IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION BENJAMIN BURGESS, RHONDA ) BURGESS, HEIDI HOWARD, ) JOYCE MARTIN, BETH ) CIVIL ACTION NO. KARAMPELAS, TERRI DACY, ) and MICHAEL DACY, individually ) 1:13-cv-02217 and on behalf of all others similarly ) situated, ) ) Plaintiffs, ) ) vs. ) ) RELIGIOUS TECHNOLOGY ) CENTER, INC., ASSOCIATION ) FOR BETTER LIVING AND ) EDUCATION INTERNATIONAL, )  NARCONON INTERNATIONAL, and )  NARCONON OF GEORGIA, INC., ) ) Defendants. ) )

PLAINTIFFS’ INITIAL DISCLOSURES

Plaintiffs make the following initial disclosures pursuant to Fed.R.Civ.P. 26(a)(1) based upon the information now reasonably available to them, and specifically reserve the right to supplement the disclosure pursuant to Fed.R.Civ.P. 26(e) based upon further investigation or upon the Defendants’ disclosures, supplemental disclosures, and/or discovery responses:

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1.

 

State precisely the classification of the cause of action being filed, a brief factual outline of the case including Plaintiffs’ contentions as to what Defendants did or failed to do, and a succinct statement of the legal issues in the case.

RESPONSE:

Plaintiffs, Benjamin Burgess, Rhonda Burgess, Heidi Howard, Joyce Martin, Beth Karampelas, Terri Dacy, and Michael Dacy, filed their Complaint individually and on behalf of the class of others similarly situated, against Defendants Religious Technology Center, Inc. (“RTC”), Association for Better Living and Education International (“ABLE”), International, and Narconon of Georgia, Inc. (“NNGA”), asserting claims sounding in fraud, contract, quasi-contract, and negligence, as well as Georgia’s Racketeer Influence and Corrupt Organizations (“RICO”) statute, O.C.G.A. § 16-14-1,

et seq.

Plaintiffs and the proposed class members paid money to one or more of the Defendants to enroll in the Narconon program at NNGA, and to cover costs associated with books, housing, and related goods and services. The Narconon  program was established in 1966 as a drug and alcohol rehabilitation program  based on the writings of L. Ron Hubbard, a science-fiction writer and the founder of the Church of Scientology. Narconon’s treatment for drug and alcohol addicts

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is based exclusively on Hubbard’s writings, also known as “technology” or “tech.”  Narconon’s proponents believe that strict adherence to the Hubbard technology alone will completely address the rehabilitation needs of its patients. Therefore,  patients receive no counseling or education in drug and alcohol rehabilitation, and the therapeutic discussion of drugs and their effects is actually discouraged. Defendant International owns, licenses, operates, and otherwise directs drug and alcohol rehabilitation services at Narconon centers, including NNGA, and thereby exercises direct control over the time, manner, and method of Defendant  NNGA’s operations. Defendant International, in turn, is controlled by Defendant ABLE, an umbrella group that oversees the drug and alcohol rehabilitation, education, and criminal-justice activities of the Church of Scientology. Finally, Defendants ABLE, International, and NNGA are controlled by Defendant RTC, which oversees Church of Scientology activities and serves as the final arbiter and enforcer of orthodoxy for all Scientology-related activities and organizations. As referenced above, Plaintiffs seek to represent a class defined as all individuals who have paid money to one or more of the Defendants to procure drug or alcohol rehabilitation services at NNGA for themselves or others, and to cover costs associated with books, housing, and other related or ancillary goods and

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