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Subject: ROBERT S. MINTON -- THIRD AFFIDAVIT -- APRIL 24, 2002
Date: Thu, 02 May 2002 12:21:44 -0400
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IN THE CIRCUIT COURT FOR THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, STATE OF FLORIDA
CIVIL DIVISION

Case No. 00-5682-CI-11, Division   11

ESTATE OF LISA MCPHERSON, by
and through the personal Representative,
DELL LIEBREICH
Plaintiff,                                       

vs.

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

AND RELATED COUNTERCLAIM.
____________________________________/


THIRD AFFIDAVIT OF ROBERT S. MINTON


STATE OF FLORIDA	)
                                                ) ss.
COUNTY OF PINELLAS	)

Robert S. Minton, being duly sworn, deposes and says:

1.   I am over 18 years old, have personal knowledge of the facts set
forth herein, and am otherwise competent to testify in this matter. 

2.  Jesse Prince attended the hearing on April 9, 2002, during which I
testified before Judge Baird to purge myself of contempt.  I later was
told that Mr. Prince became very upset when he saw me testifying. 

3.  On Friday, April 12, 2002, Mr. Prince came to see Ms. Brooks and
me at the Adam's Mark Hotel on Clearwater Beach.  He seemed glad to
see us and we had dinner together. During the dinner we talked about
the fact that we wanted to end our fight with Scientology and get on
with our lives.  We discussed what a relief it was to be finally
telling the truth about all the things that had happened. I mentioned
the meeting in the fall of 1999 where Mr. Dandar wanted our opinions
about adding David Miscavige to the lawsuit. At first Mr. Prince
didn't remember the meeting, but when Ms. Brooks reminded him that she
had been in favor of it until I said I thought it was a bad idea, Mr.
Prince said, "Oh yeah, I do remember that meeting now."  I then asked
him if he remembered Mr. Dandar telling us in the elevator that the
meeting "never happened" and he said yes, he did.
 
4. On Sunday night, April 14, 2002, Mr. Prince came to see Ms. Brooks
and me at the hotel we had moved to, the Radisson on Sand Key. He came
up to our room and at first he seemed fine, although he was obviously
intoxicated.  I brought up the subject of Judge Schaeffer's March 8,
2002, hearing and that he had no credibility with Judge Schaeffer.  He
became very antagonistic and angry.  Ms. Brooks suggested we go down
to have dinner and talk about it over dinner. When we got to the
restaurant downstairs Mr. Prince looked at me in a very angry manner
and said, "I'm not going to let you do this.  I'm not going to let you
go down this road, and I will do everything in my power to stop you."
He also said to me, "You have become a Scientologist."  He then began
talking about an incident he had recounted before, regarding when he
was in Scientology and was awakened at 4:45 in the morning and taken
to David Miscavige's office.   Mr. Prince used extremely foul language
as he was telling us this story. I asked him several times to stop
using profanity because there was a woman with her young child at the
table next to us, but he ignored me. He went into great detail about
how he left the office and went and got an AK-47 and another gun and
then returned to Mr. Miscavige's office and pointed the guns at Mr.
Miscavige.  Then he looked straight at me and said, "I don't want to
go down that road again. I'm not going to let you do this, Bob." His
tone was so threatening that I said to him, "You need to get up from
the table and walk out the front door of this hotel. I don't want to
see you any more."

5.  He then got up and left, and Ms. Brooks followed him outside. She
later told me that Mr. Prince began railing against me, saying, "He's
never done a f-ing thing for me. F-him, he's a cold-hearted bastard
and he's never done a thing for me." I have not only been Mr. Prince's
sole source of support from the summer of 1998 to the present, but I
also loaned Mr. Prince $50,000 to buy a house in Clearwater. When Mr.
Prince was arrested in August 2000, I paid for his defense in a
criminal trial for drug possession/cultivation, spending approximately
$60,000 on his defense.  I later learned he had lied to me about his
drug use when I heard the testimony at trial from the prosecution
witnesses.

6.  Mr. Prince called Ms. Brooks the next day and accused me of trying
to "set him up" to have him put in jail. He then again told her that I
have "never done a f-ing thing" for him, that I have given "big money"
to a lot of other people like Peter Alexander, Patricia Greenway and
Ken Dandar but all I've ever done for him was "nickel and dime stuff."
He then told Ms. Brooks that he was "working with law enforcement" to
try to stop me from testifying, that I was lying about Ken Dandar, and
that he was working on an affidavit that would tell the "real story." 

7.  On Wednesday, April 17, 2002, Mr. Prince had his girlfriend Dee
Phillips call Ms. Brooks and me with a message from him. Mr. Prince
said that he was "in close contact" with the FDLE and that I could
"save myself" if I turned myself in to the FDLE "up to a minute before
the hearing." He said someone from the FDLE was going to be in the
courtroom the next day (for the hearing before Judge Baird) and that
if I lied about anything on the stand I would be "arrested on the
spot."  He said "whatever trouble you are in with Scientology, the
FDLE can get you out of it."

8.  The next day he called Ms. Brooks and asked to speak to me. I had
her tell him that I would only speak to him with my attorney present.
He refused and hung up, but later he called back and agreed to speak
to me with my attorney. I called my attorney Bruce Howie and told him
what Mr. Prince had said. I asked Mr. Howie to call Mr. Prince. It is
my understanding that Mr. Prince said the FDLE and the FBI would be in
the courtroom, and that he was going to testify against me. 

9.  After Mr. Prince visited us at our hotel, there was a posting on
the internet announcing where we were staying including the room
number we were in, and inviting people to call, presumably to harass
us.  

10.  After I testified in the hearing on April 19, 2002, other
witnesses called in the hearing including Patricia Greenway and Peter
Alexander, were standing together in front of the courthouse.  Ms.
Greenway made intimidating remarks to me suggesting that I had made a
deal with Scientology.
                               

 
ss. Robert S. Minton
____________________________________
ROBERT S. MINTON


STATE OF FLORIDA	)
                                                ) ss.
COUNTY OF PINELLAS	)

The foregoing instrument was acknowledged before me to be true and
correct to the best of his ability this 24th day of April, 2002, by
Robert S. Minton.  He is personally known to me and did take an oath.


ss. Suzanne Davidson
________________________________________
Notary Public








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