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STATE OF MICHIGAN
2
IN THE CIRCUIT COURT FOR THE COUNTY OF CALHOUN
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CANDICE TYLER, a MichiganCitizen; and JOHN DEBAY, a
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Michigan Citizen,
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Plaintiffs,
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v Case No.: 15-846-NO Hon. Sarah S. Lincoln
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NARCONON FREEDOM CENTER d/b/a NARCONON FREEDOM
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TREATMENT CENTER, et al,
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Defendants. __________________________/
1011
D E P O S I T I O N
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of TODD MESZAROS, a witness called by Plaintiffs, taken
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before Kristie L. Dickinson, CSR-4667, Certified Shorthand
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Reporter and Notary Public for Firm #8453, at 161 E.
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Michigan Ave., Battle Creek, Michigan, on Thursday, October
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29, 2015, beginning at 2:55 p.m.
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102915DICKINSON REPORTING, INC.(517) 487-1072
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APPEARANCES:
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On behalf of Plaintiff: SAEED & LITTLE, LLP1433 North Meridian St., Suite 202
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Indianapolis, IN 46202BY JONATHAN LITTLE (27421-49)
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and DAVID MILLER (31855-32)(317) 721-9214
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On behalf of Defendant: MADDIN, HAUSER, ROTH & HELER, PC
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28400 Northwestern Hwy., Suite 200Southfield, MI 48034
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BY KATHLEEN H. KLAUS (P67207)(248) 359-7520
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On behalf of Defendant: SCHEPER KIM & HARRIS, LLP
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Via telephone601 W. 5th St., Suite 1200Los Angeles, CA 90071-2025
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BY WILLIAM H. FORMAN, JD
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Also present:Catherine Villanueva.
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* * *
131415161718192021222324252 1
TABLE OF CONTENTS
2 3
Page
4
Examination by MR. LITTLE 4:16
5
* No exhibits marked.
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Battle Creek, Michigan
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Thursday, October 29, 2015
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At 2:55 p.m.
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R E C O R D
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TODD MESZAROS,
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after having first been duly administered an oath, was
7
examined and testified as follows:
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THE WITNESS: I do.
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MR. LITTLE: Hold on a second
.
10
THE REPORTER:
This is an Indiana
11
identification
card
. And the name on it is Todd,
12
T-o-
d-d, J, Meszaros,
M-e-s-z-a-r-o-s.
13
MR. LITTLE: M-a -- how do you spell that
14
again? M-a?
15
EXAMINATION
16
BY MR. LITTLE:
17
Q
Sir
,
can you state and spell your name
for the
record
,
18
please?
19
A
It's Todd, T-o-d-d,
M-e-s-z-a-r-o-s.
20
Q
Okay. Just like to note on the response from your
21
counsel, your name was also misspelled. Okay.
22
MS. KLAUS: I got Beth
's
right
.
Beth Scott
,
23
I typed that one right.
24
Q
(BY MR. LITTLE) All right. So, sir, you are
25
designated today by Narconon Freedom Center to speak on
4
1
two topics, the first being you're to testify as to
2
Narconon Freedom Center's web site as it was in the
3
spring of 2012.
4
ACorrect.
5
Q
And you are to -- designated to testify as to the
6
intake procedures at Narconon Freedom Center.
7
AYep.
8
Q
Okay. So let's start with the web site. Can you tell
9
us what the web address -- did -- did Narconon Freedom
10
Center have a web site in 2012?
11
AYes.
12
Q
And what was URL?
13
AI'm not sure.
14
Q
Okay. Did you create the content for the web site?
15
ANope.
16
Q
Do you know who hosted it?
17
ANo.
18
Q
Did you edit it?
19
ANo
pe
.
20
Q
Could you edit it?
21
AI have since then
,
but not in 2012.
22
Q
Who was in charge of the web site in 2012?
23
AI'm not sure.
24
Q
What was the URL for the web site in 2012?
25
AI don't know.
102915DICKINSON REPORTING, INC.(517) 487-1072
5 1
Q
How many web sites did Narconon Freedom Center have in
2
2012?
3
ANo idea.
4
Q
Did -- do you know if it was one?
5
AIt was definitely one.
6
Q
More than one?
7
AI have no idea.
8
Q
What kind of other web presence did Narconon Freedom
9
Center have in 2012?
10
AProbably banner ads.
11
Q
Facebook or Twitter?
12
AI don't think they were doing Facebook ads
,
and I don't
13
know about Twitter.
14
Q
Does Narconon Freedom Center -- did it have a Facebook
15
page in the spring of 2012?
16
AI believe so.
17
Q
Who was in charge of --
18
ADon't know.
19
MR. LITTLE: I'm going to say on the record
20
that that's -- this is -- this is the designee, and he
21
doesn't know any of these questions.
22
MS. KLAUS: You didn't -- I'm looking at the
23
designation. It doesn't say Facebook page so -- okay.
24
MR. LITTLE: He doesn't know the URL of the
25
web site
,
he doesn't
know
who hosted the web site
,
he
6 1
doesn't
know who was in charge of the web site.
2
MS. KLAUS:
Okay. Well,
why don't
you see --
3
ask him questions what he does
know about
the web site
,
4
okay?
I'm s
ure
you know the URL
of the web site,
and
5
I'm sure you know
its
address
.
But
you can
ask him
6
what he knows about it
.
But
,
as it re
lates
to Facebook
7
and Twitter
,
I don't
see
that on the designation.
8
Q
(BY MR. LITTLE) Who was responsible for the content in
9
Narconon's web site in the spring of 2012?
10
AI don't know.
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MS. KLAUS: Is that on the des
ig
-- no,
it's
12
not on the designation.
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MR. LITTLE: I would like to state for the
14
record that Miss Klaus wrote, Number 4, "Subject to
15
these object -- objections, NFC designates Todd Meszaro
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to testify as to NFC's spring 2012 web site."
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MS. KLAUS: Right. Not who wrote it, not
18
who's responsible for the content, but the web site.
19
So you can answer those questions.
20
MR. LITTLE: And I'll state on the record he
21
doesn't know the URL, he doesn't know where it was
22
hosted. These are the things I want to know.
23
MS. KLAUS:
Okay.
24
MR. LITTLE: I --
25
MS. KLAUS:
I'm sorry
.
If you want
ed
to
7 1
know
,
maybe you could have asked that
.
But that's just
2
me
.
That's just me.
3
THE WITNESS: I would assume
that
the address
4
was Freedomdrugrehab.
c
om because that's the one that
5
we've had for some time.
6
Q
(BY MR. LITTLE) Okay. And do you know any other --
7
does Narconon have any other URLs?
8
A
Not in 2012 that I know of.
9
Q
Okay. Do you know who hosts your web site now?
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AYep.
11
Q
Do you know when they started hosting it?
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A2013.
13
Q
Do you know who hosted it prior?
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AI don't.
15
Q
Who did the transfer, if you know?
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ARebecca Ryan.
17
Q
And who's Miss Ryan work for?
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ANarconon Freedom Center.
19
Q
And what is her job duties and responsibilities?
20
AShe's in charge of
,
like
,
media, public re
lations
,
21
like
,
through any type of multi-media.
22
Q
And was she there in 2012?
23
ANo.
24
Q
But she was in 2013?
25
AYes.
8
1
Q
Who was her predecessor?
2
AI'm not sure.
3
Q
When did you start working for Narconon Freedom Center?
4
A2013.
5
Q
What are your current job duties and responsibilities
6
at Narconon Freedom Center?
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AInternet, registration.
8
Q
What do you -- when you say "Internet," what do you do
9
for the --
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AWrite conte
nt
for the web site, make sure it's
,
like
,
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to code with
,
like
,
Narconon Freedom
--
or Narconon
,
12
like
,
org
,
International
,
and so forth.
13
Q
What do you mean it's code?
14
ATh
ey have
to be standardized
.
Like,
it
just can
say
15
basics of what the book offers and so
forth
.
16
Q
So you standardize it according to guidelines from
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Narconon International?
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MS. KLAUS: Objection to form
.
19
You can answer.
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THE WITNESS: Yeah
.
Yeah.
21
Q
(BY MR. LITTLE) Okay. And who do you get those
22
guidelines from?
23
ANarconon International.
24
Q
Who at Narconon International?
25
AI'm not sure
.
I don't know.
102915DICKINSON REPORTING, INC.(517) 487-1072
9 1
Q
If you have a question, who would you ask at Narconon
2
International?
3
AIt was pretty much
just --
like
,
it was just s
e
nt to
4
us. There was
n't
anything to question
,
the way the web
5
site
i
s now.
6
Q
So you just -- they sent it to you, and you just put it
7
up?
8
AYep
.
It's just hosted now.
9
Q
Who
hos
ts it now?
10
AIt would be Narconon
.o
rg.
11
Q
But who -- who's -- where is the server located?
12
AI don't know now.
13
Q
Where was it located --
14
ABefore
-- before
I did -- how I did it, it was our web
15
site that was maintained by us
;
and it's just changed
16
recently.
17
Q
When you maintained it, where was it hosted?
18
ARe
becca
was hosting
it.
19
Q
On her own private servers?
20
AYeah.
21
Q
Okay. And Rebecca Ryan, R-e-b-e-c-c --
22
AYeah.
23
Q
-- a. Okay. Ryan, R-y-a-n?
24
ACorrect.
25
Q
And she currently works at Narconon International?
10 1
ANope.
2
Q
Or Narconon Freedom Center, I mean?
3
ACorrect.
4
Q
Okay. And is she the person most familiar with the web
5
site hosting?
6
AFor the time of
,
like
,
2013, 2014.
7
MR. LITTLE: Okay. I'd like to ask on the
8
record why wasn't Rebecca Ryan designated? She's the
9
person that knows the stuff about the web site.
10
MS. KLAUS: And I'd like to say that we've
11
des
ignated
this
person
.
So ask this person questions.
12
If you read the rules
,
you don't get to pick who we
13
designat
e
.
14
MR. LITTLE: But you
have
to designate the
15
person who can answer the question
s.
16
MS. KLAUS:
And he is answering your
17
questions about the web site.
18
Q
(BY MR. LITTLE) Okay. Who do you report to at work?
19
AThe -- the Executive Director.
20
Q
And who's that?
21
AJean
i
e Trayhan
(ph.)
.
22
Q
Okay. And who owns Narconon Freedom Center?
23
MS. KLAUS: Don't speculate
.
Only if you
24
know.
25
THE WITNESS: No one
.
It's nonprofit.
11 1
Q
(BY MR. LITTLE) Who's on the board?
2
AOn the Board of Directors
?
I don't know.
3
Q
Is that on the web site?
4
AI don't believe so.
5
Q
Do you know if it's required to be on the web site?
6
AI don't know.
7
Q
Are you -- are the Board of Directors meetings on the
8
web site?
9
AMeetings o
n their
web site
?
10
Q
Yeah, the -- the minutes of their meetings you post on
11
the web site?
12
AI believe not
,
no.
13
Q
Okay. Do you know if that's required?
14
AI don't think it would be
,
but I don't know.
15
Q
So if it's --
16
MS. KLAUS: I'm sorry, required by who?
17
Q
(BY MR. LITTLE) I mean it's your job?
18
AI sat on the
Board
of Directors
for a
previous company
,
19
and we would
never put anything like that on the
20
Internet.
21
MS. KLAUS:
The --
22
MR. LITTLE: Okay. So are your --
23
MS. KLAUS:
My objection was to the form
of
24
the
question
.
25
Q(BY MR. LITTLE) -- are your 990s posted on your web
12
