Exhibit C

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AFFIDAVIT OF ERIC TENORIO

STATE OF NEW YORK ) ) SS COUNTY OF Tompkins ) Eric Tenorio, being first duly sworn deposes and says: 1. My name is Eric Tenorio. I am over 18 years of age, I have personal knowledge of the matters stated herein, and am available to testify. I reside at 129 Hickory Circle, Ithaca,  NY 14850 . 2. I worked for Narconon for over twelve years in various capacities. I have worked at Narconon Chilocco in Oklahoma, Narconon Arrowhead in Oklahoma, Narconon Stone Hawk in Michigan, Narconon Freedom Center in Michigan and Narconon Spring Hill in Florida. I was the Executive Director of Narconon Freedom Center in Albion, Michigan. This is the highest  position at a Narconon Center. 3. During my work at five different Narconon centers, I personally observed how an individual Narconon center is supervised and controlled by Narconon International and ABLE. 4. Narconon International publishes manuals that describe in detail how Narconon

International and ABLE “micromanage” indi

vidual Narconon centers. These manuals are

“Operating An Effective Narconon Center” and “Opening A Successful Narconon Center.”

Individual Narconon centers must abide by these manuals in conducting their operations. 5. As provided in these manuals, Narconon International has ultimate authority over the hiring and firing of staff members at individual Narconon centers. A permanent staff member at an individual Narconon center cannot be transferred, demoted, or dismissed without the approval of Narconon International. In addition, Narconon International serves as a Human Resources department of sorts in that staff members at individual Narconon centers can send Job

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Endangerment Chits to Narconon International if a staff member believes another employee is  preventing him from performing his job effectively. 6. Likewise, staff members at individual Narconon centers report misconduct or

“out

-

ethics activities” by other staff members to Narconon International. Narconon International

in turn investigates those employees and may take disciplinary actions against them. 7. Narconon International and ABLE supervise and monitor the delivery or the

“rehabilitative technology” at individual Narconon centers. To do this, Narconon International

and ABLE send persons to

conduct “tech inspections” at Narconon centers. These tech inspections consist of monitoring the manner in which staff conduct the “Training Routines” or

drills that comprise the Narconon written materials. Tech inspections also include monitoring the manner in which staff instruct Narconon students on how to work through the Narconon written materials. 8. Narconon International and ABLE must approve all websites an individual

 Narconon center uses before the site can “go live” on the Internet or before a

 

site’s content is

changed. 9. Narconon International must approve all promotional materials for an individual center before the center disseminates the materials. Narconon International also directs marketing campaigns for individual centers and dictate

s the content of a center’s marketing

materials. 10.

 Narconon’s claims about its “success rates” and its sauna program’s ability to

eliminate drug cravings come from Narconon International. Individual Narconon centers do not conduct research on the success of the program for Narconon students. Similarly, individual

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