Plaintiff SARAH LOCATELLI In Pro Per (530) 274-8198 (phone/fax) SUPERIOR COURT FOR THE STATE OF CALIFORNIA COUNTY OF NEVADA SARAH LOCATELLI, an individual, ) Case No. L75070 ) ) UNLIMITED CIVIL CASE Plaintiff, ) ) vs. DECLARATION OF SARAH LOCATELLI NARCONON SOUTHERN CALIFORNIA, a ) ) IN SUPPORT OF THE OPPOSITION TO California corporation, NARCONON ) MOTION TO CHANGE VENUE JOSHUA HILLS, a California corporation, and ) DOES 1 through 20 inclusive, ) Date: September 25, 2009 ) ) Time: 10:00 a.m. Defendants. ) Date action filed: June 29, 2009 ) Trial Date: None yet ) ) ) ) ) ) ______________________________________) I, Sarah Vogel, declare: I stand by my Complaint and ask that the Court consider it while reading this DECLARATION presented to the Court as an incorporated document in support of the OPPOSITION TO MOTION TO CHANGE VENUE. I never signed a written contract with any Narconon organization. The extent of the contract between the parties in this case is the telemarketing calls to and from and between fake referral help line phone number acting as a Narconon representative (Desiree Romero) and an employee of Narconon (Micki Allen) who took my credit card information when I agreed to purchase "Joshua Hills" rehabilitation services and later the 2 post dated checks made out to Narconon Southern California which I faxed copy of and then sent originals in the mail based upon what I was told to do. I never received a receipt for the deposit monies I paid by credit card; I was never informed that my deposit was going to any other entity besides the fictitious " Joshua Hills" which I was told by the rep was the California equivalent of "St Jude's of Nebraska". I was never informed that it was a Narconon entity until after my deposit was taken and cleared via credit card transaction done over the telephone as I was told who to make the remaining post dated payments out to. I was promised many things over the phone by Narconon representatives and employees but I was never informed by the parties that the parties involved were in a collusion type of activity and that they were in violation of federal and state consumer and telemarketing law. I was never informed of any refund policy before or after my money was taken by DEFENDENTS. I was only informed after Daniel left the program and I called to get a refund of money back. To my knowledge, DEFENDENTS did not tape record the financial transaction nor provide financial receipts. This is in violation of When I asked for a receipt, my request was ignored. I was pregnant with a toddler at home during the transaction and during the whole of the pregnancy I attempted to get a refund to no avail, causing financial, emotional and physical distress. I suffered this in Nevada County where I live as I tried to unravel and rectify the situation by phone, email and fax. Defendants, NARCONON SOUTHERN CALIFORNIA (NNSC) and NARCONON JOSHUA HILLS (NN JH) are separate corporate entities with operations in various locations and in the state of California. Additionally, NARCONON SH has operations in Nevada and Colorado. NNSC solicits customers via telephone, internet, via referral websites and 3rd party sellers throughout the United States and the State of California, including customers in Grass Valley, California, County of Nevada on their official website http://www.usnodrugs.com/California/Grass_Valley/17 , the site which is noted on their 990 tax returns ( www.usnodrugs.com.) As noted in the Complaint, the true names or capacities, whether individual, corporate, associate, or otherwise, of Defendants named in this action as DOES 1 through 20, are unknown as of yet to Plaintiff, who therefore sues these Defendants by such fictitious names. Plaintiff will amend this complaint to show the true names and capacities of the fictitiously named defendants when they have been ascertained. It is my belief and understanding, that DESIREE ROMERO, formerly known as DESIREE DANNER, has worked and continues to work for various NARCONON entities across the United States beginning in 2001, after having personally completed the Narconon Program herself in Oklahoma. http://abcnews.go.com/print?id=127115 Desiree Romero is a resident of the State of Texas and operates multiple "rehab referral" and "rehab hotline" websites. It is my belief that Desiree's priority placements and referrals are on behalf of the Narconon program, as evidenced by her high earnings records from the various Narconon 990 Tax forms of different Narconons from 2001-2006 Desiree Danner 2001 Narconon Arrowhead 990 Tax return highly compensated http://www.xenu-directory.net/documents/corporate/person.php?person_id=247 Desiree Romero 2003-2006 mulitple locations 99o Returns highly compensated http://www.xenu-directory.net/documents/corporate/person.php?person_id=19 and claims made about her in the New Mexico lawsuit: Luthy v Narconon Stone Hawk et al claiming fraud and deceptive trade practices of a similar nature. Point 12: http://www.cs.cmu.edu/~dst/Stop-Narconon/StoneHawk/Luthy/complaint.pdf Desiree Romero promotes herself by name and photograph on some of her referral sites http://www.drugrehabs.net/index.php/Contact-Us/ and is a Facebook friend to NNSC's Registered Agent Arthur Bruce Haddrill , http://www.facebook.com/people/Arthur-Bruce-Haddrill/1449810547 who is registered with the Michigan Bar Association as being in house counsel to Narconon Nevada, showing the address of the property owned by NNSC in Caliente, Lincoln County, NV. Arthur B. Haddrill - P30662 (active and in good standing) General Counsel Narconon PO Box 716 Caliente, NV 89008 Phone: (775) 726-3158 Fax: (775) 726-3159 e-Mail: [email protected] Michigan Licensed: 11/15/1979 http://www.michbar.org/memberdirectory/detail.cfm?ID=30631338%2D9643%2D18%2DDETAIL Desiree uses the fictitious name "ADDICTION SOLUTIONS" and "SOLUTIONS" to provide these referral services to people in search of substance abuse and alcohol addiction help. In 2007, NNSC paid out over $400,000 in referral fees. to people and companies like Desiree and bBy deposition and interrogatory of the DEFENDENTS, it is suspected that there will be evidence of remuneration made to Desiree Romero or her company (s) because she is, in fact, an agent for the Narconon programs run by NNSC and NNJH and was the referral source for giving me Micki Allen's number for the supposed St Jude like program she and Micki called "Joshua Hills". While denying Ms. Romero and Micki Allen had any authorization, neither NNSC nor NNJH have stated who in particular at either of the NNs was authorized and did sell to me the "Joshua Hills" program service over the phone during the time of the payment of the deposit transaction.After the credit crd information was provided, Ms. Allen instructed me to fax copies of the post dated checks to "Narconon Southern California" to a fax number belonging a staff member located in Newport Beach, Orange County, CA , The Newport Beach facility address was the registered business address for NNSC on record with the IRS (See 990 form 2007) and Secretary of State of California up until the fall of 2008, after registered agent Jon Stearman passed away and was replaced with Arthur Bruce Haddrill. http://groups.google.com/group/alt.religion.scientology/msg/233b2a16cbf71f41 Mr. Haddrill's qualifications to be a registered Agent in the state of California are questionable when this and other evidence from the MI Bar Association shows him to be a resident of Nevada and licensed by the Michigan Bar. http://www.michbar.org/memberdirectory/detail.cfm?ID=30631338%2D1616%2D78%2DDETAIL Micki Allen said she was in Temecula, CA but she called me using a Nevada phone number. Ms. Allen is shown on the internet as an intake counselor for Narconon Nevada aka Rainbow Canyon in Nevada, http://www.usdrugrehabcenters.com/drug-rehab-centers/nevada-drug-rehab-centers/rainbow-canyon- l13917/ Micki Allen's email address at that site is [email protected] and the ph # listed 866-6NO- DRUG can be found on the Narconon West US web site for Narconon Nevada, and the other Narconons listed on http://www.narcononcalifornia.com Essentially all the Narconons listed there are those listed in 990 tax forms for NNSC and as presumably managed by Narconon Southern California on behalf of Narconon WUS. There is no currently registered corporate entity or DBA filed in the state of NV or any state for that matter for "Narconon Nevada" aka "Narconon Rainbow Canyon". The last time "Narconon Nevada" was name reserved in that state was in 2004, which was revoked in 2005. That was last filed by Jon Stearman in CA. On the other hand, Narconon Southern California is currently doing business in the state of Nevada under a recently revoked NV nonprofit corporation registration : https://esos.state.nv.us/SOSServices/AnonymousAccess/CorpSearch/CorpDetails.aspx? lx8nvq=jfASfEXbyzsXRCrgowbDDw%253d%253d, yet is registered with Lincoln County NV Department of Labor as one of the top 10 employers in that county The below link to the letter complaint about Narconon in Nevada and NNSC, written by E Kemp of Washington State, shows that NNSC has been doing recent business in the state of Nevada and that Micki Allen was the intake counselor who sold him the services for which he has since received a refund. http://www.scribd.com/doc/17125312/Complaint-vs-Narconon-Nevada-Narconon-Southern-California- 2009 NNSC and NNJH are profitable and expanding businesses with over 8 million in assets at the end of the calender year 2007. Despite that, over the last 2 years, NNSC has had multiple complaints posted on various internet sites and multiple lawsuits filed against it in various CA counties for, at minimum, breach of contract.