Plaintiff SARAH LOCATELLIIn Pro Per (530) 274-8198 (phone/fax)
SUPERIOR COURT FOR THE STATE OF CALIFORNIACOUNTY OF NEVADA
SARAH LOCATELLI, an individual, Plaintiff, vs. NARCONON SOUTHERN CALIFORNIA, a California corporation, NARCONON JOSHUA HILLS, a California corporation, and DOES 1 through 20 inclusive,Defendants.  ______________________________________ )))))))))))))))))))))Case No. L75070UNLIMITED CIVIL CASEDECLARATION OF SARAH LOCATELLIIN SUPPORT OF THE OPPOSITION TO MOTION TO CHANGE VENUE Date: September 25, 2009 Time: 10:00 a.m. Date action filed: June 29, 2009 Trial Date: None yet
 
I, Sarah Vogel, declare:I stand by my Complaint and ask that the Court consider it while reading this DECLARATION  presented to the Court as an incorporated document in support of the OPPOSITION TO MOTION TO CHANGE VENUE.I never signed a written contract with any Narconon organization. The extent of the contract between the parties in this case is the telemarketing calls to and from and between fake referral help line phone number acting as a Narconon representative (Desiree Romero) and an employee of Narconon (Micki Allen) who took my credit card information when I agreed to purchase "Joshua Hills" rehabilitation services and later the 2 post dated checks made out to Narconon Southern California which I faxed copy of and then sent originals in the mail based upon what I was told to do. I never received a receipt
 
for the deposit monies I paid by credit card; I was never informed that my deposit was going to any other entity besides the fictitious " Joshua Hills" which I was told by the rep was the California equivalent of "St Jude's of Nebraska". I was never informed that it was a Narconon entity until after my deposit was taken and cleared via credit card transaction done over the telephone as I was told who to make the remaining post dated payments out to. I was promised many things over the phone by  Narconon representatives and employees but I was never informed by the parties that the parties involved were in a collusion type of activity and that they were in violation of federal and state consumer and telemarketing law.I was never informed of any refund policy before or after my money was taken by DEFENDENTS. I was only informed after Daniel left the program and I called to get a refund of money back. To my knowledge, DEFENDENTS did not tape record the financial transaction nor provide financial receipts. This is in violation of When I asked for a receipt, my request was ignored.I was pregnant with a toddler at home during the transaction and during the whole of the pregnancy I attempted to get a refund to no avail, causing financial, emotional and physical distress. I suffered this in Nevada County where I live as I tried to unravel and rectify the situation by phone, email and fax.Defendants, NARCONON SOUTHERN CALIFORNIA (NNSC) and NARCONON JOSHUA HILLS (NN JH) are separate corporate entities with operations in various locations and in the state of California. Additionally, NARCONON SH has operations in Nevada and Colorado.  NNSC solicits customers via telephone, internet, via referral websites and 3rd party sellers throughout the United States and the State of California, including customers in Grass Valley, California, County of Nevada on their official website
http://www.usnodrugs.com/California/Grass_Valley/17
 , the site which is noted on their 990 tax returns (
www.usnodrugs.com.
) As noted in the Complaint, the true names or capacities, whether individual, corporate, associate, or otherwise, of Defendants named in this action as DOES 1 through 20, are unknown as of yet to Plaintiff, who therefore sues these Defendants  by such fictitious names. Plaintiff will amend this complaint to show the true names and capacities of the fictitiously named defendants when they have been ascertained.
 
It is my belief and understanding, that DESIREE ROMERO, formerly known as DESIREE DANNER, has worked and continues to work for various NARCONON entities across the United States beginning in 2001, after having personally completed the Narconon Program herself in Oklahoma. http://abcnews.go.com/print?id=127115Desiree Romero is a resident of the State of Texas and operates multiple "rehab referral" and "rehab hotline" websites. It is my belief that Desiree's priority placements and referrals are on behalf of the  Narconon program, as evidenced by her high earnings records from the various Narconon 990 Tax forms of different Narconons from 2001-2006 Desiree Danner 2001 Narconon Arrowhead 990 Tax return highly compensatedhttp://www.xenu-directory.net/documents/corporate/person.php?person_id=247Desiree Romero 2003-2006 mulitple locations 99o Returns highly compensated http://www.xenu-directory.net/documents/corporate/person.php?person_id=19and claims made about her in the New Mexico lawsuit: Luthy v Narconon Stone Hawk et al claiming fraud and deceptive trade practices of a similar nature. Point 12:http://www.cs.cmu.edu/~dst/Stop-Narconon/StoneHawk/Luthy/complaint.pdf Desiree Romero promotes herself by name and photograph on some of her referral sites http://www.drugrehabs.net/index.php/Contact-Us/and is a Facebook friend to NNSC's Registered Agent Arthur Bruce Haddrill , http://www.facebook.com/people/Arthur-Bruce-Haddrill/1449810547who is registered with the Michigan Bar Association as being in house counsel to Narconon Nevada, showing the address of the property owned by NNSC in Caliente, Lincoln County, NV. Arthur B. Haddrill - P30662 (active and in good standing) General Counsel NarcononPO Box 716Caliente, NV 89008
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