Defendant's Exhibit #191 in Dandar disqualification hearing

Typed-out Yingling notes

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Date: Mon, 8 Jul 2002 13:26:24 -0700 (PDT)
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[Exhibit 191]

Attendies. Sandy Rosen, Mike Rosen, Monique Yingling, Steven Jones, Bob
Minton, and Stacey Brooks

March 28, 2002

Mike Rinder: Introduction

Mike Rinder said he would make a list. re issues.

We are happy to hear their list first

Bob Minton: Wants us to go first

Mike Rinder: Most constructive way starts with broad strokes - both sides
agree need the disengagement - no Christmas cards, never hear name again

If this is what we are trying to accomplish (not like FACTNet) -- complete
disengagement -- we can do it.

Mike Rinder List

1. O/S litigation has to go Florida, France, Germany

Within Florida - all have to go
Civil case
Breach cases / TX and FL

2. Declarations and Affidavits - Jesse , Stacy, Vaughn - in order to not
have them used in future. Mike Binder - question of how to do it more than

3/. LMT - website, domain names, etc. Whatever is left of LMT

4. Movie - Mike Rinder doesn't know status or what his rights are

Mike Rinder - easy on how to resolve issues - he is just trying to
identity issues

[page 1]

Parameters of settlement
Mutual releases
No funding
No stirring up press, etc.

Terms of settlement

Mike Rinder - thinks BM probably cares more a -- BM may suffer criticism
from those he has been involved with kind regards,

Mike Ringer - believes BM is sincere about wanting to accomplish this but
doesn't have a specific way to go about it. Sandy has list of specifics
about litigation.

SJ - best to hear specifics of litigation them they should caucus

Sandy Rosin , - This is list of what BM has caused either by funding or
providing W's

Wrongful death a) 14.5
b) 4.5

Motion being prepared to bring Minion in to case - J Schaeffer comment --
provides of copy of motion

Breach case in Fl- - breach at BM's behest - Minton - party to case

a) $1,025,000
b) $1,000,000

J has entered Steven Jones on K claim -- still has tort claims against
Dell, BM & LMT

Over TRO case - $700,000
Over Courage/Movie $20,000

O/ sanctions against M. Jacobson and LM or Stagy

[page 2]


SR - gives s background
Minton provides $ to LW and L.eipold and affidavits
His support caused the alter- ego motion to go forward
a) $2,500,000
b) $3,000, 000

Sandy Rosen - w/o affidavit supplied by Mr. Minton's camp - motion would be
dismissed on its face ) ~ $8.5M with interest

Armstrong cases

Minton funded case in NEV. and supported Armstrong - case dismissed

2nd case in Nev. re defamation - over
3rd case Armstrong - contempt - Marin County - 131 violations at $50,000.00

Mr. Minton to be added to suit in Marin County for inducing breach

a) $260,000
b) $500,000

Henson - 2nd fugitive

BM not responsible for Henson but BM paid his attorneys. Berry and DC --
from that time,

a) $1,065,000
b) $350,000

Posting re BM to send to KH in exile - Joke? Stacey says no moneys was sent


Case before Minton but attorneys now being funded by BM: FG & DL

Case Settled but keeps going on:

a) $815,000

[page 3]

b) 75,000 - discovery/now have contempt and sanctions (May 31, 2002 -
trial) because of Minton funding

European Cases

France - $80,000 - These casts appear dead. SB - dead still or alive?
Germany - $25,000 - still outstanding


Not asking for any "relief" here because case settled
Mr. Minton funded attorneys when insurance ran out
GM gave money to LW and has lien filed in LW case
$750,000? BM says something like that

No attorney would take on contingency basis - so bad
Lipoid took case - funded by Minton

a) $1,535,000

Texas Breach Case

SJ questions - why 2 cases? Why one in Florida and Texas? SR says - work

Minton funding attorneys - Leibrick is defendant but has never paid Dandar

J. of $308,000 - damages fees- $555,000 - fees to get DM out of case - fee
provision in contract

SR - explains how could be liable for breach although allowed to amend

a) $555,000
u) 150,000 - Dandar motion for JNOV on 21 separate grounds

Leibrick says - Minton & Dandar reed to take care of this

[page 4]

IRS harassment

a) $30,000
b) 50,000

SR reaps awards notice re $360,000

Interest and TM disputes
Use- of LM name raised by LMT
Internet domain names

a) $ 32,000

BM no copyright infringement in TM

SR - now preparing RICO case which will encompass all damages above

a) $40,000 - research, etc.

Will be filed when wrongful death case won

Nonlitigation cases - demonstrations etc.

Security in Florida - $2,900,000
Security in other places Toronto, Los Angeles, DC, and San Francisco -

Maria Pia Ghardini

a) $22,000

BM asks for total?

SR - purpose - magnitude of what BM involved in

SJ - 2 purposes - magnitude re RICO case and out of packet costs - we get

SR - another reason -- will be in Mr. Minton's debt if he can make things
can away
- future expenditures not necessary - Oldster - 4.5 e.g. in wrongful death

SJ - outstanding litigation would have to go? Do we mean BM would have to
bring about dismissal of McPherson case.? MR - yes that is what we want

[page 5]

MR - have to get rid of case or can't separate ourselves because BM is in
because of funding

2 April - SB bank records
5 April Criminal contempt -- 3. Schaeffer
8-9 April,- deposition and sentencing on criminal contempt if doesn't

SJ what is our position on LW - Does BM have to get rid of that too?

SR - recaps BM involvement - if he caused it, he can make it go away

BM has lien - can collect he has influence
SBA -- You don't know LW

BM re funding of Leipold - never related to Lopez -- Harvey funded - DC
had problems with firm

BM - has given him substantial amounts of money - may have used it to pay
expenses while LW and Lopez going on.


SJ 1) Be responsive as possible to what we laid out

2) Lay out something they want to add to the mix that BM and SB find

Fair reading that want _______resolution of issues but________in details

Some gap re what BM can control - what can be brought along
BM - SB - JB - in some circumstances GW

SB tries to explain that they can't guarantee until will abide by agreement

SJ explains

Wrongful death

No Money or other support, withdrawal of JP and SB affidavits, commit to
be Ws,
effort to try to exert influence over- Dandar and Leibrick to resolve

SJ say can't commit to making case go away

[page 6]

SR - hope this is not harbinger of things to come because extremely
disappointed - SB
& JP already arc not W's - Dandar has told Ct would not be W's

MR & MY- let's just hear what they have to say - more _ _ way

SB& BM & JP -- willing to stop all activities in_____Church of Scientology
Exception hava to think through - website
Transfer domain names

Affidavits - commit to no further affidavits in______ litigation - no
willingness to say earlier affidavit improper or erroneous but she may
sign letter- saying does not support use of her affidavit.

No willingness to correct outstanding affidavits

LW - need to skip over this issue for the moment

Haven't decided what could be done or what commitment

BM has money in LW case and looking to get ii back - doesn't know how --
could be assignment to us of lien and then we pay $750,000 to him in "some

SR -- asks to clarify

BM - just to back up - not sure, what affidavits are in LW - Stacey's, JP
ard VY


Is friend of BM and he feels it is necessary to assist him in ways that
have nothing to do with Church

Struggle with way to do this

Could have and then get: agreement from GW that he would not be in
Scientology business arid would not use BM money against church

SR - dismiss what? Our claims
SR - yes

Movie - do not know status but agree to step back________no money

BM - 50% PA; 50% - BM

[page 7]

Alexander retains copyright

SJ_____suits - not sure what could be done

Stacey adds IRS domain

Mutual Releases
No funding
No pickets
Recognition of no impropriety

SR - haven't addressed certain of litigation

SJ -- doesn't know whit can be done in some - need specific

SR - breach case - pay us

SJ - what they need

Withdrawal of all claims, investigations etc, re BM's activities
in Nigeria
Cause the withdrawal of Claims brought by Nigerian government

Stacey away provision - Church affiliates, PIs (don't need to get into what
they think is going on), etc, SB, 8M, JP, GW - accountants, doctors, lawyers

No Surveillance or______gathering

All litigation and claims - go away - discovery, contempt, etc.

We too have compensation elements. If we want disengagement.

BM compensated for his payments in McPherson case - payments to Dandar.
-- yes.
Properties to purchase in CW
LMT building - $300,000
JP - bonuses, etc.


[page 8]

MR - listened, glad some agreed on some things.

Refers to telephone call re listened in 1998 -- We arc not in same,
place as l998.

MR did not: take their position as thinking we would pay them money -

We are not, in position of just expending money but also to point of

Re - wrongful death case -... we will not pay YOU - but I understood
it as offset.

MR - until wrongful death case goes away - we ; an not have

MR knows BM can do it - can discuss later how
BM - dreaming if thinks we will day money.

MR - can't control Nigerian government - wont BS him - can control
flow of information

No problem with complete disentanglement re Investigation, etc., if
out of our hair.

MR - maybe you are spot aware of where this litigation standards.

BM says he is not.

MR - "you are deep pocket" - everyone else is beneficiary of your money

We want to collect from you because you are inextricably linked to
the cases.

CT & DL saying Minton has to pay.

MR - not trying to posture or _________- just want to lay it out as I
see it.

MR - believes can go away - believes BM wants it to and MR wants it to.

MR wants to advance Church of Scientology - not litigate - not
investigate BM,

MR believes that BM does not want hassles in life anymore, also
think BM has
been screwed by people who have taken his money and not done things in his
best interest.

MR - we are not going to pay you money - money will flow the other way.

[page 9]

BM - if we settle cases money will go back to him
DL - not saying having to write iiim a dock

MR - we have a different perspective -- DL. and Dandar are not to get
anything out of this case -- and so I am saying you will not get your
money back.

SR - says Dandar is out there trying to protect his own behind.

SR - doesn't think BM has a clue of what is going on even in Florida,
(Maybe bad lawyers).
SR recaps sanctions and fines pending.

Dandar out there - trying to stop discovery because lie knows what
will happen.

SR believes BM can he very persuasive with Dandar.

SR - you know beaker - what is going on in this case

re Ws -- JP on retainer

SB - just wants to correct record re her status

SR - Clarifies position re Ward and we have J against him

SJ says knows we- have J but nor worth anything

SR Says our position is taut BM is liable for Ward's breach.

SJ asks MR is anything more.

MR wants to be sure that they are not expecting money - that would be
a waste
of time.

Re 1998 comment - not trying to be a wish guy - just thinks
BM doesn't
have a complete picture.

MR - we are now in position to recover some of money expended

SR, BM will not recover anything from estate - we will get our money
first in
breach cases.

BM will not get anything until other money is made.

[page 10]

SJ - appreciates details but not advancing ball _. he hears what
is being said re
our litigation options, etc. - we will have disagreement on what will
touch Bob,

SJ - do we have expectation that Florida case will go away - with
no money?
Yes -- no money from us,

SJ - no resolution Unless can have Case, go away with no money
Prone us.

MR - Yes.

BM - or we pay to have them go sway.

SJ - just want to know parameters

They Understand case has to go away - but want to be clear that we
won't pay
money to have case go away.

SB - Are we saying case dismissed or saying re: solved without paying

MR - latter - but same

SB - Issues in case people fool strongly about that aren't money.

She is trying to gauge what she can do.

SB explains re offset? Money against estate? (tries to -- get to)

SJ? What was last settlement offer made. Sandy says none since
criminal proceedings dropped

MR - can't discuss confidential mediation.

SJ -- they have _____ sources of information.


SJ - We've caucused and here is where we are

We wave greater expectations about resolving things there are warranted.

Let's break now and make some phony calls and get some sense of reality it
resolve case without money coming from the Church

[page 11

Will get back re MR - quest on money too?

[page 12]

March 29, 2002

SJ - Have thought about what via discussed yesterday that and I think best
thing is to the proceed - small toys

Understand Florida case: is essential and need to make efforts there

Won't happen overnight - some steps taken already

Meeting scheduled for Wednesday with Dandar

To bring Dell into discussions need to agree not to depose her
during discussions or not to depose her at all about discussions with BM
and SB

They are willing to take steps and arcs extraordinary but re do
that we have to dismiss.

1) contempt matters against BM
2) to postpone

Stacey's deposition re bank records
They me willing to take this extraordinary step but we must
give something in

BM - 90 questions in order to make case go sway.

SR - asks to clarify - 90 questions

SJ - says questions -- harassment all information already given

SR - wrong if think that deposition is just to find out BM
involvement in breach.
Deposition is into all financial information

SR -- we are encouraged, positive sups hope to keep momentum going.

They need to know settlement will not be on best efforts specific issues

Dell deposition - earliest scheduled would be April 12 - if we are going
to have
settlement, will have to before then - we will ask questions about any
about BM & SB

BM - can we get something in writing on dell and discussions.

[page 13]

SR - will send letter to Steve confirming - whoever deposes her will send

SR - re contempt etc. - recounts what happened yesterday in Florida

Dandar asked J. Schaeffer to continue contempt until after deposition - J
rejected this request

SR - we need to have settlement by 5 April to have it go away

SJ says we could tell J that questions have been answered.

SR says that is a lie with respect to bank records deposition - produce
for attorney eyes only, etc.

With respect to _________breach - we will not put off until we have a

We should have a settlement before April 8 - no middle ground necessary,

SR - Let us continue on to try to settle all issues - because we will
gamble that you will have success

SB - you are not willing to put oft deposition - what do we have to talk

SJ - we are tasking them to take extraordinary sups - arid we should give

BM disagrees with what happened before re teleconference with Howie.

[page 14 - end]

This exhibit was referenced during these sessions:
Monique Yingling Transcripts // June 12 2002 - AM session
Monique Yingling Transcripts // June 12 2002 - PM session

Return to Dandar disqualification hearing documents ndex