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Court House News: Narconon Vista Bay Being Sued

Discussion in 'Narconon' started by functionunknown, Jul 21, 2011.

Page 4 of 6

  1. Anonymous Member

    Anonymous, Jul 26, 2011
    #121

  2. RightOn Member

    RightOn, Jul 26, 2011
    #122

  3. Anonymous Member

    Narconon Vista Bay aka Narconon Watsonville is a rich target for an enterprising attorney who doesn't mind doing some research.

    Available materials include

    1. Briefing Book materials assembled by residents of Leona Valley,
    includes personal letters and details on police calls at Watsonville.

    http://www.cs.cmu.edu/~dst/Stop-Narconon/Leona_Valley/

    2. Files from the California HHS "Department of Alcohol & Drug Program" oversight office,
    including summaries and individual complaints about Narconon Northern California,
    with copies available quickly with a "California Public Records Act" request

    http://www.adp.ca.gov/feedback/feedback.shtml

    3. IRS Form 990 filings, showing incredibly overpaid executives Daniel Manson & Angie Manson,
    along with evidence of Daniel Manson's personal history committing criminal activities

    http://www.xenu-directory.net/documents/corporate/990s.php?ntt=62

    http://www.cs.cmu.edu/~dst/Stop-Narconon/Watsonville/Daniel_Manson/

    (Records more recent than 2007 are available from wources like Guidestar)

    4. Court files from Santa Cruz County describing outrageous criminal activity
    at Narconon Vista Bay

    http://forums.whyweprotest.net/threads/woh-this-is-interesting-narconon.36521/

    (Accidents and Rape cases, Links to RipOff reports, and more in the above thread)

    5. Additional research on the ground can be done, including reports of substandard
    housing conditions (County Building Department), compilation of Police Log entries
    (County Sheriff) and anecdotes from neighbors (just walk down the street and ask).

    6. The 1974 Scientology document, illustrating how Narconon is the "bridge to the bridge,"
    would be a nice finishing touch for any civil jury to see.

    http://forums.whyweprotest.net/threads/narconons-bridge-to-total-freedom-new-hubbard-doc.91981/

    I invite any readers here to forward these links and materials, to the attorney representing the plaintiff.
    Anonymous, Aug 26, 2011
    #123
    • Like Like x 2

  4. Anonymous Member

    Anonymous, Aug 26, 2011
    #124

  5. Anonymous Member

    Strangely enough, a Narconon Los Angeles has popped up again, this time in Sylmar just beyond the end of Hubbard Street.

    Narconon Los Angeles, 13850 Graber Avenue, CA (888) 819-1221
    Anonymous, Aug 26, 2011
    #125

  6. Tangerine Member

    I was pleased to see Ledyard on this: http://www.ledyard.com/

    Good luck in shutting them up. http://www.ledyard.com/pages/history.shtml
    Tangerine, Aug 26, 2011
    #126

  7. Intelligence Member

    Do you have a link to this ^^^ info :)

    .
    Intelligence, Aug 26, 2011
    #127

  8. The Wrong Guy Member

    The Wrong Guy, Aug 26, 2011
    #128

  9. Intelligence Member

    Intelligence, Aug 26, 2011
    #129

  10. The Wrong Guy Member

    The Wrong Guy, Aug 26, 2011
    #130

  11. The Wrong Guy Member

    The Wrong Guy, Aug 26, 2011
    #131
    • Like Like x 1

  12. The Wrong Guy Member


    The Wrong Guy, Aug 26, 2011
    #132
    • Like Like x 3

  13. Anonymous Member

    It's actually pretty good stuff. Unfortunately however, Kazakhstan is a dictatorship, albeit a comfortable one for its people. It's a very rich country and people have money, so they don't give a shit about being ruled by a dictator. But I can totally see Narconon arguing that a rogue legal system operated against them in Kazakhstan.
    Anonymous, Aug 27, 2011
    #133

  14. DeathHamster Member

    More Narconon (lots more in the backlog):
    DeathHamster, Aug 27, 2011
    #134

  15. DeathHamster Member

    DeathHamster, Aug 27, 2011
    #135

  16. DeathHamster Member

    DeathHamster, Aug 27, 2011
    #136
    • Like Like x 4

  17. Tangerine Member

    I just picked a name off the list: DANETTE ELLIOTT.

    Scientology Drug Rehab: Danette Elliott Sues Narconon Vista Bay for $1M, Says She Was Duped Into Church-Sponsored Program

    Source:
    http://blogs.laweekly.com/informer/2011/07/scientology_narconn_lawsuit.php

    ______________________________________________________

    http://www.courthousenews.com/2011/07/21/38330.htm

    SANTA CRUZ, Calif. (CN) - Narconon charged a woman $34,000 to treat her alcoholism, but did not inform her that the program is a recruitment tool for Scientology, and it refused to refund her money though she left after 2 days because of its "medically unsound" treatment and other misrepresentations, the woman and her husband say.

    Danette Elliott and her husband are Catholic and say they would not have chosen Narconon had it informed them of its links to Scientology. The Elliotts say Narconon misrepresented its success rate in its ads, and that Narconon and its co-defendant affiliates "are engaged in a scheme or plan to enrich themselves and to provide a recruit base for the Church of Scientology rather than to provide competent treatment for chemical dependency."

    The Elliotts sued Narconon Vista Bay, Narconon International and the Association for Living and Education International in Santa Cruz Superior Court, alleging fraud and breach of contract.
    Tangerine, Aug 27, 2011
    #137

  18. 00anon00 Member

    I believe that sums it up.
    00anon00, Aug 27, 2011
    #138
    • Like Like x 1

  19. DeathHamster Member

    Huh. This thread is invisible to the search.

    I could have saved the effort reposting the Narconon news stories.
    DeathHamster, Apr 21, 2012
    #139

  20. sofa king

    Its not the information storage, its the retreival.
    sofa king, Apr 21, 2012
    #140

  21. Jacky Blue Note Member

    When it comes to digital management of data, and although I realize some might find this to be counter-intuitive, I am for as much redundancy as possible.
    Jacky Blue Note, Apr 21, 2012
    #141
    • Like Like x 1

  22. RightOn Member

    yeah I found this thread searching on the net, not here
    RightOn, Apr 21, 2012
    #142
    • Like Like x 1

  23. Gottabrain Member

    Thanks, RightOn!

    So much WIN! :)
    Gottabrain, Apr 21, 2012
    #143
    • Like Like x 1

  24. DeathHamster Member

    Something should have happened in March, if the case is still going.

    Danette Elliott vs. Narconon, Case# CISCV 171600 - filed 07/14/2011, Case Management Hearing 03/13/2012, 8:29 AM, DEPT. 5.

    Is there a way to check that online?
    DeathHamster, Apr 21, 2012
    #144

  25. Anonymous Member

    Thatsearchfunctioniscurrentlyunavailablesorryfortheinconvenience
    Anonymous, Apr 22, 2012
    #145

  26. mammakate

    The causes of action in NN cases are typically fraud, endangerment of health, seizure of medications, and proslytization into Scientology carried out by scifag NN staff. Since these are common to most NN cases it would seem to me to be ideal for a class action suit, but IANAL. OSA is terrified of any case going before a jury and exposing NN's status as a front-group with many ties and reporting and control lines to the cult.
    Seems to me that this is the tip of the iceberg. I just removed my daughter from N. Vista Bay yesterday after she'd been there three weeks. Psychological damage, potential long term physical damage from those "cocktails"(vitamins are drugs, and CAN damage a person), misrepresenting themselves(MD? None. Therapists? None. Unless you count the extremely young kids working there as counselors...trained and licensed by themselves, not the state from what I can tell). I am truly PISSED OFF not only for my daughter but for the others who believe that this mindnumbing BS is helpful!!!! Horrible place.
    mammakate, May 3, 2012
    #146
    • Like Like x 3

  27. Anonymous Member

    Horrible! I hope your daughter - and you - are okay. What're you going to do now?
    Anonymous, May 3, 2012
    #147
    • Like Like x 2

  28. Anonymous Member

    This is why.
    Anonymous, May 3, 2012
    #148
    • Like Like x 3
    • Agree Agree x 1

  29. moarxenu Member

    First, welcome to WWP. You are among activists. We have pwned NN in Canada. We are closing them down in Oklahoma. Then Texas. Then California.

    Second, pm Intelligence, who has pwned NN in Canada, and patriot75 who is pwning NN in Oklahoma.

    Third, I would love to be in touch so would appreciate a pm. Anons in San Francisco are planning a campaign to expose NN Vista Bay.

    Fourth, are you going to file a complaint? John Hannon in Santa Cruz has handled a lot of cases. pm me for more info.

    NN_PANIC_GIF.jpg
    moarxenu, May 4, 2012
    #149
    • Like Like x 1

  30. Anonymous Member

    IRS Form 990 Filing by Narconon of Northern California for 2009
    doing business as Narconon Vista Bay of 262 Gaffey Road Watsonville CA 95076-9731
    Also identified as Narconon International of Watsonville at http://www.guidestar.org
    Tax Identification and Employer's Identification Number 77-0275827

    From $10,108.056 in Revenues reported for Narconon in Watsonville in calendar year 2009,
    payments were made to:

    Daniel M Manson
    President
    $248,902 + $9800 deferred/retirement

    Angie Manson
    Vice President
    $230,575 + $9223 deferred/retirement
    President Daniel Manson and Vice President Angie Manson are married

    Mathew Guernaccini
    Senior Director of Production
    $148,766 + $5951 deferred/retirement

    Dana Guernaccini
    Public Registration Supervisor
    $157,301 + $9,749 deferred/retirement
    Matthew Guernaccini and Dana Guernaccini are married

    Michael DiPalma
    Chief Intake Counselor and Student Intake Counselor
    $ 23,634 + $242,159 bonus/incentive
    + $9,225 deferred/retirement

    Jeffrey Panelli
    Secretary
    $123,521 + $11,649

    Juan Carlos R Ubillus
    Senior Director of Expansion
    $120,365 + $4,598

    Nathan W Tuddenham
    Senior Director Administration
    $112,727 + $9,531

    Helena Kobrin
    $14,250 Retainer for Legal Counsel
    Related to Trustee Michael Kobrin

    Trustees are Chuch Koch, Laura Blush, David Puliafico

    Directors are Jerry Nemier, Justice Edward Panelli, Scott Friend, Mary Jane Elliott Pase, and Lora French

    Director Justice Edward Panelli is the father of Jeffrey Panelli

    Kathryn L Horton
    Treasurer
    $78,439
    3233 Valencia Avenue, Units A2-A3, Aptos CA 95003 800.556.8885

    David Puliafico
    Tax Form Preparer
    Fees not disclosed on 990 form
    1630 Tennant Avenue, Morgan Hill CA 95037 408.778.1345

    Drew Hubbell
    General Contractor
    $193,401
    P O Box 8650, South Lake Tahoe CA 96158 who constructed New Rehab Facility

    Stephen M Stein MD
    Medical Doctor Services provided
    $144,000
    140 Pineridge Road in Santa Cruz

    "Return to work program" participants, 47 students, received $50 per week for a total of $18,900 in 2009

    "Narconon Vista Bay delivered 227,100 hours of drug rehabilitation services and 2,169 life
    skill courses to 386 individuals. As our final product, we graduated 195 Drug Free Lives
    Services ...there were 32,118,960 hits to the organization's internet web sites during
    the year..." (Note: 195/386 = 49%)

    The facility reported gross revenue generation of $40,034,108 for years 2005 through 2009
    ($5,114,736 in 2005, $6,330,498 in 2006, $9,778,008 in 2007, $8,723,463 in 2008 and
    $10,087,403 in 2009). An additional $50,376 in income derived from interest and dividends.

    https://whyweprotest.net/community/...bay-watsonville-2009-financial-report.101175/
    Anonymous, May 4, 2012
    #150
    • Informative Informative x 1

  31. Anonymous Member

    Information regarding Narconon Northern California (now known also as
    Narconon Vista Bay, operating at the same location on Gaffey Road in
    Watsonville) as forwarded to me (you might have to click on the thumbnails,
    to see the photos).

    A news account (Santa Cruz Sentinel May 16, 2000),
    court records and state ADP agency reports,
    state that 20 year-old Mr. Jonathan Rausch was employed
    at the Narconon facility in Watsonville, California,
    when he drove 24 year-old client Darlene M. Pentimone
    on the night of May 14, 2000.

    At about 9PM that Sunday evening, Mr. Rausch was
    at the wheel of a leased red 1996 VW Jetta, when
    "due to an unsafe movement," his car went off
    northbound State Highway 1 (near State Park Drive)
    and struck a parked California Highway Patrolmanís vehicle.

    Mr. Rausch's passenger, Darlene Pentimone, suffered
    major injuries (including a broken arm, abdominal
    injuries, and an indicated fractured pelvis) and
    was placed on life-support at San Jose Medical Center.
    CHP officer I. Troxel also sustained a moderate head injury.

    Due to findings that the defendant not only was
    "Felony" DUI but also did not have a valid California
    Driverís License and required proof of liability
    insurance, initial bail was reportedly set at $200,000.
    A later bail request noted that because his "parents
    have substantial means to post bail," it remained
    high at $100,000 as Mr. Rausch was considered a
    "flight risk." Following his guilty plea on July 7, 2000,
    Mr. Rausch was sentenced on August 10, 2000 to one year
    in County jail, 5 years probation, and a $1463. fine.

    Mr. Rausch was incarcerated in Santa Cruz County on
    November 9, 2000, when he wrote to the presiding Judge
    that "jail is a very negative place," that "I am determined
    to succeed in making better choices," and that "being
    incarcerated has opened my eyes to a lifestyle I could
    never get used to," as part of his request to the Judge
    to modify his sentence to allow him to travel home to
    New York for the holidays. At some point, Mr. Rausch was
    released to his family, and his probation was served in
    part in Nassau County, New York. (Public records list
    his mother Car-- in Oyster B-y, New York and the last known
    address for victim Darlene Pentimone was in New Jersey).

    However, a Nassau County (New York) Probation report
    described Mr. Rausch as being resistant to authority
    and not cooperative with a treatment program, and
    recommended a return of Mr. Rausch to custody.
    When Mr. Rausch did not appear for a required
    hearing in mid-2003 in Santa Cruz County, he was
    sentenced to an additional 2 years in the California
    Correctional system, and a bench warrant was issued.

    Jonathan L. Rausch, age 29, is now wanted by
    law enforcement, and any persons knowing his present
    whereabouts are asked to contact the Santa Cruz County
    Sheriff at (831) 454-2847, (831) 471-1121, or (831) 454-2311.
    Anonymous, May 4, 2012
    #151
    • Informative Informative x 1

  32. Anonymous Member

    Another accident tied to Narconon Watsonville, now also known also as
    Narconon Vista Bay at the same location on Gaffey Road, this time
    involving a dual-fatality (along with 2 seriously injured passengers)
    from later in 2000.

    (Not reported here is a related and extremely suspicious death of a relative
    of one of the victims. He worked for a Scientology entity and was planning
    to testify against Narconon, but apparently died days before scheduling a deposition).

    Complaint for Damages "Wrongful Death" of Justin Smith (Plaintiff's son)

    This case concerns the death of Justin Smith, 22 years old,
    following a July 13, 2000 collision when he drove his 1966 Mustang
    to excessive speed and it went off the road (a few hundred yards
    from the turnoff to Narcononís Watsonville facility) and hit a tree.

    Justin was a client at the Narconon facility in Watsonville,
    and the allegation is that Narconon staffer Scott Friend wrongly
    provided Justin the keys to his vehicle while he was involved
    in treatment (which enabled the accident to occur). It is not
    believed that drugs or alcohol were a factor in this accident,
    per the initial CHP repor.

    There were also 3 other persons in that vehicle, and of them
    a fellow client (Chad Skoglie, age 27) also died, and two
    Narconon staffers (Eric Petersen, age 31, and John Vereeke, age 33)
    were seriously injured.
    Chad Skoglie was the son of xxxxxxxx xxxxxxx Lxxxx Sxxxxxx,
    and a later complaint (which was consolidated into this case)
    was filed on behalf of minor children "(N)" and "(McK)"
    (regarding the loss of their relation) who resided
    with their grandmother in Idaho.

    Justin had obtained his vehicle following phone calls made to
    his mother, who had planned to remove his vehicle from a
    residential garage. Justin feared that his black 1966 Mustang,
    a prized possession, would get "destroyed" from "sitting in the
    street" near a 7-11 convenience store. Justin was in treatment
    for methamphetamine use, following unspecified legal action for
    possession (possibly of methamphetamine or paraphernalia),
    and was described by Narconon as "typical for admission (to their
    program)": "smart," "rebellious," "in denial, and in "legal trouble."

    The Plaintiff's claim was that providing car keys to an addict
    in treatment, was a violation of not only treatment rules but
    could also be seen as negligence. Narconon's attorney,
    Steven D. Werth of Low, Ball & Lynch of San Francisco,
    countered that the decedent was "negligent himself." Narconon's
    defense largely rested on a combination of "cross-complaint" legal
    filings described by the Plaintiff's attorney as being "without any
    legal or factual theory or justification" and "solely for the
    purpose of and intention to intimidate, coerce an/or deter Smith's
    pursuit of her original claim," and depositions of Narconon staff,
    (some of whom were located by private investigators after being
    transferred to a women's shelter in New Mexico, and others who
    repeated the assertion that decedent Smith had exhibited speed as
    he left the facility just prior to the accident).

    Narconon claimed that the "release of liability" signed by Justin
    when he entered his treatment program on May 8, 2000, included
    language which prevented "any legal action or litigation against
    Narconon Inc., its Board of Directors, members, employees, or
    L. Ron Hubbard arising for any reason out of my participation in
    the Narconon program."

    Staff at Narconon Watsonville in 2000 were listed as:
    Tyson Bates, Joey Burnham, John Burns, Scott Friend, Angie Manson,
    Daniel Manson, Laurie Miller, Andy Troy Moore, Lisa Moore,
    Eric Petersen, Tatsuya Sakamoto, xxxxx xxxxxx, William Starr,
    P.J. Treat, and John Vereeke. Others named (possibly clients)
    were: Ed Hocking, Frank Montara, Mr. Papastefanou, and
    Richard Prescott. A local resident who witnessed the accident
    was "Hagger."

    Eric Petersen, injured in accident, (was Narconon employee)
    Last at: Redondo Technologies, Redondo Beach CA 90277

    Smith's mother subsequently established a drug-abuse
    information program, seen at welcome to the Jason Foundation,
    which offers scholarships to students in drug counseling
    curricula, and which provides information on state legislation
    requiring training of drug counselors.

    (Excerpt from FREEDOM November-December 2005)

    It was Thursday July 13, 2000, but I remember it like it
    was yesterday. I was standing in my living room at 11:30 PM
    listening to two police officers tell me my twenty-two year
    old son had died in a car accident earlier that evening.
    My first words were, "It can't be Justin; he's in a safe place".
    It was Justin. In the weeks and months that followed,
    I learned that he had not been in a safe place. I learned that:

    In the drug addiction field there were few regulations;

    Marketing claims publicized by drug rehabilitation clinics could be unsubstantiated;

    Residential drug rehabilitation facilities could obtain state licensure by writing their own program;

    Patient recruiting and interventions could be sold on a commission basis;

    Drug addiction counselors were not required to have any formal education or training;

    Patient recruiting and interventions could be sold on a commission basis;

    Drug addiction counselors were not required to have any formal education or training;

    There were no regulations regarding length of time a counselor needed to be sober before working with clients;

    Sexual relationships between staff members and/or clients could go undisciplined;

    Alcohol and other drugs could be kept and consumed by staff on residential rehabilitation premises;

    Traffic accidents involving drunken staff and clients could go unreported to proper authorities;

    Sexual harassment and verbal abuse of staff and clients could occur without consequence;

    Even rumors of rape and sexual perversity warranted no investigation.
    I was appalled and sickened at what I heard from previous clients, staff
    and family members.
    I asked myself how I, or other parents, could have known what was going
    on behind closed doors and the answer is that we could not.
    The Justin Foundation was founded because everyone in need of
    treatment for alcohol or drug addiction should have a SAFE place to go.
    Most of us parents do not know much about addictive drugs, so
    The Justin Foundationís first task was to create a parent-friendly
    web site at The Justin Foundation offering information regarding addictive drugs.

    The second goal was to see mandatory education and training for
    drug addiction counselors. The newly enacted state regulations are
    a start. We are hopeful the newly formed CAADAC/PAC will be able to
    influence legislators to strengthen requirements.
    The Justin Foundation stands ready to support that effort and has
    agreed to serve on the Counselor Certification and Oversight Committee
    being formed by the State.

    In today's world of addiction recovery, people can be in unsafe situations
    now, so it is imperative we get more counselors that are qualified into
    the field as quickly as possible. This year The Justin Foundation started
    a scholarship fund to assist people who are committed to obtaining
    addiction counselor certification obtain a formal education.
    To insure professionalism, only CAADAC approved study programs qualify.
    Recipients receive $500.00 per semester for tuition and books, which is
    renewable as long as the student maintains a B average in six or more units.
    We were able to award two scholarships for the 2005-06 academic year.
    In 2006-07, we will award as many scholarships as we can fund.
    If you can help with this endeavor, very dollar you send will go
    directly into the scholarship fund and is 100% tax deductible.
    Anonymous, May 4, 2012
    #152
    • Like Like x 1

  33. Anonymous Member

    Reposted, from OCMB. This is reported to have occurred at Narconon
    Watsonville, also known as Narconon Vista Bay at the same Gaffey
    Road location, in 2003.

    From official case records (Victim's name and a few words deleted. Please
    do not post name of victim).

    Amended complaint for damages for negligent hiring, negligent supervision,
    failure to adequately train staff, negligence, sexual assault and battery, false
    imprisonment, intentional infliction of emotional distress, negligent infliction
    of emotional distress, conspiracy, loss of consortium, breach of contract,
    intentional misrepresentation, constructive fraud and punitive damages.

    General Allegations
    1. Plaintiff xxx is an individual, a natural person and competent adult.
    2.Plaintiff xxxx is an individual, a natural person and competent adult.
    3.For simplicity, xxx and xxxx will be collectively referred to in this
    complaint as "Plaintiffs" or by their individual names when necessary.
    4. Plaintiffs are informed and believe and on that basis allege that Defendant
    NARCONON INTERNATIONAL now is, and at all times herein mentioned was, a
    corporation organized and existing under the laws of the State of California,
    with its principal place of business located at 7060 Hollywood Boulevard, in the
    City of Los Angeles, County of Los Angeles, in the State of California.
    5. Plaintiffs are informed and believe and on that basis allege that Defendant
    NARCONON OF NORTHERN CALIFORNIA now is, and at all times herein mentioned was, a
    corporation organized and existing under the laws of the State of California,
    with its principal place of business located at 262 Gaffey Road, in the City of
    watsonville, County of Santa Cruz, in the State of California.
    6.Defendant BRETT, hereinafter referred to as JOHN DOE 1, is an individual, a
    natural person and competent adult.
    7. Defendant DAN MANSON is an individual, a natural person and a competent
    adult.
    8.Defendant STACEY PAYNE, is an individual, a natural person and a competent
    adult.
    9. Defendants Does 1 through Does 100, inclusive, are sued herein under
    fictitious names. Their true names and capacities are unknown to plaintiffs.
    When their true names and capacities are ascertained, plaintiffs will amend this
    complaint by inserting their true names and capacities herein. Plaintiffs are
    informed and believe and thereon allege that each of the fictitiously named
    defendants is responsible in some manner for the occurrences herein alleged, and
    that plaintiffs' damages as herein alleged were proximately caused by those
    defendants. Each reference in this complaint to "defendant," "defendants," or a
    specifically named defendant refers to all defendants sued under fictitious
    names.
    10. Plainiffs are informed and believe and on this information and belief allege
    that at all times mentioned in this complaint each of the defendants, including
    all defendants sued under fictitious names, was the agent and employee of each
    of the remaining defendants, and in doing the things alleged in this complaint,
    was acting within the course and scope of this agency and employment and
    ratified the acts of the other defendants.
    11. This action is filed in this county because the events that give rise to
    this action took place in this county.
    12. The following paragraphs of this pleading are alleged on information and
    belief.
    13. At all times mentioned, Defendant JOHN DOE 1 was the agent and employee of
    Defendant NARCONON OF NORTHERN CALIFORNIA and/or Defendant NARCONON
    INTERNATIONAL, and, in doing the acts herein described and referred to, was
    acting in the course and within the scope of his authority as agent and
    employee, and in the transaction of the business of Defendant NARCONON OF
    NORTHERN CALIFORNIA and/or NARCONON INTERNATIONAL committed the injurey alleged
    in this complaint. Defendant NARCONON OF NORTHERN CALIFORNIA and/or Defendant
    NARCONON INTERNATIONAL are, therefore liable to Plaintiffs for the acts of
    Defendant JOHN DOE 1.
    14. At all times mentioned, Defendant DAN MANSON was the agent and employee of
    Defendant NARCONON OF NORTHERN CALIFORNIA and/or Defendant NARCONON
    INTERNATIONAL and, in doing the acts herein described and referred to, was
    acting in the course and within the scope of his authority as agent and
    employee, and in the transaction of the business of Defendant NARCONON OF
    NORTHERN CALIFORNIA and/or NARCONON INTERNATIONAL committed the injury alleged
    in this complaint.
    15. At all times mentioned, Defendant STACEY PAYNE, was the agent and employee
    of Defendant NARCONON OF NORTHERN CALIFORNIA and/or Defendant NARCONON
    INTERNATIONAL and, in doing the acts herein described and referred to, was
    acting in the course and within the scope of her authority as agent and
    employee, and in the transaction of the business of Defendant NARCONON OF
    NORTHERN CALIFORNIA and/or NARCONON INTERNATIONAL committed the injury alleged
    in this complaint. Defendant NARCONON OF NORTHERN CALIFORNIA and/or NARCONON
    INTERNATIONAL are, therefore liable to Plaintiffs for the acts of Defendant
    STACEY PAYNE.
    16. At all times mentioned, Defendants NARCONON OF NORTHERN CALIFORNIA and/or
    NARCONON INTERNATIONAL, owned and operated an alcoholism and drug abuse recovery
    and treatment facility, hereinafter referred to as the Treatment Facility,
    located at 262 Gaffey Road, in City of Watsonville, in the State of California,
    in a secluded area of Santa Cruz County.
    17.On November 12, 2003, Plaintiffs and Defendant NARCONON OF NORTHERN
    CALIFORNIA entered into a written contract pursuant to which Defendant NARCONON
    OF NORTHERN CALIFORNIA was to provide quality drug rehabilitation in-patient
    treatment to Plaintiff XXX at the treatment Facility. "Narconon Northern
    California Drug and Alcohol Treatment Program", herinafter referred to as the
    Treatment Program, was to consist of 3-6 month inpatient treatment at the
    Treatment Facility. Pursuant to their agreement, the "drug-free withdrawal
    stage" of the Treatment Program was to be provided by a "Withdrawal Specialist"
    who is "trained in different techniques to help the person cope with the
    withdrawal period." NARCONON OF NORTHERN CALIFORNIA was also to provide 24 hour
    staff supervision by qualified and trained staff personnel, and a bonded
    security officer on the premises during off hours.
    18. Pursuant to the written agreement, on November 13, 2003, Plaintiff XXX
    enrolled in the Treatment Program at the Treatment Facility. Upon arriving at
    the Treatment Facility, Plaintiff XXX was driven to and placed for
    detoxification into a small cabin, hereinafter referred to as the Withdrawal
    Cabin, consisting of two rooms with two twin beads each; a living room
    in-between them with a couch, a futon, fireplace, and a table used for
    therapeutic massage i.e. "assists"; and a small kitchen with a stove, microwave
    and mini-fridge. The Withdrawal Cabin had no television, telephones, or cameras.
    The Withdrawal Cabin is located some distance from the Treatment Facility center
    such that Plantiff XXX was driven to the Withdrawal Cabin from the Treatment
    Facility center.
    19.On November 16, 2003, at around 10:00 p.m., Defendants NARCONON OF NORTHERN
    CALIFORNIA, NARCONON INTERNATIONAL, DAN MANSON, AND STACEY PAYNE dispatched
    defendant employee JOHN DOE 1 to care for Plaintiff XXX in her sleeping quarters
    at the Withdrawal Cabin.
    20. On the evening of November 16, 2003, Defendant JOHN DOE 1 came into
    Plaintiff XXX's room around 11:00 p.m. and woke her while she was having a bad
    dream. Plaintiff XXX got up and tried to calm down in the living room by the
    fireplace. Defendant JOHN DOE 1 then told her that she had to get an "assist".
    Plaintiff XXX told him that she did not want one. Defendant JOHN DOE 1 told
    Plaintiff XXX that she had to and that it was ordered.
    Plaintiff XXX lay on the massage table, ("assist" table) on her stomach.
    Plaintiff XXX was wearing her pajama shirt and her shorts. While giving
    Plaintiff XXX an "assist," or massage, Defendant JOHN DOE 1 began rubbing his
    penis on her arms and legs. Plaintiff XXX froze. Defendant JOHN DOE 1 then
    ordered her to turn over, but Plaintiff XXX told Defendant JOHN DOE 1 that her
    back hurt. Defendant JOHN DOE 1 then proceeded to climb on the table and
    straddle her. Defendant JOHN DOE 1 then told Plaintiff XXX that he would work on
    her back. Defendant JOHN DOE 1 then lay down on top of her, and Plaintiff XXX
    could feel that Defendant JOHN DOE 1 had an erection. Plaintiff XXX started to
    cry and asked him to "please quit."
    Anonymous, May 4, 2012
    #153

  34. Anonymous Member

    21. Defendant JOHN DOE 1 finally got off of her and told her to sit by the fire.
    Defendant JOHN DOE 1 then told her that she would have to settle down and get
    some sleep or she would "never get out" of the Withdrawal Cabin.
    22. Plaintiff XXX waited until Defendant JOHN DOE 1 went outside to smoke a
    cigarette. Plaintiff XXX then went into her room and got dressed. Defendant JOHN
    DOE 1 came back in and yelled to her asking what she was doing. Defendant JOHN
    DOE 1 then came into her room and appeared to be very upset by the fact that she
    was dressed. Defendant JOHN DOE 1 started to yell at Plaintiff XXX who became so
    frightened that he was about to attack her that she ran past him and headed for
    the door. Defendant JOHN DOE 1 caught her, stood in the doorway, and blocked the
    exit. Defendant JOHN DOE 1told Plaintiff XXX that the only way out of the
    Withdrawal Cabin was "through him." Defendant JOHN DOE 1 told her that it was
    his decision whether she would be able to go down to the main center or not.
    23. Plaintiff XXX became so upset by her confinement and so frightened for her
    safety that she pushed JOHN DOE 1, ran past him, and started running down the
    road. Defendant JOHN DOE 1 chased her, caught up with her, and grabbed her by
    the back of her hair. Plaintiff XXX fell down to the ground and Defendant JOHN
    DOE 1 jumped on top of her. Plaintiff XXX was screaming and crying. Defendant
    JOHN DOE 1 wrestled with Plaintiff XXX and overpowered her. While wrestling with
    Plaintiff XXX,Defendant JOHN DOE 1 kicked her a couple of times. Thereafter
    Defendant JOHN DOE 1 grabbed her by the face, told her to "shut-up," and ordered
    her to get back to the Withdrawal Cabin.
    24. When they arrived back at the Withdrawal Cabin Defendant JOHN DOE 1 ordered
    Plaintiff XXX to get her pajamas back on and get into bed. Plaintiff XXX changed
    into her pajamas, but sat in the living room with her comforter wrapped around
    her because she was too afraid for her safety to lie down in the bedroom,
    especially given that she was not allowed to lock the door. Defendant JOHN DOE 1
    who was still visibly angry then came over to the couch. Defendant JOHN DOE 1
    then sat down on the couch and did not say anything to Plaintiff XXX for awhile.
    Shortly thereafter, Defendant JOHN DOE 1 told Plaintiff XXX that she "had pretty
    hair" and that she "looked like an angel." Defendant JOHN DOE 1 then started
    playing with Plaintiff XXX's hair. Plaintiff XXX began to cry again, and asked
    him to stop. Plaintiff XXX
    became sick to her stomach. Defendant JOHN DOE 1 started to kiss Plaintiff XXX,
    who again asked him to "PLEASE STOP!" and told Defendant JOHN DOE 1 "LEAVE ME
    ALONE!" while crying.
    25. Defendant JOHN DOE 1 kept kissing Plaintiff XXX who kept pleading with him
    to stop. Plaintiff XXX became very ill and began to vomit. Defendant JOHN DOE 1
    became very angry again and told her to get to the bathroom. Defendant JOHN DOE
    1 then grabbed Plaintiff XXX's arm and threw her towards the bathroom. Plaintiff
    XXX vomited several times. While sitting on the bathroom floor recovering,
    Defendant JOHN DOE 1 came into the bathroom and yelled at Plaintiff XXX to get
    off the dirty bathroom floor and ordered her into the living room.
    26. Plaintiff XXX did as she was told and went into the living room. Defendant
    JOHN DOE 1 came over to the couch and started saying over and over to Plaintiff
    XXX "you know you want me," "you like this," and "you want it" over and over.
    Plaintiff XXX responded by repeating over and over "NO!" and pleaded with him to
    "PLEASE STOP!"
    27. Defendant JOHN DOE 1 then grabbed Plaintiff XXX by the arm and forced her
    over to the "assist" table. Defendant while twisting her hand bent her over, and
    then pinned her to the "assist" table with his other arm shove into herback.
    Defendant JOHN DOE 1 while pinning her on the table jerked her shorts and
    underwear down. He then let go of her hand when he forced his penis into her
    vagina and forcibly raped her. Plaintiff XXX kept saying "NO!" and begged him to
    "PLEASE STOP!" but he kept saying "you know you want me." He ordered her to "say
    it now," "you know you want me," and "you know you do." Plaintiff XXX kept
    pleading with him to "STOP!" Defendant JOHN DOE 1 then shoved her face into the
    plastic covered table, and held it there so that she could not breathe.
    28. When Defendant JOHN DOE 1 finally let go of her head, Plaintiff XXX out of
    fear for her life complied with his demand and told him what he wanted to hear.
    Plaintiff XXX while crying hysterically, said, "ok I want it." Defendant JOHN
    DOE 1 then (words deleted), let go of her, and pulled up his shorts.
    29. After forcibly raping Plaintiff XXX, Defendant JOHN DOE 1 yelled at her to
    go to the bathroom. Plaintiff XXX then ran to the bathroom and closed the door.
    Defendant JOHN DOE 1 came and opened the door to the bathroom, and told her to
    leave it open. Plaintiff XXX washed up and went into her room and got dressed.
    Defendant JOHN DOE 1 yelled for her to come out into the living room.
    30. When Plaintiff XXX went into the living room as she was ordered by Defendant
    JOHN DOE 1, it was approximately 6:45 a.m. Defendant JOHN DOE 1 was writing on
    his report papers. Defendant JOHN DOE 1 looked up at her from his writing and
    said, "You know I often worry about when I go outside to smoke that a student
    could tell me that they were going to take a shower, and they could have a knife
    from out of the kitchen, they could start the shower, and then could cut their
    wrists and they could bleed to death, and when they were found no one would know
    what had happened. They would just think that they had just killed themselves."
    He also told her that "no one would believe an alcoholic lady that wanted to get
    out of here." He said that he had written in his report that she had not slept
    at all and that they would put her in the withdrawal cabin again.
    31. That night when Defendant JOHN DOE 1 returned to the Withdrawal Cabin, he
    came into Plaintiff XXX's room at 11:30 p.m. Defendant JOHN DOE 1 turned on the
    light and sat on the bottom of her bed. Defendant JOHN DOE 1 told Plaintiff XXX
    that he had a copy of her file, that he had all of her phone numbers to her
    husband, daughter, mother, and that if she said anything, all it would take
    would be one phone call. Defendant JOHN DOE 1 said that he did not have to prove
    it to her husband, that all he had to do was plant the seed that they had
    relations and that she would be kicked out of the center and her family would
    not want anything to do with her. Defendant JOHN DOE 1 asked Plaintiff XXX if
    she understood, and she said yes. Defendant JOHN DOE 1 then left the room.
    Defendant JOHN DOE 1 came into Plaintiff XXX's room several times during the
    night. Plaintiff XXX who was very afraid for her safety would just lie there and
    pretended to be asleep.
    32. Plaintiff XXX told no one of the rape for some time because she was ashamed,
    humiliated, and frightened. In addition, she feared the effect on her husband,
    Plaintiff XXXX, if he knew that his wife had been raped. Plaintiff XXX was also
    afraid for her physical safety and her emotional well-being because of the
    imminent and very real threats that Defendant JOHN DOE 1 had made.
    33. When Plaintiff did tell the staff at the treatment Facility, Executive
    Director, Defendant DAN MANSON ratified the actions of Defendant JOHN DOE 1.
    Defendant DAN MANSON responded by isolating Plaintiff XXX in a hotel room with
    another male staff member known to Plaintiff XXX as Dave and a female staff
    member known to her as Angie. Two days later after not receiving any treatment,
    Plaintiff XXX told Dave that she wanted to go back to the treatment facility to
    finish the program. Dave took her back to the center and advised her to continue
    her program until "the 3 of us" could figure out what to do.
    34. Thereafter Defendant DAN MANSON further separated Plaintiff from other
    residents in the Treatment Program by such actions, among other things, as
    taking her to a staff apartment alone with Dave, and sending her alone to dinner
    and a movie with Dave.
    35. Thereafter, Defendant DAN MANSON advised Plaintiff XXX that he did not want
    her at the Treatment facility,and was going to move her to the Placerville
    Facility. Defendant DAN MANSON told Plaintiff XXX that if the other students
    found out, they would leave, or there would be a state investigation and that
    the staff would lose their jobs. He cried as he told her that "it could ruin
    everything that he had been working for for eight years."
    36. Defendant AND MANSON fraudulently promised Plaintiff XXX that if she went to
    Placerville and finished "two books" of the program in two weeks, she would be
    allowed to return on January 14, 2004 and finish the program at the Treatment
    facility, especially because Placerville did not have the sauna regimen that was
    included in her Treatment Program. At that time, Plaintiff XXX requested that he
    put the verbal agreement into writing. Defendant DAN MANSON told Plaintiff XXX
    that he did not want anything in writing about the situation.
    37. Thereafter Plaintiff XXX was taken to Placerville by a NARCONON employee.
    After her arrival at Placerville, Plaintiff XXX finished Book 5 and Book 8
    before January 12, 2004.
    Anonymous, May 4, 2012
    #154
    • Like Like x 1

  35. Anonymous Member

    38. On January 12, 2004, Defendant STACEY PAYNE, Executive Director of the
    Placerville Facility, also ratified by DAN MANSON, called Plaintiff XXX into her
    office and told Plaintiff XXX that she did not feel that Plaintiff XXX should go
    back to the treatment Facility at all. Plaintiff XXX explained that she had made
    a deal with Defendant DAN MANSON that if she finished 2 Books in 2 weeks, then
    Plaintiff XXX could go back to the Treatment facility and finish her Treatment
    Program. Plaintiff XXX explained that she had completed the 2 Books in ten days
    as agreed. Defendant STACEY PAYNE told Plaintiff XXX that she and Defendant DAN
    MANSON had decided that they did not want Plaintiff XXX at the Treatment
    Facility anymore. Plaintiff XXX also explained that she needed to get back to
    the Treatment facility, because she had a planned visit from her cousin there on
    January 17, 2004.
    39. Thereafter Plaintiff XXX was taken to Watsonville by a NARCONON employee
    known to her only as Paul. Upon arrival to Watsonville, however, the employee
    did not take Plaintiff XXX to the Treatment Facility as Plaintiff XXX was told
    would happen. When Plaintiff XXX inquired, Paul told her that Defendant DAN
    MANSON had instructed him not to take her back to the center but to a hotel
    instead. Plaintiff XXX was forced to call her husband Plaintiff XXXXand ask him
    for a credit card to pay for a room.
    40. Plaintiff XXXX was very distraught and upset that his wife Plaintiff XXX was
    not at the Treatment Facility.
    41. The next day Plaintiff XXX called Defendant DAN MANSON and asked him what
    was going on, and why she was not taken to the Treatment Facility. Defendant DAN
    MANSON told her that they had a lot of new arrivals at the Treatment Facility,
    and that there were no beds left for her. Plaintiff XXX told Defendant DAN
    MANSON that they had a deal. Defendant DAN MANSON responded by telling her that
    they would talk later, after her visit with her cousin.
    42. A few days later, Plaintiff XXX called Defendant DAN MANSON and told him
    that she needed to talk to him to resolve the situation, especially in light of
    the fact that her husband Plaintiff XXXX was growing increasingly worried.
    Defendant DAN MANSON told Plaintiff XXX that he would send someone to pick her
    up, and bring her to the treatment facility for a meeting with him.
    43. A short time later Defendant DAN MANSON called Plaintiff XXX and told her
    that he did not want her at the Treatment Facility, and that he would come to
    see her at the hotel. Plaintiff XXX asked why, and Defendant DAN MANSON
    responded that it was not a good idea for her to be seen at the treatment
    Facility.
    44. An hour later, Defendant DAN MANSON came over to have a meeting with
    Plaintiff XXX. Defendant DAN MANSON told Plaintiff XXX that there was no room
    for her at the Treatment Facility, because her old room had been filled.
    45. Defendant DAN MANSON then put in front of her, a Mutual Release of All
    Claims, hereinafter the Release. Defendant DAN MANSON told Plaintiff XXX that he
    would not allow her to finish the Treatment Program at either center unless she
    signed the Release. When Plaintiff XXX asked why he was making her sign this,
    Defendant DAN MANSON told her that his lawyers needed the paper signed for
    Narconon's protection. Plaintiff XXX did not sign, but told him that she would
    look over the document. Plaintiff became very agitated and cried after he left.
    46. Thereafter, Defendant STACEY PAYNE showed up to pick up Plaintiff XXX and
    take her to the Placerville Facility. Defendant STACEY PAYNE told Plaintiff XXX
    that Defendant DAN MANSON had sent her to deal with her and "deal with her she
    would." Defendant STACEY PAYNE told Plaintiff XXX that she did not have a choice
    anymore. Plaintiff XXX told Defendant STACEY PAYNE that they were just trying to
    hide her and the incident. Defendant STACEY PAYNE told Plaintiff XXX "yes," and
    that she, stacey, knew what was best for her. Plaintiff XXX was forced to go
    with Defendant STACEY PAYNE because she had no other place to go and no money.
    47. During the ride to Placerville Defendant STACEY PAYNE told Plaintiff XXX
    that some other students had tried to sue NARCONON before after a car accident
    where some students had died, but that NARCONON would not pay them anyway so
    that she should not even think about coming after NARCONON.
    48. Thereafter, Plaintiff XXX told Defendant STACEY PAYNE that she needed
    medical attention. Plaintiff XXX was very concerned for her health because
    Defendant JOHN DOE 1 was a known needle-user. Defendant STACEY PAYNE told her
    that she would only allow her to receive medical attention if she went to a
    nearby clinic. Plaintiff XXX told Defendant STACEY PAYNE that she wanted to go
    to her own doctor, but Defendant STACEY PAYNE told her that would not be
    allowed.
    49. Thereafter, Defendant STACEY PAYNE told Plaintiff XXX that she would only
    allow Plaintiff XXX to receive medical attention if she requested a leave of
    absence from the program. Plaintiff XXX was forced to sign some paperwork saying
    she was taking a leave, would check in everyday, and would return in four days.
    50. Thereafter, Plaintiff XXX learned that she had contracted a venereal disease
    and would require further treatment. Plaintiff XXX advised STACEY PAYNE by
    telephone that she would not be returning to either facility because she needed
    further medical treatment from her doctor, and because of NARCONON OF NORTHERN
    CALIFORNIA's gross mistreatment of her.
    51. Thereafter, when Plaintiff XXX returned to pick up her personal belongings,
    Defendant STACEY PAYNE requested that Plaintiff XXX sign a paper saying that she
    was leaving at her own free will. Plaintiff XXX refused to sign, and requested
    her file. Defendant STACEY PAYNE told her that she could not have her file, and
    that she could request it later from NARCONON
    INTERNATIONAL.
    52. Plaintiff XXX also requested information on Defendant JOHN DOE 1's medical
    history and Defendant STACEY PAYNE refused. Plaintiff XXX remains in extreme
    fear of her health and safety because Defendants have refused to disclose
    Defendant JOHN DOE 1's medical history.
    Anonymous, May 4, 2012
    #155

  36. Anonymous Member

    53. Plaintiff XXX incorporates and realleges Paragraphs 1-52 of this complaint
    as if fully set forth herin.
    54. Devendants NARCONON OF NORTHERN CALIFORNIA and NARCONON INTERNATIONAL are in
    the business of providing residential alcohol and drug abuse recovery treatment
    services. Necessarily, Defendants NARCONON OF NORTHERN CALIFORNIA and NARCONON
    INTERNATIONAL deal with adults who are experiencing personal instability and a
    lack of control over one's environment as associated with drug and/or alcohol
    addiction, and who rely on Devendants NARCONON OF NORTHERN CALIFORNIA and
    NARCONON INTERNATIONAL in finding a "new way to live."
    55. In view of the relationship of trust imposed by this circumstance and by
    law, Defendants NARCONON OF NORTHERN CALIFORNIA and NARCONON INTERNATIONAL owed
    a duty to its residents to protect them from harm to their persons or property
    at the hands of employees who are entrusted with their care and given access to
    their sleeping quarters, medical records, and personal information.
    56. Defendants NARCONON OF NORTHERN CALIFORNIA, NARCONON INTERNATIONAL, DAN
    MANSON and STACEY PAYNE negligently hired and entrusted Defendant JOHN DOE 1
    with the care and supervision of Plaintiff XXX, particularly by dispatching him,
    a recent patient, to care for her during the withdrawal stage, and allowing a
    male staff to be alone with a female student/patient in her sleeping quarters.
    57. Defendants NARCONON OF NORTHERN CALIFORNIA, NARCONON INTERNATIONAL, DAN
    MANSON, and STACEY PAYNE breached their duty to exercise reasonable care and
    acted negligently and carelessly in the screening, hiring, retaining,
    supervising and training Defendant JOHN DOE 1 as an employee, especially in
    prescribing a touch assist procedure between male staff and a female
    student/patient, a practice that is known to lead to improper sexual contact.
    58. At all relevant times to this complaint, Defendants NARCONON OF NORTHERN
    CALIFORNIA, NARCONON INTERNATIONAL, DAN MANSON and STACEY PAYNE knew or should
    have known that Defendant JOHN DOE 1, a recent former student/patient, was not
    competent to provide the services necessary to meet the resident needs, and in
    so doing further breached their statutory duty pursuant to California Health and
    Safety Code 11834.01 and 11834.10 to provide competentpersonnel, and personnel
    in good health, capable of performing assigned tasks and services without
    physical or verbal abuse, exploitation or prejudice.
    59. At all times mentioned in this complaint, Defendants NARCONON OF NORTHERN
    CALIFORNIA, NARCONON INTERNATIONAL, DAN MANSON and STACEY PAYNE, and each of
    them, were aware of and should have known the probable consequences of hiring
    former students/patients inadequately trained in the care and treatment of drug
    and alcohol abuse clients, to work at Narconon facilities directly with present
    students/patients, and that such practice endangers the sagety, health, and/or
    physical and mental well being of Narconon clients.
    60. At all times mentioned in this complaint, Defendants NARCONON OF NORTHERN
    CALIFORNIA, NARCONON INTERNATIONAL, DAN MANSON and STACEY PAYNE, and each of
    them, were aware of and should have known the probable consequences of directing
    touch "assists" procedures between male staff and female patients in a private
    room in leading to improper sexual contact.
    61. At all relevant times to this complaint, Defendants NARCONON OF NORTHERN
    CALIFORNIA, NARCONON INTERNATIONAL, DAN MANSON and STACEY PAYNE knew or should
    have known that Defendant JOHN DOE 1 was totally unfit for a position that
    required knowledge and implementation of alcohol and/or drug recovery principles
    in tha Defendant JOHN DOE 1 was using drugs and/or alcohol while in the course
    and scope of his employment, had a history of drug and alcohol abuse, a criminal
    record, and a tendency to commit criminal acts in violation of the rights of
    others and the penal code, and in so doing further breached their statutory duty
    pursuant to California Health and Safety Code 11834.01 and 11834.10 to provide
    cometent and adequately trained staff.
    62. As a proximate result of the acts and omissions of Defendants NARCONON OF
    NORTHERN CALIFORNIA, NARCONON INTERNATIONAL, DAN MANSON and STACEY PAYNE,
    Plaintiff XXX has suffered physical injuries, pain and suffering, severe mental
    and emotional distress in the past, and will continue to suffer severe mental
    and emotional distress in the future.
    63. Plaintiff XXX is entitled to punitive damages because the managing agents of
    Defendants NARCONON OF NORTHERN CALIFORNIA, NARCONON INTERNATIONAL,had advance
    knowledge of the unfitness of Defendant JOHN DOE 1 and employed him with
    conscious disregard for the rights and safety of others.
    64. Plaintiff XXX is further entitled to punitive damages because Defendants
    NARCONON OF NORTHERN CALIFORNIA, NARCONON INTERNATIONAL, DAN MANSON and STACEY
    PAYNE had advance knowledge of the inappropriateness of dispatching male staff
    to care for female student/patient alone in closed quarters, and that the
    prescribed touch assist procedure could lead to improper sexual contact.
    65.Plaintiff XXX is further entitled to punative damages because Executive
    Directors, Defendants STACEY PAYNE and DAN MANSON, of Defendants NARCONON OF
    NORTHERN CALIFORNIA and NARCONON INTERNATIONAL each acted with malice,
    oppression, fraud, and ratified the wrongful act of employee Defendant JOHN DOE
    1 by refusing to provide medical care to Plaintiff XXX after the rape,
    segregating her from other patients, intimidating her to not report the rape,
    and further acted in callous disregard for her safety and well-being by refusing
    to perform the agreed rehabilitation services without a signed Release by
    Plaintiff XXX.
    Wherefore, Plaintiff XXX demands judgment against defendants, and each of them,
    in an amount according to proof, plus interest and costs, as more fully set
    forth below.
    Anonymous, May 4, 2012
    #156
    • Like Like x 1

  37. Anonymous Member

    According to an investigation of the "credibility" of Narconon (by a task group affiliated with the Leona Valley Town Council of Los Angeles County in 2006), records indicated that Narconon Watsonville (also known as
    Narconon Vista Bay at the same location on Gaffey Road)\ received many notices of violations (from the California Alcohol and Drug Programs oversight office and other agencies):

    Notice of Deficiency 11/17/04:
    Failure to test employees for TB
    Addicts not tested for TB
    Mold found in bathrooms
    Beds without mattresses
    Facility not being maintained properly

    Notices 6/30/04, 8/5/04:
    Addicts being housed (male and female) without adequate facilities to allow for privacy
    (Related to the rape complaint)

    Fire Department Inspection Discrepancies 7/6/2004:
    Empty fire extinguishers
    Extinguishers not serviced
    Excessive use of extension cords
    Loose wiring/missing outlet covers
    GIF not functioning
    Fire hydrant shut off with valve overgrown with weeds
    Smoke detectors not functioning
    Weeds around propane tank and inaccessible for inspection
    Weeds around pool pump
    Flammable vegetation on roof

    Notice of Deficiency 6/15/2004:
    Failure to test addicts for TB
    Detox services without CPR/First Aid certified personnel available
    Food not being refrigerated properly
    Obstructions in passageways
    Facilities not clean, safe and sanitary
    Unclean bathing facilities
    Food not stored properly
    Overgrown weeds on pathways
    Code of Conduct: No mention of personal relations with addicts
    Participants rights not posted

    Notice 4/23/2004
    Staff member having sexual relations with addict
    Staff member not dismissed per Narconon policy after having sexual relations
    Staff member caught drinking with another staff member but not dismissed,
    as required by Narconon policy
    Dirty/Stained bed linen (allegation said it was blood)
    Food debris on kitchen floor
    Mold on windows, ceilings, showers
    Sinks and tubs covered with white residue
    Dirty/stained toilet, toilet with odor
    Debris on bathroom floors, counters, dirty cabinets
    Peeling paint, broken tiles in several bathrooms
    Spider webs throughout facility
    10:30am breakfast spilled milk, cereal still not cleaned up
    4:30pm dining area tables still not wiped down/sticky tables
    Inadequate staff coverage in evening hours

    Notice 2/10/2004
    Providing care without license
    "The facility was housing adolescent lames, 14-18 years old at a housing
    facility that was not licensed under the Watsonville treatment location.
    The adolescent males were being transported to/from the Watsonville
    facility for day treatment."

    Notice 11/18/2003
    Failure to test employees for TB
    Not health screening employees
    Addicts not tested for TB
    First aid manual missing
    No medication control log
    24 beds without mattresses

    Notice 9/30/2003
    Facility not clean and in good repair
    Smoke detectors not operational
    Improper food preparation
    Improper medication control procedures
    Improper notification to ADP on property use
    No notification to ADP on change of directors

    Notice 2/14/2003
    Two staff members left facility with addict and went drinking

    Notice 10/30/2001
    Blank admission agreement
    Blank discharge summary
    No treatment documentation
    Client not receiving copies of admission docs

    Notice of Deficiency 4/9/2001
    Staff member facilitated sexual rendezvous with other staff member and addict
    Facility administrator was found to be incompetent to evaluate and terminate staff
    Deficient TB testing for employees
    No duty statements for employees
    Electrical cord/trip hazards
    Food/debris in dining area
    Peeling paint/broken screen door
    Exposed wires
    Obstruction of doorways by equipment
    Heater vents missing
    Broken door knobs/latches
    Electrical code violations
    Broken window blinds
    Windows covered with wood and duct tape
    Fire detector without batteries
    Fire extinguisher thrown under table
    Holes in window screens
    Cardboard box filled with barbage and emitting odor
    Mattresses and sheets missing from beds
    Dirty mattresses
    Stained linen

    Notice of Deficiency 11/15/2000
    No TB tests for employees

    Dates of Investigation 8/10/2000 and 8/22/2000
    Traffic collision involving two employees and two addicts

    "Employees and addicts took an unsponsored excursion in the addict's vehicle
    resulting in a collision which killed both addicts and severely injured the employees.
    Although this was found not to be the responsibility of Narconon, it does emphasize
    the behavior that can be found at the facility. It was found that staff was inadequate
    and did not meet training requirements (staff are allowed personal vehicles on the
    property)."

    Notice 5/14/2000
    Narconon employee, driving drunk, crashed into a CHP car and injured the
    officer. Employee was arrested and booked for DUI.

    Notice of Deficiency 11/2/1999
    Employees not screened for TB
    Anonymous, May 4, 2012
    #157

  38. Anonymous Member

    Even more shocking (but not yet transcribed), are descriptions of activities at Narconon of Watsonville,
    (also known as Narconon Vista Bay in the same Gaffey Road location) found in the memoranda and other correspondence with the state ADP, as linked below.

    Here, a parent of a Narconon client stated she had filed a request for an investigation of Narconon
    Watsonville on April 8, 2000, which wasn't assigned to an investigator until August 7, 2000
    (after 2 serious vehicle accidents had occurred in the interim, on May 14th and July 13th, 2000,
    with the second accident resulting in serious injury of her son, and deaths to other Narconon clients).

    This report also alleges "illicit sexual activities" with a client by the "Senior Director of Administration"
    Joey Burnham (who was on "ethics review" but wasn't fired, weeks after a report about his actions was filed).

    Page Link:
    http://www.cs.cmu.edu/~dst/Stop-Narconon/Leona_Valley/credibility/tab15/

    Image Links:

    http://www.cs.cmu.edu/~dst/Stop-Narconon/Leona_Valley/credibility/tab15/t15-p01.jpg

    http://www.cs.cmu.edu/~dst/Stop-Narconon/Leona_Valley/credibility/tab15/t15-p02.jpg

    This memo, alleges the dual-fatality accident of July 13,2000, occurred after a Narconon client
    (instead of an employee) was asked to go to the store to pickup up supplies for that facility!

    http://www.cs.cmu.edu/~dst/Stop-Narconon/Leona_Valley/credibility/tab14/t14-p02.jpg

    Page 2 of that memo, stated Narconon Staffer Eric Peterson had an "8th grade" education,
    alleges a connection between Narconon Watsonville and Narconon Newport Beach:

    http://www.cs.cmu.edu/~dst/Stop-Narconon/Leona_Valley/credibility/tab14/t14-p03.jpg

    This ties Eric Peterson, to Narconon at Chilocco in 1994:

    http://www.cs.cmu.edu/~dst/Stop-Narconon/Leona_Valley/credibility/tab11/t11-p03.jpg
    Anonymous, May 4, 2012
    #158

  39. Anonymous Member

    Narconon has been accused of hiring practices that include ex-clients, who were
    addicts themselves with criminal histories (like the alleged rapist Brett Lengstorf).

    One person pictured on the Facebook page, is Stacey S. Payne.

    Stacey Payne was described in an interview, as a Director
    of the Narconon facility in Placerville, California --
    a satellite facility of the troubled Narconon of Watsonville, CA.
    (This can be found online, by searching for the text of the
    Placerville Mountain Democrat article of November 14, 2003)

    Could she be an example, of questionable hiring practices at Narconon?

    Although the article mentioned her past as a drug user who
    faced jail time, it did not indicate the full nature of her actions
    (before she was hired to use aspects of the Scientology
    "Purification Rundown" to do what is described as indoctrination of
    drug addicts into the "spiritual" rituals of the religion of Scientology).

    Stacey Suzanne Payne was cited by police in Long Beach, CA
    on July 2, 2000 for one count of possession of cocaine and another
    count for possession of a smoking device (in combination with a
    co-defendant "Bxxx Exxxx Kozlow," in Citation #011513476).
    Arrest citation stated she was then age 35, 5'3", weight 160 lbs.

    Although a $10,000 bail bond was posted on July 5th, when Stacey
    pled not guilty, it was forfeited to the court on October 10, 2000,
    for a failure to appear. Stacey was subsequently booked and released
    pending further court action, on October 23rd, and was sentenced
    to 18 months probation for her felony conviction on November 16, 2000.
    (Criminal Case NA045638-02 at Long Beach Superior Court)

    Very shortly thereafter, Stacey was arrested again on November 28, 2000,
    for possession of cocaine at 10xx Perry Street in Wilmington.
    In the police report, officers stated they were conducting a follow-up
    investigation on reported stolen property at that address.
    When they searched a white and blue 1989 GMC van, they found a
    "clear plastic container" containing "thin off-white wafers" of cocaine.
    Booking report mentioned Stacey had distinguishing characteristics"
    of a picture on her right shoulder (of a sun and a star).

    Perhaps the stimulants affected her eating habits, as she then weighed
    142 lbs., but her bail ballooned to $50,000 on this second felony charge.
    Once again, Stacey didn't appear in court for a scheduled appearance
    on February 1st, 2001, and she fired her attorney William Rawson of
    Palos Verdes. About this time, she had entered the Narconon program in
    Watsonville in Northern California.
    (Criminal Case NA047528-01 at Long Beach Superior Court)

    Stacey's behavior became a concern to her adoptive brother Txxx and
    mother Axx. In a court request for a restraining order, filed near
    Temecula, California on February 13, 2001, her brother Txxx wrote;

    "On January 24, 2001, my sister Stacey Payne called the house and
    became hysterical and verbally abusive. On the telephone, she told me
    that 'you're going to find yourself dead soon, and I know the people
    to do it.' "

    Txxx described Stacey Payne as "a convicted crack addict" who had
    "been living on the streets and associating with drug dealers, users
    and prostitutes."

    Txxx also related an earlier account of April 2000 when Stacey brought
    a man with a gun to her mother Axx's home (described as appearing to
    be Stacey's drug supplier) who then coerced Axx to writing a check
    for a "repayment of her drug debt" and forced Axx to go to the bank to
    confirm that the cash was valid to be cashed. Txxx indicated that he
    had moved into his mother's home to provide her with protection from
    Stacey, and had continued to receive verbal threats from her.
    (Riverside County Court Case TEV001635)

    Stacey reappeared in court on April 20, 2001, and her jail sentence
    was stayed to September 7th, 2001, to allow her to complete the
    program at Narconon in Watsonville. Letters to her probation contact
    (from Narconon Northern California legal liason Will Pritchard),
    indicated that Stacey's primary drug of choice was "crack cocaine."
    Will later noted that Stacey Payne completed the Narconon program on
    May 19, 2001, and was offered a staff position immediately, starting
    May 20, 2001, as part of an employment contract for the following
    30 months (2 1/2 years).

    The next known public mentions of Stacey Payne were in association
    with the Narconon Watsonville facility (where she had become a
    staff member, then an officer), in a news article of November 2003.
    Tragically, this appeared the same week that a woman client at the
    Narconon Watsonville reported being raped under coercion
    (by Brett Lengstorf, another Narconon staff member who had a
    drug habit and a criminal background).

    Papers from a civil case following the rape, indicate that Stacey Payne
    made statements to the rape victim discouraging her from reporting
    the incident, refused the victim access to be seen by her own doctor,
    and quoted Stacey as saying she would "deal with her" (meaning,
    the rape victim) at the Narconon facility in Placerville.
    (Santa Cruz County Civil Case CV149221, details are listed below)

    As "Senior Director of Expansion" for Narconon in Northern California,
    Stacey Payne was listed in that organization's annual IRS form 990
    tax reports, as having been paid annual salaries of
    $86,436 (in 2003), $55,433 (in 2004), and $80,605 (in 2005).
    (http://www.xenu-directory.net/documents/narcononint-watsonville-990s.html)
    Anonymous, May 4, 2012
    #159

  40. Anonymous Member

    Rip Off Report: By Consumers, For Consumers Narconon - Vista Bay Drug Rehab Reached out for help and was told my family disowned me Watsonville California Placerville California

    After trying to rehab myself for two years, I finally asked my family for help. My brother and sister-in-law made it possible for me to go to a long term rehab. I looked on the Internet for months until I found a referral number that we thought would give us more choices and find exactly what we were looking for. When I say we, I mean what my family wanted and felt was the right place for me and what I needed in all facets, emontional, physical, mental, medical and what made me feel safe. I was already educated on the text book drug addict. What I was looking for was a program that learned about me and helped me regain my self esteem, confidence and went the extra mile to make me feel I could do this. I had never asked for help and this was hard for me to let my family know I was a failure in many ways. My family was there for me in more ways then I could ever imagine.

    When we recieved our first phone call I was greeted by a happy woman who made feel good. She said she was from Narconon in Southern CA. We chatted for a while as I asked every question I could think of. I basically said what is the day in the life of being in your facility. This is what I want, need and expect. Every question I asked was answered with yes, thats exactly what we do. Then told that each person had there program designed to fit there needs as we all have different reasons and our own stories. My brother wanted me closer to his home, he said how about Nothern CA. I was told they have one in Watsonville and givin a number and name of a man who never emailed my brother back. He was sceptacale at first until he finally recieved an email. I myself recieved many emails and phone calls from Narconons all over the US. I just thought they cared.

    When I talked to someone from Vista Bay I asked if the program was the same and was told yes, we have Narconons all over the World. On there website it said there was a 24 hr nurse onsite and showed some of the pics from the facility. I asked "Do you really take us shoping twice a week to get personal products and things we may have forgot", that's what it stated on the website. I was told yes we do. that way you don't have to lug so much and your sure to get what you need. I was told that we all get a complete physical from there Doctor and that they were Certified Drug Rehab Consolers. There was a exercise program and a sauna program.

    On April 21,2007 I was to Vista Bay, only when I arrived it was not what I was told. I was asked questions by an Ethic's Officer if I or any member of my family have every said anything about Narconon or L Ron Hubbard. I said one family member doesn't seem likehe likes LRH, but you'll have to ask my family and what does this have to do with rehab? He just kept asking more questions and I just went a long with it.

    By my first week in Book One "Theraputic Routines" HA HA, they mean Training Routines (TRs) Can you imagine people just off drugs for a few days being told to sit 3 feet in friont of another student (that's what were called) and stare at them for up to 1 hr, without moving or even looking away, for a pass to go to the next crazy step. Bullbaiting...to flaten ones buttons... I was hearing the most vulgar words out of people to get that person to move or flinch. I stoped at one point and told a young man if I hear those words again I will wash your mouth out with soap, there are ladys present in this room.

    Well off to the sauna program after a week and a half of more rude and strange things. I was never told about the Niacin we were to take and how it would effect us. It burns, turns your body red and then itches. We start at 100mg and go to up to 5,000mg. Sweat for up to 5 hrs a day and take. There were so many people in the sauna by the time I started that part of the program we were stuffed in like sardines.

    They have what theyt call Knowledge Reports (KR). I was told by a friend that I started the program with that Mr X came out of his room and said in front of a dozen people to start writting KRs on Mr Z and myself that we were taking off into the woods doing what ever you can think of, Mr X hated Mr Z and wanted him kicked out for good. I went to the Ethics office and said what in the H*** is going on here? This is not high school this is my life I'm old enough to be some of these kids mother. Nothing was ever said again to me but I don't believe anything was said to the people who wrote these reports. I could have been kicked out for good after 3 weeks.

    I kept asking when do I get to meet my Drug Consolor. I was told that they all were consolors and the one on one consoling was with another student.

    I went to Placerville there other facility. I worked very hard to get through the program because it was all I had and my family put $29,000. I hade some other problems that made it hard for me to concentrate and back then even read a book. There were a couple of great people there who helped me and took the time to listen. Thank you S and J. I hated what I was learning because I didn't believe in most of it and as the Books got higher , they were so weird it seemed unreal. I thought the person who wrote this stuff must have been losing his mind. All the books said on the cover the works of L R Hubbard. I even asked if LRH or Scientology had anything to do with the program, I was told LRH helped write some of the text. I never asked if the Church owned it, just if it was the same beliefs.

    I was to do these drills that were very hard for me to do because of me being unable to concentrate. I tried very hard and kept tring but when it became to hard and I felt worse then when I arrived, I had to stop. I asked for help but was yelled at and followed around like I was someone who wanted to destroy there program and couldn't be trusted. I know this sounds wierd it did to me when it started, I almost started to laugh and say "your kidding, right". Then I realized they weren't. I had asked to call my brother the whole day and was told wait a minute or let me finish this. I asked the director if I could use the phone and he said he would take care of it. After the day was almost over finally someone came me and said come on in the office. I thought my brother was on the phone but was told he didn't want to talk to me or have anything to do with me, I wasn't aloud in my familys homes and that was that. All I could think is that my family disowned me. I was then told they would take me to a Bus Station, Airport or Homless Shelter. My family lived 3 hours from there, I had no cell phone and only a little bit of cash in the bank. I had to leave 3/4 of my things there as I couldn't bring them on the Bus with me. I didn't know what to do or where to go. That was on Oct.4,2007. About 2 months later I tried to kill myself because I thought my family disowned me.

    There is not enough staff to help, they are over the 40 people limit by there License, they rent houses and Apartments for people to live in then bus them in everyday. It's all about money. Long Beach Narconon in CA is losing there licsense for most of these violations. One is that they bus people in to use the sauna with the in patient residents. Vista Bay does the same thing and it's also located in the Mountians, if there was a fire who would they get all these people out safely?

    Sasha
    Brooklyn, New York
    U.S.A.
    Anonymous, May 4, 2012
    #160
    • Like Like x 3
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