582
1 IN THE CIRCUIT COURT FOR PINELLAS COUNTY, FLORIDA
CASE NO. 00-5682-CI-11
2
3
4
DELL LIEBREICH, as Personal
5 Representative of the ESTATE OF
LISA McPHERSON,
6
7 Plaintiff,
8 vs. VOLUME 5
9 CHURCH OF SCIENTOLOGY FLAG
SERVICE ORGANIZATION, JANIS
10 JOHNSON, ALAIN KARTUZINSKI
and DAVID HOUGHTON, D.D.S.,
11
Defendants.
12
_______________________________________/
13
14
15 PROCEEDINGS: Defendants' Omnibus Motion for
Terminating Sanctions and Other Relief.
16
CONTENTS: Testimony of Jesse Prince.
17
DATE: July 9, 2002. Afternoon Session.
18
PLACE: Courtroom B, Judicial Building
19 St. Petersburg, Florida.
20 BEFORE: Honorable Susan F. Schaeffer,
Circuit Judge.
21
REPORTED BY: Lynne J. Ide, RMR.
22 Deputy Official eCourt Reporter,
Sixth Judicial Circuit of Florida.
23
24
25
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
583
1 APPEARANCES:
2
MR. KENNAN G. DANDAR
3 DANDAR & DANDAR
5340 West Kennedy Blvd., Suite 201
4 Tampa, FL 33602
Attorney for Plaintiff.
5
6 MR. LUKE CHARLES LIROT
LUKE CHARLES LIROT, PA
7 112 N East Street, Street, Suite B
Tampa, FL 33602-4108
8 Attorney for Plaintiff
9
MR. KENDRICK MOXON
10 MOXON & KOBRIN
1100 Cleveland Street, Suite 900
11 Clearwater, FL 33755
Attorney for Church of Scientology Flag Service
12 Organization.
13
MR. LEE FUGATE
14 MR. MORRIS WEINBERG, JR.
ZUCKERMAN, SPAEDER
15 101 E. Kennedy Blvd, Suite 1200
Tampa, FL 33602-5147
16 Attorney for Church of Scientology Flag Service
Organization.
17
18 MR. ERIC M. LIEBERMAN
RABINOWITZ, BOUDIN, STANDARD
19 740 Broadway at Astor Place
New York, NY 10003-9518
20 Attorney for Church of Scientology Flag Service
Organization.
21
22
23
24
25
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
584
1 MR. STEPHEN J. WEIN
Battaglia, Ross, Dicus & Wein, P.A.
2 980 Tyrone Boulevard
St. Petersburg, Florida 33710
3 Counsel for Robert Minton.
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
585
1 THE COURT: You may be seated. Okay, before we
2 begin, two questions. Have you decided when you
3 want the trial date, Mr. Dandar?
4 MR. DANDAR: September.
5 THE COURT: All right. Have you decided
6 whether or not you need Mr. Rosen?
7 MR. DANDAR: No, I don't need Mr. Rosen.
8 THE COURT: All right. Then I'm going to
9 assume that -- I will go ahead and enter an order
10 pro hac vice admitting Mr. Rosen, just in case.
11 He'll be admitted, just for this purpose. And I'll
12 let you have --
13 MR. FUGATE: Should I prepare an order, Judge?
14 THE COURT: Do you mind?
15 MR. FUGATE: No.
16 THE COURT: Tell him to prepare an order,
17 whatever.
18 MR. FUGATE: I'll do it.
19 MR. DANDAR: So, Judge, since we will start
20 picking a jury for the trial in September, what
21 specific date would that be?
22 THE COURT: The second week in September.
23 Whatever that Monday is.
24 MR. DANDAR: All right.
25 THE COURT: You may proceed.
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
586
1 MR. DANDAR: Thank you.
2 THE COURT: That, of course, assumes the motion
3 to dismiss is not granted.
4 MR. DANDAR: I understand.
5 THE COURT: Mr. Lirot, are you still of the
6 mind that if Mr. Dandar is removed as counsel, you
7 are prepared on that date?
8 MR. LIROT: Hope springs eternal, Judge. But
9 yes, Judge, I'll be prepared on that date if need
10 be.
11 THE COURT: All right.
12 BY MR. DANDAR:
13 Q Mr. Prince, what I was trying to do before the
14 lunch break was finish up on the meetings that you had with
15 Mr. Minton and Stacy Brooks.
16 A Okay.
17 Q I believe we left off with your meeting with them
18 when things got a little testy at the hotel for dinner.
19 A At the Radisson.
20 Q At the Radisson. In my -- your note attached to
21 your affidavit, you said you met with me before you met with
22 them that Sunday. So that was April 14th.
23 A Okay.
24 Q All right? So let's go from then on. What
25 happened after April 14th?
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
587
1 A Mmm --
2 THE COURT: I'm sorry, he met with you before
3 he met with them?
4 MR. DANDAR: That same day. That is where this
5 handwritten note --
6 THE COURT: Right. For some reason, I thought
7 it was after. But it was before?
8 MR. DANDAR: On this particular day he met with
9 me at the mall with Mr. Lirot. And that was
10 April 14th.
11 THE COURT: In the afternoon? Then he went
12 there in the evening?
13 MR. DANDAR: Then he went there.
14 BY MR. DANDAR:
15 Q What happened after April 14th?
16 A Mmm, well, contact again -- and I think I
17 mentioned I had the one phone conversation with Mr. Minton
18 where I invited him over to my house. But they -- they
19 talked to me -- or got messages to me via my fiancee. They
20 would talk to her. And if anything happened -- we wouldn't
21 talk, we were not talking.
22 Q And what messages did you receive from Mr. Minton
23 and Ms. Brooks that way?
24 MR. WEINBERG: Objection. Hearsay, your Honor.
25 THE COURT: Hearsay. That would have to be
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
588
1 hearsay. I mean, that would have nothing to do with
2 Mr. Minton's state of mind or anything in this
3 proceeding, so you would have to, at the very least,
4 bring in the other person.
5 BY MR. DANDAR:
6 Q So you never talked with Mr. Minton or Ms. Brooks
7 since then directly, one-on-one?
8 A I talked with Mrs. Brooks. Mmm, she just told me
9 that everything was going to be fine, regardless of whether
10 or not I agreed to go with them or participate in activities
11 with them with Scientology. She just told me things were
12 going to be okay.
13 Q When did Ms. Brooks stop paying you your monthly
14 income?
15 A Either March or April.
16 Q And you said before that you went to Denis
17 deVlaming's office and spoke with him, and he couldn't help
18 you because of the conflict of interest.
19 Did you go to any law enforcement?
20 A Well, it's not entirely true to say that
21 Mr. DeVlaming couldn't help me. What Mr. DeVlaming did do
22 is refer me to his brother because, again, I wanted to
23 somehow get a federal law enforcement involved in this,
24 since my perception was that the criminal activity --
25 conspiracy and criminal activity happened at least in New
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
589
1 York, New Hampshire and Clearwater.
2 Mmm, he said that he would talk with a federal
3 agent that he did know and get back with me. He -- I guess
4 maybe a day or so later, he had a conversation with the
5 federal agent, Mr. Douglas DeVlaming. And he told me, after
6 speaking with an agent, they thought that it would make a
7 difficult case because Mr. Minton was now on the stand
8 lying, telling lies. If he changed his mind --
9 MR. WEINBERG: Objection. Hearsay, your Honor.
10 THE COURT: Sustained.
11 BY MR. DANDAR:
12 Q Did you ever meet personally with law enforcement?
13 A Yes, I did.
14 Q All right. Who did you meet with?
15 A I met with FDLE Agent Lee Strope.
16 Q Did you talk about Mr. Minton and Ms. Brooks?
17 A I pretty much gave Mr. Strope a complete rundown
18 of the meetings, with the dates similar to how I laid it out
19 there in the affidavit. And after --
20 THE COURT: Mr. Strope is with what agency?
21 THE WITNESS: FDLE.
22 THE COURT: FDLE?
23 A And after speaking with him, he asked me to give
24 Bob Minton a message. And the message was that if it is
25 determined that you have perjured yourself on the stand,
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
590
1 that he would see to it that charges would be brought.
2 BY MR. DANDAR:
3 Q This is Mr. Strope telling you to talk to
4 Mr. Minton?
5 A This is a message Mr. Strope asked me to give
6 Mr. Minton specifically.
7 Q Did you give him that message?
8 A Mmm, I wrote -- I hand-wrote what he said. I gave
9 it to my fiancee and she read it to Mr. Minton over the
10 phone.
11 Q Okay.
12 THE COURT: Mr. Prince, is it your testimony
13 here today under oath an agent of the Florida
14 Department of Law Enforcement asked you to deliver a
15 message to someone?
16 THE WITNESS: Yes, your Honor.
17 BY MR. DANDAR:
18 Q Any other meetings with law enforcement?
19 A Not about this specific incident.
20 Q Okay. Now, what was your impression, after
21 meeting with Ms. Brooks and Mr. Minton, on the meetings you
22 have just mentioned, all of these meetings --
23 MR. WEINBERG: Objection to the form. What was
24 his impression?
25 THE COURT: Yes. What does that mean?
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
591
1 MR. DANDAR: I didn't finish my sentence.
2 THE COURT: Go ahead.
3 BY MR. DANDAR:
4 Q What was your impression as to who was the person
5 who was creating the scenario that I told Mr. Minton to lie?
6 A Mr. Rinder.
7 Q And what is the basis of that? What is the basis
8 of your impression it is Mr. Rinder?
9 A Because that is what they said.
10 Q Who said?
11 A Bob and Stacy.
12 Q All right.
13 MR. WEINBERG: Well, could we just -- I mean,
14 is that -- your Honor, so his testimony is that at
15 some point Bob Minton and Stacy Brooks said that
16 Mike Rinder said for Mr. Minton to lie?
17 THE COURT: Yes. That is his testimony.
18 MR. WEINBERG: Could we date that testimony,
19 please?
20 THE COURT: Mr. Prince, is that your testimony?
21 THE WITNESS: Yes, it is.
22 THE COURT: If you could look at your affidavit
23 and tell us which one of these conversations that
24 that conversation took place.
25 THE WITNESS: Okay. Let me see if I see it
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
592
1 here. I don't seem to have my affidavit up here.
2 THE COURT: You don't? I think I have it right
3 here, if it will help.
4 MR. DANDAR: Well, I have the affidavit right
5 here. I'm sorry. I was looking at it instead of
6 listening to the Court.
7 THE WITNESS: This would have had to have
8 happened sometime after the date that I mentioned on
9 Page 5, Line 16, Paragraph Number 11 of the 3rd of
10 April or 2nd of April, sometime after that time
11 period.
12 BY MR. DANDAR:
13 Q After this -- after the 2nd or 3rd of April?
14 A Correct.
15 Q All right. Did Mr. Minton or Ms. Brooks tell you
16 this on more than one occasion?
17 A Well, the subject of the meetings -- after they
18 returned to Clearwater with Mr. Bunker April 2nd, the many
19 times that I met with them, the subject of the conversations
20 concerned what they were asked -- or what they were being
21 asked to do, what they wanted me to do.
22 So that was a continuing theme until, you know,
23 the point that it finally broke off, because I didn't, I
24 guess, qualify to meet with the Scientologists or speak with
25 them about this myself. But it was a continuing theme of
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
593
1 conversations.
2 THE COURT: I believe that, in fairness,
3 Mr.~Prince may have testified to some of this
4 yesterday, too.
5 MR. DANDAR: I think so maybe.
6 THE COURT: And may have dated some of this
7 yesterday. I'm looking through his affidavit. I am
8 remembering some of his testimony from yesterday.
9 MR. DANDAR: All right.
10 BY MR. DANDAR:
11 Q Now, Mr.~Prince, yesterday you talked about Volume
12 0 and 00. Do you recall that? You looked in the book
13 Introduction To Ethics and you said --
14 A Yes.
15 Q -- what you were looking for may be in Volume 0
16 and 00?
17 A Yes.
18 Q And there are a bunch of books over there. Are
19 there any of the books you want to refer the Court to?
20 A Sure, if I could just walk over there.
21 MR. DANDAR: Is that all right, Judge?
22 THE COURT: Yes. By the way, Ms. Greenway
23 asked if she could take my picture. You can't take
24 pictures when court is in session. So I gave her
25 permission to come in and take pictures when court
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
594
1 wasn't in session of whatever she wanted to take
2 pictures for. But when court is in session you
3 cannot take pictures unless you are connected with
4 the media and you are a pool photographer. Then you
5 can.
6 BY MR. DANDAR:
7 Q No other books?
8 A No.
9 Q All right.
10 A This is -- first off, I would like to say
11 yesterday that I said that this was a crime for a person to
12 give testimony about Scientology. I actually misspoke. It
13 is a suppressive act to do that, according to this document
14 here, suppressive acts, suppression of Scientology,
15 Scientologists, the fair game law.
16 And what it states specifically is --
17 THE COURT: Tell us, first of all, what are you
18 reading from.
19 THE WITNESS: Oh, sorry.
20 BY MR. DANDAR:
21 Q The book?
22 A I'm reading from HCO Division 1 Policy Volume,
23 Scientology Policy Volume.
24 THE COURT: Okay. Those are Scientology
25 policies in a book?
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
595
1 THE WITNESS: Yes, your Honor.
2 THE COURT: Is there a page number?
3 THE WITNESS: Yes, your Honor. It is 553, what
4 I'm going to make reference to.
5 MR. LIEBERMAN: Could we have the date on that
6 book?
7 BY MR. DANDAR:
8 Q Copyright on the front?
9 THE COURT: Would it matter with these
10 policies --
11 MR. LIEBERMAN: Well, some, it may.
12 THE WITNESS: This is copyright 1970 through --
13 what is it, 1950, it looks like. These are all of
14 the copyright notices here.
15 THE COURT: Okay. I'm going to let you-all
16 take a look at it.
17 MR. WEINBERG: Now? Or --
18 THE COURT: No. Let him go ahead and have his
19 testimony, and then before cross-examination you-all
20 can look at the book.
21 BY MR. DANDAR:
22 Q So a suppressive act is someone saying they want
23 to leave Scientology?
24 A Yes. And testifying as a hostile witness against
25 Scientology in public is a suppressive act.
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
596
1 Q All right. That has to do with testifying?
2 A Correct.
3 Q What about leaving Scientology or saying you want
4 to leave?
5 A Mmm, yesterday I showed the reference and we went
6 through that. It's a high crime to publicly depart
7 Scientology.
8 Q This may be something I already marked. Let me
9 show you what has been marked as Plaintiff's Exhibit 133.
10 CS Series 22.
11 Can you identify that Exhibit 133?
12 A Yes. This is an HCO bulletin of 28 November,
13 1970, Mmm, subtitled "CS Series 22." The "CS Series" means
14 case supervisor series. It's -- it's a series that is a
15 staple or basic for persons that are supervising auditing in
16 Scientology. And this document refers to the subject of
17 psychosis.
18 Q And this document came from the PTS/SP course book
19 you read yesterday. Is that correct?
20 A Correct.
21 Q Okay. Now --
22 THE COURT: Who is permitted to take that
23 course? Maybe you asked it before, but, I mean, if
24 I'm a new Scientologist, new public member, can I go
25 register for that course?
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
597
1 THE WITNESS: You certainly could. Any
2 Scientologist in good standing --
3 THE COURT: Could take that course?
4 THE WITNESS: Yes, your Honor.
5 THE COURT: Okay.
6 BY MR. DANDAR:
7 Q This course book also contains the search and
8 discovery bulletin?
9 A I believe it does.
10 Q Okay. Now, this particular document, Exhibit 133,
11 CS Series 22, does this have anything to do with people
12 wanting to leave?
13 A Well, if you turn to the second page, it talks
14 about the easiest ways for a case supervisor to detect the
15 insane, and we go down here to Number 6, it says: "They
16 often seek transfers or wish to leave."
17 Q Now, does this apply to staff as well as public
18 members?
19 A Absolutely.
20 THE COURT: I think this is already in
21 evidence, isn't it?
22 MR. DANDAR: I'm not sure. You told me to mark
23 this yesterday as an exhibit.
24 THE COURT: Well, now that I'm looking at it,
25 I'm thinking I read it before. But if you are not
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
598
1 sure, you want to introduce it again, why, that is
2 all right.
3 MR. DANDAR: I'm really not sure.
4 THE COURT: All right.
5 MR. DANDAR: I know we talked about this
6 yesterday.
7 THE COURT: I'm not positive if this was the
8 document, but I have read some of this before.
9 MR. DANDAR: Yes. It is quite possible.
10 MR. WEINBERG: We have no problem, but the
11 next-to-last sentence says: "The insane can be
12 helped, they are not hopeless." We don't have a
13 problem with this. But the introspection rundown
14 comes after this policy.
15 THE COURT: But you have no objection to this
16 being introduced?
17 MR. WEINBERG: No.
18 MR. DANDAR: We move it into evidence.
19 MR. WEINBERG: It was referred to in the
20 introspection rundown which was introduced three or
21 four years later, this policy.
22 THE COURT: All right.
23 BY MR. DANDAR:
24 Q Speaking of the introspection rundown, Mr.~Prince,
25 speaking of your experience, expertise, is there any part of
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
599
1 the introspection rundown that is considered religious?
2 MR. WEINBERG: Objection to his competence to
3 this because Mr.~Prince previously testified he
4 wasn't trained on the introspection rundown and
5 never -- as an auditor never did any introspection
6 rundown.
7 THE COURT: I thought he did.
8 THE WITNESS: That is correct. I did. I never
9 was -- I never stated that I was not trained on the
10 introspection rundown.
11 THE COURT: I'm sorry, what?
12 THE WITNESS: I never stated I was not trained
13 on the introspection rundown. That is false. I am
14 very trained on the introspection rundown.
15 MR. WEINBERG: What he said was he participated
16 in an isolation watch, not as the auditor, you know,
17 but as one of the people staying with Teresita.
18 THE COURT: Is isolation watch and
19 introspection rundown the same?
20 MR. WEINBERG: It is part, Step whatever it is,
21 0, 00.
22 THE COURT: All right.
23 MR. DANDAR: This will kind of answer the
24 question, I think.
25
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
600
1 BY MR. DANDAR:
2 Q So, Mr.~Prince, is there parts or all of the
3 introspection rundown that is religious? A religious
4 practice?
5 A Mmm, in the very first bulletin about the
6 introspection rundown, L. Ron Hubbard describes it as a new
7 technical breakthrough that marveled something else of the
8 20th century, I forget specifically what it says there. But
9 it was hailed as a researched scientific discovery for
10 handling insanity.
11 MR. WEINBERG: So, your Honor, is what
12 Mr. Dandar is doing is challenging whether or not
13 the introspection rundown is part of the religion of
14 Scientology? Because if he is, I think that has
15 already been decided in this case and it is not
16 appropriate and we should not be wasting our time on
17 it.
18 THE COURT: Haven't we decided that -- or -- I
19 don't know because I don't know -- I saw a motion
20 once that dealt with religiocity. I didn't hear any
21 of that.
22 MR. DANDAR: That was not the --
23 MR. LIEBERMAN: But you have stated several
24 times, your Honor, that there is no question in this
25 case as to the religious nature of Scientology or
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
601
1 religious nature of the introspection rundown.
2 THE COURT: Okay. I know I have stated that I
3 have no question on the -- that the Church of
4 Scientology is a religion and it is a recognized
5 religion in the Church. And I have no question in
6 my mind that Lisa McPherson was undergoing some sort
7 of introspection rundown. I didn't know whether I
8 said that introspection rundown is part of the
9 religion of the Church. I don't even know if that
10 is a call for me to make, to tell you the truth. I
11 would suspect the Church doctrine would tell us
12 whether it is or isn't.
13 MR. LIEBERMAN: That is correct. And the
14 Church characterizes what is religious practice.
15 THE COURT: I don't know if I have seen that or
16 not. I know we have a Mr. Rice affidavit. I
17 haven't looked at it in some time.
18 MR. LIEBERMAN: And he quite clearly places it
19 within the Scientology practice. In fact, every
20 part of Scientology, by definition, is part of
21 Scientology belief and practice and is not a matter
22 for the Court to challenge what is characterized by
23 the Church as this religion.
24 THE COURT: I am going to let him answer this.
25 I think he already has answered it, but I don't know
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
602
1 we're going to go there. And certainly one answer
2 isn't going to get it there.
3 MR. DANDAR: Right.
4 BY MR. DANDAR:
5 Q Mr.~Prince, Mr. Hubbard called it scientific
6 breakthrough?
7 A That is correct.
8 Q Did he ever call it religious practice?
9 A Never.
10 Q Did he call auditing a religious practice?
11 A No.
12 Q Oh.
13 A Not to my knowledge. I mean, this whole business
14 of religion -- I don't know, you know, it is kind of -- has
15 kind of reared its head in Scientology every now and again.
16 When I was here at the Flag Service Organization
17 in 1979, there was a scare -- a cold war scare of some
18 nuclear threat and conscription in the Army and on and on.
19 This is what we were told. So all of the staff had to do a
20 two-week course called the minister's course where you are
21 instantly trained to be a minister. This was part of -- a
22 program which, in part, was to kind of improve or create a
23 religious image for Scientology.
24 But if you will notice, in every document that
25 Mr. Hubbard writes about Scientology, whether or not it is a
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
603
1 green --
2 THE COURT: I don't want to hear this. The
3 United States Government, State of Florida, on and
4 on down, determined Scientology is a religion, the
5 Church of Scientology is a church. I don't care
6 what they used to think, what they used to say. It
7 doesn't matter. That is it.
8 MR. DANDAR: What I'm -- I was getting at is
9 just the introspection rundown itself.
10 THE COURT: Okay.
11 BY MR. DANDAR:
12 Q The part of the introspection rundown talking
13 about get some rest --
14 MR. WEINBERG: Your Honor, could I --
15 BY MR. DANDAR:
16 Q -- make sure you eat --
17 MR. WEINBERG: This is precisely why Mr.~Prince
18 should not be an expert, considered an expert in
19 Scientology, because as he sits here today, he still
20 is sitting there saying it is not even a religion or
21 a church. He doesn't recognize it --
22 THE COURT: He wasn't. He was talking about
23 some things that were said back in the 1970s when
24 they were all sitting around talking --
25 MR. WEINBERG: He just said that -- well, I
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
604
1 don't want to argue with you. I mean, it -- that is
2 where he was going with this and that is what
3 this -- that is what this is about.
4 MR. DANDAR: It is not what this is about. I
5 just asked him what I'm asking him now, the
6 introspection rundown, the part that talks about
7 resting and eating -- resting and eating, something
8 else --
9 THE COURT: 0, 00.
10 MR. DANDAR: Yes, those two steps.
11 BY MR. DANDAR:
12 Q In your experience within the Church of
13 Scientology, was that ever considered a spiritual or
14 religious part of Scientology?
15 MR. LIEBERMAN: Your Honor, again, this is
16 unconstitutional inquiry. You can't bifurcate a
17 religious practice and say part is and part isn't.
18 To just even hear this testimony is an
19 unconstitutional attack on the religion.
20 THE COURT: Mr. Lieberman, your objection on
21 that is preserved.
22 MR. LIEBERMAN: Thank you.
23 A Well, you know, since -- you know, people that are
24 atheists or other ideas also rest and sleep. You know, it
25 never came to me that this was a religious experience to
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
605
1 rest and eat.
2 BY MR. DANDAR:
3 Q Well, and in your knowledge of Scientology, if
4 someone is injected with Valium or chloral hydrate, are they
5 eligible to have auditing?
6 A According to -- Mmm -- the HCO bulletin entitled
7 Model Session --
8 Q How do you spell that?
9 A Model, M-O-D-E-L, model session, a person who has
10 had drugs or who has used drugs continuously is not eligible
11 for auditing until six weeks after the period of taking the
12 drugs.
13 Q Now, in your experience with Teresita, you said
14 Dr. Dink, Hubbard's doctor, came out and injected her with
15 some kind of drug?
16 A Correct.
17 Q And she went to sleep?
18 A Correct.
19 Q How soon after that did she have auditing?
20 A Within hours after awaking.
21 Q Was that within the written policy?
22 A Is that what now? I'm sorry.
23 Q Is that per policy to have an auditing right after
24 you have slept off the effects of the drug?
25 A Well, in the introspection rundown bulletin, it
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
606
1 states that each program is tailored specifically for the
2 individual. So to that degree, if the person had to sleep
3 first in order to get auditing, they would get the auditing,
4 but then there is also later references in Scientology
5 technology which state that in a period after the auditing
6 that was delivered, while the person was on drugs, you could
7 then go back and check those areas again to make sure that
8 everything is fine.
9 Q Okay. Let me show you Exhibit 134. And do you
10 recognize where this copy of this Page 258 comes from?
11 A Yes. This comes from the Hubbard Administrative
12 Dictionary.
13 Q And what -- how does it define the phrase "high
14 crimes"?
15 A It says: "High crimes. 1. These consist of
16 publicly departing Scientology or committing suppressive
17 acts. Cancellation of certificates, classifications and
18 awards and becoming fair game are amongst the penalties
19 which can be leveled for this type of offense as well as
20 those recommended by Committees of Evidence."
21 MR. DANDAR: Okay. That is all of the
22 questions I have.
23 THE COURT: All right. Thank you. You may
24 inquire.
25 MR. WEINBERG: Thank you.
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
607
1 CROSS-EXAMINATION
2 BY MR. WEINBERG:
3 Q Mr.~Prince, David Miscavige busted you from your
4 position of authority -- your executive position of
5 authority in the RTC -- in March of 1987, didn't he?
6 A Correct.
7 THE COURT: I'm sorry, you just got started.
8 Did you want to introduce this 134?
9 MR. DANDAR: Yes, sir. In fact --
10 MR. WEINBERG: We object to that. I would like
11 to see the dictionary, see what the date of the
12 dictionary was.
13 MR. DANDAR: Do you have it here? In fact, I
14 just realized, unless you want to do this later,
15 there are a bunch of things I marked and didn't move
16 them into evidence.
17 THE COURT: I'll go ahead and let you do
18 that --
19 MR. DANDAR: Later?
20 THE COURT: -- later. But don't forget.
21 MR. DANDAR: Right. Yes.
22 MR. WEINBERG: Should I start over?
23 THE COURT: Yes.
24 BY MR. WEINBERG:
25 Q Mr.~Prince, David Miscavige busted you from your
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
608
1 position -- your executive position of authority in the RTC
2 in March of 1987, didn't he?
3 A Correct.
4 Q And at that time you were removed from your post,
5 the last executive post you ever held in the Church of
6 Scientology. Correct?
7 A Correct.
8 Q And that post, you said, was deputy inspector
9 general external. Right?
10 A Right.
11 Q Now, you were removed because you had supported
12 Pat Broeker and Annie Broeker and Vicki Aznaran in their
13 effort to change Scientology tech. Correct?
14 A That is categorically false.
15 Q That was precisely what occurred, that Pat
16 Broeker, who had designated himself the loyal officer, was
17 in the process of changing, among other things, the
18 Scientology grade chart, right? That is what he was doing?
19 A That is categorically false.
20 Q So Mr. Broeker wasn't doing that?
21 A Correct.
22 Q And you never acknowledged that Mr. Broeker did
23 that?
24 A Correct.
25 Q So Mr. Broeker wasn't off on his own, trying to
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
609
1 change the religion of Scientology, after Mr. Hubbard died?
2 A Well --
3 Q Yes? Or no?
4 A Excuse me. Let me answer the question.
5 THE COURT: Well, I'll tell you how this works
6 on cross-examination. Go ahead and answer the
7 question, but if you feel you have to explain your
8 answer, you are allowed to do that after you have
9 answered it.
10 THE WITNESS: Okay. I'm sorry.
11 A Ask me the question again.
12 BY MR. DANDAR:
13 Q Wasn't Mr. Broeker caught in -- in an attempt to
14 change Scientology tech?
15 A I have no percipient knowledge of that.
16 Q You have no percipient knowledge of that?
17 A In other words, I was not there -- let me -- I was
18 not there. I didn't see him changing anything.
19 And, again, I was going to say, I have heard some
20 hearsay about it. Since you vehemently object about it, I
21 won't comment about it, but I -- you know, I haven't
22 personally been with Mr. Broeker when he's altering
23 Scientology technology.
24 Q When you were in the RTC prior to March of 1987,
25 in that year after Mr. Hubbard died, you became aware of the
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
610
1 fact that some point in time that Mr. Broeker was changing
2 and altering Scientology tech, weren't you?
3 A Incorrect.
4 Q You became aware of the fact that Vicki Aznaran
5 was part of an effort to change Scientology tech, weren't
6 you?
7 A Absolutely incorrect.
8 Q And what happened in March of 1987 is that
9 Mr.~Broeker was removed from all authority. Correct?
10 A Mr.~Broeker was removed from authority.
11 THE COURT: Wasn't? Or was?
12 THE WITNESS: He was, your Honor.
13 BY MR. WEINBERG:
14 Q Annie Broeker, his wife, was removed from all
15 positions of authority. Correct?
16 A To my knowledge, that is correct.
17 Q Your boss, Vicki Aznaran, was removed from her
18 position of authority. Correct?
19 A Correct.
20 Q And you were removed?
21 A Correct.
22 Q And you were at that time -- at that point in
23 time, you went from what you described as an executive
24 position with some authority in the -- in RTC. Right?
25 A Correct.
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
611
1 Q To no authority whatsoever?
2 A No. That is incorrect.
3 Q From -- for the next five years after March of
4 1987, did you ever hold a position where someone was junior
5 to you? You know what I mean by that?
6 A Yes, I do. And, yes, I have.
7 Q I mean, you were, what, a machine operator after
8 that?
9 A Mmm, no. I worked on post-production,
10 preproduction and post-production for films.
11 Q That was one of the things you did, and you were a
12 Cinemix, was that your job?
13 A No.
14 Q What was your job?
15 A My job was like an assistant engineer, assistant
16 sound mixer. Again, I state I worked for post-production
17 and preproduction for films and videos.
18 Q During that period of time you were in the RPF a
19 couple of times. Correct?
20 A Incorrect.
21 Q How many times were you in the RPF?
22 A I was in the RPF two times, but not that period of
23 time.
24 Q You were in the RPF in March of 1987. Correct?
25 A Correct.
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
612
1 Q All right. Until what, the end of 1987?
2 A Mmm, I think it was -- I wasn't in there a very
3 long time. I think maybe four months.
4 Q By the way, there is no higher crime in
5 Scientology than changing the tech. Correct?
6 A That is incorrect.
7 Q Well, what would be a higher crime than changing
8 Mr. Hubbard's scriptures?
9 A Placing Scientology and Scientologists at risk.
10 Q One of the highest crimes in Scientology is to
11 alter the tech. Correct?
12 A It is a high crime to do that. Yes.
13 Q Now, for the next -- for those five years after
14 you were busted -- and that was the day you claimed, by the
15 way, that you pulled these guns on David Miscavige and
16 threatened to kill him?
17 A You didn't mention a specific day. What day are
18 you talking about?
19 Q Well, what day are you talking about when you were
20 busted?
21 THE COURT: Without worrying too much about the
22 date, the date you testified about when you were
23 rousted from bed or got out of bed and went and got
24 the guns, that is on the same day, right?
25 THE WITNESS: Yes. I'm sorry.
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
613
1 THE COURT: That is the day you were busted?
2 THE WITNESS: Yes.
3 THE COURT: That is what he was referring to.
4 THE WITNESS: Okay. I'm sorry. I just didn't
5 understand the question.
6 BY MR. WEINBERG:
7 Q That is the same day you claim you pulled these
8 guns on David Miscavige and you threatened to kill him.
9 Correct?
10 A I didn't threaten to kill Mr. Miscavige. What --
11 maybe you have a wrong idea about what happened there. I
12 came there to defend myself. Twelve people were attacking
13 me, were trying to hold me. Because I do know karate and
14 have a black belt in it, I was able to get them away from me
15 until I went and got protection for myself.
16 Q So then these twelve people that were attacking
17 you let you go back to your room, get these two loaded guns?
18 A They didn't know where I was going.
19 Q That didn't really happen, did it, Mr.~Prince?
20 A Yes, it did.
21 Q You didn't pull guns on David Miscavige.
22 A Yes, it did.
23 Q So this is the person you say you could still be
24 friendly with?
25 A You know, Mmm -- yes. And I need to explain
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
614
1 something here because, you know, Mr. Weinberg, you and I
2 have been around and around on this in front of Judge Moody.
3 So, you know, you are giving me the exact same questions and
4 I'll sit here and be patient with you, but I think the
5 record reflects we have done this one or two times before.
6 THE COURT: See, I haven't heard it. This is
7 my hearing, so we'll do it again.
8 MR. DANDAR: Explain yourself.
9 THE WITNESS: Okay.
10 BY MR. WEINBERG:
11 Q So you contend that you really did go back to your
12 room, get two loaded weapons, and walk back and enter a room
13 and point them directly at David Miscavige?
14 A No, I never walked back into a room. By that
15 time --
16 Q You ran back into the room?
17 A Would you like me to explain it? I --
18 Q Explain it.
19 MR. DANDAR: Wait. Wait. Objection.
20 BY MR. WEINBERG:
21 Q Did you --
22 MR. DANDAR: He needs to explain it.
23 Mr. Weinberg --
24 MR. WEINBERG: I'll withdraw that question.
25
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
615
1 BY MR. WEINBERG:
2 Q Did you point two loaded guns --
3 MR. DANDAR: That is not fair.
4 BY MR. WEINBERG:
5 Q -- at David Miscavige?
6 A No, I did not.
7 Q Who did you point them at?
8 A I had the one gun on my hip and the .45 in my
9 hand. And they stood this way. The assault rifle never was
10 pointed at anyone. It was just on my hip like this. And I
11 had the .45.
12 And Mr. Miscavige, when he saw me, walked directly
13 up to me with those guns in my hand and said, "Jesse, we are
14 friends. Let's talk."
15 So I don't think he felt that threatened. And I
16 think that Judge Moody pointed that out to you the last time
17 we were doing this.
18 Q I mean, no one would feel threatened when they had
19 just busted somebody from position and the person got so mad
20 to go back to the room and get two loaded guns and walk into
21 a room. You can't imagine anybody would be threatened by
22 that, would they?
23 A I think that is a mischaracterization of what
24 happened.
25 Q Well, my question is was there a particular reason
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
616
1 why you never told that story until -- until you started
2 getting paid to be a witness in the FACTNet case in 19 --
3 whatever it is, 1998? Why you waited all those years to
4 tell that story?
5 A Mmm, I don't know how to answer that question,
6 Mr. Weinberg. You are associating things that don't
7 associate. You are associating with me being paid telling
8 stories. And there is no association there.
9 Q Well, is there a particular reason, in the years
10 after this alleged incident took place, that took you until
11 1998 to first tell this story about pulling guns on David
12 Miscavige?
13 MR. DANDAR: Object to the form. It makes no
14 sense. Telling stories where? Under oath? In a
15 deposition? To his friends?
16 THE COURT: I don't, either, because I don't
17 know whether you are talking about the first time he
18 ever testified about that, and if that is the first
19 case he was ever involved in, that is the first time
20 he ever testified about that.
21 MR. WEINBERG: I --
22 THE COURT: I'll tell you one thing --
23 MR. WEINBERG: I'm sorry, I didn't mean to --
24 THE COURT: -- don't get ahead of me because
25 you want to go at this witness.
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
617
1 MR. WEINBERG: You are right.
2 THE COURT: I won't have it.
3 MR. WEINBERG: Right.
4 THE COURT: I won't have you really cutting
5 this man off. I mean, I know you want to get where
6 you want to go. But you'll have to go slow.
7 And, Mr. Prince, whatever you told Judge Moody,
8 I haven't heard it, I haven't seen too much of the
9 transcript before Judge Moody, so I don't want to
10 hear what I -- I already told Judge Moody this, I am
11 not Judge Moody.
12 THE WITNESS: I understand.
13 THE COURT: If he asks you a question, unless I
14 tell him, "You can't ask that question," just
15 answer, even if you have already answered it before.
16 Okay?
17 THE WITNESS: Okay. Yes, your Honor.
18 THE COURT: Let's go.
19 BY MR. WEINBERG:
20 Q You were interviewed by Earle Cooley while still
21 in the Church in 1988, weren't you, in relation to another
22 lawsuit?
23 A I would have to see something about that. I'm not
24 sure what you are talking about.
25 Q You didn't say anything about the guns to him, did
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
618
1 you?
2 A Again, I would have to see what you're talking
3 about.
4 Q Well, you mention the 1994 interview with
5 Mr.~Cooley. You didn't say anything about the guns to him
6 in that interview, did you?
7 A I mean, you know, you are mixing apples and
8 oranges. I mean, I don't understand what you are asking me.
9 I mean, I have told that story long before 1998 to my
10 friends, my family, people that I know. I mean, you know,
11 it isn't like here is some money, let's tell this story. I
12 beg to differ with the way you are characterizing what
13 happened here.
14 Q The reason you told the story to Mr. Minton in
15 April of this year was to threaten him as to what you would
16 do as to what kind of person you were? I mean, what did you
17 tell him about it for?
18 A I told him that story, as I gave testimony
19 yesterday, to show that Scientology, more than likely, will
20 never keep or honor an agreement with anyone. It wasn't to
21 say I'm going to run and shoot you with guns. It was to
22 give him an example to show him that Scientology will never
23 honor an agreement.
24 Q Now, you would agree that the positions that you
25 held after you were busted were extremely low positions in
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
619
1 the Church of Scientology?
2 A I would beg to differ on that, as well.
3 Q Now, you were -- you were so humiliated,
4 apparently, by Mr. -- what you claim Mr. Miscavige did in
5 March of 1987 that you pulled these guns on him. That is
6 what it was about, wasn't it?
7 A Absolutely not. And even as we have been sitting
8 here, I think I made it clear to you why I went and got
9 those guns. It wasn't humiliation. It was being attacked.
10 Q You were --
11 A Physically attacked.
12 Q You resented the fact that you had been busted?
13 A I resented the fact I was being physically
14 attacked by people that used to be my friends.
15 Q No. My question is did you resent the fact that
16 you had been busted from your executive position in RTC?
17 A And I'll answer the question it isn't so much that
18 I resented the fact that --
19 THE COURT: Come on, Mr.~Prince, of course you
20 must have been annoyed. I don't know why we're
21 playing a semantics game. Anybody would be annoyed
22 if they were busted from the position they
23 thought --
24 THE WITNESS: No, your Honor, that isn't right.
25 I think that deserves clarification because I was
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
620
1 pretty much tired of that activity that I had been
2 involved in, in Scientology. I was ready for a
3 change. I was ready to be done with that position
4 because that -- that position responsibility
5 entailed being involved in criminal activity.
6 This is something that I had not experienced in
7 Scientology prior to going to Gilman, Hot Springs
8 and working at that level. To me, Scientology was
9 something different than what I was doing.
10 So, no, it wasn't a big deal for me, you know.
11 I was already wanting to be away from that
12 responsibility.
13 But what was a big problem for me was twelve
14 people grabbing me, because I had an earlier
15 incident of that happening in Scientology where six
16 people grabbed me and locked me in a room for three
17 months, and I ended up staying 16 years. So that
18 had precedent over that position I was being removed
19 from.
20 BY MR. WEINBERG:
21 Q So you were relieved by the fact you were busted
22 from your position?
23 A Yes. I was somewhat relieved by it.
24 Q Now, you -- you, Jesse Prince, dislike vehemently
25 David Miscavige, don't you?
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
621
1 A I would not say that that is true. I have no
2 vehement dislike for him. I dislike the things that he
3 does. But I don't envy his position. He's the leader of a
4 religion. He has a lot of responsibility. That doesn't
5 give you license to be a criminal, though.
6 Q You spent the last four years, ever since you met
7 apparently sometime in the summer of 1998, started getting
8 paid by, ever since you met Mr. Minton, you spent the last
9 four years trying to destroy David Miscavige, haven't you?
10 A That is incorrect.
11 Q You have picketed where you have spoken vilely and
12 obscenely about Mr. Miscavige, haven't you?
13 A Yes, I have.
14 Q You have picketed various Churches of Scientology
15 around the country and even in the world, correct?
16 A That is incorrect. I never picketed an
17 organization outside of the United States.
18 Q Just in this country?
19 A Correct.
20 Q You have threatened David Miscavige in these
21 pickets, haven't you?
22 A I need you to clarify what you mean by threatened
23 for me, please.
24 Q Threatened to do harm to him.
25 A I have jokingly alluded to it, yes, I have.
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
622
1 Q You thought it was funny?
2 A Yes, I did.
3 Q And did you think it was funny when you were
4 outside the various Churches of Scientology, including what
5 you call the mecca of Scientology, holding signs and
6 shouting obscenities about the leader? You thought that was
7 funny, too?
8 A I -- I think you would have to show me or present
9 evidence that I was holding a sign, shouting obscenities.
10 Q Oh, we will, Mr.~Prince.
11 A Okay. I would like to see that.
12 Q Did you think that was funny?
13 A I would like to see the evidence, please, sir.
14 Q Would you consider, sir -- I mean, I think you
15 said that Mr. Minton was the -- something basically the most
16 harassed person you'd ever seen, something to that order?
17 A Something along that order, correct.
18 Q Would you consider what you and Mr. Minton and
19 Ms.~Greenway and Mr. Alexander and Mr. Oliver and the other
20 folks at the LMT -- would you consider what you were doing
21 harassing Scientology?
22 A Well, what were we doing that was supposed to be
23 harassing?
24 Q I mean --
25 THE COURT: His question to you is whatever it
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
623
1 was you were doing, would that be, in your mind,
2 harassing Scientology?
3 THE WITNESS: Well, I guess to clarify it, if
4 it meant picketing, does that mean harassing
5 Scientology? It has a broader meaning to me. It
6 means I'm exercising my First Amendment rights as a
7 citizen to protest.
8 Mmm, if you want to call that harassing
9 Scientology, I call it exercising my freedom.
10 BY MR. WEINBERG:
11 Q I'm asking you, because remember you talked about
12 the harassment time line of Mr. Minton?
13 A Yes.
14 Q Do you remember talking about that?
15 A Yes.
16 Q And my question to you, if -- if we put all of
17 your pickets and all Mr. Minton's pickets and all your
18 postings and all Mr. Minton's postings and all of the
19 postings of these folks that have been in and out of the LMT
20 and all the pickets of them on a time line, do you think
21 that time line might be somewhat larger than this Minton
22 harassment time line?
23 A I think it would be minuscule and it would pale by
24 comparison.
25 Q By the way, are you part of an anti-Scientology
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
624
1 movement?
2 A I have never been part of an anti-Scientology
3 movement.
4 Q Are you an anti-Scientologist?
5 A No, I am not.
6 Q What do you consider yourself?
7 A I consider myself in the instant case where I'm
8 sitting right here today an expert witness concerning
9 Scientology.
10 Prior to that, I worked in an establishment
11 whereby I helped people who had been victimized by
12 Scientology.
13 Q And would you consider Mr. Minton to be an
14 anti-Scientologist during those four years that you were
15 part of the A team, I think you said?
16 A I consider Mr. Minton to be an activist.
17 Q An activist?
18 A Yes.
19 Q What is that?
20 A You tell me what it is. Do you need to know what
21 the word means? I mean, he was an --
22 Q What do you mean --
23 A -- activist concerning --
24 Q What do you mean when you say he was an activist?
25 A He was an activist ensuring the rights, basic
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
625
1 human rights, that are accorded to us through our
2 constitution.
3 I think Mr. Minton got started on his relationship
4 with Scientology when he found out a Scientologist was
5 trying to remove the name "Scientology" from a newsgroup --
6 or at least this is the way he explained it to me. And how
7 lawyers and raids and things would come to even discuss
8 Scientology, which is how I knew it from being in
9 Scientology.
10 I knew if you ever spoke about Scientology outside
11 of Scientology, you would get clobbered. So to actually see
12 people doing it openly on the Internet was --
13 THE COURT: That is well past the answer. You
14 don't have to -- we have to try to get through this.
15 THE WITNESS: Okay.
16 THE COURT: He simply asked you to define what
17 an activist was. And I think you have done that.
18 THE WITNESS: All right.
19 BY MR. WEINBERG:
20 Q Now, when did you begin -- when did you begin your
21 work against Scientology? What date or time?
22 A Mmm, I began to give testimony concerning
23 Scientology, to the best of my recollection, in the FACTNet
24 case.
25 Q Specifically, up until I -- I think you said you
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
626
1 considered yourself a Scientologist until, I think you said,
2 1997. Correct? Isn't that what you said in your testimony?
3 A I think maybe '96, I said.
4 Q All right. So you considered yourself a
5 Scientologist after you left the Church of Scientology in
6 1992, after you say that you were -- you said all those
7 horrible things happened to you in the five-year period, you
8 still considered yourself a Scientologist in '93, '94, '95
9 and '96. Correct?
10 A I think I should clarify that for you, if that is
11 okay. I think that I still had Scientology values. I think
12 that I still respected some of the tenets of Scientology,
13 and I freely associated with Scientologists.
14 Q Well, you were working for a public member of
15 Scientology for several years, right?
16 A Several years is incorrect.
17 Q How many years?
18 A Maybe one.
19 Q This is the job that the Church had helped you get
20 after you left the Church where you were making $60,000 or
21 $70,000 a year. Was that your testimony?
22 A I think you are mischaracterizing what happened.
23 No, that is not my testimony. The Church didn't help me do
24 anything. It never has.
25 Q Well, just tell us one of those Scientology values
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
627
1 that you -- that you continue to accept and feel close to
2 after you left the Church of Scientology.
3 A That man -- man is a spiritual entity. That --
4 Mmm -- man is capable of seemingly -- seemingly more capable
5 than is realized and those potentials can be cultivated and
6 used and expanded on.
7 Q Any other ones?
8 A You know, some of the organical principles about
9 the importance of organization, the importance of schedules.
10 You know, these kind of things.
11 Q When you were a Scientologist, you believed, did
12 you not, that psychiatric problems were spiritual in nature.
13 Correct? That is what you believed? And could be dealt
14 with spiritually through the religion of Scientology. You
15 believed that when you were a Scientologist, didn't you?
16 A Yes, I did.
17 Q And that is what Scientologists believe, don't
18 they?
19 A I can't speak for all Scientologists. I know
20 that, you know, as you are trained in Scientology, you
21 accept more and more of what you read, and it's a
22 progression, it is a degradation of belief system, I guess.
23 But I couldn't say that everyone believes that.
24 Q Well, you could say that Scientologists -- no
25 Scientologist would want to be committed to a mental
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
628
1 institution. You can say that, can't you, from your years
2 as a Scientologist?
3 A Mr. Weinberg, I can say that about Scientologists
4 and anyone else. There is no one that I know that is aching
5 to be committed to an institution.
6 Q But I'm asking you from when you were a
7 Scientologist --
8 A Uh-huh?
9 Q -- the last thing that you would have -- you would
10 have rather shot yourself than be committed to a mental
11 institution?
12 A Absolutely not. I mean, that is unreasonable. It
13 is irrational.
14 Q Well, can you think of anything worse, as a
15 Scientologist, than to be committed to a mental institution?
16 Can you just answer that question?
17 A Rehabilitation Project Force, maybe.
18 Q One of the fundamental principles of the Church
19 is -- is the Church's abhorrence with psychiatry and mental
20 health treatment. Correct?
21 A Well, you know, Mr. Weinberg --
22 Q Can you just answer that question?
23 A I used to believe that is the answer. I used to
24 believe that. But I found, from Mr. Hubbard's autopsy
25 report that I had a copy of, that he himself was taking
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
629
1 psychiatric medication --
2 MR. WEINBERG: Objection. Move to strike.
3 A -- in his life. So maybe --
4 THE COURT: Stop. There is an objection. You
5 have to stop.
6 MR. WEINBERG: It is not responsive to the
7 question. It was a very simple question. Yes or
8 no.
9 MR. DANDAR: I would say this is outside of the
10 scope of direct and the issues.
11 THE COURT: It is not outside the scope of
12 direct and not outside the scope of the issues but,
13 quite frankly, this is not helping me any.
14 MR. WEINBERG: All right.
15 THE COURT: It is an interesting banter between
16 you and Mr.~Prince and --
17 MR. WEINBERG: I'll go on.
18 THE COURT: -- this might be of interest to a
19 jury, but it really isn't of interest --
20 MR. WEINBERG: All right.
21 THE COURT: -- to me.
22 BY MR. WEINBERG:
23 Q Since you have met Bob Minton, all of the money
24 that you have received since June, other than this
25 apparently $4,000 that you just got from Mr. Dandar, that
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
630
1 you have received since June, July, of 1998, up until April
2 of 2002, came directly or indirectly from Mr. Minton, didn't
3 it?
4 A That is incorrect.
5 Q And all of the money -- all of the money that you
6 have received in that period of time you received as a
7 result of your work about or against or involving
8 Scientology?
9 A That is incorrect.
10 Q Correct?
11 A That is incorrect.
12 Q What is incorrect about that statement?
13 A I think that -- Mmm -- that all of the money that
14 I have had during those periods of time derived from those
15 activities, that is -- specifically is incorrect about it.
16 Q What, 99 percent of it? 95 percent of it?
17 A You know, I have turned over my financial records
18 to you. I think they speak for themselves.
19 Q All right. Let me play you -- because you asked
20 me to -- let me play you a video -- some videos and maybe
21 this will refresh your recollection. I'll ask you some
22 questions about it.
23 A All right.
24 MR. WEINBERG: Get the first one.
25 MR. DANDAR: We're going to object. If he
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
631
1 plays the video that they would like to play from
2 the Boston picket, I demand that they play the whole
3 video so that you, Judge, can see what Mr.~Prince
4 was responding to in that very vile video that you
5 may have already seen. You only saw their version
6 of it. There is like two, three, four minutes of
7 extremely vile language coming from ministers of the
8 Church of Scientology to bull bait Mr.~Prince into
9 responding the way he did on video. So if they are
10 going to do that, they need to play the whole thing.
11 MR. WEINBERG: That is not the one I'm playing,
12 first of all --
13 THE COURT: All right.
14 MR. WEINBERG: -- to make it easy.
15 Secondly, if he wants to do something later, he
16 can.
17 THE COURT: There is a rule of completeness
18 which we'll get into when we get to trial. At a
19 trial, if somebody will try to pick and choose, I'm
20 probably going to insist on the rule of completeness
21 in an appropriate case.
22 But in this hearing, if they play something and
23 you think I need to see it all, make a little note,
24 tell them to keep it there and play the whole thing
25 on redirect.
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
632
1 MR. DANDAR: All right.
2 THE COURT: Or ask them if they'll play it all.
3 If they say no, then you play it.
4 MR. DANDAR: All right.
5 MR. WEINBERG: Now, this is a video in front of
6 the Ft. Harrison on November 30, 1998.
7 ______________________________________
8 (WHEREUPON, the video was played.)
9 "You want to see the other side of the sign,
10 too? Just want to make sure you get all of the
11 information, all of the data.
12 "Tell David I'm coming with a dick so big, I'm
13 gonna knock his goddamn spine out cuz I'm black. I
14 got a big dick. I'm black. I got a big dick.
15 "Hey. Hey. Didn't that guy have curly hair?
16 (Inaudible.)
17 "No. No. Jesse. Yo momma. I been fucking
18 your momma a long time (inaudible). That's why you
19 got that curly hair."
20 (End of playing of the video tape.)
21 ______________________________________
22 BY MR. WEINBERG:
23 Q Do you recognize yourself, Mr.~Prince?
24 A Yes, I do.
25 Q You recognize Mr. Minton?
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
633
1 A Yes, I do.
2 Q And you thought that was funny? Your statement
3 about Mr. Miscavige?
4 A Yes, I did.
5 Q You don't consider that a threat?
6 A No, I don't.
7 Q You think it is appropriate for an expert, or
8 anybody, for that matter, but particularly an expert on --
9 supposedly on religion to be in front of the Ft. Harrison to
10 be making obscene statements about David Miscavige like that
11 to other -- to Scientologists?
12 A You know, I think there was an indiscretion that
13 happened there, certainly.
14 Q And you consider it harassment for you and
15 Mr. Prince -- and Mr. Minton and others to be holding signs
16 like the one you were holding, "Lisa, blood on her hands,"
17 and the one Mr. Minton was holding about the Third Reich, do
18 you consider that harassment to be walking in front of the
19 mecca of Scientology? Do you consider that to be
20 harassment?
21 A I consider it to be exercising my constitutional
22 right --
23 Q Okay.
24 A -- as a citizen of America.
25 MR. WEINBERG: Want to play the next one,
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
634
1 please? Actually, let me -- go ahead.
2 ______________________________________
3 (WHEREUPON, the video was played. No audio
4 available.)
5 MR. WEINBERG: This is on the same day in front
6 of the Criminal Court Complex.
7 BY MR. WEINBERG:
8 Q Now, do you remember this being the day of the
9 arraignment in the criminal case and do you remember being
10 in front of the complex with Stacy Brooks, Bob Minton, Ken
11 Dandar, Dr. Garko and yourself? Do you remember that photo?
12 A I remember that photo.
13 Q And do you recognize that as the criminal complex
14 in Clearwater?
15 A The one on 49th Street?
16 Q Yes.
17 A Yes, I do.
18 Q And who took that photo?
19 A You know, I'm not sure.
20 Q And do you think that is funny? "Scientology,
21 Hubbard Third Reich," do you think that is funny?
22 A You know, I think those people in that picture are
23 exercising their constitutional rights.
24 Q Do you think it is appropriate for the trial team
25 of Mr. Dandar, Dr. Garko and you and Ms. Brooks, along with
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
635
1 Mr. Minton, to be standing in front of a public building
2 holding signs like that?
3 MR. DANDAR: Objection.
4 BY MR. WEINBERG:
5 Q Do you think that is appropriate?
6 MR. DANDAR: Objection. Mr. Minton is not part
7 of any trial team.
8 THE COURT: He said "and Mr. Minton." So I'm
9 assuming he was excluding him.
10 MR. WEINBERG: That is what I did.
11 BY MR. WEINBERG:
12 Q Do you consider that to be appropriate behavior?
13 A I consider that unless I'm committing a crime, I'm
14 exercising my constitutional rights as an American citizen.
15 Q Do you believe that that constitutes harassment of
16 the Church of Scientology?
17 A No, I don't. I think if I was doing anything
18 illegal, Scientology would have had me arrested on the spot.
19 Q Okay.
20 THE COURT: Harassment is not illegal. I guess
21 what he's trying to ask you is, in addition to
22 exercising your First Amendment rights, did you
23 consider that that might be considered harassment?
24 THE WITNESS: You know, and I -- my answer
25 again is no. My answer is I'm exercising my
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
636
1 constitutional rights as an American citizen.
2 BY MR. WEINBERG:
3 Q You wouldn't consider that picket --
4 MR. WEINBERG: Can you put that photo back up?
5 BY MR. WEINBERG:
6 Q Somebody asked you -- I think Mr. Dandar asked you
7 whether or not he was ever on a picket.
8 THE COURT: Now, Counselor, in all fairness,
9 that is a picture, that is not a picket. What we
10 saw before --
11 MR. WEINBERG: I understand. I was asking to
12 ask him. This is a picture.
13 BY MR. WEINBERG:
14 Q My question is what was going on with these signs
15 in front of the Clearwater courthouse? What were you-all
16 doing with these signs?
17 A I think we had been picketing earlier.
18 THE COURT: Was Mr. Dandar with you when you
19 were picketing?
20 THE WITNESS: Absolutely not. Neither was
21 Mr. Garko.
22 BY MR. WEINBERG:
23 Q And whose idea was it to pose for this picture?
24 A I don't know. I don't recall. I don't remember.
25 Q I mean, no one forced you-all to do this.
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
637
1 Correct?
2 A Correct.
3 MR. WEINBERG: Go to the next one, please.
4 ______________________________________
5 (WHEREUPON, the video was played.)
6 "You work for a criminal organization. And
7 they're going to be found out. You take that and
8 put it on the camera and run it to Miscavige, your
9 leader, your guru. He's going down."
10 (End of playing of video tape.)
11 ______________________________________
12 BY MR. WEINBERG:
13 Q Now, that was right outside the Clearwater Bank
14 building where all the people go in to eat. Correct?
15 A Yes. It was.
16 Q And right down the street, as you look down the
17 street, is where the LMT offices were?
18 A That is correct.
19 Q All right. And do you consider that to be a
20 threat to Mr. Miscavige where you say he's going down?
21 A No, I do not. And I think I have to -- you know,
22 because this is just a little snippet you are showing here,
23 I think I should give the situation that was occurring.
24 On that very street that you saw me in front of
25 where the Lisa McPherson Trust is around the corner, on that
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
638
1 particular day I had gone to a shop on Cleveland to buy a
2 pack of cigarettes and go back to the office.
3 From the moment I walked out of my office, all of
4 the way up to the door of the shop I went to and all of the
5 way back, a Scientology OSA person had a camera on me like
6 this (indicating).
7 I was annoyed. If that is a crime, find me
8 guilty.
9 Q Now, was that your purpose when you say, "You're
10 going down," was your purpose to get rid of Mr. Miscavige
11 from being the chairman of the board or the ecclesiastical
12 leader of Scientology?
13 A My purpose was to express my annoyance.
14 Q And "guru," were you just being funny?
15 A Again, my purpose was to express my annoyance.
16 Q Now, was that your agenda? Strike that.
17 Was it Mr. Minton's agenda -- was part of his
18 agenda to get rid of David Miscavige?
19 A You had Mr. Minton up here --
20 Q I'm just asking you.
21 A -- Mr. Weinberg, forever, you know.
22 Q I'm asking you.
23 A He never said that to me. He never said that to
24 me.
25 THE COURT: There is an answer in the
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
639
1 courtroom. It is called "I don't know." If it
2 is --
3 A He never -- no, he never said that to me.
4 BY MR. WEINBERG:
5 Q Now, you described you, Ms. Brooks and Mr. Minton
6 as the A team, right?
7 A Correct.
8 Q And the A team got formed in the summer of 1998?
9 A I would say -- Mmm -- thereabouts.
10 Q Right. And the A team continued to be --
11 A Maybe -- wait a minute. I misspoke about that
12 because that A team business didn't come up until after --
13 after we'd worked together for a while and had done things.
14 And that concept came out -- in the summer of '98 is when I
15 first met them, so I think it would be a misrepresentation
16 to say that the A team was in the summer of '98, at least to
17 my best recollection as I sit here today.
18 Q So when was it?
19 A And I can't be sure. It was sometime later.
20 Q When you said it became the A team after you had
21 done things, what kind of things? Are you talking about
22 like -- do you mean like pickets and sending postings and
23 things like that? Are those the things that you were doing?
24 A I think more like helping people directly.
25 Q Helping people?
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
640
1 A Yes.
2 Q How was Mr. Minton helping people, by standing and
3 holding signs like that?
4 A Well, you know, I guess there is a myriad of
5 answers for that. But what I meant to say, helping people,
6 I meant helping people that had run into problems with
7 Scientology and were not able to resolve them so that they
8 can get on with their lives.
9 Q Now, where did the A team concept come from?
10 A You know, I think there used to be a television
11 program.
12 Q Are you talking about the one with Mr. T?
13 A If you let me finish. You know, the reason why I
14 can't answer that question, because when those television
15 series were going on, I was in the Sea Org and we weren't
16 allowed to watch TV. So I have a big missing section in my
17 life with serial programs and things like that.
18 So again I'll say there was some program that had
19 the A team on it. And I think Mr. Minton brought it up
20 and -- but --
21 Q And --
22 A -- but I have never seen a program called the A
23 team or anything like that.
24 Q When you said the A team yesterday, what did you
25 mean, A team? What was it that the A team was doing?
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
641
1 A The A team was myself, Bob and Stacy. And the A
2 team were helping people that needed help to resolve issues
3 with Scientology.
4 You know, just to -- to show how far at the other
5 end of the spectrums were, Mr. Minton actually thought he
6 was helping Scientology by helping these people resolve
7 issues with Scientology.
8 Q Do you remember speaking to the media about
9 bringing Mr. Miscavige down?
10 A No. I do not.
11 MR. WEINBERG: Play that next one, please.
12 ______________________________________
13 (WHEREUPON, the video was played.)
14 "It takes standing up and recognizing it for
15 what it is, a dead, arcane idea. We're dealing with
16 people who are ignorant and we're going to bring
17 them down."
18 BY MR. WEINBERG:
19 Q Do you remember that?
20 A I object to that very -- I can't object, but that
21 was an obvious edit where you sliced two things together.
22 And I think you are mischaracterizing a speech that I gave
23 for a vigil for Lisa McPherson where the press was there. I
24 was not speaking for the press. I was speaking to former
25 Scientologists.
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
642
1 Q Were you talking about bringing down Scientology?
2 Is that what you were talking about?
3 MR. DANDAR: We object and ask the whole thing
4 be played.
5 THE COURT: I think that is fair.
6 MR. WEINBERG: It was a newscast, we didn't --
7 we can play the whole newscast. It takes a minute.
8 THE COURT: I don't want the whole newscast.
9 Just whatever Mr. Prince said.
10 MR. WEINBERG: Well, that is what Mr. Prince
11 said. That is all he said is what we just played.
12 THE COURT: Well, it did look like there was a
13 definite splice.
14 MR. WEINBERG: There was. One of these
15 newscasts where the reporter said something and
16 Stacy Brooks said something and he said the first
17 thing on there, Mr. Prince, then somebody else said
18 something, then he said the last thing.
19 We took the two things Mr. Prince said and put
20 it together. But we can play the whole section.
21 THE COURT: It makes it look like he said all
22 that together, and it may not have been.
23 I think if what it is you are trying to do is
24 every time he said we're going to bring him down,
25 what is it you mean when you say that?
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
643
1 THE WITNESS: Expose -- expose what is actually
2 going on.
3 THE COURT: Okay.
4 THE WITNESS: You know, expose the fact that
5 private investigators are being used to terrorize
6 citizens because they disagree with Scientology.
7 Expose the fact that someone gave $100,000, and it
8 is Scientology's policy, if you don't use a service
9 that you paid for, they will refund it to you.
10 THE COURT: Normally, when you want to say
11 we're going to expose somebody, you don't say expose
12 somebody, you say bring them down, that kind of
13 means put them out of business. That is what I mean
14 by that. What did you mean by it?
15 THE WITNESS: I mean ending the criminal
16 activity. Ending the assault of citizens who have
17 no way to protect themselves once they get on the
18 bad side of Scientology.
19 THE COURT: When you say "We are going to bring
20 you down," this is your testimony, you did not mean
21 put the Church of Scientology out of business, do
22 away with the Church?
23 THE WITNESS: Right, in the illegal activities.
24 I never had a -- as I said, corrupt activities
25 wasn't even anything in my mind during the majority
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
644
1 of my stay in Scientology. These are things that I
2 learned about after I got to Gilman, Hot Springs,
3 and started working directly for Mr. Hubbard and
4 Mr. Miscavige. I was an ignorant, blind person to
5 it prior to that time.
6 BY MR. WEINBERG:
7 Q When you said in that newscast that I just played,
8 quote, "It takes standing up and recognizing it for what it
9 is, a dead, arcane idea," that was how you -- that -- you
10 were expressing your opinion about Scientology, that is what
11 you meant by that, isn't it?
12 A No. You have taken this out of context because I
13 don't know what "It is." You showed me a little snippet. I
14 don't know what you're talking about.
15 THE COURT: I don't, either.
16 MR. WEINBERG: I have the transcript. We'll
17 play the whole tape because we are obviously not
18 going to get done today.
19 BY MR. WEINBERG:
20 Q But -- it was a response to a question, "Today
21 they spoke out against the Church of Scientology," and then
22 they play what you said about it. But we'll play the whole
23 thing. It takes about a minute. All right.
24 You remember going on several trips to Europe with
25 Mr. Minton, correct?
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
645
1 A I think I went on a couple of trips with
2 Mr. Minton.
3 Q All right. He paid for the trips?
4 A Correct.
5 Q Who else went with you?
6 A You know, as a matter of fact, I only traveled to
7 Europe with Mr. Minton one time.
8 Q And the purpose of that trip was?
9 A To visit with his business partner, Jeff Schmidt,
10 to have a face-to-face with him to find out specifically
11 what Scientology-hired private investigator David Lee was
12 doing to try to get him to a -- do a similar thing as Bob
13 and Stacy, basically turn against Bob and provide criminal
14 information so Scientology could use it to attack Bob
15 Minton.
16 Q Now, do you remember being in Germany with
17 Mr. Minton and Ms. Brooks in or about June of 2000?
18 A I think I was in Leipzig, Germany.
19 Q And Mr. Minton paid for that trip?
20 A I think that trip was paid by the Lisa McPherson
21 Trust.
22 Q So in June of 2000 you were on the payroll of the
23 Lisa McPherson Trust at that point?
24 A Correct.
25 Q You had just gone on the payroll?
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
646
1 A You know, I can't remember.
2 Q And do you remember -- you remember being in the
3 DB lounge?
4 THE COURT: What is that?
5 A Yes.
6 THE COURT: What is a DB lounge?
7 MR. WEINBERG: It is a bar of some sort.
8 BY MR. WEINBERG:
9 Q Correct?
10 A We were at a train station in Leipzig, and there
11 was a bar called the DB Bar, which we thought was amusing
12 because DB means something very specific in Scientology, it
13 means degraded being.
14 Q And you were there with Ms. Caberta, we heard
15 about, the German government official that works against
16 Scientology, right?
17 A Correct.
18 MR. WEINBERG: I'll play this clip here. This
19 is something turned over to us by the Lisa McPherson
20 Trust.
21 ______________________________________
22 (WHEREUPON, the video was played.)
23 "Okay, so -- so, Stacy, you start. DM, this
24 drink's for you.
25 "DM, this is a special toast to you coming
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
647
1 straight from the DB Lounge in Leipzig, Germany.
2 "I'm not going to call this guy DM anymore.
3 Remember what my new name for David Miscavige is,
4 the former ecclesiastical leader of the Church of
5 Scientology.
6 "I know this is going on camera.
7 "I know, but what did I say -- (inaudible).
8 "Yes -- yes, this is -- this is a toast to
9 David Miscavige, also known as Pope David I, from
10 the DB lounge in Leipzig, Germany. Up, up, up and
11 away.
12 "Now, Ursula.
13 "Hi, Mr. Miscavige. We did a great work here
14 in Germany. And we will finish Scientology soon.
15 "This is to you, Miscavige. We are so thankful
16 that you give us reason to live. Salute.
17 "Pope David I. Cheers.
18 "Cheers.
19 "Just some DBs hanging out here.
20 "David I.
21 (Inaudible.)
22 "This is to David Miscavige in the DB Lounge in
23 Leipzig, Germany at the train station.
24 "Pope David I.
25 "Cheers, Miscavige.
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
648
1 "Rear Admiral.
2 (Inaudible.)
3 "Listen, listen, just --
4 "No, just stop here now. Now listen.
5 "We all know in Grady's deposition, when Grady
6 was deposing David Miscavige, that he went ballistic
7 over the thought of Graham --
8 "Now --
9 "-- of Graham Berry spending time --"
10 (End of playing of the video tape.)
11 ______________________________________
12 BY MR. WEINBERG:
13 Q Does that bring back memories, Mr. Prince?
14 A Yes.
15 Q And you think that is funny?
16 A Well, what I think you have is a home video of our
17 trip in Europe that was never made public -- Mmm -- to
18 anyone. And we were just having fun. Yes, I do think it
19 was funny. We were just having fun at the train station.
20 Q Does that man, Mr. Minton, look like the most
21 harassed person on the face of the earth?
22 A He does, to me.
23 Q And when Ms. Caberta, the German official who
24 has -- who flew over here and who is working against
25 Scientology, when she said, "We're going to finish
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
649
1 Scientology," she was talking about getting rid of it,
2 wasn't she?
3 A No. I think she was specifically talking about
4 Scientology isn't viewed as a religion in Germany.
5 Scientology is viewed as a political group. The reason
6 Scientology is viewed as a political group --
7 THE COURT: I don't need to know that.
8 THE WITNESS: Okay.
9 THE COURT: I don't need to know, care, what is
10 going on in Germany.
11 THE WITNESS: Okay.
12 BY MR. WEINBERG:
13 Q When you talk about the reason for living, when
14 you-all were talking about, you know, David Miscavige gives
15 us a reason to -- a reason for living -- reason to live for,
16 talking about so that you can malign him, is that what
17 you-all are talking about?
18 A No. Not at all.
19 Q And do you remember -- it was cut off at the end.
20 Do you remember that -- that at that point, Mr. --
21 Mr. Minton said something very obscene about Mr. Miscavige?
22 A I do not remember that. But, again, I'll state
23 that this was a video that we made on our trip that was a
24 private video, never made public, never put on the Internet,
25 and it is being exploited here today.
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
650
1 Q Well, it sort of gives you a different impression
2 about what you-all were about, doesn't it?
3 A Who is you-all?
4 Q Excuse me?
5 A Who are you talking about, you-all? What you-all
6 were about. What are you talking about?
7 Q You, Ms. Brooks, Mr. Minton?
8 A The --
9 Q The A team?
10 A I didn't get that impression.
11 Q Now, who took that video, this home video that
12 ended up in the LMT on this trip that was financed by the
13 LMT?
14 A I think Mr. Bunker.
15 Q So he was there, too, obviously? Was anybody else
16 on this trip? You have the A team, you have Mr. Bunker. Is
17 there anybody else on it?
18 A Not that I specifically recall.
19 Q And you-all thought the DB was kind of funny
20 because that is a Scientology term?
21 A Correct.
22 Q Now, after looking at your obscenities in front of
23 the Ft. Harrison about Mr. Miscavige, watching this toast,
24 you still think that he would be your friend? Wasn't that
25 your testimony this morning?
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
651
1 A You know, I'm talking to a camera there. The
2 answer to your question is yes, I think that if he and I sat
3 down and actually had a discussion, we would certainly find
4 friendship, would be able to communicate. I mean, isn't
5 Scientology all about helping people learn --
6 THE COURT: That didn't really answer the
7 question. You have that opinion and that is fine.
8 Then that is the answer to the question.
9 BY MR. WEINBERG:
10 Q You talk about counseling. The principal purpose
11 of the LMT, when it moved into Clearwater, was for the A
12 team and the people that were working for the A team to
13 picket and harass Scientology, wasn't it?
14 A That is incorrect beyond belief.
15 Q Okay. Now --
16 A I would like to explain that, if I could. I would
17 like to explain why the LMT came here, since you brought it
18 up, and if you would allow me to just fully answer the
19 question.
20 Q So you were involved in the --
21 THE COURT: I'm going to let him answer the
22 question. What was the purpose of the LMT that --
23 what do you believe the purpose of the LMT was?
24 THE WITNESS: The purpose of the LMT --
25 THE COURT: Fifty words or less.
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
652
1 THE WITNESS: Okay, fifty words or less, and I
2 won't talk too fast for the court reporter.
3 THE COURT: That is 25.
4 THE WITNESS: When Lisa McPherson left that
5 hotel, she had no place to go. She had a minor
6 accident, stripped off her clothes, told people that
7 she needed help. She ended up back in the Ft.
8 Harrison. Seventeen days later, she was dead.
9 The reason that Lisa McPherson came to
10 Clearwater and the reason it was there, in case
11 there was another instance where someone needed a
12 safe place to go where they could come and get help.
13 That is why we were there. And that is the only
14 reason we were there.
15 And those were the dying wishes of Fannie
16 McPherson, Lisa McPherson's mother, when she was on
17 her deathbed.
18 BY MR. WEINBERG:
19 Q So all of this picketing which happened on a
20 regular basis, correct --
21 A Incorrect.
22 Q Well, can you, like, give us an estimate of the
23 number of times you participated in a picket against the
24 Church of Scientology?
25 A Yes, I can. Let me think. Because I certainly
Kanabay Court Reporters; Serving West Central Florida
Pinellas (727)821-3320 Hillsborough (813)224-9500
Tampa Airport Marriott Deposition Suite (813)224-9500
653
1 remember the first one well enough. I think I have probably
2 been involved in maybe six or seven pickets.
3 Q So in the --
4 THE COURT: Over what periods of time,
5 Mr. Prince?
6 THE WITNESS: From 1998 to the present.
7 THE COURT: All right.
8 BY MR. WEINBERG:
9 Q So in a four-year picket --
10 THE COURT: Four-year period. Not picket.
11 BY MR. WEINBERG:
12 Q Right, I have picket on the brain. In the
13 four-year period, you say you only picketed six times?
14 A I roughly estimated six or seven times that I
15 picketed, yes.
16 Q And do you have a sense of how many times
17