Lisa McPherson Files - Sworn Statement of Brenda Gayle Hubert Spencer

Lisa's Longtime Friend and Co-Worker

From the Clearwater Police Department files on the investigation into Lisa McPherson's death:



          IN RE:

          DATE:                  October 2, 1997
          TIME:                  Began:  2:00 p.m.
                                 Ended:  3:40 p.m.

          PLACE:                 Criminal Justice Center
                                 Office of the State Attorney
                                 Room 1000
                                 Clearwater, Florida

          REPORTED BY:           Ruth M. Martin, CSR, CP, RMR
                                 Registered Merit Reporter
                                 Notary Public
                                 State of Florida at Large

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

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      1     APPEARANCES:
      2              MARX McGARRY, ESQUIRE
                     Office of the State Attorney
      3              Criminal Justice Complex, Room 1000
                     Clearwater, Florida 33760

      4                  Attorney for State of Florida
      5              RONALD CACCIATORE, ESQUIRE
                     100 North Tampa Street, Suite 2835
      6              Tampa, Florida 33602/
                          Attorney for the Witness
            ALSO PRESENT:
                    WAYNE C. ANDREWS, Detective Sergeant
      9             JORGE E. CABRASQUILLO, Detective
                    City of Clearwater Police Department





      16                             INDEX
      17    EXAMINATION
      18         BY MR. McGARRY                             3
                 BY DETECTIVE SERGEANT ANDREWS             73
      19         BY DETECTIVE CARRASQUILLO                 84

      21    CERTIFICATE OF OATH                            90

      23                          EXHIBITS
      25    State-1  Subpoena                               3

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      1               The deponent herein,
      2               BRENDA GAYLE HUBERT SPENCER,
      3    being first duly sworn to tell the truth, the
      4    whole truth; and nothing but the truth, was
      5    examined and testified as follows:
      6               MR. CACCIATORE: May I put a couple of things
      7    on the record, Mr. McGarry?
      8               MR. McGARRY: Yes.
      9               MR. CACCIATORE: As you know, I wrote you a
     10    letter, I just want it to be clear my client is not a
     11    Staff member.
     12               MR. McGARRY: I know that. It was an
     13    oversight on my part.
     14               MR. CACCIATORE: I'd like to have attached,
     15    in the event this is ever typed, a copy of the
     16    subpoena.
     17               I've advised my client that pursuant to
     18    Section 91.404 of the Florida Statutes, that she has
     19    been conferred what we lawyers commonly call use
     20    immunity.
     21               MR. McGARRY: Okay.
     22               MR. CACCIATORE: Thank you.
     23               (State Exhibit No. 1 is marked.)
     24                     EXAMINATION
     25    BY MR. McGARRY:

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      1          Q.   All right. Your name, please, for the record.
      2          A.   Brenda Hubert.
      3          Q.   And your occupation?
      4          A.   Sales representative for AMC Publishing.
      5          Q.   Okay. Not to pry, but your birth date?
      6          A.   X50.
      7          Q.   Okay. And how long have you lived in Clearwater?
      8          A.   Since December of 1993.
      9          Q.   Okay. And that's a relocation from Dallas, if I
      10   remember correctly?
      11         A.   Correct, uh-huh.
      12         Q.   Okay. Can you tell me a little bit about -- let's
      13   start back with your relationship with Lisa, since that
      14   probably goes back further than the company does, right?
      15         A.   Uh-huh. Oh, yeah.
      16         Q.   When did you first meet Lisa?
      17         A.   I met Lisa at the Church of Scientology
      18   originally, I don't remember the exact year, but around
      19   1980, 1981, somewhere in there.
      20         Q.   Okay. So that's your first meeting with her, is
      21   through the Church?
      22         A.   Correct.
      23         Q.   Okay. And that was before AMC, was it?
      24         A.   Oh, yeah.
      25         Q.   Okay. Was that a relationship that immediately

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      1    blossomed into a friendship from the get-go?
      2          A.   No. We were very casual acquaintances for quite
      3    some time. I just knew her as, you know, someone who came
      4    to the Church there. And she was just a member of the
      5    Church, as I was. And I would see her at the Church and at
      6    other social functions that we sometimes had, you know,
      7    Christmas parties, things like that.
      8               It was probably some, oh, I guess maybe four or
      9    five years later that we became closer friends. Both of us
      10   worked at that time for the Church. And at that point I had
      11   a much closer working relationship with her, and then also
      12   became personal friends with her as well.
      13         Q.   Okay. So sometime in the mid-'80s you guys were
      14    Staff, on Staff?
      15         A.   Uh-huh.
      16         Q.   Okay. What position did you hold at that time?
      17         A.   Several different positions. I originally started
      18    out working part-time for the Church, doing various
      19    administrative type things. I would go in and volunteer my
      20    time, whatever they needed done. And then later when I went
      21    to work for the Church full-time, I worked in the -- what's
      22    called the Qualifications Division, and I worked with Staff
      23    members with regard to what courses and training they were
      24    going to be doing, getting them trained up for their jobs
      25    within the Church, things like that. Later I worked in the

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      1    division of the organization where they hire personnel.
      2               And later I moved into an executive position, two
      3    3 different executive positions. One is a external position
      4    where I actually was -- my boss, if you will, actually was
      5    in Los Angeles and I worked as a -- sort of an outside
      6    entity over the organization and helped the organization
      7    with its growth and expansion through the use of programs
      8    that were used to get certain basic steps and functions that
      9    needed to be done into place and working within the
      10   organization. That's called the LRH Communications Post, is
      11   what it's called, but that's what the function of the job
      12   was.
      13              And then after that I became an executive over
      14   what's called the OES, the Organizational Executive
      15   Secretary, which is the senior executive over three
      16   different divisions of the organization. So I seniored all
      17   the personnel in three different divisions of the company --
      18   the organization, I should say --
      19         Q.   Wow.
      20         A.   -- not a company.
      21         Q.   Very impressive.
      22              Did -- were you aware what Lisa's post was at the
      23   time?
      24         A.   Yes.
      25         Q.   What did she do?

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      1          A.   She worked in what's call the Public -- the PES
      2    area, the Public Executive area, and she primarily worked
      3    with new people who were coming into the organization to
      4    find out about our services and what we did and what
      5    Scientology was and that sort of thing. So she introduced
      6    new people to what it was the Church was about and helped
      7    them get their questions answered.
      8          Q.   All right. Did she enjoy at that particular time
      9    a regular career before AMC, aside from the Church also?
      10         A.    Yes. We both had positions outside the Church.
      11    We worked mostly nights and weekends, full evenings, then
      12    all day Saturday and Sunday for the Church, and then both of
      13    us held other jobs as well.
      14         Q.    Okay. Do you recall what she did?
      15         A.    Well, when Lisa and I became really close we
      16    worked together at a company called Atlantic Financial
      17    Mortgage Corporation. And Lisa was a mortgage banker, and
      18    she basically solicited loans for the mortgage banking
      19    company. Went out and dealt with real estate people and
      20    helped them secure loans for their clients who were buying
      21    houses. And that was also my capacity there.
      22              She had been working for them for a while before I
      23    came to work for them. And so I, of course, had a working
      24    relationship with her there. In fact, we shared an office
      25    together there. So she worked a particular territory of the

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      1    Dallas area and I worked another territory, and we basically
      2    just went out and called on realtors on a regular basis to
      3    solicit loans.
      4          Q.   I think of all the people that I've talked to,
      5    which is pretty considerable now, you seem to have -- would
      6    you describe yourself as having the longest relationship, *
      7    longest ongoing relationship with Lisa around, I think in
      8    Clearwater? Maybe Benetta?
      9          A.   No, Benetta did not know Lisa as long as I did,
      10   so ...
      11         Q.   Right.
      12         A.   And I had a more personal relationship with Lisa
      13   than -- contrary to some people's beliefs, I believe, much
      14   more personal relationship with Lisa than Benetta did.
      15         Q.   Okay. We'll get to this thing. We're going to
      16   have to dissect your statement closely here because it's
      17   quite revealing of her actions.
      18              MR. CACCIATORE: Mr. McGarry, I don't mean to
      19   interrupt. Is it okay, she's nervous, can she have a
      20   copy of that in front of her when you ask her
      21   questions?
      22              MR. McGARRY: Sure, when we get it --
      23              THE WITNESS:  I actually brought a copy.
      24   I'll just put it out, if you want to ask me something.
      25              MR. CACCIATORE: Another thing I want to

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      1    point out, I meant to do this at the outset, I forgot,
      2    I just learned this recently, Brenda has a lot of
      3    information regarding what happened to Lisa the first
      4    time she went into the Church, some of the things that
      5    were going on with her.
      6    BY MR. McGARRY:
      7          Q.   Are we talking about the summer before this spin?
      8          A.   Yeah. I'm pretty familiar with most of the
      9    details about that.
      10         Q.   That was her first kind of break she had?
      11         A.   Exactly.
      12              DETECTIVE CARRASQUILLO: The one in July or
      13   June?
      14              THE WITNESS: Exactly.
      15              DETECTIVE CARRASQUILLO: Did you cut your
      16   hair?
      17             THE WITNESS: I did. Just the other day, in
      18   fact.
      19             DETECTIVE CARRASQUILLO: `Cause I remember
      20   you looked different when I met you that night.
      21             THE WITNESS: I cut about four or five inches
      22   off my hair Saturday.
      23             DETECTIVE CARRASQUILLO: And permed it?
      24             THE WITNESS: No. It's naturally curly.
      25             MR. McGARRY: All right.

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      1          THE WITNESS: I'm sorry.
      2          MR. McGARRY: That's okay. Back to Dallas.
      3          THE WITNESS: Yeah.
      4    BY MR. McGARRY:
      5          Q.   So how would you describe -- I understand Lisa
      6    started deteriorating somewhere in `94, `95, didn't look
      7    like she was holding herself together so good, but I take it
      8    this is -- this was bizarre behavior for her, going all the
      9    way -- you would know better than anybody -- correct?
      10              I mean, she was -- how would you describe her back
      11   in the `80s, if you can? Was she --
      12         A.   Lisa was a vivacious, outgoing, energetic, very
      13   sociable type of person. Made friends very easily. Very
      14   openly communicating with people on a regular basis. Had
      15   many, many acquaintances and some close friends, of course.
      16   She was -- had a tremendously wonderful sense of humor and
      17   was just sort of a -- the type of person who would play a
      18   practical joke on you, you know, and she always was looking
      19   for something funny, a funny joke to tell you or something
      20   humorous to pass along, you know. That's the type of person
      21   she was. Very jovial person.
      22         Q.   Right.
      23         A.   I've never met anybody like her before. She's
      24   very outgoing. Far more so than anyone I ever met.
      25         Q.   You socialized a lot in Dallas?

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      1          A.   In the later time. We actually became roommates
      2    and lived together for three years and that time we did a
      3    lot of socializing. Prior to that I wouldn't say we did a
      4    lot of socializing because both of us had full-time jobs and
      5    we worked at the Church almost every other waking hour. So
      6    I knew her because we worked at the -- very, very closely,
      7    but we didn't have a lot of time for socializing in our
      8    lives.
      9          Q.   You mentioned you lived together. Was that in
      10   Dallas?
      11         A.   Yes.
      12         Q.   What time was that?
      13         A.   Well, she came back from Los Angeles -- she had
      14   gone out there to live and be on Staff at the organization
      15   in California. And she came back, I believe it was in
      16   September, late August or early September of 1989, I
      17   believe. Might have been a little earlier than that, but
      18   somewhere in the summer months, right in that period of
      19   time. I could be a little off, but somewhere right in there
      20   she came back from Los Angeles.
      21              At that time I met her at a restaurant. She
      22   called me and told me she was in town and we agreed to have
      23   lunch together. And I went there and met her. And she told
      24   me that she was planning on moving in with her mother. And
      25   I was somewhat taken back by that because I knew a fair

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      1    amount about Lisa's mother, who -- she was an alcoholic; she
      2    was in real rough shape, and she had been drinking very
      3    heavily again. And she had been in rehab, I believe, and
      4    was back out again and drinking again.
      5                 And Lisa told me that she was trying to do
      6    Something to help her mother, and she felt like that she
      7    didn't know what to do, she was somewhat desperate about
      8    what to do with her mother. And I did not personally think
      9    that her moving in with her mother was a very good idea,
      10   because I thought her mother would just take her down with
      11   her instead of her being able to help her mother, because
      12   her mother had never very successfully been helped. Since
      13   she had gotten off the wagon and started drinking again, she
      14   was just like constantly in the toilet, so to speak.
      15         Q.   Right.
      16         A.   So while I didn't want -- while I thought she
      17   might be able to help her mother, I didn't want her to live
      18   there with her. I didn't think that would be the right
      19   thing for Lisa. So I encouraged her or invited her to come
      20   and live at my house, with my husband, at that time I was
      21   married, to come with my husband and I till she could kind
      22   of get on her -- she didn't have any money, she just came
      23   back, she needed to find work. She didn't have any
      24   resources, financial resources at that point. So she did
      25   move in with my husband and I in the spare room that we had.

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      1          Q.   Right.
      2          A.   And at that point we started living together.
      3          Q.   And then did she pick up a new job or did she go
      4    back to work at the Church?
      5          A.   No, not -- at that point she started to work again
      6    for the telephone company, which is a job she had many years
      7    before. She had been a service representative,
      8    Customer Service Representative for the phone company for
      9    many years, done really well at that. And she went back to
      10   work for the phone company at that time and was also working
      11   a part-time job doing sort of order taking at Domino's in
      12   the evening, couple, three nights a week.
      13         Q.   Okay. Somewhere along the line, I guess, right
      14   about in this period of time that we're talking AMC came in?
      15         A.   No. Actually a little bit later -- well, wasn't
      16   very much later than that, because I think she went to work
      17   for Jeff in January, maybe, of `90.
      18              We had both known Jeff Shaffner for quite a number
      19   of years. He too was a Scientologist, had been on Staff,
      20   worked for the Church there in Dallas. And we had known
      21   him, you know, in that capacity. And my ex-husband was in
      22   the insurance business and that was the business that Jeff
      23   was in also. And they knew one another because they were
      24   both in the insurance business and had common interests. So
      25   Jeff had been to our home a few times and to visit and that

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      1    sort of thing.
      2               And Jeff knew that Lisa had this tremendously
      3    great track record as a Customer Service Representative with
      4    the phone company and he, of course, knew how outgoing she
      5    was and vivacious she was. And so he called me and asked me
      6    if I thought I could talk her into coming to work for him.
      7    And at that point she'd only been back at the phone company
      8    a short time, but she was having to drive like 45 miles to
      9    work every day.
      10         Q.   Was AMC new at that time?
      11         A.   Yes, it was just Jeff by himself.
      12         Q.   I see. It was a brand new company?
      13         A. Yeah. Jeff had actually -- the way AMC or my
      14   understanding of how Jeff started AMC is that he was working
      15   for Union Bankers, the insurance company Union Bankers. And
      16   Jeff was a recruiter for Union Bankers, and he was trying to
      17   come up with some kind of way to easily find leads of new
      18   insurance agents for recruiting. And he had this bright
      19   idea that this direct mail program that we now advertise and
      20   publish would be a way to do that.
      21              And so he had other people in Texas who were in
      22   the insurance business that he knew, and he talked some of
      23   them into going in with him, and they put together the money
      24   to do an advertising publication. And Jeff did all the copy
      25   writing -- copy writing work on it and got it all set up and

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      1    mailed it out. And it was very successful. And these guys
      2    that he had done this for wanted him to do more of it.
      3               And so he was kind of doing this on the side, out
      4     of his apartment, you know --
      5          Q.   Right.
      6          A.   -- trying to get it going. And it was starting to
      7     take off, you know.
      8               And at that time he had decided he wanted to try
      9     to do that, pursue it as a business at that point. So he
      10    thought Lisa would be a good salesperson for these -- this
      11    advertising medium.
      12              Well, she was kind of a little -- not sure she
      13    wanted to go to work for Jeff, because she, quite frankly,
      14    thought that Jeff was interested in having a more personal
      15    relationship with her and she was not interested in Jeff in
      16    that way. And I said, Well --
      17         Q.   So I can follow you, Jeff's still one of the
      18    owners of the company?
      19         A.   That's correct, uh-huh.
      20         Q.   Okay.
      21         A.   Now, whether that was true or not, I can't speak
      22    to that, but that was her feeling.
      23         Q.   Okay.
      24         A.   Okay. That she communicated to me.
      25              I don't recall ever discussing that with Jeff to

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      1    ask him, but anyway, that was her viewpoint. And I said,
      2    Well, okay, but, you know, it looks like it's a job where
      3    you could make a lot more money. And she wasn't making a
      4    whole lot of money at the phone company, she was having to
      5    drive all this distance every day, she wasn't overly happy
      6    with what she was doing. So I finally talked her into it.
      7               So she went in and talked to Jeff. And that's how
      8    she came to work for Jeff. And then about six or eight
      9    weeks after that, things were going so well that they asked
      10   me if I would like to come and work for Jeff also. But I
      11   was going to handle all of the administrative aspects of the
      12   company while she sold and did the copy writing work and
      13   worked on the publications.
      14         Q.   This is even before David and Benetta became
      15   involved?
      16         A.   Yes.
      17         Q.   I didn't know that.
      18              DETECTIVE CARRASQUILLO: What year was that?
      19              MR. McGARRY: Must have been `90.
      20         A.   This is 1990, January. I came to work for them in
      21   March of 1990. So it. was just Jeff, me and Lisa at that
      22   time, in a little bitty office, real tiny.
      23         Q.   Right. And how did -- I guess it started adding
      24   employees from there on?
      25         A.   Well, actually, there remained the three of us for

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      1    a period of about six or seven months. And then Jeff had a
      2    meeting one day with Lisa and I and told us that David and
      3    Benetta, who at that time were living in California, were
      4    wanting to relocate back to Texas again. Now, Benetta had
      5    worked for them previously at Atlantic Financial, right, so
      6    we already had a working relationship with David and
      7    Benetta. And they were looking for a business opportunity
      8    to invest in in Dallas. And they had contacted Jeff about
      9    AMC. And Jeff let us know that he was negotiating with them
      10   as a possibility of forming a company together.
      11              And that is basically what happened. They came to
      12   Dallas, and I guess the three of them met and reviewed all
      13   the details of it and worked out a business deal, none of
      14   which Lisa and I were privy to, of course, and then they
      15   formed a corporation that became known as AMC Publishing, as
      16   far as a corporate entity.
      17              And then at that point we moved out of the tiny,
      18   little office we were in into larger quarters. And we hired
      19   Carol South, who was a graphic artist and knew a lot about
      20   copy writing work. And we knew her very well, had known her
      21   for years, also through the Church, and we were all friends.
      22   And she came to work to hold up that end of the thing so
      23   that Jeff could do more selling and less of copy writing or
      24   artwork for the publication. So then there were just the
      25   five of us.

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      1          Q.   All right. Didn't -- did Lisa run into some
      2    financial problems in Texas before she came here? Because I
      3    thought I read somewhere where she declared bankruptcy over
      4    there. Do you know anything about that?
      5          A.   Yeah, I know a bit about it.
      6               When she was working for Atlantic Financial, for
      7     the mortgage company, she was making very good money. I
      8     don't have personal knowledge, I never saw her W-2 Forms or
      9     whatever --
      10         Q.   Right.
      11         A.   -- but I know she was the top salesperson there.
      12    She was a very good salesperson. And knowing what the
      13    compensation for the job was and knowing what she was
      14    producing, it's fairly easy for me to extrapolate what kind
      15    of money she was making, and it was substantial.
      16         Q.   Right.
      17         A.   At that time he was married to Gene Skonetski, her
      18    name at that time was Skonetski, and she and Gene -- Lisa
      19    was never a person who really cared very much about money.
      20    To be candid, she just kind of was a free -- freewheeler
      21    when it came to money.
      22         Q.   Right.
      23         A.   She'd give it to Gene, and Gene would spend it.
      24    And Gene was very good at spending it, let me tell you. He
      25    bought a red Porche and a car phone and, you know, fancier

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      1    clothes and this, that and the other thing that Gene spent
      2    the money on.
      3          Q.   Right.
      4          A.   And, you know, they lived pretty -- pretty well,
      5    comfortably. And they donated a lot of money to the Church,
      6    and paid for a lot of things like that they wanted to do.
      7               And then she and Gene -- when they split up, Gene
      8    joined the C Organization and went to work in California
      9    full-time, of course. He was already working full-time for
      10   the Church in Dallas.
      11         Q.   Right.
      12              DETECTIVE CARRASQUILLO: Pardon me. Could
      13   you spell Skonetski.
      14              THE WITNESS: S-k-o-n-e-t-s-k-i.
      15              DETECTIVE CARRASQUILLO: Thanks.
      16         A.   Lisa was the one making the money anyway.
      17         Q.   Right.
      18         A.   Well, when he went into the C Organization he had
      19   no financial resources to pay the debts that they had
      20   incurred and he left Lisa with basically all the debt. And
      21   then not too long after that she also went to L.A. and went
      22   into the C Organization. And the debts just sort of sat
      23   there, you know, for the time she was out there. She wasn't
      24   there for a very long period of time before she left and
      25   came back.

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      1          Q.   And we know we're not going to make any money
      2    working for the Church.
      3          A.   She was not making what she was making --
      4          Q.   Enough to live on?
      5          A.   Certainly not what she was making in an outside
      6    sales job. I mean, it's not comparable income, that's true.
      7          Q.   Right.
      8          A.   So anyway, when she came back and they were
      9    actually going to get a divorce, hadn't been able to put
      10   their marriage back together, she had nothing. You know,
      11   she had no resources, nothing; no money, no nothing. So at
      12   that point she filed bankruptcy.
      13         Q.   So this is before you guys moved in together and
      14   before AMC?
      15         A.   Yeah. It's actually pretty much date coincident.
      16   All that was going on at about the same time. I can't give
      17   you specific dates, but it was all happening pretty much
      18   right in there at the same time frame. She came back from
      19   L.A., she had no money, not too long after that she filed
      20   for a divorce. Then she filed for bankruptcy at some point
      21   in there, I'm not sure exactly when.
      22         Q.   Okay.
      23         A.   So...
      24         Q.   At some point in time chronologically, correct me
      25   if I'm wrong, but now AMC decides -- I guess the owners

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      1    decide we're going to relocate it to Clearwater?
      2          A.   Well, actually what occurred is, the company
      3    continued to grow. We took on a lot of other employees. We
      4    had quite a number of people working for us. We increased
      5    the number of advertising publications we were mailing. You
      6    know, we were growing.
      7               And David and Benetta had always wanted to live in
      8    Florida. That was a goal of theirs for a long time. Many
      9    of the people who worked for the company had an interest in
      1O   that also because the main -- one of the biggest
      11   organizations for the Church is here in this area. And most
      12   all of us were wanting to do various services and things
      13   that were available here that were not available there. So
      14   we all had a joint interest in that.
      15              And so we had a meeting as a group of employees
      16   with the owners of AMC and said, Is this, something you guys
      17   are interested in? Are you -- is this a game you want to
      18   play to try to make this happen? And we thought it was a
      19   window of opportunity. We were at a point where most
      20   everybody was in agreement that they wanted to go, you know.
      21   And we figured if we didn't do it within that window period
      22   of time, we were going to continues to expand, bringing on
      23   more and more people, and then perhaps not everyone within
      24   that group would have that same common goal.
      25              And there would come a point where it wasn't going

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      1    to be something that could be easily done. Not that it was
      2    easily done anyway, because it took a lot, a great deal of
      3    work on all of our parts to make it a reality. You don't
      *    just pick up and move 16 families across the country and a
      5    whole company without there being a lot of planning to make
      6    it happen and execution. And so we decided that's what we
      7    wanted to do and we did it.
      8          Q.   What year was that?
      9          A.   That was 1993, I believe it was March or April,
      10   and we moved the end of December. And the reason we moved
      11   at that time, that's a very slow period of time for us, and
      12   that was the window of opportunity to be able to close down
      13   for a week and open right up right at the beginning of the
      14   week and be ready to rock and roll on our publication
      15   starting at the beginning of the year. Most people don't
      16   want to do mailings, you know, in the holiday season. So
      17   that was the reason we did it in that short -- we made the
      18   whole move in a week.
      19         Q.   Wow.
      20         A.   It was impressive, I thought.
      21         Q.   So Lisa -- she had a little easier go because she
      22   was by herself at the time. So she just came and, I guess,
      23   found herself an apartment or something?
      24         A.   Yep. She -- well, we had lived together, roomed
      25   together there in Dallas for some time, from the time she

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      1    became back from L.A. up until -- I can't remember the exact
      2    time frame that she actually moved out and got her own
      3    apartment, but at some point along the line, about maybe 10,
      4    11 months before we made the move down here she decided she
      5    wanted to get her own apartment. So she had leased an
      6    apartment in the same apartment complex where I was living.
      7    And so she was living there, but she never did -- she didn't
      8    have any furniture, you know.
      9               When she came back from L.A. she didn't have
      10   anything, you know, except her clothes and an old beat-up
      11   car. And so she had accumulated a few things. She bought a
      12   few -- little sofa, you know, little bit of furniture. It
      13   was a real small, little apartment. She didn't need much.
      14   And that's where she was living when we made the move. Most
      15   everything she had she sold when we came down here. She
      16   didn't want to move what little bit of furniture she had,
      17   she just decided she was going to buy new things when she
      18   got here. So she sold most of her used furniture and only
      19   moved a very few things here when we came.
      20         Q.   I take it she was still very active in the Church
      21   from reading some accounts, and she was very taken with
      22   achieving Clear and progressing up the ladder. And
      23   ultimately she did reach Clear, I think?
      24         A.   Certainly. She was very interested in moving
      25   forward with her training and processing through the Church,

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      1    that's correct.
      2          Q.   She had a -- when she moved to Clearwater, did
      3    you -- were you able to observe or did she ever tell you
      4    that she had any medical problems that she was -- that were
      5    bothering her? I've talked to her chiropractor so I know
      6    she had some problems with her back.
      7          A.   Yeah, Lisa had -- she had some problem with her
      8    neck and her back. She had headaches periodically,
      9    sometimes fairly severe headaches. Mostly, I think it had
      10   to do with -- I'm sure the chiropractor told you, but having
      11   to do like with the muscles here in this part of her neck
      12   and the back part of her vertebrae here in her neck.
      13              I used to -- she would wake me sometimes when we
      14   were living together, and she would get these in the night a
      15   lot of times, maybe it had something to do with the way she
      16   slept, I don't know, but she would seem to get them in the
      17   night, and sometimes she would wake me up and I would get up
      18   and rub -- massage her shoulders, and it would just be like
      19   a rock, you know.
      20         Q.   Right.
      21         A.   And that shoulder would be just like a rock. And
      22   she would cry with her head, it hurt so bad.
      23         Q.   She was also into health foods, do you know when
      24   that began, vitamins?
      25         A.   Supplements and things, vitamins?

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      1          Q.   Yeah.
      2          A.   Well, she always took vitamins, ever since I can
      3    remember. I don't know when that started.
      4          Q.   Okay.
      5               DETECTIVE SERGEANT ANDREWS: Cal mag.
      6               THE WITNESS: Calcium magnesium.
      7               DETECTIVE SERGEANT ANDREWS: Super blue-green
      8    algae.
      9               THE WITNESS: I don't know about her interest
      10   in that.
      11         A.   During the time I knew her she always took like
      12   multiple vitamins and things every day. And she was a
      13   believer in that sort of thing.
      14              Other than the headaches that Lisa had, and that
      15   she did have one flare-up with her back not very long before
      16   we moved down here, she had a disk problem in her low back
      17   that bothered her for a while and she had to get -- I
      18   thought she might have to get surgery on it at one point.
      19   She managed to get a lot of care for it and therapy,
      20   physical therapy and whatnot, it seemed to repair and it
      21   healed up and she didn't have any more problems with it.
      22   But other than those two things, Lisa was an extremely
      23   healthy person, physically, as far as anything I ever knew
      24   about her, observed.
      25         Q.   Once AMC got up and running in Clearwater, she

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      1    went right back in the same position that you were doing,
      2    that's in sales?
      3          A.   Right. I actually came onto the sales line and
      4    became involved in sales about a year after I went to work
      5    for the company. I was doing all of the administrative work
      6    for them originally. And then, I'm a much better
      7    salesperson than I am an administrative person, so they were
      8    working to get us to the point where they could have someone
      9    replace me so I could go into the sales area and we could
      10   expand to another salesperson. So that was about a year
      11   after I started to work for them that I moved over into
      12   sales.
      13         Q.   Okay. Lisa was always in sales?
      14         A.   Yeah. Customer service type work and sales all
      15   the time that I knew her, yeah.
      16         Q.   Okay. While she was here in Clearwater, was there
      17   a lot of pressure for her to -- I imagine AMC, it seems to
      18   me, puts a lot of pressure for everybody to make a quota,
      19   make their production. Was that a big thing with her, that
      20   it was too much for her?
      21         A.   Lisa was -- let me put it to you this way: Lisa
      22   herself was one of the most production oriented,
      23   self-motivated salespeople I've ever met. She did not have
      24   to have somebody quota her.
      25         Q.   Right.

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      1          A.   She quota'd herself.
      2          Q.   She was self-motivated?
      3          A.   She was very self-motivated.
      4          Q.   Any pressure she was under was probably
      5    self-applied?
      6          A.   I'll tell you, she did so exceptionally well that
      7    she was in excess of her quotas in almost every instance.
      8    And I mean, there is no pressure when you are on top of the
      9    game, there's only pressure when you are below the game and
      10   trying to come up to speed. So she was --
      11         Q.   Right.
      12         A.   So she was doing exceptionally well. I can't
      13   stress enough what an outstanding salesperson she was. And
      14   very self-motivated individual. And she drove herself in
      15   the area of production.
      16              But yes, we do -- to answer your question more
      17   fully, we do all have sales quotas, that's correct. All
      18   sales organizations I've ever worked for have sales quotas.
      19   And yes, we were expected to meet those quotas, that is true
      20   and correct.
      21         Q.   All right. Starting -- going back to the summer
      22   that she had her initial psychotic break, that's what people
      23   call it, tell us about that period of time.
      24         A.   Well, I went away, I was gone on a trip for about
      25     six weeks in the summer or late spring, actually, April and

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      1    May, first part of May, and I was not here during that time.
      2    I talked to her on the telephone a couple of times during
      3    that time period.
      4               The first conversation, she seemed to be quite
      5    up-beat, everything was going well, she -- nothing out of
      6    the ordinary, you know, just her normal -- .the way she
      7    always was, you know, telling me about this, that, the other
      8    thing, keeping her busy, just normal routine things.
      9               The second time I talked with her, which was
      10   probably about three or four weeks later, I don't know, I
      11   just felt like something was not -- something wasn't right,
      12   you know. She didn't sound as up-beat. She seemed a little
      13   despondent, a little down, which was pretty noticeable
      14   because she was so much the other way all the time, you
      15   know. And yet I was 1200 miles away when I was talking to
      16   her on the phone, and I -- I didn't really feel that it was
      17   appropriate to try to get into whatever the problem was over
      18   that long a distance communication. And I was expected
      19   back -- to be home in a short period of time and I thought,
      20   well, she -- it's probably nothing. Maybe she just had a
      21   bad day the day I talked to her. I didn't put too much into
      22   it.
      23              And -- but then when I got back I attempted to
      24   talk with her on a couple of occasions and she was very --
      25   was kind of strange. She was like, I don't want to talk to

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      1    you. I'm just not in the mood right now. Really shut me
      2    off. Like she'd never ever done before, you know. And I
      3    thought that was really odd. But I thought, well, I mean,
      4    you know, I go away and I think, well, maybe she's having a
      5    problem in her relationship with Kurt, because she was
      6    dating Kurt Payne at the time. I didn't know what the
      7    problem was, I just knew she shoved me away and didn't want
      8    to talk.
      9               And then about a week or so after that took place
      10   and I made a couple of attempts to communicate with her and
      11   sort of she cut me off, she came to my office late one
      12   afternoon, after hours, and I still happened to be there.
      13   She closed the door in my office and she started crying.
      14   And I said, you know, I don't understand what -- you know,
      15   is something -- what's upset you, you know. And she said
      16   she just didn't know, she was very unhappy, and nothing was
      17   going the way she wanted it to. And she wasn't happy
      18   with -- she was doing -- had been doing this auditing action
      19   at the Church, she was not doing well with that, it wasn't
      20   going well. She didn't know what was wrong, but she knew
      21   something was wrong and she couldn't figure it out. And she
      22   didn't know who to talk to about it.
      23              Well, when she started telling me, you know, that
      24   she was doing this auditing action at the Church. As a
      25   Scientologist, my practice of our religious beliefs is that

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      1    when someone is doing that type of action, they -- it's not
      2    data that needs to come onto my lines, you know, it needs to
      3    be put in the proper place so it can be handled properly.
      4    And I wasn't the right person for her to be telling this to.
      5    I couldn't handle it or help her with it.
      6               So I asked her if she had talked to the right
      7    person. And she --
      8          Q.   Would that have been her CS?
      9          A.   No. She would have actually gone to the
      10   Director of Processing or to the Examiner, one or the other,
      11   and made a statement about it, so then the CS could have
      12   been given the data. That would have been the way it would
      13   have been done. or she could have written up something and
      14   had it routed directly to the Case Supervisor.
      15         Q.   Who was at that time, do you remember?
      16         A.   Who was what?
      17         Q.   Was that Kartuzinski or somebody before him?
      18         A.   I have no idea. I have no data on who her Auditor
      19   or CS ever were, nor do I know who her D of P was, I don't
      20   know.
      21              MR. CACCIATORE: I'm sorry. I don't mean to
      22   interrupt. I don't know what a D of P is.
      23              THE WITNESS: D of P, Director of Processing.
      24              That's just the person who's responsible for getting
      25   the PCs, the pre-Clears into session.

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      1               MR. CACCIATORE: Okay, thanks.
      2          A.   I asked her had she given this information to them
      3    and she said no, she just didn't knows quite what to
      4    communicate. And I said, Well, Lisa, you know as well as I
      5    do that you need to go in and -- and make a statement so
      6    that they know that there's something wrong so that it can
      7    be addressed and fixed. And she was like, I know I do, but
      8    I just don't know what to do. She was very emotional,
      9    crying, very upset. So -- but she promised that she would.
      10   So I said, Now, you'll go there immediately? She said, Yes,
      11   I'll -- I'll go. I'll have something to eat and I'll go
      12   this evening immediately. I said, Okay, fine.
      13              I did check with her to make sure she had done
      14   that. She did do that. I also at that time wrote a note to
      15   the Director of Processing about the conversation I'd had
      16   with her and said, I don't know what the problem is, but
      17   obviously something is wrong, you know, she needs help.
      18         Q.   Who was that at the time?
      19         A.   I just routed it to the job, the title of the job,
      20   because I never know the person assigned.
      21              And I just took it down there and turned it in and
      22   said, here's some data, you know, for you to help her.
      23              And then I checked with her later to make sure she
      24   had gone. She had. And then she seemed to be doing a
      25   little better, you know.

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      1               And then, let's see, how long after that? I don't
      2    know. She was kind of up and down, you know, one day she
      3    would look like she was doing okay and another day she
      4    didn't look like she was doing so okay, she looked unhappy
      5    and just not her normal self.
      6               Once again, I didn't get into asking her a lot
      7    about it, because, again, it's not my place to do that when
      8    she's in the middle of this. I'm gonna be a person
      9    interjecting myself in the middle of something I don't need
      10   to be in the middle of. So I was just observing and letting
      11   her move through and work out whatever she needed to on it,
      12   but being there as a support person for her, if she needed
      13   me, of course.
      14              She came to me on another occasion, somewhat in
      15   the same state of mind. I did pretty much the same thing
      16   again with her. And then I was told, I believe I got the
      17   data from Benetta, but I can't in all honesty tell you that
      18   this is exactly correct, `cause I can't remember how it came
      19   to be that I found this out, but I was told that she had
      20   decided she was gonna take some time off of work and she was
      21   gonna go to the Church and she was gonna just move into the
      22   hotel and she was gonna work on this on a more full-time
      23   basis so that it could get handled.
      24         Q.   And she did that, I believe?
      25         A.   And she did go and do that.

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      1               MR. CACCIATORE: I apologize, you had
      2    indicated to me whenever we last talked before today
      3    that at some point in time before she went there, what
      4    caused you to write this note was she had indicated to
      5    you some language where you thought she was
      6    contemplating suicide.
      7               THE WITNESS: That's correct.
      8               MR. CACCIATORE: Now would you tell them
      9    about that.
      10         A.   She had told me in the last -- I'm glad you
      11   reminded me.
      12              She had told me in the last conversation, the last
      13   time she came to me that -- she just kept saying, I just
      14   don't think I want to live anymore. I just don't think I
      15   want to live anymore. And I'm like, Oh, my God, you know,
      16   what is this all about?
      17              DETECTIVE CARRASQUILLO: Excuse me. Could
      18   you give us the time frame you've been talking about?
      19              Is this the beginning of `95, middle of `95?
      20              MR. McGARRY: This is the summer.
      21              THE WITNESS: This is the summer of `95,
      22   June.
      23              MR. McGARRY: The summer of `95 when she's
      24   having her first psychotic break, which would be July.
      25              DETECTIVE SERGEANT ANDREWS: June, July,

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      1    August.
      2               DETECTIVE CARRASQUILLO: When did she say
      3    about the suicide?
      4               THE WITNESS: What did she say?
      5               DETECTIVE CARRASQUILLO: When? When?
      6               THE WITNESS: When? It's really hard for me,
      7    `cause I didn't date all this stuff in my head at the
      8    time, but it had to have been like late June. Latter
      9    part of June is my best guess. Maybe even mid-June.
      10              Mid to late June, somewhere in there.
      11         A.   Anyway, she said this to me more than one time.
      12   So I was, of course, concerned about that. I mean, your
      13   best friend says something like this to you, you can't help
      14   but think, oh, my goodness, you know.
      15              MR. CACCIATORE: And was it that statement,
      16   not wanting to live anymore, that caused you to do this
      17   note to the --
      18         A.   Well, the second time I wrote a note. The first
      19   time I wrote the note I just wrote it because she was so
      20   distraught and upset. The second time, she was also
      21   distraught --
      22         Q.   This is later?
      23         A.   This is later, but yes, at that time. I had two
      24    different notes I wrote.
      25              MR. CACCIATORE: Did you type them out?

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      1               THE WITNESS: Yes, I typed them out, gave
      2    them the information.
      3          Q.   So there's one previous note to this?
      4          A.   Two previous to this one.
      5          Q.   And it relates your concerns about her statements
      6    as well as her well-being?
      7          A.   To the best of my ability to recall, there are two
      8    that I wrote.
      9          Q.   And that was to the Processing Director?
      10         A.   Right. They were taken down to be given to the
      11   people handling her, whoever that was.
      12         Q.   Okay.
      13         A.   Then I was told she had decided to go take the
      14   sabbatical from work and go to the hotel and just work on
      15   this. And I thought that -- I was relieved, because totally
      16   removed from having to work and having to worry about that,
      17   you know, or put her attention on that, or whatever else she
      18   has going on in life, if she's just there doing that, then
      19   it's going to be a completely non-stressful thing, she's
      20   going to have a chance to take a look at whatever is
      21   bothering her and get it handled, you know. So I was very
      22   relieved and felt promising about it.
      23              During that time she came to my home on one
      24   occasion with Susanne, who was at that time staying with
      25   her. She was the girl that was driving her around if she

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      1    went out or taking her places and just looking -- staying
      2    with her, making sure whatever her needs were.
      3          Q.   That would be Susanne Greene?
      4          A.   I never knew Susanne's last name.
      5          Q.   She was originally Schnurrenberger.
      6          A.   Yeah, she had this real long name, I think.
      7          Q.   She remarried, I think.
      8          A.  I had never met her before that. Anyway, she
      9    seemed like a real sweet girl. Her and Lisa got along quite
      10   well. She came to my house at least once, if not twice.
      11   Everything seemed to be going, you know, according to plan.
      12              My friend Gilda had told me -- Gilda doesn't work,
      13   so she had gone down to the Church to spend some time with
      14   Lisa, had played cards with her, you know, just visited with
      15   her. And she reported back to me that Lisa seemed to be
      16   doing better and, you know, things were going well. So I
      17   was very hopeful that it was going to get all straightened
      18   out.
      19         Q.   Was she taking a course there or was there any --
      20   just auditing or do you know?
      21         A.   I think she was doing mostly auditing, but I don't
      22   really have any personal direct knowledge of what all they
      23   were doing with her or what she was doing.
      24         Q.   Okay.
      25         A.   That continued, and then the next thing I know it

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      1    was August. My husband's birthday is in August, the 12th,
      2    and I had -- was giving a party for him. And I had invited,
      3    you know, a lot of our friends over for the day for a
      4    cook-out and swimming and what not. And I found out that
      5    somehow Lisa had been told about it, I don't know if Gilda
      6    told her or how she found out, however I was told she was
      7    going to get to come. And I was so excited because I hadn't
      8    seen her for probably three or four weeks at that point.
      9               And so she did come to the party that day. And
      10   she was looking, oh, tremendously much better, you know.
      11   She was much brighter, much more like her normal self, you
      12   know. And I was very happy to see that she was looking so
      13   good.
      14              And then shortly after that she left. You know,
      15   she came -- checked out of the hotel and moved back to her
      16   apartment and came back to work not too long after that.
      17   Week or so, I think, later. And everything seemed to be
      18   totally fine with her. I mean, she was just like back to
      19   herself again.
      20              She came to me and said, Gosh, I feel like that we
      21   haven't had a chance to communicate and spend any time
      22   together. And I really feel bad about that and let's get
      23   together and go do something for a day, you know. Let's go
      24   out and go shopping and spend the day together. And I said,
      25   Okay, that would be great. So we did.

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      1               And it was on a Saturday. It was a beautiful day
      2    that day. And we went to Sea Sea Riders over in Dunedin and
      3    had lunch. Sat out on the porch and had a probably
      4    three-hour conversation, and we just laughed and talked
      5    about all kinds of things. And she was just like so totally
      6    relaxed and so totally back to herself. I just was very
      7    impressed with how she was doing at that time. Then we went
      8    shopping and we bought her a bunch of new clothes. And, you
      9    know, we -- we just had a really good day that day. We
      10   spent the whole day together.
      11              And then --
      12              MR. CACCIATORE: This is in August still?
      13              THE WITNESS: Uh-huh. This was, I'm
      14   thinking, late August at that point, maybe first week
      15   of September.
      16         Q.   September 7th she gets Clear, graduates to Clear?
      17         A.   Uh-huh.
      18         Q.   And I guess she had a big ceremony.
      19              Did you go to that?
      20         A.   I did.
      21         Q.   Okay. Things from September, October, how were
      22   they then, pretty normal or --
      23         A.   Well, she moved -- when she first came back to
      24   work, of course, she had been gone a fair amount of time in
      25   there and there had been like a lot of shifting personnel to

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      1    try to -- you have to understand, when Lisa was not there, I
      2    mean, obviously this was a person who produced a lot of
      3    sales for the company and so there were a number of people
      4    scurrying around trying to --
      5          Q.   Who took her accounts?
      6          A.   We all helped. I mean, we didn't take her
      7    accounts, we worked her accounts, sort of split them up
      8    amongst us and were just frantically trying to cover
      9    everything else, because there was no much added workload
      10   for each person and it was trying to make sure everything
      11   was covered and handled.
      12              So there were some other people that were handling
      13   the magazine and then, of course, those of us who were
      14   handling the Card-Pack Division, they were doing all the
      15   selling for that. Lisa had moved out of the Card-Pack
      16   Division anyway and was selling primarily magazines, but
      17   everybody was scurrying to cover everything. Everybody was
      18   happy to do that. There's really not a problem, just had
      19   the added extra workload, you know, when a person is
      20   missing, we had to get it together and make it happen.
      21         Q.   Right.
      22              Gloria moved in with her at that point, Cruz?
      23         A.   I don't have a clue. I can't tell you when Gloria
      24   moved in with her, I don't know.
      25              I think you were asking me how she seemed at that

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      1    period of time, so I was going to try to finish answering
      2    that.
      3          Q.   Okay.
      4          A.   She was working, when she first came back, doing
      5    some administrative type work originally, then -- `cause
      6    Benetta was trying to help her get back into things again
      7    and figure out where we were going to put her, whether she's
      8    going back to the magazine or where was she going to work,
      9    you know, when she came back in.
      10              So it was finally decided, due to some other
      11   personnel changes, that she would come back to work in the
      12   Card-Pack Division again. So she did come back into our
      13   area now for the period, which was only about two or three
      14   weeks before we went to Orlando for the trade show, so it
      15   had to be the last week of October, first week of November.
      16              So before that period she was not in my area, so
      17   there would be sometimes like all day long I would hardly
      18   see her because she was working on the other end of the
      19   building. So I don't know for sure how she was doing, you
      20   know. But once she came back into the division where I was
      21   working, she seemed to be doing pretty good.
      22              As we moved along, I do look back, I noticed two
      23   distinct things that at the time I didn't think very much
      24   about them, but in retrospect I think a lot about them.
      25              One is a strange conversation that took place in

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      1    the Sales Manager's office one day when we were talking
      2    about our sales and what we were trying to get accomplished
      3    and the plan for the next publications we were trying to get
      4    done. And we were shorthanded of personnel. Two of our
      5    people had left, and the area was shorthanded. And Lisa
      6    made the remark to all of us that were there that she wanted
      7    to go over to Kay Proctor's and see if she could talk
      8    Kay Proctor into coming back to work for AMC.
      9               Well, you have to understand, this was a very odd
      10   statement, because Kay Proctor had left under some, you
      11   know, circumstances that made it -- to us in the sales area,
      12   we didn't want Kay to come back to work for us, you know.
      13   There was dissatisfaction on Kay's part with the job she had
      14   been doing, dissatisfaction with selling. I'm sure you
      15   probably already know some of this. So whatever the
      16   circumstances were of that, we didn't want Kay Proctor to
      17   come back to work in our division. So we thought -- we were
      18   kind of all looking at each other like, Why would she say
      19   that? You know, it was an odd statement.
      20         Q.   Right.
      21         A.   And then we thought, well, maybe she just -- she
      22   really -- Lisa always really liked Kay and maybe she just
      23   really wanted to try to get her to come back and make
      24   everything right again and see if we could put it all back
      25   together and be a team again. I don't know what her

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      1    thinking was, but we thought that was odd.
      2               The second thing that was odd was that about three
      3    weeks before we went to Orlando I heard her on the
      4    telephone, which her office was directly adjacent to mine
      5    and her voice is like mine, carries, and I could almost hear
      6    everything she said when she was talking to her clients.
      7    And I heard her on the telephone basically interrogating one
      8    of her clients. I mean, she's like not selling this person
      9    or not working to help this person to get into the
      10   publication, but interrogating this man. Like, what do you
      11   mean you're not going to do this, how dare you tell me that,
      12   of course you're going to do this, you can't not do this. I
      13   mean, almost exactly that --
      14         Q.   That was in Orlando?
      15         A.   No, this is about --
      16         Q.   Prior to Orlando?
      17         A.   Right before.
      18              Very off-the-wall type of thing you would never
      19   say to a client. And I'm like, what is she doing, you know.
      20   I thought maybe I just walked into -- what I overheard, I
      21   just took it out of concept -- out of context, rather. I
      22   thought that was odd. But it happened twice.
      23              The second time Benetta happened to be coming down
      24   the hallway and overheard her doing it. And she went into
      25   her office and asked her, What the hell are you doing, you

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      1    know, what are you saying to this person? And she was sort
      2    of nonplussed, you know, she couldn't quite get herself
      3    together. And Benetta said, Just knock it off. Just sell
      4    the guy. Don't interrogate him, just sell him. That was
      5    pretty much what she said. It wasn't like it was big deal
      6    or something, it was just like, don't do that, sell the guy.
      7    But looking back now, that was a very odd thing.
      8          Q.   The beginning of what soon became very odd
      9    behavior in Orlando?
      10         A.   Exactly.
      11              So those are the only things I really noticed
      12   during that time that were peculiar, looking back on it.
      13         Q.   Before we go to Orlando and your typed statement,
      14   how did she feel about -- I mean, being a friend of hers for
      15   so long, and I know how Scientologists feel about the
      16   psychiatric field, I mean, that's not -- that's not
      17   something that she would ever, ever consider, right? I
      18   mean, she would never consider going to psychiatrist or
      19   psychologist to help her
      20         A.   Definitely not.
      21         Q.   Right. Okay. That's well known and documented
      22   and that's L. Ron Hubbard's teachings from way back?
      23         A.   Right. And that was definitely embraced by her.
      24         Q.   She felt that way?
      25         A.   Right, strongly.

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      1          Q.   Okay. How about the medical profession in
      2    general, she didn't hold any animosity or suspicions over
      3    the general practitioners or doctors in general, did she, or
      4    do you know?
      5          A.   Well, not to my knowledge. I mean, I think her
      6    viewpoint is that, you know, she was a healthy person, she
      7    hardly ever had need for a doctor. I mean, she did get her
      8    regular gynecological check-ups every year, she was pretty
      9    good about that. I never did notice her having any
      10   objection or -- or never any statements saying she didn't
      11   want to do that. I never heard her say she distrusted
      12   doctors or anything like that.
      13         Q.   You know Dr. Decuypere, right?
      14         A.   I know her very well. She's my doctor too.
      15         Q.   She was going to Dr. Decuypere as well?
      16         A.   I knew that. And, of course, Lisa had worked for
      17   a dentist, she worked for a dentist in Dallas for some
      18   time, so I don't think she had any aversion to it. But on
      19   the other hand, I don't think she embraced it with any great
      20   degree of love and affection either, you know.
      21         Q.   The reason I ask that question, I don't know
      22   whether she knew Dr. Minkoff or not -- I don't know if you
      23   do or not. Do you know Dr. Minkoff?
      24         A.   I do not. Never met him.
      25         Q.   He's a Scientologist. And I think he's an

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      1    OT-VIII. Are you an OT-VIII?
      2               MR. CACCIATORE: We're going to object on the
      3    basis of religious freedom, also on the basis of
      4    relevancy.
      5          Q.   All right. Doesn't really matter. I mean, I'm
      6    not asking you what it took to get to your particular level
      7    but I was curious as to -- as far as putting you and
      8    Dr. Decuypere -- actually, Dr. Decuypere didn't have any
      9    problem telling me she's OT-VIII.
      10         A.   Well, I've been a Scientologist for almost 25
      11   years, so I've been around for a long time.
      12         Q.   Way passed Clear, I'm sure.
      13         A.   Been around a while.
      14         Q.   So you don't know whether or not, being friends
      15   with her for a long period of time, whether she would -- if
      16   she was in a sick state or, you know, in a medical
      17   condition, would insist on going to only a Scientologist as
      18   a doctor, or would that -- would you know the answer to
      19   that?
      20         A.   I wouldn't have a clue.
      21         Q.   Okay. Moving on to Orlando, I don't want to --
      22   this is a very detailed and quite descriptive document that
      23   you've put together. I don't really necessarily need to go
      24   through this whole thing and have you rehash it. Plus, I'm
      25   sure Ruth here would probably appreciate it if we wouldn't

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      1    do that either.
      2          A.   I don't blame you, Ruth.
      3          Q.   I did have some questions about -- about how this
      4    came to be, this document.
      5               It's dated November 19th. You've already
      6    indicated that you did a couple of these documents, or I
      7    guess you call them Data or Knowledge Reports, and then
      8    routed them through the Church for Lisa's benefit, to help
      9    her -- help her problem, to the people that were auditing
      10   her and processing her.
      11              Is that what this falls into? Is that the
      12   category this document falls into, the same type of thing?
      13              MR. CACCIATORE: She can't get down the nod.
      14   You have to orally answer.
      15              THE WITNESS: I'm sorry. Sorry, Ruth.
      16         A.   Yes, it was the same type of document, just
      17   informational data to help them help her, so they would know
      18   more.
      19              I mean, basically the information they really
      20   needed would have to come from her, right? I mean, she's
      21   the only one that knew what's going on with her. At least
      22   my observations might help them know what things to ask,
      23   might get her to tell them what the situation was. So my
      24   purpose in writing it was strictly to give them as much
      25   information as I could that might allow them to pull a

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      1    string or, you know, lead them down a path that would help
      2    them get what is really the problem here, you know, so it
      3    could be addressed.
      4          Q.   Okay. So November 19th. Let me get my little
      5    calendar out here and get myself situated on when this
      6    occurred. She had car accident Saturday, the 17th.
      7          A.   Thanks.
      8          Q.   That's the same thing I'm looking at. That will
      9    help you. And that calendar is a November, `95 calendar.
      10         A.   Right.
      11         Q.   So if you look at -- the 18th is a Saturday. I
      12   guess you guys had been in Orlando earlier that week,
      13   starting what, Monday or Tuesday?
      14         A.   No. I think we went -- if memory serves me right,
      15I  think we went early Wednesday morning.
      16         Q.   Wednesday, right, Wednesday, Thursday, and I guess
      17   you guys --
      18         A.   Lisa came home on the night of the 17th.
      19         Q.   Okay. Friday, right.
      20              And then Saturday she had her accident?
      21         A.   Right.
      22         Q.   This is -- your document here is dated the 19th,
      23   which is the following Sunday.
      24         A.   Correct.
      25         Q.   Okay. So did you do this document after you knew

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      1    that she'd already had her accident and she --
      2          A.   Yes.
      3          Q.   -- went to Morton Plant --
      4          A.   Yes.
      5          Q.   -- and then went to the Church?
      6          A.   Yes.
      7          Q.   Okay. So this makes sense to me, I kind of -- I
      8    didn't know chronologically what information you were
      9    relying on.
      10              So you knew of the accident, you knew that she was
      11   running around the streets naked, and I guess that's what
      12   prompted you to --
      13         A.   Well, I was going to write this information
      14   anyway.
      15         Q.   That certainly made it more important?
      16         A.   Yeah. But once that had occurred, obviously, the
      17   necessity level to get the information to the right person
      18   as quickly as possible was greatly raised in my mind, but
      19   yes.
      20         Q.   Okay. So Sunday you -- did you type this
      21   yourself --
      22         A.   I did.
      23         Q.   -- or was this dictated?
      24         A.   No, I typed it myself.
      25         Q.   Okay. And this was, I assume, at work or

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      1    something?
      2          A.   Yeah, I typed it on the computer. I went to the
      3    office on Sunday and typed it on the computer.
      4          Q.   All right. It's not routed or doesn't have
      5    anybody specific up there. Is that because of the same
      6    reason you told me earlier, that you just routed it to the
      7    Church or --
      8          A.   The answer is --
      9               MR. CACCIATORE: Tell him the answer.
      10         A.   The answer is, it was routed. I believe the
      11   routing was to her PC folder or to -- usually the way -- I
      12   don't have a copy of it that has the routing on it, so I
      13   can't remember exactly.
      14         Q.   I have the same copy.
      15         A.   I know. But it did not have the routing vetted.
      16   It did not have the routing vetted on the top of it.
      17         Q.   What does that mean?
      18         A.   Removed. The routing is removed.
      19         Q.   The routing has been removed on this copy?
      20   That's correct.
      21         Q.   Okay. Did you do that?
      22         A.   No, sir, I didn't.
      23         Q.   Somebody else did that?
      24         A.   Yes, sir.
      25         Q.   Why was that done, do you know?

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      1          A.   I have no idea.
      2          Q.   All right. Because other documents that I see,
      3    I've been through a million documents --
      4          A.   I bet.
      5          Q.   -- have an arrow and C/S or DP or something like
      6    that. I'm kind of learning this stuff, believe it or not.
      7    But I notice this does not have any routing, that's why I
      8    wondered how it got to anywhere.
      9               Can you tell me where the routing was?
      10         A.   Well, as I said, I don't have a copy-- a copy of
      11   it that has the routing on it, but -- and it's been over two
      12   years ago that I wrote it.
      13         Q.   I'm not going to hold you --
      14         A.   Okay. So I'm just trying to tell you, the best of
      15   my knowledge, the way I do it, to her PC folder,
      16              Lisa McPherson's pre-Clear folder, care of the
      17   Case Supervisor, with a line under it and my name, I believe
      18   is the way I routed it.
      19         Q.   Arrow and a line under it and your name?
      20         A.   Only other way is if I routed it to the
      21   Director of Processing or to her PC folder via the
      22   Director of Processing. I can't remember how I did it.
      23   Either one would be correct.
      24              MR. CACCIATORE: How did that get down to the
      25   Church after you did it?

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      1               THE WITNESS: I took it down there myself.
      2               MR. CACCIATORE: What do you do with it?
      3               THE WITNESS: I took it up to the service
      4    area, where all the different pre-Clears that are
      5    waiting for their auditing services wait in the lounge
      6    there, and they have these administrative people that
      7    deal with those people. And I handed it to the
      8    administrative person who was over the area where she
      9    received her auditing. It was in an envelope, sealed.
      10   And said, Here, make sure this gets to her folder,
      11   right.
      12   BY MR. McGARRY:
      13         Q.   Okay. So it was routed to her Case -- it wasn't
      14   to the Case Supervisor, just to her Case Supervisor, there's
      15   a different --
      16         A.   I really had no idea who and what levels were
      17   handling her. I just routed it to her PC folder. That
      18   would have encompassed anyone who was handling her, they
      19   would have had that data, because they would have had the
      20   folder with the data in it.
      21         Q.   Right. Okay.
      22              DETECTIVE SERGEANT ANDREWS: While you're on
      23   that, was that typed in at the top, just like on the
      24   computer?
      25              THE WITNESS: Yes.

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      1               DETECTIVE SERGEANT ANDREWS: It's all typed
      2    in, okay. I'm sorry.
      3          Q.   The routing was typed in or handwritten?
      4          A.   No, I typed the whole thing.
      5          Q.   Oh, typewritten?
      6          A.   Sure.
      7          Q.   Paragraph 3, page -- of the first page, I had a
      8    question.
      9          A.   Sure.
      10         Q.   And I -- I have a feeling it has to deal with some
      11   Hubbard tech about office management, but you mentioned
      12   Katie Chamberlain was handling the difficulty she was
      13   having.
      14         A.   Uh-huh.
      15         Q.   Is that something that she was -- I'll probably
      16   end up asking her, but if you know, was Katie handling
      17   her -- her emotional or her lack of productivity problems
      18   within the -- within the company? Is that what she was
      19   doing?
      20         A.   Not to my knowledge.
      21         Q.   Okay. Describe what this paragraph is talking
      22    about here, her ethics cycle is still in mid-cycle on her
      23    O/W write-ups and was frequently disbursed generally in the
      24    middle of it.
      25        A. Okay. To be very candid with you, I don't really

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      1    have any idea what the nature of the matter was that Katie
      2    was addressing with her. In fact, I was unaware up until
      3    that morning when she got ready to leave she was doing any
      4    type of ethics program. I had no knowledge of it.
      5               Katie came to me, because I was going to be the In
      6    Charge on this trip. In other words, I was responsible for
      7    making sure that sales presentations were done, that the
      8    floor at the trade show was manned, that everybody was
      9    productive and everything was going like it was supposed to
      10   be going at a trade show. These are very expensive shows to
      11   put on and we're expected to, you know, make the most of the
      12   time. You go there and talk to people and get business
      13   accomplished.
      14              So I had been placed in charge of making sure that
      15   happened. Katie simply came to me, just want to let you
      16   know, Lisa has come to me and asked me to work with her on
      17   an ethics matter that she wanted to address and we've been
      18   working on it now for a little while and she's still in the
      19   middle of it, it's not finished, and I would appreciate it
      20   if you would not let her get off into discussing it with
      21   you. Sort of, again, same type of thing, I'm one more
      22   person interjected in the middle of something that I don't
      23   need to be in the middle of.
      24              And Lisa had a tendency to tell you about stuff
      25   like that. I took it Katie was letting me know for

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      1    informational purposes this was going on, so I would be
      2    aware and I wouldn't get blind-sided by Lisa starting to
      3    tell me about it or what was happening.
      4               I didn't know what it was. She didn't elaborate.
      5    She was still in the middle of it and it was not finished
      6    and, please, would I not discuss it with her. I said sure,
      7    that would be fine.
      8          Q.   I'm a little amiss as to how that works. What is
      9    an ethics handling? This is something removed kind of from
      10   the Church, this is within AMC, within the business that's
      11   going on?
      12         A.   I think you're better served to ask Katie exactly
      13   what this was.
      14              Speaking in general --
      15         Q.   It's just a general question.
      16         A.   -- not related to this particular thing, yeah, let
      17   me just explain, if I could, the difference between ethics
      18   and auditing, so you have the difference in viewpoint.
      19              Ethics has to do with -- let me just give you the
      20   definition here. I brought the dictionary. So it makes it
      21   easier to tell you exactly -- straightforwardly exactly what
      22   it is.
      23         Q.   Okay.
      24         A.   Ethics is a personal thing. By definition the
      25   word means "the study of the general nature of morals and

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      1    the specific moral choices to be made by the individual in
      2    his relationship with others."
      3               When one is ethical or "has his ethics in," it is
      4    by his own determination and is done by himself. That which
      5    is enforced by one's self, his belief in his own honor and
      6    good reason and optimum conclusion or survival, if you will,
      7    across all his areas of his life, or the eight dynamics, the
      8    different areas of life. So ethics has to do with the code
      9    of agreement amongst people that they will conduct
      10   themselves in a fashion which will obtain to the optimal
      11   survival or optimum solution of their problems.
      12              Now, while auditing certainly does allow a person
      13   to address that same type of thing, address problems they're
      14   having in life, to help them resolve, how can they solve
      15   those things and come out for optimum survival or do a
      16   better job of surviving or enhance their survival, ethics is
      17   more the person looking at their behavior and own action
      18   related to a given situation they're trying to address and
      19   deciding for themselves how they did that thing, right,
      20   wrong or indifferent, and how could they better have handled
      21   it or how can they now correct it in order to have their
      22   life go better in a more positive direction.
      23              That is what an ethics program would be, would be
      24   the steps of going through accomplishing that. And it might
      25   involve a number of different tools that are religious in

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      1    practice or nature. Of course, one of which being an
      2    overt/withhold write-up. That could be one of the tools
      3    that is elected to be used.  There are many other tools that
      4    could be used.
      5          Q.   All right. So--
      6          A.   Does that help?
      7          Q.   Yeah, it does.
      8          A.   Okay.
      9          Q.   The O/W write-up you mentioned --
      10         A.   Right.
      11         Q.   -- how does that work? You've got HC -- I believe
      12   this is all Hubbard tech stuff.
      13          A.  Exactly.
      14          Q.  It's probably beyond me.
      15          A.  Well, it's actually fairly simple. All you have
      16   to do is clear up your words on it and I'm sure you'll
      17   easily understand. You seem like a very intelligent guy.
      18   There's nothing hard here.
      19              First of all, overt act is not just injuring
      20   someone or something, an overt act is an act of omission or
      21   commission.
      22         Q.   I kind of follow you there, but the write-up
      23   part --
      24         A.   The write-up part?
      25         Q.   That's where it was in her deficiency, that she

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      1    was doing the write-up, Lisa's deficiency.
      2          A.   Right. Overt/withhold write-up would be the
      3    person themselves doing the program writing up on their own
      4    determination, whatever they felt like they had done they
      5    shouldn't have been done, or something they should have done
      6    they didn't do or failed to do.
      7          Q.   I gotcha.
      8          A.   Sort of going to confession, like a priest, except
      9    you're writing up on a piece of paper instead of telling it
      10   to somebody.
      11         Q.   I follow you.
      12              I had a question on Page 2, last paragraph.
      13         A.   Okay. Did you -- did you clear up what HC was?
      14   Did you wonder what that was?
      15         Q.   You can tell me what that was.
      16         A.   Well, HC just means that as the In Charge, the
      17   person that was in charge of what was going on there, I was
      18   responsible --
      19         Q.   You were in charge?
      20         A.   Yeah. This is having to do with running HC at the
      21   convention, right. That's just -- it stands for tight
      22   control or good control, meaning I kept everything moving
      23   the way it was supposed to be doing. If you want something
      24   to A, B, C, somebody better be in charge of A, B, C being
      25   done, and then that person better make sure that gets

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      1    carried out in that fashion. That's all HC is, making sure
      2    it gets done the way the person wants it to get done.
      3               Now, Page 2.
      4          Q.   Page 2, bottom paragraph, apparently she started
      5    interrogating you --
      6          A.   Yes.
      7          Q.   -- about a client that you all shared or that you
      8    had, I guess. It was necessary to let me know what the SPs
      9    were doing there. SP, I didn't know what that meant.
      10         A.   Well, an SP is -- stands for suppressive person.
      11   And a suppressive person is simply someone who is trying to
      12   stop things or cause things not to go forward in the way in
      13   which you would want them to go, someone who has a
      14   counterintention toward the thing you are trying to make
      15   happen.
      16              And unfortunately, in the society that we live in,
      17   there are people out there who have an interest in trying to
      18   stop people, stop organizations, stop expansion, stop
      19   growth, whatever it is. There are people who actively try
      20   to stop things from happening.
      21              And she was referring here to there must be some
      22   of those kinds of people in this man's environment that are
      23   keeping things from happening with his business the way it
      24   ought to be. And if -- if he really understands who they
      25   were and what they were doing, he would probably have a

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      1    better understanding of why he's having so much trouble is
      2    what she was trying to say here.
      3          Q.   Okay. I've heard the term before, the suppressive
      4    term, but the initials threw me there.
      5          A.   Gotcha.
      6          Q.   Boy, this behavior here in Page 3, the larger
      7    paragraph towards the bottom of the page, where she is on
      8    top of you at 3:00 in the morning is pretty descriptive.
      9    But I guess it was about then that you fully realized that
      10   she had snapped. Would that be accurate?
      11         A.   Well, it was kind -- it was a very strange
      12   situation because, I mean, frankly, I've never in my life
      13   experienced someone having a mental breakdown before, so
      14   it's not exactly like you have experience with seeing that
      15   type of thing every day and you know what you're looking at,
      16   you know.
      17              But by this point in time, after this occurred I
      18   knew that she was obviously in very deep trouble. And I
      19   didn't know exactly how -- I still don't think I totally
      20   grasped how deep the trouble was until the Saturday night
      21   after I learned about what had happened with the automobile
      22   accident and so forth. Then I really knew, oh, my God, you
      23   know.
      24              But she would do these things and then she would
      25   sort of snap out of it and be totally rational and just, you

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      1    know, be completely there and in communication and making
      2    total sense, and then ten minutes later she would do
      3    something else like what I'm describing in here. So it was
      4    sort of -- I guess I was shaken because, you know, I was
      5    like, what am I seeing here? One minute she's fine and the
      6    next minute she's not, you know.
      7          Q.   Right.
      8          A.   So it was that kind of -- it was very disruptive
      9    to me. I just wasn't sure what I was looking at. But
      10   obviously I knew she was in lots of trouble here at this
      11   point.
      12         Q.   Did you have any idea what she was talking about,
      13   fuck something up so badly? I mean, do you have any idea,
      14   was that just rambling on or was there a targeted area that
      15   that was referring to?
      16         A.   It didn't make any sense to me. I really could
      17   not tell. She just rambled. Most of it was just
      18   off-the-wall rambling. I put some of the things she said to
      19   me in hopes that maybe that would help the person at the
      20   Church know what to ask, you know, where to dig around to
      21   try to find out what the problem was, you know, but I
      22   really -- she didn't elaborate specifically what the deal
      23   was.
      24         Q.   Paragraph 2 on Page 4, started interrogating you
      25   about a mutual friend. Do I know that person, mutual

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      1    friend? Is that somebody that's in the business or
      2    something?
      3          A.   She was actually talking to me about a person
      4    whose name is Sol Spencer, who is somebody that we worked
      5    with at AMC, and she was in disagreement, that he was
      6    involved in a relationship with a girl that she didn't --
      7    that Lisa considered was not the best relationship for him
      8    to be in, and she thought I should be stepping in to try and
      9    do something about that.
      10         Q.   Wow.
      11         A.   You know, that was all her viewpoint, right, or
      12   her thinking.
      13         Q.   Right.
      14         A.   But mainly the thing -- it wasn't so much that
      15   particular thing she was talking about, but it was just
      16   interrogating me. I felt like I was being attacked by, you
      17   know, a Nazi officer or something. It was that kind of
      18   get-in-your-face interrogation type thing, you know. It was
      19   very strange.
      20         Q.   The middle paragraph of the same page, Page 4, it
      21   looks like she confided in you that she tried to suppress or
      22   to keep it discrete, the fact that she had a little lapse in
      23   the middle of summer there. Is that what she's referring to
      24   there?
      25         A.   Well, I think she's admitting to the fact that

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      1    she, quote unquote, flipped out during that period of time
      2    and that she knew she did, and that she was explaining to me
      3    that, looking back on it, and from what I wrote here two
      4    days -- even two days later, this is what I thought was
      5    happening. She was explaining to me she didn't feel she had
      6    taken responsibility for that and that she brought that on
      7    herself, you know.
      8               And she -- it was almost like she wanted me to
      9    know that -- that somehow that was really important to her
      10   to tell me that. You know, that I was a valued and trusted
      11   friend, you know, and -- I don't know. It was like she was
      12   confessing that to me, you know, that this was something
      13   that was bothering her, that she just had to tell me, you
      14   know.
      15              And, I mean, my whole thing on it was, I just
      16   wanted her to know it was okay. You know, it was okay. It
      17   was over, it was done, it was finished, you know, what was
      18   done was done, she was back at work, things had been going
      19   better. I just wanted her to get on with her life and put
      20   that behind her. And it seemed to me, from what she said at
      21   that point, obviously she still had a retention on.
      22         Q.   Right.
      23              The last paragraph on Page 4 is very difficult for
      24   me to follow. I'm not so sure maybe you didn't make a typo
      25   or something.

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      1          A.   Okay. What is it?
      2          Q.   Is the very beginning --
      3          A.   I want it known?
      4          Q.   I want it known the information I was given by
      5    Katie, that I was -- continue on from there to "heavily
      6    product".
      7          A.   Product officer her. In other words, we went to
      8    the trade show to get sales and to make contacts and to get
      9    new business for the company. That would be -- every one of
      10   those things we achieved would be a new completed thing and
      11   that's called a product.
      12         Q.   I gotcha.
      13         A.   We call that a product. I was responsible for
      14   making sure that got done. When you say "Product Officer,"
      15   that just means I was in charge of making sure that got
      16   done.
      17         Q.   Okay. That makes sense.
      18              Have you been told by anybody who it was that
      19   altered your document at the top of the first page?
      20         A.   No, sir.
      21         Q.   Who was it that was briefing you, if that was
      22   occurring? It may not be, I may be jumping ahead of myself.
      23   But were you getting information from someone as to how
      24   Lisa's progression was going on during those 17 days in the
      25   hotel?

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      1          A.   I had very little information about how anything
      2    was going with her. I knew that she, obviously, had to be
      3    getting some intense help, you know, because of this nature
      4    of what was happening, but there was very little information
      5    that anybody was saying about anything.
      6               I mean, I asked Benetta on more than one occasion
      7    had she heard anything, did she hear anything, and she was
      8    without hearing any data either as far as I know. She
      9    didn't have anything to say other than, they're working with
      10   her, they're working with her, you know. I mean, that was
      11   basically all any of us knew, you know.
      12              Earlier, when she was there in the summer, it was
      13   a little better scene because we had communication with her,
      14   you know, she came to our house. She was not nearly in as
      15   bad a shape at that point as she was as this point. And, of
      16   course, none of us knew how much worse she got after this,
      17   you know. I mean, we didn't know. None of us had any -- a
      18   clue, you know.
      19         Q.   So you weren't aware of any particular program
      20   that was going to be or try to be implemented or what was
      21   going on?
      22         A.   I had -- exactly. The last conversation I had
      23   with Lisa was on Saturday morning, the 18th. She called me
      24   at home around 6:30 or quarter of 7:00 in the morning. I
      25   was shocked to hear from her at that hour, `cause I was

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      1    exhausted from this trip and I had pleaded with her to go to
      2    bed the night before and get rest.
      3          Q.   Right.
      4          A.   And she's calling me at that hour and I'm going,
      5    Lisa, why are you up, you know. I was very much half asleep
      6    in the conversation. She was all bright, said she was fine,
      7    she was going to -- Katie was coming to pick her up, she was
      8    going to go and work at the warehouse on the
      9    Winter Wonderland props that day, she had a lot of things
      10   she wanted to get done. Seemed like she was all bright and
      11   cheerful and everything. And I'm sort of, I'll talk to you
      12   later, you know, `cause I was half asleep. It was a very
      13   short conversation. And that's the last time I ever spoke
      14   with her.
      15         Q.   All right. I assume you've been made aware of,
      16   since this has all occurred, she was there in a room and
      17   there were `round the clock people watching her and she
      18   exhibited incredible physical behavior? Have you been made
      19   aware of all that?
      20         A.   I have.
      21         Q.   Okay. When was it that you found out that she had
      22   passed away?
      23         A.   On the morning after her death, fairly early that
      24   morning.
      25         Q.   And who was it that informed you of that?

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      1          A.   Mary Vogeldean, who is the President of the
      2    Church.
      3               I was asked by Benetta to join her and go down to
      4    the Church and was taken -- I didn't know why. I thought it
      5    had something to do with something totally different. I had
      6    no idea why Benetta wanted me to go with her, but she just
      7    came to my office and asked me if I would come with her for
      8    a little while, she had something she needed me to hear and
      9    know about. And I said sure. And we went down to
      10   Mary Vogeldean's office and she told me that Lisa had died.
      11         Q.   Any detail or just general?
      12         A.   Well, she told me that she had died in -- either
      13   right at the hospital or right before they got to the
      14   hospital. I think she was probably not very sure either at
      15   that point. But dead on arrival at the hospital, I believe
      16   is the way she put it. And that she had gotten sick, and at
      17   that point she thought that she might have had meningitis or
      18   some type of really bad infection.
      19              They were -- I mean, there was no autopsy yet,
      20   there was nothing, there was very little data, but she
      21   appeared -- according to the preliminary information that
      22   had come back from Dr. Minkoff to Mary Vogeldean, it
      23   appeared she either had meningitis or some type of
      24   incredibly horrible bacterial infection that had moved very
      25   quickly. Flu like symptoms, what it was described as, that

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      1    got very bad very fast.
      2          Q.   Has Lisa's position been filled, I assume --
      3          A.   Oh, yeah.
      4          Q.   -- at AMC by anybody or --
      5          A.   Well, for a while there were only a few of us,
      6    three of us in the sales area covering everything, but now
      7    we have a full complement of salespeople again in the area.
      8    There were other people hired and trained and brought up
      9    through the ranks to, you know, get trained well enough to
      10   do the job, so now we do have a full sales staff.
      11         Q.   When you have a client -- that would be an
      12   insurance company, right, that would be your client at AMC?
      13         A.   Not necessarily the insurance company. We work
      14   with the distribution the insurance companies use, which can
      15   be a wholesaler, a marketing general agency or a broker
      16   general agency or general agency, any of those people could
      17   be our clients.
      18         Q.   Did you end up going to Dallas for her funeral?
      19         A.   I did.
      20         Q.   And accompanying you was Benetta and
      21   Brian Anderson?
      22         A.   No, Brian Anderson didn't accompany me. He came
      23   to the funeral later.
      24         Q.   That's what I meant, he went out there.
      25         A.   Yeah, he came -- I didn't know he was gonna be

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      1    there. He came to the funeral later. Jeanne Decuypere also
      2    went. Benetta and Jeanni traveled together and I traveled
      3    by myself to get there. They went on different flights.
      4          Q.   Going back for just a second to the document, the
      5    November 19th document, I kind, of went through that quickly
      6    because it could be agonizing to go through this thing
      7    detail by detail and it's very specific. Have you read this
      8    document recently and reviewed it? I assume you have.
      9          A.   (The witness nods affirmatively.)
      10         Q.   Is there anything else that might be important
      11   that you recall now that wasn't documented that might be of
      12   interest?
      13              MR. CACCIATORE: I talked to my client so I
      14   know this, there's two things, one about her being at
      15   the registration table, you told me about that. And
      16   you said in there about the -- her bizarre behavior on
      17   the way home, but -- but, you know, the thing you told
      18   me about your almost getting in an accident. So you
      19   tell him about those things.
      20              THE WITNESS: Yeah.
      21         A.   Well, one of the things that traditionally AMC has
      22   always done at that particular trade show called NAILBA,
      23   which stands for the National Association of Independent
      24   Life Brokerage Agencies, what a mouthful, is that we have
      25   always helped with the registration of the people coming in

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      1    for the convention, as a courtesy to them. `Cause we're a
      2    support organization for the insurance industry so, you
      3    know, when we go to these trade shows we're there to get
      4    business, but we're also there as a support to the industry
      5    as a whole. So we worked the registration booth.
      6               And Lisa had on a dress that day, it was not real
      7    low cut, but it had a scoop neck. And the way we were
      8    situated in this thing, this little place where we were
      9    working, you kind of had to sort the lie on the counter in
      10   order to talk to the people that were coming up to the
      11   counter, you know.
      12         Q.   Right.
      13         A.   And I was standing next to her over here, she was
      14   standing in the middle and someone else was working down
      15   there. And I happened to look up and there's a whole line,
      16   mostly the people that come to these things are men, most of
      17   these insurance people are men, right, so a whole line of
      18   people standing in front of her which fell into her category
      19   of letters of the alphabet she was doing -- registering, and
      20   they're all like gaping at her, you know. And I'm like --
      21         Q.   Was it her blouse was falling?
      22         A.   I didn't realize at first what the problem was, I
      23   just noticed these men were gaping. I'm going, What's going
      24   on? I looked over and I realized she's like leaning over on
      25   the counter, the whole entire front of her is completely

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      1    exposed, she has on no bra, which Lisa was definitely a
      2    large enough busted woman to always wear a bra. I was
      3    going, Oh, my God, she has no bra, she's like all over the
      4    counter here.
      5               I like grabbed her by the arm, said, Lisa, where
      6    is your bra? You're showing yourself over the counter. And
      7    she was like totally oblivious to it. She had no clue this
      8    was occurring, absolutely none. You could tell by the
      9    expression on her face. She was like, What do you mean, you
      10   know. And when I asked her about her bra, she said, Well, I
      11   couldn't find it, I couldn't find it in my luggage.
      12              And there had been an incident up in the room
      13   where she -- when we first got there, she had said she was
      14   looking for something in her luggage. And I had gone into
      15   the bathroom or something, and I came back out and she had
      16   taken the whole entire suitcase and she had dumped it in the
      17   middle of the floor and she had thrown the clothing and
      18   everything that was in the suitcase all over the room.
      19   Another obvious piece of erratic behavior, you know.
      20              And I'm asking her what is she doing, you know.
      21   And she's like, I'm looking for something. She never could
      22   tell me what she was trying to find, you know. And then
      23   when we got down there, that's what it turned out she had
      24   been trying to find, you know.
      25              And so I sent her back to the room to put it on,

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      1    you know, and then not bend over the counter.  But she was
      2    just -- I mean, when I asked her about it or pointed it out
      3    to her, it was just like so strange, her reaction, because
      4    it wasn't like, oh, my God, what am I doing, I should watch
      5    how I'm standing or whatever, it was more like, oh, okay,
      6    whatever, you know. Very un -- un -- not the behavior she
      7    would have normally displayed.
      8               And then the other thing that was very peculiar
      9    was on the way out of Orlando, when we were driving back, we
      10   almost had a really bad accident. There was a lot of
      11   traffic that night, and it was very heavy, and there was
      12   this person coming up behind me, I saw him in my rear-view
      13   mirror, and the person must have been driving over 100 miles
      14   an hour, I mean, he was flying. And I -- like, oh, my God,
      15   how can I get out of his way, because there was traffic in
      16   both lanes, and he was weaving in and out of the traffic,
      17   and I wanted to get over so he could just go on by, because
      18   I was in the fast lane, but I didn't have time to get over.
      19              And he came up and went this way. (Indicating)
      20   And there was a car over here next to me. And he went
      21   between me and the car over here. And there was really
      22   hardly any room between the cars, and he just barely managed
      23   not hitting us. And I swerved over off the road and I -- it
      24   panicked me, because it was -- it was so close to a really
      25   bad wreck.

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      1               I was like, God, did you see that guy? And, you
      2    know, she's over here in the passenger seat and she goes,
      3    What guy? What car? What happened? And I'm going, Didn't
      4    you see that guy? You just didn't see what happened? It
      5    was almost a horrible wreck. And I'm going on and on, and
      6    she's like, I don't know what you're talking about, you'll
      7    have to repeat that, I don't understand what you said.
      8               And then I would say it again and she would go,
      9    I'm sorry, I didn't get that, you have to tell me that
      10   again. It was very, like, monotone, robotic, you know, like
      11   it was a circuit playing or something, you know. You know,
      12   it was just coming out of her mouth that way. And finally I
      13   just gave up. I could see that, you know, she was totally
      14   out of it and I gave up trying to discuss it is with her.
      15              But, you know,  anybody that was obviously in their
      16   right frame of mind would have observed what had occurred
      17   and would have been as freaked out as I was, you know. So I
      18   thought that was extremely bizarre.
      19              MR. McGARRY: All right. That about handles
      20   my questions. These guys might have a few questions.
      21   I don't think there will be too many.
      22              If you want to take a break --
      23              THE WITNESS: I do.
      24              MR. McGARRY: All right. We'll a take a
      25   break for a second.

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      1               (Short recess is held.)
      2               DETECTIVE SERGEANT ANDREWS: I have a couple
      3    of questions and we'll get out of here.
      4               THE WITNESS: All right.
      5                      EXAMINATION
      7          Q.   In your document, you had noted the word
      8    "interrogation mock-up." Now, is that something you just
      9    made up for that or is that a term used someplace else?
      10         A.   No. Well, the word "interrogation," I just used
      11   it because that was -- reminded me of movies and things I'd
      12   seen where somebody was being interrogated by the police or
      13   the FBI or Nazis or whatever.
      14         Q.   All right. It's not a term used --
      15         A.   No.
      16         Q.   -- in Scientology?
      17         A.   No.
      18         Q.   And no one asked you for this report, you just
      19   wrote it up?
      20         A.   That's correct.
      21         Q.   Okay. Oh the end of your report -- I just wanted
      22   to ask you two questions -- on the end of the report you
      23   just put Brenda Hubert. Is that normal or is there
      24   something missing there? You wouldn't sign it?
      25         A.   No, I -- I'm just a Public person so that would

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      1    have been the way I signed it. If I had held -- if I had
      2    worked for the Church and held a job, I would have put my
      3    post title too --
      4          Q.   Okay.
      5          A.   --my job title, but
      6          Q.   You didn't.
      7               Did you get a chance -- there's no other pages to
      8    it? Have you looked at it? I have five pages with just a
      9    little bit at the top.
      10         A.   That's correct. The only thing that's missing or
      11   vetted is the routing.
      12         Q.   Routing, okay.
      13              Atlantic Financial in Dallas, was that similar to
      14   AMC as far as connected to the Church or the people worked
      15   at the Church?
      16         A.   No. There were many -- Atlantic Financial
      17   Mortgage Company was a really big company.
      18         Q.   So it was separate?
      19         A.   Yeah.
      20         Q.   Not like AMC?
      21         A.   No.
      22         Q.   Okay.
      23         A.   Many, many people that worked there in all kinds
      24   of different capacities and walks of life.
      25         Q.   Who was the Prodex Corporation?

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      1          A.   Well, Prodex is the corporation that
      2    AMC Publishing is -- I don't know how they did this, but
      3    they set it under Prodex Corporation, but we operate doing
      4    business as AMC Publishing. AMC Publishing is the same.
      5               Now, once we moved to Florida, David, I believe,
      6    the Slaughters, reincorporated our company here in Florida
      7    as opposed to -- it's not a Texas corporation any longer, I
      8    don't believe. And I believe at that time the Prodex name
      9    was totally removed and it became AMC Publishing as its own
      10   entity or corporation, if I'm not mistaken.
      11         Q.   All right. The reason I ask you that is that
      12   billing -- I have some of Lisa's billing from the Church.
      13   You know, I subpoenaed billing records.
      14         A.   Uh-huh.
      15         Q.   And on those billing records it shows
      16   Prodex Corporation paying the Church of Scientology directly
      17   on deposits for Lisa for classes, I guess.
      18         A.   If you pulled mine, you would find the same thing.
      19         Q.   Same thing.
      20              So that was just a way of paying for your
      21   schooling at the Church without having you to deposit in
      22   your account and you write a personal check to the Church?
      23         A.   That's correct. Basically, I can't speak for
      24   Lisa's situation, I can only speak for mine, but I will tell
      25   you that I borrowed, literally borrowed some money from

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      1    Prodex Corporation to purchase some services through the
      2    Church. They were actually bought by the corporation for me
      3    and I have been repaying Prodex Corporation --
      4          Q.   The corporation --
      5          A.   -- for those services since that time. But they
      6    were paid for by the corporation, you know, out of their
      7    check, and then I've been paying out -- off of like advances
      8    out of my commissions and so forth for them -- for that
      9    loan.
      10         Q.   Okay.
      11         A.   It was actually a loan.
      12         Q.   Okay. The other two reports you wrote, were those
      13   Knowledge Reports?
      14         A.   No. They were similar in nature to this.
      15         Q.   Just like this?
      16         A.   Yes.
      17         Q.   Did you write any Knowledge Reports on Lisa?
      18         A.   For her ethics folder?
      19         Q.   Yeah.
      20         A.   No.
      21         Q.   On anything that you noticed?
      22         A.   No.
      23         Q.   Speaking of those other reports, have you seen
      24   them since?
      25          A.  No, I have not.

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      1          Q.   Okay. Now, were they in this similar form, just
      2    typed on a computer --
      3          A.   Yes.
      4          Q.   -- with a heading?
      5          A.   Correct.
      6          Q.   Same type of heading that was vetted on this?
      7          A.   Correct.
      8          Q.   Okay.
      9          A.   As I said, I can't exactly recall, but there were
      10   one or two, I'm not sure. I wrote one or two.
      11         Q.   We're still searching, that's why. I'm still
      12   looking for them.
      13         A.   Yeah.
      14         Q.   I notice there was quite a big difference between
      15   your description of Lisa's stay for that time in July and
      16   August and what I've uncovered on Lisa's stay the 17 days in
      17   November.
      18         A.   In what way?
      19         Q.   Well, you know, you describe Lisa having someone
      20   with her and going out and visiting people and being open.
      21   Yet testimony so far shows Lisa secluded in this room for 17
      22   days and not allowed to leave.
      23              Now, 25 years in the Church, can you -- can you
      24   give us an explanation as far as the tech goes as to why
      25   that would have been, you know, why there was quite a

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      1    difference in the watch, I mean, if she was having some
      2    problems in July and August?
      3          A.   I have no personal knowledge of anything that took
      4    place in the 17 days, so I don't see how I can answer that
      5,   question. I simply don't know the answer to the question
      6    you're asking me.
      7          Q.   Okay.
      8               DETECTIVE CARRASQUILLO: I had a question
      9    along those lines, that way we can get out of here much
      10   quicker.
      11              MR. McGARRY: Go ahead.
      12              DETECTIVE CARPASQUILLO: Along those lines,
      13   going back to the first mental breakdown she had, you
      14   said she wanted to commit suicide or gave you those
      15   thoughts of wanting to commit suicide?
      16              THE WITNESS: She didn't come out and say she
      17   wanted to commit suicide, she said I'm not sure I want
      18   to live any longer.
      19              DETECTIVE CARBASQUILLO: She went to the
      20   Church for counseling, I guess?
      21              THE WITNESS: Correct.
      22              DETECTIVE CARRASQUILLO: Along the lines
      23   Sergeant Andrews was stating, she had friends visit
      24   her, she could have company come out, people come out,
      25   although she made those expressions she no longer

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      1    wanted to live; which is pretty serious.
      2               Now, I know you don't have knowledge what
      3    happened those 17 days, but she was allowed no company,
      4    no company, no visits, and she was not allowed to leave
      5    the room.
      6               Based on your experience, what would be the
      7    difference between the two situations? Not as to what
      8    happened those 17 days, but based on your experience
      9    what would be the difference of the handling?
      10              MR. CACCIATORE: I'm going to object to that.
      11   You're asking this lady to engage in pure speculation.
      12   She's here as a fact witness.
      13              DETECTIVE CARRASQUILLO: These are facts.
      14              MR. CACCIATORE: I'm going to object.
      15              MR. McGARRY: That's a fair objection.
      16              DETECTIVE CARRASQUILLO: Can I rephrase the
      17   question?
      18              MR. McGARRY: You're giving her
      19   hypotheticals, I could see where Ron --
      20              DETECTIVE CARRASQUILLO: Can I rephrase the
      21   question?
      22              MR. McGARRY: Go ahead, see how that works.
      23              DETECTIVE CARRASQUILLO: You've been with the
      24   Church there 25 years. Is there tech to handle the
      25   situation like in February -- I'm sorry, June, July or

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      1    August?
      2               THE WITNESS: Well, there -- there is
      3    information contained in the LRH, full opinions of the
      4    Church regarding psychotic behavior in an individual.
      5    I'm sure you have access and can find that. All you've
      6    got to do is read it for yourself. And I'm not going
      7    to paraphrase, but there is information on what the
      8    state of psychotic is, what a psychotic break is, some
      9    of the possible causes, if you will, behind that, just
      10   probably covered strictly in the definition of it alone
      11   would describe it.
      12              As far as the Church's policy regarding the
      13   treatment of such people, it is the posture and belief
      14   of the Church and well documented in -- in technical
      15   issues that the Church tries to help the able become
      16   more able. That is the public that we most work with.
      17   Now, a person who is ill, physically or mentally ill,
      18   would normally not be taken into the Church.
      19              Like if you came to the Church and you were
      20   physically ill and you were saying I want to come into
      21   your organization so you can heal me, you know, the
      22   Church would say, I'm sorry, we're not in the business
      23   of healing people's physical problems, you'll have to
      24   seek medical care, because that's the proper place to
      25   have that treated. The same would be true with someone

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      1    with a mental disorder. I'm sorry, we're not -- we're
      2    not in the business of treating mental disorders, you
      3    would need to go somewhere else.
      4               Now, once again, this is if you were a new
      5    person, not a current member of the Church, a new
      6    person coming into the organization seeking help for
      7    that specific problem. Okay?
      8               DETECTIVE CARRASQUILLO: Okay. Let's just
      9    cut it down a little bit and just go, I'm not -- I'm
      10   not a new person, I'm a current practitioner and I have
      11   a mental problem. Are there guidelines to deal with
      12   that? And you're saying there are?
      13              THE WITNESS: I'm saying that I do not
      14   know -- there's information to describe what that is,
      15   okay, and how to define that. I'm not familiar with
      16   any specific policy or reference that outlines how
      17   you're supposed to deal with somebody in that state as
      18   far as the Church's policy on it.
      19              You know, I -- I don't know such a policy
      20   that says, if one of our parishioners becomes mentally
      21   ill, this is the procedure we go through. I don't know
      22   of such a policy. I don't think such a policy exists.
      23              We don't normally have people in that
      24   situation. It's very rare. I've been in 25 years and
      25   I've never ever seen a situation like this ever occur

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      1    before, where someone had a psychotic break like that,
      2    any more than you would in maybe the normal population.
      3               So that's all I know to tell you.
      4               DETECTIVE CARRASQUILLO: Okay. Go ahead.
      6          Q.   Would it be stressful to make it to the level of
      7    Clear?
      8               And the only reason I ask you that is, Lisa has
      9    some -- the mental problems in June or July and then in
      10   September she did go Clear from -- I have some pictures of
      11   her ceremony, and then again a month and a half later she's
      12   back to exhibiting problems. And could we attribute her
      13   going Clear to any of that stressful problems? I mean --
      14         A.   I don't think I'm qualified to answer that
      15   question.
      16         Q.   Okay.
      17         A.   I don't have a clue to the answer to that
      18   question.
      19         Q.   All right. Who can look at the overt/withhold
      20   write-ups?
      21         A.   The person that would be responsible for working
      22   with you.
      23              I mean, it's sort of a -- doesn't have to be
      24   anything real technical or real difficult. Let's say you
      25   were a Scientologist and I'm a Scientologist and I'm having

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      1    a problem with my marriage. And I come to you and go, you
      2    know, I'm really having a problem with my marriage and I'd
      3    like to get it straightened out, would you be willing to
      4    work with me to help me with an ethics program? And you say
      5    yeah, I'd be willing to do that.
      6               And you would sit down, using the technology that
      7    you knew about ethics, to help steer me or direct me through
      8    whatever I needed to do. I would show you my O/W write-ups.
      9    I would have no problem with that.
      10         Q.   Oh, okay. The reason I ask that, I misunderstood,
      11   because I thought when you -- the overt/withhold write-ups
      12   was something I would write to my priest as a confession.
      13         A.   I'm comparing it in the sense of the content of
      14   being something comparable to what a Catholic person might
      15   go to a priest and say, you know, Father, I have sinned,
      16   I've done dah, dah, dah, dah, whatever.
      17         Q.   I was applying those there --
      18         A.   No.
      19         Q.   -- and was wondering who could look at those, but
      20   now I see what you're saying.
      21         A.   Exactly.
      22         Q.   My last question: Have you had an audit cycle or
      23   a Sec Check in relation to Lisa McPherson?
      24         A.   Have I had -- have I had an auditing relationship?
      25         Q.   Auditing, Sec Check, people tell me they're two

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      1    different things.
      2          A.   I have not had a Sec Check with regard to Lisa.
      3    have received some auditing since Lisa's death. And my
      4    emotional upset over the loss of my friend and her death
      5    certainly did come up as something that was very painful for
      6    me, yes.
      7          Q.   Okay.
      8          A.   And just -- but it wasn't that the auditing was
      9    designed to address that, it was that I originated it in
      10   another auditing session.
      11         Q.   You asked for it?
      12         A.   I asked -- it came up as this is painful for me.
      13         Q.   The reason I ask, not to be prying, but I've had
      14   some people, they were requested to have an auditing in
      15   reference to Lisa.
      16         A.   Not --
      17         Q.   Yours was the opposite?
      18         A.   Yes.
      19                                EXAMINATION
      21         Q. I just have a close-up on the trip back to Orlando
      22   and then we'll be done.
      23              Did you take your vehicle to Orlando?
      24         A.   Yes, I did. And wherever any other information
      25   came from, I don't know. I drove, she went with.

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      1          Q.   Did the Jeep stay at the office or the house?
      2          A.   The Jeep stayed at the office. It was loaned to
      3    Tom Mitchell, who worked with us at AMC at the time. And I
      4    know, because I heard the conversation between Lisa and
      5    Tom Mitchell when she gave him the keys, that the purpose,
      6    he was going to be hauling some things having to do with the
      7    Winter Wonderland project and he was going to use her Jeep
      8    to do it while she was gone.
      9          Q.   When you came back from Orlando, what time did you
      10   get in town, do you remember?
      11         A.   It was dark. Roughly 9:00 to 9:30 is my guess.
      12         Q.   And where did you go?
      13         A.   We went to the office in hopes that the Jeep was
      14   gonna be at the office, but it was not.
      15         Q.   And then what happened?
      16         A.   Well, we decided to go into the office and call
      17   Tom Mitchell and see if perhaps -- see, we were coming back
      18   early. We were not expected back until Saturday, but I had
      19   requested to bring Lisa home early. And so we thought it
      20   would have been an off chance the Jeep would have been there
      21   anyway.
      22              But we went in and we tried to call Tom Mitchell,
      23   see if we might could find him and get him to bring the Jeep
      24   up to the office. But he was not at home or we didn't get
      25   any chance. I can't -- we got his voice mail or whatever.

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      1               But anyway, I just said to Lisa, That's okay, why
      2    don't I just take you home and I'll help you get your Jeep
      3    tomorrow, I'll take you up and take you over or you can call
      4    Tom and he can bring it over and you can drop him off at
      5    home. That's how it came to be I took her home.
      6          Q.   And you got home to her apartment around what
      7    time, do you remember?
      8          A.   Maybe 9:45, ten o'clock, roughly.
      9          Q.   When you left her in the apartment, was she any
      10   better? Robotic?
      11         A.   No, I can guarantee if she had not been better I
      12   would not have left. In fact, as I sit -- I said this to
      13   some degree in my report here, but the thing that I have the
      14   most upset about and it is the most difficult for me to
      15   confront is that I left her there by herself that night, not
      16   realizing that -- what was gonna happen the following day
      17   was gonna happen, and feeling very badly that I left her,
      18   now looking back on it.
      19              But I have to tell you, I was exhausted after
      20   three days of dealing with this with her. I was like -- I
      21   had not slept hardly at all, the stress of the whole
      22   situation was very taxing, I just wanted to go home and get
      23   a good night's rest. And I thought, okay, if I can get her
      24   to go to bed, she's home, she's here, she's safe, she
      25   promised she would go to bed; I helped get her stuff

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      1    unpacked, you know, get settled in, it looked like she was
      2    gonna go to bed, she promised she'd call Katie and talk to
      3    her. I thought, well, she'll be okay, tomorrow I'll address
      4    this, you know, what needs to be done.
      5    But it's very hard for me to confront that I left
      6    her. And had I had any idea that she -- what was gonna
      7    happen happened, I would have never left her there by
      8    herself.
      9          Q.   Just a couple more questions, we'll be done.
      10              Do you know if Tom ever returned the Jeep to Lisa
      11   or did he take it back to the office?
      12         A.   I do not know how it is that she came to have the
      13   Jeep again the following day. All that I was -- I've been
      14   led or told or overheard is that Katie picked her up, `cause
      15   when she called me that morning she told me Katie was coming
      16   to pick her up, okay, so either -- and Katie did pick her
      17   up. Now, how she got the Jeep, whether Tom brought it to
      18   the Winter Wonderland site, they went to get it, I don't
      19   know, I have no data.
      20         Q.   The reason I ask, Katie did pick her up and they
      21   spent the day at the Winter Wonderland painting and doing
      22   props and everything else and Katie took her back to her
      23   apartment around 3:30, four o'clock.
      24         A.   For her to take a nap.
      25         Q.   Right. Without no Jeep.

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      1          A.   Right.
      2          Q.   And an hour later she's involved in an accident.
      3    I'm trying to figure out how she got the Jeep or possession
      4    of the Jeep.
      5          A.   What time was the accident?
      6               DETECTIVE SERGEANT ANDREWS: 5:30, I think.
      7               MR. CACCIATORE: I'm going to object. I
      8    think --
      9               DETECTIVE SERGEANT ANDREWS: She just don't
      10   know. He just asked her how she got the Jeep back.
      11              DETECTIVE CARRASQUILLO: I'm telling her.
      12   The reason I asked the question -- it wasn't a
      13   question, I'm telling her. The reason I asked --
      14   THE WITNESS: Okay.
      15              DETECTIVE CARRASQUILLO: From what everybody
      16   told me, that Jeep was at the office and Katie picked
      17   her up and took her home. It's just --
      18              DETECTIVE SERGEANT ANDREWS: We're trying to
      19   figure out how she got the Jeep.
      20              DETECTIVE CARRASQUILLO: -- trying to figure
      21   out how she got the Jeep.
      22              THE WITNESS: Well, I can tell you the Jeep
      23   was not at the office when we came home, I know that.
      24   Unequivocally I know that. I was there. And how she
      25   got it on Saturday, I don't know.

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      1               DETECTIVE CARRASQUILLO: The last one wasn't
      2    a question, it was the reason we asked the question.
      3               THE WITNESS: I would think Tom Mitchell
      4    could answer that.
      5                DETECTIVE CARRASQUILLO: That was the first
      6    time we've heard the name.
      7                MR. McGARRY: All right. That will do it.
      8                Thank you very much.
      10               CONCLUDED AT 3:50 P.M.)

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