10/29/15

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IN THE CIRCUIT COURT FOR THE COUNTY OF CALHOUN

NARCONON FREEDOM CENTER

d/b/a NARCONON FREEDOM
TREATMENT CENTER, et al,

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Case No.: 15-846-NO

Hon. Sarah S. Lincoln

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DEPOSITION

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13 before Kristie L. Dickinson, CSR-4667, Certified Shorthand

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14 Reporter and Notary Public for Firm #8453, at 161 E.

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15 Michigan Ave., Battle Creek, Michigan, on Thursday, October

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16 29, 2015, beginning at 2:55 p.m.

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APPEARANCES:

On behalf of Plaintiff: SAEED & LITTLE, LLP

1433 North Meridian St., Suite 202
Indianapolis, IN 46202
BY JONATHAN LITTLE (27421-49)
and DAVID MILLER (31855-32)
(317) 721-9214

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* No exhibits marked.

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On behalf of Defendant: MADDIN, HAUSER, ROTH & HELER, PC

28400 Northwestern Hwy., Suite 200
Southfield, MI 48034
BY KATHLEEN H. KLAUS (P67207)
(248) 359-7520

Battle Creek, Michigan

Thursday, October 29, 2015

At 2:55 p.m.

RECORD

TODD MESZAROS,

after having first been duly administered an oath, was

examined and testified as follows:

THE WITNESS: I do.

MR. LITTLE: Hold on a second.

On behalf of Defendant: SCHEPER KIM & HARRIS, LLP

9 Via telephone
601 W. 5th St., Suite 1200
Los Angeles, CA 90071-2025
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BY WILLIAM H. FORMAN, JD

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11 Also present:

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identification card. And the name on it is Todd,

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T-o-d-d, J, Meszaros, M-e-s-z-a-r-o-s.

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Catherine Villanueva.
*

4:16

12 of TODD MESZAROS, a witness called by Plaintiffs, taken

Page
Examination by MR. LITTLE

Defendants.
__________________________/

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TABLE OF CONTENTS

Plaintiffs,

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CANDICE TYLER, a Michigan

Citizen; and JOHN DEBAY, a
Michigan Citizen,

STATE OF MICHIGAN

THE REPORTER: This is an Indiana

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MR. LITTLE: M-a -- how do you spell that

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16 BY MR. LITTLE:

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17 Q

Sir, can you state and spell your name for the record,

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please?

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19 A

It's Todd, T-o-d-d, M-e-s-z-a-r-o-s.

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20 Q

Okay. Just like to note on the response from your

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counsel, your name was also misspelled. Okay.

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I typed that one right.

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24 Q

(BY MR. LITTLE) All right. So, sir, you are

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designated today by Narconon Freedom Center to speak on

again? M-a?
EXAMINATION

MS. KLAUS: I got Beth's right. Beth Scott,

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two topics, the first being you're to testify as to

doesn't know who was in charge of the web site.

Narconon Freedom Center's web site as it was in the

spring of 2012.

ask him questions what he does know about the web site,

MS. KLAUS: Okay. Well, why don't you see --

Correct.

okay? I'm sure you know the URL of the web site, and

And you are to -- designated to testify as to the

I'm sure you know its address. But you can ask him

intake procedures at Narconon Freedom Center.

what he knows about it. But, as it relates to Facebook

and Twitter, I don't see that on the designation.

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Yep.

Okay. So let's start with the web site. Can you tell

us what the web address -- did -- did Narconon Freedom

(BY MR. LITTLE) Who was responsible for the content in

Narconon's web site in the spring of 2012?

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Center have a web site in 2012?

10 A

11 A

Yes.

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12 Q

And what was URL?

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13 A

I'm not sure.

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14 Q

Okay. Did you create the content for the web site?

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record that Miss Klaus wrote, Number 4, "Subject to

15 A

Nope.

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these object -- objections, NFC designates Todd Meszaro

16 Q

Do you know who hosted it?

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to testify as to NFC's spring 2012 web site."

17 A

No.

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MS. KLAUS: Right. Not who wrote it, not

18 Q

Did you edit it?

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who's responsible for the content, but the web site.

19 A

Nope.

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20 Q

Could you edit it?

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MR. LITTLE: And I'll state on the record he

21 A

I have since then, but not in 2012.

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doesn't know the URL, he doesn't know where it was

22 Q

Who was in charge of the web site in 2012?

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hosted. These are the things I want to know.

23 A

I'm not sure.

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MS. KLAUS: Okay.

24 Q

What was the URL for the web site in 2012?

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MR. LITTLE: I --

25 A

I don't know.

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MS. KLAUS: I'm sorry. If you wanted to

How many web sites did Narconon Freedom Center have in

I don't know.
MS. KLAUS: Is that on the desig -- no, it's
not on the designation.
MR. LITTLE: I would like to state for the

So you can answer those questions.

know, maybe you could have asked that. But that's just
me. That's just me.

2012?

No idea.

Did -- do you know if it was one?

was Freedomdrugrehab.com because that's the one that

It was definitely one.

we've had for some time.

More than one?

I have no idea.

What kind of other web presence did Narconon Freedom

Not in 2012 that I know of.

Okay. Do you know who hosts your web site now?

Center have in 2012?

THE WITNESS: I would assume that the address

(BY MR. LITTLE) Okay. And do you know any other -does Narconon have any other URLs?

10 A

Probably banner ads.

10 A

Yep.

11 Q

Facebook or Twitter?

11 Q

Do you know when they started hosting it?

12 A

I don't think they were doing Facebook ads, and I don't

12 A

2013.

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know about Twitter.

13 Q

Do you know who hosted it prior?

14 Q

Does Narconon Freedom Center -- did it have a Facebook

14 A

I don't.

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page in the spring of 2012?

15 Q

Who did the transfer, if you know?

16 A

I believe so.

16 A

Rebecca Ryan.

17 Q

Who was in charge of --

17 Q

And who's Miss Ryan work for?

18 A

Don't know.

18 A

Narconon Freedom Center.

19 Q

And what is her job duties and responsibilities?

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MR. LITTLE: I'm going to say on the record

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that that's -- this is -- this is the designee, and he

20 A

She's in charge of, like, media, public relations,

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doesn't know any of these questions.

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like, through any type of multi-media.

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MS. KLAUS: You didn't -- I'm looking at the

22 Q

And was she there in 2012?

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designation. It doesn't say Facebook page so -- okay.

23 A

No.

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MR. LITTLE: He doesn't know the URL of the

24 Q

But she was in 2013?

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web site, he doesn't know who hosted the web site, he

25 A

Yes.

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Who was her predecessor?

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Nope.

I'm not sure.

Or Narconon Freedom Center, I mean?

When did you start working for Narconon Freedom Center?

Correct.

2013.

Okay. And is she the person most familiar with the web

What are your current job duties and responsibilities

at Narconon Freedom Center?

site hosting?
A

For the time of, like, 2013, 2014.

Internet, registration.

What do you -- when you say "Internet," what do you do

record why wasn't Rebecca Ryan designated? She's the

for the --

person that knows the stuff about the web site.

MR. LITTLE: Okay. I'd like to ask on the

10 A

Write content for the web site, make sure it's, like,

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to code with, like, Narconon Freedom -- or Narconon,

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designated this person. So ask this person questions.

MS. KLAUS: And I'd like to say that we've

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like, org, International, and so forth.

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If you read the rules, you don't get to pick who we

13 Q

What do you mean it's code?

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designate.

14 A

They have to be standardized. Like, it just can say

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basics of what the book offers and so forth.

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16 Q

So you standardize it according to guidelines from

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Narconon International?

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questions about the web site.

MR. LITTLE: But you have to designate the

person who can answer the questions.
MS. KLAUS: And he is answering your

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MS. KLAUS: Objection to form.

18 Q

(BY MR. LITTLE) Okay. Who do you report to at work?

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You can answer.

19 A

The -- the Executive Director.

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THE WITNESS: Yeah. Yeah.

20 Q

And who's that?

21 Q

(BY MR. LITTLE) Okay. And who do you get those

21 A

Jeanie Trayhan (ph.).

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guidelines from?

22 Q

Okay. And who owns Narconon Freedom Center?

23 A

Narconon International.

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24 Q

Who at Narconon International?

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25 A

I'm not sure. I don't know.

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know.
THE WITNESS: No one. It's nonprofit.

(BY MR. LITTLE) Who's on the board?

International?

On the Board of Directors? I don't know.

It was pretty much just -- like, it was just sent to

Is that on the web site?

us. There wasn't anything to question, the way the web

I don't believe so.

site is now.

Do you know if it's required to be on the web site?

So you just -- they sent it to you, and you just put it

I don't know.

up?

Are you -- are the Board of Directors meetings on the

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If you have a question, who would you ask at Narconon

MS. KLAUS: Don't speculate. Only if you

Yep. It's just hosted now.

Who hosts it now?

web site?
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Meetings on their web site?

10 A

It would be Narconon.org.

10 Q

Yeah, the -- the minutes of their meetings you post on

11 Q

But who -- who's -- where is the server located?

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the web site?

12 A

I don't know now.

12 A

I believe not, no.

13 Q

Where was it located --

13 Q

Okay. Do you know if that's required?

14 A

Before -- before I did -- how I did it, it was our web

14 A

I don't think it would be, but I don't know.

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site that was maintained by us; and it's just changed

15 Q

So if it's --

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recently.

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17 Q

When you maintained it, where was it hosted?

17 Q

(BY MR. LITTLE) I mean it's your job?

18 A

Rebecca was hosting it.

18 A

I sat on the Board of Directors for a previous company,

19 Q

On her own private servers?

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and we would never put anything like that on the

20 A

Yeah.

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Internet.

21 Q

Okay. And Rebecca Ryan, R-e-b-e-c-c --

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MS. KLAUS: The --

22 A

Yeah.

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MR. LITTLE: Okay. So are your --

23 Q

-- a. Okay. Ryan, R-y-a-n?

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24 A

Correct.

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the question.

25 Q

And she currently works at Narconon International?

25 Q

(BY MR. LITTLE) -- are your 990s posted on your web

MS. KLAUS: I'm sorry, required by who?

MS. KLAUS: My objection was to the form of

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site?

Like, standardized, like, blogs. A lot of it would be,

I don't think so.

Where -- do you know if your Board minutes are publicly

Personal history of who?

available?

Of myself. That would be personal.

You -- you would post your personal history on the web

like, personal history and so forth.

I don't know. I'm not on the Board of Directors.

Yeah. Well, I just thought they'd be on your web site.

Are your -- is your 990 publicly available, if you

Mm-hmm, like blogging.

know?

Like, what kind of -- what -- what kind of personal

I don't know.

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site?

history would you write on the web site?

10 Q

Okay. How -- how are you evaluated at work?

10 A

Just personal history of, like, you know, what's going

11 A

What do you mean "evaluated"?

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on in the center, what's happened in the center, and so

12 Q

Like, how is your production measured?

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forth.

13 A

There's Michigan State regulations; and it would be

13 Q

Oh. So not your, Todd's, personal history; but history

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based on, like, standard numbers.

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of -- of current events at the center?

15 Q

What do you mean "standard numbers"?

15 A

Sure.

16 A

Numbers of, like, impressions on web sites, impressions

16 Q

And what kind of events would you post?

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on, like, Facebook ads. Not web sites, but Facebook

17 A

Someone donated a -- turkeys a couple years ago.

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ads. That would be one thing, click-through rates and

18 Q

Okay. Do you post statistics about success rates?

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so forth.

19 A

Nope.

20 Q

Okay. And who do you report those statistics and

20 Q

I mean in 2012 -- I already know the answer to that

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conditions to?

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question.

22 A

I would give that to Jeanie.

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MR. LITTLE: Bill, are you there?

23 Q

Okay. And do you know how often you report them?

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MR. FORMAN: Hello?

24 A

Once a week.

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25 Q

And what day do you report them on?

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MR. LITTLE: Yeah. Hey, Mr. Forman, since

we're going to have to do this deposition with a

Thursday.

Okay. And then what does Jeanie do with them when she

MS. KLAUS: No.

gets them, if you know?

MR. LITTLE: -- at least on the subject of

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different deponent --

I don't know.

Do you ever get back any feedback on your work?

the web site --

Sure.

going to finish this deponent talking about the web

Who's that come from?

site. You've asked him questions not related to the

Jeanie.

topic, and now you're saying, oh, you're not answering

You ever get feedback from anybody else?

what I want. Ask him questions about the 2012 web

MS. KLAUS: No. No, you're not. You're

10 A

I mean that's a pretty general question.

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site.

11 Q

Like, when you get a -- do you get evaluated on a

11 Q

(BY MR. LITTLE) Okay. What was the URL in 2012?

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regular basis at work --

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Where was it hosted?

13 A

No.

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14 Q

-- your job performance? No? Okay. How -- you said

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you give them to me in an interrogatory. Ask him other

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-- what is -- your web site being up to code. What did

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questions about it, and he can answer.

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you mean by your web site is up to code?

16 Q

(BY MR. LITTLE) Who did the content?

17 A

Like, the code of Inter -- that International has.

17 A

I don't know. I didn't work in there in 2012. I can't

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They're trying to uniform everything we do.

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help you. I don't know.

19 Q

Narconon International is trying to uniform everything

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you do?

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content?

21 A

Mm-hmm.

21 Q

(BY MR. LITTLE) Yeah. What was on the web site in

22 Q

Okay. I don't know, what do you -- do you write any

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2012? First of all, let me ask you this: How would

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content that doesn't come from Narconon International?

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you know what was on the web site in 2012?

24 A

I have before, like, the new web site.

24 A

I don't know because I can't tell you if it had -- if

25 Q

What kind of content did you write?

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it had been changed or not. I don't know.

MS. KLAUS: I will answer those questions if

MS. KLAUS: Do you have questions about the

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MS. KLAUS: Did you change the web site?

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MR. LITTLE: Oh, hold on. I'm asking the

MS. KLAUS: Yeah, you're asking the

questions --

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questions.

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MR. LITTLE: I'm asking the questions.

MR. LITTLE: Miss Klaus, we're taking a

break. You need time.

MS. KLAUS: You need --

MR. LITTLE: You need to take a break.

MS. KLAUS: I don't need any time. We're

taking a break. You closed this topic, we'll go on to

the next.

That's it, I don't want any -- this is not the proper

designee.

MR. LITTLE: This records, right? Audio?

THE REPORTER: Yeah.

MS. KLAUS: Did you change it in 2000 --

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MR. LITTLE: Miss Klaus.

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MS. KLAUS: Because I'm clarifying it so you

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MS. KLAUS: Good.

MR. LITTLE: Let's take a five-minute break

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don't make a motion to compel on false information and

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just to let Miss Klaus calm down a little. We'll come

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waste everybody's time.

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back.

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Did you change the web site from its 2012

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content?

MS. KLAUS: I -- I don't need to calm down,

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Mr. Little. I think you do, which is why you're

walking out, and I'm sitting down.

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THE WITNESS: Yes.

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MS. KLAUS: Okay. Now maybe go on.

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(At 3:09 p.m. - Off the record.)

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(At 3:11 p.m. - Proceedings resume.)

18 Q

(BY MR. LITTLE) Okay. What did you change?

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MS. KLAUS: There you go. Questions.

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MS. KLAUS: Have we calmed down, Mr. Little?

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THE WITNESS: Mainly the --

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MR. LITTLE: I'm doing fine.

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MR. LITTLE: Excuse me. Miss Klaus, I do not

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MS. KLAUS: Good.

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like your tone. I do not like your condescending

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MR. LITTLE: Good. All right.

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comments.

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MS. KLAUS: Now maybe we can be more

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MS. KLAUS: I'm sorry.

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MR. LITTLE: Miss Klaus, you -- you are --

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you're behaving bizarrely; and I think that maybe we

need to take a five-minute break and --

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professional.
MR. LITTLE: Actually, Miss Klaus, I'd like

you to -- when you say Todd Meszaro [sic] to testify as

to NFC's spring 2012 web site --

MS. KLAUS: I'm good.

MR. LITTLE: -- get back on the record.

MS. KLAUS: No, I'm good. You can go ahead

MS. KLAUS: Mm-hmm.

MR. LITTLE: -- what do you -- what do you
mean by "spring 2012 web site"?

and ask some relevant questions and quit grandstanding

MS. KLAUS: I don't think this is the time

and acting like some kind of victim here. Ask the man

and the place. You can ask this witness questions

questions about the topic.

about that topic.

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10 Q

MR. LITTLE: Yes. Okay.

(BY MR. LITTLE) Sir -MR. LITTLE: He can't answer the questions I

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MS. KLAUS: You and I aren't going to argue

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on the record. It's a waste of everybody's time.

want to ask him about the web site, so there's no need

12 Q

(BY MR. LITTLE) All right. Sir, so where did you work

to go down this road. He's not the right designee.

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in 2012?

All right.

14 A

That doesn't pertain to this, but I didn't work for

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Narconon.

16 Q

Well, I know; but where did you work?

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MR. LITTLE: Okay.

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THE WITNESS: I looked at the web site. I

looked --

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MS. KLAUS: You're offering --

17 A

Why?

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THE WITNESS: -- at the esthetics of it.

18 Q

Well, sir, I'm asking you a question where you worked

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MS. KLAUS: Wait.

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in 2012. I think you have to answer that.

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He's offered the opportunity. He declines

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it, we can end. Go on to the next topic then. Okay,

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we'll go on --

22 Q

(BY MR. LITTLE) Where is that?

MS. KLAUS: You can go ahead and answer that.

THE WITNESS: Sign City Media.

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MR. LITTLE: Did you --

23 A

Advertising company.

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MS. KLAUS: -- to the next top -- Nope.

24 Q

Where is that located?

25 A

In Indiana.

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You're done. You closed your --

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Where in Indiana?

South Bend.

Okay. And where did you work before that?

What do you do for Narconon's web sites now?

WJ Haggertys [sic] and Sons.

Nothing.

What's that?

Okay. What do you --

That's a silver polishing, jewelry cleaner

I mean -- yeah. I mean nothing. It's not -- I don't

manufacturing company.

Okay. And so what I'm interested, what -- when did you

Where do you work now?

graduate high school?

At Narconon.

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office. Making sure the admin is in, making sure that

the payments have gone through.

have to do anything for it.

10 A

1992.

10 Q

Here at Freedom Center?

11 Q

Okay. And what's your education beyond high school?

11 A

At Freedom Center.

12 A

College.

12 Q

Do you work anywhere else?

13 Q

Where did you go?

13 A

Nope. In 2012, the web site that was presented to me

14 A

Indiana University, I went to Western University.

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that may have been the one that you're talking about,

15 Q

In Gunnison, Colorado?

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because I don't know for certain. I changed the

16 A

No.

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esthetics of it, so it was more appealing. It was kind

17 Q

Oh.

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of -- in my opinion, it was more pointed to -- or,

18 A

Michigan.

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like, the target market was younger people; and that's

19 Q

Oh. Oh, yeah, in Kalamazoo. Okay. What did you --

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not really the target market.

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what did you study at university?

20 Q

Okay. So you wrote the code to change the esthetics?

21 A

Business, art, all kinds of stuff.

21 A

I didn't write the code. I just came up with, like,

22 Q

Okay. And then, after university, where did you work

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the layout of the web site, the way it would work.

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next?

23 Q

Who wrote the code --

24 A

WJ Haggertys and Sons.

24 A

I don't know.

25 Q

Okay. And so what is your background in web sites?

25 Q

-- to change the esthetics?

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4

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Where...

I don't know who wrote the code.

Mainly more esthetics of, like, web sites. Like,

Do you know how to write code?

what's appealing to people and marketing.

No.

Okay. And so when you say "marketing," in terms of web

Have you done web sites for any other Narconon

sites, what do you mean by that?

entities?

I was a creative director. I did ad campaigns so...

No.

What kind of ad campaigns?

Are you -- do you know where calls from the Narconon --

I don't know if I can really disclose that because of

okay. Do you know what numbers on the Narconon --

telephone number's listed on the Narconon web site?

the corporation I worked for. Like, who and what

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campaigns they were. Like, jewelry stores mainly

10 A

Yeah. It's just one that rings into our office.

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though.

11 Q

Is that the only number listed on that?

12 A

Yeah.

13 Q

Who answers the calls after hours?

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MS. KLAUS: Okay. Without getting into

specifics --

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THE WITNESS: Yeah.

14 A

The same guys that answer them during the day. The

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MS. KLAUS: -- you can talk generally.

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phone always just rolls from the office to his cell

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THE WITNESS: You know, women are going to

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phone.

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buy engagement rings at certain times. So, like, I

17 Q

Did you set up that routing?

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would come up with campaigns for the products that they

18 A

The how -- I'm the one that figured out how to roll the

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sold.

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phone, but what do you mean "routing"?

20 Q

(BY MR. LITTLE) Is that what you do for Narconon now?

20 Q

Like, so when the call button, did you write the code

21 A

What's that?

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for the call button?

22 Q

Make campaigns?

22 A

What do you mean "call button"?

23 A

No.

23 Q

When you -- like, if you want to call a number, right,

24 Q

What do you do for them now?

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can you click on it to talk to a live person?

25 A

I'm in -- I'm in charge of, like, the registration

25 A

You're talking about like --

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MS. KLAUS: Through the computer?

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THE WITNESS: You're talking -- it's called

Call Per Click?

(BY MR. LITTLE) Okay. Anyways, I think we've

exhausted your knowledge of the web site.
MS. KLAUS: Objection to form, foundation.

(BY MR. LITTLE) Yeah.

We don't do Call Per Click.

Okay.

No.

I don't know if with the new web site because I haven't

Is there anything about the web site that -- that I

called in on it. I gave them the 800 number that I

bought through AT&T. I don't know if you can click on

(BY MR. LITTLE) Is there anything else about the web

site you would like to tell us?

haven't asked you that -MS. KLAUS: Objection to form.

10

it and actually speak to someone live. It's a cell

10

11

phone app. I looked at it.

11

12 Q

Okay. So you don't know, on the mobile web site, if

12 Q

(BY MR. LITTLE) All right. We will move on to intake

13

you can call click or not?

13

procedures. Okay. So do you have any medical

14 A

If you can call click it or not, I don't know. It

14

training, sir?

15

would be the same phone number though.

15 A

Nope.

16 Q

Who -- do you know who did your programming for your

16 Q

Okay. What does -- by coming to Narconon, how would I

17

app?

17

-- how would I first, as a -- a new patient, make

18 A

I don't know, because I just told you I don't even know

18

contact with you?

19

if we have that app. If someone has a cell phone, you

19

20

can look and see if it called.

20

student?

21 Q

Let's do that.

21 Q

(BY MR. LITTLE) Typically, as a new student, how would

22

MS. KLAUS: And let the record reflect

THE WITNESS: No.

MS. KLAUS: That is incredibly vague.

MS. KLAUS: Objection to form. You mean

22

I contact you?

23

they're again playing with their phones and computers

23 A

They'd be -- usually via telephone, like 99.9 percent.

24

during the dep.

24 Q

Okay. So I call, you answer?

25 A

You call. Yeah, one of the guys would answer the

25

MR. LITTLE: Okay. The record will so

26

reflect that I am using the Internet to look up

Narconon Freedom Center's web site. It does have Call

One of the guys like --

Click.

Or myself. I could answer the phone.

Okay. How many -- are you the -- how many intake

THE WITNESS: Okay, cool. That's really

cool.

phone.

people are there at Narconon Freedom Center?

(BY MR. LITTLE) All right.

Three.

Nice.

Are you their supervisor?

You didn't do that though? You never --

Yep. So, if I answer the phone and you call in, what

I didn't set it up.

would be your question?

10 Q

Okay.

10 Q

Okay. I would like to be admitted -- I have a drug

11 A

That's actually our front desk that you're calling, so

11

problem, I want to come to your facility. What happens

12

it's not even going into the --

12

next?

13

MS. KLAUS: And I object to --

13 A

Okay. We -- I'd have to fill out a Program Eligibility

14

THE WITNESS: -- Intake Office.

14

Form. This is now.

MS. KLAUS: -- you calling my client, so you

15 Q

Right.

16 A

This is present time, in 2000 and --

17 Q

Okay.

18 A

-- 15.

19 Q

Yep.

15
16

might want to hang up.

17
18

Well, do you want to give me Miss Tyler's

number; and I'll crank call her? Okay.

19
20

MR. LITTLE: I think it's time to take

20 A

You'd fill out a Program Eligibility Form. We would do

21

MS. KLAUS: I'm good.

21

it over the phone. It would have a drug rundown of,

22

MR. LITTLE: -- know what's wrong with Miss

22

like, what you're taking, what you're not taking. If

23

you're on prescription drugs and you're getting them

24

prescribed, you have to have a doctor's release to put

25

you into rehab.

23
24
25

another break. I -- I don't --

Klaus.
MS. KLAUS: There's nothing wrong with me. I
just didn't want you calling and speaking to my client.

27

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Okay.

29

After they would do the medical assessment, they would

You know, if you're buying them off of the streets,

speak to the potential client, they would let us know

it's a different story. I can't -- I can't give you

if they need a medical detox or not. They would

medical advice over the phone.

determine that.

Or can you give medical advice at all?

Be -- is that before they meet the client?

No.

This was before they would come in there. If you were

7
8

MS. KLAUS: Objection to form.

Q

(BY MR. LITTLE) Okay. Program Eligibility Form, are

they -- are they kept and maintained somewhere?

taking the certain types of drugs, you may need a

medical detox.
Q

Where are medical detoxes done at?

10 A

Yep.

10 A

Medical detox facilities.

11 Q

Where?

11 Q

Where are they -- where's the one at?

12 A

In Central Files. They're locked up.

12 A

Allegiance Hospital.

13 Q

And where is the Central Files located?

13 Q

Where is that at?

14 A

In the Treasury Office.

14 A

Allegiance Hospital in Jackson --

15 Q

And at 809 --

15 Q

Okay.

16 A

West Erie Street.

16 A

-- Michigan.

17 Q

Okay. Kansas City on that. I -- I'm going to say

17 Q

Lee -- how do you spell "Allegiant"?

18

"Kansas City" so I can find the stuff quicker in the

18 A

Allegiance.

19

word index, that's all.

19 Q

Allegiance, all right. Okay. Do people call in and

20 A

Cool.

20

say, well, I want to -- I'm considering different

21 Q

Okay. So program eligibility.

21

programs; why should I go to your program?

22 A

You fill out a Program Eligibility Form. We would do

22

23

it over the phone. It's about seven pages.

23

speaking on behalf of NFC; he just does the intake

24 Q

Okay.

24

procedures.

25 A

Okay? It's going to have a drug rundown, some

25

THE WITNESS: I mean I'll answer it.

No, usually they're just asking direct

30

MS. KLAUS: Objection. Again, he's not

questions on, like, health, medical, and so forth.

Then it would go to our doctor and nurse, and they

would do it. They would call in, and then they have a

questionnaire that they're going to fill out, and

they're going to come back and tell me if you're good

Exactly what we offer there.

questions about what we offer there.

Q

(BY MR. LITTLE) And what do you tell them about what
you offer?

to go or not.

What do you offer?

What's the questionnaire that doc --

We offer life skills, we offer a sauna program, we

I have no idea because --

9
10

THE REPORTER: I'm sorry, I didn't get all

the --

11
12

offer a series of -- of a battery called objectives.

Q

And what are -- what are the objectives?

10 A

Objectives are designed to get people to look outward

MR. LITTLE: Oh, sorry.

11

instead of inward and stop -- start -- stop thinking so

THE REPORTER: -- question. You kind of cut

12

subjectively and look more objectively.

13 Q

And when you say "objectives," are they -- is that --

14

are they written objectives?

13

him off. Let him finish, please.

14

What's the question?

31

15 Q

(BY MR. LITTLE) Oh, I just wanted to know what was the

15 A

They are written in a book. They get a workbook and a

16

questionnaire called, if you knew, that the doctor

16

book, the student.

17

fills out?

17 Q

How many workbooks and books do they get?

18 A

A medical assessment.

18 A

There -- now, in 2015, there are four.

19 Q

It's called a medical assessment?

19 Q

Okay. And are those books --

20 A

I believe so.

20

21 Q

And is that stored in Central Files?

21 Q

22 A

It would be stored in the Medical Department.

22

MS. KLAUS: -- you on speaker.

23 Q

Where is the Medical Department at?

23

(Speaking to Mr. Forman on her cell phone.)

24 A

At 809 West Erie Street.

24

25 Q

Okay. And then what else -- so after this medical --

25 Q

MS. KLAUS: Okay, I -(BY MR. LITTLE) -- written by --

THE WITNESS: I'm sorry?

(BY MR. LITTLE) Those books are based on the teachings

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33

of L. Ron Hubbard?

Doctors and nurses that work there.

They're based on the works of L. Ron Hubbard.

Who are the doctors and nurses?

Okay. Are they based on the works of anybody else?

Dr. Martin Holmes.

No.

Uh-huh. H-o-l-m-e-s?

Okay.

Correct.

As far as I know, no.

And who are the nurses?

All right.

The Director of Nursing is Melinda Sophia.

Just is based on the works. I mean there's a full

Mm-hmm. Okay.

video that somebody watches when they walk in, there's

Debbie Ray Amber. I don't know their last names.

9
10

a -- a poster or a big display that says, you know,

10 Q

Okay. So the determination is made that someone needs

11

Narconon was based on the works of L. Ron Hubbard.

11

to -- let's do both courses of action here. Does not

12 Q

What's the video they watch?

12

need a medical detox. What happens next?

13 A

It's a video that states the program was created by the

13 A

If they don't need a medical detox; and then, you know,

14

works of L. Ron Hubbard.

14

you've already presented the program, it's either

15 Q

How long is the video?

15

billed through insurance, or it's cash pay.

16 A

About ten minutes.

16 Q

Do you take the payments?

17 Q

What's the video called?

17 A

Do I physically take the payment?

18 A

I don't know. Introduction to Narconon.

18 Q

Yeah.

19 Q

So, if I wanted to get a copy of this video, what would

19 A

I mean, if you came in an intake office, yes.

20

I ask --

20 Q

What do you -- okay. So what do you do with the credit

21 A

You probably can go to Narconon International web site.

21

card if I give you a credit card?

22

It's probably on their page.

22 A

Credit card would go to Treasury, and they run it

23 Q

But I want to see the one they show at Freedom Center.

23

through a credit card machine, then the guarantor,

24

Who would have a copy?

24

whose credit card it is, would sign off on it.

25 A

I don't know. It's built into the TV. It's like a

25 Q

What about cash?

little closed-circuit thing where you can only watch

34

Like, actual cash money?

what videos are on it.

Yeah. Has that ever happened?

Is it called The Way To Happiness?

One time.

No.

Do you remember who that was?

5
6

MS. KLAUS: Can we go off the record? Can we

just stop for a second?

5
6

MS. KLAUS: No.

Q

(BY MR. LITTLE) Or was -- was it our client, Candice

(At 3:23 p.m. - Off the record.)

(At 3:23 p.m. - Proceedings resume.)

No. I wasn't even there when she came in.

Okay. What about checks? Do you take checks?

MS. KLAUS: I'm sorry, but he was just

Tyler?

10

disconnected, and I was trying to reconnect him. So I

10 A

Mm-hmm.

11

apologize for interrupting.

11 Q

What do you do with them?

12 Q

(BY MR. LITTLE) Video. So the ten-minute video, you

12 A

I would turn it in to Treasury.

13

don't know the name of it?

13 Q

Okay. And who do you turn it in to at Treasury?

14 A

It's called Introduction to Narconon.

14 A

Valerie or Karen.

15 Q

Okay, Introduction to Narconon. And, if I wanted to

15 Q

What's Valerie's last name?

16

get a copy of that, is that something you could get?

16 A

Kealoha.

17 A

No, I don't believe so.

17 Q

And what's Karen's last name?

18 Q

Who could get me the copy?

18 A

McSweeney.

19 A

I would try the International web site.

19 Q

Okay. Without saying a specific name, can you think of

20 Q

But, if I wanted to get it from Freedom Center, who

20

a time when somebody was not eligible to be in

21

would I ask for that?

21

Narconon?

22 A

I don't -- we wouldn't have a copy of it there.

22

23 Q

All right. Kansas City. Okay. So they make the

23

for what reason?

24

determination, the doc -- the Medical Department. And

24 Q

(BY MR. LITTLE) Have you ever turned somebody down --

25

who is the Medical Department?

25

someone called up that had the money, but you turned

MS. KLAUS: Objection to form. For some --

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37

them down?

But no psychiatric medication?

Yep.

Nope.

Okay. Can you tell me what kind of circumstances get

Okay. What about medication -- psychic -- what about

turned down?

medications for bipolar disorder?

Just a broad example?

That's the same thing.

Like, give me some examples, yeah.

Okay. So no medications for bipolar disorder?

If you've been convicted of rape.

It's a psychotropic drug.

Okay.

Okay. How long have you been in Intake at Narconon?

You need more?

Since July 2013.

10 Q

Yeah.

10 Q

Okay. Have you worked at any other Narconon

11 A

How many?

11

facilities?

12 Q

I mean just give me, you know, if you have examples,

12 A

No, sir.

13

just --

13 Q

Any Better -- Best Drug Rehab facilities?

14 A

If you -- if you're a violent, like, criminal, and

14 A

No.

15

you've done a lot of hard time in prison.

15 Q

Okay. Any --

16 Q

Okay.

16 A

No AFR, no BRS, none of them.

17 A

If you've -- you know, depending on your drug case, if

17 Q

Okay. Okay. So somebody comes in and -- no Best

18

it's too extensive, if you've been using drugs since

18

Choice?

19

you were three years old because, ironically, I've

19 A

I'm sorry?

20

heard this before. You know, a kid started taking --

20 Q

Best Choice Drug Rehab?

21

getting into cocaine when he was three or four years

21 A

I've never worked at a drug rehab before.

22

old, smoking pot, you're not --

22 Q

Okay.

23 Q

What --

23 A

So you can just --

24 A

-- qualified to do the program.

24 Q

Or Narconon or anything else --

25 Q

Okay. What about people who are on psychiatric

25

medication? Are they accepted at Narconon Freedom

2
3

38

MS. KLAUS: It's like green eggs and ham.

Center?

It would depend on the volume and, like, the type of

THE WITNESS: No.

Q

(BY MR. LITTLE) All right. So come in, take the

payment. What happens next as far as you're concerned?

medications.

What type of medications would not be accepted?

Lithium.

Okay.

What kind of paperwork?

Like, extensive use. If you've been on it for, like,

There's paperwork that would have to be done with the

15 years.

39

What do you do next for intake?

A

Well, I mean there's paperwork that would have to be

done.

guarantor and as well as the potential client.

10 Q

Any others?

10 Q

Can you tell me what those forms are called?

11 A

That's just too much of a broad question, you know.

11 A

Now or back then?

12

I'd have to have a specific, and then I'd have to do a

12 Q

Let's start with 2012.

13

-- I'd have to use my best judgment and then give it to

13 A

2012. Well, it would be the -- this is the -- this is

14

the doctor, you know.

14

pretty much the enrollment agreement right here.

15 Q

If someone -- if somebody was prescribed psychiatric

15 Q

And, if I wanted to refer to that, what would I call

16

medication, could they continue taking that medication

16

it?

17

while they were at Narconon Freedom Center?

17

MS. KLAUS: Exhibit 1?

18 A

No. It's a holistic program, which means we do

18

THE WITNESS: This would be --

19

everything all naturally.

19

MR. LITTLE: No.

20 Q

Okay. What about seizure medication? Would you --

20

MS. KLAUS: Is that marked as Exhibit 1 --

21

would they be allowed to be taking --

21

MR. LITTLE: In a different deposition.

22 A

Yeah.

22

MS. KLAUS: -- just for the record? Okay.

23 Q

Okay.

23

24 A

Heart medication. You know, I mean, if you've got

24

agreement.

25

diabetes, you know, it's not a problem.

25 Q

(BY MR. LITTLE) Okay. So if I said -- would it be

THE WITNESS: It would be an enrollment

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41

called an admission agreement?

HIPAA, H-I-P-P-A [sic].

Sure.

Okay. All right.

Because it's the same -- you know, it's an admission

application now.

(BY MR. LITTLE) Okay.

Okay. So, in 2015, it's called the admission

Hospital transportation, property search, like a

application?

5
6

THE REPORTER: Mm-hmm.

THE WITNESS: It would be a confidentiality
agreement. These are federal papers.

consent for a property search.

Yep.

Okay.

Okay. Now, the admission agreement from 2012, Exhibit

Release of information.

10

Number 1 from Valerie's deposition, is that a true and

10 Q

Okay.

11

accurate copy of an admissions agreement from 2012?

11 A

I'm trying to think what else is in there. I can't --

MS. KLAUS: If you know. Don't speculate.

12

I can't honestly recall the rest.

THE WITNESS: Well, I mean it's not dated.

12
13

13 Q

Okay. So I'm going to -- let me back up. Just because

14

I'm going to say yes because...

14

you haven't said it, you -- you are basing your

15 Q

(BY MR. LITTLE) Okay. Do you explain when -- so what

15

statement that these are typical drug rehab forms on

16

other forms do people sign when they --

16

the time you went to drug rehab?

17 A

Consent to receive services, suicide waiver.

17

18 Q

What's a suicide waiver?

18

19 A

You know, that you're not suicidal. Just a standard

19

20

liability form.

20

with other rehabs, and they've shown me their

21 Q

Okay.

21

paperwork.

22 A

I mean this is all standard. Like, any rehab that you

22 Q

(BY MR. LITTLE) Okay. But you've never worked for

23

go to, you're going to sign something like that.

23

another drug rehab?

24 Q

How do you know that?

24 A

No. No, sir.

25 A

Because I've been in rehab before.

25 Q

Okay. So who are these other drug rehabs that showed

42

But you said you never worked in a rehab before?

I've been into a rehab before.

Can I ask why you were in a rehab?

MS. KLAUS: No. No.

MR. LITTLE: Well, I mean he's testifying

this is a standard form.

MS. KLAUS: Objection to form. He said he

went to rehab.
THE WITNESS: I've been in -- I've worked

44

you -A

I worked -- I've worked with medical detoxes where I've

-- like, I had to take a client in there; and they
showed me the paperwork; does that make sense?

It makes sense. That's not the answer your attorney

tried to give. But you work with --

MS. KLAUS: Yeah.

MR. LITTLE: He's in charge of forms at

what, Jonathan? Stop it, okay? They said no snark.

The judge was very clear, so no snark.

9
10

Narconon -MS. KLAUS: He said he's been in one, but

MS. KLAUS: I'm not -- I just -- you know

10

MR. LITTLE: Exactly.

11

he's not going to go into his personal medical history.

11

MS. KLAUS: Okay? Exactly. So --

12

There's no confidentiality protecting this case --

12

MR. LITTLE: I'm glad --

13

MR. LITTLE: Okay, hold on.

13

MS. KLAUS: Okay, then on we go.

14

MS. KLAUS: Let me finish. There's no

14

MR. LITTLE: Miss Klaus --

15

confidentiality protective order in this case, and it's

15

MS. KLAUS: You know, that's amateur hour.

16

not relevant to his testimony. So he's not going to

16

MR. LITTLE: Miss Klaus --

17

talk about his personal medical history.

17

MS. KLAUS: Just ask him his questions --

18

MR. LITTLE: Miss Klaus --

19

MS. KLAUS: -- and cut it out.

18
19
20

MR. LITTLE: Well, he hasn't actually said

that he's been in a rehab for medical --

20

MR. LITTLE: -- this is my deposition.

21

-- the rest of your questions, consent to receive

21

MS. KLAUS: Cut out the side comment.

22

services, suicide waiver, HIPAA papers.

22

MR. LITTLE: Please refrain --

23
24
25

THE WITNESS: Okay, fair enough. So have you

THE REPORTER: I'm sorry, you want too fast.

"Consent to" --

23
24

THE WITNESS: Consent to receive services,

25

43

MS. KLAUS: I'm telling you to cut out the

side comments.
MR. LITTLE: Miss Klaus, Miss Klaus, stop it.

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45

(BY MR. LITTLE) Now, sir --

MS. KLAUS: Cut out the side comments,

Jonathan, or we'll go back upstairs.

We require, like, physical activity. And, if someone

isn't capable of doing it, they're not going to be

qualified for our program.

MR. LITTLE: Miss Klaus.

What kind of physical activity do you require?

MS. KLAUS: Yeah, I know that's my name.

Running, jogging, exercise, and so forth.

MR. LITTLE: Do not address me like that.

And who prescribes the physical activity?

The doctor, I guess.

Who makes a decision if someone's qualified for

Now --

MS. KLAUS: I'm sorry, Mr. Little, cut out

the side comments, or we're going back upstairs.

physical activity or not?

10

MR. LITTLE: We're going off the record.

10 A

If you can't walk, how can you do physical activity

11

MS. KLAUS: No.

11

there?

12

MR. LITTLE: Okay, then we're going on the

12 Q

But do you make that call, or does somebody else?

13

record. Don't talk to me like you're my mother.

13 A

It's a judgment call.

14

MS. KLAUS: Oh, I'm not your mother.

14 Q

On whose judgment?

15

MR. LITTLE: I'm asking this witness -- I'm

15 A

Depends on who's on the -- who is working with the

16

asking this witness questions. Don't interrupt my

16

potential client.

17

deposition.

17 Q

So you or one of the other Intake people?

18 A

Mm-hmm.

19 Q

Okay. So, if I wanted to get the admission agreement,

20

the consent to receive treatment, the suicide waiver,

18

MS. KLAUS: Okay. I'm not interrupting, and

19

quit out -- and stop the side -- snide comments.

20

MR. LITTLE: Okay.

21 Q

(BY MR. LITTLE) Now, you said you're familiar with

21

the HIPAA waivers, the confidentiality agreement, the

22

these forms when you went to other medical drug rehab

22

hospital transportation agreement, the property search

23

facilities?

23

agreement, and release of information agreement, who

24 A

I've seen other forms. This is just standard.

24

would I -- where -- where would these be kept for Miss

25 Q

But I -- when you say it's "standard," I'm trying to

25

Tyler? Where are they stored at?

base -- you're saying standard. I want to know why you

46

They'd be in -- in Central Files.

Okay. And who at Central Files would know -- if you

think it's standard.

Because I've seen other forms from other facilities.

Okay. And you've seen those other forms in the course

of your employment at Narconon?

I wouldn't be able to access them.

47

wanted to get them, who would you go ask at Central

Files?

Correct.

Who would be able to access them?

Because Narconon sent you to those other facilities?

Valerie.

I work with other facilities like med detoxes.

Okay. Do you know how -- okay. So do you -- but you

Okay. Which med detoxes are those?

help the people fill these forms out?

10 A

I told you Allegiance, Henry Ford Clinic.

10 A

I don't help them fill them out at all.

11 Q

In Detroit?

11 Q

Do you explain them to them?

12 A

Yep.

12 A

Yeah, and you have to read this before you come in.

13 Q

Okay.

13 Q

So you explain it to them. What if there are -- do you

14 A

I've had to route people over to Best Drug Rehab.

14

ever have people who are intoxicated when they come in?

15 Q

And that's another Narconon facility, correct?

15 A

It's kind of a broad question. It's hard to tell.

16 A

Nope.

16 Q

If somebody was intoxicated when you came in, would

17 Q

Best Drug Rehab is not a Narconon facility?

17

they sign these forms?

18 A

No.

18 A

If they were -- they'd have to go to Med Detox first if

19 Q

Okay. Have you ever received any compensation from

19

they're come -- just depends. "Intoxicated" is too

20

Best Drug Rehab?

20

broad.

21 A

No.

21 Q

If somebody was under the influence of alcohol,

22 Q

Okay. Why do you send people to Best Drug Rehab?

22

narcotics, drugs, would they sign these forms --

23 A

Because they weren't qualified to do our program.

23

24 Q

What's the difference between yours and Best Drug Rehab

24 Q

25

program?

25

MS. KLAUS: Objection to -(BY MR. LITTLE) -- when they come -MS. KLAUS: -- form. Objection to form.

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(BY MR. LITTLE) When somebody comes into the rehab

49

Okay. Nothing? No background in --

center at Narconon Freedom Center, and they're under

No.

the influence of alcohol or drugs or narcotics, do they

Okay. What about if someone goes to medical drug

sign these forms?

rehab, what -- what happens with them? They go to

medical drug rehab. Do they sign admission agreement,

MS. KLAUS: Same objection. You gave three

6
7

different conditions in one question.

(BY MR. LITTLE) Okay. You can answer.

They would sign their consent to receive services --

Mm-hmm.

And a property, like, search; so we can store their

MS. KLAUS: If you can. I mean he's asking

you three different things.

10

consent to receive, suicide waiver --

10

stuff while we take them to medical detox.

11

one that would be high, so they would sign the consent

11 Q

Okay. And then what happens?

12

paper. So now sometimes we've had to go back and have

12 A

They would go to medical detox, get signed -- get

13

them re-sign the paperwork.

13

checked in, and then they're under a different doctor's

14 Q

(BY MR. LITTLE) Okay.

14

care. It could be a day, it could be two weeks.

15 A

You know, it's common sense. Someone comes in, and

15 Q

And then --

16

they're falling over, that's where you go get the nurse

16 A

They would -- they would be in communication. They

17

and the medical doctor and take them -- you route them

17

would have to sign a release of information. This is

18

elsewhere, medical detox, hospital.

18

how I know about these forms. They would sign a

19 Q

Could somebody be admitted to Narconon and not sign

19

release of information so our medical doctor and nurses

20

these forms?

20

could be in communication with their medical doctors

21 A

They'd have to sign a consent to receive services.

21

and nurses at said facility.

22 Q

But they wouldn't sign an admission agreement or

22 Q

So you -- your knowledge of the forms comes when you

23

something else?

23

get the -- when you get Henry Ford's forms back?

24 A

No.

24 A

Well, I've went in there, and I just looked at it to

25 Q

Okay.

25

make sure because we're bringing somebody in; and I

THE WITNESS: The guarantor wouldn't be the

I mean, if they're not in their right mind, there's no

50

don't want them looking at something that's, like,

reason to have them do that.

Okay. All right.

I can't facilitate somebody there that's --

Okay. So they come in, they sign the forms, then what

Bye.

do you -- what do you do with them if you're going to

Is that your area?

admit them?

No, but --

They would be turned over to security and medical for

Okay.

You know, I would tell them good luck, you know.

the search, and then their -- their actual physical

51

crazy. They don't -- wouldn't sign their life away.

Q

I got ya. Okay. What if somebody wants to -- after

admission, wants to leave the Narconon program?

10

medical assessment and physical and so forth with the

10 Q

If somebody -- do you, as part of your job at Intake,

11

doctor. Forms would go down and get put into a folder,

11

do you ever transport new students from location to

12

and then I would turn them in to Treasury.

12

Freedom Center?

13 Q

Do you have any other interactions with the people

13 A

Is it my job to pick people up and bring them in there?

14

after that, with the new admissions?

14 Q

Yeah.

15 A

Very little.

15 A

No.

16 Q

Okay.

16 Q

Have you ever done that?

17 A

We are on site though. We're at the facility.

17 A

I have.

18 Q

Okay. Do you have any training in chemical dependency

18 Q

Is that -- how many times?

19

counseling?

19 A

I went one time to the airport just so I could see the

20 A

Nope.

20

Detroit airport, just so I had an idea what it looked

21 Q

Do you have any other education besides your college

21

like. I think twice. A few more times than that.

22

educations or beyond your college education? Any --

22

Maybe five.

23

like a -- designations, certified dependency counselor

23 Q

Who -- who typically does that? Who typically --

24

or anything like that?

24 A

Transport driver.

25 A

Nope.

25 Q

Who's the transport driver now?

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Now?

4
5

53

Did Brian Basil ever work for Narconon Freedom Center?

Yeah.

I don't know.

Lucas.

Did you ever see him at Narconon Freedom Center?

What's his last name?

Um --

I don't know how to spell it. It's Peckareco,

Physically?

Peckarocco.

I've seen him there a couple times. He came in to say

6
7

Okay.

P-e-c -- I don't know how he pronounces it. I just

call him Lucas.

hi a couple, like, months ago, like, into the, like,

administration part of the facility.
Q

Okay. What about a company called Allied Intervention

10 Q

And who was the transport driver in 2012, if you know?

10

Management, AIM, A-I-M?

11 A

I don't know.

11 A

I don't know.

12 Q

Who would be the person that you would think would know

12 Q

Okay. Okay. So, if I called up, and I was -- I

13

that information?

13

relayed that my loved one or myself had a -- a drug

14 A

Valerie probably would have known.

14

problem, okay, you -- you would be the person who would

15 Q

Are you familiar with the name Brian Basil?

15

answer the phone? Is that typically how it works?

16 A

Yep.

16 A

I wouldn't be the one that generally answered the

17 Q

Did he used to work in Intake?

17

phone.

18 A

I don't know.

18 Q

Who would that be?

19 Q

How do you know the name Brian Basil?

19 A

One of the intake coordinators.

20 A

He's an interventionist.

20 Q

Who are the intake coordinators?

21 Q

What's an interventionist?

21 A

Now?

22 A

He goes with families and stages an intervention to get

22 Q

Yeah, and in 2012.

23

someone to come into rehab.

23 A

I don't know who worked there in 2012 other than Tim

24 Q

Is that part of Intake?

24

Keller.

25 A

Not normally.

25 Q

Is he still --

Well, when would -- when would interventionist be used?

54

55

Nope.

An intervention would -- interventionist would be used

No? Okay.

when someone isn't willing to take responsibility for

Matt Henley.

their drug addiction and the family and loved ones want

Are these 2012 or current people?

to get them into treatment.

No, this is 2012.

And who makes the decision to use an interventionist?

Okay. Do you know where Tim Keller works now?

Family, loved ones, friends. I don't know.

Nope.

Do you suggest interventionists to use?

Matt Henley?

If it's necessary, like, once in a while.

Nope.

10 Q

Where do you get your referrals for interventionists

10 Q

Okay. Who are the current intake coordinators?

11

from?

11 A

Stephen Troutner.

12 A

Where do we get the interventionists from? There are a

12 Q

How do you spell that?

13

couple interventionist companies that we used to use.

13 A

S-t-e-p-h-e-n. Troutner, T-r-o-u-t-n-e-r.

14

I don't remember their name. And I believe Brian

14 Q

And who else?

15

worked for that company. I think they were out of Ohio

15 A

Brad Roussel. R-u -- or R-o-u-s-s-e-l.

16

because he is from Ohio, but I don't know for certain.

16 Q

R-o-u-s-s-e-l?

17

You can write down the world "ITS" or the acronym. I

17 A

Yep.

18

don't remember what it was for.

18 Q

Okay.

19 Q

Okay. Do you get any fees or any reimbursement for

19 A

And Tony. Last name is L-o-g-u-e.

20

recommending certain interventionists?

20 Q

Okay. And are -- do you know, do you have any

21 A

Nope.

21

supervisory authority over these people?

22 Q

Do you know how interventionists get paid?

22 A

Yep.

23 A

It would be through the family.

23 Q

You're their supervisor?

24 Q

Okay.

24 A

Mm-hmm.

25 A

Their fee would be separate, what they charge.

25 Q

Okay. So what are they instructed to tell people, you

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know, to kind of pitch the program? What's the --

2
3

57

MS. KLAUS: Objection to form.

Q

4
5

No.

-- to make comments on success rates? Okay.

(BY MR. LITTLE) If someone calls up, says, "Thinking

Even though Michigan State law requires that you, like,

about your program," what -- what do you instruct these

track that --

three gentlemen to say?

Mm-hmm.

They have a program outline.

-- it's too hard to give an analysis on, man.

What's that program outline called?

I got ya. Have you ever heard the figure 76 percent

Program outline, program overview.

Okay. And, if I wanted to get a copy of the program

success rate for Narconon Freedom Center?

A

No.

10

overview?

10 Q

Okay. Have you ever heard of 76 percent rate for

11 A

I could e-mail one to you.

11

Narconon overall?

12 Q

Okay. Perfect. I will get in touch with your lawyer

12 A

No.

13

then. And it -- it's called the program overview?

13 Q

Okay. When people call on Intake, do they ever ask

14 A

Yep.

14

questions about the sauna?

15 Q

Kan -- I'll just say "Kansas City" so I can find it in

15 A

Yeah.

16

the record. Okay. Great. And -- and what is

16 Q

What kind of -- what kind -- what kind -- what do you

17

contained in that program overview?

17

say about the sauna?

18 A

Just what we offer. Shows a picture of the center.

18 A

You know, it's a series of vitamins and minerals that

19 Q

And then some text?

19

flush out the drug toxins in your body.

20 A

Yep.

20 Q

What vitamins, if you know?

21 Q

Who wrote it?

21 A

Vitamin B-1 complex. There's Niacin involved.

22 A

I did.

22

Actually, the overview that I would send to them

23 Q

Okay.

23

explains exactly what it is because it's taken right

24 A

Kind of. I took it right out of the books.

24

out of the books.

25 Q

Out of the Narconon International books?

25 Q

What kind of oils [sic] and minerals?

Yeah. Nope, the ones that are in our center. There's

58

59

I can't remember. I don't really do the intake on --

an overview of, like, what each book offers.

over the phone. I don't know all of the -- the

What books are you referring to?

vitamins and stuff, like exactly.

The books that the students use in the program.

Are -- are those the --

No.

No?

Research as in...?

Nope, nope.

Like, if someone says, well, how do you know that these

Let me see them just a second. I'll just ask you what

Okay. Do you have any research or anything that

supports that B-1 or Niacin can help with -- or can
help with drug addiction?

vitamins help a drug reha -- you know, rehabilitation.

10

-- I'll read you a title of these, and you can tell me

10

Do you have any studies or anything that suggest that

11

this, not them. It's not the Personal Values and

11

they do, in fact, help with drug rehabilitation?

12

Integrity course --

12 A

Not -- the books have that, and there's another book

13 A

Nope.

13

that's in the program that is used.

14 Q

-- by Ron L. [sic] Hubbard? It's not the Ups and Downs

14 Q

What's that book called?

15

of Life course?

15 A

This is in 2015.

16 A

That's one of them, but it's not the same book. Same

16 Q

Okay.

17

title though.

17 A

It's called Clear Body, Clear Mind.

18 Q

Okay. Okay. Do you know -- so you -- you took the

18 Q

Clear Body, Clear Mind. Do people ever ask you what

19

intake -- you took the program overview out of -- out

19

the goal of the sauna program is?

20

of con --

20 A

It's to flush out the toxins and residuals in the body.

21 A

The new books.

21 Q

Okay.

22 Q

Okay. All right. Does the program overview state a

22 A

Like drug toxins that are oil soluble.

23

success rate?

23 Q

Do people -- do you -- oh, that are oil soluble?

24 A

Nope.

24 A

Mm-hmm.

25 Q

Do you instruct any of these gentlemen --

25 Q

Okay. And do you have any studies or research that

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support that that is actually a valid form of drug

61

Okay.

63

treatment?

I did the sauna.

I don't know.

Okay. Why did you do the sauna? Just to see what --

Okay. So how does it help the body to get rid of drug

See what it was like. I just did it for the second

toxins during drug treatment?

Well, Niacin opens up the blood capillaries.

Okay.

time.
Q

Okay. Do you know -- you attend any trainings by

Narconon International or anything like that?

You know, the vitamins, you're -- you're putting in the

No.

good stuff while the bad stuff is flushing out. Ni --

Okay. Do you know who Bobby Wiggins is?

10

this isn't, like, anything new. Like, before I worked

10 A

Mm-hmm.

11

at Narconon -- I mean Niacin's in everything; and

11 Q

Who is Bobby Wiggins?

12

that's what it's used for.

12 A

Barbie's wi -- her husband.

13 Q

Niacin's used for drug treatment?

13 Q

Who's Barbie?

14 A

Not for drug treatment per se; but to, like, flush out

14 A

His wife.

15

stuff in the body. Like, it's in pre workout. Like,

15 Q

I mean what's Bob -- what's Bobby Wiggins' relationship

16

if, you know, it opens your blood capillaries.

16

to Narconon, if any?

17 Q

So how did you -- how did you come to learn that?

17 A

He works at a Narconon, like, out in California. One

18 A

That it's in pre workout?

18

in OIJA.

19 Q

What's pre workout?

19 Q

Does he ever come to Narconon Freedom Center?

20 A

You don't know what pre -- you don't go to the gym or

20 A

Yeah, I've seen him a couple times.

21

anything?

21 Q

What does he do when he's at Narconon Freedom Center?

22 Q

No. Do I look like it? I'm skinny as -- you know.

22 A

He came in, did a drug education seminar.

23 A

I don't know, man.

23 Q

Did you attend that seminar?

24 Q

He does. (Indicating to Mr. Miller.)

24 A

Mm-hmm.

25 Q

And what was the goal of that seminar?

25

THE WITNESS: You know what I'm talking about

62

then, right?

MS. KLAUS: Objection to foundation.

MR. MILLER: Some do, some don't. Yes.

If you know.

THE WITNESS: Right.

THE WITNESS: I do know. He talked about how

(BY MR. LITTLE) What is it?

he owned a bar, and he talked about his own drug use

Just -- it's a -- it's a vitamin that opens up your

and how he became more cause over his situation. You

blood capillaries; and it helps, like, flush out stuff

know, when he got clean and sober and was able to be,

out your body. So sweats gets you more vascular and so

like, productive. He was kind of, like, giving a

forth.

motivational speech.

It's called pre workout?

(BY MR. LITTLE) And he works for Narconon

10 A

Yeah, but we don't use that at Narconon. Just giving

10

International?

11

you an example of what Niacin -- Niacin's in

11 A

I don't know if he does or not.

12

everything. Peanut butter, bread.

12 Q

Do you ever receive any calls, or do you ever receive

13 Q

How did you learn that the sauna program gets rid of

13

any referrals from a call center in Glendale,

14

drug toxins? Where did you get that information from?

14

California?

15 A

It's part of the Narconon program.

15 A

I don't know that to be where the location is.

16 Q

Okay. How do you -- how -- did you receive any

16

Narconon International, we get calls from them.

17

training in the Narconon program?

17 Q

And referrals?

18 A

And do I -- well, I don't deliver the program.

18 A

Not referrals. I mean they're calling in. It's like a

19 Q

But I mean, like, so if you're going to -- you know,

19

"where to buy."

20

you told me you were in charge of these three

20 Q

What do you mean by --

21

gentlemen, Stephen, Brad, and Tony, that answer

21

THE REPORTER: Like a...?

22

questions about the program when people call in. How

22

THE WITNESS: A "where to buy." A "where to

23

did you get the knowledge to help them answer the

23

buy." Like, it's territorial. If you're in Ohio,

24

questions?

24

you'd be -- and you're looking for a Narconon close to

25 A

I've read all the books.

25

you, you go to the one in Michigan.

DICKINSON REPORTING, INC.

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(BY MR. LITTLE) Okay.

65

67

and houses the web site?

Or, if a family member wants to get someone far from

home, they would call facility. It's like a "where to

just be through International. She does, like,

buy."

Facebook ads for me now.

I got ya.

You can't find Dr. Pepper in your area, you call

Dr. Pepper, and they tell you to go to 7-Eleven on the

Well, Narconon International is our, like, corporate.

corner of Third and Eighth or wherever.

So do they store your web site?

Got ya. Do you receive any training from Narconon Free

I believe so.

7
8
9

I mean she would be the one to ask. It would probably

When you say it's through International, what do you

mean by that?

10

-- from Narconon International in procedures on intake

10 Q

Okay. Can they edit your web site? Well, I guess they

11

or anything like that?

11

store it.

12 A

I mean there's a -- there's a manual, like, on how to

12 A

It's their web site, really. I mean it's not ours

13

do the paperwork.

13

anymore. Like, the web site that they host for us.

14 Q

What's the manual called?

14 Q

Okay.

15 A

Procedures and policies.

15 A

I mean it's theirs. We don't have our own anymore.

16

MR. LITTLE: So, if I asked you for the

16

MR. LITTLE: All right. Perfect. Thank you

17

procedures and policy manual, you would be able to get

17

very much. I have nothing further.

18

it, Miss Klaus?

18

MS. KLAUS: Okay. We're done.

19

MS. KLAUS: You can answer that question --

19

THE WITNESS: Cool.

20

THE WITNESS: Maybe.

20

(At 3:53 p.m. - Deposition concluded.)

21

MS. KLAUS: -- get it to him.

21

THE WITNESS: I don't know. I only have one

22

22
23

in my office, so probably not that one. But I might be

23

24

able to rustle one up somewhere.

24

25

MR. LITTLE: Okay. I'll say Kansas City

1
2

(BY MR. LITTLE) Do people from NI or able -- regularly

visit Narconon, if you know?

NI? Narconon International?

Yeah. They ever come to visit?

Not that I've seen.

Besides Bobby Wiggins or --

8
9

was --

10

1
2
3

STATE OF MICHIGAN
)
COUNTY OF INGHAM

MS. KLAUS: Objection. He hasn't said if he

THE WITNESS: I don't know if he -- I don't

11

know if he works for International. I don't know. I

12

think he works for OIJHA.

13 Q

(BY MR. LITTLE) Okay. What do you mean "works for

14

OIJHA"? What's OIJHA?

15 A

Narconon OIJHA. It's a facility in California.

16 Q

Okay.

17 A

O-I-J-H-A.

18 Q

Do you know Yvonne Rogers?

19 A

No.

20 Q

Okay. Robert Keifer?

21 A

Nope.

22 Q

A lady named Margarita, Margarita?

23 A

No.

24 Q

Okay. Just to go back to the web site for a minute,

25

Rebecca Ryan currently stores it or knows who stores

25
66

there so I can find it again later.

68

)
)

I certify that this transcript, consisting of

68 pages, is a complete, true and correct record of the

testimony of TODD MESZAROS, held in this case on October 29,

2015.

8
9
10

I also certify that, prior to taking this

deposition, TODD MESZAROS was duly sworn to tell the truth.
I also certify that I am not a relative or

11 employee of or an attorney for a party; or a relative or

12 employee of an attorney for a party; or financially
13 interested in the action.
14
15
16 November 8, 2015
17
18
19
20
21
22
23
24
25

DICKINSON REPORTING, INC.

(517) 487-1072

_______________________________
Kristie L. Dickinson, CSR-4667
P.O. Box 12133
Lansing, Michigan 48901-2133
Firm #8453

- 0 09 [1]

19:17

- 1 1 [3] 40:17,
20; 41:10
11 [1] 19:18
1200 [1] 2:9
12133
[1]
68:17
1433 [1] 2:2
15
[2]
28:18; 38:9
15-846-NO
[1] 1:6
16 [1] 3:4
161 [1] 1:14
1992
[1]
21:10
- 2 2 [2]
1:16;
4:3
200 [1] 2:6
2000
[2]
17:9; 28:16
2012
[33]
5:3, 10, 21,
22, 24; 6:2,
9, 15;
7:9,
16; 8:8, 22;
15:20; 16:9,
11, 17, 22,
23;
17:14;
20:2, 5, 13,
19;
23:13;
40:12,
13;
41:9,
11;
53:10;
55:22,
23;
56:4, 5
2013
[5]
8:12,
24;
9:4;
11:6;
39:9

2014
[1]
11:6
2015
[7]
1:16;
4:2;
32:18; 41:6;
60:15; 68:7,
16
202 [1] 2:2
23 [2] 34:7,
8
248 [1] 2:7
27421-49 [1]
2:3
28400
[1]
2:6
29 [3] 1:16;
4:2; 68:6
- 3 3 [5] 19:17,
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67:20
317 [1] 2:4
31855-32 [1]
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2:7
- 4 4 [2]
3:4;
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[1] 68:17
- 5 53 [1] 67:20
55 [2] 1:16;
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- 6 601 [1] 2:9

68 [1] 68:5
- 7 7-Eleven [1]
65:7
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76 [2] 59:7,
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- 8 8 [1] 68:16
800 [1] 25:8
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29:15; 30:24
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[1]
55:10
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[6]
48:5,
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64:6; 65:17,
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38:1, 5
access [2]
48:5, 6
according
[1] 9:16

accurate [1]
41:11
a c r o n ym [ 1 ]
54:17
acting
[1]
18:7
action
[2]
35:11; 68:13
activity [5]
47:1, 4, 6, 9,
10
actual
[2]
36:1; 50:9
Actually [2]
19:25; 59:22
actually [4]
25:10;
26:11;
42:18; 61:1
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7
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54:4; 60:6
address [4]
5:9;
7:5;
8:3; 45:6
admin
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23:1
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d [1] 4:6
administrati
on [1] 55:8
admission
[8]
41:1, 4,
6, 9; 47:19;
49:22; 51:5;
52:4
admissions
[2]
41:11;
50:14
admit
[1]
50:7
admitted [2]
28:10; 49:19
ads
[5]
6:10,
12;
13:17,
18;
67:4
Advertising
[1] 20:23

advice
[2]
29:4, 5
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[1]
39:16
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[2]
15:17; 55:7
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[13]
40:14,
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41:1, 9,
11;
43:4;
47:19,
21,
22,
23;
49:22; 51:5
ahead
[2]
18:5; 20:20
AIM
[1]
55:10
airport [2]
52:19, 20
al [1] 1:8
alcohol [2]
48:21; 49:3
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[5]
31:12,
14, 18, 19;
46:10
Allegiant [1]
31:17
Allied
[1]
55:9
allowed [1]
38:21
a l w a ys
[1]
24:15
amateur [1]
44:15
Amber
[1]
35:9
a n a l ys i s [ 1 ]
59:6
Angeles [1]
2:9
another [4]
26:20;
43:23;
46:15; 60:12
answer [21]
7:19;
9:19;
11:15;
15:20;

16:13,
15;
18:11;
20:19,
20;
24:14;
27:24,
25;
28:3,
8;
31:25; 44:5;
49:7; 55:15;
62:21,
23;
65:19
answered [1]
55:16
answering
[2]
11:16;
16:8
answers [1]
24:13
a n yb o d y [ 2 ]
14:9; 33:3
a n ym o r e [ 2 ]
67:13, 15
a n yt h i n g
[13]
10:4;
12:19; 23:7;
27:4,
7;
39:24;
50:24; 60:4,
10;
61:10,
21;
63:7;
65:11
An yw a ys [ 1 ]
27:1
a n yw h e r e [ 1 ]
23:12
apologize
[1] 34:11
app
[3]
25:11, 17, 19
appealing
[2]
22:3;
23:16
APPEARANC
ES [1] 2:1
application
[2] 41:5, 7
area
[2]
52:6; 65:6
aren't
[1]
20:10

argue
[1]
20:10
art [1] 21:21
asking
[8]
17:2, 4, 6;
20:18; 32:1;
45:15,
16;
49:8
assessment
[4]
30:18,
19;
31:1;
50:10
assume [1]
8:3
attend
[2]
63:6, 23
attorney [3]
44:5; 68:11,
12
Audio
[1]
19:8
authority [1]
56:21
available [2]
13:4, 7
Ave [1] 1:15
- B b [1] 1:7
B-1
[2]
59:21; 60:5
back
[11]
14:5;
18:4;
19:13; 30:5;
40:11;
43:13; 45:3,
9;
49:12;
51:23; 66:24
background
[2]
21:25;
51:1
bad [1] 61:9
banner [1]
6:10
bar [1] 64:4
Barbie
[1]
63:13
Barbie's [1]
63:12

base
[1]
46:1
based
[6]
13:14;
32:25; 33:2,
3, 8, 11
basics
[1]
9:15
Basil
[3]
53:15,
19;
55:1
basing
[1]
43:14
basis
[1]
14:12
battery [1]
32:8
Battle
[2]
1:15; 4:1
became [1]
64:5
Because [6]
17:11; 41:4,
25;
46:3, 7,
23
because [13]
8:4;
16:24;
22:8; 23:15;
25:7,
18;
30:8; 37:19;
41:14;
43:13;
51:25;
54:16; 59:23
Before
[1]
10:14
before [13]
1:13; 10:14;
14:24; 21:3;
31:5,
6;
37:20;
39:21;
41:25; 42:1,
2;
48:12;
61:10
beginning
[1] 1:16
behalf
[4]
2:2, 5, 8;
31:23

behaving [1]
18:1
being
[2]
5:1; 14:15
believe [7]
6:16;
12:4,
12;
30:20;
34:17;
54:14; 67:9
Bend
[1]
21:2
Besides [1]
66:7
besides [1]
50:21
Best
[8]
39:13,
17,
20;
46:14,
17, 20, 22,
24
best
[1]
38:13
Beth
[1]
4:22
Beth's
[1]
4:22
Better
[1]
39:13
between [1]
46:24
b e yo n d [ 2 ]
21:11; 50:22
big
[1]
33:10
Bill
[1]
15:22
billed
[1]
35:15
bipolar [2]
39:4, 6
bizarrely [1]
18:1
blogging [1]
15:7
blogs
[1]
15:1
blood
[3]
61:6,
16;
62:6

Board
[5]
12:2, 7, 18;
13:3, 5
board
[1]
12:1
Bob
[1]
63:15
Bobby
[4]
63:9, 11, 15;
66:7
Body
[2]
60:17, 18
body
[5]
59:19;
60:20; 61:4,
15; 62:7
book
[7]
9:15; 32:15,
16;
58:2,
16;
60:12,
14
books [11]
32:17,
19,
25;
57:24,
25;
58:3, 4,
21;
59:24;
60:12; 62:25
both
[1]
35:11
bought [1]
25:9
Box
[1]
68:17
Brad
[2]
56:15; 62:21
bread
[1]
62:12
break
[6]
18:2;
19:2,
4,
6,
11;
26:20
Brian
[4]
53:15,
19;
54:14; 55:1
bring
[1]
52:13
bringing [1]
51:25

broad
[4]
37:5; 38:11;
48:15, 20
BRS
[1]
39:16
built
[1]
33:25
Business [1]
21:21
butter
[1]
62:12
button
[3]
24:20, 21, 22
buy
[5]
22:17;
64:19,
22,
23; 65:4
b u yi n g
[1]
29:2
BY [51] 2:3,
7, 10; 4:16,
24;
7:8;
8:6;
9:21;
11:18; 12:1,
17,
25;
16:11,
16,
21;
17:18;
18:10;
20:12,
22;
22:20; 25:4;
26:6;
27:1,
4, 12, 21;
29:8; 30:15;
32:3, 21, 25;
34:12; 36:6,
24;
40:2,
25;
41:15;
43:5,
22;
45:1,
21;
48:24; 49:1,
7, 14; 57:3;
62:4;
64:9;
65:1;
66:2,
13
by
[15]
1:12;
3:4;
4:25; 10:15;
12:16;
14:16; 20:5;
22:5; 27:16;

32:21;
33:13;
58:14; 63:6;
64:20; 67:6
B ye [ 1 ] 5 2 : 5
- C C [1] 4:4
CA [1] 2:9
CALHOUN
[1] 1:2
California
[3]
63:17;
64:14; 66:15
Call
[3]
25:3,
5;
26:2
call
[21]
24:20,
21,
22,
23;
25:13,
14;
26:18;
27:24,
25;
28:8;
30:3;
31:19;
40:15;
47:12,
13;
53:9; 59:13;
62:22;
64:13; 65:3,
6
called [22]
1:12;
25:2,
8,
20;
30:16,
19;
32:8; 33:17;
34:3,
14;
36:25;
40:10; 41:1,
6; 55:9, 12;
57:7,
13;
60:14,
17;
62:9; 65:14
calling [4]
26:11,
15,
25; 64:18
calls
[5]
24:7,
13;

57:3; 64:12,
16
calm
[2]
19:12, 14
calmed [1]
19:19
came
[6]
23:21;
35:19; 36:8;
48:16; 55:6;
63:22
campaigns
[5]
22:6, 7,
10, 18, 22
CANDICE [1]
1:3
Candice [1]
36:6
capable [1]
47:2
capillaries
[3] 61:6, 16;
62:6
card
[6]
4:11; 35:21,
22, 23, 24
care
[1]
51:14
Case [1] 1:6
case
[4]
37:17;
42:12,
15;
68:6
cash
[3]
35:15,
25;
36:1
Catherine
[1] 2:11
cause
[1]
64:5
cell
[4]
24:15;
25:10,
19;
32:23
CENTER [2]
1:7, 8
Center [25]
4:25;
5:6;
6:1, 9, 14;
8:18; 9:3, 6;

11:2,
22;
23:10,
11;
28:5; 33:23;
34:20; 38:2,
17;
49:2;
52:12; 55:1,
3;
59:8;
63:19, 21
center
[7]
15:11,
14;
49:2; 57:18;
58:1; 64:13
Center's [2]
5:2; 26:2
Central [6]
29:12,
13;
30:21; 48:1,
2, 3
certain [5]
22:17;
23:15; 31:7;
54:16, 20
Certified [1]
1:13
certified [1]
50:23
certify
[3]
68:4, 8, 10
change [6]
17:1, 9, 14,
18;
23:20,
25
changed [3]
10:15;
16:25; 23:15
charge
[8]
5:22;
6:17;
7:1;
8:20;
22:25; 42:8;
54:25; 62:20
checked [1]
51:13
checks [2]
36:9
chemical [1]
50:18
Choice [2]
39:18, 20
CIRCUIT [1]
1:2

circumstanc
es [1] 37:3
Citizen [2]
1:3, 4
City
[6]
20:21;
29:17,
18;
34:23;
57:15; 65:25
c l a r i f yi n g
[1] 17:11
clean
[1]
64:6
cleaner [1]
21:6
Clear
[4]
60:17, 18
clear
[1]
44:9
Click
[3]
25:3,
5;
26:3
click
[4]
24:24; 25:9,
13, 14
click-throug
h [1] 13:18
client
[8]
26:15,
25;
31:2,
5;
36:6;
40:9;
44:3; 47:16
Clinic
[1]
46:10
close
[1]
64:24
closed
[2]
18:25; 19:6
closed-circu
it [1] 34:1
cocaine [1]
37:21
code
[11]
9:11,
13;
14:15,
16,
17;
23:20,
21,
23;
24:1, 2, 20
College [1]
21:12

college [2]
50:21, 22
Colorado [1]
21:15
comes
[4]
39:17; 49:1,
15; 51:22
coming [1]
27:16
comment [1]
44:21
comments
[6]
17:23;
44:24; 45:2,
9, 19; 59:2
common [1]
49:15
communicati
on
[2]
51:16, 20
companies
[1] 54:13
company [5]
12:18;
20:23; 21:7;
54:15; 55:9
compel [1]
17:12
compensatio
n [1] 46:19
complete [1]
68:5
complex [1]
59:21
computer [1]
25:1
computers
[1] 25:23
con
[1]
58:20
concerned
[1] 40:3
concluded
[1] 67:20
condescendi
ng [1] 17:22
conditions
[2]
13:21;
49:6

confidentiali
ty [4] 42:12,
15;
43:3;
47:21
Consent [3]
41:17;
42:24, 25
consent [7]
42:21; 43:7;
47:20;
49:11,
21;
51:6, 7
considering
[1] 31:20
consisting
[1] 68:4
contact [2]
27:18, 22
contained
[1] 57:17
content [9]
5:14;
7:8,
18;
9:10;
14:23,
25;
16:16,
20;
17:15
CONTENTS
[1] 3:1
continue [1]
38:16
convicted
[1] 37:7
Cool
[2]
29:20; 67:19
cool
[2]
26:4, 5
coordinator
s [3] 55:19,
20; 56:10
copy
[7]
33:19,
24;
34:16,
18,
22;
41:11;
57:9
corner
[1]
65:8
corporate
[1] 67:7
corporation
[1] 22:9

Correct [5]
5:4;
10:24;
11:3;
35:5;
46:6
correct [2]
46:15; 68:5
counsel [1]
4:21
counseling
[1] 50:19
counselor
[1] 50:23
COUNTY [2]
1:2; 68:2
couple
[5]
15:17;
54:13; 55:6,
7; 63:20
course
[3]
46:4; 58:12,
15
courses [1]
35:11
COURT [1]
1:2
crank
[1]
26:18
crazy
[1]
52:2
create
[1]
5:14
created [1]
33:13
creative [1]
22:6
Credit
[1]
35:22
credit
[4]
35:20,
21,
23, 24
Creek
[2]
1:15; 4:1
criminal [1]
37:14
CSR-4667 [2]
1:13; 68:16
current [4]
9:5;
15:14;
56:4, 10

currently [2]
10:25; 66:25
Cut
[2]
44:21; 45:2
cut
[4]
30:12;
44:19,
23;
45:8
- D D [2]
1:11;
4:4
d [1] 1:7
dated
[1]
41:13
DAVID
[1]
2:4
day
[3]
13:25;
24:14; 51:14
DEBAY
[1]
1:3
Debbie [1]
35:9
decision [2]
47:8; 54:6
declines [1]
18:20
Defendant
[2] 2:5, 8
Defendants
[1] 1:9
definitely [1]
6:5
deliver [1]
62:18
dep
[1]
25:24
Department
[4]
30:22,
23;
34:24,
25
depend [1]
38:3
dependency
[2]
50:18,
23
depending
[1] 37:17

Depends [1]
47:15
depends [1]
48:19
deponent [2]
16:1, 6
Deposition
[1] 67:20
deposition
[6]
15:25;
40:21;
41:10;
44:20;
45:17; 68:9
desig
[1]
7:11
designate
[2]
11:13,
14
designated
[4]
4:25;
5:5;
11:8,
11
designates
[1] 7:15
designation
[3]
6:23;
7:7, 12
designation
s [1] 50:23
designed [1]
32:10
designee [3]
6:20;
17:8;
18:13
desk
[1]
26:11
determinatio
n [2] 34:24;
35:10
determine
[1] 31:4
Detox
[1]
48:18
detox
[8]
31:3, 8, 10;
35:12,
13;
49:18;
51:10, 12

detoxes [4]
31:9;
44:2;
46:8, 9
Detroit [2]
46:11; 52:20
diabetes [1]
38:25
Dickinson
[2]
1:13;
68:16
difference
[1] 46:24
different [7]
16:1;
29:3;
31:20;
40:21; 49:6,
9; 51:13
direct
[1]
32:1
Director [2]
11:19; 35:7
director [1]
22:6
Directors [4]
12:2, 7, 18;
13:5
disclose [1]
22:8
disconnecte
d [1] 34:10
disorder [2]
39:4, 6
display [1]
33:10
doc
[2]
30:7; 34:24
doctor
[7]
30:2,
16;
38:14; 47:7;
49:17;
50:11; 51:19
doctor's [2]
28:24; 51:13
Doctors [1]
35:1
doctors [2]
35:2; 51:20
doing
[3]
6:12; 19:20;
47:2

donated [1]
15:17
done
[8]
18:25; 24:4;
31:9; 37:15;
40:6,
8;
52:16; 67:18
down
[10]
18:13;
19:12,
14,
16,
19;
36:24; 37:1,
4;
50:11;
54:17
Downs
[1]
58:14
Dr [3] 35:3;
65:6, 7
driver
[3]
52:24,
25;
53:10
Drug
[7]
39:13,
20;
46:14,
17,
20, 22, 24
drug
[28]
28:10,
21;
29:25;
37:17; 39:7,
21;
43:15,
16, 23, 25;
45:22; 51:3,
5;
54:4;
55:13;
59:19; 60:6,
9, 11, 22;
61:1,
4,
5,
13,
14;
62:14;
63:22; 64:4
drugs
[5]
28:23; 31:7;
37:18;
48:22; 49:3
duly [2] 4:6;
68:9
during
[3]
24:14;
25:24; 61:5

duties
[2]
8:19; 9:5
- E E [3]
1:11,
14; 4:4
e-mail
[1]
57:11
edit
[3]
5:18,
20;
67:10
education
[4]
21:11;
50:21,
22;
63:22
educations
[1] 50:22
eggs
[1]
39:25
Eighth
[1]
65:8
Eligibility
[4]
28:13,
20; 29:8, 22
eligibility
[1] 29:21
eligible [1]
36:20
elsewhere
[1] 49:18
e m p l o ye e [ 2 ]
68:11, 12
e m p l o ym e n t
[1] 46:5
end
[1]
18:21
engagement
[1] 22:17
enough [1]
42:20
enrollment
[2]
40:14,
23
entities [1]
24:5
Erie
[2]
29:16; 30:24

esthetics [5]
18:18; 22:2;
23:16, 20, 25
et [1] 1:8
evaluated
[3]
13:10,
11; 14:11
Even
[1]
59:3
even
[3]
25:18;
26:12; 36:8
events
[2]
15:14, 16
e v e r yb o d y' s
[2]
17:13;
20:11
e v e r yt h i n g
[5]
14:18,
19;
38:19;
61:11; 62:12
Exactly [3]
32:5; 44:10,
11
exactly [2]
59:23; 60:3
EXAMINATIO
N [1] 4:15
Examination
[1] 3:4
examined [1]
4:7
example [2]
37:5; 62:11
examples [2]
37:6, 12
Excuse [1]
17:21
Executive
[1] 11:19
exercise [1]
47:5
exhausted
[1] 27:2
Exhibit [3]
40:17,
20;
41:9
exhibits [1]
3:5

explain [3]
41:15;
48:11, 13
explains [1]
59:23
extensive
[2]
37:18;
38:8
- F Facebook [8]
6:11, 12, 14,
23;
7:6;
13:17; 67:4
facilitate [1]
50:4
facilities [7]
31:10;
39:11,
13;
45:23; 46:3,
7, 8
facility [8]
28:11;
46:15,
17;
50:17;
51:21; 55:8;
65:3; 66:15
fact
[1]
60:11
fair
[1]
42:20
falling
[1]
49:16
false
[1]
17:12
familiar [3]
11:4; 45:21;
53:15
families [1]
53:22
Family
[1]
54:7
family
[3]
54:4,
23;
65:2
far [3] 33:6;
40:3; 65:2
fast
[1]
42:23

federal [1]
43:4
fee
[1]
54:25
feedback [2]
14:5, 9
fees
[1]
54:19
few
[1]
52:21
figure
[1]
59:7
figured [1]
24:18
Files
[6]
29:12,
13;
30:21; 48:1,
2, 4
fill
[6]
28:13,
20;
29:22; 30:4;
48:9, 10
fills
[1]
30:17
financially
[1] 68:12
find
[4]
29:18;
57:15; 65:6;
66:1
fine
[1]
19:20
finish
[3]
16:6; 30:13;
42:14
Firm
[2]
1:14; 68:18
First
[1]
16:22
first [4] 4:6;
5:1;
27:17;
48:18
five
[1]
52:22
five-minute
[2]
18:2;
19:11
flush
[4]
59:19;

60:20;
61:14; 62:6
flushing [1]
61:9
folder
[1]
50:11
follows [1]
4:7
Ford
[1]
46:10
Ford's
[1]
51:23
Form
[4]
28:14,
20;
29:8, 22
form
[14]
9:18; 12:23;
27:3, 9, 19;
29:7; 36:22;
41:20; 42:6;
43:17;
48:25; 57:2;
61:1
FORMAN [2]
2:10; 15:23
Forman [2]
15:24; 32:23
Forms
[1]
50:11
forms [17]
40:10;
41:16; 42:8;
43:15;
45:22,
24;
46:3,
4;
48:9, 17, 22;
49:4,
20;
50:5; 51:18,
22, 23
forth
[9]
9:12,
15;
13:19; 15:2,
12;
30:1;
47:5; 50:10;
62:8
foundation
[2]
27:3;
64:1
four
[2]
32:18; 37:21

Free
[1]
65:9
FREEDOM
[2] 1:7
Freedom
[28]
4:25;
5:2, 6, 9;
6:1, 8, 14;
8:18; 9:3, 6,
11;
11:2,
22;
23:10,
11;
26:2;
28:5; 33:23;
34:20; 38:1,
17;
49:2;
52:12; 55:1,
3;
59:8;
63:19, 21
Freedomdru
grehab.com
[1] 8:4
friends [1]
54:7
front
[1]
26:11
full [1] 33:8
further [1]
67:17
- G general [1]
14:10
generally [2]
22:15; 55:16
gentlemen
[3]
57:5;
58:25; 62:21
get
[40]
9:21; 11:12;
14:5, 9, 11;
18:4;
30:9;
32:10,
15,
17;
33:19;
34:16,
18,
20;
37:3;
47:19; 48:3;
49:16;
50:11;
51:12,
23;

53:22; 54:5,
10, 12, 19,
22;
57:9,
12;
61:4;
62:14,
23;
64:16; 65:2,
17, 21
giving
[2]
62:10; 64:7
glad
[1]
44:12
Glendale [1]
64:13
goal
[2]
60:19; 63:25
goes
[2]
51:3; 53:22
Good
[3]
19:10, 21, 22
good
[6]
18:3,
5;
26:21; 30:5;
52:9; 61:9
Got [1] 65:9
got [6] 4:22;
38:24; 52:3;
59:7;
64:6;
65:5
graduate [1]
21:9
grandstandi
ng [1] 18:6
Great
[1]
57:16
green
[1]
39:25
guarantor
[3]
35:23;
40:9; 49:10
guess
[2]
47:7; 67:10
guidelines
[2] 9:16, 22
Gunnison [1]
21:15
g u ys
[3]
24:14;
27:25; 28:2
g ym
[1]
61:20

- H H [2] 2:7, 10
H-I-P-P-A [1]
43:1
H-o-l-m-e-s
[1] 35:4
H a g g e r t ys
[2] 21:4, 24
ham
[1]
39:25
hang
[1]
26:16
happened
[2]
15:11;
36:2
happens [5]
28:11;
35:12; 40:3;
51:4, 11
Happiness
[1] 34:3
hard
[3]
37:15;
48:15; 59:6
HARRIS [1]
2:8
HAUSER [1]
2:5
health
[1]
30:1
heard
[3]
37:20; 59:7,
10
Heart
[1]
38:24
held
[1]
68:6
HELER
[1]
2:5
Hello
[1]
15:23
help
[9]
16:18; 48:9,
10;
60:5, 6,
9, 11; 61:4;
62:23
helps
[1]
62:6

Henley [2]
56:3, 8
Henry
[2]
46:10; 51:23
Here
[1]
23:10
here
[3]
18:7; 35:11;
40:14
Hey
[1]
15:24
hi [1] 55:7
high
[3]
21:9,
11;
49:11
HIPAA
[3]
42:22; 43:1;
47:21
history [9]
15:2, 3, 5, 9,
10,
13;
42:11, 17
Hold [1] 4:9
hold
[2]
17:2; 42:13
holistic [1]
38:18
Holmes [1]
35:3
home
[1]
65:3
Hon [1] 1:6
honestly [1]
43:12
Hospital [3]
31:12,
14;
43:6
hospital [2]
47:22; 49:18
host
[1]
67:13
hosted
[7]
5:16;
6:25;
7:22;
8:13;
10:8,
17;
16:12
hosting [3]
8:11; 10:18;
11:5

hosts
[2]
8:9; 10:9
hour
[1]
44:15
hours
[1]
24:13
houses [1]
67:1
How
[15]
6:1;
13:10;
14:14;
16:22; 28:4;
32:17;
33:15;
37:11; 39:8;
41:24;
53:19;
56:12;
62:13, 16, 22
how
[29]
4:13; 10:14;
13:10,
12,
23;
24:2,
18;
27:16,
17,
21;
28:4; 31:17;
47:10; 48:8;
51:18;
52:18; 53:5,
8;
54:22;
55:15; 60:8;
61:4,
17;
62:16; 64:3,
5; 65:12
Hubbard [5]
33:1, 2, 11,
14; 58:14
husband [1]
63:12
Hwy [1] 2:6
- I idea [4] 6:3,
7;
30:8;
52:20
identificatio
n [1] 4:11
impressions
[2] 13:16

incredibly
[1] 27:11
index
[1]
29:19
Indiana [4]
4:10; 20:25;
21:1, 14
Indianapolis
[1] 2:3
Indicating
[1] 61:24
influence [2]
48:21; 49:3
information
[7]
17:12;
43:9; 47:23;
51:17,
19;
53:13; 62:14
INGHAM [1]
68:2
instead [1]
32:11
instruct [2]
57:4; 58:25
instructed
[1] 56:25
insurance
[1] 35:15
Intake
[7]
26:14; 39:8;
47:17;
52:10;
53:17,
24;
59:13
intake [12]
5:6;
27:12;
28:4; 31:23;
35:19; 40:4;
55:19,
20;
56:10;
58:19; 60:1;
65:10
Integrity [1]
58:12
Inter
[1]
14:17
interactions
[1] 50:13

interested
[2]
21:8;
68:13
Internationa
l [21]
9:12,
17, 23, 24;
10:2,
25;
14:17,
19,
23;
33:21;
34:19;
57:25; 63:7;
64:10,
16;
65:10; 66:4,
11;
67:3, 5,
7
Internet [4]
9:7,
8;
12:20; 26:1
interrogator
y [1] 16:14
interrupt [1]
45:16
interrupting
[2]
34:11;
45:18
Intervention
[1] 55:9
intervention
[2]
53:22;
54:2
intervention
ist
[6]
53:20,
21;
54:1, 6, 13
intervention
ists
[5]
54:8, 10, 12,
20, 22
into
[13]
22:12;
24:10;
26:12;
28:25;
33:25;
37:21; 42:2,
11;
49:1;
50:11;
53:23; 54:5;
55:7

Intoxicated
[1] 48:19
intoxicated
[2]
48:14,
16
Introduction
[3]
33:18;
34:14, 15
involved [1]
59:21
inward
[1]
32:11
ironically [1]
37:19
- J J [1] 4:12
Jackson [1]
31:14
JD [1] 2:10
Jeanie
[4]
11:21;
13:22; 14:2,
8
jewelry [2]
21:6; 22:10
job [6] 8:19;
9:5;
12:17;
14:14;
52:10, 13
jogging [1]
47:5
JOHN
[1]
1:3
JONATHAN
[1] 2:3
Jonathan [2]
44:8; 45:3
judge
[1]
44:9
judgment [3]
38:13;
47:13, 14
July
[1]
39:9
- K -

Kalamazoo
[1] 21:19
Kan
[1]
57:15
Kansas [5]
29:17,
18;
34:23;
57:15; 65:25
Karen
[1]
36:14
Karen's [1]
36:17
KATHLEEN
[1] 2:7
Kealoha [1]
36:16
Keifer
[1]
66:20
Keller
[2]
55:24; 56:6
kept
[2]
29:9; 47:24
kid
[1]
37:20
KIM [1] 2:8
Kind
[1]
57:24
kind
[19]
6:8;
14:25;
15:8,
16;
18:7;
22:7;
23:16;
30:12; 37:3;
40:7;
47:4;
48:15; 57:1;
59:16,
25;
64:7
kinds
[1]
21:21
KLAUS [96]
2:7;
4:22;
6:22;
7:2,
11, 17, 23,
25;
9:18;
11:10,
16,
23;
12:16,
21,
23;
16:2, 5, 13,
19;
17:1, 9,
11, 17, 19,

24;
18:3, 5,
17, 19, 24;
19:3, 5, 10,
14, 19, 21,
23;
20:3,
10,
20;
22:12,
15;
25:1,
22;
26:13,
15,
21,
24;
27:3, 9, 11,
19;
29:7;
31:22;
32:20,
22;
34:5,
9;
36:5,
22;
39:25;
40:17,
20,
22;
41:12;
42:4, 7, 10,
14;
43:17;
44:7, 11, 13,
15, 17, 19,
21,
23;
45:2,
5,
8,
11, 14, 18;
48:23,
25;
49:5,
8;
57:2;
64:1;
65:19,
21;
66:8; 67:18
Klaus
[15]
7:14; 17:10,
21,
25;
19:1, 12, 25;
26:23;
44:14,
16,
18,
25;
45:4; 65:18
knew
[1]
30:16
knowledge
[3]
27:2;
51:22; 62:23
Kristie
[2]
1:13; 68:16
- L -

L [7]
1:13;
33:1, 2, 11,
14;
58:14;
68:16
L-o-g-u-e [1]
56:19
lady
[1]
66:22
Lansing [1]
68:17
Last
[1]
56:19
last
[4]
35:9; 36:15,
17; 53:4
later
[1]
66:1
law [1] 59:3
l a w ye r
[1]
57:12
l a yo u t
[1]
23:22
learn
[2]
61:17; 62:13
least
[1]
16:3
leave
[1]
52:4
Lee
[1]
31:17
Let
[3]
30:13;
42:14; 58:9
let
[5]
16:22;
19:12;
25:22; 31:2;
43:13
liability [1]
41:20
Life
[1]
58:15
life
[2]
32:7; 52:2
Lincoln [1]
1:6
listed
[2]
24:9, 11
Lithium [1]
38:6

LITTLE [109]
2:2, 3;
3:4;
4:9, 13, 16,
24;
6:19,
24;
7:8, 13,
20, 24; 8:6;
9:21;
11:7,
14,
18;
12:1, 17, 22,
25;
15:22,
24;
16:3,
11, 16, 21;
17:2, 6, 10,
18, 21, 25;
18:4, 9, 10,
11,
23;
19:1,
4,
8,
11, 20, 22,
25;
20:4, 9,
12,
22;
22:20; 25:4,
25;
26:6,
19,
22;
27:1, 4, 12,
21;
29:8;
30:11,
15;
32:3, 21, 25;
34:12; 36:6,
24;
40:2,
19, 21, 25;
41:15; 42:5,
8, 13, 18;
43:5,
22;
44:10,
12,
14, 16, 18,
20, 22, 25;
45:1,
4,
6,
10, 12, 15,
20,
21;
48:24; 49:1,
7, 14; 57:3;
62:4;
64:9;
65:1, 16, 25;
66:2,
13;
67:16
Little
[3]
19:15,
19;
45:8

little
[3]
19:12; 34:1;
50:15
live
[2]
24:24; 25:10
LLP [2] 2:2,
8
located [4]
10:11,
13;
20:24; 29:13
location [2]
52:11; 64:15
locked
[1]
29:12
long
[2]
33:15; 39:8
look
[5]
25:20; 26:1;
32:10,
12;
61:22
looked
[5]
18:15,
16;
25:11;
51:24; 52:20
Los [1] 2:9
loved
[3]
54:4,
7;
55:13
Lucas
[2]
53:3, 9
luck
[1]
52:9
- M M-a
[2]
4:13, 14
M-e-s-z-a-ro-s [2] 4:12,
19
machine [1]
35:23
MADDIN [1]
2:5
Mainly
[2]
17:20; 22:2
mainly
[1]
22:10

maintained
[3]
10:15,
17; 29:9
makes
[3]
44:5;
47:8;
54:6
Making [1]
23:1
making [1]
23:1
man
[3]
18:7;
59:6;
61:23
Management
[1] 55:10
manual [3]
65:12, 14, 17
manufacturi
ng [1] 21:7
many
[6]
6:1;
28:4;
32:17;
37:11; 52:18
Margarita [2]
66:22
marked [2]
3:5; 40:20
market
[2]
23:18, 19
marketing
[2] 22:3, 4
Martin
[1]
35:3
Matt
[2]
56:3, 8
may
[2]
23:14; 31:7
M a yb e
[2]
52:22; 65:20
m a yb e
[4]
8:1;
17:17;
18:1; 19:23
McSweeney
[1] 36:18
mean
[37]
9:13;
11:2;
12:17;
13:11,
15;
14:10,
16;
15:20; 20:5;

22:5;
23:6;
24:19,
22;
27:19;
31:25; 33:8;
35:19;
37:12;
38:24; 40:5;
41:13,
22;
42:5;
49:8;
50:1; 61:11;
62:19;
63:15;
64:18,
20;
65:12;
66:13; 67:2,
6, 12, 15
means
[1]
38:18
measured
[1] 13:12
Med
[1]
48:18
med
[2]
46:8, 9
Media
[1]
20:21
media
[1]
8:20
Medical [5]
30:22,
23;
31:10;
34:24, 25
medical [28]
27:13; 29:4,
5;
30:1, 18,
19,
25;
31:1, 3, 8, 9;
35:12,
13;
42:11,
17,
19;
44:2;
45:22;
49:17,
18;
50:8,
10;
51:3, 5, 10,
12, 19, 20
medication
[7] 38:1, 16,
20,
24;
39:1, 3

medications
[4]
38:4, 5;
39:4, 6
meet
[1]
31:5
Meetings [1]
12:9
meetings [2]
12:7, 10
Melinda [1]
35:7
member [1]
65:2
Meridian [1]
2:2
Meszaro [2]
7:15; 20:1
MESZAROS
[4]
1:12;
4:5; 68:6, 9
Meszaros [1]
4:12
MI [1] 2:6
MICHIGAN
[2]
1:1;
68:1
Michigan
[11]
1:3, 4,
15;
4:1;
13:13;
21:18;
31:16; 59:3;
64:25; 68:17
MILLER [2]
2:4; 62:2
Miller
[1]
61:24
Mind
[2]
60:17, 18
mind
[1]
50:1
minerals [2]
59:18, 25
minute
[1]
66:24
minutes [3]
12:10; 13:3;
33:16
misspelled
[1] 4:21

Mm-hmm
[13]
14:21;
15:7;
20:3;
35:8; 36:10;
43:2; 47:18;
51:8; 56:24;
59:5; 60:24;
63:10, 24
mobile
[1]
25:12
money
[2]
36:1, 25
months [1]
55:7
mother [2]
45:13, 14
motion [1]
17:12
motivational
[1] 64:8
move
[1]
27:12
MR
[109]
3:4; 4:9, 13,
16,
24;
6:19,
24;
7:8, 13, 20,
24;
8:6;
9:21;
11:7,
14,
18;
12:1, 17, 22,
25;
15:22,
23,
24;
16:3, 11, 16,
21;
17:2, 6,
10, 18, 21,
25;
18:4, 9,
10, 11, 23;
19:1,
4,
8,
11, 20, 22,
25;
20:4, 9,
12,
22;
22:20; 25:4;
26:6, 19, 22;
27:1, 4, 12,
21;
29:8;
30:11,
15;
32:3, 21, 25;
34:12; 36:6,
24;
40:2,

19, 21, 25;

41:15; 42:5,
8, 13, 18;
43:5,
22;
44:10,
12,
14, 16, 18,
20, 22, 25;
45:1,
4,
6,
10, 12, 15,
20,
21;
48:24; 49:1,
7, 14; 57:3;
62:2,
4;
64:9;
65:1,
16,
25;
66:2,
13;
67:16
Mr
[6]
15:24;
19:15,
19;
32:23; 45:8;
61:24
MS
[95]
4:22;
6:22;
7:2, 11, 17,
23,
25;
9:18; 11:10,
16,
23;
12:16,
21,
23;
16:2, 5,
13,
19;
17:1,
4,
9,
11, 17, 19,
24;
18:3, 5,
17, 19, 24;
19:3, 5, 10,
14, 19, 21,
23;
20:3, 6,
10,
20;
22:12,
15;
25:1,
22;
26:13,
15,
21,
24;
27:3, 9, 11,
19;
29:7;
31:22;
32:20,
22;
34:5,
9;
36:5,
22;
39:25;

40:17,
20,
22;
41:12;
42:4, 7, 10,
14;
43:17;
44:7, 11, 13,
15, 17, 19,
21,
23;
45:2,
5,
8,
11, 14, 18;
48:23,
25;
49:5,
8;
57:2;
64:1;
65:19,
21;
66:8; 67:18
multi-media
[1] 8:21
m ys e l f
[3]
15:4;
28:3;
55:13
- N N [1] 1:11
name
[13]
4:11, 17, 21;
34:13;
36:15,
17,
19;
45:5;
53:4, 15, 19;
54:14; 56:19
named
[1]
66:22
names
[1]
35:9
NARCONON
[2] 1:7
Narconon
[74]
4:25;
5:2, 6, 9;
6:1, 8, 14;
8:7, 18; 9:3,
6,
11,
17,
23,
24;
10:1,
25;
11:2,
22;
14:19,
23;
20:15;
22:20; 23:9;
24:4, 7, 8, 9;
26:2; 27:16;

28:5; 33:11,
18,
21;
34:14,
15;
36:21; 38:1,
17;
39:8,
10,
24;
42:9;
46:5,
15,
17;
49:2,
19;
52:4;
55:1,
3;
57:25;
59:8,
11;
61:11;
62:10,
15,
17;
63:7,
16, 17, 19,
21;
64:9,
16,
24;
65:9,
10;
66:3, 4, 15;
67:7
Narconon's
[2]
7:9;
23:3
Narconon.or
g. [1] 10:10
narcotics [2]
48:22; 49:3
naturally [1]
38:19
necessary
[1] 54:9
needs
[1]
35:10
never
[5]
12:19; 26:8;
39:21; 42:1;
43:22
new
[8]
14:24; 25:7;
27:17,
21;
50:14;
52:11;
58:21; 61:10
NFC
[2]
7:15; 31:23
NFC's
[2]
7:16; 20:2
NI [2]
66:2,
4

Ni [1] 61:9
Niacin
[4]
59:21; 60:5;
61:6; 62:11
Niacin's [3]
61:11,
13;
62:11
Nice
[1]
26:7
none
[1]
39:16
nonprofit [1]
11:25
Nope
[20]
5:15,
19;
11:1; 15:19;
18:24;
23:13;
27:15; 39:2;
46:16;
50:20,
25;
54:21; 56:1,
7, 9;
58:1,
8, 13, 24;
66:21
nope
[1]
58:8
normally [1]
53:25
North
[1]
2:2
Northwester
n [1] 2:6
Notary
[1]
1:14
note
[1]
4:20
Nothing [2]
23:4; 51:1
nothing [3]
23:6; 26:24;
67:17
November
[1] 68:16
Number [2]
7:14; 41:10
number [5]
24:11,
23;
25:8,
15;
26:18

number's [1]
24:9
Numbers [1]
13:16
numbers [3]
13:14,
15;
24:8
nurse
[2]
30:2; 49:16
nurses
[5]
35:1, 2, 6;
51:19, 21
Nursing [1]
35:7
- O O [3]
1:11;
4:4
O-I-J-H-A [1]
66:17
oath [1] 4:6
object
[2]
7:15; 26:13
Objection
[13]
9:18;
27:3, 9, 19;
29:7; 31:22;
36:22;
43:17;
48:23,
25;
57:2;
64:1;
66:8
objection [2]
12:23; 49:5
objections
[1] 7:15
objectively
[1] 32:12
Objectives
[1] 32:10
objectives
[4]
32:8, 9,
13, 14
October [3]
1:15;
4:2;
68:6
offer
[8]
32:2, 4, 5, 6,
7, 8; 57:18

offered [1]
18:20
offering [1]
18:17
offers
[2]
9:15; 58:2
Office
[2]
26:14; 29:14
office
[5]
23:1; 24:10,
15;
35:19;
65:23
often
[1]
13:23
Oh
[8]
15:13; 17:2;
21:17,
19;
30:11,
15;
45:14
oh [2] 16:8;
60:23
Ohio
[3]
54:15,
16;
64:23
OIJA
[1]
63:18
OIJHA
[4]
66:12, 14, 15
oil
[2]
60:22, 23
oils
[1]
59:25
old
[2]
37:19, 22
One
[4]
28:2;
36:3;
55:19; 63:17
one
[27]
4:23; 6:4, 5,
6;
8:4;
11:25;
13:18;
23:14;
24:10,
18;
27:25;
31:11;
33:23;
42:10;
47:17; 49:6,
11;
52:19;

55:13,
16;
57:11;
58:16;
64:25;
65:22,
23,
24; 67:2
opens
[3]
61:6,
16;
62:5
opinion [1]
23:17
opportunity
[1] 18:20
order
[1]
42:15
org [1] 9:12
ours
[1]
67:12
outline [3]
57:6, 7, 8
outward [1]
32:10
overall [1]
59:11
overview [8]
57:8, 10, 13,
17;
58:2,
19,
22;
59:22
own
[3]
10:19; 64:4;
67:15
owned
[1]
64:4
owns
[1]
11:22
- P P [1] 1:11
P-e-c
[1]
53:8
P.O.
[1]
68:17
P67207 [1]
2:7
Page [1] 3:3
page
[3]
6:15,
23;
33:22

pages
[2]
29:23; 68:5
paid
[1]
54:22
paper
[1]
49:12
papers
[2]
42:22; 43:4
paperwork
[7]
40:5, 7,
8;
43:21;
44:4; 49:13;
65:13
part
[4]
52:10;
53:24; 55:8;
62:15
party
[2]
68:11, 12
patient [1]
27:17
pay
[1]
35:15
p a ym e n t [ 2 ]
35:17; 40:3
p a ym e n t s [ 2 ]
23:2; 35:16
PC [1] 2:5
Peanut [1]
62:12
Peckareco
[1] 53:5
Peckarocco
[1] 53:6
people [22]
22:3; 23:18;
28:5; 31:19;
32:10;
37:25;
41:16;
46:14,
22;
47:17; 48:9,
14;
50:13;
52:13; 56:4,
21,
25;
59:13;
60:18,
23;
62:22; 66:2
Pepper [2]
65:6, 7

Per
[2]
25:3, 5
per
[1]
61:14
percent [3]
27:23; 59:7,
10
Perfect [2]
57:12; 67:16
performance
[1] 14:14
person [8]
11:4, 9, 11,
15;
24:24;
53:12; 55:14
Personal [2]
15:3; 58:11
personal [8]
15:2, 4, 5, 8,
10,
13;
42:11, 17
pertain [1]
20:14
ph [1] 11:21
phone [16]
24:15,
16,
19;
25:11,
15,
19;
28:1,
3,
8,
21;
29:4,
23;
32:23;
55:15,
17;
60:2
phones [1]
25:23
p h ys i c a l [ 7 ]
47:1, 4, 6, 9,
10; 50:9, 10
P h ys i c a l l y
[1] 55:5
p h ys i c a l l y
[1] 35:17
pick
[2]
11:12; 52:13
picture [1]
57:18
pitch
[1]
57:1
Plaintiff [1]
2:2

Plaintiffs [2]
1:5, 12
p l a yi n g [ 1 ]
25:23
Please
[1]
44:22
please
[2]
4:18; 30:13
pointed [1]
23:17
policies [1]
65:15
policy
[1]
65:17
polishing [1]
21:6
post
[4]
12:10; 15:5,
16, 18
posted
[1]
12:25
poster
[1]
33:10
pot
[1]
37:22
potential [3]
31:2;
40:9;
47:16
pre
[5]
61:15,
18,
19, 20; 62:9
predecessor
[1] 9:1
prescribed
[2]
28:24;
38:15
prescribes
[1] 47:6
prescription
[1] 28:23
presence [1]
6:8
present [2]
2:11; 28:16
presented
[2]
23:13;
35:14
pretty
[3]
10:3; 14:10;
40:14

previous [1]
12:18
prison
[1]
37:15
private [1]
10:19
Probably [1]
6:10
probably [5]
33:21,
22;
53:14;
65:23; 67:2
problem [3]
28:11;
38:25; 55:14
Procedures
[1] 65:15
procedures
[5]
5:6;
27:13;
31:24;
65:10, 17
Proceedings
[2]
19:18;
34:8
production
[1] 13:12
productive
[1] 64:7
products [1]
22:18
professional
[1] 19:24
Program [5]
28:13,
20;
29:8,
22;
57:8
program [29]
29:21;
31:21; 32:7;
33:13;
35:14;
37:24;
38:18;
46:23,
25;
47:3;
52:4;
57:1, 4, 6, 7,
8, 9, 13, 17;
58:4, 19, 22;
60:13,
19;

62:13,
15,
17, 18, 22
programmin
g [1] 25:16
programs [1]
31:21
pronounces
[1] 53:8
proper
[1]
17:7
property [4]
43:6,
7;
47:22; 51:9
protecting
[1] 42:12
protective
[1] 42:15
p s yc h i a t r i c
[3]
37:25;
38:15; 39:1
p s yc h i c [ 1 ]
39:3
p s yc h o t r o p i
c [1] 39:7
Public
[1]
1:14
public
[1]
8:20
publicly [2]
13:3, 7
- Q qualified [4]
37:24;
46:23; 47:3,
8
question
[13] 10:1, 4;
12:24;
14:10;
15:21;
20:18; 28:9;
30:12,
14;
38:11;
48:15; 49:6;
65:19
questionnair
e [3]
30:4,
7, 16

Questions
[1] 17:19
questions
[26]
6:21;
7:3,
19;
11:11,
15,
17;
16:7, 9,
13, 15, 19;
17:3, 5, 6;
18:6, 8, 11;
20:7;
30:1;
32:2; 42:21;
44:17;
45:16;
59:14;
62:22, 24
quicker [1]
29:18
quit
[2]
18:6; 45:19
- R R [2] 4:4
R-e-b-e-c-c
[1] 10:21
R-o-u-s-s-e-l
[2]
56:15,
16
R-u
[1]
56:15
R - y- a - n [ 1 ]
10:23
rape
[1]
37:7
rate
[3]
58:23; 59:8,
10
rates
[3]
13:18;
15:18; 59:2
Ray [1] 35:9
re-sign [1]
49:13
read
[4]
11:12;
48:12;
58:10; 62:25
really
[5]
22:8; 23:19;

26:4;
60:1;
67:12
reason
[2]
36:23; 50:2
Rebecca [5]
8:16; 10:18,
21;
11:8;
66:25
recall
[1]
43:12
receive [11]
41:17;
42:21,
25;
47:20;
49:21; 51:6,
7;
62:16;
64:12; 65:9
received [1]
46:19
recently [1]
10:16
recommendi
ng [1] 54:20
reconnect
[1] 34:10
record [17]
4:17;
6:19;
7:14,
20;
11:8;
18:4;
19:17;
20:11;
25:22,
25;
34:5,
7;
40:22;
45:10,
13;
57:16; 68:5
records [1]
19:8
refer
[1]
40:15
referrals [4]
54:10;
64:13, 17, 18
referring [1]
58:3
reflect
[2]
25:22; 26:1
refrain
[1]
44:22

registration
[2]
9:7;
22:25
regular [1]
14:12
regularly [1]
66:2
regulations
[1] 13:13
reha
[1]
60:9
Rehab
[7]
39:13,
20;
46:14,
17,
20, 22, 24
rehab
[17]
28:25;
39:21;
41:22,
25;
42:1,
2,
3,
19;
43:15,
16, 18, 23;
45:22; 49:1;
51:4,
5;
53:23
rehabilitatio
n [2]
60:9,
11
rehabs
[2]
43:20, 25
reimbursem
ent
[1]
54:19
related [1]
16:7
relates [1]
7:6
relations [1]
8:20
relationship
[1] 63:15
relative [2]
68:10, 11
r e l a ye d [ 1 ]
55:13
Release [1]
43:9
release [4]
28:24;

47:23;
51:17, 19
relevant [2]
18:6; 42:16
remember
[4]
36:4;
54:14,
18;
60:1
report
[4]
11:18;
13:20, 23, 25
REPORTER
[7]
4:10;
19:9;
30:9,
12;
42:23;
43:2; 64:21
Reporter [1]
1:14
require [2]
47:1, 4
required [3]
12:5, 13, 16
requires [1]
59:3
Research [1]
60:7
research [2]
60:4, 25
residuals [1]
60:20
response [1]
4:20
responsibili
ties
[2]
8:19; 9:5
responsibili
ty [1] 54:3
responsible
[2] 7:8, 18
rest
[2]
42:21; 43:12
resume [2]
19:18; 34:8
rid [2] 61:4;
62:13
Right
[3]
7:17; 28:15;
62:3
right
[24]
4:22, 23, 24;

18:13,
14;
19:8,
22;
20:12;
24:23; 26:6;
27:12;
31:19; 33:7;
34:23; 40:2,
14;
41:3;
50:1,
3;
57:24;
58:22;
59:23; 62:1;
67:16
rings
[2]
22:17; 24:10
road
[1]
18:13
Robert
[1]
66:20
Rogers [1]
66:18
roll
[1]
24:18
rolls
[1]
24:15
Ron
[5]
33:1, 2, 11,
14; 58:14
ROTH
[1]
2:5
Roussel [1]
56:15
route
[2]
46:14; 49:17
routing [2]
24:17, 19
rules
[1]
11:12
run
[1]
35:22
rundown [2]
28:21; 29:25
Running [1]
47:5
rustle
[1]
65:24
R ya n
[6]
8:16,
17;
10:21,
23;
11:8; 66:25

- S S [2] 1:6, 11
S-t-e-p-h-en [1] 56:13
SAEED
[1]
2:2
Same
[2]
49:5; 58:16
same
[5]
24:14;
25:15; 39:5;
41:4; 58:16
Sarah
[1]
1:6
sat
[1]
12:18
sauna
[7]
32:7; 59:14,
17;
60:19;
62:13; 63:2,
3
SCHEPER [1]
2:8
school
[2]
21:9, 11
Scott
[1]
4:22
se [1] 61:14
search
[5]
43:6,
7;
47:22; 50:9;
51:9
second [4]
4:9;
34:6;
58:9; 63:4
security [1]
50:8
seizure [1]
38:20
seminar [3]
63:22, 23, 25
send
[2]
46:22; 59:22
sense
[3]
44:4,
5;
49:15

sent
[3]
10:3,
6;
46:7
separate [1]
54:25
series
[2]
32:8; 59:18
server
[1]
10:11
servers [1]
10:19
services [5]
41:17;
42:22,
25;
49:21; 51:7
set
[2]
24:17; 26:9
seven
[1]
29:23
She [1] 67:3
she
[7]
8:22,
24;
10:25; 11:4;
14:2;
36:8;
67:2
Shorthand
[1] 1:13
should
[1]
31:21
show
[1]
33:23
showed [2]
43:25; 44:4
shown
[1]
43:20
Shows
[1]
57:18
sic [5] 20:1;
21:4;
43:1;
58:14; 59:25
side
[5]
44:21,
24;
45:2, 9, 19
Sign
[1]
20:21
sign
[16]
35:24;
41:16,
23;
48:17,
22;
49:4, 11, 19,

21,
22;
50:5;
51:5,
7, 17, 18;
52:2
signed
[1]
51:12
silver
[1]
21:6
Since
[1]
39:9
since
[3]
5:21; 15:24;
37:18
site
[62]
5:2,
8,
10,
14, 22, 24;
6:25; 7:1, 3,
4, 9, 16, 18;
8:9;
9:10;
10:5,
15;
11:5, 9, 17;
12:3, 5, 8, 9,
11; 13:1, 6;
14:15,
16,
24; 15:6, 9;
16:4, 7, 10,
21,
23;
17:1,
14;
18:12,
15;
20:2,
5;
23:13,
22;
24:9;
25:7,
12;
26:2;
27:2, 5, 7;
33:21;
34:19;
50:17;
66:24; 67:1,
8, 10, 12, 13
sites
[8]
6:1;
13:16,
17;
21:25;
22:2,
5;
23:3; 24:4
sitting
[1]
19:16
situation [1]
64:5
skills
[1]
32:7

skinny
[1]
61:22
smoking [1]
37:22
snark
[2]
44:8, 9
snide
[1]
45:19
sober
[1]
64:6
sold
[1]
22:19
soluble [2]
60:22, 23
somebody
[14]
33:9;
36:20,
24;
38:15;
39:17;
47:12;
48:16,
21;
49:1,
19;
50:4; 51:25;
52:3, 10
Someone [2]
15:17; 49:15
someone
[12]
25:10,
19;
35:10;
36:25;
38:15; 47:1;
51:3; 53:23;
54:3;
57:3;
60:8; 65:2
someone's
[1] 47:8
sometimes
[1] 49:12
somewhere
[2]
29:9;
65:24
Sons
[2]
21:4, 24
Sophia [1]
35:7
sorry
[10]
7:25; 12:16;
17:24; 30:9,
11;
32:24;

34:9; 39:19;
42:23; 45:8
South
[1]
21:2
Southfield
[1] 2:6
speak
[3]
4:25; 25:10;
31:2
speaker [1]
32:22
Speaking [1]
32:23
speaking [2]
26:25; 31:23
specific [2]
36:19; 38:12
specifics [1]
22:13
speculate
[2]
11:23;
41:12
speech [1]
64:8
spell
[5]
4:13,
17;
31:17; 53:5;
56:12
spring
[6]
5:3;
6:15;
7:9,
16;
20:2, 5
St [2] 2:2, 9
stages
[1]
53:22
standard [9]
13:14,
15;
41:19,
22;
42:6; 45:24,
25; 46:1, 2
standardize
[1] 9:16
standardize
d [2]
9:14;
15:1
start
[4]
5:8;
9:3;
32:11; 40:12
started [2]
8:11; 37:20

STATE
[2]
1:1; 68:1
State
[2]
13:13; 59:3
state
[4]
4:17;
7:13,
20; 58:22
statement
[1] 43:15
states
[1]
33:13
statistics [2]
13:20; 15:18
Stephen [2]
56:11; 62:21
Stop
[1]
44:8
stop
[5]
32:11; 34:6;
44:25; 45:19
store
[3]
51:9;
67:8,
11
stored
[3]
30:21,
22;
47:25
stores
[3]
22:10; 66:25
story
[1]
29:3
Street
[2]
29:16; 30:24
streets [1]
29:2
student [3]
27:20,
21;
32:16
students [2]
52:11; 58:4
studies [2]
60:10, 25
study
[1]
21:20
stuff
[9]
11:9; 21:21;
29:18;
51:10; 60:3;
61:9,
15;
62:6

Subject [1]
7:14
subject [1]
16:3
subjectively
[1] 32:12
success [4]
15:18;
58:23; 59:2,
8
suggest [2]
54:8; 60:10
suicidal [1]
41:19
suicide [5]
41:17,
18;
42:22;
47:20; 51:6
Suite
[3]
2:2, 6, 9
supervisor
[2]
28:7;
56:23
supervisory
[1] 56:21
support [1]
61:1
supports [1]
60:5
Sure
[3]
14:6; 15:15;
41:2
sure
[10]
5:13,
23;
7:4, 5;
9:2,
10,
25;
23:1; 51:25
sweats [1]
62:7
sworn
[1]
68:9
- T T [2]
1:11;
25:9
T-o-d-d [2]
4:12, 19
T-r-o-u-t-n-e
-r [1] 56:13

TABLE
[1]
3:1
taken
[2]
1:12; 59:23
taking
[9]
19:1,
6;
28:22; 31:7;
37:20;
38:16,
21;
68:8
talk
[4]
22:15;
24:24;
42:17; 45:13
talked
[2]
64:3, 4
talking [5]
16:6; 23:14;
24:25; 25:2;
61:25
target
[2]
23:18, 19
teachings
[1] 32:25
telephone
[3]
2:9;
24:9; 27:23
tell
[13]
5:8;
16:24;
27:5;
30:5;
32:3;
37:3;
40:10;
48:15; 52:9;
56:25;
58:10; 65:7;
68:9
telling
[1]
44:23
ten
[1]
33:16
ten-minute
[1] 34:12
terms
[1]
22:4
territorial
[1] 64:23
testified [1]
4:7

testify
[4]
5:1, 5; 7:16;
20:1
t e s t i f yi n g
[1] 42:5
testimony
[2]
42:16;
68:6
text
[1]
57:19
Thank
[1]
67:16
theirs
[1]
67:15
T h e y' d
[3]
27:23; 48:1;
49:21
t h e y' d
[2]
13:6; 48:18
t h e y' v e [ 1 ]
43:20
Thinking [1]
57:3
thinking [1]
32:11
Third
[1]
65:8
thought [1]
13:6
Three
[1]
28:6
three
[6]
37:19,
21;
49:5,
9;
57:5; 62:20
Thursday [3]
1:15;
4:2;
14:1
Tim
[2]
55:23; 56:6
time
[15]
8:5;
11:6;
17:13; 19:2,
5; 20:6, 11;
26:19;
28:16; 36:3,
20;
37:15;
43:16;
52:19; 63:5

times
[5]
22:17;
52:18,
21;
55:6; 63:20
title
[2]
58:10, 17
today
[1]
4:25
TODD
[4]
1:12;
4:5;
68:6, 9
Todd
[4]
4:11,
19;
7:15; 20:1
Todd's
[1]
15:13
told
[3]
25:18;
46:10; 62:20
tone
[1]
17:22
Tony
[2]
56:19; 62:21
too
[5]
37:18;
38:11;
42:23;
48:19; 59:6
took
[3]
57:24;
58:18, 19
top
[1]
18:24
topic
[5]
16:8;
18:8,
21;
19:6;
20:8
topics
[1]
5:1
touch
[1]
57:12
toxins
[5]
59:19;
60:20,
22;
61:5; 62:14
track
[1]
59:4
training [4]
27:14;

50:18;
62:17; 65:9
trainings [1]
63:6
transcript
[1] 68:4
transfer [1]
8:15
Transport
[1] 52:24
transport [3]
52:11,
25;
53:10
transportati
on [2] 43:6;
47:22
T r a yh a n [ 1 ]
11:21
Treasury [5]
29:14;
35:22;
36:12,
13;
50:12
TREATMENT
[1] 1:8
treatment
[6]
47:20;
54:5;
61:2,
5, 13, 14
tried
[1]
44:6
Troutner [2]
56:11, 13
true
[2]
41:10; 68:5
truth
[1]
68:9
try [1] 34:19
t r yi n g
[5]
14:18,
19;
34:10;
43:11; 45:25
t u r k e ys [ 1 ]
15:17
turn
[3]
36:12,
13;
50:12
turned
[4]
36:24,
25;
37:4; 50:8

TV [1] 33:25
twice
[1]
52:21
Twitter [3]
6:11,
13;
7:7
two [2] 5:1;
51:14
TYLER
[1]
1:3
T yl e r
[2]
36:7; 47:25
T yl e r ' s
[1]
26:17
t yp e
[3]
8:21;
38:3,
5
t yp e d
[1]
4:23
t yp e s
[1]
31:7
t yp i c a l
[1]
43:15
T yp i c a l l y [ 1 ]
27:21
t yp i c a l l y [ 3 ]
52:23; 55:15
- U Uh-huh [1]
35:4
Um [1] 55:4
uniform [2]
14:18, 19
University
[2] 21:14
university
[2]
21:20,
22
Ups
[1]
58:14
upstairs [2]
45:3, 9
URL
[6]
5:12,
24;
6:24;
7:4,
21; 16:11
URLs
[1]
8:7

us [6]
5:9;
10:4,
15;
27:5;
31:2;
67:13
use
[8]
38:8,
13;
54:6, 8, 13;
58:4; 62:10;
64:4
using
[2]
26:1; 37:18
usually [2]
27:23; 32:1

violent [1]
37:14
visit
[2]
66:3, 5
Vitamin [1]
59:21
vitamin [1]
62:5
vitamins [5]
59:18,
20;
60:3,
9;
61:8
volume [1]
38:3

- V - W v [1] 1:6
vague
[1]
27:11
Valerie [3]
36:14; 48:7;
53:14
Valerie's [2]
36:15; 41:10
valid
[1]
61:1
Values
[1]
58:11
vascular [1]
62:7
Very
[1]
50:15
very
[2]
44:9; 67:17
Via [1] 2:9
via
[1]
27:23
victim
[1]
18:7
Video
[1]
34:12
video
[7]
33:9, 12, 13,
15, 17, 19;
34:12
videos
[1]
34:2
Villanueva
[1] 2:11

W [1] 2:9
Wait
[1]
18:19
waiver
[5]
41:17,
18;
42:22;
47:20; 51:6
waivers [1]
47:21
walk
[2]
33:9; 47:10
walking [1]
19:16
want
[15]
7:22;
16:9;
17:7; 18:12;
24:23;
26:16,
17,
25;
28:11;
31:20;
33:23;
42:23; 46:1;
52:1; 54:4
wanted [9]
7:25; 30:15;
33:19;
34:15,
20;
40:15;
47:19; 48:3;
57:9
wants
[3]
52:3,
4;
65:2

wasn't
[3]
10:4;
11:8;
36:8
waste
[2]
17:13; 20:11
watch
[2]
33:12; 34:1
watches [1]
33:9
Way [1] 34:3
way
[2]
10:4; 23:22
We [9] 25:5;
27:12;
28:13,
20;
29:22; 32:7;
47:1; 50:17;
67:15
we
[24]
11:12;
12:19;
14:18; 18:1,
21;
19:19,
23;
25:19;
32:2, 5, 7;
34:5,
22;
38:18;
44:13; 51:9,
10;
54:12,
13;
57:18;
62:10; 64:16
we've
[4]
8:5;
11:10;
27:1; 49:12
web
[71]
5:2, 8, 9, 10,
14, 22, 24;
6:1, 8, 25;
7:1, 3, 4, 9,
16, 18; 8:9;
9:10;
10:4,
14;
11:4, 9,
17;
12:3, 5,
8, 9, 11, 25;
13:6, 16, 17;
14:15,
16,
24; 15:5, 9;
16:4,
6,
9,
21,
23;
17:1,
14;

18:12,
15;
20:2,
5;
21:25; 22:2,
4;
23:3, 13,
22; 24:4, 9;
25:7,
12;
26:2;
27:2,
4, 7; 33:21;
34:19;
66:24; 67:1,
8, 10, 12, 13
week
[1]
13:24
weeks
[1]
51:14
Well
[15]
7:2;
13:6;
20:16,
18;
26:17; 40:5,
13;
41:13;
42:5,
18;
51:24; 54:1;
61:6;
67:7,
10
well
[4]
31:20; 40:9;
60:8; 62:18
went
[6]
21:14;
43:16,
18;
45:22;
51:24; 52:19
weren't [1]
46:23
West
[2]
29:16; 30:24
Western [1]
21:14
What's [17]
21:5; 22:21;
30:7,
14;
33:12,
17;
36:15;
41:18;
46:24; 53:4,
21; 57:1, 7;
60:14;
61:19;
65:14; 66:14

what's
[8]
15:10,
11;
21:11; 22:3;
26:22;
36:17; 63:15
where's [1]
31:11
wherever [1]
65:8
Who's
[4]
12:1;
14:7;
52:25; 63:13
who's
[5]
7:18;
8:17;
10:11;
11:20; 47:15
whose
[2]
35:24; 47:14
wi [1] 63:12
wife
[1]
63:14
Wiggins [4]
63:9, 11, 15;
66:7
will
[4]
16:13;
25:25;
27:12; 57:12
WILLIAM [1]
2:10
willing
[1]
54:3
Without [2]
22:12; 36:19
WITNESS
[34]
4:8;
8:3;
9:20;
11:25;
17:16,
20;
18:15,
18;
20:21;
22:14,
16;
25:2;
26:4,
14;
27:10;
31:25;
32:24; 40:1,
18,
23;
41:13;
42:20,
25;
43:3,
19;

49:10;
61:25; 62:3;
64:3,
22;
65:20,
22;
66:10; 67:19
witness [4]
1:12;
20:7;
45:15, 16
WJ [2] 21:4,
24
women
[1]
22:16
word
[1]
29:19
work
[19]
8:17; 11:18;
13:10; 14:5,
12;
16:17;
20:12,
14,
16;
21:3,
22;
23:8,
12,
22;
35:1;
44:6;
46:8; 53:17;
55:1
workbook
[1] 32:15
workbooks
[1] 32:17
worked [12]
20:18; 22:9;
39:10,
21;
42:1; 43:19,
22;
44:2;
54:15;
55:23; 61:10
working [2]
9:3; 47:15
workout [4]
61:15,
18,
19; 62:9
works [13]
10:25; 33:2,
3, 8, 11, 14;
55:15; 56:6;
63:17; 64:9;
66:11, 12, 13
world
[1]
54:17

Write
[1]
9:10
write
[7]
14:22,
25;
15:9; 23:21;
24:2,
20;
54:17
written [3]
32:14, 15, 21
wrong
[2]
26:22, 24
wrote
[6]
7:14,
17;
23:20,
23;
24:1; 57:21
- Y ya [ 4 ] 5 2 : 3 ;
59:7;
65:5,
9
ye a r s
[4]
15:17;
37:19,
21;
38:9
Yep
[14]
5:7;
8:10;
10:8;
28:8,
19;
29:10;
37:2;
41:8;
46:12;
53:16;
56:17,
22;
57:14, 20
You'd
[1]
28:20
yo u ' d
[1]
64:24
You've
[1]
16:7
yo u ' v e
[9]
35:14; 37:7,
15, 17, 18;
38:8,
24;
43:22; 46:4
yo u n g e r [ 1 ]
23:18
yo u r s
[1]
46:24

Yvonne
66:18

[1]