CASE NO. 00-5682-CI-11

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


                vs.                                     VOLUME 8
                                                        TESTIMONY OF
                CHURCH OF SCIENTOLOGY FLAG              JESSE PRINCE
                and DAVID HOUGHTON, D.D.S.,



                PROCEEDINGS:        Defendants' Omnibus Motion for
                                    Terminating Sanctions and Other Relief

                DATE:               July 11, 2002.  Morning Session

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

                BEFORE:             Honorable Susan F. Schaeffer
                                    Circuit Judge

                REPORTED BY:        Debra S. Turner
                                    Deputy Official Court Reporter
                                    Sixth Judicial Circuit of Florida

                                  KANABAY COURT REPORTERS
                        TAMPA AIRPORT MARRIOTT HOTEL (813) 224-9500
                        ST. PETERSBURG - CLEARWATER (727) 821-3320


                                                   Page 1008

            1   APPEARANCES:

            2   MR. KENNAN G. DANDAR
                DANDAR & DANDAR
            3   5340 West Kennedy Blvd., Suite 201
                Tampa, FL 33602
            4   Attorney for Plaintiff

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

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

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










                                  KANABAY COURT REPORTERS

                                                   Page 1009

            1                  MR. DANDAR:  Judge, I've been bringing these

            2        things to court almost every day, not doing anything

            3        about it.  I'd like to file the signed declarations of

            4        Stacy Brooks and replace the exhibits that weren't

            5        signed, when she complained about it.  And for the

            6        record, let me tell you what exhibit numbers they are.

            7                  THE COURT:  All right.

            8                  MR. DANDAR:  21, 23, 24, 25, and 27.

            9                  THE COURT:  All right.  Madam Clerk, I think

           10        the best thing to do, rather than -- I don't know,

           11        should we just file them now all together?  Or should

           12        we just replace that which we have with the signed --

           13                  MR. DANDAR:  Replace them.

           14                  THE COURT:  Okay.  That seems appropriate.

           15                  Any problem with that?

           16                  MR. WEINBERG:  Are you going to --

           17                  No, there's no problem.

           18                  Do you have copies you can show us?

           19                  MR. DANDAR:  I actually have copies for you.

           20                  MR. WEINBERG:  Okay.  We just want to take a

           21        look at them, make sure they're the right ones.

           22                  THE COURT:  Well, let's go ahead and take

           23        them out.

           24                  For now, Madam Clerk, just put them aside

           25        until you all have a chance to look at them.  So we'll

                                  KANABAY COURT REPORTERS

                                                   Page 1010

            1        go ahead and do that.  I assume they're the same ones;

            2        you checked them.

            3                  Speaking of that, when I was looking at this

            4        withheld material, one of the things, the draft --

            5        what appears to be the draft affidavit of Stacy

            6        Brooks, I actually think it was filed and I actually

            7        think it was admitted into evidence in this case.  So

            8        let me see those affidavits.

            9                  MR. DANDAR:  Here's one, No. 21.

           10                  THE COURT:  They're great big ones,

           11        86 pages.

           12                  MR. DANDAR:  Oh, okay.

           13                  THE COURT:  And it was filed, not in

           14        Wollersheim, but in a case that had to do with a

           15        Dr. Geertz.

           16                  MR. WEINBERG:  That was like 1993 or

           17        something like that --

           18                  THE COURT:  Right.

           19                  MR. WEINBERG:  -- '94.

           20                  MR. DANDAR:  This is an 82-pager.

           21                  THE COURT:  I bet that's it.  Let me see it.

           22                  MR. DANDAR:  Exhibit 23 of the plaintiff.

           23                  THE COURT:  That's it.  So I don't have to

           24        read it.  I already read that.  I kept thinking, "This

           25        is familiar."

                                  KANABAY COURT REPORTERS

                                                   Page 1011

            1                  I've read through two of the three packets

            2        of information.  Thus far it's all privileged,

            3        attorneys' bills, that kind of thing, a couple

            4        attorney e-mails, attorney-client.

            5                  I have not gone through the Patricia

            6        Greenway packet yet.  That's for tonight.

            7                  MR. FUGATE:  Here's the transcripts --

            8                  THE COURT:  Speaking of that, what do we

            9        want to do with those?  It seems -- like I said, the

           10        first packet I looked at was two e-mails, one from --

           11        it appeared to be Mr. Jonas to Mr. Minton; one from

           12        Mr. Merrett to Mr. Minton and Ms. Brooks, or LMT.

           13        Nothing really related to this proceeding.  They were,

           14        as I said, from attorney to a client.  So they

           15        wouldn't be admissible or they wouldn't be outside the

           16        privilege.

           17                  The second packet that I looked at, the

           18        first part of it, except for this draft -- which was

           19        exactly the same; I mean, it was a final draft.  It

           20        was just on yellow paper instead of white paper.  It

           21        looked exactly like that.  But the rest of it was all

           22        attorneys' bills and -- you know, from deVlaming and

           23        Howie and on and on.

           24                  So I don't even see any real need to seal

           25        that and put it in the court file.  It seems to me

                                  KANABAY COURT REPORTERS

                                                   Page 1012

            1        that -- it looked like it was their copies -- that I

            2        ought to send it back to the lawyer.

            3                  MR. WEINBERG:  Send them back to the client,

            4        I guess.  I mean, it's the client's.

            5                  THE COURT:  Yes.  I gathered that both of

            6        those things were things that Mr. McGowan had -- there

            7        was somebody's name on it.  I couldn't figure it out,

            8        read the signature.

            9                  But either give them back to Mr. Keane and

           10        tell him to send them back or give them back to the

           11        client.

           12                  MR. WEINBERG:  I mean, it's the client's

           13        materials and it's their privilege.  I'd give them

           14        back to whoever is -- in this case, it's the LMT.

           15                  THE COURT:  It's the LMT, so I think --

           16        that's why I think I would give it back to

           17        Mr. McGowan.

           18                  MR. WEINBERG:  McGowan, right.

           19                  THE COURT:  And Mr. McGowan can give it back

           20        to the client --

           21                  MR. WEINBERG:  Right.

           22                  THE COURT:  -- or keep it with the LMT

           23        records, if he's been asked to, or whatever he's been

           24        asked to.

           25                  MR. WEINBERG:  He asserted the privilege,

                                  KANABAY COURT REPORTERS

                                                   Page 1013

            1        though.  He's the one --

            2                  THE COURT:  Yes.

            3                  MR. WEINBERG:  -- that asserted the

            4        privilege.  Give it back to Mr. McGowan.

            5                  THE COURT:  As I said, that gives me one

            6        more packet.  Now, it's not very big.  It looks like

            7        it's maybe not more than ten documents.  So I just was

            8        too tired last night.  I couldn't -- I couldn't stay

            9        awake to read them anymore.

           10                  MR. WEINBERG:  I was having trouble staying

           11        awake --

           12                  THE COURT:  Yes.

           13                  MR. WEINBERG:  -- last night too.

           14                  THE COURT:  So I'll do that tonight.  If

           15        there's any that's controversial, I'll seal them.  If

           16        there's any I want to distribute, I'll make copies for

           17        everybody.  And then I'll tell you tomorrow what they

           18        are so we can decide what to do with those.

           19                  MR. FUGATE:  This is the daily copy for the

           20        notebook, your Honor.

           21                  THE COURT:  Okay.  Wonderful.  I have not

           22        looked to see where my Volumes I and II are, but I'll

           23        try to get to that.

           24                  MR. FUGATE:  That is what Volume I and II

           25        is.  It's all of the hearing --

                                  KANABAY COURT REPORTERS

                                                   Page 1014

            1                  THE COURT:  Okay.

            2                  MR. FUGATE:  -- or part of it,

            3        chronologically.

            4                  THE COURT:  Okay.  Let's see.  We were going

            5        to do that hearing on the brief, but it was at 1:30,

            6        wasn't it?

            7                  MR. LIEBERMAN:  That's what you said, yes,

            8        your Honor.

            9                  THE COURT:  Okay.  Now, if he doesn't appear

           10        and nobody appears for him, I may delay it because,

           11        frankly, I just haven't been able to get to that, to

           12        look at it.  Probably I'll hear you, and we can take a

           13        look after the fact or something like that.

           14                  MR. DANDAR:  Judge, Mr. Henson e-mailed me

           15        back.  He did not say whether or not he's coming or

           16        has a lawyer.  But he wanted your fax number to fax

           17        you a reply of some kind.  Do you want me to give him

           18        the fax number?

           19                  THE COURT:  Sure.  I don't know what it is.

           20                  MR. DANDAR:  I don't either.

           21                  THE COURT:  Sue can tell you what it is.

           22                  MR. DANDAR:  All right.  I'll ask her.

           23                  THE COURT:  But whatever -- I don't know

           24        what he's going to reply -- oh, I guess maybe to the

           25        filing of the pleading.  Is that it?

                                  KANABAY COURT REPORTERS

                                                   Page 1015

            1                  MR. DANDAR:  It could be.  I don't know.

            2                  THE COURT:  Okay.  If he files a reply, I

            3        probably won't have a chance to read it by 1:30.  But

            4        if he doesn't show up, then as far as I'm concerned,

            5        we can schedule it some other time, without further

            6        notice, if I don't have time to read his reply before

            7        1:30.

            8                  Go ahead and call him on the break this

            9        morning.

           10                  MR. DANDAR:  All right.

           11                  THE COURT:  Tell him he can fax it to me.

           12        And tell him that, that if I don't have a chance to

           13        read it before 1:30 -- I mean, he needs to get it --

           14        anything he wants to get, he needs to get it here.

           15        But if I have to schedule another hearing, I won't

           16        notice him because it will be the same hearing.

           17                  MR. DANDAR:  Right.

           18                  THE COURT:  Okay.  Anything else this

           19        morning?

           20                  MR. WEINBERG:  Well, there was one thing.

           21        There was a request to produce that went out that we

           22        got a response to yesterday that had to do with

           23        requesting from the plaintiff information concerning

           24        the submission of the disks from this proceeding --

           25                  THE COURT:  The disks?

                                  KANABAY COURT REPORTERS

                                                   Page 1016

            1                  MR. WEINBERG:  Well, the ASCII disks of the

            2        transcripts.  They're all on the Internet.  They get

            3        them on the Internet daily.  So that -- and we're

            4        not -- there's only two people that are getting ASCII

            5        disks:  There's us and there's the plaintiff.

            6                  So we asked the plaintiff -- we made a

            7        request for production to Mr. Dandar for that.

            8                  THE COURT:  For what?

            9                  MR. WEINBERG:  For all notes, memorandum --

           10        I'm sorry -- all letters, e-mails, memorandum, or

           11        other communications of any type or relevance.

           12                  THE COURT:  My court reporter couldn't

           13        probably keep up.

           14                  MR. WEINBERG:  I'm sorry.

           15                  "A list of all persons, organizations,

           16        groups, entities, or Internet sites that you or your

           17        office employs or consultants provide with ASCII disk

           18        copies of daily transcripts of the hearings."

           19                  "Objection, work product.  Otherwise, none."

           20                  Well, they're appearing on the Internet

           21        every day, this proceeding.  Which is supposedly --

           22        they're supposed to be sequestered witnesses.  The

           23        witnesses are supposed to be sequestered in this case.

           24        But apparently someone -- and it's not us -- is

           25        providing it to the Internet.  And I don't think

                                  KANABAY COURT REPORTERS

                                                   Page 1017

            1        that's -- I think it's inappropriate.  And we asked,

            2        and I don't think the objection is work product.  If

            3        that's being done, it ought -- it ought to be

            4        disclosed.  Because that is, I believe, a

            5        circumvention of what -- of the sequestration.

            6                  THE COURT:  Well, the only thing I can tell

            7        you, Counselor, is I'm not going to, short a motion,

            8        get involved with some suppression of any information

            9        going out on the Internet that is otherwise public

           10        record.  And I --

           11                  MR. WEINBERG:  We weren't seeking to

           12        suppress it.  We were seeking to discover from the

           13        plaintiff if in fact that's what the plaintiff or

           14        someone on behalf of the plaintiff has been doing.

           15        And if that's the case, I think it's appropriate to

           16        raise that issue -- not to suppress because, you know,

           17        if somebody wants to do it, they can.  But it

           18        certainly bears on what is taking -- what has

           19        transpired in this hearing, I think.  I do.  Because,

           20        I mean, they're --

           21                  THE COURT:  I'm not going to require him to

           22        respond to that.

           23                  MR. WEINBERG:  Well, he already responded.

           24                  THE COURT:  Okay.  In other words, I mean, I

           25        think the Internet is out there.  You know probably

                                  KANABAY COURT REPORTERS

                                                   Page 1018

            1        where it's going.  You know how to get to those sites.

            2        I don't, or I'd look myself.  Is it appropriate?  I

            3        don't know.  I'd have to have a motion and hear

            4        argument on it.

            5                  MR. WEINBERG:  Well, it wouldn't be

            6        appropriate for a sequestered witness to be reading

            7        daily transcripts.

            8                  THE COURT:  It should not be being read by

            9        witnesses.  But I assume you can ask that.  Frankly,

           10        once a witness testifies, I don't care if they read

           11        it.

           12                  MR. WEINBERG:  No, I mean prospective --

           13                  THE COURT:  Right.

           14                  MR. WEINBERG:  -- witnesses.

           15                  THE COURT:  And what I would do if I were

           16        you is ask the witnesses if they have read it.  The --

           17        do I think people should be putting this out on the

           18        Internet?  Probably not.

           19                  MR. DANDAR:  I can assure the Court, neither

           20        I nor anyone under my control has put this out on the

           21        Internet for public consumption.

           22                  THE COURT:  How did it get there?

           23                  MR. DANDAR:  That is a good question.  And

           24        Mr. Weinberg said the Church of Scientology hasn't

           25        done that.  That's his statement.  Well, I haven't

                                  KANABAY COURT REPORTERS

                                                   Page 1019

            1        done it.  I have not published it to the public at

            2        all.

            3                  THE COURT:  Okay.  Well . . .

            4                  I just don't want to go there, to be saying

            5        not publishing it.

            6                  MR. WEINBERG:  I didn't hear him say

            7        Ms. Greenway isn't doing it, or somebody has gotten

            8        copies, his consultants.  I can tell you nobody from

            9        our team of people in the Church of Scientology or my

           10        law office --

           11                  THE COURT:  It's a pretty good hearing,

           12        isn't it?

           13                  MR. WEINBERG:  It is pretty good.

           14                  THE COURT:  Let the public see what's going

           15        on.

           16                  MR. WEINBERG:  I don't mind the public --

           17                  THE COURT:  The reason I don't mind, I'm

           18        pretty happy that we're doing a pretty fair hearing

           19        here.  If the public -- I don't like a witness reading

           20        it.

           21                  MR. WEINBERG:  That's all I'm --

           22                  THE COURT:  Right.  Which we can ask that.

           23                  MR. WEINBERG:  Judge, I'm -- look, I'm very

           24        happy for people to read, you know, what we do, how we

           25        ask questions, and stuff like that.  That's not my

                                  KANABAY COURT REPORTERS

                                                   Page 1020

            1        problem.

            2                  THE COURT:  Okay.

            3                  MR. WEINBERG:  I'm not concerned about the

            4        public seeing this.  I'm concerned about sequestered

            5        witnesses reading it.

            6                  THE COURT:  And as I said, we can ask that

            7        question --

            8                  MR. WEINBERG:  All right.  I will.

            9                  THE COURT:  Both sides can ask the witnesses

           10        if they have been keeping up with this, and I'll have

           11        to decide what I'm going to do about it.

           12                  Okay.  Mr. Prince.

           13                  (Mr. Prince took the witness stand.)

           14                  THE COURT:  Good morning.

           15                  THE WITNESS:  Good morning.

           16                  THE COURT:  Okay.  Day 31.  This is the

           17        11th, right?

           18                  MR. WEINBERG:  Of the trial?

           19                  THE COURT:  7/11.

           20                  MR. WEINBERG:  7/11.

           21                  THE COURT:  All right.  You may continue,

           22        Counselor.


           24   BY MR. WEINBERG:

           25        Q    Now, in the vein that we just talked, the Judge

                                  KANABAY COURT REPORTERS

                                                   Page 1021

            1   and I, have -- since you have been back on the stand this

            2   week, have you met with any of the witnesses or prospective

            3   witnesses in this case?

            4                  THE COURT:  Do you know who the

            5        prospective -- does he know who they are?

            6   BY MR. WEINBERG:

            7        Q    I think -- well, the next witness is Frank

            8   Oliver, and then there's Mr. Dandar.  There's some secret

            9   person that Mr. Dandar hasn't told us about -- maybe he's

           10   told you -- and the prior witnesses were Peter Alexander,

           11   what, Teresa Summers, Vaughn Young, Stacy Young, Bob

           12   Minton, other people -- Brian Haney.  Have you met with any

           13   of those people?

           14        A    Not anything for the purposes of -- that's been

           15   in relationship to this trial.  I mean, I was here the day

           16   that Mr. Haney was here, and we had lunch when he was

           17   testifying.  I think I was waiting outside the courtroom or

           18   something.

           19                  THE COURT:  The real question is, Have you

           20        discussed with them their testimony or yours?

           21                  THE WITNESS:  Oh, no.

           22   BY MR. WEINBERG:

           23        Q    Have you discussed, since you've been back on the

           24   stand, your testimony with Mr. Dandar?

           25        A    No.

                                  KANABAY COURT REPORTERS

                                                   Page 1022

            1        Q    Or Mr. Lirot?  I'm sorry.  I had trouble with his

            2   name?

            3        A    No, Mr. Weinberg, I have not.

            4        Q    Or Ms. Greenway?

            5        A    No, Mr. Weinberg, I have not.

            6        Q    Okay.

            7        A    I followed the court instruction in that regard.

            8        Q    And have you had an opportunity to visit the --

            9   the --

           10                  THE COURT:  Unless Ms. Greenway is a

           11        witness, she could technically -- technically I

           12        suppose have chatted with her.  If people under the

           13        rule --

           14                  First of all, he's testified he ought not to

           15        be discussing his testimony; the Court instructed him

           16        so.

           17   BY MR. WEINBERG:

           18        Q    Let me ask you this.  I mean, have you eaten -- I

           19   mean, have you visited with, you know, Ms. Greenway or

           20   Mr. Oliver or anybody like that?

           21        A    Yes.

           22        Q    Okay.  Because they're friends?

           23        A    Correct.

           24        Q    When's the last time you saw Mr. Oliver?

           25        A    Last night.

                                  KANABAY COURT REPORTERS

                                                   Page 1023

            1        Q    What were you doing with him last night?

            2        A    We had dinner.  I invited him to a barbecue.

            3        Q    Did you know that he was going to be

            4   testifying --

            5        A    Yes.

            6        Q    -- after you?

            7        A    Yes.

            8        Q    And where was the barbecue?

            9        A    My house.

           10        Q    And who else was there?

           11        A    Mr. Lirot, Mrs. Greenway, my fiance.

           12                  THE COURT:  It -- really and truly, this is

           13        not your business.  What is your business is

           14        whether --

           15                  MR. WEINBERG:  I was going to ask one last

           16        question.

           17   BY MR. WEINBERG:

           18        Q    And you all didn't talk about the case?

           19                  THE COURT:  That isn't the question either.

           20        It's whether he discussed anything about his

           21        testimony.  I mean, they can talk about the trial.

           22        They can say -- we're all crazy to think that when

           23        most people get together, they don't say, "What do you

           24        think?  Is the case going to be ready for trial?"  But

           25        the question is what's going on here.

                                  KANABAY COURT REPORTERS

                                                   Page 1024

            1   BY MR. WEINBERG:

            2        Q    Did you talk at all about your testimony or

            3   Mr. Oliver's testimony?

            4        A    No.  I followed the Court's instruction in that

            5   regard.

            6        Q    Now, I touched on this a couple of days ago, but

            7   I want to go back for just a minute and see if we can focus

            8   more on the dates.  After you left the Church of

            9   Scientology at the end of October, beginning of November of

           10   1992, there came a time when, in Minneapolis, you became

           11   employed by a company called G & B.  Is that right?

           12        A    Correct.

           13        Q    And that was a company -- is a company that is

           14   run by a woman named Dana Hanson.  Is that right?

           15        A    Correct.

           16        Q    And she is a public member of Scientology?

           17        A    To my knowledge at the time, yes.

           18        Q    All right.  And you'd started working for her in

           19   March of 1994, thereabouts, correct?

           20        A    I'd say that's a fair estimation of when I

           21   started working for her.

           22        Q    And at first your then-wife had been referred to

           23   her to work, right?  Is that how it started?

           24        A    I believe, yes.  I believe you're correct in

           25   that.

                                  KANABAY COURT REPORTERS

                                                   Page 1025

            1        Q    And the reference came from a staff member in the

            2   Minneapolis Org?

            3        A    I'm not sure where the reference came from.

            4        Q    In any event, you began to work for this company,

            5   right?

            6        A    Correct.

            7        Q    And you stayed at the company until the fall of

            8   1995, when you were fired, right?

            9        A    Incorrect.  I was never fired from that company.

           10        Q    You left the company in the fall of 1995?

           11        A    Correct.

           12        Q    Now, during this period of time, Ms. Hanson was

           13   kind enough, for part of the time, to let you stay in her

           14   house.  Right?

           15                  MR. DANDAR:  Objection to relevancy.

           16                  THE COURT:  Yes.  Sustained.

           17   BY MR. WEINBERG:

           18        Q    Well, during the time that you were employed by

           19   Ms. Hanson -- oh, by the way, this company was run pursuant

           20   to Hubbard technology, correct?

           21        A    Not per se, but she wanted it to.  She wanted me

           22   to run it according to Hubbard technology.

           23        Q    And --

           24        A    It hadn't been like that before.

           25        Q    And briefly, that means what?

                                  KANABAY COURT REPORTERS

                                                   Page 1026

            1        A    Getting people to disclose intimate details about

            2   themselves because this was, you know, a Scientology belief

            3   that, you know, if you tell intimate details about yourself

            4   or things that you wouldn't necessarily want made public,

            5   then it'll somehow make you feel better and increase your

            6   production.

            7        Q    And --

            8        A    That's one thing.  Another part was to sit people

            9   down and have them study the writings of Mrs. Hanson

           10   concerning how the company should operate and make sure

           11   that they understood all the words that she had written.

           12   And also, she wanted me to do like a class, a classroom for

           13   doing the TRs, the training routines that I mentioned

           14   earlier in my testimony that's part of Scientology

           15   training --

           16        Q    Okay.

           17        A    -- that kind of thing.

           18        Q    And the idea was the company would run more

           19   efficiently, correct?

           20        A    Correct.

           21        Q    Okay.  Now, during the course of your year and a

           22   half or so with the company, there came a time when you

           23   admitted to Ms. Hanson that you had engaged in extensive

           24   unethical behavior, in violation of moral codes that were

           25   adhered to by Scientologists pursuant to this Hubbard

                                  KANABAY COURT REPORTERS

                                                   Page 1027

            1   technology, correct?

            2                  MR. DANDAR:  Objection.  This is nothing but

            3        to try to embarrass and denigrate Mr. Prince --

            4                  THE COURT:  What's the point of this?

            5                  MR. WEINBERG:  The point is that Mr. Prince

            6        said on direct that he couldn't work because of the

            7        Church of Scientology, that he lost his job as a

            8        result of the Church of Scientology.  That's what he

            9        said.

           10                  THE COURT:  That has nothing to do with this

           11        hearing.  The objection is sustained.

           12   BY MR. WEINBERG:

           13        Q    What was the reason that you left in October of

           14   '95?

           15                  MR. DANDAR:  Same objection.

           16                  THE COURT:  I'll allow that.

           17        A    I left because I didn't want to practice -- I

           18   didn't want to do that -- do the things, the Scientology

           19   things, in the company.  I just wanted to be normal, just

           20   do what a company does, instead of adding a Scientology

           21   slant to it.

           22   BY MR. WEINBERG:

           23        Q    All right.  So the Church, no staff member, had

           24   anything to do with you being terminated from your job.

           25   You just --

                                  KANABAY COURT REPORTERS

                                                   Page 1028

            1        A    I think I mentioned I was not terminated from my

            2   job, Mr. Weinberg.

            3        Q    When you terminated from your job, no staff

            4   member had anything to do with it.

            5        A    I couldn't hear you.  There was noise going on.

            6        Q    I said no staff member in any Church of

            7   Scientology had anything to do with you leaving your job.

            8   Is that right?

            9        A    No.  That's categorically false.  Mr. Sutter from

           10   the Religious Technology Center, after I would not do the

           11   Scientological things in that company, together with

           12   Ms. Hanson --

           13                  THE COURT:  This is just not relevant.

           14                  MR. WEINBERG:  Okay.  Well, I mean, a lot of

           15        that answer --

           16                  THE COURT:  It is not relevant to this

           17        proceeding, so you're not going to go into why he left

           18        the job.  It just doesn't matter.

           19                  MR. WEINBERG:  Okay.

           20   BY MR. WEINBERG:

           21        Q    Now, you said yesterday that you had -- you

           22   accused the Church yesterday of having made you sign

           23   undated resignations, resignation letters, which were then

           24   dated on the date that you were busted from the RTC.

           25   Correct?

                                  KANABAY COURT REPORTERS

                                                   Page 1029

            1        A    Correct.

            2                  MR. WEINBERG:  Now, let me show you --

            3                  Do we have the resignation letters?  Are

            4        they in evidence?

            5                  MR. DANDAR:  While they're looking for that,

            6        Judge, did you say this is Day 31?

            7                  THE COURT:  If what Mr. Weinberg said

            8        yesterday, that that was Day 30, then this would be

            9        Day 31.  I couldn't keep up with it.

           10                  MR. WEINBERG:  May I approach the clerk?

           11                  THE COURT:  You may.

           12                  MR. WEINBERG:  This is 242 (handing), your

           13        Honor.

           14   BY MR. WEINBERG:

           15        Q    I've showed you what we've marked as 242 --

           16        A    Yes.

           17        Q    -- Defendant's 242.  Can you look at those and

           18   tell me if those are copies of the three resignation

           19   letters which you signed on March 3rd, 1987?

           20        A    Yes, they are.

           21        Q    Now, you are familiar, are you not, with a dot

           22   matrix printer?  Do you know what that is?  Do you remember

           23   the printers back 13 or 14 years ago?

           24        A    Yes, I believe I know what you're talking about.

           25        Q    Right.  And this letter -- you can tell that

                                  KANABAY COURT REPORTERS

                                                   Page 1030

            1   these letters were typed on dot matrix printers.  They were

            2   printed out on dot matrix printers.  You can even see on

            3   the side, the column, some of the holes?  Do you see that?

            4   They line up exactly on the three letters, right?

            5        A    Okay.

            6        Q    And it's impossible to have typed up a letter on

            7   a dot matrix printer years before and then run it back

            8   through and put a date on it years later.  That's

            9   impossible, isn't it?

           10                  MR. DANDAR:  Objection.  Outside of his

           11        expertise.

           12                  THE COURT:  Do you know the answer to that?

           13                  THE WITNESS:  No.  But I know the answer to

           14        why these documents have this date on here.

           15                  THE COURT:  Okay.  If he can't answer that

           16        question, he can't answer it.

           17                  MR. WEINBERG:  I move these into evidence,

           18        your Honor.

           19                  THE COURT:  All right.

           20                  THE WITNESS:  Oh, can I have this?

           21                  MR. WEINBERG:  Sure.  She has it.

           22                  THE COURT:  What is the number, please?

           23                  MR. WEINBERG:  It's 242.

           24   BY MR. WEINBERG:

           25        Q    Now, in your direct testimony, you made a big

                                  KANABAY COURT REPORTERS

                                                   Page 1031

            1   point about the CSWs, the completed staff work, you know,

            2   like the purchase orders.  Do you know what I'm talking

            3   about?

            4        A    Yes, I do.

            5        Q    And --

            6        A    I didn't make a big deal out of it.  I think I

            7   explained it.

            8        Q    Well, the point was, you said that in order to --

            9   for the medical liaison office to buy, you know, chloral

           10   hydrate, you would have to have a CSW or purchase order

           11   issued.  Correct?

           12        A    Right.

           13        Q    And then you drew some conclusion.  Because there

           14   wasn't any purchase order, your conclusion was that that

           15   hadn't happened?  Was that what your conclusion was?

           16        A    I do not believe that that was my conclusion.

           17        Q    In any event, you're familiar, are you not, with

           18   cash floats?  Do you know what that is?

           19        A    Sure.

           20        Q    And are you familiar with the policy that

           21   provides for a float for the MLO?  Are you familiar with

           22   that?

           23        A    I am not.

           24        Q    Explain to the Court what a float is.

           25        A    Well, I mean, if you have a policy there, I mean,

                                  KANABAY COURT REPORTERS

                                                   Page 1032

            1   I --

            2                  THE COURT:  He just wants you to tell me

            3        what a float is, if you know.

            4                  THE WITNESS:  I don't.

            5   BY MR. WEINBERG:

            6        Q    I thought you just said you did.

            7        A    Well, not in the -- I don't think -- maybe I

            8   misspoke, because I don't understand the context you're

            9   talking about float here.

           10                  MR. WEINBERG:  All right.  I'll have it

           11        marked.

           12                  Could you mark this as 243, I believe.

           13                  This would be 243, your Honor (handing).

           14                  THE WITNESS:  Thank you.

           15   BY MR. WEINBERG:

           16        Q    Now, I've handed you a -- Defendant's 243, which

           17   is Flag Order 3082R, November 15th, 1971, with regard to

           18   medical finance.  And do you see that this policy

           19   reinstates in every Sea Organization the use of a $1,000

           20   medical float?  Do you see that?

           21        A    Yes, I do.

           22        Q    And do you understand what that means?

           23        A    Yes, I do.  But this does not negate someone else

           24   that has a medical emergency, as stated in that CSW exhibit

           25   that we put in for medical emergencies, of what it has to

                                  KANABAY COURT REPORTERS

                                                   Page 1033

            1   go through.

            2        Q    Well, do you understand that what this is saying

            3   is that for every Sea Organization, including -- which

            4   would include Flag Services, correct, Fort Harrison?

            5        A    Correct.

            6        Q    Right.  That for every organization, the MLO, the

            7   medical liaison office, has a $1,000 float from which they

            8   don't have to issue these CSWs and purchase orders and can

            9   go get what they need?  Do you understand that?

           10        A    Well, hang on a second, because I'm looking at

           11   this second page here, and it says since the medical

           12   officer has the authority in the Org more than anyone else

           13   under need of these purchases, he does not need division

           14   reapproval.  He does not have to have a CSW for his money.

           15   Division 3 just disburses the money each time.  A simple

           16   red purchase order stating $1,000 for a medical float is

           17   sufficient to get the money.

           18             Now, what this is specifically referring to is a

           19   medical officer having this float, but there's another

           20   policy letter in Scientology that's in Division 3 that has

           21   to do with accounting.  Even though this medical officer

           22   would have this float, he would still have to account in

           23   detail where the last $1,000 went as well.

           24        Q    Well, look at under "essential data."  Do you see

           25   where it says this policy -- this medical float policy is

                                  KANABAY COURT REPORTERS

                                                   Page 1034

            1   established to prevent the medical officer from having to

            2   spend much time or worry on finance?

            3        A    Yes.

            4        Q    Do you understand that the whole concept of every

            5   time I had to go get chloral hydrate for a parishioner that

            6   needed it, that I would have to fill out some CSW, that

            7   that might not be a very efficient way to help people and

            8   that that's what this float policy is all about?

            9        A    Well, you know, I understand what you're saying

           10   in theory and, you know, I don't -- I really don't think

           11   it's a common practice.

           12                  THE COURT:  Are you saying that when you go

           13        back and get more -- $1,000 float money that they're

           14        going to want to see what you spent the money for?

           15                  THE WITNESS:  Yes.  Yes, your Honor.

           16                  THE COURT:  And how are you going to account

           17        for that?  With receipts or what?

           18                  THE WITNESS:  Yes, your Honor.

           19   BY MR. WEINBERG:

           20        Q    Now, have you ever been a medical liaison

           21   officer?

           22        A    No, I have not.

           23                  THE COURT:  I mean, this sounds to me like a

           24        petty cash fund of sorts.

           25                  MR. WEINBERG:  That's exactly --

                                  KANABAY COURT REPORTERS

                                                   Page 1035

            1                  THE COURT:  When you have a petty cash fund,

            2        you still -- if it's a $1,000 petty cash fund, you're

            3        going to have to show somebody what it is you spent

            4        the money on.

            5                  MR. DANDAR:  I also object.  The last

            6        sentence on this document talks about it's only for

            7        the crew.  They hadn't mentioned anything about public

            8        members.

            9                  THE COURT:  Well, you can bring that up on

           10        cross-examination.

           11                  MR. DANDAR:  All right.

           12                  MR. WEINBERG:  I was just raising this

           13        because of the testimony on direct, that you needed a

           14        CSW.  This policy says you don't need a CSW.

           15                  THE COURT:  I frankly didn't even remember

           16        it, so . . .

           17                  MR. WEINBERG:  You do now, right?

           18                  THE COURT:  I do now.

           19                  MR. WEINBERG:  And then I'll just show

           20        you --

           21                  Then I'll mark, just so it's in the record

           22        the -- as the next exhibit@.

           23                  THE CLERK:  244.

           24                  MR. WEINBERG:  244, take one second (handing

           25        to Court and witness).

                                  KANABAY COURT REPORTERS

                                                   Page 1036

            1   BY MR. WEINBERG:

            2        Q    The Modern Management Technology Defined:

            3   Hubbard Dictionary of Administration and Management.  You

            4   know about that dictionary, right, Mr. Prince?

            5        A    Yes, I do.

            6        Q    If you go to "medical float," do you see on

            7   page 329, it says:  "With this float, the medical officer

            8   buys doctor-dentist-medical-health specialist visits and

            9   treatment, laboratory analysis, X rays, medical equipment

           10   essential for a person's health, medicines, prescriptions,

           11   and transportation."  Do you see that?

           12        A    Yes.

           13        Q    So something like a prescription for chloral

           14   hydrate would be covered by the medical float, would it

           15   not?

           16        A    This references this same Flag order.  I gave

           17   testimony that a Flag order has to do with Sea Org

           18   personnel.  It has to do with people that are on staff in

           19   the Sea Org.

           20        Q    So -- so the MLO officer has to get a purchase

           21   order to go get chloral hydrate for a parishioner who is

           22   staying at the Fort Harrison, but if he or she doesn't --

           23   if a Sea Org member is at the Fort Harrison?  Is that your

           24   testimony?

           25        A    My testimony is the evidence that you've given me

                                  KANABAY COURT REPORTERS

                                                   Page 1037

            1   here states specifically that this is how it is done for

            2   staff members.  The public, being a paying public,

            3   certainly have different policies.

            4                  THE COURT:  To be candid with you, I think

            5        it's been conceded that -- by somebody that Lisa

            6        McPherson should not have been to the hotel.  Hasn't

            7        that been conceded?

            8                  MR. WEINBERG:  Well, I don't think conceded.

            9        I think people were trying --

           10                  THE COURT:  To suggest that it really ought

           11        not to have been taken care of --

           12                  MR. WEINBERG:  It would have been a smarter

           13        thing to be in a different environment.

           14                  THE COURT:  Right.  So you have to assume

           15        that the medical that they're talking about in this --

           16        I'll ask Mr. Prince this.

           17                  You have to assume that normally it's going

           18        to be Sea Org members who are going to be taken care

           19        of because they're the ones that would be living in a

           20        Scientology facility.

           21                  THE WITNESS:  Correct.

           22                  THE COURT:  But at some place like Flag,

           23        where they have maybe -- I guess you have to be a Sea

           24        Org member to come there and take the technology

           25        courses that they offered.

                                  KANABAY COURT REPORTERS

                                                   Page 1038

            1                  THE WITNESS:  No, you don't have to be --

            2                  THE COURT:  Right.  So if somebody is

            3        there -- there, and they have to get a -- I mean, I

            4        don't know what -- they get sick and somebody is

            5        called in and they need some minor medicine, I would

            6        assume that they would allow this policy to govern,

            7        rather than have to go through all the harangue of

            8        whatever it was you were talking about.  But I think

            9        that whatever it is, you're going to still,

           10        nonetheless, account for whatever it is you bought out

           11        of your petty cash fund or your float fund or whatever

           12        you want to call it.

           13                  THE WITNESS:  Sure.  And the other thing,

           14        your Honor, is that in no way will a Scientology

           15        organization pay the medical expenses of a public

           16        paying staff member, a public person coming in, using

           17        services in Scientology.  You know, the money works

           18        the other way.  The public gives the money to

           19        Scientology.  Scientology doesn't then --

           20                  THE COURT:  Well, we know they were using

           21        Ms. McPherson's money to pay for certain things

           22        because she eventually ran out.

           23                  THE WITNESS:  Correct.

           24                  THE COURT:  So presumably everything was

           25        subject.  I mean, if she was really in a bad

                                  KANABAY COURT REPORTERS

                                                   Page 1039

            1        situation, a psychotic, where she couldn't -- you

            2        know, they apparently were free to use her funds, I

            3        guess.

            4                  THE WITNESS:  Yes.

            5                  THE COURT:  So you can't really tell us,

            6        under the circumstances that we're dealing with here,

            7        whether chloral hydrate was necessarily purchased out

            8        of the float money or whether it was purchased with

            9        this CSW.

           10                  THE WITNESS:  Correct.

           11                  THE COURT:  Would that be fair?

           12                  THE WITNESS:  Yes, your Honor.

           13                  MR. WEINBERG:  Just a few more questions,

           14        one more area.

           15   BY MR. WEINBERG:

           16        Q    Back to the gun situation just for a moment.

           17   Yesterday when we talked about this or the day before --

           18   I've sort of lost count now -- you sort of suggested that

           19   it was more of a -- of a joke, that you really weren't that

           20   serious.

           21                  THE COURT:  What was a joke?

           22   BY MR. WEINBERG:

           23        Q    That you weren't really threatening anybody.

           24                  THE COURT:  What are you talking about?

           25                  MR. WEINBERG:  Oh, I'm sorry, the gun, when

                                  KANABAY COURT REPORTERS

                                                   Page 1040

            1        he says he pulled the guns on David Miscavige.

            2        A    I didn't say anything about a joke.  I said I did

            3   it out of self-protection.

            4   BY MR. WEINBERG:

            5        Q    All right.  So --

            6        A    That's the testimony that I gave from this stand.

            7        Q    Well, I thought I heard you say that you didn't

            8   really threaten anybody.

            9        A    I can't help what you thought you heard, but I

           10   can tell you right now that when -- after -- what I

           11   testified to in this courtroom is that after those people

           12   grabbed me and I got away from them, I went to my room and

           13   got these weapons to protect myself.  It wasn't a joke to

           14   me at that point.

           15        Q    And when you first told -- do you remember when

           16   you first told this story about guns?  That was in the

           17   FACTNet deposition, which was the first deposition I

           18   think -- was that the first deposition you gave after you

           19   became a witness against Scientology?

           20                  MR. DANDAR:  Objection to form.

           21                  THE COURT:  No, that's all right.

           22                  MR. DANDAR:  All right.

           23                  THE COURT:  Overruled.

           24        A    I'm not sure.

           25   BY MR. WEINBERG:

                                  KANABAY COURT REPORTERS

                                                   Page 1041

            1        Q    All right.  Do you remember in that deposition

            2   that you said something to the effect that bodies were

            3   going to start dropping?

            4        A    If you have it, you know, I'd like to see it.

            5        Q    Okay.

            6        A    If you just have it, you show it to me, and I'll

            7   tell you what I said.

            8        Q    We'll play a short clip, you'll have it, and then

            9   I'll have a couple of questions.

           10        A    Okay.

           11                  THE COURT:  A short clip from what?  A

           12        deposition?

           13                  MR. WEINBERG:  Of his deposition.  It's his

           14        deposition.

           15                  THE COURT:  In this case?

           16                  MR. WEINBERG:  No.  It's his deposition in

           17        the FACTNet case.  It will take just a minute, I

           18        think.

           19                  MR. DANDAR:  Apparently need it brighter.

           20                  MR. WEINBERG:  I'm amazed she can pull this

           21        stuff up.

           22                  THE WITNESS:  Right in this room, I'm having

           23        a difficult time.  I think I'd better go around.

           24                  THE COURT:  Sure.  Wait a minute.

           25                  MR. WEINBERG:  Wait just one second.

                                  KANABAY COURT REPORTERS

                                                   Page 1042

            1                  (The witness left the stand,)

            2                  THE WITNESS:  Okay.

            3                  THE COURT:  Okay.

            4                  (The tape was played as follows.)

            5               FROM THE DEPOSITION OF JESSE PRINCE

            6                      DATED AUGUST 20, 1998

            7        A    And I went to my room, where I had a loaded .45

            8   and a loaded Mini 14, and I came back to David Miscavige's

            9   office with those guns.  And I said, "Which one of you

           10   wants to fuck with me now?"

           11   BY MR. ROSEN:

           12        Q    And what happened?  I'm sitting here with bated

           13   breath thinking -- to hear the end of the story.

           14        A    Well, do you want me to tell it or do you want --

           15        Q    No, I'm (unintelligible) the answer to that

           16   question that you raised.

           17        A    Well, I'm confused now.  What question did I

           18   raise?

           19        Q    You posed a question to Mr. Miscavige that "which

           20   one of you wants to F with me now?"

           21        A    Right.  So at this point Vicki comes running out:

           22   "Jesse, no, no, no, it's all been sanctioned by Annie

           23   Broker.  She knows about everything.  And Pat Broker.  She

           24   knows about everything.  Don't do this."

           25             Then here comes David Miscavige.  He completely

                                  KANABAY COURT REPORTERS

                                                   Page 1043

            1   changes his tune now:  "Oh, Jesse," you know, "we've been

            2   friends and we've gone through so much.  Let's not go here.

            3   It's a mistake what we've done here.  I know you're upset.

            4   Please let's talk about it."

            5             And I stood there looking at them with my guns in

            6   my hand, wondering.  You know, like you can pat a snake on

            7   the head, but as soon as you pull your hand back, he going

            8   to bite.  And I was wondering if that was going to happen

            9   to me as I'm sitting here with these guns.

           10             And, you know, David is like pleading.  Then it

           11   turns into a situation like, "Well," you know, "we've got

           12   lots of guns too."

           13             And I said, "What the hell do you all want to do,

           14   have a shootout?  Because I've got guns here, and bodies

           15   are going to start dropping."

           16                  (End of tape.  The witness returned to the

           17                  stand)

           18                  MR. DANDAR:  I object.  It's apples and

           19        oranges.  It doesn't even go to try to impeach the

           20        witness.

           21                  MR. WEINBERG:  Well, first --

           22                  THE COURT:  I don't know what the purpose

           23        was, so we'll hear now.

           24   BY MR. WEINBERG:

           25        Q    Yesterday or the day before, July 9th, when I

                                  KANABAY COURT REPORTERS

                                                   Page 1044

            1   asked you the question about whether you threatened to kill

            2   Mr. Miscavige, you said, quote, "I didn't threaten to kill

            3   Mr. Miscavige."

            4             Now, when you told that story to Mr. Rosen at

            5   that August 1998 deposition, you said in front of

            6   Mr. Miscavige, you know, "Bodies are going to start

            7   dropping," or something like that.  Right?  I mean, you

            8   said that --

            9        A    The video speaks for itself, and I don't contest

           10   it.  I mean, that's -- what I said is what happened, is

           11   what I meant.  So you can take it any way you want.

           12        Q    Now, when you said a Mini 14 --

           13                  THE COURT:  A what?

           14                  MR. WEINBERG:  A Mini 14.

           15                  THE COURT:  What do we care about this,

           16        about these guns?

           17                  MR. WEINBERG:  About --

           18                  THE COURT:  About something that went on

           19        between him and -- way back when.

           20                  MR. WEINBERG:  No, it's just the opposite,

           21        your Honor.  We don't believe this incident ever

           22        happened and that he just made this up for reasons

           23        that one can only imagine when he told this story for

           24        the first time in August of 1998.  But, your Honor, I

           25        mean --

                                  KANABAY COURT REPORTERS

                                                   Page 1045

            1   BY MR. WEINBERG:

            2        Q    Let me ask you.  A Mini 14 is an assault rifle,

            3   right?

            4        A    Correct.

            5                  MR. WEINBERG:  Mr. Bailiff, could I possibly

            6        have our model there?

            7                  This is just a replica.

            8                  THE COURT:  Okay.

            9                  MR. WEINBERG:  It's plastic.  It's plastic.

           10        It's not real.

           11                  MR. DANDAR:  I just wish -- I just wish the

           12        St. Pete Times was here with their camera to see this.

           13        I think this is an unbelievable game --

           14                  THE COURT:  Is that an objection?

           15                  MR. DANDAR:  -- of showmanship.  It's

           16        irrelevant.

           17                  THE COURT:  What is the point?

           18   BY MR. WEINBERG:

           19        Q    (Showing)  Is that what you're talking about?

           20   Something like that?

           21        A    Similar to, but not quite.

           22                  MR. WEINBERG:  All right.  I'm going to give

           23        you this back.

           24   BY MR. WEINBERG:

           25        Q    And you still contend that that's what you pulled

                                  KANABAY COURT REPORTERS

                                                   Page 1046

            1   on Mr. Miscavige and the other twelve people that were

            2   there.  Right?

            3        A    Mr. Weinberg, I stand behind the testimony that

            4   I've given about that incident in the past and anything

            5   I've said --

            6        Q    All right.

            7        A    -- in this hearing.

            8        Q    And then they just let you go right back to your

            9   room and put the guns in your room?

           10        A    Correct.

           11        Q    And they didn't take them away from you?

           12        A    Correct.

           13        Q    And they just stayed there for the next, what,

           14   five years?

           15        A    No.  I eventually sold the Mini 14.

           16                  MR. WEINBERG:  Okay.  I don't have any

           17        further questions, your Honor.

           18                  THE COURT:  All right.  Redirect?

           19                  MR. DANDAR:  Yes.

           20                       REDIRECT EXAMINATION

           21   BY MR. DANDAR:

           22        Q    Well, we ought to pick it up right where

           23   Mr. Weinberg just left off.

           24                  (Mr. Weinberg spoke to Mr. Dandar off the

           25                  record.)

                                  KANABAY COURT REPORTERS

                                                   Page 1047

            1                  MR. DANDAR:  Do you want me to wait?

            2                  MR. WEINBERG:  That's fine.  I just don't

            3        want to interrupt you.

            4   BY MR. DANDAR:

            5        Q    When you had these two real guns loaded as you

            6   described when you were being, quote, busted, unquote,

            7   Mr. Miscavige came right up to you while you held the two

            8   guns in your hands, correct?

            9        A    Correct.

           10        Q    And did you or he laugh?

           11        A    Laugh?

           12        Q    Laugh.

           13        A    Like laugh?

           14        Q    Yes, like laugh.

           15        A    No.

           16        Q    Did Mr. Miscavige say -- indicate to you any fear

           17   whatsoever?

           18        A    No.

           19        Q    And then you turned around and walked back to

           20   your room?

           21        A    Correct.  I believe he may have even followed me

           22   there.  And we then proceeded to that area of the ship

           23   where we saw the pictures with the swimming pool, with the

           24   mast, and we had a conversation there.

           25        Q    Did you sit around the pool?

                                  KANABAY COURT REPORTERS

                                                   Page 1048

            1        A    Well, actually, there's an area inside that's

            2   air-conditioned, has a bar in there, and we actually sat in

            3   there and drank cold water and ate fruit.

            4        Q    And when Mr. Weinberg -- or, you said that Vicki

            5   Aznaran, the president of the RTC, told you that this had

            6   all been sanctioned by Annie and Pat Broker, did she

            7   accompany you to the RPF after that?

            8        A    Yes, and other people for sure.

            9        Q    Because she took the Annie and Pat Broker side,

           10   rather than the David Miscavige power struggle side?

           11        A    Correct.

           12        Q    You're going to the RPF, Mr. Prince.  Did it have

           13   anything to do with any mistakes you made in applying the

           14   tech of Scientology?

           15        A    Absolutely not.

           16                  THE COURT:  What does this all have to do

           17        with anything I'm hearing?

           18                  MR. DANDAR:  Just trying to straighten out

           19        some misconceptions.  My computer just went onto

           20        standby.  That's not what I wanted to happen.  All

           21        right.

           22   BY MR. DANDAR:

           23        Q    Now, when you left Scientology, did you just walk

           24   out the door in '92?

           25        A    No.

                                  KANABAY COURT REPORTERS

                                                   Page 1049

            1        Q    How did you leave?

            2        A    I had to basically sign a release saying that

            3   Scientology has never done anything wrong with me and has

            4   no liability for anything that I may be suffering then or

            5   could realize in the future and on and on and on --

            6                  THE COURT:  Wasn't that release introduced

            7        yesterday?

            8                  MR. DANDAR:  Yes.

            9                  THE WITNESS:  Yes.

           10                  THE COURT:  So it said whatever it said.

           11                  MR. DANDAR:  Well, I wanted to ask him a

           12        question about it, and you can see my paralegal is not

           13        here, so I'm flying.

           14   BY MR. DANDAR:

           15        Q    That release says that you were releasing the

           16   Church of Scientology from any and all damages for valuable

           17   consideration.  There's two or three paragraphs that say

           18   that.

           19        A    M'hum (affirmative).

           20        Q    What valuable consideration did you receive from

           21   the Church of Scientology to sign that release?

           22                  MR. WEINBERG:  It was asked and answered.

           23        He explained --

           24                  THE WITNESS:  No, I never answered this.

           25                  THE COURT:  Just a second.

                                  KANABAY COURT REPORTERS

                                                   Page 1050

            1                  MR. WEINBERG:  Objection, asked and answered

            2        by Mr. Dandar.  I didn't go back into it.  It's beyond

            3        the scope.  But he already -- Mr. Prince already

            4        explained how much money he got in return for signing

            5        the release on direct.

            6                  THE COURT:  He did?

            7                  MR. WEINBERG:  Yes.  He said --

            8                  THE WITNESS:  No, I didn't.

            9                  MR. DANDAR:  Shhh.

           10                  MR. WEINBERG:  I thought he said a thousand

           11        plus dollars.

           12                  THE COURT:  I don't remember it, so I'm

           13        going to allow him to ask it.  I don't remember it.

           14                  MR. WEINBERG:  Okay.  I might have brain

           15        drain.

           16                  MR. DANDAR:  I think you're talking about

           17        some meeting in December of '94.

           18                  MR. WEINBERG:  No, I don't think so.

           19                  THE COURT:  That was more than a thousand.

           20                  THE WITNESS:  Twenty-seven.

           21                  MR. WEINBERG:  I really think he did, but it

           22        doesn't matter.

           23                  THE COURT:  All right.

           24   BY MR. DANDAR:

           25        Q    Well, did you receive anything of consideration

                                  KANABAY COURT REPORTERS

                                                   Page 1051

            1   to sign those releases?

            2        A    I think I received $2,000.

            3        Q    Okay.  From whom?

            4        A    Good question.  Marty just handed me the money.

            5        Q    Well, do you have any idea why it's not mentioned

            6   in the release?

            7        A    I do not.

            8                  THE COURT:  Most releases don't tell you

            9        what.  Most releases say "ten dollars and other

           10        valuable consideration," don't they?

           11                  MR. DANDAR:  Not the ones that I've seen,

           12        Judge.

           13                  THE COURT:  Most of the ones I've seen do,

           14        because I always wondered why they pick ten dollars.

           15   BY MR. DANDAR:

           16        Q    Mr. Prince, how is it that Ms. Dana Hanson wanted

           17   to -- picked you to come into her public business and set

           18   up her business to run the Hubbard tech?

           19                  MR. WEINBERG:  Objection as to competency.

           20        I mean, how is it that this woman --

           21                  THE COURT:  I'll sustain that.  Quite

           22        frankly, I suspect that he's already testified he was

           23        one of the premier experts on the tech.  So I mean, I

           24        think I can assume that.

           25                  MR. DANDAR:  Okay.  If you can assume that,

                                  KANABAY COURT REPORTERS

                                                   Page 1052

            1        I'll go on.

            2   BY MR. DANDAR:

            3        Q    Now, Mr. Prince, you were --

            4                  THE COURT:  I can't assume that, but, I

            5        mean, that is the testimony that he has put forth.

            6                  MR. DANDAR:  Okay.

            7                  THE COURT:  So . . .

            8   BY MR. DANDAR:

            9        Q    Mr. Prince, is there any other reason as far as

           10   you know -- without telling us what other people said -- is

           11   there any other reason as far as you know as to why Dana

           12   Hanson hired you, other than your expertise on the tech?

           13        A    You know, there --

           14                  THE COURT:  If you don't know --

           15        A    I don't know the reason.

           16                  THE COURT:  Remember yesterday, that's a

           17        perfectly valid answer in a court of law, "I don't

           18        know."

           19                  THE WITNESS:  Yes.  I don't know of any

           20        other reason.

           21   BY MR. DANDAR:

           22        Q    Mr. Prince, you wanted to tell Mr. Weinberg a

           23   little while ago why the date of March 3, 1987, appears on

           24   all three resignation letters which is Defendant's

           25   Exhibit 242.  Why does the date appear on there?

                                  KANABAY COURT REPORTERS

                                                   Page 1053

            1        A    Because after me and Mr. Miscavige had our little

            2   chat on the ship area after the gun incident, he said, you

            3   know:  "We have your undated resignation, but just help

            4   us," you know, "do everything right now."  You know:

            5   "We're talking again.  You're going to take this fall;

            6   you're going to do this.  Would you please just do it again

            7   and sign these new ones?"

            8             And I said, "Yes, I'll do it."

            9             So that's why these are signed this way.

           10        Q    So there exists other resignation letters that

           11   are undated?

           12        A    Yes, correct.

           13        Q    Have you seen those?  Have they been produced to

           14   you ever?

           15        A    Not today.

           16        Q    Have you ever seen them before this?

           17        A    Sure.

           18        Q    Where?

           19        A    In the Religious Technology Center in my office,

           20   where I signed it.  I also saw it in David Miscavige's

           21   office on the day that I was removed from the executive

           22   position of Religious Technology Center.

           23        Q    Okay.  So on the resignation letters that are in

           24   evidence, those are the ones you actually signed on

           25   March 3rd of 1987?

                                  KANABAY COURT REPORTERS

                                                   Page 1054

            1        A    Correct.

            2        Q    Okay.  And you did that because your friend David

            3   Miscavige asked you to do it?

            4        A    Correct.

            5        Q    You weren't threatened and forced to do it?

            6        A    Correct.

            7        Q    Were you being a good Scientologist when you

            8   signed that?

            9        A    Absolutely.

           10        Q    All right.  Now, Mr. Houghton, who is a defendant

           11   in this case, who is in the MLO office, who is the one that

           12   came up with the idea of using a syringe to get aspirin and

           13   Benadryl --

           14                  MR. WEINBERG:  Objection, your Honor.  First

           15        of all, to the form; he's just testifying.  Secondly,

           16        he's misstating the testimony.  And thirdly, it's

           17        beyond the scope of my cross-examination.  I didn't

           18        ask anything about Mr. Houghton.

           19                  THE COURT:  I suspect he's going to go back

           20        to the CSW that you felt compelled to raise in some

           21        fashion.

           22                  MR. WEINBERG:  That's fine.  But then --

           23                  MR. DANDAR:  How do you know that?

           24                  MR. WEINBERG:  -- I object to the form.

           25        Then I object to the form, as he's just making a

                                  KANABAY COURT REPORTERS

                                                   Page 1055

            1        speech.

            2                  THE COURT:  Your objection to form is

            3        overruled because he's not.  He's trying to provide

            4        some background to see if this witness can answer a

            5        question.

            6   BY MR. DANDAR:

            7        Q    Mr. Houghton stated on page 71 of his deposition,

            8   where the question begins on line 18, as follows.

            9   Question --

           10                  THE COURT:  You folks back there, I can hear

           11        you clear up here, so it must be disconcerting to

           12        Mr. Dandar.  So keep your voices down.  Or you may

           13        step out of the room at anytime you need to speak in a

           14        loud voice.

           15                  Go ahead.

           16   BY MR. DANDAR:

           17        Q    Question:  "And where did you get the money to

           18   buy the prescription?"

           19             Answer:  "I got it from Alain Kartuzinski."

           20             Question:  "And why did you go to him to get the

           21   money?"

           22             Answer:  "I didn't have the personal funds to pay

           23   for it.  I didn't know.  I don't know exactly why I went to

           24   Alain.  I don't know what events led me up to getting the

           25   money from Alain, but I do know that's where I got the

                                  KANABAY COURT REPORTERS

                                                   Page 1056

            1   money."

            2             The question is, Is Mr. Kartuzinski, back in

            3   November and December of 1995, pursuant to his testimony in

            4   this case, part of the MLO?

            5        A    No.

            6        Q    What was he?

            7        A    He was the Senior CS --

            8                  THE COURT:  I'll tell counsel what you

            9        really don't have to do is ask this witness that.  I

           10        would know that.

           11                  MR. DANDAR:  Sorry.

           12                  THE COURT:  You can save a lot of this for

           13        closing argument.

           14                  MR. DANDAR:  All right.  There's so much of

           15        that.

           16                  All right.  That takes care of this part.

           17                  Let's put this away.

           18                  THE COURT:  Is this a witness, by chance,

           19        that has just come in?

           20                  A SPEAKER:  (Shook head negatively.)  No,

           21        your Honor.

           22                  THE COURT:  Okay.  Welcome then.  I didn't

           23        want somebody to come in that was maybe going to

           24        testify.

           25   BY MR. DANDAR:

                                  KANABAY COURT REPORTERS

                                                   Page 1057

            1        Q    All right.  Mr. Prince, in your tenure in

            2   Clearwater at the Lisa McPherson Trust, did you ever see

            3   the Church of Scientology picketing the Lisa McPherson

            4   Trust?

            5        A    Absolutely.  You know -- yes.  Yes, many times.

            6        Q    Would they do it in front of the building, the

            7   office?

            8        A    They would do it in front of the building.  They

            9   would do it inside the building.  There's many police

           10   reports of Scientologists running and screaming, disrupting

           11   activities.  Again, my friend -- my good friend, Judge

           12   Penick, can speak about that.  And we watched videos for

           13   days.  He would be a great witness about that.

           14        Q    Okay.  All right.  Do you know if anyone from the

           15   Lisa McPherson Trust hired private investigators to follow

           16   Church members around?

           17        A    Never.

           18        Q    Go to their homes and picket their homes?

           19        A    Never.

           20        Q    Pass out leaflets in their neighborhood?

           21        A    No.

           22        Q    Now, even though you left the Church of

           23   Scientology, have you ever divulged the confidential PC

           24   folders of the people that you either audited or were a

           25   case supervisor over?

                                  KANABAY COURT REPORTERS

                                                   Page 1058

            1        A    No, I have not, never.

            2        Q    Now, Mr. Weinberg went back and talked to you

            3   about your deposition that you gave on behalf of Religious

            4   Technology Center, where their former attorney, Joseph

            5   Yanny, was suing them or RTC was suing him.  I'm not sure.

            6   Do you remember which way that was?

            7        A    I don't remember which way it was going.

            8        Q    Okay.  But anyway, that was back in 1989, while

            9   you were still in your demoted status?

           10        A    You know, that had been some years past that,

           11   yes.

           12        Q    Okay.  And when you met -- you said you met with

           13   Mr. Earle Cooley, the attorney for RTC, before your

           14   deposition commenced?

           15        A    Correct.

           16        Q    Do you also recall meeting with a person by the

           17   name of Lynn Farney?

           18        A    Yes.

           19        Q    And the reason why I know this is it's in your

           20   deposition copy that Mr. Weinberg gave me.  Before today --

           21   in fact, as you sit here today, have you ever seen a copy

           22   of that deposition?

           23        A    No.

           24        Q    That deposition is dated September 11th of 1989.

           25   Mr. Weinberg questioned you in your deposition in this case

                                  KANABAY COURT REPORTERS

                                                   Page 1059

            1   that was taken in '99, ten years after the RTC deposition.

            2   Do you remember him questioning you about that deposition?

            3        A    Yes.

            4        Q    Did he give you a copy of that deposition back

            5   then?

            6        A    No.

            7        Q    Now, Mr. Farney, do you know -- back at the time

            8   that he and Mr. Cooley, the attorney, met with you before

            9   the RTC deposition, do you know what position he had?

           10        A    Mr. Farney had been on a Rehabilitation Project

           11   Force with myself.  Mr. Lynn Farney is a person that I used

           12   to create and establish the Office of Special Affairs at

           13   International.  I had --

           14                  MR. WEINBERG:  Your Honor, he just asked him

           15        what position he was in at the time that he supposedly

           16        had this meeting with him.  Now we're getting the

           17        whole history.  Can he just answer the question,

           18        please?

           19                  THE COURT:  Sustained.

           20   BY MR. DANDAR:

           21        Q    At the time of his deposition, what was his

           22   position?

           23        A    Mr. Farney was working in OSA International.  It

           24   was my belief that Mr. Farney was working in OSA

           25   International.

                                  KANABAY COURT REPORTERS

                                                   Page 1060

            1                  THE COURT:  I'm sorry, I must have missed

            2        the beginning of this.  What did you initially ask

            3        him?  If Mr. Farney was --

            4                  MR. DANDAR:  Part of the meeting preparing

            5        Mr. Prince for deposition in the RTC case.

            6                  THE COURT:  Okay.

            7                  MR. DANDAR:  RTC slash Yanny, Y-a-n-n-e-y.

            8                  THE WITNESS:  Y-a-n-n-y.

            9                  MR. DANDAR:  Okay.  Thank you.

           10   BY MR. DANDAR:

           11        Q    Mr. Farney is someone that you worked with in

           12   establishing the Office of Special Affairs?

           13        A    Correct.

           14        Q    Do you remember what year that was?

           15        A    '84.  '83, '84.

           16        Q    Okay.  And are you aware that Mr. Farney is also

           17   the person who met with all the staff members after Lisa

           18   McPherson's death?

           19                  MR. WEINBERG:  Objection, your Honor --

           20        A    No, I was not aware of that.

           21                  MR. WEINBERG:  Objection to form.  He's

           22        testifying.

           23                  THE COURT:  True.  Sustained.  However, he

           24        wasn't aware of it, so --

           25                  MR. WEINBERG:  I understand.  It's just --

                                  KANABAY COURT REPORTERS

                                                   Page 1061

            1                  THE COURT:  Remember, questions aren't

            2        evidence, only the answers.

            3   BY MR. DANDAR:

            4        Q    Now, in that meeting before your deposition, who

            5   instructed you to avoid telling the truth in your

            6   deposition?

            7        A    Mr. Rathbun and Mr. Cooley.

            8                  THE COURT:  Is it Rathburn or Rathbun?

            9                  MR. WEINBERG:  Bun.

           10                  THE COURT:  Bun.

           11                  THE WITNESS:  Rathbun.

           12                  THE COURT:  B-u-n.

           13                  MR. WEINBERG:  Right.

           14                  MR. DANDAR:  And it's Ms. Brooks, not

           15        Mrs. Brooks.  Never mind.

           16                  MR. WEINBERG:  R-a-t-h-b-u-n.

           17                  MR. DANDAR:  I'm sorry.  All right.

           18   BY MR. DANDAR:

           19        Q    Did it surprise you when Mr. Cooley and

           20   Mr. Rathbun were giving you instructions on not telling the

           21   truth?

           22        A    No, it did not.

           23        Q    And why is that?

           24        A    Because it's expected.

           25        Q    Why is that?

                                  KANABAY COURT REPORTERS

                                                   Page 1062

            1        A    Because you have to protect Scientology.  You

            2   have to protect -- you know, it's like placing Scientology

            3   and Scientologists at risk being a crime.  You have -- you

            4   are expected as a member of the Church of Scientology to do

            5   and say whatever you have to to preserve Scientology, to

            6   preserve its leaders.

            7        Q    Is that a written policy?

            8        A    Probably.

            9        Q    And Mr. Yanny --

           10                  MR. WEINBERG:  Well, your Honor, could we

           11        just identify that policy if that's a written policy?

           12        He said "probably."

           13                  THE COURT:  I assume probably he couldn't

           14        tell us --

           15                  MR. WEINBERG:  All right.

           16                  THE COURT:  -- or he would have given us a

           17        number.

           18                  MR. WEINBERG:  Okay.

           19   BY MR. DANDAR:

           20        Q    Can you tell us -- without giving a number, but

           21   can you tell us generally what policy you're talking about?

           22        A    As I sit here today without the materials, I

           23   could not, but I could certainly submit a declaration on it

           24   at a later point.

           25        Q    All right.  What is an acceptable truth?

                                  KANABAY COURT REPORTERS

                                                   Page 1063

            1                  MR. WEINBERG:  Objection, your Honor.  I

            2        didn't ask him about --

            3                  THE COURT:  Right.

            4                  MR. WEINBERG:  Beyond the scope.

            5                  THE COURT:  I think he already -- didn't you

            6        already ask that on direct?

            7                  MR. DANDAR:  I did, I did.

            8   BY MR. DANDAR:

            9        Q    Now, you said --

           10                  THE COURT:  Didn't you also testify about

           11        the greatest good for the greatest number?

           12                  THE WITNESS:  Yes, your Honor, I did.

           13                  THE COURT:  So we've heard, I think, a lot

           14        of that.

           15                  MR. DANDAR:  You have, I'm sorry.

           16   BY MR. DANDAR:

           17        Q    Were you working for RTC at the time of that

           18   deposition in 1989?

           19        A    No, I was not.

           20        Q    Well, Mr. Yanny was the former president -- or,

           21   attorney for RTC, correct?

           22        A    Correct.

           23        Q    Why was he suing RTC?  What was that litigation

           24   about?

           25        A    You know, what I recall about that is that when

                                  KANABAY COURT REPORTERS

                                                   Page 1064

            1   Joseph Yanny was hired, he was hired by myself and

            2   Ms. Aznaran as the lead counsel for the Religious

            3   Technology Center.  When he was hired --

            4                  THE COURT:  Who was?  I'm sorry.

            5                  THE WITNESS:  Mr. Joseph Yanny, the attorney

            6        that was hired.

            7                  THE COURT:  Mr. Yanny was an attorney?

            8                  MR. DANDAR:  Yes.

            9                  THE WITNESS:  Yes.

           10                  THE COURT:  Oh, okay.

           11                  MR. DANDAR:  In fact, Judge --

           12                  Did we mark that as an exhibit at

           13        deposition?  I'd like to have that marked as an

           14        exhibit since it was used.  But Mr. Yanny is the one

           15        that actually took over questioning of Mr. Prince on

           16        the pertinent pages that Mr. Weinberg pointed out,

           17        although Mr. Yanny had his own attorney there.  He

           18        took it over because Mr. Yanny -- like me and

           19        Mr. Lirot.  I have all this stuff in my head and I

           20        know what's going on.

           21                  So the transcript -- and I'd like to make

           22        that -- and I will make it an exhibit if it's not --

           23        shows that Mr. Yanny took over the questioning of

           24        Mr. Prince in that 1989 deposition.

           25                  THE COURT:  Normally we don't use as an

                                  KANABAY COURT REPORTERS

                                                   Page 1065

            1        exhibit something that is just strictly used for

            2        impeachment purposes.

            3                  MR. WEINBERG:  That's why I didn't do it.

            4                  THE COURT:  Right.

            5                  MR. DANDAR:  All right.

            6                  THE COURT:  But if you want to make it an

            7        exhibit, why, that's your -- you can try to do that.

            8                  MR. DANDAR:  All right.

            9   BY MR. DANDAR:

           10        Q    Mr. Prince, you stated to Mr. Weinberg --

           11                  MR. WEINBERG:  Your Honor, let me object.  I

           12        mean, let me intercede for just a second.  Just so

           13        it's clear, Mr. Yanny was the party, was the

           14        plaintiff.  And I think that was clear, but I'm not

           15        sure if it was.

           16                  THE COURT:  I got it.

           17                  MR. WEINBERG:  RTC was the defendant.

           18                  THE COURT:  I didn't realize Mr. Yanny was a

           19        lawyer.  That's why I --

           20                  MR. WEINBERG:  Yes.

           21   BY MR. DANDAR:

           22        Q    So you hired Mr. Yanny to be the attorney for

           23   RTC?

           24        A    Mr. Yanny was -- yes, I did, to be the lead

           25   counsel for RTC.  RTC had other attorneys, but Mr. Yanny

                                  KANABAY COURT REPORTERS

                                                   Page 1066

            1   was hired to be the lead counsel for the Religious

            2   Technology Center at that time.

            3        Q    And is it for any particular case?

            4                  MR. WEINBERG:  Object.  Your Honor, I

            5        believe this is all beyond the scope.  All I did was

            6        impeach him on his false testimony, which he admitted

            7        was false in that deposition.  Now to get to the

            8        history of that lawsuit or Joseph Yanny I think is

            9        beyond the scope and not relevant to this proceeding

           10        either.

           11                  THE COURT:  I would tend to agree with that,

           12        Counsel.  You know, if you think it's relevant and

           13        there's something you can tell me about this, I'll

           14        listen to you.  But it's just another one of these

           15        lawsuits, many, many lawsuits.

           16                  MR. DANDAR:  Okay.

           17   BY MR. WEINBERG:

           18        Q    Mr. Prince, do you know whether or not any of the

           19   allegations made between RTC and Joseph Yanny had anything

           20   to do with Mr. Yanny perjuring himself or suborning

           21   perjury?

           22                  THE COURT:  That would be relevant.

           23        A    I don't know.  I don't remember it.

           24   BY MR. DANDAR:

           25        Q    You don't?

                                  KANABAY COURT REPORTERS

                                                   Page 1067

            1        A    No.

            2        Q    All right.  Now, did Mr. Yanny have anything to

            3   do with any of the Wollersheim litigation?

            4        A    Yes, he did.  The Wollersheim --

            5                  MR. WEINBERG:  Objection.  That was a yes or

            6        no question, and to -- if we get into the details, I'm

            7        going to object because it's beyond the scope and it's

            8        not relevant.

            9                  THE COURT:  That would be true.

           10                  MR. DANDAR:  Except he brought up the

           11        question, Mr. Weinberg did, about Mr. Prince's

           12        testimony of destruction of the PC folders.

           13                  THE COURT:  Oh, right.

           14                  MR. WEINBERG:  And I impeached him on it

           15        with the Yanny deposition.  He admitted it.  He said

           16        he lied in the deposition.  That's all I used it for.

           17                  THE COURT:  Well, I think at this point

           18        we'll see what his question is.

           19                  MR. WEINBERG:  Okay.

           20   BY MR. DANDAR:

           21        Q    Was Mr. Yanny involved in representing RTC

           22   against Mr. Wollersheim?

           23        A    Yes.

           24        Q    And was Mr. Yanny involved when Mr. Wollersheim's

           25   PC folders were destroyed?

                                  KANABAY COURT REPORTERS

                                                   Page 1068

            1        A    He had no personal knowledge of it.

            2        Q    Was any attorney for Scientology involved in that

            3   in any degree?

            4        A    The only one that I know of that would have had

            5   information about that would have been Mr. Earle Cooley.

            6                  MR. WEINBERG:  Objection, "would have had."

            7        I mean, is he saying he did have?

            8                  THE WITNESS:  I can explain if you would

            9        like me to.

           10   BY MR. DANDAR:

           11        Q    Go ahead.  Explain it.

           12        A    The decision to do this was made in a conference

           13   room at Author Services with myself, Vicki Asnaran,

           14   Mr. Rathbun was there, Mr. Cooley was there, and this all

           15   has to do with --

           16                  THE COURT:  Mr. Miscavige was there?

           17                  THE WITNESS:  Yes.  Yes, your Honor.  And

           18        this had --

           19                  THE COURT:  Who else was there?

           20                  THE WITNESS:  Mr. Miscavige, Mr. Lyman

           21        Spurlock I believe was there, myself, Vicki Aznaran,

           22        Mr. Cooley, Marty Rathbun.  And we were sitting in the

           23        conference room discussing it.  Mr. Starkey may have

           24        been there, Mr. Norman Starkey.

           25                  THE COURT:  This is when you discussed

                                  KANABAY COURT REPORTERS

                                                   Page 1069

            1        destruction of these records?

            2                  THE WITNESS:  Yes, your Honor.

            3                  THE COURT:  So Mr. Cooley would have heard

            4        this?  Is that what you're saying?

            5                  THE WITNESS:  Yes, your Honor.

            6                  THE COURT:  All right.

            7   BY MR. DANDAR:

            8        Q    And whose idea was it to destroy the records?

            9        A    As best as I can recall, it was Ms. Aznaran that

           10   said, "We have to destroy the folders."  Mr. Miscavige and

           11   everyone else agreed, so that's what was done.

           12        Q    And did the folders contain information that

           13   would hurt the Church of Scientology?

           14        A    Yes, it -- apparently, you know, that's what they

           15   felt.

           16        Q    Okay.

           17                  THE COURT:  That's what you felt too.

           18        Right?  You were there.

           19                  THE WITNESS:  Well, I had actually never

           20        seen Mr. Wollersheim's Preclear folders.  I had never

           21        audited him.

           22                  THE COURT:  But you didn't have a problem

           23        destroying it.

           24                  THE WITNESS:  Correct.

           25   BY MR. DANDAR:

                                  KANABAY COURT REPORTERS

                                                   Page 1070

            1        Q    And why didn't you have a problem destroying his

            2   records?

            3        A    Because, like every good Scientologist, you have

            4   to protect Scientology.  You have to protect the integrity

            5   of Scientology, its leadership, so that it would carry on

            6   because it's the greatest good.  Scientologists believe

            7   that Scientology is man's only answer to freedom.

            8        Q    Now, did you have to understand -- I'm sorry.

            9   Did I interrupt you?

           10        A    No, go ahead.

           11        Q    Did you understand at any point in time there was

           12   actually a court order to produce the entire PC folders of

           13   Mr. Wollersheim after the Church only produced a little bit

           14   of it?

           15                  MR. WEINBERG:  Objection, relevancy.  He's

           16        already -- and beyond the scope and all that --

           17                  THE COURT:  Sustained.

           18                  MR. WEINBERG:  -- other stuff.

           19                  THE COURT:  I'm sustaining it as beyond the

           20        scope.

           21                  MR. DANDAR:  Okay.  Well --

           22                  THE COURT:  I mean, frankly, I think we've

           23        already been over this.

           24                  MR. WEINBERG:  I do too.  That's why I

           25        objected.

                                  KANABAY COURT REPORTERS

                                                   Page 1071

            1                  THE COURT:  I don't need to hear it several

            2        times.

            3   BY MR. DANDAR:

            4        Q    Well, Mr. Prince --

            5                  MR. WEINBERG:  Just so it's clear, our

            6        position is no PC folders were destroyed.

            7                  THE COURT:  I understand that.  I understand

            8        that too.

            9                  MR. WEINBERG:  All right.

           10   BY MR. DANDAR:

           11        Q    Did you understand that Mr. Wollersheim was --

           12   did allege that his PC folders were destroyed?

           13                  THE COURT:  I mean, what are we using --

           14                  MR. DANDAR:  I'm sorry.

           15   BY MR. DANDAR:

           16        Q    Let me ask you this question.  This is what I'm

           17   leading up to.  Mr. Prince, you said that you lied in your

           18   deposition in the Yanny vs. RTC case?

           19        A    Correct.

           20        Q    And you said you sat in this meeting where

           21   Mr. Miscavige and Mr. Cooley was at this meeting where a

           22   decision was made to destroy evidence of PC folders of

           23   Mr. Wollersheim?

           24        A    Correct.

           25        Q    And Mr. Aznaran is the one who actually went out

                                  KANABAY COURT REPORTERS

                                                   Page 1072

            1   to the paper mill and had it pulped?

            2        A    Correct.

            3        Q    And you did that because you were being loyal to

            4   the Church of Scientology?

            5        A    Correct.

            6                  MR. WEINBERG:  Objection.

            7                  THE COURT:  It's irrelevant.  Besides that,

            8        you're doing the testimony, and he's just saying yes.

            9        You need to ask him, Why did you do that?

           10                  MR. DANDAR:  And he's answered that.

           11                  THE COURT:  Yes, he has.

           12                  MR. DANDAR:  I want to skip -- the question

           13        is this.

           14   BY MR. DANDAR:

           15        Q    Mr. Prince, are you testifying for the Estate of

           16   Lisa McPherson or for me because you're loyal to the

           17   Estate, to the cause, or to Ken Dandar?

           18        A    No.  I'm testifying because it's the right thing

           19   to do.  It's very difficult to divine truth from -- I'm not

           20   trying to be vicious here, but it's very difficult to

           21   divine truth from Scientology.  People that are currently

           22   working on this case, they'll do anything they can to

           23   obstruct it.  They'll do anything they can to make sure --

           24                  MR. WEINBERG:  Objection, your Honor.

           25        A    -- that you can't find out the truth, and --

                                  KANABAY COURT REPORTERS

                                                   Page 1073

            1                  MR. WEINBERG:  He's going on and on and on.

            2        A    -- that's why I do that.

            3                  MR. WEINBERG:  Objection.  He was asked a

            4        leading question, Are you testifying because you were

            5        loyal to the --

            6                  THE COURT:  Actually, that wasn't leading

            7        because his answer was no.

            8                  MR. WEINBERG:  Well, I understand he said

            9        no.  Now he's going off into some big explanation.

           10                  THE COURT:  That's true.  If you want to ask

           11        him why are you testifying, then he can go on with his

           12        explanation.

           13   BY MR. DANDAR:

           14        Q    All right.  Why are you testifying in this

           15   hearing?

           16        A    To give justice and equity a chance -- a fair

           17   chance, to give all the information, to be able to give the

           18   full view of what's going on.  You know, I think it would

           19   be fair -- it's only fair that the whole picture is seen.

           20        Q    Mr. Prince, Mr. Minton and Stacy Brooks offered

           21   to continue to pay you $5,000 a month if you, quote, went

           22   down the road with them, close quote, and lied.  Isn't that

           23   true?

           24        A    I was promised a lot more than that.

           25        Q    What else were you promised to lie?

                                  KANABAY COURT REPORTERS

                                                   Page 1074

            1        A    Retirement.

            2        Q    Did they go into any specific details?

            3        A    Financial security that will retire me for the

            4   rest of my life.

            5        Q    Any dollar figures discussed?

            6        A    A quarter of a million.  That's normally what

            7   Mr. Minton does when he gives people money.

            8        Q    Would a quarter of a million be enough?

            9        A    For me to retire for the rest of my life?  No.  I

           10   think I'm too young.  I would need more.  I would have to

           11   need more.

           12        Q    And is there any doubt in your mind that

           13   Mr. Minton and Ms. Brooks proposed this to you, to lie,

           14   that they knew that they wanted you to lie?

           15        A    Absolutely.  They knew they were lying.  They

           16   knew we all had to lie.  I mean, this is the only thing

           17   that they felt they could do to end it, disengage, to be

           18   done with it.  I mean, there's only so long you can wrestle

           19   with this demon.

           20        Q    Okay.

           21                  THE COURT:  And you don't need,

           22        Mr. Weinberg, when it's your turn, to get up and

           23        respond to that.  It's for money, he testified.  So I

           24        understand where both of you all are coming from here.

           25                  MR. WEINBERG:  I wasn't even going to make

                                  KANABAY COURT REPORTERS

                                                   Page 1075

            1        that point.

            2                  MR. DANDAR:  Well --

            3                  MR. WEINBERG:  One short point on that.

            4                  THE COURT:  Well, I saw you getting --

            5        fuming, and I was thinking, "Oh, dear."

            6                  MR. WEINBERG:  I was thinking about all the

            7        calls I have to return.

            8   BY MR. DANDAR:

            9        Q    Mr. Prince, when you and I met at the mall with

           10   Mr. Lirot, Mr. Haverty, and your fiance and you wrote out

           11   what's attached to your declaration, the handwritten note

           12   of April 14th, 2002, did I promise you money at all?

           13        A    None at all.  Money wasn't even discussed.

           14        Q    Did I pay you any money for writing that note?

           15        A    Absolutely not.

           16        Q    Did I promise to pay you money in the future if

           17   you wrote that note?

           18        A    No, you did not.

           19        Q    And isn't it true or -- what's the reason why I

           20   gave you a retainer of 4,000?

           21        A    Because my time is as valuable as anyone else's.

           22        Q    And you've been working on this -- this hearing

           23   preparing documents for me?

           24        A    Correct.

           25                  THE COURT:  You are back now as Mr. Dandar's

                                  KANABAY COURT REPORTERS

                                                   Page 1076

            1        consultant?  Is that it?

            2                  THE WITNESS:  Yes, your Honor.

            3                  THE COURT:  And expert?

            4                  THE WITNESS:  Yes, your Honor.

            5                  THE COURT:  Okay.

            6   BY MR. DANDAR:

            7        Q    I certainly haven't promised you any retirement

            8   money, have I?

            9        A    No, you have not.

           10                  MR. WEINBERG:  Your Honor, could we have a

           11        direct question instead of a leading question?

           12                  THE COURT:  Sustained.

           13   BY MR. DANDAR:

           14        Q    Now, Mr. Prince, when you were in LMT, did you

           15   know that the -- and if I asked this, I'll -- I don't

           16   remember asking this -- do you know whether or not the LMT

           17   received an anonymous $300,000 from Clambake?

           18                  MR. WEINBERG:  Your Honor, this is beyond

           19        the scope.  I didn't ask about it.

           20                  THE COURT:  It's beyond the scope.  The

           21        truth of the matter is, rather than recall, if this is

           22        an area that he thinks is important, I'm going to let

           23        him get into it.

           24                  MR. WEINBERG:  All right.

           25   BY MR. DANDAR:

                                  KANABAY COURT REPORTERS

                                                   Page 1077

            1        Q    Did you know that they got money from Clambake?

            2        A    The only -- you know, I found out about that --

            3                  MR. WEINBERG:  Your Honor, could he just

            4        answer the question?

            5                  THE WITNESS:  I'm trying to answer the

            6        question.

            7                  THE COURT:  Counsel, just let it go, would

            8        you?

            9                  MR. WEINBERG:  Okay.

           10                  THE COURT:  We need to get through this.

           11                  MR. WEINBERG:  All right.

           12        A    I found out about that whole deal with money

           13   coming from wherever it came from when Teresa Summers wrote

           14   her resignation letter to Stacy Brooks and I read it, where

           15   that was mentioned.

           16                  THE COURT:  So the truth -- you did not know

           17        about the 300,000, who it came from.  Mr. Minton never

           18        discussed this with you --

           19                  THE WITNESS:  Correct, correct.

           20                  THE COURT:  -- is that right?

           21                  THE WITNESS:  That's right.

           22   BY MR. DANDAR:

           23        Q    And did you ever -- while you were with LMT, did

           24   you ever hear the phrase "the fat man"?

           25        A    No.

                                  KANABAY COURT REPORTERS

                                                   Page 1078

            1        Q    Okay.  Now, with this Key West fishing trip in

            2   the summer of 1999, as best I can phrase that, you had

            3   already been working for me for a few months, correct?

            4        A    Correct.

            5        Q    Now, the other people that showed up down in Key

            6   West, like Mr. Ford Greene, is that someone that you had

            7   ever seen me with before that fishing trip?

            8        A    No.

            9        Q    Did I go on the fishing trip?

           10        A    No, you did not.

           11        Q    Did I stay with you and Mr. Leipold and

           12   Mr. Greene and Mr. Haverty?

           13        A    No.

           14        Q    Oh, in that release that's in evidence,

           15   Defendant's Exhibit No. 231, that release language says

           16   that you are conceding or admitting that you were not

           17   harmed by the Church of Scientology.  Do you have any

           18   reason to know why that was put in your release?

           19        A    Yes.  That was put in the release for the same

           20   reason that Scientologists are asked to lie.  It's to

           21   protect Scientology at all costs.

           22        Q    Now, Mr. Weinberg asked you on cross if you had

           23   any personal knowledge of whether or not David Miscavige

           24   was physically at the Fort Harrison Hotel while Lisa

           25   McPherson was there in November and December of '95.  Do

                                  KANABAY COURT REPORTERS

                                                   Page 1079

            1   you remember that?

            2        A    Yes.

            3        Q    Mr. Prince, would it matter where David Miscavige

            4   was physically located as to whether or not he would have

            5   knowledge and was personally involved with the care and

            6   treatment of Lisa McPherson?

            7        A    In my opinion, no.

            8        Q    Why not?

            9        A    Well, with the state of technology today, it

           10   makes no difference whatsoever.  But also, based on past

           11   experience that I have had with Mr. Miscavige during the

           12   Wollersheim case, we were really just a short distance

           13   away, and while the hearings were going on, people were

           14   calling and reporting all the time.  There's no problem of

           15   getting an on-the-ground report immediately in any place in

           16   Scientology for Mr. Miscavige.

           17                  THE COURT:  It is your opinion -- I'm sure

           18        you've probably testified to this, but I can't

           19        remember.  I've heard from several people.  It is your

           20        opinion that Mr. Miscavige was kept advised at all

           21        times of Lisa McPherson and her situation.

           22                  THE WITNESS:  Your Honor, it is my opinion

           23        that once the situation where she got out of the car

           24        and was admitted to the hospital and it became a

           25        matter for Office of Special Affairs' concern, then he

                                  KANABAY COURT REPORTERS

                                                   Page 1080

            1        was -- he knew about it.

            2                  THE COURT:  Was it your opinion while she

            3        was admittedly PTS-III, undergoing introspection

            4        rundown, he would be kept advised of this and the

            5        progress?

            6                  THE WITNESS:  Yes, your Honor.

            7                  THE COURT:  Or lack of progress?

            8                  THE WITNESS:  Yes, your Honor.

            9   BY MR. DANDAR:

           10        Q    Now, Mr. Weinberg asked you to --

           11                  THE COURT:  And that opinion comes from your

           12        having been around him when he was head of RTC?

           13                  THE WITNESS:  Yes, your Honor.

           14                  THE COURT:  Or ASI?

           15                  THE WITNESS:  Both.

           16                  THE COURT:  Okay.

           17                  THE WITNESS:  Yes, your Honor.

           18                  THE COURT:  When Mr. Hubbard was alive and

           19        was the head ecclesiastical leader of the Church,

           20        would he have been kept advised of PTS Type III

           21        introspection rundown?

           22                  THE WITNESS:  He would have taken it over

           23        and dealt with it himself.

           24                  THE COURT:  My question is, Would he have

           25        been kept advised?

                                  KANABAY COURT REPORTERS

                                                   Page 1081

            1                  THE WITNESS:  Yes, your Honor.

            2                  THE COURT:  Wherever it was being conducted?

            3                  THE WITNESS:  Well, in all honesty, your

            4        Honor, I have to answer this and say that towards the

            5        end of Mr. Hubbard's life --

            6                  THE COURT:  Forget when folks say he was

            7        mad.  I understood that.

            8                  THE WITNESS:  Oh, okay.

            9                  THE COURT:  When he was in charge of the

           10        Church and head ecclesiastical leader, would he have

           11        been kept advised of that type of situation, with

           12        either a public or staff member of Scientology?

           13                  THE WITNESS:  Absolutely, your Honor.

           14                  THE COURT:  Is there any question in your

           15        mind whatsoever about that?

           16                  THE WITNESS:  None whatsoever.  He would

           17        have taken it over and did it himself.

           18   BY MR. DANDAR:

           19        Q    Now, Mr. Weinberg asked you to admit that there's

           20   no written policy in the Church of Scientology to go out

           21   and kill somebody, and you said that's true.  Do you recall

           22   that?

           23                  THE COURT:  I'm sorry, what's that?

           24   BY MR. DANDAR:

           25        Q    There's no written policy in the Church of

                                  KANABAY COURT REPORTERS

                                                   Page 1082

            1   Scientology to go and kill somebody.

            2        A    Well, there's one thing that came into evidence

            3   here.  It was the SP declare of -- I think I read down the

            4   list.  It was maybe eight people.  And in that --

            5                  THE COURT:  I'm sorry, what came into

            6        evidence?  The, what, SP?

            7                  THE WITNESS:  Yes, your Honor.  It was an SP

            8        declare.  It was a single sheet of a paper by L. Ron

            9        Hubbard declaring -- I think it was eight people

           10        suppressive persons and declared them fair game.  And

           11        then on one of the lines, L. Ron Hubbard gave

           12        instructions whereby he said any Sea Org member

           13        encountering any of the above persons is to use

           14        process R245 on them.  Process R245 --

           15                  MR. WEINBERG:  Your Honor --

           16                  THE WITNESS:  -- is a process --

           17                  MR. WEINBERG:  -- your Honor, objection.

           18        This was the document that was not admitted that

           19        Mr. Prince is now testifying about.  It was the phony

           20        document.

           21                  MR. DANDAR:  Phony --

           22                  MR. WEINBERG:  And this is way beyond the

           23        scope of my cross-examination.

           24                  THE COURT:  It's not beyond the scope

           25        because you made it clear there's absolutely no basis

                                  KANABAY COURT REPORTERS

                                                   Page 1083

            1        upon which to make the assertions that he has.  Now,

            2        if he has a basis, he would be permitted to testify.

            3        So it's not beyond the scope.

            4                  MR. WEINBERG:  This document that he's

            5        talking about is not in evidence.

            6                  THE COURT:  All right.  If that's true, then

            7        he can't refer to that document.

            8                  MR. DANDAR:  Okay.  I thought it was.

            9                  THE COURT:  Well, go find it.  Let's take a

           10        break and we'll see whether it is or not.  I couldn't

           11        begin to tell you what documents are in and what ones

           12        aren't.  But the clerk would have them, whether they

           13        were admitted or not.

           14                  MR. DANDAR:  Right.  Before we take a break,

           15        let me ask one more question.

           16                  THE COURT:  All right.

           17   BY MR. DANDAR:

           18        Q    In your tenure at the Church of Scientology, did

           19   you ever see anything in writing called R245?

           20        A    Yes.  It actually comes from a tape lecture.  And

           21   I forget which tape lecture it was specifically, but it

           22   talks about R245 being an effective exteriorization

           23   process, whereby the person takes a .45, puts it to his

           24   head -- a loaded .45, puts it to his head, pulls the

           25   trigger, and blows their brains out.  That releases the

                                  KANABAY COURT REPORTERS

                                                   Page 1084

            1   spirit from the body.

            2        Q    Is that a lecture by -- who?

            3        A    L. Ron Hubbard.

            4                  MR. DANDAR:  All right.  Let's take our

            5        break and let me find that.

            6                  THE COURT:  All right.  It's 25 after.

            7        We'll take 15 minutes.

            8                  (A break was taken at 10:25 a.m. until

            9                  approximately 10:55 a.m.)

           10                  THE COURT:  All right.  Where is Mr. Prince?

           11                  THE WITNESS:  I'm here, your Honor.

           12                  THE COURT:  You may resume the stand.

           13                  You all may be seated.

           14                  And, Mr. Dandar, did you find whether that

           15        was in or out of evidence?

           16                  MR. DANDAR:  It was out.  And for the

           17        clerk's benefit, I still have it, so make sure I give

           18        it back to her.  Somewhere.  It's on my table.

           19                  Here it is.  I have this tendency of walking

           20        away with exhibits.

           21                  THE COURT:  Are we having a light show?

           22                  MR. DANDAR:  They had a TV or a signal that

           23        keeps coming in.  We started to watch a soap opera

           24        there for a minute.

           25                  THE COURT:  I see.

                                  KANABAY COURT REPORTERS

                                                   Page 1085

            1                  MR. DANDAR:  But I have a videotape of a

            2        Boston picket.  And the only reason I want to put this

            3        on is because Mr. Weinberg used Mr. Prince picketing

            4        in his cross-examination.  But this shows what

            5        happened before the clip-it, the snippet, that

            6        Mr. Weinberg showed.

            7                  MR. WEINBERG:  Just so it's clear, this is a

            8        different day than the picket that I showed.  But he

            9        can play it.

           10                  THE COURT:  All right.

           11                  MR. WEINBERG:  Ken (motioning to move).

           12                  THE WITNESS:  It has no audio.

           13                  MR. DANDAR:  Let's stop it.  Because I did

           14        that too.

           15                  MR. WEINBERG:  Do you know the date of this?

           16                  MR. DANDAR:  It's in the beginning of the

           17        tape.  Just a minute, and I'll get everything here.

           18                  (The tape of the picket was played, entitled

           19                  "Boston, September 10th, 1998, unedited."

           20                  As noted below, the tape was not reportable

           21                  and is not transcribed herein.)

           22                  THE COURT:  Isn't that pleasant.

           23                  MR. DANDAR:  Judge, I just put that on to

           24        show you it's not a one-way street.

           25                  THE COURT:  I understand.

                                  KANABAY COURT REPORTERS

                                                   Page 1086

            1                  MR. DANDAR:  Now, Mr. Prince --

            2                  THE COURT:  Madam Court Reporter?

            3                  THE REPORTER:  Yes, ma'am.

            4                  THE COURT:  If you didn't get all that, you

            5        can put in the record -- because this tape can be put

            6        in -- that it was just a lot of shouting and carrying

            7        on and that you did the best you could.

            8                  THE REPORTER:  Thank you very much, your

            9        Honor.

           10                  MR. WEINBERG:  Are you marking that as an

           11        exhibit?

           12                  THE COURT:  Make a copy of it for the

           13        record, because there's no way the court reporter

           14        could be expected to get all that.  Talk about your

           15        proverbial everybody talking at once.

           16                  MR. DANDAR:  That would be impossible to

           17        write down.

           18                  THE COURT:  Yes, it would.

           19                  So I'm sure you did the best you could, but

           20        as far as I'm concerned, it could be basically said

           21        you must see the tape because it's everybody talking

           22        at once and loud and obnoxious.

           23                  MR. DANDAR:  Since Mr. Lirot is bringing in

           24        our next witness, I'm going to mark it as 135A because

           25        he has all of his exhibits premarked --

                                  KANABAY COURT REPORTERS

                                                   Page 1087

            1                  THE COURT:  All right.

            2                  MR. DANDAR:  -- starting with 136.  So the

            3        videotape of Boston, September 10th, '98, is

            4        Plaintiff's 135A.

            5                  MR. WEINBERG:  Plaintiff's 135A.

            6                  MR. DANDAR:  Right.

            7                  MR. WEINBERG:  It was 9/10?

            8                  THE COURT:  9/10/98.

            9                  MR. WEINBERG:  And you received that into

           10        evidence, your Honor?

           11                  THE COURT:  Yes.

           12                  MR. WEINBERG:  Thank you.

           13   BY MR. DANDAR:

           14        Q    Mr. Prince, the people that were engaging you and

           15   Mr. Minton in that picket, where were they from?

           16        A    Office of Special Affairs, Boston.

           17        Q    Now, Mr. Prince, you talked about the taped

           18   lecture series of Mr. Hubbard where he describes R245?

           19        A    Correct.

           20        Q    And have you seen that?

           21        A    I have seen that.

           22        Q    Or heard it, whatever it is.  I don't know what

           23   it is.

           24        A    Yes, I heard it before, read the transcript.

           25                  MR. DANDAR:  Judge, I have a TV -- which I

                                  KANABAY COURT REPORTERS

                                                   Page 1088

            1        believe is a TV interview of Mr. Hubbard where he

            2        talks about this policy that he wrote called R245.

            3                  MR. LIEBERMAN:  Objection, your Honor.  It's

            4        not a policy.  It's a mischaracterization of it.

            5        Again, it mischaracterizes the policy of the Church of

            6        Scientology.

            7                  THE COURT:  Well, if this is a lecture of

            8        Mr. Hubbard, why, what could be objectionable with

            9        Mr. Hubbard --

           10                  MR. LIEBERMAN:  It's the characterization of

           11        it as a policy.

           12                  THE COURT:  All right.  That will be

           13        sustained.

           14                  MR. LIEBERMAN:  The characterization of what

           15        actually was --

           16                  MR. DANDAR:  I apparently misspoke, I'm

           17        sorry.  I'll have Mr. Prince talk about what it is.

           18        As soon as we identify -- this is, I believe,

           19        Mr. Hubbard speaking, so . . .

           20                  THE COURT:  What number is it?

           21                  MR. DANDAR:  Exhibit number?  This will be

           22        135B.

           23                  THE COURT:  Okay.

           24                  MR. WEINBERG:  Could we just ask the

           25        relevance of playing a 1950 speech of L. Ron Hubbard?

                                  KANABAY COURT REPORTERS

                                                   Page 1089

            1                  MR. DANDAR:  If he's objecting because of

            2        the age of the speech, I think it's quite clear that

            3        the age of any document Mr. Hubbard wrote or spoke

            4        about has no significance --

            5                  MR. WEINBERG:  Well --

            6                  MR. DANDAR:  -- in the Church of

            7        Scientology.  Everything remains the same.

            8                  THE COURT:  What is it, though?  I don't

            9        understand.  Is this a --

           10                  MR. WEINBERG:  This is redirect.

           11                  MR. DANDAR:  He brought this up on cross.

           12                  THE COURT:  What did he bring up?

           13                  MR. DANDAR:  Mr. Weinberg brought up on

           14        cross that there's no written policy of the Church of

           15        Scientology about killing somebody.

           16                  THE COURT:  Okay.

           17                  MR. DANDAR:  He objected to that Flag order

           18        because it wasn't properly authenticated.  That's

           19        fine.  It spoke of R245.  There's another publication

           20        we're going to bring in that is current and published

           21        by the Church of Scientology that does mention R245.

           22                  MR. WEINBERG:  What I had asked, just so

           23        it's clear, was there any policy to kill somebody, and

           24        he said no.  But secondly --

           25                  THE COURT:  I'm going to allow it, Counsel.

                                  KANABAY COURT REPORTERS

                                                   Page 1090

            1        Overruled.

            2                  I hope this isn't terribly long.  Is it?

            3                  MR. DANDAR:  It is.  I think it's

            4        35 minutes.

            5                  THE COURT:  I'm not going to listen to

            6        35 minutes.

            7                  MR. DANDAR:  All right.  Maybe -- what I

            8        would like to do over lunch is go down right to the

            9        specific area.

           10                  MR. LIEBERMAN:  Well, your Honor, you see,

           11        that's the problem.  I understand your Honor doesn't

           12        want to listen to 35 minutes.  You shouldn't have to

           13        listen to 35 minutes.  But you cannot take a speech

           14        and say this is a religious policy and take two

           15        minutes out of an entire lecture about religious

           16        matters and then play it and pretend that that gives

           17        you any idea as to the context of what's going on.

           18                  THE COURT:  All right.  I'll listen to the

           19        whole thing.

           20                  MR. LIEBERMAN:  I don't want -- I'm not

           21        urging you.

           22                  MR. DANDAR:  Let's do this after lunch.  Is

           23        that all right?

           24                  THE COURT:  All right.  Let's do it about

           25        4 o'clock.

                                  KANABAY COURT REPORTERS

                                                   Page 1091

            1                  MR. DANDAR:  Okay.

            2                  THE COURT:  All right.  We'll do it after

            3        lunch.

            4                  MR. DANDAR:  I hope Mr. Prince is still not

            5        on the stand by 4 o'clock.  In fact, I think he should

            6        be over quite soon.

            7   BY MR. DANDAR:

            8        Q    Now, talking about policies of the Church of

            9   Scientology, Mr. Prince, are you familiar with the

           10   additional steps in evidence, the policy of additional

           11   steps of an introspection rundown, where Mr. Hubbard writes

           12   that the introspection rundown can be deadly?

           13        A    Yes.

           14        Q    Are you familiar with search and discovery, the

           15   PSSSP course, where it states that some psychotics cannot

           16   be kept alive?

           17        A    Yes, I am.

           18        Q    How do you audit someone who is unconscious?

           19        A    Well, I can tell you a process.  If a person is

           20   laying unconscious on a bed, you simply give them a

           21   command, "Give me that hand," and then you actually execute

           22   that command by taking a person's hand and putting it in

           23   your hand.  And once you do that, you say, "Thank you."

           24   And then you put the hand back and say, "Give me that

           25   hand."  And you do that repeatedly, over and over.

                                  KANABAY COURT REPORTERS

                                                   Page 1092

            1        Q    Now, Mr. Weinberg asked you about the Teresita

            2   introspection rundown that you participated in -- is it

            3   Soboba?

            4        A    Soboba Indian Reservation.

            5        Q    Okay.  Is that -- was your experience in that

            6   introspection rundown similar to what Lisa McPherson

            7   experienced?

            8        A    I don't think so.

            9        Q    What were the differences?

           10                  MR. WEINBERG:  Excuse me, your Honor.  "What

           11        were the differences," I mean, he doesn't have any

           12        personal knowledge --

           13                  THE COURT:  No, but I assume as consultant

           14        he read all of the depositions of those who did.  So I

           15        suspect he can testify about that.

           16                  MR. WEINBERG:  Okay.

           17                  THE COURT:  Did you read the -- did you read

           18        the depositions or the statements --

           19                  THE WITNESS:  Yes, your Honor.

           20                  THE COURT:  -- from the persons who were

           21        attending Lisa McPherson?

           22                  THE WITNESS:  Yes, and I read the notes as

           23        well.

           24                  MR. WEINBERG:  On direct, he already did

           25        that.  I didn't ask him to -- not -- to do anything

                                  KANABAY COURT REPORTERS

                                                   Page 1093

            1        different on cross, and now Mr. Dandar is asking him

            2        to do the same thing that he did on direct.

            3                  THE COURT:  I don't recall this on direct.

            4        Overruled.

            5                  MR. WEINBERG:  All right.

            6   BY MR. DANDAR:

            7        Q    Go ahead.  What is the differences?  What are the

            8   differences?

            9        A    The difference being number one that Teresita was

           10   a staff member.  Mrs. McPherson was a paying Scientology

           11   public.  Teresita had no intentions of leaving staff or

           12   departing from Scientology.  Lisa McPherson did.

           13             Beyond that -- and, again, there's so many

           14   records.  I mean, it's stated that she was on the

           15   introspection rundown.  Yet there is no program, there is

           16   no evidence, there's no invoice, there's no running form,

           17   there's none of those things in evidence that would be in

           18   evidence if a person was on an introspection rundown in

           19   fact.

           20             And -- but as far as the manifestations of

           21   wanting to get out of the room that she was locked in,

           22   there's certainly similarities there.  But those are some

           23   of the differences.

           24        Q    When -- to your knowledge, your personal

           25   knowledge with Teresita, did people talk to Teresita?

                                  KANABAY COURT REPORTERS

                                                   Page 1094

            1        A    Yes.

            2        Q    And -- during the entire introspection rundown?

            3        A    I mean, no one held long conversations with her.

            4   But just basic civility.  You know, you walk in a room and

            5   you see a person, you say hi.  The person says something to

            6   you.  You either acknowledge or answer the questions.  You

            7   know, simple things like that.

            8        Q    Did you have to assist in any way or did you see

            9   others assist in any way Teresita in drinking water?

           10        A    Yes.

           11        Q    How did they do it?

           12        A    Sit down next to her with a glass of water with

           13   ice and a straw and sometimes they put -- the girls would

           14   do it, and I would do it, you know, put your arm around

           15   her.  Teresita seemed to like that.  She was very childlike

           16   at times.  And hold the straw to her face, and she would

           17   drink through the straw.  When she would stop, you know,

           18   you would tell her:  "You just need to drink a little bit

           19   more water because it's good for you.  It's hot out here;

           20   it's the desert.  Be a good girl.  Drink a little bit

           21   more."  And she would drink it.

           22        Q    And did you ever see her do that, as time went on

           23   in her introspection rundown, where she wouldn't drink

           24   water on her own?

           25        A    Yes.  But I certainly wouldn't have any way of

                                  KANABAY COURT REPORTERS

                                                   Page 1095

            1   making her drink water if she didn't want to drink it.

            2        Q    Okay.  What I'm saying is, did you ever observe

            3   her just pick up, without being coached or coaxed, pick up

            4   a glass of water or bottled water and just drink it by

            5   herself?

            6        A    Oh, sure.

            7        Q    Was that in the beginning, the middle, or the

            8   end, or throughout?

            9        A    You know, with Teresita, I don't think the water

           10   was so much an issue because it -- at a point in time she

           11   wasn't aware of it, but as she went through introspection

           12   and we sat with her and made her drink it, that she came to

           13   understand that it was part of the routine, that she had to

           14   drink X amount of water every day or, you know, during

           15   certain time periods.

           16        Q    You said Mr. Hubbard's doctor, Dr. Denk, came to

           17   see her?

           18        A    Yes, he did.

           19        Q    How many times?

           20        A    Once that I know of.

           21        Q    And he administered something to her?

           22        A    Yes, he did.

           23        Q    All right.  After he left, did he leave any

           24   medicine behind or something for others to administer to

           25   her?

                                  KANABAY COURT REPORTERS

                                                   Page 1096

            1        A    Yes.  There were some pills.

            2        Q    Do you know what they were?

            3        A    I do not.  I do not recall what they were.

            4        Q    All right.

            5        A    But I know they were to make her sleep.

            6        Q    Okay.  Did he leave instructions with people how

            7   often to give that?

            8        A    Yes, he did.  I think we were to break the

            9   tablets in half, to not give her a strong dose, or even

           10   lesser amounts and crush it up and mix it in with a protein

           11   drink.

           12        Q    Do you know of any licensed medical doctor who

           13   came in to see Lisa McPherson?

           14        A    No, I do not.

           15        Q    Do you know if Teresita received a medical

           16   examination by a licensed medical doctor before or

           17   during -- outside of Dr. Denk?  Well, let me start -- that

           18   was a terrible question.

           19             In addition to giving Teresita prescription

           20   drugs, did Dr. Denk examine her?

           21        A    Yes, he did.  He looked in her eyes, looked in

           22   her ears, checked her mouth, you know, pressed certain

           23   areas of her body to see if it was sore or she would react,

           24   check their feet, check their arms, check their back, check

           25   their neck.

                                  KANABAY COURT REPORTERS

                                                   Page 1097

            1        Q    Okay.  Was anything else done as far as the

            2   medical exam outside of what you just said?

            3        A    Not -- no, not -- I don't think so.

            4        Q    Okay.  Now, you mentioned on cross-examination

            5   meeting with me and preparing that handwritten note that's

            6   dated April 14th, 2002, the past year, a typed affidavit.

            7   Why did you prepare a handwritten note?

            8        A    I felt it was important to preserve in some

            9   fashion what I had discussed with you, what had been going

           10   on.  And since I had plans to investigate it further, in

           11   case something happened to me when I went off to see those

           12   people that at least there would have been something left

           13   written by me that would have indicated something was going

           14   on.

           15        Q    Now, the day that you prepared that written

           16   statement, that was the night you were supposed to meet

           17   with Mr. Rinder?

           18        A    Correct.

           19        Q    Did I assist you at all in preparing that written

           20   statement?

           21        A    No, you did not.

           22        Q    In fact, you purposely went away from me --

           23                  MR. WEINBERG:  Objection as to the form,

           24        your Honor.

           25                  THE COURT:  Sustained.

                                  KANABAY COURT REPORTERS

                                                   Page 1098

            1   BY MR. DANDAR:

            2        Q    All right.  How close were you to me when you

            3   wrote that document?

            4        A    I separated myself and went to a different table

            5   and did the document.

            6        Q    Okay.  Now, in that affidavit that you

            7   prepared -- you typed that all by yourself, correct?

            8        A    Correct.

            9                  THE COURT:  Which affidavit are we talking

           10        about?

           11                  MR. DANDAR:  The --

           12                  THE COURT:  The last one?

           13                  MR. DANDAR:  The last one, April 2002, that

           14        was actually executed --

           15                  THE WITNESS:  May 1st.

           16                  MR. DANDAR:  -- May 1st.

           17                  THE COURT:  What was the date of the last

           18        visit with Mr. Minton, Ms. Brooks?  What was the date?

           19                  MR. DANDAR:  What was the date?  Was it that

           20        Sunday?

           21                  THE WITNESS:  Yes, it was a Sunday.

           22                  THE COURT:  The 14th.

           23                  MR. DANDAR:  The 14th of April.

           24   BY MR. DANDAR:

           25        Q    Now, in that affidavit, Mr. Weinberg pointed out

                                  KANABAY COURT REPORTERS

                                                   Page 1099

            1   on cross that you put in the wrong date.  You put in August

            2   of 2001, and Mr. Minton told you on the top of the garage

            3   about his last check to me of 500,000?

            4        A    Correct.

            5        Q    As you sit here today, what are you positive

            6   about in reference to that conversation with Mr. Minton?

            7        A    Everything that I've testified to.

            8        Q    When did it take place?

            9        A    It took place -- you know, I can't say the exact

           10   month, you know.  I'm sorry, I wish I could do better with

           11   that.  But I know it was very warm.  I know that

           12   specifically it was a $500,000 check.

           13        Q    If I told you to assume that Mr. Minton only

           14   delivered to me one check for $500,000, was this

           15   conversation with Mr. Minton before or after he delivered

           16   the check?

           17        A    After.

           18        Q    And do you have any idea if it was before or

           19   after he gave a deposition in May of 2000?

           20        A    No, I have no idea.

           21        Q    Okay.  Now, you mentioned that, when you met with

           22   Mr. Minton after he testified before Judge Baird on

           23   April 9th, you then telephoned Frank Oliver?

           24        A    Correct.

           25        Q    To ask Frank Oliver to call me to have me call

                                  KANABAY COURT REPORTERS

                                                   Page 1100

            1   you?

            2        A    Correct.

            3        Q    Why did you go through that circuitous route?

            4                  MR. WEINBERG:  Objection, because he did --

            5        I asked him the same question, why did you do that,

            6        and he explained it.

            7                  THE COURT:  I think it's been asked and

            8        answered.

            9   BY MR. DANDAR:

           10        Q    Okay.  Why did you feel your home was bugged?

           11        A    Because a person that was hired by Scientology, a

           12   private investigator named David Amos, contacted me here in

           13   Clearwater, and I went to visit with him in Memphis,

           14   Tennessee, and he told me --

           15                  MR. WEINBERG:  Objection.  That's hearsay,

           16        your Honor, whatever -- he had some conversation with

           17        some guy David Amos.

           18                  THE COURT:  It's not introduced as to the

           19        truth of the matter asserted.  It's basically as to

           20        why he thought his house was bugged, not because it

           21        was bugged.

           22                  MR. WEINBERG:  Well, then he had a

           23        conversation.  We shouldn't get into the details of

           24        the conversation, should we?  Isn't that just hearsay?

           25                  MR. DANDAR:  It's an exception.

                                  KANABAY COURT REPORTERS

                                                   Page 1101

            1                  THE COURT:  I think it's an exception.  One

            2        of the exceptions I don't really understand.  I'm

            3        going to allow it.

            4        A    Mr. David Amos informed me that he had been hired

            5   by the Church of Scientology to surveil me, do surveillance

            6   on me, and to -- what he was looking for, he told me, was

            7   that he had been briefed by his Scientology handlers in Los

            8   Angeles that Mr. Minton and I were involved in child

            9   slavery and we were -- had child slaves that we were

           10   running around different countries.  And Mr. Amos had a

           11   street ministry.  He's a very Christian man, and he has a

           12   street ministry where he helps abused children.

           13                  THE COURT:  I don't need to hear about all

           14        that.

           15                  THE WITNESS:  Okay.

           16                  THE COURT:  I need to hear why you thought

           17        your house was bugged.

           18        A    Anyway, he told me that he was specifically hired

           19   to bug my house in Chicago, and when I moved from Chicago

           20   to Clearwater, that he was hired to do the same there.  And

           21   he agreed to come out and show me how he did it and where

           22   he did it.  And I sent him plane tickets and I sent him

           23   money to come out to do that.  And at the last minute, he

           24   got cold feet and didn't do it.  But I did report it to the

           25   FBI, the entire incident.

                                  KANABAY COURT REPORTERS

                                                   Page 1102

            1   BY MR. DANDAR:

            2        Q    Did you go out and visit Mr. Amos?

            3        A    Excuse me?

            4        Q    Did you actually meet with Mr. Amos?

            5        A    Yes, I did.

            6                  MR. WEINBERG:  Could we get a date of this

            7        alleged conversation?

            8                  THE COURT:  You can when it's your turn.  I

            9        don't care if it's true.  As far as I'm concerned,

           10        it's only why he thought his house was bugged.

           11                  MR. WEINBERG:  All right.  That's fine.

           12                  THE COURT:  Which is an explanation as to

           13        why he didn't call from his house, which is all that's

           14        relevant to this.

           15                  MR. WEINBERG:  But the testimony, of course,

           16        is that he did call from the house.  He got the call

           17        at the house anyway.  That's what he said.

           18   BY MR. DANDAR:

           19        Q    Did you go to see Agent Strope of the FDLE before

           20   or after you went to Dennis deVlaming's office?

           21        A    After.

           22        Q    And did you go to Dennis deVlaming's office

           23   before or after you met me at the mall on April 14th?

           24        A    Before.  I did that the day of the testimony --

           25                  THE COURT:  He's already testified about

                                  KANABAY COURT REPORTERS

                                                   Page 1103

            1        this.

            2                  MR. DANDAR:  Okay.  I wasn't clear.  Okay.

            3        All right.  And I believe . . .

            4                  Your Honor, that's all the questions I have.

            5        I just want to be able to ask Mr. Prince a question

            6        based upon this videotape that I want to play of

            7        Mr. Hubbard.

            8                  THE COURT:  Well, go on ahead and play it

            9        now.  It's a good time to do it.

           10                  MR. DANDAR:  Okay.  And I'm going to tell

           11        you in advance, Judge, I haven't seen this tape

           12        before.  So I'm going to play it.  It's represented to

           13        me as being Mr. Hubbard talking about this R245.

           14                  THE COURT:  Well, Lord, let's hope there's

           15        something in there about it, something that's

           16        relevant.

           17                  MR. DANDAR:  That's why I prefer not to do

           18        it right now.  Let me --

           19                  MR. WEINBERG:  Could he possibly hand it to

           20        us, see if we can identify it?

           21                  MR. DANDAR:  This is a copy of a copy.  This

           22        is not --

           23                  THE COURT:  You couldn't identify it.

           24                  MR. WEINBERG:  I thought it might be

           25        something he had purchased.

                                  KANABAY COURT REPORTERS

                                                   Page 1104

            1                  THE COURT:  No.

            2                  MR. DANDAR:  No.

            3                  MR. WEINBERG:  Okay.

            4                  THE COURT:  I don't want to leave here at

            5        11:30 if you've got 35 minutes of tape you're going to

            6        play.  Are you done with Mr. Prince?

            7                  MR. DANDAR:  Except for this.

            8                  THE COURT:  All right.  Well, put it in.

            9        Maybe Mr. Prince will let us know.  I mean, I don't

           10        know what Mr. Hubbard --

           11                  MR. WEINBERG:  Could we just ask -- where

           12        did Mr. Minton -- Dandar get this, is all I'm asking.

           13                  MR. DANDAR:  This is an interview of

           14        Mr. Hubbard from a Granada TV station.

           15                  THE COURT:  It really doesn't matter how he

           16        got it.  He doesn't ask you how you got your stuff.

           17                  MR. WEINBERG:  No, no.  I thought that this

           18        was the original lecture, but this is just a -- this

           19        is actually just an interview, not the lecture.

           20                  MR. DANDAR:  This is an interview --

           21                  THE COURT:  We'll see what it is, Counselor.

           22        Sit down.

           23                  MR. WEINBERG:  All right.  That's fine.

           24                  MR. LIEBERMAN:  At the expense of your

           25        Honor, I just want to point out that television can't

                                  KANABAY COURT REPORTERS

                                                   Page 1105

            1        possibly be policy letter of the Church of

            2        Scientology.

            3                  MR. DANDAR:  We didn't say it was a policy

            4        letter.  It's a lectured -- of a tape lecture of

            5        Mr. Hubbard.

            6                  And I don't know where this is taking me

            7        now.

            8                  MR. LIEBERMAN:  It's not a lecture, you

            9        said.  It was a television interview.

           10                  MR. DANDAR:  Well, we'll see.

           11                  THE COURT:  Surely you don't all care if we

           12        watch Mr. Hubbard here for 35 minutes, do you?  Then I

           13        wish you would sit down and let us watch it.

           14                  (The tape from Granada television was played

           15                  as follows.)

           16                  THE NARRATOR:  Tonight, Well in Action has

           17        tracked down one of the most elusive men on earth.

           18        This was the end of our search, an ex-(unintelligible)

           19        for Royal Scotland, docked at (unintelligible --

           20        Deserta?), a small port in North Africa.

           21                  On board about 250 people, may be some sort

           22        of a crew, and this mysterious man.  (Unintelligible)

           23        screen man thought he was a great scientist when

           24        (unintelligible).  Everybody seems to think he's a

           25        millionaire.

                                  KANABAY COURT REPORTERS

                                                   Page 1106

            1                  These are no ordinary seamen.  Their

            2        allegiance and devotion to the mysterious man is

            3        total.  To them, he is My Commodore.  The man is

            4        L. Ron Hubbard, charmer, science fiction writer, and

            5        showman, the creator of Scientology, and the man who

            6        is pushing it into its new, more militant phase.  He

            7        now requires that his crew must have training in judo

            8        and weaponry and must be ethically beyond reproach,

            9        tough, formidable, and effective.  To them he's a

           10        soldier.

           11                  One of them wrote:  "That which I have

           12        really found is the nearness to the greatness, which

           13        is Ron, our founder --"

           14                  (The tape was interrupted.)

           15                  THE COURT:  Stop this for a minute.

           16                  (Continuing with tape.)

           17                  THE NARRATOR:  "-- he, above all, My

           18        Commodore --"

           19                  (The tape was stopped.)

           20                  THE COURT:  I don't know what this is, but

           21        this is not Mr. Hubbard talking.

           22                  MR. PRINCE:  There's a little preamble, if

           23        you will, like a little introductory -- this is an

           24        interviewer talking, and then Mr. Hubbard comes on.

           25                  THE COURT:  Okay.  Go on ahead.

                                  KANABAY COURT REPORTERS

                                                   Page 1107

            1                  MR. WEINBERG:  Well, just so the record is

            2        clear, we do object to this, to the comments going in

            3        the record of this obviously reporter that was

            4        doing -- I don't think he was intending to do a

            5        favorable piece back in the '50s with regard to the

            6        Church of Scientology.  We object to his comments

            7        going into evidence.  It's like Dateline, NBC, or

            8        something, it sounds like.

            9                  THE COURT:  I haven't heard anything

           10        offensive yet.

           11                  (The tape was played as follows.)

           12                  THE NARRATOR:  After several weeks of

           13        hunting for him, with the help of almost every radio

           14        station along the Mediterranean and beyond, Well in

           15        Action at last tracked Hubbard down.  Just before dawn

           16        on a recent Sunday morning, Hubbard, who finds

           17        sleeping difficult, decided at last to speak.  He

           18        spoke for a long, long time, about his money, his

           19        beliefs, his critics, and the new authoritarian

           20        structure of Scientology.

           21                  But first he spoke about his troubles with

           22        the British government.  He put on his hat, he smiled,

           23        and he began.

           24                  MR. HUBBARD:  Well, that's very interesting.

           25        Let's correct the impression first.  You said "you

                                  KANABAY COURT REPORTERS

                                                   Page 1108

            1        were in trouble."  Let's get my relationship to this

            2        completely straight.  I am the writer of the textbooks

            3        of Scientology.  About two and a half years ago or so,

            4        I even ceased to be a director of organizations.

            5                  The government -- in the first place, I am

            6        not in trouble with the British government, not even

            7        faintly.  If I went in today or tomorrow through

            8        immigration, they would tip their hats and say, "How

            9        are you, Mr. Hubbard?" just as they have been doing

           10        for years.

           11                  THE NARRATOR:  The immigration officials

           12        might well tip their hats, but they couldn't let him

           13        in.  The day we filmed Mr. Hubbard, the home office

           14        decided that Britain would be better off without him.

           15                  Saint Hill Manor, England, Hubbard's British

           16        headquarters --

           17                  (The tape was interrupted.)

           18                  THE COURT:  Stop, stop.

           19                  (Continuing with tape.)

           20                  THE NARRATOR:  -- has made an income of

           21        something like one million pounds --

           22                  (The tape was stopped.)

           23                  THE COURT:  This is not whatever you all

           24        said it was.  This is more this other person than it

           25        is Mr. Hubbard.  You -- find what it is you want to

                                  KANABAY COURT REPORTERS

                                                   Page 1109

            1        play for me sometime and play it.  I don't want to

            2        hear all this other stuff.

            3                  MR. DANDAR:  All right.

            4                  THE COURT:  And your objection is sustained

            5        as far as this is not relevant.  Whoever this is --

            6                  MR. DANDAR:  That's it right there?  All

            7        right.

            8                  Go to the beginning of this.  All right.

            9        Sorry I had it wrong.  Sorry.

           10                  (The tape was played as follows.)

           11                  THE NARRATOR:  . . . simply to a layman what

           12        Scientology is.

           13                  MR. HUBBARD:  I think that would be a

           14        relatively easy (unintelligible) because it's

           15        factually a subject which is designed for the layman,

           16        and if you couldn't explain it to a layman, you would

           17        have a very difficult time with it.

           18                  The subject name means "steel," which means

           19        knowing how in the fullest sense of the word; "ology,"

           20        which is "study of."  So it's actually study of

           21        knowingness.  That is what the word itself means.

           22        The --

           23                  THE NARRATOR:  To me --

           24                  MR. HUBBARD:  Yes.

           25                  THE NARRATOR:  -- to me that doesn't mean

                                  KANABAY COURT REPORTERS

                                                   Page 1110

            1        very much.  (Unintelligible.)  What does it do for you

            2        in theory?

            3                  MR. HUBBARD:  It increases one's

            4        knowingness.  But if a man were totally aware of what

            5        was going on around him, he would find it was

            6        relatively simple to handle any outnesses in that.

            7                  THE NARRATOR:  Even after twelve hours of

            8        talking, we never got an explanation from him that we

            9        could understand.  In fact, Scientology is a fake, a

           10        religion --

           11                  (The tape was stopped.)

           12                  THE COURT:  This is beyond --

           13                  MR. DANDAR:  I apologize to the Court.  Let

           14        me -- let me find the spot that I'm trying to get to.

           15                  THE COURT:  All right.

           16                  MR. DANDAR:  And if Mr. Weinberg has

           17        recross --

           18                  THE COURT:  Let's get that done.

           19                  MR. DANDAR:  I'll try to get that done.

           20                  MR. WEINBERG:  I take it the last comment

           21        was struck as well.  Right?

           22                  THE COURT:  It certainly was.

           23                  MR. WEINBERG:  All right.

           24                  THE COURT:  As a matter of fact, none of

           25        this is admissible at this point.  I don't know that

                                  KANABAY COURT REPORTERS

                                                   Page 1111

            1        whatever it is they're trying to find would be

            2        admissible.

            3                  But you try to find it, Mr. Dandar, over

            4        lunch break and we'll --

            5                  MR. DANDAR:  Thank you.

            6                  THE COURT:  -- listen to it, and then I'll

            7        see.

            8                  MR. DANDAR:  All right.

            9                  You may cross-examine on the redirect.

           10                  MR. WEINBERG:  Thank you.

           11                  THE COURT:  It was very brief.

           12                  MR. WEINBERG:  Right.  Excuse me.

           13                  THE WITNESS:  You have to turn that thing

           14        off, because it keeps getting the radio station.

           15                  MR. WEINBERG:  I thought you were yelling at

           16        me.

           17                  THE COURT:  No.  I thought you were yelling

           18        at me.

           19                  MR. WEINBERG:  I looked up there to see if

           20        it was 4 o'clock.

           21                       RECROSS-EXAMINATION

           22   BY MR. WEINBERG:

           23        Q    Now, you, the first time on redirect, said that

           24   Mr. Minton had offered you a lifetime pension to join him,

           25   whenever it was, April of 2002.  Correct?  That's what you

                                  KANABAY COURT REPORTERS

                                                   Page 1112

            1   said?

            2        A    Yes.

            3        Q    Now -- and that typically --

            4                  THE COURT:  He said "retirement."  I don't

            5        know that if he used the word "pension."

            6                  THE WITNESS:  Right.

            7   BY MR. WEINBERG:

            8        Q    What you meant was you're going to be taken care

            9   of the rest of your life?

           10        A    I meant what I said, which is I would be retired.

           11        Q    All right.  And that from your experience it

           12   was -- the people that fell in that category were the

           13   people that got the $250,000.  Right?

           14        A    I gave examples of other people that have -- when

           15   Mr. Minton has given money to people to last them, this is

           16   what it was.

           17        Q    Right, like Mr. Dandar in March got the $250,000.

           18        A    No.  That was for the case.

           19        Q    Now -- now, you didn't -- do you remember that

           20   affidavit, the May 1st affidavit, that you were asked again

           21   about?

           22        A    Yes.

           23        Q    Nowhere in that affidavit do you say that

           24   Mr. Pension -- Mr. Minton offered you retirement, $250,000,

           25   or a lot of money?

                                  KANABAY COURT REPORTERS

                                                   Page 1113

            1        A    Well, I'm not sure.

            2        Q    You didn't say that in there, yes or no?

            3        A    I'm not sure.  I would have to look at the thing.

            4        Q    Do you want to do that?

            5        A    Yes.

            6                  MR. WEINBERG:  Unfortunately, we had left

            7        the documents up there, and they keep getting moved.

            8                  THE COURT:  This may be it right here.  I

            9        think I have it still.

           10                  THE WITNESS:  I could look at that real

           11        quick, your Honor.

           12                  THE COURT:  Do you want to look at my copy?

           13                  THE WITNESS:  Thank you, your Honor.  If you

           14        would just give me a moment to scan it.

           15        A    No, I don't see that here.  No, I didn't include

           16   that in the declaration.

           17                  THE WITNESS:  Thank you (handing back to

           18        Court).

           19   BY MR. WEINBERG:

           20        Q    The truth is, you complained to Stacy Brooks that

           21   Mr. Minton had treated you differently and had just

           22   nickeled and dimed you over the years.  Correct?

           23        A    I don't --

           24        Q    Something like that?

           25        A    Not quite, no.

                                  KANABAY COURT REPORTERS

                                                   Page 1114

            1        Q    Well, you were unhappy because you had never been

            2   one of the recipients of one of those big $250,000 checks,

            3   right?

            4        A    I think that -- no, that's incorrect, because the

            5   context that we were speaking about is me selling my soul,

            6   lying, perjuring myself, lying about Mr. Dandar and whoever

            7   else Scientology would want to lie for, because, I mean,

            8   you know, they had their shopping list of everything they

            9   wanted to be gone.  The Wollersheim was one; this was one.

           10   I was supposed to do that.  And, you know, I told him:  You

           11   can't do that.  At no price can you make me turn on people

           12   that I have worked with for years for Scientology's behalf.

           13             And as a matter of fact, I think my statement was

           14   I will not help Scientology hurt or destroy one more

           15   person.

           16        Q    Now, this is a 16-page affidavit, chockful of all

           17   kinds of details.  You even detailed that Mr. Minton had

           18   told you he offered Mr. Wollersheim $200,000 to try to

           19   settle that case, right?

           20        A    Correct.

           21        Q    You put that in there.  But you didn't think it

           22   was important to put in this affidavit that Mr. Minton had

           23   offered you a retire- -- basically enough money so that you

           24   could retire?  You didn't think that was important?

           25        A    Well, I admit that that is something that's

                                  KANABAY COURT REPORTERS

                                                   Page 1115

            1   important here, but I did not put it there for whatever

            2   reason.  I mean, you know, I put down what I put down.  So

            3   if you want to give me a strike for that, okay.

            4        Q    All right.  Now, you said today that -- on

            5   redirect that those three resignation letters -- remember

            6   the March 3rd, '87, letters, the ones in your hand?

            7        A    Correct.

            8        Q    Right?  You told Mr. Dandar on redirect that you

            9   actually executed those letters on March 3rd, 1987, right?

           10   The ones in your hand.

           11        A    Yes.

           12        Q    And those letters were actually typed up on

           13   March 3rd of 1987, right?

           14        A    I have no idea when they were typed.

           15        Q    Isn't that what you said on direct?

           16        A    No, I didn't say --

           17        Q    Isn't that what you said on redirect?

           18        A    No, I didn't say who typed it, because I did not

           19   type this.

           20        Q    No, I didn't say you typed them up.  I said those

           21   were actually prepared, the whole letter --

           22                  THE COURT:  He doesn't know when they were

           23        typed.

           24                  MR. WEINBERG:  No, that was his testimony.

           25                  THE WITNESS:  No, it wasn't.

                                  KANABAY COURT REPORTERS

                                                   Page 1116

            1                  THE COURT:  He said that was what he

            2        executed.

            3   BY MR. WEINBERG:

            4        Q    What you executed had the date on it already?

            5        A    Correct.

            6        Q    All right.  So -- that's all I'm saying.  In

            7   other words, the -- you didn't -- you aren't testifying

            8   that the -- that the resignation letters that you signed

            9   were actually -- and that, you know, had the date on it

           10   were actually prepared a long time before.  That's not what

           11   you're saying?

           12        A    No.  I made a distinction between the undated

           13   resignation that I had signed when I first assumed the

           14   position and these ones right here.  And I stated why these

           15   ones were done, used, instead of the undated ones.

           16        Q    Do you remember in your affidavit -- and the

           17   affidavit we're talking about is the -- that I'm talking

           18   about now is the August 1999 affidavit, which is the -- the

           19   August 20th one, which is the -- I call it the murder

           20   allegation --

           21                  THE COURT:  Okay.

           22   BY MR. WEINBERG:

           23        Q    -- affidavit.

           24                  MR. WEINBERG:  If I can approach --

           25                  THE COURT:  You may.

                                  KANABAY COURT REPORTERS

                                                   Page 1117

            1                  MR. WEINBERG:  -- is probably the easiest

            2        way of doing this.

            3   BY MR. WEINBERG:

            4        Q    Do you remember that in paragraph 14 of -- this

            5   is the -- just so you see it, is your August 20th, 1999.

            6        A    M'hum (affirmative).

            7        Q    You see, just read paragraph 14 down to -- it's

            8   short.

            9        A    Okay.

           10        Q    Read it to yourself.

           11        A    Okay.

           12        Q    Have you seen that?

           13        A    Yes.

           14        Q    Now, what you say in this affidavit in

           15   paragraph 14 on page 6 is:  "I was forcefully removed,"

           16   which is, you've already testified, on March 3rd.

           17             Then you say, quote:  "It is my belief that my

           18   undated resignation which I signed when I was appointed to

           19   the board was then dated and used to make it appear that I

           20   had resigned when I had not."

           21             So the testimony that you swore to in this

           22   affidavit that all that was -- that all that happened

           23   was -- that what happened was that a date was put on

           24   something that you had previously signed is absolutely

           25   contrary to what you just testified in this court.

                                  KANABAY COURT REPORTERS

                                                   Page 1118

            1   Correct?

            2        A    What -- what I wrote there, I wrote that as my

            3   belief.  I didn't recall this, but once it was shown to me

            4   and recalled to me, I testified about it.  I'm not able to

            5   recall every little thing all the time.  That was my belief

            6   at the time.  But then when you showed me this, I

            7   remembered more about the incident that happened in 1986.

            8        Q    '87.

            9        A    '87, sorry, January of '87.

           10        Q    So you were wrong in your August 20th, 1999,

           11   sworn affidavit?

           12        A    Right.  In that -- in that regard, in that

           13   particular regard.

           14                  MR. WEINBERG:  Now, do you have -- can I ask

           15        the clerk for a document, your Honor?

           16                  THE COURT:  You may.

           17                  MR. WEINBERG:  Plaintiff's 15B.

           18                  I'm going to show him 15B, which is Teresa

           19        Summers' letter.

           20                  THE COURT:  For the record, you probably

           21        ought to say what you said to me.

           22                  I don't know, did you get that, Madam Court

           23        Reporter?

           24                  THE REPORTER:  Yes, ma'am, I did.

           25                  MR. WEINBERG:  I guess I was speaking louder

                                  KANABAY COURT REPORTERS

                                                   Page 1119

            1        than I thought.

            2   BY MR. WEINBERG:

            3        Q    All right.  I'm showing you the September 7th,

            4   2001, Teresa Summers letter.  And I believe you said on

            5   redirect that you had learned about the Clambake money and

            6   the issues with regard to the Clambake money in -- for the

            7   first time -- or issues with regard to LMT money for the

            8   first time in Teresa Summers' letter, right?

            9        A    Correct.

           10        Q    And this is Teresa Summers' letter?

           11        A    Yes, it is.

           12        Q    Now, can you look at page 1 of that letter.

           13        A    Yes.

           14        Q    Paragraph 1.

           15        A    Where it says, "Please be advised"?

           16        Q    I'm sorry, where it says --subparagraph 1.  Do

           17   you see where the No. 1 --

           18        A    Yes.

           19        Q    Where it says, "The revelation --"  This is a

           20   letter to Stacy Brooks from Teresa Summers, right?

           21        A    Correct.

           22        Q    "The revelation in your recent deposition that

           23   800,000 was donated to the LMT from foreign sources and

           24   that every penny of that money was delivered to Bob Minton

           25   is very difficult to make sense of.  For at least the last

                                  KANABAY COURT REPORTERS

                                                   Page 1120

            1   six months, I have been told by you" all of the LMT

            2   funding -- I've been told by you that all of the LMT

            3   funding came from Bob Minton."

            4             Do you see that?

            5        A    Yes, I do.

            6        Q    And that's what you were told as well, correct,

            7   that all of the LMT funding came from Bob Minton?

            8        A    No, that's not what I was told.

            9        Q    Now, let me -- will you turn to the next-to-last

           10   page, please.  The last paragraph of the next-to-last page,

           11   the one that says "in addition"?

           12        A    Yes.

           13        Q    Do you see that?  Summers says:  "In addition,

           14   Bob and Jesse were involved with bringing money into the

           15   country illegally, and you have never discussed this matter

           16   with me."

           17        A    Yes.

           18        Q    Do you know what she's talking about?

           19        A    No.  And she doesn't either.  I never brought any

           20   money into the country illegally.

           21        Q    And Ms. Summers is someone that's worked at the

           22   LMT?

           23        A    Correct.  I can tell you what Ms. Summers is

           24   referring to, if you'd like to know.

           25                  THE COURT:  It doesn't matter.

                                  KANABAY COURT REPORTERS

                                                   Page 1121

            1                  THE WITNESS:  Okay.

            2                  MR. WEINBERG:  Doesn't matter.

            3                  THE COURT:  I have no idea why he bothered

            4        to bring that out.  Maybe he wanted you to look bad or

            5        something.

            6                  THE WITNESS:  Well . . .

            7   BY MR. WEINBERG:

            8        Q    All right.  Now, finally, you testified on

            9   redirect that the -- you testified about the release that

           10   you executed with Mr. Rathbun at the end of October, the

           11   beginning of November, 1992.  Do you remember that

           12   testimony?

           13        A    In November of 1992, I was not in the Sea Org.  I

           14   was in Minneapolis, Minnesota.

           15        Q    What I'm asking you is, Do you recall on redirect

           16   you testified about the release that you executed at the

           17   time that you left the Church of Scientology?

           18        A    Correct.

           19        Q    All right.  And your testimony is that you were

           20   under duress when you did that.  Correct?

           21        A    Absolutely, yes.

           22        Q    And you executed it in a meeting -- in a meeting

           23   with Mr. Rathbun, right?

           24        A    Correct.

           25        Q    Just you and Mr. Rathbun?

                                  KANABAY COURT REPORTERS

                                                   Page 1122

            1        A    No.  There were other staff there.

            2        Q    Do you remember who else was there?

            3        A    I believe Mr. Sutter was there.

            4        Q    They were sitting -- you were sitting in a

            5   meeting with him?

            6        A    If I say he's there, that means that I can see

            7   him.  That means we're in the same room or something like

            8   that, you know?

            9        Q    So you're saying he was there?

           10        A    Correct.

           11        Q    Okay.  Well, let me show you two -- and then it's

           12   your testimony that, at the end, Mr. Rathbun made you put

           13   the wrong date on the release.  Right?  That was your

           14   testimony?

           15        A    It was convenient for them to have it as

           16   November, as opposed to October.  I don't know why.  That's

           17   what I --

           18        Q    But it was his origination, not yours?

           19        A    Correct.

           20        Q    Okay.  I'm going to play you a short clip from

           21   the beginning of this meeting with Mr. Rathbun and then the

           22   end of the meeting with Mr. Rathbun.

           23        A    You know, I resent that unless you show the whole

           24   thing.

           25                  THE COURT:  I think that's fair.  If you're

                                  KANABAY COURT REPORTERS

                                                   Page 1123

            1        going to show something and suggest whether he was or

            2        wasn't under duress, you have to play the whole

            3        meeting.

            4                  MR. WEINBERG:  It's a long meeting.  When I

            5        have is the clip, and, you know, we can provide the

            6        whole thing if you want it.  But what I intend to do

            7        on this redirect is to show him the beginning of the

            8        meeting, which would indicate he was in the meeting,

            9        and the end of the meeting where he signs the --

           10                  THE COURT:  All right.

           11                  MR. WEINBERG:  -- release.

           12                  (Jesse Prince interview with Marty Rathbun,

           13                  November 1, '92, was played as follows.)

           14                  MR. RATHBUN:  Okay.  This is Marty Rathbun

           15        with Jesse Prince.  And Jesse is going out of the Sea

           16        Org, and he agreed to have a --

           17                  (The playback was interrupted.)

           18                  THE COURT:  Where is Jesse Prince?

           19                  MR. WEINBERG:  He's at the front.

           20                  (Continuing with tape.)

           21                  MR. RATHBUN:  -- knowledge that he might

           22        have about outstanding --

           23                  (The playback was stopped.)

           24                  MR. DANDAR:  Does Mr. Prince know he's being

           25        videotaped?

                                  KANABAY COURT REPORTERS

                                                   Page 1124

            1                  THE WITNESS:  No.

            2   BY MR. WEINBERG:

            3        Q    Well, you knew the meeting was recorded.

            4        A    Not videotaped.  And this is the first time I've

            5   seen this, and this is really gross.  This is from a hidden

            6   camera.

            7        Q    Did you know it was being recorded or not?

            8        A    On tape.  A tape recording was running, not a

            9   video.

           10        Q    Is this you?

           11        A    Yes, it is.  I think it is.

           12                  THE COURT:  Doesn't look -- I'm sorry, it

           13        doesn't look like him.

           14                  THE WITNESS:  Let me see.  They're full of

           15        tricks.

           16                  MR. DANDAR:  Yes, why don't you see.

           17                  THE WITNESS:  I can't tell.

           18                  MR. WEINBERG:  Well, when you hear your

           19        voice, I think you can tell.

           20                  THE COURT:  It does not look like Mr. Prince

           21        to me.

           22                  THE WITNESS:  You know, I really resent

           23        this.  This is secret.  Taping this is exactly what

           24        I've been saying here.  This is exactly what they do,

           25        the illegal surveillance.  It's just sneaky all the

                                  KANABAY COURT REPORTERS

                                                   Page 1125

            1        time.

            2                  MR. WEINBERG:  I asked him the question, Did

            3        you know you were being recorded?

            4                  THE COURT:  He said no.

            5                  MR. WEINBERG:  The answer is yes.  I think

            6        he said yes.

            7                  THE COURT:  He knew there was a tape

            8        recorder playing.  He did not know he was being

            9        videotaped.

           10                  MR. WEINBERG:  I guess the question, your

           11        Honor, is once you know that --

           12                  THE COURT:  Quite frankly, I would resent

           13        the tar out of it.  I hope there's none of that going

           14        on ever.  If you're going to ever take a picture of

           15        me, you'd better tell me, because I would resent the

           16        tar out of it, to say nothing of the fact that I'm not

           17        certain it's legal.

           18                  So whatever it is, Mr. Prince, you didn't

           19        know anything about this?

           20                  THE WITNESS:  No, your Honor.  They did not

           21        have my permission to do this.

           22                  THE COURT:  All right.

           23                  THE WITNESS:  This is from a hidden, secret

           24        camera.

           25                  THE COURT:  Go ahead and play it.  We'll

                                  KANABAY COURT REPORTERS

                                                   Page 1126

            1        decide whether or not it's legal or not.

            2                  (The playback continued.)

            3                  MR. RATHBUN:  -- cases going on or other

            4        matters that are involved, illegal or whatever.

            5                  MR. PRINCE:  That's right (unintelligible).

            6                  MR. RATHBUN:  We're here alone?

            7                  MR. PRINCE:  That's right.

            8                  MR. RATHBUN:  Nobody else here?

            9                  MR. PRINCE:  No coercion, nobody doing

           10        anything.

           11                  MR. RATHBUN:  Okay.  And you're here of your

           12        own free will?

           13                  MR. PRINCE:  That's right.

           14                  MR. RATHBUN:  There's no -- nobody is

           15        holding anything over your head?

           16                  MR. PRINCE:  Yes.

           17                  MR. RATHBUN:  There's no threat?

           18                  MR. PRINCE:  No threat, no pressure.  I know

           19        exactly what I'm doing.  I'm not sitting here

           20        (unintelligible) worrying about legal counsel knowing

           21        what the hell is going on.  I know exactly what I'm

           22        doing in a professional capacity.

           23                  MR. RATHBUN:  Great.  Okay.  The first thing

           24        we're going to do was you've reviewed a couple of

           25        outstanding complaints, which were the RICO case,

                                  KANABAY COURT REPORTERS

                                                   Page 1127

            1        which is our --

            2                  (The playback was interrupted.)

            3                  THE WITNESS:  You know, I can't hardly stand

            4        this.  I can hardly stand this.

            5                  MR. WEINBERG:  I was going to play the end

            6        of it.

            7                  THE COURT:  Well, how in the world can you

            8        play something that suggested somebody wasn't under

            9        coercion and not play it?  How do I know --

           10                  MR. WEINBERG:  If we can -- we can play the

           11        whole --

           12                  THE COURT:  This is the RICO case?  What is

           13        your purpose in playing it?

           14                  MR. WEINBERG:  Mr. Prince -- Mr. Prince said

           15        that there were all kinds of people in the room, that

           16        he was being coerced, that it was forced.  And there

           17        are no people.

           18                  THE WITNESS:  They left the room.

           19                  MR. WEINBERG:  Excuse me.

           20                  THE WITNESS:  They had left the room.  This

           21        was totally staged, to protect the Church, as I've

           22        given testimony before:  Mr. Prince, this is what you

           23        need to do to leave our compound.

           24                  So I'm sitting here doing whatever they

           25        asked me to do to leave their compound.  There's been

                                  KANABAY COURT REPORTERS

                                                   Page 1128

            1        articles in George magazine, press -- Riverside Press,

            2        and my suit about the coercion.  So, you know, and now

            3        you're showing me a secret camera thing?  I resent

            4        this highly.  I really resent this.

            5                  MR. DANDAR:  We object.  And for the record,

            6        that sure doesn't look like Mr. Prince.

            7                  MR. WEINBERG:  Well, you know that's you.

            8        You've heard you.

            9                  THE WITNESS:  Look, I resent this because it

           10        was done -- not only did everybody leave the room --

           11                  THE COURT:  You mean there were others there

           12        before this started?

           13                  THE WITNESS:  Yes.  Absolutely.  They were

           14        all standing around in that room.  And then it's like,

           15        "Okay, now, let's get this extra protection in."

           16                  Signing a release for your client wasn't

           17        enough.  Signing a release saying that they didn't

           18        harm me or damage me wasn't enough for them.  Now

           19        they've got to sit down and do this.  You know?  I

           20        really think anybody with common sense knows what's

           21        going on here.

           22   BY MR. WEINBERG:

           23        Q    When did you sign it?  The beginning of the

           24   meeting or the end of the meeting?

           25        A    What, the release?

                                  KANABAY COURT REPORTERS

                                                   Page 1129

            1        Q    Yes.

            2        A    Probably at the end.  I mean, they wanted me

            3   to -- this is what I had to do to leave.  I had been locked

            4   up --

            5                  THE WITNESS:  Your Honor, I had to escape

            6        from Scientology.  They didn't even know where I went.

            7                  THE COURT:  I don't want to hear it anymore.

            8        If he didn't know about it, I don't want to see it.

            9                  MR. WEINBERG:  All right.  That's all my

           10        questions.

           11                  THE COURT:  As far as I'm concerned, it can

           12        be stricken.

           13                  MR. WEINBERG:  Those are all my questions.

           14                  THE COURT:  All right.

           15                  FURTHER REDIRECT EXAMINATION

           16   BY MR. DANDAR:

           17        Q    Mr. Prince, do you have that affidavit that's --

           18                  THE COURT:  And I might suggest in the

           19        future, if you're going to videotape parishioners,

           20        that they be told about it.  Quite frankly, that is

           21        not very churchly, to be candid.

           22                  MR. LIEBERMAN:  Well, your Honor, just to be

           23        clear, it is the Church's position that Mr. Prince

           24        absolutely knew this was being taped and the videotape

           25        introductory section of this before the interview

                                  KANABAY COURT REPORTERS

                                                   Page 1130

            1        starts shows them setting up electronic equipment.

            2                  And it's his testimony here that he didn't

            3        know about it.  That is not -- we do not go along with

            4        that.  I want the record to reflect that.

            5                  THE COURT:  It's very odd that someone

            6        leaving a Church has to be videotaped.  The truth is,

            7        it's very odd he would have to sign a release.  I

            8        mean, it's all very odd.

            9                  However, it's just my suggestion to you so

           10        that you don't ever have to listen to somebody again

           11        that you might just want to put it in your release, "I

           12        understand that I'm being videotaped as I sign this."

           13        Then you won't have to worry about it.  I won't have

           14        to hear somebody saying that he resents you taking my

           15        picture, for whatever reason.

           16                  THE WITNESS:  Your Honor, this comes from --

           17                  THE COURT:  I don't want to hear any more

           18        about it.

           19                  THE WITNESS:  Okay.

           20                  THE COURT:  Go on ahead.

           21   BY MR. DANDAR:

           22        Q    Mr. Prince, I want to direct your attention to

           23   paragraph --

           24                  THE COURT:  I didn't have to sign a release

           25        when I left my church, quite frankly.  I left, I went

                                  KANABAY COURT REPORTERS

                                                   Page 1131

            1        back, who cared?

            2   BY MR. DANDAR:

            3        Q    Paragraph 15 of your --

            4                  THE COURT:  Nobody ever sued me either.  I

            5        never testified against them.

            6   BY MR. DANDAR:

            7        Q    Paragraph 15 of your April 2002 affidavit,

            8   paragraph 15 -- I don't have the page numbers on my copy

            9   for some strange reason.  But the second page of

           10   paragraph 15, could you please read the highlighted portion

           11   on -- beginning --

           12                  THE COURT:  Which affidavit is this now?

           13                  MR. DANDAR:  The April 2002.

           14                  THE WITNESS:  May 1st.

           15                  THE COURT:  Okay.

           16        A    "Bob told me that I was the one making a big

           17   mistake, that if I walked down this road with them, they

           18   would hire an attorney for me and everything would be okay.

           19   Both he and Stacy Brooks told me of a new life, where we

           20   would all live in happiness and prosperity."

           21   BY MR. DANDAR:

           22        Q    What were the details of living a new life in

           23   happiness and prosperity?

           24        A    Retired, vacationing on the Islands regularly,

           25   running around the world, world travel.

                                  KANABAY COURT REPORTERS

                                                   Page 1132

            1        Q    When you -- did the --

            2                  THE COURT:  What paragraph was that?

            3                  MR. DANDAR:  It was paragraph 15.  If I had

            4        the exhibit, I could give you the page number.

            5                  THE COURT:  It's all right, paragraph 15.

            6                  MR. DANDAR:  It's the second page of

            7        paragraph 15.  It's a real long paragraph.  It's lines

            8        19 through 22.

            9                  THE COURT:  All right.

           10                  MR. DANDAR:  And this wasn't part of the

           11        recross of Mr. Weinberg, so if it's objected to, I

           12        understand.  But --

           13                  MR. WEINBERG:  Well, I'll object in advance.

           14   BY MR. DANDAR:

           15        Q    Mr. Prince, when Teresita went insane or

           16   psychotic, did she do it like Lisa did, in the middle of

           17   the street, in public, or somewhere else?

           18        A    She did it -- she was at a work station -- oh,

           19   god, we were in a big time crunch.  We were making the

           20   first --

           21                  THE COURT:  We really don't care about that.

           22        Was it out in public or at work?

           23                  THE WITNESS:  No, it was at work.

           24   BY MR. DANDAR:

           25        Q    So there was no public PR flap?

                                  KANABAY COURT REPORTERS

                                                   Page 1133

            1        A    Correct.

            2                  MR. DANDAR:  And outside of wanting to play

            3        this videotape, that's all the questions I have.

            4                  THE COURT:  Okay.  Anything further?

            5                  Thank you, sir.

            6                  THE WITNESS:  Thank you, your Honor.

            7                  THE COURT:  Your testimony is finished.  You

            8        may step down.

            9                  I don't know about that videotape either.  I

           10        have no idea what that is either.  So you find

           11        whatever it is you want to find, show it to counsel in

           12        advance, see what it is, and see if we can make some

           13        context out of it and see if it has any relevance.

           14                  MR. DANDAR:  All right.

           15                  THE COURT:  All right.  Now, it's noontime.

           16        It's 12:05.  We'll be in recess until 1:15.

           17                  MR. WEINBERG:  How about 1:30?

           18                  THE COURT:  No, 1:15.

           19                  MR. WEINBERG:  Or 1 o'clock?

           20                  THE COURT:  No, 1:15.

           21                  MR. WEINBERG:  1:15, all right.

           22                  (A lunch recess was taken at 12:08 p.m.)

           23                 _______________________________



                                  KANABAY COURT REPORTERS

                                                   Page 1134

            1   STATE OF FLORIDA

            2   COUNTY OF PINELLAS

            3        I, Debra S. (Laughbaum) Turner, Registered Diplomate

            4   Reporter, certify that I was authorized to and did

            5   stenographically report the foregoing proceedings and that

            6   the transcript is a true record.

            7        WITNESS MY HAND this 11th day of July, 2002, at

            8   St. Petersburg, Pinellas County, Florida.


           10                      _________________________________
                                   Debra S. (Laughbaum) Turner, RDR
           11                      Court Reporter















                                  KANABAY COURT REPORTERS

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