582
           1        IN THE CIRCUIT COURT FOR PINELLAS COUNTY, FLORIDA
                                  CASE NO. 00-5682-CI-11
           2
           3
           4
                DELL LIEBREICH, as Personal
           5    Representative of the ESTATE OF
                LISA McPHERSON,
           6
           7              Plaintiff,
           8    vs.                                     VOLUME 5
           9    CHURCH OF SCIENTOLOGY FLAG
                SERVICE ORGANIZATION, JANIS
          10    JOHNSON, ALAIN KARTUZINSKI
                and DAVID HOUGHTON, D.D.S.,
          11
                          Defendants.
          12
                _______________________________________/
          13
          14
          15    PROCEEDINGS:        Defendants' Omnibus Motion for
                                    Terminating Sanctions and Other Relief.
          16
                CONTENTS:           Testimony of Jesse Prince.
          17
                DATE:               July 9, 2002.  Afternoon Session.
          18
                PLACE:              Courtroom B, Judicial Building
          19                        St. Petersburg, Florida.
          20    BEFORE:             Honorable Susan F. Schaeffer,
                                    Circuit Judge.
          21
                REPORTED BY:        Lynne J. Ide, RMR.
          22                        Deputy Official eCourt Reporter,
                                    Sixth Judicial Circuit of Florida.
          23
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           1    APPEARANCES:
           2
                MR. KENNAN G. DANDAR
           3    DANDAR & DANDAR
                5340 West Kennedy Blvd., Suite 201
           4    Tampa, FL 33602
                Attorney for Plaintiff.
           5
           6    MR. LUKE CHARLES LIROT
                LUKE CHARLES LIROT, PA
           7    112 N East Street, Street, Suite B
                Tampa, FL 33602-4108
           8    Attorney for Plaintiff
           9
                MR. KENDRICK MOXON
          10    MOXON & KOBRIN
                1100 Cleveland Street, Suite 900
          11    Clearwater, FL 33755
                Attorney for Church of Scientology Flag Service
          12    Organization.
          13
                MR. LEE FUGATE
          14    MR. MORRIS WEINBERG, JR.
                ZUCKERMAN, SPAEDER
          15    101 E. Kennedy Blvd, Suite 1200
                Tampa, FL 33602-5147
          16    Attorney for Church of Scientology Flag Service
                Organization.
          17
          18    MR. ERIC M. LIEBERMAN
                RABINOWITZ, BOUDIN, STANDARD
          19    740 Broadway at Astor Place
                New York, NY 10003-9518
          20    Attorney for Church of Scientology Flag Service
                Organization.
          21
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           1    MR. STEPHEN J. WEIN
                Battaglia, Ross, Dicus & Wein, P.A.
           2    980 Tyrone Boulevard
                St. Petersburg, Florida  33710
           3    Counsel for Robert Minton.
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           1              THE COURT:  You may be seated.  Okay, before we
           2         begin, two questions.  Have you decided when you
           3         want the trial date, Mr. Dandar?
           4              MR. DANDAR:  September.
           5              THE COURT:  All right.  Have you decided
           6         whether or not you need Mr. Rosen?
           7              MR. DANDAR:  No, I don't need Mr. Rosen.
           8              THE COURT:  All right.  Then I'm going to
           9         assume that -- I will go ahead and enter an order
          10         pro hac vice admitting Mr. Rosen, just in case.
          11         He'll be admitted, just for this purpose.  And I'll
          12         let you have --
          13              MR. FUGATE:  Should I prepare an order, Judge?
          14              THE COURT:  Do you mind?
          15              MR. FUGATE:  No.
          16              THE COURT:  Tell him to prepare an order,
          17         whatever.
          18              MR. FUGATE:  I'll do it.
          19              MR. DANDAR:  So, Judge, since we will start
          20         picking a jury for the trial in September, what
          21         specific date would that be?
          22              THE COURT:  The second week in September.
          23         Whatever that Monday is.
          24              MR. DANDAR:  All right.
          25              THE COURT:  You may proceed.
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           1              MR. DANDAR:  Thank you.
           2              THE COURT:  That, of course, assumes the motion
           3         to dismiss is not granted.
           4              MR. DANDAR:  I understand.
           5              THE COURT:  Mr. Lirot, are you still of the
           6         mind that if Mr. Dandar is removed as counsel, you
           7         are prepared on that date?
           8              MR. LIROT:  Hope springs eternal, Judge.  But
           9         yes, Judge, I'll be prepared on that date if need
          10         be.
          11              THE COURT:  All right.
          12    BY MR. DANDAR:
          13         Q    Mr. Prince, what I was trying to do before the
          14    lunch break was finish up on the meetings that you had with
          15    Mr. Minton and Stacy Brooks.
          16         A    Okay.
          17         Q    I believe we left off with your meeting with them
          18    when things got a little testy at the hotel for dinner.
          19         A    At the Radisson.
          20         Q    At the Radisson.  In my -- your note attached to
          21    your affidavit, you said you met with me before you met with
          22    them that Sunday.  So that was April 14th.
          23         A    Okay.
          24         Q    All right?  So let's go from then on.  What
          25    happened after April 14th?
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           1         A    Mmm --
           2              THE COURT:  I'm sorry, he met with you before
           3         he met with them?
           4              MR. DANDAR:  That same day.  That is where this
           5         handwritten note --
           6              THE COURT:  Right.  For some reason, I thought
           7         it was after.  But it was before?
           8              MR. DANDAR:  On this particular day he met with
           9         me at the mall with Mr. Lirot.  And that was
          10         April 14th.
          11              THE COURT:  In the afternoon?  Then he went
          12         there in the evening?
          13              MR. DANDAR:  Then he went there.
          14    BY MR. DANDAR:
          15         Q    What happened after April 14th?
          16         A    Mmm, well, contact again -- and I think I
          17    mentioned I had the one phone conversation with Mr. Minton
          18    where I invited him over to my house.  But they -- they
          19    talked to me -- or got messages to me via my fiancee.  They
          20    would talk to her.  And if anything happened -- we wouldn't
          21    talk, we were not talking.
          22         Q    And what messages did you receive from Mr. Minton
          23    and Ms. Brooks that way?
          24              MR. WEINBERG:  Objection.  Hearsay, your Honor.
          25              THE COURT:  Hearsay.  That would have to be
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           1         hearsay.  I mean, that would have nothing to do with
           2         Mr. Minton's state of mind or anything in this
           3         proceeding, so you would have to, at the very least,
           4         bring in the other person.
           5    BY MR. DANDAR:
           6         Q    So you never talked with Mr. Minton or Ms. Brooks
           7    since then directly, one-on-one?
           8         A    I talked with Mrs. Brooks.  Mmm, she just told me
           9    that everything was going to be fine, regardless of whether
          10    or not I agreed to go with them or participate in activities
          11    with them with Scientology.  She just told me things were
          12    going to be okay.
          13         Q    When did Ms. Brooks stop paying you your monthly
          14    income?
          15         A    Either March or April.
          16         Q    And you said before that you went to Denis
          17    deVlaming's office and spoke with him, and he couldn't help
          18    you because of the conflict of interest.
          19              Did you go to any law enforcement?
          20         A    Well, it's not entirely true to say that
          21    Mr. DeVlaming couldn't help me.  What Mr. DeVlaming did do
          22    is refer me to his brother because, again, I wanted to
          23    somehow get a federal law enforcement involved in this,
          24    since my perception was that the criminal activity --
          25    conspiracy and criminal activity happened at least in New
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           1    York, New Hampshire and Clearwater.
           2              Mmm, he said that he would talk with a federal
           3    agent that he did know and get back with me.  He -- I guess
           4    maybe a day or so later, he had a conversation with the
           5    federal agent, Mr. Douglas DeVlaming.  And he told me, after
           6    speaking with an agent, they thought that it would make a
           7    difficult case because Mr. Minton was now on the stand
           8    lying, telling lies.  If he changed his mind --
           9              MR. WEINBERG:  Objection.  Hearsay, your Honor.
          10              THE COURT:  Sustained.
          11    BY MR. DANDAR:
          12         Q    Did you ever meet personally with law enforcement?
          13         A    Yes, I did.
          14         Q    All right.  Who did you meet with?
          15         A    I met with FDLE Agent Lee Strope.
          16         Q    Did you talk about Mr. Minton and Ms. Brooks?
          17         A    I pretty much gave Mr. Strope a complete rundown
          18    of the meetings, with the dates similar to how I laid it out
          19    there in the affidavit.  And after --
          20              THE COURT:  Mr. Strope is with what agency?
          21              THE WITNESS:  FDLE.
          22              THE COURT:  FDLE?
          23         A    And after speaking with him, he asked me to give
          24    Bob Minton a message.  And the message was that if it is
          25    determined that you have perjured yourself on the stand,
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           1    that he would see to it that charges would be brought.
           2    BY MR. DANDAR:
           3         Q    This is Mr. Strope telling you to talk to
           4    Mr. Minton?
           5         A    This is a message Mr. Strope asked me to give
           6    Mr. Minton specifically.
           7         Q    Did you give him that message?
           8         A    Mmm, I wrote -- I hand-wrote what he said.  I gave
           9    it to my fiancee and she read it to Mr. Minton over the
          10    phone.
          11         Q    Okay.
          12              THE COURT:  Mr. Prince, is it your testimony
          13         here today under oath an agent of the Florida
          14         Department of Law Enforcement asked you to deliver a
          15         message to someone?
          16              THE WITNESS:  Yes, your Honor.
          17    BY MR. DANDAR:
          18         Q    Any other meetings with law enforcement?
          19         A    Not about this specific incident.
          20         Q    Okay.  Now, what was your impression, after
          21    meeting with Ms. Brooks and Mr. Minton, on the meetings you
          22    have just mentioned, all of these meetings --
          23              MR. WEINBERG:  Objection to the form.  What was
          24         his impression?
          25              THE COURT:  Yes.  What does that mean?
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           1              MR. DANDAR:  I didn't finish my sentence.
           2              THE COURT:  Go ahead.
           3    BY MR. DANDAR:
           4         Q    What was your impression as to who was the person
           5    who was creating the scenario that I told Mr. Minton to lie?
           6         A    Mr. Rinder.
           7         Q    And what is the basis of that?  What is the basis
           8    of your impression it is Mr. Rinder?
           9         A    Because that is what they said.
          10         Q    Who said?
          11         A    Bob and Stacy.
          12         Q    All right.
          13              MR. WEINBERG:  Well, could we just -- I mean,
          14         is that -- your Honor, so his testimony is that at
          15         some point Bob Minton and Stacy Brooks said that
          16         Mike Rinder said for Mr. Minton to lie?
          17              THE COURT:  Yes.  That is his testimony.
          18              MR. WEINBERG:  Could we date that testimony,
          19         please?
          20              THE COURT:  Mr. Prince, is that your testimony?
          21              THE WITNESS:  Yes, it is.
          22              THE COURT:  If you could look at your affidavit
          23         and tell us which one of these conversations that
          24         that conversation took place.
          25              THE WITNESS:  Okay.  Let me see if I see it
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           1         here.  I don't seem to have my affidavit up here.
           2              THE COURT:  You don't?  I think I have it right
           3         here, if it will help.
           4              MR. DANDAR:  Well, I have the affidavit right
           5         here.  I'm sorry.  I was looking at it instead of
           6         listening to the Court.
           7              THE WITNESS:  This would have had to have
           8         happened sometime after the date that I mentioned on
           9         Page 5, Line 16, Paragraph Number 11 of the 3rd of
          10         April or 2nd of April, sometime after that time
          11         period.
          12    BY MR. DANDAR:
          13         Q    After this -- after the 2nd or 3rd of April?
          14         A    Correct.
          15         Q    All right.  Did Mr. Minton or Ms. Brooks tell you
          16    this on more than one occasion?
          17         A    Well, the subject of the meetings -- after they
          18    returned to Clearwater with Mr. Bunker April 2nd, the many
          19    times that I met with them, the subject of the conversations
          20    concerned what they were asked -- or what they were being
          21    asked to do, what they wanted me to do.
          22              So that was a continuing theme until, you know,
          23    the point that it finally broke off, because I didn't, I
          24    guess, qualify to meet with the Scientologists or speak with
          25    them about this myself.  But it was a continuing theme of
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           1    conversations.
           2              THE COURT:  I believe that, in fairness,
           3         Mr.~Prince may have testified to some of this
           4         yesterday, too.
           5              MR. DANDAR:  I think so maybe.
           6              THE COURT:  And may have dated some of this
           7         yesterday.  I'm looking through his affidavit.  I am
           8         remembering some of his testimony from yesterday.
           9              MR. DANDAR:  All right.
          10    BY MR. DANDAR:
          11         Q    Now, Mr.~Prince, yesterday you talked about Volume
          12    0 and 00.  Do you recall that?  You looked in the book
          13    Introduction To Ethics and you said --
          14         A    Yes.
          15         Q    -- what you were looking for may be in Volume 0
          16    and 00?
          17         A    Yes.
          18         Q    And there are a bunch of books over there.  Are
          19    there any of the books you want to refer the Court to?
          20         A    Sure, if I could just walk over there.
          21              MR. DANDAR:  Is that all right, Judge?
          22              THE COURT:  Yes.  By the way, Ms. Greenway
          23         asked if she could take my picture.  You can't take
          24         pictures when court is in session.  So I gave her
          25         permission to come in and take pictures when court
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           1         wasn't in session of whatever she wanted to take
           2         pictures for.  But when court is in session you
           3         cannot take pictures unless you are connected with
           4         the media and you are a pool photographer.  Then you
           5         can.
           6    BY MR. DANDAR:
           7         Q    No other books?
           8         A    No.
           9         Q    All right.
          10         A    This is -- first off, I would like to say
          11    yesterday that I said that this was a crime for a person to
          12    give testimony about Scientology.  I actually misspoke.  It
          13    is a suppressive act to do that, according to this document
          14    here, suppressive acts, suppression of Scientology,
          15    Scientologists, the fair game law.
          16              And what it states specifically is --
          17              THE COURT:  Tell us, first of all, what are you
          18         reading from.
          19              THE WITNESS:  Oh, sorry.
          20    BY MR. DANDAR:
          21         Q    The book?
          22         A    I'm reading from HCO Division 1 Policy Volume,
          23    Scientology Policy Volume.
          24              THE COURT:  Okay.  Those are Scientology
          25         policies in a book?
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           1              THE WITNESS:  Yes, your Honor.
           2              THE COURT:  Is there a page number?
           3              THE WITNESS:  Yes, your Honor.  It is 553, what
           4         I'm going to make reference to.
           5              MR. LIEBERMAN:  Could we have the date on that
           6         book?
           7    BY MR. DANDAR:
           8         Q    Copyright on the front?
           9              THE COURT:  Would it matter with these
          10         policies --
          11              MR. LIEBERMAN:  Well, some, it may.
          12              THE WITNESS:  This is copyright 1970 through --
          13         what is it, 1950, it looks like.  These are all of
          14         the copyright notices here.
          15              THE COURT:  Okay.  I'm going to let you-all
          16         take a look at it.
          17              MR. WEINBERG:  Now?  Or --
          18              THE COURT:  No.  Let him go ahead and have his
          19         testimony, and then before cross-examination you-all
          20         can look at the book.
          21    BY MR. DANDAR:
          22         Q    So a suppressive act is someone saying they want
          23    to leave Scientology?
          24         A    Yes.  And testifying as a hostile witness against
          25    Scientology in public is a suppressive act.
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           1         Q    All right.  That has to do with testifying?
           2         A    Correct.
           3         Q    What about leaving Scientology or saying you want
           4    to leave?
           5         A    Mmm, yesterday I showed the reference and we went
           6    through that.  It's a high crime to publicly depart
           7    Scientology.
           8         Q    This may be something I already marked.  Let me
           9    show you what has been marked as Plaintiff's Exhibit 133.
          10    CS Series 22.
          11              Can you identify that Exhibit 133?
          12         A    Yes.  This is an HCO bulletin of 28 November,
          13    1970, Mmm, subtitled "CS Series 22."  The "CS Series" means
          14    case supervisor series.  It's -- it's a series that is a
          15    staple or basic for persons that are supervising auditing in
          16    Scientology.  And this document refers to the subject of
          17    psychosis.
          18         Q    And this document came from the PTS/SP course book
          19    you read yesterday.  Is that correct?
          20         A    Correct.
          21         Q    Okay.  Now --
          22              THE COURT:  Who is permitted to take that
          23         course?  Maybe you asked it before, but, I mean, if
          24         I'm a new Scientologist, new public member, can I go
          25         register for that course?
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           1              THE WITNESS:  You certainly could.  Any
           2         Scientologist in good standing --
           3              THE COURT:  Could take that course?
           4              THE WITNESS:  Yes, your Honor.
           5              THE COURT:  Okay.
           6    BY MR. DANDAR:
           7         Q    This course book also contains the search and
           8    discovery bulletin?
           9         A    I believe it does.
          10         Q    Okay.  Now, this particular document, Exhibit 133,
          11    CS Series 22, does this have anything to do with people
          12    wanting to leave?
          13         A    Well, if you turn to the second page, it talks
          14    about the easiest ways for a case supervisor to detect the
          15    insane, and we go down here to Number 6, it says:  "They
          16    often seek transfers or wish to leave."
          17         Q    Now, does this apply to staff as well as public
          18    members?
          19         A    Absolutely.
          20              THE COURT:  I think this is already in
          21         evidence, isn't it?
          22              MR. DANDAR:  I'm not sure.  You told me to mark
          23         this yesterday as an exhibit.
          24              THE COURT:  Well, now that I'm looking at it,
          25         I'm thinking I read it before.  But if you are not
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           1         sure, you want to introduce it again, why, that is
           2         all right.
           3              MR. DANDAR:  I'm really not sure.
           4              THE COURT:  All right.
           5              MR. DANDAR:  I know we talked about this
           6         yesterday.
           7              THE COURT:  I'm not positive if this was the
           8         document, but I have read some of this before.
           9              MR. DANDAR:  Yes.  It is quite possible.
          10              MR. WEINBERG:  We have no problem, but the
          11         next-to-last sentence says:  "The insane can be
          12         helped, they are not hopeless."  We don't have a
          13         problem with this.  But the introspection rundown
          14         comes after this policy.
          15              THE COURT:  But you have no objection to this
          16         being introduced?
          17              MR. WEINBERG:  No.
          18              MR. DANDAR:  We move it into evidence.
          19              MR. WEINBERG:  It was referred to in the
          20         introspection rundown which was introduced three or
          21         four years later, this policy.
          22              THE COURT:  All right.
          23    BY MR. DANDAR:
          24         Q    Speaking of the introspection rundown, Mr.~Prince,
          25    speaking of your experience, expertise, is there any part of
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           1    the introspection rundown that is considered religious?
           2              MR. WEINBERG:  Objection to his competence to
           3         this because Mr.~Prince previously testified he
           4         wasn't trained on the introspection rundown and
           5         never -- as an auditor never did any introspection
           6         rundown.
           7              THE COURT:  I thought he did.
           8              THE WITNESS:  That is correct.  I did.  I never
           9         was -- I never stated that I was not trained on the
          10         introspection rundown.
          11              THE COURT:  I'm sorry, what?
          12              THE WITNESS:  I never stated I was not trained
          13         on the introspection rundown.  That is false.  I am
          14         very trained on the introspection rundown.
          15              MR. WEINBERG:  What he said was he participated
          16         in an isolation watch, not as the auditor, you know,
          17         but as one of the people staying with Teresita.
          18              THE COURT:  Is isolation watch and
          19         introspection rundown the same?
          20              MR. WEINBERG:  It is part, Step whatever it is,
          21         0, 00.
          22              THE COURT:  All right.
          23              MR. DANDAR:  This will kind of answer the
          24         question, I think.
          25
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           1    BY MR. DANDAR:
           2         Q    So, Mr.~Prince, is there parts or all of the
           3    introspection rundown that is religious?  A religious
           4    practice?
           5         A    Mmm, in the very first bulletin about the
           6    introspection rundown, L. Ron Hubbard describes it as a new
           7    technical breakthrough that marveled something else of the
           8    20th century, I forget specifically what it says there.  But
           9    it was hailed as a researched scientific discovery for
          10    handling insanity.
          11              MR. WEINBERG:  So, your Honor, is what
          12         Mr. Dandar is doing is challenging whether or not
          13         the introspection rundown is part of the religion of
          14         Scientology?  Because if he is, I think that has
          15         already been decided in this case and it is not
          16         appropriate and we should not be wasting our time on
          17         it.
          18              THE COURT:  Haven't we decided that -- or -- I
          19         don't know because I don't know -- I saw a motion
          20         once that dealt with religiocity.  I didn't hear any
          21         of that.
          22              MR. DANDAR:  That was not the --
          23              MR. LIEBERMAN:  But you have stated several
          24         times, your Honor, that there is no question in this
          25         case as to the religious nature of Scientology or
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           1         religious nature of the introspection rundown.
           2              THE COURT:  Okay.  I know I have stated that I
           3         have no question on the -- that the Church of
           4         Scientology is a religion and it is a recognized
           5         religion in the Church.  And I have no question in
           6         my mind that Lisa McPherson was undergoing some sort
           7         of introspection rundown.  I didn't know whether I
           8         said that introspection rundown is part of the
           9         religion of the Church.  I don't even know if that
          10         is a call for me to make, to tell you the truth.  I
          11         would suspect the Church doctrine would tell us
          12         whether it is or isn't.
          13              MR. LIEBERMAN:  That is correct.  And the
          14         Church characterizes what is religious practice.
          15              THE COURT:  I don't know if I have seen that or
          16         not.  I know we have a Mr. Rice affidavit.  I
          17         haven't looked at it in some time.
          18              MR. LIEBERMAN:  And he quite clearly places it
          19         within the Scientology practice.  In fact, every
          20         part of Scientology, by definition, is part of
          21         Scientology belief and practice and is not a matter
          22         for the Court to challenge what is characterized by
          23         the Church as this religion.
          24              THE COURT:  I am going to let him answer this.
          25         I think he already has answered it, but I don't know
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           1         we're going to go there.  And certainly one answer
           2         isn't going to get it there.
           3              MR. DANDAR:  Right.
           4    BY MR. DANDAR:
           5         Q    Mr.~Prince, Mr. Hubbard called it scientific
           6    breakthrough?
           7         A    That is correct.
           8         Q    Did he ever call it religious practice?
           9         A    Never.
          10         Q    Did he call auditing a religious practice?
          11         A    No.
          12         Q    Oh.
          13         A    Not to my knowledge.  I mean, this whole business
          14    of religion -- I don't know, you know, it is kind of -- has
          15    kind of reared its head in Scientology every now and again.
          16              When I was here at the Flag Service Organization
          17    in 1979, there was a scare -- a cold war scare of some
          18    nuclear threat and conscription in the Army and on and on.
          19    This is what we were told.  So all of the staff had to do a
          20    two-week course called the minister's course where you are
          21    instantly trained to be a minister.  This was part of -- a
          22    program which, in part, was to kind of improve or create a
          23    religious image for Scientology.
          24              But if you will notice, in every document that
          25    Mr. Hubbard writes about Scientology, whether or not it is a
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           1    green --
           2              THE COURT:  I don't want to hear this.  The
           3         United States Government, State of Florida, on and
           4         on down, determined Scientology is a religion, the
           5         Church of Scientology is a church.  I don't care
           6         what they used to think, what they used to say.  It
           7         doesn't matter.  That is it.
           8              MR. DANDAR:  What I'm -- I was getting at is
           9         just the introspection rundown itself.
          10              THE COURT:  Okay.
          11    BY MR. DANDAR:
          12         Q    The part of the introspection rundown talking
          13    about get some rest --
          14              MR. WEINBERG:  Your Honor, could I --
          15    BY MR. DANDAR:
          16         Q    -- make sure you eat --
          17              MR. WEINBERG:  This is precisely why Mr.~Prince
          18         should not be an expert, considered an expert in
          19         Scientology, because as he sits here today, he still
          20         is sitting there saying it is not even a religion or
          21         a church.  He doesn't recognize it --
          22              THE COURT:  He wasn't.  He was talking about
          23         some things that were said back in the 1970s when
          24         they were all sitting around talking --
          25              MR. WEINBERG:  He just said that -- well, I
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           1         don't want to argue with you.  I mean, it -- that is
           2         where he was going with this and that is what
           3         this -- that is what this is about.
           4              MR. DANDAR:  It is not what this is about.  I
           5         just asked him what I'm asking him now, the
           6         introspection rundown, the part that talks about
           7         resting and eating -- resting and eating, something
           8         else --
           9              THE COURT:  0, 00.
          10              MR. DANDAR:  Yes, those two steps.
          11    BY MR. DANDAR:
          12         Q    In your experience within the Church of
          13    Scientology, was that ever considered a spiritual or
          14    religious part of Scientology?
          15              MR. LIEBERMAN:  Your Honor, again, this is
          16         unconstitutional inquiry.  You can't bifurcate a
          17         religious practice and say part is and part isn't.
          18         To just even hear this testimony is an
          19         unconstitutional attack on the religion.
          20              THE COURT:  Mr. Lieberman, your objection on
          21         that is preserved.
          22              MR. LIEBERMAN:  Thank you.
          23         A    Well, you know, since -- you know, people that are
          24    atheists or other ideas also rest and sleep.  You know, it
          25    never came to me that this was a religious experience to
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           1    rest and eat.
           2    BY MR. DANDAR:
           3         Q    Well, and in your knowledge of Scientology, if
           4    someone is injected with Valium or chloral hydrate, are they
           5    eligible to have auditing?
           6         A    According to -- Mmm -- the HCO bulletin entitled
           7    Model Session --
           8         Q    How do you spell that?
           9         A    Model, M-O-D-E-L, model session, a person who has
          10    had drugs or who has used drugs continuously is not eligible
          11    for auditing until six weeks after the period of taking the
          12    drugs.
          13         Q    Now, in your experience with Teresita, you said
          14    Dr. Dink, Hubbard's doctor, came out and injected her with
          15    some kind of drug?
          16         A    Correct.
          17         Q    And she went to sleep?
          18         A    Correct.
          19         Q    How soon after that did she have auditing?
          20         A    Within hours after awaking.
          21         Q    Was that within the written policy?
          22         A    Is that what now?  I'm sorry.
          23         Q    Is that per policy to have an auditing right after
          24    you have slept off the effects of the drug?
          25         A    Well, in the introspection rundown bulletin, it
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           1    states that each program is tailored specifically for the
           2    individual.  So to that degree, if the person had to sleep
           3    first in order to get auditing, they would get the auditing,
           4    but then there is also later references in Scientology
           5    technology which state that in a period after the auditing
           6    that was delivered, while the person was on drugs, you could
           7    then go back and check those areas again to make sure that
           8    everything is fine.
           9         Q    Okay.  Let me show you Exhibit 134.  And do you
          10    recognize where this copy of this Page 258 comes from?
          11         A    Yes.  This comes from the Hubbard Administrative
          12    Dictionary.
          13         Q    And what -- how does it define the phrase "high
          14    crimes"?
          15         A    It says:  "High crimes.  1.  These consist of
          16    publicly departing Scientology or committing suppressive
          17    acts.  Cancellation of certificates, classifications and
          18    awards and becoming fair game are amongst the penalties
          19    which can be leveled for this type of offense as well as
          20    those recommended by Committees of Evidence."
          21              MR. DANDAR:  Okay.  That is all of the
          22         questions I have.
          23              THE COURT:  All right.  Thank you.  You may
          24         inquire.
          25              MR. WEINBERG:  Thank you.
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           1                        CROSS-EXAMINATION
           2    BY MR. WEINBERG:
           3         Q    Mr.~Prince, David Miscavige busted you from your
           4    position of authority -- your executive position of
           5    authority in the RTC -- in March of 1987, didn't he?
           6         A    Correct.
           7              THE COURT:  I'm sorry, you just got started.
           8         Did you want to introduce this 134?
           9              MR. DANDAR:  Yes, sir.  In fact --
          10              MR. WEINBERG:  We object to that.  I would like
          11         to see the dictionary, see what the date of the
          12         dictionary was.
          13              MR. DANDAR:  Do you have it here?  In fact, I
          14         just realized, unless you want to do this later,
          15         there are a bunch of things I marked and didn't move
          16         them into evidence.
          17              THE COURT:  I'll go ahead and let you do
          18         that --
          19              MR. DANDAR:  Later?
          20              THE COURT:  -- later.  But don't forget.
          21              MR. DANDAR:  Right.  Yes.
          22              MR. WEINBERG:  Should I start over?
          23              THE COURT:  Yes.
          24    BY MR. WEINBERG:
          25         Q    Mr.~Prince, David Miscavige busted you from your
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           1    position -- your executive position of authority in the RTC
           2    in March of 1987, didn't he?
           3         A    Correct.
           4         Q    And at that time you were removed from your post,
           5    the last executive post you ever held in the Church of
           6    Scientology.  Correct?
           7         A    Correct.
           8         Q    And that post, you said, was deputy inspector
           9    general external.  Right?
          10         A    Right.
          11         Q    Now, you were removed because you had supported
          12    Pat Broeker and Annie Broeker and Vicki Aznaran in their
          13    effort to change Scientology tech.  Correct?
          14         A    That is categorically false.
          15         Q    That was precisely what occurred, that Pat
          16    Broeker, who had designated himself the loyal officer, was
          17    in the process of changing, among other things, the
          18    Scientology grade chart, right?  That is what he was doing?
          19         A    That is categorically false.
          20         Q    So Mr. Broeker wasn't doing that?
          21         A    Correct.
          22         Q    And you never acknowledged that Mr. Broeker did
          23    that?
          24         A    Correct.
          25         Q    So Mr. Broeker wasn't off on his own, trying to
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           1    change the religion of Scientology, after Mr. Hubbard died?
           2         A    Well --
           3         Q    Yes?  Or no?
           4         A    Excuse me.  Let me answer the question.
           5              THE COURT:  Well, I'll tell you how this works
           6         on cross-examination.  Go ahead and answer the
           7         question, but if you feel you have to explain your
           8         answer, you are allowed to do that after you have
           9         answered it.
          10              THE WITNESS:  Okay.  I'm sorry.
          11         A    Ask me the question again.
          12    BY MR. DANDAR:
          13         Q    Wasn't Mr. Broeker caught in -- in an attempt to
          14    change Scientology tech?
          15         A    I have no percipient knowledge of that.
          16         Q    You have no percipient knowledge of that?
          17         A    In other words, I was not there -- let me -- I was
          18    not there.  I didn't see him changing anything.
          19              And, again, I was going to say, I have heard some
          20    hearsay about it.  Since you vehemently object about it, I
          21    won't comment about it, but I -- you know, I haven't
          22    personally been with Mr. Broeker when he's altering
          23    Scientology technology.
          24         Q    When you were in the RTC prior to March of 1987,
          25    in that year after Mr. Hubbard died, you became aware of the
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           1    fact that some point in time that Mr. Broeker was changing
           2    and altering Scientology tech, weren't you?
           3         A    Incorrect.
           4         Q    You became aware of the fact that Vicki Aznaran
           5    was part of an effort to change Scientology tech, weren't
           6    you?
           7         A    Absolutely incorrect.
           8         Q    And what happened in March of 1987 is that
           9    Mr.~Broeker was removed from all authority.  Correct?
          10         A    Mr.~Broeker was removed from authority.
          11              THE COURT:  Wasn't?  Or was?
          12              THE WITNESS:  He was, your Honor.
          13    BY MR. WEINBERG:
          14         Q    Annie Broeker, his wife, was removed from all
          15    positions of authority.  Correct?
          16         A    To my knowledge, that is correct.
          17         Q    Your boss, Vicki Aznaran, was removed from her
          18    position of authority.  Correct?
          19         A    Correct.
          20         Q    And you were removed?
          21         A    Correct.
          22         Q    And you were at that time -- at that point in
          23    time, you went from what you described as an executive
          24    position with some authority in the -- in RTC.  Right?
          25         A    Correct.
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           1         Q    To no authority whatsoever?
           2         A    No.  That is incorrect.
           3         Q    From -- for the next five years after March of
           4    1987, did you ever hold a position where someone was junior
           5    to you?  You know what I mean by that?
           6         A    Yes, I do.  And, yes, I have.
           7         Q    I mean, you were, what, a machine operator after
           8    that?
           9         A    Mmm, no.  I worked on post-production,
          10    preproduction and post-production for films.
          11         Q    That was one of the things you did, and you were a
          12    Cinemix, was that your job?
          13         A    No.
          14         Q    What was your job?
          15         A    My job was like an assistant engineer, assistant
          16    sound mixer.  Again, I state I worked for post-production
          17    and preproduction for films and videos.
          18         Q    During that period of time you were in the RPF a
          19    couple of times.  Correct?
          20         A    Incorrect.
          21         Q    How many times were you in the RPF?
          22         A    I was in the RPF two times, but not that period of
          23    time.
          24         Q    You were in the RPF in March of 1987.  Correct?
          25         A    Correct.
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           1         Q    All right.  Until what, the end of 1987?
           2         A    Mmm, I think it was -- I wasn't in there a very
           3    long time.  I think maybe four months.
           4         Q    By the way, there is no higher crime in
           5    Scientology than changing the tech.  Correct?
           6         A    That is incorrect.
           7         Q    Well, what would be a higher crime than changing
           8    Mr. Hubbard's scriptures?
           9         A    Placing Scientology and Scientologists at risk.
          10         Q    One of the highest crimes in Scientology is to
          11    alter the tech.  Correct?
          12         A    It is a high crime to do that.  Yes.
          13         Q    Now, for the next -- for those five years after
          14    you were busted -- and that was the day you claimed, by the
          15    way, that you pulled these guns on David Miscavige and
          16    threatened to kill him?
          17         A    You didn't mention a specific day.  What day are
          18    you talking about?
          19         Q    Well, what day are you talking about when you were
          20    busted?
          21              THE COURT:  Without worrying too much about the
          22         date, the date you testified about when you were
          23         rousted from bed or got out of bed and went and got
          24         the guns, that is on the same day, right?
          25              THE WITNESS:  Yes.  I'm sorry.
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           1              THE COURT:  That is the day you were busted?
           2              THE WITNESS:  Yes.
           3              THE COURT:  That is what he was referring to.
           4              THE WITNESS:  Okay.  I'm sorry.  I just didn't
           5         understand the question.
           6    BY MR. WEINBERG:
           7         Q    That is the same day you claim you pulled these
           8    guns on David Miscavige and you threatened to kill him.
           9    Correct?
          10         A    I didn't threaten to kill Mr. Miscavige.  What --
          11    maybe you have a wrong idea about what happened there.  I
          12    came there to defend myself.  Twelve people were attacking
          13    me, were trying to hold me.  Because I do know karate and
          14    have a black belt in it, I was able to get them away from me
          15    until I went and got protection for myself.
          16         Q    So then these twelve people that were attacking
          17    you let you go back to your room, get these two loaded guns?
          18         A    They didn't know where I was going.
          19         Q    That didn't really happen, did it, Mr.~Prince?
          20         A    Yes, it did.
          21         Q    You didn't pull guns on David Miscavige.
          22         A    Yes, it did.
          23         Q    So this is the person you say you could still be
          24    friendly with?
          25         A    You know, Mmm -- yes.  And I need to explain
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           1    something here because, you know, Mr. Weinberg, you and I
           2    have been around and around on this in front of Judge Moody.
           3    So, you know, you are giving me the exact same questions and
           4    I'll sit here and be patient with you, but I think the
           5    record reflects we have done this one or two times before.
           6              THE COURT:  See, I haven't heard it.  This is
           7         my hearing, so we'll do it again.
           8              MR. DANDAR:  Explain yourself.
           9              THE WITNESS:  Okay.
          10    BY MR. WEINBERG:
          11         Q    So you contend that you really did go back to your
          12    room, get two loaded weapons, and walk back and enter a room
          13    and point them directly at David Miscavige?
          14         A    No, I never walked back into a room.  By that
          15    time --
          16         Q    You ran back into the room?
          17         A    Would you like me to explain it?  I --
          18         Q    Explain it.
          19              MR. DANDAR:  Wait.  Wait.  Objection.
          20    BY MR. WEINBERG:
          21         Q    Did you --
          22              MR. DANDAR:  He needs to explain it.
          23         Mr. Weinberg --
          24              MR. WEINBERG:  I'll withdraw that question.
          25
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           1    BY MR. WEINBERG:
           2         Q    Did you point two loaded guns --
           3              MR. DANDAR:  That is not fair.
           4    BY MR. WEINBERG:
           5         Q    -- at David Miscavige?
           6         A    No, I did not.
           7         Q    Who did you point them at?
           8         A    I had the one gun on my hip and the .45 in my
           9    hand.  And they stood this way.  The assault rifle never was
          10    pointed at anyone.  It was just on my hip like this.  And I
          11    had the .45.
          12              And Mr. Miscavige, when he saw me, walked directly
          13    up to me with those guns in my hand and said, "Jesse, we are
          14    friends.  Let's talk."
          15              So I don't think he felt that threatened.  And I
          16    think that Judge Moody pointed that out to you the last time
          17    we were doing this.
          18         Q    I mean, no one would feel threatened when they had
          19    just busted somebody from position and the person got so mad
          20    to go back to the room and get two loaded guns and walk into
          21    a room.  You can't imagine anybody would be threatened by
          22    that, would they?
          23         A    I think that is a mischaracterization of what
          24    happened.
          25         Q    Well, my question is was there a particular reason
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           1    why you never told that story until -- until you started
           2    getting paid to be a witness in the FACTNet case in 19 --
           3    whatever it is, 1998?  Why you waited all those years to
           4    tell that story?
           5         A    Mmm, I don't know how to answer that question,
           6    Mr. Weinberg.  You are associating things that don't
           7    associate.  You are associating with me being paid telling
           8    stories.  And there is no association there.
           9         Q    Well, is there a particular reason, in the years
          10    after this alleged incident took place, that took you until
          11    1998 to first tell this story about pulling guns on David
          12    Miscavige?
          13              MR. DANDAR:  Object to the form.  It makes no
          14         sense.  Telling stories where?  Under oath?  In a
          15         deposition?  To his friends?
          16              THE COURT:  I don't, either, because I don't
          17         know whether you are talking about the first time he
          18         ever testified about that, and if that is the first
          19         case he was ever involved in, that is the first time
          20         he ever testified about that.
          21              MR. WEINBERG:  I --
          22              THE COURT:  I'll tell you one thing --
          23              MR. WEINBERG:  I'm sorry, I didn't mean to --
          24              THE COURT:  -- don't get ahead of me because
          25         you want to go at this witness.
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           1              MR. WEINBERG:  You are right.
           2              THE COURT:  I won't have it.
           3              MR. WEINBERG:  Right.
           4              THE COURT:  I won't have you really cutting
           5         this man off.  I mean, I know you want to get where
           6         you want to go.  But you'll have to go slow.
           7              And, Mr. Prince, whatever you told Judge Moody,
           8         I haven't heard it, I haven't seen too much of the
           9         transcript before Judge Moody, so I don't want to
          10         hear what I -- I already told Judge Moody this, I am
          11         not Judge Moody.
          12              THE WITNESS:  I understand.
          13              THE COURT:  If he asks you a question, unless I
          14         tell him, "You can't ask that question," just
          15         answer, even if you have already answered it before.
          16         Okay?
          17              THE WITNESS:  Okay.  Yes, your Honor.
          18              THE COURT:  Let's go.
          19    BY MR. WEINBERG:
          20         Q    You were interviewed by Earle Cooley while still
          21    in the Church in 1988, weren't you, in relation to another
          22    lawsuit?
          23         A    I would have to see something about that.  I'm not
          24    sure what you are talking about.
          25         Q    You didn't say anything about the guns to him, did
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           1    you?
           2         A    Again, I would have to see what you're talking
           3    about.
           4         Q    Well, you mention the 1994 interview with
           5    Mr.~Cooley.  You didn't say anything about the guns to him
           6    in that interview, did you?
           7         A    I mean, you know, you are mixing apples and
           8    oranges.  I mean, I don't understand what you are asking me.
           9    I mean, I have told that story long before 1998 to my
          10    friends, my family, people that I know.  I mean, you know,
          11    it isn't like here is some money, let's tell this story.  I
          12    beg to differ with the way you are characterizing what
          13    happened here.
          14         Q    The reason you told the story to Mr. Minton in
          15    April of this year was to threaten him as to what you would
          16    do as to what kind of person you were?  I mean, what did you
          17    tell him about it for?
          18         A    I told him that story, as I gave testimony
          19    yesterday, to show that Scientology, more than likely, will
          20    never keep or honor an agreement with anyone.  It wasn't to
          21    say I'm going to run and shoot you with guns.  It was to
          22    give him an example to show him that Scientology will never
          23    honor an agreement.
          24         Q    Now, you would agree that the positions that you
          25    held after you were busted were extremely low positions in
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           1    the Church of Scientology?
           2         A    I would beg to differ on that, as well.
           3         Q    Now, you were -- you were so humiliated,
           4    apparently, by Mr. -- what you claim Mr. Miscavige did in
           5    March of 1987 that you pulled these guns on him.  That is
           6    what it was about, wasn't it?
           7         A    Absolutely not.  And even as we have been sitting
           8    here, I think I made it clear to you why I went and got
           9    those guns.  It wasn't humiliation.  It was being attacked.
          10         Q    You were --
          11         A    Physically attacked.
          12         Q    You resented the fact that you had been busted?
          13         A    I resented the fact I was being physically
          14    attacked by people that used to be my friends.
          15         Q    No.  My question is did you resent the fact that
          16    you had been busted from your executive position in RTC?
          17         A    And I'll answer the question it isn't so much that
          18    I resented the fact that --
          19              THE COURT:  Come on, Mr.~Prince, of course you
          20         must have been annoyed.  I don't know why we're
          21         playing a semantics game.  Anybody would be annoyed
          22         if they were busted from the position they
          23         thought --
          24              THE WITNESS:  No, your Honor, that isn't right.
          25         I think that deserves clarification because I was
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           1         pretty much tired of that activity that I had been
           2         involved in, in Scientology.  I was ready for a
           3         change.  I was ready to be done with that position
           4         because that -- that position responsibility
           5         entailed being involved in criminal activity.
           6              This is something that I had not experienced in
           7         Scientology prior to going to Gilman, Hot Springs
           8         and working at that level.  To me, Scientology was
           9         something different than what I was doing.
          10              So, no, it wasn't a big deal for me, you know.
          11         I was already wanting to be away from that
          12         responsibility.
          13              But what was a big problem for me was twelve
          14         people grabbing me, because I had an earlier
          15         incident of that happening in Scientology where six
          16         people grabbed me and locked me in a room for three
          17         months, and I ended up staying 16 years.  So that
          18         had precedent over that position I was being removed
          19         from.
          20    BY MR. WEINBERG:
          21         Q    So you were relieved by the fact you were busted
          22    from your position?
          23         A    Yes.  I was somewhat relieved by it.
          24         Q    Now, you -- you, Jesse Prince, dislike vehemently
          25    David Miscavige, don't you?
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           1         A    I would not say that that is true.  I have no
           2    vehement dislike for him.  I dislike the things that he
           3    does.  But I don't envy his position.  He's the leader of a
           4    religion.  He has a lot of responsibility.  That doesn't
           5    give you license to be a criminal, though.
           6         Q    You spent the last four years, ever since you met
           7    apparently sometime in the summer of 1998, started getting
           8    paid by, ever since you met Mr. Minton, you spent the last
           9    four years trying to destroy David Miscavige, haven't you?
          10         A    That is incorrect.
          11         Q    You have picketed where you have spoken vilely and
          12    obscenely about Mr. Miscavige, haven't you?
          13         A    Yes, I have.
          14         Q    You have picketed various Churches of Scientology
          15    around the country and even in the world, correct?
          16         A    That is incorrect.  I never picketed an
          17    organization outside of the United States.
          18         Q    Just in this country?
          19         A    Correct.
          20         Q    You have threatened David Miscavige in these
          21    pickets, haven't you?
          22         A    I need you to clarify what you mean by threatened
          23    for me, please.
          24         Q    Threatened to do harm to him.
          25         A    I have jokingly alluded to it, yes, I have.
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           1         Q    You thought it was funny?
           2         A    Yes, I did.
           3         Q    And did you think it was funny when you were
           4    outside the various Churches of Scientology, including what
           5    you call the mecca of Scientology, holding signs and
           6    shouting obscenities about the leader?  You thought that was
           7    funny, too?
           8         A    I -- I think you would have to show me or present
           9    evidence that I was holding a sign, shouting obscenities.
          10         Q    Oh, we will, Mr.~Prince.
          11         A    Okay.  I would like to see that.
          12         Q    Did you think that was funny?
          13         A    I would like to see the evidence, please, sir.
          14         Q    Would you consider, sir -- I mean, I think you
          15    said that Mr. Minton was the -- something basically the most
          16    harassed person you'd ever seen, something to that order?
          17         A    Something along that order, correct.
          18         Q    Would you consider what you and Mr. Minton and
          19    Ms.~Greenway and Mr. Alexander and Mr. Oliver and the other
          20    folks at the LMT -- would you consider what you were doing
          21    harassing Scientology?
          22         A    Well, what were we doing that was supposed to be
          23    harassing?
          24         Q    I mean --
          25              THE COURT:  His question to you is whatever it
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           1         was you were doing, would that be, in your mind,
           2         harassing Scientology?
           3              THE WITNESS:  Well, I guess to clarify it, if
           4         it meant picketing, does that mean harassing
           5         Scientology?  It has a broader meaning to me.  It
           6         means I'm exercising my First Amendment rights as a
           7         citizen to protest.
           8              Mmm, if you want to call that harassing
           9         Scientology, I call it exercising my freedom.
          10    BY MR. WEINBERG:
          11         Q    I'm asking you, because remember you talked about
          12    the harassment time line of Mr. Minton?
          13         A    Yes.
          14         Q    Do you remember talking about that?
          15         A    Yes.
          16         Q    And my question to you, if -- if we put all of
          17    your pickets and all Mr. Minton's pickets and all your
          18    postings and all Mr. Minton's postings and all of the
          19    postings of these folks that have been in and out of the LMT
          20    and all the pickets of them on a time line, do you think
          21    that time line might be somewhat larger than this Minton
          22    harassment time line?
          23         A    I think it would be minuscule and it would pale by
          24    comparison.
          25         Q    By the way, are you part of an anti-Scientology
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           1    movement?
           2         A    I have never been part of an anti-Scientology
           3    movement.
           4         Q    Are you an anti-Scientologist?
           5         A    No, I am not.
           6         Q    What do you consider yourself?
           7         A    I consider myself in the instant case where I'm
           8    sitting right here today an expert witness concerning
           9    Scientology.
          10              Prior to that, I worked in an establishment
          11    whereby I helped people who had been victimized by
          12    Scientology.
          13         Q    And would you consider Mr. Minton to be an
          14    anti-Scientologist during those four years that you were
          15    part of the A team, I think you said?
          16         A    I consider Mr. Minton to be an activist.
          17         Q    An activist?
          18         A    Yes.
          19         Q    What is that?
          20         A    You tell me what it is.  Do you need to know what
          21    the word means?  I mean, he was an --
          22         Q    What do you mean --
          23         A    -- activist concerning --
          24         Q    What do you mean when you say he was an activist?
          25         A    He was an activist ensuring the rights, basic
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           1    human rights, that are accorded to us through our
           2    constitution.
           3              I think Mr. Minton got started on his relationship
           4    with Scientology when he found out a Scientologist was
           5    trying to remove the name "Scientology" from a newsgroup --
           6    or at least this is the way he explained it to me.  And how
           7    lawyers and raids and things would come to even discuss
           8    Scientology, which is how I knew it from being in
           9    Scientology.
          10              I knew if you ever spoke about Scientology outside
          11    of Scientology, you would get clobbered.  So to actually see
          12    people doing it openly on the Internet was --
          13              THE COURT:  That is well past the answer.  You
          14         don't have to -- we have to try to get through this.
          15              THE WITNESS:  Okay.
          16              THE COURT:  He simply asked you to define what
          17         an activist was.  And I think you have done that.
          18              THE WITNESS:  All right.
          19    BY MR. WEINBERG:
          20         Q    Now, when did you begin -- when did you begin your
          21    work against Scientology?  What date or time?
          22         A    Mmm, I began to give testimony concerning
          23    Scientology, to the best of my recollection, in the FACTNet
          24    case.
          25         Q    Specifically, up until I -- I think you said you
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           1    considered yourself a Scientologist until, I think you said,
           2    1997.  Correct?  Isn't that what you said in your testimony?
           3         A    I think maybe '96, I said.
           4         Q    All right.  So you considered yourself a
           5    Scientologist after you left the Church of Scientology in
           6    1992, after you say that you were -- you said all those
           7    horrible things happened to you in the five-year period, you
           8    still considered yourself a Scientologist in '93, '94, '95
           9    and '96.  Correct?
          10         A    I think I should clarify that for you, if that is
          11    okay.  I think that I still had Scientology values.  I think
          12    that I still respected some of the tenets of Scientology,
          13    and I freely associated with Scientologists.
          14         Q    Well, you were working for a public member of
          15    Scientology for several years, right?
          16         A    Several years is incorrect.
          17         Q    How many years?
          18         A    Maybe one.
          19         Q    This is the job that the Church had helped you get
          20    after you left the Church where you were making $60,000 or
          21    $70,000 a year.  Was that your testimony?
          22         A    I think you are mischaracterizing what happened.
          23    No, that is not my testimony.  The Church didn't help me do
          24    anything.  It never has.
          25         Q    Well, just tell us one of those Scientology values
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           1    that you -- that you continue to accept and feel close to
           2    after you left the Church of Scientology.
           3         A    That man -- man is a spiritual entity.  That --
           4    Mmm -- man is capable of seemingly -- seemingly more capable
           5    than is realized and those potentials can be cultivated and
           6    used and expanded on.
           7         Q    Any other ones?
           8         A    You know, some of the organical principles about
           9    the importance of organization, the importance of schedules.
          10    You know, these kind of things.
          11         Q    When you were a Scientologist, you believed, did
          12    you not, that psychiatric problems were spiritual in nature.
          13    Correct?  That is what you believed?  And could be dealt
          14    with spiritually through the religion of Scientology.  You
          15    believed that when you were a Scientologist, didn't you?
          16         A    Yes, I did.
          17         Q    And that is what Scientologists believe, don't
          18    they?
          19         A    I can't speak for all Scientologists.  I know
          20    that, you know, as you are trained in Scientology, you
          21    accept more and more of what you read, and it's a
          22    progression, it is a degradation of belief system, I guess.
          23    But I couldn't say that everyone believes that.
          24         Q    Well, you could say that Scientologists -- no
          25    Scientologist would want to be committed to a mental
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           1    institution.  You can say that, can't you, from your years
           2    as a Scientologist?
           3         A    Mr. Weinberg, I can say that about Scientologists
           4    and anyone else.  There is no one that I know that is aching
           5    to be committed to an institution.
           6         Q    But I'm asking you from when you were a
           7    Scientologist --
           8         A    Uh-huh?
           9         Q    -- the last thing that you would have -- you would
          10    have rather shot yourself than be committed to a mental
          11    institution?
          12         A    Absolutely not.  I mean, that is unreasonable.  It
          13    is irrational.
          14         Q    Well, can you think of anything worse, as a
          15    Scientologist, than to be committed to a mental institution?
          16    Can you just answer that question?
          17         A    Rehabilitation Project Force, maybe.
          18         Q    One of the fundamental principles of the Church
          19    is -- is the Church's abhorrence with psychiatry and mental
          20    health treatment.  Correct?
          21         A    Well, you know, Mr. Weinberg --
          22         Q    Can you just answer that question?
          23         A    I used to believe that is the answer.  I used to
          24    believe that.  But I found, from Mr. Hubbard's autopsy
          25    report that I had a copy of, that he himself was taking
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           1    psychiatric medication --
           2              MR. WEINBERG:  Objection.  Move to strike.
           3         A    -- in his life.  So maybe --
           4              THE COURT:  Stop.  There is an objection.  You
           5         have to stop.
           6              MR. WEINBERG:  It is not responsive to the
           7         question.  It was a very simple question.  Yes or
           8         no.
           9              MR. DANDAR:  I would say this is outside of the
          10         scope of direct and the issues.
          11              THE COURT:  It is not outside the scope of
          12         direct and not outside the scope of the issues but,
          13         quite frankly, this is not helping me any.
          14              MR. WEINBERG:  All right.
          15              THE COURT:  It is an interesting banter between
          16         you and Mr.~Prince and --
          17              MR. WEINBERG:  I'll go on.
          18              THE COURT:  -- this might be of interest to a
          19         jury, but it really isn't of interest --
          20              MR. WEINBERG:  All right.
          21              THE COURT:  -- to me.
          22    BY MR. WEINBERG:
          23         Q    Since you have met Bob Minton, all of the money
          24    that you have received since June, other than this
          25    apparently $4,000 that you just got from Mr. Dandar, that
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           1    you have received since June, July, of 1998, up until April
           2    of 2002, came directly or indirectly from Mr. Minton, didn't
           3    it?
           4         A    That is incorrect.
           5         Q    And all of the money -- all of the money that you
           6    have received in that period of time you received as a
           7    result of your work about or against or involving
           8    Scientology?
           9         A    That is incorrect.
          10         Q    Correct?
          11         A    That is incorrect.
          12         Q    What is incorrect about that statement?
          13         A    I think that -- Mmm -- that all of the money that
          14    I have had during those periods of time derived from those
          15    activities, that is -- specifically is incorrect about it.
          16         Q    What, 99 percent of it?  95 percent of it?
          17         A    You know, I have turned over my financial records
          18    to you.  I think they speak for themselves.
          19         Q    All right.  Let me play you -- because you asked
          20    me to -- let me play you a video -- some videos and maybe
          21    this will refresh your recollection.  I'll ask you some
          22    questions about it.
          23         A    All right.
          24              MR. WEINBERG:  Get the first one.
          25              MR. DANDAR:  We're going to object.  If he
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           1         plays the video that they would like to play from
           2         the Boston picket, I demand that they play the whole
           3         video so that you, Judge, can see what Mr.~Prince
           4         was responding to in that very vile video that you
           5         may have already seen.  You only saw their version
           6         of it.  There is like two, three, four minutes of
           7         extremely vile language coming from ministers of the
           8         Church of Scientology to bull bait Mr.~Prince into
           9         responding the way he did on video.  So if they are
          10         going to do that, they need to play the whole thing.
          11              MR. WEINBERG:  That is not the one I'm playing,
          12         first of all --
          13              THE COURT:  All right.
          14              MR. WEINBERG:  -- to make it easy.
          15              Secondly, if he wants to do something later, he
          16         can.
          17              THE COURT:  There is a rule of completeness
          18         which we'll get into when we get to trial.  At a
          19         trial, if somebody will try to pick and choose, I'm
          20         probably going to insist on the rule of completeness
          21         in an appropriate case.
          22              But in this hearing, if they play something and
          23         you think I need to see it all, make a little note,
          24         tell them to keep it there and play the whole thing
          25         on redirect.
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           1              MR. DANDAR:  All right.
           2              THE COURT:  Or ask them if they'll play it all.
           3         If they say no, then you play it.
           4              MR. DANDAR:  All right.
           5              MR. WEINBERG:  Now, this is a video in front of
           6         the Ft. Harrison on November 30, 1998.
           7              ______________________________________
           8              (WHEREUPON, the video was played.)
           9              "You want to see the other side of the sign,
          10         too?  Just want to make sure you get all of the
          11         information, all of the data.
          12              "Tell David I'm coming with a dick so big, I'm
          13         gonna knock his goddamn spine out cuz I'm black.  I
          14         got a big dick.  I'm black.  I got a big dick.
          15              "Hey.  Hey.  Didn't that guy have curly hair?
          16         (Inaudible.)
          17              "No.  No.  Jesse.  Yo momma.  I been fucking
          18         your momma a long time (inaudible).  That's why you
          19         got that curly hair."
          20              (End of playing of the video tape.)
          21              ______________________________________
          22    BY MR. WEINBERG:
          23         Q    Do you recognize yourself, Mr.~Prince?
          24         A    Yes, I do.
          25         Q    You recognize Mr. Minton?
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           1         A    Yes, I do.
           2         Q    And you thought that was funny?  Your statement
           3    about Mr. Miscavige?
           4         A    Yes, I did.
           5         Q    You don't consider that a threat?
           6         A    No, I don't.
           7         Q    You think it is appropriate for an expert, or
           8    anybody, for that matter, but particularly an expert on --
           9    supposedly on religion to be in front of the Ft. Harrison to
          10    be making obscene statements about David Miscavige like that
          11    to other -- to Scientologists?
          12         A    You know, I think there was an indiscretion that
          13    happened there, certainly.
          14         Q    And you consider it harassment for you and
          15    Mr. Prince -- and Mr. Minton and others to be holding signs
          16    like the one you were holding, "Lisa, blood on her hands,"
          17    and the one Mr. Minton was holding about the Third Reich, do
          18    you consider that harassment to be walking in front of the
          19    mecca of Scientology?  Do you consider that to be
          20    harassment?
          21         A    I consider it to be exercising my constitutional
          22    right --
          23         Q    Okay.
          24         A    -- as a citizen of America.
          25              MR. WEINBERG:  Want to play the next one,
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           1         please?  Actually, let me -- go ahead.
           2              ______________________________________
           3              (WHEREUPON, the video was played.  No audio
           4         available.)
           5              MR. WEINBERG:  This is on the same day in front
           6         of the Criminal Court Complex.
           7    BY MR. WEINBERG:
           8         Q    Now, do you remember this being the day of the
           9    arraignment in the criminal case and do you remember being
          10    in front of the complex with Stacy Brooks, Bob Minton, Ken
          11    Dandar, Dr. Garko and yourself?  Do you remember that photo?
          12         A    I remember that photo.
          13         Q    And do you recognize that as the criminal complex
          14    in Clearwater?
          15         A    The one on 49th Street?
          16         Q    Yes.
          17         A    Yes, I do.
          18         Q    And who took that photo?
          19         A    You know, I'm not sure.
          20         Q    And do you think that is funny?  "Scientology,
          21    Hubbard Third Reich," do you think that is funny?
          22         A    You know, I think those people in that picture are
          23    exercising their constitutional rights.
          24         Q    Do you think it is appropriate for the trial team
          25    of Mr. Dandar, Dr. Garko and you and Ms. Brooks, along with
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           1    Mr. Minton, to be standing in front of a public building
           2    holding signs like that?
           3              MR. DANDAR:  Objection.
           4    BY MR. WEINBERG:
           5         Q    Do you think that is appropriate?
           6              MR. DANDAR:  Objection.  Mr. Minton is not part
           7         of any trial team.
           8              THE COURT:  He said "and Mr. Minton."  So I'm
           9         assuming he was excluding him.
          10              MR. WEINBERG:  That is what I did.
          11    BY MR. WEINBERG:
          12         Q    Do you consider that to be appropriate behavior?
          13         A    I consider that unless I'm committing a crime, I'm
          14    exercising my constitutional rights as an American citizen.
          15         Q    Do you believe that that constitutes harassment of
          16    the Church of Scientology?
          17         A    No, I don't.  I think if I was doing anything
          18    illegal, Scientology would have had me arrested on the spot.
          19         Q    Okay.
          20              THE COURT:  Harassment is not illegal.  I guess
          21         what he's trying to ask you is, in addition to
          22         exercising your First Amendment rights, did you
          23         consider that that might be considered harassment?
          24              THE WITNESS:  You know, and I -- my answer
          25         again is no.  My answer is I'm exercising my
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           1         constitutional rights as an American citizen.
           2    BY MR. WEINBERG:
           3         Q    You wouldn't consider that picket --
           4              MR. WEINBERG:  Can you put that photo back up?
           5    BY MR. WEINBERG:
           6         Q    Somebody asked you -- I think Mr. Dandar asked you
           7    whether or not he was ever on a picket.
           8              THE COURT:  Now, Counselor, in all fairness,
           9         that is a picture, that is not a picket.  What we
          10         saw before --
          11              MR. WEINBERG:  I understand.  I was asking to
          12         ask him.  This is a picture.
          13    BY MR. WEINBERG:
          14         Q    My question is what was going on with these signs
          15    in front of the Clearwater courthouse?  What were you-all
          16    doing with these signs?
          17         A    I think we had been picketing earlier.
          18              THE COURT:  Was Mr. Dandar with you when you
          19         were picketing?
          20              THE WITNESS:  Absolutely not.  Neither was
          21         Mr. Garko.
          22    BY MR. WEINBERG:
          23         Q    And whose idea was it to pose for this picture?
          24         A    I don't know.  I don't recall.  I don't remember.
          25         Q    I mean, no one forced you-all to do this.
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           1    Correct?
           2         A    Correct.
           3              MR. WEINBERG:  Go to the next one, please.
           4              ______________________________________
           5               (WHEREUPON, the video was played.)
           6              "You work for a criminal organization.  And
           7         they're going to be found out.  You take that and
           8         put it on the camera and run it to Miscavige, your
           9         leader, your guru.  He's going down."
          10              (End of playing of video tape.)
          11              ______________________________________
          12    BY MR. WEINBERG:
          13         Q    Now, that was right outside the Clearwater Bank
          14    building where all the people go in to eat.  Correct?
          15         A    Yes.  It was.
          16         Q    And right down the street, as you look down the
          17    street, is where the LMT offices were?
          18         A    That is correct.
          19         Q    All right.  And do you consider that to be a
          20    threat to Mr. Miscavige where you say he's going down?
          21         A    No, I do not.  And I think I have to -- you know,
          22    because this is just a little snippet you are showing here,
          23    I think I should give the situation that was occurring.
          24              On that very street that you saw me in front of
          25    where the Lisa McPherson Trust is around the corner, on that
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           1    particular day I had gone to a shop on Cleveland to buy a
           2    pack of cigarettes and go back to the office.
           3              From the moment I walked out of my office, all of
           4    the way up to the door of the shop I went to and all of the
           5    way back, a Scientology OSA person had a camera on me like
           6    this (indicating).
           7              I was annoyed.  If that is a crime, find me
           8    guilty.
           9         Q    Now, was that your purpose when you say, "You're
          10    going down," was your purpose to get rid of Mr. Miscavige
          11    from being the chairman of the board or the ecclesiastical
          12    leader of Scientology?
          13         A    My purpose was to express my annoyance.
          14         Q    And "guru," were you just being funny?
          15         A    Again, my purpose was to express my annoyance.
          16         Q    Now, was that your agenda?  Strike that.
          17              Was it Mr. Minton's agenda -- was part of his
          18    agenda to get rid of David Miscavige?
          19         A    You had Mr. Minton up here --
          20         Q    I'm just asking you.
          21         A    -- Mr. Weinberg, forever, you know.
          22         Q    I'm asking you.
          23         A    He never said that to me.  He never said that to
          24    me.
          25              THE COURT:  There is an answer in the
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           1         courtroom.  It is called "I don't know."  If it
           2         is --
           3         A    He never -- no, he never said that to me.
           4    BY MR. WEINBERG:
           5         Q    Now, you described you, Ms. Brooks and Mr. Minton
           6    as the A team, right?
           7         A    Correct.
           8         Q    And the A team got formed in the summer of 1998?
           9         A    I would say -- Mmm -- thereabouts.
          10         Q    Right.  And the A team continued to be --
          11         A    Maybe -- wait a minute.  I misspoke about that
          12    because that A team business didn't come up until after --
          13    after we'd worked together for a while and had done things.
          14    And that concept came out -- in the summer of '98 is when I
          15    first met them, so I think it would be a misrepresentation
          16    to say that the A team was in the summer of '98, at least to
          17    my best recollection as I sit here today.
          18         Q    So when was it?
          19         A    And I can't be sure.  It was sometime later.
          20         Q    When you said it became the A team after you had
          21    done things, what kind of things?  Are you talking about
          22    like -- do you mean like pickets and sending postings and
          23    things like that?  Are those the things that you were doing?
          24         A    I think more like helping people directly.
          25         Q    Helping people?
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           1         A    Yes.
           2         Q    How was Mr. Minton helping people, by standing and
           3    holding signs like that?
           4         A    Well, you know, I guess there is a myriad of
           5    answers for that.  But what I meant to say, helping people,
           6    I meant helping people that had run into problems with
           7    Scientology and were not able to resolve them so that they
           8    can get on with their lives.
           9         Q    Now, where did the A team concept come from?
          10         A    You know, I think there used to be a television
          11    program.
          12         Q    Are you talking about the one with Mr. T?
          13         A    If you let me finish.  You know, the reason why I
          14    can't answer that question, because when those television
          15    series were going on, I was in the Sea Org and we weren't
          16    allowed to watch TV.  So I have a big missing section in my
          17    life with serial programs and things like that.
          18              So again I'll say there was some program that had
          19    the A team on it.  And I think Mr. Minton brought it up
          20    and -- but --
          21         Q    And --
          22         A    -- but I have never seen a program called the A
          23    team or anything like that.
          24         Q    When you said the A team yesterday, what did you
          25    mean, A team?  What was it that the A team was doing?
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           1         A    The A team was myself, Bob and Stacy.  And the A
           2    team were helping people that needed help to resolve issues
           3    with Scientology.
           4              You know, just to -- to show how far at the other
           5    end of the spectrums were, Mr. Minton actually thought he
           6    was helping Scientology by helping these people resolve
           7    issues with Scientology.
           8         Q    Do you remember speaking to the media about
           9    bringing Mr. Miscavige down?
          10         A    No.  I do not.
          11              MR. WEINBERG:  Play that next one, please.
          12              ______________________________________
          13              (WHEREUPON, the video was played.)
          14              "It takes standing up and recognizing it for
          15         what it is, a dead, arcane idea.  We're dealing with
          16         people who are ignorant and we're going to bring
          17         them down."
          18    BY MR. WEINBERG:
          19         Q    Do you remember that?
          20         A    I object to that very -- I can't object, but that
          21    was an obvious edit where you sliced two things together.
          22    And I think you are mischaracterizing a speech that I gave
          23    for a vigil for Lisa McPherson where the press was there.  I
          24    was not speaking for the press.  I was speaking to former
          25    Scientologists.
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           1         Q    Were you talking about bringing down Scientology?
           2    Is that what you were talking about?
           3              MR. DANDAR:  We object and ask the whole thing
           4         be played.
           5              THE COURT:  I think that is fair.
           6              MR. WEINBERG:  It was a newscast, we didn't --
           7         we can play the whole newscast.  It takes a minute.
           8              THE COURT:  I don't want the whole newscast.
           9         Just whatever Mr. Prince said.
          10              MR. WEINBERG:  Well, that is what Mr. Prince
          11         said.  That is all he said is what we just played.
          12              THE COURT:  Well, it did look like there was a
          13         definite splice.
          14              MR. WEINBERG:  There was.  One of these
          15         newscasts where the reporter said something and
          16         Stacy Brooks said something and he said the first
          17         thing on there, Mr. Prince, then somebody else said
          18         something, then he said the last thing.
          19              We took the two things Mr. Prince said and put
          20         it together.  But we can play the whole section.
          21              THE COURT:  It makes it look like he said all
          22         that together, and it may not have been.
          23              I think if what it is you are trying to do is
          24         every time he said we're going to bring him down,
          25         what is it you mean when you say that?
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           1              THE WITNESS:  Expose -- expose what is actually
           2         going on.
           3              THE COURT:  Okay.
           4              THE WITNESS:  You know, expose the fact that
           5         private investigators are being used to terrorize
           6         citizens because they disagree with Scientology.
           7         Expose the fact that someone gave $100,000, and it
           8         is Scientology's policy, if you don't use a service
           9         that you paid for, they will refund it to you.
          10              THE COURT:  Normally, when you want to say
          11         we're going to expose somebody, you don't say expose
          12         somebody, you say bring them down, that kind of
          13         means put them out of business.  That is what I mean
          14         by that.  What did you mean by it?
          15              THE WITNESS:  I mean ending the criminal
          16         activity.  Ending the assault of citizens who have
          17         no way to protect themselves once they get on the
          18         bad side of Scientology.
          19              THE COURT:  When you say "We are going to bring
          20         you down," this is your testimony, you did not mean
          21         put the Church of Scientology out of business, do
          22         away with the Church?
          23              THE WITNESS:  Right, in the illegal activities.
          24         I never had a -- as I said, corrupt activities
          25         wasn't even anything in my mind during the majority
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           1         of my stay in Scientology.  These are things that I
           2         learned about after I got to Gilman, Hot Springs,
           3         and started working directly for Mr. Hubbard and
           4         Mr. Miscavige.  I was an ignorant, blind person to
           5         it prior to that time.
           6    BY MR. WEINBERG:
           7         Q    When you said in that newscast that I just played,
           8    quote, "It takes standing up and recognizing it for what it
           9    is, a dead, arcane idea," that was how you -- that -- you
          10    were expressing your opinion about Scientology, that is what
          11    you meant by that, isn't it?
          12         A    No.  You have taken this out of context because I
          13    don't know what "It is."  You showed me a little snippet.  I
          14    don't know what you're talking about.
          15              THE COURT:  I don't, either.
          16              MR. WEINBERG:  I have the transcript.  We'll
          17         play the whole tape because we are obviously not
          18         going to get done today.
          19    BY MR. WEINBERG:
          20         Q    But -- it was a response to a question, "Today
          21    they spoke out against the Church of Scientology," and then
          22    they play what you said about it.  But we'll play the whole
          23    thing.  It takes about a minute.  All right.
          24              You remember going on several trips to Europe with
          25    Mr. Minton, correct?
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           1         A    I think I went on a couple of trips with
           2    Mr. Minton.
           3         Q    All right.  He paid for the trips?
           4         A    Correct.
           5         Q    Who else went with you?
           6         A    You know, as a matter of fact, I only traveled to
           7    Europe with Mr. Minton one time.
           8         Q    And the purpose of that trip was?
           9         A    To visit with his business partner, Jeff Schmidt,
          10    to have a face-to-face with him to find out specifically
          11    what Scientology-hired private investigator David Lee was
          12    doing to try to get him to a -- do a similar thing as Bob
          13    and Stacy, basically turn against Bob and provide criminal
          14    information so Scientology could use it to attack Bob
          15    Minton.
          16         Q    Now, do you remember being in Germany with
          17    Mr. Minton and Ms. Brooks in or about June of 2000?
          18         A    I think I was in Leipzig, Germany.
          19         Q    And Mr. Minton paid for that trip?
          20         A    I think that trip was paid by the Lisa McPherson
          21    Trust.
          22         Q    So in June of 2000 you were on the payroll of the
          23    Lisa McPherson Trust at that point?
          24         A    Correct.
          25         Q    You had just gone on the payroll?
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           1         A    You know, I can't remember.
           2         Q    And do you remember -- you remember being in the
           3    DB lounge?
           4              THE COURT:  What is that?
           5         A    Yes.
           6              THE COURT:  What is a DB lounge?
           7              MR. WEINBERG:  It is a bar of some sort.
           8    BY MR. WEINBERG:
           9         Q    Correct?
          10         A    We were at a train station in Leipzig, and there
          11    was a bar called the DB Bar, which we thought was amusing
          12    because DB means something very specific in Scientology, it
          13    means degraded being.
          14         Q    And you were there with Ms. Caberta, we heard
          15    about, the German government official that works against
          16    Scientology, right?
          17         A    Correct.
          18              MR. WEINBERG:  I'll play this clip here.  This
          19         is something turned over to us by the Lisa McPherson
          20         Trust.
          21              ______________________________________
          22              (WHEREUPON, the video was played.)
          23              "Okay, so -- so, Stacy, you start.  DM, this
          24         drink's for you.
          25              "DM, this is a special toast to you coming
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           1         straight from the DB Lounge in Leipzig, Germany.
           2              "I'm not going to call this guy DM anymore.
           3         Remember what my new name for David Miscavige is,
           4         the former ecclesiastical leader of the Church of
           5         Scientology.
           6              "I know this is going on camera.
           7              "I know, but what did I say -- (inaudible).
           8              "Yes -- yes, this is -- this is a toast to
           9         David Miscavige, also known as Pope David I, from
          10         the DB lounge in Leipzig, Germany.  Up, up, up and
          11         away.
          12              "Now, Ursula.
          13              "Hi, Mr. Miscavige.  We did a great work here
          14         in Germany.  And we will finish Scientology soon.
          15              "This is to you, Miscavige.  We are so thankful
          16         that you give us reason to live.  Salute.
          17              "Pope David I.  Cheers.
          18              "Cheers.
          19              "Just some DBs hanging out here.
          20              "David I.
          21              (Inaudible.)
          22              "This is to David Miscavige in the DB Lounge in
          23         Leipzig, Germany at the train station.
          24              "Pope David I.
          25              "Cheers, Miscavige.
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           1              "Rear Admiral.
           2              (Inaudible.)
           3              "Listen, listen, just --
           4              "No, just stop here now.  Now listen.
           5              "We all know in Grady's deposition, when Grady
           6         was deposing David Miscavige, that he went ballistic
           7         over the thought of Graham --
           8              "Now --
           9              "-- of Graham Berry spending time --"
          10              (End of playing of the video tape.)
          11              ______________________________________
          12    BY MR. WEINBERG:
          13         Q    Does that bring back memories, Mr. Prince?
          14         A    Yes.
          15         Q    And you think that is funny?
          16         A    Well, what I think you have is a home video of our
          17    trip in Europe that was never made public -- Mmm -- to
          18    anyone.  And we were just having fun.  Yes, I do think it
          19    was funny.  We were just having fun at the train station.
          20         Q    Does that man, Mr. Minton, look like the most
          21    harassed person on the face of the earth?
          22         A    He does, to me.
          23         Q    And when Ms. Caberta, the German official who
          24    has -- who flew over here and who is working against
          25    Scientology, when she said, "We're going to finish
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           1    Scientology," she was talking about getting rid of it,
           2    wasn't she?
           3         A    No.  I think she was specifically talking about
           4    Scientology isn't viewed as a religion in Germany.
           5    Scientology is viewed as a political group.  The reason
           6    Scientology is viewed as a political group --
           7              THE COURT:  I don't need to know that.
           8              THE WITNESS:  Okay.
           9              THE COURT:  I don't need to know, care, what is
          10         going on in Germany.
          11              THE WITNESS:  Okay.
          12    BY MR. WEINBERG:
          13         Q    When you talk about the reason for living, when
          14    you-all were talking about, you know, David Miscavige gives
          15    us a reason to -- a reason for living -- reason to live for,
          16    talking about so that you can malign him, is that what
          17    you-all are talking about?
          18         A    No.  Not at all.
          19         Q    And do you remember -- it was cut off at the end.
          20    Do you remember that -- that at that point, Mr. --
          21    Mr. Minton said something very obscene about Mr. Miscavige?
          22         A    I do not remember that.  But, again, I'll state
          23    that this was a video that we made on our trip that was a
          24    private video, never made public, never put on the Internet,
          25    and it is being exploited here today.
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           1         Q    Well, it sort of gives you a different impression
           2    about what you-all were about, doesn't it?
           3         A    Who is you-all?
           4         Q    Excuse me?
           5         A    Who are you talking about, you-all?  What you-all
           6    were about.  What are you talking about?
           7         Q    You, Ms. Brooks, Mr. Minton?
           8         A    The --
           9         Q    The A team?
          10         A    I didn't get that impression.
          11         Q    Now, who took that video, this home video that
          12    ended up in the LMT on this trip that was financed by the
          13    LMT?
          14         A    I think Mr. Bunker.
          15         Q    So he was there, too, obviously?  Was anybody else
          16    on this trip?  You have the A team, you have Mr. Bunker.  Is
          17    there anybody else on it?
          18         A    Not that I specifically recall.
          19         Q    And you-all thought the DB was kind of funny
          20    because that is a Scientology term?
          21         A    Correct.
          22         Q    Now, after looking at your obscenities in front of
          23    the Ft. Harrison about Mr. Miscavige, watching this toast,
          24    you still think that he would be your friend?  Wasn't that
          25    your testimony this morning?
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           1         A    You know, I'm talking to a camera there.  The
           2    answer to your question is yes, I think that if he and I sat
           3    down and actually had a discussion, we would certainly find
           4    friendship, would be able to communicate.  I mean, isn't
           5    Scientology all about helping people learn --
           6              THE COURT:  That didn't really answer the
           7         question.  You have that opinion and that is fine.
           8         Then that is the answer to the question.
           9    BY MR. WEINBERG:
          10         Q    You talk about counseling.  The principal purpose
          11    of the LMT, when it moved into Clearwater, was for the A
          12    team and the people that were working for the A team to
          13    picket and harass Scientology, wasn't it?
          14         A    That is incorrect beyond belief.
          15         Q    Okay.  Now --
          16         A    I would like to explain that, if I could.  I would
          17    like to explain why the LMT came here, since you brought it
          18    up, and if you would allow me to just fully answer the
          19    question.
          20         Q    So you were involved in the --
          21              THE COURT:  I'm going to let him answer the
          22         question.  What was the purpose of the LMT that --
          23         what do you believe the purpose of the LMT was?
          24              THE WITNESS:  The purpose of the LMT --
          25              THE COURT:  Fifty words or less.
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           1              THE WITNESS:  Okay, fifty words or less, and I
           2         won't talk too fast for the court reporter.
           3              THE COURT:  That is 25.
           4              THE WITNESS:  When Lisa McPherson left that
           5         hotel, she had no place to go.  She had a minor
           6         accident, stripped off her clothes, told people that
           7         she needed help.  She ended up back in the Ft.
           8         Harrison.  Seventeen days later, she was dead.
           9              The reason that Lisa McPherson came to
          10         Clearwater and the reason it was there, in case
          11         there was another instance where someone needed a
          12         safe place to go where they could come and get help.
          13         That is why we were there.  And that is the only
          14         reason we were there.
          15              And those were the dying wishes of Fannie
          16         McPherson, Lisa McPherson's mother, when she was on
          17         her deathbed.
          18    BY MR. WEINBERG:
          19         Q    So all of this picketing which happened on a
          20    regular basis, correct --
          21         A    Incorrect.
          22         Q    Well, can you, like, give us an estimate of the
          23    number of times you participated in a picket against the
          24    Church of Scientology?
          25         A    Yes, I can.  Let me think.  Because I certainly
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           1    remember the first one well enough.  I think I have probably
           2    been involved in maybe six or seven pickets.
           3         Q    So in the --
           4              THE COURT:  Over what periods of time,
           5         Mr. Prince?
           6              THE WITNESS:  From 1998 to the present.
           7              THE COURT:  All right.
           8    BY MR. WEINBERG:
           9         Q    So in a four-year picket --
          10              THE COURT:  Four-year period.  Not picket.
          11    BY MR. WEINBERG:
          12         Q    Right, I have picket on the brain.  In the
          13    four-year period, you say you only picketed six times?
          14         A    I roughly estimated six or seven times that I
          15    picketed, yes.
          16         Q    And do you have a sense of how many times
          17    Ms. Brooks and Mr. Minton picketed in that four-year period?
          18         A    I do not.
          19         Q    A lot more than six?
          20         A    I believe so.
          21              THE COURT:  He said he didn't know.
          22              MR. WEINBERG:  I believe he just said "I
          23         believe so."
          24    BY MR. WEINBERG:
          25         Q    Now, in Clearwater there were other people in the
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           1    LMT that participated in pickets, including Peter Alexander,
           2    correct?
           3         A    Yes.
           4         Q    Patricia Greenway?
           5         A    Yes.
           6         Q    Frank Oliver?
           7         A    I -- I can't say that I have ever seen Frank
           8    Oliver carrying a sign, picketing.
           9         Q    So you are not aware he picketed?
          10         A    Correct.
          11         Q    Of course Minton -- of course, the A team, right?
          12         A    You know, I think Stacy herself maybe picketed
          13    maybe five or six times, as well.  But then she didn't do it
          14    anymore because it was not anything she agreed with, nor did
          15    she feel it was effective in handling the problem that we
          16    were dealing with.
          17         Q    Well, let me ask you this.  Do you remember that
          18    on September 2, 1998 you and Mr. Minton participated in a
          19    picket in Boston at the Boston Airport?
          20         A    At the Boston Airport?  We -- I think you have
          21    that in complete reverse.  Scientologists picketed us at the
          22    airport.
          23         Q    Do you have signs, "Scientology, The Third Reich"?
          24         A    Do I have signs?
          25         Q    Did you-all, you and/or Mr. Minton?
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           1         A    Mmm, it's a possibility.  I don't know.
           2         Q    In September of '98 did you and Mr. Minton picket
           3    in front of the Church of Scientology in Boston?
           4         A    That is possible.
           5         Q    Well, that is when he was actually arrested for
           6    assault and battery.  Right?
           7         A    Correct.
           8         Q    In October of 1998 did you picket with Mr. Minton
           9    in front of the Church of Scientology in Boston?
          10         A    It's possible.
          11         Q    You remember several pickets in Boston in October
          12    of '98 with one of Mr. -- one with Mr. Minton and one with
          13    Ms. Brooks?
          14         A    I don't remember that specifically, no.
          15              THE COURT:  Tell me why we have to spend so
          16         much times on these pickets.
          17              MR. WEINBERG:  Because, your Honor, it -- it --
          18         it demonstrates -- first of all, it puts the lie to
          19         what we've heard all of the way through --
          20              THE COURT:  But I know that this man has been
          21         involved in pickets.
          22              MR. WEINBERG:  It is way beyond that, your
          23         Honor.  I mean, really --
          24              THE COURT:  Pardon?
          25              MR. WEINBERG:  It is way beyond that.  You have
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           1         before you a harassment time line.  And Mr. Dandar
           2         has spent literally 28 days suggesting that somehow
           3         Mr. Minton was harassed to the point where -- where,
           4         for reasons that don't make any sense to me, for
           5         that purpose he would come in and incriminate
           6         himself.
           7              And the fact is -- we're not playing all of the
           8         pickets.  But when you see these clips, most of
           9         which we got from the Lisa McPherson Trust in these
          10         videos that were just turned over, you will see what
          11         was really -- what was happening here in Clearwater.
          12              THE COURT:  I have no doubt that at the LMT
          13         Trust they had very little use, if any, for the
          14         Church of Scientology.  And they picketed them
          15         fairly regularly.
          16              Quite frankly, if they had fallen on their
          17         face, they wouldn't have cared; that they were out,
          18         in essence, to undo what they perceived to be the
          19         bad things that they perceived the Church of
          20         Scientology did.  I don't have any doubt about that.
          21         I think the record is clear.  So I don't know why we
          22         keep going over those things.
          23              There are things that are really critical to
          24         this hearing.  And I don't think those are it.
          25              MR. WEINBERG:  Well, I mean --
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           1              THE COURT:  It might be important to the
           2         counterclaim, but not to this hearing.
           3              MR. WEINBERG:  Well, I mean, if you rely on,
           4         for example, what Peter Alexander said, he said he
           5         didn't have anything -- or essentially nothing to do
           6         with it.  You'll see essentially the opposite.
           7              You have heard that somehow Mr. Minton was
           8         harassed.  And you're going to see what was really
           9         going on, that the Church was harassed beyond
          10         comprehension.
          11              THE COURT:  I have no doubt Mr. Minton harassed
          12         the Church, as well as the Church harassed
          13         Mr. Minton.  It is just that simple.
          14              MR. WEINBERG:  But nothing is more -- well, can
          15         I proceed with my cross-examination?
          16              THE COURT:  Yes.  You may.
          17              MR. WEINBERG:  Thank you.
          18    BY MR. WEINBERG:
          19         Q    You went on the Internet, as well, didn't you?
          20         A    I have been on the Internet.  Yes, I have.
          21         Q    You made postings on the Internet?
          22         A    Yes, I have.
          23         Q    In that Leipzig toast you -- instead of using the
          24    name "David Miscavige," you actually said "Miss Cabbage,"
          25    didn't you?  That was a little joke, wasn't it?
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           1         A    Did I say that?
           2         Q    I'm asking you.
           3         A    I thought I said "Miscavige."
           4              MR. DANDAR:  I think we need to hear the video,
           5         rather than someone's transcript.
           6              MR. WEINBERG:  I'm going to show you a posting.
           7              THE COURT:  In a posting we have heard him
           8         called Rear Admiral.  We know what that means.  And
           9         we know they called him Miss Cabbage.  And they
          10         don't speak kindly of David Miscavige.
          11              MR. WEINBERG:  I understand that.  And I'm
          12         going to show him, have him identify, his Internet
          13         postings.
          14         A    I will admit -- I have said that before, Miss
          15    Cabbage.  I just don't know that -- if that is what you are
          16    seeing there.
          17              MR. WEINBERG:  Could I stand up here with
          18         Mr. Prince?
          19              THE COURT:  You may.
          20              MR. WEINBERG:  I have no other copies.
          21              THE WITNESS:  I have no idea what this is.
          22    BY MR. WEINBERG:
          23         Q    This is your postings, isn't it?
          24         A    Excuse me?
          25         Q    This is your postings?
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           1         A    I don't think so.  I think it is a fictitious
           2    document created --
           3         Q    So you didn't send a posting that said:  "Too bad,
           4    Little Miss Cabbage has a corncob up your ass, 724365.  I
           5    know the feeling.  That is why I have him reeling, spending
           6    money like a bitch kicked from a pimp.  Roll on, ho, big
           7    daddy can see you.  Jesse."
           8         A    Yes, correct.  But that is a fictitious document
           9    that was created for the purpose of -- to malign me.
          10         Q    To malign you?
          11         A    Yes.
          12         Q    But you have used Miss Cabbage?
          13         A    Yes, I'll admit it.  Freely admit it.
          14              MR. DANDAR:  Objection.  This does not have the
          15         normal E-Mail headers on it that you would find if
          16         it was an original document, instead of something
          17         that someone altered.
          18         A    I don't even know who Robert is.
          19              THE COURT:  I don't know.  If he can't
          20         authenticate that, I don't know whether -- I don't
          21         know whether it is in or not.  At the top it says
          22         "Spread the word, bitch."  Then it goes on to some
          23         other comments.  And that is not the way an E-Mail
          24         normally --
          25              MR. WEINBERG:  It is not an E-Mail.  It's a
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           1         posting.
           2              THE COURT:  Well, the same thing.  I don't
           3         know.  It would seem like this Jesse Prince,
           4         Jesse77@GTE.net would be Mr. Prince's -- that would
           5         be -- is that what you go by?
           6              THE WITNESS:  I had that in 1998, I think, when
           7         I had a particular type of computer, I used to have
           8         that address.  But as I sit here today, I don't know
           9         what name -- the name Robert.
          10    BY MR. WEINBERG:
          11         Q    Well, when you use the word "Miss Cabbage," what
          12    do you mean?
          13              MR. DANDAR:  Objection.  That is not his
          14         E-Mail.
          15              THE COURT:  No, he admitted that he has called
          16         David Miscavige Miss Cabbage.
          17         A    It's an obvious derogatory use of Miscavige.
          18    BY MR. WEINBERG:
          19         Q    And derogatory in -- I mean, in what context did
          20    you use it when you used it?
          21         A    I don't remember.  I just know that -- you know --
          22    I have said that before.  I admit to it.
          23         Q    Now, let me show you -- see if you recognize this
          24    posting.  Or is this another fictitious one?
          25              MR. WEINBERG:  What will this be?
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           1              THE CLERK:  219.
           2              MR. DANDAR:  What exhibit number is that?
           3              MR. WEINBERG:  219.
           4              THE COURT:  The one before that was 2-what?
           5              MR. WEINBERG:  218.
           6              THE COURT:  That did not come in because --
           7              MR. WEINBERG:  He said he couldn't authenticate
           8         it.
           9              THE COURT:  So that is not in evidence.  That
          10         is Number 218.  This one you just gave us is 219?
          11              MR. WEINBERG:  Yes, your Honor.
          12              THE COURT:  Okay.
          13              THE WITNESS:  Okay.
          14    BY MR. WEINBERG:
          15         Q    Did you make that posting?
          16         A    Yes, I did.
          17         Q    And do you consider that to be a -- a posting that
          18    would indicate a derogatory view toward Mr. Miscavige and
          19    the religion of Scientology?
          20         A    Mmm, I think that this posting is a result of the
          21    Scientology operations being run on me.
          22              While I'm trying to testify in a court in front of
          23    a judge in Denver, Scientology hired a prostitute, had a
          24    deep undercover agent, Laura Terepin, working on me, helping
          25    me with the deposition, saying there are people other than
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           1    who they are.  You know, this is an annoyance response to
           2    what had been happening to me.  You see I clearly speak
           3    about private investigators following me.
           4              In Denver, very strange things happened.
           5         Q    What do you mean, they hired a prostitute?
           6         A    A prostitute.  You know, this guy from Denver --
           7    there was a private investigative agency in Denver that was
           8    watching me.  He brought a woman who said it was his sister,
           9    who was a whore.  She got a room directly across the street
          10    from my -- not across the street, across the hall from my
          11    room in the hotel that I was staying in.  And when I came
          12    out -- and she was a beautiful woman, you know.  "Oh, can
          13    you help me get my key," on and on and start this
          14    conversation.
          15              This guy says, "This is my sister.  We're just in
          16    town."
          17              Suitable guise.  Mr. Sharp will explain it to you.
          18    And they started this whole routine of, "Come on.  Party
          19    with us tonight.  We've got drugs, we have this.  We've got
          20    whatever."
          21              I'm supposed to testify.  I literally had to get
          22    rid of them.
          23              The other person, Laura Terepin was -- her real
          24    name wasn't Laura Terepin.
          25              Jolie Steckart, specifically paid by Scientology
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           1    to infiltrate Mr. Dan Leipold's office as I sat there
           2    writing my declaration for his case.
           3              It was these kind of things that annoyed me, and I
           4    would write these things.
           5         Q    So when this hooker came to your room, you told
           6    her to leave?
           7         A    Yes.
           8         Q    Or did you --
           9         A    We were at the bar.  And then she wanted to come
          10    to the room.  I'm like, "No, I have to testify."
          11         Q    But I think you testified previously that she
          12    actually -- you let her come to your room and you did
          13    something with her.  Right?
          14         A    No.  I don't think so.  I don't think so.  I -- I
          15    think that you are fabricating that.
          16         Q    Now, when you say in the first sentence:  "It
          17    seems some people (Miscavige) just don't have the guts to
          18    quit when it's over," what did you mean by that?
          19         A    What I meant specifically by that is that I came
          20    into the case -- the FACTNet case -- Scientology had brought
          21    an action against FACTNet for copyright -- certain copyright
          22    violations.  And -- Mmm -- I -- I remember vividly the whole
          23    issue of copyrights in Scientology.  I have given a -- a
          24    detailed affidavit about it.
          25              But the fact of the matter is the copyrights -- or
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           1    at least some of them -- were completely bogus.  And the
           2    filings of the copyrights were filed under false premises.
           3    I did an affidavit against that concerning that --
           4    concerning that naming specifically the people that were
           5    involved.  Another officer, staff member, Pat Brice, was
           6    involved, because after Mr. Miscavige dismantled the
           7    Guardian's Office, there was always a section in
           8    Scientology, according to its own policy, to register
           9    trademarks and copyrights all of the time.
          10         Q    That is what you meant --
          11         A    Excuse me I'm still talking.  And they let that
          12    lapse a period of time.  So you had a large section of
          13    materials that they claim copyright protection for which, in
          14    fact, they did not have.  And I was able to identify what
          15    that was.
          16         Q    So that is what you meant when you said, "When
          17    it's over, they just don't have the guts to know when it's
          18    over"?
          19         A    Correct.  They submit false documents to the
          20    Court.  I point out to the Court that the documents are
          21    false and show them how, is specifically what I mean there.
          22         Q    The third paragraph, the last sentence, where you
          23    say:  "Can't you just --" talking about Miscavige now,
          24    "Can't you just take it like a man?  Soon you'll be in a
          25    place where you'll be taking it like a man regularly," that
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           1    is sort of like the Miss Cabbage thing, you're talking about
           2    him being in jail and sexually assaulted?
           3         A    I'm talking about him being incarcerated for being
           4    involved in criminal activity.
           5              THE COURT:  Was this a posting to David
           6         Miscavige, or somebody else?
           7              THE WITNESS:  No.  It was that newsgroup,
           8         alt.religion.scientology.
           9    BY MR. WEINBERG:
          10         Q    Let me show you another one.  You did hundreds of
          11    these things?
          12         A    I don't think so.
          13         Q    You just felt compelled, as an expert, to go on
          14    this alt.religion.scientology and say obscene things about
          15    David Miscavige?
          16         A    At the time of these writings, I was not
          17    operating -- I don't think I was -- I don't know.  I don't
          18    remember.  I don't think I was an expert in this -- I think
          19    I came in here in December of '99 when --
          20              THE COURT:  I mean, there are people that learn
          21         things from this case.  Mr. Prince, if you are going
          22         to ever testify in another case, you ought to learn
          23         not to post things on an Internet, especially not to
          24         be involved in vulgar demonstrations.  They'll
          25         always come back to haunt you in a court proceeding.
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           1         Just like I hope Mr. Dandar learned, whether you
           2         call it picket or vigil, if you are a lawyer, you
           3         ought not to be there.
           4              There are certain things you need to have
           5         learned.  I hope you learned that.
           6              THE WITNESS:  Your Honor, that is a true
           7         statement.  I have learned that from Judge Moody.
           8         He taught me quite a bit about how I needed to act
           9         in relationship to this.
          10              And you are right, I have had some
          11         indiscretions.  All right, if we need to talk about
          12         that, we will.
          13    BY MR. WEINBERG:
          14         Q    I showed you what I marked as Defendant's Exhibit
          15    220.  Do you see that, Mr. Prince?
          16         A    Yes, I do.
          17         Q    Do you remember writing that open letter to David
          18    Miscavige?
          19         A    Uh-huh.
          20              THE COURT:  That is a yes?
          21              THE WITNESS:  Yes.  I'm sorry.  Yes.
          22    BY MR. WEINBERG:
          23         Q    And -- and this is when you are definitely
          24    involved as an expert, you already worked on Wollersheim,
          25    you already reviewed the PC folders for Mr. Dandar.
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           1    Correct?
           2         A    Quite possibly I'll agree with you there.
           3         Q    And so you say in the first paragraph:  "How
           4    desperate you must feel.  If you sit quietly and listen
           5    carefully, you will hear it."
           6              MR. DANDAR:  Objection.  I need to have the
           7         question asked of the witness to identify this
           8         document and make sure it is his.
           9              MR. WEINBERG:  He just did.
          10         A    This is my document.  Yes.
          11              MR. DANDAR:  It doesn't have headers on it.
          12         That is all.
          13              THE COURT:  Well, he has identified it, so --
          14              MR. DANDAR:  All right.
          15         A    Yes.
          16              THE COURT:  You are introducing this?
          17              MR. WEINBERG:  Yes, I am.
          18              THE COURT:  It will be received.
          19              MR. WEINBERG:  And I --
          20              THE COURT:  Honestly, I'll tell you the same
          21         thing, I don't need you to read it to me.  If there
          22         is some part you want to point to --
          23              MR. WEINBERG:  Really, the first paragraph and
          24         last paragraph.
          25              THE COURT:  Okay.
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           1         A    Yes, I wrote -- I wrote the first paragraph, all
           2    of the paragraphs in the middle, all of the way to the end.
           3              And I think if you read this whole thing, you'll
           4    see that I'm upset, I'm very peeved over the fact on Page 2,
           5    second paragraph, that --
           6    BY MR. WEINBERG:
           7         Q    I didn't ask about Page 2.  I asked about the
           8    first paragraph.  That is all I asked you.
           9         A    Oh, okay.
          10         Q    And the last paragraph.  You wrote that, where you
          11    quote the Bible?
          12         A    Correct.
          13         Q    And the reason for quoting this passage from
          14    Revelations about "Avenge our blood on those who dwell upon
          15    the earth" was what?
          16         A    Well, you know, if you know this passage, these
          17    are the saints that died for righteousness but evil and
          18    corruption carries on.  And when the fifth seal is opened,
          19    biblically speaking, the saints' blood will be avenged.
          20    This is specifically what I'm talking about.
          21              And how this relates to Miscavige and Scientology
          22    is the corruption -- the agonizing activity that I had to go
          23    through to deal with my children, my father, old
          24    girlfriends, Scientology did their noisy investigation on
          25    me.
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           1              I wish I would have had this document when
           2    Mr. Dandar was asking me do you remember noisy
           3    investigations.  They ran around to my entire family.  I had
           4    to go to Chicago, I had to go to Minneapolis, to Memphis,
           5    Tennessee, to deal with friends and associates and family as
           6    a result of Scientology doing their, quote/unquote, noisy
           7    investigation, spreading lies and false information about
           8    me.
           9              THE COURT:  Are you done with Number 220?  We
          10         need to take our break.
          11              MR. WEINBERG:  We offer 220.  And I do also
          12         offer 219, the one before that.
          13              THE COURT:  That will be received, too.  And
          14         we'll go ahead and take our afternoon break.  It is
          15         25 after.  A 20-minute break.
          16              MR. WEINBERG:  Thank you.
          17        (WHEREUPON, a recess was taken from 3:25 to 3:50.)
          18              ______________________________________
          19              THE COURT:  You may continue.
          20              MR. WEINBERG:  Thank you.  At the break I had
          21         one more of these things I was going to mark.  I'll
          22         go on.  That is 221.
          23    BY MR. WEINBERG:
          24         Q    Now, Mr. Prince, do you recognize Defense Exhibit
          25    221 as a posting which you made on or about August 6 of
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           1    1998?
           2         A    If you'll give me just one minute --
           3         Q    Sure.
           4         A    -- to review this document, please, I'll indicate
           5    it for you.
           6              Okay, yes.  I do remember this document.
           7              MR. WEINBERG:  All right.  I'll offer this,
           8         your Honor.  I have a couple questions to ask on it.
           9              THE COURT:  All right.  It will be received.
          10    BY MR. WEINBERG:
          11         Q    Now, this is one of the first postings you made
          12    after you had joined the ranks of working against
          13    Scientology, correct?
          14         A    I would hardly characterize it as that.  But this
          15    is one of the first postings that I made on the Internet
          16    concerning Scientology.  Yes.
          17         Q    All right.  Now, in that first paragraph you say,
          18    second sentence:  "You know, I just can't refer to
          19    Scientology as a church in any way.  It would be an insult
          20    to all religions."  Do you see that?
          21         A    Yes.
          22         Q    And that is how you feel today, isn't it?
          23         A    You know, it is not.  And I can explain to you
          24    why.
          25         Q    You don't need to.
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           1         A    Okay.  Then I have answered the question.
           2         Q    So you think it's a church?
           3         A    Correct.
           4         Q    So you just sent this out of some hatred?
           5              MR. DANDAR:  Objection.  He didn't want him to
           6         explain it.  Now he's asking him.  So let the man
           7         explain his answer.
           8              THE COURT:  Well, I think that was a different
           9         question.  And I think that Mr. Prince is capable of
          10         answering that question, then I think he can explain
          11         it.
          12    BY MR. WEINBERG:
          13         Q    You sent this out of some hatred for Scientology?
          14         A    Mmm, no, sir.
          15         Q    Now, if you go to the fourth paragraph where it
          16    says, I quote:  "The bottom line is that the hierarchy of
          17    Scientology is composed of people who are very, very, very
          18    mentally ill, sick people of the worst sort.  Why?  Because
          19    they are sick and don't know it.  In all honesty, I hope to
          20    reach them so they can wake up and start getting well like I
          21    have and others have."
          22              You wrote that, right?
          23         A    Correct.
          24         Q    Wasn't that what you have, in essence, been doing
          25    for the last four years, trying to get rid of the hierarchy
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           1    of Scientology, including David Miscavige?
           2         A    You know, that is not exactly what I say here, to
           3    get rid of those people.  I said I hope that I could reach
           4    them so that they can wake up and start getting well
           5    themselves.
           6         Q    Now, you -- the truth is, isn't it, Mr. Prince,
           7    that you and Mr. Minton and Ms. Brooks, the A team, had a
           8    ball with regard to all this picketing you-all participate
           9    in over the last four years?
          10         A    I'm sorry, I hardly can agree to that,
          11    Mr. Weinberg.  I wouldn't call it a ball.
          12         Q    You had a lot of fun doing it, wouldn't you say?
          13         A    I wouldn't say that either, Mr. Weinberg.
          14         Q    You remember the first time that you went to New
          15    Hampshire and -- and -- and encountered picketing in New
          16    Hampshire?
          17         A    Yes, when Scientologists came in and picketed
          18    Mr. Minton's home.
          19         Q    Right.  And that was on Mr. Minton's -- that was
          20    on Ms. Brooks' harassment time line.  Right?
          21         A    It very well could have been.  Sure.
          22         Q    And do you remember that you were there with
          23    Mr. Minton and that you-all were laughing and giggling and
          24    making fun of the Scientologists, the few that came by in
          25    the cars?  You called it a drive-by --
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           1         A    The picketers, yes, it was amusing because the
           2    Scientologists came by and stood in the road with their
           3    signs, and it is quite a narrow road up in New Hampshire,
           4    there aren't sidewalks where Mr. Minton lives.  So a state
           5    trooper came and asked them not to stand in the road because
           6    it was dangerous.  It was actually kind of a blind curve by
           7    Mr. Minton's house that makes it dangerous, being there are
           8    no sidewalks.
           9              And what was particularly amusing about what the
          10    Scientologists resorted to at that point is that they --
          11    Mmm -- went around and pulled their cars way back, then took
          12    their picket signs out the window, because they were too big
          13    to stick through the window, and they held them outside of
          14    the car and drove back and forth.  I thought that was pretty
          15    pathetic.
          16         Q    And you and Mr. Minton had anti-Scientology signs,
          17    correct?
          18         A    Mr. Minton had signs.
          19         Q    You did, too?
          20         A    No.  I never owned a picket sign myself.
          21         Q    You never held a picket sign?
          22         A    I never owned --
          23         Q    I didn't ask you whether you owned it.
          24         A    I'm sorry.
          25         Q    You had a sign.  There were signs there that you
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           1    and Mr. Minton had, correct?  Anti-Scientology signs?
           2         A    That may or may not be correct.  I don't
           3    specifically recall.
           4         Q    All right.  Do you remember doing a posting with
           5    regard to that incident that appears on the harassment time
           6    line?
           7         A    I do.  But -- but, Mr. Weinberg, I have to say
           8    this because, you know, you selectively are taking
           9    paragraphs out of these things and you are painting a
          10    picture here.
          11              But really what this is about is -- this last
          12    thing you handed me is about trying to help these people.
          13    I'm telling the story about something that happened to Marty
          14    Rathbun, something that might have had a psychological
          15    impact on him that he would need help resolving.
          16         Q    But that wasn't my question.  All my question was,
          17    you did another posting about this incident which appears on
          18    Mr. Minton's harassment time line in front of his house in
          19    1998.  Correct?
          20         A    You know, I need that time line right here.  I
          21    mean, I'm saying it's possible.  But if you want to pull it
          22    out, you want to show me what you're talking about, I think
          23    I can answer the question better.
          24              Thank you.
          25              MR. WEINBERG:  Marked as 222.
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           1    BY MR. WEINBERG:
           2         Q    You can identify this as your posting, can you
           3    not, Mr. Prince?
           4         A    Yes.
           5         Q    And in the second paragraph you say, "Bob and
           6    Jesse quickly helped with the pilot and started bullbaiting
           7    the protesters."
           8              When you say bullbaiting, that would suggest that
           9    you were, what, holding signs or doing something back?
          10         A    No.  Bullbaiting is a term that is used in
          11    Scientology specifically to designate some of their training
          12    routines.  The training routines are called TRs; TRs for
          13    short.
          14              Part of the training routine is to be able to sit
          15    across from a person without flinching and without moving
          16    when the person makes gestures or tries to do something
          17    shocking; in other words, this is a routine to train you to
          18    keep your countenance during an adverse commission, I guess.
          19         Q    In here you said, "We had great fun"?
          20         A    Correct.
          21         Q    Now, do you know why this appeared on the
          22    harassment time line if it was so much fun?
          23         A    Well, you haven't shown me that -- and I have
          24    asked you, too, to show me on the time line.  So I can't
          25    answer these questions -- you know, you are referring to
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           1    something that I don't have in front of me.  I can't see it.
           2         Q    I thought from the testimony yesterday that you
           3    had reviewed the time line pretty closely?
           4              THE COURT:  Well, believe me, he has.  It's a
           5         very long thing.  I think it's a fair request.  If
           6         you want him to specifically note whether it is on
           7         the time line or not, show him the time line.
           8              MR. WEINBERG:  I will.
           9              THE COURT:  My recollection is that document
          10         was extremely long.
          11              MR. DANDAR:  It is.  And, Judge, I object to
          12         222 because there has definitely been editing done.
          13         Right after "barbecue" and before the word "soup,"
          14         something is taken out.
          15              MR. WEINBERG:  No, it is not.  You knew exactly
          16         what it is.
          17              THE WITNESS:  Where is that at?
          18              MR. DANDAR:  Where it said, "You invited Minton
          19         for barbecue," after "barbecue" there is a blank,
          20         then there is "soup."
          21              THE COURT:  222, you are talking about?
          22              MR. DANDAR:  Yes.  Right here.
          23              THE WITNESS:  Second paragraph?  Oh, yes, you
          24         are right.  You are right.  It has been edited.
          25         Something has been deleted from there.
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           1    BY MR. WEINBERG:
           2         Q    What was there?  Because we didn't edit anything.
           3         A    Yes, maybe you didn't, but your client did.  And I
           4    know specifically why.
           5              What it said, "We were having BT and cluster
           6    soup."  BT is part of the secret cosmology of the upper
           7    levels of Scientology.  So this has been, in fact, edited.
           8              MR. DANDAR:  I object to it.  It is an altered
           9         document.
          10              MR. WEINBERG:  Are you testifying, first of
          11         all?
          12              MR. DANDAR:  I'm objecting to it based on
          13         Mr. Prince's testimony.  It's an altered document by
          14         the defendant.
          15              MR. WEINBERG:  He identified it before, your
          16         Honor.
          17              THE COURT:  Well, Mr. Dandar just indicated
          18         that it had been altered.  And so if it now -- I'll
          19         ask you, Mr. Prince, is that the original document,
          20         or has it been altered?
          21              THE WITNESS:  Yes, your Honor, this has been
          22         altered.  This is not the original.
          23              THE COURT:  If you have one that has not been
          24         altered, then it will be admissible.
          25              MR. WEINBERG:  First of all, we didn't alter
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           1         anything.
           2              THE COURT:  I didn't say you did.  But if -- I
           3         mean, I'm happy to write in the original what was
           4         there if Mr. Prince remembers it and everybody
           5         agrees.
           6    BY MR. WEINBERG:
           7         Q    Do you remember what was there?
           8         A    I remember exactly what was there.  It says we
           9    were having barbecue BTs and  cluster soup.  “BTs” and
          10    “clusters” are words Scientologists aren't allowed to use
          11    outside of Scientology.
          12         Q    So it's a derogatory thing?
          13         A    No, there is nothing derogatory about BTs and
14	clusters.  This is a reality – something they believe in.
15	Q    Well, I --
          16         A    But they are sensitive to it, so they altered the
          17    document.
          18              MR. DANDAR:  And I would object.  If there is
          19         any more altered documents, that they not attempt to
          20         use them, or tell you in advance.
          21              THE COURT:  You just heard counsel say he did
          22         not know or believe it had been altered.  So be
          23         careful, though, when you look at your documents.
          24         That does look like something is missing from there.
          25              But I do know on my own E-Mails sometimes they
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           1         all get askew and don't seem to line up right.  I
           2         was on the Florida Supreme Court website looking up
           3         stuff on the death penalty cases.  And all of a
           4         sudden they go and they just stop.  So you can't
           5         tell by looking.
           6              MR. DANDAR:  But this one --
           7              THE COURT:  That one does appear to be where
           8         there is something clearly missing.  So --
           9              MR. WEINBERG:  It obviously was not what I was
          10         focusing on, BT and cluster soup.  But with the
          11         record indicating what Mr. Prince was saying was
          12         there, I offer the exhibit.
          13              THE COURT:  Take the original back and write it
          14         in.
          15              MR. WEINBERG:  Sure.
          16              THE COURT:  And ask Mr. Prince if that is what
          17         he recalls it said and, if so, then we can admit it
          18         with that --
          19              MR. WEINBERG:  I'll let him write it because I
          20         don't know -- I assume how to spell it but I'm not
          21         sure how to spell it.
          22              THE COURT:  BT , is that like two initials.
          23              THE WITNESS:  Yes.
          24    BY MR. WEINBERG:
          25         Q    Here.  Do it like this.
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           1              THE COURT:  Everybody make notations on your
           2         copies.  Cluster is C-L-U-S-T-E-R.
           3              THE WITNESS:  Yes, your Honor.
           4              MR. WEINBERG:  Okay.  And the original has “BT”
           5         and  that he wrote in.
           6              THE COURT:  Okay.  That will be admitted.
           7    BY MR. WEINBERG:
           8         Q    Now, you remember that at this --
           9         A    Excuse me.
          10         Q    I wanted to show you the harassment time line.
          11    Let me show you what has been previously marked as the
          12    harassment time line, the "Time Line of Scientology
          13    Harassment of Robert Minton and Colleagues."
          14              I show you the entry for September 7, 1998.  It
          15    says:  "Scientologists picketed Mr. Minton's home in New
          16    Hampshire again but it was done in a car with picket signs
          17    held out of the car window."
          18         A    Correct.
          19         Q    So that was the incident, right?
          20         A    Yes.
          21         Q    Now, I want to play this.  This is that -- you
          22    remember you-all videoed this?
          23         A    I don't remember videoing the incident, but let's
          24    see what you have got.
          25              Here is your pen, by the way --
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           1              ______________________________________
           2              (WHEREUPON, the video was played.)
           3              "Don't block her sign now, Jesse.  I've gotta get
           4    a picture of that good sign.
           5              "Okay.  Let me put mine up.
           6              "Okay, yeah.
           7              "Hey, Maureen, just out here having a little chat.
           8    So did you see that last --
           9              "(Inaudible.)  I don't know.  All I can say is
          10    when I was in your position, there was a lot of --
          11              "That you're a staunch Scientologist.  And it's
          12    dangerous for you to believe otherwise because you'd be
          13    wrong."
          14              ______________________________________
          15    BY MR. WEINBERG:
          16         Q    Those are Mr. Minton's signs?
          17         A    Correct.
          18              ______________________________________
          19              "Drive-by pickets.  That's cool."
          20              ______________________________________
          21              MR. DANDAR:  Could we clarify the people in the
          22         car are Scientologists?
          23    BY MR. WEINBERG:
          24         Q    They are, aren't they, Mr. Prince?
          25         A    They are.  OSA personnel.
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           1              ______________________________________
           2              "Damn dumb asses.  I got 'em.  See, what they
           3    need, what they need is like a -- what they need -- what
           4    they need is a chain -- I mean a long line of cars.
           5              "They just don't seem to be able to get more than
           6    two --
           7              "Yeah.
           8              "-- for these little New Hampshire things.
           9              "Hey, it's an hour from Boston, man.
          10              "Ain't it pathetic.  One person holding one sign
          11    out the window.  And then when they go by this way, the
          12    driver can't do it so the fucking sign's over there.  Oh, my
          13    God.  How pathetic.
          14              "They must think this is having some kind of
          15    terrible psychological impact.
          16              "Yes, it's just entertaining as all hell.
          17              "Here they come.
          18              "Okay.
          19              (Inaudible.)
          20              "Hey, you fucking idiot.
          21              "They don't have enough nerve to try to run over
          22    me.
          23              "Me, either.  I stood there, too.  I just stood in
          24    the middle of the road and got 'em driving up.
          25              "Look at this.  This is a good one.
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           1              "Here they come again.  That's when they were
           2    coming earlier.  That's all I got of them so far, but the
           3    two of them are good.
           4              "Yeah."
           5              (End of playing of the video tape.)
           6              ______________________________________
           7              MR. WEINBERG:  That is it?
           8    BY MR. WEINBERG:
           9         Q    So you were having fun, you and Mr. Minton, in
          10    this thing on the harassment time line?
          11         A    Mmm, you know, Mr. Weinberg, I think even I said
          12    on that tape it was just an annoyance that they do it;
          13    though it was pathetic and though it was funny, it's
          14    annoying.
          15              Now, you made a huge point about how harassed
          16    Scientology feels about being picketed.  But when these
          17    people come by and picket, we're supposed to be having fun.
          18    You can't have it both ways.
          19         Q    Well, what do you call what they were doing, by
          20    the way?  Do you call that harassment?  Or do you call that
          21    the First Amendment?
          22         A    They were exercising their First Amendment rights.
          23    But what happened that was harassing is that Bob and I
          24    didn't have a clue they were even out there until they
          25    parked their cars, ran up to the door, knocked on the door
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           1    screaming, "Minton, Minton, Minton," then ran back to their
           2    cars.  This is the only way they let us know they were
           3    there.
           4              We are upstairs fooling around on the computers.
           5    These guys are banging on the doors.  We wonder, what the
           6    heck.  We run down.  And we got the drive-by pickets going
           7    on.
           8         Q    They didn't shout obscenities?
           9         A    Absolutely.  "Where is your whore, Minton?"  This
          10    kind of thing.  Absolutely.
          11         Q    You didn't hear that on the tape, though, did you?
          12         A    Well, of course not.  Because what I'm speaking
          13    about is when they knocked on the door, and we were way in
          14    the back of the house.  They wanted to make themselves
          15    known.  Now, what they're doing, going up and down there,
          16    okay.
          17         Q    Now, after this, after September of 1998, was this
          18    your first encounter with picketing, having signs and stuff
          19    like that?
          20         A    It could have been.
          21         Q    Now, after this, for the next -- for the next four
          22    years, or almost four years, Mr. Minton and you and
          23    Ms. Brooks and other people affiliated with the Lisa
          24    McPherson Trust did all kinds of pickets in front of
          25    Scientology buildings, shouting obscenities, making threats,
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           1    interfering with -- with Scientologists going into their
           2    buildings and the like, didn't you?
           3         A    That is categorically false.
           4              MR. WEINBERG:  Could you play the first tape,
           5         please.  This is May 27 -- this is again -- this is
           6         the Lisa McPherson Trust.
           7              ______________________________________
           8              (WHEREUPON, the video was played.)
           9              "Stick this in the right place.  Scientology is
          10         a scam.  A white meter.  Fucking criminal.  David
          11         Miscavige is a white Jew.  He will be a convicted
          12         criminal."
          13              (End of playing of the video tape.)
          14    BY MR. WEINBERG:
          15         Q    Now, do you consider that harassment of the Church
          16    of Scientology?  That was out in front of the church in
          17    Boston, wasn't it?
          18         A    Yes.  Was I there?
          19         Q    I'm asking you, do you consider that harassment?
          20              MR. DANDAR:  Objection.  He's not there.  He
          21         should not be asked to comment about --
          22              THE COURT:  I think he can comment on that.
          23         Overruled.
          24         A    You know, what I see there, that little snippet
          25    that you showed me, I would say yes, that is a bit annoying
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           1    and harassing.
           2              But I also suspect, because when Bob Minton would
           3    go out and picket, he would just be quiet, he wouldn't say a
           4    word, he would just walk up and down the street.
           5              But then the OSA people would come out, Maureen
           6    Garde, the person I was walking with in the previous video,
           7    they would come out and start talking to Mr. Minton about
           8    things from his therapy sessions.  This is where the therapy
           9    information started, in picketing the Boston org.  And they
          10    would kind of whip him into a frenzy.  And the whole idea
          11    was to bait Mr. Minton to make him look like an ass.
          12              Well, you know, I agree everyone ended up looking
          13    like an ass on some of those things, but, you know, let's
          14    put this in perspective, because these little snips aren't
          15    going to work.  These people were specifically targeting
          16    Mr. Minton to do psychological terrorism on him.
          17    BY MR. WEINBERG:
          18         Q    Now, is it a bit annoying that Mr. Minton said
          19    that L. Ron Hubbard and David Miscavige were wife beaters?
          20    That is a bit annoying?
          21         A    And I'm sure he's annoyed because Mrs. Maureen
          22    Garde started speaking to things about -- from his
          23    confidential counseling sessions with Scientology.  How
          24    Scientology got that information, God only knows, because no
          25    one will ever speak on it, will they?  But that is what was
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           1    happening there.
           2         Q    And Mr. Minton, according to your testimony, was
           3    quiet on his pickets?
           4         A    He would just be as quiet as hell.  Then if he got
           5    antagonized, he would start in.  And I think that was known.
           6              And, you know, you talk about me hating
           7    Scientologists.  When you saw me in that first --
           8              THE COURT:  We're well past the answer to that
           9         question.
          10              THE WITNESS:  Okay.
          11              MR. WEINBERG:  Play the next one, please.
          12              ______________________________________
          13              (WHEREUPON, the video was played.)
          14              "Reform Scientology now.  Don't let David
          15         Miscavige destroy Scientology.  L. Ron Hubbard would
          16         not approve of what David Miscavige has done.
          17              "It's safe to look.  It's safe to talk.  Don't
          18         let David Miscavige destroy the Church of
          19         Scientology.  Make it something you can be proud of.
          20         Dump David Miscavige.  Dump David Miscavige.  It's
          21         safe to talk.  It's safe to look.  Don't let David
          22         Miscavige destroy Scientology.  L. Ron Hubbard would
          23         never approve of what Miscavige is doing.
          24              (Inaudible.)
          25              "Reform Scientology now.
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           1              "Don't let the introspection rundown kill you.
           2         You don't have to die in introspection rundown.  You
           3         don't have to let Miscavige scare you to death.
           4              "Don't be afraid.
           5              "Don't let Miscavige scare you out.
           6              "It's okay to confront the fact that Miscavige
           7         cannot handle some pressure."
           8              (End of playing of the video tape.)
           9              ______________________________________
          10    BY MR. WEINBERG:
          11         Q    You recognize that as people including Mr. Minton
          12    from the Lisa McPherson Trust, right where the
          13    Scientologists in Clearwater go to eat, right?  That is
          14    where that was, wasn't it?
          15         A    Yes, it was.
          16         Q    And that sure sounded like a direct attack on
          17    David Miscavige, didn't it?
          18         A    Mmm, it sounded like there was definitely some
          19    problems with Miscavige being voiced there.
          20         Q    You saw Miss Greenway there, didn't you?
          21         A    Yes.
          22         Q    You saw David Cecere from the Lisa McPherson
          23    Trust?
          24         A    Yes.  I didn't see me, though.
          25         Q    You were the vice-president of PR at the Lisa
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           1    McPherson Trust, weren't you?
           2         A    That is such a fabrication, it is laughable.  I
           3    have never been -- had anything to do with public relations,
           4    period.  Can't you tell?
           5         Q    So what was your position at the Lisa McPherson
           6    Trust?
           7         A    I was there specifically to help people who had
           8    been in -- somehow had some gripe with Scientology that they
           9    wanted to make right.
          10              And again I'll say it.  The work that we were
          11    doing at the Lisa McPherson Trust helped Scientology because
          12    you had a lot of garbage in the street, people that were
          13    hurt, people giving you a bad name.  When we finished with
          14    those people, they signed releases saying they wouldn't
          15    speak disparagingly about you again, they got their money
          16    and they went on their way.  Okay, that part needs to be
          17    told.
          18         Q    My only question was what was your title or
          19    position in the Lisa McPherson Trust?
          20         A    Vice-president.
          21         Q    Vice-president of what?
          22         A    The Lisa McPherson Trust.
          23         Q    And what was your responsibility there?
          24         A    I'll say it again.
          25              THE COURT:  He just already said that.
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           1              MR. WEINBERG:  That is just what he said?
           2              THE COURT:  Yes.
           3    BY MR. WEINBERG:
           4         Q    Now, were you referred to as the big boss at the
           5    Lisa McPherson Trust?
           6         A    No.
           7              MR. WEINBERG:  Play the next one, please.
           8              ______________________________________
           9              (WHEREUPON, the video was played.)
          10              "Make Scientology something to be proud of.
          11         Reform it now before David Miscavige ruins it.  Find
          12         the new leaders within your organization whom you
          13         can be proud of.
          14              "Stacy, why don't you try to round some of them
          15         up?
          16              "The Lisa McPherson Trust was established at 33
          17         North Ft. Harrison Avenue in order to let the world
          18         know about the abusive practices which David
          19         Miscavige has caused Scientology to live by.
          20              "The Lisa McPherson Trust will always be here
          21         to remind you that you have a responsibility to be
          22         good human beings.  David Miscavige is ruining your
          23         organization.
          24              "Telecommunications is one of the powerful
          25         things you have learned in Scientology.  Use it.
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           1         Try to use it to make the world a better place and
           2         start with dumping David Miscavige.
           3              "If you ever want any help from Scientology,
           4         you can run to 33 North Ft. Harrison Avenue to the
           5         Lisa McPherson Trust.
           6              "If you remember, Lisa McPherson is the woman
           7         who was held by Scientology for 17 days.
           8              "The whole episode in the Church of
           9         Scientology's Ft. Harrison Hotel was totally
          10         out-tech.  Even the state prosecutor said it was
          11         totally out-tech.  The whole thing was run by David
          12         Miscavige.  David Miscavige is responsible for that
          13         woman's death.
          14              "Remember, David Miscavige is the one who
          15         performed the out-tech on Lisa McPherson.
          16              "Remember, David Miscavige was responsible for
          17         the out-tech, out-tech handling of Lisa McPherson.
          18         She died after 17 days in captivity here.
          19              "It was totally out-tech and you know it.  You
          20         can look and smile.
          21              "David Miscavige pulled the plug on Lisa.  He
          22         pulled the plug on Hubbard's tech.  It's time to
          23         face reality.  Reform Scientology or it will be
          24         destroyed by David Miscavige."
          25              (End of playing of the video tape.)
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           1              ______________________________________
           2    BY MR. WEINBERG:
           3         Q    Now, what was the reason that the Lisa McPherson
           4    Trust documented all these pickets by taking videos like
           5    this?
           6         A    Mmm, I think the purpose of the Lisa McPherson
           7    Trust always having the video when in close proximity to
           8    Scientology is the same reason that -- for the same reason
           9    that happened to Mr. Minton when David Howe (phonetic) and
          10    another staff member -- I think that was a staff member that
          11    attacked him.  I personally took him to the hospital.  He
          12    just raced him, no one is looking, boom.
          13              So it became routine to take a video camera, in
          14    case something did happen that was truly criminal, that it
          15    could be documented.  That was the purpose.
          16         Q    But it was for evidentiary purposes?
          17         A    Correct.
          18         Q    It wasn't for posterity?
          19         A    Correct.
          20         Q    I mean, wasn't this what the Lisa McPherson Trust
          21    was about -- let me finish my question -- to try to get rid
          22    of David Miscavige and to terrorize, using your word now,
          23    the Church of Scientology?
          24         A    I -- I think Mr. Minton was very clear on what the
          25    Lisa McPherson Trust was for.  And I'm glad you showed that
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           1    video, because he made it clear he wasn't out to destroy
           2    Scientology, make Scientology go away, as you have, you
           3    know, suggested earlier.  He wanted it to reform.  He wanted
           4    the criminal activities to stop.
           5              Why does he pick David Miscavige?  I think we need
           6    to talk about it.  Because you know why?  He's the man that
           7    has the private investigators do what they do.  He's the one
           8    that -- that instigates these vicious attacks against
           9    individuals who have any disparaging thing to say about
          10    Scientology.
          11              Why does Mr. Minton mention him?  Because he knows
          12    he's the person that can change it.  Just like that letter
          13    that was turned into evidence concerning Bernie McCabe.
          14    He's the person that can do it.  If anyone can do it,
          15    Mr. Miscavige can do it.
          16         Q    Right.  And you accused Mr. Miscavige of murder in
          17    your affidavit, didn't you?
          18         A    I accused of -- Mr. Miscavige of letting her die?
          19         Q    Of intentionally letting her die?
          20         A    Letting her die.
          21         Q    Intentionally?
          22              THE COURT:  We'll not get anywhere.  The
          23         document speaks for itself.
          24              MR. WEINBERG:  You are right.
          25
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           1    BY MR. WEINBERG:
           2         Q    You suggested, stated, in your affidavit, that a
           3    decision was made, an intentional premeditated decision, to
           4    let her die?
           5         A    Correct.
           6         Q    This is the same man that you shouted obscenities
           7    about, it's the same man we are watching videos of Mr.
           8    Minton and others stand up, asking to be deposed or thrown
           9    out of position, right?
          10         A    It's the same man I audited.  It's the same man I
          11    have been friends with many years.  It's the same man I have
          12    done training with.  It's the same man I helped myself
          13    establish and build Scientology for many years.  So add that
          14    into the equation, too.
          15         Q    You think he would call you his friend?
          16         A    I think if David and I sat down and talked, he
          17    would --
          18              THE COURT:  I have heard this question and I
          19         have heard this answer at least twice.
          20              MR. WEINBERG:  Thank you.
          21    BY MR. WEINBERG:
          22         Q    Now, when Mr. Minton said the words "Out-tech"
          23    that is something that means something to a Scientologist,
          24    correct?
          25         A    Correct.
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           1         Q    I mean, Mr. Minton, prior to getting involved with
           2    you --
           3              THE COURT:  Counselor, it is getting pretty bad
           4         to me because I understood it.
           5              MR. WEINBERG:  But -- all right.
           6    BY MR. WEINBERG:
           7         Q    A Scientologist, or a judge that sat in a hearing
           8    for 28 days.
           9              THE COURT:  There you go.
          10    BY MR. WEINBERG:
          11         Q    That is not something Mr. Minton or any of us,
          12    having not been exposed to Scientology before, would
          13    understand, correct?
          14         A    Yes.
          15         Q    And to be out -- out to accuse the ecclesiastical
          16    leader of being out-tech is about as -- about as serious and
          17    severe an accusation as you could possibly make against
          18    David Miscavige, isn't it?
          19         A    Mmm, Mr. Weinberg, my answer is if the shoe fits,
          20    wear it.
          21         Q    Just answer that question.
          22         A    I did.  If the shoe fits, wear it.
          23              THE COURT:  No, he wants to know if that is a
          24         serious accusation to make to other Scientologists
          25         about their ecclesiastical head.  Is that a bad
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           1         thing to the head of Scientology to be out-tech.
           2              THE WITNESS:  Yes, it is.
           3              THE COURT:  To another Scientologist, those
           4         folks seeing that demonstration, if they believed
           5         that, would not think very highly of their leader?
           6              THE WITNESS:  Correct.
           7    BY MR. WEINBERG:
           8         Q    And would you not -- from looking at that video or
           9    the other videos that you have seen so far, it doesn't look
          10    like any of the Scientologists are having a lot of fun at
          11    your demonstrations, correct?
          12         A    You know, you have only shown me specifically
          13    Mr. Minton.  You haven't shown me what the Scientologists
          14    are doing or not doing, Mr. Weinberg.
          15         Q    Well, in that video we just showed, it was --
          16         A    It was going back and forth.
          17              THE COURT:  You know what, the deal is we are
          18         showing this for --
          19              MR. WEINBERG:  That is correct.
          20              Could you play the next one, please.
          21              ______________________________________
          22              (WHEREUPON, the video was played.)
          23              "Communicate to David Miscavige that he's
          24         fired.
          25              "Remember Lisa McPherson.
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           1              "When you're eating, remember Lisa at her last
           2         meal in December of '95, held captive by the Church
           3         of Scientology leader, David Miscavige.
           4              (Inaudible.)
           5              "What is not safe for you is to stand there and
           6         do nothing.  Tell David Miscavige he's wrong.  Tell
           7         him that L. Ron Hubbard would never approve of what
           8         he is doing to destroy your church.
           9              "PK, PK, don't run away."
          10              (End of playing of the video tape.)
          11              ______________________________________
          12    BY MR. WEINBERG:
          13         Q    Does it look, in that video -- I mean, and others
          14    that we've seen -- that Mr. Minton is terrorized, harassed
          15    or anything like that?
          16         A    Mmm, it looks like Mr. Minton was picketing, to
          17    me.
          18         Q    Now --
          19              ______________________________________
          20              (WHEREUPON, the video was played.)
          21              "Okay, are we going to do the locks?
          22              "But the -- are we going to do the alarms or --"
          23              (Inaudible.)
          24              (End of playing of the video tape.)
          25              ______________________________________
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           1    BY MR. WEINBERG:
           2         Q    You were just having a big time, you and
           3    Ms. Greenway?
           4         A    You know, that is an edited video you have there.
           5    It is -- there is obvious editing there, so I would be
           6    hard-pressed to draw that conclusion.
           7         Q    When it started, it started like all of the
           8    pickets started inside the offices of the LMT, correct?
           9         A    That is a mischaracterization of how pickets
          10    started because every picket did not start in the Lisa
          11    McPherson Trust.  Other people picketed the Ft. Harrison
          12    that weren't associated with the Lisa McPherson Trust or
          13    employees of the LMT -- Lisa McPherson Trust.
          14         Q    That clip from the LMT film library, that one
          15    started in the LMT building, didn't it?
          16         A    I don't know if it started or finished there
          17    because you have shown me one tiny segment.  So, you know,
          18    if I could have some perspective and see the whole thing, I
          19    would be able to comment more accurately.
          20         Q    Now, the LMT -- literally at times these pickets
          21    were intended to literally shut down Clearwater around where
          22    you-all were picketing, right?
          23         A    No.
          24              MR. WEINBERG:  Play that one, please.
          25              ______________________________________
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           1              (WHEREUPON, the video was played.)
           2              "Last year, we were all over the place in a
           3         clump.  We shut down here, we shut down here, we
           4         shut down there.  We had Flag shut down for the
           5         whole day, anyway.  This year we spread out in
           6         strategic spots and shut down the whole city.
           7              "Frank Oliver came and caused the last breach.
           8         So far about two hours now they can't hardly move
           9         anybody any way.  They can pick up people from Flag
          10         but they can't bring them in because they have to
          11         bring them in there, and they can't do it."
          12              (End of playing of the video tape.)
          13              _______________________________________
          14    BY MR. WEINBERG:
          15         Q    That is somebody from the LMT?
          16         A    Absolutely not.
          17         Q    Who is that?
          18         A    Greg Hagglund.  He lives in Canada.
          19         Q    And he was down here for the picket in December?
          20         A    Looking at that date of that, he was down for the
          21    picket and vigil.  People come from all over the United
          22    States and even Europe for that.  They were doing that long
          23    before the Lisa McPherson Trust ever existed or it was here
          24    in Clearwater.  So, you know, it would be a real bad stretch
          25    to think that, you know, he's working at the trust because
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           1    he's picketing.
           2         Q    Well, is there a particular reason why the trust
           3    had that tape in its film library?
           4         A    Maybe someone videotaped it and gave it to the
           5    trust, Mr. Weinberg.
           6         Q    Well, who was the videotaper for the trust?
           7         A    Mark Bunker.
           8              ______________________________________
           9              (WHEREUPON, the video was played.)
          10              "Remember Lisa McPherson.  Okay, let's go.
          11              (Inaudible.)
          12              "-- is one of our old friends.
          13              "Yes.  Some other friends from Germany, too.
          14              "That is a good one, too.
          15              "Where else would you like --"
          16              (Inaudible.)
          17              (End of playing of the video tape.)
          18              ______________________________________
          19    BY MR. WEINBERG:
          20         Q    Those are all people from the Lisa McPherson
          21    Trust, weren't they?
          22         A    False.
          23         Q    Oh, Miss Caberta was from Germany, your guest over
          24    here?
          25         A    Ms. Caberta was here on vacation.  Mrs. Caberta.
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           1    And if you will recall, you yourself earlier said she's
           2    employed by the German government.  So, you know, she's not
           3    LMT.  She's just like you said, employed by the German
           4    government.
           5         Q    This was an LMT-sponsored picket in front of the
           6    Ft. Harrison Hotel?
           7         A    LMT has never, to my knowledge, sponsored a
           8    picket.
           9         Q    Is there a particular reason why Mr. Merrett was
          10    at that picket?
          11         A    I believe Mr. Merrett was at the picket to make
          12    sure that nothing happened, there were no altercations, no
          13    scuffles, no -- you know, you'll notice this, people, for
          14    the most part, are just silently walking up and down the
          15    street.  They are not screaming at Scientology itself or
          16    yelling at Scientologists; they are exercising their
          17    constitutional right to protest.
          18         Q    Do you think it might be somewhat harassing to
          19    the -- on the doorstep of the mecca of Scientologists with
          20    signs saying "Blood of Lisa McPherson on your hands" and
          21    things like that?
          22         A    You know, I can see where someone could draw that
          23    inference or conclusion.  But the inference and conclusion I
          24    draw is people were exercising their constitutional right.
          25    If it was even a civil crime, they would have been sued out
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           1    of existence.
           2         Q    Do you remember that the Lisa McPherson Trust --
           3    people documented by Lisa McPherson Trust video picketed in
           4    front of the Ft. Harrison Hotel when a Hindu wedding was
           5    going on?  A Hindu wedding?
           6         A    No, I was not there.  I know nothing about it.
           7         Q    As your position as the VP of the Lisa McPherson
           8    Trust, you don't remember that one?
           9         A    Correct.
          10              MR. WEINBERG:  Why don't we show that.
          11              THE WITNESS:  Was I present here?
          12              ______________________________________
          13              (WHEREUPON, the video was played.)
          14              "Well, Jesus, that is one thing Scientology didn't
          15    believe in or any other religion, isn't that right, guys?
          16    Isn't that right?  Isn't that right?  That is all -- let's
          17    let all of the Nazis come out.
          18              "People are trying to have a wedding, sir.
          19              "What is that?
          20              "Hey, this is fine.
          21              "They're just trying to have a wedding.  They are
          22    not --
          23              "Listen, it's not my fault they got married here.
          24              "Come on now.
          25              "This is a public sidewalk, buddy, so don't start
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           1    pushing.
           2              "This is not -- (inaudible).
           3              "This is a public sidewalk.  Let's get out of the
           4    way.  It is still a public sidewalk.  Okay?
           5              "When you get out of Scientology, your luck
           6    will --
           7              (Inaudible.)
           8              "Let's go.  Let's go.
           9              "Let's go.
          10              "Come on."
          11              (End of playing of the video tape.)
          12              ______________________________________
          13    BY MR. WEINBERG:
          14         Q    Why did the LMT put that in its film library?
          15         A    I think that every -- and I'm not sure if this is
          16    not Mr. Mark Bunker's film library that you are referring
          17    to -- but, you know, we're -- we're looking at here your two
          18    star witnesses.  You are showing me videos of your witnesses
          19    that you have used in this hearing to testify for you.  What
          20    are we doing here?
          21         Q    I think you said that this is the most harassed
          22    person you have ever seen.  Does it look like Mr. Minton is
          23    the most harassed person you have ever seen when he's
          24    standing there with a sign with skulls on it in front of the
          25    Ft. Harrison --
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           1              THE COURT:  Don't --
           2              MR. WEINBERG:  I'm sorry.
           3              THE COURT:  -- raise your voice up to this
           4         witness and start approaching him.
           5              MR. WEINBERG:  I'm sorry.
           6              THE COURT:  I won't have it.  And I'm not going
           7         to remind you again.
           8    BY MR. WEINBERG:
           9         Q    With a sign with skulls on it, interrupting a
          10    Hindu wedding?
          11         A    Mr. Weinberg, I agree with you what happened
          12    there -- what happened was extremely inappropriate.  And I
          13    don't agree with it.  And you didn't see me there.
          14         Q    I'll show you one you are at, Mr. Prince.
          15              By the way, before you play that, that tape was
          16    done -- the one we just played was done in -- in September
          17    of 2000.
          18              You were full-time at the Lisa McPherson Trust,
          19    correct?
          20         A    That is possible, yes.
          21         Q    Not possible.  That is correct?
          22         A    I said it's possible.
          23         Q    Why do you say it's possible?  I mean --
          24         A    Because I'm not sure when I made that transition
          25    from -- I'll explain it to you, I'm not trying to be coy
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           1    here, but there came a point in time when my work with
           2    Mr. Dandar involved doing a bunch of depositions of
           3    Scientology staff members or Scientologists or whatever and
           4    we worked together quite a bit then.
           5              But then there came a period of time when it was
           6    time for the medical experts.  Those people are the experts.
           7    He certainly didn't need me there.  So there came a point in
           8    time when I started working at the Lisa McPherson Trust.
           9         Q    In September of 2000 when that took place, you
          10    were on the payroll of the Lisa McPherson Trust, correct?
          11         A    It is possible, yes.
          12              ______________________________________
          13              (WHEREUPON, the video was played.)
          14              "Jesse is -- this is -- Jesse, show him what
          15    you're going to do if they come at you.
          16              "Drop and fall.  That is all.  I'm going to fall
          17    down.
          18              "Hey --
          19              "You know what (inaudible).
          20              "That is a good idea.
          21              "Full resistance, that is our motto.
          22              "How are you going to do it?
          23              "Just carry the sign.
          24              "Oh, my God.
          25              "Kind of like the Three Stooges.
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           1              "The St. Pete Police.
           2              "Yes, I told them I would be there by quarter to
           3    seven.
           4              "Oh, God.
           5              "Let's do this.
           6              "Guys, remember what we all agree with.  We're all
           7    staying together.
           8              "Yes, boss.
           9              (Inaudible.)
          10              "Uh-huh.  Uh-huh.  Okay, well -- Mmm, no."
          11              (End of playing of the video tape.)
          12              ______________________________________
          13    BY MR. WEINBERG:
          14         Q    Now, that is one of your six pickets?
          15         A    Rhetorical.
          16         Q    Excuse me?
          17         A    That is one of the six pickets I have probably
          18    been in.
          19         Q    And in that video we saw Patricia Greenway,
          20    correct, who is in the audience, right?
          21         A    Show it to me again.  I missed that.
          22              THE COURT:  Yes, she was there.
          23              THE WITNESS:  Okay.  I'll take your word.
          24    BY MR. WEINBERG:
          25         Q    Peter Alexander, who testified in this hearing?
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           1              THE COURT:  I don't know if he was there or
           2         not.
           3              MR. WEINBERG:  He was.
           4              THE COURT:  I didn't recognize him, but --
           5    BY MR. WEINBERG:
           6         Q    The gentleman, sort of young guy in the pink or
           7    red shirt, that was Graham Berry, correct?
           8         A    Correct.
           9         Q    The lawyer from LA?
          10         A    Correct.
          11         Q    Now, your sign, "Mafia Cult"?
          12         A    Correct.
          13         Q    And that was --
          14         A    In relationship to the black operations that are
          15    run out of OSA.
          16         Q    And you were picketing, you walked from the LMT --
          17    this was an LMT operation, wasn't it?  That is where you-all
          18    left from, from the LMT?
          19         A    Yes.
          20         Q    And at that point, you were full-time at the LMT?
          21         A    I -- I'll stipulate to that, sure.
          22         Q    Except you were still working for Mr. Dandar, you
          23    were still doing stuff on the Lisa McPherson case, weren't
          24    you?
          25         A    Well, you know, as I said, Mr. Weinberg, there
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           1    came a time when Mr. Dandar was solely doing medical
           2    experts.  There was certainly no need for me to sit there
           3    through that.
           4              MR. WEINBERG:  One second, your Honor.
           5    BY MR. WEINBERG:
           6         Q    Now, you, Mr. Dandar and a number of other people
           7    from the LMT were at the closing when Mr. Minton closed on
           8    the purchase of the building either at the -- at the
           9    beginning -- January 5 of 2000, is that right?
          10         A    I believe that is correct.
          11         Q    And Mr. Dandar was -- and you and Mr. Minton and
          12    Ms. Brooks were very enthusiastic about the LMT and how the
          13    LMT was going to -- to operate.  Correct?
          14         A    Yes.
          15         Q    And Ms. Liebreich was very enthusiastic about the
          16    LMT opening, correct?
          17         A    I don't think Mrs. Liebreich was there.
          18         Q    But do you remember that the first phone call that
          19    was made was made to Ms. Liebreich, and you talked to her,
          20    among other people?
          21         A    I think I remember something about that, yes.
          22         Q    And she was very enthusiastic about that.  Right?
          23         A    She was very happy and proud that the last wishes
          24    of Fannie McPherson were actually taking effect, which was
          25    to expose any deceptive and abusive processes by
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           1    Scientology, you know.
           2              Mr. Minton is -- just wants reform, tired of
           3    people calling, tired of people saying, "Can you please
           4    help."
           5         Q    Your testimony, I believe, was -- and correct me
           6    if I'm wrong -- that you never met with Mr. Dandar for any
           7    purpose -- for any meeting type purpose at the LMT.  Is that
           8    right?
           9         A    Correct.
          10         Q    Now, do you remember at this opening that -- at
          11    this closing where, in essence, the LMT was opening, that
          12    you described -- or someone described what your position and
          13    responsibility was going to be at the LMT?
          14         A    I don't recall it specifically, Mr. Weinberg.
          15         Q    And you deny it was in charge of PR, right?
          16         A    Correct.
          17              MR. WEINBERG:  If you could play that, please.
          18         This is another video from the LMT.
          19              ______________________________________
          20              (WHEREUPON, the video was played.)
          21              "Ken, I'm sorry there's no more chairs.
          22              "It is okay.
          23              "Sign first -- (inaudible).
          24              "You want to sit down?  Here is the -- these
          25         are the -- (inaudible).
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           1              "Did you bring the property insurance papers?
           2              "Of course not.
           3              "You didn't?
           4              (Inaudible.)
           5              "You mean the balance, it's everything you did
           6         fax me yesterday.
           7              (Inaudible).
           8              "The insurance papers are the closing paper for
           9         the mortgage.
          10              "Yeah.  Right.  Right.
          11              (Inaudible.)
          12              "That is okay.  That is okay.
          13              "It's just that we don't have the check for
          14         him -- or, we have the check but -- (inaudible).
          15              "How are we going to do it?  How are you going
          16         to do it?
          17              (Inaudible.)
          18              "No, I'll just tell you to send a check and how
          19         much it is.  (Inaudible.)  It's a binder.
          20              (Inaudible.)
          21              "If Scott has a fax machine I can fax it to
          22         him.
          23              "Hang on one second.  Okay?
          24              "Yes.
          25              "Okay."
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           1              ______________________________________
           2    BY MR. WEINBERG:
           3         Q    Is that Tom Tobin from the St. Pete Times?
           4         A    I believe it is.
           5              ______________________________________
           6              "This is Steve Mitchell.  This is Jesse Prince.
           7              "Nice to meet you, Jesse.
           8              "Nice to meet you.
           9              "He's an expert on Scientology in the Lisa
          10    McPherson case.  He's going to be also working at the trust.
          11              "Oh.  Terrific.
          12              (Inaudible.)
          13              "So he has an idea of what we're dealing with.
          14    Big time, right?
          15              "Big time, Bobby.  This is too cool.
          16              "Jesse, what are you going to do with this
          17    organization?
          18              "Make it as successful as possible.
          19              "I mean, what's your job or what -- do you have
          20    functions or duties or --
          21              "I'm on the board of directors.  And I'm going to
          22    just, you know, be here with the organization, get it
          23    through its initial phase of establishing itself, and run
          24    around and do public relations.
          25              "Oh, really.
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           1              "Yes.
           2              "He's also an expert on the Lisa McPherson case so
           3    he's going to be spending a lot of time with Ken Dandar so
           4    he'll be --"
           5              (Inaudible.)
           6              "He's been working, you know, intimately with Ken
           7    on this case for a long time.
           8              "Oh.
           9              (Inaudible.)
          10              "You mean, does he own the building now?
          11              "Thank you very much.  Thank you.  Scott.
          12              "Thank you.
          13              "Thank you very much.  I can't tell you how much I
          14    appreciate this.
          15              "I wish you the best.  I hope you do well with
          16    this.
          17              "Thank you.
          18              "Scott's been under a lot of pressure, I'm sure.
          19              "Congratulations.
          20              "Thank you.
          21              "Jesse.
          22              "Hey, Ken?
          23              "Hey, Ken?
          24              "So anybody want to open that champagne?
          25              (Inaudible.)
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           1              "Ken, your comments?
           2              "Well, I think this is a good day for downtown
           3    Clearwater.
           4              "Hi, Mike.  How is it going?
           5              "Happy New Year.
           6              "We just closed on the building.
           7              "Okay.  Call me.
           8              "I have a binder in my office."
           9              (End of playing of the video tape.)
          10              ______________________________________
          11              MR. DANDAR:  Could we have a stipulation that
          12         was edited by the defense?
          13              MR. WEINBERG:  I mean --
          14              THE COURT:  I don't know if it was or not.
          15              MR. WEINBERG:  I mean, Mr. Bunker edited a lot
          16         of these tapes before he ever gave them to us.  I
          17         mean --
          18              MR. DANDAR:  Well, whatever.
          19              MR. WEINBERG:  I mean --
          20              THE COURT:  All I can say, Counselor, it is
          21         available for you to get a copy of, so --
          22              MR. DANDAR:  I know.
          23    BY MR. WEINBERG:
          24         Q    Now, what was the Lisa McPherson trial consultant
          25    and the Lisa McPherson case lawyer doing at the closing of
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           1    the LMT building?
           2         A    It looks like they were partaking in the
           3    festivities, to me.
           4         Q    It does to me, too, Mr. Prince.
           5         A    Yeah.
           6         Q    Now, when Ms. Brooks said that you were going to
           7    be doing public relations, was your first job to get Tom
           8    Tobin from the St. Pete Times there?
           9         A    You know, I think that is a leap in logic.  And I
          10    think the person that actually said doing public relations
          11    stuff was me.  I don't think it was Ms. Brooks.
          12         Q    All right, I stand corrected.  When you said you
          13    were doing public relations, what did you mean?
          14         A    I think that that was just an offhand comment.
          15    And I didn't even know what I meant.  Maybe I had some
          16    intention on doing something public relations-wise.
          17              But what factually ended up happening is once the
          18    door opened, the phones started ringing.  And as I
          19    mentioned, you know, getting through the initial
          20    establishment part, to find out exactly what our role is
          21    going to be, it simply turned into servicing current and
          22    ex-Scientology members.
          23         Q    The way you got your message out was to carry
          24    signs and picket in front of the Church of Scientology?
          25         A    That was the one thing that was done.
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           1         Q    And -- but at this time when this started in
           2    January 5 of 2000, you were in charge of public relations
           3    but you were being paid by Mr. Dandar to be a so-called
           4    expert in the Lisa McPherson case.  Correct?
           5         A    That is totally incorrect.  There was no public
           6    relations.  I was not doing public relations, orchestrating
           7    public relations, media contact.
           8              Mr. Weinberg, if you have shown anything with the
           9    indiscretion I have used, public relations is not anything
          10    that I would even pretend to be versed in, so, you know,
          11    let's move on.
          12              THE COURT:  I'm going to tolerate about one
          13         more of these, then I can't stand any more for the
          14         day.  I still do not know why we're playing all of
          15         these, but --
          16              MR. WEINBERG:  I can explain.
          17              THE COURT:  I'll let you do that in closing
          18         argument, but I can only stand one more today, so
          19         play it and --
          20              MR. WEINBERG:  I'll play one more and it will
          21         be this one.
          22              THE COURT:  All right.
          23              MR. WEINBERG:  December 2, picket across from
          24         the Ft. Harrison.
          25              I want you to look for Mr. Dandar here.  All
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           1         right?
           2              THE WITNESS:  Okay.  All right.
           3              THE COURT:  What is the date again, Counselor?
           4              MR. WEINBERG:  December 2, 2000.
           5              THE WITNESS:  Was I at this picket?
           6              (WHEREUPON, the video was played.  No audio
           7         available.)
           8    BY MR. WEINBERG:
           9         Q    You recognize the person with the sign was Frank
          10    Oliver?
          11         A    Yes.
          12         Q    You recognize Teresa Summers?  She testified in
          13    this case.
          14         A    Yes.
          15         Q    You recognize yourself?
          16         A    Yes.
          17         Q    You recognize Mr. Merrett?
          18         A    Yes.
          19         Q    You recognize Mr. Minton?
          20         A    Yes.
          21         Q    You recognize Mr. Dandar.  Correct?
          22         A    Yes.
          23         Q    And that was in front of the Ft. Harrison during a
          24    picket, wasn't it?
          25              THE COURT:  I didn't see any signs except
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           1         one -- I did not see what I would classify as a
           2         picket.
           3         A    There was no picket.  And I remember this
           4    incident, if you'll let me explain it to you.
           5              Bob Minton had come into town and Ken needed to
           6    talk to him or see him for something.  Mr. Dandar simply
           7    stopped by.  Mr. Dandar was not a part of any picket or
           8    doing anything.  He simply knew where Mr. Minton was going
           9    to be, he came there, spoke with him and left.
          10    BY MR. WEINBERG:
          11         Q    So what were you-all doing there?
          12              THE COURT:  I saw folks across the street,
          13         Counsel, that had signs, then somebody said hi, went
          14         across the street.  That is where Mr. Dandar was.
          15         The sign was down.  The only one person that had it,
          16         they were talking, then somebody put a sign up and
          17         went off like there was something else going on
          18         someplace else.
          19              I don't think it would be fair to classify what
          20         Mr. Dandar was in was a picket.  I could not tell
          21         they were in front of any hotel, either.
          22    BY MR. WEINBERG:
          23         Q    Well, you recognize that was across from the Ft.
          24    Harrison?
          25         A    No, I do not.
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           1              THE COURT:  I don't know where it was because I
           2         couldn't tell.  It looked like a street corner.  It
           3         might have been.  I don't recognize that.
           4              MR. DANDAR:  I can tell you, Judge.  It was
           5         catty-corner across the street from the Ft.
           6         Harrison.  These people with signs who were across
           7         the street from me, across the street from the Ft.
           8         Harrison, were standing in front of the new Super
           9         Power building.  But I wasn't part of any picket.
          10         That is right.
          11    BY MR. WEINBERG:
          12         Q    Now, was Mr. Merrett part of the picket?
          13         A    No, he was not.
          14         Q    Were you?
          15         A    No, I was not.
          16         Q    So you had been -- so all these LMT people were
          17    sort of off to the side, and there were other LMT people
          18    that were holding signs?
          19         A    You know, again, Counselor, I'm not trying to be
          20    difficult here.  You are showing snippets and you are
          21    drawing conclusions.  The conclusion that I see from this
          22    snippet is we are simply standing there having a
          23    conversation.  No one but no one is picketing.
          24              THE COURT:  Looks like there was getting ready
          25         to be a picket.  There were people with signs, but
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           1         when they saw Dandar, it looks like somebody waved,
           2         walked across the street, the guy that had the sign,
           3         whoever that was, the one, put his sign down.  When
           4         he picked up the sign, he went walking off to where
           5         I would presume a picket was going on.  But those
           6         other folks were across the street that must have
           7         been going for a picket, I'm guessing.
           8              MR. WEINBERG:  You said that was the last one
           9         you wanted to see.
          10              THE COURT:  That is absolutely the last one I
          11         want to see.
          12              It is 5 o'clock.  We're done for the day.
          13         We'll see you at 9~o'clock tomorrow.
          14              MR. WEINBERG:  Thank you.  Have a good night.
          15              (WHEREUPON, Court stands in recess at 5
          16         o'clock.)
          17              _____________________________________
          18
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                                                                        720
           1                      REPORTER'S CERTIFICATE
           2
           3    STATE OF FLORIDA         )
           4    COUNTY OF PINELLAS       )
           5              I, LYNNE J. IDE, Registered Merit Reporter,
                certify that I was authorized to and did stenographically
           6    report the proceedings herein, and that the transcript is
                a true and complete record of my stenographic notes.
           7
                          I further certify that I am not a relative,
           8    employee, attorney or counsel of any of the parties, nor
                am I a relative or employee of any of the parties'
           9    attorney or counsel connected with the action, nor am I
                financially interested in the action.
          10
          11              DATED this 9th day of July, 2002.
          12
          13
          14                              ______________________________
                                              LYNNE J. IDE, RMR
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