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LEWIS

BRISBOIS

BISG RD SMITHLLP

 ATTORNEYS AT LAW 

S. BRENT VOGELNevada Bar No. 006858Brent.Vogel@lewisbrisbois.com ALAYNE M. OPIENevada Bar No. 012623 Alayne.Opie@lewisbrisbois.comLEWIS BRISBOIS BISGAARD & SMITH

 LLP

6385 S. Rainbow Boulevard, Suite 600Las Vegas, Nevada 89118702.893.3383FAX: 702.893.3789

 Attorneys for Defendant Narconon Fresh Start d/b/a Rainbow Canyon Retreat 

UNITED STATES DISTRICT COURTFOR THE DISTRICT OF NEVADA 

DAVID WELCH, a Texas Citizen; STACY  WELCH, a Texas Citizen; and JACK WELCH,a Texas Citizen,Plaintiffs, vs.NARCONON FRESH START d/b/aRAINBOW CANYON RETREAT, aCalifornia Corporation; and DOES 1-100, ROECorporations I-X, inclusive,Defendants.CASE NO. 2:14-cv-00167-JCM-CWH

DEFENDANT’S ANSWER TOPLAINTIFFS’ COMPLAINTURY DEMAND

COMES NOW, Defendant Narcanon Fresh Start dba Rainbow Canyon Retreat(“Defendant”), by and through its attorneys, the law firm of Lewis Brisbois Bisgaard & Smith LLP,and in response to Plaintiffs’ Complaint (“Complaint”) on file herein, admit, deny and allege asfollows:

 THE PARTIES

1. Answering Paragraphs 1 and 3 of Plaintiffs’ Complaint, Defendant is withoutknowledge or information sufficient to form a belief as to the truth or falsity of the allegationscontained in said Paragraphs and on that basis deny same.2. Answering Paragraph 2 of Plaintiffs’ Complaint, Defendant admits the allegationscontained therein.

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BISG RD SMITHLLP

 ATTORNEYS AT LAW 

 JURISDICTION AND VENUE

3. Answering Paragraphs 4 and 5 of Plaintiffs’ Complaint, Defendant is withoutknowledge or information sufficient to form a belief as to the truth or falsity of the allegationscontained in said Paragraphs and on that basis deny same.

FACTUAL ALLEGATIONS

4. Answering Paragraphs 6, 7, 10, 11, 12, 14, 19, 20, 22, 27, 35, 37, 39, 40, 42, 43, 45, 47,49, 50, 51, 52, 55, 58, 62, 67, 68 and 75 of Plaintiffs’ Complaint, Defendant is without knowledge orinformation sufficient to form a belief as to the truth or falsity of the allegations contained in saidParagraphs and on that basis deny same.5. Answering Paragraphs 8, 9, 21, 24, 25, 28, 29, 30, 31, 32, 34, 36, 44, 46, 48, 53, 56, 57,59, 61, 63, 64, 65, 66, 70, 72, 73, 74 and 77 of Plaintiffs’ Complaint, Defendant denies the allegationscontained therein.6. Answering Paragraph 13 of Plaintiffs’ Complaint Defendant admits Penn explainedthat the fee for the program would be $33,000, and Defendant denies the remaining allegations.7. Answering Paragraphs 15, 16, 33, 38 and 41 of Plaintiffs’ Complaint, Defendantadmits the allegations contained therein.8. Answering Paragraph 18 of Plaintiffs’ Complaint Defendant admits the Contractprovides “The Narconon Program is secular (NON-RELIGIOUS) in nature and the program doesnot include in any participation in any religious studies of any kind.” Defendant denies the remaining allegations.9. Answering Paragraph 23 of Plaintiffs’ Complaint Defendant admits Jack wastransported to Caliente but Defendant denies the remaining allegations.10. Answering Paragraph 26 of Plaintiffs’ Complaint, Defendant alleges that Plaintiffs’allegations calls for a legal conclusion and as a result they are without knowledge or informationsufficient to form a belief as to the truth or falsity of the allegations and on that basis deny same.11. Answering Paragraph 54 of Plaintiffs’ Complaint Defendant admits it employsconcepts of “Overts and Withholds” and Defendant is without knowledge or information sufficientto form a belief as to the truth or falsity of the remaining allegations contained in said Paragraph and

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BISG RD SMITHLLP

 ATTORNEYS AT LAW 

on that basis deny same.12. Answering Paragraph 60 of Plaintiffs’ Complaint Defendant admits L. Ron Hubbardquotes are displayed at the Narconon facility in Caliente, Nevada but Defendant denies the remaining allegations.13. Answering Paragraph 69 of Plaintiffs’ Complaint Defendant is without knowledge orinformation sufficient to form a belief as to the truth or falsity of the allegations that on an occasion while Jack was undergoing the sauna program, he became unable to speak and had a constant tremorfor a period of two hours, and on that basis deny same. Defendant denies the remaining allegations insaid Paragraph.14. Answering Paragraph 71 of Plaintiffs’ Complaint Defendant admits Narcononrepresented to the Welches that its sauna program is medically safe, and Defendant denies theremaining allegations as worded.15. Answering Paragraph 76 of Plaintiffs’ Complaint Defendant is without knowledge orinformation sufficient to form a belief as to the truth or falsity of the allegations that the following day, Jack’s father, David, flew to Las Vegas, Nevada and then drove to the facility in Caliente, Nevada,and on that basis deny same. Defendant denies the remaining allegations in said Paragraph.

FIRST CAUSE OF ACTION(Breach of Contract)

16. Answering Paragraph 78 of Plaintiffs’ Complaint, Defendant hereby repeats, reallegesand incorporates by reference their responses to Paragraphs 1 through 77, supra, as though fully setforth herein.17. Answering Paragraph 79 of Plaintiffs’ Complaint, Defendant alleges that Plaintiffs’allegations calls for a legal conclusion and as a result they are without knowledge or informationsufficient to form a belief as to the truth or falsity of the allegations and on that basis deny same.18. Answering Paragraphs 80 and 81 of Plaintiffs’ Complaint, Defendant denies theallegations contained therein.

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