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Subject: 4th affidavit of Robert S. Minton from June 3rd, 2002
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[Due to popular demand:]

IN THE CIRCUIT COURT FOR THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA

ESTATE OF LISA MCPHERSON,
by and through her personal
representative, DELL LIEBREICH

Plaintiffs,

vs.

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

Defendants.

Case No. 00-5682-CI-11

FOURT AFFIDAVIT OF ROBERT S. MINTON

The undersigned, ROBERT S. MINTON, states under oath as follows:

1. I am a citizen of the United States, I am a resident of the State
of New Hampshire, and I am over the age of 18 years.

2. All facts set forth in this affidavit are personally known to me.

3. From time to time in this proceeding and in the initial related
proceeding before the Circuit Court of the Thirteenth Judicial, Case
No. 97-6890, involving the same causes of action as are continued in
this proceeding, I have been subpoenaed to testify at deposition or at
hearing or have otherwise been called upon to submit statements,
including statements under oath, as a witness in this cause.

4. In a factually related lawsuit before the Circuit Court of the
Sixth Judicial Circuit styled as CHURCH OF SCIENTOLOGY, FLAG SERVICE
ORGANIZATION, INC. vs. DELL LIEBREICH, individually and as Personal
Representative of the Estate of Lisa McPherson, ROBERT MINTON, and THE
LISA MCPHERSON TRUST, Case No. 00-002750-CI-20, I have also been
subpoenaed to testify at deposition or at hearing or have otherwise
been called upon to submit statements, including statements under
oath, as a witness.

5. During the course of the proceedings in the above-referenced causes
I have made certain statements, including statements under oath, that
I have since admitted to be false and that I recanted either by
affidavit or in my testimony. I have since discovered additional false
statements that I now recant as set forth below. I gained nothing from
these false statements.

8. [sic] I have previously made the statement under oath, including in
my deposition in this cause of September 18, 2001, at page 117, as
well as in my deposition of April 8, 2002, in Case No. 00-2750-CI-20
at page 117, that I did not have the amount of $ 500,000 wire
transferred to the Lisa McPherson Trust (hereinafter "the LMT") and
that the $ 500,000 was an anonymous contribution. These statements are
false. In truth, I used my own funds to cause that transfer to be made
to the LMT at my own direction and therefore these funds were not from
an anonymous source.

9. I have previously made the statement under oath, including in my
deposition of April 8, 2002, in Case No. 00-2750-CI-20 at pages 116
and 117 that Andreas Heldal-Lund from Operation Clambake in Norway
wired $ 300,000 to the LMT, that he received this money from someone
else, that I did not know who the source was, and that it was an
anonymous contribution to the LMT. These statements are false. In
truth, although Andreas Heldal-Lund did wire transfer the $ 300,000 to
the LMT, this was after I provided Andreas Heldal-Lund with a check
issued by UBS in the amount of $ 300,000 payable to Andreas
Heldal-Lund. This $ 300,000 was my money and this payment to the LMT
came from me and therefore was not from an anonymous source.

10. I have previously made the statement under oath, including in my
deposition of April 8, 2002, in Case No. 00-2750-CI-20 at pages 117 to
118 that Gerry Armstrong contributed $ 100,000 to the LMT in 2001 and
that I did not know where he got the $ 100,000. This statement is
false. In truth, in 2001 I gave Gerry Armstrong $ 100,000 which I
directed Gerry Armstrong to send to the LMT.

11. I have previously made the statement under oath, including in my
deposition of April 8, 2002, in Case No. 00-2750-CI-20 at page 119
that Gerry Armstrong repaid all of my $ 100,000 loan back to me. This
statement is false. In truth, I gave Gerry Armstrong $ 100,000 so that
it would appear that he repaid me his loan.

12. I have previously made the statement under oath, including in my
deposition of April 8, 2002, in Case No. 00-2750-CI-20 at page 50 that
I never paid attorney John Merrett any money for attorney's fees or
reimbursement of expenses. This statement is false. In truth, in
January of 2002 I paid John Merrett $ 100,000 to compensate him for
bonds he had posted and to bring his retainer up to date, and in 2001
I paid John Merrett $ 250,000 in exchange for his agreement to
represent the LMT and related parties exclusively. I should note that
at pages 77 and 78 of the same deposition, I partially corrected my
statement by testifying that in January of 2002 I caused a check for $
100,000 to be issued to John Merrett concerning legal matters.

13. I have previously made the statement under oath, including in my
deposition in Case No. 00-2750-CI-20 on October 11-12, 2001 at page
317, that there was no restriction in the use of the funds I loaned to
the Estate of Lisa McPherson that would prevent their use as
attorney's fees. This statement is false. In truth, the loans to the
Estate at the time they were made were specifically to cover the
expense of litigating the wrongful death case and not attorney's fees.
However, attorney Kennan Dandar informed me after the fact that he had
used $ 60,000 of these loans to pay himself attorney's fees. I
asquiesced to this and agreed to testify that this was an acceptable
use of the funds although in truth it was not.

FURTHER AFFIANT SAYETH NAUGHT.

[Signature]
ROBERT S. MINTON, Affiant

STATE OF NEW HAMPSHIRE
COUNTY OF ROCKINGHAM

Before me the undersigned authority personally appeared ROBERT S.
MINTON who is personally known to me or who presented ______________
for identification, and who swore under oath that the foregoing is
true and correct to the best of his knowledge and belief.

Subscribed and sworn this 3 day of June, 2002.

[Signature]
Notary Public

[...]

EDWARD C. GARVEY
NOTARY PUBLIC - NEW HAMPSHIRE
My Commission Expires December 20, 2005



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