In the State Court of Dekalb County State of Georgia
IN THE STATE COURT OF DEKALB COUNTY STATE OF GEORGIA PATRICK C. DESMOND, MARY C. DESMOND, Individually, and MARY C. § DESMOND, as Administratrix of the Estate § of PATRICK W. DESMOND § § Plaintiffs, § v. ? Civil Action File No: 10A28641-2 NARCONON OF GEORGIA, INC., NARCONON INTERNATIONAL, DELGADO DEVELOPMENT, INC., SOVEREIGN PLACE, LLC, SOVEREIGN PLACE APARTMENT MANAGEMENT, INC., LISA CAROLINA ROBBINS, M.D., and THE ROBBINS GROUP, INC. Defendants. DEFENDANT NARCONON OF GEORGIA, INC.'S RESPONSE TO PLAINTIFFS' CONSOLIDATED MOTION, MEMORANDUM AND SUPPLEMENTAL MEMORANDUM TO UNSEAL DOCUMENTS COMES NOW, Narconon of Georgia, Inc. ("Defendant") in the above styled civil action and files its Response to Plaintiffs' Consolidated Motion, Memorandum and Supplemental Memorandum to Unseal Documents showing the Court as follows: I. STATEMENT OF FACTS The above-referenced matter was filed on May 19, 2010, in which Plaintiffs seek damages for the alleged wrongful death of Patrick Desmond. Patrick Desmond died due to cardiopulmonary arrest secondary to a heroin overdose. In their Complaint, Plaintiffs assert a variety of causes of action against the Narconon Defendants for their alleged failure to provide safe, properly licensed, legally operated, scientifically and medically based rehabilitation treatment services to Patrick. (See generally, Complaint). Because of the nature of the discovery process, Plaintiffs have been allowed access to highly sensitive and even confidential information concerning employees and students of Narconon of Georgia and its structure and operation. Recognizing the privacy concerns of the Narconon Defendants, the parties entered into an agreement to treat certain documents and information confidential and limiting the use of such information as needed for this litigation.
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