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6:14-cv-00187-RAW Document 685 Filed in ED/OK on 06/01/16 Page 1 of 7

IN THE UNITED STATES DISTRICT COURT


FOR THE EASTERN DISTRICT OF OKLAHOMA

1.

NATIONAL ASSOCIATION OF
FORENSIC COUNSELORS, INC., et al.
Plaintiffs,

v.
1.

NARCONON INTERNATIONAL, et al.


Defendants.

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Case No. 14-cv-00187-RAW

PLAINTIFFS NATIONAL ASSOCIATION OF FORENSIC COUNSELORS, INC. AND


AMERICAN ACADEMY CERTIFIED FORENSIC COUNSELORS d/b/a AMERICAN
COLLEGE OF CERITIFIED FORENSIC COUNSELORS
PRELIMINARY WITNESS LIST
COME NOW National Association of Forensic Counselors, Inc. (NAFC) and
American Academy of Certified Forensic Counselors d/b/a American College of Certified
Forensic Counselors (AACFC), the Plaintiffs in the above-entitled action, by and through their
attorneys, David R. Keesling and Laurel A. Carbone, of the law firm, KEESLING LAW GROUP,
PLLC, and pursuant to the Courts Scheduling Order [Dkt. 651], submit their Preliminary
Witness List.
WITNESSES
No.

1.

2.

Witness

Karla Taylor c/o


David R. Keesling
Laurel A. Carbone
KEESLING LAW GROUP, PLLC
11114 South Yale Avenue,
Suite B
Tulsa, Oklahoma 74137
(918) 924-5101
Jonathan Deisler c/o

Area of Testimony

NAFCs and AACFCs CEO and President:


Ms. Taylor is expected to testify consistent with her
deposition testimony about her knowledge of the
facts and circumstances pertaining to the claims in
this case.

AACFCs Treasurer:

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3.

David R. Keesling
Laurel A. Carbone
KEESLING LAW GROUP, PLLC
11114 South Yale Avenue,
Suite B
Tulsa, Oklahoma 74137
(918) 924-5101
Lucas Catton
3895 Greensward View NW
Keenesaw, GA 30144

Mr. Deisler has been an employee and officer of both


NAFC and AACFC and is expected to testify about
the facts and circumstances pertinent to Plaintiffs
claims, as well as information regarding Plaintiffs
damages.
Witness:
Mr. Catton worked for Narconon of Oklahoma, Inc.
in supervisory and decision-making positions. He
filed a complaint with NAFC about Narconon
activities and employees. He is expected to testify
regarding his knowledge of the facts and
circumstances pertaining to the claims in this case.
Witness:
Mr. Tenorio was an employee of Narconon of
Oklahoma, Inc. and advertised himself as a CCDC.
He filed a complaint with NAFC about Narconon
activities and employees. He is expected to testify
regarding his knowledge of the facts and
circumstances pertaining to the claims in this case.
Witness:
Mr. Carr is the President of Narconon International,
has been an officer of Narconon of Oklahoma, Inc.
for many years, and advertised that he held a CCDC.
He is expected to testify regarding his knowledge of
the Narconon decision-making structure and the facts
and circumstances pertaining to the claims in this
case.

4.

Eric Tenorio
607-793-8714
607-241-5776
607-229-9866
ejtbmf@hotmail.com
10orio.eric@gmail.com

5.

Clark Carr
Narconon International
7065 Hollywood Blvd.
Los Angeles, CA 90028

6.

Tim Lomas
ABLE
7065 Hollywood Blvd.
Los Angeles, CA 90028

Witness:
My. Lomas is an employee of ABLE. He is expected
to testify regarding his knowledge of the Narconon
decision-making structure and the facts and
circumstances pertaining to the claims in this case.

7.

Jason Burdge
c/o Steidley & Neal, PLLC
CityPlex Towers, 53rd Floor
2448 East 81st Street
Tulsa, Oklahoma 74137

8.

Robert Newman
c/o Steidley & Neal, PLLC
CityPlex Towers, 53rd Floor
2448 East 81st Street
Tulsa, Oklahoma 74137

Witness:
Mr. Burdge has been an employee of Narconon of
Oklahoma, Inc. and submitted a false application to
NAFC. He is expected to testify regarding his
knowledge of the facts and circumstances pertaining
to the claims in this case.
Witness:
Mr. Newman has been an employee of Narconon
entities and is expected to testify regarding his
knowledge of the facts and circumstances pertaining
to the claims in this case.

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9.

James McLaughlin
c/o Steidley & Neal, PLLC
CityPlex Towers, 53rd Floor
2448 East 81st Street
Tulsa, Oklahoma 74137

Witness:
Mr. McLaughlin has been an employee of Narconon
of Oklahoma, Inc. and advertised that he held several
NAFC credentials. He is expected to testify regarding
his knowledge of the facts and circumstances
pertaining to the claims in this case.

10.

Derry Hallmark
c/o Riggs, Abney, Neal,
Turpen, Orbison Lewis P.C.
502 West 6th Street
Tulsa, Oklahoma 74119

11.

Gary Smith
c/o Riggs, Abney, Neal,
Turpen, Orbison Lewis P.C.
502 West 6th Street
Tulsa, Oklahoma 74119

12.

Janet Watkins
c/o Riggs, Abney, Neal,
Turpen, Orbison Lewis P.C.
502 West 6th Street
Tulsa, Oklahoma 74119

13.

Tom Widmann
c/o Riggs, Abney, Neal,
Turpen, Orbison Lewis P.C.
502 West 6th Street
Tulsa, Oklahoma 74119

14.

Vicki Smith
c/o Riggs, Abney, Neal,
Turpen, Orbison Lewis P.C.
502 West 6th Street
Tulsa, Oklahoma 74119

15.

Michael Otto
c/o Riggs, Abney, Neal,
Turpen, Orbison Lewis P.C.
502 West 6th Street
Tulsa, Oklahoma 74119

Witness:
Mr. Hallmark has been an employee of Narconon of
Oklahoma, Inc., including holding the position of the
Director of Expansion, a member of the
Executive Council, and advertised himself as
holding a CCDC. He is expected to testify regarding
his knowledge of the facts and circumstances
pertaining to the claims in this case.
Witness:
Gary Smith is the President of Narconon of
Oklahoma, Inc. and advertised himself as a CCDC.
He is expected to testify regarding his knowledge of
the facts and circumstances pertaining to the claims
in this case.
Witness:
Ms. Watkins has been an employee of Narconon of
Oklahoma, Inc., has served as a member of Narconon
of Oklahoma, Inc.s Executive Council, and
advertised herself as CCDC. She is expected to
testify regarding her knowledge of the facts and
circumstances pertaining to the claims in this case.
Witness:
Mr. Widmann has been an employee of Narconon of
Oklahoma, Inc. and advertised himself as a CCDC.
He has also owned and/or operated a number of
websites advertising Narconon. He is expected to
testify regarding his knowledge of the facts and
circumstances pertaining to the claims in this case.
Witness:
Ms. Smith has been an employee of Narconon of
Oklahoma, Inc., has advertised herself as a MAC,
and has served as a member of Narconon of
Oklahoma, Inc. Executive Council. She is expected
to testify regarding her knowledge of the facts and
circumstances pertaining to the claims in this case.
Witness:
Mr. Otto has been an employee of Narconon of
Oklahoma, Inc. and advertised that he was a CCDC.
He is expected to testify regarding his regarding his
knowledge of the facts and circumstances pertaining
to the claims in this case.

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16.

Michael J. Gosselin
c/o Riggs, Abney, Neal,
Turpen, Orbison Lewis P.C.
502 West 6th Street
Tulsa, Oklahoma 74119

17.

Kathy Gosselin
c/o Riggs, Abney, Neal,
Turpen, Orbison Lewis P.C.
502 West 6th Street
Tulsa, Oklahoma 74119

18.

Michael George
c/o Riggs, Abney, Neal,
Turpen, Orbison Lewis P.C.
502 West 6th Street
Tulsa, Oklahoma 74119

19.

Michael St. Amand


c/o Riggs, Abney, Neal,
Turpen, Orbison Lewis P.C.
502 West 6th Street
Tulsa, Oklahoma 74119

20.

Rebecca Pool
c/o Riggs, Abney, Neal,
Turpen, Orbison Lewis P.C.
502 West 6th Street
Tulsa, Oklahoma 74119

21.

Dena Goad
c/o Riggs, Abney, Neal,
Turpen, Orbison Lewis P.C.
502 West 6th Street
Tulsa, Oklahoma 74119

22.

Kent McGregor
c/o Riggs, Abney, Neal,
Turpen, Orbison Lewis P.C.
502 West 6 Street
Tulsa, Oklahoma 74119
th

Witness:
Mr. Gosselin has been an employee of Narconon of
Oklahoma, Inc., a member of the Executive Council,
and advertised himself as a CCDC. He is expected
to regarding his knowledge of the facts and
circumstances pertaining to the claims in this case.
Witness:
Ms. Gosselin has been an employee and officer of
Narconon of Oklahoma, Inc. and advertised herself as
a CCDC. She is expected to testify regarding her
knowledge of the facts and circumstances pertaining
to the claims in this case.
Witness:
Mr. George has been an employee of Narconon of
Oklahoma, Inc. and advertised himself as a CCDC.
He is expected to testify regarding his knowledge of
the facts and circumstances pertaining to the claims
in this case.
Witness:
Mr. St. Amand has been an employee and officer of
Narconon of Oklahoma, Inc., a member of the
Executive Council, and advertised himself as a
CCDC. He is expected to testify regarding his
knowledge of the facts and circumstances pertaining
to the claims in this case.
Witness:
Ms. Pool has been an employee of Narconon of
Oklahoma, Inc. and a member of the Executive
Council, and advertised herself as a BAC. She is
expected to testify regarding his knowledge of the
facts and circumstances pertaining to the claims in
this case.
Witness:
Ms. Goad has been an employee of Narconon of
Oklahoma, Inc. and owned and/or operated numerous
websites advertising Narconon. She is expected to
testify regarding his knowledge of the facts and
circumstances pertaining to the claims in this case.
Witness:
Mr. McGregor has been an employee of Narconon of
Oklahoma, Inc. and the President of the PITA Group.
He advertised that he was a MAC and that he issued
CCDC certifications. He is expected to testify
regarding his knowledge of the facts and
circumstances pertaining to the claims in this case.

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23.

Eric Mitchell
2113 Indian Trails
Jonesboro, AR 72401

Witness:
Mr. Mitchell has been an employee of Narconon of
Oklahoma, Inc. and advertised himself as a CCDC.
He is expected to testify regarding his knowledge of
the facts and circumstances pertaining to the claims
in this case.

24.

David Miscavige
6331 Hollywood Blvd.,
Ste 1100
Los Angeles, CA 90028

25.

Fernando Torres, MSc


9320 Chesapeake
Drive San Diego, CA
92123

Witness:
Mr. Miscavige is the leader of Scientology, the
organization under which Narconon is organized. He
is expected to testify regarding his knowledge of the
facts and circumstances pertaining to the claims in
this case.
Expert witness:
Mr. Torres is expected to testify regarding all alleged
trademark and/or certification mark infringement
damages claimed by Plaintiffs, excluding punitive
damages and attorney fees, and rebuttal of
Defendants claims and/or defenses regarding the
same. Matters relevant to secondary meaning and
likelihood of confusion. Matters relevant to
sampling/surveying evidence.

26.

Thomas J. Maronick,
DBA, JD.
Department of Marketing
Towson University
Towson, Maryland 21252

Expert witness:
Mr. Maronick is expected to testify regarding all
matters relevant to empirical evidence of
sampling/surveying with regard to the claims of
Plaintiffs, and rebuttal of Defendants claims and/or
defenses regarding the same.

Respectfully submitted,
KEESLING LAW GROUP, PLLC
s/ Laurel A. Carbone
David R. Keesling, OBA # 17881
Laurel A. Carbone OBA # 32176
11114 S. Yale Avenue, Suite B
(918) 924-5101 Telephone
(918) 512-4888 - Facsimile
David@KLGattorneys.com
Laurel@KLGattorneys.com
Attorneys for Plaintiffs National Association of
Forensic Counselors, Inc. and American
Academy of Certified Forensic Counselors, Inc.
d/b/a ACCFC of Certified Forensic Counselors

6:14-cv-00187-RAW Document 685 Filed in ED/OK on 06/01/16 Page 6 of 7

CERTIFICATE OF SERVICE
I hereby certify that on June 1, 2016, I electronically transmitted the attached document
to the Clerk of Court using the ECF System for filing and transmittal of a Notice of Electronic
Filing to the following ECF registrants:
M. David Riggs, driggs@riggsabney.com
Donald M. Bingham, don _bingham@riggsabney.com
Wm. Gregory James, gjames@riggsabney.com
Riggs, Abney, Neal, Turpen, Orbison & Lewis
502 West 5th Street
Tulsa, Oklahoma 74119
and
William H. Forman, wforman@scheperkim.com
Gregory A. Ellis, gellis@scheperkim.com
Scheper, Kim & Harris, LLP
601 W. 5th Street, 12th Floor
Los Angeles, CA 90071
and
David Goldstein, dgoldstein@rbksl.com
Rabinowitz, Boudin, Standard, Krinsky, & Lieberman, P.C.
45 Broadway, Suite 1700
New York, NY 10006-3791
Attorneys for Defendants, Narconon of Oklahoma, Inc. Michael George, Derry Hallmark,
Janet Watkins, Tom Widmann, Vicki Smith, Michael Otto, Michael Gosselin,
Kathy Gosselin, Kent McGregor, Michael St. Amand, Pita Group, Gary Smith, Rebecca Pool,
and Dena Goad
Stacie L. Hixon, slh@steidley-neal.com
Michelle Harris, mbh@steidley-neal.com
Steidley & Neal (Tulsa)
2448 E. 8151 St., Ste 5300
Tulsa, OK 74137
and
Charles D. Neal, Jr., cdn@steidley-neal.com
Steidley & Neal (McAlester)
P 0 Box 1165
McAlester, OK 74502
Attorneys for Defendants Jason Burdge, James McLaughlin, Robert Newman

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John H. Tucker, jtucker@rhodesokla.com


Colin H. Tucker, chtucker@rhodesokla.com
Kerry R. Lewis, klewis@rhodesokla.com
Denelda L. Richardson, drichardson@rhodesokla.com
Rhodes Hieronymus Jones Tucker & Gable
P 0. Box 21100
Tulsa, Oklahoma 74121-1100
and
Thomas M. O'Leary, thomas.o'leary@leclairrvan.com
LeClairRyan, LLP
725 S Figueroa St, Ste 350
Los Angeles, CA 90017
Attorneys for Defendants Association for Better Living and Education International,
Narconon International

And on June 1, 2016 I mailed a copy of the above and foregoing pleading to:
D. Eric Mitchell, Pro Se
6418 Wildwood Dr.
Brentwood, TN 37027-4860

/s/ Laurel A. Carbone