Author Topic: The Desmond Family v. Narconon of Georgia, Narconon International, et al  (Read 202612 times)

Offline ethercat

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Yeah, there really needs to be a "Best Of..." set of links now.   :)

A bunch of the older stuff was good at the time for us to get clues about what was going on, but they aren't needed now that we have some of the actual documents that the Rule 5.2s were submitted for.
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Offline ethercat

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From http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-10-Plaintiffs2ndInterrogatoriesToNarcononOfGeorgia.pdf
Quote
5.  Please identify every complaint or claim, including but not limited to lawsuits and informal complaints made to or received by Narconon of Georgia that alleges improper treatment and care of patients (and/or "students") of Narconon of Georgia from 2000 through 2010.

I must get Narconon of Georgia's Response to Plaintiffs' 2nd Interrogatories!   ;D

This ought to be good too:
http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-10-Plaintiffs3rdRequestForProductionOfDocumentsToNarcononOfGeorgia.pdf
Quote
11.  All documents to support your claim that Narconon of Georgia is the "most successful drug and alcohol rehabilitation program in the world," and Narconon's claim that "Narconon has a success rate of over 70%"(See document produced by Narconon of Georgia, Bates No. Desmond-D-GA 0004, 0019).

http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-10-Plaintiffs2ndInterrogatoriesToSovereignPlaceAptManagement.pdf
is missing pages 3 and 4 - I have page 3, and will get it merged in and replace the current file.  I don't have page 5, but it looks like it would be a list of the defendants to whom it was sent.

The missing part is:
Quote
Interrogatories
1. Identify the property manager(s) at One Sovereign Place in 2007-2008 and all entities that were responsible for the management of the property at One Sovereign Plave in 2007-2008.
2. Identify all tenents in Buildings B, W, and Z on the One Sovereign Place premises in June 2008.
3. Identify the date which you, and /or any of your agents and/or representatives, anticipated litigation arising out of the death of Patrick Desmond.

This 12th 15 day of November, 2010.
                                                               HARRIS PENN & LOWRY, LLP


http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-10-Plaintiffs4thInterrogatoriesToNarcononOfGeorgia.pdf
contains some license applications as exhibits.

http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-10-PlaintiffsExpertDisclosures.pdf
Quote
Dr. Stephen A. Kent
Dr. Stephen A. Kent is a Professor in the Department of Sociology at the University of Alberta and an expert in alternative religions, including the Church of Scientology.  His curriculum vitae, which details his education, experience, qualifications, and expertise, is attached hereto as Exhibit C.

Dr. Kent, if called to testify at trial, will testify regarding the connection between Scientology and the Narconon Drug and Alcohol rehabilitations programs, including testimony relating to Narconon's course materials, student and staff interactions, and Narconon International's oversight and involvement in individual Narconon programs.

http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-10-PlaintiffsResponseToDelgadoDevelopments2ndInterrogatories.pdf
has an attached chart of Patrick's attendance at rehab programs which shows Narconon of Georgia's prices as follows:

Sept 2007-February 2008
Narconon Costs for Six Months
- Program (14K)
- Medical Exam and Treatment on Induction (3K)
- Lodging (9K)
- Monthly Living Costs (2.4K)
-------------------------------
Total $26,000 + monthly living costs

May 2008-July 2008
Narconon Costs for 2.5 Months
- Program (refunded)
- Medical Exam (.5K)
- Lodging (4.5K)
- Monthly Living Costs (1K)
-------------------------------
Total $5,000 + monthly living costs

So, if Lisa Robbins made the entire amount for the Medical exams (which I find doubtful), she made $3,500 from Patrick's attendance at NNGa. 

The Delgados made $13,500 for 8 months of housing, some of which went to pay rent and utilities.  I think it's safe to say that ONE "student" at the housing covered the rent for one apartment, which must have housed more than one person.

« Last Edit: April 28, 2012, 16:38 by ethercat »
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Offline ethercat

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http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-10-Plaintiffs2ndSupplementalResponseToNNGAs1stRequestForProductionOfDocuments.pdf
Quote
PLAINTIFFS' SECOND SUPPLEMENTAL RESPONSE TO DEFENDANT NARCONON OF GEORGIA INC.'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
 
REQUESTS
16.  Copies of any Department of Human Resources investigations, reports or documents of action taken regarding any Defendant that are in your possession or your attorney's possession.
RESPONSE: Responsive documents are being produced contemporaneously herewith.
SUPPLEMENTAL RESPONSE: Plaintiffs are producing the Release and Settlement
Agreeement, dated March 26, 2007.

At the end of this document is an agreement between Narconon of Georgia (signed by Mary Rieser, Executive Director of NNGa) and Georgia Department of Human Resources/Office of Regulatory Services (signed by Sharon Dougherty, Interem Director, Office of Regulatory Services).  It states:

Quote
RELEASE AND SETTLEMENT AGREEMENT
1. Release. IN CONSIDERATION OF THE ISSUANCE OF A LICENSE TO
NARCONON OF GEORGIA, INC. ("NARCONON") TO PROVIDE DRUG ABUSE
TREATMENT AND EDUCATION PROGRAMS, INCLUDING THE OPERATION OF
AN AMBULATORY DETOXIFICATION FACILITY, by of on behalf of the State of
Georgia, Department of Human Resources ("DHR"), Narconon does hereby release and
forever discharge DHR, together with its principals, agents and assigns, as well as all
parent, subsidiary, and affiliated agencies, from any and all claims, demands, rights and
causes of action of any kind and nature for any and all known and unknown, arising or
resulting from, connected with or in any way relating to Narconon's appeal of DHR's
denial of its application for a license to provide a Drug Abuse Treatment and Education
Program under Rule 290-4-2 et seq. (the "Rules"), currently pending in the Georgia
Office of State Administrative Hearings (Docket No. OSAH-ORS-DATP-0709658-67-
Brown ("Appeal")).

IT IS UNDERSTOOD AND AGREED that this is a release of any and all claims of
Narconon which were or could have been asserted against DHR in the referenced appeal,
which will be dismissed with prejudice; by Order of the Administrative Law Judge upon
the issuance of said license by DHR.

IT IS UNDERSTOOD AND AGREED that issuance of a license to Narconon by or on
behalf of DHR is in compromise and settlement of an appeal by Narconon which is based
on factual and legal arguments not admitted, but which are denied and disputed by DHR;
as well as that this Release is conditioned upon Narconon's ability to meet, and continue
to meet; the Rules governing the conduct and operation of Drug Abuse Treatment and
Education Programs, including Ambulatory Detoxification Facilities.

IT IS UNDERSTOOD AND AGREED that the program offered by Narconon will meet
the requirements of a Drug Abuse Education and Treatment Program, including
Ambulatory Detoxification Facilities, under the above-referenced Georgia rules,
including the following aspects:

• Clients will enroll in the Narconon program by visiting the Narconon facility,
applying for participation and paying the participation fee. At this time,
Narconon will provide the Vitamin Data Sheet to clients, inform the clients of the
risk and benefits of taking vitamins in excess of the U.S. Food and Drug
Administration's recommended daily allowance and the IOM recommended
upper daily limit, and ask the client to sign a consent form reflecting the client's
understanding of these risks and benefits, as well as the client's agreement to
participate in the Program.  This form will be distinct from any consent for
treatment required by the Medical Director.

• Narconon will refer the client to the Medical Director for initial treatment and
assessment.  The Medical Director will be responsible for medical oversight and
will be available twenty-four (24) hoars a day on an "on-call"' basis. The Medical
Director will issue appropriate orders if the client intends to participate in
Narconon's Ambulatory Detoxification program (including the vitamin regimen
already discussed), which is administered on Narconon's behalf by Pur-O-Cleanse1.

• Narconon, will ensure that Pur-O-Cleanse meets the applicable regulatory
requirements for that portion of Pur-O-Cleanse's business operations Which affect
Narconon's clients.  This includes assurances by Pur-O-Cleanse that it will not
permit Narconon clients to intermingle with other Pur-O-Cleanse customers.

• Likewise, Narconon will employ a Registered Nurse to provide medical oversight
under the direction of the Medical Director, and to supervise a Licensed Practical
Nurse ("LPN") who will provide clinical services to clients participating in the
Ambulatory Detoxification Program while on-site at Pur-O-Cleanse. The LPN
will be present at Pur-O-Cleanse at all times that Program participants are there,
and the LPN will meet the training requirements in the Rules. In an effort to
ensure consistent, comprehensive coverage daring these times, Narconon may
develop an internal "PRN float pool" or contract with a nurse staffing agency for
this service. Either way, Narconon recognizes its obligation to maintain personnel
records an any and all LPNs, as well as the RN, in accordance with the Rules.

• Narconon will transfer clients to the Ambulatory Detoxification Program for these
services and document this transfer in the client's records. Likewise, once the
client has completed the Ambulatory Detoxificatian Program, as determined by
the Medical Director, Pur-O-Cleanse will transfer the client back to Narconon for
the Outpatient Drug Treatment Program. The Medical Director will assess the
client's physical condition again at the time of transfer.

• Throughout the client's participation in the Program, Narconon will maintain
timely and accurate documentation of transfers, vitamins self-administered by
clients, under the supervision of a licensed nurse, vital signs as necessary, and any
other information required by the Rules or by the Medical Director.

2. Acknowledgement by Narconon: IT IS FURTHER UNDERSTOOD AND AGREED
that Narconon and DHR have completely read and understood the terms of this Release
and had the opportunity to discuss same with counsel and agreed that the Release is
voluntarily accepted for the purpose of making a full Release of all actions, causes of
action, claims and demands for, upon, or by reason of any issue, known or unknown,
which may be traced to the Appeal, as now appearing or as may appear at any time in the
future, be connected with, be a consequence of, or relate to The Appeal.

3. Severability: This Agreement is intended to be performed in accordance with and to the
extent permitted by all applicable laws, ordinances, rules and regulations. If any
provision of this Agreement, or the application thereof to any person, corporation, entity
or circumstance shall, for any reason and to any extent, be invalid or unenforceable, the
remainder of this Agreement and the application of such provision to other persons or
circumstances, shall not be affected thereby but rather shall be enforced to the fullest
extent permitted by law.

4. Entire Understanding: This Agreement contains the entire understanding of the parties.
This Agreement supersedes any prior understandings or agreements, oral, implied or
written, and none of the parties is relying on any promises. representations,
communications, statements, assertions, declarations, admissions, agreements,
arrangements or understandings, oral, implied, or written, that are not fully expressed
herein. This Agreement is a result of arms length negotiation between the parties.

5. Binding Effect: The terms of this Agreement are binding as to each and every party
hereto, their agents, successors, assigns, employees, subsidiaries, affiliates, and
contractors.

6. Choice of Law: This Release is to be governed in all respects by the laws of the State of
Georgia and the Rules and Regulations for Enforcement and operation of an Ambulatory
Detoxification Program.

7.  Cooperative Effort: This Agreement has been drafted through a cooperative effort of all
parties, and no party shall be considered the drafter of this Agreement so as to give rise to
any presumption or convention regarding construction of this document.

8. Amendment of Agreement: This Agreement may not be changed orally, but only by a
writing signed by all parties.

9. Effective Date and Signatures: This Agreement shall be effective on the date it is
executed by the Parties below, and it may be signed in counterparts, each counterpart
having the same force and effect as any other. Facsimile signatures shall have the same
force and effect as originals.

10. Headings: The headings contained herein are for purposes of reference only and have no
legal significance.

Signed, sealed and read this 26 day of March, 2007.

1 Or any other provider Narconon contracts to provide this service.
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Offline ethercat

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http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-10-Plaintiffs4thRequestForProductionOfDocumentsToNNInt.pdf

Observant readers will recall the document attached as Exhibit A to PLAINTIFFS' FOURTH REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT NARCONON INTERNATIONAL.

I think David Love must have posted it somewhere - I remember it being posted, but can't find it now.

Ah, here it is: https://whyweprotest.net/community/threads/narconon-dox-david-love.88434/
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Offline Sunshine

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In the definition sheet for the Narconon statistics cable there is a disclaimer that several references are made to administrative policy letters written by LRH and were originally written for scientology and not for Narconon. They however cover the basics on how to make any organization to work.

http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-10-Plaintiffs4thRequestForProductionOfDocumentsToNNInt.pdf

Under Executive Division 7 “Number of square paces of useful space” the definition for a useful space is one that promotes the “Org”; looks to me like Narconon must have a space that will promote or be available to the Org.

Offline Mary_McConnell

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In the definition sheet for the Narconon statistics cable there is a disclaimer that several references are made to administrative policy letters written by LRH and were originally written for scientology and not for Narconon. They however cover the basics on how to make any organization to work.

http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-10-Plaintiffs4thRequestForProductionOfDocumentsToNNInt.pdf

Under Executive Division 7 “Number of square paces of useful space” the definition for a useful space is one that promotes the “Org”; looks to me like Narconon must have a space that will promote or be available to the Org.

Good catch, Sunshine!
I am a volunteer advocate for victims of the Narconon scam. I am a former scientologist. I post anonymously. Mary McConnell is my long time nom de plume. Feel free to contact me for assistance in righting the wrongs.

Offline Sunshine

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http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-10-PlaintiffsResponseToDelgadoDevelopments2ndInterrogatories.pdf

has an attached chart of Patrick's attendance at rehab programs which shows Narconon of Georgia's prices as follows:

What happened to Narconons six month guarantee:
After an individual completes the Narconon program they are followed up on through effective aftercare treatment and every graduate is offered a 6 month guarantee that any student who uses drugs within 6 months after their approved completion of Narconon comes back for free.

http://www.drugsno.com/narconon-program/discharge-after-care/

Offline Mary_McConnell

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http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-10-PlaintiffsResponseToDelgadoDevelopments2ndInterrogatories.pdf

has an attached chart of Patrick's attendance at rehab programs which shows Narconon of Georgia's prices as follows:

What happened to Narconons six month guarantee:
After an individual completes the Narconon program they are followed up on through effective aftercare treatment and every graduate is offered a 6 month guarantee that any student who uses drugs within 6 months after their approved completion of Narconon comes back for free.

http://www.drugsno.com/narconon-program/discharge-after-care/

Unbelievable.... Narconon of Georgia and Delgado Development were raking in the bucks. I would love to see which entity reported all that 'lodging' money paid by so many loved ones. $1,500 per month!!You can get a high end sober living shared room ( double occupancy) in a house for $400-500/month plus food.

Plaintiffs' Response to 2 Interrogatory No. 1 - Delgado Development
Name and Address of Facility or Center  Dates Attended or Participated
Cost Completed or Left Early Date of Any Relapse . Drug or Substance

Narconon of Georgia
Atlanta Georgia
Sept 2007 - Feb 2008 Narconon Costs for Six
Months
- Program (14K)
- Medical Exam and
Treatment on
Induction (3K)
- Lodging (9K)
- Monthly Living
Costs (2.4K)

Completed with
Certificate in Feb 2008
May 2008
Failed
Weekly
Drug Test at
Florida Drug
Court
(Alcohol)
Alcohol

7
Narconon of Georgia
Atlanta, Georgia
May 2008-July 2008 Narconon Costs for
2.5 Months
- Program (refunded)
- Medical Exam (.5K)
- Lodging (4.5K)
- Monthly Living
Costs (IK)
Died Under Care and
Supervision of Narconon
On June 11, 2008
I am a volunteer advocate for victims of the Narconon scam. I am a former scientologist. I post anonymously. Mary McConnell is my long time nom de plume. Feel free to contact me for assistance in righting the wrongs.

Offline Mary_McConnell

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What happened to Narconons six month guarantee:
After an individual completes the Narconon program they are followed up on through effective aftercare treatment and every graduate is offered a 6 month guarantee that any student who uses drugs within 6 months after their approved completion of Narconon comes back for free.

http://www.drugsno.com/narconon-program/discharge-after-care/

Another good catch, Sunshine.
I am a volunteer advocate for victims of the Narconon scam. I am a former scientologist. I post anonymously. Mary McConnell is my long time nom de plume. Feel free to contact me for assistance in righting the wrongs.

Offline ethercat

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In the definition sheet for the Narconon statistics cable there is a disclaimer that several references are made to administrative policy letters written by LRH and were originally written for scientology and not for Narconon. They however cover the basics on how to make any organization to work.

http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-10-Plaintiffs4thRequestForProductionOfDocumentsToNNInt.pdf

Under Executive Division 7 “Number of square paces of useful space” the definition for a useful space is one that promotes the “Org”; looks to me like Narconon must have a space that will promote or be available to the Org.

The whole program is a promotion for the org, isn't it?  Good point, though, and I wonder what kind of numbers come in on that?  It also says it should be in paces, not in feet or yards, so I guess it would result in a better stat if there's someone to do the pacing that has really tiny feet.

And I notice a typo, on the P-4 page: "As it may take a while before a staff member becomes fully hated, execcutives over the area do not see what is being done about it."

 :D   I'm sure they must have meant "hatted".

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Offline ethercat

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What happened to Narconons six month guarantee:
After an individual completes the Narconon program they are followed up on through effective aftercare treatment and every graduate is offered a 6 month guarantee that any student who uses drugs within 6 months after their approved completion of Narconon comes back for free.

I don't see anything like that on there, at all...  I do see this, however: "This final section serves as support for the client. After completing the residential stage of treatment, they will then be ready for the transition back into society. "

NN of Georgia is NOT licensed by DCH to provide residential treatment.
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Offline BigBeard

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Quote
NN of Georgia is NOT licensed by DCH to provide residential treatment.

Since when does the Cof$/NarCONon care about sticking to the rules??

BigBeard

Offline Mary_McConnell

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Quote
NN of Georgia is NOT licensed by DCH to provide residential treatment.

Since when does the Cof$/NarCONon care about sticking to the rules??

So true. Documenting it is usually the hard part but not in this case. lol
I am a volunteer advocate for victims of the Narconon scam. I am a former scientologist. I post anonymously. Mary McConnell is my long time nom de plume. Feel free to contact me for assistance in righting the wrongs.

Offline SocialTransparency

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http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-10-Plaintiffs2ndSupplementalResponseToNNGAs1stRequestForProductionOfDocuments.pdf
Quote
PLAINTIFFS' SECOND SUPPLEMENTAL RESPONSE TO DEFENDANT NARCONON OF GEORGIA INC.'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
 
REQUESTS
16.  Copies of any Department of Human Resources investigations, reports or documents of action taken regarding any Defendant that are in your possession or your attorney's possession.
RESPONSE: Responsive documents are being produced contemporaneously herewith.
SUPPLEMENTAL RESPONSE: Plaintiffs are producing the Release and Settlement
Agreeement, dated March 26, 2007.

At the end of this document is an agreement between Narconon of Georgia (signed by Mary Rieser, Executive Director of NNGa) and Georgia Department of Human Resources/Office of Regulatory Services (signed by Sharon Dougherty, Interem Director, Office of Regulatory Services).  It states:

Quote
RELEASE AND SETTLEMENT AGREEMENT
1. Release. IN CONSIDERATION OF THE ISSUANCE OF A LICENSE TO
NARCONON OF GEORGIA, INC. ("NARCONON") TO PROVIDE DRUG ABUSE
TREATMENT AND EDUCATION PROGRAMS, INCLUDING THE OPERATION OF
AN AMBULATORY DETOXIFICATION FACILITY, by of on behalf of the State of
Georgia, Department of Human Resources ("DHR"), Narconon does hereby release and
forever discharge DHR, together with its principals, agents and assigns, as well as all
parent, subsidiary, and affiliated agencies, from any and all claims, demands, rights and
causes of action of any kind and nature for any and all known and unknown, arising or
resulting from, connected with or in any way relating to Narconon's appeal of DHR's
denial of its application for a license to provide a Drug Abuse Treatment and Education
Program under Rule 290-4-2 et seq. (the "Rules"), currently pending in the Georgia
Office of State Administrative Hearings (Docket No. OSAH-ORS-DATP-0709658-67-
Brown ("Appeal")).

IT IS UNDERSTOOD AND AGREED that this is a release of any and all claims of
Narconon which were or could have been asserted against DHR in the referenced appeal,
which will be dismissed with prejudice; by Order of the Administrative Law Judge upon
the issuance of said license by DHR.

IT IS UNDERSTOOD AND AGREED that issuance of a license to Narconon by or on
behalf of DHR is in compromise and settlement of an appeal by Narconon which is based
on factual and legal arguments not admitted, but which are denied and disputed by DHR;
as well as that this Release is conditioned upon Narconon's ability to meet, and continue
to meet; the Rules governing the conduct and operation of Drug Abuse Treatment and
Education Programs, including Ambulatory Detoxification Facilities.

IT IS UNDERSTOOD AND AGREED that the program offered by Narconon will meet
the requirements of a Drug Abuse Education and Treatment Program, including
Ambulatory Detoxification Facilities, under the above-referenced Georgia rules,
including the following aspects:

• Clients will enroll in the Narconon program by visiting the Narconon facility,
applying for participation and paying the participation fee. At this time,
Narconon will provide the Vitamin Data Sheet to clients, inform the clients of the
risk and benefits of taking vitamins in excess of the U.S. Food and Drug
Administration's recommended daily allowance and the IOM recommended
upper daily limit, and ask the client to sign a consent form reflecting the client's
understanding of these risks and benefits, as well as the client's agreement to
participate in the Program.  This form will be distinct from any consent for
treatment required by the Medical Director.

• Narconon will refer the client to the Medical Director for initial treatment and
assessment.  The Medical Director will be responsible for medical oversight and
will be available twenty-four (24) hoars a day on an "on-call"' basis. The Medical
Director will issue appropriate orders if the client intends to participate in
Narconon's Ambulatory Detoxification program (including the vitamin regimen
already discussed), which is administered on Narconon's behalf by Pur-O-Cleanse1.

• Narconon, will ensure that Pur-O-Cleanse meets the applicable regulatory
requirements for that portion of Pur-O-Cleanse's business operations Which affect
Narconon's clients.  This includes assurances by Pur-O-Cleanse that it will not
permit Narconon clients to intermingle with other Pur-O-Cleanse customers.

• Likewise, Narconon will employ a Registered Nurse to provide medical oversight
under the direction of the Medical Director, and to supervise a Licensed Practical
Nurse ("LPN") who will provide clinical services to clients participating in the
Ambulatory Detoxification Program while on-site at Pur-O-Cleanse. The LPN
will be present at Pur-O-Cleanse at all times that Program participants are there,
and the LPN will meet the training requirements in the Rules. In an effort to
ensure consistent, comprehensive coverage daring these times, Narconon may
develop an internal "PRN float pool" or contract with a nurse staffing agency for
this service. Either way, Narconon recognizes its obligation to maintain personnel
records an any and all LPNs, as well as the RN, in accordance with the Rules.

• Narconon will transfer clients to the Ambulatory Detoxification Program for these
services and document this transfer in the client's records. Likewise, once the
client has completed the Ambulatory Detoxificatian Program, as determined by
the Medical Director, Pur-O-Cleanse will transfer the client back to Narconon for
the Outpatient Drug Treatment Program. The Medical Director will assess the
client's physical condition again at the time of transfer.

• Throughout the client's participation in the Program, Narconon will maintain
timely and accurate documentation of transfers, vitamins self-administered by
clients, under the supervision of a licensed nurse, vital signs as necessary, and any
other information required by the Rules or by the Medical Director.

2. Acknowledgement by Narconon: IT IS FURTHER UNDERSTOOD AND AGREED
that Narconon and DHR have completely read and understood the terms of this Release
and had the opportunity to discuss same with counsel and agreed that the Release is
voluntarily accepted for the purpose of making a full Release of all actions, causes of
action, claims and demands for, upon, or by reason of any issue, known or unknown,
which may be traced to the Appeal, as now appearing or as may appear at any time in the
future, be connected with, be a consequence of, or relate to The Appeal.

3. Severability: This Agreement is intended to be performed in accordance with and to the
extent permitted by all applicable laws, ordinances, rules and regulations. If any
provision of this Agreement, or the application thereof to any person, corporation, entity
or circumstance shall, for any reason and to any extent, be invalid or unenforceable, the
remainder of this Agreement and the application of such provision to other persons or
circumstances, shall not be affected thereby but rather shall be enforced to the fullest
extent permitted by law.

4. Entire Understanding: This Agreement contains the entire understanding of the parties.
This Agreement supersedes any prior understandings or agreements, oral, implied or
written, and none of the parties is relying on any promises. representations,
communications, statements, assertions, declarations, admissions, agreements,
arrangements or understandings, oral, implied, or written, that are not fully expressed
herein. This Agreement is a result of arms length negotiation between the parties.

5. Binding Effect: The terms of this Agreement are binding as to each and every party
hereto, their agents, successors, assigns, employees, subsidiaries, affiliates, and
contractors.

6. Choice of Law: This Release is to be governed in all respects by the laws of the State of
Georgia and the Rules and Regulations for Enforcement and operation of an Ambulatory
Detoxification Program.

7.  Cooperative Effort: This Agreement has been drafted through a cooperative effort of all
parties, and no party shall be considered the drafter of this Agreement so as to give rise to
any presumption or convention regarding construction of this document.

8. Amendment of Agreement: This Agreement may not be changed orally, but only by a
writing signed by all parties.

9. Effective Date and Signatures: This Agreement shall be effective on the date it is
executed by the Parties below, and it may be signed in counterparts, each counterpart
having the same force and effect as any other. Facsimile signatures shall have the same
force and effect as originals.

10. Headings: The headings contained herein are for purposes of reference only and have no
legal significance.

Signed, sealed and read this 26 day of March, 2007.

1 Or any other provider Narconon contracts to provide this service.

 

 Take one part Georgia Department of Community Health and one part NarCONon of Georgia/International, Shake well and what do you have? A recipe for disaster!

 The DCH when signing the above March 2007 agreement with NarCONon of Georgia/International KNEW this whole affair would come back and bite them (DCH) in the ass!

 The DCH and citizenry had to only wait 15 months after the agreement was signed to reap the horror both the DCH and NarCONon unleashed on the unsuspecting public.

 Both signing parties IMHO bare equal guilt in the tragic death of Patrick W.Desmond.

 

Offline mefree

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 Take one part Georgia Department of Community Health and one part NarCONon of Georgia/International, Shake well and what do you have? A recipe for disaster!

 The DCH when signing the above March 2007 agreement with NarCONon of Georgia/International KNEW this whole affair would come back and bite them (DCH) in the ass!

 The DCH and citizenry had to only wait 15 months after the agreement was signed to reap the horror both the DCH and NarCONon unleashed on the unsuspecting public.

 Both signing parties IMHO bare equal guilt in the tragic death of Patrick W.Desmond.

I get the impression DCH signed this agreement under protest and can't help wonder what forces were at play.
The ultimate authority must always rest with the individual's own reason and critical analysis.
-Dalai Lama

Offline ethercat

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I get the impression DCH signed this agreement under protest and can't help wonder what forces were at play.

I get that impression too:
Quote
IT IS UNDERSTOOD AND AGREED that issuance of a license to Narconon by or on
behalf of DHR is in compromise and settlement of an appeal by Narconon which is based
on factual and legal arguments not admitted, but which are denied and disputed by DHR;
...

   Narconon Reviews
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   Answers to Frequently Asked But Seldom Answered Questions

Offline Mary_McConnell

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Wow! That's a lot of dox! In that post you may want to explain what a certificate 5.2 id for the newbies.

 ooo:/  I thought I did, but to interpret the law I posted above: A Rule 5.2 Certificate is essentially a Certificate of Service, that is to say, it's a paper delivered to the court to certify that the actual documents were delivered to the party(ies) to the case. 

Discovery material and pleadings (i.e, dox) are not supposed to be filed with the court until they are needed (if needed) for the case.  I speculate that this is to save space in the courthouse, so there are not documents being stored there and taking up space unless they are actually going to be used in the case.

Quote
ps: These 3 below are getting error 404 NOT FOUND responses

http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-17-NNGAs1stRequestForAdmissionsToPlaintiffs.pdf

http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-17-NNGAs1stSupplementalObjectionsAndResponsesToPlaintiffsFirstInterrogatories.pdf

http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-17-NNIs1stSupplementalObjectionsAndResponsesToPlaintiffsFirstInterrogatories.pdf

Fixed - I missed uploading them; they're there now, along with the 2012-04-18 Lisa Robbins Answer.

There from your post on the docs are getting 404 not found notices too:

After that, came these, of which you have already seen (or at least had the opportunity to see) the Plaintiffs' Brief in Support Of Motion for Sanctions:
http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-11-LetterToJudgeHydrickFromJeffreyHarris.pdf

http://alley.ethercat.com/storage/10A28641/10A28641-2-2012-04-13-NNGAsMotionForTimeToReplyToPlaintiffsOralMotionForSanctions.pdf

I am a volunteer advocate for victims of the Narconon scam. I am a former scientologist. I post anonymously. Mary McConnell is my long time nom de plume. Feel free to contact me for assistance in righting the wrongs.

Offline ethercat

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Thanks for letting me know, Mary.  They're there now. 
   Narconon Reviews
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Offline ethercat

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Now that the facts are filling in a bit more, Mary Rieser's deposition may be an interesting read for those who haven't read it, and a good reread for those who have.

Exhibit 2, starting on page 28 of the PDF:
http://alley.ethercat.com/storage/10A28641/10A28641-2-2011-05-25-BriefInSupportOfPlaintiffsMotionsForSanctions.pdf
   Narconon Reviews
   Independent Reviews of the Narconon Drug Rehab Programs
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Offline Sunshine

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Wow, what a document this I need to read several times.

Page 15
22 A. There was a seminar, serninars, His name is Kent McGregor.

I wonder if this is the same Kent and if so was this before he went to work for CARF?
. http://www.cs.cmu.edu/~dst/Stop-Narconon/AdvisoryBoard/