
49
. sot)tf14 142:5 146:16 1s2:2
PO Box 2823, Tulsa, Oklahoma 74101
8
49 or 51 sheets Page 8 to 8 of 10 06/28/2012 05:57:10 PM
http://ReachingForTheTippingPoint.nett
Deposition of Jette McGregor - 6/8/12
sounds- 86:14 75:22, 76:18, 76:20, 93:8, 48:12,48:15, 48:21, 49:1 ,
source -133:3, 133:11 93:13, 95:6, 103:3, 103:4, 49:21, 49:24, 50:1, 50:3,
sources -133:22, 134:5 108:22, 124:5, 124:12, 50:15, 50:17,50:23, 50:25,
Soverelgn-1:9 125:16, 125:22, 126:9, 51:12,51:17,56:12,56:14,
Speclal-19:24, 20:21 126: 10, 126:12 57:9, 57:12, 57:18, 57:25,
specialist- 97:16 student's -121:8 61:20, 62:21, 66:6, 67:19,
specialties- 86:15 students -15:13, 47:1, 68:2, 68:12, 70:16, 71 :1,
specific -13:10,27:17, 78:17,78:25, 90:14,92:2, 71 :5, 71:16, 72:12, 72:25,
49:12,55:24,66:4,76:19, 92:12,92:13, 92:15,93:1, 76:14, 81 :6, 81 :12, 82:1,
109:8,110:10, 111:2, 111:3, 93:17,94:19,99:8, 103:24, 95:1, 100:9, 102:11, 116:8,
111:11, 112:9 104:5, 104:9, 105:5,116:17, 116:20, 118:20,118:25,
specifically- 12:3, 12:4, 116:22, 117:11, 120:3, 119:14, 134:24, 135:4,
57:24,70:25,111:7 120:16,124:15,126:1, 148:13
specifics- 51:25, 100:13 126:14, 126:15, 126:21, technical- 47:4, 55:11,
specified -78:10,79:1 127:9, 128:8, 128:9,128:20, 55:17,67:20,67:22, 119:21
specify- 80:9 129:2, 129:7, 130:1 technically- 57:16
specifying -122:1 study- 66:1, 77:10, n:11, techniques- 52:13
spelled -145:22 124:5 technology- 57:18
split -7:4 stuff- 57:4,68:10,93:19, telephone- 2:14,22:6,
Square- 2:4 99:10, 99:20, 101:14, 26:14,27:16, 28:5
squash -133:16 101:24, 106:22, 107:7, template- 55:16
Ss-160:2 126:8, 141:22, 142:5,156:10 ten -125:23
staff - 11:1, 47:3, 150:9 submitted -135:6 term- 19:24
stage- 57:6 Subscribed- 158:4 terms- 6:7, 56:11, 116:7,
Stair-2:12 substance -26:12,41:9 117:23, 118:25,140:3,
Stand-10:7, 22:20, 58:7, Success- 94:20,94:21 142:14
72:17, 112:19, 155:4 success 124:18, territory - 109:9
standard -49:20, 56:11, 124:24 test- 43:9
56:14, 102:11 succinct- 43:2 tested -129:12, 129:17
standards- 49:18, 65:23, suggest- 39:4, 42:23 testified- 4:5
81:24, 121:22 suggesting - 93:4 testify -160:10
standing- 4:14, 16:3 suggests- 16:11 testimony -19:1 5, 20:2,
stands -119:19 Suite-1:18, 2:4,2:12 20:15,20:18, 20:25,21:2,
start - 6:18, 75:10, 78:12, sum- 112:6 27:10
90:22, 90:24, 117:5, 122:20 summarize- 98:18, 122:2, thankfully -143:11
started- 6:11, 6:14, 8:19, 123:21 themselves- 94:19,
12:16, 34:15, 34:22, 35:4, summarized - 156:7, 133:21, 140:5
123:9.,123:15,123:17 156:9, 156:13, 156:19 therapeutic-122:17
starting - 134:3 summary- 68:3, 115:20, thereafter- 160:13
starts- 46:14 127:12, 127:16, 127:20 therefor-159:3
stat -143:20, 143:23 Sunday-74:18 they've -73:4, 73:10,
State-1:1, 1:20, 11:15, sup -116:3 73:11,94:23
11:22, 95:10, 101:11, superintendent- 63:15, thinking- 63:3, 92:22
101:19, 105:2, 160:2, 160:6 155:15 thoroughly- 45:24, 148:7
state- 34:22, 91:14, 91:22, supervising- 86:21 three- 24:18, 31:4,42:12,
91:23, 102:7 supervision -128:12, 119:20
States- 12:7, 60:18, 115:1, 160:14 Three- 28:15
138:17 supervisor- 66.:9, 66:11, Thursday- 120:23, 141:5,
statistic-155:11 66:12,77:15,77:16,77:25, 142:19,144:12,156:18
statistlcal-143:17, 78:3, 78:4,78:18, 80:5, 80:6, tickets -149:12
144:10, 144:11, 145:12 80:21, 80:25, 81:1, 81:3, title- 10:16, 114:13,
statistics-15:12, 120:22, 81 :10,81:17,86:18,91:3, 114:14,119:23,140:19,
141:6, 142:6, 142:17, 105:16, 105:18, 116:4, 152:11,152:17,154:7,
142:25, 143:14, 143:24, 117:3, 117:13, 118:1,119:8, 154:13,154:22
145:21, 145:23,146:2, 119:9,119:10, 121:9, tltles-150:24
146:21 140:21, 150:7 today -17:6, 17:18, 18:16,
stats -144:2, 156:3, supervisors- 81:11 19:4, 19:15, 20:15,20:18,
156:20 support- 36:24 21 :1, 25:18, 27:10, 38:18,
trademarks -151:16
train- 56:5,91:1,150:8
trained - 77:24, 78:3,
81:17, 81:19, 86:16,86:17,
97:16, 117:1, 117:21,
117:25, 118:1 ,118:5,
118:14, 118:24, 119:1,
119:7, 149:19,150:6
Training- 61:8
training- 8:11, 53:16,
61:5,66:7, 81:3,81:5,90:23,
116:25,117:2,117:7,118:4,
118:8, 118:17,118:19,
119:14,119:15, 122:17,
149:14, 149:16, 149:21,
149:25, 150:4
transcribed -160:14
transgression - 124:3
transgressions -94:5,
94:11,94:14, 124:2, 125:11
transported - 99:13
traumatic -46:25
treasury -119:22
treatment· 34:20, 1 09:11
trick- 28:7
Trlsha-1 :19, 160:5,
160:21
trouble- 130:10, 130:19,
133:3, 133:11, 133:21, 134:5
Trs- 68:25, 69:11, 118:5,
122:20
true- 116:14
truth -4:4, 4:5, 53:6,
160:11
try- 16:16, 47:3, 50:11,
71:16, 95:8, 100:3
trying- 26:21, 28:7,44:10,
53:23, 56:2, 69:4, 70:20,
71:14,104:24, 109:18,
118:23, 127:24, 134:6,
148:4, 153:12, 154:8
Tulsa- 1:18, 160:3, 160:9
tum- 58:20, 122:22,
135:15, 135:16
turned- 8:25, 120:23,
136:7
twice- 60:7, 132:25
two -14:9,41:4,43:13,
43:14, 45:6, 117:9, 129:12,
129:16, 138:17, 147:12,
155:1
type- 5:2
typical - 92:19
typically- 48:12, 60:11,
62:10, 135:24, 147:16
u
stay· 41:11,77:5 suppose- 40:9,81:20, 38:21,45:11, 45:16,46:1, Ua-129:12
staying -130:1 139:20 80:10, 120:13, 129:11, Uas -129:11
stenography -160:13 supposed- 66:5,68:11, 137:23, 138:3, 146:11 , ultimate -120:21
Steppler-105:23, 115:11 73:4, 73:18, 79:17,93:8, 154:13 ultimately -13:12, 46:4,
steps -131:4 94:25, 101:12, 102:24, together- 65:9,69:13, 120:22, 135:9
still - 11 :3, 11:4, 42:6, 153:10 82:20, 82:22, 85:14, 143:14, umbrella- 7:7
79:19 suppressive-133:15 145:13,145:18 under-7:6, 7:13,7:18,
stimulating - 138:25 surface- 57:20 took- 23:2, 44:11, 155:23 7:19, 9:3, 89:11, 95:1,
stolen -121:17 sworn- 4:4, 158:4, 160:10 top -7:9
1
61:25,63:22, 105:12, 107:16, 126:22,
stopped -12:17 system -120:4, 121:7 115:8 127:9,128:20, 146:12,
Store- 14:9 1-----------1 topic- 33:18, 33:22, 160:14
stories- 94:20, 94:21, T 37:19,43:4, 95:18 understandable- 33:12,
124:15, 124:18 1----_;,-----1 toplcs-42:14, 43:14 130:11
stories' -124:24 tagged -136:25 total -112:6, 120:7 understood- 29:9, 33:13,
straight -154:8 taught- 53:20 totaled - 120:24 95:7, 99:22
Street - 1:18, 2:4, 2:8, teach- 119:11 totally- 69:3, 122:14 unhappy- 107:6
2:12, 160:8 teacher -133:19 totals- 156:10 unit- 125:18, 125:23
strikes -135:21 teaches -77:10 touch- 30:12 United-12:7, 60:18,
structure -19:14,137:13 teaching -116:17,116:21, Tr-70:10,122:18 115:1,138:17
structured -6:24,6:25, 117:10 Tracy-105:22, 105:23, unless -15:23,78:25,
15:4 team-148:9 107:8, 115:11 79:5,79:6,80:23
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51 of 51 sheets
Deposition of Jette McGregor - 6/8/12
unusual - 136:2
unwritten- 153:14
up -6:11, 6:21,7:4,8:3,
8:11,8:13, 8:14,8:16,9:2,
9:6, 11:20, 14:12, 23:5, 29:2,
39:18, 43:4, 43:8, 47:9,
47:15, 49:19, 51:9, 54:20,
55:23, 56:3, 56:7, 64:14,
64:16,67:20,71:6,71:22,
73:15,74:8,74:9,78:2,
80:17, 92:17, 93:19,93:21,
94:4, 94:11' 94:13, 109:2,
109:5,112:25,113:21,
114:19, 120:15, 120:22,
121:5, 124:2, 124:3, 129:22,
131:9, 131:19, 135:12,
135:23, 136:9, 139:10,
139:11. 140:8, 142:16,
143:16, 143:20, 144:8,
146:5, 153:3. 153:7
uplift- 47:3
Ups-133:12
upstream -146:17,
146:24, 156:13, 156:19
urinalyses- 129:16
urinalysis -129:13,
129:14
utilize - 48:21
v
various- 14:8, 25:20,
45:25, 48:8,48:16,49:10,
49:22, 67:23, 68:15, 149:20
verbal · 92:25, 125:22
via - 2:14
video - 61:11
Vldeo-1:15
vldeoed • 39:19
Videographer- 2: 18, 4:1,
10:7, 10:11, 22:20, 22:24,
58:7, 58:9, 72:17, 72:20,
112:19,112:21,155:4,
155:6, 156:25
violate • 95:5
violates - 93:9
visit· 46:7, 149:1
visited - 23:6, 59:11
vitamin - 103:9
vitamins - 103:7, 103:15,
103:21, 103:23
vs - 1:7
107:19, 121:7, 160:11
William- 34:16
wise- 92:3
Withdrawal - 68:24, 69:10
withdrawal- 70:9,70:21,
95:21' 96:9, 96:12, 96:23,
97:5,97:18, 122:7, 122:8
withholds -125:6, 125:7,
125:13
Witness- 3:2, 22:12, 58:6,
156:24, 160:19
witness -17:23, 18:16,
18:19, 22:8, 39:17, 160:9
witnesses· 90:12
woman • 154:4
word -71:13, 101:15
words· 95:24. 120:5,
120:16, 121:2,121:6
works-11 :4, 22:12,35:1,
62:13,76:17,84:23, 87:21,
114:9
world· 93:7, 136:21,
137:22, 150:15
wom-115:17
worse- 143:22
write- 57:21, 65:22, 67:20,
71:6, 80:17, 80:22, 81 :15,
92:17,94:4,94:11,94:22,
94:23, 124:2, 124:3, 124:16,
127:22
write-up· 92:17
writing· 62:10, 76:2,93:1
writings - 57:22
written - 53:11, 70:23,
84:7, 91:16, 94:13, 116:12,
125:21,153:14
wrote - 30:25, 32:12,
57:19,65:7, 65:14, 68:15,
69:5,71:11 ,98:21, 103:12,
103:20, 106:6, 132:12
X
Xanax- 125:17, 125:23
Xii-117:24
y
y'all-18:15, 26:17, 40:1,
83:22, 95:17
Yaeger- 2:15
Yager- 31:19,31:21,31:23
Yar1<o- 24:8, 46:9, 46:22,
w 51:9,61:19,63:17, 64:6,
l-__ .,........,...,......,...,.....------1 74:2, 74:3, 74:7, 74:9,
W/d- 97:16 113:23, 135:2, 136:1,
wait - 100:25 140:22, 155:16
walk -12:11 Yari<o's-46:12
wants - 48:4, 61:19, year -14:3,23:16, 38:19,
109:10,111:22,121:9 48:11,60:9,147:11
Washington- 2:16 years -11:24, 34:24, 71:8,
ways -148:2, 148:14 88:1, 147:12
website- 109:23 yesterday- 40:5
websltes ·109:1,109:9, you-all-11:17, 34:4
111:9, 111:12 yourself-148:10
week -97:17, 120:25, Yvette-115:3, 115:5
142:22, 142:23, 143:24, Yvonne-114:20, 115:4,
144:17, 148:22, 156:16 151:5, 151:6
weekly-15:9, 15:12,
120:22, 142:4, 142:5,
142:17, 143:17, 144:12,
144:13, 144:17, 144:18,
144:25, 145:11, 145:12,
145:20, 145:24, 146:20,
146:21,155:11, 155:15,
155:19, 156:3
West-1 39:13, 139:20,
139:22, 140:2, 140:6, 140:9,
140:14, 140:17
z
Zrlhen- 114:7
whole - 4·4 105:2o. 1o6:·GoODI1AN
REPORTING, LLC- 918.749.5000
PO Box 2823, Tulsa, Oklahoma 74101
Page 10 to 10 of 10
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