1
STATE OF MICHIGAN
2
IN THE CIRCUIT COURT FOR THE COUNTY OF CALHOUN
3
CANDICE TYLER, a MichiganCitizen; and JOHN DEBAY, a
4
Michigan Citizen,
5
Plaintiffs,
6
v Case No.: 15-846-NO Hon. Sarah S. Lincoln
7
NARCONON FREEDOM CENTER d/b/a NARCONON FREEDOM
8
TREATMENT CENTER, et al,
9
Defendants. __________________________/
1011
D E P O S I T I O N
12
of BETH SCOTT, a witness called by Plaintiffs, taken before
13
Kristie L. Dickinson, CSR-4667, Certified Shorthand Reporter
14
and Notary Public for Firm #8453, at 161 E. Michigan Ave.,
15
Battle Creek, Michigan, on Thursday, October 29, 2015,
16
beginning at 1:22 p.m.
171819202122232425
102915DICKINSON REPORTING, INC.(517) 487-1072
1 1
APPEARANCES:
2
On behalf of Plaintiff: SAEED & LITTLE, LLP1433 North Meridian St., Suite 202
3
Indianapolis, IN 46202BY JONATHAN LITTLE (27421-49)
4
and DAVID MILLER (31855-32)(317) 721-9214
5
On behalf of Defendant: MADDIN, HAUSER, ROTH & HELER, PC
6
28400 Northwestern Hwy., Suite 200Southfield, MI 48034
7
BY KATHLEEN H. KLAUS (P67207)(248) 359-7520
8
On behalf of Defendant: SCHEPER KIM & HARRIS, LLP
9
Via telephone601 W. 5th St., Suite 1200Los Angeles, CA 90071-2025
10
BY WILLIAM H. FORMAN, JD
11
Also present:Catherine Villanueva.
12
* * *
131415161718192021222324252 1
TABLE OF CONTENTS
2
Page
3 4
Examination by MR. LITTLE 4:16
5
* No exhibits marked.
6 7 8 9101112131415161718192021222324253 1
Battle Creek, Michigan
2
Thursday, October 29, 2015
3
At 1:22 p.m.
4
R E C O R D
5
BETH SCOTT,
6
after having first been duly administered an oath, was
7
examined and testified as follows:
8
THE WITNESS: I do.
9
MR. LITTLE
:
Okay. Ma'am, could you show
10
your ID to the court reporter
?
11
THE REPORTER:
It is a Michigan driver's
12
license. The name is Beth
Ann
Scott, spelled
B-e
-t-h
13
A-n-n S-c-o-t-t.
14
MR. LITTLE: Okay, great.
15
EXAMINATION
16
BY MR. LITTLE:
17
QAnd is that -- that's your name
,
ma'am?
18
AYes, it
is
.
19
QOkay, great. All right, ma'am. So you've been
20
designated by Narconon as the person to speak about the
21
technology and the treatment program offered at
22
Narconon Freedom Center.
23
MS. KLAUS: Objection
.
That's not what our
24
designation was
.
It was to talk about the education
25
program
that's
offered at NFC.
4
1
MR. LITTLE: Well, I believe she was offered
2
to talk about the treatment program.
3
MS. KLAUS: Well
,
she wasn't
.
She was --
4
MR. LITTLE: Well, let's take a look.
5
MS. KLAUS: Look at my objections
,
not your
6
notice. My designations.
7
MR. LITTLE: All right. You're
-- you're
8
saying she can speak about the -- here we go. Let's --
9
let's start with treatment... Okay
,
the education
10
program. All right.
11
Q(BY MR. LITTLE) I think we're talking about two
12
different versions of an apple
.
All right
,
here we go.
13
Ma'am, so tell us what your role is at the Narconon
14
Freedom Center
.
15
ACurrently
?
16
QYes, please
.
17
ADirector of Income.
18
QDirector of Income?
19
AYes.
20
QOkay. How long have you been the Director of Income?
21
AMaybe a week or so.
22
QWhat did you do before then?
23
AWhen Ms. Tyler was here?
24
QWell, let's go backwards immediately before you were
25
Director of Income
.
102915DICKINSON REPORTING, INC.(517) 487-1072
5 1
AI worked with getting documentation to the insurance
2
biller.
3
QAnd how long did you hold -- what was the title for
4
that job?
5
AMedical Records Admin.
6
QAnd how long did you work in Medical Records
7
Administration?
8
AAbout 18 months.
9
QOkay. When did you start with Narconon Freedom Center?
10
A2011.
11
QOkay. What did you do when you started in 2011?
12
AI was a withdrawal specialist.
13
QOkay. What's a withdrawal specialist?
14
AWithdrawal specialist helps people get through
15
nonmedical withdrawal symptoms.
16
QAre you a nurse?
17
AI am not.
18
QWhat's your educational background?
19
AI have -- I have a Bachelor of Science degree from
20
Purdue University in management.
21
Q
In man --
a BS in
,
like
,
business manage
ment
?
22
AYes.
23
QOkay. And when -- I'm from Purdue
.
Okay
.
You're from
24
Indiana?
25
AYes.
6 1
QOkay. So are we. Where are you from?
2
AOriginally
,
I'm from
--
originally or before I came
3
here
?
4
QOriginally
,
I guess
.
5
AConner
sville
, Indiana.
6
Q
Oh,
okay. Actually
,
I don't know where
Connersville --
7
is that out east by Richmond?
8
AYes.
9
QOkay. I do actually know. That's a small place
.
10
AVery small.
11
QMy fiancé
e
's from Winchester.
12
MS. KLAUS: Okay
.
Can we just get to the
13
question and answer
,
please
?
14
MR. LITTLE: Okay
.
I'm just...
15
Q(BY MR. LITTLE) All right. So
,
after you became a
16
withdrawal specialist
,
then what did you do for
17
Narconon Freedom
Center
?
18
AI was family liaison.
19
QWhen did you start that job?
20
A2012, February.
21
QOkay. When in 2011 did you start
?
Do you know?
22
AIt was, I believe, August.
23
QOkay. And then how long were you family liaison for?
24
AUntil -- I'm trying to remember. It was November 2012.
25
QThen what did you do?
7 1
AI don't remember the title
,
but then I was a supervisor
2
of the family liaisons.
3
QAnd then what -- how long did you hold that job?
4
AA couple of months
,
then I started student services.
5
QOkay. And when did you start student services?
6
AJanuary of 2013.
7
QAnd then when did you stop student services?
8
AJuly of 2013.
9
QOkay. What are student -- what is a Director of
10
Student Services?
11
AAssist students
,
for instance
,
with -- if they need to
12
make orders for shampoo, soap, that type of thing, if
13
they would like to order tobacco products
,
then we
14
order that for them
.
Because they don't leave the
15
facility to get that on their own.
16
QOkay
.
17
ASo
we place orders for them.
18
QOkay. So, prior to 2011, did you have any familiarity
19
with the Narconon Program?
20
ANo.
21
QOkay. Have you -- well, tell us, what is the Narconon
22
Freedom Center Education Program?
23
ASpecific parts of the program
,
or can you be a little
24
bit more specific
?
25
QYeah
.
Well
,
to be hon
est
with you
,
I'm trying to
8
1
figure out -- well
,
can you tell me what's your
2
interaction with the Narconon Freedom Center Education
3
Program? Like
,
what -- have you ever -- do you
4
administer it?
5
ANot any more.
6
QOkay. But you did?
7
AIn the withdrawal area.
8
QOkay
,
and tell me about that.
When --
so this was a
--
9
2011?
10
AYes.
11
QOkay. So what did you do when you administered the
12
Education Program in the withdrawal area?
13
APeople are withdrawing from drugs
,
so
you make them as
14
comfortable as you possibly can to try to help them
15
through the withdrawal symptoms.
16
QMm-hmm
.
17
AYou help them stay out of their head so they don't
18
become depressed, you administer as
sist
to
them
,
which
19
it's not really a massage
.
What it does is relax the
20
body so they can sleep
.
Individuals coming off
of
21
heroin often can't
sleep
. It helps
them
get their
22
much-needed rest
,
administer vitamins, make sure they
23
eat healthy meals.
24
QWell --
25
AIf they're having a bad day
,
what you do is assist them
102915DICKINSON REPORTING, INC.(517) 487-1072
9 1
and help them with whatever's going on with them.
2
QOkay. So
--
okay
.
Tell us about an as
sist.
What's an
3
assist?
4
AWhat it does is it helps to relax the individual's body
5
because sometimes their body aches, they're very tired,
6
too tired to the point where they can't sleep.
7
Basically what you do is you just go down a person's
8
arms and maybe on their back
--
9
QSo it's a physical?
10
A
-- back of legs.
Yeah
,
it
's
physical. We do -- we are
11
very much informed to not get close to personal areas.
12
It's very much restricted.
13
MR. LITTLE:
You know, we're -- I'm confused
14
as to how this person is the designee on the Education
15
Program
.
16
MS. KLAUS:
Why don't you
just
ask the
17
questions
,
and
she can an -- ask questions --
18
MR. LITTLE: She
does -- she
has no idea
19
about any
of the --
20
MS. KLAUS: You haven't even asked her
,
so
21
how do you know
?
22
MR. LITTLE: Because I just went through
h
er
23
job duties
,
responsibilit
ies.
She's never had anything
24
to do with education.
25
MS. KLAUS: It
doesn't mean she's not here to
10 1
talk a
bou
t it if you ask her the questions
,
Jonathan.
2
MR. LITTLE: Okay.
All right.
3
Q
(BY MR. LITTLE)
So let's start at
the beginning
then
.
4
If somebody comes into
Narconon,
a new patient
--
5
AMm-hmm.
6
Q-- what --
what happens
?
What's
the --
what is
the
7
protocol
?
8
M
S
.
KLAUS
: That's the intake
.
That's the
9
next person.
10
MR. LITTLE:
Yeah.
Well
,
I'm trying to get
11
to how they would end
-- end
up in the educational
12
portion of the program
,
Miss Klaus
,
so
--
13
MS. KLAUS: I think she testified to how that
14
starts when she talked about the withdrawal program.
15
Q(BY MR. LITTLE) Okay. So after -- during the
16
withdrawal
,
what kind of education do you administer or
17
give?
18
AWe try to make them
com --
learn how to be comfortable
19
where they're at.
20
QLike
,
what does that entail?
21
AWhat we d
o,
we call them -- it was called a training
22
routine, and you learn how to be -- to sit there and be
23
comfortable where you're at and try to clear your mind
24
of thoughts of the past and things that are making you
25
depressed
.
Just be comfortable where you're at in your
11 1
current,
present environment.
2
QSo
,
by
"
training routine,
"
like, can -- tell me more
3
about the training routine
.
What's the training
4
routine consist of?
5
AThey'll do it with another person
,
and two chairs are
6
facing each other.
7
Q
Mm-hmm.
8
AAnd you have to be three feet apart. And it makes you
9
comfortable in your environment and around other
10
people. So that's the purpose of the other person.
11
QSo you sit three feet apart
,
and then what do you do?
12
AWhat you do is -- there are two different types that we
13
have them do
-- do
in the withdraw
[sic]
area
.
One
14
with eyes closed
,
and then the other with eyes open
15
where you look right at the
person,
and it helps them
16
with confront.
17
QOkay
.
So when
-- when
you do -- let's talk about the
18
eyes closed
.
19
AMm-hmm.
20
Q
Which one
do
you do fir
st,
eyes closed or eye
s
open?
21
A
Eyes
close
d.
22
QOkay.
So tell me
,
so,
if we're
both
sitting three feet
23
apart from each other with
our
eyes closed
,
what
--
24
what
do the
-- the
people do?
25
AQui
et,
very qui
e
t
,
much like a meditation.
12
