Desmond v Narconon et al vs. NarcononFirst Amended Complaint

7/28/2019 Desmond v Narconon et al vs. NarcononFirst Amended Complaint

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I N THE STATE COURT OF D E K A L B COUNTYSTATE OF GEORGIA

PATRICK C. DESMOND A N D M A R YC. DESMOND, I N D I V I D U A L L Y , ANDM A R Y C. DESMOND, ASA D M I N I S T R A T R I X OF THE ESTATEOF PATRICK W. DESMOND,

Plaintiffs,v.NARCONON OF GEORGIA, INC.DELGADO DEVELOPMENT, INC.,LISA C A R O L I N A ROBBINS, M . D .THE ROBBINS GROUP, INC.,NARCONON I N T E R N A T I O N A L ,

Defendants.

P L A I N T I F F S ' F I R S T A M E N D E D C O M P L A I N TT O ADD A L L E G A T I O N S AND C L A I M S

Plaintiffs Patrick C. Desmond and Mary C. Desmond, individually, and Mary C.Desmond, as Administratrix of the Estate of Patrick W. Desmond, file this First AmendedComplaint. The Plaintiffs add counts of Civ i l RICO by Fraudulent Statements to aGovernment Agency, M a i l Fraud, and Theft by Deception.

Plaintiffs hereby incorporate by reference each allegation, count, claim, requestfor damages, and all supporting evidence set out in their Original Complaint, filed withthis Court on May 19, 2011.

P A R T I E S , J U R I S D I C T I O N , AND V E N U E1.

Patrick W. Desmond ("Patrick" or "Patrick Desmond"), deceased, was the naturalson of Patrick C. Desmond and Mary C. Desmond. Patrick W. Desmond was a residento f Brevard County, Florida at the time of his death. Patrick C. Desmond and Mary C.Desmond are residents of Brevard County, Florida.

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2.Patrick W. Desmond died intestate. The Circuit Court for the Eighteenth Judicial

Circuit in and for Brevard County, Florida issued Letters of Administration dulyappointing Mary C. Desmond as Administratrix of the Estate of Patrick W. Desmond onJuly 9, 2009.

3.Narconon of Georgia, Inc. ("NNG") is a business incorporated under the laws of

the State of Georgia. NNG is in the business of providing drug and alcohol rehabilitationservices to paying patients. NNG operates various portions of its program in Gwinnett,DeKalb and Fulton counties. Service may be perfected on NNG by delivering asummons and a copy of this Complaint to its registered agent: Mathew C. Hines, 150Bankhead Highway, Carrollton, Carroll County, Georgia 30117.

4.Narconon International ( "NN I " ) is a California corporation which is the parent /

licensor o f NNG . At all relevant times, NN I was doing business in the state of Georgiaby and through its subsidiary / licensee. Service may be perfected on NN I by deliveringa summons and a copy of this Complaint to its registered agent: Sherman D . Lenske,6400 Canoga Ave. Ste 315, Woodland, CA 91367.

5.Delgado Development, Inc. ("Delgado") is a dissolved corporation that was

incorporated under the laws of the State of Georgia at the time of itsdissolution.Delgado was involved in various business dealings, including leasing property in theState of Georgia. Delgado may be properly served pursuant to O.C.G.A. 14-4-161(b)by delivering a summons and a copy of this Complaint to its registered agent at the timeo f dissolution: Maria Delgado, 2810 Valley Brook Drive, Marietta, Cobb County,Georgia 30008.

6.Lisa Carolina Robbins, M .D . ("Dr. Robbins") is a physician licensed in the State

o f Georgia. She is a resident of DeKalb County, Georgia and may be properly served at

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her current place of residence: 350 Glen Cove Drive, Avondale Estates, DeKalb County,Georgia 30002.

7.The Robbins Group, Inc. ("Robbins Group") is a business incorporated under the

laws o f the State of Georgia. Robbins Group is a medical practice group. Robbins Groupmay be properly served by delivering a summons and a copy of this complaint to itsregistered agent: Dawn Warner, 1324 Rockbridge Road, Stone Mountain, GwinnettCounty, Georgia 30087.

8.Jurisdiction is proper because all Defendants are residents of Georgia or subject to

the exercise o f long-arm jurisdiction. Venue is proper pursuant to O.C.G.A. 9-10-93and pursuant to the Georgia RICO (Racketeer Influenced and Corrupt Organizations)Act , 1 6 -1 4 -1 , Ga. Code A n n . , because a number of the requisite acts outlined belowoccurred in Dekalb County, Georgia.

NARCONON P R O GR AM S9.

Narconon of Georgia ("NNG") operates an outpatient drug treatment facilitylocated in Gwinnett County, Georgia. Part of the treatment program, the SaunaDetoxification component was, at all relevant times, located in Dekalb County, Georgia.

10.NNG is a subsidiary, licensee and/or alter ego o f N N I which owns, licenses,

operates and/or otherwise directs drug rehabilitation facilities throughout the UnitedStates and around the w o r l d . N N I is a subsidiary o f the Association of Better Liv in g andEducation ( " A B L E " ) , an umbrella group that oversees the drug rehabilitation, education,and criminal justice activities of the Church of Scientology.

11.Both NNG and N N I (collectively Narconon) rely exclusively on the written

"technology" (writings) of L . Ron Hubbard, the founder o f the Church of Scientology, toaddress the drug and alcohol rehabilitation needs of students enrolled in Narcononprograms, even though Hubbard had no training or education in drug and alcoholrehabilitation.

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12.Subsidiary programs like NNG are forbidden from deviating from the precise

texts of the Hubbard technology in order to avoid improper and unsanctioned "verbaltech." In other words, L. Ron Hubbard forbade intelligent debate about the Scientologydoctrine and required all studying the doctrine to do so directly from his writings. Anydiscussion outside his writings is considered unsanctioned "verbal tech."

13.I n order to use the "technology," NNG must pay N N I a license fee and agree to

use the "technology" in a manner that is heavily regulated by N N I .14.

Part of the technology heavily regulated by N N I includes the course materials andpurification component used by NNG to "rehabilitate" students. Neither the materialsnor the purification component are designed to advance alcohol and drug rehabilitation.Instead, the materials are comprised of eight different levels that are virtually identical tothe course materials studied by Scientologists and "The Sauna Program" is an intensive"purification ri tual" virtually identical to a required component of Scientology training.

15.Another significant portion of the program is devoted to requiring students to

undergo various "training routines" or TR's that focus on conditioning students to eithergive or receive orders. The courses are "self taught" by the students and overseen bycounselors who have little or no training other than training offered by Narconon, or theChurch of Scientology, in administering the courses themselves.

16.Narconon students receive no counseling or education in drug and alcohol

rehabilitation per se and the therapeutic discussion of drugs and their effects amongstudents and staff is actually discouraged. Instead, Narconon's proponents believe thatstrict adherence to the "technology" w i l l address the rehabilitation needs of its students.N N I routinely audited NNG to insure that this "technology" was being zealouslyfollowed.

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17 .N ot only was the N N G staff lacking in training and education in drug and alcohol

rehabilitation, but the staff was almost exclusively composed of former students of theprogram. Students, trained only in the principles of Scientology, would routinelygraduate from the program and immediately become paid staff members.

18 .Through its routine audits, N N I enforced strict compliance w i t h the L . Ron

Hubbard "technology." The NNG program was therefore operated under strict rulesrelated to discipline, structure, hierarchy, and training of the Church of Scientology andseveral employees o f N N G were disciplined by the Church for failing to properlyperform their duties at N N G pursuant to the Hubbard "technology."

19 .N N I and NNG fraudulently misrepresented the Narconon Program as one where

students suffering from alcohol and drug addiction would be provided w i t h substantiveeducation in drug and alcohol abuse. Instead o f providing drug rehabilitation, N N I andN N G have and continue to conceal the Narconon Program's true relationship w i t h theChurch of Scientology by teaching a "technology" virtually identical to fundamentaltenets and practice o f the Church of Scientology.

L I C E N S E R E Q U I R E M E N T S20.

A l l drug and alcohol rehab centers in Georgia are required to be licensed by thestate of Georgia through the Department of Human Resources, Office of RegulatoryServices, Health Care Section ("DHR"). There are various levels of licenses available,each requiring a greater level o f resources and oversight.

2 1 .Licensed programs are essentially divided between those that offer "outpatient"

services devoted to counseling and education and those that offer more intensiveresidential services for patients w i t h severe enough dependency problems to require aninpatient or residential setting.

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22.I t is illegal and criminal under Georgia law to operate an unlicensed facility or to

operate a facility at a level higher than authorized by a current license.23.

Since 2002, NNG has been authorized by DHR only as an outpatient drug andalcohol treatment facili ty. It has never been authorized to operate any form of residentialfacili ty.

24.NNG was at all relevant times licensed to operate an outpatient facili ty, w i t h a

sub-unit or branch ambulatory detoxification services program at a separate location, andwas by law specifically l imited to providing services in non-residential settings.

25.Specifically, NNG's license for an outpatient drug treatment program provided

authorization for a "non-residential program staffed by professional and paraprofessionalpersons that provides drug treatment or therapeutic services, primarily counseling andother supportive services for drug dependent persons." Ga. Comp. R. & Regs. 290-4-2.03(q). Outpatient programs are those operated, in part, outside normal business hoursso that clients who work or attend school may seek treatment at the facili ty. Ga. Comp. R.& Regs. 290-4-2-.23.

26.NNG's license for an ambulatory detoxification facility provided authorization to

operate a "program for the medical management and other support for processesassociated wi th the physical process of withdrawal from drugs in a non-residentialsetting." Ga. Comp. R. & Regs. 290-4-2-.03(a).

NNG's HOUS I NG27.

NN G had previously sought to obtain a residential license in the early 2000's for adifferent location but the license was denied.

28.Since 2002, Mary Rieser ("Rieser") has been the executive director of NNG .

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NNG for the specific purpose o f housing and monitoring NNG's patients. Delgado alsotransported the patients between NNG and housing at the direction of and as an expressagent o f NNG .

36.Delgado, acting at the direction of and as an express agent o f NNG , a licensed

outpatient program, was required to obtain a license f rom DHR prior to engaging in anysupportive services in the fo rm of housing, monitoring and/or transportation. Ga. Comp.R. & Regs. 290-4-2-.05, 290-4-2.21.

37.A t all times relevant, Defendant Delgado was not licensed to operate a supportive

housing facility under the direct control of a licensed outpatient facil i ty, and wastherefore il legally operating a supportive housing program for drug and alcoholrehabilitation.

38.Likewise, NNG , by and through Delgado as its express agent, was il legally

operating a residential rehabilitation program without the proper licensing from DHR.39.

From the outset, the Delgado housing was fraught wi th problems. Students atDelgado routinely left the premises to purchase alcohol and drugs, oversight o f thestudents was lax or non-existent, and the monitors hired by Delgado were uniformlyrecently recovered addicts wi t h no training or experience in supervising students wi thdrug problems.

40.In the months leading up to the death of Patrick Desmond, conditions at the

Delgado housing unit continued to deteriorate. As a result, NNG conducted an internalinvestigation, called a Board of Inquiry, o f the housing conditions, and essentiallyassumed control over all operations.

4 1 .NNG determined that housing was fraught wi th "service issues." There had been

physical assaults requiring police intervention, students were using drugs and alcohol in

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adjudication of criminal charges. Participants may participate in a state funded programor any other program specifically approved by the Drug Court.

49.The Drug Court required that Patrick be enrolled for a period of six months in an

in-patient, residential drug and alcohol rehabilitation facility in which he would beclosely supervised and monitored at all times.

50.A t the advice of Patrick's attorney, Patrick's parents searched for an appropriate

drug rehabilitation facility via the Internet. The Desmond's were informed that i f theycould locate a private residential rehabilitation program, and the program was approvedby the Drug Court, Patrick could serve his Pretrial Intervention sentence at a privatefacility.

51 .During their search for an appropriate drug and alcohol rehabilitation facility, the

Desmond's located NNG's website and based on the misleading information presentedon the site, the Desmond's believed that NNG provided residential in-patient drug andalcohol counseling that would meet the Drug Court's requirements.

52.NNG , by and through its agents, employees, or representatives, made fraudulent

representations to Patrick's parents, the manager of the Brevard County Drug Court, andPatrick's probation officer that NNG was a residential facility and met the Drug Court'srequirements of providing a therapeutic environment in which Patrick would be closelysupervised at all times.

53.Specifically, the Desmond's, Lisa Mooty (the Brevard Drug Court administrator)

and Patrick's probation officer were all informed by Mary Rieser, and other agents ofNNG , that the facility was: 1) properly licensed, 2) residential, 3) six months in duration,4) provided drug and alcohol rehabilitation counseling, and 5) the counseling wasprovided by adequately trained professionals. A l l of these statements were untrue.

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54 .The decision to send Patrick to the facili ty, as wel l as the Drug Court's approval

o f the program, was based on the express and false representations made by agents ofNNG . Both the Desmonds and the Brevard County Drug Court personnel have testifiedthat they would not have approved Patrick's participation in the Narconon program hadthey known these statements were untrue.

55.NNG's misrepresentations also extend to the active concealment of the Narconon

program's true relationship wi th the Church of Scientology and the teaching of a"technology" wi th an uncanny parallel to the actual practice of the Scientology religion.N N G never informed the Desmonds or the Drug Court representatives that Patrick's"counseling" would consist almost entirely of practices of Scientology, and that he wouldnot be receiving any substantive drug or alcohol counseling.

56.Major Desmond paid for services at the NN G facility based on and in reliance on

the fraudulent statements made by NNG's agents outlined above.P A T R I C K D E S M O N D 'S N A R C O N O N E X P E R I E N C E

A ND R E S U L T I N G D E A T H

57.Patrick Desmond first arrived at N N G on September 24, 2007 and was assessed

by Dr. Lisa Robbins on the same day. He was enrolled as a paying patient in theNarconon program and was to receive residential drug and alcohol rehabilitation for thecourt mandated period of six months.

58.Patrick was housed at the illegal housing facility located at the One Sovereign

Place apartment complex. Patrick's "treatment" lasted only four and one-half months ashe was permitted to "graduate" from the Narconon program on or about February 12,2008, wel l short of his court mandated six month period. He then stayed on as a staffmember for the housing and sauna programs for the remainder of the six month treatmentperiod.

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program, and cited NNG for failing to identify what treatment and services were providedin the form of vitamin and sauna therapy.

7 1 .While NNG's main goal was to ensure strict compliance with the "technology" of

L . Ron Hubbard, NNG purposefully and fraudulently misrepresented it was creatingindividualized treatment plans, was carefully and attentively updating patient files w i t hprogress notes, and was creating discharge and aftercare plans for the patient as requiredby the DHR Rules for outpatient and ambulatory treatment programs. Ga. Comp. R. &Regs. 290-4-2-.09(4). 290-4-.14(e), 290-4-2-. 14(c), 290-4-2-. 17(a), 290-4-2.17(b).

72.Despite the certifications on each license application of DHR rule compliance,

DHR has routinely cited NNG , most recently in 2007, for failing to create individualizedtreatment plans, plan updates and progress notes, and discharge and aftercare plans for itspatients.

73.Notably, an adequate aftercare plan must include a final assessment of the

student's status at the time of discharge, a description of what services and support thestudent wi l l need after discharge, and a description of potential barriers to overcome andmaintain a drug free life style. Ga. Comp. R. & Regs. 290-4-2-.17

74.NNG did not give Patrick Desmond an aftercare plan upon his init ial "graduation"

and with in a short period after his return to Florida, Patrick relapsed.75.

A t all relevant times, NNG has purposefully and fraudulently misrepresented thatNNG was in compliance wi t h the DHR Rules requiring all drug rehabilitation facilities tomaintain a drug free workplace by implementing policy and procedures for routinely andrandomly testing employees and students for alcohol and drug use. 290-4-2-.09(l 1). Ga.Comp. R. & Regs.

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76.During an inspection by DHR in 2003, a review o f NNG's personnel files

revealed the facility failed to maintain evidence of pre-employment or random urinescreens for the presence of drug use as required by 290-4-2-.09. Ga. Comp. R. & Regs.

77.On January 20, 2004, NNG provided a "plan of corrections" to DHR falsely

representing that NNG would theretofore implement a drug free workplace policy andactually enforce it.

78.Despite NNG's representations to DHR in 2004, a review of all employee

personnel files reveal NNG only conducted pre-employment drug screens.79.A t all relevant times, NNG routinely employed students immediately upon

"graduation" of the Narconon program. There is no evidence that students subsequentlyemployed by NNG were randomly tested for alcohol or drugs to ensure a drug freeworkplace as required by DHR.

80.Instead, NNG actually permitted employees monitoring other students in the

treatment program to consume alcohol and routinely found other students either under theinfluence of alcohol or drugs, or in possession of the same.

81 .Despite certification of compliance wi th all DHR Rules, NNG was inspected by

DHR on or about June 17, 2009 and cited for non-compliance wi th drug testing onemployees, as we l l as random alcohol and drug screens on the students.

82.A t all relevant times, NNG certified compliance with DHR rules, yet NNG

implemented behavioral management techniques that denied students essential programservices or placed students in a "time out," other than a brief separation f rom the groupfor less than twenty minutes, in clear violation of the DHR Rules. Ga. Comp. R. & Regs.290-4-2-.26(l)(d), 290-4-2-.09(2)(e), 290-4-2-.03(z).

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83.On regular occasion, NNG suspended students as a behavioral management

technique and ordered them to stay o f f premises, usually in a hotel, for periods lasting aslong as one week. During this time, students were prohibited from receiving anytreatment at Narconon and were given free rein to access alcohol and drugs.

84.Not only did NNG fraudulently misrepresent that the daily operations o f the

Narconon program were compliance w i t h the DHR Rules, but NNG's actual licenseswere obtained by the false statements o f NNG's Executive Director, Mary Rieser.

85.At a l l relevant times, Rieser acted as an express agent o f NNG and w i t h i n the

scope of her employment at N N G .86.

N N G , by and through its agent Mary Rieser, intentionally falsified information onlicense applications submitted to DHR in 2004, 2005, 2006, and 2007.

87.On NNG's applications for an outpatient drug rehabilitation facil i ty in 2004, 2005

and 2006, Rieser falsely identified an individual named Joan Daniels as a "ClinicalDirector" of the facil i ty. The Clinical Director is responsible for all treatment servicesprovided by the program and should presumably present on the premises for a sufficientamount o f time to actually oversee the operations. Ga. Comp. R. & Regs. 290-4-2-.09(4).Rieser signed the application and certified that the facil i ty was in compliance w i t h DHRRules.

88.Despite Rieser's certification that Joan Daniels was Narconon's Clinical Director

between 2004 and 2006, Joan Daniels's employment application is actually dated March23, 2007. In further support o f NNG's false statements to obtain a license, Rieser draftedand signed a letter on or about March 23, 2007 proclaiming Joan Daniels to be nothingmore than a consultant between 2003 and 2007.

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89.On NNG's application for an outpatient and ambulatory drug rehabilitation

facility on January 24, 2007, Rieser fraudulently claimed Joan Daniels, as wel l as RobinMuse, as full time Clinical Directors, and in furtherance o f the fraudulent scheme,falsified documents in support of the same.

90.On or about March 23, 2007, Joan Daniels purportedly signed a document entitled

"Job Description Clinical Director" (hereafter Clinical Director Agreement), whichprovided the Clinical director shall provide training for staff on treatment planning,professional ethics, and work with the Narconon staff to stay in compliance with DHRRules.

9 1 .Despite the obligations of Joan Daniels to train N N G staff as outlined in the

Clinical Director Agreement, Joan Daniels was conspicuously absent from all 13 trainingseminars by N N G between March 23, 2007 and October 12,2007.

92 .N N G , by and through its agent Rieser, fraudulently represented to DHR that

Robin Muse was a full time Clinical Director on NNG's 2007 application, when in factRobin Muse was only employed by NNG as a consultant.

93.On or about January 15, 2007, Robin Muse purportedly signed a document

entitled "Health-Care Service Provider Agreement," in which Robin Muse would beemployed as a consultant for five hours a week.

94.Over a month after N N G submitted its 2007 application, on February 23, 2007,

Robin Muse purportedly signed another agreement entitled "Clinical DirectorAgreement," whereby Muse would be employed as a Clinical Director, but was onlyrequired to work a total of five hours a week.

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95.On NNG's 2007 license application, Rieser fraudulently represented NNG had

obtained a Medical Director, Dr. Lisa Robbins, to perform the duties as required by 290-4-2-. 19(b) for all ambulatory facilities, which includes, but is not limited to, assumptiono f responsibility for all medical services and approval of all medical policies andprocedures.

96.Over a month after NNG submitted its 2007 application, NNG , by and through its

agent Rieser, executed a 'Medical Director Agreement' between Dr. Robbins and NNGon or about February 16, 2007.

97.A t all relevant times, Dr. Robbins failed to fulfi l l her duties as a Medical Director

as contemplated by the DHR Rules and with in the scope of the Medical DirectorAgreement.

98.I n fact, the only service provided by Dr. Robbins was that of completing a

physical assessment o f the students at the time of their arrival.99.

Dr. Robbins neither developed an understanding for the Narconon Life SkillsProgram, nor reviewed or approved any of the L . Ron Hubbard "technology" coursematerials, or policies and procedures for the sauna exercise program as required by theDHR Rules. 290-4-2.-19(b)(l) Ga. Comp. R. & Regs.

100.Although Dr. Robbins was required to oversee "al l medical staff by the DHR

Rules, Dr. Robbins was unable to recall the names of medical staff members under hersupervision, never updated nor approved onsite emergency medical procedures, and infact, never visited the NNG facility or the sauna.

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107.Between January 8, 2008 and May 27, 2008, over ten Knowledge Reports

identifying alcohol and drug use by NNG students and staff at housing were reported toNNG .

108.A t all relevant times, Defendants Maria and Don Delgado of Delgado

Development were either employees o f NNG or under the direct control and supervisiono f NNG , and for all intents and purposes, either participated directly in the fraudulent actso f NNG and/or are associated in fact wi th NNG .

109.Maria Delgado served as Senior Director for Administration on behalf o f NNG ,

and in furtherance of her job duties, certified NNG employee attendance to over 10seminars between June 28, 2006 and September 2006.

110.Maria Delgado also participated directly in NNG's execution of Joan Daniel's

Clinical Director Agreement, signing the same as a witness, in NNG's fraudulent effort toobtain licensing between 2005 and 2007.

111.Maria and Don Delgado, as express agents under the direct control and

supervision of NNG , also attended over fifteen seminars provided by NNG betweenFebruary 2007 and October 2007, which included information about workers'compensation and employee rights.

112.Due to NNG's direct control and supervision of Delgado, One Sovereign Place,

and the employees o f the same, NNG fraudulently incorporated an unlicensed residentialfacility without DHR approval.

113.As a result, all applications to DHR for outpatient and/or ambulatory

detoxification licensing in 2003, 2004, 2005, 2006 and 2007 were inherently andmaterially false.

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114.A t all relevant times, Dr. Robbins, as the Medical Director responsible for

oversight of a ll medical services provided, knew or should have known that NNG wasexecuting fraudulent documents, was submitting the fraudulent documents to DHR, andwas an i l legally operating a residential facil i ty without the required licensing and medicaloversight.

115.A t all relevant times, Dr. Robbins financially profited from NNG's fraudulent

scheme to i l legally operate a residential facil i ty and is associated in fact wi t h NNG , MaryRieser, Delgado, and Maria and Don Delgado.

116.A t all relevant times, NN I heavily regulated the Narconon Life Skills Program

and performed routine audits to ensure compliance wi th NNG's license to implement L.Ron Hubbard's "technology." NN I was routinely copied on NNG's internal memorandaconcerning the operations of NNG , including NNG's emergency Urgent Directivesconcerning the conditions of housing at Delgado. As a result, NN I either knew or shouldhave known that NNG was operating in violation of State regulations and had i l legallyincorporated a surrogate residential facil ity. NN I , by and through its licensing feeagreement, also profited from NNG's fraudulent scheme and is therefore associated infact wi th NNG , Mary Rieser, Delgado, Maria and Don Delgado, and Dr. Robbins.

T H E F T B Y D E C E P T I O N ANDM A I L F R A U D117.

A t a ll relevant times, NNG , by and through its agents, employed a scheme orartifice to defraud by representing the Narconon program as a facility that could andwould provide any service, regardless of truth or accuracy, i f doing so would secure thestudents enrollment and payment for the program.

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118.Particularly, NNG , by and through its agents, fraudulently represented to the

Desmonds and the Brevard County Drug Court that NNG was a residential treatmentprogram and would provide treatment to Patrick for a period of six months.

119.A t all times relevant hereto, NNG's letterhead always included an "outpatient"

designation when correspondence between NNG and DHR took place. However, MaryRieser and employees acting at her direction intentionally removed the word "outpatient"from NNG's letterhead when written communication between NNG and a court agencyoccurred.

120.On September 10, 2007, NNG , by and through its agent Mary Rieser, personally

represented that NNG was a residential program, lasting for at least for six months.Rieser faxed the Drug Court director information providing further assurances thatPatrick would be treated in a residential facili ty. Rieser intentionally removed the"outpatient" designation from the letterhead.

121.NNG , in furtherance of its scheme to defraud and secure Patrick's enrollment,

intentionally removed the "outpatient" designation from letterhead on correspondencedirected to Patrick's criminal defense attorney, soliciting support for Patrick's enrollmentin NNG .

122.I n reliance on the false and material representations of NNG , Patrick arrived at

NNG on September 24, 2007. Upon his arrival, NNG , by and through its agent Rieser,accepted payment in the amount of $13,000.00 (thirteen thousand dollars) from theDesmonds for six months of residential alcohol treatment and rehabilitation.

123.Rieser, in furtherance of the fraudulent scheme, directed the legal administrator of

NNG to remove the word "outpatient" wi th i n any letterhead sent via mai l , facsimile, orother electronic communication to the Florida Drug Court pertaining to the status of

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Patrick's recovery. On one occasion in particular, NNG removed the "outpatient"designation in correspondence directly to Patrick's probation officer, Mark O'Donnell, onJune 4, 2008.

124.After NNG , by and through agent Rieser, represented it would provide 24 hour

supervision over Patrick during his treatment and recovery, NNG delegated its exclusiveresponsibility to supervise Patrick to Delgado and sent him to housing at One SovereignPlace.

125.NNG was aware that the housing at One Sovereign Place was infiltrated wi t h

alcohol and illegal narcotics, facilitated in large part, i f not entirely, by employees ofDelgado and/or NNG acting as supervisors or "monitors" over Narconon students.

126.NN I was equally aware of the deplorable conditions at One Sovereign Place and

was even copied on at least three o f NNG's emergency Urgent Directives concerning thehousing conditions in March of 2008, just months before Patrick's death

127.Although NNG , by and through its agents, represented that Patrick would receive

alcohol and drug education and treatment, NNG provided Patrick wi th virtually nosubstantive information on the disease and effects of alcoholism. Instead, NNG hadPatrick read and study the technology of L . Ron Hubbard virtually identical to the coursematerials studied by Scientologists.

128.Although NNG , by and through its agents, represented that Patrick would receive

treatment in a six month residential drug rehabilitation program, NNG "graduated"Patrick six weeks early. NNG then paid Patrick to supervise other Narconon students atDelgado's housing.

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135.Although NNG , by and through its agents, represented that Bradley would be

under 24 hour supervision during his treatment and recovery, NNG delegated itsexclusive responsibility to supervise Bradley to Delgado.

136.Like Patrick, Bradley was also sent to housing at One Sovereign Place, which was

infiltrated with drugs and alcohol.137.

After representing that Bradley would receive treatment in a one year residentialdrug rehabilitation program, NNG accepted payment from Bradley's family, andprovided Bradley wi t h virtually no substantive information on substances. Instead, NNGhad Bradley read and study the technology of L. Ron Hubbard virtually identical to thecourse materials studied by Scientologists.

138.Although NNG , by and through its agents, represented that Bradley would receive

treatment in a one year residential drug rehabilitation program, NNG "graduated"Bradley five months early. NNG then paid Bradley to supervise other Narcononstudents.

139.During Bradley's employment by Narconon, Bradley was not supervised,

randomly tested for alcohol or drugs, or required to receive any treatment for substanceabuse.

140.Bradley, as an "employee" of Narconon, was actually permitted to drink heavily

wi t h Patrick Desmond the night Patrick died.141.

Delgado, including its agents Maria and Don Delgado, profited from NNG'sfraudulent activities amounting to theft by deception and acts of mail fraud by collectingrent directly from the students and/or receiving a portion of the same when rent was paid

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146.NNG's breach of its duties to Patrick W. Desmond included, but were not l imi t ed

to the fol lowing:a. failing to comply with its license from the State of Georgia permitting it to

operate an outpatient drug and alcohol rehabilitation facility;b. providing an unlicensed housing program to Patrick Desmond;c. allowing and facilitating Patrick Desmond's on-going use of alcohol and

drugs while in treatment;d. failing to provide reasonable and adequate security and supervision to prevent

its patients, including Patrick Desmond, from leaving its housing program;and

e. failing to exercise ordinary care in the selection, hiring and retention of itsemployees.

147.NNG ' actions and omissions proximately caused Patrick Desmond's death, pain

and suffering, and other damages.COUNT I I :

N E G L I G E N C E P E R S E O F NNG

148.NNG was licensed to operate an outpatient facility wi th a sub-unit or branch

ambulatory detoxification services program at a separate location, and was by lawspecifically l imi ted to providing services in non-residential settings.

149.NNG's operation o f unlicensed housing programs for its drug and alcohol

rehabilitation patients constituted negligence per se in the fol lowing particulars:a. violation of its licensure and O.C.G.A. 26-5-3; Ga. Comp. R. & Regs.

290-4-2-.03(s), ( t) , (u), 290-4-2.11 (8), 290-4-2-.16, 290-4-2-.19, 290-4-2-.20,290-4-2-.21;

b. violation of the limitations set upon it by its license pursuant to Ga. Comp. R.& Regs 290-4-2-.03 (a); and

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c. violation of its duty to disclose its housing programs, including the housingprogram at One Sovereign Place, to licensing and regulatory authoritiespursuant to Ga. Comp. R. & Regs 290-4-2-.05 and 290-4-2-.07 (2).

150.NNG's actions and omissions proximately caused Patrick Desmond's death, pain

and suffering, and other damages.C O U N T I I I :

F R A U D O F N N G151.

N NG , by and through its agents, employees or representatives, knowingly andwi l l f u l l y made false representations of material facts to Plaintiffs Patrick C. Desmondand Mary C. Desmond and to the Brevard County Drug Court, indicating that it waslicensed and/or otherwise authorized to operate a residential drug and alcoholrehabilitation facil i ty and would be capable of supporting and meeting the needs ofPatrick W . Desmond by providing necessary 24-hour close supervision and monitoring.

152.Additionally, NNG , by and through its agents, employees or representatives,

knowingly and wi l l f u l l y made the fo l low ing false representations of material facts toPatrick C. Desmond, Mary C. Desmond and the Brevard County Drug Court:

a. that NNG was a residential facil i ty that met the requirements of the DrugCourt; and,

b. that Patrick would be continuously and closely supported, monitored andsupervised at all times while participating in the rehabilitation program.

153.N NG , by and through its agents, employees or representatives, knew at the time

that al l such representations were false and baseless.154.

N N G knew or should have known that Patrick C. Desmond, Mary C. Desmond,and the Drug Court would rely on its false representations in choosing to enroll and allowthe participation of Patrick W . Desmond in the rehabilitation program.

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155.I n fact, Patrick C. Desmond, Mary C. Desmond and the Drug Court were unaware

o f the falsities o f NNG's statements and justifiably relied on NNG's false representationsi n choosing to enroll Patrick Desmond and to approve his enrollment and participation inthe rehabilitation program.

156.NNG's fraudulent representations proximately caused Patrick Desmond's death,

pain and suffering, and other damages.CO U N T I V :

N E G L I G E N C E OF D E L G A D O157.

Delgado had a duty to keep the premises at One Sovereign Place safe for all itsresidents, including Patrick Desmond and other illegally housed drug and alcoholrehabilitation patients.

158.Delgado knew that NNG was using the apartment complex to i l legally house drug

and alcohol rehabilitation patients.159.

Delgado breached its duty by fail ing to provide reasonable and adequate securityfor and supervision o f the drug and alcohol rehabilitation patients housed at OneSovereign Place.

160.Delgado's failure to provide a safe environment, security and supervision and

facilitation o f NNG's illegal housing program proximately caused Patrick Desmond'sdeath, pain and suffering, and other damages.

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trick, scheme, or other device the following material facts:a. Knowingly and wi l l f u l l y falsifying and/or concealing from DHR the true nature

and scope of Dr. Robbins' duties as a medical director as contemplated andrequired by DHR in order for NN G to obtain its 2007 ambulatory detoxificationlicense.

b. Knowingly and wi l l f u l l y falsifying Joan Daniels as a clinical director on alllicense applications between 2004 and 2007, who is responsible for alltreatment services, and/or concealing from DHR the true nature and scope ofJoan Daniels' employment, which was contrary to that required by DHR forclinical directors.

c. Knowingly and wi l l f u l l y falsifying Robin Muse as a clinical director on NNG2007 license application, who is responsible for all treatment services, and/orconcealing from DHR the true nature and scope of Robin Muse's employment,which was contrary to that required by DHR for clinical directors.

d. Knowingly and wi l l f u l l y concealing from DHR that NNG was illegallyoperating a residential drug and rehabilitation facility without the properlicensing from the State on all license applications between 2003 and 2007.

e. Knowingly and wi l l f u l l y falsifying and/or concealing from DHR thedetoxification component of NNG treatment regimen in its 2003 licenseapplication solely for an outpatient facility.

f. Knowingly and wi l l f u l l y falsifying and/or concealing from DHR NNG'scompliance with creating adequate individualized treatment plans, routinelyupdating patient files, and creating discharge and aftercare plans on all licenseapplications between 2003 and 2007.

g. Knowingly and wi l l f u l l y falsifying and/or concealing from DHR NNGcompliance with ensuring a drug-free workplace on all license applications

h . Knowingly and wi l l f u l l y concealing from DHR NNG's compliance with theDHR Rules prohibiting behavioral management techniques denying studentsofessential program services on all license applications between 2003 and 2007.

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COUNT IXC I V I L R I C O B Y MA I L F R A U D

170.N N I , NNG, Delgado, and Dr. Robbins, by and through their agents, unlawfully

sought employment by or associated wi th an enterprise to either conduct or participate in,either directly or indirectly, the enterprise through a pattern of racketeering activity.

171 .N N I , NNG, Delgado, and Dr. Robbins, by and through their agents, unlawfully

acquired, maintained an interest in, and/or had control over, an enterprise or property ofany nature, including money, through a pattern of racketeering activity.

172.N N I , N N G , Delgado, and Dr. Robbins, by and through their agents, are associated

in fact, and therefore engaged in at least two acts of racketeering activity by committingnumerous counts of mail fraud in violation of 18 U.S.C.A. 1343, by having transmittedwritten communication by wire or mail that was devised in scheme to defraud and/orconstituted an attempt to obtain money or property by a means of false or fraudulentpretenses, representations, or promises.

173.Specifically, NNG enrolled patients sentenced to residential rehabilitation in l ieu ofincarceration by intentionally removing or omitting the word "outpatient" in NNG's

letterhead transmitted by facsimile and/or email to the fol lowing:a. Officers of Florida Drug Court on September 10, 2007, January 4, 2008, and June

4 , 2008, as wel l as Patrick Desmond's criminal defense attorney on September 10,2007.

b . Officers of the Tennessee criminal court pertaining to Bradley Taylor on January 7,2008.

COUNT XC I V I L R I C O BY T H E F T B Y D E C E P T I O N S

174.N N I , NNG, Delgado, and Dr. Robbins, by and through their agents, unlawfully

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sought employment by or associated with an enterprise to either conduct or participate in,either directly or indirectly, the enterprise through a pattern o f racketeering activity.

175.NN I , NNG, Delgado, and Dr. Robbins, by and through their agents, unlawfully

acquired, maintained an interest in, and/or had control over, an enterprise or property ofany nature, including money, through a pattern o f racketeering activity.

176.NN I , NNG , Delgado, and Dr. Robbins, by and through their agents, are associated

in fact, and therefore engaged in at least two acts of racketeering activity by committingtheft by deception, in violation of O.C.G.A. 16-8-3, by obtaining money by deceitfulmeans or artful practice wi t h the intention of depriving the owner of the property,specifically by creating or confirming an impression and/or failing to correct the falseimpression and/or promising to perform services in which NNG did not provide to theFlorida Drug Court, Plaintiffs Patrick and Mary Desmond, the Tennessee Court, andBradley Taylor's father in the fo l lowing particulars:

a. That NNG was licensed to provide residential rehabilitation treatment.b. That NNG would provide adequate supervision of its patients twenty four hours a

day.c. That NNG would provide substantive education as the physiological component of

alcohol and substance abuse on the body.d. That NNG was otherwise in compliance wi th applicable DHR Rules governing

drug and rehabilitation treatment facilities.P U N I T I V E D A M A G E S A G A I N S T N A R C O N O N ANDNNI

177.NNG andN N I acted intentionally and in concert in i llegally operating an

unlicensed housing program for its drug and alcohol rehabilitation patients, makingintentionally false and fraudulent representations to Patrick C. Desmond, Mary C.Desmond, and the Brevard County Drug Court, and perpetrating a fraudulent cover-up ofthe circumstances and events leading up and resulting in the death o f Patrick W. Desmond.Additionally, NNG's operation of, and NNI's knowledge of, its drug and alcohol

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rehabilitation program showed w i l l fu l misconduct, wantonness, oppression, or that entirewant of care which raises the presumption of conscious indifference to consequences.Accordingly, Plaintiffs are entitled to an award o f punitive damages pursuant to O.C.G.A . 51-12-5.1.

WHEREFORE, Plaintiffs pray for the fo l l o wi ng relief:1. That summons and process be issued requiring these Defendants to appear

as provided by law to answer the allegations of thisComplaint;2. That Plaintiffs have a T R I A L B Y JURY of all issues so triable;3. That Plaintiffs recover f rom Defendants the fo l l o wi ng: special damages

such as: medical and hospital expenses, funeral expenses, past and futurelost earnings, general damages for Patrick W. Desmond's bodily i n j u r y ,fright, terror, pain and suffering and other necessary expenses incurred asa result of the incident at issue; and additional damages constituting theful l value of the life of Patrick W. Desmond. The amount of all suchcompensatory damages shall be proven at t r ia l and determined by theenlightened conscience of a j u r y ;

4. That Plaintiffs recover punitive damages against the Defendants inamounts to be determined by the enlightened conscience of a j u r y ;

5. That Plaintiffs have and recover all damages to which they are entitledunder Georgia law; and

6. That Plaintiffs have all such other and further re l ie f as this Court deemsjust and appropriate.


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Georgia Bar N o . 216815JE D D . M A N T O NGeorgia Bar N o . 868587

1201 Peachtree Street, NE400 Colony Square, Suite 900Atlanta, GA 30361Telephone: 404-961-7650Facsimile: 404-961-7651

REBECCA C. F R A N K L I NGeorgia Bar N o . 141350

F R A N K L I N L A W , L L C1201 Peachtree Street, NE400 Colony Square, Suite 900Atlanta, GA 30361Telephone: (404) 961-5333Facsimile: (404) 969-4503

Attorneys for Plaintiffs

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S T A T E O F C A L I F O R N I AC O U N T Y O F S A N F R A N C I S C O

AFFIDAVIT OF DAVID E . SMITH, M.D. , FAS AM , FAACTPERSONALLY APPEARED before the undersigned officer duly authorized to

administer oaths in this State, DAVID E. SMITH, M.D., who, after first being dulysworn, states as fo l lows:

1.M y n a m e is DAVID E. SMITH, M.D. I am a medical doctor, l icensed to

practice medicine in the State of California. I practice in the specialty of addictionmed icine , in whic h I am board-cert if ied . A t rue and correct copy of my curr iculum vi taeis at tached hereto as Exhibit A.

2 .I make th is aff idavit ba sed upo n my own p ersonal knowledge and belief. I am

over the age of eighteen years, and I suffer from no disabil i ty which would render meincompetent to make this affidavit .

3 .Based upo n my educat ion, tra in ing and experience, I am familiar with the degree

of care and skil l ordinari ly exercised by physicians generally, and those specializing inthe specialty of addiction medicine, to include those serving in the capacity of medicald i rectors or clinical directors of l icensed drug and alcohol rehabil i tat ion facil i t ies ("thestandard of care") , with regard to both the evaluation and treatment of patients who areadmit ted to drug and alcohol rehabil i tat ion facil i t ies for treatment for addictions and thedischarge of the patient care responsibil i t ies customarily associated with serving as

| | E X H IB I T


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medica l directors or cl inical directors of such facil it ies. Specifically, I am fa miliar withthe standard of care ordinari ly exercised by medical doctors generally in the care and

treatment of a patient such as Patrick W. Desmond, as his circumstances and condit ionsare discussed herein.

4 .In connection with giving this affidavit , I have reviewed the following materials:

Brevard County Drug Court Records; Pat r ick W. De sm ond 's Death Cert i f ica te ; DeK albCounty F ixe & Rescue Repo rt ; DeK alb Cou nty Med ical Exam iner ' s Report ; GeorgiaDepartment of Human Resources materia ls ; DHR Appl ica t ions for License; NarcononBrochure; Narconon Discharge Summary; Narconon Family & Friends Orienta t ionmateria ls ; Nar cono n Med ical Records; Na rcon on Outpat ient Protocol; Na rcono nProgram Descrip t ion; Northside Hospi ta l Rec ords; and, Peachford Hospi ta l Records.

5 .Ad ditiona lly, I hav e been provided with a copy of the Complaint , wh ich I '

understand is to be fi led in this case, and have been asked to assume the following facts,which are consistent with my review of the information identified in Paragraph 3 , above:

Th e Brevard Cou nty Drug Court requi red that Pat r ick W. Desmond be enrol ledin an in-patient , residential facil i ty where he would be closely supervised at al lt imes.

Na rco non made representa tions to Pat r ic k 's parents and the mana ger of theBrevard County Drug Court that Narconon was a residential facil i ty and met theDrug Cour t ' s requ irem en t s .

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How ever, Narc onon was never l icensed to opera te any category of res ident ia lprogram.

Instead, Na rco non was l icensed to oper ate an outpatient facili ty with a su b-u nitor branch ambulatory detoxification services program at a separate location,wh ich were by law specifically l imited to the provision of services in no nresidential set t ings. .

Des pite bein g l icensed to prov ide services only in non-residential set t ing s,Narcon on mainta ined operated off-s ite hou sing programs in severa l apa rtmentcom plexes, including a prog ram for male patients at One Sovereign Pl ace ,located a t 4883 R oswel l Road, A t lanta /Sandy S prings, Georgia .

Specifically, an agent for and on behalf of Na rco non leased apartments at OneSovereign Place for the specif ic purpose of hous ing Narco non 's pat ients ; a ndlikewise provided monitoring services to the patients while they were physicallypresent a t the O ne Sovereign Place .

Dr . Rob bins was the med ical director of Na rco no n and had respon sibil i t ies forassessing prospective cl ients for medical , behavioral and/or emotional problems,determining the needed level of structured treatment and therapeutical act ivi t ies,establishing procedures for a system of 24-hour, on call medical coverage toinclude del ivery of emergency medical serv ices , provid ing medical m anagem ent

services to include approving protocols and procedures, being actively involvedin a quali ty assurance program to evaluate the appropriateness of servicesprovided to pat ients , and o therwise overseeing N arcono n 's opera t ions.

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Patrick De smo nd first arrived at Na rcon on on Septem ber 2 4 , 2007 and wasassesse d by Dr. Robbins the same day. He was en rolled as a paying pa tien t inthe Na rco no n program, to include the i l legal drug and alcohol r ehab il i tat ionhousing program at the One Sovereign Place apartment complex , forapproximately four and one-half months, and successfully completed and was"graduated" from Narconon 's program on or about February 12,2008, severa lwee ks prior of the complet ion of the Drug C ourt ' s manda ted s ix mo nth t rea tmen tperiod. He then stayed on as a staff me mb er for the hous ing and sau na pro gra msfor the remainder of the six month treatment period.

Fol lowin g h is in it ia l part ic ipat ion in Na rco non 's program, Patr ick re turne d to h isfam i ly 's ho me in F lorida , but fa iled a requi red a lcohol tes t on May 2 0 , 2 00 8.This incident led to him being compelled by the Drug Court to return toNarconon 's fac i l i ty .

Pat r ick re turned to Narco non on M ay 2 3 , 2008 and wa s reassessed by DefendantDr. Robbins on June 3 , 2008.

On the evening of June 10 , 2008, Pat r ick was drinking beer and vod ka wi thNarc onon employees and s taff mem bers in a staff mem ber 's apartment a t OneSovereign Place .

After becom ing h ighly in toxicated wi th Na rcon on 's employees and s taffme mb ers , Pat r ick lef t the i l legal housin g pro gram 's premises wi th two formerpatien ts of Na rcon on wh o had annou nced the ir intention to at tempt to bu y heroin.The Na rcon on employees and s taff mem bers were aw are that Pat r ick in tended toleave these individuals for the purpose of at tempting to buy heroin, but fai led to

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intervene to prevent him from doing so. The Narconon employees and staffmembers l ikewise fai led to make any t imely report to their superiors or law

enforcement that Patrick had left the premises. N o securi ty and no reasonab le or adeq uate super vision or mon itoring to ens ure

that neither Patrick nor any other drug or alcohol-dependant patient would beallowed to freely leave the housing program premises at their own discret ion forthe purpose of engaging in on-going abuse of drugs and a lcohol was provide d byor on behalf of Narconon for the benefi t and safety of the patients.

No securi ty and no reasonable or adequate supervis ion or moni toring to ensurethat Na rcon on 's pat ients would not engage in on-going abuse of drugs andalcohol a t the housing program prem ises was provide d by or on behal f ofNarconon for the benefi t and safety of the patients.

Short ly before 2 :00 A.M . on the mor ning of June 11 ,200 8, emergenc y medica lpersonnel responded to a 911 call placed by two former patients of Narcononfrom a vehicle stopped on the shou lder of 1-285 in DeKalb County . W henemergency personnel arrived on the scene, they found Patrick incardiopulmonary arrest wi th no b lood pressure or pulse . He was taken toNorthside Hospi ta l Emergency Department where the emergency physic iandiagnosed P at r ick wi th cardiopulmonary arrest secondary to heroin overdose .

Pat r ick was pronoun ced dead a t 5 :15 P .M . on June 11, 2008.6.

Based up on the aforement ioned docu ments a nd assumed facts , and upon myeducation, training and experience, i t is my opinion that Lisa C. Robbins, M.D., in her

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care and treatment of Patrick W. Desmond fai led to exercise the degree of care and skil lordinari ly exercised by members of the medical profession generally under the same or

similar circumstan ces. Specifically, Dr. Rob bins, as the med ical director of N ar co no n o fGeorgia, fai led to exercise authori ty and responsibil i ty for the oversight and safety of thepatients at Nar cono n. At minim um , the standard of care required that a pati ent such asPatrick be prov ided with reason able and adequate supervision b y properly qua lified andtrained staff during their drug and alcohol rehabil i tat ion treatment. Although Patrick wasnot enrolled in a l icensed residential facil i ty, as required by the Brevard County DrugCourt , he was neve rtheless placed in a housin g pro gra m sett ing. Un der suchci rcumstances, i t wa s medical ly necessary that reasonable or adequate supervis ion ormonitoring be provided to ensure that Patrick and other drug or alcohol-dependantpatients would not be al lowed to freely leave the housing program premises at their owndiscretion for the purpose of engaging in on-going abuse of drugs and alcohol andsimilarly would not be al lowed to engage in on-going abuse of drugs and alcohol at thehousing program prem ises . As Na rcon on 's m edical d i rec tor , Dr. Robbins hadresponsibil i ty for the fai lure to provide reasonable or adequate supervision or monitoringin the unl icensed housing program set ting .

7.It is further m y opinion tha t the said departu res from the standard of care, to a

reasonable degree of medical certainty, caused or contributed to the death of Patrick W.D e s m o n d .

8.

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D a v i d E . S m i t h , M .D . P a g e 2

I . Curre nt Medical Practice

Chair, Adolescent Addiction Treatment, Newport Academy, Corona Del Mar, California 2008-Present Medical Director, Center Point, Inc., San Rafael, California 1993-Present Medical Review Officer - PG&E, San Francisco, California 1990-Present Adjunct Professor, University of California San Francisco 2000-Present Diplomate, American Board of Addiction Medicine 2009-Presect Fellow, American Society of Addiction Medicine 1997-Present Fellow, American Academy of Clinical Toxicology 1987-Present

n . Education

East Bakersfield High School Bakersfield College, A A . University of California, B erkeley, B. A., Zoology University of California, San Francisco, M.S., Pharmacology University of California, San Francisco, M.D ., Medicine San Francisco General Hospital, Internship University of California, San Francisco, Post-Doctoral Fellowship, Pharmacology and Toxicology Institute for the Advanced Study of Human Sexuality, Fh.D. coursework

1964

195619581960

19641965

1965-19671979-1984

H . Current Medical Practice

Chair, Adolescent AddictionTreatment, Newport Academy, Corona Del Mar, California 2008-Present Medical Director, Center Point, Inc., San R afael, California 1993-Present Medical Review Officer - PG&E, San Francisco, California 1990-Present Adjunct Professor, University of California San Francisco 2000-Present Diplomate, American Board of Addiction Medicine 2009-Present Fellow, American Society of Addiction Medicine 1997-Present


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D a v i d E . S m i t h , W I .D . P a g e 3

Fe l low, American Academy o f Clinical Toxicology 1987-Present

I I I . Past Medica l PracticeExecutive Medical Director, Prometa Center, San FranciscoChief ofAddiction Medicine, Bayside Ma rin, Titraron, CaliforniaMedicalDirector,Haight Ashbury Free ClinicsResearch Director, M PI Treatment Services, Summit Medical Center,Oakland, CaliforniaMedical Director, California Collaborative CenterforSubstance Abuse PolicyResearch, University of California, San FranciscoMedicalDirector,California State Department of Alcohol and Drug ProgramsDoping Control Officer, Winter Olympics, Salt Lake CityMedical Staff, Fresno Community Hospital and Medical Center,Community Hospitals of Central California, Fresno, CaliforniaMedical Review Officer - University of California, BerkeleyMedicalDirector, Forest Farms Community, Adolescent Drug TreatmentProgram, Forest Knolls, CaliforniaConsultant on Drug Abuse, Gladman Memorial Psychiatric Hospital,Oakland, CaliforniaConsultant on Drug Abuse, Marin Alternative Community Therapy,San Rafael, CaliforniaMember, U.S . Olympic Team, Doping Control SectionSa n Francisco Psychiatric Hospital Courtesy StaffPhysician, Presbyterian Alcoholic ClinicPhysician, Contra Costa Alcoholic ClinicDirector, Alcohol & Drug Abuse Screening Unit, San Francisco General Hospital

2006-20082006-20081967-20061984-20031998-20071998-200620021993-19951996-20061983-19941981-19861978-198419841973-19771965-19661965-19681965-1972

I V . Teaching Activities1. AdjunctProfessor, University of California, San Francisco2 . Visiting Research Professor, University of California, S an Francisco3. Associate Clinical Professor of Occupational Health an d Clinical Toxicology,Department of Occupational Health, University of California, San Francisco4. Associate Clinical Professor of Clinical Toxicology, University of California,Sa n Francisco5 . Lecturer in Criminology, University of California, Berkeley6. Co-Director,National Training Center for Drag Education, San Francisco, California7- Preceptor, Community Medicine Preceptorship Program, University of California,Sa n Diego8, FacultyMember,National College of Juvenile Justice, University of Nevada,Reno, Nevada

HonoraryLecturer, Department of Medicine, Addiction Research FoundationClinical Institute, Toronto, CaliforniaVisiting Clinical Professor of Behavioral Pharmacology, University ofNevada Medical School

11 . Lecturer on Substance Abuse, U C Berkeley-UC San Francisco Joint MedicalSchool Program12 . Guest Lecturer on Substance U se Disorders Assessment & Management of CommonPsychiatric Symptoms Course, UCSF Department of Community Health Systems

9.10,

2000-present1998-20001986-Present1967-Present1968- 196919701972-19731971-19761975-19901975-Present1980-Presant

November 1999


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D a v i d E . S m i t h , M . D . Page 4

\ Consultancies1. Consultant, Drug Abuse Division of Alcoholism, California Department ofPublic Health 1966-19682 . Consultant, Drug Abuse, Veteran's Actoinistration Hospital 1968-Present3 . Consultant, Student Association for the Study of Hallucinogens 1968-19804. Consultant,National Commission on Venereal Disease 1971-19725, Consultant, President's Special Action Office on Drug Abuse Prevention 1971-19736. Consultant, Committee on Dangerous Drugs, California Medical Association 1970-19737 . Consultant on Drug Abuse, United States A ir Force 1972-19738. Consultant on Drug Abuse, National Association of Ding Abuse 1972-19849. Consultant on Drug Abuse, SAODAP 1972-197310. Consultant on Drug Abuse, NIMH 1972-197311 . Consultant to NIMH - National Clearinghouse on Drug Abuse Information 1972-197412. Consultant to NIMH - NARB Drug Treatment Program 1972-197413. Consultant to Committee on Alcoholism an d Drug Dependence,

1973 House of Delegates 197314. Advisory Council, Department of Health, Education & Welfare 197315 . Advisory Board to PHARMCHEM Research Foundation 1975-198416. Consultant, Stanford Research Institute on Drug Abuse 1975-197617. Consultant, Alcohol an d Drug Abuse, AMA Council o n Scientific Affairs 197718. Advisory Comm ittee, San Francisco HealthDepartment, Sexual Trauma Center 197719. Advisory Council on Narcotics and Drug Abuse, Sacramento, California 1979-198020 . Advisory Committee o n Controlled Substances, Food an d Drug Administration,Washington, DC 1978-19832 1. Consultant, Mentimger Clinic, Topeka, Kansas 1983-199522 . Consultant, San Francisco General Hospital, Department of Psychiatry 1966-Present2 3 . Consultant, Committee on Alcoholism an d Other Drug Dependencies,California Medical Association 1978-199024. Consultant, American Medical Association Diagnostic an d TherapeuticTechnology Assessment 1982-198525 . Consultant an d Member Advisory B oard,Marin A C T . 1982-198526. Alternate Delegate to th e American Medical Association representingthe American Medical Society on Alcoholism an d Other Drug Dependencies 1989-Present27 . American Psychiatric Association: Consultant to Substance Abuse Section,Work Group to revise DSM-IH 199028. Johnson Institute: Faculty Training Position 199028. Alcohol, Tobacco & Other Drugs Advanced Practice Nursing Subspecialty Program:Advisory Cornmittee 199830. United States Olympic Committee National Anti-Doping Program Review 19983 1. International Society o fAddiction Medicine (ISAM)Chairman, Health Economics Cornmittee 1999-Present

VT . Coordinating Agencies1. Founder, Former President an d Former Coordinating Committee Member,

National Free Clinic Council 1968-1972

VS. MembersMps1. Member, U.S . Office of Education, Drug Education Project an dAssistantDirector, West Coast Regional Training Center 1970


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?^btt-!'tv\ :"V )^k-&thi-:*'

D a v F d E . S m i t h , W . D . P a g e 5

2 . Member, Advisory Board of Contemporary Drug Problems 19713 . Member, Governor's Task Force on Veteran Drug Addicts 19714 . Member, San Francisco Association for Mental Health ProfessionalAdvisory Committee 197049735. Member, San Francisco Medical Society for Alcoholism and DangerousDrags Committee6. Ad Hoc Committee - City College Student Health Services7. Member, Scientific Review Boards Methadone Maintenance Program8. Member, Pa n American Medical Association9. Member, Scientific Advisory Cornmittee on Drugs, National Research Council10 . Member, PAMA Section on Drug Abuse an d Narcotic Addiction11 . Member, PAMA Section on Forensic Medicine12 . Associate Member,World Medical Association13 . Member, National Association State Drug Coordinator,Drug Abuse Prevention Task Force 1982-199514 . BoardMember, Westside Community Mental Health Center 197315 . Member,Royal Society of Medicine, London, England 197316 . Member, Conference Organizing Committee First Annual NationalDrug Abuse Conference, Chicago, Illinois 197417 . Board of Directors Community Management Center 197318. Member, Clinical Review Board, National Institute on Drug Abuse 1973-Present19 . Co-Chainnan, National Free Clinic Council,National Free Clinio Physicians Caucus 197420. Member,Board of Directors, Haight Ashbury Switchboard 1974-197521. Member, American College of Emergency Physicians 1972-199521. Member, Advisory Board of the National Drug Abuse Center for Training an dResource Development 1975-199522. Member, Professional Advisory Board, "The Door: A Center of Alternatives,"

N ew York, N ew York 1974-198524. Member, Sa n Francisco Heart Association 1976-197725. Member, Northwestern Medical Association, Bic. 1974-199026 . Member,Board of Advisors, Awareness House, Oakland, California 197727. Member, California PC P Training Project Technical Advisory Group 1978-197928. Member,Physicians for Prevention, White House Office on Drag Control Policy 1995-Present29. Member, National Council on Alcoholism an d Drug Dependence, Inc. 1995-Present3 0. Member,Prescription Drug Research Center, Chicago, Illinois 20043 1. Member, Independent Advisory Committee ou Prescription Stimulant Abuse 2007-Present

VI I . Societies1. Member, San Francisco Medical Society Drug Abuse Committee,Physician's Well Being Committee2. Sa n Francisco Medical Society Local Health Affairs Committee3 . Sa n Francisco Medical Society Editorial Board4. Member, California Medical Association Drag Abuse Committee,Prescription Drug Committee5. Member, American Medical Association Drug Abuse Committee6. Member, California Society of Addiction Medicine7. Member,American Society of Addiction Medicine Board of Directors,Special Status Committee, Nomenclature Committee8. Member,Board of Medical Quality Assurance, Diversion Liaison Committee9. Member, Phi Beta Kappa10 . Member, Sigma XI11 . American Public Health Association (Mental Health Section)

1970- 1985197219721972-19951971- 19721972- 19951972-19951972-1995

1965-Present1997-Present1999-Present1965-Present1965-Present1972-Present1972-Present1982-19841960-Present1960-Present1968-Present


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D a v i d E . S m i t h , M . D . P a g e s

12 . CharterMember, American Academy of Clinical Toxicology13 . Charter Member an d Chairman, Editorial Committee, California Society for theTreatment of Alcoholism and other Drug Dependencies14. Member, Sa n Francisco Society Board of Medical Quality Assurance Committee15 . Member, Western Pharmacology Society16 . Member, Committee on the Well Being of Physicians,California Medical Association17 . Chairman, Well Being Cornmittee, American Society of Addiction Medicine18 . Founding Board of Directors, International Society of Addiction Medicine (ISAM)19 . Chairman, Pain an d Addiction Cornmittee, International Society of AddictionMedicine

1968-Present1973-Present

1 9 7 91970-Present1997-Present199919992002

E L Training Activities1. Chairperson, National Drug Abuse Conference, San Francisco 19772 . National Institute on Drug Abuse Training Advisory Committee 1978-19903 . Director, Amphetamine Evaluation an d Physician Tratoing Project 1977-19794 . Director, PC P Research an d Training Project 1978-19805 . Co-Director, Impaired Healtli Professional Research an d Training 1980-19906 . Director, Benzodiazepine Research & Physician Training Project 1980-19857. Co-Director, Drug Abuse an d Sexual Dysfunction Research an dPhysician Training Project 1979-19858 . MedicalDirector, Haight Ashbury Training an d Education Project 1980-1995

X . Political and Governmental Positions/Activities1. Member, Task Force on Domestic Affairs at the Advisory Council of the ElectedOfficials to the Democratic National Committee: A Study Group in Drug Abuse and

Alcoholism 19712 . Co-Chairman, Northern California Physicians for McGovem for President 19723 . Chairman, Northern California Physicians for Carter for President 1975-19764 . Health Advisor to President Jimmy Carter 19765. Alcoholism an d Drug Abuse Sub-Committee for the Democratic National Platform 19766 . Member, Governor's Advisory Panel on Narcotics and Drug Abuse 19777. Consultant, FD A Controlled Substances Advisory tammittee 1978-19838 . Consultant,National Institute of Drug Abuse 1976-19849 . Member, Committee on Impaired Health Professionals, California Society

for the Treatment of Alcoholism an d Other Drug Dependencies 198010. Physician's Representative on the California State Controlled SubstancePrescription Drug Advisory 1993

X L Honors1 . Borden Research Award 19642 . Research Award 19663 . California Junior College Alumnus of the Year 19694 . Chancellor's Award for Community Service, University of California,San Francisco 19745. 16th Annual San Francisco Examiner "Ten MostDistinguished" Award 19746. American Medical Association Physician's Recognition Award in Continuing Education 19787. Martin Luther King HumanitarianAward, Glide Methodist Church,San Francisco, California 1980


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8. Drug Abuse TreatmentAward, California Association State Drug Abuse Coordinators 19839. Drug Abuse TreatmentAward, National Association, State Alcohol and Drug AbuseCoordinators 198410. Career AchievementAward, National Association of State Alcohol an d Drug AbuseDirectors (NASADAD) and National Prevention Network 199411 . University of California Medal of Honor Recipient 199512 . Community Works Award, State of California Drug Policy Office 199613. Th e Best Doctors in America: Pacific Region 1996-199714. California Medicine Magazine; named one of "California's 10 0 MostInteresting and Influential Health Care Leaders" 199715. California Association of Alcoholism an d Drug Abuse Counselors(CAADAC) Council of Fellows 199816. Haight Ashbury Free Clinics, Lifetime Achievement Award 199817. Geri Taylor Memorial Award, Northern California Psychiatric Society 199818. TalbottRecovery Campus Award 199919. Governor's Older Worker an d Exemplary Employer Recognition Award 2002

X I I . Editorial Positions1. Founder an d ExecutiveEditor, Journal of Psychoactive Drugs (formerly known as

Journal of Psychedelic Drugs) 1967-Present2 . Member, Editorial Board, Th e Journal, th e official publication of the TorontoAddiction Research Institute 1974-19933. Member, EditorialBoaxd, Clinical Toxicology 1975-20074. Co-Editor, Addictions Alert Newsletter 1987-20055. Contemporary Drug Problems: A Law Quarterly6. Journal ofAmerican College of Emergency Physicians7. Editorial Board, Drug Abuse an d Drug Education8. Editorial Board, Clinical Toxicology9. Editorial Advisory Boazd^imerican Journal of Drug an d Alcohol Abuse 197310. AdvisoryBoard, Th e Center for the Study of Non-Medical Drug U se 1976-Present11. Advisory Board, Womenln Crisis, Inc., N ew York 1981-200512. Editorial AdvisoryBoard, Jownal of he American Medical Association 1984-200613 . MedicalEditor, AlcoholMD.com 2000-Present14. Editorial Board, Journal of Addiction Medicine 2002-Present

XITJ. Research Projects1. Assistant Principal Investigator, C.RC . Dug Abuse Social Rehabilitation an d DemonstrationProject Department of Health, Education an d Welfare Grant #15-P-55894. Research onvocational rehabilitation for drug abusers, including support for psychological services andvocational training through Haight Ashbury Free Clinics. National seminar with four-volume

proceedings funded by President's Special Action Office fo r Drug Abuse Prevention.1972- 1974

2 . Assistant Principal Investigator, West Coast Polydrug Research an d Treatment Projec tInvestigated patterns of polydrug abuse an d provided treatment an d teuning for physicians.Funded by the President's Special Action Office for Drug Abuse Prevention.1973- 1974

3. Associate Principal Investigator, Sa n Francisco Polydrug Project NIDA grant(number unavailable).1974- 1977


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D a v i d E . S m i t h , M . D .

4. Principal Investigator an d Director, Amphetaraine Evaluation and Physician Training Project.Research on treatment of amphetamine abuse and treatment, including several symposiums andnational conference with bound proceedings. Funded by Smith Kline & French.5. Principal Investigator an d Director,PC P Research and Training Project. Research on treatmento fPCP abuse and training for physicians and law enforcement including national conference.Diverse government an d private funding sources.5 . Co-Director, Drug Abuse an d Sexual Dysfunction Research an d Physician Training Project.Presented national conference and p roceedings. Various funding sources.6. Co-Principal Investigator and Director, Benzodiazepine Research an d Physician Training Project.Developed international physician clinical research network on effects of benzodiazepines atclinical an d non-clinical dosages. Resulted in international conference, numerous articles, booksand proceedings. Currently used benzodiazepine withdrawal protocol is named the Smith &Wesson Protocol. Funded by Hoffinann LaRoche, Nutley, N J.7. Director, Impaired Health Professional Research and Training. Ongoing clinical research on thetreatment of addicted physicians an d other health professionals leading to development ofdiversion an d treatment programs for physicians, nurses, and other health professionals. Variableprivate mnding .8. Co-Principal Investigator, A controlled study of naltrexone maintenance.NJDAResearch Grant # R 0 1 D A 0 3 5 1 6 .9. Principal Investigator, A controlled study ofL-tryptophan in cocaine withdrawal.M D A Research Grant#R01 D A 0 4 1 8 2 .10. Co-Principal Investigator, A double-blind multi center trial of gepirone and placebo in th etreatment of cocaine dependence. Collaborative site study funded by Bristol-Myers Squibb.11 . Co-Principal Investigator, A controlled study of naltrexone induction with clonidine. NJDAResearch Grant #R01 DA06038 .11 . Co-Principal Investigator, A n open usage study of Trexan as adjunctive treatment with psychosocial therapy to r individuals with alcoholism. Collaborative site study funded by DuPont Merck.12. Co-Principal Investigator, A n observational study on the clinical management of patients treatedwith naltrexone (ReVia TM ) for alcohol dependence. Collaborative site study funded by DuPont

Merck.13. Co-Principal Investigator, Reducing cocaine relapse with naltrexone, a placebo-controlled,

double-blind, randomized cluneal tria l to test th e efficacy of naltrexone fo r reducing relapseamong cocaine abusers who drink alcohol. NIDA Research Grant #R01 D A 0 8 8 7 1 .14 . Consultant, Abuse of Rohypnol in Austin and South Texas, a field work an d qualitative dataanalysis of the phenomenon an d scope ofRohypnol abuse in the southern an d border areas ofTexas. Funded by Hoffmann-LaRoche,15 . Principal Investigator, Fenflmamine/dexfenfluramine use partem surveillance program.Monitored for development of abuse of fenfluramine or dexfenflmamine. Funded by WyethAyerst

P a g e 8

1977- 1979

1978- 1980

1979- 1985

1980- 1985

1980-2006

1985-1989

1987-1991

1990-1991

1990-1994

1993-1995

1995-1996

1995- 1998

1996- 1997

1996-1998


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D a v i d E . S m i t h , M . D . Page 916 . Consultant, Tyrosine fo r memamphetamine dependence, a placeho-controlled, double-blind,randomized clinical trial oest th e efficacy of tyrosine as an adjunct to psycho social treatment inabstmence initiation in methamphetamine abusers. NIDA Research Grant No.ROl DA10739.

1996- 199917. Co-Principal Investigator, Acamprosate in-patients with alcohol dependence, a double-blindcontrolled safety and efficacy study at two active dosage levels. Collaborative site study fundedby Lipha Pharmaceuticals.1997- 1998

18 . Consultant, Rohypnol abuse in Florida, a field work an d qualitative data analysis of thephenomenon and scope of Rohypnol abuse in Florida. Funded by Hoffinann-LaRoche.1997- 1998

19. Co-Principal Investigator, A long-term safety study of SCH 39166 in the treatment of cocainedependence. Collaborative site study funded by Schering-Plough Research Institute.1998

20 . Consultant, Emerging drugs of abuse in California, a field work and qualitative data analysisproject to investigaten ew drug abuse patterns in California. Fundedby Hoffinann-LaRoche.1998- 1999

2 1 . Principal Investigator an d Medical Director, California State Department of Alcohol an d DragPrograms Contract N o. 99-00205. Administered through Institute on Health and Aging, UCSF.1998-2006

22 . Co-Investigator, Modafinil use partem surveillance program. Monitoring for possible development of abuse o rmisuse o fModafinil (Provigil T M) . Funded by Cephalon, Inc.1998-2001

23. Consultant, Methamphetamine dependence and the risk of HIV infection, a longitudinal study ofin-treatment and out-of-treatment methamphetamine users in San Francisco an d Sacramento toexamine HTv* seroprevalence, seroincidence, risks behaviors, and their antecedents. NJDAResearch GrantN o. R 0 1 D A 1 0 6 4 1 . 1998-20022 4. Principal Investigator, Technical Assistance-Prevention Outcomes and M easures . CaliforniaState Department of Alcohol an d Drug Programs Contract N o. 98-00253. Administered throughInstitute fo r Health and Aging, UCSF .

1999- 200125. Principal Investigator, Adolescent Services, California Alcohol an d Drug Programs Contract.Administered though Institute for Health and Aging, UC SF.

2000- 200326 . Principal Investigator, County Profiles, California Alcohol an d Drug Programs ContractAdministered through Institute o n Health and Aging, UCSF.

2000-2003X I V , Bibliography

1. Smith D E & Katzung BG . Mechanical Properties of Hibernating Heart Muscle. American Heart Journal, April, 1966 .2 . Smith DE . Lysergic Acid Diethylamide: An Historical Perspective. Journal ofPsychedelic Drugs, Volume 1(1), p. 307,1967.3. Shubart P, Smith D E & ConrichR . The Concept of Regionalized Health Facility for the Haight-Ashbury Subculture.Journal of Psychedelic Drugs, Volume 1(1), pp .53-55,1967.4. Smith DE . STP: A N ew Hallucinogen. Monograph - Adverse Reactions to Hallucinogenic Dregs , NIMH Publications,1967.5. SmithDE, Fisher C M & Hine CH . Effects of Chloipromazine Plienobarbital an d Iproniazid on th e Polyphasic

Mortality Curve of Aggregate Amphetamine Toxicity, Applied Pharmacology, Volume 10, p. 402, March, 1967.


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6. Smith D E . T h e Role of B Vitamins in Alcoholism Debated. Quarterly Alcohol Review, October, 1967.7. Smith D E , Fort J & Craton D . Psychoactive D r u g s . Journal of Psychedelic Drugs, Volume 1, p p . 150-158, July, 1967.8. S m l t h D E & S h u b a r t P . A Regionalized Medical Clinic in the Haight -Ashbury, California's Health, Volume 25(5) , pp .3 -6 ,1968 .9. Smith D E & Rose A J . LSD : I ts Use, Abuse an d Suggested Treatment (Observations by the Haight Ashbury MedicalClinic). Journal of Psychedelic Drugs, Volume 1(2), pp. 117-123,1968.10. Meyer F H & Smith D E . AB1399: Report to the Legis lature , California Drug Abuse Treatment an d ResearchFacil i t ies . California Medicine, September, 1968,11. Smith DE &Me yer F R The New Generation and the New Dr ugs . California's Health, Volume 25(8) p p . 7-11 ,1968 .12. Smith D E . T h e Role of Nicotinic Acid Derivatives in the Treatment of Acute Toxic Psychosis. Journal of PsychedelicDrugs, Volume 1(2), pp. 112-114,1968.13. Meyer FH , Rose A J & Smith D E . Incident s Involving th e Haight-Ashbury Population and Some Uncommonly UsedD r u g s . Journal of Psychedelic Drugs, Volume 1(2), pp. 139-146,1968.14. SanlcotM& Smith D E . Drug Problems in the Haight -Ashbury. American Journal of Nursing,August, 1968.15. Smith D E . A View of the Hippie "Non-Student". 1968 Annual Proceedings of the National College Association, Apr il ,1968.16. Smith D E . Speed Kills - Patterns of Higb Dose Methamphetamine Abuse. 1968 Annual Proceedings of he NationalCollege Association, April, 1968.17. S m i t h D E . Methamphetamine Abuse. Bulletin of the Los Angeles County Medical Society, pp . 22-24, June 6 , 1 9 6 8 .18. S m i t h D E . Youth and Drug Ab use . Th e MindBenders, McQisw Publications, 1968.19. Smith D E & Rose A J. Observations in the Haight-Ashbury Medical Clinic of San Francisco - Health Problems in aHippie Subculture . ClinicalPediatrics, Volume 6, pp . 313-322,1968,20. Smith D B. Speed Kills. Santa Cruz Health Services Proceedings, Student Drug Conference, April, 1968.21 . Smith D B. Contemporary Patterns of Youth an d Drug Ab use . Mind Drugs, McGraw Hill Publications, 1969.22 . S m i t h D E . L S D a n d th e Psychedelic Sy ndr ome . Annual Proceedings of the California Advisory Council on EducationResearch, California Journal ofEducation Research,~bfo\ember, 1968.23 . Meyer F H & Smith D E . Drug Abuse Recommendations fo r California Treatment an d Research Facilities. California

Medidne,Yohivas 109, pp. 191-197,1968.24. S m i t h D E . Acute a n d Chronic Marijuana Toxicity. Journal of Psychedelic Drags' , Volume 2 , 1 9 6 9 .25 . Smith D E & B e n t e l D J . California Drug Scene. Th e Yearbook of DrugAbuse, Behavioral Publications, New York, p . 157,1969.26. Schick F , Meyer F H & S m i t hD E . Marijuana U se in the Haight-Ashbury Sub cul tu r e . Journal of Psychedelic Drugs,Volume 2(1), 1969.27 . Smith D E & M e h l C . A n Analysis of Marijuana Toxicity. Clinical Toxicology, March, 1970.


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28 . Smith D E . Runaways and Their Health Problems in the Haight-Ashbury During th e Summer of 1967. AmericanJournal of Public Health, November, 1969.29 . Smith DE. Th e Characteristics of Dependence in High Dose Methamphetamine A b u s e . International Journal ofAddictions, Volume 4(3), pp. 453-459, 1969.30 . S m i t h D E . Changing Drug Patte rns in the Haight-Ashbury. California Medicme,'Bebruary, 1969.31 . S m i t h D E . Speed Freaks vs. Acid Heads: A Conflict Between Drug Subcultures . Clinical Pediatrics, April, 1969.32 . Smith DE. Dependence Characteristics in High Dose Methamphetamine Abuse . International Journal of Addictions,

1969.33 . S m i t h D E . Youth, Alienation and th e Drag Scene. American Journal of'Osteopathy, 1969,34 . Smith D B , Wesson D&LannonR. New Developments in Barbiturate Abuse. Drug Abuse Papers 1969, JJ.C, Berkeley

Extension, 1969,35 . S m i t h D E . Narcotics Abuse in San Francisco. DrugAbuse Papers 1969, U.C.Berkeley Extension, 1969.36 . Smith DE. LSD and th e Psychedelic Syndrome . Clinical Toxicology, Volume 2(1) , pp . 69-73, March, 1969.37 . Smith DE. Physical vs. Psychological Dependence and Tolerance in High Dose Methamphetamine A b u s e . ClinicalToxicology, Volume 2(1), pp. 99-103, March, 1969.38 . Smith DE. Th e Tr ip : There a n d Back. Emergency Medicine, December, 1969.39. SmithDE & Stages C S. T h e Semantics of the San Francisco Drug Scene, ETC, Volume 26(2), pp. 168-175,1969.40 . Smith DE . & Fischer, C M . Acute Amphetamine Toxicity. Journal of Psychedelic Drugs, Volume 2(1) , pp . 49-54 ,1969.41 . Smith D E e t al . Behavioral Mediators in the Polyphasic Mortality Curve of Aggregate Amphetamine Toxicity.

Journal of Psychedelic Drugs, Volume 2(2), p p . 28 - 36 ,1969 .42 . Smith DE. Th e Psychotomimetic Amphetamines with Special Reference t o D O M Toxicity. Journal of PsychedelicDrugs, pp. 37-41,1969.42a. SmithDE. A n Analysis of Var

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