Testimony of Jesse Prince (Volume 7) (July 10, 2002)


CASE NO. 00-5682-CI-11

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




PROCEEDINGS:  Defendants’ Omnibus Motion for Terminating Sanctions and Other Relief.

CONTENTS:   Testimony of Jesse Prince.1


DATE:   July 10, 2002. Afternoon Session.

PLACE:   Courtroom B, Judicial Building
St. Petersburg, Florida.

BEFORE:   Honorable Susan F. Schaeffer, Circuit Judge.

REPORTED BY:  Lynne J. Ide, RMR.
Deputy Official Court Reporter, Sixth Judicial Circuit of Florida.

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



5340 West Kennedy Blvd., Suite 201
Tampa, FL 33602
Attorney for Plaintiff.

1100 Cleveland Street, Suite 900
Clearwater, FL 33755
Attorney for Church of Scientology Flag Service Organization.

101 E. Kennedy Blvd, Suite 1200
Tampa, FL 33602-5147
Attorney for Church of Scientology Flag Service Organization.

740 Broadway at Astor Place
New York, NY 10003-9518
Attorney for Church of Scientology Flag Service Organization.

Battaglia, Ross, Dicus & Wein, P.A.
980 Tyrone Boulevard
St. Petersburg, Florida 33710
Counsel for Robert Minton.


THE COURT: You may be seated.

All right. Mr. Weinberg, you may continue.

MR. WEINBERG: Thank you, your Honor.


Q Now, Mr. Prince, you said earlier today — we got into this conversation — that you didn’t know until it was too late basically, in March of 1987, that RTC had trustees.

That is what you said, right?

A Or the role of the trustees, how that operated corporately. Yes, Mr. Weinberg.

Q And you didn’t know, until the day you were demoted, that David Miscavige was one of those trustees. You didn’t know that, either?

A Again, I didn’t know the role of a trustee, what they did. I didn’t have the — the idea of what they did. Correct, Mr. Weinberg.

Q Well, let me show you a couple of documents that we’ll have the reporter mark — reporter, the clerk.

MR. WEINBERG: This is our next document.


MR. WEINBERG: This, your Honor, is 229.

And this one would be 230, right?


MR. WEINBERG: This, your Honor, is 230.



Q Mr. Prince, this is 229. The thick one is 230.

A Okay. Is this stuff that I keep later?

Q Yes, we can just keep it here for the moment, and then if there is any originals — there is one —

THE COURT: If there are any copies, you can keep them, or give them to Mr. Dandar, or —

MR. WEINBERG: I’ll return these exhibits back to the clerk.

THE COURT: If they’re originals, you need to be sure they get back to the clerk.

THE WITNESS: Yes, your Honor.

MR. WEINBERG: Before I forget, let me return these exhibits for some reason I took.


Q All right, now if you’ll look at 229, Mr. Prince —

A Is that this one right here?

Q That is the short run, Unanimous Written Consent of the Directors and Trustees of the Religion Technology Center.

A Yes.

Q Do you see that?

A Yes, I do.

Q And you see you executed that document as a



A Yes. Yes, sir, I see my signature on there.

Q You see the three trustees executed that document as trustees, Lyman Spurlock, David Miscavige, and can you read the last one?

A Mmm, David Miscavige is the last one, isn’t it?

Q I think it is the second one.

A The second one is I think looks like Starkey.

Q David Miscavige is the last one. Do you know who the second one is?

A Norman Starkey. And the first one is Lyman Spurlock, I believe.

Q So certainly at that point in time you must have been aware there were trustees?

A Mr. Weinberg, I’m going to say this and it may sound incredible, but as a director, at least in this corporation, Mr. McShane was actually the secretary. I would often sign things because it was required to be signed.

You know, this isn’t anything that we all signed simultaneously. This could have been given to me and Vicki signs it, Jesse signs it, Warren signs it, send it along to OSA, then they sign it.

Q You were familiar, as director, as you said, the number two guy in RTC, you were familiar with the bylaws of the Religious Technology Center, correct?


A You know, I wouldn’t say so.

Q Well, can you pick those bylaws up, please?

A Yes, I can.

Q What is the exhibit number on that?

A Mine doesn’t have an exhibit number.




Q And do you see that if you go to the last page, it is dated June 15, 1982?

A Yes.

Q All right. If you go to —

MR. WEINBERG: In fact, if I can approach the witness it will be easier.

THE COURT: All right.


Q — Article 6, Section 1 —

A Where am I?

Q Article 6, Section 1.

A That is Article 7, so this must be Article 6 right here. Section 7 — what section number?

Q Article 6, Section 1. Right here.

A All right.

Q See that?

A Yes.


Q And that is trustees. You see that?

A Uh-huh. Yes.

Q And you see that the bylaws of the organization that you say you were number two in says, and I quote:

“The sole purpose of the board of trustees shall be to elect directors of the corporation. In furtherance of this purpose, the trustees may remove a director who fails to meet the qualifications of a director or who conducts himself in a manner which is contrary to the provisions of Article 1 through 4 of these bylaws and the survival of Scientology. In addition, the trustees shall have the power to change the trustees.”

Isn’t that exactly what happened in March of 1987, that you and Vicki Aznaran were removed by the trustees pursuant to the bylaws of the RTC because you-all had failed to meet the qualifications of a director because you conducted yourself in a manner that was contrary to these bylaws and the survival of Scientology because you had been part of an out-tech operation?

A Is that a question?

THE COURT: That was awfully —


THE COURT: Break that down.

A My signature isn’t on here, by the way, as a director on these bylaws.


But these bylaws are signed by Steven Marlowe, Laura Marlowe and someone else.


Q Right, because in 1982 you weren’t a director, you became a director after 1982.

A That is correct.

Q And I assume when you became director, you said you had all this responsibility, you must have — must have familiarized yourself with what the purpose, as set forth in the bylaws and articles of incorporation of the organization that you were part of, was.

A Well, that, in itself, would be an assumption that would have to be ratified by my testimony. And my testimony is, is that I have never been a person that was legal-minded and really understood corporate and bylaws and things like that. I just wasn’t.

THE COURT: Did you ever read this document?

THE WITNESS: I can’t say that I have.


Q But you —

A My signature is not on any part of this.

Q You understand now, after having seen this document, seen Title 6, you understand that you were removed in March of 1987 pursuant to the bylaws of RTC by the trustees as a result of your misconduct? You understand


that now, don’t you?

A No. No.

THE COURT: He already testified why he believes he was removed. It would not be consistent with this.

Obviously, the directors, if they were here, would testify differently that it was pursuant to this.

MR. WEINBERG: The trustees.

THE COURT: The trustees.



Q Mr. Prince, you can put that down.

A Okay.

Q Now —

THE COURT: I mean, I guess pursuant to your question as to wasn’t this true and wasn’t that true where he said no, that was coming from somewhere.


THE COURT: So I assume — that would have been what somebody else might have said, but he disagrees with that.



Q Now, you testified on direct that as soon as — as it became known that you were now going to work against


Scientology, that you were threatened by Elliot Abelson, the lawyer, is that what you said?

A I said I received a letter threatening to sue me from Mr. Elliot Abelson.

Q And — and you understood from receiving that letter that the problem was that you had signed a release upon your departure from Scientology — from the Sea Org in 1992, among other things promising not to — to work against the Church of Scientology, or something to that effect?

A I would have to see that, if you —

Q Okay.

A — have it here.

MR. WEINBERG: Let me have a couple of things marked, your Honor.

Your Honor, here is 231. It is one exhibit.


Q This whole package is 231, Mr. Prince.

A Okay, thank you.

Q Now, do you see Exhibit 231, Mr. Prince?

A I’m looking at it right now, Mr. Weinberg.

MR. WEINBERG: While he’s looking at it, your Honor, I’ll mark as 232 the following document.


Q That is 232.

A Okay.


Q Have you had a chance to look at 231?

A Yes.

Q All right. And is that the correspondence that you remember getting from Mr. Abelson?

A Yes.

Q And that includes a letter that — which is the second page — sent by hand-delivery to you in Minneapolis on July 24, 1998 from Mr. Abelson, along with a copy of the release. And then the first page is a letter of that same date to you in care of Leipold, Donahue & Shipe, do you see that?

A Yes, I do.

Q And is this the full extent of the communications between you and the Church of Scientology, Mr. Abelson, at that time in July of 1998 with regard to whether or not you could or would be a witness?

A Mmm, no. As I worked — I mean — I mean, I had private investigators actually trying to stop me on the street to hand me this letter.

Q I’m just asking you about any other communications with Mr. Abelson.

A With Mr. Abelson? Not that I recall specifically.

Q Then am I correct that you got Mr. Leipold, who you were already working with, I guess, at the time, to file a lawsuit?


A Correct.

Q And that is Exhibit —

MR. WEINBERG: What did I say? The lawsuit?

MR. DANDAR: 232.


Q And that is Exhibit 232 in front of you, correct?

A Yes.

Q And that was a lawsuit filed on your behalf in — that was filed — date filed August 6, 1998 in Superior Court in California seeking to declare the release, which is one which is attached to that first exhibit, not valid as it pertained to your testimony. Is that right?

A You know, I’m sorry, Mr. Weinberg, I’m a little tired. But, you know, the question gets long. Then I don’t know what I’m supposed to be answering.

Q The purpose of this was to try to allow you to work in cases against the Church of Scientology?

A No. Not at all.

THE COURT: A dec action normally just to  declare the rights of the parties.

MR. WEINBERG: That was my first question. And I tried to make it simpler.


Q I mean, you were asking the Court to declare that the release did not prohibit you from testifying?


A If that is what this says, yes.

Q Okay. And this case never — it just lay — you never prosecuted this case. Is that right?

A No, I never pursued it.

Q And the Church of Scientology didn’t — didn’t file any lawsuit against you?

A No.

Q And that release that was attached is the release that you were talking about that you signed in 1992, is that right?

A Under extreme duress, yes.

Q The extreme — did you sign it on the day that you left?

A I signed it on the 31st of October. But for whatever reason, Mr. Rathbun thought it would be more appropriate to make it November. So he wrote “November 1st” here.

But the actual date that I left that I was taken to the airport by the Scientology security official was the 31st of October.

Q Was it late at night that you signed it?

A No. But it was in the evening.

Q All right. Does it make a difference whether it is November 1st or October 31st?

A It makes a difference as far as accuracy is concerned.


Q And on this same day, you were — you talked to Mr. Rathbun in — in a recorded conversation?

A Yes.

Q And were you under any duress?

A Extreme duress, as is laid out in this complaint.

Q Did he threaten you during the conversation on the 31st?

A I was way past being threatened.

Q That was a simple question. Did he threaten you during the conversation that was recorded on the 31st?

A I don’t know. I would have to listen to it again.

Q Do you remember being threatened?

A No, I do not.

Q When you say duress, what are you talking about?

A Well —

THE COURT: He already talked about it throughout his testimony as to the whole schmear.

MR. WEINBERG: This is the last day when he decided to walk out.

THE COURT: I understand that, Counselor. But he already testified as to how he felt threatened and how he felt coerced and all that and how it came about.


THE COURT: All this long tenure. But if you


are specifically asking about right before he signed is —

MR. WEINBERG: That is what I’m asking.

THE COURT: But don’t suggest that is all he’s talking about because he talked about —

MR. WEINBERG: No. No, I’m talking about on the 31st when this was recorded.

A I’ll give you a simple statement. Unless I signed this, I would have been — remained a captive. Unless I did this, I would have remained incarcerated by Scientology.


Q Now, the first time that you — in 1987 when you went into the RPF, you actually walked out on your own, didn’t you?

A What do you mean?

Q Well, you have testified about it. You actually left the RPF and went into town, checked into a hotel —

A Escaped. I escaped. It just wasn’t walking. No. I escaped. And some Indians from the Soboba Springs Reservation put me in a truck and drove me to bingo hall so I could call the police. No, I escaped. I ran away from that place.

Q So you didn’t see Mr. Rathbun or anybody like that who paid for a hotel?

A Oh, they caught me on the road walking.


Q And they took you into town?

A Yeah.

Q So —

A In the back of a truck.

Q They didn’t take you back to the RPF?

A I wasn’t going to go back to the RPF. I made that clear. I told them if they wanted to speak with me or continue any kind of dialogue with me, it would be on my terms and not on their terms and — no longer on their terms.

That if they wanted to talk to me, I would sit still in a place a while.

So they went and paid for a hotel. I went and got a car, drove straight back to the RPF and got Vicki Aznaran out of there. Vicki Aznaran didn’t want to be there, either.

Q And they let her go, too?

A No. They had no choice.

Q What do you mean, they had no choice?

A I came in there with a car, driving up their dirt road so fast. I knew exactly where she was. As soon as I went in there, I grabbed her, put her in that car and we zoomed out the gate.

Q But the first time when you left, Mr. Rathbun picked you up on the road, and instead of taking you back to the RPF, he took you to a hotel in town and paid for a hotel



A At my demand, yes.

Q Well, if you are a prisoner, what right do you have to demand anything?

A Because I’m in the public now. You see, I’m in the open now. I’m not in Scientology’s closed system where they can do whatever they want to and people can’t see. Now I’m out on the public road with public cars passing

by. And that affords — afforded some protection because it was a PR flap.

For me to be out there, a disgruntled staff member, extremely disgruntled staff member, leaving for my life, my God, I’m walking through the desert, it is 110 degrees, that is the reason why.

I told them, “I’m going straight to the police, straight to the press. I’m sick of you people.”

Q This is in 1987?

A Correct.

Q Then after a week or two or three or whatever it was, you then voluntarily went back to the RPF?

A No.

Q From the public?

A Mmm, Mr. Weiner (sic), you know on direct we covered this quite well, and I explained the whole situation about my wife, you know, how they wanted to split my wife


and I, I didn’t want to be split with her, I stayed there an extra five years until she came to. You know, I have that same testimony today.

Q One simple question. No one drug you back.

A Correct.

Q Now, you testified that — I think that you were shocked about private investigators and how a private investigator has been running around. I mean, I think —

THE COURT: Shocked? I don’t recall him being shocked.


Q How do you recall it?

A Annoyed. Kind of surprised.

Q Now, after you left the Church of Scientology in 1992, you actually became trained and worked in Texas as a private investigator, didn’t you?

You were certified?

A Correct.

Q And the person that trained you was Rick Aznaran, who had years before left the Church of Scientology?

A In 1989, I think — no, it was five years prior to me leaving. So, yes.

Q How long did you work as a private investigator?

A Oh, probably maybe — maybe four months, five months.

Q Now, let’s go to your August 1999 affidavit.


A Okay.

Q You are familiar with that affidavit, obviously. Right?

A Well, Mr. Weinberg, if we’re going to go through and do the word games with it, I certainly need to have it present in front of me.

MR. DANDAR: I might have it.

THE COURT: Which affidavit is this?

MR. WEINBERG: This is the one that the hearing is about, basically.


MR. DANDAR: I take that back. I thought I had it.

MR. WEINBERG: Do you have a copy of it?

THE COURT: Did you say this was the one dated the 1st of May of —

MR. WEINBERG: No. No. When I said the hearing, this is the August 20, 1999 affidavit, the one where the murder allegation was made.

THE COURT: I thought you said about this hearing.

MR. WEINBERG: Well, you know, it is the —

THE COURT: What number is that, Madam Clerk?

Could I have that? I don’t have it up here.

MR. DANDAR: I’ll object. There was no murder


allegation in the affidavit.

THE COURT: The objection is on the record.

We’ll deal with — the affidavit says whatever it says.

MR. DANDAR: It says what it says.

THE COURT: It says what it says.

MR. DANDAR: I just can’t find my copy.

THE COURT: This one, is this 108 or something like that?

MR. DANDAR: It is very possible.

THE COURT: Madam Clerk, look for 108, see what that is.

THE CLERK: Defense 108 or —

THE COURT: Oh, I don’t know.

MR. FUGATE: It is not 108, Judge.

THE COURT: No, that is not it.

MR. WEINBERG: Judge, I have one that I don’t think have any highlights on it — well, one highlight, nothing much.

THE COURT: That is all right, I don’t mind the  highlights.

MR. WEINBERG: I can’t even find the one that did have highlights.


Q Do you have one, Mr. Prince?


A No, I do not.

Q Okay, I have another one.

THE COURT: This is in evidence or else it is attached to the response.

MR. DANDAR: And we would like it to be considered as evidence in this hearing.

THE COURT: Okay. Well, it needs to then be admitted — it hasn’t been admitted. Do you want to admit it as the defense next exhibit?

MR. DANDAR: That is fine.

MR. WEINBERG: How about plaintiff’s next exhibit?

MR. DANDAR: Or it could be a joint exhibit.

MR. WEINBERG: Frankly —

THE COURT: Make it your exhibit, Mr. Dandar.

MR. DANDAR: As well as the April 2002 exhibit of Mr. Prince which is also filed.

MR. WEINBERG: I am not to that one yet. Why don’t we start with this one?

THE COURT: All right.

MR. WEINBERG: I think — are these the exhibits to it?

THE COURT: I don’t know that —

MR. WEINBERG: Yours don’t have it but it is just —


MR. DANDAR: Judge, I actually —

THE COURT: I don’t know what that is. Was it attached to his affidavit?

MR. WEINBERG: Apparently so.

THE COURT: Let me see it.

MR. DANDAR: It is Plaintiff’s Exhibit 126.

Yes, Plaintiff’s Exhibit 126.

THE COURT: Do you remember, Mr. Dandar, whether there were any attachments to his? I honestly don’t remember attachments, at least I wasn’t given — in the copy I was given. It doesn’t mean there weren’t some.

MR. DANDAR: My copy with me today has nothing attached to it. But —

THE COURT: Well, let’s just look, because if there are no attachments to it, then you need not —

MR. WEINBERG: This wouldn’t be something we want in, anyway. These are not attachments. But I think we’ll probably find that he refers to some in  here somewhere.

(A discussion was held off the record.)

MR. WEINBERG: Judge, why don’t we do this. I marked one without the attachments. Why don’t we just mark it without the attachments?



MR. WEINBERG: Then we won’t have —

THE COURT: That will be plaintiff’s next in order.


THE COURT: There will be no attachments. If you later find out there are attachments with it —

MR. WEINBERG: He already put into evidence the — with the motions —

MR. DANDAR: It is already in as 126 of the plaintiff.



THE COURT: It is already in?


THE COURT: Then we don’t need it in again, Counsel. Number 126.

MR. WEINBERG: But it doesn’t have attachments.

THE COURT: I’ll just use this one and give it back to you when we’re done. Whoops, now I have two of them.

MR. WEINBERG: I know, because I had given you one with attachments and one without.

THE COURT: I’ll use them. And when I’m done, I’ll give them both back to you.

THE WITNESS: Mr. Weinberg, I would like a


copy, as well.

THE COURT: Here. Take mine, the extra.

THE WITNESS: Thank you, your Honor.

THE COURT: Now, Mr. Prince, did I give you Pages 1 through 18?

THE WITNESS: Yes, your Honor.



Q First of all, take a look at that affidavit. And go to the last page. And that is an affidavit that you executed on August 20, 1999, is that right?

A Correct.

Q And you executed it in Mr. Dandar’s office?

A Correct.

Q Now, you can put the affidavit down. I have some questions first.

A Okay.

Q You had, as of August 20, 1999, no personal knowledge as to what occurred in 1995 with regard to Lisa McPherson at the Ft. Harrison Hotel. Correct?

A Correct.

Q You had — at that time you’d been out of Scientology, out of a — sorry, by that time you’d been out  of an executive position at Scientology for — since 1987?

A Correct.


Q You were not at the Ft. Harrison Hotel in 1995.


A Correct.

Q You never spoke to anybody that was with Lisa McPherson while she was at the hotel in 1995. Correct?

A Well, let me think about that.

Q As of the time you executed your affidavit?

A Oh, not that I recall.

Q Okay. You had — at the time that you executed your affidavit in August of 1999, you had no knowledge — no personal knowledge as to what David Miscavige was doing or where he was from November 18, 1995 through December 5, 1995. Correct?

A Yes.

THE COURT: Yes, that is true?

THE WITNESS: Yes, that is true.

THE COURT: Okay. Now we are in important areas so I want the record to be clear on things like that.



Q Now, yet you opined in your affidavit —

MR. WEINBERG: Excuse me one second. (Short pause.)



Q If you go to Page 17.

A Okay.

Q You opined in your affidavit, in Paragraph 44, that:

“Lisa McPherson was held against her will in isolation. And when she did not respond to Scientology technical handling, Flag, on orders from David Miscavige, Ray Mithoff and Marty Rathbun, sat mute and watched her die after she no longer had the strength to fight for her freedom. Her death was no accident. It was a chosen option to minimize a public relations flap.”

That is what you said, correct?

A Correct.

Q At the time you said that, you did not have a shred — you did not have a piece of evidence indicating — indicating that in November and December of 1995 that either Mr. Mithoff or Mr. Rathbun or Mr. Miscavige had done one thing with regard to Lisa McPherson. Correct?

A Mmm, correct. I — you labeled this as my opinion, I think. You said I opined about these and this is what I did.

Q Go to Paragraph 34 — I mean Paragraph 43. I’m sorry, Page 17, same page. Paragraph 43, you say:

“Yet from the available records, it is apparent to me that these three individuals, Mithoff, Rathbun and Miscavige, had no


option other than to permit her to die in isolation, rather than to take her to the hospital for emergency medical treatment and risk embarrassing questions from the attending physician, press and authorities, with likely claims of imprisonment and abuse being made by Lisa McPherson upon her recovery.”

You said that. Right?

A Correct.

Q And — but when you said that, you didn’t have a shred of evidence that indicated that Mr. Mithoff, Mr. Rathbun or Mr. Miscavige made a decision to let her die.


A This was my opinion, based on experience.

Q You didn’t have any evidence, did you?

A I had no physical evidence, no.

THE COURT: Could I ask him a question here?


THE COURT: I hate to interrupt. At that time, at the time you wrote this, had the doctors, more particularly, Dr. — I can’t even think of his name now.

MR. DANDAR: Spitz.

THE COURT: — Spitz, had he been deposed yet?

Do you know, Mr. Prince?

THE WITNESS: I do not recall, your Honor.


THE COURT: In other words, this was before you had the medical testimony?

THE WITNESS: Mmm, I wouldn’t say that, either, no. I — I’m not sure about that, either. I know I have read medical testimony from Mr. Dandar’s experts concerning what —

THE COURT: Do you know whether you had knowledge of what that testimony — I mean, I have to presume you and Mr. Dandar, as his consultant, discussed what he knew, what you knew.


THE COURT: But do you know whether or not you knew about the medical doctors before you wrote your affidavit, or not?

THE WITNESS: I — as I sit here today, your Honor, I don’t know.



Q But you did know that the Church of Scientology had been charged criminally at this point. Right?

A Yes.

Q You were aware of what the medical examiner had said, correct? The autopsy report, all of the controversy? I mean, you were aware of all of that?

A Yes.


Q Now, you knew that by making an allegation like you did in your affidavit in August of 1999, that David Miscavige, the leader of the Church of Scientology, was part of an intentional decision to allow a fellow Scientologist who was on a religious program, introspection rundown, to die. You knew that making an allegation like that would — would be — would bring very negative press and very negative reactions from the Church. Correct?

A You know, Mr. Weinberg, I don’t know which part of that diatribe to respond to.

THE COURT: It wasn’t a diatribe. He said did you know that this would bring very negative reactions from the Church?

THE WITNESS: I mean, that was not in my awareness. That was not part of my thought process when I executed this document here. My thought process, in executing this document, is after reviewing the preclear folders, reviewing the caretaker notes, reviewing what other information that was available, which I had studied for months — you see, you say she was on the introspection rundown, yet your client cannot produce one sheet of paper —

THE COURT: See, you are well, well past —



THE COURT: This question is real simple. His question was did you know, when you executed this affidavit, that this would cause negative reaction — I can’t remember what word you used — negative reaction from the Church?

THE WITNESS: Right. That was not in my conscious — consciousness to create that, you know, or — or — I mean I don’t think this ever appeared in the newspaper or — or anything like that. I mean, as far as public relations is concerned, I think this is a document that is held within this courtroom.


Q No. It just appeared in a lawsuit that that document was the basis for that accused the Church of Scientology, specifically its leader, David Miscavige, of murder. It appeared in that. Right?

A I prepared this — this affidavit for this case.

Q Right. And that affidavit was the — was the principal piece of evidence that was used to seek the fifth amended complaint that made it very clear that there was a murder allegation against David Miscavige, among others. Correct?

A You know, you’re asking me to do — or to comment upon work that was actually Mr. Dandar’s work. Mr. Dandar


simply asked me, “What do you think happened with Lisa McPherson? Based on everything that you have read, what do you think happened to her?”  Then we went, “Well, why do you think it happened to her? Well, can you show me? Can you tell me?”

And after we went through that process, I went over this many times because he was like, “Are you sure? Are you sure?”   I said, “Look, this is the way it works here. I was here. I know how it works. I have seen this in operation.” You know, I’m not —

THE COURT: Mr. Prince, you are going on and on. And the long and short of it is you testified on direct examination, in response to questions either from your lawyer — or I should not say your lawyer, either from the person to whom you consult with or from me, that you’d never seen an end cycle ordered by David Miscavige —


THE COURT: — other than on a terminally ill person.


THE COURT: So the long and short of it is you really didn’t have any experience for these particular serious allegations, did you?


THE WITNESS: Yes, I did, your Honor. And I think with the first part of my testimony, when you see the pattern of the conduct of this organization in that it is not below them to do something illegal, it is not below them to put themselves before an individual, it is —

THE COURT: Well, then it was just speculative on your part. This is one of a number of possibilities that could have happened?

THE WITNESS: Right. Exactly.

THE COURT: This just happened to be the only one you mentioned?

THE WITNESS: Well, this is the only one I believe did happen.




Q You knew — at the time you executed this affidavit that was the basis for the fifth amended complaint, you knew that there was no policy, no written policy, in the Church of Scientology with regard to killing someone who was on an introspection rundown. You knew that, didn’t you?

A Basically — no, there is no policy to kill people. There is nothing in the policy to kill people that


I know of.

Q Okay. And you have said many, many times over the course of this litigation if it isn’t written, it isn’t so. Correct?

That it is — it is all in writing, it is all written down, as far as Scientology policy. Correct?

A As far as Scientology policy is concerned, that is something that they say.

Q All right. Now, you had been — you had one experience with the introspection rundown where you actually were on an introspection rundown watching someone. That is Teresita. Correct?

A Correct.

Q And Ms. Brooks was on that same introspection rundown. Right?

A For a short period of time, yes.

Q And in that — and that went over the course of a month or so?

A A couple months.

Q A couple of months?

A Yes.

Q And people were with Teresita around the clock?

A Primarily myself was with her around the clock. But, you know, her being a young woman, sometimes she would need help going to the bathroom or, you know, cleaning herself up. That is when the girls would come, like Stacy


and another girl would help.

Q And part of 0 and 00 of the introspection rundown is the isolation part, right, which is what this watch was, and also getting food and — and nutrition so you can start auditing, try to get out of the psychotic state.


A Almost correct. But the auditing pretty much happens immediately after the person has had a period of time asleep, such as eight hours, the auditing is immediately started.

Q If someone is still psychotic, in other words, out of their mind, not — not in present time, they can’t get audited, can they?

A Well, you know — no. You can audit an unconscious person. There are auditing processes where you can actually audit an unconscious person.

Q You didn’t receive an order to let Teresita die, did you?

A No. I did not.

Q No one received an order to let Teresita die?

A No.

Q Teresita was a staff member —

A Correct.

Q — who had a psychotic break, apparently.


A You know —


Q Can you just answer that question?

A Okay, I am going to answer. But, you know, you talk about psychotic break. And again, you know, what are we talking about here?

THE COURT: We’re talking about somebody that barks like a dog, which is what you said she did.

That is somebody that had a psychotic break.

THE WITNESS: Yes. Okay. Am I qualified to do a medical diagnosis? I don’t think so.

THE COURT: No, but we are all qualified in this room to know that somebody that is barking like a dog had something go wrong. And it is usually psychotic. Fair enough?

THE WITNESS: Is it temporary? Does it go on for weeks? Does it just happen for an hour? I mean, what are we talking about?

THE COURT: Let him ask his question and let him answer and we’ll all make our assumptions when it is over.


Q All right. What I’m talking about, when you were with her most of the time, you saw to it that she ate and that she drank. Correct?

A Correct.

Q And you — I think you have said in testimony,


whether it is — I think it was your affidavit, this affidavit that we’re looking at, 126, that at one point you thought that she was — was going to die, I think you said. Correct?

A Correct.

Q Because you were concerned that she wasn’t getting enough to drink or enough to eat?

A No. That is not why I thought she was going to die. I thought she was going to die because she couldn’t sleep.

Q And you —

THE COURT: Maybe you can show me where you are, because this is a long affidavit. I don’t remember where this part of it was.

MR. WEINBERG: Well, I’ll show you. It is Page 13.


MR. WEINBERG: Paragraph 31.


Q Read that out loud, Mr. Prince. It is one sentence.

A I’m sorry. What is it?

Q Page 13, Paragraph 31.

A Uh-huh.

Q Can you read that out loud?


A “If I had not forcibly made her drink water, I am positive that, based upon my own observation, she would have died.”

Q So you were concerned that she was going to die if you didn’t force her or make her drink water. That is what you said under oath in this August 1999 affidavit. Correct?

A Yes, Mr. Weinberg. But if you go to Number 29 of the same affidavit, I also mention the fact that I was afraid she was going to die because she could not sleep.

Q Okay.

THE COURT: He also said she had a — you also said she had a psychotic break, didn’t you?

THE WITNESS: Yes. I did.


Q All right. But the point is, Mr. Prince, is that you took it upon yourself to help her get through this. Correct?

A Yes.

Q So did Stacy Brooks?

A For a short time.

Q So did a number of other people that were there. Correct?

A Yes.

Q And you got an award for it?

A No, I didn’t.


Q You got recognized for it?

A No, I didn’t.

Q You didn’t?

A Come on.

MR. WEINBERG: Could I just approach the witness, your Honor, while I get copies of this?

THE COURT: You may.


Q I show you —

MR. WEINBERG: We’ll mark it —

THE COURT: I think it has already been marked because when Stacy Brooks was on the stand —

MR. WEINBERG: You are right, it has been marked, and we’ll figure out what the exhibit number is.


Q “August 31, 1988. Commendable. The following people are acknowledged for their assistance on handling a cycle that was above and beyond their duties. Their actions helped in the standard application of Scientology technology on the introspection rundown that made a being sane. Highly commended: Jesse Prince.” Do you see that?

A Where? Suzie Watson? I had forgotten about her. The


rest of them people are security guards. Well, you know, this is possible. I hadn’t remembered it.

Q Well, you were pretty happy, were you not, that you were successful in your endeavors to help Teresita?

A You know, I was happy that she survived and made it home okay. I was happy about that. Yes.

Q And you’re aware that she’s alive today and is still a Scientologist?

A I have no information about that.

Q She went home? She was allowed to go home after the introspection rundown was concluded?

A Yes. She signed her release, similar to this thing I signed, and she —

Q No one told you to keep her there to avoid a public relations flap?

A After she was well?

Q Yes.

A No.

Q No?

A No.

Q And during this process, she hit you. Correct?

A Yes.

Q She ran out several times, ran out into the country?


A Right.

Q I mean, one could say, if they didn’t know, that she was crazy, that she was trying to escape, correct, when she ran out?

A You could surmise that. I don’t know. She was running in the wrong direction to escape because where we were at, we were on a — where this place is, where we had her, the mountains are behind there. And she ran up that way. Which, unless you are a skilled mountain climber, you are not going to go very far.

Q And what you did, you ran after her, didn’t you?

A Yes.

Q And you brought her back?

A No. Actually I couldn’t catch her because she ran so fast. Sometimes people have superhuman strength. And then she climbed so high. And she was a lightweight person. And when I tried to reach for her, I couldn’t reach where she was. So I had to literally sit and wait for her to decide to come down.

Q Then you brought her back?

A No. I walked behind her. She brought herself back.

THE COURT: Mr. Prince, you brought her back, she came back, you followed her back —

THE WITNESS: She came back.


THE COURT: The deal was you weren’t going to let her, in that state, go anywhere except stay there and continue to be handled. Right?


THE COURT: All right.


Q Now, you cannot speak for what all Scientologists — other Scientologists would follow as far as policy, can you?

A No, I cannot.

Q Because — because of the concept in Scientology that what is true for you is true. Correct?

A Well, not — not wholly because also it depends on how much you have been trained, how much policy you know, you know. You can’t be expected to understand something you don’t know.

Q We’ve talked about this in your depositions before. The point is, is that it is a policy of Scientology that Scientologists can decide on their own what — whether to ignore policy or not — to ignore a particular policy or not?

A No. That is not true.

Q Then what did you mean when you testified —

A Not ignore a policy. You know, I mean, how could you ignore the policy to lock the door when all of the staff


walk out? You know, you’re going to get in trouble. That doesn’t make sense. You don’t ignore the policy. Either you understand it and you accept it, or you don’t.

Q So you don’t have to accept it if you don’t want to, that is a policy — that is what is true for you is true for you?

A No. No, no. Maybe with tech, you know, a belief — but policy that lays out the fundamental actions of the organization? No.

Q You don’t have any knowledge of what the staff members that were staying with Lisa McPherson — what policies

they were or were not following and what they believed about those policies? You are not in a position to opine about that, are you?

A What policies — policy are you referring to?

Q Whatever policies they were advised as to or practicing when they were staying with Lisa McPherson.

A You know, that is kind of ambiguous. If you have got a policy, I could tell you whether or not I think they’re aware of it.

Q All right.

Now, do you remember that in or about August or September — we’ll pull the exact affidavit now — in 2001 you executed an affidavit that was the basis of a motion for severe sanctions against the Church, and as a
result you withdrew as an expert in the case?


THE COURT: Are we done with this affidavit?

MR. WEINBERG: Oh, yes.

THE COURT: All right, I’m going to let you have that back. Mr. Prince, if you want to, you can give that back.


THE COURT: I believe this is in evidence, too, isn’t it?

MR. WEINBERG: I think it is. It is but — do we have copies of the affidavit? I think we have copies.

THE COURT: Okay. Good. I just went ahead — I’m just having the evidence filed as I read through it.

MR. WEINBERG: You know what —

THE COURT: It is too massive.

MR. WEINBERG: — this one I’m not positive about, whether it is in evidence or not.

THE COURT: I don’t know, either. Madam Clerk, how do you know what is in evidence?

MR. WEINBERG: I should know this and, frankly, I apologize.

THE COURT: Is there any way you can tell us whether an affidavit of Jesse Prince dated September of 2001 is in evidence?


THE CLERK: Yes, Judge, I can check. Is it plaintiff’s or defendant’s?

THE COURT: I can’t tell you if it is plaintiff’s or defendant’s. These come in under strange hands.

MR. DANDAR: I don’t believe the plaintiff used this at this hearing.

MR. WEINBERG: I’ll mark it. We’ll mark as the next exhibit, the September of 2001 affidavit of Mr. Prince.

THE COURT: What number is that?



THE COURT: And if you find it is in evidence, you’ll let us know and we’ll take that one out. We’ll have just a mound of evidence.

MR. WEINBERG: It is obviously part of a court record.

THE COURT: Yes. And I believe it has been referred to several times. But I’m not sure it has ever been introduced.

MR. DANDAR: 233?


THE COURT: So it will be received.

MR. WEINBERG: Then — where is the motion? Do


you have the motion? I might as well do the whole package here. 234 would be the motion for severe sanctions.

THE COURT: I don’t know why I would need the motion to be introduced. But —

MR. WEINBERG: Well, I think there was something I wanted to refer to and, frankly, I don’t know what it was. I’ll just mark it anyway. And that would be 234.


Q Now, is that an affidavit that you executed, Mr. Prince?

A Yes, it is, Mr. Weinberg.

Q And it was done — who wrote this affidavit?

A I did.

Q Did you get any help writing this affidavit?

A Mmm, maybe somebody, you know, did margins for me or, you know, word —

Q I mean, somebody drafted it for you? Nobody drafted it for you? You did all that?

A Again, I don’t want to be coy when answering the question. Sometimes Mr. Dandar or some attorney will suggest information based on conversations that we had and — quite normally.

And I think Mr. Dandar can attest to this, that I


normally start from the beginning and type my own, do my own work.

Q Now, if you go to Paragraph 22 and 23 of his affidavit, on Page 5 —

A Yes?

Q — you swore in the affidavit that — that — that:

“As a result of my arrest and criminal prosecution, I was extremely upset, embarrassed and humiliated and could see in here that my fiancee and her two minor children were traumatized by this experience.”

Then you went on in 23 to say that: “Further, I had advised Ken Dandar, counsel for the estate of Lisa McPherson, that I must withdraw as the estate’s expert in the above-captioned cause as a result of my arrest and prosecution and serious concern of further and more intense fair game by Scientology and its operatives.” Then you go on. Do you see that?

A Yes.

Q So the purpose of this affidavit was to say you were not going to be an expert anymore in this case because you were scared of Scientology. That is essentially what you said, right?

A No. I think that is a mis-characterization of what it says here.


Q How would you characterize it?

A I was concerned for my family. You see, I had no problem with weathering the storm with Scientology personally.

But this is beyond personal — I think I explained this in my testimony yesterday. Innocent people are involved here. It just wasn’t worth it to me. And I couldn’t hire an attorney. I just lost my job. You know, I don’t want to do that.

THE COURT: He said, “Not only to myself but my fiancee and her two children, who are all very dear to me.” That is all the same section.


Q Did it concern you, for the previous four years when you were threatening the Church, picketing in front of their buildings, saying obscene things about David Miscavige, did it — did it — did it concern you then about Scientology?

A Mmm, what it — it concerned me the moment that I found out that this operation had been run on me and drugs put on my back porch. I mean, it just went to a whole new level at that point. This is at my home. This is where I
live. People coming in, putting seed around, you know, commiserating with police, telling them I’m a drug dealer, cocaine dealer.

I have children. My fiancee gets her children


taken away from her. It escalated to a new level, Mr. Weinberg.

Q But the affidavit is executed in September of 2001. You had been acquitted in the spring, hadn’t you?

A Yes. Then didn’t —

Q Not acquitted. There had been a hung jury and the prosecutor decided not to pursue it. That was in the spring, wasn’t it?

A Didn’t Mr. Rinder quote, in the St. Pete Times, “We’ll get him next time.” Okay? He was quoted, “We’ll get  him next time.” I don’t want any more next times.

Q You continued to be an expert and consultant for Mr. Dandar up until — after the hung jury in the spring, up until September of 2001 when Mr. Minton said he wasn’t going to fund the case anymore. Is that what happened?

A No. Disrelated items.

Q It just happened to be coincidentally at the same time?

A If you characterize it that way. Again, like I say, as we’ve gone over, my regular job at the trust of helping people and doing things was over. We were in the process of leaving town. Everything Scientology wanted to accomplish had been accomplished. The trust was ruined.

You know, we were done. It was over. People were going home.


Q So —

A That wasn’t good enough.

Q Actually, you wouldn’t need to work on the case anymore because the trust was over. Right?

A No, you know, I wouldn’t draw that conclusion, Mr. Weinberg. I’m saying my family, right where I live, were threatened. You know, even today you knock on the door, if we get an unexpected visitor, people in my house jump out of their skin. What the hell, because that is exactly how the DEA came in my house, running around with fully automatic weapons in front of my children, because a Scientology private investigator told him I’m selling marijuana, cocaine, selling stolen auto parts; lying, in other words.

And this happened. Okay? I think I had a reason to be concerned.

Q Didn’t Mr. Minton ask you to withdraw from being an expert in the case?

A Never.

Q Did Ms. Brooks ask you to withdraw from the case?

A Yes, she did.

Q Did Ms. Brooks tell you that was Mr. Minton’s desire that you not be an expert anymore?

A No, she did not.

Q Did Ms. Brooks tell you why it was her desire you not be an expert in the case anymore?


A Yes, she did.

Q She said that had to do with the Lisa McPherson Trust, the reason?

A No, she said that Scientology had successfully inextricably mixed the work we were doing at the trust with this case, and irrespective of the lawyers and the arguments that they made, you know, it was like they wanted that, too.

Because of this, all of that discovery goes on with Mr. Minton, the trust is virtually raided, you know. Those kinds of reasons.

She said, “Look, if this case didn’t exist, none of this would be happening. We could still be doing this work. But because this has happened, it’s putting everyone in a horrible position. It ruined the company.”

Q Is there a particular reason why you didn’t put in your affidavit what Ms. Brooks had asked you to do, to withdraw?

A Yes, because it is irrelevant. It is my decision.

I spoke on this yesterday, Mr. Weinberg. I said, you know, Stacy wanted this to be done.

I spoke to Bob. And it is like, “Jesse, Stacy is upset because of discovery and things that are going on,”  yik-yik-yik. And, “You know, if you have to work with Ken, it’s up to you if there is something that is needed to be done.” He didn’t care.


Q Did you tell Mr. Dandar that Ms. Brooks had told you — asked you to withdraw as an expert?

A I think Ms. Brooks may have called him herself because she was quite panicked.

Q Did you send a copy of the motion — a draft — a copy of the draft of the motion for severe sanctions to Mr. Minton before it was ever filed? You?

A I don’t think so.

Q Well, you did make it a practice to E-Mail or send or give to Mr. Minton copies of draft pleadings. You made that a practice, didn’t you?

A No. Come on.

Q In the case?

A Uh-uh.

Q Never did that, did you?

A No. And, you know, I don’t draft pleadings. Again, I’m not the lawyer.

MR. WEINBERG: The next exhibit. Your Honor, this is 235.

THE COURT: All right.


Q Do you see 235, Mr. Prince?

A Yes, I do.

Q This is a copy of an E-Mail which you sent to whom on 9/20/01?


A Okay. Okay.

Q You sent this to Mr. Minton, didn’t you?

A Apparently, I did.

Q And you say here —

MR. WEINBERG: We move this into evidence, your Honor.

THE COURT: All right.


Q And this is an E-Mail where you say —

THE COURT: Can you show me how we know it went to Mr. Minton? I can’t read this stuff well enough to know.

MR. WEINBERG: I think maybe Mr. Prince can explain that better than me.

THE COURT: What is it at the top that shows this went to Mr. Minton?

THE WITNESS: There is nothing that says this went to Mr. Minton on this document.

THE COURT: Well, you just remember sending it to Mr. Minton?

THE WITNESS: Well, I’m assuming. You know, I’m not here saying I have never sent anything to Mr. Minton about anything.

THE COURT: Here, maybe this is it, I don’t know, this is encrypted something at the back.



THE WITNESS: As far as I know, this was an encrypted message on my computer.

MR. WEINBERG: This is where you see it at the back.

THE COURT: I think I found it already.

MR. WEINBERG: Right here, “To: Bob Minton, From: Jesse Prince. Received.”

THE COURT: How do we know — how do we know this is — I mean, I don’t care, but how do we know that this is the same thing?

THE WITNESS: Exactly. Here we have a bunch of characters, and now attached to it with — you know, when you get on the Internet, it clearly says from who to who on the message. It doesn’t look like this. It is not in this format.

It is not like that.


Q Well, look at — look at this page here.

MR. WEINBERG: Your Honor, I don’t know how to indicate it.

THE COURT: All right.


Q Look at that page. That is an E-Mail you sent to Mr. Minton. Correct?


A Correct.

Q On September 20, 2001?

A Correct.

Q 9:41:07?

A Yes, I guess so.

Q Something like that?

A Yeah.

Q This is obviously an encrypted message. Correct?

A Correct.

Q You each had that program so you could communicate with one another in an encrypted fashion?

A Correct.

Q Then you had — what do you call it — decrypted, what is it, a code or something?

A Yes.

Q Then you are able to, on the other end, decode it, right?

A Correct.

Q All right. Now, the decoding is what the first part of this exhibit is?

A The what?

Q The decrypting, decoding, whatever it is called where it says: “Here is the motion Ken will file in the next day or two. And this is not the final form as he is doing more work on it today. I’ll make sure you have a copy


of the final draft.”

A Okay.

Q You did that, didn’t you?

A I did what now?

Q You sent to Mr. Minton that message in encrypted form with a draft of this motion for severe sanctions?

A You know, I’m going to hold off on saying that happened because, you know, here is this message, it is encrypted —

THE COURT: Well, you sent this to somebody, you’ll agree?

THE WITNESS: Yes. I sent it to somebody.

THE COURT: It could have been Mr. Minton?

THE WITNESS: It could have been Mr. Minton.

It could have been Mrs. Brooks. It could —

THE COURT: You wouldn’t be apt to send it to anybody else, right?

THE WITNESS: Sometimes I would check things via Mr. Leipold just to get his opinion on it, another attorney I work with.

THE COURT: I think I know what Mr. Weinberg was saying. If you look over on this — this what we’ll call the encrypted one, the date — or the  time is 9:41:01 on September 20, 2001.



THE COURT: If you look at the one we can read, it says 9:40:22.

THE WITNESS: You show me where you are —

THE COURT: Yes, sir. Up here. See here? 9/20/01. 9:40:22. See that?


THE COURT: It looks like that is — that went out — now look over here. This encrypted, see, it says: “Date, September, 20, ’01, 9:41:01.” So it looks like it may have — it goes out once like this —

MR. DANDAR: That confirms it is not the same thing.

MR. WEINBERG: You know, I move this into evidence and we’ll get an authenticating affidavit from Mr. Minton saying that this is a document —

THE COURT: All right —

MR. WEINBERG: — that he received and he produced to us.


THE COURT: And Mr. Prince didn’t — didn’t send it to Mr. Minton. What he basically is saying, he’s not sure. And I can’t tell, but it looks like there is some correlation between these two things. I don’t — I don’t think I’m smart enough or if you


are smart enough to prove it to me, but that will be enough — and you don’t deny that, right, it could have gone to Mr. Minton?


MR. WEINBERG: I move it into evidence, your Honor.

THE COURT: And I’m going to receive it because it was clearly something from Mr. Prince. And you just don’t know for sure who it went to, is that it?

THE WITNESS: Correct, your Honor.

THE COURT: What number is it again?



MR. DANDAR: 235.

THE COURT: 235. Thank you.


Q Now, why would you be — assuming that this did go to Mr. Minton, why would you be sending Mr. Minton a draft of a motion for severe sanctions that was going to be filed by Ken Dandar in a couple days, in September of 2001, when you say that you had withdrawn from the case?

A Well, I’ll give you the — the answer I could think of about this — Mmm — this affidavit that you showed me earlier, this one here from September of 2001, I think it


is — yeah, where I talk about —

THE COURT: I’m sorry, I hate to do this. Is this the affidavit, or is this the motion?

MR. WEINBERG: This is the motion.

THE COURT: Okay. The affidavit isn’t here, unless that is what this is.

MR. WEINBERG: No. No. No. This — this — if you look at the note at the front, “Here is the motion Ken will file in the next day or so.”


MR. WEINBERG: The affidavit, you know, had already been done, apparently.


MR. DANDAR: This affidavit is dated the next day.

THE COURT: All right.

MR. WEINBERG: Anyway, this is the motion.

THE COURT: So your question was — I’m sorry — why would you send the motion —


Q What was the reason — assuming you sent this draft to Mr. Minton, what was the reason you would have been sending to Mr. Minton, in September of 2001, an advance draft of a motion that was being filed for severe sanctions in the Lisa McPherson case?


A Because as I recall, he was extremely upset with me. He was extremely upset with Ken Dandar because of this affidavit here. You know, we’re busy going along here —

Q The affidavit wasn’t done — Mr. Dandar just pointed it out — until after this E-Mail went out?

A I’m just trying to give you what I remember so you can take it apart in a minute, if you just let me get it out.

Q All right. Go ahead.

A What I recall about this is Mr. Minton was extremely upset about this affidavit because I had gone through a whole criminal trial where I had not taken the stand and — nor — and I had not admitted guilt or — you know, assumed innocence. In other words, I sat through the trial and they had to no prosecute — or whatever, a hung jury.

So from my mouth, I had never said that I had used drugs with the private investigator and, you know, running around with this detective and whatever and whatever.

Now, from my own mouth, he felt it defeated the purpose of having a trial if you are just going to run around and do that. Again, you know, I’m not a lawyer. I don’t know. I want them to know and do it.

But I do know that Ken was extremely upset over the fact that I wasn’t going to be his expert anymore, that


I wouldn’t be able to sit there and help him, as I had done, on the case. I’d worked on it for years. So this was very upsetting to him on a personal level when I told him, “Look, Ken –” and this is before — I told him, “Look, I can’t do this anymore. I can’t protect myself. I can’t protect my family. It seems the Court is letting Scientology do whatever they want to, running roughshod in here. All this crap is going on. There is no relief. I’m ready to leave this town. It is not personal against you, Mr. Dandar, that I think you know the reason why I can’t support you, but I can’t support you and protect my family, as well.”

Q Mr. Minton had told you that he wasn’t going to fund the case anymore at this time. Correct? You knew that?

A You know, I don’t understand how I can be saying one thing and then you just say something else.

THE COURT: That is a question.

THE WITNESS: No, that — no, that is not true,  Mr. — Mr. Weiner — Weinberg.


Q So you didn’t know that Mr. Minton had told Mr. Dandar, as of August of 2001, that there wasn’t going to be any more funds? You didn’t know that?

A You know, the last time we talked about this — I mean, Ken got, what, $500,000 in 2000 that was supposed to


take him to the end of the case. I wasn’t thinking about Mr. Dandar’s money. Mr. Dandar’s money and how he was operating this case financially was never — never has been any of my concern. There’s nothing I can do about it one way or the other.

Q Now, did you talk to Mr. Merrett about withdrawing from the case?

A Mr. Merrett spoke to me on behalf of Stacy Brooks. She wanted him to explain to me why it would be beneficial for the Lisa McPherson Trust and the people that we are trying to help if I withdrew from the case.

Q So that didn’t have anything to do with threats to your family or anything like that? That has to do with Mr. Minton’s request that you get out of the case because of the Lisa McPherson Trust?

A You know, I testified twice that Mr. Minton never said that. So I don’t know why you keep bringing it up.

Q Ms. Brooks then?

A Yes. Thank you. Get it right. That is why we’re here.

THE COURT: All right, Mr. Prince.

THE WITNESS: I’m sorry. I’m a little grouchy. I’m tired.

THE COURT: I understand. We all get grouchy.  If you wait for another hour, I’ll get grouchy.


MR. WEINBERG: I have that in mind.

THE COURT: I get grouchy a little after 12 and  4 o’clock just about every day.

THE WITNESS: I know that 4 o’clock is the  witching hour.

THE COURT: It’s a very bad hour for all of us.

MR. WEINBERG: I was going to say something but I won’t.

THE COURT: It is best you not.


Q All right. Well, let me show you what has already been marked as an exhibit, Exhibit 49. I have got a copy, so — it is that E-Mail.

THE COURT: The E-Mail? Okay. I thought I might see this E-Mail about now.

THE WITNESS: Everybody knows but me.

THE COURT: This has already been introduced into evidence.

MR. WEINBERG: This is 49.

THE COURT: And they testified about it.

MR. WEINBERG: Defense 49.


Q Now, this is an E-Mail that has been identified by Mr. Merrett, among others, that he sent to Mr. Dandar on August 24, 2001, which is before you executed your


affidavit, which says:

“Ken, the short version of what’s going on is this. The well is dry as far as money goes. Jesse is going to withdraw as an expert witness. Bob feels that the case is way out of control and is focused 100 percent on him and specifically on trying to put him in jail. He wants Dell to settle the case or otherwise make it go away. Bob isn’t coming into Florida any time soon. Can you meet with me and Stacy this weekend to discuss that?”

Do you see that?

A Yes, I do.

Q Now, you knew about this E-Mail?

A No. Never. This is the first time I have ever seen it.

Q Well, how did Mr. Merrett know, as early as August 24, 2001, to tell Mr. Dandar that you were withdrawing as an expert witness?

A Well, you know, you would have to ask him that.

I’m not even a part of this. I mean, somebody is talking to me about it. If I said anything, it would just be hearsay, wouldn’t it?

Q So no one told you that the well was dry then?

A You know, I heard that several times. But as you and I both know, the well is not dry. Mr. Minton still has plenty of money to extricate himself out of trouble he gets into by seeing that new lawyers, having had three of them in


here since I have been testifying, for Christ’s sake, three different ones, Mr. Battaglia, another one yesterday, the one sitting here now.

Q You didn’t know as of August 24 Mr. Minton had sent the message to Mr. Dandar that there was going to be no more money? You didn’t know that?

A No. No, sir, I did not.

THE COURT: Please try to refrain from taking the Lord’s name in vain in this case.

THE WITNESS: I’m sorry, your Honor, I didn’t even know I — did I say the GD word?

THE COURT: No, you didn’t say that one. You’ll see it on a transcript.

THE WITNESS: Okay. I’m sorry, your Honor.

Like I said, I’m tired, grouchy.


Q You did. But — he didn’t tell you that the well was dry, Mr. Minton, but he did tell you, you said, about having given Mr. Dandar a $500,000 check?

A Yeah, you know, and I’m talking about 2000, okay?

Then again, you know, just in February, he said, “Look, Ken needs more money. Go over and have this conversation with him.”

So how could the well be dry on this date, but a little while later, hey, here is another quarter of a



You know, this was not anything I was privy to, anything I was dealing with.

You know, Stacy was in a complete panic, as I said. We were being raided. You know, motion after motion, deposed, on and on. You know, she was panicked. She got spooked. You know, she was just trying to put a band-aid on this any way she can.

Q It is true Mr. Minton told you — as indicated in this E-Mail, it is true he was concerned about going to jail at that point, correct, in August of 2001?

MR. DANDAR: Objection. There is no jail mentioned in this E-Mail.

THE WITNESS: Yes, it is.

MR. WEINBERG: Yes, it is.

THE COURT: Yes, there is.

MR. DANDAR: Then I’ll sit down and be corrected.


THE WITNESS: But you are asking the wrong person. I told you I have never seen this —


Q No, I’m asking you, it is true that either Ms. Brooks or Mr. Minton told you in this time period that Mr. Minton was concerned that he was going to end up in



A I don’t know that.

Q I’m just asking you —

THE COURT: He said he doesn’t know. He told you that twice. Now, go on to the next question.




Q Did Ms. Brooks or Mr. Minton tell you, at or about that time, that they felt the case was out of control?

A I never — I never really heard those words that the case was out of control. I mean, you know —

THE COURT: But you were being told that they were very concerned that the Lisa McPherson case and Lisa McPherson Trust was all getting inextricably intertwined?


THE COURT: Courts were letting all these documents be acquired. This is what is out of control perhaps, right? So you were aware they were all disturbed about this?

THE WITNESS: Yes. Disturbed at the discovery, yes.

THE COURT: Well, disturbed with — that the Lisa McPherson Trust be shut down?



THE COURT: You knew all that, did you? Or did you?

THE WITNESS: You know, I didn’t have an understanding — you know, in all honesty, you know, Judge, Mr. Minton was going through this thing with Judge Baird where he was to appear and he didn’t appear.

I understood none of that. I didn’t understand what was going on. I didn’t understand what the big problem was. If he was supposed to be deposed, you simply come in and you get deposed. You may not like it, you may not whatever.

But, you know, then we had these problems where he can’t come down, on and on. You know, a bad situation just got worse.


Q You knew that money didn’t have anything to do with Mr. Minton shutting down the Lisa McPherson Trust, right?

A Yes.

THE COURT: Good time for a stop?

MR. WEINBERG: I think so because I have another area to go to.

THE COURT: It is — I need to take a little


longer this afternoon. We’ll be in recess until ten after. Twenty minutes.

(WHEREUPON, a recess was taken from 2:50 to 3:15 p.m.)



MR. WEINBERG: Ready? Let’s just make an exhibit search here for one second to make sure we don’t have any originals up here.

THE WITNESS: I think we took care of that.


Q All right, Mr. Prince —

A Yes?

Q — you have talked several times about being in the desert. Right?

A Yes.

Q There are two locations that are within a few miles of one another that you have been referring to. Right?

A Yes.

Q One is Hemet which is where the Golden Era Productions is where you worked after you left RTC. Correct?

A That is actually incorrect, Mr. Weinberg. It’s Gilman Hot Springs, near Hemet, but it is — it is like its own little separate town.


Q Golden Era Productions is in Gilman Hot Springs, and that is what you described as being in the desert? That is one of the locations in the desert?

A Yes.

Q Then the other location in the desert is —

A Soboba Indian Reservation.

Q Is the what?

A Soboba Indian Reservation.

Q And that is where you — that is where you had the introspection rundown with Teresita. Right?

A It was actually behind the reservation in a private-owned property, correct. Yes.

Q That is where you said the RPF was?

A Correct.

Q The incident that — that had to do with the day that you were relieved of your position at RTC and the guns, that was at Gilman Hot Springs?

A Correct.

Q I want to show you some photos.

MR. WEINBERG: These are for you. This can be marked — this Booklet A, 1 through 11, but we’ll mark it as Exhibit 236. But what I have done, your Honor, you have the same pictures, but they are in this book like this. So A1 would be the first one.




THE COURT: I can keep this?

MR. WEINBERG: You can give it back to us, unless you want to keep it.

THE COURT: No. I’ll give it back to you.

MR. WEINBERG: This is 236. I’m handing this to Mr. Prince.


MR. DANDAR: Do I get a copy?




Q Now, if you look at A1 through A11, you recognize that as being the location in Gilman Hot Springs that Golden Era Productions was at where you say is in the desert.Correct?

A Yes.

Q And if you would just flip through and just describe very briefly A1, A2, through 11. Could you do that?

A Yes. I think so.

This looks like a view from —

THE COURT: Tell me what you are talking about.

Is it A1?




A This looks like a view from the dining area and the qualifications area and the studio, the studio from a perspective of the river bank, which is just further back here, the dry riverbed.


Q What is A2?

A A2, there is a building here that, you know — wait a minute, yes, I do — this is the dining — this is apparently an aerial shot of the dining area.

Q Okay. A3, do you recognize that building?

A This — I think this may have been some new construction since I have been there. I can’t say. Do I recognize this building? I can’t rightfully say that I do.

THE COURT: Okay, that is an “I don’t know.” And that is enough.

A Okay. I don’t know.


Q Was Building 36 the main administrative offices of Golden Era? That was on-site when you were there?

A Oh, is this where they do the E-meters and things in there?

Q Do you remember that is where you were interviewed by Mr. Rathbun when you left in 1992, that was the building?

A Yes.


Q If you go to A4, do you recognize that as the lake, with the administrative building in the background?

A Yes, I do, with the exercise trail.

Q And A5, do you recognize that as a sports field for the crew?

A In all honesty, I don’t recognize it, but I believe it is.

Q And A6, do you remember there were crew basketball courts?

A Yes. Yes, I do.

Q And A7, what is that?

A I have no earthly idea.

Q That is new, isn’t it?

A I —

Q Or do you know?

A It is outside of my knowledge.

Q Okay. A8, is that another building that is new?

A It’s something that is outside of my knowledge. I don’t know. I have never seen this on the property.

Q Now, you do recognize A9 as the set inside the film studio where you were working?

A No, sir. You know, matter of fact, I never worked in this area of cinematography. I worked in the audio department.

Q There is a film studio on campus, though, right?


A Yes. But this looks considerably larger than the film studio that was there when I was present.

Q And A10, was the golf course there while you were there?

A Mmm, I think they had started construction on it and — had hired a company to come out and do it. I think so, but I have never seen this before.

Q Oh?

A What you showed me here.

Q Now, how many years did you work in the desert at Gilman Springs, this location that you looked at, A1 through 11?

A Probably at least ten years.

Q Were the RTC offices there, as well?

A Yes.

Q Okay. Let’s put those aside.

Now we’ll mark as our next exhibit — it will be Photos B1 through 5. It is Exhibit 237. I’ll give you these.

Now, you do recognize B1 through 5 as pictures of the studios where you did work when you were at Gilman Hot Springs after you — after March of 1987?

A Well, in actual fact, the only one that I recognize as the studio that I possibly worked in is B4.

Q And that would be a picture of doing what? What


was your job there?

A Well, I take that back, and I don’t want to — you know, I don’t know where this is, as a matter of fact. I haven’t seen this.

This looks like maybe they have new equipment.

You know, this is not anything I’m familiar with, in all honesty.

Q You worked in the film mix room?

A Mmm, I worked in the post-production — this is a building they have on top of the hill from the perspectives from the — the first photograph album that you showed me.

Where I worked at was close to a place that used to be called Bonnie View, which is L. Ron Hubbard’s home at Gilman Hot Springs.

Q And it was a studio something like what you were looking at there? I mean, there was film production or film mix going on. Correct?

A Mmm, I — I can’t say that, Mr. Weinberg, because everything here — all these pictures that you are showing me, with the exception of B4, seems to do with music.

Q Were there things like this at Gilman Hot Springs when you were there?

A Yes.

Q Whether you worked there or not?

A Yes.


Q And you recognize that from the photos. Correct?

A Well, again, I said again, B4 is something I recognize as being —

THE COURT: I think the long and short, you really can’t recognize it?

THE WITNESS: I can’t. This is all different from when I was there.


Q Now, let me show you —

THE WITNESS: Very beautiful, though.


Q The whole location is beautiful, though, isn’t it?

A It looks like it is now. It wasn’t quite like that when I was there.

Q Well, the first set of photos of Gilman Hot Springs, it looked like that when you were there?

A Not exactly. There has been a lot of new construction there, from what I can see.

Q The building you described as buildings that were there looked like that when you were there. Right?

THE COURT: Whatever he said, he said, Counsel.

All right?

MR. WEINBERG: 238. These photos are marked I1  through 3.



Q This is Exhibit 238. Would you look at these, please.

A Sure.

Q Do you recognize these photos?

A Yes, Mr. Weinberg. This is the place where Mr. Miscavige and I came to, after the gun incident, to talk about things.

Q This is where you said you walked to the ship in the desert? This is where the ship in the desert is?

A Yes.

THE COURT: Is that the swimming pool (indicating)?



Q This is still Gilman Hot Springs?

THE COURT: But the ship in the desert is the swimming pool?

MR. DANDAR: No. There is a ship.

MR. WEINBERG: Actually, if you look at I3, you  see the ship.

THE COURT: Oh, okay.


Q And it is around a very nice pool area. Correct?

A Correct.


Q So when you indicated the ship in the desert where, after this gun incident, you went with Mr. Miscavige is I1 through 3?

A Correct.

THE COURT: Is that a ship? Or a mast on top of a building?

MR. WEINBERG: Ask Mr. Prince.

THE COURT: Is that a ship? Or is that some masts on top of a building?

THE WITNESS: Your Honor, it is a design that looks like a ship but it is actually a beautiful pool area. It is not a ship but it looks like a ship. There is a wheel there —

THE COURT: But that is what you-all call it, ship in the desert?

THE WITNESS: No. I forgot what we call this thing.


Q That is what you called it on the stand, though?

A That is how I referred to it, yes.

Q Then we have one more set of photos to show you — two more, I guess.

MR. WEINBERG: This is just one photo here.


MR. WEINBERG: 239. And it is marked J1.



Q 239, Mr. Prince, one photo. And I ask you if you recognize that to be a photo of the conference room in Gilman Hot Springs where you were interviewed by Mr. Rathbun in 1992, just before leaving the Church of Scientology?

A Unfortunately, Mr. Weinberg, none of this looks familiar to me at all.

Q Okay.

THE COURT: I’m sorry, did you say it does not look familiar?

THE WITNESS: Correct, your Honor.

MR. WEINBERG: Okay. The last set are three photos.

THE COURT: You want to go ahead and take these?

MR. WEINBERG: Yes. These are marked K1 through 3. And this is Exhibit 240.


Q Now, you recognize Exhibit 240, don’t you?

A Which one is — is this the thing you just handed me?

Q Yes.

A No, I do not. I do not —

Q Let me go through those K1 through 3.

A I don’t recognize this at all.


Q Well, let me just see if I can refresh your recollection.

A Okay.

Q Do you recognize this being at Happy Valley, which is where this Indian reservation is?

A Not at all.

Q So you don’t recognize this as being one of the locations where you were with Teresita?

A No, I do not. It did not look like this at all.

Q Well, what did it look like?

A Mmm, well, the place where Teresita stayed in, it was a wooden house that was on wood planks that sat on the ground. And there was — Mmm — it was very old, kind of like something that had been left for a long time and then kind of started being used again kind of thing. There was none of this lush, beautiful greenery. It was just gravel roads and crap everywhere.

THE COURT: Do you recognize this?


THE COURT: As long as he can’t recognize it, it can’t really be introduced.


Q Back at the Teresita house — we don’t have to look at the photos. But the house, do you remember how many bedrooms the house was?


A To the best of my recollection, I believe there was one.

Q All right. And then there was, what, a living room, kitchen, dining room, bathroom? What else was in it? Do you remember?

A Mmm, there was a kitchen. There was a room — let me see. There was a kitchen, there was a front door, there was a small room, there was another room, and a bedroom and a bathroom, to the best of my recollection.

Q And a kitchen of some sort?

A Yes.

Q And you stayed — did you stay in the house, as well?

A No. A woman — you know, a woman would stay with her at night.

MR. WEINBERG: All right, let me sort through this, your Honor.

THE COURT: All right.

MR. WEINBERG: Okay, we offer at this time into evidence Exhibit 231, which are the A1 through 11 which are the pictures of Gilman Hot Springs.

THE COURT: I have got those as 236.

MR. DANDAR: It is 236.

MR. WEINBERG: That is because I can’t read very well. It is 236.



MR. WEINBERG: We offer 237, which are the —

THE COURT: He recognized one of those.

MR. WEINBERG: 237 B4, which is the one he identified, this one (indicating).



Q Do you remember that?

A (Nods head.)

MR. WEINBERG: Then we offer —

THE COURT: 238 he recognized.

MR. WEINBERG: 238, which is the pictures of the pool and the ship.

THE COURT: 239 and 240, he didn’t recognize any of those.

MR. WEINBERG: Right, so I’ll not offer those at this time. And we’ll leave them marked.

THE COURT: So I’ll give you these back.

MR. WEINBERG: You accepted into evidence what we just offered?

THE COURT: Yes. Mr. Dandar, once again, if you want to object, I’m assuming you’ll do so.

MR. DANDAR: Yes, I will.


MR. DANDAR: But, then again, I didn’t know if

you wanted me — no, I’m just kidding.

THE COURT: No, I have done the same with Mr. Weinberg. A lot of times I say it is admitted because I know he will pop up if he wants to object.

MR. WEINBERG: I’m not reluctant to pop up.

THE COURT: Right. But from time to time I want to remind you, you have the right to object.

And I assume if you don’t, you have none.

MR. WEINBERG: Could we fire this up?

MR. LIEBERMAN: That, of course, doesn’t cover our standing objections.

THE COURT: It does not. Standing objections are standing.

MR. WEINBERG: This will just take a second.


Q While she’s doing that, let me ask you a couple of questions with regard to what I’m about to show you.

A All right.

Q You testified either yesterday or the day before — or the day before, or weeks before, I can’t remember when it is now when you actually started —

A This — I think this is my third day.

Q Okay. But you testified that you had not participated in any meetings with Mr. Dandar at the LMT.

You remember that testimony?


MR. DANDAR: I didn’t hear that. I’m sorry.

THE COURT: He asked if he remembered that he had stated he had not participated in any meetings with you at the LMT.


Q Do you remember that?

A Not particularly, no.

Q Well, let me ask you. Did you engage in any meetings — meetings where you discussed legal strategies with Mr. Dandar at the LMT in the presence of Mr. Minton?

A Not that I can recall specifically.

Q Okay. I mean, I think you said that Mr. Dandar was barely at the LMT. Didn’t you say that?

A Correct.

Q Now, do you remember a meeting with yourself, Dr. Garko, Mr. Dandar, Mr. Minton and Ms. Brooks at the LMT to discuss picketing and the legalities of it?

A No, I do not.

Q Would you watch this, please. Then I have a few questions.

A Sure.


(WHEREUPON, the video was played.)

“I love it when I’m on camera.

“Well, tell me what Nancy Miller said to you


concerning —

“Not to me. To Kim Rondolini and Denis deVlaming.

“Okay, your lawyers.

“They said that the police department would not be quick — or they would not arrest anyone within the 10-foot zone while they were picketing except for me. If I enter a 10-foot zone, I’ll get arrested period. That is the same as before. But nobody else would be arrested.

“No Scientologist would be arrested just in the ordinary course of things. A Scientologist who happens to be walking down the street getting 20 feet away from me, they wouldn’t be arrested. What Kim Rondolini suggested or
what Lieutenant Nancy Miller said — remember I said this shouldn’t be on camera the other night, but I don’t care, we’ll just leave it on there — is that while they have no right to tell us this, they would ask that we refrain from entering into that 10-foot zone while picketing because if — if something happens — which they felt reasonably confident that the Scientologists might try to provoke — it would in- — inevitably get blamed on us. And, therefore, somebody — somebody might get arrested and it would reflect badly upon me relative to the case that is sitting in front of Bernie McCabe now with respect to the assault — battery charge. Sorry.

“Well, I still think the best practice is to stay


10 feet away from the building.

“I don’t. You know why? You know why?

“Especially for you.

“For me, I have to because I would violate the injunction by being within 10 feet.

“It is impossible for him to do right now because I just found out what Stacy told me, within the last 36 hours they closed on the building next door.

“Which building?

“The Robelling (phonetic) one going that way.

“The building right next door?

“Yes, right where — wall-to-wall, they just closed in the last 36 hours, it is confidential, somebody came and told me that, literally.

“Well, they tried to get the one right beyond that —

“They got the whole building, the whole thing from Octavio’s to here belongs to them now.

“No, it doesn’t.

“Yes, it does.

“No. No. No.


“Listen, I’m telling you —


“– the injunction is against you and agents and


employees of yours. And that doesn’t include the Lisa McPherson Trust.

“That’s right.

“Anybody can walk down that sidewalk except you.

“That is correct.

“Anybody that — that is a volunteer from the trust can walk down that sidewalk without carrying a picket sign.


“Because they are not in concert with you at the time they’re walking down there to go to a restaurant or get a Coke.

“Exactly. That is what I’m saying.

“I agree with you on that point.


“However, if you organize a picket —

“Then they should stay on the other —

“– you have to stay 10 feet away.

“Exactly. That is what I’m saying here. All I’m saying —

“But the injunction applies to you whether or not you are in a picket or not.

“Well, it would — the police said it wouldn’t apply to them.

“I think I got it now. As soon as I can — sorry.


“Well, okay. Let me give you a perfect example of this today. We had somebody coming from Tampa, Counsel. We had two Germans come in who wanted to do a picket with me.And so we went at lunchtime and did a picket. I told them that as long as they’re with me and we’re picketing, I recommend highly we all stay 10 feet away from them —


“– on the other side of the street while we’re picketing. And everybody abided by that.

“Right. Right.


“The policeman, he’s Lieutenant Hall, he’s a really, really nice guy. He’s in charge of this whole area.

“Well then, how come he didn’t know what Chief Kline said? I mean —

“He wasn’t here.

“He wasn’t here?

“Okay, he’s just —

“He’s back today.

“Okay, fine.

“He’s under Captain Jones.

“He was very courteous. He said, ‘I appreciate the fact that all of you have been trying very hard to cooperate with this whole thing. I’m sorry about the confusion that has been caused by this whole thing.’


“But, he said — he said, ‘You have every right to walk down a public sidewalk. The only person who has been named that has any kind of restriction is Bob Minton. There is no one else that has been named that has any restrictions.’

“Really, what I understood from what he was saying, it is not the police department’s job to do this. I mean, Sid Kline specifically for —

“Sid Kline — let me just explain.

“Specifically for that picket he said this is the way we’re going to do it. But I think it is putting him in an uncomfortable position to be asked to interpret the law. And so I think that Denis should go before the judge.

Don’t you, Ken?

“Well, in the meantime —

“Seek modification as soon as possible.

“But if we walk down the street, not picketing, I go buy a goddamn apple —

“Let them fucking call the police. Let them call the police, Stacy.

“Don’t talk like that.

“Ask –” (Inaudible.)

“What is this shit about?

“I’m saying it is unreasonable for them to ask us


to walk —

“It’s not legal.(Inaudible.)

“You are legally right.

“Legally what?

“You are legally what?

“You are legally right. Everybody can walk down a sidewalk except Bob Minton. (Inaudible.)

“You have the legal right to walk down the sidewalk. The police agree with that. Lieutenant D.J. Hall, who is in charge of this district, who tells his officers what to do and what not to do, said you can walk down the sidewalk except Bob Minton.


“But he said, ‘Please, until this gets sorted out, can you walk on the other side of the street so we don’t get called down here a lot and just keep wasting our time driving down here? But if you want to — if you want to and they call, we’ll come down.’ (Inaudible.)

“Okay, here he is. Hi.”

(End of playing of the video tape.)




Q Do you remember that meeting with Mr. Dandar?

A I do not, but I see it now.

Q And the reason that is part of the film library of the LMT is what?

A Personally, I have no knowledge of it being a part of a film library. This looks like a video of — a private video that was shot. And it was never published, that I know of. I don’t think this ever appeared on the Internet. It is not part of the videos that is offered by the Lisa McPherson Trust or anything else. It seemed just like a private video.

Q Do you know what the trial consultant, Dr. Garko, was doing at this meeting where there was — where the legalities of picketing were being discussed?

A No, I do not.

Q And was Mr. Dandar, Mr. Minton or your lawyer or the LMT lawyer at that point giving advice about what you could, couldn’t do, as far as Judge Penick’s order?

A You know, I don’t — I’m sorry, I don’t know. I don’t have recall about that. I know our good friend, Mr. Penick, sorted this out for everyone wonderfully, though.

Q That was at the LMT, correct?

A What we just saw there?


Q Yes.

A Yes, it was.

Q You would call that a meeting, the one where you were all sitting in the room, with Mr. Dandar, Dr. Garko and you —

A I would say we certainly were having a discussion.

Q That was one of the examples where you were having a meeting, Mr. Minton would sort of express — sort of taking over the meeting?

A You are mixing two things. He would express his opinion. That doesn’t mean he would take over the meeting. Mr. Dandar spoke. Stacy spoke. I spoke. It seems like everyone has been allowed to speak. There doesn’t necessarily seem to be a chairman of that meeting. We’re just having a discussion.

Q And that meeting took place while you were being paid by Mr. Dandar as a trial consultant?

A I don’t know those dates. I don’t know.

THE COURT: Could you give him a date?


Q Yes, what was the date? It is January of 2000?

A I’ll stipulate to the evidence. I’ll agree with that.

Q Now, did Mr. Dandar ever tell you, you know, when you were getting paid by Mr. Dandar, including then in


January of 2000, that you shouldn’t be — as his religion expert, you shouldn’t be picketing the Church?

MR. DANDAR: I’ll object to Mr. Weinberg raising his voice at the witness. It is uncalled for.

THE COURT: It was fairly modest. So I think Mr. Prince can handle that.

THE WITNESS: After all this, sure.

A You know, I think that — I forgot what the question was.

MR. WEINBERG: She can read it back to you.

THE COURT: I believe it was did Mr. Dandar ever suggest, as his consultant/expert on religion, that you should not be involved in picketing?

A Yes. He didn’t like that. Mr. Dandar didn’t like that.


Q And he didn’t express that opinion at that meeting that we just looked at, did he?

A Excuse me?

Q He didn’t express that opinion at that meeting that we just viewed, did he?

A I didn’t hear it. I think we were talking about walking down the street, though. I think the subject of that video was walking down the street. It wasn’t so much


picketing. We talked about picketing, but what we’re talking about is the ability to be able to walk down the street without being arrested.

THE COURT: And the two videos were entirely different, different — it was different, everybody was all dressed up the second time.


THE COURT: The first time —

MR. WEINBERG: It’s the same day, the same time, because Dr. Garko was there and Mr. Dandar was there. It’s from the same tape, at least.


MR. WEINBERG: Your Honor, for the record, we’re going to supply, for the record, tapes of what we played and transcripts of what we played —


MR. WEINBERG: — because I doubt that the court reporter —

THE COURT: I’m sure they are able to get it because —

MR. WEINBERG: Some are tough. I mean, that one was probably easier, but all these videos we played —

THE COURT: If the court reporter was unable to get it and you supply a transcript, let the court


reporter take it down, because the district court, and I’m sure the Supreme Court, as well, now wants videos, wants tapes, transcribed in the record.


THE COURT: So if the court reporter got it, that is grand. If the court reporter said she didn’t get it, perhaps you and Mr. Dandar can agree on the — what it was and she can put it in the transcript. Then we don’t need the transcripts in the record.

MR. WEINBERG: So what we’ll do is we’ll put the videos in the record and we’ll have transcripts available for the court reporter, if needed.

THE COURT: I saw Mr. Keane come in. I’ll bet he’s here to say something about this case.

MR. WEINBERG: Well, I’ll step down a second.

THE COURT: Mr. Keane, did you need me?

MR. KEANE: I just have things to deliver to you in camera.

THE COURT: Let’s go ahead, since he’s here, let’s take — will five minutes do it?

MR. KEANE: Yes. Fine.

THE COURT: We’ll just take a little break here. And I’ll be back as soon as I’m done.

(WHEREUPON, a recess was taken.)



THE COURT: Okay, Mr. Keane brought me four packets of E-Mails that didn’t look too overwhelming. I’ll take them home tonight and look at them. Some are Mr. Dandar’s, some of Ms. Greenway’s, some are those identified by — who is Stacy Brooks’s lawyer, Mr. McGowan?

MR. FUGATE: McGowan.

THE COURT: As attorney-client privilege.

There is a different group.

So I’ll go through them and decide if any or all of them you can have and make them available.

MR. FUGATE: Thank you, Judge.

THE COURT: If I don’t get it done tonight, I’ll try to get it done by Friday. Is today Wednesday?




MR. LIEBERMAN: One day just runs into another.

THE COURT: It sure does. I just tell everybody 9 to 5 all day every day.

MR. WEINBERG: Excuse me, could I talk to Mr. Lieberman?



MR. WEINBERG: I’ll check an exhibit number.

This is a supplemental affidavit of Jesse Prince that I put in yesterday.

THE COURT: All right.

MR. WEINBERG: This is exhibit — Plaintiff’s Exhibit 132.

THE COURT: Are these — are these the exhibits?

THE CLERK: No. Those are the transcripts.


MR. FUGATE: Yes, ma’am?

THE COURT: — I thought I had five volumes here of transcripts. And then I see that this is Volume 1 of the time line, discovery, contempt and coercive sanctions. And this is Volume 2. This says Binder 3, 4, 5. I wonder if I have Volume 2.

MR. FUGATE: You, I think, took those with you.

THE COURT: Did I take them with me?


THE COURT: I’ll look and see if maybe I have them in my office.

MR. FUGATE: Because I think we were up to Binder 3. And 2 — I mean, 4 and 5 are just since we’ve been back.

THE COURT: But you started Volume 1 with the


first day of the hearing?


THE COURT: I’ll check it. Those are exhibits.

MR. FUGATE: Let me just check.

Yes, Judge, 1 and 2 beginning, and 3 and 4 and 5 continue on. So 5 is the latest which just went up there today.

THE COURT: I’ll have to look then, because I was thinking I better start taking these home. And I thought I would start with 1. And apparently maybe it is home or here. I’ll check. Okay.


Q Okay, I just showed you your September — I’m sorry, your December 22, 1999 affidavit — or declaration, the supplemental declaration that you submitted in the Wollersheim versus Church of Scientology California case.

A Yes, you did.

Q And that is Exhibit Number 1 on the front?

A Exhibit Number 132.

Q Plaintiff’s 132?

A Yeah. Evidence 132.

Q Now, this was an affidavit — this was a declaration — but an under oath statement — that was filed by you at the request of Mr. Leipold?

A Correct.


Q Now, you did this declaration in response to a declaration that had been filed by Mr. Miscavige in this case a few months prior. Correct?

A No, sir. That is incorrect.

Q Well, you — if you turn to Page 9 —

A Okay.

Q — Paragraph 14, you say: “The missionaire in charge of the San Francisco mission holder’s vision was David Miscavige. Mr. Miscavige is flat out attempting to deceive this court in his declaration when he characterizes his presence at the conference as that of an ‘invited’ master of ceremonies.”

A Okay, yes, you are right. I remember that.

Q Do you remember that now?

THE COURT: The whole affidavit may not have been filed in that response. I remember reading that last night. It was one of the things I took home. I just remember that as being part of the affidavit. I mean, I’m not saying it wasn’t.


THE COURT: I don’t know why it was filed. But that is just one of a lot of stuff in there?





Q But what I’m saying is when you — you had reviewed and were being asked, among other things, to comment on things that had been raised or discussed by Mr. Miscavige in his declaration. Correct?

A Well, not entirely. What I was asked to do specifically by Mr. Leipold was to do a declaration that would shed some light into how Scientology works, how the different corporations relate to each other, what are the names of them, what are the practices of them. I think —

THE COURT: Well, when you said — I didn’t mean to get off here. When you said whatever you said about Mr.Miscavige was misleading the Court,  was that in some testimony? Was this in a declaration? In a deposition? Or do you know?

THE WITNESS: I don’t recall at this time.

MR. WEINBERG: But it says here the declaration.

THE COURT: Then it must be the declaration.


MR. DANDAR: Which page is that on?

MR. WEINBERG: Paragraph 14 on Page 9.


Q And declaration is this thing that is used in the California court, as opposed to an affidavit in Florida,



A Correct.

Q Now, let me show you what we’ll have the reporter mark as the next exhibit.


MR. WEINBERG: 241. Do we have a copy for the Judge?

THE COURT: What is the number?


THE COURT: Thank you.

MR. WEINBERG: 241. For this part I’ll just give you this.



Q If you look at that declaration, you remember that Mr. Miscavige filed a long declaration with regard that was submitted in the Wollersheim case that you reviewed and at least commented on in this declaration that you filed a few months later. Correct?

A Yes, I did comment, in part, in my declaration about this one.

Q Right. And as this one indicates, it was filed on September 29, 1999, which would be a few months before your declaration was done. Correct? Yours is December.

A That is correct.


Q Okay. Now —

THE COURT: Out of curiosity, I just started leafing through here real quick, and I see if this is a declaration that came before Mr. Prince’s declaration, on Page 54, Paragraph 115, it says:

“Further, I do not know why Prince would allege he signed an undated letter of resignation.”

MR. WEINBERG: Right, because this is —

Mr. Prince’s, the one in front of you, is a supplemental declaration.

THE COURT: Mr. Prince had a declaration?


THE COURT: Mr. Miscavige —

MR. WEINBERG: Responded to it.

THE COURT: Then this is a supplemental?

MR. WEINBERG: Right. All right?

THE COURT: Okay. And what I was given yesterday and what I read last night was a supplemental affidavit?

MR. WEINBERG: Yes. The one that —

THE COURT: 134, whatever you call it.

MR. WEINBERG: Let me just — I should — I’m usually better at this than that. It is 132, it is Mr. Prince’s supplemental declaration.

THE COURT: All right.


MR. WEINBERG: Okay? It is falling apart.

(A discussion was held off the record.)

MR. WEINBERG: Now, your Honor, what goes along with this declaration is there were exhibits, this and this. We will just put this in the record.

This is part of — of 241.

THE COURT: What is that?

MR. WEINBERG: It would be exhibits that go with Mr. Miscavige’s declaration.

THE COURT: Other than what I have got attached to this —

MR. WEINBERG: Yes. Well, this is Exhibit Q.


MR. WEINBERG: — of the declaration, “The Way To Happiness,” which you have seen before.

And the tape is what? The tape is — I’m not sure what the tape is. What is the tape? Oh, I need the tape back. The tape was actually some of the videos we are going to put in from yesterday.


MR. WEINBERG: So exhibit — what was it –241?


MR. WEINBERG: Exhibit 241 is what you have in front of you, plus Exhibit Q here.



MR. WEINBERG: Which you may or may not want.

That is “The Way To Happiness.”

THE COURT: I thought “The Way To Happiness” was the little book, the little brochure.

MR. WEINBERG: Well, I guess I’ll open this up and find out. I have to look.

No, this is a — well, this is a —

THE COURT: This must be a —

MR. WEINBERG: This is a better — this is what was filed. This is the — the bound copy of it.


MR. WEINBERG: I’ll give a copy to Mr. Dandar.

MR. DANDAR: I object to the relevance.

MR. WEINBERG: Well, it’s — it’s Mr. Prince’s affidavit that Mr. Dandar put in yesterday. It was in response, at least in part, to this. So,  therefore, we’re offering Mr. Miscavige’s affidavit, your Honor.

THE COURT: I’ll let it come in as to whatever part relates to this testimony. I’m sure there is stuff that doesn’t. But rather than try to pick and choose, we’ll just let it all in for now.

MR. WEINBERG: All right.

THE COURT: And this is, I’m sure, a deluxe


version of the little brochure.

MR. WEINBERG: I think it is. I’m sure it is.

THE COURT: That was Number 241?

MR. WEINBERG: Yes, your Honor.

THE COURT: Okay. Thanks.


Q Now, you have in front of you your April 2002 affidavit.

A No, I do not.

Q Probably not. Mr. Dandar marked that yesterday.

MR. WEINBERG: Could we see if we can find that one? That is the one that was filed — the most recent affidavit.

THE COURT: Is that the May 2002? No?

MR. DANDAR: April. April.

MR. WEINBERG: I think it’s April, your Honor.

You marked it as an exhibit, right, Mr. Dandar?

MR. DANDAR: I thought I did, yes.

THE COURT: Well, Mr. Dandar, I’m looking here,”Notice of Filing Affidavit in Opposition of Defendant’s Omnibus Motion.” Is that the one?

MR. DANDAR: That is the one.

THE COURT: Okay. It is dated — “Jesse Prince, sworn the 1st day of May, 2002.” So I want to make sure we’re looking at the same one.


MR. DANDAR: Let’s make sure. The front says April 2002? The next page? Yes, that is it. I see the attachment.

THE COURT: It says April 2002. He signed it May 1. We can agree it’s the same?

MR. DANDAR: It’s the same.

MR. WEINBERG: Do you have a copy for Mr. Prince?

THE CLERK: What exhibit is that, Judge?

THE COURT: I don’t know. It was something that came in —

MR. WEINBERG: Well, it was filed in this case.

THE COURT: It is filed.

MR. DANDAR: I would like it to be part of the evidence.

THE COURT: Yes, let’s make this the next plaintiff’s exhibit, which would be what? We’ll make this Plaintiff’s 135.

So now it is Plaintiff’s 135.

MR. DANDAR: All right.



Q Mr. Prince, you have a copy of it?

A Yes, I do.

THE COURT: Do you have that?


THE CLERK: No. I don’t.

THE COURT: Well, you’ll have to give the clerk one.

MR. DANDAR: Well, I’ll make a copy of that as soon as we’re done.

THE COURT: Okay. Because I have one here but it is mine.

MR. DANDAR: It is yours.

THE COURT: And I guess what you want to be sure is the notes — I think they were attached to the original affidavit.


THE COURT: — are part of the affidavit.

So, Madam Clerk, you have an affidavit with some attachments, some handwritten notes?


THE COURT: Go ahead, Counsel.


Q Now, this is an affidavit that was prepared by who?

A Which one now?

Q The one we’re looking at.

THE COURT: The one you have in front of you.


Q The one that says April 2002 but I guess it is


dated May 1, 2002.

A Okay. You know, you gave me three of them here.

Q I gave you what?

A Three declarations.

Q Oh, I’m sorry, the one that Mr. Dandar is entering as his next exhibit is your May 1, 2002 affidavit.

A Okay.

Q Who prepared that affidavit?

A I did.

Q And where did you prepare it?

A Mmm, in Mr. Dandar’s office; partially at my home.

Q When did you prepare it?

A Well, according to this document, it looks like I started it in April and executed it May 1.

Q But, now, this isn’t too long ago. So I’m asking you, when do you recall that you first started work on this affidavit?

A Mmm, let me see. Maybe the second week of April. I don’t know. The second, third week of April. No — yeah, maybe the third week of April.

Q The third week of April?

A Yeah.

Q And did you — at that point, did anybody make any suggestions, revisions, changes, to your affidavit?

A Mmm, no.


Q Who typed the affidavit?

A I did.

Q So it was produced off of your computer?

A Yes.

Q Or what?

A Yes.

Q Executed in Mr. Dandar’s office?

A Correct. I used my laptop.

Q Now, did — what prompted you to do this affidavit?

A My friends were being blackmailed and coerced. There was nothing that I could do to get them to try another solution to whatever problem that they were trying to have — they wanted me to do it with them. I refused to do
it. I spoke to law enforcement about these things. And I put it in writing for the benefit of Judge Schaeffer and anyone else who would be interested in it.

Q The time that you started this affidavit, the Church had already filed its motion terminating sanctions and for disqualification in this case of Mr. Dandar?

A I don’t know. I don’t remember.

Q Well, did you have a copy of the motion when you prepared this affidavit?

A I did not.

Q Had you — did Mr. Dandar ever provide you with a


copy of the motion?

A As I sit here today, I can’t say that he did.

THE COURT: He may have. You are not saying he  didn’t, either, right?

THE WITNESS: No, I don’t — terminating sanctions? No, I don’t think I have seen that thing.


Q And how did you find out that there was — that there had been a motion filed to dismiss this lawsuit as a result of allegations of misconduct and to disqualify Mr. Dandar?

A When it came over to this courtroom, I think it was here the first day because I had been a sequestered witness from Judge Baird’s court, you know, where this thing started. Then when it came over here, I was able to appear
in court the first day. And I was here for it.

Q Mr. Dandar asked you to prepare an affidavit in response to the motion for sanctions?

A Mmm, no, Mr. Weinberg. This is something that I had to sit down and do. It’s not anything I could keep carrying on in my head. I knew that I would have to sit down and write about this.

Q Now, these notes that are at the back of this, that is April 14th, 2002. You see that, correct?


A Yes.

Q Had you already started writing your affidavit as of April 14, 2002?

A No. Because this is the day that I met with Mr. Dandar, Mr. Lirot, then later on that evening met with Mrs. Brooks and Mr. Minton.

Q So it was sometime —

A But, you know, this was just like in case anything happens to me where I don’t appear again, at least this would be written.

Q So the affidavit was written sometime between April 14 — written and completed, obviously, sometime between April 14 and May 1?

A Correct.

Q Now, you attended — I think you testified — the April 9, 2002 hearing before Judge Baird where Mr. Minton testified, purged himself, with regard to his contempt? In other words, purged himself of perjury?

A I —

Q Do you understand that concept?

A You know, I guess that is one way to look at it.But the way I describe it in my affidavit, he got up and lied to save his own skin.

Q And you were there?

A Yes, just for a very short amount of time. And


I — and I covered that really extensively here. The first lie I heard, I got up, I was out the door.

Q And that is when you got really angry at Mr. Minton for the first time?

A I wouldn’t say that. No. I was more upset by the situation. I — I didn’t have anger directed at Mr. Minton.

I mean, I was upset about what he did but, you know, this is my friend. We have been watching these videos. You see we had a close relationship. So it wasn’t like I want to do something to him. I was angry what he had done.

Q Now, it’s your testimony that weeks before that Mr. Minton had told you, before he ever met with Mike Rinder and Sandy Rosen at the end of March, he told you that he had been told that the Church already had his $500,000 check?

A No. I gave testimony about this. I’ll try to answer it as best I can. And I think it is covered here in the very beginning of this affidavit of when all of that talk had started.

Yes, Page 3 of the same affidavit, Paragraph 9, if you go to Line 28, it says: “Bob said there was a problem with some checks he had given to Ken Dandar. Somebody is going to die,” on and on.

Q All right. But there is nowhere in this affidavit where you say that Mr. Rinder or the Church of Scientology


had the $500,000 check prior to the meetings in New York, or even at the meetings in New York, correct? You don’t say that in the affidavit, do you?

A Correct.

Q Did Mr. Minton tell you in this — at any point that his name didn’t appear on the $500,000 check?

A Yes.

Q And you first learned that when?

A That Mr. Minton’s name wasn’t on the check? I think I learned that — you know, I’m not going to speculate. I’m not sure when I learned that.

Q Well, did you learn it at or about the time that Mr. Minton gave the check to Mr. Dandar?

A No, I did not. I wasn’t present when he gave the check to Dandar. You are talking about the $500,000 check?

Q That is the one I asked you about.

A Okay. Well, that particular check I — I think I’ve given testimony concerning the fact that, you know, he took us to the top of the parking garage and told us about this. I’d never seen anything physically with my eyes.

Q Now, where in the affidavit do you talk about the parking garage? Can you show us?

A Mmm, I meant my testimony. Not in here, in the —

Q But is it — didn’t you address it in your affidavit?


A I may have. Let me see.

Q Look at Page 11 at the top.

A Okay.

Q You see where you say, “I reminded them of an incident that happened in August 2001 –”

A Yes.

Q “– where Bob said the case was costing too much and Ken had to cut costs. 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.”

Do you see that?

A Yes.

Q So your most recent sworn affidavit, May 1 of 2002, you said that this alleged incident in the garage took place in August of 2001, not in May of 2000. That is what you say. Right?

A I’m completely confused.

Q Well, look at it again then.

A Okay. Oh, 2001. Yes, that is an error. It was 2000. That is an obvious error. This happened in August of 2000 when the check was issued. Right?


Q No.

A Okay.

Q That is not right. May 1, 2000.

A The $500,000 check?

Q Yes.

A Okay. Sorry. I didn’t remember it like that. I didn’t have the check at my convenience to have that date there. I did the best I could.

Q Well, do you think it is important to be accurate in your declarations, sworn testimony, sworn affidavits?

A Yes, I do.

Q And you are very specific in this reference I just read to you about the circumstances where this alleged conversation took place when Mr. Minton was pulling back in August when we all know that the LMT was about to shut down. That is what you said. Right?

A No.

Q You — we just read it, “Part of the cost-cutting,” that is what you’re talking about?

A What does that have to do with the Lisa McPherson — LMT? I mean —

Q It’s that you described this very vivid incident on the garage in the context of the August 2001 time period when Mr. Minton is cutting back. That is how you describe it. That is how you date it. Correct?


A Okay. That is an error. I thought this $500,000 check happened in 2000. Am I wrong about that?

THE COURT: No. You are not wrong.


THE COURT: It was 2000. But what you said was August.

THE WITNESS: It was not my intention to commit perjury by making a typographical error, if that is what you want to ask me about this, and you pointed it out. No one else did. You know, I’m sorry.


Q Well, if you said May of 2001, maybe I would understand. But it says August of 2001. So where is the typographical error here?

A Because the check was given to Mr. Dandar when?

In 2000, is that right?

Q The testimony is May of 2000.

A Okay. Well, you know, beat me for making a typographical error. I may not have the exact date right. But the incident is correct.

Q So the incident when Mr. Dandar was given the $500,000 check was at the same time that Mr. Minton had decided not to fund the case anymore and to cut back? Because that is what this says.

A Mr. Minton had — well, you know, I stand by this


testimony, whatever it says, with the exception of this typographical error that you correctly point out.

And I think I explained this a little bit yesterday — or whatever day it was — when, you know, they were doing the accident reconstruction, jury surveys. I mean, the costs were mounting. And he was concerned.

Q Who was concerned?

A Mr. Minton.

Q He was concerned about the costs in the Lisa McPherson lawsuit?

A Correct.

Q And so what does that have to do with you dating the $500,000 check when he was concerned about the mounting costs of the Lisa McPherson lawsuit?

A You know, I’m just totally confused. I don’t know where we’re going with this.

Q Well, where we’re going —

A I made a mistake here. I said — I said 2001. I should have said 2000.

Q You said August and you should have said May. And then you should have said, instead of it was at the time that Mr. Minton was cutting back, it was actually the time when he was funding the lawsuit.

Other than that, you didn’t make any mistakes. Right?


A Well, beat me for making a mistake. But, Mmm —

THE COURT: Well, what page is this on, again?

MR. WEINBERG: It’s on Page 11.


MR. WEINBERG: At the top.

THE COURT: I have got it.


Q Well, it’s not that I want to beat you for making a mistake. But is it important to you that your sworn testimony is accurate, or not?

A That is the second time you asked me that. And, yes, I have the same answer. Yes, it is. I made a mistake.

Q Well, do you think you might have made some other mistakes in your sworn testimony, whether it is in court here or in this affidavit or the August 20 affidavit or the other affidavits that you filed?

A Mr. Weinberg, I think I’m doing the best that I can to bring out this testimony into this hearing.

Q Now, after you got angry when you saw Mr. Minton for a short time testify on April 9, 2002, you, a few days later, met with him and Ms. Brooks at the Adam’s Mark Hotel?

A Yes.

Q And that was on or about April 12th?

A Approximately. Yes.

Q You had dinner?


A Yes.

Q And you-all talked about ending the fight against Scientology?

A We talked about committing perjury on behalf of Scientology.

Q Did Mr. Minton tell you that he was relieved because he was finally — he was finally going to be telling the truth and not perjuring himself anymore? Did he tell you that?

A Absolutely not. He told me he didn’t feel good about it, he still wasn’t certain about it, that it was the right thing to do.

He felt horrible about what was going to happen — or the charges that were going to happen to Mr. Dandar.

Q Now —

A He had a conscience about it.

Q Now, when Mr. Minton told you, you say, in March of 2002, that the Church already had this $500,000 check, did you pick up — and it was going to cause — I guess you said it was going to cause him problems, right?

A Yes.

Q He said it was going to cause Mr. Dandar problems, right?

A Cause him problems. He didn’t say Mr. Dandar. He said it was going to cause him problems.


Q Because he was going to have to lie about it, is that what he said?

A No. Because he had already lied about it.

Q All right. Now, did you pick up the phone then, given your concern, and call up Mr. Dandar and say,

“Ken — Mr. Dandar, Bob Minton told me that the Church has this $500,000 check and he perjured himself in your lawsuit and it’s a problem”?

Did you do that?

A No.

Q Why not?

A Well, Mr. Rosen — why do I want to call you Mr. Rosen?

THE COURT: It is late in the day.

THE WITNESS: It is late in the day.

A Mr. Weinberg —


Q We’re both Sandys but he’s a lot taller than I am.

A Yes, that is true.

Why didn’t I immediately call Mr. Dandar?

Q Why didn’t you call Mr. Dandar?

A Because I thought that there was actually something that I could do to — you know, to encourage Mr. Minton to not go down this road. I mean, they’re busy trying to drag me down this road. I’m busy trying to tell


them, “Don’t do it. Don’t go down there.”

Q Did it concern you Mr. Minton was telling you he had already perjured himself in this lawsuit? That is what you just said he told you. That was a problem. Right?

A The problem was that that check surfaced. There was some problem about where it came from. Mmm, I personally don’t know his deposition testimony or his — his testimony that he had given in the courts, what he had said
about that. I don’t know that today. I haven’t read any of that stuff.

But, you know, I described the situation where a man is on the phone, crying uncontrollably, very upset. You know, there was a lot about this that didn’t make sense.

And I’m sorry I couldn’t have been more rational about it to ask a question such as that.

Q After the meeting, dinner, whatever it was, on April 12 at the Adam’s Mark, the next time you met with Ms. Brooks and Mr. Minton was at the Radisson on Sand Key a couple of days later on April 14, is that right?

A I believe I met with them on a Saturday. If I’m right, I met with them at the Adam’s Mark. And the next day I met with them at the Radisson.

Q So whatever the Saturday is, the 12th, 13th, then the next day you went back to the Radisson?

A A Sunday.


Q And that is the last meeting you had with Mr. Minton and Ms. Brooks?

A Correct.

Q That is the day you went to the Radisson is the day that you prepared these notes. Right?

A Earlier that day I prepared these notes.

Q All right. So when you actually went to meet at the Radisson with Mr. Minton and Ms. Brooks, you had already sat down with Mr. Dandar and Mr. Lirot. And who else?

A You know, my girlfriend was there.

Q Was anybody else there?

A Mr. Haverty.

Q Anybody else there?

A Not that I specifically recall.

Q Was Miss Greenway there?

A I don’t know. I don’t think so.

Q You had already sat down with Mr. Dandar and Mr. Lirot and Mr. Haverty?

A No. That is incorrect. I only spoke to Mr. Dandar about this. I pulled him aside and spoke to him about that specifically.

Q So when you said you met with Mr. Lirot, you didn’t really meet with Mr. Lirot, you only met with Mr. Dandar?

A That was the first time I had ever met Mr. Lirot.


Q Can you just answer that question? You didn’t meet with Mr. Lirot, you just met with Mr. Dandar to tell him your concerns, right?

A Correct. And then at the end of that, toward the end of that meeting, I shared some things with Mr. Lirot about it.

Q All right. And is there a particular reason why you met Mr. Dandar at a mall, as opposed to his office?

A Yes. Because I have a continuing concern that my house is electronically bugged by Scientology for illegal surveillance purposes. And I wanted to be in a place where I felt secure in not having that concern.

Q Well, you didn’t have the meeting at your house.

A Correct.

Q My question was why didn’t you have the meeting at Mr. Dandar’s office?

A Because his air-conditioning doesn’t work on the weekend and it is very hot in there. You know, they turn it off. He’s in a building where they turn the air-conditioning off — you know, it’s like a 9-to-5 kind of place. At 5 o’clock, boom, it starts getting hot. On the weekend they don’t turn it on because there is no one in the office, unless you want to pay $25 an hour.

Q So it was his suggestion you meet in the mall?

A Yes.


Q Was there a particular place in the mall where you met?

A We were at the International Plaza at some lounge.

I don’t remember the name of it.

Q Just sitting at a table?

A Yes.

THE COURT: Counsel, please. Please. Move into something —

MR. WEINBERG: I will. I will.


Q Your testimony is, I think, that you didn’t call Mr. Dandar to set up this meeting.

A Correct.

Q You called Frank Oliver, one of the people that was connected with the Lisa McPherson Trust, to set up the meeting with Mr. Dandar. Right?

A Correct.

Q Now, Frank Oliver lives in Miami?

A Correct.

Q Frank Oliver, as far as I know, has never been a consultant or expert for Mr. Dandar. Is that right?

A You would have to ask him that. You know —

Q Do you know from your experience?

A No. I do not know.

Q And you called — you have had dozens of phone


conversations with Mr. Dandar over the years. Correct?

A Hundreds.

Q Right. And we have your phone records in evidence from the LMT.

A Right.

Q There are hundreds of phone calls. Is that right?

A Well —

Q In other words —

A Well —

Q You know his number?

A Yes.

Q Why didn’t you pick up the phone and call him?

A I’ll state it again. I was at home using my home phone. I didn’t want to call him because of those concerns.
I called somebody else.

THE COURT: Was there concern that Mr. Dandar’s phone was bugged, as well? Or not? You did not have that concern.

THE WITNESS: No, I didn’t have that concern.

THE COURT: So the concern you had was your phone was bugged at your house?



Q So — and you picked Mr. Oliver because? Why?

A I trust him. He’s my friend.


Q So from your phone — which you had a concern was bugged — you called Mr. Oliver and said, “I really need you to call Mr. Dandar and set up a meeting with me”?

A No. “Ask him to call me because I want to help him.”

Q Asked who to call you?

A Mr. Dandar.

Q Call you where?

A I called Mr. Oliver and asked him to please have Mr. Dandar call me because I want to help him.

Q Okay. So doesn’t that still concern you, if your phones were bugged, if Mr. Dandar was going to call you?

A I didn’t want to have a long, protracted conversation with Mr. Dandar on my phone specifically about what I wanted to talk to him about.

Q Well, you could have just picked up the phone, called him and said, “I don’t want to have a long, protracted conversation with you over the phone, let’s have a meeting”?

A No, I could have done that. And if I was a wasp, I could have flown away. Where is this going?

Q But you didn’t do that?

A No.

THE COURT: Is there some relevance to that?

Because if there isn’t, I wish you would move on.


MR. WEINBERG: I’ll go on. Mr. Oliver is the next witness. And, you know, I —

THE COURT: Mr. Oliver may or may not be the witness.

MR. WEINBERG: Well, Mr. Dandar told me he was the next witness.

THE COURT: All right.


Q And did you have any kind of conversation with Mr. Oliver, other than to ask him to tell Mr. Dandar to call you?

A No.

Q So you didn’t tell Mr. Oliver the details of what was going on?

A No.

Q You didn’t tell anybody else the details of what was going on other than Mr. Dandar?

A Incorrect. I told Denis deVlaming. Denis deVlaming’s brother.

THE COURT: Some agent — I mean, come on.

We’ve been through this testimony.

MR. WEINBERG: I know. Just names.


Q I mean, there was no nobody else other than what you testified to?


THE COURT: That you can remember, Mr. Prince, at 4:40 in the afternoon —

A Correct.

THE COURT: — when you have been on the stand all day.

A Yes, that is correct, Mr. Weinberg.


Q Now, you testified that you went to the FDLE — to FDLE Agent Strope. Correct?

A Correct.

Q Now, Agent Strope is the — one of the two law enforcement people that were the principal investigators of the criminal investigation of the Church of Scientology. Correct? You knew that?

A Yes.

Q And you had had meetings with Agent Strope over the years?

A I would say that is correct.

Q And what kind of meetings had you had with Agent Strope over the years in your role as either LMT’s VP or trial consultant for Ken Dandar?

MR. DANDAR: Objection. Outside the scope.

THE COURT: Overruled. What is a trial VP?

MR. WEINBERG: I said VP of LMT or a trial consultant.




Q My question is —

MR. LIEBERMAN: It’s getting late.

THE COURT: It’s getting late. Okay.

MR. WEINBERG: And I know the hour.

THE COURT: Well, if you come to a nice little stopping point, we’ll stop. But whatever this is all about, you met with Agent Strope. What is it you want to know about that?

MR. WEINBERG: He said he met with him over the years.


MR. WEINBERG: What I want to know is, you know — you know, what was the — the —

THE COURT: I’m not going — you can ask him about the conversation that he had about whatever is going on in this hearing.

But as far as what he talked to Agent Strope about over the years, that is outside of the scope and I’m not going to let you go there.

MR. WEINBERG: Well, then —

THE COURT: I’m not letting you go there.

Finish up.

MR. WEINBERG: Do you think maybe we can stop


now and just go to —

THE COURT: No. Finish with Agent Strope. I don’t care if it takes until six o’clock. Then we’re going to stop.



Q Now, you met with Agent Strope where?

A In his office downtown Clearwater.

Q And you — was anybody else with you?

A No.

Q Was anybody else with him?

A No.

Q Did he record the conversation?

A He recorded it inasmuch as he took copious notes as I spoke.

THE COURT: Recording means did he put a tape recording on?

THE WITNESS: No, your Honor, nothing electronic.

THE COURT: That is what he means when he says recording. If you don’t understand what somebody says, ask.



Q Do you know if he filed a report with regard to


what you discussed with him?

A I do not.

Q Did he — did he ask to — did you have any — did you reach any agreements with him with regard to cooperation?

A I specifically asked him, “Based on the information — ” I said “– this looks like racketeering to me, it looks like RICO, criminal activity that starts in New York, continues in New Hampshire and carries on down here in Florida.”

And I briefed him on the fact that they’re calling me — you know, I wanted — when I went to deVlaming,

“Please give me a wire so that you can hear what these people are saying,” you know. You don’t — “I don’t even want you to hear it from me. Please give me a wire so you can hear what they’re saying.”

And he told me that —

Q “He” being DeVlaming? Or “he” being Strope?

A Mr. Strope — Mr. Lee Strope. He told me that he would see what he could do, but — Mmm — you know, he was — he was — he was pretty upset about what had happened himself, you know, when I told him this because, again, Mr. Strope and I do have a relationship.

But he — that is when he gave me that message to give to Mr. Minton.


Q Well, let’s — one thing at a time.

A Okay.

Q Did he wire you up?

A No.

Q Did he — did he ask you to report back to him?

A No.

Q Did you have any further conversations with him?

A No — well, I take that back. I’m sorry. He came to Judge Baird’s hearing. I believe he was there for a short time. And we made casual conversation. It was obvious that this thing was going to be protracted and no decision was going to be made any time soon about any type of perjury so he said he would be in touch — we would be in touch.

Q But you haven’t been in touch with him since?

A No.

Q Did Mr. Dandar instruct you to go to Agent Strope?

A I’m not sure if it was Mr. Dandar or Mr. Emmons.

Q Mr. Dandar’s investigator?

A Correct.

Q Did you report to Mr. Dandar and/or Mr. Emmons your contact with Agent Strope?

A Yes, I did.

Q And the day that you went to Agent Strope, was what in relation to these notes of — of April 14?


A I do not remember.

Q Well, you obviously went to Agent Strope before you met with — for the last time — Bob Minton and Stacy Brooks?

A That is incorrect. And that is my fault because I mixed it up, speaking about DeVlaming, when you were asking me specifically about Mr. Strope, because it was with Mr. DeVlaming that I asked him to give me a federal agent,
not a local person, that would be willing to put a wire on me, because, you know — but by the time I met with Mr. Strope, the opportunity was passed.

THE COURT: You met with Strope after. That is not the person you met with when Denis deVlaming or Doug DeVlaming or whenever somebody sent you to see somebody?

THE WITNESS: Douglas DeVlaming said he would do the contact himself. He contacted the agent, explained the situation to him, then he called me and told me what the federal agent told him.


Q Right. Well, that was a federal agent. You never met with a federal agent, right?

A Personally, no.

Q So that is what Mr. DeVlaming was doing?

A Douglas DeVlaming.


Q But at the suggestion of Mr. Emmons or Mr. Dandar, you are the one that initiated the contact with Agent Strope of the FDLE. Correct?

A Well, you know, that is not the way you said it, Mr. Weinberg. You said who asked you to go. I said it was either Mr. Dandar or it was Mr. Emmons. Now you are saying I arranged it and somehow — you know, one of the two persons, Mr. Emmons or Mr. Dandar, arranged or contacted Mr. Strope and arranged for me to meet with him.

Q The way we started was I was just trying to date it. It was sometime before the April 14 last meeting with Mr. Minton and Ms. Brooks. Correct?

A Incorrect.

Q So you went to Agent Strope after you had had your last meeting with Ms. Brooks and — and — and Mr. Minton?

A Correct.

Q You wanted Agent Strope to make you an informant?

A No. I wanted Agent Strope to do what he could to talk to someone on a federal level to deal with this problem, because in my mind it was a federal crime. I asked him about that.

And he — you know, he said, “If what you are saying is true, it is a federal crime.”

I didn’t want to fool around with the Florida folks. I wanted something federal, because it happened in


New York, it happened in New Hampshire, and it happened here in Clearwater.

Q At the time that this was going on, you meeting with Agent Strope, did you know that Mr. Minton had a lawyer with regard to these matters?

A Oh, I think it was Mr. Howie, wasn’t it? Well, he had a couple lawyers. Mr. Howie. Mr. Jonas.

Q And it’s your testimony that Agent Strope told you, if not instructed you, to deliver a message to Mr. Minton?

THE COURT: He already testified to that.

A Correct.

THE COURT: Asked and answered.

A Correct.

THE COURT: I believe I asked the question the second time. So we really don’t need it for the third time.

MR. WEINBERG: All right.

THE COURT: The testimony is what it is.


Q And you delivered the message?

A Yes, I did — well, as I testified, my fiancee delivered the message. She read it to him. I wrote it down on a piece of paper. She read it to him over the phone.

MR. WEINBERG: That is a good stopping point.


THE COURT: Okay. Then we’re done for the day.

And we will start tomorrow at —

(A discussion was held off the record.)

THE COURT: We’ll start tomorrow at nine.

We’ll be in recess.

MR. WEINBERG: I should tell Mr. Dandar, I don’t have very much more with Mr. Prince, so he needs to be ready for the next witness.

MR. DANDAR: How much more?

THE COURT: Have your witness here in the morning.

MR. DANDAR: Judge, I’m handing over to the defense my response to the request to produce.

THE COURT: I don’t have to get into that unless you-all don’t get together on it.

Requests to produce normally don’t require the Court.

MR. DANDAR: I just wanted to file it with the clerk.

THE COURT: We’re in recess until 9 o’clock.

Good night.

(WHEREUPON, Court is adjourned at 4:55 p.m.)





I, LYNNE J. IDE, Registered Merit Reporter, certify that I was authorized to and did stenographically report the proceedings herein, and that the transcript is a true and complete record of my stenographic notes.

I further certify that I am not a relative, employee, attorney or counsel of any of the parties, nor am I a relative or employee of any of the parties’ attorney or counsel connected with the action, nor am I financially interested in the action.

DATED this 10th day of July, 2002.



Testimony of Jesse Prince (Volume 5) (July 9, 2002)


CASE NO. 00-5682-CI-11

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




PROCEEDINGS: Defendants’ Omnibus Motion for Terminating Sanctions and Other Relief.

CONTENTS: Testimony of Jesse Prince.1


DATE: July 9, 2002. Afternoon Session.

PLACE: Courtroom B, Judicial Building
St. Petersburg, Florida.

BEFORE: Honorable Susan F. Schaeffer,  Circuit Judge.

Deputy Official Court Reporter,
Sixth Judicial Circuit of Florida.



340 West Kennedy Blvd., Suite 201
Tampa, FL 33602
Attorney for Plaintiff.

112 N East Street, Street, Suite B
Tampa, FL 33602-4108
Attorney for Plaintiff

100 Cleveland Street, Suite 900
Clearwater, FL 33755
Attorney for Church of Scientology Flag Service Organization.

101 E. Kennedy Blvd, Suite 1200
Tampa, FL 33602-5147
Attorney for Church of Scientology Flag Service Organization.

740 Broadway at Astor Place
New York, NY 10003-9518
Attorney for Church of Scientology Flag Service Organization.


Battaglia, Ross, Dicus & Wein, P.A.
980 Tyrone Boulevard
St. Petersburg, Florida 33710
Counsel for Robert Minton.


THE COURT: You may be seated. Okay, before we begin, two questions. Have you decided when you want the trial date, Mr. Dandar?

MR. DANDAR: September.

THE COURT: All right. Have you decided whether or not you need Mr. Rosen?

MR. DANDAR: No, I don’t need Mr. Rosen.

THE COURT: All right. Then I’m going to assume that — I will go ahead and enter an order pro hac vice admitting Mr. Rosen, just in case.

He’ll be admitted, just for this purpose. And I’ll let you have —

MR. FUGATE: Should I prepare an order, Judge?

THE COURT: Do you mind?


THE COURT: Tell him to prepare an order, whatever.

MR. FUGATE: I’ll do it.

MR. DANDAR: So, Judge, since we will start picking a jury for the trial in September, what specific date would that be?

THE COURT: The second week in September. Whatever that Monday is.

MR. DANDAR: All right.

THE COURT: You may proceed.


MR. DANDAR: Thank you.

THE COURT: That, of course, assumes the motion to dismiss is not granted.

MR. DANDAR: I understand.

THE COURT: Mr. Lirot, are you still of the mind that if Mr. Dandar is removed as counsel, you are prepared on that date?

MR. LIROT: Hope springs eternal, Judge. But yes, Judge, I’ll be prepared on that date if need be.

THE COURT: All right.


Q Mr. Prince, what I was trying to do before the lunch break was finish up on the meetings that you had with Mr. Minton and Stacy Brooks.

A Okay.

Q I believe we left off with your meeting with them when things got a little testy at the hotel for dinner.

A At the Radisson.

Q At the Radisson. In my — your note attached to your affidavit, you said you met with me before you met with them that Sunday. So that was April 14th.

A Okay.

Q All right? So let’s go from then on. What happened after April 14th?


A Mmm —

THE COURT: I’m sorry, he met with you before he met with them?

MR. DANDAR: That same day. That is where this handwritten note —

THE COURT: Right. For some reason, I thought it was after. But it was before?

MR. DANDAR: On this particular day he met with me at the mall with Mr. Lirot. And that was April 14th.

THE COURT: In the afternoon? Then he went there in the evening?

MR. DANDAR: Then he went there.


Q What happened after April 14th?

A Mmm, well, contact again — and I think I mentioned I had the one phone conversation with Mr. Minton where I invited him over to my house.

But they — they talked to me — or got messages to me via my fiancee. They would talk to her.

And if anything happened — we wouldn’t talk, we were not talking.

Q And what messages did you receive from Mr. Minton and Ms. Brooks that way?

MR. WEINBERG: Objection. Hearsay, your Honor.

THE COURT: Hearsay. That would have to be


hearsay. I mean, that would have nothing to do with Mr. Minton’s state of mind or anything in this proceeding, so you would have to, at the very least, bring in the other person.


Q So you never talked with Mr. Minton or Ms. Brooks since then directly, one-on-one?

A I talked with Mrs. Brooks. Mmm, she just told me that everything was going to be fine, regardless of whether or not I agreed to go with them or participate in activities with them with Scientology. She just told me things were
going to be okay.

Q When did Ms. Brooks stop paying you your monthly income?

A Either March or April.

Q And you said before that you went to Denis deVlaming’s office and spoke with him, and he couldn’t help you because of the conflict of interest. Did you go to any law enforcement?

A Well, it’s not entirely true to say that Mr. DeVlaming couldn’t help me.

What Mr. DeVlaming did do is refer me to his brother because, again, I wanted to somehow get a federal law enforcement involved in this, since my perception was that the criminal activity — conspiracy and criminal activity happened at least in New


York, New Hampshire and Clearwater.

Mmm, he said that he would talk with a federal agent that he did know and get back with me. He — I guess maybe a day or so later, he had a conversation with the federal agent, Mr. Douglas DeVlaming.

And he told me, after speaking with an agent, they thought that it would make a difficult case because Mr. Minton was now on the stand lying, telling lies. If he changed his mind —

MR. WEINBERG: Objection. Hearsay, your Honor.

THE COURT: Sustained.


Q Did you ever meet personally with law enforcement?

A Yes, I did.

Q All right. Who did you meet with?

A I met with FDLE Agent Lee Strope.

Q Did you talk about Mr. Minton and Ms. Brooks?

A I pretty much gave Mr. Strope a complete rundown of the meetings, with the dates similar to how I laid it out there in the affidavit. And after —

THE COURT: Mr. Strope is with what agency?



A And after speaking with him, he asked me to give Bob Minton a message. And the message was that if it is determined that you have perjured yourself on the stand,


that he would see to it that charges would be brought.


Q This is Mr. Strope telling you to talk to Mr. Minton?

A This is a message Mr. Strope asked me to give Mr. Minton specifically.

Q Did you give him that message?

A Mmm, I wrote — I hand-wrote what he said. I gave it to my fiancee and she read it to Mr. Minton over the phone.

Q Okay.

THE COURT: Mr. Prince, is it your testimony here today under oath an agent of the Florida Department of Law Enforcement asked you to deliver a message to someone?

THE WITNESS: Yes, your Honor.


Q Any other meetings with law enforcement?

A Not about this specific incident.

Q Okay. Now, what was your impression, after meeting with Ms. Brooks and Mr. Minton, on the meetings you have just mentioned, all of these meetings —

MR. WEINBERG: Objection to the form. What was his impression?

THE COURT: Yes. What does that mean?


MR. DANDAR: I didn’t finish my sentence.

THE COURT: Go ahead.


Q What was your impression as to who was the person who was creating the scenario that I told Mr. Minton to lie?

A Mr. Rinder.

Q And what is the basis of that? What is the basis of your impression it is Mr. Rinder?

A Because that is what they said.

Q Who said?

A Bob and Stacy.

Q All right.

MR. WEINBERG: Well, could we just — I mean, is that — your Honor, so his testimony is that at some point Bob Minton and Stacy Brooks said that Mike Rinder said for Mr. Minton to lie?

THE COURT: Yes. That is his testimony.

MR. WEINBERG: Could we date that testimony, please?

THE COURT: Mr. Prince, is that your testimony?

THE WITNESS: Yes, it is.

THE COURT: If you could look at your affidavit and tell us which one of these conversations that that conversation took place.

THE WITNESS: Okay. Let me see if I see it


here. I don’t seem to have my affidavit up here.

THE COURT: You don’t? I think I have it right here, if it will help.

MR. DANDAR: Well, I have the affidavit right here. I’m sorry. I was looking at it instead of listening to the Court.

THE WITNESS: This would have had to have happened sometime after the date that I mentioned on Page 5, Line 16, Paragraph Number 11 of the 3rd of April or 2nd of April, sometime after that time period.


Q After this — after the 2nd or 3rd of April?

A Correct.

Q All right. Did Mr. Minton or Ms. Brooks tell you this on more than one occasion?

A Well, the subject of the meetings — after they returned to Clearwater with Mr. Bunker April 2nd, the many times that I met with them, the subject of the conversations concerned what they were asked — or what they were being asked to do, what they wanted me to do.

So that was a continuing theme until, you know, the point that it finally broke off, because I didn’t, I guess, qualify to meet with the Scientologists or speak with them about this myself. But it was a continuing theme of



THE COURT: I believe that, in fairness, Mr. Prince may have testified to some of this yesterday, too.

MR. DANDAR: I think so maybe.

THE COURT: And may have dated some of this yesterday. I’m looking through his affidavit. I am remembering some of his testimony from yesterday.

MR. DANDAR: All right.


Q Now, Mr. Prince, yesterday you talked about Volume 0 and 00. Do you recall that? You looked in the book Introduction To Ethics and you said —

A Yes.

Q — what you were looking for may be in Volume 0 and 00?

A Yes.

Q And there are a bunch of books over there. Are there any of the books you want to refer the Court to?

A Sure, if I could just walk over there.

MR. DANDAR: Is that all right, Judge?

THE COURT: Yes. By the way, Ms. Greenway asked if she could take my picture. You can’t take pictures when court is in session. So I gave her permission to come in and take pictures when court


wasn’t in session of whatever she wanted to take pictures for. But when court is in session you cannot take pictures unless you are connected with the media and you are a pool photographer. Then you can.


Q No other books?

A No.

Q All right.

A This is — first off, I would like to say yesterday that I said that this was a crime for a person to give testimony about Scientology. I actually misspoke. It is a suppressive act to do that, according to this document here, suppressive acts, suppression of Scientology, Scientologists, the fair game law. And what it states specifically is —

THE COURT: Tell us, first of all, what are you reading from.

THE WITNESS: Oh, sorry.


Q The book?

A I’m reading from HCO Division 1 Policy Volume, Scientology Policy Volume.

THE COURT: Okay. Those are Scientology policies in a book?


THE WITNESS: Yes, your Honor.

THE COURT: Is there a page number?

THE WITNESS: Yes, your Honor. It is 553, what I’m going to make reference to.

MR. LIEBERMAN: Could we have the date on that book?


Q Copyright on the front?

THE COURT: Would it matter with these policies —

MR. LIEBERMAN: Well, some, it may.

THE WITNESS: This is copyright 1970 through — what is it, 1950, it looks like. These are all of the copyright notices here.

THE COURT: Okay. I’m going to let you-all take a look at it.


THE COURT: No. Let him go ahead and have his testimony, and then before cross-examination you-all can look at the book.


Q So a suppressive act is someone saying they want to leave Scientology?

A Yes. And testifying as a hostile witness against Scientology in public is a suppressive act.


Q All right. That has to do with testifying?

A Correct.

Q What about leaving Scientology or saying you want to leave?

A Mmm, yesterday I showed the reference and we went through that. It’s a high crime to publicly depart Scientology.

Q This may be something I already marked. Let me show you what has been marked as Plaintiff’s Exhibit 133. CS Series 22.

Can you identify that Exhibit 133?

A Yes. This is an HCO bulletin of 28 November, 1970, Mmm, subtitled “CS Series 22.” The “CS Series” means case supervisor series. It’s — it’s a series that is a staple or basic for persons that are supervising auditing in Scientology. And this document refers to the subject of psychosis.

Q And this document came from the PTS/SP course book you read yesterday. Is that correct?

A Correct.

Q Okay. Now —

THE COURT: Who is permitted to take that course? Maybe you asked it before, but, I mean, if I’m a new Scientologist, new public member, can I go register for that course?


THE WITNESS: You certainly could. Any Scientologist in good standing —

THE COURT: Could take that course?

THE WITNESS: Yes, your Honor.



Q This course book also contains the search and discovery bulletin?

A I believe it does.

Q Okay. Now, this particular document, Exhibit 133, CS Series 22, does this have anything to do with people wanting to leave?

A Well, if you turn to the second page, it talks about the easiest ways for a case supervisor to detect the insane, and we go down here to Number 6, it says: “They often seek transfers or wish to leave.”

Q Now, does this apply to staff as well as public members?

A Absolutely.

THE COURT: I think this is already in evidence, isn’t it?

MR. DANDAR: I’m not sure. You told me to mark this yesterday as an exhibit.

THE COURT: Well, now that I’m looking at it, I’m thinking I read it before. But if you are not


sure, you want to introduce it again, why, that is all right.

MR. DANDAR: I’m really not sure.

THE COURT: All right.

MR. DANDAR: I know we talked about this yesterday.

THE COURT: I’m not positive if this was the document, but I have read some of this before.

MR. DANDAR: Yes. It is quite possible.

MR. WEINBERG: We have no problem, but the next-to-last sentence says: “The insane can be helped, they are not hopeless.” We don’t have a problem with this. But the introspection rundown comes after this policy.

THE COURT: But you have no objection to this being introduced?


MR. DANDAR: We move it into evidence.

MR. WEINBERG: It was referred to in the introspection rundown which was introduced three or four years later, this policy.

THE COURT: All right.


Q Speaking of the introspection rundown, Mr. Prince, speaking of your experience, expertise, is there any part of


the introspection rundown that is considered religious?

MR. WEINBERG: Objection to his competence to this because Mr. Prince previously testified he wasn’t trained on the introspection rundown and never — as an auditor never did any introspection rundown.

THE COURT: I thought he did.

THE WITNESS: That is correct. I did. I never was — I never stated that I was not trained on the introspection rundown.

THE COURT: I’m sorry, what?

THE WITNESS: I never stated I was not trained on the introspection rundown. That is false. I am very trained on the introspection rundown.

MR. WEINBERG: What he said was he participated in an isolation watch, not as the auditor, you know, but as one of the people staying with Teresita.

THE COURT: Is isolation watch and introspection rundown the same?

MR. WEINBERG: It is part, Step whatever it is, 0, 00.

THE COURT: All right.

MR. DANDAR: This will kind of answer the question, I think.



Q So, Mr. Prince, is there parts or all of the introspection rundown that is religious? A religious practice?

A Mmm, in the very first bulletin about the introspection rundown, L. Ron Hubbard describes it as a new technical breakthrough that marveled something else of the 20th century, I forget specifically what it says there. But it was hailed as a researched scientific discovery for handling insanity.

MR. WEINBERG: So, your Honor, is what Mr. Dandar is doing is challenging whether or not the introspection rundown is part of the religion of Scientology? Because if he is, I think that has already been decided in this case and it is not appropriate and we should not be wasting our time on it.

THE COURT: Haven’t we decided that — or — I don’t know because I don’t know — I saw a motion once that dealt with religiocity. I didn’t hear any of that.

MR. DANDAR: That was not the —

MR. LIEBERMAN: But you have stated several times, your Honor, that there is no question in this case as to the religious nature of Scientology or


religious nature of the introspection rundown.

THE COURT: Okay. I know I have stated that I have no question on the — that the Church of Scientology is a religion and it is a recognized religion in the Church. And I have no question in my mind that Lisa McPherson was undergoing some sort of introspection rundown. I didn’t know whether I said that introspection rundown is part of the religion of the Church. I don’t even know if that is a call for me to make, to tell you the truth. I would suspect the Church doctrine would tell us whether it is or isn’t.

MR. LIEBERMAN: That is correct. And the Church characterizes what is religious practice.

THE COURT: I don’t know if I have seen that or not. I know we have a Mr. Rice affidavit. I haven’t looked at it in some time.

MR. LIEBERMAN: And he quite clearly places it within the Scientology practice. In fact, every part of Scientology, by definition, is part of Scientology belief and practice and is not a matter for the Court to challenge what is characterized by the Church as this religion.

THE COURT: I am going to let him answer this. I think he already has answered it, but I don’t know


we’re going to go there. And certainly one answer isn’t going to get it there.

MR. DANDAR: Right.


Q Mr. Prince, Mr. Hubbard called it scientific breakthrough?

A That is correct.

Q Did he ever call it religious practice?

A Never.

Q Did he call auditing a religious practice?

A No.

Q Oh.

A Not to my knowledge. I mean, this whole business of religion — I don’t know, you know, it is kind of — has kind of reared its head in Scientology every now and again. When I was here at the Flag Service Organization in 1979, there was a scare — a cold war scare of some nuclear threat and conscription in the Army and on and on. This is what we were told. So all of the staff had to do a two-week course called the minister’s course where you are instantly trained to be a minister. This was part of — a program which, in part, was to kind of improve or create a religious image for Scientology.

But if you will notice, in every document that Mr. Hubbard writes about Scientology, whether or not it is a


green —

THE COURT: I don’t want to hear this. The United States Government, State of Florida, on and on down, determined Scientology is a religion, the Church of Scientology is a church. I don’t care what they used to think, what they used to say. It doesn’t matter. That is it.

MR. DANDAR: What I’m — I was getting at is just the introspection rundown itself.



Q The part of the introspection rundown talking about get some rest —

MR. WEINBERG: Your Honor, could I —


Q — make sure you eat —

MR. WEINBERG: This is precisely why Mr. Prince should not be an expert, considered an expert in Scientology, because as he sits here today, he still is sitting there saying it is not even a religion or a church. He doesn’t recognize it —

THE COURT: He wasn’t. He was talking about some things that were said back in the 1970s when they were all sitting around talking —

MR. WEINBERG: He just said that — well, I


don’t want to argue with you. I mean, it — that is where he was going with this and that is what this — that is what this is about.

MR. DANDAR: It is not what this is about. I just asked him what I’m asking him now, the introspection rundown, the part that talks about resting and eating — resting and eating, something else —

THE COURT: 0, 00.

MR. DANDAR: Yes, those two steps.


Q In your experience within the Church of Scientology, was that ever considered a spiritual or religious part of Scientology?

MR. LIEBERMAN: Your Honor, again, this is unconstitutional inquiry. You can’t bifurcate a religious practice and say part is and part isn’t. To just even hear this testimony is an unconstitutional attack on the religion.

THE COURT: Mr. Lieberman, your objection on that is preserved.

MR. LIEBERMAN: Thank you.

A Well, you know, since — you know, people that are atheists or other ideas also rest and sleep. You know, it never came to me that this was a religious experience to


rest and eat.


Q Well, and in your knowledge of Scientology, if someone is injected with Valium or chloral hydrate, are they eligible to have auditing?

A According to — Mmm — the HCO bulletin entitled Model Session —

Q How do you spell that?

A Model, M-O-D-E-L, model session, a person who has had drugs or who has used drugs continuously is not eligible for auditing until six weeks after the period of taking the drugs.

Q Now, in your experience with Teresita, you said Dr. Dink, Hubbard’s doctor, came out and injected her with some kind of drug?

A Correct.

Q And she went to sleep?

A Correct.

Q How soon after that did she have auditing?

A Within hours after awaking.

Q Was that within the written policy?

A Is that what now? I’m sorry.

Q Is that per policy to have an auditing right after you have slept off the effects of the drug?

A Well, in the introspection rundown bulletin, it


states that each program is tailored specifically for the individual. So to that degree, if the person had to sleep first in order to get auditing, they would get the auditing, but then there is also later references in Scientology technology which state that in a period after the auditing that was delivered, while the person was on drugs, you could then go back and check those areas again to make sure that everything is fine.

Q Okay. Let me show you Exhibit 134. And do you recognize where this copy of this Page 258 comes from?

A Yes. This comes from the Hubbard Administrative Dictionary.

Q And what — how does it define the phrase “high crimes”?

A It says: “High crimes. 1. These consist of publicly departing Scientology or committing suppressive acts. Cancellation of certificates, classifications and awards and becoming fair game are amongst the penalties which can be leveled for this type of offense as well as those recommended by Committees of Evidence.”

MR. DANDAR: Okay. That is all of the questions I have.

THE COURT: All right. Thank you. You may inquire.

MR. WEINBERG: Thank you.



Q Mr. Prince, David Miscavige busted you from your position of authority — your executive position of authority in the RTC — in March of 1987, didn’t he?

A Correct.

THE COURT: I’m sorry, you just got started.

Did you want to introduce this 134?

MR. DANDAR: Yes, sir. In fact —

MR. WEINBERG: We object to that. I would like to see the dictionary, see what the date of the dictionary was.

MR. DANDAR: Do you have it here? In fact, I just realized, unless you want to do this later, there are a bunch of things I marked and didn’t move them into evidence.

THE COURT: I’ll go ahead and let you do that —

MR. DANDAR: Later?

THE COURT: — later. But don’t forget.

MR. DANDAR: Right. Yes.

MR. WEINBERG: Should I start over?



Q Mr. Prince, David Miscavige busted you from your


position — your executive position of authority in the RTC in March of 1987, didn’t he?

A Correct.

Q And at that time you were removed from your post, the last executive post you ever held in the Church of Scientology. Correct?

A Correct.

Q And that post, you said, was deputy inspector general external. Right?

A Right.

Q Now, you were removed because you had supported Pat Broeker and Annie Broeker and Vicki Aznaran in their effort to change Scientology tech. Correct?

A That is categorically false.

Q That was precisely what occurred, that Pat Broeker, who had designated himself the loyal officer, was in the process of changing, among other things, the Scientology grade chart, right? That is what he was doing?

A That is categorically false.

Q So Mr. Broeker wasn’t doing that?

A Correct.

Q And you never acknowledged that Mr. Broeker did that?

A Correct.

Q So Mr. Broeker wasn’t off on his own, trying to


change the religion of Scientology, after Mr. Hubbard died?

A Well —

Q Yes? Or no?

A Excuse me. Let me answer the question.

THE COURT: Well, I’ll tell you how this works on cross-examination. Go ahead and answer the question, but if you feel you have to explain your answer, you are allowed to do that after you have answered it.

THE WITNESS: Okay. I’m sorry.

A Ask me the question again.


Q Wasn’t Mr. Broeker caught in — in an attempt to change Scientology tech?

A I have no percipient knowledge of that.

Q You have no percipient knowledge of that?

A In other words, I was not there — let me — I was not there. I didn’t see him changing anything. And, again, I was going to say, I have heard some hearsay about it. Since you vehemently object about it, I won’t comment about it, but I — you know, I haven’t personally been with Mr. Broeker when he’s altering Scientology technology.

Q When you were in the RTC prior to March of 1987, in that year after Mr. Hubbard died, you became aware of the


fact that some point in time that Mr. Broeker was changing and altering Scientology tech, weren’t you?

A Incorrect.

Q You became aware of the fact that Vicki Aznaran was part of an effort to change Scientology tech, weren’t you?

A Absolutely incorrect.

Q And what happened in March of 1987 is that Mr. Broeker was removed from all authority. Correct?

A Mr. Broeker was removed from authority.

THE COURT: Wasn’t? Or was?

THE WITNESS: He was, your Honor.


Q Annie Broeker, his wife, was removed from all positions of authority. Correct?

A To my knowledge, that is correct.

Q Your boss, Vicki Aznaran, was removed from her position of authority. Correct?

A Correct.

Q And you were removed?

A Correct.

Q And you were at that time — at that point in time, you went from what you described as an executive position with some authority in the — in RTC. Right?

A Correct.


Q To no authority whatsoever?

A No. That is incorrect.

Q From — for the next five years after March of 1987, did you ever hold a position where someone was junior to you? You know what I mean by that?

A Yes, I do. And, yes, I have.

Q I mean, you were, what, a machine operator after that?

A Mmm, no. I worked on post-production, pre-production and post-production for films.

Q That was one of the things you did, and you were a Cinemix, was that your job?

A No.

Q What was your job?

A My job was like an assistant engineer, assistant sound mixer. Again, I state I worked for post-production and pre-production for films and videos.

Q During that period of time you were in the RPF a couple of times. Correct?

A Incorrect.

Q How many times were you in the RPF?

A I was in the RPF two times, but not that period of time.

Q You were in the RPF in March of 1987. Correct?

A Correct.


Q All right. Until what, the end of 1987?

A Mmm, I think it was — I wasn’t in there a very long time. I think maybe four months.

Q By the way, there is no higher crime in Scientology than changing the tech. Correct?

A That is incorrect.

Q Well, what would be a higher crime than changing Mr. Hubbard’s scriptures?

A Placing Scientology and Scientologists at risk.

Q One of the highest crimes in Scientology is to alter the tech. Correct?

A It is a high crime to do that. Yes.

Q Now, for the next — for those five years after you were busted — and that was the day you claimed, by the way, that you pulled these guns on David Miscavige and threatened to kill him?

A You didn’t mention a specific day. What day are you talking about?

Q Well, what day are you talking about when you were busted?

THE COURT: Without worrying too much about the date, the date you testified about when you were rousted from bed or got out of bed and went and got the guns, that is on the same day, right?

THE WITNESS: Yes. I’m sorry.


THE COURT: That is the day you were busted?


THE COURT: That is what he was referring to.

THE WITNESS: Okay. I’m sorry. I just didn’t understand the question.


Q That is the same day you claim you pulled these guns on David Miscavige and you threatened to kill him.


A I didn’t threaten to kill Mr. Miscavige. What — maybe you have a wrong idea about what happened there.

I came there to defend myself. Twelve people were attacking me, were trying to hold me. Because I do know karate and have a black belt in it, I was able to get them away from me until I went and got protection for myself.

Q So then these twelve people that were attacking you let you go back to your room, get these two loaded guns?

A They didn’t know where I was going.

Q That didn’t really happen, did it, Mr. Prince?

A Yes, it did.

Q You didn’t pull guns on David Miscavige.

A Yes, it did.

Q So this is the person you say you could still be friendly with?

A You know, Mmm — yes. And I need to explain


something here because, you know, Mr. Weinberg, you and I have been around and around on this in front of Judge Moody. So, you know, you are giving me the exact same questions and I’ll sit here and be patient with you, but I think the record reflects we have done this one or two times before.

THE COURT: See, I haven’t heard it. This is my hearing, so we’ll do it again.

MR. DANDAR: Explain yourself.



Q So you contend that you really did go back to your room, get two loaded weapons, and walk back and enter a room and point them directly at David Miscavige?

A No, I never walked back into a room. By that time —

Q You ran back into the room?

A Would you like me to explain it? I —

Q Explain it.

MR. DANDAR: Wait. Wait. Objection.


Q Did you —

MR. DANDAR: He needs to explain it.

Mr. Weinberg —

MR. WEINBERG: I’ll withdraw that question.



Q Did you point two loaded guns —

MR. DANDAR: That is not fair.


Q — at David Miscavige?

A No, I did not.

Q Who did you point them at?

A I had the one gun on my hip and the .45 in my hand. And they stood this way. The assault rifle never was pointed at anyone. It was just on my hip like this. And I had the .45.

And Mr. Miscavige, when he saw me, walked directly up to me with those guns in my hand and said, “Jesse, we are friends. Let’s talk.”

So I don’t think he felt that threatened. And I think that Judge Moody pointed that out to you the last time we were doing this.

Q I mean, no one would feel threatened when they had just busted somebody from position and the person got so mad to go back to the room and get two loaded guns and walk into a room. You can’t imagine anybody would be threatened by that, would they?

A I think that is a mischaracterization of what happened.

Q Well, my question is was there a particular reason


why you never told that story until — until you started getting paid to be a witness in the FACTNet case in 19 — whatever it is, 1998?

Why you waited all those years to tell that story?

A Mmm, I don’t know how to answer that question, Mr. Weinberg. You are associating things that don’t associate. You are associating with me being paid telling stories. And there is no association there.

Q Well, is there a particular reason, in the years after this alleged incident took place, that took you until 1998 to first tell this story about pulling guns on David Miscavige?

MR. DANDAR: Object to the form. It makes no sense. Telling stories where? Under oath? In a deposition? To his friends?

THE COURT: I don’t, either, because I don’t know whether you are talking about the first time he ever testified about that, and if that is the first case he was ever involved in, that is the first time he ever testified about that.


THE COURT: I’ll tell you one thing —

MR. WEINBERG: I’m sorry, I didn’t mean to —

THE COURT: — don’t get ahead of me because you want to go at this witness.


MR. WEINBERG: You are right.

THE COURT: I won’t have it.


THE COURT: I won’t have you really cutting this man off. I mean, I know you want to get where you want to go. But you’ll have to go slow.

And, Mr. Prince, whatever you told Judge Moody, I haven’t heard it, I haven’t seen too much of the transcript before Judge Moody, so I don’t want to hear what I — I already told Judge Moody this, I am not Judge Moody.

THE WITNESS: I understand.

THE COURT: If he asks you a question, unless I tell him, “You can’t ask that question,” just answer, even if you have already answered it before.


THE WITNESS: Okay. Yes, your Honor.

THE COURT: Let’s go.


Q You were interviewed by Earle Cooley while still in the Church in 1988, weren’t you, in relation to another lawsuit?

A I would have to see something about that. I’m not sure what you are talking about.

Q You didn’t say anything about the guns to him, did



A Again, I would have to see what you’re talking about.

Q Well, you mention the 1994 interview with Mr. Cooley. You didn’t say anything about the guns to him in that interview, did you?

A I mean, you know, you are mixing apples and oranges. I mean, I don’t understand what you are asking me. I mean, I have told that story long before 1998 to my friends, my family, people that I know. I mean, you know, it isn’t like here is some money, let’s tell this story. I beg to differ with the way you are characterizing what happened here.

Q The reason you told the story to Mr. Minton in April of this year was to threaten him as to what you would do as to what kind of person you were? I mean, what did you tell him about it for?

A I told him that story, as I gave testimony yesterday, to show that Scientology, more than likely, will never keep or honor an agreement with anyone. It wasn’t to say I’m going to run and shoot you with guns. It was to give him an example to show him that Scientology will never honor an agreement.

Q Now, you would agree that the positions that you held after you were busted were extremely low positions in


the Church of Scientology?

A I would beg to differ on that, as well.

Q Now, you were — you were so humiliated, apparently, by Mr. — what you claim Mr. Miscavige did in March of 1987 that you pulled these guns on him. That is what it was about, wasn’t it?

A Absolutely not. And even as we have been sitting here, I think I made it clear to you why I went and got those guns. It wasn’t humiliation. It was being attacked.

Q You were —

A Physically attacked.

Q You resented the fact that you had been busted?

A I resented the fact I was being physically attacked by people that used to be my friends.

Q No. My question is did you resent the fact that you had been busted from your executive position in RTC?

A And I’ll answer the question it isn’t so much that I resented the fact that —

THE COURT: Come on, Mr. Prince, of course you must have been annoyed. I don’t know why we’re playing a semantics game. Anybody would be annoyed if they were busted from the position they thought —

THE WITNESS: No, your Honor, that isn’t right.

I think that deserves clarification because I was


pretty much tired of that activity that I had been involved in, in Scientology. I was ready for a change. I was ready to be done with that position because that — that position responsibility entailed being involved in criminal activity.

This is something that I had not experienced in Scientology prior to going to Gilman, Hot Springs and working at that level. To me, Scientology was something different than what I was doing.

So, no, it wasn’t a big deal for me, you know. I was already wanting to be away from that responsibility.

But what was a big problem for me was twelve people grabbing me, because I had an earlier incident of that happening in Scientology where six people grabbed me and locked me in a room for three months, and I ended up staying 16 years. So that had precedent over that position I was being removed from.


Q So you were relieved by the fact you were busted from your position?

A Yes. I was somewhat relieved by it.

Q Now, you — you, Jesse Prince, dislike vehemently David Miscavige, don’t you?


A I would not say that that is true. I have no vehement dislike for him. I dislike the things that he does. But I don’t envy his position. He’s the leader of a religion. He has a lot of responsibility. That doesn’t give you license to be a criminal, though.

Q You spent the last four years, ever since you met apparently sometime in the summer of 1998, started getting paid by, ever since you met Mr. Minton, you spent the last four years trying to destroy David Miscavige, haven’t you?

A That is incorrect.

Q You have picketed where you have spoken vilely and obscenely about Mr. Miscavige, haven’t you?

A Yes, I have.

Q You have picketed various Churches of Scientology around the country and even in the world, correct?

A That is incorrect. I never picketed an organization outside of the United States.

Q Just in this country?

A Correct.

Q You have threatened David Miscavige in these pickets, haven’t you?

A I need you to clarify what you mean by threatened for me, please.

Q Threatened to do harm to him.

A I have jokingly alluded to it, yes, I have.


Q You thought it was funny?

A Yes, I did.

Q And did you think it was funny when you were outside the various Churches of Scientology, including what you call the mecca of Scientology, holding signs and shouting obscenities about the leader? You thought that was funny, too?

A I — I think you would have to show me or present evidence that I was holding a sign, shouting obscenities.

Q Oh, we will, Mr. Prince.

A Okay. I would like to see that.

Q Did you think that was funny?

A I would like to see the evidence, please, sir.

Q Would you consider, sir — I mean, I think you said that Mr. Minton was the — something basically the most harassed person you’d ever seen, something to that order?

A Something along that order, correct.

Q Would you consider what you and Mr. Minton and Ms. Greenway and Mr. Alexander and Mr. Oliver and the other folks at the LMT — would you consider what you were doing harassing Scientology?

A Well, what were we doing that was supposed to be harassing?

Q I mean —

THE COURT: His question to you is whatever it


was you were doing, would that be, in your mind, harassing Scientology?

THE WITNESS: Well, I guess to clarify it, if it meant picketing, does that mean harassing Scientology? It has a broader meaning to me. It means I’m exercising my First Amendment rights as a citizen to protest.

Mmm, if you want to call that harassing Scientology, I call it exercising my freedom.


Q I’m asking you, because remember you talked about the harassment time line of Mr. Minton?

A Yes.

Q Do you remember talking about that?

A Yes.

Q And my question to you, if — if we put all of your pickets and all Mr. Minton’s pickets and all your postings and all Mr. Minton’s postings and all of the postings of these folks that have been in and out of the LMT and all the pickets of them on a time line, do you think that time line might be somewhat larger than this Minton harassment time line?

A I think it would be minuscule and it would pale by comparison.

Q By the way, are you part of an anti-Scientology



A I have never been part of an anti-Scientology movement.

Q Are you an anti-Scientologist?

A No, I am not.

Q What do you consider yourself?

A I consider myself in the instant case where I’m sitting right here today an expert witness concerning Scientology.

Prior to that, I worked in an establishment whereby I helped people who had been victimized by Scientology.

Q And would you consider Mr. Minton to be an anti-Scientologist during those four years that you were part of the A team, I think you said?

A I consider Mr. Minton to be an activist.

Q An activist?

A Yes.

Q What is that?

A You tell me what it is. Do you need to know what the word means? I mean, he was an —

Q What do you mean —

A — activist concerning —

Q What do you mean when you say he was an activist?

A He was an activist ensuring the rights, basic


human rights, that are accorded to us through our constitution.

I think Mr. Minton got started on his relationship with Scientology when he found out a Scientologist was trying to remove the name “Scientology” from a newsgroup — or at least this is the way he explained it to me. And how
lawyers and raids and things would come to even discuss Scientology, which is how I knew it from being in Scientology.

I knew if you ever spoke about Scientology outside of Scientology, you would get clobbered. So to actually see people doing it openly on the Internet was —

THE COURT: That is well past the answer. You don’t have to — we have to try to get through this.


THE COURT: He simply asked you to define what an activist was. And I think you have done that.

THE WITNESS: All right.


Q Now, when did you begin — when did you begin your work against Scientology? What date or time?

A Mmm, I began to give testimony concerning Scientology, to the best of my recollection, in the FACTNet case.

Q Specifically, up until I — I think you said you


considered yourself a Scientologist until, I think you said, 1997. Correct? Isn’t that what you said in your testimony?

A I think maybe ’96, I said.

Q All right. So you considered yourself a Scientologist after you left the Church of Scientology in 1992, after you say that you were — you said all those horrible things happened to you in the five-year period, you still considered yourself a Scientologist in ’93, ’94, ’95 and ’96. Correct?

A I think I should clarify that for you, if that is okay. I think that I still had Scientology values. I think that I still respected some of the tenets of Scientology, and I freely associated with Scientologists.

Q Well, you were working for a public member of Scientology for several years, right?

A Several years is incorrect.

Q How many years?

A Maybe one.

Q This is the job that the Church had helped you get after you left the Church where you were making $60,000 or $70,000 a year. Was that your testimony?

A I think you are mis-characterizing what happened. No, that is not my testimony. The Church didn’t help me do anything. It never has.

Q Well, just tell us one of those Scientology values


that you — that you continue to accept and feel close to after you left the Church of Scientology.

A That man — man is a spiritual entity. That — Mmm — man is capable of seemingly — seemingly more capable than is realized and those potentials can be cultivated and used and expanded on.

Q Any other ones?

A You know, some of the organical principles about the importance of organization, the importance of schedules. You know, these kind of things.

Q When you were a Scientologist, you believed, did you not, that psychiatric problems were spiritual in nature. Correct? That is what you believed? And could be dealt with spiritually through the religion of Scientology. You believed that when you were a Scientologist, didn’t you?

A Yes, I did.

Q And that is what Scientologists believe, don’t they?

A I can’t speak for all Scientologists. I know that, you know, as you are trained in Scientology, you accept more and more of what you read, and it’s a progression, it is a degradation of belief system, I guess.

But I couldn’t say that everyone believes that.

Q Well, you could say that Scientologists — no Scientologist would want to be committed to a mental


institution. You can say that, can’t you, from your years as a Scientologist?

A Mr. Weinberg, I can say that about Scientologists and anyone else. There is no one that I know that is aching to be committed to an institution.

Q But I’m asking you from when you were a Scientologist —

A Uh-huh?

Q — the last thing that you would have — you would have rather shot yourself than be committed to a mental institution?

A Absolutely not. I mean, that is unreasonable. It is irrational.

Q Well, can you think of anything worse, as a Scientologist, than to be committed to a mental institution?

Can you just answer that question?

A Rehabilitation Project Force, maybe.

Q One of the fundamental principles of the Church is — is the Church’s abhorrence with psychiatry and mental health treatment. Correct?

A Well, you know, Mr. Weinberg —

Q Can you just answer that question?

A I used to believe that is the answer. I used to believe that. But I found, from Mr. Hubbard’s autopsy report that I had a copy of, that he himself was taking


psychiatric medication —

MR. WEINBERG: Objection. Move to strike.

A — in his life. So maybe —

THE COURT: Stop. There is an objection. You have to stop.

MR. WEINBERG: It is not responsive to the question. It was a very simple question. Yes or no.

MR. DANDAR: I would say this is outside of the scope of direct and the issues.

THE COURT: It is not outside the scope of direct and not outside the scope of the issues but, quite frankly, this is not helping me any.

MR. WEINBERG: All right.

THE COURT: It is an interesting banter between you and Mr. Prince and —

MR. WEINBERG: I’ll go on.

THE COURT: — this might be of interest to a jury, but it really isn’t of interest —

MR. WEINBERG: All right.

THE COURT: — to me.


Q Since you have met Bob Minton, all of the money that you have received since June, other than this apparently $4,000 that you just got from Mr. Dandar, that


you have received since June, July, of 1998, up until April of 2002, came directly or indirectly from Mr. Minton, didn’t it?

A That is incorrect.

Q And all of the money — all of the money that you have received in that period of time you received as a result of your work about or against or involving Scientology?

A That is incorrect.

Q Correct?

A That is incorrect.

Q What is incorrect about that statement?

A I think that — Mmm — that all of the money that I have had during those periods of time derived from those activities, that is — specifically is incorrect about it.

Q What, 99 percent of it? 95 percent of it?

A You know, I have turned over my financial records to you. I think they speak for themselves.

Q All right. Let me play you — because you asked me to — let me play you a video — some videos and maybe this will refresh your recollection. I’ll ask you some questions about it.

A All right.

MR. WEINBERG: Get the first one.

MR. DANDAR: We’re going to object. If he


plays the video that they would like to play from the Boston picket, I demand that they play the whole video so that you, Judge, can see what Mr. Prince was responding to in that very vile video that you may have already seen.

You only saw their version of it. There is like two, three, four minutes of extremely vile language coming from ministers of the Church of Scientology to bull bait Mr. Prince into responding the way he did on video. So if they are
going to do that, they need to play the whole thing.

MR. WEINBERG: That is not the one I’m playing, first of all —

THE COURT: All right.

MR. WEINBERG: — to make it easy. Secondly, if he wants to do something later, he can.

THE COURT: There is a rule of completeness which we’ll get into when we get to trial. At a trial, if somebody will try to pick and choose, I’m probably going to insist on the rule of completeness in an appropriate case.

But in this hearing, if they play something and you think I need to see it all, make a little note, tell them to keep it there and play the whole thing on redirect.


MR. DANDAR: All right.

THE COURT: Or ask them if they’ll play it all.

If they say no, then you play it.

MR. DANDAR: All right.

MR. WEINBERG: Now, this is a video in front of the Ft. Harrison on November 30, 1998.


(WHEREUPON, the video was played.)

“You want to see the other side of the sign, too? Just want to make sure you get all of the information, all of the data.

“Tell David I’m coming with a dick so big, I’m gonna knock his goddamn spine out cuz I’m black. I got a big dick. I’m black. I got a big dick.

“Hey. Hey. Didn’t that guy have curly hair? (Inaudible.)

“No. No. Jesse. Yo momma. I been fucking your momma a long time (inaudible). That’s why you got that curly hair.”

(End of playing of the video tape.)



Q Do you recognize yourself, Mr.~Prince?

A Yes, I do.

Q You recognize Mr. Minton?


A Yes, I do.

Q And you thought that was funny? Your statement about Mr. Miscavige?

A Yes, I did.

Q You don’t consider that a threat?

A No, I don’t.

Q You think it is appropriate for an expert, or anybody, for that matter, but particularly an expert on — supposedly on religion to be in front of the Ft. Harrison to be making obscene statements about David Miscavige like that to other — to Scientologists?

A You know, I think there was an indiscretion that happened there, certainly.

Q And you consider it harassment for you and Mr. Prince — and Mr. Minton and others to be holding signs like the one you were holding, “Lisa, blood on her hands,”and the one Mr. Minton was holding about the Third Reich, do you consider that harassment to be walking in front of the mecca of Scientology? Do you consider that to be harassment?

A I consider it to be exercising my constitutional right —

Q Okay.

A — as a citizen of America.

MR. WEINBERG: Want to play the next one,


please? Actually, let me — go ahead.

(WHEREUPON, the video was played. No audio available.)

MR. WEINBERG: This is on the same day in front of the Criminal Court Complex.


Q Now, do you remember this being the day of the arraignment in the criminal case and do you remember being in front of the complex with Stacy Brooks, Bob Minton, Ken Dandar, Dr. Garko and yourself? Do you remember that photo?

A I remember that photo.

Q And do you recognize that as the criminal complex in Clearwater?

A The one on 49th Street?

Q Yes.

A Yes, I do.

Q And who took that photo?

A You know, I’m not sure.

Q And do you think that is funny? “Scientology, Hubbard Third Reich,” do you think that is funny?

A You know, I think those people in that picture are exercising their constitutional rights.

Q Do you think it is appropriate for the trial team of Mr. Dandar, Dr. Garko and you and Ms. Brooks, along with


Mr. Minton, to be standing in front of a public building holding signs like that?

MR. DANDAR: Objection.


Q Do you think that is appropriate?

MR. DANDAR: Objection. Mr. Minton is not part of any trial team.

THE COURT: He said “and Mr. Minton.” So I’m assuming he was excluding him.

MR. WEINBERG: That is what I did.


Q Do you consider that to be appropriate behavior?

A I consider that unless I’m committing a crime, I’m exercising my constitutional rights as an American citizen.

Q Do you believe that that constitutes harassment of the Church of Scientology?

A No, I don’t. I think if I was doing anything illegal, Scientology would have had me arrested on the spot.

Q Okay.

THE COURT: Harassment is not illegal. I guess what he’s trying to ask you is, in addition to exercising your First Amendment rights, did you consider that that might be considered harassment?

THE WITNESS: You know, and I — my answer again is no. My answer is I’m exercising my


constitutional rights as an American citizen.


Q You wouldn’t consider that picket —

MR. WEINBERG: Can you put that photo back up?


Q Somebody asked you — I think Mr. Dandar asked you whether or not he was ever on a picket.

THE COURT: Now, Counselor, in all fairness, that is a picture, that is not a picket. What we saw before —

MR. WEINBERG: I understand. I was asking to ask him. This is a picture.


Q My question is what was going on with these signs in front of the Clearwater courthouse? What were you-all doing with these signs?

A I think we had been picketing earlier.

THE COURT: Was Mr. Dandar with you when you were picketing?

THE WITNESS: Absolutely not. Neither was Mr. Garko.


Q And whose idea was it to pose for this picture?

A I don’t know. I don’t recall. I don’t remember.

Q I mean, no one forced you-all to do this.



A Correct.

MR. WEINBERG: Go to the next one, please.

(WHEREUPON, the video was played.)

“You work for a criminal organization. And they’re going to be found out. You take that and put it on the camera and run it to Miscavige, your leader, your guru. He’s going down.”

(End of playing of video tape.)



Q Now, that was right outside the Clearwater Bank building where all the people go in to eat. Correct?

A Yes. It was.

Q And right down the street, as you look down the street, is where the LMT offices were?

A That is correct.

Q All right. And do you consider that to be a threat to Mr. Miscavige where you say he’s going down?

A No, I do not. And I think I have to — you know, because this is just a little snippet you are showing here, I think I should give the situation that was occurring.

On that very street that you saw me in front of where the Lisa McPherson Trust is around the corner, on that


particular day I had gone to a shop on Cleveland to buy a pack of cigarettes and go back to the office.

From the moment I walked out of my office, all of the way up to the door of the shop I went to and all of the way back, a Scientology OSA person had a camera on me like this (indicating).

I was annoyed. If that is a crime, find me guilty.

Q Now, was that your purpose when you say, “You’re going down,” was your purpose to get rid of Mr. Miscavige from being the chairman of the board or the ecclesiastical leader of Scientology?

A My purpose was to express my annoyance.

Q And “guru,” were you just being funny?

A Again, my purpose was to express my annoyance.

Q Now, was that your agenda? Strike that.

Was it Mr. Minton’s agenda — was part of his agenda to get rid of David Miscavige?

A You had Mr. Minton up here —

Q I’m just asking you.

A — Mr. Weinberg, forever, you know.

Q I’m asking you.

A He never said that to me. He never said that to me.

THE COURT: There is an answer in the


courtroom. It is called “I don’t know.” If it is —

A He never — no, he never said that to me.


Q Now, you described you, Ms. Brooks and Mr. Minton as the A team, right?

A Correct.

Q And the A team got formed in the summer of 1998?

A I would say — Mmm — thereabouts.

Q Right. And the A team continued to be —

A Maybe — wait a minute. I misspoke about that because that A team business didn’t come up until after — after we’d worked together for a while and had done things.

And that concept came out — in the summer of ’98 is when I first met them, so I think it would be a misrepresentation to say that the A team was in the summer of ’98, at least to my best recollection as I sit here today.

Q So when was it?

A And I can’t be sure. It was sometime later.

Q When you said it became the A team after you had done things, what kind of things? Are you talking about like — do you mean like pickets and sending postings and things like that? Are those the things that you were doing?

A I think more like helping people directly.

Q Helping people?


A Yes.

Q How was Mr. Minton helping people, by standing and holding signs like that?

A Well, you know, I guess there is a myriad of answers for that. But what I meant to say, helping people, I meant helping people that had run into problems with Scientology and were not able to resolve them so that they can get on with their lives.

Q Now, where did the A team concept come from?

A You know, I think there used to be a television program.

Q Are you talking about the one with Mr. T?

A If you let me finish. You know, the reason why I can’t answer that question, because when those television series were going on, I was in the Sea Org and we weren’t allowed to watch TV. So I have a big missing section in my life with serial programs and things like that.

So again I’ll say there was some program that had the A team on it. And I think Mr. Minton brought it up and — but —

Q And —

A — but I have never seen a program called the A team or anything like that.

Q When you said the A team yesterday, what did you mean, A team? What was it that the A team was doing?


A The A team was myself, Bob and Stacy. And the A team were helping people that needed help to resolve issues with Scientology.

You know, just to — to show how far at the other end of the spectrums were, Mr. Minton actually thought he was helping Scientology by helping these people resolve issues with Scientology.

Q Do you remember speaking to the media about bringing Mr. Miscavige down?

A No. I do not.

MR. WEINBERG: Play that next one, please.

(WHEREUPON, the video was played.)

“It takes standing up and recognizing it for what it is, a dead, arcane idea. We’re dealing with people who are ignorant and we’re going to bring them down.”


Q Do you remember that?

A I object to that very — I can’t object, but that was an obvious edit where you sliced two things together.

And I think you are mis-characterizing a speech that I gave for a vigil for Lisa McPherson where the press was there. I was not speaking for the press. I was speaking to former Scientologists.


Q Were you talking about bringing down Scientology?

Is that what you were talking about?

MR. DANDAR: We object and ask the whole thing be played.

THE COURT: I think that is fair.

MR. WEINBERG: It was a newscast, we didn’t — we can play the whole newscast. It takes a minute.

THE COURT: I don’t want the whole newscast.

Just whatever Mr. Prince said.

MR. WEINBERG: Well, that is what Mr. Prince said. That is all he said is what we just played.

THE COURT: Well, it did look like there was a definite splice.

MR. WEINBERG: There was. One of these newscasts where the reporter said something and Stacy Brooks said something and he said the first thing on there, Mr. Prince, then somebody else said something, then he said the last thing.

We took the two things Mr. Prince said and put it together. But we can play the whole section.

THE COURT: It makes it look like he said all that together, and it may not have been.

I think if what it is you are trying to do is every time he said we’re going to bring him down, what is it you mean when you say that?


THE WITNESS: Expose — expose what is actually going on.


THE WITNESS: You know, expose the fact that private investigators are being used to terrorize citizens because they disagree with Scientology.

Expose the fact that someone gave $100,000, and it is Scientology’s policy, if you don’t use a service that you paid for, they will refund it to you.

THE COURT: Normally, when you want to say we’re going to expose somebody, you don’t say expose somebody, you say bring them down, that kind of means put them out of business. That is what I mean by that. What did you mean by it?

THE WITNESS: I mean ending the criminal activity. Ending the assault of citizens who have no way to protect themselves once they get on the bad side of Scientology.

THE COURT: When you say “We are going to bring you down,” this is your testimony, you did not mean put the Church of Scientology out of business, do away with the Church?

THE WITNESS: Right, in the illegal activities. I never had a — as I said, corrupt activities wasn’t even anything in my mind during the majority


of my stay in Scientology. These are things that I learned about after I got to Gilman, Hot Springs, and started working directly for Mr. Hubbard and Mr. Miscavige. I was an ignorant, blind person to it prior to that time.


Q When you said in that newscast that I just played, quote, “It takes standing up and recognizing it for what it is, a dead, arcane idea,” that was how you — that — you were expressing your opinion about Scientology, that is what
you meant by that, isn’t it?

A No. You have taken this out of context because I don’t know what “It is.” You showed me a little snippet. I don’t know what you’re talking about.

THE COURT: I don’t, either.

MR. WEINBERG: I have the transcript. We’ll play the whole tape because we are obviously not going to get done today.


Q But — it was a response to a question, “Today they spoke out against the Church of Scientology,” and then they play what you said about it. But we’ll play the whole thing. It takes about a minute. All right.

You remember going on several trips to Europe with Mr. Minton, correct?


A I think I went on a couple of trips with Mr. Minton.

Q All right. He paid for the trips?

A Correct.

Q Who else went with you?

A You know, as a matter of fact, I only traveled to Europe with Mr. Minton one time.

Q And the purpose of that trip was?

A To visit with his business partner, Jeff Schmidt, to have a face-to-face with him to find out specifically what Scientology-hired private investigator David Lee was doing to try to get him to a — do a similar thing as Bob and Stacy, basically turn against Bob and provide criminal information so Scientology could use it to attack Bob Minton.

Q Now, do you remember being in Germany with Mr. Minton and Ms. Brooks in or about June of 2000?

A I think I was in Leipzig, Germany.

Q And Mr. Minton paid for that trip?

A I think that trip was paid by the Lisa McPherson Trust.

Q So in June of 2000 you were on the payroll of the Lisa McPherson Trust at that point?

A Correct.

Q You had just gone on the payroll?


A You know, I can’t remember.

Q And do you remember — you remember being in the DB lounge?

THE COURT: What is that?

A Yes.

THE COURT: What is a DB lounge?

MR. WEINBERG: It is a bar of some sort.


Q Correct?

A We were at a train station in Leipzig, and there was a bar called the DB Bar, which we thought was amusing because DB means something very specific in Scientology, it means degraded being.

Q And you were there with Ms. Caberta, we heard about, the German government official that works against Scientology, right?

A Correct.

MR. WEINBERG: I’ll play this clip here. This is something turned over to us by the Lisa McPherson Trust.

(WHEREUPON, the video was played.)

“Okay, so — so, Stacy, you start. DM, this drink’s for you.

“DM, this is a special toast to you coming


straight from the DB Lounge in Leipzig, Germany.

“I’m not going to call this guy DM anymore. Remember what my new name for David Miscavige is, the former ecclesiastical leader of the Church of Scientology.

“I know this is going on camera.

“I know, but what did I say — (inaudible).

“Yes — yes, this is — this is a toast to David Miscavige, also known as Pope David I, from the DB lounge in Leipzig, Germany. Up, up, up and away.

“Now, Ursula.

“Hi, Mr. Miscavige. We did a great work here in Germany. And we will finish Scientology soon.

“This is to you, Miscavige. We are so thankful that you give us reason to live. Salute.

“Pope David I. Cheers.


“Just some DBs hanging out here.

“David I.


“This is to David Miscavige in the DB Lounge in Leipzig, Germany at the train station.

“Pope David I.

“Cheers, Miscavige.


“Rear Admiral.


“Listen, listen, just —

“No, just stop here now. Now listen.

“We all know in Grady’s deposition, when Grady was deposing David Miscavige, that he went ballistic over the thought of Graham —

“Now —

“– of Graham Berry spending time –”

(End of playing of the video tape.)


Q Does that bring back memories, Mr. Prince?

A Yes.

Q And you think that is funny?

A Well, what I think you have is a home video of our trip in Europe that was never made public — Mmm — to anyone. And we were just having fun. Yes, I do think it was funny. We were just having fun at the train station.

Q Does that man, Mr. Minton, look like the most harassed person on the face of the earth?

A He does, to me.

Q And when Ms. Caberta, the German official who has — who flew over here and who is working against Scientology, when she said, “We’re going to finish


Scientology,” she was talking about getting rid of it, wasn’t she?

A No. I think she was specifically talking about Scientology isn’t viewed as a religion in Germany.

Scientology is viewed as a political group. The reason Scientology is viewed as a political group —

THE COURT: I don’t need to know that.


THE COURT: I don’t need to know, care, what is going on in Germany.



Q When you talk about the reason for living, when you-all were talking about, you know, David Miscavige gives us a reason to — a reason for living — reason to live for, talking about so that you can malign him, is that what
you-all are talking about?

A No. Not at all.

Q And do you remember — it was cut off at the end.

Do you remember that — that at that point, Mr. — Mr. Minton said something very obscene about Mr. Miscavige?

A I do not remember that. But, again, I’ll state that this was a video that we made on our trip that was a private video, never made public, never put on the Internet, and it is being exploited here today.


Q Well, it sort of gives you a different impression about what you-all were about, doesn’t it?

A Who is you-all?

Q Excuse me?

A Who are you talking about, you-all? What you-all were about. What are you talking about?

Q You, Ms. Brooks, Mr. Minton?

A The —

Q The A team?

A I didn’t get that impression.

Q Now, who took that video, this home video that ended up in the LMT on this trip that was financed by the LMT?

A I think Mr. Bunker.

Q So he was there, too, obviously? Was anybody else on this trip? You have the A team, you have Mr. Bunker. Is there anybody else on it?

A Not that I specifically recall.

Q And you-all thought the DB was kind of funny because that is a Scientology term?

A Correct.

Q Now, after looking at your obscenities in front of the Ft. Harrison about Mr. Miscavige, watching this toast, you still think that he would be your friend? Wasn’t that your testimony this morning?


A You know, I’m talking to a camera there. The answer to your question is yes, I think that if he and I sat down and actually had a discussion, we would certainly find friendship, would be able to communicate.

I mean, isn’t Scientology all about helping people learn —

THE COURT: That didn’t really answer the question. You have that opinion and that is fine. Then that is the answer to the question.


Q You talk about counseling. The principal purpose of the LMT, when it moved into Clearwater, was for the A team and the people that were working for the A team to picket and harass Scientology, wasn’t it?

A That is incorrect beyond belief.

Q Okay. Now —

A I would like to explain that, if I could. I would like to explain why the LMT came here, since you brought it up, and if you would allow me to just fully answer the question.

Q So you were involved in the —

THE COURT: I’m going to let him answer the question. What was the purpose of the LMT that — what do you believe the purpose of the LMT was?

THE WITNESS: The purpose of the LMT —

THE COURT: Fifty words or less.


THE WITNESS: Okay, fifty words or less, and I won’t talk too fast for the court reporter.

THE COURT: That is 25.

THE WITNESS: When Lisa McPherson left that hotel, she had no place to go. She had a minor accident, stripped off her clothes, told people that she needed help. She ended up back in the Ft. Harrison. Seventeen days later, she was dead.

The reason that Lisa McPherson came to Clearwater and the reason it was there, in case there was another instance where someone needed a safe place to go where they could come and get help.

That is why we were there. And that is the only reason we were there.

And those were the dying wishes of Fannie McPherson, Lisa McPherson’s mother, when she was on her deathbed.


Q So all of this picketing which happened on a regular basis, correct —

A Incorrect.

Q Well, can you, like, give us an estimate of the number of times you participated in a picket against the Church of Scientology?

A Yes, I can. Let me think. Because I certainly


remember the first one well enough. I think I have probably been involved in maybe six or seven pickets.

Q So in the —

THE COURT: Over what periods of time, Mr. Prince?

THE WITNESS: From 1998 to the present.

THE COURT: All right.


Q So in a four-year picket —

THE COURT: Four-year period. Not picket.


Q Right, I have picket on the brain. In the four-year period, you say you only picketed six times?

A I roughly estimated six or seven times that I picketed, yes.

Q And do you have a sense of how many times Ms. Brooks and Mr. Minton picketed in that four-year period?

A I do not.

Q A lot more than six?

A I believe so.

THE COURT: He said he didn’t know.

MR. WEINBERG: I believe he just said “I believe so.”


Q Now, in Clearwater there were other people in the


LMT that participated in pickets, including Peter Alexander, correct?

A Yes.

Q Patricia Greenway?

A Yes.

Q Frank Oliver?

A I — I can’t say that I have ever seen Frank Oliver carrying a sign, picketing.

Q So you are not aware he picketed?

A Correct.

Q Of course Minton — of course, the A team, right?

A You know, I think Stacy herself maybe picketed maybe five or six times, as well. But then she didn’t do it anymore because it was not anything she agreed with, nor did she feel it was effective in handling the problem that we
were dealing with.

Q Well, let me ask you this. Do you remember that on September 2, 1998 you and Mr. Minton participated in a picket in Boston at the Boston Airport?

A At the Boston Airport? We — I think you have that in complete reverse. Scientologists picketed us at the airport.

Q Do you have signs, “Scientology, The Third Reich”?

A Do I have signs?

Q Did you-all, you and/or Mr. Minton?


A Mmm, it’s a possibility. I don’t know.

Q In September of ’98 did you and Mr. Minton picket in front of the Church of Scientology in Boston?

A That is possible.

Q Well, that is when he was actually arrested for assault and battery. Right?

A Correct.

Q In October of 1998 did you picket with Mr. Minton in front of the Church of Scientology in Boston?

A It’s possible.

Q You remember several pickets in Boston in October of ’98 with one of Mr. — one with Mr. Minton and one with Ms. Brooks?

A I don’t remember that specifically, no.

THE COURT: Tell me why we have to spend so much times on these pickets.

MR. WEINBERG: Because, your Honor, it — it — it demonstrates — first of all, it puts the lie to what we’ve heard all of the way through —

THE COURT: But I know that this man has been involved in pickets.

MR. WEINBERG: It is way beyond that, your Honor. I mean, really —

THE COURT: Pardon?

MR. WEINBERG: It is way beyond that. You have


before you a harassment time line. And Mr. Dandar has spent literally 28 days suggesting that somehow Mr. Minton was harassed to the point where — where, for reasons that don’t make any sense to me, for that purpose he would come in and incriminate himself.

And the fact is — we’re not playing all of the pickets. But when you see these clips, most of which we got from the Lisa McPherson Trust in these videos that were just turned over, you will see what was really — what was  happening here in Clearwater.

THE COURT: I have no doubt that at the LMT Trust they had very little use, if any, for the Church of Scientology. And they picketed them fairly regularly. Quite frankly, if they had fallen on their face, they wouldn’t have cared; that they were out, in essence, to undo what they perceived to be the bad things that they perceived the Church of Scientology did. I don’t have any doubt about that.

I think the record is clear. So I don’t know why we keep going over those things.

There are things that are really critical to this hearing. And I don’t think those are it.

MR. WEINBERG: Well, I mean —


THE COURT: It might be important to the counterclaim, but not to this hearing.

MR. WEINBERG: Well, I mean, if you rely on, for example, what Peter Alexander said, he said he didn’t have anything — or essentially nothing to do with it. You’ll see essentially the opposite.

You have heard that somehow Mr. Minton was harassed. And you’re going to see what was really going on, that the Church was harassed beyond comprehension.

THE COURT: I have no doubt Mr. Minton harassed the Church, as well as the Church harassed Mr. Minton. It is just that simple.

MR. WEINBERG: But nothing is more — well, can I proceed with my cross-examination?

THE COURT: Yes. You may.

MR. WEINBERG: Thank you.


Q You went on the Internet, as well, didn’t you?

A I have been on the Internet. Yes, I have.

Q You made postings on the Internet?

A Yes, I have.

Q In that Leipzig toast you — instead of using the name “David Miscavige,” you actually said “Miss Cabbage,” didn’t you? That was a little joke, wasn’t it?


A Did I say that?

Q I’m asking you.

A I thought I said “Miscavige.”

MR. DANDAR: I think we need to hear the video, rather than someone’s transcript.

MR. WEINBERG: I’m going to show you a posting.

THE COURT: In a posting we have heard him called Rear Admiral. We know what that means. And we know they called him Miss Cabbage. And they don’t speak kindly of David Miscavige.

MR. WEINBERG: I understand that. And I’m going to show him, have him identify, his Internet postings.

A I will admit — I have said that before, Miss Cabbage. I just don’t know that — if that is what you are seeing there.

MR. WEINBERG: Could I stand up here with Mr. Prince?

THE COURT: You may.

MR. WEINBERG: I have no other copies.

THE WITNESS: I have no idea what this is.


Q This is your postings, isn’t it?

A Excuse me?

Q This is your postings?


A I don’t think so. I think it is a fictitious document created —

Q So you didn’t send a posting that said:

“Too bad, Little Miss Cabbage has a corncob up your ass, 724365. I know the feeling. That is why I have him reeling, spending money like a bitch kicked from a pimp. Roll on, ho, big daddy can see you. Jesse.”

A Yes, correct. But that is a fictitious document that was created for the purpose of — to malign me.

Q To malign you?

A Yes.

Q But you have used Miss Cabbage?

A Yes, I’ll admit it. Freely admit it.

MR. DANDAR: Objection. This does not have the normal E-Mail headers on it that you would find if it was an original document, instead of something that someone altered.

A I don’t even know who Robert is.

THE COURT: I don’t know. If he can’t authenticate that, I don’t know whether — I don’t know whether it is in or not. At the top it says

“Spread the word, bitch.”

Then it goes on to some other comments. And that is not the way an E-Mail normally —

MR. WEINBERG: It is not an E-Mail. It’s a



THE COURT: Well, the same thing. I don’t know. It would seem like this Jesse Prince, Jesse77@GTE.net would be Mr. Prince’s — that would be — is that what you go by?

THE WITNESS: I had that in 1998, I think, when I had a particular type of computer, I used to have that address. But as I sit here today, I don’t know what name — the name Robert.


Q Well, when you use the word “Miss Cabbage,” what do you mean?

MR. DANDAR: Objection. That is not his E-Mail.

THE COURT: No, he admitted that he has called David Miscavige Miss Cabbage.

A It’s an obvious derogatory use of Miscavige.


Q And derogatory in — I mean, in what context did you use it when you used it?

A I don’t remember. I just know that — you know —

I have said that before. I admit to it.

Q Now, let me show you — see if you recognize this posting. Or is this another fictitious one?

MR. WEINBERG: What will this be?



MR. DANDAR: What exhibit number is that?


THE COURT: The one before that was 2-what?


THE COURT: That did not come in because —

MR. WEINBERG: He said he couldn’t authenticate it.

THE COURT: So that is not in evidence. That is Number 218. This one you just gave us is 219?

MR. WEINBERG: Yes, your Honor.




Q Did you make that posting?

A Yes, I did.

Q And do you consider that to be a — a posting that would indicate a derogatory view toward Mr. Miscavige and the religion of Scientology?

A Mmm, I think that this posting is a result of the Scientology operations being run on me.

While I’m trying to testify in a court in front of a judge in Denver, Scientology hired a prostitute, had a deep undercover agent, Laura Terepin, working on me, helping me with the deposition, saying there are people other than


who they are. You know, this is an annoyance response to what had been happening to me. You see I clearly speak about private investigators following me.

In Denver, very strange things happened.

Q What do you mean, they hired a prostitute?

A A prostitute.

You know, this guy from Denver — there was a private investigative agency in Denver that was watching me. He brought a woman who said it was his sister, who was a whore. She got a room directly across the street from my — not across the street, across the hall from my room in the hotel that I was staying in.

And when I came out — and she was a beautiful woman, you know. “Oh, can you help me get my key,” on and on and start this conversation.

This guy says, “This is my sister. We’re just in town.”

Suitable guise. Mr. Sharp will explain it to you. And they started this whole routine of, “Come on. Party with us tonight. We’ve got drugs, we have this. We’ve got whatever.”

I’m supposed to testify. I literally had to get rid of them.

The other person, Laura Terepin was — her real name wasn’t Laura Terepin.

Jolie Steckart, specifically paid by Scientology


to infiltrate Mr. Dan Leipold’s office as I sat there writing my declaration for his case.

It was these kind of things that annoyed me, and I would write these things.

Q So when this hooker came to your room, you told her to leave?

A Yes.

Q Or did you —

A We were at the bar. And then she wanted to come to the room. I’m like, “No, I have to testify.”

Q But I think you testified previously that she actually — you let her come to your room and you did something with her. Right?

A No. I don’t think so. I don’t think so. I — I think that you are fabricating that.

Q Now, when you say in the first sentence: “It seems some people (Miscavige) just don’t have the guts to quit when it’s over,” what did you mean by that?

A What I meant specifically by that is that I came into the case — the FACTNet case — Scientology had brought an action against FACTNet for copyright — certain copyright violations.

And — Mmm — I — I remember vividly the whole issue of copyrights in Scientology. I have given a — a detailed affidavit about it.

But the fact of the matter is the copyrights — or


at least some of them — were completely bogus. And the filings of the copyrights were filed under false premises.

I did an affidavit against that concerning that — concerning that naming specifically the people that were involved. Another officer, staff member, Pat Brice, was involved, because after Mr. Miscavige dismantled the Guardian’s Office, there was always a section in Scientology, according to its own policy, to register trademarks and copyrights all of the time.

Q That is what you meant —

A Excuse me I’m still talking. And they let that lapse a period of time. So you had a large section of materials that they claim copyright protection for which, in fact, they did not have. And I was able to identify what that was.

Q So that is what you meant when you said, “When it’s over, they just don’t have the guts to know when it’s over”?

A Correct. They submit false documents to the Court. I point out to the Court that the documents are false and show them how, is specifically what I mean there.

Q The third paragraph, the last sentence, where you say: “Can’t you just –” talking about Miscavige now, “Can’t you just take it like a man? Soon you’ll be in a place where you’ll be taking it like a man regularly,” that


is sort of like the Miss Cabbage thing, you’re talking about him being in jail and sexually assaulted?

A I’m talking about him being incarcerated for being involved in criminal activity.

THE COURT: Was this a posting to David Miscavige, or somebody else?

THE WITNESS: No. It was that newsgroup, alt.religion.scientology.


Q Let me show you another one. You did hundreds of these things?

A I don’t think so.

Q You just felt compelled, as an expert, to go on this alt.religion.scientology and say obscene things about David Miscavige?

A At the time of these writings, I was not operating — I don’t think I was — I don’t know. I don’t remember. I don’t think I was an expert in this — I think I came in here in December of ’99 when —

THE COURT: I mean, there are people that learn things from this case. Mr. Prince, if you are going to ever testify in another case, you ought to learn not to post things on an Internet, especially not to be involved in vulgar demonstrations. They’ll always come back to haunt you in a court proceeding.


Just like I hope Mr. Dandar learned, whether you call it picket or vigil, if you are a lawyer, you ought not to be there.

There are certain things you need to have learned. I hope you learned that.

THE WITNESS: Your Honor, that is a true statement. I have learned that from Judge Moody. He taught me quite a bit about how I needed to act in relationship to this.

And you are right, I have had some indiscretions. All right, if we need to talk about that, we will.


Q I showed you what I marked as Defendant’s Exhibit 220. Do you see that, Mr. Prince?

A Yes, I do.

Q Do you remember writing that open letter to David Miscavige?

A Uh-huh.

THE COURT: That is a yes?

THE WITNESS: Yes. I’m sorry. Yes.


Q And — and this is when you are definitely involved as an expert, you already worked on Wollersheim, you already reviewed the PC folders for Mr. Dandar.



A Quite possibly I’ll agree with you there.

Q And so you say in the first paragraph: “How desperate you must feel. If you sit quietly and listen carefully, you will hear it.”

MR. DANDAR: Objection. I need to have the question asked of the witness to identify this document and make sure it is his.

MR. WEINBERG: He just did.

A This is my document. Yes.

MR. DANDAR: It doesn’t have headers on it. That is all.

THE COURT: Well, he has identified it, so —

MR. DANDAR: All right.

A Yes.

THE COURT: You are introducing this?

MR. WEINBERG: Yes, I am.

THE COURT: It will be received.


THE COURT: Honestly, I’ll tell you the same thing, I don’t need you to read it to me. If there is some part you want to point to —

MR. WEINBERG: Really, the first paragraph and last paragraph.



A Yes, I wrote — I wrote the first paragraph, all of the paragraphs in the middle, all of the way to the end.

And I think if you read this whole thing, you’ll see that I’m upset, I’m very peeved over the fact on Page 2, second paragraph, that —


Q I didn’t ask about Page 2. I asked about the first paragraph. That is all I asked you.

A Oh, okay.

Q And the last paragraph. You wrote that, where you quote the Bible?

A Correct.

Q And the reason for quoting this passage from Revelations about “Avenge our blood on those who dwell upon the earth” was what?

A Well, you know, if you know this passage, these are the saints that died for righteousness but evil and corruption carries on. And when the fifth seal is opened, biblically speaking, the saints’ blood will be avenged.

This is specifically what I’m talking about. And how this relates to Miscavige and Scientology is the corruption — the agonizing activity that I had to go through to deal with my children, my father, old girlfriends, Scientology did their noisy investigation on me.


I wish I would have had this document when Mr. Dandar was asking me do you remember noisy investigations. They ran around to my entire family. I had to go to Chicago, I had to go to Minneapolis, to Memphis, Tennessee, to deal with friends and associates and family as a result of Scientology doing their, quote/unquote, noisy investigation, spreading lies and false information about me.

THE COURT: Are you done with Number 220? We need to take our break.

MR. WEINBERG: We offer 220. And I do also offer 219, the one before that.

THE COURT: That will be received, too. And we’ll go ahead and take our afternoon break. It is 25 after. A 20-minute break.

MR. WEINBERG: Thank you.

(WHEREUPON, a recess was taken from 3:25 to 3:50.)

THE COURT: You may continue.

MR. WEINBERG: Thank you. At the break I had one more of these things I was going to mark. I’ll go on. That is 221.


Q Now, Mr. Prince, do you recognize Defense Exhibit 221 as a posting which you made on or about August 6 of



A If you’ll give me just one minute —

Q Sure.
A — to review this document, please, I’ll indicate it for you.

Okay, yes. I do remember this document.

MR. WEINBERG: All right. I’ll offer this, your Honor. I have a couple questions to ask on it.

THE COURT: All right. It will be received.


Q Now, this is one of the first postings you made after you had joined the ranks of working against Scientology, correct?

A I would hardly characterize it as that. But this is one of the first postings that I made on the Internet concerning Scientology. Yes.

Q All right. Now, in that first paragraph you say, second sentence: “You know, I just can’t refer to Scientology as a church in any way. It would be an insult to all religions.” Do you see that?

A Yes.

Q And that is how you feel today, isn’t it?

A You know, it is not. And I can explain to you why.

Q You don’t need to.


A Okay. Then I have answered the question.

Q So you think it’s a church?

A Correct.

Q So you just sent this out of some hatred?

MR. DANDAR: Objection. He didn’t want him to explain it. Now he’s asking him. So let the man explain his answer.

THE COURT: Well, I think that was a different question. And I think that Mr. Prince is capable of answering that question, then I think he can explain it.


Q You sent this out of some hatred for Scientology?

A Mmm, no, sir.

Q Now, if you go to the fourth paragraph where it says, I quote:

“The bottom line is that the hierarchy of Scientology is composed of people who are very, very, very mentally ill, sick people of the worst sort. Why? Because they are sick and don’t know it. In all honesty, I hope to reach them so they can wake up and start getting well like I have and others have.”

You wrote that, right?

A Correct.

Q Wasn’t that what you have, in essence, been doing for the last four years, trying to get rid of the hierarchy


of Scientology, including David Miscavige?

A You know, that is not exactly what I say here, to get rid of those people. I said I hope that I could reach them so that they can wake up and start getting well themselves.

Q Now, you — the truth is, isn’t it, Mr. Prince, that you and Mr. Minton and Ms. Brooks, the A team, had a ball with regard to all this picketing you-all participate in over the last four years?

A I’m sorry, I hardly can agree to that, Mr. Weinberg. I wouldn’t call it a ball.

Q You had a lot of fun doing it, wouldn’t you say?

A I wouldn’t say that either, Mr. Weinberg.

Q You remember the first time that you went to New Hampshire and — and — and encountered picketing in New Hampshire?

A Yes, when Scientologists came in and picketed Mr. Minton’s home.

Q Right. And that was on Mr. Minton’s — that was on Ms. Brooks’ harassment time line. Right?

A It very well could have been. Sure.

Q And do you remember that you were there with Mr. Minton and that you-all were laughing and giggling and making fun of the Scientologists, the few that came by in the cars? You called it a drive-by —


A The picketers, yes, it was amusing because the Scientologists came by and stood in the road with their signs, and it is quite a narrow road up in New Hampshire, there aren’t sidewalks where Mr. Minton lives. So a state trooper came and asked them not to stand in the road because it was dangerous. It was actually kind of a blind curve by Mr. Minton’s house that makes it dangerous, being there are no sidewalks.

And what was particularly amusing about what the Scientologists resorted to at that point is that they — Mmm — went around and pulled their cars way back, then took their picket signs out the window, because they were too big to stick through the window, and they held them outside of the car and drove back and forth. I thought that was pretty pathetic.

Q And you and Mr. Minton had anti-Scientology signs, correct?

A Mr. Minton had signs.

Q You did, too?

A No. I never owned a picket sign myself.

Q You never held a picket sign?

A I never owned —

Q I didn’t ask you whether you owned it.

A I’m sorry.

Q You had a sign. There were signs there that you


and Mr. Minton had, correct? Anti-Scientology signs?

A That may or may not be correct. I don’t specifically recall.

Q All right. Do you remember doing a posting with regard to that incident that appears on the harassment time line?

A I do. But — but, Mr. Weinberg, I have to say this because, you know, you selectively are taking paragraphs out of these things and you are painting a picture here.

But really what this is about is — this last thing you handed me is about trying to help these people. I’m telling the story about something that happened to Marty Rathbun, something that might have had a psychological
impact on him that he would need help resolving.

Q But that wasn’t my question. All my question was, you did another posting about this incident which appears on Mr. Minton’s harassment time line in front of his house in 1998. Correct?

A You know, I need that time line right here. I mean, I’m saying it’s possible. But if you want to pull it out, you want to show me what you’re talking about, I think I can answer the question better.

Thank you.

MR. WEINBERG: Marked as 222.



Q You can identify this as your posting, can you not, Mr. Prince?

A Yes.

Q And in the second paragraph you say, “Bob and Jesse quickly helped with the pilot and started bullbaiting the protesters.”

When you say bullbaiting, that would suggest that you were, what, holding signs or doing something back?

A No. Bullbaiting is a term that is used in Scientology specifically to designate some of their training routines. The training routines are called TRs; TRs for short.

Part of the training routine is to be able to sit across from a person without flinching and without moving when the person makes gestures or tries to do something shocking; in other words, this is a routine to train you to keep your countenance during an adverse commission, I guess.

Q In here you said, “We had great fun”?

A Correct.

Q Now, do you know why this appeared on the harassment time line if it was so much fun?

A Well, you haven’t shown me that — and I have asked you, too, to show me on the time line. So I can’t answer these questions — you know, you are referring to

something that I don’t have in front of me. I can’t see it.

Q I thought from the testimony yesterday that you had reviewed the time line pretty closely?

THE COURT: Well, believe me, he has. It’s a very long thing. I think it’s a fair request. If you want him to specifically note whether it is on the time line or not, show him the time line.


THE COURT: My recollection is that document was extremely long.

MR. DANDAR: It is. And, Judge, I object to 222 because there has definitely been editing done. Right after “barbecue” and before the word “soup,” something is taken out.

MR. WEINBERG: No, it is not. You knew exactly what it is.

THE WITNESS: Where is that at?

MR. DANDAR: Where it said, “You invited Minton for barbecue,” after “barbecue” there is a blank, then there is “soup.”

THE COURT: 222, you are talking about?

MR. DANDAR: Yes. Right here.

THE WITNESS: Second paragraph? Oh, yes, you are right. You are right. It has been edited.

Something has been deleted from there.



Q What was there? Because we didn’t edit anything.

A Yes, maybe you didn’t, but your client did. And I know specifically why.

What it said, “We were having BT and cluster soup.” BT is part of the secret cosmology of the upper levels of Scientology. So this has been, in fact, edited.

MR. DANDAR: I object to it. It is an altered document.

MR. WEINBERG: Are you testifying, first of all?

MR. DANDAR: I’m objecting to it based on Mr. Prince’s testimony. It’s an altered document by the defendant.

MR. WEINBERG: He identified it before, your Honor.

THE COURT: Well, Mr. Dandar just indicated that it had been altered. And so if it now — I’ll ask you, Mr. Prince, is that the original document, or has it been altered?

THE WITNESS: Yes, your Honor, this has been altered. This is not the original.

THE COURT: If you have one that has not been altered, then it will be admissible.

MR. WEINBERG: First of all, we didn’t alter



THE COURT: I didn’t say you did. But if — I mean, I’m happy to write in the original what was there if Mr. Prince remembers it and everybody agrees.


Q Do you remember what was there?

A I remember exactly what was there. It says we were having barbecue BTs and cluster soup. “BTs” and “clusters” are words Scientologists aren’t allowed to use outside of Scientology.

Q So it’s a derogatory thing?

A No, there is nothing derogatory about BTs and clusters. This is a reality – something they believe in.

Q Well, I —

A But they are sensitive to it, so they altered the document.

MR. DANDAR: And I would object. If there is any more altered documents, that they not attempt to use them, or tell you in advance.

THE COURT: You just heard counsel say he did not know or believe it had been altered. So be careful, though, when you look at your documents.

That does look like something is missing from there. But I do know on my own E-Mails sometimes they


all get askew and don’t seem to line up right. I was on the Florida Supreme Court website looking up stuff on the death penalty cases. And all of a sudden they go and they just stop. So you can’t tell by looking.

MR. DANDAR: But this one —

THE COURT: That one does appear to be where there is something clearly missing. So —

MR. WEINBERG: It obviously was not what I was focusing on, BT and cluster soup. But with the record indicating what Mr. Prince was saying was there, I offer the exhibit.

THE COURT: Take the original back and write it in.


THE COURT: And ask Mr. Prince if that is what he recalls it said and, if so, then we can admit it with that —

MR. WEINBERG: I’ll let him write it because I don’t know — I assume how to spell it but I’m not sure how to spell it.

THE COURT: BT , is that like two initials.



Q Here. Do it like this.


THE COURT: Everybody make notations on your copies. Cluster is C-L-U-S-T-E-R.

THE WITNESS: Yes, your Honor.

MR. WEINBERG: Okay. And the original has “BT” and that he wrote in.

THE COURT: Okay. That will be admitted.


Q Now, you remember that at this —

A Excuse me.

Q I wanted to show you the harassment time line. Let me show you what has been previously marked as the harassment time line, the “Time Line of Scientology Harassment of Robert Minton and Colleagues.”

I show you the entry for September 7, 1998. It says: “Scientologists picketed Mr. Minton’s home in New Hampshire again but it was done in a car with picket signs held out of the car window.”

A Correct.

Q So that was the incident, right?

A Yes.

Q Now, I want to play this. This is that — you remember you-all videoed this?

A I don’t remember videoing the incident, but let’s see what you have got.

Here is your pen, by the way —


(WHEREUPON, the video was played.)

“Don’t block her sign now, Jesse. I’ve gotta get a picture of that good sign.

“Okay. Let me put mine up.

“Okay, yeah.

“Hey, Maureen, just out here having a little chat.

So did you see that last — “(Inaudible.) I don’t know. All I can say is when I was in your position, there was a lot of —

“That you’re a staunch Scientologist. And it’s dangerous for you to believe otherwise because you’d be wrong.”



Q Those are Mr. Minton’s signs?

A Correct.

“Drive-by pickets. That’s cool.”

MR. DANDAR: Could we clarify the people in the car are Scientologists?


Q They are, aren’t they, Mr. Prince?

A They are. OSA personnel.


“Damn dumb asses. I got ’em. See, what they need, what they need is like a — what they need — what they need is a chain — I mean a long line of cars.

“They just don’t seem to be able to get more than two —


“– for these little New Hampshire things.

“Hey, it’s an hour from Boston, man.

“Ain’t it pathetic. One person holding one sign out the window. And then when they go by this way, the driver can’t do it so the fucking sign’s over there. Oh, my God. How pathetic.

“They must think this is having some kind of terrible psychological impact.

“Yes, it’s just entertaining as all hell.

“Here they come.



“Hey, you fucking idiot.

“They don’t have enough nerve to try to run over me.

“Me, either. I stood there, too. I just stood in the middle of the road and got ’em driving up.

“Look at this. This is a good one.


“Here they come again. That’s when they were coming earlier. That’s all I got of them so far, but the two of them are good.


(End of playing of the video tape.)

MR. WEINBERG: That is it?


Q So you were having fun, you and Mr. Minton, in this thing on the harassment time line?

A Mmm, you know, Mr. Weinberg, I think even I said on that tape it was just an annoyance that they do it; though it was pathetic and though it was funny, it’s annoying. Now, you made a huge point about how harassed Scientology feels about being picketed. But when these people come by and picket, we’re supposed to be having fun. You can’t have it both ways.

Q Well, what do you call what they were doing, by the way? Do you call that harassment? Or do you call that the First Amendment?

A They were exercising their First Amendment rights.

But what happened that was harassing is that Bob and I didn’t have a clue they were even out there until they parked their cars, ran up to the door, knocked on the door


screaming, “Minton, Minton, Minton,” then ran back to their cars. This is the only way they let us know they were there.

We are upstairs fooling around on the computers. These guys are banging on the doors. We wonder, what the heck. We run down. And we got the drive-by pickets going on.

Q They didn’t shout obscenities?

A Absolutely. “Where is your whore, Minton?” This kind of thing. Absolutely.

Q You didn’t hear that on the tape, though, did you?

A Well, of course not. Because what I’m speaking about is when they knocked on the door, and we were way in the back of the house. They wanted to make themselves known. Now, what they’re doing, going up and down there,

Q Now, after this, after September of 1998, was this your first encounter with picketing, having signs and stuff like that?

A It could have been.

Q Now, after this, for the next — for the next four years, or almost four years, Mr. Minton and you and Ms. Brooks and other people affiliated with the Lisa McPherson Trust did all kinds of pickets in front of Scientology buildings, shouting obscenities, making threats,


interfering with — with Scientologists going into their buildings and the like, didn’t you?

A That is categorically false.

MR. WEINBERG: Could you play the first tape, please. This is May 27 — this is again — this is the Lisa McPherson Trust.


(WHEREUPON, the video was played.)

“Stick this in the right place. Scientology is a scam. A white meter. Fucking criminal. David Miscavige is a white Jew. He will be a convicted criminal.”

(End of playing of the video tape.)


Q Now, do you consider that harassment of the Church of Scientology? That was out in front of the church in Boston, wasn’t it?

A Yes. Was I there?

Q I’m asking you, do you consider that harassment?

MR. DANDAR: Objection. He’s not there. He should not be asked to comment about —

THE COURT: I think he can comment on that.


A You know, what I see there, that little snippet that you showed me, I would say yes, that is a bit annoying


and harassing.

But I also suspect, because when Bob Minton would go out and picket, he would just be quiet, he wouldn’t say a word, he would just walk up and down the street.

But then the OSA people would come out, Maureen Garde, the person I was walking with in the previous video, they would come out and start talking to Mr. Minton about things from his therapy sessions.

This is where the therapy information started, in picketing the Boston org. And they would kind of whip him into a frenzy. And the whole idea was to bait Mr. Minton to make him look like an ass.

Well, you know, I agree everyone ended up looking like an ass on some of those things, but, you know, let’s put this in perspective, because these little snips aren’t going to work. These people were specifically targeting Mr. Minton to do psychological terrorism on him.


Q Now, is it a bit annoying that Mr. Minton said that L. Ron Hubbard and David Miscavige were wife beaters?

That is a bit annoying?

A And I’m sure he’s annoyed because Mrs. Maureen Garde started speaking to things about — from his confidential counseling sessions with Scientology.

How Scientology got that information, God only knows, because no one will ever speak on it, will they? But that is what was


happening there.

Q And Mr. Minton, according to your testimony, was quiet on his pickets?

A He would just be as quiet as hell. Then if he got antagonized, he would start in. And I think that was known.

And, you know, you talk about me hating Scientologists. When you saw me in that first —

THE COURT: We’re well past the answer to that question.


MR. WEINBERG: Play the next one, please.

(WHEREUPON, the video was played.)

“Reform Scientology now. Don’t let David Miscavige destroy Scientology. L. Ron Hubbard would not approve of what David Miscavige has done.

“It’s safe to look. It’s safe to talk. Don’t let David Miscavige destroy the Church of Scientology. Make it something you can be proud of. Dump David Miscavige. Dump David Miscavige. It’s safe to talk. It’s safe to look. Don’t let David Miscavige destroy Scientology. L. Ron Hubbard would never approve of what Miscavige is doing. (Inaudible.)

“Reform Scientology now.


“Don’t let the introspection rundown kill you. You don’t have to die in introspection rundown. You don’t have to let Miscavige scare you to death.

“Don’t be afraid.

“Don’t let Miscavige scare you out.

“It’s okay to confront the fact that Miscavige cannot handle some pressure.”

(End of playing of the video tape.)


Q You recognize that as people including Mr. Minton from the Lisa McPherson Trust, right where the Scientologists in Clearwater go to eat, right? That is where that was, wasn’t it?

A Yes, it was.

Q And that sure sounded like a direct attack on David Miscavige, didn’t it?

A Mmm, it sounded like there was definitely some problems with Miscavige being voiced there.

Q You saw Miss Greenway there, didn’t you?

A Yes.

Q You saw David Cecere from the Lisa McPherson Trust?

A Yes. I didn’t see me, though.

Q You were the vice-president of PR at the Lisa


McPherson Trust, weren’t you?

A That is such a fabrication, it is laughable. I have never been — had anything to do with public relations, period. Can’t you tell?

Q So what was your position at the Lisa McPherson Trust?

A I was there specifically to help people who had been in — somehow had some gripe with Scientology that they wanted to make right.

And again I’ll say it. The work that we were doing at the Lisa McPherson Trust helped Scientology because you had a lot of garbage in the street, people that were hurt, people giving you a bad name.

When we finished with those people, they signed releases saying they wouldn’t speak disparagingly about you again, they got their money and they went on their way. Okay, that part needs to be told.

Q My only question was what was your title or position in the Lisa McPherson Trust?

A Vice-president.

Q Vice-president of what?

A The Lisa McPherson Trust.

Q And what was your responsibility there?

A I’ll say it again.

THE COURT: He just already said that.


MR. WEINBERG: That is just what he said?



Q Now, were you referred to as the big boss at the Lisa McPherson Trust?

A No.

MR. WEINBERG: Play the next one, please.


(WHEREUPON, the video was played.)

“Make Scientology something to be proud of. Reform it now before David Miscavige ruins it. Find the new leaders within your organization whom you can be proud of.

“Stacy, why don’t you try to round some of them up?

“The Lisa McPherson Trust was established at 33 North Ft. Harrison Avenue in order to let the world know about the abusive practices which David Miscavige has caused Scientology to live by.

“The Lisa McPherson Trust will always be here to remind you that you have a responsibility to be good human beings. David Miscavige is ruining your organization.

“Telecommunications is one of the powerful things you have learned in Scientology. Use it.


Try to use it to make the world a better place and start with dumping David Miscavige.

“If you ever want any help from Scientology, you can run to 33 North Ft. Harrison Avenue to the Lisa McPherson Trust.

“If you remember, Lisa McPherson is the woman who was held by Scientology for 17 days.

“The whole episode in the Church of Scientology’s Ft. Harrison Hotel was totally out-tech. Even the state prosecutor said it was totally out-tech. The whole thing was run by David Miscavige. David Miscavige is responsible for that woman’s death.

“Remember, David Miscavige is the one who performed the out-tech on Lisa McPherson.

“Remember, David Miscavige was responsible for the out-tech, out-tech handling of Lisa McPherson. She died after 17 days in captivity here.

“It was totally out-tech and you know it. You can look and smile.

“David Miscavige pulled the plug on Lisa. He pulled the plug on Hubbard’s tech. It’s time to face reality. Reform Scientology or it will be destroyed by David Miscavige.”

(End of playing of the video tape.)



Q Now, what was the reason that the Lisa McPherson Trust documented all these pickets by taking videos like this?

A Mmm, I think the purpose of the Lisa McPherson Trust always having the video when in close proximity to Scientology is the same reason that — for the same reason that happened to Mr. Minton when David Howe (phonetic) and another staff member — I think that was a staff member that attacked him. I personally took him to the hospital. He just raced him, no one is looking, boom.

So it became routine to take a video camera, in case something did happen that was truly criminal, that it could be documented. That was the purpose.

Q But it was for evidentiary purposes?

A Correct.

Q It wasn’t for posterity?

A Correct.

Q I mean, wasn’t this what the Lisa McPherson Trust was about — let me finish my question — to try to get rid of David Miscavige and to terrorize, using your word now, the Church of Scientology?

A I — I think Mr. Minton was very clear on what the Lisa McPherson Trust was for. And I’m glad you showed that


video, because he made it clear he wasn’t out to destroy Scientology, make Scientology go away, as you have, you know, suggested earlier. He wanted it to reform. He wanted the criminal activities to stop.

Why does he pick David Miscavige? I think we need to talk about it. Because you know why? He’s the man that has the private investigators do what they do. He’s the one that — that instigates these vicious attacks against individuals who have any disparaging thing to say about Scientology.

Why does Mr. Minton mention him? Because he knows he’s the person that can change it. Just like that letter that was turned into evidence concerning Bernie McCabe.

He’s the person that can do it. If anyone can do it, Mr. Miscavige can do it.

Q Right. And you accused Mr. Miscavige of murder in your affidavit, didn’t you?

A I accused of — Mr. Miscavige of letting her die?

Q Of intentionally letting her die?

A Letting her die.

Q Intentionally?

THE COURT: We’ll not get anywhere. The document speaks for itself.

MR. WEINBERG: You are right.



Q You suggested, stated, in your affidavit, that a decision was made, an intentional premeditated decision, to let her die?

A Correct.

Q This is the same man that you shouted obscenities about, it’s the same man we are watching videos of Mr. Minton and others stand up, asking to be deposed or thrown out of position, right?

A It’s the same man I audited. It’s the same man I have been friends with many years. It’s the same man I have done training with. It’s the same man I helped myself establish and build Scientology for many years. So add that into the equation, too.

Q You think he would call you his friend?

A I think if David and I sat down and talked, he would —

THE COURT: I have heard this question and I have heard this answer at least twice.

MR. WEINBERG: Thank you.


Q Now, when Mr. Minton said the words “Out-tech” that is something that means something to a Scientologist, correct?

A Correct.


Q I mean, Mr. Minton, prior to getting involved with you —

THE COURT: Counselor, it is getting pretty bad to me because I understood it.

MR. WEINBERG: But — all right.


Q A Scientologist, or a judge that sat in a hearing for 28 days.

THE COURT: There you go.


Q That is not something Mr. Minton or any of us, having not been exposed to Scientology before, would understand, correct?

A Yes.

Q And to be out — out to accuse the ecclesiastical leader of being out-tech is about as — about as serious and severe an accusation as you could possibly make against David Miscavige, isn’t it?

A Mmm, Mr. Weinberg, my answer is if the shoe fits, wear it.

Q Just answer that question.

A I did. If the shoe fits, wear it.

THE COURT: No, he wants to know if that is a serious accusation to make to other Scientologists about their ecclesiastical head. Is that a bad


thing to the head of Scientology to be out-tech.

THE WITNESS: Yes, it is.

THE COURT: To another Scientologist, those folks seeing that demonstration, if they believed that, would not think very highly of their leader?



Q And would you not — from looking at that video or the other videos that you have seen so far, it doesn’t look like any of the Scientologists are having a lot of fun at your demonstrations, correct?

A You know, you have only shown me specifically Mr. Minton. You haven’t shown me what the Scientologists are doing or not doing, Mr. Weinberg.

Q Well, in that video we just showed, it was —

A It was going back and forth.

THE COURT: You know what, the deal is we are showing this for —

MR. WEINBERG: That is correct.

Could you play the next one, please.

(WHEREUPON, the video was played.)

“Communicate to David Miscavige that he’s fired.

“Remember Lisa McPherson.


“When you’re eating, remember Lisa at her last meal in December of ’95, held captive by the Church of Scientology leader, David Miscavige.


“What is not safe for you is to stand there and do nothing. Tell David Miscavige he’s wrong. Tell him that L. Ron Hubbard would never approve of what he is doing to destroy your church.

“PK, PK, don’t run away.”

(End of playing of the video tape.)


Q Does it look, in that video — I mean, and others that we’ve seen — that Mr. Minton is terrorized, harassed or anything like that?

A Mmm, it looks like Mr. Minton was picketing, to me.

Q Now —

(WHEREUPON, the video was played.)

“Okay, are we going to do the locks?

“But the — are we going to do the alarms or –” (Inaudible.)

(End of playing of the video tape.)



Q You were just having a big time, you and Ms. Greenway?

A You know, that is an edited video you have there. It is — there is obvious editing there, so I would be hard-pressed to draw that conclusion.

Q When it started, it started like all of the pickets started inside the offices of the LMT, correct?

A That is a mischaracterization of how pickets started because every picket did not start in the Lisa McPherson Trust. Other people picketed the Ft. Harrison that weren’t associated with the Lisa McPherson Trust or employees of the LMT — Lisa McPherson Trust.

Q That clip from the LMT film library, that one started in the LMT building, didn’t it?

A I don’t know if it started or finished there because you have shown me one tiny segment. So, you know, if I could have some perspective and see the whole thing, I would be able to comment more accurately.

Q Now, the LMT — literally at times these pickets were intended to literally shut down Clearwater around where you-all were picketing, right?

A No.

MR. WEINBERG: Play that one, please.


(WHEREUPON, the video was played.)

“Last year, we were all over the place in a clump. We shut down here, we shut down here, we shut down there. We had Flag shut down for the whole day, anyway. This year we spread out in strategic spots and shut down the whole city.

“Frank Oliver came and caused the last breach. So far about two hours now they can’t hardly move anybody any way. They can pick up people from Flag but they can’t bring them in because they have to bring them in there, and they can’t do it.”

(End of playing of the video tape.)

Q That is somebody from the LMT?

A Absolutely not.

Q Who is that?

A Greg Hagglund. He lives in Canada.

Q And he was down here for the picket in December?

A Looking at that date of that, he was down for the picket and vigil. People come from all over the United States and even Europe for that. They were doing that long before the Lisa McPherson Trust ever existed or it was here in Clearwater. So, you know, it would be a real bad stretch to think that, you know, he’s working at the trust because


he’s picketing.

Q Well, is there a particular reason why the trust had that tape in its film library?

A Maybe someone videotaped it and gave it to the trust, Mr. Weinberg.

Q Well, who was the videotaper for the trust?

A Mark Bunker.

(WHEREUPON, the video was played.)

“Remember Lisa McPherson. Okay, let’s go. (Inaudible.)

“– is one of our old friends.

“Yes. Some other friends from Germany, too.

“That is a good one, too.

“Where else would you like –”


(End of playing of the video tape.)


Q Those are all people from the Lisa McPherson Trust, weren’t they?

A False.

Q Oh, Miss Caberta was from Germany, your guest over here?

A Ms. Caberta was here on vacation. Mrs. Caberta.


And if you will recall, you yourself earlier said she’s employed by the German government. So, you know, she’s not LMT. She’s just like you said, employed by the German government.

Q This was an LMT-sponsored picket in front of the Ft. Harrison Hotel?

A LMT has never, to my knowledge, sponsored a picket.

Q Is there a particular reason why Mr. Merrett was at that picket?

A I believe Mr. Merrett was at the picket to make sure that nothing happened, there were no altercations, no scuffles, no — you know, you’ll notice this, people, for the most part, are just silently walking up and down the street.

They are not screaming at Scientology itself or yelling at Scientologists; they are exercising their constitutional right to protest.

Q Do you think it might be somewhat harassing to the — on the doorstep of the mecca of Scientologists with signs saying “Blood of Lisa McPherson on your hands” and things like that?

A You know, I can see where someone could draw that inference or conclusion. But the inference and conclusion I draw is people were exercising their constitutional right.

If it was even a civil crime, they would have been sued out


of existence.

Q Do you remember that the Lisa McPherson Trust — people documented by Lisa McPherson Trust video picketed in front of the Ft. Harrison Hotel when a Hindu wedding was going on? A Hindu wedding?

A No, I was not there. I know nothing about it.

Q As your position as the VP of the Lisa McPherson Trust, you don’t remember that one?

A Correct.

MR. WEINBERG: Why don’t we show that.

THE WITNESS: Was I present here?

(WHEREUPON, the video was played.)

“Well, Jesus, that is one thing Scientology didn’t believe in or any other religion, isn’t that right, guys? Isn’t that right? Isn’t that right? That is all — let’s let all of the Nazis come out.

“People are trying to have a wedding, sir.

“What is that?

“Hey, this is fine.

“They’re just trying to have a wedding. They are not —

“Listen, it’s not my fault they got married here.

“Come on now.

“This is a public sidewalk, buddy, so don’t start



“This is not — (inaudible).

“This is a public sidewalk. Let’s get out of the way. It is still a public sidewalk. Okay?

“When you get out of Scientology, your luck will — (Inaudible.)

“Let’s go. Let’s go.

“Let’s go.

“Come on.”

(End of playing of the video tape.)


Q Why did the LMT put that in its film library?

A I think that every — and I’m not sure if this is not Mr. Mark Bunker’s film library that you are referring to — but, you know, we’re — we’re looking at here your two star witnesses. You are showing me videos of your witnesses that you have used in this hearing to testify for you. What are we doing here?

Q I think you said that this is the most harassed person you have ever seen. Does it look like Mr. Minton is the most harassed person you have ever seen when he’s standing there with a sign with skulls on it in front of the Ft. Harrison —


THE COURT: Don’t —

MR. WEINBERG: I’m sorry.

THE COURT: — raise your voice up to this witness and start approaching him.

MR. WEINBERG: I’m sorry.

THE COURT: I won’t have it. And I’m not going to remind you again.


Q With a sign with skulls on it, interrupting a Hindu wedding?

A Mr. Weinberg, I agree with you what happened there — what happened was extremely inappropriate. And I don’t agree with it. And you didn’t see me there.

Q I’ll show you one you are at, Mr. Prince.

By the way, before you play that, that tape was done — the one we just played was done in — in September of 2000.

You were full-time at the Lisa McPherson Trust, correct?

A That is possible, yes.

Q Not possible. That is correct?

A I said it’s possible.

Q Why do you say it’s possible? I mean —

A Because I’m not sure when I made that transition from — I’ll explain it to you, I’m not trying to be coy


here, but there came a point in time when my work with Mr. Dandar involved doing a bunch of depositions of Scientology staff members or Scientologists or whatever and we worked together quite a bit then.

But then there came a period of time when it was time for the medical experts. Those people are the experts. He certainly didn’t need me there. So there came a point in time when I started working at the Lisa McPherson Trust.

Q In September of 2000 when that took place, you were on the payroll of the Lisa McPherson Trust, correct?

A It is possible, yes.

(WHEREUPON, the video was played.)

“Jesse is — this is — Jesse, show him what you’re going to do if they come at you.

“Drop and fall. That is all. I’m going to fall down.

“Hey —

“You know what (inaudible).

“That is a good idea.

“Full resistance, that is our motto.

“How are you going to do it?

“Just carry the sign.

“Oh, my God.

“Kind of like the Three Stooges.


“The St. Pete Police.

“Yes, I told them I would be there by quarter to seven.

“Oh, God.

“Let’s do this.

“Guys, remember what we all agree with. We’re all staying together.

“Yes, boss.


“Uh-huh. Uh-huh. Okay, well — Mmm, no.”

(End of playing of the video tape.)


Q Now, that is one of your six pickets?

A Rhetorical.

Q Excuse me?

A That is one of the six pickets I have probably been in.

Q And in that video we saw Patricia Greenway, correct, who is in the audience, right?

A Show it to me again. I missed that.

THE COURT: Yes, she was there.

THE WITNESS: Okay. I’ll take your word.


Q Peter Alexander, who testified in this hearing?


THE COURT: I don’t know if he was there or not.


THE COURT: I didn’t recognize him, but —


Q The gentleman, sort of young guy in the pink or red shirt, that was Graham Berry, correct?

A Correct.

Q The lawyer from LA?

A Correct.

Q Now, your sign, “Mafia Cult”?

A Correct.

Q And that was —

A In relationship to the black operations that are run out of OSA.

Q And you were picketing, you walked from the LMT — this was an LMT operation, wasn’t it? That is where you-all left from, from the LMT?

A Yes.

Q And at that point, you were full-time at the LMT?

A I — I’ll stipulate to that, sure.

Q Except you were still working for Mr. Dandar, you were still doing stuff on the Lisa McPherson case, weren’t you?

A Well, you know, as I said, Mr. Weinberg, there

came a time when Mr. Dandar was solely doing medical experts. There was certainly no need for me to sit there through that.

MR. WEINBERG: One second, your Honor.


Q Now, you, Mr. Dandar and a number of other people from the LMT were at the closing when Mr. Minton closed on the purchase of the building either at the — at the beginning — January 5 of 2000, is that right?

A I believe that is correct.

Q And Mr. Dandar was — and you and Mr. Minton and Ms. Brooks were very enthusiastic about the LMT and how the LMT was going to — to operate. Correct?

A Yes.

Q And Ms. Liebreich was very enthusiastic about the LMT opening, correct?

A I don’t think Mrs. Liebreich was there.

Q But do you remember that the first phone call that was made was made to Ms. Liebreich, and you talked to her, among other people?

A I think I remember something about that, yes.

Q And she was very enthusiastic about that. Right?

A She was very happy and proud that the last wishes of Fannie McPherson were actually taking effect, which was to expose any deceptive and abusive processes by


Scientology, you know.

Mr. Minton is — just wants reform, tired of people calling, tired of people saying, “Can you please help.”

Q Your testimony, I believe, was — and correct me if I’m wrong — that you never met with Mr. Dandar for any purpose — for any meeting type purpose at the LMT. Is that right?

A Correct.

Q Now, do you remember at this opening that — at this closing where, in essence, the LMT was opening, that you described — or someone described what your position and responsibility was going to be at the LMT?

A I don’t recall it specifically, Mr. Weinberg.

Q And you deny it was in charge of PR, right?

A Correct.

MR. WEINBERG: If you could play that, please.

This is another video from the LMT.

(WHEREUPON, the video was played.)

“Ken, I’m sorry there’s no more chairs.

“It is okay.

“Sign first — (inaudible).

“You want to sit down? Here is the — these are the — (inaudible).


“Did you bring the property insurance papers?

“Of course not.

“You didn’t?


“You mean the balance, it’s everything you did fax me yesterday.


“The insurance papers are the closing paper for the mortgage.

“Yeah. Right. Right.


“That is okay. That is okay.

“It’s just that we don’t have the check for him — or, we have the check but — (inaudible).

“How are we going to do it? How are you going to do it?


“No, I’ll just tell you to send a check and how much it is. (Inaudible.) It’s a binder.


“If Scott has a fax machine I can fax it to him.

“Hang on one second. Okay?





Q Is that Tom Tobin from the St. Pete Times?

A I believe it is.

“This is Steve Mitchell. This is Jesse Prince.

“Nice to meet you, Jesse.

“Nice to meet you.

“He’s an expert on Scientology in the Lisa McPherson case. He’s going to be also working at the trust.

“Oh. Terrific.


“So he has an idea of what we’re dealing with. Big time, right?

“Big time, Bobby. This is too cool.

“Jesse, what are you going to do with this organization?

“Make it as successful as possible.

“I mean, what’s your job or what — do you have functions or duties or —

“I’m on the board of directors. And I’m going to just, you know, be here with the organization, get it through its initial phase of establishing itself, and run around and do public relations.

“Oh, really.



“He’s also an expert on the Lisa McPherson case so he’s going to be spending a lot of time with Ken Dandar so he’ll be –”


“He’s been working, you know, intimately with Ken on this case for a long time.



“You mean, does he own the building now?

“Thank you very much. Thank you. Scott.

“Thank you.

“Thank you very much. I can’t tell you how much I appreciate this.

“I wish you the best. I hope you do well with this.

“Thank you.

“Scott’s been under a lot of pressure, I’m sure.


“Thank you.


“Hey, Ken?

“Hey, Ken?

“So anybody want to open that champagne?



“Ken, your comments?

“Well, I think this is a good day for downtown Clearwater.

“Hi, Mike. How is it going?

“Happy New Year.

“We just closed on the building.

“Okay. Call me.

“I have a binder in my office.”

(End of playing of the video tape.)

MR. DANDAR: Could we have a stipulation that was edited by the defense?

MR. WEINBERG: I mean —

THE COURT: I don’t know if it was or not.

MR. WEINBERG: I mean, Mr. Bunker edited a lot of these tapes before he ever gave them to us. I mean —

MR. DANDAR: Well, whatever.

MR. WEINBERG: I mean —

THE COURT: All I can say, Counselor, it is available for you to get a copy of, so —

MR. DANDAR: I know.


Q Now, what was the Lisa McPherson trial consultant and the Lisa McPherson case lawyer doing at the closing of


the LMT building?

A It looks like they were partaking in the festivities, to me.

Q It does to me, too, Mr. Prince.

A Yeah.

Q Now, when Ms. Brooks said that you were going to be doing public relations, was your first job to get Tom Tobin from the St. Pete Times there?

A You know, I think that is a leap in logic. And I think the person that actually said doing public relations stuff was me. I don’t think it was Ms. Brooks.

Q All right, I stand corrected. When you said you were doing public relations, what did you mean?

A I think that that was just an offhand comment. And I didn’t even know what I meant. Maybe I had some intention on doing something public relations-wise.

But what factually ended up happening is once the door opened, the phones started ringing. And as I mentioned, you know, getting through the initial establishment part, to find out exactly what our role is going to be, it simply turned into servicing current and ex-Scientology members.

Q The way you got your message out was to carry signs and picket in front of the Church of Scientology?

A That was the one thing that was done.


Q And — but at this time when this started in January 5 of 2000, you were in charge of public relations but you were being paid by Mr. Dandar to be a so-called expert in the Lisa McPherson case. Correct?

A That is totally incorrect. There was no public relations. I was not doing public relations, orchestrating public relations, media contact.

Mr. Weinberg, if you have shown anything with the indiscretion I have used, public relations is not anything that I would even pretend to be versed in, so, you know, let’s move on.

THE COURT: I’m going to tolerate about one more of these, then I can’t stand any more for the day. I still do not know why we’re playing all of these, but —

MR. WEINBERG: I can explain.

THE COURT: I’ll let you do that in closing argument, but I can only stand one more today, so play it and —

MR. WEINBERG: I’ll play one more and it will be this one.

THE COURT: All right.

MR. WEINBERG: December 2, picket across from the Ft. Harrison.

I want you to look for Mr. Dandar here. All



THE WITNESS: Okay. All right.

THE COURT: What is the date again, Counselor?

MR. WEINBERG: December 2, 2000.

THE WITNESS: Was I at this picket?

(WHEREUPON, the video was played. No audio available.)


Q You recognize the person with the sign was Frank Oliver?

A Yes.

Q You recognize Teresa Summers? She testified in this case.

A Yes.

Q You recognize yourself?

A Yes.

Q You recognize Mr. Merrett?

A Yes.

Q You recognize Mr. Minton?

A Yes.

Q You recognize Mr. Dandar. Correct?

A Yes.

Q And that was in front of the Ft. Harrison during a picket, wasn’t it?

THE COURT: I didn’t see any signs except


one — I did not see what I would classify as a picket.

A There was no picket. And I remember this incident, if you’ll let me explain it to you.

Bob Minton had come into town and Ken needed to talk to him or see him for something. Mr. Dandar simply stopped by. Mr. Dandar was not a part of any picket or doing anything. He simply knew where Mr. Minton was going to be, he came there, spoke with him and left.


Q So what were you-all doing there?

THE COURT: I saw folks across the street, Counsel, that had signs, then somebody said hi, went across the street. That is where Mr. Dandar was.

The sign was down. The only one person that had it, they were talking, then somebody put a sign up and went off like there was something else going on someplace else.

I don’t think it would be fair to classify what Mr. Dandar was in was a picket. I could not tell they were in front of any hotel, either.


Q Well, you recognize that was across from the Ft. Harrison?

A No, I do not.


THE COURT: I don’t know where it was because I couldn’t tell. It looked like a street corner. It might have been. I don’t recognize that.

MR. DANDAR: I can tell you, Judge. It was catty-corner across the street from the Ft. Harrison. These people with signs who were across the street from me, across the street from the Ft. Harrison, were standing in front of the new Super Power building. But I wasn’t part of any picket.

That is right.


Q Now, was Mr. Merrett part of the picket?

A No, he was not.

Q Were you?

A No, I was not.

Q So you had been — so all these LMT people were sort of off to the side, and there were other LMT people that were holding signs?

A You know, again, Counselor, I’m not trying to be difficult here. You are showing snippets and you are drawing conclusions. The conclusion that I see from this snippet is we are simply standing there having a conversation. No one but no one is picketing.

THE COURT: Looks like there was getting ready to be a picket. There were people with signs, but


when they saw Dandar, it looks like somebody waved, walked across the street, the guy that had the sign, whoever that was, the one, put his sign down. When he picked up the sign, he went walking off to where I would presume a picket was going on. But those other folks were across the street that must have been going for a picket, I’m guessing.

MR. WEINBERG: You said that was the last one you wanted to see.

THE COURT: That is absolutely the last one I want to see.

It is 5 o’clock. We’re done for the day.

We’ll see you at 9 o’clock tomorrow.

MR. WEINBERG: Thank you. Have a good night.

(WHEREUPON, Court stands in recess at 5 o’clock.)




I, LYNNE J. IDE, Registered Merit Reporter, certify that I was authorized to and did stenographically report the proceedings herein, and that the transcript is a true and complete record of my stenographic notes.

I further certify that I am not a relative, employee, attorney or counsel of any of the parties, nor am I a relative or employee of any of the parties’ attorney or counsel connected with the action, nor am I financially interested in the action.

DATED this 9th day of July, 2002.



Testimony of Jesse Prince (Volume 3) (July 8, 2002)


CASE NO. 00-5682-CI-11

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




PROCEEDINGS: Defendants’ Omnibus Motion for  Terminating Sanctions and Other Relief.

CONTENTS: Testimony of Jesse Prince.1


DATE: July 8, 2002. Afternoon Session.

PLACE: Courtroom B, Judicial Building
St. Petersburg, Florida.

BEFORE: Honorable Susan F. Schaeffer,  Circuit Judge.

Deputy Official Court Reporter,  Sixth Judicial Circuit of Florida.

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



5340 West Kennedy Boulevard
Suite 201
Tampa, Florida 33602
Attorney for Plaintiff.

112 N. East Street
Suite B
Tampa, Florida 33602-4108
Attorney for Plaintiff

1100 Cleveland Street
Suite 900
Clearwater, Florida 33755
Attorney for Church of Scientology Flag Service Organization.

101 E. Kennedy Blvd
Suite 1200
Tampa, Florida 33602-5147
Attorney for Church of Scientology Flag Service Organization.

740 Broadway at Astor Place
New York, New York 10003-9518
Attorney for Church of Scientology Flag Service Organization.


APPEARANCES: (Continued)

Battaglia, Ross, Dicus & Wein, P.A.
980 Tyrone Boulevard
St. Petersburg, Florida 33710
Counsel for Robert Minton.


THE COURT: Mr. Prince, you all may be seated.

MR. DANDAR: Judge, I just was advised by my  office that Judge Baird wants us to be at a hearing  tomorrow by telephone. And I’m going to be here and  my brother is covering another hearing for me in  Tampa. But Judge Baird wants to go forward with the  hearing by telephone.

So I would ask that you let  me attend that hearing by phone.

THE COURT: What time?

MR. DANDAR: Nine o’clock.

THE COURT: Okay. How long is the hearing  expected —

MR. DANDAR: I have no idea.

THE COURT: Well, that is no good. What kind  of motion is it?

MR. DANDAR: It was the Flag’s — or RTC’s —  actually, Mr. Rosen and Mr. Pope’s motion to strike  our pleading challenging the domestication of the  Texas judgment against the estate.

THE COURT: So it’s legal —

MR. DANDAR: Right. We had a hearing on that  Tuesday at about 5 o’clock before July 4 and we  filed a supplemental memorandum of law and they  filed a response over the holiday, so I guess we’ll  discuss that.


THE COURT: You think an hour?

MR. DANDAR: I hope not. I don’t think so.  But —

MR. WEINBERG: I’m told not that long. About  thirty minutes.

THE COURT: Okay. Well, let’s plan on starting  at ten o’clock anyway.

MR. WEINBERG: All right.

THE COURT: All right, go ahead, Mr. Dandar.

Mr. Prince indicated he didn’t give us his full explanation, so you can go ahead with that.

MR. DANDAR: Okay, before he does that, could I  give him a document that I had the clerk just mark?


Q Well, Mr. Prince, go ahead, give us the full explanation of why you have the opinion that Lisa McPherson was dead because of an end cycle order?

A Okay. Lisa McPherson went to the hospital.  From — from the records that I can see from the doctor,  they didn’t indicate that she was psychotic and needed to be  Baker Acted.

Now, we’re talking about terms here that mean different things to different people. In the hospital they define psychosis the way they define it and, thus, Baker Act people. In Scientology, they have a different definition


for a person, a psychotic or suffering from psychosis.  One of the definitions, reasoning of what  psychosis is in Scientology, is in their Case Supervisor  Series 22, which has been entered in on the record, I’m  sure, many times. And this is concerning psychosis.

Now, it says here —

THE COURT: I don’t know if it has been or not.

I think you’re looking in that one book?

THE WITNESS: Yes, ma’am.

THE COURT: I’m not sure if that whole book was introduced.

THE WITNESS: No. No. Not the whole book. But this issue here, psychosis, has been an exhibit.

We can put it in again.

THE COURT: I don’t know if it has or not.

MR. WEINBERG: I don’t think it has.

THE WITNESS: Okay. Well, when I finish explaining it, I’ll hand it over.

MR. DANDAR: We’ll mark it.

THE COURT: All right.

A It says — down here at the beginning of this issue here on psychosis, it says, “All characteristics classified as those of a suppressive person are, in fact, those of an insane person.”

So, in other words, it is the belief of


Scientology that a person who they consider to be suppressive and has those characteristics are also insane people, you see. So we’re working with two different  definitions here.

Now, if this person — if Lisa was taken to the hospital and they said okay, she’s not insane, she’s just having problems, she can work it out, she gets to Scientology, she’s insane. They are the ones that classify her as being insane.

Why do they classify her as — well, one of the reasons they classify her as being insane is because she wants to leave. And again that is mentioned here in this book here of people wanting to leave as also being psychotic.

So my thing is this. Lisa McPherson was taken to the Ft. Harrison. Prior to being — to this whole incident with going to the hospital and everything, she made her intentions to the Church known, to her friends, to her family, she wants to leave. In their minds, she’s psychotic. Medically, not necessarily so, she simply doesn’t want to do it anymore.

It has become a matter of PR concern because she had the accident with the boat, you know. She’s left, she’s —

THE COURT: I’m sorry, she had the what?


THE WITNESS: The accident with the boat, where she ran into the back of the boat and took off her clothes.

THE COURT: Oh, okay.

A Okay? This is something a person now who again, two months earlier, just testified to being more than human, more than a homo sapiens, this person is a homo novis. This person is almost like a demigod. Now, this person is brought to the Ft. Harrison.

In my mind, my opinion, she came in there, she said, “I want to leave.” She didn’t change her mind. She’s delegated to be psychotic. They want to put her on introspection rundown. She’s incarcerated.

In that book “What Is Scientology,” it gives a definition of introspection rundown and gives a brief summary of introspection rundown that the public people can read.

MR. DANDAR: Let me hand this to the witness, Judge. It is Exhibit 125, just marked by the clerk from “What Is Scientology,” which I believe you have the entire book.


A It says “Introspection Rundown. This is a service that helps to preclear, locate and correct things which cause him to have his attention inwardly fixated. He then


becomes capable of looking outward so he can see his  environment, handle and control it.”

Nothing in here, one, if Scientology labels you psychotic, you are going to be incarcerated until a case supervisor tells you you can leave. There is nothing in here that warns anyone of that.

So Lisa was taken to the Ft. Harrison, deemed to be psychotic, put on the introspection rundown.

Well, when did that come up that we even found out that Lisa was on introspection rundown? After Alain Kartuzinski and other people were given use immunity when they were first saying she’s a hotel guest, now the
investigators want to hear the story, “Oh, she was on introspection rundown.” Okay. So she’s on introspection rundown the second day.

And to me — again, she told them, “I want to leave.” They wouldn’t let her leave. She gets violent. The next day they order the drugs to put her down.


Q What drugs?

A I think it is chloral hydrate or Valium. Alain Kartuzinski gave some money for Valium. And if you look and see what Scientology says about drugs, psychiatric drugs, all of these things, these things are expressly prohibited.

Now, so far what we’ve seen, we see Scientology’s


policy if a person is sick, when you take them to the  hospital, make sure — but now we see things happening that — that are outside of that. By their own policy we see things they are not following that. That is a huge no-no.

We are at the place where policy and tech is applied 100 percent correctly standardly in every case, but somehow in this instance we have so many instances where this person — they are not doing it, they are not doing it.

And the reason why, you have to look behind that. And the reason, my contention is, is that she expressly wanted to leave, it escalated to her actually threatening, probably threatening with legal, threatening with law enforcement or whatever. This became a problem.

OSA was there from the very beginning, reporting about this, the very beginning, because this is a legal threat, this is a problem in Scientology.

So maybe they did try an introspection rundown on her. You know, they say they did. Maybe they did. But I think she never agreed to it. I think that she decided she was done with Scientology, no matter what they said to her,
she would no longer agree to it, because by her own word, it was making her sicker.

So instead, because of what happened, when they saw Lisa’s deteriorating condition, in their minds Lisa is


on the process. She’s on introspection rundown. Scientology has further policy, the way out is the way through, get the PC through it. What turns it on or turns it off. In their minds, whatever she’s going through is part of the process.

Plus, you have the added fear that if this person isn’t reconciled with Scientology, it’s going to be a big problem.

So instead of taking this girl to the hospital where she should have belonged, where their own policy says to do, and get her medical treatment, when it was obvious, by the reports that I have seen that she was ill, instead of
doing that, no, we’re going to keep doing Scientology because that is what it means by Keeping Scientology Working and, you know, what happens happens. Some of them don’t make it. Too bad.

But the biggest fear for Scientology was to let this girl go, in the state of mind where she was refusing to cooperate with them, caused them more problems than her actual death.

Q How do you get to your conclusion that her death was a result of an end cycle, let her die order from Mr. Miscavige?

A During my tenure in — in RTC, we would have staff meetings that had a pattern to the staff meetings. And the


patterns were this. What are the flaps? What are the  handling for those flaps? Those are the first things that are discussed and chewed around and taken care of.

Q With whom?

A Amongst the executives and the staff in any particular organization. Any particular Sea Org organization, I should say.

Q At RTC, who were the meetings with that you had?

A Flaps and handling? They would entail myself, Vicki Aznaran, Mark Yaeger, David Miscavige, Lymon Sperlock, Norman Starkey (phonetic), in some instances the executive director in the national if it had to do with stats. But
those were the people that ultimately had to know what was going on.

Now, why is Flag Service Organization so important? Because the Flag Service Organization, when I left here in 1982, made an income of over 2 million a week. So you have an organization here that makes $8 million in a
month. This is — it is the highest income-producing organization within Scientology.

It’s a major concern that everything is perfect at the Flag Service Organization. There is not going to be an instance where no one knows what is going on. So in the staff meetings you talk about flaps and handling.

Well, Lisa is a flap. It’s reported up the lines.


OSA is there from the very beginning because she is a legal threat because it is a flap. And they are busy reporting, you know, on the legal side of it and what is going on and the repercussions.

They are also coordinating and in liaison with the technical area that has the technical program that they are trying to get her through, which in their minds is going to cure her.

Everyone knows — I believe there is also testimony on the — during the time period that Lisa was going through this trouble, Mr. Miscavige was there. We would often go to the Flag Service Organization, to inspect it, to make sure it is running properly, to make sure this technology is being applied 100 percent standard.

Q What are you relying on when you say Mr. Miscavige was at the Ft. Harrison Hotel in this time period?

A I believe some — a public person who — I don’t recall the name right now — something that I read mentioned the fact that he was there. And — he was at post.

Q This public Scientologist saw Mr. Miscavige?

A Yes.

Q Was that in the police files of the Clearwater Police files?

A Yes.

Q Okay.


A So your largest income-making —

THE COURT: Where is that?

MR. DANDAR: I have it. I’ll introduce it, Judge. In fact, I have it on my computer. I’ll print it out on my next break.


MR. DANDAR: It is Detective Carrasquillo of  the Clearwater Police Department interviewed four, I  believe, public Scientologists staying in the  cabanas who heard nothing during this time period,  who saw Mr. Miscavige —

MR. WEINBERG: Excuse me, your Honor, is Mr. Dandar testifying? Or is he asking questions?

THE COURT: I just asked him a question. He’s responding to me. I was saying —

MR. DANDAR: It is a four-page document. It’s on my computer. I can print it out.


A So, you know, from the limited time that I was  there in the Religious Technology Center myself, I know that, you know, there wasn’t much about the Flag Service Organization that I didn’t know about and also had responsibilities for to make sure that the whole thing ran smoothly. And the person that I reported to was certainly the — ultimately was Mr. Miscavige.



Q Okay.

A And I am saying here today — and the reason I came to that conclusion — is by their own written policies that they have written here, you start to see violations.

And the reason why is because there was a problem. There was a legal threat. Lisa was not cooperating with them. When I did the introspection rundown on the other girl, she was cooperating. She wasn’t trying to leave. She
was going along with it. She never mentioned that she wanted to leave at any other time. There is a big difference.

So now you have a person that wants to leave, has publicly stated they want to leave to their friends, to their family, to the auditor. That is a no-no.

Q How did you —

A Again, there is reference where a person wants to leave is psychotic. So now they have put this label on her. She’s locked in a room. She’s terrified. Instead of taking her to the hospital when she was sick and letting her get
treatment because of her state of mind and because of the way she felt about Scientology, they opted to just continue the process, and either it works or it doesn’t.

Q Well, Heather Hof, who was a 17-year-old ethics officer, or studying to be an ethics officer, inspection


reports, all her records, are missing. She testified in deposition that she hand-delivered her reports to Mr. Kartuzinski, saying as early as December 2, I believe, Lisa McPherson wasn’t eating or drinking enough to survive,
something had to change, Heather was frantic. The —

MR. WEINBERG: Your Honor, objection. He’s just testifying. This isn’t a question. This is just Mr. Dandar summarizing — and I would say missummarizing — what he thinks the testimony has been. It’s not a question. It’s a statement.

THE COURT: Well, I suspect that he’s saying,  “Mr. Prince, if this is her testimony.” That is what you do with an expert sometimes. So if that is what he’s doing, I’ll allow it, I guess, with the question.


Q So I’m assuming I’m accurate in my recollection of what Heather Hof testified to the police, as well as her deposition in this case, and the pathologist retained by the estate, that Lisa was in a coma that she could be shaken out of but she would go back into, five days — the last five days of her life. And in reading — in what you know and reading what you just told us you read, why is it your opinion that they would just simply let her die rather than take her to the hospital?


A Because she was not settled with her relationship with Scientology. And this would have caused tremendous problems for them. If they would have taken her — you know, even during the period of time when she was going in  and out of the coma and say she goes to the hospital now, she starts getting treatment, she’s getting better, you know, Scientologists come around, she now tells the doctors, “No, I don’t want to see them anymore, I have to get away  from this.”

Q Mr. Prince, I guess the crux of the matter is you — you put together an affidavit that is dated August of 1999. Do you recall that?

A Yes, I do.

Q Where you talk about the role of David Miscavige and Mr. Mithoff and Marty Rathbun and your prior history in RTC. Do you remember that?

A Yes. I do.

Q And in that affidavit you have come to the conclusion that the three of them just decided to sit around and not do anything about it and end cycle Lisa McPherson?

A Yes. If she dies, she dies. If she gets better, she gets better.

Q Now, did I help you write that affidavit?

A Not at all. This affidavit came about because — from studying all of the evidence. And I spent months


studying this to come to this conclusion. This conclusion I  came to was my personal opinion, I stated it as such, based on the experience I have within that organization.

And the thing that — that became alarming to me to even point me in this direction is the amount of information that is missing, the amount of things that — that isn’t there that would clearly show like what her state of mind was based on what she was saying. All of that is missing. Which means cover-up. Which means something is hidden. Why is something hidden?

In my mind, similar to what happened in Wollersheim. This is information, if gotten out, could be harmful or damaging to Scientology. And Scientology, the survival of Scientology, is first and foremost in the mind of any Scientologist, even beyond their own lives.

Q Did Stacy Brooks put you in the mood to write this affidavit? Did she kind of persuade you to write this affidavit?

A No. Put me in the mood? I guess I didn’t understand.

Q Okay. Did she influence you in any way whatsoever to get you to write this affidavit where you conclude that Mr. Miscavige and others had decided to issue the end cycle order?

A No. Matter of fact, Stacy disagreed with my


opinion about that. She disagreed with it. But — and we’ve had discussions about this.

I mean, you know, I did it outside of her. Stacy was nowhere around when I did my affidavit. And she asked me why I came to that conclusion. I mean, we’ve had in-depth conversations about that, because Stacy was not in the position I was in to be able to make that determination.

Q Did anybody — let’s even go to Bob Minton. Did Bob Minton suggest to you, order you, tell you in any way, shape or form what to put in that affidavit?

A No. Bob Minton was so disrelated from anything that I was doing in this case.

Q Really? How so? I mean, wasn’t involved at all?

A Bob Minton never cared about the particulars that was going on in this Lisa McPherson case. He never concerned himself with that.

His words to me were, “I have hired Ken. He’s got the money. He’s the best one that — the best lawyer I could think of to do it. It’s his job. It’s his responsibility.”

Q Did Bob Minton say he hired me, Ken Dandar?

A No. No. He just said you were the attorney of record. He trusted you. You could —

Q Did you ever hear Bob Minton say to you, or to me in your presence, that — ordering me to charge David


Miscavige with — in the civil case with murder?

A Absolutely not.

Q Did anyone — maybe I haven’t mentioned the right  name, I don’t know. Let’s just cover the whole waterfront.

Is there anyone that gave you direction or influenced you in any way on how to write that affidavit and what conclusions you reached in that affidavit?

A None at all. No one.

Q Now, the only other end cycle orders you have seen when you were in RTC, did they only have to do with people who had a terminal illness?

A That is correct.

Q Did you ever come across another circumstance like Lisa McPherson where an end cycle order was given and the person did not have a known, medically diagnosed by a licensed medical doctor, terminal illness?

A No. With the exception of what I told you about John Nelson, of course.

MR. DANDAR: All right. Judge, just in case it is not present, I just want to go ahead and I marked this affidavit that we’ve been talking about as Plaintiff’s Exhibit Number 126. And I’m sure you have so many copies of this already.

THE COURT: Is this the one that is 108?

MR. DANDAR: No. That is the PC folder one,


THE COURT: Oh, okay.

MR. DANDAR: This is the one that talks about end cycle.

THE COURT: All right.

MR. DANDAR: This is what Paragraph 34 of the fifth amended complaint is dependent upon. I would like to move 126 into evidence.

MR. WEINBERG: It is already in evidence, but —

THE COURT: Yes, it is in, but we’ll let it in again.

MR. DANDAR: Somewhere. I’m not sure where.


Q Now, Mr. Prince, do you recall seeing, in the deposition testimony of Judy Goldsberry-Webber and Dr. Houghton and Kartuzinski, that liquid injectable Valium was picked up twice, two separate times, at two different places for Lisa McPherson?

A Yes.

MR. WEINBERG: I object. This just isn’t proper. Do you recall seeing somebody else’s testimony? I mean, we should be asking Mr. Prince about his testimony, whatever it is, not what he recalls somebody else’s has testified to.


THE COURT: Well, if he read — just remember, Mr. Prince was his consultant. If he read some of these depositions in some fashion to assist him with his testimony, I mean, I already heard him talking about Valium which he thought —

MR. WEINBERG: Which was never given to Ms. Lisa McPherson.

THE COURT: Well, I know that. But we want to listen to what it is he says.


THE COURT: I know that. And I know Kartuzinski was the one who said, “No, we don’t use Valium.” So, I mean, I know this case a little differently from what Mr. Prince does. But I haven’t been to all of the depositions and I haven’t read all of the depositions. But I know what I know from this hearing.

MR. WEINBERG: All right.

THE COURT: And that is that Dr. whatever his name is prescribed the Valium.

MR. DANDAR: Minkoff.

THE COURT: And Kartuzinski said no. That is all I know.


Q Mr. Prince, can you tell us how it is that the


organization works where if Dr. Minkoff, as he testified, ordered injectable Valium twice for Lisa McPherson, how would the org go about procuring that Valium from a public drug store?

A Well, you would have to use — you know, Scientology in itself is a closed system to that degree because it does disagree — seemingly disagrees with psychiatric medicines, the use of psychiatric medicines.

However, in — in the case of introspection and a person that is psychotic, there are references of using drugs to treat those people.

But Scientology would only go to another Scientologist who would have that same understanding that would provide what they needed because they are kind of like on the same track. I have never seen it work where a doctor outside of Scientology would do that.

Q Well, how does the organization work to go about getting the money approved to push the prescriptions?

MR. WEINBERG: Well, I’m sorry to interrupt.  But he’s asking how Flag would have gotten the money in 1995 or whenever it was. He wasn’t there. He wouldn’t know that.

THE COURT: Well, he can testify as to what he knew when he was there.

MR. WEINBERG: In 1982? I mean, it’s just —



THE COURT: I mean, he — this is what he based his opinion on. If it had to do with 1982 we just have to take that into consideration.

A Well, there is a simple answer to the question because it’s a Scientology policy, it’s called CSW, completed staff work. Whenever the organization is expected to — is expected to finance or pay for something, a document is submitted that — to the person senior and financial persons within Scientology that explains what the situation is, what the handling of it is.

If the situation is a person is psychotic and — you know, and in need of drugs, according to this reference, and handling is to buy the drugs, and then this is okay and they sign it and that gets passed along, the drugs are purchased.


Q So it gets passed along to who?

A If it was an emergency CSW, which would be accompanied with a purchase order, if it is an emergency CSW with an accompanying purchase order, it would normally go from the person who originated the CSW, to his immediate senior, to the commanding officer or whoever that person designated to be in authority to instantly approve moneys expended by the organization.


Q And have you seen a CSW for any of the prescription drugs purchased for Lisa McPherson?

A No, I have not.

THE COURT: What was the CSW again?

THE WITNESS: Completed staff work.

THE COURT: Thank you.


Q If — if the pathologist retained by the state who say that she’s in a coma, it was obvious for five days that she wasn’t getting any better, she was getting worse, if Heather Hof, in my recollection of what she said, is correct
that she was — Lisa was getting worse as early as December 2, if that is all true, is there any other explanation that you can think of that would explain why nothing was done sooner for Lisa McPherson?

MR. WEINBERG: I object to the form of the question, your Honor, as a completely improper hypothetical.

THE COURT: Overruled.

A You know, again, I have studied for 16 years these issues, this stuff with red writing, this stuff with black writing, called staff writing; the only — this is the way I opine this way, the only reason she would have been treated
this way is because she was a threat to Scientology.

And Scientology has a principle called the


greatest good for the greatest number of the dynamics. The dynamics being the different areas of life that L. Ron Hubbard codified or, you know, decided this is the way it was.

In Scientology, the overriding principle is to protect Scientology. That is the greatest good. For her to go in a bad condition to the hospital, complain of what Scientology did to her, to create bad publicity for them, possible lawsuits, possible investigation by law enforcement because she was incarcerated, held against her will, was not anything anyone wanted to deal with.


Q How could letting someone die be less of a PR flap than taking them to the hospital while they are alive?

A Well, I think it is an empirical fact, because it wasn’t — it was virtually unheard of until a year after her death. When you do enough cover-up — I mean, you know, not until a year after her death was it even known what happened to her. So it worked for a while.

Q Okay. Let’s go to —

THE COURT: I have just got to ask a question there. And I had so many but I didn’t want to interrupt Mr. Prince.

She went straight to the medical examiner.  Right? I mean, from the hospital to the medical



THE WITNESS: Right, with meningitis.

THE COURT: Well, whatever. There is a medical examiner who is the one that determines cause of death in this city.


THE COURT: If she had been stabbed, if she had been dehydrated, if she had been shot, whatever it is, you take a dead body to the medical examiner when they are not under a doctor’s care for the medical examiner to say what is the cause of death.




THE COURT: I don’t know how long it took her to do her work. But the deal was as far as the Church would be concerned, she was delivered to the medical examiner to determine cause of death. Right?


THE COURT: So any delay was occasioned apparently by some difficulty in determining what was the cause of death. And some disagreements in sending off lab tests and all that sort of stuff. Right?



THE COURT: Okay. So — so as far as the Church is concerned, Dr. Wood or whoever was going to do the autopsy might have known what they saw in two days.

THE WITNESS: Well, I don’t believe —

THE COURT: I mean, they have no way of knowing that, that they couldn’t just cut her open, look, say, “Whoops, there is a blood clot, this was caused by dehydration.”

THE WITNESS: Well, wasn’t it after the criminal case got started that Mrs. Wood went on national TV and spoke about dehydration and all of these things? Wasn’t that —

THE COURT: It may have been. But the fact of the matter was, is within a matter of however soon they got to this body, depending on how many bodies they had —


THE COURT: — somebody did an autopsy, you know, did an autopsy.


THE COURT: Dictated findings, and eventually this was put into an autopsy report. And Dr. Wood apparently did go on nationwide TV at some point in


time later.


THE COURT: But, I mean, it still goes without saying that there would be no way for the Church to know what was going to go on at the medical examiner’s office.

I mean, gosh, they could have said she was stabbed. They may have been wrong. But there is no way of knowing, when a body is taken under unusual circumstances, anybody not under a doctor’s care, where a doctor signs off, like in a — in a — and a medical examination is done, an autopsy is done, there would be no way for the Church to know what the ultimate result was going to be.

Why, look at all of the flap now about the different autopsy reports and what have you.



THE WITNESS: I agree with you wholeheartedly.

THE COURT: So this has been my problem all along is that you talk about a bad public relations flap.


THE COURT: Well, a death, for heaven sakes, brings about a lot worse public relation than


somebody who goes to the hospital and says, “I was kept there, I didn’t want to stay and they brought me here but I want to go home and I don’t want to be here” and some charges are brought because of that.

THE WITNESS: Well, your Honor —

THE COURT: Which they can defend on the way by saying this was a religious — she was a member of the Church, this was the way we handled this. That would have been the defense.

THE WITNESS: Right. And I — and I beg to differ with you on the fact that it was more convenient to take her to the hospital as opposed to take a dead body there.

THE COURT: I didn’t say convenient. I said it would be a — it was a worse public relations flap to have had Lisa McPherson die at the hotel under the care of the Church of Scientology than it would have been for Lisa McPherson to have gotten well in the hospital, having been taken there by the Church of Scientology and had her say, “They held me there and I wanted to leave and they wouldn’t let me leave.” That would have created less of a public relations flap.

THE WITNESS: I beg to differ, your Honor. And the reason I beg to differ is again, like I say,


this person has just attested to being almost superhuman. This person has been in the community here in Clearwater. She worked on public relations, on behalf of the Flag Service Organization, setting up the Christmas dealies. She was part of the OT committee whose responsibility is to interface Scientology with the community. Lisa was not a low-profile, no-nothing nobody-person.

THE COURT: I understand that. But here we are, we are in this hearing, it is the seventh week of this hearing. This case has been going on seven years. There has been no good publicity that has come out of it, presumably, for the Church of Scientology.

All this would have been avoided if they had taken her to a hospital if it had been something that they would have known, they took her to a hospital, and had she said, you know, “Those folks were holding me against my will,” and they just said, “No, she was there on introspection rundown,” that would have been litigated, long over.

Do you think, in the long run, it would have been less of a public relations flap?

THE WITNESS: Let’s take another perspective of it. If it had gone along as Scientology planned, if


my contention there was a cover-up and they were successfully able to cover up and this girl simply died of embolism, well, who cares? Okay, well, so, you know, another dead person.

But if this person came and said, “Hey, look, I have been in here, they have held me, these people have jumped on me, forced drugs down my throat, they shoot me up with needles,” you know, I know that — that they said they never used Valium. I’m sorry, I disagree. I have been through these introspection rundowns. The instant they give that stuff — they give it to the person because they can’t sleep.

Otherwise, they are up all night. What they call it is a free will or the person simply cannot sleep so they are giving her drugs to make them sleep. Why would you get the same drug two times and not use it?

THE COURT: A person that can’t sleep is the person that is psychotic in a very hyperactive state. Right?


THE COURT: So, consequently, you would concede that Lisa McPherson was, in fact, in a very psychotic state or she could have slept just fine.

THE WITNESS: Something caused her not to



THE COURT: Right. Which, of course, if she was in a psychotic state — now we are back to that situation where it would have been fairly dangerous for them to let her walk out the door, which —

THE WITNESS: You know, as far as her being psychotic, your Honor, I feel we can only speculate about that, because she was never taken to a doctor and diagnosed as being psychotic when they say she was psychotic.

THE COURT: Then she wouldn’t have needed Valium to make her sleep, would she?


THE COURT: I mean, you can’t have it both ways.

THE WITNESS: Well, you know, your Honor, I’ll be quite honest with you. Before I came in here —

I’m tired now because I wasn’t able to sleep that well, and I’m sure this will go on until I’m finished. So I don’t know, six to one, half dozen of another to me.

THE COURT: All right.


Q Have you ever in your experience seen drugs like Valium or chloral hydrate given to a Scientologist so they


don’t leave?

MR. WEINBERG: Can we limit it to one or the other?

A No, I have not.

THE COURT: So you have never seen Valium given to a Scientologist?

THE WITNESS: Because they want to leave?

THE COURT: Because they want to leave?


THE COURT: Because they were sick?

THE WITNESS: Because they were —

THE COURT: Psychotic?

THE WITNESS: Yes, ma’am.

THE COURT: When was that?

THE WITNESS: Again, this girl, Terese —


Q Teresita?

A Teresita. Again, she, you know, literally fell off the chair and started doing her thing. And I think one day passed and she wasn’t sleeping, and immediately Dr. Dink was contacted. You could literally see her dying in front of your face. She was just burning up. It was one of the most amazing things to see, kind of like the person caves in on themselves, they just kind of fall in, you know.

And this started happening to her after she hadn’t


slept for two and a half, three days. And she came out and she was given an injection.

Q Did you —

THE COURT: Was it Valium? That is the question.

THE WITNESS: Your Honor, I couldn’t speak truthfully as to what the injection was because the doctor was there, he injected her, and I know that within an hour, hour and a half, she was asleep.

THE COURT: So in truth now, Mr. Prince, you can’t testify in this courtroom that you ever saw Valium given to someone because they either wanted to leave or because they were psychotic; you don’t know what the psychotic person was given?




Q Mr. Prince, did you have to assist Teresita in eating and drinking?

A Yes, I did.

Q How did you do that?

A I would just gently talk to her and tell her that it is important for her to eat if she wants to get well. I would tell her the case supervisor has said you have to drink X amount a day. Would you please do it? Just trying


to get her cooperation.

Q Could she do it by herself?

A No.

Q So how did you do it?

A Oh, I thought you asked me would she do it by herself.

Q Right. Did she pick up the water and drink it by herself?

A Yes.

Q And the food, did she eat it by herself?

A Sometimes I had to take a spoon and put it to her mouth and watch her chew, you know, and, “Did you eat it all,” you know. That kind of thing.

Q All right. Your opinion that Lisa McPherson died because of an end cycle order, an order just not to do anything for her —

A Correct.

Q — is that opinion based upon because you hate Scientology? Or is it based upon something else?

A For one thing, I certainly do not hate Scientology. I don’t hate anyone or anything.

My opinion is based solely on personal observation, personal experience. I give it as an opinion. I say why. Maybe I haven’t said it as clearly as I need to, but it is so important for Scientology. And, you know,


especially Clearwater is considered a hostile environment.

I mean, I have been here when half the city of Clearwater were picketing around the Ft. Harrison with Michael Flynn.

I mean, I have seen and been involved in trying to make this a place where Scientology could comfortably be and the environment would be comfortable with Scientology.

So, no, I don’t hate Scientology. I was a Scientologist myself for sixteen years. You know, I had a firm belief in what I was doing. I have since become disillusioned with a lot of that. But my motive certainly isn’t hate.

Q Now, Mr. Prince, there came a time when the Lisa McPherson Trust was formed. Do you recall that?

A Yes, I do.

Q And after you finished working for me full-time, you went to work for them full-time. Correct?

A Yes.

THE COURT: You know, on some of these things you really are going to have to stop leading him.

That is one of the issues that is an issue here. So don’t ask him a question and then say “Correct?”

MR. DANDAR: Okay. All right.


Q Mr. Prince, were you ever with Bob Minton when he talked about giving money to me for the case?


A I have been with Mr. Minton a couple of times, yes. Two or three. Yes.

Q I want to direct your attention to May of 2000.

A Okay.

Q All right?

A Yes.

Q Do you recall any incident where Mr. Minton talked to you about giving money to me?

A Around that exact time period, Mr. Minton made it known to me that you needed more money to bring this case to trial. He had thought in his mind that he had given enough money already and, you know, it could have went to trial or whatever.

But he was concerned about the repeated motion and — motions and on and on, just the cost of the case from the filings and things, that he asked me to go over there and look into, well, what is coming up now, I mean, what can we look forward to now?

I think at that time you were working on an accident reconstruction. And Mr. Garko was talking about doing a jury pool survey or something. And these were going to be additional expenses that would be needed, you know, as
well as whatever else came up to take the trial — take this case to trial.

And I remember going back and speaking to him about that. And he wasn’t very happy about that. And then


he — he — he went away — he came into town. Mrs. Brooks  and I were working at the LMT. And he came and he said, “Come here, you guys come out here,” because he had a fear that the building that we were in was electronically bugged.

And we got in Stacy’s car and we went into the city parking lot, which is directly across the street from the LMT Trust. Went to the very top where we could see.

And he said, “Look, I’m going to tell you guys, you can’t tell anybody this, Ken Dandar has more money, he doesn’t know where it came from. It came from Europe. You know, I told him, this is as much as I think I can get, I
hope this takes you to trial.”

That was in 2000. He told us that, you know, he didn’t want the office to know, you know, Ken didn’t want everybody in the office to know or whatever, but this $500,000 came. And — and, you know, everything with the case would be okay, basically, was the one instance.

The second instance was very recently, I guess in March of 2002 —

MR. WEINBERG: Your Honor, before he gets to the second incident, that happened when, the first incident?

THE WITNESS: May of 2000.

MR. WEINBERG: May of 2000?



Q Did he say where this $500,000 came from?

A Europe. People from Europe.

Q Did he say to you it was his money?

A No. He said he had arranged from some people from Europe who made this money available.

Q Did you ever see that check?

A No.

Q Okay.

A Then the second instance was recently in March of 2002. He told me that, “Ken needs more money to finish this case and get this case to trial. You know, I’m willing to arrange to get him some money, but I have a problem with some people on the Internet saying bad things about him.

Could you ask Ken if there is any way if he has influence over these people to tell them to stop. And if you do, I’ll see if we can arrange to get him some more money.”

Q So what did you do?

A So I went and had that meeting. I went over to your office and I met with you. And I said, “You know, Bob thinks that he can get more money for you but he’s concerned about this matter. And what are you doing with that? Are you connected with these people, or are you — you know, are you encouraging them to do this?” You know, we had a bit of a conversation.


And, Mmm, you said you knew nothing about it and had no control over those people whatsoever but, you know, you would do what you could to make it stop if that is what he was worried about, but it wasn’t anything you were  actively concerned in.

Q Do you know anything about the check I got after that?

A Mmm, I know at some point that you had gotten a check. And he called me and let me know that you had.

Q He did?

A Yes.

Q Okay. Did he say where that check came from?

A He did not.

Q Okay.

MR. WEINBERG: And the date of that — the date of the conversation with Mr. Dandar was, you said, March?

THE WITNESS: Of 2002. Yes.


Q Was this before, or after, I flew to Mr. Minton’s house?

A Before.

Q Okay. If I flew to Mr. Minton’s house February 22 of 2002, when would this conversation be that you and I had?

A So I think maybe a week prior.


Q Okay. Were you aware that Mr. Minton —

THE COURT: So you are saying that was February of 2002?

THE WITNESS: Yes, your Honor.

MR. BATTAGLIA: Excuse me, your Honor, what was February of 2000?

THE COURT: 2002. This is when Mr. Dandar and this witness had a conversation.



Q Now, I jumped — when you talked about that meeting, that kind of threw me off because that is two years after where I wanted to talk to you about. So let’s go back.

Do you know a fellow by the name of Patrick Jost?

A Yes. I do.

Q Okay. How do you know him?

A I know him because he was hired by Mrs. Brooks to specifically assist Mr. Minton to deal with allegations that were being stirred up by Scientology investigators in Nigeria and Switzerland.

Q What was he supposed to do?

A Mmm, Patrick Jost is multilingual. I think he speaks maybe four or five languages. Mmm, he’s also a person — ex-CIA, spent many years in Europe on behalf of


the United States defense.

So he knew a lot of people and had a lot of contacts.

And he was supposed to go and find out where the trouble was originating from and try to deal with it accordingly.

Q Do you know if he was successful in doing that?

MR. WEINBERG: Objection, hearsay, your Honor.


MR. WEINBERG: This whole thing is hearsay.


Q Did you — can you describe for us the demeanor of Mr. Minton throughout the years — almost two years that the Lisa McPherson Trust concerning the — what he perceived to be actions taken against him by Scientology?

MR. BATTAGLIA: I’ll object to that as being far too broad, demeanor over a period of two years.

THE COURT: Mr. Battaglia, much as I would like to let you object, I don’t think you have any standing to object in this hearing. This is a hearing between these two people. Your client is simply a witness. So I’ll simply ignore that.

MR. WEINBERG: You beat me to my feet because I was about to say the same thing.

MR. FUGATE: Stereo.

MR. WEINBERG: That is like asking for — I


don’t know how you ask a question like that. His demeanor over two years?

THE COURT: I agree with that. It was a little broad.


Q Did Mr. Minton ever talk to you about what he felt concerning the Scientology investigation of him?

A Many times, to answer the question. And it wasn’t even the fact that investigations were happening. It’s the false information. The false information that was being provided to government officials in different countries,  unfounded allegations that were being provided, that disturbed him more.

And over time it became increasingly more evident that this was having more and more of an effect on him.

Q How did you pick that up?

A When I first met Mr. Minton, he was probably about 40 pounds lighter than he currently is. Just the nicest, gentlest, kindest person. I mean, I had never seen a person like him before. I mean, literally, who am I? Nobody.

But a person like that to come around in your life that just was — I don’t know — genuinely concerned about other people to the point of almost fault. And very — very kind. Very intelligent person.

I seen him go from that, to — to kind of being a


person that is annoyed — kind of annoyed by what is going on, kind of — Mmm — annoyed with, you know, what is happening with his kids, you know, what is happening with his house, his phone lines, on and on.

Then I seen him go to a person that actually became very doubtful about what he was involved in, what he was doing. He seemed to be less confident as time went on that he would be able to do anything to restrain Scientology from exercising some of its practices that are detrimental to the general public at large.

Q Have you — are you familiar with the doctrine of Scientology called fair game?

A For sure.

Q Has fair game been canceled?

A No. It’s alive and well.

MR. WEINBERG: It’s what? I couldn’t hear.

THE COURT: Alive and well.

THE WITNESS: Alive and well.

MR. WEINBERG: And that is based on your —

THE COURT: Counsel, we’re going to let you ask that question later.

MR. WEINBERG: I will. I’ll withdraw it. I’m sorry.


Q Based on your expertise and experience in


Scientology, did you personally observe any fair game practiced on Mr. Minton?

A Yes. I have.

Q Can you give us some examples?

A Mmm, leaflets passed around in Boston where his wife and children live, saying that he’s an adulterous, robbed the Nigerian children — the Nigerian people of moneys, this is a starving country. And — and kind of — he’s kind of somehow aligned with the KKK because he was attacking Scientology. Mmm, his children being followed around. You know, the whole Nigeria/Switzerland thing.

They used to meet him at every airport he went to, irrespective of any city, they would just show up and meet him and picket him at the airport. I have been with him when the police literally have to stand in the airport and hold Scientologists back from attacking him.

I have been with him in Boston where somehow Scientology OSA people had gotten a hold of his — his — his records, his counseling records when he was seeing a psychiatrist. And they started saying things to him that he said to his therapist, I know, that upset him extremely that it could even happen.

And the fact of the matter is that therapist decided to no longer see Mr. Minton after Mr. Minton went


back and told him, “Hey, why are these guys saying this to me?”

Q This was a psychiatrist?

A Yes.

Q Of Mr. Minton’s?

A Yes.

Q So —

A And —

Q — he refused to see him after the records were made public?

A Correct. Or exposed. His position was exposed.

Q Okay. Did there come a point in time when Mr. Minton, in your presence, was — had any dramatic change in his emotions compared to the years that you have known him?

A Again, you know, what I said earlier. For sure, he changed. He became more of a somber person. He wasn’t as cheerful anymore. He was more serious.

And at some point it even got into, “Well, you know, they did this to me  so I’m going to go picket them. They did this to me so I’m going to go picket.”

You know, this is — was kind of like his last line of defense, as I testified the first day I came here, that he could possibly do, you know. “I’m just going to go picket. When they fool with my wife, I’m going to picket.


When they fool with my children, I’m going to picket. What they are doing over in Nigeria, doing all this crap, I’m going to go picket.”

So he became increasingly despondent about that. And, you know, Mr. Minton takes medication. Not that there is anything wrong with medication, but sometimes he wouldn’t take it. You know, he seemed to just be extremely stressed.

And during the time periods when he didn’t take his medication, he would literally be in a state of collapse with just — crying uncontrollably and totally despondent.

I remember one time he told me he was going to kill himself. He was walking around in the woods with a gun, you know. 200 acres up there where he lives and it is nothing but beautiful woods in New England and he’s walking  around with a gun. He drove his car in the woods, got it caught on a tree stump and he’s out there in the middle of the night, with a gun, crying. You know, that has happened.

Q When did that happen, that particular incident?

A That was in the fall of 2001, I believe.

Q Okay. Do you have any knowledge concerning Stacy Brooks’ desire, in the summer of 2001, to go see Dell Liebreich to get her to drop the case?

A Yes. I do.

Q What is your knowledge?

A Mmm, Scientology had very effectively convinced


the courts — and I’m not trying to cast any aspersions here — tried to convince the court that somehow the Lisa McPherson Trust had something to do with this Lisa McPherson case.

And this assertion, this stuff that had grew over the years, inextricably tied these two things together, which allowed a way to now do continuing discovery on Mr. Minton and Mrs. Brooks and other staff members that worked at the trust.

And this was something that he was very concerned about, because financially it was ruining the Lisa McPherson Trust to have a lawyer have to represent all of the staff members, you know, when they get deposed, and they’re away, and on and on and on. So —

Q Did there come a time when — well, let’s go back to the question.

Did there come a time when you had knowledge about Stacy Brooks wanting to go to Dell Liebreich?

A Yes. So because of that, you know, and there was more discovery by Scientology specifically on Mr. Minton’s finances, they were just narrowing down on that, which is pursuant to their policy here to cut off the funds, on and  on and on. They are on a systematic program.

One thing that can be said about Scientologists, they are extremely organized and they have resources to do


what they need to do.

So Stacy thought that, you know, a lot of stress was coming because of this. So she thought, well, the only reason this is happening is because of this wrongful death case. So she decided to go visit with Dell Liebreich and ask her to drop the case because of what was happening with Bob Minton. And she decided to do this without Mr. Minton knowing about it.

And she consulted me on it and asked me, “Do you think he will be extremely upset if I do this?”

And I told her that I thought he would be extremely upset, you know, without talking to you about it and just go down there because there was no relationship.

Stacy had no relationship with Dell Liebreich. So for her to now — now come out of the blue and ask her to drop the case, it would be like a woodpecker coming along, telling me to pay my house rent or something, something as bizarre as that. So, you know, Stacy decided she was going to do it anyway.

She finally asked Bob Minton. And he said, “No, you don’t do it. You don’t do that.” She decided to do it anyway. She attempted to have a phone conversation with Mrs. Liebreich. And I think at that point, after Mrs. Liebreich spoke with Stacy, she then spoke with you and refused to speak with Stacy anymore.


Q Are you aware of any instance where Bob Minton controlled the wrongful death case?

A Not at all. The wrongful death case was the last thing that Mr. Minton was interested in because he had turned it over to you, he felt you were a competent, honest attorney, and, you know, many arguments have happened  between Mrs. Brooks and Mr. Minton concerning the fact that she did not need to be involved in the case, or if there was a differing of opinion, to do what you say because you are the lawyer.

And, no, he — he — he never — Bob Minton was more concerned about what was going on at the Lisa McPherson Trust.There was a period of time, after we came into existence and actually established a phone number, that people just started calling like crazy. “Hey, can you help me with this? Can you help me with this? Can you tell me what is going on with my brother? He doesn’t speak to me anymore. Can you tell us what it means to be an SP? I need to get my money back from Scientology that I haven’t used because I have no life, I don’t have a place to live.” You know, all of these kind of phone calls. And we — we became extremely interested because after the trust was set up, it gave you a broad cross section of, well, what types of things do people need help


with in relationship to Scientology?

So our job became, well, there is nothing we can do about it. If there is a criminal activity concerned, if there is any fraud that is concerned or bad business practices, at that point we started referring people to the responsible governmental agencies.

If you have a problem with them returning your repayment money, you refer them to the Consumer Fraud Department — Department of Agriculture, Consumer Fraud. If it is bad business practices, the Better Business Bureau. If it has something to do with money — the IRS could possibly be a person to contact if they are not getting satisfaction with known policies on giving money back. This kind of thing.

And we had nothing whatsoever — and the whole reason I stopped working in your office is that we had gone through deposing the majority of the Scientologists and Scientology witnesses. And you were going on to your medical experts. So there was no reason for me — I mean, I didn’t need to sit and listen to a medical expert being deposed.

So I worked at the trust. And this is kind of what we were doing. It was kind of like when you went off doing your medical people, we just forgot about the case.

At least, I did.


Q So you actually did work at the trust in answering calls for people who needed counseling?

A Very much so.

Q You weren’t just waiting for the trial of the Lisa McPherson case to start?

A This trial — you know, as much as I’m willing to offer my services — help point out certain things, what happened with Mrs. McPherson was a very unfortunate thing but there are still a lot of people alive that needed help.

And that is where I went to — what I wanted to do.

Q What was my involvement with the Lisa McPherson Trust?

A Occasionally stop by to have dinner.

Occasionally, like maybe I think I maybe seen you there two times during its entire existence, maybe three.

Q Did I give any orders to anyone at the Lisa McPherson Trust?

A Not that I ever saw. It would be highly unusual if that happened.

Q Did I direct any of the picketing?

A No.

Q Do you know if I ever participated in a picket?

A No. You know, I was sitting here listening to testimony about that, and I listened with a sharp ear as Judge Schaeffer here mentioned the fact that you shouldn’t


have been anywhere near picketing. And I think what may be kind of misunderstood here is the fact that the vigil is not — was not and never has been a picketing experience. The vigil is where the people come from all over, they light the candles, they — they do some Bible stuff, they sing hymns and they may place a wreath where she died at the cabana. That is not a picketing experience.

And that is where I have seen you with the vigils, along with the family. And you were there because the family was there.

Q Okay.

MR. WEINBERG: Your Honor, I have an objection.

In light of Mr. Prince’s last statement, he said he understood you had said certain things during the hearing? How would he know that if he was to be  excluded?

THE COURT: I am sure he read transcripts.

MR. WEINBERG: Well, but it is —

THE COURT: It would have been what he read or somebody told him, which would be inappropriate, too.

A I think it came up on the first day when I sat here in the courtroom giving testimony where you admonished Ken and pointed that out. I heard that direction from this



THE COURT: I’m not excluding you from testifying if you read something or heard something.

THE WITNESS: Well, I’m just saying that is not the case. I heard it right here in this seat on the first day I was here.

THE COURT: You have to understand to the — to the rest of the world, if candles are being carried, signs are being carried, it is being done, the Church of Scientology — it may look and seem like a picket. A lot of folks have talked about it as being a picket.

THE WITNESS: Right. But at the vigil there are no signs, though.



Q Now, did you ever hear Mr. Minton talk about the money that he gave me as — giving it to me or giving it to the estate? Did you ever hear him talk about that?

A I have. And what Mr. Minton has always said to me is he is giving this money to Ken to use on the case at his discretion. He’s loaning the money to Ken. That is what I heard.

Q Did you ever hear Mr. Minton write or speak about the LMT or Mr. Minton getting the bulk of any of the money


that may be realized from the wrongful death case?

A The only time I heard that statement made was when Mr. Minton came back from a radio interview. And he was laughing. And he said, “Hey, you know what, I just went in there and said the bulk of the proceeds are going to go to an anti-cult group or whatever. And I know this is going to chap Scientology’s behind.” He was into that kind of tit for tat kind of thing.

Q Did you ever hear him talk about it in private or outside of the media’s presence?

A Well, you know, the particular time that I’m talking about was private, you know. And I — you know, I made the comment, “Really, you know, is that the way it’s going to go?”

He said, “Look, I’ll probably never see a dime from this stuff. I just said it.”

Q Okay. Did there come a point in time when  Mr. Minton started to express concern over the discovery by Scientology of a UBS check?

A What I recall about that, and I mentioned or made reference to it in the affidavit that I did, I guess the last one that I did, the April 2002.

He called me just in grief, crying. He’s like, “It’s over. They got me. You know, I’m going to jail.”

He’s just —


THE COURT: Can we have a date on this? You want your last affidavit? I think it was in there.

THE WITNESS: Yes, it would probably be a week prior to the meeting that happened on March 28th. So we’re talking like maybe March 21st or something like that. You know, the week prior to going to New York.


Q All right, here is the April 2002 affidavit.2

A Okay.

MR. DANDAR: Judge, do you need another copy?

THE COURT: No. I know it is in evidence somewhere. If I need to see it, I’ll ask to see a copy of it.

MR. DANDAR: All right.

A So, you know, I immediately called Mrs. Brooks and —


Q Well, let’s back up.

Bob Minton called you up, crying, saying, “It is all over.” What else?

A He said that, Mmm, “I’m going to jail. I have been told I’m going to jail. They’re coming after Therese and the kids.”

And he was just completely despondent about that.


Q And this was before the New York City meetings?

A Yeah.

Q Okay.

A Yeah. So then —

Q But he didn’t go into detail as to why he thought he was going to jail?

A No, he wouldn’t tell me then. I wanted to know, what is his new thing? What in the heck happened? What new thing has happened? He wouldn’t tell me.

Q Okay.

A Stacy, I called her to try to get additional information. She didn’t know what the heck had happened. But she knew she had to go up there. So she went up there that day.

Q To New Hampshire?

A Yes, to New Hampshire. Subsequent days, I got an idea of what happened. And it had no significance to me, I had no idea that this was a significant incident.

But he told me that Mike Rinder had somehow gotten a copy of a check, of the $500,000 check, and told him that he knew that Bob Minton lied in deposition about this $500,000 check and they had the proof and they were going to prosecute him on it.

Q Did Mr. Minton say he, Mr. Minton, also had a copy of this UBS check?


A No. He said he didn’t know how they got a copy because he can’t get a copy of it. He said, “I tried. I can’t get a copy of it.” Somehow, they come up with a copy and show him.

And he was just beside himself.

MR. WEINBERG: Your Honor, could I ask, could we point out in this affidavit where this incident is that he’s just described?


MR. WEINBERG: Because I don’t think it’s in there. They are saying something about a $500,000 check prior to the New York meetings.

THE COURT: You have your affidavit there in front of you?


THE COURT: See if it is in the affidavit, or if it is something not in your affidavit.

THE WITNESS: Okay. Okay, so here, if you turn to Page 3 of the affidavit, I started talking about what I’m explaining right now on the 20th of March, 2002.

THE COURT: What is this number?

MR. DANDAR: Paragraph 9.

THE WITNESS: Paragraph Number 9.

THE COURT: I don’t have it. Maybe I do need


it. What is the number of the exhibit and I’ll have the clerk get it?

MR. FUGATE: I believe it is attached to Mr. Dandar’s response to our memorandum of fact and law. I believe that is where it is.


MR. FUGATE: Can I give you a copy?

THE COURT: Yes, please. If you would, that would be great. I’ll give this back to you because I know it is in evidence or in the pleadings.

MR. FUGATE: It is in the pleadings, I believe, Judge.

MR. DANDAR: He’s reading from Paragraph 9 on Page 3.


Q Am I right?

A Yes. But, you know — yes, that was on Page 3, Number 9, during the time period, what I’m talking about

And before I wrote this affidavit on the attachment, when I met with Mr. Dandar, I wrote on the first page that — that Scientology had gathered enough information about Bob Minton to get him prosecuted, convicted and jailed.

MR. DANDAR: He’s looking at his handwritten



THE COURT: Oh, okay.


MR. DANDAR: The first page, the first paragraph.

THE WITNESS: Did I answer the question?

MR. WEINBERG: I asked you — I asked you, does it say in the affidavit about this conversation you supposedly had with Mr. Minton prior to the New York meetings where he told you that the Church had a copy of a $500,000 check, and he didn’t —

THE WITNESS: I don’t —

MR. WEINBERG: — have a copy and didn’t know where they got it.

THE WITNESS: I’m sorry, I don’t mean to cut you off.

I don’t mention the check specifically, but what I mention is, is the information that Scientology had gotten, information that said they were going to get him prosecuted and put in jail.

You know —


Q Paragraph 9, do you talk about the conversation — the first conversation where he’s crying?

A Yes. They discovered information about him that


threatened his wife and children’s future. You know, again,he’s suicidal. And then —

THE COURT: In your handwritten notes it appears that you are talking about this — this information before Paragraph 3 which deals with Bob Minton and Stacy Brooks flew to New York.

So I presume you were discussing — or you — your notes indicated that occurred before the New York trip?


THE COURT: I don’t think it is very clear, certainly, in the affidavit, but he says that is what he’s talking about.

THE WITNESS: Well, you know, your Honor, I really did try to do the best I could. This is a very disturbing time for me, too.

THE COURT: There is nothing that says that you have to speak to every word of your affidavit. You can expand on it. If that is your testimony, that is fine.

THE WITNESS: Thank you. And, you know, in the days between the New York meeting and the 20th of March that I noted here, which is where I came to find out, you know, what is this. Because Stacy flew there. And after she was there, I let her, you know, get settled.


And then he’s telling me, you know, they have got this check. And, you know, and he says — basically, it’s come down to me or Ken Dandar, somebody has to die here.

And I’m like, you know, this was such a complete turnaround. These are people I worked with now for years. We have all been on one accord, doing what we thought were good work. Suddenly now Mr. Minton has to turn on Ken Dandar.


Q And did you have any further conversation in that phone call with Mr. Minton?

A Well, he informed me —

THE COURT: This is the phone call before –you are saying this is the phone call before the first time Mr. Minton and Ms. Brooks went to New York?

THE WITNESS: Yes, your Honor.

THE COURT: We’re going to finish that phone call, then we’ll take a break.


MR. DANDAR: All right.

A Yes. He said he didn’t feel safe about discussing the information over the phone, he was too upset to talk about it.


MR. DANDAR: All right.

THE COURT: Did you say this was about a week before the trip to New York?

THE WITNESS: Yes, your Honor. I said on or around the 20th of March. And the trip to New York was the 28th of March.


THE WITNESS: The 28th and 29th of March.

THE COURT: Let me just say this about affidavits. They wanted me to sign an affidavit of borrower to buy my house. And I refused to sign it without — I said, “I’m not going to sign this without this and this and this and this.”

And finally they just said, “Well, we’re going to throw it out. It is not that important.”

I said, “Well, good.”

All this, and affidavits. It makes me very nervous. You know, some things might not have made me so nervous.


Q Anything else on that phone call with Mr. Minton before we take our break?

A Mmm, you know, again, starting on March 20th until they actually went to New York, there were many conversations. You know, I don’t want to give the illusion


this just happened one phone call and suddenly they were in New York.

THE COURT: Let’s go ahead and break and then we’ll start with — if you want to go into the other phone calls before New York. All right?

MR. DANDAR: All right.

THE COURT: We’ll be in recess until 3:15.

(WHEREUPON, a recess was taken from 2:55 to 3:15 p.m.)

THE COURT: All right. You may be seated.

MR. FUGATE: Your Honor, before we begin back again, on May 13, 2002 we had filed a request to produce to Mr. Dandar for all financial records of payments to Jesse Prince, including bank records and checks, all W2s, 1099s, and any other tax form issued from Dandar & Dandar for Jesse Prince for tax years 1999, 2000 and 2001. It was never responded to.

I think it is now relevant, based on the testimony elicited, that that be produced, or at least responded to that was filed May 13th of 2001 (sic).

MR. DANDAR: Didn’t we respond to that?

THE COURT: Had you responded to this?

MR. DANDAR: We produced at the time they took


Jesse Prince’s deposition — he’s no longer working for me — all of the W2s, 1099s, all of the checks we wrote. We did not respond to that one.

THE COURT: Is there anything additional?

MR. DANDAR: I’ll have to check. I’m sure — you know, since I brought him back on board as my expert, yes, I paid him since then. So there is something additional. But not back on May 13.

THE COURT: You don’t need him to regive you what he has already given you.

MR. FUGATE: No, I’ll go verify what we have and compare that to what he gives us. But — but he needs to respond. And he needs to give us —

THE COURT: I’m not going to require you to give him what he gave you already. So if he gave you stuff for the depositions —

MR. FUGATE: I’ll check that tonight.

THE COURT: Then you must give him whatever else there is.

MR. DANDAR: I will.

THE COURT: Try to have that to him by the morning. All right?

MR. DANDAR: All right.

THE COURT: You may continue.



Q Okay, Mr. Prince, following that telephone conversation, which you said was on or about March 20, 2002 with Mr. Minton, did you have any more conversations with him before he went to see Mr. Rinder and Mr. Rosen in New York City?

A Yes, I did. I may have had maybe three to four conversations with Mr. Minton and Mrs. Brooks concerning this. Yes.

Q Before the New York City meeting?

A Yes.

Q And what was your relationship with Mr. Minton at that time?

A Mr. Minton was a good friend of mine. A person that I trusted. You know, we worked together.

Q Okay. Did he confide in you?

A Yes. On some things, he certainly did.

Q And some things, he didn’t?

A I can’t say that he confided in me on everything. But I know some things he did.

Q All right. For instance, when he talked about somehow this check was going to make him and his wife go to jail, did he confide in you what it was that they got — this new thing in the year 2002 that caused him to think he was going to go to jail?


A You know, he said that they got a copy of that check, that — Mmm — that he — you know, had given different testimony, I think, in a deposition or something.

And this is what was going to — this is how they were going to put him in jail for perjury.

Q And did he — all right. Did he go into more detail how that was going to be perjury?

A Because he said that he had given testimony contrary to — you know, in other words, this check, this $500,000 check, came from him, apparently, not people from Europe. Scientology had discovered that. And they were going to use it to get him convicted for perjury.

Q Did you ask him why he lied to you and told you that check was from people in Europe?

A You know, that was a very good question that I should have asked. But at the time this was all new news to me.

He’s telling me, you know, “Oh, well, it came from me, it didn’t come from him. Now I’m in trouble and now they are getting ready to depose my wife Therese and bring her in on all of this stuff.”

And in the heat of the moment, the panic of the moment, I’m sure I didn’t ask, you know, all of the right questions. But no, I didn’t ask him that specific question.

Q During those three or four other telephone calls with Mr. Minton before the New York meeting he had with


Mr. Rosen and Mr. Rinder, did Mr. Minton tell you how it was that Scientology can find out that this bank check from UBS that doesn’t have his name on it came from him?

A The only comment he said was he had no idea how they possibly got a copy of that check because he himself did not have a copy, nor did he know how to obtain a copy.

Q Did Mr. Minton ever mention to you anything about Swiss prosecutors during — before the New York meeting?

A Yes, he did. He told me that there was yet another action being contemplated by a prosecutor in Switzerland. And it was my understanding that this had something to do with Nigeria but I’m not sure. You know, I don’t know the details of it.

Q And he told you this in March before the New York meeting?

A Yes.

Q Now, isn’t it true that before Minton called —

MR. WEINBERG: Object to the form to the question, “Isn’t it true.”

THE COURT: Yes, “isn’t it true” is suggesting that the answer to that is yes. I mean, I don’t know what the question is, but I know what the answer is. That is what the leading part is.


Q What was your understanding, Mr. Prince, of the


status of the Swiss prosecution concerning Mr. Minton prior to Mr. Minton’s frantic calls to you in March of 2002?

MR. FUGATE: Objection, hearsay. Or at least the basis for this statement, “What was your understanding.”

THE COURT: If it came from Mr. Minton, he can answer. If it came from somebody else, then I am not sure you can answer.


Q From Mr. Minton.

A Mr. Minton told me they were going to prosecute, going to file charges.

THE COURT: In Switzerland?



Q When did he tell you that?

A Mmm, at one of the phone conversations between the 20th and 28th of March.

Q Well, my question is prior to that, had you ever heard from Mr. Minton about Swiss prosecutors?

A Oh, yes. I mentioned that before.

Q Right. And what was the status of the Swiss prosecution prior to you getting this call —

A These phone calls? Oh, I thought it was over.

Q What made you think that?


A Because Patrick Jost had went over there and talked with people.

There was one other thing that was pending which, when Scientology got the bank records for the Bank of America, somehow the Bank of — someone in the Bank of America in Europe, some executive or some banking official, had did something that was improper concerning either divulging or passing along information about Mr. Minton’s accounts. And Mr. Jost was over there to pursue that.

MR. WEINBERG: Objection. Hearsay as to any conversations with Mr. Jost or anybody else. If he’s saying this is something Mr. Minton said, I would appreciate if he could date it.

THE COURT: Is this something you learned from Mr. Minton?


THE COURT: Okay. Could you tell us about when that was?

THE WITNESS: Mmm, gosh. This — this would have to be in the fall of 2001. Maybe October, something like that.

THE COURT: As best you can remember?

THE WITNESS: As best I can recall, yes.


Q All right. What was it the Bank of America


official in Europe did improperly, according to Mr. Minton, what he told you?

THE COURT: Does this have something to do with this Swiss prosecution?

MR. DANDAR: I don’t know.

A This has something to do with when the bank records were obtained by Scientology here, the Bank of America somehow simultaneously did something — something happened in Europe, as well. I think they used the fact they had these records to get information that they were not supposed to get, they made it appear like the Court sanctioned them having this information or it was proper for them to get the information, when it was not.


Q How did Mr. Minton react to them getting this information in Europe?

MR. WEINBERG: Objection. Your Honor, this is hearsay based on hearsay. It is speculation. Then the question is how did they react to the Church supposedly getting this information in Europe? What information in Europe? What is he talking about? This is just hearsay.

And, you know, Mr. Minton testified. Mr. Dandar had an opportunity to ask Mr. Minton about this. He didn’t say anything about this,


about this accusation or anything like this. He didn’t even ask him the question.

THE COURT: Overruled. This bears on Mr. Minton’s state of mind, anything Mr. Minton may have said about what he thought was going on, what the Church knew. Remember, we had a lot of this, as I tried to explain.

MR. WEINBERG: I object more to the form of the question. When he said the Church did such and such at such and such a time, it is just an improper form, I think.

MR. DANDAR: It is based on the witness’s answer.


A He was very distraught and upset that this had happened. You know, he felt like that there was no one that could be trusted or no one who was impervious to Scientology’s ability to penetrate and get information that they should necessarily have.

MR. WEINBERG: Your Honor, just for the record, so we are talking about now the fall of 2001 that he’s distraught?


THE COURT: Is this —



THE COURT: The same October period of 2001?

THE WITNESS: Yes, your Honor.


Q And even — did you have any conversations with Mr. Minton in January or February of 2002 before you had this — what you described as this March 20 — the first call in 2002?

A Conversations concerning?

Q Mr. Minton’s well-being, his mental state?

A Well, Mr. Minton — back in the fall of 2001, we decided that we could no longer operate the Lisa McPherson Trust. He was quite despondent about that. He was despondent about what to do with the people that we were either in the process of servicing or starting some — something with new people that were calling. And plus the phones just never stopped ringing.

So he was distraught over the fact that it wouldn’t be there anymore. He was distraught over the fact he felt Scientology had successfully caused the Lisa McPherson Trust to no longer exist because of a misunderstanding, that misunderstanding being that it was somehow inextricably tied into the Lisa McPherson case.

Q Did Mr. Minton or Ms. Brooks order you to quit being the expert for the estate?

A Ms. Brooks asked me to — and this, again, is in


the fall of 2001 — to not be an expert in this case on the theory that anything — we were trying to sever any real or imagined ideas that the Lisa McPherson Trust was connected with the ongoing litigation.

Q And did you listen to her?

A No. I — I — I consulted Bob about that. I had a conversation with him.

And he told me that Mrs. Brooks was very upset about the discovery that was going on, particularly the finances. And — Mmm — this is why she was doing it. And he understood why she was doing it.

And — Mmm — what he said, you know, “If Ken — you are Ken’s expert. If he’s going to need you, you know, I’m sure you’re going to go and do what you have to do.”

MR. WEINBERG: Could we date that, your Honor, when that conversation took place?

THE WITNESS: Mmm, I think we were speaking about late 2001/early 2002. Maybe January, around there. This is as close as I can place it.


Q Well, prior to that, you filed or signed an affidavit dated September of 2001 withdrawing as the expert for the estate.

A Okay.

Q So was this conversation with Stacy Brooks before,


or after, that affidavit?

A Preceding that.

Q So it was before that?

A Correct.

Q All right. And in that affidavit — do you recall that affidavit when you withdrew as the expert?

A Not particularly.

Q No?

A I mean, I have a general idea.

Q What is your general idea of why you withdrew as the expert?

A Mmm, again, this was during the time period when the Lisa McPherson Trust was in the process of closing. The trust itself had literally been drained of operating funds for, you know, paying lawyers. This wasn’t anything that we ever anticipated or budgeted for. And it became the most expensive part of the operation, which was trying to step away from this case. And that is what I remember about it.

Q Let me show you your signed affidavit September 21, 2001 and see if you can identify that.

MR. DANDAR: Judge, do you need another copy of this?

THE COURT: No. No. This is the one I remember quite well.

MR. DANDAR: All right.


MR. WEINBERG: Excuse me, is he impeaching Mr. Prince with this affidavit now?

THE COURT: I don’t know if he’s trying to refresh his memory or what.

MR. DANDAR: Refresh.


Q First of all, is that your affidavit?

A Yes, it is.

Q Did you prepare that affidavit?

A Yes, I did.

Q Did you sign it?

A Yes, I did.

Q Is that the affidavit that you signed concerning the reasons for your withdrawal as the estate’s expert?

A Yes, it is. And, you know, I remember because I was talking about now the trust was closing, there were no lawyers — I mean we just couldn’t afford to pay lawyers anymore.

I personally cannot afford to have a lawyer to come in here and do activities like you are involved in or represent me or — or be here on my behalf. I have a family. I have people that are totally innocent to this and could care less.

But my family was threatened with the Scientology operation that was wrought on me to plant drugs in my house


and get my house raided by the DEA, and try to get multiple charges put against me. And now I’m losing my job, too. There is no way that I could continue this activity without being able to see that my family would be safe and cared for.

Q Did you continue to receive income from Bob Minton or Stacy Brooks in the fall of 2001?

A Yes.

Q And the income you received in the fall of 2001, was that from Stacy Brooks individually, or from the Lisa McPherson Trust?

A I think it was probably Ms. Brooks individually.

Q Okay. What about 2002? Did she continue to pay you?

THE COURT: When did — when did LMT close down again? I have been away from this awhile and some of the details are out of my mind.

MR. DANDAR: It closed in August.

THE COURT: Of 2001?



Q Well, you tell us, Mr. Prince, instead of me.

What was going on in the LMT in the fall of 2001?

A They were closing — wrapping up, closing down, terminating the operation. Mmm, there was an order to allow


a magistrate to come in and go through the personal files and records at the trust. So for a month or two it was kind of kept open for that reason alone, just to finish that. So that — you know, there was an extensive library that —
that library had to be shipped, cleaned — the building had to be cleaned up and prepared to be sold.

It became our responsibility to ensure that the building did get sold. I had a verbal agreement with Mr. Minton, because at that point I didn’t have a lot of money either, that if I sold the building, I would get  25 percent of whatever the building sold for so that I could move — I was in the process of leaving Clearwater. My house was on the market. We were finished — the trust was over. We were finished.

I mean, if that is what Scientology wanted, they had accomplished it. It was finished. We were all moving.

I put my house on the market, put the building on the market, we were trying to sell it. We’re — we’re done. But it is never done, I guess.

Q Back to 2002, do you believe — have we exhausted your conversations with Mr. Minton or Stacy Brooks prior to the New York City meetings?

A The only additional things —

THE COURT: I just dread the thought of asking this question, but are you suggesting there is some


agreement between you and Mr. Minton regarding the sale of real estate, as to your receiving proceeds from it?

THE WITNESS: Yes, your Honor.

THE COURT: I see. Is there a lawyer in the room that wants to take that on a contingency? Probably not, Mr. Prince.

Okay. Continue on.

THE WITNESS: You know, I missed the point. I guess you’ll explain it to me later.

MR. DANDAR: That is all right.

THE WITNESS: I hate to miss the punch line.


Q So anything else about these phone calls, before we get to the New York City meeting?

A Well, the only other thing I think I covered in my affidavit that Mr. Minton said is, you know, after having conversations with Mr. Rinder, that it basically boiled down to who is going to die? Is it going to be Ken Dandar? Is
it going to be me. And I —

THE COURT: Is that the word he used, “die”?

THE WITNESS: Yes, your Honor. And for the life of me, you know, I couldn’t get a concept of what he was saying. I mean, he said it several times —


THE COURT: Is this — I’m sorry, my mind is off on agreements and it is kind of an insider joke that has nothing to do with you really, a lot of agreements we’re talking about in this particular hearing, and we teasingly asked about what lawyer would take what on a contingency fee.

THE WITNESS: Oh, okay. So nobody wants my opinion.

THE COURT: Well, it will be volunteered, Mr. Prince.

Was this before or after the New York meeting, this conversation?

THE WITNESS: This was before the New York meeting. This is after Ms. Brooks arrived.


THE WITNESS: He was telling me that, you know, that somebody has to die.

And, you know, Bob has always come to me, when he wanted to interface or maybe know something from Ken, he’s asked me, you know.

So for the life of me, I couldn’t figure out how is it now that suddenly we sit here today and we have to decide who dies. Why does anyone have to die? That was my question.

And — Mmm — he told me that for them — for


him not to go to jail and be prosecuted — and he had actions going in both cases in front of both judges, Judge Schaeffer and Judge Baird — that he somehow had to make this case go away, the Lawrence Wollersheim case go away, and that is — he said, “That is all — that is what they said they want.

So we’re going to go talk about that.”


Q In New York City?

A Yes.

Q All right. And — all right. Anything else, before we get to New York City?

A That — Mmm — Stacy was just adamant that she would be able to successfully settle with Scientology so that they would disengage Bob Minton, because he was literally being driven insane. He was terrorized into a state of mind that was beyond anything he was capable of dealing with.

THE COURT: Did you ever ask him what — when he used the word “die,” whether he was — I mean, we all say, “Oh, I’m just going to die if such and such happens.” But he was not using that word in a literal sense, that was a —

THE WITNESS: Well, I asked him later about this.



THE WITNESS: After they came back from New York and was in the hotel, what was he talking about.


THE WITNESS: And what he was talking about was saying that Ken Dandar, as one thing, perjured — you know, blamed the perjury on Ken. I mean, these are all things to do to get rid of the case. Okay, so now we made Ken responsible for any perjury that Bob Minton did. Then, you know, he mentioned about what’s going to happen is Mr. Dandar is going to be disbarred.

And I took it a step further. I said, “Well, if Mr. Dandar gets disbarred, he’s going to lose his business. If Mr. Dandar loses his business, he’s going to lose his home and his family. Is this really what you want for Ken Dandar after you built him up all of this time, and now you get in trouble and now this is what we do?”

THE COURT: So, again, I think my question was is we all tend to use the word “die” and we don’t really mean it literally, drop dead, I mean, die.

THE WITNESS: Oh, yes, I don’t think —

THE COURT: He meant either business-wise or



THE WITNESS: Professional decease, to cause decease, which is in accord with one of the Scientology policies we have gone over here.


Q Is that known as fair game?

A No. It is called the Scientologist’s Manual of Dissemination, where it talks about, if possible, of course, ruin the person utterly.

Q Let’s get to New York City. Did you have any conversations with Bob Minton or Stacy Brooks about the New York City meeting with Rosen, Rinder and Yingling?

A Yes, I did. When they were traveling to New York City, I was traveling to Memphis, Tennessee to drop my family off. It had just reached a peak for me. And I just wanted to have some safety in my life.

So they called me when they left home. They called me when they arrived. They called me when they met, had the first meetings. They seemed somewhat hopeful. Then, of course, the next day happened.

But when they got there, you know, Steve Jonas arrived. They were there. They met. They went over what they wanted. And Bob — you know, one of the things Bob did, which I didn’t know he was going to do until he got to New York, is he said he wanted my house to be able to be


sold, because I had had my house on the market for some time, zillions of people were coming there. And, you know, unfortunately, it just didn’t sell.

So he thought that that may have had some Scientology influence. And the reason why I think he thinks that, because the realtor for our building —

THE COURT: He? This is Mr. Minton again?



A The realtor for the building in downtown called Mr. Minton while he was in New York and told him he had had a buyer for the LMT building, and this buyer was a person that sold furniture, sold used furniture.

And he mentioned this potential buyer — this potential buyer mentioned to his clients, current clients, that he was going to move his operations to this building, and would that be okay, would he still be able to service them.

And he came back and said he found out that 45 percent of his clients were, in fact, Scientologists.

And he was told in no uncertain terms that if he moved into that building, that they would no longer do business with him. So —

MR. WEINBERG: Your Honor, I object.

A He couldn’t — he couldn’t —


MR. WEINBERG: This is hearsay on hearsay. This is supposedly what Mr. Minton said that somebody said.

THE WITNESS: No. Mr. Minton said to me that the realtor —

MR. WEINBERG: Said to him. Objection, double hearsay.

THE COURT: I do understand. But, remember, this has to do with Mr. Minton and whether Mr. Minton has lied or whether Mr. Dandar is lying.

Mr. Minton’s state of mind, therefore, becomes, to some extent, relevant.

I understand it is double hearsay. I understand what that means. But I’ll allow it. It is a very unusual hearing.



Q So when did you first hear back from Bob Minton concerning the first day of the New York City meeting on the 28th?

A The night of the 28th after they met. He said, “Well, we met.”

I spoke to Stacy. She said, “I think it is going to be okay. I think we’ll be able to work this out. Ken Dandar is not going to be happy.”


Mmm, you know, I said, “Okay,” whatever that meant, because, you know, I’m not really tracking. I just know something traumatic has happened, it has to do with some information that came up on Bob, and I know that now Stacy Brooks and Bob Minton are in negotiations to disengage this whole thing, and I am not there but they are calling me, telling me what is going on.

Q Did they tell you why I would not be happy?

A Whew. Because they were going to say that you caused Bob Minton to lie about the check — that you advised him to lie about the check. This was during that particular time.

THE COURT: Is this Ms. Brooks testifying — or Ms. Brooks telling you this? Or is this Mr. Minton telling you this?

THE WITNESS: You know, it is kind of a bit of both, your Honor.

THE COURT: Was this over the telephone?


THE COURT: This was after the first New York meeting?

THE WITNESS: This was the night of the first day of the meeting on the 28th.

THE COURT: Of March?



THE COURT: It was this night they were explaining to you — either Bob or Stacy, or both of them, on the phone, explaining why Ken wasn’t going to be happy?


THE COURT: Okay. Go ahead.


Q Now, Mr. Prince, I want to make sure you don’t have your dates mixed up. Could you look at your affidavit to refresh your memory and make sure you have your dates down when you first mentioned that Ken Dandar wasn’t going to be happy.

A Okey-doke. Okay, I’m looking at my affidavit —

Q By the way, who typed that affidavit?

MR. WEINBERG: Your Honor —

THE COURT: Just a second now.

MR. WEINBERG: I object to this process. He has done this a number of times. He elicits testimony. Mr. Prince testifies, he’s very specific, he had this conversation.

Then Mr. Dandar takes his affidavit and says, “Well, look at this and see if it is really your testimony.” He’s impeaching him.

MR. DANDAR: Well —

MR. WEINBERG: I don’t think it is proper.


THE COURT: I think that I’m — I have heard his testimony. I think he can look at his affidavit and see if it refreshes his memory. If it does, I’ll just have to remember his testimony was different before it was refreshed with this


A Yes. Okay. I talk about the problem with the checks. We talked about that again. This was the next day on the 29th — now, wait a minute. “Bob told me he called –” now, see, this is before they went to New York, “Bob told me he made — ”

THE COURT: You are going way too fast.

A “Scientology was going to put him in jail.”

THE COURT: What page are you on, please?

THE WITNESS: I’m on Page 3. Bottom of Page 3, Line 27 —

THE COURT: All right.

THE WITNESS: — and 28. “Bob said there was a problem with some checks he had given to Ken Dandar.”

That was the —


Q That is before the New York trip?

A Yes. Okay, so they arrive in New York. “The next


day, on the 29th, the next day around noontime,” I’m on Page 4, Line 10, “Stacy called me. She was upset. Bob was going to jail for contempt in front of Judge Schaeffer, going to jail for perjury in front of Judge Baird. At this point they had only mentioned to me about the wrongful death suit and the Wollersheim suit having to be dismissed for Bob not to go to jail. Mr. Rinder –”

THE COURT: You don’t have to read out loud.

You really are looking to see when it was that — if this — if this refreshes your memory as to when this statement about why it was that Mr. Dandar would not be happy.

MR. DANDAR: Right.


Q When did that first occur?

THE COURT: When it occurred.

A Either the 28th or the 29th, one of those two days.


Q Okay. And then again I want you to look at your affidavit —

A And, you know, this information was sketchy because I didn’t get the full picture until they came here to Florida. I wasn’t able to divine the full picture until they actually came back from that meeting.


Q Okay.

A Now —

Q Do you recall — do you recall that Mr. Minton called you up, after the second day of the New York City meeting, to talk to you about a phone call he received from Mr. Rinder?

A Oh, after they got back from New York?

Q Right.

A Yes — well, no. Stacy is the one that I spoke to.

Q What did she say?

A She said, after they got back from New York, they were all upset and thought they wouldn’t be able to negotiate with Mr. Rinder and Mr. Rosen.

Q Why? Why wouldn’t they be able to negotiate?

A Because they told Mr. Rosen and Mr. Rinder flat out that they had no influence to get either of these cases dismissed or made go away or whatever, they had no authority to do that; that Stacy Brooks had already made an attempt to contact Dell Liebreich to get her to drop the case, so she wasn’t interested in hearing from Stacy; and Mr. Wollersheim certainly — and Mr. Leipold were certainly not interested in dismissing their case, either.

THE COURT: When — now, I’m so confused, and I haven’t read your affidavit in some time so I’m


listening basically to your testimony.

You indicated — what I think you just said is Ms. Brooks told you on the telephone that she had told Mr. Rinder that they didn’t have the proper influence to get the case dismissed?

THE WITNESS: See, I’m totally screwing this up if you think that, your Honor, because what I’m saying there is that happened in New York where they were face-to-face with Mr. Rinder, with — at least this is what was relayed to me by Stacy and by Bob on the phone conversation when they left the office, I think it was about noontime on the 29th where they tried to make it clear that they had no influence over these cases and they were asking them to do something they were not able to do.

THE COURT: What confuses me, if I did understand your testimony, after the New York meeting, perhaps the very night of the New York meeting, Stacy called and — Stacy and/or Bob called and said, “I think we’re going to be able to work this out.”

THE WITNESS: Yes, that was after they came back to New Hampshire, left New York, because they were back in New Hampshire that day.



THE WITNESS: It was either that night or the next day I spoke to Stacy Brooks, and she said she had received a second conversation from Mr. Rinder, who mentioned that he thought that there may have been a misunderstanding, while he understood that they legally — or, you know, weren’t plaintiff or defendant, had no standing to effect these cases one way or another, that there were things that could be done to get the same result.

THE COURT: This was another conversation with Mr. Rinder and Mr. Minton or Ms. Brooks, when they told you about that, that is when they said, “We think we can do something but it is not going to make Ken Dandar happy”?


MR. WEINBERG: Would that be on the 29th, your Honor?

THE COURT: I believe.

THE WITNESS: The 29th or the 30th or such a date of this.




Q When did you get the details about what that meant about Ken Dandar not being happy?


A When they traveled to Florida for the Judge Baird hearing that was, I think, occurring on April 5.

Q That is Judge Schaeffer.

A Hmmm?

Q Judge Schaeffer was April 5?

A That is right. Judge Schaeffer was April 5. But they had a Baird one right the next week or whatever.

Q Right.

A Anyway, when they came down for that activity, then we had a meeting at the Harbour Bay Hotel in Tampa, Florida where they made it clear to me what was happening here.

Because I asked them, “Did you find out what these things were that you can do to make these cases go away?”

I’ll start with Wollersheim because that will be quickly.

Q All right.

A She said what she had already done and told Scientology she would do and had done, that she called Dan Leipold and told him to withdraw her testimony — her affidavits in the Wollersheim case, and she had instructed him to do the same for my affidavits.

And there was only three, Vaughn Young, Stacy and me. Vaughn Young, because of his physical condition, how upset he would be to even do that, she told me she had not


promised Scientology anything in relationship to Vaughn, but she could promise the relationship to me and her.

Q How did you react to your affidavit being withdrawn?

A I was shocked. I was like, “I’m not withdrawing my affidavit.”

Q Why did she want to withdraw her affidavit?

A Because these are the things that she could do — you know, they want — they want what are the things you can do? What you can do is take your testimony out. Take Jesse’s testimony out of there. Because there was only three witnesses that they were using on the issue of alter ego to claim the judgment.

Q Did you ever —

MR. WEINBERG: Before — could we just date that? Is that at Harbour Island? Is that what you are saying? Could we just date it?

THE WITNESS: I think I dated it in the affidavit.

THE COURT: You want to look at your affidavit and see if you can find it then?

THE WITNESS: Okay. Okay. Yes, Page 5, Line 11.


Q What is the date?


A If you look at Line 22, he starts talking about things that could be done.

THE COURT: Line 22?

THE WITNESS: Yes. Where it starts talking about things that could be done.

THE COURT: And that is where you use the phrase, “Ken Dandar was not going to be happy”?

THE WITNESS: Right. So when we met at the hotel, you know — and I’m doing the best job I can here — I asked them — they mentioned about getting the affidavits out of the Wollersheim case, then specifically here in the wrongful death case — “Well, what are you going to do with that?”

“Well, Mmm, we’re going to –” they had a couple of things they were going over. One, the perjury of the check to make it seem like it was Ken Dandar’s fault. And then they were insistent about some meeting that had occurred which included myself, Dr. Garko, Stacy Brooks, Bob Minton, Mr. Dandar, where we were discussing adding Mr. Miscavige as a party, and how Ken Dandar had instructed Mr. Minton to say the conversation never happened, something about it never happened.

Now, you know, for me, I’m not understanding


this because it is not making a whole lot of sense why it would matter one way or another. You know, I’m not a lawyer, I’m not a criminal, I didn’t understand what they were talking about. But those were two things specifically that they mentioned bringing out about Mr. Dandar and connecting him with perjury.

THE COURT: One was the check? Is it the $500,000 check that you testified to previously?

THE WITNESS: Yes, your Honor.

THE COURT: Number two was some meeting that occurred dealing with adding Mr. Miscavige as a party?

THE WITNESS: Yes, your Honor.


Q Was there anything else of how they were going to get Ken Dandar, besides these two items?

A Well, the only other thing that came up — I knew about those two things. But then they had the meeting with Judge Schaeffer where Bruce Howie did something, and the whole thing was moot. And they were happy about that.

I think maybe that same day he got served with the Armstrong suit. And he told me, “It’s not over, I still have got to go in front of Judge Baird.”
Now, I think at that same time the decisions came


down from the 2nd — from the appeals court concerning discovery issues with finances and this, that and the other thing, so it was kind of like things were turning around.

So I’m questioning them, “Do you really think you need to do this?”

And they are trying to elicit my cooperation, like we used to have this thing amongst us, me, Stacy and Bob, we called ourselves the A team. There was three of us, this is an A team activity. It is tough at the top, we have to make some hard decisions here, you know. So I’m part of that entity. So we’re discussing these matters. And, Mmm —

MR. WEINBERG: Your Honor, is this all one conversation? Does it mean it happened after your hearing on April 5?

THE COURT: I’m not real sure.

MR. WEINBERG: All right.

THE COURT: Was this all at the same conversation?

THE WITNESS: Mmm, your Honor, maybe not because, I mean, I was with them the whole time and, you know, Page 5, starting at Line 11 — 16, Number on the affidavit, I talked about the time periods we were there, the 2nd or 3rd of April through —

THE COURT: Did you try, in your affidavit, to date the time frames when these conversations took


place as you remembered them?

THE WITNESS: Yes, I did. I sat there with a calendar and I did it as best I could.

THE COURT: Okay. So those are the dates as best you can recall?

THE WITNESS: As best I can recall.

THE COURT: All right. So whatever it says in the affidavit is the best he can recall.

MR. WEINBERG: All right.

THE WITNESS: Yes, that is the way I sat and worked on it.

MR. WEINBERG: I was really more asking whether this was one conversation or he was — he talked about a conversation in the Harbour — I think he meant Harbour Island Hotel, but —

THE COURT: It depends what the affidavit says.

MR. WEINBERG: All right.

THE COURT: Is that right, Mr. Prince?

THE WITNESS: Yes, your Honor.

THE COURT: The affidavit speaks of these things that you have been talking about in different conversations. That would be your testimony if you refreshed your memory?

THE WITNESS: Yes, your Honor.



Q So your memory was better when you wrote this in April than it is in July?

A For sure.

Q In your affidavit you say Harbor Bay Hotel. That is not Harbour Island Hotel. Do you know where the Harbor Bay Hotel is?

A No, I guess not if I am confused about it. It is the one that has the restaurant in there — well, that means nothing, they all have. Okay, I’m sorry, I spoke out of turn.

Q All right. But what I’m saying, when you took the time to sit down and write your affidavit of April 2002, of course you weren’t under pressure, being examined in front of a judge in a courtroom. You said you had a calendar in
front of you?

A Yes.

Q Okay. Now, let’s jump back again to New York City. All right?

A Okay.

Q Well, no, I’m sorry. Let’s go to the conversations you had with Bob Minton and Stacy Brooks about New York City.

Did they tell you what type of things Mr. Rosen said to Mr. Minton at the New York City meetings?


A That he was going to jail and actually spoke with him quite loudly about this. That he was going to jail. He was going to be prosecuted in front of Judge Schaeffer and Judge Baird.

Mmm, by giving the affidavit, I wrote either Bob — Mr. Rinder — he told me — Bob Minton told me specifically Mr. Rinder said, you know, “Bob, you know I’m f-ing you but I’m doing it to your face. You have people around you that are doing it behind your back.”

And he mentioned the people that were doing it behind his back being yourself, Patricia Greenway and Peter Alexander.

Q Did there come a point in time when Mr. Minton showed you any documents that he received from the Church of Scientology?

A Yes. This was when they had — yeah, now this is after I actually attended the Judge Baird hearing, saw Bob get up on the stand and start lying, and left and went to —

Q All right, I probably jumped the gun. And I apologize. Let’s go back.

Before we get to the Judge Baird hearing, let’s make sure, as far as you can recall today, what transpired when Bob and Stacy came to Florida.

A The first time they came to Florida, they were concerned about the hearing in front of Judge Schaeffer.


They were meeting with Bruce Howie. They were continuing to meet with Scientology, working on the things that could be done to get these suits dismissed.

And I guess part of it was to elicit my cooperation to go along with this new plan to disengage Scientology from Bob Minton.

Q Okay. And did Mark Bunker come with them?

A Yes.

Q And Mark Bunker, did he stay at your house?

A Yes, he did.

Q Did anyone else stay at your house?

A No.

Q All right. So did you attend the deposition of Mr. Minton on April 8?

A No, I did not.

Q All right. So the first time you saw Mr. Minton testify was before Judge Baird?

A Correct.

Q All right. And you said that you sat in the audience?

A Yes, I did.

Q And what did you hear Mr. Minton say you thought was a lie?

A Mmm, something about Mr. Dandar making — telling Bob to perjure himself in relationship to the checks.


Q All right. How did you know that was a lie?

A Because if that would have happened, I would have known about it when it happened. You know —

Q Why is that?

MR. WEINBERG: Objection, your Honor. I move to strike, “if that would have happened, I would have known about it when it happened.” How is that a response?

MR. DANDAR: I’m asking him to explain it right now.

THE COURT: Yes. Overruled.

A If there had been some agreement between Mr. Dandar and Bob Minton to hide the fact that — the check, I would have known about it when it happened.

THE COURT: Are you saying that Mr. Minton would have told you?

THE WITNESS: Yes. That is what I’m trying to say. He would have told me when it happened. Now, this coming up after all of this time, when I’m sitting there and he — you know, he’s taking us up to the garage when he gave the check, he’s saying this stuff is coming from Europe and you don’t know where it is coming from, on and on, now suddenly he changes his mind, I knew it was a lie.

Or he told me — one way or another, he’s lying now.



Q All right. What was the next thing he lied about before Judge Baird?

A I just got up and just walked out. I couldn’t take it. I couldn’t believe what was happening. I was extremely distraught.

As I say in my affidavit, I actually wept because — you know, because once again we see the big Scientology machine, with all of its high-priced lawyers and endless resources, endless staff, to make this occur. “We can’t get the case dismissed or thrown out in any other way so now let’s go manufacture some information.”

MR. WEINBERG: Objection, your Honor.

A Let’s create —

MR. WEINBERG: This is pure and utter speculation.

THE COURT: Not only that, but I think it is just kind of a discussion what he thinks. And, frankly, I need his testimony, not what he thinks. He can put that in someplace else.

That objection is sustained.


Q Before you walked out of the courtroom, did you hear Mr. Minton say any other lie outside of the Dandar making a lie about the $500,000 check?


A No. I got up and left immediately.

Q All right. And when is the next time you were talking with Mr. Minton or Stacy Brooks?

A After they had left Clearwater. I mean, I just couldn’t even stand to be around them anymore. When I saw that that thing happened in front of Judge Baird, I didn’t know what to do.

And I finally figured that, you know, in my mind something criminal was going on here, I need to do something to help my friends. So I went to visit Mr. Denis deVlaming. And I —

THE COURT: When you say to help your friends, you are talking about your friends Bob Minton and Stacy Brooks?

THE WITNESS: Yes, your Honor.


Q So you went, on your own, to Denis’s office?

A Yes.

THE COURT: I’m sorry, I should not put words in your mouth, either. Obviously you meant Mr. Minton when you say friends. Who was the other friend?

THE WITNESS: Mmm, Stacy Brooks. I went to Mr. deVlaming’s office and I explained to him that I had been privileged to know that this was going to


happen, that this was going to be created and done against you, and I explained the whole thing to him.

And his reaction was, “Oh, well, they got him this time.” But because he had represented me before, and he had also represented Mr. Minton, he told me that it was a conflict of interest, because I went there to see if I could somehow get law enforcement involved in what was going on here because I was confident that Bob was lying on behalf of Scientology.

And I asked him to put me in touch with someone on a federal level, because I believed that Scientology did have influence in the state prosecutor’s office. I believed that they were able to somehow enact, somehow, undue influence on prosecutors simply because they never get prosecuted for the things that they do. And I myself, you know, I could have one little small marijuana plant in my house, I’m raided by the DEA.

But, you know, a person — a dead body shows up, they can’t do anything.

I had no confidence in that. I asked a federal — asked for federal protection, a federal level, because I said in my mind what they have done is RICO; they have conspired to commit a crime that


started in New York, they continued it down here in Clearwater.

Bob told me clearly that he was not going to involve his lawyers in the negotiations proper to any degree where they’re really getting down to the meat and potatoes.

THE COURT: Did Bob tell you why?

THE WITNESS: Because they disagreed.

Mr. Jonas thought the whole thing was disgusting and distasteful that was going on.


Q Mr. Minton’s lawyer?

A Yes. Mr. Jonas, up in Boston. And you notice he has been visibly gone. He didn’t want nothing to do with this.

So they decided to use Mr. Howie to enact this. And they didn’t tell him what was going on. They were happily meeting with these lawyers and without any representation.

Q Well, why —

THE COURT: Wait, you said they were happily meeting with these lawyers without representation.

What is it you mean?

THE WITNESS: The lawyers specifically that Bob and Stacy were meeting with was Sandy Rosen and


Monique Yingling.

THE COURT: All right.


Q Did Mr. Minton tell you why he chose not to have Mr. Howie or Mr. Jonas go with him to meet with Mr. Rinder, Mr. Rosen and Ms. Yingling?

A Mr. Jonas thought the whole thing was disgusting and distasteful and thought it would be improper.

And he told Bob specifically — and Bob told me he told him — not to meet with Scientology without representation.

Mr. Minton — Mr. Minton mentioned that Mr. Howie could be used because he didn’t really understand what was going on in the first place with — I mean, and the reason why he didn’t understand, it is not because he’s a stupid or ignorant person — but because they weren’t giving him all of the information, Bob and Stacy were not telling Mr. Howie everything, they were negotiating with Scientology and telling Mr. Howie what they wanted him to hear.

Q But why — did Mr. Minton explain to you why he chose not to have his attorneys be present at the meetings?

THE COURT: I presume you’re talking about the meetings in Florida?


THE COURT: And his lawyer down in Florida being Mr. Howie?



THE COURT: Because Mr. Jonas was in New York?


Q Yes. Did he tell you why he didn’t want Mr. Howie at these meetings?

A Mr. Minton expressed to me that he had personally had enough of lawyers, period. And he thought that this is something he needed to do.

Q All right. By the way, did Mr. Minton ever appear at a meeting with you, me, Dr. Garko, Stacy Brooks, to talk about adding on David Miscavige?

A No.

Q Ever?

A No. This was the second big point, you know, that — you know, that Stacy is going on and on, “Jesse, you have to remember, it happened like this.”

“I told you, you are imagining this. It never happened. I’m not going to sit and lie about this.”

But this was another point I was supposed to go along with at the meeting. This is where they were really trying to bring me in to find these points to get you, basically.

Q Well, what made you not join and continue to be part of the A team, as you call it?

A Well —


MR. WEINBERG: Your Honor, I — can we explain what the A team is? Because maybe I missed something.

THE COURT: Yes, the A team is Jesse Prince, Bob Minton and Stacy Brooks. They laughingly referred to themselves as the A team.

MR. WEINBERG: I guess I was daydreaming. I didn’t hear that. Sorry.

THE COURT: I did. So I — I miss some, but I recall that.

MR. WEINBERG: You caught that but I missed the A team. Okay.


Q So why did you choose not to go along?

A Well, Mr. Dandar, for obvious reasons. Number one, I worked for years on this case. I have worked honestly, to the best of my ability, on this case. I assumed that Stacy was, as well.

Mmm, I understood that Bob Minton — Scientology discovered something about him that upset him greatly and had him horribly concerned. But I wasn’t going to lie to protect him to hurt someone else.

And, in fact, my exact words to Mr. Minton was — and Mrs. Brooks, that I will never, in my life, help Scientology hurt or destroy one more person.


Q When did you tell them that?

A After — after I walked out of Judge Baird’s courtroom, and then now they’re all looking for me and they’re calling around to see if I’m in jail or see if I’m in the hospital. They thought I had a heart attack, because I was visibly upset. I mean, I was shaking when I walked out of that Judge Baird’s courtroom.

But the thing is I didn’t want to see them. I told my fiance, “You tell them to go home where they live because –” excuse this expression “– they have come and shit all over where I live, I don’t want to see them. You go back to where you live and then we’ll discuss this.”

And we discussed it. And when we discussed it, when I got on the phone with them after they got back, that is when I had the conversation and said that to them. “I can’t do it.”

Q Did you meet with them after Judge Baird’s hearing in Clearwater?

A Yes. I met with them a couple — not after the Judge Baird hearing. You know, at a later date after that, sure.

Q Do you recall meeting with them that following weekend?

A It could have been that weekend. Again, I have done the dates here to the best of my recollection, with


sitting down with the calendar. But it was after the Judge Baird — yeah, because Bob had been deposed — no, wait a minute, I’m confusing incidents now, because by the time they went back, they had already been through the Baird (sic) deposition and they were having the contempt hearing or whatever it was in front of Baird where he lied.

So, you know, they came back at a later date. And the discussion was — after they got back to New Hampshire, I told them how upset I was and how I couldn’t do it, and Stacy said to me in no uncertain terms that, “The reason you feel this way is because you don’t have all of the information. We’ve been leaving you out of the loop on some things that you need to know.”

She said that they had signed some agreement with Scientology, so — she couldn’t tell me everything, but the next step was to bring me back into the circle to make this go away for Bob.

And Stacy was just hell bent for leather to do whatever she had to do to disengage Bob from Scientology because she thought it was killing him.

Q Did you meet with them in Clearwater then?

A Yes, I did. We met at Adam’s Mark Hotel.

Q At the Adam’s Mark Hotel there are two things I want you to talk about. Number one, the conversation. And, number two, any documents you saw.


A Well, I hadn’t seen Bob. He knew I was furious with him. I hadn’t seen Stacy because I was furious with her. But we agreed to meet because we were friends.

Friends don’t get along every day. It would be nice if you did. But you don’t lose a friend because there is a disagreement.

So we met. And Bob told me, you know, he said, “Look, Jesse, you know, I’m not sure that this is gonna work, either. Stacy is more confident about doing this than I am. I don’t know.” We were kind of having that discussion.

Then the phone rang. Mr. Minton spoke with someone and he said, “Okay, leave it at the desk” and he hung up the phone.

And I asked him what that was.

And he said Scientology was delivering to him a packet of information that had to do with his prior deposition testimony — or prior testimony, that amounted to about 11 inches, for him to go through for the purpose of finding more things for him to — Mmm — quote/unquote, recant or do whatever he was going to do.

There was total — I asked him, “How many things besides Wollersheim and the Lisa McPherson case, what else do they want you to do? Do you know when your leash is over with, where they get done with you? Okay, you think if you


destroy Ken, that will make you safe. But what else are they going to have you do? Do you know?”

He said he didn’t know, but this package represented six to seven other things that they wanted him to change testimony about or — or say something different about.

Q Did you see this package?

A Mmm, no.

Q How do you know it was 11 inches high?

A He told me.

Q Okay.

A And he also told me at that time that his attorney, Steve Jonas, told him not to meet with Scientology concerning that package without representation, but he was going to do it anyway —

Q Okay.

A — because he’s taking control.

Q Did you ever see any lawsuits that Mr. Minton was given where Scientology was suing him or contemplating suing him?

A He had a rough draft of a RICO suit that he showed me. It was about this thick.

Q How many inches is that?

A It was about maybe an inch, inch and a quarter, something like that. And he —


Q All right.

A — flipped through it like this. And he would never physically give it to me.

He said — and we all predicted they were going to do some crazy RICO thing. He said, “They finally did it. Here is the RICO thing. We already have the Armstrong thing. They are suing me for 80 million which I’ll be liable for, here is the — another RICO, that is another 110 million. They are adding me as a defendant in the breach of contract.

And,” he said, “I’m the only person with money. I have got to get out of this.”

Q Okay. Now, did you at any time tell Mr. Minton or Ms. Brooks that you were willing to meet with Scientology?

A Yes.

Q When was that?

A Mmm, at the Adam’s Mark Hotel when they — you know, what they call bringing me into the circle.

And I’m looking at these people that I have worked with for years and I might as well have been looking at strangers, because Stacy has this whole thing lined up.

She — you know, she knows exactly what is going to happen, who is going to do what. And Bob is kind of like following along because he’s just at his wit’s end.

And Stacy figures that she knew Mike Rinder for a long time and they were good friends and she’s just going to make this as good for Bob as possible.


And, to me, she just delivered Bob into the hands of his enemies.

Q Did Stacy Brooks ever — in all of the years you have known her, did she ever say to you, “I filed a false declaration or affidavit”?

A Never in a million years. To the contrary, Stacy is fully aware that part of, you know, Scientology’s intelligence operations are to get rid of the lawsuit in any way possible. You know, whether you actually have real evidence, get rid of it, or you manufacture it or you bring up enough threat where the person just wants to be done with it.

She knows this because it happened to her.

Q When?

A December of 1999 she did an affidavit about it, about the same people, Mr. Rinder, Mr. Sutter, coming in, wanting them to change testimony, offering money.

THE COURT: We have had testimony about that.

THE WITNESS: Yes. All right.


Q Well, did she ever say — I just wanted to touch on that. Did she ever say that Mr. Rinder was actually telling her the truth about attacking Graham Berry and Graham Berry did something bad?

A No. But what she did mention to me, she said, “You know, after speaking with Mr. Rinder, you know, I


always thought in the Fishman case –” where she appeared as an expert, she said she always thought that because they tried to add Miscavige on as a party, that that made Scientology want to instantly settle because, you know,
hands off from Miscavige, he’s the ecclesiastical leader of the Church, Sea Org, on and on.

So she said that after speaking with Mr. Rinder, she came to realize that it wasn’t adding Miscavige that caused the suit to be settled in the way it was. After talking with Mr. Rinder she came to understand that it was because of the introduction of Scientology’s upper levels at which they commonly call it as being trade secrets that was the real issue at hand.

Q Okay. Did Stacy Brooks ever say that her affidavits that she filed about Mr. Rinder offering her and her husband over $200,000 to change their testimony — did she ever tell you that Mr. Rinder’s version of what her declaration should be was true versus what Mr. Berry had her sign?

A Mmm, no. We — I mean, I had read that information before that she had done this. And at this point in time at the Adam’s Mark Hotel, Stacy was not an obvious target. They were working on Bob Minton.

Q Okay.

A Stacy was incidental at that point.


Q All right.

A It wasn’t contemplated for her to change her testimony. It was Minton to do it.

Q Did you ever have a conversation with Bob Minton, for instance, let’s go to that night, the Adam’s Mark Hotel, where he’s talking about the $500,000 UBS check and what he told you in the parking lot about it?

A Oh, I brought that up to him. You know, they were saying, you know, “Ken is really going to get it. He told me to lie about this check.”

I said, “Wait a minute, Bob, let me remind you –“he and Stacy are like gleeful children, like all responsibility is gone. “Hee-hee. Guess what?”

“Are you insane? We were both on the parking lot. Bob got you and me out of the office, said he was giving this check to Ken, Ken didn’t know where it was coming from, told us it was from people from Europe. I mean, why are you gleefully now telling me somehow this is Ken’s fault?”

Q What did they say?

A They just looked at me like, “Oh, yeah, we forgot about that part.” Mmm, they were telling me things like, “We really got him now.”

I said, “But don’t you remember what we did?

Don’t you remember this is what really happened as opposed


to this story you are making up now? Do you remember what actually happened?”

Q What was their response?

A “Hmmm.” You know, just “Hmmm.” Like, “He’s not cooperating.”

Q So —

A So I told him, you know, “Now, you know we were up in the parking lot. We went through this whole thing. So now what do you want me to say what happened now, when this is what did happen? What am I supposed to do?”

THE COURT: What did he say?

THE WITNESS: He just looked at me like I was crazy. And they looked at each other and they changed the subject. We started talking about — Mmm — what else did we start talking about?

They brought up something else that — the meeting, yeah, oh, and the other thing they want — “they” being Rinder and Rosen, the other thing they want brought out is how Minton was supposedly at some meeting that  happened where we all said, “Yeah, add Miscavige and don’t talk to anybody about it.” I am like, “Are you crazy? That didn’t happen either.”


Q So when you told them it didn’t happen —


A Then they said, “Look, let’s stop talking about this. Let’s go to dinner. We’ve made some progress.”

But, on the other hand, I’m thinking, “I have to talk to somebody from Scientology about this,” because obviously I’m looking at Bob and Stacy, they are just convinced that I’m just going to to-to-to, go along with this. They are just convinced.

They are telling me — Stacy said, “Look, we’re going to do this, it is unpleasant, but we’ll put all this behind us. You won’t have worry — money problems anymore, you’ll have plenty of money, you’ll be taken care of, you know, and –”

THE COURT: Who was going to give you the money?

THE WITNESS: The same — your Honor, the same person that has been, Bob Minton. They have been taking care of everything.

(Discussion had off the record.)


Q So this was — then you went out to dinner?

A Yes. We went out to dinner and we just kind of changed the subject because it was getting heated. You know, I’m trying to find a scintilla of logic of what is going on here. And I can’t — I can’t even imagine — I can’t even make myself imagine what they are talking about



Then I told Bob, I said, “Bob, isn’t this strange –”

(Discussion had off the record.)


Q So Bob Minton said —

A I keep losing my train of thought.

Q I know. Sorry. Maybe we should read it back.

(A discussion was held off the record.)

(Last answer read back by the reporter.)

THE WITNESS: Repeat the last line again.

(Last answer reread by the reporter.)

A I got it. Because I started talking to them, I said, “Well, look, we had further discussions about Wollersheim, too.”

And I said, “Well, you have loaned Lawrence money to continue his case. Now you’re going after him. You have given all of this money against Ken Dandar. Now you are going after him. Don’t you think it is obvious what has happened here? Don’t you think it is going to be obvious to all concerned that something bad happened here?”

His response was, you know, “I’m not convinced.

Stacy is convinced this is going to work, Jesse. I’m not convinced about it. And I feel bad what is going on with Ken.”


My thing was, okay, I have to talk to somebody about Scientology about this because obviously these two things — I have a ring in my nose and they have a leash. I have to let Scientology know they’re not going to get away with this, this is not going to work.

THE COURT: Who was it — you are saying you had the ring through your nose and they had a leash?

THE WITNESS: Yes, this is an analogy of what seemingly was in their minds.

THE COURT: “Their” meaning Bob Minton and Stacy Brooks?


THE COURT: Thought they had the leash and were leading you around.


THE COURT: You thought you had to tell Scientology that wasn’t accurate?



A So I’m going along now with this whole thing. I said, “Look,” I told them, “Okay, I’ll do it. Okay, I’ll do it. Tell me –” because they said, “We have to bring you in. You have to meet with Mike Rinder now. You have to meet him face-to-face and go over this and you are going to be happy like us.”


“Okay. Okay.”

I tell you, I left that Adam’s Mark Hotel and I felt like, “Oh, my God.” You know, I would rather be doing anything. But ultimately I came home and I told my fiance, I said, “Look, it is over. I can’t do it anymore. I have to let Ken know. I have to call somebody.”

So I called Frank Oliver and told him the whole story of what had been going on the whole time and told him to please tell Ken, and I’m so sorry what happened to him.

I sat in Judge Baird’s courtroom and it upset me greatly, and asked him to arrange for you and I to meet, at which point you called me and we met the Sunday.

And I was supposed to meet with Bob and Stacy and Mike Rinder that time. And I told them, “Yes, I’m going to go along with your plan.”

And as I state here in my affidavit and I said to you to your face, I just want to see Mike Rinder’s face when he finds out that this isn’t going to work if he thinks he’s going to use me to do this thing.

So we have that meeting —


Q You and I had a meeting?

A You and I had the meeting. And Mr. Lirot was there.

Q Right. Right. And then you went to meet with Bob


and Stacy and, you thought, Mike Rinder?

A I thought Mike Rinder would be there. So what happens, now they moved hotels, they moved to the Radisson on Clearwater Beach. I guess they didn’t like the Adam’s Mark. So we are at the Radisson.

And he has this big sheaf of papers. And he said, “Jesse, you are unreal. Let me show you what Judge Schaeffer is saying about you.” And he read something that, to me, was totally uncomprehensible.

And he said, “See, she doesn’t trust you. You are not credible in her eyes. You are going to jail if you don’t do what we tell you to do.”

I said, “Bob, I think you’re the one going to jail. You’re the one lying. You’re the one that has already went in court and lied. And you want me to do it? I think you’re the one going to jail.”

Oh, my God, it gets hot. “Okay, let’s go down to dinner.”

Then I sit and I explained to them, I said, “Look, let me tell you specific experiences I have personally had making deals with Scientology. Let me tell you the results.”

I told them painstakingly some awful things if I even started to mention, I am sure Mr. Weinberg would be up in a flash.


MR. WEINBERG: No, your Honor, I would like to hear exactly what he said he told Mr. Minton about all these awful experiences.


Q Okay. Go ahead.

A I told him about the time I was removed from that position you saw me on the video with the sailor clothes, on and on. I told them about the circumstances about me being removed from there.

THE COURT: I’m not sure I saw that.

THE WITNESS: Your Honor, it was the first day I was here, Miscavige introduces me, I’m telling him I’m from RTC and we are going to get the squirrels and what do the squirrels mean.

THE COURT: I remember.

MR. DANDAR: This is the New Year’s Eve speech.

THE COURT: Right. I remember now.

A Well, how I got removed from that position. I’m telling him the story where Miscavige wants to come in and get rid of Broeker because he thinks Broeker is crazy.


Q So you were caught in between Broeker and Miscavige?

A Yes. And I told them, either one, “I don’t want anything to do with either one of you,” because when I got


involved myself in doing illegal activities, with listening to wiretapping and, you know, all of this crazy stuff I’m being shown how to do, I’m cutting my teeth, I am being broken into OSA, this is no Scientology that I ever knew
anything about.

You know, I don’t want nothing to do with this part of it. I didn’t even know it happened where they do this stuff to people.

Mmm, and then, you know, they — because I didn’t go along with that, I’m woken up at 5 o’clock in the morning, there is — there is Miscavige standing there, there is Lymon Sperlock, Ray Mithoff, Mike Sutter, Greg Wilheir (phonetic), his brother, security guards. There are about 12 people there.

I walk into Miscavige’s office, and there is Vicki Aznaran, the person that used to be inspector general of RTC, just crying in the corner, crumpled. They are all in their Sea Org uniforms just like, grrr. And I’m running around with something that looks like pajamas.

And he told me, “You didn’t go along with this, you wouldn’t follow me, now you are going to the RPF. You call me sir. You have been disrespectful.”

I stood up and told him to go to hell and went and tried to leave, at which point they tried to grab me. And me and Judge Moody has been through this story before so I’m


not telling a new story.

And I ran to my bedroom and I got a Mini 14 assault rifle I had been given for my birthday from L. Ron, and a .45, loaded in both, went back to that office, and I have them like this (indicating). And now they are standing there like — oh, Norman Starkey was there. And Norman says, “Jesse, you traitor. You can’t kill us all.”

And I said, “Well, I’ll tell you what, maybe not, but you will certainly be the first to go.”

And I’m standing there with these guns. Then Miscavige, because he and I used to be very good friends, too, he and I were very good friends at one point in time, he came over and he said, “Jesse, look, this is horrible, let’s stop this.”

He knew I wasn’t going to do anything. He walked right up to me. He told all those other jerks, “Get out of here, I have got to talk to Jesse.”

So we go down to the ship and we have a conversation. And he tells me, “Jesse, I know this all seems horrible now, but I need you to take this fall. I need you to be a head on a pike.” Head on a pike is a term in Scientology where somebody takes a fall for Scientology.

Put a head on the pike means if you are going through the gate, you end up like this, head on the pike.

“I want you to be the head on the pike.” He


wanted me to go to RPF. You know, Vicky and Rick really screwed things up with the Broekers and conspired about him, yik-yik and on and on. And he said, “Look, this will be over, you’ll be restored to your position,” on and on.

“Oh, okay, Dave, I do it.” We talked. I willingly once again go to the damn concentration camp.

Once again. Like eighteen months wasn’t long enough. Now I’m in there again.

What immediately happens? Miscavige starts issuing this horrible stuff about me, “He’s terrible, he’s a piece of crap.”

I stood up and walked out of that place, went to that base and said, “Look, if this is the way you want to play this, I’m going to the police, I’m going to go talk to them about what you do here.”

Oh, my God, all them issues are canceled. No, Jesse is good again. “Jesse, I’m sorry.” It is always someone’s fault, someone else acted in an unauthorized manner and put these things out.

Okay, he got rid of all of that stuff. I mean, I had to have something to show for being in Scientology 16 years. Every certificate I had — I had a wall from top to bottom, at least half of that, of everything I have ever done in Scientology used to be in my office.

And, Mmm, so I ended up going back to the RPF.


Oh, no, we straighten it all out again. That was one instance.

Just lying. Just can’t wait to get me in a position to where I am incapacitated to do something.

The second time I’m trying to leave Scientology, “Look, you guys can do this. Do whatever you want to do, you know. You want to do this activity? I don’t want to do it anymore. I just want to take me and my wife and leave, just be away.”

Well, of course that didn’t happen. I had to be degraded for four and a half months, locked up, sec-checked, told to divorce my wife. I have written about this, too. Finally, I leave.

THE COURT: What did you say, seg-checked?

THE WITNESS: Sec, security checked. Being interrogated on the E-meter.

A Well, what happens, as soon as I leave, they have someone that is a tail on me that works for this Scientology business who, because I won’t continue to do Scientology and their business, now I’m no good. You know, I have come in there and boomed that business. I was hired, I was on salary making $60,000 or $70,000 a year.


Q Are you talking about the artwork business?

A Yes, the artwork business.


would call me once or twice a week. Mike Sutter, RTC, “Jesse, how are you doing?”

So now they want me to do Scientology work where they want me to do cramming, do correction, yik-yik, on and on.

I said, “Look, I have left that. I’m not doing that anymore. Let me just do a regular job. I’m just doing a regular job now, not using the Scientology mess, and everything is going fine. You know, don’t fix something when it is not broke.”

No, that is not good enough, that gets reported to RTC. Now I have to get removed and now I have to go through endless crap.

It finally culminated losing my job, having to start my own business, being followed around every place in Minneapolis, because I travel a lot. Then one day I found a bag right outside my hotel room, like this (indicating), Rock cocaine.

THE COURT: How big?


THE COURT: You are showing it.


Q Tell —

A Like this (indicating).

THE COURT: Say for the record, is that the


size of a baseball?

THE WITNESS: About the size of a softball.

THE COURT: About the size of a softball?

THE WITNESS: With individually little crack cocaines.

A And I’m like, uh-uh, this is it.

So, to me, I’d already been through enough betrayal with Scientology. And I explained this to them.

THE COURT: This is just — all that cocaine just sitting outside your hotel room?

THE WITNESS: Yes. Yes. And the fact of the matter is, your Honor, it is known that I had, you know, smoked marijuana before or whatever, but if anyone in my family — because my brother tried it — does cocaine, he did it, had a double aneurysm. I sat in the hospital a month while they cut off his dreadlocks, peeled his skin back, cut his scalp, went through his brain, cauterized two microscopic veins because his head exploded from fooling around with crap, and put it all back together.

And the reason they said it happened to him, something genetically in our family that makes those veins do that. What do I want to do with cocaine


for? It is just —

THE COURT: I think we’re far afield.

MR. WEINBERG: Is this what — all these incidents you told Mr. Minton?

THE WITNESS: Yes, I’m telling all this to Mr. Minton. I said, “In the end you may think –” and I told him, “As you sit here you can’t tell me when Scientology is going to be done with you. When are they going to be finished having you done whatever they want you to do? All you know, you have Wollersheim and you have McPherson.”

He said, “Jesse, you are being unreal.” He got mad. He cursed at me and said something. And his last words were, “Well, fuck it, you’re going to jail.”


Q Did you use the same language back at him?

A I said, “Bob, I’m sorry, you’re going to jail.

Stacy, you’re going to jail. I’m not having anything to do with this.”

I got up — he asked me to leave. He said, “Get out.”

I said, “Fine.”

Stacy follows me in the parking lot. She said, “You know, after all of the things Bob has done for you,


this is how you treat him?”

I’m looking, “What in the hell has Bob done for me that I have to perjure myself, I have to become a criminal because he thinks this is what I got to do to save him?

Uh-uh. He’s not done anything for me. And there is only one person can sell my soul. That is me. I already sold my soul to this organization one time and I got it back. Bob Minton is in no position to offer my soul to them.”

And I told her that. And we really haven’t talked that much since.

Q Well, now, was there a point in time when Bob Minton was coming over to your house after that for barbecue?

A Well, again, we have been friends a long time. This was another bridge of disagreement, blowup, everybody cursing, but we have such history. Even as I sit here today, I can’t fathom not talking to him once or twice a week.

So, you know, we’re talking again.

“Look –” Stacy said, “Look, this is going to blow over with or without you. We’re going to make sure.”

So I said, “Okay, well, then if we’re not doing this, could we still be friends?”

They love to come over to the house. We barbecue and have little parties. “Sure.”


But then he called his lawyer and he was told not to come.

Q This is while the hearing is going on in this courtroom?

A Yes. They want to tell me what is going on. They want me to be a part of it because I have been since the beginning. But I can’t because of what they’re doing.

Q Did Bob Minton want to close down the LMT?

A No.

Q Whose idea was that?

A I don’t think it was any one person’s idea. Well, if it was anybody’s idea, I think it was Stacy’s, because the LMT was being used as a vehicle to get to Bob. And —

THE COURT: I think it sounds — this must be allowed to start at 4:30, but it is giving me a headache. Is this a good stopping point?

MR. WEINBERG: Yes — I’m sorry.

MR. DANDAR: This would be — this would be fine.

THE COURT: They probably are allowed to start up at 4:30.

MR. WEINBERG: I thought I was having a ringing in my ears, which I do have an ear issue.

THE COURT: So we’ll go ahead and quit. We’ll start up at 9 o’clock. Mr. Prince —


MR. WEINBERG: Remember you said ten?

THE COURT: Oh, I did. Ten o’clock tomorrow.

Ten o’clock tomorrow. I think I told you this before, but if I didn’t, let me remind you: While you are on the witness stand, I did give you permission to speak with Mr. Dandar because of the long break, but now, like overnight,  you and he can’t talk.


THE COURT: Okay? I mean, you can talk about something else, but you can’t talk anything about your testimony or about this case. Of course you can’t talk to the other side, you can’t talk to anybody while you are on the stand about this case or your testimony. Okay?

THE WITNESS: Yes, your Honor, I understand that.

THE COURT: We shall be in recess.

MR. FUGATE: Judge, I have one issue on the E-Mails. And I’ll be really quick.


MR. FUGATE: There are, to my understanding, about 3,000 E-Mails. And during the break —

THE COURT: Have you-all come up with any agreement as to a list?


MR. FUGATE: That is what I want to talk to you about. I went over to see, there is a list that prints out all of the ones that they were able to recover from the various hard drives. And I have found a series of — on that list of E-Mails that related to Peter Alexander and Patricia Greenway, and I have left a list of those with Mr. Keane.

And then I understand that Mr. Dandar indicated that those shouldn’t be produced because Ms. Greenway is a consultant. And, you know, in this hearing he said she wasn’t.

I don’t really care what she is today. But back during the time that she was at LMT prior to this hearing beginning, which is where all these E-Mails generate from, I don’t think they would be covered as a consultant —

THE COURT: Counsel, I can’t deal with something that won’t be agreed to with this noise. That is why I stopped this hearing. We’ll take this up first thing in the morning, and hopefully we won’t have any noise and we’ll get it done then.

Ten o’clock tomorrow. Bring it to my attention then.

MR. FUGATE: All right.

THE COURT: All right. Thank you all.


(WHEREUPON, Court is adjourned at 4:50 p.m.)



I, LYNNE J. IDE, Registered Merit Reporter, certify that I was authorized to and did stenographically report the proceedings herein, and that the transcript is a true and complete record of my stenographic notes.

I further certify that I am not a relative, employee, attorney or counsel of any of the parties, nor am I a relative or employee of any of the parties’ attorney or counsel connected with the action, nor am I financially interested in the action.

DATED this 9th day of July, 2002.



Affidavit of Jesse Prince (May, 2002)

From mirele@sonic.net Thu May 02 22:23:37 20021
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Newsgroups: alt.religion.scientology
Subject: Jesse Prince Affidavit April 2002
From: Deana Holmes <mirele@sonic.net>>
Organization: Scientology Killed Lisa McPherson
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This affidavit was provided to me by Dandar & Dandar and has been filed as part of the court record. I don’t know if it was signed May 1st or May 2nd. I added what I believe are the approximate page numbers in brackets.

Deana M. Holmes


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

Case No. 00-5682-C1
Section 11
APRIL 2002



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

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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

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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

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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
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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

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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

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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

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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

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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

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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

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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

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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

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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

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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.



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.

My commission expires:


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