10A28641 2 2011-11-18 DepositionOfTraceyStepler Ocr

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Desmond, et al. v. Narconon, et al. Tracey E. Reynolds (Stepler) - 11 /18/2011

IN THE STATE COURT OF DEKALB COUNTY STATE OF GEORGI A

PATRICK C. DESMOND AND MARY ) c ·. DESMOND , INDI VIDUALLY, AND) MARY C. DESMOND, AS ) ADMINISrRATRIX OF THE ESTATE ) OF PATRICK C. DESMOND , )

Plaintiffs , ) ) CIVIL ACTION FILE

vs. ) ) NO . 10A2864 1-2

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

Defendants. )

Vi deo deposition of TRACEY EVELYN REYNOLDS

(STEPLE~) , taken on behalf of the P l aintiffs ,

pursuant t o the sti pul ations contained herein,

before Jo Tomoff Fischer , RMR, CCR No . B- 924 , at

880 West Peachtree Street, Atlanta , Georgia , on

November 18, 2011, commencing at the hour of

10:09 a .m.

Q&A REPORTING SERVICES, INC. Certified Cpurt Reporters 2165 Fairhaven Circl e , NE

. Atlanta , GA 30305 404 .233 .3300 ** (Fax) 404 . 233 . 1 530

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

1 APPEARANCES OF COUNSEL 2 ON BEHALf OF THE PLAINllFFS: 3 REBECCAFRM1<LIN, ESQ.

Fr.mklin Law, LLC 4- 400 Colony Square, Saite 900

1201 Peachlrte St=t, NE 5 Atlanta, GA 30361

(404) 961·5333 5 1

ON BEHALF OF 111EDEF"ENDANfS NARCONON OF GEORGlA a aodNARCONONJNTERNATIONAL: 9 KATHRYNS. Wlll'TLOCK, ESQ.

Drew, Eckl & FamhiU!l, LLP l 0 SSO West Peachtree Street

P.O. Box 7600 ll Atlanta, GA 30357

(404) 885-1400 12 13

ON BEHALF OP TiiE D£!F'f2\'DA.'IT DELGADO DEVELOPMENT: 14

CALVINP. YAEGER, ESQ. 15 Downey & C1eve!and, llP

288 Washington Avenue 16 1\{nrietto, GA 30060

(770) 422-3233 l7 19 19 ON BEHALF OF THE DEFENDANTS LISA CAROLINA ROBB!KS,

M.D. and TilE ROBBINS OROUP,JNC.: 20

JEFFREY N. AMASON, ESQ. 21 Weinb<:rg, Wheelet, Hudgins, Gwm & Dial, LlC

Suite2400 2 2 3344 Peachtree Road

Atlanta, GA 30326 2 3 ( 404) 876-2700

. 24 ALSO PRESENT: ELIZABETH KEMP, Legal Technology

2 5 Servioes, 770.554-1633

1 illDEXTO~ATION 2 3 By Ms. Franklin. ....... , .•... .•. . . . 5 4 By Ms. Whitlock .......... . .. . ..... .100 5 6

7 8 9

10

11

12

lNDEX TO EXHIBITS PlAINTIFFS' EXHIBIT DESCRIPTION

1 Organization Chart 21

2 9-1 0-07 Fax from M. Rieser 13 to L Mooty 38 14 3 9-10-07 Letter from T. Stepler

to Mr. Berry 40 · 15

4 Narconon of Georgia 1 6 Orientation Checklist 50

PAGE

17 5 9-26-07 P. Desmond Post-orientation Interview 57

18 6 S-30-08 E-Mail from M. O'Donnell

19 {o L. Mooty 66 20 21 22 23 24 25

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.r __..,...,_ ..... ~ .... - Oi"'="c ... 1 ........ -. _.,.. •o'>,b....:::;;;:;e;:.-:p·· - . -

Tracey E. Reynolds (Stepler) - 11/18/2011

Page 4 ~ (THE FOLLOWING mANSCRIPT CONTAINS QUOTED ~

" MATERIAL; SUCH MA TERlAL IS REPRODUCED AS ~ READ OR SPOKEN.) I

i - - -

I (IN THE FOLLOWING TRANSCRIPT, A DASH [ -- ) ~ IS USED TO INDICATE AN UNINTENTIONAL OR PURPOSEFUL IN1ERRUPTION OF A SEN1ENCE; i ANELLIPSIS [ ... ]IS USED TO INDICATE HALTING SPEECH OR AN tiNFTNISHED SEN"TENCE IN DIALOGUE, OR AN OMISSION

I OF WORD[S] WHFN READJNG WRlTIEN MATERIAL.)

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I (TI1ereupon, the court reporter disclosed that she was there on behalf ofQ &·A Reporting Services, Inc. I Incompliance with Article lO.B of the Rules and Regulations of the Board of Court Reporting of the s Judicial Council of Georgia and O.C.G.A. 15-14-37(a)

I and (b), the court reporter discloses that she VI'!IS

retained by Rebecca Franklin, Esq., to ta_lce down

~ the proceedings. Q & A Reporting Services, Inc. will charge the attorneys the usual and customary ~

rate for the transcript, and '1'.111 be paid by the ~ attorneys upon their receipt of the transcript.)

I il ·~

- - - j Page J 5 ~

(Off video record.) ~ !

MS. FRANKLIN: Just for purposes of the g record, we're taking the deposition of Tracey ; Evelyn Reynolds pursuant to the Georgia Civil Practice Act and the standing order in this case. Anything else you all want on the record?

MS. WHITLOCK: Nothing. ~ MR. AMASON: No. ~

(On video record.) TilE VIDEOGRAPHER: One moment. Stand

by. ~

. We're now on the video record. This is ~ a the beginning of tape number 1; the time is I 10:09 a.m. ~

MS. FRANKLIN: Swear in the witness. j TRACEY EVELYN REYNOLDS (STEPLER), I

having been first duly sworn, was examined and ~ 1

testified as follows: I EXA.i\1INATION il

BY MS. FRANKLIN: ~ Q. Ms. Stepler, could you please tell us your ~

~ full name? ~ A. It's Traeey Evelyn Reynolds. I do go by ~ Tracey Stepler--that's my married name-but I haven't

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Desmond, et a l . v. Narconon, et al.

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legally changed it. 1 Q. Okay. Cani call you Tracey? 2 A Sure. 3 Q. Okay. Tracey, where do you live? 4 A. I live in Roswell. 5 Q. Can you give us your address, please? 6 A It's 111 Warm Springs Circle. 7 Q. Okay. And what's your birth date'? 8 A. 6-23-73. 9

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Q. How long have you lived in Roswell? 1 0 A. About seven years. 11 Q. Okay. Where did you live before that? 12 A Doraville. 13 Q. What -- maybe this is the best way to start; 14

where were you born? 15 A. New York. 16 Q. And when did you move to Georgia? 1 7 A. Approximately ... Probably about 13 years ago, 1 8

14 years ago. 1 9 Q. Okay. I'm bad at math; how old were you when 2 0

you moved to Georgia? 21 A. 24. 22 Q. And did you move to the Atlanta area when you 2 3

first moved to Georgia? 2 4 A Yes. 25

Page 7

1 Q. Okay. Where? 2 A. It would be -- have been -- I guess that area 3 is considered Sandy Springs. 4 Q. All right. And have you always lived in 5 the -- ·when I say "the Atlanta area," I - I mean 6 Roswell, Sandy Springs, so I guess the greater Atlanta 7 area, since you've moved to Georgia 13 years ago? 8 A. Yes. 9 Q. Okay. And what do you do for a living?

1 0 A. I work at a medical office. 11 Q. And give me the name of that medical office, 12 :ifyou will. 13 A It's Natural Health Solutions. 14 Q. Okay. What do you do there? 15 A. Administrative work. 16 Q. Are you a -- a receptionist, or -- do you have 17 a title, or just administrator, administrative 1 8 assistant? 19 A Yes. 2 0 Q. Okay. And how long have you worked at Natural 21 Health Solutions? 2 2 A. I don't know the exact time. 23 Q. Can yougiveme an approximate ammmtoftime? 2 4 A. A year and a hal£ 2 5 Q. And what did you-- where did you work before

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Tracey E. Reynolds (Stepler ) - 11/18/2011

you worked at Natural Health Solutions? A. Narconon. Q. Narconon of Georgia? A. Uh-huh (affumative).

·Page

Q. And bow long did you work at Narconon of Georgia?

A. I don't know the exact time. Q. Okay. If you can just give me an estimate of

bow long you worked there. A. 11aybe three years. Q. Sofrommaybe2007to2010? A. TI1ere was some space in beh¥een when I started

work at this new job and left Narconon. So I'm not sure.

~

I I ~~· ..

Q. Okay. So you had som~ time between Narconon ~

and this new job? a A. Thafs right. Q. All right. What did you do before you worked

at Narconon of Georgia? A. I worked at a place called Price Breakers. Q. Price Breakers? A. Uh-huh (affirmative). Q. Where is that? A. It's no longer in existence. Q. Where was it?

Page 9 ,

I A. It was in -- kind of like in the -- not in ~ the -- right in the downtown area, but near the downtown J

~ area.

Q. DowntownAtlanta? A. Near Howell Mill. Q. Okay. A Near Howell Mill. Q. And what - what is, or what was, Price

Breakers? A. A wholesale company of women's clothing. Q. How long did you work there? A. Again, I don't know exactly. Q. If you can just give me some rough estimates,

I--A Okay. Q. This isn't a test, I promise. A Okay. Probably about a year and a half or so. Q. What did you do before Price Breakers? A. I worked at my church. Q. What's your church? A. Chmch of Scientology. Q. Here in Atlanta? A. Yes. Q. What did you do for the Church of Scientology

when you worked for them?

3 (Pa ges 6 to 9)

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Desmond, et al. v. Narconon, e t al. Tracey E. Reynolds (Stepler) - 11/18/2011

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1 A. I held cliff- several different positions. 1 A. I don't -- ~ 2 Q. Ifyoucouldlistthoseallforme,please. 2 Q. --Tracey? ~ 3 A. I was the organization officer. I was an 3 A. I don't even have any idea. I~ 4 auditor. And I think- those are-- that's probably 4 Q. Okay. More or less than a year? ~ 5 officially it, yeah. 5 A. I really don't know. I don't. I don't know. i 6 Q. Okay. Are- so are you still certifie-d to do 6 Q. All right. Did you have any other jobs in i 7 auditing for the church? - 7 Plano, Texas? ] 8 A. Yes. 8 A. No. J 9 Q. - Qualified? 9 Q. Where did you work before you -- Seventh ~

~ 10 Howlongdidyouwm:k--workfortheCburch 10 Avenue? i 11 of Scientology? 11 A. I don't know. I had some high school jobs, -12 A. Approximately 12 or 13 years. 12 some different things when I went to school. MJ:: .. -13 Q. And while you were there, the - your only job 13 Q. Okay. Where did you go to high school? 14 titles were as an organization officer and an auditor? 14 A. Rutherford, New Jersey. And I also -I 15 A. In Atlanta, yes. 1 5 attended high school in Dallas. I 16 Q. Okay. "What did you do before you worked for 16 Q. Okay. What were the names of those high ~ 1 7 the Church of Scientology in Atlanta? 17 schools, if you will? I 1 8 A. I worked for the Church of Scientology in 18 A. Rutherford High and-- I don't-- I don't even i 19 Dallas. 19 remember the one in Dallas. ~r!~·. 2 0 Q. Okay. And what-- what did you do there? 2 0 Q. Okay. 21 A. Admini -- different administrative jobs. 21 A. lin sorry. 2 2 Q. Did you have any titles? 2 2 Q. That's okay. Were either.- which one did you ! 2 3 A LRH communicator. 2 3 graduate from? ~

; : ~: ~:~:~~~~~~ corps member. And I think ; i ~: ~f~;.'t ~~:~~:r~l~~~~~c~~~~tfade. ~ ~----~~~====~==~~~==~~~~==~-r------~-=~~~~==~~==~~~-------4~

Page 11 Page 13 1 1 I was the OES--again, the organization executive 1 Scientology-based schools? I 2 secretary-for a little bit. 2 A. No. ~ 3 Q. Okay. Where did you do your technical 3 Q. Now, you mentioned that you lived in i 4 training? 4 Califomia and you did your technical training at the i 5 A. I did part of it at- in Dallas and part of 5 Celebrity Center; is that conect? ;,~ 6 it in California. 6 A. Yes. ~

7 Q. Where in California? 7 Q. When-- when did you do that? ' 8 A. At Celebrity Center Intemational. 8 A. I'm not sure ofthe exact year. 1 9 Q. Okay. Is that there on Hollywood Boulevard? 9 Q. If you can just give me an estimate -- j

10 A. NWho. th ? 11

01

AQ. Iy,was 21,- ~ 11 Q. ere is at. . ou were - • 12 A. I don't know the street it's on. I don't 12 ·A. -- whatever... I 13 remember the street name. 13 Q. -- 21, all right And you were born in '73-, ~

14 Q. All right. So how-- I'm sorry ifl already 14 so-- ~ 15 asked you this; how long did you work for the Church of 1 5 A. So approximately -- I 16 Scientology in Dallas? 1 6 Q. - '94-ish? ~

1 7 A Probably about five years. Approximately. 1 7 QA.. AAllppn~oghximal Hteolwy,lyoen~1di. 'd you Il·,·e l·n ~ 18 Q. Okay. And did you -where did you work 18 ::_ . ~

19 before the Church of Scientology in Dallas? 19 California? ~ 2 0 A. I worked at a clothing store. 2 0 A I was there, I think, about a year. ~ 21 Q. Where? 2 1 Q. What brought you to California? ~ 2 2 A. In -- in -- in Plano, Texas. 2 2 A. The training. ~ 2 3 Q. 'What's the name of that clothing store? 2 3 Q. All1·ight. And you lived in Dallas before ~ 2 4 A. Seventh A venue. 2 4 that? l 2:_=-·~~d~o_::~~:,~~~!:~~--®"'}5 __ ~~.~yes, ... ~~}n~~·-~:h~~ _ J

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Des~ond, et al . v . Narconon, et al. Tracey E. Reynolds (Stepler} - 11/18/2011

Page 14 Page 16 I ~ ~ 1 (affirmative). 1 A. Well, the Narconon-speci:fic training I did at

2 Q. How did you become affiliated with the Church 23

Narco~on, butdthied~d- I'hatve be~n :rainedthas ahcash.e i 3 of Scientology? superVIsor, an 1 t trainmg at e c urc l

4 A. My brother-in-law. 4 Q. Okay. And how are they different- I 5 Q. He's a member of the church? 5 different, if they are? ~ 6 A. Yes. 6 A. The -- I mean, you're dealing with different i 7 Q. Didn't -- does he live or did he live in 7 people, obviously, that's specific to people who are or ~

j 8 Califomia? 8 have been on drugs. So that's different. But otherwise ~ 9 A. No. 9 the basic same principles. ~

10 Q. Where did he live? 10 Q. Okay. Because the Narconon program has the ~

11 A. In Dallas. 11 same -- similar principles as the Chm'Ch of Scientology ! 12 Q. All right Did you- besides doing your 12 teachings; is that correct? ~ 1 3 technical training at the Celebri -- Celebrity Center, 13 A. Same tenets, some similar tenets, yes. ~ 14 did you hold any jobs while you lived in California? 1 4 Q. All right So tell me what-- about the ~ 15 A. No. 15 training-- specific you --training you had for working ~

16 Q. All 1igb.t, let's get back to-- well, not your 1'6 with Narconon students. r! 17 current job, 'cause you-- you work for Natural Health 17 A. Basically they're looking at their worksheets. ~ 18 Solutions, coiTect? -- 18 Some people would need to go on certain actions longer ~ 19 A. Uh-huh (affirmative). 19 because they have been addicted to drugs in the recent ~ 2 0 Q. --Now, right? 2 0 past ~

l 21 When you worked for Narconon of Georgia, how 21 Q. Okay. Who - who provided this training? You ~ 2 2 did you get to Narconon of Georgia? How did you get 2 2 said Narconon earlier? I need to know persons. People. ~ 2 3 that job? 2 3 A. Okay. I- I don't understand the question. ~ 2 4 A Through Mary. 2 4 Q. Okay. And that -that's fair enough. ~

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1 A. Yes. 1 know, 'cause 1'11- I'm liable to ask a bad question. ~ 2 Q. - Rieser? 2 Or two. Or more. 3 A. Yes. 3 A. Uh-huh (affinnative). 4 Q. How did you know Mary? 4 Q. Did Mary Rieser train you for the Narconon 5 A. From my church. 5 program? 6 Q. The church, all right. And what was your 6 A. Yeah, she did some of it. 7 first position at Narconon of Georgia? 7 Q. Okay. Who else? 8 A. I supervised the case folders. 8 A. And -- I -- I'm going to ask for a 9 Q. Okay. Youwere--wereyoucalledacase 9 clarificationofthequestion. Becauseidon't

1 0 supervisor? 1 0 understand, when you're saying "training," -11 A. Yes. 11 Q. Okay. 12 Q. All right. And what training were you 12 A. --what you're talking about. 13 provided before you became a case supervisor? 13 Q. Okay. I asked you earlier what -- what 14 A. Case supervisor training. 1 4 training you were provided in order to become a case 15 Q. Okay. And tell me about that. 15 supervisor. 1 6 A. ·Basically studying how-- what to look for iu 1 6 A. Okay. 17 the worksheets ofsomebody's folder. You're looking for 1 7 Q. Does that make sense? Does that question make 18 certain end points on different processes. 1 B sense? 19 Q. Okay. And who -who provided that tra.inlng? 19 A. Yes; I was trained at the church to become a 2 0 A. Ma -- Narconon and the church. 2 0 2 1 Q. Okay. TheChurchofScientology? 2 1 22 A. Uh-huh(affumative). 22 2 3 Q. And where did you- physically where did you 2 3 2 4 do that training? Was it at Narconon of Georgia, or did 2 4 2 5 you do it in California? In Dallas? 2 5

case supervisor. Q . Okay. A. I didn't need additional training to do that

job. Q. Okay. And you- and you- you didn't need

any additional training to be a case supervisor at

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Desmond, e t al. v . Narconon, et al.

Page ·18

1 Narconon? 2 A Right 3 Q. Okay. So did you have any specific training 4 in drug or alcohol addiction outside of your case 5 supervisor training with the church? 6 A. No. 7 Q. What --how long did you hold the title as a 8 case supervisor when you were with Narconon of Georgia? 9 A. The whole time that I was there.

10 Q. Okay. What other job positions did you have 11 when you were there? 12 A I did intake. 13 Q, All right. Explain to me what you mean by 14 that; what - what was your -- what did you do as an 15 intake -- supervisor, is that what they were called? 1 6 A. I didn't really have a title as that - as 1 7 that position, necessarily. 1 8 Q. Okay. 19 A I mean, I acted as -- in that capacity. 2 0 Q. Okay. And what did you do? \\Then you say you 21 "did intake," what did that mean? 22 A If somebody called about the program, I would 23 explain what the progtarn was about and answer any 2 4 questions. And then when the person arrived to the 25 program, I would sometimes check them in as welL

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1 Q. Okay. And were you provided any specific 2 training for that position, or-- or that job? 3 A. On-the-job training. 4 Q. By who? 5 A. I worked with Kmtis, a person who did intake 6 before me. 7 Q. Do you know Kurtis's last name? B A Money. 9 Q. Okay. Anybody else provide any on-the-job

10 training for your role as an intake person? 11 A. I don't remember. 1 2 Q. All right. Besides doing intake and acting as 13 a case supervisor, what other job titles or duties did 14 you have at Narconon of Georgia? 1 5 A. None. 1 6 . Q. What did you do as a case supervisor? 17 A. I looked over the folders. 18 Q. These are the student folders? 19 A. Yes. 20 Q. When you say you "looked over" them, what does 21 that mean? 2 2 A. When they completed a portion of certain 23 books, I would look at the folder, the worksheets that 24 were in there, and see if they could go on to the next 25 action. ~'$>-;_.._.,.,.,.,~~-~~b-------- ...... ,.., .... ,

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Tracey E. Reynolds (Stepler ) - 11/18/2011

Page

Q. Okay. Did you do any auditing of students while you were atNarconon?

A. No. Q. Do you have any training at all-- and I asked

you earlier specific to Narconon of_ Georgia, but do you have any training in drug and alcohol rehabilitation or counseling?

A. No. Q. Why did you leave Narconon of Georgia? A At the time, I wanted to pursue something

else. Q. Which is your current job? A. No. Q. Okay. What did you want to pursue -- you said

a ye.ar and a half ago is when you left? A. Uh-huh (af:finnative). Q. All right. What was it that you wanted to

pmsue? A. I didn't know exactly; I just didn't want to

do that job anymore. Q. Did you leave on bad terms? A No. Q. How did you find your job at Natural Health

Solutions? A. My husband is !he office manager.

Page

Q. And what is Natural Health Solutions? A It's a natural medical -- well, it's a natural

health office. Q. Is it -- is it affiliated with the Church of

Scientology? A. No. Q. And where is it located? A. It's in Roswell. Q. Do you know the address? A. Yes. It's 11285 Elkins Road. Q. All right.

(Discussion off the record.) (Thereupon, marked for identification purposes, Plaintiffs' Exhibit No. 1.)

BY MS. FRANKLIN: Q. Ms. Stepler, I'm going to hand you what I'm

marking as Plaintiffs' R'<lnbit 1. This is --::viS. FRANKLIN": rve only got one copy ... MR. AMASON: That's fine.

BYMS. FRANKLIN: Q. Do you recognize that docmnent? A. No. i Q. Do you-- you see your name under the sort of J

bottom set of boxes, under "Qualifications Division 5," ~

_, ~~t~ ·-~ ~v-~ ~''M_,_ ->§40~ 6 (Pages 18 to 21)

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Desmond, et al . v . Narconon, et al . Tracey E. Reynolds (Stepler ) - 11/18/2011

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A. Yes. Q. Okay. What-- did you hold some position

called "Qualifications Division 5"? A. No. Q. Okay. So do you know what tbat means? A. Yes. Q. What? A. That's the division that the case supervisor

would be in. Q. Explain that tome. A. That's - I don't understand the question. Q. Okay. So case supervis - let me back up.

Page 22

How many case supervisors were at Narconon when you were there?

A. There were several people that could hold that position. And several people who did, from time to time.

Q. Well, was there anyone -- when you were acting as a case supervisor, was anyone else acting as a case supervisor?

A. Yes. Q. Who? A. Mary Rieser. Q. Okay. Who else? A. Abby Bailey.

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A. At her office. ~ Q. And why did you visit Dr. Robbins, to her ~

3 office? ~

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A. I took someone there. Q. You took a student there? A. I took-- yeah, I took a student there. I Q. Okay. Did you ever talk with Dr. Robbins 1

about her role as the medical director? ~ A. I don't know. ~

Q. Do you know what her duties were as a medical I director? !

A. Probably not completely. ~ Q. Okay. Well, tell me what you do know. Or I

whatyouremember. ~ A. She would see the students when they came in I

to the program. She would see them inte11nittently if ~ they needed something additionaL I think that's it. ~

Q. Okay. Did you ever see Dr. Robbins ever visit ~

the Narconon facility? ~

A. I di~~ i Q. Do you know whether she did? j A. I couldn't - I feel like I would be guessing. i

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Do youiever -- do you have any independent .~,~.j reco ection? understand you say you never saw her, -

2 5 but did you ever hear of her visiting the facility? ~ · Page 25 1

!l.~ Q. Anybody else? 1 A That's the part I would be guessing at. ~

A. Not as far as I know, no. 2 Q. Okay. ~ Q. Okay. What does the title "Qualifications 3 A I feel like I did, yes. ~

Division 5" meat.1? 4 Q. But you're not sure? ~ A. "Qualifications" means that is the -- akin to 5 A. Right. 1

a quality control section. And the division is just in 6 Q. Okay. Now, this "Pur-0-Cleanse," which is the ~~ order ofthe number. Division 1,2, 3, 4 and 5. 7 box out to therightofDr. Robbins, what is that?

Q. Okay. !understand. 8 A. Where is that? Okay. Timt v.ras a company that ~~, So you also held -- well, you told me earlier 9 delivered the sauna program.

You also perfom1ed the duties of the intake coordinator, 1 0 Q. Okay. And when you say a "sauna program," was ~ which is under Division 6B, correct? 11 that similar-- similar to the Purification Rundown· J

A. Yes. 12 program within the Church of Scientology? 1 Q. Okay. But did you ever officially hold that 13 A. Yes. i

title? 14 Q. Were there any differences? ~ 15 A. I don't un -- I don't know. 1 5 A No. j 16 Q. Now, the sort of top middle box has "Medical 1 6 Q. The ·- tlllder -if you go to sort of tvvo boxes ~ 17 Director,11 and it lists "Dr. Lisa Robbins"; do you know 17 to the right, it says "Sauna In Charge, Martin Cohen.'' ~

~

18 her? 18 Do you know who that is? ~ ~

1 9 A. Yes. 19 A. Martin, he -- yeah; he was the person who ran i

2 0 Q. How do you know her? 2 0 the sauna for a time. ! 21 A. She was the medical director. 21 Q. Was he affiliated with Narconon in any other ~ 2 2 Q. How many times have you met Dr. Robbins? 2 2 way that you knew of, or know of? ~ 23 A. Maybetwice. 23 A. Yes. ~

2 4 Q. Was it there at the Narconon facility, or at 2 4 Q. How so? ~1

2 5 her office? Or somewhere else? 2 5 A He did the program himself at one time.

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1 Q. Okay. Do you remember him having any job 1 MS. WHITLOCK: Do you want to take a break? 2 titles, did he work at the program -- besides maybe 2

3 being a student, and I don't want to know anything about 3 MS. FRANKLIN: If you want to take a break, that's fme. 4 that. But was he -- did he ever --was he ever employed 4

5 or work at Narconon? 5 THE VIDEOGRAPHER: Going off the video record at 10:38. 6 A. I don't think so. 6

7 Q. He's a member of the Church of Scientology, is 7 (Recess at 10:38, resumed at 10:45.) 8 henot? 8 11ffi VIDEOGRAPHER: One moment. Stand 9 A. I don't have any information about that. 9 by. We're back on the record at 10:45.

10 Q. Okay. Now, you'llseesmtofonelevel 10 BYMS.FRANKLIN: 11 below, maybe two levels below, there -- the names for 11 Q. Okay. Ms. Stepler, before we broke I asked 12 "Senior Director of Administration" and "Senior Director 12 you a question about Mr. Chorvas, and - and I just want 13 for Expansion." That's Maria and Don Delgado. Do 13 you to know I'm not trying to upset you, I-- !just 14 you-- did you know Mr. or Mrs. Delgado? 14 have to -I've just got some questions that I don't 15 A. Yes. 15 knowtheanswerto. -16 Q. And what were their job- well, let me back 16 A Ifs okay. f 17 up. Were those- those their job titles when you were 17 Q. Do you- I think the question was, do you ~ 18 there? Director of administration and director for 18 know the circmnstances suiTounding Mr. Chorvas's death? i.-

19 eJ.:pansion? 19 A Yes. ~ 2 0 A. I don't- I don't think Maria-- welL I 2 0 Q. Can you tell us about that? ~ 21 don't know. 21 A He- he passed away from cancer. ~ 2 2 Q. What did you understand their job to be when 2 2 Q. And was this while you were working at i 2 3 you were there? 2 3 Narconon? ~~.· 2 4 A. Don helped with marketing, and Mmia I -- what 2 4 A. No.

I-2_5_...:I:...:s:.::a:.::w...:s:.::h..:..e.:::;:di:.::d;...;was..:.=....:::ethi=·c:..::s.:.... -----------t-2_5 __ ~ Q .. _ W:...:.:..::as::...:.:it....:::aft=er:..:..? ____________ -1~ Page 27 Page 29 I

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~ Q. Was she the ethics officer? 1 A. Yes. t A. No. She-- I-- she prob- what I'm saying 2 Q. Were you-- were you close to hlln? i

is I don't know if that's the title t11at she was. 3 A. Yes. ~ Q. What do you re -- 4 Q. What kind of cancer did he have? I A. It - 5 A. Pancreatic, I think. ~

6 ~ Q. Sorry. Q- Okay. So- 1 A. It makes sense that that was the title. I 7 A. I'm pro --I'm sorry, I think it was pros - I ~

don't know for sure. 8 don't know. It was either prostate, something like... j Q. Okay. Youmentionedethics. Idon'tseeon 9 Q. Do youknowhowlongagohepassedaway? ~

here--tell me if I'm wrong-the "ethics officer" title, 1 0 A. About a year, I guess. I'm guessing, about a but there was an ethics officer at Narconon, right? 11 year.

A. Yes. 12 Q. What other-- you mentioned that there were Q. And who was the ethics officer when you were 13 other individuals who held the position of ethics ~

there? 14 officer at Narconon of Georgia. Who else was ethics i A. It was held by different people at times. 15 officer while you were there? ~ Q. Okay. Was Larry Chorvas tl1e ethics officer at 16 A. Well, the- when I say "held," I mean 1!

some point in time? 17 sometimes filled that capacity. ~ A. Yes. 1 B Q. I understand. ~ Q. And I understand he's passed away? 19 A. Okay. ~ A. Uh-huh (affliillative). 2 0 Q. That makes sense. ~ Q. Do you know the circumstances, how he died? 21 A. Mm·ia, Larry- Larry, and-- and when I ve1y I A. (Witness nods head affirmatively.) 2 2 first got there, I did some ethics cycles. ~ Q. And, I'm sony, if you -- if you want to take 2 3 Q. And ymu· training-- rm --I'm sorry, were '

a break... 2 4 you finished? Was there anyone else that you remember ~ A. Excuse me. 2 5 filling that position? ~

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A. I think Abby. And these- this is like from 1 time to time, you know, if somebody was needed to do 2 something. I - I would be guessing at anybody else. 3 I -yeah. Mary. 4

Q. Mary? What about Allison Riepe? Do you 5 remember Allison? 6

A. Yes, and Allison. Yes. 7 Q. So I'm just trying to understand; were you-- 8

were you all qualified to act as the ethics officer or 9 fill in for the ethics officer? Or -- all the people 1 0 you just named. 11

A. Yes. 1 2 Q. Okay. And were you qualified because of your 1 3

training with the Church of Scientology? 14 A. Ifyou have done-- there's-- I mean, you're 15

doing -you're basically handling them on the same work 1 6 that they're doing on their course work. So, I mean, I 17 have done that cmtrse. I can't say for anybody else. 18 I- yeah. 1 9

Q. Okay. When you say "that course," the --the 2 0 ethics course? 21

A. I have done the nonsecular version of the 2 2 course that they were working on, yes. A version of 2 3 that course. 2 4

Q. When you say "thai course " what do you mean? 2 5

Pag e 31

A. There's a - I -- a clac;s that talks - 1

teaches personal values and integrity. 2

Q. Right. 3 A. Okay. I have done a class that has similar 4

information. 5 Q. Through the church? 6

A. Yes. 7

Q. Okay. Personal values and integrity was - is 8 a course that the students take, right? 9

A. I don't know; I don't remember the exact name 10 of their course. Yes. 11

Q. But it's something similar? 12 A. It's bas-- yes, it talks about values and 13

integrity, yes. 14 Q. Okay. And because you had -- you had done 15

that course through the Church of Scientology, you were 16 qualified to fill in as the ethics officer? 17

A. Yes. 18 Q. Back to the - Plaintiffs' Exhibit I real 19

quickly. There's a-- under "Pur-0-Cleanse" there's - 20 . it lists two registered nurses and an LPN. Do you know 21 those individuals listed? 22

MS. WHITLOCK: Object to the form. I 23 don't think they're listed under 24 "Pur -0-Cleanse." 25

Page 32 J

~ BYMS. FRANKLIN: Q. I'm sorry, besides "Pur-0-Cieanse." Be -

beside the block for "Pur-0-Cleanse.'' A Can you repeat the question? Q. Sure. Do you know- and I'll rephrase it

There's two individuals, Linda Hall and Lany- excuse me, Mary Lou Schmidt, under "Registered Nurse"; do you know those individuals?

A. Yes. Q. Who are they? A They were the nurses. Q. For-- for Pur-0-Cleanse? A. I don't know. Q. Did-- was it your understanding thftt they

worked for Narconon of Georgia? A. I don't have an understanding of that,

actually. I don't know how that works. Q. Did -- okay. Did you see them a1 the Narconon

facility? A In the capacity of a registered nurse? Q. Or just did you ever see them at the Narconon

facility? A. I never saw Mary L<lu, I saw Linda. Q. Okay. Was Mazy Lou-- did you see her at the

Pur-0-Cleanse or the sauna program?

Page 33

A I think I have seen her there before.

I

Q. Okay. Well, how else would you know Maiy Lou? . I Let me take that back. Do you know her from ;

church? :l

A Yes. I Q. Okay. Do you know Linda Hall from church? i A. Yes. ~· Q. Now, under the "LPNs" there's Danielle

~ Madock- Madlock and Veronica? ~

A. Yes. l Q. Do you !mow them? ~ A. Yes. ~

Q. Do you know them from church? I A. No. ~. Q. Was it your understanding that they worked for ~

Narconon of Georgia? ~ A Yes. ~ Q. Is - is that how you know them? ~ A. Yes. ~ Q. And what did they do, to your knowledge? ! A They were there at the progr --while the ~.

sauna program was nmning. ~ Q. Okay. They were at the salllla, but did they ~

also come to the -- well, let me back up. The salUla is at a separate -- or, it was at a separate facility than

9 (Pages 30 to 33)



Desmond, et al . v. Nar conon, et a 1. Tr acey E. Reynolds (Stepler) - 11/18/2011

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the Narconon of Georgia facility; is that right? A. Yes. Q. And so the Mad locks -- is that how you say -

is that their name? A. Yeah. That's what it looks like. I don't ...

Yeah. Q. Did they typically stay over at the sauna

program, or were they over at the Narconon facility? A. At the sauna program. Q. The next box over to the right I asked you

about Martin Cohen; what about Holly Cohen, do you know her?

Yes. How do you know her?

A. Q. A. They used to run Pur-0-Cleanse. The sauna

program. Q. Did you ever see them at the Narconon of

Georgia facility? A. Yes. Q. All right. What did they do there? A. I don't know. I- I just saw them. Q. And I may have asked you this earlier; did you

know them from church? A. No. Q. All right.

Page 35

A. Can I go back? Q. Sure. Any-- anytime you--A They -- I think they were there for a meeting. Q. Okay. A I- you know. Not-- they weren't working

tbere, but they were - they would meet there. Q. On more than one occasion? Or do you remember

one specific meeting? A. On more than one. Q. Were they there for regular meetings? A. I don't know what the meetings were about; I

know they were there to see somebody. They were there to see Mary.

Q. Okay. All right, let's talk a little bit about

Patrick Desmond. You knew Patrick, right? Or did you? A. No -- I know-- yes, I know-- rd seen him

before, and maybe spoke with him briefly. Q. Okay. Do you remember whether you were acting

as the intake coordinator when Patrick's fumily first called Narconon?

A. Yes. Q. You were acting as the intake coordinator? A. Yeah. The person who they first contact on

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Q. And do you specifically remember them ~ contacting you? ~

~ A. Yes. ~ Q. What do yfiou remember about that? Let me back ~

up. Who- who rrst contacted you? ~· A. I don't remember.

~ Q. What do you remember about the :first contact ~ ~ that the Desmond family had with you? ~

A. I remember receiving a call from them and them ~ asking some questions. I don't really remember what the J questions were. t

Q. You said you don't "really" remember. What do you remember about the questions?

A. I don't remember anything specifically. Q. Okay. Do you believe they asked about the

program? A. Yes. Q. And do you remember what you told them? A. No. Q. Do you remember whether they indicated to you

that Patrick was part of the drug court program in Florida?

A. I do remember them saying that. Q. What else do you remember about that? A. I remember them- I -- and I don't even know

Page 37 ~ ~

which parent. I-- it was Mrs. Desmond. -- being J.

concerned that he wouldn't be able to come to the program here because he had been assigned to drug court. ~-·.

Q. Okay. What else did she tell you about the clntg court? Well, did she tell you about any of the ~

drug court requirements? i A. No; not that I-- well, I-- not that I ~

remember. i Q. Okay. Did she ask you-- do you remember ~

whether she asked you whether Narconon of Georgia was an ~ ~.~ inpatient facility? 1~

A. No. d Q. No, she didn't ask you, or no, you don't ;

remember? ~.~ A. I don't know either way. I don't remember. i Q. Do you remember whether she told you that 1

Patrick was ordered to a minimwn six-month drug ~~ rehabilitation program? :

A. I don't remember talking about that. ~ ~ Q. Was there any -- is there anything else you ~

remember about that first conversation? With ~ Mrs. Desmond. -~

A. Not specifically, no. } Q. Generally? ~

the phone? Yes. A. You know, when I have vague impressions ofthe ! • . ~~~ ................ '¢''P"t~~~~"SS.:.;~~~~- • ~ ... .-.; ·'!'!.;"---·~-·,,....., ~··'-<-..f*'.oa<'"":··-... .... - ,..., -;,;;w~

1 0 (Pages 34 t o 3 7 )

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Page 38

conversation, but I would completely be guessing if I 1 said, "She said this," or "I said this" or "She said 2 this." Ifs like --it's like when-- something you 3 come away from a conversation with. I got that be was 4 not going to be able to come to the program at one point 5 from her. I vaguely remember her asking me to contact 6 someone at drug court. Other than that, I -- I don't -- 7 I don't recall. B

Q. Okay. Did you contact someone at drug comt? 9 A I think I attempted to, and I could not reach 1 0

anybody there. 11 Q. Allright. 12

(Thereupon, marked for identification 13 purposes, Plaintiffs' Exhibit No.2.) 14

BYMS. FRANKLIN: 15 Q. I'm going to hand you what I'm marking as 16

Exhibit 2. 1 7 MS. FRANKLIN: There's a copy. I'll 18

just circulate it to -- 1 9 MS. WHITLOCK: Ob. 20 MS. FRAl'H<LIN: --opposing counsel. So 21

they've seen it. 2 2 BYMS.FRANKLIN: 23

Q. Have you see11 this docmnent, Ms. Stepler? 2 4 A. No. 25

Page 39

Q. Okay. 1 A Well, I did-- yes. I saw this yesterday. 2 Q. Okay. When you were preparing for your 3

deposition? 4 A Yes. 5 Q. When you saw it yesterday, do you believe you 6

had seen it prior to that? 7 A . No. 8 Q. All right Does it appear to be - well, do 9

you know - do you recognize Mru.y Rieser's handwriting? 1 0 A There are certain parts here that I could 11

recognize. I 1p.ean, the M looks like how she writes her 12 M. 13

Q. Okay. And-- and I'm just asking-- it says 14 "Sent from Mazy Rieser," right? 1 5

A. Yes. 16 Q. Okay. And at the bottom it says -- well, it 17

says, "You called Tracey --" - it's to Lisa Mooty; do 1 8 you remember Lisa Mooty? 19

A. No. 20 Q. And it says, "You called Tracey --" -- I don't 21

know what it says there, "but you--" -- 2 2 MS. WFITILOCK: "Earlier"? 2 3

BYMS.FRANKLIN: 24 Q. --"spoke to me this-"-- Yes, "-earlier, 2 5

Page 40 ~ ~

but you spoke to me this time." So do you remember ! whether Mary spoke to the drug comt after you did? ~

A. I don't remember speaking to the drug comt. j Q. Okay. You don't remember speaking to anyone j

from the drug comt at all? a A No. ~ Q. All right !

(Thereupon, marked for identification ~ purposes, Plaintiffs' Exhibit No. 3.) ~

BYQ~i!~~~~d you what l'm marking as ~ Plaintiffs' Exhibit 3. If you'll take a chance to read t through that document ~

A. (Witness complies with request of counsel.) ~ Q. Have you had a chance to review that document? ~

A. Not completely. i Q. Okay. I'm sorry, take your time. l A. Okay. ~

~ Q. Okay. This document, which is Plaintiffs' -Exhibit 3, is- appears to be a letter from you to I Patrick's attorney; is that con·ect? ~

A Yes, it appears that way. j Q. Do you remember writing this letter? ~ A. I don't. ~

Q. Do you have any reason to believe that you did ~

not write this letter? A. Some of the words aren't what I would -how I

would speak. And ies not signed by me, but -I don't-- I - and I just don't remember doing it.

Q. Okay. The fast sentence says, "I spoke with Mr. Patrick Desmond, and his son Patrick as well." Do you remember speaking- you told me earlier about speaking with Mrs. Desmond,-Colleen--and do you remember spe.aking witl1 Mr. Desmond?

A. Yes. Q. Tell me about that conversation. A. It was at the same time. Like one person got

on the phone after the other person. Q. Okay. So it wasn't a different telephone

call? A The time I remember was right after. The -

the time -the very frrst time they called. Q. Okay. So you spoke with Mr. Desmond and

Mrs. Desmond? A. Yes. Q. All right. And it says that you spoke with

his -- Patrick Desmond. Their son. A. I don't remember speaking to him Q. Okay. You don't ever remember speaking to him

before he enrolled? Before he got to Georgia?

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Page Page 42

1 A. I may have spoken to him-- I may have spoken 1 only heard like a advertisement or something for it; I 2 to him. I don't remember -I have a vague memory, but 2 don't know anything about it. 3 I don't remember the conversation. 3 Q. Okay. So you don't know whether that's an 4 Q. What do you remember about your conversation 4 inpatient program? A residential facility? 5 with his father? 5 A. Huh-uh (negative). I don't even know ifl'm 6 A. I just re -- I remember him. I remember him 6 confusing Bridge with Bridges. I don't - I've never --7 being very professional, how he sounded on the phone. I 7 I don't know if it's just Bridge; I've never heard of

44 ~

t ~

l B don't-- I --he asked questions, but I couldn't really 8 that program. 9 tell you what he asked specifically. He asked me to 9 Q. Okay. And then you say, "I know that a I

1 0 send him - if I could send him information on tbe 1 0 decision needs to be made by the 17th of September." ~ 11 program. 11 Presumably that's something that the Desmonds told you, ~ 12 Q. Okay. And did you do that? 12 correct? 1 1 3 A. I don't remember doing it, but I'm sure I did. 13 A. If-- it must have been, because I don't -- I 11 14 Q. Okay. What type of infonnation would you 14 mean, I don't have any significance on that date. j 15 typically send if someone asks you that question? 15 Q. Okay. And then you say that you've "attempted ~,:, 16 A. There's a packet that I would have E-mailed, I 1 6 to contact Ms. Mooty but- but have been unsuccessful." 1 7 think. Like I said, I don't specifically remember 17 That's consistent with what you told us earlier, that 18 £-mailing it, but he asked me for it, and that's what I 1 8 you believe you contacted Ms. Mooty? I 19 would typically send off. 1 9 A. I don't -- I don't actually remember j 2 0 Q. Okay. Do you remember whether he asked-- 2 0 contacting Ms. Mooty. I don't remember speaking to a ~ 2 1 strike that 2 1 Ms. Mooty. I -- honestly, on that, I couldn't say ~

2 2 Do you remember whether Mr. Desmond, Patrick's 2 2 anything for sure, because I have no recollection of ~ 23 father, told you about any of the conditions of the dmg 23 :M.s. Mooty. The only reason I even put ittogetheris ! 2 4 coutt in Florida? 2 4 this letter. I don't --I don't know. ~

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Page 43 Page 45 i Q. All right. The next sentence says, "I would 1 it's on Narconon of Georgia letterhead, - ~

like to solicit your assistance in working with Lisa 2 A. Uh-huh (affinnative). ~

Mooty, the drug cmut director. 11 Presumably either 3 Q. -- correct? How would --how did you ~ Patrick or his mom and dad told you about Mrs. Mooty. 4 determine what letterhead to use? In other words, when Would that make sense? 5 you-- when you wrote this letter, where did you get the

A. It does make sense. 6 letterhead from? Q. · Okay. And do you know how you got Mr. Berry's 7 A. That's -- I don't remember writing this

name and address? 8 letter. If-- this looks like a typical letter that A. I don't remember exactly. I think I got it 9 Narconon would send out. And these letters are on the

from Mrs. Desmond. 1 0 computer. Q. Okay. Did she ask you, or did any of them ask 11 Q. Okay.

you, to contact Mr. Berry? 1 2 A. Different computer screens might have this A. I - that's - I don't remember them asking me 13 particular letter in the file. Like in -- in a file.

to do that. I don't remember specifically. 1 4 Q. As an intake person or intake coordinator, did Q. Okay. The next sentence says, "I would like 15 you -- did you have a certain desk where you would sit

her -"-I think that's referring to Lisa Mooty-" --to 16 at and answer phone calls? allow Patrick to attend the Narconon of Georgia -- 1 7 A. Yes. Narconon program in Georgia as a private alternative to 18 Q. Okay. And did-- was there a computer at that the state program, Bridge. 11 Did they give you any 1 9 desk? infonnation about Bridge? 2 0 A. Yes.

A. No. 21 Q. Do you know ·whether there was saved letterhead Q. Do you know anything-- or, did you know 2 2 on that computer that you would use to write letters?

anything about Bridge? 2 3 A. Yes. A. I don't know anything about -- I thought even 2 4 Q. Do you know whether there were different ~

bridged it -- I thought maybe it was Bridges, but I've 2 5 versions of letterhead on that computer? ~ ~-~'"==~· .oz; .. .;.,...,;;;;.<;;;""""=·-p.iil"<;;;;,~·-~- ~i01.1·5.:""""":;l\i· f:ii.·~o;;;· =!;;i' ~·-==~·~,...,~~;;;;~.?";;z.~.·.;;:;.,:;::;~=::;;-.,5:,.,·;;:;;:n·Si·~'Zrh~,..;;;;._,;;::,_~;~~~== ... ~;:;;-,;:;:..,;~· -=;;;<· :Ei~al!;;·' ·~;:;;-.::;;;;;;;.;-""":;;o.~;;;;=;;;::-;;;; ... ;:;: •. -::;;m<::;·~M.:;;-.Z1 .. ..:.'ll>~~;;::;·;;;: .. ;;;~;'li;i:ll;o.;::·.:::;;-.~=:;;"s;:;:~~""...,...::ie-·~rl

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1 A. I can't say for sure. 1 Q. Now --just stay on the second page. A couple ~ 2 Q. Okay. Do you-- do you remember there being 2 of paragraphs up, the -- you say, "The initial Narconon

I 3 different versions? 3 program length is six months." Is that true? 4 A. No. I remember there being different saved 4 "Depending on the individual." 5 letters in the computer. 5 A. It usually says "three to six monfus." ' 6 Q. For different students or potential students? 6 Sometimes it can be longer than six months, even. I 7 A. Right. 7 Q. Okay. Do you know why this letter says "six I 8 Q. Okay. Would you typically-- if you received 8 months" rather than "three to six months"? 9 a-- a call, would jt be your job as intake coorrunator 9 A. No. i 10 to send out some smt of responsive letter? And I 10 Q. All right The next paragraph-excuse me--you

11 understand you don't remember this one specifically, but 11 say, ''Narconon of Georgia was oliginally founded as an I 12 just generally. 1 2 alternative to incarceration. We write reports to I 13 A. It could be; I would do it in a pinch. 13 probation officers and judges as requested." ' ,, 14 Sometimes-- it wouldn't necessarily be my job to do 14 Did you personally ever write reports to ~

15 this. Sometimes Mary would do it, or sometimes Allison 15 probation officers and judges? 16 would do it as the legal coordinator, kind ofbolcling 1 6 A. No. 17 that position. But, yeah, I would -- I would do it 17 Q. Do you know whether Narconon -- anyone at ~

18 sometimes. 18 Narconon did? ~ 19 · Q. Did you ever have to make a de-- a choice 19 A. Yes. I think Allison would have done that. i

20 about what letterhead to use if you were sending out a 20 Q. And you mentioned earlier that in a pinch you ~ 2 1 letter to a potential student or their agent, their 21 would fill in possibly for Allison or Mary. Did you ~ 22 lawyer? 22 e-ver fill in for them in writing reports to probation 1 23 A. A choice. I don't understand the question. 2 3 officers or judges? ~ 24 Q. Okay. Was there a choice of letterhead to use 24 A. Only I -- I don't remember specifically, but ·m 25 saved on any of your computers? 2 5 if it was a letter like this, that had to be sent off ~

Page 47 Page 49 1

1 A. TI1ere were different students' letters in 1 yeah, I would -- in - I would do that kind of thing. 2 there, so usually what I would do is just go in there 2 But not like a -- not a report. t 3 and type over, so if it pulled up an old letterhead or 3 Q. So-- I 4 it -- it could pull up -- it could possibly pull up 4 A. Not a progress report.

I 5 something different than tbjs, because of how the 5 Q. -- sort of a form letter? 6 letters were saved in there. I would just go in there 6 A. Yes. Not a progress report ~ 7 and type over-- over a previous letter. 7 Q. Okay. Now, as a case supervisor, you ~ 8 Q. This number, 770-379-0208, do you know-- 8 wouldn't -- you would not -- that would not be one of ~ 9 A. Uh-huh (a.ffumative). 9 your duties, is to write a progress report? I 1 0 Q. - what phone number that js? 1 0 A. No. Not -- well, not to a probation officer. !!

1 1 A. That's Narconon's phone number. 11 Q. Okay. Did you ever have any contact with 12 Q. Is that the main line? 12 probation officers, or judges, or drug court 13 A. Yes. 13 administrators? ! 14 Q. Did you also individually have like direct 14 A. Yes. I 15 dials? 1 5 Q, Tell me about that. ~ 16 A. I had my own cell phone number. My personal 16 A. I - the memory I have is of one time -- I 17 cell phone number. 17 ' MS. WHITLOCK: I'm sorry, let me just 18 Q. Okay. Is that the number here at the end of 18 inte1Tupt and remind you that you're not 19 the letter, on the last-- the last paragraph, 19 supposed to identify any other students. ~

20 678~557-2055? 20 THE WI1NESS: Yes, I know. 21 A. Yes. 2 1 MS. WIDTLOCK: Okay. 22 Q. So tlris letter asks Mr. Berry, Patrick's 22 THE WI1NESS: The-- the-- is ! 23 lawyer in Florida, to call you directly on your cell 23 contacting on behalf of somebody who had just 24 phone? 24 arrived, that -- we had to let them know I 25 A. Yes. 25 immediately that they were in the program. :J

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BY MS. FRANKLlN: 1 Q. Okay. And did you write a letter, or did you 2

make a phone call? 3 A. I think I called and then sent. Got the 4

inf01mation from -- for where we needed to send the -- 5 send the report. 6

Q. The next paragraph, you say, "Narconon has a 7 76 percent success rate." Where does -- is that true? 8

A. That's the success rate 1 -- I was told. 9 Q. ByMary? 10 A. I don't know. 11 Q. When you were working there, was Narconon of 12

Georgia a residential rehab facility? 13 A. Yes. 14 Q.- Okay. Did it provide inpatient services? 15 A. No. 16 Q. Okay. Do you consider it to be outpatient? 1 7 A. Yes. 18

(Thereupon, marked for identification 1 9 purposes, Plaintiffs' Exhibit No. 4.) 2 0

BY MS. FRANKLIN'": 21 Q. All right. I'm going to hand you what I'm 2 2

marking as Plaintiffs' Exhibit 4. Take a look at that, 2 3 Ms. Stepler, and see if you recognize that document. 2 4

A. Okay. 25

Page 51

MS. WHI1LOCK: Before you answer any 1 questions, I'm looking at what you've marked 2 as Exhibit 4, and it appears that there is 3 another student's name that. was not blacked 4 out; that was my error. Can we black that 5 out before we - 6

MS.FRANKLIN: Yes. 7 MS. WHITLOCK: -- attach it to the 8

exhibit -- the -- 9 MS. FRANKLIN: Yes. 1 o MS. WHITLOCK: -- deposition? 11

BYMS.FRANKLIN: 12 Q. Ms. Stepler, is that your signature at the 13

bottom of the flrst page of Exhibit 4? 14 A.. Yes. 15 Q. And this is a Narconon of Georgia orientation 16

checklist. Is that your handwriting at the top? 1 7 A. No. 18 Q. Do you know whose handwriting that is? 19 A. No. 20 Q. All right. Under number 4 there's a-- it 2 1

says "Name of buddy," which is going-- is redacted, or 2 2 will be l'edacted. Who -- were -- presumably buddies 2 3 were assigned to new patients, or new students, correct? 2 4

A. Yes. 25

Page 52~

Q. How did youwere-- how did you deteliDine ~ who would be a new patient's, or a new student's, buddy? i

A. I didn't. I Q. Whodid? J A. The - I - I suppose -- I would - I suppose ~

the orientation supervisor would do that. j Q. Okay. Do you know who Patric-k's orientation ~

supervisor was? i A. I don't remember. ~ Q. All right And let me back up just-- just a ,

minute. Did you have any other conversations with i.-.-_

anyone prior to Patrick enrolling in the program, I besides what you've just told me about? ~--

A. I don't understand the question. t

Q. Okay. We just talked about your conversation ~-with Patrick's mom and dad on the phone, right? ~

A. Uh-huh(affirmative). ~ Q. And you said you didn't remember talking to i

the dmg court administrator, right? ~

~: ~!~n'J~n't remember talking to Patrick's 1_11

probation officer? ~ A. No. j Q. Did you talk to Mr. Berry? ~-: A I don't remember talking to him. ~

Page 53 l I

Q. Did you have any other con-- conversations with Patrick's parents prior to his arrival? Or with Patrick?

A. No.

~ ~

I ~ Q. Did you have any conversations with anyone ~

else before his anival about Patrick's enrollment? ~

A. Yes. I Q. Who? 'I

il A. Mruy. ' Q. What-- what did you discuss with Mary? ~ A. That he was going to be arriving. That-- l

that the -- we had this person who wanted to come into : the program. ~

Q. Okay. Well, how did you know he was going to ~ be arriving? 'Cause in the letter you wrote Mr. Beny, ~ you said you're -- you were working to -- you were i soliciting his assistance to have -- allow Patrick to ~

attend the program. I A. Yeah. I misworded that. A possible person. ~

~ Q. Okay. Any other- what else did you talk ~

about with Ms. (Pronouncing) Riser? Rieser. li A. I don't remember anything else specifically. Q. Any other conversations you had with anybody

prior to his arrival? ~ A. No. g

14 (Pages 50 t o 53)

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Desmond, et al . v. Na~conon , et a l . Tracey E. Reynolds (Stepler) - 11/18/2011

Page 5<1 Page 56~ ·*

1 Q. Okay. Did you meet Patrick when he arrived? 1 look at number 11; it says, 11The student wat -- watched 2 A No. 2 educational videos betvveen light communication 3 Q. When's the first time you met him? 3 exercises." What is "light communication exercises"? 4 A. I don't remember. 4 A. It could be walking arOlmd, going for a walk,

'

5 ' Q. Alhight. So back to Exhibit 4. This lists 5 you know, getting outside, looking at things, touching 6 a number of things, 1he orientation checklist. Did you 6 different things. 7 check all of these off? 7 Q. Okay. And the orientation supervisor would be j 8 A. No. B in charge of conducting those light communi -- 1 9 Q. Do you know who did? 9 communication exercises?

10 A. No. 10 A. Yes. I 11 Q. As -- as Patrick's case supervisor, was this 11 Q. Okay. Now, number 17 says, "Sendstudent to i 12 generally -- strike that. 12 the course supervisor, who must ensw-e that the full 13 As a case supervisor, would you generally do 13 intake is complete." So :iny understanding is that once 1 4 this orientation checklist? 14 Patrick does his orientation, you look at the file to 15 A. No. 15 make sure evet}'thlng is okay, correct? 16 Q. Who would? 16 A. Can you say that again? 17 A. The orientation supervisor. 17 Q. Sure. Based on what you've just told me, -- ~

j 1 8 Q. Okay. And you would sign off based on their 18 . A. Uh-huh (affirmative). i 19 recommendation? 19 Q. - is it accurate to say that after Patrick I 20 A. No. 20 perfonns these orientation-- well, performs the things 21 Q. Okay. Well, how would you decide the "student 21 listed under the orientation checklist, then you would 22 is okay for Narconon program"? Which is where your 22 sign off on his intake; does that make sense? 23 signature is. 23 A. Right, yes. -- I 24 A. There are other forms. 24 Q. Okay. I 25 o. That you would consider? 25 A. - Uh-huh(affmnative).

Page 55 Page 57

1 A. Uh-huh (affirmative). 1 Q. When's the first time you met Patrick? 2 Q. Okay. What forms would you consider? 2 A. I don't remember. 3 A. Well, there's a preadmission assessment 3 Q. Do you remember Patrick specifically? 4 There's --there would be some other information in the 4 A. Yes. 5 folder. 5 Q. Were you his case supervisor throughout the

I 6 Q. Would you complete the preadmission 6 program? 7 assessment? 7 A. I don't know. 8 A. No. 8 Q. Okay. rm going to hand you what rm marking l 9 Q. Who would do that? 9 as Exhibit 5.

l 1 0 A. I'm not sure. 1 0 (Thereupon, marked for identification 11 Q. Would you review it? Or, did you review 11 purposes, Plaintiffs' Exhibit No. 5.) 12 Patrick's preadmission assessment? 12 BYMS. FRANKLIN: 13 A. I don't remember, but I can assume ifl signed 13 Q. Take a look at that, please, Ms ... 14 this off I did. 14 A. Uh-huh (affumative). Okay. ~ 15 Q. Okay. Who was the director -- and I'm looking 15 Q. Is this your handwriting on Page 1 of .. 16 at the second page now, under paragraph 8. It says, 16 Exhibit 5? I

17 "The student is introduced to the director of technical 17 A. No. 18 services." Who was the director -- director of 18 Q. Do you recognize that handwriting? 19 technical services when you were there? 19 A. No. Not particularly. 20 A. I think it was Abby Bailey who held that. I 20 Q. Okay. Have you ever seen this document

~ 21 think. 21 before? 22 Q. And-- and the "technical services," was that 22 A. I don't remember seeing this specifically. I 23 the -- sort of the course material? 23 Q. All right. In the middle of the page it has 24 A. Yes. 24 in sort of capital -- not "sort of, 11 but in capital 25 Q. And then under -- a couple places, but we can 25 letters, "No worries." -- ~

j .. ~.:s~~~~.i.'~~~lll:.-..!;.'~\t:~.,.,...~~·~·;:w;:~.:;i;.:t.t.·~r.:tt~.:.;~·· ·· .. ··~;;;.o . ..- ' ~·'1-~r.:::::.;..-t:"'~'liOt.'"o."">''> "SeN" ·...,. '"-'J'J""~·'O:~~~"-·~~~...,~~·••;v~~~·;.~t'...:U'1.0.~~l..'".:.-t.>""l"~~r,;:.c;~~!:...·J.l>.;:~'k-·o~l:.lr.W::;:;~

15 (Pages 54 to 57)

Q&A Reporting Services, Inc . [email protected] * * 404-233.3300


Desmond, e t a l. v. Narconon, et al . Tracey E. Reynolds (Stepler) - 11/18/2011

1 2 3 4 5 6 7 8 9

10 11 12 13 14 15 1 6 17 18 19 20 21 22 23 24 25

1 2 3 4 5 6 7 8 9

10 11 12 13 14 15 1 6 17 18 19 20 2 1 22 23 24 25

Page 58

A. Uh-huh (affirmative). 1 Q. - What is that? 2

MS. \VHI1LOCK: Object to the form. 3 BY MS. FR..Al\TKLIN: 4

Q. To --to your knowledge. 5 A. I don't know specifically what's in it. 6 Q. Is it a sort of a vitamin regime, "No 7

won·ies"? 8 A. I --yeah; I think it's some kind of 9

natural - natural thing. 1 0 Q. Okay. If you'll look at the second page of 11

this, of Exhibit 5, is that your handwriting? 12 A. No. 1 3 Q. I may have asked you this earlie1~ but were 14

you ever told that Patlick was required to stay at 15 Narconon for six months, minimum? 16

A. Not that I remember, no. 1 7 Q. All right. What role did you have in 18

Patrick's treatment? I understand you were his case 19 supervisor, but I need to know what you smt of did on a 2 0 day-to-day basis. 21

A. In regards to Patrick, I don't remember if I 2 2 was his case supervisor all the time. I worked -- 2 3 during this time, I had worked at home for a lot of that 2 4 time. 25

Page 59

Q. Okay. You do remember being his case 1 supervisor at some point, right? 2

A. No. 3 Q. Okay. So you don't remember reviewing any of 4

Patrkk's work? 5 A. I must have. I - but I don't remember. No. 6 Q. Okay. Do you-- did students that were going 7

through the Narconon program, did they have something 8 called a r.vin? 9

A. Yes. 10 Q. Who does that mean? 11 A. It's the person that they're working on the 12

course -- a particular course with. 13 Q. Is that the same as their buddy? 14 A. No. 15 Q. All right. Does a student have a twin 16

throughout the whole program? 17 A. No. ' 18 Q. How long do you have a twin? Or, a student. 19 A. There's a certain book where they have a twin. 2 0

And that is a- it's in here. The "Communication and 21 Perception Course." They have a twin on that course. 2 2 And they might - it vrould be the action of twinning up, 2 3 meaning working with somebody, on other cotu-ses. 2 4

Q. Okay. How much involvement-- you just told . 2 5

Page 60 ~

me that you weren't sure whether you were actually - ~ acted as Patrick's case supervisor, right? i

A. Uh-huh (affhmative). m Q. How much involvement did you have on a I

day-to-day basis with Patrick? I · A. None. ~ Q. None. Okay. How many times did you see '

Patrick when he was enrolled 1:here? ~ A. I couldn't say. Maybe three. · ~ Q. Was that just sort of around the facility, I

just in passing? I A. Yes. 3 Q. Any other -- any specific time that you !

remember talking or seeing Patrick? ~~ A. Yes. Q. Tell me about that. • A. I saw him in the orientation area one tjme and ~

we said hello. And I saw him at the hospital. And I _I know I met him --I said hello to him, like, "Hi, I'm ~ Tracey," one time, I don't know how long after he I arrived. Some ki - short time after he arrived, maybe ~ within a week or two. ~

Q. Okay. Did you find him to. be pleasant? ~ A. Yes. :<

Q. Did you ever hear of or know about any ~

complaints from other students or staff members about Patrick?

A. No. Q. Is there a housing component to Narccnon? A. No. Q. All right. Where did the students live when

you worked there? A. There's a separate housing; it's a housing

company called Delgado Development Q. That was owned and run by Maria and Don

Delgado? A. Yes. Q. All right. Did you -- did all the students

stay at Delgado Development? A. I don't know. Q. Do you know anywhere else that students

stayed? A. Hotel. Home, sometimes. Q. Okay. How many students do you remember

staying at a hotel during your approximate three years there?

A Students that I specifically remember,--this is an approximate--five or six.

Q. Okay. Did you ever visit Delgado Development Recovery Residence?

16 (Pages 58 t o 61)



Desmond, et al . v . Na r conon, et al. Tracey E. Reynolds (Stepler) - 11/ 19/201 1

Page 62 Page 64 ll ~

1 A. Yes. 1 Rieser would pay Delgado, right? i 2 Q. How often? 2 MS. WIDTLOCK: Object to the form.

. . ~

3 A. Not very often at all. 3 THE WI1NESS: I -- I don't recall that ! 4 Q. Once a week? 4 at all. ~ 5 A. No. 5 BY MS. FRANKL1N: ~ 6 Q. Once a month? 6 Q. Okay.

' 7 A. No. Occasionally, very occasionally. 7 A. I know that I had accepted a check written out 8 Q. Okay. Would you-- during your time at 8 sometimes to housing, and I would give it to them. ~ 9 Narconon, do you think you would have visited more than 9 Q. To Delgado? i

10 ten times? 10 A. Yeah. Or-- well, there was different ~.

11 A. No. 11 housings during different periods of times. I ~ 12 Q. Did you provide transportation or help provide 12 Q. Do - do you remember whether Mary Rieser ever ~

13 transportation between Delgado Development and Narconon? 13 wrote a check from Narconon to the Church of I 14 A. There was a short time, maybe a few days in a 1 4 Scientology? ~

I 15 row, that some -- that they needed someone to drive, and 1 5 A. I don't know. 16 I was -- I lived fairly close. So maybe three days I 16 Q. Do -- do you have any recollection one way or ~

~ 17 drove maybe three girls in to the sauna program. Yeah. 17 the other? ~ 18 Q. Okay. That's all you remember? 18 A. No. ~ 1 9 A. That's all I recall, uh-huh (affirmative). 19 Q. While you were working for Narconon, did any ~

~ 20 Q. Do you -- are you aware of any rules that were 20 students ever graduate and then become staff at I 21 in place by Delgado Development for the students who 21 Narconon? And rmnot asking for names of people. 22 lived there? 22 A. Okay. Yes. I

l!

23 A. rm sure there are rules; I don't know them 23 Q. Did -- do you remember whether Patrick did ! ~ 24 specifically, no. 24 that? ~ ;;

25 Q. Okay. Did you ever see any written rules? 25 A. I don't-- not that I know of ~ ~

Page 63 Page ~ 65 ~

1 A I have a v~oue memory of Maria having the 1 Q. Do you remember when Patrick graduated? ~ 2 students sign something. 2 A. No. i 3 Q. Is that part of their file? At Narconon? 3 Q. Do you remember whether f01mer students who 4 A I don't think so. 4 had graduated would become staff at Delgado Development? ~

~ 5 Q. Okay. When-- why would you have seen those 5 A. Ithink so, yes. Yes. ~ 6 rules, then? 6 Q. I'm sorry, I'm jumping around a little bit ~

~

7 A. Because sometimes Maria would come pick up a 7 here. Did you ever-- were you ever involved in paying ~

I B student after they checked in, if it was time - if it 8 the staff? Were you involved in the fmancial part of i 9 was during an hour where they would go straight, you 9 Nar -- Narconon? Payroll? ~ 1 0 know, after the intake, to housing, someone from housing 10 A. I wasn't involved in the payroll; I think -- I ~

~

11 would usually come and meet the student. And the -the 11 think one time the person who was able to do it was out. I 12 mem -- the -- the memory that I recall is her having 12 I knew that computer program., maybe printed off checks. 1

j

13 them sign something. 13 But it wouldn't-- it would have been an instance. i 14 Q. Okay. But you never - you never saw those 14 Q. Okay. 1

~ 15 rules? 15 A. It wasn't a part of my duties. ~ 1 6 A I don't remember seeing them specifically, no. 16 Q. Like QuickBooks? ~

17 Q. Okay. 17 A. I think it was QuickBooks, -- 1 18 A. Like reading over them? No. 1 8 Q. Okay. 19 Q. Would students pay their rent to Delgado 19 A. --yes. ~ 20 Development, or Narconon? 20 Q. And who was in charge of that generally? ~ 2 1 A. I don't know. I think it was both. I think 21 A. James Wagner at one time, and at another time I 22 it could -- like sometimes it was like a contra; we 22 I think TomDavis. ~

~

23 would accept it or ., and then pass it over. 23 Q. Anybody else you remember? I 24 Q. Okay. But sometimes students would write 24 A. It's just so long ago. No. ii

:i 25 their check direct1y to Narconon, and Nar- and Mary 25 Q. Do you remember whether Allison ruepe was ever ~

l ~~~~~- """1'"1-t"'"'l"::: ... £\""''96;8'¢"~'"' :;~~~~ •. - ... ;;., ~ .. .. -· ~•~ ,.. . .,., ..-. • .,. .... ,..w.-.,__.ee'i'ie·• ··· ·N.,. ........... ....u.:.~~...;c.o. _.,,..... ·- 'l

17 (Pages 62 to 65)



Desmond, et al. v . Narconon, e t al . Tracey E. Re ynolds · (Stepler} - 11/18/2011

Pag e 66

1 involved in payroll? 2 A. No. I don't rememb -- I don't think so. 3 Q. Were you friends with Allison? 4 A. Yes. 5 Q. Are you still friends with Allison? 6 A. On Facebook. 7 (Thereupon, marked for identification 8 purposes, Plaintiffs' Exhibit No. 6.) 9 BYMS. FRANKLIN:

10 Q. I'm handing you Exhibit 6. You can go ahead 11 and take a look at that. 12 A. Okay. 13 Q. You mentioned earlier that you don't remember 14 Patrick graduating. Do you remember when he 15 re-enrolled? 16 A. I - I remember hearing that he did. 17 Q. Okay. Were you involved in his re-enrollment? 18 A. No. 1.9 Q. All right. In this -- Plaintiffs' Exhibit 6; 20 have you ever seen this E-mail? 21 A. No. 22 Q. Okay. It appears to be an E-mail from Mark 23 O'Donnell, who rn represent to you was Patrick's 24 probation officer, and it says that "I just confirmed

1 2 3 4 5 6 7 8 9

10 11 12 13 14 15 16 17 1 8 19 20 21 22 23 24 25

Page

MS. Win1LOCK: Object to the form. BY MS. FRANKLIN:

Q. To your knowledge. A I -- can you be more spe.cific? Q. Well, do you know whether those course

materials relate to drug or alcohol rehabilitation or counseling?

A They're part of the Na.rconon drug rehabilitation program.

Q. Okay. How do they help people overcome their addictions, if they do?

.Y1S. WHITLOCK: Object to the form. 1HE WITNESS: I-- I feel like that's

I f

! ~

' I asking for my opinion. ~

BY MS. FRANKLIN: ! Q. Yeah. } A. It... ~ Q. You can-- ! A. Okay. ~

Q. -- give your opinion. ~ A. Okay. ~ Q. I understand it's just - ~ A. Okay. If a person is having difficulty in ~

life, usually they're having difficulty with something ~ ~

in particular. And that could be ethics, or it could be & ~~~~~~~~~~~~~~~~~~------~--~~~==~~~~~~~~~~~~~P~a~g~e~6_,9 ~

~

25 that he is there at Narconon with Tracy Settler." Pag e 67

1 2 3 4 5 6 7 8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 2£,

25 ~s..t.-•

That's not your name, -- 1

A. No. 2 Q. -- correct? Do you remember ever talking to 3

Mr. O'Donnell? 4 A. I don't remember that. I --I didn't do 5

Patrick's check-in. 6 Q. Do you remember who did? 7

A: No. 8 Q. Did you have any involvement with Patrick 9

after he re-enrolled? 10 A I - that was that conversation I saw him in 11

the back, roo - in orientation, and he said hello. 12 Q. Would-~ this is after he graduated and came 13

back? 14 A. Yes. 1 5

MS. WHTILOCK: Calvin, do you need that? 16 BY MS. FRANKLIN: 17

Q. We've talked a little bit about some of the 18 course matelial today, Ms. Stepler, and I think you 19 referenced Plaintiffs' Exhibit 3, which is the letter 20 that has your name on it. And it -- it outlines several 2 1 of the different courses. Right? 22

A. Uh-huh (affirmative). 23 Q. How did these courses relate to drug or 24

alcohol rehabil-~ rehabilitation or counseling? 25 ~~~~ex·'i' .,.,_,." ~-~""'"'~···"""~~..,., ..... s;,;.~~~~~..-,.:,_~-t

the fact that they have drugs in their body that, you know, is-- is making them crave drugs. It could be any number of things. So these cover a wide variety oflife problems and address those particular areas.

Q. Okay. And are they the - the -- the titles of the courses in Exhibit 3, are they the same titles as the courses that you mentioned that were similar as part

~

j ~ a ~ j j

' ~

of the Scientology technical training? ~ A Honestly, it's been so long since I did any of ~~

these courses that I couldn't tell you iftheyre the-I -- I dent think the"'re the exact same names. ~

J ~ Q. Are you still a member of the Church of ·~

Scientology? ~ A. Yes. Q. And do you still perform ~- you said that you

were an auditor when you were in Dallas; do you audit folks now?

A. I don't.

I

1 Q. Was there anE-Meter a1 the-- at Narconon? ll

A. Not that I know of, no. If there was, it was i for prob - it would have been for personal use; it was l never used - never ~-E-Meter was never used with the ~ students. ~

.i Q. Okay. But do you remember there being an ~

E-Me~~~:!'=~ a:,the Nar,~ . .. -=J 18 (Pages 66 to 69)



Desmond , et a l . v . Narconon , et a l .

Page 70

1 A. I don't. 1 2 Q. -- facility? 2 3 Do you remember anyone ever using an 3 4 E-Meter -- I understand you said that not with the 4 5 students, but ever using an E-Meter at the church? I 5 6 mean, at the Narconon facility? 6 7 A. I have a vague memory of Mary doing something 7 8 with a client- one of her-- a client. Not a-- not a B 9 Narconon person. In the next-door building. 9

1 0 Q. What was the next-door building? 1 0 1 1 A. It was an office. Just - it wasn't pa11 of 11 12 Narconon, it was just a spare office space. 12 13 Q. Okay. Who-did--didMaryrentthatspace? 13 14 A. I don't know. 14 15 Q. Okay. Well, did it have a-- did it have a 1 5 16 sign on it? 1 6 1 7 A. I don't-- I don't think so. 17 1 8 Q. All right. Tell me about your memory of Mary 18 19 using an E-Meter with a client 19 2 0 A See, I didn't even see her use theE-Meter. I 2 0 2 1 don't - I don't - I don't remember. 2 1 2 2 Q. All right. What do you know about the-- 2 2 2 3 about tl1is office space next door? 2 3 2 4. A . Nothing. 2 4 2 5 Q. All right. Mary had access to it? 2 5

Page 71

1 A Yes. 1 2 Q. During your entire three years when you worked 2 3 there? 3 4 A. I don't know. 4 5 Q. Did you ever go in it? 5 6 A. Yes. 6 7 Q. Who worked in that office? 7 8 A Noone. 8 9 Q. Was it just completely empty? 9

1 0 A. Yes; until a later time we took over that 1 0 11 space. I think -- I wasn't even worlcing there at the 11 12 time. 12 13 · Q. Narconon-- 13 14 A. They took over that space. 14 15 Q. Expanded? 15 16 A. Yes. 16 17 Q. Wereyouever- 17 1 8 A. Can I- 18 19 Q. Sure. 19 2 0 A. -- clarify the E-Meter tiring? 2 0 21 Q. Sure. 21 2 2 A. Okay. So the person that I saw come in, I 2 2 2 3 know that Mary has previously audited him. ·Which made 2 3 2 4 me think-- I just don't want -- I want to answer your 2 4 2 5 com-- questions as honestly as I can, but I don't 2 5

Tracey E . Reynolds (Stepler) - 11/18 /2011

Pa ge 72 ~

specifically remember seeing her take an E-Meter or I something. I just know that that person was a person ~ that she had previously audited. J

Q. Okay. Did Mary perform auditing in this t next-door office, to your knowledge? i

A. I think she had on occasion, yes. i Q. Did you ever do any auditing -- I A. No. I Q. -- next door? ~

MS. WIDTLOCK: I'm sorry, what was your I last question, Rebecca? ~

MS. FRANKLIN: ''Did you ever do any s

auditing next door?" MS. WHITLOCK: "Did you." "Did you." THE WITNESS: No.

BY MS. FRANKLIN: Q. Were you a member of the Sea Org? A. No. Q. All right You-- you mentioned that you

saw -well, how did you Jearn ofPatrick's death? A Through a phone call. Q. Who called you? A. A police officer. Q. And were you at home? A. Iwas.

Q. Did he call your cell phone? A. No. Q. Yourhomephone? A. No. Q. What did he call?

Page

A. He called the Narconon phone number that was directed to my phone.

Q. Okay. Was it ahotline? A. It was a forwarded number. Q. Can you give me that number? A. I think it's tbis one. Possibly. Q. The 770 number from Exhibit 3? A. Yes. Q. But you're not -- but not positive? A. I'm not positive. Q. Okay. So was that number directed to you

after hours? A. Yes. Q. All the time? A. No. Not ali the time. Q. Okay. How did -- did you have -- were you on

call, or ~d you have shifts? · A. Yeah, there were nights that I took the phone.

TI1ere was a time when it was mainly me, but there was a time when Kurtis was also working there he would take

19 (Pages 70 to 73)

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Desmond, et al. v. Narconon, e t a l .

Page 74

1 ~~00~ 1 2 Q. All right. 2 3 A. I don't know if he was work -- I don't think 3 4 he was there at that time. So it was probably me. 4 5 Q. Okay. What did the police officer tell you? 5 6 A. Honestly, it was like 3 o'clock in the morning 6 7 or some -- some time like that; I don't remember 7 3 exactly. 8 9 Q. 'What do you remember genera lty? 9

1 0 A. He told me what had happened with Patrick. 1 0 11 Q. What did he tell you happened? 1 1 12 A. That's the part I don't remember specifically. 12 13 I know what I walked away with, tmderstanding. 13 14 Q. And that's -that's all I'm asking for. I 1 4 15 tmderstand it was a .long time ago. - 15 16 A. Okay. Yeah. 16 17 Q. -- It was the middle of the night. 17 18 A. That Patrick was not responsive. That he -- 18 19 the- the police officer didn't seem to totally, 19 2 0 compLetely know himself what had happened. But he had a 2 0 21 couple of former students with him there, and he told me 21 2 2 they had given the number. Which is '\'VhY I assume it 2 2 2 3 wasn't my cell phone number. And that they had tried to 2 3 2 4 revive him, and then that they called the ambulance, ·and 2 4 2 5 Patrick was a± the hospital, and he needed the family's 2 5

Page 75

1 contact infonnation. 1 2 Q. Okay. So when the police officer called you, 2 3 you believe Patrick was already at the hospital? 3 4 A. Yes. 4 5 Q. Okay. And did you give him Patrick's family's 5 6 contact information? 6 7 A. I didn't have it 7 8 Q. So what did you-- well, let me ba.Ck up. Did 8 9 be tell you anything else? 9

1 0 A. He told me who the students were. 1 0 11 Q. The students that Patrick was with? 11 12 A. Yes. 1 2 13 Q. And you recognized them to be Na:rconon 13 14 students? 14 15 A. No. 15 16 Q. How did you recognize them? 16 1 7 A To be suspended Narconon students. 1 7 1 8 Q. Okay. Both of them were suspended Narconon 1 8 1 9 students? 1 9 20 A. Yes. 2 0 2 1 Q. Okay. 2 1 2 2 A. That's all I recall him saying to me. In -- 2 2 2 3 you know, without having the details of the exact words, 2 3 2 4 that was the general conversation. 2 4 2 5 Q. Did he mention why he thought he was 2 5 -- • - 4 :#OQr.

Trac ey E. Reynolds (Stepl er } - 11/18/2011

Page 7 6 3

nonresponsive? I A. No. ~ Q. Did he mention a potential drug overdose? I A. No. ~ Q. Did he mention--excuse me-a potential alcohol !I

overdose? ~ A. Not -- I don't remember him mentioning either I

of those things. ~ Q. Okay. Did he ask you any other questions, ~

besides for Patrick's family's information? ~ A. That - no; thafs the reason he called. i Q. Did he ask you where Patrick lived? ~ A. No. He-- he asked if Patrick was part of the J

program. He -- these two fonner students had told him 1 that he was part of the program, and he asked me if this ! was that program. i

Q. Okay. And you said "former"; "suspended I students" is what you said a few minutes ago.

A. Yes, they were -- yeah. Q. Suspended? A. The suspended students, the two suspended

students. Q. Oh. So -- and the police officer asked

whether the folks with Patrick were students? A. No. He asked ifPatrickwas indeed -- like

Page 77 i ij

did I have that information. Q. Gotyou. A. They had given the information that he was a

student; did I have his parents' contact information. Q. Okay. But did he ask you whether -- where

Patrick lived? A. I don't think so, no. Q. All right. And you confirmed that he -

Patrick was in fact a student at Narconon? A. Yes. Q . Anything else you told the police officer,

that you remember? A. No. Q. What did you do when you hung up with the

police officer? A. I called-- I called Mary and Maria. Q . All right. And do you remember whether you

gave the police officer their infonnation? Or either one oftheir information?

A. I don't remember. Q. All right What did you tell Mary? A. I don't remember exactly. I told her - in

general-- generally, that Patrick was in the hospital. And basically that's it, in a nutshell.

Q. Did you tell them who Patrick was with?

I ~ ~ I i i ~ ~

I ~ ~

I ~ ~

i •

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Desmond, et al. v . Ka r conon, et al. Tracey E. Reynol ds (Stepler ) - 11/18/2011

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A. I told her that a police officer had called me from the police station, and I did-- I told her the two students. But I just remember I -- I wanted to go to the hospital I --

Q. Okay. A. --told her I was going to go to the hospital. Q. Okay. And Mary didn't go to the hospital

right then, did she? A. No. Q. So after you called Mary and Maria --well,

what did you tell Maria?

1 2 3 4 5 6 7 8 9

10 11

A. I told Maria that Patrick was in the hospital, 12 and of com-se she asked what happened, and I told her I 13 didn't know what was hap --I didn't know. That those 14 two students were at the police station with the police officer, he called me, and -- and I said, "I want -- I'm going - I'm going to the hospital."

Q. You knew -- you knew that Brandon Ormsby had -- had prior heroin overdoses while he was at Narconon, right?

MS. WID'ILOCK: Object to the form, and instruct

TilE WITNESS: I can't answer that. MS. WHITLOCK: I don't think tbe witness

can answer that.

MS. FR<\NKLIN: Based on? THE WITNESS: Confidentiality.

BY MS. FRANKLIN: Q. Yeah, rm -A. Oh.

MS. FRANKLIN: You're instl'Ucting the witness not to answer based on confidentiality?

MS. WHITLOCK: Yes.

Page 7 9

MS. FRANKLIN: Okay. The --the witness has waived; Mr. Onnsbyhas testified and said he'd bad a heroin overdose at Narconon.

Here, I think we - I think we can clarify this.

BYMS. FRANKLIN: Q. Did you assume that Patrick had had a heroin

overdose when the police officer called you? A No. Q. Did you assume anything about what- why he

was unresponsive? A. I knew something horrible happened. I assumed

something horrible happened. Q. Okay. After you hung up the phone with Maria,

you went to the hospital? A. Uh-huh (affirmative).

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Page 80 ~

§ Q. Were you the first one who arrived from •

~ Narconon? ~

A No; Maria picked me up. We went together. ~

Q. Okay. And was anyone there at the hospital? ~.~ A. I -- what are -- I don't understand the ~

qu~oa ~ Q. I'm sorry, was there anyone there from !

Narconon? ~ ~ A. No. ~

Q. How long did you stay at the hospital? ~ A. I don't remember. ~ Q. Do you remember whether- do you need to take i

abreak? ~

A. No. ~ Q. Do you remember- did you stay until ~

Pa1lick's parents got there? ~

~: ~~~long did you stay? ~ A. A couple of hours, at least. A couple of

hours. Q. Were you asked by any nurses or personnel at

·the hospital what you knew about Patrick? A. No. Not that I remember. Q. Did anyone else show up from Na.rconon after

you got there?

Page

A Not while I was there, no. Q. All right. Were you told at any time you were

in the hospital what was wrong with Patrick? A. !asked. Q. Who did you ask? A. I asked one of the nurses that kept coming in

and out of his room. Q. What did she say? A She said they didn't know. They didn't know

yet. Q. Did Mary come to the hospital while you were

there? A. No. Q. So after you left it was-- was it about

morning time? A. Yeah. It was - I don't remember what time it

was. Q. Okay. Did Maria drop you off? A. At some point, yes. Q. And then what did you do? Did you go back to ~

sleep, or did you -A. 1--Q. --go over to Narconon? j A. I don't remember. ' Q. Okay. Did you show up for work the next day? ~ ~- vC .. ? - ~~~- ~

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Desmond, et al. v . Narcon on, et al .

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1 A. I usually worked from home. 1 2 Q. When you're an intake -- I'm sotty to change 2 3 subjects, but when you're an - when you were doing 3 4 intake, you answered the phone from home? 4 5 A. Yes. 5 6 Q. Did you ever have a office there at Narconon? 6 7 A. I hr:td a place that -- yeah, I bad a -- yes, I 7 8 had a place that I could sit when I was there. -- 8 9 Q. Right; -- 9

10 A --Yes. 10 11 Q. -but you just chose to work from home a lot? 11 12 A. Yes. 12 13 Q. All right. So did you work from home the next 13 14 day? 14 15 A I don't-- I don't remember. 15 1 6 Q. Do you remember whether there was any meeting 1 6 17 the following day amongst the stafffi:omNarconon about 1 7 1 8 Patrick's, at that time, death -I don't know if it was 18 19 his death at that point, but about what had happened? 19 2 0 A A meeting? No. Like a gatheting? No. 2 0 21 Q. Gathering, no. 21 2 2 A. Not that I remember. No. 2 2 2 3 Q. Did you go over to Delgado Development after 2 3 2 4 Patrick's death? 2 4 2 5 A. Ever? Like ever? Or are you asking -- 2 5

Page 83

1 Q. In the days after. 1 2 A. In the days after. No. 2 3 Q. Did you meet - well, it's my understanding 3 4 that Colleen, Patrick's mom, came to Atlanta, came to 4 5 the hospital; did you know that? 5 6 A. Yes; but I don't knowhow. 6 7 Q. Did youmeether? - 7 B A. No. 8 9 Q. -Did you talk to her when she came here? 9

10 A No. 10 11 Q. Was there a memorial service for Patrick, to 11 12 your knowledge, at Narconon? 12 1 3 A Yes. 13 14 Q. Did you attend? 14 15 A I could not. 15 1 6 Q. You could not? 16 1 7 A I -I chose not to. 17 18 Q. Anyreason? 18 19 A I was too upset 19 2 0 Q. Okay. Did you ever hear about what it was 2 0 21 that caused Patrick to die? 21 2 2 A Specifically, no. 2 2 2 3 Q. Generally. 2 3 2 4 A. I asked - I just assu - I had assumed some 2 4 2 5 things from something the nurse bad said that night 2 5

Tracey E. Reynolds (Stepler) - 11/18 /2011

Page 84 a

Q. Okay. And what did the nurse say? ' A She said -- well, she said they're not sure, i

and -- I don't remember exactly. I... I got the idea i that he had opiates -- they found opiates in his system. ~

Q. But you're not s:ure -- I A. And that they -- yeah. That they suspected ~

that that had caused some problem. ~ Q. And you got that from the nurse, you believe? J A. I think so, yeah. ! Q. Okay. Did yon talk to Mary Rieser about the ~

cause of Patrick's death? A. I don't remember specifically talking to her.

I think I re - I probably passed that on to her. Q. ToMary? A. Yes. Q. You say you "probably"; do you specifically

remember telling Mary? A. I don't Q. Okay. Did Mary ever teU you not to talk to

anyone else about Patrick's situation? A. I don't remember her saying that, but that's

an implied thing. I mean, that's... Yeah, I wouldn't. -

Q. Why? --A. -I wouldn't.

Q. - 'Cause you wanted to keep it within the organization?

A. Because he's a patient, he --he's a client out of rehab, we wouldn't...

Page

Q. What about other students; did Mary tell you not to talk to any other students about it?

A. No. Q. Okay. Did Mruy tell you not to talk to any

other staff members about it? A. I don't remember her giving any instruction

not to talk to somebody. Q. Did she tell you, if you did talk to folks,

what to say? A. I don't remember any conversation about that. Q. After Patrick's death, do you remember whether

anyone from Narconon International visited the Narconon of Georgia facility?

A I don't remember anybody visiting. Q. Okay. Have you ever met anybody from Narconon ~

International? i A [ don't think so. ~ Q. Do you remember whether there was any sort of

investigation witlllil Narconon about Patrick's death? A. Can you clarify the question for me? Q. Okay. Did anyone ask you, after the fact,

~ ~ • 3

f ~

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Desmond, et al. v . Narconon, e t al. Tr acey E. Reynolds {Stepler) - 11/ 18/201 1

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1 whether you knew anything about Patrick's death? 1 A. [email protected]. < i

2 A. I don't think so. 2 MS. WHITLOCK: Say that again? ~ 3 Q. Anyone from the Church of Scientology ask you 3 THE WITNESS: That was my E-mail.

~ • 4 about it? 4 MS. WHITLOCK: Say it again, slow? I

~ 5 A. No. 5 THE WITNESS: It was i 6 Q. Have you talked to anyone outside of the 6 RehabThatWorks@Y ahoo.com. ~·

7 Narconon organization or any lawyers about Patrick's 7 BYMS. FRANKLIN: I 8 death? 8 Q. Is that still an active E-mail address? ~ • 9 A. Talked to anybody outside the organization. 9 A. Probably; because it gets lots of junk mail to ~.

10 My husband was there when the call came in. 10 it. 11 Q. All right. 11 Q. Okay. Do you- i 12 A. But no lawyers or anything, no. 12 A. I don't use it as a -- a correspondence with <

1 3 Q. Anyone from the church headquarters in 13 Narconon. For Narconon. " 14 California? 14 Q. Okay. Well, speaking of that, do you still 15 A. No. · 15 have any association with Narconon? ! 16 MR. AMASON: Do you aJl mind if we take 16 A. How do you mean? I 17 a short break? 17 Q. Do you have friends that still work there? 18 MS. FRANKLIN: Sure. Yeah. I don't 18 A. Yes. 1

19 have much longer after this, so... Take a 19 Q. Who? i 20 break. 20 A. Well, Mary goes to my church, so I guess in-- I 2 1 TilE VIDEOGRAPHER: Going off the video 21 I mean, it's not- we don't hang out or anything, but I ~ 22 record at 12:08. 22 could say she was a friend. There are people that I ~

23 (Recess at 12:08, resumed at 12:18.) 23 know that still work there. i 24 THE VIDEOGRAPHER; We're back on the 24 Q. Do you hang out socially with anyone that ]!

25 video record at 12:18. This is the beginning 25 still works there? ~

Page 87 Pa ge 89 J . • 1 of tape number 2. 1 A. No. 1

2 BY MS. FRANKLIN: 2 Q. Do you keep in touch with the Delgados? ~ 3 Q. Ms. Stepler, how long did you work for 3 A. Occasionally. Maria. ~

4 Narconon after Patrick's death? 4 Q. Okay. Anybody else that you keep in touch ~

5 A. I don't remember. 5 with or correspond with from Narconon? ~ i 6 Q. Approximately. 6 A. I have a whole -- I have a -I have people on • • 7 A. Several months. 7 my Facebook, but I reaJiy could probably log onto t a· Q. And did you work from home during that several 8 Facebook maybe once a month and not correspond with

9 months after his death? 9 anybody. Let me just take some time to think about ~ i 10 A. Yes. 1 0 it, -- l 11 Q. Did you - how many times do you think you 11 Q. Sure. ~ 12 went to the facility? 12 A --make sure. ~

13 A. I would go in the mornings to look at the case 13 There's no one that works atNarconon right ~ 1 4 files. So however many times that would be. 14 now that I hang out with or correspond with. ·t 1 5 Q. So you would go to look at the hard copy of 15 Q. Okay. And I asked you earlier whether you ·~

~

16 the case files at the facility? 16 left on bad terms, and I think you said no. Were you--17 A. Yes, 17 were you asked to leave? 1 8 Q. You wouldn't get them by E-mail or anything? 1 8 A. No.

• 1 9 A. No. 1 9 Q. It was completely your decision? ~ 20 Q. Right. But you would take calls at home; is 2 0 A. Yes. ~

21 that right? 21 Q. And did anything instigate that, your leaving? ' 22 A. Yes. 2 2 Anything that happened at Narconon? i 2 3 Q. Did you have a Narconon E-mail address? 2 3 A. Nothing in pruticular that spurred it off. !t

24 A. Yes. 2 4 Like someone getting upset with me and then I quit or ~ 25 Q. What was it? 25 something like that, no. ~

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Desmond, et al . v . Narconon, e t al. Tr ace y E. Reynolds (St epl er) - 11/18/2011

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Page 90

Q. Okay. Anything generally? A. I just felt like I wanted to do something

else. Q. Have you visited any other Narconon

facilities? In any other states? A. No. Q. Do you have friends at any other Narconon

facilities? A. I don't think so. Q. You mentioned earlier -- we had the date 1994,

and I can't remember what that was -- is that when you said you moved from Dallas to California?

A. I think that's the year that I stayed in Califonria doing some training.

Q. Okay. That was at the Celebrity Center? A. Yes. Q. Did - did you ever have a chance to meet Dave

Miscavige? A. As a fluke. Actually, one time, but it was

not that - it was not at that time. Q. Okay. Was it -- where was it? A. It was at a gala event there, and he was

walking in the hallways and he said hello to me. Q. And you said earlier that no one from the

church has asked you or talked to you about Patrick's

death, right? . A. Right.

Page 91

Q. Anybody help you --help you prepare for your deposition today? -

A. No. Q. -From the church? A. No. Q. Have you talked to anybody from the church

about your deposition today? A No. That works at the -- in the capacity at

the church, no. Q. Any other -- anybody just from chmch? A My husband. Q. You talked to Ms. Korbin from California? A I don't even know who Ms. Korbin is. Q. Okay. Were you ever interviewed by any

Department of Human Resource investigators or surveyors while you worked at Narconon? To yom· knowledge?

A No. Q. Were you aware of any DHR investigation of

Narconon while you worked there? A I -- I'm not -- you know, I don't know if I'm

familiar with that With the term you're talking about. Q. DHR? A. Like Department ofHwnan Resources.

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Page 92

Q. Yeah. i A. What would they do? ~ Q. Well, if you're-- if you're not familiar with ~

that term, that's fine. I A. I don't know. i Q. Are you aware of any sort of State i~.~.

investigation ofNarconon while you worked there? ~

A. No. I Q. Are you aware of any complaints by any l

students of the housing conditions? i A. Can you --like more specifically? I Q. Did you ever hear of any students complaining ~

about the housing conditions at Delgado? ~ A. Yes. •

~ Q. Tell me about those. What do you remember? ~ A. There's one person I remember complaining ~

about his roommates. I mean, people don't always get ~ along. I don't remember even specifically what... I ~ just remember the complaining part. !

Q. Okay. Do you remember ever any complaints ~. about students using alcohol or drugs at Delgado? ~

A. Can you ask that again? ~ Q. Sure. Do you remember any complaints about i

students or allegations about students using diUgs or 1

1 alcohol at Delgado apartments? tJ.

A. Yes. Q. Tell me about that. A. I would hear things like -- that -- I never

received. necessarily, a complaint. I would hear almost like a rumor of something happening. Or there were occas - occasional sometimes a report would show up in a folder. You know, "11ris person--" --I don't remember specific incidents of it. But I have. Yes, rve - I've seen that

Q. Okay. Did you ever-- were you ever made aware of any allegations of staff members using drugs or alcohol at the- at Delgado apartments?

A. No. Q. All right. I think I know the answer to this

one, but have you ever been convicted of a crime? A. No. Q. How did you learn about this lawsuit? A. I don't --I don't remember if it was through

Kate Whitlock or if it was through Maria Delgado. One of the --I'm not sure.

Q. All right. Have you spoken with Maria about this lawsuit?

A. Yes. Q. Tell me about that-- those conversations. A. I remember hearing about the lawsuit from her.

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1 She called me, I think. or - I don't know if I called 1 Q. Besides your husband, Maria Delgado, Mary ~ 2 her. I'm not sure. Either way, it was a telephone 2 Rieser, who else have you spoken to about Patrick's 3 call. And she said there was a lawsuit. 3 death? Alld Ms. Whitlock. i 4 Q. What all did she say about it? 4 A. About Patrick's death, no one. No one. About ~

5 A. That's -- I mean, there wasn't anything else 5 the deposition, I mean, I told my boss I was coming for I 6 really said about it. I mean... Of course, she was 6 a deposition. So if that is--7 upset about it. 7 Q. Right. 8 Q. About the lawsuit? 8 A. -- related to that. 9 A. About Patrick, about the lawsuit, yes. 9 Q. I understand.

10 Q. Did she express any opinions about the fact 10 A. Yeah. 11 that there had been a lawsuit filed? 11 MS. FRANKLIN: All right. lneedjust 12 A. No. She was worried about it, concemed. You 12 two or three minutes to go over my notes; if I 13 know, she - I mean, the -- yeah, the Patrick-- that -- 13 you guys have any questions you want to ask. 14 the whole thing. Upset. Upset about the whole thing. 14 MR. YAEGER: I don't have any questions. 1 5 Q. Okay. Have you spoken with Mary Rieser about 15 MR. AMASON: I don't believe I'll have 16 this lawsuit? 16 any questions.

~ 17 A. No. 17 MS. FRANKLIN: All right. ~ 18 Q. When's the last time.you spoke with Mary? 1 8 BY MS. FRANKLIN: J 19 A. A few months ago I saw her in our church 19 Q. Let's take just two or three minutes, and we I 20 reception area. And she said hello and I said hello, 20 may be done here, Ms. Stepler . . 2 1 and that was basically it. 21 THE VIDEOGRAPHER: Going off the video 22 Q. What did you do to prepare for your deposition 22 record at 12:32. i 23 today? 23 (Recess at 12:32, resumed at 12:34.) ~

24 A. I came in and met with Kate Whitlock. 24 THE VIDEOGRAPHER: We are back on the ' 25 Q. Anything else? 25 record at 12:34. ~

Page 95 Page 97 i t 1 A. I talked with my husband about it. 1 BY MS. FRANKLIN:

2 Q. Did you watch any videos? 2 Q. Okay, Ms. Stepler, just a couple of follow-up

I 3 A. I watched a video here. 3 questions and then we'll be done. 4 Q. Okay. About depositions and -~ 4 Were there any changes in housing after 5 A. Yeah. 5 Patrick's death? 6 Q. -- conduct -- 6 A Yes. 7 A Like- 7 Q. Tell me about 1hat 8 Q. - during the deposition? B A. We wanted to offer an additional option. We 9 A. -- a video like you watch when you go to jury 9 bad had other options for people to go, places for

10 duty kind of '<ideo. 1 0 people to go. We-- another housing company opened up. I 11 Q. Okay. How long did you meet with 11 Q. What v.ras 1he name of that company? 12 Ms. Whitlock? 1 2 A. I don't remember the -- the legal name of the 13 A. Maybe an hour and a half. 13 company. 14 Q. And you looked at some documents? 14 Q. Do you remember who ran it? 15 A. Yes. 15 A Allison Riepe. And in the beginning another 16 Q. What documents did you look at? 16 person. I don't remember his la.,-1: name. I think 1 1 7 A. I saw -- I saw this (indicating). And I don't 17 it's -- and honestly the fust name; it may be Ryan. ' 18 remember any others specifically, but I-- I looked over 18 rm not sure. ~ 19 this one (indicating). 19 Q. Where was that housing facility located? 20 Q. Okay. Have you read anything on the Internet 20 A It was a few miles away from Narconon. 2 1 about this lawsuit? 21 Q. So did you move all your students from the One

' 22 A. No. 22 Sovereign Place to this new facility? ' 23 Q. Have you read anything on the Internet about 23 A. Well,-24 Patrick's death? 2 4 Q. Or was it gradual? 25 A. No. 25 A. - Narconon wasn't in charge of movmg the i

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Desmond, et al . v . Na=conon , et a : . Tracey E. Reynolds (Stepler) - 11/18/2011

Page 98 Page

1 students around. If they came into a program, you can 1 Q. Did you ever visit the new facility? 2 tellthemifthey-iftheywantahousing,wewould 2 A. Yes. 3 recommend a housing company. These two. Or they had a 3 Q. How many times? 4 choice to stay somewhere else. 4 A. Well, I went-- ifi dropped someone off 5 Q. So you just started recommending a different 5 there, I would be there. So a handful of times? A 6 place rather than Delgado; is that right? 6 couple handfuls. You know, many. Maybe ten. 7 A. I don't -- I don't recall necessarily 7 Q. Did you ever hear any complaints OJ

8 recommending one over the other, if that's what you're 8 allegations about students using drugs or alcohol at the 9 asking. 9 new facility?

1 0 Q. So did you offer both as a- potential 1 0 A. Yes. 1 1 housing options? 1 1 Q. What do you remember about those? 12 A. I -I think in certain cases, yes. If I knew 1 2 A. The same. Kind of-- I-- when I look back in 13 that someplace was full, I wouldn't recommend trying to 13 my mind, those report -like if I saw a report. I 14 go to that place. 1 4 don't know if I... Let me just think. 15 Q. Okay. Andbythetimeyouleft,weremostor 15 Mymind,itgetsjumbledup,isit -- wasit ~ 1 6 all of the students staying at the new housing facility? 16 there or was it here. I don't-- I don't know. ~ 17 A. I-- I-- honestly, I don't remember. I 17 Q. I understand. That's all the questions I ! 1 B don't. I'm not sure. 1 8 have, Ms. Stepler. ,. 1 9 Q. Do you remember any students that were staying 19 A. Okay. 2 0 at One Sovereign Place moving ~o the new facility? 2 0 EXAMINATION ! 21 A. I don't remember. 21 BY MS. WillTLOCK: J 2 2 Q. Were there different conditions at the new 2 2 Q. Ms. Stepler, I want to clarifY just a couple ! 2 3 facility? 2 3 of things. Ms. Franklin was just asking you about ~

2 4 A. What do you mean? 2 4 residential, and rm not sure I heard what you testified 5 2 5 Q. Okay. Did you-- at the Delg!idO Development, 2 5 to earlier in the day, ~ ~----~~~~~~~~~~~~~~~~Z---~~~~~~~~~~-----------------------4,

Page 99 Page 101 1 1 did they provide security? 1 Did you say that Narconon provided a - or ~ 2 A... They provided supervision 2 offered a residential program or residential facilities? ~ 3 Q. Okay. How is that different than security? 3 MS. FRANKLIN: Object to the form. i 4 A. It may be just different in my mind. Security 4 THE \VITNESS: I-- I think I said yes. I~ 5 I think of as -- yeah, it's probably different in my 5 BY MS. WHITLOCK: M

~ 6 mind. As a hired company. Like hire -- a hired company 6 Q. Okay. Did they offer a residential program or ~ 7 that they wear unifonns and things like that 111at's 7 residential facility? ~ 8 what I think of as security. 8 A. Narconon is an outpatient facility. We did ~ 9 Q. Okay. And they didn't provide what you 9 offer or reCDmmend that people stay in a supportive il

i ~ co~def ~~~ :,~~~ ~ f:!~~d: idea that they ~ ~ houQ~g,;~~~:~f the Narconon program? ~ 12 did at one time and maybe they didn't at another time, 12 A. No. It was separate, but we would have rather i 13 but that's not-- wasn't necessarily told to me. I 13 have somebody living in a housing facility than in like i 14 don't -- I'm not sure. 14 a-- in a hotel or something like that, if they're from ~ 15 Q. Do you know whether they provided security at 1 5 out of state. 'Cause at least they have somebody -- a ) 16 the new housing option? 16 supportive environment. • J 17 A. Again, I think: there were times \¥hen they did 1 7 Q. Okay. Looking at Plaintiffs' EXhibit 3~ you 1 B and maybe there were times when tl1ey didn't. I kind of 18 talked to Ms. Franklin a lot about that letter? 19 remember both. 19 A. Uh-huh (affinnative ). 2 0 . Q. Do you know whether the- the rules for the 2 0 Q. And you said this was like a f01m letter that 21 students were the same at Delgado as they were for the 21 you all would send out? 2 2 new facility? 2 2 A. Yes. 2 3 A. I never saw the rules, so I couldn't say if 2 3 Q. Did you ever send these letters out if they 2 4 they were exactly the same. I would assume they're 2 4 were not requested? 25 similar. 25 A. No.

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1 Q. Okay. 2 MS. WHITLOCK: That's all I have. 3 :MR. YAEGER: No questions. 4 :MR. AMASON: No questions. 5 MS. WHITLOCK: All right. 6 MS. FRANKLIN: Thank you, Ms. Stepler. 7 Tiffi WITNESS: Okay. 8 THE VIDEOGRAPHER: Going off the vid~o 9 record at 12:41.

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CERTIFICATE GEORGIA: FULTON COUNTY:

I hereby certify that the foregoing deposition was taken down, as stated in the 1 caption, and the questions and the answers thereto were reduced to printing under my direction; that the preceding pages represent a true and correct transcript, to the best of my ability, of the evidence given by said witness upon said hearing. And I further certify that I am not of kin or counsel to the pm1ies to the case; am not in the regular employ of coWlSel for any of said pru.1ies; nor am I in anywise interested in the result of said case.

This, the 29th day of November, 2011 .

Jo TomoffFischer, RMR CCRNo. B-924 Notary Commission Expires 8-25-2012

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1 ERRATA SH EET 2 I, the undersigued, TRACEY EVELYN REYNOLDS (STEPLER),

do hereby certify that I have read the foregoing 3 deposition and that, to the best of my knowledge, said

deposition is true and accurate (with the exception of 4 the following corrections listed below.) 5 6 7 PAGE/LINE CORRECTION (and reason for correction) 8 I 9 I

10 I 11 I 12 I 13 I 14 I 15 I 16 I 1 7 I 18 I 19 I 2'0 I 21 22

Notary Public Signature 23 Date 24 My Commission Expires: 25

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