10A28641 2 2010-11-05 DepositionOfLisaRobbinsMD Ocr

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LISA ROBBINS, M.D. 11-5-10 Desmond, et al. vs. Narconon, et a l .
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APPEARANCES OF COUNSEL:
ON BEHALF OF TilE PLAINTIFFS:
REBECCA FRANKLIN, ESQ.
Franklin. Law, LLC
1170 Peachtree Street
Suite 1200
Afllmta, GA 30309
(404) 961-5333
( 404) 969-4503 (fax)
Rebecca@FranklinLaw.org
ON BEHALF OF DEFENDANTS NARCONON OF GEORGL\ and
NARCONONINrERNATIONAL:
KATHRYN'S. WHITLOCK, ESQ.
Drew, Eckl & Farnham, LLP
880 West Pcacb!rce S!reet
P.O. Box 7600
Atlanta, GA 30357
(404) 885-1400
(404) 876-0992 (fax)
ky,futlock@deflaw.com
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ON BEHALF OF THE DEFENDANr DELGADo DEVELOPMENT:
MELANIE C. EYRE, ESQ. {Via Telephone}
Belli, Weil, Grozbean & Davis
8010 Road
Suite 200
Atlanta, GA 30350
(770) 993-3300
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INDEX TO TESTIMONY
By Ms. Franklin.......................... ........ 6
By Mr. Bartlett .................................. 106
By Ms. Eyre ............................. ....... 108
By Mr. Tanner .................................... 109
INDEX TO EXHIBITS
PLAINTIFF'S DESCRIPTION PAGE
EXHIBIT
NARCANON of Georgia Organizatiooal
Chart ....... .......... .......... ...... 9
2 NARCONONProgramDescription .......... 10
3 ApplicationforaUceoseto Operate
a Drug Abuse Treatment and Education
Program ................. .............. 11
4 New Life Detoxification Program
Discharge Summary and Transfer Fonn ... 14
5 :,tealth Care Provider Agreement. 15
6 Medical Director Agreement ......... 38
7 Memo on Vitamin Aclminitration for the
New Ufc Detoxification Program
(Sauna and E.xercise Program)........... 56
8 Medical Report ..................... .. 70
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9 Pur.().Qeanse Medical Release Consent ii
Form .......... ....................... . 94
10 Application for a License to Operntc
a Drug Abuse Treatment and Education
; ! Prognun. ......................... ...... 96
11 CVofDr.LisaC. Robbins,M.D ......... !OO
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ONHEHALF OF DEFENDANTS SOVEREIGN PLACE and
SOVEREIGNPLACEAPARTMENTMANAGEMENT: .
SHANE BARTLETT, ESQ.
Webb, ZSchunke, Neary & Dikeman, LLP
One Securities Centre, Suite 1210
3490 Piedmoot Road, NE
Atlaota, GA 30305
(404) 264-1080
sbartlett@wmd. net
ON BEHALF OF DEFENDANTS LISA CAROLINA ROBBINS, MD.
and THE ROBBINS GROUP, INC.:
ROBERT G. TANNER, ESQ.
Weinberg, Wheeler, Hudgins, Gunn & DtU
3344 Peachtree Road
Suite 2400
Atlanla, GA 30326
(404) 876-2700
(404} 875-9433 (fax.}

ALSO PRESENT:
ROSEMARY BILEIJ..O, Videographer
Legal Technology Services
4470 Atlanta Highway
Suite A
Log;mville, Georgia 30052
(770) 554-1633
(770) 554-6298 (fux)
www.ltsatlanta.com
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(mE FOILOWll'!G 1RANSCRIPT CONTAINS QUOTED :MATER.JAL; SUCH
MATERIAL IS REPRODUCED AS READ OR SPOKEN.)
(INTiffiFOLLOWINGTRANSCRIPT,ADASH[ -] IS USED TO
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SPEECH ORAN UNFlNISHED SENTENCE lN DIALOGUE, ORAN
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(Thereupon, the court reporter disclosed that she v.>as
there on behalf of Q & A Reporti ng Services, Inc. In
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of the Board of Court Reporting and O.C.G.A. 15-14-37(3.)
and (b), the court reporter discloses t hat she was
retained by Harris, Penn & Lowry to take down the
proceedings. Q & A Reporting Services, Inc., will charge
the attorneys the U3Ual and customary rate for the
transcript and will be paid by the attorneys upon their
receipt of the transcript)
,... 1 r
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Q&A REPORTING SERVICES ,
404.233.3300 ** JFischer @QAReporti n g . com,

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LISA ROBBINS, M.D. 11-5-10 Desmond, et al. vs. Narconon, et al.
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PROCEEDINGS
---
TilE VIDEOGRAPHER: This begins tape number
1. We're now on video record. Today's date is
Kovember 5th, 2010. The time on the video
monitor is 3:08p.m.
MS. FRANKLIN: Sharon, will you please swear
in the witness.
-- -
LISA CAROLINA ROBBINS, M.D.,
having been first duly sworn, was examined and testified
as follows:
EXAMINATION
BY MS. FRANKLIN:
Q. Good afternoon, Dr. Robbins.
A Good afternoon.
Q. Would you please give us your full name for the
record.
A Lisa Carolina Robbins.
Q. And what's your home address, Dr. Robbins?
A. 350 Glen Cove Drive, Avondale Estates, Georgia.
Q.
And was that your address in June oftbis year?
A. Yes.
Q.
Are you currently the medical director of
NARCONON of Georgia?
Pac;e 7
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Page 8 f.

interrogatory asks.
MS. FRANKLIN: I'm asking her to clear that
up ifl misunderstood it.
BY MS. FRANKLIN: ,
: in terms of being a medical
I director, as far as I understand it and understood it at
that time, was that I was the on-call physician for any of
the participants in the program and I was also to examine
the clients to see if they were medically able to undergo
the program, and tl1at was it.
Q. Okay. And you said that you began acting as
medical director, and we'll go through in more detail what
your duties were, but in 2003; is that correct?
A. I believe. rmnot sure of the exact date but
it was around 2003-2004 to 2008.
Q. What month in 2008 did you cease being the
medical director?
A. When Mary Rieser told me that I was no longer
the medical director because she found- well, she said
she found another physicians group to do the physicals
that was closer to her, and I don't remember what month
that was.
Q. Okay. Do you know whether you were the medical
director in June of2008?
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A. No. 1 A. I don't remember if I was officially a medical
Q. Okay. Have you ever been tbe medical director 2 director at that time. And like I said, in terms of I
3 ofNARCONON of Georgia? 3 medical director, it was mainly based on whether or not I
4 A. Yes. 4 she was sending me patients to do exams on.
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Q. Okay. When was that? 5 (Plaintiff's Exhibit Number 1 I
A. I believe it vias from 2003 until -two years 6 was marked for identification.) !
Q. And the reason I ask that is I'm sure you 8 Plaintiffs Exhibit 1.
ago -- 2008. 7 Q. I'm going to hand you what I've just marked as
9 understand that I represent the family of Patrick Desmond, 9 MS. FRANKLIN: And counselors, I have copies
10 who was =oiled at NARCONON of Georgia when he passed 1 0 of other --this one I don't particularly have a
11 away a couple years ago; right? 11 copy of but you're welcome to take a look at it.
A Yes. 12 MS. WIDTLOCK: Was tl'lis produced? Because :
Q. And you're a named defendant in this lawsuit 13 it doesn't have a Bates number on it. i
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1 4 You understand that; correct? 14 MS. FRANKLIN: It was produced subject to a

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A Yes. 15 third-party request from DHR. ';
Q. Okay. And we sent you some discovery asking a 16 MS. EYRE: Guys, can I interrupt for two i
number of questions and one of those was dealing with your 17 seconds?
role with NARCONON of Georgia and you responded by saying 18 MS. WHITLOCK: Yes. i
19 that you were not the medical director ofNARCONON. Is 19 MS. EYRE: At some point would somebody tell
2 o that right? 2 0 me, I mean, obviously whenever it's appropriate,
21 :MR. TANNER: Let me object to the fonn of 21 what these ex11ibits are as you go through?
the question. 2 2 MS. FRANKLIN: Of course. Sure. We're
THE Wll'NES S: Depends on what your 2 3 going to talk about them.
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2 4 de:finition of a medical directoris. 2 4 :MR. TANNER: Just so you'll know, Melanie, i
2 5 :MR. TANNER: That's not what the 2 5 I'm looking at Plaintiffs Exhibit 1. It apperus I
.. . ,_., ---- > ._.,._,-. ......., . ....
3 (Pages 6 to 9)
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LISA ROBBINS, M.D. 11-5-10 Desmond, et al. vs . Narconon, et al.
Page 10 Page
1 to be something like what Major Desmond would 1 for the record, an application for license to
2 have called a table of organization in the 2 operate a drug abuse treatment and education
3 military with sort of a little hierarchical 3 program dated January 24, 2007.
4 flowsheet showing Board of Directors, executive 4 MS. WHITLOCK: Whose application is it?
5 director. It's labeled NARCONON of Georgia 5 MS. FRANKLJN: NARCONON of Georgia
6 Organization-- ORG Board. 6 MR. TANNER: Melanie, Exhibit 3 is a
7 MS. EYRE: Okay. Thanks, Bob. 7 document that says at the top Office of
8 BY MS. FRANKLIN: 8 Regulatory Services, Health Care Section, 2
9 Q. Dr. Robbins, have you ever seen this document? 9 Peachtree Street, so it's evidently a Georgia
10 A. No. 10 Department ofHwnan Resources document, and it
11 Q. Would you agree with me that it lists you at the 11 says application for a license to operate drug
12 top of the organization chart as the medical director? 12 abuse treatment and education program
13 A. Thafs what it says. 13 MS. EYRE: Okay. Great. Thank you, Bob.
14 (Plaintiff's Exhibit Nmnber 2 1 4 BY MS. FRANKLIN:
15 was marked for identification.) 15 Q. Dr. Robbins, have you ever seen this document?
16 Q. I'm going to hand you what I'm marking as 16 A No.
17 Plaintiffs Exhibit2. 17 Q. Okay. If you'll look on the second page, you'll
1 8 MS. FRANKLIN: Here's copies for y'all. 18 notice that there's a section for personnel for the i
19 Melanie, it's the NARCONON Program Description 19 program and one of the categories is medical director. Do I
2 0 that's filed with the Department of Human 2 0 you see that? I
21 Resources. 21 A Yes.
2 2 BY MS-. FRANKLIN: 2 2 Q. And your name is listed there; is that correct? j
2 3 Q. Have you ever seen that document, Dr. Robbins? 2 3 A Yes. J
2 4 A. No. 2 4 Q. Okay. And that's dated-- the application is
r2_s _____ Q __ __ __ d ____ _,_2_s ___ d_m_e_d_Jan __ uary ___ o_f_2_00_7_? ______________________
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see whether your name is listed as the medical director in 1 A. Yes.
that particular document. 2 Q. Were you ever consulted by anyone from NARCONON
A. It doesn't say that I'm the medical director. 3 during the application process where you're listed as
It says medical care by Dr. Robbins. 4 medical director?
Q. Okay. And then -- what page is that on? 5 MS. WHITLOCK: About what?
A There's no page number but it looks to be like 6 BY MS. FRANKLIN:
the third page, the top before psychosocial assessment and 7
treatment planning. 8
Q. All right. And then if you flip a few more 9
pages, you'll find the same organization chart that we've 1 0
labeled as Exhibit Number 1, and that, again, lists you as 11
the medical director; correct? 12
A. I don't know what page you're oiL 13
Q. There il is. 14
A. Here we go. Okay. 15
Q. Does that appear to be the same organizational 1 6
chart that we just talked about? 1 7
A It's what it looks like, yes. rve never seen 18
it before. 19
(Plaintiff's Exhibit Number 3 2 0
was marked for identificatioiL) 21
Q. I'm going to hand you what I'm marking as 2 2
Plaintifi's Exhibit 3. 23
MS. FRANKLIN: Again, this is -I don't 2 4
have a copy of this document, counselors. It is, 2 5
Q. About the application process. Let me rephrase.
A. I'm not exactly sure what you mean.
MR. TANNER: Hold on. She's going to ask
the question.
BY MS. FRANKLIN:
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Q. I'm going to ask it hopefully in a better way.
Did you know that you were listed on NARCONON of Georgia's
application for license to operate a drug and rehab
facility? Didyouknowyou were listed as their medical
director?
A. rm not really- I don't know. All I know is I
that I was hired by them to do the physicals on their
patients and if they needed any medical treatment. That's
all I know in tenns of my relationship with NARCONON.
Q. Okay. And I don't want to put words in your
mouth. You did not know at the time that that application
was submitted to the Department ofHuman Resources that
you were listed as, quote, the medical director.
A No.
4 (Pages 10 to 13)

404 . 233 .3300 ** JFi scher @QAReport i ng .com
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(Plaintiffs Exhibit Number 4 1
was marked for identification.) 2
Q. I'm going to hand you what I'm marking 3
Exhibit4. 4
MS. FRANKLIN: Melanie, this is titled New 5
Life Detoxification Program Discharge Summary and 6
Transfer Form. It bas the NARCONON of Georgia 7
logo on the top. Here's several copies. 8
MS. EYRE: Thank you. 9
BY :MS. FRA.i'JKLIN: 1 0
Q. Have you ever seen -- and this is actually 11
two-sided. Have you ever seen either of these two 12
documents? 13
A. I've seen the document on the back where it's 1 4
got my signature. 15
Q. Okay. And that's above the words medical 16
director? 1 7
A. Yes. 18
Q. And is that your handwriting above that? 19
A. No. 20
Q. Okay. Do you recognize that handwriting? 21
A. No, I don't recognize that handwriting but it's 2 2
notmine. 23
Q. Okay. There's an indication that a nurse-- 2 4
there's the name of a nurse above your name. Do you 2 5
Page 15
recognize that nurse's name? 1
A. No. I was told that NARCONON hired nurses with 2
the program and so I assume that's who that is. 3
Q. Okay. Do you remember signing this particular 4
document? 5
A. It's my signature but it's been a long time ago. 6
I apparently did sign it' 7
Q. Okay. But you don't have any independent B
recollection of signing this particular document. 9
A No. 10
Q. What about on the other side of the page; 11
there's a signature at the bottom that says staff 12
signature. Is that your signature? 13
A. No. 14
Q. Okay. Do you recognize that signature? 15
A. No. 16
Q. Do you have any independent recollection of ever 17
seeing this particular page? 18
A. No. 19
Q. Do you know- strike that. 2 0
(Plaintiffs Exhibit Nmn.ber 5 21
was marked for identification.) 2 2
Q. Dr. Robbins, I'm going to hand you what I'm 2 3
marking as Exhibit 5, and it is titled Health Care 2 4
Provider Sel"<ice Agreement, if you'll just take a look at 2 5
Page 16
that and tell me if you've seen that document before. I
MS. WHITLOCK: This is Bates stamped Desmond J'
D-Georgia 073, 074, 075, 076 and 077. What did
you say it was, Plaintiffs 6? 5. I
MS. FRANKLIN: 5. 1
BY MS. FRANKLIN: I'
Q. Have you had a chance to look at that docwnent? ,
A. Yes.
Q. And have you seen that before?
A. Yes. J
Q. In fact, you produced this in this litigation;
correct?
A. AB far as I know, yes. !
Q. Okay. And the page 5 of this document has your l
correct? i
A. That's right.
Q. And then-- and it's under the title physician;
right?
A. Right.
Q. And then under that is the words medical I
director.
A. That's correct.
Q. And did you write those words?
A. At the request of Mary Rieser, yes.
Q. Okay.

Tell me what you remember about- strike
Page 17 I

that. Do you remember signing this document?
A. It was a while ago. rm kiod of fuzzy about it
but I remember the generalities about, you know, why I
signed it.
Q. Well, tell me what you remember about this
contract. And just to be clear, it appears to be a
contract between you and NARCONON of Georgia; right?
A. That's conect.
Q. For senices that you were to provide as well as
in consideration for things that the facility agreed to
do; correct?
A. Right.
Q. Okay. Tell me what you remember about this
particular contract.
A. Mary wanted me -- Mary rueser wanted me to
perform physical exams on potentia.[ NARCONON clients to
make sure that they were physically able to undergo the
treatment program, and also during the time of their
treatment if anybody had developed any kind of medical
issue, for instance, a cold or bladder infection or
something like that, that I was considered basically the
on-call physician to handle those concerns.
Q. Okay.
A. And that was it really.
Q. You told me earlier that you started with
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NARCONON in 2003; right?
A Something like that.
Q. And this document is dated December of2006.
A rught.
Q. What's your understanding of why-- well, first
of all, did you have any sort of written agreement with
NARCONON of Georgia prior to this document?
A No.
Q. Okay. Did Mary Rieser tell you why she needed
you to sign this contract at that time?
A. Because prior to that time I was doing
physicals, physical exams for NARCONON of Georgia but
there were other physicians that she had been using as
well in addition to me and it seemed like they didn't
really have anybody who they could utilize as an on-call
doctor 'and so she wanted to use me as like basically an
on-call physician.
Q. Did she call you up and tell you that? Did you
have a face-to-face meeting?
A. She called me and told me that and we had a
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face-to-face. 21
Q. Did you come to the NARCONON facility or did she 2 2
come to your office?
A. She came to my office.
Q. Okay. Did she tell you anything about any
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Q. Okay. Did you, in fact, develop and maintain an
understanding of the NARCONON educational program?
A. I guess in the sense that the patient underwent . 1.
the sauna program and took vitamin supplements. That was _
the main thing I was told that was part of the program in
terms of that and that was what I understood. And that
was basically what Mary Rieser had told me about the
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program.
Q. That's what she had told you in the past?
A That's what she told me throughout. That's what
I understood the program involved.
Q. Okay. So in your mind, based on what Mary
Rieser had told you, you believe that you had developed
and maintained an understanding of the NARCONON
educational program.
A. Based on what she told me.
Q. Okay. Did you review any documents?
A. No.
Q. Did you review any sort of treatment plans of
any of the patients?
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A In what way?
Q. In order to help develop and understand the
NARCONON educational program.
A I mean, the only thing that I looked at in tenns
of the patients were the paperwork that I used to evaluate j
Page 19 Page 21 J

requirements from the Department of Human Resources about 1 the patient to see if they were going to be physically $
NARCONON having a medical director? 2 able to utilize the program.
A. No, not really. 3 Q. Okay. But you didn't look at any of the course !
Q. Did she tell you about any s01t of settlement 4 materials that they were provided I
negotiations or negotiations that she was having with any 5 A No.
other party that dealt with having a medical director? 6 Q. Okay. Section 4 says that you are to provide
A No. 7 medical oversight for the sauna exercise program.
Q. Okay. Did you go through the terms of this 8 MS. WHITLOCK: What section are you on? I'm e
document? 9 sorry.
A Not really. I mean, we generally \vent through 1 0 MS. FRANKLIN: Section4.
the document as basically saying that, you know, I would 11 MS. WHITLOCK: 4 what? i
provide 24-hour on-call coverage and maintain a proper 12 MS. FRANKLIN: Well, it's under paragraph A.
medical license, like it says on here, and that was 13 MS. WIITTLOCK: Oh, I'm sony. Right tmder
really-- and the fact that we would-- you know, the 14 number 4. I see it.
things that we would provide in the context of the 15 MS. FRANKLIN: The next one.
physical exam oftl1e patient. 1 6 BY MS. FRANKLIN: I
Q. Okay. 1 7 Q. Do you believe you did that? I
A. And that was it really. 18 A. In tenns of recommendations and approval for
Q. Well, number 3 under paragraph A says develop 19 who's eligible -- f
and maintain an understanding of the NARCONON educational 2 0 Q. Okay. l
program. Did you discuss that provision? 21 A. -- as well as if a patient, you know, needed to J
A. We didn't discuss it but it was generally 2 2 be referred to a specialist for any other reason that we I
understood that I was doing the physical exams in order to 2 3 fotmd necessary. I
see if the patient would be able to handle their treatment 2 4 Q. What sort of specialist?
_ 2 5 _! ... patieirt
program.
6 (Pages 18 to 21 )
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are a few patients who came through who we found were 1
positive for hepatitis Cor HIV positive or maybe they had 2
cardiovascular disease. I would refer them to a 3
cardiologist or an infectious disease physician or 4
gastroenterologist in those cases. 5
Q. Did you ever make a recommendation or a finding 6
that a prospective patient or student was not -- would not 7
be eligible for the NARCONON program? 8
A There were a few patients that I did deem not 9
eligible. 1 0
Q. And on what basis? 11
A There were a couple of patients who just really 12
weren't physically able to undergo the program. I think 13
one patient had like renal failure. Another patient had 1 4
uncontrolled hypertension. There were a couple of 1 5
patients who were methadone abusers. 1 6
Q. Okay. So in those circmnstances did you refer 1 7
those patients to some other drug or alcohol treatment 18
facility? 19
A. I recommended that the patient go to see a 2 0
psychiatrist or go to an inpatient facility. 2 1
Q. Okay. Did you provide the patient or NARCONON 2 2
with specific referrals? 2 3
A. I gave them the names of the physicians that I 2 4
suggested they refer the patient to. 2 5
Page 23
Q. Okay. What about residential facilities; did 1
you give them other -names of other residential drug and 2
alcohol treatment facilities? 3
MS. WIDTLOCK: Object to the form of the 4
question insofar as it assumes that NARCONON was 5
a residential program. 6
BYMS. FRANKLIN: 7
Q. You can answer the question. 8
A. There were one or two patients that I 9
recommended go to like a Summit Ridge program. 1 0
Q. And that's an inpatient facility? 11
A. Yes. 12
Q. Okay. 1 3
A. A couple o1her ones I suggested that they take 1 4
them to the emergency room to have them evaluated to see 1 5
if they may need to be placed in a hospitalized 1 6
environment. 1 7
Q. Okay. Any other -- any other facilities that 18
you- drug and alcohol facility that you referred 1 9
potential patients to besides Summit Ridge? 2 0
A. Charter Peachford. 21
Q. Is that an inpatient facility? 2 2
A. Yes. 23
Q. Any others? 2 4
A No. 25
Page 24
'
Q. And on what basis -- why would you refer a
patient or a potent ial client to an inpatient facility as
opposed to what you believe NARCONON to be?
A. Well, if the patient were notably psychotic or
belligerent or if there was any sign of severe withdrawal
effects that were apparent.
Q. Anything else?
A. No.
Q. Okay. You mentioned that your primary role was
to determine whether a patient was eligible to participate
in the sauna program. What was your understanding of the
specifics of that sauna program?
A That the patients were to be in an environment
where 1hey were provided healthy nutrition, nutritional
supplements, as well as to undergo a physical
detoxification of whatever drugs they were on through the
use of sauna --
Q. Goahead.
A. - as well as exercise.
Q. Were you provided any materials that outline the
specifics that a patient would be required to do? In
other words, did you know how often a patient - if you
deemed them eligible, did you know how often the patient
would go to the sauna?
A. As far as I knew, they would go to the sauna on
Page
a daily basis.
Q. Okay. And did you know how long they were to
spend in the sauna?
A From what I -was told by Mary-- and this was -
a lot of it was based on the patient's ability to
tolerate, you know, high temperatures, but they're usually
asked to spend anywhere from 20 minutes to 45 minutes.
Q. Okay. What about the exercise part of the
program; what's your understanding of the exercise
that's--
A That they would be walking on a treadmill to get
their heart rate up and to help with the detoxification
process.
Q. Okay. And were you provided with any written
materials that set out the requirements or details of the
sauna exercise program?
A. No.
Q. It was all verbal from Mary Rieser.
A. It was all verbal .
I
~
Q. Under Section C or subsection C, we were talking ~
just a second ago about medical oversight. DJd you, in J
fact, begin to offer 24-hour on-call coverage 10r patients
at NARCONON?
A Yes.
Q. And that means that if you were on vacation or
7 (Pages 22 to 25)
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unavailable you would have another physician that would 1
fill in for you; is that right? 2
(Telephone interruption and discussion off 3
the record). 4
BY MS. FRANKLIN: 5
Q. Okay. Dr. Robbins, I think I was asking you 6
about whether you provided-- if you were unavailable, 7
would you have someone cover your on-call coverage? 8
A. Yes. 9
Q. Who? 10
A. Well, at that time it was Dr. Frenesa Hall. 11
Q. Can you spell that, Frenesa Hall? 12
A. F-R-A-N-E-S-A Hall. 13
Q. Okay. And who was she? 14
A. She was a physician colleague who covered my 15
office while I was on vacation. 16
Q.' Okay. But she's not a business partner of
17
yours.
1 8
A. No.
19
Q. The next subsection said that you would -- or 20
indicates that you would provide updates and approval for 21
onsite emergency medical procedures and safety precautions 22
at NARCONON. Did you do that as prut of your role as 23
medical director?
24
A. Where is that? 25
Page 27
Q. It's just 1he next subsection after the 24 hours 1
on-call coverage. 2
A. Oh, first page. I don't know what that means, 3
but as far as I was concerned, it was - I took that to 4
mean at my clinic. 5
Q. Okay. Did you ever visit the sauna? 6
A. No. 7
Q. Did you ever visit the NARCONON facility? 8
A. No. 9
Q. The next section is E. I believe you already 1 0
told me that you did do a treatment assessment on 11
potential patients; right? 12
A. Correct. 13
Q. And you took a drug history of each patient that 1 4
yousaw? 1 5
A. Yes. 16
Q. Okay. And asked them or made a dete11:1Unation of 17
the current cause for admission; right? 18
A Yes. 19
Q. Determining me-dical risks; right? 2 0
A. Yes. 21
Q. Okay. Determine whether there were any 2 2
emotional problems? 2 3
A. Right. 2 4
Q. Okay. And you took their vital signs; right? 2 5
Page 28
A. Correct.
Q. Okay. Section F says you would provide
diagnostic services. Did you do that?
A. Yes.
Q. Section G indicates that you should refer
clients not eligible for any aspect of the NARCONON
program to appropriate facilities; right?
A. Correct.
Q. And that's what you just told me about
A. Correct.
Q. So if you believe that the patient needed
inpatient residential care, you would refer them to
Summit -- what's the full nan1e of that facility?
A. Summit Ridge.
Q. Summit Ridge or Charter Peachford?
A. Right
Q. Did you include parameters for immediate
physician notification in each clienfs treatment plan,
which is - I'm just reading directly from Section H.
A. No, not specifically. ~
Q. Okay. ~
A. If the patient was having any issues, they would ~
call me or the patient would call me. , ..
Q. Okay. But you were never asked by Mmy Rieser I
to indicate for each patient the parameters that would ~
Page 29 ~
I
I
J
require your notification.
A. Correct.
Q. Section I says that you would recommend sauna
and exercise time for the patient's treatment plan. Did
you do that for each patient?
~ b ~ . And how did you nwke that deteamnation? ~
A. Based on my physical assessment of the patient. g
Q. Did you ever have patients that you believed J
were eligible for the sa1ma progran1 but not necessarily J
for the terms or the time that you just told me, the 45 ~
minutes a day? ,
~
A. I had a couple of patients where I just told ~
t!
them to cut it in half.
Q. Okay. So you would modify their treatment plan.
A. Correct
Q. And what physical-- under what conditions would ~
you do that? What are you looking for in your physical ~
1r
assessment to make that detennination? !
A. Well, if a patient had any physical disabilities ~
or injuries or sign of infection or just whatever might ~ ~
make it more difficult for them to handle the full time in
..
the sauna.
There was one patient, fur example, who seemed
to have issues with dehydration or problems with high
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Page 30
temperatures and so we cut it in half and she seemed to 1
tolerate it really well. 2 Q. And how did you make that detennination?
BY MS. FRANKLJN:
Page 32 I
I

Q. Did you take into consideration the patienfs 3 A. There was already a set plan that involved
lab work? 4 specific vitamins and supplements and their dosages and I
A. Yes. 5 either agreed with that or made a modification in what
Q. Specifically \\'aS there anything that you would 6 they were to get on that list.
look for in the patienfs lab work to make a determination 7 Q. And that list was provided to you by Mary I
whether the sauna program was appropriate? 8 Rieser? 1
A. Yes. 9 A. Yes.
Q. What? 10 Q. Okay. AndduringyourtimewithNARCONON, I
A. If they had any signs of severe cardiovascular 11 whether you're medical director or just associated, did
illness, if they had any signs ofhepatitis, HIV, 12 that plan change?
syphilis, SID's. 13 A. No.
Q. Anything else? 14 Q. What would you look for in determining whether a
A. Electrolyte abnormalities. 15 patient was an appropriate candidate for the vitamin and
Q. What particular lab tests would show that, 16 supplement portion of the NARCONON program? i
electrolyte abnonnalities? 17 A. Well, for instance, if a patient had a history I
A. Sodium levels, potassium levels, chloride 1 B of renal failure or renal disease, that would preclude him
levels. 1 9 from-- he or she from receiving magnesium or potassium.
Q. Anything else? 2 0 So those were really the folks who we really had to
A. BUN, creatinine levels. 21 modify.
Q. rm sorry. I couldn't understand what you said. 2 2 Q. Okay. And you would gain that information by a I
A. BUN and creatinine levels. 2 3 patient's history as well as their lab work; right?

Q. Okay. So if those levels were elevated, you may 2 4 A. Conect.
modify the treatment plan for that particular patient. 2 5 Q. Anything else that you would look for in

Page 31 Page 33
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A. Correct
Q. Anything else besides your physical assessment
and the lab work that you would consider in determining
whether you needed to modify the treatment plan or the
typical treatment plan?
A. Well, I think I'd already mentioned earlier
about if a patient \vere going through severe withdrawal
symptoms or had any signs of severe injury, and by that I
mean, you know, there are some patients who came in from
jail and had injuries.
Q. That wouldn't be consistent with -- consistent
isn't the word I'm looking for, but that wouldn't be
appropriate for the sauna program?
A. Maybe not appropriate for the full
participation. In other words, either they just needed
time to heal or instead of spending a ful1 hour in a
sauna, maybe 30 minutes depending on what the problem was.
Q. Okay. The next subsection outlines the vitamin
and supplement dosages. Did you prescribe the vitamins
and supplements to the patients at J\ARCONON?
MS. WHITLOCK: What number are you looking
at? I'm sorry.
MS. FRANKLIN: I may have skipped ont:. J.
MS. WHITLOCK: I see. I'm sorry.
THE WITNESS: Okay. Yes.
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determining whether a patient was a candidate for the
supplement or the vitamin and supplement program?
A. Wel1, if they stated a history of allergies to a
specific product.
Q. Anything else?
A. That's it.
Q. All right. Did you perform a followup medical
exam on each of the patients participating in the program
within 20 days?
A I definitely made eve1y attempt to.
Q. What do you mean by that!
A. There were some patients who left the program
prematurely.
Q. Okay.
A. Couldn't get to them.
Q. Sure. So they didn't come back to see you.
A. No.
Q. What about other patients? What about patients
who stayed in the program for 20 days or more; did you
'
J
perform a followup medical exam on those patients?

A. Yes. l
Q. And how was that exam scheduled?
A. Usually it was scheduled about 20 -- well, about I
three or four weeks after my initial assessment. I
Q. Okay. Did NARCONON c.ontact you or your staff
' "" - - -,. "---c>. 5?-:""''i""
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Page 34 Page 36 ~
$
1 and say we're sending over a patient? 1 Q. Tell me your understanding of how an ASAM Level ~
2 A. Yes. 2 1 facility is to operate. ~
3 Q. They've been through the detox program? 3 A. I have no idea. i
4 A. Yes. 4 Q. The next set of provisions under Section B J
5 Q. Okay. And '\Wat sort of exam did you perform at 5 outlines thing;; that the facility agreed to do, and number ~
6 that time? 6 5 says that the facility - and that's NARCONON -- would ~
7 A. Well, at that time we would, you know, check to 7 provide the physician, you, with any reference materials ~
8 see how the patient's doing and if they needed any 8 used by NARCONON relevanfto the scope ofNARCONON's ~
9 rechecks in lab work based on what we found or what they 9 services. Did NARCONON or anyone at NARCONON do that? I
1 0 maybe showed initially. 1 0 A. No. ~
11 Q. So you wouldn't automatically do another set of 11 Q. Okay. Do you believe that NARCONON provided you i
12 labs. 12 with the pertinent administrative and social data about J
13 A. No. 13 clients? 1
14 Q. Would you typically run the labs again? 14 A. Pertinent administrative and social data-- that
15 A. There were some patients that needed labs to be 15 I don't know. I mean, I received information that these ~ ~
1 6 redone and quite a few ended up getting labs redone. 16 forms show that the patient had filled out and at times I 11
1 7 Q. All right. Did you always perform a physical 17 would get a form like this that the nurse had filled out, 1.
18 exam? Did you see each patient that came back? 18 so if that's what you mean, then yes.
19 A. Yes. 19 Q. But you don't lmow whether there was anything
2 0 Q. All right The last subsection is nwnber 7 and 2 0 pertinent that you didn't receive. J
21 it required you to provide instruction to facility staff 21 A. Exactly. i
2 2 on appropriate admissions to ASAMLevell program and how 2 2 Q. Okay. Under Section Cit indicates that the - ~
2 3 to refer those patients requiring higher ASAM level 2 3 billing for your time with NARCONON patients will be $750 1
2 4 treatment. Did you do that? 2 4 per client at the initial visit. ~
2 5 A. No. 2 5 A Correct. ~
r - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - r - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ ~
37 ! Page 35
1 Q. What's your understanding of that provision?
2 A. I don't understand that provision. Well, I take
3 that back. I understand it in terms of the fact that
4 if- like I'd stated earlier, if a patient came in who
5 'i'i>as going through severe withdrawal symptoms or who was
6 requiring in-hospital treatment, I would l.et the patient
7 and NARCONON know about that.
8 Q. Okay. But did you--
9 A. So-
10 Q. I'm sorry. I didn't mean to cut you off.
11 A No. Go ahead.
12 Q. Okay. Based on what you've just told me, you
13 did the second part of this particular provision- well,
14 you yourself would refer those patients to a higher ASAM
15 level treatment program; right?
16 A Right.
17 Q. Okay. But did you provide any instruction to
18 NARCONON about referring patients to other facilities?
1 9 A Well, I kind of answered that already in terms
2 0 of sending them to like Charter Peachford or Summit Ridge
21 or one of the local hospitals in that regard.
2 2 Q. Okay. Let me ask it this way. Did you provide
2 3 any instruction to anyone at NARCONON about how an ASAM
2 4 Levell facility is to operate?
25 A -- No.
. ~
Page
1
Q. That money was c.ollected by the facility and
2 then paid by NARCONON to you; right?
3 A. Correct.
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Q. And did that include the followup visit? ~
AQ .. Yes. ~ .
How long was your typical initial client visit? ~
A How long? ~ ~
Q. Uh-huh.
A. About an hour. 1
Q. And does that include the lab tests? ~
A. Yes, andEKG. '
Q. Okay. And again, you indicated that your ~
signature on the last page, which is Bates number 0077, is ~
your signature; right? I
A. Yes. ~
Q. And the writing below that says medical ~
director, that's your handwriting; correct ? ~
A. Yes. ~
Q. Okay. Excuse me if I asked you this earlier, ~
but do you remember whether you signed this in the ~
presence of Mary Rieser? I
A. Yes. ~
Q. Okay. She was at your office? ~
~
A. Yes. 1
Q. Did you keep a copy of this? ::
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LI SA ROBBINS, M.D. 11-5-10 Desmond, et al. vs. Narconon, et al.
Page 38
1 A. Yes. 1
2 Q. Did you have any other discussion with :Mary 2
3 Rieser about this particular agreement that we haven't 3
4 already talked about? 4
5 A Not that I can remember. 5
6 Q. Okay. 6
7 (Plaintiffs Exhibit Number 6 7
8 was marked for identification.) 8
9 Q. I'm going to mark as Exhibit 6 the medical 9
10 director agreement dated Feb1uary 16,2007, if you'll take 1 o
11 a look at that document. ll
12 MS. WHITLOCK: Melanie, this is Desmond D-GA 12
13 0068, 69, 70, 71 and 72. 13
14 MS. EYRE: Okay. Great. What is the date 14
15 onitagain? 15
16 MS. FRANKLIN: February 16,2007. 16
17 MS. EYRE: Okay. Thank you. 17
18 MS. WHITLOCK: And this is Plaintiffs 6? 18
1 9 MS. FRANKLIN: Yes. 19
2 0 THE WITNESS: Can I ask you a quick 2 o
21 question? 21
2 2 MS. FRANKLIN: Do you need to take a break? 2 2
2 3 MR. TANNER: Take a break'? 2 3
2 4 THE WITNESS: If you don't mind, yeah. 2 4
2 5 THE VIDEOGRAPHER: Going off video Iecord at 2 5
Page 39
1 3:59p.m. 1
2 (Brief recess.) 2
3 THE VIDEOGRAPHER: We're back on video 3
4 record at 4:04p.m. 4
5 BYMS.FRANKLIN: 5
6 Q. Dr. Robbins, before we broke -- we just broke 6
7 and I understand that you wanted to clarify. And just so 7
8 you know, any time that you 1hink of something or you want 8
9 to clarify an answer that you gave before, feel free to do 9
10 that. 10
11 A. Okay. 11
12 Q. I want to make sure I leave here today with all 12
13 the information, you know, that you have to give me and so 13
14 feel free to back up if we need to. 14
15 MR TANNER: And Doctor, if you want to 1 5
1 6 clarify an exhibit, use the exhibit number so 1 6
1 7 it's clear on the record. 1 7
18 TilE WITNESS: Okay. Exl1ibit Number 5 -- 18
19 well, it's Number 5 and 6 actually. This is 19
2 0 looking at bo1h exhibits, the last page of each 2 0
2 1 where rve signed my name, and under the title it 2 1
2 2 says medical director on Exhibit 5, the last 2 2
2 3 page, and medical director/president on the last 2 3
2 4 page. 2 4
25 25
Page 40 ~
BY MS. FRANKLIN:
Q. Right
A. I'm signing that as medical director ofRobbins
Health Alliance, my clinic.
Q. Thank you for clearing that up. Okay. Why did
you- and again, I'm not -- I'm just asking-- why did
you sign it as medical director of your clinic?
A. Because I guess this -- these contracts, I was
under the impression that I was one party signing it
representing my clinic--
Q. Okay.
A. -you know, in a contract with NARCONON.
Q. That's fair enough. Did you have any
I
j
I
~
I
I
j
discussions with Mary Rieser about whether the contract ~
was between you and NARCONON or your clinic and NARCONON? I
A Well, I kind of figured me and my clinic are the ~ ..
same. j
Q. Okay. ~
~
A. I'm a solo doc so I am my clinic.
Q. I understand. I am my law finn so I understand
i
wliat you're saying. But you didn't have any specific-- ~
or do you have any recollection of any specific ~
discussions about that? ~
~
A. About whether it's just me versus the c.Jinic? ~
. Q. Whether the contract was between your clinic and ~
Page 41
NARCONON or you personally and NARCONON.
A Well, I guess I assumed it was my clinic because
my clinic-- me and my clinic were performing a service
for NARCONON.
Q. And I understand that, but do you remember
discussing that specifically with anyone at NARCONON?
A. In this manner, no. I guess it was --I just
assumed that's what this was.
Q. Okay. And on Exhibit 5 -- well, I was going to
ask you -- do you know whether there are any differences
between Exhibit 5 aud 6? Exhibit 5 is the health care
provider service agreement. Exhibit 6 is the medical
director agreement.
A. I thought this was like an update from the frrst
contract. That was kind of how I assume this was.
Q. Okay. Tell n1e what you remember about the
circumstances of signing this second contract, Exhibit 6.
A Like I said, I j ust thought this was an update
of the other.
Q. Do you remember whether you received it in the
mail?
A No, I don't remember. I might have. I don't
i
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A. Not really.
Q. Do you rernell)ber having any discussions with Mary
Rieser or anyone at NARCONON about this document?
A Off the top of my bead, no.
Q. Okay. Do you remember reading this document
befme you signed it?
A. No, not really.
Q. Okay. And when you signed Exhibit 5 as medical
director, do you remember having any conversations with
Mary Rieser about you being the medical director of
NARCONON?
A. After signing --
Q. Either one of them.
A. Only in tenns of the fact that, you know, she
wanted me to, like I said, do all of the physicals. She
wanted-- instead of using several different physicians,
she just wanted to use one physician who would do the
intake physicals and to be on call.
Q. And when she explained those services to you or
when you discussed them, did she specifically talk about
you having a title as medical director?
A. She said that I would service all the patients
that needed any medical treatment to come in.
Q. Right And I understand --
A. As they came in.
Page 43
Q. I just want y ~ u to listen to my question, and I
know it may seem silly and it may be silly but I just need
you to answer. Do you remember whether Mary Rieser
discussed with you your title of medical director?
A. I guess in terms oflike being the only
physician to do the physicals. She just said okay, well,
I want you to just be my main medical person to take care
of any medical problems.
Q. Okay. And medical person isn't the same as
medical director. Do you know whether she discussed with
you having the title of medical director?
A. Not really.
Q. You don't know whether she did?
A. No. If she did, I don't remember.
Q. Okay.
A. But the only thing I do remember is that she
wanted me at one point in time to do, you know, all the
medical ireatment that was necessary.
Q. Okay. Butyoujusttold us that when you wrote
the words medical director on Exhibit 5 and medical
director/president on Exhibit 6 that you were writing that
as medical director of your own practice.
A. Correct.
Q. Okay.
A. Correct.
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Q. So it wasn't at the direction of or because of
any discussion Mary Rieser had had with you about being
medical director at NARCONON.
A. Right.
Q. Okay. On Exhibit 6 under physician agrees to
there' s several things enumerated, and under 4, again,
1
ifs the same language, that you're required to provide ~
~
medical oversight of the facility, and under subsection H i
it says that you are to include in each clienfs treatment
plan physical indicators which require NARCONON to notify ~
11 a physician. Do you know what that means? li
12 A. If the patient's blood pressure, you know, was
13 going either too high or too low or if they were noticing ~
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any cardiopulmonary signs of distress or anything like ~ ~
that.
Q. Okay. And did you note that in-- if you did--
if a patient did have some sort of indicator that required ~
NARCONON to notify you, where would you note that? ~
A. Well, I think that was something that was i
inherent in the treatment of the patient. I mean, you ~
know, they have nurses over there who are checking vital ~
signs and if their vital signs weren't stable --which I ~ .
never got a call about that, about any instability of ~
vital signs during the 1reatment. ~
Q. Okay. I think you told me earlier that you M

Page 45 i
~
never looked at clients' or patients' individual treatment
plan.
I
A. My job was just to look at the ability of the
patient physically to enter into the program.
Q. Okay. And nothing else that may be required by
law or that NAR.CONON did as part of their program. You -
didn't look at anything else.
A. No.
Q. Okay. Under Section 5 it says that you are to
inform the patients referred by the fucility if patients
would be at risk by participating in the program. A copy
of this notice should be sent to the facility. And that's
a little different than the subsection 5 in Exhibit 5.
Tell me what your understanding of that provision is in
Exhibit6.
A. I guess they took out cross-reference such
findings and they just said copy of this notice.
Q. Right. Is there any significance to you to that
change m that provision?
A. No, because if the patient-- if I found a
patient that I didn't think would qualify for entering the
program, I would let them know.
Q. Okay. Would you do that in vvTiting?
A. Yes.
Q. And would that be -
12 (Pages 42 to 45)
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Page 46 Page 48
~
A. I mean, they would automatically - they 1 not exactly sure what you're getting at . She really I
~
automatically would receive a copy of that anyway -- 2 didn't send me much of any correspondence.
~
Q. Okay. 3
Q. Okay. \Vhat else is in your NARCONON file
.
i
A. -- of whether or not they were deemed fine to
4 besides the- and I don't know if you said this but v.ras
enter in the program or not. 5
Exhibit 5 in your NARCONON file?
Q. They provided )IOU with some fom1s that you were 6 A. Well, you just told me it was.
to fill out; right? 7 Q. I don't know. .You produced it !mt do you
A. Right. 8 remember when you looked for it whether it was in your
Q. And that was part of the packet of information 9 file?
that you were to fill out; right? 10
A. Yeah, it was there.
~
A. Right.
11
Q. What else is in your NARCONON file?
!
Q. Okay. Did those forms change at all over the 12 A. Probably a copy of the forms that we were to
years? 13 fill out on each patient.
A. I don't think so, no. 14 Q. Okay. V.'hat else?
a
Q. And then number 6 again looks like the same 15 A. That might be it.
~
provision-- well, it's actually titled 7 in Exhibit 5 but
16
Q. And that file is still in existence; right?
i!
it's provision 6 in Exhibit 6, but it says that you are to
17
A. Right.
I provide instruction to facility staff on appropriate 18
Q. So you haven't discarded that just because your
admissions to ASAMLevell program. Again, do you !mow 19 relationship with them-
I
what that means? 20 A. No.
I
A. No. 21
Q. And I'd ask you just not to do that until you're
Q. Did you keep a copy of this medical director 22 told by your lawyer you can.
I
agreement? 23
Okay. I think we've gone over your role in the
i
A. I'm not sure. I know I had one of these. 24
NARCONON program, but tell me whether you as the medical
~
"
~
Q. rn represent t o you that you produced in 25 director ofNARCONON were in charge of overseeing any
E'age 47 Page
49 .
discovery the Exhibit 5 but -- and correct me if I'm
1 policies and procedures for NARCONON of Georgia.
wrong-- you didn't produce Exhibit 6 and I'm just asking
2 A ~ o .
whether you know whether you kept a copy of Exhibit 6.
3
1\.ffi. TANNER: For the record, I would obj ect
A. I don't think I did.
4 to the form of the question because you're
Q. You don't think you kept a copy?
5 assuming that somehow that title is the title
A. I'm not sure. I don't know. 6 that she thinks she had at any given time, but if
Q. Where would you normally keep an agreement like
7
you want to ask her if she was in charge of
this?
8 looking at policies, that's fine.
A. I mean, I would usually keep it in the file,
9 BY MS. FRANKLIN:
NARCONON file.
10 Q: At any point in time did you believe you were
Q. You have a file dedicated to your relationship 11 medical <lirector ofNARCONON of Georgia? I thought we had
with NARCONON; right?
12
established this but clarifY me -- clarify this for me.
A. Right.
13
A. Well, you clarifY it for me. What exactly do
Q. And presumably you vvere asked to look for
14 you mean by that?
certain things in this case; right?
15
Q. In your mind at any point in thne did you
A. Right. 16 believe you had the title of medica] director atNARCONON
Q. And you foWld this first agreement.
17
of Georgia?
A. Right. 18 A I mean, if you mean the director in tenns of the
Q. But not the second agreement.
19
whole program and how it's supposed to ron, no.
A. Right.
20
Q. Is that what you associate with the tenu medical
Q.. Do you normally keep cover letters? Let's say
21 director?
something was sent to you by Mary Rieser by mail and there
22 A. Well, that's what y'all think it is but that's
was a cover letter that went with it. Do you normally 23 not what I think it is.
keep those?
24
Q. rm asking you-
A. Depending on what it said on it. I mean, l'm
25
A I assume what I've already told you several
13 (Pages 46 to 49)
404. 233.3300 ** J Fi scher@QAReport ing.com
LISA ROBBINS, M.D. 11- 5- 10 Desmond, e t a1. vs. Narconon, et al.
Page 50
1 times, which is that my job was to evaluate, examine
2
patients to see if they were medically fit to undergo
3 their treatment program.
4
Q. Okay. If I bad asked you in 2007 are you the
5 medical director at NARCONON of Georgia, what would your
6 answer have been?
7 A. What do you mean by that?
8 Q. Okay. Ifihadaskedyou in2007 do you
9 consider yourself tn be the medical director at NARCONON
10 of Georgia, what would you have said?
11 A. What do you mean by that?
12 Q. So you couldn't answer that question.
13 A. No.
14 Q. Okay. When you were working with patients at
15 NARCONON did you oversee any policies or procedures?
16 A. No.
17 Q. Were you involved in any drafting of any
18 guidelines or policies or procedures?
19 A. No.
20 Q. Were you involved with ensuring that tl1e
21 facility was accredited?
22 A. No.
23
Q. Were you responsible for any staff training at
24 NARCONON?
25 A. No.
Page 51
1 Q. Did you know any of the nursing staff?
2 A Nope.
3 Q. Did you know anybody else besides Mary Rieser at
4 NARCONON?
5 A. 'I11e only other people I lmewwcre the drivers
6 who brought the clients to and from NARCONON to the
7 clinic.
8 Q. How did you initially become involved with
9 NARCONON of Georgia?
10 A. Mary Rieser contacted me saying that she was
11 looking for a physician to do physical exams on their
12 patients.
13 Q. Did she contact you by phone?
14 A Yes.
15 Q. And that was sometime in 2003?
16 A I believe so.
17 Q. Did you know Mary before that?
18 A No.
19 Q. Were you familiar with the NARCONON program
2 :> before that?
21 A. No.
22 Q. What did she tell you about the NARCONON
23 progran1?
24 A She told me that it was a drug-free program that
25
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Page 52

supplements as well as sauna therapy to help naturally i
detoxify patients who had substance abuse problems.
Q. Did you do any independent research on the I
NARCONON program? I
A. I tried to find some information on it but I i
guess I was looking in the \vrong spot. I really didn't 1
find much of anything.
Q. Where did you look? I'm sony.
A. I tried to look it up on the internet and I !
don't remember finding anything about it other than the
fact that I think they had a website that said, you know,
who they were and that they were a program that didn't
utilize medications or drugs or anything like that.
Q. Do you know how Mary Rieser found you?
A. She knew an acquaintance of mine who - '
Q. Who was that?
A. Her name is -- who I haven't heard from in a
long time. Let me look her name up. Dana Kuebler. l
Q. Is she a doctor? i
A. No. )
Q. How do you know --
A. K-U-E-B-L-E-R. She's a holistic practitioner l
who had referred some patients to me.
Q. She's .a holistic practitioner- she's not a
medical doctor. What does she do holistically? Is she a
Page
yoga instructor? I mean, that holistic practitioner -
explain that to me.
A. She has her own practice in which she helps to 1
naturally detox patients if they have roxie buildup of
toxic chemicals or parasites or something like that.
Q. How does she do that? 11
A. She uses sauna therapy, infrared sauna therapy,
I shoUld say. !
Q. And you do that as well? Well, you use infrared I
therapy; correct?
A. At my clinic, yes.
Q. Okay. And how did you become acquainted with
Mrs. -- is it Kruebler?
A. Kuebler?
Q. Kuebler.
A. K-U-E-B-L-E-R. Thafs a good question. I don't
know. I think she heard about my practice and she sent j
some patients over.
Q. Okay. Did you-- were you fiiends? I
A. Can I ask you a question?
Q. Not while a question is pending. I would ask
that you would just answer it and then if you -- i
A. Well, I don't !mow ifi'm allowed to say that, .
though. I
MR. TANNER: The question is are you !

involved using natural products like vitamins and
1 4 (Pages 50 t o 53)
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LISA ROBBINS, M.D. 11-5-10 Desmond, et al. vs . Narconon, et al.
Page 54
1 friends. 1
2 BY MS. FRANKLIN: 2
3 Q. Yeah; are you friends? 3
4 A. No. 4
5 Q. Wereyoufriendsatthetime? 5
6 A. No. 6
7 Q. Did you have any relationship with Mrs. Kuebler 7
8 outside of- 8
9 A. No. 9
10 Q. -- outside of sort of a referral or-- 1 D
11 A. I want to answer your question but I want to 11
12 make sure that it's okay for me to answer it. 12
13 Q. Well, I'd like-- 13
14 A. No, really, seriously. 14
1 5 MR TANNER: Do you have some legal concern? 15
16 THE WITNESS: It's just something I just 16
1 7 want to ask you real quick if I can. 1 7
18 MS. FRANKLIN: Let's just go off the record. 18
19 THE VIDEOGRAPHER: Going off the video 19
2 0 record at 4:30p.m. 2 o
21 (Brief recess.) 21
22 THEVIDEOGRAPHER: We'rebackonvideo 22
2 3 record at 4:32p.m. 2 3
2 4 :MR. TANNER: Having conferred with the 2 4
2 5 defendant, I now understand why she's having 2 5
Page 55
1 trouble with the question, and to the extent that 1
2 the question might potentially involve some sort 2
3 of HIP AA violation, I'm. going to instruct her she 3
4 can't answer that question. 4
5 BY MS. FRANKLIN: 5
6 Q. Okay. I understand Do you know how 6
7 Dr. Robbins -- I mean- excuse me-- Mary Rieser knew- 7
8 without disclosing any medical information that you may 8
9 have received as part of your role as a doctor, do you 9
1 0 know how Mary Rieser knew Mrs. - 10
11 A. Kuebler. 11
12 Q. Kuebler. I can't remember that. Do you kuow? 12
13 A. I think they were fiieuds. 13
14 Q. Okay. And so you- it's your understanding 14
1 5 that Ms. Rieser was referred to you and called you, told 15
1 6 you about the program. Did she give you any or send you 1 6
1 7 any written materials about NARCONON? 17
18 A. I think at one time I did receive a brochure 18
1 9 about it. 19
2 0 Q. Do you still have that brochure? 2 0
2 1 A. No. 21
2 2 Q. Any other information, written information that 2 2
2 3 was provided to you before you decided to begin to work 2 3
2 4 with NARCONON on the basis that you've explained? 2 4
2 5 A. That's it. 2 5
Page
Q. Okay.
(Plaintiffs Exhibit Nwnber 7
was marked for identification.)
Q. I might be going a little out of order here.
I'm going to give you what lin marking as Plaintiffs
Exhibit 7. I do not believe I have a copy.
MS. FRANKLJN: Melanie, this is titled
Executive Directive, Apri l 30, 2007. It's
NARCONON of Georgia to all staff and students.
It's a vitamin administration for the New Life
Detoxification Program. I believe it was
produced as a part of third-party request to DHR.
MS. EYRE: Thank you.
BY MS. FRANKLlN:
Q. Dr. Robbins, have you ever seen this document?
A. I don't recall ever seeing it.
Q. Okay.
A. I might have received it but I don't remember
receiving it.
Q. Well, it mentions the medical director for
NARC ON ON in several places and I just want to ask you
whether - well, let's just take the first sentence. '
It says a NARCONONNew Life Detoxification Care I
Plan shall be developed by the medical director before a i
student is admitted to NARCONON New Life detoxification 1
Page 57
Program.
Did you ever develop a New Life Detoxification
Care Plan for any student?
A. I lUlderstand that to be whatever the
recommendations would be based onon physical examination
of the patient.
Q. Okay. Do you know whether the forms that you
were provided, are they-- are any of them entitled New
Life Detoxification Care Plan?
A. They might be.
Q. Okay. Butyoujustdon'tknow?
A. Not off the top of my head. It's been a while.
Q. Do you provide any - or did you provide any
clients with any infom1ation relating to the risks and
benefits of taking vitamins and food supplements?
A. About the risks? No.
Q. Did you provide any patient wifu any infonnation
about the vitamins and food supplements that they were to
take as part of the NARCONON progran1?
A. It was my understanding that they were given
that information by the staff.
Q. Okay. So you didn't independently provide them
\v:ith any information about the vitamins they were going to
take.
A. No.
15 (Pages 54 to 57)
Q&A SERVICES, INC .
LISA ROBBINS, M.D. 11-5-10 Desmond
1
et a l . vs. Narconon, et a l .
Page 58
1 Q. All right. After you spoke with Ms. Rieser that 1 Q. Okay.
2 first time, did you begin to see patients that were 2 A. It just depended on how many people they had to
3 referred to you by NARCONON? 3 bring over.
4 A. Yes. 4 Q. Okay. How often- on average how often did you
5 Q. How soon after that frrst phone call? 5 see NARCONON patients?
6 A. I mean, we were already seeing patients. 6 A. Initially it was about once or twice a week
7 Q. From NARCONON? 7 Well, on average it was about once or twice a week
8 A. Yes. 8 Q. And was that consistent throughout?
9 Q. Okay. Well, I'm just trying to fmd out how you 9 A Yeah. It was about once or twice a week.
10 became involved with NARCONON and you said Mary Rieser 10 Q. All right. Did you do any research, medical
11 called you. 11 research about the sauna and exercise program that you
12 A. Oh,initially. 12 were-- thatMaryRiesertoldyouabout?
13 Q. Initially, yes. 13 A. I looked up infrared sauna therapy, did a little
14 A. Ob, yeah; I think pretty soon after I'd met with 1 4 research on that and found it to be really helpful for
15 her, within -I don't know-- a few weeks, I guess. 15 detoxification as well as other conditions, diabetes,
16 Q. Okay. 16 muscle problems. I
17 A. I don't remember offhand. 17 Q. Where did you look that up?
18 Q. You met with her after you had a phone call? 18 A. I looked it up on the internet.
19 A. Yes. 19 Q. Any particular -- I mean, Med Line, any
2 0 Q. Okay. How soon after the phone call did you 2 0 particular medical journal?
21 meet with her in person? 21 A. I don't remember. It was so long ago. l
2 2 A. I guess about a week after. 2 2 Q. Did you print- excuse me-- print out any of !
2 3 Q. And she came to your office; right? 2 3 that information?
2 4 A. Yes. 2 4 A. I probably did buti don't think I kept it. II
_____ Q __ ._An __ d_d_id __ sh_e_b_ rin_g __ __ be_r_M_Y_wn __ __________ -1_2_5 _____ __ __ __ th_e ____ -41
Page 59
1 materials?
2
A Some of the forms that they used.
3
Q. Okay. So she brought you the forms, and did
4
y'all go over how she'd like you to fiU those out?
5
A. Yes.
6
Q. Anything else she brought with her?
7 A. Like I said, she probably brought-- I think she
8 probably brought a brochure about the program.
9
Q. Okay. What else did you discuss at t hat time,
10
at that meeting?
11
A. I don't really remember what else we discussed.
12
Q. Did you discuss price?
13 A. I'm sure we did, yeah.
1 4 Q. Okay. Have you--
15
A. I think we probably discussed like when the
1 6
patient -- w-hen I could see the patients, when they could
17 bring them over and how long it would take, how many --
18 maybe how many people they could bring over, something
19 like that
20
Q. Well, typically did NARCONON send a group
21 together --
22 A. Yes.
23
Q. --to be seen? Okay. How many were--
24
A. Well, sometimes it \'V3S one. Sometimes it was
25 ten.
1
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:9
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24
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Page 61
internet to research the N;\RCONON sauna therapy program?
A. Not that I can remember.
Q. Did you feel that the saW1a program was
medically appropriate?
A. It seemed like it was probably a helpful thing
in terms of improving a patient's diet, nuo:ition,
providing them with supplements for vitamins they might be
deficient in that the body might need and utilizing sauna
therapy to try to pull out whatever toxins were in the
system.
Q. Okay. Did you make any independent medical
opinion as to whether the sauna therapy was effective in
treating drug dependency?
A. I do remember finding a few .. I don't know if
1hey were studies or articles online about that, and it
seemed to be effective.
Q. Do you remember the source of those studies or
articles?
A. No.

<
I

i
,f
i
1
I
I
Q. Did you print those out? f
A. I probably did but, like I said, I don't think I 1
keptthem. f
Q. Okay. Were you asked by Mary Rieser or anyone
at NARCONON to make a medical judgment about whether the
sauna program was an effective treatment for drug
.. .,_,.. ,_. ....
.......t=1.(:._y:+- .. --
16 (Pages 58 to 61 )
Q&A REPORTING SERVICES , INC.
404.233.3300 ** JFischer @QAReporting.com
LISA ROBBINS, M. D. 11-5-10 Desmond, et al . vs. Narconon, et al.
Page 62 Page
64 m
1 dependency?
1 therapy?

2 A. No. In. terms of-- I mean, overall generally,
2 A No. i
3
no. In a particular patienfs situation, I would write
3
Q. Do you have an opinion, a medical opinion about

4
down whether or not I thought infrared sauna therapy was
4 the usefulness of the salma therapy in drug dependent
I
5
helpful for a patient.
5 patients'?

I
6 Q. Okay. Andrmjust trying to distinguish.
6 A All I know is that the -- I mean, I'm not an

7 whether you made a detennination whether it was going to
7 expert on drug dependency so I really couldn't -
B be helpful for a patient or whether it was your job to
B Q. Okay. I just asked if you had an opinion.
9 determine whether the patient was eligible. Does that
9 A. No.
10
distinction make sense?
10
Q. Okay. Do you know what ASAM level NARCONON is
11
A. I see what you're saying, but I think the way I
11 licensed for?
12 looked at it, it seemed to me that my job was to see if
12 A. Probably 1.

13 the patient would be eligible to receive that kind of
13 Q. Are you familiar with the American -- I don't

14 treatment.
14 know if it's the American College of Addictionology or

15 Q. Right. And rmjusttrying to see if you were
15 Society of Addictionology, but you understand the term

16
ever asked to make a determination whether that type of
16 ASM1level; right? Or do you?

17
treatment would be medically not only appropriate but
17 A. No.

18 would help in a drug dependent patient, help resolve their
18 Q. Okay. Do you -- were you ever provided with any oi
19 drug dependency.
19 materials about NARCONON International?

,
20 .MR. TANNER: I'm going to object to the form
20 A. No.

21 of the question because I'm sitting here trying
21 Q. Do you know anything about NARCONON
'
22 to understand the difference between a program
22 International?
23 for which a patient is appropriate and a program
23 A. No.

24 for which the program is helpful. I mean. why
2 4 Q. Were you ever told anything about the

25 would you ever send a patient to a program that
25 relationship between NARCONON of Georgia and NARCONON

Page 63 Page 651
'/:.
1 was not helpful and say it's appropriate?
1 International?

2 BYMS. FRANKLIN:
2
A. No.
3 Q. Do you understand the question, Dr. Robbins?
3 Q. Do you know what, if anything, the role of

4
A. Yeah, I understand it.
4 Scientology, the Church of Scientology played in NARCONON

5
MR. TANNER: If you understand it, that's
5 of Georgia?

6
fine.
6 A. No.
I
7
THE WITNESS: I mean, I'm not sure if one
7
Q. Have you ever heard that there may be a

8 precludes the other. I mean, the way I
8 connection between the Church of Scientology and NARCONON

9 understood it, you know, it seemed as though
9 of Georgia?

1 0
there were no -- ifthere were no medical
10 A. I heard something about that.

!I
11
contraindications for a patient to undergo sauna
11
Q. Okay. what did you hear?
a
12 therapy, then that's what I relayed to the
12 A. That there might be a connection.
m
13 program.
13
Q. Okay. '\Vl10 did yoll hear that from? ;
14 BY MS. FRANKLIN:
14 A. One of the-- I think one of the clients.
I
15 Q. Right. But did you ever make any determination,
15 Q. One of the patients?
16 any medical judgment about whether the program would be
16 A. Yeah.
i

17
beneficial, would help resolve the drug dependency
17
Q. Okay. Did you ever discuss that with Mary

18
problems? In other words --
18 Rieser or anybody at NARCONON?
I
19
A. I mean, I wasn't-- it wasn't my understanding
19 A. No.

20 to be an expert on drug dependency.
20 Q. What was the nature of what ihe patient told you
i
21 Q. Okay.
21 about Scientology?
I
22 A. My job was to see if they would work well with
22 A. Just that that was something that they had heard
23 that, you know, particular procedure in the program.
23 that it was associated with.
i
24
Q. Were you ever asked to advocate for the
24 Q. And that was the extent of it?

25 usefulness-- for or against the usefulness of the sauna
25
A. Yep.
... r- . ..,-,,,.;,.
17 (Pages 62 to 65)
Page 66 Page 68

1 That's the only association 1hat you've ever 1 A. We would get paid at the time of service.

Q.

2 heard made between the Church of Scientology and NARCONON. 2 Q. So if a driver brought ten patients over, you

3 A. As far as I know. 3 would get a check for $7,500.
I
4 Q. You never r=ived any materials that reference 4 A. Yeah, but we never got that much, but right;
i
5 Scientology or Ron Hubbard or anybody associated with 5 that example is correct.

6 Scientology? 6 Q. I thought you said earlier that sometimes you'd
I
7 A No. 7 have ten patients.
<
8 Q. Are you yourself a member of the Church of 8 A. Yeah, but some of those patients were there for

9 Scientology? 9 followup.

10 A. No. 10 Q. Okay. Got you. Are you familiar with the
I
11 Q. How would you conununicate the results of your 11 Department ofHwnan Resources regulations as they relate

12 initial assessment of patients to the staff at NARCONON? 12 to drug and alcohol treatment facilities? I
1 3 A 1' d fill out the form that they provided and 13 A. No.
14 then I would make a copy of it and give the copy to 14 Q. Did you ever discuss the DRR regulations with
15 NARCONON and then we'd keep the original in the patienfs 15 Mary Rieser or anyone at NARCONON'?
16 chart. 16 A. No.
17 Q. Okay. And how would you get a copy to the folks 17 Q. So you don't know what those regulations require
18 at NARCONON? 18 from a medical director at any facility licensed under
19
A. We would give it to the drivers. 19 Georgia.

20 Q. All right In your discovery responses you 20 A. No, I don't know.
21 indicated that you were -- let me back up. How often 21 Q. Are you aware of any investigations by the i
22 would you talk with Mazy Rieser? 22 Department of Human Resources of a NARCONON facility?

i
23 A Not vety often; once a year maybe. 23
A No.

24
Q. And what circomstance would you have to 24
Q. Are you aware of any citations of noncompliance

25 communicate with Ms. Rieser? 25 relating to the medical director at NARCONON of Georgia?

:it:

Page 67 Page 69
i
1 A. If there was a patient that I didn't think: was
1 A. No.

2 medically appropriate to enter into the program.
2 Q. Were you ever contacted by anybody from the
3 Q. You would call her?
3 Department ofHurnan Resources during your entire

4 A. Yeah. I would have one of the drivers give her
4 relationship with NARCONON from-- strike that. Were you

5 a call and then I would talk to her and just let her know. 5 ever contacted by anyone from DHR about NARCONON?

6 Q. What other-- any other circumstance that you 6 A I did get a call once and they asked me what I
I
7 would have to speak with Ms. Rieser?
7 did and I said 1hat I did physical exams, intake physical
i
8 A. If there was a payment issue.
8 exams, and that was it.

9
Q.
Was there ever a payment issue? 9 Q. Do you remember when that was?

10 A. Yeah.
10 A. Four years -- maybe three, four years ago, I
11 Q. Tell me about that.
11 something like that.
'
12
A. If a check bounced.
12
Q. Was it a man or a woman that called you?
13
Q. How often did that happen?
13
A. A woman.
'
14 A. A few times.
14
Q. Do you remember her mune?
15
Q. More than five?
15 A. No.
-,
16 A. No. I think about four maybe, no more than five 16 Q. Did you make any written notes about that
i
17 times.
17
conversation?
18 Q. Okay. And would Ms. Rieser resolve that issue
18
A. No. I mean, it lasted as long as what I just

19 if you gave her a call?
19
said. They said what do you do with NARCONON, and I said

20 A. Yes.
20 what !just said. That was it.
I
21 Q. Okay. And would you- how would you receive
21 Q. Okay. Did you discuss that phone call with Mary
I
22 payment? Obviously by check. How often would you receive 22 Rieser at any point?

23 payment?
23 A. I did mention it to her and she was like -- she
I 24 A. Whenever they brought people over.
24 told me okay.
25
Q. You would get paid --
25
Q. Okay. After Patrick's death were you contacted
I
- ..... ... ..
18 (Pages 66 to 69)
Page 70 Page 72

1 by anyone from the Department ofHuman Resources? 1 25th- no; September 25th.

2 A. No.
2 Q. Okay. And at that point had he undergone the
I
3 Q. Okay. Let's talk about Patrick. Do you have an
3 medical detoxification at Peachford?
4 independent recollection of Mr. Desmond? 4 A. I don't know.
ii
5 A. No. 5 Q. Did you ever order patients to undergo a medical
I
6
Q. But you did, in fact, do a patient -- or an 6 detoxification before entering the NARCONON program?
7 initial intake on Mr. Desmond when he initially was
7
A. If they were going through heavy withdrawal,

8 admitted at NARCONON; right? 8 yes.

9 A. CotTect.
9 Q. Okay. Well, based on yotrr records, were you

10 Q. Okay. Did you bring your chart with you? 10 ever provided with any infonnation from Peachford Health

11 A. No.
11 relating to Patrick's medical detoxification?
i
;:.,!

12
Q. Let me give you a copy of what you produced in 12 A. No.
;
13 discovety when we asked for your medical records and 13 Q. Were you aware that he went through detox?
I
14 labeHng it Exhibit 8. 14 A. No.
15 (Plaintiff's Exhibit Number 8 15
Q. Does that -- is the decision to have a person go
16 was marked for identification.) 16 through a formal detoxification process, is that a medical
17 MS. FRANKLIN: And I've got one extra copy. 17 decision?
I 18 I got another copy of the NARCONON chart, which I 18 A To undergo a medical detox, I would think so,

19 think has everything in there ify'all need it.
19 yes.

20 :MR. BAR1LETI: I've got most of it here. 20
Q. All right. You saw Patrick on September 25th;

21 BY MS. FRANKLIN:
21 right?

22 Q. Okay. IfyouUjust take a look at E.xhibit 8, 22 A."
Correct.

23 Dr. Robbins, and let me know whether that looks like your 23 Q. And you saw him at the Robbins Health Alliance? :m
24 entire chart on Patrick Desmond. 24 A. That's correct.

25 A. Looks like it.
25 Q. That's your group? i
Page 71 Page 73
j

1
Q. Okay. If you will just-- before we get into 1 A. That's right.
i
2 Patrick's chart let me just ask you-- what was your 2 Q. Or it's your practice.

3 tmderstanding of the housing arrangements for the patients 3 A. That's right.

4 at NARCONON of Georgia? 4 Q. Okay. And what did you do?

5 A. I was just told that they stayed somewhere 5 A. I did an intake histmy and physical on him.
!
6
nearby while they were participating in the program.
6
Q. Do you remember whether that was at a time when
7 Q. And who told you that? 7 there were a group ofNARCONON students or patients in
.
8 A. Mary, Mary Rieser. 8 your office or do you remember?
i

9
Q. Did you ever have occasion to visit -- 9 A. I don't remember.
i
10 A No. 10 Q. Okay. And you read his lab results?
I
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Q. And were you ever told exactly where? 11 A. Yes.
I
12
A. No.
12
Q. Okay. And did you find anything significant in
13
Q. Did any of the patients that you saw ever 13 his lab results from the initial -- from your initial

14 discuss the housing arrangements at NARCONON? 14 intake?
I
15 A. Not really. I mean, I think there were people 15
A. He had a slight elevation in his liver function
16 who maybe didn't like their roommate or something but that
1 6
test.
17
was about it.
1 7
Q. Okay. And is that indicated in the AST and AL T
18
Q. Was it your understanding that the patients were 18 results?
19 free to come and go from the housing? 19 A. That's correct.
20
A. I didn't know anything about that. 20 Q. Okay. Is liver enzymes - or at least his AST .,
2:
Q. All right. If you'll just walk me through 21 should have been between 10 and 40; is that right?
22 your - each time you saw Patrick Desmond, and feel free 22 A. Right.
23 to use the medical records that are in front of you. When
23
Q. And he had an elevated enzyme level of 73;
24
was fue first time you saw Patrick?
24 right?
25
A Looks Like September 24th, 2007, or September 25 A. Right.
-, ."
19 (Pages 70 to 73)
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Page 7 4
Q. Okay. And his ALT was 60. What did that
indicate, if anything, to you?
A. That he was having effects of drug abuse and/or
detoxing off of drugs, liver involvement.
Q. In your history did you ask him -- did you take
a drug history?
A. Yes.
Q. Okay. What drugs did he tell you -- or what
substances did he tell you he bad used in the past?
A. It says drug history, including past detox
episodes, THC, opiates, cocaine and meth.
Q. Could the elevated liver enzymes also indicate a
lristory of alcohol abuse?
A. Yes.
Q. Can you distinguish drug abuse versus alcohol
abuse based on anything in Iris lab results?
A. We did a urine drug screen. It all came back
negative.
Q. So you don't believe there were any drugs in his
system at the time you saw him.
A. By the time he can1e to me, probably not.
Q. Okay. Back to my question about the liver
enzymes, could you - well, any of his lab results. Could
you make a determination about his drug use versus alcohol
abuse based on any of his lab results?
Page 75
A. No.
Q. And you determined thai he was -- well, lees
look at your note on 9-25-07. It looks like your physical
exam- you write down at the bottom the diagnosis and
treatment, if you'll just read that into the record
Well, first of all, is that your handwriting?
A. I'm trying to fmd it.
Q. Okay. Ifs about four pages in. Sony. This
copy is ~ o t Bates mnnbered. Actually, it's on the second
page, the back of the first page. Well, that' s a
different date.
A. I found it. Are you talking about the -- what
did you ask again?
Q. If you could go fom or five pages in, there's
your physical assessmenton9-25-07. Youmake some
hand-wTitten notes and I just want you to read that into
the record.
A. I'm not exactly sure what page you're talking
about but there's a page v.rith his vital signs on it. Is
that what you mean?
Q. Yes.
A. Okay.
Q. And is it dated 9-25-07?
A. Yes.
Q. Okay.
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A And I've got that his physical assessment was
normal.
Q. Okay. And there's some handwritten notes down
at the bottom under diagnosis and treatment?
A Right; that he has a history of polysubstance
abuse and recommended -- is that what you're talking
about?
~
Q. Yes; if you'll just read your handwritten notes. ~
A Okay. Infrared sauna therapy, living foods ; .~
diet, exercise and antioxidant vitanrins.
Q. Okay. What is living foods diet? ~
A Living foods is like raw foods, organic foods. ~
Q. Okay. Is that something that you -- J
A That's what I recommended. ~
Q. Is that what you normally -- were you asked by ~
NARCONON to make a recommendation as to diet? ~ ~ - -
A They would ask me recommendations based on this
patient's situation, and a living foods diet is actually
really helpful for detoxification. i
Q. Okay. And based on the lab results, was there !
~
any other -- anything else abu01mal or out of range from ~
the lab results that were part of his initial assessment ~
besides the liver enzymes we just talked about? li
A. Other than a slight increase in total protein, ~
but that's not really significant. No; that was it. I
Page 77 ~
Q. Okay. Do you believe that the-- based on his
elevated liver enzymes that he was still an appropriate
candidate for the sauna program?
A. Yes,Ido.
Q. Wby isthat?
A. Because sauna therapy has been found to be
really helpful for liver detoxification, as shows on the
neAt set of Jabs.
Q. Okay. And besides -- I understand what you're
about to say, but based on what medical research?
A. I don't have any medical research to give you
right now.
Q. Okay. Just based on your own experience.
A. Yes.
Q. Okay. Anything besides the physical assessment
and the labs that you did on the initial meeting with
Mr. Desmond?
A. HisEKG.
Q. Okay. Was that found to be normal?
A. Yes.
Q. Okay. Anything else?
A. I guess thaes it.
Q. All right. When's the next time you saw
Patrick?
A. October 26th, '07.
I
I
20 (Pages 7 4 to 77)
Q&A REPORTING SERVICES , INC .
404.233.33 00 ** J Fischer@QAReporting . com
LI SA ROBBINS, M.D. 11-5-10 Desmond, et a l . vs. Na rconon, et al.
Page 78 Page 80
1 Q. And was that for his followup visit? 1 TilE VIDEOGRAPHER: This begins tape number
2 A. That was his followup visit. 2 2. We're back on video record at 5:22p.m.
3 Q. Allright. Anddoyouhaveanyindependent 3
4 recollection of that? 4 Q. Dr. Robbins, is there anything else that you did
BY MS. FRANKLIN:
5 A. No. 5 beside the physical examination and the lab work during
6 Q. And you took Jabs then as well? 6 the followup visit on October 25th, 2007?
7 A. Yes. 7 A. No.
8 Q. And what were those results? 8 Q. Now, when was the next time you s a w ~ - Desmond?
9 A. Much improved from the flrst visit in tenns of 9 A. December 17th.
1 0 his liver function. 1 o Q. Okay. What was that for?
11 Q. What was his AST level? 11 A. Looks like he had an upper respiratory
1 2 A. AST was 46, which is very good. 12 infection.
1 3 Q. Is it still elevated? 1 3 Q. Do you have an independent recollection ofthat?
14 A. Only mildly, but thafs not significant enough 14 A. No.
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1 5 elevation to really cause alarm. 1 5 Q. Okay. Would a patient who came in for a non -- ~
1
17
6 Q. Okay. Do you have an opinion as to whether the 1
17
6 or for a visit that. was not an initial intake, would the I
decrease in liver enzymes was a result of his sobriety? NARCONON vans still drive or bring them there? l
18 A. I'm sure that definitely played a huge part in 18 A Yes. ii
19 that. 19 Q. And did you prescribe anything for Mr. Desmond
2 0 Q. 'iVbat did you do atthat visit? 2 0 that visit? I
21 A. Checked to see bow he was doing, how he was 2 1 A. Yes; an antihistamine and a decongestant. i
2 2 feeling, drew his labs. That's it 2 2 Q. Okay. Did you do any lab work at that time? i
2 3 Q. Okay. And you signed a medical discharge that 2 3 A. No. ~
2 4 says New Life Detoxification Plan? I believe that was- 2 4 Q. All right. Anything else besides a physical !
2 5 we've already separately identified that as Exhibit -- you 2 5 examination that you did on that visit? ~
r - - - - - - - - - ~ ~ - - ~ - - - - - - - - - - - - - - ~ - - - 1 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ ~
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Page 79 Page 81 ~

a
see it? Okay. We've already talked about this particular 1 A No. ~
document. 2 Q. When's the next time you saw Mr. Desmond? i
A Yes. 3 A 2008; I think June 3rd, 2008. 1
Q. And you told me that you didn' t write these 4 Q. Okay. And do you -- what was that for? ~
notes here at the top; right? 5 A. To do another intake physical for hin:l. ~
A Right. The nurse apparently did. 6 Q. What was your understanding of why you were to i
Q. The nurse-- one of your nurses? 7 do another intake physical? ~
A No. 8 A He was going back into the program. !
Q. Okay. Thiswasanurseatthe-- 9 Q. Okay. Andhow didyou.kn.owthat? i
A NARCONON. 1 0 A. Because he presented to me as a patient that -
Q. Okay. How did you -how would this have gotten 11 needed to go into the program.
in your chart'? 12 Q. Did you !mow that he had-- you see a lot of
A. They would bring it over to me, the driver, one 13 these patients so did you know that you had seen him
of the drivers. 14 before?
Q. Would bring doc\llllents that you needed to sign? 15 A Yeah. I mean, we had his chart.
A Yes. 1 6 Q. Okay. Do you know how long he had been out of
Q. Okay. Is that your signature at the bottom? 17 the program when you saw him on June 3rd?
A Yes, it is. 18 A I don't remember.
THE VIDEOGRAPHER: Ms. Franklin, I'm sorry. 19 Q. Is that something you would normally ask the
I need to go ahead and change tapes. 2 0 patient?
MS. FRANKLIN: Okay. That' s fine. You can 21 A. Yes.
go ahead and change. 2 2
THE VIDEOGRAPHER: Going off video record at 2 3
5: 14 p.m. This is the end of tape number 1. 2 4
(Brief recess.) 2 5
- - ~
Q. Do you see anywhere in your notes where you had
any discussion about his reenrollinent at NARCONON?
A. No.
Q. Does the fact that a patient has for whatever
21 (Pa ges 78 to 81)
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Page 82
reason left the program and reenrolled-- does that have
any bearing on your assessment of their eligibility to
participate in the sauna program?
A. No.
Q. Okay. And if you can just read for me on the
6-3-08 physical examination note just like you did on the
initial intake Wlder diagnosis and treatment.
A. Polysubstance abuse, infrared satma therapy,
exercise, living foods diet, antioxidant vitamin therapy.
Q. So that's exactly what you prescribed the first
time.
A. Yes.
Q. And you did lab tests at that point?
A. Yes.
Q. Was there anything significant or out of range
in Mr. Desmond's lab test on the Jooe 3rd?
A. No.
Q. He didn't have elevated liver enzymes on the
3rd?
A. I'm trying to go through all-
Q. I know. I apologize. l11ey're not in very good
order.
A. He did have an elevated AS T but his ALT was
normal.
Q. Okay.
Page 83
A. Alkaline phosphatase was normal.
Q. Okay. And presumably you found him to be an
appropriate canctidate for the sauna detox.
A. Yes.
Q. What was the next-- did you ask Patrick what
vitamins he's currently taking - he was currently taking
at that time?
A. No.
Q. Is that a question you typically ask patients?
A. No, not these patients.
Q. Were you prescribing them--
A. These patients usually aren't taking vitamins.
Q. Okay. When you prescribe a vitamin regimen such
as the one that is utilized by NARCONON, is it important
to know what vitamins patients are ti:!ki.ng before adding
additional vitamins?
A. The only things that they're taking are what -
from what I understand, the only vitamins that they're
taking are the vitamins that NARCONON's giving them.
Q. Okay. And what do you base that on?
A. That's what Mary told me-- Mary Rieser told me.
Q. Okay. When did she tell you that?
A. I don't know what day.
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Page 84
A Yeah; probably around the first meeting we had
about the program.
Q. Okay. Wbat independent research did you do into J
the effectiveness of a vitamin regimen such as the one
utilized by NARCONON?
A. What do you mean independent research?
Q. Did you do any independent research about this
vitamin regimen? I mean--
A. 'This is a decent vitamin regimen. I would
probably -- I mean, I didn't have any problem with what
they were prescribing, the way they were doing it.
Q. Were they prescribing it or were you prescribing
it?
A. Well, they were administering it.
Q. But you were authorizing it.
A. I v.>asn't giving it to the patient. I was
authorizing it.
Q. Sure. Okay. And what I need to know is why you
believed that these patients needed these high Level of
vitamin doses.
A BecaiJSe they're usually vitamin deficient;
they're nutritionally deficient.
Q. All right. Did you ever take any sort of- do
any assessment of a person's vitamin levels before --
A. No.
Q. So it's just in your experience they were
vitamin deficient.
Page
A. Well, most of the folks who were coming into the
program didn't seem to be doing a very good job in te1ms
of, you know, good nutritional balance.
Q. Okay.
A. But also, you know, this is what the N.ARCONON
program recommended and I agreed with it.
Q. Did NARCONON provide you with any mectical
research or literature to suppmt this vitamin regimen?
A. No, but probably over the years I've come to see
several patients who don't have substance abuse with
significant vitamin deficiencies.
Q. Okay. But in order to know that they're
deficie:nt you have to draw some smt of vitamin level or
make that determination.
A Not necessarily.
Q. Okay. How else would you determine that a
patient's vitamin deficient?

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A I guess looking at their history of the fact i
that they may be having, you know, muscle aches or
whatever kind of complaints they might be experiencing or

describing, headaches, fatigue. 1
Q. When you initially - when she initially
contacted you? 25
Q. Do you ever draw any or assess vitamin levels
_ _ _ __ I
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LISA ROBBINS, M.D. 11-5-1 0 Desmo nd, et al. vs. Narconon, et al.
Page 86
1 patient? 1
2 A. Depends on the patient and it depends on what 2
3 \Ve're looking for. 3
4 Q. Did you ever do it for any of the NARCONON 4
5 patients? 3
6 A No. 6
7 Q. Okay. Do you believe this vitamin regimen is 7
8 appropriate for a patient with an already compromised B
9 liver? 9
10 A Yes. 10
. 11
12
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Q. And what-- again, you've told me about your 11
experience, but besides your experience, anecdotal 12
experience with patients, do you have any medical research 13
or literature to support that? 1 4
A I'm sure there's literature out there but I 15
don't have any on me right now. 1 6
Q. Do you have any knowledge about the reasons 1 7
Patrick came-- was reenrolled at NARCONON? 18
A Off the top of my hea_d I really couldn't tell 19
you. 20
Q. Okay. Based on your entire chart, is there 21
anythjng jn the medical records that suggests that Patrick 2 2
had any history of heroine use or abuse? 2 3
A. Only what he admitted to and what we found or 2 4
didn't find in his drug screen, his urine screen. 2 5
Page 87
1 Q. Okay. Well, he didn't admit to any past heroine 1
2 abuse, right, or use? 2
3 A Right. 3
4 Q. And he didn't -- there was no evidence of such 4
5 in the lab reports; right? 5
6 A. Correct. 6
7 Q. Were you contacted by anyone after Patrick's 7
8 death? 8
9 A. No. 9
1 0 Q. What's your understanding of what happened to 1 0
11 Patrick on the night he died? 11
12 A. Only what y'all send me. 12
13 Q. Okay. And I don't want to know anything that 13
14 your lawyer bas told you but-- let me put it this way. 14
15 Have you spoken with Mary Rieser about Patrick's death? 15
16 A. No. 16
17 Q. Have you spoken with anyone at NARCONON about 17
1 B Patrick's death? 18
19 A. No. 19
2 0 Q. How did you learn about it? 2 0
2 1 A. Through y'all. 21
2 2 Q. The lawsuit. Okay. Obviously, you told me that 2 2
2 3 you quit working with NARCONON in 2008 and I asked you 2 3
2 4 when. Obviously, it was after June 3rd, 2008; correct? 2 4
2 5 A Correct. 2 5
Q. Because you saw Patrick on the 3rd.
A. Correct.
Page
Q. Do you know how soon after that you quit working
with N.'WCONON?
A. I don't know.
Q, Is that somethlng that you could find out based
on your records?
A. No, because I never really got anything in
paper. Ijustgot -she just stopped sending me clients.
Q. Okay. Did you have a discussion with Ms. Rieser
about it?
A. Eventually. And she just told me our prices
were too high. They couldn't afford the costs. They had
to cut costs. And they found a clinic that was closer to
us -- l mean closer to them. They wanted me to - she
wanted me to start trying to bill insurance for these
visits and I told her that I wouldn't do that.
88 ~
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Q. Okay. So you told me earlier you saw patients,
NARCONON patients approximately or on average one to two ~
times a week; right? i
A. Right. ~ - ~
Q. Did you just stop seeing them completely or did ~
it sort of trickle off? ~
A. It kind of trickled out. ~
Q. Okay. And when you realized that patients were I
Page 89 i
no longer coming from NARCONON, did you make a phone can ~ ~
to Mary Rieser?
A. Yes, and left a message on her cell phone and ~
she called me b a c ~ later on. . ~
Q. Okay. Besides what you j ust told us, was there ~
anything else that you discussed dl.ll'ing that phone call? ~
A h
.
. T at was 1t. ~
Q. Okay. And have you seen Mary Rieser since then I
personally? ~
A. Seen, heard, nothing. ~
. 4
Q. Cost was one of the reasons that Ms. Rieser ~
indicated for going with another physician? ~
A Cost and location. ~
Q. Okay. ~
A. It wasn't the first time she's used other
doctors. She was using us for a while earlier and then
she started using another doctor near her.
Q. When was that?
A. I don't know. 2005 or something like that,
2006,2005.
Q. \Vhat other doctor did she use?
A. It was -- l'm sorry -- an Indian doctor. I
don't remember his name.
J
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Q. Did you have any discussions with her about why J
-"'n-- - ~
she was using another doctor?
23 (Pages 86 to 89)
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LISA ROBBINS, M.D. 11- 5- 10 Desmond, et al. vs. Narconon, et al.
Page 90
1 A. he was close by.
2 Q. Okay. So you asked her why you weren't seeing
3 any of the patients?
4 A. Yeah.
5 Q. And she responded by saying because he was
6 close?
7 A. Yep.
8 Q. And how long did she send patients to that
9 doctor or another doctor?
1 0 A. I really don't !mow. She never told me.
11 Q. Well, under what circumstance did you start
12 seeing patients again?
13 A. I was told she didn't like that doctor and
14 wanted to come back to see us.
1 5 Q. She told you that?
16 A. The driver did.
17 Q. Okay. So just one day a driver with some
18 patients showed up?
19 A Well, they called and asked if we wanted to
2 0 start seeing -- if we had openings for them to bring some
21 backin.
2 2 Q. Okay. Any other time during- between 2003 and
2 3 2008 that there was -- that you believe Ms. Rieser sent
2 4 patients to another physician?
2 5 A. Oh, I'm sure she was doing it the whole tin1e.
Pag e 91
1 Q. What do you base that on?
2 A. The fact that there would be long $tretches of
3 time when we wouldn't get any NARCONON patients.
4 Q. Okay. How many times were there long stretches
5 of time where you didn't see NARCONON patients?
6 A. How many times did that occur?
7 Q. Yes.
8 A I don't know. Maybe four or five times.
9 Q. When was the last time that you remember there
1 0 being some long stretch without seeing NARCONON patients?
11 A. Before --
12 Q. Before the .final.
13 A. -- she stopped?
14 Q. Yeah.
1 5 A. I don't know. I don't remember exactly dates or
1 6 anything.
1 7 Q. Was it after 2006?
1 8 A. Yeah, it would have been after 2006 but it was
19 before - I mean, there was some -- some times occmred
2 0 before 2006 and some after.
21 Q. What do you consider a long stretch of time?
2 2 A A month or at least two weeks.
2 3 Q. Okay. Do you know specifically of any other
2 4 physicians that Ms. Rieser sent patients to besides the
2 5 Indian doctor that you referenced?
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Page 92
l
A. The only other one was -- that I knew of was the
doctor that was near her, that was nearby her. They had
an urgent care center, she said, and they could get them !
in and out.
Q. Do you know the name of that urgent care center? I
A. No.
Q. How often were you ever called -- well, strike
that. You told us earlier that you were required to be on

call, the on-call physician based on the terms of your
contract; right?
ever called when you were outside the I
office or called as part of-- I
A Like late at night. I
Q. Yes.
A Yeah. Not often, though.
Q. Tell me every time you remember being called.
A. Every time that I was called-
Q. Every time that you remember.
A. Probably around 2004-2005 I got calls about
patients having withdrawal sympt oms and I would advise
them to go to the emergency room so that they could get
immediate care.
Q. Okay. Was this on a number of occasions?
A. I guess what do you define as a number of
1
Page 93
occasions?
Q. Well, bow many times do you remember being
called about patients having withdrawal symptoms?
A. Maybe five or six times.
Q. Okay. And who would call you?
A. I got calls from patients a couple of times.
Q. Directly?
A. Yeah.
Q. How did they get your nwnber?
A. They have my card.
Q. You give them your card?
'l
i

I
I

A. Well, I mean, it was available for anybody to
pickup.
Q. Okay.
A. Other times it was from one of the NARCONON
employees.
Q. All right Did Mary Rieser ever ca11 you?
A. No.
Q. What other NARCONON employees called you after l
hours?

A. I don't know their names but I think I got maybe
two or three calls from NARCONON employees and the other
calls were from the patients themselves. i
Q. Okay. What do you remember specifically about J
the two or three calls from the NARCONON employees?
,- .,.. --- -.... .,
24 (Page s 90 t o 93)
Q&A REPORTING SERVICES, I NC.
404.233.3300 ** JFischer@QARepor ting . com
LISA ROBBINS, M.D. 11-5-10 Desmond, et a l . vs . Narconon, et al.
Page 94
1 A. They were letting me know that the patient was 1
2 having withdrawal symptoms and I would recommend that they 2
3 take them to the emergency room. 3
4 Q. Any other instance? 4
5 A. I think I got a call one night because somebody 5
6 had a cold. 6
7 Q. Anything else? 7
8 A. No. I can't remember anything else. B
9 Q. Okay. Do you know whether Patrick considered 9
1 0 you to be his doctor? 1 0
11 A. No. 11
12 Q. You don't know or you-- 12
13 A. I don't know. 13
1 4 (Plaintiffs Exhibit Number 9 14
15 was marked for identification.) 15
16 Q. Now we'll mark as Exhibit 9 a document and ask 16
17 if you have ever seen that document 1 7
1 8 MS. WHITLOCK: This is 9? 1 8
on this form.
BY MS. FRANKLIN:
Q.
A
You can answer the question.
I don't know.
(Plaintiffs Exhibit Number 10
was marked for identification.)
Page
Q. Okay. I'm going to hand you what I'm marking as
Exhibit 10.
MS. FRANia..IN: I don't have copies but,
Melanie, it's another application for a license
to operate a drug abuse treatment and education
program. It's dated 8-04-2005.
MS. EYRE: Thank you.
MS. WHITLOCK: Does it have a Bates number
on it?
MS. FRANKLIN: No, it does not have a Bates
number on it.
BY MS.
19 MS. FRANKLIN: Yes. 1 9 Q.. If you'll just take a look at that and tell me
2 0 MR. TANNER: Is there a question on the 2 0 whether you've ever seen it
21 floor? 21 MS. WHITLOCK: Can you pass it down this way
22 MS. FRANKLIN: rd asked her if she'd ever 22 and let us take a look at it before you question
2 3 seen that document. 2 3 her about it? .
2 4 THE WITNESS: No. 2 4 :MR. TANNER: The only question on the table
2 5 2 5 is whether or not you've seen that particular

Page 97 f Page 95
1 BY MS. FRANKLIN: 1 document.
2 Q. Okay. Would you agree with me that Patrick 2 THE WITNESS: I'm sorry?
3 noted you as his physician? 3 BY MS. FRANKLIN:
4 I'v1R.. TANNER: Letmeobjecttothefonnof 4 Q. Haveyoueverseenthatdocument?
5 the question. Nobody has identified this as 5 A. No.
6 being signed by anybody. TI1e record speaks for 6 Q. Okay. You'll notice on the back page that it
7 itself. The doctor -- someone wrote in 7 indicates under the same category of information we
8 Dr. Robbins' name. 8 discussed in one of the prior documents medical director,
9 BYMS. FRANKLIN: 9 a place for medical director to be identified and it does
l 0 Q. Can you answer the question, Dr. Robbins? 10 not- it has not applicable; correct?
11 MS. EYRE: Can I ask what document it is? 11 A. That's what it says.
1 2 MS. FRANKLIN: Actually, I don't have one 12 Q. Okay. And then the next line lists --
i
t
1
l!

13 right in front of me. 13 references you as the doctor who does the initial client
14 MS. WHITLOCK: It'sDesmondD-GA0179and 14 assessment; right?
15 0180. 15 A That's1ight. 1
16 MS.EYRE: Thankyou. 1 6 Q. Doyouknowwhyyouwerenotnamedasthe
17 THE WITNESS: I'm sorry. What's the 1 7 medical director in that exhibit but you were in the
18 question? 18 exhibit we looked at earlier? I don't remember what j
19 BY MS. FRANKLIN: 1 9 number.
2 0 Q. Would you agree with me that that document 2 0 A. I don't know. I
21 indicates that Patrick identified you as his physician? 21 Q. Okay. Did you ever have any discussions -.,vith
2 2 MR. TANNER: I'm going to object to the form 2 2 anyone at NARCONON about that?
23 again because-- 23 A No. J
24 MS. FRANKLIN: Youcananswer, Doctor. 24 Q. DoyouknowaMr.orDr.NathanielJohnson? d
2 5 MR. TANNER: -- Dr. Robbins' name isn't even 2 5 A. No. I
,., s->'-",_..,_.,.,--"'"""f '$k""' 1'' \ v, ... ....,..,..,. ..,. ..... .,....,
25 (Pages 94 L O 97)
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Page 98 Page
100
Q. Have you ever - since the initial contact from 1 Alliance. It's a d/b/a.

Mary Rieser have you ever looked at NARCONON's website? 2 Q. Okay. How long have you had your practice?

I
A. No. 3 A. Since December 2000.

Q. I'm jumping around here a little bit and I 4 Q. And are you -- do you have any education or
I
apologize, but what is your typical rate for-- okay. 5 training in addictionology?
Strike that. Let's say you did a physical exam and lab 6 A. No.
I
tests on a patient that was not a patient ofNARCONON. 7 Q. rm going to give you, if I can find it, a copy
What would your typical rate be? 8 of yom CV that you produced in this case.
i
A. If that means doing the same things with 9 (Plaintiffs Exhibit Number 11
i

everything included, close to 500. 10 was marked for identification.)

Q. And what was the basis of a higher fee, rate for 11 Q. If you'll just take a look at it and let me know
J
NARCONON patients? 12 if you have anything to add or amend to your CV.
A. Because of the followup visits and the lab work 13 MS. WHITLOCK: What number are we up to?
I involved and if they needed to come in any time in between 14 MS. FRANKLIN: 11.
for anything. 15 BY MS. FRANKLIN:
I
Q. And being on call? 16 Q. Do you have anything to add or amend to this CV?
A. Right. 17 A. I'm a member of the American Society of s
Q. Have you ever reviewed any medical records or 18 Nutrition.
have you ever reviewed, yeah, any medical records from the 19 Q. Okay. Anything else?
GBI? 20 A. That's it.
.
A. GDI? 21 Q. You note that you're the medical director of the

Q. Or any records. 22 Robbins Health Alliance. Do you-- well, why didn't you
a
l\.1R. TANNER: About him, the deceased? 23 reference your affiliation with NAR.CONON on your CV? I
MS. FRANKLIN: Yes. 24 A. Because I didn't think it warranted that.

THE \VITNESS: GBI --no. 25 Q. Okay. And why not?

Page 99 Page 101 t
BY MS. FRANKLIN:
1 A. I didn't see any reason to add that to it. I'm
i
;
!i
Q. Did you review the DeKalb County medical
2 not - I mean, I was just seeing their patients.

"'
examiner's report?
3 Q. Okay. And this may make it easier because
I
A. No.
4 currently you don't have an affiliation with NARCONON;
Q. What other documents besides the patient's chart
5 right?
have you reviewed in preparation for your deposition?
6 A. Well, right now; right.
j
A. Mainly the records and this -- 7 Q. Have you ever referenced NARCONON on your CV? I
Q. The contract?
8 A. No. I
A. The service agreement.
9 Q. What did you -- you did youl' - let me just back
I
Q. Okay. Anything else?
10 up. Arc you originally from Georgia?
A That's it.
11 A. No.
Q. I think I know the answer to this but did you
12 Q. Where are you from?
come to the hospital the night Patrick died? 13 A. Texas.
I
A. I didn't know anything about it.
14 Q. And you went to -- you got your bachelor in
Q. Okay. And no one from the medical examiner's
15 biology at Austin College in Texas; right?

i
office contacted you after his death.
16 A. Correct.
I A. No.
17 Q. Okay. And you got your M.D. in Texas and then

Q. Tell me a little bit about your separate 18 you did your internship and your residency. Did you do
I
practice, the Robbins -- well, tell me the name of your 19 your internship in any particular area of medicine?
I
group or your practice.
20 A. Internal medicine.
A. The Robbins Health Alliance.
21 Q. Sorry. I should have read the following
Q. Okay. We named-- I don't have it right in
22 sentence. What about your residency; same?
i
front of me but The Robbins Group as a defendant in this
23 A. Same.
I
case. Is that the name of your practice?
24 Q. Okay. Did you take any classes during medical

A The Robbins Group is the Robbins Health 25 school relating to addictionology?
..
...... .....
26 {Pages 98 to 101)
404.233.3300 **
http://ReachingFForTheTippingPoint.net
Page 102 Page 104

1 A. No. 1 MR. TANNER: Let her ask -- she'll ask the

2
Q. Besides your experience with the NARCONON
2 question. I
3
patients, do you have any experience with treating
3 BY MS. FRANKLIN:
i

4
patients for drug or alcohol dependency?
4 Q. Let me rephrase it You mentioned that

5 A. No.
5 NARCONO}.. '"'s patients contacted you directly a couple of
i
6 Q. Do you currently treat or see patients with a 6 times.
I
7
drug or alcohol dependency?
7 A Correct. i
8 A. No.
8 Q. You didn't consider yourself to be an emergency

I
9
Q. Do you subscribe to any publications that relate
9 hotline to assist clients, did you, or did you?

10
to addiction medicine?
10 A. In what terms?

11
A. No.
11 Q. Well, you were- under the tetms of the
I
1 2 Q. Has your license, your medical license ever been 12 contract you were to be available 24 hours a day; right?
13 suspended or revoked?
13 A Right.
1 4 A. No.
14
Q. So you would have taken a call from a NARCONON
-
15
Q. You identified two lawsuits in response to your
15 patient.
16
discovery request, if you'll just give me a general idea
16.
A. Right.
i
17 of the allegations in those lawsuits. The first was a 17 Q. Because you considered them to be your patients.
18 Brooks versus Robbins.
18 A. Right; during that period of time while they I
19 A. Patient came in with testicular pain. I
19 were in the program, if they needed anything while they I
2 0 diagnosed him with epididymitis and be later developed
20 were in the NARCONON program.
21 torsion of the testicles -- one testicle.
21 Q. Are you familiar with the clinical director or
2 2 Q. Do you know where that action was pending?
22 were you familiar with the clinical director at NARCONON?
2 3 A. It was settled. 23 A. Who was the clinical director? I don't know.
2 4 Q. Settled, but was it here in Georgia?
24 If it wasn't Mary, then I don't know.
i
I
25 A. Yes.
25 Q. Okay.

Page 103 Page 1 os I
1
Q. Do you know what county it was in? 1 A. She's executive director.
I
2
A. 2 MS. FRANKLIN: Okay. I probably have a
3
Q. "What about the Darden versus Robbins? 3 couple of followup but I need a few minutes to
I
4
A. Patient later developed renal failure, did not 4 look over my notes. Take a break.

5 follow up with me, and there was no knowledge provided 5 1HE VIDEOGRAPHER: Going off video record at '
,,
tl
6 that there was a family history of renal disease. 6 6:04p.m.

i
7
Q. What did the patient initially see you for? 7 (Brief recess.)
I
8 A. Headaches. 8 1liE VIDEOGRAFHER: We're back on video
il
9
Q. And was that case resolved before trial? 9 record at 6:09p.m.
I
10 A. Yes. 1 0 BY MS. FRANKIJN:
I
11 Q. Who all have you discussed this case with? 11 Q. Dr. Rrlbbins, just a couple of foUovmp
12
MR. TANNER: I assume you mean other than 12 questions. We talked a lot about your experience or your
13
me. 13 opinions relating to the sauna and the vitamin regimen J
14
BY:MS. FRANKLIN: 14 provided at NARCONON; right?
I 15 Q. Besides laVv)'ers.
15 A. Right.
16 A. That's it. 16 Q. Okay. Can you provide us \\>ith any specific
I
1 7 Q. No one from NARCONON? 17 literature oc infonnation that support your opinions --
I
18 A. No. 18 well, strike that. Do you know of any specific literature
19
Q. Do you know whether NARCONON had an emergency 1 9 that addresses these type of programs as they relate to
I
20
hotline, so to speak, a 24-hour emergency hotline 2 0 drug dependency or drug dependency and recovery? I
21
available to patients? 21 A. No.
I
22
A No. In tenns - I'm sony. I'm not sure what 22
Q. Did NARCONON or anyone :fium NARCONON ever
23 you mean by that. 23 represent to you that the facility was a residential or

24
Q. Well, you mentioned that NARCONON's patients - 24 inpatient facility?

25 A. You mean in order to contact me? 25 A. I was under the impression that the people who
I
'
.
eztn ? ?f'i"'t'- "' = ==- >'&m
......
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27 (Pages 102 t o 1 05 )
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Page 106
participated, they stayed at a location and then they went 1
to NARCONON to participate in the program. That's all I 2
know. 3
Q. Okay. And that was based on conunents :fi:om the 4
patients. 5
A. From the patients, yes. 6
Q. Okay. Did Mary Rieser ever represent to you one 7
way or the other \\nether NARCONON was a residential 8
facility or tiuly an outpatient facility? 9
A. Not really, no. 1 0
Q. Did you - forgive me ifl've already asked you 11
this. Did you meet anyone besides the patients and 12
besides Mary Rieser personally-- did you meet anyone from 13
NARCONON that worked with or for NARCONON personally? 14
A. The only other people I met were the drivers. 15
Q. The drivers. Okay. That's all I have right 16
now. Thank you for your patience, Doctor. 17
MS. WHITLOCK: I don't have anything right 18
now.
MR. TANNER: Any other questions?
MR. BAR1LEIT: I've got a few real quick.
19
20
21
EXAMJNATION
BYMS.EYRE:
Q. Yeah. Dr. Robbins,hi. I'msorrytobedoing
this-by phone. My name is Melanie Eyre and I represent
Delgado Development. Can you hear me okay?
A. Yes.
Q. Have you heard of that entity, Delgado
Development, Incorporated?
A. Only related to this case.
Q. Have you ever had any conversations with a
person nan1ed Maria Delgado?
A No.
Q. How about Don Delgado?
A. No.
Q. Do you have any understanding of the
relationship, if any, between Delgado Development and the
claims in this lawsuit?
A. No, not until this case came up.
Q. Okay. Do you remember the names of any of the
drivers you met?
A. One; Deborah Toth, T-0-T-H. Her name's on the
2 2 record, the medical record.
EXAMINATION 2 3 Q. Okay. Anybody else or is that it?
BYNlR. BAR1LETI: 2 4 A. There were several different drivers but I'm
Q. Dr. Robbins, I'm Shane Bartlett. I'm here on 2 5 sorry I couldn't-- I don't remember their names. ~
1 - - - - ~ - - - - - - - - - - - - - - - - - - + - - - - - - - - - - - - - - - - - - - - - - - - - i . ~
109 ~
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Page 107
behalf of Sovereign Place, both the management company and
the corporate entity. Just a couple questions for you.
Just a second ago Miss Franklin asked a question
concerning residential facilities and I believe you
replied that you are aware that they stayed at a location.
A. Right.
Q. And they being the patients.
A. Correct.
Q. Okay. Do you know anything about this location
where they stayed?
A. No.
Q. You don't know the name of the location?
A. No.
Q. Address?
A. No.
Q. Okay. Other than you knew they stayed elsewhere
than the NARCONON facility, do you have any other
information whatsoever about that location?
A. No.
Q. So you don't know who owned or managed that
location.
A. No.
MR. BARTLETT: Okay. No further questions.
MS. WillTLOCK: Melanie?
1
2
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Q. Okay. I don't have any other questions. Thanks
very much, Doctor.
A. You're welcome.
EXMIINATION
BY 1\.1R. TANNER:
Q. Doctor, can you find the office records, your
office notes on the patient?
A Yes.
Q. And could you turn to the first visit you had,
which I think you said was September 25.
A. Yes.
Q. And can you grab from the pile Exhibit 9, which
I thillk is in front of you there. With regard to what you
were told by Mr. Desmond on September 25, what drugs did
he tell you he bad taken?
A. It says here drug history including past
detoxification episodes include THC, opiates, cocaine and
meth.
Q. What is TIIC?
A. I figure it's marijuana.
Q. All right Now, can you look at Exhibit 9?
A. Yes.
Q. Okay. How does Exhibit 9 compare in terms of
what he was telling you that he was taking?
I
I
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28 (Pages 106 to 109)
LISA ROBBINS, M.D. 11-5-iO Desmond, et al. vs . Narconon, et a l .
Page 110
1 A. It says here alcohol, marijuana, cocaine and
2 Ecstasy.
3 Q. Did he say anything about opiates?
4 A. No.
5 Q. Are opiates -
6 A No, not on this, not on Exhibit 9.
7 Q. Okay. Are opiates different than Ecstasy?
8 A Yes.
9 Q. And how long had he been-- according to the
10 form, Exhibit 9, assuming that's something to do with him,
11 how long had he been taking the Ecstasy?
12 A It says here six years.
13 Q. How often?
14 A It says here weekly.
15 Q. Okay. AndaccordingtoExhibit9,howlonghad
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16 he been taking cocaine?
17 A. It says here daily for four years. 16
18 Q. And same question with regard to marijuana.
17
19 A. Marijuana daily for six years. i ~
20 MR. TANNER: Allright. I justwantedto
20
21 ask about that. That's all rve got.
21
CERTIFICATE
STATE OF GEORGIA:
COlJ"NTY OF CHEROKEE:
Page
I hereby certify that the foregoing transcript
was taken down as stated in the caption, that the witness
was first duly sworn, and the questions and answers
thereto were reduced to typewriting under my direction;
that the foregoing transcript is a true and con-ect record
of the evidence given, and I further certify that I am not
a relative or counsel to the parties in this case, am not
in 1he regular employ of counsel for any of said pruties,
nor am I in anywise interested in the result of said case.
This, the 8th day ofNovember, 20 10.
Sharon J. Ruschell, RMR, CRR, CCR B-1179
My Commission Expires 2-19-2012
2 2 MS. FRANKLIN: I have no followup. 2 2
2 3 THE VIDEOGRAPHER: This concludes the 2 3 I
2 4 deposition at 6:16p.m. 2 4 ~
25 --- 25 ~
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Page 111
(It was stipulated and agreed by and between
counsel for the respective parties and the
witness that the signature of the witness to the
deposition be waived.)
(Deposition concluded at 6:16p.m.)
~
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29 ( Pages 110 to 112)
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