IN THE STATE COURT OF DEKALB COUNTY STATE OF

PATRICK C. DESMOND AND MARY C. DESMOND, INDIVIDUALLY, AND MARY C. DESMOND, AS Civil Action No. 10A28641-2 ADMINISTRATRIX OF THE ESTATE OF PATRICK W. DESMOND,

Plaintiffs,

v.

NARCONON OF GEORGIA, INC. DELGADO DEVELOPMENT, INC., SOVEREIGN PLACE, LLC, SOVEREIGN PLACE APARTMENT MANAGEMENT, INC., LISA CAROLINA ROBBINS, M.D. THE ROBBINS GROUP, INC., and INTERNATIONAL,

Defendants.

PLAINTIFFS' EXPERT DISCLOSURES

Plaintiffs supplement their responses to Defendant Narconon of Georgia's First

Interrogatory No. 13, Lisa Robbins, M.D.'s First Interrogatory No. 18, and Delgado

Development Interrogatory No. 9, and identify expert witnesses they may call at the trial of

this case:

A. Kenison Roy, III, MP, FASAM, DFAPA

Dr. Ken Roy is a medical doctor licensed to practice in the State of

Louisiana. Dr. Roy specializes in the study and treatment of substance , specifically

drug and alcohol addiction. A copy of Dr. Roy's curriculum vitae, which details his

education, experience, qualifications, and expertise, is attached hereto as Exhibit A.

Counsel for Plaintiffs expect that Dr. Roy, if called to testify as a witness at trial, will

testify regarding the appropriate treatment for individuals enrolled in addiction recovery and

-1- rehabilitation facilities. Specifically, Dr. Roy may offer opinions relating to the care and treatment of Patrick Desmond while participating in the Narconon of Georgia program and while a resident of Delgado Development Recovery Residence. Dr. Roy may testify that

Defendants Narconon of Georgia, Narconon International, Delgado Development, and Dr.

Lisa Robbins - individually and/or through their agents - deviated from the standards of care and practice for addiction medicine in their care and treatment of Patrick Desmond, ultimately resulting in his death.

Steven M Lynn, M.D.

Dr. Steven Lynn is a medical doctor licensed to practice medicine in the State of

Georgia. Dr. Lynn specializes in the study and treatment of substance addiction, specifically drug and alcohol addiction. A copy of Dr. Lynn's curriculum vitae, which details his education, experience, qualifications, and expertise, is attached hereto as Exhibit B.

Counsel for Plaintiffs expect that Dr. Lynn, if called to testify as a witness at trial, will testify regarding the appropriate treatment for individuals enrolled in addiction recovery and rehabilitation facilities. Specifically, Dr. Lynn may offer opinions relating to the care and treatment of Patrick Desmond while participating in the Narconon of Georgia program and while a resident of Delgado Development Recovery Residence. Dr. Lynn may testify that

Defendants Narconon of Georgia, Narconon International, Delgado Development, and Dr.

Lisa Robbins - individually and/or through their agents - deviated from the standards of care and practice for addiction medicine in their care and treatment of Patrick Desmond, ultimately resulting in his death.

Dr. Stephen A. Kent

Dr. Stephen A. Kent is a Professor in the Department of Sociology at the University of

-2- Alberta and an expert in alternative religions, including the Church of .

His curriculum vitae, which details his education, experience, qualifications, and expertise, is attached hereto as Exhibit C.

Dr. Kent, if called to testify at trial, will testify regarding the connection between

Scientology and the Narconon Drug and Alcohol rehabilitations programs, including testimony relating to Narconon's course materials, student and staff interactions, and

Narconon International's oversight and involvement in individual Narconon programs.

Francis Willard Rushing, Ph.D.

Dr. Rushing is an economist familiar with the methodology used for calculating the economic and financial costs associated with lost past and future earnings. He is expected to testify regarding the economic value of the life of Patrick W. Desmond, Deceased. Plaintiffs attach a copy of Dr. Rushing's Curriculum Vitae, marked as Exhibit D.

This 1st day of November, 2011.

HARRIS PENN LOWRY DELCAMPO, LLP

400 Colony Square 1201 Peachtree Street, NE Suite 900 Atlanta, Georgia 30361 Telephone: (404)961-7650 Facsimile: (404)961-7651 REBECCA FRANKLIN Georgia Bar No. 141350 FRANKLIN LAW, LLC 400 Colony Square 1201 Peachtree Street, NE Suite 900 Atlanta, Georgia 30361 Telephone: (404) 961-5333 Facsimile: (404) 969-4503 Attorneys for Plaintiffs

-A- CURRICULUM VITAE A. Kenison Roy, III, MD, FASAM, DFAPA

November 1,2011

IDENTIFYING Name: A. Kenison Roy, III, MD, FASAM, DFAPA INFORMATION: DOB: September 29, 1942 SS# 437-58-5370 Address: 4824 Cleary Ave. Metairie, La. 70002 Phone: (504) 780-2766 Married: Patricia Lilly Roy Children: Alex 1986, Darryl 1968 and Darci 1963.

MEDICAL Tulane University School of Medicine, CREDENTIALS: New Orleans, La. MD, May 1972

Louisiana State Board of Medical Examiners License in Medicine and Surgery - # 012078 July 1972

Internship, Charity Hospital of New Orleans, New Orleans, LA April 1972-March 1973

Certified in Addiction Medicine American Society of Addiction Medicine Certificate #000708 October 1986,1998,2008

Residency in Psychiatry Tulane University School of Medicine New Orleans, LA January 1, 1992 - December 31, 1994

Board certified in Psychiatry American Board of Psychiatry and Neurology Certificate #44452 December 4, 1997, Recertified 2008

Board certified in Addiction Medicine American Board of Addiction Medicine Certificate #000088 April 2008

Medicaid #: 1324400

Medicare #: 55865

UPIN# B89887

CURRENT ADDICTION MEDICINE - ADULT PSYCHIATRY PRACTICE: Biobehavioral Medicine Corp. Tax ID #72-1131527 Individual patient care, Medical Directorships and Professional Re-entry Monitoring Groups Continuous since 1985

President/Medical Director Neurobehavioral Associates, Inc Metairie, LA Continuous since 1989

President/Medical Director Addiction Recovery Resources, Inc. Metairie, LA Continuous since 1991

Founder and Medical Director, Chemical Dependency Unit, River Oaks Hospital, Harahan, LA January 1985 - December 1989 October 2000 - Present

HOSPITAL East Jefferson General Hospital AFFILIATIONS: River Oaks Hospital

APPOINTMENTS: Department of Psychiatry, Tulane University School of Medicine Clinical Instructor - July 1991 Clinical Assistant Professor - June 1999

American Psychiatric Association Distinguished Fellow May, 2005 American Society of Addiction Medicine Fellow (FASAM) April, 1997

PROFESSIONAL American Society of Addiction Medicine ASSOCIATIONS: American Academy of Addiction Psychiatry American Psychiatric Association Louisiana Psychiatric Association New Orleans Psychiatric Association American Medical Association Louisiana State Medical Society Jefferson Parish Medical Society

PUBLICATIONS: Reentry Monitoring in the treatment of with Substance Dependence. Southern Medical Journal, 1994; 87:881-883.

Parity and the Medicalization of Addiction Treatment Co-author, Michael M. Miller, MD Journal of Psychoactive Drugs 2010; 42(2); 115-120

PROFESSIONAL Nancy C. A. Roeske, M.D. Certificate of Recognition AWARDS: For Excellence in Medical Student Education Awarded by the American Psychiatric Association on May 4, 2008

Psychiatric Care Associates Annual Leadership Award For Leadership, Commitment and Service Awarded by Psychiatric Care Associates on December 19, 2008

American Society of Addiction Medicine Annual Award For outstanding contributions to the growth and vitality of our Society, for thoughtful leadership in the field, and for deep understanding of the art and science of Addiction Medicine April 17, 2010

PREVIOUS 1984 - June 1997 PRACTICE: Co-owner and Medical Director New Freedom, Inc. Metairie, LA January 1992 - December 1994 Resident in Psychiatry Tulane University School of Medicine New Orleans, LA

March 1988 - February 1992 Founder and Medical Director, Chemical Dependency Unit, Slidell Memorial Hospital, Slidell, LA

December 1989 - August 1991 Founder and Medical Director, Chemical Dependency Unit River Bend Hospital, Metairie, LA

January 1985 - December 1989 Founder and Medical Director, Chemical Dependency Unit, River Oaks Hospital, Harahan, LA

January 1986 - December 1991 General Practice/Chemical Dependency, Metairie, LA

November 1982 - December 1988 General Practice/Chemical Dependency Chalmette, LA

June 1982 -October 1982 Treatment for Chemical Dependency

December 1975 - April 1982 Family/General Practice Boise,

April 1973 - June 1975 Emergency Medicine Methodist Hospital New Orleans, LA

PROFESSIONAL, American Society of Addiction Medicine CIVIC Board of Directors April 1989-April 1993 April 1997-April 2009 Secretary of the Society April 2005 - April 2009 Louisiana Psychiatric Medical Association Chairman, Insurance Committee April, 2002 - Current July, 2007 - Secretary of the Society April, 2009 President Elect of the Society April, 2010 President of the Society

Louisiana State Medical Society Member, Mental Health & Committee April 2003 - Current

State of Louisiana Member, Governor's Drug Policy Board July 2008 - Current Member, Board of Practical Nurse Examiners

East Jefferson General Hospital Chairman, Department of Psychiatry January 1999 - December 2000

East Jefferson General Hospital Vice Chairman - Department of Psychiatry January 1997 - December 1998

DePaul/Tulane Behavioral Health Center Chairman, Pharmacy & Therapeutics Committee January 1996 - January 1998 '

DePaul/Tulane Behavioral Health Center Clinical Directors Committee January 1997 - October 1997

Louisiana State Board of Certification for Substance Abuse Counselors Psychiatrist Member March, 1995-April, 2004

DePaul/Tulane Behavioral Health Center Physicians Advisory Committee, Computers & Automation January 1997 - October 1997

DePaul/Tulane Behavioral Health Center Physicians Advisory Committee, Unified Laboratory Services January 1997 - October 1997 American Society of Addiction Medicine Chairman, Membership Committee June 1991 - January 1996

Louisiana Psychiatric Association Acting Chairman, Health Committee June 1993 - April 1996

Jefferson Parish Medical Society Chairman, Drug Free Schools Committee May, 1993 - current

Previous member, Impaired Physicians Committee of the La. State Medical Society, Orleans Parish Medical Society, St. Bernard Parish Medical Society, St. Tammany Parish Medical Society, the Board of Directors of Bridge House, Inc. and of Phoenix House, Inc., and Board of Advisors, Committee on Alcoholism and Drug Addiction STEVEN M. LYNN, M.D. 4015 South Cobb Dr, Suite 255 Smyrna, GA 30080

CURRICULUM VITAE

PERSONAL: Date of Birth: March 25, 1953 Married

TELEPHONE: Home: 770-698-9716 Office: 770-333-1755 Fax: 770-333-6115

EDUCATION: 1971 - High School Diploma, Southfield - Lathrup High School, Southfield, .

1975 - Bachelor of Science Degree, Wayne State University, Detroit, Michigan.

1979 - Medical Degree, Wayne State University School of Medicine Detroit, Michigan.

POST GRADUATE TRAINING: July 1979 - June 1980 Sinai Hospital of Detroit - Internship, Detroit, MI July 1980 - June 1981 Obstetrics and Gynecology Residency, Sinai Hospital of Detroit, Detroit, MI Jan 1983- June 1984 Anesthesiology Residency - University Of Hospital, Chicago, IL July 1986 - June 1989 Psychiatry Residency, Emory University School of Medicine, Atlanta, GA

MEDICAL RESEARCH: 1973- 1976 - Research Associate; re: Maternal/Fetal Physiology and Drug Addiction, C. S. Mott Center for Human Growth, Wayne State University School of Medicine, Detroit, MI

1974- 1976 - Research Associate; re: Maternal/Fetal Physiology and Drug Addiction, Dept. of OB/GYN and Dept. of Neonatology, Hutzel Hospital, Wayne State University School of Medicine, Detroit, MI

1988-1989 - Research Associate; re: Substance Abuse and Adolescent Relapse, PLAINTIFF'S Dept. of Child Psychiatry, Emory School of Medicine, Atlanta, GA EXHIBIT PUBLICATIONS:

"Fetal Physiology in Drug Addicted Pregnant Macques" (J.S. Stryher, A. Koen, S. Lynn), Reproductive Physiology, 1974 "Tissue Levels of in Newborns of Drug Addicted Rhesus Monkeys (E. Ostrea, S. Lynn), Journal of Experimental Pharmacology, 1976 "Dual Diagnosis: Addiction & Depression" (S. Lynn) Ridgeview Institute "Insight", 1993 "Helping the Helpers (and Public Safety Too!)"(S. Lynn) A View From the Ridge, August 2008 "ASAM Update" (S. Lynn), A View From the Ridge, August 2008 "Helping the Helpers (and Public Safety Too!)" (S. Lynn) Atlanta Hospital News, September 2008 "ASAM Update" (S. Lynn), Atlanta Hospital News, September 2008 "Helping the Helpers (and Public Safety Too!)" (S. Lynn), GPPA Newsletter, 2008 "ASAM Update" (S. Lynn), GPPA Newsletter, 2008

PRESENTATIONS: "Bipolar" - Ridgeview Institute - November 2007 "Basics of Addiction" - Ridgeview Institute - June 2008 "ASAM Update" - Ridgeview Institute - July 2008 "College Age Drinking" - Ridgeview Institute - August 2008 "Addiction and Dual Diagnosis Lecture Series" - Ridgeview Institute - Fall 2008 "Professional Impairment"- Ridgeview Institute - November 2008 "Addiction" - North Georgia EAPA Chapter - November 2008 "The Changing Face of Addiction Medicine" - SEC AD- February 2009 "Disease & Neurobiology of Addiction" - Southern College Health Association - March 2009 "Addiction - Professional Impairment & Drug Courts" - State Bar Association of Georgia - March 2009 "Suboxone and Subutex" - Ridgeview Institute - April 2009 "Basics of Addiction & College Age Drinking" - Dunwoody United Methodist Church — October 1, 2009

MEDICAL EXPERIENCE: July 1981- Jan 1982 Emergency Medicine, Heritage National, Taylor, MI July 1981- Jan 1982 Emergency Medicine, Redford Community Hospital, Redford, MI July 1981-Jan 1982 General Medicine, Neighborhood Health Clinic, Redford, MI July 1981-Jan 1982 General Medicine Planned Parenthood, , CA Feb 1985- July 1986 General Medicine, Georgia Health Group, Atlanta, GA July 1986- June 1989 State of Georgia DHR, Regional Hospital Consulting Staff Admissions, Atlanta, GA July 1989 - Present Private Practice - Psychiatry and Addictive Medicine, Atlanta, GA July 1989- Present Private Practice - Attending Psychiatrist, Ridgeview Institute and Peachford Hospital Sept 1995-Aug 1996 President Medical Staff, Ridgeview Institute Oct 1999-Dec 2001 Medical Director, Anchor Hospital 1999-Present Georgia Advisor/Consultant to American Psychiatric Association Substance Abuse Committee CERTIFICATIONS: National Board of Medical Examiners - #214188

A.S.A.M. Certified Addictionologist - February 1991

American Board of Psychiatry & Neurology - April 1992

American Board of Psychiatry & Neurology - June 1993 & 2002 Added Qualifications - Addiction Psychiatry

American Board of Addiction Medicine - May 2009

American Psychiatric Association Distinguished Fellow - 2010

Aviation (HIMS) Psychiatrist - 2010

HOSPITAL AFFILIATIONS:

1989- 2003 Emory University - Dept. of Psychiatry Clinical Assistant Professor 1990- 1991 Associate Director Dual Diagnosis Unit: Director Co - Dependency Services, Charter Peachford Hospital 1989-2006 Charter Peachford Hospital - Consultant for Dual Diagnosis Unit and Attending Psychiatrist and Addictionologist 1989-Present Ridgeview Institute - Attending Psychiatrist and Addictionologist 1992- 2004 Dunwoody Medical Center 1993- 2000 Smyrna Hospital 1995-1996 President, Ridgeview Medical Staff 1999-2001 Medical Director, Anchor Hospital 2006-2006 Director of Inpatient Psychiatric Unit, Ridgeview Institute 2006-Present Director of Addiction Services and Professional Program, Ridgeview Institute 2011 -Present Clinical Assistant Professor, Department of Psychiatry, Georgia Health Sciences University

MEDICAL ASSOCIATIONS: American Medical Association (until 2000) Dekalb Medical Society (until 2000) Medical Association of Georgia American Psychiatric Association - Distinguished Fellow Georgia Psychiatric Physicians Association Georgia Psychiatric Association Board of Trustees (2008- American Society of Addictive Medicine American Academy of Addiction Psychiatrist Georgia Chapter of American Academy of Addiction Psychiatrists President - Georgia Chapter of AAAP - 2/96 - 2/98 Georgia Psychiatric Physician Association Board of Trustees 2008 - present 1

November 1,2011 CURRICULUM VITAE NAME: Dr. Stephen A. Kent Professor

ADDRESS: Department of Sociology University of Alberta Edmonton, Alberta T6G 2H4

TELEPHONE: (780) 492-2204 or (780) 492-5234 (messages) FAX: (780) 492-7196 E-MAIL: [email protected] Web Site: http://www.arts.ualberta.ca/~skent/

ACADEMIC TRAINING

UNDERGRADUATE: University of , College Park. 1969-1973.: B.A. Sociology; Social and Political Theory Minor.

GRADUATE: American University, Washington, D.C. 1975-1977. M.A. History of Religions-Hinduism; Minor. Thesis: "Valentinian Gnosticism and Classical Samkhya: A Thematic and Structural Study." Degree Awarded: August 1978.

McMaster University, Hamilton, . 1977-1979. M.A. Religion and Modern Western Society; Indian Buddhism Minor. Thesis: "A Sociological Interpretation of Millenarian Quakerism-1648 to 1662." Degree Awarded: May 1980.

McMaster University, Hamilton, Ontario. 1979-1983. Ph.D. Religion and Modern Western Society; Indian Buddhism Minor. Dissertation Topic: Quaker Mobilization and the Tithe Controversy in Interregnum : A Social-Psychological Study. Degree awarded: May 1984.

FELLOWSHIPS AND AWARDS

May 2010 Received the Bill Meloff Award for Undergraduate Teaching, Department of Sociology, University of Alberta

March 12, Received one of three campus-wide Graduate Student Supervisor Awards 2009 from the Graduate Students' Association, University of Alberta

May 2007 University of Alberta Killam Cornerstone Grant ($50,000.00 plus an additional $15,000.00 from the Faculty of Arts and the Department of PLAINTIFF'S EXHIBIT 2

Sociology)

October 1996 University of Alberta Support for the Advancement of Scholarship Grants for course release and research assistant

June 1992 Center for Criminology, University of Alberta ($500.00 for typing transcriptions of interviews with alleged satanic abuse survivors)

May 1992 Social Science and Humanities Research Council of (SSHRC) "'' and 'New Religions' in Canada" ($73,610.00)

October 1988 Central Research Fund Operating Grant, University of Alberta ($1500.00 for typing transcriptions of interviews with current and former 'cults/new religions' members)

June 1988 Central Research Fund Operating Grant, University of Alberta ($2,000.00 for the acquisition of a major 'cults/new religions' collection from the )

1986-87 Social Sciences and Humanities Research Council of Canada. Research Grant, "Sects and Cults in Canada, 1970-1980: A Resource Mobilization Perspective" ($23,000.00)

1986-88 Social Sciences and Humanities Research Council Post-Doctoral Fellowship (offered)

1984-88 Izaac Walton Killam Post-Doctoral Scholarship, Department of Sociology, University of Alberta

1982-83 Social Sciences and Humanities Research Council Fellowship Ontario Graduate Scholarship (offered)

1981-82 Ontario Graduate Scholarship

TEACHING EXPERIENCE

2006 -2011 Appointed as a Fellow of the Institute for United States Policy Studies, University of Alberta

2005-2006 Teaching University of Alberta undergraduate courses on the Sociology of Religion, Religion and Societies, Deviance and Conformity, and Religious Sects; plus graduate courses on Religious Sects and Globalization, Religion, and Fundamentalism. All courses about religion are cross-listed with the Interdepartmental Program in Religious Studies 3

July 2002- Associate Chair-Graduate, Department of Sociology, University of Alberta July 2003

July 1997 Full Professor, Department of Sociology, University of Alberta May 1992 Adjunct Professor, Department of Religious Studies, University of Alberta

July 1989 Associate Professor, Department of Sociology, University of Alberta - Religious Sects (including a graduate course); Sociology of World Religions

Fall 1988 Assistant Professor, Department of Sociology, University of Alberta - Deviance, Religion, and Introduction to Sociology.

Fall 1986 Assistant Professor, Department of Sociology, University of Waterloo (Ontario) - Sociological Theory; Social Movements; Social Change; Ideology and Belief Systems; Social Psychology.

Fall 1984 Lecturer and Sessional Professor, Department of Sociology, Spring, University of Alberta - Sociology of Religion; Religion and 1986 Societies; Qualitative Methods; Contemporary Theory; Deviance.

1977-1983 Teaching Assistant, Department of Religious Studies, McMaster University - The Social- Psychological Dimension of Religion; Cults in North America; Psychology and Religion; Sociology of Religion; Comparative Religion; The Possibility of Religion in the Modern World.

Spring 1977 Teaching Assistant, Department of Philosophy and Religion, American University - Occult World; Comparative Religion

PROFESSIONAL CONTRIBUTIONS

Book: From Slogans to Mantras: Social Protest and Religious Conversion in the Late Vietnam War Era. Syracuse: Syracuse University Press (2001). Selected by Choice: Current Reviews for Academic Libraries as an "Outstanding Academic Title" for 2002.

Articles:

1) "Valentinian Gnosticism and Classical Samkhya — A Thematic and Structural Comparison," Philosophy East and West 30 no.2 (April 1980): 241-259.

2) "'Early' Samkhya in the Buddhacarita," Philosophy East and West 32 no. 3 (July 1982): 259-278; available at: . 4

3) "The 'Papist' Charges Against the Interregnum Quakers," Journal of Religious History 12 (1982): 180-190.

4) "The Quaker Ethic and the Fixed Price Policy: Max Weber and Beyond," Sociological Inquiry 53 no.l (February, 1983): 16-32; Revised Reprint in Time, Place, and Circumstance: Neo-Weberian Essays in Religion, Culture, and Society. Edited by William Swatos. Westport, Connecticut: Greenwood Press, 1990:139-150,198-201.

5) "Relative Deprivation and Resource Mobilization: A Study of Early Quakerism," British Journal of Sociology 33 no. 4 (December 1982): 529-544.

6) "A Sectarian Interpretation of the Rise of Mahayana," Religion 12 (1982): 311-322.

7) "Weber, Goethe, and the Nietzschean Allusion: Capturing the Source of the 'Iron Cage' Metaphor," Sociological Analysis 44 no. 4 (Winter 1983): 297-319.

8) "Weber, Goethe, and William Penn: Themes of Marital Love," Sociological Analysis 46 no. 3 (1985): 315-320.

9) "Psychological and Mystical Interpretations of Early Quakerism: William James and Rufus Jones," Religion 17 (1987): 251-274.

10) "Psychology and Quaker Mysticism: The Legacy of William James and Rufus Jones," Quaker History 76 no. 1 (Spring 1987): 1-17.

11) "Puritan Radicalism and the New Religious Organizations: Seventeenth Century England and Contemporary America," Comparative Social Research 10, (1987): 3-46.

12) "Slogan Chanters to Mantra Chanters: A Mertonian Deviance Analysis of Conversion to the Religious Organizations of the Early 1970s," Sociological Analysis 49 no. 2 (1988): 104-118; Reprinted in Sights on the Sixties, edited by Barbara L. Tischler. New Brunswick, New Jersey: Rutgers University Press, 1992.

13) "Mysticism, Quakerism, and Relative Deprivation: A Sociological Reply to R.A. Naulty," Religion 19 (1989): 157-178.

14) "Deviance Labelling and Normative Strategies in the Canadian 'New Religions/Countercult' Debate," Canadian Journal of Sociology 15 no.4 (1990): 393- 416.

15) (second author with Robert H. Cartwright). "Social Control in Alternative Religions: A Familial Perspective." Sociological Analysis (Winter 1992): 345-361.

16) "Radical Rhetoric and Mystical Religion in America's Late Vietnam War Era." 5

Religion 23 no.l (January 1993): 45-60.

17) "Deviant Scripturalism and Ritual Satanic Abuse. Part One: Possible Judeo- Christian Influences." Religion 23 no.3 (July 1993): 229-241.

18) "Deviant Scriptualism and Ritual Satanic Abuse" Part Two: "Possible Mormon, Magick, and Pagan Influences." Religion 23 no.4 (October 1993): 355-367.

19) "Misattribution and Social Control in the Children of God." Journal of Religion and Health. 33 No.l (Spring 1994): 29-43; Reprinted in Spirituality in East and West No. 1 (1997): 16-22.

20) (with James Spickard). "The 'Other' Civil Religion and the Tradition of Radical Quaker Politics." Journal of Church and State (Spring 1994): 301-315.

21) "Diabolic Debates: A Reply to David Frankfurter and J. S. La Fontaine," Religion 24 (1994): 361-378.

22) "Lustful Prophet: A Psychosexual Historical Study of the Children of God's Founder, David Berg." Cultic Studies Journal 11 No. 2 (1994): 135-188; Available at: < .

23) "Scientology's Relationship with Eastern Religious Traditions." Journal of Contemporary Religion 11 No. 1 (1996): 21-36; Two-Part German Translation as "Scientology und ostliche religiose Traditionen," Berliner Dialog Heft 1-97 (Ostern 1997): 16-21; and "Scientology, religiose Anspruche und Heilungsschwindel," Berliner Dialog Heft 1-97 (Ostern 1997): 22-25. Located on the World Wide Web at: .

24) (with Theresa Krebs). "Academic Compromise in the Social Scientific Study of Alternative Religions." Nova Religio 2 No.l (October 1998): 44-54; Located on the World Wide Web at: .

25) "The Globalization of Scientology: Influence, Control, and Opposition in Transnational Markets." Religion 29 No. 2 (April 1999): 147-169.

26) "Scientology-Is This a Religion?" Marburg Journal of Religion 4 No.l (July 1999): llpp.(ll,006 words); Electronic Journal Located at: ; Italian translation at: .

27) "The Creation of 'Religious' Scientology." Religious Studies and Theology 18 No. 2 (December 1999): 97-126. 6

28) (first author with Deana Hall). " and Re-Indoctrination Programs in the Children of God/The Family." Cultic Studies Journal 17 (2000): 56-78.

29) "The French and German Versus American Debate Over 'New Religions,' Scientology, and Human Rights." Marburg Journal of Religion 6 No. 1 (January 2001): 11 pp. (27,825 words); Electronic Journal Located at: .

30) "'s Celebrity-Lobbyists and the Clinton Administration's American Foreign Policy Toward German Scientology." Journal of Religion and Popular Culture 1 (Spring 2002); Electronic Journal Available at: .

31) (with Joe Szimhart). "Exit Counseling and the Decline of ." Cultic Studies Review 1 No.3 (2002): 241-291; Reprinted in The Phenomenon of Cults From A Scientific Perspective, Edited by Piotr T. Nowakowski. Cracow, Poland: Dom Wydawniczy Rafael, 2007: 327-367.

32) "Spiritual Kinship and New Religions." Religious Studies and Theology 22 No. 1 (2003): 85-100.

33) "Scientology and the European Human Rights Debate: A Reply to Leisa Goodman, J. Gordon Melton, and the European Rehabilitation Project Force Study." Marburg Journal of Religion 8 No. 1 (September 2003); Downloaded from: on September 11, 2003.

34) (co-author with Doni Whitsett). "Cults and Families." Families in Society (October- December 2003):491-502; Reprinted in Cultic Studies Review 3 No. 2 (2004).

35) "Generational Revolt by the Adult Children of First-Generation Members of the Children of God/The Family." Cultic Studies Review 3 No. 1 (2004): 56-72.

36) "Scientific Evaluation of the Dangers Posed by Religious Groups: A Partial Model." Cultic Studies Review 3 No. 2/3 (2004); 101-134; Revised Reprint in The New Religious Question: State Regulation or State Interference? Edited by Pauline Cote and Jeremy T. Gunn. Berlin: Peter Lang: 343-370.

37) "Education and Re-education in Ideological Organizations and Their Implications for Children." Cultic Studies Review 4 No. 2 (2005): 119-145.

38) "A Matter of Principle: Fundamentalist Mormon Polygamy, Children, and Human Rights Debates." Nova Religio: The Journal of Alternative and Emergent Religions 10 Issue 1 (2006): 7-29. 7

39) "Narcissistic Fraud in the Ancient World: Lucian's Account of Alexander of Abonuteichos and the of Glycon:'Ancient Narrative 6 (2007): 77-99,161; reprinted in Cultic Studies Review 7 No. 3 (2008): 225-253.

40) '"Hand-Maids and Daughters of the Lord': Quaker Women, Quaker Families, and Somerset's Anti-Tithe Petition in 1659." Quaker History 97 No. 1 (Spring 2008): 32- 61.

41) "Contemporary Uses of the Brainwashing Concept: 2000 to Mid-2007." Cultic Studies Review 7 No. 2 (2008): 99-128.

42) (co-author with Jodi Lane). "Politiques de Rage et Narcissisme Malin [on Scientology's L. Ron Hubbard]." Criminologie 41 No. 2 (2008): 117-155.

43) "House of Judah, the Northeast Kingdom Community, and 'the Jonestown Problem': Downplaying Child Physical Abuses and Ignoring Serious Evidence." International Journal of Cultic Studies 1 No. 1 (2010): 27-48.

Encyclopedia Articles:

1) "Freemasonry," Canadian Encyclopedia, 2nd Edition. Edmonton, Alberta: Hurtig Publishers, 1988: 845.

2) "Cults." The Encyclopedia of Sociology Volume 1. Edited by Edgar F. Borgotta and Marie L. Borgotta. New York: Macmillan, 1992: 402-404.

3) "Historical Sociology." The Encyclopedia of Sociology, Volume 2. Edited by Edgar F. Borgatta and Marie L. Borgotta. New York: Macmillan, 1992: 837-843; Revised in The Encyclopdia of Sociology Volume 2. 2nd Edition. Edited by Edgar F. Borgatta and Rhonda J. V. Montgomery. New York: Macmillan Reference USA, 2000: 1195- 1202.

4) "Crimes." The Encyclopedia of Religion and Society. Edited by William Swatos. London: Alta Mira Press, 1998: 121-122.

5) "Deviance." The Encyclopedia of Religion and Society. Edited by William Swatos. London: Alta Mira Press, 1998: 137-139.

6) "Quakerism." The Encyclopedia of Religion and Society. Edited by William Swatos. London: Alta Mira Press, 1998: 395-396.

7) "Violence." The Encyclopedia of Religion and Society. Edited by William Swatos. London: Alta Mira Press, 1998: 540. 8

8) (with Melodie Campbell). "UFO/Flying Saucer Cults." The Encyclopedia of Religion and Society. Edited by William Swatos. London: Alta Mira Press, 1998: 531-532.

9) "Scientology." Encyclopedia of Religion and Nature. Edited by Bron R. Taylor and Jeffrey Kaplan. London: Thoemmes Continuum, 2005:1499-1501.

10) (co-author with Susan Raine). "New Religious Movements." Encyclopedia of Language and Linguistics. Edited by E.K. Brown. Volume 8. 2nd Edition. Oxford: Elsevier, 2006:: 608-611.

11) "Scientology." Encyclopedia of Religion, Communication, and Media. Edited by Daniel A. Stout. New York: Routledge, 2006: 390-392.

12) (co-author with Janet Klippenstein). "New Religions." Encyclopedia of Love in World Religions, Volume 2. Edited by Yudit Kornberg Greenberg. Oxford: ABC Clio, 2008: 447-451.

13) (first author with Ashley Samaha.) 2011. "Deconversion." Vocabulary for the Study of Religion. Edited by Kocku von Stuckrad and Robert Segal. Leiden: E.J. Brill (forthcoming).

Book Chapters:

1) "New Religious Movements," in The Sociology of Religion: A Canadian Focus. Edited by Ted Hewitt. New York: Butterworths, 1993: 83-106.

2) (coauthor with Charles Hobart). "Religion and Societies," in Introduction to Sociologyj_2nd Edition. Edited by David Pierce and Bill Meloff. Scarborough, Ontario: Nelson Canada (1994): 311-339.

3) (second author with Gordon Drever). "Gods From Afar," in Edmonton: The Life of a City. Edited by Bob Hesketh and Frances Swyripa. Edmonton: NeWest Press (1995): 275-282.

4) "Brainwashing Programs in The Family/Children of God and Scientology." in Misunderstanding Cults: Searching for Objectivity in a Controversial Field. Edited by Benjamin Zablocki and Thomas Robbins. Toronto: University of Toronto Press: 2001: 349-378.

5) "Compelling Evidence: A Rejoinder to Lorne Dawson's Chapter." in Misunderstanding Cults: Searching for Objectivity in a Controversial Field. Edited by Benjamin Zablocki and Thomas Robbins. Toronto: University of Toronto Press: 2001:401-411. 9

6) "Seven Thousand 'Hand-Maids and Daughters of the Lord': Lincolnshire and Cheshire Quaker Women's Anti-Tithe Protests in Late Interregnum and Restoration England." In Women, Gender and Radical Religion in Early Modern Europe. Edited by Sylvia Brown. Leiden: E.J. Brill: 2007: 65-96.

7) "Post World War II New Religious Movements in the West." In The World's Religions: Continuities and Transformations. 2nd Edition. Edited by Peter Clarke and Peter Beyer. New York: Routledge: 2008: 492-510.

8) "Harm, Human Rights, and the Continued Criminalization of Fundamentalist Mormon Polygamy." Fundamentalism, Politics, and the Law. Edited by Marci Hamilton and MarkRozell. New York: Palgrave: 2011:161-192.

9) "The Decline of Scientology," In Dialog in Konfrontation—und die Wahrheit wird sie frei machen: Eine Festschrift fur Thomas Gandow. Edited by Christoph Polster and Ede Ingolf Christiansen. Jena: Jenaer Akademische Verlagsgesellschaft.

Institute Publications

1) "Scientology in the United States." in Wie umgehen mit Scientology? Ein internationaler Vergleich. Edited by Christian Koecke. Konrad Adenauer Stiftung Interne Studie Nr. 152/1998. Sant Augustin, Germany (April 1998): 15-24.

2) "Scientology in Canada."in Wie umgehen mit Scientology? Ein internationaler Vergleich. Edited by Christian Koecke. Konrad Adenauer Stiftung Interne Studie Nr. 152/1998. Sant Augustin, Germany (April 1998): 25-31.

3) Gehirnwasche im Rehabilitation Project Force (RPF) der Scientology-Organisation. Freie und Hansestadt Hamburg [Germany], Behorde fur Inneres-Arbeitsgruppe Scientology und Landeszentrale fur politische Bildung. (October 2000): 72 pp.; in English as Brainwashing in Scientology's Rehabilitation Project Force (RPF). Behorde fur Inneres-Arbeitsgruppe Scientology und Landeszentrale fur politische Bildung. (October 2000): 63 pp.

Popular Press:

1) (co-author with Theresa Krebs). "When Scholars Know Sin: Alternative Religions and Their Academic Supporters." Skeptic 6 No.3 (1998): 36-44; Located on the World Wide Web at: .

2) "Zur wissenschaftlichen Untersuchung von Religionen und neuen religiosen Bewegungen." Berliner Dialog Heft 2 (1998): 4-8. 10

3) (co-author with Theresa Krebs). "Clarifying Contentious Issues: A Rejoinder to Melton, Shupe, and Lewis." Skeptic 7 No.l (1999): 21-26; Located on the World Wide Web at: http://www.gospelcom.net/apologeticsindex/c40.html>.

Reviews:

1) Gordon Marshall, In Search of the Spirit of Capitalism: An Essay on Max Weber's Protestant Ethic Thesis. Journal for the Scientific Study of Religion 22 no.4 (December 1983): 388,390.

2) Roger O'Toole, Religion: Classic Sociological Approaches. Canadian Journal of Sociology 10, (1985): 322-324.

3) Said Arjomand, The Shadow of God and the Hidden Imam: Religion, Political Order, and Societal Change in Shi'ite Iran from the Beginning to 1890. Sociological Analysis 47 no.4 (Winter 1987): 369-370.

4) E. Burke Rochford, Jr. Hare Krishna in America. Canadian Journal of Sociology 10 no. 3 (Summer 1987): 153-157.

5) Douglas Curran, In Advance of the Landing: Folk Concepts of Outer Space. Sociological Analysis 49 no.2 (1988): 197-198.

6) Randall Collins, Max Weber: A Skeleton Key. Sociological Analysis 49 no.3 (1988): 314-315.

7) Review of "The Sage Qualitative Research Methods Series: Vols.1-7." Canadian Review of Sociology and Anthropology 26: 848-852.

8) Miriam Williams, Heaven's Harlots: My Fifteen Years as a Sacred Prostitute in the Children of God Cult. Nova Religio 3 No. 1 (1999): 163-167.

9) Rosemary Hamilton, Hellbent for Enlightenment: Sex, Power, and Death with a Notorious Master. Nova Religio 6 No. 1 (October 2002): 204-206.

10) James D. Chancellor, Life in The Family: An Oral History of the Children of God. Nova Religio 8 No. 1 ((July 2004): 108-112.

RELATED EXPERIENCE

Occasional reviewer, Journal for the Scientific Study of Religion; Social Science Federation of Canada; Research in the Social Scientific Study of Religion; Social Sciences and Humanities Research Council of Canada; Religion; Nova Religio, Current Sociology; Cultic Studies Review; Journal of Religion and Popular Culture, etc. 11

Spring 2004 Editorial Advisory Committee, Journal of Religion and Popular Culture to Present

2002 to Editorial Board, Cultic Studies Review Present

1990 to Lecturer to various professional and civic organizations on non-traditional Present religions.

Summer 1989 Field Research, interviews, and archival research —Vancouver, Victoria, Seattle, Portland, , Los Angeles, Toronto, and Thunder Bay, Ontario.

Spring 1988 Associate Editor, Sociological Analysis.

Summer 1988Field research, interviews, and archival research - Calgary, Berkeley, San Francisco, Los Angeles, Santa Barbara.

Fall 1987 Field research, interviews, and archival research - Toronto, Ottawa, , New York, Washington D.C., Pittsburgh, Philadelphia, and Knoxville.

1983 Co-designer - "Hierophant's Heaven: An Instructional Simulation for Religious Studies" ().

Summer 1982 English Archival and Library Research - Chester, Lincoln, Tauton, Kendal, and 1983 and London.

LEGAL CONSULTATIONS AND TESTIMONIES

1984 "Midtdal vs. Midtdal" Civil Case, Edmonton, Alberta. Report on Behalf of Ms. Midtdal [Concerning Scientology]. (November 11).

1993 "Regina v. Ronald Lee Stephenson."Criminal Trial, Edmonton, Alberta. Testified as an Expert Witness for the Plaintiff [Concerning Satanism]. (April 1).

1994 "Paterson v. Paterson." Court of Queen's Bench, Swift Current, Saskatchewan. Testified as an Expert Witness for Ms. Paterson [Concerning Satanism].

1997 "Ken Montgomery v. Allan Anthony Buttnor." Expert Statement on Behalf of Plaintiff [Concerning Scientology]. (August 27).

1997 Filed an Expert Report, and Testified for the Alberta Ministry of Justice, Family 12

Law Division, in a child visitation case (Report Filed October 20, 1997), and testified in the trial [concerning ritual abuse and Satanism].

1998 "Bonnie Louis Woods v. Sheila Chaleff, Graeme Wilson, Cathy Sproule, and Religious Education Inc." High Court of Justice, Queen's Bench Division [London, England]. 1993 W No. 2079. Witness Statement [Concerning Scientology]. (November 3,1998).

1998 "Religious Technology Center and , Inc.v Dennis Erlich." United States District Court for the Northern District of . Case No. C95-20091. Expert Statement [concerning Internet postings of Scientology documents]. (December 29).

1999 Filed an Expert Report in a Child Visitation Case in London, England [Concerning Scientology]. (February 10).

1999 Court submission about Scientology's perception of Dennis Erlich as a "," and its aggressive actions against him. (February 11).

1999 "Bridge Publications, Inc. v. F.A.C.T.NET, Inc., , and Robert Penny" United States District Court for the District of Colorado. Civil Action No. 95-K-2143. Expert Statement on Behalf of Defendant [concerning Scientology]. (February 16).

1999 "EEOC v. 1-20 Animal Medical Center." C.A. No. 3-98-CV 2316-X. Expert Report for the Plaintiff [Concerning Scientology]. (November 9).

1999 "Jesse Wickenheiser, et. Al vs. City of Austin, et. al." [Concerning The Children of God/The Family]. Cause No. 97-06837. Deposed August 27,1999.

1999 "B.F. et al v. Society of Kabalarians of Canada et al." SCBC Action No. C983834, Vancouver Registry. Expert Report for Plaintiffs [Concerning Sexual Abuse Allegations]. (August 24).

2000 "Estate of Lisa McPherson... v. Church of Scientology Flag Service Organization, Janis Johnson, Alain Kartuzinski, and David Houghton," Case No.: 97-01235, Division H. Expert Report filed for Plaintiff [Concerning Scientology]. (January 6).

2001 "Laura Vannoy Padgett vs. Thomas C. Padgett." Commonwealth of Kentucky, Hopkins Circuit Court, Madisonville, Kentucky 42431. Civil Action Number 92-CI- 00444. Expert Statement for the Defendant [Concerning Scientology]. (April 27).

2003 "Mary Johnston v. Church of Scientology Mission of Dublin Limited, John Keane, Tom Cunningham, and Gerard Ryan." Expert Witness Testimony [Concerning 13

Scientology]. (January and March). Case Settled Out of Court, Spring 2003.

2003 "Diana Kostelny, Jerry Kostelny, Gail Eberhardt, Carl Eberhardt, Melanie Post (formerly Grant) and Gregory R. Post v. C. Aydin Cabi, DDS, INC. Expert Statement for the Plaintiff [Concerning Scientology and WISE]. (September 7).

2003 "Front Sight Management... and Dr. Ignatius A. Piazza v. Diana Mertz Hsieh." Expert Report Submitted on Behalf of the Defendant. (November 13).

2008 "In re Marriage of EGLASH." L.A.S.C. Case No. BD 477485. Statement on Behalf of Petitioner Carolyn Eglash [involving Scientology]. (January 14).

2010 Reference Opinion to the Supreme Court of British Columbia on Behalf of Stop Polygamy in Canada in the Matter of The Constitutional Question Act, R.S.B.C. 1986, C. 68 and the Matter of The Canadian Charter of Rights and Freedoms and in the Matter of: a Reference by the Lieutenant Governor in Council Set Out in Order in Council No. 533 Dated October 22,2009 Concerning the Constitutionality of S. 293 of the Criminal Code of Canada, R.S.C. 1985, C.C-46 (July 15). Testified before the British Columbia Supreme Court on January 19,2011.

2010 Affidavit and Supplemental Expert Report on the Case of Nakishia Williams v. Dr. Lowery's Dental Group. Case No. 09 CV-9557. Denver, Colorado (October 22). [Concerning WISE and Scientology; case settled out of court].

2011 Amicus Curiae Submission Concerning Polygamy on Behalf of Stop Polygamy in Canada; Cross Examination in the Supreme Court of British Columbia at Vancouver, Concerning the Constitutionality of Section 293 of the Criminal Code (January 19, 2011). CURRICULUM VITAE

Francis Willard Rushing 912 Dixie Avenue Madison, Georgia 30650

Phone: 706-343-0110 Cell: 706-474-2422 E-Mail [email protected]

PERSONAL DATA: Date of Birth: July 30,1939 Citizenship: United States Marital Status: Married Children: 4

EDUCATION: Ph.D., Economics, University of North Carolina at Chapel Hill, 1967 A.B., Economics, University of Georgia, 1961 (Magna cum laude)

FELLOWSHIPS AND AWARDS: Phi Beta Kappa; Phi Kappa Phi; Who's Who in American Colleges and Universities; NDEA Graduate Fellowship

EXPERIENCE: Academic Appointments

July, 2000 Emeritus Professor of Economics, Georgia State University

August, 2000 - August, 2002 Professor of Economics and Director, Center for (Part time) Business and Economic Education

1990 - July, 2000 Holder, Bernard B. and Eugenia A. Ramsey Chair of Private Enterprise, Georgia State University

1980 - July, 2000 Professor of Economics, Georgia State University

1974 - 1980 Associate Professor of Economics, Georgia State University

1972 -1974 Associate Professor of Economics, College of William and Mary

1968 - 1972 Assistant Professor of Economics, University of Georgia

Summers 1969, Visiting Assistant Professor of Economics, 1970, 1971 University of North Carolina at Chapel Hill

1

PLAINTIFF'S EXHIBIT Administrative Appointments

1993-1996 Interim Chairman, Department of Economics, Georgia State University

1986-1999 Director, International Center for Entrepreneurship, Georgia State University

1986- 1990 Associate Dean for Research, College of Business Administration

1980- 1986 Chairman, Department of Economics, Georgia State University

1984-1986 Interim Director, Institute of International Business, Georgia State University

1974-1981 Executive Director of the Georgia Council on Economic Education and Director, Center for Business and Economic Education, Georgia State University

1971 - 1972 Assistant Dean of Graduate School, University of Georgia

Consulting

1977-1993 Senior Economics Consultant, Science Policy Program, International Policy Center, SRI International, Arlington, Virginia

1976-1977 Senior Economist and Program Manager in Economics, Center for Strategic Studies, SRI International, formerly Stanford Research Institute (on leave from Georgia State University)

Military Service 1965 - 1968 Officer, United States Air Force, assigned as an economic analyst to the Department of Defense

2 PUBLICATIONS

Books:

The Visible Hand: The Challenges to Private Enterprise in the 21st Century, editor, Ramsey Chair of Private Enterprise, Georgia State University, Atlanta, Georgia, June, 2000. 257pp.

Intellectual Property Rights in Science, Technology, and Economic Performance: International Comparisons, editor (with Carole Ganz Brown, National Science Foundation), Westview Press, January 1990, 354 pp. (abstracted in Journal of Economic Literature, December 1990, pp. 1837- 1838)

National Policies for Developing High Technology Industries: International Comparisons, editor (with Carole Ganz Brown), Westview Press, 1986, 243 pp. (abstracted in Journal of Economic Literature. March 1987)

Economics, a textbook (with Arnold Heertje and Felicity Skidmore), Dryden Press, 1983,473 pp.

The Science Race: Training and Utilization of Scientists and Engineers, US and USSR (with Catherine P. Ailes), Crane, Russak and Company, Inc., 1982, 254 pp.

Articles, Book Chapters and Monographs:

"An Educational Policy for Teaching Entrepreneurship to Pre-University Students" in Global Perspectives on Entrepreneurship Policy. U.S. Small Business Administration Office of Advocacy, National Federation of independent Business Research Foundation, United States Association for Small Business and Entrepreneurship, June, 2005 Pp. 47-50.

"Introduction" pp. 1-14 and "Criticisms of the Free Market and Response" (with Don Mathrews) pp. 137-158 in The Visible Hand: The Challenge to Private Enterprise in the 21s' Century, Francis W. Rushing, Editor. Ramsey Chair of Private Enterprise, Georgia State University, Atlanta, Georgia. 2000.

"The Status of K-12 Entrepreneurship Education in the United States (with Calvin Kent) in Social Studies Education: An International Perspective, David Lines and William Walstad, Editors, Institute of Education, University of London, London, England, 2000.

"Economic Education and Business Education: Convergence or Divergence?" (with Marie Wilson) in Social Studies Education: An International Perspective, David Lines and William Walstad, Editors, Institute of Education, University of London, London, England, 2000.

"Enterprising People, Born or Created?" Children's Social and Economic Education, 2000.

"An Empirical Analysis of the Impact of Patent Protection on Economic Growth: An Extended Analysis" (with Mark Thompson) Journal of Economic Development, Vol. 24, No, 1, June, 1999. Pp.67-76. "Coverage of Entrepreneurship in Principles of Economics Textbooks: An Update" (with Calvin KenQ.Journal of Economic Education., 1999. Pp. 184-188.

"The Status of Entrepreneurship Education in the United States: A Summary", (with Calvin Kent) Frontiers of Entrepreneurship Research. 1998. Arthur M. Blank Center for Entrepreneurship, Babson College, 1998, Pp. 675-676.

"Education in Transition from School to the Workplace", (with John Soper and George Vredeveld), Journal of Private Enterprise. Vil. XIV, No. 1, Fall 1998. Pp. 29-44.

"Science, Technology, Education, Institutions and Economic Growth" in Humanities and Science: Present and Prospective Vision, Universidad del Salvador, Buenos Aries, Argentina, 1998.

Creating the Workforce of the Future: A Requirements Analysis, (with Stanley Smits) Fiscal Research Program, Georgia State University, February, 1998,44pp.

"An Empirical Analysis of the Impact of Patent Protection on Economic Growth", (with Mark Thompson) Journal of Economic Development. Vol.21, No.2,1996.

"Positioning the United Kingdom's Workforce for the 21st Century: Meeting the Leadership Challenge at the Community Level," (with Stanley Smits, and David W.G. Hind), Proceedings of the ENDEC Conference on Globalization and Entrepreneurship. December 1996. pp. 83-91.

"Global Competition for Work: Recent Preparations in Wales," (with Stanley Smits), Journal of Transnational Management Development. Vol.2, No.2,1996 pp. 55-68.

"Intellectual Property Protection, Entrepreneurship, and Economic Growth" (with Mark Thompson), Journal of Enterprising Culture, Vol. 4.3, Singapore: Nanyang Technological University, Entrepreneurship Development Center, September 1996. pp. 267-285.

"Olympic Tickets: Good as Gold" (with Marie Wilson), The Senior Economist. New York: National Council on Economic Education, Vol. 11, no. 4, April 1996.

"Economics and Entrepreneurship Education in ," in New Developments in Economic and Business Education. The Economics and Business Education Association of the United Kingdom, 1996. pp. 125-133.

"An Approach to Issues-Oriented Economics Education Course" (with Beverty J. Armento and Wayne A. Cook), in Handbook on Teaching Social Issues. Ronald W. Evans and David W. Saxe, eds., National Council for the Social Studies, 1996. pp. 211-219.

'Technology Transfer and Environmental Issues," Society and the University in the 21st Century. Universidad del Salvador, Argentina, Fall 1994, pp. 373-384.

"The Changing Face of Economics Instruction in Russia," Chapter 14 in William Walstad (ed.), An International Perspective on Economic Education. Kluwer Academic Publishers, 1994, pp. 233-254. "Environmental Issues and Economic Growth: The Case of NAFTA" (with Carole Ganz Brown), proceedings of the symposium, The New Vision of America in the 21 st Century, Universidad del Salvador, Argentina, 1993, pp 71-96. The paper is published in both Spanish and English.

"Clarifying the Role of Entrepreneurship in Neo-Classical Macro-Economics: Policy Implications" (with Calvin Kent), Journal of Private Enterprise, Vol. 9, no. 1, Summer 1993.

"The Emerging World Market," Visions, an international magazine, July 1993.

"Economics, Technology Transfer and Strategies for Development," chapter in New World Order, Social and Economic Implications, David C. Bruce (ed.). Georgia State University Business Press, Winter 1993, pp. 163-172.

"Economics, Entrepreneurship and Enterprising Individuals: A Challenge for the Social Sciences ." Georgia Social Studies Journal, Vol. 22, no. 1, March 1992, pp. 20-24.

"The Position of Distinguished Economists on Economics Education," Chapter 3 in Judith Staley Brenneke, Editor, An Economy at Risk: Does Anyone Care?, Georgia State University Business Press, 1992, pp. 25-33.

"Cost-Effective Solutions to Environmental Problems: Give the Market a Chance" (with Carl Mink), Journal of Private Enterprise. Fall 1992, Vol. VIII, no. 1, pp. 171-84.

"General Issues Affecting the Development of High Technology Industries," Proceedings of the MidSouth Academy of Economics and Finance, 1991. pp. 471-477.

"Intellectual Property Rights in the 1990's: Problems and Solutions," J. Anderson Davis Lecture Series Keynote Address, February 1990. Journal of Economics and Finance Papers and Proceedings, 1991, pp. 1-5.

"Soviet Math and Science Educational Reforms During Perestroika," Technology in Society (with Catherine P. Ailes), Vol. 13, February 199I, pp. I09-I22

"An Overview of Entrepreneurship in Economics" (with Calvin A. Kent) pp. ix-xiv; and 'The Enterprising Teacher" (with Gary Rabbior), pp. 65-70; Master Curriculum Guide: Teaching Strategies in Economics and Entrepreneurship, Joint Council on Economic Education, 1991.

"The Next Stage of the DEEP Process," Chapter 21 in Effective Economic Education in the Schools, William B. Walstad and John C. Soper, editors, National Education Association and Joint Council on Economic Education, 1991, pp. 295-308.

"Entrepreneurship and Education," in Calvin Kent, ed., Entrepreneurship Education: Current Developments, Future Directions, Quorum Press, 1990, pp. 29-39

"Economics and Entrepreneurship Education in the Elementary Grades," in Calvin Kent, ed., Entrepreneurship Education: Current Developments. Future Directions, Quorum Press, 1990, pp. 153-164 "Private Enterprise and Perestroika: Contrast or Convergence?", The Senior Economist (with Douglas D. Frutiger), Vol. 5, No. I, May 1990, pp. 6-7

"Update China: Technology Transfer and Trade", Business (with Arnold Miller), January/February/March 1990, Vol. 40, No. I, pp. 25-33

Science and Mathematics Education in the USSR (with Catherine Ailes), Technical Note STPP- TN-89-I, Summary Report prepared for Directorate of Science and Engineering Education, National Science Foundation, SRI International, 1989,104 pp.

"A Rationale for Entrepreneurship Education in Secondary Schools (with William D. Donnelly), Journal of Private Enterprise, Vol. IV, Fall 1988, pp. 97-102

"Black Entrepreneurship: Opportunities and Challenges" (with Mark Rider), Journal of Private Enterprise. Vol. Ill, Number I, Fall 1987, pp. 117-121

"Summary of the Proceedings," U.S.-P.R.C. Joint Workshop on Measurement of the Impact of S&T on Development. Final Report. National Science Foundation, September 1987, pp. 1-14. Chinese language version published May 1989.

"Science Curricula: An International Comparison Between the U.S. and the USSR" (with Catherine P. Ailes), Chapter 9 in The Science Curriculum, ed. by Audrey B. Champagne and Leslie E. Hornig, American Association for the Advancement of Science, Washington, D.C., 1987, pp. 165-168

"In Defense of Realistic International Economics: Free Trade," Journal of Economic Education. Vol. 18, No. 2, Spring 1987, pp. 185-190

'Training and Utilization of Scientists and Engineers in the U.S." (with Catherine P. Ailes), Proceedings. U.S.-China Conference on Science Policy. Committee on Scholarly Communication with the People's Republic of China, American Council of Learned Societies, National Academy of Sciences, Social Science Research Council, National Academy Press, 1985, pp. 244-281. Chinese language edition, 1986

"High Tech Trade - Are We Losing the War?", Business. July/August/September 1985, pp. 36- 42

Communicating Economic Understanding: A Handbook for Program Directors (with Craig Aronoff and David Martin), Joint Council on Economic Education, 1985

"Review of U.S. Advanced Technology Policy," Proceedings, Brazil-U.S. Business Council VII Plenary. 1983. U. S. Chamber of Commerce, 1985, pp. 81-93

"U.S.-Brazil Private Sector Cooperation in Science and Technology for the 1980's" (with Carole Ganz Brown), Proceedings. Conference on U.S.-Brazil Private Sector Cooperation in Science and Technology, National Science Foundation, 1983

"A Summary Report on the Educational System of the United States and the Soviet Union: Comparative Analysis" (with Catherine P. Ailes), prepared for the National Commission on Excellence in Education and cited in A Nation at Risk: The Imperative for Educational Reform. A Report to the Nation and the Secretary of Education. National Commission on Excellence in Education, April 1983

'The Emerging Impact of Foreign Competition on National Security and Emergency Preparedness Telecommunication" (with Catherine P. Ailes), SRI International, Menlo Park, California, January 1982

"Education and Human Resources in Soviet Growth Strategy" (with Catherine P. Ailes), Comparative Strategy: An International Journal. Vol. 3, No. 3, Winter 1982, pp. 219-244

Comparison of the Methods of Financing Research and Development in the U.S. and USSR (with Catherine P. Ailes and James Styles), prepared for National Science Foundation, Washington, D.C., 1981, 78 pp.

"What is Economic Education?" in Consumer Education and Economic Education in the Public Schools. Judith Staley Brenneke, Editor, U.S. Department of Education and Joint Council on Economic Education, 1981, pp. 45-49

"Building an Effective Economic Education Program Using Principles of Successful Adoption and Implementation" (with Carole Hahn), Economic Education: Links to the Social Studies, S. Stowell Symmes, ed., National Council of the Social Sciences and the Joint Council on Economic Education, 1981

The Planning and Management of Research and Development in Soviet Industrial Organizations, editor, prepared for National Science Foundation, May 1980

A Summary Report on the Educational Systems of the United States and the Soviet Union: Comparative Analysis (with Catherine P. Ailes), Technical Note SSC-TN-7557-12, prepared for National Science Foundation, Washington, DC, March 1980, 33 pp.

"An Assessment of the USSR-US Scientific and Technical Exchange Program," in Soviet Economy in a Time of Change, Joint Economic Committee, United States Congress, October 1979, pp. 605-624

"The Application of Economic Leverage in U.S.-USSR Relations," Comparative Strategy: An International Journal. Vol. I, No. 4, October 1979 (with Herbert S. Levine and Charles H. Movit), pp. 371-404

'The Role of U.S. Imports in the Soviet Growth Strategy for the Seventies," Journal of International Business Studies. FalWVinter 1977, pp. 31-47 (with Anne Lieberman)

Pacing Industries in the USSR. 1944-1990. and Implications for Forecasting New Plant Facilities (with Holland Hunter, Charles Movit, and Arthur Zuehlke), SSC-TN-77-3, SRI International, Menlo Park, California, July 1977

"Promoting Curriculum Change in Economics: A Model," Southern Social Studies Quarterly, Winter 1976 "A Prime Need: Education in Economics," Atlanta Magazine, January 1976

"U.S.-USSR Trade and Soviet Technology Requirements," (with Anne Lieberman), Association for Comparative Economic Studies Bulletin, Fall 1976, pp. 61-77

Contributor to the SRI-WEFA Soviet Econometric Model, Vol. I and II: Phase III (authors: Donald W. Green, Lawrence Klein, Herbert S. Levine, Peter Miovic, Gene D. Guill, and Ross S. Preston), SSC-TN-2970-5, Stanford Research Institute, Menlo Park, California, October 1976

"Soviet Chemical Industry: A Modern Growth Sector," in Soviet Economy in a New Perspective, Joint Economic Committee, United States Congress, October 1976, pp. 535-557

"Economic Education: What Course of Action," Georgia Social Studies Journal. November 1976

Study of the Political and Military Utility of U.S.-USSR Economic Relations (with Herbert S. Levine, Arthur A. Zuehlke, Charies H. Movit, and James E. Cole), SSC-TN-5087-I, Stanford Research Institute, Menlo Park, California, December 1976

Impact on U.S. Foreign Trade and Investment From Commercial Transfers of Advanced Technology to the Soviet Union and Eastern Europe (with Anne Lieberman), SSC-TN-75-3, Stanford Research Institute, Menlo Park, California, February 1975, 66 pp.

Technical Change in the Soviet Chemical Industry (with Carlisle Moody, Jr.), SSC-TN-2625-8, Stanford Research Institute, Menlo Park, California, February 1975,41 pp.

"Economic Education in Georgia, Progress, Joint Council on Economic Education, December 1975

"An Economics Index to the Quality of Life," a note, Western Economic Journal, Volume XI, No. I, March 1973, p. 116

"Growth, Capital-Output Ratios, and the Soviet Chemical Industry," Economia Intemazionale, Volume 25, No. 4, November 1972, pp. 3-15

"Bonus Formulae and Soviet Managerial Performance: A Comment," Southern Economic Journal. Vol. 38, No. 4, April 1972, pp. 569-572.

A series of articles on comparative economic systems in Economic Encyclopedia. Dushkin Publishing Group, Inc., 1972.

Transportation and Spatial Mobility in India (with J.C.D. Blaine), Chapel Hill Graduate School of Business Administration, University of North Carolina, 1965, 59 pp.

Book Reviews:

Intellectual Property Rights and Capital Formation by Charles E. Walker and Mark A. Bloomfield (eds.), Small Business Economics. An International Journal, 1992, pp. 245-246.

Technology in Comecon, by Wilczynski, ACES Bulletin. Summer 1976

8 The Spoils of Progress: Environmental Pollution in the Soviet Union by Marshall I. Goldman, Southern Economic Journal, Vol. 40, No. I, July 1973.

The Soviet Model and Underdeveloped Countries by Charles K. Wilber, Southern Economic Journal. Vol. 37, No. 1,1970.

Myth. Oil, and Politics. Introduction toth e Political Economy of Petroleum by Charles F. Doran, Journal of Comparative Strategy. Vol. I, No. 2,1980

Research Papers and Reports:

"An Empirical Analysis of the Impact of Patent Protection on Economic Growth," (with Mark A. Thompson), Research Paper No. 54, Georgia State University, Policy Research Center, June 1995.

"Preparing for the Challenge of a Global Workforce: A Study of Training and Enterprise Councils in Wales," (with Stanley J. Smits), Research Paper No. 47, Georgia State University, Policy Research Center, August 1994.

"Human Resource and Enterprise Development at the Community Level in Great Britain: A Strategic Constituencies Assessment," (with Stanley J. Smits and David W. G. Hind), Research Paper No. 62, Georgia State University, Policy Research Center, July 1996.

"Strategies for Designing Economic Education Programming for the Commonwealth of Independent States," (with Thomas McKinnon), Research Paper No. 27, Georgia State University, Policy Research Center, July 1992.

"Georgia's Workforce Development Challenge: A Study of Best Practices and Options", (with Stanley J. Smits, and Lori Fancher) Report for the Office of Planning and Budget, State of Georgia. June, 1997.

"Plant Closings in the Textile and Apparel Industries: An Analysis" (with Julia Melkers and David Sjoquist) Report for the Office for Planning and Budget, State of Georgia, July, 2000 CERTIFICATE OF SERVICE

I hereby certify that I have this day served the attorneys of record a copy of the foregoing Plaintiffs' Expert Disclosures by placing same in the United States Mail with adequate postage affixed thereon, addressed as follows:

Robert G. Tanner, Esq. Sean L. Hynes, Esq. Scott Kerew, Esq. Downey & Cleveland, LLP Jeffrey Amason, Esq. 288 Washington Ave. Weinberg, Wheeler, Hudgins, Gunn & Dial, LLC Marietta, GA 30060 3344 Peachtree Road, Suite 2400 Atlanta, Georgia 30326 Attorneys for Delgado Development, Inc.

Attorneys for Lisa Carolina Robbins, M.D., and The Robbins Group, Inc.

Stevan A Miller, Esq. Drew, Eckl & Farnham, LLP 880 W. Peachtree Street P.O. Box 7600 Atlanta, Georgia 30357

Attorneys for Narconon of Georgia, Inc., and Narconon International

This 1st day of November, 2011.

HARRIS PENN LOWRY DELCAMPO, LLP

JEFFREY R. HARRIS /Georgia Bar No: 330315 J. ANTONIO DELCAMPO Georgia Bar No. 216815

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