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Affidavit of Jesse Prince


Case No. 00-5682-C1
Section 11

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




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 [page 1] 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 [page 2] 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 [page 3] 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 [page 4] 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 [page 5] 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 [page 6] 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 [page 7] 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 [page 8] 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 [page 9] 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 [page 10] 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 [page 11] 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 [page 12] 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 [page 13] 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.


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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 [location placeholder] Florida, this [date placeholder] day of May, 2002.

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My commission expires:

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