DOCUMENT NO.

27, 130, (3) pages

FILED
Sep 25 1987
9 45 AM
U.S. DISTRICT COURT
NEW HAVEN, CONN

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF

CONNECTICUT

ALFRIEDA SLEE, Administratrix

Of the Estate of Jack Andrew Slee
Deceased,

Plaintiff,

v.

WERNER ERHARD, ET AL,

Defendants.

CIVIL ACTION NO.

N 84 497 (JAC)

AFFIDAVIT OF DR. JAMES MERIKANGAS

STATE OF CONNECTICUT

CITY OF NEW HAVEN

SS

I, James R. Merikangas, M.D., being duly sworn according to law do hereby

state as follows:

I am informed by counsel for plaintiff, Gerald F. Ragland, Jr., in the case of

Slee v Werner Erhard and Associates, et al., that defendants’ have filed a
motion based in part on my testimony in deposition to the effect that no one
could have predicted, in advance, the death of Jack Slee. While this is true,
this statement does not fully reflect the nature of my opinions pertaining to
this case. Mr. Ragland has requested that I outline my opinions as to
forseeability and causation in this affidavit.

It is my opinion that defendants had every reason to know, prior to the death
of Jack Slee, that their training was likely to cause emotional distress, stress,
adverse changes in the autonomic nervous system and both psychological
and physiological harm.

It is further my opinion that it is a known fact that deaths from cardiac

arrhythmia can and have resulted from emotional distress.

While it was not possible to predict the exact occurrence of the death of Jack
Slee, his death was within the range of foreseeable harm that could likely
result from the est training. Viewing the events in retrospect, it is my opinion
that the death of Jack Slee was caused by the est training.

[signature]
James R. Merikangas, M.D.

Subscribed and sworn to before me the undersigned notary public this 18

day of September, 1987.

[signature]
My commission expires:

Susan J. Moffa
Notary Public
My commission expires March 31, 1990.