10A28641 2 2012-01-05 DepositionOfStephenAlanKent Ocr

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http://ReachingForTheTippingPoint.net


In The Matter Of:

Desmond, et al. v.

N arconon, et al.

Stephen Alan Kent

January 5, 2012

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Atlanta, GA 30305

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Desmond, et al. v. Narconon, et al.

IN THE STATE COURT OF DEKALB COUNTY STATE OF GEORGIA

PATRICK C. DESMOND AND MARY ) C . DESMOND, INDIVIDUALLY, AND) MARY C. DESMOND, AS ) ADMINISTRATRIX OF THE ESTATE ) OF PATRICK C. DESMOND, )

Plaintiffs, ) ) CIVIL ACTION PILE

vs. ) ) NO. 10A28641-2

NARCONON OF GEORGIA, INC., ) DELGADO DEVELOPMENT, INC., ) SOVEREIGN PLACE, LLC, ) SOVEREIGN PLACE APARTMENT ) MANAGEMENT, INC. , LISA ) CAROLINA ROBBINS, M.D., THE ) ROBBINS GROUP, INC., AND ) NARCONON INTERNATIONAL, )

Defendants. )

Deposition of STEPHEN ALAN KENT, taken

on behalf of the Defendants Narconon, pursuant

to the stipulations contained herein, before

Jo Tornoff Fischer, RMR, CCR No. B- 924, at

1201 Peachtree Street, 400 Colony Square,

Suite 900, Atlanta, Georgia, on January 5,

2012, commencing at the hour of 10:10 a.m.

Q&A REPORTING SERVICES, INC. Certified Court Reporters 2165 Fairhaven Circle, NE

Atlanta, GA 30305 404.233.3300 ** (Fax) 404.233 . 1530

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1 APPEARANCES OF COUNSEL

2 ON BEHALF OF THE PLAINTIFFS:

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REBECCA FRANKLIN, ESQ. Franklin Law, LLC 400 Colony Square, Suite 900 1 201 Peacht ree Street, NE Atlanta, GA 30361 (404) 961-5333

ON BEHALF OF THE DEFENDANTS NARCONON OF GEORGIA and NARCONON INTERNATIONAL:

STBVAN A. MILLER, ESQ. BARBARA A. MARSCHALK, ESQ. Drew, Eckl & Farnham, LLP 880 West Peachtree Street P.O. Box 7600 Atlanta, GA 30357 (404) 885-1400

ON BEHALF OF THB DEFENDANT NARCONON INTERNATIONAL:

HELENA K. KOBRIN, ESQ. Moxon & Kobrin Suite 900 3055 Wilshire Blvd. Los Angeles, CA 90010 (2 13) 487-4468

ON BEHALF OF THE DEFENDANT DELGADO DEVELOPMENT:

SEAN L. HYNES, ESQ. Downey & Cleveland, LLP 288 Washington Avenue Marietta, GA 30060 (770) 422-3233

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Stephen Alan Kent January 5, 2012

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ON BEHALF OF THE DBFBNDANTS LISA CAROLINA ROBBINS, M.D. and THE ROBBINS GROUP, INC.:

JEFFREY N. AMASON, ESQ. Weinberg, Wheeler, Hudgins, Gunn & Dial, LLC Suite 2400 3344 Peachtree Road Atlanta, GA 30326 (404) 876 - 2700

INDEX TO EXAMINATION

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2 By Mr. Miller.

3 By Mr. Hynes

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4 By Ms. Franklin .

5 By Mr. Miller.

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DEFENDANTS' EXHIBIT

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INDEX TO EXHIBITS

DESCRIPTION PAGE

S. Kent CV 8

c~~~~~!ies~~t~~Io~ ~~n~a~!~~a{s re Work in Desmond Case (NP-Kent-0737 - 0907) 8

Composite Exhibit - Kent File Materials Not Reviewed: Document Productions/Depositions/ Discovery Responses 8

12-12 - 11 Letter from R. Franklin to K. Whitlock I Supplemental Expert Disclosures 8

Plaintiffs' Expert Disclosures 8

Chart of Lawsui ts Involving Narconon

IRS/Sc i entology Settlement Agreement (NP - Kent - 0838 - 0896)

Photocopies I Front Covers of Books Used in Narconon Courses

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Photocopy I "The Scientology Handbook" {NP-Kent-0759 - 0767)

nNarconon News•• {NP-Kent-0835 - 0837)

"Purification: An Illustrated Answer to Drugs • {NP-Kent - 0768 - 0773)

Book 6 I "Personal Values and Integrity Course•

Marburg Journal Art icle I "Alternative Therapy, Dianetics, and Scientology" {NP-Kent-0737 - 0758)

Composite Exhibit Narconon Info {NP-Kent-0774 - 0797)

"The Narconon Rehabilitation Program• - Article by W. Benitez {NP-Kent-0798 - 080 1)

"Celebrity• Article I How the Purifica t i on Rundown Works 11

{NP-Kent - 0802 - 0808)

Scientol ogy Submission to IRS {NP-Kent-0809 - 0820)

Composite Exhibit re NarcononiScientology {NP-Kent-0821 - 0834)

Narconon Drug Rehabilitation Program Information {NP-Kent-0901 - 0907)

USA vs. M.S. Hubbard I ;:~~l~~l:r;~ Informal Bill of

{NP-Kent-0897 - 0900)

Book l I "Therapeutic TR Course•

Book 3 I "Learning Improvement Course•

Book 4a I "Communication and Perception Course"

Book 5 I "Ups & Downs in Life Course"

Book 7 I •changing Conditions in Life Cour se•

Book 8 I "The Way to Happiness Course"

Listing of Scientology Articles from Kent Web Site

N. Williams vs . T. Lowery I Deposition of S. Kent

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{Original Defendants• Exhibits 12 and 21 - 26 were retained by Ms. Franklin.)

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{THE FOLLOWING TRANSCRIPT CONTAINS QUOTED MATERIAL; SUCH MATERIAL I S REPRODUCED AS READ OR SPOKEN.)

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{IN THE FOLLOWING TRANSCRIPT, A DASH [ -- ) IS USED TO INDICATE AN UNINTENTIONAL OR PURPOSEFUL INTERRUPTION OF A SENTENCE; AN ELLIPSIS [ .•• ) IS USED TO INDICATE HALTING SPEECH OR AN UNFINISHED SENTENCE IN DIALOGUE, OR AN OMISSION OF WORD[S) WHEN READING WRITTEN MATERIAL.)

(Thereupon , the court reporter disclosed that she was there on behalf of Q & A Reporting Services, Inc. In compliance with Article lO.B of the Rules and Regul ations of the Board of Court Reporting of the Judi cial Council of Georgia and O.C. G.A. l5-l4-37{a) and {b), the court reporter d iscloses that she was retained by StevanA . Miller, Esq. , t o take down the proceedings . Q & A Reporting Services, Inc. will charge the attorneys t he usual and customary rate for the transcript, and will be paid by the attorneys upon their receipt of the transcript.)

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(Thereupon, marked for identification purposes, Defendants' Exhibit Nos. 1 through 6.)

MR. MILLER: This will be the deposition of Dr. Stephen Kent, taken by the defendants for purposes of discovery only. I realize that you may -- well, I'm just going to say we want to take this for purposes of discovery only. It's being taken at this time and place pursuant to agreement of counsel, with waiver of all formalities with respect to the time and place of taking the deposition. And we can agree, 1 believe, to reserve all objections except as to the fonn of the question until such time as the deposition might be used for some purpose.

MS. FRANKLIN: We can agree to that. We don't agree to the deposition being taken just for purpose of discovery; we would ask the deposition be taken for all purposes allowed under the Georgia Civil Practice Act. But with that, everything else we can agree to.

MR. MILLER: Okay. And how about signature?

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Desmond, ct al. v. Narcooon, et al.

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1 MS. FRANKLIN: He's going to read and 2 sign. 3 MR. MILLER: And we'll stipulate he can 4 do that in front of any notary public. 5 MS. FRANKLIN: Yes. 6 MR. MILLER: Dr. Kent, my name is Steve 7 Miller, and here in a moment the court 8 rep01ter is going to swear you in and we'll 9 ask you some questions.

10 (Discussion off the record.) 11 STEPHEN ALAN KENT, 12 having first duly affirmed, was examined and 1 3 testified as follows: 14 EXAMINATION 15 BY MR. MILLER: 16 Q. Dr. Kent, my name is Steve Miller; I represent 1 7 Narconon of Georgia and Narconon International in a 18 lawsuit that's been filed here in Georgia. And my 19 understanding is that you've been designated as an 20 expert witness in this lawsuit; is that your 21 understanding? 22 A. That's my understanding, yes. 23 Q. And my purpose here today is to find out all 24 of the opinions that you might come to court to testify 25 about. Do you understand that?

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1 A. I do. 2 Q. And I also want to fmd out the basis for all 3 those opinions. 4 A. I understand. 5 Q. And if I ask you a question in an inartful 6 way, I would appreciate it if you would let me know. 7 A. I understand. 8 Q. So if you answer my question, I'm going to 9 assume that you've understood my question; is that fair?

10 A. That's fair. 11 Q. And we can take a break anytime you would 12 like. 13 Why don't we go ahead and have you just tell 14 us your full name, where you live, and how old you are. 15 A. Okay. My name is Stephen, S-T-E-P-H-E-N, 1 6 Alan, A-L-A-N, Kent, K-E-N-T. And I live in Edmonton, 17 Alberta, Canada, and I'm 60 years old. 18 Q. And are you a Canadian citizen? 19 A. Dual citizen. 20 Q. With Canada and ... ? 21 A. And U.S. Canada and U.S. 22 Q. We've marked as Exhibit 1 to your deposition 23 what's been provided to us as your CV. Could you 24 confirm that for us? 25 A. Yes, sir, that's my CV.

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Q. A.


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And is it current and up to date? Yes. I don't believe any articles have come

out since the last one I've got listed, number 43. I don't think anything else has come out in print since then, so, as far as I know, it's up to date .

Q. And we've been provided with Exhibit 2, which l S --

A. All right. Q. --my understanding of your file materials

conceming your work on this case? A. Yes. These are some initial submissions that

I -- that I made. Right. Uh-huh (affirmative). Everything looks ... I'm just astonished how much paper court cases

take. Yeah, this looks like -- this is certainly what I submitted. I haven't seen anything omitted so far.

Q. Well, I will represent to you that I tried to print out everything --

A. Sure. I understand. Q. --that was E-mailed to us. A. Sure. Q. But let me know ifthere's any reason--A. Okay. Q. -- you think that's not your complete file

materials on this case.

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A. Hmrn. Uh-huh (affirmative). Almost at the end. It looks -- it looks fine

so far. Looks fine. And, sir, what's "NP" mean, down

at the bottom? Q. I'll explain that right now. Exhibit 2 has

been m arked with what we call Bates numbers? A. Uh-huh (affirmative). Q. And so it's Kent-0737 through Kent-0907.

That's just a way for us --A. Sure. Q. --to, in--A. Sure. Q. -- effect, you know, reference certain pages

in here. A. Sure. Q. So Exhibit 2 is your complete file materials

on this matter? A. lt looks like it. And "NP," what does that

mean? I'm just curious; I don't know. Q. Non-party. A. Okay. Thank you. Sorry to ... Q. No. No problem. You said that was your

"initial submission." Would that have been an initial submission of information that yo u sent to the

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http://ReachingForTheTTipii pingPoint.net

Desmond, et al. v. Narconon, et at.

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1 plaintiffs' lawyers in this case? 2 A. That's right, yes. 3 Q. Have you sent them anything else? 4 A. No. 5 Q. Any other file materials that you've generated 6 on this case? 7 A. No. B Q. Have you consulted any documents that are not 9 contained in Exhibit 2 in order to reach your opinions?

10 A. I've looked at all of the Narconon course pack 11 materials that plaintiffs have. 12 And then I've done, you know, background 13 research material on different aspects ofNarconon, back 14 in files that are at the university. But in terms of 15 this particular -- this particular case, it's those 16 Narconon books. That-- I think copyright 2004. 17 Q. Okay. So let me be clear. In terms of 18 specific documents that you've referenced to reach your 19 opinions in this case, it would be Exhibit 2 and what 20 you describe as the course pack materials for Narconon? 21 A. That's right. And then reference from the 22 course pack material back to Scientology documents. 23 Q. What Scientology documents are you talking 24 about? 25 A. Well, the simple way is to look at Scientology

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1 web sites. So I would find documents and mentions of 2 terms, for example, say, "suppressant person," and then 3 go to the Scientology web site and see if on the 4 Scientology web site a term like that exists. And in 5 all the instances of the terms that I identified as 6 crucial in this case, I found them all on Scientology 7 web sites, and then previously, when I've looked at B another Narconon case, or-- or earlier pack, not this 9 one, in documents back at the University.

10 So, for example, there's a course pack on the 11 TRs that I've looked at. But the TRs are mentioned--at 12 least, TR 1 through 4 is mentioned--on the Scientology 13 web page. So that's the sin1plest place to go. And I 14 cettainly went there to verify these terms. That these 15 terms are from Scientology. 1 6 Q. Do you have any notes from your review of the 17 course pack materials? 18 A. No. 19 Q. Nothing on a computer someplace about --20 A. No. 21 Q. -- you made --22 A. No. 23 Q. Okay. Give me the complete list of the terms 24 that you found in the course pack materials that you 25 thought were significant.

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A. I can do my best by memory. Now, it would be useful if I had the course packs here. I don't know if that's appropriate. If I do it by memory, I'm certainly going to forget some things.

Q. Well, we're here, as you !mow, to find out all of your opinions, --

A. Sure. Q. -- and the basis for all of your opinions, so

I want for you to be as complete as you possibly can be. A. Uh-huh (affirmative). Q. But give me that .list as completely as you can

right now. A . Okay. And I'll do so with the understanding

that I may forget something. MS. FRANKLIN: Did you bring the course

packs? THE WITNESS: The course pack's here.

BY MR. MILLER: Q. Okay. A. Do you want to -- if we can get them, it would

certainly reduce the mistakes I might make or the omissions I might make.

Q. Okay. Have you tabbed them in some way? A. No. I think I've put in two tabs in the

course packs. But it's pretty easy to look at them and

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know what's in them. Q. Well, let's do this. Let me get your list off

the top of your head now, and then we'll come back to the course pack materials a little bit later in the deposition.

A. If that's -- as long as we come back to them, that's -- that's fine.

An initial course pack has to do with training routines. And in this case it's TR, for training routines, 1 through 4, and then 8 through -- I'm sorry, there's no TR5, as near as I can tell. And then TR6 to 9, although 9 seems to be repetition ofTR6. So in essence there are -- the pack has nine TRs, but there's actually only eight -- eight ones. Number 2 is --refers to the "Purification Rundown." And that book isn't here, so I had to look at other PUiification Rundown materials. But I've known about the Purification Rundown for years, so ...

Number 3 I believe is a pack about learning how to learn. So banicrs to learning, attitudes that a student might have that he or she knows everything ahead of time. Three banicrs to leaming, one involving doing modeling. Often clay modeling, but even using items--paper clips and pencils and so on-- erasers--to give mass -- well, it's to give mass --mass to an

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1 object, as it's called. 2 Second problems to learning involves what's 3 called too steep a gradient. So a person gets exposed 4 to infonnation too -- that's above his or her learning 5 level. So information is too complicated for the 6 person. "Too steep a gradient" is the term. 7 Then third is what's called "misunderstood 8 word." And "misunderstood word" is a cmcial concept in 9 Scientology. The argument is that if a person reacts

10 badly to a course, doesn't like the course, gets bored, ll gets angry, it's almost certainly because be or she went 12 past a word that he or she did not understand. So it's 13 a misunderstood. So it's emphasis about always looking 14 up misunderstood words in a dictionary. 15 Now, 4, if I remember correctly, is-- there 16 are two books, there's 4a and 4b. 4a, if I'm not 17 mistaken, is essentially a repeat of the TR course. And 18 then 4b is an examination or a use of things called 19 "objectives." Objectives, at least as I see them, 20 are -- well, they're similar to some things that come up 21 in the TRs, but they're also similar to what's called 22 "locationals," Hubbard's -- L. Ron Hubbard's assumption 23 was that people can get focused on events, negative 24 events, in their past. And these locational -- or, 25 these objectives, bring a person up into what's called

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1 present time. So they'll be corrunands to a person, you 2 know, to look at a wall and touch a wall, look at a 3 comer, on -- and touch a desk, and so on. 4 Q. Let me stop you just a minute. Who is L. Ron 5 Hubbard? 6 A. Oh. L. Ron Hubbard is the founder of both 7 Dianetics and Scientology, and he's the inspiration for 8 the materials in these -- all the course packs are based 9 upon the works of L. Ron Hubbard.

10 Q. And is that fairly common knowledge, tl1at 11 L. Ron Hubbard was the founder of the Church of 12 Scientology? 13 A. You know, I'm always surprised how many people 14 don't know that. You know, because I've worked in it 15 through the years so much I assume it's widely known, 16 but I just run into people who don't know. So I 17 can't-- you'd think with the amount of publicity that 18 it would be widely known, but I can't say that it is. I 19 think a lot of people really don't know. 20 Q. But certainly it's out in the general body of 21 knowledge that people might have? 22 A. People might have it. I just don't know if 23 they do. 24 Q. Have you done any sort of studies in terms of 25 name recognition to see what percentage of people--you

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know, adults--would recognize that L. Ron Hubbard was the founder of the Church --

A. No. Q. -- of Scientology? A. No, I'm talking about any name recognition.

So--Q. Certainly easy to determine in this Internet

age, if you wanted to? A. If you typed in "L. Ron Hubbard," you'd get

"Scientology" at some point. Q. Okay. I intcnupted you; go ahead. A. No, that's all right. 5 --I could get 5 and

6, the books, mixed up. One is the "Ups & Downs of Life Course," and that's a straight recitation of Scientology concepts about social personalities, antisocial personalities and potential trouble sources. And these are standard Scientology terms you can find many places. There's even a course that Scientologists can take.

Next is -- and again, knowing that I could be switching 5 and 6, next is a course on values. And this is a Narconon course, really based upon -- I think it's called the "Personal Integrity and Values Course" in Scientology. And it gives forward to a person a number of precepts or values that L. Ron Hubbard thought were important.

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6, let me see what 6 is. I'm blanking on 6. 7 is "The Way to Happiness." Which is a 21 --21 numbered set of precepts about what Hubbard thought were important. Similar to, you know, do not kill, do not... You know, honor governments if they respect people, and so on and so on. And these are straight out of"The Way to Happiness" book, published by Scientology for Hubbard.

Now, the one that I'm missing, it's a person -- let's see, the values... I'd have to -- if I -- oh, oh, oh, oh, oh, oh. No, it's not the objectives.

Ifl saw the -- if I saw the... Oh, um ... It'll come. I j ust can't remember. There's one that I'm missing. And if I saw the book I could tell you. It may in fact -- if it comes to me, I'll come back and correct this.

Q. Okay. Well, we'll come back to the books, but what I'm unclear on is, did you have to go and do research in connection with reaching your opinions in this case, to look at these books and say that there arc Scientology type concepts in the books?

A. Well, I knew from previous research on Narconon and Narconon cases that these are Scientology books. So when I actually got ahold of this particular

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1 case it was very easy go through them again and say, 2 "Oh, yeah. Oh, yeah, I recognize this. This is where 3 it comes from." So that was-- that was simple. 4 Q. Did you have a set of the books in Canada? 5 A. Not of-- not from this program, no. 6 Q. So I assume that the set of books you looked 7 at were provided to you by plaintiffs' counsel? 8 A. The set of books for this -- for this program, 9 for Georgia, yes.

10 Q. And when did you receive that set of books? 11 A. Yesterday.

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1 A. Jeff Harris. 2 Q. Anybody else on the call? 3 A. I'm not sure; I know at some -- at some point 4 I had spoken to Rebecca. I'm not sure whether it was a 5 conference call or not. 6 Q. Have you talked to anybody in reaching your 7 opinions in this case other than Jeff Harris or Rebecca? 8 A. No. 9

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Q. You haven't talked to any of the witnesses in this case?

A. No. No. 12 Q. Other than looking at that set ofbooks 12 Q. You mentioned that you had worked on a another 13 yesterday and just confmning on the Internet some l3 Narconon case. 14 things, -- 14 A. No, there's -- well, it wasn't a case, no; it 15 A. Uh-huh (affim1ative). 15 was just the course-- the course pack. I mean, 16 Q. --anything else you've consulted, outside of 16 Narconon's been an interest, well, for a long time, 17 your Exhibit 2? 17 'cause it's part of Scientology. 18 A. As I say, I consulted a previous Narconon pack 18 Q. So you have not had any other claim where you 19 from Chilocco, Oklahoma. If you'll notice, these books 19 did any sort of legal consulting involving Narconon? 20 are copyright I think 1991 and 2004. The course pack 20 A. As far as I can recall, no. 21 that I had looked through was 2001. And it didn't have 21 Q. Let me show you Exhibit 3, which was a 22 the-- you know, the one booklet that the 2001 didn't 22 document that was--23 have was "The Way to Happiness." 23 A. Yes. 24 Q. And when did you consult that Oklahoma course 24 Q. --supplied to us. And based on the 25 pack? 25 discussion we had at the beginning of the deposition, my

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1 A. When I was back in Canada. And I've had -- 1 understanding is that, whether you were or were not 2 you know, I've looked at it on and off for years, 'cause 2 provided with any of the documents on Exhibit 3, you 3 the university's had it for a long time. 3 have not consulted them in order to reach your opinions 4 Q. Did you specifically go and pull it out for 4 in this case? 5 this case? 5 A. That's right. I've not consulted -- I've not 6 A. Yes. 6 formed my opinion based upon any of -- any material 7 Q. When were you first contacted about this case? 7 here. And I-- I didn't even think I've seen the a A. Geez. I'm --I can't tell you exactly. I'm 8 depositions here. As 1 say, I've got a CD-ROM which I 9 going to say probably November. 9 just assumed was repeats of Mary Rieser's, and I never

10 Q. Of 2011? 10 opened it. And then when I got my instructions, I 11 A. Of -- that's right, yes. 11 thought it really didn't matter what other people said 12 Q. Do you remember what part of the month? 12 in the depositions. This was just going to be exh·a, l3 A. Oh, I can't -- I can't tell you. I really 13 unnecessmy work. So I didn't use anything on here to 14 can't tell you. 14 form my opinion. 15 Q. Do you have billing records? 15 Q. Prior to yesterday, when I assume you came to 16 A. Back in Canada I've got-- I've got some. We 16 Atlanta and met with the plaintiffs' lawyers, --17 could look at the dates of when I got served that-- 17 A. Uh-huh (affirmative). 18 that document about what I was going to testify. 18 Q. --is that correct? 19 Q. How would we be able to tell from that 19 A. That's right. I was in the night before, but, 20 document when you were contacted? 20 yes, came -- we met yesterday. 21 A. Well, that-- that would give you at least one 21 Q. How long did you meet yesterday? 22 figure. I was contacted before then, I guess is what 22 A. 10:00 to about 3:30. 23 I'm saying. But I don't know that 1 can tell you in any 23 Q. And that's when you looked at the course pack 24 way when I first got the phone call. 24 materials for Narconon of Georgia? 25 Q. And who called you? 25 A. I took them home last night.

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1 Q. So it wasn't until last night that you looked 2 at the course pack material? 3 A. I started about 4:30. 4 Q. And how long did it take for you to go through 5 them? 6 A. Went up to-- I took a break for dinner, but 7 went up to about 11:00, and then fmished up one this 8

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morning. Q. How much time did you spend this morning? A. 20 minutes, half hour. Q. And it was during the course of doing that

that you went onto the Internet to just double-check that some of these were Scientology type principles?

A. Well, I knew they were. They're such basic 15 principles of Scientology that they're really everywhere 16 in the literature. I just got curious in tenns -- for

availability, to see if they were on the Internet, and there they were.

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Q. Before yesterday when you were -A. Yes. Q. --reviewing these materials, how much time

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1 two hours, because, again, I had to make the nip tvvice. 2 Going through the documents, the Chilocco, 3 Oklahoma, it's at least six hours. 4 Q. Okay. So approximately eight hours prior to 5 yesterday? 6 A. More like ten. At least. 7

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Q. Did anybody else help you do any of this work? A. I don't think so. 1 think I did all the

9 collections. I think I pulled all the documents myself, 10 as far as I can remember. 11 Q. Would that approximately ten hours also 12 include the time you spent talking on the telephone to 13 the plaintiffs' lawyers? 14 A. No. I didn't-- no, 1 didn't factor that in 15 at all. 1 6 Q. Have you provided them with any summa1y of 17 your opinions in writing, E-mails, anything like that? 18 A. No. 19 Q. Let me show you what's been marked as

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20 Exhibit 4, which is the Jetter we received disclosing 21 the areas where you're going to offer expert opinion,

and ask you to look at that letter and tell me if that is a fair statement of all of the areas that you're going to offer expert opinions in in this case.

23 A. A-- well, I can't-- I haven't added up 23

24 hours, but I-- I spent enough time going -- collecting 24

2 5 materials from files, which would have been a couple of 2 5 A. " .. . provide testimony at n·ial outlining the

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1 hours. Getting -- going through those files and pulling 2 out the materials that I sent down. And that took a bit 3 longer, because I drove to FedEx and FedEx was closed 4 that day, so I had to go back a second day. It's the 5 holidays, and things are a bit screwed up. Then I spent 6 several nights going through the -- the Narconon 7 Chilocco booklets, and just to see, you know, to see 8 where that material came from. 9 Q. Okay. I'm just trying to find out the total

10 number of hours you've spent working on this--11 A. Yeah. 1 have--12 Q. --before yesterday. 13 A. I haven't even added them up, sir; I couldn't 14 tell you. 1 5 Q. Can you give me your best estimate? 16 Actually, don't write on the back of that.

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1 beliefs and practices of members ... Scientology"; if I 2 get asked, yes. Number 2, " ... the vast majority of 3 Narconon of Georgia's training materials and course 4 exercises are based prima1ily on the principles of the 5 Church of Scientology." Yes. " ... testify ... Narconon 6 International's corporate structure and explain how 7 Narconon International and Narconon of Georgia are a connected to the Church of Scientology." I can't say 9 much about number 3, I can say, you know, a little.

10 But ... ll

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Q. Okay. And I'll come back and ask you some specific questions.

A. Sure. 14 Q. Is there anything else you're going to offer 1 5 an opinion on, that's not set out here in Exhibit 4? 16 A. I don't intend to.

1 7 I'll give you a blank piece of paper. 17 Q. Going back to your CV for just a minute, let 1 8 A. Okay, thanks. 18 me ask you a few questions about your background. 1 9 I'm going to -- again, this is from-- from 19 I'll tell you, before I do that, Dr. Kent, let 20 memory, but two in terms of collecting files-- 20 me ask you to look at Exhibit 5, which was an earlier 21 Q. And that would be the Exhibit 2 materials? 21 disclosure we got about your opinions. And I believe 22 A. More than that. And I had a large amount of 22 there's nothing in there that's not consistent with what 23 material-- probably-- that I had to go through and 23 you have identified to us as your expert opinions that 24 weed out. And so the weeding out -- and I'll include 24 you're going to testify about in Exhibit No.2? Or, 2 5 that with sending. And this will be lowball, I'll say 25 excuse me, Exhibit No. 4? But I just want to make sure.

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1 A. Uh-huh (affirmative). Well, it's a bit 1

2 different. I hadn't planned to talk about student and 2

3 staff interactions, and that's mentioned in here. 3

4 Q. Okay. I just wanted to confirm-- 4

5 A. Sure. 5

6 Q. --you're not going to talk about student and 6

7 staff interactions -- 7

a A. Yeah. 8

9 Q. --in the Narconon of Georgia program. 9

10 A. Yeah. That-- you know, I'd rather stick to 10

11 the December 12th. And then "Narconon International's 11

12 oversight," as much as 1 can say, I'll say number 3 12

13 here, it's not a-- that's not a major focus of my -- of 13

14 my intentions. 14

15 Q. Maybe I can speed this up. Can we rely upon 15

16 what's in Exhibit 4 as -- 16

17 A. Oh, yes. 17

18 Q. --the complete universe of the opinions 18

19 you're going to give in this case? 19

20 A. Yes, sir. 20

21 Q. And to the extent Exhibit No.5 may have 21

22 anything in it that's not in Exhibit No.4, we can 22

23 ignore that? 23

24 A . Yes. 24

25 Q. Okay. Going back to your CV. It looks like 25

Page 30

1 you got your undergraduate degree at the University of 1

2 Maryland in sociology? 2

3 A. That's correct. 3

4 Q. And then it looks like you were out of school 4

5 for a couple years? 5

6 A. Two years. 6

7 Q. What did you do during that period of time? 7

8 A. Looked for jobs, worked as a cook, was a 8

9 counselor for handicapped. So I think those three 9

10 things. 10

11 Q. And then in 1975 you went back to graduate 11

12 school in religion? 12

13 A. That's right. I -- it was the department of I 13

14 think philosophy and religion, but my -- I was in the 14

15 religion side ofthe department. 15

16 Q. It looks like you've got two master's degrees 16

17 in religion, and then a Ph.D. in religion? 17

18 A. Yes, sir. Two master's is just bad planning 18

19 on my part, but it's true. 19

20 Q. Why two master's? 20

21 A. Changed schools, changed area of focus. 21

22 You'll notice the first M.A., the focus was "Histmy of 22

23 religions--Hinduism," and in order to go on to Hinduism 23

24 I would have had to do ex -- I'd studied Hindi for two 24

25 years, and I'd've had to go into San -- and study 25


Page 31

Sanskrit. And I started it, but just wasn't-- not enjoying it, so I changed from that program. And the program had a-- I think it was a social sciences of religion focus that I then shifted into, but I bad to do a second M.A. So it was a different school.

Q. And so all of your graduate work and your Ph.D., your doctorate, is in the area of religion?

A. Yes; but it's -- especially at McMaster, the religion department at McMaster was in the social sciences faculty. Some religious studies programs are in humanities, and McMaster's was in social sciences. So it was a Ph.D. in religion, but in the social sciences. I remember, for example, I was a teaching assistant for a sociologist. So -- so it was the social sciences of religion program, if that helps clarify its location.

Q. Okay. But your advanced degrees are in the area of religion?

A. That's right, yeah. Q. How did you support yourself from 1975 to

1983? A. At first, at American University, I was a dorm

counselor. For I think three -- three long and arduous and painful semesters. It was an awful job. And then I got a job as a teaching assistant, for the final

Page 32

semester. At McMaster, one of the reasons I went to

McMaster is it had good funding for graduate students. It was one of the best-funded programs I think in North America, and I happened to get into it. So there was funding there, but it also involved us doing teaching assistantships. And then at some point at McMaster I sta1ted getting some student's fellowships and scholarships and so on.

And I'm sure, you know, I -- I'm sure my parents helped me out at various times.

Q. From 1983 on, how have you been employed? A. I finished the dissertation -- I remember

interrupting people's Christmas parties to give them -to try to give them my dissertation. Got in the car in Ontario and then drove out to Edmonton, Alberta, so I got there in January 1984, and I was a-- it's called a postdoctoral fellow. It's -- it was a two-year position, doctoral in -- the teclmical term was Izaak Walton Killam postdoctoral fellow. And it's a-postdocs, as they're called, usually go to recent Ph.D.s who haven't gotten jobs yet but who have shown a lot of promise in scholarship. And I'd published a fair amount as a graduate student. So I was at University of Alberta for two years as a postdoctoral fellow and then

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for one semester as a sessional instructor. And after that I got a job--I don't think it

was-- it wasn't tenure stream, it was the dangling carrot of possible tenure stream--back at -- oh, University-- back at University of Waterloo. I was there for one year. And while I was there, a position

7 opened up back at the University of Alberta which was 8 tenure stream, in sociology of religion. So when I went 9 from McMaster and Ph.D., I went into a sociology


Page 35

1 affidavit or a deposition, you would have copies of 2 those? 3 A. I should. 4 Q. On Exhibit 1, could you check for us the legal 5 matters where you've offered some sort of opinion that

touched upon Scientology? 6

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A. Sure. Q. And just check on the exhibit for us, if you

would. 10 department as the Killam. And when I left the sociology 10

11 department in Alberta, I went to Waterloo, into a sociology department, and during my year there a position -- tenure stream position opened up back in 13

sociology at the University of Alberta, and I applied 14

and got the job. And it was a tenure stream job, and I 15

eventually got tenure, and I've remained there since. 16

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A. Okay. In 1984, the Midtdal versus Midtdal civil case in Edmonton, Alberta.

Q. Maybe you could give us the numbers. A. Oh, that's the first one, in 1984, under

"Legal Consultations and Testimonies." Q. Okay. Just tick off the ones that touched on

Scientology. Q. And in addition to teaching at the university, 17 1 7

18 it sounds like you've also done some consulting work? 18

A. Okay. And then 1997, the Ken Montgomery versus Allan Anthony Buttnor.

19 A. I've done some, yes. 19

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Q. What percentage of your time would you say is 20

Q. And I'll tell you, Let's go back to Midtdal, and--

spent consulting? 21 A. Midtdal? A. Geez. I mean, it's a tiny amount. I've gone 22 22

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for a couple years and done nothing. So it's just the 23

odd case. And the cases will take up ... When they 24

happen, they'll take up... I'd have to make a wild 25

Q. Yeah. And just tell us very briefly what the nature of the issue --

A. Boy. Q. -- was in the case.

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1 guess, but just a small amount of time. 2 Q. Have you listed all of the legal consulting or 3 legal type work you've done on Exhibit No. 1? 4 A. As far as I know, I have. 1 don't-- if I've 5 left anything out, it's certainly not been intentional. 6 Q. I don't see this case on your list. 7 A. Oh, no; I wouldn't -- I wouldn't have put it 8 on there. 9 Q. Okay. But other than this case, is there

10 anything else that you can think of where you've offered 11 opinions or testimony involving matters of legal 12 d ispute, that's not on Exhibit 1? 13 A. As far as I know, sir, all the submissions I 14 made in legal matters are listed on here, except for 15 this case. 16 Q. And do you keep copies of all the submissions 1 7 that you've made? 18 A. I do. 1 9 Q. 1 know some of them are posted on your web 2 o site, 1 believe. 21 A. That's right, yes. 22 Q. But not all of them? 23 A. That's true. There arc some ... Well, some 24 there aren't even written reports for. 25 Q. But if there was a written report, or an

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1 A. That's a long time ago. As I can best recall 2 at this time, it was a custody dispute, if I'm not 3 mistaken. I know it involved children. So I'm saying 4 custody; it could have been visitation. 5 Q. Okay. How about Ken Montgomery? 6 A. Ken Montgomery was an Edmonton city police 7 officer at that time, and Allan Anthony Buttnor was a 8 prominent local Scientologist. Background for that 9 case, Ken Montgomery worked in an intelligence unit in

10 the police, the Edmonton h1tegrated Intelligence Unit, 11 EIIU. He was city police, and there was an RCMP 12 partnered with him. They had -- Scientology thought the 1 3 intelligence unit was investigating Scientology. And so 14 Scientology called a meeting with the two police 15 officers. I wasn't at the meeting. I was working a lot 16 with the police at this time, so I wasn't at the meeting 1 7 but 1 was cettainly in touch with the cops. I think the 18 meeting didn't go terribly well. And then a few days 1 9 later, Mr. Buttnor -- well, a few days later, very short 20 time later, Mr. Buttnor got arrested in the city. And 2 1 initially he was charged with something involving child 22 interference. There was a person who had left the 2 3 group, and she had a number of kids and this is one of 24 her children, and Mr. Buttnor got charged. 25 Eventually-- and I'll spare you all the

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1 details about how the case unfolded, but eventually the 2 charges against Mr. Buttnor got dropped. 3

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Q. Yeah. I--

1 Q. Okay. Well, I'm going to ask you-- would you 2 have any objection to me getting copies of these various

submissions? 3

A. And at some point-- at some point Mr. Buttnor lay charges, probably-- involving-- something involving harassment of some sort, against the two

7 police officers. And Ken Montgomery countersued. So

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8 this was Ken Montgomery's countersuit against Mr. Buttnor in this whole mess of a series of allegations.

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Q. Okay. What's the next thing that had anything 11

to do with Scientology? 12

13 A. This would be the 1998 "Bonnie Louis Woods 13

14 versus Sheila Chaleff, Graeme Wilson, Cathy Sproule, and 14

15 Church of Scientology Religious Education Inc." This -- 15

I didn't testify in this case; I submitted a witness 16

statement. I'd have to go back and check what's in it. 17

I believe it discussed some dimensions of fair game. 18

But I can't tell you anything else about what's in it.

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I'm just not entirely clear, and I don't want to guess. 20

21 Q. Okay. What's the next thing? 21

2 2 A. 1998, "Religious Technology Center and Bridge 22

23 2 3 Publications versus Dennis Erlich." There were several cases in this period, so 1998, there's a 1999 court submission about "Scientology's perception of Dennis 25

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A. I don't have any objection. If--Q. Well, I'm going to ask you, then, to, you

know, through your lawyer--A. Yeah. Q. -- to provide that to me. So I'm really

looking for just a brief nutshell -A. Yeah. Q. --on what the issue was. A. Yeah, I mean, I don't mind. I don't know how

these processes work, because it doesn't -- none of these have direct bearing upon this case. I didn't consult any of them.

Q. I understand. A. So, you know, ifl -- again, I don't know

how-- what the law is. A lot of them are on the Internet; if I say --just ifl say no, what are the consequences?

Q. Well, I would ask you what objection you would have to me having them.

A. Uh-huh (affirmative). MS. FRANKLIN: l'd make an objection to

the question, but you can answer.

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BY MR. MILLER: 2

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2 Q. Dr. Kent, is there any reason that you would 3 object to me seeing what you've said about Scientology

in the past? 4

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Erlich as a 'suppressive person,' and its aggressive actions against him,'' then there's 1999, "Bridge Publications versus F.A.C.T.NET, Lawrence Wallersheim ... " This was a period where a number of Scientology critics--I think in most cases former members--were putting Scientology documents on the Internet. Some of the documents may have been upper level, so-called secret documents, but some of the -were just ordinary ones, and Scientology in various cases sued for copytight violations and so on. Now, I 10

can't tell you exactly what I said in each one of these 11

cases. In part because they were so, in some ways,

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similar. So I can't tell you exactly what the

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think I had gone back through a lot of the early -earliest Scientology publications, and found that there

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A. Well, the only issue is 1 don't know-- it doesn't have any bearing on this patticular case, as near as I can tell; I didn't consult any of them. And so I just am trying to make sure I don't have things used against me that didn't have any bearing upon my particular decision. That's the only reason.

Q. Okay. So, having articulated your reason, do you have an objection to providing me with copies?

MS. FRANKLIN: The ...

17 were I think 19 or 20 or so early publications that had 17

18 been written by someone other than Mr. Hubbard. And 18

19 that Mr. Hubbard subsequently attached his name to. And 19

THE WITNESS: I think I'll check with counsel and see what the best thing is. But, again, you can get a lot of them tight off the Internet.

Q. Okay. A. The expert-- now, 1999, I don't-- I don't

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1--Q. But this was all in the context of copyright

infringement litigation? A. I'll say yes, as long as we take that

copyright litigation broadly. 'Cause there was a lot going on in this period.

20 have that one written down, and I'll tell you why. This 21 was a child visitation case in London, England. And

there were two experts, me and another person, I'll say on -- I'll use this language, but I'll clarify it in a second. -- on one -- on one side, and Scientology had

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clear to us that the court said, "You can't take sides," that "The expert witnesses have to be on the side of the best interests of the child." So the judge instructed us to sit in a room and come up with an agreed-upon

5 statement. So we sat in a room for, I don't know, a 6 good day, maybe longer, and I thought we had hammered

out a pretty good statement. But none of us had-- this is really before laptops, particularly. So none of us had a computer, and I typed it up later, and the other

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10 expert on, I'll say, my side signed it. The person who 11 was representing Scientology, although also representing

the interests of the child, then backed away from signing it. So in essence our consultation fell apart. So there's no written document for that one at all.

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1 telephone. And this was also a -- if I'm not mistaken, 2 it was a divorce. And I think it was a custody case. 3 And Tom Padgett had left the group, and be was claiming, 4 among other things, he had been fair-gamed. And I'm not 5 sure what else I discussed in that. I'm pretty sure I 6 discussed issues about fair gan1e, which is a policy that 7 Scientology now denies exists but critics are insistent 8 that it continues, of-- of various kinds of harassments 9 against critics. So I'm pretty sure that was -- I

10 remembered something about Tom Padgett saying he had 11 some slogans sprayed on his garage door and so on. So I 12 think there was something about fair game in there. 13 Q. Okay. Up until this point in time, had you 14 been deposed in any of these other matters, other than 15 the Padgett case? 16 A. I'll look, but I don't think so. 17 Not in Midtdal versus Midtdal. Not in Ken 17

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Q. Are we up to "EEOC versus I-20 Animal Medical 19

Montgomery, as far as I can ... Not in Bonnie Woods. Dennis Erlich, I don't think so. Certainly not in the case in London in '99. Dennis Erlich, suppressant person, don't think so. Bridge, no. EEOC, no; it never -- it got settled out of court. Lisa McPherson, wasn't deposed in that. So as far as I can recall here, the Padgett one was the first instance.

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Center"? A. That's right. And that one I think is on the

net. Q. What was the issue there, very briefly? A. This was a case involving what's called the

World Institute of Scientology Enterprises. It's the

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application of Scientology practice management or business management programs into work -- into the workplace. And this was a veterinary hospital, if you can call it, and the head -- the head veterinarian had

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Scientology? A. This was a case in Ireland. And Mary Johnston

5 taken these practice management courses and was bringing 6 them into her workplace. And I can't remember how many 7 employees objected. They -- they were clainllng that a Scientology was a religion, and it violated their

had been receiving Dianetics auditing. And she was 4 about to join the Sea Org when she had an interaction 5 with members of her family, and she suddenly decided not 6 to go in. And then made some critical comments about 7

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Scientology publicly, ifi remember the scenario. And after she made these critical comments, she claimed that she was fair-gamed. That somebody was coming to her workplace and -- and the other incidents I really can't

9 religious principles. And so they went to the EEOC, and 1 o the EEOC picked up that case. Now, that one is on the 11 Internet.

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11 remember that she claimed had happened. So she launched 12 a lawsuit against Scientology, and I was a witness on

her behalf. I was on the witness stand for a long time, but twice. I flew over there. And at the time I believe I was associate chair graduate, so I was -associate chair for graduate students in the sociology depattment, so I had a reduced cour -- I think I had a reduced course load. So I had some flexibility with time, and I was -- I flew there once and they didn't finish the deposition, so I had to fly back again. And that case settled out of court.

12 Q. Okay. What's ilie next one? 13 A. "Estate of Lisa McPherson versus Church of 13

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Scientology Flag Service Organization." l think that's 14

on the net too. I'm pretty sure that is. And this was 15

a -- geez, I'm not even sure what's in it. I think it 16

had a discussion, among other things, about what in 17

Scientology is called the "Introspection Rundown." It's 18

a program that L. Ron Hubbard developed, he said to 19

handle psychoses. As be defined it. But there are 20

other-- some other issues in there, and, again, I just 21

can't remember what's there. And I think that one's on 22

the net. 23

Q. How about Padgett versus Padgett? 24

A. Now, I was deposed in that case, but over the 25

Q. Were you deposed, or did you just testify in some sort of court proceeding?

A. I just testified in a court proceeding. And, to my recollection, there isn't a fmmal-- there isn't

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1 a formal court record of what happened. 2 Scientology -- if I'm not mistaken, 3 Scientology bad hired its own court rcpmter. But Mary 4 Johnston's had not hired anyone, so -- so the only 5 formal notes were the court reporter that Scientology 6 had hired. But, as far as 1 know, there is no 7 objective, neutral record of what the testimonies were 8 in that case. 9 Q. What's the next one?

10 A. Okay. Oh, the "Diana Kostelny ... conceming 11 Scientology and WISE." You know, I can't remember 12 anything in detail about what that case was. So I 13 just -- I can't help you there. l4 2003, "Front Sight Management..."; he was a 15 gun instructor in Nevada, I think Las V cgas. And, if I 16 remember correctly, he had started using WISE in his 1 7 company, and there was --I'm not going to say-- I know 18 there was a big objection by one person who had been an 19 employee. And I think I submitted a statement on -- on 20 her behalf. I don't recall what happened to the case. 21 I think it settled out of court, but I'm not sure. As 22 far as I know, 1 was never deposed there. 23 The last one was 2000 ... I hesitate at 2010; 24 I 'll have to check the date, 'cause it feels like it was 2 5 just 2011. So I want to check the year on that one.

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1 But I -- maybe time does fly that fast. But this was a WISE case, and I was deposed in this case. This was a case in D enver, and this was -- Nakishia Williams was a -- I believe a dental hygienist, and her employ -employer, Dr. Lowery, started using practice -Scientology-based practice management programs in the business. And Nakishia objected on several grounds. And, you know, got -- it was a civil case that settled out of court. But I was deposed for a few hours in that case.

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Q. Okay. Any other Scientology-related matters on here?

A. I don't think so. Q. I think we established earlier, none of these

involve Narconon or Narconon Intemational; -A. None. Q. -- is that-A. No, sir. Q. -- conect? And I counted 22 matters; I guess

if we count this one it would be 23. A. 22, and this would be 23. Q. Right. And of those, if we include this one,

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eight, nine, ten, 11 , 12, 13, 14, 15; this would be 16? Is that conect?

Q. I'll take your count, 16 of the 23. And on all of those occasions, Dr. Kent, I assume that you have testified in opposition to something having to do with Scientology?

A. I've always been on -- I've never testified on behalf of Scientology. Scientology's never contacted me to testify, so ...

Q. And you've always been critical of Scientology in some regard with respect to these legal matters?

A. Critical about some aspect of Scientology's behavior, yeah .

Q. Let me ask you about that. Would it be fair for me to assume that you're not going to offer criticism of Scientology as a religious belief system?

A. That's not my intention here, no, sir. You know ...

Q. But my understanding is that in these cases that you've identified, there was some specific practice or set of practices that you were critical of?

A. Certainly in the ones I can think of of fhand. Again, with the understanding that I can't remember clearly what I said in some of these cases, it would be the case that I'd be clitical of some aspects of

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Scientology behavior. Q. Right. And that's what I'm getting at, just

broadly speaking; you're not going to be critical of anyone's religious beliefs, it would just be if there was some practice or behavior that you found objectionable?

A. In this case I'm no t even talking about being critical of people's religious beliefs. My attitude

9 about religion is that people can believe whatever they 10 want. Religion only becomes an issue if practices ll associated with religion are arguably hannful. But in 12 terms of belief, what goes on in a person's head, that's 13 entirely up to the individual. It's always behavior 14 that becomes crucial. 15 Q. Right. And so if there was ham1ful behavior, 1 6 you would be critical of it?

A. I would be critical of harmful behavior. 17

18 Q. Based on your CV and what you've told us, my 19 understanding is that you don't have any background or 20 experience with regard to drug and alcohol addiction 21 programs? 22

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A. That's true; I have no experience in drug or alcohol addiction programs.

Q. And you--A. One, two, three, four, five, six, seven, 25 A. So I have no plans to make any comments about


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Desmond, et al. v. N arconon, et al.

1 them. 2 Q. You're not going to have any opinions

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3 whatsoever with regard to how effective or not effective 4 the Narconon drug and alcohol treatment program is? 5 A. I have no intention of making any -- offering 6 any opinions about how effective the Narconon program is 7 or may be. 8 Q. And you also do not appear to have any 9 background as a medical doctor or a psychiatrist or a

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Stephen Alan Kent Januat·y 5, 2012

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effective than any other kinds of programs. Q. And so if people come in and testify in this

case that they've gone tlu·ough the Narconon course and it's gotten them off a drug or it's gotten them off of

5 alcohol dependency, you would have no reason to dispute that?

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there anything else that you plan to do? A. I don't -- let me think. I think I've done --

11 A. That's true; I'm not a medical-- on one of 11 as far as I know, I've done everything that -- that I 12 the initial fonns I got identified as an M.D. But it 12 plan to, other than remember the name of that one book 13 looks like it's got conected. No, I'm not an M.D., I'm 13 I'm forgetting. You know, 1--1 think I've done all 14 not a psych -- I'm not a psychologist. 14 that I need to. 15 Q. Okay. And, again, I just want to try to make 15 Q. The reason I'm asking, of course, is because 16 sure we're clear on this. You're not going to offer any 16 we want to know what you might testify to in the trial 17 opinions in this case about what Dr. Robbins may or may 17 of the case, so if there was something else --18 not have done as a medical doctor; is that conect? 18 A. Yeah, if there was something else. 19 A. No, I have no-- I have no intention of making 19 Q. --you were planning to do or that you've 2 o any comments about anything Dr. Robbins may or may not

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Q. And you're not going to offer any opinions about whether sauna programs are healthful or not healthful for people?

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stay away from any discussions about, say, physiology, which I would include in the sauna.

Q. And same with the vitamin therapy? A. That's true. Q. Okay. So, in other words --

(Discussion off the record.) (Recess at 11:16, resumed at 11:17.)

BY MR. MILLER: Q. Dr. Kent, I appreciate you clarifying the

areas you are not going to give opinions. But in addition to not planning to give opinions in those areas we've just discussed, it sounds like you would not feel that you would be qualified as an expert to give opinions in those areas.

A. No; I'm not-- anything involving medicine I don't feel qualified to talk about. So physiology or drug rehab benefits or whatnot, that's just -- they're not my area of training, so ...

Q. Okay. And I think I know the answer to this, but you're not going to offer any opinions about whether the Narconon program is more or less effective than any other type of drug and alcohol addiction --

A. I'm not going to offer any opinions --Q. --program? A. --as to whether Narconon is more or less

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suggested be done, we need to know that. But what [ understand your answer to be is that you've done everything that you can think you need to do, and that you haven't asked to do anything additional?

A. As far as I know, that's true. I don't have any plans. I've got -- I've been putting off preparing

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my courses for next semester, so that's what I'm going to do next.

Q. And let's go to Exhibit 4 for a minute, which is the statements about the opinions --

A. Uh-huh (affirmative). Q. --that you anticipate giving in this case.

And I'm going to ask you quite a few questions about numbers 1 and 2, since you indicate those are areas where you're going to give opinions?

A. Yes. Q. Okay. But you indicated that there would be

something very limited that you might say about number 3, and I thought I would just start there and try to find out what, if anything, you're going to say about--

A. Yeah. Q. -- Narconon International's corporate

structure, and how Narconon International and Narconon of Georgia are connected to the Church of Scientology.

A. Okay. That's fair enough, and that's fairly short. Narconon uses materials written by L. Ron Hubbard. And in order to -- and as part of the right to use that materials, Narconon pays I believe it's a ten percent fee back into... 1'11 say the Scientology organization, for this right.

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Now, I'm not clear whether the ten percent fee goes to a Narconon regional organization, whether it

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1 percent is paid for? 2 A. My understanding is -- I call it a licensing 3 fee. It's a fee for use ofL. Ron Hubbard's materials. 4 As I understand it. 5 Q. Okay. But in tetms of the interaction between 6 Narconon International and Narconon of Georgia, you

don't have any information about that? 7

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A. No, sir, I'm not. Q. And are you going to offer any opinions about

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not a whole lot I can say of any substance. Q. Okay. A. And I defer to other people for their insights

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licensing and types of things like that?

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A. I'm not an expe1t --Q. And I--A. -- in licensing or anything like that, no. Q. Okay. And so in terms of how a drug and

alcohol program might be licensed or regulated, you're not going to offer any opinions about that?

A. I have no opinions on that, no. Q. And same with any sort of housing that might

be associated with the program? A. No opinion on housing issues. Q. Okay. Or how housing should be run, or how

people should be supervised, or anything like that? A. No, that's all-- you know, l wasn't asked to

comment on the daily runnings of the program, and, you know, I'm not going to.

Q. As far as nwnber 3 is concerned, then, it sounds like -- I'm going to try to summarize but be fair; is that you believe that Narconon of Georgia pays a ten percent licensing type fee that goes to somebody, and you're not sure where it goes, and whoever it goes to, you're not sure where it might go, if anyplace, after that?

A. That's correct. Q. And is it your understanding it is a licensing

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A. Beyond what I've said already, I'm not going to make any comments about relationships between Narconon International and Scientology.

Q. And your understanding is Narconon lntemational is a nonprofit organization?

A. Well, in the documents I submitted, there are certain-- in one of the initial submissions to the IRS, ifl remember correctly, that Narconon said that it was a tax-- I believe it said it was a tax-exempt organization. Before -- this is before the IRS ruling.

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Q. Maybe I can approach it this way. A. Okay. Q. I will tell you that my understanding is that

Narconon International is a nonprofit organization. Do you have any reason to believe that that's not true, as we sit here today?

A. I would want to look at, again, very carefully, the IRS decision. Because it looks to me like Narconon International-- it was one ofl think it was 136 Scientology satellite organizations, ancillary organizations, that received charitable status. Through the IRS decision. That's my understanding now. But I do remember that Narconon had claimed that it was a tax-exempt prior to that IRS decision. So however the IRS decision -- we'd have to look at that -- that carefully. But... And we'd have to fmd it-- see, I think this -- all right, let me see.

It might take a few minutes for us -- and feel free to help me on this. The mentions ofNarconon in the IRS decision. That's my only concern with agreeing with your statement, is that it's -- I've got a certain level of ambiguity about the impact of this IRS decision upon Narconon.

Q. My recollection, Dr. Kent, was that Narconon International is not in that list of organizations

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Desmond, et at. v. Narconon, et al.

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1 that's in the IRS, and so... But 1 think we both need 2 to look at the document. 3 A. Yeah, 1... 4 MR. MILLER: Swap with me. You have my 5 copy where I've got them stapled separately. 6 MS. FRANKLIN: Yeah. I've got a copy of 7 his file, but it's not Bates numbered, and 8 you're going to --9 MR. MILLER: Yeah, I've got one that's

10 Bates numbered. And I'm--11 THE WITNESS: Yeah, it looks like this 12 is --13 MS. FRANKLIN: That's fme. That's 14 fine. 15 THE WITNESS: It is -- A Narconon is ... 16 MR. MILLER: Would you mark this as the 17 next. 18 THE WITNESS: Tbjs could take us a few 19 minutes to find, but I agree with -- well, 20 it's an important point; now, whether we want 21 to spend time here sitting ... Association 22 for Better Living and Education, ABLE, is 23 here. It's on Page Bates 870. 24 (Thereupon, marked for identification 25 purposes, Defendants' Exhibit No.7.)

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1 THE WITNESS: I don't think it's back 2 beyond that. 3 Page Bates 885, number 4. "The social 4 benefit and other public benefit entities 5 discussed at pages 1-28 through 1-42 of the 6 June submission along with the subsidiaries, 7 subordinate chapters, subordinate 8 organizations, or sublicenses thereof, e.g., 9 organizations that are permitted to use

10 particular names, copyrights, service marks, 11 and/or technologies, are Scientology-relatcd 12 entities. Thus, for example, Citizens 13 Commission on Human Rights, National 14 Commission on Law Enforcement and Social 15 Justice, Scientology Defense Fund Trust, 16 Association for Better Living and Education, 17 Applied Scholastics Incorporated, Narconon 18 International, The Way to Happiness 19 Foundation, and the Foundation for Religious 20 Freedom are Scientology-related entities." 21 Attach-- " ... entities Pages 1-28 through 22 1-42 are attached as exhibit Roman numeral 23 V ill-2 to this agreement." So it is 24 mentioned in here. 25 BY MR. MILLER:


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1 Q. Well, maybe l can get to it this way. First 2 of all, I've marked the document you're looking at I 3 believe as Exhibit 7 --4 A. Okay. 5 Q. --to your deposition? 6 MS. FRANKLIN: That's just--7 THE WITNESS: Just the IRS --8 MS. FRANKLIN: -- 838 through --9 BY MR. MILLER:

10 Q. And, Dr. Kent, as I understand it, this is an 11 agreement by the United States government in 1993 that 12 found that the -- well, I want to be careful about the 13 date, but this was an agreement that resolved some 14 disputes with some of the Scientology entities and the 15 Internal Revenue Service about whether or not the Church 16 of Scientology would be tax-exempt? 17 A. That's true. l'd say -- I'd go a bit further; 18 I'd say it settled all disputes. This was a blanket 19 settlement. 20 Q. And the upshot of this was that at least 21 sometime in the 1990s there was an agreement by the 22 government that these entities were all tax-exempt? 23 A. There was an agreement by the IRS. It 24 wasn't-- there had been an earlier court decision that 2 5 was -- that was different, but this is an IRS agreement.

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1 Q. I'm treating the Internal Revenue Service as 2 part of the United States government. 3 A. Sure. Sure. But the United States government 4 is multifaceted. And so the court system was not party 5 to this particular decision. 6 Q. Okay. Well, as far as the United States 7 government is concerned for tax purposes, all the 8 Scientology organizations are considered to be 9 tax-exempt?

10 A. That's my -- 1 wouldn't say all ofthem. So, 11 for example, there's no mention in the IRS decision of 12 the Scientology Rehabilitation Project Force program. 13 And this is an -- well, I've called it an internal 14 reeducation -- well, reindocttination, reeducation, 15 penal system. That's not mentioned anywhere in here. 16 So I wouldn't say that all Scientology organizations, 1 7 and there may be some others. But certainly I believe, 18 as I said earlier, I think it covered 136 19 Scientology-related organizations. 20 Q. Okay. What was the page you were looking at 21 earlier? Never mind, I found it. 22 A . Okay. 23 Q. But going back to my original question; --24 A. Uh-huh (affitmative). 25 Q. -- do you have any reason to think that

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1 Narconon International is not a nonprofit organization? 2 A. It's -- I'm unclear as to whether it's a 3 nonprofit or-- or a charity. So ... 4 Q. What's the distinction that you're drawing 5 there? 6 A. I think it might have to do with paying a 7 pmticular kind of taxes. Again, I'm not a -- so it's 8 either one or the other. 9 Q. Well, I'm not ruling out that it's a

10 charitable nonprofit; --ll A. Yeah. 12 Q. -- in fact, I believe it is a charitable 13 nonprofit. 14 A. Okay. 15 Q. You would have no reason to disagree with 16 that, would you? 17 A. Not necessarily, no. 18 Q. And same with Narconon of Georgia; if there's 19 evidence that that's a charitable nonprofit 20 organization, would you have any reason to disagree with 21 that? 22 A. Wouldn't surprise me. Let's put it that way. 23 Q. Okay. I just want to make sure that you're 24 not going to offer some opinion that Narconon of Georgia 25 or Narconon International are not charitable nonprofit

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1 organizations. 2 A. I don't intend to. 3 Q. And this IRS agreement that we've marked as 4 Exhibit 7, this had to do with a dispute about the 5 religious status of some of these organizations, as I 6 understand it? 7 A. In various -- this is -- the final IRS 8 agreement is secret. So both Scientology and the IRS 9 have not released the fmal agreement. This was, as

10 near as 1 can -- near as I recall, the -- the 11 next-to-last agreement, that the Wall Street Journal got 12 ahold of and released. And then it's been reproduced in 13 various web sites. So there could be differences in the 14 final agreement. I think there is even a tax case that 15 demanded the IRS release the agreement, and it -- it 16 refused to do so. So there conceivably could be some 17 differences in the final agreement. I don't think there 18 are. I'd be very surprised. 19 Q. But in terms of those negotiations, the 20 drafting of these agreements, that type of thing, you 21 don't have any personal knowledge about that, do you? 22 A. I was not involved in any of it, so ... 23 Q. And you're not a tax expert or anything like 24 that? 25 A. Oh, l'm far from a tax expert.

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Okay. So going back to Narconon lntemational, it sounds like you don't have any opinions that you're going to offer in tenus of how Narconon International interac~s with any other organization that you would consider to be a Scientology-related organization?

A. No, sir, I have no plans to talk about how Narconon lntemational interacts with any other Narconon organizations.

Q. And 1 think you already answered this, but you're not going to talk about how Narconon International may interact with Narconon of Georgia? Other--

A. I'm not going to talk about interactions between Narconon International and Narconon of Georgia.

Q. And I think I know the answer to this, Dr. Kent, but let me just make sure; have you spoken to anybody who has ever gone through a Narconon program?

A. I have, actually. Q. Who is that? A. I understand why you ask the question, but

according to the university ethics that I have to follow, we have to guarantee anonymity and confidentiality of our sources. So by the requirements that I have to follow for research, unless the person's

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given me permission to use his or her name, 1 can't. Q. Well, are you going to rely upon any

infonnation --A. No. Q. -- that you were provided? A. No, sir, I'm not going to rely upon anything

anybody's told me. Q. About going through the Narconon program, or

what the Narconon program is like, or anything like that?

A. I'm not going to rely on any of that, no, sir. Q. Or recount or offer that information at trial? A. No, sir, I'm not going to recount anything

from any-- any account. Q. Would your billing records indicate when you

were first contacted about this matter? A. Oh, I doubt it. Q. What sort ofbilling records do you keep? A. When I start reading, I scribble down the

time, and when I stop, I scribble down the time. Q. Would those scribbles also have a date? A. They'd have a date, yeah. Q. So wouldn't that tell us when you first were

contacted, or at least when you first did some work on it that you were going to bill for?

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1 A. Yeah, they would. It's just that I don't --2 with phone calls, I -- I'm an academic, I talk to people 3 all the time for free. And so when I talk to lawyers, I 4 almost never bill them. It's just part of what I do as 5 a researcher. It's very different organization behavior 6 for lawyers, and you can understand why. 7 Q. Well, ifl understand what you're saying, 8 though, is that when Jeff Harris called you up on the 9 phone, you would not have made a note on that for

10 billing purposes? 11 A. That's very true. 12 Q. But when somebody decided to hire you, and you 13 started, for example, pulling these materials out of 14 your files, --15 A. Yeah. 16 Q. -- then you would make a notation of the date 17 that you started to pull those materials out and some 18 record of the time you spent? 19 A. That's true. 20 Q. Is that piece of paper still in existence? 21 A. The -- it would be back in E dmonton. 2:;1 Q. Okay. Can we have an agreement that you will 23 provide that to Rebecca, and --24 A. Oh, yeah; I've got to provide that at some 25 point. Sure.

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1 Q. Have you billed them anything to date? 2 A. Nothing. 3 MS. FRANKLIN: I can't agree that he's 4 going to provide that to me. If he does, 5 I'll provide it to you. 6 BY MR. MILLER: 7 Q. Well, so you'll provide her with the record of 8 when you first started doing work? 9 A. Yes, sir.

10 Q. And then she'll provide that to us; --11 A. Yes, sir. 12 Q. -- is that fair? 13 The course pack that you looked at last 14 night --15 A. Yes, sir. 16 Q. -- from the Narconon of Georgia course, was 1 7 there anything in that course pack that you're going to 18 offer the opinion was harmful to the students going 19 through the Narconon of Georgia program? 20 A. I'm not -- I don't plan to get into issues 21 about hatm or potential hann. Again, because those 22 issues primarily would be medical. But even if they 23 would be social, they're not what I was, you might say, 24 contracted to talk about. So I have no plans to do 25 anything like that.

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So whether they were helpful, harmful , you're just not going to offer any opinion about that one way or the other?

A. That's correct. Q. And the same with regard to any of the course

pack materials that you've reviewed from Oklahoma; you're not going to offer any opinions about whether those are helpful or hannful?

A. No; and they don't-- they're not this case anyway, but same-- same thing.

Q. And, again, I'm not trying to beat a dead horse, --

A. Uh-huh (affinnative). Q. -- but my understanding of what you're telling

me is that you're not going to come into court in this case and say that there was something that was going on in this course pack of materials from Narconon of Georgia that you consider to be harmful to any of the students like Patrick Desmond?

A. That's not my hired intention, so I plan to stay away from any of those areas.

MR. MILLER: Why don 't we go ahead and take a short break, Rebecca?

MS. FRANKLIN: That's fine. MR. MILLER: I think Barbara is going to

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have to leave here in a minute. (Recess at ll :41, resumed at 11:58.) (Thereupon, Ms. Marschalk is not present in the deposition room .)

BY MR. MILLER: Q. Dr. Kent, let me go back and clean up just a

couple things. I think you've already testified that you're

not relying upon any of the documents or depositions that we've identified in this Exhibit 3?

A. That's conect. Q. But you had also mentioned that you might have

glanced at some portion of something in there, a deposition or something, --

A. U h-huh (affmnative). Q. --but I take it you're not relying upon

anything you may have, you know, read in the depositions?

A. I'm not relying upon anything in the depositions. I figured in terms of what I was asked to do, outlining the beliefs and practices of Scientology and also any connection between course materials of Narconon and Scientology, it didn't matter what any of these testimony -- any of these depositions may have said.

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1 Q. Okay. 2 A. So I'm just not getting anywhere near them. 3 Q. And in terms of what the events may have been 4 on the day that Patrick Desmond died, you're not going 5 to offer any opinions about what happened that night, 6 are you? 7 A. No, sir. 8 Q. And you're not going to offer any opinions 9 about the cause of his death, are you?

10 A. No, sir. 11 Q. You're not going to offer any opinions 12 critical of the defendant Delgado in this case? 13 A. No, sir. 14 Q. Or, specifically, you're not going to offer 15 any opinions critical ofNarconon of Georgia or Narconon 16 International, as I understand it? 17 A. I don't see it as my obligation here. 18 Q. Okay. 19 A. So I don't intend to. 20 Q. And basically it's going to be 1 and 2 on 21 Exhibit 4, will be the limit of your opinions in this 22 case? 23 A. That's true. 24 Q. And those opinions are based, as I understand 25 it, on your general familiarity with Scientology and

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1 with documents that you have pulled to refer to in 2 Exhibit No.2, and your review of the course pack 3 materials? 4 A. That's correct. 5 Q. And the ten percent number, is that just 6 something that you've heard from somebody? 7 A. Oh, I'm -- no, I'm sure I read it in some 8 materials over the years. I mean, I've been studying 9 Scientology and other groups for at least a quarter of a

10 century. And it's a fairly standard practice in 11 Scientology for these satellite groups to pay a 12 percentage back to the organization. So that's fairly 13 standard procedure. 14 Q. Is it fairly standard, though, in lots of 15 organizations to have people pay some sort oflicensing 16 or royalty fee if they're using copyrighted or 17 trademarked materials? 18 A. I can't say. 19 Q. So whether this is the same or different than 20 practices in groups like Alcoholics Anonymous or the Boy 21 Scouts or anything, you just don't know? 22 A. I'm not an organizational sociologist, so I 23 can't say. 24 Q. I think you've told us this already, but am I 25 conect that you don't have any notes whatsoever on any

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of the subjects that we're talking about today? A. No. Q. Did you review Exhibit 4 before it was sent to

the lawyers in this case? That's the letter that outlines your opinions.

A. I got I think a draft of it, but I hadn't seen the actual letter until I got here.

Q. Okay. But as far as Exhibit No. 4 is concerned, as far as your opinions are concerned, they did run this language by you for opinions 1 and 2?

A. I believe so. I do recall getting a draft and approving the draft.

Q. And let me work kind of up backwards on this list, as we've done already. We talked about 3 already on your list, and I think you've told me all the opinions you have connected to number 3 --

A. Uh-huh (affim1ative). Q. -- on Exhibit 4. Let's talk about your

opinion number 2 on Exhibit No. 4. And that opinion is that " ... the vast majority ofNarconon of Georgia's training materials and course exercises are based primarily on the principles of the Church of Scientology"?

A. Yes. Q. And the "training materials and course

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exercises"; are you referring to the course pack that you looked at?

A. Really referring to all of the books that I looked at.

So let's put it this way; I didn't see anything, any-- any of the major concepts, even any of the minor concepts, in any of the books I looked at that did not come from Scientology.

There was one term I wasn't familiar with, I think it was called "Checkout." But everything else has a direct Scientology connection.

MR. MILLER: Mark this as the next exhibit.

(Thereupon, marked for identification purposes, Defendants' Exhibit No. 8.)

BY MR. MILLER: Q. Let me show you what's been marked as

Defendants' Exhibit 8. A. Uh-huh (affirmative). Okay. Good. Good. Q. I'll represent to you that I believe this is

the front cover of the books that have been produced in this case as the books used in what I think you would describe as the course pack for Narconon of Georgia, Inc.?

A. That's right.

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1 Q. And does this look like the books that you've 2 looked at in terms of reaching your opinion number 2? 3 A. Yes. That's the one I forgot. "Changing 4 Conditions in Life Course." That's the one I couldn't 5 remember. 6 Q. Okay. 7 A. Now, I don't-- the attomeys here didn't have 8 a copy of the book number 2, the detoxification program, 9 but I looked-- well, for years I've been, you know,

10 familiar with the "Clear Body, Clear Mind" material. 11 And I think they were also missing 4b, the 12 "Communication & Perception Course"; that would have 13 been the -- I believe that's primarily objectives. And 14 I have seen that, the earlier version, the 1991 version; 15 I just haven't seen the 2004 version. 16 Q. Okay. So you did not look at the course book 17 number 2, "New Life Detoxification Program," or 4b? 18 A. If-- in terms of the 2004 documents, no, I 19 haven't seen those. 20 MR. MILLER: Rebecca, I'll just tell 21 you, my understanding is we've produced 22 those, so ifthere's any question in your 23 mind whether we produced those to you or 24 not--25 MS. FRANKLIN: Produced the entire set

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1 of books? 2 MR. MILLER: I believe so. 3 MS. FRANKLIN: Okay. We've got the set 4 here without those two. I thought we 5 produced them to you all. But--6 MR. MILLER: You may have. You may 7 have. 8 MS. FRANKLIN: Okay. I mean, he's 9 looked at an older version, so ...

10 MR. MILLER: I just didn't want there to 11 be any misunderstanding that we hadn't 12 produced these to you. 13 MS. FRANKLlN: Okay. 14 THE WITNESS: Uh-huh (affinnative). 15 MR. MILLER: But what he looked at--16 BY MR. MILLER: 17 Q. Did the books you looked at look like they 18 were used books, that somebody had initialed and written 19 in? 20 A. Oh, yes. Yes. The ones last night for sure. 21 Q. And these looked like books that Patrick 22 Desmond had read through? 23 A. I don't know that he had read through them. 24 I'm not -- I don't know whose books they were. I don't 25 think they were his.

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MS. FRANKLIN: Just for clarification, they were Nick Parsons' books, who has been deposed in this case.

MR. MILLER: Okay. MS. FRANKLIN: 1 think they were used

during his deposition. BY MR. MILLER:

Q. Dr. Kent, we were provided with a chart of some lawsuits involving Narconon.

A. That's right, yes. Q. And my understanding is that was a chmt that

was prepared by the plaintiffs' counsel? A. It's my understanding. Q. That's not a document you prepared or --A. Oh, no. No, no, no. Q. Do you have any personal knowledge of any of

those lawsuits? A. I haven't been involved in any of them. Q. So that's one question. You haven't been

involved in any of them. But do you have any personal knowledge? You know, know any of the people involved, do any investigation in any of them, anything like that?

A. I've -- the university has documents on some of the cases. I've not worked with any of the documents extensively; I've certainly looked through them over the

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years. On some of them. Q. Well, my question is, are you going to rely

upon any of these lawsuits in reaching any of your opinions?

A. Oh, no, sir; not at all. Q. And are you going to come to court and testify

about any knowledge that you have about any of these lawsuits?

A. No, sir; it's not my intention at all. Q. And so it's just a document that was provided

to you, but it's not a document you're going to use, rely upon or testify about?

A. That's correct. Q. Or the subject matter of the document? A. That's coiTect. Q. You're not going to come to court and testify,

"Well, Narconon has been sued" in some other place for doing something?

A. That's not my intention. Q. Okay. A. And you see that -- that list had lawsuits,

but I've no idea about the fmal history of what happened, whether they got settled out of court, whether there was a ... You know, it's one thing to sue, it's another thing to have a court settlement. And I just

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1 can't tell fi-om that list how the cases got resolved. 1 A. As far as I can recall, and I was looking for 2 Q. And some of them are things like Wikipedia 2 any mentions of, for example, the term Thetan, 3 entries or newspaper articles, that type of thing? 3 T-H-E-T-A-N. I don't recall seeing any mention of 4 A. Yeah. You've got to be careful about 4 something like that in the -- in the course packs. 5 Wikipedia. 5 Q. So as far as you can tell from the review 6 Q. And the document we're talking about has been 6 you've done to date, it looks like the materials in this 7 marked to your deposition as Exhibit 6; is that correct? 7 course pack, while they embrace principles that would 8 A. This looks -- this looks right. I think the 8 come from L. Ron Hubbard and principles that are used in 9 one I have has some color-- color things on it, but 9 the Church of Scientology, these are not religious

10 this looks right. 10 documents, as far as you can tell? 11 Q. Okay. I think maybe some of the shading 11 A. I didn't see any reference to a supernatural 12 didn't come out-- 12 element--13 A. Sure. 13 Q. Right. 14 Q. --on the printer. Okay. So that's just not 14 A. --in any of them, as far as I can recall. 15 anything we need to talk about;-- 15 Q. Okay. So would it be fair to characterize 16 A. No. 16 this as a secular program based on L. Ron Hubbard's 17 Q. --is that correct? 17 principles? 18 A. That's correct. We do not have to talk about 18 A. I'd say a secular program based upon L. Ron 19 that. 19 Hubbard's principles that the IRS has deemed to be 20 (Discussion off the record.) 20 charitable based upon religious claims. 21 BY MR. MILLER: 21 Q. Well, let's take the IRS out of it. Let's 22 Q. And based upon the books that you've looked at 22 just talk about Dr. Kent's opinions here. 23 that are similar to what's in Exhibit 8, there are 23 A. Okay. 24 concepts in there that would be similar to concepts that 24 Q. From what you're telling me, it sounds like 2 5 you would understand the Church of Scientology might 2 5 there's nothing in these course pack materials that you

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1 use? 1 would characterize as religious under the definition 2 A. Yes, sir. And I'd probably be a bit stronger. 2 you've given us? 3 That in many cases the botTowings are direct. 3 A. There's nothing involving the supernatural. 4 Q. And the Church of Scientology, as I understand 4 Q. And so would it be fair, under your opinion, 5 it, in your opinion, is a mixture of religious 5 to say that this is a set of secular materials that are 6 organizations and secular organizations? 6 based on L. Ron Hubbard's principles? 7 A. What I've said in academic circles, willch 7 A. Again, I -- I always come back to the IRS 8 might be what you're referring to, is that Scientology 8 decision. That it-- it provides a context, I think, in 9 is a multifaceted transnational organization, only part 9 the American legal system. And if organizations -- for

10 or parts of willch are religious. That in addition there 10 example, The Way to Happiness International has 11 are a number of secular-related activities. 11 charitable status under tills blanket IRS decision. And 12 It's difficult, however, in the legal setting 12 there's a course pack, the number 7 course pack, that 13 in America to make that claim, because of the IRS 13 borrows directly from The Way to Happiness. Then it 14 decision. So the IRS decision, as far as I'm concerned, 14 becomes complicated for me to say it's just secular. 15 trumps here any academic opinion about -- about how I 15 Because of that IRS decision. 16 see Scientology's structure. 16 Q. Well, first of all, you don't know what the 17 Q. Well, how would you define something that's 17 final IRS decision says, correct? 18 religious? How would you defme religion? 18 A. No. 19 A. Well, there's different definitions, but the 19 Q. So we don't know, sitting here today, you 20 standard one, really, has to do with belief in 20 don't know what the IRS decision ultimately said? 21 supernatural forces or beings. That's a very basic one. 21 A. Well, the only reason I-- I'd hesitate that 22 There's a lot of debate about it. 22 in terms of actually what's happened, what's unfolded in 23 Q. Is there anytillng in the Narconon course 23 society is that, as far as I know, all of these 24 materials that talks about a belief in a supernatural 24 organizations that got identified in the version we have 25 being or force? 25 all got charitable status. So as near as I can tell, we

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1 have the document, the last document before, then we 2 have the settled document -- the settled behavior about 3 the IRS decision, so I think it's clear to infer that 4 the docwnent we have is pretty close, if not exact, to 5 the final decision. 6 Q. Well, let me explore that with you for just a 7 minute. You can have nonprofit charitable status and 8 not be a religious organization? 9 A. That's true.

10 Q. I mean, the Red Cross is a nonprofit 11 organization, but it's not religious? 12 A. That's ttue. 13 Q. Boy Scouts are a nonprofit organization that's 14 not religious? 15 A. Uh-huh (affnmative). 16 Q. Correct? 17 A. That's -- I'll take your word for it. 18 Q. Okay. So you can have a charitable nonprofit 19 type organization --20 A. Yeah. That's my understanding. 21 Q. -- that is not religious? 22 A. That's my understanding. 23 Q. So the nonprofit status ofNarconon, or the 24 IRS's choice to treat Narconon as a nonprofit for tax 25 purposes, does not necessarily mean that they're

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1 treating them as a nonprofit for religious reasons? 2 A. Doesn't necessarily; but I know I've gone 3 through the IRS decision and looked for mentions about 4 religion. Involving the overall Scientology tax 5 exemption. And words about religion or religious do 6 appear in various places in the settlement. 7 Q. I think--8 A. So-- so it would take, as you would say, I 9 guess a tax expert to sort this out. But I'm just being

10 vety cautious because, you know, there's this blanket 11 agreement, and Narconon's included in it, and, you know, 12 the major push for the Church of Scientology was its 13 religious claims. 14 Q. Well, the Church of Scientology, as far as you 15 know, does have a religious element to it, correct? 16 A. That's true. 17 Q. And there was some dispute about that, that 18 presumably got resolved by this agreement, the final 19 agreement which none of us have seen? 20 A. That's correct. And to say "got resolved," 21 but it got resolved for tax purposes. 22 Q. Okay. So going back, you know, in fairness, 23 since you don't see anything in the Narconon course pack 24 that you would characterize as religious, and since we 25 don't know for sure if the government ever took a

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position one way or another about this specific organization, Narconon, would it be fair to say you have no basis to say that this Narconon course pack or the Narconon program is a religious program?

A. It's based-- the Narconon course packs are based upon principles and concepts that are central to Scientology. Scientology beliefs and practices. And those beliefs and practices are part of which have received nonprofit status -- or, charitable status from the IRS, based in part upon religious claims.

Q. Well, Dr. Kent, my question, though, is, do you have any basis for saying that the Narconon of Georgia materials that you've reviewed or that the Narconon of Georgia program was a religious program?

A. Only to the extent that all the concepts in it are based upon Scientology. Which, as I said, has the non-- has the charitable status from the IRS.

Q. But other than the IRS possibly thinking that Narconon of Georgia is religious, that would be the only basis for your opinion that there's anything religious in the Narconon of Georgia program?

A. To go back to your earlier question, I didn't see any mention of anything supernatural in anyplace in the Narconon materials that I reviewed.

Q. Right. So if all we had, if all you had, were

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the Narconon materials to look at, and you didn't know anything about the IRS, you would be comfortable saying that this is a secular program based upon L. Ron Hubbard's principles?

A. With respect, sir, it's speculative. 'Cause I -- I can't answer it, 'cause I'm not, and at this point can never be, in that head space. You know, because I know other things about...

Q. The other things being that there was some agreement that was reached between the Church of Scientology and the Internal Revenue Service?

A . Yes. Q. Okay. Other than what you speculate might be

in that agreement between the IRS and the Church of Scientology, is there any other basis for you to offer the opinion that the Narconon of Georgia program is religious in any way?

A. I have not seen any mentions of the supernatural in this program.

Q. And I appreciate what you just said, but I'm going to have her read back my last question and ask you--

A. Okay. Q. --if you can answer it.

MS. FRANKLIN: Well, I think he did, but

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1 go ahead. 2 MR. MILLER: He may have, but I want to 3 be sure. 4 (Thereupon, the record was read by the 5 court reporter .) 6 THE WITNESS: First, I'd say this one's 7 not speculation. We have a very clear sense 8 about the IRS's decision, even if we don't 9 have the final documents. And it's that

10 connection between the concepts and 11 terminology in the Narconon course pack 12 related back to Scientology that's -- makes 13 me hesitate to just simply write this off as 14 a secular program. I've always -- so that's 15 about as good as I can answer it. 16 BY MR. MILLER: 17 Q. Well, what I'm trying to find out is whether 18 you're going to come to court and tell people on the 19 jury that you think N arconon of Georgia is a religious 20 program. 21 A. What I would intend to say is that-- that 22 Scientology has --in the United States has charitable 23 status, based in part upon its religious claims, and all 24 of the concepts in Narconon come from Scientology. 25 Q. Okay. My question's different, though. Are

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1 you going to say to the people on the jury that you can 2 offer an expert opinion, based upon reasonable science, 3 that this Narconon of Georgia program is religious? 4 A. I'd have to give the same answer, sir; that 5 it's-- you know, that's the connection between-- you 6 know, if Scientology has charitable status based upon 7 religious claims, and then people wind up using central, 8 core concepts, many of them, in a program, then I'm not 9 going to simply say that that program's secular.

10 Q. Well, I think maybe we're having a little bit

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Q. Let me ask this question. IfNarconon of Georgia's tax-exempt status from the IRS is based upon its charitable status and not religious status, would you have any reason to disagree with that?

A. That's why I'd want to look at the IRS decision, see exactly what it says.

Q. But on an annual basis Narconon of Georgia probably files taxes and claims a particular status for--

A. Uh-huh (affirmative). Q. --not having to pay taxes? A. Yes; but it's still -- still the problem is

the content of the courses that it-- the content of the material that it uses --

Q. But, Dr. Kent--A. --in its courses. Q. But, Dr. Kent, you're--

MS. FRANKLIN: Just let him finish. BY MR. MILLER:

Q. Have you finished? A. I think so. Q. Okay. Dr. Kent, you're saying the hesitancy

you have about agreeing that N arconon of Georgia is a purely secular program is because of your belief about what's in this IRS agreement that was reached in the

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1990s? A That's largely true, yes. Q. Well, if we have documents from the 2000s and,

4 the, you know, 2008 time frame where Narconon of Georgia s has filed for tax-exempt status based upon something

other than religious grounds, and the IRS has accepted that, then wouldn't that be evidence that Narconon of

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A. Even if that is the case, N arconon of Georgia is still using central concepts from Scientology, which has charitable status based upon largely its religious claims.

Q. Well--13 positively not religiou s. That's what I'm hearing you 13

14 say. Because of your belief in what the IRS has done. 14

15 A. That's correct. 15 A. Now, these ancillary organizations may--16 you're suggesting may have charitable status based upon

other claims. That may or may not be hue. But the 16 Q. But there's a difference, I think, between 17 being hesitant to agree that it's 100 percent secular 17

18 based upon your belief about what the IRS has done 18

19 versus corning in and affirmatively testifying that you 19

2 o think it is religious. 20

21 A. Well, once again, Scientology has the 22 charitable status, and that charitable status is a real 23 privilege because of the tax benefits it gives. It's 24 always appeared to me that in-- that Scientology's 25 tried to have it both ways in some cases.

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central Scientology claims, you know, appear throughout the Scientology organization, and that's what has charitable status based in part upon its religious claims.

Q. Do you think that Scientology would have been able to get religious status if they did not claim belief in the supematural?

A. I think it would have -- there are such things

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1 as functional religions, but I'm not sure they get 2 charitable status based upon those actions. I mean, I'm 3 not sure what the requirements are in the U.S. 4 government to get religious status. And that's a --5 it's an interesting constitutional question. 6 Q. But I think bottom line is you're not an 7 expert on taxes, tax-exempt status, nonprofit status, or 8 what the IRS does or does not do in tenns of treating 9 people as tax-exempt?

10 A. All that's true. 11 Q. And you don't have personal knowledge, or any 12 knowledge, really, other than, you know, an earlier 13 draft of what you believe was an agreement that was 14 entered into between the IRS and the Church of 15 Scientology? 16 A. I'd say it's not-- I don't think it's an 17 earlier draft; 1 think it's the last draft before the 18 decision. 19 Q. And what's the basis of that belief? 20 A. The Wall Street Journal got ahold of a copy 21 and released it to the public. 22 Q. But there was a subsequent agreement, and you 23 have not seen that? 24 A. I haven't seen the final agreement, no. 25 Q. And you don't know what changes were made

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1 between the draft that the Wall Street Journal released 2 and the final agreement? 3 MS. FRANKLIN: Object to the form. 4 THE WITNESS: I don't know, other than 5 the con -- the reality in consequence is that 6 all the ancillary organizations to 7 Scientology have charitable status. So ... 8 BY MR. MILLER: 9 Q. Well, but the basis for that charitable-- I

10 mean, you don't know what the ultimate decision was 11 about why some of these organizations were given 12 charitable status, do you? 13 A. No, I don't. 14 Q. And you haven't talked to an IRS lawyer or a 1 5 lawyer for the Church of Scientology who negotiated 16 these agreements, or anybody who had personal knowledge 17 of what the final agreement looked like? 18 A. I did talk to someone. 19 Q. And who was that? 20 A. I -- a IRS agent. 21 Q. What's that person's name? 22 A. I have no idea. It's been quite a number of 23 years ago. 24 Q. When did you talk to him? 25 A. God. Late -- it could even go as far back as

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the late 1990s. Q. Okay. A. I mean, I can't even begin to give you an

exact date. Q. Was this before or after a final agreement had

been reached? A. It was after. Q. And what did the IRS agent tell you? A. I asked him a number of questions. He did not

reveal any secrets. Did not reveal anything about the final agreement.

Q. Because the final agreement was confidential? A. That's true. Q. So he did not reveal any detai Is about the

fmal agreement? A. That's true. Q. So what did he tell you? A. He said a number of things. He said, for

example, that, I'll say it, one or more IRS agents had been harassed, been followed, by either Scientologists or Scientology-hircd Pis, and I said, "Well, bow did you know they were Scientologist?"

He said, "Well, we got their license plates and we relayed it to the FBI." And he said, "This kind of thing happens to us all the time."

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Q. Maybe I should be more focused on my question. Did he tell you anything having to do with the tax-exempt status ofNarconon of Georgia--

A. No. Q. -- or Narconon Intemational? A. Not at all. No. Q. And no details about the confidential

agreement that was ultimately reached? A. He did not breach any issues of

confidentiality, as near as I can recall. Q. Where was the IRS agent from? A. Washington. Q. Was he in a Washington office? A. Yes. Q. And do you know if he had anything to do with

the negotiations of the agreement? A. I thought so, but I couldn't tell you exactly

what role, if any, he played. I mean, he certainly was knowledgeable about it, so ...

Q. Well, knowledgeable in the sense that he may have known information but he didn't share it with you about what the final agreement looked like?

A. Oh, he did not share that with me. Q. Okay. Looking at Exhibit 8, based upon either

your review of Nick Parsons' books or your review of an

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1 earlier version, can you very briefly tell me what in 2 each of these books are principles that you would relate 3 back to L. Ron Hubbard? 4 A. Okay. And I'll stick really to the-- as much 5 as I can, to the 2004 books here. 6 Book 1 involves, you see, a "TR Course"; 7 they're short for training routines. And they're very 8 basic routines that people go into often in their first 9 moments in Scientology. There are TRs 1 through 4; I

1 0 think, as I said earlier, I don't believe I've ever seen 11 a TR5; and there's 6 to 8. Now, in this book there's 12 also a 9. But I think the ninth training routine is 13 just a repeat of 6b. So the training routines, they go 14 back decades in Scientology. 15 Q. These training routines, as I understand it in 16 this first book, have to do with helping people 17 communicate with each other? 18 A. That's what Scientology says. 19 Q. Okay. Anything else about book number I that 20 you would relate back to Scientology, other than the 21 fact that it has what are called training routines in 22 it? 23 MS. FRANKLIN: Before you answer, I'm 24 just noting for the record that the books are 25 not in front of Dr. Kent, and we have those

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1 available; if you choose to question him 2 about it and if he needs those, then he can 3 indicate that. 4 THE WITNESS: Okay. Each one of those 5 training routines bas an exact parallel in 6 Scientology materials. An exact parallel. 7 And the wording of the routines is the same. 8 So it's impossible to make -- come to any 9 other conclusion than the training routines

10 in the Narconon program come from 1l Scientology. 12 BY MR. MILLER: 13 Q. Well, and Scientology comes from the mind of 14 L. Ron Hubbard? 15 A. That's hue. 16 Q. And so the Narconon book number 1 is based on 17 the works of L. Ron Hubbard is what you concluded? 18 A. That's hlle. Yes. 19 Q. And the same for the other books where the 20 front covers are identified by Exhibit 8? 21 A. Yes; all of them have direct bases in existing 22 Scientology courses that drew directly -- that Narconon 23 drew directly from. 24 Q. You know the hist01y ofNarconon, where it 25 came from?

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A. Came, at least the Scientology story goes, in 1966 in tlte Arizona state prison. A gentleman named William Benitez found a Scientology book in the library and read it, was impressed by it, started doing some processes with other prisoners. They felt it benefited them. He eventually got some permission to do some other prisoners. And I think from that contact-- it was '66. By about '72 -- not -- but the early -early-- what's now called Narconon didn't -- it only involved -- it didn't involve the purification program. It only involved different sorts of training routines and so on. So the Narconon program now is different in content.

Then by the early '70s, 1 think in '72, there was a Narconon program that opened up in California, and then also, fairly soon afterwards, a Narconon program statted doing the Purification Rundown.

Now, the-- but to go back earlier, for history, you really have to go back to the 1950s. To look at Hubbard's writings about radiation. I mean, as we all know, tlte '50s was a time of great concern about atomic radiation. In this country there were aboveground testings that were going on, and a number of people were in communities where the wind changed and they got doses of radiation from the tests. So back in

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the '50s Hubbard was claiming that he had developed techniques that could 1id the body of radiation residues. And those claims eventually migrated into the Purification Rundown. So the Pur -- claims that it is able to expel from the body drug and radiation residues. Although the one drug it omits is, of course, nicotine, and I always assumed it omitted nicotine because L. Ron Hubbard smoked.

The Crirninon program started later, and, in my estimation, I don't believe the Criminon program routinely now runs the Purif. It does a number of exercises for criminals, but 1 don't think it runs the Purification Rundown. I think that's limited primarily now to Narconon. So it's --now Narconon has most --well, a great number of the services are outside of prisons. I can't say whether it still has any active . . . m-pnson servtces.

Q. Would it be fair to say that the Narconon program, since it started in 1966 with the man who was in prison who organized some prisoners and they got off drugs and alcohol using L. Ron Hubbard's principles, that it's evolved over the years?

A. Well, the figures I've seen in those early days claim that the success rate of getting people off was somewhere between 60 and 70 percent plus. The

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1 trouble is their claims and the documentation, 2 throughout the whole Narconon programs, to back up those 3 percentages is in dispute. Now, I'm not going to cover 4 those issues in my -- in my expett statement. I think 5 that's up to a drug expert. So -- so I think 6 Scientology would agree with your representation; 7 historians might raise some questions about it. 8 Q. Well, I'm not sure if that's the question I 9 asked; let me approach it this way. First, clearly,

10 you're not going to offer an opinion about what the ll success rate ofNarconon is --12 A. No. 13 Q. --or is not? 14 A. I'm not going to offer an opinion about the 15 success rate ofNarconon. 16 Q. Or its success rate compared to any other 17 program? 18 A. Nor its success rate to any other program; I'm 19 not going to offer any opinion on it. 20 Q. Right. My question I was going to ask was, as 21 you've already mentioned that pmification got added in 22 at a later time, that the program materials, and the 23 program itself, have changed somewhat in tem1s of the 24 materials being used and things like that? 25 A. Yes, sir, that's true .

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1 Q. And matelials that you've looked at for the 2 most part would have been mate1ials that were in use in 3 2008? 4 A. Well, my star-- the records go back farther 5 than that in some of the matelials I'd submitted. 6 Q. That's not a very good question. You looked 7 at Nick Parsons' books, which would have been I believe 8 books that would have been used around the 2008 time 9 frame?

10 A. That's correct, yes. l1 Q. And where you had some gaps, you may have gone 12 back and looked at books that go back to 2004 or 1 3 something like that? 14 A. Yeah. The-- the two copyrights, ifl'm not 1 5 mistaken, in the Narconon books is 1991 and 2004. 1 6 Q. Okay. But for the most part, in terms of 17 evaluating the course pack materials, you're looking at 18 what I'll call kind of modem N arconon materials, 19 compared to something that might have been used back in 20 the 1960s or 1970s or even the 1980s? 2 1 A. I've got-- I submitted some materials back 22 from the early period, but in terms of the training 23 materials and course exercises, I'm basing them upon 24 modem-- modem Narconon. 25 Q. Okay.

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I think there's some interesting historical materials that may provide some light about Narconon, but that's what l'm basing, primarily, my discussion on.

Q. Going back to the discussion we had a few minutes ago about whether or not there was any religious element to the Narconon of Georgia --

A. Uh-huh (affirmative). Q. -- materials; do you have any opinion about

whether Narconon of Georgia was trying to recruit people to the Church of Scientology?

A. I don't intend to give a specific answer on that question. I can speak generally about Narconon and possible recruitment. But in tenns of actually what went on on the day-to-day basis in Narconon Georgia, I'd rather defer to others.

Q. Okay. So you're not going to offer the opinion that Narconon of Georgia was trying to recruit people to the Church of Scientology?

A. I don't plan to offer the opinion. I would say that if -- generally in Narconon, if a person graduates from the program having done the purification, a number of people do enter Scientology. But that's as far as I go. I'm not going to say that -- that there was an active recruitment program in Georgia.

Q. Do you know of anybody in Georgia who went

Page 100

through the Narconon of Georgia program who claims that they were recruited in any way for the Church of Scientology?

A. No, sir, I don't. Q. Do you know anybody who went through any other

Narconon program that you have personal knowledge of who says that they were recruited for the Church of Scientology?

A. I know there's a Canadian, for example, and I can speak about him because he's been very public. 1 think his name is David Love. He claims to have been --to have gone through Narconon and through the program.

Q. Other than David Love, is there any other person that you've heard who went through the Narconon program who claimed there was any effort made to recruit them to Scientology?

A. I'd have to think about it, because I've talked to people who have been to the Narconon program, I've talked about -- talked to people who have been Seientologists who went through the Purification Rundown, and it's easier for me to jumble what their stories are. So I'm not going to base any of my claims on any of these stoties. If that allays your concerns.

Q. Are you going to go in and testify in this case that Narconon of Georgia or Narconon International

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1 are organizations that recruit for the Church of 2 Scientology?

1 that case here, but I don't want to retreat from the 2 general position.

3 A. The -- I offered two documents in my 3 MR. MILLER: Let me mark a couple 4 submissions. And these are old documents. One shows 4 exhibits. 5 people going into the Purification Rundown, and at the 5

6 end they leave the Purification Rundown and enter into 6

7 an archway that says "Scientology." 7

8 Q. Right. B

9 A. And the other is a pamphlet, I'm not even sure 9

10 what year it was, that says, "Narconon is the bridge to 10

11 the bridge." 11

12 Q. Okay. I think I'm familiar with those 12

13 documents. 13

14 A. Yeah. And so they're -- that's why I'm-- I 14

15 won't say that Narconon Georgia was doing that, but I 15

16 would-- if pressed, I would say that-- that people do 16

17 move from one to the other. 17

18 Q. Well, I think it's different to say that 18

19 people might move from, -- 19

20 A. Uh-huh (affirmative). 20

21 Q. --you know, Narconon, to decide to join the 21

22 Church of Scientology, and trying to contend that this 2 2

23 drug and alcohol progran1 is somehow trying to recruit 23

24 for the church. 24

25 A. Well-- 25

Page 102

1 Q. I mean, if you help change my flat tire and I 1

2 find out that you're Methodist, I might be attracted to 2

3 go to the Methodist church, -- 3

4 A. U11-huh (affinnative). 4

5 Q. -- I suppose, right? 5

6 A. Well, again, these are all-- the Narconon 6

7 courses are all based upon the low-level Scientology 7

8 courses. And 1 seem to recall--and 1 can't tell you 8

9 where 1 read this, and I could be wrong about this, but 9

10 I'll offer it with that caveat--that when -- part of the 10

11 assessment people go through when they enter Narconon is 11

12 they go through-- they get an Oxford Capacity Analysis 12

13 test on them. If my memory-- if that's in fact true, 13

14 then the Oxford Capacity Analysis is often a recruitment 14

15 tool for Scientology. So -- 15

16 Q. It's the Oxford -- 16

17 A . OCA, it's called; Oxford Capacity Analysis. 17

18 Now, again, I'm-- I'm not going --because I'm not 18

19 going to argue about-- talk about the daily routines of 19

20 Narconon Georgia, so I'm not going to say it was 20

21 actively recruiting. But I'm also -- I know in general 21

22 Sci -- people can and sometimes do move from Narconon 22

23 into Scientology. 23

24 Now, whether that var -- that probably varies 24

25 from organization to organization. I don't plan to make 25

(Thereupon, marked for identification purposes, Defendants' Exhibit Nos. 9 through 11.)

BY MR. MILLER: Q. I think I've located the two documents that

you've talked about. MR. MILLER: Do you have a stapler in

here, Rebecca? MS. FRANKLIN: I can grab one.

(Brief recess.) BY MR. MILLER:

Q. Dr. Kent, Exhibit 11 I believe is the document-

A. Yes. Q. --that has the ... A. Yes, this is the one that has the -- published

by Bridge Publications, which I believe also is the publisher for the Narconon course pack. It has a picture of people going into the -- I'll call it a gate -- a gateway called "Purification Rundown," and then later on in the book it -- a person claims to be --

Page 104

regained his life and is then marching in to Scientology.

Q. And Exhibit 10 is the other document that you referred to?

A. That's right. This is an earlier, '74, "Narconon helps ... people up Ron's bridge to freedom," and it's-- "Nareonon is the bridge to the bridge." And, see, it's often the case that Narconon's staffed by a number of Scientologists. Now, it's an open question the extent to which they may or may not talk about their practice of Scientology, but-- so that's why I'm not going to comment on what may have happened in the Georgia case, but I don't want to back away from the general concept that people often move from one to the other, and that Scientology has aspirations that people would move in that direction.

Q. Okay. Well, let me break that down and ask you some ques tions. First of all, in your stack of materials, your file materials that we've marked as Exhibit 2, do you have any reason to believe that any of those documents were used by anybody at Narconon of Georgia?

A. No. No. Q. Or that these were seen by any students who

went through the Narconon of Georgia program in the

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1 2000s and later? 2 A. I don't recall -- I'm trying to remember the 3 "Clear Body, Clear Mind" more recent documents, but I 4 don't trunk anything like what we're talking about is in 5 the more recent documents. 6 Q. Right. And the Exhibit No. 10 is a document 7 from 1974? B A. Uh-huh (affirmative). 9 Q. Is that correct?

10 A. Yes, sir. 11 Q. And do you know when Exhibit No. 11 was 12 published? 13 A. I thought I had-- it looks --it's a bit bard 14 to read here. It looks like, and I'll defer to your 15 judg -- it looks like that says 1984? Does that seem 16 true to you? 17 Q. It certainly looks possible, so based on what 18 we can see here, it looks like this may be from around 19 1984? 20 A. Wouldn't surprise me. 21 Q. Do you have any documents that are less than 22 20 years old that would suggest to you in any way that 23 there is any expectation that people who go through the 24 Narconon drug and alcohol program are going to later 25 become Scientologists?

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1 A. Yeah. I don't think I -- I cannot recall 2 having any documents that make that case. But the 3 absence of documents shouldn't be taken as an absence of 4 intent or aspiration or satisfaction. If that move 5 indeed occurs. 6 Q. Do you have any basis to offer an expert 7 opinion that within the last ten years that there is any 8 effmt to get people who go into the Narconon programs 9 to become members ofthe Church of Scientology?

10 A. Well, there isn't evidence that I'm going to 11 introduce in this case. If that --12 Q. So there is no evidence that --13 A. That I'm going to introduce in this case, 14 along those lines. 15 Q. And if you have no evidence that you're going 16 to introduce in this case, can I fairly assume that 17 you're not going to offer the opinion in this case that 18 within the modem, last ten years, let's say, that the 19 Narconon programs are intended to recruit people for the 20 Church of Scientology? 21 A. I had intended to be neutral on the point. 22 Q. I'm comfortable with you just not offering 23 that opinion; --24 A. Uh-hub (affirmative). 25 Q. -- I just want to make sure you're not going

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to offer that opinion. A. Yeah. Again, I had not planned to get into

the daily operations of what's gone on in the Narconon Georgia program, --

Q. Right. A. -- 'cause I think that takes a different kind

of expertise. That requires talking to people, looking at their affidavits, you know, and that just isn't what I was required to do here,--

Q. Right. A. --so ... Q. And I appreciate that fact. But I'm asking a

little broader question. Which is, 1 want to make sure that you're not going to come to court in this case and say that in the modem era, in the 2008 time frame, that Narconon programs were being used to somehow recruit for the Church of Scientology?

A. I hadn't planned to make any statements along those lines.

Q. Okay. And the reason I'm asking is because if you were going to offer that opinion at trial, I would need to spend a lot of time asking you what the basis of that--

A. Sure. Q. -- opinion would be.

Page 108

A. 1 understand. Q. But as long as we have an agreement you're not

going to offer that opinion at trial, then I can move on.

A. That's flne, you can move on. Q. Okay. And Exhibits 10 and 11 I think we can

agree are probably going to be irrelevant in terms of anything that you're going to point to or rely upon in reaching your opinions in this case?

A. I--MS. FRANKLIN: Object to the form. THE WITNESS: I -- at this point I

cannot see bow I would use them. BY MR. MILLER:

Q. Some of these documents that you've produced are incomplete, you know, they're missing pages, --

A. Sure. Q. -- they're just excerpts. Have you given us

evetything you have from any of these particular documents, or did you pick and choose from a larger document that's sitting in Canada?

A. Oh, I --just to save on photo -- on photocopying, l didn't photocopy, for example, the whole purification book.

Q. Okay.

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A. I was even surprised that so much of the IRS agreement is -- I don't recall photocopying all of that; now, maybe I did. But -- and some of these are just short excerpts, and they would be part of larger

5 documents. But in terms of what 1 was using, if there 6 were a magazine, for example, I wouldn't photocopy all

six pages ifl was only using one small section. 7

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Q. So where we have incomplete documents, the complete documents may exist back in your file?

A. That's uue.


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1 So I've read it somewhere; whether it applies 2 to Narconon Georgia I'm not entirely sure. I may have 3 seen it when I was looking through the Mary Rieser 4 material, but --5 Q. Okay. But if there's evidence in the case 6 that Patrick Desmond and other students were not 7 . receiving an Oxford Capacity Analysis, you're not going

to dispute that? B

9 A. No, I wouldn't dispute that at all. 10 Q. I think we talked about on Exhibit 8 the first 11 book What is it about the second book that is an

12 Oxford Capacity Analysis, but do you know one way or the 12 L. Ron Hubbard principle? Q. And I think you mentioned something called the 11

13 other whether the Oxford Capacity Analysis was being 13 A. "Clear Body, Clear Mind." The Purification 14 used at Narconon of Georgia? 14 Rundown is a program -- the detoxification program in 15

16

A. Well, I have-- I'm not sure. 15 Narconon is the same as the Purification Rundown in Q. What is the Oxford Capacity Analysis? 16 Scientology. And the Purification Rundown in

17

18

A. Oxford Capacity Analysis is a 200-item 17 Scientology was developed by L. Ron Hubbard. In its

19

questionnaire that Scientologists claim identifies areas 18 various dimensions. It involves claims about the value, in a person's life that need improvement. I've seen it 19 first, of running; second, fairly long periods--up to

2 o used in variations as a recruitment tool so people can 2 o five hours, if possible--of saunas; it involves taking a come in off the street. There'll be an advertisement, 21 particular-- the-- Hubbard's claim was that -- that "Get your personality-- free personality test." And 22 drugs absorbed vitamins from the body. Hence he had a

21

22

23 they'll be given an Oxford Capacity Analysis test. 23 drink called Cal-Mag, which is calcium and magnesium. 24 There are-- I've seen it used as an initial 24 He also had a particular increasing vitamin dosage that 25 IQ test, I've seen it used in a variation as a work-- 25 people are supposed to take, including niacin. That

Page 110

1 work analy -- hiring document. So it's got variations. 2 As far as I know, and I know this fairly well, 3 it doesn't have any standing in the psychological 4 community. It's a straight Scientology program. And 5 the Scientology documents that I have talk about how 6 it's --how it's marked. And the way that it's marked 7 is always for the --for Scicntologists to mark it and 8 identify some apparent weak spots on the chart and say, 9 "We can handle this. We can help you improve this."

10 Q. Okay. My understanding is you have not 11 reviewed Patrick Desmond's file from Narconon of 12 Georgia? 13 A. I don't think so. 14 Q. And you don't know whether his file contains 15 an Oxford Capacity Analysis or not? 16 A. I'm not sme. You know, I say I had those two 17 depositions from ... Oh, the head ofNarconon Georgia, 18 is it Mary Rider? Rieser, Mary Rieser. And there are 19 some documents attached to the back. But, again, I 20 looked at them a long time ago and very quickly. So 21 that's why I'm being hesitant, because I'm not-- I'm 22 not speaking definitively, and I've said I'm not using 23 those documents in my--24 Q. Okay. 25 A. --in my-- analysis.

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1 he -- he claimed that drug and radiation residues were 2 stored in the fatty tissues of the body and the niacin 3 helped open up pores that would expel these drug and 4 radiation residues from the body in sauna. 5 Q. And the medical effect or the physiological 6 effect of detoxification, you're not going to offer 7 opinions about that? 8 A. I'm not going to talk about it, no. 9 Q. What about book number 3, "Learning

10 Improvement Course"? 11 A. I think earlier I talked about what's in it, 12 and the content is straight Scientology assumptions 13 about learning how to learn and barriers to learning. 14 Q. Helping people to be better students, not 15 stumbling over-- you know, not ignoring a word they 16 don't understand but look it up in the dictionary, that 17 type of thing? 18 A. Some other factors. Yes. 19 Q. How about book 4a, "Communication & Perception 20 Comse"? 21 A. If I remember correctly, 4a is a-- more or 22 less a repetition of the TRs. And it's in preparation 23 for 4b, which is an analysis of the objectives. Now, it 24 seems to me Hubbard made a statement, maybe in the late 25 '60s, that the objectives were very useful to someone

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1 who had been on drugs. Because it-- maybe-- his 1 Q. How about number 7? 2 assumption was that people who had been on drugs were 2 A. "Changing Condition ... " You know, the 3 not oriented to the present time. They were often 3 conditions are principles that-- or , concepts that 4 oriented toward past events, often negative events. And 4 Scientology uses in order to identify either where one 5 the objectives were ways he thought would bring them up 5 is in relation to patiicular work assignments or where 6 into present time. Similar in many ways to some of the 6 the particular organizational operation is in relation 7 TRs and what's often called "locationals" in 7 to work assignments. So it has to do with, on the top 8

9

Scientology. 8 end, people in a position of power who are really Q. Book 5? 9 blasting ahead with their -- with their success.

10 A. "Ups and Downs in Life Course" is a straight 10 There's a level about people's ability to write down 11

12

rendition of Scientology's concepts about social 11 what they're doing in a power position so they can pass personality, antisocial personality and a potential 12 it on to a person who may fulfill the job later.

13 trouble source. 13 Then it goes down into various levels about 14 Q. "Avoid people who are negative influences on 14

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your life," that smi of thing? A. That's a -- not to disparage what you say,

that's a simple version of what an antisocial personality is. I think there's 12 or 14 characteristics that are -- that are listed in there. And 12 or 14 parallel characteristics of the social

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21 personality. And a PTS is somebody who's associated 21

22 with an antisocial personality. But through that 22

association, the person's being brought down by, you 23

24 might say, the negative energy of the PTS. The person 23

24

25 2 5 finds him- or herself on a roller coaster and so on.

Page 114

1 Q. It looks like you're married? 1

2 A. I am. 2

3 Q. Do you have children? 3

4 A. Don't. 4

5 Q. I was going to ask because it's like telling 5

6 your kids not to associate with people that you think 6

7 are going to lead them in a bad direction? 7

8 A. Well, I'm not going to get into the ways that 8

9 these contents are used. 9

10 Q. Okay. How about book number 6? 10

11 A. "Personal Values and Integrity --" -- there's 11

12 actually a whole Scientology course, I think it's called 12

13 "Personal Integrity and Values." I could have the order 13

14 of the terms switched. But these are I believe moral 14

1 5 of-- I'm trying to remember when Hubbard talked about 1 5

16 morals. B ut these are--I'll use this term; it's not one 16

17 that Scientology used--the principles that Hubbard felt 17

1 8 were important for people to follow. And they're in 1 8

1 9 some ways similar to what happens on The Way to 19

20 Happiness. 20

21 Q. Things like being honest and things like that? 21

22 A. I'm not sure where the being honest-- whether 22

23 it shows up in that "Personal Values and Integrity 23

24 Course" or The Way to Happiness. But those kind of 24

25 principles show up in one or the other. 25

normal -- normal, which is a person or an operation that's moving ahead, having -- having constant but low increases. Then it keeps going down into -- it gets down --lower and lower into, you know, negative conditions. And I -- I forget the order. I think, you know, the bottom one talks about a chaos a person's life may be in. There's a person who is -- who's labeled as being treasonous, or condition is treasonous. And there's one with enemy, and one with doubt, and so on. There's quite a, you know, a number of them. And one is supposed to be able to locate one's own behav -- in an organization, really in a relationship, one's supposed

Page 116

to be able to locate one's self in one of those conditions. And try to raise up to the next one.

Q. And what is book number 8, "The Way to Happiness"?

A. "Way to Happiness." If you look at the back of the Narconon course pack, you'll see The Way to Happiness booklet is a smaller booklet. lt was a paperback. There's actually a hardback version of The Way to Happiness that's produced, and it -- I'm not sure when it came out. It might have been as late as the early 1980s. But my understanding is that Mr. Hubbard wanted to produce a document that he said was secular in nature. So there's no mention about anything religious in here, about fates or whatnot.

Q. And no mention of anything religious in any of these books that we've talked about?

A. There are some mentions of religion in terms of -- in one of these upper-level courses, it -- I'm not even sure which one it would be. It's what's called the dynamics. The dynamics arc eight levels of existence for Scientologists. And, again, fearing that I may omit some, it starts with self, and then the second level's currently called creativity; before it used to be family and sex. Third was -- they use the term "mankind"; I'd say "humankind." Fourth would be I think-- I think

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1 it's all species. Fifth I think is the -- the universe. 1 Concepts," and the desire to survive through these. The 2 Six is spirit, and seven is infmity. I thought there 2 seventh dynamic is life source; this is separate from 3 were eight, so I may be forgetting one. But the upper 3 the physical universe and that's the source of life 4 two involve spirit and infinity. And they're mentioned, 4 itself. Best there are some efforts for the survival of 5 if I'm not mistaken, in the-- in the Narconon course 5 life source. 6 that deals with them. 6 And then there's some cartoons, and then --7 Q. Which book do you think it's in? 7 and when I say "cartoons" I don't mean to disparage 8 A. Oh, goodness. 8 these cartoons. Some of these are very talented 9 MS. FRANKLIN: Do you need the books in 9 illustrations. You know, for lack of a better term, I

10 front of you? 10 use the word "cattoon," but I'm really quite impressed 11 THE WITNESS: Well, it might take a few 11 with whoever the artists were. 12 minutes, but it'd be easy to -- it'd pin it 12 And then there's -- on Page 69 there's a clay 13 down exactly. 13 demo; "Demonstrate what the seventh dynamic is. Get a 14 MS. FRANKLIN: Are they in your bag? 14 pass on this from the supervisor." Then there's the 15 THE WITNESS: I brought them in that 15 eighth dynamic. The eighth dynamic is the urge toward 16 roller thing today. This morning. 16 existence as infinity. The eighth dynamic is commonly 17 MS. FRANKLIN: Want to take a break and 17 supposed to be a supreme being or creator. It is 18 get them? 18 correctly defined as infinity, it actually embraces the 19 MR. MILLER: Yes. 19 allness of all. 20 THE WITNESS: Okay. 20 Page 72, "Demonstrate what the eighth dynamic 21 (Recess at 1:08, resumed at 1:25.) 21 is. Get a pass on this from the supervisor." 22 BY MR. MILLER: 22 "An individual who seeks survival on one or 23 Q. Dr. Kent, while we were on the break you went 23 all of these dynamics fails when he abandons a dynamic 24 and retrieved the books that you've reviewed last night 24 as a survival route." So a person is supposed to work 25 and then I guess partially this morning, and in terms of 25 on all those levels. And the reason I had this marked

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1 that last series of questions I was asking you, you've 2 identified book number 6, entitled "Personal Values and 3 Integrity Course," and the seventh dynamic talks about 4 that people are urged to be spiritual, in effect, and 5 then the eighth dynamic talks about the possibility of 6 the supreme being or creator? 7 A. That's right. s Q. And so these would be the two things you would 9 point to in this book number 6, along with... It looks

10 like on Page 595 there is a space where somebody can 11 talk about what their spiritual beliefs might be or what 12 their belief in the supreme being might be? 13 A. Would you mind -- I want to check-- if you 14 don't mind, Mr. Miller, 1 want to check through 15 something else. 16 Yeah, just to get -- the -- it's on 65, it's 17 called the seventh dynamic. The seventh dynamic is the 18 spiritual dynamic, the urge to survive as spiritual 19 beings, or the urge for life itself to survive. 20 Anything spiritual, with or without identity, would come 21 under the heading of the seventh dynamic. It includes 22 one's beingness, the ability to create, the ability to 23 cause survival or survive, the ability to destroy or 24 pretend to be destroyed. 25 A subheading in this dynamic is "Ideas and

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1 in the back. .. And this is, as you indicated on 595, 2 "Write--" --okay. This is what I was looking for. 3 "Write up your overts and withholds on your seventh 4 dynamic. Do this until you are satisfied that they are 5 complete and you feel good about it and have experienced 6 relief." Now, "overts and withholds" is another classic 7 Scientology term. 8 And then -- let me see. Page 607, "You may 9 use this space to write down any wins or gains you had

10 while writing up your overts and withholds on the 11 seventh dynamic." 12 "Write up your ovetts and withholds on your 13 eighth dynamic. Do this until you are satisfied they 14 are complete, and you feel good about it and have 15 experienced relief." So they were asking people to 16 identify any issues they may have not brought forward 17 about these dynamics. And the withholds and -- the 18 withholds eventually become an overt act. TI1e process 19 of withholding. To write these up. So, llmow we 20 talked earlier about whether I had seen anything 21 spiritual in these books; I had forgotten all about that 22 section, but--23 Q. Okay. Well, that's fair. I had told you we'd 24 come back to the books, --25 A. Sure.

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Q. -- and I appreciate you getting the books. With the benefit of having the books in front of you, Dr. Kent, other than the materia ls we've just talked about in book 6, anything else in here that you would identify as spiritual or religious?

A. lfl may? Q. Sure. A. There's more -- "Demonstrate to supervisor

using a demo kit an example of a survival action on each dynamic and why that action would be a survival action." And it lists the eighth dynamics, including the seventh and the eighth dynamic. It's on Page 79.

Q. Well, again, I'm not asking you to identify every page in book 6 --

A. Uh-bub (affirmative). Q. -- that may discuss the seventh or eighth

dynamics. But I think what you've told me now is that the seventh and eighth dynamics have a spiritual dimension to them?

A. That's my understanding. Q. Okay. What I want to do is just find out,

other than what we're talking about here in book 6, now, is there anything else that you would identify as being spiritual or religious in the Narconon course materials?

A. Let me look through this for a second.

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For what it's worth, this is on Page 120. "When one thinks of survival, one is apt to make the error of thinking in terms of barest necessity," in quotation marks. "That is not survival. Survival is a graduated scale with infmity or immortality at the top, and death and pain at the bottom." So 1 don't recall any other issues, but it...

I just am afraid if I close it up 1 might miss something that could be important. So if! could indulge you just for another minute or two.

Q. Sure . That's fme. Although, again, I'm going to mark book 6 as an exhibit to the deposition, -

A. Sure. Q. --and I think to the extent it touches on

that seventh or eighth dynamic, we will have already discussed it, so ...

A. Okay. Ethics and morals ... I' ll let that-let it go from there and ...

MR. MILLER: Let's mark book 6 that Dr. Kent's been looking at as the next exhibit.

Want to just put it on the front cover? MS. FRANKLIN: Yeah , shecan putiton

the front cover. (Thereupon, marked for identification

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purposes, Defendants' Exl1ibit No. 12.) BY MR. MILLER:

Q. Okay, that's now marked as Exhibit 12 to the deposition.

So, Dr. Kent, with the exception of what we've talked about in book 6, you would still agree that there's nothing else in these materials that you would identify as being religious?

A. Not that 1 can recall at this time. Q. And what's in book 6 about spir ituality or the

possibility of a supreme being, it's not advocating any particular spiritual belief, is it?

A. I didn't get that impression. Q. It could encompass Christianity or Judaism or

Buddhist philos -- I mean, religion? A. I didn't see it specific to any one

particular. Q. And just from your common knowledge of things,

not as an expert but just commonly, are you familiar with the fact that Alcoholics Anonymous, for example, talks about spiritual things and the belief in a higher being or a higher power?

A. I've heard that about Alcoholics Anonymous. 12-step program.

Q. Right. So it's not uncommon for a drug or

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1 addiction program to encourage people to get in touch 2 with some sort of a spiritual dimension? 3 A. I do know there's controversy about the 4 12-step program precisely for that reason. 5 Q. But, again, you're not going to offer opinions 6 about Alcoholics Anonymous and their 12-step program any 7 more than you're going to offer opinions about Narconon 8 and its program? 9 A. That's true; I'm not going to talk about the

10 12-step program at all. 11 Q. Okay. So going back to your opinions that 12 you're going to offer in this case, I think on your 1 3 opinion number 2 1 can fairly summarize it in this way, 14 but I want you to let me know if this is not a fair--15 A. Okay. 16 Q . -- summary of your opinion number 2. 1 7 L. Ron Hubbard had a series of principles that 1 8 were incorporated into what we now know to be the Church 19 of Scientology, and those similar principles, at least 2 o with regard to the matters that are touched upon in 21 these books, were also incorporated into Narconon's 22 materials? 23 A. I'd be a bit stronger. I'd say that L. Ron 2 4 Hubbard included in Scientology techniques, principles, 25 morals, etcetera, that transferred it directly into the

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1 Narconon program. 2 Q. The Narconon books are based on the works of 3 L. Ron Hubbard, correct? 4 A. That's -- that's very true, yes. 5 Q. Okay. 6 A. Says so right on the front cover. 7 Q. Right. In other words, the book themselves 8 all state on the front cover they're based on the works 9 ofL. Ron Hubbard?

10 A. That's right. 11 Q. And you would agree with that? 12 A. Yes. 13 Q. And your ana lysis of those books and your 14 knowledge of L. Ron Hubbard's writings is consistent 15 with that? 16 A. That's true, yes, sir. 17 Q. In other words, your expert opinion basically 18 on number 2 is that these Narconon ·materials are based 19 on the works of L. Ron Hubbru·d? 20 A. That's true. 21 Q. As far as number 2 is concerned, is there 22 anything beyond what we just talked about, that these 23 books are based on the works ofL. Ron Hubbard, that you 24 concluded? 25 A. If we had the time, I could go through each

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1 one and I'm sure there's many more examples. But I 2 don't want to, you know, tie us up all day doing that. 3 But -- so, you know, concepts, terms, techniques come 4 straight from Scientology. 5 Q. Okay. So your opinion on number 2 is, it 6 sounds like, bottom line, what we just talked about, 7 which is that these books incorporate L. Ron Hubbard's 8 works and principles. Not just the specific examples 9 we've talked about, but other examples as well?

10 A. Well, L. Ron Hubbard's, but also, more 11 specifically, Scientology's opinions-- or, doctrines, 12 opinions, techniques that Scientology uses. 13 Q. But Scientology is in effect based on L. Ron 14 Hubbard's works as well? 15 A. That's true. Scientology is based upon the 16 works. But a lot of these tenns predate Narconon. And 17 a lot of these terms go back to the very early -- early 18 days in Scientology, so ... 19 Q. But the early days of L. Ron Hubbard as well? 20 A. Uh-huh (affirmative). 21 Q. Right? 22 A. That's true, yes. 23 Q. Let me ask you what your opinion number 1 is. 24 It says you intend to "provide testimony at trial 25 outlining the beliefs and practices of the members of

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the Church of Scientology." A. Well, it depends upon what somebody would ask

me about -- about them. Q. Let me divide it up for a minute. A. Sure. Q. Whatever the beliefs are in Scientology, you

would respect people's right in a religious context to enjoy whatever beliefs they want?

A. In the abstract, separating beliefs from any kind of action, people can hold in their consciences whatever they want.

Q. And in terms of practices, would I be correct in assuming that as long as a practice is not harmful to other people, you would be of the opinion that you can practice whatever you want in connection with your religion as long as you're not harming other people?

A. That's true. Now, it may be of academic interest to study what the practices are, and even study what the beliefs are. But in terms of any kind of intervention to limit beliefs or practices, it has to be based upon -- intervention has to be based upon harm.

Q. So you have been a critic of the Church of Scientology over the years, as I understand it?

A. I've been a critic of what I think are some hannful behaviors in Scientology.

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Q. Right. But it's the harmful behaviors you're critical of, not the fact that people might have this particular belief system, or even a series of practices, as long as it's not resulting in some harmful effect?

A. That's true. I do -- I do study, and I think a lot of academics study, unusual belief systems. So in that regard Scientology is interesting, but in terms of a lot -- areas where I've had concerns, it's on issues of harm.

Q. Are you aware of anything that you would consider to be a harmful practice of the Church of Scientology that was occwTing in the Narconon of Georgia program?

A. There's nothing I'm going to speak about, but I do have some -- I do have concerns about some practices.

Q. Well, this is important, because, you know, you're going to come testify at cowt.

A. Uh-huh (affirmative). Q. Are you going to come and testify at court

that there is some harmful practice of the Church of Scientology that you will contend was occurring in the Narconon of Georgia program at any time that's relevant to this lawsuit?

A. I don't intend to talk about the issues of

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1 harm. It doesn't mean I don't believe that those issues 2 exist. 3 Q. Well--4 A. Of the issues of harm, I would-- you know, 5 I'd want to look at issues involving the purification 6 program in its different dimensions, but I'm not going 7 there. I don't have medical or physiological training. 8 So I'll tell you that, but it's nothing I'm going to 9 bring up in court.

10 Q. Okay. So for purposes of this lawsuit, you're 11 not going to offer the opinion in court, as an expert, 12 that there was anything that you would consider to be a 13 hannful practice of the Church of Scientology that was 14 being practiced or followed in the Narconon of Georgia 15 program? 16 A. As far as I could foresee, Mr. Miller, I have 17 no intention of talking about issues of harm, period. 18 Q. Well, and when you say like as far as you can 19 foresee and that type of thing, --20 A. Yeah. 21 Q. -- I mean, can we agree that you're just not 22 going to offer an opinion that there was any harmful 23 practice going on in the Narconon --24 A. Yeah, I don't intend to, 1 just -- I have to 25 have the caveat, 'cause I don't know what kind of

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1 question somebody might ask me. 2 Q. Well, that's the problem, Dr. Kent. 3 A. Yeah. 4 Q. I can't leave this deposition and have you 5 say, "Oh, I'm going to--"-- you know, have you testify 6 to something in the courtroom --7 A. Uh-huh (affirmative). 8 Q. -- because some lawyer has decided to ask you 9 that question. I mean, the purpose of this --

10 A. Well--11 Q. -- deposition is for me to understand what 12 your opinions are going to be in court. 13 A. Sure. 14 Q. And 1 appreciate what you're saying, that 15 there might be something that you would say, you know, 16 "Gee, I don't know if the sauna should be run at 160 17 degrees, but I'm not an expert on that." 18 A. Yeah. See, I want to avoid any question of 19 hann because I think they involve issues of medical 20 analysis, physiology, and areas that I'm just not 2~ trained in. I could make a case that there may or may 22 not be issues of social harm that would come through 23 these practices, but I wasn't hired to look at any 24 issues of social harm. I haven't done so. So I'd say 25 even as a sociologist, in this particular case, I'm not

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going there. Q. Okay. A. I'm not going to the issue of hatm. I want to

limit myself to identifying coru1ections, which I do believe are very strong, between the Narconon content and Scientology content. That's it.

Q. Okay. And so in terms of the beliefs and practices of the Church of Scientology with respect to this particular case, --

A. Uh-huh (affirmative). Q. -- it sounds like the only significance there

is that you've identified things in these Narconon materials that are common principles from L. Ron Hubbard that you see between the Church of Scientology and the Narconon written materials?

A. I think. that's true. I mean, one could talk about Scientology -- part of Scientology involves -- its tenn is "Making the able more able." And in that general practice, it tries to help people identify issues that have occurred in this life that may be hindering them. That general practice certainly appears in the Scientology programs. And, for example, it claims that people who have been involved in drugs have mental images of their drug involvement, and that the Narconon program -- the purification program, excuse me,

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greatly reduces those mental images. They still exist, and the Narconon program doesn't talk about any further way to remove them. You know, which one conceivably--a Scientologist would argue one could do through Scientology. But-- you know, so there is a sense about-- one aspect of Scientology is -- is, you know, what it believes to be identifying issues in people's lives and getting them -- getting them handled. Now, I don't know how relevant that general perspective is with the Narconon program, because I think it finally comes down to what's been botTowed. But there is a larger context to Narconon that I'm aware of in the context of, you know, beliefs and practices and so on.

Q. Okay. What I'm trying to nail down, and I think you're helping me do this, but --

A. Uh-huh (affirmative). Q. --is that the Narconon materials which

incorporate works and principles ofL. Ron Hubbard are similar to works and principles ofL. Ron Hubbard that have been incorporated into the Church of Scientology?

A. Again, I'd be stronger. Might say "are exactly," but...

Q. Closely aligned. Would you say that? A. In many cases, exact. Q. Okay. But in tenns of what you might testify

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1 to at trial about the beliefs and practices of the 2 Church of Scientology, it would seem like it's going to 3 be limited to there are certain beliefs in the Church of 4 Scientology which are very similar or identical, in your 5 opinion, to beliefs that are in these Narconon books? 6 A. That's very true. You know, I-- 1 could 7 envision saying that Mr. Hubbard identified, probably by 8 the early '70s, or -- that people's ability to do 9 Scientology courses was severely damaged if they had

10 unresolved drug issues. Consequently, there's a big 11 push to get Scientologists to do the Purification 12 Rundown. People in the Narconon program have now done 13 it. So-- so I leave it at that. You know, it goes 14 back to the question about whether Narconon is actively 15 recruiting, and I can't say that's true. But I can say 16 that the-- that people have gone through the Narconon 17 program and hence met Mr. Hubbard's requirement that--18 that people who want to advance in Scientology have 19 already gone through the Purif. 20 Q. Now, 1 know you have --let me back up. 21 The general goal of the Narconon materials, as 2 2 you've read them, is to help people get off of dmgs and 2 3 alcohol and somehow become better, more complete people? 24 Would that be a fair assessment? 25 MS. FRANKLIN: Object to the form.

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BY MR. MILLER: Q. In light of the objection, let me ask a

different question. Do you have any reason to-- I'm going to

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Let me ask your opinion number 1, Dr. Kent, in this way. What is it about the beliefs and practices of

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1 own techniques. So Scientology has a global vision 2 about its importance and its value. Consequently it 3 markets itself to different aspects of society, with the 4 hope of getting Scientology's ethics in, to use a phrase 5 from Hubbard. And getting ethics in, it would take a 6 while to fmd, but it's actually in one of these course 7 books; I was really -- I was a bit startled to see it. 8 So in addition to whatever benefits people may 9 feel-- Scientologists may feel, or Narconon people who

10 are not Scientologists may feel, about the value of the 11 program, getting people off drugs, there's also the 12 consequence that Narconon is trying to get Scientology 13 ethics into the drug rehabilitation realm in a way that 14 knocks out psychiatiy. There's a couple of mentions 15 against psychiatry that appear in these books. You 16 know, the sense is that-- and Narconon is quite proud 17 of the fact that it says it gets people off drugs 18 without using additional drugs to addict them. And 19 that, you know, psychiatry makes billions of dollars off 20 its vm;ous kinds of drug treatments, and so on. So 21 Narconon, in one way, fits into the larger 22 anti-psychiatry effmt of Scientology. On the other, 23 it's ·an attempt to get ethics in, into this aspect of 24 society. 25 And, you know, I'm not in a position to accept

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or question Narconon participants, indeed, or Scientologists or non-Scientologists, who may genuinely believe that this program helps people get off drugs.

Q. When you say that it's ttying to inte1ject ethics, what ethics are you talking about?

A. Scientology ethics. Q. That's what I'm trying to understand; what are

Scientology ethics? 8

9 A. Well, the final, foundational ethic is to keep 10 Scientology working. Is to keep Scientology working and 11 expanding in all realms of society. And that's really 12 the bottom line. And what you see in these courses, for 13 example, is the emphasis on practicing the Narconon 14 techniques exactly according to Scientology principles.

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19 that held them back :fi·om reaching their full potential. 19 so on. So, you know, there's just a larger context for The second was to clear the planet of opposition, of 20 ethics. And if one were to, you know-- and, see, this 20

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date, Hubbard's anger grew so much against psychiatry 23 and say, "Well, let's look at this particular that he said the goal of Scientology now is to destroy 24 statement," and I'm not going to do it in comt. But psychiauy, essentially to replace psychiatry with its 25 one could do that kind of thing. Or go through the TRs,

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you know, and say, "Well, what's the pw·pose of bullbaiting?" You know, and, "What's the purpose of yelling at an ashtray, telling it to stand up, sit down, and so on." According to number 2 here, I just was required to identify whether the vast majority of N arconon of Georgia's training materials and course exercises are based primarily on the principles of the Church of Scientology. That's definite. So... So there's a whole other dimension, but I haven't been hired nor have I prepped to address those larger issues.

Q. What were you asked to do? A. Well, what's here. Q. You were specifically asked to say can you

talk about the beliefs and practices of members of the Church of Scientology, and can you offer the opinion that these materials are primarily based on L. Ron Hubbard's works?

A. Yeah. Q. Okay. A. And this third issue about Narconon, but I--

as I said, I really -- 1 don't think I've got any really definitive evidence one way or the other on those. --

Q. Okay. A. -- Those points. Q. And the way that the Narconon program, as 1

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understand it, that you say gets into the larger scheme of Church of Scientology would be that in general it's a non-drug program to get people off drugs and alcohol, so it's therefore contrary to what a psychiatrist might be doing?

A. That's true. Q. That's number one. Then number two is that in

stressing ethics, it uses some of the same principles that L. Ron Hubbard uses to try to encourage people towards more ethical behavior?

A. Hubbard outlined --well, there's a whole series of statements in the upper levels of these

13 Narconon courses that involve morals, ethics, The Way To 14 Happiness, and so on. And one could go through and

identity them as different moral and ethical statements, codes and so on. Talks about moral codes in here.

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Q. Okay. In other words, it is a program that is stressing, through principles that Hubbard laid out, moral and ethical behavior?

A. They are Hubbard's visions of moral and ethical behavior. Not a complete statement by any means.

Q. Right. But, for example, The Way to Happiness

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Q. And so the way it fits into the larger Scientology schemes would be that that -- it's sort of a systematic structure for trying to encourage things like the ways of happiness?

A. The reason 1 hesitate, and the reason I hope we don't go too far this direction, is that the Scientology organization is multiple levels.

Q. Okay. A. And-Q. But--A. And some of the multiple levels-- some people

in some of those multiple levels have engaged in behaviors that would seem to me to be contrary, directly contrary, to the ethical and moral behaviors that are laid out in the book. So --just as a basic example, the whole fair game issue.

Q. Let me use that as an example. A. Uh-huh (affirmative). Q. Again, you're not going to come to court and

testify that there was something going on at Narconon of Georgia that was similar to your criticism of Church of Scientology's fair game?

A. That's not my -- no. I don't intend to do that at all.

Q. Right. In other words, what l'm struggling

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1 with a little bit is -- you may have already answered 2 this question, but in terms of talking about the Church 3 of Scientology's beliefs and practices, I just want to 4 know what you're going to say that you would then say 5 is, you know, relevant to this case, and what I'm 6 hearing you say is that these materials are L. Ron 7 Hubbard type materials, and they are consistent with 8 L. Ron Hubbard's belief that people shouldn't be, you 9 know, taking dmgs, for example, to help get off dmgs,

10 and that they should engage in ethical behavior? 11 A. I wouldn't even go that far. I would say that 12 these-- the statements that appear in the Narconon 13 books come from existing Scientology programs, courses,

doctrines and so on, and just leave it at that. 14

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A. Yeah. Q. --which is that basically yow- opinion

number 1 is to substantiate your opinion number 2? A. Yes.

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Q. So that your anticipated testimony which you plan to present would be enough of the Church of Scientology's beliefs and-practices to illustrate bow it is that the Narconon materials are consistent with the Hubbard stuff that's in the Church of Scientology? 25 A. That's true.

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1 A. I think that's a fair representation. I mean, 2 I can see how someone would ask a question, "What is a 3 suppressive person," or "What is a PTS." You know, 4 "What's a rule in Scientology, does it appear in the 5 Narconon." Or even go the other direction. But those 6 kind of questions. And not go beyond the implications 7 about how Scientology may respond to a suppressant 8 person; that's a different -- that's not relevant to 9 this particular case here.

10 Q. Okay. I think that's fair enough. So what 1 11 wanted to make sure was that you weren't going to come 12 and offer expert testimony in this case about practices 13 of the Church of Scientology that you're critical of and 14 then to sort of, you know, make the Narconon program 15 seem bad because there's some connection through these 16 L. Ron Hubbard works? 17 A. I didn't intend to talk about issues of harm. 18 I thought it was just enough to say, "These documents 19 exist." Or, "These concepts exist here, they exist 20 there." And if it's a jury trial, let the jury make 21 conclusions. 22 Q. Are there any opinions about the Church of 23 Scientology's practice or beliefs that you intend to 24 offer at the trial of this case that we haven't talked 25 about?

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1 MS. FRANKLIN: Object to the form. 2 THE WITNESS: I can't think of any at 3 this time. Again, I've tried to be as clear 4 as possible about what I see my role is, and 5 which is to -- and I do agree that the vast 6 majority ofNarconon Georgia's training 7 materials and course exercises are based 8 primarily on the principles of the Church of 9 Scientology. That I agree with. And I'm

10 happy to stop right there. 11 I wouldn't even say principles. I think 12 direct bon-owings, but -- but more or less I 13 can stop right there. 14 BY MR. MILLER: 15 Q. Well, we have the documents that you've 16 produced to us in Exhibit 2, and we've talked about a 17 few of them. Are any of those documents ones that you 18 would need to specifically point to in order to support 19 your opinions 1 and 2, or -- and I realize that 20 sometimes you pull documents and --21 A. Yeah. 22 Q. --they aren't necessarily doctUnents you're 23 going to specifically rely upon. I have those separated 24 out. If you want to flip through the ones that you --25 in their separated-out fonn, I just want to talk to you

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about the ones that you would point to to support the opinions you're going to give in this case.

A. Uh-huh (affirmative). Q. But if there're ones that are just general

background, that you're not going to point to to support your opinions, then I don't need to talk to you about them. But I would like to identify them.

A. Sure. MS. FRANKLIN: And if you want to take a

minute to go through them. Take a little break and --

THE WITNESS: Sure. MR. MILLER: Let me do this. I will

mark the rest of them as separate documents. MS. FRANKLIN: Okay. MR. MILLER: And that may -- we've

already talked about a few of them, but... (Thereupon, marked for identification purposes, Defendants' Exhibit Nos . 13 through 18.) (Recess at 2:05, resumed at 2: 15.)

BY MR. MILLER: Q. Dr. Kent, during the break you were going to

look through the exhibits -- or, the documents that arc encompassed within Exhibit 2, and identifY any documents

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in there that you might use to support your opinions in this case, and I think you've now gotten to the point where we can do it. And if you wouldn't mind, just identify by exhibit number and then tell me.

And, for the record, too, what I've done is I've taken Exhibit 2 and I've broken it down into individual documents. So maybe what we can do is the exhibit number and the Bates range of the pages.

A. Forgive me for being slow here; I just ran across a section I thought I should pay a bit more attention to.

Okay. And again, I apologize, I just wanted to check that one document.

I will jump around, unfortunately, with some of the exhibits, but if we can start with No.--Exhibit 18. Again, as I got the charge and started thinking about it, there's nothing in 18 that specifically relates to this -- to the possibility of Scientology courses influencing or being part of the Narconon program.

MR. AMASON: Excuse me, can we get the Bates numbers when we look at these?

THE WITNESS: Oh, I-- sure. This is Exhibit 18, Bates number starts at 0821.

MR. AMASON: Thank you.

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Desmond, et al. v. Stephen Alan Kent January 5, 2012 Narconon, et al.

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THE WITNESS: And it goes to 0834. There's a section in there about

Chilocco, Oklahoma, but this isn't Chilocco, Oklahoma. So I think we can dispense -- with what I've seen, we can dispense with anything in there.

BY MR. MILLER: Q. Okay. So Exhibit 18 is not going to be --A. Sure. Q. -- something you rely upon. A. Okay. Exhibit 17, which is Bates number 0809

through 0820, is Scientology's submission to the IRS, I believe, about Narconon's status. And beyond what I--the vague things I said about it having charitable --or, nonprofit status, certainly before the IRS decision, I'm not going to make any big deal out of that one.

Q. Is this just a portion of the submission? A. Oh, the submission was -- you can see on the

table of contents there was quite a number of other items included. I just photocopied the ABLE section and the Narconon section. But I'm not-- I'm not going to push any issues about the relationship between Narconon International and this particular program. You know, I talked a little bit about it in the vaguest terms for number 3, and that's about as good as I can go right

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now. Q. Okay. A. So part of my comments are based upon this

section, but... Q. But, again, you're not going to say anything

more about the relationship between N arconon International and Narconon of Georgia, beyond what you've already testified to?

A . I'm not going to say anything beyond what I've testified already.

Q. So that Exhibit 17, then, is simply consistent with your belief that as part of this dialogue with the IRS, the Church of Scientology discussed Narconon?

A. That's true. And I believe even before the IRS decision Narconon had nonprofit status .

Q. And, again, whether that nonprofit status was based on it just being a charity versus religion you don't know?

A. I'll leave that open. Q. Okay. A. Exhibit 16, which is Bates number 0802 to

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realized if it's got medical issues or medical claims, I'm just going to stay away from that area. So I don't plan to raise anything that's right now in Defendants' Exhibit 16.

Q. Okay. So you're not going to rely on Exhibit 16?

A. No. Q. That's conect, right? A. And we already talked --Q. I'm sorry. I asked my question poorly.

You're not going to rely upon Exhibit 16 in your opinions in this case?

A. That's correct. Now, Exhibit 15 does have a-- this is Bates

0798 through 0801. This is an early Narconon program that does discuss Scientology's portrayal of the history ofNarconon. That's a question that came up between us, so maybe this would be of some value. 1f the history -if a history ofNarconon comes up in court. So-- I mean, it came up here, and ...

Q. But it would be fair to say, I think, Dr. Kent, that your knowledge of the history -

(Discussion off the record.) BY MR. MILLER:

Q. Your knowledge about the history ofNarconon

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1 is based simply on documents you may have read? 2 A. Yes. I don't think, again, with the specifics 3 of what I'm addressed to speak with, I'm not sure it's 4 going to have any real bearing on the case here. 5 Q. And Exhibit 15, it looks like, is an article 6 written by William Benitez as the founder ofNarconon? 7 A. That's right. 8 Q. And he's the prisoner who started a program to 9 help get people off dmgs and alcohol when he was in

10 prison? 11 A. That's true. He was in Arizona state prison, 12 I believe. 13 We've already --1 don't have a Bates number 14 on this, Exhibit No . 3, but this is the-- "Dr. Kent's 15 File Materials" for Desmond, and it lists all those 16 depositions, the ones that I haven't looked at and may 17 or may not even have. And all discovery responses from 18 all parties. ~9 Q. Well--20

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A. 1 don't have those, so ... Q. I think that inadvertently got in your

0808, I had copied a section from Celebrity Magazine 22

about how the Purification Rundown works. This has 2 3

stack;--A. Okay.

24 discussions about drugs in it and so on. And I'm-- you 24

know, again, once I got going on my directions, I 25 25

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Page 149

1 Q. -- talked about that. 2 A. Now ... What is this? Yeah, the reason I 3 included Exhibit 13, which is Bates number 0737 to 0758, 4 was there were some -- if issues came up -- well, 5 nothing's come up about Narconon and the larger 6 scholarship. So as long as I'm not going to get asked 7 about Narconon and the larger scholarship, I won't have 8 to refer to this article. Ifi get asked, there's a 9 question about Narconon and the larger scholarship, then

10 I will refer to this article. But it's not come up in 11 the deposition today, so ... 12 Q. What do you mean by "Narconon and the larger 13 scholarship"? 14 A. This is an article entitled "Alternative 15 therapy, Dianctics, and Scientology." And it looks at 1 6 the sub-social world of Scientology as an alternative 17 medical practice. 18 Q. Okay. But--19 A. And in that context there are a couple 20 mentions ofNarconon. So just-- I'm not going to refer 21 to it unless somebody were to challenge me and say, "You 22 have no -- no academic basis for talking about your 23 subject," then I would say, "Oh, yes, I do." Hasn't 24 come up, so if it doesn't come up in trial, I won't 25 mention the article. If someone challenges me in hial,

Page 150

1 then I'll mention it. 2 Q. But in terms of an academic basis for your 3 opinions, it doesn't sound like that's necessary for 4 your opinion that these materials are coming from L. Ron 5 Hubbard's writings? 6 A. This atticle doesn't talk about Narconon 7 Georgia, so ... 8 Q. Right. And it doesn't sound to me like you're 9 going to talk about the Narconon of Georgia program one

10 way or the other in terms of its efficacy, or whether 11 it's pseudo medicine or not pseudo medicine, or 12 whether--13 A. That's -- that's fair enough. 14 Q. As I understood that article, that has to do 1 5 with -- I think it would be fair to say that Exhibit 13 16 is not going to be something you would need to rely upon 1 7 to offer any of the opinions that you've identified here 18 today that you're going to give at trial? 19 A. That's true. That's true. 20 Now, Exhibit 14. And this is Bates number 21 0774 through 0797. If the issue were to come up, as it 22 has in the deposition here, about the antipathy that 23 Scientology feels toward psychiatry, on Bates 24 number 0776 there's a discussion about what's called 25 "The Crisis: Drugs; The Solution: Narconon; The Plan:

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"In mistreating dmg addiction, psychiatry makes billions, destroying millions of lives in the process. For the first time in American history, a social matter--dmgs--is a major concern for the population." And it goes on to talk about -- well, "The Narconon Chilocco New Life Center--an 80-building, 167-acre residential facility--is the biggest project in our history to create overwhelming public popularity for Drug Rehabilitation Technology developed by LRH." I only mark that section because if the issue comes up about how Scientology sees the value of its program as a drug-free solution to a drug problem, here's the statement that helps solidify Scientology's antipathy to psychiatry.

I included in Bates 0780 -- this is a statement from-- in a Narconon publication about L. Ron Hubbard. And I was interested in the fourth paragraph down. '"Recent research has demonstrated that the single most destructive element in these societies today is drugs,' he said in 1979. Always concerned with the well-being of his fellow man, he engaged in extensive research in this subject. His years of research and the success of the drug rehabilitation technology resulting from it led to the fonnation of a network of centers

Page 152

called Narconon, which exclusively uses his methods." Now, you know, "exclusively uses his methods"

is pretty much what I'm saying in my submissions. But I was also interested in the statement about his years of research. One of the things that comes out about Narconon is, there's a tremendous number of claims but there's no production of any kind of research notes or research protocol or tests or whatnot. So that issue could come up. Is it in terms of what Narconon's based upon, there hasn't been the presentation of research documents, in a n·aditional scientific sense, that one might expect when there's so much talk about research. So that's why I marked that particular number.

And then finally, just on Bates Page 0793, just to make sure that radiation gets included in a discussion about purification, there's a picture of an atomic explosion. So that's why I included these.

Oh, and you've broken down No. 2, so I needn't go through -- unless I'm mistaken, that's -- unless I've gotten some papers mixed up, I believe that's all of the breakdown there is of the No.2 fatter exhibit.

Q. Okay. So going back to Exhibit 14 for a minute, which is Bates range 0774 to 797?

A. Okay. I don't have a copy-- oh, I see, I might in this large pack. I'm sorry, what is the

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1 number, 07 ... ? 1 A. -- because there isn't the production of 2 Q. 774. You said this would have some connection 2 documents to back up the claims. 3 to your opinions in that Narconon is supportive of a 3 Q. Whether those documents exist or don't exist 4 non-drug, non-psychiatrist smt of solution to drug 4 you just don't know? 5 problems . 5 A. Oh, they don't exist. 6 A. That's how it portrays itself. There's a 6 Q. How do you know that? 7 real -- again, in Scientology there's a very strong 7 A. 'Cause I've talked to so many people who were 8 anti-psychiatry strain. 8 with Hubbard. I'm-- and he never, ever had any kind of 9 Q. And that's a document that looks like it was 9 scientific tests. He never conducted any kind of

10 generated in 1989? If you flip back a couple pages. 10 scientific tests. 11 A. Yeah, there's an ABLE ... 1989 October is 11 Q. So based upon conversations you've had with 12

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research looks like it's also a 1989 document? A. Probably so. Q. I think you said 1979 earlier, but it looks

like Page 779, Bates number 779? A. Yeah, and 0780. Q. Right. A. Yeah. Q. And it looks like--flip back one page--that's

a 1989 document?

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A. Biographies about Hubbard, reading his -reading, I mean, hundreds and hundreds of pages of-there just isn't any of the kind of research and sci -it's not -- nothing's been published anywhere about-from Hubbard, to show what his findings were.

Q. Okay, we're talking about two different things here. You're saying that you're not aware of any published research by L. Ron Hubbard. That's one-

A. That's very true. Q. Okay.

A. Yeah; on the bottom of that page it says 1989, 23 A. And I'm not aware of any private -- depends upon what you mean by "research." yeah. 24

Q. Okay. And you haven't tried to research, I 25 Q. I was going to ask you that question.

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1 don't believe, what, if any, research may exist out 1

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Page 156

A. Yeah. 2 there to support the effectiveness of the Narconon Drug 3 and Alcohol Rehabilitation program, have you? 3

Q. 'Cause in your field, for example, your research can consist of talking to people, right?

4 A. It's nothing that I'm going to bring up in the 4 A. Well, it's a -- yes, but it's -- it's got to 5

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trial. 5 be done in a systematic way. Now, especially in the Q. I mean, really, it's not your area of 6 early days, there were a lot of people doing Dianetics

expertise to try to evaluate the effectiveness of a 7 and Scientology. But in terms of doing it program like this? 8 systematically, you know, keeping records, testing

A. That's correct. 9 hypotheses and so on, none of that was done. And I've Q. Or any of the medical or physiological issues 10 never seen anything-- it was years ago -- oh, what was

11 that might be concerned with, you know, whether the 11 it called. There were attempts from Scientology to sauna program or the vitamins assist people in helping 12 enter the field of science. I think there are even one them to get off drugs? 13 or two very early journals of Journal of Scientology

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A. Yeah. In this context, I had no intention of 14 that were really hying to portray itself as systematic. discussing any of those issues. So it was more the 15 But in this kind of-- in the Narconon books, there's no issue about the research claims. But the research 16 citation to any research that Hubbard actually did. claims, ifl may, you know, in the back of each one of 17 There's constant statements about it, but there's just these books there's a short biography of Mr. Hubbard, 18 no evidence that he-- to produce the basis for the and there's always claims about-- about his research. 19 claims. This is Page 396 of book 1, "Therapeutic TR Course." 20 MR. MILLER: Let me see that blue book,

"His research proved that not only is a 21 if you would please, Rebecca. person's health hannfully affected by drugs ... " It's 22 MS. FRANKLIN: Sure. more the issue about research. That one has to take 23 MR. MILLER: Thank you. these claims of research on faith, -

Q. Okay. 24

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BY MR. MILLER: Q. I'm trying to find the biography of...


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1 But, bottom line, Dr. Kent, it sounds like you 1 Q. And that document would be from the 1990s? 2 are not going to offer opinions in tllis case about what 2 A. The 1993. 3 does or does not work in tenns of getting people off 3 Q. The draft settlement agreement, which was not 4 drugs? 4 the final settlement agreement? 5 A. I don't want to go there. 5 A. That's correct. 6 Q. Okay. And you have not made an attempt to try 6 Q. But you haven't done anything to research the 7 to research that issue yourself, nor is that within your 7 basis ofNarconon of Georgia's charitable status? 8 field of expertise? 8 A. No. No. 9 A. I've certainly not done any kind of studies to 9 Q. Or Narconon International's charitable -- or,

10 measure success rates. In this Narconon program or any 10 nonprofit status at the current time? 11 others. 11 A. I have not done any research on it. 12 Q. And then on Exhibit 14, Page 793, the mushroom 12 Q. Nor would that be within your expertise, to 13 cloud, that just relates to the fact that there was a 13 determine what basis either Narconon of Georgia or 14 belief that part of this detoxification could assist in 14 Narconon Intemational might have for nonprofit status? 15 getting radiation out of somebody's body? 15 A. Yeah, 1 don't really foresee going in that 16 A. That's correct. 16 direction. I mean, I've told you what little I know, 17 Q. Okay. Which you talked about earlier? 17 and --about the relational issues. And they're just 18 A. That's true. 18 not clear enough for me to say anything definitive. 19 Q. Have we now talked about all the documents in 19 Q. In the course of this deposition, is there 20 your file that you would point to to support any of your 20 anything else, other than possibly going back and 21 opinions in this case? 21 looking at Exhibit 7 some more, that you would do to get 22 A. "All the documents ... " Now, ifl were to go 22 ready for trial? 23 through these Narconon booklets point by point, there'd 23 A. I'd want to have another run-through of these 24 be a lot more cormections I'd make with Scientology. 24 books. But, other than that, I can't tlllnk of anything. 2 5 Q. I appreciate that. I'm trying to -- 2 5 Q. But if there was no dispute in this case that

Page 158 Page 160

1 A. Yeah. I don't have documents right now, 1 the books that you've reviewed are based on the works of 2 but-- but I'm not planning on going home and fmding 2 L. Ron Hubbard, would there be anything else you would 3 more documents, if that's part of what you're asking. 3 do? 4 Q. It is. 4

5 A. Yeah. 5

6 Q. What I wanted to do is to make sure that, of 6

7 that collection of documents that we've marked as 7

8 Exhibit 2, that we've talked about any documents or 8

9 portions of documents in there that you would point to 9

10 to support any of your opinions. 10

11 A. Yeah, I-- the only other outlier might be 11

12 this IRS agreement. I've read it several times; I 'm 12

13 going to go back and do it. But, again, I can-- you 13

14 know the sum total of what I can say about this 14

15 charitable status issue. 1 think it's an interesting 15

16 one, an important one. I'm not sure finally it has 16

17 bearing upon -- well. So... That's the only thing I'm 17

18 going to go back and look at. Whether or not I use or 18

19 even figure out what it says is another question. I 19

20 don't want to necessarily throw that out, though. 20

21 Q. And your purpose of going back and looking at 21

22 it would be to determine what? 22

23 A. If it's-- if I can figure out if it's a 23

24 charitable status. How its charitable status relates to 24

25 Scientology's charitable status. 25

MS. FRANKLIN: Object to the form. THE WITNESS: Well, the only concem is

exactly what that agreement -- agreement would mean. It's hard -- it's put right on the cover, "Based on the works of L. Ron Hubbard." I think the question is, well, what does that mean in the context of Scientology being a religion, these documents bon-owing from a religion, these being secular. So there's still some areas of discussion. But I could agree with you that the Narconon books are based upon the works ofL. Ron Hubbard.

BY MR. MILLER: Q. Right. And with the exception of the two

dynanlics that you've discussed in book 6, there's notl1ing that you've identified in there that would be religious?

A. At this point I can't recall anything else. Again, if-- I don't want to waste your time going through all these books, you know.

Q. Okay. But even if there was something else in

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Desmond, et at. v. Narconon, et at.

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1 one of these books that would be religious in nature of 1

2 any type, it would be neutral; it would be something 2

3 probably talking about, you know, spirituality or 3

4 getting in touch with a higher being? 4

5 A. Again, I don't want to -- I want to be very 5

6 careful not to get into issues about discussing moral or 6

7 ethical issues about Scientology. Because there's a lot 7

8 of moral and ethical statements. You know, I simply 8

9 want to point out that, you know, the dynamics contain 9

10 two issues that arguably directly mention, you know, 10

11 realms beyond the secular one, and there's some 11

12 discussion of it there. And leave it at that, if... 12

13 Q. Have we talked about all the opinions that 13

14 you're going to offer in this case? 14

15 MS. FRANKLIN: Object to the fonn. 15

16 THE WITNESS: Certainly in the broad 16

17 sense. Again, there's a lot more in the 17

18 books that I could pull out and identifY, but 18

19 it would be more of the same along the lines 19

20 of what we've discussed. 20

21 BY MR. MILLER: 21

22 Q. Well, I want to explore that with you for a 22

23 minute. I mean, when you say "there's ... more in the 23

24 books," I'm assuming that what you mean is that there 24

25 are more things in the books that you could point to and 25

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1 say, "This is something that I can also find a parallel 1

2 to in the Church of Scientology"? 2

3 A. That's correct. 3

4 Q. But other than that, is there anything else in 4

5 these books, other than specific examples you might find 5

6 to support your second opinion here, which is that the 6

7 majority of these-- 7

8 A. Uh-huh (affirmative). 8

9 Q. --books are based on the principles of the 9

10 Church of Scientology? 10

11 A. I think that's -- you've summarized it very 11

12 well. That I'd find more specific examples, but 12

13 nothing --no new bombshells, you might say. 13

14 Q. Okay. So, with that understanding, have we 14

15 talked about all the opinions that you're going to offer 15

16 at the trial of the case? 16

17 MS. FRANKLIN: Object to the fmm. 11

18 THE WITNESS: With that understanding, 18

19 knowing there's a lot more specifics, I can 19

20 say yes. 20

21 BY MR. MILLER: 21


Page 163

again and-A. Sure. Q. --talk to you about those. You understand

that--A. I understand, yeah. Q. I want to make sure that we've covered

everything that's in Exhibit 2. MR. MILLER: Let's take a short break

and just look at what we've already marked. I'll tell you what we can do... Go off the record.

(Discussion off the record.) (Thereupon, marked for identification purposes, Defendants' Exhibit Nos. 19 and 20.)

THE WITNESS: The only items I came across that might be of use is Bates number 0760 through 0767. These have to do with assists. I mentioned locational assists a couple times . May or may not come up. They're similar to some other kinds of processes that appear in these -- in these books.

BY MR. MILLER: Q. The Narconon books?

Page 164

A. In the Narconon books, yes, sir. Other than that... And, again, I'll -- other

than what we've discussed, I think we've covered this Exhibit No. 2 fairly well.

Q. There were two other documents in Exhibit No.2 that, in my effort to mark them separately, that I haven't asked you about. Let me ask you first, Exhibit 19, --

A. Okay. Q. --if that's anything you're going to be

relying upon? A . Again, this is from the old historical record,

and since I -- the historical record really doesn't come to bear in this particular case, so I see no reason to include it.

Q. So you're not going to rely on Exhibit 19; -A. No. Q. --how about Exhibit 20? Is that anything

that you're going to rely upon? A. I don't think it's any need to, no. Q. Okay. So just to be clear, I think we have an

2 2 Q. And if you have any additional opinions, will 2 2 agreement that if you come up with any new or additional 23 you let your lawyer know right away? 23 opinions, you'll let your lawyers know right away, and 24 A . Sure. 24 then we have an agreement we can come back and depose 25 Q. And we'll need to come back and depose you 25 you on it.

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1 A. Yes, sir. Yes, sir. 2 Q. And if we don't hear anything between now and 3 the time of trial, it's fair for us to assume you're not 4 going to offer any opinions other than what you've 5 already talked about today? 6 A. Yes, sir, that's --7 MS. FRANKLIN: Object to--a THE WITNESS: -- tme. 9 MS. FRANKLIN:-- the form.

10 BY MR. MILLER: 11 Q. And you've completed your work? 12 A. Other than going back through the books. 13 Q. And if you went back through the books to find 14 more specific examples, my understanding would be you'd 15 say, "Okay, there's the word--" --I mean, give me an 16 example of something else that's in there that's ... 17 A. Overt withholds. 1a Q. Okay. And then you would explain what that 19 means in the context of Hubbard's writings and the 20 Church of Scientology? 21 A. Yes, sir. 22 Q. But you would not offer the opinion that 23 because that's in the book, that makes the book a bad 24 book or this a bad program or anything like that? 25 A. That's correct.

Page 166

1 Q. It would just be more examples to support your 2 opinion number 2? --3 A. Right. 4 Q. --On Exhibit 4. 5 A. And, again, I don't want to get into questions 6 of goodness or badness. 7 Q. Let me ask you about the financial aspects of a all this. What are you charging for your time in this 9 case?

10 A. 250 an hour. 11 Q. 250 an hour? 12 A. Yes. Yes, sir. 13 Q. Is that for all of the time you've spent on 14 the case? 15 A. Yes. 16 Q. Will that be the same for depositions, trials, 17 everything? 1a A. Yes, sir. 19 Q. And that would mean you've put in about $2500 20 of work before you came to Atlanta, assuming you've 21 spent about --22 A. About ten hours, okay. Yeah. 23 Q. And then since you've been in Atlanta you bad 24 the meeting yesterday with -- was it Rebecca or Jeff 25 Harris?

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A. That's correct, yeah. Q. Was there anything they asked you to offer an

opinion about that we haven't talked about today? A. I'm not sure. I think counsel would know

better than me. And I understand after -- at the end of a deposition counsel may get a few minutes to ask me questions, so I don't want to answer for counsel.

Q. No. The--A. We've had-- I think we've covered a lot.

There's nothing that 1 can think of at this point, but counsel may have some other-- some related questions.

Q. Well, I just don't want to be surprised at trial, --

A. Yeah, I understand. Q. --so if there's something that, based on your

conversations yesterday, or any time, that you think, "Ah, I think they're going to ask me this question at trial," I need to know of any --

A. Uh-huh (affirmative). Q. -- opinions that you--A. Uh-huh (affirmative). No,-Q. --reasonably--A. --yeah. Q. --anticipate you might be asked. A. Yeah, no, I understand. I can't think of any

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questions offhand. Again, we may learn in a couple minutes.

Q. Well, you've made reference to the books that you reviewed last night. Let's go ahead-- we marked one of those, book number 6, as Exhibit 12; let's just mark the remainder of the books, because I think that's something that we wanted to do.

MR. MILLER: I'll get the court reporter to mark those.

And then, Rebecca, you said these have been scanned in in some fashion that we can get these from you?

MS. FRANKLIN: Well, can we agree to use the scanned-in versions that you've produced in discovery?

MR. MILLER: Well, the only hesitancy I have to that would be that these are the books that he's reviewed.

MS. FRANKLIN: Okay. MR. MILLER: What we could do is maybe

look at the publication dates or something and just determine whether it's necessary to--

MS. FRANKLIN: Right. MR. MILLER: As long as we have the

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1 agreement that you'll keep these books. 2 MS. FRANKLIN: Sure, sure, --3 MR. MILLER: -- and we'll have access to 4 them. 5 MS. FRANKLIN: --of course. 6 THE WITNESS: Uh-huh (affirmative). 7 MR. MILLER: So let's go ahead and mark 8 these as the next series of exhibits. 9 (Recess at 2:54, resumed at 3:00.)

10 (Thereupon, marked for identification 11 purposes, Defendants' Exhibit Nos. 21 12 through 26.) 13 (Thereupon, Mr. Hynes is not present in 14 the deposition room.) 15 BY MR. MILLER: 16 Q. Dr. Kent, during the short break we have 17 marked as exhibits 21, which is book number 1 that you 18 reviewed; Exhibit 23, which is book 4a; Exhibit 24, 19 which is book 5; Exhibit 25, which is book 7, and 20 Exhibit 26, which is book 8, for purposes of 21 identification. And what we've agreed to do is, with 22 these exhibits, including the book we marked earlier as 23 Exhibit 12, which is book number 6, that Rebecca's going 24 to keep those books, we'll all have access to them as 25 necessary, --

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1 (Thereupon, Mr. Hynes entered the 2 deposition room.) 3 BY MR. MILLER: 4 Q. -- and we can compare these books to the ones 5 that have already been produced in litigation and decide 6 whether there's any need for any of us to get copies of 7 the books. 8 A. Okay. 9 MR. MILLER: Is that agreeable with

10 everybody? 11 MS. FRANKLIN: Sure. 12 BY MR. MILLER: 13 Q. So, for the record, Exhibits 12, 21, 23, 24, 14 25 and 26 will stay with R ebecca. 15 (Discussion off the record.) 16 BY MR. MILLER: 17 Q. I think I may have omitted Exhibit 22, which 18 is book number 3 that got marked. 19 Dr. Kent, do you have any idea how Jeff Harris 20 and the plaintiffs' lawyers found you? 21 A. I asked Jeff that. I think he -- I'm not 22 entirely sure. I think he saw a reference to me in a 23 newspaper article. 24 Q. What newspaper article is that? 25 A. It was one-- it was a New York Times article,

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and I'm not -- I know I was quoted in one New York Times article about Scientology; 1 can't recall if I've been quoted in any more. But other than that, I'm not sure.

Q. What was the thrust of the article? A. Let's see, there were -- there were two

ruiicles, and I'm not sure which one I was in, or both. One was about the IRS agreement, and the other was about the Lisa McPherson case. This is a case in Florida where a Scientologist died who was in Scientology's care. And I'm not sure ifi was in one article or both articles, and even ifl were, which article Jeffhad seen. So, I'm sony, I can't give any more specifics than that.

Q. Okay. MR. MILLER: Will you mark another

document? (Thereupon, marked for identification purposes, Defendants' Exhibit No. 27.)

BY MR. MILLER: Q. I show you what's been marked as Exhibit 27,

which is a list of --A. Uh-huh (affirmative). Q. -- Scientology articles from your web site, I

believe? A. That's true. Okay, this is ... I'd say the CV

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may be more up to date than the web site, so ... Q. Between the CV and Exhibit 27 would we have

all of the articles that you've ever written on Scientology identified?

A. You should. Let me check on one here. As far as I !mow, everything's listed in the

resume that I published on Scientology. I'm not sure everything's on the web site yet.

Q. But between Exhibit 1 and Exhibit 27 we have all of the articles you've written about Scientology or L. Ron Hubbard or any --

A. Uh-huh (affirmative). Q. -- organization related to Scientology and --A. As far as 1 know, that's true, yes, sir. Q. And all of the written or deposition testimony

you've given would be identified on Exhibit 1, and it sounds like you've given two depositions before this case having to do with Scientology; the--

A. I believe that's true, uh-huh (affirmative). Q. --Williams case in Colorado, and the--A. Padgett case in Kentucky, l believe it was. Q. Okay. And you have copies of both those

depositions? A. I don't have copies of either one of them. Q. Okay.


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1 A. At least l -- l surely don't have one from 2 Colorado, and I'm pretty sure I don't have one from--3 I'm almost entirely sure I don't have one from Padgett. 4 Q. I may have the Colorado one. 5 A. lfyou do, I have to chuckle, because I'd be 6 the one hoping that you give me a copy of my deposition. 7 'Cause I don't have one. 8 Q. Let me just hand you a document. Does that 9 appear to be the deposition you gave in the Colorado

10 case? 11 A. It was taken by Stuart Mann, so ... But I'm 12 certain I don't have this. And unless I'm drawing a 13 brain -- brain blank here, I don't think I ever got a 14 copy. 15 Q. Okay. 16 MR. MILLER: Let's mark this as the next 17 exhibit. 18 THE WITNESS: And I 'll get a copy 19 eventually through the... Good, good. Thank 20 you. 21 (Thereupon, marked for identification 22 purposes, Defendants' Exhibit No. 28.) 23 BY MR. MILLER: 24 Q. Exhibit 28 now is -- and I want you to satisfy 25 yourself that that appears to be a true and accurate

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1 copy of the deposition testimony you gave in that 2 Williams case? 3 A. 2010. I -- it's the right attomeys. I'm 4 sure. 5 Yeah, he's over -- I'm sure that's accurate. 6 For the deposition. 7 Q. Have you spoken to Dr. Roy, who's --8 A. No. 9 Q. -- another expert in this case?

10 A. No, I haven't. 11 Q. And you haven't seen any repmts or writings 12 from him, have you? 13 A. No. 14 Q. And 1 take it you don't have any plans to get 15 together with Dr. Roy and talk about the case or any --16 A. No, I don't. 17 Q. Okay. Would you characterize Scientology as a 18 cult? 19 A. Generally speaking, I try to avoid the word. 20 I've used it sometimes. There's a number of different 21 meanings to the word "cult." If one can avoid the term, 22 it just -- you sidestep a whole series of issues. I do 23 think there are a couple times when I thought it was 24 appropriate and I've used it, but, generally speaking, I 25 try not to.

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Okay. But you have in the past sometimes refened to Scientology as a cult?

A. I'm fairly sure. Now, I'm not sure in what publication it may have been. I mean, generally speaking, I avoid it; I'm not going to say I've never used the term "cult," because I just have a little inkling that somewhere I have.

Q. What, if any, connection or knowledge do you have about the Cult Awareness Network?

A. And ... ? Q. Just, what is the Cult Awareness Network? A. It's outside of what I was asked to talk about

here, so... That's the only reason I'm hesitating. I don't know that it has any bearing on the case.

Q. I'm not going to ask you very many questions about it, --

A. Ub-huh (affirmative). Q. -- but I understand you know or knew Cynthia

Kisser, who was the principal at the Cult Awareness Network?

A. Yeah. I mean, in this case she's a public figure, so I can say I did know her.

Q. And I'm just trying to find out, did you ever work with the Cult Awareness Network in any way, as an expert, or giving them advice, or providing them with

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materials, or anything like that? A. Never as an expert, never as-- in any court

cases. I wrote about a Cult Awareness Network core case, but it was a year or two after it happened. Maybe longer. But at the time, no.

Q. What was the case that you wrote about? A. This was a case brought against the Cult

Awareness Network by a person named Jason Scott. Q. Was that the gentleman who claimed that he had

been kidnapped and deprogrammed from a Pentecostal church?

A. Yes, sir, that's the one. Q. And that was his claim, was the Cult Awareness

Network had kidnapped him and deprogrammed him to try to persuade him not to be a Pentecostal?

A. Yes, sir. Q. Okay. And I believe you have described

yourself at some point as "the most vocal academic in the world" when it comes to discussing what you perceive as human rights abuses by Scientology? Would that be the way you've characterized yourself?

A. 1 can't remember saying it, but it certainly is something I could say. Ifl --so I can't tell you if I said it at a particular time. There is a-- "the most vocal academic --"-- I don't know, there's --

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1 there's an academic who's not really in the field of 2 studying religious groups who in many ways is I think 3 much more aggressive about Scientology than I am. And 4 that's David Touretzky. There was a very strong article 5 written against Scientology, using words I have never 6 used, and phrases, by an Israeli academic named Benjamin 7 Beit-Hallahmi. His last-- so it's B-E-1-T, hyphen, 8 H-A-L-A-H-H-M-1 [sic], I think? Beit-Hallahmi. Who's 9 at Tel Aviv. Tel Aviv University. And he published an

10 article in Marburg Journal of Religion. And I think his 11 statements were much, shall we say, stronger than

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12 anything I've written. You know, I try to keep a fairly 12

13 low-key and balanced tone, and he was really blasting. 13

A. Okay, sure, thanks. This is not the copy that got pub -- there's an article that he published in the book. Now, this may be -- so we don't know which edition this is, if any. But what I'm looking for here is footnotes. And the footnotes -- see, this is -- this is just an article. It doesn't-- it has no indication that it's ever been published, and, in essence, anybody can write an article. Now, he did write an article attempting to refute me in a book. The reason I'm looking at this article--and the published version is

14 Q. Would it be fair to say, though, that your 15 views you've written about Scientology have been 16 somewhat controversial in the academic community? 17 A. It's raised some contToversy with some people. 18 Q. There are people who have published things 19 being critical of your methodology and the manner in 20 which you've reached your conclusions? 21 A. Do you have a specific? 22 Q. I think Dr. Lome Dawson, for example, 23

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Q. Do you know Dr. Lorne Dawson? A. I do. Q. And who is he? A. He's a sociologist at University of Waterloo

in Waterloo, Ontario. Q. Was he a colleague of yours when you were at

the University of Waterloo? A. No; we were colleagues in graduate school. I

was a year or two ahead of him, so was a slight bit older.

Q. He makes the statement in a paper that, "To the surprise of many, Stephen Kent and Benjamin--"--

A. Beit-Hallahmi. Q. Well, it's Z-A-B --A. Oh, I'm sorry. Q. Z-A-B-L-0-C-K-1? A. Zablocki. Q. " ... are seeking to reconceptualize and

reestablish brainwashing or coercive persuasion as a legitimate social scientific concept, reversing the results of 20 years of academic and legal struggle between sociologists, religion, and others in the anti -cult movement."

A. Would you mind if I had that copy of that paper, just-- first, --

14 different, because I didn't see any footnotes or end 15 notes here--is in the published aliicle he identified-

self-identified that when he wrote this he was doing consulting work for Scientology.

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or how much he got paid. So, you know, the ar -- and then I responded to these criticisms in the same publication.

Q. I guess my question is just a little more 24 basic, Dr. Kent, which is, is it fair to say that there 25 has been some controversy in the academic community

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1 about some of the conclusions that you've drawn about 2 Scientology? 3 A. Well, if you can cite any more about the RPF, 4 I'd be happy to see them in published accounts. And, 5 again, you know, we have to keep in mind the source 6 here. 7 Q. Well, just so we all know what we're talking 8 about, this is a paper by Lorne Dawson, who's an 9 associate professor of sociology and religious studies

10 at the University of Waterloo, entitled "A 11 Methodological Critique of Stephen Kent's 'Brainwashing 12 and Scientology Rehabilitation Project Force.m Which I 13 guess refers to some paper that you'd written earlier? 14 A. In the book I've got an article for this --15 before Lome Dawson's that talks about what I called 16 brainwashing in two different groups. One was in the 1 7 Rehabilitation Project Force in Scientology, which I had 18 mentioned earlier, which is, at least as I portrayed it, 19 the reeducation program in Scientology that's equivalent 20 to a penal system. And there was another group, 21 Children of God, that had a program especially against 22 teens. Lome wrote this response, but, again, citing a 23 paper isn't good enough, because it doesn't have the 24 cmcial information that I need in it to respond 25 appropriately. And then there was my response to his

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1 that specifically addresses some of the methodological 2 critiques he made. So this is not a good -- that's not 3 going to get us too far in understanding what that 4 particular debate is.

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a Ph.D." And I said, "What? He signed Ph.D. on this. I've got it here in writing, Ph.D." So I made phone calls around, and it turned out he had had his Ph.D. revoked. I think it was the University of-- I think he

5 Q. Okay. Well, again, I'm not trying to ask you 6 to agree or respond to what Dr. Dawson said. I'm just 7 trying to determine if there has been academic debate s about some of yow- theories about Scientology?

5 was at Syracuse and then University of North Carolina. 6 I don't know; one of them had revoked his Ph.D. So

Lewis committed academic fraud there. 7

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10 RPF work. Now, there was a response, I wrote an a1iicle 10

11 in the Marburg Journal of Religion, and a Scientologist 11

12 responded to that article, and I responded to her 13

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criticism that Mr. Lewis has?

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Subsequently, he now claims to be a Ph.D. I think he says he got it in a school in Wales someplace. And the last I heard he bad some kind of appointment in ... Scandinavia? Norway, perhaps?

Q. How about Dr. Anson Shupe? A. He's a sociologist at Indiana. Q. Has he had criticisms of some of your work? A. He got ahold of-- when the Cult Awareness

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18 Network collapsed and got bought by Scientology and Scientology interests, he inherited all the -- all the Cult Awareness files. Now, I ctiticized Shupe-- these are long stories. These are kind of the academic debates that go on, though. I criticized Shupe for his expert testimony in the Jason Scott Cult Awareness Network case. So--

20 about the same age. The crucial issues with James Lewis 20

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title correct. It was an annual publication. And the article was -- initially was called "Lustful God." And it was an article about David Berg, who was a leader of the Children of God. The publishers sent out a copy of the table of contents as an advertisement. And an academic in Britain got it, contacted the Children of God, and said, "This a11icle's about to appear." Apparently the Children of God-- either the academic or the Children of God contacted James R. Lewis.

2 him, be responded, and then, you know, we responded. So 3 we had this series of unpleasant exchanges. He then 4 published a book, I think it's called The Agents of 5 Discord, which is about the Cult Awareness Network. And

there's a whole -- there's a section in there tl1at 6

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that the Children of God wrote, and a one-page letter 14

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James R. Lewis, Ph.D. Okay, fme. A couple years 17

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has -- I don't know, I can't remember how long it is, I'm going to say a couple paragraphs, no more than a page, against me. And when I read it, he got fact after fact after fact wrong. A lot of it was about my trips to Germany and talks before a German Bundestag, a parliamentary committee, about-- about sex cults, and they called them psycho groups. And he just got-- he got -- he didn't have the book -- he didn't have the final report from the Gem1an government in front of him, and he made assumptions about what I said. He didn't know that the Gem1an report quoted me in one section, actually about the RPF. So-- so Shupe-- and I've responded to Shupe in this last item that came out on Scientology in a German festschrift, a series of essays in honor of a particular person. These festschrift was in honor of a person named Thomas Gandow, G-A-N-D-0-W,

who's the initial person who brought me over to Germany. He retired, they asked for essays in his honor, I wrote something, and then I thought, "I might as well try to

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1 at least get in print my response to Shupe." So... 1 my work. So there's a bias there. 2 Q. How about Dr. Gordon Melton? 2 Q. Okay. Of cow·se, you would say that he's 3 A. Gordon Melton is not a-- a tenured faculty 3 biased because he brings a religious perspective to the 4 member. As far as I know, Gordon Melton is a Ph.D., I 4 work, I suppose? 5 think in something like church history or religious 5 A. I've seen it in various aspects of his work, 6 history, something. He's an ordained minister. He is 6 yes. 7 the director of the Institute for the Study of American 1 Q. Are there other academics that you're aware of 8 Religion that's based out of-- his collection is in the 8 who have been critical of any of your work or opinions? 9 University of California at Santa Barbara, but as far as 9 A. Well, there's an article that came out in a

10 I know he's not a faculty member. So he's not-- he's 10 journal called Religious Studies and Theology, by Susan 11 done a lot of consulting work for both Scientology and a 11 Rain, that looked at surveillance in Scientology, and 12 number of other groups. You know, we could get into 12 she quotes favorably my RPF work. So it would be 13 reasons why. In part, he doesn't get an academic 13 misrepresenting to believe that it is all, you know, me 14 paycheck, so he's got to get income from somewhere, and 14 against the world. 15 he gets it from books. He's published a number of 15 Q. Well, I guess all I'm trying to establish, 16 books. And-- but he's done consulting for a lot of 16 which I think is true, is that among academics there are 17 groups too. 1 7 different points of view and disagreements, and that's 18 Q. Going back to my original question, what I'm 18 normal in the academic world, and you have a point of 19 really trying to determine is whether there has been 19 view, and there are people who oppose your point of view 2 o some dispute in the academic community about some of 2 o on a number of points and you oppose their point of 21 your opinions about the Church of Scientology? 21 view. I mean, would that be fair? 22 A. Yes; but you have to identify what the 22 A. Yeah, but they're on different issues. I 23 academic community consists of. See, Gordon Melton, you 23 don't know that anyone else in an academic peer-reviewed 24 know, is a player, but he's not-- he's not an academic, 24 joumal has criticized the RPF work. Now, Dawson, you 25 in the sense that he doesn't have a-- he's not 25 know, they're collections of book essays, and the peer

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university-appointed. Q. Okay. He's not doing academic work at this

Institute of--A. He does a range of work. I mean, he's

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1 review process gets a bit murky in books. Sometimes 2 book articles get sent out to outside reviewers. I 3 don't think this one did. I think it was just the

5 certainly published some in academic journals, but he's 6 done some-- a number of apologetic pieces. -

4 judgment of the two editors. So Lome Dawson's article 5 was in there; does it have the weight of the peer-review 6 article, probably not.

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Q. Well, it sounds - 1 MR. MILLER: Let me do this. I'm almost A. -- Including some for Scientology. 8 done. Sean has to go in a minute. Q. Well, it sounds like you would question James 9 I don't know, Sean, did you want to ask

Lewis's credentials for the reasons you've - 10 any questions before you go? A. Uh-huh (affinnative). 11 MR. HYNES: I just have a couple. Q. --stated, but do you question Anson Shupe's

credentials or Gordon Melton's credentials in tenus of 12 MR. MILLER: I mean, if it's okay --13 MS. FRANKLIN: That's fine.

being well-educated and having expertise - 14

A. I don't- 15

Q. --in religion- 1 6

A. -- question Shupe's educational background; I 17

question his use of facts and his -- his judgment. At 18

least with regard to responding to my publications. 19

Gordon Melton seems to have a religious bias 20

in his work. And in scholarship, it seems to me that 21

some people believe that bad theology is one thing, but 22

a secular approach is even worse. And my impression 23

about Gordon Melton is that he is not supportive of all 24

secular interpretations, which is what I try to bring to 25

MR. MILLER: -- with you, Rebecca, I'd let him.

THE WITNESS: Sure. EXAMINATION

BY MR. HYNES: Q. I represent Delgado Development. As I

understand what you said earlier, you don't have any opinions or criticism regarding the housing in this particular case; is that correct?

A. I'm not going to discuss the housing issue at all.

Q. And you don't have any opinions, criticisms

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Desmond, et al. v. Narconon, et at.

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1 that you're going to express in this case regarding 2 Delgado Development; is that also true? 3 A. I'm not going to express any criticisms or 4 anythjng about Delgado Development. 5 Q. Okay. Thanks. 6 A. Sure. 7 MR. MILLER: I need to ask Helena a 8 question, and I think I may be done. 9 MS. FRANKLIN: Okay.

10 MR. MILLER: Do you have -- are you 11 going to ask him some questions? 12 MS. FRANKLIN: Yes, I'm going to have 13 follow-up. 14 (Discussion off the record.) 15 (Recess at 3:3 1, resumed at 3:33.) 16 MS. FRANKLIN: Before I begin asking 17 Dr. Kent some questions, l'd like for 18 everybody to put on the record who they are 19 and who they are here representing or here on 20 behalf of. 21 MR. AMASON: Jeff Amason; I'm 22 representing Dr. Robbins. 23 MR. HYNES: Sean Hynes, Delgado 24 Development. 25 MR. MILLER: Steve Miller and Helena

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1 Kobrin here on behalf of Narconon of Georgia. 2 MS. KOBRIN: Narconon International. 3 MR. MILLER: I'm sorry, I'm sorry, 4 Nar--5 MS. KOBRIN: Narconon International. 6 MR. MILLER: I'm sorry, 1 miss poke. 7 EXAMINATION 8 BY MS. FRANKLIN: 9 Q. Dr. Kent, I just have some follow-up questions

10 for you. First of all, you just heard that Ms. Korbin 11 is here apparently on behalf ofNarconon International; 12 do you know Ms. Korbin? 13 MS. KOBRIN: I'm son·y, my name is not 14 Korbin. 15 MS. FRANKLIN: I'm sorry, how do you 16 pronounce it? 17 MS. KOBRIN: It's Kobrin. 18 MS. FRANKLIN: Kobrin, I apologize. 19 BY MS. FRANKLIN: 20 Q. Do you know Ms. Kobrin? 21 A. We've never met. 22 Q. Okay. Do you know of her? 23 A. I do. 24 Q. Do you know what she does for a living? 25 A. She's an attorney, I believe in partnership

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with Kendrick -- Kendrick Moxon. Q. Okay. A. She did give me a card, and it says Moxon &

Kobrin, so ... Q. Okay. And do you know what her practice area

is? MR. MILLER: Object to the form of the

question. THE WITNESS: I know she handles a

number of -- has handled in the past a number of Scientology-related cases. I can't tell you which areas of law.

BY MS. FRANKLIN: Q. Do you know where her practice is located? A. I've always assumed that it's through

Los Angeles. Q. Okay. Dr. Kent, you were asked a nwnber of

questions generally about the course materials which are Defendants' Exhibits 21, 22, 23, 24, 25, 26, and 12, and you said you reviewed these materials yesterday or last night, correct?

A. That's right. Q. What were you looking for? A. I was looking for connections between what was

in these documents and Scientology concepts, procedures,

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techniques, defmitions, et cetera. Q. And in your review did you see anything within

these materials that is not based on the teachings of Scientology?

A. Every major concept in these books seemed to be based upon Scientology.

Q. Okay. And you weren't asked many specifics about all of the books, and I'm not going to ask you to go through, page by page, each of them, but you did mention that you saw a number of l think you said "classic Scientology terms"; is that right?

A. Oh, sure. Q. And if at trial you're asked to discuss those

terms, Scientology terms, and how they fit into the beliefs and practices of the Church of Scientology, you're prepared and able to do that, conect?

A. Yes. Q. And same thing with the different teachings

within these books; you're prepared to, you know, talk about any one that you're asked about and how that particular teaching or lesson fits into the beliefs and practices of the Church of Scientology, right?

A. Let me trunk. Yes, as long as they don't drift-- as long as they don't have to drift into discussions about morals or ethics or whatnot.


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1 Q. Okay. 1 understand that. 2 A. Yeah. 3 Q. I'm just going to flip through some of these 4 and just ask you a couple questions about each one. 5 Let's start with book number 1. First of all, 6 it's titled "Therapeutic TR Course." Is there a course 7 in the Church of Scientology called "Therapeutic TR 8 Course," or something similar? 9 A. I think it's called "The Communications

10 Course.'' 11 Q. Okay. 12 A. lt includes the TRs. 13 Q. And just tell me generally, what are TRs? 14 A. They're training routines. They're exchanges 1 5 that go on between a client and what's called a coach. 16 Q. And the Church of Scientology uses the term 1 7 "TR," correct? 18 A. That's right, yes. 19 Q. All right. And I'm just looking at tills one, 20 it's TR 8, on Page 333, and some of the depositions, 21 which I understand you haven't read, talk about a TR 22 where the students are asked to sort of shout at an 23 ashtray. Are you familiar with that? 24 A. Oh, sure; that's a well-known TR in 25 Scientology.

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1 Q. Okay. And if you can just generally tell us 2 how that particular TR fits into the beliefs and 3 practices of Scientology? 4 A. Well, Scientology sees the TRs--well, 5 especially this TR--as trying to get a person to project 6 intention into a particular target. And in this case 7 the target, for practicing purposes, is supposed to be 8 an ashtray. The person is supposed to project his or 9 her intention in a very firm, clear, loud manner. You

10 know, tell the ashtray to stand up and fix it up, and 11 tell the ashtray to sit down, and so on. What it means 12 in a larger case of Scientology, well, on the one hand 1 3 in Scientology one - especially as one moves up -- up 14 the bridge, one gives and receives a Jot of orders and 1 5 commands and directives. And that one interpretation, 1 6 at least, is that the TRs are preliminary training for 17 those processes. You know, how to give direct orders, 18 how not to be dissuaded from them, how not to be 1 9 djssuaded from the path if one starts bullbaiting or 20 making criticisms about a person's appearance, or -- or 21 distractions or so on. So it helps prepare the person 22 for the kinds of exchanges one will experience later on. 23 There's even courses about -- in the TRs about moving 24 people around. You know --25 Q. Explain that to me.

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(Discussion off the record.) BY MS. FRANKLIN:

Q. Doctor, do you remember where you were in the process of answering that question?

A. Yeah, we were talking about TRs and what their signjficance is in Scientology. Scientology also believes that people who have had traumatic events are not oriented into what is called present time. So some of the TRs are supposed to get a person oriented towards the here and now. And they're important-- Narconon officials or somebody--Scicntology officials, Narconon officials--must think the TRs are important, because they reappear in the Narconon program. So people go through the TRs a second time later on.

Q. Based on your understanding, are the TRs in the Narconon materials any different than the TRs in the Scientology course books?

A. The only difference 1 saw is that in the Narconon booklet it talks about TR9. But TR9 is actually just a repeat ofTR6b, if I'm not mistaken. Now, I've never seen a mention ofTR9. But because it's a repetition ofTR6b, I don't put a whole Jot of weight on its existence.

Q. Okay. And on Page 368, and it's discussing TR8, the direction is, "The student now does TR8 with

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ills twin." Is the tenn "twin" a Scientology term? A. Oh, sure; it's an assigned person to go

through the -- with whom one goes through the courses. Q. Okay. Now, Defendants' Exhibit 22, which is

the "Learning Improvement Course 3," is that a course that members of the Church of Scientology go through?

A. I -- they wouldn't -- I don't think they go under it in that name, but certainly the content they go through.

Q. Okay. And on Page 114 of Defendants' Exhibit 22, there's a discussion of "working things out in clay." Are you familiar with this sort of drill?

A. Oh, sure, yes. Q. And is that a principle or a drill practiced

by the members of the Church of Scientology? A. It is. The concept behind it is that one

should bring mass, or something physical, to ideas. The example used in the book is that you can talk about a tractor, but until you actually see and touch a tractor you really don't know what it is. The working with clay is one form of bringing a mass to ideas.

Now, other forms involve doing demonstrations with whatever items one has. Sticky notes, a pencil, paper clips, a rubber band, or so on. But it's still the same basic principle.


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1 Q. Exhibit 23, which is 4a, the "Communication 1 negative ones. The person subverts an environment which 2 and Perception Course." Is that a course that members 2 he or she is in. Addresses a wrong target. You know, 3 of Scientology may go through? 3 if something goes wrong, he or she blames the wrong 4 A. Let me look at this, because this is-- if I'm 4 person. Speaks in generalities. Will say, you know, 5 not mistaken, this is for all the-- okay. The 5 "they say" as opposed to a social personality, who he 6 objectives are here, and objectives are standard 6 specifically identifies by name that Joe Blow said. 7 Scientology practices; again, these are ones that 7 Person is opposed to any beneficial social action, and B Hubbard said would be useful for people who have been on a it goes on and.on like this. And the parallels in the 9 drugs to bring them up to present time. Now, I 9 social personality are the opposite. People who work

10 thought-- yeah. I thought this was the one-- yeah, 10 for the betterment of society; who speak in specifics; 11 you're back -- but also you're back to the training 11 who, when transmitting communications, don't make it 12 routines in this book. 12 worse, but make it a bit easier for the person to hear 13 Q. Okay. And training routine number 6 describes 13 who is going to receive the communication. So it's 14 a dtill where it sounds like the students look at a wall 14 things like that. 15 and then go touch a wall and then look at a wall. Are 15 Q. And so is it fair to say that in Scientology 16 you familiar with that training routine? 16 people may be declared an SP, a suppressive person? 17 A. It's a-- it's done in Scientology. 17 MR. MILLER: Object to the form. 18 Q. Okay. What's sort of the purpose, or-- 18 THE WITNESS: Well, in Scientology 19 relating to the beliefs and practices of Scientology of 19 people do get declared to be SPs, or 20 that drill? 20 suppressive persons, and Hubbard made an 21 A. Well, it seems like it's a variation on the 21 association, which actually appears in the 22 location. It's again to make sure a person gets brought 22 Narconon books, between being an SP and being 23 into present time. 23 psychotic. Now, it's not necessarily the 24 Q. Okay. 24 case that a psychotic means the same for 2 5 A. Some variations on that drill involve a 2 5 Hubbard that it might mean in a psychiatric

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1 person, one's twin, walking around with one. So to 1 context. But he does use the term. So an SP 2 physically take one up to a wall and get the person to 2 is an enemy of all things good. 3 touch it. I think some of the walking is not 3 BY MS. FRANKLIN: 4 necessarily involved in touching, but some of it is, so 4 Q. Okay. Now, on Page 269 under the title 5 gently taking hold of a person's arm and walking the 5 "Handling the potential trouble source," there's a tenet 6 person up to the wall. 6 or a ptinciple that discusses illnesses and what they 7 Q. But it's a Scientology concept? 7 stem from. And I'm just going to read from it. Says 8 A. Oh, sure. Sure. 8 that "All illnesses, in greater or lesser degree, and 9 Q. All right. And then Defendants' Exhibit 24, 9 all foul-ups, stem directly and only from a PTS

10 "The Ups & Downs in Life Course." Book number 5. Is 10 condition." Is that a Scientology principle? 11 that a course that members of the Church of Scientology 11 A. Yes. 12 would go through? 12 Q. And just generally if you can explain that 13 A. Well, the -- what you get in here is the -- if 13 principle to us. 14 I'm not mistaken, this is the booklet that discusses the 14 A. People who are not antisocial personalities 15 social personality, the antisocial personality and the 15 but who are associated with them get a lot of the 1 6 potential trouble source. They're standard -- they're 16 negativity from the suppressive people. And the problem 17 Scientology te1ms; there's actually a Scientology course 17 becomes when a -- that potential trouble source is 18 called "SP/PTS." 18 associated with a Scientologist or a person in a 19 Q. Just explain to us generally what an SP and 19 particular group and has to receive the criticisms, 20 PTS is, and how that fits into the beliefs and practices 20 through the PTS, of that particular program or 21 of the Church of Scientology. 21 activities or behaviors or belief and so on. And so, in 22 A. The booklet identifies at least 12 22 order-- in Scientology you can't progress in courses if 23 characteristics for an SP, and then 12 mirror 23 you have-- if you're associated with a PTS. You've got 24 characteristics for a social personality. And the 12 24 to deal with the PTS in some way. You've got to get the 25 characteristics for an antisocial personality are all 25 PTS to realize what he or she is doing and then stop.

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1 You've got to handle the PTS in some way, and if those 2 techniques fai l, then you're allowed to disconnect from 3 the PTS. 4 Q. Okay. This may be a little out of order, but 5 is there any principle or tenet in Scientology relating 6 to the discussion of the Scientology tech among its 7 members, or externally? 8 A. Uh-huh (affirmative). You'll notice in the 9 course pack that if one's having trouble, then there

10 are -- then the course pack gives three explanations as 11 to why. The big issue is the misunderstood word. The 12 claim is that a person has gone past a word that he or l3 she didn't understand, and in doing so bas disrupted the 14 ability to engage in the material. 15 At no time can a person who has questions go 16 to, say, a case supervisor and get the case supervisor 17 to explain with a for-example. The only discussions in 18 Scientology involve a case supervisor either helping a 19 person find a misunderstood word or pointing the 20 individual to the exact Hubbard policy letter which 21 outlines the doctrines. This kind of explanation that 22 would go on in a classroom, where one might try to draw 23 analogies outside of the particular example, cannot go 24 on in Scientology. 25 Q. Okay. What about criticisms of Scientology?

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1 Is there some sort of principle or guideline relating to 2 members' criticisms of the church? 3 A. If someone hears you criticizing Scientology, 4 the person is supposed to do a knowledge report on you. 5 To write you up. You know, it's out -- it's out ethics. 6 Q. Okay. And just explain to us generally what 7 "out ethics" means. 8 A. You know, ethics is, you know, to keep 9 Scientology working, and even if there are problems, to

10 keep the problems internal. Out ethics is doing 11 something that has the potential for hmting, damaging 12 Scientology's ability to progress and develop and so on. 13 And these knowledge reports are write-ups of a person 14 who knows about some out ethics phenomenon that's going 15 on, hence the term "knowledge report." 16 Q. And ifNarconon bas a policy against 17 criticizing the Narconon program, meaning that a person 18 may be out ethics if they criticize the program 19 internally or externally, would that be consistent with 2 0 the teachings of the Church of Scientology? 21 MR. MILLER: Object to the fotm of the 22 question. 23 THE WITNESS: Well, yeah, you can't --24 you know, you can't object to Hubbard's 25 writings. There's -- there's no movement

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inside Scientology that allows for discussion or an augmentation of Hubbard's writings, a variation. What's written is true, according to Scientologists. So there can't be any criticism or any kind of-- any kind of variation from them.

BY MS. FRANKLIN: Q. And is that why there's little variation

between these course books and the courses in Scientology?

MR. MILLER: Object to the form of the question.

THE WITNESS: Well, that certainly makes sense to me. I mean, you can't have -- you couldn't have course books that are -- that are based upon L. Ron Hubbard without actually using L. Ron Hubbard. You know, Scientology is very careful about how groups use Hubbard technology. You know, the perspective is that it's the road to total freedom. It's not a road, it's the road. So it's got to be followed precisely as Hubbard laid it out.

BY MS. FRANKLIN: Q. Defendants' Exhibit 25 is comse book

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number 7, which is "Changing Conditions in Life Course." Is there a similar or exactly same course that members of the Church of Scientology may go through?

A. Yeah, I j ust want to make sure this is all the conditions -- oh, yeah, these are the conditions -- the conditions are standard doctrines in Scientology. I mean, they're fairly basic to the organization.

Q. Well, just explain what conditions -- you don't have to list the conditions, but what does the term "condition" mean in the context or the beliefs and practices of Scientology?

A. Yeah, I have to use my own words. It's always best to use Hubbard's, but in this case I'll have to use my own. The conditions are descriptions of one's relationship to, you might say, one's responsibilities. This relationship can be on the straight organizational level, but it also involves bow an individual relates to his or her, say, job assignment. Or even his or her relationship with, you know, family and so on. So the conditions lay out how one is performing what one should be perfonning, or how an organization is performing and what it should be performing.

Q. And are those also found in the Narconon comse --

A. Oh, --


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1 Q. --materials?

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2 A. --yes. The-- it seems to me theNar --3 well, the Narconon --the conditions laid out in 4 Narconon are exactly the same as I found-- as I know 5 exist in Scientology. 6 Q. What does the term "technology" mean in 7 Scientology and/or Narconon materials? 8 A. It's probably --I guess, again, using not 9 Hubbard's term but my own, it's probably the sum total

10 of the techniques, methods, definitions, the 11 applications of Scientology beliefs and principles into 12 a particular situation. 13 Q. And did you see that term used similarly in 14 the Narconon materials? 15 A. "Technology"? I don't recall, just because 16 it's so common. 1 7 Q. That's fme, if you don't recall. 18 A. Yeah, I don't... I could very quickly check 19 some other books, but it's sometimes just referred to as 20 "the tech." 21 Q. "The tech"? 22 A. T-E --T-E-C-H. 23 Q. Okay. 24 A. I'm just looking in the indexes. Well, 25 here--

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glossruy or an index at the end of each of these course material books?

A. There is. I believe it literally is at the end of each one.

Hand me those two. Thank you. There's "technical." "Having to do with a

learned procedure or skill." Q. Uh-huh (affmative). A. Not quite the same, but it's close. No. Q. All right. Defendants' Exhibit 26 is book


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1 A. Well, they -- they can pay to take it, but 2 it's also-- "The Way to Happiness" booklet is a 3 dissemination booklet for Scientology. 4 Q . Okay. And what do you mean by that? 5 A. It's another one of these long academic 6 explanations. Back in the early part of the 20th 1 century there was an author not related to L. Ron 8 Hubbard, his name was Elbert Hubbard. Well-known for 9 popularizing of writings and so on. And earliest years

1 o of the -- I'm thinking around 1902, but I could be off 11 about the date, he wrote a pamphlet called "A Message to 12 Garcia." This was supposedly a message that a military 13 commander of some sort gave to an underling to take to a 14 person named Garcia, who happened to be a rebel fighting 15 in the jungles. Without question, the individual took 16 the command, and spent two years, found Garcia, gave him 17 the message, and Elbert Hubbard's "Message to Garcia" 18 booklet got reproduced by many, many companies. These 19 companies wanted to convey to their employees that if 2 o you get a command, a directive, you should do it. You 21 know, even if it 's hard to do, "Look what this soldier 22 went through to find Garcia." 23 Now, Hubbard knew about Elbert Hubbard. 24 He's-- I think it's in one of the early Dianetics --25 one of the earliest Dianetics books, the books dedicated

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to Elbert Hubbard. So he certainly knew about Elbert Hubbard. And L. Ron Hubbard wanted some sort of document he could portray to the public that was secular in nature that would spur their interest in what

5 Scientology was. So it's a booklet, and the hope 6 was--and it has happened, I believe, in some cases--that

companies would then reproduce it and give it to their employees and so on.

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Q. So it's a ... A. Yeah, it's a statement of a -- of morals and

ethics. Just for what it is, you know, on the surface. I think the behind-the-scenes story, it's a way of getting Hubbard's name into a secular environment.

14 number 8, and it's "The Way to Happiness Course." Is 14

15 this a course that members of the Church of Scientology 1 5

16 are offered? 16

Q. Okay. So we just discussed a couple of just different things in each of these course books, but as you said before, you're prepared to discuss other principles or tenets of the Church of Scientology and how they're evidenced in these books, and explain the beliefs and practices of Scientology at tJial if you're asked about those, correct?

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A. There's an entire book called "The Way to Happiness," and there's a "Way to Happiness Course" that's related to it.

Q. That members of the church can pay for that course to--

MR. MILLER: Object to the form of the form.

BY MS. FRANKLIN: Q. --or the course material?

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A. If I'm asked. MR. HYNES: Sorry to inteiTupt you, but

I have a 4 o'clock meeting in Marietta; is it possible for me to call in?

MS. FRANKLIN: Sure. I've got like

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three more questions, though. But, I mean ... 1

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Q. Okay. And last point, Dr. Kent. You 1

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number, but you all keep going, and then I'll call in. Just keep going.

4 MS. FRANKLIN: Did I pronounce it right?

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(Discussion off the record.) (Thereupon, Mr. Hynes exited the deposition room.)

BY MS. FRANKLIN: Q. Just a couple more questions, Dr. Kent. At

least for me. In your review of these materials, did

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you see any mention or discussion or analysis of drugs 13

and alcohol as they relate to the treatment of addiction?

A. I can't tell you where in the booklets, but there are occasional mentions.

Q. Okay. A. Actually, I can tell you one. Q. All right. A. In the course number 8, "The Way to

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1 people from taking harmful drugs." Page 31, "Defme 1

2 excess," Page 32, "What is meant by 'Do not take alcohol 2

3 in excess."' Page 33, "Give an example you've seen of 3

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5 down five real examples of how you could prevent someone 5

6 from drinking alcohol to excess." So there -- there're 6

7 occasional mentions. 7

8 Q. Are those also included in the regular "Way to 8

9 Happiness Course" in Scientology? 9

10 A. Yes, they're included in the regular -- 10

11 Q. Okay. So the reference-- 11

12 A. --"Way to Happiness" course in Scientology, 12

13 yes. 13

14 Q. The references to drugs and alcohol that 14

15 you've seen in these materials are not specific to the 15

16 Narconon program? 16

17 A. I'd have to go back very carefully through the 17

18 booklets. There are occasional mentions about drugs. 18

19 You know, "Don't take, don't use," and so on. And I'm 19

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21 where I'm sure they appear in Scientology, I'm not going 21

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23 Occasions, the Scientology documents do discourage drug 23

24 and alcohol use. But that's where you have to actually 24

25 sit down with these books, go to the courses, and 25

MS. KOBRIN: Uh-huh (affirmative). BY MS. FRANKLIN:

Q. --represents the Church of Scientology in a number oflegal matters; did you notice whether Ms. Kobrin was passing Mr. Miller notes during this deposition?

A. Oh, I did notice she passed quite a number of notes; I can't tell you how many.

Q. Okay. Thank you, Dr. Kent. A. Sure. Thank you.

FURTHER EXAMINATION BY MR. MILLER:

Q. Dr. Kent, just a few more questions. You checked on the word "teclmology," which is

a Scientology term that's in fairly common use in the Church of Scientology, to see ifthere's any mention of that word in the Narconon books, and I think as far as you can tell that that word is not being used in the Narconon books?

A. I'd have to go-- it's not in any of the glossaries that I looked at.

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Q. Right. And you don't recall, from your review of the books last night, seeing that term?

A. I don't recall one way or the other. I wasn't looking for it, so I can't really say.

Q. And the word "Scientology" also does not appear in these books; is that correct?

A. As far as I know, it doesn't. Q. And there's no suggestion in these books that

to the extent people have a spiritual aspect to their lives, that it has to be Scientology versus any other spiritual aspect?

A. No-- would you mind, sir, ifl saw that green book for a second?

Thank you. I just want to check, there's some ...

No, I think we're okay. I was-- let me see. No, I just remembered, they were in the back

of "The Way to Happiness." There were references to the -- it looks like the booklet, but I didn't see any references in the booklet to anything involving Scientology.

Now, "The Way to Happiness Foundation International, 201 East Broadway, Glendale, California"; I'm not sure if there's any other Scientology org --if there's a Scientology organization also at that address.

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1 I know there have been -- Glendale's been a popular 2 location for Scientology organizations, but... 3 Q. Bottom line is, there's no reference to 4 Scientology in these books that you --5 A. Not that I've seen. 6 Q. Okay. You have never been a Scientologist? 7 A. I-- no. 8 Q. Have you ever gone through any training from 9 the Church of Scientology?

10 A. Any formal training, no. I've been to a 11 number of Scientology meetings. 12 Q. But you've never --13 A. No. 14 Q. -- trained as a Scientologist? 15 A. I've never trained as a Scientologist. 1 6 Q. Have you practiced any religious discipline in 17 your life? 18 A. I have. I'd like to keep those issues 19 private. 20 Q. Let me just ask if at the present time you 21 practice any religious discipline? 22 A. No. 23 Q. Can you tell me approximately how many years 24 ago that you ceased having practiced any religious 25 discipline?

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1 A. I'm trying to locate... In and around the 2 year 2000, probably a bit earlier. 3 Q. But in terms of any formal study ofthe Church 4 of Scientology provided by Scientologists, it sounds 5 like you have not engaged in a formal course of study 6 with anyone from the Church of Scientology? 7 A. I've not been through any of the courses. As 8 I said, I've been through events and interviewed 9 Scientologists, but no courses.

10 Q. Okay. But basically your knowledge of 11 Scientology comes from reading materials and then your 12 own interpretation of those materials, and maybe a 13 conversation or two with people who are Scientologists? 14 A. Yes. I'd say more than -- more than a 1 5 conversation or two. Certainly I've talked a lot to 16 former members. And I talked, indeed, to Scientologists 1 7 as well. 18 And then there's a lot of material written 1 9 about Scientology. Both primary and second-- secondary 20 materiaL 2 1 Q. Okay. But basically you've read about it and 22 talked to people who may have practiced it? 23 A. That's right. 24 Q. The "misunderstood word" issue; am I correct 25 that the books, the Narconon books, provide, in effect,

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an encyclopedia, or a glossary of terms, and students are encouraged, if they come across a word they don't understand, to go look in the dictionary to determine the meaning?

MS. FRANKLIN: I don't mean to interrupt you, but I j ust think for purposes of the record we need to -- is this Sean?

MR. HYNES: It's me. MS. FRANKLIN: Okay. We just want to

put on the record that you're back. (Thereupon, Mr. Hynes is present via telephone.)

MR. MILLER: So is --MR. HYNES: I'm back, and my car got

booted, so I'm still in the garage, but I can't come back up there.

THE WITNESS: Oh, my God. MR. MILLER : Holy smokes. --MR. HYNES: So --MR. MILLER: -- What happened? MR. HYNES: -- carry on. MR. MILLER: Sorry. THE WITNESS: He's awfully calm about

that, I... MS. FRANKLIN: Do you want to go off the

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record? (Discussion off the record.)

BY MR. MILLER: Q. So students are encouraged to go look up the

word or figure it out for themselves? A. Yes, sir; there's a very -- I think usually,

if not always, at least in books, a glossary of words that people might have trouble with. And also they're encouraged to look in various dictionaries. And there are -- there are specific Scientology dictionaries in addition to ordinary English language ones.

Q. And, generally speaking, the training routines are to help people become better communicators?

A. That's what Scientology claims. Q. Have you evaluated professionally -- I mean,

can you offer expertise on communication skills? A. I can't. Q. Or on what can assist people in the

interpersonal relationships? A. No. Q. Or what can help people's self image or make

them feel better about themselves? A. No, sir, I can't. Q. I mean, those are not areas that you're going

to ...

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1 A. No. 2 Q. So whether the training routines help people 3 become better communicators or confront life situations 4 in a more positive way, you don't have an opinion one 5 way or the other? 6 A. I don't have an opinion one way or the other. 7 Q. And dealing with life's ups and downs, that 8 type of issue, you're not an expert on how people deal 9 with emotional distress or stressful situations in their

10 life? 11 A. I'm not a -- I don't study the sociology of 12 emotions, so ... 13 Q. Okay. And whether the "Ups & Downs" book, for 14 example, helps students deal with stressful life 15 situations, you don't have an opinion one way or the 16 other? 17 A. I don't have an opinion. 18 Q. And the "Conditions" book that discusses 19 students' responsibilities to, say, family, or 20 responsibility to friends, or the responsibility to 21 themselves, perhaps, I mean, again, you wouldn't have 22 any expertise about whether that's effective in 23 encouraging people to become more responsible; is that 24 fair to say? 25 A. I have no opinion.

Page 218

1 Q. Right. And "The Way to Happiness," as I 2 understand it, was generated by the Church of 3 Scientology at one time as a purely secular document 4 that would just be of use to people in dealing with 5 moral and ethical issues? 6 A. That's my understanding. 7 Q. Right. In other words, it was -- "Respect the 8 religious beliefs of others" --9 A. Yeah.

10 Q. -- is a principle in that book. "Try not to 1 1 do things to others that you would not like them to do 12 to you" is another principle? 13 A. Uh-hub (affirmative). 14 Q. Correct? 15 A. That's true. 16 Q. These would be ... 17 And I may have misspoken. "The Way to 18 Happiness Course," do you know who developed that book? 19 A. I've always assumed it was Mr. Hubbard. 20 There's certainly a Way to Happiness Foundation fixed 21 around it, but I've always -- everything I know is that 22 Mr. Hubbard wrote it. 23 Q. Okay. Would it be fair to say that that is 24 something of an assumption on your pa1t? 25 A. I don't think so.

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Q. Do you know if Mr. Hubbard wrote things that were unrelated to the Church of Scientology?

A. Early on he did, and later in his career there is a big science fiction book. One was a ten-- a decalogue, a ten-volume book. Now, to say it's unrelated to Scientology is generally true, but if one knows how to read it and one reads certain sections, one can see some references, some allusions to Scientology, in there. There's also I think a later single-volume science fiction book be wrote.

Q. Okay. Going back to these books, there's one book about learning improvement. You're not an expert in bow to improve people's ability to learn or --

A. No, sir, I'm not. Q. --remember things? So, again, whether the

materials in here in the "Learning Improvement Course," which is book number 3, whether those are effective or not in terms of helping people leam, you don't know one way or the other?

A. I'm not going to make comments one way or the other.

Q. And same with communications and perception; you're not an expert in communications or perception, are you?

A. I'm not, no.

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Q. Or in teaching people personal values and integrity?

A. I'm going to do my best to stay away from moral issues if I can.

Q. Okay. So in terms of the substance of these books -- you can say the opinions you have about that they parallel things that you see in the Church of Scientology very closely, or in some cases you think may be even identical, but in terms of the substance of whether they are effective or valid, you're not going to offer opinions one way or the other about that.

A. I'm not going to offer opinions on whether they're effective or valid.

Q. Right. And I think would you agree that, in general terms, that any organization that promotes good moral values, good ethics, people's ability to communicate effectively, to deal with life's stresses, those types of things, is generally a positive thing?

A. It's a complicated question. I mean, my ... Q. Well, let me withdraw the question, because I

think it's probably beyond the scope of what--A. Fair enough. Q. --you've come here to testify about.

I think we're done. Dr. Kent, I appreciate your time. --


(55) Pages 217- 220



1 A. Thank you very much.

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2 Q. --Again, you know, we don't want to be 3 surprised; if there's anything else that you come up 4 with that you're going to ever testify about in this 5 case, we need to hear about it. 6 A. Okay. Sure enough. 7 Q. Thankyou. 8 A. Thank you. 9 MS. FRANKLIN: Thanks.

10 (Deposition concluded at 4:21 p.m.) 11

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E R R A T A S HE E T

I, the undersigned, STEPHEN ALAN KENT, do hereby certify that I have read the foregoing deposition and that, to the best of my knowledge, said deposition is true and accurate (with the exception of the following corrections listed below.)

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Notary PublJ.c SJ.gnat ure Date. ________________ __

My Commission Expires:


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1 CERTIFICATE

2 G E 0 R G I A:

3 FULTON COUNTY:

4 I hereby certify that the foregoing

5 deposi t ion was taken down, as stated in the

6 caption, and the questions and the answers

7 thereto were reduced to printing under my

B direction; that the preceding pages represent

9 a true and correct t ranscript , to the best

10 of my ability, of the evidence given by said

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witness upon said hearing. And I further

certify that I am not of kin or counsel to

the parties to the case; am not in the regular

employ of counsel for any of said parties;

nor am I in anywise interested in the result

of said case .

This, the 17th day of January, 2012.

Jo Tomoff F1scher, RMR CCR No. B- 924

Notary Commission Expires B-25-2012


(56) Pages 221 - 223



$

$2500 (1) 166:19

[

[sic) (1) 177:8

A

abandons (1) 119:23

ability (9) 115: 10;118:22,22,23; 133:8;201 :14;202: 12; 219:13;220:16

able (12) 22:19;53:4;57:22; 88:23;96:5; 115:24; 116:1 ;131:18,18;145:20; 153:11;192:16

above (1) 17:4

aboveground (1) 95:23

absence (2) 106:3,3

absolutely (1) 86:12

absorbed (1) 111:22

abstract (1) 127:9

abuses (1) 176:20

academic (29) 65:2;78:7,15;127: 17; 149:22; 150:2;176: 18,25; 177: 1,6,16;178:21; 179:25; 181 :7, 15; 182:6,8, 16; 183:7 ,21; 185:13,20, 23,24;186:2,5; 187:18,23; 207:5

academics (3) 128:6;1 87:7, 16

accept (1) 135:25

accepted (1) 88:6

access (2) 169:3,24

according ( 4) 63:22; 136: 14; 137:4; 203:3

account (1) 64:14

accounts (1) 180:4

accurate (2) 173:25;174:5

Min-U-Script®

across (3) 11:13;12:1,8;15:10; 169:21 144: 10; 163:17;215:2 21: 15;24:17;29: 1;39:23; agreed-upon (1)

Act (2) 52:5;60:24;67:13;68: 15; 41:4 8:2 1;120:18 71: 17;72: 19;74: 14; agreeing (2)

action (5) 81: 15;87:1 0;99:7; 56:20;87:23 121:9,10, 10;127: 10; 101 :20;102:4;105:8; agreement (44) 199:7 106:24; 121: 15;126:20; 8: 10;58:23;59: 11,13,

actions (2) 128: 19;130:7;131 :10; 21 ,23,25;62:3,8,9,11 ,14, 38:2;89:2 132: 16;139: 18; 143:3; 15,17;65:22;82:11,18,19;

active (2) 162:8; 167:19,21 ; 169:6; 84:10, 14;87:25 ;89: 13,22, 96: 16;99:24 171 :22; 172: 12,19; 24;90:2,17;91 :5,11,12,

actively (2) 175: 17;186: 11;201:8; 15;92:8,16,22;108:2; 102:21;133:14 206:11 ;211 :5;218: 13 109:2;158:12; 159:3,4;

activities (3) affirmatively (1) 160:6,6; 164:22,24; 169: I; 78:11 ;182:21 ;200:21 86:19 171:7

actual (1) affirmed (1) ag•·eements (2) 71:7 9:12 62:20;90: 16

actually (19) afraid (1) Ah (1) 16: 14;20:25 ;26: 16; 122:8 167:17 63:19;80:22;99:13; afterwards (1) ahead (10) 114: 12; 116:8;119:18; 95:16 10:13;16:21;19:11; 135:6; 156: 16;184:18; again (52) 67:22;85: 1; 115:9, 15; 195:20; 196:1 9; 198: 17; 19: 19;21: 1;26: 19;27:1; 168:4; 169:7; 178:9 199:21 ;203:17;209: 19; 39: 17;40:16;42:21; ahold (4) 210:24 44:20;47:23;49: 15;56:7; 20:25;62: 12;89:20;

added (3) 61 :7;66:21 ;67:11 ;80:7; 183:17 25:23;26: 13;97:21 86:21; 102:6,18; 107:2; ALAN (2)

addict (1) 110: 19; 116:21; 121:13; 9:11;10:16 135:18 122: 11;124:5;132:21; A-L-A-N (1)

addiction (6) 139: 19;142:3;144:12,16; 10:16 48:20,23;50:22; 124: 1; 146:5, 16,25; 148:2; 153:7; Alberta (7) 151:2;209:15 158: 13;160:23;161 :5,17; 10: 17;32: 16,25;33:7,

addition (5) 163: 1; 164:2,12;166:5; 11,14;35:11 33: 17;50: 11 ;78: 1 0; 168:1; 180:5,22;181 :5; alcohol (19) 135:8;216:11 197:7,22;205 :8;217:21; 48:20,23;49:4;50:22;

additional (4) 219:15;221:2 51 :5;54:5;96:21; 10 I :23; 51:23;135:18;162:22; against (16) 105:24;133:23; 138:3; 164:22 37:2,6,8;38:2;40:9; 148:9;154:3;209: 14;

address (2) 43:9;44: 12; 134:23; 210:2,4,6,14,24 137: 10;212:25 135: 15;176:7;177:5; Alcoholics (4)

addressed (1) 180:21 ;182:19;184:9; 70:20; 123:20,23;124:6 148:3 187: 14;202: 16 aligned (1)

addresses (2) age (2) 132:23 181:1;199:2 19:8;181:20 Allan (2)

adults-would (1) agent (3) 35:18;36:7 19:1 90:20;91:8;92:11 allays (1)

advance (1) agents (2) 100:23 133:18 91:19;184:4 allegations (1)

advanced (1) aggressive (2) 37:10 31:17 38:1;177:3 allness (1)

advertisement (2) ago (7) 119:19 109:21;182:5 36:1 ;90:23;99:5; allowed (2)

advice (1) 110:20; 156: 10;181: 18; 8:21;201:2 175:25 213:24 allows (1)

advocating (1) agree (18) 203:1 123:11 8:13,17,18,22;57: 19; allusions (1)

affected (1) 66:3;86: 17;97:6;1 08:7; 219:8 154:22 123:6; 125:11 ;129:21; Almost (5)

affidavit (1) 142:5,9;160: 14; 168: 13; 12:2; 17:11 ;65:4; 173:3; 35:1 181 :6;220:14 188:7

affidavits (1) agreeable (1) along (8) 107:8 170:9 58:6;1 06:14;107: 18;

affirmative (43) agreed (1) 118:9; 161:19; 181 :22;


Stephen Alan Kent January 5 2012

' 182:12,20

Alternative (2) 149:14,16

although (4) 16: 12;41: 11;96:6; 122:11

always (17) 17: 13; 18: 13;47:7,10; 48: 13;80:7;85: 14;86:24; 96:7;110:7;151 :21; 154: 19; 191: 15;204: 12; 216:7;218: 19,21

AMASON (4) 144:21,25;189:21 ,21

ambiguity (1) 56:22

America (2) 32:5;78:13

American (4) 31:22;80:9; 151 :4; 185:7

among (4) 42: 17;43:4; 187: 16; 201:6

amount (5) 18: 17;26:22;32 :23; 33:22;34:1

analogies (1) 201:23

analy (1) 110:1

Analysis (15) 102:12,14, 17;109: 12, 13,16,17 ,23; 110: 15,25; Ill :7;112:23;125: 13; 130:20;209: 13

analyzes (1) 136:17

ancillary (3) 56: 10;88: 15;90:6

and/or (2) 58:11;205:7

Angeles (1) 191 :16

anger (1) 134:23

angry (1) 17:11

Animal (1) 41:19

annual (2) 87:7;182:1

anonymity (1) 63:23

Anonymous (4) 70:20; 123 :20,23; 124:6

Anson (2) 183:14;186:12

answered (2) 63: 10; 140:1

Anthony (2) 35:18;36:7

anticipate (2)

(1) $2500 - anticipate



52:6;167:24 anticipated (1)

140:21 anti-cult (1)

178:23 antipathy (2)

150:22;151:14 anti-psychiatry (2)

135:22; 153:8 antisocial (7)

19: 15;113: 12, 17,22; 198: 15,25;200: 14

anyplace (2) 54:21 ;83 :23

apart (1) 41:13

apologetic (1) 186:6

apologize (2) 144:12;190:18

apparent (1) 110:8

Apparently (2) 182:8; 190:11

appear (12) 49:8;82:6;88: 18; 135: 15;}40: 12;141 :4; 163:22;173:9;182:7; 210:21,22 ;212:6

appearance (1) 194:20

appeared (1) 86:24

appears (3) 131:21; 173:25;199:21

application (1) 42:1

applications (1) 205:11

applied (2) 33:14;58:17

applies (1) 111: 1

appointment (2) 182:16;183:12

appreciate (8) 10:6;50:9;84:20; 107: 12;121 :1;130: 14; 157:25;220:24

approach (3) 56: 1;97:9; 186:23

appropriate (2) 15:3;174:24

appropriately (1) 180:25

approving (1) 71:12

approximately (3) 27:4,11;213:23

apt (1) 122:2

ar (1) 179:20

Min-U-Script@

archway (1) assigned (1) auditing (1) 101:7 196:2 44:3

arduous (1) assignment (1) augmentation (1) 31:23 204:18 203:2

area (7) assignments (2) author (1) 30:21;31:7,18;50: 18; 115:5,7 207:7 147:2; 154:6;191:5 assist (3) availability (1)

areas (13) 154: 12;157: 14;216: 18 25:17 27:21 ,23;50:10, 11 ,14; assistant (2) available (1) 52:8;67:21; 109:18; 31 :14,25 94:1 128:8; 130:20;160: 13; assistantships (1) Aviv (2) 191:12;216:24 32:7 177:9,9

are-I'U (1) assists (2) Avoid (5) 114:16 163:19,19 113: 14; 130: 18;174: 19,

arguably (2) associate (5) 21 ;175:5 48:11;161:10 44: 15, 16;55: 14;114:6; aware (6)

argue (2) 180:9 128: 10;132:12;155: 19, 102:19;132:4 associated ( 6) 23;181:16;187:7

argument (1) 48: 11;54:9; 113:21; Awareness (11) 17:9 200:15,1 8,23 175:9,11,19,24;176:3,

Arizona (2) Association (5) 8, 13;183: 17,20,23;184:5 95:2;148:11 53:5;57:21 ;58: 16; away (9)

arm (1) 113:23;199:21 41 : 12;49:25;50: 1; 198:5 assume (8) 67:21; 104: 13;147:2;

around (9) 10:9; 18: 15;21 :6;24: 15; 162:23; 164:23;220:3 98:8; 105: 18; 144:14; 47:4,15;106: 16;165:3 awful (1) 183:3; 194:24;198:1; assumed(4) 31:24 207: 10;214: 1;218:21 24:9;96:7;191:15; awfully (1)

arrested (1) 218:19 215:23 36:20 assuming (3)

article (32) 127: 13;161 :24;166:20 B 148:5; 149:8, 10,14,25; assumption (3) 150:6,14;170:23,24,25; 17:22;113:2;218:24 back (85) 171:2,4,1 0,11; 177:4, I 0; assumptions (2) 13: 13,22;14:9;16:3,6; 179:5,9,11,11 ,15;180:14; 112:12;184:16 20:16, 18;22: 1, 16;26:4, 181: 10,12,22,23;1 82:2,3, astonished (1) 16;28: 11 , 17;29:25;30: II; 21; 187:9;188:4,6 11:14 33:5,7,13;35:19;37: 17;

article-and (1) Atlanta (3) 38: 15;44:20;52:24;58: 1; 179:13 24: 16; 166:20,23 60:23;63 : 1;65:21 ;68:6;

articles (8) atomic (2) 70: 12;80:7;82:22;83:22; 11 :2;77:3;171 :6, 11,23; 95:22; 152:17 84:21;85: 12;90:25;93:3, 172:3,10;188:2 Attach (1) 14,20;95:18, 19,25;97:2;

article's (1) 58:21 98:4,12,12, 19,21;99:4; 182:7 attached (3) 104: 13;109:9;110: 19;

articulated (1) 38:19;58:22;1 10:19 116:5;120: 1,24; 124:11 ; 40:11 attempt (2) 126: 17;133: 14,20;

artists (1) 135:23;157:6 134: 13,19;152:22; 119:11 attempting (1) 153:10,21 ; 154: 17; 155:2;

ashtray (5) 179:12 158: 13 ,18,21;159:20; 137:3; 193:23;194:8, I 0, attempts (1) 162:25; 164:24;165: 12, 11 156:11 13;181: 19; 182:24;

aspect (5) attention (1) 185:18;197:11,11;207:6; 47: 12; 132:6; 135:23; 144:11 210: 17;212: 17;215 : 10, 212:9,11 attitude (1) 14,16;219:11

aspects (5) 48:8 backed (1) 13: 13;47:25; 135:3; attitudes (1) 41:12 166:7;187:5 16:20 background (7)

aspiration (1) attorney (1) 13:12;28: 18;36:8; 106:4 190:25 48: 19;49:9;143:5;186: 17

aspirations (1) attorneys (3) backwards (l) 104:15 73:7;174:3; 182:15 71:13

assessment (2) attracted (1) bad (6) 102: I I ;133:24 102:2 30: 18;114:7;141 :15;


Stephen Alan Kent Januar y 5, 2012

165:23,24; 186:22 badly (1)

17:10 badness (1)

166:6 bag (1)

117:14 balanced (1)

177:13 band (1)

196:24 Barbara (2)

67:25;185:9 barest (1)

122:3 barriers (3)

16:20,22;112:13 base (1)

100:22 based (58)

18:8;19:21;23:24;24:6; 28:4;48: 18;69:24;71 :21; 77:22;79: 16, 18,20;80:6; 83:5,6,1 0, 16;84:3;85:23; 86:2,6, 18;87:2;88:5, 12, 16,20;89:2;92:24;94: 16; I 02:7; 105: 17; 125:2,8,18, 23; 126: 13,15; 127:21,2 1; 137:7,16; 142:7;146:3,17; 148:1; 152:9;155:11; 160: 1,8,15;162:9; 167: 15; 185:8;192:3,6; 195:15; 203:16

bases (1) 94:21

basic (7) 25: 14;78:21;93:8; 139: 15; 179:24; 196:25; 204:7

basically (5) 69:20;125: 17;140:18; 214:10,21

basing (2) 98:23 ;99:3

basis (18) 1 0:2;15:8;83:3,12,20; 84: 15;87:7;88:8;89: 19; 90:9;99: 14; 106:6; 107:22; 149:22; 150:2; 156:18;159:7, 13

Bates (20) 12:7;57:7,1 0,23;58:3; 144:8,22,24; 145:11; 146:21; 147: 14; 148: 13; 149:3; 150:20,23;151:16; 152: 14,23; 153: 17;163: 17

bear (1) 164:14

bearing (6) 39: 14;40:6,9; 148:4; 158:17;175:14

beat (1) 67:11

(2) anticipated - beat



became (1) 40:25

become (7) 1 05:25;106:9;120: 18; 133:23;216: 13;217:3,23

becomes (4) 48:10, 14;80: 14;200: 17

begin (2) 91 :3;189:16

beginning (1) 23:25

behalf (6) 44: 13;45:20;47:8; 189:20;190:1,11

behav (1) 115:24

behavior (12) 47: 13;48: 1,5, 13, 15,17; 65:5;81 :2;138:1 0,19,21; 140:10

behaviors (5) 127:25; 128: 1;139: 13, 14;200:21

behind (1) 196:16

behind-the-scenes (1) 208:12

beingness (1) 118:22

beings (2) 78:21;118:19

B-E-1-T (1) 177:7

Beit-Hallahmi (3) 177:7,8;178:13

belief (18) 47: 16;48: 12;78:20,24; 86:14, 18;87:24;88:24; 89:19;11 8:12; 123:12,21; 128:3,6;140:8;146: 12; 157: 14;200:21

beliefs (32) 28:1 ;48:4,8;68:21; 83:7,8;118:11;126:25; 127:6,8,9,19,20; 131 :7; 132:13; 133: I ,3,5; 134:7; 137:14; 140:3,23;141 :23; 192: 15,21; 194:2;197:19; 198 :20;204: 1 0;205: 11; 208:19;218:8

believes (2) 132:7; 195:7

beneficial (1) 199:7

benefit (3) 58:4,4; 121:2

benefited (1) 95:5

benefits (3) 50: 17;86:23; 135:8

Benitez (2) 95:3; 148:6

Benjamin (2)

!\lin-U-Script\'ID

177:6; 178 :12 157:15 78:3;142:12 Berg (1) bombshells (1) borrows (1)

182:3 162:13 80:13 best (8) Bonnie (2) both (9)

15:1 ;26: 15;36: 1;40: 15; 37:13;43:18 18:6;57: 1 ;62: 8;86:25; 41 :3; 11 9:4;204: 13;220:3 book (72) 171:6, I 0;172:22;185:11;

best-funded (1) 16:15;20:7,15;51 :12; 214:19 32:4 73:8,16;93:6,1 1,16, 19; bottom (9)

Better (10) 94: 16;95:3;103:25; 12:5;89:6; 115 : 19; 53:5;57:22;58: 16; 108:24; 111 :11,11 ;112:9, 122:6;126:6;136: 12; 112: 14;119:9;133:23; 19;113:9; 114: 10;116:3; 153:23; 157:1 ;213:3 167:5;216: 13,22;217:3 117:7; 118:2,9; 121:4,14, bought (1)

betterment (1) 22; 122:12, 19; 123:6,1 0; 183:18 199:10 125:7;139: 15;154:20; Boy (3)

beyond (10) 156:20;160: 19; 165:23, 35:24;70:20;81: 13 53:16;55: 16;58:2; 23,24;168:5;169: 17, 18, brain (2) 125:22;141 :6; 145: 13; 19,19,20,22,23; 170: 18; 173:13, 13 146:7,9;161: 11;220:21 179:6,12;180: 14;184:4, brainwashing (3)

bias (2) 14; 187:25;188:2;193:5; 178: 19;180:11 ,16 186:20;187:1 196: 18; 197: 12; 198:1 0; breach (1)

biased (1) 203:25;206:13,17; 92:9 187:3 212: 13;217: 13,18; break (10)

big (5) 218: 10,18;219:4,5, 10,12, 10:11;25:6;67:23; 45: 18; 133:1 0; 145: 16; 17 104: 17; 117:17,23; 201:11;219:4 booklet (12) 143: II ,23; 163:8;169: 16

biggest (1) 21:22;116:7,7;195:19; breakdown (1) 151:8 198: 14,22;207:2,3,18; 152:21

bill (2) 208:5;212:19,20 Bridge (10) 64:25;65:4 booklets (4) 37:22;38:2;43 :21;

billed (1) 26:7; 157:23;209: 16; 101: 10,11;1 03:21; 104:6, 66:1 210:18 7,7;194:14

billing (4) books (102) brief (2) 22: 15;64: 15, 18;65: 10 13: 16; 17: 16;19: 13; 39:9;103:14

billions (2) 20: 18,21,22,25;21 :4,6,8, briefly (3) 135:19; 151:3 10,12,19;72:3,7,21,22; 35:22;41 :23;93: 1

Biographies (1) 73:1 ;74: 1 '17' 18,21 ,24; bring (8) 155:13 75:2;77:22;92:25;93:2,5, 15: 15; 17:25; 113:5;

biography (2) 24;94: 19;98:7,8,12, 15; 129:9; 154:4; 186:25; 154:18;156:25 116:16;117:9,24;120:21, 196: 17;197:9

bit (17) 24;121 :1 ,2;124:21; 125:2, bringing (2) 16:4;26:2,5;29: 1; 13,23;126:7;133:5;135:7, 42:5;196:21 59: 17;78:2;86:10; 15; 140: 13; 154: 18; brings (1) 105: 13;124:23;135:7; 156:15; 159:24;160: I ,15, 187:3 140: I; 144:1 0;145:24; 24; 161 :1 ,18,24,25; 162:5, Britain (1) 178:9; 188: 1;199:12; 9; 163:23,25;164: 1; 182:6 214:2 165:12, 13;168:3,6,18; broad (1)

blames (1) 169: 1,24; 170:4,7; 185:15, 161:16 199:3 16; 188:1; 192:5,8, 19; broader (1)

blank (2) 195: 17; 199:22;203:9,15; 107:13 26:17;173:13 205: 19;206:5;207:25,25; broadly (2)

blanket (3) 208: 15,18;210:25; 38:24;48:3 59: 18;80: 11;82:10 211 :21 ,23;212:2,6,8; Broadway (1)

blanking (1) 213:4;214:25,25;216:7; 212:23 20:1 219:11;220:6 broken (2)

blasting (2) booted (1) 144:6;152:18 115:9;177:13 215:15 brought (6)

Blow (1) bored (1) 113:23;117: 15; 120: 16; 199:6 17:10 176:7; 184:23;197:22

blue (1) borrowed (1) Buddhist (1) 156:20 132:11 123:15

body (10) bon-owing (1) bullbaiting (2) 18:20;73: 1 0;96:2,5; 160:12 137:2;194:19 105:3;111:13,22;112:2,4; borrowings (2) Bundestag (1)



184: 11 business (2)

42:2;46:7 Buttnor (8)

35: 18;36:7 ,19,20,24; 37:2,4,9

c calcium (1)

111 :23 California (3)

95: 15;185:9;212:23 call (11)

12:7;22:24;23:2,5; 42:4;55:2;98: 18;1 03:23; 134:21;208:24;209:6

called (43) 17: 1,3,7,18,21,25; 19:22;22:25;32: 17,21 ; 36: 14;41:24;42:18; 60:13;65:8;72:1 0;93:21; 95:9;102:17;103:24; 109: 11;111 :23;113:7; 114:12;116:19,23; 118:17;150:24;152:1; 156: 11 ; 180: 15; 181:22; 182:2;184:4, 13; 187: 10; 193:7,9,15;195:8;198: 18; 206: 17;207: 11

calls (2) 65:2;183:3

calm (1) 215:23

Cal-Mag (1) 111:23

came (15) 24: 15,20;26:8;94:25; 95:1;116:10;147:17,20; 149:4; 163: 16;166:20; 181 :21; 182:24; 184: 19; 187:9

can (124) 8:13,17 ,22;9:3; 10:11 ; 15: I ,9, 11 ,20;16:11 ; 17:23;19:17,18;22:23; 23:20;26: 15;27: 10;28:9; 29: 12,15,15,22;34: 10; 36: 1;39:25;40:7,1 6;42:4; 43: 18,23;47:22;48:9; 51 :22;53: 17;56: 1 ;59: 1; 62: 10;65:6,22;79:1 ,5,10, 14;80:25;81 :7,18;84:7, 24;85: 15;86: 1 ;92: 1 0; 93: 1,5;94:2;99: 12; 100: 10;102:22;103: 13; 105: 18;1 06: 16;108:3,5,6; 109:20;110:9,9;115:11; 118: 10;122:23; 123:9; 124: 13;127:10,14; 129:18,21 ;133: 15; 134:12, 13; 137: 13,15; 141 :2; 142: 13;144:3,7,15,

(3) became - can



21; 145:4,5,18,25;156:3; 158:13, 14,23;162: 1, 19; 163: 10;164:24; 167: 10; 168:11,13;170:4; 174:21; 175:22; 177:24;179: 11; 180:3;194:1 ;196: 18; 200: 12;201 :15;204:16; 206: 1,20;207: 1;209: 19; 211 :22;213:23;216: 16, 18,21 ;219:8;220:4,6

Canada (7) 10: 17,20,21;21 :4;22: 1, 16;108:21

Canadian (2) 10: 18; 100:9

Capacity (10) 102: 12,14,17;1 09:12, 13,16, 17,23; 110: 15; 11 1:7

car (2) 32:15;215: 14

card (I) 191:3

care (I) 171:10

career (1) 219:3

careful (4) 59: 12;77:4; 161 :6; 203: 18

cuefully (3) 56:8,16;210:17

Carolina (1) 183:5

Carr (1) 53:14

C-A-R-R (1} 53: 15

carrot(1) 33:4

carry (1) 215:21

cartoon (1) 119:10

cartoons (3) 119:6,7,8

case (123) 11: 10,25;13:1,6,15,19; 14:6,8;16:9;20:21;21: I ; 22:5,7;23:7,10,13,14; 24:4;25:22;27:24;29: 19; 33:24;34 :6,9, 15;35:11, 25;36:9;37: 1 ,16;39: 14; 40:6,21 ;41 :24;42: 10,25; 43:2, 15,20;44:2,21;45:8, 12,20;46:2,2,3,8,1 0; 47:25;48:7;49: 17;51 :3,8, 17;52:6;62:14;67:9,16; 69: 12,22;71 :4;72:22; 75:3;88: 10; I 00:25; 103:1 ;104:8, 13; I 06:2,11, 13,16,17;107: 14; I 08:9; 111 :5; 124: 12; 130:21,25;

Min-U-Scr ipt®

131 :9;134:9;140:5;141 :9, 44:15,16 21: 19;26:7;27:2;145:3, 12,24;143:2; 144:2; Chaleff(1) 3; 151: 1,7 147: 12;148:4; 157:2,21; 37:14 choice (1) 159:25;161:14;162: 16; challenge (1) 81:24 164:14;166:9,14; 171 :8,8; 149:21 choose (2) 172: 18,20,2 1; 173: 10; challenges (1) 94:1;108:20 174:2,9, 15; 175: 14,21; 149:25 Christianity (I) 176:4,6,7;183:24; 188:22; change (1) 123:14 189: 1; 194:6,12; 199:24; 102:1 C hristmas (1) 201:16, 16,18;204: 13; C hanged (5) 32:14 221:5 30:2 1,21 ;31 :2;95:24; chuckle (1)

cases (I7) 97:23 173:5 11:14;20:24;33:24; changes (1) Church (82) 37:24;38:5,10, 12;47: 19, 89:25 18: 11 ; 19:2;28:5,8; 24;75:24;77:1 ;78:3; Changing (3) 37: 15;42:13;43:25; 86:25; 132:24; 176:3; 73:3;115:2;204:1 52: 19;55:15;59:15; 191:11 ;220:8 chaos (1) 7 1 :22;77:25;78:4;79:9;

cases-that (1) 115:19 82: 12, 14;84: 10,14;89:14; 208:6 chapters (1) 90: 15;99: I 0,18;100:2,7;

Cathy (1) 58:7 I 01: I ,22,24; 102:3;106:9, 37:14 characteristics (5) 20; 107:17;124: 18; 127:1,

cause (13) 113: 19,20; 198:23,24, 22; 128: 11,21;129:13; 22:2;23: 17;38:24; 25 131 :8,14;132:20;133:2,3; 45:24;69:9;84:5,6; I 07:6; characterize ( 4) 134:8; 137:8,15;138:2; 118:23; 129:25 ;155:7; 79: 15;80: I ;82:24; 139:21;140:2,22,25; 156:2;173:7 174:17 141 :1 3,22; 142:8;146:13;

cautious (1) characterized (1) 162:2, I 0;165:20;176: 11; 82:10 176:21 185:5,21; 192: 15,22;

caveat (1) charge (1) 193:7,16;196:6,15; 129:25 144:16 198:11 ,2 1 ;202:2,20;

caveat-that (1) charged (2) 204:3;206: 15,20;208: 17; 102:10 36:21,24 211 :7,20;213:9;214:3,6;

CD-ROM (1) charges (2) 218:2;21 9:2;220:7 24:8 37:2,5 circ.les (1)

ceased (1) charging (1) 78:7 213:24 166:8 citation (1)

Celebrity (1) char itable (31) 156:16 146:22 56: 11;61:10, 12,19,25; cite (1)

Center (2) 79:20;80: 11,25;81 :7 ,18; 180:3 37:22;41 :20 83:9,1 7;85:22;86:6,22, citing (1)

Center-an (1) 22;87:3;88: 12,16,20; 180:22 151:7 89:2;90:7,9, 12;145: 14; citizen (2)

centers (1) 158: 15,24,24,25;159:7,9 10: 18,19 151:25 charity (2) Citizens (1)

central (4) 61:3;146: 17 58:12 83:6;86:7;88:11 ,18 chart (3) city (3)

century (2) 75: 8,1 1;110:8 36:6,11,20 70: 10;207 :7 check (12) Civil (3)

certain (6) 35:4,8;37: 17;40: 14; 8:21 ;35: 11 ;46:8 12: 14;55:22;56:21; 45:24,25;1 18:13,14; claim (8) 133:3;173: 12;219:7 144: 13;172:5;205: 18; 23: 18;78: 13;88:23;

certainly (26) 212: 14 96:24; 109: 18; 111 :21; 11: 15; 14: 14;15:3,2 1; checked (1) 176:13;201:12 17:11;18:20;19:7;34:5; 211 :18 claimed (6) 36: 17;43:19;47:22; Checkout (1) 44:8,11;56: 13;100: 15; 60:17;75:25;92: 18; 72:10 112 :1;176:9 105: 17; 131:21; 145:15; child (4) claiming (4) 157:9;161 :16;176:22; 36:21;40:21 ;41:3, 12 42:7;43:3;88:8;96: 1 186:5; 196:8;203: 13; children (12) claims (29) 208:1;214: 15;218:20 36:3,24;11 4:3 ;180:21; 79:20;82: 13;83:1 0;

cetera (2) 181 :23;182:4,6,8,9,13,14, 85:23;86:7;87:8;88: 13, 124:25;192:1 15 17,18,21 ;96:3,4;97: 1;

chair (2) Chilocco (7) 100:1, 11,22;103:25;



111: 18;131 :23;147: 1; 152:6; 154: 16,17, 19,24; 155:2; 156: 19;183: 10; 216:14

clarification (1) 75:1

clarify (2) 3 1:15;40:23

clarifying (I) 50:9

Cla r k (I) 53:14

classic (2) 120:6;192:11

classroom (1) 201:22

clay (4) 16:23;119: 12;196: 12, 20

clean (1) 68:6

clear (20) 13: 17;37:20;41:1; 49: 16;53: 1 ;73: 10,10; 81 :3;85:7; I 05:3,3; 111: 13,13;134:16,16,20; 142:3; 159: 18; 164:21; 194:9

clearly (2) 47:24;97:9

client (1) 193:15

clips (2) 16:24; 196:24

close (3) 81:4;122:8;206:1 2

closed (1) 26:3

Closely (2) 132:23;220:8

cloud {1) 157:13

coach (1) 193:15

coaster (1) 113:25

codes (2) 138:16,16

coercive (1) 178:19

collapsed (1) 183:18

colleague (1) 178:6

colleagues (1) 178:8

collecting (2) 25:24;26:20

collection (2) 158:7;185:8

collections (2) 27:9;187:25

color (2)

(4) Canada- color



77:9,9 Colorado (4)

172:20;173:2,4,9 comfortable (2)

84:2;106:22 coming (3)

44:9;86: 19; 150:4 command (2)

207:16,20 commander (1)

207:13 commands (2)

18:1;194:15 comment (2)

54:14;104:12 comments (8)

44:6,8;48:25;49:20; 53: 16;55: 17;146:3; 219:20

Commission (2) 58:13,14

committed (1) 183:7

committee (1) 184:12

common (5) 18: 10;123:18; 131: 13; 205:16;211:19

commonly (2) 119:16;123:19

communicate (2) 93: 17;220: 17

Communication (5) 73: 12; 112: 19;197: I ; 199:13;216:16

Communications (4) 193:9; 199: II ;219:22, 23

communicators (2) 216: 13;217:3

communities (1) 95:24

community (5) 11 0:4; 177:16; 179:25; 185:20,23

companies (3) 207:18,19;208:7

company (1) 45:17

compare (2) 170:4;211: I

compared (2) 97:16;98:19

complete (10) 11:24; 12: 17;14:23; 15:9;29:18; 109:9; 120:5, 14; 133:23;138:21

completed (1) 165:11

completely (1) 15:11

complicated (3) 17:5;80: 14;220:19

Min-L"-Script®

computer (2) consequence (2) controversial (1) 14:19;41:9 90:5;135:12 177:16

con (1) consequences (1) controversy (3) 90:5 39:20 124:3; 177: 17;179:25

conceivably (2) Consequently (2) conversation (2) 62:16;132:3 133:10;135:2 214:13,15

concept (6) consider (4) conversations (2) 17:8;1 04:14;178:20; 63:5;67: 18; 128:11; 155:11;167:16 192:5; 196: 16; 198:7 129:12 convey (1)

concepts (18) considered (1) 207:19 19: 15;20:22;72:6,7; 60:8 cook (1) 77:24,24;83:6,15;85: 10, consist (1) 30:8 24;86:8;88: 11 ;113: 11 ; 156:3 copied (1) 115:3; 119:1;126:3; consistent (6) 146:22 141:19;191:25 28:22; 125: 14; 140:7, copies (7)

concern (5) 24; 146:11 ;202: 19 34: 16;35: 1;39:2;40: 12; 41: 16;56:20;95:21; consists {1) 170:6; 172:22,24 151:5;160:5 185:23 cops (1)

concerned (8) constant (2) 36:17 54: 16;60:7;71:9,9; 115:15;156:17 copy (12) 78: 14;125:21;151 :21; constitutional (1) 57:5,6;73 :8;89:20; 154:11 89:5 152:24;173 :6,14,18;

concerning (1) consult (3) 174: 1; 178:24; 179:4; 11:10 21:24;39: 15;40:7 182:4

concerns (3) consultation (1) copyright (5) 100:23;128:8,15 41:13 13: 16;21:20;38: 10,21'

concluded (3) Consultations (1) 24 94: 17;125:24;221: 10 35:14 copyrighted (1)

conclusion (1) consulted (6) 70:16 94:9 13:8;21: 16,18;24:3,5; copyrights (2)

conclusions (3) 46:23 58:10;98:14 141:21;177:20;180: I consulting (7) core (2)

Condition (4) 23:1 9;33: 18,21 ;34:2; 86:8;176:3 115:2,21;200:10; 179:17;185:11,16 corner (1) 204:10 contact (1) 18:3

Conditions (14) 95:7 corporate (2) 73:4;115:3,18;116:2; contacted (8) 28:6;52:17 204: 1,5,5,6,8,9,14,20; 22:7,20,22;47:8;64: 16, corrected (1) 205:3;217: 18 24;182:6,9 49:13

conducted (1) contain (1) correctly (5) 155:9 161:9 17: 15;45: 16;55:23;

conference (1) contained (1) 112:21;119:18 23 :5 13:9 counsel (8)

confidential (2) contains (1) 8: 11;21 :7;40: 15;75: 12; 91:12;92:7 110:14 167:4,6,7, 11

confidentiality (2) contend (2) counselor (2) 63:24;92: 10 101:22;128:22 30:9;31:23

confirm (2) content (7) count (2) 10:24;29:4 87:13,13;95:13; 46:20;47:3

confirming (1) 112:12;131:5,6;196:8 counted (1) 21:13 contents (3) 46:19

confront (1) 114:9; 145: 19; 182:5 counter-intention (1) 217:3 context (12) 134:21

connected (3) 38:21;80:8; 127:7; countersued (1) 28:8;52: 19;71 :16 132: 12,12;136: 19; 37:7

connection (9) 149: 19;154: 14;160: 10; countersuit (1) 20:20;68:22;72: 1 1; 165:19;200:1 ;204: 10 37:8 85: 10;86:5;127: 15; continues (1) country (1) 141: 15;153:2;175:8 43:8 95:22

connections (3) contracted (1) couple (18) 131:4; 157:24;191 :24 66:24 25:25;30:5;33:23;68:7;

consciences (1) contrary (3) 103:3; 134: 17; 135: 14; 127:10 138:4;139:13,14 149: 19; 153: 10;163:20;



168:1 ;174:23;182: 17; 184:8;188:11;193:4; 208:14;209:1 1

cour (1) 44:17

course (112) 13: I 0,20,22;14:1 0, 17, 24; 15:2, 15,17,25; 16:4,8; 17: 10,10,17; 18:8;19: 14, 18,20,21 ,22;21 :20,24; 23:15, 15;24:23;25:2,11; 28:3;44: 18;51 :3,15; 66: 13,16,17;67:5,17; 68:22;70:2;71:21,25; 72: 1,23;73:4,12,16; 78:23;79:4,7,25;80: 12, 12;82:23;83 :3,5;85: 11; 93:6;96:6;98:17,23; 103:22; 112: 10,20; 113:10;114:12,24;116:6; 117:5; 118:3;121 :24; 135:6; 136:22; 137:6; 142:7;154:20;159: 19; 169:5;187:2;191:18; 193:6,6,8, 10;195: 17; 196:5,5; 197:2,2; 198:10, 11,17;201:9,10;203:9,15, 25;204: I ,2,24;206:4, 14, 15,18,21 ,25;208: 15; 209:21;210:9, 12;214:5; 218:18;219:16

courses (20) 42:5;52: 1;87: 13,16; 94:22; 102:7,8;116: 18; 133:9;136: 12; 138: 13; 140: 13;144: 19;194:23; 196:3;200:22;203 :9; 210:25;214:7,9

court (34) 9 :7,24;1 1:14;37:24; 41: 1;43:22;44:21,23,24; 45:1,3,5,21 ;46:9;59:24; 60:4;67: 15;76:6,16,23, 25;85:5,18;107: 14; 128: 18,20;129:9,11; 130: 12; 136:24;139: 19; 147: 19; 168:8;176:2

courtroom (1) 130:6

cover (7) 72:21 ;97:3 ; 122:22,24; 125:6,8;160:8

covered (4) 60: 18;163:6;164:3; 167:9

covers (1) 94:20

create (2) 118:22;151:9

creativity (1) 116:23

creator (2) 118:6;1 19:17

(5) Colorado -creator



credentials (3) 186:10, 13,13

criminals (1) 96:12

Criminon (2) 96:9,10

Crisis (1) 150:25

critic (2) 127:22,24

critical (16) 44:6,8;47:10, 12,21,25; 48:3,8,16,17;69: 12, 15; 128:2; 141: 13;177:19; 187:8

criticism (5) 47: 16; 139:21 ;181:17; 188:21;203:5

.criticisms (8) 179:21; 183:16; 188:25; 189:3; 194:20;200: 19; 20 I :25 ;202 :2

criticize (1) 202:18

criticized ( 4) 183:20,22;184:1; 187:24

criticizing (2) 202:3,17

critics (2) 43:7,9

critics-I (1) 38:5

Critique (1) 180:11

critiques (1) 181:2

Cross (1) 81:10

crucial (5) 14:6; 17:8;48: 14; 180:24;181:20

cult (15) 174:18,21 ;175:2,6,9, 11,19,24;176:3, 7,13; 183:17 ,20,23; 184:5

cults (1) 184:12

curious (2) 12:20;25:16

current (3) 11:1 ;53: 12; 159:10

currently (1) 116:23

custody (3) 36:2,4;43:2

CV(7) 10:23,25;28: 17;29:25; 48: 18; 171 :25;172:2

Cynthia (1) 175:18

l\1in-U-Script@

145: 15;146:15 11 ,12;44:17

D declared (2) dependency (1) 199:16,19 51:5

daily (3) dedicated (1) depends (2)

54: 14; 102: 19; 107:3 207:25 127:2; 155:23

damaged (1) deemed (1) depose (2)

133:9 79:19 162:25;164:24

damaging (1) defendant (1) deposed (8)

202:11 69:12 42:25;43: 14,23;44:22;

dangling (1) defendants (1) 45:22;46:2,9;75:3

33:3 8:5 deposition (33)

date (13) Defendants' (18) 8:4,13, 16, 18,20; I 0:22;

11:1 ,5;45:24;59: 13; 8:2;57:25;72: 15,18; 16:5;23:25;35:1 ;44:20;

64:21,22;65: 16;66:1; 1 03:6;123:1 ;143:19; 59:5;68:4,14;75 :6;77:7;

79:6;91 :4;134:23;172:1 ; 147:3;163:14;169:11; 122: 12;123:4;130:4,11;

207:11 171: 18; 173:22; 191: 19; 149:11; 150:22;159: 19;

dates (2) 196:4,1 0;198:9;203:25; 167:6; 169: 14;170:2;

22:17;168:21 206:13 172: 15;173:6,9;174:1,6;

David (4) Defense (1) 209:9;211: 10;221: 10

100:11,13;177:4;182:3 58:15 depositions (12)

Dawson (5) defer (3) 24:8,12;68:9, 18,20,24;

177:22; 178: 1; 180:8; 53: 19;99: 15; 105:14 110: 17; 148: 16;166: 16;

181:6;187:24 detine (3) 172:17 ,23; 193:20

Dawson's (2) 78:17,18;210:1 dcprogrammcd (2)

180: 15;188:4 defined (2) 176:10,14

day (5) 42:20;119:18 deprogramming (1)

26:4,4;41 :6;69:4; 126:2 definite (1) 183:25

days (6) 137:8 describe (2)

36:18, 19;96:24; 126:18, definition (1) 13:20;72:23

19;156:6 80:1 described (1)

day-to-day (1) definitions (3) 176:17

99:14 78: 19; 192:1 ;205: 10 describes (1)

dead (1) definitive (2) 197:13

67:11 137:22; 159:18 descriptions (1)

deal (5) definitively (1) 204:14

145: 16;200:24;21 7:8, 110:22 designated (1)

14;220:17 degree (2) 9:19

dealing (2) 30:1;200:8 desire (1)

217:7;218:4 degrees (3) 119:1

deals (1) 30: 16;31 :1 7;130:17 desk (1)

117:6 Delgado (5) 18:3

death (2) 69: 12; 188: 19; 189:2,4, Desmond (5)

69:9;122:6 23 67: 19;69:4;74:22;

debate (3) demanded (1) 111:6;148:15

78 :22;1 81:4,7 62:15 Desmond's (1)

debates (1) demo (2) 110: l1

183:22 119:13;121:9 destroy (2)

decades (1) Demonstrate (3) 118:23;134:24

93:14 119: 13,20;121:8 destroyed (1)

decalogue (1) demonstrated (1) 118:24

219:5 151:19 destroying (1)

December (1) demonstrations (1) 151:3

29:11 196:22 destructive (1)

decide (2) denies (1) 151:20

101:21;170:5 43:7 detail (1)

decided (3) Dennis (4) 45:12

44:5;65: 12;130:8 37:23,25;43: 19,20 details (3)

decision (26) dental (1) 37:1 ;91:14;92:7

40: 10;56:8,12,14,15, 46:4 determine (8)

20,22;59:24;60:5,11; Denver (1) 19:7;53: II; 158:22;

78:14,14;80:8, 11, 15, 17, 46:3 159: 13; 168:22; 181:7;

20;81:3,5;82:3;85:8; department (7) 185:19;215:3

87:6;89:18;90:10; 30: 13,15;31 :9;33:10, determining (1)



53:13 detoxification (5)

73:8,17;111 :14;112:6; 157: 14

develop (1) 202:12

developed (5) 42: 19;96:1 ;111:17; 151:10;218:18

Development (4) 188: 19;189:2,4,24

dialogue (1) 146:12

Diana (1) 45:10

Dianetics (6) 18:7;44:3; 149: 15; 156:6;207:24,25

dictionaries (2) 216:9,10

dictionary (3) 17:14;112:16;215:3

died (2) 69:4;171:9

difference (2) 86:16; 195:18

differences (2) 62:13,17

different (26) 13: 13;29:2;31 :5;59:25; 65:5;70:19;78: 19;85:25; 95:11,12;101:18;107:6; 129:6; 134:3; 135:3; 138: 15; 141:8;155: 18; 174:20; 179: 14; 180: 16; 187: 17,22;192:18; 195:16;208:15

difficult (1) 78:12

dimension (3) 121: 19;124:2; 137:9

dimensions (3) 37: 18;111: 18;129:6

dinner (1) 25:6

direct (6) 39: 14;72: II ;78:3; 94:21;142: 12;194: 17

direction (6) 104: 16; 114:7;139:6; 141 :5;159: 16; 195:25

directions (1) 146:25

directive (1) 207:20

directives (1) 194:15

directly (7) 80: 13;94:22,23; 124:25;139: 13;161:10; 200:9

director (1) 185:7

(6) cr edentials- director



disagree (3) 61:15,20;87:4

disagreements (1) 187:17

discipline (3) 213:16,21,25

disclosing (1) 27:20

disclosure (1) 28:21

disconnect (1) 201:2

Discord (1) 184:5

discourage (2) 209:25;210:23

discovery (5) 8:6,9,19; 148: 17; 168:15

discuss (5) 121: 16; 147: 16;188:23; 192: 13;208: 16

discussed (11) 37: 18;43:5,6;50: 12; 58:5;122: 16; 146: 13; 160: 19;161 :20; 164:3; 208:14

discusses (3) 198:14;200:6;217:18

discussing ( 4) 154: 15;161 :6;176:19; 195:24

Discussion (22) 9: 10;23:25;42: 17;50:6; 77:20;99:3,4;147:23; 150:24;152: 16;160: 14; 161: 12;163: 12; 170: 15; 189: 14; 195:1;196: 11; 201 :6;203: 1;209:7, 13; 216:2

discussions (4) 50:1; 146:24;192:25; 201 :17

disparage (2) 113:16;119:7

dispense (2) 145:4,5

dispute (10) 34: 12;36:2;51 :5;62:4; 82: 17;97:3; 111 :8,9; 159:25;185:20

disputes (2) 59: 14,18

disrupted (1) 201: 13

dissemination (1) 207 :3

dissertation (2) 32:13,1 5

dissuaded (2) 194:18,19

distinction (1) 61:4

distractions (1)

Min-D-Script®

194:21 25: 12 151:13 distress (1) doubt (2) drugs (24)

217:9 64:17;1 15:22 96:21; 111:22;1 13:1,2; divide (1) down (22) 131 :23;133:22;135: 11,

127:4 12:4;26:2;40:20;64: 19, 17, 18;136:3; 138:3;140:9, divorce (1) 20; 104: 17;113 :23; 9; 146:24; 148:9; 150:25;

43:2 115:10,13,16, 17;117: 13; 154: 13,22; 157:4; 197:9; doctor (3) 120:9;132:11,14;137:3; 209: 13;210: 1,14,18

49:9,18; 195:3 144:6; 151: 19;152: 18; drugs' (2) doctoral (1) 194:11 ;210:5,25 151:21;209:24

32:19 Downs (5) Dual (1) doctorate (1) 19:13;113:1 0; 198:10; 10:19

31:7 217:7,13 duly (1) doctrines (5) Dr (52) 9:12

126:11; 136: 18; 140: 14; 8:5;9:6,16;28: 19;40:2; during (7) 201:21 ;204:6 46:5;47:4;49:17,20;50:9; 25: 11;30:7;33: 12;75:6;

document (31) 56:24;59: 1 0;63: 17;68:6; 143:23; 169:16;211 :9 22: 18,20;23:22;41: 14; 75:8;79:22;83 : 11 ;87:15, dynamic (20) 57 :2;59:2;75: 14;76: 10, 17,22;93:25;103: 16; 118:3,5,17,17,18,21,25; 11, 14;77:6;81 :1, 1,2,4; 117:23;121 :3;122:20; 119:2,13,15,15,16,20,23; 1 03:17;104:3;1 05:6; 123:5; 130:2;134:6; 120:4,11,13;121:10, 12; 108:21; 110: 1;116: 12; 143:23; 147:22;148: 14; 122:15 144: 13; 153:9, 13,14,22; 157: 1; 169: 16; 170: 19; dynamics (9) 159: 1; 171: 16;173:8; 174:7,15;177:22;178:1; 116:20,20; 119:23; 208:3;218:3 179 :24; 181 :6;182:22; 120: 17; 121 : 11 , 17, 18;

documentation (1) 183: 14; 185 :2;189: 17,22; 160:19;161:9 97:1 190:9; 191: 17;209: 11;

documented (1) 21 1:2,13,17;220:24 E 182:21 draft (8)

documents (64) 7 1:6,11 ,12;89: 13,17, earlier (24) 13:8,18,22,23;14: 1,9; 17;90: 1; 159:3 14:8;28:20;46: 14; 24:2;27:2,9;38:6,7,8; drafting (1) 59:24;60:18,21 ;73: 14; 55:21;68:9;70: 1;73: 18; 62:20 83:22;89: 12, 17;93:1 , 10; 75:23,24;79: 1 0;85 :9; draw (1) 95:18;104:5;1 12: 11; 88:3;101:3,4,13;103 :9; 201:22 120:20; 153: 16;157: 17; 104:21; I 05:3,5,21 ;106:2, drawing (2) 169:22;180: 13,18; 3;108: 15,20;109:5,8,9; 61:4;173:12 188:20;211:3;214:2 110:5, 19,23;141: 18; drawn (1) earliest (3) 142:15, 17,20,22;143: 14, 180: I 38: 16;207:9,25 24,25;144:7;148: 1; drew (2) early (19) 152:1 1 ;155:2,3;157: 19, 94:22,23 38:1 5,1 7;95:8,9,14 ; 22;158: 1,3,7,8,9;160:11; drift (2) 96:23;98:22;116: 11; 164:5;191 :25;210:22,23 192:24,24 126: 17,17, 19;133:8;

dollars (1) drill (5) 134: 15; 147: 15;156:6,13; 135:19 196:12,14; 197:14,20, 207:6,24;219:3

done (33) 25 easier (2) 13: 12; 18:24;33: 18, 19, drink (1) 100:21;199: 12 23;34:3;49:18,21;5 1: 10, 111 :23 East (1) 11,13,20,21;71:14;79:6; drinking (2) 212:23 86: 14,18;99:21 ;130:24; 210:4,6 easy (4) 133: 12; 144:5; 156:5,9; dropped (1) 15:25;19:7;21: 1; 157:9;159:6,11;185: 11, 37:2 117:12 16; 186:6; 188:8;189:8; drove (2) edition (1) 197:17;220:24 26:3;32:16 179:7

door (1) drug (26) editors (1) 43:11 48:20,22;49:4;50: 17' 188:4

dorm (1) 22;51 :4;54 :4;96:5,6; Edmonton (6) 31:22 97:5; 101 :23; 105:24; 10:16;32:1 6;35:11;

dosage (1) 112: 1,3; 123:25; 131:24; 36:6,10;65:21 111:24 133: 10; 135: 13,20; 151:2, Education (4)

doses (1) 10,13,24; 153:4;154:2; 37: 15;53:5;57:22; 95:25 210:23 58:16

double-check (1) drug-free (1) educational (1)



186: 17 EEOC (4)

41: 19;42:9,10;43:21 effect (7)

12: 14; 112:5,6; 11 8:4; 126: 13;128:4;214:25

effective (9) 49:3,3,6;50:21;51: 1; 217:22;219:17;220: 10,13

effectively (1) 220:17

effectiveness (2) 154:2,7

effects (1) 210:4

efficacy (1) 150:10

effort (4) 100: 15; 1 06:8;135:22; 164:6

efforts (1) 119:4

eg (1) 58:8

eight (6) 16: 14,14;27:4;47: 1; 116:20;117:3

eighth (11) 118:5;119: 15, 15, 16,20; 120: 13;121 : II ,12, 16,18; 122:15

EIIU (1) 36:11

either (8) 61:8;91:20;92:24; 115:4;159:13;172:24; 182:8;201:18

Elbert (5) 207:8,17,23;208:1 ,1

element (4) 79: 12;82: 15;99:6; 151:20

else (27) 8:22;11:4;13:3;21:16; 23:2;27:7;28: 14;34: 10; 37 : 19;43:5;51:9,17,18; 72: 10;93: 19;118:15; 121:4,23;123 :7;159:20; 160:2,22,25; 162:4; 165: 16;187:23;221 :3

E-mailed (1) 11:20

E-mails (1) 27:17

embrace (1) 79:7

embraces (1) 119: 18

emotional (1) 217:9

emotions (1) 217:12

emphasis (2)

(7) disagree - emphasis



17:13;136:13 employ (1)

46:4 employed (1)

32:12 employee (1)

45:19 employees (3)

42:7;207:19;208:8 employer (1)

46:5 encompass (1)

123:14 encompassed (1)

143:25 encourage (3)

124: 1; 138:9; 139:3 encouraged (3)

215:2;216:4,9 encouraging (I)

217:23 encyclopedia (1)

215:1 end (7)

12:2;101:6;115:8; 167:5; 179: 14;206:4, 7

enemy(2) 115:22;200:2

energy (1) 113:24

Enforcement (1) 58:14

engage (2) 140: 10;201:14

engaged (3) 139: 12; 151:22;214:5

England (1) 40:21

English (1) 216: 11

enjoy (1) 127:8

enjoying (1) 31:2

enough (10) 25:24;52:20; 140:22; 141:1 0,18;150: 13; 159: 18;180:23;220:22; 221:6

enter (4) 99:22;101 :6;102:11; 156:12

entered (2) 89:14;170:1

Enterprises (1) 41:25

entire (2) 73:25;206: 17

entirely (5) 37:20;48: 13; 111:2; 170:22;173:3

entities ( 6) 58:4,12,20,21 ;59: 14,22

Min-L'-Script®

entitled (3) 116: 19;127: 18;128:3; exchanges (3) 118:2; 149: 14;180: 10 130:25;140:11 ;141 :5; 184:3; 193: 14;194:22

entries (1) 142:11 ;146: 14; 148:17; exclusively (2) 77:3 156: 12; 158: 19;160:25; 152:1,2

environment (2) 171:11; 186:23; 194:23; excuse (3) 199:1;208:13 202:9;204: 18;207:21; 28:25; 131 :25;144:21

envision (1) 220:9 exemption (1) 133:7 events (7) 82:5

equivalent (1) 17:23,24;69:3;113:4,4; exercises (7) 180:19 195:7;214:8 28:4;71 :21;72: 1 ;96: 12;

era (1) eventually (7) 98:23;137:7;142:7 107:15 33:16;36:25;37: 1;95:6; Exhibit (110)

erasers-to (1) 96:3;120: 18; 173:19 8:2;10:22;11:6;12:6, 16:24 everybody (3) 17; 13:9, 19;21: 17;23:21;

Erlich (4) 134: 18;170:10; 189:18 24:2;26:21 ;27:20;28: 15, 37:23;38:1 ;43:19,20 everything's (2) 20,24,25;29:16,21,22;

error (I) 172:6,8 34:3, 12;35:4,8;52:3; 122:3 everywhere (I) 57:25;58:22;59:3;62:4;

especially (5) 25:15 68:1 0;69:21; 70:2;71; 3,8, 31 :8; 156:5; 180:21; evidence (8) 18, 19;72: 13,15,18;77:7' 194:5,13 61: 19;88:7;106: 10,12, 23;92:24;94:20; 103:6, 16;

essays (3) 15;11 1:5;137:22;156:18 104:3,20;105:6,11; 184:20,24;187:25 evidenced (1) 111:10;122:12,21;123:1,

essence (3) 208:18 3; 142:16;143: 19,25; 16: 13;41:13;179: 10 evolved (I) 144:4,6,8,16,24; 145:8, II;

essentially (2) 96:22 146:11,21;147:4,6,11,14; 17:17;134:25 ex (1) 148:5,14;149:3;150: 15,

cstablislt (I) 30:24 20; 152:21,22; 157:12; 187:15 exact (7) 158:8; 159:21 ;163 :7, 14;

established (1) 81 :4;91 :4;94:5,6; 164:4,6,8, 16,18; 166:4; 46:14 132:24; 134:22;20 1:20 168:5;169:11,18, 18, 19,

Estatt; (1) exactly (11) 20,23; 170: 17; 171: 18,20; 42:13 22:8;38: 11 ,13;87:6; 172:2,9,9,16; 173:17,22,

estimate (1) 92:17;117:13;132:22; 24;196:4,11;197:1;198:9; 26:15 136: 14; 160:6;204:2; 203:25;206:13

estimation (1) 205:4 exhibits (9) 96:10 EXAMINATION (5) 103:4; 108:6; 143:24;

et (2) 9 : 14; 17: 18; 188: 17; 144: 15; 169:8,17,22; 124:25;192:1 190:7;211: 15 170:13;191: 19

ethic (1) examined (1) exist (11) 136:9 9:12 109:9; 129:2; 132:1;

ethical (10) example (27) 141: 19' 19' 19; 154: 1; 138:10,15, 19,21 ,24; 14:2,1 0;31: 13;58: 12; 155:3,3,5;205:5 139: 14;140:10;161 :7,8; 60:11 ;65: 13;79:2;80: 1 0; existence (4) 218:5 91: 19; 100:9;108:23; 65:20; 116:20;119: 16;

etltics (24) 109:6;121 :9;123:20; 195:23 63:22;122: 17;135:4,5, 131 :22; 136: 13; 138:23; existing (2) 13,23; 136:5,5,6,8,15, 16, 139:15, 17; 140:9;156:2; 94:21;140:13 20; 138:8,13;192:25; 165: 16;177:22; 196: 18; exists (2) 202:5,7,8,10,14,18; 201 :23 ;210:3;217: 14 14:4;43:7 208: 11;220:16 examples (8) exited (1)

evaluate (1) 126: 1,8,9; 162:5,12; 209:8 154:7 165: 14;166:1 ;21 0:5 expanding (1)

evaluated (1) except (2) 136:11 216:15 8:14;34:14 expect (1)

evaluating (1) exception (2) 152:12 98:17 123:5; 160:18 expectation (1)

even (39) excerpts (2) 105:23 16:23;19: 18;24:7; 108:18;109:4 expel (2) 26: 13;34:24;42: 16;48:7; excess (2) 96:5; 112:3 53:13,13, 15;62:14;66:22; 210:2,6 experience (3) 72:6;85:8;88: 1 0;90:25; excess' (1) 48:20,22; 194:22 91 :3;98:20;101:9; I 09:1; 210:3 experienced (2)



120:5,15 expert (32)

9:20;27:21,24;28:23; 40:19,25;41:2, 10;50: 13; 53:21 ,24;54: 1 ;62:23,25; 82:9;86:2;89:7;97:4,5; 106:6; 123:19;125: 17; 129: 11;130: 17; 141: 12; 174:9; 175:25;176:2; 183:23;217:8;219:12,23

expertise (7) 107:7; 154:7;157:8; 159: 12;186: 14;216: 16; 217:22

experts (1) 40:22

explain (11) 12:6;28:6; 165:18; 194:25; 198: 19;200: 12; 20 I: 17;202:6;204:8; 208: 18;209:25

explanation (I) 201:21

explanations (2) 201:10;207:6

explore (2) 81 :6; 161:22

explosion (1) 152:17

exposed (1) 17:3

express (2) 189:1,3

extensive (1) 151:22

extensively (1) 75:25

extent (5) 29:21;83: 15;104: 10; 122:14;212:9

externally (2) 201 :7;202: 19

extra (1) 24:12

F

facility-is (1) 151:8

fact (12) 20: 16;61: 12;93:21; 102: 13;107: 12; 123:20; 128:2; 135:17;157: 13; 184:9,10,10

FACTNET(1) 38:3

factor (1) 27:14

factors (1) 112:18

facts (1) 186:18

faculty (3)

(8) employ - faculty



31: 10; 185:3,10 fail (1)

201:2 fails (1)

119:23 fair (33)

10:9,1 0;27:23;32:23; 37: 18;43:6,12;47: 14; 52:20;54: 18;66: 12; 79: 15;80:4;83 :2;96: 18; 120:23;124:14;133:24; 139: 16,22; 141: 1,10; 147:21; 150:13,15;165:3; 177: 14; 179:24;187:21; 199: 15;217:24;218:23; 220:22

fair-gamed (2) 43:4;44:9

fairly (15) 18:1 0;52:20;70: 10, 12, 14;95:16; 106:16;110:2; Ill : 19;124: 13;164:4; 175:3; 177:12;204:7; 21 1:19

fairness (1) 82:22

faith (1) 154:24

familiar (7) 72:9;73: 10; I 01: 12; 123: 19; 193:23; 196: 12; 197:16

familiarity (1) 69:25

family (4) 44:5;1 16:23;204: 19; 217:19

far (40) 11 :5,16;12:3;23:20; 27: 10;34:4,13;43: 18,23; 45:6,22;51:11,24;54: 16; 60:6;62:25;71 :8,9;78: 14; 79: 1,5,10,14;80:23; 82: 14;90:25;99:23; 110:2;125:21;129:16,18; 139:6;140: II ; 172:6, 14; 181 :3; 185:4,9;211 :21; 212:7

farther (1) 98:4

fashion (1) 168:11

fast (1) 46:1

fates (1) 116: 14

fatter (1) 152:21

fatty (1) 112:2

favorably (1) 187:12

FBI (1)

1\tin-L'-Script®

91:24 9:23;10:2; 14: 1;15:5; following (1) fearing (1) 19:17 ;26:9;52: 14;56: 16; 136:18

116:21 57: 19;85: 17; 102:2; follows (1) FedEx (2) 121 :21;135:6;156:25; 9:13

26:3,3 162: 1,5,12;165: 13; follow-up (2) fee (7) 175:23;201 :19;207:22 189:13;190:9

52:24;53: I ;54: 19,25; finding (1) footnotes (3) 55:3,3;70:16 158:2 179:8,8,1 4

feel (9) findings (1) Force (3) 50:12, 16;56: 18;120:5, 155: I 7 60: 12;78:25; 180:17 14; 135:9,9, 10;216:22 finds (1) Force' (1)

feels (2) 113:25 180: 12 45:24; 150:23 fine (11) forces (1)

fell (1) 12:2,4; 16:7;57: 13, 14; 78:21 41:13 67:24; 108:5; 122: 11; foresee (3)

fellow (4) 182:17;188: 13;205: I 7 129: 16,19; 159:15 32: 18,20,25;151 :22 finish (2) for-example (1)

fellowships (1) 44:20;87:18 201:17 32:8 finished (4) forget (4)

felt (2) 25:7;32: 13;51 :8;87:20 I 5:4,14;115: 18;134:22 95:5;114:17 firm (1) forgetting (2)

festscbrift (2) 194:9 51:13;117:3 184:20,21 first (26) Forgive (1)

few (14) 9:12;22:7,24;30:22; 144:9 28: 18;36: 18, 19;46:9; 31 :22;35: 13;43:24;59: 1; forgot (1) 52:7;56:18;57: 18;99:4; 64: 16,23,24;66:8;80: 16; 73:3 117: 11;142: 17;143: 17; 85:6;93:8, 16;97:9; forgotten (1) 167:6;209:3;211:17 104: 18; Ill: 1 0,19; 151 :4; 120:21

fiction (2) 164:8; 178:25;181 :19; form (18) 219:4,10 190:10;193:5 8: 14;24: 14;90:3;

field (4) fit (1) 108: 11 ; 133:25;142: 1 ,25; 156:2,12;157:8;177: 1 192:14 160:4; 161: 15; 162: 17;

Fifth (1) fits (5) 165:9;191 :7; 196:21; 117: 1 135:21; 139:1 ; 192:21; 199:17;202:21;203:11;

fighting (1) 194:2; 198:20 206:22,23 207:14 five (3) formal (6)

figure (5) 46:25; 1 I 1 :20;210:5 44:25;45: 1,5;213: 10; 22:22;158: 19,23; fiX (1) 214:3,5 175:22;216:5 194:10 formalities (1)

figured (1) fixed (1) 8: I I 68:20 218:20 formation (1)

figures (1) Flag (1) 151:25 96:23 42:14 formed (1)

file (11) flat (2) 24:6 11 :9,24;12: 17;13:5; 86:12;102:1 former (2) 57:7; 104: I 9;109:9; flew (2) 38:5;214:16 110:11 ,14;148:15;157:20 44:14,19 forms (2)

filed (2) flexibility (1) 49:12;196:22 9:18;88:5 44:18 forth (1)

flies (7) flip (3) 134:13 13: 14;25:25;26: 1,20; 142:24;153:10;193:3 forward (2) 65: 14;87:8; 183:20 Florida (I) 19:23;120:16

final (21) 171:8 foul-ups (1) 31:25;62:7,9, 14, 17; fly (2) 200:9 76:22;80: 17;81 :5;82: 18; 44:20;46:1 found (11) 85:9;89:24;90:2,17;91 :5, focus (4) 14:6,24;38: 16;48:5; 11 ,12,15;92:22;136:9; 29: 13;30:2 I ,22;31 :4 59: 12;60:21 ;95:3; 159:4;184: 15 focused (2) 170:20;204:23 ;205:4;

fmally (3) 17:23;92:1 207:16 132: 10;152: 14; 158: 16 follow (3) Foundation (4)

financial {I) 63:23,25;114:18 58: 19,19;212:22; 166:7 followed (3) 218:20

find (21) 91 :20;129: 14;203:22 foundational (1)



136:9 founder (4)

18:6,11;19:2; 148:6 four (1)

46:25 Fourth (2)

116:25;15 1:18 frame (3)

88:4;98:9; 107:15 FRANKLIN (66)

8: 17;9: 1,5; 15: 15; 39:24;40: 13 ;57:6, 13; 59:6,8;66:3 ;67 :24;73 :25; 74:3,8,13;75: I ,5;84:25; 87: 18;90:3;93:23; 103: 13; I 08:11; 117:9,1 4, 17; 122:23; 133:25; 142:1; 143:9,15;156:22;160:4; 161: 15;162:17; 165:7,9; 168: 13,19,24;169:2,5; 170: 11;188: 13;189:9,12, 16; 190:8,15,18, 19; 191: 13; 195:2;200:3; 203:7,24 ;206:24 ;208 :25; 209:10;211:4,6;215:5,9, 25;221:9

fraud (1) 183:7

free (3) 56: 19;65:3; 109:22

Freedom (3) 58 :20; 1 04:6;203 :21

friends (1) 217:20

front (12) 9:4;45:14;72:21;93:25; 94:20;117: 10;121 :2; 122:22,24;125:6,8; 184:15

frustrated (I) 182:18

fulfill (1) 115: 12

full (2) 10:14;134:19

functional (1) 89:1

Fund (1) 58:15

funding (2) 32:3,6

further (3) 59: 17; 132:2;211: 15

G

gains (1) 120:9

game (5) 37: 18;43:6,12; 139: 16, 22

Gandow (1) 184:22

(9) fail - Gandow



G-A-N-D-0-W (1) 184:22

gaps (1) 98:11

garage (2) 43: 11;215:15

Garcia (5) 207:12,14,16,17,22

gate (1) 103:24

gateway (1) 103:24

gave (4) 173:9;174: 1;207: 13,16

Gee (1) 130:16

Geez (3) 22:8;33:22;42:16

general (13) 18:20;53: 16;69:25; 102:21; 1 03:2;104: 14; 131:19,21; 132:9;133:21; 138:2; 143:4;220:15

genemlities (1) 199:4

generally (14) 99: 12,20; 174:19,24; 175:4;191 :18;193: 13; 194: 1; 198:19;200:12; 202:6;216:12;219:6; 220:18

generated (3) 13:5;153: 10;218:2

gentleman (3) 53: 14;95:2;176:9

gently (1) 198:5

genuinely (1) 136:2

Georgia (59) 8:21 ;9: 17,18;21 :9; 24:24;28:7;29:9;52: 19; 54: 18;55:6;61: 18,24; 63: 12,15;66:16,1 9;67: 18; 69: 15;72:23;83: 13,14, 19, 21 ;84: 16;85:19;86:3; 87:7,23 ;88 :4,8, I 0;92 :3; 99:6,9, 14,17,24,25;100:1 , 25;101 :15;102:20; I 04: 13,22,25; 107:4; 109: 14;110:12,17; 111 :2; 128: 13,23;129: 14; 139:21 ;146:7;150:7,9; 159:13;190:1

Georgia's (6) 28:3;71 :20;87:2;137:6; 142:6;159:7

German (4) 184:11 , 15,17,20

Germany (2) 184:11,23

gets (12) 17:3,10, 11;53:8,9;

1\'lin-U-Script®

115: 16;135: 17;138:1; great (3) 152: 15;185: 15; 188: 1; 53: 13;95:21 ;96: 15 197:22 greater (1)

given (7) 200:8 64: I ;80:2;90: 11; greatly (1) 108: 18;1 09:23; 172:16,17 132:1

gives (4) green (1) 19:23;86:23; 194: 14; 212:12 201 : I 0 grew (1)

giving (2) 134:23 52:6;175:25 grounds (2)

glanced (1) 46:7;88:6 68:13 group (5)

Glendale (1) 36:23;43:3; 180:20; 212:23 181:22;200:19

Glendale's (1) groups (9) 213:1 70:9,11,20;177:2;

global (1) 180: 16; 184: 13;185: 12, 135:1 17;203: 18

glossaries (1) guarantee (1) 211:25 63:23

glossary (3) guess (10) 206:4;215 : 1 ;216:7 22:22;34:1 ;37:20;

goal (3) 46:19;82:9;117:25; 133:21 ;134: 15,24 179:23; 180: 13;187: 15;

God (11) 205:8 90:25; 180:21 ;181:23; guideline (1) 182:2,4,7 ,8,9, 14,15; 202:1 2 15:17 gun (1)

goes (18) 45:15 48: 12;53:2,3,3,4,6,7; 54: 19,20,20;95: I ;115: 13; H 133: 13; 145:1; 151 :6; 196:3; 199:3,8 H-A-L-A-H-H-M-1 (1)

good (18) 177:8 32:3;41 :6,7;72: 19, 19; half (1) 85: 15;98:6; 120:5,14; 25:10 134:12;145:25;173:19, hammered {1) 19;180:23;181 :2;200:2; 41:6 220:15,16 hand (3)

goodness (2) 173 :8;194: 12;206:8 117:8;166:6 handicapped (1)

Gordon (7) 30:9 185:2,3,4 ,23; 186:13, handle (3) 20,24 42:20;110:9;201 :1

government (8) handled (2) 59: 11 ,22;60:2,3,7; 132:8;191:10 82:25;89:4; 184:15 handles (1)

governments (1) 191:9 20:5 Handling (1)

grab (1) 200:5 103:13 happen (1)

gradient (2) 33:25 17:3,6 happened (12)

graduate (8) 32:5;44: 11 ;45: 1,20; 30:11 ;31:6;32:3,24; 69:5;76:23;80:22; 44: 15,16; 178:8;182:20 104: 12;176:4;207: 14;

graduated (1) 208:6;215:20 122:5 happens (3)

graduates (1) 53:9;91:25; 114:19 99:21 Happiness (27)

Graeme (1) 20:2,7;21 :23;58: 18; 37:14 80: 10,13;114:20,24;

116:4,5,7,9;138: 14,23; 139:4;206: 14,18,18; 207:2;209:22;210:9, 12; 212: 18,22;218: I, 18,20

happy (2) 142:10;180:4

harassed (1) 91:20

harassment (1) 37:6

harassments (1) 43:8

bard (3) 105:13; 160:7;207:21

hardback (1) 116:8

harm (12) 66:21,21; 127:21; 128:9;129: 1,4,17;130: 19, 22,24; 131 :3; 141:17

harmful (17) 48:11,15, 17;66: 18; 67: 1,8,18; 127: 13,25; 128:1,4,11,21;129:13,22; 209:24;210:1

harmfully (1) 154:22

harming (1) 127:16

Harris (5) 23: 1,7;65:8;166:25; 170:19

head (6) 16:3;42:4,4;48: 12; 84:7;110:17

heading (1) 118:21

health (1) 154:22

healthful (2) 49:23,24

hear (3) 165:2; 199: 12;221:5

beard (5) 70:6;100: 14; 123:23; 183: 12; 190:10

bearing (2) 86:13;140:6

hears (1) 202:3

held (1) 134:19

Helena (2) 189:7,25

help (13) 27:7;45: 13;56: 19; 102:1 ;110:9;131 :19; 133:22; 134: 18;140:9; 148:9;216: 13,21 ;217:2

helped (2) 32: 11;112:3

helpful (2) 67:1 ,8


helping (6) 93: 16; 112: 14;132: 15; 154: 12;201: 18;219: 18

helps (5) 31: 15; 136:3; 151: 14; 194:21;217:14

helpspeople (1) 104:6

Hence (4) 11 1:22;133:17;136:15; 202:15

here-is (1) 179:15

here's (1) 151:13

herself (1) 113:25

hesitancy (2) 87:22;168:16

hesitant (3) 86:12,17;110:21

hesitate ( 4) 45:23;80:21 ;85: 13; 139:5

hesitating (1) 175:13

higher (3) 123:21,22;161 :4

him- (1) 113:25

hindering (1) 131:21

Hindi (1) 30:24

hindrances (1) 134:18

Hinduism (1) 30:23

hire (1) 65:12

hired (6) 45:3,4,6;67:20;130:23; 137:10

hiring (1) 110:1

historians (1) 97:7

historical (3) 99:1;164:12,13

History (13) 30:22;76:22;94:24; 95: 19;147: 16,18,19,22, 25; 151 :4,9; 185:5,6

Hmm(1) 12:1

bold (2) 127:10;198:5

holidays (1) 26:5

Holy (1) 215:18

home (2) 24:25; 158:2


(10) G-A-N-D-0-W- home


Desmond, et at. v. Narconon, et a t.

honest (2) 114:21,22

honor (4) 20:5;184:21,22,24

hope (3) 135:4; 139:5;208:5

hoping (1) 173:6

horse (1) 67: 12

hospital (1) 42:3

hour (3) 25:10;166:10,11

hours (10) 25:24;26: I , I 0;27: I ,3,4, 11 ;46:9; Ill :20; 166:22

housing (5) 54:8,10, 11 ;188:21,23

Hubbard (73) 18:5,6,9,1 1;19:1,9,24; 20:3,8;38: 18,19;42: 19; 52:22;79:8;93:3;94:14, 17;96: 1,8;111: 12, 17; 1 12:24;11 4:15,17; 116:11; 124: 17,24;125:3, 9, 19,23;126: 19; 131:13; 132: 18, 19; 133:7; 134: 15; 135:5; 138:9, 11,18;140:7, 25; 141 : 16;151: 18; 154: 18;155:8, 13,17,20; 156: 16;160:2,9, 16; 172: 11;197:8;199:20,25; 201 :20;203:16, 17, 19,22; 207:8,8,23,23;208: 1,2,2; 218: 19,22;219:1

Hubbard's (27) 17:22,22;55:3;79:16, 19;80:6;84:4;95:20; 96:21; 111:21 ;125: 14; 126:7,10,14;133:17; 134:23;137: 17;138:20; 140:8; 150:5; 165: 19; 202:24;203 :2;204: 13; 205:9;207:17;208:13

Human (2) 58: 13;176:20

humanities (1) 31:1 1

humankind (1) 116:25

hundreds (2) 155: 14, 14

hurting (1) 202:1 I

hygienist (1) 46:4

Hynes (15) 169:13 ;170:1;188:11 , 18;189:23,23;208:22; 209:2,4,8;215:8, 11 , 14,19, 21

hyphen (1)

Min-D-Script®

177:7 19:25;20:4;57:20; individual (7) hypotheses (1) 114: 18;122:9;128:17; 48:13;119:22;136:16;

156:9 158:16;195: 10,12 144:7;20 I :20;204: 17; impossible (1) 207: 15

I 94:8 indulge (1) impressed (2) 122: 10

1-20 (1) 95:4;1 19:10 infer (1) 41:19 impression (2) 81:3

idea (3) 123: 13; 186:23 infinity (5) 76:22;90:22;170: 19 improve (2) 117:2,4;119:16,18;

Ideas (3) 110:9;219:13 122:5 118:25;196: 17,21 improvement (5) influences (1)

identical (2) 109: 19;11 2: I 0;196:5; 113:14 133:4;220:9 219: 12,16 influencing (1)

identification (11) inadvertently (1) 144:19 8: 1;57:24;72:14; I 03:5; 148:21 information (8) 122:25; 143: 18;163: 13; inappropriate (1) 12:25; 17:4,5;55:7; 169:10,21; 171 :17;173:21 182:19 64:3,12;92:21; 180:24

identified (15) inartfu1 (1) infringement (1) 14:5;28:23;47:20; 10:5 38:22 49: 12;68:10;80:24; Inc (2) inherited (1) 94:20;118:2;131 :12; 37: 15;72:24 183: 19 133:7;150: J 7; 160:20; incidents (1) initial (1 0) 172:4,16;179:15 44:10 11: 11;12:24,24;16:8;

identifies (3) include (5) 49: 12;55:22;109:24; 109: 18; 198:22;199:6 26:24;27: 12;46:22; 134: 13,15;184:23

identify (15) 50:2;164:15 initialed (1) 110:8; 11 5:4;120: 16; included (10) 74: 18 121:5,13,23;123:8; 82: 11 ; 124:24;145:20; initially (2) 131: 19;137:5;138: 15; 149:3;151: 16;152: 15,17; 36:21; 182:2 143:7,25;144:4; 161: 18; 182:12;210:8,10 inkling (1) 185:22 includes (2) 175:7

identifying (2) 118:21;193:12 in-prison (1) 131:4; 132:7 including (4) 96:17

identity (1) 111 :25;121: 11;169:22; inside (1) 118:20 186:8 203: 1

l'd've (1) income (1) insights (1) 30:25 185:14 53:19

ignore (1) incomplete (2) insistent (1) 29:23 108:16;109:8 43:7

ignoring (1) incorporate (2) inspiration (1) 112:15 126:7;132:1 8 18:7

illnesses (2) Incorporated (4) instance (2) 200:6,8 58: 17;124:18,21; 43:24;21 0:20

illustrate (1) 132:20 instances (1) 140:23 increases (1) 14 :5

illustrations (1) 115: 16 Institute (3) 119:9 increasing (1) 41 :25; 185:7; 186:3

image (1) 111:24 instructed (1) 216:21 indeed (3) 41:3

images (2) 106:5; 136: I ;214: 16 instructions (1) 131:24;132:1 index (1) 24:10

immediately (1) 206:4 instructor (2) 40:25 indexes (2) 33:1;45:15

immortality (1) 205:24;206:3 Integrated (1) 122:5 Indiana (1) 36: 10

impact (1) 183:1 5 Integrity (7) 56:22 indicate (3) 19:22;114:1 1,13,23;

implications (1) 52:8;64: 15;94:3 11 8:3;136:22;220:2 141 :6 indicated (2) intelligence (3)

importance (1) 52: II ; 120: I 36:9,10,13 135:2 indication (l) intend (12)

important (9) I79:9 28: 16;49:25;62:2;



69: 19;85:21 ;99: 11; 126:24;128:25;129:24; 139:23;141:17,23

intended (2) 106:19,21

intent (1) 106:4

intention (10) 47: 17;49:5,19;67:20; 76:9,19; 129: 17; 154:14; 194:6,9

intentional (1) 34:5

intentions (1) 29:14

interact (1) 63:12

interaction (2) 44:4;55:5

interactions ( 4) 29:3,7;55: 13;63: 14

interacts (2) 63:4,8

interest (3) 23: 16;127:18;208:4

interested (2) 151:18;152:4

interesting ( 4) 89:5;99:1; 128:7; 158:15

interests (3) 41:3,12;183:19

interference (1) 36:22

interject (1) 136:4

Internal (5) 59: 15;60: 1,13;84:11; 202:10

internally (1) 202:19

International (32) 9: 17;28:7;46: 15;52: 18; 53:4,12;55:6,13, 18,20; 56:4,9,25;58:18;61: 1,25; 63:2,4,8, 12, 15;69: 16; 80: 1 0;92:5; 1 00:25; 145:23; I46:7;159: 14; 190:2,5,11 ;212:23

International's (4) 28:6;29:11;52:17; 159:9

Internet (8) 19:7;21: 13;25:12,17; 38:7;39: 19;40: 17;42: I I

interpersonal ( l) 216:19

interpretation (2) 194:15;214:12

interpretations (1) 186:25

interrupt (2) 208:22;215:5

(11) honest- interrupt



interrupted (1) 19:11

interrupting (1) 32: 14

intervention (2) 127:20,21

interventions (1) 182:19

interviewed (1) 214:8

into (53) 17:25; 18: 16;30:25; 31 :4;32:5;33:9,11 ;42:2,2, 6;52:24;53:4,8,10;66:20; 67: 15;89: 14;93:8;96:3; 10 1:5,6;102:23;1 03:23; 106:8;107:2;113:6; 114:8; 115:13, 16, 17; 124:18,21 ,25; 132:20; 135: 13,21,23;138: 1; 139: 1;144:6;161:6; 166:5;185: 12;192: 14,21, 24; 194:2,6; 195:8;197:23; 198:20;205:11;208:13

introduce (3) 106:11 ,13,16

Introspection (1) 42:18

investigating (1) 36:13

investigation (1) 75:22

involve (8) 46: I 5;95: 10;117:4; 130: 19;138: 13;196:22; 197:25;201:18

involved (10) 32:6;36:3;62:22;75: 18, 20,2 1 ;95:10, 11 ;131 :23; 198:4

involvement (1) 131:24

involves (6) 17:2;93:6;111: 18,20; 131 :17;204:1 7

involving (13) 16:22;23:19;34:11; 36:21 ;37:5,6;41 :24; 50: 15;75:9;80:3;82:4; 129:5;212:20

IQ (1) 109:25

Ireland (1) 44:2

irrelevant (1) 108:7

IRS (53) 55:22,25;56:8,12, 14, 15,20,22;57: 1 ;59:7,23, 25;60: 11 ;62:3,7,8,15; 78:13,14;79:19,21 ;80:7, 11,15,17,20;81:3;82:3; 83:1 0,17,18;84:2,14;

Min-U-Script®

86: 14,I8;87:2,5,25;88:6; Journal (8) Kentucky (1) 89:8,14;90: 14,20;9I :8, 62:1 1 ;89:20;90: I ; 172:21 I9;92: II; I09: I; I45: I2, 156:13;177: 10;181:11 ; kidnapped (2) 15;146: 13, 15;158: 12; 187:10,24 176:10,14 171:7 journals (2) kids (2)

IRS's (2) 156:13;186:5 36:23;114:6 81:24;85:8 Judaism (1) kill (1)

Israeli (1) 123:14 20:4 177:6 judg (1) Killam (2)

issue (19) 105:15 32:20;33:10 35:23;39:11;40:5; judge (1) kind (23) 41 :23;48: 1 0;131 :3; 41:3 61 :7;71: 13;91 :24; 13 7:20; 139: 16; 150:21 ; judgment (2) 98: 18; 107:6; 114:24; 151:I1;152:8;154:16,23; 186:18;188:4 127:10, 19; 129:25; 157:7; 158: 15;188:23; jumble (1) 136:25; 141 :6; 152:7; 201:11 ;214:24;217:8 100:21 155:8,9, 15; 156: 15; 157:9;

issues (38) jump (1) 182:11 ;183: 12,21; 42:21 ;43:6;54:10; 144:14 201:21 ;203:5,5 66:20,22;92:9;97:4; June (1) kinds (5) 120: 16;122:7; 128:8,25; 58:6 43:8;51: 1; 135:20; 129: 1,4,5,17;130: 19,22, jungles (1) 163:21 ;194:22 24; 131 :20; 132:7; 133: I 0; 207: 15 Kisser {1) 137: 10; 141 : 17; 145:22; jury (4) 175:19 147: I; 149:4; 154:10, 15; 85: 19;86: 1; 141:20,20 kit (1) 159: 17;161 :6, 7,10; Justice (1) 121:9 174:22;181 :20;187:22; 58:15 knew (6) 213:18;218:5 ;220:4 20:23;25: 14;175: 18;

item (1) K 181: 18;207:23 ;208: 1 184:19 knocks (1)

items (3) keep (13) 135:14 145:20;163: 16; 196:23 34:16;64:18; 136:9,10; knowing (2)

items-paper (1) 169: I ,24; 177: 12; 180:5; 19:19;162: 19 16:24 202:8,1 0;209:5,6;213: 18 knowledge (19)

lzaak (1) keeping (1) 18: 10,21 ;62:21 ;75:16, 32:19 156:8 21 ;76:7;89: II ,12;90: 16;

keeps (1) 100:6; 123: I 8;125: 14; J 115:16 147:22,25; 175:8;202:4,

Ken (7) 13,15;214:10 James (8) 35: 17;36:5,6,9;37:7,8; knowledgeable (2)

181 : 16,18,20;182:9, 10, 43:17 92:19,20 12,1 7;186:9 Kendrick (2) known (4)

January (1) 191:1,1 16: 17; 18: 15,18;92:21 32:17 Kent (40) knows (3)

Jason (2) 8:5;9:6,11, 16;10:16; 16:21;202:14;219:7 176:8; 183:23 28: 19;40:2;47:4;50:9; Kobrin (12)

Jeff (8) 56:24;59: 1 0;63: 17;68 :6; 190: 1,2,5,13,17,17,18, 23 : 1,7;65:8;166:24; 75:8;83 : 11 ;87: 15,17 ,22; 20;191 :4;211 :3,5,9 170:1 9,21 ;171 :11 ;189:21 93:25;103: 16; 11 7:23 ; Korbin (3)

job (6) 121 :3;123:5;130:2; 190:10,12, 14 31 :24,25;33: 15, 15; 134:6; 143:23;147:22; Kostelnyconcerning (1) 115:12;204:1 8 157: 1; 169: 16;170: 19; 45:10

job-1 (1) 178: 12;179:24;189: 17; 33:2 190:9;191:17;209: 11; L

jobs (2) 211 :2,13,17;220:24 30:8;32:22 K-E-N-T (1) labeled (1)

Joe (1) 10:16 115:20 199:6 Kent-0737 (1) lack (1)

Johnston (2) 12:9 119:9 43:25;44:2 Kent-0907 (1) laid (4)

Johnston's (1) 12:9 138: 18;139: 15;203:23; 45:4 Kent's (4) 205:3

join (2) 79:22;122:20;148: 14; language (3) 44:4;101:21 180: 11 40:23;71:10;216:11

Q&A Reporting Services, Inc. J [email protected]


laptops (1) 4I: 8

large (2) 26:22;152:25

largely (2) 88:2,12

larger (14) 53:8; 108:20;109:4; 132:11; 135:21; 136: 19; 137: 10;138: 1; 139:1; 149:5,7,9, 12; 194:12

Las (1) 45:15

last (20) II :3;24:25;25: 1;45:23; 66: 13;74:20;81: 1;84:21; 89:17; I 06:7,18; I I7:24; 118: 1; 168:4;177:7; 183: 12;184: 19; 191:20; 211:2;212:2

Late (5) 90:25;91:1 ; 11 2:24; 116:10;181:19

later (15) 16:4 ;36: 19,1 9,20;41 :9; 96:9;97:22;1 03:25;105: I, 24;1 15: 12;194:22; 195: 14;219:3,9

launched (1) 44:11

law (3) 39: 18;58: 14; 191:12

Lawrence (1) 38:3

lawsuit (5) 9: 18,20;44: 12;128:24; 129:10

lawsuits (5) 75:9,17;76:3,8,21

lawyer (6) 39:6;53:21 ;90:14, 15; 130:8; 162:23

lawyers (8) 13 :1 ;24 : 16;27:13;65:3, 6;71 :4; 164:23;170:20

lay (2) 37:5;204:20

lead (1) 11 4:7

leader (2) 53: 12;182:3

learn (5) 16:20;1 12:13;168: 1; 219:13,18

learned (1) 206:10

learning (1 1) 16: 19,20,22;17:2,4; 11 2:9,13, 13;196:5; 219: 12,16

least (18) 14: 12; 17: 19;22:21; 27:3,6;59:20;64:24;70:9;

(12) interrupted - least



95: 1; 124:19; 173:1; 180: 18; 185: I ;186: 19; 194: 16; 198:22;209: 12; 216:7

leave (7) 68: 1; 10I :6; 130:4; 133: 13; 140: I4; 146: 19; 161:12

led (1) 151:25

left (4) 33: 10;34:5;36:22;43:3

legal {14) 23:19;34:2,3,11 , 14; 35:4,14;46:24;47: 11 ; 53:21;78:12;80:9; 178:21 ;211 :8

legitimate (1) 178:20

length (1) 53: 11

less (5) 50:21 ,25 ;1 05:21; 112:22;142:12

lesser (1) 200:8

lesson (1) 192:21

letter (9) 27:20,22;71:4,7; 182: 12, 13, 14,23;20 I :20

letters (1) 182:23

level (5) 17:5;38:8;56:22; 115:10;204:17

levels (7) 115: 13;116:20; 119:25; 138: 12; 139:7,1 1,12

level's (1) 116:22

Lewis (11) 181:16,17,1 8,20; 182:9, 10,12,17,22,24;183:7

Lewis's (1) 186:10

library (1) 95:3

license (1) 9 1:23

licensed (1) 54:5

licensing (6) 53 :25;54:3, 19,24;55:2; 70:15

Life (20) 19: 13;73:4,17;1 04:1; 109: 19;113 : 10, 15; 115: 19;1 18: 19; l I 9:2,3,5; 131 :20; 151 :7;198:1 0; 204:1 ;213: 17;217:3,10, 14

life' s (2)

Min-L-Script®

217:7;220:17 111: 19;127:13, 16;128:4; lowball (1) light (2) 149:6;168:25;1 83:21; 26:25

99:2;134:2 184:7; 192:23,24;207:5 lower (2) like-flip (1) longer (3) 115:17,17

153:21 26:3 ;41:6; 176:5 Lowery (1) limit (3) look (37) 46:5

69:2I; I27:20; 13 1:4 13:25; 15:25; I6:I6; low-key (1) limited (3) 18:2,2 ;20:21;22: 17; 177:13

52: 12;96: 13 ;133:3 27:22;28:20;43: 16;56:7, low-level (1) line (5) 15;57:2;73: 1,16;74: 17; 102:7

89:6; 126:6; 136:12; 84:1;87:5;95:20; 112: 16; LRH (1) 157:1 ;213:3 116:5; 121 :25;129:5; 151:10

lines (3) 130:23; 136:23;143:24; Lustful (1) 106: 14; I 07: 19;161: l9 144:22; 158: 18;163:9; 182:2

Lisa (3) 168:21 ; 197:4, 14,15; 42: 13;43:22;171:8 207:21 ;215:3;216:4,9 M

list (12) looked (32) 14:23; 15: 11 ; 16:2;34:6; 13:10;14:7,1I ;2I:6,2 1; MA(2) 41: 17;56:25;71 :14,15; 22:2;24:23;25:1;30:8; 30:22;31:5 76:21;77: 1;171 :21;204:9 53: 14;66: 13;72:2,4,7 ; magazine (2)

listed (5) 73:2,9;74:9, 15,17,21; I09:6;146:22 11 :3;34:2, 14; 113:19; 75:25;77:22;82:3;90:17; magnesium (1) 172:6 92:22;98: 1,6,1 2;110:20; 111:23

lists (2) 148: 16; 187:11 ;211:25 major (5) 121: 11 ;148:15 looking (21) 29: 13;72:6;82: I2;

literally (1) 17: 13;21 : 12;39:9;59:2 ; 151:5; 192:5 206:6 60:20;79: 1 ;92:24;98: 17; majority (5)

literature (1) 107:7; 111 :3; 120:2; 28:2;71:20; 137:5; 25: I6 122:20;158:21; 159:21; 142:6;162:7

litigation (3) I79:7, 13;191 :23,24; makes (6) 38:22,24;170:5 193: 19;205:24;212:4 85 : 12; 135:19; 151 :3 ;

little (12) looks (30) 165:23;178:1 1;203:13 16:4;28:9;86: 1 0; 11:13,15;12:2,2,4,19; making (4) 107: 13; 140:1; 143: 10; 29:25;30:4, 16;49: 13; 49:5, 19;131: 18; 194:20 145:24;159: 16;175:6; 56:8;57: 11;77:8,8,10; man (2) 179:23;201 :4;203:8 79:6;1 05:13,14,15,17, 18; 96:19;151:22

live (2) 114: 1; 118:9; 148:5; management (5) 10:14,I6 149: 15; 153:9,14, 16,21; 42:1 ,2,5;45: 14;46:6

lives (3) 212:19 mankind (1) 132:8;151 :3;2 12: 10 Lorne (6) 116:24

Living (4) 177:22; 178:1 ; 180:8,15, Mann (1) 53:5;57:22;58: 16; 22; 188:4 173:11 190:24 Los (1) manner (2)

load (1) 191:16 177:19;194:9 44:18 lot (28) many (17)

local (1) 18: 19;32:22;36:15; 18:13; 19:17;42:6;78:3; 36:8 38: 15,24;39: 18;40: 16; 86:8; 1 13:6; 126:1;

locate (3) 53: 17;78:22;107:22; 132:24;155:7; 175: 15; 115:24;116:1;214:1 126:16, 17; 128:6,8;156:6; 177:2; 178: 12; 192:7;

located (2) 157:24; 161:7 ,17;162: 19; 207:18,18;211 :12;213:23 103:9;191:14 167:9;184: 1 0; 185: 11,16; Marburg(2)

location (3) 194: 14;195:22;200: 15; 177:10;181:11 31: 16; 197:22;213:2 214:15,1 8 marching (1)

1ocational (2) lots (1) 104:1 17:24;163:19 70:14 Marietta (1)

locationals (2) loud (1) 208:23 17:22;113:7 194:9 mark (14)

London (2) Louis (1) 57:16;72:12; 103 :3; 40:21 ;43:20 37:13 I I 0:7;122: 12,19; 143: 14;

long (22) Love (2) 151: 11;1 64:6;1 68:6,9; 16:6;22:3;23: 16;24:21; 100:11,13 169:7; 171: 15;173: 16 25:4;31 :23;36: 1 ;38:23; low (1) marked (30) 44: 13; 108:2; 110:20; 115:15 8: 1;10:22;12:7;27: 19;



57:24;59:2;62:3 ;72: 14, 17;77:7; 103:5; 104: 19; II 0:6,6;119:25; 122:25; I23 :3; 143: 18; I52: 13; I58:7; I63:9,13; I68:4; 169: 10, I7,22;170: 18; 17I :17 ,20;173:2I

markets (1) 135:3

marks (2) 58:10;122:4

married (1) 114:1

Marschalk (1) 68:3

Mary (6) 24:9;44:2;45:3; 110:18, 18;111:3

Maryland (1) 30:2

mass (5) I6:25,25,25;I96: 17,21

master's (3) 30: 16,18,20

material (14) 13: 13,22;24:6;25:2; 26:8,23;73: 1 0;87: 14; Ill :4;201: 14;206:5,25; 214:18,20

materials (81) 11:9,25;12:17;13:5,11 , 20;14: 17,24;16:4,17; 18:8;24:24;25:21,25; 26:2,21 ;28:3;52:21 ,23; 55:3;65:13,17;67:6,17; 68:22;70:3,8,17;71:21, 25;78:24;79:6,25;80:5; 83 : 13,24;84:1;94:6; 97:22,24;98: I ,2,5, 17 ,18, 21,23;99:2,8;104: 19, 19; 121 :3,24;123:7; 124:22; 125: 18; 131:13, 15; 132: 17;133:21 ;137:6,16; 140:6, 7,24;142:7; 148: 15; 150:4; 176:1; 191: 18,20; 192:3;195: 16;205: 1,7,14; 209:12;210: 15;214: 11' 12;219:16

matter (6) 12: 18;24: 11 ;46:24; 64: 16;68:23;76: 14

matter-drugs-is (1) 15 1:5

matters (9) 34:1 1,14;35:5;43:14; 46: 11,19;47:11 ;124 :20; 2 11:8

may (74) 8:7; 15: 14;20: 16;29:21; 38:7;49:7,17,17,20,20; 60: 17;63: 12;68: 17,24; 69:3;74 :6,6;85:2;88 : 15, 16, I 7,17;92:20;98: 11;

(13) leave - may



99:2;1 04:10,10, 12; 105:18;109:9;111:2; 115: 12,20; 116:21; 117:3; 120:8,16; 121:6,16; 127: 17; 130:21 ,21; 131 :20;135:8,9, 1 0;136:2; 140:1 ;141 :7;143: 16; 148: 1,16,17; 154: 1,17; 163:20,20;167:6, 11; 168: I ;170:17;172:1; 173:4;175:4;179:6; 189:8; 197:3;199:16; 20 1:4;202: 18;204:3; 214:22;218: 17;220:8

Maybe (17) 29: 15;35: 12;41 :6;46: 1; 56:1;59:1;77:11;86:10; 92: 1;109:3;112:24; 113:1 ;144:7; 147: 18; 168:20;176:4;214: 12

McMaster (6) 31 :8,9;32:2,3,7;33:9

McMaster's (1) 31:1 1

McPherson (3) 42: 13;43:22;171 :8

MD(2) 49:12,13

mean (52) 12:4,20;23 : 15;33:22; 39:12;70:8;74:8;81:10, 25;89:2;90:10;91:3; 92: 18;95:20; 102:1; 119:7;123:15;129:1,21; 130:9; 131: 16;134: 11; 141 :1; 147:20;149: 12; 154:6;155: 14,24; 159: 16; 160:7,1 0; 161 :23,24; 165: 15; 166: 19;175:4,21; 186:4; 187:21 ;188: 12; 199:25;203: 14;204:7,10; 205:6;207:4;209: 1; 215:5;216: 15,24;217:21; 220:19

meaning (2) 202:17;215:4

meanings (1) 174:21

means (5) 138:22;165: 19;194: 11; 199:24;202:7

meant (3) 134: 17;209:24;210:2

measure (1) 157:10

Medical (12) 41: 19;49:9,11,18; 66:22;1 12:5;129:7; 130: 19; 147:1 ,1; 149: 17; 154:10

medicine (3) 50:15;150:11,11

meet (1)

Min-D-Script@

24:21 17 99:5;117:12;167:6;168:2 meeting (6) might (52) mirror (I)

36:14, 15, 16,18;166:24; 8:16;9:24; 15:21 ,22; 198:23 208:23 16:21; 18:21 ,22;51: 16; misrepresenting (1)

meetings (1) 52:12;54:5,8,21 ;56: 18; 187:13 213:11 61 :6;66:23;68:12;77:25; miss (1)

Melton (6) 78:8;84: 13;97:7;98: 19; 122:8 185:2,3,4,23; 186:20,24 101: 19; 102:2;113:24; missing (4)

Melton's (1) 116:10;117:11;118:11, 20:9,15;73: 11 ;108:16 186:13 12; 122:8; 128:2; 130:1 '15; misspoke (1)

member (2) 132:21 ,25; 134:9; 138:4; 190:6 185:4,10 144: 1;152: I2,25;I 54: I 1; misspoken (1)

members (13) I 58: I 1; 159: 14;162:5,13; 218:17 44:5;106:9;126:25; 163: 17;167:24;182:25; mistaken (10) 137: 14;196:6, 15;197:2; 184:25; 199:25;201 :22; 17:17;36:3;43: 1;45:2; 198:11 ;201 :7;204:2; 204:15;216:8 98: 15; 117:5;152: 19; 206: 15,20;214: 16 migrated (I) 195:20; 197:5; 198:14

members' (1) 96:3 mistakes (1) 202:2 military (1) 15:21

membersScientology (1) 207:12 mistreating (1) 28:1 MILLER(99) 151:2

members-were (1) 8:4,24;9:3,6,7,15,16; misunderstanding (1) 38:6 15:18;40: 1;50:8;57:4,9, 74:11

memory (4) 16;58:25;59:9;66:6; misunderstood (7) 15: 1,3;26:20; 102:13 67:22,25;68:5;72: 12,1 6; 17:7 ,8,13,14;20 1:11,

mental (2) 73:20;74:2,6,10,15, 16; 19;214:24 131:24;132:1 75:4,7;77:21 ;85:2,16; mixed (2)

mention (13) 87: 19;90:8;94: 12;1 03:3, 19:13;152:20 60:11;79:3;83:23; 8,11,15;108:14;117:19, mixture (1) 11 6:13,15;149:25;150:1; 22;118: 14; 122: 19;123:2; 78:5 161:10;179:19;192:10; 129: 16; 134:1; 142:14; modeling (2) 195:21;209:13;211:20 143: 13,16,22;145:7; 16:23,23

mentioned (13) 147:24; 156:20,23,24; modern (5) 23: 12;29:3;58:24; 160: 17; 161 :21; 162:21; 98: 18,24,24;106:18; 60:15;68: 12;97:21; 163:8,24;165: 10;168:8, 107:15 109:11;117:4;163:19; 16,20,25; 169:3,7, 15; moment (1) 180: 18;182:22;206:3; 170:3,9, 12,16; 171:15, 19; 9:7 211:3 173: 16,23; 188:7, 12,14; moments (I)

mentioned-at (1) 189:7 , I 0,25,25; 190:3,6; 93:9 14:11 191 :7; 199:17;202:21; money (1)

mentioned-on (1) 203: 11;206:22;209:3; 53:6 14:12 21 1:9, 16;215: 13,18,20, Montgomery (6)

mentions (11) 22;216:3 35: 17;36:5,6,9;37:7; 14:1 ;56: 19;79:2;82:3; millions (1) 43:18 84:18;116:17;135:14; 151:3 Montgomery's (1) 149:20;209:17;210:7,18 mind (13) 37:8

mess (1) 39: 12;60:21;73: 10,23; month (1) 37:9 94:13;105:3;111:13; 22:12

Message (4) 118:13, 14;144:3; 178:24; moral (12) 207:11,12,17,17 180:5;212:12 114:14;138:15,16,19,

met (5) mine (1) 20,24; 139: 14;161 :6,8; 24: 16,20; 133: 17; 153:12 218:5;220:4,16 181: 19; 190:21 minister (1) morals (6)

Methodist (2) 185:6 114: 16;122: 17; 124:25; 102:2,3 minor (1) 138:13; 192:25;208: 10

Methodological (2) 72:7 More (45) 180:11;181:1 minute (11) 26:22;27:6;50:21,25;

methodology (1) 18:4;28: 17;52:3;68: 1; 91: 19;92: 1; 105:3,5; 177:19 81 :7; 122:1 0; 127:4; 112:21; 121:8; 124:7;

methods (3) 143: 10; 152:23;161:23; 126: I ,10;131: 18; 133:23; 152:1,2;205:10 188:8 138: 10;142: 12;144: 10;

Midtdal (6) minutes (7) 146:6;154: 15,23;157:24; 35:10, 10, 19,21;43: 17, 25: 10;56: 18;57: 19; 158:3;159:21 ;161: 17, 19,



25;162: 12,19;165: 14; 166: 1; 171 :3,12; 172:1; 177:3; 179:23; 180:3; 184:8;209:1,11;211:17; 214: 14,14;217:4,23

morning (4) 25:8,9; 117:16,25

most (8) 38:5;41: 16;96: 14;98:2, 16;151 :20;176: 18,25

move (9) 101: 17,19;102:22; 104: 14,16; 1 06:4;108:3,5; 206:1

movement (2) 178:23;202:25

moves (1) 194:13

moving (2) 115: 15;194:23

Moxon (2) 191:1,3

much (16) 11:14;18:15;25:9,21; 28:9;29:12;93:4; 109:1; 134:23;152:3,12; 177:3, 11 ;179:20;210:4;221:1

multifaceted (2) 60:4;78:9

multiple (3) 139:7,11,12

murky (1) 188:1

mushroom (1) 157:12

myse1f(2) 27:9;131:4

N

nail (1) 132:14

Nakishia (2) 46:3,7

name (16) 9:6, 16;10: 14,15; 18:25; 19:5;38: 19;51:12;64: 1; 90:21; 100:11 ;190: 13; 196:8; 199:6;207:8; 208:13

named (6) 53: 14;95:2;176:8; 177:6;184:22;207:14

names (1) 58:10

Nar (2) 190:4;205:2

Narconon (255) 9: 17,17;13: 10,13, 16, 20; 14:8; 19:21;20:24,24; 21: 18;23: 13,19;24:24; 26:6;28:3,7,7;29:9,11; 46: 15,15;49:4,6;50:21,

(14) Maybe- Narconon



25;51 :3;52: 17' 18,18,21' 23;53:2,3,4,7, 12;54:18; 55:6,6,13,18,19,23;56:4, 9,13,19,23,24;57: 15; 58: 17;61: 1,18,24,25; 63:1,4,8,8, 11 ,12,15,15, 18;64:8,9;66: 16,19; 67:17;68:23;69: 15,15; 71 :20;72:23;75:9;76: 17; 78:23;81 :23,24;82:23; 83:2,3,4,5,12,14,19,21, 24;84: 1, 16;85: 11 '19,24; 86:3;87: 1 ,7,23;88:4,7, I 0; 92:3,5;94: 10, 16,22,24; 95:9,12, 15,16;96:14, 14, 18;97:2, 11 ,15;98: 15,18, 24;99:2,6,9, 12,14,17,20; 100:1,6, 12,14,18,25,25; 101:10,15,21;102:6,11, 20,22; 103:22;104:6,7,21, 25;105:24; 106:8,19; 107:3, 16;109: 14; 110: II , 17;111:2,15;116:6;117:5; 121 :24;124:7; 125:1,2, 18; 126: 16;128: 12,23; 129:14,23;131 :5,12, 15, 25;132:2,10,12, 17;133:5, 12, 14,16,21; 135:9,12,16, 21 ;136: 1,13; 137:6,20,25; 138: 13; 139:20;140: 12, 24; 141 :5,14 ;142:6; 144:20; 145:21 ,22;146:6, 7,13, 15;147:15, 17, 19,25; 148:6; 149:5,7,9,12,20; 150:6,9,25;151:7,17; 152: 1,6;153:3;154:2; 156: 15; 157: 10,23;159:7, 9,13,14;160: 15; 163:25; 164:1;190:1,2,5,11; 195:10,11,13,16, 19; 199:22;202: 16,17; 204:23;205:3,4,7, 14; 21 0:16;211 :21 ,23;214:25

Narconon's (6) 23: 16;82:11;104:8; 124:21 ;145: 13; 152:9

national (2) 53:3;58:13

nature (4) 35:23; 116: 13; 161: 1; 208:4

near (7) 16: 11;40:7;62: 10,10; 69:2;80:25;92: 10

necessarily (7) 61: 17;81 :25;82:2; 142:22;158:20; 198:4; 199:23

necessary (3) 150:3; 168:22; 169:25

necessity (1) 122:3

need (20)

Min-U-Script@

51: 14,20,22;57:1; 39:13;41 :7,8;46: 14, 16; 153: 1,17; 163:1 8; 166:2; 77: 15; 107:22; 109: 19; 82: 19; 156:9 168:5;169: 17,23;170:18; 117:9; 136:15;142: 18; Non-party (1) 174:20; 185:12, 15; 186:6; 143:6; 150: 16;162:25; 12:21 187:20;191 :10,10, 17; 164:20;167: 18;170:6; nonprofit (23) 192:1 0;193:5;197: 13; 180:24;189:7;215:7; 55:20;56:4;61: 1,3,10, 198: 10;204:1;206:14; 221:5 13,19,25;81 :7,10, 13,18, 209:5,21;211:8,11;

needn't (1) 23,24;82: 1 ;83:9;88:8; 213: 11;219: 17 152:18 89:7;145: 15; 146: 15,16; numbered (3)

needs (1) 159:10,14 20:3;57:7,10 94:2 non-psychiatrist (1) numbers (4)

negative (6) 153:4 12:7;35: 12;52:8; 17:23;113:4,14,24; non-Scientologists (1) 144:22 115:17;199:1 136:2 numeral (1)

negativity (1) Nor (4) 58:22 200:16 97: 18; 137: 10;157:7; nutshell (1)

negotiated (1) 159:12 39:9 90:15 normal (3)

negotiations (2) 115: 14,14;187:18 0 62:19;92:16 North (2)

net (3) 32:4;183:5 object (16) 41:22;42:15,23 Norway (1) 17:1 ;40:3;90:3;1 08: 11;

network (11) 183:13 133:25; 142: I ; 160:4; 151:25; 175:9,11,20,24; Nos (5) 161 : 15; 162: 1 7; 165:7; 176:3,8,14;183: 18,24; 8:2;103:6; 143: 19; 191 :7; 199:17;202:21,24; 184:5 163:14;169:11 203 :11 ;206:22

neutral (3) notary (1) objected (2) 45:7;1 06:21;161:2 9:4 42:7;46:7

Nevada (1) notation (1) objection (7) 45:15 65:16 39:2,4,21,24;40: 12;

New (6) note (1) 45:18;134:2 73: 17; 151:7;162: 13; 65:9 objectionable (1) 164:22;170:25;171: 1 notes (8) 48:6

newspaper (3) 14: 16;45:5;70:25; objections (1) 77:3; 170:23,24 152:7; 179:15;196:23; 8:14

Next (14) 211:9,12 objective (1) 19: 19,20;37: 11 ,21; nothing's (2) 45:7 42: 12;45:9;52: 1,2;57: 17; 149:5;155:16 objectives (10) 72:12;116:2;122:20; notice (6) 17: 19, 19,25;20:12; 169:8;173:16 21: 19;30:22;41 :15; 73:13;112:23,25;113:5;

next-to-last (1) 201 :8;211 :8,11 197:6,6 62:11 noting (1) obligation (1)

niacin (2) 93:24 69:17 111 :25; 112:2 November (1) OCA (1)

Nick (3) 22:9 102:17 75:2;92:25;98:7 NP(2) occasional (3)

nicotine (2) 12:4,19 209: 17;210:7,18 96:6,7 number (92) occasions (2)

night (10) 11:3;16:14,19;19:23; 47:4;210:23 24: 19,25;25: 1;66: 14; 26: 10;28:2,9;29: 12; occurred (1) 69:5;74:20; 117:24; 36:23;38:4;52: 13;54: 16; 131:20 168:4; 191:21 ;212:2 58:3;70:5;71 : 16,19;73:2, occurring (2)

nights (1) 8,17;78: I I ;80: 12;90:22; 128:12,22 26:6 91:9,18;93: 19;94: 16; occurs (1)

nine (2) 95:23;96:11,15;99:22; 106:5 16: 13;47: 1 104:9;112:9;114:10; o'clock (1)

ninth (1) 115: I ,23; 116:3; 118:2,9; 208:23 93:12 124: 13, 16; 125: 18,21; October (1)

non (1) 126:5,23; 134:6; 137:4; 153:11 83:17 138:7,7 ,24;140: 19, 19; odd (1)

non-drug (2) 144:4,8,24;145: 11,19,25; 33:24 138:3;153:4 146:21 ;148: 13;149:3; off (34)

none (7) 150:20,24;152:6,13; 9: 10;16:2;22:2;35: 15;



40: 16;50:6;51 :4,4,25; 77:20;85: 13;96:20,24; 109:21;133:22;135: 11 , 17, 19; 136:3;138:3;140:9; 147:23;148:9; 154:13; 157:3;163: 1 0,12; 170: 15; 189: 14;195: I ;207:10; 209:7;215:25;216:2

otler (53) 27:21,24;28:14;47: 15; 49: 16,22;50:20,23;54:6; 55:9,12;61 :24;63:3; 64:12;66: 18;67:2,7;69:5, 8,11,14;84:15;86:2; 97:1 0,14,19;99:16, 19; 102: 10;106:6,17;107: 1, 21; 108:3;112:6; 124:5,7, 12;129:11,22;137:15; 141: 12,24; 150:17;157:2; 161: 14; 162:15;165:4,22; 167:2;216: 16;220: II, 12

offered (4) 34: 10;35:5; 101:3; 206:16

offering (2) 49:5; 106:22

offhand (2) 47:22;168:1

office (1) 92:13

officer (3) 36:7;136:15,16

officers (2) 36:15;37:7

officials (2) 195: 11,11

officials-must (1) 195:12

Often (8) 16:23;93:8; 102: 14; 104:8,14;113:3,4,7

Oklahoma (6) 21:19,24;27:3;67:6; 145:3,4

old (5) 10:14,17;101:4; 105:22;164:12

older (2) 74:9;178:10

omissions (1) 15:22

omit (1) 116:21

omits (1) 96:6

omitted (3) 11: 16;96:7; 170:17

once (4) 44: 19;53:9;86:21; 146:25

one (165) 11 :3; 14:9; 16:22;19: 13; 20:9,14;21 :22;22:21;

(15) Narconon's - one



25:7;32:2,4;33: 1,6;35: 13; 36:23;38: 11, 14;40:20,24, 24;41: 14,21 ;42:10, 12; 43:24;45:9,18,23,25; 46:20,22,25;49:11;51: 12; 53 :20;55:22;56:9;57:9; 61 :8;67:2;72:9;73:3,4; 75: 19;76:24;77:9;78:20, 21;83: 1;91:19;94:4;96:6; I 01:4, 17;103:13,20; I 04: 14; 1 09:7,12; 114:16, 25; 115:4, 19,22,22,23; 116:1,2,18,19;117:3; 119:22; 122:2,2;123: 16; 126:1; 131; 16; 132:3,4,6; 134:5,17;135:6,21; 136:20,25;137:22; 138:7, 14; 144: 13;145:16;150:9; 152:5,11 ;153:21 ;154: 17, 23;155:20;156: 12; 158:16, 16; 161: 1,11; 168:5; 170:25; 171; 1,6, 7' 10;172:5,24;173:1,2,3,4, 6,7; 174:21; 176: 12; 180: 16;181 :9; 182:24; 183:6; 184:17; 186:22; 188:3; 192:20;193 :4,19; 194:12,13,13, 14,15,19, 22; 196:3, 16,21,23; 197: 10; 198: I ,2;201:22; 204:20,20;206:7 ;207: 5, 24,25 ;209: 19 ;21 0:20; 212:3;217:4,6,15;218:3; 219:4,6,7,7, 11,18,20; 220:11

one-page (2) 182:12,14

ones (15) 16: 14;35: 15;38:9; 41: 16;47:22;74:20; 142:17,24;143:1,4; 148: 16;170:4;197:7; 199:1;216:11

one's (10) 42:22;85:6;115:24,25; 116:1;118:22;198:1; 201:9;204: 14,15

only (27) 8:6,9; 16: 14;40:5, 10; 45:4;48:10;56:20;78:9; 80:21 ;83: 15,19;95:9, 11; 109:7;131 :11 ;151 :11; 154:21;158:11 ,17;160:5; 163: 16;168:16;175: 13; 195: 18;200:9;201:17

Ontario (2) 32: 16;178:5

onto (1) 25:12

open (3) 1 04:9;112:3;146: 19

opened (4) 24: 10;33:7,13;95: 15

J\Iin-U-Script@

operation (2) 183:9;204:7,21 ;212:25; own (8) 115:6,14 220:15 45:3;115:24;135: 1;

operations (1) organizational (3) 183:9;204: 12, 14;205 :9; 107:3 70:22; 115:6;204:16 214:12

opinion (55) organizations (21) Oxford (11) 24:6,14;27:21 ;28: 15; 56: 10,11,25;58:8,9; 102:12,14,16, 17; 35:5;51 :7;54: 10;61 :24; 60:8,16, 19;62: 1 ,5;63:9; 109: 12,13,16,17,23; 66: 18;67:2;71: 19,19; 70:15;78:6,6;80:9,24; 110:15;111:7 73:2;78:5, 15;80:4;83:20; 88: 15;90:6,11; 101:1; 84: 16;86:2;97: I 0,14,19; 213:2 p 99:8,17, 19; 106:7, 17,23; organized (1) 107: 1,21,25;108:3; 96:20 pack (37) 124:13, 16; 125: 17; 126:5, oriented (4) 13: 10,20,22;14:8,1 0, 23;127: 14; I29: 1 I ,22; 113:3,4; 195:8,9 17,24;16:4,8,13, 19;21: 18, 133:5; 134:6; 13 7: 15; original (2) 20,25;23: 15;24:23;25:2; 140: 18,19;150:4;162:6; 60:23;185:18 66:13, I 7;67:6, 17;70:2; 165:22; 166:2; 167:3; others (6) 72:1,23;79:7,25;80: 12, 217:4,6,15,17,25 60: 17 ;99: 15; 157:11; 12;82:23;83:3;85:11;

opinions (77) 178:22;218:8,1 I 98: 17;103:22;116:6; 9:24; 10:3;13:9,19; out (69) 152:25;201 :9,10 15:6,8;20:20;23 :7;24:3; 9:23; 10:2; I 1:3,4, 18; packs (6) 27: 17,24;28:21 ,23;29: I 8; 15:5; 18:20;20:6;22:4; 15:2, 16,25;18:8;79:4; 34:11;49:2,6,17,22; 26:2,9,24,24;28: 15;30:4; 83:5 50:10,11 ' 14,20,23;52:4,9; 32: 11,16;34:5;41:7; pack's (1) 54:6,7;55:9,12;63:3;67:7; 43:22;44:21 ;45:21 ;46:9; 15:17 69:5,8,11 ,15,21,24;71:5, 52:14;53:6;61 :9;65: 13, Padgett (8) 9,1 0, 16;76:4;79 :22; 17;76:23;77: 12;79:21; 42:24,24;43:3,10, 15, 108:9;112:7;124:5,7 ,11; 82:9;85: 17;86:12;102:2; 24;172:21;173:3 126: 11' 12; 130: 12; 116: 10;121 :21;135: 14; page (28) 141:22;142: 19; 143:2,6; 138: 18; 139: 15; 142:24; 14: 13;57:23;58:3; 144:1 ;147:12;150:3, 17; 145: 16;152:5;154:1; 60:20;118: 10;119: 12,20; 153:3; 157:2,21 ; 158:1 0; 157: 15;158: 19,20,23; 120:8; 121:12, 14; 122:1 ; 161: 13; 162: 15,22; 161 :9,18;175:23;182:4; 152: 14; 153: 17,23; 164:23; 165:4; 167:20; 183:3; 184:19;185:8; 154:20;157: 12; 184:9; 185:21; 187:8;188:21,25; 187:9; 188:2;196: 11; 192:9,9;193:20; 195:24; 220:6,11,12 201 :4;202:5,5,7, I 0, 14, 18; 196:1 0;200:4;209:25,25;

oppose (2) 203:23;204:20;205:3; 210:1,2,3 187:19,20 216:5 pages (8)

opposed (2) outlier (1) 12:14;58:5,21 ;108:16; 199:5,7 158:11 109:7; 144:8;153: 10;

opposite (1) outlined (1) 155:14 199:9 138:11 page-that's (1)

opposition (2) outlines (2) 153:21 47:5;134:20 71:5;201:21 paid (3)

ordained (1) outlining (3) 55:1 ;179:19,20 185:6 27:25;68:21 ;126:25 pain (1)

order (10) outside (5) 122:6 13:9;24:3;30:23;52:22; 21:16;96: 15;175: 12; painful (1) 114:13;115:4,18;142:18; 188:2;201:23 31:24 200:22;20 I :4 over (9) pamphlet (2)

orders (2) 42:25;44: 14;70:8; 101:9;207:11 194:14,17 75 :25;96:22;112: 15; paper (9)

ordinary (2) 127:23;174:5;184:23 11 :14;26:17;65:20; 38:9;216:11 overall (1) 178 : 11 ,25;180:8, 13,23;

Org (2) 82:4 196:24 44:4;212:24 oversight (1) paperback (1)

Organization (32) 29:12 116:8 42:14;52:25;53:2,8; overt (2) papers (I) 55: 14,20,25;56:4;61: 1, 120:18;165:17 152:20 20;63:5,6;65:5;70: 12; overts (4) paragraph (1) 78:9;81 :8, 11, 13,19;83:2; 120:3,6,10,12 151:18 88:9, 19; 102:25,25; overwhelming (1) paragraphs (1) 115:25;139:7;172:13; 151:9 184:8



parallel (5) 94:5,6; 113:20;162:1; 220:7

parallels (1) 199:8

parents (1) 32:11

parliamentary (1) 184:12

Parsons' (3) 75:2;92:25;98:7

part (26) 22: 12;23: 17;30:19; 38:12;41; 17;52:22;60:2; 65 :4;78:9 ;83 :8,1 0;85 :23; 88:20;98:2, 16;102: I 0; 1 09:4;131:17;144: 19; 146:3, 12; 157: 14; 158:3; 185: 13;207:6;218:24

partially (1) 117:25

participants (1) 136:1

particular (35) 13: 15,15;20:25;40:6, 1 0;58: 1 0;60:5;61 :7;87:8; 108: 19; Ill :21,24;115:5, 6;123: 12,17;128:3; 130:25;131:9; 136:23; 141:9; 145:23;152:13; 164: 14;176:24;181 :4; 184:21; 188:22; 192:21; 194:2,6;200: 19,20; 201 :23;205: 12

particularly (1) 41 :8

parties (2) 32:14;148:18

partnered (1) 36:12

partnership (1) 190:25

parts (1) 78:10

party (1) 60:4

pass (3) 115:11 ;119: 14,21

passed (2) 182:18;211:11

passing (1) 211:9

past (7) 17: 12,24;40:4; 113:4; 175: 1; 191:1 0;201: 12

path (1) 194:19

Patrick (5) 67: 19;69:4;74:21; 110:11;111:6

pay (6) 70:1 1,15;87:11; 144: 10;206:20;207: 1

(16) one-page- pay



paycheck (1) 185:14

paying (1) 61:6

pays (2) 52:23;54:18

peer (2) 182:23;187:25

peer-review (1) 188:5

peer-reviewed (1) 187:23

penal (2) 60: 15; 180:20

pencil (1) 196:23

pencils (1) 16:24

Pentecostal (3) 176:10, 15;183:25

people (105) 17:23;18 : 13,16,19,21, 22;20:5;24: 11 ;48:9; 49:24;51 :2;53: 19;54: 12; 65:2;70: 15;75:21 ;85: 18; 86: 1,7;89:9;93:8,16; 95:24;96:24;99:9, 18,22; 100: 18,19; 101:5, 16,19; 102: 11,22;103:23; I 04: 14,15;105:23; 106:8, 19;107:7;109:20; 111 :25; 112:14;113:2,14;114:6, 18;115:8;118:4;120: 15; 124: I ;1 27:10,14,16; 128:2;131 :19,23; 133:12, 16,18,22,23;135:8,9,11, 17; 136:3; 138:3,9; 139: II; 140:8;148:9;154: 12; 155:7 ,12; 156:3,6; 157:3; 177: 17,1 8;186:22; 187: 19;194:24; 195:7,13; 197:8; 199:9,16, 19; 200: 14,16;210: 1;212:9; 214: 13,22;216:8,13, 18; 217:2,8,23;218:4;219: 18; 220: 1

people's (9) 32: 14;48:8; 115:10; 127:7;132:7; 133:8; 216:21;219: 13;220: 16

people-you (1) 18:25

perceive (1) 176:19

percent (7) 52:24;53: 1 ;54: 19;55: 1; 70:5;86: 17;96:25

percentage (3) 18:25;33:20;70: 12

percentages (1) 97:3

perception (6) 37:25;73:12;112:19;

Min-U-Script®

197:2;219:22,23 philosophy (1) played (1) performing (4) 30:14 92:18

204:20,21,21,22 phone (4) player (1) perhaps (2) 22:24;65:2,9;183:2 185:24

183: 13 ;217:21 photo (1) please (1) period (6) 108:22 156:21

30:7;37:24;38:4,25; photocopied (1) plus (1) 98:22; 129:17 145:20 96:25

periods-up (1) photocopy (2) pm (1) 111:19 108:23;109:6 221:10

permission (2) photocopying (2) point (33) 64:1;95:6 108:23;109:2 19:1 0;23:3;32:7;37:4,

permitted (1) phrase (1) 4;43: 13;57:20;65:25; 58:9 135:4 84:7; 106:21 ;108:8,12;

person (49) phrases (1) 118:9; 134:22;142: 18; 14:2;17:3,6,9,25;18: 1; 177:6 143: 1,5; 144:2; 157:20,23, 19:23;20: 10;36:22; physical (2) 23;158:9;160:22;161 :9, 40:22;41: 10;43 :21; 119:3;196:17 25; 167: 10; 176:18; 45: 18;99:20;100: 14; physically (1) 187:18,19,20;211: 1, 1,2 103:25;113 :24;115: 12, 198:2 pointing (1) 14,20;119:24;141 :3,8; physiological (3) 201:19 176:8; 184:21 ,22,23; 112:5; 129:7; 154:10 points (3) 194:5,8,21 ;195:9;196:2; physiology (3) 137:24;187: 17,20 197:22; 198: I ,2,6; 199: I, 50: 1,16; 130:20 police (6) 4,7, 12,16;200:18;201: 12, pick (1) 36:6,10,11 , 14,16;37:7 15,19;202:4, 13,17; 108:20 policy (3) 207:14 picked (1) 43:6;201 :20;202: 16

person' (1) 42:10 poorly (1) 38: 1 picture (2) 147:10

Personal (13) 103:23;152:16 popular (1) 19:22;62:21 ;75: 16,20; piece (2) 213:1 89:11;90:16;100:6; 26:17;65:20 popularity (1) 114: 11, 13,23; 118:2; pieces (1) 151 :9 136:22;220: 1 186:6 popularizing (1)

personalities (3) pin (1) 207:9 19:15,16;200:14 117:12 population (1)

personality (13) Pis (1) 151:6 109:22,22;113: 12, 12, 91:21 pores (1) 18,21,22; 198:15,15,24, place (4) 112:3 25;199:5,9 8:10,12; 14: 13;76: 17 portion (2)

persons (1) places (2) 68:13; 145:17 199:20 19:17;82:6 portions (1)

person's (10) plaintiffs (1) 158:9 48: 12;63:25;90:21; 13:11 portray (2) 109: 19; 113:23;115: 19; plaintiffs' ( 6) 156:14;208:3 136: 16;154:22;194:20; 13: 1;21 :7;24: 16;27: 13; portrayal (1) 198:5 75: 12; 170:20 147:16

perspective (3) plan (9) portrayed (1) 132:9; 187:3;203 :20 51 :9,12;66:20;67:20; 180:18

persuade (1) 99: 19; 102:25;140:22; portrays (1) 176:15 147:3; 150:25 153:6

persuasion (1) planet (4) position (9) 178:19 134:16,17,18,20 32:19;33:6, 13,13;83: 1;

PhD (12) planned (3) 103:2;115:8,11;135 :25 30: 17;31:7,12;33:9; 29:2;107:2,18 positive (2) 182: 17; 183: 1,1,2,3,6, 10; planning ( 4) 217:4;220:1 8 185:4 30: 18;50: 11;51: 19; positively (1)

PhDs (1) 158:2 86:13 32:21 plans (5) possibility (3)

phenomenon (1) 48:25;5 1 :25;63:7; 118:5; 123: II ;144: 18 202:14 66:24;174:14 possible (5)

philos (1) plates (1) 33:4;99: 13; 105:17; 123:15 91:23 142:4;208:24



possible-of (1) 111:20

possibly (3) 15:9;83: 18; 159:20

postdocs (1) 32:21

postdoctoral (3) 32:18,20,25

posted (1) 34:19

potential (8) 19:16;66:21;113:12; 134: 19; 198: 16;200:5, 17; 202:11

power (3) 115:8,11;123:22

Practice (22) 8:21 ;42: 1,5;46:5,6; 47:20;48:5;70:10; 104:11;127:13,15; 128: 11,21;129: 13,23; 131:19,21;141:23; 149: 17; 191 :5, 14;213:21

practiced (5) 129: 14; 196: 14;213: 16, 24;214:22

practices (30) 28:1;47:21 ;48:10; 68:21 ;70:20;83:7 ,8; 126:25; 127:12, 18,20; 128:3,16; 130:23;131 :8; 132: 13;133: I ;134:7; 137: 14; 140:3,23; 141: 12; 192: 15,22;194:3;197:7, 19; 198:20;204: II ;208: 19

practicing (2) 136:13;194:7

precepts (2) 19:24;20:3

precisely (2) 124:4;203:22

predate (1) 126:16

preliminary (1) 194:16

preparation (1) 112:22

prepare (1) 194:21

prepared (5) 75: 12,14;192:16,19; 208:16

preparing (1) 51:25

prepped (1) 137:10

present (11) 18: 1;68:3; 113:3,6; 140:22;169: 13;195:8; 197:9,23;213:20;215: 11

presentation (1) 152:10

president (1)

(17) paycheck - president



53 :1 2 pressed (1)

101 :16 presumably {1)

82:18 pretend (1)

118:24 pretty (8)

15:25;41 :7;42: 15;43:5, 9;81 :4;152 :3 ;1 73:2

prevent (1) 210:5

previous (2) 20:23;21 :18

previously (1) 14:7

primarily (9) 28:4;66:22;71 :22; 73: 13;96: 13;99:3; 137:7, 16;142:8

primary (1) 2 14:19

principal (1) 175:19

principle (10) 111 : 12;196: 14,25; 200:6,10,13;201:5;202: I ; 21 8:10,12

principles (33) 25: 13,15;28:4;42:9; 71 :22;79:7,8,17, 19;80:6; 83:6;84:4;93:2;96:21 ; 114:17,25;11 5:3;124:17, 19,24; 126:8; 13 1: 13; 132: 18,1 9;136:14;137:7; 138:8, 18; 142:8,11;162:9; 205: 11 ;208:17

print (3) 11 :4 ,18;185: 1

printer {1) 77: 14

Prior (3) 24: 15;27:4;56: 14

prison (4) 95 :2;96:20; 148:10,11

prisoner (1) 148:8

prisoner s (3) 95:5,7;96:20

prisons (1) 96: 16

private (2) 155:23;213:19

privilege (1) 86:23

probably (17) 22:9;26:23;37:5;78:2; 87:8; 102:24;108:7; 133:7;153:15;161 :3; 181: 19,25; 188:6;205:8,9; 214:2;220:21

problem (5) 12:23;87: 12;130:2;

1\Iin-U-~cript@

151:13;200:16 17; 194:5,8 37:23;38:3, 16,17; problems (5) prominent (1) 103:21;186:19

17:2;86: 11 ;153:5; 36:8 publicity {1) 202:9,10 promise {1) 18: 17

procedure (2) 32:23 publicly (1) 70:13;206:10 promotes (1) 44:7

procedures (2) 220:15 published (18) 136:18;19 1:25 pronounce (2) 20:7;32:23;103:20;

proceeding (2) 190:16;211:4 105: 12; 155: 16,20; 172:7; 44:23,24 proper (1) 177:9, 18; 179:5,1 0,13,15;

process (4) 136 :18 180:4; 181 :24;184:4; 120: 18; 151 :4; 188 :1 ; protocol (1) 185:15;186:5 195:4 152 :8 publisher (1)

processes (4) proud (1) 103:22 39: 13;95:5; 163:22; 135:16 publishers (1) 194:17 proved (1) 182:4

produce (2) 154 :21 pull (4) 116: 12;156: 18 provide (12) 22:4;65: 17;142:20;

produced (11) 27:25;39:8;65:23,24; 16 1:18 72:21 ;73:21 ,23,25; 66:4,5,7 ,1 0;99:2; 126:24; pulled (2) 74:5,12;108:15;116:9; 177:24;214:25 27:9;70: I 142: 16;168: 14;170:5 provided (9) pulling (2)

production (2) 1 0:23; 11 :6;21 :7;24:2; 26:1;65 :13 152:7;155:1 27: 16;64:5;75:8;76:10; Pur (1)

professionally (1) 214:4 96:4 216:15 provides (1) purely (2)

professor (1) 80:8 87:24;218:3 180:9 providing (2) Purif(2)

program (103) 40:12;175:25 96: 11;133:19 21 :5,8;29:9;31 :2,3,15; pseudo (2) Purification (22) 42: 19;49:4,6;50:21 ,24; 150:11, 11 16: 15,16,18;95: 10,17; 54:5,9,14;60: 12;63 : 18; psych (1) 96:4,13;97:21;99:21; 64:8,9;66: 19;73:8, 17; 49:14 100:20; 10 I :5,6; I 03:24; 79: 16,18;83 :4,4,14,14,2 1; psychiatric (1) 108:24;111 : 13,15,16; 84:3, 16, 19;85: 14,20; 199:25 129:5; 131 :25; 133: I I ; 86:3,8;87:24;94: 10; psychiatrist (2) 146:23;152: 16 95:10,12, 15,16;96:9,1 0, 49:9;138:4 purpose (8) 19;97: 17,18,22,23;99:21, psychiatry (9) 8: 16,19;9:23; 130:9; 24;100: 1,6,12,15,18; 134:23,25,25; 135: 14, 137: 1,2;158:21;197: 18 10 1:23; 104:25;105:24; 15,19; 150:23;151:2, 15 purposes (21) 107 :4; 11 0:4; 111: 14, 14; psycho (1) 8:2,6,8,20;57:25;60:7; 123:24; 124: I ,4,6,8,1 0; 184:13 65: 10;72: 15;81 :25 ; 125: 1;128: 13,23; 129:6, psychological (1) 82:21; 103:6;123: 1; 15; 131 :25,25; 132:2,1 0; 110:3 129: 10;143: 19;163: 14; 133:12,17;135:11 ;136:3; psychologist (2) 169: 11,20; 17 1: 18; 137:25; I 38:3,17; 141 :14; 49 :10,14 173:22;194 :7;215:6 144:20;145:23;147: 15; psychoses (1) pursuant (1) 148:8;150:9;151 :12; 42:20 8:10 154:3,8,12;157: 10; psychotic (2) push (3) 165:24;1 80:1 9,21; 199:23,24 82: 12;133: 11 ;145:22 195: 13;200:20;202: 17, PTS (11) put (11) 18;210:16 113:21,24 ;141:3; 15:24;34:7;61 :22;72:5;

programs (14) 198 :20;200:9,20,23,24, 122:22,23; 160:7; 166: 19; 31:1 0;32:4;42:2;46:6; 25;201 : 1,3 189: 18; 195:22;215: I 0 48:21,23;49:23;51: 1; pub (1) putting (2) 97:2;106:8,19;107: 16; 179:5 38:6;5 1:25 131 :22;140: 13 public (7)

program's (1) 9:4 ;58:4;89:21; 100: 1 0; Q 86:9 151:9; 175:21;208:3

progress (2) publication (5) qualified (2) 200:22;202: 12 151: 17; 168:21;175:4; 50:13,16

Project (6) 179:22;182:1 quarter (1) 60: 12; 151 :8; 180:12, Publications (6) 70:9

Q&A Repor ting Services, Inc. JFischer @QAReporting.com


questionnaire (1) 109: 18

question's (1) 85:25

quickly (3) 41 : 17;110:20;205: 18

quite (9) 52:7;53:7;90:22; 115:23;119: 10;135: 16; 145: 19;206: 12;211 :11

quotation (1) 122:4

quoted (3) 17 1:1,3;184:17

quotes (1) 187: 12

R

r adiation (9) 95:20,22,25;96:2,5; 112: 1,4; 152: 15;157: 15

Rain (1) 187:1 1

raise (3) 97:7;116:2;147:3

raised (1) 177: 17

ran (1) 144:9

range (3) 144:8;152:23; 186:4

rate (5) 96:24;97: 11 ,15,1 6,18

rates (1) 157: 10

rather (2) 29: 10;99:15

RCMP(1) 36:11

reach (3) 13:9,18;24 :3

reached (5) 84 : 10;87:25;91 :6;92:8; 177:20

reaching (6) 20:20;23 :6;73 :2 ;76:3; 108:9;134:19

reacts (1) 17:9

read (19) 9:1 ;68:17;70:7;74:22, 23;84:21;85:4;95:4; 102:9;105:14;1 11:1; 133:22; 148: I ;158: 12; 184:9; 193:21 ;200:7; 214:21;219:7

reading (4) 64: 19;155: 13 ,14; 2 14:1 1

rea ds (1) 2 19:7

rea dy (1)

(18) pressed - ready



159:22 real (4)

86:22; 148:4;153:7; 210:5

reality (1) 90:5

realize (3) 8:6;142: 19;200:25

realized (1) 147:1

really (30) 18: 19; 19:21 ;22: 13; 24:11;25:15;39:8;41:8; 44: I 0;72:3;78:20;89: 12; 93:4;95: 19; 115:8,25; 119:10;135:7;136:11; 137:21,21;154:6; 156: 14; 159: 15;164: 13;177: 1,13; 181 : 15; 185: 19;196:20; 212:4

realm (1) 135:13

realms (2) 136: 11;161:11

reappear (1) 195: 13

reason (23) 11 :22;40:2,10, 11 ;5 1 :5, 15;56:5;60:25;61: 15,20; 80:21 ;87:4; 1 04:20; 107:20;119:25;124:4; 134:4; 139:5,5;149:2; 164: 14;175:13; 179:12

reasonable (1) 86:2

reasonably (1) 167:22

reasons (4) 32:2;82: I ;185: 13; 186: 10

Rebecca (11) 23:4,7;65:23;67:23; 73:20;103:12; 156:21; 166:24; 168: 10; 170: 14; 188: 14

Rebecca's (1) 169:23

rebel (1) 207:14

recall (21) 23:20;36: 1;43:23; 45:20;62: 10;71: ll ;79: I, 3, 14;92: I 0;1 05:2;106: 1; 109:2; 122:6;123:9; 160:22; 171 :2;205: 15,17; 2 12: 1,3

recall-and (1) 102:8

receive (3) 21: 10; 199: 13;200: 19

received (3) 27:20;56:11 ;83:9

receives (2)

1\fin-L-Script®

136: 16; 194:14 70: 1;149:8,10,20 91:24 receiving (2) reference (7) release (1)

44:3;111:7 12:14;13:21;79:1 1; 62: 15 recent (3) 168:3;170:22;210: 11; released ( 4)

32:2 1;105:3,5 213:3 62:9,12;89:21 ;90: 1 referenced (I) relevant (5)

I 13:18 128:23;132:9;134 :9; references (4) 140:5;141 :8

'Recent (1) 210: 14;212: 18,20; relief (2) 151:19 219:8 120:6,15

referred (3) religion (31) R 104:4; 175:2;205:19 30:12,14,15,17, 17;

referring (3) 31 :4,7,9,12, 15, 18;33 :8; Recess (7) 72:1,3;78:8 42:8;48:9,10,11 ;78: 18;

50:7;68:2;103: 14; refers (2) 82:4,5; 116: 17; 123: 15; 117:21 ;143:21;169:9; 16:15;180:13 127:16;146: 17;160:1 1, 189:15 refused (1) 12; 177: 10;178:22;

recitation (1) 62:16 181:11,25;185:8;186:16 19:14 refute (1) religions (1)

recognition (2) 179:12 89:1 18:25;19:5 regained (1) religions-Hinduism (1)

recognize (2) 104:1 30:23 19: 1;21 :2 regard (8) religious (62)

recollection (2) 46:24;47: 11;4 8:20; 31: 10;37: 15,22;42:9; 44:25;56:24 49:3;67:5; 124:20; 128:7; 47: 16;48:4,8;58: 19;62:5;

reconceptualize (1) 186: 19 78:5,10,18;79:9,20;80: 1; 178:18 regarding (2) 81: 8,1 1, 14,21;82: 1,5,1 3,

record (25) 188:21;189 :1 15,24;83:4,1 0, 14, 19,20; 9:10;45:1 ,7;50:6; regional (1) 84:17;85: 19,23;86:3,7, 65: 18;66:7;77:20;85 :4; 53:2 13,20;87:3 ;88:6,9, 12,20, 93:24; 144:5; 147:23; regular (2) 23;89:4;99:5;1 16:13,15; 163:11 ,12;164:12,13 ; 210:8,10 121 :5,24;123:8; 127:7; 170:13, 15; 189: 14, 18; regulated (1) 160:21 ;161: I ;177:2; 195:1 ;209:7;2 15:7,10; 54:5 180:9;185:5; 186:20; 216:1,2 regulations (1) 187:3,10;213: 16,21,24;

records (5) 53:24 2 18:8 22: 15;64: 15,18;98:4; rehab (1) rely (14) 156:8 50:17 29: 15;64:2,6,1 1 ;76:2,

recount (2) Rehabilitation (7) 12;108:8; 142:23;145: 10; 64:12,13 60: 12; 135: 13;151 : 10, 147:5,11;150:16; 164: 16,

recruit (7) 24;154:3;180 : 12,17 19 99:9, 17; 100: 15;101 :1, reindoctrination (1) relying (4) 23; 106: 19;107: 16 60:14 68:9,16,19; 164: 11

recruited (2) relate (3) remainder (1) 100:2,7 93:2,20;209: 14 168:6

recruiting (2) related (5) remained (1) 102:21;133:15 85: 12; 167:11 ;172: 13; 33:16

recruitment (4) 206: 19;207:7 remember (24) 99: 13,24;102:14; relates (4) 17: 15;20: 14;22: 12; 109:20 144: 18;157: 13;158:24; 27: 10;3 1: 13;32: 13;42:6,

Red (1) 204:17 22;44:7, 11 ;45: 11, 16; 81:10 relating (3) 47:23;51:12;55:23;

reduce (1) 197: 19;201 :5;202: I 56: 13;73:5;105:2; 15:21 relation (2) 112:21;114:15;176:22;

reduced (2) 115:5,6 184:7; 195:3;219: 15 44:17,18 relational (1) remembered (2)

reduces (1) 159:17 43:10;212:17 132: 1 relationship (6) remove(l)

reeducation (3) 115:25;145:22;146:6; 132:3 60:14, 14;180: 19 204:15,16,19 rendition (1)

reestablish (1) relationships (2) 113:1 1 178: 19 55: 17;216:19 repeat (3)

refer (4) relayed (1) 17: 17;93 : 13;195:20



repeats (1) 24:9

repetition (3) 16: 12;112:22;195:22

replace (1) 134:25

report (5) 34 :25;184: 15,17;202 :4, 15

reporter (5) 9:8;45:3,5;85:5; 168:8

reports (4) 34:24; 136: 16; 174:11; 202:13

represent (4) 9: 16;11: 17;72:20; 188: 19

representation (2) 97:6;141: 1

representing (4) 41:1 1,1 1;189:19,22

represents (1) 211:7

reproduce (1) 208:7

reproduced (2) 62: 12;207: 18

required (4) 107:9;136:21,21; 137:5

requirement (1) 133: 17

requirements (2) 63:24;89:3

requires (1) 107:7

research (30) 13: 13;20:20,23;63:25; 151:19,23,23; 152:5,7,8, 10, 12; 153: 14,25;154: 1, 16,16,19,21 ,23,24; 155: 15,20,24;156:3, 16; 157:7;159:6,11;181:24

researcher (1) 65:5

reserve (1) 8: 14

residential (1) 151:8

residues (4) 96:3,5; 11 2: 1,4

resolved (5) 59: 13;77: 1;82: 18,20,21

respect (7) 8: 12;20:5;47: 11;84:5; 127:7; 131 :8;218:7

respond (3) 141:7; 180:24;181:6

responded (6) 179:21; 181: 12, 12; 184:2,2,19

responding (1) 186: 19

response (5)

(19) real- r esponse



180:22,25;181 :10,13; 185:1

responses (1) 148:17

responsibilities (2) 204:15;217 : 19

responsibility (2) 217:20,20

responsible (1) 217:23

rest (1) 143:14

resulting (2) 128:4;151:24

results (1) 178:21

resume (1) 172:7

resumed (6) 50:7;68:2; 117:21; 143:21 ;169:9; 189:15

retired (1) 184:24

retreat (1) 103:1

retrieved (1) 117:24

reveal (3) 91:10,10,14

Revenue (3) 59: 15;60: 1;84: 11

reversing (1) 178:20

review (12) 14: 16;70:2;71 :3 ;79:5; 92:25,25; 181 :24; 182:23 ; 188:1 ;192:2;209:12; 212:1

reviewed (10) 67:6;83: 13,24;110:11; 117:24; 160:1; 168:4, 18; 169:18;191:20

reviewers (1) 188:2

reviewing (1) 25:21

reviews (1) 182:22

revoked (2) 183:4,6

rid (2) 96:2;134:18

Rider (1) 110:18

Rieser (3) 110:18,18;111:3

Rieser's (1) 24:9

right (77) 11:8,12;12:6;13:2,21; 15:12;19:12;22:11;24:5, 19;30: 13;31 : 19;34:21; 40: I 6;41 :21 ;46:22;48:2,

1\lin-U-Script®

15;52:22,25;56:17;72:25; 187:12,24 130: 14; 133:7; 152:3; 75:1 0;77:8,10;79: 13; rubber (1) 155:19;176:22 83:25;97:20; I 01 :8; 196:24 scale (1) 102:5;104:5; 105:6;1 07:5, rule (1) 122:5 10;118:7;123:25;125:6,7, 141:4 Scandinavia (1) I 0; 126:21 ;127:7; 128: I; ruling (2) 183:13 138:23; 139:25; 142:10, 55:25;61:9 scanned (1) 13; 145:25; 147:3,8;148:7; run (5) 168:11 150:8; 153: 19;156:3; 18: 16;41: 17;54: 11; scanned-in (I) 158: 1;160:7,18; 162:23; 71:10;130:16 168:14 164:23;166:3;168:24; Rundown (16) scenario (1) 174:3; 184: 1,1;191 :22; 16: 15,17,18;42: 18; 44:7 192: 11,22; 193: 18,19; 95: 17;96:4, 13; 100:21; scheduled (1) 198:9;206: 13;209:20; 101 :5,6; 103:24; Ill: 14, 181:23 211 :4;212: 1 ;214:23; 15, 16; 133: 12;146:23 scheme (1) 218:1,7;220:14 running (2) 138:1

Rights (2) 111:19;183:9 schemes (1) 58:13;176:20 runnings (1) 139:2

road (3) 54:14 scholarship (6) 203:20,21,21 runs (2) 32:23; 149:6,7,9,13;

Robbins (3) 96:11,12 186:21 49:17,20;189:22 run-through (1) scholarships (1)

role (2) 159:23 32:9 92 :18;142:4 Scholastics (1)

roller (2) s 58:17 113:25; 117:16 school (5)

Roman (1) same (23) 30:4, 12;31 :5; 178:8; 58:22 50:3;54:8;61: 18;67:5, 183:11

Ron (54) 10,1 0;70: 19;86:4;94:7, schools (1) 17:22; 18:4,6,9,11; 19:1, 19;111: 15;138:8;161: 19; 30:21 9,24;42: 19;52:21;55:3; 166: 16; 179:21; 181 :20; Sci (2) 79:8,16, 18;80:6;84:3; 192: 18; 196:25;199:24; 102:22;155:15 93:3;94: 14,17;96:7,21; 204:2;205:4;206: 12; science (4) 111:12,17;124:17,23; 219:22 86:2;156: 12;219:4,10 125:3,9, 14,19,23; 126:7, San (1) sciences (5) 1 0,13,19; 13 1: 13;132: 18, 30:25 31:3,10,11,13,15 19;134: 15;137:16;138:9; Sanskrit (1) scientific (4) 140:6,8;141: 16;150:4; 31:1 152:11;155:9,10; 151: 17; 155:20;160:2,8, Santa (1) 178:20 16;172: 11 ;203: 16, 17; 185:9 Scientologist (9) 207:7;208:2 sat (1) 36:8;91:22; 132:4;

Ron's (1) 41:5 171 :9;181: 11;200: 18; 104:6 satellite (2) 213:6,14,15

room (6) 56:10;70:11 Sci en tologists (17) 41 :4,5;68:4; 169: 14; satisfaction (1) 19: 18;91:20;100:20; 170:2;209:9 106:4 1 04:9;105:25;109: 18;

route (1) satisfied (2) 110:7;116:21;133:11; 119:24 120:4, 13 135:9,1 0;136:2;203:4;

routine (3) satisfy (1) 214:4,9,13,16 93:12;197:13,16 173:24 Scientology (319)

routinely (1) sauna (5) 13:22,23,25; 14:3,4,6, 96:11 49:23;50:2; 1 I 2:4; 12,15; 17:9;18:7,12;19:4,

routines (16) 130:16;154:12 I 0, 14, I 7 ,23;20:7,22,24; 16:9,10;93:7,8,13,15, saunas (1) 23:17;25:13,15;28:5,8; 21 ;94:5,7,9;95:11; 111:20 35:6,16;36:12,13,14; 102: 19; 193: 14;197: 12; save (1) 37:12, 15;38:5,6,9, 16; 216:12;217:2 108:22 40:3,24;41 :11 ,16,25;

Roy (2) saw (7) 42:1 ,8,14, 18;43:7;44: I ,7, 174:7,15 20: 13,13,15;170:22; 12;45:2,3,5,11 ;46:24;

royalty (1) 192: 10;195: 18;212: 12 47:6,8, 10,16;48:1 ;52: 19, 70:16 saying (12) 24;53:8, 10;55: 15,18;

RPF (5) 22:23;36:3;43: 10;65:7; 56: 10;58:15;59: 14,16; 180:3;181: 10;184: 18; 83: 12;84:2;87:22; 60:8,12, 16;62:8;68:21,

Q&A Repor·ting Services, Inc. [email protected]


23;69:25;70:9,11;71:23; 72:8,11 ;77:25;78 :4,8; 79:9;82:4, 12, 14;83:7, 7, 16;84:11,15;85:12,22,24; 86:6,21 ;88: 11,18, 19,22; 89:15;90:7, 15 ;93:9,1 4, 18,20;94:6,11,13,22;95 :1, 3;97:6;99: 10, 18,22 ; 100:3,8,16;101 :2,7,22; 1 02:7,15,23;104:2,11,15; 106:9,20;107:17;110:4,5; Ill: 16,17;112: 12;113:8; 114: 12,17; 115:4;120:7; 124:19,24; 126:4,12,13, 15,18;127: 1,6,23,25; 128:7,12,22;129: 13; 131:6,8, 14,17, 17,22; 132:5,6,20; 133:2,4,9,18; 134:8,21,24;135: 1, 12,22; 136:6,8,10,10, 14,18; 137:8,15; 138:2; 139:2,7; 140:13,25;141 :4,7, 13; 142:9; 144: 19;146:13; 149:15, 16;150:23; 151: 12; 153:7;156:7, 11, 13;157:24;160:11; 161 :7; 162:2,10;165:20;171 :2, 23;172:4,7 ,10,13, 18; 174: 17; 175:2; 176:20; 177:3,5,15; 179: 17;180:2, 12,17,19;181 :8; 183:18, 19; 184:20;185: 11,21; 186:8;187:11;191:25; 192:4,6, II, 14, 15,22; 193:7 ,16,25; 194:3 ,4,12, 13;195:6,6,17;196: 1,6, 15;197:3,7' 17, 19; 198:7, 11,17, 17,21; 199:15, 18; 200:1 0,22;20 1 :5,6,18,24, 25;202:3,9,20;203: I, 10, 18;204:3,6, 11;205:5,7, 11 ;206: 15;207:3;208:5, 17,19;210:9,12,21 ,22,23; 211 :7,19,20;212:5,10,21, 24,25;213:2,4,9,11 ;214:4, 6,11, 19;216: 10,14;218:3; 219:2,6,8;220:8

Scientology-based (1) 46:6

Scientology-hired (1) 91:21

Scientology-related (6) 46: I 1;58:11 ,20;60: 19; 63:6;191:11

Scientology's (18) 37:25;47:8,12;78: 16; 86:24;113:11 ;126:11; 135:4; 139:22;140:3,23; 141:23; 145:12;147: 16; 151 : 14; 15 8 :25; 171 :9; 202:12

scope (1) 220:21

(20) responses - scope



Scott (2) 176:8;183:23

Scouts (2) 70:21;81:13

screwed (1) 26:5

scribble (2) 64:19,20

scribbles (1) 64:21

Sea (1) 44:4

Sean (4) 188:8,9; 189:23;2 15:7

Second (13) 17:2;26:4 ;3 1:5;40:24; 111:11 ,19;116:22; 121:25;134:20; 162:6; 195: 14;212:13;214: 19

secondary (1) 214:19

secret (2) 38:8;62:8

secrets (1) 91:10

section (11) 109:7; 120:22; 144: 10; 145:2,20,21 ;146:4,22; 151:11;184:6,17

sections (1) 219:7

secular (18) 78:6;79:16, 18;80:5,14; 84:3;85: 14;86:9,17; 87:24; 116: 12;160: 13; 161:11 ;186:23,25;208:3, 13;218:3

secular-related (1) 78:11

seeing (3) 40:3;79:3;212:2

seeking (1) 178:18

seeks (1) 119:22

seem (5) 102:8;105: 15;133:2; 139:13;141:15

seemed (1) 192:5

seems (6) 16: 12;112:24;186:20, 2 1;197:21;205:2

sees (2) 151:12;194:4

self (3) 116:1,22;216:21

self-identified (1) 179:16

semantics (1) 86:11

semester (3) 32:1 ;33: 1;52: 1

Min-U-Script®

semesters (1) shall (1) single-volume (1) 31 :24 177:11 219:9

sending (1) share (2) sit (5) 26:25 92:21,23 41:4;56:6;137:3;

sense (8) Sheila (1) 194:11;210:25 85:7;92:20; 132:5; 37:14 site (6) 135: 16; 152: 11;161: 17; shifted (1) 14:3,4;34:20; 171:23; 185:25;203:14 31:4 172:1,8

sent (6) short (8) sites (3) 12:25; 13:3;26:2;71 :3; 36: 19;52:21;67:23; 14: 1,7;62: 13 182:4;188:2 93:7;109:4; 154: 18; sitting (3)

separate (2) 163:8;169:16 57:21;80: 19; 108:21 119:2;143 :14 shout (1) situation (1)

separ ated (1) 193:22 205:12 142:23 show (6) situations (3)

separated-out (1) 23:21;27: 19;72: 17; 217:3,9,15 142:25 114:25; 155: 17;171 :20 six (4)

separately (2) shown (1) 27:3;46:25; 109:7; 57:5;164:7 32:22 117:2

separating (1) shows (2) skill (1) 127:9 101 :4; 114:23 206:10

series (9) Shupe (6) skills (1) 37:9; 118:1 ;124: 17; 183: 14,20,22;184: 18, 216:16 128:3;138: 12; 169:8; 19;185:1 slight (1) 174:22; 184:3,20 Shupe's (2) 178:9

served (1) 186:12,17 slogans (1) 22:17 side (5) 43:11

Service (5) 30: 15;40:24,25;41 :2, I 0 slow {1) 42: 14;58:1 0;59: 15; sides (1) 144:9 60:1;84:11 41:1 small (2)

services (2) sidestep (1) 34:1;109:7 96:15,17 174:22 smaller (1)

sessional (1) Sight (1) 116:7 33 :1 45:14 smoked (1)

set(ll) sign (1) 96:8 20:3;21:4,6,8, 10,12; 9:2 smokes (1) 28: 15;47:21 ;73:25;74:3; signature (1) 215:18 80:5 8:25 so-called (2)

setting (1) signed (3) 38:8;136:15 78: 12 41:1 0; 182: 16; 183:1 social (20)

settled (8) significance (2) 19:15;31:3,9,1 1, 12,14; 43:22;44:21 ;45:21; 131: 11;195:6 58:3,14;66:23;113:11,20; 46:8;59: 18;76:23;81 :2,2 significant (1) 130:22,24;151 :5; 178:20;

settlement (5) 14:25 198: 15,24; 199:5,7,9 59: 19;76:25 ;82:6; signing (1) societies (1) 159:3,4 41:13 151:20

seven (2) similar (15) society (5) 46:25; 117:2 17:20,21 ;20:4;38: 13; 80:23;135:3,24;

seven-page (1) 77:23,24;113:6;114:19; 136:11;199:10 182:13 124: 19;132:19;133 :4; sociologist (5)

seventh (12) 139:21 ;163:21;193 :8; 3 1:14;70:22;130:25; 118:3,17,17,21; 119:2, 204:2 178:4;183:15 13;120:3,11;121:11,16, similarly (1) sociologists (1) 18;122:15 205:13 178:22

several (4) simple (3) sociology (10) 26:6;37:23;46:7; 13:25;21 :3; 113 :] 7 30:2;33 :8,9,1 0,12,14; 158:12 simplest (1) 44: 16; 180:9;18 I :25;

severely (1) 14:13 2 17:11 133:9 simply (5) soldier (1)

sex (2) 85:13;86:9;146:11 ; 207:21 116:24;184:12 148:1;161:8 solidify (1)

shading (1) single (1) 151:14 77:11 151:20 Solution (3)



150:25;151: 13;153:4 somebody (10)

44:9;54:19;65: 12;70:6; 74: 18; 113:21; 118: 10; 127:2; 130:1; 149:21

somebody's (1) 157:15

somebody-Scientology (1) 195:11

somehow (3) 101 :23;107:16;133:23

someone (7) 38: 18;90: 18;112:25; 141:2; 149:25;202:3; 210:5

someplace (2) 14:19;183:11

sometime (1) 59:21

sometimes (6) 1 02:22; 142 :20; 17 4:20; 175: 1;188: I ;205: 19

somewhat (2) 97:23;177:16

somewhere (4) 96:25;111:1;175:7; 185:14

soon (1) 95:16

Sorry (13) 12:22;16: 10;147: 10; 152:25;171: 12; 178: 15; 190:3,3,6, 13, 15;208 :22; 2 15:22

sort (20) 18:24;23: 19;35:5;37:6; 44:23;54:8;64: 18;70: 15; 82:9;113:15;124:2; 139:2; 141: 14;153:4; 193:22;196: 12;197:18; 202:1 ;207: 13;208:2

sorts (1) 95:11

sound (2) 150:3,8

sounds (13) 33: 18;50:12;54:17; 63:2;79:24; 126:6; 131:11 ;157:1;172:17; 186:7,9;197: 14;214:4

source (8) 113:13;119:2,3,5; 180:5;198: 16;200:5,17

sources (2) 19:16;63:24

SP (5) 198: 19,23; 199: 16,22; 200:1

SP/PTS (1) 198:18

space (3) 84:7;118: 10;120:9

spare (1)

(21) Scott- spare



36:25 speak (5)

99: 12;100: 10; 128: 14; 148:3; 199:10

speaking (6) 48:3;11 0:22;174:19, 24;175:5;216:12

Speaks {1) 199:4

species (1) 117:1

specific (13) 13: 18;28: 12;47:20; 83: 1;99: 11; 123: 16; 126:8;162:5,12; 165:14; 177:21;210: 15;216:1 0

specifically (9) 22:4;69: 14; 126:11; 137:13;142: 18,23; 144: 18; 181: 1;199:6

specifics (5) 148:2;162: 19; 17 1: 12; 192:7;199:10

speculate (1) 84:13

speculation {1) 85:7

speculative (1) 84:5

speed (1) 29:15

spend (3) 25:9;57:21;107:22

spent (10) 25:22,24;26:5, 1 0; 27: 12;33:21;65:18; 166:13,21 ;207: 16

spirit (2) 117:2,4

spiritual (14) 118:4,11 , 18,18,20; 120:21 ;121:5,18,24; 123:12,21 ;124:2;212:9, 11

spirituality (2) 123:10;161:3

spoken (3) 23:4;63: 17; 174:7

spots (1) 110:8

sprayed (1) 43:11

Sproule (1) 37:14

SPs (I) 199:19

spur (1) 208:4

stack (2) 104:18;148:22

staff (2) 29:3,7

staffed (1)

1\fin-U-Script®

104:8 S-T-E-P-H-E-N (1) 67:19;104:24;111:6; stand (3) 10:15 112: 14; 193:22; 197: 14;

44: 13; 137:3;194: 10 Steve (3) 215: 1;216:4;217: 14 standard (8) 9:6,16;189:25 student's (1)

19: 17;70: 10,13, 14; stick (2) 32:8 78:20; 197:6; 198: 16; 29:10;93:4 students' (1) 204:6 Sticky (1) 217:19

standing (1) 196:23 studied (1) 110:3 still (10) 30:24

staple (2) 65:20;87:12,12;88: 11; studies (5) 179:1 ,3 96: 16; 123 :6; 132:1; 18:24;31: 10; 157:9;

stapled (1) 160: 13;196:24;215:15 180:9;187:10 57:5 stipulate (1) study (9)

stapler (1) 9:3 30:25; 127: 18,18; 128:5, 1 03: 11 stop (5) 6;185:7;214:3,5;217: 11

star (1) 18:4;64:20; 142:10,13; studying (2) 98:4 200:25 70:8;177:2

start (5) stored (1) stuff (1) 52: 13;64:19; 134: 12; 112:2 140:25 144:15;193:5 stories (3) stumbling (1)

started (14) 100:22,23; 183:21 112:15 25:3;31: 1 ;32:8;45: 16; story (2) subheading (1) 46:5;65: 13, 17;66:8;95:4, 95:1;208:12 118:25 17;96:9,19;144:16;148:8 straight (8) subject (3)

startled (1) 19: 14;20:6;110:4; 76: 14; 149:23; 151:23 135:7 112: 12; 113:1 0; 126:4; subjects (1)

starts (3) 182:25;204: 16 71:1 116:22; 144:24; 194:19 strain (1) sublicenses (1)

state (3) 153:8 58:8 95:2;125:8;148:11 stream (4) submission (7)

stated (1) 33:3,8,13,15 12:24,25 ;3 7:25 ;58: 6; 186:12 stream-back (1) 145:12,17,18

statement (16) 33:4 submissions (9) 27:23;37: 17;41 :5,7; Street (4) 11: II ;34: 13,16;38: 14, 45: 19;56:21 ;97:4; 62: 11;89:20;90: 1; 14;39:3;55:22; 101 :4; 112:24;136:24; 138:21; 109:21 152:3 151: 14,17;152:4;177:25; stresses (1) submitted (6) 178:11;208:10 220:17 11: 16;37: 16;45: 19;

statements (9) stressful (2) 55:21;98:5,21 52:4; 107: 18; 138:12,15, 217:9,14 subordinate (2) 24;140: 12; 156:17;161 :8; stressing (2) 58:7,7 177:11 138:8,18 subsequent (1)

States (5) strike (1) 89:22 59:11 ;60:2,3,6;85:22 134:5 subsequently (2)

status (41) strong (3) 38:19;183:10 56:11;62:5;80:11,25; 131 :5; 153:7; 177:4 subsidiaries (1) 81:7,23;83:9,9,17;85:23; stronger (4) 58:6 86:6,22,22;87 :2,3 ,3 ,8; 78:2;124:23; 132:21 ; sub-social (1) 88:5,8, 12, 16,20,23;89:2, 177:11 149:16 4,7,7;90:7, 12;92:3; structure (4) substance (3) 145:13, 15;146: 15,16; 28 :6;52: 18;78: 16; 53:17;220:5,9 158:15,24,24,25;159:7, 139:3 substantiate (1) 10,14 struggle (1) 140:19

stay (6) 178:21 subverts (1) 49:25;50:1;67:21; struggling (1) 199: I 147:2; 170: 14;220:3 139:25 success (8)

steep (2) Stuart (1) 96:24;97: 11 ,15,16,18; 17:3,6 173:11 115:9; 151 :24;157: 10

stem {2) student (7) suddenly (1) 200:7,9 16:21;29:2,6;32:24; 44:5

Stephen (5) 181 :22; 182:20; 195:25 sue (1) 8:5;9:11;10:15 ;178:12; students (12) 76:24 180:11 32:3;44: 16;66: 18; sued (2)



38:10;76:17 sufficiently (1)

182:18 suggest (2)

105:22; 134:8 suggested (1)

51:20 suggesting (1)

88:16 suggestion (1)

212:8 sum (2)

158:14;205:9 summarize (2)

54:17;124:13 summarized (1)

162:1 1 summary (2)

27:16;124:16 supernatural (7)

78:21,24;79: 11 ;80:3 ; 83:23;84: 19;88:24

supervised (1) 54:12

supervisor (6) 119:14,21 ;121:8; 201:16,16,18

supplied (1) 23:24

support (10) 31:20; 142: 18; 143: I ,5; 144: 1;154:2;157:20; 158: I 0; 162:6; 166:1

supportive (2) 153 :3; 186:24

suppose (2) 102:5;187:4

supposed (9) 111:25;115:24,25; 119: 17,24; 194:7,8; 195:9; 202:4

supposedly (1) 207:12

suppressant (3) 14:2;43:20; 141:7

suppressive (5) 38: I; 141 :3; 199:16,20; 200:16

supreme (4) 1 I8:6,12;119:17; 123:11

Sure (103) 1 I: I 9,21 ;12: 11, 13, 16; 15:7;23:3,4;28: 13 ,25; 29:5 ;32: 10,1 0;35:7 ;40: 8; 41: 18;42:15,16;43:5,5,9; 45:21 ;49: 16;53: 15;54:20, 21 ;60:3,3;61:23;63: 17; 65:25;70:7;74:20;77: 13; 82:25;85:3;89: 1,3;97:8; 101:9;106:25;1 07: 13,24; 108:17;109:15;110:16; 111 :2;114:22; 116:9, 19;

(22) speak - Sure



120:25; 121 :7; 122: II ,13; 126: I ; 127:5; 130: 13; 134: 13; 136: 17;141:11; 143:8, 12;144:23;145:9; 148:3; 152:15;156:22; 158:6, 16; 162:24; 163 :2,6; 167:4; 169:2,2; 170:11 ,22; 171:3,6, 10;172:7; 173:2, 3;174:4,5;175:3,3; 179:4; 188: 16; 189:6;192:12; 193:24; 196:2, 13;197:22; 198:8,8;204:4;208:25; 210:21 ;211 :14;212:24; 221:6

surely (1) 173:1

surface (1) 208:11

surprise (3) 61:22; 105:20;178: 12

surprised (5) 18:13 ;62: 18; 109:1; 167:12;221:3

surveillance (1) 187:11

survival (9) 118:23;119:4,22,24; 121 :9,10;122:2,4,4

survive (4) 118:18,19,23;119:1

Susan (I) 187:10

Swap (I) 57:4

swear (1) 9:8

switched (1) 114:14

switching (1) 19:20

Syracuse (1) 183:5

system ( 6) 4 7: 16;60:4, 15 ;80:9; 128:3;180:20

systematic (3) 139:3;156:5,14

systematically (1) 156:8

systems (1) 128:6

T

tabbed (1) 15:23

table (2) 145:19;182:5

tabs (1) 15:24

talented (I) 119:8

talk (38)

1\[ in-t.:-Script®

29:2,6;50:16;63:7,11 , 37:22; 151 :10,24; 16;76:6,12,16;100:24; 14;65:2,3;66:24;71: 18; 203:19;205:6,-1 5;211:18 128: 18,20; 130:5;132:25; 77:15, 18;79:22;90: 18,24; teens (I) 134:9;139:20;220:23; 102: 19;104: 10;110:5; 180:22 221:4 112:8;118:11 ;124:9; Tel (2) testifying (1) 128:25; 131: 16; 132:2; 177:9,9 86:19 137: 14;141: 17;142:25; telephone (3) testifyN arconon (1) 143:6;150:6,9; 151 :6; 27: 12;43: 1;215: 12 28:5 152: 12;163:3;174 : 15; telling (4) Testimonies (2) 175: 12;192: 19;193:21; 67: 14;79:24;114:5; 35:14;45:7 196:18 137:3 testimony (9)

talked (35) temperate (2) 27:25;34: 11;68:24; 23:6,9;71: 14;90:14; 209:22,23 126:24;140:21;141: 12; 100:18, 19,19; 103: 10; ten (I2) 172: 15;174:1;183 :23 111:10;112:11;114:15; 27:6,11 ;47:1;52:23; testing (1) 116: 16;120:20;121 :3 ; 53:1 ;54: 19,25;70:5; 156:8 123:6; 125:22; 126:6,9; 106:7,18;166:22;219:4 testings (1) 141 :24; 142: 16;143: 17; tenet (2) 95:23 145:24;147:9; 149:1; 200:5;201 :5 tests (4) 155:7;157: 17,19;158:8; tenets (1) 95:25; 152:8;155:9,10 161: 13;162: 15;165:5; 208:17 thanks (4) 167:3;214: 15,16,22 tenure (6) 26: 18;179:4;189:5;

talking (18) 33:3,4,8,13,15,16 . 221:9 13:23;19:5;27: 12;48:7; tenured (1) theology (2) 71: 1 ;77:6; 105:4; 107:7; 185:3 186:22;187:10 121 :22;129: 17;136:5; ten-volume (1) theories (1) 140:2;149:22;155: 18; 219:5 181:8 156:3;161 :3;180:7;195:5 term (24) Therapeutic (3)

talks (10) 14:4; 17:6;32:19;72:9; 154:20;193:6,7 78:24;115: 19;118:3,5; 79:2;114:16;116:24; therapy {2) 123:21 ;138: 16;153: 13; 119:9;120:7;131 :18; 50:3; 149:15 180:15;184:11;195:19 134: 16;174:21 ;175:6; there'd (1)

target (3) 193: 16;196: 1,1;200: I ; 157:23 194:6,7;199:2 202: 15;204:1 0;205:6,9, therefore (1)

tax (10) 13;211: 19;212:2 138:4 55:24;60:7;62: 14,23, terminology (I) There'll (1) 25;81 :24;82:4,9,21 ;86:23 85: 11 109:21

taxes (4) terms (59) thereof (1) 61:7;87:8, 11 ;89:7 13: 14,17;14:2,5,14, 15, 58:8

tax-exempt (10) 23;18:24;19: 17;25: 16; there're (2) 55:24;56: 14;59: 16,22; 26:20;48: 12;54:4;55:5; 143:4;210:6 60:9;87:2;88:5;89:7,9; 62: 19;63:3;68:20;69:3; there'smore (1) 92:3 73:2,18;80:22;89:8; 161:23

T-E (1) 97:23;98: 16,22;99: 13; Thereupon (16) 205:22 108:7; 109:5;114: 14; 8:1;57:24;68:3;72: 14;

teaching (6) 116:17;117:25;122:3; 85:4; 103:5; 122:25; 31: 13,25;32:6;33: 17; 126:3,16, 17; 127: 12, 19; 143: 18; 163: 13; 169:10, 192:21;220:1 128:7; 131 :7;132:25; 13;170: 1;171:17;173:21;

teachings (3) 140:2;145:24;150:2,10; 209:8;215: 11 192:3,18;202:20 152:9; 156:7; 157:3; Thetan (1)

tech (3) 181 :9;186: 13;192: 11,14, 79:2 201: 6;205 :20,21 14;198:17;214:3;215: 1; T-H-E-T-A-N (1)

T-E-C-H (1) 219:18;220:5,9, 15 79:3 205:22 terribly (1) thinking (5)

technical (2) 36:18 83: 18; 122:3;140: 15; 32: 19;206:9 test (4) 144:17;207:10

techniques (9) 102: 13; 109:22,23,25 third (3) 96:2; 124:24; 126:3, 12; testified (7) 17:7; 116:24; 137:20 135: 1;136: 14;192:1; 9: 13;44:24;47:5,7; Thomas (1) 201:2;205:10 68:8;146:8,10 184:22

technologies (1) testify (20) though (8) 58:11 9 :24;22: 18;28:24; 65:8;70: 14;83: 11 ;

Technology (7) 37:16;44:22;47:9;51 :2, 85:25; 158:20; 177: 14;



183:22;209:1 thought (19)

14:25; 19:24;20:3; 24:11 ;36: 12;41 :6;52: 13 ; 74:4;92: 17; 105: 13; 113:5;117:2;141:18; 144:1 0;174:23;182: 19; 184:25;197:10,10

Three (7) 16:22;30:9;31 :23,23; 46:25;201: 10;209: I

throughout (2) 88:18;97:2

throw (1) 158:20

thrust (1) 171:4

Thus (1) 58:12

tick (1) 35:15

tie (1) 126:2

times (7) 32: 11;46:23; 158: 12; 163:20;170:25;171:1; 174:23

tiny (I) 33:22

tire (I) 102:1

tissues (1) 112:2

title (2) 182:1;200:4

titled (1) 193:6

today (10) 9:23;56:6;71: 1 ;80: 19; 117: 16; 149: 11;150: 18; 151:20;165:5; 167:3

together (1) 174:15

told (7) 48: 18;64:7;70:24; 71 : 15; 120:23;121: 17; 159:16

Tom (2) 43:3,10

tone (1) 177:13

took (5) 24:25;25:6;26:2;82:25; 207:15

tool (2) 102:15;109:20

top (3) 16:3;115:7;122:5

total (4) 26:9;158: 14;203:20; 205:9

touch (8) 18:2,3;36: 17; 124:1;

(23) surely - touch



161:4; 196: 19;197:15; 198:3

touched (3) 35:6,15;124:20

touches (1) 122:14

touching (1) 198:4

Touretzky (1) I77:4

toward (3) 113:4;119:15;150:23

towards (2) 138:10;195:9

TR (12) 14:12;16:9;17: 17;93:6; 154:20;193:6,7,17,20,21' 24;194:2

TR5 (2) I6:11;93:11

TR6(2) 16:1 1,12

TR6b (2) 195:20,22

TR8 (2) I95:25,25

TR9 (3) I95:19, 19,21

tractor (2) 196:I9, 19

trademarked (I) 70:17

traditional (1) 152:11

trained (3) 130:21 ;213: 14,15

training (27) I6:8,9;28:3;50: I8; 71:21 ,25;93:7,12,13,15, 21 ;94:5,9;95: 11 ;98:22; 129:7;137:6;142:6; 193:14;194:16;197:11, 13,I6;213:8,10;216: 12; 217:2

transferred (1) I24:25

transmitting (1) 199:11

transnational (1) 78:9

TR-as (1) 194:5

traumatic (1) 195:7

treasonous (2) 115:21 ,21

treat (1) 81:24

treating (3) 60:1;82:1;89:8

treatment (2) 49:4;209: 14

treatments (1)

!\Ti n-U-Scr ipt®

135:20 136:4,7;139:3; 156:14,25; 59: 11;60:2,3,6;85:22 tremendous (1) 157:25;175:23; 181 :5,7; universe (3)

152:6 185: 19;187: 15;194:5; 29:18;117:1;119 :3 trial (20) 2I4: 1 university (19)

27:25;51: 16;64: 12; turned (1) 13: 14;14:9;30: I ;31 :22; 107:21 ; 108:3;126:24; 183:3 32:24;33:5,5,7, 14,17; 133: 1;141:20,24; 149:24, twice (2) 63:22;75:23;177:9;178:4, 25; 150: 18; 154:5; 159:22; 27:1;44:14 7;180: 10; 183:4,5; 185:9 162: 16; 165:3; 167: 13,18; twin (3) university-appointed (1) 192: 13;208: 19 196:1, 1;198:1 I86: 1

trials (1) two (39) university's (1) 166:16 15:24;I7:16;26:20; 22:3

tried (5) 27:1 ;30:6, 16,18,20,24; unless (6) Il:I7;53:1I;86:25; 32:25 ;36: 14;3 7:6;40:22; 63 :25; I49:21 ;152: 19, 142:3;I53:25 46:25;74:4;98: 14; 101 :3; 19;173: 12;206: I

tries (1) I 03 :9;110: 16;117:4; unnecessary (1) 131 :19 118:8;122: 10; 138:7; 24:13

trip (1) 155: 18; 156: 13; 160: 18; unpleasant (1) 27:1 161:10; 164:5;171:5; 184:3

trips (1) 172: 17; 176:4;178:9; unrelated (2) 184:10 I80: 16; 182:23; 188:4; 2I9:2,6

trouble (9) 206:8;207: 16;214:13,15 unresolved (1) I9:I6;53:13;97:I; two-year (1) 133:10 11 3: 13; 198:16;200:5,17; 32:18 unusual (1) 20 1:9;216:8 type (14) 128:6

TRs (18) 20:22;25: 13;34:3; up (76) 14:II , l1 ;16:13;17:21; 46:23;50:22;54: 19; 11 : I,5; 17: 14,20,25; 93:9;112:22;113:7; 62:20;77:3;81 :I9; 19: 13;25:6,7,7,23;26:5, 136:25; 193: 12,13; 112: I7; 129: 19;I40:7; 13;29: 15;33:7, 13,24,25; 194: 16,23;195:5,9,12,14, 161:2;2I7:8 41 :4,9,19;42: 10;43: 13; I5,16 typed (2) 48: 13;65:8;68:6;71: 13;

TRs-well (1) 19:9;41:9 86:7;95: 15 ;97:2,5;1 04:6; 194:4 types (2) I12:3,16;113:5;114:23,

true (54) 53:25;220:18 25;116:2; 120:3,10,12, 19; 30: 19;34:23;48:22; I22:8; I26:2; 127:4; 49: 11;50:4;51:24;56:5; u 129:9; 133:20; I37:3; 59: 17;65: 11, 19;69:23; 147: 17,19,20; 149:4,5,10, 81:9, 12;82: 16;88:2,17; ultimate (1) 24,24;150:21 ;151: 11; 89:10;91 :13, 16;94: 15, 18; 90:10 152:9,20; 154:4;I55:2; 97:25; 102: 13;105: 16; ultimately (2) 163 :20; 164:22; 172:1; 109: I0;124:9; 125:4,16, 80:20;92:8 181 :2I ;I94: 10,10,13,13; 20; 126: 15,22; 127: 17; um(1) 197:9; 198:2,6;202:5; 128:5;13 1 :16;133:6, 15; 20:13 215: I6;216:4;221 :3 138:6,25; 146: 14; 148: 11; unclear (2) upon (55) 150:19,19;155:21; 20:19;6I:2 18:9;19:21 ;24:6;29: 15; 157: 18; 165:8;171 :25; uncommon (1) 35:6;39: 14;40:9;56:23; 172: 14,19; 173:25; 123:25 64:2,6;68:9, 16,19;76:3, 187: 16;189:2;203:3; under (8) 12; 77 :22;79: 18,20;83 :6, 218:15;219:6 8:21;35:13;80:1,4,I1; 10, 16;84:3;85:23;86:2,6,

trumps (1) 118:21 ;196:8;200:4 18;87:2;88:5,12, 16,20; 78:15 undergraduate (1) 89:2;92:24;98:23;102:7;

Trust (1) 30:1 108:8; 124:20; 126: 15; 58:15 underling (1) 127:2,21,21 ;142:23;

try (16) 207:13 145: 10; 146:3; 147:I1; 32: 15;49: 15;52:13; understood (2) 150:16;152:10;155:11, 54:17;116:2;138:9; 10:9;150:14 24; 158: 17; 160: 15; 154:7; 157:6; 174: 19,25; unfolded (2) 164:11,19;192:6;203:16 176: 14; 177: 12; 184:25; 37:1;80:22 upper (3) 186:25;201 :22;218:10 unfortunately (1) 38:7;117:3;138: 12

trying (25) 144:14 upper-level (1) 26:9;40:8;67: 11 ;85: 17; unit (3) 116:18 99:9,17; 101 :22,23;105:2; 36:9,10,13 Ups (5) 114: 15; 132: 14; 135: 12; United (5) 19: 13;I13: 1 0; 198: I 0;



217:7,13 upshot (1)

59:20 urge (3)

118: 18, 19;119:I5 urged (1)

118:4 use (31)

17: 18;24:13 ;40:23; 52:23;55:3;58:9;64: 1; 76:11 ;78: 1 ;98:2; 108: 13; 114: 16; 116:24;119: 10; 120:9;135:4; 139:17; 144: I ; 15 8: 18; 163: I7; 168: I3; I86: I8;200:1; 203: 19;204: I2,13, 13; 2 10:19,24;211:19;21 8:4

used (24) 8: 16;40:9;72:22;74: 18; 75:5;79:8;97:24;98:8,19; 104:21 ;107: 16;109: 14, 20,24,25;114:9;116:23; 174:20,24; 175:6; 177:6; 196:18;205:13;211:22

used-the (1) I14: 17

useful (3) 15:2;1I2:25;197:8

uses (9) 52:21;87:14;115:4; 126: 12; 138:8,9; 152:1 ,2; 193:16

using (15) 16:23;45: 16;46:5; 70:16;86:7;88:11;96:21; I 09:5,7; 110:22; 121:9; I35: 18; 177:5;203: 17; 205:8

usually (2) 32:21;216:6

v vague (1)

145:14 vaguest (1)

145:24 valid (2)

220:10,13 value (5)

111:18;135:2,1 0; 147:18;151:12

values (11) 19:20,22,24;20: 1 0; 114:11 ,13,23;118:2; 136:22;220: 1 '1 6

var (1) 102:24

variation (5) 109:25; 197:21;203:3,6, 8

variations (3) 109:20;1 1 0: 1; 197:25

(24) touched- variations



varies (I) 102:24

various (12) 32:11;38:9;39:2;43:8; 62:7,13;82:6;111:18; 115: 13;135:20;187:5; 216:9

vast (4) 28:2;71:20;137:5; 142:5

Vegas (1) 45:15

verify (1) 14: 14

version (9) 73:14, 14, 15;74:9; 80:24;93: 1; 113: 17; 116:8;179:13

versions (1) 168:14

versus (13) 35: 10,18;37: I4)23; 38 :3;4 I: 19;42: 13,24; 43:1 7,25;86: 19; 146: 17; 212: l 0

veterinarian (1) 42:4

veterinary (1) 42:3

via (1) 215:11

view (4) 187:17,19, 19,21

views (1) 177:15

VIII-2 (1) 58:23

violated (1) 42:8

violations (1) 38: 10

vision (1) 135:1

visions (1) 138:20

visitation (2) 36:4;40:21

vitamin (2) 50:3;111:24

vitamins (2) 111:22;154:12

vocal(2) 176:18,25

w

waiver (1) 8:11

Wales (1) 183:11

walking (3) 198:1,3,5

wall (10)

l\:lin-C -Script@

18:2,2;62: 11 ;89:20; 72 : 17;77:23;80:22,22; Wollersheim (1) 90:1 ;197: 14, 15,15; 198:2, 87:25;89: 19;90:2 1 ;95:9; 38:4 6 107:3; 112:1 1 ;113:7; Woods (2)

Walton (1) 116:19;123:10;132:11; 37:13;43:18 32:20 137:1,2, 12; 141 :4;150:24; word (19)

was-and (1) 153: 12;171 :20; 193: 15; 17:8,8,12;81:17; 208:6 197:18;203:3 112:15;119:10;165:15;

Washington (2) whatsoever (2) 174:19,21 ;201:11 ,12,19; 92:12,13 49:3;70:25 2 11: 18,21 ,22;212:5;

waste (1) whole (11) 214:24;215:2;216:5 160:23 37:9;53: 17;97:2; wording (1)

Watch (2) 108:23; 114: 12; 137:9; 94:7 179:1,3 138:11 ; 139: 16; 174:22; words (11)

Waterloo (6) 184:6; 195:22 17: 14;50:5;82:5;125:7, 33:5,11 ; 178:4,5, 7; who's (7) 17;138: 17; 139:25; 177:5; 180:10 113 :21 ;115:20; 174:7; 204: 12;216:7;218:7

way (66) 177: 1,8;180:8;184:23 work (36) 10:6;12: 10; 13:25; whose (1) 11:10;24: 13;27:7;31:6; 15:23 ;20:2,6;21 :23; 74:24 33: 18;34:3;39: 13;42:2; 22:24;56: 1;5 8: 18;59: l; widely (2) 51 :8;64:24;66:8;71: 13; 61 :22;67:2;72:5;80: 10, 18:15,18 109:25;110:1;115:5,7; l3;83:I ;84: 17;97:9; Wikipedia (2) 119:24; 157:3;165: I 1; 100:2; I05:22;109: 12; 77:2,5 166:20;175:24;179: 17; 110:6;114:19,24; 116:3,5, wild (1) 181:10;182: 19;183: 16; 6,9;124: 13;132:3;134:7; 33:25 185: 11;186:2,4,21;187: I , 135: 13,21 ; 137:22,25; William (2) 4,5,8,12,24; 199:9 138: 13,23; 139: 1; 150: 10; 95:3;148:6 worked (5) 156:5;175:24;176:21; Williams (3) 18:14;23: 12;30:8;36:9; 200:24;20 1: 1 ;206: 14,17' 46:3;172:20;174:2 75:24 18;207:2;208: 12;209:21; Wilson (1) working (7) 210:8,12;212:3,18,22; 37:14 26: 10;36: 15;136: 10, 217:4,5,6, 15;218: I, 17,20; wind (2) l 0; 196: 11,20;202:9 219:19,20;220:11 86:7;95:24 workplace (3)

ways (8) wins (1) 42:3,6;44:10 38: 12;86:25; 113:5,6; 120:9 works (17) 114:8,19;139:4;177:2 WISE (3) 18:9;94:17;125:2,8,19,

weak (1) 45: 11,16;46:2 23;126:8, 14,16; 132:18, 110:8 'vithdraw (1) 19; 137: 17; 141:16;

we!J (10) 220:20 146:23;160: I ,8, 15 14:1 ,3 ,4 ,7, 13;34: 19; withholding (1) World (5) 62: 13;17I :23; 172:1,8 120:19 4 1 :25; 149: 16; 176: 19;

weed (1) withholds (7) 187: 14,1 8 26:24 120:3,6,10,12,17,18; worse (2)

weeding (1) 165 :17 186:23;199:12 26:24 within (7) worth (1)

weight (2) 106:7,18;143:25; 122:1 188:5;195:22 157:7;159: 12;192:2,19 write {12)

well-being (1) without (5) 26: 16;85: 13; 115: I 0; 151:22 74:4;118:20;135: 18; 120:2,3,9, 12, 19; 179:11,

well-educated (1) 203: 16;207: 15 ll ;202:5;210:4 186:14 witness (37) write-ups (1)

well-known (2) 9:20;15: 17;37: 16; 202:13 193:24;207:8 40:14;44:1 2,13;57: 11 , 15, writing (3)

weren't (2) 18;58: 1;59:7;74: 14;85:6; 27: 17;120: 10;183:2 141:11;192:7 90:4;94:4;108: 12; 117:11' writings (8)

whatnot (4) 15,20; 142:2;143: 12; 95:20;125: 14;150:5; 50: 17; 116: 14;152:8; 144:23; 145:1 ;160:5; 165:19;174: 11;202:25; 192:25 161: 16;162: 18;163: 16; 203:2;207 :9

what's (43) 165:8; 169:6; 173: 18; written (21) 10:23; 12:4; 16: l ;17:2, 188: 16; 191:9; 199: 18; 34:24,25;38: 18;40:20; 7,21 ,25;27: 19;29: 16; 202:23;203:13;215:17,23 41 : 14;52:21;74: 18; 37:11, 17,19,2I ;41 :24; witnesses (2) 131: 15;148:6;153: 12; 42: 12,16,22;45:9;61 :4; 23:9;41:2 172:3,10,15; 177:5,12,15;



180: 13; 181:21; 182:23; 203:3;214: 18

wrong (5) 102:9; 184: 10; 199:2,3,3

wrote (14) 176:3,6;177:23; 179: 16;180:22; 181: 10; 182: 14, 15,20; 184:24; 207: 11;21 8:22;219: 1,10

y

year (7) 33:6,12;45:25; 101: 10; 176:4; 178:9;214:2

years (27) l 0: 17; 16: 18; 18: 15; 22:2;30:5,6,25;32:25; 33:23;70:8;73:9;76: 1; 90:23;96:22;105:22; I 06:7, 18;127:23; !51 :23; 152:4;156: 10;178:21; 181: 18; 182: 17;207:9,16; 213:23

yelling (1) 137:3

Yesterday (11) 21:11 , 13;24: 15,20,21; 25: 19;26: 12;27:5; 166:24;167: 16; 191:20

York (2) 170:25;171:1

z Z-A-B (1)

178:14 Zablocki (1)

178:17 Z-A-B-L-0-C-K-1 {1)

178 :16

0

07 (1) 153: I

0737 (1) 149:3

0758 (1) 149:3

0760 (1) 163:18

0767 (1) 163:18

0774 (2) 150:21;152:23

0776 (1) 150:24

0780 (2) 151:16;153:18

0793 (1) 152:14

0797 (1)

(25) varies - 0797



150:2I 0798 (1)

147: 15 0801 (1)

147: 15 0802 (1)

146:21 0808 (1)

I46:22 0809 (1)

I45 :11 0820 (1)

I45:12 0821 (1)

144:24 0834 (1)

145: 1

1

1 (23) 8:2; 10:22; 14:12;16: 10; 34:3,12;35:4;52:8;69:20; 71 :10;93:6,9,19;94: 16; 126:23; 134:6;140: I9; 142:19;154:20;169:17; I72:9, I6;I93:5

1:08 (1) Il7:21

1:25 (1) 117:2 1

10 (3) I 04:3;105:6;1 08:6

10:00 (1) 24:22

100 (1) 86:17

11 (5) 47: I ;103:7, 16;105:11; 108:6

11:00 (1) 25:7

11:16 (1) 50:7

11:17 (1) 50:7

11:41 (1) 68:2

11:58 (1) 68:2

114 (1) 196:10

12 (12) 47: I ;113: 18,20;123: 1, 3; 168:5;169:23;170: 13; I 9 1: I9;198:22,23,24

120 (1) 122: 1

1-28 (2) 58:5,2I

12-step (4) 123:24;124:4,6,10

12th (1)

t\'lin-t:-Script®

29:I1 1999 (3) 203:25 13 (4) 37:24;38:2;40: 19 250 (2)

47: I ;143: 19;149:3; 166:10,11 150:15 2 26 (5)

136 (2) 169: 12,20; 170: 14; 56:10;60:18 2 (37) 191:19;206:13

14 (6) 11:6;12:6, 17;13:9, 19; 269 (1) 47:1;113:18,20 ; 16: 14;21: 17;26:21 ;28 :2, 200:4 150:20;I52:22;157: 12 24;52:8;69:20;70:2; 27 (4)

1-42 (2) 7 1: 10,19;73:2,8,17; 171: 18,20;172 :2,9 58:5,22 104:20;124: 13 ,16; 28 (2)

15 (4) 125: 18,21; 126:5; 137:4; 173:22,24 46:23;47:1;147:14; I40: I9;I42:16,19; 29 (1) 148:5 143:25;144:6;152:18,21; 209:25

16 (6) I58:8; 163:7;I64:4,6; 47:1 ,3;146:21 ;147:4,6, 166:2 3 I1 2:05 (1)

160 (1) I43:21 3 (16) 130:16 2:15 (1) 16: 19;23:21 ;24:2;28:9;

167-acre (1) 143:21 29: 12;52: 13;54:16; 151:8 2:54 (1) 68: 10;71: 14,16;1I2:9;

17 (2) I69:9 145:25;148: 14;170: 18; 145:11;146:11 20(6) 196:5;2I9: 17

18 (5) 25: I 0;38: 17; I 05:22; 3:00 (1) 143:20;144: 16, 17,24; 163: 15; 164: 18; 178:21 169:9 145:8 2000 (2) 3:30 (1)

19 (4) 45:23;214:2 24:22 38: 17;163: 14;164:8,16 2000s (2) 3:31 (1)

1902 (1) 88:3;105:1 I 89:I5 207:10 2001 (2) 3:33 (1)

1950s (1) 21:21,22 I 89: I5 95:19 2003 (1) 30 (1)

1960s (1) 45: 14 209:25 98:20 2004 (7) 31 (1)

1966 (2) 13: 16;21 :20;73: 15, 18; 2 I0:1 95:2;96: 19 93:5;98: 12,15 32 (1)

1970s (1) 2008 (4) 210:2 98:20 88:4;98:3,8;107: I5 33 (1)

1974 (1) 200-item (1) 210:3 105:7 109:17 333 (1)

1975 (2) 201 (1) 193:20 30:1 1;3 1:20 212:23 34 (1)

1979 (2) 2010 (2) 210:4 151:21;153: 16 45:23; 174:3 368 (1)

1980s (2) 2011 (2) 195:24 98:20;1 16:11 22: I0;45:25 396 (1)

1983 (2) 20th (1) 154:20 31:2 I;32:12 207:6

1984 (5) 21 (6) 4 32: I7;35: 10,13; I 05: I 5, 20:2,2;169:I1 ,17; 19 170:13;191:19 4 (18)

1989 (5) 22 (6) 14: 12; 16: 10;17: 15; 153:10,11 ,14,22,23 46:19,21 ;170: 17; 27 :20;28: 15,25 ;29: 16,22;

1990s (4) 191:19;196:4,11 52:3;58:3;69:21 ;71 :3,8, 59:21;88: 1 ;91: 1 ;159: 1 23 (8) 18, 19;93 :9; 166:4;208:23

1991 (3) 46:20,2 1,23;47:3; 4:21 (1) 21 :20;73:14;98: 15 169: 18;170: 13;191: 19; 221:10

1993 (3) I97:1 4:30 (1) 59: 11 ;159:2;181 :2 1 24 (4) 25:3

1997 (l) 169: 18;170: 13;191:19; 43 (1) 35: 17 198:9 11:3

1998 (3) 25 (4) 4a (6) 37: 13,22,24 169: 19;170: 14;191: 19; 17: 16,16;112: 19,21;

Q&A Reporting Services, Inc. J F ischer @QAReporting.com


169:18;I97:1 4b (5)

17: 16,18;73:1 1,17; 112:23

5

5 (8) I9: 12,12,20;28:20; 29:21; 113:9; 169: 19; 198:10

50s (2) 95:21;96:1

595 (2) II 8: 10;120: 1

6

6 (22) 8:3;19: 13,20;20:1,1,1; 77:7;93:11;114:10;118:2, 9; 121:4, 14,22;122:12,19; 123:6,1 O;I60: 19;168:5; 169:23;197:13

60 (2) 10: 17;96:25

607 (1) 120:8

60s (1) I12:25

65 (1) 118:I6

66 (1) 95:8

69 (1) 119:12

6b (1) 93:13

7

7 (9) 20:2;57:25;59:3;62:4; 80: I2; 115: 1;159:21; 169: 19;204: 1

70 (1) 96:25

70s (2) 95: 14;133:8

72 (3) 95:8,14;1 19:20

74 (1) 104:5

774 (1) 153:2

779 (2) 153:1 7,17

79 (1) 121:12

793 (1) 157:12

797 (1) 152:23

(26) 0798 - 797



8

8 (13) 16: 10;72: 15, 18;77:23; 92:24;93: 11 ;94:20; 11 1:10;116:3;169:20; 193:20;206: 14;209:21

SO-building (1) 151 :7

80s (1) 181:19

838 (1) 59:8

870 (1) 57:23

885 (I) 58:3

9

9 (4) 16:12, 12;93: 12;103:6

99 (1) 43:20

1\lin-U-Scri]lt® Q&A Reporting Services, Inc. J [email protected]


(27) 8 - 99