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           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 3
           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
                CONTENTS:           Testimony of Jesse Prince.
          17
                DATE:               July 8, 2002.  Afternoon Session.
          18
                PLACE:              Courtroom B, Judicial Building
          19                        St. Petersburg, Florida.
          20    BEFORE:             Honorable Susan F. Schaeffer,
                                    Circuit Judge.
          21
                REPORTED BY:        Lynne J. Ide, RMR.
          22                        Deputy Official Court Reporter,
                                    Sixth Judicial Circuit of Florida.
          23
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           1    APPEARANCES:
           2
                MR. KENNAN G. DANDAR
           3    DANDAR & DANDAR
                5340 West Kennedy Boulevard
           4    Suite 201
                Tampa, Florida  33602
           5    Attorney for Plaintiff.
           6
                MR. LUKE CHARLES LIROT
           7    LUKE CHARLES LIROT, PA
                112 N. East Street
           8    Suite B
                Tampa, Florida 33602-4108
           9    Attorney for Plaintiff
          10
                MR. KENDRICK MOXON
          11    MOXON & KOBRIN
                1100 Cleveland Street
          12    Suite 900
                Clearwater, Florida  33755
          13    Attorney for Church of Scientology Flag Service
                Organization.
          14
          15    MR. LEE FUGATE
                MR. MORRIS WEINBERG, JR.
          16    ZUCKERMAN, SPAEDER
                101 E. Kennedy Blvd
          17    Suite 1200
                Tampa, Florida 33602-5147
          18    Attorney for Church of Scientology Flag Service
                Organization.
          19
          20    MR. ERIC M. LIEBERMAN
                RABINOWITZ, BOUDIN, STANDARD
          21    740 Broadway at Astor Place
                New York, New York 10003-9518
          22    Attorney for Church of Scientology Flag Service
                Organization.
          23
          24
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           1    APPEARANCES:
                (Continued)
           2
           3    MR. ANTHONY S. BATTAGLIA
                Battaglia, Ross, Dicus & Wein, P.A.
           4    980 Tyrone Boulevard
                St. Petersburg, Florida  33710
           5    Counsel for Robert Minton.
           6
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           1              THE COURT:  Mr. Prince, you all may be seated.
           2              MR. DANDAR:  Judge, I just was advised by my
           3         office that Judge Baird wants us to be at a hearing
           4         tomorrow by telephone.  And I'm going to be here and
           5         my brother is covering another hearing for me in
           6         Tampa.  But Judge Baird wants to go forward with the
           7         hearing by telephone.  So I would ask that you let
           8         me attend that hearing by phone.
           9              THE COURT:  What time?
          10              MR. DANDAR:  Nine o'clock.
          11              THE COURT:  Okay.  How long is the hearing
          12         expected --
          13              MR. DANDAR:  I have no idea.
          14              THE COURT:  Well, that is no good.  What kind
          15         of motion is it?
          16              MR. DANDAR:  It was the Flag's -- or RTC's --
          17         actually, Mr. Rosen and Mr. Pope's motion to strike
          18         our pleading challenging the domestication of the
          19         Texas judgment against the estate.
          20              THE COURT:  So it's legal --
          21              MR. DANDAR:  Right.  We had a hearing on that
          22         Tuesday at about 5 o'clock before July 4 and we
          23         filed a supplemental memorandum of law and they
          24         filed a response over the holiday, so I guess we'll
          25         discuss that.
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           1              THE COURT:  You think an hour?
           2              MR. DANDAR:  I hope not.  I don't think so.
           3         But --
           4              MR. WEINBERG:  I'm told not that long.  About
           5         thirty minutes.
           6              THE COURT:  Okay.  Well, let's plan on starting
           7         at ten o'clock anyway.
           8              MR. WEINBERG:  All right.
           9              THE COURT:  All right, go ahead, Mr. Dandar.
          10         Mr. Prince indicated he didn't give us his full
          11         explanation, so you can go ahead with that.
          12              MR. DANDAR:  Okay, before he does that, could I
          13         give him a document that I had the clerk just mark?
          14    BY MR. DANDAR:
          15         Q    Well, Mr. Prince, go ahead, give us the full
          16    explanation of why you have the opinion that Lisa McPherson
          17    was dead because of an end cycle order?
          18         A    Okay.  Lisa McPherson went to the hospital.
          19    From -- from the records that I can see from the doctor,
          20    they didn't indicate that she was psychotic and needed to be
          21    Baker Acted.
          22              Now, we're talking about terms here that mean
          23    different things to different people.  In the hospital they
          24    define psychosis the way they define it and, thus, Baker Act
          25    people.  In Scientology, they have a different definition
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           1    for a person, a psychotic or suffering from psychosis.
           2              One of the definitions, reasoning of what
           3    psychosis is in Scientology, is in their Case Supervisor
           4    Series 22, which has been entered in on the record, I'm
           5    sure, many times.  And this is concerning psychosis.
           6              Now, it says here --
           7              THE COURT:  I don't know if it has been or not.
           8         I think you're looking in that one book?
           9              THE WITNESS:  Yes, ma'am.
          10              THE COURT:  I'm not sure if that whole book was
          11         introduced.
          12              THE WITNESS:  No.  No.  Not the whole book.
          13         But this issue here, psychosis, has been an exhibit.
          14         We can put it in again.
          15              THE COURT:  I don't know if it has or not.
          16              MR. WEINBERG:  I don't think it has.
          17              THE WITNESS:  Okay.  Well, when I finish
          18         explaining it, I'll hand it over.
          19              MR. DANDAR:  We'll mark it.
          20              THE COURT:  All right.
          21         A    It says -- down here at the beginning of this
          22    issue here on psychosis, it says, "All characteristics
          23    classified as those of a suppressive person are, in fact,
          24    those of an insane person."
          25              So, in other words, it is the belief of
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           1    Scientology that a person who they consider to be
           2    suppressive and has those characteristics are also insane
           3    people, you see.  So we're working with two different
           4    definitions here.
           5              Now, if this person -- if Lisa was taken to the
           6    hospital and they said okay, she's not insane, she's just
           7    having problems, she can work it out, she gets to
           8    Scientology, she's insane.  They are the ones that classify
           9    her as being insane.
          10              Why do they classify her as -- well, one of the
          11    reasons they classify her as being insane is because she
          12    wants to leave.  And again that is mentioned here in this
          13    book here of people wanting to leave as also being
          14    psychotic.
          15              So my thing is this.  Lisa McPherson was taken to
          16    the Ft. Harrison.  Prior to being -- to this whole incident
          17    with going to the hospital and everything, she made her
          18    intentions to the Church known, to her friends, to her
          19    family, she wants to leave.  In their minds, she's
          20    psychotic.  Medically, not necessarily so, she simply
          21    doesn't want to do it anymore.
          22              It has become a matter of PR concern because she
          23    had the accident with the boat, you know.  She's left,
          24    she's --
          25              THE COURT:  I'm sorry, she had the what?
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           1              THE WITNESS:  The accident with the boat, where
           2         she ran into the back of the boat and took off her
           3         clothes.
           4              THE COURT:  Oh, okay.
           5         A    Okay?  This is something a person now who again,
           6    two months earlier, just testified to being more than human,
           7    more than a homo sapiens, this person is a homo novis.  This
           8    person is almost like a demigod.
           9              Now, this person is brought to the Ft. Harrison.
          10    In my mind, my opinion, she came in there, she said, "I want
          11    to leave."  She didn't change her mind.  She's delegated to
          12    be psychotic.  They want to put her on introspection
          13    rundown.  She's incarcerated.
          14              In that book "What Is Scientology," it gives a
          15    definition of introspection rundown and gives a brief
          16    summary of introspection rundown that the public people can
          17    read.
          18              MR. DANDAR:  Let me hand this to the witness,
          19         Judge.  It is Exhibit 125, just marked by the clerk
          20         from "What Is Scientology," which I believe you have
          21         the entire book.
          22              THE COURT:  Yes.
          23         A    It says "Introspection Rundown.  This is a service
          24    that helps to preclear, locate and correct things which
          25    cause him to have his attention inwardly fixated.  He then
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           1    becomes capable of looking outward so he can see his
           2    environment, handle and control it."
           3              Nothing in here, one, if Scientology labels you
           4    psychotic, you are going to be incarcerated until a case
           5    supervisor tells you you can leave.  There is nothing in
           6    here that warns anyone of that.
           7              So Lisa was taken to the Ft. Harrison, deemed to
           8    be psychotic, put on the introspection rundown.
           9              Well, when did that come up that we even found out
          10    that Lisa was on introspection rundown?  After Alain
          11    Kartuzinski and other people were given use immunity when
          12    they were first saying she's a hotel guest, now the
          13    investigators want to hear the story, "Oh, she was on
          14    introspection rundown."  Okay.  So she's on introspection
          15    rundown the second day.
          16              And to me -- again, she told them, "I want to
          17    leave."  They wouldn't let her leave.  She gets violent.
          18    The next day they order the drugs to put her down.
          19    BY MR. DANDAR:
          20         Q    What drugs?
          21         A    I think it is chloral hydrate or Valium.  Alain
          22    Kartuzinski gave some money for Valium.  And if you look and
          23    see what Scientology says about drugs, psychiatric drugs,
          24    all of these things, these things are expressly prohibited.
          25              Now, so far what we've seen, we see Scientology's
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           1    policy if a person is sick, when you take them to the
           2    hospital, make sure -- but now we see things happening
           3    that -- that are outside of that.  By their own policy we
           4    see things they are not following that.  That is a huge
           5    no-no.
           6              We are at the place where policy and tech is
           7    applied 100 percent correctly standardly in every case, but
           8    somehow in this instance we have so many instances where
           9    this person -- they are not doing it, they are not doing it.
          10              And the reason why, you have to look behind that.
          11    And the reason, my contention is, is that she expressly
          12    wanted to leave, it escalated to her actually threatening,
          13    probably threatening with legal, threatening with law
          14    enforcement or whatever.  This became a problem.  OSA was
          15    there from the very beginning, reporting about this, the
          16    very beginning, because this is a legal threat, this is a
          17    problem in Scientology.
          18              So maybe they did try an introspection rundown on
          19    her.  You know, they say they did.  Maybe they did.  But I
          20    think she never agreed to it.  I think that she decided she
          21    was done with Scientology, no matter what they said to her,
          22    she would no longer agree to it, because by her own word, it
          23    was making her sicker.
          24              So instead, because of what happened, when they
          25    saw Lisa's deteriorating condition, in their minds Lisa is
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           1    on the process.  She's on introspection rundown.
           2              Scientology has further policy, the way out is the
           3    way through, get the PC through it.  What turns it on or
           4    turns it off.  In their minds, whatever she's going through
           5    is part of the process.
           6              Plus, you have the added fear that if this person
           7    isn't reconciled with Scientology, it's going to be a big
           8    problem.
           9              So instead of taking this girl to the hospital
          10    where she should have belonged, where their own policy says
          11    to do, and get her medical treatment, when it was obvious,
          12    by the reports that I have seen that she was ill, instead of
          13    doing that, no, we're going to keep doing Scientology
          14    because that is what it means by Keeping Scientology Working
          15    and, you know, what happens happens.  Some of them don't
          16    make it.  Too bad.
          17              But the biggest fear for Scientology was to let
          18    this girl go, in the state of mind where she was refusing to
          19    cooperate with them, caused them more problems than her
          20    actual death.
          21         Q    How do you get to your conclusion that her death
          22    was a result of an end cycle, let her die order from
          23    Mr. Miscavige?
          24         A    During my tenure in -- in RTC, we would have staff
          25    meetings that had a pattern to the staff meetings.  And the
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           1    patterns were this.  What are the flaps?  What are the
           2    handling for those flaps?  Those are the first things that
           3    are discussed and chewed around and taken care of.
           4         Q    With whom?
           5         A    Amongst the executives and the staff in any
           6    particular organization.  Any particular Sea Org
           7    organization, I should say.
           8         Q    At RTC, who were the meetings with that you had?
           9         A    Flaps and handling?  They would entail myself,
          10    Vicki Aznaran, Mark Yaeger, David Miscavige, Lymon Sperlock,
          11    Norman Starkey (phonetic), in some instances the executive
          12    director in the national if it had to do with stats.  But
          13    those were the people that ultimately had to know what was
          14    going on.
          15              Now, why is Flag Service Organization so
          16    important?  Because the Flag Service Organization, when I
          17    left here in 1982, made an income of over 2 million a week.
          18    So you have an organization here that makes $8 million in a
          19    month.  This is -- it is the highest income-producing
          20    organization within Scientology.
          21              It's a major concern that everything is perfect at
          22    the Flag Service Organization.  There is not going to be an
          23    instance where no one knows what is going on.  So in the
          24    staff meetings you talk about flaps and handling.
          25              Well, Lisa is a flap.  It's reported up the lines.
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           1    OSA is there from the very beginning because she is a legal
           2    threat because it is a flap.  And they are busy reporting,
           3    you know, on the legal side of it and what is going on and
           4    the repercussions.
           5              They are also coordinating and in liaison with the
           6    technical area that has the technical program that they are
           7    trying to get her through, which in their minds is going to
           8    cure her.
           9              Everyone knows -- I believe there is also
          10    testimony on the -- during the time period that Lisa was
          11    going through this trouble, Mr. Miscavige was there.  We
          12    would often go to the Flag Service Organization, to inspect
          13    it, to make sure it is running properly, to make sure this
          14    technology is being applied 100 percent standard.
          15         Q    What are you relying on when you say Mr. Miscavige
          16    was at the Ft. Harrison Hotel in this time period?
          17         A    I believe some -- a public person who -- I don't
          18    recall the name right now -- something that I read mentioned
          19    the fact that he was there.  And -- he was at post.
          20         Q    This public Scientologist saw Mr. Miscavige?
          21         A    Yes.
          22         Q    Was that in the police files of the Clearwater
          23    Police files?
          24         A    Yes.
          25         Q    Okay.
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           1         A    So your largest income-making --
           2              THE COURT:  Where is that?
           3              MR. DANDAR:  I have it.  I'll introduce it,
           4         Judge.  In fact, I have it on my computer.  I'll
           5         print it out on my next break.
           6              THE COURT:  Okay.
           7              MR. DANDAR:  It is Detective Carrasquillo of
           8         the Clearwater Police Department interviewed four, I
           9         believe, public Scientologists staying in the
          10         cabanas who heard nothing during this time period,
          11         who saw Mr. Miscavige --
          12              MR. WEINBERG:  Excuse me, your Honor, is Mr.
          13         Dandar testifying?  Or is he asking questions?
          14              THE COURT:  I just asked him a question.  He's
          15         responding to me.  I was saying --
          16              MR. DANDAR:  It is a four-page document.  It's
          17         on my computer.  I can print it out.
          18              THE COURT:  Okay.
          19         A    So, you know, from the limited time that I was
          20    there in the Religious Technology Center myself, I know
          21    that, you know, there wasn't much about the Flag Service
          22    Organization that I didn't know about and also had
          23    responsibilities for to make sure that the whole thing ran
          24    smoothly.  And the person that I reported to was certainly
          25    the -- ultimately was Mr. Miscavige.
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           1    BY MR. DANDAR:
           2         Q    Okay.
           3         A    And I am saying here today -- and the reason I
           4    came to that conclusion -- is by their own written policies
           5    that they have written here, you start to see violations.
           6    And the reason why is because there was a problem.  There
           7    was a legal threat.  Lisa was not cooperating with them.
           8              When I did the introspection rundown on the other
           9    girl, she was cooperating.  She wasn't trying to leave.  She
          10    was going along with it.  She never mentioned that she
          11    wanted to leave at any other time.  There is a big
          12    difference.
          13              So now you have a person that wants to leave, has
          14    publicly stated they want to leave to their friends, to
          15    their family, to the auditor.  That is a no-no.
          16         Q    How did you --
          17         A    Again, there is reference where a person wants to
          18    leave is psychotic.  So now they have put this label on her.
          19    She's locked in a room.  She's terrified.  Instead of taking
          20    her to the hospital when she was sick and letting her get
          21    treatment because of her state of mind and because of the
          22    way she felt about Scientology, they opted to just continue
          23    the process, and either it works or it doesn't.
          24         Q    Well, Heather Hof, who was a 17-year-old ethics
          25    officer, or studying to be an ethics officer, inspection
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           1    reports, all her records, are missing.  She testified in
           2    deposition that she hand-delivered her reports to
           3    Mr. Kartuzinski, saying as early as December 2, I believe,
           4    Lisa McPherson wasn't eating or drinking enough to survive,
           5    something had to change, Heather was frantic.  The --
           6              MR. WEINBERG:  Your Honor, objection.  He's
           7         just testifying.  This isn't a question.  This is
           8         just Mr. Dandar summarizing -- and I would say
           9         missummarizing -- what he thinks the testimony has
          10         been.  It's not a question.  It's a statement.
          11              THE COURT:  Well, I suspect that he's saying,
          12         "Mr. Prince, if this is her testimony."  That is
          13         what you do with an expert sometimes.  So if that is
          14         what he's doing, I'll allow it, I guess, with the
          15         question.
          16    BY MR. DANDAR:
          17         Q    So I'm assuming I'm accurate in my recollection of
          18    what Heather Hof testified to the police, as well as her
          19    deposition in this case, and the pathologist retained by the
          20    estate, that Lisa was in a coma that she could be shaken out
          21    of but she would go back into, five days -- the last five
          22    days of her life.  And in reading -- in what you know and
          23    reading what you just told us you read, why is it your
          24    opinion that they would just simply let her die rather than
          25    take her to the hospital?
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           1         A    Because she was not settled with her relationship
           2    with Scientology.  And this would have caused tremendous
           3    problems for them.  If they would have taken her -- you
           4    know, even during the period of time when she was going in
           5    and out of the coma and say she goes to the hospital now,
           6    she starts getting treatment, she's getting better, you
           7    know, Scientologists come around, she now tells the doctors,
           8    "No, I don't want to see them anymore, I have to get away
           9    from this."
          10         Q    Mr. Prince, I guess the crux of the matter is
          11    you -- you put together an affidavit that is dated August of
          12    1999.  Do you recall that?
          13         A    Yes, I do.
          14         Q    Where you talk about the role of David Miscavige
          15    and Mr. Mithoff and Marty Rathbun and your prior history in
          16    RTC.  Do you remember that?
          17         A    Yes.  I do.
          18         Q    And in that affidavit you have come to the
          19    conclusion that the three of them just decided to sit around
          20    and not do anything about it and end cycle Lisa McPherson?
          21         A    Yes.  If she dies, she dies.  If she gets better,
          22    she gets better.
          23         Q    Now, did I help you write that affidavit?
          24         A    Not at all.  This affidavit came about because --
          25    from studying all of the evidence.  And I spent months
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           1    studying this to come to this conclusion.  This conclusion I
           2    came to was my personal opinion, I stated it as such, based
           3    on the experience I have within that organization.
           4              And the thing that -- that became alarming to me
           5    to even point me in this direction is the amount of
           6    information that is missing, the amount of things that --
           7    that isn't there that would clearly show like what her state
           8    of mind was based on what she was saying.  All of that is
           9    missing.  Which means cover-up.  Which means something is
          10    hidden.  Why is something hidden?
          11              In my mind, similar to what happened in
          12    Wollersheim.  This is information, if gotten out, could be
          13    harmful or damaging to Scientology.  And Scientology, the
          14    survival of Scientology, is first and foremost in the mind
          15    of any Scientologist, even beyond their own lives.
          16         Q    Did Stacy Brooks put you in the mood to write this
          17    affidavit?  Did she kind of persuade you to write this
          18    affidavit?
          19         A    No.  Put me in the mood?  I guess I didn't
          20    understand.
          21         Q    Okay.  Did she influence you in any way whatsoever
          22    to get you to write this affidavit where you conclude that
          23    Mr. Miscavige and others had decided to issue the end cycle
          24    order?
          25         A    No.  Matter of fact, Stacy disagreed with my
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           1    opinion about that.  She disagreed with it.  But -- and
           2    we've had discussions about this.
           3              I mean, you know, I did it outside of her.  Stacy
           4    was nowhere around when I did my affidavit.  And she asked
           5    me why I came to that conclusion.  I mean, we've had
           6    in-depth conversations about that, because Stacy was not in
           7    the position I was in to be able to make that determination.
           8         Q    Did anybody -- let's even go to Bob Minton.  Did
           9    Bob Minton suggest to you, order you, tell you in any way,
          10    shape or form what to put in that affidavit?
          11         A    No.  Bob Minton was so disrelated from anything
          12    that I was doing in this case.
          13         Q    Really?  How so?  I mean, wasn't involved at all?
          14         A    Bob Minton never cared about the particulars that
          15    was going on in this Lisa McPherson case.  He never
          16    concerned himself with that.
          17              His words to me were, "I have hired Ken.  He's got
          18    the money.  He's the best one that -- the best lawyer I
          19    could think of to do it.  It's his job.  It's his
          20    responsibility."
          21         Q    Did Bob Minton say he hired me, Ken Dandar?
          22         A    No.  No.  He just said you were the attorney of
          23    record.  He trusted you.  You could --
          24         Q    Did you ever hear Bob Minton say to you, or to me
          25    in your presence, that -- ordering me to charge David
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           1    Miscavige with -- in the civil case with murder?
           2         A    Absolutely not.
           3         Q    Did anyone -- maybe I haven't mentioned the right
           4    name, I don't know.  Let's just cover the whole waterfront.
           5              Is there anyone that gave you direction or
           6    influenced you in any way on how to write that affidavit and
           7    what conclusions you reached in that affidavit?
           8         A    None at all.  No one.
           9         Q    Now, the only other end cycle orders you have seen
          10    when you were in RTC, did they only have to do with people
          11    who had a terminal illness?
          12         A    That is correct.
          13         Q    Did you ever come across another circumstance like
          14    Lisa McPherson where an end cycle order was given and the
          15    person did not have a known, medically diagnosed by a
          16    licensed medical doctor, terminal illness?
          17         A    No.  With the exception of what I told you about
          18    John Nelson, of course.
          19              MR. DANDAR:  All right.  Judge, just in case it
          20         is not present, I just want to go ahead and I marked
          21         this affidavit that we've been talking about as
          22         Plaintiff's Exhibit Number 126.  And I'm sure you
          23         have so many copies of this already.
          24              THE COURT:  Is this the one that is 108?
          25              MR. DANDAR:  No.  That is the PC folder one,
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           1         108.
           2              THE COURT:  Oh, okay.
           3              MR. DANDAR:  This is the one that talks about
           4         end cycle.
           5              THE COURT:  All right.
           6              MR. DANDAR:  This is what Paragraph 34 of the
           7         fifth amended complaint is dependent upon.  I would
           8         like to move 126 into evidence.
           9              MR. WEINBERG:  It is already in evidence,
          10         but --
          11              THE COURT:  Yes, it is in, but we'll let it in
          12         again.
          13              MR. DANDAR:  Somewhere.  I'm not sure where.
          14    BY MR. DANDAR:
          15         Q    Now, Mr. Prince, do you recall seeing, in the
          16    deposition testimony of Judy Goldsberry-Webber and
          17    Dr. Houghton and Kartuzinski, that liquid injectable Valium
          18    was picked up twice, two separate times, at two different
          19    places for Lisa McPherson?
          20         A    Yes.
          21              MR. WEINBERG:  I object.  This just isn't
          22         proper.  Do you recall seeing somebody else's
          23         testimony?  I mean, we should be asking Mr. Prince
          24         about his testimony, whatever it is, not what he
          25         recalls somebody else's has testified to.
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           1              THE COURT:  Well, if he read -- just remember,
           2         Mr. Prince was his consultant.  If he read some of
           3         these depositions in some fashion to assist him with
           4         his testimony, I mean, I already heard him talking
           5         about Valium which he thought --
           6              MR. WEINBERG:  Which was never given to
           7         Ms. Lisa McPherson.
           8              THE COURT:  Well, I know that.  But we want to
           9         listen to what it is he says.
          10              MR. WEINBERG:  Okay.
          11              THE COURT:  I know that.  And I know
          12         Kartuzinski was the one who said, "No, we don't use
          13         Valium."  So, I mean, I know this case a little
          14         differently from what Mr. Prince does.  But I
          15         haven't been to all of the depositions and I haven't
          16         read all of the depositions.  But I know what I know
          17         from this hearing.
          18              MR. WEINBERG:  All right.
          19              THE COURT:  And that is that Dr. whatever his
          20         name is prescribed the Valium.
          21              MR. DANDAR:  Minkoff.
          22              THE COURT:  And Kartuzinski said no.  That is
          23         all I know.
          24    BY MR. DANDAR:
          25         Q    Mr. Prince, can you tell us how it is that the
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           1    organization works where if Dr. Minkoff, as he testified,
           2    ordered injectable Valium twice for Lisa McPherson, how
           3    would the org go about procuring that Valium from a public
           4    drug store?
           5         A    Well, you would have to use -- you know,
           6    Scientology in itself is a closed system to that degree
           7    because it does disagree -- seemingly disagrees with
           8    psychiatric medicines, the use of psychiatric medicines.
           9              However, in -- in the case of introspection and a
          10    person that is psychotic, there are references of using
          11    drugs to treat those people.
          12              But Scientology would only go to another
          13    Scientologist who would have that same understanding that
          14    would provide what they needed because they are kind of like
          15    on the same track.  I have never seen it work where a doctor
          16    outside of Scientology would do that.
          17         Q    Well, how does the organization work to go about
          18    getting the money approved to push the prescriptions?
          19              MR. WEINBERG:  Well, I'm sorry to interrupt.
          20         But he's asking how Flag would have gotten the money
          21         in 1995 or whenever it was.  He wasn't there.  He
          22         wouldn't know that.
          23              THE COURT:  Well, he can testify as to what he
          24         knew when he was there.
          25              MR. WEINBERG:  In 1982?  I mean, it's just --
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           1         okay.
           2              THE COURT:  I mean, he -- this is what he based
           3         his opinion on.  If it had to do with 1982 we just
           4         have to take that into consideration.
           5         A    Well, there is a simple answer to the question
           6    because it's a Scientology policy, it's called CSW,
           7    completed staff work.  Whenever the organization is expected
           8    to -- is expected to finance or pay for something, a
           9    document is submitted that -- to the person senior and
          10    financial persons within Scientology that explains what the
          11    situation is, what the handling of it is.
          12              If the situation is a person is psychotic and --
          13    you know, and in need of drugs, according to this reference,
          14    and handling is to buy the drugs, and then this is okay and
          15    they sign it and that gets passed along, the drugs are
          16    purchased.
          17    BY MR. DANDAR:
          18         Q    So it gets passed along to who?
          19         A    If it was an emergency CSW, which would be
          20    accompanied with a purchase order, if it is an emergency CSW
          21    with an accompanying purchase order, it would normally go
          22    from the person who originated the CSW, to his immediate
          23    senior, to the commanding officer or whoever that person
          24    designated to be in authority to instantly approve moneys
          25    expended by the organization.
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           1         Q    And have you seen a CSW for any of the
           2    prescription drugs purchased for Lisa McPherson?
           3         A    No, I have not.
           4              THE COURT:  What was the CSW again?
           5              THE WITNESS:  Completed staff work.
           6              THE COURT:  Thank you.
           7    BY MR. DANDAR:
           8         Q    If -- if the pathologist retained by the state who
           9    say that she's in a coma, it was obvious for five days that
          10    she wasn't getting any better, she was getting worse, if
          11    Heather Hof, in my recollection of what she said, is correct
          12    that she was -- Lisa was getting worse as early as
          13    December 2, if that is all true, is there any other
          14    explanation that you can think of that would explain why
          15    nothing was done sooner for Lisa McPherson?
          16              MR. WEINBERG:  I object to the form of the
          17         question, your Honor, as a completely improper
          18         hypothetical.
          19              THE COURT:  Overruled.
          20         A    You know, again, I have studied for 16 years these
          21    issues, this stuff with red writing, this stuff with black
          22    writing, called staff writing; the only -- this is the way I
          23    opine this way, the only reason she would have been treated
          24    this way is because she was a threat to Scientology.
          25              And Scientology has a principle called the
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           1    greatest good for the greatest number of the dynamics.  The
           2    dynamics being the different areas of life that L. Ron
           3    Hubbard codified or, you know, decided this is the way it
           4    was.
           5              In Scientology, the overriding principle is to
           6    protect Scientology.  That is the greatest good.  For her to
           7    go in a bad condition to the hospital, complain of what
           8    Scientology did to her, to create bad publicity for them,
           9    possible lawsuits, possible investigation by law enforcement
          10    because she was incarcerated, held against her will, was not
          11    anything anyone wanted to deal with.
          12    BY MR. DANDAR:
          13         Q    How could letting someone die be less of a PR flap
          14    than taking them to the hospital while they are alive?
          15         A    Well, I think it is an empirical fact, because it
          16    wasn't -- it was virtually unheard of until a year after her
          17    death.  When you do enough cover-up -- I mean, you know, not
          18    until a year after her death was it even known what happened
          19    to her.  So it worked for a while.
          20         Q    Okay.  Let's go to --
          21              THE COURT:  I have just got to ask a question
          22         there.  And I had so many but I didn't want to
          23         interrupt Mr. Prince.
          24              She went straight to the medical examiner.
          25         Right?  I mean, from the hospital to the medical
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           1         examiner?
           2              THE WITNESS:  Right, with meningitis.
           3              THE COURT:  Well, whatever.  There is a medical
           4         examiner who is the one that determines cause of
           5         death in this city.
           6              THE WITNESS:  Correct.
           7              THE COURT:  If she had been stabbed, if she had
           8         been dehydrated, if she had been shot, whatever it
           9         is, you take a dead body to the medical examiner
          10         when they are not under a doctor's care for the
          11         medical examiner to say what is the cause of death.
          12              THE WITNESS:  Correct.
          13              THE COURT:  Right?
          14              THE WITNESS:  Correct.
          15              THE COURT:  I don't know how long it took her
          16         to do her work.  But the deal was as far as the
          17         Church would be concerned, she was delivered to the
          18         medical examiner to determine cause of death.
          19         Right?
          20              THE WITNESS:  Yes.
          21              THE COURT:  So any delay was occasioned
          22         apparently by some difficulty in determining what
          23         was the cause of death.  And some disagreements in
          24         sending off lab tests and all that sort of stuff.
          25         Right?
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           1              THE WITNESS:  Yes.
           2              THE COURT:  Okay.  So -- so as far as the
           3         Church is concerned, Dr. Wood or whoever was going
           4         to do the autopsy might have known what they saw in
           5         two days.
           6              THE WITNESS:  Well, I don't believe --
           7              THE COURT:  I mean, they have no way of knowing
           8         that, that they couldn't just cut her open, look,
           9         say, "Whoops, there is a blood clot, this was caused
          10         by dehydration."
          11              THE WITNESS:  Well, wasn't it after the
          12         criminal case got started that Mrs. Wood went on
          13         national TV and spoke about dehydration and all of
          14         these things?  Wasn't that --
          15              THE COURT:  It may have been.  But the fact of
          16         the matter was, is within a matter of however soon
          17         they got to this body, depending on how many bodies
          18         they had --
          19              THE WITNESS:  Right.
          20              THE COURT:  -- somebody did an autopsy, you
          21         know, did an autopsy.
          22              THE WITNESS:  Correct.
          23              THE COURT:  Dictated findings, and eventually
          24         this was put into an autopsy report.  And Dr. Wood
          25         apparently did go on nationwide TV at some point in
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           1         time later.
           2              THE WITNESS:  Right.
           3              THE COURT:  But, I mean, it still goes without
           4         saying that there would be no way for the Church to
           5         know what was going to go on at the medical
           6         examiner's office.
           7              I mean, gosh, they could have said she was
           8         stabbed.  They may have been wrong.  But there is no
           9         way of knowing, when a body is taken under unusual
          10         circumstances, anybody not under a doctor's care,
          11         where a doctor signs off, like in a -- in a -- and a
          12         medical examination is done, an autopsy is done,
          13         there would be no way for the Church to know what
          14         the ultimate result was going to be.
          15              Why, look at all of the flap now about the
          16         different autopsy reports and what have you.
          17              THE WITNESS:  Right.
          18              THE COURT:  Right?
          19              THE WITNESS:  I agree with you wholeheartedly.
          20              THE COURT:  So this has been my problem all
          21         along is that you talk about a bad public relations
          22         flap.
          23              THE WITNESS:  Right.
          24              THE COURT:  Well, a death, for heaven sakes,
          25         brings about a lot worse public relation than
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           1         somebody who goes to the hospital and says, "I was
           2         kept there, I didn't want to stay and they brought
           3         me here but I want to go home and I don't want to be
           4         here" and some charges are brought because of that.
           5              THE WITNESS:  Well, your Honor --
           6              THE COURT:  Which they can defend on the way by
           7         saying this was a religious -- she was a member of
           8         the Church, this was the way we handled this.  That
           9         would have been the defense.
          10              THE WITNESS:  Right.  And I -- and I beg to
          11         differ with you on the fact that it was more
          12         convenient to take her to the hospital as opposed to
          13         take a dead body there.
          14              THE COURT:  I didn't say convenient.  I said it
          15         would be a -- it was a worse public relations flap
          16         to have had Lisa McPherson die at the hotel under
          17         the care of the Church of Scientology than it would
          18         have been for Lisa McPherson to have gotten well in
          19         the hospital, having been taken there by the Church
          20         of Scientology and had her say, "They held me there
          21         and I wanted to leave and they wouldn't let me
          22         leave."  That would have created less of a public
          23         relations flap.
          24              THE WITNESS:  I beg to differ, your Honor.  And
          25         the reason I beg to differ is again, like I say,
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           1         this person has just attested to being almost
           2         superhuman.  This person has been in the community
           3         here in Clearwater.  She worked on public relations,
           4         on behalf of the Flag Service Organization, setting
           5         up the Christmas dealies.  She was part of the OT
           6         committee whose responsibility is to interface
           7         Scientology with the community.  Lisa was not a
           8         low-profile, no-nothing nobody-person.
           9              THE COURT:  I understand that.  But here we
          10         are, we are in this hearing, it is the seventh week
          11         of this hearing.  This case has been going on seven
          12         years.  There has been no good publicity that has
          13         come out of it, presumably, for the Church of
          14         Scientology.
          15              All this would have been avoided if they had
          16         taken her to a hospital if it had been something
          17         that they would have known, they took her to a
          18         hospital, and had she said, you know, "Those folks
          19         were holding me against my will," and they just
          20         said, "No, she was there on introspection rundown,"
          21         that would have been litigated, long over.
          22              Do you think, in the long run, it would have
          23         been less of a public relations flap?
          24              THE WITNESS:  Let's take another perspective of
          25         it.  If it had gone along as Scientology planned, if
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           1         my contention there was a cover-up and they were
           2         successfully able to cover up and this girl simply
           3         died of embolism, well, who cares?  Okay, well, so,
           4         you know, another dead person.
           5              But if this person came and said, "Hey, look, I
           6         have been in here, they have held me, these people
           7         have jumped on me, forced drugs down my throat, they
           8         shoot me up with needles," you know, I know that --
           9         that they said they never used Valium.  I'm sorry, I
          10         disagree.  I have been through these introspection
          11         rundowns.  The instant they give that stuff -- they
          12         give it to the person because they can't sleep.
          13         Otherwise, they are up all night.  What they call it
          14         is a free will or the person simply cannot sleep so
          15         they are giving her drugs to make them sleep.  Why
          16         would you get the same drug two times and not use
          17         it?
          18              THE COURT:  A person that can't sleep is the
          19         person that is psychotic in a very hyperactive
          20         state.  Right?
          21              THE WITNESS:  Correct.
          22              THE COURT:  So, consequently, you would concede
          23         that Lisa McPherson was, in fact, in a very
          24         psychotic state or she could have slept just fine.
          25              THE WITNESS:  Something caused her not to
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           1         sleep.
           2              THE COURT:  Right.  Which, of course, if she
           3         was in a psychotic state -- now we are back to that
           4         situation where it would have been fairly dangerous
           5         for them to let her walk out the door, which --
           6              THE WITNESS:  You know, as far as her being
           7         psychotic, your Honor, I feel we can only speculate
           8         about that, because she was never taken to a doctor
           9         and diagnosed as being psychotic when they say she
          10         was psychotic.
          11              THE COURT:  Then she wouldn't have needed
          12         Valium to make her sleep, would she?
          13              THE WITNESS:  No.
          14              THE COURT:  I mean, you can't have it both
          15         ways.
          16              THE WITNESS:  Well, you know, your Honor, I'll
          17         be quite honest with you.  Before I came in here --
          18         I'm tired now because I wasn't able to sleep that
          19         well, and I'm sure this will go on until I'm
          20         finished.  So I don't know, six to one, half dozen
          21         of another to me.
          22              THE COURT:  All right.
          23    BY MR. DANDAR:
          24         Q    Have you ever in your experience seen drugs like
          25    Valium or chloral hydrate given to a Scientologist so they
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           1    don't leave?
           2              MR. WEINBERG:  Can we limit it to one or the
           3         other?
           4         A    No, I have not.
           5              THE COURT:  So you have never seen Valium given
           6         to a Scientologist?
           7              THE WITNESS:  Because they want to leave?
           8              THE COURT:  Because they want to leave?
           9              THE WITNESS:  No.
          10              THE COURT:  Because they were sick?
          11              THE WITNESS:  Because they were --
          12              THE COURT:  Psychotic?
          13              THE WITNESS:  Yes, ma'am.
          14              THE COURT:  When was that?
          15              THE WITNESS:  Again, this girl, Terese --
          16    BY MR. DANDAR:
          17         Q    Teresita?
          18         A    Teresita.  Again, she, you know, literally fell
          19    off the chair and started doing her thing.  And I think one
          20    day passed and she wasn't sleeping, and immediately Dr. Dink
          21    was contacted.  You could literally see her dying in front
          22    of your face.  She was just burning up.  It was one of the
          23    most amazing things to see, kind of like the person caves in
          24    on themselves, they just kind of fall in, you know.
          25              And this started happening to her after she hadn't
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           1    slept for two and a half, three days.  And she came out and
           2    she was given an injection.
           3         Q    Did you --
           4              THE COURT:  Was it Valium?  That is the
           5         question.
           6              THE WITNESS:  Your Honor, I couldn't speak
           7         truthfully as to what the injection was because the
           8         doctor was there, he injected her, and I know that
           9         within an hour, hour and a half, she was asleep.
          10              THE COURT:  So in truth now, Mr. Prince, you
          11         can't testify in this courtroom that you ever saw
          12         Valium given to someone because they either wanted
          13         to leave or because they were psychotic; you don't
          14         know what the psychotic person was given?
          15              THE WITNESS:  Correct.
          16              THE COURT:  Okay.
          17    BY MR. DANDAR:
          18         Q    Mr. Prince, did you have to assist Teresita in
          19    eating and drinking?
          20         A    Yes, I did.
          21         Q    How did you do that?
          22         A    I would just gently talk to her and tell her that
          23    it is important for her to eat if she wants to get well.  I
          24    would tell her the case supervisor has said you have to
          25    drink X amount a day.  Would you please do it?  Just trying
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           1    to get her cooperation.
           2         Q    Could she do it by herself?
           3         A    No.
           4         Q    So how did you do it?
           5         A    Oh, I thought you asked me would she do it by
           6    herself.
           7         Q    Right.  Did she pick up the water and drink it by
           8    herself?
           9         A    Yes.
          10         Q    And the food, did she eat it by herself?
          11         A    Sometimes I had to take a spoon and put it to her
          12    mouth and watch her chew, you know, and, "Did you eat it
          13    all," you know.  That kind of thing.
          14         Q    All right.  Your opinion that Lisa McPherson died
          15    because of an end cycle order, an order just not to do
          16    anything for her --
          17         A    Correct.
          18         Q    -- is that opinion based upon because you hate
          19    Scientology?  Or is it based upon something else?
          20         A    For one thing, I certainly do not hate
          21    Scientology.  I don't hate anyone or anything.
          22              My opinion is based solely on personal
          23    observation, personal experience.  I give it as an opinion.
          24    I say why.  Maybe I haven't said it as clearly as I need to,
          25    but it is so important for Scientology.  And, you know,
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           1    especially Clearwater is considered a hostile environment.
           2    I mean, I have been here when half the city of Clearwater
           3    were picketing around the Ft. Harrison with Michael Flynn.
           4    I mean, I have seen and been involved in trying to make this
           5    a place where Scientology could comfortably be and the
           6    environment would be comfortable with Scientology.
           7              So, no, I don't hate Scientology.  I was a
           8    Scientologist myself for sixteen years.  You know, I had a
           9    firm belief in what I was doing.  I have since become
          10    disillusioned with a lot of that.  But my motive certainly
          11    isn't hate.
          12         Q    Now, Mr. Prince, there came a time when the Lisa
          13    McPherson Trust was formed.  Do you recall that?
          14         A    Yes, I do.
          15         Q    And after you finished working for me full-time,
          16    you went to work for them full-time.  Correct?
          17         A    Yes.
          18              THE COURT:  You know, on some of these things
          19         you really are going to have to stop leading him.
          20         That is one of the issues that is an issue here.  So
          21         don't ask him a question and then say "Correct?"
          22              MR. DANDAR:  Okay.  All right.
          23    BY MR. DANDAR:
          24         Q    Mr. Prince, were you ever with Bob Minton when he
          25    talked about giving money to me for the case?
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           1         A    I have been with Mr. Minton a couple of times,
           2    yes.  Two or three.  Yes.
           3         Q    I want to direct your attention to May of 2000.
           4         A    Okay.
           5         Q    All right?
           6         A    Yes.
           7         Q    Do you recall any incident where Mr. Minton talked
           8    to you about giving money to me?
           9         A    Around that exact time period, Mr. Minton made it
          10    known to me that you needed more money to bring this case to
          11    trial.  He had thought in his mind that he had given enough
          12    money already and, you know, it could have went to trial or
          13    whatever.  But he was concerned about the repeated motion
          14    and -- motions and on and on, just the cost of the case from
          15    the filings and things, that he asked me to go over there
          16    and look into, well, what is coming up now, I mean, what can
          17    we look forward to now?
          18              I think at that time you were working on an
          19    accident reconstruction.  And Mr. Garko was talking about
          20    doing a jury pool survey or something.  And these were going
          21    to be additional expenses that would be needed, you know, as
          22    well as whatever else came up to take the trial -- take this
          23    case to trial.
          24              And I remember going back and speaking to him
          25    about that.  And he wasn't very happy about that.  And then
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           1    he -- he -- he went away -- he came into town.  Mrs. Brooks
           2    and I were working at the LMT.  And he came and he said,
           3    "Come here, you guys come out here," because he had a fear
           4    that the building that we were in was electronically bugged.
           5              And we got in Stacy's car and we went into the
           6    city parking lot, which is directly across the street from
           7    the LMT Trust.  Went to the very top where we could see.
           8              And he said, "Look, I'm going to tell you guys,
           9    you can't tell anybody this, Ken Dandar has more money, he
          10    doesn't know where it came from.  It came from Europe.  You
          11    know, I told him, this is as much as I think I can get, I
          12    hope this takes you to trial."
          13              That was in 2000.  He told us that, you know, he
          14    didn't want the office to know, you know, Ken didn't want
          15    everybody in the office to know or whatever, but this
          16    $500,000 came.  And -- and, you know, everything with the
          17    case would be okay, basically, was the one instance.
          18              The second instance was very recently, I guess in
          19    March of 2002 --
          20              MR. WEINBERG:  Your Honor, before he gets to
          21         the second incident, that happened when, the first
          22         incident?
          23              THE WITNESS:  May of 2000.
          24              MR. WEINBERG:  May of 2000?
          25
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           1    BY MR. DANDAR:
           2         Q    Did he say where this $500,000 came from?
           3         A    Europe.  People from Europe.
           4         Q    Did he say to you it was his money?
           5         A    No.  He said he had arranged from some people from
           6    Europe who made this money available.
           7         Q    Did you ever see that check?
           8         A    No.
           9         Q    Okay.
          10         A    Then the second instance was recently in March of
          11    2002.  He told me that, "Ken needs more money to finish this
          12    case and get this case to trial.  You know, I'm willing to
          13    arrange to get him some money, but I have a problem with
          14    some people on the Internet saying bad things about him.
          15    Could you ask Ken if there is any way if he has influence
          16    over these people to tell them to stop.  And if you do, I'll
          17    see if we can arrange to get him some more money."
          18         Q    So what did you do?
          19         A    So I went and had that meeting.  I went over to
          20    your office and I met with you.  And I said, "You know, Bob
          21    thinks that he can get more money for you but he's concerned
          22    about this matter.  And what are you doing with that?  Are
          23    you connected with these people, or are you -- you know, are
          24    you encouraging them to do this?"  You know, we had a bit of
          25    a conversation.
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           1              And, Mmm, you said you knew nothing about it and
           2    had no control over those people whatsoever but, you know,
           3    you would do what you could to make it stop if that is what
           4    he was worried about, but it wasn't anything you were
           5    actively concerned in.
           6         Q    Do you know anything about the check I got after
           7    that?
           8         A    Mmm, I know at some point that you had gotten a
           9    check.  And he called me and let me know that you had.
          10         Q    He did?
          11         A    Yes.
          12         Q    Okay.  Did he say where that check came from?
          13         A    He did not.
          14         Q    Okay.
          15              MR. WEINBERG:  And the date of that -- the date
          16         of the conversation with Mr. Dandar was, you said,
          17         March?
          18              THE WITNESS:  Of 2002.  Yes.
          19    BY MR. DANDAR:
          20         Q    Was this before, or after, I flew to Mr. Minton's
          21    house?
          22         A    Before.
          23         Q    Okay.  If I flew to Mr. Minton's house February 22
          24    of 2002, when would this conversation be that you and I had?
          25         A    So I think maybe a week prior.
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           1         Q    Okay.  Were you aware that Mr. Minton --
           2              THE COURT:  So you are saying that was February
           3         of 2002?
           4              THE WITNESS:  Yes, your Honor.
           5              MR. BATTAGLIA:  Excuse me, your Honor, what was
           6         February of 2000?
           7              THE COURT:  2002.  This is when Mr. Dandar and
           8         this witness had a conversation.
           9              MR. BATTAGLIA:  Oh.  Okay.
          10    BY MR. DANDAR:
          11         Q    Now, I jumped -- when you talked about that
          12    meeting, that kind of threw me off because that is two years
          13    after where I wanted to talk to you about.  So let's go
          14    back.
          15              Do you know a fellow by the name of Patrick Jost?
          16         A    Yes.  I do.
          17         Q    Okay.  How do you know him?
          18         A    I know him because he was hired by Mrs. Brooks to
          19    specifically assist Mr. Minton to deal with allegations that
          20    were being stirred up by Scientology investigators in
          21    Nigeria and Switzerland.
          22         Q    What was he supposed to do?
          23         A    Mmm, Patrick Jost is multilingual.  I think he
          24    speaks maybe four or five languages.  Mmm, he's also a
          25    person -- ex-CIA, spent many years in Europe on behalf of
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           1    the United States defense.  So he knew a lot of people and
           2    had a lot of contacts.
           3              And he was supposed to go and find out where the
           4    trouble was originating from and try to deal with it
           5    accordingly.
           6         Q    Do you know if he was successful in doing that?
           7              MR. WEINBERG:  Objection, hearsay, your Honor.
           8              THE COURT:  Okay.
           9              MR. WEINBERG:  This whole thing is hearsay.
          10    BY MR. DANDAR:
          11         Q    Did you -- can you describe for us the demeanor of
          12    Mr. Minton throughout the years -- almost two years that the
          13    Lisa McPherson Trust concerning the -- what he perceived to
          14    be actions taken against him by Scientology?
          15              MR. BATTAGLIA:  I'll object to that as being
          16         far too broad, demeanor over a period of two years.
          17              THE COURT:  Mr. Battaglia, much as I would like
          18         to let you object, I don't think you have any
          19         standing to object in this hearing.  This is a
          20         hearing between these two people.  Your client is
          21         simply a witness.  So I'll simply ignore that.
          22              MR. WEINBERG:  You beat me to my feet because I
          23         was about to say the same thing.
          24              MR. FUGATE:  Stereo.
          25              MR. WEINBERG:  That is like asking for -- I
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           1         don't know how you ask a question like that.  His
           2         demeanor over two years?
           3              THE COURT:  I agree with that.  It was a little
           4         broad.
           5    BY MR. DANDAR:
           6         Q    Did Mr. Minton ever talk to you about what he felt
           7    concerning the Scientology investigation of him?
           8         A    Many times, to answer the question.  And it wasn't
           9    even the fact that investigations were happening.  It's the
          10    false information.  The false information that was being
          11    provided to government officials in different countries,
          12    unfounded allegations that were being provided, that
          13    disturbed him more.
          14              And over time it became increasingly more evident
          15    that this was having more and more of an effect on him.
          16         Q    How did you pick that up?
          17         A    When I first met Mr. Minton, he was probably about
          18    40 pounds lighter than he currently is.  Just the nicest,
          19    gentlest, kindest person.  I mean, I had never seen a person
          20    like him before.  I mean, literally, who am I?  Nobody.
          21              But a person like that to come around in your life
          22    that just was -- I don't know -- genuinely concerned about
          23    other people to the point of almost fault.  And very -- very
          24    kind.  Very intelligent person.
          25              I seen him go from that, to -- to kind of being a
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           1    person that is annoyed -- kind of annoyed by what is going
           2    on, kind of -- Mmm -- annoyed with, you know, what is
           3    happening with his kids, you know, what is happening with
           4    his house, his phone lines, on and on.
           5              Then I seen him go to a person that actually
           6    became very doubtful about what he was involved in, what he
           7    was doing.  He seemed to be less confident as time went on
           8    that he would be able to do anything to restrain Scientology
           9    from exercising some of its practices that are detrimental
          10    to the general public at large.
          11         Q    Have you -- are you familiar with the doctrine of
          12    Scientology called fair game?
          13         A    For sure.
          14         Q    Has fair game been canceled?
          15         A    No.  It's alive and well.
          16              MR. WEINBERG:  It's what?  I couldn't hear.
          17              THE COURT:  Alive and well.
          18              THE WITNESS:  Alive and well.
          19              MR. WEINBERG:  And that is based on your --
          20              THE COURT:  Counsel, we're going to let you ask
          21         that question later.
          22              MR. WEINBERG:  I will.  I'll withdraw it.  I'm
          23         sorry.
          24    BY MR. DANDAR:
          25         Q    Based on your expertise and experience in
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           1    Scientology, did you personally observe any fair game
           2    practiced on Mr. Minton?
           3         A    Yes.  I have.
           4         Q    Can you give us some examples?
           5         A    Mmm, leaflets passed around in Boston where his
           6    wife and children live, saying that he's an adulterous,
           7    robbed the Nigerian children -- the Nigerian people of
           8    moneys, this is a starving country.  And -- and kind of --
           9    he's kind of somehow aligned with the KKK because he was
          10    attacking Scientology.
          11              Mmm, his children being followed around.
          12              You know, the whole Nigeria/Switzerland thing.
          13              They used to meet him at every airport he went to,
          14    irrespective of any city, they would just show up and meet
          15    him and picket him at the airport.  I have been with him
          16    when the police literally have to stand in the airport and
          17    hold Scientologists back from attacking him.
          18              I have been with him in Boston where somehow
          19    Scientology OSA people had gotten a hold of his -- his --
          20    his records, his counseling records when he was seeing a
          21    psychiatrist.  And they started saying things to him that he
          22    said to his therapist, I know, that upset him extremely that
          23    it could even happen.
          24              And the fact of the matter is that therapist
          25    decided to no longer see Mr. Minton after Mr. Minton went
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           1    back and told him, "Hey, why are these guys saying this to
           2    me?"
           3         Q    This was a psychiatrist?
           4         A    Yes.
           5         Q    Of Mr. Minton's?
           6         A    Yes.
           7         Q    So --
           8         A    And --
           9         Q    -- he refused to see him after the records were
          10    made public?
          11         A    Correct.  Or exposed.  His position was exposed.
          12         Q    Okay.  Did there come a point in time when
          13    Mr. Minton, in your presence, was -- had any dramatic change
          14    in his emotions compared to the years that you have known
          15    him?
          16         A    Again, you know, what I said earlier.  For sure,
          17    he changed.  He became more of a somber person.  He wasn't
          18    as cheerful anymore.  He was more serious.  And at some
          19    point it even got into, "Well, you know, they did this to me
          20    so I'm going to go picket them.  They did this to me so I'm
          21    going to go picket."
          22              You know, this is -- was kind of like his last
          23    line of defense, as I testified the first day I came here,
          24    that he could possibly do, you know.  "I'm just going to go
          25    picket.  When they fool with my wife, I'm going to picket.
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           1    When they fool with my children, I'm going to picket.  What
           2    they are doing over in Nigeria, doing all this crap, I'm
           3    going to go picket."
           4              So he became increasingly despondent about that.
           5    And, you know, Mr. Minton takes medication.  Not that there
           6    is anything wrong with medication, but sometimes he wouldn't
           7    take it.  You know, he seemed to just be extremely stressed.
           8    And during the time periods when he didn't take his
           9    medication, he would literally be in a state of collapse
          10    with just -- crying uncontrollably and totally despondent.
          11              I remember one time he told me he was going to
          12    kill himself.  He was walking around in the woods with a
          13    gun, you know.  200 acres up there where he lives and it is
          14    nothing but beautiful woods in New England and he's walking
          15    around with a gun.  He drove his car in the woods, got it
          16    caught on a tree stump and he's out there in the middle of
          17    the night, with a gun, crying.  You know, that has happened.
          18         Q    When did that happen, that particular incident?
          19         A    That was in the fall of 2001, I believe.
          20         Q    Okay.  Do you have any knowledge concerning Stacy
          21    Brooks' desire, in the summer of 2001, to go see Dell
          22    Liebreich to get her to drop the case?
          23         A    Yes.  I do.
          24         Q    What is your knowledge?
          25         A    Mmm, Scientology had very effectively convinced
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           1    the courts -- and I'm not trying to cast any aspersions
           2    here -- tried to convince the court that somehow the Lisa
           3    McPherson Trust had something to do with this Lisa McPherson
           4    case.
           5              And this assertion, this stuff that had grew over
           6    the years, inextricably tied these two things together,
           7    which allowed a way to now do continuing discovery on
           8    Mr. Minton and Mrs. Brooks and other staff members that
           9    worked at the trust.
          10              And this was something that he was very concerned
          11    about, because financially it was ruining the Lisa McPherson
          12    Trust to have a lawyer have to represent all of the staff
          13    members, you know, when they get deposed, and they're away,
          14    and on and on and on.  So --
          15         Q    Did there come a time when -- well, let's go back
          16    to the question.
          17              Did there come a time when you had knowledge about
          18    Stacy Brooks wanting to go to Dell Liebreich?
          19         A    Yes.  So because of that, you know, and there was
          20    more discovery by Scientology specifically on Mr. Minton's
          21    finances, they were just narrowing down on that, which is
          22    pursuant to their policy here to cut off the funds, on and
          23    on and on.  They are on a systematic program.
          24              One thing that can be said about Scientologists,
          25    they are extremely organized and they have resources to do
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           1    what they need to do.
           2              So Stacy thought that, you know, a lot of stress
           3    was coming because of this.  So she thought, well, the only
           4    reason this is happening is because of this wrongful death
           5    case.  So she decided to go visit with Dell Liebreich and
           6    ask her to drop the case because of what was happening with
           7    Bob Minton.  And she decided to do this without Mr. Minton
           8    knowing about it.
           9              And she consulted me on it and asked me, "Do you
          10    think he will be extremely upset if I do this?"
          11              And I told her that I thought he would be
          12    extremely upset, you know, without talking to you about it
          13    and just go down there because there was no relationship.
          14    Stacy had no relationship with Dell Liebreich.
          15              So for her to now -- now come out of the blue and
          16    ask her to drop the case, it would be like a woodpecker
          17    coming along, telling me to pay my house rent or something,
          18    something as bizarre as that.  So, you know, Stacy decided
          19    she was going to do it anyway.
          20              She finally asked Bob Minton.  And he said, "No,
          21    you don't do it.  You don't do that."
          22              She decided to do it anyway.  She attempted to
          23    have a phone conversation with Mrs. Liebreich.  And I think
          24    at that point, after Mrs. Liebreich spoke with Stacy, she
          25    then spoke with you and refused to speak with Stacy anymore.
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           1         Q    Are you aware of any instance where Bob Minton
           2    controlled the wrongful death case?
           3         A    Not at all.  The wrongful death case was the last
           4    thing that Mr. Minton was interested in because he had
           5    turned it over to you, he felt you were a competent, honest
           6    attorney, and, you know, many arguments have happened
           7    between Mrs. Brooks and Mr. Minton concerning the fact that
           8    she did not need to be involved in the case, or if there was
           9    a differing of opinion, to do what you say because you are
          10    the lawyer.
          11              And, no, he -- he -- he never -- Bob Minton was
          12    more concerned about what was going on at the Lisa McPherson
          13    Trust.
          14              There was a period of time, after we came into
          15    existence and actually established a phone number, that
          16    people just started calling like crazy.  "Hey, can you help
          17    me with this?  Can you help me with this?  Can you tell me
          18    what is going on with my brother?  He doesn't speak to me
          19    anymore.  Can you tell us what it means to be an SP?  I need
          20    to get my money back from Scientology that I haven't used
          21    because I have no life, I don't have a place to live."  You
          22    know, all of these kind of phone calls.
          23              And we -- we became extremely interested because
          24    after the trust was set up, it gave you a broad cross
          25    section of, well, what types of things do people need help
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           1    with in relationship to Scientology?
           2              So our job became, well, there is nothing we can
           3    do about it.  If there is a criminal activity concerned, if
           4    there is any fraud that is concerned or bad business
           5    practices, at that point we started referring people to the
           6    responsible governmental agencies.
           7              If you have a problem with them returning your
           8    repayment money, you refer them to the Consumer Fraud
           9    Department -- Department of Agriculture, Consumer Fraud.  If
          10    it is bad business practices, the Better Business Bureau.
          11    If it has something to do with money -- the IRS could
          12    possibly be a person to contact if they are not getting
          13    satisfaction with known policies on giving money back.  This
          14    kind of thing.
          15              And we had nothing whatsoever -- and the whole
          16    reason I stopped working in your office is that we had gone
          17    through deposing the majority of the Scientologists and
          18    Scientology witnesses.  And you were going on to your
          19    medical experts.  So there was no reason for me -- I mean, I
          20    didn't need to sit and listen to a medical expert being
          21    deposed.
          22              So I worked at the trust.  And this is kind of
          23    what we were doing.  It was kind of like when you went off
          24    doing your medical people, we just forgot about the case.
          25    At least, I did.
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           1         Q    So you actually did work at the trust in answering
           2    calls for people who needed counseling?
           3         A    Very much so.
           4         Q    You weren't just waiting for the trial of the Lisa
           5    McPherson case to start?
           6         A    This trial -- you know, as much as I'm willing to
           7    offer my services -- help point out certain things, what
           8    happened with Mrs. McPherson was a very unfortunate thing
           9    but there are still a lot of people alive that needed help.
          10    And that is where I went to -- what I wanted to do.
          11         Q    What was my involvement with the Lisa McPherson
          12    Trust?
          13         A    Occasionally stop by to have dinner.
          14    Occasionally, like maybe I think I maybe seen you there two
          15    times during its entire existence, maybe three.
          16         Q    Did I give any orders to anyone at the Lisa
          17    McPherson Trust?
          18         A    Not that I ever saw.  It would be highly unusual
          19    if that happened.
          20         Q    Did I direct any of the picketing?
          21         A    No.
          22         Q    Do you know if I ever participated in a picket?
          23         A    No.  You know, I was sitting here listening to
          24    testimony about that, and I listened with a sharp ear as
          25    Judge Schaeffer here mentioned the fact that you shouldn't
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           1    have been anywhere near picketing.
           2              And I think what may be kind of misunderstood here
           3    is the fact that the vigil is not -- was not and never has
           4    been a picketing experience.  The vigil is where the people
           5    come from all over, they light the candles, they -- they do
           6    some Bible stuff, they sing hymns and they may place a
           7    wreath where she died at the cabana.  That is not a
           8    picketing experience.
           9              And that is where I have seen you with the vigils,
          10    along with the family.  And you were there because the
          11    family was there.
          12         Q    Okay.
          13              MR. WEINBERG:  Your Honor, I have an objection.
          14         In light of Mr. Prince's last statement, he said he
          15         understood you had said certain things during the
          16         hearing?  How would he know that if he was to be
          17         excluded?
          18              THE COURT:  I am sure he read transcripts.
          19              MR. WEINBERG:  Well, but it is --
          20              THE COURT:  It would have been what he read or
          21         somebody told him, which would be inappropriate,
          22         too.
          23         A    I think it came up on the first day when I sat
          24    here in the courtroom giving testimony where you admonished
          25    Ken and pointed that out.  I heard that direction from this
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           1    seat.
           2              THE COURT:  I'm not excluding you from
           3         testifying if you read something or heard something.
           4              THE WITNESS:  Well, I'm just saying that is not
           5         the case.  I heard it right here in this seat on the
           6         first day I was here.
           7              THE COURT:  You have to understand to the -- to
           8         the rest of the world, if candles are being carried,
           9         signs are being carried, it is being done, the
          10         Church of Scientology -- it may look and seem like a
          11         picket.  A lot of folks have talked about it as
          12         being a picket.
          13              THE WITNESS:  Right.  But at the vigil there
          14         are no signs, though.
          15              THE COURT:  Okay.
          16    BY MR. DANDAR:
          17         Q    Now, did you ever hear Mr. Minton talk about the
          18    money that he gave me as -- giving it to me or giving it to
          19    the estate?  Did you ever hear him talk about that?
          20         A    I have.  And what Mr. Minton has always said to me
          21    is he is giving this money to Ken to use on the case at his
          22    discretion.  He's loaning the money to Ken.  That is what I
          23    heard.
          24         Q    Did you ever hear Mr. Minton write or speak about
          25    the LMT or Mr. Minton getting the bulk of any of the money
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           1    that may be realized from the wrongful death case?
           2         A    The only time I heard that statement made was when
           3    Mr. Minton came back from a radio interview.  And he was
           4    laughing.  And he said, "Hey, you know what, I just went in
           5    there and said the bulk of the proceeds are going to go to
           6    an anti-cult group or whatever.  And I know this is going to
           7    chap Scientology's behind."  He was into that kind of tit
           8    for tat kind of thing.
           9         Q    Did you ever hear him talk about it in private or
          10    outside of the media's presence?
          11         A    Well, you know, the particular time that I'm
          12    talking about was private, you know.  And I -- you know, I
          13    made the comment, "Really, you know, is that the way it's
          14    going to go?"
          15              He said, "Look, I'll probably never see a dime
          16    from this stuff.  I just said it."
          17         Q    Okay.  Did there come a point in time when
          18    Mr. Minton started to express concern over the discovery by
          19    Scientology of a UBS check?
          20         A    What I recall about that, and I mentioned or made
          21    reference to it in the affidavit that I did, I guess the
          22    last one that I did, the April 2002.
          23              He called me just in grief, crying.  He's like,
          24    "It's over.  They got me.  You know, I'm going to jail."
          25    He's just --
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           1              THE COURT:  Can we have a date on this?  You
           2         want your last affidavit?  I think it was in there.
           3              THE WITNESS:  Yes, it would probably be a week
           4         prior to the meeting that happened on March 28th.
           5         So we're talking like maybe March 21st or something
           6         like that.  You know, the week prior to going to New
           7         York.
           8    BY MR. DANDAR:
           9         Q    All right, here is the April 2002 affidavit.
          10         A    Okay.
          11              MR. DANDAR:  Judge, do you need another copy?
          12              THE COURT:  No.  I know it is in evidence
          13         somewhere.  If I need to see it, I'll ask to see a
          14         copy of it.
          15              MR. DANDAR:  All right.
          16         A    So, you know, I immediately called Mrs. Brooks
          17    and --
          18    BY MR. DANDAR:
          19         Q    Well, let's back up.
          20              Bob Minton called you up, crying, saying, "It is
          21    all over."  What else?
          22         A    He said that, Mmm, "I'm going to jail.  I have
          23    been told I'm going to jail.  They're coming after Therese
          24    and the kids."
          25              And he was just completely despondent about that.
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           1         Q    And this was before the New York City meetings?
           2         A    Yeah.
           3         Q    Okay.
           4         A    Yeah.  So then --
           5         Q    But he didn't go into detail as to why he thought
           6    he was going to jail?
           7         A    No, he wouldn't tell me then.  I wanted to know,
           8    what is his new thing?  What in the heck happened?  What new
           9    thing has happened?  He wouldn't tell me.
          10         Q    Okay.
          11         A    Stacy, I called her to try to get additional
          12    information.  She didn't know what the heck had happened.
          13    But she knew she had to go up there.  So she went up there
          14    that day.
          15         Q    To New Hampshire?
          16         A    Yes, to New Hampshire.  Subsequent days, I got an
          17    idea of what happened.  And it had no significance to me, I
          18    had no idea that this was a significant incident.
          19              But he told me that Mike Rinder had somehow gotten
          20    a copy of a check, of the $500,000 check, and told him that
          21    he knew that Bob Minton lied in deposition about this
          22    $500,000 check and they had the proof and they were going to
          23    prosecute him on it.
          24         Q    Did Mr. Minton say he, Mr. Minton, also had a copy
          25    of this UBS check?
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           1         A    No.  He said he didn't know how they got a copy
           2    because he can't get a copy of it.  He said, "I tried.  I
           3    can't get a copy of it."
           4              Somehow, they come up with a copy and show him.
           5    And he was just beside himself.
           6              MR. WEINBERG:  Your Honor, could I ask, could
           7         we point out in this affidavit where this incident
           8         is that he's just described?
           9              THE COURT:  Yes.
          10              MR. WEINBERG:  Because I don't think it's in
          11         there.  They are saying something about a $500,000
          12         check prior to the New York meetings.
          13              THE COURT:  You have your affidavit there in
          14         front of you?
          15              THE WITNESS:  Yes.  I do.
          16              THE COURT:  See if it is in the affidavit, or
          17         if it is something not in your affidavit.
          18              THE WITNESS:  Okay.  Okay, so here, if you turn
          19         to Page 3 of the affidavit, I started talking about
          20         what I'm explaining right now on the 20th of March,
          21         2002.
          22              THE COURT:  What is this number?
          23              MR. DANDAR:  Paragraph 9.
          24              THE WITNESS:  Paragraph Number 9.
          25              THE COURT:  I don't have it.  Maybe I do need
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           1         it.  What is the number of the exhibit and I'll have
           2         the clerk get it?
           3              MR. FUGATE:  I believe it is attached to
           4         Mr. Dandar's response to our memorandum of fact and
           5         law.  I believe that is where it is.
           6              THE COURT:  Okay.
           7              MR. FUGATE:  Can I give you a copy?
           8              THE COURT:  Yes, please.  If you would, that
           9         would be great.  I'll give this back to you because
          10         I know it is in evidence or in the pleadings.
          11              MR. FUGATE:  It is in the pleadings, I believe,
          12         Judge.
          13              MR. DANDAR:  He's reading from Paragraph 9 on
          14         Page 3.
          15    BY MR. DANDAR:
          16         Q    Am I right?
          17         A    Yes.  But, you know -- yes, that was on Page 3,
          18    Number 9, during the time period, what I'm talking about
          19    here.
          20              And before I wrote this affidavit on the
          21    attachment, when I met with Mr. Dandar, I wrote on the first
          22    page that -- that Scientology had gathered enough
          23    information about Bob Minton to get him prosecuted,
          24    convicted and jailed.
          25              MR. DANDAR:  He's looking at his handwritten
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           1         attachment.
           2              THE COURT:  Oh, okay.
           3              THE WITNESS:  Yes.
           4              MR. DANDAR:  The first page, the first
           5         paragraph.
           6              THE WITNESS:  Did I answer the question?
           7              MR. WEINBERG:  I asked you -- I asked you, does
           8         it say in the affidavit about this conversation you
           9         supposedly had with Mr. Minton prior to the New York
          10         meetings where he told you that the Church had a
          11         copy of a $500,000 check, and he didn't --
          12              THE WITNESS:  I don't --
          13              MR. WEINBERG:  -- have a copy and didn't know
          14         where they got it.
          15              THE WITNESS:  I'm sorry, I don't mean to cut
          16         you off.
          17              I don't mention the check specifically, but
          18         what I mention is, is the information that
          19         Scientology had gotten, information that said they
          20         were going to get him prosecuted and put in jail.
          21         You know --
          22    BY MR. DANDAR:
          23         Q    Paragraph 9, do you talk about the conversation --
          24    the first conversation where he's crying?
          25         A    Yes.  They discovered information about him that
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           1    threatened his wife and children's future.  You know, again,
           2    he's suicidal.  And then --
           3              THE COURT:  In your handwritten notes it
           4         appears that you are talking about this -- this
           5         information before Paragraph 3 which deals with Bob
           6         Minton and Stacy Brooks flew to New York.  So I
           7         presume you were discussing -- or you -- your notes
           8         indicated that occurred before the New York trip?
           9              THE WITNESS:  Yes.
          10              THE COURT:  I don't think it is very clear,
          11         certainly, in the affidavit, but he says that is
          12         what he's talking about.
          13              THE WITNESS:  Well, you know, your Honor, I
          14         really did try to do the best I could.  This is a
          15         very disturbing time for me, too.
          16              THE COURT:  There is nothing that says that you
          17         have to speak to every word of your affidavit.  You
          18         can expand on it.  If that is your testimony, that
          19         is fine.
          20              THE WITNESS:  Thank you.  And, you know, in the
          21         days between the New York meeting and the 20th of
          22         March that I noted here, which is where I came to
          23         find out, you know, what is this.  Because Stacy
          24         flew there.  And after she was there, I let her, you
          25         know, get settled.
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           1              And then he's telling me, you know, they have
           2         got this check.  And, you know, and he says --
           3         basically, it's come down to me or Ken Dandar,
           4         somebody has to die here.
           5              And I'm like, you know, this was such a
           6         complete turnaround.  These are people I worked with
           7         now for years.  We have all been on one accord,
           8         doing what we thought were good work.  Suddenly now
           9         Mr. Minton has to turn on Ken Dandar.
          10    BY MR. DANDAR:
          11         Q    And did you have any further conversation in that
          12    phone call with Mr. Minton?
          13         A    Well, he informed me --
          14              THE COURT:  This is the phone call before --
          15         you are saying this is the phone call before the
          16         first time Mr. Minton and Ms. Brooks went to New
          17         York?
          18              THE WITNESS:  Yes, your Honor.
          19              THE COURT:  We're going to finish that phone
          20         call, then we'll take a break.
          21              THE WITNESS:  Okay.
          22              MR. DANDAR:  All right.
          23         A    Yes.  He said he didn't feel safe about discussing
          24    the information over the phone, he was too upset to talk
          25    about it.
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           1              MR. DANDAR:  All right.
           2              THE COURT:  Did you say this was about a week
           3         before the trip to New York?
           4              THE WITNESS:  Yes, your Honor.  I said on or
           5         around the 20th of March.  And the trip to New York
           6         was the 28th of March.
           7              THE COURT:  Okay.
           8              THE WITNESS:  The 28th and 29th of March.
           9              THE COURT:  Let me just say this about
          10         affidavits.  They wanted me to sign an affidavit of
          11         borrower to buy my house.  And I refused to sign it
          12         without -- I said, "I'm not going to sign this
          13         without this and this and this and this."
          14              And finally they just said, "Well, we're going
          15         to throw it out.  It is not that important."
          16              I said, "Well, good."
          17              All this, and affidavits.  It makes me very
          18         nervous.  You know, some things might not have made
          19         me so nervous.
          20    BY MR. DANDAR:
          21         Q    Anything else on that phone call with Mr. Minton
          22    before we take our break?
          23         A    Mmm, you know, again, starting on March 20th until
          24    they actually went to New York, there were many
          25    conversations.  You know, I don't want to give the illusion
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           1    this just happened one phone call and suddenly they were in
           2    New York.
           3              THE COURT:  Let's go ahead and break and then
           4         we'll start with -- if you want to go into the other
           5         phone calls before New York.  All right?
           6              MR. DANDAR:  All right.
           7              THE COURT:  We'll be in recess until 3:15.
           8        (WHEREUPON, a recess was taken from 2:55 to 3:15 p.m.)
           9              ______________________________________
          10              THE COURT:  All right.  You may be seated.
          11              MR. FUGATE:  Your Honor, before we begin back
          12         again, on May 13, 2002 we had filed a request to
          13         produce to Mr. Dandar for all financial records of
          14         payments to Jesse Prince, including bank records and
          15         checks, all W2s, 1099s, and any other tax form
          16         issued from Dandar & Dandar for Jesse Prince for tax
          17         years 1999, 2000 and 2001.  It was never responded
          18         to.
          19              I think it is now relevant, based on the
          20         testimony elicited, that that be produced, or at
          21         least responded to that was filed May 13th of 2001
          22         (sic).
          23              MR. DANDAR:  Didn't we respond to that?
          24              THE COURT:  Had you responded to this?
          25              MR. DANDAR:  We produced at the time they took
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           1         Jesse Prince's deposition -- he's no longer working
           2         for me -- all of the W2s, 1099s, all of the checks
           3         we wrote.  We did not respond to that one.
           4              THE COURT:  Is there anything additional?
           5              MR. DANDAR:  I'll have to check.  I'm sure --
           6         you know, since I brought him back on board as my
           7         expert, yes, I paid him since then.  So there is
           8         something additional.  But not back on May 13.
           9              THE COURT:  You don't need him to regive you
          10         what he has already given you.
          11              MR. FUGATE:  No, I'll go verify what we have
          12         and compare that to what he gives us.  But -- but he
          13         needs to respond.  And he needs to give us --
          14              THE COURT:  I'm not going to require you to
          15         give him what he gave you already.  So if he gave
          16         you stuff for the depositions --
          17              MR. FUGATE:  I'll check that tonight.
          18              THE COURT:  Then you must give him whatever
          19         else there is.
          20              MR. DANDAR:  I will.
          21              THE COURT:  Try to have that to him by the
          22         morning.  All right?
          23              MR. DANDAR:  All right.
          24              THE COURT:  You may continue.
          25
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           1    BY MR. DANDAR:
           2         Q    Okay, Mr. Prince, following that telephone
           3    conversation, which you said was on or about March 20, 2002
           4    with Mr. Minton, did you have any more conversations with
           5    him before he went to see Mr. Rinder and Mr. Rosen in New
           6    York City?
           7         A    Yes, I did.  I may have had maybe three to four
           8    conversations with Mr. Minton and Mrs. Brooks concerning
           9    this.  Yes.
          10         Q    Before the New York City meeting?
          11         A    Yes.
          12         Q    And what was your relationship with Mr. Minton at
          13    that time?
          14         A    Mr. Minton was a good friend of mine.  A person
          15    that I trusted.  You know, we worked together.
          16         Q    Okay.  Did he confide in you?
          17         A    Yes.  On some things, he certainly did.
          18         Q    And some things, he didn't?
          19         A    I can't say that he confided in me on everything.
          20    But I know some things he did.
          21         Q    All right.  For instance, when he talked about
          22    somehow this check was going to make him and his wife go to
          23    jail, did he confide in you what it was that they got --
          24    this new thing in the year 2002 that caused him to think he
          25    was going to go to jail?
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           1         A    You know, he said that they got a copy of that
           2    check, that -- Mmm -- that he -- you know, had given
           3    different testimony, I think, in a deposition or something.
           4    And this is what was going to -- this is how they were going
           5    to put him in jail for perjury.
           6         Q    And did he -- all right.  Did he go into more
           7    detail how that was going to be perjury?
           8         A    Because he said that he had given testimony
           9    contrary to -- you know, in other words, this check, this
          10    $500,000 check, came from him, apparently, not people from
          11    Europe.  Scientology had discovered that.  And they were
          12    going to use it to get him convicted for perjury.
          13         Q    Did you ask him why he lied to you and told you
          14    that check was from people in Europe?
          15         A    You know, that was a very good question that I
          16    should have asked.  But at the time this was all new news to
          17    me.  He's telling me, you know, "Oh, well, it came from me,
          18    it didn't come from him.  Now I'm in trouble and now they
          19    are getting ready to depose my wife Therese and bring her in
          20    on all of this stuff."
          21              And in the heat of the moment, the panic of the
          22    moment, I'm sure I didn't ask, you know, all of the right
          23    questions.  But no, I didn't ask him that specific question.
          24         Q    During those three or four other telephone calls
          25    with Mr. Minton before the New York meeting he had with
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           1    Mr. Rosen and Mr. Rinder, did Mr. Minton tell you how it was
           2    that Scientology can find out that this bank check from UBS
           3    that doesn't have his name on it came from him?
           4         A    The only comment he said was he had no idea how
           5    they possibly got a copy of that check because he himself
           6    did not have a copy, nor did he know how to obtain a copy.
           7         Q    Did Mr. Minton ever mention to you anything about
           8    Swiss prosecutors during -- before the New York meeting?
           9         A    Yes, he did.  He told me that there was yet
          10    another action being contemplated by a prosecutor in
          11    Switzerland.  And it was my understanding that this had
          12    something to do with Nigeria but I'm not sure.  You know, I
          13    don't know the details of it.
          14         Q    And he told you this in March before the New York
          15    meeting?
          16         A    Yes.
          17         Q    Now, isn't it true that before Minton called --
          18              MR. WEINBERG:  Object to the form to the
          19         question, "Isn't it true."
          20              THE COURT:  Yes, "isn't it true" is suggesting
          21         that the answer to that is yes.  I mean, I don't
          22         know what the question is, but I know what the
          23         answer is.  That is what the leading part is.
          24    BY MR. DANDAR:
          25         Q    What was your understanding, Mr. Prince, of the
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           1    status of the Swiss prosecution concerning Mr. Minton prior
           2    to Mr. Minton's frantic calls to you in March of 2002?
           3              MR. FUGATE:  Objection, hearsay.  Or at least
           4         the basis for this statement, "What was your
           5         understanding."
           6              THE COURT:  If it came from Mr. Minton, he can
           7         answer.  If it came from somebody else, then I am
           8         not sure you can answer.
           9    BY MR. DANDAR:
          10         Q    From Mr. Minton.
          11         A    Mr. Minton told me they were going to prosecute,
          12    going to file charges.
          13              THE COURT:  In Switzerland?
          14              THE WITNESS:  Yes.
          15    BY MR. DANDAR:
          16         Q    When did he tell you that?
          17         A    Mmm, at one of the phone conversations between the
          18    20th and 28th of March.
          19         Q    Well, my question is prior to that, had you ever
          20    heard from Mr. Minton about Swiss prosecutors?
          21         A    Oh, yes.  I mentioned that before.
          22         Q    Right.  And what was the status of the Swiss
          23    prosecution prior to you getting this call --
          24         A    These phone calls?  Oh, I thought it was over.
          25         Q    What made you think that?
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           1         A    Because Patrick Jost had went over there and
           2    talked with people.
           3              There was one other thing that was pending which,
           4    when Scientology got the bank records for the Bank of
           5    America, somehow the Bank of -- someone in the Bank of
           6    America in Europe, some executive or some banking official,
           7    had did something that was improper concerning either
           8    divulging or passing along information about Mr. Minton's
           9    accounts.  And Mr. Jost was over there to pursue that.
          10              MR. WEINBERG:  Objection.  Hearsay as to any
          11         conversations with Mr. Jost or anybody else.  If
          12         he's saying this is something Mr. Minton said, I
          13         would appreciate if he could date it.
          14              THE COURT:  Is this something you learned from
          15         Mr. Minton?
          16              THE WITNESS:  Yes.
          17              THE COURT:  Okay.  Could you tell us about when
          18         that was?
          19              THE WITNESS:  Mmm, gosh.  This -- this would
          20         have to be in the fall of 2001.  Maybe October,
          21         something like that.
          22              THE COURT:  As best you can remember?
          23              THE WITNESS:  As best I can recall, yes.
          24    BY MR. DANDAR:
          25         Q    All right.  What was it the Bank of America
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           1    official in Europe did improperly, according to Mr. Minton,
           2    what he told you?
           3              THE COURT:  Does this have something to do with
           4         this Swiss prosecution?
           5              MR. DANDAR:  I don't know.
           6         A    This has something to do with when the bank
           7    records were obtained by Scientology here, the Bank of
           8    America somehow simultaneously did something -- something
           9    happened in Europe, as well.  I think they used the fact
          10    they had these records to get information that they were not
          11    supposed to get, they made it appear like the Court
          12    sanctioned them having this information or it was proper for
          13    them to get the information, when it was not.
          14    BY MR. DANDAR:
          15         Q    How did Mr. Minton react to them getting this
          16    information in Europe?
          17              MR. WEINBERG:  Objection.  Your Honor, this is
          18         hearsay based on hearsay.  It is speculation.  Then
          19         the question is how did they react to the Church
          20         supposedly getting this information in Europe?  What
          21         information in Europe?  What is he talking about?
          22         This is just hearsay.
          23              And, you know, Mr. Minton testified.
          24         Mr. Dandar had an opportunity to ask Mr. Minton
          25         about this.  He didn't say anything about this,
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           1         about this accusation or anything like this.  He
           2         didn't even ask him the question.
           3              THE COURT:  Overruled.  This bears on Mr.
           4         Minton's state of mind, anything Mr. Minton may have
           5         said about what he thought was going on, what the
           6         Church knew.  Remember, we had a lot of this, as I
           7         tried to explain.
           8              MR. WEINBERG:  I object more to the form of the
           9         question.  When he said the Church did such and such
          10         at such and such a time, it is just an improper
          11         form, I think.
          12              MR. DANDAR:  It is based on the witness's
          13         answer.
          14              THE COURT:  Right.
          15         A    He was very distraught and upset that this had
          16    happened.  You know, he felt like that there was no one that
          17    could be trusted or no one who was impervious to
          18    Scientology's ability to penetrate and get information that
          19    they should necessarily have.
          20              MR. WEINBERG:  Your Honor, just for the record,
          21         so we are talking about now the fall of 2001 that
          22         he's distraught?
          23              MR. DANDAR:  Yes.
          24              THE COURT:  Is this --
          25              THE WITNESS:  Yes.
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           1              THE COURT:  The same October period of 2001?
           2              THE WITNESS:  Yes, your Honor.
           3    BY MR. DANDAR:
           4         Q    And even -- did you have any conversations with
           5    Mr. Minton in January or February of 2002 before you had
           6    this -- what you described as this March 20 -- the first
           7    call in 2002?
           8         A    Conversations concerning?
           9         Q    Mr. Minton's well-being, his mental state?
          10         A    Well, Mr. Minton -- back in the fall of 2001, we
          11    decided that we could no longer operate the Lisa McPherson
          12    Trust.  He was quite despondent about that.  He was
          13    despondent about what to do with the people that we were
          14    either in the process of servicing or starting some --
          15    something with new people that were calling.  And plus the
          16    phones just never stopped ringing.  So he was distraught
          17    over the fact that it wouldn't be there anymore.
          18              He was distraught over the fact he felt
          19    Scientology had successfully caused the Lisa McPherson Trust
          20    to no longer exist because of a misunderstanding, that
          21    misunderstanding being that it was somehow inextricably tied
          22    into the Lisa McPherson case.
          23         Q    Did Mr. Minton or Ms. Brooks order you to quit
          24    being the expert for the estate?
          25         A    Ms. Brooks asked me to -- and this, again, is in
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           1    the fall of 2001 -- to not be an expert in this case on the
           2    theory that anything -- we were trying to sever any real or
           3    imagined ideas that the Lisa McPherson Trust was connected
           4    with the ongoing litigation.
           5         Q    And did you listen to her?
           6         A    No.  I -- I -- I consulted Bob about that.  I had
           7    a conversation with him.
           8              And he told me that Mrs. Brooks was very upset
           9    about the discovery that was going on, particularly the
          10    finances.  And -- Mmm -- this is why she was doing it.  And
          11    he understood why she was doing it.  And -- Mmm -- what he
          12    said, you know, "If Ken -- you are Ken's expert.  If he's
          13    going to need you, you know, I'm sure you're going to go and
          14    do what you have to do."
          15              MR. WEINBERG:  Could we date that, your Honor,
          16         when that conversation took place?
          17              THE WITNESS:  Mmm, I think we were speaking
          18         about late 2001/early 2002.  Maybe January, around
          19         there.  This is as close as I can place it.
          20    BY MR. DANDAR:
          21         Q    Well, prior to that, you filed or signed an
          22    affidavit dated September of 2001 withdrawing as the expert
          23    for the estate.
          24         A    Okay.
          25         Q    So was this conversation with Stacy Brooks before,
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           1    or after, that affidavit?
           2         A    Preceding that.
           3         Q    So it was before that?
           4         A    Correct.
           5         Q    All right.  And in that affidavit -- do you recall
           6    that affidavit when you withdrew as the expert?
           7         A    Not particularly.
           8         Q    No?
           9         A    I mean, I have a general idea.
          10         Q    What is your general idea of why you withdrew as
          11    the expert?
          12         A    Mmm, again, this was during the time period when
          13    the Lisa McPherson Trust was in the process of closing.  The
          14    trust itself had literally been drained of operating funds
          15    for, you know, paying lawyers.  This wasn't anything that we
          16    ever anticipated or budgeted for.  And it became the most
          17    expensive part of the operation, which was trying to step
          18    away from this case.  And that is what I remember about it.
          19         Q    Let me show you your signed affidavit
          20    September 21, 2001 and see if you can identify that.
          21              MR. DANDAR:  Judge, do you need another copy of
          22         this?
          23              THE COURT:  No.  No.  This is the one I
          24         remember quite well.
          25              MR. DANDAR:  All right.
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           1              MR. WEINBERG:  Excuse me, is he impeaching
           2         Mr. Prince with this affidavit now?
           3              THE COURT:  I don't know if he's trying to
           4         refresh his memory or what.
           5              MR. DANDAR:  Refresh.
           6    BY MR. DANDAR:
           7         Q    First of all, is that your affidavit?
           8         A    Yes, it is.
           9         Q    Did you prepare that affidavit?
          10         A    Yes, I did.
          11         Q    Did you sign it?
          12         A    Yes, I did.
          13         Q    Is that the affidavit that you signed concerning
          14    the reasons for your withdrawal as the estate's expert?
          15         A    Yes, it is.  And, you know, I remember because I
          16    was talking about now the trust was closing, there were no
          17    lawyers -- I mean we just couldn't afford to pay lawyers
          18    anymore.
          19              I personally cannot afford to have a lawyer to
          20    come in here and do activities like you are involved in or
          21    represent me or -- or be here on my behalf.  I have a
          22    family.  I have people that are totally innocent to this and
          23    could care less.
          24              But my family was threatened with the Scientology
          25    operation that was wrought on me to plant drugs in my house
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           1    and get my house raided by the DEA, and try to get multiple
           2    charges put against me.  And now I'm losing my job, too.
           3    There is no way that I could continue this activity without
           4    being able to see that my family would be safe and cared
           5    for.
           6         Q    Did you continue to receive income from Bob Minton
           7    or Stacy Brooks in the fall of 2001?
           8         A    Yes.
           9         Q    And the income you received in the fall of 2001,
          10    was that from Stacy Brooks individually, or from the Lisa
          11    McPherson Trust?
          12         A    I think it was probably Ms. Brooks individually.
          13         Q    Okay.  What about 2002?  Did she continue to pay
          14    you?
          15              THE COURT:  When did -- when did LMT close down
          16         again?  I have been away from this awhile and some
          17         of the details are out of my mind.
          18              MR. DANDAR:  It closed in August.
          19              THE COURT:  Of 2001?
          20              MR. DANDAR:  Yes.
          21    BY MR. DANDAR:
          22         Q    Well, you tell us, Mr. Prince, instead of me.
          23    What was going on in the LMT in the fall of 2001?
          24         A    They were closing -- wrapping up, closing down,
          25    terminating the operation.  Mmm, there was an order to allow
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           1    a magistrate to come in and go through the personal files
           2    and records at the trust.  So for a month or two it was kind
           3    of kept open for that reason alone, just to finish that.  So
           4    that -- you know, there was an extensive library that --
           5    that library had to be shipped, cleaned -- the building had
           6    to be cleaned up and prepared to be sold.
           7              It became our responsibility to ensure that the
           8    building did get sold.  I had a verbal agreement with
           9    Mr. Minton, because at that point I didn't have a lot of
          10    money either, that if I sold the building, I would get
          11    25 percent of whatever the building sold for so that I could
          12    move -- I was in the process of leaving Clearwater.  My
          13    house was on the market.  We were finished -- the trust was
          14    over.  We were finished.
          15              I mean, if that is what Scientology wanted, they
          16    had accomplished it.  It was finished.  We were all moving.
          17    I put my house on the market, put the building on the
          18    market, we were trying to sell it.  We're -- we're done.
          19    But it is never done, I guess.
          20         Q    Back to 2002, do you believe -- have we exhausted
          21    your conversations with Mr. Minton or Stacy Brooks prior to
          22    the New York City meetings?
          23         A    The only additional things --
          24              THE COURT:  I just dread the thought of asking
          25         this question, but are you suggesting there is some
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           1         agreement between you and Mr. Minton regarding the
           2         sale of real estate, as to your receiving proceeds
           3         from it?
           4              THE WITNESS:  Yes, your Honor.
           5              THE COURT:  I see.  Is there a lawyer in the
           6         room that wants to take that on a contingency?
           7         Probably not, Mr. Prince.
           8              Okay.  Continue on.
           9              THE WITNESS:  You know, I missed the point.  I
          10         guess you'll explain it to me later.
          11              MR. DANDAR:  That is all right.
          12              THE WITNESS:  I hate to miss the punch line.
          13    BY MR. DANDAR:
          14         Q    So anything else about these phone calls, before
          15    we get to the New York City meeting?
          16         A    Well, the only other thing I think I covered in my
          17    affidavit that Mr. Minton said is, you know, after having
          18    conversations with Mr. Rinder, that it basically boiled down
          19    to who is going to die?  Is it going to be Ken Dandar?  Is
          20    it going to be me.  And I --
          21              THE COURT:  Is that the word he used, "die"?
          22              THE WITNESS:  Yes, your Honor.  And for the
          23         life of me, you know, I couldn't get a concept of
          24         what he was saying.  I mean, he said it several
          25         times --
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           1              THE COURT:  Is this -- I'm sorry, my mind is
           2         off on agreements and it is kind of an insider joke
           3         that has nothing to do with you really, a lot of
           4         agreements we're talking about in this particular
           5         hearing, and we teasingly asked about what lawyer
           6         would take what on a contingency fee.
           7              THE WITNESS:  Oh, okay.  So nobody wants my
           8         opinion.
           9              THE COURT:  Well, it will be volunteered,
          10         Mr. Prince.
          11              Was this before or after the New York meeting,
          12         this conversation?
          13              THE WITNESS:  This was before the New York
          14         meeting.  This is after Ms. Brooks arrived.
          15              THE COURT:  Okay.
          16              THE WITNESS:  He was telling me that, you know,
          17         that somebody has to die.
          18              And, you know, Bob has always come to me, when
          19         he wanted to interface or maybe know something from
          20         Ken, he's asked me, you know.  So for the life of
          21         me, I couldn't figure out how is it now that
          22         suddenly we sit here today and we have to decide who
          23         dies.  Why does anyone have to die?  That was my
          24         question.
          25              And -- Mmm -- he told me that for them -- for
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           1         him not to go to jail and be prosecuted -- and he
           2         had actions going in both cases in front of both
           3         judges, Judge Schaeffer and Judge Baird -- that he
           4         somehow had to make this case go away, the Lawrence
           5         Wollersheim case go away, and that is -- he said,
           6         "That is all -- that is what they said they want.
           7         So we're going to go talk about that."
           8    BY MR. DANDAR:
           9         Q    In New York City?
          10         A    Yes.
          11         Q    All right.  And -- all right.  Anything else,
          12    before we get to New York City?
          13         A    That -- Mmm -- Stacy was just adamant that she
          14    would be able to successfully settle with Scientology so
          15    that they would disengage Bob Minton, because he was
          16    literally being driven insane.  He was terrorized into a
          17    state of mind that was beyond anything he was capable of
          18    dealing with.
          19              THE COURT:  Did you ever ask him what -- when
          20         he used the word "die," whether he was -- I mean, we
          21         all say, "Oh, I'm just going to die if such and such
          22         happens."  But he was not using that word in a
          23         literal sense, that was a --
          24              THE WITNESS:  Well, I asked him later about
          25         this.
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           1              THE COURT:  Okay.
           2              THE WITNESS:  After they came back from New
           3         York and was in the hotel, what was he talking
           4         about.
           5              THE COURT:  Right.
           6              THE WITNESS:  And what he was talking about was
           7         saying that Ken Dandar, as one thing, perjured --
           8         you know, blamed the perjury on Ken.  I mean, these
           9         are all things to do to get rid of the case.  Okay,
          10         so now we made Ken responsible for any perjury that
          11         Bob Minton did.  Then, you know, he mentioned about
          12         what's going to happen is Mr. Dandar is going to be
          13         disbarred.
          14              And I took it a step further.  I said, "Well,
          15         if Mr. Dandar gets disbarred, he's going to lose his
          16         business.  If Mr. Dandar loses his business, he's
          17         going to lose his home and his family.  Is this
          18         really what you want for Ken Dandar after you built
          19         him up all of this time, and now you get in trouble
          20         and now this is what we do?"
          21              THE COURT:  So, again, I think my question was
          22         is we all tend to use the word "die" and we don't
          23         really mean it literally, drop dead, I mean, die.
          24              THE WITNESS:  Oh, yes, I don't think --
          25              THE COURT:  He meant either business-wise or
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           1         something?
           2              THE WITNESS:  Professional decease, to cause
           3         decease, which is in accord with one of the
           4         Scientology policies we have gone over here.
           5    BY MR. DANDAR:
           6         Q    Is that known as fair game?
           7         A    No.  It is called the Scientologist's Manual of
           8    Dissemination, where it talks about, if possible, of course,
           9    ruin the person utterly.
          10         Q    Let's get to New York City.  Did you have any
          11    conversations with Bob Minton or Stacy Brooks about the New
          12    York City meeting with Rosen, Rinder and Yingling?
          13         A    Yes, I did.  When they were traveling to New York
          14    City, I was traveling to Memphis, Tennessee to drop my
          15    family off.  It had just reached a peak for me.  And I just
          16    wanted to have some safety in my life.
          17              So they called me when they left home.  They
          18    called me when they arrived.  They called me when they met,
          19    had the first meetings.  They seemed somewhat hopeful.
          20    Then, of course, the next day happened.
          21              But when they got there, you know, Steve Jonas
          22    arrived.  They were there.  They met.  They went over what
          23    they wanted.  And Bob -- you know, one of the things Bob
          24    did, which I didn't know he was going to do until he got to
          25    New York, is he said he wanted my house to be able to be
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           1    sold, because I had had my house on the market for some
           2    time, zillions of people were coming there.  And, you know,
           3    unfortunately, it just didn't sell.
           4              So he thought that that may have had some
           5    Scientology influence.  And the reason why I think he thinks
           6    that, because the realtor for our building --
           7              THE COURT:  He?  This is Mr. Minton again?
           8              THE WITNESS:  Yes.
           9              THE COURT:  Okay.
          10         A    The realtor for the building in downtown called
          11    Mr. Minton while he was in New York and told him he had had
          12    a buyer for the LMT building, and this buyer was a person
          13    that sold furniture, sold used furniture.
          14              And he mentioned this potential buyer -- this
          15    potential buyer mentioned to his clients, current clients,
          16    that he was going to move his operations to this building,
          17    and would that be okay, would he still be able to service
          18    them.
          19              And he came back and said he found out that
          20    45 percent of his clients were, in fact, Scientologists.
          21    And he was told in no uncertain terms that if he moved into
          22    that building, that they would no longer do business with
          23    him.  So --
          24              MR. WEINBERG:  Your Honor, I object.
          25         A    He couldn't -- he couldn't --
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           1              MR. WEINBERG:  This is hearsay on hearsay.
           2         This is supposedly what Mr. Minton said that
           3         somebody said.
           4              THE WITNESS:  No.  Mr. Minton said to me that
           5         the realtor --
           6              MR. WEINBERG:  Said to him.  Objection, double
           7         hearsay.
           8              THE COURT:  I do understand.  But, remember,
           9         this has to do with Mr. Minton and whether
          10         Mr. Minton has lied or whether Mr. Dandar is lying.
          11         Mr. Minton's state of mind, therefore, becomes, to
          12         some extent, relevant.
          13              I understand it is double hearsay.  I
          14         understand what that means.  But I'll allow it.  It
          15         is a very unusual hearing.
          16              MR. WEINBERG:  Okay.
          17    BY MR. DANDAR:
          18         Q    So when did you first hear back from Bob Minton
          19    concerning the first day of the New York City meeting on the
          20    28th?
          21         A    The night of the 28th after they met.  He said,
          22    "Well, we met."
          23              I spoke to Stacy.  She said, "I think it is going
          24    to be okay.  I think we'll be able to work this out.  Ken
          25    Dandar is not going to be happy."
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           1              Mmm, you know, I said, "Okay," whatever that
           2    meant, because, you know, I'm not really tracking.  I just
           3    know something traumatic has happened, it has to do with
           4    some information that came up on Bob, and I know that now
           5    Stacy Brooks and Bob Minton are in negotiations to disengage
           6    this whole thing, and I am not there but they are calling
           7    me, telling me what is going on.
           8         Q    Did they tell you why I would not be happy?
           9         A    Whew.  Because they were going to say that you
          10    caused Bob Minton to lie about the check -- that you advised
          11    him to lie about the check.  This was during that particular
          12    time.
          13              THE COURT:  Is this Ms. Brooks testifying -- or
          14         Ms. Brooks telling you this?  Or is this Mr. Minton
          15         telling you this?
          16              THE WITNESS:  You know, it is kind of a bit of
          17         both, your Honor.
          18              THE COURT:  Was this over the telephone?
          19              THE WITNESS:  Yes.
          20              THE COURT:  This was after the first New York
          21         meeting?
          22              THE WITNESS:  This was the night of the first
          23         day of the meeting on the 28th.
          24              THE COURT:  Of March?
          25              THE WITNESS:  Yes.
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           1              THE COURT:  It was this night they were
           2         explaining to you -- either Bob or Stacy, or both of
           3         them, on the phone, explaining why Ken wasn't going
           4         to be happy?
           5              THE WITNESS:  Yes.
           6              THE COURT:  Okay.  Go ahead.
           7    BY MR. DANDAR:
           8         Q    Now, Mr. Prince, I want to make sure you don't
           9    have your dates mixed up.  Could you look at your affidavit
          10    to refresh your memory and make sure you have your dates
          11    down when you first mentioned that Ken Dandar wasn't going
          12    to be happy.
          13         A    Okey-doke.  Okay, I'm looking at my affidavit --
          14         Q    By the way, who typed that affidavit?
          15              MR. WEINBERG:  Your Honor --
          16              THE COURT:  Just a second now.
          17              MR. WEINBERG:  I object to this process.  He
          18         has done this a number of times.  He elicits
          19         testimony.  Mr. Prince testifies, he's very
          20         specific, he had this conversation.
          21              Then Mr. Dandar takes his affidavit and says,
          22         "Well, look at this and see if it is really your
          23         testimony."  He's impeaching him.
          24              MR. DANDAR:  Well --
          25              MR. WEINBERG:  I don't think it is proper.
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           1              THE COURT:  I think that I'm -- I have heard
           2         his testimony.  I think he can look at his affidavit
           3         and see if it refreshes his memory.  If it does,
           4         I'll just have to remember his testimony was
           5         different before it was refreshed with this
           6         affidavit.
           7              MR. WEINBERG:  Okay.
           8         A    Yes.  Okay.  I talk about the problem with the
           9    checks.  We talked about that again.  This was the next day
          10    on the 29th -- now, wait a minute.  "Bob told me he
          11    called --" now, see, this is before they went to New York,
          12    "Bob told me he made -- "
          13              THE COURT:  You are going way too fast.
          14         A    "Scientology was going to put him in jail."
          15              THE COURT:  What page are you on, please?
          16              THE WITNESS:  I'm on Page 3.  Bottom of Page 3,
          17         Line 27 --
          18              THE COURT:  All right.
          19              THE WITNESS:  -- and 28.  "Bob said there was a
          20         problem with some checks he had given to Ken
          21         Dandar."
          22              That was the --
          23    BY MR. DANDAR:
          24         Q    That is before the New York trip?
          25         A    Yes.  Okay, so they arrive in New York.  "The next
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           1    day, on the 29th, the next day around noontime," I'm on Page
           2    4, Line 10, "Stacy called me.  She was upset.  Bob was going
           3    to jail for contempt in front of Judge Schaeffer, going to
           4    jail for perjury in front of Judge Baird.  At this point
           5    they had only mentioned to me about the wrongful death suit
           6    and the Wollersheim suit having to be dismissed for Bob not
           7    to go to jail.  Mr. Rinder --"
           8              THE COURT:  You don't have to read out loud.
           9         You really are looking to see when it was that -- if
          10         this -- if this refreshes your memory as to when
          11         this statement about why it was that Mr. Dandar
          12         would not be happy.
          13              MR. DANDAR:  Right.
          14    BY MR. DANDAR:
          15         Q    When did that first occur?
          16              THE COURT:  When it occurred.
          17         A    Either the 28th or the 29th, one of those two
          18    days.
          19    BY MR. DANDAR:
          20         Q    Okay.  And then again I want you to look at your
          21    affidavit --
          22         A    And, you know, this information was sketchy
          23    because I didn't get the full picture until they came here
          24    to Florida.  I wasn't able to divine the full picture until
          25    they actually came back from that meeting.
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           1         Q    Okay.
           2         A    Now --
           3         Q    Do you recall -- do you recall that Mr. Minton
           4    called you up, after the second day of the New York City
           5    meeting, to talk to you about a phone call he received from
           6    Mr. Rinder?
           7         A    Oh, after they got back from New York?
           8         Q    Right.
           9         A    Yes -- well, no.  Stacy is the one that I spoke
          10    to.
          11         Q    What did she say?
          12         A    She said, after they got back from New York, they
          13    were all upset and thought they wouldn't be able to
          14    negotiate with Mr. Rinder and Mr. Rosen.
          15         Q    Why?  Why wouldn't they be able to negotiate?
          16         A    Because they told Mr. Rosen and Mr. Rinder flat
          17    out that they had no influence to get either of these cases
          18    dismissed or made go away or whatever, they had no authority
          19    to do that; that Stacy Brooks had already made an attempt to
          20    contact Dell Liebreich to get her to drop the case, so she
          21    wasn't interested in hearing from Stacy; and Mr. Wollersheim
          22    certainly -- and Mr. Leipold were certainly not interested
          23    in dismissing their case, either.
          24              THE COURT:  When -- now, I'm so confused, and I
          25         haven't read your affidavit in some time so I'm
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           1         listening basically to your testimony.
           2              You indicated -- what I think you just said is
           3         Ms. Brooks told you on the telephone that she had
           4         told Mr. Rinder that they didn't have the proper
           5         influence to get the case dismissed?
           6              THE WITNESS:  See, I'm totally screwing this up
           7         if you think that, your Honor, because what I'm
           8         saying there is that happened in New York where they
           9         were face-to-face with Mr. Rinder, with -- at least
          10         this is what was relayed to me by Stacy and by Bob
          11         on the phone conversation when they left the office,
          12         I think it was about noontime on the 29th where they
          13         tried to make it clear that they had no influence
          14         over these cases and they were asking them to do
          15         something they were not able to do.
          16              THE COURT:  What confuses me, if I did
          17         understand your testimony, after the New York
          18         meeting, perhaps the very night of the New York
          19         meeting, Stacy called and -- Stacy and/or Bob called
          20         and said, "I think we're going to be able to work
          21         this out."
          22              THE WITNESS:  Yes, that was after they came
          23         back to New Hampshire, left New York, because they
          24         were back in New Hampshire that day.
          25              THE COURT:  Okay.
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           1              THE WITNESS:  It was either that night or the
           2         next day I spoke to Stacy Brooks, and she said she
           3         had received a second conversation from Mr. Rinder,
           4         who mentioned that he thought that there may have
           5         been a misunderstanding, while he understood that
           6         they legally -- or, you know, weren't plaintiff or
           7         defendant, had no standing to effect these cases one
           8         way or another, that there were things that could be
           9         done to get the same result.
          10              THE COURT:  This was another conversation with
          11         Mr. Rinder and Mr. Minton or Ms. Brooks, when they
          12         told you about that, that is when they said, "We
          13         think we can do something but it is not going to
          14         make Ken Dandar happy"?
          15              THE WITNESS:  Yes.
          16              MR. WEINBERG:  Would that be on the 29th, your
          17         Honor?
          18              THE COURT:  I believe.
          19              THE WITNESS:  The 29th or the 30th or such a
          20         date of this.
          21              MR. WEINBERG:  Of March?
          22              THE WITNESS:  Yes.
          23    BY MR. DANDAR:
          24         Q    When did you get the details about what that meant
          25    about Ken Dandar not being happy?
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           1         A    When they traveled to Florida for the Judge Baird
           2    hearing that was, I think, occurring on April 5.
           3         Q    That is Judge Schaeffer.
           4         A    Hmmm?
           5         Q    Judge Schaeffer was April 5?
           6         A    That is right.  Judge Schaeffer was April 5.  But
           7    they had a Baird one right the next week or whatever.
           8         Q    Right.
           9         A    Anyway, when they came down for that activity,
          10    then we had a meeting at the Harbour Bay Hotel in Tampa,
          11    Florida where they made it clear to me what was happening
          12    here.
          13              Because I asked them, "Did you find out what these
          14    things were that you can do to make these cases go away?"
          15              I'll start with Wollersheim because that will be
          16    quickly.
          17         Q    All right.
          18         A    She said what she had already done and told
          19    Scientology she would do and had done, that she called Dan
          20    Leipold and told him to withdraw her testimony -- her
          21    affidavits in the Wollersheim case, and she had instructed
          22    him to do the same for my affidavits.
          23              And there was only three, Vaughn Young, Stacy and
          24    me.  Vaughn Young, because of his physical condition, how
          25    upset he would be to even do that, she told me she had not
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           1    promised Scientology anything in relationship to Vaughn, but
           2    she could promise the relationship to me and her.
           3         Q    How did you react to your affidavit being
           4    withdrawn?
           5         A    I was shocked.  I was like, "I'm not withdrawing
           6    my affidavit."
           7         Q    Why did she want to withdraw her affidavit?
           8         A    Because these are the things that she could do --
           9    you know, they want -- they want what are the things you can
          10    do?  What you can do is take your testimony out.  Take
          11    Jesse's testimony out of there.  Because there was only
          12    three witnesses that they were using on the issue of alter
          13    ego to claim the judgment.
          14         Q    Did you ever --
          15              MR. WEINBERG:  Before -- could we just date
          16         that?  Is that at Harbour Island?  Is that what you
          17         are saying?  Could we just date it?
          18              THE WITNESS:  I think I dated it in the
          19         affidavit.
          20              THE COURT:  You want to look at your affidavit
          21         and see if you can find it then?
          22              THE WITNESS:  Okay.  Okay.  Yes, Page 5, Line
          23         11.
          24    BY MR. DANDAR:
          25         Q    What is the date?
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           1         A    If you look at Line 22, he starts talking about
           2    things that could be done.
           3              THE COURT:  Line 22?
           4              THE WITNESS:  Yes.  Where it starts talking
           5         about things that could be done.
           6              THE COURT:  And that is where you use the
           7         phrase, "Ken Dandar was not going to be happy"?
           8              THE WITNESS:  Right.  So when we met at the
           9         hotel, you know -- and I'm doing the best job I can
          10         here -- I asked them -- they mentioned about getting
          11         the affidavits out of the Wollersheim case, then
          12         specifically here in the wrongful death case --
          13         "Well, what are you going to do with that?"
          14              "Well, Mmm, we're going to --" they had a
          15         couple of things they were going over.  One, the
          16         perjury of the check to make it seem like it was Ken
          17         Dandar's fault.
          18              And then they were insistent about some meeting
          19         that had occurred which included myself, Dr. Garko,
          20         Stacy Brooks, Bob Minton, Mr. Dandar, where we were
          21         discussing adding Mr. Miscavige as a party, and how
          22         Ken Dandar had instructed Mr. Minton to say the
          23         conversation never happened, something about it
          24         never happened.
          25              Now, you know, for me, I'm not understanding
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           1         this because it is not making a whole lot of sense
           2         why it would matter one way or another.  You know,
           3         I'm not a lawyer, I'm not a criminal, I didn't
           4         understand what they were talking about.
           5              But those were two things specifically that
           6         they mentioned bringing out about Mr. Dandar and
           7         connecting him with perjury.
           8              THE COURT:  One was the check?  Is it the
           9         $500,000 check that you testified to previously?
          10              THE WITNESS:  Yes, your Honor.
          11              THE COURT:  Number two was some meeting that
          12         occurred dealing with adding Mr. Miscavige as a
          13         party?
          14              THE WITNESS:  Yes, your Honor.
          15    BY MR. DANDAR:
          16         Q    Was there anything else of how they were going to
          17    get Ken Dandar, besides these two items?
          18         A    Well, the only other thing that came up -- I knew
          19    about those two things.  But then they had the meeting with
          20    Judge Schaeffer where Bruce Howie did something, and the
          21    whole thing was moot.  And they were happy about that.
          22              I think maybe that same day he got served with the
          23    Armstrong suit.  And he told me, "It's not over, I still
          24    have got to go in front of Judge Baird."
          25              Now, I think at that same time the decisions came
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           1    down from the 2nd -- from the appeals court concerning
           2    discovery issues with finances and this, that and the other
           3    thing, so it was kind of like things were turning around.
           4              So I'm questioning them, "Do you really think you
           5    need to do this?"
           6              And they are trying to elicit my cooperation, like
           7    we used to have this thing amongst us, me, Stacy and Bob, we
           8    called ourselves the A team.  There was three of us, this is
           9    an A team activity.  It is tough at the top, we have to make
          10    some hard decisions here, you know.  So I'm part of that
          11    entity.  So we're discussing these matters.  And, Mmm --
          12              MR. WEINBERG:  Your Honor, is this all one
          13         conversation?  Does it mean it happened after your
          14         hearing on April 5?
          15              THE COURT:  I'm not real sure.
          16              MR. WEINBERG:  All right.
          17              THE COURT:  Was this all at the same
          18         conversation?
          19              THE WITNESS:  Mmm, your Honor, maybe not
          20         because, I mean, I was with them the whole time and,
          21         you know, Page 5, starting at Line 11 -- 16, Number
          22         11 on the affidavit, I talked about the time periods
          23         we were there, the 2nd or 3rd of April through --
          24              THE COURT:  Did you try, in your affidavit, to
          25         date the time frames when these conversations took
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           1         place as you remembered them?
           2              THE WITNESS:  Yes, I did.  I sat there with a
           3         calendar and I did it as best I could.
           4              THE COURT:  Okay.  So those are the dates as
           5         best you can recall?
           6              THE WITNESS:  As best I can recall.
           7              THE COURT:  All right.  So whatever it says in
           8         the affidavit is the best he can recall.
           9              MR. WEINBERG:  All right.
          10              THE WITNESS:  Yes, that is the way I sat and
          11         worked on it.
          12              MR. WEINBERG:  I was really more asking whether
          13         this was one conversation or he was -- he talked
          14         about a conversation in the Harbour -- I think he
          15         meant Harbour Island Hotel, but --
          16              THE COURT:  It depends what the affidavit says.
          17              MR. WEINBERG:  All right.
          18              THE COURT:  Is that right, Mr. Prince?
          19              THE WITNESS:  Yes, your Honor.
          20              THE COURT:  The affidavit speaks of these
          21         things that you have been talking about in different
          22         conversations.  That would be your testimony if you
          23         refreshed your memory?
          24              THE WITNESS:  Yes, your Honor.
          25
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           1    BY MR. DANDAR:
           2         Q    So your memory was better when you wrote this in
           3    April than it is in July?
           4         A    For sure.
           5         Q    In your affidavit you say Harbor Bay Hotel.  That
           6    is not Harbour Island Hotel.  Do you know where the Harbor
           7    Bay Hotel is?
           8         A    No, I guess not if I am confused about it.  It is
           9    the one that has the restaurant in there -- well, that means
          10    nothing, they all have.  Okay, I'm sorry, I spoke out of
          11    turn.
          12         Q    All right.  But what I'm saying, when you took the
          13    time to sit down and write your affidavit of April 2002, of
          14    course you weren't under pressure, being examined in front
          15    of a judge in a courtroom.  You said you had a calendar in
          16    front of you?
          17         A    Yes.
          18         Q    Okay.  Now, let's jump back again to New York
          19    City.  All right?
          20         A    Okay.
          21         Q    Well, no, I'm sorry.  Let's go to the
          22    conversations you had with Bob Minton and Stacy Brooks about
          23    New York City.
          24              Did they tell you what type of things Mr. Rosen
          25    said to Mr. Minton at the New York City meetings?
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           1         A    That he was going to jail and actually spoke with
           2    him quite loudly about this.  That he was going to jail.  He
           3    was going to be prosecuted in front of Judge Schaeffer and
           4    Judge Baird.
           5              Mmm, by giving the affidavit, I wrote either
           6    Bob -- Mr. Rinder -- he told me -- Bob Minton told me
           7    specifically Mr. Rinder said, you know, "Bob, you know I'm
           8    f-ing you but I'm doing it to your face.  You have people
           9    around you that are doing it behind your back."
          10              And he mentioned the people that were doing it
          11    behind his back being yourself, Patricia Greenway and Peter
          12    Alexander.
          13         Q    Did there come a point in time when Mr. Minton
          14    showed you any documents that he received from the Church of
          15    Scientology?
          16         A    Yes.  This was when they had -- yeah, now this is
          17    after I actually attended the Judge Baird hearing, saw Bob
          18    get up on the stand and start lying, and left and went to --
          19         Q    All right, I probably jumped the gun.  And I
          20    apologize.  Let's go back.
          21              Before we get to the Judge Baird hearing, let's
          22    make sure, as far as you can recall today, what transpired
          23    when Bob and Stacy came to Florida.
          24         A    The first time they came to Florida, they were
          25    concerned about the hearing in front of Judge Schaeffer.
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           1    They were meeting with Bruce Howie.  They were continuing to
           2    meet with Scientology, working on the things that could be
           3    done to get these suits dismissed.
           4              And I guess part of it was to elicit my
           5    cooperation to go along with this new plan to disengage
           6    Scientology from Bob Minton.
           7         Q    Okay.  And did Mark Bunker come with them?
           8         A    Yes.
           9         Q    And Mark Bunker, did he stay at your house?
          10         A    Yes, he did.
          11         Q    Did anyone else stay at your house?
          12         A    No.
          13         Q    All right.  So did you attend the deposition of
          14    Mr. Minton on April 8?
          15         A    No, I did not.
          16         Q    All right.  So the first time you saw Mr. Minton
          17    testify was before Judge Baird?
          18         A    Correct.
          19         Q    All right.  And you said that you sat in the
          20    audience?
          21         A    Yes, I did.
          22         Q    And what did you hear Mr. Minton say you thought
          23    was a lie?
          24         A    Mmm, something about Mr. Dandar making -- telling
          25    Bob to perjure himself in relationship to the checks.
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           1         Q    All right.  How did you know that was a lie?
           2         A    Because if that would have happened, I would have
           3    known about it when it happened.  You know --
           4         Q    Why is that?
           5              MR. WEINBERG:  Objection, your Honor.  I move
           6         to strike, "if that would have happened, I would
           7         have known about it when it happened."  How is that
           8         a response?
           9              MR. DANDAR:  I'm asking him to explain it right
          10         now.
          11              THE COURT:  Yes.  Overruled.
          12         A    If there had been some agreement between
          13    Mr. Dandar and Bob Minton to hide the fact that -- the
          14    check, I would have known about it when it happened.
          15              THE COURT:  Are you saying that Mr. Minton
          16         would have told you?
          17              THE WITNESS:  Yes.  That is what I'm trying to
          18         say.  He would have told me when it happened.
          19              Now, this coming up after all of this time,
          20         when I'm sitting there and he -- you know, he's
          21         taking us up to the garage when he gave the check,
          22         he's saying this stuff is coming from Europe and you
          23         don't know where it is coming from, on and on, now
          24         suddenly he changes his mind, I knew it was a lie.
          25         Or he told me -- one way or another, he's lying now.
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           1    BY MR. DANDAR:
           2         Q    All right.  What was the next thing he lied about
           3    before Judge Baird?
           4         A    I just got up and just walked out.  I couldn't
           5    take it.  I couldn't believe what was happening.  I was
           6    extremely distraught.
           7              As I say in my affidavit, I actually wept
           8    because -- you know, because once again we see the big
           9    Scientology machine, with all of its high-priced lawyers and
          10    endless resources, endless staff, to make this occur.  "We
          11    can't get the case dismissed or thrown out in any other way
          12    so now let's go manufacture some information."
          13              MR. WEINBERG:  Objection, your Honor.
          14         A    Let's create --
          15              MR. WEINBERG:  This is pure and utter
          16         speculation.
          17              THE COURT:  Not only that, but I think it is
          18         just kind of a discussion what he thinks.  And,
          19         frankly, I need his testimony, not what he thinks.
          20         He can put that in someplace else.
          21              That objection is sustained.
          22    BY MR. DANDAR:
          23         Q    Before you walked out of the courtroom, did you
          24    hear Mr. Minton say any other lie outside of the Dandar
          25    making a lie about the $500,000 check?
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           1         A    No.  I got up and left immediately.
           2         Q    All right.  And when is the next time you were
           3    talking with Mr. Minton or Stacy Brooks?
           4         A    After they had left Clearwater.  I mean, I just
           5    couldn't even stand to be around them anymore.  When I saw
           6    that that thing happened in front of Judge Baird, I didn't
           7    know what to do.
           8              And I finally figured that, you know, in my mind
           9    something criminal was going on here, I need to do something
          10    to help my friends.  So I went to visit Mr. Denis deVlaming.
          11    And I --
          12              THE COURT:  When you say to help your friends,
          13         you are talking about your friends Bob Minton and
          14         Stacy Brooks?
          15              THE WITNESS:  Yes, your Honor.
          16    BY MR. DANDAR:
          17         Q    So you went, on your own, to Denis's office?
          18         A    Yes.
          19              THE COURT:  I'm sorry, I should not put words
          20         in your mouth, either.  Obviously you meant
          21         Mr. Minton when you say friends.  Who was the other
          22         friend?
          23              THE WITNESS:  Mmm, Stacy Brooks.  I went to
          24         Mr. deVlaming's office and I explained to him that I
          25         had been privileged to know that this was going to
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           1         happen, that this was going to be created and done
           2         against you, and I explained the whole thing to him.
           3              And his reaction was, "Oh, well, they got him
           4         this time."  But because he had represented me
           5         before, and he had also represented Mr. Minton, he
           6         told me that it was a conflict of interest, because
           7         I went there to see if I could somehow get law
           8         enforcement involved in what was going on here
           9         because I was confident that Bob was lying on behalf
          10         of Scientology.
          11              And I asked him to put me in touch with someone
          12         on a federal level, because I believed that
          13         Scientology did have influence in the state
          14         prosecutor's office.  I believed that they were able
          15         to somehow enact, somehow, undue influence on
          16         prosecutors simply because they never get prosecuted
          17         for the things that they do.  And I myself, you
          18         know, I could have one little small marijuana plant
          19         in my house, I'm raided by the DEA.  But, you know,
          20         a person -- a dead body shows up, they can't do
          21         anything.
          22              I had no confidence in that.  I asked a
          23         federal -- asked for federal protection, a federal
          24         level, because I said in my mind what they have done
          25         is RICO; they have conspired to commit a crime that
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           1         started in New York, they continued it down here in
           2         Clearwater.
           3              Bob told me clearly that he was not going to
           4         involve his lawyers in the negotiations proper to
           5         any degree where they're really getting down to the
           6         meat and potatoes.
           7              THE COURT:  Did Bob tell you why?
           8              THE WITNESS:  Because they disagreed.
           9         Mr. Jonas thought the whole thing was disgusting and
          10         distasteful that was going on.
          11    BY MR. DANDAR:
          12         Q    Mr. Minton's lawyer?
          13         A    Yes.  Mr. Jonas, up in Boston.  And you notice he
          14    has been visibly gone.  He didn't want nothing to do with
          15    this.
          16              So they decided to use Mr. Howie to enact this.
          17    And they didn't tell him what was going on.  They were
          18    happily meeting with these lawyers and without any
          19    representation.
          20         Q    Well, why --
          21              THE COURT:  Wait, you said they were happily
          22         meeting with these lawyers without representation.
          23         What is it you mean?
          24              THE WITNESS:  The lawyers specifically that Bob
          25         and Stacy were meeting with was Sandy Rosen and
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           1         Monique Yingling.
           2              THE COURT:  All right.
           3    BY MR. DANDAR:
           4         Q    Did Mr. Minton tell you why he chose not to have
           5    Mr. Howie or Mr. Jonas go with him to meet with Mr. Rinder,
           6    Mr. Rosen and Ms. Yingling?
           7         A    Mr. Jonas thought the whole thing was disgusting
           8    and distasteful and thought it would be improper.  And he
           9    told Bob specifically -- and Bob told me he told him -- not
          10    to meet with Scientology without representation.
          11              Mr. Minton -- Mr. Minton mentioned that Mr. Howie
          12    could be used because he didn't really understand what was
          13    going on in the first place with -- I mean, and the reason
          14    why he didn't understand, it is not because he's a stupid or
          15    ignorant person -- but because they weren't giving him all
          16    of the information, Bob and Stacy were not telling Mr. Howie
          17    everything, they were negotiating with Scientology and
          18    telling Mr. Howie what they wanted him to hear.
          19         Q    But why -- did Mr. Minton explain to you why he
          20    chose not to have his attorneys be present at the meetings?
          21              THE COURT:  I presume you're talking about the
          22         meetings in Florida?
          23              MR. DANDAR:  Yes.
          24              THE COURT:  And his lawyer down in Florida
          25         being Mr. Howie?
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           1              MR. DANDAR:  Yes.
           2              THE COURT:  Because Mr. Jonas was in New York?
           3    BY MR. DANDAR:
           4         Q    Yes.  Did he tell you why he didn't want Mr. Howie
           5    at these meetings?
           6         A    Mr. Minton expressed to me that he had personally
           7    had enough of lawyers, period.  And he thought that this is
           8    something he needed to do.
           9         Q    All right.  By the way, did Mr. Minton ever appear
          10    at a meeting with you, me, Dr. Garko, Stacy Brooks, to talk
          11    about adding on David Miscavige?
          12         A    No.
          13         Q    Ever?
          14         A    No.  This was the second big point, you know,
          15    that -- you know, that Stacy is going on and on, "Jesse, you
          16    have to remember, it happened like this."
          17              "I told you, you are imagining this.  It never
          18    happened.  I'm not going to sit and lie about this."
          19              But this was another point I was supposed to go
          20    along with at the meeting.  This is where they were really
          21    trying to bring me in to find these points to get you,
          22    basically.
          23         Q    Well, what made you not join and continue to be
          24    part of the A team, as you call it?
          25         A    Well --
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           1              MR. WEINBERG:  Your Honor, I -- can we explain
           2         what the A team is?  Because maybe I missed
           3         something.
           4              THE COURT:  Yes, the A team is Jesse Prince,
           5         Bob Minton and Stacy Brooks.  They laughingly
           6         referred to themselves as the A team.
           7              MR. WEINBERG:  I guess I was daydreaming.  I
           8         didn't hear that.  Sorry.
           9              THE COURT:  I did.  So I -- I miss some, but I
          10         recall that.
          11              MR. WEINBERG:  You caught that but I missed the
          12         A team.  Okay.
          13    BY MR. DANDAR:
          14         Q    So why did you choose not to go along?
          15         A    Well, Mr. Dandar, for obvious reasons.
          16              Number one, I worked for years on this case.  I
          17    have worked honestly, to the best of my ability, on this
          18    case.  I assumed that Stacy was, as well.
          19              Mmm, I understood that Bob Minton -- Scientology
          20    discovered something about him that upset him greatly and
          21    had him horribly concerned.  But I wasn't going to lie to
          22    protect him to hurt someone else.
          23              And, in fact, my exact words to Mr. Minton was --
          24    and Mrs. Brooks, that I will never, in my life, help
          25    Scientology hurt or destroy one more person.
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           1         Q    When did you tell them that?
           2         A    After -- after I walked out of Judge Baird's
           3    courtroom, and then now they're all looking for me and
           4    they're calling around to see if I'm in jail or see if I'm
           5    in the hospital.  They thought I had a heart attack, because
           6    I was visibly upset.  I mean, I was shaking when I walked
           7    out of that Judge Baird's courtroom.
           8              But the thing is I didn't want to see them.  I
           9    told my fiance, "You tell them to go home where they live
          10    because --" excuse this expression "-- they have come and
          11    shit all over where I live, I don't want to see them.  You
          12    go back to where you live and then we'll discuss this."
          13              And we discussed it.  And when we discussed it,
          14    when I got on the phone with them after they got back, that
          15    is when I had the conversation and said that to them.  "I
          16    can't do it."
          17         Q    Did you meet with them after Judge Baird's hearing
          18    in Clearwater?
          19         A    Yes.  I met with them a couple -- not after the
          20    Judge Baird hearing.  You know, at a later date after that,
          21    sure.
          22         Q    Do you recall meeting with them that following
          23    weekend?
          24         A    It could have been that weekend.  Again, I have
          25    done the dates here to the best of my recollection, with
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           1    sitting down with the calendar.  But it was after the Judge
           2    Baird -- yeah, because Bob had been deposed -- no, wait a
           3    minute, I'm confusing incidents now, because by the time
           4    they went back, they had already been through the Baird
           5    (sic) deposition and they were having the contempt hearing
           6    or whatever it was in front of Baird where he lied.
           7              So, you know, they came back at a later date.  And
           8    the discussion was -- after they got back to New Hampshire,
           9    I told them how upset I was and how I couldn't do it, and
          10    Stacy said to me in no uncertain terms that, "The reason you
          11    feel this way is because you don't have all of the
          12    information.  We've been leaving you out of the loop on some
          13    things that you need to know."
          14              She said that they had signed some agreement with
          15    Scientology, so -- she couldn't tell me everything, but the
          16    next step was to bring me back into the circle to make this
          17    go away for Bob.
          18              And Stacy was just hell bent for leather to do
          19    whatever she had to do to disengage Bob from Scientology
          20    because she thought it was killing him.
          21         Q    Did you meet with them in Clearwater then?
          22         A    Yes, I did.  We met at Adam's Mark Hotel.
          23         Q    At the Adam's Mark Hotel there are two things I
          24    want you to talk about.  Number one, the conversation.  And,
          25    number two, any documents you saw.
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           1         A    Well, I hadn't seen Bob.  He knew I was furious
           2    with him.  I hadn't seen Stacy because I was furious with
           3    her.  But we agreed to meet because we were friends.
           4    Friends don't get along every day.  It would be nice if you
           5    did.  But you don't lose a friend because there is a
           6    disagreement.
           7              So we met.  And Bob told me, you know, he said,
           8    "Look, Jesse, you know, I'm not sure that this is gonna
           9    work, either.  Stacy is more confident about doing this than
          10    I am.  I don't know."  We were kind of having that
          11    discussion.
          12              Then the phone rang.  Mr. Minton spoke with
          13    someone and he said, "Okay, leave it at the desk" and he
          14    hung up the phone.
          15              And I asked him what that was.
          16              And he said Scientology was delivering to him a
          17    packet of information that had to do with his prior
          18    deposition testimony -- or prior testimony, that amounted to
          19    about 11 inches, for him to go through for the purpose of
          20    finding more things for him to -- Mmm -- quote/unquote,
          21    recant or do whatever he was going to do.
          22              There was total -- I asked him, "How many things
          23    besides Wollersheim and the Lisa McPherson case, what else
          24    do they want you to do?  Do you know when your leash is over
          25    with, where they get done with you?  Okay, you think if you
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           1    destroy Ken, that will make you safe.  But what else are
           2    they going to have you do?  Do you know?"
           3              He said he didn't know, but this package
           4    represented six to seven other things that they wanted him
           5    to change testimony about or -- or say something different
           6    about.
           7         Q    Did you see this package?
           8         A    Mmm, no.
           9         Q    How do you know it was 11 inches high?
          10         A    He told me.
          11         Q    Okay.
          12         A    And he also told me at that time that his
          13    attorney, Steve Jonas, told him not to meet with Scientology
          14    concerning that package without representation, but he was
          15    going to do it anyway --
          16         Q    Okay.
          17         A    -- because he's taking control.
          18         Q    Did you ever see any lawsuits that Mr. Minton was
          19    given where Scientology was suing him or contemplating suing
          20    him?
          21         A    He had a rough draft of a RICO suit that he showed
          22    me.  It was about this thick.
          23         Q    How many inches is that?
          24         A    It was about maybe an inch, inch and a quarter,
          25    something like that.  And he --
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           1         Q    All right.
           2         A    -- flipped through it like this.  And he would
           3    never physically give it to me.  He said -- and we all
           4    predicted they were going to do some crazy RICO thing.  He
           5    said, "They finally did it.  Here is the RICO thing.  We
           6    already have the Armstrong thing.  They are suing me for
           7    80 million which I'll be liable for, here is the -- another
           8    RICO, that is another 110 million.  They are adding me as a
           9    defendant in the breach of contract.  And," he said, "I'm
          10    the only person with money.  I have got to get out of this."
          11         Q    Okay.  Now, did you at any time tell Mr. Minton or
          12    Ms. Brooks that you were willing to meet with Scientology?
          13         A    Yes.
          14         Q    When was that?
          15         A    Mmm, at the Adam's Mark Hotel when they -- you
          16    know, what they call bringing me into the circle.
          17              And I'm looking at these people that I have worked
          18    with for years and I might as well have been looking at
          19    strangers, because Stacy has this whole thing lined up.
          20    She -- you know, she knows exactly what is going to happen,
          21    who is going to do what.  And Bob is kind of like following
          22    along because he's just at his wit's end.  And Stacy figures
          23    that she knew Mike Rinder for a long time and they were good
          24    friends and she's just going to make this as good for Bob as
          25    possible.
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           1              And, to me, she just delivered Bob into the hands
           2    of his enemies.
           3         Q    Did Stacy Brooks ever -- in all of the years you
           4    have known her, did she ever say to you, "I filed a false
           5    declaration or affidavit"?
           6         A    Never in a million years.  To the contrary, Stacy
           7    is fully aware that part of, you know, Scientology's
           8    intelligence operations are to get rid of the lawsuit in any
           9    way possible.  You know, whether you actually have real
          10    evidence, get rid of it, or you manufacture it or you bring
          11    up enough threat where the person just wants to be done with
          12    it.  She knows this because it happened to her.
          13         Q    When?
          14         A    December of 1999 she did an affidavit about it,
          15    about the same people, Mr. Rinder, Mr. Sutter, coming in,
          16    wanting them to change testimony, offering money.
          17              THE COURT:  We have had testimony about that.
          18              THE WITNESS:  Yes.  All right.
          19    BY MR. DANDAR:
          20         Q    Well, did she ever say -- I just wanted to touch
          21    on that.  Did she ever say that Mr. Rinder was actually
          22    telling her the truth about attacking Graham Berry and
          23    Graham Berry did something bad?
          24         A    No.  But what she did mention to me, she said,
          25    "You know, after speaking with Mr. Rinder, you know, I
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           1    always thought in the Fishman case --" where she appeared as
           2    an expert, she said she always thought that because they
           3    tried to add Miscavige on as a party, that that made
           4    Scientology want to instantly settle because, you know,
           5    hands off from Miscavige, he's the ecclesiastical leader of
           6    the Church, Sea Org, on and on.
           7              So she said that after speaking with Mr. Rinder,
           8    she came to realize that it wasn't adding Miscavige that
           9    caused the suit to be settled in the way it was.  After
          10    talking with Mr. Rinder she came to understand that it was
          11    because of the introduction of Scientology's upper levels at
          12    which they commonly call it as being trade secrets that was
          13    the real issue at hand.
          14         Q    Okay.  Did Stacy Brooks ever say that her
          15    affidavits that she filed about Mr. Rinder offering her and
          16    her husband over $200,000 to change their testimony -- did
          17    she ever tell you that Mr. Rinder's version of what her
          18    declaration should be was true versus what Mr. Berry had her
          19    sign?
          20         A    Mmm, no.  We -- I mean, I had read that
          21    information before that she had done this.  And at this
          22    point in time at the Adam's Mark Hotel, Stacy was not an
          23    obvious target.  They were working on Bob Minton.
          24         Q    Okay.
          25         A    Stacy was incidental at that point.
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           1         Q    All right.
           2         A    It wasn't contemplated for her to change her
           3    testimony.  It was Minton to do it.
           4
           5         Q    Did you ever have a conversation with Bob Minton,
           6    for instance, let's go to that night, the Adam's Mark Hotel,
           7    where he's talking about the $500,000 UBS check and what he
           8    told you in the parking lot about it?
           9         A    Oh, I brought that up to him.  You know, they were
          10    saying, you know, "Ken is really going to get it.  He told
          11    me to lie about this check."
          12              I said, "Wait a minute, Bob, let me remind you --"
          13    he and Stacy are like gleeful children, like all
          14    responsibility is gone.  "Hee-hee.  Guess what?"
          15              "Are you insane?  We were both on the parking lot.
          16    Bob got you and me out of the office, said he was giving
          17    this check to Ken, Ken didn't know where it was coming from,
          18    told us it was from people from Europe.  I mean, why are you
          19    gleefully now telling me somehow this is Ken's fault?"
          20         Q    What did they say?
          21         A    They just looked at me like, "Oh, yeah, we forgot
          22    about that part."  Mmm, they were telling me things like,
          23    "We really got him now."
          24              I said, "But don't you remember what we did?
          25    Don't you remember this is what really happened as opposed
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           1    to this story you are making up now?  Do you remember what
           2    actually happened?"
           3         Q    What was their response?
           4         A    "Hmmm."  You know, just "Hmmm."  Like, "He's not
           5    cooperating."
           6         Q    So --
           7         A    So I told him, you know, "Now, you know we were up
           8    in the parking lot.  We went through this whole thing.  So
           9    now what do you want me to say what happened now, when this
          10    is what did happen?  What am I supposed to do?"
          11              THE COURT:  What did he say?
          12              THE WITNESS:  He just looked at me like I was
          13         crazy.  And they looked at each other and they
          14         changed the subject.  We started talking about --
          15         Mmm -- what else did we start talking about?
          16              They brought up something else that -- the
          17         meeting, yeah, oh, and the other thing they want --
          18         "they" being Rinder and Rosen, the other thing they
          19         want brought out is how Minton was supposedly at
          20         some meeting that happened where we all said, "Yeah,
          21         add Miscavige and don't talk to anybody about it."
          22              I am like, "Are you crazy?  That didn't happen
          23         either."
          24    BY MR. DANDAR:
          25         Q    So when you told them it didn't happen --
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           1         A    Then they said, "Look, let's stop talking about
           2    this.  Let's go to dinner.  We've made some progress."
           3              But, on the other hand, I'm thinking, "I have to
           4    talk to somebody from Scientology about this," because
           5    obviously I'm looking at Bob and Stacy, they are just
           6    convinced that I'm just going to to-to-to, go along with
           7    this.  They are just convinced.
           8              They are telling me -- Stacy said, "Look, we're
           9    going to do this, it is unpleasant, but we'll put all this
          10    behind us.  You won't have worry -- money problems anymore,
          11    you'll have plenty of money, you'll be taken care of, you
          12    know, and --"
          13              THE COURT:  Who was going to give you the
          14         money?
          15              THE WITNESS:  The same -- your Honor, the same
          16         person that has been, Bob Minton.  They have been
          17         taking care of everything.
          18                 (Discussion had off the record.)
          19    BY MR. DANDAR:
          20         Q    So this was -- then you went out to dinner?
          21         A    Yes.  We went out to dinner and we just kind of
          22    changed the subject because it was getting heated.  You
          23    know, I'm trying to find a scintilla of logic of what is
          24    going on here.  And I can't -- I can't even imagine -- I
          25    can't even make myself imagine what they are talking about
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           1    here.
           2              Then I told Bob, I said, "Bob, isn't this
           3    strange --"
           4              (Discussion had off the record.)
           5    BY MR. DANDAR:
           6         Q    So Bob Minton said --
           7         A    I keep losing my train of thought.
           8         Q    I know.  Sorry.  Maybe we should read it back.
           9             (A discussion was held off the record.)
          10             (Last answer read back by the reporter.)
          11              THE WITNESS:  Repeat the last line again.
          12              (Last answer reread by the reporter.)
          13         A    I got it.  Because I started talking to them, I
          14    said, "Well, look, we had further discussions about
          15    Wollersheim, too."
          16              And I said, "Well, you have loaned Lawrence money
          17    to continue his case.  Now you're going after him.  You have
          18    given all of this money against Ken Dandar.  Now you are
          19    going after him.  Don't you think it is obvious what has
          20    happened here?  Don't you think it is going to be obvious to
          21    all concerned that something bad happened here?"
          22              His response was, you know, "I'm not convinced.
          23    Stacy is convinced this is going to work, Jesse.  I'm not
          24    convinced about it.  And I feel bad what is going on with
          25    Ken."
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           1              My thing was, okay, I have to talk to somebody
           2    about Scientology about this because obviously these two
           3    things -- I have a ring in my nose and they have a leash.  I
           4    have to let Scientology know they're not going to get away
           5    with this, this is not going to work.
           6              THE COURT:  Who was it -- you are saying you
           7         had the ring through your nose and they had a leash?
           8              THE WITNESS:  Yes, this is an analogy of what
           9         seemingly was in their minds.
          10              THE COURT:  "Their" meaning Bob Minton and
          11         Stacy Brooks?
          12              THE WITNESS:  Yes.
          13              THE COURT:  Thought they had the leash and were
          14         leading you around.
          15              THE WITNESS:  Correct.
          16              THE COURT:  You thought you had to tell
          17         Scientology that wasn't accurate?
          18              THE WITNESS:  Yes.
          19              THE COURT:  Okay.
          20         A    So I'm going along now with this whole thing.  I
          21    said, "Look," I told them, "Okay, I'll do it.  Okay, I'll do
          22    it.  Tell me --" because they said, "We have to bring you
          23    in.  You have to meet with Mike Rinder now.  You have to
          24    meet him face-to-face and go over this and you are going to
          25    be happy like us."
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           1              "Okay.  Okay."
           2              I tell you, I left that Adam's Mark Hotel and I
           3    felt like, "Oh, my God."  You know, I would rather be doing
           4    anything.  But ultimately I came home and I told my fiance,
           5    I said, "Look, it is over.  I can't do it anymore.  I have
           6    to let Ken know.  I have to call somebody."
           7              So I called Frank Oliver and told him the whole
           8    story of what had been going on the whole time and told him
           9    to please tell Ken, and I'm so sorry what happened to him.
          10              I sat in Judge Baird's courtroom and it upset me
          11    greatly, and asked him to arrange for you and I to meet, at
          12    which point you called me and we met the Sunday.
          13              And I was supposed to meet with Bob and Stacy and
          14    Mike Rinder that time.  And I told them, "Yes, I'm going to
          15    go along with your plan."
          16              And as I state here in my affidavit and I said to
          17    you to your face, I just want to see Mike Rinder's face when
          18    he finds out that this isn't going to work if he thinks he's
          19    going to use me to do this thing.
          20              So we have that meeting --
          21    BY MR. DANDAR:
          22         Q    You and I had a meeting?
          23         A    You and I had the meeting.  And Mr. Lirot was
          24    there.
          25         Q    Right.  Right.  And then you went to meet with Bob
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           1    and Stacy and, you thought, Mike Rinder?
           2         A    I thought Mike Rinder would be there.  So what
           3    happens, now they moved hotels, they moved to the Radisson
           4    on Clearwater Beach.  I guess they didn't like the Adam's
           5    Mark.  So we are at the Radisson.
           6              And he has this big sheaf of papers.  And he said,
           7    "Jesse, you are unreal.  Let me show you what Judge
           8    Schaeffer is saying about you."  And he read something that,
           9    to me, was totally uncomprehensible.
          10              And he said, "See, she doesn't trust you.  You are
          11    not credible in her eyes.  You are going to jail if you
          12    don't do what we tell you to do."
          13              I said, "Bob, I think you're the one going to
          14    jail.  You're the one lying.  You're the one that has
          15    already went in court and lied.  And you want me to do it?
          16    I think you're the one going to jail."
          17              Oh, my God, it gets hot.  "Okay, let's go down to
          18    dinner."
          19              Then I sit and I explained to them, I said, "Look,
          20    let me tell you specific experiences I have personally had
          21    making deals with Scientology.  Let me tell you the
          22    results."
          23              I told them painstakingly some awful things if I
          24    even started to mention, I am sure Mr. Weinberg would be up
          25    in a flash.
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           1              MR. WEINBERG:  No, your Honor, I would like to
           2         hear exactly what he said he told Mr. Minton about
           3         all these awful experiences.
           4    BY MR. DANDAR:
           5         Q    Okay.  Go ahead.
           6         A    I told him about the time I was removed from that
           7    position you saw me on the video with the sailor clothes, on
           8    and on.  I told them about the circumstances about me being
           9    removed from there.
          10              THE COURT:  I'm not sure I saw that.
          11              THE WITNESS:  Your Honor, it was the first day
          12         I was here, Miscavige introduces me, I'm telling him
          13         I'm from RTC and we are going to get the squirrels
          14         and what do the squirrels mean.
          15              THE COURT:  I remember.
          16              MR. DANDAR:  This is the New Year's Eve speech.
          17              THE COURT:  Right.  I remember now.
          18         A    Well, how I got removed from that position.  I'm
          19    telling him the story where Miscavige wants to come in and
          20    get rid of Broeker because he thinks Broeker is crazy.
          21    BY MR. DANDAR:
          22         Q    So you were caught in between Broeker and
          23    Miscavige?
          24         A    Yes.  And I told them, either one, "I don't want
          25    anything to do with either one of you," because when I got
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           1    involved myself in doing illegal activities, with listening
           2    to wiretapping and, you know, all of this crazy stuff I'm
           3    being shown how to do, I'm cutting my teeth, I am being
           4    broken into OSA, this is no Scientology that I ever knew
           5    anything about.
           6              You know, I don't want nothing to do with this
           7    part of it.  I didn't even know it happened where they do
           8    this stuff to people.
           9              Mmm, and then, you know, they -- because I didn't
          10    go along with that, I'm woken up at 5 o'clock in the
          11    morning, there is -- there is Miscavige standing there,
          12    there is Lymon Sperlock, Ray Mithoff, Mike Sutter, Greg
          13    Wilheir (phonetic), his brother, security guards.  There are
          14    about 12 people there.
          15              I walk into Miscavige's office, and there is Vicki
          16    Aznaran, the person that used to be inspector general of
          17    RTC, just crying in the corner, crumpled.  They are all in
          18    their Sea Org uniforms just like, grrr.  And I'm running
          19    around with something that looks like pajamas.
          20              And he told me, "You didn't go along with this,
          21    you wouldn't follow me, now you are going to the RPF.  You
          22    call me sir.  You have been disrespectful."
          23              I stood up and told him to go to hell and went and
          24    tried to leave, at which point they tried to grab me.  And
          25    me and Judge Moody has been through this story before so I'm
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           1    not telling a new story.
           2              And I ran to my bedroom and I got a Mini 14
           3    assault rifle I had been given for my birthday from L. Ron,
           4    and a .45, loaded in both, went back to that office, and I
           5    have them like this (indicating).  And now they are standing
           6    there like -- oh, Norman Starkey was there.  And Norman
           7    says, "Jesse, you traitor.  You can't kill us all."
           8              And I said, "Well, I'll tell you what, maybe not,
           9    but you will certainly be the first to go."
          10              And I'm standing there with these guns.  Then
          11    Miscavige, because he and I used to be very good friends,
          12    too, he and I were very good friends at one point in time,
          13    he came over and he said, "Jesse, look, this is horrible,
          14    let's stop this."
          15              He knew I wasn't going to do anything.  He walked
          16    right up to me.  He told all those other jerks, "Get out of
          17    here, I have got to talk to Jesse."
          18              So we go down to the ship and we have a
          19    conversation.  And he tells me, "Jesse, I know this all
          20    seems horrible now, but I need you to take this fall.  I
          21    need you to be a head on a pike."  Head on a pike is a term
          22    in Scientology where somebody takes a fall for Scientology.
          23    Put a head on the pike means if you are going through the
          24    gate, you end up like this, head on the pike.
          25              "I want you to be the head on the pike."  He
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           1    wanted me to go to RPF.  You know, Vicky and Rick really
           2    screwed things up with the Broekers and conspired about him,
           3    yik-yik and on and on.  And he said, "Look, this will be
           4    over, you'll be restored to your position," on and on.
           5              "Oh, okay, Dave, I do it."  We talked.  I
           6    willingly once again go to the damn concentration camp.
           7    Once again.  Like eighteen months wasn't long enough.  Now
           8    I'm in there again.
           9              What immediately happens?  Miscavige starts
          10    issuing this horrible stuff about me, "He's terrible, he's a
          11    piece of crap."
          12              I stood up and walked out of that place, went to
          13    that base and said, "Look, if this is the way you want to
          14    play this, I'm going to the police, I'm going to go talk to
          15    them about what you do here."
          16              Oh, my God, all them issues are canceled.  No,
          17    Jesse is good again.  "Jesse, I'm sorry."  It is always
          18    someone's fault, someone else acted in an unauthorized
          19    manner and put these things out.
          20              Okay, he got rid of all of that stuff.  I mean, I
          21    had to have something to show for being in Scientology 16
          22    years.  Every certificate I had -- I had a wall from top to
          23    bottom, at least half of that, of everything I have ever
          24    done in Scientology used to be in my office.
          25              And, Mmm, so I ended up going back to the RPF.
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           1    Oh, no, we straighten it all out again.  That was one
           2    instance.
           3              Just lying.  Just can't wait to get me in a
           4    position to where I am incapacitated to do something.
           5              The second time I'm trying to leave Scientology,
           6    "Look, you guys can do this.  Do whatever you want to do,
           7    you know.  You want to do this activity?  I don't want to do
           8    it anymore.  I just want to take me and my wife and leave,
           9    just be away."
          10              Well, of course that didn't happen.  I had to be
          11    degraded for four and a half months, locked up, sec-checked,
          12    told to divorce my wife.  I have written about this, too.
          13    Finally, I leave.
          14              THE COURT:  What did you say, seg-checked?
          15              THE WITNESS:  Sec, security checked.  Being
          16         interrogated on the E-meter.
          17         A    Well, what happens, as soon as I leave, they have
          18    someone that is a tail on me that works for this Scientology
          19    business who, because I won't continue to do Scientology and
          20    their business, now I'm no good.  You know, I have come in
          21    there and boomed that business.  I was hired, I was on
          22    salary making $60,000 or $70,000 a year.
          23    BY MR. DANDAR:
          24         Q    Are you talking about the artwork business?
          25         A    Yes, the artwork business.  But people from RTC
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           1    would call me once or twice a week.  Mike Sutter, RTC,
           2    "Jesse, how are you doing?"
           3              So now they want me to do Scientology work where
           4    they want me to do cramming, do correction, yik-yik, on and
           5    on.
           6              I said, "Look, I have left that.  I'm not doing
           7    that anymore.  Let me just do a regular job.  I'm just doing
           8    a regular job now, not using the Scientology mess, and
           9    everything is going fine.  You know, don't fix something
          10    when it is not broke."
          11              No, that is not good enough, that gets reported to
          12    RTC.  Now I have to get removed and now I have to go through
          13    endless crap.
          14              It finally culminated losing my job, having to
          15    start my own business, being followed around every place in
          16    Minneapolis, because I travel a lot.  Then one day I found a
          17    bag right outside my hotel room, like this (indicating),
          18    Rock cocaine.
          19              THE COURT:  How big?
          20              THE WITNESS:  Huh?
          21              THE COURT:  You are showing it.
          22    BY MR. DANDAR:
          23         Q    Tell --
          24         A    Like this (indicating).
          25              THE COURT:  Say for the record, is that the
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           1         size of a baseball?
           2              THE WITNESS:  About the size of a softball.
           3              THE COURT:  About the size of a softball?
           4              THE WITNESS:  With individually little crack
           5         cocaines.
           6         A    And I'm like, uh-uh, this is it.
           7              So, to me, I'd already been through enough
           8         betrayal with Scientology.  And I explained this to
           9         them.
          10              THE COURT:  This is just -- all that cocaine
          11         just sitting outside your hotel room?
          12              THE WITNESS:  Yes.  Yes.  And the fact of the
          13         matter is, your Honor, it is known that I had, you
          14         know, smoked marijuana before or whatever, but if
          15         anyone in my family -- because my brother tried
          16         it -- does cocaine, he did it, had a double
          17         aneurysm.  I sat in the hospital a month while they
          18         cut off his dreadlocks, peeled his skin back, cut
          19         his scalp, went through his brain, cauterized two
          20         microscopic veins because his head exploded from
          21         fooling around with crap, and put it all back
          22         together.
          23              And the reason they said it happened to him,
          24         something genetically in our family that makes those
          25         veins do that.  What do I want to do with cocaine
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           1         for?  It is just --
           2              THE COURT:  I think we're far afield.
           3              MR. WEINBERG:  Is this what -- all these
           4         incidents you told Mr. Minton?
           5              THE WITNESS:  Yes, I'm telling all this to
           6         Mr. Minton.  I said, "In the end you may think --"
           7         and I told him, "As you sit here you can't tell me
           8         when Scientology is going to be done with you.  When
           9         are they going to be finished having you done
          10         whatever they want you to do?  All you know, you
          11         have Wollersheim and you have McPherson."
          12              He said, "Jesse, you are being unreal."  He got
          13         mad.  He cursed at me and said something.  And his
          14         last words were, "Well, fuck it, you're going to
          15         jail."
          16    BY MR. DANDAR:
          17         Q    Did you use the same language back at him?
          18         A    I said, "Bob, I'm sorry, you're going to jail.
          19    Stacy, you're going to jail.  I'm not having anything to do
          20    with this."
          21              I got up -- he asked me to leave.  He said, "Get
          22    out."
          23              I said, "Fine."
          24              Stacy follows me in the parking lot.  She said,
          25    "You know, after all of the things Bob has done for you,
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           1    this is how you treat him?"
           2              I'm looking, "What in the hell has Bob done for me
           3    that I have to perjure myself, I have to become a criminal
           4    because he thinks this is what I got to do to save him?
           5    Uh-uh.  He's not done anything for me.  And there is only
           6    one person can sell my soul.  That is me.  I already sold my
           7    soul to this organization one time and I got it back.  Bob
           8    Minton is in no position to offer my soul to them."
           9              And I told her that.  And we really haven't talked
          10    that much since.
          11         Q    Well, now, was there a point in time when Bob
          12    Minton was coming over to your house after that for
          13    barbecue?
          14         A    Well, again, we have been friends a long time.
          15    This was another bridge of disagreement, blowup, everybody
          16    cursing, but we have such history.  Even as I sit here
          17    today, I can't fathom not talking to him once or twice a
          18    week.
          19              So, you know, we're talking again.  "Look --"
          20    Stacy said, "Look, this is going to blow over with or
          21    without you.  We're going to make sure."
          22              So I said, "Okay, well, then if we're not doing
          23    this, could we still be friends?"
          24              They love to come over to the house.  We barbecue
          25    and have little parties.  "Sure."
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           1              But then he called his lawyer and he was told not
           2    to come.
           3         Q    This is while the hearing is going on in this
           4    courtroom?
           5         A    Yes.  They want to tell me what is going on.  They
           6    want me to be a part of it because I have been since the
           7    beginning.  But I can't because of what they're doing.
           8         Q    Did Bob Minton want to close down the LMT?
           9         A    No.
          10         Q    Whose idea was that?
          11         A    I don't think it was any one person's idea.  Well,
          12    if it was anybody's idea, I think it was Stacy's, because
          13    the LMT was being used as a vehicle to get to Bob.  And --
          14              THE COURT:  I think it sounds -- this must be
          15         allowed to start at 4:30, but it is giving me a
          16         headache.  Is this a good stopping point?
          17              MR. WEINBERG:  Yes -- I'm sorry.
          18              MR. DANDAR:  This would be -- this would be
          19         fine.
          20              THE COURT:  They probably are allowed to start
          21         up at 4:30.
          22              MR. WEINBERG:  I thought I was having a ringing
          23         in my ears, which I do have an ear issue.
          24              THE COURT:  So we'll go ahead and quit.  We'll
          25         start up at 9 o'clock.  Mr. Prince --
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           1              MR. WEINBERG:  Remember you said ten?
           2              THE COURT:  Oh, I did.  Ten o'clock tomorrow.
           3         Ten o'clock tomorrow.  I think I told you this
           4         before, but if I didn't, let me remind you:  While
           5         you are on the witness stand, I did give you
           6         permission to speak with Mr. Dandar because of the
           7         long break, but now, like overnight, you and he
           8         can't talk.
           9              THE WITNESS:  Okay.
          10              THE COURT:  Okay?  I mean, you can talk about
          11         something else, but you can't talk anything about
          12         your testimony or about this case.  Of course you
          13         can't talk to the other side, you can't talk to
          14         anybody while you are on the stand about this case
          15         or your testimony.  Okay?
          16              THE WITNESS:  Yes, your Honor, I understand
          17         that.
          18              THE COURT:  We shall be in recess.
          19              MR. FUGATE:  Judge, I have one issue on the
          20         E-Mails.  And I'll be really quick.
          21              THE COURT:  Okay.
          22              MR. FUGATE:  There are, to my understanding,
          23         about 3,000 E-Mails.  And during the break --
          24              THE COURT:  Have you-all come up with any
          25         agreement as to a list?
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           1              MR. FUGATE:  That is what I want to talk to you
           2         about.  I went over to see, there is a list that
           3         prints out all of the ones that they were able to
           4         recover from the various hard drives.  And I have
           5         found a series of -- on that list of E-Mails that
           6         related to Peter Alexander and Patricia Greenway,
           7         and I have left a list of those with Mr. Keane.
           8              And then I understand that Mr. Dandar indicated
           9         that those shouldn't be produced because
          10         Ms. Greenway is a consultant.  And, you know, in
          11         this hearing he said she wasn't.
          12              I don't really care what she is today.  But
          13         back during the time that she was at LMT prior to
          14         this hearing beginning, which is where all these
          15         E-Mails generate from, I don't think they would be
          16         covered as a consultant --
          17              THE COURT:  Counsel, I can't deal with
          18         something that won't be agreed to with this noise.
          19         That is why I stopped this hearing.  We'll take this
          20         up first thing in the morning, and hopefully we
          21         won't have any noise and we'll get it done then.
          22         Ten o'clock tomorrow.  Bring it to my attention
          23         then.
          24              MR. FUGATE:  All right.
          25              THE COURT:  All right.  Thank you all.
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           1           (WHEREUPON, Court is adjourned at 4:50 p.m.)
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           1                      REPORTER'S CERTIFICATE
           2
           3    STATE OF FLORIDA         )
           4    COUNTY OF PINELLAS       )
           5              I, LYNNE J. IDE, Registered Merit Reporter,
                certify that I was authorized to and did stenographically
           6    report the proceedings herein, and that the transcript is
                a true and complete record of my stenographic notes.
           7
                          I further certify that I am not a relative,
           8    employee, attorney or counsel of any of the parties, nor
                am I a relative or employee of any of the parties'
           9    attorney or counsel connected with the action, nor am I
                financially interested in the action.
          10
          11              DATED this 9th day of July, 2002.
          12
          13
          14                              ______________________________
                                              LYNNE J. IDE, RMR
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