Tyler v. Scientology: Meszaros Deposition

8/20/2019 Tyler v. Scientology: Meszaros Deposition

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1 STATE OF MICHIGAN

2 IN THE CIRCUIT COURT FOR THE COUNTY OF CALHOUN

3 CANDICE TYLER, a MichiganCitizen; and JOHN DEBAY, a

4 Michigan Citizen,

5 Plaintiffs,

6 v Case No.: 15-846-NO Hon. Sarah S. Lincoln

7 NARCONON FREEDOM CENTER d/b/a NARCONON FREEDOM

8 TREATMENT CENTER, et al,

9 Defendants. __________________________/

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11 D E P O S I T I O N

12 of TODD MESZAROS, a witness called by Plaintiffs, taken

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

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

15 Michigan Ave., Battle Creek, Michigan, on Thursday, October

16 29, 2015, beginning at 2:55 p.m.

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DICKINSON REPORTING, INC.(517) 487-1072

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1 APPEARANCES:

2 On behalf of Plaintiff: SAEED & LITTLE, LLP1433 North Meridian St., Suite 202

3 Indianapolis, IN 46202BY JONATHAN LITTLE (27421-49)

4 and DAVID MILLER (31855-32)(317) 721-9214

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

6 28400 Northwestern Hwy., Suite 200Southfield, MI 48034

7 BY KATHLEEN H. KLAUS (P67207)(248) 359-7520

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On behalf of Defendant: SCHEPER KIM & HARRIS, LLP9 Via telephone 601 W. 5th St., Suite 1200

Los Angeles, CA 90071-202510 BY WILLIAM H. FORMAN, JD

11 Also present: Catherine Villanueva.

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1 TABLE OF CONTENTS

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3 Page

4 Examination by MR. LITTLE 4:16

5 * No exhibits marked.

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1 Battle Creek, Michigan

2 Thursday, October 29, 2015

3 At 2:55 p.m.

4 R E C O R D

5 TODD MESZAROS,

6 after having first been duly administered an oath, was

7 examined and testified as follows:

8 THE WITNESS: I do.

9 MR. LITTLE: Hold on a second.

10 THE REPORTER: This is an Indiana

11 identification card. And the name on it is Todd,

12 T-o-d-d, J, Meszaros, M-e-s-z-a-r-o-s.

13 MR. LITTLE: M-a -- how do you spell that

14 again? M-a?

15 EXAMINATION

16 BY MR. LITTLE:

17 Q Sir, can you state and spell your name for the record,

18 please?

19 A It's Todd, T-o-d-d, M-e-s-z-a-r-o-s.

20 Q Okay. Just like to note on the response from your

21 counsel, your name was also misspelled. Okay.

22 MS. KLAUS: I got Beth's right. Beth Scott,

23 I typed that one right.

24 Q (BY MR. LITTLE) All right. So, sir, you are

25 designated today by Narconon Freedom Center to speak on

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1 two topics, the first being you're to testify as to

2 Narconon Freedom Center's web site as it was in the

3 spring of 2012.

4 A Correct.

5 Q And you are to -- designated to testify as to the

6 intake procedures at Narconon Freedom Center.

7 A Yep.

8 Q Okay. So let's start with the web site. Can you tell

9 us what the web address -- did -- did Narconon Freedom

10 Center have a web site in 2012?

11 A Yes.

12 Q And what was URL?

13 A I'm not sure.

14 Q Okay. Did you create the content for the web site?

15 A Nope.

16 Q Do you know who hosted it?

17 A No.

18 Q Did you edit it?

19 A Nope.

20 Q Could you edit it?

21 A I have since then, but not in 2012.

22 Q Who was in charge of the web site in 2012?

23 A I'm not sure.

24 Q What was the URL for the web site in 2012?

25 A I don't know.

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1 Q How many web sites did Narconon Freedom Center have in

2 2012?

3 A No idea.

4 Q Did -- do you know if it was one?

5 A It was definitely one.

6 Q More than one?

7 A I have no idea.

8 Q What kind of other web presence did Narconon Freedom

9 Center have in 2012?

10 A Probably banner ads.

11 Q Facebook or Twitter?

12 A I don't think they were doing Facebook ads, and I don't

13 know about Twitter.

14 Q Does Narconon Freedom Center -- did it have a Facebook

15 page in the spring of 2012?

16 A I believe so.

17 Q Who was in charge of --

18 A Don't know.

19 MR. LITTLE: I'm going to say on the record

20 that that's -- this is -- this is the designee, and he

21 doesn't know any of these questions.

22 MS. KLAUS: You didn't -- I'm looking at the

23 designation. It doesn't say Facebook page so -- okay.

24 MR. LITTLE: He doesn't know the URL of the

25 web site, he doesn't know who hosted the web site, he

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1 doesn't know who was in charge of the web site.

2 MS. KLAUS: Okay. Well, why don't you see --

3 ask him questions what he does know about the web site,

4 okay? I'm sure you know the URL of the web site, and

5 I'm sure you know its address. But you can ask him

6 what he knows about it. But, as it relates to Facebook

7 and Twitter, I don't see that on the designation.

8 Q (BY MR. LITTLE) Who was responsible for the content in

9 Narconon's web site in the spring of 2012?

10 A I don't know.

11 MS. KLAUS: Is that on the desig -- no, it's

12 not on the designation.

13 MR. LITTLE: I would like to state for the

14 record that Miss Klaus wrote, Number 4, "Subject to

15 these object -- objections, NFC designates Todd Meszaro

16 to testify as to NFC's spring 2012 web site."

17 MS. KLAUS: Right. Not who wrote it, not

18 who's responsible for the content, but the web site.

19 So you can answer those questions.

20 MR. LITTLE: And I'll state on the record he

21 doesn't know the URL, he doesn't know where it was

22 hosted. These are the things I want to know.

23 MS. KLAUS: Okay.

24 MR. LITTLE: I --

25 MS. KLAUS: I'm sorry. If you wanted to

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1 know, maybe you could have asked that. But that's just

2 me. That's just me.

3 THE WITNESS: I would assume that the address

4 was Freedomdrugrehab.com because that's the one that

5 we've had for some time.

6 Q (BY MR. LITTLE) Okay. And do you know any other --

7 does Narconon have any other URLs?

8 A Not in 2012 that I know of.

9 Q Okay. Do you know who hosts your web site now?

10 A Yep.

11 Q Do you know when they started hosting it?

12 A 2013.

13 Q Do you know who hosted it prior?

14 A I don't.

15 Q Who did the transfer, if you know?

16 A Rebecca Ryan.

17 Q And who's Miss Ryan work for?

18 A Narconon Freedom Center.

19 Q And what is her job duties and responsibilities?

20 A She's in charge of , like, media, public relations,

21 like, through any type of multi-media.

22 Q And was she there in 2012?

23 A No.

24 Q But she was in 2013?

25 A Yes.

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1 Q Who was her predecessor?

2 A I'm not sure.

3 Q When did you start working for Narconon Freedom Center?

4 A 2013.

5 Q What are your current job duties and responsibilities

6 at Narconon Freedom Center?

7 A Internet, registration.

8 Q What do you -- when you say "Internet," what do you do

9 for the --

10 A Write content for the web site, make sure it's, like,

11 to code with, like, Narconon Freedom -- or Narconon,

12 like, org, International, and so forth.

13 Q What do you mean it's code?

14 A They have to be standardized. Like, it just can say

15 basics of what the book offers and so forth.

16 Q So you standardize it according to guidelines from

17 Narconon International?

18 MS. KLAUS: Objection to form.

19 You can answer.

20 THE WITNESS: Yeah. Yeah.

21 Q (BY MR. LITTLE) Okay. And who do you get those

22 guidelines from?

23 A Narconon International.

24 Q Who at Narconon International?

25 A I'm not sure. I don't know.

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1 Q If you have a question, who would you ask at Narconon

2 International?

3 A It was pretty much just -- like, it was just sent to

4 us. There wasn't anything to question, the way the web

5 site is now.

6 Q So you just -- they sent it to you, and you just put it

7 up?

8 A Yep. It's just hosted now.

9 Q Who hosts it now?

10 A It would be Narconon.org.

11 Q But who -- who's -- where is the server located?

12 A I don't know now.

13 Q Where was it located --

14 A Before -- before I did -- how I did it, it was our web

15 site that was maintained by us; and it's just changed

16 recently.

17 Q When you maintained it, where was it hosted?

18 A Rebecca was hosting it.

19 Q On her own private servers?

20 A Yeah.

21 Q Okay. And Rebecca Ryan, R-e-b-e-c-c --

22 A Yeah.

23 Q -- a. Okay. Ryan, R-y-a-n?

24 A Correct.

25 Q And she currently works at Narconon International?

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1 A Nope.

2 Q Or Narconon Freedom Center, I mean?

3 A Correct.

4 Q Okay. And is she the person most familiar with the web

5 site hosting?

6 A For the time of , like, 2013, 2014.

7 MR. LITTLE: Okay. I'd like to ask on the

8 record why wasn't Rebecca Ryan designated? She's the

9 person that knows the stuff about the web site.

10 MS. KLAUS: And I'd like to say that we've

11 designated this person. So ask this person questions.

12 If you read the rules, you don't get to pick who we

13 designate.

14 MR. LITTLE: But you have to designate the

15 person who can answer the questions.

16 MS. KLAUS: And he is answering your

17 questions about the web site.

18 Q (BY MR. LITTLE) Okay. Who do you report to at work?

19 A The -- the Executive Director.

20 Q And who's that?

21 A Jeanie Trayhan (ph.).

22 Q Okay. And who owns Narconon Freedom Center?

23 MS. KLAUS: Don't speculate. Only if you

24 know.

25 THE WITNESS: No one. It's nonprofit.

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1 Q (BY MR. LITTLE) Who's on the board?

2 A On the Board of Directors? I don't know.

3 Q Is that on the web site?

4 A I don't believe so.

5 Q Do you know if it's required to be on the web site?

6 A I don't know.

7 Q Are you -- are the Board of Directors meetings on the

8 web site?

9 A Meetings on their web site?

10 Q Yeah, the -- the minutes of their meetings you post on

11 the web site?

12 A I believe not, no.

13 Q Okay. Do you know if that's required?

14 A I don't think it would be, but I don't know.

15 Q So if it's --

16 MS. KLAUS: I'm sorry, required by who?

17 Q (BY MR. LITTLE) I mean it's your job?

18 A I sat on the Board of Directors for a previous company,

19 and we would never put anything like that on the

20 Internet.

21 MS. KLAUS: The --

22 MR. LITTLE: Okay. So are your --

23 MS. KLAUS: My objection was to the form of

24 the question.

25 Q (BY MR. LITTLE) -- are your 990s posted on your web

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1 site?

2 A I don't think so.

3 Q Where -- do you know if your Board minutes are publicly

4 available?

5 A I don't know. I'm not on the Board of Directors.

6 Q Yeah. Well, I just thought they'd be on your web site.

7 Are your -- is your 990 publicly available, if you

8 know?

9 A I don't know.

10 Q Okay. How -- how are you evaluated at work?

11 A What do you mean "evaluated"?

12 Q Like, how is your production measured?

13 A There's Michigan State regulations; and it would be

14 based on, like, standard numbers.

15 Q What do you mean "standard numbers"?

16 A Numbers of, like, impressions on web sites, impressions

17 on, like, Facebook ads. Not web sites, but Facebook

18 ads. That would be one thing, click-through rates and

19 so forth.

20 Q Okay. And who do you report those statistics and

21 conditions to?

22 A I would give that to Jeanie.

23 Q Okay. And do you know how often you report them?

24 A Once a week.

25 Q And what day do you report them on?

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1 A Thursday.

2 Q Okay. And then what does Jeanie do with them when she

3 gets them, if you know?

4 A I don't know.

5 Q Do you ever get back any feedback on your work?

6 A Sure.

7 Q Who's that come from?

8 A Jeanie.

9 Q You ever get feedback from anybody else?

10 A I mean that's a pretty general question.

11 Q Like, when you get a -- do you get evaluated on a

12 regular basis at work --

13 A No.

14 Q -- your job performance? No? Okay. How -- you said

15 -- what is -- your web site being up to code. What did

16 you mean by your web site is up to code?

17 A Like, the code of Inter -- that International has.

18 They're trying to uniform everything we do.

19 Q Narconon International is trying to uniform everything

20 you do?

21 A Mm-hmm.

22 Q Okay. I don't know, what do you -- do you write any

23 content that doesn't come from Narconon International?

24 A I have before, like, the new web site.

25 Q What kind of content did you write?

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1 A Like, standardized, like, blogs. A lot of it would be,

2 like, personal history and so forth.

3 Q Personal history of who?

4 A Of myself . That would be personal.

5 Q You -- you would post your personal history on the web

6 site?

7 A Mm-hmm, like blogging.

8 Q Like, what kind of -- what -- what kind of personal

9 history would you write on the web site?

10 A Just personal history of , like, you know, what's going

11 on in the center, what's happened in the center, and so

12 forth.

13 Q Oh. So not your, Todd's, personal history; but history

14 of -- of current events at the center?

15 A Sure.

16 Q And what kind of events would you post?

17 A Someone donated a -- turkeys a couple years ago.

18 Q Okay. Do you post statistics about success rates?

19 A Nope.

20 Q I mean in 2012 -- I already know the answer to that

21 question.

22 MR. LITTLE: Bill, are you there?

23 MR. FORMAN: Hello?

24 MR. LITTLE: Yeah. Hey, Mr. Forman, since

25 we're going to have to do this deposition with a

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1 different deponent --

2 MS. KLAUS: No.

3 MR. LITTLE: -- at least on the subject of

4 the web site --

5 MS. KLAUS: No. No, you're not. You're

6 going to finish this deponent talking about the web

7 site. You've asked him questions not related to the

8 topic, and now you're saying, oh, you're not answering

9 what I want. Ask him questions about the 2012 web

10 site.

11 Q (BY MR. LITTLE) Okay. What was the URL in 2012?

12 Where was it hosted?

13 MS. KLAUS: I will answer those questions if

14 you give them to me in an interrogatory. Ask him other

15 questions about it, and he can answer.

16 Q (BY MR. LITTLE) Who did the content?

17 A I don't know. I didn't work in there in 2012. I can't

18 help you. I don't know.

19 MS. KLAUS: Do you have questions about the

20 content?

21 Q (BY MR. LITTLE) Yeah. What was on the web site in

22 2012? First of all, let me ask you this: How would

23 you know what was on the web site in 2012?

24 A I don't know because I can't tell you if it had -- if

25 it had been changed or not. I don't know.

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1 MS. KLAUS: Did you change the web site?

2 MR. LITTLE: Oh, hold on. I'm asking the

3 questions.

4 MS. KLAUS: Yeah, you're asking the

5 questions --

6 MR. LITTLE: I'm asking the questions.

7 That's it, I don't want any -- this is not the proper

8 designee.

9 MS. KLAUS: Did you change it in 2000 --

10 MR. LITTLE: Miss Klaus.

11 MS. KLAUS: Because I'm clarifying it so you

12 don't make a motion to compel on false information and

13 waste everybody's time.

14 Did you change the web site from its 2012

15 content?

16 THE WITNESS: Yes.

17 MS. KLAUS: Okay. Now maybe go on.

18 Q (BY MR. LITTLE) Okay. What did you change?

19 MS. KLAUS: There you go. Questions.

20 THE WITNESS: Mainly the --

21 MR. LITTLE: Excuse me. Miss Klaus, I do not

22 like your tone. I do not like your condescending

23 comments.

24 MS. KLAUS: I'm sorry.

25 MR. LITTLE: Miss Klaus, you -- you are --

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1 you're behaving bizarrely; and I think that maybe we

2 need to take a five-minute break and --

3 MS. KLAUS: I'm good.

4 MR. LITTLE: -- get back on the record.

5 MS. KLAUS: No, I'm good. You can go ahead

6 and ask some relevant questions and quit grandstanding

7 and acting like some kind of victim here. Ask the man

8 questions about the topic.

9 MR. LITTLE: Yes. Okay.

10 Q (BY MR. LITTLE) Sir --

11 MR. LITTLE: He can't answer the questions I

12 want to ask him about the web site, so there's no need

13 to go down this road. He's not the right designee.

14 All right.

15 THE WITNESS: I looked at the web site. I

16 looked --

17 MS. KLAUS: You're offering --

18 THE WITNESS: -- at the esthetics of it.

19 MS. KLAUS: Wait.

20 He's offered the opportunity. He declines

21 it, we can end. Go on to the next topic then. Okay,

22 we'll go on --

23 MR. LITTLE: Did you --

24 MS. KLAUS: -- to the next top -- Nope.

25 You're done. You closed your --

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1 MR. LITTLE: Miss Klaus, we're taking a

2 break. You need time.

3 MS. KLAUS: You need --

4 MR. LITTLE: You need to take a break.

5 MS. KLAUS: I don't need any time. We're

6 taking a break. You closed this topic, we'll go on to

7 the next.

8 MR. LITTLE: This records, right? Audio?

9 THE REPORTER: Yeah.

10 MS. KLAUS: Good.

11 MR. LITTLE: Let's take a five-minute break

12 just to let Miss Klaus calm down a little. We'll come

13 back.

14 MS. KLAUS: I -- I don't need to calm down,

15 Mr. Little. I think you do, which is why you're

16 walking out, and I'm sitting down.

17 (At 3:09 p.m. - Off the record.)

18 (At 3:11 p.m. - Proceedings resume.)

19 MS. KLAUS: Have we calmed down, Mr. Little?

20 MR. LITTLE: I'm doing fine.

21 MS. KLAUS: Good.

22 MR. LITTLE: Good. All right.

23 MS. KLAUS: Now maybe we can be more

24 professional.

25 MR. LITTLE: Actually, Miss Klaus, I'd like

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1 you to -- when you say Todd Meszaro [sic] to testify as

2 to NFC's spring 2012 web site --

3 MS. KLAUS: Mm-hmm.

4 MR. LITTLE: -- what do you -- what do you

5 mean by "spring 2012 web site"?

6 MS. KLAUS: I don't think this is the time

7 and the place. You can ask this witness questions

8 about that topic.

9 MR. LITTLE: Okay.

10 MS. KLAUS: You and I aren't going to argue

11 on the record. It's a waste of everybody's time.

12 Q (BY MR. LITTLE) All right. Sir, so where did you work

13 in 2012?

14 A That doesn't pertain to this, but I didn't work for

15 Narconon.

16 Q Well, I know; but where did you work?

17 A Why?

18 Q Well, sir, I'm asking you a question where you worked

19 in 2012. I think you have to answer that.

20 MS. KLAUS: You can go ahead and answer that.

21 THE WITNESS: Sign City Media.

22 Q (BY MR. LITTLE) Where is that?

23 A Advertising company.

24 Q Where is that located?

25 A In Indiana.

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1 Q Where in Indiana?

2 A South Bend.

3 Q Okay. And where did you work before that?

4 A WJ Haggertys [sic] and Sons.

5 Q What's that?

6 A That's a silver polishing, jewelry cleaner

7 manufacturing company.

8 Q Okay. And so what I'm interested, what -- when did you

9 graduate high school?

10 A 1992.

11 Q Okay. And what's your education beyond high school?

12 A College.

13 Q Where did you go?

14 A Indiana University, I went to Western University.

15 Q In Gunnison, Colorado?

16 A No.

17 Q Oh.

18 A Michigan.

19 Q Oh. Oh, yeah, in Kalamazoo. Okay. What did you --

20 what did you study at university?

21 A Business, art, all kinds of stuff.

22 Q Okay. And then, after university, where did you work

23 next?

24 A WJ Haggertys and Sons.

25 Q Okay. And so what is your background in web sites?

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1 Where...

2 A Mainly more esthetics of , like, web sites. Like,

3 what's appealing to people and marketing.

4 Q Okay. And so when you say "marketing," in terms of web

5 sites, what do you mean by that?

6 A I was a creative director. I did ad campaigns so...

7 Q What kind of ad campaigns?

8 A I don't know if I can really disclose that because of

9 the corporation I worked for. Like, who and what

10 campaigns they were. Like, jewelry stores mainly

11 though.

12 MS. KLAUS: Okay. Without getting into

13 specifics --

14 THE WITNESS: Yeah.

15 MS. KLAUS: -- you can talk generally.

16 THE WITNESS: You know, women are going to

17 buy engagement rings at certain times. So, like, I

18 would come up with campaigns for the products that they

19 sold.

20 Q (BY MR. LITTLE) Is that what you do for Narconon now?

21 A What's that?

22 Q Make campaigns?

23 A No.

24 Q What do you do for them now?

25 A I'm in -- I'm in charge of , like, the registration

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1 office. Making sure the admin is in, making sure that

2 the payments have gone through.

3 Q What do you do for Narconon's web sites now?

4 A Nothing.

5 Q Okay. What do you --

6 A I mean -- yeah. I mean nothing. It's not -- I don't

7 have to do anything for it.

8 Q Where do you work now?

9 A At Narconon.

10 Q Here at Freedom Center?

11 A At Freedom Center.

12 Q Do you work anywhere else?

13 A Nope. In 2012, the web site that was presented to me

14 that may have been the one that you're talking about,

15 because I don't know for certain. I changed the

16 esthetics of it, so it was more appealing. It was kind

17 of -- in my opinion, it was more pointed to -- or,

18 like, the target market was younger people; and that's

19 not really the target market.

20 Q Okay. So you wrote the code to change the esthetics?

21 A I didn't write the code. I just came up with, like,

22 the layout of the web site, the way it would work.

23 Q Who wrote the code --

24 A I don't know.

25 Q -- to change the esthetics?

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1 A I don't know who wrote the code.

2 Q Do you know how to write code?

3 A No.

4 Q Have you done web sites for any other Narconon

5 entities?

6 A No.

7 Q Are you -- do you know where calls from the Narconon --

8 okay. Do you know what numbers on the Narconon --

9 telephone number's listed on the Narconon web site?

10 A Yeah. It's just one that rings into our off ice.

11 Q Is that the only number listed on that?

12 A Yeah.

13 Q Who answers the calls after hours?

14 A The same guys that answer them during the day. The

15 phone always just rolls from the office to his cell

16 phone.

17 Q Did you set up that routing?

18 A The how -- I'm the one that figured out how to roll the

19 phone, but what do you mean "routing"?

20 Q Like, so when the call button, did you write the code

21 for the call button?

22 A What do you mean "call button"?

23 Q When you -- like, if you want to call a number, right,

24 can you click on it to talk to a live person?

25 A You're talking about like --

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1 MS. KLAUS: Through the computer?

2 THE WITNESS: You're talking -- it's called

3 Call Per Click?

4 Q (BY MR. LITTLE) Yeah.

5 A We don't do Call Per Click.

6 Q Okay.

7 A I don't know if with the new web site because I haven't

8 called in on it. I gave them the 800 number that I

9 bought through AT&T. I don't know if you can click on

10 it and actually speak to someone live. It's a cell

11 phone app. I looked at it.

12 Q Okay. So you don't know, on the mobile web site, if

13 you can call click or not?

14 A If you can call click it or not, I don't know. It

15 would be the same phone number though.

16 Q Who -- do you know who did your programming for your

17 app?

18 A I don't know, because I just told you I don't even know

19 if we have that app. If someone has a cell phone, you

20 can look and see if it called.

21 Q Let's do that.

22 MS. KLAUS: And let the record reflect

23 they're again playing with their phones and computers

24 during the dep.

25 MR. LITTLE: Okay. The record will so

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1 reflect that I am using the Internet to look up

2 Narconon Freedom Center's web site. It does have Call

3 Click.

4 THE WITNESS: Okay, cool. That's really

5 cool.

6 Q (BY MR. LITTLE) All right.

7 A Nice.

8 Q You didn't do that though? You never --

9 A I didn't set it up.

10 Q Okay.

11 A That's actually our front desk that you're calling, so

12 it's not even going into the --

13 MS. KLAUS: And I object to --

14 THE WITNESS: -- Intake Office.

15 MS. KLAUS: -- you calling my client, so you

16 might want to hang up.

17 Well, do you want to give me Miss Tyler's

18 number; and I'll crank call her? Okay.

19 MR. LITTLE: I think it's time to take

20 another break. I -- I don't --

21 MS. KLAUS: I'm good.

22 MR. LITTLE: -- know what's wrong with Miss

23 Klaus.

24 MS. KLAUS: There's nothing wrong with me. I

25 just didn't want you calling and speaking to my client.

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1 Q (BY MR. LITTLE) Okay. Anyways, I think we've

2 exhausted your knowledge of the web site.

3 MS. KLAUS: Objection to form, foundation.

4 Q (BY MR. LITTLE) Is there anything else about the web

5 site you would like to tell us?

6 A No.

7 Q Is there anything about the web site that -- that I

8 haven't asked you that --


10 THE WITNESS: No.

11 MS. KLAUS: That is incredibly vague.

12 Q (BY MR. LITTLE) All right. We will move on to intake

13 procedures. Okay. So do you have any medical

14 training, sir?

15 A Nope.

16 Q Okay. What does -- by coming to Narconon, how would I

17 -- how would I first, as a -- a new patient, make

18 contact with you?

19 MS. KLAUS: Objection to form. You mean

20 student?

21 Q (BY MR. LITTLE) Typically, as a new student, how would

22 I contact you?

23 A They'd be -- usually via telephone, like 99.9 percent.

24 Q Okay. So I call, you answer?

25 A You call. Yeah, one of the guys would answer the

27

1 phone.

2 Q One of the guys like --

3 A Or myself. I could answer the phone.

4 Q Okay. How many -- are you the -- how many intake

5 people are there at Narconon Freedom Center?

6 A Three.

7 Q Are you their supervisor?

8 A Yep. So, if I answer the phone and you call in, what

9 would be your question?

10 Q Okay. I would like to be admitted -- I have a drug

11 problem, I want to come to your facility. What happens

12 next?

13 A Okay. We -- I'd have to fill out a Program Eligibility

14 Form. This is now.

15 Q Right.

16 A This is present time, in 2000 and --

17 Q Okay.

18 A -- 15.

19 Q Yep.

20 A You'd fill out a Program Eligibility Form. We would do

21 it over the phone. It would have a drug rundown of ,

22 like, what you're taking, what you're not taking. If

23 you're on prescription drugs and you're getting them

24 prescribed, you have to have a doctor's release to put

25 you into rehab.

28


8/38

1 Q Okay.

2 A You know, if you're buying them off of the streets,

3 it's a different story. I can't -- I can't give you

4 medical advice over the phone.

5 Q Or can you give medical advice at all?

6 A No.


8 Q (BY MR. LITTLE) Okay. Program Eligibility Form, are

9 they -- are they kept and maintained somewhere?

10 A Yep.

11 Q Where?

12 A In Central Files. They're locked up.

13 Q And where is the Central Files located?

14 A In the Treasury Off ice.

15 Q And at 809 --

16 A West Erie Street.

17 Q Okay. Kansas City on that. I -- I'm going to say

18 "Kansas City" so I can find the stuff quicker in the

19 word index, that's all.

20 A Cool.

21 Q Okay. So program eligibility.

22 A You fill out a Program Eligibility Form. We would do

23 it over the phone. It's about seven pages.

24 Q Okay.

25 A Okay? It's going to have a drug rundown, some

10 29 15


29

1 questions on, like, health, medical, and so forth.

2 Then it would go to our doctor and nurse, and they

3 would do it. They would call in, and then they have a

4 questionnaire that they're going to fill out, and

5 they're going to come back and tell me if you're good

6 to go or not.

7 Q What's the questionnaire that doc --

8 A I have no idea because --

9 THE REPORTER: I'm sorry, I didn't get all

10 the --

11 MR. LITTLE: Oh, sorry.

12 THE REPORTER: -- question. You kind of cut

13 him off. Let him finish, please.

14 What's the question?

15 Q (BY MR. LITTLE) Oh, I just wanted to know what was the

16 questionnaire called, if you knew, that the doctor

17 fills out?

18 A A medical assessment.

19 Q It's called a medical assessment?

20 A I believe so.

21 Q And is that stored in Central Files?

22 A It would be stored in the Medical Department.

23 Q Where is the Medical Department at?

24 A At 809 West Erie Street.

25 Q Okay. And then what else -- so after this medical --

30

1 A After they would do the medical assessment, they would

2 speak to the potential client, they would let us know

3 if they need a medical detox or not. They would

4 determine that.

5 Q Be -- is that before they meet the client?

6 A This was before they would come in there. If you were

7 taking the certain types of drugs, you may need a

8 medical detox.

9 Q Where are medical detoxes done at?

10 A Medical detox facilities.

11 Q Where are they -- where's the one at?

12 A Allegiance Hospital.

13 Q Where is that at?

14 A Allegiance Hospital in Jackson --

15 Q Okay.

16 A -- Michigan.

17 Q Lee -- how do you spell "Allegiant"?

18 A Allegiance.

19 Q Allegiance, all right. Okay. Do people call in and

20 say, well, I want to -- I'm considering different

21 programs; why should I go to your program?

22 MS. KLAUS: Objection. Again, he's not

23 speaking on behalf of NFC; he just does the intake

24 procedures.

25 THE WITNESS: I mean I'll answer it.

31

1 No, usually they're just asking direct

2 questions about what we offer there.

3 Q (BY MR. LITTLE) And what do you tell them about what

4 you offer?

5 A Exactly what we offer there.

6 Q What do you offer?

7 A We offer life skills, we offer a sauna program, we

8 offer a series of -- of a battery called objectives.

9 Q And what are -- what are the objectives?

10 A Objectives are designed to get people to look outward

11 instead of inward and stop -- start -- stop thinking so

12 subjectively and look more objectively.

13 Q And when you say "objectives," are they -- is that --

14 are they written objectives?

15 A They are written in a book. They get a workbook and a

16 book, the student.

17 Q How many workbooks and books do they get?

18 A There -- now, in 2015, there are four.

19 Q Okay. And are those books --

20 MS. KLAUS: Okay, I --

21 Q (BY MR. LITTLE) -- written by --

22 MS. KLAUS: -- you on speaker.

23 (Speaking to Mr. Forman on her cell phone.)

24 THE WITNESS: I'm sorry?

25 Q (BY MR. LITTLE) Those books are based on the teachings

32


9/38

1 of L. Ron Hubbard?

2 A They're based on the works of L. Ron Hubbard.

3 Q Okay. Are they based on the works of anybody else?

4 A No.

5 Q Okay.

6 A As far as I know, no.

7 Q All right.

8 A Just is based on the works. I mean there's a full

9 video that somebody watches when they walk in, there's

10 a -- a poster or a big display that says, you know,

11 Narconon was based on the works of L. Ron Hubbard.

12 Q What's the video they watch?

13 A It's a video that states the program was created by the

14 works of L. Ron Hubbard.

15 Q How long is the video?

16 A About ten minutes.

17 Q What's the video called?

18 A I don't know. Introduction to Narconon.

19 Q So, if I wanted to get a copy of this video, what would

20 I ask --

21 A You probably can go to Narconon International web site.

22 It's probably on their page.

23 Q But I want to see the one they show at Freedom Center.

24 Who would have a copy?

25 A I don't know. It's built into the TV. It's like a

10 29 15


33

1 little closed-circuit thing where you can only watch

2 what videos are on it.

3 Q Is it called The Way To Happ iness?

4 A No.

5 MS. KLAUS: Can we go off the record? Can we

6 just stop for a second?

7 (At 3:23 p.m. - Off the record.)

8 (At 3:23 p.m. - Proceedings resume.)

9 MS. KLAUS: I'm sorry, but he was just

10 disconnected, and I was trying to reconnect him. So I

11 apologize for interrupting.

12 Q (BY MR. LITTLE) Video. So the ten-minute video, you

13 don't know the name of it?

14 A It's called Introduction to Narconon.

15 Q Okay, Introduction to Narconon. And, if I wanted to

16 get a copy of that, is that something you could get?

17 A No, I don't believe so.

18 Q Who could get me the copy?

19 A I would try the International web site.

20 Q But, if I wanted to get it from Freedom Center, who

21 would I ask for that?

22 A I don't -- we wouldn't have a copy of it there.

23 Q All right. Kansas City. Okay. So they make the

24 determination, the doc -- the Medical Department. And

25 who is the Medical Department?

34

1 A Doctors and nurses that work there.

2 Q Who are the doctors and nurses?

3 A Dr. Martin Holmes.

4 Q Uh-huh. H-o-l-m-e-s?

5 A Correct.

6 Q And who are the nurses?

7 A The Director of Nursing is Melinda Sophia.

8 Q Mm-hmm. Okay.

9 A Debbie Ray Amber. I don't know their last names.

10 Q Okay. So the determination is made that someone needs

11 to -- let's do both courses of action here. Does not

12 need a medical detox. What happens next?

13 A If they don't need a medical detox; and then, you know,

14 you've already presented the program, it's either

15 billed through insurance, or it's cash pay.

16 Q Do you take the payments?

17 A Do I physically take the payment?

18 Q Yeah.

19 A I mean, if you came in an intake office, yes.

20 Q What do you -- okay. So what do you do with the credit

21 card if I give you a credit card?

22 A Credit card would go to Treasury, and they run it

23 through a credit card machine, then the guarantor,

24 whose credit card it is, would sign off on it.

25 Q What about cash?

35

1 A Like, actual cash money?

2 Q Yeah. Has that ever happened?

3 A One time.

4 Q Do you remember who that was?

5 MS. KLAUS: No.

6 Q (BY MR. LITTLE) Or was -- was it our client, Candice

7 Tyler?

8 A No. I wasn't even there when she came in.

9 Q Okay. What about checks? Do you take checks?

10 A Mm-hmm.

11 Q What do you do with them?

12 A I would turn it in to Treasury.

13 Q Okay. And who do you turn it in to at Treasury?

14 A Valerie or Karen.

15 Q What's Valerie's last name?

16 A Kealoha.

17 Q And what's Karen's last name?

18 A McSweeney.

19 Q Okay. Without saying a specific name, can you think of

20 a time when somebody was not eligible to be in

21 Narconon?

22 MS. KLAUS: Objection to form. For some --

23 for what reason?

24 Q (BY MR. LITTLE) Have you ever turned somebody down --

25 someone called up that had the money, but you turned

36


10/38

1 them down?

2 A Yep.

3 Q Okay. Can you tell me what kind of circumstances get

4 turned down?

5 A Just a broad example?

6 Q Like, give me some examples, yeah.

7 A If you've been convicted of rape.

8 Q Okay.

9 A You need more?

10 Q Yeah.

11 A How many?

12 Q I mean just give me, you know, if you have examples,

13 just --

14 A If you -- if you're a violent, like, criminal, and

15 you've done a lot of hard time in prison.

16 Q Okay.

17 A If you've -- you know, depending on your drug case, if

18 it's too extensive, if you've been using drugs since

19 you were three years old because, ironically, I've

20 heard this before. You know, a kid started taking --

21 getting into cocaine when he was three or four years

22 old, smoking pot, you're not --

23 Q What --

24 A -- qualified to do the program.

25 Q Okay. What about people who are on psychiatric

10 29 15


37

1 medication? Are they accepted at Narconon Freedom

2 Center?

3 A It would depend on the volume and, like, the type of

4 medications.

5 Q What type of medications would not be accepted?

6 A Lithium.

7 Q Okay.

8 A Like, extensive use. If you've been on it for, like,

9 15 years.

10 Q Any others?

11 A That's just too much of a broad question, you know.

12 I'd have to have a specific, and then I'd have to do a

13 -- I'd have to use my best judgment and then give it to

14 the doctor, you know.

15 Q If someone -- if somebody was prescribed psychiatric

16 medication, could they continue taking that medication

17 while they were at Narconon Freedom Center?

18 A No. It's a holistic program, which means we do

19 everything all naturally.

20 Q Okay. What about seizure medication? Would you --

21 would they be allowed to be taking --

22 A Yeah.

23 Q Okay.

24 A Heart medication. You know, I mean, if you've got

25 diabetes, you know, it's not a problem.

38

1 Q But no psychiatric medication?

2 A Nope.

3 Q Okay. What about medication -- psychic -- what about

4 medications for bipolar disorder?

5 A That's the same thing.

6 Q Okay. So no medications for bipolar disorder?

7 A It's a psychotropic drug.

8 Q Okay. How long have you been in Intake at Narconon?

9 A Since July 2013.

10 Q Okay. Have you worked at any other Narconon

11 facilities?

12 A No, sir.

13 Q Any Better -- Best Drug Rehab facilities?

14 A No.

15 Q Okay. Any --

16 A No AFR , no BRS, none of them.

17 Q Okay. Okay. So somebody comes in and -- no Best

18 Choice?

19 A I'm sorry?

20 Q Best Choice Drug Rehab?

21 A I've never worked at a drug rehab before.

22 Q Okay.

23 A So you can just --

24 Q Or Narconon or anything else --

25 MS. KLAUS: It's like green eggs and ham.

39

1 THE WITNESS: No.

2 Q (BY MR. LITTLE) All right. So come in, take the

3 payment. What happens next as far as you're concerned?

4 What do you do next for intake?

5 A Well, I mean there's paperwork that would have to be

6 done.

7 Q What kind of paperwork?

8 A There's paperwork that would have to be done with the

9 guarantor and as well as the potential cl ient.

10 Q Can you tell me what those forms are called?

11 A Now or back then?

12 Q Let's start with 2012.

13 A 2012. Well, it would be the -- this is the -- this is

14 pretty much the enrollment agreement right here.

15 Q And, if I wanted to refer to that, what would I call

16 it?

17 MS. KLAUS: Exhibit 1?

18 THE WITNESS: This would be --

19 MR. LITTLE: No.

20 MS. KLAUS: Is that marked as Exhibit 1 --

21 MR. LITTLE: In a different deposition.

22 MS. KLAUS: -- just for the record? Okay.

23 THE WITNESS: It would be an enrollment

24 agreement.

25 Q (BY MR. LITTLE) Okay. So if I said -- would it be

40


11/38

1 called an admission agreement?

2 A Sure.

3 Q Okay. All right.

4 A Because it's the same -- you know, it's an admission

5 application now.

6 Q Okay. So, in 2015, it's called the admission

7 application?

8 A Yep.

9 Q Okay. Now, the admission agreement from 2012, Exhibit

10 Number 1 from Valerie's deposition, is that a true and

11 accurate copy of an admissions agreement from 2012?

12 MS. KLAUS: If you know. Don't speculate.

13 THE WITNESS: Well, I mean it's not dated.

14 I'm going to say yes because...

15 Q (BY MR. LITTLE) Okay. Do you explain when -- so what

16 other forms do people sign when they --

17 A Consent to receive services, suicide waiver.

18 Q What's a suicide waiver?

19 A You know, that you're not suicidal. Just a standard

20 liability form.

21 Q Okay.

22 A I mean this is all standard. Like, any rehab that you

23 go to, you're going to sign something like that.

24 Q How do you know that?

25 A Because I've been in rehab before.

10 29 15


41

1 Q But you said you never worked in a rehab before?

2 A I've been into a rehab before.

3 Q Can I ask why you were in a rehab?

4 MS. KLAUS: No. No.

5 MR. LITTLE: Well, I mean he's testifying

6 this is a standard form.

7 MS. KLAUS: Yeah.

8 MR. LITTLE: He's in charge of forms at

9 Narconon --

10 MS. KLAUS: He said he's been in one, but

11 he's not going to go into his personal medical history.

12 There's no confidentiality protecting this case --

13 MR. LITTLE: Okay, hold on.

14 MS. KLAUS: Let me finish. There's no

15 confidentiality protective order in this case, and it's

16 not relevant to his testimony. So he's not going to

17 talk about his personal medical history.

18 MR. LITTLE: Well, he hasn't actually said

19 that he's been in a rehab for medical --

20 THE WITNESS: Okay, fair enough. So have you

21 -- the rest of your questions, consent to receive

22 services, suicide waiver, HIPAA papers.

23 THE REPORTER: I'm sorry, you want too fast.

24 "Consent to" --

25 THE WITNESS: Consent to receive services,

42

1 HIPAA, H-I-P-P-A [sic].

2 THE REPORTER: Mm-hmm.

3 THE WITNESS: It would be a confidentiality

4 agreement. These are federal papers.

5 Q (BY MR. LITTLE) Okay.

6 A Hospital transportation, property search, like a

7 consent for a property search.

8 Q Okay.

9 A Release of information.

10 Q Okay.

11 A I'm trying to think what else is in there. I can't --

12 I can't honestly recall the rest.

13 Q Okay. So I'm going to -- let me back up. Just because

14 you haven't said it, you -- you are basing your

15 statement that these are typical drug rehab forms on

16 the time you went to drug rehab?

17 MS. KLAUS: Objection to form. He said he

18 went to rehab.

19 THE WITNESS: I've been in -- I've worked

20 with other rehabs, and they've shown me their

21 paperwork.

22 Q (BY MR. LITTLE) Okay. But you've never worked for

23 another drug rehab?

24 A No. No, sir.

25 Q Okay. So who are these other drug rehabs that showed

43

1 you --

2 A I worked -- I've worked with medical detoxes where I've

3 -- like, I had to take a client in there; and they

4 showed me the paperwork; does that make sense?

5 Q It makes sense. That's not the answer your attorney

6 tried to give. But you work with --

7 MS. KLAUS: I'm not -- I just -- you know

8 what, Jonathan? Stop it, okay? They said no snark.

9 The judge was very clear, so no snark.

10 MR. LITTLE: Exactly.

11 MS. KLAUS: Okay? Exactly. So --

12 MR. LITTLE: I'm glad --

13 MS. KLAUS: Okay, then on we go.

14 MR. LITTLE: Miss Klaus --

15 MS. KLAUS: You know, that's amateur hour.


17 MS. KLAUS: Just ask him his questions --


19 MS. KLAUS: -- and cut it out.

20 MR. LITTLE: -- this is my deposition.

21 MS. KLAUS: Cut out the side comment.

22 MR. LITTLE: Please refrain --

23 MS. KLAUS: I'm telling you to cut out the

24 side comments.

25 MR. LITTLE: Miss Klaus, Miss Klaus, stop it.

44


12/38

1 Q (BY MR. LITTLE) Now, sir --

2 MS. KLAUS: Cut out the side comments,

3 Jonathan, or we'll go back upstairs.

4 MR. LITTLE: Miss Klaus.

5 MS. KLAUS: Yeah, I know that's my name.

6 MR. LITTLE: Do not address me like that.

7 Now --

8 MS. KLAUS: I'm sorry, Mr. Little, cut out

9 the side comments, or we're going back upstairs.

10 MR. LITTLE: We're going off the record.

11 MS. KLAUS: No.

12 MR. LITTLE: Okay, then we're going on the

13 record. Don't talk to me like you're my mother.

14 MS. KLAUS: Oh, I'm not your mother.

15 MR. LITTLE: I'm asking this witness -- I'm

16 asking this witness questions. Don't interrupt my

17 deposition.

18 MS. KLAUS: Okay. I'm not interrupting, and

19 quit out -- and stop the side -- snide comments.

20 MR. LITTLE: Okay.

21 Q (BY MR. LITTLE) Now, you said you're familiar with

22 these forms when you went to other medical drug rehab

23 facilities?

24 A I've seen other forms. This is just standard.

25 Q But I -- when you say it's "standard," I'm trying to

10 29 15


45

1 base -- you're saying standard. I want to know why you

2 think it's standard.

3 A Because I've seen other forms from other facilities.

4 Q Okay. And you've seen those other forms in the course

5 of your employment at Narconon?

6 A Correct.

7 Q Because Narconon sent you to those other facilities?

8 A I work with other facilities like med detoxes.

9 Q Okay. Which med detoxes are those?

10 A I told you Allegiance, Henry Ford Clinic.

11 Q In Detroit?

12 A Yep.

13 Q Okay.

14 A I've had to route people over to Best Drug Rehab.

15 Q And that's another Narconon facility, correct?

16 A Nope.

17 Q Best Drug Rehab is not a Narconon facility?

18 A No.

19 Q Okay. Have you ever received any compensation from

20 Best Drug Rehab?

21 A No.

22 Q Okay. Why do you send people to Best Drug Rehab?

23 A Because they weren't qualified to do our program.

24 Q What's the difference between yours and Best Drug Rehab

25 program?

46

1 A We require, like, physical activity. And, if someone

2 isn't capable of doing it, they're not going to be

3 qualified for our program.

4 Q What kind of physical activity do you require?

5 A Running, jogging, exercise, and so forth.

6 Q And who prescribes the physical activity?

7 A The doctor, I guess.

8 Q Who makes a decision if someone's qualified for

9 physical activity or not?

10 A If you can't walk, how can you do physical activity

11 there?

12 Q But do you make that call, or does somebody else?

13 A It's a judgment call.

14 Q On whose judgment?

15 A Depends on who's on the -- who is working with the

16 potential client.

17 Q So you or one of the other Intake people?

18 A Mm-hmm.

19 Q Okay. So, if I wanted to get the admission agreement,

20 the consent to receive treatment, the suicide waiver,

21 the HIPAA waivers, the confidentiality agreement, the

22 hospital transportation agreement, the property search

23 agreement, and release of information agreement, who

24 would I -- where -- where would these be kept for Miss

25 Tyler? Where are they stored at?

47

1 A They'd be in -- in Central Files.

2 Q Okay. And who at Central Files would know -- if you

3 wanted to get them, who would you go ask at Central

4 Files?

5 A I wouldn't be able to access them.

6 Q Who would be able to access them?

7 A Valerie.

8 Q Okay. Do you know how -- okay. So do you -- but you

9 help the people fill these forms out?

10 A I don't help them fill them out at all.

11 Q Do you explain them to them?

12 A Yeah, and you have to read this before you come in.

13 Q So you explain it to them. What if there are -- do you

14 ever have people who are intoxicated when they come in?

15 A It's kind of a broad question. It's hard to tell.

16 Q If somebody was intoxicated when you came in, would

17 they sign these forms?

18 A If they were -- they'd have to go to Med Detox first if

19 they're come -- just depends. "Intoxicated" is too

20 broad.

21 Q If somebody was under the influence of alcohol,

22 narcotics, drugs, would they sign these forms --

23 MS. KLAUS: Objection to --

24 Q (BY MR. LITTLE) -- when they come --

25 MS. KLAUS: -- form. Objection to form.

48


13/38

1 Q (BY MR. LITTLE) When somebody comes into the rehab

2 center at Narconon Freedom Center, and they're under

3 the influence of alcohol or drugs or narcotics, do they

4 sign these forms?

5 MS. KLAUS: Same objection. You gave three

6 different conditions in one question.

7 Q (BY MR. LITTLE) Okay. You can answer.

8 MS. KLAUS: If you can. I mean he's asking

9 you three different things.

10 THE WITNESS: The guarantor wouldn't be the

11 one that would be high, so they would sign the consent

12 paper. So now sometimes we've had to go back and have

13 them re-sign the paperwork.


15 A You know, it's common sense. Someone comes in, and

16 they're falling over, that's where you go get the nurse

17 and the medical doctor and take them -- you route them

18 elsewhere, medical detox, hospital.

19 Q Could somebody be admitted to Narconon and not sign

20 these forms?

21 A They'd have to sign a consent to receive services.

22 Q But they wouldn't sign an admission agreement or

23 something else?

24 A No.

25 Q Okay.

10 29 15


49

1 A I mean, if they're not in their right mind, there's no

2 reason to have them do that.

3 Q Okay. All right.

4 A I can't facilitate somebody there that's --

5 Q Okay. So they come in, they sign the forms, then what

6 do you -- what do you do with them if you're going to

7 admit them?

8 A They would be turned over to security and medical for

9 the search, and then their -- their actual physical

10 medical assessment and physical and so forth with the

11 doctor. Forms would go down and get put into a folder,

12 and then I would turn them in to Treasury.

13 Q Do you have any other interactions with the people

14 after that, with the new admissions?

15 A Very little.

16 Q Okay.

17 A We are on site though. We're at the facility.

18 Q Okay. Do you have any training in chemical dependency

19 counseling?

20 A Nope.

21 Q Do you have any other education besides your college

22 educations or beyond your college education? Any --

23 like a -- designations, certified dependency counselor

24 or anything like that?

25 A Nope.

50

1 Q Okay. Nothing? No background in --

2 A No.

3 Q Okay. What about if someone goes to medical drug

4 rehab, what -- what happens with them? They go to

5 medical drug rehab. Do they sign admission agreement,

6 consent to receive, suicide waiver --

7 A They would sign their consent to receive services --

8 Q Mm-hmm.

9 A And a property, like, search; so we can store their

10 stuff while we take them to medical detox.

11 Q Okay. And then what happens?

12 A They would go to medical detox, get signed -- get

13 checked in, and then they're under a different doctor's

14 care. It could be a day, it could be two weeks.

15 Q And then --

16 A They would -- they would be in communication. They

17 would have to sign a release of information. This is

18 how I know about these forms. They would sign a

19 release of information so our medical doctor and nurses

20 could be in communication with their medical doctors

21 and nurses at said facility.

22 Q So you -- your knowledge of the forms comes when you

23 get the -- when you get Henry Ford's forms back?

24 A Well, I've went in there, and I just looked at it to

25 make sure because we're bringing somebody in; and I

51

1 don't want them looking at something that's, like,

2 crazy. They don't -- wouldn't sign their life away.

3 Q I got ya. Okay. What if somebody wants to -- after

4 admission, wants to leave the Narconon program?

5 A Bye.

6 Q Is that your area?

7 A No, but --

8 Q Okay.

9 A You know, I would tell them good luck, you know.

10 Q If somebody -- do you, as part of your job at Intake,

11 do you ever transport new students from location to

12 Freedom Center?

13 A Is it my job to pick people up and bring them in there?

14 Q Yeah.

15 A No.

16 Q Have you ever done that?

17 A I have.

18 Q Is that -- how many times?

19 A I went one time to the airport just so I could see the

20 Detroit airport, just so I had an idea what it looked

21 like. I think twice. A few more times than that.

22 Maybe five.

23 Q Who -- who typically does that? Who typically --

24 A Transport driver.

25 Q Who's the transport driver now?

52


14/38

1 A Now?

2 Q Yeah.

3 A Lucas.

4 Q What's his last name?

5 A I don't know how to spell it. It's Peckareco,

6 Peckarocco.

7 Q Okay.

8 A P-e-c -- I don't know how he pronounces it. I just

9 call him Lucas.

10 Q And who was the transport driver in 2012, if you know?

11 A I don't know.

12 Q Who would be the person that you would think would know

13 that information?

14 A Valerie probably would have known.

15 Q Are you familiar with the name Brian Basil?

16 A Yep.

17 Q Did he used to work in Intake?

18 A I don't know.

19 Q How do you know the name Brian Basil?

20 A He's an interventionist.

21 Q What's an interventionist?

22 A He goes with families and stages an intervention to get

23 someone to come into rehab.

24 Q Is that part of Intake?

25 A Not normally.

10 29 15


53

1 Q Well, when would -- when would interventionist be used?

2 A An intervention would -- interventionist would be used

3 when someone isn't willing to take responsibility for

4 their drug addiction and the family and loved ones want

5 to get them into treatment.

6 Q And who makes the decision to use an interventionist?

7 A Family, loved ones, friends. I don't know.

8 Q Do you suggest interventionists to use?

9 A If it's necessary, like, once in a while.

10 Q Where do you get your referrals for interventionists

11 from?

12 A Where do we get the interventionists from? There are a

13 couple interventionist companies that we used to use.

14 I don't remember their name. And I believe Brian

15 worked for that company. I think they were out of Ohio

16 because he is from Ohio, but I don't know for certain.

17 You can write down the world "ITS" or the acronym. I

18 don't remember what it was for.

19 Q Okay. Do you get any fees or any reimbursement for

20 recommending certain interventionists?

21 A Nope.

22 Q Do you know how interventionists get paid?

23 A It would be through the family.

24 Q Okay.

25 A Their fee would be separate, what they charge.

54

1 Q Did Brian Basil ever work for Narconon Freedom Center?

2 A I don't know.

3 Q Did you ever see him at Narconon Freedom Center?

4 A Um --

5 Q Physically?

6 A I've seen him there a couple times. He came in to say

7 hi a couple, like, months ago, like, into the, like,

8 administration part of the facility.

9 Q Okay. What about a company called Allied Intervention

10 Management, AIM, A-I-M?

11 A I don't know.

12 Q Okay. Okay. So, if I called up, and I was -- I

13 relayed that my loved one or myself had a -- a drug

14 problem, okay, you -- you would be the person who would

15 answer the phone? Is that typically how it works?

16 A I wouldn't be the one that generally answered the

17 phone.

18 Q Who would that be?

19 A One of the intake coordinators.

20 Q Who are the intake coordinators?

21 A Now?

22 Q Yeah, and in 2012.

23 A I don't know who worked there in 2012 other than Tim

24 Keller.

25 Q Is he still --

55

1 A Nope.

2 Q No? Okay.

3 A Matt Henley.

4 Q Are these 2012 or current people?

5 A No, this is 2012.

6 Q Okay. Do you know where Tim Keller works now?

7 A Nope.

8 Q Matt Henley?

9 A Nope.

10 Q Okay. Who are the current intake coordinators?

11 A Stephen Troutner.

12 Q How do you spell that?

13 A S-t-e-p-h-e-n. Troutner, T-r-o-u-t-n-e-r.

14 Q And who else?

15 A Brad Roussel. R-u -- or R-o-u-s-s-e-l.

16 Q R-o-u-s-s-e-l?

17 A Yep.

18 Q Okay.

19 A And Tony. Last name is L-o-g-u-e.

20 Q Okay. And are -- do you know, do you have any

21 supervisory authority over these people?

22 A Yep.

23 Q You're their supervisor?

24 A Mm-hmm.

25 Q Okay. So what are they instructed to tell people, you

56


15/38

1 know, to kind of pitch the program? What's the --


3 Q (BY MR. LITTLE) If someone calls up, says, "Thinking

4 about your program," what -- what do you instruct these

5 three gentlemen to say?

6 A They have a program outline.

7 Q What's that program outline called?

8 A Program outline, program overview.

9 Q Okay. And, if I wanted to get a copy of the program

10 overview?

11 A I could e-mail one to you.

12 Q Okay. Perfect. I will get in touch with your lawyer

13 then. And it -- it's called the program overview?

14 A Yep.

15 Q Kan -- I'll just say "Kansas City" so I can find it in

16 the record. Okay. Great. And -- and what is

17 contained in that program overview?

18 A Just what we offer. Shows a picture of the center.

19 Q And then some text?

20 A Yep.

21 Q Who wrote it?

22 A I did.

23 Q Okay.

24 A Kind of. I took it right out of the books.

25 Q Out of the Narconon International books?

10 29 15


57

1 A Yeah. Nope, the ones that are in our center. There's

2 an overview of , like, what each book offers.

3 Q What books are you referring to?

4 A The books that the students use in the program.

5 Q Are -- are those the --

6 A No.

7 Q No?

8 A Nope, nope.

9 Q Let me see them just a second. I'll just ask you what

10 -- I'll read you a title of these, and you can tell me

11 this, not them. It's not the Personal Values and

12 Integrity course --

13 A Nope.

14 Q -- by Ron L. [sic] Hubbard? It's not the Ups and Downs

15 of Life course?

16 A That's one of them, but it's not the same book. Same

17 title though.

18 Q Okay. Okay. Do you know -- so you -- you took the

19 intake -- you took the program overview out of -- out

20 of con --

21 A The new books.

22 Q Okay. All right. Does the program overview state a

23 success rate?

24 A Nope.

25 Q Do you instruct any of these gentlemen --

58

1 A No.

2 Q -- to make comments on success rates? Okay.

3 A Even though Michigan State law requires that you, like,

4 track that --

5 Q Mm-hmm.

6 A -- it's too hard to give an analysis on, man.

7 Q I got ya. Have you ever heard the figure 76 percent

8 success rate for Narconon Freedom Center?

9 A No.

10 Q Okay. Have you ever heard of 76 percent rate for

11 Narconon overall?

12 A No.

13 Q Okay. When people call on Intake, do they ever ask

14 questions about the sauna?

15 A Yeah.

16 Q What kind of -- what kind -- what kind -- what do you

17 say about the sauna?

18 A You know, it's a series of vitamins and minerals that

19 flush out the drug toxins in your body.

20 Q What vitamins, if you know?

21 A Vitamin B-1 complex. There's Niacin involved.

22 Actually, the overview that I would send to them

23 explains exactly what it is because it's taken right

24 out of the books.

25 Q What kind of oils [sic] and minerals?

59

1 A I can't remember. I don't really do the intake on --

2 over the phone. I don't know all of the -- the

3 vitamins and stuff , like exactly.

4 Q Okay. Do you have any research or anything that

5 supports that B-1 or Niacin can help with -- or can

6 help with drug addiction?

7 A Research as in...?

8 Q Like, if someone says, well, how do you know that these

9 vitamins help a drug reha -- you know, rehabilitation.

10 Do you have any studies or anything that suggest that

11 they do, in fact, help with drug rehabilitation?

12 A Not -- the books have that, and there's another book

13 that's in the program that is used.

14 Q What's that book called?

15 A This is in 2015.

16 Q Okay.

17 A It's called Clear Body, Clear Mind.

18 Q Clear Body, Clear Mind. Do people ever ask you what

19 the goal of the sauna program is?

20 A It's to flush out the toxins and residuals in the body.

21 Q Okay.

22 A Like drug toxins that are oil soluble.

23 Q Do people -- do you -- oh, that are oil soluble?

24 A Mm-hmm.

25 Q Okay. And do you have any studies or research that

60


16/38

1 support that that is actually a valid form of drug

2 treatment?

3 A I don't know.

4 Q Okay. So how does it help the body to get rid of drug

5 toxins during drug treatment?

6 A Well, Niacin opens up the blood capillaries.

7 Q Okay.

8 A You know, the vitamins, you're -- you're putting in the

9 good stuff while the bad stuff is flushing out. Ni --

10 this isn't, like, anything new. Like, before I worked

11 at Narconon -- I mean Niacin's in everything; and

12 that's what it's used for.

13 Q Niacin's used for drug treatment?

14 A Not for drug treatment per se; but to, like, flush out

15 stuff in the body. Like, it's in pre workout. Like,

16 if , you know, it opens your blood capillaries.

17 Q So how did you -- how did you come to learn that?

18 A That it's in pre workout?

19 Q What's pre workout?

20 A You don't know what pre -- you don't go to the gym or

21 anything?

22 Q No. Do I look like it? I'm skinny as -- you know.

23 A I don't know, man.

24 Q He does. (Indicating to Mr. Miller.)

25 THE WITNESS: You know what I'm talking about

10 29 15


61

1 then, right?

2 MR. MILLER: Some do, some don't. Yes.

3 THE WITNESS: Right.

4 Q (BY MR. LITTLE) What is it?

5 A Just -- it's a -- it's a vitamin that opens up your

6 blood capillaries; and it helps, like, flush out stuff

7 out your body. So sweats gets you more vascular and so

8 forth.

9 Q It's called pre workout?

10 A Yeah, but we don't use that at Narconon. Just giving

11 you an example of what Niacin -- Niacin's in

12 everything. Peanut butter, bread.

13 Q How did you learn that the sauna program gets rid of

14 drug toxins? Where did you get that information from?

15 A It's part of the Narconon program.

16 Q Okay. How do you -- how -- did you receive any

17 training in the Narconon program?

18 A And do I -- well, I don't deliver the program.

19 Q But I mean, like, so if you're going to -- you know,

20 you told me you were in charge of these three

21 gentlemen, Stephen, Brad, and Tony, that answer

22 questions about the program when people call in. How

23 did you get the knowledge to help them answer the

24 questions?

25 A I've read all the books.

62

1 Q Okay.

2 A I did the sauna.

3 Q Okay. Why did you do the sauna? Just to see what --

4 A See what it was like. I just did it for the second

5 time.

6 Q Okay. Do you know -- you attend any trainings by

7 Narconon International or anything like that?

8 A No.

9 Q Okay. Do you know who Bobby Wiggins is?

10 A Mm-hmm.

11 Q Who is Bobby Wiggins?

12 A Barbie's wi -- her husband.

13 Q Who's Barbie?

14 A His wife.

15 Q I mean what's Bob -- what's Bobby Wiggins' relationship

16 to Narconon, if any?

17 A He works at a Narconon, like, out in California. One

18 in OIJA.

19 Q Does he ever come to Narconon Freedom Center?

20 A Yeah, I've seen him a couple times.

21 Q What does he do when he's at Narconon Freedom Center?

22 A He came in, did a drug education seminar.

23 Q Did you attend that seminar?

24 A Mm-hmm.

25 Q And what was the goal of that seminar?

63

1 MS. KLAUS: Objection to foundation.

2 If you know.

3 THE WITNESS: I do know. He talked about how

4 he owned a bar, and he talked about his own drug use

5 and how he became more cause over his situation. You

6 know, when he got clean and sober and was able to be,

7 like, productive. He was kind of , like, giving a

8 motivational speech.

9 Q (BY MR. LITTLE) And he works for Narconon

10 International?

11 A I don't know if he does or not.

12 Q Do you ever receive any calls, or do you ever receive

13 any referrals from a call center in Glendale,

14 California?

15 A I don't know that to be where the location is.

16 Narconon International, we get calls from them.

17 Q And referrals?

18 A Not referrals. I mean they're calling in. It's like a

19 "where to buy."

20 Q What do you mean by --

21 THE REPORTER: Like a...?

22 THE WITNESS: A "where to buy." A "where to

23 buy." Like, it's territorial. If you're in Ohio,

24 you'd be -- and you're looking for a Narconon close to

25 you, you go to the one in Michigan.

64


17/38


2 A Or, if a family member wants to get someone far from

3 home, they would call facility. It's like a "where to

4 buy."

5 Q I got ya.

6 A You can't find Dr. Pepper in your area, you call

7 Dr. Pepper, and they tell you to go to 7-Eleven on the

8 corner of Third and Eighth or wherever.

9 Q Got ya. Do you receive any training from Narconon Free

10 -- from Narconon International in procedures on intake

11 or anything like that?

12 A I mean there's a -- there's a manual, like, on how to

13 do the paperwork.

14 Q What's the manual called?

15 A Procedures and policies.

16 MR. LITTLE: So, if I asked you for the

17 procedures and policy manual, you would be able to get

18 it, Miss Klaus?

19 MS. KLAUS: You can answer that question --

20 THE WITNESS: Maybe.

21 MS. KLAUS: -- get it to him.

22 THE WITNESS: I don't know. I only have one

23 in my office, so probably not that one. But I might be

24 able to rustle one up somewhere.

25 MR. LITTLE: Okay. I'll say Kansas City

10 29 15


65

1 there so I can find it again later.

2 Q (BY MR. LITTLE) Do people from NI or able -- regularly

3 visit Narconon, if you know?

4 A NI? Narconon International?

5 Q Yeah. They ever come to visit?

6 A Not that I've seen.

7 Q Besides Bobby Wiggins or --

8 MS. KLAUS: Objection. He hasn't said if he

9 was --

10 THE WITNESS: I don't know if he -- I don't

11 know if he works for International. I don't know. I

12 think he works for OIJHA.

13 Q (BY MR. LITTLE) Okay. What do you mean "works for

14 OIJHA"? What's OIJHA?

15 A Narconon OIJHA. It's a facility in California.

16 Q Okay.

17 A O-I-J-H-A.

18 Q Do you know Yvonne Rogers?

19 A No.

20 Q Okay. Robert Keifer?

21 A Nope.

22 Q A lady named Margarita, Margarita?

23 A No.

24 Q Okay. Just to go back to the web site for a minute,

25 Rebecca Ryan currently stores it or knows who stores

66

1 and houses the web site?

2 A I mean she would be the one to ask. It would probably

3 just be through International. She does, like,

4 Facebook ads for me now.

5 Q When you say it's through International, what do you

6 mean by that?

7 A Well, Narconon International is our, like, corporate.

8 Q So do they store your web site?

9 A I believe so.

10 Q Okay. Can they edit your web site? Well, I guess they

11 store it.

12 A It's their web site, really. I mean it's not ours

13 anymore. Like, the web site that they host for us.

14 Q Okay.

15 A I mean it's theirs. We don't have our own anymore.

16 MR. LITTLE: All right. Perfect. Thank you

17 very much. I have nothing further.

18 MS. KLAUS: Okay. We're done.

19 THE WITNESS: Cool.

20 (At 3:53 p.m. - Deposition concluded.)

21 * * *

22

23

24

25

67

1 STATE OF MICHIGAN ) )

2 COUNTY OF INGHAM ) 3

4 I certify that this transcript, consisting of

5 68 pages, is a complete, true and correct record of the

6 testimony of TODD MESZAROS, held in this case on October 29,

7 2015.

8 I also certify that, prior to taking this

9 deposition, TODD MESZAROS was duly sworn to tell the truth.

10 I also certify that I am not a relative or

11 employee of or an attorney for a party; or a relative or

12 employee of an attorney for a party; or financially

13 interested in the action.

14

15

16 November 8, 2015 _______________________________ Kristie L. Dickinson, CSR-4667

17 P.O. Box 12133 Lansing, Michigan 48901-2133

18 Firm #8453

19

20

21

22

23

24

25

68


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19/38

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1 7 : 1 1 ; 4 1 : 4 ,

2 5 ; 4 6 : 3 , 7 ,

2 3

b e c a u s e [ 1 3 ]

8 : 4 ; 1 6 : 2 4 ;

2 2 : 8 ; 2 3 : 1 5 ;

2 5 : 7 , 1 8 ;

3 0 : 8 ; 3 7 : 1 9 ;

4 1 : 1 4 ;

4 3 : 1 3 ;

5 1 : 2 5 ;

5 4 : 1 6 ; 5 9 : 2 3

B e f o r e [ 1 ]

1 0 : 1 4

b e f o r e [ 1 3 ]

1 : 1 3 ; 1 0 : 1 4 ;

1 4 : 2 4 ; 2 1 : 3 ;

3 1 : 5 , 6 ;

3 7 : 2 0 ;

3 9 : 2 1 ;

4 1 : 2 5 ; 4 2 : 1 ,

2 ; 4 8 : 1 2 ;

6 1 : 1 0

b e g i n n i n g

[ 1 ] 1 : 1 6

b e h a l f [ 4 ]

2 : 2 , 5 , 8 ;

3 1 : 2 3


20/38

b e h a v i n g [ 1 ]

1 8 : 1

b e i n g [ 2 ]

5 : 1 ; 1 4 : 1 5

b e l i e v e [ 7 ]

6 : 1 6 ; 1 2 : 4 ,

1 2 ; 3 0 : 2 0 ;3 4 : 1 7 ;

5 4 : 1 4 ; 6 7 : 9

B e n d [ 1 ]

2 1 : 2

B e s i d e s [ 1 ]

6 6 : 7

b e s i d e s [ 1 ]

5 0 : 2 1

B e s t [ 8 ]

3 9 : 1 3 , 1 7 ,

2 0 ; 4 6 : 1 4 ,

1 7 , 2 0 , 2 2 ,

2 4

b e s t [ 1 ]

3 8 : 1 3

B e t h [ 1 ]

4 : 2 2

B e t h ' s [ 1 ]

4 : 2 2

B e t t e r [ 1 ]

3 9 : 1 3

b e t w e e n [ 1 ]

4 6 : 2 4

b e y o n d [ 2 ]

2 1 : 1 1 ; 5 0 : 2 2

b i g [ 1 ]

3 3 : 1 0

B i l l [ 1 ]

1 5 : 2 2

b i l l e d [ 1 ]

3 5 : 1 5

b i p o l a r [ 2 ]

3 9 : 4 , 6

b i z a r r e l y [ 1 ]

1 8 : 1

b l o g g i n g [ 1 ]

1 5 : 7

b l o g s [ 1 ]

1 5 : 1

b l o o d [ 3 ]

6 1 : 6 , 1 6 ;

6 2 : 6

B o a r d [ 5 ]

1 2 : 2 , 7 , 1 8 ;

1 3 : 3 , 5

b o a r d [ 1 ]

1 2 : 1

B o b [ 1 ]

6 3 : 1 5B o b b y [ 4 ]

6 3 : 9 , 1 1 , 1 5 ;

6 6 : 7

B o d y [ 2 ]

6 0 : 1 7 , 1 8

b o d y [ 5 ]

5 9 : 1 9 ;

6 0 : 2 0 ; 6 1 : 4 ,

1 5 ; 6 2 : 7

b o o k [ 7 ]

9 : 1 5 ; 3 2 : 1 5 ,

1 6 ; 5 8 : 2 ,

1 6 ; 6 0 : 1 2 ,

1 4

b o o k s [ 1 1 ]

3 2 : 1 7 , 1 9 ,

2 5 ; 5 7 : 2 4 ,

2 5 ; 5 8 : 3 , 4 ,

2 1 ; 5 9 : 2 4 ;

6 0 : 1 2 ; 6 2 : 2 5

b o t h [ 1 ]

3 5 : 1 1

b o u g h t [ 1 ]

2 5 : 9

B o x [ 1 ]

6 8 : 1 7

B r a d [ 2 ]

5 6 : 1 5 ; 6 2 : 2 1

b r e a d [ 1 ]

6 2 : 1 2

b r e a k [ 6 ]

1 8 : 2 ; 1 9 : 2 ,

4 , 6 , 1 1 ;

2 6 : 2 0

B r i a n [ 4 ]

5 3 : 1 5 , 1 9 ;

5 4 : 1 4 ; 5 5 : 1

b r i n g [ 1 ]

5 2 : 1 3

b r i n g i n g [ 1 ]

5 1 : 2 5

b r o a d [ 4 ]

3 7 : 5 ; 3 8 : 1 1 ;

4 8 : 1 5 , 2 0

B R S [ 1 ]

3 9 : 1 6

b u i l t [ 1 ]

3 3 : 2 5B u s i n e s s [ 1 ]

2 1 : 2 1

b u t t e r [ 1 ]

6 2 : 1 2

b u t t o n [ 3 ]

2 4 : 2 0 , 2 1 , 2 2

b u y [ 5 ]

2 2 : 1 7 ;

6 4 : 1 9 , 2 2 ,

2 3 ; 6 5 : 4

b u y i n g [ 1 ]

2 9 : 2

B Y [ 5 1 ] 2 : 3 ,

7 , 1 0 ; 4 : 1 6 ,

2 4 ; 7 : 8 ;

8 : 6 ; 9 : 2 1 ;

1 1 : 1 8 ; 1 2 : 1 ,

1 7 , 2 5 ;

1 6 : 1 1 , 1 6 ,

2 1 ; 1 7 : 1 8 ;

1 8 : 1 0 ;

2 0 : 1 2 , 2 2 ;

2 2 : 2 0 ; 2 5 : 4 ;

2 6 : 6 ; 2 7 : 1 ,

4 , 1 2 , 2 1 ;

2 9 : 8 ; 3 0 : 1 5 ;

3 2 : 3 , 2 1 , 2 5 ;

3 4 : 1 2 ; 3 6 : 6 ,

2 4 ; 4 0 : 2 ,

2 5 ; 4 1 : 1 5 ;

4 3 : 5 , 2 2 ;

4 5 : 1 , 2 1 ;

4 8 : 2 4 ; 4 9 : 1 ,

7 , 1 4 ; 5 7 : 3 ;

6 2 : 4 ; 6 4 : 9 ;

6 5 : 1 ; 6 6 : 2 ,

1 3

b y [ 1 5 ]

1 : 1 2 ; 3 : 4 ;

4 : 2 5 ; 1 0 : 1 5 ;

1 2 : 1 6 ;

1 4 : 1 6 ; 2 0 : 5 ;

2 2 : 5 ; 2 7 : 1 6 ;

3 2 : 2 1 ;

3 3 : 1 3 ;

5 8 : 1 4 ; 6 3 : 6 ;

6 4 : 2 0 ; 6 7 : 6

B y e [ 1 ] 5 2 : 5

- C -

C [ 1 ] 4 : 4

C A [ 1 ] 2 : 9

C A L H O U N

[ 1 ] 1 : 2

C a l i f o r n i a

[ 3 ] 6 3 : 1 7 ;

6 4 : 1 4 ; 6 6 : 1 5

C a l l [ 3 ]

2 5 : 3 , 5 ;

2 6 : 2

c a l l [ 2 1 ]

2 4 : 2 0 , 2 1 ,

2 2 , 2 3 ;

2 5 : 1 3 , 1 4 ;

2 6 : 1 8 ;

2 7 : 2 4 , 2 5 ;

2 8 : 8 ; 3 0 : 3 ;

3 1 : 1 9 ;

4 0 : 1 5 ;

4 7 : 1 2 , 1 3 ;

5 3 : 9 ; 5 9 : 1 3 ;

6 2 : 2 2 ;6 4 : 1 3 ; 6 5 : 3 ,

6

c a l l e d [ 2 2 ]

1 : 1 2 ; 2 5 : 2 ,

8 , 2 0 ;

3 0 : 1 6 , 1 9 ;

3 2 : 8 ; 3 3 : 1 7 ;

3 4 : 3 , 1 4 ;

3 6 : 2 5 ;

4 0 : 1 0 ; 4 1 : 1 ,

6 ; 5 5 : 9 , 1 2 ;

5 7 : 7 , 1 3 ;6 0 : 1 4 , 1 7 ;

6 2 : 9 ; 6 5 : 1 4

c a l l i n g [ 4 ]

2 6 : 1 1 , 1 5 ,

2 5 ; 6 4 : 1 8

c a l l s [ 5 ]

2 4 : 7 , 1 3 ;

Date post:	07-Aug-2018
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Tyler v. Scientology: Meszaros Deposition

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