721
           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 6
           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 10, 2002.  Morning 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
          24
          25
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           1    APPEARANCES:
           2
                MR. KENNAN G. DANDAR
           3    DANDAR & DANDAR
                5340 West Kennedy Blvd., Suite 201
           4    Tampa, FL 33602
                Attorney for Plaintiff.
           5
           6    MR. KENDRICK MOXON
                MOXON & KOBRIN
           7    1100 Cleveland Street, Suite 900
                Clearwater, FL 33755
           8    Attorney for Church of Scientology Flag Service
                Organization.
           9
          10    MR. LEE FUGATE
                MR. MORRIS WEINBERG, JR.
          11    ZUCKERMAN, SPAEDER
                101 E. Kennedy Blvd, Suite 1200
          12    Tampa, FL 33602-5147
                Attorney for Church of Scientology Flag Service
          13    Organization.
          14
                MR. ERIC M. LIEBERMAN
          15    RABINOWITZ, BOUDIN, STANDARD
                740 Broadway at Astor Place
          16    New York, NY 10003-9518
                Attorney for Church of Scientology Flag Service
          17    Organization.
          18
                MR. HOWARD ROSS
          19    Battaglia, Ross, Dicus & Wein, P.A.
                980 Tyrone Boulevard
          20    St. Petersburg, Florida  33710
                Counsel for Robert Minton.
          21
          22
          23
          24
          25
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           1              THE COURT:  Good morning.  Mr. Prince.  All
           2         right.  Mr. Dandar, you are standing.  You must want
           3         something.
           4              MR. DANDAR:  Well, we have a proposed order
           5         here.  I have some responses here.  I have
           6         declarations of Stacy Brooks and others I want to
           7         file.  But let's just go with Mr. Prince.
           8              THE COURT:  Okay.
           9             (A discussion was held off the record.)
          10              THE COURT:  What day is today?  The 10th?  I
          11         was looking, what is -- how many days of hearings is
          12         this?
          13              THE BAILIFF:  30.
          14              THE COURT:  No, no.  Mr. Bailiff says 30.  Does
          15         anybody --
          16              MR. WEINBERG:  Add zero to that.  That is where
          17         we are.
          18              THE COURT:  Is that where we are, 30?
          19              MR. WEINBERG:  I think so.
          20              THE COURT:  Good morning, Mr. Ross.  Are you
          21         designated Mr. Minton's attorney here today?
          22              MR. ROSS:  That is correct.
          23              THE COURT:  I think that probably you have been
          24         advised Mr. Minton needs a lawyer in this proceeding
          25         and, therefore, we welcome you.  But you have no
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           1         ability to object in this particular proceeding.
           2              MR. ROSS:  I understand, your Honor.
           3              THE COURT:  You understand you may hear some
           4         very weird testimony as far as some strange
           5         evidentiary rulings.  But this is a strange hearing
           6         and sort of the rules of evidence -- we're going to
           7         deal with that after the hearing.
           8              MR. ROSS:  I understand.
           9              THE COURT:  Okay.
          10              MR. WEINBERG:  Just give me a minute, your
          11         Honor.
          12              THE COURT:  I will.  I will ask Mr. Dandar,
          13         while you are doing that, did you have a chance to
          14         E-Mail Mr. Henson?
          15              MR. DANDAR:  Yes, I did.  And he E-mailed me
          16         back and said, "Can you find me a lawyer, is it
          17         worth it?"  I said no, both questions.
          18              THE COURT:  Okay.
          19              MR. FUGATE:  Your Honor, I notified Mr. Hill's
          20         secretary that Mr. Rosen would not be called.  And I
          21         should have an order here on the pro hac vice, if it
          22         is not by the morning break, by noontime.
          23              THE COURT:  All right.  Fine.
          24              MR. LIEBERMAN:  I would just like to inquire,
          25         does that mean Mr. Henson is abandoning his motion?
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           1              THE COURT:  No, I think what that means, he
           2         will not be represented.  And I suspect you
           3         should -- as I said, let me have time to read it.  I
           4         may be able to rule on your motion without any
           5         argument.
           6              MR. LIEBERMAN:  Very good.
           7              THE COURT:  But, frankly, I want to still leave
           8         it scheduled for hearing, because he may get
           9         somebody to appear.  And we'll deal with it at the
          10         scheduled time.  I would not assume that is an
          11         abandonment.
          12              MR. LIEBERMAN:  All right.
          13              MR. DANDAR:  Right.
          14              THE COURT:  Okay.
          15              MR. WEINBERG:  All right?  I'm ready.
          16              THE COURT:  You may proceed.
          17    BY MR. WEINBERG:
          18         Q    Mr. Prince, you -- I think you said on your direct
          19    testimony -- but let me go over it again -- you have
          20    testified previously as a witness under oath in either trial
          21    testimony or deposition testimony.  Is that right?
          22         A    In this -- in this case, yes, I have.
          23         Q    In other cases, as well.  Correct?
          24         A    Yes, I have.
          25         Q    And -- and is it your testimony that at all times
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           1    in those other cases when you were under oath, that you
           2    testified truthfully?
           3         A    Yes, it is.
           4         Q    Okay.  Now, yesterday -- or the day before,
           5    whenever it was -- you testified that you had participated
           6    in the destruction of PC folders, particularly
           7    Mr. Wollersheim's PC folder which he said was pulped, I
           8    believe, while you were at RTC?
           9         A    Correct.
          10         Q    Now, you remember testifying as a witness in 1989
          11    in the lawsuit Religious Technology versus Joseph Yanny?
          12         A    I do not.
          13         Q    You don't remember that?
          14         A    No, I do not.
          15              THE COURT:  I don't even remember hearing about
          16         that case.  That is a new one for me.
          17    BY MR. WEINBERG:
          18         Q    I thought you testified, by the way, on your
          19    direct, that you had been a witness in that case, in fact,
          20    that while you were in Scientology, you were actually a
          21    witness in that case.
          22         A    No.  While I was in Scientology I said I was a
          23    witness in the Wollersheim 4 case, specifically concerning
          24    the Advancability Center, David Mayo.
          25              MR. WEINBERG:  Could I approach the witness,
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           1         your Honor?
           2              THE COURT:  You may.
           3    BY MR. WEINBERG:
           4         Q    Let me show you a transcript of your deposition
           5    taken in Los Angeles, California on September 11, 1989 and
           6    ask you if you can identify that transcript and identify
           7    that as your testimony on that day under oath, and at the
           8    end you'll see an errata sheet which I believe also has your
           9    signature on it.
          10         A    What is this on?  On September '89?  Okay.
          11    Then --
          12         Q    At the end is an errata sheet.  Do you see that?
          13         A    Uh-huh.
          14         Q    And you see that you -- do you recognize your
          15    signature on there dated --
          16         A    12 December, '89.  Yes, I do.
          17         Q    Obviously -- I'll leave this here because I have a
          18    few questions on it.  Obviously you testified as a witness
          19    in 1989 and were given the opportunity to review that
          20    testimony and make corrections.  Correct?
          21         A    I don't -- Mmm -- recall that, Mr. Weinberg, but
          22    since I did sign the errata sheet, I'll say okay.
          23              MR. DANDAR:  I would like to have a copy of
          24         that, Judge.  If they're going to start using it,
          25         pulling things out of context, I would like to be
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           1         able to review it.
           2              MR. WEINBERG:  Well, it's amazing I'm being
           3         accused of pulling something out of context.
           4              MR. DANDAR:  We all do, we pull something out
           5         and say, "Did you say this?"
           6              THE COURT:  If you are going to use a
           7         deposition and he doesn't have a copy of it, he
           8         ought to have a copy of it.
           9              MR. WEINBERG:  Do we have an extra copy of it?
          10         Do we have copies of these?
          11              THE COURT:  I tell you what, go ahead and use
          12         it and then get him a copy before Mr. Dandar --
          13         Mr. Dandar, please listen if you care, maybe you
          14         don't care.  If you care, I'll have them provide you
          15         a copy of the deposition before your redirect.
          16              MR. DANDAR:  Thank you.
          17              THE COURT:  If anything was pulled out of
          18         context, you can correct it.
          19              MR. DANDAR:  Okay.  Thank you.
          20              MR. WEINBERG:  Now, in addition --
          21              THE COURT:  You-all provide him a copy.
          22              MR. WEINBERG:  Yes.
          23    BY MR. WEINBERG:
          24         Q    Now, in addition to your testimony in this
          25    proceeding that you had participated in the destruction of
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           1    PC folders, you also, in your August 20, 1999 affidavit,
           2    that is the -- the affidavit where you made the accusation
           3    about David Miscavige, in that affidavit, in Paragraph 22
           4    you swore that you had participated in the destruction of
           5    Wollersheim's PC folder.  Correct?
           6         A    Correct.
           7         Q    Now, if you will turn, Mr. Prince -- when I get
           8    the right folder here -- to Page 153 of your Yanny
           9    deposition.  You find Page 153?
          10         A    Mmm, just about.  I have it here.
          11         Q    I want you to read Line 5, 6 and 7.
          12              "Question:  Were you ever involved in the
          13    destruction of PC folders?
          14              "Answer.  No."
          15              Okay.  That was your sworn testimony then,
          16    correct?
          17         A    Yes, it was.
          18         Q    And when you go to that errata sheet, does it say
          19    anything about you making any mistakes with regard to that
          20    sworn answer where you swore under oath in 1989 that you had
          21    not been involved in the destruction of PC folders?
          22         A    Mr. -- you know, I don't recall this errata sheet,
          23    to answer the question that quickly.  I don't even recall
          24    the errata sheet.
          25              THE COURT:  The real question is that was your
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           1         testimony on that date, is that right?
           2              THE WITNESS:  Yes, this was the testimony I had
           3         given on that date.
           4    BY MR. WEINBERG:
           5         Q    And you previously testified that all your prior
           6    sworn testimony was true.  Correct?
           7         A    Correct.
           8         Q    So you lied here in court when you said that you
           9    had participated in PC folders being destroyed?
          10         A    Well, you know, I have to at least look at a
          11    couple pages earlier here to kind of get an idea what was
          12    going on here to orient myself to 1989.
          13         Q    Look at a couple pages earlier.
          14              THE COURT:  Might I just ask, where he was
          15         reading, was he testifying for plaintiff, or
          16         defendant?
          17              MR. WEINBERG:  He was testifying for the
          18         Church.  For RTC.
          19         A    Okay.
          20    BY MR. WEINBERG:
          21         Q    That was certainly -- you wouldn't have had a
          22    recollection problem back in 1989, would you, as to what had
          23    occurred a year or so or two or three before that, as
          24    opposed to 2002, talking about things that supposedly
          25    happened?
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           1         A    Mmm, Mr. Weinberg, I -- I don't think I would have
           2    had a recollection problem, but maybe I would have had a
           3    problem with coercion.
           4         Q    Let's see now --
           5         A    Or -- or manipulation.
           6         Q    Excuse me.  I'm sorry.  I didn't mean to
           7    interrupt.
           8         A    Or manipulation.  This was a very bad time for me.
           9    This was shortly -- well, let's see, this was a couple years
          10    after I had been away from any position of authority.  I was
          11    still being asked to -- Mmm -- participate in the courts,
          12    for whatever reason, God only knows.  And I was not in a
          13    very good state of mind.
          14         Q    Well, I thought you said you were relieved
          15    yesterday to leave your post at RTC and that you were in a
          16    better state of mind as a result of being relieved and not
          17    having to do all those things that you swore yesterday and
          18    the day before that you had participated in.
          19         A    Certainly in that regard, Mr. Weinberg, I was
          20    relieved.  But I didn't have a lot of direction for my life.
          21    I think I was pretty suicidal at that point.  And I had
          22    written about that, as well.
          23         Q    All right.  So you started saying these things
          24    about destroying PC folders after people started paying you,
          25    like Mr. Minton and Mr. Leipold and through Mr. Dandar, that
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           1    is when you started saying these things, not when you
           2    weren't being paid.
           3         A    No, Mr. Weinberg, quite the contrary.  I -- this
           4    came out because I decided that it was no longer an
           5    operating principle of mine that the greatest good is for
           6    Scientology.  I kind of -- you know, just kind of got away
           7    from that.
           8         Q    So it's a principle now the greatest good for
           9    Jesse Prince, whoever will put the money in your pocket,
          10    that is what you'll say?
          11         A    No, Mr. Weinberg, the greatest good is the truth
          12    and justice and equity.
          13         Q    All right.  So what you're saying, just so I get
          14    this right, you lied back in 1989?
          15         A    Yes -- yes.  According to these documents, I lied
          16    on behalf of Scientology.
          17         Q    All right.  And you lied in -- I'll just refresh
          18    your recollection about being asked about this before -- do
          19    you remember giving a deposition in this case when -- when I
          20    deposed you?
          21         A    I think you and I have been at it a time or two.
          22         Q    And do you remember that I asked you the questions
          23    on Page -- I'll refer now to Page 465 of your deposition
          24    of -- of November 17, November 18, 1999.
          25              "Question:  Now, when you testified -- how many
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           1    times have you testified in your entire career, life?
           2              "Answer:  In a courtroom or deposition setting?
           3              "Question:  Both.
           4              "Answer:  Possibly five.
           5              "Question:  All right, and each time you
           6    testified, whether in deposition or in court, you were under
           7    oath, right?
           8              "Answer:  Correct.
           9              "You raised your hand and swore to tell the truth.
          10              "Answer:  Correct.
          11              "Question:  Nothing but the truth, right?
          12              "Answer:  Correct.
          13              "And you testified truthfully on those five
          14    occasions.
          15              "Answer:  Correct.
          16              "Question:  You didn't perjure yourself.
          17              "Answer:  Correct.
          18              "Question:  So if you were asked the questions in
          19    a deposition that I asked and those were your answers then
          20    when you gave those answers, it is your testimony that they
          21    were truthful answers, correct?
          22              "Answer:  Well, you know, yeah, okay.  I'll say
          23    yeah, okay, yeah."
          24              Then later in the deposition -- do you remember
          25    being asked those questions and giving those answers?
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           1         A    No, I do not, Mr. Weinberg.
           2         Q    Do you remember being asked on Page 469 of your
           3    deposition two years ago, "You testified in the Yanny case
           4    we've already talked about, was that deposition and trial or
           5    just deposition?
           6              "Answer:  I believe it was just deposition.  And
           7    again, I was never afforded the opportunity -- well, no, I'm
           8    sorry, I'll answer the direct question, I won't tell
           9    stories.  Yes."
          10              Do you remember being asked that question and
          11    giving that answer?
          12         A    No, Mr. Weinberg.  But if it's there, then I
          13    believe it.
          14         Q    So apparently three years ago when we took your
          15    deposition you remembered the Yanny case testimony but today
          16    you don't?
          17         A    I -- Mr. Weinberg, I think that is a bit of
          18    mischaracterization to say I would have remembered the Yanny
          19    testimony.  You know, this document here is a couple hundred
          20    pages long.  I -- I don't think any of us are capable of
          21    remembering a couple hundred pages of something that
          22    happened ten years ago.
          23         Q    Is there a particular reason why, in all these
          24    accusations you made against Scientology, you didn't say,
          25    "And they told me to perjure myself in 1989 in the Yanny
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           1    deposition"?  Why didn't you do that?
           2         A    Well, the fact of the matter is, Mr. Weinberg,
           3    again, like I -- I was damaged goods during that time.  I
           4    had gone through a lot of stress, a lot of -- Mmm --
           5    decisions to change my life.  Mmm, didn't have certain --
           6    you know, a certainty on where I was going with my life.  I
           7    felt pretty hopeless.
           8              But let's talk about the perjury here since this
           9    is the subject here.  What I have testified to before
          10    concerning preclear folder destruction is the fact that
          11    because these preclear folders of Mr. Wollersheim were being
          12    asked to be produced and ultimately the whole folders were
          13    turned over, the order to destroy the folders came from
          14    Mr. Miscavige with Mr. Rathbun present, myself, Vicki
          15    Aznaran.  It became my responsibility to report when that
          16    fact was done.
          17              I myself was not the person that destroyed the
          18    preclear folders or had -- or pulped them.  Rick Aznaran is
          19    the person, along with another current Office of Special
          20    Affairs, Charlie Earl, rented a truck, took these folders;
          21    Vicki Aznaran -- Lawrence Wollersheim, possibly Bill Franks,
          22    Gerry Armstrong and others took them to the recycling plant,
          23    and when Mr. Aznaran came back, he showed me a liquid bottle
          24    with paper on -- with the pulp paper on the bottom.
          25              So technically did I know about it?  Yes.
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           1    Technically did I do it?  No.
           2         Q    Oh, I see.
           3         A    But I sanctioned it and I went along with it.
           4         Q    So perjury -- the question was:  "Were you ever
           5    involved in the destruction of PC folders?
           6              "Answer:  No."
           7              That is not perjury because you have somehow
           8    justified in your mind that you really weren't involved
           9    because you didn't actually pull the switch?  Is that what
          10    you're saying?
          11         A    No, I'm saying that I'm not the person that
          12    actually did it myself, but I knew about it.  And reported
          13    about it.
          14         Q    Is that --
          15         A    I didn't stop it.  So, you know, the fact of the
          16    matter is I won't beat around the bush with you,
          17    Mr. Weinberg.  Right here I was not being truthful.
          18         Q    Now, did somebody tell you to perjure yourself?
          19    Is this something that somebody told you to do?  Or you just
          20    did this on your own?
          21         A    No, I was told to do it.  Mr. Earle Cooley, who
          22    was lead counsel for the Church of Scientology at the time,
          23    wanted me to do it.  Mr. Rathbun, who was -- was again and
          24    always responsible for church legal, wanted me to do it.
          25    Mmm, I was being a good Scientologist and protecting
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           1    Scientology.
           2         Q    That is amazing.  So when this started out you
           3    didn't have any recollection of the Yanny deposition, you
           4    don't remember having even signed the errata sheet, and now
           5    you have this clear recollection that -- that Mr. Cooley, a
           6    lawyer who is on the board of trustees of Boston College --
           7    or Boston University, and Mr. Rathbun told you to lie?  Is
           8    that what you're saying now?
           9         A    Mr. -- Mr. Weinberg, I mean, because we are
          10    talking about this, because you have presented me with
          11    documentation, we've discussed it, I think I do have a mind
          12    and I can have some recollection about this.  And I'm just
          13    telling you what happened here.
          14              Mmm, there are other things that I have written
          15    specifically about my relationship with Earle Cooley, and
          16    because you have all of those E-Mails, I'm sure you have
          17    those in evidence, too.  That is not the only thing that I
          18    thought was unethical that happened with Mr. Cooley,
          19    irrespective of where he sits.
          20         Q    So the way it works is, if we can catch you at it
          21    and if we can show you a video or show you some testimony
          22    where you perjured yourself, then it's an indiscretion,
          23    essentially, you sort of caught me.  Is that the way it
          24    works?
          25              MR. DANDAR:  Objection, argumentative.
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           1              THE COURT:  Sustained.
           2         A    Mmm --
           3    BY MR. WEINBERG:
           4         Q    It was sustained, Mr. Prince.
           5              THE COURT:  You don't have to answer the
           6         question.
           7    BY MR. WEINBERG:
           8         Q    Now, you said your life was hopeless?
           9         A    Correct.
          10         Q    When was this deposition, 1989?
          11         A    Correct.
          12         Q    But having been hopeless, you stayed another three
          13    years?
          14         A    I stayed another five years after my life was
          15    pretty much hopeless.  You know, I fell into the
          16    hopelessness -- you know, right in 1987 when that whole
          17    thing happened I was ready to leave Scientology at that
          18    point.  All I wanted to do was walk away.  I had to escape
          19    to leave because I was in the RPF, walking through the
          20    desert, on and on, and I'm sure you don't want to hear that
          21    story.
          22         Q    That story?  Is that what you said?  Do I want to
          23    hear the story?
          24         A    Let's please maintain civility here, Mr. Weinberg.
          25         Q    All right, I asked you --
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           1         A    I'm trying to explain this to you.  I had escaped.
           2    I had helped Vicki Aznaran escape.  We were being kept in
           3    the RPF in a -- behind a -- Soboba Indian Reservation in the
           4    most horrid conditions.  All I wanted to do was walk away.
           5    I had to threaten to go to the press, threaten to go to the
           6    police, the same thing I suspect Lisa had to do when she
           7    tried to leave, as well.
           8              And ultimately because the woman that I was
           9    married to, who had no idea what I had been involved in,
          10    what my position really was in the Church of Scientology,
          11    what my participation was, it came down to Mr. Mithoff,
          12    Mr. Miscavige specifically talking to my wife and telling
          13    her what a horrible person I was and that I'm blowing and
          14    I'm psychotic and I'm crazy because I want to leave and this
          15    kind of thing.
          16              So then I was faced with even a bigger problem.
          17    And my bigger problem was now am I just going to walk out of
          18    Scientology and leave this person that I love, that I'm
          19    married to, because she hasn't woke even up, because she
          20    doesn't understand, because I haven't been with her and let
          21    her know what's going on.  And that is kind of a problem in
          22    Scientology in and of itself because the right hand doesn't
          23    know what the left hand is doing.  You are not allowed to
          24    talk about your case, you're not allowed to talk about
          25    secret this, secret that.  So we had had a breach of
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           1    communication for many years.
           2              But in my mind at that time I was thinking, you
           3    know, I'm not going to desert another person in my life, I'm
           4    not going to desert this woman for Scientology.  I will sit
           5    here with her until she sees what I see.  And I was
           6    actually, therefore, there for another five years.
           7              And these are points I have written about as well.
           8    I felt almost like an animal, I had no mind, no brain, no
           9    will, nothing.  And this is what happened to me and I went
          10    and did this and it was wrong.  And yeah, I did that and you
          11    have pointed it out and here we are.
          12         Q    Now, in 1989 when you perjured yourself --
          13         A    Uh-huh?
          14         Q    -- according to your testimony now, or didn't,
          15    depending upon whether you perjured yourself in this
          16    hearing, you weren't on the RPF, were you, in 1989?  You
          17    were working in the Golden Era studio, correct?
          18         A    I think in 1989 I was on what is considered --
          19    what is called the DPF, the Deck Project Force.  The reason
          20    I say that is because in 1987 when I was removed from my
          21    position and I went to the RPF -- Mmm -- I think I was there
          22    for -- until December of '87.
          23              In December of '87 I got off the RPF, I started
          24    trying to practice auditing again.  I did that for some time
          25    and really didn't want to do it anymore.
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           1              Toward the end of '88, I believe, a security guard
           2    at Golden Era Productions got kind of rough with my wife.
           3              THE COURT:  You know, this really doesn't
           4         matter where he was.  You weren't in RPF.
           5         A    No, I was in DPF.  I wasn't in Golden Era
           6    Productions, I mean, working in the studios, as you
           7    suggested.  I was actually on the DPF.  And this is the same
           8    period I did that watch with Mrs. Brooks, Terese or -- or
           9    Teresita --
          10    BY MR. WEINBERG:
          11         Q    That was in '88?
          12         A    That was in '88?
          13         Q    Yes.  You say things were hopeless for you?
          14    Things were hopeless for you in 1997 and 1998, as well,
          15    wasn't it?
          16         A    I wouldn't say that.
          17         Q    You filed for bankruptcy and went bankrupt in
          18    November of -- filed in what, May of '97, and it was
          19    finalized in November of '97, correct?
          20         A    I believe there are documents to that effect that
          21    have the correct dates.
          22         Q    But -- but you went bankrupt in 1997, correct?
          23         A    Mmm --
          24         Q    Yes, or no?
          25         A    Yes, I did.  I believe that is correct.
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           1         Q    So you were broke in 1997?
           2         A    I filed for bankruptcy in 1997, but I -- I wasn't
           3    able to pay my bills adequately in 1997.
           4         Q    And except for Mr. Minton coming like an angel
           5    from heaven in June of 1998, you didn't know what you were
           6    going to do?
           7         A    Utterly and completely false.
           8         Q    After Mr. Minton appeared on the scene you then
           9    hooked up with Stacy Brooks, you hooked up with Dan Leipold,
          10    you hooked up with Ken Dandar, and since that time this is
          11    what you have been doing, getting paid to testify, write
          12    affidavits and work against Scientology, correct?
          13         A    No, that is absolutely incorrect and it is false.
          14         Q    Now, let's go back to the deposition for a moment.
          15    Now, you testified under oath a lot about the GO and OSA and
          16    all that.  Do you remember that, here in this proceeding?
          17    You said you had all this knowledge about the kinds of
          18    activities that had gone on.  Do you remember that?
          19         A    No, I think you are mischaracterizing my earlier
          20    testimony.  I don't think that the words Guardian's Office
          21    exited my lips during these proceedings.  I have spoke about
          22    OSA and I have -- I have presented Mr. Hubbard's eternal
          23    words on -- on what intelligence is expected to do, what
          24    legal is expected to do and some of what public relations is
          25    supposed to do.  I think that better characterizes --
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           1         Q    Well, let me refresh your recollection, if you
           2    remember on June 18 saying, "Question, was there any
           3    carryover from the Guardian's Office to OSA?
           4              "Answer:  Yes, there was, there was a carryover of
           5    some of the staff and some of the policies.
           6              Then you went on to say, "Question, was OSA still
           7    Department 20 like the Guardian's Office was?
           8              You said, "Yes, OSA wanted to make sure they
           9    didn't make the same mistakes as the past Guardian Office
          10    was.  One of the mistakes was putting in writing and
          11    detailing some of the operations."
          12         A    Yes, I did.
          13         Q    Do you remember that?
          14         A    Yes.
          15         Q    Now, turn to Page 149, please, of the Yanny
          16    deposition.
          17         A    Okay.
          18         Q    I want you to read Line 5 through Line 16 -- Line
          19    5 through Line 13 -- 16, I'm sorry.
          20         A    To 16?
          21         Q    Yes, just read it out loud.
          22              MR. DANDAR:  Objection, that is not the way you
          23         do it.
          24              THE COURT:  That is true.
          25         A    I have read it.
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           1    BY MR. WEINBERG:
           2         Q    I'll read it.  Did you give -- were you asked
           3    these questions and give these answers?
           4              MR. DANDAR:  Objection, that is not the way
           5         you --
           6              THE COURT:  Yes, it is the way you do it.
           7         Overruled.
           8    BY MR. WEINBERG:
           9         Q    "You ever heard of the GO?
          10              "Answer:  Yes.
          11              "Question:  What was the GO?
          12              "It was Guardian's Office.
          13              "Question:  And Mary Sue Hubbard was in charge of
          14    that for a period of time?
          15              "Answer:  I have no knowledge of the Guardian's
          16    Office.  I was never associated or affiliated with it in any
          17    way.
          18              "Answer (sic):  You do know that a number of
          19    Guardian's Office people went to jail?
          20              "Answer:  I don't --"
          21              Then there was objection.
          22         A    Okay.
          23         Q    Were you asked those questions and give those
          24    answers?
          25         A    Yes, that is correct.
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           1         Q    And that was true or was that perjury, as well,
           2    that you had no knowledge of the Guardian's Office?
           3         A    Well, that was true then and it is true now.
           4    Prior to my association with going to Gilman Hot Springs, I
           5    had -- you know -- you know, I had done protests at the
           6    behest of the Guardian's Office where all Scientologists got
           7    together, and I think did a demonstration of the courthouse
           8    down there at a point in time on -- Hebert would -- what
           9    they do is they have a thing in Scientology called a call to
          10    arms --
          11         Q    Really, all I asked you, was that true or not and
          12    you said it was true that --
          13         A    Okay.
          14         Q    Using your words, you had no percipient
          15    knowledge --
          16         A    Well, I don't want to play --
          17         Q    Can I ask my question first?
          18         A    I told you that there was -- you know, was some
          19    association with the Guardian Office, and I tried to clarify
          20    that.  So you know, I don't want to get into word games here
          21    where you say, well, you said you never did it but suddenly
          22    now you have me picketing at the behest of Scientology.  I
          23    mean, little activities like that, I mean, I popped out of a
          24    coffin across the park doing a skit based on something
          25    that --
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           1         Q    I understand, but you waxed eloquent about the GO
           2    and how it's the same -- OSA was the same, and under oath
           3    here you said you didn't know, didn't have information about
           4    the GO.  You didn't know anything about it.
           5         A    No, I think you are confused on that issue,
           6    Mr. Weinberg.
           7         Q    Now, do you remember testifying in this proceeding
           8    that -- that you were -- had responsibility for legal,
           9    intelligence and PR activities of OSA?  Do you remember
          10    that?
          11         A    Yes.
          12         Q    Particularly intelligence activities of OSA, that
          13    was your testimony?
          14              THE COURT:  Could you define or tell him -- I
          15         don't remember, was it here in this hearing?
          16              MR. WEINBERG:  That is what I said.  I was just
          17         reading from his testimony.
          18              THE COURT:  Here?
          19              MR. WEINBERG:  Yes.
          20              THE COURT:  Okay.
          21    BY MR. WEINBERG:
          22         Q    I'll read -- this is the dirty -- when I say
          23    dirty, this is the --
          24              THE COURT:  Dirty copy, I know.
          25
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           1    BY MR. WEINBERG:
           2         Q    The dirty copy, but on my Page 71 of the dirty
           3    copy, which is obviously not the actual transcript, what it
           4    says is, "As I mentioned --" this is your answer -- "we used
           5    to do the technology side of Scientology.  Then there was a
           6    separate area, areas that I also had responsibility for.
           7    And those were legal, intelligence and PR activities of OSA
           8    which is a separate network in Scientology."
           9              That was your testimony, right?
          10         A    Yes.  Yes.
          11         Q    Now, I want you to turn, if you will, Mr. Prince,
          12    to Page 77, first, of your Yanny depo.
          13              While you are looking for it, you were deputy
          14    inspector general of RTC, correct?
          15         A    Correct.
          16         Q    And it was deputy inspector general external was
          17    your actual -- DIG external, right?
          18         A    Right.
          19         Q    Did you -- if you go to the bottom of the page,
          20    Line 22, were you asked this question and did you give this
          21    answer.
          22              "Question:  Back when you were the DIG external,
          23    did you have any responsibility for intelligence?
          24              "Answer:  Not particularly.
          25              "Question:  Is there a group or subgroup within
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           1    Scientology organization referred to as Intel?
           2              "Answer:  No, not that I know of.
           3              "Question:  Has Intel ever been part of your job
           4    description?
           5              "Answer:  No.
           6              "Have you ever had any responsibility for Intel?
           7              "Answer:  No."
           8              Were you asked those questions and did you give
           9    those answers?
          10         A    Yes, I did.
          11         Q    And was that truthful testimony?
          12         A    Yes, it was.  And you know, in -- inasmuch as
          13    it -- that it was deceptive testimony because we've sat here
          14    and we've gone over all of these Scientology issues, now
          15    that says intelligence action, this, that and other thing,
          16    but when the GO was gotten rid of, the section that was
          17    called intelligence was no longer called intelligence; it
          18    was called the information bureau.  And I think if you look
          19    at a current organization chart for the Office of Special
          20    Affairs, you will find that it says information bureau.  It
          21    doesn't say intelligence bureau.  But if you look at the
          22    materials that the persons are trained on in the information
          23    bureau, it is intelligence.
          24         Q    It is sort of like your testimony yesterday where
          25    I asked you about the picket sign, you know, in front of
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           1    Mr. Minton's house and you said you didn't own a sign?
           2         A    You know, I don't know about that, Mr. --
           3         Q    Was that truthful but deceptive testimony, or is
           4    that sort of like an example of what you're talking about?
           5         A    I don't know about that analogy, Mr. Weinberg.  I
           6    think you are confused on that issue and you are mixing
           7    apples and oranges.  But I pretty much answered your
           8    question with this.
           9         Q    All right.  So this is truthful but -- and so what
          10    is -- by the way, just so -- it's not perjury when you tell
          11    the truth but you are deceptive?  In your mind, that is
          12    okay?
          13         A    Well, you know, I'm --
          14         Q    Just answer the question.
          15         A    I'm not going to draw a legal conclusions.  You
          16    are the trained lawyer here.  I'm the trained Scientologist.
          17         Q    You are the trained witness.
          18         A    I can tell you about that.  I can't tell you about
          19    the lawyering so much.  I can't explain the law to you.  You
          20    can explain that to me.
          21         Q    Explain to me how you are being truthful when you
          22    are being deceptive?
          23         A    By the mere fact being deceptive, you are not
          24    being totally honest.  But then again, as I understand the
          25    law, you are not obligated to answer but an exact question,
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           1    and the exact question here was about intelligence and --
           2    and again, I'll tell you, when the GO was changed, the word
           3    "intelligence" was gotten rid of and the word "information"
           4    was put in there; information bureau, information
           5    department.
           6              So if they would have said information department,
           7    I could have answered these questions a little differently.
           8    But I didn't say, oh, you know, well, they changed
           9    intelligence to information because no person wants a
          10    witness walking in just blah-blah-blah, blah-blah-blah.
          11    Answer the question you are asked and that is it, okay.
          12              THE COURT:  Sort of like you are doing now?
          13              THE WITNESS:  Okay.
          14    BY MR. WEINBERG:
          15         Q    So why did you use the word "intelligence" when
          16    you testified for Mr. Dandar?  I just read you the
          17    testimony.  "In those areas that I was responsible for,
          18    legal, intelligence and PR activities of OSA," why did you
          19    use the word "intelligence"?
          20         A    Because I was able to take the eternal words of L.
          21    Ron Hubbard that had that on there and show it.  I used it
          22    because that is what the issue says.
          23         Q    And by the way, that is acceptable to you to give
          24    truthful but deceptive testimony?  That is acceptable to you
          25    as you sit here as a so-called expert in Scientology?
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           1         A    It is acceptable to me to answer -- answer the
           2    question that is asked.
           3         Q    So I have got to ask the absolutely right question
           4    or you can deceive me and there is no problem here?  You can
           5    deceive me and the Court?  And everybody else that is --
           6    that is in this room?
           7         A    Mmm, well, you know, you can call it deception or
           8    you can call it inadequate lawyering.  I mean, I don't know.
           9    What do you want to say about it?
          10         Q    Well, have you had any of those answers while you
          11    have been on the stand, those truthful but deceptive
          12    answers?  Can you think of a couple where we just missed the
          13    question a little bit?
          14         A    You know, Mr. Weinberg, I think I'm making a
          15    valiant effort here to keep perspective and keep things in
          16    perspective.  And I think I have gone overboard in
          17    explaining my rationale.
          18              THE COURT:  The question is, Mr. Prince, is
          19         there any time in this hearing you have not told the
          20         absolute whole truth, that is what the oath is, the
          21         truth, whole truth and nothing but the truth?
          22              THE WITNESS:  No, there is not.
          23              THE COURT:  All right.
          24    BY MR. WEINBERG:
          25         Q    Now, you testified, I think -- correct me if I'm
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           1    wrong -- a number of times that -- that Mr. Miscavige was
           2    deeply involved in the activities of you and Ms. Aznaran at
           3    the RTC and that -- and that you and her reported to
           4    Mr. Miscavige when you were there.  Is that right?
           5         A    Mmm, partially right.  I -- I don't -- don't
           6    remember saying Miscavige was deeply involved with me and
           7    Mrs. Aznaran in RTC.  I don't remember --
           8              THE COURT:  He did say he reported --
           9              THE WITNESS:  Yes, but the other part, I --
          10    BY MR. WEINBERG:
          11         Q    Let's make it clear because that is actually the
          12    question I wanted to ask you.  You said -- you testified
          13    under oath you reported to David Miscavige while you were
          14    DIG external at RTC?
          15         A    I -- ultimately, I did report to him, yes.
          16              THE COURT:  Frankly, I think he said he
          17         reported to Vicki Aznaran.
          18              MR. WEINBERG:  I'm just asking him now --
          19         we'll, I'll read you what he said.
          20              THE COURT:  You have to read him what he says
          21         because I can't even remember, myself.
          22    BY MR. WEINBERG:
          23         Q    This is actually the real transcript, Page 342,
          24    lines 19 through 25.  And this is in response to a question
          25    from Mr. Dandar.  And you say:  "Answer:  So you know from
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           1    the --"
           2              THE COURT:  Read the question.
           3              MR. WEINBERG:  That is what I'm trying to find.
           4         There was a lot of interruptions.
           5              MR. DANDAR:  Well, that is surprising!
           6    BY MR. WEINBERG:
           7         Q    Mr. Prince just starts talking.  There was --
           8    there was dialogue about the Clearwater Police Department.
           9              THE COURT:  Well, let me hear what it is you
          10         are wanting to read to him, then we'll see if he can
          11         remember this testimony.
          12    BY MR. WEINBERG:
          13         Q    Okay.
          14              "Answer:  So you know from the limited time that I
          15    was there in Religious Technology Center myself, I know
          16    that -- you know, there wasn't much about the Flag Service
          17    Organization I didn't know about and also had
          18    responsibilities for to make sure the whole thing ran
          19    smoothly, and the person that I reported to was certainly
          20    the -- ultimately was Mr. Miscavige."
          21              That is what you said?
          22         A    Correct.  That doesn't mean to the exclusion of
          23    Mrs. Aznaran who was my direct --
          24         Q    No, I didn't -- wasn't suggesting that.
          25         A    Okay.
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           1         Q    Now, if you'll go to -- by the way, did you also
           2    report to Marty Rathbun back then?
           3         A    Yes.  Yes.
           4         Q    If you go to Page 52 of the Yanny deposition,
           5    please --
           6         A    Was that 52, Mr. Weinberg?
           7         Q    Yes, 52.
           8         A    Okay.
           9         Q    Look at Line 15 through 19.
          10              "Question --" were you asked these questions and
          11    gave these answers under oath.
          12              "Question:  Back in this '84, '86 time period did
          13    you ever have an occasion to report to Marty Rathbun?
          14              "Answer:  No.
          15              "Question:  Did you ever report to David
          16    Miscavige?
          17              "Answer:  No."
          18         A    Right.
          19         Q    Were you asked those questions, did you give those
          20    answers?
          21         A    Yes, I did.
          22         Q    Were those truthful answers?
          23         A    No, they were not.
          24         Q    So you perjured yourself?
          25         A    Correct.
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           1              THE COURT:  I honestly don't want you to use
           2         the word "perjury."  Perjury is a term of law.
           3              MR. WEINBERG:  Okay.
           4              THE COURT:  Lie would be fine.
           5              MR. WEINBERG:  Well, I have had judges tell me
           6         not to use lie because it is inflammatory.
           7              THE COURT:  If that were in front of a jury,
           8         that may be true, but for me in this particular
           9         proceeding perjury is a term of law.
          10              MR. WEINBERG:  Fine.
          11              THE COURT:  If you say is that a lie, that
          12         would be fine.
          13    BY MR. WEINBERG:
          14         Q    Was that a lie?
          15         A    Yes, it was.
          16         Q    And did somebody instruct you to lie?
          17         A    Yes.  Again, Mr. Earle Cooley, Mr. Rathbun.
          18    Again, I'm being a good Scientologist and I'm protecting
          19    Scientology.
          20         Q    And you're not being a good anti-Scientologist as
          21    you sit on the stand in this proceeding and write affidavits
          22    and stuff like that, correct?
          23         A    I'm sorry, I didn't understand the question.
          24         Q    Well, is there a code of ethics for people like
          25    you that are part of the anti-Scientology movement?
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           1              MR. DANDAR:  I'll object to the phrase
           2         "Anti-Scientology movement."  I don't know if that
           3         has been established anywhere.
           4              THE COURT:  I think you need to save that for
           5         another time.
           6              MR. WEINBERG:  Okay.
           7    BY MR. WEINBERG:
           8         Q    Is there a code of ethics, did you and members of
           9    the A team and those people that were carrying the signs for
          10    the Lisa McPherson Trust that we saw that video yesterday,
          11    was there some code of ethics as to what you guys were going
          12    to do when you were under oath?
          13         A    Mr. Weinberg, no one carried a sign for the Lisa
          14    McPherson Trust.  You know, you make it impossible for me to
          15    answer these questions when you draw these conclusions and
          16    inferences that simply are just not true.
          17         Q    Well --
          18              THE COURT:  So the question is, was there a
          19         code of ethics that you and Mr. Minton and --
          20              MR. WEINBERG:  Ms. Brooks.
          21              THE COURT:  -- Ms. Brooks developed when you
          22         were to testify?
          23              THE WITNESS:  No.
          24              THE COURT:  In this proceeding?
          25              THE WITNESS:  No.  The answer to the question,
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           1         your Honor, is no.
           2    BY MR. WEINBERG:
           3         Q    Now, you have testified again today about the RPF
           4    and I believe that on direct -- and I'll read you your
           5    testimony if you don't remember it, but I believe that you
           6    have referred to the RPF as being a concentration camp or
           7    something like that, correct?
           8              THE COURT:  Prison camp.
           9         A    Prison camp.
          10              MR. WEINBERG:  Actually, in this transcript it
          11         says concentration camp on Page 456.
          12              THE COURT:  I heard prison camp for sure.
          13         Prison, concentration camp, I guess they're all the
          14         same.
          15              MR. WEINBERG:  Well, actually --
          16              THE COURT:  They're not.
          17              MR. WEINBERG:  In my mind a concentration camp
          18         brings images of Nazi Germany, and a prison camp,
          19         you know, we have them in Florida.  But --
          20              MR. DANDAR:  Well, Japanese had concentration
          21         camps in the United States.  We had --
          22              MR. WEINBERG:  I'm not even going there.
          23              MR. DANDAR:  There must be a difference.
          24              THE COURT:  Maybe not to this particular
          25         witness.  He may not -- not make a distinction.
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           1              THE WITNESS:  Well, actually, your Honor, I
           2         think there is a distinction in that I think the
           3         Rehabilitation Project Force is more akin to a
           4         concentration camp in that part of the program is to
           5         have not -- not only to have a mind-altering
           6         experience, but to have a total revamping of the way
           7         you were before.
           8              THE COURT:  Okay.  So you refer to it as a
           9         concentration camp?
          10              THE WITNESS:  Yes.
          11    BY MR. WEINBERG:
          12         Q    By the way, did you lose a lot of weight when you
          13    were in the RPF?
          14         A    Which time?
          15         Q    I mean, did you get meals?
          16         A    Which time?
          17         Q    You said you were in twice, I believe.
          18         A    Right.  So you mean both times?
          19              THE COURT:  Either time.
          20    BY MR. WEINBERG:
          21         Q    Either time.
          22         A    The first time I lost weight dramatically.  I
          23    think I got down to 144 pounds because we weren't allowed to
          24    eat regular food, we had to eat fruit and -- and protein
          25    supplement called Progest.  Then we had to run around with
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           1    plastic suits on our body to, quote/unquote, get the
           2    impurities out.  This is all we were allowed to eat is fruit
           3    and Progest.
           4         Q    That was in the '70s?
           5         A    That was '77.
           6         Q    So then in '87 when, you know, everything came
           7    down on you and you got --
           8         A    I lost weight there, too, yes.
           9         Q    Were you running around drinking protein drinks
          10    and wearing sweat suits?
          11         A    No, not the second time.
          12         Q    Now, you testified that you were -- let me
          13    quote -- "forcibly," quote/unquote, that is what you said
          14    here, "removed from the RTC."  That is what you said on the
          15    stand.
          16         A    Yes.
          17         Q    Do you remember that?  Now, when you said
          18    forcibly, what -- what were you referring to?
          19         A    Well, I was referring to a couple of things.
          20    Prior to assuming any position as a board member in the
          21    Scientology conglomerate, the one thing that you're asked to
          22    do in order to have this position is to sign an undated
          23    resignation.
          24              After signing an undated resignation, then you are
          25    allowed to be a corporate officer, on the board of directors
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           1    or -- or some such like that, you know, having to do with
           2    corporate matters.
           3              So I was a -- on the board of directors of the
           4    Religious Technology Center.  I was the treasurer.  But when
           5    I was graced with that position I also at that time had to
           6    sign an undated resignation.
           7              Again, I was woken up at I guess 5 o'clock in the
           8    morning with 12 people in -- security guards wearing
           9    uniforms like they're on a mission, and I was told that I
          10    was removed, I was shown my undated resignation so that, you
          11    know -- and this is a legal process.  And apparently this is
          12    a problem that they had, but I won't diverge, but this and
          13    this, and I was told, "You stand up, you call me sir."
          14    Miscavige wanted me to do that, and I didn't want to do it.
          15    So they grabbed me and they started jumping me.
          16         Q    All right.  That is the gun thing?
          17         A    Right.
          18         Q    The gun thing?
          19         A    Right.  We talked about that yesterday.
          20              THE COURT:  Are you also talking about the fact
          21         your resignation was filled in, is that what you
          22         considered part of forcible removal?  Or not?
          23              THE WITNESS:  Yes.
          24              THE COURT:  So when you mentioned that, that is
          25         also part of your forcibly removed because it was
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           1         filled in and, therefore, you were removed?
           2              THE WITNESS:  Yes.
           3    BY MR. WEINBERG:
           4         Q    Now, you understood when Scientology reorganized
           5    in the early '80s and created RTC and CSI and a variety of
           6    other corporations, you understood that there was a
           7    corporate structure then that was very clear and defined in
           8    corporate documents, correct?
           9         A    Before --
          10         Q    You understood that?
          11         A    Before or after -- I guess -- there was a
          12    corporate structure before they created RTC, CSI, all these
          13    other corporations?
          14         Q    No, I said you understood in the early '80s, the
          15    Church of Scientology reorganized with a new corporate
          16    structure --
          17         A    Right.
          18         Q    -- including the RTC, CSI, which was the mother
          19    church, and all the churches under them.  You understood
          20    that, right?
          21         A    Yes.  Yes.
          22         Q    And there was a very detailed corporate structure
          23    with -- with articles of incorporation and various
          24    agreements that set forth clearly the corporate way in which
          25    various -- Scientology would be run, correct?
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           1         A    Correct.
           2         Q    And that was the wish and desire of L. Ron
           3    Hubbard, who was still alive that that happened, that there
           4    be this reorganization of the church?
           5         A    You know, I can't say that that is true.  I
           6    can't --
           7              THE COURT:  Who would care?  The idea there was
           8         a corporate reorganization, surely this is going
           9         somewhere.
          10              MR. WEINBERG:  It is going somewhere.
          11              THE COURT:  Get there.
          12    BY MR. WEINBERG:
          13         Q    The RTC was composed of a board of directors.
          14    Correct?
          15         A    That was part of it, sure.
          16         Q    And there were trustees?
          17         A    Correct.
          18         Q    In fact, there were trustees in every Scientology
          19    corporation, correct?
          20         A    Well, I came to learn that in 1987.  But you are
          21    correct.
          22         Q    Well, you learned when you joined RTC that there
          23    were trustees, there were three trustees?
          24         A    No.  No.  No.
          25         Q    Well, what you learned is that the trustees had
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           1    one function, correct, and that is to -- that is to -- to
           2    name or remove directors.  You understood that, didn't you?
           3         A    No, sir.
           4         Q    And you were removed in 1987, along with
           5    Ms. Aznaran, by the trustees of RTC, one of which was
           6    Mr. Miscavige, correct?
           7         A    Incorrect.  I was removed by one person, only one
           8    person's will, on one person's authority, and that was
           9    Mr. Miscavige.
          10         Q    Was he one of the trustees of RTC?
          11         A    Yes.  And this got explained to me as he was doing
          12    this.  You know, he -- you know, and I guess I was a bit
          13    naive, you know, I didn't know.  I wasn't a corporate
          14    person.  I'm not trained, you know.
          15              And he explained it to me very well.  He said,
          16    "Look, I am a trustee.  Norman is a trustee."  I think Marty
          17    may have been a trustee or Steve Marlowe may have been a
          18    trustee.  I'm not sure.  And he explained to me how it
          19    worked.
          20              And he said, "Here is your undated resignation and
          21    you have officially resigned and this is how it works and we
          22    have the authority to do that."  And at that point I was
          23    cognizant of how it worked.
          24         Q    Are you saying that for the five years that you
          25    were in RTC and for the three or so that you were a board
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           1    member and, you said, the number two person at RTC, you
           2    didn't know that there were trustees that had the ability
           3    to -- to remove you?
           4         A    Correct.
           5         Q    But you are an expert on the corporate structure
           6    of Scientology?
           7         A    I have never said I am an expert on the corporate
           8    structure of Scientology, Mr. Weinberg.  I said that I am an
           9    expert in the -- in the policies, bulletins and issues that
          10    are Scientology.  That is Scientology.
          11         Q    If you go to Page 16 of your deposition --
          12              THE COURT:  Which deposition?
          13              MR. WEINBERG:  I'm sorry, the Yanny deposition.
          14    BY MR. WEINBERG:
          15         Q    The --
          16         A    I'm not quite there.
          17         Q    Okay.
          18         A    Okay.  I'm there.
          19         Q    Okay, Line 4, question -- were you asked these
          20    questions and did you give these answers -- and you will see
          21    there is one date that is wrong, but it is wrong in the
          22    transcript, and I think you -- it didn't affect the
          23    question.
          24              "Question -- Line 4 were you asked this question,
          25    "October of '83 to March of '87 you were deputy inspector
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           1    general for external affairs.
           2              "Answer:  That's right.
           3              "Question:  Was Vicki Aznaran your senior during
           4    that entire course of time?
           5              "Answer:  Yes.
           6              "Question:  Were you out at Gilman Hot Springs?
           7              "Answer:  Gilman Hot Springs and Los Angeles.
           8              "Question:  What was your next position then in
           9    March of '83."  That would be obviously March of '87, I
          10    think you understand that by your answer.  And did you give
          11    this answer.
          12              "Answer:  Then I went to the RPF for three months,
          13    probably three and a half.  Then I was an auditor.  I was an
          14    auditor at Golden Era, the same place at Gilman Hot Springs,
          15    for a while.
          16              "Question:  For about three and a half months
          17    starting in March of '83 --" but it is '87 -- "you were in
          18    the RPF again?
          19              "Answer:  Yes."
          20              Then I'll skip to Page 17.  Top of the page.  Line
          21    3 were you asked this question and gave this answer:  "What
          22    were the circumstances of your transferring from RTC to
          23    Golden Era Productions?
          24              "Answer:  Well, when I was in RTC I wanted to go
          25    to the RPF because I needed more training.  I needed -- I
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           1    just needed more skill than I presently had.  And that
           2    afforded me an opportunity to do that because I could go
           3    five hours a day, so I did that and also got auditing,
           4    co-audited and life audited, because I audited practically
           5    my whole career in Scientology.  So I decided to audit for a
           6    while."
           7              Do you see that?
           8         A    Yes, I do.
           9         Q    Were you asked those questions, did you give those
          10    answers?
          11         A    Yes, I did.
          12         Q    So that was false testimony?
          13         A    This was coached testimony by Mr. Earle Cooley,
          14    Mr. Rathbun, for the purpose of deposition with Mr. Yanny.
          15         Q    So is that a definite category --
          16              THE COURT:  That was also false, correct?
          17              THE WITNESS:  Yes, yes, your Honor.
          18              THE COURT:  You were coached by who?
          19              THE WITNESS:  Mr. Earle Cooley and Mr. Marty
          20         Rathbun.
          21    BY MR. WEINBERG:
          22         Q    Now, that deposition -- you were asked questions
          23    by whom in that deposition?
          24         A    You know, I don't know.  I -- I don't know.
          25              THE COURT:  Take a look at the front.  It
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           1         should say who was representing Mr. Yanny.  Did you
           2         give him the front page?
           3              MR. WEINBERG:  I gave him the whole deposition.
           4         If I could approach, I think I could show him.
           5              THE COURT:  Okay.
           6         A    Cummings & White.  Is that who it was?
           7    BY MR. WEINBERG:
           8         Q    Barry VanSickle.  Do you remember Barry VanSickle?
           9         A    Not really.
          10         Q    But do you remember this was a deposition, now
          11    that we refreshed your recollection, the questions were
          12    being asked by Mr. Yanny's lawyer, not by Mr. Cooley, the
          13    ones we went over.
          14         A    Okay.
          15              MR. WEINBERG:  Just one second, your Honor.  I
          16         need to move some stuff and get some other stuff.
          17    BY MR. WEINBERG:
          18         Q    Now, going to a different subject now, Mr. Prince.
          19         A    Are we finished with this?
          20         Q    Yes, let me take that back.
          21              THE COURT:  Why don't you go ahead and give
          22         that, then, to Mr. Dandar.
          23              MR. WEINBERG:  I will.
          24              THE COURT:  That will save you all from having
          25         to copy it.
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           1              MR. WEINBERG:  Is this our only copy?  No, we
           2         have other copies.
           3              MR. DANDAR:  You do have another copy?
           4              MR. WEINBERG:  Apparently, somewhere back at
           5         the ranch.
           6              THE COURT:  But you can go ahead and make
           7         yourselves a copy and he can have that one?
           8              MR. WEINBERG:  Right.  Right.
           9    BY MR. WEINBERG:
          10         Q    Now, let's go back to the LMT now.  And I think
          11    you said a minute ago that I had some misconception of the
          12    LMT and picketing.  Did I hear you say that?
          13         A    Mmm, that is quite possible, yes.
          14              THE COURT:  What he said, Counselor, was that
          15         you were suggesting that they were picketing on
          16         behalf of LMT, and that wasn't exactly correct.
          17              THE WITNESS:  That is right.  That's right.
          18    BY MR. WEINBERG:
          19         Q    But the -- part of the purpose -- part of what the
          20    LMT did in 1999 and 2000 was to picket various buildings of
          21    the Church of Scientology?
          22         A    You know, Mr. Weinberg, I hear you saying that.
          23    But with every video that you have shown here and you have
          24    related to the LMT, there are LMT staff that have never
          25    picketed, never wanted to, never would, and would not
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           1    participate --
           2              THE COURT:  Mr. Prince, this is really simple.
           3         Really the question is here, and I don't think it is
           4         that difficult, one of the things that LMT did,
           5         those folks who were at LMT, was to picket when they
           6         thought it appropriate.
           7              THE WITNESS:  Yes, occasionally they would.
           8              THE COURT:  Exercising their rights, whatever
           9         you want to call it.
          10              THE WITNESS:  Yes.
          11              THE COURT:  They would at times organize a
          12         picket and go picket the Church.
          13              THE WITNESS:  Correct.
          14    BY MR. WEINBERG:
          15         Q    Now, in January of 2000 you were the consultant,
          16    expert, working with Ken Dandar in this case, right?
          17         A    Correct.
          18         Q    And you were also working in the Wollersheim case,
          19    as well, at that time?
          20         A    Mmm, more than likely, yes.
          21         Q    And you were also vice-president at the LMT?
          22         A    Well, we already did LMT.  You said I was at the
          23    LMT.  And I was working with Mr. Dandar.  There are two
          24    things.
          25         Q    I'm focusing on the time, January of --
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           1         A    Okay.
           2         Q    -- 2000, you were the expert for Mr. Dandar --
           3         A    Yes, I was the expert for Mr. Dandar, but I don't
           4    think that I immediately assumed work at the Lisa McPherson
           5    Trust.  I don't think that is how it happened.
           6         Q    Now, I asked you yesterday about you being the big
           7    boss at the LMT?
           8         A    Yes.
           9         Q    And you said no.
          10         A    Correct.
          11              MR. WEINBERG:  Could we play that video,
          12         please.
          13    BY MR. WEINBERG:
          14         Q    By the way, do you remember a situation where
          15    Mr. Minton handed out parrots to various members at the LMT
          16    as Christmas gifts so that -- indicating -- rather, whether
          17    you are a big parrot or little parrot, squawking at
          18    Scientology, do you remember that happening?
          19         A    I think you are referring to a newspaper -- a
          20    press that Mr. Minton had -- had done and that came up --
          21              THE COURT:  Did he give you all parrots?
          22              THE WITNESS:  Yes.
          23              THE COURT:  Okay.
          24              THE WITNESS:  Little ones.
          25              MR. WEINBERG:  All right, could we play this?
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           1         This is from the film library, January 5, 2000.
           2              ______________________________________
           3              (WHEREUPON, the video was played.)
           4              "I have a little presentation, a little sort of
           5         Christmas present for the people who are associated
           6         with the Lisa McPherson Trust who have made all this
           7         possible.  Some of you may be aware that back in
           8         December a guy named Dave -- no, Rick Barry wrote an
           9         article in the Tampa Tribune about -- I think the
          10         headline was 'Bob Minton, will he rouse the
          11         gorilla?'
          12              "Yes.  Yes.
          13              "But the real headline is 'Lisa McPherson
          14         Trust, will they rouse the gorilla.'  And in that
          15         article, he referred to -- in terms of the gorilla,
          16         first of all, he was talking about how this gorilla
          17         came to Clearwater 25 years ago, 800-pound gorilla,
          18         set himself down in the middle of Clearwater, began
          19         buying influence, began buying property, and for the
          20         last 25 years they have basically made themselves a
          21         force in this community by buying people off one at
          22         a time.
          23              "And the -- the question that Mr. Barry raised
          24         in this article was whether, you know, this small
          25         band of parrots would be able to, you know, make a
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                                                                        772
           1         difference here in terms of changing the way that
           2         this -- that this organization is perceived in this
           3         community and in terms of the way this organization
           4         behaves in this community.
           5              "Well, I remember a good friend of mine, Mark
           6         DeLarma, who you all know, said, 'You thought that
           7         was a good article?  He, like, called you guys
           8         parrots.'  I said, 'I thought it was a great
           9         article.'
          10              "So did I.
          11              "Because it really expressed in a very vivid
          12         way how the Lisa McPherson Trust was going to change
          13         the way this community interacts and perceives
          14         Scientology.  And how Scientology will have to -- if
          15         they want to be healthful here, start acting like an
          16         organization that is a church if they want to be
          17         called a church.
          18              "So I figured that the first thing that the
          19         Lisa McPherson Trust had to do is we had to set up a
          20         little -- Mmm -- mascot for this organization.  And
          21         everybody who is part of it.  So for the first --
          22         the first group of -- of Christmas presents are for
          23         those people who will be based here as part of the
          24         organization day in and day out.
          25              "And so the first of those goes -- goes to --
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           1         this is my little parrot that we want to have, the
           2         staff members of the Lisa McPherson Trust, and the
           3         most famous staff member of all is -- is Stacy
           4         Brooks.
           5              "There you go.
           6              "The president and chief operating -- executive
           7         officer.
           8              "The next one -- the next one, the same parrot,
           9         you know, the same parrot, goes to Jesse Prince, the
          10         boss of the whole thing.  Who we all love.
          11              "Thank you, Bobby.
          12              "And the -- and the third -- the third of the
          13         fifth parrots goes to Mark Bunker, the multimedia
          14         king of the world.
          15              "Sweet.
          16              "Who is doing everything he can to keep a
          17         straight face while this is going on.
          18              "There is one for me.  I want to keep that.
          19              "And then when David gets here, this is for
          20         David Cecere.  And I have another parrot which is
          21         not currently in waiting here, but that is for Kim
          22         Baker when she arrives.
          23              "So we've got plenty of parrots.
          24              "We're not done.
          25              "We're not done.  You know -- you know, I mean,
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           1         so I would like to make a recommendation that we
           2         adopt this parrot as the mascot of the Lisa
           3         McPherson Trust so that everybody knows that we are
           4         going to make a lot of noise, we're going to be
           5         squawking about what Scientology does in terms of
           6         harming people and their abusive and deceptive
           7         practices, and we're going to, as little parrots,
           8         we're going to make a lot of noise and drop a lot of
           9         stuff that parrots -- come out the back end and help
          10         these guys learn the way to behave.  Okay?
          11              "So --
          12              "Bravo.
          13              "So now -- now -- now we have little parrots.
          14         We have little parrots for all of the big people who
          15         have made all this possible.  And the first and most
          16         important little parrot goes to Patricia because --
          17         because what Patricia has done, to help everybody
          18         who is down here, get themselves down here and get
          19         them settled in and make them feel comfortable in
          20         this -- in this whole environment, which is not an
          21         easy place for -- for former Scientologists to come
          22         to.  You know, they have been willing to stick their
          23         neck out and come down here and really make this
          24         organization happen.  And so Patricia has really
          25         made everybody feel comfortable, she's -- she's sort
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           1         of like --
           2              "She chased PIs into the bathroom for me.
           3              "Yes, and you -- you know -- so I -- I want
           4         Patricia to have a parrot.
           5              "Thank you.  Thank you.  Thank you very much.
           6              "Ray Emmons has been teaching us all for -- and
           7         a lot of people didn't listen for a long time, how
           8         this organization really operates.  And he did this
           9         in Clearwater.  He made himself known nationwide in
          10         terms of his opposition to Scientology.  And the
          11         type of organization that they really are underneath
          12         the surface.  And so I want Ray to know that he's a
          13         parrot, as well.  You have been a parrot for a long
          14         time.
          15              "Okay.
          16              "Let me have a kiss here, Patricia, because I
          17         didn't do that.  Thank you so much.
          18              "The order of the parrot.
          19              "The order of the parrot.  This is like the
          20         highest award that the Lisa McPherson Trust can
          21         bestow upon somebody.
          22              "Now, you know, Peter Alexander has been
          23         squawking about Scientology for a long time, even
          24         when he was in it, especially toward the end of the
          25         time he was in it, when he was -- when he was --
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           1         when he was being squawked at by Patricia -- you
           2         know, rather regularly.  So -- and Peter has allowed
           3         Patricia particularly to devote so much time and
           4         energy into helping this organization get off the
           5         ground.
           6              "And I just want you to know, Peter, that we're
           7         totally thankful for your help and support in this
           8         organization, your being on the board.  And I really
           9         want all of us to know that this is an incredibly
          10         tight-knit little group, and got a lot of hard work
          11         to do here in Clearwater.  But with people like all
          12         of us here and you, Peter, thank you so much for
          13         doing this.  And I want to present you with a little
          14         parrot.
          15              "Yes.
          16              "Thank you, sir.  Thank you.
          17              "And I want to -- I want to --
          18              "The order of the parrots.
          19              "The order of the parrots.
          20              "I want to talk to you about a theme park.
          21              "Yeah.  Yeah.
          22              "Now, the next parrot -- the next parrot is for
          23         Duncan Pierce, you know, our national coordinator.
          24         Our national coordinator.
          25              "Oh, my God.
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           1              "Duncan has been abused by Stacy so much in the
           2         last few months that he really deserves a big
           3         parrot.  But because he's not here on the staff in
           4         the office every day, he can't get a big parrot, you
           5         know, it's just not part --
           6              "The big parrot --
           7              "Look at Peter.
           8              "It's -- you know, the problem is --
           9              "Patricia?  Look at Patricia.
          10              "The problem is it is not in the tech.  He
          11         can't have a big parrot.  But --
          12              "The standard tech.
          13              "Yeah.  Yeah.  But -- but Duncan has done so
          14         much to get us off the ground, as well.
          15              "I don't know what I would do without him.
          16              "It is amazing.  The thing is there are so many
          17         people that have really pushed so hard to get this
          18         thing going.  And, you know, there is no recognition
          19         for us.  You know, we get abused a lot on the
          20         Internet.  Our demise has already been scripted by,
          21         you know, anti-cult and Diane Richardson.  Fine, let
          22         them squawk all they want.  But the real squawking
          23         will be done here in Clearwater by a bunch of
          24         parrots.  And Duncan is one of those parrots.
          25              (Inaudible.)
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           1              "Then for the -- and the person who lives the
           2         furtherest from Clearwater, Grady Ward, who is
           3         standing right here, we have another parrot, because
           4         Mr. Ward -- Mr. Ward is -- is our security expert
           5         here.  And already -- and already during the course
           6         of this day he has learned a lot about security.
           7              (Inaudible.)
           8              "Yeah, don't tell me about it.  But I can tell
           9         you some things about Grady personally because --
          10              (Inaudible.)
          11              "Because one of the things that really got me
          12         involved in this thing was Grady Ward.  And Grady's
          13         stand against Scientology, you know, back in 1995
          14         or -- early '96 when he started going after them
          15         directly after they sued him, he went after them as
          16         his own attorney, you know.  You know what they say
          17         about guys who are their own attorney.
          18              "It is perfectly true.
          19              "And it is perfectly true.  Grady will be the
          20         first to tell you he had no expertise, no competence
          21         whatsoever.  But he -- he studied the law.  He
          22         studied what Scientology was doing.  He -- he
          23         learned so much about it.  And has become a really
          24         good legal man in terms of fighting Scientology.
          25         And I -- you know, I -- I can't -- I can't imagine
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           1         somebody having the patience to understand and go
           2         through and traveling back and forth from Arcadia,
           3         California, eight hours to San Francisco in his car
           4         and memorizing the Rules of Civil Procedure.  You
           5         know, while he's going back and forth.  And I mean
           6         memorizing so he knows every paragraph, every
           7         subparagraph, whatever.  And --
           8              (Inaudible.)
           9              "You know, if you talk about a parrot, then
          10         this guy is a parrot.  And I want to give -- I want
          11         to give this guy who is a shining example for many
          12         people on the Internet in terms of standing up to
          13         somebody who is trying to curtail free speech on the
          14         Internet, I want Grady to have this parrot as a
          15         symbol of our love for him and his contribution to
          16         this whole battle.
          17              "Thank you very much.
          18              "Thank you, Grady.  Thank you.
          19              "And -- and now.
          20              (Inaudible.)
          21              "And now this other parrot, I forgot to tell
          22         you.  I told you this was mine.  And this parrot is
          23         mine because all of you gave me this parrot and I
          24         really appreciate it.  So --
          25              "Something about Rob and why he gets a parrot,
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           1         because if it weren't for him, none of us would be
           2         here.
           3              "Absolutely.
           4              "None of us.
           5              "For sure.
           6              "There is nothing else to say.
           7              "Bob is the big parrot.
           8              "Definitely.
           9              "Oh, but this is not all.  Oh, some of the best
          10         stuff is -- some of the best is saved for last.
          11         Well, what I would like everybody --
          12              "He's big with presents, you can see that.
          13              "What I would like everybody to do, if you put
          14         the parrots around in a little circle here, if you
          15         put the parrots around in a little circle there.
          16              (Inaudible.)
          17              "Right, don't anybody forget -- don't anybody
          18         forget -- don't anybody forget.  But, you know what
          19         the parrots are supposed to do, don't you?  We're
          20         going to get the gorilla.  And I didn't want you to
          21         think I forgot about that gorilla.  So this gorilla
          22         is going to sit right there.
          23              "Whew.
          24              "Don't dump on the gorilla.  Come on.  But --
          25         but that is what this is all about here.  All of us
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           1         little parrots and some of us big parrots here,
           2         we're going to be here and we're going to make sure
           3         this gorilla behaves.
           4              "We're going to educate this gorilla and --
           5              "We're going to put the -- we're going to put
           6         the gorilla in the cage or the jungle, wherever it
           7         belongs.
           8              "We're going to turn this gorilla into a
           9         parrot.
          10              "Yeah, this gorilla is going to be cooperating
          11         with us.
          12              "In any case, everybody can take their parrot
          13         back now.  And I'll keep the gorilla, so when we
          14         have it on the desk out there, it will be --
          15              "Yes, a constant reminder.
          16              "Yes, as a constant reminder of what we need to
          17         do."
          18    BY MR. WEINBERG:
          19         Q    Bring back memories, Mr. Prince?
          20         A    Very fond memories.  I'm so sorry that that place
          21    doesn't exist anymore.
          22              MR. DANDAR:  I'll object because we just went
          23         through that long video and with the -- the question
          24         was -- to Mr. Prince, "Mr. Prince, were you called
          25         or did you call yourself a big boss at the LMT," and
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           1         that is not what that video showed.  Mr. Minton
           2         called Mr. Prince a boss of the whole thing.  So --
           3         so whatever Mr. Weinberg's question was was not
           4         supported by the video.
           5              THE COURT:  Well, it certainly is a video that
           6         he could play at some other time so he played it
           7         now.
           8              MR. WEINBERG:  Right.
           9              THE COURT:  But it is true, he was not called a
          10         big boss --
          11              MR. WEINBERG:  He was called the boss of the
          12         whole thing.
          13              THE COURT:  But I think Mr. Minton made it
          14         clear he was the big boss.
          15              MR. WEINBERG:  Right.
          16    BY MR. WEINBERG:
          17         Q    Now, Mr. Prince, I asked you a lot of questions
          18    about what the Lisa McPherson Trust was about.  That meeting
          19    there was initially the start-up meeting of the Lisa
          20    McPherson Trust, wasn't it?  It is essentially right at the
          21    beginning?
          22         A    I think so.  You know, I think you are right about
          23    that.
          24         Q    Right.  And Mr. Minton made it very clear what it
          25    was about, squawking about Scientology.  That is what the
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           1    Lisa McPherson Trust was about, wasn't it?
           2         A    No, sir.  It was about making Scientology behave.
           3    I think that was also part of this video.  Just to behave.
           4    Be decent.
           5         Q    Putting the gorilla in the cage?  Was that what it
           6    was about?
           7         A    Or in the jungle, wherever it belonged.
           8         Q    What does that mean, "or in the jungle, wherever
           9    it belonged"?
          10         A    Well, it means everything has its place,
          11    Mr. Weinberg.  And there is hardly anything sinister about
          12    what we just watched here.
          13         Q    "We're going to make a lot of noise," that means
          14    you are going to disrupt the activities of the Church of
          15    Scientology in Clearwater, right?
          16         A    No, Mr. Weinberg.  That means that we're going to
          17    expose the deceptive and abusive practices of Scientology
          18    and help those who have been victimized by it.  That is what
          19    we were talking about there.
          20         Q    And at that time when you got the second parrot
          21    for being the boss of the whole thing, you were supposedly
          22    the full-time expert for Ken Dandar, correct?
          23         A    I was working for Mr. Dandar as his expert.  I
          24    wouldn't go as far as to say full-time.  I mean, even you
          25    brought up the fact I was working on the Wollersheim case,
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           1    as well, simultaneously.
           2         Q    We'll get to the -- we'll get -- I'll ask you one
           3    question.  From June of '99 until May of 2000 you were
           4    getting $5,000 a month from Dandar & Dandar?
           5         A    I think the record reflects that, Mr. Weinberg.
           6         Q    And this was in that period of time, wasn't it,
           7    this parrot thing?
           8         A    I believe it was.
           9         Q    Now, you saw this meeting and you were at a number
          10    of meetings with Mr. Minton, correct, over the years?  You
          11    have been with him a lot?
          12         A    Yes, I have been with him a lot.
          13         Q    And in this particular meeting and others that you
          14    were in, Mr. Minton was pretty outspoken, outgoing, he would
          15    take over, right?  He would speak his piece?  He was in
          16    control?
          17         A    No.  Mr. Minton is not that way.  That is the
          18    biggest myth.  You know, Mr. Minton has exact things that he
          19    likes to do and he does them.  I mean, I learned a lot from
          20    him myself.  You know, I have never had millions upon
          21    millions of dollars myself.  I have never been able to help
          22    people the way he has been able to help people.  He has a
          23    different agenda, a different track.  Unfortunately, in some
          24    instances he has a very short attention span.
          25              And he never, in any instance, ever wants to be
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           1    the person that is the leader.  I mean, he doesn't -- he
           2    doesn't do that.  You know, if you want to do it, great.  If
           3    what you want to do makes sense, great, he'll support you.
           4    But he's not going to tell you how to do it.
           5         Q    So this was just an aberration?
           6         A    No, this was -- it was clear what this was.
           7    Mr. Minton was showing his appreciation to persons like
           8    Patricia Greenway, myself, Peter Alexander, Duncan Pierce,
           9    for helping organize and make the people feel welcome at the
          10    Lisa McPherson Trust and helping us be a social -- be a
          11    social reform group, if nothing else, in order to ultimately
          12    help Scientology.
          13         Q    By the way, did he look harassed?  Did he look
          14    like a man that was under some wave of harassment unknown to
          15    mankind?
          16         A    Actually, he looked like a man giving a speech to
          17    a group of people.
          18         Q    It looked like he was -- that was in the Lisa
          19    McPherson Trust building, correct?
          20         A    Correct.
          21         Q    It looked like all of you, Ms. Greenway, you,
          22    Mr. --
          23              THE COURT:  What difference does that make they
          24         were having fun at the LMT?  When gifts were given
          25         out?
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           1              MR. WEINBERG:  All right.  I'll go on.
           2    BY MR. WEINBERG:
           3         Q    Let me ask you a question about Ray Emmons, the
           4    guy that put the parrot on his head.
           5         A    I know Ray Emmons well.
           6         Q    Now, Mr. Emmons had been a Clearwater police
           7    officer and had done an investigation of the Church of
           8    Scientology in the '80s, is that right?
           9         A    Yes, I believe that is correct.
          10         Q    And Mr. Emmons has been and continues to be the
          11    investigator for Ken Dandar in this case, you know that?
          12         A    I know that Mr. Dandar has used him to do service
          13    of process or locate witnesses and things like that.
          14         Q    Now, what was Mr. Emmons' position at the Lisa
          15    McPherson Trust?
          16         A    I don't think he had a position.  He may have been
          17    on the board of directors, which was huge and basically was
          18    a friends list.  But as far as an official position or
          19    coming into that office on a daily basis to work or
          20    accomplish a specific task, that was never anything that he
          21    did.
          22              MR. WEINBERG:  I have a couple E-Mails -- or
          23         postings I was going to put in, your Honor.
          24              THE COURT:  All right.  I want to take a break
          25         here in five minutes, so if it will take more than
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           1         that, break now.  If not, go ahead and do those and
           2         we'll take a break.
           3              MR. WEINBERG:  I think we can do those in five
           4         minutes.  I mean, it is just identifying them.
           5              THE COURT:  Okay.
           6              MR. WEINBERG:  These are actually E-Mails, I'm
           7         told.  I have trouble telling the difference.
           8              THE COURT:  Yes, I don't know the difference,
           9         either.  If they're up there on the screen and
          10         people can read it, to me, it's an E-Mail.
          11              MR. WEINBERG:  Okay, your Honor, this is 223.
          12         I didn't write the number on it.
          13              THE COURT:  Okay, I'll do it.
          14              MR. WEINBERG:  And this is 224.
          15              THE COURT:  All right.
          16    BY MR. WEINBERG:
          17         Q    I'm going to hand you the originals.  We'll put
          18    them back when we're done.
          19         A    Okay.
          20         Q    All right.  If you'll look at first, Mr. Prince,
          21    223.
          22         A    223?  Which one is 223?
          23         Q    That is the --
          24         A    Okay, I have it here.
          25         Q    That is the Jeff Jacobsen --
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           1              THE COURT:  It is the long one.
           2              THE WITNESS:  Yes, okay.
           3              MR. WEINBERG:  I'm really only referring to --
           4         I -- we just received these from the Lisa McPherson
           5         Trust.  I have attached the whole thing, your Honor,
           6         but the only page that -- that -- this is part of
           7         the E-Mails that were produced.
           8              THE COURT:  All right.
           9              MR. WEINBERG:  But really what I'm focusing on
          10         is the first page.
          11    BY MR. WEINBERG:
          12         Q    Mr. Prince, you can look at it all, but I don't
          13    know if the rest -- sometimes it comes off the computer
          14    and --
          15              THE COURT:  Who is this from?
          16    BY MR. WEINBERG:
          17         Q    If you look at this, Mr. Prince, this is from Jeff
          18    Jacobsen to you and Mr. Bunker and Stacy Brooks.  Who is
          19    Karen Case?
          20         A    She used to be a person hired specifically to work
          21    as public relations.
          22         Q    And this is dated August 2, 2000.  Is that right?
          23         A    Well, you know, okay.
          24         Q    Do you see that?
          25         A    Yes.  I do.
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           1         Q    And this is -- do you remember having meetings
           2    about things that needed to be done at the Lisa McPherson
           3    Trust?
           4              MR. DANDAR:  Well, Judge, I have to object.
           5         This is not Mr. Prince's E-Mail so I don't know how
           6         he can question him about some hearsay document
           7         authored by somebody that is not here.
           8              THE COURT:  Well, I think he can state whether
           9         or not this is accurate or not.
          10              MR. WEINBERG:  It is to him.
          11    BY MR. WEINBERG:
          12         Q    You received this, right, Mr. Prince?
          13         A    I have no memory of this.
          14              MR. DANDAR:  Which one are you on?
          15              MR. WEINBERG:  He's copied on the E-Mail, it is
          16         addressed to him.
          17              THE WITNESS:  I don't even know what this is.
          18    BY MR. WEINBERG:
          19         Q    It is an E-Mail to you.
          20         A    Okay.
          21         Q    Among other people.  All right?
          22         A    Okay.
          23         Q    What it says, "This is a list of things we talked
          24    about, elaborated on by me."
          25              Now, Mr. Jacobsen was also part of the Lisa
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           1    McPherson Trust, correct?
           2         A    Yes, he was.
           3         Q    In fact, in some of those videos yesterday you saw
           4    Mr. Jacobsen in it with a camera himself?
           5         A    No, I did not see that yesterday, but --
           6         Q    Oh.  He did take -- he took videos from time to
           7    time, didn't I?
           8         A    Yes.
           9         Q    Do you know why those videos haven't been turned
          10    over, by the way, his, Mr. Jacobsen's?
          11         A    No, I do not.  Were they asked for?
          12              THE COURT:  Don't ask him what he knows or
          13         doesn't know about something like that.
          14              MR. WEINBERG:  I'll ask it a different way.
          15    BY MR. WEINBERG:
          16         Q    Do you know where the videos that he took are?
          17         A    No, I do not.
          18         Q    Were they kept at the Lisa McPherson Trust?
          19         A    I don't know what he did with his personal videos.
          20         Q    But, anyway, this -- this -- this E-Mail talks
          21    about a list of things we talked about, 1, speeches, radio
          22    talk shows.  2, picket.  3, press releases.  4, press
          23    conferences.  5, help with investigations by EEOC, DEB.  6,
          24    the library open for public use.  7, concert November 11.
          25    8, newsletter.  9, attend city council meetings,
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           1    participate.  10, put up a sign for the office outside.  11,
           2    ads in local newspaper.  12, support group.  13, radiofree
           3    Clearwater."
           4              Now, that is 13 things that the Lisa McPherson
           5    Trust, I assume, prioritized to do.  Not one says anything
           6    about counseling, does it?
           7         A    You know, I think you are mischaracterizing this
           8    E-Mail to somehow reflect or -- or be a staple for the
           9    activities of the Lisa McPherson Trust, and what this is is
          10    just simply an E-Mail of Jeff writing.  I have no
          11    recollection of it whatsoever and I don't even remember what
          12    it relates to at this point in time.
          13              I mean, I literally have had thousands of E-Mails,
          14    Mr. Weinberg.  I'm not trying to be uncooperative, I'm
          15    trying to cooperate in the spirit, but what you are asking
          16    me has no perspective.  You are tying this into the Lisa
          17    McPherson Trust and it just doesn't make sense to me.
          18         Q    Well, does it make sense to you one of the
          19    priorities of the Lisa McPherson Trust was pickets?  Does
          20    that make sense to you?
          21         A    No, not at all.
          22              THE COURT:  This is really -- in fairness, this
          23         is a statement from somebody about some meeting and,
          24         frankly, you don't have to persuade me that the Lisa
          25         McPherson Trust picketed.  I don't know why you just
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           1         keep badgering that home.  I know what he's going to
           2         say, you know what he's going to say.  It is me that
           3         is in charge of this hearing, and I'm persuaded, but
           4         the point was not picketing, it was counseling,
           5         wasn't on the list.
           6              You know, that is unfair to suggest because
           7         somebody writes a letter with things they talked
           8         about on a given day of things that needed to be
           9         done, you can hardly assume putting a sign outside
          10         is a primary -- is something that needs to be done.
          11         It doesn't say this is our purpose.  I mean, fair is
          12         fair, Counselor.  And that is not fair to suggest
          13         that those are the purposes of the LMT.
          14              MR. WEINBERG:  I move it into evidence, your
          15         Honor.
          16              THE COURT:  All right.  It will be received.
          17         It will be received, although it is only being
          18         received for the fact that -- that we have a bunch
          19         of E-mails.
          20              MR. WEINBERG:  I understand.
          21              THE COURT:  -- that I have let in.
          22              MR. WEINBERG:  Then 224 quickly is an E-Mail
          23         that --
          24    BY MR. WEINBERG:
          25         Q    Is this a posting or E-Mail, 224, Mr. Prince?
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           1         A    I have no idea.
           2         Q    Well, this is something that you --
           3         A    There is no "to".
           4              THE COURT:  It says it is from you.
           5              THE WITNESS:  Yes, is this a note to myself?  I
           6         don't know what it is.
           7    BY MR. WEINBERG:
           8         Q    Do you recognize this as something that you did?
           9              THE COURT:  Who is Mark?  I know there is a
          10         Mark.
          11              THE WITNESS:  You know, there are lots of
          12         Marks.
          13    BY MR. WEINBERG:
          14         Q    I think it is pretty clear, the message at the
          15    bottom is a Mark Bunker passage.  Then --
          16         A    The message at the bottom?  Oh, I see what you are
          17    saying.
          18         Q    Do you see?
          19         A    Okay.
          20         Q    And my question to you is, your advice was, "With
          21    regard to the Lisa McPherson Trust, contact Ken Dandar."
          22    That is what it says, correct?
          23         A    Absolutely not.
          24         Q    That is not what it says?
          25              MR. DANDAR:  I'll object.  It doesn't say that,
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           1         either.
           2         A    No.
           3    BY MR. WEINBERG:
           4         Q    Are you saying, "In the meantime, I recommend you
           5    contact U.S. attorney Kennan G. Dandar," and give his E-Mail
           6    address?
           7              THE COURT:  What is the date on that?
           8              MR. WEINBERG:  It is November 10, 1999.
           9              THE COURT:  Before the trust was formed?
          10              MR. WEINBERG:  Right -- well, the trust
          11         actually had already been formed, remember, it was
          12         incorporated and it was in the process of being set
          13         up.
          14         A    You know, this is a partial thing here from Mark.
          15    I can't tell if somebody wrote in and had a legal question
          16    and I'm referring them to Ken Dandar, who is a lawyer that
          17    could maybe answer a legal question for them, or whether or
          18    not they need assistance or the service the trust has to
          19    offer.  I can't tell from this.  I can't draw the inference
          20    that somehow this means Ken Dandar is running the Lisa
          21    McPherson Trust or anything like that.
          22              MR. WEINBERG:  I move it into evidence, your
          23         Honor.
          24              MR. DANDAR:  I object.  It is too partial to
          25         make sense.
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           1              THE COURT:  I'm going to let it in for whatever
           2         value it has, which is little, as to a lot of the
           3         other E-Mails, because of the same problem.
           4              MR. WEINBERG:  So is this a good time to take a
           5         break?
           6              THE COURT:  It is a good time to take a break.
           7         We'll be in recess for 15 minutes.  I show it is 25
           8         till.  That will be about ten till.
           9              MR. WEINBERG:  Okay.
          10     (WHEREUPON, a recess was taken from 10:35 to 10:55 a.m.)
          11             _______________________________________
          12              THE COURT:  Okay.  I signed the order and I
          13         mailed out the copies.  But those of you who are
          14         here, I'll give you yours.  Mr. Dandar.  Here is
          15         Mr. Lirot's, too.  I didn't realize he wasn't here.
          16         Mr. Moxon, Mr. Lieberman, Mr. Fugate.  Always trying
          17         to save you all some stamp money.
          18              MR. WEINBERG:  Everything counts.
          19              THE COURT:  Every little bit counts.  That is
          20         right.
          21              You may continue.
          22              MR. DANDAR:  I returned the envelopes to
          23         opposing counsel.
          24              THE COURT:  All right.  Thank you.
          25              MR. DANDAR:  So they can save their stamps.
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           1    BY MR. WEINBERG:
           2         Q    Now, Mr. Prince, you first learned about Bob
           3    Minton after watching a television show Dateline in which he
           4    appeared and Ms. Brooks appeared in June of '98?
           5         A    That is incorrect.
           6         Q    Did you watch a television show before you met
           7    Mr. Minton where you learned about him?
           8         A    No, I did not.
           9         Q    How did you learn about Mr. Minton?
          10         A    Through Mrs. Brooks.
          11         Q    So she just reached out for you, you didn't reach
          12    out for her?
          13         A    Well, Mr. Weinberg, I think I spoke on this before
          14    but I'll speak on it again.
          15              I was on vacation in Connecticut.  I had been in
          16    the cyber coffee cafe.  I had gone on the Internet.  Do you
          17    remember that testimony, Mr. Weinberg?
          18              THE COURT:  It was rather elaborate.
          19         A    I left my phone number and she called me.
          20              (Telephone interruption.)
          21    BY MR. WEINBERG:
          22         Q    Did you ever see the Dateline --
          23              THE COURT:  Don't be sorry to him.  Be sorry to
          24         me.  It is my word that says no phone.
          25              THE WITNESS:  I'm sorry, I apologize for the
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           1         distraction.
           2    BY MR. WEINBERG:
           3         Q    Did you ever see the television show The Crusader,
           4    I think on NBC Dateline, where Mr. Minton was featured about
           5    his crusade against Scientology?
           6         A    Mmm, more than likely, many months to possibly a
           7    year after he had done that program, I'd seen it.  But I
           8    didn't see it when it ran on national television.
           9         Q    Well, you learned, shortly after your call from
          10    Ms. Brooks, that Mr. Minton was a very wealthy person who
          11    was handing out a lot of money to people that would work
          12    against Scientology, correct?
          13         A    That is categorically false.
          14         Q    Ms. Brooks didn't tell you that Mr. Minton had
          15    given her and Vaughn a lot of money, including the purchase
          16    of a $250,000 home?
          17         A    At one point in time Mrs. Brooks did relay the
          18    information that Mr. Minton had given her and her husband
          19    some money and she explained the circumstances about that.
          20         Q    Did a relative tell you about the Dateline show
          21    featuring --
          22              THE COURT:  A relative of whom?
          23    BY MR. WEINBERG:
          24         Q    A relative of yours tell you about -- in or about
          25    this time period before you met Mr. Minton -- did a relative
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           1    tell you about having seen this show where Mr. Minton was
           2    featured or some friend or some family member?
           3         A    A cousin of mine, when I lived in -- I guess I
           4    must have been still living in Minneapolis and we were in a
           5    phone conversation.  And she was telling me about a program
           6    where she had seen -- she had seen concerning Scientology
           7    and there was a man that was helping people or somehow got
           8    involved in it.  She didn't remember his name.  She just
           9    remembered -- and, you know, as it is with my family, if
          10    they see something about Scientology on TV, they tell me
          11    about it when I speak to them.
          12         Q    Was that before you communicated with Ms. Brooks?
          13         A    I believe it was.
          14         Q    So when you learned about Ms. Brooks, you already
          15    knew about Mr. Minton?
          16         A    As I said, she didn't know Mr. Minton's name.  All
          17    she related was, "I saw a story on TV about Scientology and
          18    the different things that they do.  And there was a man that
          19    was helping people that had been in Scientology before."
          20         Q    And did you research, prior to hearing from
          21    Ms. Brooks, did you research to learn who this guy was and
          22    what he was doing for people who had been in Scientology?
          23         A    No.  I had not.
          24         Q    Now, when did you learn, after communicating with
          25    Ms. Brooks, how wealthy Mr. Minton was?
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           1         A    When I spoke to him.
           2         Q    And how long after you talked to Ms. Brooks did
           3    you talk to Mr. Minton?
           4         A    Mmm, maybe a month.  Maybe two months.
           5         Q    So I was under the impression that on this trip --
           6    I guess I'm wrong -- this trip to Connecticut, that you went
           7    from Connecticut right up to Mr. Minton's house after
           8    talking to Ms. Brooks?
           9         A    No, that is incorrect, Mr. Weinberg.
          10         Q    So you went home after that?
          11         A    Correct.
          12         Q    And you stayed in touch --
          13         A    Oh, no, no, I'm sorry, you know, because it is so
          14    important to make sure the record is correct.  From
          15    Connecticut, I flew to Ohio and met with Mrs. Brooks and
          16    Mr. Haney.
          17         Q    And was it at that time that you were given a new
          18    car?
          19         A    No.  No.  It was not.  And I was never given a new
          20    car by anyone.
          21         Q    Somebody purchased it?  Mr. Minton purchased a new
          22    car for you or caused a new car to be purchased for you?
          23         A    No.  That is incorrect.
          24         Q    Well, how did you get the $23,000 Rodeo vehicle?
          25         A    I never got a $23,000 Rodeo.  I had use of a
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           1    $23,000 Rodeo but that $23,000 Rodeo belonged to FACTNet,
           2    and when I terminated my employment with them, that car
           3    stayed with FACTNet.  You understand?
           4         Q    Now, that was purchased where, the car?
           5         A    In --
           6              THE COURT:  Where like what dealer?  What city?
           7    BY MR. WEINBERG:
           8         Q    What city?  What city?
           9         A    You know, I don't remember the name of the city.
          10         Q    But it was in Ohio, that area, either Minneapolis
          11    or Ohio, correct?
          12         A    Correct.
          13         Q    And did --
          14         A    Well, wait a minute.  Let me not do this thing
          15    because you accused me of this earlier.  It was in
          16    Minneapolis specifically.  I know the specific answer.  I'm
          17    not going to play charades here with you.  It was in a place
          18    near Minneapolis, a city that was near Minneapolis, and I
          19    don't specifically recall the name of the city.
          20         Q    And it was purchased new, is that correct?
          21         A    Yes.
          22         Q    And you and who went to pick it up at the dealer?
          23         A    Mmm, a friend of mine -- Mmm -- took me -- drove
          24    me to the dealership to pick it up.
          25         Q    And did you have a check with you?  How was it
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           1    paid for?
           2         A    No.  I didn't have a check.
           3         Q    Ms. Brooks took care of paying for the car?  Is
           4    that what happened?
           5         A    No.  Ms. Brooks did not -- well, you know, I don't
           6    think so.  But quite factually, I don't know who -- how that
           7    part of it happened.
           8         Q    There just happened to be a new car waiting for
           9    you at the dealership?
          10         A    No.  They needed a vehicle for FACTNet.  You know,
          11    let me -- if you have patience with me, I'll tell you the --
          12    what happened there.
          13              They needed a car in Boulder --
          14         Q    Boulder, Colorado?
          15         A    Boulder, Colorado, which is where FACTNet was
          16    located.  I was going to FACTNet to assist in that
          17    organization.  The car was purchased.  I moved everything
          18    that I had in Minneapolis and moved to Boulder, Colorado.  I
          19    made that move to at least be safe or -- or to be around
          20    some people that could offer some protection to me, because
          21    after I'd contacted Mr. -- Mr. Minton, the private
          22    investigators started, the threatening letters to sue me
          23    from Scientology started.  And I was alone in Minneapolis,
          24    and it was like, "Okay, come here, we'll help you, we'll
          25    protect you, we have lawyers," whatever.
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           1         Q    You were alone and bankrupt in Minneapolis, right?
           2         A    I had filed bankruptcy in 1997.  I think the year
           3    we're talking about now is 1998.
           4         Q    June of 1998.  Bankruptcy in November of 1997,
           5    right?  Your next real job after bankruptcy was to be paid
           6    by FACTNet and Mr. Minton, correct?
           7         A    That is completely false.
           8         Q    Now --
           9         A    You want to know what my next job was or you just
          10    want to leave it like that.
          11         Q    Tell me what your next job was.
          12         A    I was self-employed.  I had an art business called
          13    The Art Guy.  I had a kiosk in the mall in downtown
          14    Minneapolis.  I was making my own money and I was actually
          15    doing pretty good for myself.
          16         Q    But something encouraged you, prompted you, to
          17    pick up and leave Minneapolis and move to Boulder, Colorado,
          18    at which time you became associated with FACTNet and started
          19    being a paid witness in various Scientology cases, correct?
          20         A    I think you have added a little bit of baggage on
          21    that.  But what actually occurred is I left Minneapolis with
          22    my business intact.  I had employees in Wisconsin and
          23    employees in Minneapolis, and I left and went to Boulder,
          24    Colorado.
          25         Q    Driving this car?
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           1         A    Correct.
           2         Q    And you drove this car for how long?  How many
           3    months did you drive this new car that somebody paid for
           4    that you picked up new?
           5         A    Off and on, maybe about three months.
           6         Q    Now, after -- but before you moved to Boulder, you
           7    went to New Hampshire to visit Mr. Minton?
           8         A    Yes.
           9         Q    And you and who went to New Hampshire to visit
          10    Mr. Minton?
          11         A    It was just myself.
          12         Q    And he flew you to New Hampshire?
          13         A    I -- I believe the way the scenario worked is
          14    Mrs. Brooks arranged flight -- airfare, the flight, for me
          15    to fly there, yes.
          16         Q    Much like she had arranged the car to be
          17    purchased?
          18         A    I think we're mixing apples and oranges here
          19    because I think I stated earlier in the testimony I'm not
          20    quite sure who did that on behalf of FACTNet.  That car was
          21    purchased in FACTNet's name.  It was never in Jesse Prince's
          22    name, Bob Minton's name, Stacy Brooks's name.  It was a
          23    corporate car.  That is the way it was purchased and that is
          24    the way it was left.
          25         Q    And the person that was financing FACTNet at the
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           1    time was Bob Minton?
           2         A    Mmm, no.
           3         Q    Did Mr. -- one last question about the car.  Did
           4    Mr. Haney provide the funds for the car, Brian Haney?
           5         A    Not that I'm aware of.  But then again, I don't
           6    know the details of it.  I know that -- I think Mr. Haney
           7    did have some association with FACTNet at the time.
           8         Q    And what were you seeing Mr. Haney in Ohio about
           9    with Ms. Young?
          10         A    I mean, I had never known Mr. Haney.  I didn't
          11    know who he was.  He just happened to be there.  I was there
          12    to visit with Stacy.
          13              The visit with Stacy -- her and I have been
          14    associated -- associated and friends through Scientology
          15    since 1976.  She was one of the very first persons that I
          16    met when I joined the Sea Org.  And we were just happy to
          17    see each other.  Her ex-husband, Vaughn Young, and I were
          18    very good friends.  You know, he was an executive and we
          19    were friends, and it was -- and from leaving Scientology --
          20    because when you leave and you are ostracized, people
          21    disconnect from you; you are a suppressive person, degraded
          22    being, whatever, you don't have any friends anymore.  But to
          23    actually encounter someone from Scientology that you knew
          24    before that will talk to you because you are not a
          25    Scientology is a rare thing.
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           1         Q    Now, the Youngs left in 1989, correct?
           2         A    Yes, I assume that, yes.
           3         Q    You left in 1992?
           4         A    Yes.
           5         Q    But you didn't communicate with the Youngs until
           6    Mr. Minton came on the scene in 1998, after you left
           7    Scientology, correct?
           8         A    I think that is a mischaracterization of my
           9    earlier testimony, Mr. Weinberg.  Because I think the way I
          10    testified, and again I'll go through the whole thing --
          11         Q    No, just answer that question.
          12         A    But I wrote an E-mail from a cybercafe that said,
          13    "If you know Vaughn Young or Stacy Brooks, please give them
          14    my phone number."  Mr. Minton was not part of the equation.
          15         Q    My question was you didn't have any communication
          16    with Vaughn or Stacy Young after you left Scientology in
          17    1992 until this cybercafe thing in 1998?
          18         A    Correct.
          19         Q    As far as you know, they didn't reach out for you
          20    prior to that time, either, is that correct, as far as you
          21    know?
          22         A    As far as I know.
          23         Q    Now, Stacy Young must have told you, when you were
          24    in Ohio with her and Brian Haney, she must have told you
          25    about the activities that she and Vaughn, her husband, had
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           1    been involved in for the past four years concerning cases
           2    involving Scientology.  She told you about that, didn't she?
           3         A    In our first meeting?
           4         Q    When you --
           5         A    Oh, when I went to Ohio?  Are you talking about
           6    the Ohio trip?
           7         Q    Yes.
           8         A    There may have been a brief mention of that, what
           9    she was doing.  But for sure the substance and the bulk of
          10    our conversation was the fact that we were together, we were
          11    alive, we actually made it out somewhat sane people and we
          12    were just happy to see each other.
          13         Q    Did she tell you she and her husband had been
          14    making a living off testifying and being experts in cases
          15    against Scientology for the past three or four years?
          16         A    No, she did not.
          17         Q    Did she tell you you had a good opportunity to --
          18    to get in on the gravy train, so to speak?  Did she tell you
          19    that?
          20         A    I take offense to that characterization.  But that
          21    statement is categorically false.
          22         Q    Did she tell you that you had the opportunity to
          23    make money by being -- by working with lawyers in cases
          24    involving Scientology?  Did she tell you that?
          25         A    No, she did not.
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           1         Q    So you didn't have any discussion about you
           2    getting involved in any of these cases?
           3         A    At that point in time in Ohio, no, we did not.
           4         Q    There came a point in time where you did talk to
           5    Stacy about that?
           6         A    Yes.
           7         Q    And when was that?
           8         A    Mmm, I'm not quite sure.  It was maybe some months
           9    later or -- I'm not quite sure.  But I think while we were
          10    talking she was telling me about FACTNet.  She was telling
          11    me about this organization which, in some respects, was
          12    similar to the Lisa McPherson Trust which had as its
          13    intention of providing information and doing what it can to
          14    assist people or persons who felt they had been victimized
          15    by Scientology.
          16              And --
          17              THE COURT:  Was FACTNet just Scientology or was
          18         it cults in general?
          19              THE WITNESS:  Cults in general, you know, the
          20         whole subject.  Very broad.
          21    BY MR. WEINBERG:
          22         Q    It was primarily Scientology, though, wasn't it?
          23         A    No.  If you go on their website, you know,
          24    Scientology has its place, but there are many other cults
          25    that they have provided information, ex-members speaking
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           1    about it, you know.
           2         Q    Well, the staff members of FACTNet tended to be
           3    people that were more interested in Scientology or had had
           4    some involvement with Scientology as opposed to other
           5    groups.  Correct?
           6         A    No.  That is actually false.  There was one person
           7    that was a staff -- that was a staff member in FACTNet, I
           8    think her name was Justine.  She was a Christian woman that
           9    had never been in Scientology before.
          10         Q    You are telling me so you learned about how you
          11    could make some money involving Scientology from Ms. Brooks.
          12    So when did that happen?
          13         A    You know, I --
          14              THE COURT:  Make some money involving
          15         Scientology?  That doesn't make sense.
          16    BY MR. WEINBERG:
          17         Q    Who was the first person that told you --
          18    suggested to you that you might be -- you might be a witness
          19    and could be paid as a, quote, expert on Scientology?  Who
          20    told you that?
          21         A    No one told me that, Mr. Weinberg.
          22         Q    Who asked you to be involved in the first case
          23    that you got involved in?
          24         A    Mr. Leipold.
          25         Q    He just reached out for you?
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           1         A    He was an associate of Mrs. Brooks.  Mrs. Brooks
           2    was explaining to me about FACTNet.  And the whole subject
           3    came about because we were talking about being in touch with
           4    people that we had lost contact with, old friends that were
           5    in Scientology.  So she was introducing me, "Well, you know,
           6    another person, you know, people from Los Angeles, hey, do
           7    you know this one?  He's out."  And Andre Tabayoyon, I think
           8    I spoke with him.  We were just talking about the people
           9    that we knew in Scientology that were no longer there that
          10    were out, you know, getting on with their lives, doing what
          11    they do.
          12         Q    What were you doing in Ohio with Mr. Haney and
          13    Ms. Brooks?  I mean, why Ohio?  You live in Minneapolis.
          14    She lived in Seattle.  Why were you in Ohio?
          15         A    That is where she was when she called me.  And I
          16    was in Connecticut and she was in Ohio.
          17         Q    Is there something special in Ohio?
          18         A    I think that is where Mr. Haney lives.  She was in
          19    Columbus, Ohio.  That is where Mr. Haney lives.
          20         Q    You went to New Hampshire.  How did you get in
          21    touch with Mr. Minton?  Did you call him?  He call you?
          22         A    I think I answered this before.  This happened
          23    through Mrs. Brooks.  I met Mrs. Brooks, and then I had --
          24    you know, sometime after that I spoke to Mr. Minton on the
          25    phone and maybe a month or two later actually went to visit
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           1    with him.
           2         Q    He flew you to New Hampshire --
           3              THE COURT:  He said he didn't know who paid for
           4         the ticket.  We can assume it was Mr. Minton,
           5         directly or indirectly.
           6              MR. WEINBERG:  Right.
           7    BY MR. WEINBERG:
           8         Q    Somebody arranged for you to fly to New Hampshire,
           9    right?
          10         A    Stacy Brooks.
          11         Q    All right.  But she wasn't at this weekend -- was
          12    it a weekend?
          13         A    Actually a couple weeks.
          14         Q    You were at Mr. Minton's house for a couple weeks?
          15         A    Yes.
          16         Q    Who else was there other than you and Mr. Minton?
          17         A    His family would come occasionally.  His wife.
          18    His children.
          19         Q    And anybody -- I mean, other than his family,
          20    anybody else?
          21         A    No.
          22         Q    What did you-all -- did you talk about Scientology
          23    in those two weeks?
          24         A    Yes, we did.  We talked about Scientology.  We
          25    talked about why -- why he became involved.  What this was
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           1    all about.  He was very interested to know my involvement,
           2    my history, compared to other people that he had talked to.
           3    And again, this is all in reference to, hey, you know, these
           4    ex-people, these people that used to be in and now they are
           5    not in and now they're getting together and talking to each
           6    other and it is okay to do that.
           7         Q    And did he give you some money, some expense money
           8    at that point, either before the trip or during the visit or
           9    after the trip?
          10         A    No.  No.  I don't think so.
          11         Q    Did he pay for your expenses to move from
          12    Minneapolis to Denver?
          13         A    Yes.
          14         Q    And --
          15              MR. DANDAR:  I object because we have got to
          16         establish a time frame here.  It sounds like it all
          17         happened on the same day.
          18              THE COURT:  That is true.  Whatever the time
          19         frame is, I don't think it all happened on the same
          20         day.
          21              MR. DANDAR:  All right.
          22         A    It didn't.
          23    BY MR. WEINBERG:
          24         Q    It didn't.  I'm not suggesting that.  Do you
          25    remember how much he gave you to move from Minneapolis to
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           1    Denver?
           2         A    Mmm, $10,000.
           3         Q    In a check?  Cash?  I mean, how did you get the
           4    money?
           5              THE COURT:  What difference does it make?
           6              MR. WEINBERG:  Probably not.
           7              THE COURT:  It doesn't make any difference.
           8              MR. DANDAR:  Right.
           9    BY MR. WEINBERG:
          10         Q    Where did you get the money?  I mean, did this
          11    happen in New Hampshire?  Or did it happen after the trip to
          12    New Hampshire that he gave you the $10,000?
          13         A    You know, I'm not sure because, you know, I made a
          14    couple of trips to New Hampshire.  So I'm not really sure
          15    how that came about.  But I'll do the best I can to explain
          16    it to you, Mr. Weinberg.
          17              I went there once, I stayed there for a couple of
          18    weeks, came back to Minneapolis.  The threats started.  I
          19    was starting to get letters from Elliot Abelson, Scientology
          20    attorney in Chicago, letting me know I would be sued.  I had
          21    private investigators starting a noisy investigation in my
          22    neighborhood.  And I think I alerted Mr. Minton and
          23    Mrs. Brooks, I said, "Look, I can't believe this whole thing
          24    is starting all over again."  You know -- you are right, I
          25    did do the bankruptcy thing.  I cut ties with Scientology
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           1    completely.  I was done with it.  I didn't want another
           2    thing to do with it.  You know, it is kind of like every
           3    time you put your hand in the fire, you know you are going
           4    to get burned.  I was done.
           5         Q    You were done but then you decided to get involved
           6    in cases against Scientology?
           7         A    Then I went to meet these people and my freedom of
           8    association was trying to be inhibited from Scientology --
           9    by Scientology.  They didn't want me to associate with these
          10    people.  There were no -- no criminal activity occurred,
          11    nothing happened.  I'm simply talking to people that used to
          12    be in Scientology.
          13         Q    All I asked you, did you get the money from
          14    Mr. Minton during your trips to New Hampshire or after.
          15    That is all I asked, and if you don't remember just --
          16         A    In one of the trips.
          17         Q    -- just tell me you don't know.
          18         A    In one of the trips, Mr. Weinberg, I did get the
          19    money from him to move.
          20         Q    Now, did Mr. Minton tell you that he would, in
          21    essence, take care of you thereafter to support you with
          22    regard to your work involving Scientology?
          23         A    No, he did not.
          24         Q    But in reality, that is what happened for the next
          25    four years, didn't it?
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           1         A    No, it is not.
           2         Q    Well, you began to get money from Mr. Minton after
           3    this first $10,000, correct?  I mean, from that point on for
           4    the next four years you received money, directly or
           5    indirectly, from Bob Minton on a monthly basis, didn't you?
           6         A    Mr. Weinberg, I received money from FACTNet when I
           7    started working for FACTNet, when I moved from Minneapolis
           8    to Boulder, Colorado.  I started to receive some -- and very
           9    little from FACTNet.  The fact of the matter is that I was
          10    able to live and do what I was doing because I had been -- I
          11    had my own business, I had staff working for me in two
          12    states.  I was receiving regular moneys from profits that I
          13    had made.  And this was where the bulk of my money was
          14    coming from.
          15         Q    So you had all these profits that you had
          16    accumulated after the November bankruptcy between November
          17    and June of '98?
          18         A    Correct.
          19         Q    Okay.  Now, you got the $10,000 from Mr. Minton.
          20    And how much money do you remember that you received from
          21    FACTNet?
          22         A    Maybe a couple of thousand.  You know, one month.
          23    A thousand another.  You know, it was kind of back and
          24    forth.
          25         Q    And then you came -- then, shortly after this, you
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           1    came to Florida in the fall of 1998 to begin work with
           2    regard to the PC folders in this case.  Correct?  You flew
           3    to Florida?
           4         A    Correct.
           5         Q    And you spent how many days with Ms. Brooks
           6    reviewing the PC folders of Lisa McPherson in the fall of
           7    '98?
           8         A    You know, I'm not sure, but it was like many days,
           9    maybe even more than a week.  And it was something I came
          10    back to, as well, and participated in getting the folders
          11    copied.  So this whole thing with the folders started in
          12    December but it went through a period of time, a month's
          13    period of time of going through those folders.
          14         Q    So at that point when you first came you were now
          15    officially on board as an expert for Mr. Dandar in the Lisa
          16    McPherson matter, correct?
          17         A    I -- I wouldn't say that.  The reason why
          18    Mr. Dandar wanted me to go through those folders is because
          19    of my expertise in Scientology, my prior technical
          20    experience, the many courses and certificates and
          21    internships I had finished.
          22              THE COURT:  Were you his consultant, as well?
          23              THE WITNESS:  Not at that time.  I just came
          24         down to do the preclear folders.  Mr. Dandar and I
          25         did not have a relationship because we didn't know
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           1         each other.  And through time -- and he could see my
           2         competence in interpreting Scientology policies and
           3         bulletins -- that I then became a consultant and
           4         worked more closely with him on the case.
           5    BY MR. WEINBERG:
           6         Q    Well, at the time -- when you were reviewing these
           7    folders it was in Mr. Dandar's office?
           8         A    Yes.
           9         Q    And you had -- you met with Mr. Dandar at that
          10    period of time?
          11         A    Yes.
          12         Q    I mean, you introduced yourself to him and all
          13    that?
          14              THE COURT:  Well, Counsel, come on.
          15    BY MR. WEINBERG:
          16         Q    Did you bill him for your time?
          17         A    No.
          18         Q    You just did this for free?
          19         A    Yes.  And I had done it for free many times.  I
          20    mean, I have worked for Morrison & Foerster, and Feaster
          21    from -- out of San Francisco in a legal case.  I worked for
          22    Mr. Leipold in a legal case.  I worked for Mr. Dandar.  I
          23    mean, by that time I had been working with these different
          24    attorney firms or at least they had been calling me to see
          25    if I could assist them in these other legal cases.
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           1         Q    Well, who was paying you to be in Tampa, St. Pete,
           2    wherever it was, that you were to work with Mr. Dandar and
           3    Ms. Brooks with regard to this case in the fall of 1998 and
           4    early 1999 when you were going through these PC folders?
           5         A    Again I'll say that my expenses to fly down to
           6    Florida, I believe, was paid by Mr. Dandar.  The money that
           7    I used to exist for that period of time, I think we're
           8    talking about maybe six months, for the most part -- for the
           9    greater majority of it were residuals from the business I
          10    operated in Minneapolis.
          11         Q    Well, didn't Mr. Minton give you checks in early
          12    1999, $5,000, $6,000 a month?
          13         A    No.
          14         Q    He didn't do that?
          15         A    He may have did it a time or two but it wasn't
          16    consistent.  And FACTNet was a very small organization.  It
          17    sometimes just didn't have money.  And my -- you know, and
          18    this was kind of like a period of time like where how do you
          19    fit in?  So, you know, I would occasionally tell Mr. Minton,
          20    "Hey, you know, these people don't have money.  I can't live
          21    on air here.  Can you help out?"
          22         Q    Well, why Mr. Minton?  Why not Mr. Dandar who you
          23    were doing the work for?
          24         A    Because I was working on FACTNet now, you know.
          25    We're mixing apples and oranges here.  FACTNet was a
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           1    corporation that Mr. Minton was on the board of directors
           2    of.
           3         Q    Well, I thought -- correct me if I'm wrong, I
           4    thought I heard you say that starting in the fall of 1998,
           5    into 1999, you spent a number of days, weeks, whatever,
           6    working on this case, the Lisa McPherson case?
           7         A    Well, hold on, hold on, hold on.  I never even met
           8    Mr. Dandar until 1999.  So let's leave 19 --
           9         Q    How can you say that?  You just said you were in
          10    his office in the fall of 1998 looking at the PC folders?
          11         A    Wait -- okay.  Well, okay, I'm confused with the
          12    dates.  So --
          13              THE COURT:  So what is the right date?
          14              THE WITNESS:  I don't know.  I mean, was it
          15         1998?
          16              THE COURT:  That is fine.  I told you and I'll
          17         tell you again and it is really a wonderful answer,
          18         you know, 1997, '98, '99, there could be a lot of
          19         these dates you simply don't know, and there is
          20         nothing wrong with saying, "I'm not sure what the
          21         date was.  I don't know for sure."
          22              THE WITNESS:  Thank you, your Honor.
          23         A    Mr. Weinberg, I don't know.  I don't recall for
          24    sure.
          25
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           1    BY MR. WEINBERG:
           2         Q    Now, when did you become the expert/consultant in
           3    the Lisa McPherson case?
           4         A    I believe that I got a letter from Mr. Dandar
           5    quite possibly in March of 1999 that memorialized the fact
           6    that he wanted to hire me to be his consultant.  We had had
           7    a working relationship at that point because I helped him a
           8    lot and I -- and --
           9              THE COURT:  You know, I haven't heard a date
          10         yet.  When is the question?
          11         A    March of '99.  I think that is when we formed an
          12    agreement and decided on terms.
          13    BY MR. WEINBERG:
          14         Q    All right.  Prior to March of '99, in the months
          15    prior to March of '99, you had done a lot of work assisting
          16    Mr. Dandar with, for example, PC folders, correct?
          17         A    Correct.
          18         Q    So whether that started in November or December of
          19    '98, it was sometime several months before March of '99 when
          20    you signed on as the expert.  Right?
          21         A    Yes.
          22         Q    And --
          23         A    To the best of my recollection.
          24         Q    And prior to signing on as the expert, can you
          25    tell us how much time you had spent down here helping out
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           1    Mr. Dandar before you signed on as the expert?
           2         A    I'm sorry, I can't tell you how much time it was.
           3         Q    Okay.  Now, once you signed on with Mr. Dandar,
           4    then was it established that you were on a monthly salary?
           5         A    Mmm, I think the letter that memorializes that
           6    agreement, I was on a monthly retainer of $5,000 a month and
           7    my billable hours which I believe was either $100 or $150 an
           8    hour.
           9         Q    If you exceeded the $5,000?  Or is it in addition
          10    to the $5,000?
          11         A    The $5,000 retainer, and the hours against that,
          12    plus any other hours if I put in more hours or whatever.
          13         Q    But you didn't keep your hours, we established --
          14    remember we established that in front of Judge Moody that
          15    you didn't keep your hours.  Right?
          16         A    Well, no, in the beginning I didn't.  And again,
          17    Mr. Weinberg, there was nothing to keep prior to that
          18    because I had just literally done the work for free.
          19         Q    Well, we have asked for your hours as part of the
          20    various discovery, and it came up in the Judge Moody hearing
          21    when you testified in front of Judge Moody and your
          22    testimony was, I believe, that either you didn't keep them
          23    or you didn't have them.
          24         A    Right.  I didn't have accurate records.  I didn't
          25    have any notes to turn over or -- no.
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           1         Q    So what you got paid by Mr. Dandar was $5,000 a
           2    month because you didn't keep the time in order to get
           3    anything in addition to that.  Correct?
           4         A    Well, you see, we're mixing apples and oranges
           5    here again now.  Because I think, you know, you talk about
           6    that time period from 1998 to --
           7              THE COURT:  I'm -- he's talking about the time
           8         period from March of '99 when you were placed on a
           9         $5,000-a-month retainer, was it $100 or $150 an hour
          10         again that -- which was it?
          11              THE WITNESS:  I'm not sure, I think it may have
          12         been $150, actually.
          13              THE COURT:  Let's assume it was $150 an hour.
          14         Basically how that works, if you go over, whatever
          15         $150 into $5,000 is, then you get more, but if you
          16         get less, you still keep the five.
          17              THE WITNESS:  Yes.
          18              THE COURT:  Was that the deal?
          19              THE WITNESS:  Yes.
          20              THE COURT:  So you didn't keep records,
          21         apparently?
          22              THE WITNESS:  No.
          23              THE COURT:  You were paid $5,000 a month?
          24              THE WITNESS:  Yes.
          25              THE COURT:  For whatever -- for however many
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           1         hours you worked?
           2              THE WITNESS:  Yes.
           3    BY MR. WEINBERG:
           4         Q    We'll show you the checks, but that continued up
           5    until -- your recollection is that continued to a particular
           6    point in time, I believe the records will show, May of 2000
           7    when you left Mr. Dandar's payroll and went on LMT's
           8    payroll.  Correct?
           9         A    My reference point for that, Mr. Weinberg, is that
          10    we had finished the depositions of all of the Scientology
          11    persons that needed to be deposed.  And Mr. Dandar was going
          12    to go on to --
          13              THE COURT:  Well, is that correct?  Is that the
          14         date?  I mean, all he wants to know --
          15    BY MR. WEINBERG:
          16         Q    All I want to know --
          17         A    I don't know if that is the right date.  I'm
          18    saying my reference is this --
          19         Q    At some point, and we'll show you the checks, I'm
          20    representing to you I think the last Dandar check is May of
          21    '99 -- or May of 2000.  At some point in time you quit
          22    getting Dandar & Dandar checks and you started getting LMT
          23    checks?
          24         A    Correct.
          25         Q    And LMT continued to pay you at $5,000 a month?
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           1         A    Correct.
           2         Q    The same $5,000 -- the same amount.  And you
           3    negotiated that rate with Mr. Minton?
           4         A    And Mrs. Brooks.
           5         Q    Now, and then the LMT at some point -- you
           6    testified about either yesterday or the day before -- closed
           7    down, correct?
           8         A    Correct.
           9         Q    And whenever that was, your recollection it was
          10    sometime in August or September of 2001.  Right?
          11              THE COURT:  When was the date?  When was the
          12         date?
          13              MR. WEINBERG:  That I don't know exactly.  I
          14         mean, it depends on -- I mean, I'm really asking
          15         Mr. Prince.
          16    BY MR. WEINBERG:
          17         Q    I believe that you, Mr. Minton and Ms. Brooks said
          18    it was sometime in the August/September of 2001 time period,
          19    is that correct?
          20         A    Mr. Weinberg, my recollection is I think it ceased
          21    to exist as a corporation -- I think there was something
          22    that Stacy wrote.  But again as I testified to yesterday,
          23    there was that period of time when Judge Beach still had to
          24    come into the trust in order to go through all of the
          25    offices, the library, looking for discovery, so in effect it
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           1    was kind of forced to stay open longer after that.
           2         Q    Well, we'll show you the checks.  But the records
           3    from LMT --
           4              THE COURT:  If you have got the checks,
           5         wouldn't it make a lot more sense to show him, then
           6         I wouldn't have to listen to this?
           7              MR. WEINBERG:  Right.  I will.
           8              THE COURT:  What you said yesterday was even
           9         after it closed down there was a period of time when
          10         you were working and you got paid for that, too, is
          11         that right?
          12              THE WITNESS:  Yes.
          13              THE COURT:  Whatever the checks show, the
          14         checks show.
          15    BY MR. WEINBERG:
          16         Q    And then at some point you quit getting LMT
          17    checks, right?
          18         A    Correct.
          19         Q    And -- but Mr. Minton continued to pay you.
          20    Right?
          21         A    No.  That is incorrect.  Mrs. Brooks did.
          22         Q    You knew that Mrs. Brooks was getting the money
          23    from Mr. Minton.  Right?
          24         A    Well, you know -- come on.
          25         Q    Come on yeah?
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           1         A    Do I need to assume that for you to make a point?
           2    The answer to the question is I was being paid by
           3    Mrs. Brooks.  Her name is on the check.  It is to me.  That
           4    is it.
           5         Q    All right.  And that was at $5,000 a month, as
           6    well?
           7         A    Correct.
           8         Q    And who did you negotiate that deal with?
           9         A    Mrs. Brooks.
          10         Q    And did you talk to Mr. Minton about it?
          11         A    No.  I specifically talked to Mrs. Brooks about it
          12    because she wanted everyone to take a cut in pay.  And,
          13    again, this constant figure of $5,000 is something that we
          14    had discussed many years earlier.
          15         Q    "We" being?
          16         A    Mrs. Brooks, Mr. Minton.  This is what I need to
          17    be able to live.
          18         Q    So --
          19         A    This is comparable to what I was making before I
          20    came and started doing this.  I --
          21         Q    I'm sorry, before you ever signed on with
          22    Mr. Dandar, you had already discussed with Mr. Minton and
          23    Ms. Brooks that you needed $5,000 a month to live, correct?
          24         A    Correct.
          25         Q    And is that what you're getting paid at FACTNet,
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           1    as well?
           2         A    No.
           3         Q    Now, when you started getting these checks -- they
           4    were checks, right, from Ms. Brooks, you were still living
           5    in Clearwater.  Right?  Or -- or Florida?
           6         A    I'm still living here.  Yes.
           7         Q    And you're living in a house that Mr. Minton gave
           8    you a $50,000 downpayment on.  Correct?
           9         A    That was part of the downpayment that I had to
          10    make.  My total downpayment for that house was $70,000.
          11         Q    How much of that $70,000 did Mr. Minton give you?
          12         A    $50,000.
          13         Q    And when was that?  When did he give you the
          14    $50,000?
          15         A    You know, I guess it was sometime in February.
          16    And, you know --
          17              THE COURT:  If you have the check, show it to
          18         him.
          19              MR. WEINBERG:  I don't have the check, I don't
          20         think.
          21         A    Well, you know, we've said --
          22    BY MR. WEINBERG:
          23         Q    Well, could you just tell me when you bought your
          24    house?
          25              THE COURT:  If he doesn't know, he doesn't
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           1         know.  If you don't know, say you don't know.
           2         A    I know when I bought the house.  I think the 21st
           3    or 22nd of February of 2000.
           4    BY MR. WEINBERG:
           5         Q    And at that point in February of 2000, you were
           6    getting Dandar & Dandar monthly checks as his consultant.
           7    Right?
           8         A    Correct.
           9         Q    All right.  And how did it come about Mr. Minton
          10    gave you $50,000 of the $70,000 that you needed for the
          11    downpayment?
          12         A    You want to hear this?
          13         Q    You asked him for it?
          14              THE COURT:  Go on ahead.  You asked.  He can
          15         tell it.  Go on and rattle off however long this
          16         story is going to take.
          17         A    Prior to moving down to Clearwater, we had
          18    discussed -- had many discussions about, well, where to put
          19    the Lisa McPherson Trust.  We were kicking around this idea
          20    of the LMT, where is it going to go?  Should it be in D.C.,
          21    should it be in Boston, in the Los Angeles area.  Bob said
          22    Clearwater.
          23              We discussed this, David Cecere, myself, I think
          24    Mrs. Brooks, Mr. Minton and there -- there quite possibly
          25    could have been someone else there -- I don't remember -- of
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           1    where to put this thing.
           2              And Mr. Minton really wanted to put it in
           3    Clearwater.  He felt that it was important that it happen in
           4    Clearwater.  Which meant that everyone that was going to
           5    work there would be displaced from where they were currently
           6    living to move here.
           7              Mr. Minton offered to pay the moving expenses for
           8    all concerned and to help all concerned establish residence
           9    in Clearwater.
          10         Q    So he paid your moving expenses which --
          11         A    Correct.
          12         Q    -- included a $50,000 downpayment?
          13         A    No, sir.  That is what was discussed in -- in New
          14    Hampshire, you know, before we moved here.  Ultimately,
          15    Mr. Minton gave me the $50,000 loan to purchase that house,
          16    but I paid for my own moving expenses and I paid -- I mean,
          17    the whole deal cost about $80,000 for me to relocate.
          18    Because I had a place in Memphis.  And by this time I'm kind
          19    of living with -- in Chicago.  By this time I'm kind of
          20    living with my fiancee in Memphis, Tennessee, as well.  So
          21    when I moved down to Clearwater I had to move from two
          22    cities; I had to move from Chicago, I had to move from
          23    Memphis, Tennessee, to Clearwater.
          24         Q    Mr. Minton paid some other things for you.  He
          25    paid your attorney fees in the criminal case down here,
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           1    didn't he?
           2         A    I believe the Lisa McPherson Trust paid those.
           3         Q    Well, did you -- did you discuss with Mr. Minton
           4    that you needed funds to pay an attorney when you got
           5    charged down here?
           6         A    No.
           7         Q    So who did you discuss that with so that the Lisa
           8    McPherson Trust paid for your attorney fees?
           9         A    I wanted to hire a fellow named Rob Love to defend
          10    me in that action.  Mrs. Brooks insisted that Mr. DeVlaming
          11    would handle my case and it would be taken care of by the
          12    Lisa McPherson Trust as a job hazard.
          13         Q    As a job hazard?
          14         A    Yes.
          15         Q    Okay.  And that was around $60,000 or $70,000?
          16         A    The bill that I saw -- I think it was about
          17    $45,000 that I saw.
          18         Q    Do you think it was more than that or you don't
          19    know?
          20         A    I think it could have been more.
          21         Q    Now, how long -- so how would you get these checks
          22    from Ms. Brooks after the Lisa McPherson Trust closed down?
          23         A    She would mail them to me from Atlanta.
          24         Q    The last check you got was on or about April 4 of
          25    2002?
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           1         A    Correct.
           2         Q    And did you have a discussion -- all these
           3    discussions that you had with Ms. Brooks and Mr. Minton that
           4    you have testified about this year, in any of those
           5    discussions did you discuss with them your need for them to
           6    continue paying you?
           7         A    Mmm, no, I haven't had a discussion about that.  I
           8    mean, we -- I think I brought up earlier, in September there
           9    was a renegotiation of -- Stacy wanted people to take pay
          10    cuts or whatever.  And --
          11         Q    But you didn't take one?
          12         A    Correct.
          13         Q    I was talking about April.  In that -- do you
          14    remember you said you had all these conversations, that you
          15    referred to them in your affidavit, with Mr. Brooks -- with
          16    Ms. Brooks and Mr. Minton --
          17         A    Oh, okay.
          18         Q    In those conversations did you raise the fact that
          19    you needed more money, you needed money, you wanted money?
          20         A    No.
          21         Q    Okay.
          22         A    I did not.
          23         Q    Now, you said that you began as the paid
          24    expert/consultant in the Lisa McPherson case in March of --
          25    of 1999.  Correct?
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           1         A    Yes.
           2              MR. WEINBERG:  Now, let me have the reporter --
           3         the clerk --
           4         A    To the best of my recollection.
           5              MR. WEINBERG:  -- mark as a 3-page exhibit, if
           6         we can do that, your Honor --
           7              THE COURT:  Sure.
           8              MR. WEINBERG:  -- some checks.
           9              This will be 225.
          10              THE COURT:  All right.  Do I have the right
          11         order, the way you handed it to me?
          12              MR. WEINBERG:  I think so.
          13              THE COURT:  Okay.
          14              MR. WEINBERG:  It is possible, however, that I
          15         screwed that up, but --
          16              THE COURT:  It is all right.
          17              MR. WEINBERG:  But the order should be
          18         February, March and May.  That is what I'm hoping.
          19              THE COURT:  Yes.
          20    BY MR. WEINBERG:
          21         Q    This is 225, Mr. Prince.
          22         A    Okay.
          23         Q    And you recognize the first page of 225 to be a
          24    February 2nd of 1999 check from Bob Minton for $6,500 to
          25    you?
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           1         A    Yes, I do.
           2         Q    Do you recognize the second page to be a March --
           3    appears to be March 18, 1999 check to you for $5,000, do you
           4    see that?
           5         A    Yes, I do.
           6         Q    From Mr. Minton again?
           7         A    Yes.
           8         Q    And the third check to be a May 4, 1999 check for
           9    $5,000 from Mr. Minton?
          10         A    Correct.
          11         Q    Now, this was -- these checks had to do with the
          12    agreement that you had already worked out with Mr. Minton
          13    and Ms. Brooks about you getting at least $5,000 a month?
          14         A    Correct.
          15         Q    But you were getting this on top of what you were
          16    getting from Mr. Dandar?
          17         A    No.
          18         Q    Okay.  You think you started getting from
          19    Mr. Dandar a little bit later?
          20         A    Yes.
          21         Q    Now, what was this $5,000 a month for?  I mean,
          22    one was $6,500.  Do you know why it was $6,500?
          23         A    Do you know, I don't know.  I was looking at that.
          24    That is an anomaly.  That must have been money left over
          25    from another month.  Because as I said, there was a
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           1    stretch -- period of time after I met -- certainly from 1998
           2    until I guess this first check here that I was just simply
           3    not paid at all.
           4         Q    But this -- you are not getting paid for FACTNet
           5    work, you are getting paid for Lisa McPherson work prior to
           6    signing on with --
           7         A    No.
           8         Q    -- Ken Dandar?
           9         A    No.
          10         Q    Well, what is this work?  What is this --
          11         A    I'm in FACTNet when this is happening.
          12         Q    Why was FACTNet paying you?
          13         A    Well, I think I mentioned earlier that sometimes
          14    FACTNet just didn't have money and I would call Mr. Minton.
          15    I can't just be down here.
          16         Q    Now, when --
          17              THE COURT:  Weren't you making $3,500 a month
          18         at FACTNet?  Or am I thinking of something else?
          19              THE WITNESS:  Your Honor, you may be right
          20         about that because we did have -- have some
          21         agreement, I think I reached some agreement with
          22         them to do that.  And, you know, at that time I
          23         still had my other business.  I still had other
          24         employees.  I would often make trips, you know.  So
          25         that could have been the case.
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           1              But the fact of the matter is the organization
           2         didn't have the money.
           3              THE COURT:  I'm trying to think of why -- I
           4         have no idea why it was $6,500 either unless
           5         perhaps --
           6              MR. WEINBERG:  I think it might have been some
           7         expenses or something.
           8              THE COURT:  Or perhaps he was getting $3,500
           9         from FACTNet.  He was supposed to start getting
          10         $5,000 from whatever, and I didn't get -- the
          11         difference from $3,500 to $5,000 would be $6,500.
          12         That would be rational but --
          13    BY MR. WEINBERG:
          14         Q    In any event, Mr. Minton knew you had been doing
          15    this work in Clearwater for Mr. Dandar with regard to the PC
          16    folders?  He knew that?
          17         A    I assume he did.
          18         Q    I mean, you were in -- once you had spent that
          19    however long you said it was, I forgot now, a couple weeks
          20    at his house, you communicated with him regularly after
          21    that, didn't you?
          22         A    Up until this very occurrence, yes.
          23              THE COURT:  What is "this very occurrence"?
          24         This --
          25              THE WITNESS:  That is occurring here.
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           1              THE COURT:  Okay.
           2              MR. WEINBERG:  Now I'm going to mark as our
           3         next exhibit, your Honor --
           4              THE CLERK:  226.
           5              MR. WEINBERG:  -- 226, this is 226 --
           6              THE COURT:  Okay.
           7    BY MR. WEINBERG:
           8         Q    Now, Mr. Prince, 226 is a response that was filed
           9    by Mr. Dandar on April 6, 2001.  And attached -- and the
          10    response shows that it has checks attached, but if you'll
          11    look at the summary on Page 2, it identifies a 6/30/99
          12    check, an 8/20/99 check, a 9/15/99 --
          13         A    Excuse me, I'm not following you at all.
          14              MR. WEINBERG:  If I could approach a second?
          15              THE COURT:  You don't need to read them all
          16         into evidence.  Just put it into evidence.
          17              MR. WEINBERG:  I just wanted him to look at it.
          18    BY MR. WEINBERG:
          19         Q    You see those?
          20         A    Uh-huh.
          21         Q    Attached is those checks.  So either look at the
          22    attachment or summary there.
          23              Is it your recollection that is the sum and
          24    substance of what Dandar & Dandar paid you while you were on
          25    the -- you know, being working as a consultant/expert?
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           1         A    I believe this is correct with the possible
           2    exception of recent activity.
           3         Q    Right.  No, I'm talking about prior to 2002.
           4         A    Okay.
           5         Q    And that the first check was on or about June 30,
           6    1999.  Do you see that?
           7         A    Yes, I do.
           8         Q    And the last check was on or about May 24, 2000.
           9         A    Yes.
          10         Q    And it's your recollection that after you received
          11    the last check, that is when you started getting paid at the
          12    same rate by Lisa McPherson Trust?
          13         A    Correct.
          14         Q    You see for the most part these checks are $5,000
          15    a month?
          16         A    Correct.  I think I can explain what this other
          17    one is for, $1,772.
          18         Q    What?
          19         A    I mean all of $5,000 with the exception of the
          20    $1,772 --
          21         Q    Is that some expense check?
          22         A    Yes.
          23         Q    Okay.  Now, the Lisa McPherson Trust actually
          24    withheld from your check.  Right?
          25         A    Yes.
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           1         Q    In other words, you -- your salary was $5,000 a
           2    month but your take-home was whatever --
           3         A    About 35.
           4         Q    So I'm going to show you a series of those checks,
           5    as well.
           6         A    Okay.
           7         Q    You were on a 1099 for Mr. Dandar, in other words,
           8    he didn't withhold from your checks, right?
           9         A    Correct.
          10              THE COURT:  You were considered an independent
          11         contractor when you worked for him, is that right?
          12              THE WITNESS:  Yes, your Honor.
          13              THE COURT:  All right.
          14              THE CLERK:  227.
          15              MR. WEINBERG:  This is 227, your Honor.
          16              THE COURT:  All right.
          17    BY MR. WEINBERG:
          18         Q    This is 227.
          19         A    Okay.
          20              MR. WEINBERG:  I'll mark as 228 this document.
          21         And all this is is the payroll records of Mr. Prince
          22         which show that the salary was $5,000, it shows what
          23         the withholding was.
          24              THE COURT:  All right.
          25              MR. WEINBERG:  That is 228.
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           1              THE COURT:  All right.
           2              MR. WEINBERG:  These were produced by the Lisa
           3         McPherson Trust.
           4              THE COURT:  These weren't additional moneys.
           5              MR. WEINBERG:  No, it just shows what the
           6         salary was, 228, and they withheld --
           7    BY MR. WEINBERG:
           8         Q    If you look at the checks, Mr. Prince, they are
           9    $3,552, starting in June of -- of 2000, do you see that?
          10         A    Mmm, yes, I do.
          11         Q    And it is June, July, August, September, October,
          12    November, December --
          13              THE COURT:  Counselor -- Counselor, just can
          14         you go from the beginning to the end?
          15    BY MR. WEINBERG:
          16         Q    It begins in June -- end of June of 2000 and
          17    ends -- one is out of place -- ends --
          18              THE COURT:  June '01.
          19    BY MR. WEINBERG:
          20         Q    June/01, except if you look at the other exhibit,
          21    Mr. Prince -- if I could just approach, your Honor -- the
          22    payroll records indicate that you would have received -- you
          23    would have received a -- one last payment on August 1, 2001
          24    of $5,000 salary with all of the withholding.
          25              Do you see that?
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           1         A    I'm trying to follow.
           2         Q    It is the last page.  Right there (indicating).
           3    August 1 --
           4         A    Oh, yeah.  Okay.
           5         Q    All right?  So that was probably the close-out
           6    payment or something?
           7         A    That was the last check.  Yeah.
           8              THE COURT:  Counselor, from LMT again?
           9              MR. WEINBERG:  These are the LMT records, this
          10         is what they produced.
          11    BY MR. WEINBERG:
          12         Q    So it appears you were paid a salary as an
          13    employee from June of 2000 until August of 2001 at $5,000 a
          14    month.  Correct?
          15         A    Correct.
          16         Q    And after August 1 of 2001, you continued to get
          17    your $5,000 a month but it was from Ms. Brooks?
          18         A    Correct.
          19         Q    Now, did Ms. Brooks withhold from -- I mean --
          20              THE COURT:  What could she withhold from?  I
          21         mean, she was not paying him out of a business; she
          22         was giving him money.
          23              MR. WEINBERG:  It's a good question.
          24    BY MR. WEINBERG:
          25         Q    Did -- what were you considered at that point when
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           1    you were getting this $5,000 a month from Ms. Brooks?
           2         A    What was I considered?  Stranded in Clearwater.
           3    All of the other staff had moved.
           4              THE COURT:  Was this a friend giving -- giving
           5         you living money until you could get some other job?
           6              THE WITNESS:  Absolutely.
           7    BY MR. WEINBERG:
           8         Q    Was there some understanding how long that was
           9    going on?
          10         A    No.
          11         Q    Was -- had there been discussions it was going to
          12    end?
          13         A    No.
          14         Q    Now, you have a monthly mortgage, obviously,
          15    because you haven't sold this house yet, right?
          16         A    Correct.
          17         Q    Who paid you in May of 2002?
          18         A    It's not here?
          19         Q    May of 2002.  The last check from Ms. Brooks you
          20    said was April 4, 2002.
          21         A    Correct.
          22         Q    You said for years you needed $5,000 a month to
          23    live.
          24         A    Correct.
          25         Q    So my question is who paid -- where did you get
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           1    your money to live in May of 2002?
           2         A    I think from the State of Florida.
           3         Q    What do you mean?
           4         A    I filed for unemployment.
           5         Q    Well, how did you do that?
           6              THE COURT:  Because he was unemployed.
           7    BY MR. WEINBERG:
           8         Q    But you'd been unemployed since August of 2001.
           9         A    Yeah.
          10         Q    Or did you tell them that you had been employed
          11    since August of 2001 and just lost your job when you had
          12    this argument or disagreement with Mr. Minton and
          13    Ms. Brooks?
          14         A    Mr. Weinberg, it is actually quite a simple
          15    process.  You go online, you tell them you are employed --
          16    unemployed, you put it in there, and they send you a check.
          17    You check in.  You have to look for employment.  I mean,
          18    that is what I know about.
          19         Q    And who did you say your last employer was?
          20         A    Lisa McPherson Trust.
          21         Q    And what did you say the circumstances were that
          22    you had lost your job?
          23         A    Mmm, I -- I think -- I think maybe the place was
          24    bankrupt, went out of business, closed shop.  Something like
          25    that, you know.
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           1         Q    Is there some application you have to fill out?
           2         A    Online, yes.
           3         Q    And is there -- so it is all online, it is with
           4    the State of Florida?
           5         A    Yes, it is with the State of Florida online, yes.
           6         Q    And so since May of 2002, you have been on
           7    unemployment?
           8         A    Since late May of -- yeah.  Late May of 2002.
           9    Yes.
          10         Q    So you are still on unemployment?
          11         A    No.
          12         Q    Well, when did that end?
          13         A    Well, when I worked out a new agreement with
          14    Mr. Dandar and came to appear as an expert and give
          15    testimony here, he gave me a check which I think he said he
          16    would send here, and at that point when you receive money --
          17    when you are employed and you are actually receiving money,
          18    whether it is self-employed or otherwise, that terminates
          19    unemployment.
          20              So that check effectively terminated my
          21    unemployment.
          22         Q    And so you notified the authorities of that?
          23         A    Yes.  And I haven't received another check since.
          24         Q    How many checks did you get -- where do you get
          25    it, from the State of Florida, is that where you get the
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           1    checks?
           2         A    Yes.
           3         Q    And how many checks did you get for unemployment?
           4         A    Mmm, well, they do it -- I think I was getting
           5    like $293 a week or something like that.  Then they would
           6    double them up so the checks were like $494, I would get two
           7    of those --
           8              THE COURT:  Were you getting weekly checks?
           9              THE WITNESS:  No, I had it every other week.
          10         So I got $494 -- I believe I received --
          11              THE COURT:  Do you know?
          12              THE WITNESS:  No.
          13              THE COURT:  Then why don't you say that?
          14              THE WITNESS:  Sorry.  I don't know.
          15    BY MR. WEINBERG:
          16         Q    When did you get the first money from -- when did
          17    you sign up with Mr. Dandar to be an expert again?  What
          18    date?
          19         A    I don't know.
          20         Q    Well, that can't be long ago, so what is your
          21    best --
          22         A    Well, I don't know the date.  I don't know.
          23         Q    What were the circumstances of you becoming an
          24    expert again?
          25         A    Mmm, you know, again, this whole thing was over.
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           1    People were going home.  It was over.  Your client took
           2    Mrs. Brooks and Mr. Minton as trophies and we are sitting
           3    here today and this brought me into this position here again
           4    today.  So, you know, those are kinds of the circumstances.
           5              THE COURT:  Are you back as a consultant or
           6         expert or combination of the two?
           7              THE WITNESS:  I have been a combination of the
           8         two with him.
           9              THE COURT:  And what time did that start,
          10         about?  Was it like --
          11              THE WITNESS:  Maybe a week ago, two weeks ago
          12         or however.
          13              THE COURT:  So between May of 2002 up until
          14         that time you were collecting unemployment?
          15              THE WITNESS:  Yes.
          16    BY MR. WEINBERG:
          17         Q    And is there some agreement you executed with
          18    Mr. Dandar a week or two weeks ago?
          19         A    Yeah, that I participate in the case, I would
          20    help --
          21         Q    No, is there some written agreement?
          22         A    Oh, no.
          23         Q    And the day that it started is when you got the
          24    check.  Is that when you became the expert, when you got the
          25    check?
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           1         A    You know, I'm not -- I'm not sure because --
           2              THE COURT:  As opposed to they talked, then
           3         they got a check --
           4              MR. WEINBERG:  I'm trying to date it.  It is
           5         not that long ago.  I'm trying to date it.
           6    BY MR. WEINBERG:
           7         Q    I mean, when it happened, did you -- I mean, did
           8    this essentially happen simultaneously that somehow it was
           9    established that you were going to be the expert again and
          10    you negotiated what you needed?
          11         A    There was no -- I'll try to explain it as best as
          12    I can, Mr. Weinberg.
          13              THE COURT:  I don't care.  I don't want to hear
          14         it, I'm not interested.  I'm just not interested.
          15    BY MR. WEINBERG:
          16         Q    Could I ask the amount then?  What is the
          17    agreement?  Are you getting paid on monthly basis?  Salary?
          18         A    We have no agreement like that.  I just -- you
          19    know, I will put in X amount of time, I'll get through this
          20    hearing --
          21              THE COURT:  Are you going to bill him per hour,
          22         or what?
          23              THE WITNESS:  Yes, your Honor, I am.
          24    BY MR. WEINBERG:
          25         Q    And how much have you received from Mr. Dandar?
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           1         A    $4,000.
           2         Q    Is that just a retainer?
           3         A    Yes.
           4              THE COURT:  Are you keeping records now?
           5              THE WITNESS:  Yes, your Honor, I am.
           6              THE COURT:  What is your hourly fee?
           7              THE WITNESS:  150.
           8              THE COURT:  All right.
           9              MR. WEINBERG:  I think this would be -- I have
          10         a few other questions.
          11    BY MR. WEINBERG:
          12         Q    Did anybody else, between the time that Ms. Brooks
          13    quit giving you money and the time that Mr. Dandar did give
          14    you money, did anybody else give you whatever you want to
          15    call it, expense money, living money, expert money, money?
          16         A    No.
          17              THE COURT:  Between the time Ms. Brooks --
          18              MR. WEINBERG:  -- quit giving him the money in
          19         April of 2002 of this year and whenever it was
          20         Mr. Dandar gave this check.
          21              THE COURT:  Other than his unemployment?
          22              MR. WEINBERG:  Other than his unemployment.
          23    BY MR. WEINBERG:
          24         Q    Did anybody else give you money?
          25         A    The answer is no.
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           1              MR. WEINBERG:  I think that -- you know, I'm
           2         sort of at the end of this section.  If you want me
           3         to start another section I will, or we can --
           4              THE COURT:  Yes, I would like to go until about
           5         12:15, if you don't mind.
           6              MR. WEINBERG:  No.
           7              THE COURT:  Because we kind of got a late
           8         break.
           9              MR. WEINBERG:  No, I really don't mind.
          10              THE COURT:  Gee, I thought you were about to
          11         say you were done.
          12              MR. DANDAR:  I thought so, too.
          13              THE COURT:  I was real excited.
          14              MR. WEINBERG:  Or I could put it a different
          15         way.  Maybe I could have some time to collect my
          16         thoughts.  No, I'm not done.
          17              THE COURT:  All right.
          18    BY MR. WEINBERG:
          19         Q    Now, you have been asked before about --
          20              THE COURT:  Could I ask one question?  I'm
          21         sorry.
          22              MR. WEINBERG:  Sure.
          23              THE COURT:  What is the number of the response
          24         from Mr. Dandar?  Can somebody give me a number on
          25         that?
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           1              MR. DANDAR:  226.
           2              THE COURT:  Thank you.  I forgot to mark it.
           3              MR. WEINBERG:  Which means that the -- that the
           4         LMT --
           5              THE COURT:  I have everything else marked.  I
           6         just didn't have that marked.
           7              MR. WEINBERG:  All right.
           8    BY MR. WEINBERG:
           9         Q    You have been asked before and testified about
          10    going to Key West.  Do you remember that?
          11         A    I don't remember testifying about that.
          12         Q    Well, did you go to Key West?
          13         A    Yes.  But I don't remember testifying about it.
          14              MR. DANDAR:  It is outside of the scope of
          15         direct.
          16              THE COURT:  Well, I don't know what he's going
          17         to ask about it, but it is probably doubtful it is
          18         outside of the scope of direct but --
          19              MR. WEINBERG:  It is.  It is.
          20              THE COURT:  Go ahead.
          21    BY MR. WEINBERG:
          22         Q    And you were in Key West for what purpose?
          23         A    Vacation.
          24         Q    For a fishing trip is what you previously
          25    testified to.
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           1         A    Yes, okay.  And, you know, I don't want to do
           2    this -- if I have testimony, could you please just show it
           3    to me and ask me about it?
           4              THE COURT:  That is a fair question.  I mean --
           5              MR. WEINBERG:  Well, let me ask a few questions
           6         and then I will show it to you because we do have --
           7         actually we'll show you the video.
           8              THE COURT:  If he wants to see it, you show it
           9         to him now.
          10              MR. WEINBERG:  Well, this is it.  He can look
          11         at it.
          12              THE COURT:  Then put it up then.
          13              MR. WEINBERG:  Well, I need to ask him one
          14         question before.
          15              THE COURT:  Okay.
          16              MR. WEINBERG:  One series.
          17    BY MR. WEINBERG:
          18         Q    In Key West, it didn't have anything to do about
          19    Scientology or this case or cases against Scientology, is
          20    that right?
          21         A    Mmm, you know, we were there for a fishing trip.
          22    I was there with Mr. Haverty, Mr. Haney, Mr. Ford Greene,
          23    Mr. Dan Leipold, Mr. Dandar; Mr. Garko came out there.  We
          24    all have a common interest, and it would be crazy for me to
          25    say that the subject of our work didn't come up and was
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           1    discussed or whatever at some -- you know, during the
           2    fishing trip.
           3              So the -- that is the best way I can answer that
           4    question.
           5              THE COURT:  So the answer is yes, you all
           6         discussed the case?
           7              THE WITNESS:  Yes.
           8              THE COURT:  All right.
           9    BY MR. WEINBERG:
          10         Q    Well, let me play your testimony and then I'll ask
          11    you about it.
          12              THE COURT:  What testimony?  This is on direct?
          13              MR. WEINBERG:  No, it's in his deposition under
          14         oath in this case on November 17 --
          15              THE COURT:  See, you misled -- I think
          16         Mr. Prince and I both thought you were talking about
          17         on direct examination which is what Mr. Dandar said
          18         was outside the scope.
          19              MR. WEINBERG:  No, in this case about Key West.
          20              THE COURT:  But it was in his deposition?
          21              MR. WEINBERG:  Yes.
          22              THE COURT:  Okay.  When you say testimony in
          23         this case, I'm going to assume you're talking about
          24         direct.
          25              MR. WEINBERG:  I'm sorry.
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           1              THE COURT:  So if it is something else, you
           2         need to identify it for him and for me.
           3              MR. WEINBERG:  Okay.
           4              MR. DANDAR:  What page number is this going to
           5         be?
           6              MR. WEINBERG:  Right here.  This is a
           7         transcript of where this comes from.
           8              THE COURT:  Okay.
           9              THE WITNESS:  May I have a transcript, too?
          10              MR. WEINBERG:  Oh, sure.
          11              THE WITNESS:  Thank you.
          12              ______________________________________
          13              (WHEREUPON, the video was played.)
          14    BY MR. WEINBERG:
          15         Q    Did you go to Key West?
          16         A    Yes.
          17         Q    Who sent you to Key West?
          18         A    No one sent.  I went.
          19         Q    Who paid for the trip?
          20         A    I paid for the majority of it while I was there,
          21    but it wasn't -- really not much to pay for.  I paid to be
          22    on a boat to go out fishing.  I paid --
          23         Q    Who -- well, who gave you the money?
          24         A    I used my own money.
          25         Q    Well, where did that money come from?
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           1         A    Money that I earned from working.
           2         Q    For FACTNet and Mr. Dandar and Mr. Leipold?
           3         A    I think we've covered this earlier.  You know, I
           4    have a -- you know -- different businesses, as well as
           5    expert, and, you know, the money that I used for that
           6    particular trip came from money derived from income from
           7    work that I've done.
           8         Q    Including FACTNet, Mr. Dandar and Mr. Leipold,
           9    right?
          10         A    I'm not sure why you're bringing up FACTNet.  I
          11    thought we --
          12         Q    Is that right?
          13         A    No, that is wrong.
          14         Q    Well, when was the trip to Key West?
          15         A    Well, six weeks ago now.
          16         Q    And who was on the trip?  What people were on the
          17    trip?
          18         A    Oh, you know, I really don't want to discuss that
          19    because I was on a complete pleasure trip.  It had nothing
          20    do with McPherson, or Wollersheim.  Nothing.  It had to do
          21    with fishing and having a good time.  Okay?
          22         Q    Now --
          23         A    And I explained to you earlier that I am very
          24    reticent to bring up the names of people that I'm involved
          25    with that is activity outside of Scientology because of the
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           1    behavior of your client.  How many times do we have to keep
           2    going over this?
           3         Q    Were you on the trip with Mr. Dandar?  Or are you
           4    embarrassed about bringing his name up?  Were you on the
           5    trip with Mr. Dandar?
           6         A    No, Mr. Dandar was not --
           7         Q    Answer yes or no?
           8         A    -- on the trip.  No.
           9         Q    Was Mr. Leipold on the trip?
          10         A    Mr. Leipold -- Leipold was there, Mr. Weiner
          11    (sic).  He was there.
          12         Q    Was Mr. Minton on the trip?
          13         A    No.
          14         Q    Ms. Young on the trip?
          15         A    No.
          16         Q    Vaughn Young on the trip?
          17         A    No.
          18         Q    Mr. Jacobsen on the trip?
          19         A    Who is Mr. Jacobsen?
          20         Q    You don't know Mr. Jacobsen?
          21         A    No.
          22         Q    That is fine.  Mr. Ward on the trip?
          23         A    No.  No.
          24         Q    Did you talk about Lisa McPherson on the trip?
          25         A    Very little.
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           1         Q    So Mr. Leipold went from California to Key West to
           2    just fish --
           3         A    Yes.
           4         Q    -- with Jesse Prince?
           5         A    Yes.  We went deep-sea fishing.  We went 40 miles
           6    off the coast, caught fish like this.  Had a ball.
           7         Q    And there was no planning session with regard to
           8    litigation.  Is that correct?
           9         A    No.
          10         Q    Was Mr. Haney on the trip?
          11         A    Yes.  And his son.  And he learned to fish.
          12              Excuse me.  Now that we don't have a question
          13    pending I would like to take a break.  My leg is going to
          14    sleep.
          15         Q    We just broke ten minutes ago?
          16         A    Well, okay, I'm sorry, my leg is going to sleep.
          17    I'll take a two-minute break.  Is that okay, Mr. Weiner
          18    (sic)?
          19         Q    Okay, take a break.
          20              ____________________________________
          21         Q    Now, I asked you if Mr. Dandar was in Key West
          22    with you.  And you said no.  You said no repeatedly.  Is
          23    that correct?
          24         A    I don't -- if I did say no, I'm very sorry.  He
          25    was not part of the trip.  He came and appeared one day,
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           1    said, "Hi," we had dinner and he left.
           2         Q    When you were outside did they -- did they --
           3    Ms. Young remind you that you had made yet another mistake
           4    under oath?  Did they tell you that?
           5         A    How could Ms. Young said -- say that when I gave
           6    you testimony that she wasn't there?
           7         Q    Well, who told you that then?  Who told you -- who
           8    corrected your -- your false testimony that Mr. Dandar
           9    wasn't there?
          10         A    I never gave false testimony.  You asked me if
          11    Dandar was part of the trip that I went fishing.  I said no.
          12         Q    And you were absolutely insistent that Mr. Dandar
          13    wasn't there and yet he was in Key West?
          14         A    And came and had dinner and left.  One time.
          15         Q    Flew down to Key West to have dinner and left.
          16              MR. DANDAR:  Objection, asked and answered and
          17         don't answer it again.
          18              THE WITNESS:  Okay.
          19    BY MR. WEINBERG:
          20         Q    Did he stay in a hotel down there?
          21         A    I don't know.
          22         Q    What do you mean, you don't know?
          23         A    That means that I don't have personal knowledge of
          24    it.
          25         Q    And you understand what personal knowledge is,
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           1    right?
           2         A    Oh, come on, please.
           3         Q    No, do you understand it, personal knowledge?
           4         A    I do not know if he was staying in a hotel there.
           5    I was in a different place.  I don't know where he was.
           6         Q    How many -- how long did you spend with him in Key
           7    West on that trip this summer?
           8         A    A dinner.  Maybe 15, 20 minutes.  Outside of
           9    dinner --
          10         Q    Dinner is usually at night, right?
          11         A    Correct.
          12         Q    Did you see him the next morning?
          13         A    No.
          14         Q    Now, was Mike Garko down there?
          15         A    Yes, he was.  Dr. Garko was there.
          16         Q    Was Thom Haverty down there?
          17         A    Yes.  He was.
          18         Q    So that is like the whole consulting team for the
          19    McPherson case?
          20         A    Mr. Garko was with Mr. Dandar.
          21         Q    So he just flew in for dinner?
          22         A    Came in and left.
          23         Q    Didn't have anything to do with the Lisa McPherson
          24    case?
          25         A    No.
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           1         Q    Who paid for your trip?
           2         A    As I gave testimony to earlier, I paid my own
           3    expenses to -- Mmm -- take the boat out.  I went out on a
           4    boat several times.  I paid about 50, 60 bucks a time.  I
           5    bought beer, wine, food, cigarettes.
           6              (End of playing of the video tape.)
           7              ______________________________________
           8              THE COURT:  Counselor, is it -- is it important
           9         that --
          10              MR. WEINBERG:  We are demonstrating --
          11              THE COURT:  Right now we have testimony coming
          12         out, I paid for my trip.
          13              MR. WEINBERG:  We are playing it in context.
          14              THE COURT:  No, it is not.  I see about a
          15         jillion pages.  You are on Page 259 and I see it
          16         going straight through to Page 267.  That is a lot
          17         of pages.  And I see that you're -- there is a lot
          18         of consistent testimony here.
          19              MR. WEINBERG:  But, your Honor, when we play
          20         this, I think you'll see that there is a lot of
          21         inconsistent statements.
          22              THE COURT:  Yes, you already played it.  I'm
          23         saying why do I have to listen to the consistent
          24         testimony from a deposition, it is improper.
          25              MR. WEINBERG:  Well, because -- because --
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           1         there has been a lot of argument, accusations in
           2         here about taking things out of context so we left
           3         it in context is what we did.
           4              THE COURT:  All right.
           5              If you have any more like this, you -- you cut
           6         and paste.  You can give it all to me, go to where
           7         you want to go, but I don't want to hear it --
           8              MR. WEINBERG:  I understand.
           9              THE COURT:  I have better things to do than
          10         listen to this man's testimony two times when it is
          11         exactly the same both times.  Now, there is
          12         differences and I'm interested in hearing the
          13         differences.
          14              MR. WEINBERG:  And it is different from the
          15         other sworn testimony before --
          16              THE COURT:  And I'm interested in hearing that.
          17         I'm not interested in hearing that which is not
          18         inconsistent.  Do I make myself clear?
          19              MR. WEINBERG:  Yes.
          20              THE COURT:  It is improper.  All right.
          21              MR. WEINBERG:  We could play it on rebuttal
          22         case, and we thought it would be appropriate to play
          23         it here with Mr. Prince on the stand and get his
          24         explanation for the inconsistencies between this
          25         and --
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           1              THE COURT:  I have no problem with your playing
           2         inconsistencies.
           3              MR. WEINBERG:  All right.
           4              THE COURT:  That is called impeachment.  I do
           5         have a problem with having to listen to Mr. Prince's
           6         testimony on the stand and then listen to identical
           7         testimony in a deposition.  Cut and paste it.  You
           8         can give me the whole deposition, so if I want to
           9         read it in between, I can.
          10              MR. WEINBERG:  I apologize.  Just play the
          11         rest -- no, are we done?
          12              That is fine.
          13              THE COURT:  I mean, there is more here and
          14         there may be more inconsistencies and I want you to
          15         play that --
          16              MR. WEINBERG:  I understand, and we don't have
          17         it set up and I'll go back and look at it at the
          18         break.
          19              THE COURT:  Let me look and I can see what you
          20         have underlined and that is probably the important
          21         part.  I see I have two pages here not underlined.
          22              MR. WEINBERG:  The only stuff being played is
          23         the underlined stuff.
          24              THE COURT:  That is not true, Counsel, it is
          25         not true.
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           1              MR. DANDAR:  And I don't have anything
           2         underlined.
           3              MR. WEINBERG:  Well, then -- then I should have
           4         followed the transcript.
           5              THE COURT:  Page 259, this is about the time I
           6         interrupted you, "Who paid for your trip down there?
           7              "As I gave testimony to you earlier, I paid my
           8         own expenses.  I went out on a boat several
           9         times --"
          10              MR. WEINBERG:  Wait a minute.  I thought --
          11         point made.  I really thought when I was -- that I
          12         had this -- only the stuff that was yellowed.
          13              THE COURT:  No.
          14              MR. WEINBERG:  That is why it was yellowed.
          15              THE COURT:  If there is something else in here
          16         you want to impeach, that is perfectly fine, you can
          17         catch it during lunch.
          18              MR. WEINBERG:  I'll catch it during lunch.  I
          19         think I pretty much made my point.
          20    BY MR. WEINBERG:
          21         Q    Now, in Mr. Dandar's testimony in this proceeding
          22    on May 3, 2002 --
          23         A    Not this?
          24         Q    No, it is not this.
          25         A    Okay.
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           1         Q    On Page 90 -- this is in his direct testimony when
           2    it first started at the beginning -- I could hand this up.
           3              THE COURT:  If you are going to try to impeach
           4         this witness from Mr. Dandar's testimony --
           5              MR. WEINBERG:  No, I'm going to ask him a
           6         question about it.
           7              THE COURT:  You don't need to show him
           8         Mr. Dandar's testimony or ask him about it.  You
           9         can't do it.  If their testimony differs, it
          10         differs.  You can bring it up, inconsistencies in
          11         their testimony, but you can't show him Mr. Dandar's
          12         testimony and say, "Is that true?"
          13    BY MR. WEINBERG:
          14         Q    I take it that you did not spend hours and hours
          15    talking about Scientology strategy, the Lisa McPherson case
          16    and the other Scientology cases with Mr. Dandar or anyone
          17    else at the Key West meeting.  Is that correct?
          18         A    That is correct.  My recollection, I didn't spend
          19    hours speaking to anyone about this.  I mean, you know,
          20    there were a point in time when the attorneys were meeting,
          21    you know.  And again, I don't profess to be an attorney, I
          22    don't try to be an attorney.  I was there on a fishing trip,
          23    you know.  Mr. Leipold has certain experience in dealing
          24    with Scientology.  Mr. Ford Greene has certain experience
          25    with dealing with Scientology because of the cases he has
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           1    done.  They had discussed with Mr. Dandar about that.  This
           2    had nothing to do with me.
           3         Q    Well, you said Mr. Dandar in your testimony was
           4    only there for dinner one night for a few hours with
           5    Dr. Garko and flew back and there was no discussion about --
           6    about the case.  That is what you said?
           7         A    You know --
           8         Q    Under oath.  Correct?
           9         A    This is getting ridiculous, Mr. Weinberg.  I mean,
          10    he flew in for dinner.  He flew in.  He brought in
          11    Mr. Garko.  He had his own personal pilot.  They were flying
          12    a little personal plane.  They came, you know, while it was
          13    still light outside, you know, "Hi."  Thom Haverty's wife is
          14    there and Captain Wayne's wife is there, the boat.  This is
          15    a social setting.
          16         Q    All right, so --
          17         A    There is nothing sinister about it.
          18         Q    So Mr. Dandar was not there for two or three or
          19    four days with Dr. Garko, was he?
          20         A    Not to my recollection.  No.
          21         Q    Did you fly back to Tampa with Mr. Dandar?
          22         A    No, I did not.
          23         Q    And did you talk, on the trip in Key West -- which
          24    you remember it was in August of 1999?
          25         A    I'll take your word for it.
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           1         Q    And do you remember that on August 20th of 1999 is
           2    when you wrote that David Miscavige affidavit that was used
           3    about him ordering the death of -- letting -- ordering or
           4    allowing her or causing her to die?  Do you remember that?
           5         A    You got me all screwed up on the dates now.  Could
           6    you just tell me again?
           7         Q    The testimony in this case is that the Key West
           8    trip was around August 8, 9, 10, 11 of 1999.  Or 12th of
           9    1999.
          10         A    Whose testimony is that now?
          11         Q    Mr. Dandar's testimony, Dr. Garko's testimony,
          12    Mr. Haney's testimony.  That is the testimony.
          13         A    Okay.
          14         Q    All right?  You executed an affidavit -- the
          15    affidavit in this case, part of what this hearing is about,
          16    on August 20 of 1998?
          17              THE COURT:  We are talking about that is the
          18         date he signed it?
          19              MR. WEINBERG:  Yes, that is the date he signed
          20         it.
          21              THE COURT:  You are not going to suggest to
          22         this witness that whole affidavit was written on the
          23         date it was --
          24              MR. WEINBERG:  I wasn't going to ask that.
          25
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                                                                        864
           1    BY MR. WEINBERG:
           2         Q    Just ten or fifteen days later you executed this
           3    affidavit, right?
           4         A    Correct.
           5         Q    Now, did you participate in any conversations in
           6    Key West with anyone, whether it is Ford Greene, lawyer on
           7    Scientology cases, or Dandar Leipold, or Ken Dandar, or
           8    Dr. Garko or Thom Haverty, part of the -- part of the Lisa
           9    McPherson team, did you have conversations with anybody down
          10    there about any of the assertions in this what became the
          11    August 20th affidavit?
          12         A    Not that I recall.
          13         Q    Did you have any discussions down there with
          14    anyone about adding David Miscavige as a strategy to the
          15    Lisa McPherson case?
          16         A    Not that I recall.
          17         Q    As far as you know, was anybody down there talking
          18    about the strategy of adding David Miscavige to the Lisa
          19    McPherson case?
          20         A    Not that I know of.
          21         Q    And was it --
          22         A    Or not that I recall or have memory of.
          23         Q    But you did leave Key West and go directly to
          24    Tampa, correct, after that trip that you call a fishing
          25    trip?
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                                                                        865
           1         A    I believe that -- that that is correct.
           2         Q    And as soon as you got to Tampa, you started
           3    work -- you must have started working on this affidavit.
           4    Right?
           5         A    I think that affidavit was a work in progress by
           6    the time I got to Tampa already.  If you notice -- I mean,
           7    that thing is pretty detailed.  I have references.  I have
           8    studied.  You know, it takes me time to do these affidavits.
           9    I just don't sit and imagine it.  I have my calendar, I have
          10    my notes or whatever and I sit and I do these things.
          11         Q    But the first check you got from Mr. Dandar was
          12    June 30, 1999.  Correct?
          13         A    If that is what you just showed me, I'll take your
          14    word for it.  Okay.
          15         Q    So as you look back, as you think back, do you
          16    recall whether you were working on this affidavit before you
          17    went to Key West?
          18         A    I'm pretty sure that was a work in progress.
          19         Q    So you had already had discussions with people
          20    about adding Mr. Miscavige to the case?
          21         A    I don't know.  I don't recall it so I'm going to
          22    say I don't know.
          23              THE COURT:  The only thing I'm going to allow
          24         you to inquire about -- remember we had this little
          25         business about the work product -- is the meeting
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           1         which is at issue in this case, the meeting, whether
           2         Minton was there and whether Minton influenced that.
           3         Whether this man, as a consultant, paid or
           4         otherwise, had a conversation about adding David
           5         Miscavige is what I would have expected him to add.
           6         Nothing sinister about that.
           7              MR. WEINBERG:  Nothing said it was sinister,
           8         except Mr. Dandar already asked Dr. Garko about
           9         meetings, Mr. Haney about meetings, Ms. Brooks about
          10         meetings, so --
          11              THE COURT:  Meetings?  What meetings?  The only
          12         person that I know of that was asked about the Key
          13         West meetings was you-all.  Maybe he brought it
          14         up --
          15              MR. WEINBERG:  He brought it up on May 3rd.
          16         You didn't let me cross-examine him.  Mr. Dandar is
          17         the one that brought up the Key West meeting, said
          18         that is where he --
          19              THE COURT:  Well, do you think I think all
          20         those people sat down there and didn't talk about
          21         this case?
          22              MR. WEINBERG:  No, I don't.
          23              THE COURT:  I don't care what they said.
          24              MR. WEINBERG:  I'm just --
          25              THE COURT:  I mean, you know --
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           1              MR. WEINBERG:  I --
           2              THE COURT:  You are acting as if you have a
           3         jury here that -- I'm a judge that has been involved
           4         in this case very deeply, and as I tried to suggest
           5         to you on several occasions, I'm not an idiot.
           6              MR. WEINBERG:  I know that.
           7              THE COURT:  I know what lawyers do.
           8              MR. WEINBERG:  I understand that.
           9              THE COURT:  And I know if you get this many
          10         lawyers together, all of whom have Scientology
          11         cases, you put them on fishing trip or movie theater
          12         or whatever, the subject comes up and they talk
          13         about it.
          14              MR. WEINBERG:  And you couldn't have said it
          15         better, and I'm making a record which I'm done with
          16         on this thing --
          17              THE COURT:  All right.
          18              MR. WEINBERG:  -- indicating that this witness,
          19         that is what this -- you know, this Paragraph 34 in
          20         the complaint is all about, his sworn affidavit, has
          21         told lies.  You know, I'm using that --
          22              THE COURT:  I already told you and I told your
          23         team, save it for the jury.  I don't care if he told
          24         a bunch of lies or not.  The law in Florida is if he
          25         qualifies as an expert, he can testify.
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           1              MR. WEINBERG:  No, I understand your ruling.
           2         I'm --
           3              THE COURT:  Okay.
           4              MR. WEINBERG:  This is for credibility
           5         purposes.
           6              THE COURT:  I understand.
           7              MR. WEINBERG:  All right.  But I'm pretty much
           8         done with this area.
           9              THE COURT:  All right.  Then let's have lunch.
          10              MR. WEINBERG:  Good.
          11              THE COURT:  And as I said, you just have to
          12         forget -- I hope you all don't forget that I was a
          13         lawyer for a long time.
          14              MR. WEINBERG:  Judge, believe me --
          15              THE COURT:  Please.
          16              MR. WEINBERG:  -- I am well aware of that.
          17              THE COURT:  Frankly, my findings will go to the
          18         court this time with a presumption of correctness.
          19         This is not a de novo hearing --
          20              MR. WEINBERG:  No, I understand that.
          21              THE COURT:  -- by the Second District.
          22              MR. WEINBERG:  No, but it has also been a long
          23         proceeding.
          24              THE COURT:  Well, I understand, but it seems to
          25         me as if part of what you want to do is have
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           1         Mr. Prince up here just forever.  I made statements
           2         before about Mr. Prince.  I'm aware of Mr. Prince's
           3         bias.  I mean, Mr. Minton, according to Mr. Prince,
           4         shows where I said this before, this is not new.
           5              MR. WEINBERG:  I understand, but I just started
           6         yesterday -- I mean, yesterday late --
           7              THE COURT:  I understand.  But you are spending
           8         an awful lot of time about pickets which I knew what
           9         they would say, with pickets that I knew would not
          10         be pretty, all as if you are trying to show me what
          11         I already know.  You are wasting time here.
          12              MR. WEINBERG:  But --
          13              THE COURT:  We'll be in recess until 1:30.
          14     (WHEREUPON, a recess was taken from 12:00 to 1:35 p.m.)
          15              ______________________________________
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                                                                        870
           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 10th day of July, 2002.
          12
          13
          14                              ______________________________
                                              LYNNE J. IDE, RMR
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