tyler v. scientology: scott deposition

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

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1 MR. LITTLE: Well, I believe she was offered

2 to talk about the treatment program.

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

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

5 MS. KLAUS: Look at my objections , not your

6 notice. My designations.

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

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

9 let's start with treatment... Okay , the education10 program. All right.

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

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

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

14 Freedom Center .

15 A Currently ?

16 Q Yes, please .

17 A Director of Income.

18 Q Director of Income?

19 A Yes.

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

21 A Maybe a week or so.

22 Q What did you do before then?

23 A When Ms. Tyler was here?

24 Q Well, let's go backwards immediately before you were

25 Director of Income .

10 29 15

DICKINSON REPORTING, INC.(517) 487-1072

5

1 A I worked with getting documentation to the insurance

2 biller.

3 Q And how long did you hold -- what was the title for

4 that job?

5 A Medical Records Admin.

6 Q And how long did you work in Medical Records7 Administration?

8 A About 18 months.

9 Q Okay. When did you start with Narconon Freedom Center?

10 A 2011.

11 Q Okay. What did you do when you started in 2011?

12 A I was a withdrawal specialist.

13 Q Okay. What's a withdrawal specialist?

14 A Withdrawal specialist helps people get through

15 nonmedical withdrawal symptoms.

16 Q Are you a nurse?

17 A I am not.

18 Q What's your educational background?

19 A I have -- I have a Bachelor of Science degree from

20 Purdue University in management.

21 Q In man -- a BS in , like , business manage ment ?

22 A Yes.

23 Q Okay. And when -- I'm from Purdue . Okay . You're from

24 Indiana?

25 A Yes.

6

1 Q Okay. So are we. Where are you from?

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

3 here ?

4 Q Originally , I guess .

5 A Conner sville , Indiana.

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

7 is that out east by Richmond?

8 A Yes.

9 Q Okay. I do actually know. That's a small place .10 A Very small.

11 Q My fiancé e 's from Winchester.

12 MS. KLAUS: Okay . Can we just get to the

13 question and answer , please ?

14 MR. LITTLE: Okay . I'm just...

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

16 withdrawal specialist , then what did you do for

17 Narconon Freedom Center ?

18 A I was family l ia ison.

19 Q When did you start that job?

20 A 2012, February.

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

22 A It was, I believe, August.

23 Q Okay. And then how long were you family liaison for?

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

25 Q Then what did you do?

7

1 A I don't remember the title , but then I was a supervisor

2 of the family liaisons.

3 Q And then what -- how long did you hold that job?

4 A A couple of months , then I started student services.

5 Q Okay. And when did you start student services?

6 A January of 2013. 7 Q And then when did you stop student services?

8 A July of 2013.

9 Q Okay. What are student -- what is a Director of

10 Student Services?

11 A Assist students , for instance , with -- if they need to

12 make orders for shampoo, soap, that type of thing, if

13 they would like to order tobacco products , then we

14 order that for them . Because they don't leave the

15 facility to get that on their own.

16 Q Okay .

17 A So we place orders for them.

18 Q Okay. So, prior to 2011, did you have any familiarity

19 with the Narconon Program?

20 A No.

21 Q Okay. Have you -- well, tell us, what is the Narconon

22 Freedom Center Education Program?

23 A Specific parts of the program , or can you be a little

24 bit more specific ?

25 Q Yeah . Well , to be hon est with you , I'm trying to

8


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1 figure out -- well , can you tell me what's your

2 interaction with the Narconon Freedom Center Education

3 Program? Like , what -- have you ever -- do you

4 administer it?

5 A Not any more.

6 Q Okay. But you did?

7 A In the withdrawal area .

8 Q Okay , and tell me about that. When -- so this was a --

9 2011?10 A Yes.

11 Q Okay. So what did you do when you administered the

12 Education Program in the withdrawal area?

13 A People are withdrawing from drugs , so you make them as

14 comfortable as you possibly can to try to help them

15 through the withdrawal symptoms.

16 Q Mm-hmm .

17 A You help them stay out of their head so they don't

18 become depressed, you administer as sist to them , which

19 it's not really a massage . What it does is relax the

20 body so they can sleep . Individuals coming off of

21 heroin often can't sleep . It helps them get their

22 much-needed rest , administer vitamins, make sure they

23 eat healthy meals.

24 Q Well --

25 A If they're having a bad day , what you do is assist them

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9

1 and help them with whatever's going on with them.

2 Q Okay. So -- okay . Tell us about an as sist. What's an

3 assist?

4 A What it does is it helps to relax the individual's body

5 because sometimes their body aches, they're very tired,

6 too tired to the point where they can't sleep.7 Basically what you do is you just go down a person's

8 arms and maybe on their back --

9 Q So it's a physical?

10 A -- back of legs. Yeah , it 's physical. We do -- we are

11 very much informed to not get close to personal areas.

12 It's very much restricted.

13 MR. LITTLE: You know, we're -- I'm confused

14 as to how this person is the designee on the Education

15 Program .

16 MS. KLAUS: Why don't you just ask the

17 questions , and she can an -- ask questions --

18 MR. LITTLE: She does -- she has no idea

19 about any of the --

20 MS. KLAUS: You haven't even asked her , so

21 how do you know ?

22 MR. LITTLE: Because I just went through h er

23 job duties , responsibilit ies. She's never had anything

24 to do with education.

25 MS. KLAUS: It doesn't mean she's not here to

10

1 talk a bou t it if you ask her the questions , Jonathan.

2 MR. LITTLE: Okay. All right.

3 Q (BY MR. LITTLE) So let's start at the beginning then .

4 If somebody comes into Narconon, a new patient --

5 A Mm-hmm.

6 Q -- what -- what happens ? What's the -- what is the

7 protocol ?

8 MS . KLAUS : That's the intake . That's the

9 next person.10 MR. LITTLE: Yeah. Well , I'm trying to get

11 to how they would end -- end up in the educational

12 portion of the program , Miss Klaus , so --

13 MS. KLAUS: I think she testified to how that

14 starts when she talked about the withdrawal program.

15 Q (BY MR. LITTLE) Okay. So after -- during the

16 withdrawal , what kind of education do you administer or

17 give?

18 A We try to make them com -- learn how to be comfortable

19 where they're at.

20 Q Like , what does that entail?

21 A What we d o, we call them -- it was called a training

22 routine, and you learn how to be -- to sit there and be

23 comfortable where you're at and try to clear your mind

24 of thoughts of the past and things that are making you

25 depressed . Just be comfortable where you're at in your

11

1 current, present environment.

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

3 about the training routine . What's the training

4 routine consist of?

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

6 facing each other. 7 Q Mm-hmm.

8 A And you have to be three feet apart. And it makes you

9 comfortable in your environment and around other

10 people. So that's the purpose of the other person.

11 Q So you sit three feet apart , and then what do you do?

12 A What you do is -- there are two different types that we

13 have them do -- do in the withdraw [sic] area . One

14 with eyes closed , and then the other with eyes open

15 where you look right at the person, and it helps them

16 with confront.

17 Q Okay . So when -- when you do -- let's talk about the

18 eyes closed .

19 A Mm-hmm.

20 Q Which one do you do fir st, eyes closed or eye s open?

21 A Eyes close d.

22 Q Okay. So tell me , so, if we're both sitting three feet

23 apart from each other with our eyes closed , what --

24 what do the -- the people do?

25 A Qui et, very qui e t , much like a meditation.

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1 Q No speaking?

2 A No speaking.

3 Q Okay. And how long do they do that for ?

4 A It's done on a gradient. It depends on the individual

5 and what they're comfortable w ith, and then they work

6 up . I don't really remember the time frame we would

7 have them do it in the withdrawal area because , as I

8 said , a lot of times they are not feeling well

9 sometimes. As they begin to feel better , it kind of 10 helps them become more -- more comfortable in their

11 present environment.

12 Q So they -- they sit three -- and is there a goal time

13 like , if once you do eyes closed for X time , you move

14 on to eyes open ? Is that how that works or --

15 A Actually , it -- it's alternated.

16 Q Okay .

17 A They may do five minutes of eyes closed and then

18 however long they feel comfortable doing eyes open.

19 Q What, do they -- they speak to each other during eyes

20 opened?

21 A They do not .

22 Q Okay. How long do they sit three feet apart from each

23 ot her ?

24 A However long is comfortable for that individual . We're

25 trying to get them to increase each time ; but , for a

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13

1 withdrawal student, ten or fifteen minutes.

2 Q How many t imes a day?

3 A It just all depends on the activity in the withdrawal

4 unit and what that person is comfortable with.

5 Q So how long -- so once you -- is there a -- a goal of

6 this sit ting across from each other , like a goal time7 period before you would advance?

8 A The advancement out of withdrawal really isn't the

9 passing of a training routine, it is getting through

10 the withdrawal symptoms. That's what determines

11 whether or not they move on to the next step.

12 Q Okay. What other educational activities take place in

13 withdrawal?

14 A That's about it for that point because most of the time

15 they're not feeling good , we're just trying to get them

16 to feel better , eat better , and get sleep . And then

17 they move on to the next step.

18 Q All right. You have mentioned vitamins .

19 A Mm-hmm.

20 Q What kind of vitamins did you give?

21 A It's -- it was called withdrawal vitamins. I don't

22 know what's in -- involved with the withdrawal

23 vitamins.

24 Q You d on't know what kind of vitamins they were or

25 anything?

14

1 A No . I don't know what the mixture is.

2 Q Okay. You said " confront. " What does it mean to learn

3 to confront?

4 A Okay. For instance, a drug addict cannot look at you

5 like I'm looking at you right now . They're very

6 uncomfortable , they're -- they're ashamed of

7 themselves , excuse me , they don't have any confidence .

8 And what that does is kind of help -- help them come

9 out of their shell a little bit and begin to gain10 confidence.

11 Q Now, do you have any training in addiction counseling?

12 A I do not.

13 Q Okay. Were you the supervisor in the Withdrawal Unit

14 in 2011?

15 A I was not.

16 Q Who was the supervisor?

17 A I don't remember her name.

18 Q Okay. Was there a doctor around?

19 A We have a center medical director.

20 Q And where -- is his office at 809 --

21 A It is not.

22 Q Where is h is office?

23 A I don't know.

24 Q Is it a he or she ? I guess I don't know .

25 A It's a he.

15

1 Q A physician?

2 A Yes.

3 Q Who -- and who was that -- who is that now?

4 A Dr. Martin Holmes.

5 Q And who was it in 2012?

6 A Dr. Martin Holmes. 7 Q Okay. Okay. So , after the training or the first

8 exercise , is that a good -- the eyes closed , eyes open?

9 A Yes.

10 Q How would you -- how would you call that?

11 A The first set of drills.

12 Q The fi rs t set of dri ll s , okay .

13 A Yes.

14 Q Is there any literature or anything at that time?

15 A No.

16 Q No.

17 A They move on to the next phase of the program.

18 Q What's the next phase of the program?

19 A They go in and learn more extensive communication

20 drills.

21 Q Okay. And what are those drills?

22 A Basically learning how to acknowledge when people speak

23 to you, learning how to communicate effectively with

24 others.

25 Q So what -- what kind of -- are there any materials

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1 provided or anything?

2 A There are. There are books.

3 Q Okay. And where -- what are those books called?

4 A At the time Candice Tyler was here , that was -- those

5 were the books. Book 1 .

6 Q Book 1?

7 A Yes.

8 Q Who -- do you know who wrote Book 1?

9 A There is a -- okay, you have it right there.10 Q Is it -- is it -- okay , so I'm just --

11 A You've got a Book 3 and a Book 5 and a Book 6.

12 Q And just --

13 A I don't know who wrote it.

14 Q Okay. But this is -- is this the correct series?

15 A Yes, it is .

16 MS. KLAUS: For -- wait a minute , I'm going

17 to object to the form.

18 THE WITNESS: Oh , sorry.

19 MS. KLAUS: Correct series for what ?

20 MR. LITTLE: The books, the -- the series

21 one --

22 Q (BY MR. LITTLE) How -- how many levels of the -- the

23 learning improvement course are there?

24 A Now or when Ms. Tyler was in the program?

25 Q Let's start with when Ms. Tyler was in the program .

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17

1 A Eight .

2 Q And how much are there now?

3 A One, two, three, four, five.

4 Q There's five?

5 A Yes.

6 Q Okay. So tell us what Level 1 is or what learning7 improvement course one is, Book 1, I guess.

8 MS. KLAUS: Objection.

9 Q (BY MR. LITTLE) Actually , you know what ? What would

10 you call the first book or course ? What i s it called ?

11 MS. KLAUS: Objection to form.

12 If you understand what he's asking --

13 THE WITNESS: I -- I don't really. Are you

14 looking for a title of the book?

15 Q (BY MR. LITTLE) Right. Where we -- where --

16 A I don't remember the title.

17 Q Okay. What -- what is the entire course called?

18 A Okay, the entire program or each book or --

19 Q Yeah, yeah, number -- so number one . After you do the

20 eyes closed , eyes opened, you move on to -- you --

21 A That's also part of the next step --

22 Q Okay .

23 A -- at a higher gradient.

24 Q What's the next step called ? Do you know?

25 A I don't remember.

18

1 Q Okay, but you said there was eight ste p s , eight

2 course s?

3 MS. KLAUS: " She ," you mean Candice Tyler ?

4 Q (BY MR. LITTLE) When Candice Tyler was there , there

5 were eight courses?

6 A Yes.

7 Q Okay. Okay. So does everybody go through the same

8 eight courses ?

9 MS. KLAUS: You mean did they back then?10 Q (BY MR. LITTLE) Well, let's start with, yeah, back

11 then did they all go through the same eight courses in

12 2012, do you know?

13 A Yes.

14 Q Okay. And those eight courses, where did those

15 materials come from for the eight courses?

16 A I don't know.

17 Q How did you get the materials to teach people?

18 A O h, it was given to me by a course supervisor .

19 Actually , not given to me , but they're given to the

20 students by the course supervisors.

21 Q And who was the course supervisor in 2012?


23 Q Who's the course supervisor now?

24 A I -- it varies.

25 Q If I wanted to get a complete set of the course

19

1 materials now, who would I contact?

2 A I don't know.

3 Q Do you know where they're kept at Narconon?

4 A I don't, I don't. I don't work in that area , so I

5 don't know where the books are kept.

6 Q Okay. What about in 2012 or ' 13, who -- do you know 7 where I would -- who I would contact to get a complete

8 set of materials from 2012 or '13?

9 A I don't know that either.

10 MR. LITTLE: I would just like to state on

11 the record that I'm trying to take a discovery

12 deposition. I want a complete set of the course

13 materials , and the witness doesn't know where to get

14 them.

15 MS. KLAUS: She's not the attorney , so that

16 doesn't surprise me that she wouldn't know where to get

17 the books from three years ago. And she's not offered

18 as to the location of books . She's offered to talk

19 about the program . So , if you have questions about the

20 program, ask her.

21 MR. LITTLE: Okay.

22 Q (BY MR. LITTLE) So tell us about the eight-ste p

23 program from 2012. How -- how did -- how are the eight

24 steps divided?

25 A Into eight step s.

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1 Q Right. What are -- like, what's step number one?

2 A It would be the communications course.

3 Q Okay. So can you tell me about the communications

4 course?

5 A People learn how to communicate better .

6 Q Okay . What kind of activities do they do?

7 A Communicat ion dri ll s.

8 Q Like , can you give me examples of communication drills?

9 A For instance, if I was partnered with you, then what we10 would do is work on -- first it starts at a very l ow

11 gradient , and then you would learn how to respond to me

12 during a conversation to acknowledge that you've heard

13 me. And then they learn how to deal with difficult

14 communication. So you would pretend to be

15 antagonistic , and I would have to learn how to deal

16 with that.

17 Q Okay. And so what -- when you say " low gradient ," what

18 do you mean " low gradient "? What does that mean?

19 A They don't start out too hard at first , too difficult

20 at first . They first learn how to re -- first they

21 respond to a communication , then it begins to get a

22 little bit more difficult . Then comes the antagonis --

23 the antagonism, or people trying to get off the

24 subject, that type of thing . And you learn how to

25 handle that, how to get them back into what you need

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21

1 for them to -- to talk to you a bou t.

2 Q Okay. So when you say easy -- like , a less combative

3 first question , can you give me an example of the first

4 question?

5 A There are some in -- they're demonstrated in the book ,

6 and I believe you can use either Do Birds Fly or Do7 Fish Swim .

8 Q And how often do you repeat that question?

9 A Depends on the drill. Depends on that -- the back and

10 forth with the drill.

11 Q Well , I mean , in the first drill , how often do you guys

12 go back and forth?

13 A We don't really count the number of times. They don't

14 count the number of times. It's more like you drill

15 until you're comfortable that that individual is

16 comfort able with -- the two people involved are

17 comfortable with performing that action.

18 Q Were you -- did you participate in these courses

19 yourself?

20 A I did.

21 Q Okay. Where did you do your training at , or where did

22 you participate in these courses at?

23 A Narconon Freedom Center.

24 Q Okay. Was that during the course of your employment?

25 A No.

22

1 Q When was it?

2 A It was previous to my employment.

3 Q Okay. Were you there as an employee or as a patient ?

4 MS. KLAUS: We're not going to -- she's not

5 going to answer any questions about her personal

6 medical history.

7 MR. LITTLE: I'm just trying to figure out

8 how she got trained in these courses, and she's the

9 person most knowledge able on education , so I thi nk I10 have the -- I'm entitled to k now how she got trained on

11 them.

12 MS. KLAUS: No , we're not saying she's the

13 person most knowledgeable. I don't understand why you

14 can't read The Court Rules. The Court Rule sa y s you

15 per -- put a person up who's going to speak on behalf

16 of the company about that. It doesn't have to be the

17 person most knowledgeable --

18 MR. LITTLE: Well, if she --

19 MS. KLAUS: -- and she's not here to testify

20 about any personal medical history.

21 MR. LITTLE: This is a discovery deposition .

22 I'm trying to figure out where she was trained on these

23 courses . She can't tell me where the books are kept ,

24 she can't tell me -- I mean --

25 MS. KLAUS: Okay.

23

1 MR. LITTLE: -- there's a lot of specific --

2 I mean who -- how am I suppose d to know w here -- what

3 I'm asking for if the person that you designate to

4 speak about it doesn't know where it is ?

5 MS. KLAUS: She -- I don't know what you

6 d on't understand about how discovery works , Jonathan ; 7 but I'm not here to educate you on how discovery works .

8 MR. LITTLE: Okay. Well, I'm --

9 MS. KLAUS: I suggest you get a copy of the

10 Michigan Court Rules and read them.

11 MR. LITTLE: I would like to -- to do this

12 without --

13 THE REPORTER: One at a time.

14 MS. KLAUS: If you want a set of books, why

15 didn't you ask me for a set of books? But you didn't .

16 Instead , you're asking her if she knows where the

17 facility books from 2012 are lo cated, which is a

18 patently ridiculous question, but I'm not objecting

19 because I want to get this thing over with .

20 MR. LITTLE: Well --

21 MS. KLAUS: But you're not going to ask her

22 about her personal medical history.

23 MR. LITTLE: I'm trying to figure out when

24 the person des ignated to speak on behalf of the company

25 went through the training that she was designated to

24


7/39

1 speak about.

2 MS. KLAUS: Well , maybe she didn't go through

3 the training .

4 MR. LITTLE: Well , she said she did.

5 MS. KLAUS: Well, she's not -- I don't --

6 Did you say you went through training ?

7 THE WITNESS: I don't recall.

8 MS. KLAUS: Yeah . She went through the

9 program . That's not the same thing as going through10 training . But she's not going to talk a bou t her

11 experience in the program on a personal basis . She's

12 talking about the program.

13 MR. LITTLE: Al l right , we get it , we get it .

14 I disagree with you .

15 MS. KLAUS: Okay.

16 MR. LITTLE: There will be a motion to compel

17 a more appropriate designee , but we're trying to get

18 through this. Okay. So, ma'am --

19 MS. KLAUS: Maybe you should finish the de p

20 before you make that conclusion.

21 MR. LITTLE: Al l right.

22 Q (BY MR. LITTLE) Ma'am, so you've -- you've been

23 through this program yourself , correct ? The eight-ste p

24 program?

25 A I've done the books , correct.

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25

1 Q All of it, the eight that were in 2012?

2 A Yes.

3 Q Okay. Now, have you ever been trained in how to

4 administer this program?

5 A I have not.

6 Q Has anybody at your facility -- first in 2012, was7 anybody at your facility training people in this

8 program?

9 A In 2012, yes.

10 Q Okay. And who were the trainers in 2012?

11 A I don't recall.

12 Q Okay. Who are the current trainers?

13 A There are different ones in the facility , but they have

14 also been trained in that , so they train other s.

15 Q Right. What are their names?

16 MS. KLAUS: You can go ahead and give their

17 names.

18 THE WITNESS: Okay. Sawyer Grose.

19 Q (BY MR. LITTLE) Sawyer?

20 A Mm-hmm.

21 Q S-a --

22 A W-y-e-r G-r-o-s-e. He's the main one.

23 Q Okay. Now, does Mr. Grose -- does he go to any

24 workshops about how to administer this program or --

25 A I don't know.

26

1 Q Okay. Who are the other trainers?

2 A Is this currently , or from 2012?

3 Q Well , if you remember any from 20 12 , but you said you

4 didn't .

5 A I don't remember from 20 12.

6 Q So currently?

7 A And could you repeat the question , please ?

8 Q Who are the other current train ers in this program?

9 A Actually, he's the main one. He is the designated10 trainer currently.

11 Q Okay. And who does he -- and he -- when -- does he

12 train -- who -- do you know who he trains ? Like , who

13 does he train to administer this course?

14 A Staff-wise, those that are interested in learning it.

15 Q Okay. And is there a certification when you complete

16 his training, Sawyer's training?

17 A I don't know.

18 Q Okay. All right. So, in 2012, you state d there were

19 eight books. You stated you don't remember the names

20 of them ; is that correct?

21 A Correct.

22 Q Okay. How are the books -- how are the eight courses

23 divided ?

24 MS. KLAUS: Asked and answered. If you can

25 add anything...

27

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

2 and when Course 2 starts?

3 A As you go through the book , when you're finished , the

4 book , if someone -- if it's -- it's -- they've

5 satisfied the criteria for that book , they move on to

6 the next one. 7 Q Is anything in the book -- is there any , like , you

8 completed Course 1 or Book 1 , here's a certificate ; or

9 how -- how do you verify that a student has complete d a

10 course?

11 A Now or in 2012 ?

12 Q In 2012 .

13 A In 2 -- 2012 , they did receive a certificate .

14 Q Okay. And now?

15 A I don't know.

16 Q Okay. Now, these books, they say on the cover , " Based

17 on the works of L. Ron Hubbard " ?

18 A Correct.

19 Q Okay. Is it based on the works of anybody else besides

20 L. Ron Hubbard?

21 A I don't know.

22 Q Okay. As -- as the person designated to speak on this

23 on behalf of Narconon Freedom Center , in the -- all

24 eight books, do you know if anybody else's work is

25 cited?

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1 A I do not know.

2 Q Okay. Which works of L. Ron Hubbard are these courses

3 based on?

4 A I don't know.

5 Q Okay. Narconon advertises that they can customize

6 these programs for each individual.

7 MS. KLAUS: Objection to -- objection to

8 foundation.

9 MR. LITTLE: Okay .10 MS. KLAUS: That's -- you're trying to create

11 evidence when it isn't there . If you have a document

12 that says that , that's fine.

13 MR. LITTLE: Than ks.

14 MS. KLAUS: But you can't just make that

15 statement and then ask her questions about it --

16 MR. LITTLE: Thanks.

17 MS. KLAUS: -- as if it were true.

18 MR. LITTLE: Thanks for your comment,

19 Counsel. Okay. So --

20 MS. KLAUS: It's an objection , it's not a

21 comment.

22 MR. LITTLE: T hank you for your comment,

23 Counsel.

24 Q (BY MR. LITTLE) All right. So are -- is this program

25 customizable for each student?

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29

1 A Don't know.

2 Q So as the -- as the person designated to speak on

3 behalf of Narconon Freedom Center , you don't know if

4 this eight-step program in 2012 is customizable for

5 each patient?

6 A I do not know that.7 Q Currently, do you know if this now five-step program is

8 customizable for each patient?

9 A That, I don't know either.

10 Q Do you know where -- where these -- where the

11 eight - step books come from?

12 A I don't.

13 Q Do you know who orders them?

14 A No idea.

15 Q If I wanted to get a copy -- if I -- if you want ed to

16 get a copy, how would you get them?

17 A I -- I would have to ask around because I have no idea.

18 I would -- I would just pick staff members and ask them

19 becau -- and ask in they knew . I have no idea . I have

20 no idea how to get them.

21 Q Okay. What i s a TR?

22 A Training routine.

23 Q Okay. And , tell me , what does a training routine mean?

24 A It's a drill, basically a communication drill.

25 Q Can you give me an example? Is this -- go ahead .

30

1 A We've already discussed it . Right.

2 Q Which one was a TR ? Is that the canaries -- Do Birds

3 Fl y ?

4 A Yes.

5 Q Okay. Is -- is the eyes closed , eyes open , is that a

6 TR?

7 A Yes.

8 Q Okay. What is the go a l of teaching people how to

9 communicate , teaching drug users how to communicate?10 A Drugs are normally a problem but not the problem. And ,

11 through better communication, they're more able to

12 confront their problems, be more confident , and won't

13 -- hopefully , it' s just part of the foundation of what

14 they learn ; but it does help them move forward in

15 learning how to confront their problems , communicate

16 with others , and not run to drugs to avoid what's wrong

17 with them -- what's wrong -- what's wrong with their

18 life.

19 Q Okay . And what do you base -- what do you base that

20 statement on ? Or what -- how does the -- what's the

21 statement based on ? Any empirical research or

22 anything ?

23 MS. KLAUS: Objection to form and foundation .

24 THE WITNESS: Empirical research ? I'm not

25 aware of any empirical research . I don't know .

31

1 That's --

2 Q (BY MR. LITTLE) Okay. Okay.

3 A Doesn't mean it doesn't exist, I just don't know what

4 it is.

5 Q Okay. What are some of the other drills associated

6 with Course 1 besides Do Birds Fly and Do Fish Swim ? 7 A You have to learn how to request something from someone

8 and get your point across so that they can react and do

9 what you ask them to do.

10 Q Okay. I mean you gave a very specific example before

11 of Do Fish Swim .

12 A Mm-hmm.

13 Q There's nothing like you c an think of for -- for that ?


15 If you understand what he's asking , go ahead.

16 THE WITNESS: I'm not quite sure what you're

17 asking.

18 MR. LITTLE: I would appreciate it if counsel

19 would let the client testify.

20 MS. KLAUS: And I would appreciate it if you

21 would ask a question to which she could answer , so

22 there you are.

23 Q (BY MR. LITTLE) Okay. So you gave the specific

24 example Do Fish Swim , Do Birds Fly --

25 A Correct.

32


9/39

1 Q -- right?

2 A Correct.

3 Q And then you said, you know, there's -- that you called

4 that a low gradient question .

5 A Correct.

6 Q Okay. What's the next gradient up kind of question?

7 A Someone tries to get off topic , and you guide them back

8 onto top ic.

9 Q Can you give me an example of that?10 A For instance -- this is a good example . For instance,

11 okay, if you have a question and I go off on a tangent ,

12 and you don't get your answer, what would you do? Ask

13 the question again.

14 Q Okay. And what kind of grad ient question is that ? Or

15 what kind of gradient ? Is that like middle or --

16 A It's m id level, yes .

17 Q Okay . And where do these gradients com e from ? Do you

18 know who originated the different gradients with the

19 types of questions?

20 A I don't.

21 Q Okay. What are -- then what are some of the other

22 drills in Course 1?

23 A Very similar , only maybe a little more resistance to a

24 question or a request of an action.

25 Q Okay . I s there any clay modeling in Course 1? You

10 29 15


33

1 build any clay models?

2 A I don't recall.

3 Q Okay. So what's -- when do -- how do you know if -- or

4 how does one complete Course 1? What's the last

5 gradient of Course 1?

6 A When they can communicate smoothly , get -- with7 confidence, get their point across, and handle any type

8 of obstacle that they may come in contact with . For

9 instance , someone not responding , not giving them the

10 answer that they're look -- not the answer they're

11 looking for but getting someone's attention , being able

12 to communicate effectively w ith that person , and

13 getting the appropriate response.

14 Q And who's the judge of the person -- the subject has

15 completed it ? Who's the judge that that's good enough?

16 A There's a supervisor in the area.

17 Q Okay. A nd who wa s the 2012 supervisor?

18 A I don't know.

19 Q Who was the 2013 supervisor?

20 A Don't remember.

21 Q 2014 supervisor?


23 Q Current supervisor?

24 A Sa wyer Grose.

25 Q Okay, Course 2 . What's Course 2 ? Narconon , what's

34

1 the --

2 A Sauna.

3 Q Oh, the Book 2 is the sauna?

4 A Yes.

5 Q Okay. And tell me about the sauna .

6 A Sauna is a program where you basically sweat out all

7 the drug toxins that are in the body.

8 Q Okay. And is there any scientific research you can

9 point to that says that you can sweat out drug toxins?10 A I don't know.

11 Q Okay. What do you -- how long -- tell us about the

12 sauna . How hot is it?

13 A I don't know.

14 Q Okay. How long do you stay in the sauna?

15 A The sauna period, itself , can last five hours. Now ,

16 the individuals are not in the sauna box five hours.

17 As a matter of fact , that's strictly prohibited.

18 Q How -- how long are they actually in the sauna box?

19 A Everybody's different. Everybody's different. What we

20 -- what -- it's my understanding what we do tell people

21 to do is , when they begin to feel uncomfortable , they

22 must come out. Cool off, drink water.

23 Q Is there any restriction on the amount of water someone

24 can drink during the time they're in the sauna?

25 A No.

35

1 Q In the sauna , can you drink water ? Like , in the

2 literal sauna , can you drink water?

3 A I don't know.

4 Q Are they -- do you consume any vitamins when you're in

5 the sauna?

6 A Yes , they do. 7 Q What type -- what kind of vitamins do you consume in

8 the sauna?

9 A That, I don't know.

10 Q Are there any other supplements consumed in the sauna

11 besides the vitamins?

12 A Oils.

13 Q What kind of oils are consumed in the sauna?

14 A Don't know.

15 Q Is there any literature that goes along with the sauna

16 program , like a book for the sauna program?

17 A Yes.

18 Q Okay. And where -- what's -- what's contained in that

19 book? What -- is it -- can you tell me about the book,

20 about the sauna program ? Can you tell me a bou t it?

21 A I can't.

22 Q Okay. Is there a doctor on site when people are in the

23 sauna?

24 A No.

25 Q Is there a nurse on site when people are in the sa una?

36


10/39

1 A Absolutely.

2 Q All the time?

3 A Be specific.

4 Q Like , if there's somebody in the sauna , is it a

5 guarantee there's a nurse at 8 : 09?

6 A Yes.

7 Q Okay. And that's same -- that's true in 2012 as well?

8 A Yes.

9 Q Okay. So what is the -- what is the goal behind -- you10 said sweat ing out the drug toxins ; is that right ? The

11 goal behind the sauna is to sweat out the drug toxins?

12 A Correct.

13 Q Okay. Why do you want to sweat out the drug toxins?

14 A To detoxify your body , to my understanding. Detoxify

15 the body , you start to begin to feel better . Just like

16 a body detox like , okay , you see detox e s advertise d.

17 Why would people do that ?

18 Q Are you familiar with the purif i -- are you familiar

19 with a term " the purification ritual " ?

20 A No , not that term.

21 Q Purificat -- purification rundown?

22 A No.

23 Q Okay. So you've not heard the term " purification

24 rundown " ?

25 A Not purification rundown , no.

10 29 15


37

1 Q Scientology purification rundown , never heard it?

2 A No . No, I'm not familiar with Scientology.

3 Q Okay. So these -- these harmful toxins --

4 A Mm-hmm.

5 Q -- where are they stored in your body?

6 A Fat cells.7 Q Okay. Do you have any medical basis?

8 A I have none.

9 Q Okay. In fat cells generally or any specific areas o f

10 fat cells?

11 A Don't know.

12 Q Do harm -- do these toxins -- or are they the same as a

13 thetan?

14 A I don't know what a thetan is.

15 Q So -- okay, so how many days do you spend in the sauna

16 program?

17 A Each individual is different.

18 Q Who decides when somebody is through with the sauna

19 program?

20 A That, I'm not sure.

21 Q Okay. So how do you know if somebody sweated out their

22 tox -- their toxins?

23 A I don't know.

24 Q Okay. So how do you decide when somebody goes on to

25 Course 3?

38

1 A That, I'm not familiar with. Whenever it's determined

2 that they finished the sauna part of the program ; and ,

3 unfortunately , I don't know how that's determined.

4 Q Okay . How -- how big is the sauna?

5 A I don't know. Need more specifics like square --

6 MS. KLAUS: We designated another person to

7 talk about the sauna program . Maybe you want to save

8 these questions for that person . Just a suggestion .

9 MR. LITTLE: Well , you -- this -- I asked her10 what Course 2 in the education is . She's the education

11 person , so I'm asking.

12 MS. KLAUS: She's also not the person

13 designated to talk about the sauna program .

14 MR. LITTLE: Okay. Well --

15 MS. KLAUS: Just so that's clear.

16 MR. LITTLE : Okay. Well, who's designated to

17 talk about the sauna program ?

18 MS. KLAUS: Kirk Harwood.

19 MR. LITTLE: Okay, good.

20 MS. KLAUS: For now.

21 Q (BY MR. LITTLE) So, when you complete the sauna

22 program, which you don't know how to -- you don't know

23 when somebody would -- you're not familiar with when

24 somebody would have completed the sauna program , what

25 the met ric is to complete the sauna program , right?

39

1 A Correct.

2 Q Okay. Course 3, are you familiar with the learning

3 improvement course?

4 A Yes.

5 Q Okay. Can you tell me about the learning improvement

6 course? 7 A Learning improvement course helps people sort of learn

8 how to -- who's good for their life and who isn't.

9 Q Okay. And is that based on the works of L. Ron

10 Hubbard?

11 A Yes, it is .

12 Q Okay. Is it based on the works of anybody else?

13 A Don't know.

14 Q Is there any neuropsychological stud ie s that you know

15 of in that course ?

16 MS. KLAUS: Objection to form and foundation.

17 THE WITNESS: I don't know.

18 Q (BY MR. LITTLE) Okay. What does a -- what does one

19 study in the learning improvement course?

20 A How to -- how to look at people and their life and

21 decide whether or not those people are good for them.

22 Q Okay. When you say " decide if those people are good

23 for them, " what do you mean by that?

24 A For instance, if you have someone in your life that's

25 constantly putting you down and isn't supportive of you

40


11/39

1 at all , that person isn't good for you . Or someone

2 that 's leading you to do drugs , that person isn't good

3 for you.

4 Q Okay. And so what kind of -- what kind of exercises or

5 things do you go over with the students during that

6 course?

7 A I don't remember. It's been a while since I've seen

8 that book.

9 Q Do you remember if it talks about obstacles to10 learning?

11 A Yes, I remember that.

12 Q What's the first obstacle to learning?


14 Q During this course, do you need to clear words?

15 A I believe so.

16 Q What does it mean to clear words?

17 A Look it up in the dictionary and find the appropriate

18 definition .

19 Q Okay. And which dictionary is that?

20 A I don't know.

21 Q Is there a separate dictionary for the Narconon course?

22 A I used a Webster's when I went through that book.

23 Q Okay. Do you know what they use in -- used in 2012?

24 A No idea.

25 Q Do you know what they use now?

10 29 15


41

1 A Don't know .

2 Q Okay . So you looked the words up in the dictionary,

3 and what is the goal of looking the words up in the

4 dictionary?

5 A Understand what the word means.

6 Q And what is the goal of that exercise , clearing words?7 A To help you understand what you're reading.

8 Q Do you keep track of how many words a student clears?

9 A I don't know.

10 Q How does a student prove that they've cleared it , a

11 word , or not?

12 A I don't know . I don't know that.

13 Q Okay. Does this course cover barriers to study?


15 Q Can you tell me what absence of mass is?


17 Q Can you tell me what it means to feel bent?

18 A (The witness shakes her head.)

19 Q Or squashed?

20 A (The witness shakes her head.)

21 Q Spin ney?

22 A That is a matter -- I don't know . Can you be more

23 specific, like. ..

24 MS. KLAUS: And let the record reflect

25 counsel is reading from a book.

42

1 MR. LITTLE: Yeah . So let the record reflect

2 that counsel is reading from the book Learning

3 Improvement Course , based on the works of L. Ron

4 Hubbard , Number 3 .

5 THE WITNESS: That would -- that's all

6 subjective.

7 Q (BY MR. LITTLE) Okay.

8 A What I feel looks bent may be different than what you

9 feel looks bent or squashed.10 Q What does Narconon feel " bent " means in the context of

11 Course Number 3 ?


13 Q Do you remember what it felt " squashed " meant?

14 A No.

15 Q Okay. What' s datum mean ? D-a -t- u-m?

16 A Datum , as far as that book is concerned or --

17 Q Yes .

18 A Like --

19 Q As far as Narconon Course Number 3.

20 A Datum would be data.

21 Q Okay. Is " datum " a word you would have to clear?

22 A Me personally , or anyone else ?

23 Q Like , a student in this course .

24 A Depends on the s tudent .

25 Q What's doingness?

43

1 A Doing something.

2 Q Is " doingness " a word you'd have to look up in the

3 dictionary?

4 A Depends on the individual. Would you be able to tell

5 me what doingness was if I -- say , for instance , if --

6 if I asked you what doingness was ; and then, okay, 7 would you have to look it up , or do you believe others

8 would have to look it up ? That's the point I'm trying

9 to make.

10 Q Okay. But do you know if -- if " datum " is a word in

11 the Webster dictionary?

12 A Don't know .

13 Q What if a word is not a word in the Webster dictionary ?

14 What do you do then? What does a student do then?

15 A I have no idea.

16 Q Is there a separate Scientology dictionary they would

17 consult?

18 A No idea.

19 Q What -- what does the second barrier , too steep a

20 gradient , what does " too steep a gradient " mean?

21 A When you advance too quickly on a task, when you

22 haven't really learned how to do the first -- for

23 instance, if you don't learn well how to do the first

24 step , and you advance to the second one in anything

25 that you do, then you may not fully understand what you

44


12/39

1 need to do.

2 Q Okay. What -- what does the word reelingnes s,

3 r-e-e-l -i-n- g - n - e-s [sic] , have to do with too steep a

4 gradient?

5 A Don't remember.

6 Q Do you know if reelingnes s is a word in the Webster

7 dictionary?

8 A Don't know.

9 Q What are the drills associated with too steep a10 gradient that the students do?


12 Q What are the drills associated with relieving a sort of

13 confusingness or reelingne s s?

14 A I don't know.

15 Q What is -- what is the field of doingness?

16 A No idea.

17 Q What is the misunderstood word?

18 A A word you don't understand.

19 Q Okay. And what is -- what -- what doe s the

20 misunderstood word have to do with Course Number 3 of

21 L. Ron Hubbard's learning improvement course?

22 A Could you be more specific ?


24 Q (BY MR. LITTLE) Well, in the context of L. Ron

25 Hubbard's Learning Improvement Course Number 3, Section

10 29 15


45

1 3 , the third and most important barrier, the

2 misunderstood word . So what do you teach students

3 about the misunderstood word ?

4 A Don't know. I 'm not -- I 'm not --

5 MS. KLAUS: Objection to form. The witness

6 is -- or the lawyer's reading from a book and not7 showing a copy to the witness . It's a very confusing

8 way to try to ask questions.

9 MR. LITTLE: Just for the record , for our

10 motion to compel, I am reading from the course book

11 Learning Improvement , Course Number 3, by Ron -- based

12 on the works of Ron L . [sic] Hubbard , that this -- that

13 deponent was designated as the designee to speak on

14 behalf of her company on.

15 MS. KLAUS: That's exactly not true . You

16 never asked about specific books . You never asked us

17 to designate someone to talk about Course 3. You said

18 " education program offered, " okay? You didn't ask for

19 the implementation of the program , you didn't ask for

20 the specific books or anything else . Education program

21 offered.

22 Q (BY MR. LITTLE) Ma'am, is there --

23 MS. KLAUS: -- tell you about the program as

24 it's offered . She was family liaison.

25 Q (BY MR. LITTLE) Ma'am , is there any other educational

46

1 program offered at Narconon besides these current five

2 books or the past eight books?

3 A No.

4 Q Thank you. Okay. I'm sorry your lawyers have put you

5 in this position . I'm --

6 MS. KLAUS: I'm sorry you're putting her in

7 this position . And the judge instructed you not to be

8 snarky with the witness es, so stop it .

9 MR. LITTLE: I'm being snarky?10 MS. KLAUS: -- will bring it up again, yes.

11 MR. LITTLE: Well, I disagree with that

12 characterization by counsel.

13 MS. KLAUS: The record speaks for itself.

14 MR. LITTLE: Okay , it does.

15 Q (BY MR. LITTLE) All right. So , going back to the most

16 important exercise in Course Number 3 --

17 MS. KLAUS: Again , you're testifying.

18 Q (BY MR. LITTLE) -- the most important barrier, the

19 misunderstood word, how do you -- in -- in the Narconon

20 Education Program, how do you teach students to -- wha t

21 do you teach student s about the misunderstood word?

22 A I don't teach the books , un fortunately . I cannot

23 answer that question .

24 Q Okay. What does a blow mean in terms of the Narconon

25 Course Number 3 ?

47

1 A Context.

2 Q Leaving the course in this way is called a blow?

3 A If they just get up and leave.

4 Q Okay. And what happen s if a student blows a -- Course

5 Number 3 ?

6 A Don't remember. 7 Q Are there penalties for blowing a course?

8 A Don't know.

9 Q Do you remember any of the drills associated with the

10 misunderstood word?

11 A I do not.

12 Q I'm turning to Sect ion 4 of Course Number 3, handling

13 the misunderstood word. What do you -- what does

14 Narconon teach students to do in their education

15 program about handling the misunderstood word ?


17 Q (BY MR. LITTLE) Do you know?

18 A If you're asking me what's in that book, I don't

19 remember. If you're asking me what the procedure is, I

20 don't know either.

21 Q Does anybody study these books with the students?

22 A I don't know. I'm not in the course room with them.

23 Q Does anybody supervise the students' studies on --

24 A Yes.

25 Q On a daily bas is?

48


13/39

1 A When they study, they have a supervisor present.

2 Q Okay. And how -- how do -- who grades them , or who

3 decides if they've completed a course or not?

4 A The supervisor.

5 Q Okay. And are copies of those grades kept?

6 A Don't know . I don't know.

7 Q Okay. Do you know if there's lists or records o f

8 cleared words for each student?

9 A I don't know.10 Q Do you recall the two phenomena of misunderstood words?

11 A I don't.

12 Q Okay. Can you tell us about Books 4-A and 4-B,

13 Communication and Perception ?

14 A They run objective exercises. That's what those books

15 are for. And what those objective exercises do is help

16 them make realizations about themselves.

17 Q Okay. What kind of objective exercises do they do?

18 A They're drills. They're not drills, but I don't really

19 know what the ex -- the exact exercises are. I

20 couldn't sit here and quote them to you verbatim . I

21 would have to refer to a book.

22 Q Can you give me an example?

23 A I can't right now . I really can't.

24 Q Okay. So what -- what's the goal of 4-A and 4-B?

25 A I don't know.

10 29 15


49

1 Q How would you know --

2 A I don't know.

3 Q I'm sorry. How would -- how would one -- how would a

4 student know when he's progressed through 4-A? What's

5 the penultimate exercise of 4-A ?

6 MS. KLAUS: Objection to form. I don't think7 you know what " penultimate " means.

8 THE WITNESS: And I don't.

9 MS. KLAUS: It means second to last so ...

10 Q (BY MR. LITTLE) And what's the ultimate exercise of

11 4-A?

12 A When Candice Tyler was in the program or now ?

13 Q Yeah , yeah, when Candice Tyler was in the program .

14 A When Candice Tyler was in the program 4-A ?

15 Q Yeah .

16 A Honestly , I don't know . I didn't administer the

17 program itself to the students , so I'm not going to be

18 much help with that.

19 Q What -- okay. So I guess do you know the penultimate

20 exercise of 4-B?

21 A I do not.

22 MS. KLAUS: Same objection.

23 Q (BY MR. LITTLE) And of 4-A -- or then the ultimate

24 exercise of 4-B?

25 A As I've said, I -- I don't administer the program to

50

1 the students ; so , unfortunately, I do not know.

2 Q Do you know when the clay table or the clay table

3 trainings, when -- when do they occur in the Narconon

4 education course?


6 Q Do you know what c lay -- clay table trainings are?

7 A I've not heard it referred to in that context.

8 Q Let me show you -- I'm not going to admit it ; but ,

9 here , take a look at Page 137.10 MS. KLAUS: Objection , form and foundation.

11 Q (BY MR. LITTLE) Narconon Book 3.

12 A Okay. What -- what am I looking for ?

13 Q That's clay table trainings .

14 A Okay.

15 Q I want to ask you about that .

16 A So what would you like for me to --

17 Q Oh, just -- I -- just to refresh your memory . You can

18 take a second and --

19 A Okay.

20 MS. KLAUS: She didn't say she needed her

21 memory refreshed . Objection.

22 Q (BY MR. LITTLE) Okay. All right. So what -- what is

23 the clay table training?

24 A Clay model s are used , but I don't remember what for. I

25 don't remember what the ultimate goal is.

51

1 Q Okay. What about exercises in sketching ? Do you know

2 what -- what's the go a l of the sketching exercises?

3 A Don't remember that either.

4 Q Do you know what clay table training has to do with

5 drug rehabilitation?

6 MS. KLAUS: Objection , form . 7 THE WITNESS: Don't remember. Yeah, I don't

8 -- I'm sorry, but I don't remember.

9 Q (BY MR. LITTLE) Same thing . Do you know what word

10 clearing has to do with drug rehabilitation ?


12 Q (BY MR. LITTLE) Are there any studies that you know of

13 that link word clearing to drug addiction success?

14 A I don't know, I don't know. But , because I haven't

15 heard of them , doesn't mean they don't exist . I just

16 have not heard of them.

17 Q Okay. What is theory coaching?


19 Q What are checkouts?


21 Q If I wanted to know what theory coaching and checkout s

22 were, who would be the person I would want to talk to

23 at Narconon?

24 A It would be a course supervisor.

25 Q That would be Sawyer?

52


14/39

1 A Actually , though , now or when Candice Tyler was in the

2 program?

3 Q Both.

4 A And that 's Book 3, correct ?

5 Q Yes .

6 A Book 3 is -- we don't use Book 3 now.

7 Q Okay. S o I guess , in 2012 , who would I want to talk

8 to?

9 A The course supervisor at that time , and I don't10 remember who it was.

11 Q Why don't you guys use Course 3 now?

12 A I don't know.

13 Q Okay. Number 5 , Narconon Book Number 5 , The Ups And

14 Downs of Life . What's that book about?

15 A I don't remember. Actually, I think some of the things

16 I told you about Book 3 are probably Book 5. That's

17 how I'm not -- like I said , I don't administer this

18 program , and I don't really remember.

19 Q Do you know what the goal of Course 5 and of Ups and

20 Downs of Life by Ron L . [sic] Hubbard is?

21 A Do not know.

22 Q What can you tell me about the education program at

23 Narconon ? Just anything . Like , if I'm asking you as a

24 person --

25 MS. KLAUS: Are you asking for an over view of

10 29 15


53

1 what --

2 MR. LITTLE: Yes.

3 MS. KLAUS: -- the program is ?

4 Q (BY MR. LITTLE) Give me an overview of what the

5 program is .

6 A Basically it's to help individuals get off drugs and7 stay off them.

8 Q Okay . And how w o -- does Narconon Freedom Center

9 program do that?

10 A The sa una detoxification helps them learn to

11 communicat e, helps them learn good ethics and morals ,

12 helps them handle problem s with their -- learn how to

13 handle problems in their own life , and helps them learn

14 how to confront their problem s.

15 Q Okay. And do you know of any peer reviews of any of

16 these materials?

17 A I don't know of any.

18 Q Okay. Do you know of any medical study that says the

19 sauna program is -- you know, helps with drug

20 rehabilitation?

21 A I don't. Doesn't mean it doesn't exist , I just don't

22 know of it.

23 Q What's --

24 A I didn't -- I didn't pursue it.

25 Q Okay. What's a video called The Way To Happiness ? Do

54

1 you show that in your -- in the Narconon Education

2 Program?

3 A When Candice Tyler was a student?

4 Q Yes .

5 A Yes.

6 Q Okay. W hat is The Way To Happiness movie about?

7 A It's basically what most of us have been taught. Doing

8 the right thing , keeping your morals , and that type of

9 thing.10 Q Who produced that video?


12 Q When you say " what most of us have been taught ," what

13 do you mean by that?

14 A Well, what I would hope that most of us have been

15 taught . Good ethics, good morals, treat others kindly,

16 do the right things in your life, help other s.

17 Q Ethics are very important in the Narconon Education

18 Program ; is that correct?

19 A That's correct.

20 Q What do ethics mean in terms of the Narconon Education

21 Program?

22 A That def -- that -- the exact definition, I don't

23 remember. But -- yeah.

24 MS. KLAUS: You can talk about it generally.

25 THE WITNESS: Yeah . Generally, if your

55

1 ethics are in , you're doing the right thing.

2 Q (BY MR. LITTLE) And who judges if you're doing the

3 right thing or not in the Narconon Program?

4 A It's not as if ethics in the Narconon Program are

5 different than any other ethics the rest of us need to

6 follow in our life. 7 Q Who -- who decides that?

8 A We have an Ethics Department.

9 Q Who's in charge of the Ethics Department?

10 A Right now, I don 't know.

11 Q In 2012?

12 A I definitely don't know .

13 Q Are there repercussions in the Narconon Education

14 Program for bad ethics?

15 A There are, but I'm not -- I -- when Candice Tyler was

16 here , I don't remember what those are , and I don't know

17 what that is now.

18 Q In the Narconon Education Program, who decided if there

19 were -- well, could --

20 A They do have student rules that they have to follow.

21 Q Okay . And who -- who originated the student rules?

22 A No idea.

23 Q If I want ed to get a copy of the student rules, where

24 would I go to get one ?

25 A Again, along with the books, I don't know who you would

56


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1 ask for that , unfortunately.

2 Q Are the student rules displayed at the Narconon Freedom

3 Center?

4 A I don't know, but students receive a copy. I don't

5 know if they did when Candice Tyler was there.

6 Q Who keeps a copy of the student's educational file?

7 A That, I don't know.

8 Q Bad ethics, can you give me an example of -- of

9 somebody who has bad ethics?10 A They try to sneak out of the facility to go use drugs.

11 Q Okay. And what are -- what are the repercussions of

12 that kind of bad ethics?

13 A I don't know.

14 Q What is the e ffect of that kind of bad ethics on their

15 education in the Narconon Program?

16 A That, I don't know either. That's kind of a general

17 question though. You mean personally or -- or whether

18 or not they're stopped from doing their program or --

19 Q Like , if somebody sneaks out to get drugs and they're

20 half way through , do they go back ? Do they get kicked

21 out of the program ? Do es it start over? Like, what

22 are the repercussions of bad ethics?

23 A That would depend on the ethics officer and the

24 situation surrounding it.

25 Q And who -- and the ethics officer alone makes that

10 29 15


57

1 decision?

2 A No.

3 Q Who else is involved in making that decision?

4 A You -- I don't believe it's the ethics officer's sole

5 decision , but there's usually more than one person

6 involved . The other person , I don't really know who7 that is.

8 Q Are all the people involved at Narconon Freedom Center?

9 A Yes.

10 Q They're not from outside of Narconon Freedom Center?

11 A No.

12 Q Okay. Are there any appeals in the Narconon

13 educational process that a student could have?

14 A Don't know.

15 Q Who e nsures that the program -- who i s Sawyer -- so

16 does Sawyer Grose currently e nsure -- strike all that.

17 Okay. Who, from Narconon Freedom Center , e nsures that

18 the course by L. Ron Hubbard is being administered

19 properly currently ?

20 MS. KLAUS: Objection to -- objection to

21 form.

22 Go ahead.

23 THE WITNESS: Okay. Could you rephrase that?

24 Q (BY MR. L ITTLE) Who i s in charge of administering the

25 -- the L. Ron Hubbard eight-book program or currently

58

1 five-book program today at Narconon Freedom Center?

2 A I don't know.

3 Q Okay . And who -- okay. Can you tell us about Book 6 ?

4 Do you guys current -- does Narconon currently use

5 Personal Values and Integrity Course by L. Ron Hubbard?

6 A Not that book. It's a different book.

7 Q Is it still Course 6, the personal values and integrity

8 course?

9 A Just called Personal Values .10 Q Okay. And what's -- what are the changes between 2012

11 and today in that book?

12 A I don't really know. I couldn't be specific.

13 Q Okay. So , in the personal values and integrity course,

14 can you tell me what -- what you know about it? What

15 is it?

16 A That's when they learn about morals and ethics, that

17 type of thing.

18 Q And what do they learn about morals and ethics?

19 A Specifically, I would have to refer to the book.

20 Q I'm handing the witness a copy of Personal Values and

21 Integrity , Course 6 , by L . Ron Hubbard .

22 MS. KLAUS: Objection , unless it's going to

23 be marked at an exhibit .

24 But you can go ahead and look at it .

25 THE WITNESS: It would take -- it would take

59

1 a while for me to go through this book and really get

2 into it.

3 Q (BY MR. LITTLE) Okay. I want to know . I mean you're

4 the person designated to speak about the education at

5 Narconon.

6 MS. KLAUS: No , education offered at 7 Narconon .

8 MR. LITTLE: Right. I'm asking her about it.

9 So tell me what course --

10 MS. KLAUS: You're asking her --


12 MS. KLAUS: You're asking her about details

13 from a book that's about an inch and a half big. So do

14 you have a specific question ?

15 Q (BY MR. LITTLE) Again, is there any other program

16 offered at Narconon besides the program you've

17 described to me , detox , sauna , these classes?

18 A No.

19 Q Okay .

20 A Well, when Candice Tyler was there or now ?

21 Q When Candice Tyler was there .

22 A No.

23 Q Okay.

24 A I don't administer this program. So , for me to go

25 through this book and tell you what's in it and how --

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16/39

1 how it gets taught to the students or whatever,

2 unfortunately, I will not be able to do that.

3 Q Does anybody ever say that this program is just

4 Scientology ?

5 MS. KLAUS: Does anybody ever ?

6 MR. LITTLE: Okay , never mind . Strike that.

7 Q (BY MR. LITTLE) What are the differences between your

8 program and Scientology ?

9 MS. KLAUS: Objection to form and foundation .10 You're assuming she even knows anything about it. It's

11 -- it's -- about Scientology .

12 MR. LITTLE: I'm only assuming --

13 MS. KLAUS: What's the difference between

14 this and nuclear physics ? It's a ridiculous question.

15 MR. LITTLE: I'm only assuming that she knows

16 anything about the course because she was designated to

17 speak on the education offered by Narconon.

18 MS. KLAUS: Right.


20 MS. KLAUS: Now you're asking h er to compare

21 it to something else when you haven't established that

22 she knows anything about the something else.

23 MR. LITTLE : What is -- well, actually , she

24 didn't know anything about the purification rundown.

25 Okay , that's fair enough. All right.

10 29 15


61

1 Q (BY MR. LITTLE) What does Course 6 do to help students

2 regain their personal integrity?

3 A That, I don't know. I don't administer the course, so

4 I don't really know.

5 Q How about to recognize their personal values?

6 A Don't know.7 Q Do students go through audits as part of the Narconon

8 program?

9 A An audit?

10 Q Are you familiar with --

11 A I don't know what that is.

12 Q Okay. What kind of things does Narconon -- okay. Is

13 one of the goals of Course 6 to teach students to be

14 accountable for their own actions and take

15 responsibility for their own actions?

16 A That, I don't know for sure.

17 Q How is a student's production measured in this -- in

18 this program?

19 A I don't administer the course , so I don't know.

20 MR. LITTLE: I'm really baffled as to why

21 this witness was produce d.

22 MS. KLAUS: I'm really baffled as to why you

23 didn't read your own request for what this witness was

24 supposed to testify a bou t. She's A , and you're asking

25 her questions about B . So I'm equally baffled. If you

62

1 wanted a person to talk about the books, you should

2 have said we want you to produce a person to talk about

3 Book 6 , a person to talk about Book 7 , a person to talk

4 a bou t book whatever , and you didn't.

5 MR. LITTLE: I went with the general

6 education , meaning the only education offered , and you

7 said --

8 MS. KLAUS: Look at your request , and look at

9 my objection.10 MR. LITTLE: You designate Beth Scott --

11 MS. KLAUS: We object --


13 MS. KLAUS: -- to this topic because it is

14 vague , and the terms in quotes are not defined and do

15 not have a commonly understood definition. Subject to

16 these objections , we'll produce Beth Scott to testify

17 as to the education program offered. She was family

18 liaison. People have questions about the program,

19 generally, she answers them. You're got -- you're

20 reading footnotes from inches -- books that are inches

21 thick --

22 MR. LITTLE: There's no footnotes.

23 MS. KLAUS: -- and asking her questions about

24 them when that's not what she was offer ed to . So , if

25 you're frustrated , look in the mirror.

63

1 MR. LITTLE: All right. This is a -- a waste

2 of time for the deponent and for myself. We will be

3 filing a motion to compel .

4 This isn't your fault.

5 MS. KLAUS: And we'll be responding to the

6 motion to compel and maybe a suggestion that , if you 7 want something more specific , ask for specific.

8 MR. LITTLE: Mm-hmm.

9 MS. KLAUS: If you ask for a general person ,

10 we give you a person who has a general understanding of

11 it as she's testified to.

12 Q (BY MR. LITTLE ) Just -- just for the sake of the

13 record , can you tell us about Book 7 by L. Ron Hubbard ,

14 Changing Conditions In The Life ? Do you -- what do you

15 recall about that book?

16 A Unfortunately , I don't administer the program ; so I

17 don't really know what the goals of it are; and I

18 wouldn't be able to tell you much about what's actually

19 in the book unless I had reference to it . And then it

20 would only be my personal interpretation and not how

21 it's administered to the student s.

22 Q Okay. Same thing with Narconon Course Book 8, The Way

23 To Happiness .

24 A Mm -hm m.

25 Q What can you te ll me a bou t The W ay To Happiness ?

64


17/39

1 A Same thing .

2 Q Okay . Can you tell me about the 21 practical drills in

3 The Way To Happ iness ?

4 A I cannot.

5 Q So , if I was a parent , and I called up and said I'm

6 concerned my -- my student -- my child is learning only

7 books -- is learning only materials produced by L. Ron

8 Hubbard, is there anything else in the Narconon

9 Educational Program that is not produced by L . Ron10 Hubbard?

11 A Don't know.

12 MR. LITTLE: Okay. Again, any questions ?

13 MR. MILLER: Can we take a quick break ?


15 MS. KLAUS: Sure .

16 (At 2:32 p.m. - Off the record.)

17 ( At 2:33 p.m. - Proceedings resume. )

18 Q (BY MR. LITTLE) Okay. Well , in your role as family

19 liaison, what -- what do you -- what did you do with

20 regards to education? What were your job duties and

21 responsibilities with regards to the Narconon education

22 course ?

23 MS. KLAUS: Objection to form , but you can go

24 ahead and answer.

25 THE WITNESS: Okay. Do you have a specific

10 29 15


65

1 question? Can you be a little bit more specific with

2 that ?

3 Q (BY MR. LITTLE) When you were family liaison , which I

4 understand is what got you designated today --

5 A Mm-hmm.

6 MS. KLAUS: Objection.7 Q (BY MR. LITTLE) -- what -- what did you do in relation

8 to the Narconon -- to the education offered at

9 Narconon?

10 A With respect to the education itself? I wasn't

11 involved with the education itself.

12 Q Okay. Well, what was your involvement with the

13 education at all when you were family liaison?

14 A Are you asking if I had a part of how it was

15 administered? What I did was call families.

16 Q Okay. When you called families , what did you do?

17 A I would call them . Did they have any questions, did

18 they have any concerns. If the ir loved one was in

19 the --

20 Q Okay. Well --

21 MS. KLAUS: Wait . Can she -- can she answer

22 the question, please ?

23 Q (BY MR. LITTLE) I want -- I want to break it down .

24 She's already put three parts in it.

25 MS. KLAUS: No , but let her finish answering ,

66

1 and then you can break it down . You can't interrupt

2 her and stop her . It's rude.

3 MR. LITTLE: You interrupt me all the time ,

4 Miss Klaus.

5 MS. KLAUS: Finish your answer.

6 THE WITNESS: Okay . I'll start over. I' ll

7 begin again . I don't remember where I left off.

8 Questions, concerns . If the individual wasn't feeling

9 well, let them know that we're doing what we can on our10 part to keep them as comfortable as we can to get them

11 through that very difficult part of the program. If

12 they -- if they were willing, if they were not wil ling,

13 what their issues might be at that point in time, and

14 what we're doing to help with that willingness.

15 Q (BY MR. LITTLE) Okay. So let's go back and start with

16 what were the common questions that you encountered

17 when you were family liaison?

18 A A lot of them were general . What's your mailing

19 address, how are they feeling . Or I got more questions

20 like that earlier in the program. Later in the

21 program, the families didn't really have a lot of

22 questions except when they might be finished. Most of

23 it was how do we put money on a student account ; are

24 they cooperating ; they seemed a little down last night,

25 what can you tell me about that ?

67

1 Q Go ahead .

2 A Mm-hmm . Yeah , what can you tell me about that ; or they

3 seemed extremely happy, that type of thing.

4 Q Are these calls monitored?

5 A They're not.

6 Q Are they recorded? 7 A No.

8 Q Are there phone records of who was called?

9 A I don't know.

10 Q Are calls between students and family members

11 monitored?

12 A I don't know.

13 Q Are they recorded?

14 A No.

15 Q Okay. So did you ever have any questions or concerns

16 regarding the education course offered at Narconon?

17 A I did. I did. Sauna in particular . Not the sauna

18 itself , but how long might they be i n there , and each

19 person's different. As far as Book 4-A and 4-B, just

20 explain to them that it was -- it's a part of the

21 program where they have to do some soul searching.

22 It's going to be tough for them , but they're also going

23 to get a lot out of it. Sometimes a loved one wouldn't

24 call home for, say, a week. I haven't heard from

25 so-and-so for a week , how are they doing ? And then

68


18/39

1 what I would tell that family is -- and this is a true

2 statement -- from my experience, from my personal

3 experience, they go through a spell maybe where they

4 don't call home as often as the family wants them to .

5 And what I would do is find that individual and get

6 them on the phone with their family member right then

7 if I could. If they , for instance , were , say , in the

8 course room or in the sauna , get them on later so the

9 family member wouldn't worry. But they -- they get10 involved and get en thused about their own recovery .

11 And then they still love their family , but they're just

12 involved with other things.

13 Q Did you get any specific questions about education that

14 you can recall when you were family liaison?

15 A No.

16 Q Did anybody ever complain that the courses were just

17 Scientology?

18 A No.

19 Q Okay. Did anyone ever complain the sauna program was

20 dangerous or they were concerned it was dangerous?

21 A I didn't field any calls about that.

22 Q Did anybody ever complain that the cor e -- education

23 course offered was not secular , medically-supervised

24 drug rehabilitation with a 70-plus success -- or

25 70-plus percent success rate?

10 29 15


69

1 A I never had that conversation either.

2 Q Okay. Do you know who Robert Keifer is?

3 A No.

4 Q Do you know who Marga -- Margarita , a woman named

5 Margarita?

6 A No.7 Q You know who Kathy Nather Thomas is?

8 A Don't know her .

9 Q Do you hold any certifications in general besides , you

10 know , your degree from Pur d ue ? But do you have any

11 certifications or... ? Like an --

12 A CPR.

13 Q Okay. Anything e lse?

14 A No.

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

16 A I've seen his pic ture .

17 Q Who --

18 A I met him once . I met him one time.

19 Q Who is he?

20 A Don't really know what his title is.

21 Q Is he connected to Narconon Freedom Center?


23 Q Did you m ee t him in Albion?

24 A I did.

25 Q At the Freedom Center?

70

1 A Yes.

2 Q Why was he at the Freedom Center , if you know?

3 A I don't know . I don't remember. It was brief , and he

4 wasn't there long.

5 Q Okay. Are there any -- do you know who Yvonne Rogers

6 is?

7 A No.

8 MR. LITTLE: Well, thank you.

9 MS. KLAUS: Okay. I have to go to my car to10 get my cord because I'm running out of juice , but we'll

11 bring the next witness out then.

12 MR. LITTLE: Great .

13 (At 2 :40 p.m. - Off the record.)

14 * * *

15

16

17

18

19

20

21

22

23

24

25

71

1 STATE OF MICHIGAN ) )

2 COUNTY OF INGHAM ) 3

4 I certify that this transcript, consisting of

5 72 pages, is a complete, true and correct record of the

6 testimony of BETH SCOTT, held in this case on October 29,

7 2015.

8 I also certify that, prior to taking this

9 deposition, BETH SCOTT 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

72


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5 7 : 9 , 1 2 , 1 4 ,2 2b a f f l e d [ 3 ]6 2 : 2 0 , 2 2 , 2 5b a r r i e r [ 3 ]4 4 : 1 9 ; 4 6 : 1 ;4 7 : 1 8b a r r i e r s [ 1 ]4 2 : 1 3


21/39

b a s e [ 2 ]3 1 : 1 9B a s e d [ 1 ]2 8 : 1 6b a s e d [ 7 ]2 8 : 1 9 ; 2 9 : 3 ;

3 1 : 2 1 ; 4 0 : 9 ,1 2 ; 4 3 : 3 ;4 6 : 1 1B a s i c a l l y [ 3 ]1 0 : 7 ; 1 6 : 2 2 ;5 4 : 6b a s i c a l l y [ 3 ]3 0 : 2 4 ; 3 5 : 6 ;5 5 : 7b a s i s [ 3 ]2 5 : 1 1 ; 3 8 : 7 ;4 8 : 2 5

B a t t l e [ 2 ]1 : 1 5 ; 4 : 1b e c a m e [ 1 ]7 : 1 5b e c a u [ 1 ]3 0 : 1 9B e c a u s e [ 2 ]8 : 1 4 ; 1 0 : 2 2b e c a u s e [ 9 ]1 0 : 5 ; 1 3 : 7 ;1 4 : 1 4 ;2 4 : 1 9 ;3 0 : 1 7 ;5 2 : 1 4 ;6 1 : 1 6 ;6 3 : 1 3 ; 7 1 : 1 0b e c o m e [ 2 ]9 : 1 8 ; 1 3 : 1 0b e f o r e [ 7 ]1 : 1 2 ; 5 : 2 2 ,2 4 ; 7 : 2 ;1 4 : 7 ; 2 5 : 2 0 ;3 2 : 1 0b e g i n [ 5 ]1 3 : 9 ; 1 5 : 9 ;3 5 : 2 1 ;3 7 : 1 5 ; 6 7 : 7b e g i n n i n g[ 2 ] 1 : 1 6 ;1 1 : 3b e g i n s [ 1 ]2 1 : 2 1

b e h a l f [ 8 ]2 : 2 , 5 , 8 ;2 3 : 1 5 ;2 4 : 2 4 ;2 8 : 2 3 ; 3 0 : 3 ;4 6 : 1 4

b e h i n d [ 2 ]3 7 : 9 , 1 1b e i n g [ 3 ]3 4 : 1 1 ; 4 7 : 9 ;5 8 : 1 8b e l i e v e [ 6 ]5 : 1 ; 7 : 2 2 ;2 2 : 6 ; 4 1 : 1 5 ;4 4 : 7 ; 5 8 : 4b e n t [ 4 ]4 2 : 1 7 ; 4 3 :

tyler v. scientology: scott deposition

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