Opposition To Toucan Motion Re Scientology

Case 8:11-cv-01368-JDW-TGW Document 68
Filed 12/12/12 Page 1 of 47 PageID 1194
IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF FLORIDA

TAMPA DIVISION
TOUCAN PARTNERS, LLC, a Florida limited liability company, NARCONON SPRING HILL, INC., a Florida corporation,
CASE NO: 8:11-cv-1368-T-27TGW
Plaintiffs,
vs.
HERNANDO COUNTY, FLORIDA, a political subdivision of the State of Florida,
Defendant.
DEFENDANT'S RESPONSE IN OPPOSITION TO PLAINTFFS'OTION IN LIMINE TO PRECLUDE REFERENCES TO CHURCH OF SCIENTOLOGY. AND SUPPORTING MEMORANDUM OF LAW
Defendant
HERNANDO
COUNTY. by and through

for entry
undersigned
counsel, moves this
Court to deny
implying
Plaintiffs'otion
between
of an Order
precluding
Defendant from mentioning

would
or
a connection
Plaintiffs
and Scientology.
Defendant
show that the

by any
matter is relevant
in the instant
case and this relevance is not substantially
outweighed
preiudice to Plaintiffs
In support thereof, Defendant offers the following Memorandum
of Law.
MEMORANDUM
OF LAW
I.
Upon being prevented
Introduction
and Factual Background
from expanding
Plaintiffs'rug
and alcohol rehabilitation
facility,
Plaintiffs filed suit alleging violations
of the Federal
Housing Act and
of the Americans With of lost
Disabilities Act, for which Plaintiffs are seeking monetary
damages. in part, on a theory
profits.
[Doc. I] This theory requires Plaintiffs to make a showing that the facility would have
as Plamtiffs intended.
been able to operate as successfully
The deposition
testimony
taken in the instant
case shows that there is a connection

licenses
pays
between Scientology and Narconon
Mr Mitchell testified that Narconon International

with
Narconon
centers; Narconon
is affiliated
the Church
of Scientology,
the facility
royalty fees to an organization
run by the Church
of Scientology
and license fees to Narconon
International;
and the connection to the Church
of Scientology has an effect on the ability to

past who decided not to go to Narconon
attract clients in that there have been people

as a result.
in the
[Exhibit A, Depo. of Mitchell, p. 22. Ins, 3-4; p. 66, Ins 1-25; p. 67, 19-25; p. 68,
lns. 1-3] Mr. Mithcell also testified that the "model

Spring Hill, which is based on Scientology
of treatment'r
"the program" at Narconon
[66 5-16] is a 'major factor in decision making for

Mr. Morgenstern
testified that
would likely
people in where they go to treatment."

there is a relationship
[56: 5-8]. Additionally,
between Narconon and Scientology and that this relationship
decrease demand to some people
[Exhibit
8,
Depo
of Morgenstern
dated Oct. 11, 2012, p
29, lns 4-22].

The facility's
website further
with specially
supports
trained
the connection
by stating
that the facility is a
'Narconon"
program
staf1'n the program

the founder
methodology
of Narconon,
[Exhibit
based upon the prmciples
of Mr. L. Ron
Hubbard,
of Scientology.
C-
Excerpt from Suncoast Rehabilitation

specifically state: "The Corporation
by providing
Center Website].
Plaintiffs'rticles
of Incorporation
is organized
to operate exclusively
and prevention
for charitable purposes
drug rehabilitation
and drug educational
services through the use
of
technology
researched
and
developed
by
L. Ron Hubbard."
Additionally,
[Exhibit
Articles of
Incorporation
of Narconon Spring Hill, Inc]
the facility
is one
of
the various
Narconon
International
facilities
operating
around
the world
[Exhibit E-I Excerpt from Narconon
Website].
shows that Scientology played a huge role in the
The website for Narconon International

formation
of Narconon,
as well as continues to do so today
[Exhibit E-2. E-3, E-4, and
E-5
Excerpt from Narconon

was founded
International
Website]. In particular, the website shows that Narconon

set forth in "Scientology: The Fundamentals
upon the principles
of Thought"
written by L. Ron Hubbard;
that "Professional
with the Church
Scientologists'ere
in contact with the founder
of Narconon, Mr Benitez,
of Scientology even inviting Mr. Benitez to Hav,aii

financially
International
to propose the program to prison officials; and that Mr. Hubbard and his organization
supported
the development
of Narconon
[Exhibit E-2 Excerpt from Narconon
Website, Exhibit E-3 Excerpt from Narconon International

pioneered
program,
the
Website]. Moreover, Mr. Hubbard

New
drug-free
withdrawal
program
and
the Narconon
Life Detoxification
which Narconon
claims is Narconon's
distinguishing
factor, as set forth in

Plaintiffs'otion
in Limine on this topic. [Exhibit
E-4 Excerpt from Narconon International
Website].
from the
Narconon
Church
International
and
makes it clear that there is a large amount
of support
of Scientology
Scientologists
- the program
is supported
by Scientologists,
as
encouraged by the Church

by Scientologists.
of Scientology, as
well as the majonty ol the centers are open and run
[Exhibit E-5 Excerpt from Narconon International

made evident by Narconon
Website]. Additionally,
aside from the connection
itself. a simple google search will show
that a connection clearly exists. [Exhibit F
Cioogle Search for "Narconon"].
Thus, it is beyond evident that there is a connection between Scientology and Narconon
and that this connection
is something
that is immediately
apparent
for any individual
that is
researching or considering Narconon; to state otherwise is disingenuous
II.
Standard of Review
This Court has broad authority to control the admission

International
admission
of evidence
during trial. Chrysler
Corp.
v,
Chemaly,
280 F 3d 1358 (11th Cir. 2002).

right
Error is created when
of evidence affects
a substantial
of the
party. Fed R. Evid. 103(a). A motion in
limine is the vehicle to exclude irrelevant
evidence or unduly
pre)udicial
1
or confusing relevant
evidence.
See Hodgettsv. City
of Venice, 2011
WL 2192819,
(M.D. Fla. June 6, 2011).
III.
Discussion
- Evidence is relevant
Rale 401t Relevance and Rale 402t Admissibility
if
it has any
tendency to make a fact more or less probable than it would be without the evidence and the fact
is
of consequence
in determining
the action; relevant
evidence is admissible
unless provided
otherwise by statutory authority.

would have successfully
Fed.R.Evid. 401, 402 Plamtiffs must establish that the facility
attracted the amount
of participants
that Plaintiffs expected in order to

is
prove their damages.
Plaintiffs will meet this burden by offering evidence that the program
successful and widely accepted.
Accordingly.
it is absolutely
relevant
to, and a critical portion
of, Defendant's
defense in this matter to be able to set forth the way in which the Narconon
the history and background
program is run, including

very own materials,
of the
program as set forth in Narconon's

and widely accepted.
to show that the program
was not successful
That
Narconon is tied to Scientology is certainly true, as made clear above, and relevant, as Plaintiffs
witnesses have testified that the connection affects attracting potential participants.
Thus, evidence
of the relationship
between Scientology and Narconon is relevant to show

less attractive or less popular and this fact is
that there is a connection which makes the program
of consequence
in determining
Plaintift s damages.
Fcd R Evid
401. As the evidence

Fed R Evid. 402.
is
relevant and not prohibited
by any other
source. it is therefore admissible.
Rule d03r Not Unduly Prejudicial and Confusing - Relevant testimony is excluded if the
probative
value
of the evidence
is substantially
outweighed
by danger
of unfair preJudice or
confusing the issues. Fed R,Evid. 403. In the instant case, Plaintiffs seek to present the positives
of Narconon to paint a picture of a program

the community,
including
that has absolute success and is widely accepted by
while preventing
Defendant
from presenting
any evidence that shows otherwise,
a relationship
between
Scientology and Narconon
that is made clear in Narconon's
very own materials
and by Narconon
employees'wn
testimony.
Evidence does not become
madniissible
as prejudicial
simply
because it is negative
for the Plaintiffs. but. rather, it must
substantially
outweigh the probative value
of the evidence.
is not seeking to inject religious views mto this
on the basis
Despite Plaintiffs'ontention,
Defendant
case to attack or support Narconon's

prohibited
by Federal Rule
credibility
of religion. as contemplated
and
of Evidence 610. But,
rather, Defendant
seeks to properly introduce
such evidence to show that the relationship
would prevent Plaintiffs from having the success that
Plaintiffs are setting forth that they would have had

that potential
The probative value of this information- is not substantially
customers would be less likely to choose Plaintiffs'acility

by the prejudice to Plaintiffs
outweighed
of the
jurors knowing actual facts about the Narconon
program set forth by Narconon itself.
WHEREFORE, Defendant
Plaintiffs'equest
above
HERNANDO
COUNTY
requests
this
Court
to deny
as stated
to enter an Order on this Motion in Limine prohibiting
any testimony
I HEREBY CERTIFY that on December 12, 2012, the foregoing was electronically
filed with the Clerk
of the Courts
by using the CM/ECF system which will send a notice
of
electronic tiling to: Carole Joy Barice. Esquire. McGee
Mason, P.A.. Post Oflice Box 1900,
Brooksville, FL 34605-1900; Ethan J. Loeb, Esquire, Bricklemyer Smolker & Bolves, P.A., 500
E Kennedy Blvd., Suite 200. Tampa, FL 33602; Joseph M. Mason.

Mason, P
Jr,
Esquire, McGee &
A, P.O Box 1900. Brooksville, FL 34605;
David Smolker, Esquire, Bricklemyer
Smolker & Bolves, P.A., 500 E. Kennedy

Esquire, Bricklemyer
Blvd., Suite 200, Tampa, FL 33602: Jon P. Tasso,
Smolker & Bolves, P
A, 500
E Kennedy
Blvd., Suite 200, Tampa, FL
33602.
s/Dour.las T. Noah DOUGLAS T. NOAH, ESQ. Florida Bar No. 0863970 Dean, Ringers, Morgan & Lawton, P.A. Post Office Box 2928
Orlando, Florida 32802-2928 Tel 407-422-4310 Fax: 407-648-0233
corn Rebecca((sdrml-lav .corn
DNoah,'a',drml-lav
Attorneys for Defendant
IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA
TAMPA
DIVISION
PARTNERS, LLC, FLORIDA LIMITED LIABILITY SPRING HILL, COMPANY, NARCONON INC., A FLORIDA CORPORATION
TOUCAN
PLAINTIFFS
VS.
NO.
8:11-CV-1368-T-27TGW
HERNANDO
A
COUNTY~
POLITICAL
FLORI DA~ SUBDIVISION OF
THE
STATE OF FLORIDA
DEFENDANT
ORAL DEPOSITION
ERIC MITCHELL
TAKEN AUGUST
OF
29t11, 2012
AT
9:37 A.M.
WARNER
REPORTING
294 OLD FERRY LANE ARKANSAS 72455 POCAHONTAS,
(870) 219-9814
warner
reporting8centurytel.
net
EXHIBIT
NIGINAL
22
1
2
3
4
6
7 8
centers operate off of is based on an independent study that Narconon International, which is the entity that licenses Uh, that Narconon centers, provided to each center. rate is 76 percent.. Again, based on a study that had done on graduates two and a Narconon International half years after completion of the program.
A
The
success rate that Narconon
When
was
this study
I didn't
performed'?
A
Q
I'm sorry?
When
understand
the question.
10
11
12
13
14
15
16
17 18
this study performed? I'm not sure. I don't have any of that information A in front of me. And I don't really know. that was Do you know if this was a study that, Q information or was produced -- their own independent to audit and to provide this study? A I don't really have any information at hand right
was
19
20
it was done understanding third party. But I do not have any by an uninterested hard information regarding that study with me today. Okay. And, and you knew about this study back when Q
now
about the study.
It's
my
21
22
you were
A
at Narconon of I knew of the study,
Oklahoma?
yes.
I didn't
have,
23
24
25
that time, hard information about who did it dates. But, yes, I knew of it. So then it would be fair to say the study is Q
Warner
at or exact
even
Reporting
(870)219-9814
Certified
Court Reporter
66
1
2
Q
Do you
know
if
Narconon
is affiliated
with any
religious
A
3
4
organizations? Yeah. I'm, I'm well-versed

what
in Narconon's
structure.
Q
5 6 7
8
And
religious organizations
is
Narconon
affiliated
A
with?
10
11
12
13
14
15
16
17 18
19
20
of Scientology in that Narconon pays royalty fees to an organization known as the Association for Better Living and Education who own the copyright to everything ever written by L. Ron Hubbard. The Narconon program is based on a book written by Hubbard called Fundamentals of Thought. And they, so Narconon International pays a royalty fee to an organization that's run by the Church of Scientology. We, as a center, pay licenses fees to Narconon International, That, to my knowledge, is the only affiliation at all with any religious organization. Is that a question that sometimes comes up, uh, Q when people are asking about your program?
Narconon
is affiliated
with the Church
A
Q
Yes.
And
21
22
23
24
Do then a similar question about reputation. you, do you believe then that it's fair to say that the reputation of the Church of Scientology has some
relationship
Suncoast'?
to your ability to acquire clients for
25
Warner
Reporting
(870)219-9814
Certified
Court Reporter
67
3
4
I, don',
Q
Object to form. I don't think so. I think that's I don't believe that has an effect
MR. TASSO:
stretch.
on us
directly.
don't think that any clients say I don't want to go this program because they'e associated with that particular church?
(By Mr. Lowe)
You
A
5
6 7
8
how
Q
Well, yeah, I understood

And
that's probably fair,

the
but I
I, that's
not
first question.
I'm not saying
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
to be affiliated with it. But, uh, but -- effect on your ability to attract clients? I'm so sorry. You'e going to have to ask that A question again. MR. TASSO: Object to form. broke up again A We, we broke up, uh, the, something so I'm going to have to ask you to ask me that last question again, please. (By Mr. Lowe) So you would agree, then, that your Q affiliation with the Church of Scientology has an effect on your ability to attract clients to your program? MR. TASSO: Object to form. A Uh, I, I agree that there have been people in the past who decided not to go to Narconon because of, uh, the connection to the Church of Scientology, if that
want
Warner
this church and I
isn',
--
like that
Reporting
(870)219-9814
Certified
Court Reporter
68
1
2
3
4
I just want to the question. answering the question properly. (By (4r. Lowe) Yes. Q
answers
A
Q
make
sure I'm
Okay.
Thank
5 6 7
8
died as a rehab program?

A
of any patients who have result of participating in the Narconon drug

you.
Are you aware
Uh,
you know,
I, like
most of the country,
have
become
10
11
12
of that only recently, uh, at the Narconon Until, you know, the recent media center in Oklahoma. coverage on that I was not aware of any deaths ever in
aware
the Narconon
Q
program.
13
14
Do
you know how many

my
people died?
It's
understanding
you
that three people have died
15 16
17 18
at that center. And you said that Q
this, like, is that

A
through
recently have become aware of the media reading newspaper reports,

of
had
19
20
Uh,
I, I first
became aware
it,
you know,
from
21
22
23
24
the coworkers at my center who heard, you know. Someone said hear about, you know, the death So then at Narconon Arrowhead.
said, hey,
have you
to me one day did you at Narconon in Oklahoma, I did some research

and so
25
online, read recently saw,
some news
articles
forth.
on NBC, a
And
then
you know,
Reporting
of, something
(870)219-9814
Certified
special
Warner
Court Reporter

ORiGiggi'N
THE UNITED
MIDDLE
STATES DISTRICT COURT DISTRICT OF FLORIDA TAMPA DIVISION
8:11CV-1368 T-27TGW
PARTNERS, LLC, a Florida limited liability company, NARCONON SPRING HILL, INC., Florida corporation, a
TOUCAN
Plaintiffs,
7
8
vs
a
HERNANDO
10
State of Florida,
political subdivision
COUNTY,
FLORIDA
of the
11
12
Defendant.
13
DEPASTTTAN
OF:
FOR TOUCAN
15 16
17 18
CORPORATE
REPRESENTATIVE
PARTNERS
LLOYD MORGENSTERN
Examination
of
Witness,
beginning
19
20
at 10:30 A.M.
on Thursday,
and concluding
at 1:42 P.M.
21
22
October 11, 2012, taken by the Defendant at Bricklemeyer, Smolker & Bolves; 500 E. Kennedy Boulevard, Suite
23
200; Tampa, Florida, before Roberta Turner, RPR, FPR, CCR (GA),
25
Certified Court Reporter.
EXHIBIT
TOIINER REPORTING,
INC.
(407) 497-6070
29
1
2
Yes.
The
may
and
negative,
Q
of Narconon, positive affect demand at Narconon Spring

reputation
whether
3
4
Hill.
or not Narconon is affiliated with the Church of Scientology? A I don't believe that they'e affiliated by ownership, but I believe there is some relationship with the teachings of the Church of Scientology. Do you know whether or not there is a Q perception in the market that Narconon is affilrated with the Church of Scxentology? A I don't have a specific answer, but my sense is that there are some potential customers that may be effected by that. that Do you believe that this perception Q Narconon is affiliated with the Church of Scientology would make the demand for the Narconon program less than the market demand for services generally for drug, alcohol and substance abuse treatment facilities? A decrease demand My sense is that it would to some people and increase demand to others. And what is that belief based upon? Q
Do you
know
5
6 7 8
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
The program
has no
affiliation
with
the
25
Church
of Scientology.
It
does not teach or does
TURNER
(407) 497-6070
REPORTING,
INC.
.The Founder of Narconon Suncoast Drug Rehab 68 Filed 12/12/12 Page 14 of 47 PageID 12072 Page 1 of Case 8:11-cv-01368-JDW-TGW Document Center
i
SIJNCOAST REHAIIILI IATION CFNTI:It

Home
Programs
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Contact Us
The Founder of Narconon
The first Narconon was started and founded by William Benitez, an inmate at Anzona State Pnson Mr Benitez was a heroin addict who could not seem to get off of drugs using traditional forms of treatment After being sentenced to pnson he had a re alizauon that il rug,id di i tia had caused most of the problems in his life. mcluding the current ane He set out ta change himself through self-improvement
i i
Insurance Accepted
)f
ClgllG
HUMANA
Narconon The History of the Program
he read lots of self-beuerment Dunng his quest at selnmprovement, books One of those books, titled "Fundamentals of Thought" was a self-help book wntten by Mr L Ron Hubbard
Fniledfleatlthcare
aetna
Qx.
Mga Mca
that he started practiong and incorporated into his kfe He found himself responding favorably to his efforts and wrote the warden asking permission lo start a small drug recovery program to help others
This had some basic pnnaples
Blue(:tx&ss Blueghield
~l Vhtl)FOVTIONS
Industry Assooations
Mr Benitez Delivenng
Officials denied permission for the following six months Mr Bemtez's request to start a program consisting of twenty convicted drug addicts, caused concern to offioals who feared such a program might pose a secunty problem (such programs were rare in pnsons
dunng that decade)
a Drug
Lecture
'k
'I'&'to
Offiaals had little reason to believe that the request of a habitual drug addict and repeatedly convicted felon, would result in one of the nation's most successful rehabiktation program for substance abusers
Mr Benitez persisted and finally assured offioals the program was needed and would not pose a threat to
iQ N.AA1? AC.
the safe and orderly operation of the pnson After being allowed to start the program on a tnal basis, he founded IIIARCONON INARCOtics-NONe) on February 19, 1966
Today, Narconon has spread from that one program in Anzona State Pnson to include i ommunity programs in many states and countnes such as Denmark, Italy, Holland, Germany, France, Sweden, Spain, Canada, Russia, Ukraine, Kazakhstan, Mexico, Columbia, Switzerlanil, New 2ealand, tiie Umted Kingdom, Australia, Taiwan, Argentma, and Brazil
Mr Bemtez was a Heanng officer with the Anzona Department of corrections, the same system which once kept him under lock and key
I-le was a
We'e Here to Help'all

Now
husband for 30 years as well as a father and grandfather
Mr Benitez passed away in June
af
1999
877-435-6329
ALL CALLS ARE
EXHIBIT
CONFIDENTIAL
l
http: //www
C.
12/5/2012
suncoastrehabcenter,corn/the-founder-ot'-narconon/
The Founder of Narconon Suncoast Drug Rehab CenterFiled 12/12/12 Page 15 of 47 PageID 2 of 2 Page 1208 Case 8:11-cv-01368-JDW-TGW Document 68
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12/5/2012
in Spring 68 Our Rehabilitation Program Narconon Document Hill Case 8:11-cv-01368-JDW-TGW

I
Page 1 of 3 Filed 12/12/12 Page 16 of 47 PageID 1209
Our Rehabilitation
About Our Program
What we deliver is a results
Program
based program
rehab program
It
is a long-term
Many of our
graduates are finished within 3

to 4 months but some take
longer
Every step of the
program has a concrete end result and
a person
it
is only done
when they achieve that end, no
matter how long
takes
One of the main differences

with our drug rehab program
is that is consists of an exact sequence of steps that bnng a
person up to a point of being able to live a happy life without the use of drugs
Shortly after the person starts
in
treatment,
they would begin The Narconon
New Life
Detoxification program which helps the person get nd of the build-up and residuals of drugs and toxins in the body It has been scientifically proven that this build-up creates a
crawng for the drugs, even though the person himself wants to stop These residual
chemicals make
it
harder for the person to get off drugs and stay off them for good
This detox program helps remove the build-up, and therefore the crawng
http: //narconon-spring-hill,
corn/about-narco
non-spring-hill/
12/5/2012
Oar Rehabilitation Program NarcononDocument Hill in Spring 68 Case 8:11-cv-01368-JDW-TGW

I
As part of the program, there is
the social education and

learning
how to recognize their own tnggers which is delwered
at different points
in
the
These help the person overcome their drug

program
addiction and become a part of

the family and community
once
again
In our program
the indiwdual
also helps the student identify

situations
in
their personal
lives
that led them to drugs initially
They learn important tools to

apply to their lives, and develop
confidence
in
their ability to live
a drug-free life they can truly

enloy
About our Staff

The staff we have are specially trained
staff
with
in
the program methodology
of Narconon
The
as a
whole has many years of expenence and tens of thousands
of hours working
addicts to help them conquer their addiction(s)

in
Another point is that the staff pnde
themselves
their desire of continued education
They attend training classes and
enhance their skills on a regular basis

We have many counselors who are themselves
strong shared understanding
with
recovered addicts which allows for a

the staff truly gets where our
our students and gives them the ability to know first
hand how our clients feel Having been there themselves,
students have been, what they are going through, and the bnght, drug free future they can each have
The Founder of Narconon

The first Narconon was started and founded by William Bemtez, an inmate at Anzona State Prison Mr Benitez was a heroin
addict who could not seem to get off of drugs using traditional
forms of treatment realization
After being sentenced
to pnson he had a
that drug addiction had caused most of the problems
http: //narconon-spring-htll.cont/about-narconon-spring-hill/
12/5/2012
OQr Rehabilitation Program NarcononDocument Hill in Spring 68 Case 8:11-cv-01368-JDW-TGW

i
in
his life, including
the current one He set out to change himself
through
self-improvement
License
Suncoast Rehabilitation
of Flonda
Center is hcensed by the State
State License
ff
0527AD1983
The Florida Department

the licensing agency
in
of Children and Families
is
this state
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','i
1601 W Gulf Atlantic Highway
Wildwood,
Flonda 34785
'avsr,
Phone (352) 330-2177

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12/5/2012
Division of Corporations
Public Access System
Electronic Filing Cover Sheet

Note: Please print this page and use lt as a cover sheet. Type the fax audit number (shown below) on the top and bottom of all pages of the document.
(((H08000190958 3)))
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Note; DO NOT hit the REFRESH/RELOAD button on your browser fiom this page, Doing so will generate another cover sheet.
Oiviazon of Corporariona Fax Number: ) 650) 617-63 st

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Account. Name Account Number Phone Fax
: JONNsoN,
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popE, SOKOR, RUPPEL
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Number:
076666002140 (727)461 1616 (727) 441 "6617
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FX.ORID& PROFIT/NON PROFIT CORPO~TION

NARCONON SPRING HILL, INC.
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EXHIBIT
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JOHNSON
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(((H08000190958 3)))
ARTICLES OF INCORPORATION NARCONON SPRING IBLL, INC.
A Florida "blot for Profit" Corporation
Thc undersigned,
acting as incorporator of a coqotatioo under Chapter Articles of Incorporation;
617 of Florida Statutes,
44doprs the ibllowing
A.
NAME OF CORPORATION:
The name of the corporation shall be:
Narconon Spring Hill,
Iac
PRINCIPAL OIPIRICE: Thc principal cdfice of the corporation is locatedit:~i, &'o~',
co
O
33 North Garden Avenue Suite 770 Clearwater, FL 33755
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C.
MAKING ADDRESS: Thc
maQbtg address
of Sbc corporation ir.
33 North Garden
Avenue Suite 770 Clearwater, FL 33755
REGISTERED AGENTS The name of the registered Rebecca Heist. The address of Shia registered agent is:
D.
agent
of tbe
corporation
is
Johnson, Pope, Bokor, Ruppel dt 911 Chestnut Street Clearwater, FL 33756
Burn, LLP
The period of the Coqorauon's duration is perpetual: DURATION/MEMBERSHIPS E. The qualification for members, if any, aud the manner of their admission shall be regulated by the bylaws.
F.
number
BOARD OF DIRECTORS: The method of selection of the Boanl of Directors and of dhectum shaH be stated in the bylsws.
XNCORPORATORSJ
G.
Jolmson, Pope, Bokor, Ruppel
Ek
The name and address of the incoqerator is: Rebecca Heist, Butns. LLP, 911 Chestnut Sueet, Clearwater, Florida 33756.
(((H08000190958 3)))

4as 00-08
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IL
CORPORATE PURPOSES: The purposes For which this corporation exclusively charitabl, eduoational and scientific snd consist of the following:
is formed aze
1. This corporation
corresponding
is formed exclusively foz charitable and educarional purposes witbimhe meamng of section 501(c)(3) of the Internal Revenue Code of 1986 or tbe
provision
of any
future United States Internal Revenue law.
2. Th corporation
is organized to operate eatclusively for charitable purposes by rehabilitation and drug and prevention services through thc pzovi4ng drug us: of technology rescarched and developed by L. Ron Hubbard.
ed~
3 To aid, support, snd assist by gifts, contribudons,
or otherwise, other corporations, chests, funds and foundanons organized and operated exclusively for community charitabl, educational or scientific purposes, no part of the net earnings of which inures to the benefit of any private shareholder or individual, and no substandal part of the activities of which is carrying on pzopagaruh, or otherwise to influence legislation.
~g
4. To do
any and all lawful activities which may be necessary, useful. or desixnble for the urthezancc, accomplishmen4 fostering, or atttunittg of the foregoing purposes, either dirccdy or indirectly, and either alone or in conjunction or coopexnfion with others, whether such others be persons or organizations of any kind or nature, such as corporations. firms, association, trusts, hstitution, foundanons, or govennnental bureaus, departments or agencies.
5, All of the foxegoing purposes shall bc exercised exclusively charitable and educadonal purposes in such a manner xbat the Coxporation vrrll qualify as an exempt otgazuzation under section 50l (c)(3) of the Internal Revenue Code of 1936 or ihc corresponding
provision
of any
future United States Interne! Revenue Iaw.
501(c)(3)LIMITATIONS
L CORPORATE PURPOSES: Notwithstanding any other provision of these articles, this orgnnlzadon shad) not carry on any other activities not permitted to be carried on by an ozgsnization exempt fixnn pcdcral and state income tax under section 501 (cx3) of the Internal Revenue Code of 1986 or the corresponding provision of sny future United States Internal Revenue Iaw.
2.
EXCLVSIVITl'z
Thc Corporation is organized exclusively for charitable and
educational purposes.
NO PRIVATE INUREMENT: The Corporation is not oxgsnized nor shall it be operated for thc primary purpose of generating pecuniary gain or profit. The Corporation shall not distribute any gains, pmfits or dividends to the Directors, Officezs, or Mernbcrs thereof, or to any htdivtdual, except as reasonable compensation for services actually performed in carrying out me corpozaxton's ctauixan0c curt ertucnuorrnt Jrnrtronao. 'xxrn
3.
(((HQS00019095S 3)))

400-00-00

7274410012
II:50as
Pros-Jctu0011
POPE
040
P 04/05
F-201
(((H08000190958 3)))
property, assets, profits and net income of thc Corporation are irrevocably dedicated to charitable and educsrlonal purposes no part of which shall inmc to the benefit of any individual.
LOBBYING AND POLITICAL CAMPAIGNS: No substantial part of the 4. activifies of the corporation shall consist of the canying on of pmpaganda or otherwise attempting to influence legislation, and the corporabon shall not participate in, or intervene in, any politica! campaign on behalf of sny candidate for public office.
DISSOLUTION: Upon winding up and dissolution of thc Corporation, the assets of the Corporation atter payment of all debts and liabilities shall be distrihuted to an organization tecogoiaM as exempt under section S01(c)(3) of the Internal Revenue Code of 1986 to be used exclusively for charitable aud educational purposes, If the Corporation holds any assets in trust, such esse:ts shall be disposed of in such a manner as may be directed by decree of the Circuit Court of the district in which the Cciporation's principal offirc is located. upon petition thereof by the Attorney General or by any person concerned in the litluidstion.
S.
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PRIVATE FOUNDATION" PROVISIONSF In the event this Corporation is considered to be a "Private Foundation- by the U.S. Internal Revenue Service under pmvisions of the United States Code the following provisions apply:
The Corporation will distribute its income for each uui year at a time and a.) iu s manner as not to become subject to ihe tax on undistributed income imposed by section 4942 of the Internal Revenu Code, or the corresponding section of any funue federal tax code.
6.
b.)
The Corporation wiB not engage in any act of self-dealing ss defined in section 4941 (d) of the Internal Revenue Code, or the conesponding section of any future federal tax code,
The Corporadon will not retain any cxccss business holdings as defined in section 4943(c) of the Internal Revenue Code, or the conesponding section of any fiuure federal tax code.
c.)
The Corporation will not make any investments in a manner as to subject d.) it to tax under secdon 4944 of thc huercal Revenue Code, or the corresponding section of sny future federal tax code. The Corporation will not make any taxable expenditures as defined in section 4945(d) of the Internal Revenue Code, or the corresponding secdon of auy future federal tsx code.
e.)
J.
INDENINIPICATION - Any person (and the heirs, executors snd administrators of such person) made or threatened m be made a pany to any acnan, suti of procccamg ny reason cf rbc
(((H080001909S 8 3)))

Ang

7224410012
00-00
11:5rnn
Frnn-JOWI505
POPE
045
05/05
F-201
(((H08000190958 3)))
fact that he is or was a Director or Of6cer of the Corporation shall be indcmuiffed by the Corporation against any snd rdl liability and the reasonable expenses, including attorney's fees snd disbursements, incurred by birn (or by his heirs, exncutors or administrators) in connection with the defense or settlemcnt of such action, suit or proceeding, or in connection with any appearance therein, except in tehtnon to matters as to which lt shall be adjudged in such action, suit or proceeding that such Ducctor or Of6ccr is liable for negligence or misconduct in the performance of his duties. Such right of indemnification shall not be deemed exclusive of any other rights to which such Director or Officer (or such heirs, executors of administrators) may be catt itled apart from this Article.
IN WIThlESS WHEREOF, thy,undersigned, being the original incorporator, these Articles of incorporanon this day of August, 20
has executed
CERTIFICATE DESIGNATING REGISTERED AGENT AND STREET ADDRESS FOR SERVICE OF PROCESS
FLORIDA
Pursuant to QL stat. the laws of tbe State
548.09I, NARCONON SPRING HILL. INC., desiring to organize under

undersigned
RKBECCA L. HEIST
accept service
of Florida, hereby designates thc of process within tbc State of Florida
as its registered agent to
ACCEPTANCE OF DESIGNATION
The undersigned hereby accepts the shove designation as registered agent to accept service of process for the above-named corporarion, at the place designated above. and agrees to 38Lt. C1'48.091(2) relative to maintaining an offfcc for the comply with the provisions of service of process
Dated: August
2008
REBECCA
~ST
(({H08000190958 3)))
Case 8:11-cv-01368-JDW-TGW Ikiac unon Locations
Document 68
Filed 12/12/12 Page 24 of 47 PageID 12174 Page 1 of
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Since opmung ils doors m 1966 the Narconon program has been derkcated to savmg as many hves as possible from the devastauou of ahhcnon Because of tlus and the fact that the program works and gets results wtth any type of subsumce abuse problem more and more Nsrconon locauoos have been estabhshed across the Uruted States and the world.
Narronon is a worldemde solubon for handling drug abuse Seven out of ten graduates stay permanently clean and sober aftm treatment The success wrth Ihe methodology is higher than most other types of rehabilttanon avmlable And the geograpluc locabon of the drug user should not be a reasoa to aot do the Narcoooo program
Gd gr'll 1 '1
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Locations For Narconon In The United States:

Narconon curn:ntly has 100 locauons m more than "0 ihfferent couotnes One of the pnmary areas for Narconon centers ts m the United States where the program began Narconon mitially started m Anzona State Penttenbmy mth its central office located in Phoemx, Anzona The first residenual Narconoa program stwted m Los Angeles, Cahfonua in 1972
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Nnrcoaon aow has several locations i the Unitwl States iacludingt
Narcoaon Arrowhead
tlus is our largest residenual program that has over 100 dedicated staff and services nearly 200 clients ate tune consistently producmg the largest numbers oF fice dmg lives
EXHIBIT
http: //www.narconon.org/narconon-centers/locations.
html
12/7/2012
Case 8:11-cv-01368-JDW-TGW Document 68 Narconon Locations
Filed 12/12/12 Page 25 of 47 PageID 1218 Page 2 of 4
Narconon Vista Bay mth three locauons, Narcoaon Vmta Bay is one of the most successful Narconon programs avmlablc Tbe locau one fm the program caler to an imbvidual's enmronmcntal reeds and include fsciliues m Santa Cruz, South Lake Tahoe aod Placervige Narconon San Diego located m Warner Spnngs, Cahfonua thu orgamzatlon " has been there s mes 1966 and m md led "A New Life Program
Io addtuon to the many faml mes m the state of Cahfouua, Narconon also
operates two drug prevenuon groups rncludmg Frrerafr ofNorcotma as well as thc Narconou Drug Prew.'lurou and gdvouron Program m Cahforrua wtuch help to educate youth and adults algm mth mdeos as well as bve prevenuoa prcscalatlons
Narconoa Colorado located m Fmt Colhos, Narconon Colorado ls at tbe foottulls of tbe Rocky Mountmas and is one of the best places m the world to start one's Id'e over through trcatnlctlt. Narconoa Nevada nestled outside of the business of Las Vegas, Naramon Nevada u also called the Rmnbow Canyon Retreat. It is ln a very secluded and safe locauon for treatment
Harlmgton, Texas 0 the locauon for Narconoo South Texas Tlus Narconon center is located m the Rto Grande Valley ooly 30 mdes from the Gulf of Memco snd offers both Spuush and Engksh treatment opuons
Narconoa South Texas
Narconoa Hawaii On the island of Oahu, near Honolulu, Narconon Hawau ls a drug prevenuon program to help those on thc island and across the world to get the unvanushed facts on adlbcuon aed drugs
In the vacauon city of De sun, on the Plonda panhandle Narcouoa Gulf Coast u ooc of the most relmung and aeslhrnc Narconon settmgs
Narcoaoa Gulf Coast
Nsrconoa Fiends
An outpauent caster located Clearwater, Narconon Flonda is near beauuful clear beaches The faclhty bas hclpml hundreds to stably recover from drug and alcohol abuse problems for nearly 13 years
)~l~
Narcoooa Spring Httt Just north of Tampa, Narconoa Spnng Hill m known as Suocoast Rebablbtation Center Suutrd Just a few years ago the famhty holds many events for clients and otfers top of the hne smvices to those enrolled in
tlcsnncnl
Nsrconoa of Georgia
The Narconon Georgia pmgrsm ls an outpatient facihty located m Norcross, Georgia. The founder, Msty Rteser helps each student to develop their own sense of ethics aad personal responsibdity to aid ln lhelr recovery
Narcon os Lou is la as Also called Narconon verbend Retreat, this facihty is located on acreage that allows for a qmct and serene expenence where chents can enloy heing spaces, rerzeamon and lounging areas dunng thetr
treatment
Narconoa Freedom Ceater The 58,000 square foot buikhng for Nsrconon Freedom Center sits on 10 arres wiuch are ideal for those m treatment. The locanon bas mngs for
both males and females
Nsrconon also operates a drug educauon and prevennon program m New England.
International
Narconon Locations
Nsrcoaon not only has rusny locauons io the US but across thc world m many ditferent countnes Du ectly north of the Uruted States are the Narconon prrorams m Canada
Canadian Narconon locations:

this is a drug prevennon and refemd group that has saved thousands of
Narconoa Vancouver
hvcs
http: //wvtrw.narconon.org/narconon-centers/locations.
html
12/7/2012
Case 8:11-cv-01368-JDW-TGW Document 68 Narconon Locations
Filed 12/12/12 Page 26 of 47 PageID 12194 Page 3 of
Narconon also bas a great preseace around the rest of the world mcluihng m Lean Amencs.
I~
Latin America Narconoa Locations:

Narconoa Columbia Bogota.
center dchvers Tlus
treatment outside
of Seats Fe de
Narconoa Meuco Located m Celaya which is outside of Mexico City, dns fsnhty bas bccn helping people for oearly 15 years m aa area where treatment is most needed hmause of tbe ongomg drug wsr.
Narcoeon Navsjoa Situated ia the state of Sonora, dus governmeat sponsored program has baca protudmg serssces once 2005 tk
Narconon Argentina Began as a drug educanoa program m 2002, and soon opened the rehabditauon faahty m the Bueaos Au'es area
Narconon Tijuaaa Opened m 2012, tlus center services people throughout Mcmco as well as Spuush speahng people &om the
US
The Narcoaon oroersm slee has a stress riresence in Eurooe.
Narconon Europe Locationsi southern

Narconon Urutcd kingdom that started m 1975 Narconon Smtzerland that has two centers Narconon Sweden that was snutcd m 1972 and n now located m tbe relpon as Narconon Eslov Later, two drug prcvenuoa and educanon groups opeaed, Narconoa Vmteras aod Narconon Gothenburg. Narconon Spun opened m 1983 eth three centers, Narconon Los Molmos, Nsrconon Teaenfc and Nsrconon Meditenaneo Narconon Denmark that was opened m 1986 snd u located m Skuthngsted Naramon Germany tbeu first caster opened m 1989 and currently the facdity is m the Bevans region First opened m Amsterdam to inn die the on go mg Narcon on Holland drug pmblems the present locauon is Narconon Zutphen. The fambty has been m operauon for 20 years Narconon Israel A center north of Tel Aviv, provuhng the pmgram m both English and Hebrew There is also a Nsrconon center located in the Commonwealth of Independent states called Narconon Moscow Tbe ongmal famlity opened m 1994 with Narconoa Dmutmvgrad, Narconon Ekstennburg, Narconon Standard, Narcooon South, Narconon St Petersburg and Narconon Erev m Ukraine followmg Narconon Balkan - opened tn MacetHnm in 2012 and provides drug educanon in schools as well as rehab program. Narconon Hungmy - has been providmg drug education throughout the country smce 2002 In 2007 they opened an out-pauent rebab center and m 2010 a res ideatml drug rebab center m Novgrwk
Ntslconnn Saves Live

As a special place, there is alm Narconon Italy nth more casters than any other country m the world aod morc than 4,000 graduates Italy bad its first program opea m Lombardy m 1981 Smce thea the country has opened several other centers
Calabria Regioa -Narconon Albatrcs, Narconon La Fmuce and Narcooon ll Falco

Puglia
Narconon
Narco non
Il Gabbiano
Alfiere and Narco
non
Marche Astore
Sicdy
Nsrconon
Gnfone
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html
12/7/2012
Case 8:11-cv-01368-JDW-TGW Document 68 Na Tconon Locations
Filed 12/12/12 Page 27 of 47 PageID 1220 Page 4 of 4
The programs m Italy not only deltver elfecnve drug rehabrlrtanon but also do masnvc outreach fm drug prcvenuon and educauon throughout tbe country
In Asta Narconon Tmwan was opeoed government and Buddlust commuruty the former Katmandu Cluef of pokes ag over Nepal wbtlc rcadung rrulhons the world
mth tbe help of the Tmwanese

Narconoo Nepal also opened m 2DPS by In mkbnoa they ddrver drug educauon through cadre and other muha throughout
On the Afncan connoent, there are also several 1ocanoas for Narconon wbtch mcludc Narcoooo Cape Town that u located in Moorresburg, South
Afnca.
There u also a Narconon program m Austrahn Narconon Melbourne was started as the "Get Off Drugs Naturally" program m 1997 and became a full mndennal omter m Warburton shortly ager
Evea with all om curreat Narconon locanons, we are sttll expandmg There mll be plans over the commg weeks, months and years to open maay more Narconon
locanons m the Uruted States and across the worht
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Narconon History: 1966 Case 8:11-cv-01368-JDW-TGW Document 68
Page 1 of2 Filed 12/12/12 Page 28 of 47 PageID 1221
NA,A ruNukTIcxNAL
NUN'NT
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Narconon Program History 1966: The Beginning

The year 1966 was the year the ground was broken for Ihe Narconon program. This was the year that Wdliam Bemtez, an mmate in the Anzona Staie Pnson sysiem, first dehvered drug rehablhtsnon services under the banner of Narconon Whde stdl a youog man, Mr Bemtez had already spent many years m pnson as a result of a hemm adlhction Tune ager tune, lus mabihty to shake the drug habit landed hun m lad. But despite every temptation to give up, he sull held onto the hope that somehow he would find a way to hve clean and sober
ln 1965, whde he was soll m pnson vnth many more years to go on tus sentence, Mr Bemtez found the basic matenal that would enable him to beat his adCiction Much more thea that, it was the matenal that would enable hun to found a drug rehabditauoa system that would help other addicts kick then habits and would eventually extend around the world
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It started when he came awoss a slim volume titled Screnrology The Fundamentals of Thought by Amencan author and humarutanaa L Ron Hublmrd The simple basics m tlus book changed hn way of tluntung As he stuCied the book over and over a@un, he realned he was no longer tlunlnng or actmg like an adCict He deternuned that he would use this ncw understaodmg to help other addicts recover liom then adCicuons.
While he made this daemon m August of 1965, it took untd February 1966 for hnn to convmce pnson ofilmals to allow hun to run a rehabditation scrvicc mside the pnson walls In those days, ttus kmd of acuvity was a complete novelty His persistence pmd off, and he finally got permnsion to offer classes m what he had learned to the other inmates m the pheon who had also struggled with adCtcuon
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He had put those months of wmtmg to good use He had started up a correspondence vnth the author of tbe book, L Ron Hubbard, who wrote back
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12/7/2012
Narconon History: 1966 Case 8:11-cv-01368-JDW-TGW Document 68
Page 2 of Filed 12/12/12 Page 29 of 47 PageID 12222
with his complete support of Mr. Benitez's mtennons Mr Bemtez got his hands on more books by Mr Hubbard and found that they also enhanced ius abdity to stay sober himself, and help others aclueve sobnety
With a small hbrary of purchased and donated books, on February 19, 1966, Mr Bemtez began to teach other adlhcts that theu addichon was nothmg more than a disabdity that they could apply themselves to overcommg.
He later stated, "1 found that if a persoa rehabditated and apphed certam abdities, that person could toward goals set, conf'ront hfe, isolate problems and resolve them, commumcate with life, be responsible and set efmcal standards, and function within the band of certmnty "
From these humble begmungs, Mr Berutez expanded lus oew Narconon program to provide service to more adihcted uunates and then mmates who were not adlhcted but wanted help livmg better lives. When he was released gum pnson in 1967, he traveled to Los Angeles to found a rehabditauoo program that was avmlable to anyone One after another, the hopelessly addicted began to stream through the doors, findmg 1astmg recovery for the first tune Gradually these grateful people enabled Narconon to grow mto an mtemauonal rehabditation and educanonal mshtunon
Allei
I'Rll
Articles and photos imm 1966
1966 - Wtll iatn Berutez ivith 2nd Varco mside Anzona State pnson
Sl
non
u roun
Batthna Adtbctlon
Article Narconon
Adihction
The Narconon historv
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aldau Eaaadi
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12/7/2012
Narconon History 1970 Pali Press Article Hawaii Case 8:11-cv-01368-JDW-TGW Document 68
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Narconon History 1970 Pali Press Article Hawaii Case 8:11-cv-01368-JDW-TGW Document 68
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Narconon Offers Convicts New Rehabilitation Program
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Wdbam Bmutez
L Ron Hubbard
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GREETING his mamlaed guest William Benitez, Rev lobn Egiott, Ieg, of the Church of Smcntology, yves him a coconut as a souvenrr of the Islands The symbol of a broken hypodemuc needle on Benitez's bnefcase symbohzes the Narconon orgamzation, dcsigncd to help drug addicts quit -Psb Press Photo
A dynamic young man ath a message of hope for narcotic addicts and others with aceous problems visited Hawan last week to mtroduce a program called Narconon
Wilbam C Bmutcz, a narcotic user smce ihe age of 13, and a four ume loser m the Anmna State Pnson, bas not only sumgbtened out lus own bfe, but is devotmg it to helping his fellow men He is domg this thmugb Narconon, an organization he started m Jail while serving tune on a narconc charge
Bemtez was mvited to Hawau by the local Church of Smeutology In company vwth its pastor, the Reverend John Egiott, he called upm pnson officmls hereto outlme the program he proposes for the inmates of the Hawau Pnson. Accordmg to Benitez, they were well received by many pnson ofamals, mcludmg Ray Eel nap, Admnustrator of the Corrections Division
The pmgram is now bemg senously considcrcd for tost mthm pnson walls, and also for members of the State's Condiuonal Release Center, Accordmg to Benitez The men m the Center work outside m the community, and are returned to the Center at ntght The Narconon program is m use m Anzona State Pnson and is composed more than 100 men, many of them non-a@hots
of
Benitez. mcalls that while m pnsou, he was despondent to the pomt of considenng suicide, when he was mspired by readmg a book called "Fundamentals of Ihought" by L Ron Hubbard, founder of Smentology and Dianeucs The book was gn en to turn m Jml by a fellow nunate
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PJarconon History 1970 Pali Press Article Hawaii Case 8:11-cv-01368-JDW-TGW Document 68
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"Whee I had fuushed rewhng it" says Benrtez, "I kvmw that Ierne found the way had out, and that I would never be tempted to touch drugs agan And that is how it bas been I also knew I would found an organmation for people bkc reyself and that wheri I ready, I would get out of lml, even though at the l was 1ookmg " forward to 15 years belund bars
Wastmg no tune on the demsioo to remake lus life, Ben itez, Iogether with a fellow uunate who was studymg law, begae to work toward lus own release Afler considerable research he found a teduucal loophole m the manner m wluch he had been sentenced, and on this basis was re-sentenced to a four year term He had almady served a year of that tone
Bmutez fimshed out the three years, workmg mtlun the pnsou to set up the Narconon program
The fimdamentsl
of thmgs,
idea is shove ag people who are m tmuble how to be the cause rather than tbe effect
Substanbally it means givmg the person the confidence to change and rbrect his own life, despite any and ag adverse cecumstances
Berutez talked to the gdl pnson popuiauon, says Ihat 95 per cent of lus awhence waisted to uy it.
m Hawau for more than an hour, aml
enthusmsm
for the program and
Smce Bmutez must return to Califonua to present lus program to the Governor, and to California penologists, Ihe program would be cerned on in Hav au under Reverend Egiott's tbrecuon
ls the program Just for drug addictsv By no means" says Benrtez "Anyone is welcome to Jom who has any type of disability, and we have many such
members We do not behave m classifymg people, cslbng them drug arkhcts, alcoholics, or whatever lt is important that the person not identify himself vnth a label, but that he reabzes at all arne be is a human bemg, and has the capacity to make himself the kind of person he wants to be Narconon, while it started in the field of drug addiction, u for people mth problems that are mterfenng with their ability to cope mth bfe Ag are welcome"
Reverend El bott, who would be adm in istenng the program, was asked to deffne how it would work Said Elbott "The program would cover both theory and practice The theory part would break down basic concepts of bfe such as control, cause, responsibdity and communicauon, defining them clearly
"For example control is basic to life, we go through life mther controlbng or being conuolled lf you ask someone what is control, or what are the parts of control, you will have s difficult arne getung an answer wtuch has a workable value for you
"The man who knows nothmg about the theory
of automobile engme will have a hard arne repainng one if it is not fuectionmg well The person who bkewtse knows nothmg about the anatomy of control wdl have a ditricult tune controlbng well, and vwg not readily be able to improve his own abibty
changmg are good changmg stoppmg
"Control, as used in our program, simply means startmg or creatmg sometlung, somethmg, or stopng somethmg undesirable Pmnters and mvcntors at creating or startmg Ilungs Managers and repairmen are good and thmgs or aidmg them to contmue pobcemen and fimmen are good at
tlungs
ln the practical part of Ibe course the student is involved in exercises which are designed to mcrease lus control abdily Just as a football player is coached mto greater abihty, so the student is hkcmse supervised in pracuce
"When a pnson inmate really learns how to control himself and to communicate, his life becomes easier to handle, and tbe neml to violate law is drastically " reduced
Related Articlcsr
First Narconon Outside of Pnson Narconon'I Fourth Annivcrsaiv in Anzonal State pnson
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,Narconon History 1970 Pali Press Article Hawaii Case 8:11-cv-01368-JDW-TGW Document 68
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1967 El Saguaro Golden West Penal Document 68 Filed 12/12/12 Page 34 of 47 PageID 12273 Page 1 of Case 8:11-cv-01368-JDW-TGW Newspaper Features Narconon
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Wdbam Berutez
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EISaguaro
Golden West's Best Penal Newspaper
June
I, 1967
NARCONON Founder Wdham Berutez

William C Bemtez, holdmg Founded s Plaque presented to bim by uunate members Looking on is the groups Sponsor, Mr John L Russell, and guest honor, Mr Peter Greene Professional Scientoloyst
of
New posts have been mstalled for both groups The new appomtments are Mmn Yard Narconon-Danny Domsky, Vice-Chmrman, Charles Johnson, Activity Rruorder and Libranan, Steve Williams, Narconoe Staf Artist, I E R NarcononJoe DeSanu, Vice-Chairman, Larry Hasungs, Actnnty Recorder and Libranan
IER. Institute for Educauon and Rehabilitation NARCONOJF Joseph De Sana

Vice-Cbmrman
IER Narconon is ASP's (Anzona State Pnson's) second Narconon gmup and is represented by addict and non-addict members It ongmated on September 12, 1966
(Note The second Narconon program was located vntlun tbe "Annex" section connected to the mam walls of the pnson It handled first arne otfenders and men under the age of 25 )
For full support of IER Narconon our acknowledgements
go to IER Capmm,
RC
Ward Directors of Education, Mr Jack Dillard Jt Mr Jeny Thompson Founder of Narconon, Inmate, Wdbam C Berutez SponsorofNarconon,Mr JohnL Russell Doctor of Scientology, Mr Peter Greene
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bout 8:11-cv-01368-JDW-TGW Document Page 1 of gCase William Benitez - Founder of Narconon 68 Filed 12/12/12 Page 37 of 47 PageID 12304
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Drug educauon presentauon given tn Apnl I 968 by William Benitez, founder the Narconon program, at the Scottsdale High School, Anzona
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4'out William Benitez - Founder of Narconon 68 Filed 12/12/12 Page 38 of 47 PageID 12314 Page 2 of Case 8:11-cv-01368-JDW-TGW Document
The Origins of the Narconon. Program

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On August 2, 1965, Wdbam Berutez, an ummte at Anzona State Pnson lumped down from his double bunk m the old cellblock where he was housed and made the fogomng notauon on lus wall calendar "Decision to set up Narcotic " He also mrcled the 18th of the same month, lus larget date to Foundation approach pnson otficmls to request pennnston to setup a drue rehabilitanon UtqtgpH umde the pnson walls
Wilham Berutez
Offimals derued pemussion for the fogoasng sm months Mr Benitez's request to suut a program consisung of twenty convicted drug nkbcts caused coocern to offiaals who fearnl such a program might pose a secunty problem (such programs were rare m pnsons dunng that decade) Officuds had I mls reason to believe that the request of a habitual drug nldict and repeatedly conrncted felon would result in one of the nauon's most successful rehabtlrtauon programs for
substance abusers
L Ron Hubbard
Mr Bnutez persnted and finally assured otYimals the program was needed and would not pose a threat to the safe and orderly operahon of the pnson Aber bemg allowed to start the program on a tnal basis, he founded the NARCONON program (NARCOhcs-NONe) on February 19, 1966
Today, the Narconon program has spread from that one program m Anzona Stale Pnson to mclude commuruty programs in many slates and countnes such as Denmark, Italy, Holland, Germany, France, Sweden, Spain, Canada, Russia, Ukrmne, Kazakhstsn, Mexico, Colombia, Switzerlaml, New Zealand, South Afnca, Ghana, the United Kmgdom, Austraba, Indonesia, Tmwsn, Argentina and Brazd
Unul he dred fiom a sudden igness m 1999, Mr Benitez was a Heanng Ogicer ustb the Anzona Department of Correcuons, the same system wluch ooce kept lum under lock and key Below, he tells hrs owo story
smoking pot ia 1947, when I wss thirleea. Thea I weot on to Intertied opium and other drugs whee I was shoat fifteea. I startnl to get iato trouble sad was arrested for venous crimes, so I decidml to joie tbe Msriaes to see if I could getaway from drugs. Instead, I ceded ap getnng arrmted on drug ebs rgm during the Ko res a cooflict, received a mibtsry court martial aad was duehargcd as audesirable.
I started
I kept trying to slay away from drugs. Sometimes I could stay clean fora short while, thea I would go nght back oo the needle agan. I carrml tbe monkey for about eighteen years, and it cost me thirteen caleadsr yean of beiag locked up. Ia additma to doing time ia tbe Marines, I did a Federal prison term aad also wss convnted three times in Anzsua slate corsets.
Ia the fogovnag yean,
On my last tnp to prnoa, I pled gudty oa December 22, 1964 to pessessioa oF uarcotics. Because I wss belag seateaced as s habitual oflender, tbe seateace calbd for a mandatory fifteea years, and ap to life. I remember speaking to oae court oflicial and teaiag him bow I was stig goiag to leave drugs sloae and maybe evea start s drug program. I remember hn words so well: "Tbe best thing to do with guys like you, alter tbe first time, n take you behind a buikhag and do you aad everyone else a favor aad put you out of your misery."
My attorney arra aged For me to go before the judge lust before Cbnstmas, feelrag that tbe spirit of the holiday might be in my favor. It may have worked. I made my plea to the ludge raging him of ag the attempts I bad made over the years to stop usiag drugs, such as loiamg tbe Menses, committing myself to hospitals for psychi stra cure aud therapy on several occasions, isolating myself in miamg towns ia a persoaal attempt to kick tbe habit, aad even bow two marrmges bad aot helped me straigbtea ap. I told bim that m spite of ag those fsdures, I was sug goiag to moke it snd was gomg to find a solunoa to my problem, that I hsd aot yet qua. He must have believed there was sttg a spark of hope for mc. He sentcaced me to the mandatory fifteen years, but instead of ruaniag it to life, he made the term fifteen to sntem yean.
After arriviog st prnon, a fnend of mise gave me some reading matenal to keep me occupied whde I was ia the Orientation Cellblock pending transfer lo general populatioa. Amoag tbe
12/7/2012
g'out William Benitez - Founder of Narconon 68 Filed 12/12/12 Page 39 of 47 PageID 12324 Page 3 of Case 8:11-cv-01368-JDW-TGW Document
material was sa old, tattered book, Puadameatals of Thought, by L. Ron Hubbard. I bsd beard of his writings whee I prevaasly served s tea-year sentence at Arimna State Prison, but bsd never read them. I hsd always been an avid reader of books dealing vdth human behavior. Yet, this small book impressed me more than soytbing else I bad ever read before. read it over and over and then purchased sddifloasl books by Mr. Hubbard snd studied them very carefufly during the foflowtag year, aves iato tbe fate bours of tbe night m my celL
Tbe matermf identified hum as abilities sad their developmeat. I wss amsmd I bad aeter ran acmss such workabihty uvthiu s multttude of other works I bad studied over the years. I'm not a gullible person whee it comes to accepting uew or different approaches or ideas. If they work, fisc. Otherwise, tbmw them out the window. They either work or they don'L I was tired of experimenting vdth so maay idms and philosopbim, many having credeace ooly because some "suthority" hsd written
them.
What impressed me the most about (Hubbard'sf matetmls was tbst they coaceatrsted aot only on idenhfysng abilities, but also oa methods (prscticaf exermses) by which to develop them. I realwed that drug sddictioa was aothmg more tbaa s "d isa bihty," resul hag when a pemon casern to me abilities essential to constructive surmvsL
that d's pemoa rehabilitated aad sppbed certoia sbilitws, that person could pemevere toward gosh set, confront hfe, isolate problems snd resolve them, communicate sth hfe, be responsible sad set tnbical standards, sad fuacuoa ustbia ihe bead of certaiaty.
I fouad
reslmed I bsd developed the essential abilities needed to overcome my drug problem. I'cali ng myself on safe grouad, I kaew I bsd to make this technology available to other addicts m the prison. I thought back over the years of all the I au kiss I bad shot up vwtb, snd remembered their most treasured convemstioa, "Ooe of these days I'm goiag to quit." I bsd fouad the means snd wss going lo share u wuh them. That's when I made the decisan real by wnting it down on my cstcadsr page Ia my erIL
I fiaafly
So effective wss the technology I bsd learned, tlmt I experienced s frmdom loag lost to me. The tall prison walk became only temporary barriers I realized that my 6zg foot cell wos sg that I aeedwl as a command posz Even back thea, I knew Nsrconoa would reach internstioasl proporhons, snd even wrote an s Aide os it m 1967, "The Purpose of Nsrcoaon."
The program wss ssnctiooed by the warden, aad rt soon began to expaad from its omginal twenty members. I then started to get requests from aoa-addict iamstes who wanted to get iato Narconon. They told me they were impressed vwtb what Nsrcoaon students bad told them about tbe program snd what ihe technology tsughL I approached tbe Admiautrahon for permusioa to iadude aoa-addicts. At first it resisted, sayiag that non-addict members didn't need tbe servkes of Narcoaon, snd tbst they might dwrupt the program.
I demonstrated to oflimals that say person, mmate or otherwise, could benefit from Nsrconoa because its suention wss on incressiag abihties, that we bad aa ethics mecbsawm budt into tbe program, sod that the responsibihty sad mvolvwnent required of a member would soon dissuade sayone aot serious shout improvement. I convi nced the p mon oflidsls. The program met ils expectauoas so well that saves months after the bqpaoing of Nsrconon, I was asked to start another program for youag offenders housed ia tbe essex outside tbe prison wsfls. I then wrote to Mr. Hubbard about Norcoaon. He sad bu organizahons supported our program by doaating books, tapes snd course ms terisb. We received ho ad redo of lettem from throughout the world validatmg our efforts to make drug addiction snd crimiasl or igegsl behavwr a thmg of the psst m
our livm.
Shortly sfler foundmg the Nsrconon pmgram, William Benitez resesrched his court coovicuon snd ihscovered he had been toed under the wrong statute snd wss sentenced in excess of that prescnbed by law Upon return to court, Mr Benitcz wss advised that he could conceivably be re-sentenced to tune served
12/7/2012
&6 bout William Benitez - Founder Case 8:11-cv-01368-JDW-TGW
of Narconon Document 68
and be released based on lus eighteen months already served because
of the
miscamage ofiustice
The Narconon program was only a few months old at lhat arne and Mr Bemtez believed the program would collapse rf he didn't return to complete it Rather than petitiorung for lus immediate release, he requested a smaller sentence which would allow him to fully unplement Narcooon program development The Court re-seotenccd turn to four to six years, leavmg lum smteen mooths to serve Mr Bmutez returned to puson and developed the progmm to its full capamty As hc slates, "It was the best, but toughest decision I ever made in my hfe. I would have loved to walk away from that cours a free maa." The Narconon program subsequently came lo the attention of the pubbc when reporters from the Auzona Duly Star secured penn usion from the warden to interview the mmate who requested io be returned to tbe walls The Star punted a two-part sensa on the Narconon program m August 1966 TV Channel 10 News from Phomux also took rts cameras to the puson to mterview Mr Benitez and members of tbe Narconon program and io observe its funcnons
Mr Berntcz completed lus pnson term and was released in October 1967 He moved to California to expand the Narconon orgaruzation and to raake it avmlable lo persons m need Mr Hubbard and his organizauons supported the effort, resultmg in worldwide excansion
Years later, Mr Benitez returned to Anzona and was hued as Inmate Luuson by former Auzona Department of Corrections Director, Ellis McDougall, in 1981 Unul his death in 1999, he served as a Ileanng Officer on inmate complamts foi the Correcnons Duector at Central Headquarters
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Narconon Program L. Ron Hubbard Document 68 Case 8:11-cv-01368-JDW-TGW

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"yoa may /rave noticed thai socieff rs raprdly going downhill Inflatio lack of fuel aird even war cast deep shadolrs over the liorld And the most serious pari of this rs that drags, boih medical and srrccr di ags, have disabled a emfomiy of ihose iiho could have handled ii, mcladmg ihe pahiical leoders, aad have even paraly ed the coming generaaons "
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The Narconon pmgram has Som the begmnmg been founded on key pnamples developed by author aud humamtanan L Ron Hubbard The keynote is that an mdhvhdual ts responsible for lus own conrhtlon and that anyone can improve his condition if be is given a workable way to do so It is based on unproved understandmg of his fundamental oature that man is basically good and it is pen, suffcnng, and loss that lead hun astray
In the early 1960's, Mr Hubbard was one of the first to see the long-term consequences of the acceleratmg drug culture He responded warmly to Wdlham Berutez's request for help with his fledglmg Narconon program m Anzona State Pnson and contmued to wnte up hn observations on the effects of drugs on lhe mChvidual person, his body, and the somety as a whole
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The Narconon program &om its mcepuon proruoted an approach to drug rehabditauon without recourse to alternanve drugs This early program Chd not, however, deal chrectly eath withdrawal symptoms and chfficulties In f93 L after Mr Hubbard had conducted further research to rud Narconon statr to help others through the chfficulties of withdrawal rhscom fort safely and with munmal discomfort, the Narconon program adopted these procedures to mclude drug-free hmthdrawat, usmg vhtamms and mmeral supplements along with special tecluuques to ease the mental and physical symptoms
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Narconon Program L. Ron Hubbard Document 68 Case 8:11-cv-01368-JDW-TGW

I
Another tndy pioneenng umovimon researched by Mr Hubbard was adopted m 1978, known as the Narcononth New Life Detoxiiicanon Program ltus tissuecteansmg regimen of spectflo vitamm/mmeral therapy with carthovascular exercise, mtensive sweaung m low heat saunas, adequate replacement of fluids and ods, has become uumeusely valuable for reducmg the long-term physical and mental efftmts of drug residuals on people who have taken drugs Mr Hubbard noted the scienufic emdeuce Mund the accumul anon of drug and other toxic residuals m tbe human body He postulated the mfluence that these psychoacnve toxms might have subluninafly and overt etrects on tbe mmd and person and developed a safe, healthy, and thomugh method of cleansmg the human body of the actual drug residuals
Author and Humamtanan Hubbard
L Ron
"One has the choice of being dead with drugs or being alive without diem Drugs rob hfe of the se near i one andf oys uluch are the only reason for hvmg anyhow "
Ron Hubbard
With this Narconon New Life Detoxification Pro aram students regularly report a remarkable mcrease in clarity of thudtmg, peace of mmd, and well bemg It also greatly reduces or elunumtes cravmgs for drugs that stem &om ludden drug
toxiiis
More than three decades of scientific studies and foflow-up have vahdated Ihe theory and practice of this remarkable pmcedure
L Ron Hubbard's mnovauons to the Narconon pmgram contmued through the years, always designed to famhtate a stable, drug-flee life for mthviduals
Grdteftd dpk m Iedgemeni ts made Id L Rdn Hhbbdrd Ltbr ry fdr per 2 I teem fed tbe ppy gtt d p Et pfL Re Hubbard
tistpn Id reprvdhpe
elye hve in a chemical oriented society One tvould be hmdput ta fird someone m the present-day civihzaiton wtro is not a/feared by tttts faci t have evenfound that there rs such a ltnng as the 'Drug Persanattry'
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Support 8:11-cv-01368-JDW-TGW Document 68 Case of Narconon Program
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Support For the Narconon Program

Narconon sonsties, ffom lies-standmg residential drua treannmt centers to education, receive support m many ways, varymg with the counby and coiririiuirity
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Celebnty Support
Direct Government Funding

in parts of Sweden, Denmark, Holland and Switzerland, once the Narconon method received officia recogniuon as a drug rehabdrtation program, it became ehgible for government fundmg, as prescnbed by local laws, dtstnbuted from the Social Boards of each country The Muustry of Health m England has also ducctly funded Narconon residential rehabditatiOn Nsrconon Colombia has received fundmg for services to youth The State of Utah m the Umted Slates has funded Narconon non-residential services for iuverules on probation for misdemeanor drug charges who are then court-ordered to the program
Additionally, Narconon drug education has received federal, state and local fundmg assistance m many countnes
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Narcouon drug education programs m the U S have been supported for over 30 years with contnbutions ffom corporanons aud fouadations mterested m the long -term value of this work
ln Sweden, where drug education has been dehvered m great quantity across the whole country, the Narconon staff have received repeated grants not fust ffom the government for support of admuustratrve expenses, but liom the business commumty as well, duecily toward the cost of school lectures
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Other Benefactors and Volunteers

As with other channes, non-profit associations and corporations around Ihe world, many Narconon centers are fortunate to receive support m rh fferent forms
fleset
http: //www.narconon.org/about-narconon/support.
html
12/7/2012
Support8:11-cv-01368-JDW-TGW Document 68 Case of Narconon Program
Page2of3 Filed 12/12/12 Page 44 of 47 PageID 1237

etc Tlus has
tmm volunteer agenaes, churches, avic volunteer orgmuzauons, mcluded, to give only a few examples
Pohce and other social agenaes giving close support and wotkmg hand m hand
with drug educauon teams m Sweden, Norway and other countnes
A Tmwanese Buddlust socml betterment gmup is stgmficandy funtbng and promotmg the use of Narconon rehabditauon services for adults and Juvaules m Taiw air
Catbohc sisters m Holland are fundraismg to help provide student scholarships at Narconon Zutohen
Inthgenous Maon orgamzahons operatmg expenses
m New Zealand donatmg land, faalibes and
Narconon Sweden Drug Education
Celebnties and other notables givmg then names and pubhc drawmg power to md m Narconon fundrusmg events, as wiib the many "Narconon All-Stare softball games in Hollywood, stunt shows, etc
K.=~i
Narconon Utah Juvau1e Program
Fee-For-Service and Insurance

Many Narconon centers mamtmn then viabdity and contmued production by charging fees for service ln the Umted States, where this m the norm, Narconon centers have been largdy self-supportmg for 25 years
U S insurance compames are mcreasmgly commg to recogmze the Narconon program for its long-term success rate or, to state it more accordmg to the "bottom hne," for the low recidivism and drug reversion rate achieved by Narconon graduates Because of tlus, health care funders arc covenng the umque Narconon program m steaddy gmwmg numbers.
Narconon All Stars
Support from the Church of Scientology and Its Membership

L Ron Hubbard, who developed the drug rehabditation methodology which the Narconon Prognun uulizes, was also the founder of the Scree(ology rcbgion Wlule the Narconon program ts a purely secular program which is open to members of all faiths, it has enloyed the support of the Church of Saentology attd mdividual Saentologists smce its beguuungs
In 1966, when Anzona State Pnson mmate William Bennez wrote E Ron Hubbard askmg for help, it was Saeutologtst volunteers who helped turn to set up the onipnal Narconon courses mside the pnson
~tgl
Narconoo All Stars
Narconon Tmwan
In fact, the maionty of new Narconon faahues established smce that tune have been made possible by ibe volunteer and financial support given by Scientologists
It is an unportant part of tbe Saentology religion's soaal mission to reduce the suffenng and degradation caused by alcohol and drug abuse on a worldwide scope. Saentology churches Jom churches of other faiths m seetung to improve
hvmg conditions as well as the social and moral environments m which we bve As pmt of this mission, Churches of Saentology acuvely encourage then members to support the Narconon program, by helpmg to open new centers for drug rehabditation or drug education and by volunteenng then tune to assist existmg Narconon programs
Therefore, it is common to find Saentologists &om all walks of hfe volunteenng to help the Narconon orgamzation by conductmg fundrmsmg doves, estabhshmg new centers and makmg its soluuons knovm to people m neal
The N arconon program bnngs new soluuons to the field of drug rehabditation and education to all peoples of the world Saentology Churches and Scientologists are proud to support this program
The Association for Better Living and Education
(ABLE)
http: //www.oar con on.org/about-narconon/support.
html
12/7/2012
Case of Narconon Program . Support8:11-cv-01368-JDW-TGW
Document 68
ABI.F. Is au mternimonal
non-profit, public benefit corporauon, established in lpgg, which hcenses groups usmg L Ron Hubbard's technologies m purely secular chantable programs
ABLE bcenses Narconon Intemanonal to use Mr Hubbard's drug rehabditanon snd prevention methods It also ensures that tlus technology is made avadable to
anyone who needs it and that the programs dehvered under the Narconon trademark are dehvered in accordaace hwth Mr Hubbard's specifications ABLE provides the needed guidance and tecluucal assistance to Narconon through its mtemational and contmental ollices More mfonnanon can be found about the Assocation For Better Livmg and Education by visitmg then website at www able org.
From tune to tune, Narconon centers and Narconon International itself have requested grants fiom the International Association of Sctcntologtsts (IAS) for spemfic Narconon needs The IAS has provided grants to tbe Narconon orgaruzation for such unportant prolects as the pdot mstallation of the Narconon program mside Ensenada State Fnsoa m BaIa California, Mexico, and the purchase by Narconon International of the beautiful qumters of Narconon Mediterraneo outside of Sevdle, Spam
Individual churches of Scientology have also occasionally held fundraismg benefits for local Narconon centers One such recent benefit was a chanty concert held at L Ron Hubbard's former home at Samt Hill m Sussex, England which raised donations for Narconon United Kmsdom and two other channesThe Roval National Lifeboat Institution and the Youth Trust
The Church of Scientology, the IAS, and mdtvtdual Scientologuts are among many other benefactors, mdtvidual and corporate, who have supported Narconon drug rehabditanon or prevention activines
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12/7/2012
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12/7/2012

Opposition To Toucan Motion Re Scientology

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Opposition To Toucan Motion Re Scientology

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Case 8:11-cv-01368-JDW-TGW Document 68

Filed 12/12/12 Page 1 of 47 PageID 1194

IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF FLORIDA

CASE NO: 8:11-cv-1368-T-27TGW

COUNTY. by and through

counsel, moves this

Defendant from mentioning

show that the

case and this relevance is not substantially

In support thereof, Defendant offers the following Memorandum

and Factual Background

and alcohol rehabilitation

Plaintiffs filed suit alleging violations

Housing Act and

of the Americans With of lost

Disabilities Act, for which Plaintiffs are seeking monetary

damages. in part, on a theory

Case 8:11-cv-01368-JDW-TGW Document 68

Filed 12/12/12 Page 2 of 47 PageID 1195

been able to operate as successfully

taken in the instant

case shows that there is a connection

between Scientology and Narconon

Mr Mitchell testified that Narconon International

royalty fees to an organization

run by the Church

and license fees to Narconon

and the connection to the Church

of Scientology has an effect on the ability to

attract clients in that there have been people

lns. 1-3] Mr. Mithcell also testified that the "model

"the program" at Narconon

[66 5-16] is a 'major factor in decision making for

people in where they go to treatment."

[56: 5-8]. Additionally,

between Narconon and Scientology and that this relationship

decrease demand to some people

dated Oct. 11, 2012, p

29, lns 4-22].

that the facility is a

staf1'n the program

based upon the prmciples

Excerpt from Suncoast Rehabilitation

for charitable purposes

and drug educational

services through the use

of Narconon Spring Hill, Inc]

Case 8:11-cv-01368-JDW-TGW Document 68

Filed 12/12/12 Page 3 of 47 PageID 1196

[Exhibit E-I Excerpt from Narconon

The website for Narconon International

as well as continues to do so today

[Exhibit E-2. E-3, E-4, and

Excerpt from Narconon

Website]. In particular, the website shows that Narconon

upon the principles

written by L. Ron Hubbard;

in contact with the founder

of Scientology even inviting Mr. Benitez to Hav,aii

[Exhibit E-2 Excerpt from Narconon

Website, Exhibit E-3 Excerpt from Narconon International