Testimony of Jesse Prince (Volume 6) (July 10, 2002)

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IN THE CIRCUIT COURT FOR PINELLAS COUNTY, FLORIDA

CASE NO. 00-5682-CI-11

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

vs.

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

_______________________________________/

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

CONTENTS: Testimony of Jesse Prince.1

VOLUME 6

DATE: July 10, 2002. Morning 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

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APPEARANCES:

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

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

MR. LEE FUGATE
MR. MORRIS WEINBERG, JR.
ZUCKERMAN, SPAEDER
101 E. Kennedy Blvd, Suite 1200
Tampa, FL 33602-5147
Attorney for Church of Scientology Flag Service Organization.

MR. ERIC M. LIEBERMAN
RABINOWITZ, BOUDIN, STANDARD
740 Broadway at Astor Place
New York, NY 10003-9518
Attorney for Church of Scientology Flag Service Organization.

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

THE COURT: Good morning. Mr. Prince. All right. Mr. Dandar, you are standing. You must want something.

MR. DANDAR: Well, we have a proposed order here. I have some responses here. I have declarations of Stacy Brooks and others I want to file. But let’s just go with Mr. Prince.

THE COURT: Okay.

(A discussion was held off the record.)

THE COURT: What day is today? The 10th? I was looking, what is — how many days of hearings is this?

THE BAILIFF: 30.

THE COURT: No, no. Mr. Bailiff says 30. Does anybody —

MR. WEINBERG: Add zero to that. That is where we are.

THE COURT: Is that where we are, 30?

MR. WEINBERG: I think so.

THE COURT: Good morning, Mr. Ross. Are you designated Mr. Minton’s attorney here today?

MR. ROSS: That is correct.

THE COURT: I think that probably you have been advised Mr. Minton needs a lawyer in this proceeding and, therefore, we welcome you. But you have no ability to object in this particular proceeding.

MR. ROSS: I understand, your Honor.

THE COURT: You understand you may hear some very weird testimony as far as some strange evidentiary rulings. But this is a strange hearing and sort of the rules of evidence — we’re going to deal with that after the hearing.

MR. ROSS: I understand.

THE COURT: Okay.

MR. WEINBERG: Just give me a minute, your Honor.

THE COURT: I will. I will ask Mr. Dandar, while you are doing that, did you have a chance to E-Mail Mr. Henson?

MR. DANDAR: Yes, I did. And he E-mailed me back and said, “Can you find me a lawyer, is it worth it?” I said no, both questions.

THE COURT: Okay.

MR. FUGATE: Your Honor, I notified Mr. Hill’s secretary that Mr. Rosen would not be called. And I should have an order here on the pro hac vice, if it is not by the morning break, by noontime.

THE COURT: All right. Fine.

MR. LIEBERMAN: I would just like to inquire, does that mean Mr. Henson is abandoning his motion?

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THE COURT: No, I think what that means, he will not be represented. And I suspect you should — as I said, let me have time to read it. I may be able to rule on your motion without any argument.

MR. LIEBERMAN: Very good.

THE COURT: But, frankly, I want to still leave it scheduled for hearing, because he may get somebody to appear. And we’ll deal with it at the  scheduled time. I would not assume that is an  abandonment.

MR. LIEBERMAN: All right.

MR. DANDAR: Right.

THE COURT: Okay.

MR. WEINBERG: All right? I’m ready.

THE COURT: You may proceed.

BY MR. WEINBERG:

Q Mr. Prince, you — I think you said on your direct testimony — but let me go over it again — you have testified previously as a witness under oath in either trial testimony or deposition testimony. Is that right?

A In this — in this case, yes, I have.

Q In other cases, as well. Correct?

A Yes, I have.

Q And — and is it your testimony that at all times

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in those other cases when you were under oath, that you testified truthfully?

A Yes, it is.

Q Okay. Now, yesterday — or the day before, whenever it was — you testified that you had participated in the destruction of PC folders, particularly Mr. Wollersheim’s PC folder which he said was pulped, I believe, while you were at RTC?

A Correct.

Q Now, you remember testifying as a witness in 1989 in the lawsuit Religious Technology versus Joseph Yanny?

A I do not.

Q You don’t remember that?

A No, I do not.

THE COURT: I don’t even remember hearing about that case. That is a new one for me.

BY MR. WEINBERG:

Q I thought you testified, by the way, on your direct, that you had been a witness in that case, in fact, that while you were in Scientology, you were actually a witness in that case.

A No. While I was in Scientology I said I was a witness in the Wollersheim 4 case, specifically concerning the Advanced ability Center, David Mayo.

MR. WEINBERG: Could I approach the witness,

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your Honor?

THE COURT: You may.

BY MR. WEINBERG:

Q Let me show you a transcript of your deposition taken in Los Angeles, California on September 11, 1989 and ask you if you can identify that transcript and identify that as your testimony on that day under oath, and at the end you’ll see an errata sheet which I believe also has your signature on it.

A What is this on? On September ’89? Okay.

Then —

Q At the end is an errata sheet. Do you see that?

A Uh-huh.

Q And you see that you — do you recognize your signature on there dated —

A 12 December, ’89. Yes, I do.

Q Obviously — I’ll leave this here because I have a few questions on it. Obviously you testified as a witness in 1989 and were given the opportunity to review that  testimony and make corrections. Correct?

A I don’t — Mmm — recall that, Mr. Weinberg, but since I did sign the errata sheet, I’ll say okay.

MR. DANDAR: I would like to have a copy of that, Judge. If they’re going to start using it, pulling things out of context, I would like to be

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able to review it.

MR. WEINBERG: Well, it’s amazing I’m being accused of pulling something out of context.

MR. DANDAR: We all do, we pull something out and say, “Did you say this?”

THE COURT: If you are going to use a deposition and he doesn’t have a copy of it, he ought to have a copy of it.

MR. WEINBERG: Do we have an extra copy of it?

Do we have copies of these?

THE COURT: I tell you what, go ahead and use it and then get him a copy before Mr. Dandar —

Mr. Dandar, please listen if you care, maybe you don’t care. If you care, I’ll have them provide you a copy of the deposition before your redirect.

MR. DANDAR: Thank you.

THE COURT: If anything was pulled out of context, you can correct it.

MR. DANDAR: Okay. Thank you.

MR. WEINBERG: Now, in addition —

THE COURT: You-all provide him a copy.

MR. WEINBERG: Yes.

BY MR. WEINBERG:

Q Now, in addition to your testimony in this proceeding that you had participated in the destruction of

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PC folders, you also, in your August 20, 1999 affidavit, that is the — the affidavit where you made the accusation about David Miscavige, in that affidavit, in Paragraph 22 you swore that you had participated in the destruction of Wollersheim’s PC folder. Correct?

A Correct.

Q Now, if you will turn, Mr. Prince — when I get the right folder here — to Page 153 of your Yanny deposition. You find Page 153?

A Mmm, just about. I have it here.

Q I want you to read Line 5, 6 and 7.

“Question: Were you ever involved in the destruction of PC folders?

“Answer. No.”

Okay. That was your sworn testimony then, correct?

A Yes, it was.

Q And when you go to that errata sheet, does it say  anything about you making any mistakes with regard to that sworn answer where you swore under oath in 1989 that you had not been involved in the destruction of PC folders?

A Mr. — you know, I don’t recall this errata sheet, to answer the question that quickly. I don’t even recall the errata sheet.

THE COURT: The real question is that was your

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testimony on that date, is that right?

THE WITNESS: Yes, this was the testimony I had given on that date.

BY MR. WEINBERG:

Q And you previously testified that all your prior sworn testimony was true. Correct?

A Correct.

Q So you lied here in court when you said that you had participated in PC folders being destroyed?

A Well, you know, I have to at least look at a couple pages earlier here to kind of get an idea what was going on here to orient myself to 1989.

Q Look at a couple pages earlier.

THE COURT: Might I just ask, where he was reading, was he testifying for plaintiff, or defendant?

MR. WEINBERG: He was testifying for the Church. For RTC.

A Okay.

BY MR. WEINBERG:

Q That was certainly — you wouldn’t have had a recollection problem back in 1989, would you, as to what had occurred a year or so or two or three before that, as  opposed to 2002, talking about things that supposedly happened?

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A Mmm, Mr. Weinberg, I — I don’t think I would have had a recollection problem, but maybe I would have had a problem with coercion.

Q Let’s see now —

A Or — or manipulation.

Q Excuse me. I’m sorry. I didn’t mean to interrupt.

A Or manipulation. This was a very bad time for me. This was shortly — well, let’s see, this was a couple years  after I had been away from any position of authority. I was still being asked to — Mmm — participate in the courts, for whatever reason, God only knows. And I was not in a very good state of mind.

Q Well, I thought you said you were relieved yesterday to leave your post at RTC and that you were in a better state of mind as a result of being relieved and not  having to do all those things that you swore yesterday and the day before that you had participated in.

A Certainly in that regard, Mr. Weinberg, I was relieved. But I didn’t have a lot of direction for my life.

I think I was pretty suicidal at that point. And I had written about that, as well.

Q All right. So you started saying these things about destroying PC folders after people started paying you,like Mr. Minton and Mr. Leipold and through Mr. Dandar, that

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is when you started saying these things, not when you  weren’t being paid.

A No, Mr. Weinberg, quite the contrary. I — this came out because I decided that it was no longer an operating principle of mine that the greatest good is for  Scientology. I kind of — you know, just kind of got away from that.

Q So it’s a principle now the greatest good for Jesse Prince, whoever will put the money in your pocket, that is what you’ll say?

A No, Mr. Weinberg, the greatest good is the truth and justice and equity.

Q All right. So what you’re saying, just so I get this right, you lied back in 1989?

A Yes — yes. According to these documents, I lied on behalf of Scientology.

Q All right. And you lied in — I’ll just refresh your recollection about being asked about this before — do you remember giving a deposition in this case when — when I deposed you?

A I think you and I have been at it a time or two.

Q And do you remember that I asked you the questions on Page — I’ll refer now to Page 465 of your deposition of — of November 17, November 18, 1999.

“Question: Now, when you testified — how many

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times have you testified in your entire career, life?

“Answer: In a courtroom or deposition setting?

“Question: Both.

“Answer: Possibly five.

“Question: All right, and each time you testified, whether in deposition or in court, you were under oath, right?

“Answer: Correct.

“You raised your hand and swore to tell the truth.

“Answer: Correct.

“Question: Nothing but the truth, right?

“Answer: Correct.

“And you testified truthfully on those five occasions.

“Answer: Correct.

“Question: You didn’t perjure yourself.

“Answer: Correct.

“Question: So if you were asked the questions in a deposition that I asked and those were your answers then when you gave those answers, it is your testimony that they were truthful answers, correct?

“Answer: Well, you know, yeah, okay. I’ll say yeah, okay, yeah.”

Then later in the deposition — do you remember being asked those questions and giving those answers?

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A No, I do not, Mr. Weinberg.

Q Do you remember being asked on Page 469 of your deposition two years ago, “You testified in the Yanny case we’ve already talked about, was that deposition and trial or just deposition?

“Answer: I believe it was just deposition. And again, I was never afforded the opportunity — well, no, I’m sorry, I’ll answer the direct question, I won’t tell  stories. Yes.”

Do you remember being asked that question and giving that answer?

A No, Mr. Weinberg. But if it’s there, then I believe it.

Q So apparently three years ago when we took your deposition you remembered the Yanny case testimony but today you don’t?

A I — Mr. Weinberg, I think that is a bit of mischaracterization to say I would have remembered the Yanny testimony. You know, this document here is a couple hundred pages long. I — I don’t think any of us are capable of remembering a couple hundred pages of something that happened ten years ago.

Q Is there a particular reason why, in all these accusations you made against Scientology, you didn’t say,

“And they told me to perjure myself in 1989 in the Yanny

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deposition”? Why didn’t you do that?

A Well, the fact of the matter is, Mr. Weinberg, again, like I — I was damaged goods during that time. I had gone through a lot of stress, a lot of — Mmm —  decisions to change my life. Mmm, didn’t have certain — you know, a certainty on where I was going with my life. I felt pretty hopeless.

But let’s talk about the perjury here since this is the subject here. What I have testified to before concerning preclear folder destruction is the fact that  because these preclear folders of Mr. Wollersheim were being asked to be produced and ultimately the whole folders were turned over, the order to destroy the folders came from Mr. Miscavige with Mr. Rathbun present, myself, Vicki Aznaran. It became my responsibility to report when that fact was done.

I myself was not the person that destroyed the preclear folders or had — or pulped them. Rick Aznaran is the person, along with another current Office of Special  Affairs, Charlie Earl, rented a truck, took these folders; Vicki Aznaran — Lawrence Wollersheim, possibly Bill Franks, Gerry Armstrong and others took them to the recycling plant, and when Mr. Aznaran came back, he showed me a liquid bottle with paper on — with the pulp paper on the bottom.

So technically did I know about it? Yes.

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Technically did I do it? No.

Q Oh, I see.

A But I sanctioned it and I went along with it.

Q So perjury — the question was: “Were you ever involved in the destruction of PC folders?

“Answer: No.”

That is not perjury because you have somehow justified in your mind that you really weren’t involved because you didn’t actually pull the switch? Is that what  you’re saying?

A No, I’m saying that I’m not the person that actually did it myself, but I knew about it. And reported about it.

Q Is that —

A I didn’t stop it. So, you know, the fact of the matter is I won’t beat around the bush with you, Mr. Weinberg. Right here I was not being truthful.

Q Now, did somebody tell you to perjure yourself?

Is this something that somebody told you to do? Or you just did this on your own?

A No, I was told to do it. Mr. Earle Cooley, who was lead counsel for the Church of Scientology at the time, wanted me to do it. Mr. Rathbun, who was — was again and always responsible for church legal, wanted me to do it.

Mmm, I was being a good Scientologist and protecting

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Scientology.

Q That is amazing. So when this started out you didn’t have any recollection of the Yanny deposition, you don’t remember having even signed the errata sheet, and now you have this clear recollection that — that Mr. Cooley, a lawyer who is on the board of trustees of Boston College — or Boston University, and Mr. Rathbun told you to lie? Is that what you’re saying now?

A Mr. — Mr. Weinberg, I mean, because we are talking about this, because you have presented me with documentation, we’ve discussed it, I think I do have a mind and I can have some recollection about this. And I’m just telling you what happened here.

Mmm, there are other things that I have written specifically about my relationship with Earle Cooley, and because you have all of those E-Mails, I’m sure you have those in evidence, too. That is not the only thing that I thought was unethical that happened with Mr. Cooley, irrespective of where he sits.

Q So the way it works is, if we can catch you at it and if we can show you a video or show you some testimony where you perjured yourself, then it’s an indiscretion, essentially, you sort of caught me. Is that the way it works?

MR. DANDAR: Objection, argumentative.

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THE COURT: Sustained.

A Mmm —

BY MR. WEINBERG:

Q It was sustained, Mr. Prince.

THE COURT: You don’t have to answer the question.

BY MR. WEINBERG:

Q Now, you said your life was hopeless?

A Correct.

Q When was this deposition, 1989?

A Correct.

Q But having been hopeless, you stayed another three years?

A I stayed another five years after my life was pretty much hopeless. You know, I fell into the hopelessness — you know, right in 1987 when that whole thing happened I was ready to leave Scientology at that point. All I wanted to do was walk away. I had to escape to leave because I was in the RPF, walking through the desert, on and on, and I’m sure you don’t want to hear that story.

Q That story? Is that what you said? Do I want to hear the story?

A Let’s please maintain civility here, Mr. Weinberg.

Q All right, I asked you —

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A I’m trying to explain this to you. I had escaped. I had helped Vicki Aznaran escape. We were being kept in the RPF in a — behind a — Soboba Indian Reservation in the most horrid conditions. All I wanted to do was walk away. I had to threaten to go to the press, threaten to go to the police, the same thing I suspect Lisa had to do when she tried to leave, as well.

And ultimately because the woman that I was married to, who had no idea what I had been involved in, what my position really was in the Church of Scientology, what my participation was, it came down to Mr. Mithoff, Mr. Miscavige specifically talking to my wife and telling her what a horrible person I was and that I’m blowing and I’m psychotic and I’m crazy because I want to leave and this kind of thing.

So then I was faced with even a bigger problem. And my bigger problem was now am I just going to walk out of Scientology and leave this person that I love, that I’m married to, because she hasn’t woke even up, because she doesn’t understand, because I haven’t been with her and let her know what’s going on. And that is kind of a problem in Scientology in and of itself because the right hand doesn’t know what the left hand is doing. You are not allowed to talk about your case, you’re not allowed to talk about secret this, secret that. So we had had a breach of

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communication for many years.

But in my mind at that time I was thinking, you know, I’m not going to desert another person in my life, I’m not going to desert this woman for Scientology. I will sit here with her until she sees what I see. And I was actually, therefore, there for another five years.

And these are points I have written about as well.

I felt almost like an animal, I had no mind, no brain, no will, nothing. And this is what happened to me and I went and did this and it was wrong. And yeah, I did that and you have pointed it out and here we are.

Q Now, in 1989 when you perjured yourself —

A Uh-huh?

Q — according to your testimony now, or didn’t, depending upon whether you perjured yourself in this hearing, you weren’t on the RPF, were you, in 1989? You  were working in the Golden Era studio, correct?

A I think in 1989 I was on what is considered — what is called the DPF, the Deck Project Force. The reason I say that is because in 1987 when I was removed from my  position and I went to the RPF — Mmm — I think I was there for — until December of ’87.

In December of ’87 I got off the RPF, I started trying to practice auditing again. I did that for some time and really didn’t want to do it anymore.

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Toward the end of ’88, I believe, a security guard at Golden Era Productions got kind of rough with my wife.

THE COURT: You know, this really doesn’t matter where he was. You weren’t in RPF.

A No, I was in DPF. I wasn’t in Golden Era Productions, I mean, working in the studios, as you suggested. I was actually on the DPF. And this is the same  period I did that watch with Mrs. Brooks, Terese or — or Teresita —

BY MR. WEINBERG:

Q That was in ’88?

A That was in ’88?

Q Yes. You say things were hopeless for you?

Things were hopeless for you in 1997 and 1998, as well, wasn’t it?

A I wouldn’t say that.

Q You filed for bankruptcy and went bankrupt in November of — filed in what, May of ’97, and it was finalized in November of ’97, correct?

A I believe there are documents to that effect that have the correct dates.

Q But — but you went bankrupt in 1997, correct?

A Mmm —

Q Yes, or no?

A Yes, I did. I believe that is correct.

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Q So you were broke in 1997?

A I filed for bankruptcy in 1997, but I — I wasn’t able to pay my bills adequately in 1997.

Q And except for Mr. Minton coming like an angel from heaven in June of 1998, you didn’t know what you were going to do?

A Utterly and completely false.

Q After Mr. Minton appeared on the scene you then hooked up with Stacy Brooks, you hooked up with Dan Leipold, you hooked up with Ken Dandar, and since that time this is what you have been doing, getting paid to testify, write affidavits and work against Scientology, correct?

A No, that is absolutely incorrect and it is false.

Q Now, let’s go back to the deposition for a moment.

Now, you testified under oath a lot about the GO and OSA and all that. Do you remember that, here in this proceeding? You said you had all this knowledge about the kinds of activities that had gone on. Do you remember that?

A No, I think you are mischaracterizing my earlier testimony. I don’t think that the words Guardian’s Office exited my lips during these proceedings. I have spoke about OSA and I have — I have presented Mr. Hubbard’s eternal words on — on what intelligence is expected to do, what legal is expected to do and some of what public relations is supposed to do. I think that better characterizes —

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Q Well, let me refresh your recollection, if you remember on June 18 saying, “Question, was there any carryover from the Guardian’s Office to OSA?

“Answer: Yes, there was, there was a carryover of some of the staff and some of the policies. Then you went on to say, “Question, was OSA still Department 20 like the Guardian’s Office was?

You said, “Yes, OSA wanted to make sure they didn’t make the same mistakes as the past Guardian Office was. One of the mistakes was putting in writing and detailing some of the operations.”

A Yes, I did.

Q Do you remember that?

A Yes.

Q Now, turn to Page 149, please, of the Yanny deposition.

A Okay.

Q I want you to read Line 5 through Line 16 — Line 5 through Line 13 — 16, I’m sorry.

A To 16?

Q Yes, just read it out loud.

MR. DANDAR: Objection, that is not the way you do it.

THE COURT: That is true.

A I have read it.

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BY MR. WEINBERG:

Q I’ll read it. Did you give — were you asked these questions and give these answers?

MR. DANDAR: Objection, that is not the way you —

THE COURT: Yes, it is the way you do it.

Overruled.

BY MR. WEINBERG:

Q “You ever heard of the GO?

“Answer: Yes.

“Question: What was the GO?

“It was Guardian’s Office.

“Question: And Mary Sue Hubbard was in charge of that for a period of time?

“Answer: I have no knowledge of the Guardian’s Office. I was never associated or affiliated with it in any way.

“Answer (sic): You do know that a number of Guardian’s Office people went to jail?

“Answer: I don’t –”

Then there was objection.

A Okay.

Q Were you asked those questions and give those answers?

A Yes, that is correct.

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Q And that was true or was that perjury, as well, that you had no knowledge of the Guardian’s Office?

A Well, that was true then and it is true now.

Prior to my association with going to Gilman Hot Springs, I had — you know — you know, I had done protests at the behest of the Guardian’s Office where all Scientologists got together, and I think did a demonstration of the courthouse down there at a point in time on — Hebert would — what they do is they have a thing in Scientology called a call to arms —

Q Really, all I asked you, was that true or not and you said it was true that —

A Okay.

Q Using your words, you had no percipient knowledge —

A Well, I don’t want to play —

Q Can I ask my question first?

A I told you that there was — you know, was some association with the Guardian Office, and I tried to clarify that. So you know, I don’t want to get into word games here where you say, well, you said you never did it but suddenly now you have me picketing at the behest of Scientology. I mean, little activities like that, I mean, I popped out of a coffin across the park doing a skit based on something that —

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Q I understand, but you waxed eloquent about the GO  and how it’s the same — OSA was the same, and under oath here you said you didn’t know, didn’t have information about the GO. You didn’t know anything about it.

A No, I think you are confused on that issue, Mr. Weinberg.

Q Now, do you remember testifying in this proceeding that — that you were — had responsibility for legal, intelligence and PR activities of OSA? Do you remember  that?

A Yes.

Q Particularly intelligence activities of OSA, that was your testimony?

THE COURT: Could you define or tell him — I don’t remember, was it here in this hearing?

MR. WEINBERG: That is what I said. I was just reading from his testimony.

THE COURT: Here?

MR. WEINBERG: Yes.

THE COURT: Okay.

BY MR. WEINBERG: Q I’ll read — this is the dirty — when I say dirty, this is the —

THE COURT: Dirty copy, I know.

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BY MR. WEINBERG:

Q The dirty copy, but on my Page 71 of the dirty copy, which is obviously not the actual transcript, what it says is, “As I mentioned –” this is your answer — “we used to do the technology side of Scientology. Then there was a separate area, areas that I also had responsibility for.

And those were legal, intelligence and PR activities of OSA which is a separate network in Scientology.”

That was your testimony, right?

A Yes. Yes.

Q Now, I want you to turn, if you will, Mr. Prince,to Page 77, first, of your Yanny depo. While you are looking for it, you were deputy inspector general of RTC, correct?

A Correct.

Q And it was deputy inspector general external was your actual — DIG external, right?

A Right.

Q Did you — if you go to the bottom of the page, Line 22, were you asked this question and did you give this answer.

“Question: Back when you were the DIG external, did you have any responsibility for intelligence?

“Answer: Not particularly.

“Question: Is there a group or subgroup within

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Scientology organization referred to as Intel?

“Answer: No, not that I know of.

“Question: Has Intel ever been part of your job description?

“Answer: No.

“Have you ever had any responsibility for Intel?

“Answer: No.”

Were you asked those questions and did you give those answers?

A Yes, I did.

Q And was that truthful testimony?

A Yes, it was. And you know, in — inasmuch as it — that it was deceptive testimony because we’ve sat here and we’ve gone over all of these Scientology issues, now  that says intelligence action, this, that and other thing, but when the GO was gotten rid of, the section that was called intelligence was no longer called intelligence; it was called the information bureau. And I think if you look at a current organization chart for the Office of Special Affairs, you will find that it says information bureau. It doesn’t say intelligence bureau. But if you look at the materials that the persons are trained on in the information bureau, it is intelligence.

Q It is sort of like your testimony yesterday where I asked you about the picket sign, you know, in front of

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Mr. Minton’s house and you said you didn’t own a sign?

A You know, I don’t know about that, Mr. —

Q Was that truthful but deceptive testimony, or is that sort of like an example of what you’re talking about?

A I don’t know about that analogy, Mr. Weinberg. I think you are confused on that issue and you are mixing apples and oranges. But I pretty much answered your  question with this.

Q All right. So this is truthful but — and so what is — by the way, just so — it’s not perjury when you tell the truth but you are deceptive? In your mind, that is okay?

A Well, you know, I’m —

Q Just answer the question.

A I’m not going to draw a legal conclusions. You are the trained lawyer here. I’m the trained Scientologist.

Q You are the trained witness.

A I can tell you about that. I can’t tell you about the lawyering so much. I can’t explain the law to you. You can explain that to me.

Q Explain to me how you are being truthful when you are being deceptive?

A By the mere fact being deceptive, you are not being totally honest. But then again, as I understand the law, you are not obligated to answer but an exact question,

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and the exact question here was about intelligence and — and again, I’ll tell you, when the GO was changed, the word “intelligence” was gotten rid of and the word “information” was put in there; information bureau, information department.

So if they would have said information department, I could have answered these questions a little differently.

But I didn’t say, oh, you know, well, they changed intelligence to information because no person wants a witness walking in just blah-blah-blah, blah-blah-blah. Answer the question you are asked and that is it, okay.

THE COURT: Sort of like you are doing now?

THE WITNESS: Okay.

BY MR. WEINBERG:

Q So why did you use the word “intelligence” when you testified for Mr. Dandar? I just read you the testimony. “In those areas that I was responsible for,  legal, intelligence and PR activities of OSA,” why did you use the word “intelligence”?

A Because I was able to take the eternal words of L. Ron Hubbard that had that on there and show it. I used it because that is what the issue says.

Q And by the way, that is acceptable to you to give truthful but deceptive testimony? That is acceptable to you as you sit here as a so-called expert in Scientology?

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A It is acceptable to me to answer — answer the question that is asked.

Q So I have got to ask the absolutely right question or you can deceive me and there is no problem here? You can deceive me and the Court? And everybody else that is — that is in this room?

A Mmm, well, you know, you can call it deception or you can call it inadequate lawyering. I mean, I don’t know. What do you want to say about it?

Q Well, have you had any of those answers while you have been on the stand, those truthful but deceptive answers? Can you think of a couple where we just missed the question a little bit?

A You know, Mr. Weinberg, I think I’m making a valiant effort here to keep perspective and keep things in perspective. And I think I have gone overboard in explaining my rationale.

THE COURT: The question is, Mr. Prince, is there any time in this hearing you have not told the absolute whole truth, that is what the oath is, the truth, whole truth and nothing but the truth?

THE WITNESS: No, there is not.

THE COURT: All right.

BY MR. WEINBERG:

Q Now, you testified, I think — correct me if I’m

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wrong — a number of times that — that Mr. Miscavige was deeply involved in the activities of you and Ms. Aznaran at the RTC and that — and that you and her reported to Mr. Miscavige when you were there. Is that right?

A Mmm, partially right. I — I don’t — don’t remember saying Miscavige was deeply involved with me and Mrs. Aznaran in RTC. I don’t remember —

THE COURT: He did say he reported —

THE WITNESS: Yes, but the other part, I —

BY MR. WEINBERG:

Q Let’s make it clear because that is actually the question I wanted to ask you. You said — you testified under oath you reported to David Miscavige while you were  DIG external at RTC?

A I — ultimately, I did report to him, yes.

THE COURT: Frankly, I think he said he reported to Vicki Aznaran.

MR. WEINBERG: I’m just asking him now — we’ll, I’ll read you what he said.

THE COURT: You have to read him what he says because I can’t even remember, myself.

BY MR. WEINBERG:

Q This is actually the real transcript, Page 342, lines 19 through 25. And this is in response to a question from Mr. Dandar. And you say: “Answer: So you know from

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the –”

THE COURT: Read the question.

MR. WEINBERG: That is what I’m trying to find.

There was a lot of interruptions.

MR. DANDAR: Well, that is surprising!

BY MR. WEINBERG:

Q Mr. Prince just starts talking. There was — there was dialogue about the Clearwater Police Department.

THE COURT: Well, let me hear what it is you are wanting to read to him, then we’ll see if he can remember this testimony.

BY MR. WEINBERG:

Q Okay.

“Answer: So you know from the limited time that I was there in Religious Technology Center myself, I know that — you know, there wasn’t much about the Flag Service  Organization I didn’t know about and also had responsibilities for to make sure the whole thing ran smoothly, and the person that I reported to was certainly the — ultimately was Mr. Miscavige.”

That is what you said?

A Correct. That doesn’t mean to the exclusion of  Mrs. Aznaran who was my direct —

Q No, I didn’t — wasn’t suggesting that.

A Okay.

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Q Now, if you’ll go to — by the way, did you also report to Marty Rathbun back then?

A Yes. Yes.

Q If you go to Page 52 of the Yanny deposition, please —

A Was that 52, Mr. Weinberg?

Q Yes, 52.

A Okay.

Q Look at Line 15 through 19.

“Question –” were you asked these questions and gave these answers under oath.

“Question: Back in this ’84, ’86 time period did you ever have an occasion to report to Marty Rathbun?

“Answer: No.

“Question: Did you ever report to David Miscavige?

“Answer: No.”

A Right.

Q Were you asked those questions, did you give those answers?

A Yes, I did.

Q Were those truthful answers?

A No, they were not.

Q So you perjured yourself?

A Correct.

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THE COURT: I honestly don’t want you to use the word “perjury.” Perjury is a term of law.

MR. WEINBERG: Okay.

THE COURT: Lie would be fine.

MR. WEINBERG: Well, I have had judges tell me not to use lie because it is inflammatory.

THE COURT: If that were in front of a jury, that may be true, but for me in this particular proceeding perjury is a term of law.

MR. WEINBERG: Fine.

THE COURT: If you say is that a lie, that would be fine.

BY MR. WEINBERG:

Q Was that a lie?

A Yes, it was.

Q And did somebody instruct you to lie?

A Yes. Again, Mr. Earle Cooley, Mr. Rathbun.

Again, I’m being a good Scientologist and I’m protecting Scientology.

Q And you’re not being a good anti-Scientologist as you sit on the stand in this proceeding and write affidavits and stuff like that, correct?

A I’m sorry, I didn’t understand the question.

Q Well, is there a code of ethics for people like you that are part of the anti-Scientology movement?

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MR. DANDAR: I’ll object to the phrase “Anti-Scientology movement.” I don’t know if that has been established anywhere.

THE COURT: I think you need to save that for another time.

MR. WEINBERG: Okay.

BY MR. WEINBERG:

Q Is there a code of ethics, did you and members of the A team and those people that were carrying the signs for the Lisa McPherson Trust that we saw that video yesterday, was there some code of ethics as to what you guys were going to do when you were under oath?

A Mr. Weinberg, no one carried a sign for the Lisa McPherson Trust. You know, you make it impossible for me to answer these questions when you draw these conclusions and inferences that simply are just not true.

Q Well —

THE COURT: So the question is, was there a code of ethics that you and Mr. Minton and —

MR. WEINBERG: Ms. Brooks.

THE COURT: — Ms. Brooks developed when you were to testify?

THE WITNESS: No.

THE COURT: In this proceeding?

THE WITNESS: No. The answer to the question,

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your Honor, is no.

BY MR. WEINBERG:

Q Now, you have testified again today about the RPF and I believe that on direct — and I’ll read you your testimony if you don’t remember it, but I believe that you have referred to the RPF as being a concentration camp or something like that, correct?

THE COURT: Prison camp.

A Prison camp.

MR. WEINBERG: Actually, in this transcript it says concentration camp on Page 456.

THE COURT: I heard prison camp for sure.

Prison, concentration camp, I guess they’re all the same.

MR. WEINBERG: Well, actually —

THE COURT: They’re not.

MR. WEINBERG: In my mind a concentration camp brings images of Nazi Germany, and a prison camp, you know, we have them in Florida. But —

MR. DANDAR: Well, Japanese had concentration camps in the United States. We had —

MR. WEINBERG: I’m not even going there.

MR. DANDAR: There must be a difference.

THE COURT: Maybe not to this particular witness. He may not — not make a distinction.

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THE WITNESS: Well, actually, your Honor, I think there is a distinction in that I think the Rehabilitation Project Force is more akin to a concentration camp in that part of the program is to have not — not only to have a mind-altering experience, but to have a total revamping of the way you were before.

THE COURT: Okay. So you refer to it as a concentration camp?

THE WITNESS: Yes.

BY MR. WEINBERG:

Q By the way, did you lose a lot of weight when you were in the RPF?

A Which time?

Q I mean, did you get meals?

A Which time?

Q You said you were in twice, I believe.

A Right. So you mean both times?

THE COURT: Either time.

BY MR. WEINBERG:

Q Either time.

A The first time I lost weight dramatically. I think I got down to 144 pounds because we weren’t allowed to eat regular food, we had to eat fruit and — and protein supplement called Progest. Then we had to run around with

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plastic suits on our body to, quote/unquote, get the impurities out. This is all we were allowed to eat is fruit and Progest.

Q That was in the ’70s?

A That was ’77.

Q So then in ’87 when, you know, everything came down on you and you got —

A I lost weight there, too, yes.

Q Were you running around drinking protein drinks and wearing sweat suits?

A No, not the second time.

Q Now, you testified that you were — let me quote — “forcibly,” quote/unquote, that is what you said here, “removed from the RTC.” That is what you said on the stand.

A Yes.

Q Do you remember that? Now, when you said forcibly, what — what were you referring to?

A Well, I was referring to a couple of things.

Prior to assuming any position as a board member in the Scientology conglomerate, the one thing that you’re asked to do in order to have this position is to sign an undated resignation.

After signing an undated resignation, then you are  allowed to be a corporate officer, on the board of directors

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or — or some such like that, you know, having to do with corporate matters.

So I was a — on the board of directors of the Religious Technology Center. I was the treasurer. But when I was graced with that position I also at that time had to sign an undated resignation. Again, I was woken up at I guess 5 o’clock in the morning with 12 people in — security guards wearing uniforms like they’re on a mission, and I was told that I was removed, I was shown my undated resignation so that, you know — and this is a legal process. And apparently this is a problem that they had, but I won’t diverge, but this and this, and I was told, “You stand up, you call me sir.”

Miscavige wanted me to do that, and I didn’t want to do it.

So they grabbed me and they started jumping me.

Q All right. That is the gun thing?

A Right.

Q The gun thing?

A Right. We talked about that yesterday.

THE COURT: Are you also talking about the fact your resignation was filled in, is that what you considered part of forcible removal? Or not?

THE WITNESS: Yes.

THE COURT: So when you mentioned that, that is also part of your forcibly removed because it was

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filled in and, therefore, you were removed?

THE WITNESS: Yes.

BY MR. WEINBERG:

Q Now, you understood when Scientology reorganized in the early ’80s and created RTC and CSI and a variety of other corporations, you understood that there was a corporate structure then that was very clear and defined in corporate documents, correct?

A Before —

Q You understood that?

A Before or after — I guess — there was a corporate structure before they created RTC, CSI, all these other corporations?

Q No, I said you understood in the early ’80s, the Church of Scientology reorganized with a new corporate structure —

A Right.

Q — including the RTC, CSI, which was the mother church, and all the churches under them. You understood that, right?

A Yes. Yes.

Q And there was a very detailed corporate structure with — with articles of incorporation and various agreements that set forth clearly the corporate way in which various — Scientology would be run, correct?

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A Correct.

Q And that was the wish and desire of L. Ron  Hubbard, who was still alive that that happened, that there be this reorganization of the church?

A You know, I can’t say that that is true. I can’t —

THE COURT: Who would care? The idea there was a corporate reorganization, surely this is going somewhere.

MR. WEINBERG: It is going somewhere.

THE COURT: Get there.

BY MR. WEINBERG:

Q The RTC was composed of a board of directors.

Correct?

A That was part of it, sure.

Q And there were trustees?

A Correct.

Q In fact, there were trustees in every Scientology corporation, correct?

A Well, I came to learn that in 1987. But you are correct.

Q Well, you learned when you joined RTC that there were trustees, there were three trustees?

A No. No. No.

Q Well, what you learned is that the trustees had

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one function, correct, and that is to — that is to — to name or remove directors. You understood that, didn’t you?

A No, sir.

Q And you were removed in 1987, along with Ms. Aznaran, by the trustees of RTC, one of which was Mr. Miscavige, correct?

A Incorrect. I was removed by one person, only one person’s will, on one person’s authority, and that was Mr. Miscavige.

Q Was he one of the trustees of RTC?

A Yes. And this got explained to me as he was doing this. You know, he — you know, and I guess I was a bit naive, you know, I didn’t know. I wasn’t a corporate person. I’m not trained, you know.

And he explained it to me very well. He said, “Look, I am a trustee. Norman is a trustee.” I think Marty may have been a trustee or Steve Marlowe may have been a trustee. I’m not sure. And he explained to me how it worked.

And he said, “Here is your undated resignation and you have officially resigned and this is how it works and we have the authority to do that.” And at that point I was cognizant of how it worked.

Q Are you saying that for the five years that you were in RTC and for the three or so that you were a board

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member and, you said, the number two person at RTC, you didn’t know that there were trustees that had the ability to — to remove you?

A Correct.

Q But you are an expert on the corporate structure of Scientology?

A I have never said I am an expert on the corporate structure of Scientology, Mr. Weinberg. I said that I am an expert in the — in the policies, bulletins and issues that are Scientology. That is Scientology.

Q If you go to Page 16 of your deposition —

THE COURT: Which deposition?

MR. WEINBERG: I’m sorry, the Yanny deposition.

BY MR. WEINBERG:

Q The —

A I’m not quite there.

Q Okay.

A Okay. I’m there.

Q Okay, Line 4, question — were you asked these questions and did you give these answers — and you will see there is one date that is wrong, but it is wrong in the transcript, and I think you — it didn’t affect the question.

“Question — Line 4 were you asked this question, “October of ’83 to March of ’87 you were deputy inspector

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general for external affairs.

“Answer: That’s right.

“Question: Was Vicki Aznaran your senior during that entire course of time?

“Answer: Yes.

“Question: Were you out at Gilman Hot Springs?

“Answer: Gilman Hot Springs and Los Angeles.

“Question: What was your next position then in March of ’83.”

That would be obviously March of ’87, I think you understand that by your answer. And did you give this answer.

“Answer: Then I went to the RPF for three months, probably three and a half. Then I was an auditor. I was an auditor at Golden Era, the same place at Gilman Hot Springs, for a while.

“Question: For about three and a half months starting in March of ’83 –” but it is ’87 — “you were in the RPF again?

“Answer: Yes.”

Then I’ll skip to Page 17. Top of the page. Line 3 were you asked this question and gave this answer: “What were the circumstances of your transferring from RTC to Golden Era Productions?

“Answer: Well, when I was in RTC I wanted to go to the RPF because I needed more training. I needed — I

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just needed more skill than I presently had. And that afforded me an opportunity to do that because I could go five hours a day, so I did that and also got auditing, co-audited and life audited, because I audited practically my whole career in Scientology. So I decided to audit for a while.”

Do you see that?

A Yes, I do.

Q Were you asked those questions, did you give those answers?

A Yes, I did.

Q So that was false testimony?

A This was coached testimony by Mr. Earle Cooley, Mr. Rathbun, for the purpose of deposition with Mr. Yanny.

Q So is that a definite category —

THE COURT: That was also false, correct?

THE WITNESS: Yes, yes, your Honor.

THE COURT: You were coached by who?

THE WITNESS: Mr. Earle Cooley and Mr. Marty Rathbun.

BY MR. WEINBERG:

Q Now, that deposition — you were asked questions by whom in that deposition?

A You know, I don’t know. I — I don’t know.

THE COURT: Take a look at the front. It

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should say who was representing Mr. Yanny. Did you give him the front page?

MR. WEINBERG: I gave him the whole deposition. If I could approach, I think I could show him.

THE COURT: Okay.

A Cummings & White. Is that who it was?

BY MR. WEINBERG:

Q Barry Van Sickle. Do you remember Barry Van Sickle?

A Not really.

Q But do you remember this was a deposition, now that we refreshed your recollection, the questions were being asked by Mr. Yanny’s lawyer, not by Mr. Cooley, the ones we went over.

A Okay.

MR. WEINBERG: Just one second, your Honor. I need to move some stuff and get some other stuff.

BY MR. WEINBERG:

Q Now, going to a different subject now, Mr. Prince.

A Are we finished with this?

Q Yes, let me take that back.

THE COURT: Why don’t you go ahead and give that, then, to Mr. Dandar.

MR. WEINBERG: I will.

THE COURT: That will save you all from having to copy it.

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MR. WEINBERG: Is this our only copy? No, we have other copies.

MR. DANDAR: You do have another copy?

MR. WEINBERG: Apparently, somewhere back at the ranch.

THE COURT: But you can go ahead and make yourselves a copy and he can have that one?

MR. WEINBERG: Right. Right.

BY MR. WEINBERG:

Q Now, let’s go back to the LMT now. And I think you said a minute ago that I had some misconception of the LMT and picketing. Did I hear you say that?

A Mmm, that is quite possible, yes.

THE COURT: What he said, Counselor, was that you were suggesting that they were picketing on behalf of LMT, and that wasn’t exactly correct.

THE WITNESS: That is right. That’s right.

BY MR. WEINBERG:

Q But the — part of the purpose — part of what the LMT did in 1999 and 2000 was to picket various buildings of the Church of Scientology?

A You know, Mr. Weinberg, I hear you saying that.

But with every video that you have shown here and you have related to the LMT, there are LMT staff that have never picketed, never wanted to, never would, and would not

769

participate —

THE COURT: Mr. Prince, this is really simple.

Really the question is here, and I don’t think it is that difficult, one of the things that LMT did, those folks who were at LMT, was to picket when they thought it appropriate.

THE WITNESS: Yes, occasionally they would.

THE COURT: Exercising their rights, whatever you want to call it.

THE WITNESS: Yes.

THE COURT: They would at times organize a picket and go picket the Church.

THE WITNESS: Correct.

BY MR. WEINBERG:

Q Now, in January of 2000 you were the consultant, expert, working with Ken Dandar in this case, right?

A Correct.

Q And you were also working in the Wollersheim case, as well, at that time?

A Mmm, more than likely, yes.

Q And you were also vice-president at the LMT?

A Well, we already did LMT. You said I was at the LMT. And I was working with Mr. Dandar. There are two things.

Q I’m focusing on the time, January of —

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A Okay.

Q — 2000, you were the expert for Mr. Dandar —

A Yes, I was the expert for Mr. Dandar, but I don’t think that I immediately assumed work at the Lisa McPherson Trust. I don’t think that is how it happened.

Q Now, I asked you yesterday about you being the big boss at the LMT?

A Yes.

Q And you said no.

A Correct.

MR. WEINBERG: Could we play that video, please.

BY MR. WEINBERG:

Q By the way, do you remember a situation where Mr. Minton handed out parrots to various members at the LMT as Christmas gifts so that — indicating — rather, whether you are a big parrot or little parrot, squawking at Scientology, do you remember that happening?

A I think you are referring to a newspaper — a press that Mr. Minton had — had done and that came up —

THE COURT: Did he give you all parrots?

THE WITNESS: Yes.

THE COURT: Okay.

THE WITNESS: Little ones.

MR. WEINBERG: All right, could we play this?

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This is from the film library, January 5, 2000.

______________________________________

(WHEREUPON, the video was played.)

“I have a little presentation, a little sort of Christmas present for the people who are associated with the Lisa McPherson Trust who have made all this possible. Some of you may be aware that back in December a guy named Dave — no, Rick Barry wrote an article in the Tampa Tribune about — I think the headline was ‘Bob Minton, will he rouse the gorilla?’

“Yes. Yes.

“But the real headline is ‘Lisa McPherson Trust, will they rouse the gorilla.’ And in that article, he referred to — in terms of the gorilla, first of all, he was talking about how this gorilla came to Clearwater 25 years ago, 800-pound gorilla, set himself down in the middle of Clearwater, began buying influence, began buying property, and for the last 25 years they have basically made themselves a force in this community by buying people off one at a time.

“And the — the question that Mr. Barry raised in this article was whether, you know, this small band of parrots would be able to, you know, make a

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difference here in terms of changing the way that this — that this organization is perceived in this community and in terms of the way this organization behaves in this community.

“Well, I remember a good friend of mine, Mark DeLarma, who you all know, said, ‘You thought that was a good article? He, like, called you guys parrots.’ I said, ‘I thought it was a great article.’

“So did I.

“Because it really expressed in a very vivid way how the Lisa McPherson Trust was going to change the way this community interacts and perceives Scientology. And how Scientology will have to — if they want to be healthful here, start acting like an organization that is a church if they want to be called a church.

“So I figured that the first thing that the Lisa McPherson Trust had to do is we had to set up a little — Mmm — mascot for this organization. And everybody who is part of it. So for the first — the first group of — of Christmas presents are for those people who will be based here as part of the organization day in and day out.

“And so the first of those goes — goes to —

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this is my little parrot that we want to have, the staff members of the Lisa McPherson Trust, and the most famous staff member of all is — is Stacy Brooks.

“There you go.

“The president and chief operating — executive officer.

“The next one — the next one, the same parrot, you know, the same parrot, goes to Jesse Prince, the boss of the whole thing. Who we all love.

“Thank you, Bobby.

“And the — and the third — the third of the fifth parrots goes to Mark Bunker, the multimedia king of the world.

“Sweet.

“Who is doing everything he can to keep a straight face while this is going on.

“There is one for me. I want to keep that.

“And then when David gets here, this is for David Cecere. And I have another parrot which is not currently in waiting here, but that is for Kim Baker when she arrives.

“So we’ve got plenty of parrots.

“We’re not done.

“We’re not done. You know — you know, I mean,

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so I would like to make a recommendation that we adopt this parrot as the mascot of the Lisa McPherson Trust so that everybody knows that we are going to make a lot of noise, we’re going to be squawking about what Scientology does in terms of harming people and their abusive and deceptive practices, and we’re going to, as little parrots, we’re going to make a lot of noise and drop a lot of stuff that parrots — come out the back end and help these guys learn the way to behave. Okay?

“So —

“Bravo.

“So now — now — now we have little parrots. We have little parrots for all of the big people who have made all this possible. And the first and most important little parrot goes to Patricia because — because what Patricia has done, to help everybody who is down here, get themselves down here and get them settled in and make them feel comfortable in this — in this whole environment, which is not an easy place for — for former Scientologists to come to. You know, they have been willing to stick their neck out and come down here and really make this organization happen. And so Patricia has really made everybody feel comfortable, she’s — she’s sort

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of like —

“She chased PIs into the bathroom for me.

“Yes, and you — you know — so I — I want Patricia to have a parrot.

“Thank you. Thank you. Thank you very much.

“Ray Emmons has been teaching us all for — and a lot of people didn’t listen for a long time, how this organization really operates. And he did this in Clearwater. He made himself known nationwide in terms of his opposition to Scientology. And the type of organization that they really are underneath the surface. And so I want Ray to know that he’s a parrot, as well. You have been a parrot for a long time.

“Okay.

“Let me have a kiss here, Patricia, because I didn’t do that. Thank you so much.

“The order of the parrot.

“The order of the parrot. This is like the highest award that the Lisa McPherson Trust can bestow upon somebody.

“Now, you know, Peter Alexander has been squawking about Scientology for a long time, even when he was in it, especially toward the end of the time he was in it, when he was — when he was —

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when he was being squawked at by Patricia — you know, rather regularly. So — and Peter has allowed Patricia particularly to devote so much time and energy into helping this organization get off the ground.

“And I just want you to know, Peter, that we’re totally thankful for your help and support in this organization, your being on the board. And I really want all of us to know that this is an incredibly tight-knit little group, and got a lot of hard work to do here in Clearwater. But with people like all of us here and you, Peter, thank you so much for doing this. And I want to present you with a little parrot.

“Yes.

“Thank you, sir. Thank you.

“And I want to — I want to —

“The order of the parrots.

“The order of the parrots.

“I want to talk to you about a theme park.

“Yeah. Yeah.

“Now, the next parrot — the next parrot is for Duncan Pierce, you know, our national coordinator. Our national coordinator.

“Oh, my God.

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“Duncan has been abused by Stacy so much in the last few months that he really deserves a big parrot. But because he’s not here on the staff in the office every day, he can’t get a big parrot, you know, it’s just not part —

“The big parrot —

“Look at Peter.

“It’s — you know, the problem is —

“Patricia? Look at Patricia.

“The problem is it is not in the tech. He can’t have a big parrot. But —

“The standard tech.

“Yeah. Yeah. But — but Duncan has done so much to get us off the ground, as well.

“I don’t know what I would do without him.

“It is amazing. The thing is there are so many people that have really pushed so hard to get this thing going. And, you know, there is no recognition for us. You know, we get abused a lot on the Internet. Our demise has already been scripted by, you know, anti-cult and Diane Richardson. Fine, let them squawk all they want. But the real squawking will be done here in Clearwater by a bunch of parrots. And Duncan is one of those parrots. (Inaudible.)

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“Then for the — and the person who lives the furtherest from Clearwater, Grady Ward, who is standing right here, we have another parrot, because Mr. Ward — Mr. Ward is — is our security expert here. And already — and already during the course of this day he has learned a lot about security. (Inaudible.)

“Yeah, don’t tell me about it. But I can tell you some things about Grady personally because — (Inaudible.)

“Because one of the things that really got me involved in this thing was Grady Ward. And Grady’s stand against Scientology, you know, back in 1995 or — early ’96 when he started going after them directly after they sued him, he went after them as his own attorney, you know. You know what they say about guys who are their own attorney.

“It is perfectly true.

“And it is perfectly true. Grady will be the first to tell you he had no expertise, no competence whatsoever. But he — he studied the law. He studied what Scientology was doing. He — he learned so much about it. And has become a really good legal man in terms of fighting Scientology. And I — you know, I — I can’t — I can’t imagine

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somebody having the patience to understand and go through and traveling back and forth from Arcadia, California, eight hours to San Francisco in his car and memorizing the Rules of Civil Procedure. You know, while he’s going back and forth. And I mean memorizing so he knows every paragraph, every subparagraph, whatever. And — (Inaudible.)

“You know, if you talk about a parrot, then this guy is a parrot. And I want to give — I want to give this guy who is a shining example for many people on the Internet in terms of standing up to somebody who is trying to curtail free speech on the Internet, I want Grady to have this parrot as a symbol of our love for him and his contribution to this whole battle.

“Thank you very much. “Thank you, Grady. Thank you.

“And — and now. (Inaudible.)

“And now this other parrot, I forgot to tell you. I told you this was mine. And this parrot is mine because all of you gave me this parrot and I really appreciate it. So —

“Something about Rob and why he gets a parrot,

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because if it weren’t for him, none of us would be here.

“Absolutely.

“None of us.

“For sure.

“There is nothing else to say.

“Bob is the big parrot.

“Definitely.

“Oh, but this is not all. Oh, some of the best stuff is — some of the best is saved for last. Well, what I would like everybody —

“He’s big with presents, you can see that.

“What I would like everybody to do, if you put the parrots around in a little circle here, if you put the parrots around in a little circle there. (Inaudible.)

“Right, don’t anybody forget — don’t anybody forget — don’t anybody forget. But, you know what the parrots are supposed to do, don’t you? We’re going to get the gorilla. And I didn’t want you to think I forgot about that gorilla. So this gorilla is going to sit right there.

“Whew.

“Don’t dump on the gorilla. Come on. But — but that is what this is all about here.

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little parrots and some of us big parrots here, we’re going to be here and we’re going to make sure this gorilla behaves.

“We’re going to educate this gorilla and —

“We’re going to put the — we’re going to put the gorilla in the cage or the jungle, wherever it belongs.

“We’re going to turn this gorilla into a parrot.

“Yeah, this gorilla is going to be cooperating with us.

“In any case, everybody can take their parrot back now. And I’ll keep the gorilla, so when we have it on the desk out there, it will be —

“Yes, a constant reminder.

“Yes, as a constant reminder of what we need to do.”

BY MR. WEINBERG:

Q Bring back memories, Mr. Prince?

A Very fond memories. I’m so sorry that that place doesn’t exist anymore.

MR. DANDAR: I’ll object because we just went through that long video and with the — the question was — to Mr. Prince, “Mr. Prince, were you called or did you call yourself a big boss at the LMT,” and

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that is not what that video showed. Mr. Minton called Mr. Prince a boss of the whole thing. So — so whatever Mr. Weinberg’s question was was not supported by the video.

THE COURT: Well, it certainly is a video that he could play at some other time so he played it now.

MR. WEINBERG: Right.

THE COURT: But it is true, he was not called a big boss —

MR. WEINBERG: He was called the boss of the whole thing.

THE COURT: But I think Mr. Minton made it clear he was the big boss.

MR. WEINBERG: Right.

BY MR. WEINBERG:

Q Now, Mr. Prince, I asked you a lot of questions about what the Lisa McPherson Trust was about. That meeting there was initially the start-up meeting of the Lisa McPherson Trust, wasn’t it? It is essentially right at the beginning?

A I think so. You know, I think you are right about that.

Q Right. And Mr. Minton made it very clear what it was about, squawking about Scientology. That is what the

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Lisa McPherson Trust was about, wasn’t it?

A No, sir. It was about making Scientology behave.

I think that was also part of this video. Just to behave. Be decent.

Q Putting the gorilla in the cage? Was that what it was about?

A Or in the jungle, wherever it belonged.

Q What does that mean, “or in the jungle, wherever it belonged”?

A Well, it means everything has its place, Mr. Weinberg. And there is hardly anything sinister about what we just watched here.

Q “We’re going to make a lot of noise,” that means you are going to disrupt the activities of the Church of Scientology in Clearwater, right?

A No, Mr. Weinberg. That means that we’re going to expose the deceptive and abusive practices of Scientology and help those who have been victimized by it. That is what we were talking about there.

Q And at that time when you got the second parrot for being the boss of the whole thing, you were supposedly the full-time expert for Ken Dandar, correct?

A I was working for Mr. Dandar as his expert. I wouldn’t go as far as to say full-time. I mean, even you brought up the fact I was working on the Wollersheim case,

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as well, simultaneously.

Q We’ll get to the — we’ll get — I’ll ask you one question. From June of ’99 until May of 2000 you were getting $5,000 a month from Dandar & Dandar?

A I think the record reflects that, Mr. Weinberg.

Q And this was in that period of time, wasn’t it, this parrot thing?

A I believe it was.

Q Now, you saw this meeting and you were at a number of meetings with Mr. Minton, correct, over the years? You have been with him a lot?

A Yes, I have been with him a lot.

Q And in this particular meeting and others that you were in, Mr. Minton was pretty outspoken, outgoing, he would take over, right? He would speak his piece? He was in control?

A No. Mr. Minton is not that way. That is the biggest myth. You know, Mr. Minton has exact things that he likes to do and he does them. I mean, I learned a lot from him myself. You know, I have never had millions upon millions of dollars myself. I have never been able to help people the way he has been able to help people. He has a different agenda, a different track. Unfortunately, in some instances he has a very short attention span.

And he never, in any instance, ever wants to be

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the person that is the leader. I mean, he doesn’t — he doesn’t do that. You know, if you want to do it, great. If what you want to do makes sense, great, he’ll support you.

But he’s not going to tell you how to do it.

Q So this was just an aberration?

A No, this was — it was clear what this was.

Mr. Minton was showing his appreciation to persons like Patricia Greenway, myself, Peter Alexander, Duncan Pierce, for helping organize and make the people feel welcome at the Lisa McPherson Trust and helping us be a social — be a social reform group, if nothing else, in order to ultimately help Scientology.

Q By the way, did he look harassed? Did he look like a man that was under some wave of harassment unknown to mankind?

A Actually, he looked like a man giving a speech to a group of people.

Q It looked like he was — that was in the Lisa McPherson Trust building, correct?

A Correct.

Q It looked like all of you, Ms. Greenway, you, Mr. —

THE COURT: What difference does that make they were having fun at the LMT? When gifts were given out?

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MR. WEINBERG: All right. I’ll go on.

BY MR. WEINBERG:

Q Let me ask you a question about Ray Emmons, the guy that put the parrot on his head.

A I know Ray Emmons well.

Q Now, Mr. Emmons had been a Clearwater police officer and had done an investigation of the Church of Scientology in the ’80s, is that right?

A Yes, I believe that is correct.

Q And Mr. Emmons has been and continues to be the investigator for Ken Dandar in this case, you know that?

A I know that Mr. Dandar has used him to do service of process or locate witnesses and things like that.

Q Now, what was Mr. Emmons’ position at the Lisa McPherson Trust?

A I don’t think he had a position. He may have been on the board of directors, which was huge and basically was a friends list. But as far as an official position or coming into that office on a daily basis to work or accomplish a specific task, that was never anything that he did.

MR. WEINBERG: I have a couple E-Mails — or postings I was going to put in, your Honor.

THE COURT: All right. I want to take a break here in five minutes, so if it will take more than

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that, break now. If not, go ahead and do those and we’ll take a break.

MR. WEINBERG: I think we can do those in five minutes. I mean, it is just identifying them.

THE COURT: Okay.

MR. WEINBERG: These are actually E-Mails, I’m told. I have trouble telling the difference.

THE COURT: Yes, I don’t know the difference, either. If they’re up there on the screen and people can read it, to me, it’s an E-Mail.

MR. WEINBERG: Okay, your Honor, this is 223. I didn’t write the number on it.

THE COURT: Okay, I’ll do it.

MR. WEINBERG: And this is 224.

THE COURT: All right.

BY MR. WEINBERG:

Q I’m going to hand you the originals. We’ll put them back when we’re done.

A Okay.

Q All right. If you’ll look at first, Mr. Prince, 223.

A 223? Which one is 223?

Q That is the —

A Okay, I have it here.

Q That is the Jeff Jacobsen —

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THE COURT: It is the long one.

THE WITNESS: Yes, okay.

MR. WEINBERG: I’m really only referring to —

I — we just received these from the Lisa McPherson Trust. I have attached the whole thing, your Honor, but the only page that — that — this is part of the E-Mails that were produced.

THE COURT: All right.

MR. WEINBERG: But really what I’m focusing on is the first page.

BY MR. WEINBERG:

Q Mr. Prince, you can look at it all, but I don’t know if the rest — sometimes it comes off the computer and —

THE COURT: Who is this from?

BY MR. WEINBERG:

Q If you look at this, Mr. Prince, this is from Jeff Jacobsen to you and Mr. Bunker and Stacy Brooks. Who is Karen Case?

A She used to be a person hired specifically to work as public relations.

Q And this is dated August 2, 2000. Is that right?

A Well, you know, okay.

Q Do you see that?

A Yes. I do.

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Q And this is — do you remember having meetings about things that needed to be done at the Lisa McPherson Trust?

MR. DANDAR: Well, Judge, I have to object.

This is not Mr. Prince’s E-Mail so I don’t know how he can question him about some hearsay document authored by somebody that is not here.

THE COURT: Well, I think he can state whether or not this is accurate or not.

MR. WEINBERG: It is to him.

BY MR. WEINBERG:

Q You received this, right, Mr. Prince?

A I have no memory of this.

MR. DANDAR: Which one are you on?

MR. WEINBERG: He’s copied on the E-Mail, it is addressed to him.

THE WITNESS: I don’t even know what this is.

BY MR. WEINBERG:

Q It is an E-Mail to you.

A Okay.

Q Among other people. All right?

A Okay.

Q What it says, “This is a list of things we talked about, elaborated on by me.”

Now, Mr. Jacobsen was also part of the Lisa

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McPherson Trust, correct?

A Yes, he was.

Q In fact, in some of those videos yesterday you saw Mr. Jacobsen in it with a camera himself?

A No, I did not see that yesterday, but —

Q Oh. He did take — he took videos from time to time, didn’t I?

A Yes.

Q Do you know why those videos haven’t been turned over, by the way, his, Mr. Jacobsen’s?

A No, I do not. Were they asked for?

THE COURT: Don’t ask him what he knows or doesn’t know about something like that.

MR. WEINBERG: I’ll ask it a different way.

BY MR. WEINBERG:

Q Do you know where the videos that he took are?

A No, I do not.

Q Were they kept at the Lisa McPherson Trust?

A I don’t know what he did with his personal videos.

Q But, anyway, this — this — this E-Mail talks about a list of things we talked about, 1, speeches, radio talk shows. 2, picket. 3, press releases. 4, press conferences. 5, help with investigations by EEOC, DEB. 6, the library open for public use. 7, concert November 11. 8, newsletter. 9, attend city council meetings,

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participate. 10, put up a sign for the office outside. 11, ads in local newspaper. 12, support group. 13, radiofree Clearwater.”

Now, that is 13 things that the Lisa McPherson Trust, I assume, prioritized to do. Not one says anything about counseling, does it?

A You know, I think you are mischaracterizing this E-Mail to somehow reflect or — or be a staple for the activities of the Lisa McPherson Trust, and what this is is just simply an E-Mail of Jeff writing. I have no recollection of it whatsoever and I don’t even remember what it relates to at this point in time.

I mean, I literally have had thousands of E-Mails, Mr. Weinberg. I’m not trying to be uncooperative, I’m trying to cooperate in the spirit, but what you are asking  me has no perspective. You are tying this into the Lisa McPherson Trust and it just doesn’t make sense to me.

Q Well, does it make sense to you one of the priorities of the Lisa McPherson Trust was pickets? Does that make sense to you?

A No, not at all.

THE COURT: This is really — in fairness, this is a statement from somebody about some meeting and, frankly, you don’t have to persuade me that the Lisa McPherson Trust picketed. I don’t know why you just

792

keep badgering that home. I know what he’s going to say, you know what he’s going to say. It is me that is in charge of this hearing, and I’m persuaded, but the point was not picketing, it was counseling, wasn’t on the list.

You know, that is unfair to suggest because somebody writes a letter with things they talked about on a given day of things that needed to be done, you can hardly assume putting a sign outside is a primary — is something that needs to be done.

It doesn’t say this is our purpose. I mean, fair is fair, Counselor. And that is not fair to suggest that those are the purposes of the LMT.

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

THE COURT: All right. It will be received. It will be received, although it is only being received for the fact that — that we have a bunch of E-mails.

MR. WEINBERG: I understand.

THE COURT: — that I have let in.

MR. WEINBERG: Then 224 quickly is an E-Mail that —

BY MR. WEINBERG:

Q Is this a posting or E-Mail, 224, Mr. Prince?

793

A I have no idea.

Q Well, this is something that you —

A There is no “to”.

THE COURT: It says it is from you.

THE WITNESS: Yes, is this a note to myself? I don’t know what it is.

BY MR. WEINBERG:

Q Do you recognize this as something that you did?

THE COURT: Who is Mark? I know there is a Mark.

THE WITNESS: You know, there are lots of Marks.

BY MR. WEINBERG:

Q I think it is pretty clear, the message at the bottom is a Mark Bunker passage. Then —

A The message at the bottom? Oh, I see what you are saying.

Q Do you see?

A Okay.

Q And my question to you is, your advice was, “With regard to the Lisa McPherson Trust, contact Ken Dandar.”

That is what it says, correct?

A Absolutely not.

Q That is not what it says?

MR. DANDAR: I’ll object. It doesn’t say that,

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either.

A No.

BY MR. WEINBERG:

Q Are you saying, “In the meantime, I recommend you contact U.S. attorney Kennan G. Dandar,” and give his E-Mail address?

THE COURT: What is the date on that?

MR. WEINBERG: It is November 10, 1999.

THE COURT: Before the trust was formed?

MR. WEINBERG: Right — well, the trust actually had already been formed, remember, it was incorporated and it was in the process of being set up.

A You know, this is a partial thing here from Mark. I can’t tell if somebody wrote in and had a legal question and I’m referring them to Ken Dandar, who is a lawyer that could maybe answer a legal question for them, or whether or not they need assistance or the service the trust has to offer. I can’t tell from this. I can’t draw the inference that somehow this means Ken Dandar is running the Lisa McPherson Trust or anything like that.

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

MR. DANDAR: I object. It is too partial to make sense.

795

THE COURT: I’m going to let it in for whatever value it has, which is little, as to a lot of the other E-Mails, because of the same problem.

MR. WEINBERG: So is this a good time to take a break?

THE COURT: It is a good time to take a break.

We’ll be in recess for 15 minutes. I show it is 25 till. That will be about ten till.

MR. WEINBERG: Okay.

(WHEREUPON, a recess was taken from 10:35 to 10:55 a.m.)

_______________________________________

THE COURT: Okay. I signed the order and I mailed out the copies. But those of you who are here, I’ll give you yours. Mr. Dandar. Here is Mr. Lirot’s, too. I didn’t realize he wasn’t here.

Mr. Moxon, Mr. Lieberman, Mr. Fugate. Always trying to save you all some stamp money.

MR. WEINBERG: Everything counts.

THE COURT: Every little bit counts. That is right.

You may continue.

MR. DANDAR: I returned the envelopes to opposing counsel.

THE COURT: All right. Thank you.

MR. DANDAR: So they can save their stamps.

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BY MR. WEINBERG:

Q Now, Mr. Prince, you first learned about Bob Minton after watching a television show Dateline in which he appeared and Ms. Brooks appeared in June of ’98?

A That is incorrect.

Q Did you watch a television show before you met Mr. Minton where you learned about him?

A No, I did not.

Q How did you learn about Mr. Minton?

A Through Mrs. Brooks.

Q So she just reached out for you, you didn’t reach out for her?

A Well, Mr. Weinberg, I think I spoke on this before but I’ll speak on it again.

I was on vacation in Connecticut. I had been in the cyber coffee cafe. I had gone on the Internet. Do you remember that testimony, Mr. Weinberg?

THE COURT: It was rather elaborate.

A I left my phone number and she called me.

(Telephone interruption.)

BY MR. WEINBERG:

Q Did you ever see the Dateline —

THE COURT: Don’t be sorry to him. Be sorry to me. It is my word that says no phone.

THE WITNESS: I’m sorry, I apologize for the

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distraction.

BY MR. WEINBERG:

Q Did you ever see the television show The Crusader, I think on NBC Dateline, where Mr. Minton was featured about his crusade against Scientology?

A Mmm, more than likely, many months to possibly a year after he had done that program, I’d seen it. But I didn’t see it when it ran on national television.

Q Well, you learned, shortly after your call from Ms. Brooks, that Mr. Minton was a very wealthy person who was handing out a lot of money to people that would work against Scientology, correct?

A That is categorically false.

Q Ms. Brooks didn’t tell you that Mr. Minton had given her and Vaughn a lot of money, including the purchase of a $250,000 home?

A At one point in time Mrs. Brooks did relay the information that Mr. Minton had given her and her husband some money and she explained the circumstances about that.

Q Did a relative tell you about the Dateline show featuring —

THE COURT: A relative of whom?

BY MR. WEINBERG:

Q A relative of yours tell you about — in or about this time period before you met Mr. Minton — did a relative

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tell you about having seen this show where Mr. Minton was featured or some friend or some family member?

A A cousin of mine, when I lived in — I guess I must have been still living in Minneapolis and we were in a phone conversation. And she was telling me about a program where she had seen — she had seen concerning Scientology and there was a man that was helping people or somehow got involved in it. She didn’t remember his name. She just remembered — and, you know, as it is with my family, if they see something about Scientology on TV, they tell me about it when I speak to them.

Q Was that before you communicated with Ms. Brooks?

A I believe it was.

Q So when you learned about Ms. Brooks, you already knew about Mr. Minton?

A As I said, she didn’t know Mr. Minton’s name. All she related was, “I saw a story on TV about Scientology and the different things that they do. And there was a man that was helping people that had been in Scientology before.”

Q And did you research, prior to hearing from Ms. Brooks, did you research to learn who this guy was and what he was doing for people who had been in Scientology?

A No. I had not.

Q Now, when did you learn, after communicating with Ms. Brooks, how wealthy Mr. Minton was?

799

A When I spoke to him.

Q And how long after you talked to Ms. Brooks did you talk to Mr. Minton?

A Mmm, maybe a month. Maybe two months.

Q So I was under the impression that on this trip — I guess I’m wrong — this trip to Connecticut, that you went from Connecticut right up to Mr. Minton’s house after talking to Ms. Brooks?

A No, that is incorrect, Mr. Weinberg.

Q So you went home after that?

A Correct.

Q And you stayed in touch —

A Oh, no, no, I’m sorry, you know, because it is so important to make sure the record is correct. From Connecticut, I flew to Ohio and met with Mrs. Brooks and Mr. Haney.

Q And was it at that time that you were given a new car?

A No. No. It was not. And I was never given a new car by anyone.

Q Somebody purchased it? Mr. Minton purchased a new car for you or caused a new car to be purchased for you?

A No. That is incorrect.

Q Well, how did you get the $23,000 Rodeo vehicle?

A I never got a $23,000 Rodeo. I had use of a

800

$23,000 Rodeo but that $23,000 Rodeo belonged to FACTNet, and when I terminated my employment with them, that car stayed with FACTNet. You understand?

Q Now, that was purchased where, the car?

A In —

THE COURT: Where like what dealer? What city?

BY MR. WEINBERG:

Q What city? What city?

A You know, I don’t remember the name of the city.

Q But it was in Ohio, that area, either Minneapolis or Ohio, correct?

A Correct.

Q And did —

A Well, wait a minute. Let me not do this thing because you accused me of this earlier. It was in Minneapolis specifically. I know the specific answer. I’m not going to play charades here with you. It was in a place near Minneapolis, a city that was near Minneapolis, and I don’t specifically recall the name of the city.

Q And it was purchased new, is that correct?

A Yes.

Q And you and who went to pick it up at the dealer?

A Mmm, a friend of mine — Mmm — took me — drove me to the dealership to pick it up.

Q And did you have a check with you? How was it

801

paid for?

A No. I didn’t have a check.

Q Ms. Brooks took care of paying for the car? Is that what happened?

A No. Ms. Brooks did not — well, you know, I don’t think so. But quite factually, I don’t know who — how that part of it happened.

Q There just happened to be a new car waiting for you at the dealership?

A No. They needed a vehicle for FACTNet. You know, let me — if you have patience with me, I’ll tell you the — what happened there.

They needed a car in Boulder —

Q Boulder, Colorado?

A Boulder, Colorado, which is where FACTNet was located. I was going to FACTNet to assist in that organization. The car was purchased. I moved everything that I had in Minneapolis and moved to Boulder, Colorado. I made that move to at least be safe or — or to be around some people that could offer some protection to me, because  after I’d contacted Mr. — Mr. Minton, the private investigators started, the threatening letters to sue me from Scientology started. And I was alone in Minneapolis, and it was like, “Okay, come here, we’ll help you, we’ll protect you, we have lawyers,” whatever.

802

Q You were alone and bankrupt in Minneapolis, right?

A I had filed bankruptcy in 1997. I think the year we’re talking about now is 1998.

Q June of 1998. Bankruptcy in November of 1997, right? Your next real job after bankruptcy was to be paid by FACTNet and Mr. Minton, correct?

A That is completely false.

Q Now —

A You want to know what my next job was or you just want to leave it like that.

Q Tell me what your next job was.

A I was self-employed. I had an art business called The Art Guy. I had a kiosk in the mall in downtown Minneapolis. I was making my own money and I was actually doing pretty good for myself.

Q But something encouraged you, prompted you, to pick up and leave Minneapolis and move to Boulder, Colorado, at which time you became associated with FACTNet and started being a paid witness in various Scientology cases, correct?

A I think you have added a little bit of baggage on that. But what actually occurred is I left Minneapolis with my business intact. I had employees in Wisconsin and employees in Minneapolis, and I left and went to Boulder, Colorado.

Q Driving this car?

803

A Correct.

Q And you drove this car for how long? How many months did you drive this new car that somebody paid for that you picked up new?

A Off and on, maybe about three months.

Q Now, after — but before you moved to Boulder, you went to New Hampshire to visit Mr. Minton?

A Yes.

Q And you and who went to New Hampshire to visit Mr. Minton?

A It was just myself.

Q And he flew you to New Hampshire?

A I — I believe the way the scenario worked is Mrs. Brooks arranged flight — airfare, the flight, for me to fly there, yes.

Q Much like she had arranged the car to be purchased?

A I think we’re mixing apples and oranges here because I think I stated earlier in the testimony I’m not quite sure who did that on behalf of FACTNet. That car was purchased in FACTNet’s name. It was never in Jesse Prince’s name, Bob Minton’s name, Stacy Brooks’s name. It was a corporate car. That is the way it was purchased and that is the way it was left.

Q And the person that was financing FACTNet at the

804

time was Bob Minton?

A Mmm, no.

Q Did Mr. — one last question about the car. Did Mr. Haney provide the funds for the car, Brian Haney?

A Not that I’m aware of. But then again, I don’t know the details of it. I know that — I think Mr. Haney did have some association with FACTNet at the time.

Q And what were you seeing Mr. Haney in Ohio about with Ms. Young?

A I mean, I had never known Mr. Haney. I didn’t know who he was. He just happened to be there. I was there to visit with Stacy.

The visit with Stacy — her and I have been associated — associated and friends through Scientology since 1976. She was one of the very first persons that I  met when I joined the Sea Org. And we were just happy to see each other. Her ex-husband, Vaughn Young, and I were very good friends. You know, he was an executive and we  were friends, and it was — and from leaving Scientology — because when you leave and you are ostracized, people disconnect from you; you are a suppressive person, degraded being, whatever, you don’t have any friends anymore. But to actually encounter someone from Scientology that you knew before that will talk to you because you are not a Scientology is a rare thing.

805

Q Now, the Youngs left in 1989, correct?

A Yes, I assume that, yes.

Q You left in 1992?

A Yes.

Q But you didn’t communicate with the Youngs until Mr. Minton came on the scene in 1998, after you left Scientology, correct?

A I think that is a mischaracterization of my earlier testimony, Mr. Weinberg. Because I think the way I testified, and again I’ll go through the whole thing —

Q No, just answer that question.

A But I wrote an E-mail from a cybercafe that said, “If you know Vaughn Young or Stacy Brooks, please give them my phone number.” Mr. Minton was not part of the equation.

Q My question was you didn’t have any communication with Vaughn or Stacy Young after you left Scientology in 1992 until this cybercafe thing in 1998?

A Correct.

Q As far as you know, they didn’t reach out for you prior to that time, either, is that correct, as far as you know?

A As far as I know.

Q Now, Stacy Young must have told you, when you were in Ohio with her and Brian Haney, she must have told you about the activities that she and Vaughn, her husband, had

806

been involved in for the past four years concerning cases involving Scientology. She told you about that, didn’t she?

A In our first meeting?

Q When you —

A Oh, when I went to Ohio? Are you talking about the Ohio trip?

Q Yes.

A There may have been a brief mention of that, what she was doing. But for sure the substance and the bulk of our conversation was the fact that we were together, we were alive, we actually made it out somewhat sane people and we were just happy to see each other.

Q Did she tell you she and her husband had been making a living off testifying and being experts in cases against Scientology for the past three or four years?

A No, she did not.

Q Did she tell you you had a good opportunity to — to get in on the gravy train, so to speak? Did she tell you that?

A I take offense to that characterization. But that statement is categorically false.

Q Did she tell you that you had the opportunity to make money by being — by working with lawyers in cases involving Scientology? Did she tell you that?

A No, she did not.

807

Q So you didn’t have any discussion about you getting involved in any of these cases?

A At that point in time in Ohio, no, we did not.

Q There came a point in time where you did talk to Stacy about that?

A Yes.

Q And when was that?

A Mmm, I’m not quite sure. It was maybe some months later or — I’m not quite sure. But I think while we were talking she was telling me about FACTNet. She was telling me about this organization which, in some respects, was similar to the Lisa McPherson Trust which had as its intention of providing information and doing what it can to assist people or persons who felt they had been victimized by Scientology. And —

THE COURT: Was FACTNet just Scientology or was it cults in general?

THE WITNESS: Cults in general, you know, the whole subject. Very broad.

BY MR. WEINBERG:

Q It was primarily Scientology, though, wasn’t it?

A No. If you go on their website, you know, Scientology has its place, but there are many other cults that they have provided information, ex-members speaking

808

about it, you know.

Q Well, the staff members of FACTNet tended to be people that were more interested in Scientology or had had some involvement with Scientology as opposed to other groups. Correct?

A No. That is actually false. There was one person that was a staff — that was a staff member in FACTNet, I think her name was Justine. She was a Christian woman that had never been in Scientology before.

Q You are telling me so you learned about how you could make some money involving Scientology from Ms. Brooks.

So when did that happen?

A You know, I —

THE COURT: Make some money involving Scientology? That doesn’t make sense.

BY MR. WEINBERG:

Q Who was the first person that told you –suggested to you that you might be — you might be a witness and could be paid as a, quote, expert on Scientology? Who told you that?

A No one told me that, Mr. Weinberg.

Q Who asked you to be involved in the first case that you got involved in?

A Mr. Leipold.

Q He just reached out for you?

809

A He was an associate of Mrs. Brooks. Mrs. Brooks was explaining to me about FACTNet. And the whole subject came about because we were talking about being in touch with people that we had lost contact with, old friends that were in Scientology. So she was introducing me, “Well, you know, another person, you know, people from Los Angeles, hey, do you know this one? He’s out.” And Andre Tabayoyon, I think I spoke with him. We were just talking about the people that we knew in Scientology that were no longer there that were out, you know, getting on with their lives, doing what they do.

Q What were you doing in Ohio with Mr. Haney and Ms. Brooks? I mean, why Ohio? You live in Minneapolis. She lived in Seattle. Why were you in Ohio?

A That is where she was when she called me. And I was in Connecticut and she was in Ohio.

Q Is there something special in Ohio?

A I think that is where Mr. Haney lives. She was in Columbus, Ohio. That is where Mr. Haney lives.

Q You went to New Hampshire. How did you get in touch with Mr. Minton? Did you call him? He call you?

A I think I answered this before. This happened through Mrs. Brooks. I met Mrs. Brooks, and then I had — you know, sometime after that I spoke to Mr. Minton on the phone and maybe a month or two later actually went to visit

810

with him.

Q He flew you to New Hampshire —

THE COURT: He said he didn’t know who paid for the ticket. We can assume it was Mr. Minton, directly or indirectly.

MR. WEINBERG: Right.

BY MR. WEINBERG:

Q Somebody arranged for you to fly to New Hampshire, right?

A Stacy Brooks.

Q All right. But she wasn’t at this weekend — was it a weekend?

A Actually a couple weeks.

Q You were at Mr. Minton’s house for a couple weeks?

A Yes.

Q Who else was there other than you and Mr. Minton?

A His family would come occasionally. His wife. His children.

Q And anybody — I mean, other than his family, anybody else?

A No.

Q What did you-all — did you talk about Scientology in those two weeks?

A Yes, we did. We talked about Scientology. We talked about why — why he became involved. What this was

811

all about. He was very interested to know my involvement, my history, compared to other people that he had talked to.

And again, this is all in reference to, hey, you know, these ex-people, these people that used to be in and now they are not in and now they’re getting together and talking to each other and it is okay to do that.

Q And did he give you some money, some expense money at that point, either before the trip or during the visit or after the trip?

A No. No. I don’t think so.

Q Did he pay for your expenses to move from Minneapolis to Denver?

A Yes.

Q And —

MR. DANDAR: I object because we have got to establish a time frame here. It sounds like it all happened on the same day.

THE COURT: That is true. Whatever the time frame is, I don’t think it all happened on the same day.

MR. DANDAR: All right.

A It didn’t.

BY MR. WEINBERG:

Q It didn’t. I’m not suggesting that. Do you remember how much he gave you to move from Minneapolis to

812

Denver?

A Mmm, $10,000.

Q In a check? Cash? I mean, how did you get the money?

THE COURT: What difference does it make?

MR. WEINBERG: Probably not.

THE COURT: It doesn’t make any difference.

MR. DANDAR: Right.

BY MR. WEINBERG:

Q Where did you get the money? I mean, did this happen in New Hampshire? Or did it happen after the trip to New Hampshire that he gave you the $10,000?

A You know, I’m not sure because, you know, I made a couple of trips to New Hampshire. So I’m not really sure how that came about. But I’ll do the best I can to explain it to you, Mr. Weinberg.

I went there once, I stayed there for a couple of weeks, came back to Minneapolis. The threats started. I was starting to get letters from Elliot Abelson, Scientology attorney in Chicago, letting me know I would be sued. I had private investigators starting a noisy investigation in my neighborhood. And I think I alerted Mr. Minton and Mrs. Brooks, I said, “Look, I can’t believe this whole thing is starting all over again.” You know — you are right, I did do the bankruptcy thing. I cut ties with Scientology

813

completely. I was done with it. I didn’t want another thing to do with it. You know, it is kind of like every time you put your hand in the fire, you know you are going to get burned. I was done.

Q You were done but then you decided to get involved in cases against Scientology?

A Then I went to meet these people and my freedom of association was trying to be inhibited from Scientology — by Scientology. They didn’t want me to associate with these people. There were no — no criminal activity occurred, nothing happened. I’m simply talking to people that used to be in Scientology.

Q All I asked you, did you get the money from Mr. Minton during your trips to New Hampshire or after. That is all I asked, and if you don’t remember just —

A In one of the trips.

Q — just tell me you don’t know.

A In one of the trips, Mr. Weinberg, I did get the money from him to move.

Q Now, did Mr. Minton tell you that he would, in essence, take care of you thereafter to support you with regard to your work involving Scientology?

A No, he did not.

Q But in reality, that is what happened for the next four years, didn’t it?

814

A No, it is not.

Q Well, you began to get money from Mr. Minton after this first $10,000, correct? I mean, from that point on for the next four years you received money, directly or indirectly, from Bob Minton on a monthly basis, didn’t you?

A Mr. Weinberg, I received money from FACTNet when I started working for FACTNet, when I moved from Minneapolis to Boulder, Colorado. I started to receive some — and very little from FACTNet. The fact of the matter is that I was able to live and do what I was doing because I had been — I had my own business, I had staff working for me in two states. I was receiving regular moneys from profits that I had made. And this was where the bulk of my money was coming from.

Q So you had all these profits that you had accumulated after the November bankruptcy between November and June of ’98?

A Correct.

Q Okay. Now, you got the $10,000 from Mr. Minton.

And how much money do you remember that you received from FACTNet?

A Maybe a couple of thousand. You know, one month.

A thousand another. You know, it was kind of back and forth.

Q And then you came — then, shortly after this, you

815

came to Florida in the fall of 1998 to begin work with regard to the PC folders in this case. Correct? You flew to Florida?

A Correct.

Q And you spent how many days with Ms. Brooks reviewing the PC folders of Lisa McPherson in the fall of ’98?

A You know, I’m not sure, but it was like many days, maybe even more than a week. And it was something I came back to, as well, and participated in getting the folders copied. So this whole thing with the folders started in December but it went through a period of time, a month’s period of time of going through those folders.

Q So at that point when you first came you were now officially on board as an expert for Mr. Dandar in the Lisa McPherson matter, correct?

A I — I wouldn’t say that. The reason why Mr. Dandar wanted me to go through those folders is because of my expertise in Scientology, my prior technical experience, the many courses and certificates and internships I had finished.

THE COURT: Were you his consultant, as well?

THE WITNESS: Not at that time. I just came down to do the preclear folders. Mr. Dandar and I did not have a relationship because we didn’t know

816

each other. And through time — and he could see my competence in interpreting Scientology policies and bulletins — that I then became a consultant and worked more closely with him on the case.

BY MR. WEINBERG:

Q Well, at the time — when you were reviewing these folders it was in Mr. Dandar’s office?

A Yes.

Q And you had — you met with Mr. Dandar at that period of time?

A Yes.

Q I mean, you introduced yourself to him and all that?

THE COURT: Well, Counsel, come on.

BY MR. WEINBERG:

Q Did you bill him for your time?

A No.

Q You just did this for free?

A Yes. And I had done it for free many times. I mean, I have worked for Morrison & Foerster, and Feaster from — out of San Francisco in a legal case. I worked for Mr. Leipold in a legal case. I worked for Mr. Dandar. I mean, by that time I had been working with these different attorney firms or at least they had been calling me to see if I could assist them in these other legal cases.

817

Q Well, who was paying you to be in Tampa, St. Pete, wherever it was, that you were to work with Mr. Dandar and Ms. Brooks with regard to this case in the fall of 1998 and early 1999 when you were going through these PC folders?

A Again I’ll say that my expenses to fly down to Florida, I believe, was paid by Mr. Dandar. The money that I used to exist for that period of time, I think we’re talking about maybe six months, for the most part — for the greater majority of it were residuals from the business I operated in Minneapolis.

Q Well, didn’t Mr. Minton give you checks in early 1999, $5,000, $6,000 a month?

A No.

Q He didn’t do that?

A He may have did it a time or two but it wasn’t consistent. And FACTNet was a very small organization. It sometimes just didn’t have money. And my — you know, and this was kind of like a period of time like where how do you fit in? So, you know, I would occasionally tell Mr. Minton, “Hey, you know, these people don’t have money. I can’t live on air here. Can you help out?”

Q Well, why Mr. Minton? Why not Mr. Dandar who you were doing the work for?

A Because I was working on FACTNet now, you know.

We’re mixing apples and oranges here. FACTNet was a

818

corporation that Mr. Minton was on the board of directors of.

Q Well, I thought — correct me if I’m wrong, I thought I heard you say that starting in the fall of 1998, into 1999, you spent a number of days, weeks, whatever, working on this case, the Lisa McPherson case?

A Well, hold on, hold on, hold on. I never even met Mr. Dandar until 1999. So let’s leave 19 —

Q How can you say that? You just said you were in his office in the fall of 1998 looking at the PC folders?

A Wait — okay. Well, okay, I’m confused with the dates. So —

THE COURT: So what is the right date?

THE WITNESS: I don’t know. I mean, was it 1998?

THE COURT: That is fine. I told you and I’ll tell you again and it is really a wonderful answer, you know, 1997, ’98, ’99, there could be a lot of these dates you simply don’t know, and there is nothing wrong with saying, “I’m not sure what the date was. I don’t know for sure.”

THE WITNESS: Thank you, your Honor.

A Mr. Weinberg, I don’t know. I don’t recall for sure.

819

BY MR. WEINBERG:

Q Now, when did you become the expert/consultant in the Lisa McPherson case?

A I believe that I got a letter from Mr. Dandar quite possibly in March of 1999 that memorialized the fact that he wanted to hire me to be his consultant. We had had a working relationship at that point because I helped him a lot and I — and —

THE COURT: You know, I haven’t heard a date yet. When is the question?

A March of ’99. I think that is when we formed an agreement and decided on terms.

BY MR. WEINBERG:

Q All right. Prior to March of ’99, in the months prior to March of ’99, you had done a lot of work assisting Mr. Dandar with, for example, PC folders, correct?

A Correct.

Q So whether that started in November or December of ’98, it was sometime several months before March of ’99 when you signed on as the expert. Right?

A Yes.

Q And —

A To the best of my recollection.

Q And prior to signing on as the expert, can you tell us how much time you had spent down here helping out

820

Mr. Dandar before you signed on as the expert?

A I’m sorry, I can’t tell you how much time it was.

Q Okay. Now, once you signed on with Mr. Dandar, then was it established that you were on a monthly salary?

A Mmm, I think the letter that memorializes that agreement, I was on a monthly retainer of $5,000 a month and my billable hours which I believe was either $100 or $150 an hour.

Q If you exceeded the $5,000? Or is it in addition to the $5,000?

A The $5,000 retainer, and the hours against that, plus any other hours if I put in more hours or whatever.

Q But you didn’t keep your hours, we established — remember we established that in front of Judge Moody that you didn’t keep your hours. Right?

A Well, no, in the beginning I didn’t. And again, Mr. Weinberg, there was nothing to keep prior to that because I had just literally done the work for free.

Q Well, we have asked for your hours as part of the various discovery, and it came up in the Judge Moody hearing when you testified in front of Judge Moody and your testimony was, I believe, that either you didn’t keep them or you didn’t have them.

A Right. I didn’t have accurate records. I didn’t have any notes to turn over or — no.

821

Q So what you got paid by Mr. Dandar was $5,000 a month because you didn’t keep the time in order to get anything in addition to that. Correct?

A Well, you see, we’re mixing apples and oranges here again now. Because I think, you know, you talk about that time period from 1998 to —

THE COURT: I’m — he’s talking about the time period from March of ’99 when you were placed on a $5,000-a-month retainer, was it $100 or $150 an hour again that — which was it?

THE WITNESS: I’m not sure, I think it may have been $150, actually.

THE COURT: Let’s assume it was $150 an hour.

Basically how that works, if you go over, whatever $150 into $5,000 is, then you get more, but if you get less, you still keep the five.

THE WITNESS: Yes.

THE COURT: Was that the deal?

THE WITNESS: Yes.

THE COURT: So you didn’t keep records, apparently?

THE WITNESS: No.

THE COURT: You were paid $5,000 a month?

THE WITNESS: Yes.

THE COURT: For whatever — for however many

822

hours you worked?

THE WITNESS: Yes.

BY MR. WEINBERG:

Q We’ll show you the checks, but that continued up until — your recollection is that continued to a particular point in time, I believe the records will show, May of 2000 when you left Mr. Dandar’s payroll and went on LMT’s payroll. Correct?

A My reference point for that, Mr. Weinberg, is that we had finished the depositions of all of the Scientology persons that needed to be deposed. And Mr. Dandar was going to go on to —

THE COURT: Well, is that correct? Is that the date? I mean, all he wants to know —

BY MR. WEINBERG:

Q All I want to know —

A I don’t know if that is the right date. I’m saying my reference is this —

Q At some point, and we’ll show you the checks, I’m representing to you I think the last Dandar check is May of ’99 — or May of 2000. At some point in time you quit getting Dandar & Dandar checks and you started getting LMT checks?

A Correct.

Q And LMT continued to pay you at $5,000 a month?

823

A Correct.

Q The same $5,000 — the same amount. And you negotiated that rate with Mr. Minton?

A And Mrs. Brooks.

Q Now, and then the LMT at some point — you testified about either yesterday or the day before — closed down, correct?

A Correct.

Q And whenever that was, your recollection it was sometime in August or September of 2001. Right?

THE COURT: When was the date? When was the date?

MR. WEINBERG: That I don’t know exactly. I mean, it depends on — I mean, I’m really asking Mr. Prince.

BY MR. WEINBERG:

Q I believe that you, Mr. Minton and Ms. Brooks said it was sometime in the August/September of 2001 time period, is that correct?

A Mr. Weinberg, my recollection is I think it ceased to exist as a corporation — I think there was something that Stacy wrote. But again as I testified to yesterday, there was that period of time when Judge Beach still had to come into the trust in order to go through all of the offices, the library, looking for discovery, so in effect it

824

was kind of forced to stay open longer after that.

Q Well, we’ll show you the checks. But the records from LMT —

THE COURT: If you have got the checks, wouldn’t it make a lot more sense to show him, then I wouldn’t have to listen to this?

MR. WEINBERG: Right. I will.

THE COURT: What you said yesterday was even after it closed down there was a period of time when you were working and you got paid for that, too, is that right?

THE WITNESS: Yes.

THE COURT: Whatever the checks show, the checks show.

BY MR. WEINBERG:

Q And then at some point you quit getting LMT checks, right?

A Correct.

Q And — but Mr. Minton continued to pay you. Right?

A No. That is incorrect. Mrs. Brooks did.

Q You knew that Mrs. Brooks was getting the money from Mr. Minton. Right?

A Well, you know — come on.

Q Come on yeah?

825

A Do I need to assume that for you to make a point?

The answer to the question is I was being paid by Mrs. Brooks. Her name is on the check. It is to me. That is it.

Q All right. And that was at $5,000 a month, as well?

A Correct.

Q And who did you negotiate that deal with?

A Mrs. Brooks.

Q And did you talk to Mr. Minton about it?

A No. I specifically talked to Mrs. Brooks about it because she wanted everyone to take a cut in pay. And, again, this constant figure of $5,000 is something that we had discussed many years earlier.

Q “We” being?

A Mrs. Brooks, Mr. Minton. This is what I need to be able to live.

Q So —

A This is comparable to what I was making before I came and started doing this. I —

Q I’m sorry, before you ever signed on with Mr. Dandar, you had already discussed with Mr. Minton and Ms. Brooks that you needed $5,000 a month to live, correct?

A Correct.

Q And is that what you’re getting paid at FACTNet,

826

as well?

A No.

Q Now, when you started getting these checks — they were checks, right, from Ms. Brooks, you were still living in Clearwater. Right? Or — or Florida?

A I’m still living here. Yes.

Q And you’re living in a house that Mr. Minton gave you a $50,000 down payment on. Correct?

A That was part of the down payment that I had to make. My total down payment for that house was $70,000.

Q How much of that $70,000 did Mr. Minton give you?

A $50,000.

Q And when was that? When did he give you the $50,000?

A You know, I guess it was sometime in February.

And, you know —

THE COURT: If you have the check, show it to him.

MR. WEINBERG: I don’t have the check, I don’t think.

A Well, you know, we’ve said —

BY MR. WEINBERG:

Q Well, could you just tell me when you bought your house?

THE COURT: If he doesn’t know, he doesn’t

827

know. If you don’t know, say you don’t know.

A I know when I bought the house. I think the 21st or 22nd of February of 2000.

BY MR. WEINBERG:

Q And at that point in February of 2000, you were getting Dandar & Dandar monthly checks as his consultant.

Right?

A Correct.

Q All right. And how did it come about Mr. Minton gave you $50,000 of the $70,000 that you needed for the downpayment?

A You want to hear this?

Q You asked him for it?

THE COURT: Go on ahead. You asked. He can tell it. Go on and rattle off however long this story is going to take.

A Prior to moving down to Clearwater, we had discussed — had many discussions about, well, where to put the Lisa McPherson Trust. We were kicking around this idea  of the LMT, where is it going to go? Should it be in D.C., should it be in Boston, in the Los Angeles area. Bob said Clearwater.

We discussed this, David Cecere, myself, I think Mrs. Brooks, Mr. Minton and there — there quite possibly could have been someone else there — I don’t remember — of

828

where to put this thing.

And Mr. Minton really wanted to put it in Clearwater. He felt that it was important that it happen in Clearwater. Which meant that everyone that was going to work there would be displaced from where they were currently living to move here.

Mr. Minton offered to pay the moving expenses for all concerned and to help all concerned establish residence in Clearwater.

Q So he paid your moving expenses which —

A Correct.

Q — included a $50,000 downpayment?

A No, sir. That is what was discussed in — in New Hampshire, you know, before we moved here. Ultimately, Mr. Minton gave me the $50,000 loan to purchase that house, but I paid for my own moving expenses and I paid — I mean, the whole deal cost about $80,000 for me to relocate.

Because I had a place in Memphis. And by this time I’m kind of living with — in Chicago. By this time I’m kind of living with my fiancee in Memphis, Tennessee, as well. So when I moved down to Clearwater I had to move from two cities; I had to move from Chicago, I had to move from Memphis, Tennessee, to Clearwater.

Q Mr. Minton paid some other things for you. He paid your attorney fees in the criminal case down here,

829

didn’t he?

A I believe the Lisa McPherson Trust paid those.

Q Well, did you — did you discuss with Mr. Minton that you needed funds to pay an attorney when you got charged down here?

A No.

Q So who did you discuss that with so that the Lisa McPherson Trust paid for your attorney fees?

A I wanted to hire a fellow named Rob Love to defend me in that action. Mrs. Brooks insisted that Mr. DeVlaming would handle my case and it would be taken care of by the Lisa McPherson Trust as a job hazard.

Q As a job hazard?

A Yes.

Q Okay. And that was around $60,000 or $70,000?

A The bill that I saw — I think it was about $45,000 that I saw.

Q Do you think it was more than that or you don’t know?

A I think it could have been more.

Q Now, how long — so how would you get these checks from Ms. Brooks after the Lisa McPherson Trust closed down?

A She would mail them to me from Atlanta.

Q The last check you got was on or about April 4 of 2002?

830

A Correct.

Q And did you have a discussion — all these discussions that you had with Ms. Brooks and Mr. Minton that you have testified about this year, in any of those discussions did you discuss with them your need for them to continue paying you?

A Mmm, no, I haven’t had a discussion about that. I mean, we — I think I brought up earlier, in September there was a renegotiation of — Stacy wanted people to take pay cuts or whatever. And —

Q But you didn’t take one?

A Correct.

Q I was talking about April. In that — do you remember you said you had all these conversations, that you referred to them in your affidavit, with Mr. Brooks — with Ms. Brooks and Mr. Minton —

A Oh, okay.

Q In those conversations did you raise the fact that you needed more money, you needed money, you wanted money?

A No.

Q Okay.

A I did not.

Q Now, you said that you began as the paid expert/consultant in the Lisa McPherson case in March of — of 1999. Correct?

831

A Yes.

MR. WEINBERG: Now, let me have the reporter — the clerk —

A To the best of my recollection.

MR. WEINBERG: — mark as a 3-page exhibit, if we can do that, your Honor —

THE COURT: Sure.

MR. WEINBERG: — some checks. This will be 225.

THE COURT: All right. Do I have the right order, the way you handed it to me?

MR. WEINBERG: I think so.

THE COURT: Okay.

MR. WEINBERG: It is possible, however, that I screwed that up, but —

THE COURT: It is all right.

MR. WEINBERG: But the order should be February, March and May. That is what I’m hoping.

THE COURT: Yes.

BY MR. WEINBERG:

Q This is 225, Mr. Prince.

A Okay.

Q And you recognize the first page of 225 to be a February 2nd of 1999 check from Bob Minton for $6,500 to you?

832

A Yes, I do.

Q Do you recognize the second page to be a March — appears to be March 18, 1999 check to you for $5,000, do you see that?

A Yes, I do.

Q From Mr. Minton again?

A Yes.

Q And the third check to be a May 4, 1999 check for $5,000 from Mr. Minton?

A Correct. Q Now, this was — these checks had to do with the agreement that you had already worked out with Mr. Minton and Ms. Brooks about you getting at least $5,000 a month?

A Correct.

Q But you were getting this on top of what you were getting from Mr. Dandar?

A No.

Q Okay. You think you started getting from Mr. Dandar a little bit later?

A Yes.

Q Now, what was this $5,000 a month for? I mean, one was $6,500. Do you know why it was $6,500?

A Do you know, I don’t know. I was looking at that. That is an anomaly. That must have been money left over from another month. Because as I said, there was a

833

stretch — period of time after I met — certainly from 1998 until I guess this first check here that I was just simply not paid at all.

Q But this — you are not getting paid for FACTNet work, you are getting paid for Lisa McPherson work prior to signing on with —

A No.

Q — Ken Dandar?

A No.

Q Well, what is this work? What is this —

A I’m in FACTNet when this is happening.

Q Why was FACTNet paying you?

A Well, I think I mentioned earlier that sometimes FACTNet just didn’t have money and I would call Mr. Minton. I can’t just be down here.

Q Now, when —

THE COURT: Weren’t you making $3,500 a month at FACTNet? Or am I thinking of something else?

THE WITNESS: Your Honor, you may be right about that because we did have — have some agreement, I think I reached some agreement with them to do that. And, you know, at that time I still had my other business. I still had other employees. I would often make trips, you know. So that could have been the case.

834

But the fact of the matter is the organization didn’t have the money.

THE COURT: I’m trying to think of why — I have no idea why it was $6,500 either unless perhaps —

MR. WEINBERG: I think it might have been some expenses or something.

THE COURT: Or perhaps he was getting $3,500 from FACTNet. He was supposed to start getting $5,000 from whatever, and I didn’t get — the difference from $3,500 to $5,000 would be $6,500.

That would be rational but —

BY MR. WEINBERG:

Q In any event, Mr. Minton knew you had been doing this work in Clearwater for Mr. Dandar with regard to the PC folders? He knew that?

A I assume he did.

Q I mean, you were in — once you had spent that however long you said it was, I forgot now, a couple weeks at his house, you communicated with him regularly after that, didn’t you?

A Up until this very occurrence, yes.

THE COURT: What is “this very occurrence”?

This —

THE WITNESS: That is occurring here.

835

THE COURT: Okay.

MR. WEINBERG: Now I’m going to mark as our next exhibit, your Honor —

THE CLERK: 226.

MR. WEINBERG: — 226, this is 226 —

THE COURT: Okay.

BY MR. WEINBERG:

Q Now, Mr. Prince, 226 is a response that was filed by Mr. Dandar on April 6, 2001. And attached — and the response shows that it has checks attached, but if you’ll look at the summary on Page 2, it identifies a 6/30/99 check, an 8/20/99 check, a 9/15/99 —

A Excuse me, I’m not following you at all.

MR. WEINBERG: If I could approach a second?

THE COURT: You don’t need to read them all into evidence. Just put it into evidence.

MR. WEINBERG: I just wanted him to look at it.

BY MR. WEINBERG:

Q You see those?

A Uh-huh.

Q Attached is those checks. So either look at the attachment or summary there.

Is it your recollection that is the sum and substance of what Dandar & Dandar paid you while you were on the — you know, being working as a consultant/expert?

836

A I believe this is correct with the possible exception of recent activity.

Q Right. No, I’m talking about prior to 2002.

A Okay.

Q And that the first check was on or about June 30, 1999. Do you see that?

A Yes, I do.

Q And the last check was on or about May 24, 2000.

A Yes.

Q And it’s your recollection that after you received the last check, that is when you started getting paid at the same rate by Lisa McPherson Trust?

A Correct.

Q You see for the most part these checks are $5,000 a month?

A Correct. I think I can explain what this other one is for, $1,772.

Q What?

A I mean all of $5,000 with the exception of the $1,772 —

Q Is that some expense check?

A Yes.

Q Okay. Now, the Lisa McPherson Trust actually withheld from your check. Right?

A Yes.

837

Q In other words, you — your salary was $5,000 a month but your take-home was whatever —

A About 35.

Q So I’m going to show you a series of those checks, as well.

A Okay.

Q You were on a 1099 for Mr. Dandar, in other words, he didn’t withhold from your checks, right?

A Correct.

THE COURT: You were considered an independent contractor when you worked for him, is that right?

THE WITNESS: Yes, your Honor.

THE COURT: All right.

THE CLERK: 227.

MR. WEINBERG: This is 227, your Honor.

THE COURT: All right.

BY MR. WEINBERG:

Q This is 227.

A Okay.

MR. WEINBERG: I’ll mark as 228 this document.

And all this is is the payroll records of Mr. Prince which show that the salary was $5,000, it shows what the withholding was.

THE COURT: All right.

MR. WEINBERG: That is 228.

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THE COURT: All right.

MR. WEINBERG: These were produced by the Lisa McPherson Trust.

THE COURT: These weren’t additional moneys.

MR. WEINBERG: No, it just shows what the salary was, 228, and they withheld —

BY MR. WEINBERG:

Q If you look at the checks, Mr. Prince, they are $3,552, starting in June of — of 2000, do you see that?

A Mmm, yes, I do.

Q And it is June, July, August, September, October, November, December —

THE COURT: Counselor — Counselor, just can you go from the beginning to the end?

BY MR. WEINBERG:

Q It begins in June — end of June of 2000 and ends — one is out of place — ends —

THE COURT: June ’01.

BY MR. WEINBERG:

Q June/01, except if you look at the other exhibit, Mr. Prince — if I could just approach, your Honor — the payroll records indicate that you would have received — you would have received a — one last payment on August 1, 2001 of $5,000 salary with all of the withholding. Do you see that?

839

A I’m trying to follow.

Q It is the last page. Right there (indicating).

August 1 —

A Oh, yeah. Okay.

Q All right? So that was probably the close-out payment or something?

A That was the last check. Yeah.

THE COURT: Counselor, from LMT again?

MR. WEINBERG: These are the LMT records, this is what they produced.

BY MR. WEINBERG:

Q So it appears you were paid a salary as an employee from June of 2000 until August of 2001 at $5,000 a month. Correct?

A Correct.

Q And after August 1 of 2001, you continued to get your $5,000 a month but it was from Ms. Brooks?

A Correct.

Q Now, did Ms. Brooks withhold from — I mean —

THE COURT: What could she withhold from? I mean, she was not paying him out of a business; she was giving him money.

MR. WEINBERG: It’s a good question.

BY MR. WEINBERG:

Q Did — what were you considered at that point when

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you were getting this $5,000 a month from Ms. Brooks?

A What was I considered? Stranded in Clearwater.

All of the other staff had moved.

THE COURT: Was this a friend giving — giving you living money until you could get some other job?

THE WITNESS: Absolutely.

BY MR. WEINBERG:

Q Was there some understanding how long that was going on?

A No.

Q Was — had there been discussions it was going to end?

A No.

Q Now, you have a monthly mortgage, obviously, because you haven’t sold this house yet, right?

A Correct.

Q Who paid you in May of 2002?

A It’s not here?

Q May of 2002. The last check from Ms. Brooks you said was April 4, 2002.

A Correct.

Q You said for years you needed $5,000 a month to live.

A Correct.

Q So my question is who paid —

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your money to live in May of 2002?

A I think from the State of Florida.

Q What do you mean?

A I filed for unemployment.

Q Well, how did you do that?

THE COURT: Because he was unemployed.

BY MR. WEINBERG:

Q But you’d been unemployed since August of 2001.

A Yeah.

Q Or did you tell them that you had been employed since August of 2001 and just lost your job when you had this argument or disagreement with Mr. Minton and Ms. Brooks?

A Mr. Weinberg, it is actually quite a simple process. You go online, you tell them you are employed — unemployed, you put it in there, and they send you a check.  You check in. You have to look for employment. I mean, that is what I know about.

Q And who did you say your last employer was?

A Lisa McPherson Trust.

Q And what did you say the circumstances were that you had lost your job?

A Mmm, I — I think — I think maybe the place was bankrupt, went out of business, closed shop. Something like that, you know.

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Q Is there some application you have to fill out?

A Online, yes.

Q And is there — so it is all online, it is with the State of Florida?

A Yes, it is with the State of Florida online, yes.

Q And so since May of 2002, you have been on unemployment?

A Since late May of — yeah. Late May of 2002.

Yes.

Q So you are still on unemployment?

A No.

Q Well, when did that end?

A Well, when I worked out a new agreement with Mr. Dandar and came to appear as an expert and give testimony here, he gave me a check which I think he said he  would send here, and at that point when you receive money — when you are employed and you are actually receiving money, whether it is self-employed or otherwise, that terminates unemployment.

So that check effectively terminated my unemployment.

Q And so you notified the authorities of that?

A Yes. And I haven’t received another check since.

Q How many checks did you get — where do you get it, from the State of Florida, is that where you get the

843

checks?

A Yes.

Q And how many checks did you get for unemployment?

A Mmm, well, they do it — I think I was getting like $293 a week or something like that. Then they would double them up so the checks were like $494, I would get two of those —

THE COURT: Were you getting weekly checks?

THE WITNESS: No, I had it every other week.

So I got $494 — I believe I received —

THE COURT: Do you know?

THE WITNESS: No.

THE COURT: Then why don’t you say that?

THE WITNESS: Sorry. I don’t know.

BY MR. WEINBERG:

Q When did you get the first money from — when did you sign up with Mr. Dandar to be an expert again? What date?

A I don’t know.

Q Well, that can’t be long ago, so what is your best —

A Well, I don’t know the date. I don’t know.

Q What were the circumstances of you becoming an expert again?

A Mmm, you know, again, this whole thing was over.

844

People were going home. It was over. Your client took Mrs. Brooks and Mr. Minton as trophies and we are sitting here today and this brought me into this position here again today. So, you know, those are kinds of the circumstances.

THE COURT: Are you back as a consultant or expert or combination of the two?

THE WITNESS: I have been a combination of the two with him.

THE COURT: And what time did that start, about? Was it like —

THE WITNESS: Maybe a week ago, two weeks ago or however.

THE COURT: So between May of 2002 up until that time you were collecting unemployment?

THE WITNESS: Yes.

BY MR. WEINBERG:

Q And is there some agreement you executed with Mr. Dandar a week or two weeks ago?

A Yeah, that I participate in the case, I would help —

Q No, is there some written agreement?

A Oh, no.

Q And the day that it started is when you got the check. Is that when you became the expert, when you got the check?

845

A You know, I’m not — I’m not sure because —

THE COURT: As opposed to they talked, then they got a check —

MR. WEINBERG: I’m trying to date it. It is not that long ago. I’m trying to date it.

BY MR. WEINBERG:

Q I mean, when it happened, did you — I mean, did this essentially happen simultaneously that somehow it was  established that you were going to be the expert again and you negotiated what you needed?

A There was no — I’ll try to explain it as best as I can, Mr. Weinberg.

THE COURT: I don’t care. I don’t want to hear it, I’m not interested. I’m just not interested.

BY MR. WEINBERG:

Q Could I ask the amount then? What is the agreement? Are you getting paid on monthly basis? Salary?

A We have no agreement like that. I just — you know, I will put in X amount of time, I’ll get through this hearing —

THE COURT: Are you going to bill him per hour, or what?

THE WITNESS: Yes, your Honor, I am.

BY MR. WEINBERG:

Q And how much have you received from Mr. Dandar?

846

A $4,000.

Q Is that just a retainer?

A Yes.

THE COURT: Are you keeping records now?

THE WITNESS: Yes, your Honor, I am.

THE COURT: What is your hourly fee?

THE WITNESS: 150.

THE COURT: All right.

MR. WEINBERG: I think this would be — I have a few other questions.

BY MR. WEINBERG:

Q Did anybody else, between the time that Ms. Brooks quit giving you money and the time that Mr. Dandar did give you money, did anybody else give you whatever you want to call it, expense money, living money, expert money, money?

A No.

THE COURT: Between the time Ms. Brooks —

MR. WEINBERG: — quit giving him the money in April of 2002 of this year and whenever it was Mr. Dandar gave this check.

THE COURT: Other than his unemployment?

MR. WEINBERG: Other than his unemployment.

BY MR. WEINBERG:

Q Did anybody else give you money?

A The answer is no.

847

MR. WEINBERG: I think that — you know, I’m sort of at the end of this section. If you want me to start another section I will, or we can —

THE COURT: Yes, I would like to go until about 12:15, if you don’t mind.

MR. WEINBERG: No.

THE COURT: Because we kind of got a late break.

MR. WEINBERG: No, I really don’t mind.

THE COURT: Gee, I thought you were about to say you were done.

MR. DANDAR: I thought so, too.

THE COURT: I was real excited.

MR. WEINBERG: Or I could put it a different way. Maybe I could have some time to collect my thoughts. No, I’m not done.

THE COURT: All right.

BY MR. WEINBERG:

Q Now, you have been asked before about —

THE COURT: Could I ask one question? I’m sorry.

MR. WEINBERG: Sure.

THE COURT: What is the number of the response from Mr. Dandar? Can somebody give me a number on that?

848

MR. DANDAR: 226.

THE COURT: Thank you. I forgot to mark it.

MR. WEINBERG: Which means that the — that the LMT —

THE COURT: I have everything else marked. I just didn’t have that marked.

MR. WEINBERG: All right.

BY MR. WEINBERG:

Q You have been asked before and testified about going to Key West. Do you remember that?

A I don’t remember testifying about that.

Q Well, did you go to Key West?

A Yes. But I don’t remember testifying about it.

MR. DANDAR: It is outside of the scope of direct.

THE COURT: Well, I don’t know what he’s going to ask about it, but it is probably doubtful it is outside of the scope of direct but —

MR. WEINBERG: It is. It is.

THE COURT: Go ahead.

BY MR. WEINBERG:

Q And you were in Key West for what purpose?

A Vacation.

Q For a fishing trip is what you previously testified to.

849

A Yes, okay. And, you know, I don’t want to do this — if I have testimony, could you please just show it to me and ask me about it?

THE COURT: That is a fair question. I mean —

MR. WEINBERG: Well, let me ask a few questions and then I will show it to you because we do have — actually we’ll show you the video.

THE COURT: If he wants to see it, you show it to him now.

MR. WEINBERG: Well, this is it. He can look at it.

THE COURT: Then put it up then.

MR. WEINBERG: Well, I need to ask him one question before.

THE COURT: Okay.

MR. WEINBERG: One series.

BY MR. WEINBERG:

Q In Key West, it didn’t have anything to do about Scientology or this case or cases against Scientology, is that right?

A Mmm, you know, we were there for a fishing trip.

I was there with Mr. Haverty, Mr. Haney, Mr. Ford Greene, Mr Dan Leipold, Mr. Dandar; Mr. Garko came out there. We all have a common interest, and it would be crazy for me to say that the subject of our work didn’t come up and was

850

discussed or whatever at some — you know, during the fishing trip.

So the — that is the best way I can answer that question.

THE COURT: So the answer is yes, you all discussed the case?

THE WITNESS: Yes.

THE COURT: All right.

BY MR. WEINBERG:

Q Well, let me play your testimony and then I’ll ask you about it.

THE COURT: What testimony? This is on direct?

MR. WEINBERG: No, it’s in his deposition under oath in this case on November 17 —

THE COURT: See, you misled — I think Mr. Prince and I both thought you were talking about on direct examination which is what Mr. Dandar said was outside the scope.

MR. WEINBERG: No, in this case about Key West.

THE COURT: But it was in his deposition?

MR. WEINBERG: Yes.

THE COURT: Okay. When you say testimony in this case, I’m going to assume you’re talking about direct.

MR. WEINBERG: I’m sorry.

851

THE COURT: So if it is something else, you need to identify it for him and for me.

MR. WEINBERG: Okay.

MR. DANDAR: What page number is this going to be?

MR. WEINBERG: Right here. This is a transcript of where this comes from.

THE COURT: Okay.

THE WITNESS: May I have a transcript, too?

MR. WEINBERG: Oh, sure.

THE WITNESS: Thank you.

______________________________________

(WHEREUPON, the video was played.)

BY MR. WEINBERG:

Q Did you go to Key West?

A Yes.

Q Who sent you to Key West?

A No one sent. I went.

Q Who paid for the trip?

A I paid for the majority of it while I was there, but it wasn’t — really not much to pay for. I paid to be on a boat to go out fishing. I paid —

Q Who — well, who gave you the money?

A I used my own money.

Q Well, where did that money come from?

852

A Money that I earned from working.

Q For FACTNet and Mr. Dandar and Mr. Leipold?

A I think we’ve covered this earlier. You know, I have a — you know — different businesses, as well as  expert, and, you know, the money that I used for that particular trip came from money derived from income from work that I’ve done.

Q Including FACTNet, Mr. Dandar and Mr. Leipold, right?

A I’m not sure why you’re bringing up FACTNet. I thought we —

Q Is that right?

A No, that is wrong.

Q Well, when was the trip to Key West?

A Well, six weeks ago now.

Q And who was on the trip? What people were on the trip?

A Oh, you know, I really don’t want to discuss that because I was on a complete pleasure trip. It had nothing do with McPherson, or Wollersheim. Nothing. It had to do with fishing and having a good time. Okay?

Q Now —

A And I explained to you earlier that I am very reticent to bring up the names of people that I’m involved with that is activity outside of Scientology because of the

853

behavior of your client. How many times do we have to keep going over this?

Q Were you on the trip with Mr. Dandar? Or are you embarrassed about bringing his name up? Were you on the trip with Mr. Dandar?

A No, Mr. Dandar was not —

Q Answer yes or no?

A — on the trip. No.

Q Was Mr. Leipold on the trip?

A Mr. Leipold — Leipold was there, Mr. Weiner (sic). He was there.

Q Was Mr. Minton on the trip?

A No.

Q Ms. Young on the trip?

A No.

Q Vaughn Young on the trip?

A No.

Q Mr. Jacobsen on the trip?

A Who is Mr. Jacobsen?

Q You don’t know Mr. Jacobsen?

A No.

Q That is fine. Mr. Ward on the trip?

A No. No.

Q Did you talk about Lisa McPherson on the trip?

A Very little.

854

Q So Mr. Leipold went from California to Key West to just fish —

A Yes.

Q — with Jesse Prince?

A Yes. We went deep-sea fishing. We went 40 miles off the coast, caught fish like this. Had a ball.

Q And there was no planning session with regard to litigation. Is that correct?

A No.

Q Was Mr. Haney on the trip?

A Yes. And his son. And he learned to fish.

Excuse me. Now that we don’t have a question pending I would like to take a break. My leg is going to sleep.

Q We just broke ten minutes ago?

A Well, okay, I’m sorry, my leg is going to sleep.

I’ll take a two-minute break. Is that okay, Mr. Weiner (sic)?

Q Okay, take a break.

____________________________________

Q Now, I asked you if Mr. Dandar was in Key West with you. And you said no. You said no repeatedly. Is that correct?

A I don’t — if I did say no, I’m very sorry. He was not part of the trip. He came and appeared one day,

855

said, “Hi,” we had dinner and he left.

Q When you were outside did they — did they — Ms. Young remind you that you had made yet another mistake under oath? Did they tell you that?

A How could Ms. Young said — say that when I gave you testimony that she wasn’t there?

Q Well, who told you that then? Who told you — who corrected your — your false testimony that Mr. Dandar wasn’t there?

A I never gave false testimony. You asked me if Dandar was part of the trip that I went fishing. I said no.

Q And you were absolutely insistent that Mr. Dandar wasn’t there and yet he was in Key West?

A And came and had dinner and left. One time.

Q Flew down to Key West to have dinner and left.

MR. DANDAR: Objection, asked and answered and don’t answer it again.

THE WITNESS: Okay.

BY MR. WEINBERG:

Q Did he stay in a hotel down there?

A I don’t know.

Q What do you mean, you don’t know?

A That means that I don’t have personal knowledge of it.

Q And you understand what personal knowledge is,

856

right?

A Oh, come on, please.

Q No, do you understand it, personal knowledge?

A I do not know if he was staying in a hotel there.

I was in a different place. I don’t know where he was.

Q How many — how long did you spend with him in Key West on that trip this summer?

A A dinner. Maybe 15, 20 minutes. Outside of dinner —

Q Dinner is usually at night, right?

A Correct.

Q Did you see him the next morning?

A No.

Q Now, was Mike Garko down there?

A Yes, he was. Dr. Garko was there.

Q Was Thom Haverty down there?

A Yes. He was.

Q So that is like the whole consulting team for the McPherson case?

A Mr. Garko was with Mr. Dandar.

Q So he just flew in for dinner?

A Came in and left.

Q Didn’t have anything to do with the Lisa McPherson case?

A No.

857

Q Who paid for your trip?

A As I gave testimony to earlier, I paid my own expenses to — Mmm — take the boat out. I went out on a boat several times. I paid about 50, 60 bucks a time. I bought beer, wine, food, cigarettes.

(End of playing of the video tape.)

______________________________________

THE COURT: Counselor, is it — is it important that —

MR. WEINBERG: We are demonstrating —

THE COURT: Right now we have testimony coming out, I paid for my trip.

MR. WEINBERG: We are playing it in context.

THE COURT: No, it is not. I see about a jillion pages. You are on Page 259 and I see it going straight through to Page 267. That is a lot of pages. And I see that you’re — there is a lot of consistent testimony here.

MR. WEINBERG: But, your Honor, when we play this, I think you’ll see that there is a lot of inconsistent statements.

THE COURT: Yes, you already played it. I’m saying why do I have to listen to the consistent testimony from a deposition, it is improper.

MR. WEINBERG: Well, because — because —

858

there has been a lot of argument, accusations in here about taking things out of context so we left it in context is what we did.

THE COURT: All right.

If you have any more like this, you — you cut and paste. You can give it all to me, go to where you want to go, but I don’t want to hear it —

MR. WEINBERG: I understand.

THE COURT: I have better things to do than listen to this man’s testimony two times when it is exactly the same both times. Now, there is differences and I’m interested in hearing the differences.

MR. WEINBERG: And it is different from the other sworn testimony before —

THE COURT: And I’m interested in hearing that.

I’m not interested in hearing that which is not inconsistent. Do I make myself clear?

MR. WEINBERG: Yes.

THE COURT: It is improper. All right.

MR. WEINBERG: We could play it on rebuttal case, and we thought it would be appropriate to play it here with Mr. Prince on the stand and get his explanation for the inconsistencies between this and —

859

THE COURT: I have no problem with your playing inconsistencies.

MR. WEINBERG: All right.

THE COURT: That is called impeachment. I do have a problem with having to listen to Mr. Prince’s testimony on the stand and then listen to identical testimony in a deposition. Cut and paste it. You can give me the whole deposition, so if I want to read it in between, I can.

MR. WEINBERG: I apologize. Just play the rest — no, are we done?

That is fine.

THE COURT: I mean, there is more here and there may be more inconsistencies and I want you to play that —

MR. WEINBERG: I understand, and we don’t have it set up and I’ll go back and look at it at the break.

THE COURT: Let me look and I can see what you have underlined and that is probably the important part. I see I have two pages here not underlined.

MR. WEINBERG: The only stuff being played is the underlined stuff.

THE COURT: That is not true, Counsel, it is not true.

860

MR. DANDAR: And I don’t have anything underlined.

MR. WEINBERG: Well, then — then I should have followed the transcript.

THE COURT: Page 259, this is about the time I interrupted you, “Who paid for your trip down there?

“As I gave testimony to you earlier, I paid my own expenses. I went out on a boat several times –”

MR. WEINBERG: Wait a minute. I thought — point made. I really thought when I was — that I had this — only the stuff that was yellowed.

THE COURT: No.

MR. WEINBERG: That is why it was yellowed.

THE COURT: If there is something else in here you want to impeach, that is perfectly fine, you can catch it during lunch.

MR. WEINBERG: I’ll catch it during lunch. I think I pretty much made my point.

BY MR. WEINBERG:

Q Now, in Mr. Dandar’s testimony in this proceeding on May 3, 2002 —

A Not this?

Q No, it is not this.

A Okay.

861

Q On Page 90 — this is in his direct testimony when it first started at the beginning — I could hand this up.

THE COURT: If you are going to try to impeach this witness from Mr. Dandar’s testimony —

MR. WEINBERG: No, I’m going to ask him a question about it.

THE COURT: You don’t need to show him Mr. Dandar’s testimony or ask him about it. You can’t do it. If their testimony differs, it differs. You can bring it up, inconsistencies in their testimony, but you can’t show him Mr. Dandar’s testimony and say, “Is that true?”

BY MR. WEINBERG:

Q I take it that you did not spend hours and hours talking about Scientology strategy, the Lisa McPherson case and the other Scientology cases with Mr. Dandar or anyone else at the Key West meeting. Is that correct?

A That is correct. My recollection, I didn’t spend hours speaking to anyone about this. I mean, you know, there were a point in time when the attorneys were meeting, you know. And again, I don’t profess to be an attorney, I don’t try to be an attorney. I was there on a fishing trip, you know. Mr. Leipold has certain experience in dealing with Scientology. Mr. Ford Greene has certain experience with dealing with Scientology because of the cases he has

862

done. They had discussed with Mr. Dandar about that. This had nothing to do with me.

Q Well, you said Mr. Dandar in your testimony was only there for dinner one night for a few hours with Dr. Garko and flew back and there was no discussion about — about the case. That is what you said?

A You know —

Q Under oath. Correct?

A This is getting ridiculous, Mr. Weinberg. I mean, he flew in for dinner. He flew in. He brought in Mr. Garko. He had his own personal pilot. They were flying a little personal plane. They came, you know, while it was still light outside, you know, “Hi.” Thom Haverty’s wife is there and Captain Wayne’s wife is there, the boat. This is a social setting.

Q All right, so —

A There is nothing sinister about it.

Q So Mr. Dandar was not there for two or three or four days with Dr. Garko, was he?

A Not to my recollection. No.

Q Did you fly back to Tampa with Mr. Dandar?

A No, I did not.

Q And did you talk, on the trip in Key West — which you remember it was in August of 1999?

A I’ll take your word for it.

863

Q And do you remember that on August 20th of 1999 is when you wrote that David Miscavige affidavit that was used  about him ordering the death of — letting — ordering or allowing her or causing her to die? Do you remember that?

A You got me all screwed up on the dates now. Could you just tell me again?

Q The testimony in this case is that the Key West trip was around August 8, 9, 10, 11 of 1999. Or 12th of 1999.

A Whose testimony is that now?

Q Mr. Dandar’s testimony, Dr. Garko’s testimony, Mr. Haney’s testimony. That is the testimony.

A Okay.

Q All right? You executed an affidavit — the affidavit in this case, part of what this hearing is about, on August 20 of 1998?

THE COURT: We are talking about that is the date he signed it?

MR. WEINBERG: Yes, that is the date he signed it.

THE COURT: You are not going to suggest to this witness that whole affidavit was written on the date it was —

MR. WEINBERG: I wasn’t going to ask that.

864

BY MR. WEINBERG:

Q Just ten or fifteen days later you executed this affidavit, right?

A Correct.

Q Now, did you participate in any conversations in Key West with anyone, whether it is Ford Greene, lawyer on  Scientology cases, or Dandar Leipold, or Ken Dandar, or Dr. Garko or Thom Haverty, part of the — part of the Lisa McPherson team, did you have conversations with anybody down there about any of the assertions in this what became the August 20th affidavit?

A Not that I recall.

Q Did you have any discussions down there with anyone about adding David Miscavige as a strategy to the Lisa McPherson case?

A Not that I recall.

Q As far as you know, was anybody down there talking about the strategy of adding David Miscavige to the Lisa McPherson case?

A Not that I know of.

Q And was it —

A Or not that I recall or have memory of.

Q But you did leave Key West and go directly to Tampa, correct, after that trip that you call a fishing trip?

865

A I believe that — that that is correct.

Q And as soon as you got to Tampa, you started work — you must have started working on this affidavit. Right?

A I think that affidavit was a work in progress by the time I got to Tampa already. If you notice — I mean,  that thing is pretty detailed. I have references. I have studied. You know, it takes me time to do these affidavits.

I just don’t sit and imagine it. I have my calendar, I have my notes or whatever and I sit and I do these things.

Q But the first check you got from Mr. Dandar was June 30, 1999. Correct?

A If that is what you just showed me, I’ll take your word for it. Okay.

Q So as you look back, as you think back, do you recall whether you were working on this affidavit before you went to Key West?

A I’m pretty sure that was a work in progress.

Q So you had already had discussions with people about adding Mr. Miscavige to the case?

A I don’t know. I don’t recall it so I’m going to say I don’t know.

THE COURT: The only thing I’m going to allow you to inquire about — remember we had this little business about the work product — is the meeting

866

which is at issue in this case, the meeting, whether Minton was there and whether Minton influenced that. Whether this man, as a consultant, paid or otherwise, had a conversation about adding David Miscavige is what I would have expected him to add. Nothing sinister about that.

MR. WEINBERG: Nothing said it was sinister, except Mr. Dandar already asked Dr. Garko about meetings, Mr. Haney about meetings, Ms. Brooks about meetings, so —

THE COURT: Meetings? What meetings? The only person that I know of that was asked about the Key West meetings was you-all. Maybe he brought it up —

MR. WEINBERG: He brought it up on May 3rd.

You didn’t let me cross-examine him. Mr. Dandar is the one that brought up the Key West meeting, said that is where he —

THE COURT: Well, do you think I think all those people sat down there and didn’t talk about this case?

MR. WEINBERG: No, I don’t.

THE COURT: I don’t care what they said.

MR. WEINBERG: I’m just —

THE COURT: I mean, you know —

867

MR. WEINBERG: I —

THE COURT: You are acting as if you have a jury here that — I’m a judge that has been involved in this case very deeply, and as I tried to suggest to you on several occasions, I’m not an idiot.

MR. WEINBERG: I know that.

THE COURT: I know what lawyers do.

MR. WEINBERG: I understand that.

THE COURT: And I know if you get this many lawyers together, all of whom have Scientology cases, you put them on fishing trip or movie theater or whatever, the subject comes up and they talk about it.

MR. WEINBERG: And you couldn’t have said it better, and I’m making a record which I’m done with on this thing —

THE COURT: All right.

MR. WEINBERG: — indicating that this witness, that is what this — you know, this Paragraph 34 in the complaint is all about, his sworn affidavit, has told lies. You know, I’m using that —

THE COURT: I already told you and I told your team, save it for the jury. I don’t care if he told a bunch of lies or not. The law in Florida is if he qualifies as an expert, he can testify.

868

MR. WEINBERG: No, I understand your ruling. I’m —

THE COURT: Okay.

MR. WEINBERG: This is for credibility purposes.

THE COURT: I understand.

MR. WEINBERG: All right. But I’m pretty much done with this area.

THE COURT: All right. Then let’s have lunch.

MR. WEINBERG: Good.

THE COURT: And as I said, you just have to forget — I hope you all don’t forget that I was a lawyer for a long time.

MR. WEINBERG: Judge, believe me —

THE COURT: Please.

MR. WEINBERG: — I am well aware of that.

THE COURT: Frankly, my findings will go to the court this time with a presumption of correctness.

This is not a de novo hearing —

MR. WEINBERG: No, I understand that.

THE COURT: — by the Second District.

MR. WEINBERG: No, but it has also been a long proceeding.

THE COURT: Well, I understand, but it seems to me as if part of what you want to do is have

869

Mr. Prince up here just forever. I made statements before about Mr. Prince. I’m aware of Mr. Prince’s bias. I mean, Mr. Minton, according to Mr. Prince, shows where I said this before, this is not new.

MR. WEINBERG: I understand, but I just started yesterday — I mean, yesterday late —

THE COURT: I understand. But you are spending an awful lot of time about pickets which I knew what they would say, with pickets that I knew would not be pretty, all as if you are trying to show me what I already know. You are wasting time here.

MR. WEINBERG: But —

THE COURT: We’ll be in recess until 1:30.

(WHEREUPON, a recess was taken from 12:00 to 1:35 p.m.)
______________________________________

870

REPORTER’S CERTIFICATE

STATE OF FLORIDA )
COUNTY OF PINELLAS )

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.

______________________________
LYNNE J. IDE, RMR

Notes

Testimony of Jesse Prince (Volume 2) (July 8, 2002)

0159

IN THE CIRCUIT COURT FOR PINELLAS COUNTY, FLORIDA

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

vs.

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

CASE NO. 00-5682-CI-11

PROCEEDINGS: Defendants’ Ominbus Motion for Terminating Sanctions and Other Relief

Testimony of Jesse Prince.1

VOLUME 2

DATE: July 8, 2002.

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

BEFORE: Hon. Susan F. Schaeffer, Circuit Judge.

REPORTED BY: Donna M. Kanabay RMR, CRR, Notary Public, State of Florida at large.

160

APPEARANCES:

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

MR. LUKE CHARLES LIROT
LUKE CHARLES LIROT, PA
112 N East Street, Street, Suite B
Tampa, FL 33602-4108
Attorney for Plaintiff.

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

MR. LEE FUGATE and MR. MORRIS WEINBERG, JR. and ZUCKERMAN, SPAEDER
101 E. Kennedy Blvd, Suite 1200
Tampa, FL 33602-5147
Attorneys for Church of Scientology Flag Service Organization.

MR. ERIC M. LIEBERMAN
RABINOWITZ, BOUDIN, STANDARD
740 Broadway at Astor Place
New York, NY 10003-9518
Attorney for Church of Scientology Flag Service Organization.

MR. ANTHONY S. BATTAGLIA
BATTAGLIA ROSS DICUS & WEIN
980 Tyrone Blvd.
St. Petersburg, FL 33743
Attorney for Mr. Minton.

0161

INDEX TO PROCEEDINGS AND EXHIBITS

   PAGE           LINE

Recess                                                      261             18
Recess                                                       327              1
Reporter’s Certificate                            328              1

0162

(The proceedings resumed at 8:58 a.m.)

[… Other court business]

0191

THE COURT: I understand that. Take it up.

Mr. Prince —

Are we going to put Mr. Prince back on the stand?

MR. DANDAR: Yes, we are.

THE COURT: All right. Mr. Prince, you want to step forward?

Mr. Prince, you’re already under oath. So you understand that the oath that you took will be valid throughout your testimony.

THE WITNESS: Yes, I do.

THE COURT: All right. Would you please resume the stand?

Let me make sure, before we start, that I’ve got the right book.

Give me just a minute, Mr. Dandar.

0192

Hugh Haney? Was that the last witness?

MR. DANDAR: Brian —

THE COURT: Brian.

MR. DANDAR: Hugh Brian —

THE COURT: Brian.

MR. DANDAR: Hugh Brian Haney.

THE COURT: Okay. I wrote down Hugh. Hugh Brian?

MR. DANDAR: Yes. He goes by Brian.

THE COURT: Okay. All right. I’ve got the right book. I’m ready.

Mr. Bailiff, before we start, is this coffee — I mean — coffee — see, I was thinking of coffee. That’d be nice. Maybe you’ll bring me some. Is this water fresh?

THE BAILIFF: I’m not sure, your Honor.

MR. WEINBERG: I would say that would be —

MR. FUGATE: — a “no.”

THE COURT: That’s what I would say.

Would you mind?

No telling how long that’s been sitting in there. You know what he’ll do? It’ll have mold on it. He’ll go — pour it out — Thank you very much.

When this trial comes — because I will let you

0193

all have water during the trial. Not coffee, once we get to a trial —

MR. WEINBERG: Right.

THE COURT: — just water.

But I’m going to get me a little cooler and keep it up here. Because I don’t trust them — I can’t ask every day. Just one of the tiny little things that needs to be done.

And by the way, Mr. Dandar —

MR. DANDAR: Yes, Judge.

THE COURT: — if I might just suggest, I did notice in that article that you were quoted. The truth of the matter is, this is an ongoing case. It would be well for you not to be quoted in these articles.

MR. DANDAR: I do not believe that I or Mr. Prince gave an interview for that article.

THE COURT: Okay.

MR. DANDAR: I think — I think the reporter is quoting from in-court testimony.

THE COURT: If that’s the case, then we can’t help that.

But — but do not — and I’m not going to tell the lawyers how they ought to be lawyers, because you know, part of the — part of the canons say one

0194

ought not to be talking to the press about their case while it’s ongoing.

MR. DANDAR: Right.

THE COURT: That would be like you all having some comment for me. I don’t think you would be appreciative of that.

MR. DANDAR: I do —

That’s what happens to me — off the record?

Can we go off the record for just a second?

MR. LIEBERMAN: Yes.

MR. DANDAR: Yes.

THE COURT: Madam Reporter?

THE REPORTER: Yes, ma’am.

(A discussion was held off the record.)

THE COURT: All right. Back on the record.
___________________________________

BY MR. DANDAR:

Q All right. Mr. Prince, two weeks ago, we talked about your position with the Religious Technology Center; you getting these eyes-only reports on ongoing investigations involving litigation and other critics of Scientology.

And I’m showing you today Plaintiff’s Exhibit 113, entitled Intelligence Actions.

Can you identify that document?

A Yes.

0195

Q And what is it?

A This is a document — a document written by L. Ron Hubbard concerning intelligence. And it speaks about predicting trouble before it occurs, investigating individuals for crimes, and prosecuting the individuals.

And this all has to do with people who Scientology perceives to be enemies or suppressive persons.

Q Against whom? They’re enemies of whom?

A These are perceived enemies of Scientology. These are the actions that are done against perceived enemies of Scientology.

Q On the — it’s a one-page document. The third paragraph talks about a standard, is to — when you’re under attack, you attack back. Does that have anything to do with the prior document where you — where it mentioned, and you explained to the judge two weeks ago, manufacturing evidence if there’s no crimes found?

MR. WEINBERG: Well, I object to all this, your Honor.

First of all, this is a 1968 thing.

Secondly, I just want to let the record be clear again as to our position about Mr. Prince interpreting policy. He was booted out of the church — booted out of the position in 1987; left in disgrace from the church; has been — has been —

0196

has been, you know, paid to testify against the church. And now he’s coming in here trying to interpret policies; one a 1968 thing that doesn’t say anything about creating or manufacturing evidence and saying that — trying to interpret it?

I — I object to that.

THE COURT: Overruled.

BY MR. DANDAR:

Q Does this policy have anything to do with the prior policy that you identified two weeks ago, and explained to the court about, if you can’t find the crimes of the attacker, you manufacture the crimes?

A Yes. This is part and parcel of the activities of the intelligence department in different Scientology organizations.

Q What does that mean in that third paragraph from the bottom, attack loudly?

A You know, I think we must be looking at a different — I must be looking at a different document than you.

Q I hope not.

A Where did you see that –Oh, I see, okay. Yes. Okay.

Q What does that mean, attack loudly?

A Noisy investigation.

0197

MR. WEINBERG: Excuse me, your Honor. What he’s saying is what it means to him?

THE COURT: Yes.

MR. WEINBERG: As opposed to what it means?

THE COURT: That’s what he’s saying.

BY MR. DANDAR:

Q Within your experience and your position of the inspector general RTC worldwide, tell us what that understanding — what you’re understanding of that means.

MR. WEINBERG: Well, see —

A This would mean —

MR. WEINBERG: That, I object to. If he wants to sit up there and say what it means to him, that’s one thing. If he wants to sit up there and say, “This is Jesse Prince and this is what this policy means to a Scientologist,” that’s nonsense. And that isn’t right.

And that’s what’s been going on for — for — you know, with Mr. Prince and Mr. Young and other people that used to be in the — in the church. It’s not right. They shouldn’t be up here trying to interpret for the — for the religion of Scientology, what policy is.

THE COURT: That’s not even your argument; that’s the argument of the First Amendment scholar.

0198

And I have let him preserve that argument —

MR. WEINBERG: I understand.

THE COURT: — and it is preserved. And your objection therefore is overruled.

MR. WEINBERG: Okay.

THE COURT: Because quite frankly, if I don’t agree with his position, this would be relevant to this, and it would be relevant probably to your counterclaim.

MR. LIEBERMAN: Your Honor, I guess that means I should be objecting to —

THE COURT: No. Because I’ve allowed you to preserve a continuing objection.

MR. LIEBERMAN: Right. I understand that, your Honor.

But the point is, from the First Amendment point of view, to even let this kind of testimony in creates an untenable position for the church. Because if we — if we merely preserve our position, then we’re put in the position of, do we have to counter it? To counter it, we would then have to engage in a process which we shouldn’t have to constitutionally, which would be incredibly burdensome on us and on the court.

Because in order to understand Scientology

0199

policies, you can’t take one and look at it in isolation, and have somebody who was not — who was — who was basically removed from his position —

THE COURT: Yes.

MR. LIEBERMAN: — by the church —

THE COURT: But he was there. And he was there. And he presumably was high up in the scale. And he presumably knew what was going on, whether he was removed or not.

I’ve therefore ruled he’s qualified.

If you want to withdraw your motion, saying there was no basis in fact or law, and it was a fraudulent claim to file this lawsuit, then I will agree with you.

You filed the motion in this hearing. I think it’s relevant, quite frankly, and I think no matter what your First Amendment argument is going to be, I’m going to allow it in for this hearing. It’s your motion. That’s why I said I think you’re going to have some distinctions that I’m going to be willing to draw for different things. You do whatever you want to do for this motion. I’ve allowed you to preserve it. Your objection is preserved. You can argue it. Quite frankly, you

0200

may lose that motion for this hearing, as long as you have filed the motion you have filed.

You’ve made your argument. I’m ready to move on.

This is not somebody who was not in the church. This is not some scholar outside. This is somebody who was there, who says, “This is what we did.”

MR. LIEBERMAN: I know, your Honor. And he also was — was removed —

THE COURT: Well, then —

MR. LIEBERMAN: — from his position —

THE COURT: — do it on cross examination.

MR. LIEBERMAN: — for not being a Scientology expert; for being the opposite of a Scientology expert by the authority that had the ability to determine who are — who is capable, who is proper to speak for Scientology.

THE COURT: You know, the only thing I can suggest is, by all the argument that I hear from you all about Jesse Prince, you must be really frightened of him.

You’ve made your point. We’re going to move on.

BY MR. DANDAR:

Q Now, Mr. Prince, this third paragraph, third

0201

paragraph on Exhibit 113 states,

“Even if you don’t have enough data to win the case, still attack loudly. Reason is, it is only those people that have crimes that will attack us, and they will soon back off for fear of being found out when attacked back.”

Is this considered a scripture of the Church of Scientology?

A During — during my tenure in Scientology, this document was not considered to be any type of scripture. This was a training material to train a person in intelligence activities as practiced in Scientology.

Q Okay. Now, before the objection, you were talking about — answering the question about if this relates to the noisy investigation when this document, in the third paragraph from the bottom, speaks of or uses the word “loudly.”

A Yeah.

Q And what is a noisy investigation?

A A noisy investigation — I believe we covered that the first day I gave testimony, and we actually submitted the document in the church. But it’s basically to go around and arouse the neighbors and the friends and associates of a person that Scientology perceives to be an enemy, and make allegations about the person that may or may not be true. And according

0202

to Scientology’s Manual of Justice, which is a further document, that gives the exact procedure by which you go through to terrorize someone through investigation, noisy investigation, investigating loudly is certainly a part of it.

MR. WEINBERG: Object to the use of the word “terrorism” or “terrorize.” I mean, that’s just —

THE COURT: I didn’t hear him say that. Did he say that?

MR. WEINBERG: That’s what he said.

MR. DANDAR: Use it to terrorize the person who is attacking the Church of Scientology.

THE COURT: Overruled. I’m not thinking of that as terrorism; I’m thinking of that as just simply a word.

MR. WEINBERG: Well, that’s fine. But I’m a little sensitive, after reading this article this morning, where — or yesterday morning, where Osama Bin Laden and David Miscavige were mentioned in the same sentence.

MR. DANDAR: Take that up with the St. Pete Times.

MR. WEINBERG: Well, no, I —

THE COURT: Well, that was mentioned by Mr. Minton.

0203

MR. WEINBERG: Who — who — let’s make it clear — is not our witness, and is a person that has — that has worked very closely with Mr. Dandar from — from the beginning of this lawsuit.

THE COURT: I hate to tell you this, Counselor, but he is your witness.

MR. WEINBERG: Well —

THE COURT: You called him.

MR. WEINBERG: — your Honor, that’s where we disagree. But I’m not here to argue with that.

THE COURT: No.

MR. WEINBERG: We disagree about that.

We called him as a witness.

THE COURT: You can disagree all you want. You called him as a witness. I did not declare him a hostile or adverse witness. It appeared as if he was able to respond to your questions without leading questions.

You called him in this hearing as your witness.

MR. WEINBERG: But that doesn’t mean that Mr. Minton is — Well —

THE COURT: It does seem to be a lot ado about nothing, doesn’t it?

I understand about the article. That was

0204

Mr. Minton who said —

MR. WEINBERG: My —

THE COURT: — that.

MR. WEINBERG: — objection had to do with Mr. Prince saying “terrorize,” which is — which is —

THE COURT: Well, your objection’s overruled.

He can use the word “terrorize” if that’s the word he wants to use. That has nothing to do, in my opinion, with a terrorist attack. “Terrorize” is just a word. We use it all the time. Don’t be so sensitive.

Golly, we’ve got to get down into getting back into — stop being so sensitive.

BY MR. DANDAR:

Q In your experience in — in RTC, in Scientology, how do you go about finding or manufacturing threats against the critics?

A Well, there’s several ways that I’ve — I’ve seen it done —

THE COURT: And I’m sorry. When I indicated about the —

Excuse me.

When I indicated about the motion to dismiss, what I also meant to say is that this is relevant to this hearing because of Mr. Minton and the

0205

allegations that Mr. Minton has been extorted for his testimony. So for that reason as well, I think it’s admissible in this hearing.

Forget what I said about — I — I haven’t gotten my head back into this case.

MR. WEINBERG: My head was doing fine until I read the paper yesterday and then I got all upset.

BY MR. DANDAR:

Q So —

THE COURT: I’m sorry, Mr. Prince. I interrupted you.

Madam Court Reporter, read back that question before I interrupted him.

THE REPORTER: The pending question is, “In your experience in RTC, in Scientology, how do you go about finding or manufacturing threats against the critics?”

The witness began to answer, “Well, there’s several ways that I’ve — I’ve seen it done –”

A Yes.

As far as out-and-out manufacturing information — And again, I want to clarify that. During the time that I was in RTC, the greater part of my history in Scientology certainly had to do with what it calls

0206

technology, which is the delivery of auditing and training of things.

Now, when I got in RTC, I began to learn about this other aspect of Scientology, which had been hidden from me until that point. So I — I actually had a very short amount of time there. But as what I’ve seen as far as manufacturing information to nullify a critic, a person — Rick Aznaran took a private investigator over to Taiwan to investigate a fellow named John Nelson. John Nelson used to be a person that was the CO — the commanding officer of Sea Org —

MR. WEINBERG: Objection.

A — International.

MR. WEINBERG: Hearsay, your Honor. How’s he know this?

THE WITNESS: Because I was there.

MR. WEINBERG: You were in Hong Kong?

THE WITNESS: No. I was on the phone with the parties.

THE COURT: I’m going to allow it.

BY MR. DANDAR:

Q Were you in charge of the parties?

A Yes. The party was working in one of my divisions.

At any rate, Rick Aznaran flew to Taiwan with a

0207

private investigator to investigate a fellow named John Nelson, who used to be in a very high position in Scientology. He was the commanding officer of CMO.

THE COURT: At what?

THE WITNESS: The commanding officer of the Commodores Messenger Organization.

BY MR. DANDAR:

Q And that was an elite organization?

A At the time, it was located at Gilman Hot Springs, which eventually became Church of Scientology International. CSI.

Q All right.

A And he had started his own splinter organization with another fellow named David Mayo. At any rate, he was perceived to be a great enemy by Scientology. So he was on a business trip in Taiwan. Rick Aznaran, along with the private investigator, rented a room next door to his, electronically bugged his room so that they would know when he was coming and going; and when he left, subsequently put heroin in his room. And the plan was to call the police when he came, to say he was a — a heroin dealer, to get him turned in for this heroin package.

I found out about that because the private investigator that was working with Mr. Aznaran called back to the United States. I was on the phone. He said, “Look,

0208

this is going down. Over here in Taiwan, if a person gets convicted as a heroin dealer, they get the death sentence.”

I was not going to be a party to anything like that; neither did the private investigator. He was coming back. I immediately informed my senior, who was Vicki Aznaran. We conferenced with Mr. Miscavige on the situation and immediately had Mr. Aznaran come back and be away — not to do that particular operation.

This was an instance of manufacturing information that I know of, that I was personally involved in and had personal knowledge of. I’ve heard other things about that.

And of course, that would be hearsay, as Mr. —

Q Well, what year was this?

A That this occurred?

Q Yes.

A This happened in 1985.

Q Okay. Okay. And in your position, though, at RTC, you would hear about many operations against critics or perceived enemies of Scientology, is that right?

A Perceived enemies of Scientology is a — is — is what would correctly define — as opposed to critics.Because there was — you know, critics wasn’t a word that we used in Scientology when I was there. “Oh, this person’s a critic.” That’s not a word that we would use in Scientology. We would use this person is a suppressive.

0209

This person is attacking Scientology. But it wasn’t — this whole critic thing didn’t come into being, I believe, until after I even left Scientology.

Q All right. Well, what about the enemies of Scientology? What other examples can you give us where you have personal knowledge as to the operations that were going on?

A The other partner of this fellow, his name was David Mayo. He was the actual author of the NOTS Materials, the NED for OTs. And he —

THE COURT: Of the what materials?

THE WITNESS: NED for OTs materials. This is the — this is the —

MR. DANDAR: NOTS.

THE WITNESS: In Scientology, this is OT4, 5, 6 and 7.

THE COURT: What does the N mean on the front of that?

THE WITNESS: New Era Dianetics for Operating Thetans. And it’s an acronym, NED.

MR. DANDAR: NED.

THE WITNESS: NED.

MR. WEINBERG: Your Honor, objection. No foundation for any of this testimony. I mean, that David Mayo wrote this? Based on what?

0210

THE COURT: I’m sorry. I didn’t understand. I thought he was talking about the NOTS. I’ve seen that in some of the literature.

MR. DANDAR: Yes. That’s what he was —

MR. WEINBERG: But what —

MR. DANDAR: — talking —

THE COURT: I just simply asked what it — what it meant.

MR. WEINBERG: No — all right.

But what he said before that was — that prompted your question — was that David Mayo had actually been the author of the NOTS Materials, OT, whatever it is.

MR. DANDAR: You know, this is great for cross examination, but it’s really interrupting the flow of the direct.

MR. WEINBERG: Excuse me.

There was an entire proceeding in California about all this.

THE COURT: Well, I’m going to allow it.

BY MR. DANDAR:

Q How do you know that David Mayo is the author of NOTS, since Mr. Weinberg wants to know?

A Because it’s — the NOTS Materials, as I saw them in 1985 — each and every one of them had his signature or

0211

his initials on each page of the issues of the various NED for OTs issues. I think at the time there was 55 of them. So 55 little signatures of David Mayo, who wrote these materials. This is what I base that opinion on.

Q And he was a Scientologist at the time he wrote them, correct?

A He was a senior CS international at the time he wrote that.

Q And he worked closely with Mr. Hubbard, correct?

A He was Mr. Hubbard’s auditor, correct.

Q All right. So what happened — what was the operation against Mr. Mayo?

A Well, he was the other partner of John Nelson.

And what was done to him was they had rented a place, a business place, office complex. They were on the first floor. Scientology PIs rented the office directly above his office and electronically bugged the downstairs area. Also, a fellow named Bob Mithoff, who is the brother of Ray Mithoff, who is the current senior CS Int —

(The reporter asked for clarification.)

THE WITNESS: I’m sorry.

A — was the current senior CS Int, sent in as a deep undercover operative, as well as Carolyn Letkerman, as well as Nancy Mainy.2

And the purpose of these deep cover operatives

0212

were to divine the legal strategies of the Advanced Abilities Center to provide information about financial accounts, how much money the place was making. They stole the mailing list for the place. It was turned over to the Religious Technology Center. And they were basically sent in there to not only glean information but to disrupt activities, covertly disrupt activities.

MR. WEINBERG: Your Honor, could we date this, and could Mr. Prince tell us what the basis — what his —

THE COURT: Yes. What was the year?

MR. WEINBERG: — of the information is?

THE WITNESS: This, I believe, was 1985. It was Wollersheim 4, where I actually testified in a hearing in front of Judge Mariana Phaelzer3 ultimately. And on March 15th — not March 15th, but somewhere around that time period. This all had to do with the Wollersheim case.

BY MR. DANDAR:

Q And when you testified in front of a judge on Wollersheim 4, who were you testifying for?

A Church of Scientology — Religious Technology Center.

THE COURT: You testified for the Religious Technology Center that the — that someone from the

0213

Church of Scientology went into —

THE WITNESS: No, no, no, your Honor.

THE COURT: — this man’s place and —

THE WITNESS: No. I —

THE COURT: — stole —

MR. DANDAR: Wait —

THE WITNESS: No.

THE COURT: — his mailing list and —

THE WITNESS: No, no. No. That’s not what I testified to.

What I testified to was the fact that the materials that were being used in the Advanced Abilities Center were identical, basically, to the ones that the church had owned and copyrighted.

THE COURT: I see. So he — this Mr. David Mayo was another person who kind of broke off and was in a splinter group.

THE WITNESS: Yes. He was — he was kicked out of Scientology.

As a matter of fact, I think I brought the document with me today that — that shows why he was kicked out of Scientology.

And when he left he started his own movement, basically.

THE COURT: Okay.

0214

BY MR. DANDAR:

Q What’s the name of that document?

THE COURT: Was he — was he —

A RTC Conditions Order Number 1.

THE COURT: Was he — was he with Mr. Nelson?

THE WITNESS: Yes.

THE COURT: They were part of the same splinter group?

THE WITNESS: Yes.

THE COURT: I see.

MR. DANDAR: Your Honor — I’ll tell you what —

MR. WEINBERG: Could we just have Mr. Prince say what the basis for his testimony was, whether it’s hearsay or did he give these alleged orders to — to —

THE COURT: Okay.

MR. WEINBERG: — break in and bug and —

THE COURT: How did you know about this?

THE WITNESS: I knew about this because the — the people that were doing the activities were in a division in RTC that I supervised.

THE COURT: Okay.

THE WITNESS: And the — the people that were involved — I can tell you specifically the names of

0215

this person. Gary Klinger, who was our intelligence officer in RTC.

THE COURT: Who was “our”? “Our”?

THE WITNESS: I’m sorry. RTC.

THE COURT: Okay.

THE WITNESS: Jeff Schriver.

THE COURT: So you were supervising the people who were doing this?

THE WITNESS: Yes, your Honor.

THE COURT: There’s your foundation. I mean, that’s the foundation.

MR. DANDAR: Judge, I only have — I haven’t copied this yet, but I want him to identify it. We have the copier in the jury room so it doesn’t cause any noise. And then we’ll copy it. But this is Plaintiff’s Exhibit 114.

THE COURT: Okay.

BY MR. DANDAR:

Q Can you identify that?

MR. DANDAR: Then we’ll have it copied.

A This is the first Religious Technology Center Conditions Order, which is a committee of evidence, actually. And it lists — one, two, three, four, five, six, 24 seven, eight, nine, 10, 11, 12, 13, 14, 15, 16 — has 16 individuals listed on this document, of people that are

0216

receiving a justice action. These are people that were once in management, in Scientology, prior to 9 October, 1982. So David Mayo here was the senior CS international. He’s on this document. And this is the document that lists all of their supposed and alleged crimes.

And the people that constituted the committee that would determine their guilt or innocence on this crime composed of — one, two, three, four, five, six — seven people.

And the chairman was Ray Mithoff. The secretary was Shelly Miscavige. That’s David Miscavige’s wife. A member was Laura Marlowe. Laura Marlowe was Commander Steve Marlowe’s wife, who — at the time, he was a commander of the Religious Technology Center. And then is myself, Jesse Prince. Then there’s Gelda Mithoff, who’s the wife of Ray Mithoff, and Matt Pesch and Mark Fisher. Matt Pesch was a security guard. Mark Fisher was a personal assistant to David Miscavige.

And this committee was charged with finding — and this was basically what is constituted all of in management — to, you know, basically do another housecleaning or purging, as has happened in Scientology a time or two.

MR. DANDAR: Judge, I’d like to go ahead and

0217

have this copied, and I’ll distribute it. Is that all right?

THE COURT: Sure.

Did you mark it?

MR. DANDAR: Yes. It’s 114.

MR. WEINBERG: I have an objection to relevance. I haven’t looked at it yet. But what’s the relevance of a 1982 —

THE COURT: I don’t know.

MR. WEINBERG: — religious justice action against people?

THE COURT: I can only assume that this is part of Mr. Dandar’s case regarding his allegations of threats, extortions or whatever it is he’s alleging about.

MR. WEINBERG: That may be. But Mr. Minton was never a Scientologist so Mr. Minton didn’t — didn’t — didn’t undergo any committee of evidence or Scientology justice action.

I just don’t understand the relevance.

THE COURT: What is the relevance?

THE WITNESS: Well —

THE COURT: No. Not you.

THE WITNESS: Oh.

MR. DANDAR: Mr. Prince, who Mr. Weinberg

0218

called a janitor, is on this committee of evidence, with the other top Int management people, on a committee of evidence against David Mayo, who is the author of this highly secretive NOTS material. And it just shows Mr. Prince’s involvement in the higher echelons of Scientology.

THE COURT: So this is — this is just to show that he’s got some — what, that is — that he — is — is capable of testifying as an expert here?

MR. DANDAR: Yes. And —

THE COURT: Well, I’ve already accepted him as an expert.

MR. DANDAR: Okay. But it also goes to the policy bulletin on intelligence actions, which he — which is the basis of this testimony before we reached that document.

THE COURT: All right. Then I suppose it may have some relevance. I don’t know.

MR. WEINBERG: How does it go to that?

THE COURT: I don’t know. I mean, I have to believe some of the things the lawyers say.

MR. DANDAR: Let me show our next exhibit.This is in a series of, like, three or four documents on this subject. And then we’ll get on to a different matter.

0219

BY MR. DANDAR:

Q Plaintiff’s Exhibit 115, Mr. Prince. Can you identify that?

A Yes. This is a confidential issue that goes along with intelligence actions, noisy investigation, the Manual of Justice and other issues that really gives the attitude of how to go about taking apart a perceived enemy. It kind of gives the thought process, the — the basis of it. It comes from Klausewitz.

Q Again, this is entitled Battle Tactics. This is directed against the enemies of Scientology?

A Correct.

Q And then the third — actually, the fourth paragraph from the bottom it states — states, quote, One cuts off enemy communications, funds, connections. This policy letter goes to — applies to former Scientologists as well as someone who’s an — an enemy, who has never been a Scientologist?

A It could be anyone Scientology perceives as a — as an enemy.

THE COURT: Is this again what you call a suppressive person?

THE WITNESS: Yes. Or a suppressive group.

THE COURT: Okay.

THE WITNESS: And this talks about cutting off

0220

enemy communications, funds, connections; deprive the enemy of political advantages, connections and power. He takes over enemy territory; he raids and harasses. All on a thought plane —

THE COURT: Okay. You don’t have to read it to me, Mr. Prince. I —

THE WITNESS: Okay.

THE COURT: — can read.

BY MR. DANDAR:

Q Mr. Prince, on page 2, the second paragraph states, “Legal is a slow if often final battle arena. It eventually comes down to legal in the end. If intelligence and PRO have done well, then legal gets an easy win, close quote. What is PRO?

A Public relations officer.

Q And intelligence is what?

A Intelligence is the intelligence branch or department or division of Scientology organizations. Intelligence having to do with the prediction. Again, it goes back to this issue we have here, intelligence actions. The purpose of intelligence is to predict trouble, basically, before it occurs. And it states that in the issue.

So intelligence would predict or would start filing, start indexing, start doing this overt data collection, covert data collection, amass as much

0221

information about the situation as possible, then proceed accordingly.

Q That’s the — does that include the use of the private investigators?

A Yes.

Q Okay. Let me show you Exhibit 116.

THE COURT: While you’re doing that, can you all tell me whether or not a document called Middle — well, it’s something filed by Middle District of Florida, Complaint for Copyright infringement, Courage Productions versus Stacy Brooks — is that an exhibit in this hearing?

MR. WEINBERG: I believe so.

THE COURT: Okay.

MR. DANDAR: Not anymore?

MR. LIROT: It wasn’t one of our exhibits.

MR. WEINBERG: No. It was one of our exhibits.

THE COURT: Okay. Petition to Define Scope of Accounting and to Require Expedited Accounting?

MR. WEINBERG: I don’t think that is.

THE COURT: Okay.

MR. WEINBERG: I think it was just the complaint.

THE COURT: Okay.

0222

BY MR. DANDAR:

Q Mr. Prince, what is 116?

A 116 is a document in the same vein of the documents we’ve been studying before. It’s the public investigation section. And this basically has to do with — “investigates attacking individual members and see the results of the investigation, get adequate legal and publicity.”

So this again is similar to what we’ve gone over here before.

Q So it’s in a series of the other exhibits on how to deal with perceived enemies of Scientology?

A Correct.

Q Let me show you Plaintiff’s Exhibit 117, entitled Attacks on Scientology. What is that?

A Again, same year, same type of policy letter. It talks about dealing with attacks on Scientology. “An attack on Scientology –” well, you know, the basic principle is, never agree with the attack on Scientology; attack the attacker. That kind of thing.

Q Now, these were written in the mid- to late ’60s.

Were they still in effect when you were in your management position at RTC?

A Very much so. And they’re still in effect today.

MR. WEINBERG: Excuse me. Objection, your

0223

Honor. Based on what?

THE COURT: Sustained.

BY MR. DANDAR:

Q And how do you know they’re still in effect today?

A Because of that time track that was submitted into this courtroom of specific things that have — that have occurred to Mr. Minton over a period of years; over specifically what has happened to me because of my involvement in this case and other cases.

MR. WEINBERG: Same objection. Lack of foundation.

THE COURT: I think that he might can draw that inference, but I suspect he can’t testify that that is in fact what’s happening today. But he can infer that, I think.

BY MR. DANDAR:

Q Now, Mr. Minton — Mr. Prince, have any of the — these policies come into play in the — Pinellas County in the past?

MR. WEINBERG: Based on his experience while he was in the church? Is that what you’re asking?

MR. DANDAR: Yes.

MR. WEINBERG: You mean while he was there?

MR. DANDAR: No. Based upon his experience.

MR. WEINBERG: Well, then, I object. Come into

0224

play in Pinellas County?

THE COURT: If he’s talking about what occurred to him? Is that what you’re —

MR. DANDAR: No. What occurred to non-Scientologists in Pinellas County, orchestrated by the Church of Scientology in the past years. Before Mr. Minton arrived on the scene.

MR. WEINBERG: Your Honor —

THE COURT: How does he know that?

MR. DANDAR: Well, let me just use these exhibits then. I can see if he can qualify to talk  about them.

THE COURT: All right.

MR. DANDAR: I probably gave you the wrong exhibit, but — I withdraw the question. And I’m just going to go to another question. I had the wrong exhibit in my hand.

BY MR. DANDAR:

Q Mr. Prince, can you identify Plaintiff’s Exhibit 118?

A Yes. This is similar to RTC Conditions Order Number 1, in that it’s an ethics order that declare — one, two, three, four, five, six, seven, eight, nine, 10, 11 — 12 people to be suppressive persons.

0225

Q Paragraph numbered 4 says, “They are fair game.” What does this have to do with?

A Fair game?

Q Yeah. What’s this exhibit have to do with?

A This exhibit has to do with people that used some version of what Scientology perceived to be as upper-level materials and started some type of distribution of those materials, and for this they were labeled suppressive.

Q All right. And —

MR. WEINBERG: Your Honor, again, objection. What does this have to do with this case? If the Church of Scientology, within its internal structure, just like the Catholic church, declares somebody, in their language, a suppressive, you know, because they did something against the church; like, you know, attempt to — to take the — the scripture and change it — what’s that got to do with this hearing?

THE COURT: I think —

MR. WEINBERG: Has nothing to do with this  hearing.

THE COURT: Well, it does have something to do with this hearing. And if you don’t understand it, then I’ll have to explain it to you.

MR. WEINBERG: All right.

0226

THE COURT: It is very clear that the assertion being made is that Mr. Minton was a suppressive person; that Mr. Minton was subject to all of these things, including finding out all of the crimes that he may have committed, and bring it to his attention. That is the allegation of extortion.

MR. WEINBERG: These are people that are Scientologists, that are being declared pursuant — at the time, 1968 — being declared pursuant to the Scientology religious practices, under their justice system. Mr. Minton’s not a Scientologist.

THE COURT: There’s no question in my mind that, according to the matters that have been brought to this hearing, that Mr. Minton would have been considered a suppressive person.

MR. WEINBERG: But he’s putting in a document that — that says pursuant to church policy, these Scientologists are — are getting a certain justice action. That’s what that is. I mean, he doesn’t have personal knowledge. This is 1968, before he ever was in the church.

THE COURT: But you remember that the testimony has been that when Mr. Hubbard wrote something, it was followed. And it wasn’t changed. And it would be a high crime to change the writings of

0227

Mr. Hubbard.

You know, we don’t change the Bible just because times change. I presume you don’t change the writings of Mr. Hubbard. I mean, that is about as clear as anything I know.

MR. WEINBERG: To suggest that — that there is only one interpretation —

THE COURT: Nobody said there was one —

MR. WEINBERG: — of 50 words that are written —

THE COURT: Nobody said there is one interpretation. This is something that —

MR. WEINBERG: — is preposterous.

THE COURT: — that Mr. Hubbard wrote.

MR. WEINBERG: That has to do with an internal justice action with regard to Scientologists, in 1968.

THE COURT: I see the relevance, Counselor.

Apparently you don’t. I do. It’s this hearing. I think it’s relevant to this hearing. And it’s coming in. Take it up. Make your objection. It’s made, take —

MR. WEINBERG: I understand.

THE COURT: — it to the appellate court. Do

0228

whatever you want to do. Your objection is overruled.

MR. WEINBERG: I understand.

BY MR. DANDAR:

Q Mr. Prince, is this document 118 strictly internal?

A This issue would have been published internally, but it would have gone out — but it’s something that would have been put in each organization so that they would know who these suppressive persons are.  The purpose of these ethics orders — one of the purposes of these ethics orders is, when they’re issued, for everyone to have a copy, so that the same people couldn’t then walk into an organization and pretend to be Scientologists in good  standing and — and wreak further havoc on the organization —

MR. WEINBERG: Your Honor —

A — if that’s what’s —

MR. WEINBERG: — that’s not —

A — Scientology —

MR. WEINBERG: — that’s not — objection.

(Simultaneous speakers.)

MR. WEINBERG: He cannot authenticate this document. I believe this document, for whatever it’s worth, is a forgery. But he can’t authenticate

0229

it. He’s just guessing. He’s speculating. He wasn’t there when it was published. If it was published.

BY MR. DANDAR:

Q Mr. Prince, how did you obtain this document?

THE COURT: Yeah. Where did you get it?

THE WITNESS: This document was provided to me by Vaughn Young.

THE COURT: So you did not receive this document or see this document when you were in the church.

THE WITNESS: No.

THE COURT: Then that objection is sustained and it will not be admitted.

BY MR. DANDAR:

Q Well, Mr. Prince, does this have the — does this appear to be a genuine document?

THE COURT: Well, that —

A Absolutely.

THE COURT: That isn’t going to get it. He can’t — he can’t authenticate something that was given to him by Mr. Young. I mean, this is not quite the same as some of these other things that I’ve seen — this is something called — I mean, I don’t know if this is authentic or not. Some of the

0230

other things that all look like the same, then I’m going to allow it in, necessarily, without his authenticating.

MR. DANDAR: All right.

THE COURT: But this is different. So 118 is out.

MR. DANDAR: Okay.

BY MR. DANDAR:

Q Let me show you Plaintiff’s Exhibit 119. Can you identify this, please?

A Yes. This is a policy letter dated 3 February, 1966, and it concerns illegal tax accounting and those activities within the Scientology organization.

Q You highlighted the first paragraph under the caption Illegal Officer? Why did you do that? A Because I think that it, again, just like these other issues that we’ve seen, goes along in the same vein, in that Scientology will do anything to protect itself, including what it says it’ll do here: Create the greatest possible confusion and loss to an individual, to a government or whoever to protect Scientology.

MR. DANDAR: Your Honor, I move Exhibits 113 through 117 into evidence, skipping over 118, and I move 119 into evidence.

THE COURT: I’m going to receive those.

0231

BY MR. DANDAR:

Q Now, Mr. Prince —

MR. FUGATE: Judge, I have an objection. And I know —

THE COURT: And I’m not going to hear from Mr. Weinberg and from you and from counsel from New York. I mean, there’s three lawyers at the table. It isn’t going to happen. So you sit down.

Mr. Weinberg’s making the objections. Or Mr. Weinberg, you defer to Mr. Fugate? Which is it going to be?

MR. FUGATE: Mr. Weinberg’s witness, your Honor.

THE COURT: All right. Thank you.

Occasionally I will hear from our First Amendment expert, occasionally.

BY MR. DANDAR:

Q Let me show you —

MR. LIEBERMAN: I’ll exercise restraint, your Honor.

THE COURT: Thank you.

MR. LIEBERMAN: But there are times when —

THE COURT: I’m sure.

MR. LIEBERMAN: — I may try —

0232

BY MR. DANDAR:

Q Plaintiff’s Exhibit 120, Mr. Prince?

A Yes.

Q Can you identify that?

A Yes.

THE COURT: Please remember this is a most unusual hearing that we’re having.

A This is a document that explains — a confidential document written by someone in the Guardian’s Office, which was the predecessor of the Office of Special Affairs, concerning — the mayor, Gabe Cazares.

MR. WEINBERG: Objection.

BY MR. DANDAR:

Q Of course, Mr. Cazares wasn’t a Scientologist, right?

A Correct.

Q So these actions — do the actions we just previously introduced into evidence have anything to do with the actions taken by the Church of Scientology against Mayor Cazares?

MR. WEINBERG: Objection, your Honor. He has no — he has no knowledge — he was never in the Guardian’s Office. We’ve heard a lot of testimony about the Guardian’s Office, all of which is that Mr. Miscavige came in and eliminated it because of

0233

its misconduct. This is a 1976 document. There’s no way he can authenticate it. God knows where he got this one and who gave it to him.

THE COURT: Where did you get this?

THE WITNESS: Your Honor, this was, I believe, on our Internet site — not ours — on the Lisa McPherson Trust Internet site.

THE COURT: And —

BY MR. DANDAR:

Q Is this from the evidence in the Washington, D.C. prosecution?

A Yes.

THE COURT: What Washington, D.C. prosecution?

THE WITNESS: This was — I believe this was an exhibit in the D.C. case —

MR. DANDAR: Mary —

THE WITNESS: — where the 11 defendants were —

MR. DANDAR: The Mary Sue Hubbard case, the Guardian’s Office; people who broke into the FBI and other public government buildings and were prosecuted. Mr. Franks talked about this —

MR. WEINBERG: So —

THE COURT: Excuse me.

0234

MR. WEINBERG: Your Honor, Mr. Dandar likes to throw allegations around. One that he did throw around was David Miscavige murdered or caused the murder of Lisa McPherson, which he has not addressed, and he needs to address it. But this Guardian’s Office stuff has nothing to do with this hearing. Nothing. They were — they were — whatever they did wasn’t authorized by Mr. Hubbard, wasn’t authorized by the Church of Scientology. It was found out, they were thrown out  of the church and they were prosecuted. And that was all long before 1995. And what they were doing before Mr. Prince even got into Scientology. And he said he didn’t have anything to do with it.

THE COURT: This was — yeah. What is the relevance of this? It is true that the guardian ad litem — guardian ad litem. I need to get back to thinking — The Guardian’s office was — but I think that there’s been testimony that the Guardian’s Office was simply supplanted by another office. And I’ve  forgotten the name of it.

THE WITNESS: Office of —

MR. DANDAR: Office of —

0235

THE WITNESS: — Special Affairs.

MR. DANDAR: — Special Affairs.

THE COURT: Office of Special Affairs.

THE WITNESS: Yes.

MR. DANDAR: It’s the same —

THE COURT: And consequently — there is testimony that it was the same — and it was just — it was just something that was done to — I don’t know if this is true, because — I mean, this is — I think there’s sufficient information to allow this in.

MR. WEINBERG: It’s not true. And Mr. Prince wasn’t in the Office of Special Affairs. He wasn’t, and he doesn’t have any — he is not competent to testify about what went on in the Office of Special Affairs. He certainly can’t testify about what went on in the Guardian’s Office because he wasn’t even — he wasn’t there, and he wasn’t in the church at the time.

THE COURT: Well —

MR. WEINBERG: I mean, this is just — it’s just like we’re just going to throw all of the slime we can — excuse me, Ken — we’re going to throw all the slime we can out here? Well, why don’t we —

THE COURT: Well, you know —

0236

MR. WEINBERG: — address —

THE COURT: — it’s your motion. If you want to withdraw it, then you’re not going to have any slime.

MR. WEINBERG: We’re not —

THE COURT: Withdraw —

MR. WEINBERG: — going to —

THE COURT: — or —

MR. WEINBERG: We’re not going —

THE COURT: — listen and make your objection and I’ll rule on it. And sit down. Now. I’m going to rule this is admissible.

MR. WEINBERG: All right.

THE COURT: You’re going to hear some slime when you throw out the kind of motion that you made.

MR. WEINBERG: Well, I understand that, but we’ve been hearing it for a long time.

THE COURT: Well, we’re going to hear it for a lot longer. You’ve had your turn. This is his turn.

BY MR. DANDAR:

Q What’s the significance of 120; Exhibit 120?

A Exhibit 120 here just kind of shows a pattern of conduct where —

THE COURT: I’m not sure that he needs to

0237

explain this to us.

What — was he in the office in 1976, in the church?

MR. DANDAR: No.

BY MR. DANDAR:

Q Were you in the church at that time?

THE COURT: Well, then —

A Yes —

THE COURT: — how does he know about —

A — I was —

THE COURT: — that?

THE WITNESS: Excuse me.

A But yes, I was in Scientology in ’76.

THE COURT: Then did this come up when you were with RTC or something like that?

THE WITNESS: Well, your Honor, I think the reason why we have this document in here is because it shows the pattern of conduct that is a continuing pattern of conduct, where if there’s a perceived enemy, such as Gabe Cazares, they wrote up a specific program to remove him from any position. That’s the first thing it says in this document, you know, to remove this person from his job so that he’s not a threat to Scientology. And — and it goes on where, you know, they had

0238

some college — the person pretend to be a college student and write a letter —

THE COURT: Well —

THE WITNESS: — saying —

THE COURT: — this is 2002. The allegation that this occurred is in the year 2002.

Do we have any thought that was — what was going on in 1976 is still going on or was going in 2002 with Mr. Minton? I mean, it’s farfetched.

THE WITNESS: Well —

THE COURT: As I said, I let it in, but I don’t need a whole bunch of —

THE WITNESS: Okay.

THE COURT: — explanation from Mr. Prince.

BY MR. DANDAR:

Q Well, let’s — we’ll quickly then look at 121, and then we’re finished with this part.

A Okay.

THE COURT: And by the way, you call it slime. I should not have used that word. That was your word. Very poor choice of my words.

MR. WEINBERG: It was my word.

THE COURT: Yes, it was.

MR. WEINBERG: And I never —

THE COURT: Okay. I don’t even know what it

0239

says. I haven’t read it. So I don’t know if it’s slime or not.

BY MR. DANDAR:

Q Mr. Prince, can you identify Plaintiff’s Exhibit 121?

A Yes. This is a document called Project Normandy. This was a project that was executed when Scientology first arrived in Clearwater, which describes an intelligence activity so that it would be informed of exactly —

MR. WEINBERG: Objection, your Honor. No competence. There’s no way he can authenticate this document.

THE COURT: Yeah. This document doesn’t look like any document that I have seen. How do you — where did you see this document?

THE WITNESS: There’s a — this — this document, the first copy that I saw, was on a long sheet of paper, and it had an exhibit — an exhibit stamp on it, because this is one of the documents that was taken from the 1977 raid in Los Angeles. As — in this current form, it doesn’t have it. This was something that’s on — that was on the Lisa McPherson Trust Web site.

THE COURT: So you’ve never seen this document except on the Web site?

0240

THE WITNESS: No. I — I have seen the document with the exhibit number on it. The exhibit number was put on it by a court in D.C. It was part 4 of the documents — stipulation of evidence that was turned in in D.C.

MR. DANDAR: There was a stipulation of evidence between the government prosecutor and the Church of Scientology.

MR. WEINBERG: How does he know? I mean, your Honor, he — Mr. Dandar’s testifying about some case that went on 20 years ago.

THE COURT: Well, I suppose he knows because presumably he’s done some homework on it. I don’t know.

MR. WEINBERG: Well, your Honor, there is no exhibit —

THE COURT: I’m not allowing this in.

MR. DANDAR: All right.

THE COURT: I’m not allowing it in because there’s nothing that tells me it can be authenticated by this witness.

MR. DANDAR: All right.

THE COURT: And we — I’m not going to let the Lisa McPherson Web site be the basis upon which anything is authenticated.

0241

BY MR. DANDAR:

Q Let me show you Plaintiff’s Exhibit 122.

THE COURT: How much of this are we going to have to go through?

MR. DANDAR: It’s the last —

THE COURT: Your point’s been made, I think, the point you’re trying to make.

MR. DANDAR: Last one.

THE COURT: Well, you just said that about Number 121.

MR. DANDAR: Well, you didn’t let it in, so — I’m just kidding. I’m just kidding.

BY MR. DANDAR:

Q Can you identify 122, Mr. Prince?

A Yes. Number 22 (sic) is a document written and copyrighted by Scientology, written by L. Ron Hubbard. It was intended, when it was written, for persons that worked in the 1st Division of Scientology —

THE COURT: The what division?

THE WITNESS: The 1st, the number 1 —

THE COURT: F-i-r-s-t?

THE WITNESS: Yes, your Honor. The 1st Division of Scientology, which is called Division 1, HCO division. Hubbard Communications Office division.

0242

And this basically outlined again how to deal with bad press, how to investigate an attacker, this kind of thing. And public relations; how to deal with the press and public relations.

MR. DANDAR: I move 122 into evidence.

THE COURT: Any objection?

MR. WEINBERG: No.

Only as to relevance. This has to do with internal justice actions —

THE COURT: Well —

MR. WEINBERG: — with regard to Scientologists.

THE COURT: If it can be authenticated —

MR. WEINBERG: I didn’t object to the authentication.

THE COURT: All right. It will be admitted for any relevance that it might have. May not have any. It’s just hard for me to — when documents are presented, to take the time out to read them. It may not have any relevance. And some of these — these things that I’m letting in may be absolutely irrelevant, but they’re long and they’re hard — and it’s hard to read them.

MR. WEINBERG: I understand. I mean, this church, like the Catholic church and a lot of

0243

churches, has internal — has an internal justice system where they deal internally with — with what —

THE COURT: Well —

MR. WEINBERG: — you know, what they call crimes but, you know, in the secular world, are not necessarily crimes. And —

THE COURT: And you can make — and you can certainly make that point in your closing argument.

MR. DANDAR: I would object to any reference to similarities with the Catholic church.

THE COURT: Well, you can object all you want.

MR. DANDAR: Thank you.

THE COURT: It’s been declared a religion. It is a religion. So is the Catholic church a religion.

BY MR. DANDAR:

Q Mr. Prince, is there anything in particular on this Exhibit 122 that you want to bring to the court’s attention?

A Well, if you turn to the second page, under the Investigations section, second paragraph, it says, “When we need somebody haunted, we investigate.”

This talks about not only people inside of Scientology; this is referring to individuals outside of

0244

Scientology; people that have never been Scientologists; people that are perceived enemies of Scientology. They don’t have to be a Scientologist. And it — and it — this is — this document itself explains the basis of intelligence, investigation, how it’s used, how you handle bad press. And it — it’s just kind of like a little handbook or a blueprint to the persons whose job it is to have that function within Scientology.

THE COURT: All right.

BY MR. DANDAR:

Q All right. Now —

THE COURT: Number 122 is in evidence.

BY MR. DANDAR:

Q Have you ever been the subject of a Scientology intelligence operation, Mr. Prince?

A Yes, I have.

Q What and when?

A I guess it was 1999. I used to do work with families that would call, that had — members within the Church of Scientology. And they were concerned, they wanted another opinion, a different viewpoint presented to their family member. I was called by a fellow named John Porter, who informed me about a fellow in Bakersfield, Las Vegas, Nevada — Bakersfield, Nevada, who had a son in Scientology.

0245

He had spend $200,000 within a month, and the family was concerned that he was squandering his inheritance. I flew to Vegas, met with the person who supposedly was the father, and we had a chat and were going to proceed with it. But as it turned out the person, John Porter, was a person hired — a Scientology-hired private investigator.

The person that posed as the victim’s father was a retired sheriff. And I guess the purpose — and you know, they paid me a thousand dollars to come down and do this. But I guess the purpose was to see if I was going to say or do anything criminal that could be used to show that I’m forcefully deprogramming or capturing people. And of course, that never happened, so — And then this — I’ve only recently learned that this even was so. The whole deal with having a black private investigator come, give me marijuana, come to my house, putting the seeds on the back porch — you know, I’m  wondering, “Where is this,” you know, and I’m throwing it all — that whole stuff, as later come out, was an operation. I mean, they — they — My father lives in a retirement community. He’s 74 years old. The Scientologists have come and picketed his house and circled his house with signs.

0246

You know, those are just some of the things that have happened.

Q Okay. All right. Now, let’s go to Mr. Minton.

By the way, before we get to Minton, one question. You said you testified in the Wollersheim 4 case for the Church of Scientology Religious Technology Center. Did you ever testify in any other case for the Church of Scientology?

THE COURT: What year was that, please, Mr. Prince?

THE WITNESS: Your Honor, I believe it was 1986.

THE COURT: Were you still in the Church of Scientology at the time?

THE WITNESS: Yes.

THE COURT: And you testified as an expert for the church?

THE WITNESS: I testified as to — an expert particularly in the NED for OTs material.

THE COURT: See, he keeps saying that. I don’t know what that —

THE WITNESS: Oh.

THE COURT: Nefrotease (phonetic)?

THE WITNESS: NED for OTs.

MR. DANDAR: F-o-r.

0247

THE WITNESS: For. NED for OTs.

THE COURT: Oh. Sounds like you’re saying nefrotease.

THE WITNESS: Oh.

THE COURT: NED for OTs.

THE WITNESS: NED for OTs.

THE COURT: Okay.

THE WITNESS: I was a person qualified to study those documents, so I did a comparison to what David Mayo had as opposed to what the church had copyrighted, and I gave testimony about that.

THE COURT: So Madam Court Reporter, you understand all this time he’s been saying that, it’s NED for OTs?

THE REPORTER: Yes, your Honor.

THE COURT: Not “nefrotease.” All right.

(A discussion was held off the record.)

MR. DANDAR: And it’s abbreviated as NOTS.

THE COURT: So you were called to say, what, that this NED for OTs material was —

THE WITNESS: Was virtually identical to —

THE COURT: To some L. Ron Hubbard material.

THE WITNESS: No. The NED for OTs is the L. Ron Hubbard material. I was comparing them to  similar materials that they were using at what was

0248

known as the Advanced Abilities Center.

MR. WEINBERG: Your Honor, just for the record, my — my understanding is that Mr. Prince was testifying as a fact witness, not as an expert witness.

THE COURT: Well, it does seem as if there’s some complications as to who’s a fact witness and who’s an expert witness, and that’s something we’ll have to wrestle with in this trial too. So we’ll not go there. We’ll say he was either a fact or an expert witness.

BY MR. DANDAR:

Q And you were — you were always — when you — before you were told — you didn’t choose Mr. Miscavige as being a leader and you were booted out onto the rehabilitation project force, were you considered, before that point in time, an expert on the tech of Scientology?

A Very much so.

Q Okay. I don’t think your microphone’s on.

A Oh. How about now?

Q No. I don’t think it’s turned on.

A Oh.

THE COURT: I can hear him fine. If you lawyers can hear him, okay.

0249

BY MR. DANDAR:

Q Now, is there a — how does Scientology consider a Scientologist coming into a courtroom or anywhere and talking about Scientology?

MR. WEINBERG: Well —

THE COURT: I’m sorry. What was the question?

BY MR. DANDAR:

Q How does the Church of Scientology consider someone who testifies or talks about Scientology?

MR. WEINBERG: Objection. He’s now speaking for the entire Church of Scientology now?

THE COURT: I don’t know.

A Well —

BY MR. DANDAR:

Q Pursuant to the — pursuant to written policy of the Church of Scientology.

A According —

MR. WEINBERG: We —

A — to —

MR. WEINBERG: We object. He is certainly not talking for the Church of Scientology as to how the church considers some Scientologist coming in and testifying.

THE COURT: If he is testifying regarding his experience when he was in the church and as a

0250

witness, I will allow it. He is testifying, however, based on that and not — he really wouldn’t know how everybody else thinks.

MR. DANDAR: No. It’s based on the former.

Right.

THE COURT: Right.

A It is written policy in the Scientology ethics book, in its management series and basic staff books, that it is a crime to come into a court and testify about Scientology without first going over the information with Scientology or ethics officer, somebody within Scientology.

In other words, it’s a crime to just walk into a courtroom and speak, give testimony about Scientology, without first Scientology being privy to what that’s going to be —

MR. WEINBERG: Well, could we — could he tell us where this policy is?

THE COURT: Right.

THE WITNESS: Introduction to Scientology Ethics. It’s right there. I can pull it out and read it for you.

MR. WEINBERG: Could you point out —

MR. DANDAR: I’m handing the witness a hardbound book, Introduction to Scientology Ethics.

THE COURT: Did you say without first

0251

discussing it with an ethics officer?

THE WITNESS: Yes, your Honor.

THE COURT: Okay.

THE WITNESS: Here’s one reference to that. It says, “Testifying hostilely before a state –”

THE COURT: Why don’t you give us a page number?

THE WITNESS: Oh, I’m sorry. This is page number 209.

THE COURT: Okay.

THE WITNESS: It’s listed under Suppressive Act. Suppressive Acts. And it says, “Testifying hostilely before state or public inquiries into Scientology to suppress it –”

THE COURT: Well, that doesn’t really say –what you had just testified to is that it was a crime to testify without first discussing —

THE WITNESS: Right.

THE COURT: — it with an ethics officer.

THE WITNESS: Yeah. You’re right.

And what I’m looking for is called —

THE COURT: I’ll tell you what we’ll do. Let’s just let him look for that either over the break, our morning break, or at lunch. And if he can’t find it, you can make your objection. And if he

0252

can, then he can cite it into the record at that time and we can just go ahead and move on.

THE WITNESS: Yeah.

THE COURT: So you keep that with you and you can —

MR. WEINBERG: We have no problem with bringing the whole book into evidence. I mean, the book — many of the policies in there are — we were probably going to — are completely contradictory to what Mr. Dandar’s witnesses have been saying.

THE COURT: Okay. Well, if you want to —

MR. WEINBERG: So —

THE COURT: — put it in — this may be Mr. Dandar’s only copy. So if you want to put it in, maybe you have an extra one and you can do that.

MR. WEINBERG: Okay.

BY MR. DANDAR:

Q Mr. Prince, have you heard the term “acceptable truth”?

A Yes.

Q In Scientology policy, what does that mean?

A An acceptable truth is basically a truth where you don’t have to tell the — tell the whole truth or to tell an accurate truth, but just tell the truth that would be acceptable to the person that you’re speaking to.

0253

Q Okay. Does it have anything to do with not telling the truth?

A Very much so. It’s a way to evade or avoid a question or to avoid — yeah — to — a direct question.

MR. WEINBERG: Could we ask Mr. Prince to identify the policy and show us where in the policy it says what he just said?

THE COURT: I think — I think there’s some stuff in evidence already on acceptable truth.

MR. WEINBERG: There is, but it doesn’t say what he just said, that it’s okay to lie.

THE COURT: Well, then it — I presume, Mr. Prince, whatever it is you’re talking about, is the document that I think I’ve already seen —

THE WITNESS: Yes, your Honor.

THE COURT: — acceptable truth?

MR. LIEBERMAN: Yes.

THE COURT: So this is your interpretation of it based on your years in the church?

THE WITNESS: Yes, your Honor.

THE COURT: I can’t — I can’t remember what number it is, but there is some number in evidence that deals with acceptable truth.

MR. DANDAR: It’s — it’s called a PR series,

0254

and it talks about PR, public relations, and the second page mentions acceptable truths. And I’ll find that for you during the break.

BY MR. DANDAR:

Q All right, Mr. — Mr. Prince. When is the first time you met Bob Minton?

A I met Bob Minton in 1998. I think it was the spring of 1998 or perhaps — no, perhaps it was the summer of 1998.

Q And how was it that you came to meet him?

A I met him through Mrs. Brooks. She introduced me to him.

Q Where at?

A New Hampshire. At his home in New Hampshire.

Q And what caused you to be at his home in New Hampshire?

A I was on vacation —

Well, this is kind of a long story. I was on vacation in Connecticut. Previous to that, I had seen the Internet. And I never knew anything about it, and I just typed in, “Hey, my name is Jesse Prince. If anyone sees Stacy or Vaughn, you know, have them contact me. Here’s my number.” So I was vacationing in Connecticut.

Stacy called me, and we met and talked, and she introduced me to Bob.

0255

Q Why is it that you went on the Internet for the first time and asked for — have Stacy Vaughn — Stacy Young or Vaughn Young call you?

A Well, this was 1998. I had literally no contact with computers after leaving Scientology, in a way that there would be messaging systems amongst organizations and people and things like that. I was — I didn’t know anything about the Internet. I was at a cafe, a cybercafe.

And I did a search and typed in Scientology, and saw all of this stuff come up about Scientology. I saw all of these people openly critical of Scientology.

Now, for me this was completely unheard of. Because if a person was critical of Scientology, they would quickly be silenced. And I saw that — that Stacy and Vaughn were saying something, or someone made reference to them.

So I answered their message as best that I could, and say, “I need these people to contact me.”

Q When was the last time you considered yourself a Scientologist?

A You know, I know I’ve answered the question in different ways. And the fact of the matter is, is it’s kind of hard to tell. I — for me, I think probably by 1996, maybe, I was kind of like pretty much completely done with anything about it.

Q You left the — you left the organization where

0256

you — from RTC, then RPF, and — and you went to work for a Scientology-run public company or a private company run by a Scientologist, correct?

A Correct.

Q And they practiced the Hubbard technology at that company?

A Correct.

Q All right. So were you a Scientologist, then, when you were working for that company?

A You know, part of it, yes; part of it, no.

Q Okay. When did you leave that company?

A I left that company, I believe, in 1997.

Q Okay. When did you get contacted by Earle Cooley, the attorney for the Church of Scientology, after you left, formally, your position in Scientology?

THE COURT: Well, let me help myself out here, ’cause I don’t know — When you left, whatever that is, were you still a member of the Sea Org?

THE WITNESS: No, your Honor.

THE COURT: Okay. When did you stop being a member of the Sea Org?

THE WITNESS: October 31st, 1992.

THE COURT: Okay.

MR. WEINBERG: Well, that is the answer to your

0257

question. That’s when he left.

THE COURT: Well, that’s —

MR. WEINBERG: So — so when he left — the day he left, he stopped being a member of the Sea Org, is what he’s telling you, I think.

THE WITNESS: Correct.

THE COURT: So why is it, from 1992 to 1996, that you still — you were — You’re saying you were like a public member? Is that it?

THE WITNESS: Just a Scientologist. Correct.

THE COURT: Just a Scientologist. Okay.

BY MR. DANDAR:

Q Judge just brought up something.

When — how — what is the — what do the Sea Org people call Scientologists who are not on staff, but they’re Scientologists?

A Public Scientologists.

Q So they use the word “public.”

A Correct.

Q Okay. After meeting with Mr. Minton in the summer of ’98, what did you do after that, in reference to Mr. Minton?

A I went back home to Minneapolis. At the time, I was living in Minneapolis. And I continued to have dialogue

0258

with Mrs. Brooks, who informed me about a lawsuit that Scientology had filed against a corporation called FACTNet. And we started to —

THE COURT: What was the date, now?

I’m sorry, Mr. Prince.

THE WITNESS: This would have been 1998.

THE COURT: Okay. This was after you went to Mr. Minton’s home in New Hampshire? You stayed in touch? Is what you’re —

THE WITNESS: Yes.

THE COURT: Okay.

THE WITNESS: Yes, your Honor.

A She said — she talked to me about that, and she put me in touch with Daniel Leipold. And I started looking over some of the issues, and thought that I could help. So I started talking with Daniel Leipold, Mrs. Brooks. And within a week I received a letter from a Scientology attorney, Elliott Abelson4, letting me know that I was going to be sued if I cooperated with anyone against Scientology, basically.

BY MR. DANDAR:

Q Based on what?

A Based on — well, for me to leave the situation that I was in in the Sea Org, I had to — it was a kind of a give-or-take thing. I had to make certain concessions.

0259

I was being held there against my will, as well as my wife. We were, you know, deprived of basic human needs and — for months. And we were told that if we signed these documents, we would be allowed to walk out the door. Again, this went on for months. And then finally, in October, whatever they wanted us to sign —

THE COURT: Of what year?

You see, everything —

THE WITNESS: October of 1992.

A Whatever they wanted us to sign, we signed. So he made reference to the fact that I had signed a document saying I wouldn’t assist anyone in bringing any legal action against Scientology, nor would I do it myself.

BY MR. DANDAR:

Q FACTNet wasn’t bringing legal action; they were being sued by Scientology.

A Correct.

THE COURT: Who was this lawyer again? Which lawyer?

THE WITNESS: Elliott Abelson.

BY MR. DANDAR:

Q And so when you started to meet with Mr. Leipold on the FACTNet case, you got this letter from Mr. Abelson. What did you do?

0260

A Well, I took it to the lawyer, and I explained the situation to him then, Daniel Leipold. And when I explained the situation to him, he actually drafted a suit against maybe Golden Era or whatever — I never actually saw the suit myself — and filed it in Riverside County. And then there was a whole press thing. I was interviewed by the newspaper and on and on.

Q Okay. Anything come out of that lawsuit?

A No.

Q All right. So did you go to work for FACTNet?

A Yes, I did.

Q All right. And how long did you stay there?

A Maybe about a year, a year and a half.

Q Okay. ’98 to ’99?

A ’98 to ’99. Yeah. About a year.

Q Okay. And at some point in time you came to Florida to look at the Lisa McPherson PC folders?

A Correct.

Q All right. And you looked over those folders with Stacy Brooks?

A Yes, I did.

Q And then after we received a copy of the PC folders under court order, you went and took your time and examined all —

MR. WEINBERG: Your Honor, could there be

0261

direct questions and not —

THE COURT: Yes.

MR. DANDAR: I’m just trying to speed it up.

MR. WEINBERG: Well, I would prefer a direct question.

THE COURT: Okay. Well, you know what, some of this — you’re right. But some of this is preliminary. We know he looked at the folders.

MR. WEINBERG: It’s the — it’s the testimony.

THE COURT: Okay.

MR. WEINBERG: I know he looked at them, and I didn’t object to that part of it.

THE COURT: Okay.

(A discussion was held off the record.)

THE COURT: We’ll take a break right now.

We’ll be in recess for 15 minutes or 20 minutes. 15, we’ll try for.

(A recess was taken at 10:48 a.m.)

(The proceedings resumed at 11:18 a.m.)

MR. BATTAGLIA: Your Honor, may I approach the bench?

THE COURT: You may.

MR. BATTAGLIA: I’d like to announce to the court I’m going to be making an appearance in this matter for Robert Minton as lead counsel, so I will

0262

be submitting a formal notice. I just want the court to be aware of that.

THE COURT: Now, will that be for all purposes?

MR. BATTAGLIA: Well, for all purposes. But Mr. Howie still will be involved in portions of the case.

We will send in a formal notice. We were retained this past Thursday.

THE COURT: All right. Very good. I think, Mr. Battaglia, there is a matter pending that I frankly would like to hear. Because it is a motion, I believe, to dismiss the counterclaim. And if it’s not dismissed, then obviously he needs to answer it because it could have some bearing on the counterclaim.

MR. BATTAGLIA: I have to check that. I understand from talking to Mr. Howie that he may have responded to that counterclaim and affirmative defenses. I’d have to check that out.

THE COURT: If he did, I haven’t seen it.

MR. DANDAR: I’m Ken Dandar, by the way. Judge, Mr. Howie filed a motion to dismiss the pending counterclaim. They never filed the new counterclaim naming Mr. Minton, so he prematurely filed a motion to dismiss. We never received a new

0263

counterclaim which is supposed to name Mr. Minton as a defendant. We’re still waiting for that.

THE COURT: Okay. I think that perhaps the reason why they didn’t file a new one is because I allowed him to be added orally, to be — to be amended, I guess. So perhaps they — I mean, Mr. Howie obviously thought it had been filed, for all intents and purposes, with the oral amendments, because he did file a motion to dismiss or something.

MR. BATTAGLIA: Your Honor, I did look. That was a problem that puzzled me a bit, because there was no order in the file, and then there was a corrective counterclaim that was filed. And I didn’t understand the import of that, because the party was just added by a corrective counterclaim without an order of the court. I assumed you had granted that orally.

THE COURT: I had. And I had granted it orally, and maybe I just forgot to sign an order. Can you all go back and maybe look into that? Because it was your motion, I believe, to add him.

MR. LIEBERMAN: Yes.

THE COURT: And I granted it. And I know Mr. Howie was here, and I said, “It’s granted and he

0264

is now a party.”

MR. LIEBERMAN: Yes. And he was allowed to sit in as a party from then on, as opposed to being excluded under the rules.

MR. BATTAGLIA: Is there presently a motion to dismiss pending?

THE COURT: Yes. That Mr. Howie has filed.

MR. BATTAGLIA: Filed on behalf of Minton?

THE COURT: Yes.

MR. BATTAGLIA: We’ll look into that.

THE COURT: It’s more than a motion to dismiss.

MR. BATTAGLIA: It is. It’s a motion to dismiss and a motion to strike.

THE COURT: Yes.

MR. BATTAGLIA: I saw that. And we’ll get back to the court.

You got to understand we’re coming in very late. There’s thousands and thousands of exhibits. And we’re just trying to catch up here.

THE COURT: Yes. There are thousands and thousands of exhibits.

MR. BATTAGLIA: It’s going to take a bit —

THE COURT: I’m sure it is.

(The reporter had technical problems and there was a pause in the proceedings.)

0265

MR. WEINBERG: Your Honor, before the break, Mr. Prince had said he was going to find the section —

THE COURT: Yes.

MR. WEINBERG: In the ethics book that said you had to get the permission of an ethics officer to testify about Scientology. Could he —

THE COURT: Did you find that?

THE WITNESS: Your Honor, I misspoke as to where the actual quote was. It’s not in the ethics book, but it is in another volume which unfortunately we do not have here, but I will get it and I will submit it to the court.

THE COURT: All right. And the same — if you can’t, why, we’ll strike that.

THE WITNESS: Okay.

BY MR. DANDAR:

Q Mr. Prince, let me show you Plaintiff’s Exhibit Number 123. Can you identify 123?

A Yes. This is a series that’s put out for the technical part of Scientology which has to do with the PC Folder and the contents of the PC folder.

Q And is this something you were trained on as a technical person in Scientology?

A Yes.

0266

Q Okay.

THE COURT: I hate to interrupt you, and I feel really bad about it.

This was laying here. I don’t know whether this is something that was previously admitted. It doesn’t have a number on it.

MR. DANDAR: This was. This was 114, which was admitted.

THE COURT: Okay. Thank you.

MR. DANDAR: I’d like to move Exhibit 123 in evidence.

MR. WEINBERG: Is it one exhibit or two exhibits? You handed me —

MR. DANDAR: Did I hand you two?

MR. WEINBERG: You handed me The PC folder and Its Contents, and Mixing Rundowns and Repairs. One was an exhibit dated November 13th, 1997, which was after Mr. Hubbard died. But I don’t have an objection to it, if you want —

THE COURT: It does look like you have two different things here.

MR. DANDAR: I have two. And I meant to do that. It involves the —

THE COURT: Well, then, how about making them A and B?

0267

MR. DANDAR: All right.

THE COURT: 123-A will be The PC folder and Its Contents; 123-B, if you’re saying it’s related, will be Mixing Rundowns and Repairs —

MR. DANDAR: Well —

THE COURT: — 123-B?

MR. DANDAR: Let’s make sure I’m right about that.

MR. WEINBERG: When I say I’m not going to object, I do have an objection to all of this and Mr. Prince testifying, but I don’t object to the authenticity of these.

THE COURT: Okay.

BY MR. DANDAR:

Q Mr. Prince, is the separate document, that apparently is paper clipped to The PC Folder and Its Contents, entitled Mixing Rundowns and Repairs — is that related to The PC folder and Its Contents or is that something different?

A That’s something different.

MR. DANDAR: Okay. Then I will withdraw that.

THE COURT: All right. So it’s just 123, The PC Folder and Its Content.

MR. DANDAR: Right.

THE COURT: Okay.

0268

BY MR. DANDAR:

Q Now, Mr. Prince, is the Church of Scientology allowed to deviate from this bulletin of November 13th, 1987 on what is supposed to be in a person’s PC folder?

A Not at all. The whole purpose of this issue is to clearly define what is expected to be in a preclear folder. It gives the significance of what each item is, in detail, and auditors — any person that audits in Scientology is trained on this as a basic for auditing.

Q Now, Mr. Weinberg brought up a good point. Mr. Hubbard died in 1986. How can this policy letter dated November of 1987 bear his stamp of approval with his name on it?

A Well, turning to the last page, it says, “This is a compilation assisted by the LRH Technical Research Compilations.” There are other — there’s another issue type that isn’t a formal issue type within Scientology, which is called advices. And often, from advices, policy letters can be compiled and issued.

Q And that’s what this is? This is a compilation?

A Correct.

MR. DANDAR: Like to move Exhibit 123 into evidence.

THE COURT: It’ll be received.

0269

BY MR. DANDAR:

Q Also Mr. Prince, I’m going to show you Exhibit 124. It’s marked for identification.

MR. DANDAR: Hand one to the court and counsel.

BY MR. DANDAR:

Q Can you identify 124?

A Yes. This is a Scientology policy directive. And this was issued from the writings of L. Ron Hubbard and authorized by the watchdog committee, adopted as church policy. This concerns confidentiality aspects of preclear folders and what’s expected to be in them.

MR. DANDAR: Okay. I’d like to move 124 into evidence.

MR. WEINBERG: No objection.

THE COURT: All right. It’ll be received.

BY MR. DANDAR:

Q Now, Mr. Prince, when you started to review Lisa McPherson’s 1995 PC folders, did you find them to be intact?

A No, I did not.

Q Did you create an affidavit which — where you disclosed things that were missing?

A Yes, I did.

THE COURT: Are we now into that part of the testimony that deals with the complaint itself?

MR. DANDAR: Yes.

0270

THE COURT: Okay.

BY MR. DANDAR:

Q Mr. Prince — and we’ve already had marked, and I believe it’s in evidence, Plaintiff’s Exhibit 108, which is your affidavit dated April 4, 2000, concerning the PC folders, and with a list of things that are missing. Do you
recall creating that affidavit?

A Yes, I do.

Q Do you need to see it to refresh your memory?

A Yes, I do.

Q Did anyone help you in creating that affidavit?

THE COURT: What was the number of Plaintiff’s Exhibit again? 108?

MR. DANDAR: Yes.

Let’s make sure it’s in evidence. I’m pretty sure it is.

THE COURT: As a matter of fact, if he’s going to be referring to it, Madam Clerk, if you could get — let me use the official copy. And I’m sure you filed mine in its appropriate book.

MR. WEINBERG: Your Honor, while she’s looking, I object to all this as to the relevance, as to what was or what was not in the PC folder.

What the hearing is about is whether or not Mr. Dandar made a sham pleading and Mr. Prince

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executed in essence a sham affidavit, accusing David Miscavige of murder, and whether or not there’s been various misconduct from the plaintiff’s side regarding various testimony in the case.

What does what was in the PC folder or not have to do with that?

MR. DANDAR: This falls under the second category in Mr. Weinberg’s comments: Various misconduct. They have accused me of lying about the fact that Lisa McPherson wanted to leave Scientology. Somehow I just made that all up and I got people to lie about it.

And that’s part of their terminating sanction motion and disqualification motion.

MR. WEINBERG: So you —

But what’s that got to do with what’s missing?

You going to ask him what was in the PC folders? Is that what you’re saying?

THE COURT: Well, there’s also an allegation as to his complaint and whether or not there’s any basis for it. And part of what I have read, maybe in Mr. Prince’s affidavit, that some of the missing data is data from the workers, which the testimony would be, from some witness — Mr. Prince, perhaps — should have been in the PC folders,

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and —

MR. WEINBERG: I mean, I — they’ve made that allegation, although the workers all testified what they did, what they saw and all that.

But that has nothing to do with whether or not David Miscavige ordered Lisa McPherson to be killed. Just —

THE COURT: Well, whether it was an intentional death, I think, is at issue here, and I think it does. So your objection’s overruled.

MR. DANDAR: Was 109 not in evidence?

THE COURT: And besides that — I don’t know what his testimony’s going to be, but if this is, in some fashion, what he relied upon for his opinion, then I think it’s got to be relevant for his opinion.

MR. WEINBERG: I thought it was inquiring. I mean, it’s —

THE COURT: I think that probably for all those different things it has some relevance, so I’m going to let it in.

MR. DANDAR: And Judge, 108’s previously been admitted into evidence.

THE COURT: Right.

BY MR. DANDAR:

Q Now, Mr. Prince, when you reviewed the files of

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Lisa McPherson, did you find routing forms?

A I did not.

Q And recently we showed you some routing forms that, within the last few weeks, that the Church of Scientology states they have reproduced to us. And did you review those?

A Yes, I did.

Q Do those routing forms have anything to do with Lisa McPherson spending six to eight weeks at the Ft. Harrison Hotel in the summer of 1995?

A No, they do not.

Q Do those routing forms have anything to do with Lisa McPherson spending 17 days at the Ft. Harrison Hotel from November 18th of ’95 to December 5th of ’95?

A No, they do not.

Q Can a person, a public member like Lisa McPherson, stay at the Ft. Harrison Hotel without a routing form?

A No, she could not.

Q What would the routing form tell us?

MR. WEINBERG: Objection. Competence. I mean, is Mr. Prince saying that he has knowledge as to what a person that checks into the Ft. Harrison Hotel has to fill out in order to be a guest there?

You have to have a routing form as opposed to registering as a guest? What basis? He never

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worked at the Ft. Harrison Hotel.

THE COURT: He is telling us, based on his experience in Scientology, as to what a routing form is used for and what a routing form should have on it.

MR. WEINBERG: But Mr. Dandar asked him whether you needed a routing form to be a guest at the Ft. Harrison Hotel.

MR. DANDAR: Well, let me rephrase the question.

BY MR. DANDAR:

Q Do you need a routing form, Mr. Prince, to be in a program such as the introspection rundown, whether it’s the Ft. Harrison Hotel or any other property of the Church of Scientology?

A Yes, you do.

Q And why is that?

A Because the Ft. Harrison —

And I’ll just say this: It’s incorrect that I never worked at the Ft. Harrison Hotel. I worked at the Ft. Harrison from 1979 to 1982.

The Ft. Harrison has many divisions, many departments, many sections that people come either for training or for auditing. They have different places where people would get auditing.

0275

And the whole purpose of a routing form is when a person comes in for service, they sign in, they get their hotel room, they’re routed to pay for their hotel room, they get what their room is, any questions are answered. When
they’re ready for services, they go down, they’re put on another routing form.

And like, if they’re going to get a service — a training course, a TRs course, it would be on the routing form, and they would go see the registrar; they would go and see the director of processing; maybe they would get an interview.

In other words, the routing form gives you the areas and the people that you need to see and the places you need to go to in order to accomplish what you have come for.

Q And is there any policy that permits a deviation from the requirement to have a routing form?

A No, there is not.

Q As an expert on Scientology tech, what does it mean to you that there is no routing form for Lisa McPherson?

A Well, in and of itself, that is an oddity. But when you take into consideration the fact — many other items that are missing from her preclear folder, I can only opine that this was information that would have not been good to discover for Scientology’s behalf.

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MR. WEINBERG: Objection.

BY MR. DANDAR:

Q Have you —

MR. WEINBERG: Competence, your Honor.

THE COURT: I’m going to allow it. I’m going to allow it for this hearing.

BY MR. DANDAR:

Q Have you been involved in the destruction — intentional destruction of PC folders of members, in addition to Mr. Wollersheim’s, that you previously testified about at this hearing —

A Well —

Q — which was ordered to be pulped by Mr. Miscavige?

A Well, at the time that the Wollersheim incident happened, because there were threats from other people such as John Nelson and — well, I don’t know. You know, there was a list of people at the time. The only one that I specifically recall right now is John Nelson. But their folders were destroyed as well.

Q What about Mr. Armstrong?

A Yes. His as well.

Q What about Mr. Franks?

A I believe his was as well.

MR. WEINBERG: Excuse me.

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THE COURT: Yeah.

MR. WEINBERG: Believe? Or does he know?

THE COURT: Do you know that or —

THE WITNESS: Your Honor, as I sit here today, I can’t say for certain —

THE COURT: Okay.

THE WITNESS: — but I knew there were certainly more than Mr. Wollersheim’s folders, because there were a list of people. And I can’t sit here and recall today every name —

THE COURT: Okay.

THE WITNESS: — that was on that list.

THE COURT: Okay.

BY MR. DANDAR:

Q What is the significance to you — let’s start with the missing — what’s missing from her folder. In the introspection rundown that Mr. Kartuzinski states she was under November 18th through December 5th of ’95, is there supposed to be documentation in a PC folder that Lisa McPherson was indeed under the introspection rundown?

THE COURT: What dates, now? Are we talking about the 17-day dates?

MR. DANDAR: Yes.

THE COURT: Okay.

0278

A Yes. There would have been, in the very front of the folder, what’s called a program. It would have been a repair program. It would have been something that’s on a pink piece of paper as opposed to a blue piece of paper.
The color in the paper — the color within the preclear folder also has significance.

But in Lisa’s case, there would have been, if she was on — on the introspection rundown, it would have given a short statement of who she was, what she’s accomplished, what her last auditing activities were, and what the current problem was, what the symptoms were that she was experiencing that would cause her to be on introspection rundown.

MR. WEINBERG: Your Honor, I have an objection to this whole line. I — I take it where he’s going is to suggest that she wasn’t on the introspection rundown, when he alleged in the complaint that she was on the introspection rundown. It’s not an issue in this case. We answered the complaint. It’s not an issue.

THE COURT: That’s true.

MR. DANDAR: I subsequently discovered that this program was missing, that Mr. Kartuzinski, under oath, said was in her PC folder. Now I’m not sure what she was going through and where she was.

0279

These things — these things are missing, and we would have to conform the pleadings to the evidence as we discover new things that are — go on.

THE COURT: So what are you saying? Are you saying that you — that she was not under the introspection rundown?

MR. DANDAR: Well —

THE COURT: Or you don’t know?

MR. DANDAR: I’m saying it’s not a confirmed fact that she was on the introspection rundown, because of what’s missing.

THE COURT: Okay. I’m going to let this witness testify at this hearing, because we need to get to where it was that he comes up with his conclusions —

MR. WEINBERG: I understand.

THE COURT: — and I assume all this has something to do with it, so —

MR. WEINBERG: I’m not sure I have the same assumption, but I understand where you’re —

THE COURT: All right.

BY MR. DANDAR:

Q In your experience in Scientology, were things that were beneficial — papers and documents that were

0280

beneficial to Scientology removed from a member’s PC folder?

A No. You know — and I’ve written a declaration about this before — well, this declaration may be in and of itself — you know, with the Wollersheim, there was the process of, “Okay, well, we’ll turn over something; we’ll go
through and we’ll — we’ll get rid of any kind of incriminating things that would incriminate Scientology.”

Then when the production of all the folders were called for, it — that became too massive of a task and it was decided to destroy them.

MR. WEINBERG: Your Honor, could I say one more thing, so I don’t lose this train of thought?

I did object, and I understand your ruling, but he already had alleged that — that the introspection rundown happened, and his response to your question and my statement was, “I just recently discovered it.”

Well, Mr. Prince reviewed the PC folders, his expert, in December of 1998, and whatever wasn’t there in December of 1998 certainly isn’t there now. So what’s he talking about?

THE COURT: I don’t know, but I think that this testimony is going to tell us why Mr. Prince concluded what he concluded, which is what Mr. Dandar relied on for his complaint. It is relevant for this hearing.

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Please don’t object again.

MR. WEINBERG: I’m sorry.

BY MR. DANDAR:

Q Mr. Prince, you — when did you actually sit down and review the 1995 PC folders of Lisa McPherson?

A It was in the fall of 1999.

Q What’s the date of that affidavit?

A The date of this affidavit is April — the 4th of April, 2000.

Q Okay. And concerning this one issue, the issue of whether or not Lisa McPherson was satisfied with her Scientology experience, do the PC folders reveal what she had to say about her Scientology experience in 1995?

A Yes, it does. And I think I’ve covered that with as much detail as possible: That she wanted to leave. She actually made plans to leave. And she felt like she was starting to become damaged.

Q And that’s inside the PC folders?

A Correct.

Q Now, within your experience of Scientology, have you used — have you — are you familiar with the term “end cycle”?

A Yes, I am.

Q And what is your understanding or familiarity with that term?

0282

THE COURT: Can I —

I’m sorry. I’m as bad at interrupting chain of thought as anybody.

This — this particular affidavit is the affidavit that was dealing with her wishing to leave that was part of the motion for summary judgment that was ruled on by Judge Quesada, is that right?

MR. DANDAR: Well, that was part of it, but there’s a lot more than just that in there. It talks about things that are missing from her PC folder.

THE COURT: Okay. All right. Now we’re past the missing items from the PC folder and to —

MR. DANDAR: Trying to get that paragraph 34.

THE COURT: Okay. Thank you.

MR. DANDAR: All right.

BY MR. DANDAR:

Q Are people who want to leave the Church of Scientology — how are they looked at, within your experience and per policy by the Church of Scientology?

A Well, people who want to leave Scientology and publicly state such are considered criminals, because that’s a high crime in Scientology.

MR. WEINBERG: Your Honor —

A I do have the instant reference on that right now.

0283

BY MR. DANDAR:

Q And what is that?

A That PT/SP 5package that was —

MR. WEINBERG: Can we just establish, is he talking about staff members or public members or both?

THE WITNESS: Any member of Scientology, public member of Scientology, it’s a high crime.

MR. DANDAR: Okay. I’m handing the witness PT/SP course, a booklet that was previously talked about —

THE COURT: Oh, yes.

MR. DANDAR: — by other witnesses.

THE COURT: I think it’s in evidence, isn’t it?

MR. DANDAR: It’s possible. I mean, I’m not sure.

THE COURT: Maybe it isn’t, but I’ve seen that book.

MR. DANDAR: Right. Search and Discovery is in evidence. That came out of here.

THE WITNESS: Says right here, “It is a high crime to publicly depart Scientology.” And this comes from HCO policy letter of 23 December, 1965, RB, Suppressive X, Suppression of Scientology and Scientologists.

0284

THE COURT: What page are you reading from, sir, in that book?

THE WITNESS: Where I read that quote from, I am reading from — I just read from 159.

THE COURT: Okay.

MR. DANDAR: Judge, I’ll have that entire policy marked.

MR. WEINBERG: Your Honor, my objection to this is it talks about — Mr. Prince read it –publicly — a person publicly announces he’s going to depart Scientology. Well, that’s not what we have in this case. What’s that have to do with this case?

THE COURT: I’m sorry. I didn’t hear him say “publicly.”

MR. WEINBERG: That’s what he read. That was —

THE WITNESS: It says, “It is a high crime to publicly depart Scientology.”

I think Lisa had done that, because she had told her mother and she had told a friend that she was leaving Scientology. And she made it known, in the notes that I made here, that she intended to leave. She wasn’t happy with —

MR. WEINBERG: I object to that statement

0285

because the evidence —

THE COURT: Well, look, you don’t need to object to that, because I know enough about —

MR. WEINBERG: Okay.

THE COURT: — the evidence with the mother and the evidence with the friend and the fact that what would be in her PC folder would hardly be public, where I can determine the validity of that statement.

MR. WEINBERG: Okay. All right.

BY MR. DANDAR:

Q Mr. Prince, within your experience with Scientology, what does that — what does it mean to publicly leave Scientology?

A You could publicly leave Scientology in several ways. You could submit a letter of resignation and make that letter available to other parties beyond a recant, which would — in a normal organization, would be the ethics officer.

I guess in these days and times you could go on the Internet or you could just simply announce to your friends and fellow Scientologists that you have the intention of leaving.

THE COURT: How about if I just don’t go back? I mean, if I’m a member of a church — which I was at one time when I was a child — and I just don’t

0286

go back? I mean, is that — is that leaving?

THE WITNESS: Yes. That is considered a form of leaving. And — and in that instance, if you just simply left, you would be contacted and asked to come into the organization so that they could find out what happened. If you —

THE COURT: And what if you just don’t go in?

In other words, I’m a public member, which is what Lisa McPherson was — this is a hypothetical — and I — even — I don’t want to go back and I don’t want to get any more auditing and I don’t want to go to any more services and I just don’t go?

THE WITNESS: Well —

THE COURT: They say, “Come in,” and I just decline and I don’t go.

THE WITNESS: Then they’ll show up on your door.

THE COURT: Oh.

BY MR. DANDAR:

Q Okay.

A There’s a process of getting out of Scientology. There is a way to do it. And normally, it involves signing a release agreeing that you will never — that you’ll be ineligible for Scientology services in the future —

Q To —

0287

A — and you would also have to sign a statement saying that you release any claims of any possible damage or upset that you had — in other words, a general release for the different Scientology corporations that you’ve been involved in.

MR. WEINBERG: Could we just make it clear that that’s only — that he’s talking about staff members and not public members having to sign a release?

THE WITNESS: I — it’s staff and public. I — that’s the second time I’ve said that.

BY MR. DANDAR:

Q Okay. Mr. Prince, you said that she talked to her friend from high school about wanting to leave. Where did you get that information from?

A From her testimony.

Q The friend’s testimony?

A Yes.

Q Kelly Davis?

A Yes.

Q And when you said that Lisa called her mother and said she wanted to leave. Where did you get that from?

A I think — I read — I read it — I read it somewhere in the evidence. I can’t —

Q Okay.

A — put my finger on exactly where —

0288

Q Do you recall —

A — I saw it.

Q — Lisa’s mother, Fannie, having a Hospice worker by the name Sandra Anderson?

A That’s right.

Q Is that what you’re referring to?

A Yes.

MR. WEINBERG: Your Honor, is he, like, prompting him now?

THE COURT: I would say so.

Stop leading him.

MR. DANDAR: It’s either — wanted to make sure it wasn’t from me. Because that’s the accusation.

THE COURT: Move on, Counselor.

MR. DANDAR: All right.

BY MR. DANDAR:

Q Mr. Prince, end cycle. Can you tell us what — where and when you’ve heard that or seen that term?

A End cycle has a history in Scientology. And it has varied meanings.

One meaning of end cycle is to start, change and stop something. In other words, you start it — you start an activity, you carry through to its intended result or purpose, and then you end it. So ending the cycle, you know, like this hearing is going to have an end of cycle

0289

when the judge decides who’s right and who’s wrong or discovers the issues. That’s one form of end cycle. Another form of end cycle is to die. This — this — this idea of ending cycle to die came into prominence in my mind and in my experience in Scientology after Mr. Hubbard passed in 1986 at a discussion with senior CS Ray Mithoff. Because I was curious. He sat on a deathbed with L. Ron Hubbard.

And I asked him, you know, “When he died –” I asked him, you know, because this was — L. Ron Hubbard was a person that we all looked up to. And I — and I was curious. You know, “Well, how did this man die? What were the exact circumstances? What happened there?”

And he said that he positively started shutting down certain parts of his body; his, you know, certain part of his systems.

And I asked, “Well, how does this happen? I mean, what are you — what are you doing?” And he told me the Scientology process is that you use — you know, you talk about what the — your attention may be stuck on; at what problems do you have with dying? I mean, there’s a whole procedure that you go through to prepare for death so that you have no attention or problems with death and can die.

When Mr. Hubbard passed, at that point I started seeing, you know, more of the concept of ending cycle, as

0290

far as to die.

THE COURT: Is this a little bit like a — what we might think of Hospice and how they prepare someone —

THE WITNESS: Sure.

THE COURT: — with a terminal disease in your family and —

THE WITNESS: Correct.

THE COURT: Okay.

BY MR. DANDAR:

Q Well, Mr. Hubbard didn’t have a terminal disease, though, did he?

A To my knowledge, no.

Q But he still went through that process of end cycle?

A Yes.

Q So where else did you see that term used in reference to dying?

A Terminally ill people. I’ve also read this up in affidavits.

A friend of mine, Ted Cormack (phonetic), had Hodgkin’s disease. It was apparently fatal. I saw in his folder from Mr. Mithoff the necessary steps that people do in order to, you know, give up the ghost, basically; you know, to die.

0291

THE COURT: Die in peace —

THE WITNESS: Right.

THE COURT: — like in Hospice.

THE WITNESS: Exactly.

BY MR. DANDAR:

Q Do they do that by themselves?

A No. It’s done with an auditor.

Q And did you —

THE COURT: With what, sir?

THE WITNESS: An auditor.

BY MR. DANDAR:

Q And is there ever anything in writing about having an auditor go in and assist someone to die?

A Absolutely. There would be, as in Lisa’s case, a program. That program would —

MR. DANDAR: Can I — can I please have these people stop laughing?

THE COURT: Yes.

MR. WEINBERG: We apologize.

And I object. “As in Lisa’s case, a program.” I mean, he has just said 10 minutes ago that there was no program, and therefore —

THE COURT: He is trying to tell us what he believes to be missing —

MR. WEINBERG: Well —

0292

THE COURT: — which is what he’s talking about: Missing things in the PC folder, which is what gave his opinion that he gave to Mr. Dandar, who filed the complaint.

MR. WEINBERG: But the question was, though, was generally about his understanding of end cycle, end of cycle.

THE COURT: Your objection is overruled.

And I’m going to instruct you all back there to stop laughing.

MR. WEINBERG: You’re right.

THE COURT: Go ahead, Mr. Dandar.

MR. DANDAR: Okay.

THE COURT: So it’s your belief that an auditor would have been with Lisa McPherson when she died? Is that what you’re suggesting, from this missing — missing documents, or what?

THE WITNESS: Well — well, you know, your Honor, for me that’s kind of mixing apples and oranges. Because the question he asked me was about a specific incident that happened with a fellow named Ted Cormack —

THE COURT: Right.

THE WITNESS: — so.

THE COURT: Did you see his PC folder?

0293

THE WITNESS: Yes, your Honor.

THE COURT: And what is in there?

THE WITNESS: The process is similar to what you said, in Hospice, when a person dies in peace; you know — you know, as far as they’re concerned everything’s taken care of and they can go.

THE COURT: Okay. And so that you saw that in his PC folder?

THE WITNESS: Yeah. You know —

THE COURT: And said an auditor was there?

THE WITNESS: Yes.

THE COURT: Okay. So how do you jump from there to something that’s missing in Lisa McPherson’s folder and assume that there was an auditor with her with some end cycle directive?

THE WITNESS: Well, with — and we’ll get to that too.

But in relationship to Lisa McPherson, it is — it is my belief that she was most assuredly on a program; that that program most assuredly was in her file folder at some point, along with other reports that are detailed — that are missing; and those — you know, for whatever reason, those things weren’t turned over or made available.

THE COURT: Let’s assume that — for the sake

0294

of argument, that what she was on was the introspection rundown, and that something went wrong, and she wasn’t taken to the hospital as quickly as she should have been, and she died. And let’s assume further that somehow or another somebody removed part of that from her folder. That would have nothing to do with an end cycle, an auditor being there or anything of the sort. So I guess my main question is, what caused you to leap to the conclusion that the fact that the documents were missing?

And there’s no question of that. So two and a half days, I guess of documents are missing —

THE WITNESS: Right.

THE COURT: — toward the end of this — I’ll call it an introspection rundown.

You know, how do you know that that just didn’t have something to do with the fact that either somebody, A, forgot to put them in a folder or, B, if they were destroyed it was because somebody was negligent and they didn’t want somebody to see that? How do you get to the fact that somebody ordered her death and said, “End cycle,” or whatever it is that’s in the complaint?

THE WITNESS: Okay. This is exactly how I came

0295

to the conclusion —

THE COURT: Do you mind, Mr. Dandar?

MR. DANDAR: No, no.

THE COURT: That’s what we need to get to.

MR. DANDAR: Let’s get — let’s get to it.

THE WITNESS: Let’s get to it.

THE COURT: Get to it.

How did you conclude — how did you — I presume that you read the PC folders.

THE WITNESS: Right.

THE COURT: You answered Mr. Dandar’s questions. He asked you as his consultant, “Can you tell me what you think –”

THE WITNESS: “What happened?”

THE COURT: This is what you told him, and he put it in the complaint.

THE WITNESS: Correct.

THE COURT: All right. So now you got to tell me how you came to the conclusion you came to and what it is you told Mr. Dandar —

THE WITNESS: I’ll —

THE COURT: — okay?

THE WITNESS: — tell you exactly —

THE COURT: All right.

THE WITNESS: — how I did that, your Honor.

0296

THE COURT: All right.

THE WITNESS: From reading Lisa McPherson’s preclear folders, reading her ethics folders, seeing, kind of like, what’s missing — and it didn’t make sense for these things to be out of the preclear folder unless they were damaging to the church.

And again, I’ve been in a position where, you know, it was considered documents within a preclear folder were damaging to Scientology so they’re removed for Scientology’s sake.

But even a step back from that, your Honor, you get a person —

And it clearly states on the introspection rundown that once you are assigned to the introspection rundown, you are not allowed to leave introspection rundown until the case supervisor tells you you can leave. You are literally incarcerated until you are told you can leave.

THE COURT: Well, you know, that may be your interpretation. If somebody is — is what I would consider schizophrenic or very, very mentally disturbed, you really wouldn’t want them leaving because they might be — you know —

You handled an introspection rundown, right?

0297

THE WITNESS: Sure. Yes. I’ve done them.

THE COURT: And I’ve read what — what you and Ms. Brooks said about this woman. So apparently there was a time when she was in a situation where you wouldn’t have wanted her just stumbling around the street, right?

THE WITNESS: Right. Correct.

But you know, be that as it may, again, the person is not allowed to leave until they have permission to leave.

THE COURT: Okay.

THE WITNESS: So whether or not this person experienced some lucid moment or had a lucid hour and said, “Hey, look, I just want to do something else,” they still could not leave, okay? Now, what happens in that situation, from introspection rundowns that I’ve done — that I have done, participated in myself, and myself seeing and being incarcerated — what happens?

When you’re in a situation you don’t want to be, you say — you tell them, “Look, I don’t want to be here.” “Well, too bad. You have to be here.” “No. It’s not too bad. Now, really, guys, it’s over. I just want to go.” “No. You’re not going.”

Well, what happens? It escalates. The person

0298

says, “Hey, look, if you don’t let me out of here, I’m going to call the police. If you don’t call — let me out of here, I’m going to find a way to contact law enforcement. I’m going to find a way to get out of here. You better let me out of here.” And it escalates like that. And this has happened. And the reason why I say what happened to Lisa happened to Lisa — the reason why I gave that opinion is, number one, what is missing and what would have been there, which happens as a natural consequence, is, when you’re held against your will and people don’t want to let you go, then you complain. You threaten. She threatened. Oh, no.

Now it becomes a huge problem, if Lisa is being held against her will and she wants to leave, and she’s already made it clear, through what I’ve written here, that Scientology procedures are — is not making her spiritually more able; it’s not furthering her ideas of — of, kind of, what she had in mind.

So it is my opinion that Lisa started threatening Scientology at some point. She started threatening to go to the police. She may have threatened that, “I’m going to sue you if you don’t let me go. I’m going to do whatever.” You know,

0299

push the buttons in — in the hope to get out. They didn’t let her out.

I think that Lisa became very sick. I think Lisa did change her mind about what her plans were once she left. And when — and in that horrible situation, for Scientology, it would have been a nightmare for that girl to leave that hospital — to leave Scientology and go to the hospital.

Now, this is, you know, is my opinion and I state it as such.

For them — for her to say, “Look, they locked me in there.” You know, “This happened, that happened.” And —

THE COURT: Well —

THE WITNESS: — boom —

THE COURT: — there was nothing that indicates she wanted to go to the hospital. She left — I mean, she left the hospital because she wanted to leave the hospital, so —

THE WITNESS: Yeah.

THE COURT: — if she’d left, presumably she was going to go home.

THE WITNESS: Right.

Well, you know — of course, we know that that didn’t happen.

0300

THE COURT: Well, I know. But you’re saying what a horrible nightmare it would have been. The truth of the matter is, if she had been well and had gone home to her mother and sister and what have you, there would have been no nightmare at all —

THE WITNESS: That’s —

THE COURT: — for Scientology.

THE WITNESS: — right. That’s right. It would have been fine.

But now we’re in a different situation, you see, because now she’s being held against her will. You know, you see — you see in the reports how she becomes violent.

You know, again, in my experience, as a natural progression, when you are being held and you want to be in one place and somebody’s making you stay in one place, it starts to escalate.

THE COURT: Let me ask you a question, Mr. Prince: Have you ever been in a mental hospital?

THE WITNESS: Yes.

THE COURT: So you know how, in a mental hospital, when somebody is really — I’m going to use the term “crazy,” okay? Very sick. Somebody who’s psychologically extremely disturbed.

0301

THE WITNESS: Right.

THE COURT: Well, they want to leave too, right? That’s why they have them behind locked doors and bars and all that sort of stuff, is because they want to leave.

THE WITNESS: Mm-hmm.

THE COURT: And they’re not fit to leave mentally. They would be a danger to themselves, perhaps others, to let them out in the street. So when somebody’s in a mental hospital, very sick, and they say they want to go, well, they’re not allowed to leave.

THE WITNESS: Well, you know — you know — now, let’s take a look at this.

You’re talking about a person that’s sick, right?

THE COURT: Right.

THE WITNESS: That means a medical diagnosis, right?

There is no medical diagnosis here. There is no authority that says this person was crazy. This is just the opinion, based on the beliefs of Scientology, that they gave her this label of being crazy, okay? That’s way different than being in a mental institution where you’ve been diagnosed, or

0302

you’ve committed some crime, or you’ve harmed somebody, or something has caused to you go to an institution —

THE COURT: Well —

THE WITNESS: — which —

THE COURT: — schizophrenic.

THE WITNESS: — is certainly not the case with Lisa.

THE COURT: I mean, you can be in a mental hospital and not have harmed anybody and not be a danger — I mean, you’re talking about a Baker Act, where you’re — you’re kept against your will involuntarily.

But I mean, there are sick people in a hospital, just because they’re sick and they’re crazy and they — and they just aren’t fit to be on the street, right?

THE WITNESS: Right. Right. In a hospital.

There’s a difference between being in a hospital and being locked in a room with people who don’t understand really what’s going on and are just following orders.

THE COURT: Well, they may not.

But the truth of the matter is, that’s the belief of the Church of Scientology. You were a part of it and you participated in it, right?

0303

THE WITNESS: Correct.

THE COURT: You participated in an introspection rundown with somebody who was in the same boat that Lisa McPherson was in; at least in — at times, right?

THE WITNESS: Correct.

THE COURT: Nobody ordered that this lady would end cycle that you were watching, right?

THE WITNESS: Correct.

THE COURT: Well, then, how — you see, I’m just — I’m trying to help you, here, to see if there’s any basis for this.

THE WITNESS: Okay.

THE COURT: How is it that you’ve come to this conclusion, other than just it’s — it’s one of many, many thoughts that you might have as to what might have happened?

THE WITNESS: Because based on Scientology’s own policy, the first thing you do when a person starts demonstrating these symptoms is take them to a medical doctor to ensure that the reason why these symptoms are occurring aren’t based upon some medical reason, okay?

THE COURT: Okay.

THE WITNESS: Now, this is in their own

0304

documents.

Now, why would they not do that? Why would they not do that? If their documents say if a person is demonstrably mentally ill, the first thing you do is, even in introspection rundown, is take them to the hospital.

Well, why wouldn’t you do that?

THE COURT: Because maybe —

THE WITNESS: The reason why you wouldn’t do it is because the person in — they were also telling you, “I’m going to sue you. I’m going to tell about this. I’m threatening you. You got to let me out of here.”

No, you’re not going to the hospital. Because once they go to the hospital, because they are lost.

THE COURT: Okay. But that —

THE WITNESS: They’re not going to go back to Scientology.

THE COURT: Let’s assume — Slow down.

Let’s assume, for the sake of your testimony and for the sake of your beliefs and what you told Mr. Dandar, that you are right. That Lisa was saying, “I want to leave,” and they were saying, “No, you can’t leave,” and she said, “I want to

0305

leave.” And therefore — and therefore, they didn’t take her to a medical doctor. Of course, she just came from a medical doctor where she had been seen and had been released. So that could have been one of the reasons.

However, how do you jump from that conclusion to the conclusion that somebody said, “Let her die,” or — not only, “Let her die,” but proceed to assist this along in some fashion; bring an auditor in and cause her to die?

THE WITNESS: Okay. I’ll explain to you.

THE COURT: Okay.

THE WITNESS: By their own documents, people that get into this state of mind, all of them do not live. Search and Discovery, it says some don’t make it —

THE COURT: Right.

THE WITNESS: — okay?

You have a person here who, in my opinion, based on what I’ve seen, and even the missing evidence — because you know, if everything — again, like the one that I did, okay, well, this girl didn’t want to leave. This little girl didn’t
really know what was going on.

THE COURT: Which little girl we talking about

0306

now?

THE WITNESS: Terese, the one —

THE COURT: The one that you watched.

THE WITNESS: Yeah.

THE COURT: Okay.

THE WITNESS: She didn’t know. She —

THE COURT: When you say that, you meant she was really out of it mentally.

THE WITNESS: Completely.

THE COURT: Crazy.

THE WITNESS: Crazy. Barking like a dog, you know, doing —

THE COURT: Right.

THE WITNESS: — wild things.

When she started to come out of it, she certainly wanted to leave. She was certainly demanding to leave. But she was not allowed to leave until she had signed releases that released the Church of Scientology and related  organizations with any liability concerning her condition.

So in other words, she signed away, you know, “what happened to me is an anomaly. It had nothing to do with my studies and training or experience in Scientology, and they have no liability for me getting into this.” This is something that’s

0307

demanded of a person who finishes that rundown, to release any liability.

Here you have a person that isn’t in that position. And it is my belief, because there’s so many —

THE COURT: What position is she in? Tell me how her position differs from —

She’s still crazy.

THE WITNESS: Well — hold on. Because when she was released, they didn’t say she was crazy, from the hospital. That was not a diagnosis that Lisa was given when she left Morton Plant Hospital.

THE COURT: But you have to admit, from the — from the — from the reports that were in there from some of the workers, she started staring at a lightbulb; she started talking about she was L. Ron Hubbard, and she started acting crazy.

THE WITNESS: Well, that’s when they brought her in there.

THE COURT: Right. And that’s when she began the introspection rundown perhaps, right?

THE WITNESS: Well, come on, Judge. Let’s back up on this. Because you just said medically she was not diagnosed as being insane. The — the medical

0308

records didn’t say, “Hey, this is a person we got to Baker Act. This is a person that’s mentally ill.”  Didn’t say that, okay? So I think it’s wrong to assume that. And the reason why I think it’s wrong —

THE COURT: Well, what —

THE WITNESS: — to assume that —

THE COURT: — was — let me ask you, Mr. Prince, what’s the difference in the lady that you took care of and how she started barking like a dog — and you say she was crazy —

THE WITNESS: Mm-hmm.

THE COURT: — and what you read in the reports of Lisa McPherson, where she was crawling on the floor, humping the floor, carrying on like a crazy person?

THE WITNESS: After she had been in their — incarcerated. And I think by the fact of incarceration, it tipped her over the edge.

THE COURT: Well, you think that same thing happened with the lady you were watching?

THE WITNESS: Huh-uh. No. I mean, she was literally sitting in a chair, you know, fine, one moment, and then the next moment somebody went over to see what she was doing and she peed herself

0309

and — you know, it was a huge difference.

THE COURT: Could that have been like Lisa McPherson, who was all right, released from the hospital, went to the Ft. Harrison, and then just kind of went like this, and all of a sudden she was crazy?

THE WITNESS: Well, you know, you could —

THE COURT: Could it be?

THE WITNESS: Not necessarily. And I’ll tell you why.

Because by the fact of incarceration, it already pushes a person further than, maybe, where they were. I mean, she’s locked in a little room.

No one’s talking to her. She’s feeling horrible. She’s already wanting to go home —

THE COURT: She’s a Scientologist. That’s part of the procedure.

THE WITNESS: Yeah.

THE COURT: You were a Scientologist. That’s part of the procedure.

THE WITNESS: No, no, no, no. See, that’s another myth, now. Because you’re a Scientologist it does not mean that one day you are going to know, when they lock you in a room, because you studied it, this is what they — what’s going to happen to

0310

people that do this. There is no place, no — absolutely no place that gives clear instructions on what happens to a person should they experience this and Scientology decides to take them in and put them through this routine.

You find that out after the fact, after the fact it’s been determined that you have a mental problem.

You see —

THE COURT: Well, let me ask you a question: If the church doesn’t believe in psychiatrists and psychologists and they don’t believe in mental health treatment in the — in the traditional form —

THE WITNESS: Mm-hmm.

THE COURT: Everybody knows that.

THE WITNESS: Correct.

THE COURT: That’s a very basic tenet of the church.

THE WITNESS: Right.

THE COURT: Okay. It would be like a Christian Scientist. They would know that they don’t believe in medical treatment, at least in part. So if you’re a member of the Christian Scientists, you know that you believe that.

THE WITNESS: Right.

0311

THE COURT: Okay. Well, there has to be some folks that become mentally deranged, who are Scientologists, so they know that there’s some other treatment, just like you would know, if you were in the — in the Christian Scientists, if there’s a belief of laying on of hands and God will heal you — So they’ve got to be told there’s some substitute for somebody —

THE WITNESS: Your Honor —

THE COURT: — that has a mental lapse.

THE WITNESS: Your Honor, they’re not. They are not told that. It’s just simply not true. You don’t find it out until after the fact. There’s no course —

Say I’m a public member of Scientology, wants to do auditor training up to class 4. They go and they train and they — they get their certificates and stuff like that. There is no class that says, “Okay. If this happens to you, this is the exact procedure.”

That was something that was developed during the time when the introspection first came out. But then this is something that moved totally off and away from anything that public people could see or

0312

even staff would know. They were isolated and hidden from view.

And then normally, the person doesn’t do any more Scientology after introspection rundown. And I know several cases after that — of that.

Because they make you sign waivers and releases which say, “The church did not cause your condition. The church did not contribute to your condition. The church is not liable or responsible for what happened to you.”

And you agree to that, and you sign it, and then you’re on your way.

THE COURT: Okay. Well, like the lady did in your case.

THE WITNESS: Correct.

THE COURT: But she is a Scientologist.

THE WITNESS: Yes.

THE COURT: Okay. So — so — Okay. I understand what you’re saying; that — that perhaps Lisa McPherson didn’t know what was going to happen to her, is what you’re basically saying.

THE WITNESS: None of them do.

THE COURT: Okay. Now — okay. I’ll take your word for that for the sake of your testimony. How do you get from that — okay. Let’s assume

0313

there was some gross negligence going on here. She wanted to leave.

THE WITNESS: You —

THE COURT: Which there’s already been a judge that says there’s none of this. But let’s assume that she says, “I want to leave.” They say, “You’re not going to leave.” “I want to leave.” “You’re not going to leave.”

One of two things happened to Lisa McPherson, based on her doctors and her experts and the experts for the church: Either she became severely dehydrated and that caused this embolism to break loose and it damaged her lungs and she became unable to breath, I guess, and she died; or there was no real dehydration connected with it, except perhaps slight, and the same embolism broke loose and lodged in her lung in some fashion and she died.

THE WITNESS: Right.

THE COURT: So it’s one or the other. One or the other things happened to her, medically —

THE WITNESS: Right.

THE COURT: — okay?

THE WITNESS: Right.

THE COURT: Now — so that’s a given, okay?

THE WITNESS: Right.

0314

THE COURT: So how do you leap from the fact, in your mind, she wanted to leave and they said, “No,” to the fact that she died from one of those causes, through anything other than either no negligence, slight negligence, or really gross, flagrant negligence? How do you jump from point A to point B by saying that David Miscavige said, “Kill this woman”?

THE WITNESS: Or, “Let her die.”

THE COURT: Or, “Let her die”?

THE WITNESS: Okay. Now, you got to listen.

I’m going to explain this to you, okay?

THE COURT: Okay. I’m listening.

THE WITNESS: Now, again by their own policy, this woman first should have been examined by a medical doctor to see if the insanity itself was coming as a result of some medical condition.

THE COURT: Okay.

THE WITNESS: That was not determined when she went to the hospital because it was determined she was not insane.

So if she did get worse when she was at the Ft. Harrison, then the next thing that they should have done was to take her to get her medically examined to see if there was a medical reason for this

0315

behavior.

THE COURT: And you did that in your case? In the case where you handled the introspection rundown?

THE WITNESS: No.

Oh, yeah. They had a doctor come out. Sure. They had a doctor come out. Dr. Gene Dink came out to be with her. He examined her.

THE COURT: Was this a real doctor?

THE WITNESS: Yes.

THE COURT: I mean — by that I mean a licensed doctor? ‘Cause they had doctors with Lisa McPherson too, except they weren’t —

THE WITNESS: This was —

THE COURT: — licensed.

THE WITNESS: — L. Ron Hubbard’s doctor, your Honor.

THE COURT: Okay. Well, was this a licensed doctor?

THE WITNESS: Yes. Dr. Gene Dink, Los Angeles, California.

THE COURT: Okay.

THE WITNESS: Worked with the one that we have.

THE COURT: So — so as I recall, Ms. Arundo (sic) — and I may be wrong on this, but as I recall

0316

she was a doctor licensed somewhere else. There was another doctor, one — the head of the medical liaison, who had been a doctor.

MR. DANDAR: And lost her license.

THE COURT: And lost her license.

MR. DANDAR: Arrunada’s from Mexico and was never licensed.

THE COURT: Okay. But Ms. — but what’s Ms. — please give me the name.

MR. DANDAR: Johnson.

THE COURT: Ms. Johnson was a physician who had lost her license, who presumably was in charge. But — okay. You say they should have taken her to a doctor.

THE WITNESS: Yeah. They —

THE COURT: Or had a doctor come in.

THE WITNESS: Right.

THE COURT: Like they did in your case.

THE WITNESS: Right.

THE COURT: Your case, meaning the case where you were directly involved.

THE WITNESS: Correct.

THE COURT: And they didn’t do that. Okay. What else?

THE WITNESS: Well, we have to wonder why they

0317

didn’t do that.

Now, I hate to be — your Honor, you know, irrespective of what the defendants believe in this case, it brings me no great joy to — to malign them or say horrible things about them.

But because I’ve been there and because I’ve seen what happens and because I’ve seen what they do, it is my belief because when they brought this girl back from the hospital, she was not insane. She wasn’t diagnosed as that. She went insane there. She wanted to leave. She said, “I want to go.” They said, “No, you can’t go. You got a problem. We’re diagnosing you. Forget what the doctor said. We’re going to do it.”

THE COURT: Okay.

THE WITNESS: She began to struggle. She began to fight. At that point, it becomes a OSA matter. It was already an OSA matter.

THE COURT: I’m sorry. A what matter?

THE WITNESS: O-S-A. OSA. Office of —

THE COURT: OSA.

THE WITNESS: — Special Affairs matter.

THE COURT: Okay.

THE WITNESS: For several reasons now: One, because she apparently left the hotel,

0318

drove around and had a minor accident, took her clothes off, told people that she needed help.

Okay. That in and of itself was something that drew attention to Scientology that was non-optimum. And in Scientology, that is called a flap. An unpredicted activity that now involves Scientology’s reputation somehow.

Now, here is a person, Lisa McPherson, who just two months earlier attested to the state of clear. She stood in front of every Scientologist at the mecca of technical perfection, their highest level, their highest office of — of tech, and told everyone that, “I no longer have a reactive mind. I no longer have,” you know, “have problems with the past that now come up. I’m totally free from the past and I’m ready to move on.”

In other words, she was what they call in Scientologist (sic) — not a Homo sapien, but they call it a Homo novis. Homo novis in Scientology is a step above Homo sapiens.

So now this person is literally a demigod two months ago. Now she’s screaming in a room, insane, crazy.

This is a problem. This is a problem that this woman took her clothes off, walking down the street, and — and OSA had to get involved and, you know, they rushed down there, “Oh, my God.” They bring

0319

her back. She’s not diagnosed as being crazy. They just give her — she wants to get some help. She’s got something on her mind. Okay. So she comes back.

It is my contention that she wanted to leave, just like she had been saying. And they said, “No.” And they put her on the introspection rundown and she went over the edge and she got crazy. Well, before that she made many threats.

Now, it is Scientology’s belief that once you start these processes — once you start any process  in Scientology, you take it to the end. It’s called processing. The way out is the way through. What turns it on or turn it off. Get the preclear through it. Whatever. In other words, keep that auditing going until the end result happens.

THE COURT: Or get the person in the introspection rundown fit for auditing. That is part of the preliminary process.

THE WITNESS: Well, the person is fit for auditing after they’ve had one eight-hour period of sleep. Okay? You got — you know, you got that step 0, step 00.

THE COURT: Right.

THE WITNESS: The first thing that normally

0320

happens with a person that gets into that state of mind, they don’t sleep for days, they can’t sleep, they’re up — a part of auditing in Scientology is, you have to have had sufficient rest to get audited.

So —

And again, in the instance where I did introspection rundown with the person, the first time that woman — after she was given Valium or whatever they gave her to put her to sleep, the first time she had an 8-hour period of time to sleep —

(The reporter interrupted.)

THE WITNESS: I’m sorry.

MR. DANDAR: Slow down.

THE REPORTER: After they gave her —

THE WITNESS: — or chloral hydrate or whatever they give them to go to sleep, the first time eight hours pass and that person wakes up, the auditor is there immediately to start.

THE COURT: I think they tried to bring an auditor into Lisa McPherson and she wasn’t capable.

THE WITNESS: Well, I heard —

THE COURT: I mean, I think I remember that.

THE WITNESS: — I heard the story that, you know, she licked the cans and — you know, that

0321

means nothing.

An auditor is trained — I don’t care if you take the cans and throw them across the room. An auditor is trained to stand up, take those cans, put them back in the person’s hands and get them to do what you want them to do. It’s called model session. You know, that’s part of the same —

THE REPORTER: Slow down, please.

THE WITNESS: — auditor series you have. Model session. Which talks about how to conduct a session.

THE COURT: That’s tough to do if the person is still in a psychological state, that’s crazy.

THE WITNESS: Well, you know — and you’re assuming that that’s the case. But the doctor didn’t assume that when she was let out.

THE COURT: Well, I’m assuming that’s the case because of the reports I read.

THE WITNESS: You know — well, you know, after —

THE COURT: Just like I’m assuming the lady that you watched after, when she barked like a dog and carried on, was crazy; like Stacy Brooks said she was crazy and like I think you said she was crazy.

0322

THE WITNESS: Right.

THE COURT: Crazy in the sense that I know — would think someone was crazy; not medically.

THE WITNESS: A danger to themselves or other people.

THE COURT: Not somebody you would want out on the street.

THE WITNESS: Right.

Okay. So again, she is in a situation now where she’s drawn into the local public attention. They’ve been promised by the doctors that she’ll be okay. Turn her over to Judy Fontana. They don’t turn her over to Judy. Because I think these things all mean in some way she was not agreeing with what was happening to her. And because she wasn’t agreeing and she wanted to leave, it got wild. It intensified.

Now, Scientology’s belief is, you know —

THE COURT: I think I can go along with you there. I mean, I think that there’s enough in that folder to realize she was not thinking clearly. She may have wanted to leave. You know, the lady you took care of may have wanted to leave. I mean, they — they act irrational, right?

THE WITNESS: Right.

0323

THE COURT: And the idea is they can’t leave.

THE WITNESS: Right.

THE COURT: Okay. So let’s say I accept that —

THE WITNESS: Right.

THE COURT: — okay? She wants to leave, they’re saying, “No, you’re not able to leave yet.”

She’s getting more and more upset.

THE WITNESS: Right.

THE COURT: She wants to leave.

How do we know they’re still not trying the introspection rundown to make her well?

THE WITNESS: I think —

THE COURT: What —

THE WITNESS: — they were doing it.

THE COURT: Sure.

THE WITNESS: I think —

THE COURT: So —

THE WITNESS: — they were doing it. But I think that she had decided she had had enough. You see — and the reason why I say that is because, if you look at this affidavit, she keeps telling them, “I had enough. I don’t want any more auditing. This is aggravating my condition. It’s making me worse.”

This is what she’s saying in her

0324

own words, the only thing she was able to say before she died. And in which whole thing, if you read this line by line in the preclear folder, “This is making me worse. I’m not getting better.”

So what do they do? Give her more auditing. Well, she doesn’t want that.

THE COURT: I will say, for the sake of this hearing, that I — I can accept that.

THE WITNESS: So because she doesn’t want it, and because she has no way to leave, because she’s actually under guard — I mean, we have a statement by Paul Kellerhals where he actually jumps on top of her and holds her down. You know, you have people not speaking to a person, keeping her in a room — I mean, that, to me, in retrospect, after my Scientology experience, is something that would make a person, if they weren’t over the edge, would certainly push them over the edge.

THE COURT: But you did that when you took care of the lady you took care of.

THE WITNESS: No. I talked to her. I did not not talk to her.

THE COURT: Was that — were you breaking the rules?

THE WITNESS: Yes. I was breaking the rules.

0325

THE COURT: Well, you don’t know that somebody else might not have broken the rules.

THE WITNESS: Well, I don’t know that either.

THE COURT: All right. So let’s take — we really need to break for lunch.

But let’s assume for the sake of argument that you are correct. She wants to leave. They say, “No.” She wants to leave, they say, “No.” And let’s assume that they’re saying “no” because they believe that she’s not finished the introspection rundown, and they’re going to get her finished.

Just like —

THE WITNESS: Yeah. And they do believe that.

Right.

THE COURT: All right. So now, one of two things happens at some point in time: Either she’s not getting enough water, right; and so she’s not getting enough water or whatever, and they should have known better, and they should have given her more water, and she reaches this miserable state and dies.

Or she is getting enough water and a pulmonary — you know, an embolus in her leg breaks loose, goes to her lungs and kills her. One of those two things happened at the end of this. And it was — it was from the embolism, right?

0326

And you wouldn’t have known that. They wouldn’t have known that. There wasn’t a worker there that would have known that. Nobody. These are the silent — silent killers —

THE WITNESS: Right.

THE COURT: — okay?

So one of those two things happened, and that’s a fact.

How do you reach the conclusion that anywhere along the line it was, “We’re going to keep her here until the embolism we don’t even know about breaks loose”?

THE WITNESS: Well, you know, that’s ridiculous, your Honor.

THE COURT: Of course it is.

THE WITNESS: Let me — you got to let me finish —

THE COURT: Okay.

THE WITNESS: — the whole thing.

THE COURT: I’m going to do that, but we’re going to take a lunch break first —

THE WITNESS: Okay.

THE COURT: — all right?

All right. It’s 12:20. Let’s be in recess until 1:30.

0327

(A recess was taken at 12:23 p.m.)

0328

REPORTER’S CERTIFICATE

STATE OF FLORIDA )
COUNTY OF PINELLAS )

I, Donna M. Kanabay, RMR, CRR, 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.

WITNESS my hand and official seal this 8th day of July, 2002.

______________________________
DONNA M. KANABAY, RMR, CRR

Notes

  1. Document source: http://www.xenu-directory.net/mirrors/www.whyaretheydead.net/lisa_mcpherson/bob/A-007-070802-Prince-V2.html
  2. Caroline Letkeman; Nancy Many.
  3. Judge Marianna R. Pfaelzer
  4. Elliot J. Abelson
  5. Should be “PTS/SP.” Key documents: http://www.suppressiveperson.org/sp/documents/key-documents-sp-doctrine

Second in command of Scientology tells all, Part 1 (October 2, 1998)

Second in command of Scientology tells all, Part 11

Introduction by FACTNet

This is one part of a series of articles being released by Jesse Prince . Jesse Prince was second in command of all of Scientology. He has shown great courage and has put himself at considerable personal risk to tell the world about the real everyday criminal and immoral activities of Scientology.

FACTNet has helped Jessie through our Victim Assistance Fund because we knew how much publicizing this information would help others who were and are being victimized by Scientology’s criminal activities.

FACTNet now needs your immediate help to get Jesse’s articles distributed as widely as possible. FACTNet believes — and we think you will also believe, especially after reviewing Jesse’s series of articles — that there is a real growing danger to individuals involved with Scientology, particularly to staff members.

FACTNet believes that Scientology is at a dangerous pressure point as more information comes out revealing its actual activities. The world has learned horrible lessons when cults are trapped at pressure points from tragedies such as Jonestown, Heaven’s Gate, Waco, the Swiss Solar Temple, and Aum Shin Rikyo.

Because of Scientology’s current crisis state and the new revelations about its criminal activities, FACTNet is issuing a worldwide alert to all individuals who have friends of family in Scientology, particularly if they are on staff. Do everything you can to legally get them away from this group as fast as possible.

FACTNet recommends among other things getting Jesse Prince ‘s series of articles to everyone currently in Scientology. Once they have read them, even the most hardened Scientologists will have powerful doubts about how they have been deceived.

In addition to distributing these articles to Scientology’s current members, we also ask that you distribute them to media all over the world and to your local and national governments.

Only information can solve the problem dangerous criminal cults like Scientology present. If the Jesse Prince articles are widely circulated, we will help avert another horrific cult tragedy.

End of Introduction

 

Part I

October 2, 1998
By Jesse Prince

During September 1982, through spring of 1987, I attended biweekly meetings at Author Services, Inc. (ASI), which at the time was located in the 6700 block of Sunset Blvd. in Los Angeles, CA.

From late 1982 until the spring of 1983 I held an executive position in the Religious Technology Center (RTC) titled Inspector General Cramming Officer. During the spring of 1983 I was promoted to Inspector General External and Treasurer on the board of directors of the Religious Technology Center. There were two other board members; Vicki Aznaran, Inspector General and President, and Warren Mc Shane, executive over legal matters concerning RTC, was a member. David Micavage, Norman Starkey and Lyman Spurlock were the trustees of RTC. It was during this time that I learned the true nature of Scientology management and how it ran its affairs.

The meetings I attended at ASI were always called and run by David Miscavige. It was here that I learned that David Miscavige was a managing agent of the various Scientology corporations, including but not limited to ASI, RTC and Church of Scientology International (CSI). Each senior executive of RTC, CSI and ASI met once or twice a week to give a report concerning each of the above corporations. This in fact was the inner circle of Scientology’s elite and as a result of my position I was involved in and received communications concerning Scientology’s most secret operations.

During my time as an executive and senior executive in RTC, David Miscavige was the decision maker concerning all legal suits filed by any of Scientology’s corporations. Miscavige had complete authority concerning all litigation within Scientology, and he made the final decisions as to how each case would be litigated as well as which lawyers would be used in each and every case. Miscavige had two Scientology staff, Marty Rathbun and Lyman Spurlock, who assisted in Scientology litigation matters, but Miscavige always made the final decisions. CSI majorly operated on orders from LRH, which were called advices to avoid legal problems for himself and Scientology, since he supposedly had not managed any of the corporations of Scientology since 1966, when he had officially resigned as Executive Director.

ASI served as LRH’s literary agency, but it was really a clearing house for his orders into the various Scientology corporations and organizations, which included but was not limited to RTC, CSI, CSC, Flag Land Base, CST and the Office of Special Affairs (formerly the Guardian’s Office). Miscavige was the person responsible for ensuring the execution of LRH orders in these various corporations, until LRH’s death in 1986. ASI and some of its staff members exercised complete financial authority over other church entities. Fran Harris, a staff member of ASI, was responsible for the gross income of the organization.

ASI received its operating expenses from commissions it received for collection of royalties owed to LRH based on moneys collected from LRH book outlets. Some time ago, LRH wrote a policy letter entitled “Minimum Book Stocks” which in effect placed a minimum on the amount of books each Scientology org had to have. Bridge Publications is the organization responsible for enforcing the minimum book stocks policy.

More often than not, on orders from Miscavige to get the stats up, Fran Harris would bypass Bridge Publications and go direct to org finance personnel and demand that the orgs buy books from BPI so that ASI would get its weekly commissions. Fran enforced her demands by using lower conditions, ethics hearings, comm evs and just plain intimidation to make the nonprofit scientology orgs pay money to BPI, often before the org had even had a chance to feed and clothe its staff. BPI never saw much of this money itself, as it was considered that BPI owed a debt to ASI going back to before ASI was ever incorporated. This action, which went on every week, was a known criminal act by all concerned, as not only did it violate Scientology’s own policy of corporate integrity, it also violated the laws of the land.

ASI is a for-profit corporation and paid its staff minimum wage plus a bonus based on royalties collected. Every week ASI had to get more and more money in order to keep its stats up to receive bonuses. ASI staff were in fact Sea Org members that were paid very well when you consider the average Sea Org member was paid $24.00 per week. It was considered a privilege to be on staff at ASI and the staff were encouraged not to discuss with other Sea Org members what they were paid weekly in order not to create a rift among Sea Org members.

In 1984 David Miscavige received word there was an IRS criminal investigation pending with the threat of a raid in Los Angeles. Fran Harris was flown out of the country and sent to Copenhagen, Denmark, to avoid possible interrogation by IRS officials. This was just the beginning of the “clean up” most senior executives executed within various Scientology corporations. One morning I awoke to find my senior, Vicki Aznaran, her husband Rick Aznaran, who was head of all security for Scientology, and Foster Tompkins, executive over INCOMM, removing evidence from hard disk drives that proved LRH was in fact the managing agent of Scientology as well as other sensitive information. Vicki and the others had been up most of the night purging computer files and creating back-up disks to be stored at confidential storage sights.

At this time I was ordered to verify that other corporations had purged their files of LRH “advices.” The corporations concerned were RTC, CSI and CSC. I did in fact verify that no evidence of LRH advices existed. This was accomplished by gathering up all hard copy advices and getting them mulched at a paper treatment plant located near Riverside, CA. Back-up copies of these advices were placed in secret unknown storage facilities by head of security, Rick Aznaran. The only people who knew these locations were Rick, the security chief, whose name was Jackson, DM and Norman Starkey.

From 1982 through 1986, LRH would use a dictaphone to dictate his orders to the various Scientology corporations. The tapes from the dictation would be delivered by LRH’s top aides Pat or Annie Broeker to the Scientology location at Gilman Hot Springs. At this location a special unit, headed by a staff member named Susie Bennick, would transcribe the tapes and issue hard copy dispatches to various executives and staff of ASI, RTC, CSI, CST and CSC. Often, these dispatches had certain time deadlines for compliance as mandated by LRH. I’ve seen as many as 150 orders dictated by LRH in one run. Often the staff who had orders issued to them were not allowed to sleep until they complied to the LRH order issued to them. David Miscavige oversaw the transcribing operation and enforced compliance to LRH orders by staff in all Scientology corporations.

Scientology Legal Procedures

During my tenure as an executive and senior executive in RTC, I was taught how to aggressively go about destroying an enemy or critic of Scientology. Enemies and critics of Scientology are considered to be suppressive persons or groups. In Scientology the suppressive element is basically dealt with in the same way: investigation, black operations, black propaganda and frivolous litigation. Scientology believes anyone labeled a suppressive is “fair game” and can be cheated, tricked, lied to and even physically harmed in order to “save” Scientology as mandated in policy by L Ron Hubbard. The following are specific instances I have either been a party to or observed being done to persons labeled “suppressive.”

David Mayo

David Mayo was once one of the top senior executives in Scientology. He worked directly with LRH on technical policies, he was LRH’s auditor, and even authored the “Ned for OTs” series when it was first issued. By the time I arrived in September 1982 at the secret management base located in Hemet, CA, David Mayo had fallen from grace. Upon my promotion to this secret location, the first duty I had was to security check (interrogate) Mayo endlessly. LRH had the idea that Mayo had been bought off by Scientology mission holders and was either a dupe or a plant. At this time Scientology was once again getting rid of its criminals. The executives of all management organizations had been removed and brought to Hemet to receive severe Scientology justice and ethics. Mayo was part of a group of 11 management executives being given a comm eve that went on for 3 months. Nearly all 11were eventually labeled suppressive persons and left Scientology.

Once David Mayo was off staff he decided to start his own church, the Advanced Ability Center (AAC), that was an alternative to Scientology and used many of the same techniques used by LRH. At this point David became the target for “fair game.” DM became infuriated and ordered Mayo’s new group to be destroyed using all means possible. Bob Mithoff, brother of Senior C/S Int Ray Mithoff, was placed by RTC in David Mayo’s new church as a plant to obtain financial and critical legal information to forward a planned attack on his group. Week after week Bob Mithoff provided financial information to RTC concerning Mayo’s new group. The fact of the matter is Mayo had drawn a good amount of people who were ex-Scientologists to his new church and was making $20,000 to $30,000 gross income every week. This was better than most Scientology Class 4 organizations. Mithoff stole a copy of the AAC’s mailing list and provided it to RTC. Within four months of its inception, AAC had a standard newsletter it mailed to its adherents.

With the stolen mailing list RTC operative Gary Klinger designed a similar newsletter that contained disparaging information concerning AAC to the same mailing list. This list was used by RTC to contact members of the AAC for the purpose of harassment and intimidation.

Mithoff also stole a copy of the NOTs materials that David Mayo had rewritten, and he provided it to RTC. At one point before her “suicide” Flo Barnett, David Miscavige’s mother-in-law, became a member of the AAC. More black operatives were sent into the AAC by RTC. Black operations included renting the office above Mayo’s AAC to electronically bug him. At one point private investigator Gene Ingram was hired to pose as an investigative reporter and Mayo was duped into believing he was participating in a TV program to promote his new group. Through Mithoff, it was learned that David Mayo planned to travel abroad to Europe. Through investigator Gene Igram, it was arranged to have Mayo stopped at customs as a suspected drug dealer, which did happen, and he was detained for hours based on false information by European customs officials. Gene Ingram received his instructions on these matters from Gary Klinger, an executive in RTC.

Ingram’s fee was paid by CSI through the office of John Peterson, who was retained as in-house counsel by CSC. As a note, John Peterson was not fully aware of why his office paid private investigator expenses to Bob Mithoff.

Prior to Mayo writing his own version of the NOTs materials it was learned through Mithoff that several other ex-Scientologists had copied and were planning to use Scientology HCO P/Ls and HCOBs. A former mission holder, Sarge Gerbode, had an ongoing project to copy via computer all HCOPLs and HCOBs and sell them to Mayo or trade them for Scientology OT materials. Through Mithoff we learned that Mayo and Gerbode had come to an agreement and Mayo’s new group was in fact more computerized than most Scientology facilities.

As part of the weekly ASI meetings, Vicki and I were confronted by David Miscavige concerning what we planned to do to put an end to Mayo and the AAC. The first option we suggested was to bring a copyright suit against the AAC. David Miscavige called in LRH Personal Secretary Pat Brice to get a briefing on the status of current church copyright filings. He was sorely disappointed when he found out that no one in the entirety of Scientology was responsible for copyright filings since the Guardian’s Office had been reorganized by him. He decided at that time to give Pat a project to file for copyright protection ofall Scientology bulletins and policies. This is the reason most Scientology copyright filings have a date starting in 1983 forward. The best option for the church to sue Mayo was through trade secrets and trademarks. Then-RTC lawyer Joe Yanny recommended a RICO complaint be drawn up, as evidence existed that David Mayo had formed agreements with other Scientology dissidents to exchange Scientology materials to strengthen the alternative movement which David Mayo was the leader of.

While all of this was going on Mayo and the AAC were successful in getting a Temporary Restraining Order against RTC and CSI because of the constant harassment and plants sent in. The specific incident which resulted in the TRO was in fact when Gary Klinger posed as a Jewish rabbi and went to a barbecue the AAC had one weekend and created havoc at the party. There is no difference between the black operations executed by the “Old GO” and the then new RTC. Because of the very nature of Scientology it will never change. L Ron Hubbard himself issued the marching orders for Scientology to become a criminal organization and people are trained to lie from the moment they walk in the door and take a Scientology course.

Almost immediately a person is taught how to use “ethics” to control another. Example: Hubbard Policy Letter 29 April, 1965 titled “Ethics Review” instructs a person how to effectively harass and attack another, a few quotes from the above mentioned P/L:

“Levels of Ethics Actions”

“Ethics actions in degree of severity are as follows:

  1. “Noticing something non-optimum without mentioning it but only inspecting it silently.”
  2. “Noticing something non-optimum and commenting on it to the person.”
  3. “Requesting information by ethics personnel.”
  4. “Requesting information and inferring there is a disciplinary potential in the situation.”
  5. “Talking to somebody about another derogatorily.”
  6. “Talking to the person derogatorily.”

The list get worse and worse. L Ron Hubbard was mentally ill for at least 4 years before he died that I know of through direct experience and association. When Gerry Armstrong , Omar Garrison, Vaughn Young and Stacy Young all at one time or another tried to write a biography of L Ron Hubbard based on his own records the records clearly showed he was mentally disturbed much earlier as well. As can be seen from the above-quoted HCOPL, a NAZI like dedication to the “group” is required which in fact turn people against one another in a spy-like fashion. In Scientology, people are dehumanized and in fact become members of a human ant family – you are only as good as you produce for the group. The concept of self is surrendered to the false idea that “Scientology” is much more important than individual life.

In the case of the RICO suit filed by RTC and CSI against the AAC, another type of Scientology “ethics” was applied. L Ron Hubbard believed certain words and catch phrases used together in a writing could have a psychological effect on the reader. The words and phrases are part of a confidential course called “R6 End Words” or “R6EW.” Hubbard ordered his “magic words” to be sewn into each and every legal motion and complaint submitted to any court. Hubbard said by doing this a judge would subconsciously become antagonistic to anyone trying to fight Scientology with the current justice system.

It is not necessary to be a brain surgeon to see this as pretty crazy, but because its so stupid the point can be lost. Hubbard thought he was superior to his culture and sought to make a mockery of the way everyday people live. In late 1952 Hubbard thought he had discovered something so powerful with Dianetics that he had to protect us all from his own invention. He wrote a journal called “Black Dianetics.” Here is how it starts: “Death, insanity, aberration, or merely a slavish obedience can be efficiently effected by the use of Black Dianetics. Further, adequate laws do not exist at this time to bar the use of these techniques. The law provides that only the individual so wronged can make complaint or swear out a warrant for offenders using these techniques.”

Well, now you know why there is an organization of people that have ruined lives and are a slave to the idea they are “saving the world.” Of course, the organization I am talking about is Scientology’s “Sea Org.” Sorry for digressing so about this — back to Mayo.

The RICO suit was filed against the AAC and black operations against it by RTC were at an all time high. There was a preliminary injunction hearing in the RICO case. The day before the hearing I was drilled by Earle Cooley and other church lawyers as to what I would say because I was an expert witness in this case. The fact of the matter is that I was drilled all day, all that night and up until the time I arrived in the courtroom as to what I would say as a witness. It’s funny how Sandy Rosen, Scientology’s replacement for Earle Cooley, asked me in my deposition in the FACTNet case in Denver several weeks ago if I had been coached at all by my lawyer before the deposition. He knows he works for criminals and that they are the ones who commit the crimes of which they accuse others.

RTC won its injunction against AAC, and Mayo was effectively shut down at that point.

It is shameful to have been a part of Scientology. I am grateful to be free of it physically and mentally. I promise to work just as hard exposing Scientology for what it is.

Respectfully Submitted,
Jesse Prince

Notes

Jesse Prince: Scientology’s Use of PC Folder Information (September 9, 1998)

Title: Scientology’s Use of PC Folder Information (reformatted)
Date: 9 Sep 1998 15:22:37 GMT

[This is article <6t64ln$nvd$1@news-2.news.gte.net> by Jesse Prince
(jesse.prince@gte.net) reformatted to fix the line length.]

What does it really mean in Scientology when they create a file folder
which contains a written account of confessions, fears, doubts, and
the secrets of the souls of its parishioners? What is written on
these file folders is “Confessional Formulary.” Let’s take a look at
this.

Confessional is not a brilliant new form of spiritual counseling that
L Ron Hubbard bestowed upon the world. On the contrary, confessional
as a way of spiritual healing has been practiced by religions
throughout the ages. The idea of a person talking to another in
confidence and “baring my soul,” “really saying how I feel,” or “Swear
you’ll never tell? OK, this is what I know” is the way we live in
peace with each other and help each other stay honest. Trust and
respect is an automatic consequence of such a relationship.

There is some form of confessional in most all religions that believe
in a god. The common denominator in these religions is that there is
an underlying faith in the goodness of the heart. I call this the Good
Faith principle.

In no other church that I know of besides “Scientology” are
confessions that are given in confidence ever written down. I dont
know of any other instance in which a written record is kept of
confessional counseling.

The only profession that does anything close to this is the field of
psychotherapy, in which I also include the fields of psychology and
psychiatry. Scientology, like psychology and psychiatry, keeps notes
of the therapy for use as a reminder in later sessions if need
be. Counselors in each of these fields psychology, psychiatry and
Scientology have an ethical duty never, under any circumstances, to
divulge information given in a counseling session. In fact, there are
laws in the United States that protect the patients privacy under
these circumstances, no matter the content of the information. As a
matter of fact, no police or government agency can demand information
given in confidence by a patient to a practitioner. These laws exist
to protect the privacy of each and every individual in the United
States.

Of course, there is always the oddball group or individual that will
violate this basic human right of confidentiality (Linda Tripp, David
Miscavige). For the most part, no matter what the reason may be for
the person who is the tattle-tale, he or she is looked upon with
disdain. No one in their right mind would continue to talk to someone
who would violate such a fundamental trust. That is the bottom
line. Sometimes good relationships are utterly destroyed after one
person violates the others right to privacy, especially when
information is given in confidence.

Now I want to give you some specific examples of how Scientology uses
information given in confidence by its parishioners to entrap and
control its members. Scientology is not a religion at all. Scientology
is a private intelligence group masquerading as a church.

In August of this year, 1998, I sat in deposition as a witness in a
case brought by Scientology against FACTNet. The cause of action has
to do with allegations of copyright violations by FACTNet against
Scientology.

Yet during this deposition, I found myself looking at over a foot of
information carefully culled and copied from my “confessional
formulary” files that are still in Scientologys possession. Of course,
they had culled my most intimate confessions which I had confessed in
confidence to them and which they then had me authenticate, mostly in
my own hand.

This is standard operating proceedure for Scientology to do to its
critics, because critics are “fair game.” To be fair game means that a
person can be tricked, cheated, decieved and lied to without any
punishment of the Scientologist who does these things.

So here is this lawyer named Sandy Rosen, the Scientology attorney who
is interrogating me in this deposition, asking me to authenticate
records which contain information given in confidence to what I
thought at the time was a religious institution for spiritual relief
and growth. Never in my wildest dreams during my early days in
Scientology did I think as I confessed this information that it would
ever fall into the hands of persons other than certified professionals
within my then-faith, Scientology. I really don’t think my trust was
outrageously naive or legally incorrect. Lets face it; there are
privacy laws in this country. As a matter of fact, as a minister in
Scientology I took an oath never to divulge information given in
confidence from any patient I counseled, no matter the reason.

I must say the experience of that deposition was painful and
degrading. I’m no angel. I was born a human man, not a god or a
demi-god. Just a man. I have made mistakes and have done things that I
am not proud of, as have many of us humans. For the things I have done
wrong, in the same measure I have worked to improve in areas where I
had problems in the past.

Yes, it is my past that they want to use against me. No, I have not
murdered anyone, nor was I ever a party or witness to murder. I broke
some other rules, and what they are bringing to light for the most
part are childhood confessions of 20 to 30 years ago. I have no
criminal record at all, but the deposition was psychological torture
for me all the same. Their intention was to hurt me and get me to back
off. I’d be lying if I said they didn’t hurt me with this cheap trick
of bringing out information from my pc folders, but in no way did it
back me down.

Also, I have to tell you the truth that I am no innocent in this. I
have been on the other side of this coin. I have contributed to and
helped in similar heinous acts against others. Unfortunately, it is
standard policy in Scientology to attack its enemies in any and every
way, and when I was in there, I did it too.

In 1979, I worked on a project with Sue Price, Bernadette OConnell and
Cirrus Sleven for many months, going through the counseling files of
every staff member in every organization located in the LA Scientology
complex. I had to go through every auditing file of each and every
staff member and cull out any embarrassing sexual exploit or business
crimes or any crimes, government connections, etc. It was just another
failed “plant sweep” in reality. At the time it was my belief that I
was doing the right thing in some way, helping the organization ,
still oh-so-blind to the truth. When this happened I truly did this
work in innocence, but I lost even that innocence once I became a
senior executive in Scientology.

Later I actively participated in other criminal activities, some of
which are documented in the declaration submitted to the courts in
Denver. The declaration is also posted on the FACTNet web page. I
guess in a way you could say I got or am getting what I deserve. I
can’t and won’t argue the point, but what I will say is the practice
of divulging personal and private information of a church parishoner,
past or present, is illegal. What they are doing is not right. What I
have done concerning the same act was wrong as well.

The first line of attack David Miscavige will have used against me is
to try to utterly and totally destroy my character by using
information given in confidence and expose it as broadly as
possible. Ive got news for you, David. You won’t have my auditing
files for long, so cull fast. The law is going to make sure you give
me my files. You have proven you are not worthy of trust, not only to
me but even to your current members. I say come on with it. I want you
to go ahead and pull out that big shot gun so I can watch you shoot
yourself and your cult in the foot.

I’m standing up and I’m not alone. I don’t care what you do. As a
matter of principle and law I am going to make sure you never have a
chance to spiritually desecrate another human being again.

Respectfully submitted,

Jesse Prince

Notes

Jesse Prince: David Miscavige’s Rise to Corruption (or: Ding Dong the King is Dead)–Reformatted (September 5, 1998)

Title: David Miscavige’s Rise to Corruption (or: Ding Dong the King is Dead)–Reformatted1
Author: jesse.prince@gte.net (Jesse Prince)
Date: Sat, 05 Sep 1998 23:15:50 GMT

The following is an account of my opinion based on eye witness events and secret
meetings I either witnessed or actively participated in while I was in the inner
sanctum of the cult known as “The Church of Scientology.” I write this in an
effort to provide an insight into the truth of the actual motives and agenda of
Scientology, which is no religion at all.

On Thursday, August 20, 1998, I attended a hearing at 8:30 a.m. in U.S. District
Court in Denver, Colorado. I had been in deposition all day the day before.
Scientology was deposing me, supposedly concerning the declaration I had filed
in the FACTNet case, but in fact I had been asked very few questions that
related in any way to the FACTNet copyright case. Most of the deposition had
concerned my personal history, much of which had been culled from my pc folders.
It was obvious to me that they were using the deposition to gather intelligence
information about me, which they would then use to discredit me. But I remained
courteous and answered all of their questions as well as I could. I have nothing
to hide. I am not ashamed of anything I”ve done in my life.

The issues before the magistrate were twofold. One was a letter which Lawrence
Wollersheim”s attorney Dan Leipold had sent to Scientology attorney Samuel
Rosen, in which Dan promised to turn the entire transcript of my deposition over
to Ken Dandar, the attorney for Lisa McPherson”s estate, if Rosen dared to bring
up any information from my confidential pc folders. The other issue was the
length of time Scientology would be allowed to keep me in deposition. Dan and my
attorney Ford Greene wanted to limit the amount of time they could keep me;
Scientology wanted unlimited access to me.

So I am sitting in the courtroom next to my friend Stacy Young, who is there as
a director of FACTNet. Suddenly I hear Samuel Rosen say: “Your honor, the
witness they are bringing into this case, Jesse Prince, was second in command of
the Church of Scientology. He signed a confidential non-discolosure agreement
not to divulge any information he obtained as a result of his being second in
command of Scientology.”

Rosen continued to do his best to persuade the magistrate not to allow Dan to
send the deposition transcript to the McPherson case (the outcome was that the
magistrate told Dan not to send the transcripts without getting his OK first,
and, by the way, we convinced the magistrate not to allow them to depose me past
noon of the following day).

But I sat there stunned that I had just heard Scientology admit, on the record,
that I was second in command of Scientology. For me, that was the high point of
the entire deposition experience.

Now let”s go back in time to an afternoon in the late summer of 1984. I am
sitting in one of many legal/litigation meetings at Author Services, Inc., or
ASI. I am in RTC, a nonprofit religious corporation which ostensibly has
absolutely nothing to do wth ASI, a for-profit corporation. But David Miscavige
finds it convenient at the moment to be the Chairman of the Board of ASI, and,
since David Miscavige runs Scientology (no matter where he places himself
corporately), he can order all of us to meet wherever and whenever he wants us
to.

The subject of this particular meeting concerns the LRH probate case in
Riverside, California, and, as always, more corporate “sort-out.” Lawyers have
advised that there is still too much evidence to prove that LRH is incompetent
to manage his own affairs. This is crucial, since the case has been brought by
LRH”s son Nibbs, who has claimed that LRH is incompetent to manage his own
affairs and that his estate is being stolen by the Church of Scientology under
David Miscavige”s leadership. Nibbs is hoping to take over LRH”s assets if he
can prove that LRH is incompetent. So this is a very serious threat.

LRH has repeatedly said he wants different lawyers to represent him, and that he
wants different legal advice on how to win this case against Nibbs. But DM has
decided that the lawyers LRH already has (and who were chosen, of course, by DM)
are the best possible legal counsel. LRH specifically doesn”t like the fact that
these attorneys are advising him to back away from managing Scientology”s
affairs. Part of the reason for this is that DM feels (and has told the
attorneys) that LRH is losing his grip on reality.

In truth, DM was not the only one who knew that LRH was an old man past his
prime, with no real “new ideas” or “brilliant revelations” for quite some time.
All he could do was say the same thing, over and over: “There are more BTs! Many
more than people realize!” Hubbard really was a bit senile at the end there –
his brain pretty well fried by a wide range of drugs which he used for his
“research” — and this scared the hell out of his top messengers and others near
him.

For many years, LRH’s top aide, Pat Broeker, and his wife, Annie Broeker, looked
after the daily care of LRH. Pat was the financial conduit between LRH and the
vast reserves of liquid cash mounting in the multiple corporations of
Scientology which LRH always had at his disposal. David Miscavige would be
called by Pat to bring hundreds of thousands or millions of dollars in cash in
briefcases to cover “basic expenses” for LRH and his small crew of four staff.
Often the prearranged meeting place was near Las Vegas. On many of these
occasions, Pat and Dave would go to a casino and gamble away thousands of
dollars of  LRH’s money, just hanging out having a good time together.

But as LRH felt his grasp on the Scientology empire weakening, he became
extremely suspicious of Dave and ordered me to give him a security check to see
if Dave was trying to prevent LRH from having his way with the church as he was
used to having. Basically, LRH was upset that he could not simply romp from one
fake corporation to another, wreaking havoc in his wake, as he had always done.
And he was being advised by attorneys whom Dave had hired that in order to
protect his money, he should disappear for a while. All of these circumstances
added up for LRH, and he was not at all sure he could trust DM. He was afraid DM
was trying to take over. Sure, he had practically raised Dave from a pup, but
still, who could be trusted in this business?

So I was ordered to sec check DM to determine his real motives for passing along
legal advice that he back off from his own church. When I walked into Dave”s
office he was crying like a child who had taken a crap in his pants and now
stank to high heaven. Dave swore up and down to me that he was only following
LRH”s own orders to get an “All Clear” — meaning to get LRH dismissed from all
the outstanding litigation — so that LRH could travel freely again, without
fear of subpoenas or worse.

LRH had been in hiding, not only from the public but also from 95 percent of all
his staff, for the last fifteen to twenty years anyway. Dave was extremely
indignant at being asked such incriminating questions, but because of the
questions I was asking him, he was fairly certain that LRH would soon assign him
to the RPF (the Rehabilitation Project Force, Scientology”s political prison).

In the security check Dave made sure he told me about the trips to the casinoes,
the heavy drinking and the women he and Pat had enjoyed together. Dave freely
confessed his sins and Pat Broeker”s sins as well. He said if he was going to go
down, he was going to make sure Pat Broeker went down as well. He was very
critical of Pat, saying he had a long history of alcohol abuse and recklessly
spending LRH’s money. Of course, the person who received the report of Dave”s
sec check was Pat Broeker. So it didn”t surprise me a bit when Dave and Pat
suddenly became best buddies again. I seriously doubt that anything but reports
full of glowing praise for Dave ever went to LRH. In retrospect I realize both
Pat Broeker and David Miscavige had an interest in keeping the status quo with
LRH, since both of them had dreams of one day being the new dictator of
Scientology once the current Ding Dong king was dead.

LRH went on spending his millions freely on property and “research” (all this
really meant was that he was buying more and more drugs for himself) and buying
exotic animals like buffalo, llamas, swans and  peacocks at the ranch at
Creston.

LRH seemed resigned to follow the legal advice of Dave”s lawyers and stayed away
from Scientology. However, he made it known that he was still very salty about
the whole deal and refused to make contact as he had done in the past.

About a year and a half later he became very ill.

I will continue this story very soon. It is not my intention to post a book on
this newsgroup all at one time. However, I will say this: What I am relating to
you here will never cost you a dime. It will always be free on the internet. I
am not a writer, nor am I trying to be. (And here is a good place to say thanks
to Stacy for being my editor — she”s making sure my posts to you are readable!)
If I could have anything I wanted in return for exposing the true nature of the
inner workings of Scientology, I would ask its current members and staff to run
away as fast as possible to recover their lives. That”s all I want.

Part of the agreement we all made when we became cult slaves was to turn our
backs on our friends and family, so I know that many people literally have no
place to go if they leave Scientology, particularly the Sea Org. But there are
people working to resolve this problem. This will change soon.

Respectfully Submitted,

Jesse Prince

Notes

Stacy Brooks Young: Scientology’s reign of terrorism is at an end (September 3, 1998)

Title: Scientology’s reign of terrorism is at an end
Author: stacy8@gte.net (Stacy Brooks Young)
Date: Thu, 03 Sep 1998 05:52:14 GMT

By now everyone should have seen the lengthy message Vaughn posted last night.
For various reasons he did not want to discuss what he has been doing until now,
and I realize this silence has created concern and allowed Scientology to hope
for the worst. But Vaughn is, more than  ever, doing what he does best in this
battle with Scientology. He and I are in daily contact, and I suggest that any
hope Scientology may have had that they could drive a wedge between Vaughn and
me is just as futile now as it ever was when we were inside the cult. It will
never happen.

Now it is time to bring everyone up to date on the relentless campaign of
intimidation and harassment to which both Bob Minton and I have been subjected
recently. It is a campaign which has increased dramatically since Jesse Prince
emailed Bob at FACTNet after hearing about the Dateline program and, shortly
thereafter, met with me in Columbus, Ohio. It will become clear as you read this
report that Scientology is terrified of what Jesse’s information is going to do.
So terrified, in fact, that they have literally made death threats against him.
But let me start earlier.

It began on July 7, while I was in Columbus, Ohio, for a meeting with Brian
Haney and Bob. That evening when I checked my email I found that the executive
director of FACTNet had forwarded a message to me that Jesse Prince had sent to
Bob Minton. In the email message Jesse suggested to Bob that he check with
Vaughn and me about who he was, since the three of us had worked together
extensively when we were in Scientology. He included a cell phone number in his
message. I called him immediately and left a message giving him my hotel phone
number.

I had known Jesse since 1976 in Scientology and was thrilled to see that he was
reaching out to re-establish contact. He had been third in command of
Scientology, under David Miscavige and Vicki Aznaran, from 1982 until he was
busted, along with Vicki and many others (including Vaughn), by DM in 1987.
Jesse had always been a kind-hearted person, even when he had every reason to
advance his own position by becoming one of DM’s vicious lieutenants. Jesse
never crossed that threshold. He always remained my friend and someone that I
and others could trust not to sell us out.

I also knew that Jesse would be David Miscavige’s worst nightmare if he decided
to come forward to expose what he knows about Scientology. He was not just in
the inner circle; Jesse was in the innermost inner sanctum, privy to all of the
illegalities, covert operations, destruction of enemies, and degradation of Sea
Org staff – all order by Miscavige. He was also a direct witness to the rift
between LRH, Pat Broeker and DM which began in 1981 and increased as LRH and
Broeker realized with growing alarm that DM was wresting control of Scientology
away from them. I was electrified at the possibility that Jesse and I might
re-connect. The ramifications for the battle being waged to reform Scientology
were staggering. I knew that if Jesse came forward with the information he had,
it would mean the end of DM’s reign of terror. I also knew that Jesse would be
in serious danger as soon as DM found that that he had contacted me. But Jesse
had always been fearless when I knew him. I hoped he would still be that way.

On Wednesday, July 8, Bob left Columbus in the morning and I spent several hours
finishing up some business with Brian. When I got back to my hotel at 3:30 I had
a message from Jesse Prince asking me to call him on his cell phone. When I
heard Jesse’s voice again, after not having seen or heard from him for nine
years, I literally cried with joy. I called him right away and he answered on
the first ring. He was sitting in a bar in downtown Boston with some friends
when I reached him. We were so happy to hear each other’s voices that we
practically shouted at each other, it was such an emotional moment for us. The
idea that we had both survived so much, and that our friendship had survived all
these years and was as strong as ever, was just too much for us. I was the first
friend Jesse had contacted since he had gone into hiding after he left
Scientology and they began coming after him.

Immediately, without even thinking about it, my support for Jesse was
unconditional. Whatever you need to recover, I told him, I’ll help you get it.
This is how I feel about Jesse and every other victim of the unspeakable abuse
and degradation to which DM subjects his subordinates. I experienced the
nightmare  myself. I know the horror he survived. Jesse is my friend. He is a
decent, kind-hearted, caring person. He’s no angel and never claimed to be, any
more than I am. But I will help him in any way I can. He knows it, and we trust
each other, and nothing Scientology can do will ever drive a wedge between us.

I arranged for Jesse to fly to Columbus that very night. He didn’t even have
time to go back to his hotel to get his suitcase. Brian and I met him at the
airport and when he walked down that ramp I can’t remember ever being happier to
see anyone than I was to see Jesse that night. We stayed up for hours just
catching up on each other’s experiences. He filled in the missing pieces for me
about the dismal failure of the 1987 attempted  coup, when Pat Broeker sent
Vicki Aznaran, Jesse Prince and Spike Bush on a mission to the secret base of
international Scientology management in Gilman Hot Springs to remove Miscavige
from post and take over command of Scientology. I won’t retell the whole story
here because Jesse can do that much better than I, but it answered many
questions that I had had. At the same time, I was able to fill in missing pieces
for Jesse, since I had been in the LRH biography unit in LA under Vaughn and
Broeker at the time, and had therefore been directly and catastrophically
affected by the upheaval caused by their failed coup.

Jesse and I spent all day Thursday together, just catching each other up and
re-establishing our friendship. Jesse told me how difficult it had been for him
to make the transition back to the real world after sixteen years in the bizaare
“through-the-looking-glass” world of the Sea Org. He told me that during the
first five years after he escaped, he felt he had hit rock bottom and it seemed
as if he had suffered just about all the loss possible for him. He said he had
felt as if he had nothing else to lose for a time. He had been forced to declare
bankruptcy in 1994 and start all over again. He said he found that he was so
unsocialized that he literally could not work with other people, because no
matter what he did, he just couldn’t fit in. He said he would experience a
physical revulsion to being around too many people, and sometimes he couldn’t
bear to be around even one other person. To his credit, Jesse started his own
company and was able to pull himself up by his bootstraps and begin the long
journey toward becoming a functioning member of society. By the time he and I
met, Jesse said he felt he was finally gaining some stability personally and
some success in his business. He was coming back to himself, he said, and coming
back to the world, and it was finally OK for him to be doing that.

Jesse told me that for several years after he left, he had avoided any contact
with Scientology or Scientologists to try to separate himself from the deep
deception and delusion that, as far as Jesse was concerned, happens to anyone
who practices and associates with Scientology for any length of time. But at the
end of June, he said, he was in Chicago visiting his family, and his cousin told
him she had seen a program on NBC’s Dateline about a guy named Bob Minton. She
told Jesse that Bob helped people get out of Scientology and exposed the abusive
and deceptive practices of the Scientology cult.

Two weeks later, for the first time ever, Jesse logged onto the Internet. He did
it via a computer at a cyber-cafe in Minneapolis, and he found
alt.religion.scientology. According to Jesse, he could hardly believe what he
was seeing! He had never seen so many people unafraid to stand up and tell the
truth about the misery that families and friends have suffered at the hands of
Scientology. He came across the FACTNet web page and saw something about Vaughn
and me, and that was how it all began. The more we talked, the more Jesse’s
conviction grew that it was time for him to stand up and tell his story and do
everything possible to end the abuse of Scientology. We talked about how
Scientology would go after him, how they would do everything they could to ruin
his life, discredit him, portray him as a criminal, a pervert and worse. He knew
he would be subjecting his own family to harassment and abuse if he took a
public stand against them. And he knew it was very possible he could be in
physical danger. But Jesse’s strength and courage increased before my very eyes.
By Thursday evening, Jesse was committed to exposing the evil of Scientology,
whatever the cost.

Although I didn’t know it until several days later, it was on July 9 that the
Boston Globe published its huge article about Bob’s battle with the Church of
Scientology. It was extremely favorable toward Bob, and extremely critical of
Scientology.

After an emotionally exhausting couple of days with Jesse, on Friday morning,
July 10, I flew to Boston to meet my family for a week-long vacation on Cape
Cod, while Jesse returned home to Minneapolis to prepare for his life to change
radically. We were in touch every day while I was in South Harwich, because as
soon as Jesse touched down in Minneapolis he discovered he was being followed,
and we realized that Scientology had had us under surveillance in Columbus.
Because of the information Jesse has, we had to assume he and I both would at
the very least be under continual surveillance once Scientology found out he had
hooked up with me.

I suggested it would be wise for Jesse to meet with attorney Dan Leipold in
Santa Ana, California, just south of Los Angeles. I thought Jesse should speak
to an attorney as soon as possible about the legal risks to which he was
exposing himself by taking on Scientology. Dan is one of the most experienced
attorneys I know in the strange world of Scientology litigation. He is also
representing Lawrence Wollersheim in the FACTNet litigation and I thought he
would probably be interested in what Jesse knew about possible fraud concerning
the copyrights in question in the FACTNet case. Jesse was extremely apprehensive
about flying to LA, since it was in that city that much of his nightmarish
Scientology experiences occurred. I offered to meet him in LA so that he would
not have to deal with the painful memories alone. He accepted my offer with
great relief and I arranged for both of us to fly into Los Angeles on Saturday
evening, July 18, after my family vacation was over. .

Little did either of us realize that painful memories would be the least of
Jesse’s difficulties during his stay in Los Angeles.

I arrived several hours before Jesse, on Saturday evening, July 18. A dear
friend of both Jesse’s and mine met me at the airport and treated me to a
leisurely dinner until it was time to meet Jesse’s plane. Jesse and our friend
had not seen each other since the late 1970s, so it was a dramatic reunion.
Moreover, they had much to reminisce about, since they were both on the infamous
1977-78 RPF in Los Angeles, when the RPF was forced to renovate the
newly-acquired Cedars of Lebanon Hospital, now known simply as “the Complex” and
best-known for the fact that the entire complex of buildings is painted light
blue. Thirty hours on, three off, that was the schedule during the horrific
sixteen months they spent together in the RPF. Our friend told Jesse the story
of how she escaped, a heartbreaking story Jesse had never heard before, and
Jesse told her what had happened to him after she left Scientology.

The reunion of the three of us was deeply moving. I imagine it to be very much
like the emotion that victims of any totalitarian, terrorist regime must
experience when they are reunited after so many years. For us as former Sea Org
members, our relief was in finding that the three of us had survived with our
sanity at least relatively in tact. We are three of the lucky ones. I have
encountered many former Sea Org members who have seemingly irreparable
psychological, emotional and physical damage, and it is heartbreaking to realize
that they may very well never fully recover. That night Jesse, our mutual friend
and I were poignantly aware of our good fortune.

The next day the harassment began.

Jesse and I took a short drive for some morning coffee at Starbuck’s and quickly
realized we were being followed. We decided to confirm our suspicion by taking a
circuitous route and, sure enough, we confirmed without a shadow of a doubt that
we had tail. There were two different cars on us, and wherever we went one or
the other was always behind us.

The next day we visited a former Scientologist in a suburb north of Los Angeles.
While we were there, a neighbor called to say there were two cars parked outside
of her house, and that a man had actually come to her door trying to get
information about Jesse and me. The neighbor described the cars  for us and gave
us the license plates. She also assured us that she had totally refused to
cooperate with Scientology’s hired thugss.

When Jesse and I left our friend’s house several hours later, sure enough, the
two cars the neighbor had described pulled out and began to follow us. It was
dark by then, and the truth is that neither Jesse nor I see very well at night.
So we got lost several times and ended up driving around in circles trying to
get home. Somehow our tail got in front of us, and we laughed as we pulled up
behind them at a stoplight. When the light turned green, our Scientology friends
sped off into the darkness, undoubtedly embarrassed at their clumsy attempt at
surveillance. By the way, Scientology has no idea how many quiet enemies it has.
The friend with whom Jesse and I were staying had another houseguest at the
time, a non-Scientologist. He jumped right into the fray, directing us to park
our car in a parking lot near our friend’s house, picking us up in his own car,
getting us to lie down on the back seat so the Scientology tails wouldn’t see
us, and safely delivering us home. All the while, private investigators were
circling the house as if we were carrion. And Jesse hadn’t said a word about
Scientology yet!

I had to leave Jesse in LA to go to Wellspring (that will be the subject of a
separate post coming very soon), but Vaughn flew down to be with him so he
wouldn’t be alone. The day after I left, Vaughn and Jesse were at Dan Leipold’s
officeworking on a declaration for the FACTNet case concerning Scientology’s
extensive copyright fraud. Suddenly Jesse heard someone shouting his name
through the window.

“Hey, Jesse! Come out here!” they were yelling. It was obvious that the two
people were OSA operatives, so, of course, Jesse didn’t go outside. One of the
operatives finally opened the door himself and threw a letter addressed to Jesse
inside the door. It was a letter threatening to sue Jesse if he said a word
about what he knew about Scientology. But, as Jesse told me on the phone that
night, it was too late to frighten him. The blanket of fear was being rolled
back, and the war was on.

Two days later Jesse was falsely detained by two private investigators at four
in the morning as he returned to his hotel. As he pulled into the parking lot,
they pulled up behind him so that he couldn’t move his car and handed him
another threatening letter. Jesse lost his temper at them, and one of the PI’s
responded by screaming at Jesse, “You black motherfucker! I’m going to blow your
damn head off!”

As Jesse said later, that PI obviously didn’t realize that as a veteran Sea Org
member, Jesse was quite used to racial slurs. Jesse just watched the guy spit
and stammer, and then he chased him to the highway in his red convertible
Mustang.

Meanwhile, I left Los Angeles and flew to Boston on Friday, July 24. I was
literally exhausted after the harassment Jesse and I had been subjected to in
L.A., and I badly needed a rest. Bob met me at the airport and told me that
someone pretending to be my “travel agent” had called the house in Boston the
night before and told Therese what flight I was coming in on. Although Therese
already knew about the relationship between Bob and me and knew that I was
flying to Boston, having an obvious Scientology operative call her and throw
this in her face had been extremely upsetting for her, particularly because she
was scheduled to leave for England Friday morning with the two girls. Bob told
me about this phone call on the way to his house in Sandown, New Hampshire,
where we planned to spend a quiet weekend before I went to Wellspring. But as
all of you know by now, it turned out to be anything but a quiet weekend in New
Hampshire.

On Saturday afternoon, July 25, Bob and I were swimming in the pool on his
property in New Hampshire. Bob was telling me about a phone call he had received
from high-level Scientology operative Mike Rinder. Bob was telling me that
Scientology had had Jesse and me under surveillance when we met for the first
time in Columbus, Ohio, on Wednesday, July 8, and that the reason he knew this
was that on Sunday, July 19, he had received a telephone call from Rinder.
During the phone call Rinder let Bob know that he was aware that Jesse Prince
had met with me in Ohio, and he demanded to know if Jesse Prince was on Bob’s
payroll, meaning was he now paying Jesse to do anti-Scientology work. Bob told
me he had replied that he was not, but because of that  phone call Bob had known
the harassment of both Jesse and me was going to increase, and that was exactly
what had happened in Los Angeles.

This was at about 5:00 p.m. on Saturday afternoon. I suddenly looked up the hill
toward the driveway and saw someone standing at the top of the hill near the
barn, looking down at us in the pool. When another person appeared and began to
shout my name along with outrageous obscenities, we both realized with alarm
that it was Scientologists on Bob’s property.

As Bob wrote in his report to the New Hampshire prosecutor, “At that point I
knew that the Scientologists were trespassing on my property and invading my
privacy for the express purpose of continuing their campaign of harassment and
intimidation against Stacy Young and myself. Having experienced this harassment
for the past year, I was fully aware that these people are fanatical in their
beliefs and that they had been indoctrinated into believing that both Stacy
Young and I were dangerous criminals. There is a policy in Scientology known as
“Fair Game,” which states that anyone who is a threat to Scientology can be
“lied to, tricked, sued, and destroyed” in any way necessary without the
perpetrator being punished in any way. I fully believed this to be the state of
mind of the Scientologists on my property and considered that both Stacy Young
and I were in physical danger as long as these people were trespassing on my
property.

As everyone knows, the final outcome of this incident was that no charges were
filed against Bob and the Scientologists were warned never to set foot on his
property again. But it was an extremely stressful weekend.

The next day, Sunday, July 26, Bob got a call from Therese in England saying
that a letter had been hand-delivered to her father’s house outside of London.
The letter was signed by Mike Rinder and was filled with terrible information
about a number of people that Bob has assisted, but the majority of the letter
was filled with scurrilous information about me, clearly calculated to upset
Therese as much as possible.

Later that day, Bob drove me down to Boston so I could take a flight to
Columbus, Ohio, and from there I drove south to Wellspring. As soon as I
arrived, I arranged for Jesse to fly to New Hampshire to stay with Bob to make
sure he was safe while I was in Ohio. Jesse flew to Boston on July 27 and was
there until August 8. As I had expected, Jesse and Bob became the best of
friends during the week he stayed there.

Later Jesse would tell me that he was amazed to meet Bob, and utterly surprised
to meet someone who has compassion for people who have had a bad experience that
he has not personally had. As Jesse pointed out, the common reaction of people
toward ex-cult members is that they are strange and somehow basically stupid ,
easily manipulated people. But the fact of the matter is that it’s just plain
bad luck when a person gets into a cult, and it could and does happen to almost
anyone. Bob understands that, and Jesse loves him for it.

As Jesse told me after his trip to New Hampshire, “Bob restored my faith and
belief in humanity. I don’t know how else to describe it beyond that. Bob has
the courage of a lion and the heart and mind of an angel. He is not afraid of
anything I’ve seen yet.”

From New Hampshire Jesse flew to Minneapolis to pack up his things and get ready
for his life to change radically. Vaughn flew to Minneapolis to meet Jesse so
that he would have someone with him while he prepared to move to Boulder. The
most difficult part about getting Vaughn to Minneapolis was that MacPherson, our
85-pound dog, had to go with him. Mac is the dog who was kidnapped last February
and beaten brutally while Vaughn was in Germany testifying against Scientology.
You’ll be glad to know that he has fully recovered from the beating. The only
vestige of it is that he is missing all of his bottom front teeth, but that
doesn’t bother Mac at all. He and Vaughn are inseparable, so, of course, he goes
everywhere Vaughn goes. He is a very large dog (and an excellent watchdog – if
anyone ever tried to hurt Vaughn they would probably lose an arm) so it took a
while to find a crate big enough to hold him, and then we had to find a flight
that would allow him on. But we solved all of these logistical problems and
Vaughn and Mac arrived safely in Minneapolis.

FACTNet purchased a car for Jesse’s use when he got to Minneapolis. Two days
later, one of Scientology’s hired thugs kicked in the passenger door of the car
(there is a picture of kicked-in door on alt.binaries.scientology).

Jesse took Vaughn on a fairly wild journey to Chicago, where he got a chance to
meet Jesse’s Blues/Rock Star brother Ron. In vintage Jesse style, the two of
them ran all around the North and South sides of Chicago, visting old friends
and having a good time meeting new people.

They left Chicago and went to visit Jesse’s daughter and his grandchildren in a
small town in southern Illinois, then headed for Memphis, Tennesse, where
Jesse’s father and sister live. As it happened, Vaughn checked into a hotel
right across the street from Graceland, and it happened to be Elvis week. So
Vaughn enjoyed the Elvis celebration while Jesse had a great time with his
father and sister, whose birthday happened to be just when they were there. The
best part of the trip for Jesse, though, was that he met his great-nephew
Malachi, who is two years old and, according to Jesse, is a “joy to behold.”

While Jesse and Vaughn were ennroute to Denver, I was finishing my stay at
Wellspring. What an incredible place!

Because of several extremely harassive visits from Scientology private
investigator Eugene Ingram a few years back, Wellspring has a gate at the
beginning of their driveway which they kept locked most of the time while I was
there to protect me from being harassed. So my two-week stay was wonderfully
free of Scientologists or private investigators — until Bob Minton arrived
toward the end of my stay. He came to Wellspring so that he and I could speak to
one of the counselors there together. As he drove up to the Wellspring gate he
was met with several scruffy looking individuals who soon made it clear that
they were Scientologists, there to take photographs of Bob and me.

We took down their license plate numbers and reported them to the local sheriff,
who was already familiar with their tactics because of the trouble Wellspring
had had with Scientology earlier. The sheriff was very supportive and told us to
let him know immediately if we had any further instances of being followed or
harassed in any way. We assumed the Scientologists found out that the sheriff
was on the look-out for them, because we didn’t see them again for the duration
of our stay.

When we left Wellspring Bob and I stopped briefly in Washington, D.C., to have
dinner with a high-level media contact, and then on Sunday, August 9, I returned
to Vashon Island and he flew back to Boston.

Vaughn and Jesse made it to Denver in time for Jesse to be deposed in the
FACTNet case in a grueling three-day confrontation with Scientology attorney
Samuel Rosen. I met Jesse in Denver on Tuesday, August 18, so that I could
attend the deposition as a FACTNet director. Also attending were Ford Greene,
representing Jesse, Dan Leipold, representing Lawrence Wollersheim, Lawrence
himself (who is also named in the suit as an individual), and, sitting on
Rosen’s side of the table for Scientology, Mike Rinder and RTC staff member
Allan Cartwright. Jesse was senior to both of these Scientology operatives when
he was in RTC, so it was fascinating to observe these two as they reacted to
Jesse’s testimony. I won’t go into details here about the deposition, because it
will be the subject of another post once Scientology’s protective order is
lifted. I will say, however, that I have never seen anyone treated with more
contempt, discourtesy and blatant racism than Jesse was by Sam Rosen in that
deposition. It was staggering. To Jesse’s credit, he maintained his composure
throughout the deposition and never once rose to Rosen’s bait. Jesse is truly
and profoundly a gentleman.

One night while we were all in Denver, Scientology sent a call girl in on Jesse
to try to entrap him. The woman stole a  $100 bill that Jesse put on the table
to pay for the drink he had bought her in the bar of the hotel where we were
staying. Jesse was so irritated that she had stolen his money!

“Now, I know this girl was being well paid,” Jesse laughingly complained to me
later. “Why did she have to rob poor me?”

Oddly, Scientology also hired a gay man to try to entrap Jesse. Anyone who knows
Jesse Prince at all can tell you that he has never had any interest and probably
never will have any interest in anything but women. As Jesse put it, “With all
the pc folder information they have about me and use against me, I have no idea
why they thought I might go for a gay guy.”

Needless to say, Jesse didn’t fall for either of Scientology’s attempts to
entrap him.

After the deposition Jesse remained in Boulder to begin a thorough debriefing
with Lawrence Wollersheim, and I returned to Vashon Island. (This debriefing
will be the subject of a series of stunning posts in the near future.)

Neither Ford Greene, Dan Leipold, Jesse nor I had been aware of any surveillance
while the deposition was ongoing. But as soon as Ford, Dan and I left and Jesse
was alone in Boulder, the PIs descended upon him in force. Jesse told me that
one day the PIs were following him in such a harassive way that he was forced to
call the police four times. The police ordered a female PI to leave Jesse alone
and watched to make sure she didn’t follow Jesse as he drove away. But when he
arrived at the house where he was staying, the very same female PI was waiting
for him, laughing, in front of the house.

During this same period of time, on Monday, August 24, Scientologists picketed
the financial district in Boston and for several hours distributed fliers
concerning the relationship between Bob Minton and me. It was the distribution
of these fliers that prompted Bob to post his now-famous message on a.r.s. in
which he announced that he and I are getting married. What immediately preceeded
this post was a private email from one of the regulars on a.r.s. attacking Bob
really harshly for “not living up to proper moral standards.” He was extremely
upset by the distribution of the fliers, and the private message just hit him
the wrong way. He tried to reach me before he posted his announcement but I was
in Seattle and unreachable. When he finally reached me in the early evening, he
was extremely upset about what had happened that day and told me the stress of
Scientology’s harassment had nearly broken him. He read me what he had posted
about our relationship. I suppose it was because of the stress of having
Scientology turn our personal lives into a fishbowl that we decided that night
that we would no longer hide our relationship in any way.

The next morning Bob flew into Seattle. I was there to meet him, and as we got
off the escalator from the gate, we nearly ran into four picketers holding signs
about Bob Minton and me. This was the first of a series of pickets which have
happened everywhere we have flown in the past two weeks. Somehow the
Scientologists know when both of us are flying, what airlines we are taking, our
flight number and the gate where we will arrive in the airport. They have met
every plane either of us has taken since Bob’s post on August 23.

They have picketed not only our flghts. Bob was in Seattle from Tuesday, August
24, until Thursday, August 26, when we both flew to San Francisco. While he was
in Seattle the Scientologists picketed the hotel where we were staying in
downtown Seattle and my cat sanctuary on Vashon Island. The hotel security ran
them off at the hotel, and Vashon’s local sheriff ordered them off the island
when he discovered them on Vashon.

On Wednesday, August 25, my assistant at the sanctuary reported to me that she
had received two telephone death threats. The calls seemed to come from two
different people, and both callers assumed that it was I who answered the phone.
The callers said roughly the following:

“Listen, you fucking cunt, you better get that black bastard in the witness
protection program because we’re going to fucking kill him. Do you understand,
you fucking whore?”

Forgive my language, but I want you to have the full impact of these calls. My
assistant was terrified, and Bob and I were both extremely alarmed at this
dramatic shift in Scientology’s approach. I called Jesse and Lawrence
immediately to let them both know Scientology was now threatening to kill Jesse.
Soon afterwards I received two telephone calls from the FBI wanting full details
of the telephone death threats. I spoke to the FBI agents at great length,
briefing them on the full implications of Jesse’s knowledge of Scientology’s
crimes and assuring them that the Scientology leadership is perfectly capable of
murdering Jesse to keep his knowledge from ever surfacing. To my knowledge, the
FBI has had Jesse under surveillance protection ever since and is keeping
detailed records of all the Scientology tails they are able to ascertain.

Bob and I flew to San Francisco on Friday, August 28, to meet with Ford Greene
and several other people. Our departure was not without incident, as a lone
picketer said goodbye to us as we boarded the plane at the Seattle airport. When
we arrived at the San Francisco airport we were confronted with several
picketers with signs about Bob and me. They were extremely rude and continued to
harass us until we reached the baggage claim area of the airport.

The next day Bob and I, along with Grady Ward, Keith Henson, and several others,
picketed the San Franicisco org. Several Scientologists came out and distributed
leaflets about Bob Minton and me to anyone who received a flier about Lisa
McPherson from Grady Ward or a flier about Xenu from Kristi. Kristi, I might
add, is better at working a crowd than anyone I’ve seen at any trade show.
Otherwise, it was a peaceful demonstration that concluded without further
incident.

The next morning Therese Minton called Bob to let him know that Scientologists
had picketed their homes in Boston and New Hampshire, in both locations passing
out fliers about Bob and me. She was angry at the despicable tactics of the
Scientologists and concerned that these fliers were being passed out where
friends of the Minton children might recieve them. Therese had gone out and
photographed the picketers. She was not in the least bit intimidated by them.
She was merely furious at them for their hypocrisy in feigning concern for the
children while doing everything possible to hurt them.

This incident upset Bob a great deal, and after a meeting with Grady, we were
ready for a long walk in downtown San Francisco just to try to relax. We set out
from our hotel toward Fisherman’s Wharf. When we had walked several blocks Bob
decided we should turn back and get a map from the Fairmont Hotel. We were
nearly to the front door of the Fairmont when we suddenly realized that one of
the Scientology operatives we had seen at the org the day before was standing
with his back to us in front of the Fairmont, holding a walkie-talkie to his
mouth, and saying, “They’re heading back toward their hotel now; they’re in
front of the Fairmont.”

We were flabbergasted that we were being stalked like this by Scientology. Bob
was in no mood to be cordial to this Scientology goon. He walked over to him and
demanded to know why he was following us. The Scientologist sneered at Bob and
said, “I’m a citizen of San Francisco. I have as much right to be here as you
do.”

At that, Bob called the San Franicisco police and reported that we were being
stalked, that we had been met at our gate at the San Francisco airport by
Scientologists, that they were stalking us all across the country, meeting us
wherever we fly, and now here they were stalking us through the streets of San
Francisco. We followed this man for many blocks, deep into the heart of
Chinatown, keeping tabs on him until the police could arrive. Every few feet the
Scientologist (we later found out his name was Mark Warlick) stopped and
pretended to be videoing scenes from Chinatown as if he were a tourist. Later
one of the police officers suggested that he was probably erasing the footage he
had taken of Bob and me in case they confiscated his camera. When the police
arrived the officer did take the video camera, although he later returned it.

This Scientologist, Mark Warlick, admitted to the police that he was one of the
people who met us at our gate two days before, so it was obvious to the police
that the Scientologists were harassing us. But when the police sergeant finally
arrived and interviewed both the Scientologist and Bob and me, he came to the
conclusion, albeit reluctantly, that Mark Warlick had not technically broken any
law.

“Listen,” he said to us, “you two are celebrities, and there is just no way to
control what people are going to do when you arrive in town. It’s the same
problem politicians have. People picket them, they follow them, they yell at
them, and what can the police do? Unless these people actually break the law, we
can’t arrest them.”

This was unnerving to hear from a law enforcement officer. Bob and I looked at
each other in dismay as we realized that what this policeman had just told us
was that Scientology would be able to continue to harass us and there was
nothing the law of the United States could do to stop them.

The sergeant did warn Mark Warlick that he had come dangerously close to
breaking the stalking law, and he did tell him to let all the other Scientology
operatives know that if they crossed the line and broke the law they would be
arrested. The sneer on Mark Warlick’s face that he had had when we first saw him
in front of the Fairmont Hotel was definitely gone by the time the police let
him go. But the incident had had a profound effect on Bob and me.

We returned to our hotel room and talked about what had happened. What we
realized was that the only way we can deal with the harassment from Scientology
is to refuse to be intimidated by them in any way.

We went out and purchased a large portfolio case that holds up to ten picket
signs and sticks. When we left San Francisco for Boulder, Colorado, to visit
Jesse and to have a board meeting with Lawrence Wollersheim, we carried our
portfolio case on board the airplane with us. When we landed in Denver, I got
out my digital camera, and Bob carried the portfolio case with him as we walked
out to the gate.

I saw Jesse with several picketers as I rounded the corner to the gate and I
immediately started shooting pictures. Bob pulled out picket signs, handed one
to Jesse and held up one himself, and we immediately turned the tables on these
Scientology picketers. Bob and Jesse were following the picketers and I was
taking photographs of the entire incidents. Bob was announcing to everyone in
the airport that these were Scientologists who were stalking us, following us
everywhere we go and trying to frighten us into silence so we won’t expose the
true nature of their so-called “church.”

We got on the shuttle to baggage claim and noticed that the Scientology
picketers purposely did not get on the shuttle. So when our shuttle arrived, we
waited for the next one. When the picketers got off, we began shooting their
photos again and following them with our own picket signs, again announcing
loudly who they were and why they were there. By the time we were finished with
them, these four picketers had their signs between their legs and they were
running out of the airport.

The next night Jesse, Lawrence, Bob and I had dinner at the Boulderado Hotel. At
a certain point we recognized someone from the ARSCC Boulder Underground
standing outside the restaurant. Bob went out to say hello and when he came
back, he reported that there were approximately seven to ten Scientology PIs
surrounding the hotel, but that the ARSCC Boulder Underground had successfully
scrambled the radio signals of the PIs and disrupted their surveillance so
effectively that most of them had given up and left.

Today I flew home to Seattle and Bob and Jesse flew to Boston. When I arrived on
Vashon Island I was met with picketers right up the street from the sanctuary,
undoubtedly because the sheriff warned them if they trespassed on private
property again he would arrest them.

When Jesse and Bob got off their plane in Boston they were met by seven
picketers, including the DSA Maureen O’Keefe, OSA operative Gerard Renna, Frank
Hall, and several others who have picketed in Boston before.

Immediately Bob pulled picket signs out of his portfolio case and both of them
held picket signs up while Bob also took photos with his digital camera, so he
could download them right away to post on alt.binries.scientology.

Maureen came at Bob with, as he put it, “a stomach that stuck out three feet
from her face,” and holding the taunting a.r.s. post that Bob had sent from the
airplane announcing that he and Jesse were arriving in Boston and providing OSA
with their flight number. Gerard Renna was also trying to get in Bob’s face,
although he is so short that he wasn’t able to reach.

Both Jesse and Bob pointed out to Renna on several occasions that he was in
serious need of mouthwash, as they were having a very difficult time every time
he got close to them.

The Scientologists were extremely hostile all along, but they were unable to
stop the verbal tech of the tag-team duo, Bob and Jesse. Finally in the baggage
claim area the encounter became so boisterous that the Massachusetts state
troopers had to come in to restore order. When they found out that Jesse and Bob
were passengers who had arrived on a flight from Denver, had been stalked
through the terminal, and were trying to pick up their bags, they told the
Scientologists that had they known they were demonstating at the gate or
anywhere in the airport, for that matter, they would have arrested them, as FAA
regulations prohibit such activities.

The Scientologists were removed to a neutral location, where they couldn’t
bother Bob and Jesse while they left the airport.

Bob called Therese from the car and told her what had happened at the airport,
but Therese said she wasn’t afraid of “those fools” and told them to go ahead
and go to the house. But four Scientologist followed Bob and Jesse to a house
they knew Bob no longer lives in, specifically for the purpose of upsetting
Therese and the children. Jesse went outside of the Beacon Hill house and spoke
to the four Scientologists. DSA Maureen O’Keefe told the other three to stay
away from Jesse, but Gerard Renna and the other two Scientologists gathered
round him and listened, spellbound, as he told them the real story of life in
the inner circle of Scientology leadership.

This conversation with Jesse continued until two Boston police cars arrived and
ordered the Scientologists to leave.

From now on, we will document every instance of harassment or attempted
intimidation by Scientology. Soon we’ll have a web page set up that will get
daily updates of harassment from all over the country, complete with photographs
and video footage where appropriate.

The reign of terrrorism by these bullies is at an end.

Notes

The Jesse Prince Story, Part 3 (August 6, 1998)

Subject: Welcome to the Sea Org, Marty Rathbun
Date: Thu, 06 Aug 1998 08:36:05 GMT
From: jesse_prince@minton.org (Jesse Prince)
Organization: ARSCC
Newsgroups: alt.religion.scientology

The Jesse Prince Story, Part III1

by Jesse Prince

I just want to give my heartfelt thanks to all of you out there that are interested in knowing the truth concerning Scientology. You know I just can’t refer to Scientology as a church in any way; it would be an insult to all religions.

I have many questions being asked of me and I promise, in one way or another, to get to all of them. It will be best if I just get the whole story out, chapter by chapter, and I promise all will be revealed.

Now, an issue has been raised concerning the pc folder information of those in power in Scientology. This is what I have to say about that: No, I am not a Scientologist! That means that I will not act like one. My intention in going public with the information I have is not to malign any single group or individual in Scientology. I am simply telling the truth about real incidents I’ve seen with my own eyes, that’s all. There is no need for me to talk about anyone’s pc folder information. Real events that have nothing to do with auditing are much more interesting; Just the facts, please.

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 that they can wake up and start getting well, like I have, and others have to.

Well, this ties into the next story I’m going to tell, which may give some insight into why some of those people are so sick in the first place.

This story is about Marty Rathbun.

The year is circa 1978. I was forcefully incarcerated in the PAC RPF, and I had been since one week before my 22nd birthday in March 1977. We were 125 strong in the RPF. David Miscavige had been running several missions, along with Mark Ingber, to renovate what is now the big blue building on Sunset Avenue in Los Angeles. These missions were basically a two stage process.

Missions were sent to all the Sea Org locations to get all ethics bait personnel and send them to the PAC RPF to renovate the Complex. We lived in a slave labor camp environment and for weeks on end were on a schedule of working 30 hours on and three hours off for sleep, so that we could “meet deadlines.” People were literally dropping like flies, which resulted in many unnecessary injuries. I remember one person, Bobby Schaffner, who cut off part of a finger during this time. He was so numb that it meant nothing to him, but he was happy to be off, since he could at least sleep for a while.

But my RPF experience is not the subject I’m trying to cover here; that’s another story. I’m just trying to set the stage here.

Now, it happened one day that a fellow named John Coletto was routed to the RPF forcefully. By “forcefully,” I mean he was surrounded by others who forced him to go, just the way it happened to me. He came from the Pubs Org, which later came to be known as Bridge Publications, Inc., or BPI. His wife Diane Coletto was the Commanding Officer, or CO, of the Pubs Org, and she had been instructed to divorce her husband John because he was a “criminal.”

Well, this sent John “over the top.” After some weeks, he managed to escape the PAC RPF and shortly afterwards called Scientology officials to let them know that they had turned his wife against him (a common practice in Scientology), and he was going to kill her.

Diane was assigned a body guard. A new person who just routed onto the EPF (Estates Project Force). The EPF is where you get your initial Sea Org training (brainwashing).

Marty was in a car with Diane driving down what is now known as L. Ron Hubbard Way, when out of nowhere here comes John, her husband, and he has a gun in his hand. John stopped the car and got into an argument with Diane because she would not leave with him. He then took the gun and emptied it into her body. Blood and guts were everywhere. He then took the gun and pointed it at Marty and started to shoot – click, click, click – no more bullets.

Marty sat there in shock staring at John as John stared at him. Marty had blood, bone and guts all over him and barely escaped death that day. John ran off and was found dead himself a few days later for self-inflicted wounds from the same gun he used to kill his wife.

This was Marty Rathbun’s introduction to the Sea Org. Marty was assigned a special Guardian’s Office auditor and spent months trying to audit out the incident. He became part of OSA and was watched and guarded himself for a long time.

Is it any wonder he is a mindless robot today with little to no will or spirit left now?

Monsters of Scientology are created. This is just one story. All John Coletto wanted was to be with his wife.

The result was death.

Death is more common than one would think in Scientology.

Yes, Marty did blow after the IRS decision. Little David Miscavige often beat Marty up (in the presence of bigger stronger goons, of course) and all of this has an effect on a person.

I’m sure Marty was a decent person before, but now he probably feels hopeless and is just waiting for his life to end, as, seemingly, that is the only way out of the Sea Org for him in his mind.

I want Marty to know it’s OK to leave. In fact, Marty, run away as fast as you can. I’ll make sure you won’t get hurt any more. Your suffering will be over for good. I promise.

Respectfully submitted,

Jesse Prince

Notes

Jesse Prince: Hello Critics of Scientology and Scientologists; (August 3, 1998)

Title: Hello Critics of Scientology and Scientologists; 1
Author: jesse_prince@minton.org (Jesse Prince)
Date: Mon, 03 Aug 1998 20:03:22 GMT

My name is Jesse Prince. I was part of the horrid organization known as the “Sea Organization” from 1976 – 1992. I was a Senior Executive in RTC for 5 years (1982-1987). This is not something that I am proud of—to the contrary I am still recovering from the experience. I have been disassociated from any form of Scientology for the last 6 years, since I escaped in 1992, I had been afraid to come out and was feeling hopeless, but that is all behind me now.

Three weeks ago I contacted Stacy Young. In talking with her I realized I could help in the struggle to expose the truth about Scn and get them to stop hurting people and ruining lives of decent and innocent people. The following Sunday after Stacy and I met, Mike Rinder called Bob Minton to ask if I was now on his payroll. It was obvious that they knew Stacy and I had met and were ready to attack all of us—which is what they have been doing ever since. Scn attorney Rick Moxon has already put me on notice that I am to be sued if I divulge any information about their criminal activities. However, I will not be silenced by these thugs.

I feel an obligation to do something to expose the criminal and psychotic nature of the upper echelon of the Sea Org (all corporations included) in an effort to get some relief from the attacks that come to anyone who opposes this godless so called church. Since I made the decision to expose the truth about the true nature of Scn I have had my life threatened by one of their hired thugs and they try to follow me around where ever I go. To say the least, I have personal knowledge of crimes and cover-ups that have them very worried if they want me killed before I could even fully come out of hiding!

Well, I want you to know I am alive and well and I have one hell of a story to tell. The Internet will be the forum I use to tell the truth and nothing but. If you liken the Internet to a basketball game, I plan to take Scn to the hoop like Michel Jordan.

Bob Minton, Stacy Young, FACTnet and others are making this possible.

I’m coming out for me and you.

Jesse

Notes

The Jesse Prince Story, Part 1 (August 3, 1998)

Subject: Hello Critics of Scientology and Scientologists
Date: Mon, 03 Aug 1998 20:03:22 GMT
From: jesse_prince@minton.org (Jesse Prince)
Reply-To: bob@minton.org
Organization: ARSCC
Newsgroups: alt.religion.scientology

The Jesse Prince Story, Part I1

My name is Jesse Prince . I was part of the horrid organization known as the “Sea Organization” from 1976 – 1992. I was a Senior Executive in RTC for 5 years (1982-1987). This is not something that I am proud of—to the contrary I am still recovering from the experience. I have been disassociated from any form of Scientology for the last 6 years, since I escaped in 1992, I had been afraid to come out and was feeling hopeless, but that is all behind me now.

Three weeks ago I contacted Stacy Young. In talking with her I realized I could help in the struggle to expose the truth about Scn and get them to stop hurting people and ruining lives of decent and innocent people. The following Sunday after Stacy and I met, Mike Rinder called Bob Minton to ask if I was now on his payroll. It was obvious that they knew Stacy and I had met and were ready to attack all of us—which is what they have been doing ever since. Scn attorney Rick Moxon has already put me on notice that I am to be sued if I divulge any information about their criminal activities. However, I will not be silenced by these thugs.

I feel an obligation to do something to expose the criminal and psychotic nature of the upper echelon of the Sea Org (all corporations included) in an effort to get some relief from the attacks that come to anyone who opposes this godless so called church. Since I made the decision to expose the truth about the true nature of Scn I have had my life threatened by one of their hired thugs and they try to follow me around where ever I go. To say the least, I have personal knowledge of crimes and cover-ups that have them very worried if they want me killed before I could even fully come out of hiding!

Well, I want you to know I am alive and well and I have one hell of a story to tell. The Internet will be the forum I use to tell the truth and nothing but. If you liken the Internet to a basketball game, I plan to take Scn to the hoop like Michel Jordan.

Bob Minton, Stacy Young, FACTNet and others are making this possible.

I’m coming out for me and you.

Jesse

Notes

 

Letter from Heber Jentzsch to James McGovern, Assistant IRS Commissioner (November 5, 1994)

Church of Scientology International

Office of the President

November 5, 1994

James McGovern
Assistant Commissioner (Employee
Plans and Exempt Organizations)
Internal Revenue Service
Room 3408E
1111 Constitution AVe., N.W.
Washington, D.C. 20224

Re: FACTNET, Inc.1

Dear Jim:

I have written to you previously in February 19942 and again in August 1994 concerning “Fight Against Coercive Tactics Network (“FACTNET”) describing the purposes and activities of this group and demonstrating that the application for tax exemption that they filed — and which was granted by the Service in August 1994 — was fraudulent. I will not repeat the information set forth in those letters but attach copies, (without exhibits) here for your reference. (Exhibits 1 & 2). I am writing this letter to bring to your attention additional evidence concerning FACTNET that has come up since my last letter.

In my earlier letters I described the close relationship between FACTNET and the Cult Awareness Network (“CAN”), an anti-religion hate group that serves as a referral service for deprogrammers, and evidence that FACTNET itself was carrying out similar referral services. Further evidence has been brought to light of these two organizations working together and carrying out similar functions.

FACTNET’s former president, Gerald Armstrong, testified in the last two weeks that in November 1993, shortly after FACTNET was formed, its founder, Larry Wollersheim, gave a demonstration of the FACTNET system to the Executive Director of CAN, Cynthia Kisser and other CAN principles. FACTNET and CAN use very similar language for.describing what they do and similar euphemisms for promoting their deprogrammer referral network. A recent computerized advertisement by FACTNET promoted via the Internet system, says that they can connect up anyone who contacts them to

6331 HOLLYWOOD BOULEVARD, SUITE 1200, LOS ANGELES, CA 90028-6329
TELEPHONE (213) 960-3500   FAX (213) 960-3508  /  960-3509

 

JAMES MCGOVERN
PAGE TWO

“an assortment of key mental health professionals, clergy, attorneys, support groups, ex-members, and organizations who work with victims and families of this group.” (Exhibit 3) Compare this to a recently promotional piece for CAN that describes who they are as “.  . . mental health professionals, lawyers, physicians, legislators, clergy, law enforcement officers and educators” and in the`next paragraph admits that “CAN recognizes the need for voluntary exit counseling/deprogramming . . ..”
Exhibit 4 FACTNET and CAN are working together and FACTNET appears to be taking part in the deprogrammer referral business.

Recent additional evidence of the extent of CAN’s involvement in deprogramming demonstrates what such referrals actually mean.

A declaration from the manager of a Bed and Breakfast house in Albany, Ohio (“The Albany House”) situated near the Wellspring Retreat and Rehabilitation Center, (run by CAN Board member Paul Martin), states that between 1988 and 1993, about 20 different families who stayed at The Albany House said they were having a family member deprogrammed at Wellspring. Members of about 10 of these families stated that their adult child had been kidnapped during the deprogramming upon the advice of CAN. Exhibit 5

Similarly, in a deposition of CAN’s Office Manager, Marty Butz, he admitted that he had given 500 referrals to deprogrammers since he started working at CAN in 1989, including referrals to deprogrammers like Rick Ross known for using force and violence. Exhibit 6 As demonstrated above, FACTNET is also part of this network, working with CAN in its deprogramming referral activities.

That FACTNET is playing an active role in deprogramming is further demonstrated by the fact that its president, Jon Atack, who lives .in the United Kingdom, is himself a deprogrammer, specializing in attempts to deprogram Scientologists. He has been paid tens of thousands of dollars over the years for such services. As described in my  August 1994 letter, Atack has also exported FACTNET’s operation to the United Kingdom and has attempted to spread its activities into other parts of Europe by forming a “Counter-Scientology Europe” network. Among other things he has done through this group, he has attempted to incite opposition to the Church’s application for religious recognition with the United Kingdom Charity Commission and has disseminated to the Charity Commission some of the same false information put out by FACTNET.

Atack is also a litigant against the Church in the UK and thus personally interested in causing the Church as much trouble as he can. Recently, however, the suit that Atack filed against the Church was dismissed for lack of merit. The Church was

 

JAMES MCGOVERN
PAGE THREE

awarded costs, which Atack has refused to pay. The Church is taking the necessary collection actions.

My earlier letters briefed you on the kinds of scurrilous and defamatory information that FACTNET has put out about Scientology and the plans of its founder, Larry Wollersheim, to sell this information and otherwise solicit “tax deductible” contributions to fund harassive litigation against Scientology. Recent evidence shows that this is exactly what FACTNET is doing.

One of the major sources of the false information disseminated by FACNET has been Steven Fishman, who was previously convicted for obstruction of justice for falsely trying to implicate the Church in his crimes as a way of deflecting guilt from himself. It didn’t work and he went to jail. Fishman is currently under investigation again by the Probation Department for involvement in a new round of fraudulent schemes and violating his parole by associating with felons.

Fishman recently sought legal representation from an attorney in North Hollywood for a “malicious prosecution” case against the Church of Scientology he wishes to  bring. In making this request for representation, Fishman repeated many of the same blatantly false allegations against Scientology that have been promoted by FACTNET. Included in these is the scurrilous allegation that the tragic suicide of David Miscavige’s mother-in-law was actually a murder for which Mr. Micavige may be charged. Fishman also represented that with respect to the funding of this proposed litigation, funds may be forthcoming from FACTNET, a tax-exempt organization headquartered in Golden, Colorado, to help cover the costs of the suit. This shows FACTNET’s funds being earmarked for harassive litigation against the Church, which is not a tax exempt purpose. Exhibit 7

Attorney Graham Berry, who earlier paid about $20,000 to FACTNET for false information (which Berry proceeded to file in court in the Fishman case) attempted to get Senator Chafee of Rhode Island to connect up with FACTNET so as to get Senator Chafee’s assistance in getting the tax exempt status of the Church of Scientology revoked.

Last week, FACTNET’s Systems Op, Bob Penny, posted a letter from Graham Berry in which Berry solicited data which could support his false allegation about the confidentiality of the advanced levels of Scientology religious services. Even though Berry stated that his letter was to be kept confidential, FACTNET posted it broadly on its computer system asking people to send information about Scientology confidential advanced levels to Larry Wollersheim clearly for the purpose of supporting private litigation. This is not an activity that should be supported by tax exempt contributions. Tab 8

 

JAMES MCGOVERN
PAGE FOUR

My letters in February and August 1994 showed that FACTNET does not qualify for tax exemption, that its exemption application was a sham and should have been more than ample to result in revocation of its tax exempt status. The additional evidence provided here demonstrates that FACTNET is operating in the non-exempt manner described in those earlier letters.

Please contact me if I can provide any other information.

Sincerely yours,

[signed] Heber Jentzsch
Heber Jentzsch
President
Church of Scientology
International

Notes

  1. This document in PDF format.
  2. February 1994 letter in PDF format.