IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF OKLAHOMA
1. NATIONAL ASSOCIATION OF ) FORENSIC COUNSELORS, INC., et al. ) )
Plaintiffs,
) ) v. ) Case No. 14-cv-00187-RAW ) 1. NARCONON INTERNATIONAL, et al. ) )
Defendants.
)
PLAINTIFFS NATIONAL ASSOCIATION OF FORENSIC COUNSELORS, INC. AND AMERICAN ACADEMY CERTIFIED FORENSIC COUNSELORS d/b/a AMERICAN COLLEGE OF CERITIFIED FORENSIC COUNSELORS’
PRELIMINARY WITNESS LIST
COME NOW
National Association of Forensic Counselors, Inc. (“NAFC”) and American Academy of Certified Forensic Counselors d/b/a American College of Certified Forensic Counselors (“AACFC”), the Plaintiffs in the above-entitled action, by and through their attorneys, David R. Keesling and Laurel A. Carbone, of the law firm, K
EESLING
L
AW
G
ROUP
, PLLC, and pursuant to the Court’s Scheduling Order [Dkt. 651], submit their Preliminary Witness List.
W
ITNESSES
No.
Witness
Area of Testimony
1. Karla Taylor c/o David R. Keesling Laurel A. Carbone K
EESLING
L
AW
G
ROUP
, PLLC 11114 South Yale Avenue, Suite B Tulsa, Oklahoma 74137 (918) 924-5101 NAFC’s and AACFC’s CEO and President: Ms. Taylor is expected to testify consistent with her deposition testimony about her knowledge of the facts and circumstances pertaining to the claims in this case. 2. Jonathan Deisler c/o AACFC’s Treasurer:
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David R. Keesling Laurel A. Carbone K
EESLING
L
AW
G
ROUP
, PLLC 11114 South Yale Avenue, Suite B Tulsa, Oklahoma 74137 (918) 924-5101 Mr. Deisler has been an employee and officer of both NAFC and AACFC and is expected to testify about
the facts and circumstances pertinent to Plaintiffs’ claims, as well as information regarding Plaintiffs’ damages. 3. Lucas Catton 3895 Greensward View NW
Keenesaw, GA 30144 Witness: Mr. Catton worked for Narconon of Oklahoma, Inc. in supervisory and decision-making positions. He
filed a complaint with NAFC about Narconon activities and employees. He is expected to testify regarding his knowledge of the facts and circumstances pertaining to the claims in this case. 4. Eric Tenorio 607-793-8714 607-241-5776 607-229-9866 ejtbmf@hotmail.com 10orio.eric@gmail.com Witness: Mr. Tenorio was an employee of Narconon of Oklahoma, Inc. and advertised himself as a CCDC. He filed a complaint with NAFC about Narconon activities and employees. He is expected to testify regarding his knowledge of the facts and circumstances pertaining to the claims in this case. 5. Clark Carr Narconon International
7065 Hollywood Blvd. Los Angeles, CA 90028 Witness: Mr. Carr is the President of Narconon International, has been an officer of Narconon of Oklahoma, Inc. for many years, and advertised that he held a CCDC. He is expected to testify regarding his knowledge of the Narconon decision-making structure and the facts and circumstances pertaining to the claims in this case. 6. Tim Lomas ABLE 7065 Hollywood Blvd. Los Angeles, CA 90028 Witness: My. Lomas is an employee of ABLE. He is expected to testify regarding his knowledge of the Narconon decision-making structure and the facts and circumstances pertaining to the claims in this case. 7. Jason Burdge c/o Steidley & Neal, PLLC
CityPlex Towers, 53
rd
Floor 2448 East 81
st
Street Tulsa, Oklahoma 74137 Witness: Mr. Burdge has been an employee of Narconon of Oklahoma, Inc. and submitted a false application to NAFC. He is expected to testify regarding his knowledge of the facts and circumstances pertaining to the claims in this case. 8. Robert Newman c/o Steidley & Neal, PLLC
CityPlex Towers, 53
rd
Floor 2448 East 81
st
Street Tulsa, Oklahoma 74137 Witness: Mr. Newman has been an employee of Narconon entities and is expected to testify regarding his knowledge of the facts and circumstances pertaining to the claims in this case.
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9. James McLaughlin c/o Steidley & Neal, PLLC
CityPlex Towers, 53
rd
Floor 2448 East 81
st
Street Tulsa, Oklahoma 74137 Witness: Mr. McLaughlin has been an employee of Narconon of Oklahoma, Inc. and advertised that he held several
NAFC credentials. He is expected to testify regarding his knowledge of the facts and circumstances pertaining to the claims in this case. 10. Derry Hallmark c/o Riggs, Abney, Neal, Turpen, Orbison Lewis P.C.
502 West 6
th
Street Tulsa, Oklahoma 74119 Witness: Mr. Hallmark has been an employee of Narconon of Oklahoma, Inc., including holding the position of the
Director of Expansion, a member of the Executive Council, and advertised himself as holding a CCDC. He is expected to testify regarding his knowledge of the facts and circumstances ertainin to the claims in this case. 11. Gary Smith c/o Riggs, Abney, Neal, Turpen, Orbison Lewis P.C.
502 West 6
th
Street Tulsa, Oklahoma 74119 Witness: Gary Smith is the President of Narconon of Oklahoma, Inc. and advertised himself as a CCDC.
He is expected to testify regarding his knowledge of the facts and circumstances pertaining to the claims in this case. 12. Janet Watkins c/o Riggs, Abney, Neal, Turpen, Orbison Lewis P.C.
502 West 6
th
Street Tulsa, Oklahoma 74119 Witness: Ms. Watkins has been an employee of Narconon of Oklahoma, Inc., has served as a member of Narconon of Oklahoma, Inc.’s Executive Council, and advertised herself as CCDC. She is expected to testify regarding her knowledge of the facts and circumstances pertaining to the claims in this case.
13.
Tom Widmann c/o Riggs, Abney, Neal, Turpen, Orbison Lewis P.C.
502 West 6
th
Street Tulsa, Oklahoma 74119 Witness: Mr. Widmann has been an employee of Narconon of Oklahoma, Inc. and advertised himself as a CCDC.
He has also owned and/or operated a number of websites advertising Narconon. He is expected to testify regarding his knowledge of the facts and circumstances pertaining to the claims in this case.
14.
Vicki Smith c/o Riggs, Abney, Neal, Turpen, Orbison Lewis P.C.
502 West 6
th
Street Tulsa, Oklahoma 74119 Witness: Ms. Smith has been an employee of Narconon of Oklahoma, Inc., has advertised herself as a MAC,
and has served as a member of Narconon of Oklahoma, Inc.’ Executive Council. She is expected to testify regarding her knowledge of the facts and circumstances pertaining to the claims in this case.
15.
Michael Otto c/o Riggs, Abney, Neal, Turpen, Orbison Lewis P.C.
502 West 6
th
Street Tulsa, Oklahoma 74119 Witness: Mr. Otto has been an employee of Narconon of Oklahoma, Inc. and advertised that he was a CCDC.
He is expected to testify regarding his regarding his knowledge of the facts and circumstances pertaining to the claims in this case.
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