TAMPA AIRPORT MARRIOTT HOTEL (813) 224-9500
             ST. PETERSBURG - CLEARWATER (727) 821-3320

1 IN THE CIRCUIT COURT FOR PINELLAS COUNTY, FLORIDA CASE NO. 00-5682-CI-11 2 3 4 DELL LIEBREICH, as Personal 5 Representative of the ESTATE OF LISA McPHERSON, 6 7 Plaintiff, 8 vs. VOLUME 7 9 CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, JANIS 10 JOHNSON, ALAIN KARTUZINSKI and DAVID HOUGHTON, D.D.S., 11 Defendants. 12 _______________________________________/ 13 14 15 PROCEEDINGS: Defendants' Omnibus Motion for Terminating Sanctions and Other Relief 16 DATE: May 13, 2002. Afternoon Session 17 PLACE: Courtroom B, Judicial Building 18 St. Petersburg, Florida 19 BEFORE: Honorable Susan F. Schaeffer Circuit Judge 20 REPORTED BY: Debra S. Turner 21 Deputy Official Court Reporter Sixth Judicial Circuit of Florida 22 _________________________________________________ 23 KANABAY COURT REPORTERS 24 TAMPA AIRPORT MARRIOTT HOTEL (813) 224-9500 ST. PETERSBURG - CLEARWATER (727) 821-3320 25 0839
1 APPEARANCES: 2 MR. KENNAN G. DANDAR 3 DANDAR & DANDAR 5340 West Kennedy Blvd., Suite 201 4 Tampa, FL 33602 Attorney for Plaintiff 5 MR. LUKE CHARLES LIROT 6 LUKE CHARLES LIROT, PA 112 N East Street, Street, Suite B 7 Tampa, FL 33602-4108 Attorney for Plaintiff 8 MR. KENDRICK MOXON 9 MOXON & KOBRIN 1100 Cleveland Street, Suite 900 10 Clearwater, FL 33755 Attorney for Church of Scientology Flag Service Organization 11 12 MR. LEE FUGATE and MR. MORRIS WEINBERG, JR. and 13 ZUCKERMAN, SPAEDER 101 E. Kennedy Blvd, Suite 1200 14 Tampa, FL 33602-5147 Attorneys for Church of Scientology Flag Service 15 Organization 16 MR. ERIC M. LIEBERMAN 17 RABINOWITZ, BOUDIN, STANDARD 740 Broadway at Astor Place 18 New York, NY 10003-9518 Attorney for Church of Scientology Flag Service Organization 19 20 MR. BRUCE HOWIE 5720 Central Avenue 21 St. Petersburg, Florida. 22 Counsel for Robert Minton 23 24 25 0840
1 APPEARANCES: (Continued) 2 MR. THOMAS H. MCGOWAN MCGOWAN & SUAREZ, LLP 3 150 2nd Avenue North, Suite 870 St. Petersburg, FL 33701-3381 4 Attorney for Stacy Brooks 5 ALSO PRESENT: 6 Ms. Donna West 7 Mr. Rick Spector Mr. Allan Cartwright 8 Ms. Lara Cartwright Ms. Sarah Heller 9 Mr. Ben Shaw Ms. Joyce Earl 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0841
1 (The afternoon session began at 2:05 p.m.) 2 THE COURT: I have a couple of things. 3 These documents are here pursuant -- 4 Mr. Moxon, this is the one that you talked 5 about on Friday. 6 This came to me Friday, and I just said, 7 "Well, I'll just give everybody a copy on Monday." I 8 don't remember. Apparently, it's something I must 9 have signed an order for because it's here, request 10 under the Hague Convention of the taking of evidence 11 abroad in civil or personal matters. 12 MR. MOXON: Yes, your Honor. I'll see if we 13 can find the order -- 14 THE COURT: Okay. Anyway, it says: 15 "Referring to your request dated" -- I'm going to 16 guess it's 11/16/01 -- "the Royal Marine Administer of 17 Justice and the Police have the honor to inform 18 you" -- I like this; these folks do nice work -- "the 19 honor to inform you that your request has been 20 complied with. Please find enclosed documents." 21 Then it's signed by some folks, and this is 22 all in some language other than English. I don't know 23 what it is. But is there any reason why I just can't 24 hand everybody a copy? 25 MR. DANDAR: Well, because of the Second 0842
1 DCA's opinion, I believe this has to do with financing 2 or money or things like that. 3 THE COURT: I have no idea. 4 MR. MOXON: This has nothing to do with 5 Mr. -- 6 THE COURT: Is this funds? 7 MR. MOXON: -- funds from Mr. Minton to 8 Mr. Dandar. This is the -- this is the money that was 9 testified to that went from Helda Lund, this Operation 10 Clambake, to LMT. 11 MR. DANDAR: That's right, that's right. 12 THE COURT: The $300,000? 13 MR. MOXON: That's right. 14 THE COURT: Okay. 15 MR. DANDAR: Yes, we need to see where that 16 came from. 17 THE COURT: There is one document -- there's 18 a whole bunch of stuff. It's all, as I said, in some 19 language -- I guess this would be Norwegian. 20 MR. MOXON: Yes, I think so. 21 THE COURT: But there's one thing that looks 22 like -- it's got numbers on it, and it looks like 23 there's something called 299815, and then there's some 24 other little numbers. So maybe that's it. 25 MR. MOXON: Okay. 0843
1 THE COURT: But I don't know what to do with 2 it. I mean, was this supposed to be in the court 3 file -- 4 MR. MOXON: No. 5 THE COURT: -- or supposed to go to counsel 6 or what? 7 MR. MOXON: We made -- I've got the order 8 here. 9 THE COURT: Okay. 10 MR. DANDAR: But I think you ought to 11 address it with Mr. Howie, Mr. Minton's counsel. 12 THE COURT: Okay. 13 MR. DANDAR: Oh, there he is. Okay. 14 MR. MOXON: Normally, you, of course, would 15 go to another state, and the state would just go 16 through the discovery procedures in that state. And 17 that's what happened in Norway. 18 But we're informed by Norwegian counsel that 19 because the request was an order, essentially a 20 request from the Court, like a normal out-of-state 21 commission would be, they wanted to send the documents 22 back to the Court, to the requester. And so our 23 counsel provided the Norwegian court the documents. 24 They got them from Helda Lund, gave them back to the 25 Court, and we were informed the Court was going to 0844
1 send them to you. 2 THE COURT: Okay. The only thing I would 3 ask -- this was in January -- apparently this is Judge 4 Beach's initials that says, I guess, a stay of 60 days 5 for execution or extension of this order is granted. 6 MR. MOXON: Yes, in case they wanted to file 7 a writ, but they didn't. 8 THE COURT: Did you file any writ? 9 MR. DANDAR: I had nothing to do with it. 10 THE COURT: Mr. Howie, do you know -- this 11 says UC counsel of record. I just got a whole bunch 12 of documents here that come -- that I can't read, and 13 I was just prepared to hand them out. 14 This copy is no good -- not that I can't 15 read them, but this copy isn't even -- it looks like 16 when Ms. Rudd made a copy that perhaps that one came 17 out bad. Maybe they're all that way. See what the 18 original looks like. 19 Do you want to look at this? 20 MR. HOWIE: Yes, your Honor. 21 MR. MOXON: In fact, your Honor, here's the 22 other order. We had a hearing in front of Judge Beach 23 on this. 24 THE COURT: There's two documents in here. 25 MR. MOXON: The language of the order was 0845
1 approved by both Mr. Dandar and -- 2 THE COURT: Okay. 3 MR. MOXON: -- whoever was representing LMT 4 at that time. 5 THE COURT: Oh, I see the problem with this 6 little -- this original is very light, and when 7 Mrs. Rudd copied it, it didn't turn out very well. 8 But you all can see even on the original, that's very 9 light. 10 MR. MOXON: Yes. But it's readable, I mean, 11 if you could read it. 12 THE COURT: That's the original. I don't 13 know that you can read this -- see? I guess that's 14 the best. 15 MR. MOXON: No, I can't read that. Maybe we 16 can make a new copy of this. 17 THE COURT: Well, you study that if you 18 will, Mr. Howie. 19 MR. HOWIE: Yes, your Honor. 20 THE COURT: Good luck. 21 MR. HOWIE: Well, I have -- 22 MR. FUGATE: "Howie" is Norwegian, isn't it? 23 THE COURT: I'll just keep them here until 24 he's had a chance to look at them, but it does look as 25 though there's been a court order. 0846
1 MR. MOXON: I said that was your order, but 2 I see it's Judge Beach's order. 3 THE COURT: I like this. It says: "Circuit 4 Court of the Sixth Judicial Circuit presents its 5 compliments to the appropriate judicial probate of 6 Norway." No wonder they wrote back and said they had 7 the honor to inform me. 8 MR. MOXON: We copied those from the Hague 9 Convention. 10 THE COURT: Kind of nice. It's very -- 11 MR. DANDAR: All orders should start out 12 that way. 13 THE COURT: You can have a seat, Mr. Howie. 14 MR. HOWIE: Thank you very much, ma'am. 15 THE COURT: You may take your time. 16 MR. DANDAR: For the record, the plaintiff 17 does request a copy of that document. 18 THE COURT: Okay. And defendant obviously 19 wants a copy of it. And I'm not sure why Mr. Howie's 20 reading it. I just had a copy for everybody, but -- 21 MR. DANDAR: Oh. 22 (Ms. Brooks entered the courtroom.) 23 THE COURT: I'm looking at the documents 24 requested. I can understand why funds transferred 25 from Operation Clambake to the LMT would be 0847
1 appropriate to this case, but it says then "or Robert 2 Minton." What would that have to do with this case? 3 MR. MOXON: Well, it has a lot to do with 4 the case. 5 THE COURT: Okay. What? 6 MR. MOXON: I can't read the documents in 7 Norwegian. I don't know. 8 THE COURT: No, I'm saying why would Judge 9 Beach sign an order allowing this Norwegian place to 10 send money that this man, whoever he is, sent to 11 Mr. Minton? I mean, I understand it went to LMT. 12 MR. MOXON: It's a question as to where 13 these funds are actually from, whether they're from 14 Mr. Minton, rather, or to LMT or to Mr. Minton. 15 THE COURT: Okay. Well, as I said, 16 Mr. Howie, you tell me if you have a problem with 17 this. I've got copies for everybody that I've made. 18 I've got the original. 19 MR. MOXON: I'd like to get the original if 20 I could, your Honor. I could make better copies. 21 THE COURT: Okay. 22 MR. MOXON: Then I could make sure everybody 23 gets -- 24 THE COURT: Okay. Yes, you saw what I was 25 saying -- it was a very light copy, and it didn't come 0848
1 out very well. 2 MR. MOXON: Okay. 3 THE COURT: So I have those here, if someone 4 will remind me I have them. Mr. Howie can read it. 5 Ms. Brooks -- 6 Is it "Brooks" or "Brook"? 7 MS. BROOKS: Brooks. 8 THE COURT: -- Brooks is back with us, so 9 let's go on ahead. 10 MR. LIROT: Thank you, Judge. 11 CROSS-EXAMINATION OF STACY BROOKS (RESUMED) 12 BY MR. LIROT: 13 Q Ms. Brooks, during the break, Mr. Fugate was nice 14 enough to break out the documents we've got into two 15 separate sections, I guess the documents that were provided 16 to Minton and the documents that were provided to you. And 17 what I'll do is I've got about -- it looks like to me like 18 almost three-quarters of an inch. Does this look to be 19 generally the size of the document packet that was provided 20 to you on the 15th? 21 A Well, if there were some that were folded over, 22 it might be. 23 Q Fair enough. All right. I'm going to go ahead 24 and just hand you -- since I just have the one copy, I'm 25 just going to clip them as we go through them. 0849
1 MR. LIROT: Judge, if I could ask for 2 continuing permission to approach the witness? 3 THE COURT: You may, as long as you've got 4 something in your hand. I always tell the lawyers, if 5 you don't have something in your hand, the lawyers -- 6 the witness wonders why you're coming. 7 MR. LIROT: Okay. 8 THE COURT: Having been a witness a few 9 times myself, it's disconcerting if you don't have a 10 document. 11 BY MR. LIROT: 12 Q Ms. Brooks, I've got the first segment of the 13 packet given to me by Mr. Fugate. It appears to be an 14 excerpt of your deposition of April 15th, 2001. Does that 15 look to be one of the documents that you were provided on 16 April 15th by Mr. Fugate? 17 A Possibly. It refers to the secret agreement, so 18 I would say so. 19 Q All right. Well, what does it -- I mean, there 20 is a portion highlighted there, is there not? 21 A Yes. 22 Q All right. What does that question highlighted 23 actually ask? 24 A It refers to the secret agreement, if I knew 25 about it. 0850
1 Q Well, why don't you read me the question. 2 A "Do you have any knowledge" -- well, you want me 3 to edit out all the stumbling? "Do you have any knowledge 4 or do you know what the agreement is between Mr. Dandar and 5 Ms. Liebreich?" 6 THE COURT: I'm sorry, and who? Mr. Dandar? 7 THE WITNESS: Mr. Dandar and Ms. Liebreich. 8 BY MR. LIROT: 9 Q Okay. That doesn't have anything to do with any 10 secret agreement, does it, between LMT and Mr. Minton or 11 the Trust or anything. That's Mr. Dandar and 12 Ms. Liebreich, correct? 13 A Yes, and I didn't include this in my -- 14 Q Okay. 15 A -- affidavit. 16 MR. LIROT: The second one, Judge, actually 17 we took time to make a copy of this one. I'll give a 18 copy to counsel. 19 And, Judge, I'll hand this to the witness. 20 This is a September 7th, 2001, letter, from apparently 21 Teresa Summers to Ms. Brooks, which looked to be the 22 second component of the packet that Mr. Fugate 23 represents was handed over to Ms. Brooks on 24 April 15th. 25 BY MR. LIROT: 0851
1 Q Ms. Brooks, what is this letter from Ms. Summers 2 to you on September 7th, 2001? 3 A It's a letter that I found on my desk on the 4 morning of September 10th, which was a Monday morning, 5 which was also accompanied by another letter in which 6 Ms. Summers quit. And this letter is a very lengthy letter 7 in which she accuses me and Mr. Minton of a number of 8 various criminal acts, things like that. 9 Q Okay. There are a couple paragraphs -- this 10 looks to have been an exhibit to somebody's deposition, 11 although it was cut off. It says, on the bottom of the 12 first page, Defendants' Exhibit Summers. Do you know that 13 this was ever made an exhibit of a deposition or anything? 14 A Well -- 15 THE COURT: Maybe somebody here could help 16 us out. It looks like it. 17 MR. MOXON: It was. Ms. Summers produced it 18 in her deposition. 19 THE COURT: And so this was made an exhibit 20 to her deposition? 21 MR. MOXON: That's correct. 22 THE COURT: Okay. 23 MR. LIROT: And I assume that deposition was 24 taken in this case? 25 MR. MOXON: That's right. 0852
1 BY MR. LIROT: 2 Q Okay. So this is a long letter. And there seem 3 to be two paragraphs. On page 2, the only thing circled 4 there is paragraph No. 2. Did you circle that? 5 A No. It was circled when I got it. 6 Q Okay. And -- 7 THE COURT: When was Ms. Summers' 8 deposition? 9 MR. MOXON: When? 10 THE COURT: M'hum (affirmative). 11 MR. MOXON: I don't know. I can ask Sarah, 12 your Honor. It was about five months ago. 13 THE COURT: Her deposition? 14 MR. MOXON: About five months ago. 15 THE COURT: Oh, five months ago. I thought 16 you said about five minutes ago. 17 MR. MOXON: No. 18 THE COURT: Five months ago, okay. 19 MR. FUGATE: We were busy over lunch. 20 THE COURT: Yes. 21 MR. MOXON: It's a little more, 22 September 5th. 23 THE COURT: September 5th? 24 MR. MOXON: Yes. 25 MR. LIROT: Judge, I think, quite simply -- 0853
1 THE WITNESS: No, it couldn't have been 2 September 5th. 3 MR. LIROT: Well, I'll tell you what, Judge. 4 The documents -- 5 MR. MOXON: Your Honor, October 16th. 6 THE WITNESS: Yes. 7 MR. LIROT: All right. The documents that 8 we were provided actually have excerpts. At least one 9 deposition of Ms. Summers was taken on September 5th 10 of 2001, and there looks to be another deposition 11 taken of Ms. Summers on October 16th of 2001. 12 THE COURT: And then there was a third one? 13 MR. LIROT: And if there was a third one, 14 there is no except in what we were provided. 15 MR. MOXON: That's the third one, your 16 Honor. 17 THE COURT: Pardon me. 18 MR. MOXON: The October deposition was the 19 third. There are three very short versions of her 20 deposition. October was the last one. 21 THE COURT: I was just given 9/5 and 22 then 10/16, so -- 23 MR. MOXON: There's one about -- oh, a year 24 earlier. 25 MR. DANDAR: June 13th, 2001, I took her 0854
1 deposition, the first one. 2 THE COURT: Okay. 3 BY MR. LIROT: 4 Q Ms. Brooks, you told me that the only two -- I 5 guess paragraph 2 and paragraph 7 on this letter were 6 circled. And apparently the letter was provided to you 7 with those circled? 8 A Yes. 9 Q Was it accompanied by any instruction that those 10 are the only issues that were in this letter that needed to 11 be addressed by you? 12 A No, it wasn't -- as I said earlier, the things 13 that were highlighted or circled or whatever, was somebody 14 else's idea of what I might possibly have to include in a 15 recantation. 16 Q Okay. Did you go through this entire document 17 relative to what you were considering to put in an 18 affidavit to recant earlier testimony? 19 A Yes, I did. 20 Q All right. And I guess I'll look at paragraph 21 No. 2, since that one says -- and I'm quoting a letter 22 here. It says your stated purpose of dissolving the LMT as 23 a corporation: 24 So that you and Bob would not have to 25 testify as to financial matters also places me 0855
1 and all of the other staff members at risk. The 2 argument that you just don't want Scientology to 3 know about the finances takes on new meaning in 4 light of Item No. 1. It also brings up the 5 question of the validity of the LMT, if it can be 6 dissolved at once in order to protect you and 7 Bob -- once again, with little care for 8 employees. 9 What importance, if any, did you place on that 10 sentence? 11 A None. 12 Q Okay. And why was the LMT dissolved? 13 A I believe I testified about this earlier. The 14 LMT was dissolved around the same time that I ordered 15 Jesse -- Mr. Minton and I ordered Jesse to withdraw as an 16 expert, that I withdrew as a witness, that Mr. Minton 17 informed Mr. Dandar that he wasn't going to fund the case 18 any longer, and basically we disbanded the LMT in a further 19 effort to try to distance ourselves from this wrongful 20 death case. 21 Q Well, I think your earlier testimony was that the 22 LMT did a lot more than participate in any activity with 23 the wrongful death case. Isn't that true? 24 A That's correct. 25 Q And Ms. Summers did a lot more than participate 0856
1 in the wrongful death case. Isn't that true? 2 A That's correct. 3 Q All right. What about paragraph No. 7? 4 THE COURT: Are we introducing this or is -- 5 MR. LIROT: Yes, I would like to -- 6 THE COURT: -- this an exhibit or what? 7 MR. LIROT: Judge, I'll go ahead and mark 8 it. 9 And I believe we're up to No. 16? 10 THE CLERK: 15. 11 MR. LIROT: 15. 12 THE COURT: So you're referring to -- these 13 references have been to Defendants' -- Plaintiff's 15? 14 MR. LIROT: Yes, Judge. 15 THE COURT: Do you have any objection to 16 this being introduced? 17 MR. FUGATE: No, your Honor. I think for 18 the record that it's my understanding that the 19 circling was done at the deposition, if that makes any 20 difference to anybody. But other than that, I have no 21 objection to it. 22 THE COURT: Okay. Well, I suppose if that 23 becomes important, you can put somebody on for that -- 24 MR. FUGATE: Okay. 25 THE COURT: -- if that's important. 0857
1 THE WITNESS: Your Honor, if I could make a 2 comment? 3 THE COURT: Sure. 4 THE WITNESS: This letter was full of lies 5 and innuendo, which ended up on the Internet, and was 6 the beginning of an unbelievable smear campaign that's 7 going on against us by Ms. Summers and other people 8 who are now part of Mr. Dandar's trial team. And -- 9 THE COURT: Well, we don't need this, so 10 just know you can't get into that. Maybe they'll ask 11 you something about it, and you can answer it. But I 12 don't need that kind of a discourse without a 13 question. 14 MR. LIROT: Well, I'll just ask one final 15 question on the letter. Was there -- 16 THE COURT: That reminds me. I'm getting a 17 couple things in the mail, anonymous. You know, "You 18 might want to see this," some Internet postings. 19 Typically I just would throw those things out. I 20 mean, I wouldn't bog the court file down. I'm happy 21 to put them in the court file. I mean, I don't pay 22 much attention to anonymous stuff off of an Internet 23 Web site. 24 What do you want me to do with it? 25 MR. FUGATE: You're getting them addressed 0858
1 to you -- 2 THE COURT: I got one. It came certified. 3 And, you know, Sue just stamps it in and puts it on my 4 desk. And it was an anonymous letter to me saying, 5 "You might want to read" -- I don't know what it said, 6 to tell you the truth. "You might want to read the 7 following," something about Mr. Hubbard and his -- 8 I'll show it to you all, and you tell me what to do -- 9 I mean, I wouldn't be surprised if I didn't get more. 10 It's not unusual for a judge to get mailings on a 11 high-profile case. I usually just throw them out or 12 file them in the court file. In this case, I normally 13 would just file it in the court file. If that's all 14 right, that's what I'll do. 15 MR. MOXON: One suggestion, your Honor. If 16 you keep the envelope, the post office can trace it 17 and see who is doing it. It's certified. 18 THE COURT: Well, this has an address on it. 19 MR. MOXON: Okay. 20 THE COURT: It's actually an address like 21 Clearwater, as I recall. But I normally put that in 22 the court file too. I mean, I just put the whole 23 thing in the court file. 24 I mean, I guess what I'm trying to say, do 25 you all want copies of this? This is not the kind of 0859
1 stuff that I normally would think my secretary would 2 make copies of. 3 MR. FUGATE: I think for both sides to take 4 a look at as far as -- I don't think -- I mean, 5 there's so much paper in this case. 6 THE COURT: Well, I kind of figured. And 7 nobody would ever know what it was there for. So -- 8 but what I would like to do is just show it to you 9 all, and if you don't have any need for it -- 10 MR. FUGATE: Well, I don't mean to speak for 11 them, but I certainly don't. 12 THE COURT: I will throw it away or file it 13 in the court file. I think I told my secretary just 14 before lunch to make a copy of this so you all can see 15 what I'm talking about. That was the first one I got, 16 but it wouldn't be surprising to me, if this case 17 ended up in trial, that I started getting mail. It's 18 not uncommon. 19 MR. LIROT: Thanks, Judge. 20 THE COURT: What I would really have to 21 worry about is if this was a death penalty case. Then 22 I do have to worry about it, because I have to be sure 23 everybody gets copies. And I put in an order that I 24 have -- you know, that can become bothersome. But in 25 a case like this -- anonymous Internet postings. 0860
1 Worse than whatever it is they could send me, I 2 suppose. 3 Continue on. 4 BY MR. LIROT: 5 Q Ms. Brooks, on the first page of that letter, I 6 guess Ms. Summers talks about in paragraph 1, or at least 7 the No. 1, it says, "The revelation in your recent 8 deposition of $800,000 that was donated to the LMT from 9 foreign sources and then every penny of that money was 10 delivered to Bob Minton is difficult to make sense of." 11 Down at the bottom, it continues to say, in the 12 next full paragraph, "I cannot make sense of this. If Bob 13 was the sole source of LMT funding and our salaries came 14 from the LMT account, how then can he be given $800,000 15 from this account and then turn around and claim there's no 16 money to pay our salaries?" 17 What does that refer to? Did Mr. Minton take 18 $800,000 out of the LMT account? 19 A No. 20 Q Was there a period of time that you gave 21 Mr. Minton money out of the LMT account? 22 A Yes. 23 Q Okay. Can you tell me how much that was? 24 A $800,000. 25 Q Okay. And what was that for? 0861
1 A It was to repay monies that he had put into the 2 LMT. 3 Q Was this -- was it hidden by you at some point 4 that all the money had come from Mr. Minton? 5 A I wasn't aware of it at that point. 6 Q Did you ever recant that statement anywhere else? 7 A That's already come up in this testimony. And 8 that was done. 9 Q Was there anything else in Ms. Summers' letter 10 that you felt appropriate to put in your two affidavits 11 recanting earlier testimony? 12 A No. 13 Q So you looked at this and said, "I've got this 14 one handled. Let's go on to the next one"? 15 A I looked at this and gave it the legitimacy that 16 it was due. 17 Q All right. The next document in that packet 18 appears to be an excerpt from a videotaped deposition of 19 you individually on September 7th of 2001. And again, that 20 document was given to me with the highlighted portions just 21 as they are. 22 THE COURT: What -- are you marking this? I 23 mean, we need a record here. Is this a number? 24 MR. LIROT: Judge, I'll go ahead and we'll 25 put this entire packet in as Plaintiff's Exhibit 0862
1 No. 16. I don't have any copies of it. We just got 2 it this morning, and I only had time to make a few 3 copies of some of the things that I thought were more 4 interesting. 5 THE COURT: Well, why don't you make it then 6 a composite exhibit? 7 MR. LIROT: I will do that, Judge. We will 8 make this Plaintiff's Composite Exhibit No. 16. 9 MR. WEINBERG: Well, is the letter -- is 10 Ms. Summers' letter part of that composite -- 11 MR. LIROT: We'll make -- we'll make 12 Ms. Summers' letter a part of that. If you would like 13 to renumber -- 14 MR. WEINBERG: Why don't we just make it a 15 Composite Exhibit 15? 16 THE COURT: 15, and Ms. Summers' letter will 17 be part of it. 18 MR. LIROT: Very good, Judge. 19 THE COURT: And I'll count on you making a 20 copy to the clerk and keeping your copy. 21 MR. LIROT: Very good. 22 THE COURT: If you think I need it for 23 whatever reason, why, you can make me a copy as well. 24 BY MR. LIROT: 25 Q Now, describe to me that next item. You 0863
1 obviously -- I'm going on the belief that you looked at all 2 these documents that were provided to you and that you used 3 these to analyze -- to in fact comply with your desire to 4 make the record straight. Right? 5 A This was part of what I used. 6 Q Okay. What is the -- what's the information in 7 that particular -- I guess what I'll -- I guess this will 8 be Composite Exhibit 15, Sub C, we'll call this. And we'll 9 call the first -- the first excerpt A, Ms. Summers' letter 10 is B, and this will be 15C. 11 MR. WEINBERG: Your Honor, I just ask for -- 12 if we're going to do that, if we could go back to A 13 and just identify what pages, at least, of the 14 deposition there are so the record is clear. And then 15 on C, just -- because these are excerpts -- what pages 16 there are in the deposition that are in front of her. 17 I think that would be useful. 18 These are not the entire depos, I don't 19 believe, are they? 20 MR. LIROT: No. 21 THE COURT: I think the only thing this is 22 being put in the record for is just to show what she 23 was given, so -- 24 MR. WEINBERG: And just for the clarity of 25 the record, I would ask -- 0864
1 THE COURT: Whose deposition and what date? 2 Maybe you could tell us the pages. 3 THE WITNESS: Okay. This is the cover page, 4 page 1 -- 5 THE COURT: Right. 6 THE WITNESS: -- deposition of Stacy Brooks, 7 August 15th, 2001, 1:35 p.m. 8 THE COURT: Pages? 9 THE WITNESS: Page 1, page 49, page 93, 94, 10 95, and 149. 11 THE COURT: Thank you. 12 Is that what you wanted? 13 MR. WEINBERG: Yes. And each time we go 14 through a transcript, if we could do that. 15 THE COURT: Yes. 16 MR. WEINBERG: That would be useful. 17 MR. LIROT: I'll do that, Judge. 18 BY MR. LIROT: 19 Q So C would be your deposition of September 7th, 20 2001. And I don't have that copy. Can you tell the Court 21 what pages I've handed you that were part of this packet 22 provided to me. 23 A Page 1, page 40, and the reporter's deposition 24 certificate page. 25 Q And what was it that you reviewed in that 0865
1 document that had any impact on the affidavits recanting 2 testimony that you offered? 3 A There was a document that Mr. Minton received 4 from Mr. Dandar. And Mr. Dandar had told Mr. Minton not to 5 tell anyone that he had gotten it from Mr. Dandar. And so 6 when I was asked, "Do you know" -- well, it says, "Do you 7 aware [sic] Mr. Minton got this report," but I think it 8 meant to say, "Do you know where Mr. Minton got this 9 report?" 10 And I said, "No. That was false." 11 So in my first recantation affidavit, it's 12 covered in Point B on page 2. 13 Q Okay. Do you know what the document was that you 14 referred to? The document in your recant affidavit. 15 A Oh. Yes. It was a report written by Brenda 16 Hubert concerning Lisa McPherson. 17 THE COURT: Report written by whom, ma'am? 18 THE WITNESS: A woman named Brenda Hubert. 19 THE COURT: Oh, that's that thing? 20 MR. FUGATE: That's the Brenda Hubert 21 knowledge report -- 22 THE COURT: Knowledge report, okay. 23 THE WITNESS: Right, the knowledge report. 24 BY MR. LIROT: 25 Q How was it that you were made aware of that 0866
1 document? 2 A Mr. Minton told me he had it. 3 Q Anything else? Did he tell you how he got it? 4 A I just said he told me he got it from Mr. Dandar. 5 Q Fair enough. 6 The next one I have is Composite Exhibit 15D, 7 which is an excerpt of the videotaped deposition of Stacy 8 Brooks of June 23rd, 2000, and pages -- 9 THE COURT: How many depositions did you 10 have to give? 11 THE WITNESS: Many, many, many. 12 THE COURT: Wow. Maybe I should add you to 13 the list of the ones that probably had too many 14 depositions taken. 15 THE WITNESS: I was hoping you would do 16 that, your Honor. 17 THE COURT: I'm sorry, I thought you only 18 had one, so -- 19 THE WITNESS: No, your Honor. 20 THE COURT: Well, then I'll add you to the 21 list as well. If you were deposed in two separate 22 cases about the same thing, that shouldn't have been 23 allowed to happen. And that's the fault of either me 24 or Judge Baird or both of us, but I'm not sure we were 25 exactly understanding that this was happening on both 0867
1 ends of the county. Certainly I was not. And I 2 apologize to you. That should not happen. 3 THE WITNESS: Thank you, your Honor. 4 BY MR. LIROT: 5 Q All right. Ms. Brooks, just to make the record 6 clear, this is 15D, June 23rd, 2000 -- 7 THE COURT: And so that's clear, I'm not 8 being critical of counsel here. There are separate 9 counsel involved in these cases. But the deal is that 10 we shouldn't have witnesses coming in, take -- have 11 long depositions being taken about the same 12 information, when really they should be -- two lawyers 13 ought to be able to be there at the same time, one of 14 them ask questions, somebody else listen in, and the 15 deponent inconvenienced one time. 16 And I'm sure if Judge Baird and I had 17 realized that this was happening, he and I, one or the 18 other, would have said, well, you know, we're not 19 going to have this. It's not fair to the folks. 20 I can only assure you I really didn't 21 realize that this was happening. At least if I did, 22 I'm not aware of it. So that's what I was referring 23 to. And I'm sure Judge Baird would feel the same way. 24 One person to be deposed, there's two lawyers, well, 25 you tell the lawyers to consolidate these things, take 0868
1 them together. 2 I'm not suggesting if only one is there that 3 the other doesn't have a right to take a deposition. 4 We don't normally put witnesses through duplicate, 5 very lengthy depositions. 6 MR. LIROT: We certainly acknowledge that, 7 your Honor. 8 BY MR. LIROT: 9 Q What I'm referring to here is 15D, June 23rd, 10 2000. And just for the record, it says here, "Do you know 11 if Mr. Minton" -- I guess I'll give the page numbers. It's 12 the cover page, page 126, and then the certificate page of 13 146. 14 And the question here was whether or not 15 Mr. Minton provided any money to Dell Liebreich. Your 16 answer was: "I don't know." 17 The question was: "Do you know if there's any 18 agreement with Dell Liebreich and Mr. Minton with respect 19 to the potential proceeds of this case?" 20 Your answer was: "Well, that's been discussed, I 21 know that." 22 Then question, which isn't a question: "It 23 certainly has." 24 And then Mr. Bolt says: "Now, that's a yes or no 25 question, Ms. Brooks." 0869
1 And the answer was: "To be honest, I'm not 2 sure." 3 Now, this was in June of 2000, and I'll hand that 4 to you so you can look at that. And that was part of the 5 packet that was provided to you relative to the affidavits 6 that you prepared to recant earlier testimony. And I think 7 it's pretty clear that you used that in some fashion to 8 recant earlier testimony in some of your affidavits, right? 9 MR. FUGATE: Your Honor, I object to that as 10 testifying. And also for point of clarification, I 11 think the entire -- the entirety of the depositions 12 were also provided. So this is somewhat confusing, 13 and I don't know -- 14 I don't want to interject myself into the 15 cross, but don't you have copies of each of her 16 depositions as well, as well as the highlighted 17 portions? 18 MR. LIROT: We don't know what you gave her. 19 That's only what we're going by. 20 MR. FUGATE: Judge, I'll go back and -- 21 THE COURT: Okay. 22 MR. FUGATE: -- let the submission, but I do 23 object to the testifying. 24 THE COURT: That would be sustained. 25 BY MR. LIROT: 0870
1 Q Well, I guess my question was, Were these 2 excerpts given to you, or did you get the entire 3 depositions for those dates? 4 A I believe I had more than this, for sure. 5 MR. LIROT: Well, then, Judge, I need some 6 clarification. Is counsel's position that the whole 7 deposition was given to Ms. Brooks and that just these 8 highlighted portions were given to us? 9 MR. FUGATE: Judge, I'm confused because I 10 don't know what's over there now. I know that the 11 request was both to both counsel for Ms. Brooks and 12 counsel for Mr. Minton for the entire depositions. 13 And as I sit here, I know that all of Mr. Minton's 14 depositions were given to him. I do believe -- and I 15 thought Ms. Brooks' were. If we need to give those in 16 their entirety to them, we will. But Mr. McGowan can 17 clear that up. If we only gave excerpts, we only gave 18 excerpts. 19 Do you remember? 20 MR. McGOWAN: Your Honor, I believe that 21 there were excerpts, but I believe separate from the 22 excerpts were the entire depositions. 23 THE COURT: So but there were excerpts? 24 These were excerpts? 25 MR. McGOWAN: There were excerpts, and then 0871
1 there were depositions. 2 THE COURT: Okay. 3 MR. LIROT: And, Judge, I think we requested 4 the excerpts. We were interested in what was 5 highlighted. That's what we were interested in. 6 THE WITNESS: Yes. That's what I'm looking 7 at here, just this highlighting. 8 THE COURT: Okay. 9 BY MR. LIROT: 10 Q The next document I'm going to hand to you is 11 apparently a notice of filing plaintiff's witness list, 12 which appears to be an April 17th, 2000, witness list in 13 the wrongful death case when it was still in Hillsborough 14 county. And it looks like the only highlighted portion 15 here is the name Teresa Summers. What significance would 16 that have being placed in this packet? 17 A Well, it was my understanding -- and I'm going to 18 refer to documents that you haven't yet put in evidence 19 that should be in your package. It was my understanding 20 that the reason this was included was that there was 21 testimony by me in another excerpt, which we haven't talked 22 about yet, about whether or not I knew Teresa Summers or 23 something. And I can't remember exactly, and I'd have to 24 look at it again. But there was -- clearly, someone had 25 thought that I was -- that I had lied about my knowledge of 0872
1 Teresa Summers in some way. But I did not include this 2 because I didn't feel that that was the case based on the 3 dates of the various documents that I reviewed. 4 Q Okay. Well, this might clear it up. I guess 5 Composite Exhibit 15 Sub F appears to be the cover page or 6 at least page 4 of Ms. Summers' deposition of June 13th of 7 2000. And just the -- I guess the next page is page 5, and 8 it just has one page of her direct examination. And 9 there's nothing highlighted on this. Does this refresh 10 your memory as to the significance of those documents? 11 A I believe I was given more than this, but -- 12 Q I think you were too, actually. I see what I'll 13 call Exhibit 15G. It appears to be the deposition of Stacy 14 Brooks from June 23rd of 2000 -- oops. And it's the cover 15 page, and then pages 254, 255, and then the signature page 16 of 283. Let me hand you that, because it looks like 17 there's certain questions asked of you regarding 18 Ms. Summers' in this excerpt. 19 MR. WEINBERG: I don't think he said it, but 20 the presumption is that 15E was little witness list. 21 Is that what he said it was? 22 MR. DANDAR: Yes, that's what he said it 23 was. 24 MR. LIROT: Yes. 25 A Okay. I should probably read this to the Court 0873
1 so that she can understand what I'm about to say. 2 THE COURT: Okay. 3 THE WITNESS: The highlighted part: 4 The question: "Teresa Summers, you claim, 5 has come to you?" 6 And my answer, "Is she a witness? She has 7 contacted us. We did not contact her." 8 THE COURT: Maybe I don't -- that's -- 9 THE WITNESS: It's to the LMT. 10 THE COURT: Oh, okay. 11 Has come to you as an employee -- oh, this 12 is to be taught -- in other words, LMT, you told me 13 the other day that one of the things that LMT did was 14 to counsel people -- 15 THE WITNESS: Yes. 16 THE COURT: -- who left the Church. 17 THE WITNESS: Yes. 18 THE COURT: Is that what you're talking 19 about? 20 THE WITNESS: Yes. 21 THE COURT: Okay. 22 THE WITNESS: And the question was: "When 23 was this?" 24 Answer: "Recently." 25 And then question: "When?" 0874
1 And then my answer: "You know, this is 2 going to get this girl in trouble. I don't like 3 this." 4 And then the counsel said: "She's 5 testified." 6 And then Mr. Dandar said to me: "We've 7 already deposed her. She's been deposed." 8 And then I say: "Oh, okay." And then: "So 9 what's the question?" 10 And the question: "When did you talk to 11 Teresa Summers?" 12 And the answer: "I haven't talked to Teresa 13 Summers. I haven't talked to Teresa Summers." 14 And the question: Who talked to Teresa 15 Summers in the LMT?" 16 And my answer: "Nobody. She sent an e-mail 17 or maybe a letter." 18 And question: "When? When?" 19 And the answer: "Actually, I think she sent 20 it -- well, it was to Jesse, and it was received maybe 21 two days ago." 22 Okay. So that was the testimony. And I 23 believe that someone -- or, I thought at the time that 24 someone may have thought that I was lying about not 25 knowing her at that time, but in fact what I said was 0875
1 true -- 2 BY MR. LIROT: 3 Q Okay. 4 A -- because -- well, it was true. 5 Q Okay. Composite Exhibit 15H is an excerpt of 6 Ms. Summers' deposition of September 5th, 2001, with a 7 cover page, pages 36, 37, and the signature page of 8 page 105. And I guess there are only two questions. There 9 on page 36, they ask about Ms. Summers having worked for 10 the LMT, and the other question is about Ms. Summers making 11 complaints about the Church. And I'll hand you this. 12 THE COURT: I thought she was a consultant. 13 No. Was this somebody else? 14 MR. DANDAR: This is a former Scientologist. 15 THE COURT: Oh, okay. 16 MR. DANDAR: Not retained by the plaintiff. 17 THE WITNESS: But on his witness list. 18 THE COURT: Okay. 19 THE WITNESS: On the plaintiff's witness 20 list. 21 THE COURT: Well, was she the one -- I 22 remember when you were going through, at somebody's 23 request, a group of people who had worked for LMT -- 24 THE WITNESS: Yes. She was one of them. 25 THE COURT: -- and one of them in particular 0876
1 you said had really done a lot of work and done 2 some -- 3 THE WITNESS: Yes. That was Teresa Summers. 4 THE COURT: Okay. That's where I heard the 5 name then. 6 THE WITNESS: Do you want me to read the 7 highlighted part every time? 8 THE COURT: I don't. 9 THE WITNESS: Okay. 10 MR. LIROT: No. 11 THE COURT: I'm not saying -- if counsel 12 wants you to, but . . . 13 THE WITNESS: Okay. 14 BY MR. LIROT: 15 Q Now, I take it that the explanation there about 16 your knowledge of Ms. Summers coincides with the dates of 17 that excerpt. Is that correct? 18 A I'm sorry, I -- say that again. 19 Q You said that you had not said anything 20 untruthful about your knowledge -- 21 A Oh. 22 Q -- or relationship with Ms. Summers at the LMT, 23 and they speak about dates in that certain highlighted 24 section. 25 A Right. 0877
1 Q So that's consistent with you? 2 A Yes. This was September 5th, 2001 -- 3 Q Right. 4 A -- and this is Teresa's deposition on 5 September 5th, 2001. 6 Q And that's her deposition. So obviously you 7 don't know what she testified to. That's just some point 8 of reference for you, right? 9 A Right. 10 Q All right. The next sub exhibit I have is 15I, 11 and this is an excerpt from the September 7th, 2001, 12 deposition of Stacy Brooks as representative of the Lisa 13 McPherson Trust. And this is page 1, the cover page; 14 page 60; page 107; page 108; and then the signature page. 15 And I'll hand this document to you. There looks 16 to be only two things about -- one being the LMT office 17 being operated out of Mr. Dandar's office, and I think you 18 already testified to that. Wasn't it true that the only -- 19 the only thing she did at Mr. Dandar's office was try to 20 find office space for the LMT, make phone calls from there 21 for a little while? 22 A Well, we operated out of -- yes, it is true to a 23 certain degree. We did operate out of Mr. Dandar's office 24 until we had our own office. So part of what I was doing 25 was -- you know, Mr. Dandar let us work out of his office 0878
1 to find our office. 2 Q Okay. And there was something else in that 3 segment about a check going to Mr. Spector? 4 A Yes. 5 Q Do you know who Mr. Spector is? Can you tell the 6 Court? 7 A He's been in the courtroom, your Honor. He's 8 Mr. Dandar's videographer and a private investigator who 9 works for Mr. Dandar. 10 Q And I think the question was, Did the Lisa 11 McPherson Trust ever pay Mr. Spector for anything? 12 A Right. And I said I don't think so. 13 Q And then I think -- 14 A But I had to correct that in my first recantation 15 affidavit because I found a check for $168. 16 Q Right. Well, we'll call that Exhibit 15J. And 17 that looks to be, at least to some extent -- a little bit 18 bad copy -- but at least a copy of the check to Mr. Spector 19 for $168? 20 A Correct. 21 THE COURT: From LMT? 22 MR. LIROT: Pardon me? 23 THE COURT: From LMT? 24 THE WITNESS: From LMT, yes, your Honor. 25 BY MR. LIROT: 0879
1 Q What was that check for? 2 A As I recall, it was for a copy of a videotape of 3 one of my depositions. I think that's what it was for. 4 THE COURT: Did the Church have the LMT 5 checks? 6 THE WITNESS: Yes, your Honor. 7 THE COURT: Have those been produced at some 8 time? 9 MR. DANDAR: Deposition (nodding 10 affirmatively). 11 THE COURT: Okay. So these were some checks 12 pursuant to a request to produce? 13 MR. DANDAR: At the deposition of the bank. 14 THE COURT: Oh, okay. One of those ones 15 that says if -- in other words, they give you the ten 16 days to object, and if you don't object, then the 17 people send the -- 18 MR. DANDAR: No -- 19 THE COURT: -- documents. There's no -- no, 20 this is a deposition. 21 MR. DANDAR: It's a real deposition. 22 THE COURT: Okay. Because there wasn't 23 anything wrong with it. That check was given 24 pursuant -- 25 THE WITNESS: Yes, your Honor. 0880
1 THE COURT: -- to the work that had been 2 done by him -- 3 THE WITNESS: Oh. 4 THE COURT: -- for LMT -- 5 THE WITNESS: Yes. 6 THE COURT: -- for you or -- 7 THE WITNESS: Yes. 8 THE COURT: But you had said you didn't 9 think so and -- 10 THE WITNESS: Right. 11 THE COURT: -- you were just correcting your 12 testimony. 13 THE WITNESS: Yes. 14 THE COURT: Okay. 15 BY MR. LIROT: 16 Q All right. Ms. Brooks, the next one will be 15K, 17 which appears to be excerpts of your deposition of 18 August 15th, 2001. And it has the cover page, page 1; 19 page 62; page 63; page 72; and then the signature page, 20 149. And there look to be two -- two areas highlighted 21 here. One highlighted is a question. It says: "You have 22 no statements of any, slash, no written statements by any 23 of the witnesses in this case?" 24 And your answer was: "No." 25 And then there's another highlighted part. It 0881
1 says -- your question was -- or, your answer, I guess: 2 "Why not? I don't have any reason to have any statements 3 by witnesses. I'm not involved in this case." 4 What was there you needed to recant about that? 5 Did you review those particular excerpts? 6 A Can I see that one? 7 Q Yes, you can. There was a lengthy part I want to 8 get to, but I guess I'll retrieve it back after you answer 9 the first part of my question. 10 THE COURT: I think if that's your only copy 11 you'd better make sure you get all that stuff back if 12 you're going to copy it for the clerk. 13 A Okay. Sorry. 14 BY MR. LIROT: 15 Q I haven't gotten to the second part yet, just 16 about the witness statements. Anything there that you were 17 made aware of that you needed to recant? 18 A Yes. 19 Q Okay. What was it in that particular statement 20 that you had to set the record straight on? 21 A Well, this was a document production line of 22 questioning. And this is -- I need a few pages earlier, 23 but I believe this was referring to the unedited videotape, 24 either the unedited videotape or information -- or data on 25 our hard drives. And I did have to inform the Court that 0882
1 the hard drives were removed and they've now been turned 2 over to the special master. And the unedited videotape 3 also needs to be turned over to the special master. 4 Q Okay. 5 THE COURT: I kept reading about this in 6 this series of orders signed by the judge. I don't 7 even know what they are. 8 MR. McGOWAN: I do. There were a series 9 of -- I don't know how many. They were unedited 10 videotapes at the LMT. My understanding is -- 11 THE COURT: Unedited what? 12 MR. McGOWAN: Videotapes. Of what, I don't 13 know. 14 THE WITNESS: I can explain. 15 THE COURT: Okay. 16 MR. McGOWAN: But there was a body of 17 videotapes that existed. They were removed from the 18 LMT, my understanding it is, by John Merrett. 19 I have made numerous attempts to contact 20 Mr. Merrett and get those back. He was supposed to 21 call my office today. As of the lunch break, he had 22 not. We were trying to retrieve those to get them 23 into the hands of the special master. What is on 24 those, I have no idea. 25 THE COURT: Okay. Ms. Brooks, what are 0883
1 they? 2 THE WITNESS: Well, in fact the entire body 3 of unedited videotapes is the property of our 4 videographer, whose name is Mark Bunker. And a lot of 5 the unedited videotapes are things that he videoed 6 before he was doing anything with the LMT at all. But 7 some of the unedited videotape is of -- you know, it's 8 picket footage. I'm not sure what else it is, but it 9 has to do with Scientology in some way. 10 And the history of the discovery on this, to 11 my understanding is that at first Judge Moody -- and I 12 may be wrong about this, but this is my recollection. 13 At first Judge Moody had limited what should be turned 14 over just to statements by witnesses on the list. And 15 then somehow or another it got expanded to being 16 anything at all about Scientology, or at least that 17 was my understanding. And so -- 18 THE COURT: Not said by a witness in this 19 case -- 20 THE WITNESS: Right. 21 THE COURT: -- but just any old body -- 22 THE WITNESS: Said by anybody. 23 THE COURT: Well, that would have been too 24 broad, most likely, of an order, but -- 25 THE WITNESS: Well, but it was the order -- 0884
1 THE COURT: Okay. 2 THE WITNESS: -- as far as I know. So, you 3 know, unfortunately, I felt that it was too broad of 4 an order, and I took it upon myself not to comply. So 5 that was the wrong thing to do. So now we're trying 6 to get the videotape back. 7 And then what we'll have to do, I think, is 8 have Mark Bunker come down here and work with the 9 special master to go through each reel of unedited 10 videotape to identify which -- which ones are relevant 11 to this proceeding and which ones really are not. 12 MR. FUGATE: Does that mean if you get them 13 back from Mr. Merrett -- I hate to interrupt. 14 But you don't have them, right? 15 MR. McGOWAN: No. 16 THE COURT: Mr. Merrett was quite a prize. 17 He was the one that used to appear by phone -- 18 MR. FUGATE: Yes. 19 THE COURT: -- and on what I would consider 20 to be some fairly important matters. And to me, it's 21 difficult to deal with a lawyer on important matters 22 over the telephone. 23 But if you're suggesting -- and I don't 24 know, somebody better contact Mr. Merrett, because if 25 Mr. Merrett, knowing that there was a court order that 0885
1 said there was something to be produced -- and I 2 already heard Ms. Brooks say that Mr. Merrett said 3 leave them in the hallway, and didn't show up. 4 Mr. Merrett might find himself in some difficulty. 5 So Mr. Merrett most likely, would be my 6 guess, isn't going to have those videotapes. He's not 7 going to know what you're talking about. Maybe I'm 8 wrong. But I don't know. I just imagine that's why 9 you haven't heard from him. 10 MR. McGOWAN: I have actually heard -- 11 THE COURT: He, by the way -- he, by the 12 way, is, as I said -- just all I can say is quite a 13 character. I mean, and I'm not saying that -- he just 14 walks to a different drummer. 15 MR. McGOWAN: Your Honor, with -- in hopes 16 that he would comply, in hopes that your Honor was 17 wrong about that, it was my intention to give him 18 today to do that, or at least to turn them over, and 19 if I didn't hear from him today I would get either a 20 subpoena or court order and we'd bring it to the 21 Court's attention. 22 THE COURT: Okay. 23 MR. McGOWAN: Hopefully, that won't be 24 necessary. If it is, it is. 25 THE COURT: Well, as you know, as I said, 0886
1 I'll be happy to command Mr. Merrett to appear in 2 court with anything that he took that was ordered 3 turned over by the Court and he said put out in the 4 hallway and just whisked them away. But I'm betting 5 you, he won't show up with a box for us. 6 MR. McGOWAN: Well, your Honor, I'm still 7 struggling for phone numbers. But I would -- 8 MR. DANDAR: Judge, the plaintiff would love 9 for you to issue an order to have him appear in court 10 this week. 11 THE COURT: Well, you know, as I said, 12 Mr. Merrett has never -- luckily, Mr. Merrett 13 practices in Jacksonville, and I don't have to deal 14 with Mr. Merrett very often. 15 MR. DANDAR: But I have to deal with him. 16 THE COURT: I guess I was just traveling -- 17 this was another Court's problem. My guess is he 18 knows what's going on here and what is being suggested 19 about these tapes. I don't know, but I expect that if 20 he ever had them, they were deep-sixed somewhere and 21 he's never going to admit it. This is my guess. Now, 22 I could be wrong. 23 THE WITNESS: I don't think so. 24 MR. DANDAR: Would you let him appear by 25 phone? 0887
1 THE WITNESS: I think he'll produce them. 2 He's out of town. 3 THE COURT: Oh, okay. 4 MR. DANDAR: Judge, would you let him appear 5 by phone? 6 THE COURT: No, I absolutely will not. 7 MR. DANDAR: All right. I mean -- 8 THE COURT: I mean for what? How can he 9 bring something by the telephone? 10 MR. DANDAR: Well, he can tell you what it 11 is and where it is and why he hasn't produced it and 12 also testify in reference to the allegations 13 Ms. Brooks has made against him. 14 THE COURT: Well, he can -- what's wrong 15 with this man? Something like this, his -- his 16 practice of law has been challenged. You mean he's 17 just too damn arrogant to get in the car and come down 18 here and defend himself or -- 19 MR. DANDAR: That I can't answer. 20 THE COURT: Well, that's what I sure would 21 do if I were a lawyer and I had these kind of 22 accusations being made. I would either -- I would 23 either -- but I wouldn't say: Gee, Judge, if you 24 don't mind again, once again, let me just appear on 25 the telephone. That's good enough for you. 0888
1 So, yes, I'll let him appear by phone, and 2 if his credibility is at issue, I guess I'll just have 3 to guess. 4 MR. DANDAR: (Gestured.) 5 MR. LIROT: Well, I guess -- 6 THE COURT: I don't think he served his 7 client very well, what he would be appearing on, what 8 I perceived his client must have thought were some 9 fairly important matters. Over a telephone, it's 10 difficult to -- you do the best you can. But, I mean, 11 what happens is lawyers are talking and the judge 12 wants to interrupt or the other side does, and the 13 next thing you know they're still prattling. They've 14 been prattling, and you don't know even know what they 15 said. It's just not a very good way to do business in 16 an important matter. 17 I suppose Mr. Minton was paying him well, 18 and Mr. Minton would probably have paid him to come 19 down and represent him. That didn't seem to be a very 20 good thing for him to do. If he was too far away, 21 then he probably needed to retain local counsel to 22 come in. 23 BY MR. LIROT: 24 Q With that as an introduction, Judge. On page 72, 25 the question posed to Ms. Brooks: 0889
1 Question, it says: "I just want to make it very 2 clear then -- correct me if I'm wrong -- your testimony is 3 that there's not a single piece of paper in the LMT 4 building which is a statement by you or Minton or Prince 5 concerning Scientology, concerning any issue in this case, 6 or concerning Lisa McPherson. Correct?" 7 Your answer, Ms. Brooks, was: "That's correct. 8 The only place anything exists like that are in John 9 Merrett's files, which are his files." 10 Question: "So you gave some files to 11 Mr. Merrett?" 12 Answer: "Well, he -- he is in charge of all of 13 our legal files, and they have -- I believe they probably 14 have -- well, to be honest, I don't know if they do or not. 15 I asked Mr. Merrett if there was anything in his files 16 responsive, and he said no. Other than that, you know, 17 said, 'Anything in my files is a attorney work product or 18 attorney/client privilege.'" 19 Question: "So there might be some documents, but 20 you consider them to be privileged?" 21 Answer: Well, what he told me is that they were 22 legal documents and that wasn't something that I needed to 23 be concerned about in this document production." 24 And that's the conclusion of that, so I think in 25 your affidavit you put something to the effect of 0890
1 Mr. Merrett being an extension of Mr. Dandar? 2 A Not by this point. By this point, we were 3 extremely alienated from Mr. Dandar, and the relationship 4 had changed. 5 THE COURT: Between you all or between 6 Mr. Merrett and Mr. Dandar? 7 THE WITNESS: Well, Mr. Merrett representing 8 us; therefore, his relationship had changed as well. 9 BY MR. LIROT: 10 Q The next document I have is Sub Exhibit K, and 11 this is a videotaped deposition of Stacy Brooks from 12 September 7th, 2001. I have the cover page 1 -- 13 THE COURT: Maybe I'm all wet here. Did I 14 not -- did I not read in an affidavit where somebody 15 alleged that Mr. Merrett said, about something that 16 was compelled or supposed to be delivered at a 17 deposition, "Just leave it outside and I'll take care 18 of it"? 19 MR. FUGATE: Yes. 20 THE COURT: Who said that, Ms. Brooks? 21 THE WITNESS: I think I said that, your 22 Honor. 23 MR. FUGATE: And that's in reference to the 24 videotapes. 25 THE COURT: That's in reference to the 0891
1 videotapes. And then they disappeared, never to be 2 seen again. And this lawyer knew that they were 3 supposed to be produced. And this lawyer said, "Leave 4 them out in the hallway, and they'll be gone"? And 5 he's going to come in and tell me that and say, "Here 6 they are, and I whisked them away so she wouldn't 7 produce them"? Well, good for him. 8 MR. LIROT: Oh, did I publish -- I'm sorry, 9 this is L. 10 BY MR. LIROT: 11 Q All right. September 7th, 2001, will be Sub 12 Exhibit 15L, and Ms. Brooks' deposition from September 7th 13 of 2001, on page 1, I have page 78, and I have the 14 signature page. And this deals with destruction of records 15 from LMT. And I'll go ahead and hand you that, Ms. Brooks. 16 And I'll ask if you reviewed that in preparing your 17 affidavit. 18 THE COURT: What is that, Counselor? 19 MR. LIROT: Judge, this is the -- an excerpt 20 from Ms. Brooks' deposition of 9/7/01, September 7th, 21 2001. And they're asking her questions about the 22 destruction of some documents at the LMT. 23 BY MR. LIROT: 24 Q And I'll go ahead and ask you, for the Court's 25 edification, just to read what the questions and answers 0892
1 are on that page. 2 THE COURT: What does it say on the front, 3 did you say? 4 MR. LIROT: It's the cover page of her -- 5 it's a videotape -- it's a transcript of a videotaped 6 deposition from September 7th, 2001, of Stacy Brooks. 7 A Do you want me to read the highlighted part? 8 BY MR. LIROT: 9 Q Sure. Please. That's what I've been focusing 10 on. 11 A Question, by Mr. Moxon: "Just to clarify one 12 point you've mentioned here, since May of 2000, you 13 periodically destroyed all e-mails to and from Mr. Prince, 14 yourself, Mr. Minton, Mr. Jacobsen, Mr. Bunker, and 15 Ms. Summers that came into LMT computers?" 16 Answer: "Correct." 17 Question: "You also did that since July, 18 obviously, right?" 19 Answer: "As I said, we have a policy --" 20 Question: "Yes." 21 Answer: "-- that we do not retain records." 22 Question: "Okay. The answer is yes, you 23 destroyed everything from May to the present, and you did 24 it periodically?" 25 Answer: "Yes. Shall I read my declaration into 0893
1 the record about it?" 2 BY MR. LIROT: 3 Q Okay. Did you have such a policy? 4 A Yes. 5 Q And what was that policy? 6 A Well, our security person, whose name is Grady 7 Ward, instituted a policy with everybody, which he 8 communicated to them via several e-mails -- a whole 9 procedure that the people were supposed to follow to 10 maintain the security of their records. 11 Q And what did that have to do with destroying 12 records? 13 A Well -- 14 THE COURT: Well, deleting them. Are you 15 talking about e-mails now? 16 THE WITNESS: Yes, your Honor, I am. 17 (The Court's judicial assistant, Mrs. Rudd, 18 entered the courtroom and spoke to the Court 19 off the record.) 20 THE COURT: Excuse me. 21 Give me just a second here. 22 For the information of the people -- I'm not 23 going to tell you who this is from, but this is 24 something from the person who apparently sent the 25 materials to me in the mail, who is most distressed 0894
1 that I was going to give those up. But I must admit, 2 I'm wondering whose -- I mean -- 3 THE WITNESS: How does he know? 4 THE COURT: I don't know. 5 MR. WEINBERG: Maybe you could do something 6 of a side bar, your Honor. 7 THE COURT: Well, I really can't, because 8 this is somebody is that very frightened of my giving 9 this information to counsel and indicating that she's 10 got children and she's a sitting duck and on and on. 11 And I don't know what to do with it, to tell 12 you the truth. I just am not used to getting 13 something delivered to me in the middle of a hearing. 14 Obviously, my secretary must have thought it was 15 rather important, so I'm going to take just about five 16 minutes and reflect on it, and then I'll let you all 17 know what I'm going to do with it. 18 Anybody that's here, don't send me stuff 19 unless you want me to put it in the court file. 20 That's what I do with stuff. I don't do ex parte 21 stuff. If somebody sends me stuff, it goes in the 22 court file. 23 (A break was taken at 3:05 p.m. until 24 3:22 p.m.) 25 THE COURT: Okay. I think what -- I'll put 0895
1 this in an envelope, which I'll put it back in. The 2 fear of this person, apparently, was that this 3 certified -- I mean, it always amazes me, somebody 4 sends me certified mail -- which means, in other 5 words, they know that I've got it and now -- I don't 6 know what they thought I was going to do with it. 7 Somebody is going to come along years down the road 8 and say, "What did you do with that? I don't know 9 what you're talking about." 10 They paid $9 to have this delivered to me. 11 As I say, it is a -- it's talking about some gloating 12 Internet posts made on April 7th, transferred from 13 www.altreligion-.scientology.org to www.xenu.net. 14 It says: "While there's no way to know for 15 certain who made them," I could only have -- "it could 16 only have been by someone very close to the McPherson 17 case, with intimate knowledge of the behind-the-scenes 18 goings-on because they were posted prior to all this 19 being made public. Also enclosed are direct quotes 20 from L. Ron Hubbard. They speak for themselves. It 21 might be considered that the dictates are being 22 followed precisely." 23 And then it goes on: "He with the deepest 24 pocket" -- I don't know if I read this as carefully as 25 I'm reading it now -- "He with the deepest pockets and 0896
1 most skilled lawyers and heavy-handed tactics 2 shouldn't necessarily win or lose. Justice will have 3 been served and the judicial system allowed to work as 4 it was designed and both sides are allowed to present 5 their case to twelve jurors" -- somebody doesn't know 6 the Florida system, obviously, very well -- "let the 7 chips fall where they may. Then only then will we 8 have all won." 9 And there's a quote here: "The truth is too 10 simple. It must always be arrived at through 11 complication. Blessings to you and your work and 12 life," unsigned. 13 And then there are some postings here, 14 page 1 of 40. Must have been a big night or 15 something. I don't know if that means there's 40 16 pages or what, but I've got 1 of 40 and 2 of 40. 17 And at the top it says: "Bob and Stacy in 18 court, true or," dot, dot, dot, dot. "Operation 19 Clambake forum, opinion and debate." 20 What is that? I don't even know what this 21 is. Is this what these postings are -- 22 THE WITNESS: Yes, your Honor. 23 THE COURT: -- that everybody keeps talking 24 about? I keep telling you all, maybe one of these 25 days you all ought to invite me to go to a couple of 0897
1 these so I can look at them, because I don't go to 2 these places that have postings. 3 THE WITNESS: You don't want to. 4 THE COURT: Oh, okay. 5 Anyway, it appears there's inquiry being 6 made here as to whether or not Bob and Stacy have -- I 7 guess that being Mr. Minton and the lady right here 8 before us as we're talking about -- are going to go 9 in, and what is -- what is apparently of importance 10 that I read, the only thing that's seemingly 11 underlined -- and I believe this was the way I 12 received it: "Tomorrow morning Bob Minton will walk 13 into Wally Pope's office and suborn perjury by telling 14 all the lies Scientology asks him to" -- I don't know 15 what these little daggers, little caret marks -- "with 16 the anticipated result of bringing down the," caret 17 marks, "case." 18 So I guess that is what this was referring 19 to, that this must be somebody close to this. And 20 then there's a bunch of stuff -- I couldn't even tell 21 which side wrote this because -- 22 THE WITNESS: It's hard to tell. 23 THE COURT: It's hard to tell, because on 24 the other thing -- I mean, I suppose that somebody 25 telling the group that's listening that Bob and Stacy 0898
1 are going to try to ruin this case, but then I've got 2 some stuff that sounds like it come from a -- maybe, I 3 don't know -- the Church is going to acknowledge that 4 these were supporters. But -- 5 THE WITNESS: What's it say? 6 THE COURT: Well, it says: "Minton must be 7 in some deep shit. He's supposed to take the deal the 8 Church offered him. What a sucker. We always knew he 9 would roll over. How do you like your boy now? Why 10 don't you ask him" what he and Stacy -- "why he and 11 Stacy Brooks were meeting with Church officials until 12 wee hours of Sunday morning? Ha, ha, ha, ha, ha, ha." 13 THE WITNESS: Yes. This was someone who 14 obviously was following us. 15 THE COURT: "Keep idolizing Minton, but how 16 will you rationalize --" 17 I mean, I don't know. But anyway, the deal 18 is, was when I said I was going to give this to you 19 all -- oh, the last page, I'm sorry, is Ron Hubbard in 20 his own words. And there's -- I wouldn't know what it 21 was, to tell you the truth, and I don't believe I read 22 it. There is something here underlined. I wouldn't 23 even know what it meant. "Branch 5 Project, Project 24 Swirl." Anyway. And then of course there's this 25 letter. 0899
1 Now, of course, now I've got this, which 2 seems to say, "What in the hell are you thinking?" 3 And then it says: I'm the one that sent you the 4 Internet postings. I did it because" -- and the quote 5 from Ron Hubbard. "I did it because I thought it was 6 very revealing. If I were in your position, I would 7 have wanted that information." 8 Well, don't do me any favors, folks. I've 9 got all the information I could deal with. 10 And then it says: "Approximately ten days 11 ago, I had a recording of a blood-curdling, 12 terror-filled message left on my voice mail. I 13 received an e-mail with a message" -- I don't have any 14 idea what this means -- "PM exiting, and my computer 15 was" -- a word, I don't even know what it is -- "with 16 advertisements for life insurance. Unknown charges 17 have appeared on my credit card." 18 And then this next might be revealing to 19 this person if she identifies -- something personal 20 about her. She's a sitting duck. "And now you're 21 going to hand them my name" -- I wonder who "they" 22 are -- "my name and address. I'm the source of giving 23 you that info." 24 THE WITNESS: Well, your Honor, I think 25 "them" -- she thinks Scientology is going to do 0900
1 something to hurt her. 2 THE COURT: "If ever there was a case of 3 directly feeding someone to the lions, that would be 4 it. You're the judge. Use good judgment." 5 And then I suppose this was this woman's 6 name. So I've got a name, apparently. I've got a 7 name on here, and I've got this $9.09 envelope that's 8 got an address. And then I've got somebody suggesting 9 that I'm going to be feeding this person to a lion's 10 den if I -- but in essence, that's what it is. 11 I've asked my secretary to take one of these 12 copies and go talk to somebody to see if what I've got 13 from this person, anybody would know -- I mean, I 14 don't want to -- if somebody doesn't understand it, 15 let it be clear. I mean, when you give a judge 16 something, the judge generally throws it in the 17 wastebasket, files it in the court file, or gives it 18 to the lawyer, depending on the case and what the 19 import of it is or what have you. 20 I brought this up only because I figured I 21 might start getting more of these, and I thought I 22 might want you all to tell me what you wanted me to 23 do, whether you wanted a copy, whether you wanted it 24 thrown in the court file, thrown in the wastebasket. 25 Any of this would have been okay with me. 0901
1 But now that somebody suggests that if I 2 reveal this that somebody is going to be in harm's 3 way -- which I don't believe -- I'm not sure what it 4 is I should do. So I'm going to think about it 5 overnight, and maybe you all would think about it 6 overnight and give me some suggestions. 7 MR. FUGATE: Judge, obviously, if she's 8 looking to -- if I heard correctly what you read in 9 the handwritten note, that somebody was in the 10 courtroom and then left when they thought you were 11 going to reveal it. There's only one person that has 12 come and gone, and that was a blond woman, who I have 13 no idea who she was, sitting in the second row there. 14 And the only person that we saw her have contact with 15 was Mr. Jesse Prince, who was standing in the hallway. 16 So I can't tell you anything other than 17 that -- the old Florida circumstantial evidence 18 instruction -- I don't know what that means. But 19 that's what happened. I mean, obviously whoever gave 20 that to you was sitting in the courtroom and realized 21 you were going to give it up, wrote the letter and 22 took it to your J.A. 23 THE COURT: Well, it -- nonetheless, it's 24 somebody suggesting that if I give this up, they 25 can't -- as I said, it's "What in the hell are you 0902
1 thinking of?" Well, I thought I was thinking like a 2 judge. 3 But I just -- I'm just going to tell you I'm 4 going to think about this overnight. I don't -- I 5 don't know that anybody really needs to know who that 6 was. Does anybody need to know who this person was? 7 MR. LIROT: We don't need to know anything, 8 Judge. 9 THE COURT: I mean, would that -- 10 MR. MOXON: Judge, we don't care who it was. 11 Our only concern is that there was an attempt to, you 12 know, influence the Court by somebody who has been 13 talking -- the woman that was talking to Mr. Lirot at 14 the last hearing and was talking to Mr. Prince in the 15 hallway. 16 THE COURT: Well, trust me. 17 MR. MOXON: I know that you wouldn't -- 18 THE COURT: And you know that -- 19 MR. MOXON: Of course not. 20 THE COURT: -- I get this stuff all the 21 time. When I used to be at criminal, I mean, I got 22 letters all the time: This guy needs to be put away, 23 up -- you know, hung from a tree. And this guy is a 24 wonderful fellow. 25 And I just didn't pay much attention to that 0903
1 stuff. I just usually filed it in the court file. 2 But on death penalty cases, as I said, I would have to 3 try not to read them and put them in a box and try, if 4 I did hand them out -- and there's all kinds of 5 problems. 6 This is not a death penalty case. So, as I 7 said, I just was trying to get a feel for how we might 8 want to deal with it. But I don't want somebody to -- 9 they think they sent me something and now all of a 10 sudden I'm -- 11 MR. MOXON: Judge, we don't care. We don't 12 care. 13 THE COURT: You don't care, nobody cares. 14 Then the best thing to do is just to tell my secretary 15 to shred this. I'll file the original in the court 16 file without the envelope, throw this thing away, that 17 hand letter away. And assuming that there's nothing 18 in here that's identifying, I'll give you copies of 19 it. But as I said, I read it more fully in court 20 today than I ever read it. 21 MR. FUGATE: Well, the only concern I have 22 Judge, and my first impulse I stated to the Court when 23 you read the first one was just throw them away. But 24 if it's someone who is providing the Court something 25 and attempting -- and I know that it won't -- to 0904
1 influence your Honor and that someone is having 2 contact with Jesse Prince, I do have a problem with 3 that. But I don't know that there's anything we're 4 going to be able to do with it based on what you've 5 got right there. And that's my concern. 6 I mean, I think that we're all here to try 7 to get this hearing over with, and the less of this, 8 the more likely we are to get it over with. But I 9 don't want to have somebody think they can come in to 10 give things to the Court to influence the Court. And 11 I think both sides ought to be instructed fairly to 12 make sure that anybody on either side keeps that from 13 happening. 14 THE COURT: But, you know, it's real hard. 15 I mean, I understand why neither side -- I mean, I've 16 been involved in this court system for 20 years. 17 People send stuff to the judge. And naturally they're 18 trying to influence them. That's why they send it. I 19 mean, that's exactly why they've sent it. They've got 20 a position, and they want you to know it. 21 Judges just aren't influenced by stuff like 22 this. If we were, we couldn't ever sit on a case. We 23 get it all the time. If somebody knew that if we got 24 something we couldn't sit on a case, I guarantee you 25 the other side that didn't want us would be sending us 0905
1 stuff to get us off the case. So it isn't that big a 2 deal. But, yes, would both sides please instruct 3 their -- 4 MR. FUGATE: Gallery? 5 THE COURT: -- their folks that are -- their 6 supporters, for lack of a better word, that please 7 don't send me stuff. I mean, all I have to do is -- I 8 will file it in the court file, I will hand it out to 9 the lawyers, or I will throw it in the wastebasket, 10 depending on what the lawyers tell me they want me to 11 do in this case. And if they don't want that to 12 happen, then they really ought not to send it. 13 MR. FUGATE: Thank you, Judge. 14 THE COURT: Okay. 15 MR. LIROT: Judge, just for the record, in 16 light of what Mr. Moxon said, I was never asked about 17 anything. I've never told anybody to send anything to 18 the Court. And if anybody did ask me, I would tell 19 them absolutely under no uncertain circumstances -- 20 THE COURT: I have no doubt that that is 21 true, and I have no doubt that that is true for all 22 the lawyers that appear in front of me on this case. 23 But I'm just telling you that sometimes people -- 24 obviously, somebody in court didn't know that. 25 And so do I think they were trying to 0906
1 influence me? Maybe. I don't know what this means, 2 to tell you the truth. "Five years ago, Bob Minton 3 set out to destroy Scientology by funding the Lisa 4 McPherson case. Today he's made a pact with 5 Scientology to destroy the Lisa McPherson case to save 6 his own skin." 7 I mean, that kind of stuff isn't influential 8 to a judge. 9 THE WITNESS: Well, your Honor, this is 10 raging on the Internet. 11 THE COURT: Is it? 12 THE WITNESS: This whole attitude, this 13 fervent belief that Mr. Minton and I are both under 14 some sort of threat of death by Scientology and that 15 that's why we're doing this. 16 And there are a lot of people who think they 17 are really doing us a big favor by posting things like 18 that on the Internet and, you know, saying that we're 19 lying and this whole thing. I mean, the feelings are 20 very, very high. You know, people are just raging 21 about this whole issue. 22 And what you're reading there is just one 23 example of literally hundreds of postings about 24 Mr. Minton and myself and our testimony and -- 25 THE COURT: Yes, there's some stuff in 0907
1 these -- I'll give these to you that are fairly long. 2 There's vulgar stuff here. 3 THE WITNESS: Very vulgar. 4 THE COURT: Very vulgar stuff. As I said, 5 if anybody thinks that's influential, it really isn't. 6 But that -- I mean, I know you all wouldn't 7 occasion this stuff to be sent to the Court. People 8 that think I need to know things, I really don't. I 9 need to know what comes from a lawyer. 10 So the best you can, pass that onto anybody 11 that might -- and the rest of it I'll just deal with 12 at the time. 13 Okay. 14 MR. LIROT: Very good, Judge. 15 THE COURT: I'm sorry that we had to have 16 that interruption, but . . . 17 BY MR. LIROT: 18 Q Ms. Brooks, I believe we left off at Exhibit 15L, 19 and I'm going to hand you what I've marked as Exhibit 15M. 20 This is the declaration of Stacy Brooks regarding records 21 retention and destruction. And it looks to be an exhibit 22 from -- it says Witness 1SB9-7-01LC, and it looks like 23 you've signed this under penalty of perjury. And that 24 looks to me to be a declaration that you prepared and 25 signed, or at least signed, about the policies of the Lisa 0908
1 McPherson Trust and document destruction. 2 What does that -- what does that paragraph say? 3 If you can, read the highlighted paragraph to the Court. 4 A "From its -- from its inception, the records 5 retention policy of the Lisa McPherson Trust has been to 6 minimize the number of records retained. Under that --" 7 THE COURT: Go slow. Remember my court 8 reporter here is doing realtime. 9 THE WITNESS: Sorry, sorry. 10 Did you get what I just said? 11 THE REPORTER: Yes. 12 A Okay. "Under that policy, all records, 13 correspondence -- correspondence, e-mails and Internet 14 postings are deleted or destroyed as soon as is practical 15 after their use has terminated, with the exception of 16 minimal archival records which are stored in digital form. 17 It is not possible to identify the records which have been 18 purged pursuant to the aforesaid policy. All records have 19 been dealt with according to that policy." 20 BY MR. LIROT: 21 Q All right. Was that true? 22 A Yes. There -- that policy did exist. And, 23 unfortunately, everybody didn't adhere to the policy. 24 There were things that were still in the office. And the 25 special master has now gone through the whole office and 0909
1 found -- I don't know what he's found, whatever he's found. 2 And also, he has the hard drives so he can -- you know, I'm 3 not really sure what there is to find, but I wouldn't be 4 surprised if there were documents and things on the 5 computers that he found that would be -- that would have 6 been responsive to whatever subpoena that was in response 7 to. 8 Q Okay. Now, the next paragraph is not 9 highlighted. And this one says: "No archival records 10 include statements of any person having knowledge of the 11 facts of the complaint or counterclaim in the case of 12 McPherson vs. Scientology. No archival records contain any 13 statement or information concerning the subject matters of 14 the aforesaid action. No archival records contain any 15 reference to any person designated as a witness in that 16 case or to any person who has knowledge of the facts of the 17 case, except a digital copy of Teresa Summers' privilege 18 records concerning" -- Marcus Quirino? Is that how you 19 pronounce his name? 20 A I would imagine. 21 Q Okay. "Are stored there, as are digital 22 duplicates of the statements of the Woodcraft family which 23 appear on the Lisa McPherson Trust Web site. Only Teresa 24 Summers has access to the records concerning Marcus 25 Quirino." 0910
1 That wasn't highlighted at all. So all that I 2 would assume would be true in your declaration. Isn't that 3 correct? 4 A I think you have the wrong idea here. The things 5 that are highlighted aren't highlighted because they're 6 false. And I think we've gone through quite a number of 7 these highlighted excerpts -- 8 Q Okay. 9 A -- that I have testified clearly were true. 10 Q Okay. 11 A So I think you're misstating my testimony or 12 misstating something -- 13 Q Well -- 14 A -- to say that everything that's highlighted is a 15 lie. 16 Q That wasn't my statement. 17 A Well, that is I think what you said. 18 Q No. You testified that some of the things were 19 highlighted that were true. And I think at one of the 20 meetings certain things came up, and you had said, well, 21 not all of that was false. I think in testifying about 22 Mr. Rinder's discussions with you, he apparently brought 23 some things up. And you said, "Well, not everything you've 24 brought to my attention did I testify to falsely." 25 So I took it to be your description of these 0911
1 documents that these highlighted sections were sections 2 that were brought to your attention so that you could set 3 the record straight. And you don't know who highlighted 4 them, so I'm trying to find exactly what it is -- 5 A That's incorrect. 6 Q What's incorrect? 7 A If that's your understanding of what I've been 8 saying, your understanding is incorrect. 9 Q Correct me. What is it exactly that was 10 highlighted in these documents? 11 A Someone's idea about things that I might need to 12 correct. It didn't -- it certainly didn't mean that I 13 might not need to correct something else. 14 Q Okay. 15 A And I certainly didn't rely on only these 16 excerpts to determine what I needed to do. 17 Q Okay. 18 A I think it's important for you to understand that 19 when we finally went -- 20 And, your Honor, this is what -- this is what 21 these people that are making these postings on the Internet 22 cannot even wildly imagine could be true, what I'm about to 23 say. 24 By the time we went and spoke to Mr. Rinder on 25 Saturday, April 6th, we felt that Mr. Dandar had put us in 0912
1 a very, very, very dangerous position. And we -- we felt 2 that we could no longer trust him at all. And we were 3 confronted with a landscape of players that was so surreal, 4 because on one side, we had people that we had been working 5 with that we now no longer trusted at all. And on the 6 other hand -- and on the other side, we had Scientology, 7 that we had spent years demonizing and not trusting at all. 8 And -- and suddenly we were in a position 9 where -- and Mr. Minton will probably testify about this, 10 but I will say for myself that I had the impression from 11 Mr. Minton that he found himself in a position where the 12 world had turned upside-down, and the person that he could 13 think of that he might possibly be able to trust in the 14 world was Mike Rinder. 15 And so when we went and spoke to him and when we 16 were working with him, this was not a matter of Mike Rinder 17 directing us in any way. I need for you to understand 18 that. You won't believe me. All these people that are 19 posting these things don't believe this. But all of these 20 people that are posting these things don't believe what 21 Mr. Dandar has been doing either. And if they believed 22 what Mr. Dandar has been doing, then they would understand 23 perhaps why we found ourselves in such a surreal situation. 24 And we went to Mr. Rinder, and he was extremely 25 uncomfortable about talking to us. He was not quite sure 0913
1 what to do. But we said to him -- and this is not a 2 quote -- but basically what we said -- and Mr. Minton. 3 Basically what Mr. Minton said was: 4 I need help, and I'm in -- I'm in a situation 5 where I'm facing another contempt hearing in three days. I 6 just escaped from a contempt hearing by the skin of my 7 teeth. Judge Schaeffer was going to put me in jail, and 8 I'm facing another judge that's even madder at me than 9 Judge Schaeffer has ever been. And I don't know what to 10 do, and I need help. And how do I get myself out of this 11 situation? You know, I need to set the record straight. 12 And he had by now spoken to his attorney, 13 Mr. Howie, and Mr. Jonas had spoken to him about this case, 14 and I'm not -- I'm not getting into any substantive 15 description of what was said between him and his attorneys. 16 But I can tell you this, that -- that he felt that there 17 was nowhere else to turn for help and that Mr. Dandar was 18 willing to -- and Mr. Dandar had said this many times -- 19 that Mr. Dandar was willing to let Mr. Minton go to jail 20 for the sake of this lawsuit. 21 And I was not in any way willing to let 22 Mr. Minton go to jail for the sake of this lawsuit. And I 23 don't think Mr. Dandar should have been willing to after 24 what Mr. Minton did to try to help the family. And -- and 25 Mr. Minton -- and again, he may testify differently -- but 0914
1 it was my feeling that Mr. Minton had gotten to the point 2 where if there was anybody in the world that he might be 3 able to trust to be -- to be -- to help him get out of the 4 situation that he felt Mr. Dandar had put him in, it would 5 be Mr. Rinder. 6 And I've got to tell you that that was the truth, 7 because we sat down with Mr. Rinder, and he was nothing but 8 courteous. He was nothing but -- as far as I know, 9 completely ethical about what would be acceptable in such a 10 situation for Judge Schaeffer or for Judge Baird. He was 11 very, I think, meticulous about that. 12 But he was willing to provide the documents that 13 we were asking for. We explained to him. He said, "Why 14 are you asking me?" 15 We said: "Who else are we suppose to ask? We 16 can't ask Mr. Dandar. That's for sure. We can't ask 17 Mr. Merrett. We can't even find him. You know, we've got 18 nobody on our side to help us get out of this mess. You 19 know, will you please help us?" 20 And that's what he did. So when you're talking 21 about this -- I understand that you need to impeach my 22 testimony, but you need to be straight on what exactly 23 happened here and what your partner's role in this was. 24 Q That's all I'm asking. 25 A Well, I -- 0915
1 Q I just want to find out -- 2 A -- want to clarify for you. 3 Q I appreciate that. 4 Okay. So you've gone over that and you've gone 5 over your declaration which we had as Exhibit M. 6 Exhibit N is a copy of the video -- or, 7 transcript of the videotaped deposition of Teresa Summers 8 of October 16th, 2001, consisting of page 1, page 52, and a 9 signature page. And apparently all this is, is asking 10 Ms. Summers about your document retrieval policies or -- 11 A Right. And she said no, we don't have them. 12 Q All right. And Exhibit O is a transcript of the 13 video deposition of Robert Peterson -- 14 A And he said no, we don't have one. 15 Q Fair enough. That's page 81, and he says no, you 16 don't have one. 17 Then there's the videotaped deposition of David 18 Cecere, Exhibit 15P. That's the cover page, 67, page 68, 19 and page 92, which appears to be the signature page. And 20 he asked about -- he was asked about any policy at LMT 21 concerning deleting Internet messages and a written policy. 22 He answered no. 23 Any orders to people that they must delete their 24 messages? 25 He answered no. 0916
1 And he was asked if there was any policy about 2 shredding documents, and he answered no. 3 A Okay. Well, I think that if these people would 4 have been asked the question, "Have you ever received from 5 Grady Ward instructions on what to do about your documents 6 and your electronic documents, they would have answered 7 differently. Their understanding of what a policy is was 8 different from mine. 9 Q Okay. And Exhibit Q looks to be an order signed 10 by Judge Moody, I believe, on May 15th, 2000, which I -- 11 apparently is the order that the Lisa McPherson Trust shall 12 produce within ten days a person most knowledgeable to 13 testify to matters addressed in the court's ruling, et 14 cetera, and shall produce unedited videotapes in the 15 possession, custody, or control of the Lisa McPherson 16 Trust. And I think that one speaks for itself. 17 THE COURT: What are you doing? I mean, 18 Counsel -- 19 MR. LIROT: I'm just going -- Judge, I'm 20 just trying to go through all these documents. It 21 will make sense when I get to the end. 22 THE COURT: Oh, okay. 23 BY MR. LIROT: 24 Q Next is the May 18th, 2000 videotaped deposition 25 I believe of the Lisa McPherson Trust, which I assume to be 0917
1 you. And this is Sub Exhibit R, May 18th. And this again 2 is obviously asking you again questions about all of these 3 videos and tapes and I guess the hard drives. This will 4 speak for itself. Is there anything else in that document 5 that comes to your attention? 6 MR. WEINBERG: I think that's Mr. Minton as 7 the representative, although I'm not positive. 8 THE WITNESS: Let me -- I think I'll be able 9 to recognize it pretty quickly. 10 MR. WEINBERG: Sorry. 11 THE COURT: It's all right. 12 THE WITNESS: That's Mr. Minton. 13 BY MR. LIROT: 14 Q Okay. So did you go through the highlighted 15 sections of this exhibit? 16 A That's Mr. Minton's testimony. 17 Q All right. Well, apparently this was part of the 18 packet provided to you, so we'll leave it in there. Did 19 you review it to make sure that there was anything you were 20 concerned about? 21 A If it was provided to me, I think it was probably 22 done in error. 23 Q Fair enough. 24 A And when -- you know, I wasn't -- I wasn't 25 interested in recanting Mr. Minton's testimony. 0918
1 Q Fair enough. Okay. The next one is 15S, it was 2 the order regarding videotapes of the Lisa McPherson Trust. 3 And apparently this is also an order signed by Judge Moody 4 on July 18th of 2000, ordering the production of any 5 unedited videos in the possession, custody, control of the 6 Lisa McPherson Trust of statements of any person presently 7 identified as a witness in this case. And it says, 8 "Mr. Minton shall further file a sworn statement that LMT, 9 Inc., searched their video files as to the entire witness 10 list of the parties and produced all segments of 11 statements --" 12 THE COURT: Counsel, slow down. I just know 13 that my court reporter is going crazy down there. 14 Slow down. We all do that when we can read. We read 15 real fast, but she's -- 16 MR. LIROT: Understood, Judge. 17 THE COURT: Especially when she's doing 18 realtime. 19 MR. LIROT: Balancing these competing 20 interests, Judge. 21 THE COURT: Yes. 22 BY MR. LIROT: 23 Q And I'll pick it up at the beginning of page 2, 24 "search their video files as to the entire witness list of 25 the parties and produce all segments of statements dealing 0919
1 with Lisa McPherson, the Lisa McPherson case, the 2 defendants, and Scientology." 3 What was the significance of that order being 4 attached to the packet delivered to you? 5 A Well, this was again having to do with whether or 6 not my compliance with the discovery had been, whatever you 7 call it, false or -- 8 Q Okay. Exhibit T is an order compelling document 9 production of Lisa McPherson Trust, Inc. It's signed by 10 Judge Quesada, apparently on November 20th of 2000. And 11 that looks to be pretty much identical to Judge Moody's 12 statement. 13 A Okay. 14 Q So that, again, your testimony would be that 15 that's attached -- 16 THE COURT: Whoa. You don't know that 17 that's identical or not. It's a different order. It 18 may or may not be identical. I don't know if it is or 19 it isn't. 20 THE WITNESS: Well, your Honor, it has to do 21 with videotapes and documents. 22 THE COURT: Okay. 23 THE WITNESS: So that's probably why it 24 would have been included. 25 BY MR. LIROT: 0920
1 Q Okay. And then Exhibit 15V, this appears to be 2 excerpts of your deposition, Ms. Brooks, of August 15th, 3 2001. And it has page 1 and then pages 58, 59, 60, 61, 62, 4 124, 125, 127, 128, 129 -- 5 THE COURT: How many pages are there? 6 MR. LIROT: -- 130 -- 7 There's just a couple more, Judge. 8 -- 131, 132, 133, 134, 135, and then 149 is 9 the signature page. 10 MR. WEINBERG: Your Honor, while he's -- I 11 didn't hear a U. Did you call it V or U? 12 MR. LIROT: This is U. Did I call it V? 13 MR. WEINBERG: Yes, you called it V on the 14 record. So it's U. 15 MR. LIROT: Can't even read my own 16 handwriting. I apologize. 17 A So what is your -- 18 BY MR. LIROT: 19 Q And then the questions in that deposition also 20 deal with documents, videotapes, hard drives, and those 21 types of issues, correct? 22 MR. WEINBERG: Do you want her to go through 23 all the papers? 24 MR. LIROT: She can. 25 A Do -- you want me to do what? 0921
1 BY MR. LIROT: 2 Q Why don't you just take a look at that document 3 and make sure that you're aware of what it was that they 4 were providing that document for you to be aware of when 5 you asked for these documents. 6 A Okay. 7 Q All right. Would you agree that that deposition 8 testimony all centers on documents, Mr. Bunker's use of the 9 videotapes, and those issues? 10 A Well, it centers on the videotapes. 11 Q Okay. 12 THE COURT: Again, these are these 13 videotapes, and we don't even know what they are? 14 MR. LIROT: Apparently so, Judge. 15 THE WITNESS: This is unedited videotape 16 that had been ordered. 17 EXAMINATION 18 BY THE COURT: 19 Q Of maybe some pickets or -- 20 A Yes. Well, it hadn't been clarified. But 21 basically what happened was we were being very -- whatever, 22 recalcitrant about turning over anything. 23 Q That is true. 24 A And so -- 25 Q Like I said, I went through order after order 0922
1 after order. 2 A Yes. And so what finally Scientology said was, 3 "Look, we want -- just make them turn over the unedited 4 videotape," because -- you know, so that they -- I would 5 assume so that they could see what all there was and we 6 could stop -- and they could stop us from, you know, 7 saying, "Well, we only have edited stuff," blah, blah, 8 blah. 9 So then they made a request to the judge for the 10 unedited, raw footage so that they could look for 11 themselves. I think that's why they did it. 12 Q Well, what did it have to do with the Lisa 13 McPherson wrongful death case? 14 A Well, your Honor, I don't think it had much to do 15 with it, but -- but I never went through all the raw 16 footage, so I couldn't tell you that for sure. And I think 17 Scientology wanted to go through all the raw footage to see 18 if it did. 19 Q Okay. 20 A But that's the best of my understanding. 21 Q Were somehow some of these tapes taken and edited 22 for certain other things -- 23 A Yes. 24 Q -- is that it? 25 A Yes. 0923
1 Q What were they used for? 2 A Well, for example, there were some videotapes 3 that were put up on our Web site that were -- maybe it was 4 an inner deal with someone. Or there were a couple of 5 videos that Mr. Bunker edited that one of them was sort of 6 a behind-the-scenes sort of a -- what do you call that 7 word, candid -- a candid video of me and Mr. Minton and 8 Mr. Prince and a number of other people just sitting around 9 and talking about various aspects of Scientology, that kind 10 of thing. And, you know, they wanted to see what else had 11 been said that he hadn't put in the edited version, I 12 think. 13 THE COURT: Okay. 14 CROSS-EXAMINATION (RESUMED) 15 BY MR. LIROT: 16 Q I guess the last thing in your packet was a 17 declaration of Michael Rinder, which was apparently signed 18 by Mr. Rinder or -- I don't know, it was signed by somebody 19 on October 24th, 1994. Is this the -- is this the 20 declaration -- and I guess you had a chance to review this, 21 and I'll hand it to you. 22 And this is Sub Exhibit V. Is that the 23 declaration that Mr. Rinder provided that inspired you to 24 write the responsive declaration of December 12th, 1994, 25 that we've already given to the Court? 0924
1 A Okay. First of all, I don't think that this was 2 part of the package that I was given. I don't remember 3 being given this. 4 Q Okay. Well, it was given to me as -- 5 A Okay. 6 Q -- part of what was given to you. So -- I have 7 no idea. So if it wasn't, please tell me that. 8 A Well, I don't believe it was. I don't remember 9 having this turned over to me as -- 10 THE COURT: Well, assuming -- whether it was 11 or it wasn't, is that the -- I mean, your declaration 12 was in response, obviously, to a declaration of 13 Mr. Rinder. 14 THE WITNESS: Yes. This is -- 15 THE COURT: And you've already testified 16 about that -- 17 THE WITNESS: Yes. 18 THE COURT: -- and you indicated, where it 19 may be slanted in some regards, it was true. And your 20 declaration was saying, now, Mr. Rinder's declaration 21 was not true. 22 THE WITNESS: Right. 23 THE COURT: In part, that was what your 24 declaration was saying. 25 THE WITNESS: Yes. This is the declaration 0925
1 that I was responding to. 2 BY MR. LIROT: 3 Q Okay. Why don't you read paragraph 12 to that 4 declaration, whether you got it or not, since you've 5 already seen it. 6 A "Both of the Youngs readily agree that they could 7 easily set the record --" 8 THE COURT: Slow down for me. 9 THE WITNESS: Sorry. 10 A "Both of the Youngs readily agree that they could 11 easily set the record straight by writing new declarations 12 which would clarify the statements they had made 13 previously. Vaughn said that he did not want to write 14 anything that would be a direct contradiction to what he 15 had written earlier, but this was simply a matter of 16 interpreting things differently. He said he intended to 17 make his career as a writer and would need credibility in 18 order to obtain future jobs so wanted to do this properly." 19 Q Okay. And you don't remember if that was 20 provided to you or not in order to prepare these 21 affidavits? 22 A In fact, I -- in fact, I remember that it wasn't. 23 Q Okay. Fair enough. Now, since we've had an 24 opportunity to take a look at what was provided to you, I 25 think your testimony was that you had many meetings between 0926
1 April 9th and the 15th. And then subsequent to April 15th, 2 did you have any additional meetings with members of the 3 Church or their counsel relative to preparing the 4 affidavits that you filed in this case? 5 A I believe so. 6 Q Okay. Can you tell me when those may have been 7 after the 15th? 8 A Well, it would have been sometime after the 15th 9 and before the 29th, which was when I signed my -- 10 Q Okay. 11 A -- affidavit. I think Mr. Minton signed his 12 several days earlier. 13 Q Okay. Were there a couple of days after you were 14 given these materials to digest, or did you meet the very 15 next day on April 16th? Do you remember that? 16 A I don't recall. I believe I met with my attorney 17 the next day. 18 Q Okay. And then after having received these 19 documents, you prepared I believe -- and I know we've 20 already testified to this -- you prepared an affidavit 21 of -- affidavit recanting testimony of Stacy Brooks, which 22 apparently you signed on -- 23 A April 17th. 24 Q -- April 17th. So you had these documents, and 25 you had numerous meetings between the 9th and the 15th. 0927
1 And then on the 17th, you provided -- 2 MR. FUGATE: Excuse me, your Honor. I just 3 object to "numerous meetings." I think she's 4 identified the meetings in past testimony. 5 THE COURT: Sustained. However many she 6 said. 7 BY MR. LIROT: 8 Q You had some meetings between the 9th and the 9 15th, and then you had some meetings after the 15th. And 10 then on the 17th, you filed your affidavit. Correct? 11 A I believe I said that on the 16th I met with my 12 attorney. 13 Q All right. And then you filed your affidavit. 14 Now, after this affidavit was filed, did you have any other 15 meetings to make sure that the affidavit was appropriate 16 for this global settlement that you were trying to 17 obtain -- 18 A No. 19 Q -- with the Church of Scientology? 20 A No. 21 THE COURT: The date of the 17th is the date 22 that this affidavit was signed, actually. I'm guilty 23 of the same thing. It's filed. This is a notice of 24 filing. It's signed by Mr. McGowan. That was 25 included. And Lord knows whether it was actually 0928
1 filed then or whether it was filed on the 19th. That 2 depends on when the clerk stamped it in. So -- but 3 we're talking about when she signed it on the 17th, 4 right? 5 MR. LIROT: That's correct, your Honor. 6 THE COURT: Okay. 7 BY MR. LIROT: 8 Q Did -- after this was filed, did you have any 9 additional meetings? Did you send this affidavit to the 10 Church for approval? 11 A No. 12 Q Well, then why did you -- why did you have to 13 file the second affidavit? 14 A Because I wanted to. 15 Q All right. Well, you wanted to set the record 16 straight, and you had many meetings with -- whatever number 17 you testified to. And then you had a meeting with your 18 counsel, and then you filed one affidavit. So out of the 19 blue, you decided to file a second affidavit, which -- 20 A I didn't -- 21 Q Okay. 22 A -- say it was out of the blue at all. 23 Q All right. 24 A In fact, it wasn't out of the blue at all. 25 Q Well, why did you file the one and then file a 0929
1 second affidavit after that? 2 A Well, as I recall, the first affidavit Mr. Howie 3 and Mr. McGowan both felt that we needed to get a 4 recantation -- a recantation affidavit filed with both 5 Judge Schaeffer and Judge Baird. And I believe that at 6 that time there was the possibility -- I don't remember 7 what the -- I believe that at that time there was some 8 question about what was going to go forward, whether Judge 9 Schaeffer -- whether we were going to be beginning a 10 hearing before Judge Schaeffer or beginning one before -- 11 or continuing one before Judge Baird. 12 But I think there was some question about what 13 was going to be happening next, and our attorneys felt that 14 it was important to let the courts see and know that we 15 were trying to cooperate with the court and that we were 16 acting in good faith and working with our attorneys to 17 correct our testimony. 18 Q Couldn't you just have been called as a witness? 19 THE COURT: Counselor, let's not be naive 20 here. I know what their lawyers were thinking. The 21 lawyers were thinking that somebody might move before 22 they moved, in which case they wouldn't recant; it 23 would be too late. They would be charged with 24 perjury, a third-degree felony. I suspect; I don't 25 know that. But that's, if I were a lawyer, what I 0930
1 would be thinking. We'd better get something in 2 there. 3 THE WITNESS: I believe that's basically 4 correct. 5 THE COURT: Yes. They said we need to just 6 get something filed, and then we'll go back and 7 work -- maybe I'm putting words in your mouth. But 8 that's what good criminal defense lawyers do. I guess 9 maybe these civil lawyers know the same -- pretty 10 smart too. 11 MR. LIROT: Fair enough. 12 BY MR. LIROT: 13 Q And -- 14 THE COURT: Maybe they called a criminal 15 lawyer. I don't know. But the deal is you've got to 16 get going before somebody comes after you. For all 17 they knew Mr. McCabe might come up pounding or I might 18 start some proceeding, in which case it's too late. 19 You can't recant. 20 MR. LIROT: Fair enough. Now -- 21 THE COURT: Right? Mr. Fugate, you're a 22 criminal lawyer. Isn't that right? 23 MR. FUGATE: Well, that's right, and that's 24 what I understand was happening, so . . . 25 BY MR. LIROT: 0931
1 Q Now, just to go back to all the materials now, 2 most of those materials -- 3 THE COURT: By the way, I'm not suggesting 4 you can't explore the fact, and maybe it's true, that 5 what you're suggesting I guess is if somebody said, 6 "This isn't good enough, you've got to write a better 7 one, we want you to write a better one," not 8 suggesting you can't explore that. But I certainly 9 know, and you would know, why the lawyers would want 10 it filed as quickly as possible. 11 MR. LIROT: I understand, your Honor. 12 BY MR. LIROT: 13 Q Look at those -- most of the documents that you 14 were provided just don't have anything to do with 15 Mr. Dandar, do they? I mean, if you look at exhibits -- 16 from Exhibit K, I guess, is where they talk about the 17 Merrett files, documents of destruction, the videotapes. 18 Mr. Dandar had no idea what was on any of those videos, did 19 he? 20 A Yes. 21 Q He did? 22 A As far as I knew, he did. 23 Q How would he know? 24 A Well, he was there for some of it. He was on 25 some of the videotape -- 0932
1 Q Okay. Well -- 2 A -- for example. 3 Q All right. What difference would that make to 4 this wrongful death case? 5 A I -- are you asking me what was in his mind? I 6 don't know what was in his mind. 7 Q If Mr. Dandar appears in public at a vigil or 8 anything else that he might be on, what difference would 9 that have in the wrongful death case? 10 MR. FUGATE: Your Honor, I object to that as 11 testimony again. That's not been established in the 12 record that that's what the videos are of. 13 THE COURT: Assuming that's what's on the 14 video I guess is what he's saying. 15 THE WITNESS: Well, I can answer that. 16 THE COURT: It might annoy the lawyer -- it 17 might annoy the judge if the lawyer in the case was 18 out involved in what might perceived as a picket. 19 THE WITNESS: Exactly, your Honor. 20 THE COURT: But it was too late, because the 21 judge had already seen pictures. 22 THE WITNESS: But Mr. Dandar didn't want it 23 to go any further. He certainly didn't want to have 24 the courts provided with any further footage of him 25 being involved, because -- I think this has been 0933
1 covered pretty extensively from other aspects of this 2 situation. But there came a point in time where -- 3 which was towards the end of -- which really began in 4 earnest towards the end of 2000 where -- where 5 Mr. Dandar wanted to do everything possible to make it 6 appear that there was no connection between Mr. Minton 7 and the case, the LMT and the case, any of us and him. 8 He was trying to distance himself from all of us as 9 much as he possibly could. He didn't want there to be 10 any connection. He didn't want the courts to see that 11 there was any kind of connection whatsoever. 12 So, you know, obviously being on a videotape 13 with all of us unsavory characters, as he came to 14 feel, would not be good for him or his case. 15 Q How -- how many videotapes are we talking about 16 in total? 17 MR. FUGATE: In the LMT or Mr. Dandar's? 18 A I believe there's several -- I believe there's -- 19 maybe several hundred. 20 BY MR. LIROT: 21 Q Okay. How many of those do you know Mr. Dandar 22 was on? 23 A Oh. Maybe 15 or 20, maybe 25. 24 Q Okay. And how about the hard drives? Is there 25 any way Mr. Dandar would know what you guys at the LMT had 0934
1 on your hard drives on your computer? 2 A Only if there was any e-mail from him or anything 3 like that. Again, the issue for Mr. Dandar was only to be 4 separate from us and only to distance himself from us. It 5 was -- it would have been the same situation in any -- in 6 any of these things. 7 Q Didn't he suggest that you guys should just turn 8 over all of this stuff? 9 A No. I don't remember that. 10 Q Well, he wasn't around when Mr. Merrett told you 11 to leave the stuff in the hall, was he? 12 A No, he wasn't there that day. 13 Q And as far as all the documents and whatever else 14 disappeared, you have no -- you have no independent 15 knowledge if any of this stuff went to Mr. Dandar, do you? 16 A What? 17 Q Well, apparently there's a lot of things missing 18 here that apparently Mr. Merrett has. You don't have any 19 knowledge that Mr. Dandar has any of that material, do you? 20 A No. 21 THE COURT: I don't even know that she said 22 Mr. Merrett had it. Her testimony, I thought, was 23 that Mr. Merrett said -- maybe -- maybe I read this -- 24 "Leave it in the hallway," and then it was gone. So I 25 don't know that Mr. Merrett has it. I suspect 0935
1 Mr. Merrett is going to tell us he doesn't. Now the 2 witness thinks Mr. Merrett will tell us he does. 3 THE WITNESS: Well, I can see your point. 4 THE COURT: Good. 5 MR. LIROT: Okay. 6 THE COURT: He'll want to appear in front of 7 me by phone. I can see why. I mean, you can't as a 8 lawyer tell your client that's been ordered to bring 9 something to -- by a judge to bring something, to 10 leave it out in the hallway and it'll be gone, you 11 won't have to worry about it. That would cause a 12 lawyer to be in serious trouble. 13 THE WITNESS: Well, your Honor, I can only 14 tell you that it's a very good experience for me to be 15 represented by Mr. McGowan. 16 THE COURT: Well, good. 17 BY MR. LIROT: 18 Q Now, as far as the -- was it Mr. Dandar that 19 helped you contact Mr. McGowan? Was he the introduction 20 between and you Mr. McGowan? 21 A Yes, originally when he wanted Mr. McGowan to 22 take on Jesse Prince's lawsuit against Scientology. 23 Q Okay. 24 THE COURT: Oh, my Lord, is there another 25 suit? 0936
1 THE WITNESS: No, your Honor. 2 THE COURT: Good. I hope it's not in my 3 court. 4 THE WITNESS: Mr. McGowan didn't take it. 5 THE COURT: No offense, guys, but one is 6 just all one judge can handle. My office wouldn't 7 handle any more than one. 8 BY MR. LIROT: 9 Q Now, we've gone through the documents, and 10 apparently you're familiar with what it was that you wanted 11 to say in these affidavits. Why do we have so many 12 meetings? 13 A There was a lot to talk about. 14 Q Okay. And were you being told what to put in 15 your affidavit? 16 A No. 17 Q Well, why is there so much to talk about? 18 A We had a lot to say. A lot had happened. We 19 felt really bad about what had happened. We were very glad 20 to have somebody to talk to about it. We were working with 21 our attorneys. Mr. Howie had provided a written -- what do 22 you call it? You know, he had put it in writing that it 23 was okay for us to have these meetings, and we were keeping 24 him informed and Mr. McGowan that it was happening. And it 25 wasn't any secret -- 0937
1 THE COURT: Tell me about that. Mr. Howie 2 had put it in writing that it was okay for you all to 3 have these meetings. Tell me about that. 4 THE WITNESS: Well, the day of -- I believe 5 it was on the day of your hearing -- 6 THE COURT: The 5th -- 7 THE WITNESS: Yes, and I remember it 8 because -- because Mr. Jonas wasn't able to come down 9 for your hearing. He was going to go -- come down for 10 Judge Baird's hearing, but he wasn't able to come down 11 for yours. And so -- and Mr. Jonas at that time was 12 the only attorney who was involved in the -- well, he 13 was -- he was the attorney that had been there for the 14 March 28th to March 29th meeting. And so I believe 15 Mr. Minton had told Mr. Howie that he wanted to meet 16 with Mr. Rinder, and -- 17 THE COURT: Without a lawyer. 18 THE WITNESS: Well, and that Mr. Jonas 19 wasn't going to be there that weekend. And so I think 20 the reason for it was that Mr. Howie was basically, 21 you know, saying that that would be okay. And then 22 Mr. Howie was on the phone with Mr. Minton -- well, 23 several times over that weekend, as I recall as well. 24 I don't have a copy of that -- 25 THE COURT: Okay. 0938
1 THE WITNESS: -- but I believe that 2 happened. 3 BY MR. LIROT: 4 Q Well, let me ask you again about this other stack 5 of documents that was apparently provided to you and 6 Mr. Minton when Mr. Prince was with you. You were at a 7 hotel either on the beach or somewhere in Clearwater? 8 A Actually, Mr. Lirot, I don't believe that any 9 documents ever arrived while Mr. Prince was there. I 10 believe that some documents arrived before he got there at 11 Mr. Minton's request -- 12 Q Okay. 13 A -- in preparation for Mr. Minton's speaking to 14 Mr. Prince. 15 Q What -- what documents were delivered to 16 Mr. Minton prior to Mr. Prince arriving in preparation for 17 Mr. Minton speaking to Mr. Prince? 18 A Mr. Minton was very concerned -- well, if I could 19 just back up briefly. Mr. Prince had told us that on the 20 day of Judge Baird's hearing on Tuesday, April 9th, he came 21 into the courtroom briefly and he wasn't -- he wasn't aware 22 of the agreement that Mr. Minton had made to recant his 23 testimony in return for a withdrawal of Scientology's 24 motion for contempt -- 25 THE COURT: I'm sorry, I'm all confused. I 0939
1 thought this question had something to do with some 2 stack of documents. 3 THE WITNESS: It does. 4 THE COURT: You're going to get there for 5 me? 6 THE WITNESS: Yes, your Honor. 7 THE COURT: Okay. 8 THE WITNESS: Yes, your Honor. 9 THE COURT: All right. 10 A And Mr. Prince apparently came into the courtroom 11 and heard Mr. Minton testifying and thought that he was 12 about to be put in jail. And Mr. Prince told us later that 13 he was so upset about that that he took an overdose of 14 Vistaril and drank a fifth of vodka and tried to kill 15 himself. 16 BY MR. LIROT: 17 Q Mr. Minton did or Mr. Prince did? 18 A Mr. Prince. And he told us this I believe on 19 Friday night when he came to see us at our hotel when we 20 were staying at the Adam's Mark on Clearwater Beach. 21 Q If Tuesday is the 9th, Thursday -- 22 A We didn't see him until Friday. 23 Q You saw him Friday the 13th? 24 A Yes. And I believe that was the first time we 25 had seen him since the hearing on Tuesday. 0940
1 Q This is Friday the 12th, I'm sorry. 2 A Okay. And when we saw him on Friday, he was very 3 intoxicated, but we had dinner with him in the restaurant. 4 We had a good -- 5 THE COURT: I'm sorry, let me just talk to 6 you for just a minute. Naturally, I've seen these 7 affidavits flying back and forth. This is the only 8 time that you saw Mr. Prince between your hearing in 9 front of Judge Baird and this intoxicated episode, 10 just this one time? 11 THE WITNESS: No, no -- well, there were -- 12 there were -- there was another incident on Sunday, 13 after this Friday. 14 THE COURT: Oh, okay. 15 THE WITNESS: Yes. 16 THE COURT: This is -- all right. 17 THE WITNESS: Yes. And Sunday is what he's 18 asking me about, so I'm just trying to lead up to 19 that. 20 A But we had a good conversation on Friday night, 21 we -- Mr. Minton and I felt that we had. We felt that -- 22 well, Mr. Prince said that he was very happy that we 23 were -- that we had initiated settlement talks with 24 Scientology, that he really wanted to be a part of that 25 settlement, that -- that he didn't want to have anything 0941
1 more to do with this litigation, and he was -- what he was 2 saying that night -- and this is what he had said for 3 months prior to this too -- was that he wanted to work with 4 us to bring that about. And we told him that we were -- 5 well, actually, we didn't tell him that night. 6 Then on Sunday, we saw Mr. Prince again. Now -- 7 BY MR. LIROT: 8 Q Well, let me ask you -- 9 A This is where the documents came up. 10 Q Let me slow you down a little bit. So Friday 11 Mr. Prince comes up, and he tells you that he's so 12 disappointed with whatever happened, what he heard 13 Mr. Minton testify to in front of Judge Baird on the 9th, 14 that he left to go kill himself? Is that your testimony? 15 A He may have -- he may have told me that over the 16 telephone. 17 Q Okay. 18 A I believe we made reference to it on Friday, but 19 I believe he had already told us that. 20 Q All right. And your testimony was that -- 21 A And it wasn't that he was so disappointed. He 22 was frightened for Mr. Minton, is what he said to us. 23 Q He was frightened for Mr. Minton -- 24 A Yes. 25 Q -- or Mr. Prince was frightened he would go to 0942
1 jail? 2 A What he -- the impression I got was that he was 3 frightened for Mr. Minton. 4 Q Okay. So Mr. Minton's recanting his earlier 5 testimony in the hearing in front of Judge Baird, and he 6 cares so much for Mr. Minton that he leaves in the middle 7 of the hearing, before the end of the hearing? 8 A Yes, he left before the middle. He didn't stay 9 very long. 10 Q And it depressed him to the point where he 11 subsequently made a phone call to you or communicated with 12 you in some fashion saying that "I was so depressed with 13 what I heard that I decided to take an overdose." I don't 14 know what you referred to, some pharmaceutical drug or 15 something like that? 16 A Yes. I believe it's an antianxiety medication, 17 if I'm not mistaken. 18 Q And he mixed that with a quart of vodka? A 19 fifth? I'm sorry. 20 A Well, what he said, I mean, his girlfriend has a 21 prescription for Vistaril. He said he took her Vistaril, 22 took enough pills that he thought that if he also drank it 23 with a fifth of vodka, it would kill him. That's what he 24 told me. 25 Q Okay. And that would have been that Tuesday, and 0943
1 then did you hear from him between that Tuesday and the 2 Friday that he met with you at the hotel? 3 A I'm not sure I heard from him again until after 4 Wednesday, and I spoke to him on the phone. And that's 5 when he told me what had happened -- 6 Q Okay. 7 A -- and how upset he had been at what he thought 8 he was looking at. So I spent quite a bit of time with him 9 on the telephone explaining to him that he was mistaken 10 about that, that in fact Mr. Minton was -- was stepping 11 forward to correct his testimony in return for 12 Scientology's withdrawing their motion for contempt. 13 And when I spoke to Jesse about it on the phone 14 either Wednesday or Thursday -- I think it was Wednesday -- 15 he was very, very happy about that. He was very relieved 16 and -- or at least he acted like he was. 17 And then on Friday, as I said, we had a good talk 18 with him. He was a little -- he wasn't acting like 19 himself, we didn't feel. And he was -- he was obviously 20 either on some medication or had been drinking and seemed a 21 bit fragile. So we had a talk with him. We told him about 22 what we were doing. 23 As I said, he was very happy. Actually, what he 24 specifically said was, "Well, I'm really glad about what 25 you're doing, because I choose life." That was his 0944
1 statement, "I choose life." And what I understood him to 2 mean by that was he wanted his life back. He didn't want 3 to be involved in this litigation any longer. 4 And so -- so we were very hopeful about that. 5 Jesse was a very good friend of both of ours, and we 6 knew -- I was aware of the fact that Jesse had quite a bit 7 of false testimony, because I had sat in at least two of 8 his depositions, that I knew -- although I hadn't reviewed 9 his testimony, I knew from my memory that -- that Jesse had 10 some things that he needed to correct as well. 11 So Mr. Minton, I believe, asked for the hearing 12 before Judge Schaeffer where Judge Schaeffer had -- because 13 Mr. Dandar had told us about this -- where Judge Schaeffer 14 had -- I'm not sure exactly what she said, but the 15 impression we had from what Mr. Dandar had told us was that 16 Judge Schaeffer had said that Mr. Prince's credibility was 17 questionable because of his bias and that she didn't 18 believe that he was so afraid of Scientology that that was 19 how come he had withdrawn or -- anyway. 20 And then she had said -- well, at least what 21 Mr. Dandar had said was that Judge Schaeffer had said that 22 she couldn't imagine why Mr. Dandar would want Jesse Prince 23 as his expert, but if he did, she would certainly help him 24 with that in some way or whatever, and if she had to put 25 him in jail to keep him here for his testimony, she would. 0945
1 Anyway, something like that. That's what Mr. Dandar had 2 said to Mr. Minton. 3 THE COURT: I remember. That's all 4 accurate, except I don't remember saying I would put 5 him in jail. But I think Mr. Dandar reflected what I 6 said pretty well. 7 THE WITNESS: Well, I'll tell you, your 8 Honor, we really had the feeling that you were going 9 to put all of us in jail. 10 THE COURT: Well, I found out where the six 11 years came from. That was about the first time I met 12 you all. And I was real annoyed because Mr. Minton 13 wasn't showing up for a deposition, and you all wanted 14 sanctions. And I said: You all don't know how I 15 play. This is how I play. I'm not going to find 16 somebody who could pay the money. You know, as far as 17 I'm concerned, we'll put him in jail and if he wants 18 to stay there for six years, it wouldn't matter to me. 19 THE WITNESS: There you go. I knew you said 20 that. 21 THE COURT: Well, Mr. Minton always appeared 22 at depositions, I guess, because nobody asked me to 23 put him in jail for that except for one unsworn 24 contempt. 25 THE WITNESS: Yes. 0946
1 BY MR. LIROT: 2 Q See, I think you testified -- 3 THE COURT: I don't recall that he didn't 4 show up at a deposition. I recall other things. 5 MR. FUGATE: The deposition he didn't show 6 up to was in front of Judge Baird, I think is what -- 7 THE COURT: Okay. 8 THE WITNESS: Yes, not in front of you. 9 THE COURT: Right. As I said, he must have 10 taken heed for that. 11 THE WITNESS: Oh, he did. He did. That's 12 why we're here. 13 BY MR. LIROT: 14 Q So -- 15 A So Mr. Minton asked -- I believe Mr. Rinder, I 16 assume it was Mr. Rinder -- if he could get a copy of that 17 transcript. And -- 18 Q This is all on Friday the 12th? 19 A No, no, no. This is Sunday. 20 Q Well -- 21 A This is Sunday, because Jesse was going to come 22 back over. Jesse had called and said that he wanted to 23 come over and see us on Sunday. And we were really glad, 24 you know, come over and have dinner or whatever. 25 Q So that's Sunday the 14th. Well, on the 13th he 0947
1 meets with you at the hotel? 2 A No, on Friday. 3 Q On Friday the 12th, correct. And he meets with 4 you. And were you in the restaurant at the time, or did 5 he -- 6 A Yes. 7 Q -- come up to your room? 8 A I believe at that -- on Friday -- I met them both 9 downstairs, as I recall. Actually, I may have been -- I 10 may have joined them -- I think I may have arrived at the 11 hotel and joined them downstairs, so I don't know -- 12 Q Okay. When you say that, was it Jesse and his 13 girlfriend and Mr. Minton? 14 A Unh-unh (negative). 15 Q Or just Jesse and Mr. Minton? 16 A Just Mr. Prince and Mr. Minton. 17 Q Okay. So they were already downstairs either in 18 the restaurant or someplace else, not in the room? 19 A Right, right. We met in the bar. They were just 20 waiting for me to go in to dinner. 21 Q Okay. And apparently this was -- Jesse is 22 already aware that Mr. Minton is taking a certain change of 23 position relative to the Church. And then -- 24 THE COURT: He knew that on the 9th when he 25 was in court. 0948
1 MR. LIROT: Exactly, Judge. 2 THE WITNESS: He knew that before. 3 THE COURT: Well, he certainly knew it as of 4 that night. 5 THE WITNESS: For sure, but he had known it 6 for months, your Honor. 7 BY MR. LIROT: 8 Q Well, how did he know about it for months? 9 A Well, not -- I should say for a couple of months. 10 Because he knew that we were initiating settlement. 11 Q How did he know? 12 A I had told him. I think Mr. Minton had also told 13 him. He was very excited. He was happy. He said great. 14 You know, he wanted to -- this is what he told us. He 15 wanted to be a music manager, he didn't want to do this 16 litigation anymore, he wanted his life back. And he said 17 many, many times to Mr. Minton that he was really glad that 18 this was happening. 19 Q When did you first start to talk to him about 20 this issue? 21 A Probably in -- somewhere in the middle of 2001. 22 Q So you're saying about June 2001, you were 23 already telling Mr. Prince that you had decided that you 24 were going to set the record straight and try to get 25 yourself extricated from all of this litigation? 0949
1 A No. In at least August of 2001, I was telling 2 Mr. Prince that I thought the wrongful death case was badly 3 off the rails, that it was endangering Mr. Minton. I 4 didn't talk to him about why, but I told him -- I told him 5 that I wanted to contact Ms. Liebreich and -- 6 THE COURT: Ms. who? 7 THE WITNESS: Ms. Liebreich, the -- 8 THE COURT: Oh, yes, okay. Yes. 9 A So Mr. Prince was aware. And Mr. Prince was also 10 saying to me and to Mr. Minton as early as August 2001 that 11 he also didn't want anything to do with the wrongful death, 12 he didn't want anything to do with Ken Dandar, he was very 13 upset with Ken Dandar for the affidavit that Mr. Dandar had 14 Jesse sign after -- in order to -- because Mr. Dandar 15 wanted to file the severe sanctions motion. He was 16 extremely upset about what Mr. Dandar had done at that 17 time. 18 BY MR. LIROT: 19 Q Okay. So at least he knows that you certainly 20 changed your position as of the middle of 2001 and now he 21 shows up and it's April -- April 9th, and he hears 22 Mr. Minton testifying and gets so depressed that he leaves. 23 Then on Friday, April 12th, he comes to the hotel, meets 24 Mr. Minton. You arrive. What was discussed then? 25 A Well, as I just said, we told him that we were -- 0950
1 we wanted to extricate ourselves from the situation that we 2 had gotten ourselves into. Jesse was very glad. He wanted 3 us to talk to him about it. We told him -- excuse me -- we 4 told him that -- and we were a little bit gentle about 5 this, but we told him that it was, you know -- that 6 settlement couldn't occur until the record was set 7 straight. 8 And I say we were a little bit gentle about this 9 because we felt that it had been -- well, it had been a 10 very, very difficult thing for Mr. Minton and myself to 11 come forward and basically put ourselves at the mercy of 12 these two courts in order to set the record straight. And 13 based on the difficulty that we had had -- 14 THE COURT: I'm sure your lawyers told you 15 that at least I as a judge, and I'm sure Judge Baird, 16 somebody is going to have to relay this information of 17 all these criminal accusations going back and forth to 18 the state attorney's office. 19 THE WITNESS: Yes. Yes, your Honor. 20 THE COURT: That certainly must be done. 21 THE WITNESS: Yes, your Honor. 22 A And we were not sure and I'm still not sure what 23 would become of us for having done this, but -- but we felt 24 that the alternative to coming forward and setting the 25 record straight was a whole lot worse. And so we felt that 0951
1 we really didn't have a choice but to do what we were 2 doing. And so -- 3 Q Well -- and I guess my question would be then, 4 you told Jesse to meet you again on Sunday and that you 5 would have the statements made by Judge Schaeffer about his 6 credibility? What happened? 7 A No, Mr. Lirot, that's not what I said. 8 Q I don't know. I'm asking the question. You 9 haven't testified to that yet. 10 A Yes, I did. Yes, I did, but I'll say it again. 11 So we were -- as I was -- just to finish my last sentence, 12 we were a little bit gentle about all of this with 13 Mr. Prince because we knew or we had reason to believe that 14 it was going to be an even more difficult reversal, 15 basically, for him. 16 And so we were being a little bit gentle about 17 it, and plus the fact that he still seemed to be not fully 18 recovered from what seemed to have been a fairly serious 19 breakdown of some sort from what he had described on 20 Tuesday, and also what his girlfriend had described. 21 So -- 22 Q Well, who was paying Mr. Prince at this time? 23 A Mr. Minton. 24 Q Still paying him up through April 12th? 25 A April 4th -- 0952
1 Q April 4th. 2 A -- was the last check, and I actually wrote a 3 check to Dee, his girlfriend, for $588, I think, the day 4 of -- at testimony of -- or, the day of -- one of the days 5 before Judge Baird in his hearing. 6 Q Sometime before -- 7 A So that was even more recent. 8 Q -- the 9th? 9 THE REPORTER: I'm sorry? 10 THE WITNESS: I said so that was even more 11 recent. 12 MR. FUGATE: I object to the interruption, 13 because I didn't hear. 14 THE COURT: I didn't either. I'm sorry, 15 wait till -- I think she wasn't quite done. 16 A What I said was that payment to her was even more 17 recent to her than April 4th. So -- so we felt that it was 18 important for Mr. Prince to understand how the Court felt 19 about his credibility and that perhaps if he understood how 20 the Court viewed his testimony that it might be a good sort 21 of an introduction for us to be able to talk to him about 22 the process of recantation. And that was the reason 23 Mr. Minton wanted to have that transcript of Judge 24 Schaeffer's -- I believe it was March 8th -- 25 THE COURT: I don't know. 0953
1 A -- hearing. 2 THE COURT: It was the hearing on the severe 3 sanctions, probably, that was heard. 4 THE WITNESS: Yes, exactly. 5 A So what we had in mind was that -- because Jesse 6 had said that he wanted to come and see us. And we had 7 said that we wanted to see him, we were good friends, we 8 were glad that he wanted to see us. We suggested that we 9 have dinner together on Sunday. 10 And I believe that the package was delivered in 11 the afternoon when we were -- before Mr. Prince got there. 12 But in any case, that was the reason -- 13 THE COURT: Ah, we're back now, this is 14 where the question started, the package. 15 THE WITNESS: Yes, yes. 16 THE COURT: This is the package you got. 17 THE WITNESS: Yes. 18 THE COURT: All right. 19 MR. LIROT: So -- 20 THE COURT: Don't just go on. I want to 21 hear about it now. So the documents came. 22 THE WITNESS: So the documents came. 23 THE COURT: All right. 24 A And so that was what it was. It was -- it was 25 Judge Baird -- I mean, Judge Schaeffer saying these things 0954
1 about Mr. Prince. And -- 2 BY MR. LIROT: 3 Q Well, wait a minute, I'm truly confused here. 4 We're talking about -- 5 THE COURT: Oh, my God, I hope we're not 6 going to have it all repeated. 7 MR. LIROT: No, no, no. 8 BY MR. LIROT: 9 Q On Friday the 12th -- 10 THE WITNESS: I promise I won't. 11 THE COURT: All right. 12 BY MR. LIROT: 13 Q Friday the 12th, you have no documents. So is 14 this Sunday that these documents are provided to you? 15 A Yes -- 16 Q Okay. 17 A -- the transcript of that hearing. 18 Q All right. Were there any other documents sent 19 over to Mr. Minton that he had that he pointed out to 20 Mr. Prince on Friday the 12th? 21 A Not that I know of. The -- 22 MR. FUGATE: Excuse me, I object to that. 23 There's nothing in the record that documents were sent 24 over on the 12th. 25 THE WITNESS: Oh, sorry. 0955
1 MR. FUGATE: I think she's talking about 2 Sunday the 14th. 3 THE COURT: Right. 4 BY MR. LIROT: 5 Q Okay. Let me ask you this. You got your 6 documents on the 15th from Mr. Fugate. When did Mr. Minton 7 get his records? Because I believe your testimony was he 8 got his records sometime before that. 9 A I believe that wasn't my testimony. I believe my 10 testimony was pretty clear, several times, that he -- very 11 many times -- that he got his documents the same day I got 12 mine from Mr. McGowan, when Mr. McGowan was with me. I was 13 given some documents, and Mr. Minton was given some 14 documents on that day. 15 The document that he was given or provided with 16 on Sunday the 14th had nothing to do with anything except 17 getting ready to try to talk to Jesse about what he was 18 going to have to do to recant. 19 Q So -- 20 A And -- 21 Q And who delivered these documents? 22 A I'm not sure. 23 Q Well, who did you ask to have them delivered to 24 you from? 25 A I believe he asked Mr. Rinder. 0956
1 Q Okay. 2 A And I believe someone just left it at the desk. 3 But now we were at the Radisson Hotel. 4 Q Okay. 5 A And I believe somebody just left it at the desk. 6 But anyway, so Jesse came. 7 Q Is it safe to say somebody from the Church? 8 A I would assume. 9 Q You asked Mr. Rinder -- 10 A I would assume. 11 Q Either somebody from the Church or some courier 12 service brings you over some documents, but it's at the 13 behest of Mr. Rinder? 14 A Yes. 15 Q Okay. So -- 16 THE COURT: At the behest of Mr. Rinder? 17 THE WITNESS: Well, at Mr. Minton's behest 18 of Mr. Rinder, who then must have behested someone 19 else. 20 MR. LIROT: It's a repeat behest. 21 THE COURT: Okay. I got it. 22 BY MR. LIROT: 23 Q All right. So did Mr. Minton pick these 24 documents up, or did he wait until Jesse got there and then 25 you all walked over to the desk and got them? Did he have 0957
1 them before Jesse arrived? 2 A As I recall, they were in the room. That's my 3 recollection. 4 Q Okay. So you're downstairs, you arrived, 5 Mr. Prince -- 6 A No, no, no. No. No, no, no, no. That was 7 Friday. 8 Q Okay. 9 A Okay. On Sunday, we had moved over to the 10 Radisson, and we were in Room 503. If you saw the posting 11 on the Internet that said where we were staying and our 12 room number, Jesse got it wrong. 13 THE COURT: He probably didn't go to the 14 Internet. I don't go to the Internet; he doesn't go 15 to the Internet. I guarantee you, probably most of 16 us -- probably nobody goes to the Internet. 17 A Well, Mr. Prince went back and informed 18 Mr. Dandar's people where we were staying and had it posted 19 on the Internet. 20 THE COURT: Well, I'm not going to attribute 21 that to Mr. Dandar. I think that there are some folks 22 here that are fairly -- what should we call them? I 23 don't know, whatever I would say. But anyway -- 24 MR. LIROT: Renegades. 25 THE COURT: Well, they're -- they're -- 0958
1 THE WITNESS: Loose cannons. 2 THE COURT: Yes. And I don't know why 3 anybody would want to post Mr. -- I can't imagine why 4 a lawyer would want to post Mr. Minton's room number 5 for those people. 6 THE WITNESS: Nor could I. 7 THE COURT: So, now, some of the -- I mean, 8 there's some people that feel very -- I hate to use 9 the word "rabid." It's so bad. People who feel very 10 strongly -- 11 THE WITNESS: Fervent. 12 THE COURT: Fervent. You were one of them. 13 I mean, there are people that feel very fervent about 14 one side or the other, and so they say hateful things 15 about the other side. But I don't know that a lawyer 16 trying a case would necessarily want to let somebody, 17 a rabid -- a fervent person know where somebody else 18 is staying. 19 THE WITNESS: I think "rabid" is good. 20 THE COURT: Rabid. I guess somebody will 21 say that I -- I guess I can't be charged with what I 22 say in court. Fairly rabid people. They were 23 fairly -- as I said, I went back and reread some of 24 the things that Mr. Minton had said -- 25 THE WITNESS: Oh, that was rabid. 0959
1 THE COURT: -- on the Internet. 2 THE WITNESS: This -- 3 THE COURT: That's what I said. Whatever 4 this person sent me in the mail couldn't begin to 5 compare with some of the Internet postings, if that's 6 what you call them, that I read. 7 THE WITNESS: He regrets those, your Honor. 8 And so -- 9 BY MR. LIROT: 10 Q So this is Sunday, and we're in Room 503. 11 A Right. And -- 12 Q And Jesse comes up to your room? 13 A Yes. I was in the room, and Mr. Minton was in 14 the room. And Jesse came up, and I -- we were waiting for 15 him, and -- excuse me -- I was very glad to have -- that he 16 was coming over. I was worried about him. 17 And I stuck my head out the door, and I saw him 18 coming from way down the hall -- or, not the hall, but the 19 balcony thing. And I went down to the end of the balcony 20 walkway and met him. And then we came -- we walked 21 together back to the room. 22 Q Was he alone, just him? 23 A Yes. 24 Q Okay. 25 A And I was asking how he was doing and was he 0960
1 okay. He smelled like alcohol. He was very intoxicated. 2 But -- well, I just -- you know, Jesse -- well, in any 3 case, he was very intoxicated and still didn't seem like 4 himself, and he was talking a little bit slurry. 5 Q How was it left on Friday? "Jesse, come on back 6 on Sunday, and we'll have something for you to look at 7 so --" 8 A No, Mr. Lirot. You tried that before, and it's 9 not what happened. 10 Q What did happen? 11 A We had a good dinner with him on Friday night, 12 and we -- and he left. And then I tried to call him on 13 Saturday -- or, I mean, I did call him on Saturday. He 14 wasn't home. I called in the mid afternoon and spoke to 15 one of Dee's -- Dee is his girlfriend -- one of Dee's 16 children, who said that he and Dee were gone and they said 17 they weren't going to be back all day. 18 Well, then on Sunday, I -- as we were walking 19 back to the room, I said, you know, "What did you guys do 20 yesterday?" 21 And Jesse said: "Well, we were just around the 22 house all day. I was just working outside and stuff." 23 Well, then I knew he was lying because he hadn't 24 been there all day and his -- the little boy wouldn't have 25 any reason to lie. So it was my feeling when Jesse said 0961
1 that that he was lying and that there was something really 2 wrong. But, you know, I wasn't sure -- I just thought that 3 he was not in good shape. I didn't -- I didn't think that 4 he was, you know, doing -- well, in any case, so we went 5 back into our room, and we sat down and -- 6 THE COURT: Are we still on trying to get 7 what these documents -- 8 THE WITNESS: I'm there right now, your 9 Honor. 10 THE COURT: Okay. 11 THE WITNESS: I'm there. 12 A We sat down in the little living room part of the 13 room, and we started talking. And Jesse was seeming a 14 little bit -- just not himself. He was just not acting 15 like the person that we had known before. He was acting a 16 little bit surly, a little bit challenging. But again, he 17 was drunk, so we weren't sure why. 18 And so Bob, Mr. Minton, began to tell Mr. Prince 19 about Judge Schaeffer's -- about the hearing before Judge 20 Schaeffer. And right away, Mr. Prince got very defensive, 21 and unfortunately when he got very defensive, then 22 Mr. Minton got a little bit edgy. 23 And so then Mr. Minton said: Listen, Jesse, you 24 know, this judge is -- doesn't think you have any 25 credibility at all. 0962
1 This isn't a quote, but this is basically what he 2 was saying: Judge Schaeffer doesn't think you have any 3 credibility to you at all, and, you know, you've got to 4 read this testimony about what she said. 5 And Mr. Prince said -- and by now he was really 6 acting surly. And he said: "Well, listen, Bobby, I don't 7 feel like sitting here reading it. Why don't you read 8 it -- why don't you tell me about it," like that. 9 And so then -- I mean, you have to understand 10 that these are two guys that have been really, really good 11 friends for a long time and have been through a lot 12 together. And so for -- for Mr. Prince to be talking to 13 Mr. Minton like that was really -- you know, just stunning 14 to Mr. Minton and to me. And so -- but, you know, 15 different people react in difference ways to being stunned. 16 I react by going, "Wait a minute, what's going on?" 17 Mr. Minton reacted by getting fairly angry. 18 And so he said: "Okay. Well, let me tell you 19 what she said. She said that you don't have any 20 credibility, that she doesn't think Ken ought to use you as 21 his expert, and that she's going to put you in jail," or 22 something like that. 23 Well, at that point, Mr. Prince stood up, and he 24 said -- I don't know, something like, you know, "Nobody 25 said I'm going to jail. What are you doing saying that I'm 0963
1 going to jail?" or, you know, something like this. 2 And I said, you know, "Look, you guys, why don't 3 we go downstairs and get something to eat," because I 4 figured food would be good. 5 BY MR. LIROT: 6 Q Had Mr. Minton been drinking that day? 7 A No. No, not that I remember. 8 Q Does Mr. Minton drink? 9 A Yes, he does. 10 Q Sometimes to excess? 11 A He has. 12 THE COURT: Well, what does that have to do 13 with anything? 14 THE WITNESS: He's just trying to impeach 15 Mr. Minton. 16 THE COURT: Well, no, he's not trying to 17 impeach Mr. Minton. In fact, you know how I get at 18 the end of the day? Annoyed? That has nothing to do 19 with this, unless Mr. Minton is, A, intoxicated while 20 he's testifying or close thereto, or at the time of 21 the event. So we don't need to get into his drinking 22 habits. 23 A So we went downstairs at my suggestion. And by 24 now both Mr. Prince and Mr. Minton were very on edge. And 25 we sat down in the restaurant of the Radisson and -- 0964
1 THE COURT: Have you asked a question? I 2 mean, we're just going on and on and on here. Are you 3 going somewhere? What is it you want to know? What 4 happened next? Is that it? 5 MR. LIROT: Judge, I want to know what 6 documents were referred to, and obviously I haven't 7 had much success cutting the witness off without being 8 chastised. 9 THE COURT: Well, Lord, all you have to do 10 is ask me: "Not responsive, your Honor." 11 "Sustained. Stop. We don't need any more." 12 This is your show. Run it. I don't mean 13 "show." 14 BY MR. LIROT: 15 Q What documents were in the hotel room on the 14th 16 that Mr. Minton showed Mr. Prince? 17 A As I said, the transcript of the testimony from 18 October 8th. 19 Q And that's it? 20 A I don't know of anything else. 21 Q Were there -- there wasn't a big, thick 11-inch 22 pile of documents that Mr. Minton pointed out to 23 Mr. Prince? 24 A I've got to tell you that's an hallucination, 25 Mr. Lirot. 0965
1 Q Okay. Was there any mention of the Armstrong 2 lawsuit to Mr. Prince when he was in your room on the 14th? 3 A Not that I recall. 4 Q Was there ever any mention of any threats being 5 made to Mr. Minton as part of this overall -- 6 A No. 7 Q -- global settlement? 8 A No. 9 Q Okay. 10 THE COURT: This is on this last night, this 11 Sunday -- 12 MR. LIROT: This is Sunday the 14th. 13 THE COURT: -- that we're talking about? 14 Okay. 15 BY MR. LIROT: 16 Q So -- so as I understand it, you point out -- or, 17 Mr. Minton summarizes Judge Schaeffer's views or statements 18 regarding Mr. Prince. And things get a little heated, and 19 you suggest everybody go downstairs and get something to 20 eat? 21 A Correct. 22 Q Okay. What happened next? 23 A Okay. So then what happened was we sat down at a 24 table. There was a woman with a young child sitting at a 25 table next to us. Mr. Prince starts -- and by now, 0966
1 Mr. Prince is having another drink, and now he's getting 2 very loud and very drunk. And he's telling -- and he's 3 sitting across from Mr. Minton, and I'm sitting, you know, 4 watching these two. 5 And Mr. Prince starts telling Mr. Minton this 6 whole story about how when -- when he was in Scientology, 7 he was awakened at 4:45 in the morning and he was summonsed 8 to Mr. Miscavige's office -- that's the head of 9 Scientology, your Honor -- and everybody was there in their 10 dress uniforms and, you know, all the head people of 11 Scientology. He named a lot of different people. And they 12 were all in the room, and they wanted him to go to the RPF. 13 That's the Rehabilitation Project Force, which is where 14 Scientology sends people when they screw up. 15 And he went back to his room, and he got a couple 16 of guns. And he brought those guns -- 17 THE COURT: Is this the place that's been 18 referred to as out in the desert? 19 THE WITNESS: Yes. Well, yes, he was out at 20 INT. That's what they call it. 21 THE COURT: What was it? 22 THE WITNESS: INT, short for 23 "international." 24 THE COURT: Okay. 25 BY MR. LIROT: 0967
1 Q So he gets boisterous, and you have him thrown 2 out, right? 3 A Hang on. No, no, no, no. You have the wrong 4 story here. Absolutely that is not what happened, 5 Mr. Lirot. So then -- 6 Q Let me back up. I appreciate your thoroughness 7 in responding to my questions. Why is Jesse part of this 8 deal? Why does he have to recant anything? 9 A He doesn't. 10 Q Well, why do you care about him? 11 A We cared about him a lot. He was our friend. We 12 were afraid that he was going to end up being caught 13 between these two ships, basically. 14 Q Obviously, he disagreed? 15 A He obviously -- he seems to now. He didn't act 16 like he did up until a few minutes -- I mean, I didn't 17 quite get to the part where we realized what was going on. 18 But up until a few minutes later from where I ended off the 19 story, we didn't know that. 20 And if -- if Mr. Prince doesn't want to recant, 21 if Mr. Prince doesn't want to get himself out of legal 22 trouble with the courts, that's up to Mr. Prince. We used 23 to think that it was up to us because he was our friend and 24 we've helped him out of other pretty serious legal 25 problems. 0968
1 Mr. Minton paid for his whole criminal trial when 2 he got caught with drugs. And, you know, it was sort of 3 our habit to take care of Mr. Prince when he got in 4 trouble. And we were planning on helping him again. 5 Q Was that part of this global settlement that was 6 discussed at these other meetings? 7 A Never came up. His name never came up. 8 Q What -- what do you know he said that was 9 untruthful in any testimony that he gave? 10 THE COURT: Oh, dear. I mean -- 11 BY MR. LIROT: 12 Q I guess I'll ask it this way. What did he need 13 to recant? 14 THE COURT: I mean, I don't know what all 15 she knows -- I don't know if Mr. Prince has filed 16 affidavits, Mr. Prince -- I don't know if she knows 17 when he's testified, where he's been. Can we just ask 18 that in general terms? I mean, maybe he's given a 19 bundle of depositions. How many did he give? 20 MR. LIROT: I don't know if he's given any. 21 Has he given any depositions? 22 MR. DANDAR: Two depositions -- one long, 23 seven-volume deposition. 24 MR. FUGATE: And he's filed a number of 25 affidavits. 0969
1 THE COURT: Okay. Seven volumes. How many 2 pages do you suppose that is? 3 MR. LIROT: Longer than I have the energy to 4 go over today, Judge. 5 THE COURT: Who took that one? Mr. Moxon? 6 MR. MOXON: No. Mr. Dandar has a lot of 7 them. 8 THE WITNESS: I think Mr. Weinberg took one 9 of them, and Mr. Rosen took another one. 10 THE COURT: Okay. Mr. Rosen seems to be 11 longer than either of you all. 12 MR. WEINBERG: He was announced as an 13 expert. I can't remember how long it was. We took a 14 couple of days of deposition. And then a lot of time 15 passed, and there were some other depositions which I 16 didn't do, but I can't remember what the dates of them 17 were. 18 THE WITNESS: But there was one with you at 19 the -- 20 MR. WEINBERG: At the Hyatt. 21 THE WITNESS: -- at the Hyatt in Tampa. 22 MR. WEINBERG: And you were there. 23 THE WITNESS: Yes. 24 BY MR. LIROT: 25 Q So -- 0970
1 THE COURT: Notice I didn't ask you all to 2 give me all those depositions. Seven volumes, I can't 3 do it. 4 MR. WEINBERG: I didn't think you wanted to 5 read those. 6 THE WITNESS: No. 7 MR. DANDAR: Three full days in November of 8 '99. 9 THE COURT: Okay. 10 MR. DANDAR: Two days in May of 2000. 11 THE WITNESS: In Denver. There was one of 12 them in Denver. 13 MR. DANDAR: That's another unrelated case. 14 MR. WEINBERG: Remember, your Honor, this 15 came right after Mr. Prince filed his affidavit about 16 end cycle and all these things. And then we were 17 allowed to take his deposition. And you might 18 imagine, the case having expanded, that he became a 19 central focus as far as we were concerned. 20 THE COURT: I just said I don't want to read 21 anymore. I'm not going to ask you all anymore for all 22 the depositions because you give them to me and I get 23 frustrated when I'm halfway through and think, "Oh, my 24 God, I can't believe I said I would read all of them." 25 BY MR. LIROT: 0971
1 Q So bottom line, Jesse, he didn't take your 2 suggestion or your advice on doing anything, did he? 3 A No. 4 Q And he ended up -- he left the hotel, no deal. 5 Safe to say? 6 MR. FUGATE: Your Honor, I object to "no 7 deal." I didn't hear any conversation about a deal. 8 THE WITNESS: Right. 9 A That's really not accurate. 10 BY MR. LIROT: 11 Q All right. He left the hotel and basically said, 12 "I'm not interested in following in your path of working 13 this case out or being in any way --" 14 THE COURT: That isn't what either he said 15 or she said or Mr. Minton said. 16 THE WITNESS: No. 17 THE COURT: So the deal is, Counselor, you'd 18 better just ask her what was said. Ask her what was 19 said by Mr. Prince. And then we'll ask Mr. Minton, 20 and we'll see if we get anything close to the same. 21 Don't you try to suggest it. You weren't there. 22 MR. LIROT: I wasn't there. 23 THE COURT: Either ask -- 24 MR. LIROT: I wasn't there. 25 THE COURT: Either ask or lead. 0972
1 A Do you want me to tell you? 2 BY MR. LIROT: 3 Q Tell me. 4 A Okay. 5 THE COURT: Preferably lead. But since you 6 haven't, go ahead. 7 MR. WEINBERG: Did you say "leave" or 8 "lead"? 9 THE COURT: "Lead." 10 MR. WEINBERG: I thought you meant "leave." 11 THE COURT: "Lead." Leading questions are 12 sometimes good. 13 A So Mr. Prince finished this whole story about 14 drawing these guns on these people. And then he said to 15 Mr. Minton something like, "I don't want to go down that 16 road with you, Bobby." 17 And Mr. Minton took that -- felt -- took that as 18 a threat. And he said, "What the hell are you talking 19 about, Jesse?" 20 And Jesse said, "You've become a Scientologist." 21 And that was when we understood that Jesse was 22 not with us and -- anymore. And so then some other words 23 were exchanged, and then Mr. Minton said, "You need to 24 get --" 25 Oh, oh, and this other thing that was happening 0973
1 was, he was using a lot of profanity, and Mr. Minton kept 2 asking him to stop because this woman and her child were 3 sitting right there and Mr. Prince just kept getting louder 4 and louder. And it was my feeling that he was just really, 5 really drunk. 6 And so I -- and so Mr. Minton got really mad and 7 said, "You need to get up and you need to leave this hotel 8 right now and I never want to see you again." 9 Well, okay, but he was angry, and Mr. Prince was 10 really drunk. And so I walked out with Mr. Prince to try 11 and talk to him about what had happened and, you know, get 12 him to go in and apologize to Mr. Minton. 13 But instead, Mr. Prince, as we were walking 14 towards his car, he started yelling and saying, you know -- 15 you know, "Bob's never done anything for me." 16 He -- well, he was using a lot of profanity, and 17 I was just really shocked at what he was saying, because I 18 mean, you can say a lot of things about Mr. Minton, but you 19 can't say that he's not done a lot for Jesse Prince. That 20 you cannot say. And for Mr. Prince to be talking that way, 21 it was just stunning to me. 22 And so I just stopped, and I just figured that he 23 needed to go home and get some sleep and sober up. 24 Q So you took him to his car, and that was the 25 end -- 0974
1 A Well, I didn't take him. He just walked on to 2 his car. 3 Q All right. And then you went back and joined 4 Mr. Minton? 5 A Yes. 6 Q All right. Now, did you speak with Mr. Prince 7 after that? 8 A Yes. The next day he called me. 9 THE COURT: Are we at a good stopping point 10 or are we about to end with this or do we have a lot 11 more? 12 MR. LIROT: Judge, after we go through this, 13 I wanted to go through the deposition -- not the 14 deposition, but the affidavit. This would be a good 15 stopping point. 16 THE COURT: The affidavit? 17 MR. LIROT: The 22-pager, and then I'm done. 18 THE COURT: Okay. All right. 19 THE WITNESS: Your Honor -- your Honor, can 20 we find out if I will be done tomorrow? 21 THE COURT: I don't think you will. I mean, 22 we just took a long time getting through one evening. 23 He's going to go through that 27-page [sic] affidavit. 24 There's a lot of stuff in there. I bet it will be 25 days. 0975
1 MR. LIROT: No, Judge, I won't make it last 2 days. 3 THE COURT: What's that? 4 MR. LIROT: I won't make it last days. 5 There are a number of questions I think are 6 relevant -- 7 THE COURT: I'm not -- trust me, as I said, 8 I'm not trying to cut you short. It just seems like 9 it's taking an awful long time to get whatever it is 10 you want out. 11 So I don't know if you'll be done tomorrow 12 or not. Why? Is there somewhere you need to be the 13 next day? 14 THE WITNESS: No, your Honor. 15 THE COURT: Just tired? 16 THE WITNESS: Yes, your Honor. 17 THE COURT: If you're tired, understand 18 this. When you're done, I'm not. So there you go. 19 THE WITNESS: Your Honor, I'm sure you're a 20 lot more tired of this than I am. 21 THE COURT: All right. You can count on it. 22 We're going to stop for the day. Oh, I did 23 want to -- 24 MR. McGOWAN: Judge -- 25 THE COURT: Yes, we were going to talk about 0976
1 the -- 2 You can step down. 3 I wanted to take up that motion, but you 4 know what? I'm tired, and I don't feel like doing 5 justice to a legal matter, so -- 6 MR. McGOWAN: That's fine. 7 THE COURT: -- can we do it in the morning? 8 9 o'clock? 9 You all don't have to be here. We'll take 10 up this legal whatever it is that they want to object 11 to. Who was it who produced? They did. 12 You're all welcome to come, but if you 13 don't, this is going to be a legal argument. 14 MR. McGOWAN: What time did you tell 15 Ms. Brooks? 16 THE COURT: 9:30? Is that okay? 17 THE WITNESS: Yes, your Honor. 18 THE COURT: Is that okay with you all? Do 19 you think half an hour, we can do the motions? 20 MR. McGOWAN: That's fine. 21 THE COURT: Well, we're going to take up 22 this motion at 9, so -- 23 THE WITNESS: Better be here. 24 THE COURT: This has to do with your income 25 tax and LMT's tax returns, so you might want to be 0977
1 here for it. 2 See you all tomorrow at 9 o'clock. 3 (Court adjourned at 5:07 p.m.) 4 ____________________________________ 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0978
1 STATE OF FLORIDA 2 COUNTY OF PINELLAS 3 I, Debra S. (Laughbaum) Turner, Registered Diplomate 4 Reporter, certify that I was authorized to and did 5 stenographically report the foregoing proceedings and that 6 the transcript is a true record. 7 WITNESS MY HAND this 14th day of May, 2002, at 8 St. Petersburg, Pinellas County, Florida. 9 10 _________________________________ Debra S. (Laughbaum) Turner, RDR 11 Court Reporter 12 13 14 15 16 17 18 19 20 21 22 23 24 25

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