Noah Levine's Full Statement to RR Board

“All of the above conduct sadly speaks volumes about the current Board’s motives and intentions, which seem to be contrary to the Buddhist principles of truth, transparency, right speech, and right action. Turning now to the allegations in the motion, they are false. I will address each of them in the order in which they are made…”, Noah Levine writing to the RR Board after his removal.


Taken directly from the court filings:

EXHIBIT B

STATEMENT OF NOAH LEVINE IN RESPONSE TO MOTION FOR HIS REMOVAL FROM THE REFUGE RECOVERY BOARD OF DIRECTORS

Greetings, with love and metta to you all.

First, thank you for telling me something I did not know, namely, that I am still a member of the Board of Directors of Refuge Recovery, the organization that you acknowledge I founded. After I took a leave of absence from the Board last year, I saw that the Board seemed to take advantage of my absence by eliminating my position as President. I assumed, mistakenly it seems, that when you eliminated my position, you thereby eliminated my seat on the Board.

You say that you have been in a dispute with me for well over a year. Three months ago, you sued me in federal court. Now you have given me only 40 hours to respond to an abrupt motion for my removal – a motion that one of your many lawyers sent to my counsel Thursday afternoon. You told me the motion is scheduled to be heard at 7:30am today (Saturday).

In response to my counsel’s request for any evidence that supports the “causes” alleged in the motion, one of your lawyers told us by email Thursday that any such evidence will be presented and discussed only at the meeting, with no advance notice to us.

In response to my counsel’s request, pursuant to Article II, Section I of the RR by-laws, for any minutes or other records evidencing the election or appointment of each member of the current board of directors, so that we can ascertain the qualifications, if any, of the stated members of the current board, your counsel declined to provide any such evidence.

The above is a simple, basic, understandable request. Yet the Board, for reasons unknown, has declined to provide the documentation required by the RR by-laws.

All of the above conduct sadly speaks volumes about the current Board’s motives and intentions, which seem to be contrary to the Buddhist principles of truth, transparency, right speech, and right action.

Turning now to the allegations in the motion, they are false. I will address each of them in the order in which they are made.

The motion says that “Noah Levine has been and is an adverse party in litigation by and pertaining to the Organization such that an irresolvable conflict of interest has arisen.”

This is false. There is no “irresolvable conflict of interest.” The path of litigation was chosen by the Board. Prior to your suing me, I suggested mediation of the dispute out of court. You refused to agree to my proposal that mediation sessions be held in February 2019. You announced publicly on January 16 that you decided to litigate instead. I withdrew my own later lawsuit against the Board (filed only because you said you were suing me anyway) to engage in settlement talks, precisely because there are multiple ways to resolve the conflict, if only you were willing. For example:

1. Consistent with the Refuge Recovery program as set forth in the RR Book, we requested that Refuge Recovery retreats, led by qualified teachers, be allowed. In particular, I would like to lead such retreats, and to train others to lead such retreats, all of which could be organized either by a non-profit organization, or by license from RR.

2. Also consistent with the Refuge Recovery program as set forth in the RR Book, we requested the opportunity to create and manage professional RR treatment modalities in various treatment centers. This could be done through a non-profit treatment organization, or by license from RR. Under this proposal, my ostensibly "for profit" treatment organizations (which never generated any profit) would be dissolved.

3. We requested an agreement that the Board in future will be democratically elected, either by sangha representatives, or by delegates at the 2019 Refuge Recovery annual convention, or by some other democratic means to be worked out.

The motion says I “put the reputation, finances, and standing of the Community at risk through [my] commercial ventures, transfer of funds from the Organization to private ventures operated by or for the personal benefit of [myself], and [became] the defendant in additional litigation raising concerns about [my] ethics and business practices, and has publicly disparaged the operation of the Organization and encouraged division within the community.”

All of this too is false, as summarized below.

1. The formation of the Refuge Recovery Treatment Center was entirely consistent with the Refuge Recovery principle of embracing, rather than shunning, the provision of Buddhist-oriented treatment options for addicts. Indeed, the RR Board encouraged the treatment center, and referred a steady stream of patients to it. In your official filing with the IRS, signed by Chris Kavanaugh, you stated that the “primary [tax] exempt purpose” of the organization includes the creating and building of treatment options.

2. This long-standing principle and purpose now has been rejected by you, the alleged current RR Board. You apparently have decided to adopt the opposite approach. Your proposed model for the most part would leave addicts who need treatment to fend for themselves, in a world of often corrupt, usually ineffective, money-centered treatment facilities that too many times do more harm than good. The Refuge Recovery Treatment Center, by contrast, was a great success story, until the RR Board and others drove it out of business in 2018, in part by orchestrating a boycott against it. Over 560 addicts received treatment there, and the lives of many people were turned around for the better, as a result. If you decide to continue on your chosen path of litigation, you will hear the testimony of many witnesses confirming all of this.

3. As for your allegation that I’ve “become the defendant in additional litigation raising concerns about [my] ethics and business practices,” this sadly further confirms the unprofessional and non-Buddhist approach you are taking. I do not know what litigation you are talking about, yet you have given me only 40 hours to respond to this specious and unfounded allegation, while you refuse to provide me with any evidence to support your claims. Perhaps you are talking about the lawsuit of a disgruntled former employee of the treatment center, who lasted only two weeks there, and who has yet to serve his false complaint on anyone. I don’t know if this is what you are taking about, because you have refused to provide me with any details or evidence to support your claims.

Lastly, the motion purportedly relies on the decision of Jack Kornfield and the Spirit Rock organization to remove their authorization of me to teach under their auspices – something I’ve not done for years. As you know, I am supported by my Buddhist masters in the Thai Forest Tradition of Ajahn Chah, who have encouraged me to keep teaching. I note your statement that you “have not conducted [your] our own investigation, nor do [you] make any independent conclusions regarding Mr. Levine’s personal businesses, teaching, or need for rehabilitation. [You] find, however, that [my] rejection of the recommendations and findings causes and has caused harm to the [RR] Organization and disqualifies [me] from participation as a Director.”

This is disturbing on several levels.

First, an authorization to teach on the part of Spirit Rock obviously never has been a requirement for membership of the RR Board of Directors. If that were the case, none of the current members of the Board would be qualified.

Second, the decision and findings of Jack Kornfield and Spirit Rock were a sham. They were completely unmoored from the facts, and based entirely on a herd mentality that you helped create, by your false allegations in your lawsuit against me, including, but not limited to, your false assertions that I diverted monies from RR for my own benefit. You and others helped create the Spirit Rock conclusions, and now you are relying on them, while admitting that you’ve conducted no investigation of your own. As for the false allegations of “rape and sexual assault” that you have propagated on your Facebook page and elsewhere, they are based on claims that have been rejected by the Los Angeles Police Department, which conducted its own investigation. I have not been charged with anything. I am innocent of these allegations. Both your Board Chairman and your Executive Director told me that they do not believe any of the allegations, but that whether they are true or false does not matter to them. What matters to them, and to the Board, as your Board members stated to me and others, are “the optics.” This has nothing to do with Buddhism or the principles of Refuge Recovery.

I refer you and others to the following link to my response to the Board’s unfounded lawsuit against me, in which you are wasting the dana/donations contributed by addicts who never knew you would be using their generosity to sue the founder of their organization:

Link to counterclaims

Rather than ousting me from the Board, I respectfully suggest you look into your own hearts, examine your true intentions, and either change course or resign.


—The American Buddhist