DOCUMENT NO. 28, 131, (4) pages
FILED
SEP 29 87
4 53 PM
U.S. DISTRICT COURT
NEW HAVEN, CONN
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT
ALFRIEDA SLEE, Administratrix
Of the Estate of Jack Andrew Slee
Deceased,
Plaintiff
v.
WERNER ERHARD, ET AL
Defendants.
CIVIL ACTION NO.
N 84 497 (JAC)
AFFIDAVIT OF DR. MARGARET T. SINGER
STATE OF CALIFORNIA
CITY OF BERKKELEY
SS
I, Margaret T. Singer, Ph.D., being duly sworn according to law do hereby state as follows:
I am a licensed Clinical Psychologist, licensed in the state of California. I have observed the est training, interviewed many who have taken the training, viewed video tapes of the trainings, studied literature pertaining to the training as well as sudden death, etc. I have reviewed materials sent by Mr. Ragland pertaining to this case. I have not attempted to outline in detail the materials since this was covered in my deposition.
Counsel for plaintiff in the above case, Gerald F. Ragland, Jr., has requested that I briefly outline my opinions as to the foreseeability of harm from the est training, the role of emotional distress in the marketing of the trainings and the question of the cause of Jack Slee's death. It is my opinion that the defendants in this case either knew of or should have known that the est training caused emotional distress on the part of most individuals taking the training and that this emotional distress created the high probability of psychological and physiological harm. While it was not the highest probability, the range of foreseeable physiological harm included death. It is further my opinion that the defendants intentionally inflict emotional distress as part of their system of marketing the training. While his death was not predictable, harm of that general nature was foreseeable and, in retrospect, his death was the product of a well known harm produced by the defendants, emotional distress.
[signature] Margaret T. Singer, Ph.D.
Subscribed and sworn to before me the undersigned notary public this 16th day of September, 1987.
[signature] My commission expires: Jan. 14, 1991
OFFICIAL SEAL
LISBETH A. HIBBARD
NOTARY PUBLIC CALIFORNIA
COUNTY OF ALAMEDA
My Commission Expires Jan. 14, 1991
This is to certify that a copy of the foregoing was mailed postage prepaid to John R. McGrail, Esq., P.O. Box 1111, New Haven, Connecticut 06505 and Michael M. Futterman, Bower & Gardner, 110 East 59th Street, New York, NY 10022 this 24th day of September, 1987.
