1987 Slee V Werner Erhard Affidavit James Merikangas Md

DOCUMENT NO. 27, 130, (3) pages FILED Sep 25 1987 9 45 AM 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. JAMES MERIKANGAS STATE OF CONNECTICUT CITY OF NEW HAVEN SS I, James R. Merikangas, M.D., being duly sworn according to law do hereby state as follows: I am informed by counsel for plaintiff, Gerald F. Ragland, Jr., in the case of Slee v Werner Erhard and Associates, et al., that defendants’ have filed a motion based in part on my testimony in deposition to the effect that no one could have predicted, in advance, the death of Jack Slee. While this is true, this statement does not fully reflect the nature of my opinions pertaining to this case. Mr. Ragland has requested that I outline my opinions as to forseeability and causation in this affidavit. It is my opinion that defendants had every reason to know, prior to the death

of Jack Slee, that their training was likely to cause emotional distress, stress, adverse changes in the autonomic nervous system and both psychological and physiological harm. It is further my opinion that it is a known fact that deaths from cardiac arrhythmia can and have resulted from emotional distress. While it was not possible to predict the exact occurrence of the death of Jack Slee, his death was within the range of foreseeable harm that could likely result from the est training. Viewing the events in retrospect, it is my opinion that the death of Jack Slee was caused by the est training. [signature] James R. Merikangas, M.D. Subscribed and sworn to before me the undersigned notary public this 18 day of September, 1987. [signature] My commission expires: Susan J. Moffa Notary Public My commission expires March 31, 1990.