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Case No. 00-5682-CI-11, Division   11

and through the personal Representative,





                                                ) ss.

Robert S. Minton, being duly sworn, deposes and says:

1.   I am over 18 years old, have personal knowledge of the facts set
forth herein, and am otherwise competent to testify in this matter.
2.  On March 9, 1997, I met attorney Ken Dandar for the first time
when I participated in a picket in Clearwater, Florida against the
Church of Scientology.  The picket focused on the death of Lisa
McPherson.  Mr. Dandar was introduced to me by Mr. Lawrence
Wollersheim at the Howard Johnson's Motel on U.S. 19 in Clearwater.
Mr. Dandar had an extensive discussion with Mr. Wollersheim at that
meeting in my presence to learn about the pursuit of other Scientology
corporations and church leaders as a litigation tactic to "go after"

3.  I had previously loaned Mr. Wollersheim $700,000 and have since
loaned his attorney, Dan Leipold, $500,000 to assist in their
litigation against Scientology.  My money was used in part to pay the
witnesses in that litigation to provide affidavits to support Messrs.
Wollersheim and Leipold's theories.  The same witnesses have been used
by Mr. Dandar in this litigation.

4.  Until October 1997 my financial involvement  against Scientology
was limited to the Wollersheim litigation.   At that time, I decided
that the Lisa McPherson wrongful death case would be a far more
effective centerpiece for me and I contacted Mr. Dandar in October
1997 and offered to loan the Estate $100,000 to defray costs and
expenses so this case could become a vehicle to attack Scientology on
a broad scale.

5.  That $100,000 and all subsequent amounts, up to a total of
$2,050,000, I loaned to the Estate was specifically for covering the
expenses of litigating the wrongful death case.  It was not a personal
loan to Mr. Dandar, and was not to be spent for other purposes or
other cases. The agreement I had with the Estate was that if the case
was won or favorably settled, I would get my money back from the
Estate (with no interest) once the Estate's expenses were covered.

6.  Following receipt of my $100,000, Mr. Dandar sent me a letter
telling me that I would have no participation in the control of the
litigation.  This self-serving statement quickly became untrue, as Mr.
Dandar immediately began consulting me about the conduct of the
litigation, briefing me on confidential information from the case,
sending me copies of deposition and hearing transcripts, and calling
me for advice.  His statements concerning case control became
increasingly untrue throughout my involvement in the case when Mr.
Dandar would do things in the litigation designed to satisfy my wishes
and thus get more money from me.

7.  Two days after I sent Mr. Dandar the first $100,000 check, I made
postings to the internet making my views clear - I wanted Scientology
charged with murder.  Mr. Dandar then filed his First Amended
Complaint in the wrongful death case, expanding the case and claiming
that Scientology intentionally caused the death of Lisa McPherson.
8.  In early December 1997 I first discussed with Mr. Dandar the
possibility that it would be a good idea if the Estate of Lisa
McPherson would agree to donate a substantial part of any proceeds
from this case to an anti-cult group as I believed this would mute
Scientology's criticisms of the Estate and Mr. Dandar and it was a way
for me to recover the funds I had invested in the litigation.  Mr.
Dandar told me on or about December 5, 1997, that he had discussed
this matter with the family of Lisa McPherson and they agreed to
donate the "bulk" of any proceeds received, after covering expenses
and Mr. Dandar's contingency fee, to an anti-cult group. I later
testified about this agreement in a deposition in Boston,
Massachusetts on January 13, 1998 in the presence of Mr. Dandar.  At
that time, Mr. Dandar told me that the anti-cult group that would
receive the money was FACTNet, an anti-Scientology group started by
Mr. Wollersheim. I was President and on the Board of FACTNet at that

9.  Shortly before this deposition, I had met Mr. Dandar at lunch time
at a Starbucks on Cambridge Street in Boston, across from Mass
General.  Mr. Dandar was there taking a deposition in a disrelated
case.  Mr. Dandar was asking about further funding for the wrongful
death case.  He also wanted to know whether I had any offshore funds
that could facilitate the litigation.  He told me that with every
dollar that I provided to support the litigation, Scientology would
spend $20.

10.  Dell Liebreich and her two sisters, Lee Skelton and Ann Carlson
confirmed in depositions in May 1999 that they had agreed to donate
the bulk of any money to a cult awareness group.  Further, Ms.
Liebreich and Ms. Carlson confirmed that they wanted a cult awareness
group named for Lisa McPherson to receive the "bulk" of the proceeds
from the case.
11.  As a result of this agreement to pay the proceeds of a judgment
to an entity I controlled, and because the case had now been turned
into a broad attack on Scientology, I continued to provide money to
fund the case, a total of $400,000 through 1998 alone.  This money was
used in part to pay witnesses to be used in the wrongful death
litigation.  All of these witnesses were ex-Scientologists who had
left Scientology years before Lisa McPherson died, and had no personal
knowledge of any facts surrounding her death.

12.  In June 1998 I was featured in a forty-minute segment on Dateline
entitled "The Crusader." The program focused on my activities
concerning Scientology. Throughout the filming of the Dateline
program, Mr. Dandar indicated his excitement at the possibility of
more sensational anti-Scientology coverage on national television,
especially if I could get Dateline to focus on the wrongful death
case.   Mr. Dandar told me he was anxious to have any media against
Scientology especially if it would have some impact on the jury pool
in Florida.

13.  Mr. Dandar encouraged me to get as much negative media about
Scientology as possible and I gave media interviews whenever I could.
I attended and organized regular picketing of Scientology facilities -
which Mr. Dandar and others in the trial team also attended on

14.  I also funded production of a movie about Scientology ("The
Profit").  I invested $2.5 million to have two anti-Scientology
critics produce the movie.  Along with me, Jesse Prince, Stacy Brooks
and other LMT staff, Mr. Dandar also had an acting role in the movie.
Mr. Dandar played an FBI agent.  Mr. Dandar felt the movie would help
generate a negative view of Scientology with potential jurors in the
area.   The only place in the United States the movie was ever
screened was in Clearwater and Tampa. The movie was of such poor
quality that distribution became impossible.

15.  In August 1999, Ms. Brooks and I met with Mr. Dandar in
Philadelphia so that Mr. Dandar could brief us on the status of the
wrongful death case. I complained to Mr. Dandar that he was not
adequately pressing the Scientology aspects of the case and urged him
to make more use of Ms. Brooks and Mr. Prince as Scientology

16.  Ms. Brooks and I told Mr. Dandar that we really wanted him to
focus the case on Scientology and its leadership as I was funding a
case about the "death of a Scientologist on the Introspection
Rundown," not just a "simple wrongful death case."  It is my belief
that because I was funding the case, and in order to ensure that I
would continue to do so, Mr. Dandar was willing to shift the emphasis
of the case from a simple wrongful death suit to a case against the
beliefs and practices of Scientology.  At the end of this meeting, Mr.
Dandar said this would cost more and I then handed Mr. Dandar a check
for $250,000, bringing the total I had loaned to the Estate at that
time to $750,000.

17.  In the fall of 1999 I flew into the Tampa airport and was picked
up by Ms. Brooks and taken to Mr. Dandar's new office on Kennedy
Boulevard in Tampa for a meeting concerning whether Mr. Dandar should
add David Miscavige as a defendant in the wrongful death case.
Attending that meeting in Mr. Dandar's new conference room were Ms.
Brooks, Mr. Prince, Dr. Garko, Mr. Dandar and myself.  The focus of
the discussion was not what the facts were concerning Mr. Miscavige,
but how to pressure him.

18.  Mr. Dandar was enthusiastic about this prospect even though there
was no evidence to support it, as he felt it would force Scientology
to the settlement table and would increase the amount of any
settlement that Scientology would agree to.  He also stated this would
generate sensational publicity for the case.  During the meeting, Dr.
Garko specifically pointed out that there was not a single shred of
evidence to support adding Mr. Miscavige and was opposed to adding him
as a defendant.

19.  The whole theory of adding Mr. Miscavige was based on an
affidavit of Jesse Prince dated August 20, 1999, which I have reviewed
and which has been filed in this case, speculating about events in
December 1995, three years after Mr. Prince had left Scientology
staff.  This was the pattern used in this and other Scientology cases
I have seen - an attorney comes up with a strategy and gets one of the
paid "Scientology experts" to come up with a theory and write an
affidavit that could be used to support a court filing based purely on
speculation and written with allegations by innuendo.

20.  At the end of the meeting, Mr. Dandar accompanied Ms. Brooks, Mr.
Prince and myself down the elevator. Just before the elevator arrived
at the first floor, Mr. Dandar said to us that we could never discuss
this meeting. We all agreed.

21.  Subsequently, shortly before I was scheduled to be deposed in the
breach of contract case on October 11-12, 2001, Mr. Dandar asked me,
"Do you remember the meeting that never happened?" I answered, "No,"
and he laughed and said, "You're good! Just remember that answer."

22.  During that deposition in October 2001, Mr. Dandar, on
cross-examination, asked me questions to elicit false testimony to
support his position that I had no control over the litigation:  "Do
you know of anyone who was involved in the decision-making process to
add David Miscavige or any other Scientologist or Scientology
corporation to the wrongful death case?" I said that I supposed
Michael Garko, Dell Liebreich and Mr. Dandar had discussed it. Mr.
Dandar then asked me if anyone outside of the litigation team was
involved in the decision-making process, and I answered, "I don't
know." These answers were not truthful because Mr. Dandar did not want
me to reveal anything that would indicate that I had any control over
the litigation.  He knew my answers were false.  Not only did Mr.
Dandar elicit false testimony but he also had coached me to do so.

23.  During the summer and fall of 1999 steps were taken to organize
an entity to be called the Lisa McPherson Foundation for the purpose
of being the beneficiary of the bulk of the proceeds of the wrongful
death litigation at some point in the future.  This organization was
created with the full knowledge and support of the family of Lisa
McPherson, the Estate through its personal representative, and Ken
Dandar, the attorney for the Estate.  In fact, creating this
organization had been suggested by Dell Liebreich, as she testified in
her deposition in May 1999.

24.  In October 1999, Mr. Dandar incorporated the organization under
the name Lisa McPherson Trust (LMT).   I was the President and sole
shareholder.  Mr. Dandar organized the LMT as a for-profit entity but
he told me that we would reincorporate it as a non-profit when it was
time to distribute funds from the wrongful death case.  At a dinner on
November 30, 1999, Ms. Liebreich and Mr. Dandar reaffirmed to me their
commitment to donate the bulk of the proceeds of the case to the LMT
when they visited Clearwater in December 1999 to picket Scientology
and to attend an LMT Board meeting.   Subsequent to this reaffirmation
of the Estate's commitment, I made statements on a radio show in
Boston and in an Internet posting dated February 2, 2000, that the
Estate had "promised to give the vast majority of any settlement or
award from trial to the Lisa McPherson Trust."
25.  Mr. Dandar put Ms. Liebreich on the Board of Directors of the
LMT, and it was Mr. Dandar who got Ms. Liebreich's agreement to use
the Lisa McPherson name.  Mr. Dandar thought it would be good for the
"image" of the case to have her on the LMT Board.  Ms. Liebreich
indicated her full support of the activities of the LMT.  Mr. Dandar
was very happy about my setting up the LMT, as it was going to get
"Scientology onto the front page of the newspaper" and help create a
favorable jury pool for his case.  I purchased a building in downtown
Clearwater for the LMT for $325,000 in November 1999. When we first
opened the LMT for business on January 6, 2000, Ms. Liebriech was the
first person we called.  She congratulated us and gave us her full
support.  This phone call was recorded on videotape.

26.  I gathered the most vocal Scientology critics and most of the
anti-Scientology witnesses under the umbrella of the LMT.  I paid the
witnesses through my funding of the LMT and put other critics on the
LMT Board of Advisors.  Because I was funding both the case and its
witnesses, the wrongful death case and the LMT became virtually
27.  I paid for Mr. Prince to move to Clearwater and loaned him
$50,000 to buy a home.  I arranged for Mr. Prince to work for Mr.
Dandar as his expert.  He was paid $5,000 per month with the money I
gave Mr. Dandar.  I had Stacy Brooks set up the LMT and paid her
$5,000 a month as the LMT president.  Both were being paid by me, one
through Mr. Dandar and the other through the LMT.  In the spring of
2000, I had Mr. Prince transfer from Dandar & Dandar to the LMT, but
his salary of $5,000 remained the same.  David Cecere came to
Clearwater to be executive director of the LMT at $5,000 per month and
later, after his employment at the LMT was terminated, he became a
Scientology "expert" for Mr. Dandar in the wrongful death case.  Ms.
Brooks gave disaffected former Scientologist Teresa Summers a job at
the LMT earning $3,500 per month, after Mr. Dandar had put her on the
witness list in the wrongful death case.  I put Gerry Armstrong on the
Advisory Board of the LMT after Mr. Dandar put him on his witness
list.  I had earlier given Mr. Armstrong $100,000.  I later learned he
used these funds to forward an attack on Scientology and pursue a
lawsuit against David Miscavige and various Scientology entities.
Others on the "Advisory Board" of LMT included Ken Dandar, Dan
Leipold, Dell Liebreich, Keith Henson, Grady Ward and Arnie Lerma, all
of whom I financially supported in their litigation with Scientology.

28.  On May 24, 2000, in deposition in the wrongful death case, I
reaffirmed the agreement between the Estate and myself regarding the
case proceeds going to the LMT.  Soon thereafter, Mr. Dandar,
accompanied by Dr. Garko, his trial consultant, came to the offices of
the LMT and expressed his extreme concern to me about these public
statements and answers in depositions concerning the agreement between
the Estate, the Lisa McPherson Trust and myself, and stated that we
would have to "backtrack big time" on these statements. The reason he
gave was that my financial involvement in this case, as well as the
Estate's commitment to me concerning the proceeds, were allowing the
Church of Scientology the opportunity to characterize the relationship
as an inappropriate  "business deal" (which is exactly what it was, a
"business deal") between the Estate and myself.

29.  On December 1, 2000, after a board meeting of the LMT, Ms.
Liebreich reconfirmed to me on behalf of the Estate the commitment
that they had made to donate the bulk of the proceeds from the
wrongful death case to the Lisa McPherson Trust.

30.  Later in December 2000, Mr. Dandar phoned me and said he had an
affidavit for me to sign concerning a number of points, including the
Estate's agreement with me. I asked that he forward the affidavit to
me in New Hampshire. Shortly before December 13, 2000, an affidavit
was couriered to me from Mr. Dandar that stated in part that "Dell
Liebreich has made no promise or commitment to make any donation to
the LMT, and is under no obligation to make any such donation." I
called Mr. Dandar and told him I was very uncomfortable with this
affidavit, because this statement was completely false and
contradictory to all previous testimony. The statement also made me
uncomfortable because I saw it as an opportunity for the Estate to
renege on the agreement and that was in large part why I was funding
the case. Mr. Dandar explained to me that it was critical "for the
good of the case" to make this agreement appear to "go away" in the
eyes of the Court and the Church of Scientology. He also told me that
he would get Ms. Liebreich to sign a similar false affidavit for the
same purpose and he in fact had her do that on December 20, 2000.
Dandar also filed a false affidavit in this case that there was no
agreement.  He also assured me that the agreement was still real, but
that it would henceforth be secret.
31.  I am aware that Mr. Dandar subsequently used these three
affidavits to make misrepresentations to the Circuit Court and to the
Second District Court of Appeals.  In September 2001, during my
deposition in this case, I was asked about the agreement I had with
the Estate, and because I had signed the affidavit of December 13,
2000, I asserted a Fifth Amendment privilege. In another deposition in
the Breach of Contract case, in October 2001, I outright denied the
existence of such an agreement and "backtracked" as much as possible
by saying that I had "misunderstood" various communications from Mr.
Dandar.  I did this because Mr. Dandar insisted it would "protect" me
as Scientology had been closing in with discovery orders that I was
seeking to avoid.

32.  It was my observation and intent that the LMT was not only the
vehicle designated to receive the proceeds of the wrongful death case,
it was also used to avoid discovery in the case and disguise the fact
that witnesses were being paid.  The LMT, represented by Mr. Dandar,
maintained that it was separate from the wrongful death case in order
to avoid discovery and prevent witnesses from being deposed.  Mr.
Dandar filed many motions on behalf of LMT and me to try to prevent
discovery requests from going forward.  The truth was that LMT was
inextricably linked to this litigation.

33.  To frustrate Scientology's discovery efforts, the LMT refused to
produce evidence subpoenaed in the case, "lost" evidence and removed
evidence from the premises.  In one incident, Ms. Brooks informed me
that LMT's attorney, John Merrett, who worked closely with Mr. Dandar,
advised Ms. Brooks to leave unedited video footage in the hallway and
it would "be taken care of."  These videos of witness statements had
been ordered produced by the Court.  In another incident, on my
instructions, the hard drives from the LMT computers were removed from
the LMT before the Special Master put in place a stay regarding the
evidence in the LMT though they too had been compelled by subpoena.


34.  Several weeks before my deposition on May 24, 2000, I had several
conversations with Mr. Dandar regarding additional funds he said he
needed for the trial of the wrongful death case.  He asked me for
enough money to take him through the trial.  He told me an additional
$500,000 would be sufficient.  He told me he had a way to hide the
funds from Scientology and told me I should arrange payments in such a
way that the funds could not be traced back to me.  He told me he
would not put these funds in his client trust account and that he had
another account that Scientology could never find.

35.  Mr. Dandar also told me he did not want the money to appear to
come from me because my financial involvement was making the case too
messy and that he wanted to conceal the money from his employees, Dr.
Garko and Tom Haverty, to justify cutting back payments to them.  He
told me I should never disclose these funds were from me.  From this
point forward, Mr. Dandar told me that he would tell his employees he
was funding the litigation from his retirement account.
36.  Following these conversations with Mr. Dandar about the $500,000,
I caused a check dated May 1, 2000 in that amount to be issued to Mr.
Dandar by the Union Bank of Switzerland, payable at Chase Manhattan
Bank in New York.  I handed this check to Mr. Dandar at the Bombay
Bicycle Club in Clearwater, Florida a few days after May 1, 2000.

37.  I was later deposed about the amount of money I had provided to
fund the wrongful death case.  Prior to my deposition Mr. Dandar told
me to ignore this check for $500,000 and only concentrate "on the
checks you have written."  When asked in deposition how much money I
had provided, I testified falsely and omitted this $500,000 check.

38.  I was also served with a deposition subpoena in the wrongful
death case to produce all documents relating to my payments to Mr.
Dandar or his law firm.  Mr. Dandar told me not to produce this check
for $500,000.  He said that he had not disclosed this check to the
Court and that I should not disclose it either.  He told me that I did
not have to disclose the check because I did not write it.  He said
the check came from "Fred."  Fred was Mr. Dandar's nickname for me as
the source of  funds that would not be traced back to me.
39.  By August 2001, I was extremely reluctant to advance any further
funds to Mr. Dandar for the wrongful death case and advised him
accordingly.  I no longer believed that Mr. Dandar and Ms. Liebreich
planned to honor their commitment to me regarding the proceeds of the
case.  We had been forced to dissolve the Lisa McPherson Trust because
it had become mired in the wrongful death case.

40.  I had already loaned approximately $1.8 million to the Estate
through its attorney, Mr. Dandar, and he then approached me for more
money starting in late December 2001.  By February 2002, there was a
certain desperation in his pleas for more money.  I did not want to
provide any further funds and refused to meet with him in January 2002
in Nashville, Tennessee.

41.  The next request for a meeting by Mr. Dandar happened just prior
to his going to the Cayman Islands in January or February 2002.  He
called me in New Hampshire prior to this trip and asked me to meet him
in the Caribbean on the Wednesday of the week that he would be in the
Caymans.  He also said to me that if I wanted to send him more money,
I could wire it from my bank to a Cayman Islands bank for him.  I told
him on the phone that I would see if I could arrange my schedule to
accommodate his request for a meeting. Mr. Dandar told me the name of
the hotel I should book in the Caymans.  Once he arrived in the
Caymans, he called me again and left a message to make sure I was
going to be able to meet him there. I did not take his calls, because
I was still uneasy about any further discussions with him about more

42.  Once Mr. Dandar returned from the Cayman Islands, he again
contacted me several times.   I told him that I had no plans to
travel, but if he wanted to come to New Hampshire he was welcome.  A
date was set for the weekend of February 23,  2002. Within 24 hours of
this meeting being arranged, Mr. Dandar called and asked if it was OK
for him to "bring Michael Garko."  I said that was fine with me.

43.  The next day Mr. Dandar called me again and I mentioned to him
that money discussions would be more complicated with Dr. Garko
around. Mr. Dandar understood perfectly and said we should couch any
discussions concerning any new funding of the case in terms of "Fred"
or "your friends," or "overseas investors."

44.  Ms. Brooks and I picked up Messrs. Dandar and Garko at the
Manchester, New Hampshire airport on Saturday and we drove to my home
in Sandown.  I began our meeting by informing Mr. Dandar that I no
longer trusted him, the Estate of Lisa McPherson, or Dell Liebreich,
the Estate's personal representative.   Ms. Brooks told Mr. Dandar
that she was adamantly against my giving Mr. Dandar any further money
for the wrongful death case because I was getting deeper and deeper
into legal trouble as the case continued.  During the course of that
weekend, Mr. Dandar and Dr. Garko assured me that "the case has never
been stronger," and that all that was needed was enough money to get
the case through trial.

45.  All discussions concerning money in the presence of Dr. Garko
were couched, at Mr. Dandar's insistence, as if the money were not
coming from me but from European "friends" of mine. The purpose of
this masquerade was intended to keep Dr. Garko in the dark about who
was really providing this money.

46.  The result of this February 23-24, 2002 meeting was that I told
Mr. Dandar I would see what I could do about additional monies to
support the case. In Dr. Garko's presence I said that I would see if
my "friends overseas" were willing to be of any further assistance.
Another issue of principal concern to me was that people that Mr.
Dandar and the Estate were apparently close to, such as Patricia
Greenway, Deana Holmes, and Shirley Wilson had launched a smear
campaign against me beginning in the fall of 2001.  I believed that
the smear campaign was orchestrated by Mr. Dandar to make me feel
guilty about not providing any more funding. I told Mr. Dandar he had
to get these people to stop their campaign against me if he wanted to
get any more money from me. In fact, when Mr. Dandar returned to
Tampa, Patricia Greenway's smear campaign stopped at once.
47.  To try to alleviate my concerns about my pending contempt
proceedings, Mr. Dandar (with Dr. Garko present) reviewed with me the
approximately 86 questions that I had previously pled the Fifth
Amendment to and that Judge Schaeffer had ordered me to answer in
deposition. Mr. Dandar asked me the questions to work out how I would
answer each one. It was clear to me that he did this to help me to lie
about the funds that I had given him for the wrongful death case.

48.  One question on that list concerned a transfer of funds to the
Lisa McPherson Trust.   Mr. Dandar asked me how I planned to answer
this question.  I stated that I would tell Kendrick Moxon when he
asked me in deposition that the monies came from an anonymous source
who had contacted me by email using the nickname "The Fat Man." Mr.
Dandar gave me a very skeptical look and said something to the effect
that "Bob, nobody will believe that ridiculous answer."

49.  On February 26, 2002, Mr. Dandar sent me a letter that we had
discussed during his visit to New Hampshire. This letter was a
"suck-up" letter because I wanted something in writing from Mr. Dandar
to reassure me that he and the Estate were appreciative of all that I
had done to be of assistance to this case.
50.  The second item I wanted confirmation on from Mr. Dandar
concerned the "secret agreement" between the Estate, Mr. Dandar and
me.  Shortly after he returned to Tampa, Mr. Dandar called me and
said, "You know I cannot put the secret agreement in writing. If
anyone ever got hold of it, it would ruin the case." However, he
assured me in no uncertain terms that the agreement was still in place
and the funds would go to a group that Ms. Brooks and I would set up
once we prevailed in the wrongful death case. He further went on to
tell me that he wanted to be my attorney for the rest of my life and
that together we would "destroy these evil people."

51.  Once Mr. Dandar returned to Tampa from New Hampshire he became so
concerned about maintaining communication with me regarding getting
more money to him that he arranged to have me receive a phone
scrambling device for my telephone in New Hampshire as part of the
"trial team."

52.  On March 2, 2002, I received the Privatel Model 960V RSA
Telephone Encryption Device from Rick Spector, of Rick Spector and
Associates, who is Mr. Dandar's videographer/private
investigator/security consultant. The reference on Mr. Spector's
accompanying letter was "McPherson v. Scientology," and the letter
stated, in part, "Ken has asked me to forward the enclosed telephone
encryption device to you [sic] attention and request that it be used
for future conversations between you and other members of the trial
team,"  and "I do expect it to go a long way toward keeping 'their'
noses out of our business."  This letter confirmed my significant
involvement in the case.

53.  Mr. Dandar called me several times prior to March 6, 2002, in a
frantic state about money and asked me whether I was going to "come
through for the case" or not. He said that we needed to talk about
this seriously and as privately as possible, and in the absence of two
phone encryption devices, he suggested that we both speak on our
digital cell phones.
54.  Subsequently I caused to be issued a check dated March 7, 2002,
in the amount of $250,000 payable to Ken Dandar. Mr. Dandar called me
on the 15th of March to tell me my check had not been received at his
office. I told him I had sent it to his PO Box.  I included the check
with other papers so it wouldn't be seen by his staff. I enclosed the
check in an essay from Caroline Letkeman. (Caroline Letkeman had
written this essay in an LMT essay contest and was paid a few thousand
dollars as a prize by the LMT.  In response to an inquiry from Mr.
Dandar, I had advised him to use Ms. Letkeman as an expert witness.)
I told Mr. Dandar that the check was inside that document, at page 23.
Mr. Dandar, who was out of town, told me he sent Donna West to pick up
the overnight mail pack and then Mr. Dandar called me to confirm it
had been received.


55.  In Mr. Dandar's self-serving letter to me of October 9, 1997, he
stated that I was to have no control over the litigation.   In
contrast to this statement, I was routinely informed of confidential
information concerning the case, consulted as to its progress and sent
deposition transcripts and documents.  There have been a number of
instances in which confidential or improper information has been
imparted to me, either directly by Mr. Dandar or through his agents,
Ms. Brooks and Mr. Prince, at Mr. Dandar's suggestion.  For example,
Mr. Dandar advised me about his early mediation discussions in June or
July 1998 with the Church of Scientology. I later posted information
about those discussions on the Internet, not realizing the information
was supposed to be confidential.  I learned from Keith Henson that he
had obtained copies of autopsy photos from Larry Bedore in the Medical
Examiner's office before they were made public.  I was also told about
the content of depositions, many of which were sealed. Several
deposition transcripts were copied and delivered to me at the LMT
offices. The most recent deposition that was sent to me in email by
Mr. Dandar was that of Teresa Summers. Mr. Dandar said to me on the
phone before he sent the transcript, "You didn't get it from me."
Subsequently, Mr. Dandar filed a sanctions motion against Mr. Moxon
for not asking Ms. Summers whether or not she wanted the deposition
confidential.   Mr. Dandar gave me a copy of a Knowledge Report by
Brenda Hubert and told me not to tell anybody I had gotten it from
him.  I posted it on the Internet, in early 2000.  When I was asked in
deposition about this document, I followed Dandar's instructions, and
said it arrived anonymously in an envelope postmarked from Florida and
that I didn't know whom it had come from.
56.  With more pressure being brought to bear on me through discovery
orders, I became increasingly concerned that I was getting in more
legal trouble.  In August 2001, I asked Ms. Brooks to call Ms.
Liebreich to set up a meeting with her.  After discussion with Ms.
Brooks, it was my belief that Mr. Dandar was not informing his client
about the trouble I was getting into by advising me to lie in
deposition to protect him and the case.  I learned that Ms. Liebreich
refused to meet with Ms. Brooks after Mr. Dandar advised her not to,
and at that point I began to be extremely concerned about my position
and the possibility that I could be prosecuted for perjury.  I spoke
to Ms. Brooks about this and she and I discussed how to distance me
and the LMT from the wrongful death case in every possible way.  Based
on that discussion, Ms. Brooks and I both spoke to Mr. Prince and told
him we wanted him to withdraw as an expert witness in the wrongful
death case.  Because we were paying him, Mr. Prince wrote a letter to
Mr. Dandar withdrawing as his expert.  Ms. Brooks also formally
withdrew as a witness.  On August 24, 2001, John Merrett, an attorney
representing me and the LMT in Florida, wrote an e-mail on my behalf
informing Mr. Dandar that I would provide no further funding for the
case and that Mr. Prince would no longer be his expert.

57.  Mr. Dandar responded by filing a motion for severe sanctions
against Scientology, falsely stating that his expert Jesse Prince had
withdrawn because Mr. Prince was frightened of being harassed by
Scientology. Mr. Dandar drafted an affidavit for Mr. Prince to sign
regarding the alleged harassment even though he knew Mr. Prince had
withdrawn for other reasons.   Mr. Dandar filed this false affidavit
with the Court and used it as a basis for sanctions against
58.  I became increasingly concerned with the perjury I had been
involved in and the possibility that I could be prosecuted.  I
authorized my attorneys to contact Scientology's attorneys in early
February 2002 to initiate settlement discussions.  My initial intent
was to extricate myself from this litigation and simply walk away
without affecting the course of this litigation.  With my attorney,
Stephen Jonas, Ms. Brooks and I met with Scientology representatives
in New York.  We tried to extract concessions from Scientology
concerning the two upcoming contempt hearings I faced - one before
Judge Schaeffer and one before Judge Baird - as well as a deposition
in the breach of contract case that was also scheduled within the next
two weeks.  Scientology refused any concessions whatsoever.
Scientology made it very clear there were pre-conditions to talking
settlement, that they suspected I had been less than forthcoming in
both the wrongful death case and the breach of contract case, and that
any settlement discussions that took place would have to be predicated
on my telling the truth in those cases.

59.  I called Mr. Dandar on the evening of March 28, 2002, and he
said, "Hi, Fred!" I said, "This is not 'Fred,'" in a very stern voice,
and said, "This is Bob Minton." I then told him that he needed to
arrange a meeting with his client, Ms. Liebreich, so that the four of
us (including Ms. Brooks) could discuss the wrongful death case. Mr.
Dandar said he would contact Ms. Liebreich and get back to us.  The
next night I called Mr. Dandar and told him that we wanted to meet to
talk about dropping the wrongful death case.  I told him that after
consultation with my counsel in Boston, I knew I had to be truthful
concerning all matters in this case, starting with the deposition
scheduled for April 8, 2002, in the breach of contract case.
Specifically, I told Mr. Dandar that I would be revealing the
existence of the $500,000 check issued to him by Union Bank of
Switzerland (UBS) in May 2000 and the March 7, 2002 UBS check for
$250,000. Mr. Dandar said that I couldn't possibly disclose that
information, that he had not disclosed this to the court and it would
land him in serious trouble. Mr. Dandar was quite frantic about this
and said I didn't need to reveal the checks as they did not have my
name on them, and, as he had said several times previously, "I've told
you before to just concentrate on the checks you have written."  He
said to me that he had suspected from my call the night before that I
wanted to talk about dropping the case and, after advising his client
of his suspicion, he said Ms. Liebreich did not want to meet with us.
He said he had instructed her not to answer the phone so that we
couldn't speak with her. I made it very clear to Mr. Dandar that he
and I would both be destroyed because of the perjury if he continued
this case.  He proposed that we meet him in Cleveland on Wednesday or
Thursday, because he had a heart checkup there on Tuesday.

60.  The next morning I called Mr. Dandar again.  I kept insisting
that I had to tell the truth.  Mr. Dandar repeated that there was no
way that the two UBS checks could be revealed. When I kept insisting I
had to tell the truth, he said he did not want Ms. Brooks and me to
meet him in Cleveland or anywhere else, because, "it would give him a
heart attack."

61.  In light of this affidavit, I hereby recant any false statement I
have made under oath that may contradict my sworn statements in this


ss. Robert S. Minton

                                                ) ss.

The foregoing instrument was acknowledged before me to be true and
correct to the best of his ability this 24th day of April, 2002, by
Robert S. Minton.  He is personally known to me and did take an oath.

ss. Suzanne Davidson
Notary Public

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