Tyler v. Scientology: Scott Deposition

10/29/15
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IN THE CIRCUIT COURT FOR THE COUNTY OF CALHOUN
NARCONON FREEDOM CENTER

d/b/a NARCONON FREEDOM
TREATMENT CENTER, et al,
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Case No.: 15-846-NO

Hon. Sarah S. Lincoln
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DEPOSITION
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14 and Notary Public for Firm #8453, at 161 E. Michigan Ave.,
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15 Battle Creek, Michigan, on Thursday, October 29, 2015,
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16 beginning at 1:22 p.m.
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APPEARANCES:
On behalf of Plaintiff: SAEED & LITTLE, LLP

1433 North Meridian St., Suite 202
Indianapolis, IN 46202
BY JONATHAN LITTLE (27421-49)
and DAVID MILLER (31855-32)
(317) 721-9214
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On behalf of Defendant: MADDIN, HAUSER, ROTH & HELER, PC

28400 Northwestern Hwy., Suite 200
Southfield, MI 48034
BY KATHLEEN H. KLAUS (P67207)
(248) 359-7520
Battle Creek, Michigan
Thursday, October 29, 2015
At 1:22 p.m.
RECORD
BETH SCOTT,
after having first been duly administered an oath, was
examined and testified as follows:
On behalf of Defendant: SCHEPER KIM & HARRIS, LLP

9 Via telephone
601 W. 5th St., Suite 1200
Los Angeles, CA 90071-2025
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BY WILLIAM H. FORMAN, JD
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11 Also present:
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Catherine Villanueva.
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* No exhibits marked.
13 Kristie L. Dickinson, CSR-4667, Certified Shorthand Reporter
4:16
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Examination by MR. LITTLE
12 of BETH SCOTT, a witness called by Plaintiffs, taken before
Page
Defendants.
__________________________/
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TABLE OF CONTENTS
Plaintiffs,
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CANDICE TYLER, a Michigan

Citizen; and JOHN DEBAY, a
Michigan Citizen,
STATE OF MICHIGAN
THE WITNESS: I do.
MR. LITTLE: Okay. Ma'am, could you show

your ID to the court reporter?
THE REPORTER: It is a Michigan driver's
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license. The name is Beth Ann Scott, spelled B-e-t-h
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A-n-n S-c-o-t-t.
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MR. LITTLE: Okay, great.
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EXAMINATION
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16 BY MR. LITTLE:
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17 Q
And is that -- that's your name, ma'am?
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18 A
Yes, it is.
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19 Q
Okay, great. All right, ma'am. So you've been
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designated by Narconon as the person to speak about the
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technology and the treatment program offered at
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Narconon Freedom Center.
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designation was. It was to talk about the education
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program that's offered at NFC.
MS. KLAUS: Objection. That's not what our
DICKINSON REPORTING, INC.

(517) 487-1072
10/29/15
MR. LITTLE: Well, I believe she was offered
to talk about the treatment program.
Okay. So are we. Where are you from?
Originally, I'm from -- originally or before I came
MS. KLAUS: Well, she wasn't. She was --
MR. LITTLE: Well, let's take a look.
Originally, I guess.
MS. KLAUS: Look at my objections, not your
Connersville, Indiana.
Oh, okay. Actually, I don't know where Connersville --
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notice. My designations.
MR. LITTLE: All right. You're -- you're
here?
is that out east by Richmond?
saying she can speak about the -- here we go. Let's --
Yes.
let's start with treatment... Okay, the education
Okay. I do actually know. That's a small place.
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program. All right.
10 A
Very small.
11 Q
(BY MR. LITTLE) I think we're talking about two
11 Q
My fiance's from Winchester.
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different versions of an apple. All right, here we go.
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Ma'am, so tell us what your role is at the Narconon
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Freedom Center.
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15 A
Currently?
15 Q
(BY MR. LITTLE) All right. So, after you became a
16 Q
Yes, please.
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withdrawal specialist, then what did you do for
17 A
Director of Income.
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Narconon Freedom Center?
18 Q
Director of Income?
18 A
I was family liaison.
19 A
Yes.
19 Q
When did you start that job?
20 Q
Okay. How long have you been the Director of Income?
20 A
2012, February.
21 A
Maybe a week or so.
21 Q
Okay. When in 2011 did you start? Do you know?
22 Q
What did you do before then?
22 A
It was, I believe, August.
23 A
When Ms. Tyler was here?
23 Q
Okay. And then how long were you family liaison for?
24 Q
Well, let's go backwards immediately before you were
24 A
Until -- I'm trying to remember. It was November 2012.
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Director of Income.
25 Q
Then what did you do?
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I worked with getting documentation to the insurance
MS. KLAUS: Okay. Can we just get to the

question and answer, please?
MR. LITTLE: Okay. I'm just...
I don't remember the title, but then I was a supervisor
biller.
And how long did you hold -- what was the title for
of the family liaisons.

And then what -- how long did you hold that job?
that job?
A couple of months, then I started student services.
Medical Records Admin.
Okay. And when did you start student services?
And how long did you work in Medical Records
January of 2013.
Administration?
And then when did you stop student services?
July of 2013.
Okay. What are student -- what is a Director of
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About 18 months.
Okay. When did you start with Narconon Freedom Center?
10 A
2011.
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Student Services?
11 Q
Okay. What did you do when you started in 2011?
11 A
Assist students, for instance, with -- if they need to
12 A
I was a withdrawal specialist.
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make orders for shampoo, soap, that type of thing, if
13 Q
Okay. What's a withdrawal specialist?
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they would like to order tobacco products, then we
14 A
Withdrawal specialist helps people get through
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order that for them. Because they don't leave the
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nonmedical withdrawal symptoms.
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facility to get that on their own.
16 Q
Are you a nurse?
16 Q
Okay.
17 A
I am not.
17 A
So we place orders for them.
18 Q
What's your educational background?
18 Q
Okay. So, prior to 2011, did you have any familiarity
19 A
I have -- I have a Bachelor of Science degree from
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with the Narconon Program?
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Purdue University in management.
20 A
No.
21 Q
In man -- a BS in, like, business management?
21 Q
Okay. Have you -- well, tell us, what is the Narconon
22 A
Yes.
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Freedom Center Education Program?
23 Q
Okay. And when -- I'm from Purdue. Okay. You're from
23 A
Specific parts of the program, or can you be a little
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Indiana?
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bit more specific?
25 A
Yes.
25 Q
Yeah. Well, to be honest with you, I'm trying to

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figure out -- well, can you tell me what's your
interaction with the Narconon Freedom Center Education
Program? Like, what -- have you ever -- do you
administer it?
talk about it if you ask her the questions, Jonathan.

MR. LITTLE: Okay. All right.
Q
(BY MR. LITTLE) So let's start at the beginning then.

If somebody comes into Narconon, a new patient --
Not any more.
Mm-hmm.
Okay. But you did?
-- what -- what happens? What's the -- what is the
In the withdrawal area.
Okay, and tell me about that. When -- so this was a --
2011?
protocol?
MS. KLAUS: That's the intake. That's the
next person.
10 A
Yes.
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11 Q
Okay. So what did you do when you administered the
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to how they would end -- end up in the educational
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Education Program in the withdrawal area?
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portion of the program, Miss Klaus, so --
13 A
People are withdrawing from drugs, so you make them as
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MS. KLAUS: I think she testified to how that
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comfortable as you possibly can to try to help them
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starts when she talked about the withdrawal program.
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through the withdrawal symptoms.
15 Q
(BY MR. LITTLE) Okay. So after -- during the
16 Q
Mm-hmm.
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withdrawal, what kind of education do you administer or
17 A
You help them stay out of their head so they don't
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give?
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become depressed, you administer assist to them, which
18 A
We try to make them com -- learn how to be comfortable
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it's not really a massage. What it does is relax the
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where they're at.
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body so they can sleep. Individuals coming off of
20 Q
Like, what does that entail?
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heroin often can't sleep. It helps them get their
21 A
What we do, we call them -- it was called a training
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much-needed rest, administer vitamins, make sure they
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routine, and you learn how to be -- to sit there and be
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eat healthy meals.
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comfortable where you're at and try to clear your mind
24 Q
Well --
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of thoughts of the past and things that are making you
25 A
If they're having a bad day, what you do is assist them
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depressed. Just be comfortable where you're at in your
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and help them with whatever's going on with them.

Q
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MR. LITTLE: Yeah. Well, I'm trying to get
Okay. So -- okay. Tell us about an assist. What's an
assist?
current, present environment.

Q
So, by "training routine," like, can -- tell me more

about the training routine. What's the training
What it does is it helps to relax the individual's body
because sometimes their body aches, they're very tired,
too tired to the point where they can't sleep.
Basically what you do is you just go down a person's
Mm-hmm.
arms and maybe on their back --
And you have to be three feet apart. And it makes you
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So it's a physical?
routine consist of?

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They'll do it with another person, and two chairs are

facing each other.
comfortable in your environment and around other
10 A
-- back of legs. Yeah, it's physical. We do -- we are
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people. So that's the purpose of the other person.
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very much informed to not get close to personal areas.
11 Q
So you sit three feet apart, and then what do you do?
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It's very much restricted.
12 A
What you do is -- there are two different types that we
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have them do -- do in the withdraw [sic] area. One
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MR. LITTLE: You know, we're -- I'm confused
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as to how this person is the designee on the Education
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with eyes closed, and then the other with eyes open
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Program.
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where you look right at the person, and it helps them
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with confront.
17 Q
Okay. So when -- when you do -- let's talk about the
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eyes closed.
19 A
Mm-hmm.
20 Q
Which one do you do first, eyes closed or eyes open?
21 A
Eyes closed.
22 Q
Okay. So tell me, so, if we're both sitting three feet
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MS. KLAUS: Why don't you just ask the

questions, and she can an -- ask questions -MR. LITTLE: She does -- she has no idea
about any of the -MS. KLAUS: You haven't even asked her, so
how do you know?
MR. LITTLE: Because I just went through her
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job duties, responsibilities. She's never had anything
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apart from each other with our eyes closed, what --
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to do with education.
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what do the -- the people do?
25 A
Quiet, very quiet, much like a meditation.
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MS. KLAUS: It doesn't mean she's not here to
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No speaking?
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No. I don't know what the mixture is.
No speaking.
Okay. You said "confront." What does it mean to learn
Okay. And how long do they do that for?
It's done on a gradient. It depends on the individual
and what they're comfortable with, and then they work
like I'm looking at you right now. They're very
up. I don't really remember the time frame we would
uncomfortable, they're -- they're ashamed of
have them do it in the withdrawal area because, as I
themselves, excuse me, they don't have any confidence.
said, a lot of times they are not feeling well
And what that does is kind of help -- help them come
sometimes. As they begin to feel better, it kind of
out of their shell a little bit and begin to gain
to confront?
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Okay. For instance, a drug addict cannot look at you
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helps them become more -- more comfortable in their
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confidence.
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present environment.
11 Q
Now, do you have any training in addiction counseling?
12 Q
So they -- they sit three -- and is there a goal time
12 A
I do not.
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like, if once you do eyes closed for X time, you move
13 Q
Okay. Were you the supervisor in the Withdrawal Unit
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on to eyes open? Is that how that works or --
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in 2011?
15 A
Actually, it -- it's alternated.
15 A
I was not.
16 Q
Okay.
16 Q
Who was the supervisor?
17 A
They may do five minutes of eyes closed and then
17 A
I don't remember her name.
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however long they feel comfortable doing eyes open.
18 Q
Okay. Was there a doctor around?
19 Q
What, do they -- they speak to each other during eyes
19 A
We have a center medical director.
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opened?
20 Q
And where -- is his office at 809 --
21 A
They do not.
21 A
It is not.
22 Q
Okay. How long do they sit three feet apart from each
22 Q
Where is his office?
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other?
23 A
I don't know.
24 A
However long is comfortable for that individual. We're
24 Q
Is it a he or she? I guess I don't know.
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trying to get them to increase each time; but, for a
25 A
It's a he.
withdrawal student, ten or fifteen minutes.
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A physician?
How many times a day?
Yes.
It just all depends on the activity in the withdrawal
Who -- and who was that -- who is that now?
unit and what that person is comfortable with.
Dr. Martin Holmes.
So how long -- so once you -- is there a -- a goal of
And who was it in 2012?
this sitting across from each other, like a goal time
Dr. Martin Holmes.
period before you would advance?
Okay. Okay. So, after the training or the first
The advancement out of withdrawal really isn't the
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passing of a training routine, it is getting through
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exercise, is that a good -- the eyes closed, eyes open?

A
Yes.
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the withdrawal symptoms. That's what determines
10 Q
How would you -- how would you call that?
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whether or not they move on to the next step.
11 A
The first set of drills.
12 Q
Okay. What other educational activities take place in
12 Q
The first set of drills, okay.
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withdrawal?
13 A
Yes.
14 A
That's about it for that point because most of the time
14 Q
Is there any literature or anything at that time?
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they're not feeling good, we're just trying to get them
15 A
No.
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to feel better, eat better, and get sleep. And then
16 Q
No.
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they move on to the next step.
17 A
They move on to the next phase of the program.
18 Q
All right. You have mentioned vitamins.
18 Q
What's the next phase of the program?
19 A
Mm-hmm.
19 A
They go in and learn more extensive communication
20 Q
What kind of vitamins did you give?
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drills.
21 A
It's -- it was called withdrawal vitamins. I don't
21 Q
Okay. And what are those drills?
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know what's in -- involved with the withdrawal
22 A
Basically learning how to acknowledge when people speak
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vitamins.
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to you, learning how to communicate effectively with
24 Q
You don't know what kind of vitamins they were or
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others.
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anything?
25 Q
So what -- what kind of -- are there any materials

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provided or anything?
There are. There are books.
Okay. And where -- what are those books called?
At the time Candice Tyler was here, that was -- those
Okay, but you said there was eight steps, eight

courses?
MS. KLAUS: "She," you mean Candice Tyler?
(BY MR. LITTLE) When Candice Tyler was there, there
were the books. Book 1.
Book 1?
Yes.
Yes.
Okay. Okay. So does everybody go through the same
Who -- do you know who wrote Book 1?
There is a -- okay, you have it right there.
were eight courses?
eight courses?
MS. KLAUS: You mean did they back then?
10 Q
Is it -- is it -- okay, so I'm just --
10 Q
(BY MR. LITTLE) Well, let's start with, yeah, back
11 A
You've got a Book 3 and a Book 5 and a Book 6.
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then did they all go through the same eight courses in
12 Q
And just --
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2012, do you know?
13 A
I don't know who wrote it.
13 A
Yes.
14 Q
Okay. But this is -- is this the correct series?
14 Q
Okay. And those eight courses, where did those
15 A
Yes, it is.
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materials come from for the eight courses?
16 A
I don't know.
17 Q
How did you get the materials to teach people?
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MS. KLAUS: For -- wait a minute, I'm going
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to object to the form.
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THE WITNESS: Oh, sorry.
18 A
Oh, it was given to me by a course supervisor.
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MS. KLAUS: Correct series for what?
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Actually, not given to me, but they're given to the
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MR. LITTLE: The books, the -- the series
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students by the course supervisors.
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one --
21 Q
And who was the course supervisor in 2012?
22 Q
(BY MR. LITTLE) How -- how many levels of the -- the
22 A
I don't remember.
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learning improvement course are there?
23 Q
Who's the course supervisor now?
24 A
Now or when Ms. Tyler was in the program?
24 A
I -- it varies.
25 Q
Let's start with when Ms. Tyler was in the program.
25 Q
If I wanted to get a complete set of the course
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Eight.
And how much are there now?
I don't know.
One, two, three, four, five.
Do you know where they're kept at Narconon?
There's five?
I don't, I don't. I don't work in that area, so I
Yes.
Okay. So tell us what Level 1 is or what learning
improvement course one is, Book 1, I guess.
where I would -- who I would contact to get a complete
set of materials from 2012 or '13?
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MS. KLAUS: Objection.

Q
(BY MR. LITTLE) Actually, you know what? What would
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materials now, who would I contact?
don't know where the books are kept.

Q
Okay. What about in 2012 or '13, who -- do you know
I don't know that either.
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you call the first book or course? What is it called?
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MS. KLAUS: Objection to form.
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the record that I'm trying to take a discovery
MR. LITTLE: I would just like to state on
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If you understand what he's asking --
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deposition. I want a complete set of the course
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THE WITNESS: I -- I don't really. Are you
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materials, and the witness doesn't know where to get

them.
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looking for a title of the book?
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15 Q
(BY MR. LITTLE) Right. Where we -- where --
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16 A
I don't remember the title.
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doesn't surprise me that she wouldn't know where to get
17 Q
Okay. What -- what is the entire course called?
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the books from three years ago. And she's not offered
18 A
Okay, the entire program or each book or --
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as to the location of books. She's offered to talk
19 Q
Yeah, yeah, number -- so number one. After you do the
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about the program. So, if you have questions about the
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eyes closed, eyes opened, you move on to -- you --
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program, ask her.
21 A
That's also part of the next step --
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22 Q
Okay.
22 Q
(BY MR. LITTLE) So tell us about the eight-step
23 A
-- at a higher gradient.
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program from 2012. How -- how did -- how are the eight
24 Q
What's the next step called? Do you know?
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steps divided?
25 A
I don't remember.
25 A
Into eight steps.
MS. KLAUS: She's not the attorney, so that
MR. LITTLE: Okay.

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Right. What are -- like, what's step number one?
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When was it?
It would be the communications course.
It was previous to my employment.
Okay. So can you tell me about the communications
Okay. Were you there as an employee or as a patient?
course?
MS. KLAUS: We're not going to -- she's not
People learn how to communicate better.
going to answer any questions about her personal
Okay. What kind of activities do they do?
medical history.
Communication drills.
Like, can you give me examples of communication drills?
how she got trained in these courses, and she's the
For instance, if I was partnered with you, then what we
person most knowledgeable on education, so I think I
MR. LITTLE: I'm just trying to figure out
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would do is work on -- first it starts at a very low
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have the -- I'm entitled to know how she got trained on
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gradient, and then you would learn how to respond to me
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them.
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during a conversation to acknowledge that you've heard
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me. And then they learn how to deal with difficult
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person most knowledgeable. I don't understand why you
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communication. So you would pretend to be
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can't read The Court Rules. The Court Rule says you
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antagonistic, and I would have to learn how to deal
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per -- put a person up who's going to speak on behalf
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with that.
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of the company about that. It doesn't have to be the
17 Q
Okay. And so what -- when you say "low gradient," what
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person most knowledgeable --
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do you mean "low gradient"? What does that mean?
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19 A
They don't start out too hard at first, too difficult
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at first. They first learn how to re -- first they
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respond to a communication, then it begins to get a
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little bit more difficult. Then comes the antagonis --
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I'm trying to figure out where she was trained on these
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the antagonism, or people trying to get off the
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courses. She can't tell me where the books are kept,
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subject, that type of thing. And you learn how to
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she can't tell me -- I mean --
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handle that, how to get them back into what you need
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MS. KLAUS: Okay.
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for them to -- to talk to you about.

Q
MS. KLAUS: No, we're not saying she's the
MR. LITTLE: Well, if she -MS. KLAUS: -- and she's not here to testify
about any personal medical history.
MR. LITTLE: This is a discovery deposition.
MR. LITTLE: -- there's a lot of specific --
Okay. So when you say easy -- like, a less combative
I mean who -- how am I supposed to know where -- what
first question, can you give me an example of the first
I'm asking for if the person that you designate to
question?
speak about it doesn't know where it is?
There are some in -- they're demonstrated in the book,
and I believe you can use either Do Birds Fly or Do
don't understand about how discovery works, Jonathan;
Fish Swim.
but I'm not here to educate you on how discovery works.
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And how often do you repeat that question?
Depends on the drill. Depends on that -- the back and
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MS. KLAUS: She -- I don't know what you
MR. LITTLE: Okay. Well, I'm -MS. KLAUS: I suggest you get a copy of the
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forth with the drill.
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Michigan Court Rules and read them.
11 Q
Well, I mean, in the first drill, how often do you guys
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go back and forth?
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13 A
We don't really count the number of times. They don't
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THE REPORTER: One at a time.
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count the number of times. It's more like you drill
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MS. KLAUS: If you want a set of books, why
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until you're comfortable that that individual is
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didn't you ask me for a set of books? But you didn't.
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comfortable with -- the two people involved are
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Instead, you're asking her if she knows where the
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comfortable with performing that action.
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facility books from 2012 are located, which is a
18 Q
Were you -- did you participate in these courses
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patently ridiculous question, but I'm not objecting
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yourself?
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because I want to get this thing over with.
20 A
I did.
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21 Q
Okay. Where did you do your training at, or where did
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you participate in these courses at?
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23 A
Narconon Freedom Center.
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24 Q
Okay. Was that during the course of your employment?
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the person designated to speak on behalf of the company
25 A
No.
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went through the training that she was designated to
MR. LITTLE: I would like to -- to do this

without --
MR. LITTLE: Well -MS. KLAUS: But you're not going to ask her
about her personal medical history.
MR. LITTLE: I'm trying to figure out when

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speak about.
MS. KLAUS: Well, maybe she didn't go through
the training.
Okay. Who are the other trainers?
Is this currently, or from 2012?
Well, if you remember any from 2012, but you said you
MR. LITTLE: Well, she said she did.
MS. KLAUS: Well, she's not -- I don't --
I don't remember from 2012.
Did you say you went through training?
So currently?
THE WITNESS: I don't recall.
And could you repeat the question, please?
MS. KLAUS: Yeah. She went through the
Who are the other current trainers in this program?
Actually, he's the main one. He is the designated
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program. That's not the same thing as going through
didn't.
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training. But she's not going to talk about her
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trainer currently.
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experience in the program on a personal basis. She's
11 Q
Okay. And who does he -- and he -- when -- does he
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talking about the program.
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train -- who -- do you know who he trains? Like, who
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does he train to administer this course?
14 A
Staff-wise, those that are interested in learning it.
MS. KLAUS: Okay.
15 Q
Okay. And is there a certification when you complete
MR. LITTLE: There will be a motion to compel
13
MR. LITTLE: All right, we get it, we get it.
14
I disagree with you.
15
16
16
his training, Sawyer's training?
17
a more appropriate designee, but we're trying to get
17 A
I don't know.
18
through this. Okay. So, ma'am --
18 Q
Okay. All right. So, in 2012, you stated there were
19
eight books. You stated you don't remember the names
20
of them; is that correct?
21 A
Correct.
19
MS. KLAUS: Maybe you should finish the dep
20
before you make that conclusion.
21
MR. LITTLE: All right.
22 Q
(BY MR. LITTLE) Ma'am, so you've -- you've been
22 Q
Okay. How are the books -- how are the eight courses
23
through this program yourself, correct? The eight-step
23
divided?
24
program?
24
25 A
I've done the books, correct.
25
26
All of it, the eight that were in 2012?
Yes.
Okay. Now, have you ever been trained in how to
MS. KLAUS: Asked and answered. If you can

add anything...
Q
(BY MR. LITTLE) Like, who decides when Course 1 ends

and when Course 2 starts?
As you go through the book, when you're finished, the
administer this program?
book, if someone -- if it's -- it's -- they've
I have not.
satisfied the criteria for that book, they move on to
Has anybody at your facility -- first in 2012, was
anybody at your facility training people in this
program?
completed Course 1 or Book 1, here's a certificate; or
how -- how do you verify that a student has completed a
In 2012, yes.
the next one.

Q
Is anything in the book -- is there any, like, you
10 Q
Okay. And who were the trainers in 2012?
10
course?
11 A
I don't recall.
11 A
Now or in 2012?
12 Q
Okay. Who are the current trainers?
12 Q
In 2012.
13 A
There are different ones in the facility, but they have
13 A
In 2 -- 2012, they did receive a certificate.
14
also been trained in that, so they train others.
14 Q
Okay. And now?
15 Q
Right. What are their names?
15 A
I don't know.
16 Q
Okay. Now, these books, they say on the cover, "Based
17
on the works of L. Ron Hubbard"?
16
17
MS. KLAUS: You can go ahead and give their

names.
18
THE WITNESS: Okay. Sawyer Grose.
27
18 A
Correct.
19 Q
(BY MR. LITTLE) Sawyer?
19 Q
Okay. Is it based on the works of anybody else besides
20 A
Mm-hmm.
20
L. Ron Hubbard?
21 Q
S-a --
21 A
I don't know.
22 A
W-y-e-r G-r-o-s-e. He's the main one.
22 Q
Okay. As -- as the person designated to speak on this
23 Q
Okay. Now, does Mr. Grose -- does he go to any
23
on behalf of Narconon Freedom Center, in the -- all
24
workshops about how to administer this program or --
24
eight books, do you know if anybody else's work is
25 A
I don't know.
25
cited?

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I do not know.
29
We've already discussed it. Right.
Okay. Which works of L. Ron Hubbard are these courses
Which one was a TR? Is that the canaries -- Do Birds
based on?
Fly?
I don't know.
Yes.
Okay. Narconon advertises that they can customize
Okay. Is -- is the eyes closed, eyes open, is that a
these programs for each individual.
6
7
MS. KLAUS: Objection to -- objection to
foundation.
MR. LITTLE: Okay.
10
TR?
Yes.
Okay. What is the goal of teaching people how to
MS. KLAUS: That's -- you're trying to create
communicate, teaching drug users how to communicate?
10 A
Drugs are normally a problem but not the problem. And,
11
evidence when it isn't there. If you have a document
11
through better communication, they're more able to
12
that says that, that's fine.
12
confront their problems, be more confident, and won't
13
MR. LITTLE: Thanks.
13
-- hopefully, it's just part of the foundation of what
14
MS. KLAUS: But you can't just make that
14
they learn; but it does help them move forward in
15
learning how to confront their problems, communicate
15
statement and then ask her questions about it --
16
MR. LITTLE: Thanks.
16
with others, and not run to drugs to avoid what's wrong
17
MS. KLAUS: -- as if it were true.
17
with them -- what's wrong -- what's wrong with their
18
MR. LITTLE: Thanks for your comment,
18
life.
19 Q
Okay. And what do you base -- what do you base that
20
statement on? Or what -- how does the -- what's the
21
statement based on? Any empirical research or
22
anything?
19
Counsel. Okay. So --
20
MS. KLAUS: It's an objection, it's not a
21
comment.
22
MR. LITTLE: Thank you for your comment,
23
Counsel.
23
24 Q
(BY MR. LITTLE) All right. So are -- is this program
24
25
customizable for each student?
25
Don't know.
30
MS. KLAUS: Objection to form and foundation.

THE WITNESS: Empirical research? I'm not
aware of any empirical research. I don't know.
32
That's --
So as the -- as the person designated to speak on
(BY MR. LITTLE) Okay. Okay.
behalf of Narconon Freedom Center, you don't know if
Doesn't mean it doesn't exist, I just don't know what
this eight-step program in 2012 is customizable for
each patient?
it is.
Q
Okay. What are some of the other drills associated
I do not know that.
Currently, do you know if this now five-step program is
customizable for each patient?
and get your point across so that they can react and do
what you ask them to do.
8
9
That, I don't know either.
31
with Course 1 besides Do Birds Fly and Do Fish Swim?

A
You have to learn how to request something from someone
10 Q
Do you know where -- where these -- where the
10 Q
Okay. I mean you gave a very specific example before
11
eight-step books come from?
11
of Do Fish Swim.
12 A
I don't.
12 A
Mm-hmm.
13 Q
Do you know who orders them?
13 Q
There's nothing like you can think of for -- for that?
14 A
No idea.
14
15 Q
If I wanted to get a copy -- if I -- if you wanted to
15
If you understand what he's asking, go ahead.
16
get a copy, how would you get them?
16
17 A
I -- I would have to ask around because I have no idea.
17
18
I would -- I would just pick staff members and ask them
18
19
becau -- and ask in they knew. I have no idea. I have
19
20
no idea how to get them.
20
21 Q
Okay. What is a TR?
21
would ask a question to which she could answer, so
22 A
Training routine.
22
there you are.
23 Q
Okay. And, tell me, what does a training routine mean?
23 Q
(BY MR. LITTLE) Okay. So you gave the specific
24 A
It's a drill, basically a communication drill.
24
example Do Fish Swim, Do Birds Fly --
25 Q
Can you give me an example? Is this -- go ahead.
25 A
Correct.
THE WITNESS: I'm not quite sure what you're

asking.
MR. LITTLE: I would appreciate it if counsel
would let the client testify.
MS. KLAUS: And I would appreciate it if you

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33
-- right?
Correct.
Sauna.
And then you said, you know, there's -- that you called
Oh, the Book 2 is the sauna?
that a low gradient question.
Yes.
the --
Correct.
Okay. And tell me about the sauna.
Okay. What's the next gradient up kind of question?
Sauna is a program where you basically sweat out all
Someone tries to get off topic, and you guide them back
onto topic.
Can you give me an example of that?
8
9
the drug toxins that are in the body.

Q
Okay. And is there any scientific research you can

point to that says that you can sweat out drug toxins?
10 A
For instance -- this is a good example. For instance,
10 A
I don't know.
11
okay, if you have a question and I go off on a tangent,
11 Q
Okay. What do you -- how long -- tell us about the
12
and you don't get your answer, what would you do? Ask
12
sauna. How hot is it?
13
the question again.
13 A
I don't know.
14 Q
Okay. And what kind of gradient question is that? Or
14 Q
Okay. How long do you stay in the sauna?
15
what kind of gradient? Is that like middle or --
15 A
The sauna period, itself, can last five hours. Now,
16 A
It's mid level, yes.
16
the individuals are not in the sauna box five hours.
17 Q
Okay. And where do these gradients come from? Do you
17
As a matter of fact, that's strictly prohibited.
18
know who originated the different gradients with the
18 Q
How -- how long are they actually in the sauna box?
19
types of questions?
19 A
Everybody's different. Everybody's different. What we
20 A
I don't.
20
-- what -- it's my understanding what we do tell people
21 Q
Okay. What are -- then what are some of the other
21
to do is, when they begin to feel uncomfortable, they
22
drills in Course 1?
22
must come out. Cool off, drink water.
23 A
Very similar, only maybe a little more resistance to a
23 Q
Is there any restriction on the amount of water someone
24
question or a request of an action.
24
can drink during the time they're in the sauna?
25 Q
Okay. Is there any clay modeling in Course 1? You
25 A
No.
34
build any clay models?
In the sauna, can you drink water? Like, in the
I don't recall.
Okay. So what's -- when do -- how do you know if -- or
I don't know.
how does one complete Course 1? What's the last
Are they -- do you consume any vitamins when you're in
gradient of Course 1?
literal sauna, can you drink water?
the sauna?
When they can communicate smoothly, get -- with
Yes, they do.
confidence, get their point across, and handle any type
What type -- what kind of vitamins do you consume in
of obstacle that they may come in contact with. For
instance, someone not responding, not giving them the
35
the sauna?
A
That, I don't know.
10
answer that they're look -- not the answer they're
10 Q
Are there any other supplements consumed in the sauna
11
looking for but getting someone's attention, being able
11
besides the vitamins?
12
to communicate effectively with that person, and
12 A
Oils.
13
getting the appropriate response.
13 Q
What kind of oils are consumed in the sauna?
14 Q
And who's the judge of the person -- the subject has
14 A
Don't know.
15
completed it? Who's the judge that that's good enough?
15 Q
Is there any literature that goes along with the sauna
16 A
There's a supervisor in the area.
16
program, like a book for the sauna program?
17 Q
Okay. And who was the 2012 supervisor?
17 A
Yes.
18 A
I don't know.
18 Q
Okay. And where -- what's -- what's contained in that
19 Q
Who was the 2013 supervisor?
19
book? What -- is it -- can you tell me about the book,
20 A
Don't remember.
20
about the sauna program? Can you tell me about it?
21 Q
2014 supervisor?
21 A
I can't.
22 A
Don't remember.
22 Q
Okay. Is there a doctor on site when people are in the
23 Q
Current supervisor?
23
sauna?
24 A
Sawyer Grose.
24 A
No.
25 Q
Okay, Course 2. What's Course 2? Narconon, what's
25 Q
Is there a nurse on site when people are in the sauna?

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37
Absolutely.
All the time?
Be specific.
Like, if there's somebody in the sauna, is it a
Okay. How -- how big is the sauna?
I don't know. Need more specifics like square --
That, I'm not familiar with. Whenever it's determined

that they finished the sauna part of the program; and,
unfortunately, I don't know how that's determined.
guarantee there's a nurse at 8:09?
Yes.
MS. KLAUS: We designated another person to
Okay. And that's same -- that's true in 2012 as well?
talk about the sauna program. Maybe you want to save
Yes.
these questions for that person. Just a suggestion.
Okay. So what is the -- what is the goal behind -- you
MR. LITTLE: Well, you -- this -- I asked her
10
said sweating out the drug toxins; is that right? The
10
what Course 2 in the education is. She's the education
11
goal behind the sauna is to sweat out the drug toxins?
11
person, so I'm asking.
12 A
Correct.
12
13 Q
Okay. Why do you want to sweat out the drug toxins?
13
14 A
To detoxify your body, to my understanding. Detoxify
14
MR. LITTLE: Okay. Well --
15
the body, you start to begin to feel better. Just like
15
MS. KLAUS: Just so that's clear.
16
a body detox like, okay, you see detoxes advertised.
16
17
Why would people do that?
17
18 Q
Are you familiar with the purifi -- are you familiar
18
MS. KLAUS: Kirk Harwood.
19
with a term "the purification ritual"?
19
MR. LITTLE: Okay, good.
20 A
No, not that term.
20
21 Q
Purificat -- purification rundown?
21 Q
(BY MR. LITTLE) So, when you complete the sauna
22 A
No.
22
program, which you don't know how to -- you don't know
23 Q
Okay. So you've not heard the term "purification
23
when somebody would -- you're not familiar with when
24
rundown"?
24
somebody would have completed the sauna program, what
25 A
Not purification rundown, no.
25
the metric is to complete the sauna program, right?
Scientology purification rundown, never heard it?
4
5
38
MS. KLAUS: She's also not the person

designated to talk about the sauna program.
MR. LITTLE: Okay. Well, who's designated to

talk about the sauna program?
MS. KLAUS: For now.
40
Correct.
No. No, I'm not familiar with Scientology.
Okay. Course 3, are you familiar with the learning
Okay. So these -- these harmful toxins --
Mm-hmm.
Yes.
-- where are they stored in your body?
Okay. Can you tell me about the learning improvement
Fat cells.
Okay. Do you have any medical basis?
I have none.
Okay. In fat cells generally or any specific areas of
39
improvement course?
course?
A
Learning improvement course helps people sort of learn

how to -- who's good for their life and who isn't.
Okay. And is that based on the works of L. Ron
10
fat cells?
10
Hubbard?
11 A
Don't know.
11 A
Yes, it is.
12 Q
Do harm -- do these toxins -- or are they the same as a
12 Q
Okay. Is it based on the works of anybody else?
13
thetan?
13 A
Don't know.
14 A
I don't know what a thetan is.
14 Q
Is there any neuropsychological studies that you know
15 Q
So -- okay, so how many days do you spend in the sauna
15
of in that course?
16
program?
16
17 A
Each individual is different.
17
THE WITNESS: I don't know.
18 Q
Who decides when somebody is through with the sauna
18 Q
(BY MR. LITTLE) Okay. What does a -- what does one
19
program?
19
study in the learning improvement course?
20 A
That, I'm not sure.
20 A
How to -- how to look at people and their life and
21 Q
Okay. So how do you know if somebody sweated out their
21
decide whether or not those people are good for them.
22
tox -- their toxins?
22 Q
Okay. When you say "decide if those people are good
23 A
I don't know.
23
for them," what do you mean by that?
24 Q
Okay. So how do you decide when somebody goes on to
24 A
For instance, if you have someone in your life that's
25
Course 3?
25
constantly putting you down and isn't supportive of you

(517) 487-1072
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41
at all, that person isn't good for you. Or someone
that's leading you to do drugs, that person isn't good
that counsel is reading from the book Learning
for you.
Improvement Course, based on the works of L. Ron
Okay. And so what kind of -- what kind of exercises or
Hubbard, Number 3.
things do you go over with the students during that
course?
I don't remember. It's been a while since I've seen
(BY MR. LITTLE) Okay.
that book.
What I feel looks bent may be different than what you
Do you remember if it talks about obstacles to
8
9
MR. LITTLE: Yeah. So let the record reflect
THE WITNESS: That would -- that's all

subjective.
feel looks bent or squashed.
10
learning?
10 Q
What does Narconon feel "bent" means in the context of
11 A
Yes, I remember that.
11
Course Number 3?
12 Q
What's the first obstacle to learning?
12 A
I don't remember.
13 A
Don't remember.
13 Q
Do you remember what it felt "squashed" meant?
14 Q
During this course, do you need to clear words?
14 A
No.
15 A
I believe so.
15 Q
Okay. What's datum mean? D-a-t-u-m?
16 Q
What does it mean to clear words?
16 A
Datum, as far as that book is concerned or --
17 A
Look it up in the dictionary and find the appropriate
17 Q
Yes.
18
definition.
18 A
Like --
19 Q
Okay. And which dictionary is that?
19 Q
As far as Narconon Course Number 3.
20 A
I don't know.
20 A
Datum would be data.
21 Q
Is there a separate dictionary for the Narconon course?
21 Q
Okay. Is "datum" a word you would have to clear?
22 A
I used a Webster's when I went through that book.
22 A
Me personally, or anyone else?
23 Q
Okay. Do you know what they use in -- used in 2012?
23 Q
Like, a student in this course.
24 A
No idea.
24 A
Depends on the student.
25 Q
Do you know what they use now?
25 Q
What's doingness?
Don't know.
3
4
42
Doing something.
Okay. So you looked the words up in the dictionary,
Is "doingness" a word you'd have to look up in the
and what is the goal of looking the words up in the
dictionary?
dictionary?
Understand what the word means.
me what doingness was if I -- say, for instance, if --
And what is the goal of that exercise, clearing words?
if I asked you what doingness was; and then, okay,
To help you understand what you're reading.
would you have to look it up, or do you believe others
Do you keep track of how many words a student clears?
would have to look it up? That's the point I'm trying
Depends on the individual. Would you be able to tell
I don't know.
to make.
10 Q
How does a student prove that they've cleared it, a
10 Q
Okay. But do you know if -- if "datum" is a word in
11
word, or not?
11
the Webster dictionary?
12 A
I don't know. I don't know that.
12 A
Don't know.
13 Q
Okay. Does this course cover barriers to study?
13 Q
What if a word is not a word in the Webster dictionary?
14 A
I don't remember.
14
What do you do then? What does a student do then?
15 Q
Can you tell me what absence of mass is?
15 A
I have no idea.
16 A
Don't remember.
16 Q
Is there a separate Scientology dictionary they would
17 Q
Can you tell me what it means to feel bent?
17
consult?
18 A
(The witness shakes her head.)
18 A
No idea.
19 Q
Or squashed?
19 Q
What -- what does the second barrier, too steep a
20 A
(The witness shakes her head.)
20
gradient, what does "too steep a gradient" mean?
21 Q
Spinney?
21 A
When you advance too quickly on a task, when you
22 A
That is a matter -- I don't know. Can you be more
22
haven't really learned how to do the first -- for
23
specific, like...
23
instance, if you don't learn well how to do the first
24
step, and you advance to the second one in anything
25
that you do, then you may not fully understand what you
24
25
MS. KLAUS: And let the record reflect

counsel is reading from a book.
43

(517) 487-1072
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1
2
45
need to do.
Q
program offered at Narconon besides these current five
Okay. What -- what does the word reelingness,
r-e-e-l-i-n-g-n-e-s [sic], have to do with too steep a
No.
gradient?
Thank you. Okay. I'm sorry your lawyers have put you
books or the past eight books?
Don't remember.
Do you know if reelingness is a word in the Webster
MS. KLAUS: I'm sorry you're putting her in
dictionary?
this position. And the judge instructed you not to be

snarky with the witnesses, so stop it.
7
8
Don't know.
What are the drills associated with too steep a
in this position. I'm --
MR. LITTLE: I'm being snarky?
10
gradient that the students do?
10
11 A
I don't remember.
11
12 Q
What are the drills associated with relieving a sort of
12
13
confusingness or reelingness?
13
14 A
I don't know.
14
15 Q
What is -- what is the field of doingness?
15 Q
(BY MR. LITTLE) All right. So, going back to the most
16 A
No idea.
16
important exercise in Course Number 3 --
17 Q
What is the misunderstood word?
17
18 A
A word you don't understand.
18 Q
(BY MR. LITTLE) -- the most important barrier, the
19 Q
Okay. And what is -- what -- what does the
19
misunderstood word, how do you -- in -- in the Narconon
20
misunderstood word have to do with Course Number 3 of
20
Education Program, how do you teach students to -- what
21
L. Ron Hubbard's learning improvement course?
21
do you teach students about the misunderstood word?
22 A
Could you be more specific?
22 A
I don't teach the books, unfortunately. I cannot
23
answer that question.
23
MS. KLAUS: -- will bring it up again, yes.

MR. LITTLE: Well, I disagree with that
characterization by counsel.
MS. KLAUS: The record speaks for itself.
MR. LITTLE: Okay, it does.
MS. KLAUS: Again, you're testifying.
24 Q
(BY MR. LITTLE) Well, in the context of L. Ron
24 Q
Okay. What does a blow mean in terms of the Narconon
25
Hubbard's Learning Improvement Course Number 3, Section
25
Course Number 3?
3, the third and most important barrier, the
2
3
4
46
48
Context.
misunderstood word. So what do you teach students
Leaving the course in this way is called a blow?
about the misunderstood word?
If they just get up and leave.
Don't know. I'm not -- I'm not --
Okay. And what happens if a student blows a -- Course
MS. KLAUS: Objection to form. The witness
Number 3?
is -- or the lawyer's reading from a book and not
Don't remember.
showing a copy to the witness. It's a very confusing
Are there penalties for blowing a course?
way to try to ask questions.
Don't know.
Do you remember any of the drills associated with the
MR. LITTLE: Just for the record, for our
10
motion to compel, I am reading from the course book
10
misunderstood word?
11
Learning Improvement, Course Number 3, by Ron -- based
11 A
I do not.
12
on the works of Ron L. [sic] Hubbard, that this -- that
12 Q
I'm turning to Section 4 of Course Number 3, handling
13
deponent was designated as the designee to speak on
13
the misunderstood word. What do you -- what does
14
behalf of her company on.
14
Narconon teach students to do in their education
15
program about handling the misunderstood word?
15
MS. KLAUS: That's exactly not true. You
16
never asked about specific books. You never asked us
16
17
to designate someone to talk about Course 3. You said
17 Q
(BY MR. LITTLE) Do you know?
18
"education program offered," okay? You didn't ask for
18 A
If you're asking me what's in that book, I don't
19
the implementation of the program, you didn't ask for
19
remember. If you're asking me what the procedure is, I
20
the specific books or anything else. Education program
20
don't know either.
21
offered.
21 Q
Does anybody study these books with the students?
22 Q
(BY MR. LITTLE) Ma'am, is there --
22 A
I don't know. I'm not in the course room with them.
23
MS. KLAUS: -- tell you about the program as
47
23 Q
Does anybody supervise the students' studies on --
24
it's offered. She was family liaison.
24 A
Yes.
25 Q
(BY MR. LITTLE) Ma'am, is there any other educational
25 Q
On a daily basis?

(517) 487-1072
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When they study, they have a supervisor present.
Okay. And how -- how do -- who grades them, or who
decides if they've completed a course or not?
trainings, when -- when do they occur in the Narconon

education course?
the students; so, unfortunately, I do not know.

Q
Do you know when the clay table or the clay table
The supervisor.
Okay. And are copies of those grades kept?
I don't remember.
Don't know. I don't know.
Do you know what clay -- clay table trainings are?
Okay. Do you know if there's lists or records of
I've not heard it referred to in that context.
cleared words for each student?
Let me show you -- I'm not going to admit it; but,
I don't know.
8
9
here, take a look at Page 137.
10 Q
Do you recall the two phenomena of misunderstood words?
10
11 A
I don't.
11 Q
(BY MR. LITTLE) Narconon Book 3.
12 Q
Okay. Can you tell us about Books 4-A and 4-B,
12 A
Okay. What -- what am I looking for?
13
Communication and Perception?
13 Q
That's clay table trainings.
14 A
They run objective exercises. That's what those books
14 A
Okay.
15
are for. And what those objective exercises do is help
15 Q
I want to ask you about that.
16
them make realizations about themselves.
16 A
So what would you like for me to --
17 Q
Okay. What kind of objective exercises do they do?
17 Q
Oh, just -- I -- just to refresh your memory. You can
18 A
They're drills. They're not drills, but I don't really
18
take a second and --
19
know what the ex -- the exact exercises are. I
19 A
Okay.
20
couldn't sit here and quote them to you verbatim. I
20
21
would have to refer to a book.
21
memory refreshed. Objection.
22 Q
Can you give me an example?
22 Q
(BY MR. LITTLE) Okay. All right. So what -- what is
23 A
I can't right now. I really can't.
23
the clay table training?
24 Q
Okay. So what -- what's the goal of 4-A and 4-B?
24 A
Clay models are used, but I don't remember what for. I
25 A
I don't know.
25
don't remember what the ultimate goal is.
50
MS. KLAUS: Objection, form and foundation.
MS. KLAUS: She didn't say she needed her
How would you know --
I don't know.
I'm sorry. How would -- how would one -- how would a
Don't remember that either.
student know when he's progressed through 4-A? What's
Do you know what clay table training has to do with
the penultimate exercise of 4-A?
MS. KLAUS: Objection to form. I don't think
you know what "penultimate" means.
THE WITNESS: And I don't.
MS. KLAUS: It means second to last so...
Okay. What about exercises in sketching? Do you know

what -- what's the goal of the sketching exercises?
drug rehabilitation?
MS. KLAUS: Objection, form.

THE WITNESS: Don't remember. Yeah, I don't
-- I'm sorry, but I don't remember.
Q
(BY MR. LITTLE) Same thing. Do you know what word
10 Q
(BY MR. LITTLE) And what's the ultimate exercise of
10
11
4-A?
11
12 A
When Candice Tyler was in the program or now?
12 Q
(BY MR. LITTLE) Are there any studies that you know of
13 Q
Yeah, yeah, when Candice Tyler was in the program.
13
that link word clearing to drug addiction success?
14 A
When Candice Tyler was in the program 4-A?
14 A
I don't know, I don't know. But, because I haven't
15 Q
Yeah.
15
heard of them, doesn't mean they don't exist. I just
16 A
Honestly, I don't know. I didn't administer the
16
have not heard of them.
17
program itself to the students, so I'm not going to be
17 Q
Okay. What is theory coaching?
18
much help with that.
18 A
Don't remember.
19 Q
What -- okay. So I guess do you know the penultimate
19 Q
What are checkouts?
20
exercise of 4-B?
20 A
Don't remember.
21 A
I do not.
21 Q
If I wanted to know what theory coaching and checkouts
22
were, who would be the person I would want to talk to
22
MS. KLAUS: Same objection.
51
clearing has to do with drug rehabilitation?

23 Q
(BY MR. LITTLE) And of 4-A -- or then the ultimate
23
at Narconon?
24
exercise of 4-B?
24 A
It would be a course supervisor.
25 A
As I've said, I -- I don't administer the program to
25 Q
That would be Sawyer?

(517) 487-1072
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Actually, though, now or when Candice Tyler was in the
53
you show that in your -- in the Narconon Education
program?
Both.
When Candice Tyler was a student?
And that's Book 3, correct?
Yes.
Yes.
Yes.
Book 3 is -- we don't use Book 3 now.
Okay. What is The Way To Happiness movie about?
Okay. So I guess, in 2012, who would I want to talk
It's basically what most of us have been taught. Doing
to?
the right thing, keeping your morals, and that type of
The course supervisor at that time, and I don't
thing.
8
9
Program?
10
remember who it was.
10 Q
Who produced that video?
11 Q
Why don't you guys use Course 3 now?
11 A
I have no idea.
12 A
I don't know.
12 Q
When you say "what most of us have been taught," what
13 Q
Okay. Number 5, Narconon Book Number 5, The Ups And
13
do you mean by that?
14
Downs of Life. What's that book about?
14 A
Well, what I would hope that most of us have been
15 A
I don't remember. Actually, I think some of the things
15
taught. Good ethics, good morals, treat others kindly,
16
I told you about Book 3 are probably Book 5. That's
16
do the right things in your life, help others.
17
how I'm not -- like I said, I don't administer this
17 Q
Ethics are very important in the Narconon Education
18
program, and I don't really remember.
18
Program; is that correct?
19 Q
Do you know what the goal of Course 5 and of Ups and
19 A
That's correct.
20
Downs of Life by Ron L. [sic] Hubbard is?
20 Q
What do ethics mean in terms of the Narconon Education
21 A
Do not know.
21
Program?
22 Q
What can you tell me about the education program at
22 A
That def -- that -- the exact definition, I don't
23
Narconon? Just anything. Like, if I'm asking you as a
23
remember. But -- yeah.
24
person --
24
MS. KLAUS: You can talk about it generally.
25
THE WITNESS: Yeah. Generally, if your
25
MS. KLAUS: Are you asking for an overview of
54
what --
ethics are in, you're doing the right thing.
MR. LITTLE: Yes.
MS. KLAUS: -- the program is?
(BY MR. LITTLE) Give me an overview of what the
program is.
Basically it's to help individuals get off drugs and
stay off them.
Who -- who decides that?
Okay. And how wo -- does Narconon Freedom Center
We have an Ethics Department.
Who's in charge of the Ethics Department?
5
6
7
8
program do that?
55
(BY MR. LITTLE) And who judges if you're doing the

right thing or not in the Narconon Program?
It's not as if ethics in the Narconon Program are

different than any other ethics the rest of us need to
follow in our life.
10 A
The sauna detoxification helps them learn to
10 A
Right now, I don't know.
11
communicate, helps them learn good ethics and morals,
11 Q
In 2012?
12
helps them handle problems with their -- learn how to
12 A
I definitely don't know.
13
handle problems in their own life, and helps them learn
13 Q
Are there repercussions in the Narconon Education
14
how to confront their problems.
14
Program for bad ethics?
15 Q
Okay. And do you know of any peer reviews of any of
15 A
There are, but I'm not -- I -- when Candice Tyler was
16
these materials?
16
here, I don't remember what those are, and I don't know
17 A
I don't know of any.
17
what that is now.
18 Q
Okay. Do you know of any medical study that says the
18 Q
In the Narconon Education Program, who decided if there
19
sauna program is -- you know, helps with drug
19
were -- well, could --
20
rehabilitation?
20 A
They do have student rules that they have to follow.
21 A
I don't. Doesn't mean it doesn't exist, I just don't
21 Q
Okay. And who -- who originated the student rules?
22
know of it.
22 A
No idea.
23 Q
What's --
23 Q
If I wanted to get a copy of the student rules, where
24 A
I didn't -- I didn't pursue it.
24
would I go to get one?
25 Q
Okay. What's a video called The Way To Happiness? Do
25 A
Again, along with the books, I don't know who you would

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1
2
3
4
57
ask for that, unfortunately.
five-book program today at Narconon Freedom Center?
Are the student rules displayed at the Narconon Freedom
I don't know.
Center?
Okay. And who -- okay. Can you tell us about Book 6?
I don't know, but students receive a copy. I don't
Do you guys current -- does Narconon currently use
know if they did when Candice Tyler was there.
Who keeps a copy of the student's educational file?
Not that book. It's a different book.
That, I don't know.
Is it still Course 6, the personal values and integrity
Bad ethics, can you give me an example of -- of
somebody who has bad ethics?
Personal Values and Integrity Course by L. Ron Hubbard?
course?
A
Just called Personal Values.
10 A
They try to sneak out of the facility to go use drugs.
10 Q
Okay. And what's -- what are the changes between 2012
11 Q
Okay. And what are -- what are the repercussions of
11
and today in that book?
12
that kind of bad ethics?
12 A
I don't really know. I couldn't be specific.
13 A
I don't know.
13 Q
Okay. So, in the personal values and integrity course,
14 Q
What is the effect of that kind of bad ethics on their
14
can you tell me what -- what you know about it? What
15
education in the Narconon Program?
15
is it?
16 A
That, I don't know either. That's kind of a general
16 A
That's when they learn about morals and ethics, that
17
question though. You mean personally or -- or whether
17
type of thing.
18
or not they're stopped from doing their program or --
18 Q
And what do they learn about morals and ethics?
19 Q
Like, if somebody sneaks out to get drugs and they're
19 A
Specifically, I would have to refer to the book.
20
half way through, do they go back? Do they get kicked
20 Q
I'm handing the witness a copy of Personal Values and
21
out of the program? Does it start over? Like, what
21
Integrity, Course 6, by L. Ron Hubbard.
22
are the repercussions of bad ethics?
22
23 A
That would depend on the ethics officer and the
23
24
situation surrounding it.
24
But you can go ahead and look at it.
25 Q
And who -- and the ethics officer alone makes that
25
THE WITNESS: It would take -- it would take
58
decision?
MS. KLAUS: Objection, unless it's going to

be marked at an exhibit.
No.
Who else is involved in making that decision?
a while for me to go through this book and really get

into it.
Q
(BY MR. LITTLE) Okay. I want to know. I mean you're
You -- I don't believe it's the ethics officer's sole
the person designated to speak about the education at
decision, but there's usually more than one person
Narconon.
involved. The other person, I don't really know who
that is.
7
8
Are all the people involved at Narconon Freedom Center?
Yes.
MS. KLAUS: No, education offered at

Narconon.
MR. LITTLE: Right. I'm asking her about it.
So tell me what course --
10 Q
They're not from outside of Narconon Freedom Center?
10
MS. KLAUS: You're asking her --
11 A
No.
11
12 Q
Okay. Are there any appeals in the Narconon
12
MS. KLAUS: You're asking her about details
13
educational process that a student could have?
13
from a book that's about an inch and a half big. So do
14 A
Don't know.
14
you have a specific question?
15 Q
Who ensures that the program -- who is Sawyer -- so
15 Q
(BY MR. LITTLE) Again, is there any other program
16
does Sawyer Grose currently ensure -- strike all that.
16
offered at Narconon besides the program you've
17
Okay. Who, from Narconon Freedom Center, ensures that
17
described to me, detox, sauna, these classes?
18
the course by L. Ron Hubbard is being administered
18 A
No.
19
properly currently?
19 Q
Okay.
20 A
Well, when Candice Tyler was there or now?
21 Q
When Candice Tyler was there.
Go ahead.
22 A
No.
THE WITNESS: Okay. Could you rephrase that?
20
21
22
23
MS. KLAUS: Objection to -- objection to

form.
59
23 Q
Okay.
24 Q
(BY MR. LITTLE) Who is in charge of administering the
24 A
I don't administer this program. So, for me to go
25
-- the L. Ron Hubbard eight-book program or currently
25
through this book and tell you what's in it and how --

(517) 487-1072
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how it gets taught to the students or whatever,
2
3
61
wanted a person to talk about the books, you should
unfortunately, I will not be able to do that.
have said we want you to produce a person to talk about
Does anybody ever say that this program is just
Book 6, a person to talk about Book 7, a person to talk
Scientology?
about book whatever, and you didn't.
MS. KLAUS: Does anybody ever?
MR. LITTLE: I went with the general
MR. LITTLE: Okay, never mind. Strike that.
education, meaning the only education offered, and you
(BY MR. LITTLE) What are the differences between your
said --
program and Scientology?
MS. KLAUS: Look at your request, and look at
10
You're assuming she even knows anything about it. It's
10
MR. LITTLE: You designate Beth Scott --
11
-- it's -- about Scientology.
11
MS. KLAUS: We object --
MR. LITTLE: I'm only assuming --
12
MS. KLAUS: What's the difference between
13
12
13
14
this and nuclear physics? It's a ridiculous question.
15
MR. LITTLE: I'm only assuming that she knows
my objection.
MS. KLAUS: -- to this topic because it is
14
vague, and the terms in quotes are not defined and do
15
not have a commonly understood definition. Subject to
16
anything about the course because she was designated to
16
these objections, we'll produce Beth Scott to testify
17
speak on the education offered by Narconon.
17
as to the education program offered. She was family
18
MS. KLAUS: Right.
18
liaison. People have questions about the program,
19
MR. LITTLE: Okay.
19
generally, she answers them. You're got -- you're
20
MS. KLAUS: Now you're asking her to compare
20
reading footnotes from inches -- books that are inches

thick --
21
it to something else when you haven't established that
21
22
she knows anything about the something else.
22
MR. LITTLE: There's no footnotes.
23
MS. KLAUS: -- and asking her questions about
23
MR. LITTLE: What is -- well, actually, she
24
didn't know anything about the purification rundown.
24
them when that's not what she was offered to. So, if
25
Okay, that's fair enough. All right.
25
you're frustrated, look in the mirror.
2
3
(BY MR. LITTLE) What does Course 6 do to help students
62
MR. LITTLE: All right. This is a -- a waste
regain their personal integrity?
of time for the deponent and for myself. We will be
That, I don't know. I don't administer the course, so
filing a motion to compel.
I don't really know.
This isn't your fault.
How about to recognize their personal values?
MS. KLAUS: And we'll be responding to the
Don't know.
motion to compel and maybe a suggestion that, if you
Do students go through audits as part of the Narconon
want something more specific, ask for specific.
program?
8
9
An audit?
MR. LITTLE: Mm-hmm.

MS. KLAUS: If you ask for a general person,
10 Q
Are you familiar with --
10
we give you a person who has a general understanding of
11 A
I don't know what that is.
11
it as she's testified to.
12 Q
Okay. What kind of things does Narconon -- okay. Is
12 Q
(BY MR. LITTLE) Just -- just for the sake of the
13
one of the goals of Course 6 to teach students to be
13
record, can you tell us about Book 7 by L. Ron Hubbard,
14
accountable for their own actions and take
14
Changing Conditions In The Life? Do you -- what do you
15
responsibility for their own actions?
15
recall about that book?
16 A
That, I don't know for sure.
16 A
Unfortunately, I don't administer the program; so I
17 Q
How is a student's production measured in this -- in
17
don't really know what the goals of it are; and I
18
this program?
18
wouldn't be able to tell you much about what's actually
19 A
I don't administer the course, so I don't know.
19
in the book unless I had reference to it. And then it
20
would only be my personal interpretation and not how
21
it's administered to the students.
22 Q
Okay. Same thing with Narconon Course Book 8, The Way
20
21
22
MR. LITTLE: I'm really baffled as to why

this witness was produced.
MS. KLAUS: I'm really baffled as to why you
63
23
didn't read your own request for what this witness was
23
To Happiness.
24
supposed to testify about. She's A, and you're asking
24 A
Mm-hmm.
25
her questions about B. So I'm equally baffled. If you
25 Q
What can you tell me about The Way To Happiness?

(517) 487-1072
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Same thing.
65
and then you can break it down. You can't interrupt
Okay. Can you tell me about the 21 practical drills in
her and stop her. It's rude.
The Way To Happiness?
I cannot.
MR. LITTLE: You interrupt me all the time,

Miss Klaus.
So, if I was a parent, and I called up and said I'm
concerned my -- my student -- my child is learning only
books -- is learning only materials produced by L. Ron
begin again. I don't remember where I left off.
Hubbard, is there anything else in the Narconon
Questions, concerns. If the individual wasn't feeling
Educational Program that is not produced by L. Ron
well, let them know that we're doing what we can on our
MS. KLAUS: Finish your answer.

THE WITNESS: Okay. I'll start over. I'll
10
Hubbard?
10
part to keep them as comfortable as we can to get them
11 A
Don't know.
11
through that very difficult part of the program. If
12
MR. LITTLE: Okay. Again, any questions?
12
they -- if they were willing, if they were not willing,
13
MR. MILLER: Can we take a quick break?
13
what their issues might be at that point in time, and
14
MR. LITTLE: Okay.
14
what we're doing to help with that willingness.
15
MS. KLAUS: Sure.
15 Q
(BY MR. LITTLE) Okay. So let's go back and start with
16
(At 2:32 p.m. - Off the record.)
16
what were the common questions that you encountered
17
(At 2:33 p.m. - Proceedings resume.)
17
when you were family liaison?
18 Q
(BY MR. LITTLE) Okay. Well, in your role as family
18 A
A lot of them were general. What's your mailing
19
liaison, what -- what do you -- what did you do with
19
address, how are they feeling. Or I got more questions
20
regards to education? What were your job duties and
20
like that earlier in the program. Later in the
21
responsibilities with regards to the Narconon education
21
program, the families didn't really have a lot of
22
course?
22
questions except when they might be finished. Most of
23
it was how do we put money on a student account; are
24
they cooperating; they seemed a little down last night,
25
what can you tell me about that?
23
MS. KLAUS: Objection to form, but you can go
24
ahead and answer.
25
THE WITNESS: Okay. Do you have a specific
question? Can you be a little bit more specific with
2
3
66
Go ahead.
that?
Mm-hmm. Yeah, what can you tell me about that; or they
(BY MR. LITTLE) When you were family liaison, which I
seemed extremely happy, that type of thing.
understand is what got you designated today --
Are these calls monitored?
Mm-hmm.
They're not.
Are they recorded?
(BY MR. LITTLE) -- what -- what did you do in relation
No.
to the Narconon -- to the education offered at
Are there phone records of who was called?
Narconon?
I don't know.
5
6
7
MS. KLAUS: Objection.
10 A
With respect to the education itself? I wasn't
10 Q
Are calls between students and family members
11
involved with the education itself.
11
monitored?
12 Q
Okay. Well, what was your involvement with the
12 A
I don't know.
13
education at all when you were family liaison?
13 Q
Are they recorded?
14 A
Are you asking if I had a part of how it was
14 A
No.
15
administered? What I did was call families.
15 Q
Okay. So did you ever have any questions or concerns
16 Q
Okay. When you called families, what did you do?
16
regarding the education course offered at Narconon?
17 A
I would call them. Did they have any questions, did
17 A
I did. I did. Sauna in particular. Not the sauna
18
they have any concerns. If their loved one was in
18
itself, but how long might they be in there, and each
19
the --
19
person's different. As far as Book 4-A and 4-B, just
20 Q
Okay. Well --
20
explain to them that it was -- it's a part of the
21
program where they have to do some soul searching.
21
MS. KLAUS: Wait. Can she -- can she answer
22
the question, please?
22
It's going to be tough for them, but they're also going
23 Q
(BY MR. LITTLE) I want -- I want to break it down.
23
to get a lot out of it. Sometimes a loved one wouldn't
24
She's already put three parts in it.
24
call home for, say, a week. I haven't heard from
25
so-and-so for a week, how are they doing? And then
25
MS. KLAUS: No, but let her finish answering,
67

(517) 487-1072
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10/29/15
what I would tell that family is -- and this is a true
2
3
69
71
Yes.
statement -- from my experience, from my personal
Why was he at the Freedom Center, if you know?
experience, they go through a spell maybe where they
I don't know. I don't remember. It was brief, and he
don't call home as often as the family wants them to.
And what I would do is find that individual and get
them on the phone with their family member right then
if I could. If they, for instance, were, say, in the
course room or in the sauna, get them on later so the
MR. LITTLE: Well, thank you.
family member wouldn't worry. But they -- they get
MS. KLAUS: Okay. I have to go to my car to
10
involved and get enthused about their own recovery.
10
get my cord because I'm running out of juice, but we'll
11
And then they still love their family, but they're just
11
bring the next witness out then.
12
involved with other things.
12
MR. LITTLE: Great.
13 Q
Did you get any specific questions about education that
13
(At 2:40 p.m. - Off the record.)
14
you can recall when you were family liaison?
14
15 A
No.
15
16 Q
Did anybody ever complain that the courses were just
16
17
Scientology?
17
18 A
No.
18
19 Q
Okay. Did anyone ever complain the sauna program was
19
20
dangerous or they were concerned it was dangerous?
20
21 A
I didn't field any calls about that.
21
22 Q
Did anybody ever complain that the core -- education
22
23
course offered was not secular, medically-supervised
23
24
drug rehabilitation with a 70-plus success -- or
24
25
70-plus percent success rate?
25
70
I never had that conversation either.
Okay. Do you know who Robert Keifer is?
No.
Do you know who Marga -- Margarita, a woman named
Margarita?
No.
You know who Kathy Nather Thomas is?
Don't know her.
Do you hold any certifications in general besides, you
1
2
3
know, your degree from Purdue? But do you have any
11
certifications or...? Like an --
12 A
CPR.
13 Q
Okay. Anything else?
14 A
No.
15 Q
Okay. Do you know who Bobby Wiggins is?
16 A
I've seen his picture.
17 Q
Who --
18 A
I met him once. I met him one time.
19 Q
Who is he?
20 A
Don't really know what his title is.
21 Q
Is he connected to Narconon Freedom Center?
22 A
I have no idea.
23 Q
Did you meet him in Albion?
24 A
I did.
25 Q
At the Freedom Center?
Okay. Are there any -- do you know who Yvonne Rogers

is?
No.
STATE OF MICHIGAN
)
COUNTY OF INGHAM
72
)
)
I certify that this transcript, consisting of
72 pages, is a complete, true and correct record of the
testimony of BETH SCOTT, held in this case on October 29,
2015.
10
wasn't there long.
9
10
I also certify that, prior to taking this

deposition, BETH SCOTT was duly sworn to tell the truth.
I also certify that I am not a relative or
11 employee of or an attorney for a party; or a relative or

12 employee of an attorney for a party; or financially
13 interested in the action.
14
15
16 November 8, 2015
17
18
19
20
21
22
23
24
25

(517) 487-1072
_______________________________
Kristie L. Dickinson, CSR-4667
P.O. Box 12133
Lansing, Michigan 48901-2133
Firm #8453
- 0 09 [1]
37:5
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8;
18:6, 7;
28:1,
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1200 [1] 2:9
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2012
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5,
18;
28:11,
12,
13;
30:4;
34:17; 37:7;
41:23; 53:7;
56:11; 59:10
2013
[3]
8:6,
8;
34:19
2014
[1]
34:21
2015
[4]
1:15;
4:2;
72:7, 16
202 [1] 2:2
21 [1] 65:2
22 [2] 1:16;
4:3
248 [1] 2:7
27421-49 [1]
2:3
28400
[1]
2:6
29 [3] 1:15;
4:2; 72:6
- 3 3
[21]
17:11;
38:25; 40:2;
43:4, 11, 19;
45:20,
25;
46:1, 11, 17;
47:16,
25;
48:5,
12;
51:11; 53:4,
6, 11, 16
317 [1] 2:4
31855-32 [1]
2:4
32 [1] 65:16
33 [1] 65:17
359-7520 [1]
2:7
- 4 4 [2]
3:4;
48:12
4-A
[8]
49:12,
24;
50:4, 5, 11,
14,
23;
68:19
4-B
[5]
49:12,
24;
50:20,
24;
68:19
40 [1] 71:13
46202
[1]
2:3
48034
[1]
2:6
48901-2133
[1] 72:17
- 5 5 [5] 17:11;
53:13, 16, 19
5th [1] 2:9
- 6 6 [7] 17:11;
59:3, 7, 21;
62:1,
13;
63:3
601 [1] 2:9
- 7 7 [2]
63:3;
64:13
70-plus [2]
69:24, 25
72 [1] 72:5
721-9214 [1]
2:4
- 8 8 [3]
37:5;
64:22; 72:16
809
[1]
15:20
8453
[2]
1:14; 72:18
- 9 90071-2025
[1] 2:9
- A A-n-n
[1]
4:13
able
[5]
31:11;
34:11; 44:4;
61:2; 64:18
absence [1]
42:15
Absolutely
[1] 37:1
account [1]
67:23
accountable
[1] 62:14
aches
[1]
10:5
acknowledg
e [2] 16:22;
21:12
across
[3]
14:6;
32:8;
34:7
action
[3]
22:17;
33:24; 72:13
actions [2]
62:14, 15
activities [2]
14:12; 21:6
activity [1]
14:3
Actually [7]
7:6;
13:15;
18:9; 19:19;
27:9;
53:1,
15
actually [4]
7:9;
35:18;
61:23; 64:18
add
[1]
27:25
addict
[1]
15:4
addiction [2]
15:11; 52:13
address [1]
67:19
Admin
[1]
6:5
administer
[14] 9:4, 18,
22;
11:16;
26:4,
24;
27:13;
50:16,
25;
53:17;
60:24; 62:3,
19; 64:16
administere
d [5]
4:6;
9:11; 58:18;
64:21; 66:15
administerin
g [1] 58:24
Administrati
on [1] 6:7
admit
[1]
51:8
advance [3]
14:7; 44:21,
24
advancemen
t [1] 14:8
advertised
[1] 37:16
advertises
[1] 29:5
ago
[1]
20:17
ahead
[7]
26:16;
30:25;
32:15;
58:22;
59:24;
65:24; 68:1
al [1] 1:8
Albion
[1]
70:23
alone
[1]
57:25
along
[2]
36:15; 56:25
alternated
[1] 13:15
amount [1]
35:23
Angeles [1]
2:9
Ann [1] 4:12
another [2]
12:5; 39:6
answer [10]
7:13;
23:5;
32:21;
33:12;
34:10;
47:23;
65:24;
66:21; 67:5
answered [1]
27:24
answering
[1] 66:25
answers [1]
63:19
antagonis
[1] 21:22
antagonism
[1] 21:23
antagonistic
[1] 21:15
a n yb o d y [ 1 1 ]
26:6,
7;
28:19,
24;
40:12;
48:21,
23;
61:3; 69:16,
22
a n yo n e [ 2 ]
43:22; 69:19
An yt h i n g [ 1 ]
70:13
a n yt h i n g
[15]
10:23;
14:25;
16:14; 17:1;
27:25; 28:7;
31:22;
44:24;
46:20;
53:23;
61:10,
16,
22, 24; 65:8
apart
[4]
12:8, 11, 23;
13:22
appeals [1]
58:12
APPEARANC
ES [1] 2:1
apple
[1]
5:12
appreciate
[2]
32:18,
20
appropriate
[3]
25:17;
34:13; 41:17
area [6] 9:7,
12;
12:13;
13:7;
20:4;
34:16
areas
[2]
10:11; 38:9
arms
[1]
10:8
around [3]
12:9; 15:18;
30:17
ashamed [1]
15:6
asking [17]
18:12; 24:3,
16;
32:15,
17;
39:11;
48:18,
19;
53:23,
25;
60:8, 10, 12;
61:20;
62:24;
63:23; 66:14
Assist
[1]
8:11
assist
[4]
9:18,
25;
10:2, 3
associated
[4]
32:5;
45:9,
12;
48:9
assuming [3]
61:10, 12, 15
attention [1]
34:11
attorney [3]
20:15;
72:11, 12
audit
[1]
62:9
audits
[1]
62:7
August [1]
7:22
Ave [1] 1:14
avoid
[1]
31:16
aware
[1]
31:25
- B B [1] 62:25
b [1] 1:7
B-e-t-h [1]
4:12
Bachelor [1]
6:19
back
[11]
10:8,
10;
19:9,
10;
21:25; 22:9,
12;
33:7;
47:15;
57:20; 67:15
background
[1] 6:18
backwards
[1] 5:24
Bad [1] 57:8
bad
[6]
9:25; 56:14;
57:9, 12, 14,
22
baffled [3]
62:20, 22, 25
barrier [3]
44:19; 46:1;
47:18
barriers [1]
42:13
base
[2]
31:19
Based
[1]
28:16
based
[7]
28:19; 29:3;
31:21; 40:9,
12;
43:3;
46:11
Basically [3]
10:7; 16:22;
54:6
basically [3]
30:24; 35:6;
55:7
basis
[3]
25:11; 38:7;
48:25
Battle
[2]
1:15; 4:1
became [1]
7:15
becau
[1]
30:19
Because [2]
8:14; 10:22
because [9]
10:5;
13:7;
14:14;
24:19;
30:17;
52:14;
61:16;
63:13; 71:10
become [2]
9:18; 13:10
before
[7]
1:12;
5:22,
24;
7:2;
14:7; 25:20;
32:10
begin
[5]
13:9;
15:9;
35:21;
37:15; 67:7
beginning
[2]
1:16;
11:3
begins
[1]
21:21
behalf
[8]
2:2, 5, 8;
23:15;
24:24;
28:23; 30:3;
46:14
behind
[2]
37:9, 11
being
[3]
34:11; 47:9;
58:18
believe [6]
5:1;
7:22;
22:6; 41:15;
44:7; 58:4
bent
[4]
42:17; 43:8,
9, 10
besides [6]
28:19; 32:6;
36:11; 47:1;
60:16; 70:9
BETH
[4]
1:12;
4:5;
72:6, 9
Beth
[3]
4:12; 63:10,
16
better
[6]
13:9; 14:16;
21:5; 31:11;
37:15
between [4]
59:10; 61:7,
13; 68:10
big [2] 39:4;
60:13
biller
[1]
6:2
Birds
[4]
22:6;
31:2;
32:6, 24
bit [4] 8:24;
15:9; 21:22;
66:1
blow
[2]
47:24; 48:2
blowing [1]
48:7
blows
[1]
48:4
Bobby
[1]
70:15
body
[8]
9:20;
10:4,
5;
35:7;
37:14,
15,
16; 38:5
Book
[22]
17:5,
6,
8,
11;
18:7;
28:8;
35:3;
51:11; 53:4,
6, 13, 16;
59:3;
63:3;
64:13,
22;
68:19
book
[31]
18:10,
14,
18;
22:5;
28:3, 4, 5, 7;
36:16,
19;
41:8,
22;
42:25; 43:2,
16;
46:6,
10;
48:18;
49:21;
53:14; 59:6,
11,
19;
60:1, 13, 25;
63:4; 64:15,
19
Books
[1]
49:12
books [28]
17:2,
3,
5,
20;
20:5,
17,
18;
23:23;
24:14,
15,
17;
25:25;
27:19,
22;
28:16,
24;
30:11;
46:16,
20;
47:2,
22;
48:21;
49:14;
56:25; 63:1,
20; 65:7
Both
[1]
53:3
both
[1]
12:22
Box
[1]
72:17
box
[2]
35:16, 18
break
[3]
65:13;
66:23; 67:1
brief
[1]
71:3
bring
[2]
47:10; 71:11
BS [1] 6:21
build
[1]
34:1
business [1]
6:21
BY [48] 2:3,
7, 10; 4:16;
5:11;
7:15;
11:3,
15;
17:22; 18:9,
15;
19:4,
10;
20:22;
25:22;
26:19; 28:1;
29:24; 32:2,
23;
39:21;
40:18; 43:7;
45:24;
46:22,
25;
47:15,
18;
48:17;
50:10,
23;
51:11,
22;
52:9,
12;
54:4;
56:2;
58:24; 60:3,
15;
61:7;
62:1; 64:12;
65:18; 66:3,
7, 23; 67:15
by
[19]
1:12;
3:4;
4:20;
7:7;
12:2; 19:18,
20;
40:23;
46:11;
47:12;
53:20;
55:13;
58:18; 59:5,
21;
61:17;
64:13; 65:7,
9
- C C [1] 4:4
CA [1] 2:9
CALHOUN
[1] 1:2
call
[7]
11:21;
16:10;
18:10;
66:15,
17;
68:24; 69:4
called [14]
1:12; 11:21;
14:21; 17:3;
18:10,
17,
24;
33:3;
48:2; 54:25;
59:9;
65:5;
66:16; 68:8
calls
[3]
68:4,
10;
69:21
came [1] 7:2
canaries [1]
31:2
CANDICE [1]
1:3
Candice [12]
17:4;
19:3,
4;
50:12,
13,
14;
53:1;
55:3;
56:15; 57:5;
60:20, 21
cannot
[3]
15:4; 47:22;
65:4
car [1] 71:9
Case [1] 1:6

case
[1]
72:6
Catherine
[1] 2:11
cells
[3]
38:6, 9, 10
CENTER [2]
1:7, 8
Center [18]
4:22;
5:14;
6:9;
7:17;
8:22;
9:2;
22:23;
28:23; 30:3;
54:8;
57:3;
58:8, 10, 17;
59:1; 70:21,
25; 71:2
center
[1]
15:19
certificate
[2] 28:8, 13
certification
[1] 27:15
certification
s [2]
70:9,
11
Certified [1]
1:13
certify
[3]
72:4, 8, 10
chairs
[1]
12:5
changes [1]
59:10
Changing [1]
64:14
characteriza
tion
[1]
47:12
charge
[2]
56:9; 58:24
checkouts
[2]
52:19,
21
child
[1]
65:6
CIRCUIT [1]
1:2
cited
[1]
28:25
Citizen [2]
1:3, 4
classes [1]
60:17
Clay
[1]
51:24
clay
[9]
33:25; 34:1;
51:2, 6, 13,
23; 52:4
clear
[5]
11:23;
39:15;
41:14,
16;
43:21
cleared [2]
42:10; 49:8
clearing [3]
42:6; 52:10,
13
clears
[1]
42:8
client
[1]
32:19
close
[1]
10:11
closed [10]
12:14,
18,
20, 21, 23;
13:13,
17;
16:8; 18:20;
31:5
coaching [2]
52:17, 21
com
[1]
11:18
combative
[1] 22:2
comes
[2]
11:4; 21:22
comfortable
[14]
9:14;
11:18,
23,
25;
12:9;
13:5, 10, 18,
24;
14:4;
22:15,
16,
17; 67:10
coming [1]
9:20
comment [3]
29:18, 21, 22
common [1]
67:16
commonly
[1] 63:15
communicat
e [8] 16:23;
21:5;
31:9,
15;
34:6,
12; 54:11
Communicat
ion [2] 21:7;
49:13
communicati
on
[6]
16:19; 21:8,
14,
21;
30:24; 31:11
communicati
ons
[2]
21:2, 3
company [3]
23:16;
24:24; 46:14
compare [1]
61:20
compel [4]
25:16;
46:10; 64:3,
6
complain [3]
69:16, 19, 22
complete [8]
19:25; 20:7,
12;
27:15;
34:4; 39:21,
25; 72:5
completed
[5]
28:8, 9;
34:15;
39:24; 49:3
concerned
[3]
43:16;
65:6; 69:20
concerns [3]
66:18; 67:8;
68:15
conclusion
[1] 25:20
Conditions
[1] 64:14
confidence
[3] 15:7, 10;
34:7
confident [1]
31:12
confront [6]
12:16; 15:2,
3;
31:12,
15; 54:14
confused [1]
10:13
confusing
[1] 46:7
confusingne
ss [1] 45:13
connected
[1] 70:21
Connersville
[2] 7:5, 6
consist [1]
12:4
consisting
[1] 72:4
constantly
[1] 40:25
consult [1]
44:17
consume [2]
36:4, 7
consumed
[2]
36:10,
13
contact [3]
20:1,
7;
34:8
contained
[1] 36:18
CONTENTS
[1] 3:1
Context [1]
48:1
context [3]
43:10;
45:24; 51:7
conversatio
n [2] 21:12;
70:1
Cool
[1]
35:22
cooperating
[1] 67:24
copies
[1]
49:5
copy
[8]
24:9; 30:15,
16;
46:7;
56:23; 57:4,
6; 59:20
cord
[1]
71:10
core
[1]
69:22
Correct [8]
17:19;
27:21;
28:18;
32:25; 33:2,
5;
37:12;
40:1
correct [8]
17:14;
25:23,
25;
27:20; 53:4;
55:18,
19;
72:5
Counsel [2]
29:19, 23
counsel [4]
32:18;
42:25; 43:2;
47:12
counseling
[1] 15:11
count
[2]
22:13, 14
COUNTY [2]
1:2; 72:2
couple
[1]
8:4
Course [32]
28:1, 2, 8;
32:6; 33:22,
25;
34:4, 5,
25;
38:25;
39:10; 40:2;
43:3, 11, 19;
45:20,
25;
46:11,
17;
47:16,
25;
48:4,
12;
53:11,
19;
59:5, 7, 21;
62:1,
13;
64:22
course [45]
17:23; 18:7,
10,
17;
19:18,
20,
21, 23, 25;
20:12; 21:2,
4;
22:24;
27:13;
28:10; 40:3,
6, 7, 15, 19;
41:6, 14, 21;
42:13;
43:23;
45:21;
46:10; 48:2,
7, 22; 49:3;
51:4; 52:24;
53:9; 58:18;
59:8,
13;
60:9; 61:16;
62:3,
19;
65:22;
68:16; 69:8,
23
courses [13]
19:2,
5,
8,
11, 14, 15;
22:18,
22;
23:8,
23;
27:22; 29:2;
69:16
COURT [1]
1:2
Court
[3]
23:14; 24:10
court
[1]
4:10
cover
[2]
28:16; 42:13
CPR
[1]
70:12
create
[1]
29:10
Creek
[2]
1:15; 4:1
criteria [1]
28:5
CSR-4667 [2]
1:13; 72:16
Current [1]
34:23
current [5]
12:1; 26:12;
27:8;
47:1;
59:4
Currently [2]
5:15; 30:7
currently [7]
27:2, 6, 10;
58:16,
19,
25; 59:4
customizabl
e [3] 29:25;
30:4, 8
customize
[1] 29:5
- D D [2]
1:11;
4:4
d [1] 1:7
D-a-t-u-m [1]
43:15
daily
[1]
48:25
dangerous
[2] 69:20
data
[1]
43:20
Datum
[2]
43:16, 20
datum
[3]
43:15,
21;
44:10
DAVID
[1]
2:4
day
[2]
9:25; 14:2
d a ys
[1]
38:15
deal
[2]
21:13, 15
DEBAY
[1]
1:3
decide
[3]
38:24;
40:21, 22
decided [1]
56:18
decides [4]
28:1; 38:18;
49:3; 56:7
decision [3]
58:1, 3, 5
def
[1]
55:22
Defendant
[2] 2:5, 8
Defendants
[1] 1:9
defined [1]
63:14
definitely [1]
56:12
definition
[3]
41:18;
55:22; 63:15
degree
[2]
6:19; 70:10
demonstrate
d [1] 22:5
dep
[1]
25:19
Department
[2] 56:8, 9
depend [1]
57:23
Depends [4]
22:9; 43:24;
44:4
depends [2]
13:4; 14:3
deponent [2]
46:13; 64:2
deposition
[3]
20:12;
23:21; 72:9
depressed
[2]
9:18;
11:25
described
[1] 60:17
designate
[3]
24:3;
46:17; 63:10
designated
[13]
4:20;
24:24,
25;
27:9; 28:22;
30:2;
39:6,
13,
16;
46:13; 60:4;
61:16; 66:4
designation
[1] 4:24
designation
s [1] 5:6
designee [3]
10:14;
25:17; 46:13
details [1]
60:12
determined
[2] 39:1, 3
determines
[1] 14:10
detox
[2]
37:16; 60:17
detoxes [1]
37:16
detoxificatio
n [1] 54:10
Detoxify [1]
37:14
detoxify [1]
37:14
Dickinson
[2]
1:13;
72:16
dictionary
[10]
41:17,
19,
21;
42:2,
4;
44:3, 11, 13,
16; 45:7
difference
[1] 61:13
differences
[1] 61:7
different
[11]
5:12;
12:12;
26:13;
33:18;
35:19;
38:17; 43:8;
56:5;
59:6;
68:19
difficult [4]
21:13,
19,
22; 67:11
Director [5]
5:17, 18, 20,
25; 8:9
director [1]
15:19
disagree [2]
25:14; 47:11
discovery
[4]
20:11;
23:21; 24:6,
7
discussed
[1] 31:1
d i s p l a ye d
[1] 57:2
divided [2]
20:24; 27:23
doctor
[2]
15:18; 36:22
document
[1] 29:11
documentati
on [1] 6:1
Doing
[2]
44:1; 55:7
doing
[7]
13:18; 56:1,
2;
57:18;
67:9,
14;
68:25
doingness
[5]
43:25;
44:2, 5, 6;
45:15
done
[2]
13:4; 25:25
down
[5]
10:7; 40:25;
66:23; 67:1,
24
Downs
[2]
53:14, 20
Dr [2]
16:4,
6
drill
[6]
22:9, 10, 11,
14; 30:24
drills
[14]
16:11,
12,
20,
21;
21:7,
8;
32:5; 33:22;
45:9,
12;
48:9; 49:18;
65:2
drink
[4]
35:22,
24;
36:1, 2
driver's [1]
4:11
drug
[12]
15:4;
31:9;
35:7,
9;
37:10,
11,
13;
52:5,
10,
13;
54:19; 69:24
Drugs
[1]
31:10
drugs
[6]
9:13; 31:16;
41:2;
54:6;
57:10, 19
duly [2] 4:6;
72:9
During
[1]
41:14
during
[6]
11:15;
13:19;
21:12;
22:24;
35:24; 41:5
duties
[2]
10:23; 65:20
- E E [3]
1:11,
14; 4:4
earlier
[1]
67:20
east [1] 7:7
easy
[1]
22:2
eat [2] 9:23;
14:16
educate [1]
24:7
Education
[11]
8:22;
9:2,
12;
10:14;
46:20;
47:20; 55:1,
17,
20;
56:13, 18
education
[27]
4:24;
5:9;
10:24;
11:16; 23:9;
39:10;
46:18;
48:14; 51:4;
53:22;
57:15; 60:4,
6;
61:17;
63:6,
17;
65:20,
21;
66:8, 10, 11,
13;
68:16;
69:13, 22
Educational
[1] 65:9
educational
[6]
6:18;
11:11;
14:12;
46:25; 57:6;
58:13
effect
[1]
57:14
effectively
[2]
16:23;
34:12
Eight
[1]
18:1
eight
[14]
19:1,
5,
8,
11, 14, 15;
20:23,
25;
26:1; 27:19,
22;
28:24;
47:2
eight-book
[1] 58:25
eight-step
[4]
20:22;
25:23; 30:4,
11
else's
[1]
28:24
Empirical [1]
31:24
empirical [2]
31:21, 25
e m p l o ye e [ 3 ]
23:3; 72:11,
12
e m p l o ym e n t
[2]
22:24;
23:2
encountered
[1] 67:16
end
[2]
11:11
ends
[1]
28:1
enough [2]
34:15; 61:25
ensure
[1]
58:16
ensures [2]
58:15, 17
entail
[1]
11:20
enthused [1]
69:10
entire
[2]
18:17, 18
entitled [1]
23:10
environment
[3]
12:1, 9;
13:11
equally [1]
62:25
established
[1] 61:21
et [1] 1:8
Ethics
[3]
55:17; 56:8,
9
ethics [17]
54:11;
55:15,
20;
56:1,
4,
5,
14;
57:8, 9,
12, 14, 22,
23,
25;
58:4; 59:16,
18
even
[2]
10:20; 61:10
e v e r yb o d y
[1] 19:7
E v e r yb o d y' s
[2] 35:19
evidence [1]
29:11
ex [1] 49:19
exact
[2]
49:19; 55:22
exactly [1]
46:15
EXAMINATIO
N [1] 4:15
Examination
[1] 3:4
examined [1]
4:7
example [8]
22:3; 30:25;
32:10,
24;
33:9,
10;
49:22; 57:8
examples [1]
21:8
except
[1]
67:22
excuse [1]
15:7
exercise [7]
16:8;
42:6;
47:16; 50:5,
10, 20, 24
exercises
[7]
41:4;
49:14,
15,
17, 19; 52:1
exhibit [1]
59:23
exhibits [1]
3:5
exist
[3]
32:3; 52:15;
54:21
experience
[3]
25:11;
69:2, 3
explain [1]
68:20
extensive
[1] 16:19
extremely
[1] 68:3
E ye s
[1]
12:21
e ye s
[17]
12:14,
18,
20,
23;
13:13,
14,
17, 18, 19;
16:8; 18:20;
31:5
- F facility [6]
8:15; 24:17;
26:6, 7, 13;
57:10
facing
[1]
12:6
fact
[1]
35:17
fair
[1]
61:25
familiar [7]
37:18; 38:2;
39:1,
23;
40:2; 62:10
familiarity
[1] 8:18
families [3]
66:15,
16;
67:21
family [16]
7:18,
23;
8:2;
46:24;
63:17;
65:18; 66:3,
13;
67:17;
68:10; 69:1,
4, 6, 9, 11,
14
far
[3]
43:16,
19;
68:19
Fat [1] 38:6
fat [2] 38:9,
10
fault
[1]
64:4
February [1]
7:20
feel
[9]
13:9,
18;
14:16;
35:21;
37:15;
42:17; 43:8,
9, 10
feeling [4]
13:8; 14:15;
67:8, 19
feet
[4]
12:8, 11, 22;
13:22
felt
[1]
43:13
fiance's [1]
7:11
field
[2]
45:15; 69:21
fifteen
[1]
14:1
figure
[4]
9:1;
23:7,
22; 24:23
file [1] 57:6
filing
[1]
64:3
financially
[1] 72:12
find
[2]
41:17; 69:5
fine
[1]
29:12
Finish
[1]
67:5
finish
[2]
25:19; 66:25
finished [3]
28:3;
39:2;
67:22
Firm
[2]
1:14; 72:18
first
[18]
4:6;
12:20;
16:7, 11, 12;
18:10;
21:10,
19,
20;
22:3,
11;
26:6;
41:12;
44:22, 23
Fish
[4]
22:7;
32:6,
11, 24
five
[6]
13:17; 18:3,
4;
35:15,
16; 47:1
five-book [1]
59:1
five-step [1]
30:7
Fly [4] 22:6;
31:3;
32:6,
24
follow
[2]
56:6, 20
follows [1]
4:7
footnotes
[2]
63:20,
22
form
[15]
17:17;
18:11;
31:23;
32:14;
40:16;
45:23; 46:5;
48:16; 50:6;
51:10; 52:6,
11;
58:21;
61:9; 65:23
FORMAN [1]
2:10
forth
[2]
22:10, 12
forward [1]
31:14
foundation
[6]
29:8;
31:13,
23;
40:16;
51:10; 61:9
four
[1]
18:3
frame
[1]
13:6
FREEDOM
[2] 1:7
Freedom
[18]
4:22;
5:14;
6:9;
7:17;
8:22;
9:2;
22:23;
28:23; 30:3;
54:8;
57:2;
58:8, 10, 17;
59:1; 70:21,
25; 71:2
frustrated
[1] 63:25
fully
[1]
44:25
- G G-r-o-s-e [1]
26:22
gain
[1]
15:9
general [6]
57:16; 63:5;
64:9,
10;
67:18; 70:9
Generally [1]
55:25
generally [3]
38:9; 55:24;
63:19
get
[46]
6:14;
7:12;
8:15;
9:21;
10:11;
11:10;
13:25;
14:15,
16;
19:17,
25;
20:7, 13, 16;
21:21,
23,
25;
24:9,
19;
25:13,
17;
30:15,
16,
20;
32:8;
33:7,
12; 34:6, 7;
48:3;
54:6;
56:23,
24;
57:19,
20;
60:1; 67:10;
68:23; 69:5,
8, 9, 10, 13;
71:10
giving
[1]
34:9
goal
[12]
13:12; 14:5,
6;
31:8;
37:9,
11;
42:3,
6;
49:24;
51:25; 52:2;
53:19
goals
[2]
62:13; 64:17
goes
[2]
36:15; 38:24
Good
[1]
55:15
good
[12]
14:15; 16:8;
33:10;
34:15;
39:19; 40:8,
21,
22;
41:1,
2;
54:11; 55:15
got
[6]
17:11; 23:8,
10;
63:19;
66:4; 67:19
grades
[2]
49:2, 5
gradient [14]
13:4; 18:23;
21:11,
17,
18;
33:4, 6,
14,
15;
34:5; 44:20;
45:4, 10
gradients [2]
33:17, 18
Great
[1]
71:12
great
[2]
4:14, 19
Grose
[4]
26:18,
23;
34:24; 58:16
guarantee
[1] 37:5
guess
[5]
7:4;
15:24;
18:7; 50:19;
53:7
guide
[1]
33:7
g u ys
[3]
22:11;
53:11; 59:4
- H H [2] 2:7, 10
half
[2]
57:20; 60:13
handing [1]
59:20
handle
[4]
21:25; 34:7;
54:12, 13
handling [2]
48:12, 15
happens [2]
11:6; 48:4
Happiness
[5]
54:25;
55:6; 64:23,
25; 65:3
happy
[1]
68:3
hard
[1]
21:19
harm
[1]
38:12
harmful [1]
38:3
HARRIS [1]
2:8
Harwood [1]
39:18
HAUSER [1]
2:5
head
[3]
9:17; 42:18,
20
healthy [1]
9:23
heard
[7]
21:12;
37:23; 38:1;
51:7; 52:15,
16; 68:24
held
[1]
72:6
HELER
[1]
2:5
help
[13]
9:14,
17;
10:1;
15:8;
31:14; 42:7;
49:15;
50:18; 54:6;
55:16; 62:1;
67:14
helps
[11]
6:14;
9:21;
10:4; 12:15;
13:10; 40:7;
54:10,
11,
12, 13, 19
here
[11]
5:8, 12, 23;
7:3;
10:25;
17:4; 23:19;
24:7; 49:20;
51:9; 56:16
here's
[1]
28:8
heroin
[1]
9:21
higher
[1]
18:23
history [3]
23:6,
20;
24:22
hold [3] 6:3;
8:3; 70:9
Holmes [2]
16:4, 6
home
[2]
68:24; 69:4
Hon [1] 1:6
honest
[1]
8:25
Honestly [1]
50:16
hope
[1]
55:14
hopefully [1]
31:13
hot
[1]
35:12
hours
[2]
35:15, 16
How
[18]
5:20; 13:22;
14:2; 16:10;
17:22;
19:17;
20:23;
27:22;
35:12,
14,
18;
39:4;
40:20;
42:10; 50:1,
3; 62:5, 17
how
[79]
6:3, 6; 7:23;
8:3;
10:14,
21;
11:11,
13, 18, 22;
13:3,
14;
14:5; 16:10,
22,
23;
17:22; 18:2;
20:23; 21:5,
11, 13, 15,

20, 24, 25;
22:8,
11;
23:8,
10;
24:2, 6, 7;
26:3,
24;
27:22; 28:9;
30:16,
20;
31:8, 9, 15,
20;
32:7;
34:3,
4;
35:11,
18;
38:15,
21,
24;
39:3, 4,
22;
40:8,
20;
42:8;
44:22,
23;
47:19,
20;
49:2;
50:3;
53:17; 54:8,
12,
14;
60:25; 61:1;
64:20;
66:14;
67:19,
23;
68:18, 25
Hubbard [14]
28:17,
20;
29:2; 40:10;
43:4; 46:12;
53:20;
58:18,
25;
59:5,
21;
64:13; 65:8,
10
Hubbard's
[2]
45:21,
25
Hwy [1] 2:6
- I ID [1] 4:10
idea
[12]
10:18;
30:14,
17,
19,
20;
41:24;
44:15,
18;
45:16;
55:11;
56:22; 70:22
immediately
[1] 5:24
implementat
ion
[1]
46:19
important
[4]
46:1;
47:16,
18;
55:17
Improvement
[3]
43:3;
45:25; 46:11
improvement
[7]
17:23;
18:7;
40:3,
5,
7,
19;
45:21
inch
[1]
60:13
inches
[2]
63:20
Income [4]
5:17, 18, 20,
25
increase [1]
13:25
Indiana [2]
6:24; 7:5
Indianapolis
[1] 2:3
individual
[8] 13:4, 24;
22:15; 29:6;
38:17; 44:4;
67:8; 69:5
individual's
[1] 10:4
Individuals
[1] 9:20
individuals
[2]
35:16;
54:6
informed [1]
10:11
INGHAM [1]
72:2
instance
[10]
8:11;
15:4;
21:9;
33:10; 34:9;
40:24; 44:5,
23; 69:7
Instead [1]
24:16
instructed
[1] 47:7
insurance
[1] 6:1
intake
[1]
11:8
Integrity [2]
59:5, 21
integrity [3]
59:7,
13;
62:2
interaction
[1] 9:2
interested
[2]
27:14;
72:13
interpretatio
n [1] 64:20
interrupt [2]
67:1, 3
Into
[1]
20:25
into
[3]
11:4; 21:25;
60:2
involved [8]
14:22;
22:16; 58:3,
6, 8; 66:11;
69:10, 12
involvement
[1] 66:12
issues
[1]
67:13
- J January [1]
8:6
JD [1] 2:10
job [5] 6:4;
7:19;
8:3;
10:23; 65:20
JOHN
[1]
1:3
JONATHAN
[1] 2:3
Jonathan [2]
11:1; 24:6
judge
[3]
34:14,
15;
47:7
judges
[1]
56:2
juice
[1]
71:10
July [1] 8:8
- K KATHLEEN
[1] 2:7
Kathy
[1]
70:7
keep
[2]
42:8; 67:10
keeping [1]
55:8
keeps
[1]
57:6
Keifer
[1]
70:2
kept
[4]
20:3,
5;
23:23; 49:5
kicked
[1]
57:20
KIM [1] 2:8
kind
[19]
11:16; 13:9;
14:20,
24;
15:8; 16:25;
21:6;
33:6,
14,
15;
36:7,
13;
41:4; 49:17;
57:12,
14,
16; 62:12
kindly
[1]
55:15
Kirk
[1]
39:18
KLAUS [90]
2:7;
4:23;
5:3, 5; 7:12;
10:16,
20,
25;
11:8,
13;
17:16,
19;
18:8,
11; 19:3, 9;
20:15; 23:4,
12, 19, 25;
24:5, 9, 14,
21;
25:2, 5,
8, 15, 19;
26:16;
27:24; 29:7,
10, 14, 17,
20;
31:23;
32:14,
20;
39:6, 12, 15,
18,
20;
40:16;
42:24;
45:23; 46:5,
15,
23;
47:6, 10, 13,
17;
48:16;
50:6, 9, 22;
51:10,
20;
52:6,
11;
53:25; 54:3;
55:24;
58:20;
59:22; 60:6,
10,
12;
61:5, 9, 13,
18,
20;
62:22; 63:8,
11, 13, 23;
64:5,
9;
65:15,
23;
66:6, 21, 25;
67:5; 71:9
Klaus
[2]
11:12; 67:4
knew
[1]
30:19
knowledgea
ble [3] 23:9,
13, 17
Kristie
[2]
1:13; 72:16
- L L [18] 1:13;
28:17,
20;
29:2;
40:9;
43:3; 45:21,
24;
46:12;
53:20;
58:18,
25;
59:5,
21;
64:13; 65:7,
9; 72:16
Lansing [1]
72:17
last
[4]
34:4; 35:15;
50:9; 67:24
Later
[1]
67:20
later
[1]
69:8
l a w ye r ' s [ 1 ]
46:6
l a w ye r s [ 1 ]
47:4
leading [1]
41:2
learn
[20]
11:18,
22;
15:2; 16:19;
21:5, 11, 13,
15, 20, 24;
31:14; 32:7;
40:7; 44:23;
54:10,
11,
12,
13;
59:16, 18
learned [1]
44:22
Learning [4]
40:7;
43:2;
45:25; 46:11
learning [14]
16:22,
23;
17:23; 18:6;
27:14;
31:15; 40:2,
5,
19;
41:10,
12;
45:21; 65:6,
7
leave
[2]
8:14; 48:3
Leaving [1]
48:2
left [1] 67:7
legs
[1]
10:10
less
[1]
22:2
Let [1] 51:8
let
[5]
32:19;
42:24; 43:1;
66:25; 67:9
Level
[1]
18:6
level
[1]
33:16
levels
[1]
17:22
liaison [9]
7:18,
23;
46:24;
63:18;
65:19; 66:3,
13;
67:17;
69:14
liaisons [1]
8:2
license [1]
4:12
Life
[3]
53:14,
20;
64:14
life
[7]
31:18; 40:8,
20,
24;
54:13;
55:16; 56:6
Lincoln [1]
1:6
link
[1]
52:13
lists
[1]
49:7
literal
[1]
36:2
literature [2]
16:14; 36:15
LITTLE [107]
2:2, 3;
3:4;
4:9, 14, 16;
5:1, 4, 7, 11;
7:14,
15;
10:13,
18,
22;
11:2, 3,
10,
15;
17:20,
22;
18:9,
15;
19:4,
10;
20:10,
21,
22;
23:7,
18,
21;
24:1, 8, 11,
20,
23;
25:4, 13, 16,
21,
22;
26:19; 28:1;
29:9, 13, 16,
18, 22, 24;
32:2, 18, 23;
39:9, 14, 16,
19,
21;
40:18; 43:1,
7;
45:24;
46:9, 22, 25;
47:9, 11, 14,
15,
18;
48:17;
50:10,
23;
51:11,
22;
52:9,
12;
54:2,
4;
56:2; 58:24;
60:3, 8, 15;
61:6, 7, 12,
15, 19, 23;
62:1,
20;
63:5, 10, 22;
64:1, 8, 12;
65:12,
14,
18;
66:3, 7,
23;
67:3,
15; 71:8, 12
little
[6]
8:23;
15:9;
21:22;
33:23; 66:1;
67:24
LLP [2] 2:2,
8
located [1]
24:17
location [1]
20:18
long
[15]
5:20; 6:3, 6;
7:23;
8:3;
13:3, 18, 22,
24;
14:5;
35:11,
14,
18;
68:18;
71:4
Look
[3]
5:5;
41:17;
63:8
look
[12]
5:4;
12:15;
15:4; 34:10;
40:20; 44:2,
7, 8;
51:9;
59:24; 63:8,
25
looked
[1]
42:2
looks
[2]
43:8, 9
Los [1] 2:9
love
[1]
69:11
loved
[2]
66:18; 68:23
low
[4]
21:10,
17,
18; 33:4
- M MADDIN [1]
2:5
mailing [1]
67:18
main
[2]
26:22; 27:9
makes
[2]
12:8; 57:25
making [2]
11:24; 58:3
man
[1]
6:21
management
[2] 6:20, 21
many
[4]
14:2; 17:22;
38:15; 42:8
Marga
[1]
70:4
Margarita [2]
70:4, 5
marked [2]
3:5; 59:23
Martin
[2]
16:4, 6
mass
[1]
42:15
massage [1]
9:19
materials [8]
16:25;
19:15,
17;
20:1, 8, 13;
54:16; 65:7
matter
[2]
35:17; 42:22
may
[4]
13:17; 34:8;
43:8; 44:25
M a yb e
[3]
5:21; 25:19;
39:7
m a yb e
[5]
10:8;
25:2;
33:23; 64:6;
69:3
meals
[1]
9:23
mean
[23]
10:25; 15:2;
19:3,
9;
21:18;
22:11;
23:24; 24:2;
30:23; 32:3,
10;
40:23;
41:16;
43:15;
44:20;
47:24;
52:15;
54:21;
55:13,
20;
57:17; 60:3
meaning [1]
63:6
means
[5]
42:5,
17;
43:10; 50:7,
9
meant
[1]
43:13
measured
[1] 62:17
Medical [2]
6:5, 6
medical [6]
15:19; 23:6,
20;
24:22;
38:7; 54:18
m e d i c a l l y- s u
pervised [1]
69:23
meditation
[1] 12:25
meet
[1]
70:23
member [2]
69:6, 9
members [2]
30:18; 68:10
memory [2]
51:17, 21
mentioned
[1] 14:18
Meridian [1]
2:2
met
[2]
70:18
metric
[1]
39:25
MI [1] 2:6
MICHIGAN
[2]
1:1;
72:1
Michigan [8]
1:3,
4,
14,
15; 4:1, 11;
24:10; 72:17
mid
[1]
33:16
middle
[1]
33:15
MILLER [2]
2:4; 65:13
mind
[2]
11:23; 61:6
minute
[1]
17:16
minutes [2]
13:17; 14:1
mirror
[1]
63:25
misundersto
od
[10]
45:17,
20;
46:2,
3;
47:19,
21;
48:10,
13,
15; 49:10
mixture [1]
15:1
Mm-hmm
[12]
9:16;
11:5;
12:7,
19;
14:19;
26:20;
32:12; 38:4;
64:8,
24;
66:5; 68:2
modeling [1]
33:25
models [2]
34:1; 51:24
money
[1]
67:23
monitored
[2] 68:4, 11
months [2]
6:8; 8:4
morals
[5]
54:11; 55:8,
15;
59:16,
18
motion [4]
25:16;
46:10; 64:3,
6
move
[7]
13:13;
14:11,
17;
16:17;
18:20; 28:5;
31:14
movie
[1]
55:6
MR
[106]
3:4; 4:9, 14,
16;
5:1, 4,
7, 11; 7:14,
15;
10:13,
18,
22;
11:2, 3, 10,
15;
17:20,
22;
18:9,
15;
19:4,
10;
20:10,
21,
22;
23:7, 18, 21;
24:1, 8, 11,
20,
23;
25:4, 13, 16,
21,
22;
26:19; 28:1;
29:9, 13, 16,
18, 22, 24;
32:2, 18, 23;
39:9, 14, 16,
19,
21;
40:18; 43:1,
7;
45:24;
46:9, 22, 25;
47:9, 11, 14,
15,
18;
48:17;
50:10,
23;
51:11,
22;
52:9,
12;
54:2,
4;
56:2; 58:24;
60:3, 8, 15;
61:6, 7, 12,
15, 19, 23;
62:1,
20;
63:5, 10, 22;

64:1, 8, 12;
65:12,
13,
14,
18;
66:3, 7, 23;
67:3,
15;
71:8, 12
Mr [1] 26:23
MS
[89]
4:23; 5:3, 5;
7:12; 10:16,
20,
25;
11:8,
13;
17:16,
19;
18:8,
11;
19:3,
9;
20:15; 23:4,
12, 19, 25;
24:5, 9, 14,
21;
25:2, 5,
8, 15, 19;
26:16;
27:24; 29:7,
10, 14, 17,
20;
31:23;
32:14,
20;
39:6, 12, 15,
18,
20;
40:16;
42:24;
45:23; 46:5,
15,
23;
47:6, 10, 13,
17;
48:16;
50:6, 9, 22;
51:10,
20;
52:6,
11;
53:25; 54:3;
55:24;
58:20;
59:22; 60:6,
10,
12;
61:5, 9, 13,
18,
20;
62:22; 63:8,
11, 13, 23;
64:5,
9;
65:15,
23;
66:6, 21, 25;
67:5; 71:9
Ms [3] 5:23;
17:24, 25
much-neede
d [1] 9:22
m ys e l f
[1]
64:2
- N N [1] 1:11
name
[3]
4:12,
17;
15:17
named
[1]
70:4
names
[3]
26:15,
17;
27:19
NARCONON
[2] 1:7
Narconon
[56]
4:20,
22;
5:13;
6:9;
7:17;
8:19,
21;
9:2;
11:4;
20:3; 22:23;
28:23; 29:5;
30:3; 34:25;
41:21;
43:10,
19;
47:1, 19, 24;
48:14; 51:3,
11;
52:23;
53:13,
23;
54:8;
55:1,
17,
20;
56:3, 4, 13,
18;
57:2,
15;
58:8,
10, 12, 17;
59:1,
4;
60:5, 7, 16;
61:17; 62:7,
12;
64:22;
65:8,
21;
66:8,
9;
68:16; 70:21
Nather
[1]
70:7
needed [1]
51:20
n e u r o p s yc h o
logical [1]
40:14
never
[6]
10:23; 38:1;
46:16; 61:6;
70:1
new [1] 11:4
NFC
[1]
4:25
night
[1]
67:24
none
[1]
38:8
nonmedical
[1] 6:15
normally [1]
31:10
North
[1]
2:2
Northwester
n [1] 2:6
Notary
[1]
1:14
nothing [1]
32:13
notice
[1]
5:6
November
[2]
7:24;
72:16
nuclear [1]
61:14
Number [12]
43:4, 11, 19;
45:20,
25;
46:11;
47:16,
25;
48:5,
12;
53:13
number [5]
18:19; 21:1;
22:13, 14
nurse
[3]
6:16; 36:25;
37:5
- O O [3]
1:11;
4:4
oath [1] 4:6
object
[2]
17:17; 63:11
objecting [1]
24:18
Objection
[20]
4:23;
18:8,
11;
29:7; 31:23;
32:14;
40:16;
45:23; 46:5;
48:16; 50:6;
51:10,
21;
52:6,
11;
58:20;
59:22; 61:9;
65:23; 66:6
objection [5]
29:7,
20;
50:22;
58:20; 63:9
objections
[2]
5:5;
63:16
objective [3]
49:14, 15, 17
obstacle [2]
34:8; 41:12
obstacles
[1] 41:9
occur
[1]
51:3
October [3]
1:15;
4:2;
72:6
offered [18]
4:21,
25;
5:1;
20:17,
18;
46:18,
21,
24;
47:1;
60:6,
16;
61:17;
63:6, 17, 24;
66:8; 68:16;
69:23
office
[2]
15:20, 22
officer
[2]
57:23, 25
officer's [1]
58:4
often
[4]
9:21;
22:8,
11; 69:4
Oh [5]
7:6;
17:18;
19:18; 35:3;
51:17
Oils
[1]
36:12
oils
[1]
36:13
One
[5]
12:13; 18:3;
24:13;
60:11; 63:12
one
[19]
12:20;
17:21; 18:7,
19;
21:1;
26:22; 27:9;
28:6;
31:2;
34:4; 40:18;
44:24; 50:3;
56:24; 58:5;
62:13;
66:18;
68:23; 70:18
onto
[1]
33:8
open
[6]
12:14,
20;
13:14,
18;
16:8; 31:5
opened [2]
13:20; 18:20
order
[2]
8:13, 14
orders
[3]
8:12,
17;
30:13
Originally
[2] 7:2, 4
originally
[1] 7:2
originated
[2]
33:18;
56:21
outside [1]
58:10
overview [2]
53:25; 54:4
own
[6]
8:15; 54:13;
62:14,
15,
23; 69:10
- P P [1] 1:11
P.O.
[1]
72:17
P67207 [1]
2:7
Page
[2]
3:2; 51:9
pages
[1]
72:5
parent
[1]
65:5
part
[8]
18:21;
31:13; 39:2;
62:7; 66:14;
67:10,
11;
68:20
participate
[2]
22:18,
22
particular
[1] 68:17
partnered
[1] 21:9
parts
[2]
8:23; 66:24
party
[2]
72:11, 12
passing [1]
14:9
past
[2]
11:24; 47:2
patently [1]
24:18
patient [4]
11:4;
23:3;
30:5, 8
PC [1] 2:5
peer
[1]
54:15
penalties [1]
48:7
penultimate
[3]
50:5, 7,
19
People
[3]
9:13;
21:5;
63:18
people [18]
6:14; 12:10,
24;
16:22;
19:17;
21:23;
22:16; 26:7;
31:8; 35:20;
36:22,
25;
37:17; 40:7,
20, 21, 22;
58:8
per
[1]
23:15
percent [1]
69:25
Perception
[1] 49:13
performing
[1] 22:17
period
[2]
14:7; 35:15
person [34]
4:20; 10:14;
11:9;
12:5,
10,
15;
14:4;
23:9,
13, 15, 17;
24:3,
24;
28:22; 30:2;
34:12,
14;
39:6, 8, 11,
12; 41:1, 2;
52:22;
53:24; 58:5,
6;
60:4;
63:1, 2, 3;
64:9, 10
person's [2]
10:7; 68:19
Personal [3]
59:5, 9, 20
personal
[11]
10:11;
23:5,
20;
24:22;
25:11; 59:7,
13; 62:2, 5;
64:20; 69:2
personally
[2]
43:22;
57:17
phase
[2]
16:17, 18
phenomena
[1] 49:10
phone
[2]
68:8; 69:6
p h ys i c a l [ 2 ]
10:9, 10
p h ys i c i a n
[1] 16:1
p h ys i c s [ 1 ]
61:14
pick
[1]
30:18
picture [1]
70:16
Plaintiff [1]
2:2
Plaintiffs [2]
1:5, 12
please
[4]
5:16;
7:13;
27:7; 66:22
point
[7]
10:6; 14:14;
32:8;
34:7;
35:9;
44:8;
67:13
portion [1]
11:12
position [2]
47:5, 7
possibly [1]
9:14
practical [1]
65:2
present [4]
2:11;
12:1;
13:11; 49:1
pretend [1]
21:14
previous [1]
23:2
probably [1]
53:16
problem [2]
31:10
problems [5]
31:12,
15;
54:12, 13, 14
procedure
[1] 48:19
Proceedings
[1] 65:17
process [1]
58:13
produce [2]
63:2, 16
produced [4]
55:10;
62:21; 65:7,
9
production
[1] 62:17
products [1]
8:13
Program [15]
8:19,
22;
9:3,
12;
10:15;
47:20; 55:2,
18,
21;
56:3, 14, 18;
57:15; 65:9
program [78]
4:21,
25;
5:2,
10;
8:23; 11:12,
14;
16:17,
18;
17:24,
25;
18:18;
20:19,
20,
23;
25:9,
11, 12, 23,
24;
26:4, 8,
24;
27:8;
29:24; 30:4,
7;
35:6;
36:16,
20;
38:16,
19;
39:2, 7, 13,
17, 22, 24,
25;
46:18,
19, 20, 23;
47:1; 48:15;
50:12,
13,
14, 17, 25;
53:2, 18, 22;
54:3,
5,
9,
19;
57:18,
21;
58:15,
25;
59:1;
60:15,
16,
24; 61:3, 8;
62:8,
18;
63:17,
18;
64:16;
67:11,
20,
21;
68:21;
69:19
programs [1]
29:6
progressed
[1] 50:4
prohibited
[1] 35:17
properly [1]
58:19
protocol [1]
11:7
prove
[1]
42:10
provided [1]
17:1
Public
[1]
1:14
Purdue [3]
6:20,
23;
70:10
purifi
[1]
37:18
Purificat [1]
37:21
purification
[6]
37:19,
21, 23, 25;
38:1; 61:24
purpose [1]
12:10
pursue [1]
54:24
- Q question
[19]
7:13;
22:3, 4, 8;
24:18; 27:7;
32:21; 33:4,
6,
11,
13,
14,
24;
47:23;
57:17;
60:14;
61:14; 66:1,
22
Questions
[1] 67:8
questions
[19]
10:17;
11:1; 20:19;
23:5; 29:15;
33:19; 39:8;
46:8; 62:25;
63:18,
23;
65:12;
66:17;
67:16,
19,
22;
68:15;
69:13
quick
[1]
65:13
quickly [1]
44:21
Quiet
[1]
12:25
quiet
[1]
12:25
quote
[1]
49:20
quotes
[1]
63:14
- R R [2] 4:4
r-e-e-l-i-n-gn-e-s
[1]
45:3
rate
[1]
69:25
re [1] 21:20
react
[1]
32:8
read
[3]
23:14;
24:10; 62:23
reading [6]
42:7,
25;
43:2;
46:6,
10; 63:20
realizations
[1] 49:16
really [18]
9:19;
13:6;
14:8; 18:13;
22:13;
44:22;
49:18,
23;
53:18; 58:6;
59:12; 60:1;
62:4, 20, 22;
64:17;
67:21; 70:20
recall
[6]
25:7; 26:11;
34:2; 49:10;
64:15; 69:14
receive [2]
28:13; 57:4
recognize
[1] 62:5
record
[9]
20:11;
42:24; 43:1;
46:9; 47:13;
64:13;
65:16;
71:13; 72:5
recorded [2]
68:6, 13
Records [2]
6:5, 6
records [2]
49:7; 68:8
recovery [1]
69:10
reelingness
[3]
45:2, 6,
13
refer
[2]
49:21; 59:19
reference [1]
64:19
referred [1]
51:7
reflect
[2]
42:24; 43:1
refresh [1]
51:17
refreshed
[1] 51:21
regain
[1]
62:2
regarding
[1] 68:16
regards [2]
65:20, 21
rehabilitatio
n [4]
52:5,
10;
54:20;
69:24
relation [1]
66:7
relative [2]
72:10, 11
relax
[2]
9:19; 10:4
relieving [1]
45:12
remember
[40]
7:24;
8:1;
13:6;
15:17;
18:16,
25;
19:22; 27:3,
5,
19;
34:20,
22;
41:7, 9, 11,
13;
42:14,
16;
43:12,
13;
45:5,
11;
48:6, 9,
19;
51:5,
24,
25;
52:3,
7,
8,
18,
20;
53:10,
15,
18;
55:23;
56:16; 67:7;
71:3
repeat
[2]
22:8; 27:7
repercussio
ns
[3]
56:13;
57:11, 22
rephrase [1]
58:23
REPORTER
[4]
4:11;
24:13;
60:11; 63:12
Reporter [1]
1:13
reporter [1]
4:10
request [4]
32:7; 33:24;
62:23; 63:8
research [4]
31:21,
24,
25; 35:8
resistance
[1] 33:23
respect [1]
66:10
respond [2]
21:11, 21
responding
[2]
34:9;
64:5
response [1]
34:13
responsibili
ties
[2]
10:23; 65:21
responsibili
ty [1] 62:15
rest
[2]
9:22; 56:5
restricted
[1] 10:12
restriction
[1] 35:23
resume [1]
65:17
reviews [1]
54:15
Richmond
[1] 7:7
ridiculous
[2]
24:18;
61:14
Right
[7]
18:15; 21:1;
26:15; 31:1;
56:10; 60:8;
61:18
right
[27]
4:19;
5:7,
10,
12;
7:15;
11:2;
12:15;
14:18; 15:5;
17:9; 25:13,
21;
27:18;
29:24; 33:1;
37:10;
39:25;
47:15;
49:23;
51:22; 55:8,
16; 56:1, 3;
61:25; 64:1;
69:6
ritual
[1]
37:19
Robert
[1]
70:2
Rogers [1]
71:5
role
[2]
5:13; 65:18
Ron
[17]
28:17,
20;
29:2;
40:9;
43:3; 45:21,
24;
46:11,
12;
53:20;
58:18,
25;
59:5,
21;
64:13; 65:7,
9
room
[2]
48:22; 69:8
ROTH
[1]
2:5
routine [7]
11:22; 12:2,
3, 4;
14:9;
30:22, 23
rude
[1]
67:2
Rule
[1]
23:14
Rules
[2]
23:14; 24:10
rules
[4]
56:20,
21,
23; 57:2
run
[2]
31:16; 49:14
rundown [5]
37:21,
24,
25;
38:1;
61:24
running [1]
71:10
- S S [2] 1:6, 11
S-a
[1]
26:21
S-c-o-t-t [1]
4:13
SAEED
[1]
2:2
sake
[1]
64:12
Same
[4]
50:22; 52:9;
64:22; 65:1
same
[5]
19:7,
11;
25:9;
37:7;
38:12
Sarah
[1]
1:6
satisfied [1]
28:5
Sauna
[3]
35:2,
6;
68:17
sauna [37]
35:3, 5, 12,
14, 15, 16,
18,
24;
36:1, 2, 5, 8,
10, 13, 15,
16, 20, 23,
25;
37:4,
11;
38:15,
18;
39:2, 4,
7,
13,
17,
21, 24, 25;
54:10,
19;
60:17;
68:17; 69:8,
19
save
[1]
39:7
S a w ye r [ 6 ]
26:18,
19;
34:24;
52:25;
58:15, 16
S a w ye r ' s [ 1 ]
27:16
SCHEPER [1]
2:8
Science [1]
6:19
scientific [1]
35:8
Scientology
[7]
38:1, 2;
44:16; 61:4,
8, 11; 69:17
SCOTT
[4]
1:12;
4:5;
72:6, 9
Scott
[3]
4:12; 63:10,
16
searching
[1] 68:21
second [4]
44:19,
24;
50:9; 51:18
Section [2]
45:25; 48:12
secular [1]
69:23
seemed [2]
67:24; 68:3
separate [2]
41:21; 44:16
series
[3]
17:14, 19, 20
Services [1]
8:10
services [3]
8:4, 5, 7
set
[7]
16:11,
12;
19:25; 20:8,
12;
24:14,
15
shakes [2]
42:18, 20
shampoo [1]
8:12
She [9] 5:3;
10:18; 19:3;
23:23; 24:5;
25:8; 46:24;
51:20; 63:17
she
[30]
5:1, 3, 8;
10:17,
18;
11:13,
14;
15:24;
20:16; 23:8,
10, 18, 22,
24;
24:16,
25; 25:2, 4;
32:21;
51:20;
61:10,
15,
16, 22, 23;
63:19,
24;
66:21
shell
[1]
15:9
Shorthand
[1] 1:13
should
[2]
25:19; 63:1
show
[3]
4:9;
51:8;
55:1
showing [1]
46:7
sic
[4]
12:13; 45:3;
46:12; 53:20
similar [1]
33:23
since
[1]
41:7
sit
[5]
11:22;
12:11;
13:12,
22;
49:20
site
[2]
36:22, 25
sitting
[2]
12:22; 14:6
situation [1]
57:24
sketching
[2] 52:1, 2
sleep
[4]
9:20,
21;
10:6; 14:16
small
[2]
7:9, 10
smoothly [1]
34:6
snarky
[2]
47:8, 9
sneak
[1]
57:10
sneaks [1]
57:19
so-and-so
[1] 68:25
soap
[1]
8:12
sole
[1]
58:4
somebody
[9]
11:4;
37:4; 38:18,
21,
24;
39:23,
24;
57:9, 19
Someone [1]
33:7
someone [7]
28:4;
32:7;
34:9; 35:23;
40:24; 41:1;
46:17
someone's
[1] 34:11
Sometimes
[1] 68:23
sometimes
[2]
10:5;
13:9
sorry
[5]
17:18; 47:4,
6;
50:3;
52:8
sort
[2]
40:7; 45:12
soul
[1]
68:21
Southfield
[1] 2:6
speak [13]
4:20;
5:8;
13:19;
16:22;
23:15; 24:4,
24;
25:1;
28:22; 30:2;
46:13; 60:4;
61:17
speaking [2]
13:1, 2
speaks [1]
47:13
specialist
[4] 6:12, 13,
14; 7:16
Specific [1]
8:23
specific [17]
8:24;
24:1;
32:10,
23;
37:3;
38:9;
42:23;
45:22;
46:16,
20;
59:12;
60:14; 64:7;
65:25; 66:1;
69:13
Specifically
[1] 59:19
specifics [1]
39:5
spell
[1]
69:3
spelled [1]
4:12
spend
[1]
38:15
Spinney [1]
42:21
square
[1]
39:5
squashed [3]
42:19; 43:9,
13
St [2] 2:2
staff
[1]
30:18
Staff-wise
[1] 27:14
start
[13]
5:9;
6:9;
7:19,
21;
8:5;
11:3;
17:25;
19:10;
21:19;
37:15;
57:21; 67:6,
15
started [2]
6:11; 8:4
starts
[3]
11:14;
21:10; 28:2
STATE
[2]
1:1; 72:1
state
[1]
20:10
stated
[2]
27:18, 19
statement
[4]
29:15;
31:20,
21;
69:2
stay
[3]
9:17; 35:14;
54:7
steep
[4]
44:19,
20;
45:3, 9
step
[6]
14:11,
17;
18:21,
24;
21:1; 44:24
steps
[3]
19:1; 20:24,
25
stop [3] 8:7;
47:8; 67:2
stopped [1]
57:18
stored
[1]
38:5
strictly [1]
35:17
Strike
[1]
61:6
strike
[1]
58:16
Student [1]
8:10
student [23]
8:4, 5, 7, 9;
14:1;
28:9;
29:25; 42:8,
10;
43:23,
24;
44:14;
48:4;
49:8;
50:4;
55:3;
56:20,
21,
23;
57:2;
58:13; 65:6;
67:23
student's [2]
57:6; 62:17
students
[19]
8:11;
19:20; 41:5;
45:10; 46:2;
47:20,
21;
48:14,
21,
23;
50:17;
51:1;
57:4;
61:1;
62:1,
7,
13;
64:21; 68:10
studies [3]
40:14;
48:23; 52:12
study
[5]
40:19;
42:13;
48:21; 49:1;
54:18
Subject [1]
63:15
subject [2]
21:24; 34:14
subjective
[1] 43:6
success [3]
52:13;
69:24, 25
suggest [1]
24:9
suggestion
[2]
39:8;
64:6
Suite
[3]
2:2, 6, 9
supervise
[1] 48:23
supervisor
[15]
8:1;
15:13,
16;
19:18,
21,
23;
34:16,
17, 19, 21,
23; 49:1, 4;
52:24; 53:9
supervisors
[1] 19:20
supplements
[1] 36:10
supportive
[1] 40:25
supposed
[2]
24:2;
62:24
Sure
[1]
65:15
sure
[4]
9:22; 32:16;
38:20; 62:16
surprise [1]
20:16
surrounding
[1] 57:24
sweat
[4]
35:6,
9;
37:11, 13
sweated [1]
38:21
sweating [1]
37:10
Swim
[4]
22:7;
32:6,
11, 24
sworn
[1]
72:9
s ym p t o m s
[3]
6:15;
9:15; 14:10
- T T [1] 1:11
TABLE
[1]
3:1
table
[6]
51:2, 6, 13,
23; 52:4
taken
[1]
1:12
taking
[1]
72:8
talk
[18]
4:24;
5:2;
11:1; 12:17;
20:18; 22:1;
25:10; 39:7,
13,
17;
46:17;
52:22; 53:7;
55:24; 63:1,
2, 3
talked
[1]
11:14
talking [2]
5:11; 25:12
talks
[1]
41:9
tangent [1]
33:11
task
[1]
44:21
taught
[4]
55:7, 12, 15;
61:1
teach
[7]
19:17; 46:2;
47:20,
21,
22;
48:14;
62:13
teaching [2]
31:8, 9
technology
[1] 4:21
telephone
[1] 2:9
Tell [1] 10:2
tell
[36]
5:13;
8:21;
9:1, 8; 12:2,
22;
18:6;
20:22; 21:3;
23:23,
24;
30:23; 35:5,
11,
20;
36:19,
20;
40:5; 42:15,
17;
44:4;
46:23;
49:12;
53:22; 59:3,
14;
60:9,
25;
64:13,
18,
25;
65:2; 67:25;
68:2;
69:1;
72:9
ten [1] 14:1
term
[3]
37:19, 20, 23
terms
[3]
47:24;
55:20; 63:14
testified [3]
4:7;
11:13;
64:11
testify
[4]
23:19;
32:19;
62:24; 63:16
t e s t i f yi n g
[1] 47:17
testimony
[1] 72:6
Thank
[2]
29:22; 47:4
thank
[1]
71:8
Thanks [3]
29:13, 16, 18
themselves
[2]
15:7;
49:16
theory
[2]
52:17, 21
thetan
[2]
38:13, 14
T h e y' l l
[1]
12:5
t h e y' v e [ 3 ]
28:4; 42:10;
49:3
thick
[1]
63:21
third
[1]
46:1
Thomas [1]
70:7
thoughts [1]
11:24
three
[8]
12:8, 11, 22;
13:12,
22;
18:3; 20:17;
66:24
Thursday [2]
1:15; 4:2
time
[18]
13:6, 12, 13,
25;
14:6,
14;
16:14;
17:4; 24:13;
35:24; 37:2;
53:9; 60:11;
63:12; 64:2;
67:3,
13;
70:18
times
[4]
13:8;
14:2;
22:13, 14
tired
[2]
10:5, 6
title [5] 6:3;
8:1;
18:14,
16; 70:20
tobacco [1]
8:13
today
[3]
59:1,
11;
66:4
told
[1]
53:16
too [8] 10:6;
21:19;
44:19,
20,
21; 45:3, 9
topic
[3]
33:7,
8;
63:13
tough
[1]
68:22
tox
[1]
38:22
toxins
[8]
35:7,
9;
37:10,
11,
13;
38:3,
12, 22
TR
[3]
30:21; 31:2,
6
track
[1]
42:8
train
[3]
26:14;
27:12, 13
trained [5]
23:8, 10, 22;
26:3, 14
trainer
[1]
27:10
trainers [4]
26:10,
12;
27:1, 8
Training [1]
30:22
training [18]
11:21; 12:2,
3;
14:9;
15:11; 16:7;
22:21;
24:25; 25:3,
6, 10; 26:7;
27:16;
30:23;
51:23; 52:4
trainings [3]
51:3, 6, 13
trains
[1]
27:12
transcript
[1] 72:4
treat
[1]
55:15
TREATMENT
[1] 1:8
treatment
[3]
4:21;
5:2, 9
tries
[1]
33:7
true
[5]
29:17; 37:7;
46:15; 69:1;
72:5
truth
[1]
72:9
try [5] 9:14;
11:18,
23;
46:8; 57:10
t r yi n g [ 1 3 ]
7:24;
8:25;
11:10;
13:25;
14:15;
20:11;
21:23; 23:7,
22;
24:23;
25:17;
29:10; 44:8
turning [1]
48:12
two
[6]
5:11;
12:5,
12;
18:3;
22:16; 49:10
TYLER
[1]
1:3
T yl e r
[15]
5:23;
17:4,
24,
19:3,
50:12,
14;
55:3;
57:5;
21
t yp e
8:12;
34:7;
55:8;
68:3
t yp e s
12:12;
25;
4;
13,
53:1;
56:15;
60:20,
[7]
21:24;
36:7;
59:17;
[2]
33:19
- U ultimate [3]
50:10,
23;
51:25
uncomfortab
le [2]
15:6;
35:21
Understand
[1] 42:5
understand
[8]
18:12;
23:13; 24:6;
32:15; 42:7;
44:25;
45:18; 66:4
understandi
ng
[3]
35:20;
37:14; 64:10
understood
[1] 63:15
Unfortunatel
y [1] 64:16
unfortunatel
y [5]
39:3;
47:22; 51:1;
57:1; 61:2
Unit
[1]
15:13
unit [1] 14:4
University
[1] 6:20
unless
[2]
59:22; 64:19
Until
[1]
7:24
until
[1]
22:15
Ups
[2]
53:13, 19
us
[14]
5:13;
8:21;
10:2;
18:6;
20:22;
35:11;
46:16;
49:12; 55:7,
12,
14;
56:5;
59:3;
64:13
use
[7]
22:6; 41:23,
25;
53:6,
11;
57:10;
59:4
users
[1]
31:9
usually [1]
58:5
- V v [1] 1:6
vague
[1]
63:14
Values
[3]
59:5, 9, 20
values
[3]
59:7,
13;
62:5
varies
[1]
19:24
verbatim [1]
49:20
verify
[1]
28:9
versions [1]
5:12
Very
[2]
7:10; 33:23
very
[10]
10:5, 11, 12;
12:25; 15:5;
21:10;
32:10; 46:7;
55:17; 67:11
Via [1] 2:9
video
[2]
54:25; 55:10
Villanueva
[1] 2:11
vitamins [9]
9:22; 14:18,
20, 21, 23,
24;
36:4, 7,
11
- W W [1] 2:9
W - y- e - r [ 1 ]
26:22
Wait
[1]
66:21
wait
[1]
17:16
want
[13]
20:12;
24:14,
19;
37:13; 39:7;
51:15;
52:22; 53:7;
60:3;
63:2;
64:7; 66:23
wanted [6]
19:25;
30:15;
52:21;
56:23; 63:1
wants
[1]
69:4
wasn't
[4]
5:3;
66:10;
67:8; 71:4
waste
[1]
64:1
water
[4]
35:22,
23;
36:1, 2
Way
[5]
54:25; 55:6;
64:22,
25;
65:3
way
[3]
46:8;
48:2;
57:20
We
[8]
10:10;
11:18;
15:19;
22:13; 39:6;
56:8; 63:11;
64:2
we [24] 5:8,
12; 7:1, 12;
8:13,
17;
10:10;
11:21;
12:12; 13:6;
18:15; 21:9;
25:13;
35:19,
20;
53:6;
63:2;
64:10;
65:13; 67:9,
10, 23
We've
[1]
31:1
Webster [3]
44:11,
13;
45:6
Webster's
[1] 41:22
week
[3]
5:21; 68:24,
25
Well
[27]
5:1, 3, 4, 24;
8:25;
9:24;
11:10;
19:10;
22:11;
23:18; 24:8,
20;
25:2, 4,
5;
27:3;
39:9, 14, 16;
45:24;
47:11;
55:14;
60:20;
65:18;
66:12,
20;
71:8
well
[8]
8:21;
9:1;
13:8;
37:7;
44:23;
56:19;
61:23; 67:9
went
[6]
10:22;
24:25; 25:6,
8;
41:22;
63:5
What's [19]
6:13,
18;
10:2;
11:6;
12:3; 16:18;
18:24; 33:6;
34:4,
25;
41:12;
43:15,
25;
50:4; 53:14;
54:23,
25;
61:13; 67:18
what's [18]
9:1;
14:22;
21:1; 31:16,
17,
20;
34:3,
25;
36:18;
48:18;
49:24;
50:10; 52:2;
59:10;
60:25; 64:18
whatever [2]
61:1; 63:4
whatever's
[1] 10:1
Whenever
[1] 39:1
whether [3]
14:11;
40:21; 57:17
Who's
[3]
19:23;
34:15; 56:9
who's
[4]
23:15;
34:14;
39:16; 40:8
Wiggins [1]
70:15
will
[4]
25:16;
47:10; 61:2;
64:2
WILLIAM [1]
2:10
willing
[2]
67:12
willingness
[1] 67:14
Winchester
[1] 7:11
withdraw [1]
12:13
Withdrawal
[2]
6:14;
15:13
withdrawal
[17]
6:12,
13,
15;
7:16;
9:7,
12,
15;
11:14,
16;
13:7;
14:1,
3, 8, 10, 13,
21, 22
withdrawing
[1] 9:13
without [1]
24:12
WITNESS
[16]
4:8;
17:18;
18:13; 25:7;
26:18;
31:24;
32:16;
40:17; 43:5;
50:8;
52:7;
55:25;
58:23;
59:25;
65:25; 67:6
witness [10]
1:12; 20:13;
42:18,
20;
46:5,
7;
59:20;
62:21,
23;
71:11
witnesses
[1] 47:8
wo [1] 54:8
woman
[1]
70:4
won't
[1]
31:12
word
[21]
42:5,
11;
43:21; 44:2,
10,
13;
45:2, 6, 17,
18,
20;
46:2,
3;
47:19,
21;
48:10,
13,
15; 52:9, 13
words
[8]
41:14,
16;
42:2, 3, 6, 8;
49:8, 10
work
[5]
6:6;
13:5;
20:4; 21:10;
28:24
worked [1]
6:1
works [10]
13:14; 24:6,
7;
28:17,
19;
29:2;
40:9,
12;
43:3; 46:12
workshops
[1] 26:24
worry
[1]
69:9
wrong
[3]
31:16, 17
wrote
[2]
17:8, 13
- X X [1]
13:13
- Y ye a r s
[1]
20:17
yo u ' d
[1]
44:2
You've
[1]
17:11
yo u ' v e
[6]
4:19; 21:12;
25:22;
37:23; 60:16
yo u r s e l f [ 2 ]
22:19; 25:23
Yvonne [1]
71:5

Tyler v. Scientology: Scott Deposition

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Tyler v. Scientology: Scott Deposition

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10/29/15

IN THE CIRCUIT COURT FOR THE COUNTY OF CALHOUN

NARCONON FREEDOM CENTER

Case No.: 15-846-NO

14 and Notary Public for Firm #8453, at 161 E. Michigan Ave.,

15 Battle Creek, Michigan, on Thursday, October 29, 2015,

16 beginning at 1:22 p.m.

On behalf of Plaintiff: SAEED & LITTLE, LLP

On behalf of Defendant: MADDIN, HAUSER, ROTH & HELER, PC

Battle Creek, Michigan

Thursday, October 29, 2015

after having first been duly administered an oath, was

examined and testified as follows:

On behalf of Defendant: SCHEPER KIM & HARRIS, LLP

13 Kristie L. Dickinson, CSR-4667, Certified Shorthand Reporter

Examination by MR. LITTLE

12 of BETH SCOTT, a witness called by Plaintiffs, taken before

CANDICE TYLER, a Michigan

THE WITNESS: I do.

MR. LITTLE: Okay. Ma'am, could you show

license. The name is Beth Ann Scott, spelled B-e-t-h

MR. LITTLE: Okay, great.

And is that -- that's your name, ma'am?

Okay, great. All right, ma'am. So you've been

designated by Narconon as the person to speak about the

technology and the treatment program offered at

Narconon Freedom Center.

designation was. It was to talk about the education

program that's offered at NFC.

MS. KLAUS: Objection. That's not what our

DICKINSON REPORTING, INC.

MR. LITTLE: Well, I believe she was offered

to talk about the treatment program.

Okay. So are we. Where are you from?

Originally, I'm from -- originally or before I came

MS. KLAUS: Well, she wasn't. She was --

MR. LITTLE: Well, let's take a look.

MS. KLAUS: Look at my objections, not your

Oh, okay. Actually, I don't know where Connersville --

MR. LITTLE: All right. You're -- you're

is that out east by Richmond?

saying she can speak about the -- here we go. Let's --

let's start with treatment... Okay, the education

Okay. I do actually know. That's a small place.

program. All right.

(BY MR. LITTLE) I think we're talking about two

My fiance's from Winchester.

different versions of an apple. All right, here we go.

Ma'am, so tell us what your role is at the Narconon

(BY MR. LITTLE) All right. So, after you became a

withdrawal specialist, then what did you do for

Narconon Freedom Center?

I was family liaison.

When did you start that job?

Okay. How long have you been the Director of Income?

Maybe a week or so.

Okay. When in 2011 did you start? Do you know?

What did you do before then?

It was, I believe, August.

When Ms. Tyler was here?

Well, let's go backwards immediately before you were

Until -- I'm trying to remember. It was November 2012.

Then what did you do?

I worked with getting documentation to the insurance