Exhibit C

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AFFIDAVIT OF ERIC TENORIO

STATE OF NEW YORK )
) SS
COUNTY OF Tompkins )

Eric Tenorio, being first duly sworn deposes and says:

1. My name is Eric Tenorio. I am over 18 years of age, I have personal knowledge
of the matters stated herein, and am available to testify. I reside at 129 Hickory Circle, Ithaca,
NY 14850 .
2. I worked for Narconon for over twelve years in various capacities. I have worked
at Narconon Chilocco in Oklahoma, Narconon Arrowhead in Oklahoma, Narconon Stone Hawk
in Michigan, Narconon Freedom Center in Michigan and Narconon Spring Hill in Florida. I was
the Executive Director of Narconon Freedom Center in Albion, Michigan. This is the highest
position at a Narconon Center.
3. During my work at five different Narconon centers, I personally observed how an
individual Narconon center is supervised and controlled by Narconon International and ABLE.
4. Narconon International publishes manuals that describe in detail how Narconon
International and ABLE micromanage individual Narconon centers. These manuals are
Operating An Effective Narconon Center and Opening A Successful Narconon Center.
Individual Narconon centers must abide by these manuals in conducting their operations.
5. As provided in these manuals, Narconon International has ultimate authority over
the hiring and firing of staff members at individual Narconon centers. A permanent staff member
at an individual Narconon center cannot be transferred, demoted, or dismissed without the
approval of Narconon International. In addition, Narconon International serves as a Human
Resources department of sorts in that staff members at individual Narconon centers can send Job
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Endangerment Chits to Narconon International if a staff member believes another employee is
preventing him from performing his job effectively.
6. Likewise, staff members at individual Narconon centers report misconduct or
out-ethics activities by other staff members to Narconon International. Narconon International
in turn investigates those employees and may take disciplinary actions against them.
7. Narconon International and ABLE supervise and monitor the delivery or the
rehabilitative technology at individual Narconon centers. To do this, Narconon International
and ABLE send persons to conduct tech inspections at Narconon centers. These tech
inspections consist of monitoring the manner in which staff conduct the Training Routines or
drills that comprise the Narconon written materials. Tech inspections also include monitoring the
manner in which staff instruct Narconon students on how to work through the Narconon written
materials.
8. Narconon International and ABLE must approve all websites an individual
Narconon center uses before the site can go live on the Internet or before a sites content is
changed.
9. Narconon International must approve all promotional materials for an individual
center before the center disseminates the materials. Narconon International also directs
marketing campaigns for individual centers and dictates the content of a centers marketing
materials.
10. Narconons claims about its success rates and its sauna programs ability to
eliminate drug cravings come from Narconon International. Individual Narconon centers do not
conduct research on the success of the program for Narconon students. Similarly, individual
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Narconon centers must advertise that the sauna program can eliminate an addicts drug cravings
by flushing out residual toxins stored in the addicts fatty tissue.
11. Narconon centers are required to send detailed reports to Narconon International
every Thursday providing the centers statistics for the week. These statistics include the number
of students who started the program during the week, the amount of money received and payed
out along with 40 or so other statistics which are graphed. The purpose of this is so that
Narconon International and ABLE can then monitor the trends of the organizations statistics and
then order changes in the areas that are not doing well or strengthen areas that are doing well.
This is known as Management by Statistics. This method of management can be found in every
organization that has anything to do with L. Ron Hubbard, including all Churches of
Scientology.
12. Narconon International and ABLE also advise centers on how to handle legal
matters and bad publicity known as black propaganda".
13. As an Executive Director at Narconon Freedom Center, it was not unusual for me
to receive calls from the Executive Director or other persons at Narconon International several
times per day. Narconon International was always interested in what was happening at the
facility, and, in particular, how much money the facility was bringing in and how much money
was going to be sent to Narconon International.
14. Narconon International receives ten percent of the gross income from each
Narconon center. Because of this, Narconon International is constantly pushing Narconon
centers to bring in more students.
15. The president of Narconon International does not keep up with the day-to-day
activities of individual Narconon centers. That is not his role. But others at Narconon
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