NAFC v. Scientology: Answer and Counterclaim by Narconon Oklahoma
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Transcript of NAFC v. Scientology: Answer and Counterclaim by Narconon Oklahoma
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IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF OKLAHOMA
1. NATIONAL ASSOCIATION OF FORENSIC )
COUNSELORS, INC., a Nevada Non-Profit )Corporation; et al. ))
Plaintiffs, )
)v. ) Case No.: 6:14-cv-00187-RAW
)
1. NARCONON INTERNATIONAL, a California )
Non-Profit Corporation; et al. ))
Defendants. )
ANSWER AND COUNTERCLAIM
OF NARCONON OF OKLAHOMA, INC.
The Defendant, Narconon of Oklahoma, Inc. (NNOK) hereby answers the
Complaint of Plaintiffs, National Association of Forensic Counselors, Inc. (hereinafter
NAFC) and American Academy of Certified Forensic Counselors, Inc. d/b/a American
College of Certified Forensic Counselors (hereinafter ACCFC), and counterclaims
against NAFC and ACCFC.
ANSWER
COMES NOW NNOK and for its Answer to the Complaint of NAFC and
ACCFC, does generally and specifically deny each and every allegation contained in the
Plaintiffs' Complaint except those admitted below:
PARTIES JURISDICTION AND VENUE
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1. NNOK is without sufficient knowledge to admit or deny the allegations
contained in paragraph 1 of Plaintiffs Complaint and therefore denies them.
2. NNOK is without sufficient knowledge to admit or deny the allegations
contained in paragraph 2 of PlaintiffsComplaint and therefore denies them.
3. The allegations contained in paragraph 3 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient information to admit or deny those allegations and therefore
denies them.
4. NNOK admits the allegations contained in paragraph 4 of Plaintiffs
Complaint.
5. The allegations contained in paragraph 5 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
6. The allegations contained in paragraph 6 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
7. The allegations contained in paragraph 7 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
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NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
8. The allegations contained in paragraph 8 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
9. The allegations contained in paragraph 9 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
10. The allegations contained in paragraph 10 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
11. The allegations contained in paragraph 11 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
12. The allegations contained in paragraph 12 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
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13. The allegations contained in paragraph 13 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
14. The allegations contained in paragraph 14 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
15. The allegations contained in paragraph 15 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
16. The allegations contained in paragraph 16 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
17. The allegations contained in paragraph 17 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
18. The allegations contained in paragraph 18 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
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NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
19. The allegations contained in paragraph 19 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
20. The allegations contained in paragraph 20 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
21. The allegations contained in paragraph 21 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
22. The allegations contained in paragraph 22 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
23. The allegations contained in paragraph 23 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
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24. The allegations contained in paragraph 24 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
is without sufficient knowledge to admit or deny those allegations and therefore denies
them.
25. The allegations contained in paragraph 25 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
26. The allegations contained in paragraph 26 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
27. The allegations contained in paragraph 27 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
28. The allegations contained in paragraph 28 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
29. The allegations contained in paragraph 29 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
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NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
30. The allegations contained in paragraph 30 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
31. The allegations contained in paragraph 31 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
upon information and belief, NNOK admits those allegations.
32. The allegations contained in paragraph 32 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
upon information and belief, NNOK admits those allegations.
33. The allegations contained in paragraph 33 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
34. The allegations contained in paragraph 34 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
upon information and belief, NNOK admits those allegations.
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35. The allegations contained in paragraph 35 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
upon information and belief, NNOK denies those allegations.
36. The allegations contained in paragraph 36 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
upon information and belief, NNOK admits those allegations.
37. The allegations contained in paragraph 32 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
upon information and belief, upon information and belief, NNOK denies those
allegations.
38. The allegations contained in paragraph 38 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
upon information and belief, NNOK denies those allegations.
39. The allegations contained in paragraph 39 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
upon information and belief, NNOK denies those allegations.
40. The allegations contained in paragraph 40 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
upon information and belief, NNOK admits those allegations.
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41. The allegations contained in paragraph 41 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
upon information and belief, NNOK admits those allegations.
42. The allegations contained in paragraph 42 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
43. The allegations contained in paragraph 43 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
44. The allegations contained in paragraph 44 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
45. The allegations contained in paragraph 45 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
46. The allegations contained in paragraph 46 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
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NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
47. The allegations contained in paragraph 47 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
48. The allegations contained in paragraph 48 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
49. The allegations contained in paragraph 49 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
50. The allegations contained in paragraph 50 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
51. The allegations contained in paragraph 51 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
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52. The allegations contained in paragraph 52 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
53. The allegations contained in paragraph 53 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
54. The allegations contained in paragraph 54 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
55. The allegations contained in paragraph 55 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
56. The allegations contained in paragraph 56 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
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57. The allegations contained in paragraph 57 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
upon information and belief, NNOK admits those allegations.
58. The allegations contained in paragraph 58 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
59. The allegations contained in paragraph 59 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
60. The allegations contained in paragraph 60 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
61. The allegations contained in paragraph 61 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
62. The allegations contained in paragraph 62 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
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NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
63. The allegations contained in paragraph 63 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
64. The allegations contained in paragraph 64 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
65. The allegations contained in paragraph 56 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
66. The allegations contained in paragraph 66 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
67. The allegations contained in paragraph 67 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
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68. The allegations contained in paragraph 68 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
69. The allegations contained in paragraph 69 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
70. The allegations contained in paragraph 70 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
71. The allegations contained in paragraph 71 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
72. The allegations contained in paragraph 72 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
73. The allegations contained in paragraph 73 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
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NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
74. The allegations contained in paragraph 74 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
75. The allegations contained in paragraph 75 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
76. The allegations contained in paragraph 76 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
77. The allegations contained in paragraph 77 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
78. The allegations contained in paragraph 78 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
upon information and belief, NNOK admits those allegations.
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79. The allegations contained in paragraph 79 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
80. The allegations contained in paragraph 80 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
81. The allegations contained in paragraph 81 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
82. The allegations contained in paragraph 82 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
83. The allegations contained in paragraph 83 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
84. The allegations contained in paragraph 84 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
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NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
85. NNOK denies the Plaintiffs allegations giving rise to claims under 15
U.S.C 1116 and 1121, 28 U.S.C. 1331, 1338(a), and 1367(a), but admits that the
Court would have subject matter jurisdiction over claims made against this Defendant,
only, as alleged in paragraph 85 of Plaintiffs Complaint.
86. NNOK admits this Court has personal jurisdiction over it but is without
sufficient information to admit or deny whether the Court has jurisdiction over any of the
co-Defendants identified in paragraph 86 of Plaintiffs Complaint and there fore denies
those allegations. NNOK specifically denies the allegations contained in the last two
sentences of paragraph 86 of Plaintiffs Complaint. Further, Plaintiffs' Complaint
improperly contains separate unrelated counts, causes of action and/or claims against
other Defendants which should be severed from any action against NNOK.
87. NNOK denies the Plaintiffs allegations of any acts or omissions giving
rise to Plaintiffs claims but admits that those allegations allow this District to be a proper
venue with respect to claims against this Defendant, only, as alleged in paragraph 87 of
Plaintiffs Complaint.
FACTUAL BACKGROUND AND ALLEGATIONS
NAFC Backgrounds and Trademarks
88. The allegations contained in paragraph 88 of Plaintiffs Complaint amount
to a statement or conclusion to which no answer is required. To the extent that an answer
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is required, NNOKis without sufficient information to admit or deny those allegations
and therefore denies them.
89. The allegations contained in paragraph 89 of Plaintiffs Complaint amount
to a statement or conclusion to which no answer is required. To the extent that an answer
is required, NNOK is without sufficient information to admit or deny those allegations
and therefore denies them.
90. The allegations contained in paragraph 90 and 90 a. through 90 f. of
Plaintiffs Complaint amount to statements or conclusions to which no answers are
required. To the extent that answers are required, NNOK is without sufficient
information to admit or deny those allegations and therefore denies them.
91. The allegations contained in paragraph 91 of Plaintiffs Complaint amount
to a self-serving statement or conclusion to which no answer is required. To the extent
that an answer is required, NNOK is without sufficient information to admit or deny
those allegations and therefore denies them.
92. The allegations contained in paragraph 92 of Plaintiffs Complaint amount
to a statement or conclusion to which no answer is required. To the extent that an answer
is required, NNOK is without sufficient information to admit or deny those allegations
and therefore denies them.
93. The allegations contained in paragraph 93 of Plaintiffs Complaint amount
to a statement or conclusion to which no answer is required. To the extent that an answer
is required, NNOK is without sufficient information to admit or deny those allegations
and therefore denies them.
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94. The allegations contained in paragraph 94 of Plaintiffs Complaint amount
to a statement or conclusion to which no answer is required. To the extent that an answer
is required, NNOK is without sufficient information to admit or deny those allegations
and therefore denies them.
95. The allegations contained in paragraph 95 of Plaintiffs Complaint amount
to a statement or conclusion to which no answer is required. To the extent that an answer
is required, NNOK is without sufficient information to admit or deny those allegations
and therefore denies them.
96. The allegations contained in paragraph 96 of Plaintiffs Complaint amount
to a statement or conclusion to which no answer is required. To the extent that an answer
is required, upon information and belief, NNOK generally admits that individuals must
meet certain requirements in order to be certified by or through NAFC as alleged in
paragraph in paragraph 96 of Plaintiffs Complaint. To the extent that the allegations
contained in paragraph 96 go beyond the generality of the need for individuals to meet
certain requirements in order to be certified by or through NAFC, NNOK is without
sufficient information to admit or deny those allegations and therefore denies them.
97. The allegations contained in paragraph 97 of Plaintiffs Complaint amount
to a statement or conclusion to which no answer is required. To the extent that an answer
is required, NNOK is without sufficient information to admit or deny those allegations
and therefore denies them.
98. The allegations contained in paragraph 98 of Plaintiffs Complaint amount
to a statement or conclusion to which no answer is required. To the extent that an answer
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is required, NNOK is without sufficient information to admit or deny those allegations
and therefore denies them.
99. The allegations contained in paragraph 99 of Plaintiffs Complaint amount
to a statement or conclusion to which no answer is required. To the extent that an answer
is required, NNOK is without sufficient information to admit or deny those allegations
and therefore denies them.
100. The allegations contained in paragraph 100 of Plaintiffs Complaint
amount to a statement or conclusion to which no answer is required. To the extent that an
answer is required, NNOK, upon information and belief, admits the allegations contained
in paragraph 100 of Plaintiffs Complaint.
101. The allegations contained in paragraph 101 and 101 a. and b. of Plaintiffs
Complaint amount to statements or conclusions to which no answers are required. To the
extent that answers are required, NNOK, upon information and belief, denies the
allegations contained in paragraph 101 and 101 a. and b. of Plaintiffs Complaint.
102. The allegations contained in paragraph 102 of Plaintiffs Complaint
amount to a statement or conclusion to which no answer is required. To the extent that an
answer is required, NNOK is without sufficient information to admit or deny those
allegations and therefore denies them.
103. The allegations contained in paragraph 103 of Plaintiffs Complaint
amount to a statement or conclusion to which no answer is required. To the extent that an
answer is required, NNOK is without sufficient information to admit or deny those
allegations and therefore denies them.
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104. The allegations contained in paragraph 104 of Plaintiffs Complaint
amount to a statement or conclusion to which no answer is required. To the extent that an
answer is required, NNOK, upon information and belief, denies those allegations.
105. The allegations contained in paragraph 105 of Plaintiffs Complaint
amount to a statement or conclusion to which no answer is required. To the extent that an
answer is required, NNOK is without sufficient information to admit or deny those
allegations and therefore denies them.
106. The allegations contained in paragraph 106 of Plaintiffs Complaint
amount to a statement or conclusion to which no answer is required. To the extent that an
answer is required, NNOK is without sufficient information to admit or deny those
allegations and therefore denies them.
107. The allegations contained in paragraph 107 and 107 a. through h. of
Plaintiffs Complaint amount to statements or conclusions to which no answers are
required. To the extent that answers are required, NNOK is without sufficient
information to admit or deny those allegations and therefore denies them.
108. The allegations contained in paragraph 108 of Plaintiffs Complaint
amount to a statement or conclusion to which no answer is required. To the extent that an
answer is required, NNOK is without sufficient information to admit or deny those
allegations and therefore denies them.
109. NNOK is without sufficient information to admit or deny the allegations
contained in paragraph 109 of Plaintiffs Complaint and therefore denies them.
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Defendants Misuse of NAFC Mark, Certifications and Logos
110. NNOKs answers in paragraphs 1 through 109 above are incorporated
herein as if fully repeated.
111. The allegations contained in paragraph 111 of Plaintiffs Complaint which
impose a definition of an alleged Narconon Network are denied. The remaining
allegations contained in paragraph 111 are denied, and NNOK specifically denies that
drug treatment utilizing the technology of L. Ron Hubbard is a fundraising and
recruitment program of the Defendant Church of Scientology.
112. NNOK is without sufficient information to admit or deny the allegations
contained in paragraph 112 of Plaintiffs' Complaint insofar as they relate to other
Defendants but admits that it is a drug treatment and rehabilitation center but denies that
it is part of the Narconon Network as defined by Plaintiffs and further denies that it is
run by Narconon International.
113. NNOK denies the allegations of paragraph 113 of Plaintiffs Complaint
insofar as they related to Pita Group, Inc. Dena Goad, and Kent McGregor. NNOK
specifically denies the implication in paragraph 113 that Pita Group, Inc., Dena Goad and
Kent McGregor operate websites for the sole purpose of referring business to NNOK.
NNOK is without sufficient information to admit or deny the allegations of paragraph
113 as they relate to the other entities and/or individuals identified and therefore denies
them.
114. The allegations contained in paragraph 114 of Plaintiffs Complaint
amount to a statement or conclusion about other Defendants and require no answer by
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NNOK. To the extent that an answer is required, NNOK is without sufficient
information to admit or deny those allegations and therefore denies them.
115. NNOK denies the allegations contained in paragraph 115 and specifically
denies the existence of and participation in any alleged common scheme with other
Defendants to promote the Narconon Network through the misuse of NAFC logos,
trademarks and certifications.
116. The allegations contained in paragraph 116 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
117. The allegations contained in paragraph 117 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
118. The allegations contained in paragraph 118 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
119. The allegations contained in paragraph 119 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
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120. NNOK denies the allegations contained in paragraph 120 of Plaintiffs
Complaint, as framed. NNOK affirmatively states that references to NAFC credentials
by listing certifications after Defendants names were voluntarily removed by this
Defendant following NAFCs alleged revocation in March of 2013 for reasons that were
both arbitrary and capricious and in violation of NAFCs own written policies and
procedures (the Alleged NAFC Revocation). If any references to NAFC credentials or
certifications were made after the Alleged NAFC Revocation, alleged suspension, alleged
expiration or alleged lack of certification, such references were inadvertent and not
willful or intentional conduct violating any law. This Defendant affirmatively alleges
that good faith efforts were taken to remove references to NAFC credentials and
certifications following the Alleged NAFC Revocation, and efforts to remove any that
may still exist and can be accessed continue.
121. The allegations contained in paragraph 121 of Plaintiffs Complaint
amount to a statement or conclusion as to the individual Defendants and are therefore
unrelated to and require no answer from NNOK. To the extent that the allegations of
paragraph 121 of Plaintiffs' Complaint relate to NNOK and require an answer from
NNOK, those allegations are denied.
122. The allegations contained in paragraph 122 of Plaintiffs Complaint
amount to a statement or conclusion as to Defendants other than NNOK and that are
therefore unrelated to and require no answer from NNOK. To the extent that the
allegations of paragraph 122 of Plaintiffs' Complaint relate to NNOK and require an
answer from NNOK, those allegations are denied, as framed. NNOK affirmatively
alleges that any of its IRS 990 Tax Forms speak for themselves.
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123. The allegations contained in paragraph 123 of Plaintiffs Complaint
amount to a statement or conclusion as to Defendants other than NNOK and that are
therefore unrelated to and require no answer from NNOK. To the extent that the
allegations of paragraph 123 of Plaintiffs' Complaint relate to NNOK and require an
answer from NNOK, those allegations are denied. This Defendant affirmatively alleges
that good faith efforts were taken to remove any references to NAFC credentials,
certifications or boards following the Alleged NAFC Revocation, and efforts to remove
any that may still exist and can be accessed continue.
124. The allegations contained in paragraph 124 of Plaintiffs Complaint
amount to a statement or conclusion as to Defendants other than NNOK and that are
therefore unrelated to and require no answer from NNOK. To the extent that the
allegations of paragraph 124 of Plaintiffs' Complaint relate to NNOK and require an
answer from NNOK, those allegations are denied. This Defendant affirmatively alleges
that good faith efforts were taken to remove any references to NAFC credentials,
certifications or boards following the Alleged NAFC Revocation, and efforts to remove
any that may still exist and can be accessed continue.
125. The allegations contained in paragraph 125 of Plaintiffs Complaint
amount to a statement or conclusion as to Defendants other than NNOK and that are
therefore unrelated to and require no answer from NNOK. To the extent that the
allegations of paragraph 125 of Plaintiffs' Complaint relate to NNOK and require an
answer from NNOK, those allegations are denied. This Defendant affirmatively alleges
that good faith efforts were taken to remove any references to NAFC credentials,
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certifications or boards following the Alleged NAFC Revocation, and efforts to remove
any that may still exist and can be accessed continue.
126. NNOK denies the allegations contained in paragraph 126 of Plaintiffs
Complaint. This Defendant affirmatively alleges that good faith efforts were taken to
remove any references to NAFC certifications or boards following the Alleged NAFC
Revocation, and efforts to remove any that may still exist and can be accessed continue.
127. NNOK denies the allegations contained in paragraph 127 of Plaintiffs
Complaint, as framed, and affirmatively alleges that references, if any, to NAFC
credentials or certifications after the Alleged NAFC Revocation were inadvertent and not
willful or intentional conduct in violation of any law. Further, this Defendant
affirmatively alleges that good faith efforts were taken to remove references to any
NAFC credentials and certifications following the Alleged NAFC Revocation, and efforts
to remove any that may still exist and can be accessed continue.
128. NNOK denies the allegations contained in paragraph 128 of Plaintiffs
Complaint, as framed, and affirmatively alleges that references, if any, to NAFC
credentials or certifications after the Alleged NAFC Revocation were inadvertent and not
willful or intentional violating any law. Further, this Defendant affirmatively alleges that
good faith efforts were taken to remove references to any NAFC credentials and
certifications following the Alleged NAFC Revocation, and efforts to remove any that
may still exist and can be accessed continue.
129. The allegations contained in paragraph 129 of Plaintiffs Complaint are
denied by NNOK. Further, this Defendant affirmatively alleges that good faith efforts
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were taken to remove references to any NAFC credentials and certifications following the
Alleged NAFC Revocation, and efforts to remove any that may still exist and can be
accessed continue.
130. The allegations contained in paragraph 130 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
131. The allegations contained in paragraph 131 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
132. The allegations contained in paragraph 132 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
133. The allegations contained in paragraph 133 of Plaintiffs Complaint
amount to a statement or conclusion or are unrelated to and require no answer from
NNOK. To the extent that an answer is required, NNOK is without sufficient
information to admit or deny those allegations and must therefore deny them.
134. The allegations contained in paragraph 134 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
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denies them. Further, NNOK affirmatively states that Plaintiffs' Complaint improperly
contains separate unrelated counts, causes of action
135. The allegations contained in paragraph 135 of Plaintiffs Complaint
amount to a statement or conclusion or are unrelated to and require no answer from
NNOK. To the extent that an answer is required, NNOK is without sufficient
information to admit or deny those allegations and must therefore deny them.
136. The allegations contained in paragraph 136 of Plaintiffs Complaint
amount to a statement or conclusion or are unrelated to and require no answer from
NNOK. To the extent that an answer is required, upon information and belief, NNOK
denies those allegations.
137. NNOK denies the allegations contained in paragraph 137 of Plaintiffs
Complaint, as framed, and affirmatively alleges that references, if any, to NAFC
credentials or certifications after the Alleged NAFC Revocation were inadvertent and not
willful or intentional conduct violating any law. Further, this Defendant affirmatively
alleges that good faith efforts were taken to remove references to any NAFC credentials
and certifications following the Alleged NAFC Revocation, and efforts to remove any
that may still exist and can be accessed continue.
138. The allegations contained in paragraph 138 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
upon information and belief, NNOK denies those allegations, as framed, and
affirmatively alleges that references, if any, to NAFC credentials or certifications after
the Alleged NAFC Revocation were inadvertent and not willful or intentional conduct
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violating any law. Further, this Defendant affirmatively alleges that good faith efforts
were taken to remove references to any NAFC credentials and certifications following the
Alleged NAFC Revocation, and efforts to remove any that may still exist and can be
accessed continue.
139. The allegations contained in paragraph 139 of Plaintiffs Complaint
amount are unrelated to and require no answer from NNOK. To the extent that an answer
is required, upon information and belief, NNOK denies those allegations, as framed, and
affirmatively alleges that references, if any, to NAFC credentials or certifications after
the Alleged NAFC Revocation were inadvertent and not willful or intentional conduct
violating any law. This Defendant further affirmatively alleges that good faith efforts
were taken to remove any references to NAFC certifications following the Alleged
NAFC Revocation, and efforts to remove any that may still exist and can be accessed
continue.
140. The allegations contained in paragraph 140 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
upon information and belief, denies those allegations, as framed, and affirmatively
alleges that references, if any, to NAFC credentials or certifications after the Alleged
NAFC Revocation were inadvertent and not willful or intentional conduct violating any
law. Further, this Defendant affirmatively alleges that good faith efforts were taken to
remove references to any NAFC credentials and certifications following the Alleged
NAFC Revocation, and efforts to remove any that may still exist and can be accessed
continue.
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141. The allegations contained in paragraph 141 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
142. NNOK denies the allegations contained in paragraph 142 of Plaintiffs
Complaint, as framed, and affirmatively alleges that any reference to CCDC certification
following Alleged NAFC Revocation was inadvertent and not willful or intentional
conduct violating any law. Further, this Defendant affirmatively alleges that good faith
efforts were taken to remove any references to NAFC certifications following the Alleged
NAFC Revocation, and continues its efforts to remove any that may still exist and can be
accessed.
143. The allegations contained in paragraph 143 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
144. The allegations contained in paragraph 144 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them, and affirmatively alleges that any use of the CCDC certification following
the Alleged NAFC Revocation was inadvertent and not willful or intentional conduct
violating any law. This Defendant further affirmatively alleges that good faith efforts
were taken to remove any references to NAFC certifications following the Alleged
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NAFC Revocation, and continues its efforts to remove any that may still exist and can be
accessed.
145. NNOK denies the allegations contained in paragraph 145 of Plaintiffs
Complaint, as framed, and affirmatively alleges that any reference to CCDC certification
following Alleged NAFC Revocation was inadvertent and not willful or intentional
conduct violating any law. Further, this Defendant affirmatively alleges that good faith
efforts were taken to remove references to NAFC certifications following the Alleged
NAFC Revocation, and efforts to remove any that may still exist and can be accessed
continue.
146. NNOK denies the allegations contained in paragraph 146 of Plaintiffs
Complaint, as framed, and affirmatively alleges that any reference to CCDC certification
following Alleged NAFC Revocation was inadvertent and not willful or intentional
conduct violating any law. Further, this Defendant affirmatively alleges that good faith
efforts were taken to remove references to NAFC certifications following the Alleged
NAFC Revocation, and efforts to remove any that may still exist and can be accessed
continue.
147. NNOK denies the allegations contained in paragraph 147 of Plaintiffs
Complaint, as framed, and affirmatively alleges that any reference to CCDC certification
following Alleged NAFC Revocation was inadvertent and not willful or intentional
conduct violating any law. Further, this Defendant affirmatively alleges that good faith
efforts were taken to remove references to NAFC certifications following the Alleged
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NAFC Revocation, and efforts to remove any that may still exist and can be accessed
continue.
148. NNOK denies the allegations contained in paragraph 148 of Plaintiffs
Complaint, as framed, and affirmatively alleges that any reference to CCDC certification
following Alleged NAFC Revocation was inadvertent and not willful or intentional
conduct violating any law. Further, this Defendant affirmatively alleges that good faith
efforts were taken to remove references to NAFC certifications following the Alleged
NAFC Revocation, and efforts to remove any that may still exist and can be accessed
continue.
149. NNOK denies the allegations contained in paragraph 149 of Plaintiffs
Complaint, as framed, and affirmatively alleges that any reference to CCDC certification
following Alleged NAFC Revocation was inadvertent and not willful or intentional
conduct violating any law. Further, this Defendant affirmatively alleges that good faith
efforts were taken to remove references to NAFC certifications following the Alleged
NAFC Revocation, and efforts to remove any that may still exist and can be accessed
continue.
150. The allegations contained in paragraph 150 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK denies those allegations, as framed, and affirmatively alleges that any reference to
the CCDC certification following the Alleged NAFC Revocation was inadvertent and not
willful or intentional conduct violating any law. This Defendant further affirmatively
alleges that good faith efforts were taken to remove references to NAFC certifications
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following the Alleged NAFC Revocation, and efforts to remove any that may still exist
and can be accessed continue.
151. The allegations contained in paragraph 151 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK denies those allegations, as framed, and affirmatively alleges that any reference to
the CCDC certification following the Alleged NAFC Revocation was inadvertent and not
willful or intentional conduct violating any law. This Defendant further affirmatively
alleges that good faith efforts were taken to remove references to NAFC certifications
following the Alleged NAFC Revocation, and efforts to remove any that may still exist
and can be accessed continue.
152. The allegations contained in paragraph 152 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK denies those allegations, as framed, and affirmatively alleges that any reference to
the CCDC certification following the Alleged NAFC Revocation was inadvertent and not
willful or intentional conduct violating any law. This Defendant further affirmatively
alleges that good faith efforts were taken to remove references to NAFC certifications
following the Alleged NAFC Revocation, and efforts to remove any that may still exist
and can be accessed continue.
153. The allegations contained in paragraph 153 of Plaintiffs Complaint
amount are unrelated to and require no answer from NNOK. To the extent that an answer
is required, upon information and belief, NNOK denies those allegations, as framed, and
affirmatively alleges that references, if any, to NAFC credentials or certifications after
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the Alleged NAFC Revocation were inadvertent and not willful or intentional conduct
violating any law. This Defendant further affirmatively alleges that good faith efforts
were taken to remove any references to NAFC certifications following the Alleged
NAFC Revocation, and continues its efforts to remove any that may still exist and can be
accessed.
154. NNOK denies the allegations contained in paragraph 154 of Plaintiffs
Complaint, as framed, and affirmatively alleges that any reference to CCDC certification
following Alleged NAFC Revocation was inadvertent and not willful or intentional
conduct violating any law. Further, this Defendant affirmatively alleges that good faith
efforts were taken to remove references to NAFC certifications following the Alleged
NAFC Revocation, and efforts to remove any that may still exist and can be accessed
continue.
155. The allegations contained in paragraph 155 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK denies those allegations, as framed, and affirmatively alleges that any reference to
the CCDC certification following the Alleged NAFC Revocation was inadvertent and
willful or intentional conduct violating any law. This Defendant further affirmatively
alleges that good faith efforts were taken to remove references to NAFC certifications
following the Alleged NAFC Revocation, and efforts to remove any that may still exist
and can be accessed continue.
156. NNOK denies the allegations contained in paragraph 156 of Plaintiffs
Complaint, as framed, and affirmatively alleges that any reference to CCDC certification
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following Alleged NAFC Revocation was inadvertent and not willful or intentional
conduct violating any law. Further, this Defendant affirmatively alleges that good faith
efforts were taken to remove references to NAFC certifications following the Alleged
NAFC Revocation, and efforts to remove any that may still exist and can be accessed
continue.
157. The allegations contained in paragraph 157 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK denies those allegations, as framed, and affirmatively alleges that any reference to
the CCDC certification following the Alleged NAFC Revocation was inadvertent and not
willful or intentional conduct violating any law. This Defendant further affirmatively
alleges that good faith efforts were taken to remove references to NAFC certifications
following the Alleged NAFC Revocation, and efforts to remove any that may still exist
and can be accessed continue.
158. NNOK denies the allegations contained in paragraph 158 of Plaintiffs
Complaint, as framed, and affirmatively alleges that any reference to CCDC certification
following Alleged NAFC Revocation was inadvertent and not willful or intentional
conduct violating any law. Further, this Defendant affirmatively alleges that good faith
efforts were taken to remove references to NAFC certifications following the Alleged
NAFC Revocation, and efforts to remove any that may still exist and can be accessed
continue.
159. The allegations contained in paragraph 159 of Plaintiffs Complaint
amount are unrelated to and require no answer from NNOK. To the extent that an answer
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is required, upon information and belief, NNOK denies those allegations, as framed.
This Defendant affirmatively alleges that any reference to the CCDC certification
following the Alleged NAFC Revocation was inadvertent and not willful or intentional
conduct violating any law. This Defendant further affirmatively alleges that good faith
efforts were taken to remove any references to NAFC certifications following the Alleged
NAFC Revocation, and efforts to remove any that may still exist and can be accessed
continue.
160. The allegations contained in paragraph 160 of Plaintiffs Complaint
amount are unrelated to and require no answer from NNOK. To the extent that an answer
is required, upon information and belief, NNOK denies those allegations, as framed.
This Defendant affirmatively alleges that any reference to the CCDC certification
following the Alleged NAFC Revocation was inadvertent and not willful or intentional
conduct violating any law. This Defendant further affirmatively alleges that good faith
efforts were taken to remove any references to NAFC certifications following the Alleged
NAFC Revocation, and efforts to remove any that may still exist and can be accessed
continue.
161. The allegations contained in paragraph 161 of Plaintiffs Complaint
amount are unrelated to and require no answer from NNOK. To the extent that an answer
is required, upon information and belief, NNOK denies those allegations, as framed.
This Defendant affirmatively alleges that any reference to CCDC certification following
the Alleged NAFC Revocation was inadvertent and not willful or intentional conduct
violating any law. This Defendant further affirmatively alleges that good faith efforts
were taken to remove any references to NAFC certifications following the Alleged
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NAFC Revocation, and efforts to remove any that may still exist and can be accessed
continue.
162. The allegations contained in paragraph 162 of Plaintiffs Complaint
amount are unrelated to and require no answer from NNOK. To the extent that an answer
is required, upon information and belief, NNOK denies those allegations, as framed.
This Defendant affirmatively alleges that any reference to the CCDC certification
following the Alleged NAFC Revocation was inadvertent and not willful or intentional
conduct violating any law. This Defendant further affirmatively alleges that good faith
efforts were taken to remove any references to NAFC certifications following the Alleged
NAFC Revocation, and efforts to remove any that may still exist and can be accessed
continue.
163. The allegations contained in paragraph 163 of Plaintiffs Complaint
amount are unrelated to and require no answer from NNOK. To the extent that an answer
is required, upon information and belief, NNOK denies those allegations, as framed.
This Defendant affirmatively alleges that any reference to the CCDC certification
following the Alleged NAFC Revocation was inadvertent and not willful or intentional
conduct violating any law. This Defendant further affirmatively alleges that good faith
efforts were taken to remove any references to NAFC certifications following the Alleged
NAFC Revocation, and efforts to remove any that may still exist and can be accessed
continue.
164. The allegations contained in paragraph 164 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
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NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
165. The allegations contained in paragraph 165 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
166. The allegations contained in paragraph 166 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
167. The allegations contained in paragraph 167 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK admits there was a link to NNOK on the site referenced in the allegations of
paragraph 167. NNOK states the site/link has been taken down. Further, this Defendant
affirmatively alleges that good faith efforts were taken to remove any references to
NAFC certifications following the Alleged NAFC Revocation, and efforts to remove any
that may still exist and can be accessed continue. This Defendant affirmatively alleges
that any reference to NAFC credentials or certifications following the Alleged NAFC
Revocation was inadvertent and not willful or intentional conduct violating any law.
168. The allegations contained in paragraph 168 of Plaintiffs Complaint
amount to a statement or conclusion or are unrelated to and require no answer from
NNOK. To the extent that an answer is required, NNOK is without sufficient
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information to admit or deny those allegations and must therefore deny them. Further,
this Defendant affirmatively alleges that good faith efforts were taken to remove any
references to NAFC certifications following the Alleged NAFC Revocation, and efforts
to remove any that may still exist and can be accessed continue.
169. NNOK denies the allegations contained in paragraph 169 of Plaintiffs
Complaint, to the extent they allege that NNOK owns and operates the website
referenced in those allegations. NNOK is without sufficient information to admit or deny
the remaining allegations of paragraph 169 and therefore denies them. Further, this
Defendant affirmatively alleges that good faith efforts were taken to remove any
references to NAFC credentials and certifications following the Alleged NAFC
Revocation, and efforts to remove any that may still exist and can be accessed continue.
170. The allegations contained in paragraph 170 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
171. The allegations contained in paragraph 171 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
172. The allegations contained in paragraph 172 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
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NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
173. The allegations contained in paragraph 173 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
174. The allegations contained in paragraph 174 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
175. The allegations contained in paragraph 175 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
176. The allegations contained in paragraph 176 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
177. The allegations contained in paragraph 177 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
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178. The allegations contained in paragraph 178 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
179. The allegations contained in paragraph 179 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
180. The allegations contained in paragraph 180 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
181. The allegations contained in paragraph 181 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
182. The allegations contained in paragraph 182 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
183. The allegations contained in paragraph 183 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
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NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
184. The allegations contained in paragraph 184 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
185. The allegations contained in paragraph 185 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
186. The allegations contained in paragraph 186 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
187. The allegations contained in paragraph 187 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
188. The allegations contained in paragraph 188 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
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189. The allegations contained in paragraph 189 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
190. The allegations contained in paragraph 190 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
191. The allegations contained in paragraph 191 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
192. The allegations contained in paragraph 192 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
193. The allegations contained in paragraph 193 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
194. The allegations contained in paragraph 194 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
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NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
195. The allegations contained in paragraph 195 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
196. The allegations contained in paragraph 196 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
197. The allegations contained in paragraph 197 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
198. The allegations contained in paragraph 198 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
199. The allegations contained in paragraph 199 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
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200. The allegations contained in paragraph 200 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
201. The allegations contained in paragraph 201 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
202. The allegations contained in paragraph 202 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
203. The allegations contained in paragraph 203 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
204. The allegations contained in paragraph 204 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
205. The allegations contained in paragraph 205 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
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NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
206. The allegations contained in paragraph 206 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
207. The allegations contained in paragraph 207 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
208. The allegations contained in paragraph 208 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
209. The allegations contained in paragraph 209 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
210. The allegations contained in paragraph 210 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
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211. The allegations contained in paragraph 211 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
212. The allegations contained in paragraph 212 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
213. The allegations contained in paragraph 213 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
214. The allegations contained in paragraph 214 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
215. The allegations contained in paragraph 215 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
216. The allegations contained in paragraph 216 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
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NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
217. The allegations contained in paragraph 217 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
218. The allegations contained in paragraph 218 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
219. The allegations contained in paragraph 219 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
220. The allegations contained in paragraph 220 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
221. The allegations contained in paragraph 221 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
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222. The allegations contained in paragraph 222 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
223. The allegations contained in paragraph 223 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
224. The allegations contained in paragraph 224 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
225. The allegations contained in paragraph 225 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
226. The allegations contained in paragraph 226 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
227. The allegations contained in paragraph 227 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
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NNOK is without sufficient knowledge to admit or deny those allegations and therefore
denies them.
228. The allegations contained in paragraph 228 of Plaintiffs Complaint are
unrelated to and require no answer from NNOK. To the extent that an answer is required,
NNOK is without sufficient knowledge to admit or deny those allegations and