Testimony of Jesse Prince (Volume 3) (July 8, 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 3

DATE: July 8, 2002. Afternoon Session.

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

BEFORE: Honorable Susan F. Schaeffer,  Circuit Judge.

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

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

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APPEARANCES:

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

MR. LUKE CHARLES LIROT
LUKE CHARLES LIROT, PA
112 N. East Street
Suite B
Tampa, Florida 33602-4108
Attorney for Plaintiff

MR. KENDRICK MOXON
MOXON & KOBRIN
1100 Cleveland Street
Suite 900
Clearwater, Florida 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, Florida 33602-5147
Attorney for Church of Scientology Flag Service Organization.

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

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APPEARANCES: (Continued)

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

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THE COURT: Mr. Prince, you all may be seated.

MR. DANDAR: Judge, I just was advised by my  office that Judge Baird wants us to be at a hearing  tomorrow by telephone. And I’m going to be here and  my brother is covering another hearing for me in  Tampa. But Judge Baird wants to go forward with the  hearing by telephone.

So I would ask that you let  me attend that hearing by phone.

THE COURT: What time?

MR. DANDAR: Nine o’clock.

THE COURT: Okay. How long is the hearing  expected —

MR. DANDAR: I have no idea.

THE COURT: Well, that is no good. What kind  of motion is it?

MR. DANDAR: It was the Flag’s — or RTC’s —  actually, Mr. Rosen and Mr. Pope’s motion to strike  our pleading challenging the domestication of the  Texas judgment against the estate.

THE COURT: So it’s legal —

MR. DANDAR: Right. We had a hearing on that  Tuesday at about 5 o’clock before July 4 and we  filed a supplemental memorandum of law and they  filed a response over the holiday, so I guess we’ll  discuss that.

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THE COURT: You think an hour?

MR. DANDAR: I hope not. I don’t think so.  But —

MR. WEINBERG: I’m told not that long. About  thirty minutes.

THE COURT: Okay. Well, let’s plan on starting  at ten o’clock anyway.

MR. WEINBERG: All right.

THE COURT: All right, go ahead, Mr. Dandar.

Mr. Prince indicated he didn’t give us his full explanation, so you can go ahead with that.

MR. DANDAR: Okay, before he does that, could I  give him a document that I had the clerk just mark?

BY MR. DANDAR:

Q Well, Mr. Prince, go ahead, give us the full explanation of why you have the opinion that Lisa McPherson was dead because of an end cycle order?

A Okay. Lisa McPherson went to the hospital.  From — from the records that I can see from the doctor,  they didn’t indicate that she was psychotic and needed to be  Baker Acted.

Now, we’re talking about terms here that mean different things to different people. In the hospital they define psychosis the way they define it and, thus, Baker Act people. In Scientology, they have a different definition

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for a person, a psychotic or suffering from psychosis.  One of the definitions, reasoning of what  psychosis is in Scientology, is in their Case Supervisor  Series 22, which has been entered in on the record, I’m  sure, many times. And this is concerning psychosis.

Now, it says here —

THE COURT: I don’t know if it has been or not.

I think you’re looking in that one book?

THE WITNESS: Yes, ma’am.

THE COURT: I’m not sure if that whole book was introduced.

THE WITNESS: No. No. Not the whole book. But this issue here, psychosis, has been an exhibit.

We can put it in again.

THE COURT: I don’t know if it has or not.

MR. WEINBERG: I don’t think it has.

THE WITNESS: Okay. Well, when I finish explaining it, I’ll hand it over.

MR. DANDAR: We’ll mark it.

THE COURT: All right.

A It says — down here at the beginning of this issue here on psychosis, it says, “All characteristics classified as those of a suppressive person are, in fact, those of an insane person.”

So, in other words, it is the belief of

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Scientology that a person who they consider to be suppressive and has those characteristics are also insane people, you see. So we’re working with two different  definitions here.

Now, if this person — if Lisa was taken to the hospital and they said okay, she’s not insane, she’s just having problems, she can work it out, she gets to Scientology, she’s insane. They are the ones that classify her as being insane.

Why do they classify her as — well, one of the reasons they classify her as being insane is because she wants to leave. And again that is mentioned here in this book here of people wanting to leave as also being psychotic.

So my thing is this. Lisa McPherson was taken to the Ft. Harrison. Prior to being — to this whole incident with going to the hospital and everything, she made her intentions to the Church known, to her friends, to her family, she wants to leave. In their minds, she’s psychotic. Medically, not necessarily so, she simply doesn’t want to do it anymore.

It has become a matter of PR concern because she had the accident with the boat, you know. She’s left, she’s —

THE COURT: I’m sorry, she had the what?

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THE WITNESS: The accident with the boat, where she ran into the back of the boat and took off her clothes.

THE COURT: Oh, okay.

A Okay? This is something a person now who again, two months earlier, just testified to being more than human, more than a homo sapiens, this person is a homo novis. This person is almost like a demigod. Now, this person is brought to the Ft. Harrison.

In my mind, my opinion, she came in there, she said, “I want to leave.” She didn’t change her mind. She’s delegated to be psychotic. They want to put her on introspection rundown. She’s incarcerated.

In that book “What Is Scientology,” it gives a definition of introspection rundown and gives a brief summary of introspection rundown that the public people can read.

MR. DANDAR: Let me hand this to the witness, Judge. It is Exhibit 125, just marked by the clerk from “What Is Scientology,” which I believe you have the entire book.

THE COURT: Yes.

A It says “Introspection Rundown. This is a service that helps to preclear, locate and correct things which cause him to have his attention inwardly fixated. He then

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becomes capable of looking outward so he can see his  environment, handle and control it.”

Nothing in here, one, if Scientology labels you psychotic, you are going to be incarcerated until a case supervisor tells you you can leave. There is nothing in here that warns anyone of that.

So Lisa was taken to the Ft. Harrison, deemed to be psychotic, put on the introspection rundown.

Well, when did that come up that we even found out that Lisa was on introspection rundown? After Alain Kartuzinski and other people were given use immunity when they were first saying she’s a hotel guest, now the
investigators want to hear the story, “Oh, she was on introspection rundown.” Okay. So she’s on introspection rundown the second day.

And to me — again, she told them, “I want to leave.” They wouldn’t let her leave. She gets violent. The next day they order the drugs to put her down.

BY MR. DANDAR:

Q What drugs?

A I think it is chloral hydrate or Valium. Alain Kartuzinski gave some money for Valium. And if you look and see what Scientology says about drugs, psychiatric drugs, all of these things, these things are expressly prohibited.

Now, so far what we’ve seen, we see Scientology’s

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policy if a person is sick, when you take them to the  hospital, make sure — but now we see things happening that — that are outside of that. By their own policy we see things they are not following that. That is a huge no-no.

We are at the place where policy and tech is applied 100 percent correctly standardly in every case, but somehow in this instance we have so many instances where this person — they are not doing it, they are not doing it.

And the reason why, you have to look behind that. And the reason, my contention is, is that she expressly wanted to leave, it escalated to her actually threatening, probably threatening with legal, threatening with law enforcement or whatever. This became a problem.

OSA was there from the very beginning, reporting about this, the very beginning, because this is a legal threat, this is a problem in Scientology.

So maybe they did try an introspection rundown on her. You know, they say they did. Maybe they did. But I think she never agreed to it. I think that she decided she was done with Scientology, no matter what they said to her,
she would no longer agree to it, because by her own word, it was making her sicker.

So instead, because of what happened, when they saw Lisa’s deteriorating condition, in their minds Lisa is

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on the process. She’s on introspection rundown. Scientology has further policy, the way out is the way through, get the PC through it. What turns it on or turns it off. In their minds, whatever she’s going through is part of the process.

Plus, you have the added fear that if this person isn’t reconciled with Scientology, it’s going to be a big problem.

So instead of taking this girl to the hospital where she should have belonged, where their own policy says to do, and get her medical treatment, when it was obvious, by the reports that I have seen that she was ill, instead of
doing that, no, we’re going to keep doing Scientology because that is what it means by Keeping Scientology Working and, you know, what happens happens. Some of them don’t make it. Too bad.

But the biggest fear for Scientology was to let this girl go, in the state of mind where she was refusing to cooperate with them, caused them more problems than her actual death.

Q How do you get to your conclusion that her death was a result of an end cycle, let her die order from Mr. Miscavige?

A During my tenure in — in RTC, we would have staff meetings that had a pattern to the staff meetings. And the

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patterns were this. What are the flaps? What are the  handling for those flaps? Those are the first things that are discussed and chewed around and taken care of.

Q With whom?

A Amongst the executives and the staff in any particular organization. Any particular Sea Org organization, I should say.

Q At RTC, who were the meetings with that you had?

A Flaps and handling? They would entail myself, Vicki Aznaran, Mark Yaeger, David Miscavige, Lymon Sperlock, Norman Starkey (phonetic), in some instances the executive director in the national if it had to do with stats. But
those were the people that ultimately had to know what was going on.

Now, why is Flag Service Organization so important? Because the Flag Service Organization, when I left here in 1982, made an income of over 2 million a week. So you have an organization here that makes $8 million in a
month. This is — it is the highest income-producing organization within Scientology.

It’s a major concern that everything is perfect at the Flag Service Organization. There is not going to be an instance where no one knows what is going on. So in the staff meetings you talk about flaps and handling.

Well, Lisa is a flap. It’s reported up the lines.

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OSA is there from the very beginning because she is a legal threat because it is a flap. And they are busy reporting, you know, on the legal side of it and what is going on and the repercussions.

They are also coordinating and in liaison with the technical area that has the technical program that they are trying to get her through, which in their minds is going to cure her.

Everyone knows — I believe there is also testimony on the — during the time period that Lisa was going through this trouble, Mr. Miscavige was there. We would often go to the Flag Service Organization, to inspect it, to make sure it is running properly, to make sure this technology is being applied 100 percent standard.

Q What are you relying on when you say Mr. Miscavige was at the Ft. Harrison Hotel in this time period?

A I believe some — a public person who — I don’t recall the name right now — something that I read mentioned the fact that he was there. And — he was at post.

Q This public Scientologist saw Mr. Miscavige?

A Yes.

Q Was that in the police files of the Clearwater Police files?

A Yes.

Q Okay.

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A So your largest income-making —

THE COURT: Where is that?

MR. DANDAR: I have it. I’ll introduce it, Judge. In fact, I have it on my computer. I’ll print it out on my next break.

THE COURT: Okay.

MR. DANDAR: It is Detective Carrasquillo of  the Clearwater Police Department interviewed four, I  believe, public Scientologists staying in the  cabanas who heard nothing during this time period,  who saw Mr. Miscavige —

MR. WEINBERG: Excuse me, your Honor, is Mr. Dandar testifying? Or is he asking questions?

THE COURT: I just asked him a question. He’s responding to me. I was saying —

MR. DANDAR: It is a four-page document. It’s on my computer. I can print it out.

THE COURT: Okay.

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

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BY MR. DANDAR:

Q Okay.

A And I am saying here today — and the reason I came to that conclusion — is by their own written policies that they have written here, you start to see violations.

And the reason why is because there was a problem. There was a legal threat. Lisa was not cooperating with them. When I did the introspection rundown on the other girl, she was cooperating. She wasn’t trying to leave. She
was going along with it. She never mentioned that she wanted to leave at any other time. There is a big difference.

So now you have a person that wants to leave, has publicly stated they want to leave to their friends, to their family, to the auditor. That is a no-no.

Q How did you —

A Again, there is reference where a person wants to leave is psychotic. So now they have put this label on her. She’s locked in a room. She’s terrified. Instead of taking her to the hospital when she was sick and letting her get
treatment because of her state of mind and because of the way she felt about Scientology, they opted to just continue the process, and either it works or it doesn’t.

Q Well, Heather Hof, who was a 17-year-old ethics officer, or studying to be an ethics officer, inspection

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reports, all her records, are missing. She testified in deposition that she hand-delivered her reports to Mr. Kartuzinski, saying as early as December 2, I believe, Lisa McPherson wasn’t eating or drinking enough to survive,
something had to change, Heather was frantic. The —

MR. WEINBERG: Your Honor, objection. He’s just testifying. This isn’t a question. This is just Mr. Dandar summarizing — and I would say missummarizing — what he thinks the testimony has been. It’s not a question. It’s a statement.

THE COURT: Well, I suspect that he’s saying,  “Mr. Prince, if this is her testimony.” That is what you do with an expert sometimes. So if that is what he’s doing, I’ll allow it, I guess, with the question.

BY MR. DANDAR:

Q So I’m assuming I’m accurate in my recollection of what Heather Hof testified to the police, as well as her deposition in this case, and the pathologist retained by the estate, that Lisa was in a coma that she could be shaken out of but she would go back into, five days — the last five days of her life. And in reading — in what you know and reading what you just told us you read, why is it your opinion that they would just simply let her die rather than take her to the hospital?

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A Because she was not settled with her relationship with Scientology. And this would have caused tremendous problems for them. If they would have taken her — you know, even during the period of time when she was going in  and out of the coma and say she goes to the hospital now, she starts getting treatment, she’s getting better, you know, Scientologists come around, she now tells the doctors, “No, I don’t want to see them anymore, I have to get away  from this.”

Q Mr. Prince, I guess the crux of the matter is you — you put together an affidavit that is dated August of 1999. Do you recall that?

A Yes, I do.

Q Where you talk about the role of David Miscavige and Mr. Mithoff and Marty Rathbun and your prior history in RTC. Do you remember that?

A Yes. I do.

Q And in that affidavit you have come to the conclusion that the three of them just decided to sit around and not do anything about it and end cycle Lisa McPherson?

A Yes. If she dies, she dies. If she gets better, she gets better.

Q Now, did I help you write that affidavit?

A Not at all. This affidavit came about because — from studying all of the evidence. And I spent months

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studying this to come to this conclusion. This conclusion I  came to was my personal opinion, I stated it as such, based on the experience I have within that organization.

And the thing that — that became alarming to me to even point me in this direction is the amount of information that is missing, the amount of things that — that isn’t there that would clearly show like what her state of mind was based on what she was saying. All of that is missing. Which means cover-up. Which means something is hidden. Why is something hidden?

In my mind, similar to what happened in Wollersheim. This is information, if gotten out, could be harmful or damaging to Scientology. And Scientology, the survival of Scientology, is first and foremost in the mind of any Scientologist, even beyond their own lives.

Q Did Stacy Brooks put you in the mood to write this affidavit? Did she kind of persuade you to write this affidavit?

A No. Put me in the mood? I guess I didn’t understand.

Q Okay. Did she influence you in any way whatsoever to get you to write this affidavit where you conclude that Mr. Miscavige and others had decided to issue the end cycle order?

A No. Matter of fact, Stacy disagreed with my

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opinion about that. She disagreed with it. But — and we’ve had discussions about this.

I mean, you know, I did it outside of her. Stacy was nowhere around when I did my affidavit. And she asked me why I came to that conclusion. I mean, we’ve had in-depth conversations about that, because Stacy was not in the position I was in to be able to make that determination.

Q Did anybody — let’s even go to Bob Minton. Did Bob Minton suggest to you, order you, tell you in any way, shape or form what to put in that affidavit?

A No. Bob Minton was so disrelated from anything that I was doing in this case.

Q Really? How so? I mean, wasn’t involved at all?

A Bob Minton never cared about the particulars that was going on in this Lisa McPherson case. He never concerned himself with that.

His words to me were, “I have hired Ken. He’s got the money. He’s the best one that — the best lawyer I could think of to do it. It’s his job. It’s his responsibility.”

Q Did Bob Minton say he hired me, Ken Dandar?

A No. No. He just said you were the attorney of record. He trusted you. You could —

Q Did you ever hear Bob Minton say to you, or to me in your presence, that — ordering me to charge David

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Miscavige with — in the civil case with murder?

A Absolutely not.

Q Did anyone — maybe I haven’t mentioned the right  name, I don’t know. Let’s just cover the whole waterfront.

Is there anyone that gave you direction or influenced you in any way on how to write that affidavit and what conclusions you reached in that affidavit?

A None at all. No one.

Q Now, the only other end cycle orders you have seen when you were in RTC, did they only have to do with people who had a terminal illness?

A That is correct.

Q Did you ever come across another circumstance like Lisa McPherson where an end cycle order was given and the person did not have a known, medically diagnosed by a licensed medical doctor, terminal illness?

A No. With the exception of what I told you about John Nelson, of course.

MR. DANDAR: All right. Judge, just in case it is not present, I just want to go ahead and I marked this affidavit that we’ve been talking about as Plaintiff’s Exhibit Number 126. And I’m sure you have so many copies of this already.

THE COURT: Is this the one that is 108?

MR. DANDAR: No. That is the PC folder one,

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THE COURT: Oh, okay.

MR. DANDAR: This is the one that talks about end cycle.

THE COURT: All right.

MR. DANDAR: This is what Paragraph 34 of the fifth amended complaint is dependent upon. I would like to move 126 into evidence.

MR. WEINBERG: It is already in evidence, but —

THE COURT: Yes, it is in, but we’ll let it in again.

MR. DANDAR: Somewhere. I’m not sure where.

BY MR. DANDAR:

Q Now, Mr. Prince, do you recall seeing, in the deposition testimony of Judy Goldsberry-Webber and Dr. Houghton and Kartuzinski, that liquid injectable Valium was picked up twice, two separate times, at two different places for Lisa McPherson?

A Yes.

MR. WEINBERG: I object. This just isn’t proper. Do you recall seeing somebody else’s testimony? I mean, we should be asking Mr. Prince about his testimony, whatever it is, not what he recalls somebody else’s has testified to.

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THE COURT: Well, if he read — just remember, Mr. Prince was his consultant. If he read some of these depositions in some fashion to assist him with his testimony, I mean, I already heard him talking about Valium which he thought —

MR. WEINBERG: Which was never given to Ms. Lisa McPherson.

THE COURT: Well, I know that. But we want to listen to what it is he says.

MR. WEINBERG: Okay.

THE COURT: I know that. And I know Kartuzinski was the one who said, “No, we don’t use Valium.” So, I mean, I know this case a little differently from what Mr. Prince does. But I haven’t been to all of the depositions and I haven’t read all of the depositions. But I know what I know from this hearing.

MR. WEINBERG: All right.

THE COURT: And that is that Dr. whatever his name is prescribed the Valium.

MR. DANDAR: Minkoff.

THE COURT: And Kartuzinski said no. That is all I know.

BY MR. DANDAR:

Q Mr. Prince, can you tell us how it is that the

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organization works where if Dr. Minkoff, as he testified, ordered injectable Valium twice for Lisa McPherson, how would the org go about procuring that Valium from a public drug store?

A Well, you would have to use — you know, Scientology in itself is a closed system to that degree because it does disagree — seemingly disagrees with psychiatric medicines, the use of psychiatric medicines.

However, in — in the case of introspection and a person that is psychotic, there are references of using drugs to treat those people.

But Scientology would only go to another Scientologist who would have that same understanding that would provide what they needed because they are kind of like on the same track. I have never seen it work where a doctor outside of Scientology would do that.

Q Well, how does the organization work to go about getting the money approved to push the prescriptions?

MR. WEINBERG: Well, I’m sorry to interrupt.  But he’s asking how Flag would have gotten the money in 1995 or whenever it was. He wasn’t there. He wouldn’t know that.

THE COURT: Well, he can testify as to what he knew when he was there.

MR. WEINBERG: In 1982? I mean, it’s just —

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okay.

THE COURT: I mean, he — this is what he based his opinion on. If it had to do with 1982 we just have to take that into consideration.

A Well, there is a simple answer to the question because it’s a Scientology policy, it’s called CSW, completed staff work. Whenever the organization is expected to — is expected to finance or pay for something, a document is submitted that — to the person senior and financial persons within Scientology that explains what the situation is, what the handling of it is.

If the situation is a person is psychotic and — you know, and in need of drugs, according to this reference, and handling is to buy the drugs, and then this is okay and they sign it and that gets passed along, the drugs are purchased.

BY MR. DANDAR:

Q So it gets passed along to who?

A If it was an emergency CSW, which would be accompanied with a purchase order, if it is an emergency CSW with an accompanying purchase order, it would normally go from the person who originated the CSW, to his immediate senior, to the commanding officer or whoever that person designated to be in authority to instantly approve moneys expended by the organization.

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Q And have you seen a CSW for any of the prescription drugs purchased for Lisa McPherson?

A No, I have not.

THE COURT: What was the CSW again?

THE WITNESS: Completed staff work.

THE COURT: Thank you.

BY MR. DANDAR:

Q If — if the pathologist retained by the state who say that she’s in a coma, it was obvious for five days that she wasn’t getting any better, she was getting worse, if Heather Hof, in my recollection of what she said, is correct
that she was — Lisa was getting worse as early as December 2, if that is all true, is there any other explanation that you can think of that would explain why nothing was done sooner for Lisa McPherson?

MR. WEINBERG: I object to the form of the question, your Honor, as a completely improper hypothetical.

THE COURT: Overruled.

A You know, again, I have studied for 16 years these issues, this stuff with red writing, this stuff with black writing, called staff writing; the only — this is the way I opine this way, the only reason she would have been treated
this way is because she was a threat to Scientology.

And Scientology has a principle called the

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greatest good for the greatest number of the dynamics. The dynamics being the different areas of life that L. Ron Hubbard codified or, you know, decided this is the way it was.

In Scientology, the overriding principle is to protect Scientology. That is the greatest good. For her to go in a bad condition to the hospital, complain of what Scientology did to her, to create bad publicity for them, possible lawsuits, possible investigation by law enforcement because she was incarcerated, held against her will, was not anything anyone wanted to deal with.

BY MR. DANDAR:

Q How could letting someone die be less of a PR flap than taking them to the hospital while they are alive?

A Well, I think it is an empirical fact, because it wasn’t — it was virtually unheard of until a year after her death. When you do enough cover-up — I mean, you know, not until a year after her death was it even known what happened to her. So it worked for a while.

Q Okay. Let’s go to —

THE COURT: I have just got to ask a question there. And I had so many but I didn’t want to interrupt Mr. Prince.

She went straight to the medical examiner.  Right? I mean, from the hospital to the medical

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examiner?

THE WITNESS: Right, with meningitis.

THE COURT: Well, whatever. There is a medical examiner who is the one that determines cause of death in this city.

THE WITNESS: Correct.

THE COURT: If she had been stabbed, if she had been dehydrated, if she had been shot, whatever it is, you take a dead body to the medical examiner when they are not under a doctor’s care for the medical examiner to say what is the cause of death.

THE WITNESS: Correct.

THE COURT: Right?

THE WITNESS: Correct.

THE COURT: I don’t know how long it took her to do her work. But the deal was as far as the Church would be concerned, she was delivered to the medical examiner to determine cause of death. Right?

THE WITNESS: Yes.

THE COURT: So any delay was occasioned apparently by some difficulty in determining what was the cause of death. And some disagreements in sending off lab tests and all that sort of stuff. Right?

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THE WITNESS: Yes.

THE COURT: Okay. So — so as far as the Church is concerned, Dr. Wood or whoever was going to do the autopsy might have known what they saw in two days.

THE WITNESS: Well, I don’t believe —

THE COURT: I mean, they have no way of knowing that, that they couldn’t just cut her open, look, say, “Whoops, there is a blood clot, this was caused by dehydration.”

THE WITNESS: Well, wasn’t it after the criminal case got started that Mrs. Wood went on national TV and spoke about dehydration and all of these things? Wasn’t that —

THE COURT: It may have been. But the fact of the matter was, is within a matter of however soon they got to this body, depending on how many bodies they had —

THE WITNESS: Right.

THE COURT: — somebody did an autopsy, you know, did an autopsy.

THE WITNESS: Correct.

THE COURT: Dictated findings, and eventually this was put into an autopsy report. And Dr. Wood apparently did go on nationwide TV at some point in

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time later.

THE WITNESS: Right.

THE COURT: But, I mean, it still goes without saying that there would be no way for the Church to know what was going to go on at the medical examiner’s office.

I mean, gosh, they could have said she was stabbed. They may have been wrong. But there is no way of knowing, when a body is taken under unusual circumstances, anybody not under a doctor’s care, where a doctor signs off, like in a — in a — and a medical examination is done, an autopsy is done, there would be no way for the Church to know what the ultimate result was going to be.

Why, look at all of the flap now about the different autopsy reports and what have you.

THE WITNESS: Right.

THE COURT: Right?

THE WITNESS: I agree with you wholeheartedly.

THE COURT: So this has been my problem all along is that you talk about a bad public relations flap.

THE WITNESS: Right.

THE COURT: Well, a death, for heaven sakes, brings about a lot worse public relation than

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somebody who goes to the hospital and says, “I was kept there, I didn’t want to stay and they brought me here but I want to go home and I don’t want to be here” and some charges are brought because of that.

THE WITNESS: Well, your Honor —

THE COURT: Which they can defend on the way by saying this was a religious — she was a member of the Church, this was the way we handled this. That would have been the defense.

THE WITNESS: Right. And I — and I beg to differ with you on the fact that it was more convenient to take her to the hospital as opposed to take a dead body there.

THE COURT: I didn’t say convenient. I said it would be a — it was a worse public relations flap to have had Lisa McPherson die at the hotel under the care of the Church of Scientology than it would have been for Lisa McPherson to have gotten well in the hospital, having been taken there by the Church of Scientology and had her say, “They held me there and I wanted to leave and they wouldn’t let me leave.” That would have created less of a public relations flap.

THE WITNESS: I beg to differ, your Honor. And the reason I beg to differ is again, like I say,

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this person has just attested to being almost superhuman. This person has been in the community here in Clearwater. She worked on public relations, on behalf of the Flag Service Organization, setting up the Christmas dealies. She was part of the OT committee whose responsibility is to interface Scientology with the community. Lisa was not a low-profile, no-nothing nobody-person.

THE COURT: I understand that. But here we are, we are in this hearing, it is the seventh week of this hearing. This case has been going on seven years. There has been no good publicity that has come out of it, presumably, for the Church of Scientology.

All this would have been avoided if they had taken her to a hospital if it had been something that they would have known, they took her to a hospital, and had she said, you know, “Those folks were holding me against my will,” and they just said, “No, she was there on introspection rundown,” that would have been litigated, long over.

Do you think, in the long run, it would have been less of a public relations flap?

THE WITNESS: Let’s take another perspective of it. If it had gone along as Scientology planned, if

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my contention there was a cover-up and they were successfully able to cover up and this girl simply died of embolism, well, who cares? Okay, well, so, you know, another dead person.

But if this person came and said, “Hey, look, I have been in here, they have held me, these people have jumped on me, forced drugs down my throat, they shoot me up with needles,” you know, I know that — that they said they never used Valium. I’m sorry, I disagree. I have been through these introspection rundowns. The instant they give that stuff — they give it to the person because they can’t sleep.

Otherwise, they are up all night. What they call it is a free will or the person simply cannot sleep so they are giving her drugs to make them sleep. Why would you get the same drug two times and not use it?

THE COURT: A person that can’t sleep is the person that is psychotic in a very hyperactive state. Right?

THE WITNESS: Correct.

THE COURT: So, consequently, you would concede that Lisa McPherson was, in fact, in a very psychotic state or she could have slept just fine.

THE WITNESS: Something caused her not to

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sleep.

THE COURT: Right. Which, of course, if she was in a psychotic state — now we are back to that situation where it would have been fairly dangerous for them to let her walk out the door, which —

THE WITNESS: You know, as far as her being psychotic, your Honor, I feel we can only speculate about that, because she was never taken to a doctor and diagnosed as being psychotic when they say she was psychotic.

THE COURT: Then she wouldn’t have needed Valium to make her sleep, would she?

THE WITNESS: No.

THE COURT: I mean, you can’t have it both ways.

THE WITNESS: Well, you know, your Honor, I’ll be quite honest with you. Before I came in here —

I’m tired now because I wasn’t able to sleep that well, and I’m sure this will go on until I’m finished. So I don’t know, six to one, half dozen of another to me.

THE COURT: All right.

BY MR. DANDAR:

Q Have you ever in your experience seen drugs like Valium or chloral hydrate given to a Scientologist so they

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don’t leave?

MR. WEINBERG: Can we limit it to one or the other?

A No, I have not.

THE COURT: So you have never seen Valium given to a Scientologist?

THE WITNESS: Because they want to leave?

THE COURT: Because they want to leave?

THE WITNESS: No.

THE COURT: Because they were sick?

THE WITNESS: Because they were —

THE COURT: Psychotic?

THE WITNESS: Yes, ma’am.

THE COURT: When was that?

THE WITNESS: Again, this girl, Terese —

BY MR. DANDAR:

Q Teresita?

A Teresita. Again, she, you know, literally fell off the chair and started doing her thing. And I think one day passed and she wasn’t sleeping, and immediately Dr. Dink was contacted. You could literally see her dying in front of your face. She was just burning up. It was one of the most amazing things to see, kind of like the person caves in on themselves, they just kind of fall in, you know.

And this started happening to her after she hadn’t

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slept for two and a half, three days. And she came out and she was given an injection.

Q Did you —

THE COURT: Was it Valium? That is the question.

THE WITNESS: Your Honor, I couldn’t speak truthfully as to what the injection was because the doctor was there, he injected her, and I know that within an hour, hour and a half, she was asleep.

THE COURT: So in truth now, Mr. Prince, you can’t testify in this courtroom that you ever saw Valium given to someone because they either wanted to leave or because they were psychotic; you don’t know what the psychotic person was given?

THE WITNESS: Correct.

THE COURT: Okay.

BY MR. DANDAR:

Q Mr. Prince, did you have to assist Teresita in eating and drinking?

A Yes, I did.

Q How did you do that?

A I would just gently talk to her and tell her that it is important for her to eat if she wants to get well. I would tell her the case supervisor has said you have to drink X amount a day. Would you please do it? Just trying

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to get her cooperation.

Q Could she do it by herself?

A No.

Q So how did you do it?

A Oh, I thought you asked me would she do it by herself.

Q Right. Did she pick up the water and drink it by herself?

A Yes.

Q And the food, did she eat it by herself?

A Sometimes I had to take a spoon and put it to her mouth and watch her chew, you know, and, “Did you eat it all,” you know. That kind of thing.

Q All right. Your opinion that Lisa McPherson died because of an end cycle order, an order just not to do anything for her —

A Correct.

Q — is that opinion based upon because you hate Scientology? Or is it based upon something else?

A For one thing, I certainly do not hate Scientology. I don’t hate anyone or anything.

My opinion is based solely on personal observation, personal experience. I give it as an opinion. I say why. Maybe I haven’t said it as clearly as I need to, but it is so important for Scientology. And, you know,

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especially Clearwater is considered a hostile environment.

I mean, I have been here when half the city of Clearwater were picketing around the Ft. Harrison with Michael Flynn.

I mean, I have seen and been involved in trying to make this a place where Scientology could comfortably be and the environment would be comfortable with Scientology.

So, no, I don’t hate Scientology. I was a Scientologist myself for sixteen years. You know, I had a firm belief in what I was doing. I have since become disillusioned with a lot of that. But my motive certainly isn’t hate.

Q Now, Mr. Prince, there came a time when the Lisa McPherson Trust was formed. Do you recall that?

A Yes, I do.

Q And after you finished working for me full-time, you went to work for them full-time. Correct?

A Yes.

THE COURT: You know, on some of these things you really are going to have to stop leading him.

That is one of the issues that is an issue here. So don’t ask him a question and then say “Correct?”

MR. DANDAR: Okay. All right.

BY MR. DANDAR:

Q Mr. Prince, were you ever with Bob Minton when he talked about giving money to me for the case?

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A I have been with Mr. Minton a couple of times, yes. Two or three. Yes.

Q I want to direct your attention to May of 2000.

A Okay.

Q All right?

A Yes.

Q Do you recall any incident where Mr. Minton talked to you about giving money to me?

A Around that exact time period, Mr. Minton made it known to me that you needed more money to bring this case to trial. He had thought in his mind that he had given enough money already and, you know, it could have went to trial or whatever.

But he was concerned about the repeated motion and — motions and on and on, just the cost of the case from the filings and things, that he asked me to go over there and look into, well, what is coming up now, I mean, what can we look forward to now?

I think at that time you were working on an accident reconstruction. And Mr. Garko was talking about doing a jury pool survey or something. And these were going to be additional expenses that would be needed, you know, as
well as whatever else came up to take the trial — take this case to trial.

And I remember going back and speaking to him about that. And he wasn’t very happy about that. And then

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he — he — he went away — he came into town. Mrs. Brooks  and I were working at the LMT. And he came and he said, “Come here, you guys come out here,” because he had a fear that the building that we were in was electronically bugged.

And we got in Stacy’s car and we went into the city parking lot, which is directly across the street from the LMT Trust. Went to the very top where we could see.

And he said, “Look, I’m going to tell you guys, you can’t tell anybody this, Ken Dandar has more money, he doesn’t know where it came from. It came from Europe. You know, I told him, this is as much as I think I can get, I
hope this takes you to trial.”

That was in 2000. He told us that, you know, he didn’t want the office to know, you know, Ken didn’t want everybody in the office to know or whatever, but this $500,000 came. And — and, you know, everything with the case would be okay, basically, was the one instance.

The second instance was very recently, I guess in March of 2002 —

MR. WEINBERG: Your Honor, before he gets to the second incident, that happened when, the first incident?

THE WITNESS: May of 2000.

MR. WEINBERG: May of 2000?

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BY MR. DANDAR:

Q Did he say where this $500,000 came from?

A Europe. People from Europe.

Q Did he say to you it was his money?

A No. He said he had arranged from some people from Europe who made this money available.

Q Did you ever see that check?

A No.

Q Okay.

A Then the second instance was recently in March of 2002. He told me that, “Ken needs more money to finish this case and get this case to trial. You know, I’m willing to arrange to get him some money, but I have a problem with some people on the Internet saying bad things about him.

Could you ask Ken if there is any way if he has influence over these people to tell them to stop. And if you do, I’ll see if we can arrange to get him some more money.”

Q So what did you do?

A So I went and had that meeting. I went over to your office and I met with you. And I said, “You know, Bob thinks that he can get more money for you but he’s concerned about this matter. And what are you doing with that? Are you connected with these people, or are you — you know, are you encouraging them to do this?” You know, we had a bit of a conversation.

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And, Mmm, you said you knew nothing about it and had no control over those people whatsoever but, you know, you would do what you could to make it stop if that is what he was worried about, but it wasn’t anything you were  actively concerned in.

Q Do you know anything about the check I got after that?

A Mmm, I know at some point that you had gotten a check. And he called me and let me know that you had.

Q He did?

A Yes.

Q Okay. Did he say where that check came from?

A He did not.

Q Okay.

MR. WEINBERG: And the date of that — the date of the conversation with Mr. Dandar was, you said, March?

THE WITNESS: Of 2002. Yes.

BY MR. DANDAR:

Q Was this before, or after, I flew to Mr. Minton’s house?

A Before.

Q Okay. If I flew to Mr. Minton’s house February 22 of 2002, when would this conversation be that you and I had?

A So I think maybe a week prior.

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Q Okay. Were you aware that Mr. Minton —

THE COURT: So you are saying that was February of 2002?

THE WITNESS: Yes, your Honor.

MR. BATTAGLIA: Excuse me, your Honor, what was February of 2000?

THE COURT: 2002. This is when Mr. Dandar and this witness had a conversation.

MR. BATTAGLIA: Oh. Okay.

BY MR. DANDAR:

Q Now, I jumped — when you talked about that meeting, that kind of threw me off because that is two years after where I wanted to talk to you about. So let’s go back.

Do you know a fellow by the name of Patrick Jost?

A Yes. I do.

Q Okay. How do you know him?

A I know him because he was hired by Mrs. Brooks to specifically assist Mr. Minton to deal with allegations that were being stirred up by Scientology investigators in Nigeria and Switzerland.

Q What was he supposed to do?

A Mmm, Patrick Jost is multilingual. I think he speaks maybe four or five languages. Mmm, he’s also a person — ex-CIA, spent many years in Europe on behalf of

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the United States defense.

So he knew a lot of people and had a lot of contacts.

And he was supposed to go and find out where the trouble was originating from and try to deal with it accordingly.

Q Do you know if he was successful in doing that?

MR. WEINBERG: Objection, hearsay, your Honor.

THE COURT: Okay.

MR. WEINBERG: This whole thing is hearsay.

BY MR. DANDAR:

Q Did you — can you describe for us the demeanor of Mr. Minton throughout the years — almost two years that the Lisa McPherson Trust concerning the — what he perceived to be actions taken against him by Scientology?

MR. BATTAGLIA: I’ll object to that as being far too broad, demeanor over a period of two years.

THE COURT: Mr. Battaglia, much as I would like to let you object, I don’t think you have any standing to object in this hearing. This is a hearing between these two people. Your client is simply a witness. So I’ll simply ignore that.

MR. WEINBERG: You beat me to my feet because I was about to say the same thing.

MR. FUGATE: Stereo.

MR. WEINBERG: That is like asking for — I

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don’t know how you ask a question like that. His demeanor over two years?

THE COURT: I agree with that. It was a little broad.

BY MR. DANDAR:

Q Did Mr. Minton ever talk to you about what he felt concerning the Scientology investigation of him?

A Many times, to answer the question. And it wasn’t even the fact that investigations were happening. It’s the false information. The false information that was being provided to government officials in different countries,  unfounded allegations that were being provided, that disturbed him more.

And over time it became increasingly more evident that this was having more and more of an effect on him.

Q How did you pick that up?

A When I first met Mr. Minton, he was probably about 40 pounds lighter than he currently is. Just the nicest, gentlest, kindest person. I mean, I had never seen a person like him before. I mean, literally, who am I? Nobody.

But a person like that to come around in your life that just was — I don’t know — genuinely concerned about other people to the point of almost fault. And very — very kind. Very intelligent person.

I seen him go from that, to — to kind of being a

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person that is annoyed — kind of annoyed by what is going on, kind of — Mmm — annoyed with, you know, what is happening with his kids, you know, what is happening with his house, his phone lines, on and on.

Then I seen him go to a person that actually became very doubtful about what he was involved in, what he was doing. He seemed to be less confident as time went on that he would be able to do anything to restrain Scientology from exercising some of its practices that are detrimental to the general public at large.

Q Have you — are you familiar with the doctrine of Scientology called fair game?

A For sure.

Q Has fair game been canceled?

A No. It’s alive and well.

MR. WEINBERG: It’s what? I couldn’t hear.

THE COURT: Alive and well.

THE WITNESS: Alive and well.

MR. WEINBERG: And that is based on your —

THE COURT: Counsel, we’re going to let you ask that question later.

MR. WEINBERG: I will. I’ll withdraw it. I’m sorry.

BY MR. DANDAR:

Q Based on your expertise and experience in

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Scientology, did you personally observe any fair game practiced on Mr. Minton?

A Yes. I have.

Q Can you give us some examples?

A Mmm, leaflets passed around in Boston where his wife and children live, saying that he’s an adulterous, robbed the Nigerian children — the Nigerian people of moneys, this is a starving country. And — and kind of — he’s kind of somehow aligned with the KKK because he was attacking Scientology. Mmm, his children being followed around. You know, the whole Nigeria/Switzerland thing.

They used to meet him at every airport he went to, irrespective of any city, they would just show up and meet him and picket him at the airport. I have been with him when the police literally have to stand in the airport and hold Scientologists back from attacking him.

I have been with him in Boston where somehow Scientology OSA people had gotten a hold of his — his — his records, his counseling records when he was seeing a psychiatrist. And they started saying things to him that he said to his therapist, I know, that upset him extremely that it could even happen.

And the fact of the matter is that therapist decided to no longer see Mr. Minton after Mr. Minton went

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back and told him, “Hey, why are these guys saying this to me?”

Q This was a psychiatrist?

A Yes.

Q Of Mr. Minton’s?

A Yes.

Q So —

A And —

Q — he refused to see him after the records were made public?

A Correct. Or exposed. His position was exposed.

Q Okay. Did there come a point in time when Mr. Minton, in your presence, was — had any dramatic change in his emotions compared to the years that you have known him?

A Again, you know, what I said earlier. For sure, he changed. He became more of a somber person. He wasn’t as cheerful anymore. He was more serious.

And at some point it even got into, “Well, you know, they did this to me  so I’m going to go picket them. They did this to me so I’m going to go picket.”

You know, this is — was kind of like his last line of defense, as I testified the first day I came here, that he could possibly do, you know. “I’m just going to go picket. When they fool with my wife, I’m going to picket.

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When they fool with my children, I’m going to picket. What they are doing over in Nigeria, doing all this crap, I’m going to go picket.”

So he became increasingly despondent about that. And, you know, Mr. Minton takes medication. Not that there is anything wrong with medication, but sometimes he wouldn’t take it. You know, he seemed to just be extremely stressed.

And during the time periods when he didn’t take his medication, he would literally be in a state of collapse with just — crying uncontrollably and totally despondent.

I remember one time he told me he was going to kill himself. He was walking around in the woods with a gun, you know. 200 acres up there where he lives and it is nothing but beautiful woods in New England and he’s walking  around with a gun. He drove his car in the woods, got it caught on a tree stump and he’s out there in the middle of the night, with a gun, crying. You know, that has happened.

Q When did that happen, that particular incident?

A That was in the fall of 2001, I believe.

Q Okay. Do you have any knowledge concerning Stacy Brooks’ desire, in the summer of 2001, to go see Dell Liebreich to get her to drop the case?

A Yes. I do.

Q What is your knowledge?

A Mmm, Scientology had very effectively convinced

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the courts — and I’m not trying to cast any aspersions here — tried to convince the court that somehow the Lisa McPherson Trust had something to do with this Lisa McPherson case.

And this assertion, this stuff that had grew over the years, inextricably tied these two things together, which allowed a way to now do continuing discovery on Mr. Minton and Mrs. Brooks and other staff members that worked at the trust.

And this was something that he was very concerned about, because financially it was ruining the Lisa McPherson Trust to have a lawyer have to represent all of the staff members, you know, when they get deposed, and they’re away, and on and on and on. So —

Q Did there come a time when — well, let’s go back to the question.

Did there come a time when you had knowledge about Stacy Brooks wanting to go to Dell Liebreich?

A Yes. So because of that, you know, and there was more discovery by Scientology specifically on Mr. Minton’s finances, they were just narrowing down on that, which is pursuant to their policy here to cut off the funds, on and  on and on. They are on a systematic program.

One thing that can be said about Scientologists, they are extremely organized and they have resources to do

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what they need to do.

So Stacy thought that, you know, a lot of stress was coming because of this. So she thought, well, the only reason this is happening is because of this wrongful death case. So she decided to go visit with Dell Liebreich and ask her to drop the case because of what was happening with Bob Minton. And she decided to do this without Mr. Minton knowing about it.

And she consulted me on it and asked me, “Do you think he will be extremely upset if I do this?”

And I told her that I thought he would be extremely upset, you know, without talking to you about it and just go down there because there was no relationship.

Stacy had no relationship with Dell Liebreich. So for her to now — now come out of the blue and ask her to drop the case, it would be like a woodpecker coming along, telling me to pay my house rent or something, something as bizarre as that. So, you know, Stacy decided she was going to do it anyway.

She finally asked Bob Minton. And he said, “No, you don’t do it. You don’t do that.” She decided to do it anyway. She attempted to have a phone conversation with Mrs. Liebreich. And I think at that point, after Mrs. Liebreich spoke with Stacy, she then spoke with you and refused to speak with Stacy anymore.

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Q Are you aware of any instance where Bob Minton controlled the wrongful death case?

A Not at all. The wrongful death case was the last thing that Mr. Minton was interested in because he had turned it over to you, he felt you were a competent, honest attorney, and, you know, many arguments have happened  between Mrs. Brooks and Mr. Minton concerning the fact that she did not need to be involved in the case, or if there was a differing of opinion, to do what you say because you are the lawyer.

And, no, he — he — he never — Bob Minton was more concerned about what was going on at the Lisa McPherson Trust.There was a period of time, after we came into existence and actually established a phone number, that people just started calling like crazy. “Hey, can you help me with this? Can you help me with this? Can you tell me what is going on with my brother? He doesn’t speak to me anymore. Can you tell us what it means to be an SP? I need to get my money back from Scientology that I haven’t used because I have no life, I don’t have a place to live.” You know, all of these kind of phone calls. And we — we became extremely interested because after the trust was set up, it gave you a broad cross section of, well, what types of things do people need help

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with in relationship to Scientology?

So our job became, well, there is nothing we can do about it. If there is a criminal activity concerned, if there is any fraud that is concerned or bad business practices, at that point we started referring people to the responsible governmental agencies.

If you have a problem with them returning your repayment money, you refer them to the Consumer Fraud Department — Department of Agriculture, Consumer Fraud. If it is bad business practices, the Better Business Bureau. If it has something to do with money — the IRS could possibly be a person to contact if they are not getting satisfaction with known policies on giving money back. This kind of thing.

And we had nothing whatsoever — and the whole reason I stopped working in your office is that we had gone through deposing the majority of the Scientologists and Scientology witnesses. And you were going on to your medical experts. So there was no reason for me — I mean, I didn’t need to sit and listen to a medical expert being deposed.

So I worked at the trust. And this is kind of what we were doing. It was kind of like when you went off doing your medical people, we just forgot about the case.

At least, I did.

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Q So you actually did work at the trust in answering calls for people who needed counseling?

A Very much so.

Q You weren’t just waiting for the trial of the Lisa McPherson case to start?

A This trial — you know, as much as I’m willing to offer my services — help point out certain things, what happened with Mrs. McPherson was a very unfortunate thing but there are still a lot of people alive that needed help.

And that is where I went to — what I wanted to do.

Q What was my involvement with the Lisa McPherson Trust?

A Occasionally stop by to have dinner.

Occasionally, like maybe I think I maybe seen you there two times during its entire existence, maybe three.

Q Did I give any orders to anyone at the Lisa McPherson Trust?

A Not that I ever saw. It would be highly unusual if that happened.

Q Did I direct any of the picketing?

A No.

Q Do you know if I ever participated in a picket?

A No. You know, I was sitting here listening to testimony about that, and I listened with a sharp ear as Judge Schaeffer here mentioned the fact that you shouldn’t

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have been anywhere near picketing. And I think what may be kind of misunderstood here is the fact that the vigil is not — was not and never has been a picketing experience. The vigil is where the people come from all over, they light the candles, they — they do some Bible stuff, they sing hymns and they may place a wreath where she died at the cabana. That is not a picketing experience.

And that is where I have seen you with the vigils, along with the family. And you were there because the family was there.

Q Okay.

MR. WEINBERG: Your Honor, I have an objection.

In light of Mr. Prince’s last statement, he said he understood you had said certain things during the hearing? How would he know that if he was to be  excluded?

THE COURT: I am sure he read transcripts.

MR. WEINBERG: Well, but it is —

THE COURT: It would have been what he read or somebody told him, which would be inappropriate, too.

A I think it came up on the first day when I sat here in the courtroom giving testimony where you admonished Ken and pointed that out. I heard that direction from this

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seat.

THE COURT: I’m not excluding you from testifying if you read something or heard something.

THE WITNESS: Well, I’m just saying that is not the case. I heard it right here in this seat on the first day I was here.

THE COURT: You have to understand to the — to the rest of the world, if candles are being carried, signs are being carried, it is being done, the Church of Scientology — it may look and seem like a picket. A lot of folks have talked about it as being a picket.

THE WITNESS: Right. But at the vigil there are no signs, though.

THE COURT: Okay.

BY MR. DANDAR:

Q Now, did you ever hear Mr. Minton talk about the money that he gave me as — giving it to me or giving it to the estate? Did you ever hear him talk about that?

A I have. And what Mr. Minton has always said to me is he is giving this money to Ken to use on the case at his discretion. He’s loaning the money to Ken. That is what I heard.

Q Did you ever hear Mr. Minton write or speak about the LMT or Mr. Minton getting the bulk of any of the money

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that may be realized from the wrongful death case?

A The only time I heard that statement made was when Mr. Minton came back from a radio interview. And he was laughing. And he said, “Hey, you know what, I just went in there and said the bulk of the proceeds are going to go to an anti-cult group or whatever. And I know this is going to chap Scientology’s behind.” He was into that kind of tit for tat kind of thing.

Q Did you ever hear him talk about it in private or outside of the media’s presence?

A Well, you know, the particular time that I’m talking about was private, you know. And I — you know, I made the comment, “Really, you know, is that the way it’s going to go?”

He said, “Look, I’ll probably never see a dime from this stuff. I just said it.”

Q Okay. Did there come a point in time when  Mr. Minton started to express concern over the discovery by Scientology of a UBS check?

A What I recall about that, and I mentioned or made reference to it in the affidavit that I did, I guess the last one that I did, the April 2002.

He called me just in grief, crying. He’s like, “It’s over. They got me. You know, I’m going to jail.”

He’s just —

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THE COURT: Can we have a date on this? You want your last affidavit? I think it was in there.

THE WITNESS: Yes, it would probably be a week prior to the meeting that happened on March 28th. So we’re talking like maybe March 21st or something like that. You know, the week prior to going to New York.

BY MR. DANDAR:

Q All right, here is the April 2002 affidavit.2

A Okay.

MR. DANDAR: Judge, do you need another copy?

THE COURT: No. I know it is in evidence somewhere. If I need to see it, I’ll ask to see a copy of it.

MR. DANDAR: All right.

A So, you know, I immediately called Mrs. Brooks and —

BY MR. DANDAR:

Q Well, let’s back up.

Bob Minton called you up, crying, saying, “It is all over.” What else?

A He said that, Mmm, “I’m going to jail. I have been told I’m going to jail. They’re coming after Therese and the kids.”

And he was just completely despondent about that.

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Q And this was before the New York City meetings?

A Yeah.

Q Okay.

A Yeah. So then —

Q But he didn’t go into detail as to why he thought he was going to jail?

A No, he wouldn’t tell me then. I wanted to know, what is his new thing? What in the heck happened? What new thing has happened? He wouldn’t tell me.

Q Okay.

A Stacy, I called her to try to get additional information. She didn’t know what the heck had happened. But she knew she had to go up there. So she went up there that day.

Q To New Hampshire?

A Yes, to New Hampshire. Subsequent days, I got an idea of what happened. And it had no significance to me, I had no idea that this was a significant incident.

But he told me that Mike Rinder had somehow gotten a copy of a check, of the $500,000 check, and told him that he knew that Bob Minton lied in deposition about this $500,000 check and they had the proof and they were going to prosecute him on it.

Q Did Mr. Minton say he, Mr. Minton, also had a copy of this UBS check?

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A No. He said he didn’t know how they got a copy because he can’t get a copy of it. He said, “I tried. I can’t get a copy of it.” Somehow, they come up with a copy and show him.

And he was just beside himself.

MR. WEINBERG: Your Honor, could I ask, could we point out in this affidavit where this incident is that he’s just described?

THE COURT: Yes.

MR. WEINBERG: Because I don’t think it’s in there. They are saying something about a $500,000 check prior to the New York meetings.

THE COURT: You have your affidavit there in front of you?

THE WITNESS: Yes. I do.

THE COURT: See if it is in the affidavit, or if it is something not in your affidavit.

THE WITNESS: Okay. Okay, so here, if you turn to Page 3 of the affidavit, I started talking about what I’m explaining right now on the 20th of March, 2002.

THE COURT: What is this number?

MR. DANDAR: Paragraph 9.

THE WITNESS: Paragraph Number 9.

THE COURT: I don’t have it. Maybe I do need

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it. What is the number of the exhibit and I’ll have the clerk get it?

MR. FUGATE: I believe it is attached to Mr. Dandar’s response to our memorandum of fact and law. I believe that is where it is.

THE COURT: Okay.

MR. FUGATE: Can I give you a copy?

THE COURT: Yes, please. If you would, that would be great. I’ll give this back to you because I know it is in evidence or in the pleadings.

MR. FUGATE: It is in the pleadings, I believe, Judge.

MR. DANDAR: He’s reading from Paragraph 9 on Page 3.

BY MR. DANDAR:

Q Am I right?

A Yes. But, you know — yes, that was on Page 3, Number 9, during the time period, what I’m talking about
here.

And before I wrote this affidavit on the attachment, when I met with Mr. Dandar, I wrote on the first page that — that Scientology had gathered enough information about Bob Minton to get him prosecuted, convicted and jailed.

MR. DANDAR: He’s looking at his handwritten

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attachment.

THE COURT: Oh, okay.

THE WITNESS: Yes.

MR. DANDAR: The first page, the first paragraph.

THE WITNESS: Did I answer the question?

MR. WEINBERG: I asked you — I asked you, does it say in the affidavit about this conversation you supposedly had with Mr. Minton prior to the New York meetings where he told you that the Church had a copy of a $500,000 check, and he didn’t —

THE WITNESS: I don’t —

MR. WEINBERG: — have a copy and didn’t know where they got it.

THE WITNESS: I’m sorry, I don’t mean to cut you off.

I don’t mention the check specifically, but what I mention is, is the information that Scientology had gotten, information that said they were going to get him prosecuted and put in jail.

You know —

BY MR. DANDAR:

Q Paragraph 9, do you talk about the conversation — the first conversation where he’s crying?

A Yes. They discovered information about him that

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threatened his wife and children’s future. You know, again,he’s suicidal. And then —

THE COURT: In your handwritten notes it appears that you are talking about this — this information before Paragraph 3 which deals with Bob Minton and Stacy Brooks flew to New York.

So I presume you were discussing — or you — your notes indicated that occurred before the New York trip?

THE WITNESS: Yes.

THE COURT: I don’t think it is very clear, certainly, in the affidavit, but he says that is what he’s talking about.

THE WITNESS: Well, you know, your Honor, I really did try to do the best I could. This is a very disturbing time for me, too.

THE COURT: There is nothing that says that you have to speak to every word of your affidavit. You can expand on it. If that is your testimony, that is fine.

THE WITNESS: Thank you. And, you know, in the days between the New York meeting and the 20th of March that I noted here, which is where I came to find out, you know, what is this. Because Stacy flew there. And after she was there, I let her, you know, get settled.

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And then he’s telling me, you know, they have got this check. And, you know, and he says — basically, it’s come down to me or Ken Dandar, somebody has to die here.

And I’m like, you know, this was such a complete turnaround. These are people I worked with now for years. We have all been on one accord, doing what we thought were good work. Suddenly now Mr. Minton has to turn on Ken Dandar.

BY MR. DANDAR:

Q And did you have any further conversation in that phone call with Mr. Minton?

A Well, he informed me —

THE COURT: This is the phone call before –you are saying this is the phone call before the first time Mr. Minton and Ms. Brooks went to New York?

THE WITNESS: Yes, your Honor.

THE COURT: We’re going to finish that phone call, then we’ll take a break.

THE WITNESS: Okay.

MR. DANDAR: All right.

A Yes. He said he didn’t feel safe about discussing the information over the phone, he was too upset to talk about it.

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MR. DANDAR: All right.

THE COURT: Did you say this was about a week before the trip to New York?

THE WITNESS: Yes, your Honor. I said on or around the 20th of March. And the trip to New York was the 28th of March.

THE COURT: Okay.

THE WITNESS: The 28th and 29th of March.

THE COURT: Let me just say this about affidavits. They wanted me to sign an affidavit of borrower to buy my house. And I refused to sign it without — I said, “I’m not going to sign this without this and this and this and this.”

And finally they just said, “Well, we’re going to throw it out. It is not that important.”

I said, “Well, good.”

All this, and affidavits. It makes me very nervous. You know, some things might not have made me so nervous.

BY MR. DANDAR:

Q Anything else on that phone call with Mr. Minton before we take our break?

A Mmm, you know, again, starting on March 20th until they actually went to New York, there were many conversations. You know, I don’t want to give the illusion

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this just happened one phone call and suddenly they were in New York.

THE COURT: Let’s go ahead and break and then we’ll start with — if you want to go into the other phone calls before New York. All right?

MR. DANDAR: All right.

THE COURT: We’ll be in recess until 3:15.

(WHEREUPON, a recess was taken from 2:55 to 3:15 p.m.)
______________________________________

THE COURT: All right. You may be seated.

MR. FUGATE: Your Honor, before we begin back again, on May 13, 2002 we had filed a request to produce to Mr. Dandar for all financial records of payments to Jesse Prince, including bank records and checks, all W2s, 1099s, and any other tax form issued from Dandar & Dandar for Jesse Prince for tax years 1999, 2000 and 2001. It was never responded to.

I think it is now relevant, based on the testimony elicited, that that be produced, or at least responded to that was filed May 13th of 2001 (sic).

MR. DANDAR: Didn’t we respond to that?

THE COURT: Had you responded to this?

MR. DANDAR: We produced at the time they took

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Jesse Prince’s deposition — he’s no longer working for me — all of the W2s, 1099s, all of the checks we wrote. We did not respond to that one.

THE COURT: Is there anything additional?

MR. DANDAR: I’ll have to check. I’m sure — you know, since I brought him back on board as my expert, yes, I paid him since then. So there is something additional. But not back on May 13.

THE COURT: You don’t need him to regive you what he has already given you.

MR. FUGATE: No, I’ll go verify what we have and compare that to what he gives us. But — but he needs to respond. And he needs to give us —

THE COURT: I’m not going to require you to give him what he gave you already. So if he gave you stuff for the depositions —

MR. FUGATE: I’ll check that tonight.

THE COURT: Then you must give him whatever else there is.

MR. DANDAR: I will.

THE COURT: Try to have that to him by the morning. All right?

MR. DANDAR: All right.

THE COURT: You may continue.

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BY MR. DANDAR:

Q Okay, Mr. Prince, following that telephone conversation, which you said was on or about March 20, 2002 with Mr. Minton, did you have any more conversations with him before he went to see Mr. Rinder and Mr. Rosen in New York City?

A Yes, I did. I may have had maybe three to four conversations with Mr. Minton and Mrs. Brooks concerning this. Yes.

Q Before the New York City meeting?

A Yes.

Q And what was your relationship with Mr. Minton at that time?

A Mr. Minton was a good friend of mine. A person that I trusted. You know, we worked together.

Q Okay. Did he confide in you?

A Yes. On some things, he certainly did.

Q And some things, he didn’t?

A I can’t say that he confided in me on everything. But I know some things he did.

Q All right. For instance, when he talked about somehow this check was going to make him and his wife go to jail, did he confide in you what it was that they got — this new thing in the year 2002 that caused him to think he was going to go to jail?

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A You know, he said that they got a copy of that check, that — Mmm — that he — you know, had given different testimony, I think, in a deposition or something.

And this is what was going to — this is how they were going to put him in jail for perjury.

Q And did he — all right. Did he go into more detail how that was going to be perjury?

A Because he said that he had given testimony contrary to — you know, in other words, this check, this $500,000 check, came from him, apparently, not people from Europe. Scientology had discovered that. And they were going to use it to get him convicted for perjury.

Q Did you ask him why he lied to you and told you that check was from people in Europe?

A You know, that was a very good question that I should have asked. But at the time this was all new news to me.

He’s telling me, you know, “Oh, well, it came from me, it didn’t come from him. Now I’m in trouble and now they are getting ready to depose my wife Therese and bring her in on all of this stuff.”

And in the heat of the moment, the panic of the moment, I’m sure I didn’t ask, you know, all of the right questions. But no, I didn’t ask him that specific question.

Q During those three or four other telephone calls with Mr. Minton before the New York meeting he had with

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Mr. Rosen and Mr. Rinder, did Mr. Minton tell you how it was that Scientology can find out that this bank check from UBS that doesn’t have his name on it came from him?

A The only comment he said was he had no idea how they possibly got a copy of that check because he himself did not have a copy, nor did he know how to obtain a copy.

Q Did Mr. Minton ever mention to you anything about Swiss prosecutors during — before the New York meeting?

A Yes, he did. He told me that there was yet another action being contemplated by a prosecutor in Switzerland. And it was my understanding that this had something to do with Nigeria but I’m not sure. You know, I don’t know the details of it.

Q And he told you this in March before the New York meeting?

A Yes.

Q Now, isn’t it true that before Minton called —

MR. WEINBERG: Object to the form to the question, “Isn’t it true.”

THE COURT: Yes, “isn’t it true” is suggesting that the answer to that is yes. I mean, I don’t know what the question is, but I know what the answer is. That is what the leading part is.

BY MR. DANDAR:

Q What was your understanding, Mr. Prince, of the

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status of the Swiss prosecution concerning Mr. Minton prior to Mr. Minton’s frantic calls to you in March of 2002?

MR. FUGATE: Objection, hearsay. Or at least the basis for this statement, “What was your understanding.”

THE COURT: If it came from Mr. Minton, he can answer. If it came from somebody else, then I am not sure you can answer.

BY MR. DANDAR:

Q From Mr. Minton.

A Mr. Minton told me they were going to prosecute, going to file charges.

THE COURT: In Switzerland?

THE WITNESS: Yes.

BY MR. DANDAR:

Q When did he tell you that?

A Mmm, at one of the phone conversations between the 20th and 28th of March.

Q Well, my question is prior to that, had you ever heard from Mr. Minton about Swiss prosecutors?

A Oh, yes. I mentioned that before.

Q Right. And what was the status of the Swiss prosecution prior to you getting this call —

A These phone calls? Oh, I thought it was over.

Q What made you think that?

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A Because Patrick Jost had went over there and talked with people.

There was one other thing that was pending which, when Scientology got the bank records for the Bank of America, somehow the Bank of — someone in the Bank of America in Europe, some executive or some banking official, had did something that was improper concerning either divulging or passing along information about Mr. Minton’s accounts. And Mr. Jost was over there to pursue that.

MR. WEINBERG: Objection. Hearsay as to any conversations with Mr. Jost or anybody else. If he’s saying this is something Mr. Minton said, I would appreciate if he could date it.

THE COURT: Is this something you learned from Mr. Minton?

THE WITNESS: Yes.

THE COURT: Okay. Could you tell us about when that was?

THE WITNESS: Mmm, gosh. This — this would have to be in the fall of 2001. Maybe October, something like that.

THE COURT: As best you can remember?

THE WITNESS: As best I can recall, yes.

BY MR. DANDAR:

Q All right. What was it the Bank of America

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official in Europe did improperly, according to Mr. Minton, what he told you?

THE COURT: Does this have something to do with this Swiss prosecution?

MR. DANDAR: I don’t know.

A This has something to do with when the bank records were obtained by Scientology here, the Bank of America somehow simultaneously did something — something happened in Europe, as well. I think they used the fact they had these records to get information that they were not supposed to get, they made it appear like the Court sanctioned them having this information or it was proper for them to get the information, when it was not.

BY MR. DANDAR:

Q How did Mr. Minton react to them getting this information in Europe?

MR. WEINBERG: Objection. Your Honor, this is hearsay based on hearsay. It is speculation. Then the question is how did they react to the Church supposedly getting this information in Europe? What information in Europe? What is he talking about? This is just hearsay.

And, you know, Mr. Minton testified. Mr. Dandar had an opportunity to ask Mr. Minton about this. He didn’t say anything about this,

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about this accusation or anything like this. He didn’t even ask him the question.

THE COURT: Overruled. This bears on Mr. Minton’s state of mind, anything Mr. Minton may have said about what he thought was going on, what the Church knew. Remember, we had a lot of this, as I tried to explain.

MR. WEINBERG: I object more to the form of the question. When he said the Church did such and such at such and such a time, it is just an improper form, I think.

MR. DANDAR: It is based on the witness’s answer.

THE COURT: Right.

A He was very distraught and upset that this had happened. You know, he felt like that there was no one that could be trusted or no one who was impervious to Scientology’s ability to penetrate and get information that they should necessarily have.

MR. WEINBERG: Your Honor, just for the record, so we are talking about now the fall of 2001 that he’s distraught?

MR. DANDAR: Yes.

THE COURT: Is this —

THE WITNESS: Yes.

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THE COURT: The same October period of 2001?

THE WITNESS: Yes, your Honor.

BY MR. DANDAR:

Q And even — did you have any conversations with Mr. Minton in January or February of 2002 before you had this — what you described as this March 20 — the first call in 2002?

A Conversations concerning?

Q Mr. Minton’s well-being, his mental state?

A Well, Mr. Minton — back in the fall of 2001, we decided that we could no longer operate the Lisa McPherson Trust. He was quite despondent about that. He was despondent about what to do with the people that we were either in the process of servicing or starting some — something with new people that were calling. And plus the phones just never stopped ringing.

So he was distraught over the fact that it wouldn’t be there anymore. He was distraught over the fact he felt Scientology had successfully caused the Lisa McPherson Trust to no longer exist because of a misunderstanding, that misunderstanding being that it was somehow inextricably tied into the Lisa McPherson case.

Q Did Mr. Minton or Ms. Brooks order you to quit being the expert for the estate?

A Ms. Brooks asked me to — and this, again, is in

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the fall of 2001 — to not be an expert in this case on the theory that anything — we were trying to sever any real or imagined ideas that the Lisa McPherson Trust was connected with the ongoing litigation.

Q And did you listen to her?

A No. I — I — I consulted Bob about that. I had a conversation with him.

And he told me that Mrs. Brooks was very upset about the discovery that was going on, particularly the finances. And — Mmm — this is why she was doing it. And he understood why she was doing it.

And — Mmm — what he said, you know, “If Ken — you are Ken’s expert. If he’s going to need you, you know, I’m sure you’re going to go and do what you have to do.”

MR. WEINBERG: Could we date that, your Honor, when that conversation took place?

THE WITNESS: Mmm, I think we were speaking about late 2001/early 2002. Maybe January, around there. This is as close as I can place it.

BY MR. DANDAR:

Q Well, prior to that, you filed or signed an affidavit dated September of 2001 withdrawing as the expert for the estate.

A Okay.

Q So was this conversation with Stacy Brooks before,

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or after, that affidavit?

A Preceding that.

Q So it was before that?

A Correct.

Q All right. And in that affidavit — do you recall that affidavit when you withdrew as the expert?

A Not particularly.

Q No?

A I mean, I have a general idea.

Q What is your general idea of why you withdrew as the expert?

A Mmm, again, this was during the time period when the Lisa McPherson Trust was in the process of closing. The trust itself had literally been drained of operating funds for, you know, paying lawyers. This wasn’t anything that we ever anticipated or budgeted for. And it became the most expensive part of the operation, which was trying to step away from this case. And that is what I remember about it.

Q Let me show you your signed affidavit September 21, 2001 and see if you can identify that.

MR. DANDAR: Judge, do you need another copy of this?

THE COURT: No. No. This is the one I remember quite well.

MR. DANDAR: All right.

405

MR. WEINBERG: Excuse me, is he impeaching Mr. Prince with this affidavit now?

THE COURT: I don’t know if he’s trying to refresh his memory or what.

MR. DANDAR: Refresh.

BY MR. DANDAR:

Q First of all, is that your affidavit?

A Yes, it is.

Q Did you prepare that affidavit?

A Yes, I did.

Q Did you sign it?

A Yes, I did.

Q Is that the affidavit that you signed concerning the reasons for your withdrawal as the estate’s expert?

A Yes, it is. And, you know, I remember because I was talking about now the trust was closing, there were no lawyers — I mean we just couldn’t afford to pay lawyers anymore.

I personally cannot afford to have a lawyer to come in here and do activities like you are involved in or represent me or — or be here on my behalf. I have a family. I have people that are totally innocent to this and could care less.

But my family was threatened with the Scientology operation that was wrought on me to plant drugs in my house

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and get my house raided by the DEA, and try to get multiple charges put against me. And now I’m losing my job, too. There is no way that I could continue this activity without being able to see that my family would be safe and cared for.

Q Did you continue to receive income from Bob Minton or Stacy Brooks in the fall of 2001?

A Yes.

Q And the income you received in the fall of 2001, was that from Stacy Brooks individually, or from the Lisa McPherson Trust?

A I think it was probably Ms. Brooks individually.

Q Okay. What about 2002? Did she continue to pay you?

THE COURT: When did — when did LMT close down again? I have been away from this awhile and some of the details are out of my mind.

MR. DANDAR: It closed in August.

THE COURT: Of 2001?

MR. DANDAR: Yes.

BY MR. DANDAR:

Q Well, you tell us, Mr. Prince, instead of me.

What was going on in the LMT in the fall of 2001?

A They were closing — wrapping up, closing down, terminating the operation. Mmm, there was an order to allow

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a magistrate to come in and go through the personal files and records at the trust. So for a month or two it was kind of kept open for that reason alone, just to finish that. So that — you know, there was an extensive library that —
that library had to be shipped, cleaned — the building had to be cleaned up and prepared to be sold.

It became our responsibility to ensure that the building did get sold. I had a verbal agreement with Mr. Minton, because at that point I didn’t have a lot of money either, that if I sold the building, I would get  25 percent of whatever the building sold for so that I could move — I was in the process of leaving Clearwater. My house was on the market. We were finished — the trust was over. We were finished.

I mean, if that is what Scientology wanted, they had accomplished it. It was finished. We were all moving.

I put my house on the market, put the building on the market, we were trying to sell it. We’re — we’re done. But it is never done, I guess.

Q Back to 2002, do you believe — have we exhausted your conversations with Mr. Minton or Stacy Brooks prior to the New York City meetings?

A The only additional things —

THE COURT: I just dread the thought of asking this question, but are you suggesting there is some

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agreement between you and Mr. Minton regarding the sale of real estate, as to your receiving proceeds from it?

THE WITNESS: Yes, your Honor.

THE COURT: I see. Is there a lawyer in the room that wants to take that on a contingency? Probably not, Mr. Prince.

Okay. Continue on.

THE WITNESS: You know, I missed the point. I guess you’ll explain it to me later.

MR. DANDAR: That is all right.

THE WITNESS: I hate to miss the punch line.

BY MR. DANDAR:

Q So anything else about these phone calls, before we get to the New York City meeting?

A Well, the only other thing I think I covered in my affidavit that Mr. Minton said is, you know, after having conversations with Mr. Rinder, that it basically boiled down to who is going to die? Is it going to be Ken Dandar? Is
it going to be me. And I —

THE COURT: Is that the word he used, “die”?

THE WITNESS: Yes, your Honor. And for the life of me, you know, I couldn’t get a concept of what he was saying. I mean, he said it several times —

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THE COURT: Is this — I’m sorry, my mind is off on agreements and it is kind of an insider joke that has nothing to do with you really, a lot of agreements we’re talking about in this particular hearing, and we teasingly asked about what lawyer would take what on a contingency fee.

THE WITNESS: Oh, okay. So nobody wants my opinion.

THE COURT: Well, it will be volunteered, Mr. Prince.

Was this before or after the New York meeting, this conversation?

THE WITNESS: This was before the New York meeting. This is after Ms. Brooks arrived.

THE COURT: Okay.

THE WITNESS: He was telling me that, you know, that somebody has to die.

And, you know, Bob has always come to me, when he wanted to interface or maybe know something from Ken, he’s asked me, you know.

So for the life of me, I couldn’t figure out how is it now that suddenly we sit here today and we have to decide who dies. Why does anyone have to die? That was my question.

And — Mmm — he told me that for them — for

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him not to go to jail and be prosecuted — and he had actions going in both cases in front of both judges, Judge Schaeffer and Judge Baird — that he somehow had to make this case go away, the Lawrence Wollersheim case go away, and that is — he said, “That is all — that is what they said they want.

So we’re going to go talk about that.”

BY MR. DANDAR:

Q In New York City?

A Yes.

Q All right. And — all right. Anything else, before we get to New York City?

A That — Mmm — Stacy was just adamant that she would be able to successfully settle with Scientology so that they would disengage Bob Minton, because he was literally being driven insane. He was terrorized into a state of mind that was beyond anything he was capable of dealing with.

THE COURT: Did you ever ask him what — when he used the word “die,” whether he was — I mean, we all say, “Oh, I’m just going to die if such and such happens.” But he was not using that word in a literal sense, that was a —

THE WITNESS: Well, I asked him later about this.

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THE COURT: Okay.

THE WITNESS: After they came back from New York and was in the hotel, what was he talking about.

THE COURT: Right.

THE WITNESS: And what he was talking about was saying that Ken Dandar, as one thing, perjured — you know, blamed the perjury on Ken. I mean, these are all things to do to get rid of the case. Okay, so now we made Ken responsible for any perjury that Bob Minton did. Then, you know, he mentioned about what’s going to happen is Mr. Dandar is going to be disbarred.

And I took it a step further. I said, “Well, if Mr. Dandar gets disbarred, he’s going to lose his business. If Mr. Dandar loses his business, he’s going to lose his home and his family. Is this really what you want for Ken Dandar after you built him up all of this time, and now you get in trouble and now this is what we do?”

THE COURT: So, again, I think my question was is we all tend to use the word “die” and we don’t really mean it literally, drop dead, I mean, die.

THE WITNESS: Oh, yes, I don’t think —

THE COURT: He meant either business-wise or

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something?

THE WITNESS: Professional decease, to cause decease, which is in accord with one of the Scientology policies we have gone over here.

BY MR. DANDAR:

Q Is that known as fair game?

A No. It is called the Scientologist’s Manual of Dissemination, where it talks about, if possible, of course, ruin the person utterly.

Q Let’s get to New York City. Did you have any conversations with Bob Minton or Stacy Brooks about the New York City meeting with Rosen, Rinder and Yingling?

A Yes, I did. When they were traveling to New York City, I was traveling to Memphis, Tennessee to drop my family off. It had just reached a peak for me. And I just wanted to have some safety in my life.

So they called me when they left home. They called me when they arrived. They called me when they met, had the first meetings. They seemed somewhat hopeful. Then, of course, the next day happened.

But when they got there, you know, Steve Jonas arrived. They were there. They met. They went over what they wanted. And Bob — you know, one of the things Bob did, which I didn’t know he was going to do until he got to New York, is he said he wanted my house to be able to be

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sold, because I had had my house on the market for some time, zillions of people were coming there. And, you know, unfortunately, it just didn’t sell.

So he thought that that may have had some Scientology influence. And the reason why I think he thinks that, because the realtor for our building —

THE COURT: He? This is Mr. Minton again?

THE WITNESS: Yes.

THE COURT: Okay.

A The realtor for the building in downtown called Mr. Minton while he was in New York and told him he had had a buyer for the LMT building, and this buyer was a person that sold furniture, sold used furniture.

And he mentioned this potential buyer — this potential buyer mentioned to his clients, current clients, that he was going to move his operations to this building, and would that be okay, would he still be able to service them.

And he came back and said he found out that 45 percent of his clients were, in fact, Scientologists.

And he was told in no uncertain terms that if he moved into that building, that they would no longer do business with him. So —

MR. WEINBERG: Your Honor, I object.

A He couldn’t — he couldn’t —

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MR. WEINBERG: This is hearsay on hearsay. This is supposedly what Mr. Minton said that somebody said.

THE WITNESS: No. Mr. Minton said to me that the realtor —

MR. WEINBERG: Said to him. Objection, double hearsay.

THE COURT: I do understand. But, remember, this has to do with Mr. Minton and whether Mr. Minton has lied or whether Mr. Dandar is lying.

Mr. Minton’s state of mind, therefore, becomes, to some extent, relevant.

I understand it is double hearsay. I understand what that means. But I’ll allow it. It is a very unusual hearing.

MR. WEINBERG: Okay.

BY MR. DANDAR:

Q So when did you first hear back from Bob Minton concerning the first day of the New York City meeting on the 28th?

A The night of the 28th after they met. He said, “Well, we met.”

I spoke to Stacy. She said, “I think it is going to be okay. I think we’ll be able to work this out. Ken Dandar is not going to be happy.”

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Mmm, you know, I said, “Okay,” whatever that meant, because, you know, I’m not really tracking. I just know something traumatic has happened, it has to do with some information that came up on Bob, and I know that now Stacy Brooks and Bob Minton are in negotiations to disengage this whole thing, and I am not there but they are calling me, telling me what is going on.

Q Did they tell you why I would not be happy?

A Whew. Because they were going to say that you caused Bob Minton to lie about the check — that you advised him to lie about the check. This was during that particular time.

THE COURT: Is this Ms. Brooks testifying — or Ms. Brooks telling you this? Or is this Mr. Minton telling you this?

THE WITNESS: You know, it is kind of a bit of both, your Honor.

THE COURT: Was this over the telephone?

THE WITNESS: Yes.

THE COURT: This was after the first New York meeting?

THE WITNESS: This was the night of the first day of the meeting on the 28th.

THE COURT: Of March?

THE WITNESS: Yes.

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THE COURT: It was this night they were explaining to you — either Bob or Stacy, or both of them, on the phone, explaining why Ken wasn’t going to be happy?

THE WITNESS: Yes.

THE COURT: Okay. Go ahead.

BY MR. DANDAR:

Q Now, Mr. Prince, I want to make sure you don’t have your dates mixed up. Could you look at your affidavit to refresh your memory and make sure you have your dates down when you first mentioned that Ken Dandar wasn’t going to be happy.

A Okey-doke. Okay, I’m looking at my affidavit —

Q By the way, who typed that affidavit?

MR. WEINBERG: Your Honor —

THE COURT: Just a second now.

MR. WEINBERG: I object to this process. He has done this a number of times. He elicits testimony. Mr. Prince testifies, he’s very specific, he had this conversation.

Then Mr. Dandar takes his affidavit and says, “Well, look at this and see if it is really your testimony.” He’s impeaching him.

MR. DANDAR: Well —

MR. WEINBERG: I don’t think it is proper.

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THE COURT: I think that I’m — I have heard his testimony. I think he can look at his affidavit and see if it refreshes his memory. If it does, I’ll just have to remember his testimony was different before it was refreshed with this
affidavit.

MR. WEINBERG: Okay.

A Yes. Okay. I talk about the problem with the checks. We talked about that again. This was the next day on the 29th — now, wait a minute. “Bob told me he called –” now, see, this is before they went to New York, “Bob told me he made — ”

THE COURT: You are going way too fast.

A “Scientology was going to put him in jail.”

THE COURT: What page are you on, please?

THE WITNESS: I’m on Page 3. Bottom of Page 3, Line 27 —

THE COURT: All right.

THE WITNESS: — and 28. “Bob said there was a problem with some checks he had given to Ken Dandar.”

That was the —

BY MR. DANDAR:

Q That is before the New York trip?

A Yes. Okay, so they arrive in New York. “The next

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day, on the 29th, the next day around noontime,” I’m on Page 4, Line 10, “Stacy called me. She was upset. Bob was going to jail for contempt in front of Judge Schaeffer, going to jail for perjury in front of Judge Baird. At this point they had only mentioned to me about the wrongful death suit and the Wollersheim suit having to be dismissed for Bob not to go to jail. Mr. Rinder –”

THE COURT: You don’t have to read out loud.

You really are looking to see when it was that — if this — if this refreshes your memory as to when this statement about why it was that Mr. Dandar would not be happy.

MR. DANDAR: Right.

BY MR. DANDAR:

Q When did that first occur?

THE COURT: When it occurred.

A Either the 28th or the 29th, one of those two days.

BY MR. DANDAR:

Q Okay. And then again I want you to look at your affidavit —

A And, you know, this information was sketchy because I didn’t get the full picture until they came here to Florida. I wasn’t able to divine the full picture until they actually came back from that meeting.

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Q Okay.

A Now —

Q Do you recall — do you recall that Mr. Minton called you up, after the second day of the New York City meeting, to talk to you about a phone call he received from Mr. Rinder?

A Oh, after they got back from New York?

Q Right.

A Yes — well, no. Stacy is the one that I spoke to.

Q What did she say?

A She said, after they got back from New York, they were all upset and thought they wouldn’t be able to negotiate with Mr. Rinder and Mr. Rosen.

Q Why? Why wouldn’t they be able to negotiate?

A Because they told Mr. Rosen and Mr. Rinder flat out that they had no influence to get either of these cases dismissed or made go away or whatever, they had no authority to do that; that Stacy Brooks had already made an attempt to contact Dell Liebreich to get her to drop the case, so she wasn’t interested in hearing from Stacy; and Mr. Wollersheim certainly — and Mr. Leipold were certainly not interested in dismissing their case, either.

THE COURT: When — now, I’m so confused, and I haven’t read your affidavit in some time so I’m

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listening basically to your testimony.

You indicated — what I think you just said is Ms. Brooks told you on the telephone that she had told Mr. Rinder that they didn’t have the proper influence to get the case dismissed?

THE WITNESS: See, I’m totally screwing this up if you think that, your Honor, because what I’m saying there is that happened in New York where they were face-to-face with Mr. Rinder, with — at least this is what was relayed to me by Stacy and by Bob on the phone conversation when they left the office, I think it was about noontime on the 29th where they tried to make it clear that they had no influence over these cases and they were asking them to do something they were not able to do.

THE COURT: What confuses me, if I did understand your testimony, after the New York meeting, perhaps the very night of the New York meeting, Stacy called and — Stacy and/or Bob called and said, “I think we’re going to be able to work this out.”

THE WITNESS: Yes, that was after they came back to New Hampshire, left New York, because they were back in New Hampshire that day.

THE COURT: Okay.

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THE WITNESS: It was either that night or the next day I spoke to Stacy Brooks, and she said she had received a second conversation from Mr. Rinder, who mentioned that he thought that there may have been a misunderstanding, while he understood that they legally — or, you know, weren’t plaintiff or defendant, had no standing to effect these cases one way or another, that there were things that could be done to get the same result.

THE COURT: This was another conversation with Mr. Rinder and Mr. Minton or Ms. Brooks, when they told you about that, that is when they said, “We think we can do something but it is not going to make Ken Dandar happy”?

THE WITNESS: Yes.

MR. WEINBERG: Would that be on the 29th, your Honor?

THE COURT: I believe.

THE WITNESS: The 29th or the 30th or such a date of this.

MR. WEINBERG: Of March?

THE WITNESS: Yes.

BY MR. DANDAR:

Q When did you get the details about what that meant about Ken Dandar not being happy?

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A When they traveled to Florida for the Judge Baird hearing that was, I think, occurring on April 5.

Q That is Judge Schaeffer.

A Hmmm?

Q Judge Schaeffer was April 5?

A That is right. Judge Schaeffer was April 5. But they had a Baird one right the next week or whatever.

Q Right.

A Anyway, when they came down for that activity, then we had a meeting at the Harbour Bay Hotel in Tampa, Florida where they made it clear to me what was happening here.

Because I asked them, “Did you find out what these things were that you can do to make these cases go away?”

I’ll start with Wollersheim because that will be quickly.

Q All right.

A She said what she had already done and told Scientology she would do and had done, that she called Dan Leipold and told him to withdraw her testimony — her affidavits in the Wollersheim case, and she had instructed him to do the same for my affidavits.

And there was only three, Vaughn Young, Stacy and me. Vaughn Young, because of his physical condition, how upset he would be to even do that, she told me she had not

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promised Scientology anything in relationship to Vaughn, but she could promise the relationship to me and her.

Q How did you react to your affidavit being withdrawn?

A I was shocked. I was like, “I’m not withdrawing my affidavit.”

Q Why did she want to withdraw her affidavit?

A Because these are the things that she could do — you know, they want — they want what are the things you can do? What you can do is take your testimony out. Take Jesse’s testimony out of there. Because there was only three witnesses that they were using on the issue of alter ego to claim the judgment.

Q Did you ever —

MR. WEINBERG: Before — could we just date that? Is that at Harbour Island? Is that what you are saying? Could we just date it?

THE WITNESS: I think I dated it in the affidavit.

THE COURT: You want to look at your affidavit and see if you can find it then?

THE WITNESS: Okay. Okay. Yes, Page 5, Line 11.

BY MR. DANDAR:

Q What is the date?

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A If you look at Line 22, he starts talking about things that could be done.

THE COURT: Line 22?

THE WITNESS: Yes. Where it starts talking about things that could be done.

THE COURT: And that is where you use the phrase, “Ken Dandar was not going to be happy”?

THE WITNESS: Right. So when we met at the hotel, you know — and I’m doing the best job I can here — I asked them — they mentioned about getting the affidavits out of the Wollersheim case, then specifically here in the wrongful death case — “Well, what are you going to do with that?”

“Well, Mmm, we’re going to –” they had a couple of things they were going over. One, the perjury of the check to make it seem like it was Ken Dandar’s fault. And then they were insistent about some meeting that had occurred which included myself, Dr. Garko, Stacy Brooks, Bob Minton, Mr. Dandar, where we were discussing adding Mr. Miscavige as a party, and how Ken Dandar had instructed Mr. Minton to say the conversation never happened, something about it never happened.

Now, you know, for me, I’m not understanding

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this because it is not making a whole lot of sense why it would matter one way or another. You know, I’m not a lawyer, I’m not a criminal, I didn’t understand what they were talking about. But those were two things specifically that they mentioned bringing out about Mr. Dandar and connecting him with perjury.

THE COURT: One was the check? Is it the $500,000 check that you testified to previously?

THE WITNESS: Yes, your Honor.

THE COURT: Number two was some meeting that occurred dealing with adding Mr. Miscavige as a party?

THE WITNESS: Yes, your Honor.

BY MR. DANDAR:

Q Was there anything else of how they were going to get Ken Dandar, besides these two items?

A Well, the only other thing that came up — I knew about those two things. But then they had the meeting with Judge Schaeffer where Bruce Howie did something, and the whole thing was moot. And they were happy about that.

I think maybe that same day he got served with the Armstrong suit. And he told me, “It’s not over, I still have got to go in front of Judge Baird.”
Now, I think at that same time the decisions came

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down from the 2nd — from the appeals court concerning discovery issues with finances and this, that and the other thing, so it was kind of like things were turning around.

So I’m questioning them, “Do you really think you need to do this?”

And they are trying to elicit my cooperation, like we used to have this thing amongst us, me, Stacy and Bob, we called ourselves the A team. There was three of us, this is an A team activity. It is tough at the top, we have to make some hard decisions here, you know. So I’m part of that entity. So we’re discussing these matters. And, Mmm —

MR. WEINBERG: Your Honor, is this all one conversation? Does it mean it happened after your hearing on April 5?

THE COURT: I’m not real sure.

MR. WEINBERG: All right.

THE COURT: Was this all at the same conversation?

THE WITNESS: Mmm, your Honor, maybe not because, I mean, I was with them the whole time and, you know, Page 5, starting at Line 11 — 16, Number on the affidavit, I talked about the time periods we were there, the 2nd or 3rd of April through —

THE COURT: Did you try, in your affidavit, to date the time frames when these conversations took

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place as you remembered them?

THE WITNESS: Yes, I did. I sat there with a calendar and I did it as best I could.

THE COURT: Okay. So those are the dates as best you can recall?

THE WITNESS: As best I can recall.

THE COURT: All right. So whatever it says in the affidavit is the best he can recall.

MR. WEINBERG: All right.

THE WITNESS: Yes, that is the way I sat and worked on it.

MR. WEINBERG: I was really more asking whether this was one conversation or he was — he talked about a conversation in the Harbour — I think he meant Harbour Island Hotel, but —

THE COURT: It depends what the affidavit says.

MR. WEINBERG: All right.

THE COURT: Is that right, Mr. Prince?

THE WITNESS: Yes, your Honor.

THE COURT: The affidavit speaks of these things that you have been talking about in different conversations. That would be your testimony if you refreshed your memory?

THE WITNESS: Yes, your Honor.

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BY MR. DANDAR:

Q So your memory was better when you wrote this in April than it is in July?

A For sure.

Q In your affidavit you say Harbor Bay Hotel. That is not Harbour Island Hotel. Do you know where the Harbor Bay Hotel is?

A No, I guess not if I am confused about it. It is the one that has the restaurant in there — well, that means nothing, they all have. Okay, I’m sorry, I spoke out of turn.

Q All right. But what I’m saying, when you took the time to sit down and write your affidavit of April 2002, of course you weren’t under pressure, being examined in front of a judge in a courtroom. You said you had a calendar in
front of you?

A Yes.

Q Okay. Now, let’s jump back again to New York City. All right?

A Okay.

Q Well, no, I’m sorry. Let’s go to the conversations you had with Bob Minton and Stacy Brooks about New York City.

Did they tell you what type of things Mr. Rosen said to Mr. Minton at the New York City meetings?

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A That he was going to jail and actually spoke with him quite loudly about this. That he was going to jail. He was going to be prosecuted in front of Judge Schaeffer and Judge Baird.

Mmm, by giving the affidavit, I wrote either Bob — Mr. Rinder — he told me — Bob Minton told me specifically Mr. Rinder said, you know, “Bob, you know I’m f-ing you but I’m doing it to your face. You have people around you that are doing it behind your back.”

And he mentioned the people that were doing it behind his back being yourself, Patricia Greenway and Peter Alexander.

Q Did there come a point in time when Mr. Minton showed you any documents that he received from the Church of Scientology?

A Yes. This was when they had — yeah, now this is after I actually attended the Judge Baird hearing, saw Bob get up on the stand and start lying, and left and went to —

Q All right, I probably jumped the gun. And I apologize. Let’s go back.

Before we get to the Judge Baird hearing, let’s make sure, as far as you can recall today, what transpired when Bob and Stacy came to Florida.

A The first time they came to Florida, they were concerned about the hearing in front of Judge Schaeffer.

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They were meeting with Bruce Howie. They were continuing to meet with Scientology, working on the things that could be done to get these suits dismissed.

And I guess part of it was to elicit my cooperation to go along with this new plan to disengage Scientology from Bob Minton.

Q Okay. And did Mark Bunker come with them?

A Yes.

Q And Mark Bunker, did he stay at your house?

A Yes, he did.

Q Did anyone else stay at your house?

A No.

Q All right. So did you attend the deposition of Mr. Minton on April 8?

A No, I did not.

Q All right. So the first time you saw Mr. Minton testify was before Judge Baird?

A Correct.

Q All right. And you said that you sat in the audience?

A Yes, I did.

Q And what did you hear Mr. Minton say you thought was a lie?

A Mmm, something about Mr. Dandar making — telling Bob to perjure himself in relationship to the checks.

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Q All right. How did you know that was a lie?

A Because if that would have happened, I would have known about it when it happened. You know —

Q Why is that?

MR. WEINBERG: Objection, your Honor. I move to strike, “if that would have happened, I would have known about it when it happened.” How is that a response?

MR. DANDAR: I’m asking him to explain it right now.

THE COURT: Yes. Overruled.

A If there had been some agreement between Mr. Dandar and Bob Minton to hide the fact that — the check, I would have known about it when it happened.

THE COURT: Are you saying that Mr. Minton would have told you?

THE WITNESS: Yes. That is what I’m trying to say. He would have told me when it happened. Now, this coming up after all of this time, when I’m sitting there and he — you know, he’s taking us up to the garage when he gave the check, he’s saying this stuff is coming from Europe and you don’t know where it is coming from, on and on, now suddenly he changes his mind, I knew it was a lie.

Or he told me — one way or another, he’s lying now.

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BY MR. DANDAR:

Q All right. What was the next thing he lied about before Judge Baird?

A I just got up and just walked out. I couldn’t take it. I couldn’t believe what was happening. I was extremely distraught.

As I say in my affidavit, I actually wept because — you know, because once again we see the big Scientology machine, with all of its high-priced lawyers and endless resources, endless staff, to make this occur. “We can’t get the case dismissed or thrown out in any other way so now let’s go manufacture some information.”

MR. WEINBERG: Objection, your Honor.

A Let’s create —

MR. WEINBERG: This is pure and utter speculation.

THE COURT: Not only that, but I think it is just kind of a discussion what he thinks. And, frankly, I need his testimony, not what he thinks. He can put that in someplace else.

That objection is sustained.

BY MR. DANDAR:

Q Before you walked out of the courtroom, did you hear Mr. Minton say any other lie outside of the Dandar making a lie about the $500,000 check?

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A No. I got up and left immediately.

Q All right. And when is the next time you were talking with Mr. Minton or Stacy Brooks?

A After they had left Clearwater. I mean, I just couldn’t even stand to be around them anymore. When I saw that that thing happened in front of Judge Baird, I didn’t know what to do.

And I finally figured that, you know, in my mind something criminal was going on here, I need to do something to help my friends. So I went to visit Mr. Denis deVlaming. And I —

THE COURT: When you say to help your friends, you are talking about your friends Bob Minton and Stacy Brooks?

THE WITNESS: Yes, your Honor.

BY MR. DANDAR:

Q So you went, on your own, to Denis’s office?

A Yes.

THE COURT: I’m sorry, I should not put words in your mouth, either. Obviously you meant Mr. Minton when you say friends. Who was the other friend?

THE WITNESS: Mmm, Stacy Brooks. I went to Mr. deVlaming’s office and I explained to him that I had been privileged to know that this was going to

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happen, that this was going to be created and done against you, and I explained the whole thing to him.

And his reaction was, “Oh, well, they got him this time.” But because he had represented me before, and he had also represented Mr. Minton, he told me that it was a conflict of interest, because I went there to see if I could somehow get law enforcement involved in what was going on here because I was confident that Bob was lying on behalf of Scientology.

And I asked him to put me in touch with someone on a federal level, because I believed that Scientology did have influence in the state prosecutor’s office. I believed that they were able to somehow enact, somehow, undue influence on prosecutors simply because they never get prosecuted for the things that they do. And I myself, you know, I could have one little small marijuana plant in my house, I’m raided by the DEA.

But, you know, a person — a dead body shows up, they can’t do anything.

I had no confidence in that. I asked a federal — asked for federal protection, a federal level, because I said in my mind what they have done is RICO; they have conspired to commit a crime that

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started in New York, they continued it down here in Clearwater.

Bob told me clearly that he was not going to involve his lawyers in the negotiations proper to any degree where they’re really getting down to the meat and potatoes.

THE COURT: Did Bob tell you why?

THE WITNESS: Because they disagreed.

Mr. Jonas thought the whole thing was disgusting and distasteful that was going on.

BY MR. DANDAR:

Q Mr. Minton’s lawyer?

A Yes. Mr. Jonas, up in Boston. And you notice he has been visibly gone. He didn’t want nothing to do with this.

So they decided to use Mr. Howie to enact this. And they didn’t tell him what was going on. They were happily meeting with these lawyers and without any representation.

Q Well, why —

THE COURT: Wait, you said they were happily meeting with these lawyers without representation.

What is it you mean?

THE WITNESS: The lawyers specifically that Bob and Stacy were meeting with was Sandy Rosen and

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Monique Yingling.

THE COURT: All right.

BY MR. DANDAR:

Q Did Mr. Minton tell you why he chose not to have Mr. Howie or Mr. Jonas go with him to meet with Mr. Rinder, Mr. Rosen and Ms. Yingling?

A Mr. Jonas thought the whole thing was disgusting and distasteful and thought it would be improper.

And he told Bob specifically — and Bob told me he told him — not to meet with Scientology without representation.

Mr. Minton — Mr. Minton mentioned that Mr. Howie could be used because he didn’t really understand what was going on in the first place with — I mean, and the reason why he didn’t understand, it is not because he’s a stupid or ignorant person — but because they weren’t giving him all of the information, Bob and Stacy were not telling Mr. Howie everything, they were negotiating with Scientology and telling Mr. Howie what they wanted him to hear.

Q But why — did Mr. Minton explain to you why he chose not to have his attorneys be present at the meetings?

THE COURT: I presume you’re talking about the meetings in Florida?

MR. DANDAR: Yes.

THE COURT: And his lawyer down in Florida being Mr. Howie?

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MR. DANDAR: Yes.

THE COURT: Because Mr. Jonas was in New York?

BY MR. DANDAR:

Q Yes. Did he tell you why he didn’t want Mr. Howie at these meetings?

A Mr. Minton expressed to me that he had personally had enough of lawyers, period. And he thought that this is something he needed to do.

Q All right. By the way, did Mr. Minton ever appear at a meeting with you, me, Dr. Garko, Stacy Brooks, to talk about adding on David Miscavige?

A No.

Q Ever?

A No. This was the second big point, you know, that — you know, that Stacy is going on and on, “Jesse, you have to remember, it happened like this.”

“I told you, you are imagining this. It never happened. I’m not going to sit and lie about this.”

But this was another point I was supposed to go along with at the meeting. This is where they were really trying to bring me in to find these points to get you, basically.

Q Well, what made you not join and continue to be part of the A team, as you call it?

A Well —

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MR. WEINBERG: Your Honor, I — can we explain what the A team is? Because maybe I missed something.

THE COURT: Yes, the A team is Jesse Prince, Bob Minton and Stacy Brooks. They laughingly referred to themselves as the A team.

MR. WEINBERG: I guess I was daydreaming. I didn’t hear that. Sorry.

THE COURT: I did. So I — I miss some, but I recall that.

MR. WEINBERG: You caught that but I missed the A team. Okay.

BY MR. DANDAR:

Q So why did you choose not to go along?

A Well, Mr. Dandar, for obvious reasons. Number one, I worked for years on this case. I have worked honestly, to the best of my ability, on this case. I assumed that Stacy was, as well.

Mmm, I understood that Bob Minton — Scientology discovered something about him that upset him greatly and had him horribly concerned. But I wasn’t going to lie to protect him to hurt someone else.

And, in fact, my exact words to Mr. Minton was — and Mrs. Brooks, that I will never, in my life, help Scientology hurt or destroy one more person.

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Q When did you tell them that?

A After — after I walked out of Judge Baird’s courtroom, and then now they’re all looking for me and they’re calling around to see if I’m in jail or see if I’m in the hospital. They thought I had a heart attack, because I was visibly upset. I mean, I was shaking when I walked out of that Judge Baird’s courtroom.

But the thing is I didn’t want to see them. I told my fiance, “You tell them to go home where they live because –” excuse this expression “– they have come and shit all over where I live, I don’t want to see them. You go back to where you live and then we’ll discuss this.”

And we discussed it. And when we discussed it, when I got on the phone with them after they got back, that is when I had the conversation and said that to them. “I can’t do it.”

Q Did you meet with them after Judge Baird’s hearing in Clearwater?

A Yes. I met with them a couple — not after the Judge Baird hearing. You know, at a later date after that, sure.

Q Do you recall meeting with them that following weekend?

A It could have been that weekend. Again, I have done the dates here to the best of my recollection, with

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sitting down with the calendar. But it was after the Judge Baird — yeah, because Bob had been deposed — no, wait a minute, I’m confusing incidents now, because by the time they went back, they had already been through the Baird (sic) deposition and they were having the contempt hearing or whatever it was in front of Baird where he lied.

So, you know, they came back at a later date. And the discussion was — after they got back to New Hampshire, I told them how upset I was and how I couldn’t do it, and Stacy said to me in no uncertain terms that, “The reason you feel this way is because you don’t have all of the information. We’ve been leaving you out of the loop on some things that you need to know.”

She said that they had signed some agreement with Scientology, so — she couldn’t tell me everything, but the next step was to bring me back into the circle to make this go away for Bob.

And Stacy was just hell bent for leather to do whatever she had to do to disengage Bob from Scientology because she thought it was killing him.

Q Did you meet with them in Clearwater then?

A Yes, I did. We met at Adam’s Mark Hotel.

Q At the Adam’s Mark Hotel there are two things I want you to talk about. Number one, the conversation. And, number two, any documents you saw.

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A Well, I hadn’t seen Bob. He knew I was furious with him. I hadn’t seen Stacy because I was furious with her. But we agreed to meet because we were friends.

Friends don’t get along every day. It would be nice if you did. But you don’t lose a friend because there is a disagreement.

So we met. And Bob told me, you know, he said, “Look, Jesse, you know, I’m not sure that this is gonna work, either. Stacy is more confident about doing this than I am. I don’t know.” We were kind of having that discussion.

Then the phone rang. Mr. Minton spoke with someone and he said, “Okay, leave it at the desk” and he hung up the phone.

And I asked him what that was.

And he said Scientology was delivering to him a packet of information that had to do with his prior deposition testimony — or prior testimony, that amounted to about 11 inches, for him to go through for the purpose of finding more things for him to — Mmm — quote/unquote, recant or do whatever he was going to do.

There was total — I asked him, “How many things besides Wollersheim and the Lisa McPherson case, what else do they want you to do? Do you know when your leash is over with, where they get done with you? Okay, you think if you

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destroy Ken, that will make you safe. But what else are they going to have you do? Do you know?”

He said he didn’t know, but this package represented six to seven other things that they wanted him to change testimony about or — or say something different about.

Q Did you see this package?

A Mmm, no.

Q How do you know it was 11 inches high?

A He told me.

Q Okay.

A And he also told me at that time that his attorney, Steve Jonas, told him not to meet with Scientology concerning that package without representation, but he was going to do it anyway —

Q Okay.

A — because he’s taking control.

Q Did you ever see any lawsuits that Mr. Minton was given where Scientology was suing him or contemplating suing him?

A He had a rough draft of a RICO suit that he showed me. It was about this thick.

Q How many inches is that?

A It was about maybe an inch, inch and a quarter, something like that. And he —

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Q All right.

A — flipped through it like this. And he would never physically give it to me.

He said — and we all predicted they were going to do some crazy RICO thing. He said, “They finally did it. Here is the RICO thing. We already have the Armstrong thing. They are suing me for 80 million which I’ll be liable for, here is the — another RICO, that is another 110 million. They are adding me as a defendant in the breach of contract.

And,” he said, “I’m the only person with money. I have got to get out of this.”

Q Okay. Now, did you at any time tell Mr. Minton or Ms. Brooks that you were willing to meet with Scientology?

A Yes.

Q When was that?

A Mmm, at the Adam’s Mark Hotel when they — you know, what they call bringing me into the circle.

And I’m looking at these people that I have worked with for years and I might as well have been looking at strangers, because Stacy has this whole thing lined up.

She — you know, she knows exactly what is going to happen, who is going to do what. And Bob is kind of like following along because he’s just at his wit’s end.

And Stacy figures that she knew Mike Rinder for a long time and they were good friends and she’s just going to make this as good for Bob as possible.

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And, to me, she just delivered Bob into the hands of his enemies.

Q Did Stacy Brooks ever — in all of the years you have known her, did she ever say to you, “I filed a false declaration or affidavit”?

A Never in a million years. To the contrary, Stacy is fully aware that part of, you know, Scientology’s intelligence operations are to get rid of the lawsuit in any way possible. You know, whether you actually have real evidence, get rid of it, or you manufacture it or you bring up enough threat where the person just wants to be done with it.

She knows this because it happened to her.

Q When?

A December of 1999 she did an affidavit about it, about the same people, Mr. Rinder, Mr. Sutter, coming in, wanting them to change testimony, offering money.

THE COURT: We have had testimony about that.

THE WITNESS: Yes. All right.

BY MR. DANDAR:

Q Well, did she ever say — I just wanted to touch on that. Did she ever say that Mr. Rinder was actually telling her the truth about attacking Graham Berry and Graham Berry did something bad?

A No. But what she did mention to me, she said, “You know, after speaking with Mr. Rinder, you know, I

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always thought in the Fishman case –” where she appeared as an expert, she said she always thought that because they tried to add Miscavige on as a party, that that made Scientology want to instantly settle because, you know,
hands off from Miscavige, he’s the ecclesiastical leader of the Church, Sea Org, on and on.

So she said that after speaking with Mr. Rinder, she came to realize that it wasn’t adding Miscavige that caused the suit to be settled in the way it was. After talking with Mr. Rinder she came to understand that it was because of the introduction of Scientology’s upper levels at which they commonly call it as being trade secrets that was the real issue at hand.

Q Okay. Did Stacy Brooks ever say that her affidavits that she filed about Mr. Rinder offering her and her husband over $200,000 to change their testimony — did she ever tell you that Mr. Rinder’s version of what her declaration should be was true versus what Mr. Berry had her sign?

A Mmm, no. We — I mean, I had read that information before that she had done this. And at this point in time at the Adam’s Mark Hotel, Stacy was not an obvious target. They were working on Bob Minton.

Q Okay.

A Stacy was incidental at that point.

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Q All right.

A It wasn’t contemplated for her to change her testimony. It was Minton to do it.

Q Did you ever have a conversation with Bob Minton, for instance, let’s go to that night, the Adam’s Mark Hotel, where he’s talking about the $500,000 UBS check and what he told you in the parking lot about it?

A Oh, I brought that up to him. You know, they were saying, you know, “Ken is really going to get it. He told me to lie about this check.”

I said, “Wait a minute, Bob, let me remind you –“he and Stacy are like gleeful children, like all responsibility is gone. “Hee-hee. Guess what?”

“Are you insane? We were both on the parking lot. Bob got you and me out of the office, said he was giving this check to Ken, Ken didn’t know where it was coming from, told us it was from people from Europe. I mean, why are you gleefully now telling me somehow this is Ken’s fault?”

Q What did they say?

A They just looked at me like, “Oh, yeah, we forgot about that part.” Mmm, they were telling me things like, “We really got him now.”

I said, “But don’t you remember what we did?

Don’t you remember this is what really happened as opposed

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to this story you are making up now? Do you remember what actually happened?”

Q What was their response?

A “Hmmm.” You know, just “Hmmm.” Like, “He’s not cooperating.”

Q So —

A So I told him, you know, “Now, you know we were up in the parking lot. We went through this whole thing. So now what do you want me to say what happened now, when this is what did happen? What am I supposed to do?”

THE COURT: What did he say?

THE WITNESS: He just looked at me like I was crazy. And they looked at each other and they changed the subject. We started talking about — Mmm — what else did we start talking about?

They brought up something else that — the meeting, yeah, oh, and the other thing they want — “they” being Rinder and Rosen, the other thing they want brought out is how Minton was supposedly at some meeting that  happened where we all said, “Yeah, add Miscavige and don’t talk to anybody about it.” I am like, “Are you crazy? That didn’t happen either.”

BY MR. DANDAR:

Q So when you told them it didn’t happen —

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A Then they said, “Look, let’s stop talking about this. Let’s go to dinner. We’ve made some progress.”

But, on the other hand, I’m thinking, “I have to talk to somebody from Scientology about this,” because obviously I’m looking at Bob and Stacy, they are just convinced that I’m just going to to-to-to, go along with this. They are just convinced.

They are telling me — Stacy said, “Look, we’re going to do this, it is unpleasant, but we’ll put all this behind us. You won’t have worry — money problems anymore, you’ll have plenty of money, you’ll be taken care of, you know, and –”

THE COURT: Who was going to give you the money?

THE WITNESS: The same — your Honor, the same person that has been, Bob Minton. They have been taking care of everything.

(Discussion had off the record.)

BY MR. DANDAR:

Q So this was — then you went out to dinner?

A Yes. We went out to dinner and we just kind of changed the subject because it was getting heated. You know, I’m trying to find a scintilla of logic of what is going on here. And I can’t — I can’t even imagine — I can’t even make myself imagine what they are talking about

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here.

Then I told Bob, I said, “Bob, isn’t this strange –”

(Discussion had off the record.)

BY MR. DANDAR:

Q So Bob Minton said —

A I keep losing my train of thought.

Q I know. Sorry. Maybe we should read it back.

(A discussion was held off the record.)

(Last answer read back by the reporter.)

THE WITNESS: Repeat the last line again.

(Last answer reread by the reporter.)

A I got it. Because I started talking to them, I said, “Well, look, we had further discussions about Wollersheim, too.”

And I said, “Well, you have loaned Lawrence money to continue his case. Now you’re going after him. You have given all of this money against Ken Dandar. Now you are going after him. Don’t you think it is obvious what has happened here? Don’t you think it is going to be obvious to all concerned that something bad happened here?”

His response was, you know, “I’m not convinced.

Stacy is convinced this is going to work, Jesse. I’m not convinced about it. And I feel bad what is going on with Ken.”

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My thing was, okay, I have to talk to somebody about Scientology about this because obviously these two things — I have a ring in my nose and they have a leash. I have to let Scientology know they’re not going to get away with this, this is not going to work.

THE COURT: Who was it — you are saying you had the ring through your nose and they had a leash?

THE WITNESS: Yes, this is an analogy of what seemingly was in their minds.

THE COURT: “Their” meaning Bob Minton and Stacy Brooks?

THE WITNESS: Yes.

THE COURT: Thought they had the leash and were leading you around.

THE WITNESS: Correct.

THE COURT: You thought you had to tell Scientology that wasn’t accurate?

THE WITNESS: Yes.

THE COURT: Okay.

A So I’m going along now with this whole thing. I said, “Look,” I told them, “Okay, I’ll do it. Okay, I’ll do it. Tell me –” because they said, “We have to bring you in. You have to meet with Mike Rinder now. You have to meet him face-to-face and go over this and you are going to be happy like us.”

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“Okay. Okay.”

I tell you, I left that Adam’s Mark Hotel and I felt like, “Oh, my God.” You know, I would rather be doing anything. But ultimately I came home and I told my fiance, I said, “Look, it is over. I can’t do it anymore. I have to let Ken know. I have to call somebody.”

So I called Frank Oliver and told him the whole story of what had been going on the whole time and told him to please tell Ken, and I’m so sorry what happened to him.

I sat in Judge Baird’s courtroom and it upset me greatly, and asked him to arrange for you and I to meet, at which point you called me and we met the Sunday.

And I was supposed to meet with Bob and Stacy and Mike Rinder that time. And I told them, “Yes, I’m going to go along with your plan.”

And as I state here in my affidavit and I said to you to your face, I just want to see Mike Rinder’s face when he finds out that this isn’t going to work if he thinks he’s going to use me to do this thing.

So we have that meeting —

BY MR. DANDAR:

Q You and I had a meeting?

A You and I had the meeting. And Mr. Lirot was there.

Q Right. Right. And then you went to meet with Bob

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and Stacy and, you thought, Mike Rinder?

A I thought Mike Rinder would be there. So what happens, now they moved hotels, they moved to the Radisson on Clearwater Beach. I guess they didn’t like the Adam’s Mark. So we are at the Radisson.

And he has this big sheaf of papers. And he said, “Jesse, you are unreal. Let me show you what Judge Schaeffer is saying about you.” And he read something that, to me, was totally uncomprehensible.

And he said, “See, she doesn’t trust you. You are not credible in her eyes. You are going to jail if you don’t do what we tell you to do.”

I said, “Bob, I think you’re the one going to jail. You’re the one lying. You’re the one that has already went in court and lied. And you want me to do it? I think you’re the one going to jail.”

Oh, my God, it gets hot. “Okay, let’s go down to dinner.”

Then I sit and I explained to them, I said, “Look, let me tell you specific experiences I have personally had making deals with Scientology. Let me tell you the results.”

I told them painstakingly some awful things if I even started to mention, I am sure Mr. Weinberg would be up in a flash.

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MR. WEINBERG: No, your Honor, I would like to hear exactly what he said he told Mr. Minton about all these awful experiences.

BY MR. DANDAR:

Q Okay. Go ahead.

A I told him about the time I was removed from that position you saw me on the video with the sailor clothes, on and on. I told them about the circumstances about me being removed from there.

THE COURT: I’m not sure I saw that.

THE WITNESS: Your Honor, it was the first day I was here, Miscavige introduces me, I’m telling him I’m from RTC and we are going to get the squirrels and what do the squirrels mean.

THE COURT: I remember.

MR. DANDAR: This is the New Year’s Eve speech.

THE COURT: Right. I remember now.

A Well, how I got removed from that position. I’m telling him the story where Miscavige wants to come in and get rid of Broeker because he thinks Broeker is crazy.

BY MR. DANDAR:

Q So you were caught in between Broeker and Miscavige?

A Yes. And I told them, either one, “I don’t want anything to do with either one of you,” because when I got

454

involved myself in doing illegal activities, with listening to wiretapping and, you know, all of this crazy stuff I’m being shown how to do, I’m cutting my teeth, I am being broken into OSA, this is no Scientology that I ever knew
anything about.

You know, I don’t want nothing to do with this part of it. I didn’t even know it happened where they do this stuff to people.

Mmm, and then, you know, they — because I didn’t go along with that, I’m woken up at 5 o’clock in the morning, there is — there is Miscavige standing there, there is Lymon Sperlock, Ray Mithoff, Mike Sutter, Greg Wilheir (phonetic), his brother, security guards. There are about 12 people there.

I walk into Miscavige’s office, and there is Vicki Aznaran, the person that used to be inspector general of RTC, just crying in the corner, crumpled. They are all in their Sea Org uniforms just like, grrr. And I’m running around with something that looks like pajamas.

And he told me, “You didn’t go along with this, you wouldn’t follow me, now you are going to the RPF. You call me sir. You have been disrespectful.”

I stood up and told him to go to hell and went and tried to leave, at which point they tried to grab me. And me and Judge Moody has been through this story before so I’m

455

not telling a new story.

And I ran to my bedroom and I got a Mini 14 assault rifle I had been given for my birthday from L. Ron, and a .45, loaded in both, went back to that office, and I have them like this (indicating). And now they are standing there like — oh, Norman Starkey was there. And Norman says, “Jesse, you traitor. You can’t kill us all.”

And I said, “Well, I’ll tell you what, maybe not, but you will certainly be the first to go.”

And I’m standing there with these guns. Then Miscavige, because he and I used to be very good friends, too, he and I were very good friends at one point in time, he came over and he said, “Jesse, look, this is horrible, let’s stop this.”

He knew I wasn’t going to do anything. He walked right up to me. He told all those other jerks, “Get out of here, I have got to talk to Jesse.”

So we go down to the ship and we have a conversation. And he tells me, “Jesse, I know this all seems horrible now, but I need you to take this fall. I need you to be a head on a pike.” Head on a pike is a term in Scientology where somebody takes a fall for Scientology.

Put a head on the pike means if you are going through the gate, you end up like this, head on the pike.

“I want you to be the head on the pike.” He

456

wanted me to go to RPF. You know, Vicky and Rick really screwed things up with the Broekers and conspired about him, yik-yik and on and on. And he said, “Look, this will be over, you’ll be restored to your position,” on and on.

“Oh, okay, Dave, I do it.” We talked. I willingly once again go to the damn concentration camp.

Once again. Like eighteen months wasn’t long enough. Now I’m in there again.

What immediately happens? Miscavige starts issuing this horrible stuff about me, “He’s terrible, he’s a piece of crap.”

I stood up and walked out of that place, went to that base and said, “Look, if this is the way you want to play this, I’m going to the police, I’m going to go talk to them about what you do here.”

Oh, my God, all them issues are canceled. No, Jesse is good again. “Jesse, I’m sorry.” It is always someone’s fault, someone else acted in an unauthorized manner and put these things out.

Okay, he got rid of all of that stuff. I mean, I had to have something to show for being in Scientology 16 years. Every certificate I had — I had a wall from top to bottom, at least half of that, of everything I have ever done in Scientology used to be in my office.

And, Mmm, so I ended up going back to the RPF.

457

Oh, no, we straighten it all out again. That was one instance.

Just lying. Just can’t wait to get me in a position to where I am incapacitated to do something.

The second time I’m trying to leave Scientology, “Look, you guys can do this. Do whatever you want to do, you know. You want to do this activity? I don’t want to do it anymore. I just want to take me and my wife and leave, just be away.”

Well, of course that didn’t happen. I had to be degraded for four and a half months, locked up, sec-checked, told to divorce my wife. I have written about this, too. Finally, I leave.

THE COURT: What did you say, seg-checked?

THE WITNESS: Sec, security checked. Being interrogated on the E-meter.

A Well, what happens, as soon as I leave, they have someone that is a tail on me that works for this Scientology business who, because I won’t continue to do Scientology and their business, now I’m no good. You know, I have come in there and boomed that business. I was hired, I was on salary making $60,000 or $70,000 a year.

BY MR. DANDAR:

Q Are you talking about the artwork business?

A Yes, the artwork business.

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would call me once or twice a week. Mike Sutter, RTC, “Jesse, how are you doing?”

So now they want me to do Scientology work where they want me to do cramming, do correction, yik-yik, on and on.

I said, “Look, I have left that. I’m not doing that anymore. Let me just do a regular job. I’m just doing a regular job now, not using the Scientology mess, and everything is going fine. You know, don’t fix something when it is not broke.”

No, that is not good enough, that gets reported to RTC. Now I have to get removed and now I have to go through endless crap.

It finally culminated losing my job, having to start my own business, being followed around every place in Minneapolis, because I travel a lot. Then one day I found a bag right outside my hotel room, like this (indicating), Rock cocaine.

THE COURT: How big?

THE WITNESS: Huh?

THE COURT: You are showing it.

BY MR. DANDAR:

Q Tell —

A Like this (indicating).

THE COURT: Say for the record, is that the

459

size of a baseball?

THE WITNESS: About the size of a softball.

THE COURT: About the size of a softball?

THE WITNESS: With individually little crack cocaines.

A And I’m like, uh-uh, this is it.

So, to me, I’d already been through enough betrayal with Scientology. And I explained this to them.

THE COURT: This is just — all that cocaine just sitting outside your hotel room?

THE WITNESS: Yes. Yes. And the fact of the matter is, your Honor, it is known that I had, you know, smoked marijuana before or whatever, but if anyone in my family — because my brother tried it — does cocaine, he did it, had a double aneurysm. I sat in the hospital a month while they cut off his dreadlocks, peeled his skin back, cut his scalp, went through his brain, cauterized two microscopic veins because his head exploded from fooling around with crap, and put it all back together.

And the reason they said it happened to him, something genetically in our family that makes those veins do that. What do I want to do with cocaine

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for? It is just —

THE COURT: I think we’re far afield.

MR. WEINBERG: Is this what — all these incidents you told Mr. Minton?

THE WITNESS: Yes, I’m telling all this to Mr. Minton. I said, “In the end you may think –” and I told him, “As you sit here you can’t tell me when Scientology is going to be done with you. When are they going to be finished having you done whatever they want you to do? All you know, you have Wollersheim and you have McPherson.”

He said, “Jesse, you are being unreal.” He got mad. He cursed at me and said something. And his last words were, “Well, fuck it, you’re going to jail.”

BY MR. DANDAR:

Q Did you use the same language back at him?

A I said, “Bob, I’m sorry, you’re going to jail.

Stacy, you’re going to jail. I’m not having anything to do with this.”

I got up — he asked me to leave. He said, “Get out.”

I said, “Fine.”

Stacy follows me in the parking lot. She said, “You know, after all of the things Bob has done for you,

461

this is how you treat him?”

I’m looking, “What in the hell has Bob done for me that I have to perjure myself, I have to become a criminal because he thinks this is what I got to do to save him?

Uh-uh. He’s not done anything for me. And there is only one person can sell my soul. That is me. I already sold my soul to this organization one time and I got it back. Bob Minton is in no position to offer my soul to them.”

And I told her that. And we really haven’t talked that much since.

Q Well, now, was there a point in time when Bob Minton was coming over to your house after that for barbecue?

A Well, again, we have been friends a long time. This was another bridge of disagreement, blowup, everybody cursing, but we have such history. Even as I sit here today, I can’t fathom not talking to him once or twice a week.

So, you know, we’re talking again.

“Look –” Stacy said, “Look, this is going to blow over with or without you. We’re going to make sure.”

So I said, “Okay, well, then if we’re not doing this, could we still be friends?”

They love to come over to the house. We barbecue and have little parties. “Sure.”

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But then he called his lawyer and he was told not to come.

Q This is while the hearing is going on in this courtroom?

A Yes. They want to tell me what is going on. They want me to be a part of it because I have been since the beginning. But I can’t because of what they’re doing.

Q Did Bob Minton want to close down the LMT?

A No.

Q Whose idea was that?

A I don’t think it was any one person’s idea. Well, if it was anybody’s idea, I think it was Stacy’s, because the LMT was being used as a vehicle to get to Bob. And —

THE COURT: I think it sounds — this must be allowed to start at 4:30, but it is giving me a headache. Is this a good stopping point?

MR. WEINBERG: Yes — I’m sorry.

MR. DANDAR: This would be — this would be fine.

THE COURT: They probably are allowed to start up at 4:30.

MR. WEINBERG: I thought I was having a ringing in my ears, which I do have an ear issue.

THE COURT: So we’ll go ahead and quit. We’ll start up at 9 o’clock. Mr. Prince —

463

MR. WEINBERG: Remember you said ten?

THE COURT: Oh, I did. Ten o’clock tomorrow.

Ten o’clock tomorrow. I think I told you this before, but if I didn’t, let me remind you: While you are on the witness stand, I did give you permission to speak with Mr. Dandar because of the long break, but now, like overnight,  you and he can’t talk.

THE WITNESS: Okay.

THE COURT: Okay? I mean, you can talk about something else, but you can’t talk anything about your testimony or about this case. Of course you can’t talk to the other side, you can’t talk to anybody while you are on the stand about this case or your testimony. Okay?

THE WITNESS: Yes, your Honor, I understand that.

THE COURT: We shall be in recess.

MR. FUGATE: Judge, I have one issue on the E-Mails. And I’ll be really quick.

THE COURT: Okay.

MR. FUGATE: There are, to my understanding, about 3,000 E-Mails. And during the break —

THE COURT: Have you-all come up with any agreement as to a list?

464

MR. FUGATE: That is what I want to talk to you about. I went over to see, there is a list that prints out all of the ones that they were able to recover from the various hard drives. And I have found a series of — on that list of E-Mails that related to Peter Alexander and Patricia Greenway, and I have left a list of those with Mr. Keane.

And then I understand that Mr. Dandar indicated that those shouldn’t be produced because Ms. Greenway is a consultant. And, you know, in this hearing he said she wasn’t.

I don’t really care what she is today. But back during the time that she was at LMT prior to this hearing beginning, which is where all these E-Mails generate from, I don’t think they would be covered as a consultant —

THE COURT: Counsel, I can’t deal with something that won’t be agreed to with this noise. That is why I stopped this hearing. We’ll take this up first thing in the morning, and hopefully we won’t have any noise and we’ll get it done then.

Ten o’clock tomorrow. Bring it to my attention then.

MR. FUGATE: All right.

THE COURT: All right. Thank you all.

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(WHEREUPON, Court is adjourned at 4:50 p.m.)

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 9th day of July, 2002.

______________________________
LYNNE J. IDE, RMR

Notes

Declaration of Jesse Prince (December, 1999)

Daniel A. Leipold, State Bar No. 77159
LEIPOLD, DONOHUE & SHIPE, LLP
960-A West Seventeenth Street
Santa Ana, CA 92706
Telephone: (714) 796-1555
Facsimile: (714) 796-1550

Craig J. Stein, State Bar No. 98041
GARTENBERG JAFFE GELFAND & STEIN LLP
11755 Wilshire Boulevard, Ste. 1230
Los Angeles, CA 90025-1518
Telephone: (310) 479-0044

Ford Greene, State Bar No. 107601
HUB LAW OFFICES
711 Sir Francis Drake Blvd.
San Anselmo, CA 94960
Telephone: (415) 258-0360

Attorney for Plaintiff,
LAWRENCE DOMINICK WOLLERSHEIM

SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES

LAWRENCE DOMINICK WOLLERSHEIM

Plaintiff,
vs.
CHURCH OF SCIENTOLOGY OF CALIFORNIA
Defendant
Case No.: C 332 027

Honorable Charles W. McCoy
Department 24

SUPPLEMENTAL DECLARATION OF JESSE PRINCE1

I, Jesse Prince declare as follows:

1. I am over 18 years of age and currently reside in the State of Illinois, County of Cook. This declaration is of my own personal knowledge and if called upon to testify to the facts herein I could and would be competently able to testify thereto.

MY PARTICIPATION IN SCIENTOLOGY
THE SEA ORGANIZATION

2. I joined the Sea Organization, commonly referred to as the Sea Org, in September of 1976. The Sea Org is a para-military organization that manages and controls all of the Scientology Organizations and related entities that exist in the world. I was also required to sign a billion year contract at the time I was recruited. Within a week, I entered the first Sea Org indoctrination program named the Estates Project Force. The Estates Project Force consists of several levels of indoctrination named “Product Levels.” On these “Product Levels,” I was indoctrinated in Scientology ethics and justice procedures and the history of the Sea Organization. I was invasively interrogated (called confessional in Scientology) and took a mission school-training course, among other indoctrination courses. Flag Order 3155RC, entitled “The Basic Sea Org Training Program,” details the training required for persons newly recruited to the Sea Org. A true and correct copy of this document is attached hereto as Exhibit “HHH-99.” From the very beginning, through indoctrination from these courses, I learned that the Sea Org managed all Scientology Organizations and related entities such as Scientology Missions International (SMI), World Institute of Scientology Enterprise (WISE) and Narconon, to name a few. The length and breadth of the doctrine of the Sea Org is detailed and codified in issues named “Flag Orders.” The primary business of the Sea Org is missions. One definition of “mission” in Sea Org terms describes an activity whereby two or more Sea Org members go to a remote Scientology organization or enterprise and take over the activity for the purpose of getting the activity to make more money which, in turn, benefits the Sea Org financially. The governing policy of the type of mission referred to above, is to cause the activity (Organization) to make money, then make more money, then make other people produce so as to make money. See HCO Policy Letter 9 March 1972 “Income Flows and Pools,” a true and correct copy of which is attached hereto as Exhibit “QQ-99.” These same missions are authorized by the Sea Org to use Scientology ethics and justice procedures. This authority gives these types of missions total authority to remove and demote personnel, including corporate officers and executives in any Scientology Organization, corporation or Scientology-related entity as it sees fit. See Exhibits: “M-99,” “Y-99” and “FF-99,” which are true copies of the original documents. See also, Sea Organization Central Bureaux Order 621 29 November 1979 “By Pass of Management Sector Handling of,” a true copy of which is attached hereto as Exhibit “RR-99.”

3. The success of the Sea Org is primarily measured by its income. Sea Org income is defined as “the amount of money received by the corporation (Sea Org) after the allocation to Sea Org and Scientology Organizations” [translated, this means each and every Sea Org organization as well as each and every Scientology organization world wide sends to the Sea Org all monies remaining after the basic necessities (bills and payroll for staff) of the individual organization are paid and before management expenses are taken out; this is the classic double bite which normally reduced the Sea Org and Scientology Organization staff payroll allocation]. This is according to Hubbard policy letter of 9 March 1972, called “Income Flows and Pools, Principles of money management,” a true copy of which is attached as Exhibit “QQ-99.” This “policy” was written by L Ron Hubbard. During my tenure in the Sea Org, I executed many of these missions within the United States and other countries of the world.

COMMAND STRUCTURE AND HIERARCHY OF THE COMMODORE’S MESSENGER ORGANIZATION AND THE SEA ORGANIZATION

4. Until his death in 1986, L. Ron Hubbard was the unchallenged dictator of the entire Scientology enterprise. L. Ron Hubbard designated himself “Commodore”. In the hierarchy of the Sea Org, “Commodore” is the highest rank. L. Ron Hubbard created a “statistic system” for every function and activity of Sea Org and Scientology organizations and micro-managed this created “statistic system.” According to his many written policies, the best thing a Sea Org member or Scientologist could do was to always have “statistics” going up. Hubbard authored, or had others author, many thousands of detailed instructions and directives intended to teach his flock how to keep the “statistics” going up. He wrote or had written Polices, Flag Orders, Bulletins and Executive Directives concerning every aspect of the operation of the Sea Org and Scientology organizations. Sea Org members and Scientologists are required to follow these instructions and orders of Hubbard to the letter. This is documented and made very clear in a policy letter written by Hubbard, entitled “Keeping Scientology Working.” This policy letter declares that it is a “criminal offense” not to follow any L. Ron Hubbard instruction to the letter. These crimes are punishable through Scientology ethics and justice procedures.

5. Next in authority in the Sea Org hierarchy are the “Commodore’s Messengers.” L. Ron Hubbard authored Flag Order 3729, also known as Executive Directive 106 Commodore’s Messenger Organization (CMO), entitled “Commodore’s Messengers.” This issue is one of many directives and instructions on how to be a “good” Commodore’s Messenger. In the above issue, Hubbard shares his total authority over his Sea Org and Scientology Empire with others who have been trained to think and act in the same way as Hubbard himself. He designated his “messengers” as emissaries of himself. This same issue was issued to all Sea Org members with the instruction that all were to recognize his messengers as an extension of himself. All were instructed to show his messengers the same respect and courtesy as his flock of Sea Org members and Scientologists were required to show Hubbard, the single highest authority of the Sea Org and Scientology empire he created. Messengers had complete authority to go within any Sea Org, Scientology, or Scientology-related entity. A true and correct copy of Flag Order 3729 is attached hereto as Exhibit “UU-99.” As a note, only Sea Org members are ever eligible to become Commodore’s Messengers.

6. There is a hierarchy within the Commodore’s Messengers Organization. The top messenger, also known as the “Commanding Officer,” commands and orders all other messengers within the organization of messengers. The top Commodore’s Messenger in Scientology is David Miscavige. There are also subordinate “In Charge” positions within the messenger organization. An In Charge would have the authority to command and order lesser messengers, Sea Org Members and any Scientologist if it meant complying with an order from a higher messenger or L. Ron Hubbard himself. Two issues written or ordered by L. Ron Hubbard, entitled CMO Command Channels, issued 15 June 1976 and issue CMO Regulations, issued 11 Jan 1976 are among the many directives that define the authority of the Commodore’s Messenger Organization. A true and correct copy of CMO Command Channels is attached hereto as Exhibit “TT-99;” a true and correct copy of CMO Regulations is attached hereto as Exhibit “SS-99.”

7. There is also a hierarchy among the different messenger organizations. The most senior messenger organization in all of the different messenger organizations is “The Religious Technology Center” (RTC). This is documented in the many different “Command Channels” booklets issued and authored, and/or authorized by RTC since the early 80s. See Exhibit “X-99.”

8. The next command level below RTC is called “The International Watchdog Committee.” The Watchdog Committee was created with the purpose of overseeing the activities of the Guardian’s Office and Scientology management bodies in order to “keep Scientology working.” It is a senior management committee that manages all sectors of Scientology, i.e., all Sea Organizations, all Scientology Organizations International, and related Scientology entities such as Scientology Missions International (SMI), and World Institute of Scientology Enterprise, International (WISE). See HCO PL 22 December 1981, “International Watchdog Committee,” a true and correct copy of which is attached hereto as Exhibit “VV-99.”

9. The next level of hierarchical authority within the messenger organizations and Scientology Enterprise is the “Commodore’s Messengers Organization International” (COMINT). This body executes the orders and commands of the Watchdog Committee, and manages and supervises the many other Commodore’s Messenger Organizations within the United States and abroad. (See Exhibit “VV-99.”)

10. Next in the chain of hierarchy is the Office of the Executive Director International (EDINT). The Executive Director International orders and commands the senior-most Sea Org executives over all the different management sections of the Sea Org, Scientology Organizations International, and every other Scientology related entity. These executives in turn order and command all areas of the Scientology empire. This office is not a Commodore’s Messenger Organization, but it is a Sea Org organization.

11. There are descending levels of the hierarchical chain of command from this point, as described in Scientology’s Command Channel booklets. From early 1983 until January 1987, I was the second in command of the Religious Technology Center. I was identified by RTC attorney Samuel Rosen as such in Federal Court in Denver on August 20, 1998. See Exhibit “C-99,” attached hereto.

A CLASSIC EXMAPLE OF THE APPLICATION OF “MISSION TECH” TO BYPASS CORPORATE LINES OF AUTHORTIY

12. In October of 1982, I was part of a Sea Org Mission that was sent to San Francisco to “handle” the Mission Holders of the Church of Scientology. The Mission Holders were Franchisees of Scientology who offered introductory
courses in Scientology to the public.

13. L. Ron Hubbard was upset with the Mission Holders because he felt that the Mission Holders in general were withholding tithes owed to Sea Org International Management. L. Ron Hubbard had also sent down orders stating that several Sea Org members in high leadership positions within the Commodor’s Messenger Organization International (“CMO Int.”) and the Office of the Executive Director International (“ED Int.”) were dissatisfied with Scientology management and were siding with the Mission Holders. L.Ron Hubbard’s orders went to David Miscavige and they were clear: Handle this insurrection and crush anyone who protested.

14. The missionaire in charge of the San Francisco Mission Holder’s Mission was David Miscavige. Mr. Miscavige is flat out attempting to deceive this court in his declaration when he characterizes his presence at this conference as that of an “invited” master of ceremonies. Mr. Miscavige was the Missionaire I/C (In Charge) and was running the entire operation. Further, his “invitation” certainly did not come from the Mission Holders, it came in the form of Mission orders from the Commodore himself, L. Ron Hubbard. Lest there be any doubt whatsoever about the truth of what I am saying, I invite the court to examine Exhibit “L-99,” a true and correct copy of which is attached hereto.

15. Exhibit “L-99,” paints a far different picture of the San Francisco Mission Holder’s Conference than the “Shore Story” Scientology is telling. Exhibit “L-99,” THE SEA ORG MOVES IN, is a newsletter that shows clearly how Miscavige and the Sea Org characterized the San Francisco Mission Holder’s conference for the purpose of letting the staff and paying public of Scientology know who had won the power struggle between the Sea Org and the Mission Holders. It gives a far truer picture of what was going on at this conference than even the published “transcript” of the conference, because the transcript was heavily edited before Miscavige approved it for publication.

16. I was part of the mission headed up by David Miscavige that was ordered to handle the San Francisco Mission Holder’s Conference. The first thing the mission did upon its arrival in San Francisco was to visit the local Scientology Organization. Missionaire I/C, David Miscavige immediately bypassed all corporate lines of authority and started an inspection of the organization. He decided that the Executive Director of the organization was incompetent and he viciously interrogated him with an e-meter, (a form of lie detector), physically abused him, and removed him from his position on the spot.

17. From the local Org, we proceeded to the Mission Holder’s Conference. By this time, David Miscavige had really worked himself into a lather, and he declared two Mission Holders “Suppressive Persons” and expelled them on the spot. This is brazenly bragged about in the issue “The Sea Org Moves In.” The doors to the conference room were locked and guarded. Miscavige then lined up approximately 20 other Mission Holders, most of whom were crying and terrified, and told them to get their checkbooks ready as they had been “ripping off” Scientology Organizations of their “rightful income” for too long. In reality, Miscavige and several others just took whatever amount of money they wanted out of the Mission Holder’s corporate accounts.

18. Miscavige introduced Larry Heller, attorney for Scientology who was personally hired by Miscavige, who informed the Mission Holders that the “New Tough Management” intended to prosecute and jail anyone who did not comply with the orders and directions of the new management.

19. Lyman Spurlock, a senior Sea Org executive who was one of Miscavige’s inner circle, threatened the Mission Holders with prosecution and explained that the Sea Org now had the power to do this to the Mission Holders because of all the new corporate changes that were designed to exert more control over the Mission Holders.

20. The “new management” is pictured in their Sea Org uniforms at the speaker’s table in Exhibit “L-99.” These are the same people who manage Scientology today, and they do it in the same manner, through their positions of power in the Sea Org.

21. When all of the speakers were done, each and every Mission Holder was viciously interrogated by multiple missionaires using the e-meter. Then each mission holder was required to have a mug shot taken, one from the front and one from the side, in the same way police commonly do. After the mug shots were taken, the Mission Holders were required to write checks from their corporate accounts for the maximum amount of money possible.

22. When all the Sea Org Missionaires returned to Gilman Hot Springs, which is the true home of Scientology’s International Management, the results of the mission were sent directly to L. Ron Hubbard. The Commodore was very pleased with the report he got from David Miscavige and decided to make it a policy to run this mission in European countries where Scientology existed. I was sent on this mission along with others to do the same activity to Mission Holders in Copenhagen, Denmark.

23. This activity continued in other locations, executed by the International Finance Police under the direction of the International Finance Dictator located in the Commodore’s Messenger Organization International. All of this was under the dictatorship of Miscavige.

ATTACK THE ATTACKER

24. Attached hereto as Exhibit “A-99,” is a true and correct copy of a Scientology directive titled “Attacks on Scientology, Additional Policy Letter,” which states, in part: “This is the correct procedure:

“(1) Spot who is attacking us.

“(2) Start investigating them promptly for FELONIES or worse using our own professionals, not outside agencies.

“(3) Double curve our reply by saying we welcome an investigation of them.

“(4) Start feeding lurid, blood, sex, crime actual evidence on the attackers to the press.

“Don’t ever tamely submit to an investigation of us. Make it rough, rough on attackers all the way…

“Never talk about us – only them. Use their blood, sex, crime to get headlines. Don’t use us…

“Shift the spotlight to them. No matter how. Do it!”

25. Attached as Exhibit “AAA-99,” is A true and correct copy of the Committee of Evidence and “Declare” statement of Alex Sibersky, and attached as Exhibit “BBB-99,” is a true and correct copy of the Committee of Evidence and “Declare” statement of David Mayo.

26. I was a member of the committees of evidence documented in Exhibits “AAA-99” and “BBB-99.” There was no fairness involved in these supposed “justice” actions. Hubbard considered that these people were “disaffected with management,” and disloyalty (meaning questioning anything at all) is the worst crime a Sea Org member can commit. What was going to happen to these people was already pre-determined by Hubbard and executed by Miscavige. We were required to sign our names to a document that had already been prepared. I have personal knowledge that such actions are
based on long-standing policies.

27. Attached hereto, as Exhibit LL-99 is a true and correct copy of Flag conditions Order 7068, 27 December 1982, SURPPRESSIVE PERSONS DECLARE pertaining to eight separate individuals.

28. With regard to my former position as a high-ranking executive in the Sea Org, even Scientology attorney Samuel Rosen told the judge in the FACTNet hearing in Denver that I had been second in command of all of Scientology (See Exhibit “C-99”). I was an expert witness on the subject of Scientology on behalf of RTC in the Robin Scott/David Mayo litigation. In addition, on December 31, 1986, Miscavige himself introduced me as “Deputy Inspector General” at a New Year’s Eve event at the Flag Land Base in Clearwater, Florida. I gave a briefing at that event about how RTC was going about crushing people who tried to apply any part of Scientology technology without paying for it, an issue which was part of the Scott/Wollersheim II litigation. (A true and correct copy of a audio tape of the Scientology New Years Event of 86/87 is contained on Exhibit “XX-99,” attached to this motion.)

29. I did give two taped interviews, which contradict my statements in this declaration concerning Miscavige’s control of Scientology. The first interview occurred shortly before Halloween in 1992. With my wife, I was trying to get permission to leave the secret compound in Gilman Hot Springs, and they would not allow us to leave unless I agreed to state on audiotape that I was leaving on my own free will, that I was happy and pleased with being incarcerated against my will on the Rehabilitation Project Force, that I had committed many crimes in Scientology and Scientology had helped me overcome these criminal tendencies, that Miscavige was not the dictator of Scientology, and that I had never witnessed any illegal activities being committed within Scientology. I was also required to make self-denigrating statements on this tape which were not true. I was threatened by Marty Rathbun and Mike Sutter that if I did not agree to make this taped statement, I would become the target of Fair Game. The giving of “interviews” such as I went through are part of the policy of Scientology and anyone leaving the Sea Org is required to “route out” pursuant to policy or be declared.

30. The second interview happened in Boston in 1994. Mike Sutter called me and said that he wanted to see me to find out how I was doing. He made it sound like a friendly chat that we were going to have. At that time I was still afraid of the imagined power these people had over me. I agreed to meet with Mike Sutter and Scientology attorney Earl Cooley at Cooley’s office in Boston. Instead of a friendly chat, it turned into an interrogation in which they told me they were doing poorly in some of their legal cases and demanded to know if I was assisting “the enemy.” Before I was allowed to go, they drilled me on what to say and then put it all on tape. They took information from my auditing folders and kept “reminding” me of things I had said in sessions.

31. These taped statements are Scientology’s way of attempting to destroy the credibility of a former Scientologist who has knowledge that can harm the organization in case that individual later decides to come forward to expose the truth.

32. Until the reorganization of 1982, in which RTC was formed, it had been CSC that registered the trademarks for Scientology. RTC was specifically created to take over that function from CSC. As far as I know, ASI took over the function of overseeing the copyrights.

I declare under penalty of perjury that the foregoing is true and correct under the laws of the State of California executed this __ day of December 1999, at Tampa, Florida

_____________________________
JESSE PRINCE

Notes

Declaration of Michael Lee Hertzberg (September 20, 1999)

Gerald L. Chaleff, SBN 39552
ORRICK, HERRINGTON & SUTCLIFFE LLP
777 South Figueroa Street, Suite 3200
Los Angeles, California 90017-5832
Telephone: (213) 629-2020

William. T. Drescher, SBN 93737
LAW OFFICES OF WILLIAM T. DRESCHER
PMB 338
23679 Calabasas Road
Calabasas, California 93102-1502
Telephone: (818) 349-8100
Attorneys for Non-Party
CHURCH OF SCIENTOLOGY INTERNATIONAL

Samuel D. Rosen, pro hac vice
PAUL, HASTINGS, JANOFSKY & WALKER LLP
399 Park Avenue, 3 1 st Floor
New York, New York 10022-4697
Telephone: (212) 318-6000

Alan K. Steinbrecher, SBN 79201
PAUL, HASTINGS, JANOFSKY & WALKER LLP
555 South Flower Street, 23rd Floor
Los Angeles, California 90071-2371
Telephone: (213) 683-6000
Attorneys for Non-Party
RELIGIOUS TECHNOLOGY CENTER

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

LARRY WOLLERSHEIM,

Plaintiff,

vs.

CHURCH OF SCIENTOLOGY OF
CALIFORNIA,

Defendant.

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Case No. C 332 027

DECLARATION OF
MICHAEL LEE HERTZBERG
1

DATE: October 15, 1999
TIME: 8:30 a.m.
DEPT: 24
Judge Charles W. McCoy, Jr.

I, Michael Lee Hertzberg, hereby declare and state:

1. I am an attorney, admitted to practice before the courts of New York State, the District of Columbia Bar, Ninth Circuit Court of Appeals and the United States Supreme Court. I make the following statement of my own personal knowledge, and if called to testify thereto, I could and would do so competently.

2. I was counsel of record in Aznaran v. Church of Scientology of California, et al. I was present in May of 1994 in Dallas, Texas when Vicki Aznaran settled her then pending litigation against several churches of Scientology and related organizations. I was present to provide legal advice to the representatives of the defendants who were negotiating directly with Ms. Aznaran. She was represented by her attorney, Karen MacRae of Dallas.

3. On May 19, 1994 when Ms. Aznaran settled her litigation, she executed several declarations. Annexed hereto as Exhibits A – E are true and correct copies of the declarations executed by Ms. Aznaran. Her declarations cover a wide range of subjects. The most comprehensive declaration is annexed hereto as Exhibit A. This declaration provides an overview of her experience as a litigant against churches of Scientology, tactics used by individuals litigating against churches of Scientology, specific allegations from her complaint that she formally repudiated and ordered her attorneys to withdraw, the payment of thousands of dollars to witnesses for sworn statements against the churches of Scientology, and the addition of eleven pages of one of Ms. Aznaran’s declarations by an attorney representing opponents of Scientology, Graham Berry.

4. The remaining declarations (Exhibits B – E), cover specific topics related to Ms. Aznaran’s experiences as a litigant against churches of Scientology. Specifically, these declarations cover the following topics:

– Litigation tactics by Lawrence Wollersheim and Gerry Armstrong (Exhibit B);

– A specific refutation of claims that her testimony supports the contention that Church officials have destroyed documents in litigation (Exhibit C;

– Ms. Aznaran’s knowledge regarding Stacy Young (one of Mr. Wollersheim’s witnesses) (Exhibit D);

– In this declaration Ms. Aznaran also repudiates allegations of corporate irregularities similar to those being made in the instant case (Exhibit A);

– A declaration in which Ms. Aznaran explains why she executed the other declarations and her response to what she anticipates other apostates will say about her for having revealed their tactics (Exhibit E).

5. I invite the Court’s attention to particular passages relevant to the claims at issue here. Ms. Aznaran signed her declarations in May 1994, a year after her most recent statement cited by Wollersheim in support of his motion. In one declaration Ms. Aznaran explains how witnesses have been conditioned to sign affidavits to support whatever arguments opponents of churches of Scientology wish to “prove”:

The abusive device most consistently utilized by litigants and counsel adverse to the Church occurs in connection with the filing of declarations or affidavits. It is common knowledge among the stable of disaffected ex-Scientologists who supply such sworn statements that the attorneys dictate the desired content of such testimony with the primary, often sole, purpose of presenting inflammatory accusations that prejudice the Church in the eyes of the court. In such declarations or affidavits, context, the truth, and relevance to the issues in the case are disregarded altogether. As time has passed and this technique has evolved, anti-Church litigants and their counsel have become more and more emboldened in making such declarations and affidavits because the tactic has proven to be so effective in poisoning courts and juries against the Church.

Thus, it has become a routine practice of litigants to make accusations against the Church, including even false allegations of threats of murder, which would be summarily thrown out of court as unsupported and scandalous in other litigation. There is a group or “team” of anti-Scientology witnesses who are being paid for their testimony, and based on my experience, this testimony is being altered and falsified, either by the witnesses themselves or the attorneys. (Ex. A, Declaration of Vicki Aznaran; 12, 17, 19.)

6. Ms. Aznaran even predicted that the attached declarations would be attacked by adverse litigants whose litigation tactics she has exposed:

On May 19, 1994, my husband and I each executed a series of declarations under penalty of perjury addressing a variety of issues. Among those declarations are one of mine that demonstrates that perhaps the most common litigation ploy that is used against Churches of Scientology is for opponents to submit false, inflammatory and accusatory declarations which make wild accusations irrespective of their falsity, lack of relevance, or lack of first hand knowledge.

I am executing this declaration on May 19, 1994 because I am certain that litigation opponents of the Church will react to one or more of my other contemporaneously dated declarations in precisely the fashion I describe in the preceding paragraph.

(Ex. E, Declaration of Vicki Aznaran; 2, 3.)

7. Ms. Aznaran identifies Stacy Young as employed by Graham Berry, Mr. Leipold’s former co-counsel in Wollersheim, to create inaccurate affidavits:

I know from subsequent conversations I have had that Andre Tabayoyon is similarly employed, as are Vaughn and Stacy Young and others, each paid to create declarations for Mr. Berry when he needs them. On the basis of my knowledge of the Church and the declarants, I can state that these individuals are not “experts” ‘in any recognized sense of the word as I understand it. They are nothing more than witnesses who are being paid to make sworn statements against the Church. More than just being paid, they are actually employed by Mr. Berry as a source of signed declarations of testimony or as a ” source” of allegations, the need for such is decided by him. (Ex. A, Declaration of Vicki Aznaran; 22.)

That Vaughn and Stacy Young are experts is not true. They are being called experts not due to expertise in Scientology but in order to collect insurance money for their testimony.

What this creates, and what the Youngs are part of, is a stable of people who, for pay, write declarations. (Ex. D, Declaration of Vicki Aznaran; 7, 8.)

8. Ms. Aznaran also swore to Ms. Young’s lack of knowledge of inside workings of churches of Scientology, both corporately and ecclesiastically:

In my staff capacities in the early 1980s, and later in my executive positions in the Religious Technology Center, I was directly or closely involved in meetings with senior staff members of various Church corporations. These senior staff made significant or major decisions which affected the future of the Church. I know that neither Vaughn nor Stacy Young were included in such senior decision-making processes. They were never senior or key Church executives. They were not consulted regarding, nor were they privy to, the meetings where major issues were discussed an decisions made.

I am informed that the Youngs have made claims to specialized knowledge about the corporate status and structure of the Church. Such claims are false. Neither of the Youngs were in a position to have detailed knowledge of the corporate and fiscal structures and operations of any Church of Scientology. In fact, Vaughn Young worked in the area of Public Relations for the entire time that I was acquainted with him. Stacy was primarily a writer in the Church public relations department. (Ex. D, Declaration of Vicki Aznaran; 4, 5.)

9. Ms. Aznaran repudiated allegations of corporate irregularities that were contained in her complaint against the Church of Scientology of California. These allegations are very similar to those being made by Wollersheim in the instant case:

Paragraph 16 of the complaint included the allegation that I had been employed as a “missionaire” to remove assets of Defendant Church of Scientology of California to overseas trusts where they could not be accessed. This allegation was false, and it was not an allegation that either my husband or I requested be included in the complaint….

It was also alleged in paragraph 16 of the complaint that I was employed as a”missionaire” to “set up sham corporate structures to evade prosecution generally.” This allegation is also false. (Ex. A, Declaration of Vicki Aznaran; 8, 9.)

10. In another sworn declaration Ms. Aznaran identifies Wollersheim witness Gerald Armstrong as the source of a litigation technique utilized by this small group of witnesses:

The fundamental premise upon which the Church’s adversaries and their lawyers operate is the likelihood that courts and juries are willing to believe any allegation made against the Church by a former member, without regard to plausibility, contrary evidence or the true facts. That concept was most succinctly expressed, on videotape, by anti-Scientology litigant, Gerald Armstrong, when he state that a lack of documents or evidence was no impediment to litigating against the Church when the litigant can “just allege it.” The active pursuit of that litigation approach has now led to the formation of a small group of disaffected Scientologists who are now employed by an even smaller number of attorneys who are making a practice of litigating against the Church. This stable of witnesses can be relied upon to furnish ” corroboration” for any allegation which an attorney wishes to make against the Church in pleadings, at deposition, in affidavits, and ultimately in trial testimony. (Ex. A, Declaration of Vicki Aznaran; 5.)

11. Ms. Aznaran even addressed Larry Wollersheim’s allegations:

While I was in the Church I witnessed the “Fair Game” allegations made by Gerry Armstrong and Larry Wollersheim in their litigation against the Church. My position in the church at the time gave me broad access to what was occurring and I would have known were the allegations made by Armstrong and Wollersheim true. Wollersheim, for example, made the allegation that a pipe bomb was found on his parent’s lawn and, without any corroboration, blamed the Church. I know from my own personal knowledge that this outrageous allegation of Church involvement is absolutely false. During the Wollersheim trial, rumors began to spread throughout the trial courtroom that Judge Ronald Swearinger had been followed, his tires had been slashed, and his pet dog drowned, and that the Church was responsible for that supposed activity. All of those allegations of Church complicity were false, as I now personally attest. Armstrong alleged the Church was trying to kill him and this allegation was just made up. I know of its falsity of my own personal knowledge. Both Armstrong and Wollersheim, continue to make the same type of outrageous allegations of Fair Game to forward their litigation to this day, due ‘in no small measure to the fact that they practiced Fair Game so effectively in their earlier, victorious litigation against the Church.” (Ex. B, Declaration of Vicki Aznaran; 12.)

12. An allegation relied upon by Wollersheim is that David Miscavige ordered Vicki Aznaran and Jesse Prince to destroy documents, including documents compelled to be produced in this case. However, Ms. Aznaran states in another declaration:

During the time I was President of RTC, we fully complied to all discovery requests, I have never received an order from David Miscavige, Norman Starkey or Lyman Spurlock to destro any documents related to litigation and I have no reason to believe that the Church would destroy any documents related to the consolidated cases… (Ex. C, Declaration of Vicki Aznaran; 8.)

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.

Executed this 20th day of September, 1999 at ______________.

MICHAEL LEE HERTZBERG

Notes

  1. Document source: http://bernie.cncfamily.com/sc/Aznaran.htm

Jesse Prince: Earle Cooley’s memory lapse with the Boston Globe (October 9, 1998)

Title: Earle Cooley’s memory lapse with the Boston Globe1
Author: jesse77@gte.net (Jesse Prince)
Date: Fri, 09 Oct 1998 22:19:48 GMT

I recently read a column by Alex Beam in the September 16 edition of the
Boston Globe. It was titled  “Boston U’s Scientology Connection” and it was
about Earle Cooley. One thing that really caught my eye was the part where
Beam said that “whenever Cooley and I discussed the excesses committed by
the church – the harassment of a journalist, for instance – he said he had
no knowledge of illegal activities.” I had to laugh when I read this. It
was the private kind of laugh a person has when they have knowledge or
information not known by many others. Cooley said he had no knowledge of
illegal activities being done by Scientology.  I offer here another voice
based on the experience of having been there.

In 1985, when I was Deputy Inspector General for External Affairs for the
Religious Technology Center (RTC), I hired Earle Cooley to represent RTC in
a RICO (Racketeering Influenced Corrupt Organizations) lawsuit against
David Mayo’s Advance Ability Center (AAC), a Scientology splinter group, as
lead counsel. This decision was not made by the board of directors of RTC.
This decision was made by a trustee of RTC who is also the managing agent
of the entire Scientology empire, David Miscavige. At the time I was on the
board of directors of RTC. As new as he was to Scientology as an entity,
Cooley was eager to please because, in my opinion, he correctly smelled a
lot of money. You know, the good old American way. Cooley quickly made
himself very popular with Miscavige and was soon retained as lead counsel
for all major Scientology litigation.

These are the facts:

Scientology has and operates an intelligence network which is orchestrated
from the highest levels of the organization and extends throughout the
world. The people who run the intelligence network are in RTC, the most
senior organization within all of Scientology.

To give you an idea of how I came to have the information I am about to
tell you about Earle Cooley, in August of this year, in a hearing in U.S.
District Court in Denver, Colorado, current Scientology lead counsel Sandy
Rosen identified me as having been the #2 person in control of all of
Scientology. As he was saying this he might as well have said  to the judge
by implication, “Your  honor, here is yet another illustration of the fact
there is no actual corporate integrity in any of  Scientology’s
corporations.”  The intelligence operation of RTC was one area of  RTC that
I was responsible for. With the advent of the RICO case, legal and
intelligence operations consumed the majority of my day.  I had privilege
and access to many levels of intelligence operations and programmed
strategy against critics and enemies of Scientology.  From a privileged
position,  I also received daily reports of such activities as routine
information. The fact of the matter is that since L. Ron Hubbard’s death,
David Miscavige has been the self-appointed  managing agent of Scientology,
and it was upon his direct orders that I carried out the legal and
intelligence actions involving Earle Cooley.

It has been almost  six years since I left Scientology physically and
almost 3 years since I left them in my mind.  I guess it has taken me a
minute to wake up from Scientology, because I was there for 16 years.
That’s a long time, some people we all know haven’t even been alive that
long.l

Anyway, to bring a long story to the point, I was with Earle under the
conditions given above. Earle was fully aware of the tactical intelligence
capabilities of Scientology and took advantage of it to make a name for
himself, in my opinion. Wanna know why I think this? I’ll tell you.

The key piece of evidence provided in the RTC RICO case  for a preliminary
injunction against the aforementioned Scientology splinter group (AAC,
David Mayo) was a newly authored rendition of one of  Scientology’s most
sacred  (only to them) scriptures, NOTs. This is a well known acronym for
those that are familiar with Scientology. Suffice to say, the bottom line
is that NOTs was a good source of income for a market share that could
afford it . NOTs  is  very expensive and,  considering the fact that the
information contained in this “secret information” is so ridiculous, only a
fool would ask why upon first glance.  Scientology can and does condition
its parishioners into a mental state of utter foolishness in my humble
opinion., based on actual experience.

David Mayo was principle in the authorship of  the NOT’s materials as
practiced in Scientology today, but surrendered his rights to authorship,
or more correctly stated,  his co-authorship with LRH.  After Mayo was
expelled from Scientology he authored another version of NOTs  for his own
movement, and market share of dissident Scientologists  from which he found
success, much to the dismay of  Scientology. Believe it or not,  the point
of David’s rights to authorship  never  gained recognition in the RICO case
because Mayo’s lawyers never argued the point. I wonder if Mayo had a
lawyer hired by Scientology to represent him? Every NOTs issue bore the
initials DM, which stands for David Mayo, not David Miscavige. Now you  see
yet another example of why it takes more than an instant to recover
mentally from a dance with Scientology.

So deep was the deception in this case, that in his own defense Mayo never
questioned how Scientology  ever obtained a copy of his newly authored NOTs
issues being used against him in a court of law. The fact of the matter is
that RTC paid and hired an informant to steal these materials from under
Mayo’s nose.

Earle Cooley coached me for nearly ten hours before I was to appear as a
witness in the RICO preliminary injunction hearing in the case against
David Mayo. He told me how to answer questions when I was asked by Mayo’s
attorneys and also what I should say when Earle himself asked me questions.

The last question I asked Earle Cooley before I went on as a witness was
this, “What do I say if someone asks where I got the copy that I now submit
as evidence to the court, of Mayo’s newly authored NOTs materials?” Earle
Cooley told me to say that a concerned parishioner dropped it off at RTC
anonymously. Cooley was fully aware at the time of the fact that
Scientology paid an informant to steal Mayo’s NOTs  issues. For some weeks
before, like me, Cooley had been receiving reports and was being verbally
briefed by Marty Rathbun and David Miscavige on every intelligence
operation ongoing in Scientology. Now he had a chance to act out his own
fantasies and create or be part of creating new ideas to torment the
critics and enemies of Scientology. Why does almost every lawyer in America
think he’s an expert spy? I don’t know. Now it seemed I’d hired  Mr. Get
Smart Cooley to show and teach me how to lie in court. Again, amazingly,
the point never even came up.

I could go on at length with stories like this about Earle Cooley. But
maybe just this one story will help refresh his memory for the next time he
talks to a columnist for the Boston Globe.

This is how Earle Cooley walked in the door of  Scientology. Things only
got worse from his advice on how to carry out covert intelligence
operations, always “off the record. After the 1977 FBI raid the amount of
covert intelligence operations that were being done in Scientology had
diminished. But when Earle Cooley hooked up with Scientology, covert
operations started increasing again. Some trend Mr. Cooley got started.

Out of all the so-called “brilliant leaders” in Scientology during the time
I was there, the only major players that had a college education were the
lawyers. I’ll let you tell me what happened then. The old maxim applies:
Never give a sucker an even break, and the attorneys have played DM, who
never even finished high school,  for a total fool. Soon he will be thrown
away, just like he threw L Ron Hubbard away and for the same reasons.

It would be wrong for me to give Earle Cooley credit for more intellectual
prowess than he deserves. Other lawyers were involved who were much more
intelligent and much more highly paid than Earle Cooley.  Cooley had
criminal tendencies so he seemed to fit in well with Scientology.  Another
difference in the other lawyers is they never ever claimed to be
Scientologists, which was true. There was nothing Scientology could do for
these lawyers but pay them handsomely.  I believe for me to reveal or speak
against those particular attorneys could threaten my life.  However, in the
event of  death, what I know has been written down and will survive me. I’m
truly not worried about such a fate at this time, it’s out of my hands,
literally.

Alex Beam also wrote:

“I contend that Cooley is more than “just” a lawyer for Scientology. I say
he is deeply allied with one of the greatest anti-intellectual movements of
our time, and his activities are wildly incompatible with his status as top
official of a major American university.”

This conclusion could not be more accurate given the lack of education by
current Scientology managing agent David Miscavige. Not to mention the lack
of formal education by Scientology founder L Ron Hubbard. Hubbard has been
dead for nearly 12 years. He died mentally incompetent, a victim of his own
machinations.

I sure hope  Mr. Cooley and his conscience reacquaint.  Reason? It’s time
for him to be honest about his relationship with Scientology. The truth has
always been and will forever be stranger and more fascinating than a lie
could ever be.

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