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In the State Court of Dekalb County State of Georgia

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In the State Court of Dekalb County State of Georgia IN THE STATE COURT OF DEKALB COUNTY STATE OF GEORGIA 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 NARCONON 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 medicine in the State of Louisiana. Dr. Roy specializes in the study and treatment of substance addiction, 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 Scientology. 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 Physicians 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, Idaho 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 & Substance Abuse 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
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