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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF OKLAHOMA 1. NATIONAL ASSOCIATION OF ) FORENSIC COUNSELORS, INC., a Nevada ) Non-Profit Corporation, and ) 2. AMERICAN ACADEMY OF CERTIFIED ) FORENSIC COUNSELORS, INC., d/b/a ) AMERICAN COLLEGE OF CERTIFIED ) FORENSIC COUNSELORS, a Nevada For- ) Profit Corporation, ) ) Plaintiffs, ) ) v. ) Case No. 14-CV-00187-RAW ) 1. NARCONON INTERNATIONAL, a ) California Non-Profit Corporation, ) 2. NARCONON OF OKLAHOMA, INC., ) d/b/a PITA GROUP, d/b/a ) ADVANCE DETOX, d/b/a ARROWHEAD ) MEDICAL DETOX, d/b/a NARCONON ) CHILOCCO NEW LIFE CENTER, an ) Oklahoma Non-Profit Corporation, et al., ) ) Defendants. )

DEFENDANTS’ WITNESS LIST

COME NOW the Defendants Narconon of Oklahoma, Inc., Gary Smith, Derry Hallmark, Janet Watkins, Tom Widmann, Vickie Smith, Michael Otto, Michael J. Gosselin, Kathy Gosselin, Michael George, Michael St. Amand, Rebecca Pool, Dena Goad, Kent McGregor, Pita Group, Inc., Narconon International, Association for Better Living and Education, Jason Burdge, James McLaughlin, and Robert Newman, and for their Witness List, offer the following: 1

6:14-cv-00187-RAW Document 686 Filed in ED/OK on 06/01/16 Page 1 of 21

- Preliminary Statement -

The fact that Defendants have listed or will list an individual in their Witness List and/or in any Amended or Supplemental Witness List is not an acknowledgment or admission by Defendants that any part or all of the individual’s testimony is admissible into evidence at trial or in any pretrial proceeding. Defendants reserve their right to object at trial or in any pretrial proceeding to all or part of the testimony, including any affidavit or declaration, of any individual identified below or in any Amended or Supplemental Witness List submitted by Defendants, and reserve their right to withdraw unilaterally the name of any such individual.

WITNESSES No. Name / Contact Subject Matter of Anticipated Testimony

1.

Gary Smith c/o Counsel: M. David Riggs Donald M. Bingham Wm. Gregory James RIGGS, ABNEY, NEAL, TURPEN, ORBISON & LEWIS 502 West 6th Street Tulsa, OK 74119 (918) 587-3161 Will testify to matters in Plaintiffs’ Complaint and in his Answer and Narconon of Oklahoma, Inc.’s Answer and Narconon of Oklahoma, Inc.’s Answer to Plaintiffs’ Complaint; matters relating to his CCDC; other relevant matters as a staff member of Narconon Arrowhead.

2.

Derry Hallmark c/o Counsel: M. David Riggs Donald M. Bingham Wm. Gregory James RIGGS, ABNEY, NEAL, TURPEN, ORBISON & LEWIS 502 West 6th Street Tulsa, OK 74119 (918) 587-3161 Will testify to matters in Plaintiffs’ Complaint and in his Answer to Plaintiffs’ Complaint; matters relating to his CCDC; other relevant mattes as a staff member of Narconon Arrowhead.

3.

Janet Watkins c/o Counsel: Will testify to matters in Plaintiffs’ Complaint and in her Answer to Plaintiffs’ Complaint; other relevant matters as a 2


M. David Riggs Donald M. Bingham Wm. Gregory James RIGGS, ABNEY, NEAL, TURPEN, ORBISON & LEWIS 502 West 6th Street Tulsa, OK 74119 (918) 587-3161 staff member of Narconon Arrowhead.

4.

Tom Widmann c/o Counsel: M. David Riggs Donald M. Bingham Wm. Gregory James RIGGS, ABNEY, NEAL, TURPEN, ORBISON & LEWIS 502 West 6th Street Tulsa, OK 74119 (918) 587-3161 Will testify to matters in Plaintiffs’ Complaint and in his Answer to Plaintiffs’ Complaint; other relevant matters as a staff member of Narconon Arrowhead.

5.

Vicki Smith c/o Counsel: M. David Riggs Donald M. Bingham Wm. Gregory James RIGGS, ABNEY, NEAL, TURPEN, ORBISON & LEWIS 502 West 6th Street Tulsa, OK 74119 (918) 587-3161 Will testify to matters in Plaintiffs’ Complaint and in her Answer to Plaintiffs’ Complaint; matters relating to her MAC; other relevant matters as a staff member of Narconon Arrowhead.

6.

Michael Otto c/o Counsel: M. David Riggs Donald M. Bingham Wm. Gregory James RIGGS, ABNEY, NEAL, TURPEN, ORBISON & LEWIS 502 West 6th Street Tulsa, OK 74119 (918) 587-3161 Will testify to matters in Plaintiffs’ Complaint and in his Answer to Plaintiffs’ Complaint; matters relating to his CCDC; other relevant matters as a staff member of Narconon Arrowhead. 3
