Notice of Filing Excerpts of Robert Minton Depositions

9 May 2002

Introduction by Rob Clark: These are from the Federal District Court case which flowed out of the Lisa McPherson wrongful death case in a dispute over discovery. This particular filing is by the defense in that case, which is Dell Liebreich as Personal Representative of the Estate of Lisa McPherson. Where some documents were already available in electronic form, I substituted them rather than OCR and proof from the PDF, which might result in inconsequential differences in format or markings such as page numbers or initialing of pages.

This file in 2730kb PDF


                                     IN THE UNITED STATES DISTRICT
                                       COURT MIDDLE DISTRICT OF 
                                        FLORIDA TAMPA DIVISION

RELIGIOUS TECHNOLOGY CENTER, a 
California corporation,

         Plaintiff,

vs.	                                      Case No. 8:02-MC-42-T026EAJ

DELL LIEBREICH, Individually and
as Personal Representative of the 
Estate of Lisa McPherson,

         Defendant.

 	t

                                         NOTICE OF FILING
                                EXCERPTS OF ROBERT MINTON DEPOSITIONS
                             AFFIDAVIT OF JESSE PRINCE and CORRESPONDENCE
                                    IN SUPPORT OF MOTION TO QUASH,
                                   MOTION FOR PROTECTIVE ORDER AND
                                       MOTION FOR SANCTIONS

     COMES NOW the Defendant, DELL LIEBREICH, Personal Representative of the 
Estate of Lisa McPherson. by and through her undersigned attorney and hereby 
files the attached excerpts of ROBERT MINTON, affidavit of JESSE PRINCE and 
correspondence between Steven Jonas, Esq. and Kennan Dandar, Esq. in support 
of Defendant's Motion to Quash Subpoenas, Motion for Protective Order and 
Motion for Sanctions, and Defendant would state as follows:

     1.  The excerpts from deposition of Robert Minton clearly show that all 
funds were loans to Ken Dandar or Dandar & Dandar, P.A. Thus, they never 
became assets of the Estate of Lisa McPherson.

     2.  The Affidavit of Jesse Prince clearly indicates that Robert 
Minton's 180 change of position attacking the character of Kennan Dandar 
and Dell Liebreich are motivated by undue influence amounting to nothing 
less than extortion exerted by the Church of Scientology of which Religious 
Technology Center is an entity.

     3.	 The transcripts of the ongoing hearing in the wrongful death case 
clearly indicate the amount of "duress" placed upon Robert Minton and his 
mistress, Stacy Brooks, to achieve the recantation of their sworn testimony. 
This undue influence or coercion consists of:

         a.  Naming Robert Minton to the Gerald Armstrong litigation which
             seeks damages nearing $100 million in which Robert Minton is
             the only financial viable party.

         b.  A draft of a RICO suit against Robert Minton, which Mr. Prince 
             indicates was in the amount of $110 million; and

         c.  Threats of jail made by Sandy Rosen, counsel for Religious
             Technology Center to Robert Minton and his wife, Terese Minton.

     4.  Attached are also letters exchanged between Ken Dandar, counsel for 
the Estate, and Steve Jonas, Boston counsel for Robert Minton, indicating 
that at these meetings, the Church of Scientology demanded that the case of 
Lisa McPherson be dismissed even though Mr. Minton has no control in any 
degree over the wrongful death litigation.  According to Mr. Prince's 
affidavit, when the Estate refused to dismiss the case, the alternative plan 
was to remove Ken Dandar from the wrongful death litigation. This hearing is 
presently ongoing.

     WHEREFORE, based upon the attached evidence, the court should summarily 
deny all requested relief of the Plaintiff, RELIGIOUS TECHNOLOGY CENTER, and
impose severe sanctions since RTC has failed and refused to come forward 
with the secret agreement it reached through its affiliates with Robert 
Minton and Stacy Brooks.

     I HEREBY CERTIFY that a true and correct copy of the foregoing has been 
furnished by FAX this 8th day of May, 2002, to F. WALLACE POPE, JR.,ESQ., 
727-441-8617 and SAMUEL ROSEN, ESQ., 212-230-7783.


                                   KENNAN G. DANDAR, ESQ.
                                   DANDAR & DANDAR, P.A.
                                   1715 North Westshore Blvd., Suite 750
                                   Post Office Box 24597
                                   Tampa, Florida 33623-4597
                                   813-289-3858/FAX: 813-287-0895
                                   Florida Bar No. 289698
                                   Attorney for Defendant, ESTATE






                                 IN THE COURT OF THIRTEENTH JUDICIAL CIRCUIT

                                   IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
                                                  CIVIL DIVISION



DELL LIEBREICH, as Personal
Representative of the Estate
of Lisa McPherson,
     Plaintiff,


                                                            Superior Court
vs.	                                                    Civil Action
                                                            No. 97-6890

CHURCH OF SCIENTOLOGY, d/b/a 
CHURCH OF SCIENTOLOGY, FLAG 
SERVICE ORGANIZATION, INC., et al.
     Defendant.



     THE DEPOSITION OF ROBERT S. MINTON,
called by the Defendant, taken pursuant to the 
applicable provisions of the Florida Rules of Civil 
Procedure, before Kathleen L. Good, Registered 
Professional Reporter and Notary Public in and for the 
Commonwealth of Massachusetts, at the offices of 
Cooley, Manion, Moore & Jones, LLP, 21 Custom House 
Street, Boston, Massachusetts 02110 on Tuesday, 
January 13, 1998, commencing at 9:16 a.m.

             K. L. GOOD & ASSOCIATES
        REGISTERED PROFESSIONAL REPORTERS
                  P. O. BOX 6094
           BOSTON, MASSACHUSETTS 02209 
               TEL. (781) 598-6405
               FAX  (781) 598-0815     

_____________________________________________________
                   CONFIDENTIAL






                   KATHLEEN L. GOOD & ASSOCIATES
                           P.O. BOX 6094
                         BOSTON, MA 02209
                        TEL. (781) 598-6405
                       FAX (781) 598-0815

Date:	                January 15, 1998
To:	                Stephen A. Jonas, Attorney
From:	                Kathleen L. Good

Case Name:	        McPherson v. Church of 
                        Scientology, et al.

Name of Deponent	ROBERT S. MINTON

Date Taken	        January 13, 1998

Enclosed Please Find: 
Copy of Transcript

Signature Requirements:

Original transcript (or merely original signature page)
is enclosed for deponent's signature. If the deponent wishes
to make any corrections, please use enclosed errata sheet.

Please forward the signed transcript and/or signature page 
with errata sheet, if any, to:

     Zuckerman, Spaeder, Taylor & Evans, LLP 
     Suite 2525 Street
     401 East Jackson Street 
     Tampa, Florida 33602

    ATTENTION: Morris Weinberg, Attorney


cc:  Kennan G. Dandar, Attorney
     Morris Weinberg, Attorney



_____________________________________________________
                   CONFIDENTIAL






APPEARANCES:

     Dandar & Dandar
     (by Kennan G. Dandar, Attorney)
     1009 North O'Brien Street
     PO Box 24597
     Tampa, Florida 33623-0895
     Attorneys for the Plaintiff

     Zuckerman, Spaeder, Taylor & Evans, LLP
     (by Morris Weinberg, Jr., Attorney, Laura L. 
     Vaughan, Attorney, and Lee Fugate, Attorney)
     Suite 2525
     401 East Jackson Street 
     Tampa, Florida 33602
-and-
     Cooley, Manion, Moore & Jones, LLP
     (by Earle C. Cooley, Attorney)
     21 Custom House Street 
     Boston, Massachusetts 02110
     Attorneys for the Church of Scientology

     Hale and Dorr
     (by Stephen A. Jonas, Attorney) 
     60 State Street Boston, Massachusetts 02109 
     Attorneys for the Deponent

VIA TELEPHONE: Trombley & Hanes
               (by Ronald P. Hanes, Attorney) 
               707 N. Franklin Street 
               Tampa, Florida 33602 
               Attorneys for Janis Johnson

               Ronald Cacciatore, Attorney                
               Suite 2835
               100 N. Tampa Street 
               Tampa, Florida 33602
               Attorney for Bennetta Slaughter and 
               Prodex, Inc.



_____________________________________________________
                   CONFIDENTIAL






VIA TELEPHONE: George & Titus
               (by Douglas Titus, Attorney)
               PO Box 3240
               Tampa, Florida 33601-3240 
               Attorneys for Alain Kartuzinski

               Kynes, Markman & Felman
               (by James Felman, Attorney) 
               PO Box 3396
               Tampa, Florida 33601-3396 
               Attorneys for David Minkoff, MD


ALSO PRESENT: Craig Newman, Videographer
              Cathy Ships 
              Ben Shaw










_____________________________________________________
                   CONFIDENTIAL
                               





                                                                    43

A     It was an original handwritten letter and I didn't keep
      a copy of it.
Q     We'll get to the Youngs' checks in a minute but to
      close the loop here, did you enclose a letter to the
      Youngs when you sent the checks to them?
A     No.
Q     You just sent them three checks in the mail?
A     Yeah.
Q     Did you get any written agreement from Mr. Dandar as to
      how the funds should be used?
A     No.
Q     Are there any restrictions on how the funds should be
      used?
A     Well, they're to be used for the Lisa McPherson case.
Q     For example --
A     And there are no restrictions put on by me.
Q     -- could Mr. Dandar buy a car with them?
A     That would hardly facilitate the Lisa McPherson case.
Q     I'm not being facetious. I'm asking a question that I
      would ask you to answer.
           Can these funds be used by Mr. Dandar to buy a car
     for himself? Yes or No?
A    No.
Q    Can these funds be used by Mr. Dandar for personal use

_____________________________________________________
                   CONFIDENTIAL






                                                                    44

      of Mr. Dandar?
A     Can I perhaps ask you to reask the question before,
      which was are these funds to be used for the Lisa McPherson case?
Q     it will go really quicker if you just let me ask the
      question.
                MR. JONAS: If you don't understand the
      question or can't answer the question, say that.
A     No. They're not to be used by Mr. Dandar for his
      personal use. That's nothing to do with it.
Q     How was that communicated? How were those restrictions
      communicated by you to Mr. Dandar? Is there something 13
A     Because I said it's for the Lisa McPherson case.
Q     Is there something in writing that says that?
A     Anything other than what's on my check or this letter,
      no.
Q     There is no legal agreement that has been drawn up;
      is that correct?
A     Correct. This would be as close to it as you would
      get.
Q     Did you have any communication with the family of Lisa 
      McPherson? 
A     No.


_____________________________________________________
                   CONFIDENTIAL





                                                                    45

Q     Ever?
A     I did ask Mr. Dandar in my letter to him to convey my
      sympathies to the family of Lisa McPherson and I hoped
      that this $100,000 would help in allowing this case to
      go to court where the truth could come out about what
      happened to Lisa. That's the -- that's something I
      asked him to relay.
Q     Have you ever talked to Dell Liebreich?
A     No.
Q     Have you ever talked to any of Ms. McPherson's mother's
      sisters or brothers?
A     No, no. 
Q     Have you ever talked to any representative of the
      estate of Lisa McPherson, other than Mr. Dandar as the
      attorney?
A     No, no.
Q     Do you get an accounting as to how the funds were used?
A     No.
Q     Did you ask for an accounting as to how the funds were
      used?
A     No.
Q     Is there any vehicle that you have set up to ensure
      yourself that these funds are going to be used for the
      case, for the wrongful death case?

_____________________________________________________
                   CONFIDENTIAL





                                                                    46

A     I trust Mr. Dandar.
Q     Is this a gift to -- is this a gift, the $100,000?
A     What do you mean, is it a gift?
Q     You're a businessman?  You've been a businessman for
      many years?
A     Right.
Q     You know the difference between -- you know what a loan
      is; right?
A     Right.
Q     When you loan something to someone, do you typically
      get a note or some legal document evidencing that that
      money has been loaned to them?
A     Not always but you can, yes. It's typical.
Q     So you know the difference between a loan and a gift; 
      right?
A     Yes.
Q     You know the difference between a loan and investment,
      capital investment in something?
A     Yes.
Q     My question is: Was this $100,000 a loan to
      Mr. Dandar?
A     It was.
Q     Or a gift to Mr. Dandar?
A     It requires a little bit of thought because it could be 


_____________________________________________________
                   CONFIDENTIAL






                                                                    47


      either depending on what happens in the case.
Q     Can you explain that?
A     What I have said and what he has said is that if
      they -- "they" being the estate of Lisa McPherson --
      are successful in getting money back over and above
      their legal expenses in this case and they had $100,000
      left to pay me, I would get paid back my $100,000.  If
      they do not succeed in this case, they're under no
      obligation to pay me back.
           So from my standpoint, there would be a question
      of whether it's a gift or a loan.
Q     Do you own a piece of the litigation?
                MR. JONAS: Objection to form.
Q     Do you own a piece of the litigation?
A     This $100,000 is my piece, if that's what you want to
      call it.
Q     Did you file a lien in the case?
A     No.
Q     Do you know what a UCC filing is?
A     I do.
Q     In fact, you've filed one with regard to the
      Wollersheim matter?
A     Correct.
Q     But you have not filed one in this case?


_____________________________________________________
                   CONFIDENTIAL






  IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL
CIRCUIT OF FLORIDA, IN AND FOR HILLSBOROUGH COUNTY
                  CIVIL DIVISION

3
ESTATE OF LISA McPHERSON, by and
through its Personal Representative,
DELL LIEBREICH,

     Plaintiff,
vs.                               Case No.:   97-01235

CHURCH OF SCIENTOLOGY FLAG
SERVICE ORGANIZATION, INC.; JANIS 
JOHNSON; ALAIN KARTUZINSKI; and
DAVID HOUGHTON, D.D.S.,

     Defendants.

      VIDEOTAPED DEPOSITION OF ROBERT MINTON
                     Volume II
1 2
              C O N F I D E N T I A L
13
BEFORE: MR. JOHN W. BOULT, SPECIAL MASTER
        Barr, Murman, Tonelli, Herzfeld & Rubin
        Attorneys at Law
        201 East Kennedy Boulevard, Suite 2000
        Tampa, Florida 33602









                                                     Reported by:
                                             Susan D. Wasilewski, RPR, CRR
                                                     May 24, 2000
___________________________________________________________________________
                        Sclafani Williams Court Reporters, Inc.
                Registered Professional Reporters Serving Central Florida
                Lakeland    Tampa    Sarasota      Winter Haven
                Sebring    Bartow  St. Petersburg  Bradenton



                                                                    203

                    APPEARANCES

Counsel for Plaintiff:

    MR. KENNAN G. DANDAR
    Dandar & Dandar, P.A.
    Attorneys at Law
    5340 West Kennedy Boulevard, Suite 201
    Tampa, Florida 33609

6
Counsel for Defendant Church of Scientology Flag
Service Organization, Inc.:

    MR. KENDRICK L. MOXON
    Moxon & Kobrin
    Attorneys at Law
    1100 Cleveland Street, Suite 900
    Clearwater, Florida 33755

    MR. MICHAEL LEE HERTZBERG
    Attorney at Law
    740 Broadway, 5th Floor
    New York, New York 10003

Counsel for Defendant Janis Johnson:

    MR. RONALD P. HANES
    Trombley & Hanes
    Attorneys at Law
    707 North Franklin Street, 10th Floor
    Tampa, Florida 336D2

Counsel for the Lisa McPherson Trust, Inc., and
Robert Minton:

    MR. JOHN M. MERRETT
    Attorney at Law
    2716 Herschel Street
    Jacksonville, Florida 32205

Also Present:

    Mr. Michael Garko
    Mr. Jesse Prince
    Mr. Michael Rinder
    Ms. Sarah Heller
    Ms. Wendy Beccaccini (Via Internet)                                


___________________________________________________________________________
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            LAKELAND, FLORIDA (863) 688-5000





                                                                    212

it's obvious from the question or unless I specify
otherwise is as of January 13th, 1998.	I'm not 
asking --
    A.   Through today?
    Q.   Yes.
    A.   Yes, I understand that.
    Q.   So with that parameter	in mind and for all
the questions I'm giving you, did you have or were
you in any contract with Mr. Dandar?
    A.   No.
    Q.   Have you given Mr. Dandar any money since
January 13th, 1998?
    A.   Yes.
    Q.   Tell me all the amounts that you have 
given him.
    A.	 I don't know all the amounts. The total
amounts to a little over a million dollars,
$1,050,000.
    Q.   Did you make these checks to him yourself?
    A.   Did I what?
    Q.	 Did you make the checks to him yourself?
    A.   Yes.
    Q.   Each check was drawn on one of your
personal accounts?
    A.   I believe it was, yes.
    Q.    Did you instruct anyone else to write the
checks or --
    A.    No.
    Q.    -- did you physically write them?
    A.    I think I physically wrote them all.
There may have been a wire transfer in there or
two.	I don't remember.
    Q.    Let me see if I can get the approximate
dates.
    A.    I have no idea of the approximate dates.
    Q.    How is it that you've paid over a million
dollars to Mr. Dandar since February of 1998?
    A.    No, no.  I didn't say that.  I said the
total paid to him is $1,050,000.  If you subtract
whatever the amount was before January the 13th,
which was in deposition, you will find out how much
has been paid since January 13th, 1998.
    Q.    Let's see if I can refresh your
recollection then on it. You indicated in your
last deposition you had paid $100,000 to Mr. Dandar
in October of '97.	Does that --
    A.    I don't remember.
    Q.    -- sound right to you?
    A.    I don't remember.
    Q.    How do you know that you've paid him



___________________________________________________________________________
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                                                                    218

case of the estate.
    Q.    Now, the million dollars you're talking
about were checks written from you directly to 
Mr. Dandar or his law firm, Dandar & Dandar, correct?
    A.    Correct.
    Q.    Those checks were not written to a third
party to give to Mr. Dandar?
    A.    No.
    Q.    And they certainly weren't written to Dell
Liebreich or the estate to give to Mr. Dandar,
correct?
    A.    That's correct.
    Q.    You testified yesterday in your criminal
proceedings that you didn't give money to
Mr. Dandar directly, you gave it to the family to
give to him. Do you remember that testimony?
    A.    No.
    Q.    You don't remember doing that?
    A.    No. Mr. Dandar represents the family.
    Q.    Okay. I just want to make it clear. You
didn't give any money then to the Estate of Lisa
McPherson to give to Mr. Dandar, correct?
    A.    That's correct.  I've never written a
check to the Estate of Lisa McPherson or to any of



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            LAKELAND, FLORIDA (863) 688-5000








                                                                    239

    A.    No.
    Q.    I asked you Ann Carlson, just for the 
record?
    A.    I don't remember whether you did but if
you -- I haven't had any e-mail communication with
Ann Carlson.
    Q.    Have you had any communications with Kathy 
Skelton Little?
    A.    I don't know who she is.
    Q.    Have you had any written communications
with any other family member I haven't mentioned?
    A.    Not to my knowledge.
    Q.    Do you have any agreement of any kind with
the Estate of Lisa McPherson?
    A.    No.
    Q.    Does the Lisa McPherson Trust have any
agreement with the Estate of Lisa McPherson?
    A.    No.
    Q.    Does the Lisa McPherson Trust have any
agreement with any family member?
    A.    No.
          THE WITNESS:  The Coke?
          MR. MERRETT:  -- product placement in the
    video.
          THE WITNESS:  Yeah, it's an ad for Coke.



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            LAKELAND, FLORIDA (863) 688-5000







     IN THE CIRCUIT COURT FOR PINELLAS COUNTY, FLORIDA
                   CASE NO. 00-5682-CI-11

DELL LIEBREICH, as Personal
Representative of the ESTATE OF
LISA McPHERSON,

          Plaintiff,

vs.                                     VOLUME 1

CHURCH OF SCIENTOLOGY FLAG
SERVICE ORGANIZATION, JANIS
JOHNSON, ALAIN KARTUZINSKI
and DAVID HOUGHTON, D.D.S.,

          Defendants.

_______________________________________/

DEPOSITION OF:      ROBERT B. MINTON.
DATE:               September 18, 2001, 10:18 a.m.
PLACE:              Courtroom "C," Judicial Building
                    St. Petersburg, Florida.

BEFORE:             Hon. Robert E. Beach
                    Senior Circuit Judge.
REPORTED BY:        Donna M. Kanabay RMR, CRR,
                    Notary Public,
                    State of Florida at large.


               Kanabay Court Reporters; Serving West Central Florida
                  Pinellas (727)821-3320 Hillsborough (813)224-9500 
              Tampa Airport Marriott Deposition Suite (813)224-9500





APPEARANCES:

MR. KENNAN G. DANDAR
DANDAR & DANDAR
5340 West Kennedy Blvd., Suite 201
Tampa, FL 33602
Attorney for Plaintiff.

MR. KENDRICK MOXON
MOXON & KOBRIN
1100 Cleveland Street, Suite 900
Clearwater, FL 33755
Attorneys for Church of Scientology Flag Service
Organization.

MR. MICHAEL HERTZBERG
740 Broadway, Fifth Floor
New York, NY 10003
Attorney for Church of Scientology Flag Service
Organization.

MR. LEE FUGATE and
MR. MORRIS WEINBERG, JR.
ZUCKERMAN, SPAEDER
401 East Jackson Street, Suite 2525
Tampa, FL 33602
Attorney for Church of Scientology Flag Service
Organization.

MR. JOHN MERRETT
11250 St. Augustine Road
Suite 15-393
Jacksonville, FL 32257-1147
Attorney for Lisa McPherson Trust.

ALSO PRESENT:

Michael G. Garko, PhD
Mr. Allan Cartwright
Ms. Lara Cartwright
Ms. Sarah Heller
Mr. Ben Shaw




               Kanabay Court Reporters; Serving West Central Florida
                  Pinellas (727)821-3320 Hillsborough (813)224-9500 
              Tampa Airport Marriott Deposition Suite (813)224-9500






                                                                    156

     Q    It's been characterized in different ways.
          Is there any written agreement of any kind with
Mr. Dandar?
     A    There was some agreement in that -- those first
letters, yeah.
               MR. MERRETT:  The ones that you provided
previously.
               THE DEPONENT:  That's right.
BY MR. MOXON:
     Q    Has Mr. Dandar repaid any of the funds that you've
given to him?
     A    No.
     Q    Has he told you how the case is going?
     A    Not really.
     Q    General terms?
     A    Well, I read the -- some of the transcripts that I
get hold of.  I think I have an idea how it's going.
     Q    Mr. Dandar gives you some transcripts, right?
     A    He's never given me any transcripts, that I know
of.
     Q    Does he give them to LMT?
     A    He may have.  He may have from time to time.
     Q    So you get them --
     A    But he's not very -- he's not very helpful when it
comes to transcripts.  He's not very helpful in terms of


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                  Pinellas (727)821-3320 Hillsborough (813)224-9500 
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                                                                    157

providing information if one wants it.  You know --
     Q    So it's -- the information he gives you is spotty?
     A    That would be a fair characterization.
     Q    Have you told him you'd like him to give you
better information?
     A    No.  I respect the -- the fact that his client is
the estate of Lisa McPherson, not me.
     Q    There's nothing secret about the fact that you've
given money to Mr. Dandar, is there?
     A    Not unless you're making it.
     Q    You've -- you've repeatedly made public notice of
the fact that you're giving money to Mr. Dandar in this
case.
     A    In the past I have, yeah.
     Q    In fact, you've testified about it in this case,
right?
     A    I've testified right here in this -- this case,
yeah.
     Q    Yeah.
     A    In depositions.
     Q    What makes your payments to Mr. Dandar after May
of 2000 different from the ones you gave him before 2000?
               MR. MERRETT:  Don't answer that.  He's asking
you for the basis behind your assertion of the Fifth
Amendment privilege, and that itself is privileged.


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                                                                    158

     A    That's privileged information.
BY MR. MOXON:
     Q    You're asserting the Fifth Amendment privilege?
     A    Yes.  I'm asserting my Fifth Amendment privilege.
     Q    Has Mr. Dandar told you he has any other sources
of funding for the case?
     A    I haven't discussed with him other sources of
funding, so I don't know.
     Q    He's told you he has other sources of funding,
hasn't he?
     A    I haven't discussed it.  He hasn't told me.
     Q    Well, whether or not --
          Is it your understanding that Mr. Dandar does in
fact have other sources of funding for the case other than
you?
     A    You know, I don't know what Mr. Dandar has or
doesn't have.  You'll have to ask Mr. Dandar.
     Q    Do you know of anyone else investing in the case?
               MR. MERRETT:  Objection.  Assumes facts not
in evidence, argumentative.
               THE COURT:  Overruled.
               MR. MERRETT:  Do you know of anybody
investing?
     A    I don't know of anyone investing in the case,
including me.

               Kanabay Court Reporters; Serving West Central Florida
                  Pinellas (727)821-3320 Hillsborough (813)224-9500 
              Tampa Airport Marriott Deposition Suite (813)224-9500







                                         COPY


     IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL
   CIRCUIT OF FLORIDA, IN AND FOR PINELLAS COUNTY

CHURCH OF SCIENTOLOGY FLAG 
SERVICE ORGANIZATION, INC.,
             
     Plaintiff,                    
                           
vs.                      Case No.:  00-002750-CI-20
                                           
DELL LIEBREICH, Individually 
and as Personal Representative 
of the Estate of Lisa McPherson,
                         
     Defendants.               
   
      VIDEOTAPED DEPOSITION OF ROBERT MINTON
                     Volume II
   
Counsel for Plaintiff: 
    MR. SAMUEL D. ROSEN
    Paul, Hastings, Janofsky & Walker, L.L.P.
    Attorneys at Law
    75 East 55th Street
    New York, New York 10022 

Counsel for Defendants: 
    MR. KENNAN G. DANDAR
    Dandar & Dandar, P.A.
    Attorneys at Law 
    5340 West Kennedy Boulevard, Suite 201 
    Tampa, Florida 33609  

Counsel for the witness:
    MR. JOHN M. MERRETT
    Attorney at Law
    2716 Herschel Street
    Jacksonville, Florida 32205
   
Also Present:  Sarah Heller
               Allan Cartwright
               Dr. Michael Garko
               Ben Shaw
   
   
   
   
                    Reported by:
            Susan D. Wasilewski, RPR, CRR
               October 11 & 12, 2001


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     Clearwater. 
          Do you see that?
     A.   I do.
     Q.   And is that statement accurate?
     A.   It's not.
     Q.   Huh?
     A.   It's not.
     Q.   What is incorrect about it?
     A.   It's just completely incorrect.
     Q.   Is there anything that's right about it?
     A.   No.
     Q.   Okay.  Let's take it one at a time.
          MR. DANDAR:  What date are you on? 
          MR. ROSEN:  Next to the last page of the 
     exhibit.
          MR. MERRETT:  Last paragraph, next to the 
     last page. 
     Q.   Did the family of Lisa McPherson agree to 
     donate the bulk of any funds?
     A.   No.
     Q.   Do they agree to donate anything?
     A.   No.
     Q.   Had they ever agreed to do so?
     A.   No.
     Q.   I don't want to get hung up on the word  


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     Q.   Was he limited by your agreement with him 
to use the funds that you loaned only for expenses 
in the wrongful death case?
     A.   There weren't any conditions about it.  It 
was -- the conditions were that it was to support 
that case.
     Q.   Okay.  Well, let me give you an example.  
Let's assume that Mr. Dandar's carpeting in his 
office is getting a little ratty, so he decides to 
replace it.  Was there anything in your discussion 
with him which would prohibit him from using any of 
the funds that you loaned to replace his carpet?
     A.   Like I said, I didn't put any restrictions 
on what Mr. Dandar did with the money.
     Q.   So he could use it to replace his carpet 
if he wanted to?
     A.   You know, he could walk away from the 
thing and steal the money, basically, if he wanted.
     Q.   But you wouldn't have been happy with 
that, right?
     A.   You know, I think I was able to make a 
good enough judgment about Mr. Dandar to think that 
that's not something he would be doing.
     Q.   Okay.  But by the same token, if he wanted 
to replace the carpet in his office or he wanted to 

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buy a new pencil sharpener, you know, it didn't 
have to be related to the case, right, that would 
be okay?
          MR. MERRETT:  I'm sorry, could you tell me 
     how this modifies his statement that there 
     were no conditions?
          MR. ROSEN:  Because now I'm talking about 
     his understanding of -- what his understanding 
     was of the terms of the loan.  When he spoke 
     about conditions, I think he was referring to 
     things that were articulated, that came out of 
     his mouth.
     A.   Yeah.  Look, Mr. Dandar has never 
explained to me how he spent a penny in this case.
     Q.   And you haven't asked him, right?
     A.   And I haven't asked him.
     Q.   Okay. 
     A.   So, you know, Mr. Dandar can literally do 
whatever he wants with this money.
     Q.   Well, no.  You're taking it -- you're 
taking me too literally.  I don't mean that he can, 
physically has the ability to do this.  What I'm 
asking is if he told you, for example, I used part 
of the money to replace the ratty carpeting in my 
office or to buy a new pencil sharpener, you would 


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not react by saying, hey, you can't do that, you're 
supposed to use the money just for the case, am I 
correct?  Or would you say, hey, you weren't 
supposed to do that, the carpeting is not part of 
the case?
     A.   You know, I'm not going to speculate on 
what I would do in hypothetical situations.  I 
don't know.
     Q.   Do you know whether Mr. Dandar has used 
part of your funds to buy a new car?
     A.   I don't.
     Q.   If, in fact, he did do that, would, in 
your mind, that use of the funds be inconsistent 
with what you had intended, not what you said to 
each other but what you had intended when you 
loaned him the money?
     A.   Again, you're talking hypotheticals here.
     Q.   Yeah.  My question is if he did that, 
would it, in your mind, be inconsistent with what 
you had intended when you loaned him --
     A.   Well, I'm not prepared to make a decision 
on hypotheticals.  I don't know what I would have 
done.
     Q.   Okay.  In any event, have you -- you told 
me Mr. Dandar has not given you any accounting, if 


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you will, of the moneys that have been spent.
     A.   Right, I did say that.
     Q.   Has Mr. Dandar given you any estimates or 
any -- I shouldn't say estimates, I should say any 
reports or approximations on how much money he has 
spent in the case?
     A.   No.
     Q.   Was it your understanding -- let me take 
it first in terms of what was in your mind and then 
we'll get to the discussion with Mr. Dandar.  Was 
it your understanding that Mr. Dandar could use 
some of the money to pay himself attorney's fees 
for the wrongful death case?
     A.   If he wanted to do that, yeah, he could.  
I mean there wasn't any restriction to it.
     Q.   Okay.  And that would have been okay with 
you?
     A.   Yeah.
     Q.   All right.  Because you know that he -- 
when you made this arrangement with him, you knew 
that he had signed a contingent fee agreement with 
the family, right?
     A.   I didn't.
     Q.   Okay.  Did there come a time when you 
learned that?

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     A.   No.  I always assumed it.
     Q.   Oh, you assumed it from the beginning?
     A.   Yeah.  I never --
     Q.   Okay.  So you knew from the beginning or 
you assumed from the beginning that Mr. Dandar's 
deal with the -- with Dell and the family was that 
he was on a contingent fee, in other words, he gets 
paid no fees, no legal fees at all unless there is 
a recovery, right?
     A.   You know, I'm not familiar with 
contingency arrangements.
     Q.   But did you assume that to be the case?
     A.   Yeah, pretty much.
     Q.   Okay.  So if he had signed on with the 
family to work for no fee, you know, unless he 
recovered, and then got a percentage of the 
recovery, would it have been consistent with your 
intention when you loaned him the money if he took 
some of that money and paid himself a legal fee?
     A.   There weren't any conditions.
     Q.   Okay.  So you would not have been offended 
by it is what you're saying, right?
     A.   No.
     Q.   That's all I want to know.
     A.   No.


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     Q.   Okay.  That's fine.  Did you ever 
discuss -- withdraw that.
          Did you ever reduce to writing by way of a 
letter or a note or a note on your computer as to 
what your agreement with Mr. Dandar was?
     A.   No.
     Q.   So as you're testifying today about what 
the agreement was with Mr. Dandar, you're doing 
that exclusively from memory, right?
     A.   That's right.
     Q.   And this agreement that you struck with 
Mr. Dandar respecting loaning the money, no 
interest, nonrecourse, et cetera, as we went over 
before, I won't read the whole thing, this occurred 
by way of an in-person discussion with Mr. Dandar?
     A.   On the phone --
     Q.   On the phone?
     A.   -- in person.  I think it was phone.
     Q.   And this was when?
     A.   In '97.
     Q.   November?
     A.   I don't know when in '97 but in 1997.
     Q.   I'm sorry, that's a question.  My voice 
should have gone up in the end of it.  November, 
question mark?


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                                       ORIGINAL

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, STATE OF FLORIDA
GENERAL CIVIL DIVISION


ESTATE OF LISA McPHERSON, by and		Case No. 00-5682-C1
through the Personal Representative, 			Section 11
DELL LIEBREICH
	Plaintiff, 
vs. 								
CHURCH OF SCIENTOLOGY FLAG		
SERVICE ORGANIZATION, INC.; 
JANIS JOHNSON; ALAIN KARTUZINSKI; 
and DAVID HOUGHTON, 
	Defendants.						
_________________________________/   

 APRIL 2002 AFFIDAVIT OF JESSE PRINCE
STATE OF FLORIDA
COUNTY OF HILLSBOROUGH

	BEFORE ME, the undersigned authority, personally appeared JESSE 
PRINCE, who after being duly sworn by me, deposes and says:

	I, JESSE PRINCE,  provide the following information which is based 
on 
my personal knowledge:

	1.	Affiant had been retained as the expert on the practices of 
Scientology by the ESTATE OF LISA MCPHERSON.

	2.	From 1982-1987,  I served as a corporate officer, executive, 
and 
board
member of Scientology's Religious Technology Center (RTC). RTC owns the 
trademarks 

                                                                 1    J.P.





of Scientology and licenses all Scientology organizations to use its 
trademarks.  RTC licenses all Scientology organizations to use Scientology 
trademark material.  RTC  is also the senior corporate entity of all 
Scientology or Scientology related organizations internationally.

	3.	Affiant has been a friend and confidant of Bob Minton for 
many 
years, the trial expert on Scientology for Ken Dandar in the Lisa McPherson 
death case, and the Vice President of the Lisa McPherson Trust, an 
organization which was dedicated to exposing the deceptive and abusive of 
Scientology and helping those who have been victimized by Scientology.

	4.	Affiant was picketing at the Boston Org of Scientology years 
ago 
with Bob Minton.  At this picket and in my presence, members of 
Scientology's Office of Special Affairs confronted Bob Minton and relayed 
detailed information of Bob's recent visit to his psychiatrist.  This 
greatly concerned Bob because his psychiatrist's information was strictly 
confidential.  Bob Minton acts irrational when not on his medication.  
Bob's psychiatrist then discharged Bob as his patient when Bob confronted 
the psychiatrist.

	5.	Sometime after this picket, I observed that Scientology 
posted 
on the Internet Bob Minton's confidential psychological records.

	6.	Bob Minton also relayed to affiant that Scientology obtained 
his 
bank records and telephone records, which he said caused him great 
distress.

	7.	Due to the continuous harassment of Bob Minton by 
Scientology 
and its operatives, I personally observed Bob Minton and Stacy Brooks begin 
a compilation of a timeline of Scientology attacks and noisy investigations 
of Bob Minton per Scientology practices.

	8.	At the request of Bob Minton, affiant traveled to the office 
of 
Ken Dandar in February 2002 to relay to Ken Dandar that if Ken could get 
the Internet critics of Bob Minton to stop posting criticism of Bob and if 
Ken would quit meeting with Patricia Greenway, Bob would try to arrange to 
have his friends loan additional funds to Ken Dandar.  Bob had told the 
affiant that he was still willing to help finance the case so that 

                                                                 2   J.P.





it would go to trial.
	9.     On or around March 20, 2002, affiant called Mr. Minton at his 
home in NH to see how he was doing. Affiant learned from Mr. Minton that 
Scientology operatives had discovered information about him that threatened 
his wife and children's future and Mr. Minton was very sad and upset about 
this. Mr. Minton said he no longer felt like living. He just felt like 
killing himself and things were really bad. Mr. Minton was crying as he 
told me these things. I asked him if there was anything I could do to help 
him and what specifically was the new threat. Mr. Minton told me he did not 
feel safe discussing the information over the phone and he was too upset to 
even talk about it. He told me that Stacy Brooks was leaving Atlanta, GA 
and flying to NH to help him with this new attack. I told him if there was 
nothing I could do to help him I would at least pray for him. After talking 
with Mr. Minton I immediately called Stacy Brooks to see if she would give 
me more information. Stacy said Bob was in really bad shape.  Due to the 
harrassive discovery by Scientology of Mr. Minton, he was about to fall 
apart. Stacy said she had to get Bob out of harms way and end his 
participation in opposing Scientology. Stacy said that no one including the 
Florida courts or law enforcement had been willing to help stop 
Scientology's relentless attack on Bob and she was putting an end to any 
and all liability for Bob. Stacy swore that she would protect Bob no matter 
what. She did in fact arrive in NH on the same day in question to help Bob. 
The next day after Stacy arrived in NH, I called to check and see how 
things were going. I talked to Bob and he told me he was going to contact 
Mike Rinder, who is the top executive of Scientology's legal and 
intelligence activities to see if he could work out a deal. Mr. Minton said 
he felt like he had no other choice but to take this action of trying to 
negotiate with Mr. Rinder. Mr. Minton and Stacy Brooks have in the past 
successfully ended a lawsuit with Scientology, that ended with both parties 
being pleased with the results.  I asked Mr. Minton and Stacy Brooks to be 
careful and to keep me informed of any progress. The next time I talked to 
Bob and Stacy was on or around 23 March 2002. Bob told me that he had made 
the call to Mike Rinder, and the bottom line was Scientology was going to 
put him in jail. Bob said there was a problem with some checks he had given 
to 

                                                                 3   J.P.





Ken Dandar.   After his talk with Mike Rinder, Bob said it boiled down to 
who was going to live, him or Ken Dandar, but someone was going to die. He 
said he called Ken and begged him to drop the wrongful death lawsuit at the 
demand of Michael Rinder, but Ken refused saying he had an obligation to 
his client Dell Liebreich. I told Bob that while I did not understand how 
his life would end unless he chose for Ken to die, I advised him to choose 
life, and I reminded him of his own family and how they needed him. Bob 
told me he was going to NY with Stacy Brooks to meet with Mike Rinder the 
following Friday. Thursday of the following week, Stacy and Bob flew to NY 
and called me when they arrived. Bob's attorney Steve Jonas was also flying 
in for the meeting set for the next day.  Bob and Stacy promised to call me 
after the meeting with Mr. Rinder. The next day at around noon time Stacy 
called me and she was very upset. She said that Mr. Rosen screamed at her 
and Bob that Bob was going to jail for contempt in front of judge Schaeffer 
and he was also going to jail for perjury in front of Judge Baird.   Mr. 
Rosen also said that unless the wrongful death lawsuit and the Wollershiem 
lawsuit were dismissed Bob was going to jail.  Bob told me  how Mr. Rinder 
coldly told Bob Minton that he knew was f__king him, but at least he was 
doing it to him to his face. Bob went on to tell me Mr. Rinder went on to 
say that other people who were suppose to be his friends were F__king him 
behind his back: Ken Dandar, Patricia Greenway and Peter Alexander were 
mentioned specifically. Bob told me that Mr. Sandy Rosen or Mr. Rinder, I 
do not remember which one, told Bob that he is crazy if he thinks Ken 
Dandar will ever see any money even if he wins. The same person said to 
take the Wollersheim case as an example.   Mr. Rosen told Bob that the only 
way he would not go to jail is if he got the wrongful death case dismissed 
along with the Wollersheim case. Both Stacy and Bob said they tried to 
explain the fact that they had no power or authority to get these cases 
dismissed. They told Mr. Rinder and Mr. Rosen that they had earlier tried 
to get Ken to get Dell Liebreich to drop the case but they flat out 
refused. The response was "too bad, because Bob was going to jail."  Stacy 
said that both Mr. Rinder and Mr. Rosen were being very nasty to them both 
and Bob and Stacy got up and walked out of the meeting because it was 
horrible. Bob and Stacy took the next plane 

                                                                 4   J.P.





home and were back in NH by 7:00PM the same day. Both Stacy and Bob called 
me when they got back to NH and expressed to me how deeply disappointed 
they were about not being able to reconcile anything with Scientology and 
they were putting the whole idea of negotiations with them on the back 
burner for now.

	10.     The next day, late in the afternoon I talked to Stacy on the 
phone and she told me that Mike Rinder called and said he really didn't 
understand why Bob and Stacy walked out of the meeting. She went on to say 
that Mr. Rinder said that he understood that Bob and Stacy could not 
dismiss the wrongful death suit and the Wollersheim case in CA, but there 
were things Stacy and Bob could do. I asked what were the things they could 
do, and Stacy said she did not know but they were going to meet with Mr. 
Rinder and company again in Clearwater a day or so before the contempt 
hearing on Bob Minton in front of judge Schaeffer on 5 April, 02. Stacy was 
happy about being able to negotiate with Scientology and reaffirmed to me 
that she was getting Bob out of the Scientology mess before it killed him. 
Bob was very nervous about coming back to Clearwater and he expressed that 
he felt like he was going to jail if he came back to Clearwater.

	11.     Stacy Brooks, Bob Minton and Mark Bunker arrived in 
Clearwater 
FL, from NH on the 2nd or 3rd of April, 02. Bob and Stacy got a room at the 
Harbor Bay Hotel in Tampa, FL and Mark Bunker stayed at my house in 
Clearwater FL. The following day, Stacy and Bob went to meet with Mike 
Rinder, Sandy Rosen, and Monique Yingling  at a restaurant in the Belleview 
Biltmore Hotel. After the meeting was over, Stacy called me and I asked her 
how the meeting went. She said she thought they made progress and things 
were going to be okay. I asked her specifically what were the "things that 
could be done" that would make Scientology stop trying to put Bob in jail. 
She told me she would tell me when she saw me but Ken Dandar was not going 
to be happy. Bob got on the phone and said Stacy was a lot more optimistic 
about what was happening and he was still worried about going to jail. Bob 
and Stacy had a very busy schedule meeting with Mr. Bruce Howie and Mr. 
Steve Jonas preparing for the contempt hearing with judge Schaeffer. Stacy 
and Bob asked that I not come to the hearing and she would brief me on what 
happened when 

                                                                 5   J.P.





it was over.

	12.      After the hearing on 5 April, 02, Bob and Stacy called and 
they were satisfied with the results of the hearing.  Both said that Bruce 
Howie was brilliant and Bob got off on the contempt due to a technical 
error made by Mr. Kendrick Moxon. They were very happy about this and 
invited me, and 3 other staff members that worked at the LMT out to dinner 
at Jackson's restaurant located in the hotel they were staying at.  Before 
dinner we met in the lounge/bar area at the hotel and talked about the 
hearing. Bob was still concerned and said Scientology had filed another 
suit where he was named as a defendant. He pulled the suit out and showed 
us what it was. It was a suit against Jerry Armstrong and Bob Minton. The 
suit alleged that Jerry Armstrong had broken his settlement agreement with 
Scientology multiple times and some how Bob had enabled and encouraged 
Jerry to do this. In the end, the suit asked for 80 million dollars in 
damages. Bob commented on the fact that Jerry had no money and he was sure 
Scientology would force him to defend himself in the suit and pay any 
judgments as a result.  He gave me a copy of the suit to look at and I 
pointed out that according to what I was reading, Scientology alleged Bob 
co-conspired with Jerry Armstrong to violate his settlement with 
Scientology before Bob ever knew or met Jerry Armstrong.  I told him the 
suit was crap. Bob's retort was Scientology does a lot of crap and gets 
away with it and they would get away with this suit as well. Another 
person, Ingrid Wagner, read the suit and agreed with Bob that it was not 
crap and Bob should be concerned. We talked about the next hearing and 
deposition with judge Baird that was scheduled for 8 and 9 April, 02 and 
had a nice dinner. For the next few days, Bob and Stacy continued to have 
meetings with Mike Rinder and company and both started to reveal to me what 
Scientology wanted them to do. The bottom line was Scientology wanted Bob 
to say that Ken Dandar caused Bob Minton to perjure himself in the breach 
of contract case in front of Judge Baird. The plan was to get Ken removed 
from the wrongful death case and get disbarred as an attorney. I asked Bob 
what has Ken done to deserve that?  Stacy cut in and asked me if I 
remembered a meeting that supposedly happened in the early fall of 1999. 
Stacy said she and I were at a meeting along with Bob 

                                                                 6   J.P.





Minton, Michael Garko and Ken Dandar when Ken announced that he was adding 
David Miscavige as a party in the wrongful death case. As Bob was not 
involved in the case, Ken told him if he were ever asked, the meeting never 
occurred. She asked me if I remembered that and I said I did not. Bob said 
"Jesse, we need you to walk with us on this", I said I would stand behind 
him but the meeting never happened and I was not going to lie about it. I 
told both Stacy and Bob that there was no way the case was going to be 
thrown out by trying to get rid of Ken. I told them that they were working 
with criminals who are accusing others of doing criminal acts. Bob said he 
felt horrible about what he was asked to do against Ken and he was not sure 
it was the right thing to do because it felt so wrong.  At one point he 
read a letter that Ken had recently sent him which mentioned Ken having the 
blood of Bob's wife and children on his hands if he did not get the 
wrongful death suit dismissed. I asked both Stacy and Bob what else 
Scientology wanted them to do to avoid going to jail.  Bob replied there 
was a lot more Scientology wanted him to do but he did not know when 
Scientology would be done with him.  Stacy and Bob had been working on a 
reply to Ken's letter and Bob asked Stacy to read me the reply. I started 
to feel sick as she read the response but one point really caught my 
attention: the point was that Bob alleged in the letter that I had given 
false testimony because Ken Dandar had manipulated me to write that David 
Miscavige  knew about Lisa's condition and instead of letting her be taken 
to a hospital he let her die because of the public relations flap it would 
cause. I told both Bob and Stacy there was no manipulation of me by Ken and 
my testimony is true so don't say that in the letter. Detailed evidence by 
Scientology's own policies commands its adherents to immediately report to 
RTC ANYONE who has gone psychotic as a result of Scientology's 
psychological practices. David Miscavige was and still is the Senior 
executive in RTC and has full knowledge of information sent to his 
organization. Stacy said the letter was just a draft and they were letting 
me see it to get my input. The letter was being drafted with Mr. Rosen and 
Mr. Rinders help. Bob laughed and said another thing he had offered 
Scientology as part of the settlement negotiations  was  to turn over my 
partnership in the film "The Profit" so Peter and Patricia would have to 
deal with Scientology on the 

                                                                 7   J.P.



film. I changed the subject and asked what about the Wollersheim case? 
Stacy informed me that she had talked to Dan Liepold, the attorney, and 
asked him to remove her testimony from the case. Dan refused to do it but 
Stacy said she would deal with that after they finished doing what 
Scientology wanted them to do in the wrongful death case. She explained 
that there were three witnesses for the plaintiff  concerning alter ego. 
The witnesses are Stacy Brook, Vaughn Young and myself. I told her I had no 
intentions of asking for my testimony to be removed from the case for 
Scientology and we left it at that.  The following Monday arrived and Bob 
was to be deposed by Sandy Rosen. After the deposition Stacy called me and 
briefed me on what happened in the deposition. She told me Bob was being 
deposed and she heard him tell a lie. Stacy said she had Mr. Howie stop the 
deposition so that she could clear up what Bob had just said. Stacy said 
she told Bob not to lie again and to go in and correct the record. She said 
when Bob went back into deposition he just broke down and started to cry 
uncontrollably. At that point the deposition was stopped and Mr. Rosen 
assured Bob that the record would be corrected later. The next day was the 
hearing for contempt in front of Judge Baird. Bob and Stacy had been 
meeting with Mr. Howie and Mr. Rosen to prepare Bob for his testimony. Bob 
and Stacy asked me to be at the hearing. They told me Bob was going to 
testify against Ken. I told them I couldn't believe things had degraded to 
this level. Bob said he still did not feel good about what he was about to 
do and felt it was wrong. Stacy said they had to stay on this road and get 
through this. Bob told me that Sandy Rosen assured him that if he 
implicated Ken with his testimony that Scientology would withdraw the 
contempt motion and ask that all fines be dropped. Stacy and Bob asked that 
I attend the hearing, I told them I would be there. Monday came, and I sat 
in Judge Baird's court room waiting for the proceedings to start. Bob got 
up on the stand and when he started saying Ken made him lie I got up and 
walked out of the court room. I felt like I'd been struck by lightning, and 
I started to cry. For the life of me I could not believe what I had just 
seen. Bob lying about Ken Dandar?  Mr. Rosen now acting on Bob's behalf? I 
knew I had to do something but I didn't know what. I drove to the beach to 
think. I decided that I had to somehow get law enforcement involved 

                                                                 8   J.P.





or I could lose my friends forever.  I left the beach and went to see 
attorney Denis DeVlaming.  I told him I just saw Bob Minton up on the stand 
lying about Ken Dandar because that's what Scientology wanted him to do. I 
poured my heart out to him told him everything that had happened and asked 
him if there was any way he could put me in contact with a federal agent 
that could investigate this and take the matter to a federal court. I told 
him I have to do something to help my friends. Denis said that I had been 
his client as well Bob Minton and there could be a conflict of interest, as 
Bob may need his help later. He told me his brother Doug DeVlaming knew 
someone in the FBI that might be interested in investigating possible 
blackmail and coercion. I explained the situation to Doug and he said he 
would contact someone, and for me to call him later. I left Mr. DeVlaming's 
office and went out and rented a hotel room. I did not want to see Bob or 
Stacy and I knew they would be looking for me. I called my girlfriend and 
told her what happened and that I did not want to talk with Bob or Stacy 
until they were back at home. Bob and Stacy looked for me everywhere 
calling hospitals and checking with the police. My girlfriend gave them the 
message that I was very upset and I would contact them after they arrived 
back to NH.   They calmed down and the next day Bob, Stacy and Mark left 
Clearwater, headed for NH.

	13.	The next day I was in telephone communication with Bob and 
Stacy. They wanted to know why I walked out of the hearing and what was 
wrong. I told them I could not believe what I had seen Bob do and it upset 
me greatly. I told them Scientology was making a fool out of them in my 
opinion. Stacy said the reason I felt that way was because I did not have 
all of the information. She said I had been left in the dark about some 
things that both her and Bob were not able to talk about because they had 
signed a non-disclosure agreement with Scientology concerning the 
settlement talk and it was time they brought me into the picture. She said 
it was time for me to start meeting with Scientology and their attorneys. I 
told her I was ready to start understanding what was going on. Stacy told 
me that she and Bob would be back in Clearwater on 12 April, 02 and we 
would meet and they would bring me into the picture fully. They arrived 
late that Friday, we talked on 

                                                                 9   J.P.





the phone, and agreed to meet the following Saturday at 8:00PM for dinner 
at the Adams Mark hotel on Clearwater Beach. Stacy told me that she and Bob 
were meeting with Michael Garko Saturday afternoon. She mentioned that 
Michael was upset with Ken because Ken had not paid Michael since September 
of 01. I arrived at the hotel on time, Stacy met me in the lobby and we 
went to a room on the 9th floor where Bob was. We made small talk and Bob 
told me he had something to show me. He pulled out a stack of paper at 
least 2 inches thick and gave it to me. What he had given me was a RICO 
suit Scientology had put together that named him as a defendant. At the end 
of the suit it asked for 110 million in damages. Bob said,  "So Jesse how 
much is that now? The recently filed Armstrong suit asked for 80 million, 
this new RICO suit wants 110 million in damages so that's 190 million they 
want, plus they're adding me as a defendant in the breach of contract 
cases. The only person that has money is me so it is me that will end up 
paying for all of this and I just can't do it. I can't fight them anymore". 
He went on to say that he needed me to stand with him and Stacy on this to 
pull it off. I pretended like I agreed with him and asked when would I be 
able to meet with the Scientologist. Stacy said tomorrow but we have to go 
over some things first. Bob said what was needed from me was to change my 
testimony. As he was talking the phone rang. Someone was asking where a 
package should be delivered. Bob told the person where he was and he asked 
the person to leave the package a the front desk and he would pick it up 
later and he hung up the phone. I asked him what that was all about and he 
said Scientology had been talking with him and  wanted him to change more 
testimony so as to implicate Ken further. He said the package was 
approximately 11 inches of testimony he had given before and some of it 
needed to be changed. I told him I don't know what I'm suppose to change in 
my testimony because I told the truth when I gave it the first time. I 
asked how the meeting went with Michael Garko and Stacy said really good. 
She said Michael Garko said he knew the how much the case had cost to put 
on to date and there was no way Ken had spent 2 million dollars. Bob said 
Mr. Garko said he thought Ken had put the money in an account in the Cayman 
Islands. Stacy and Bob told me how upset Dr. Garko was over not being paid 
and 

                                                                 10   J.P.





he was going to help Bob and Stacy get Ken. I looked at both of them like 
they were insane. I reminded them of an incident that happened in August of 
01 where Bob said the case was costing too much and Ken had to cut cost. 
Part of the cost cutting was to not pay Mr. Garko until the case was over. 
Bob invited me and Stacy Brooks to the top level of a parking structure 
directly across the street from the LMT to make sure there was no illegal 
surveillance going on and he said Ken is getting $500.000 and that was all 
he was going to get and it was a big secret and we were not to tell anyone 
about it. I asked them why they were both acting like they didn't know Dr. 
Garko had not been paid. They didn't have anything to say.  We started 
talking about how they were going to get the Wollersheim case dismissed.  
Bob said that he had had a conversation with Dan Leipold about getting the 
case dismissed and Mr. Leipold stated that he could not do that because he 
had an obligation to this client.  Bob was upset that Daniel Leipold would 
not agree to getting the case dismissed because he had loaned him money 
before.  Bob then told me that he offered Lawrence Wollersheim, the 
Plaintiff in a California case against Church of Scientology, $200,000.00 
of his own personal money to drop the case.   I asked Bob and Stacy, how is 
it if you are in settlement negotiations with Scientology where you are 
trying to settle cases where you are neither Plaintiff or Defendant?  I 
reminded them of a mandatory settlement conference that was scheduled to 
take place on the 19th of April.  Stacy commented that she did not think 
that settlement conference would occur because Bruce Howie and Lee Fugate 
had met with Judge Schaeffer and briefed her on the information that came 
up on Ken in front of Judge Baird and that Ken would be disqualified.  I 
asked if Ken Dandar was present when Judge Schaeffer was being briefed by 
Mr. Howie and Mr. Fugate and Stacy said no.  I told her at that point that 
they were on very dangerous grounds and reminded Stacy of an incident 
whereby I was interrogated by the FBI for five to six hours because I had 
been in a meeting with David Miscavige, Lyman Spurlock and Marty Rathbun 
along with Earl Cooley where we discussed having a Scientology staff member 
take a motion to Judge Maryanne Fauscher to get a temporary injunction 
against David Mayo.  I told her that I learned that it was against the 
rules for 

                                                                 11   J.P.





attorneys to make ex-parte contact with the Judge of record without having 
the attorney of record present.   Both Bob and Stacy looked at me 
dumbfounded and Stacy commented that she did not think that what they had 
done was a problem.    On that note we went down and had dinner and made 
small talk the rest of the evening. Bob did repeat that he needed me to 
walk with them on this, I said I would.

	14.     When I left Stacy and Bob that night I was shaking so badly 
I 
could hardly drive home and I had no idea what I was going to do to stop 
what was happening. I called a friend named Frank Oliver and asked him to 
have Ken Dandar call me as I had something to tell him. Ken called and I 
told him I knew that Bob was lying in court about Ken because this is what 
Scientology wanted him to do to stop the harassment and law suits. We 
agreed to meet at the International Mall in Tampa Florida for a meeting.  
He asked me if it was okay if Mr. Luke Lirot and Mr. Thom Haverty came, I 
told him yes. We all met in the mall and went to a lounge and I told only 
Ken everything that had been going on and I told him I could not live with 
what was going on. He thanked me for coming to him and told me how sad this 
whole thing was making him and how he could not believe it was happening. I 
hand wrote some of the details of what had been happening and signed it, 
see attached copy.   I told Ken I was willing to testify about what was 
really going on. Ken said he was going to talk to law enforcement to try 
and save Bob and get him away from Scientology. I told Ken I was having a 
meeting with Bob and Stacy again and this time I was to be fully brought in 
and I would get a chance to talk to the Scientologist myself. I told him 
the only reason I was going to the meeting was  to see the expression on 
Mike Rinder's face when I tell them that I contacted law enforcement the 
day Bob lied and that other people knew what was really going on.
	15.     Later that Sunday evening I met with Stacy and Bob at the 
Radisson hotel on Bellaire Beach. They were staying in room 502. When I got 
up there Bob had a stack of papers in is hand and said he had something he 
had to show me. He read something that was totally incomprehensible to me 
and said that what this means is judge Schaeffer did not trust me as a 
witness and there was nothing I could do to help Ken with the wrongful 

                                                                 12   J.P.





death case. He said unless I change my testimony, Judge Schaeffer was going 
to put me in jail. Things got a bit heated between Bob and me because I 
told him I had no testimony that I needed to change. Stacy suggested that 
we all go downstairs for dinner and continue the conversation. When we got 
downstairs I mentioned that we had talked enough together and it was time I 
sat down and met with the Scientologist. Bob said no, I was not ready for 
that because I needed to walk with he and Stacy down this road first. At 
that point I realized I was not going to see a Scientologist that night so 
I had better try to say or do something to get my friends to stop lying for 
Scientology.  I told them of two specific instances of when I had agreed to 
negotiate with Scientology but they never ever held up their end of the 
bargain and each time my life was ruined by them anyway. I told them I 
thought they were negotiating with the devil. I reminded them about the 
secretary of a Scientology private investigator named John Porter calling 
me and I put her in touch with Ray Emmons because she said she was in 
meetings with Mr. Porter and Scientology people where they planned months 
before in great detail how they were going to get me busted for marijuana. 
She even told me how they planned on planting seeds in my back yard. This 
information had been given to Bob when I found out about it. I was not the 
person who discussed what the secretary said, Mr. Ray Emmons did. Bob 
Minton was the one who told me about them putting the seeds on my back 
porch. I told them they were making a big mistake. Bob told me that I was 
the one making a mistake but if I walked down this road with them they 
would hire an attorney for me and everything would be okay. Both he and 
Stacy Brooks told me of a new life where we would all live in happiness and 
prosperity. I exploded at that point and told them the truth. I told them 
from the very beginning when Bob started to lie I called law enforcement 
and told them the whole story. I told them they were the ones who were 
screwed. Bob told me I was going to jail and I should leave, and I did. My 
two best friends have been backed into a corner due to the unlawful 
discovery practices of Scientology which was allowed to go on and on by the 
lower courts. The fact that there has been plenty of illegal discovery 
allowed into Mr. Minton,  the LMT and Mr.  Dandar on financial matters has  
been acknowledged  by the 

                                                                 13   J.P.





appeals courts only recently. In effect, if the law had been correctly 
interpreted and applied these matters would have never been an issue.  As  
a result, my friends are being blackmailed and coerced and are now lying 
for Scientology with the hope of getting Scientology out of their lives 
forever.  I invite the court to look at the introduction to the "harassment 
time track" authored by Bob Minton and Stacy Brooks and reconcile what was 
written then against what they are doing now and have mercy on them both.

FURTHER AFFIANT SAYETH NOT.

							____________________
___________
							JESSE PRINCE


	BEFORE ME, personally appeared JESSE PRINCE, to me well known to be 
the person described in and who executed the foregoing instrument and who 
acknowledged having executed same for the uses and purposes therein set 
forth.

	WITNESS my hand and official seal at ________________ Florida, this 
____ day of May, 2002.


						____________________________
_______
						NOTARY PUBLIC
						My commission expires:

                                                                 14   J.P.

[Handwritten]
     Within the last 6 weeks, Bob
Minton and Stacy Brooks informed me
that Scientology had gathered enough
information about Bob Minton to get
him prosecuted, convicted and jailed.
Specifically, he said (Bob Minton) that
Scientology had information to also
convict his wife Terese (sp?) as well.

Bob said "its down to me or Ken, who
lives and who dies.  I told Bob I
don't know why its that way, but if I were
you, I'd choose to live.

Bob Minton and Stacy Brooks flew to
New York to meet with Scn atty
Samuel Rosen and Moniq Yingling
to negotiate a settlement with
Scn to end the discovery in the [illegible]
[illegible] wrongful death case, and to
halt possible prosecution in Switzerland.
He mentioned that there was an ongoing
investigation of him in Switzerland.




     I talked to Bob Minton and Stacy
Brooks extensively during the time
they were in settlement negotiations
with Scn in NY and Clearwater, FL

[illegible, struck through]

The details of the conversations
I had with Bob and Stacy will be
the subject of an affodavit I
will construct tomorrow.

Tonight, Bob Minton & Stacy Brooks
at 8:00PM expect me to give false
testimony as Bob Minton has done
in front of Judge Baird 10 Apr 02.

I will meet at [illegible] and let
them know I will not cooperate
in the criminal activity Scn has them
involved in.                14 Apr 02
                   Jesse Prince












                                HALE AND DOOR LLP
                                COUNSELORS AT LAW

                                   haledoor.com
                         60 STATE STREET BOSTON MA 02109
                           617-526-6000 FAX 617-526-5000

                                                        STEPHEN A. JONAS
                                                           617-526-6144
                                                  stephen.jonas@haledorr.com



                                              April 1, 2002

By Facsimile and First Class Mail

Kennan G. Dandar, Esq.
Dandar & Dandar
1715 Northwestshore Blvd.
Suite 750
P.O. Box 24597
Tampa, FL 33607

       Re: Robert S. Minton/Scientology


Dear Ken:

     Thank you for your time on Friday. As I mentioned during our telephone 
conversation, we did agree with Scientology that the substance of the 
discussions we had with them last week would remain confidential. That is 
why I could not provide any detail to you and I hope you understand.

     One of the matters that was discussed on Friday, which I neglected to 
mention in our telephone conversation concerned Ms. Liebreich. Sandy Rosen, 
on behalf of Scientology, agreed that Scientology would never ask your 
client in a deposition any questions concerning efforts by Mr. Minton or Ms. 
Brooks to settle the Florida action after last Thursday. I understand that 
Ms. Liebrich may be deposed sometime in April and I wanted to make sure that 
you understood that Scientology agreed not to ask her any questions on that 
topic. So, for example, Scientology should not ask your client, and she 
should not testify, concerning Friday's discussions (or subsequent ones) 
among Mr. Minton, Ms. Brooks, yourself and your client. If you have any 
questions or comments, please feel free to call me.

                                                  Very truly yours


                                                  Stephen A. Jonas

SAJ:kmr
cc:	Mr. Robert S. Minton



BOSTON LONDON MUNICH NEW YORK OXFORD PRINCETON RESTON WALTHAM WASHINGTON
Hale and Dorr LLP is a Massachusetts Limited Liability Partnership and 
includes Professional Corporations  * an independent joint venture law firm






                                   DANDAR & DANDAR
                              A PROFESSIONAL ASSOCIATION
                                  A T T O R N E Y S

April 10, 2002


FAX: 617-526-5000

Stephen A. Jonas, Esquire
Hale and Dorr
60 State Street
Boston, Massachusetts 02109

RE: McPHERSON v. CHURCH OF SCIENTOLOGY
    OUR FILE NO. 54597 199

Dear Steve:

This letter is in reply to your letter of April 1, 2002. During our
telephone conversation on the evening of Good Friday, March 29, 2002, after
I spoke with Mr. Minton, you told me that Scientology had made certain
demands and threats toward Mr. Minton with the first demand being the 
absolute dismissal with prejudice of the Lisa McPherson wrongful death case.
You did not go into detail as the threats and demands made by Scientology
other than the dismissal because I refused to sign and be bound by any
confidentiality agreement that Mr. Minton may have entered into with
Scientology.

What I do understand from discussing this matter with Mr. Minton that these
threats that they have made are substantial and in my opinion, form the
classic example of extortion.

It amazes me how Mr. Rinder and his counsel believe that Mr. Minton has any
capacity to attempt to dismiss the wrongful death case let alone settle it.
He has no authority whatsoever over the Estate. I am also wondering why Mr.
Minton would even have agreed to attempt to have Dell Liebreich dismiss the
death case when he knows he has no authority or persuasive power to do so.
This to me is nothing but the best evidence that whatever they have on Mr.
Minton must be extremely damaging, in light of the fact that he told me that
if the case was not dismissed, I would have the "blood and death" of he, his
wife and two daughters on my hands.

Sincerely yours, 

Kennan G. Dandar

KGD/dmw

1715 North Westshore Blvd., Suite 750, Tampa, Florida 33607 
Mail: P.O. Box 24597, Tampa, Florida 33623 Telephone: 813.289-3858 
Facsimile: 813-287-0895,  Website: DandarLaw.com


                                HALE AND DOOR LLP
                                COUNSELORS AT LAW

                                   haledoor.com
                         60 STATE STREET BOSTON MA 02109
                           617-526-6000 FAX 617-526-5000

                                                        STEPHEN A. JONAS
                                                           617-526-6144
                                                  stephen.jonas@haledorr.com



                                              April 11, 2002
By Facsimile and First Class Mail

Kennan G. Dandar, Esq. 
Dandar & Dandar
1715 North Westshore Blvd. 
Suite 750
P.O. Box 24597
Tampa, FL 33607

       Re:  Robert S. Minton/Scientology

 
Dear Ken:

     I received your letter of April 10, 2002 and have the following 
comments. We did speak on March 29, 2002 and I did tell you that Scientology 
had made certain demands (I did not mention threats) toward Mr. Minton. One 
of them was their request that Mr. Minton bring about the dismissal of the 
Lisa McPherson wrongful death case. I did not offer to go into detail about 
the discussions between Mr. Minton and Scientology and, in fact, told you 
that through me Mr. Minton had entered into a confidentiality agreement that 
would prevent either Mr. Minton or me from going into detail about those 
discussions. We did not discuss your signing or being bound by such an 
agreement.

     If you have any questions or comments, please feel free to contact me. 

                                                  Very truly yours


                                                  Stephen A. Jonas

SAJ:kmr
cc:  Mr. Robert S. Minton







BOSTON LONDON MUNICH NEW YORK OXFORD PRINCETON RESTON WALTHAM WASHINGTON
Hale and Dorr LLP is a Massachusetts Limited Liability Partnership and 
includes Professional Corporations  * an independent joint venture law firm

			


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