721
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 6
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 10, 2002. Morning 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 Court Reporter,
Sixth Judicial Circuit of Florida.
23
24
25
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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. KENDRICK MOXON
MOXON & KOBRIN
7 1100 Cleveland Street, Suite 900
Clearwater, FL 33755
8 Attorney for Church of Scientology Flag Service
Organization.
9
10 MR. LEE FUGATE
MR. MORRIS WEINBERG, JR.
11 ZUCKERMAN, SPAEDER
101 E. Kennedy Blvd, Suite 1200
12 Tampa, FL 33602-5147
Attorney for Church of Scientology Flag Service
13 Organization.
14
MR. ERIC M. LIEBERMAN
15 RABINOWITZ, BOUDIN, STANDARD
740 Broadway at Astor Place
16 New York, NY 10003-9518
Attorney for Church of Scientology Flag Service
17 Organization.
18
MR. HOWARD ROSS
19 Battaglia, Ross, Dicus & Wein, P.A.
980 Tyrone Boulevard
20 St. Petersburg, Florida 33710
Counsel for Robert Minton.
21
22
23
24
25
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1 THE COURT: Good morning. Mr. Prince. All
2 right. Mr. Dandar, you are standing. You must want
3 something.
4 MR. DANDAR: Well, we have a proposed order
5 here. I have some responses here. I have
6 declarations of Stacy Brooks and others I want to
7 file. But let's just go with Mr. Prince.
8 THE COURT: Okay.
9 (A discussion was held off the record.)
10 THE COURT: What day is today? The 10th? I
11 was looking, what is -- how many days of hearings is
12 this?
13 THE BAILIFF: 30.
14 THE COURT: No, no. Mr. Bailiff says 30. Does
15 anybody --
16 MR. WEINBERG: Add zero to that. That is where
17 we are.
18 THE COURT: Is that where we are, 30?
19 MR. WEINBERG: I think so.
20 THE COURT: Good morning, Mr. Ross. Are you
21 designated Mr. Minton's attorney here today?
22 MR. ROSS: That is correct.
23 THE COURT: I think that probably you have been
24 advised Mr. Minton needs a lawyer in this proceeding
25 and, therefore, we welcome you. But you have no
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1 ability to object in this particular proceeding.
2 MR. ROSS: I understand, your Honor.
3 THE COURT: You understand you may hear some
4 very weird testimony as far as some strange
5 evidentiary rulings. But this is a strange hearing
6 and sort of the rules of evidence -- we're going to
7 deal with that after the hearing.
8 MR. ROSS: I understand.
9 THE COURT: Okay.
10 MR. WEINBERG: Just give me a minute, your
11 Honor.
12 THE COURT: I will. I will ask Mr. Dandar,
13 while you are doing that, did you have a chance to
14 E-Mail Mr. Henson?
15 MR. DANDAR: Yes, I did. And he E-mailed me
16 back and said, "Can you find me a lawyer, is it
17 worth it?" I said no, both questions.
18 THE COURT: Okay.
19 MR. FUGATE: Your Honor, I notified Mr. Hill's
20 secretary that Mr. Rosen would not be called. And I
21 should have an order here on the pro hac vice, if it
22 is not by the morning break, by noontime.
23 THE COURT: All right. Fine.
24 MR. LIEBERMAN: I would just like to inquire,
25 does that mean Mr. Henson is abandoning his motion?
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1 THE COURT: No, I think what that means, he
2 will not be represented. And I suspect you
3 should -- as I said, let me have time to read it. I
4 may be able to rule on your motion without any
5 argument.
6 MR. LIEBERMAN: Very good.
7 THE COURT: But, frankly, I want to still leave
8 it scheduled for hearing, because he may get
9 somebody to appear. And we'll deal with it at the
10 scheduled time. I would not assume that is an
11 abandonment.
12 MR. LIEBERMAN: All right.
13 MR. DANDAR: Right.
14 THE COURT: Okay.
15 MR. WEINBERG: All right? I'm ready.
16 THE COURT: You may proceed.
17 BY MR. WEINBERG:
18 Q Mr. Prince, you -- I think you said on your direct
19 testimony -- but let me go over it again -- you have
20 testified previously as a witness under oath in either trial
21 testimony or deposition testimony. Is that right?
22 A In this -- in this case, yes, I have.
23 Q In other cases, as well. Correct?
24 A Yes, I have.
25 Q And -- and is it your testimony that at all times
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1 in those other cases when you were under oath, that you
2 testified truthfully?
3 A Yes, it is.
4 Q Okay. Now, yesterday -- or the day before,
5 whenever it was -- you testified that you had participated
6 in the destruction of PC folders, particularly
7 Mr. Wollersheim's PC folder which he said was pulped, I
8 believe, while you were at RTC?
9 A Correct.
10 Q Now, you remember testifying as a witness in 1989
11 in the lawsuit Religious Technology versus Joseph Yanny?
12 A I do not.
13 Q You don't remember that?
14 A No, I do not.
15 THE COURT: I don't even remember hearing about
16 that case. That is a new one for me.
17 BY MR. WEINBERG:
18 Q I thought you testified, by the way, on your
19 direct, that you had been a witness in that case, in fact,
20 that while you were in Scientology, you were actually a
21 witness in that case.
22 A No. While I was in Scientology I said I was a
23 witness in the Wollersheim 4 case, specifically concerning
24 the Advancability Center, David Mayo.
25 MR. WEINBERG: Could I approach the witness,
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1 your Honor?
2 THE COURT: You may.
3 BY MR. WEINBERG:
4 Q Let me show you a transcript of your deposition
5 taken in Los Angeles, California on September 11, 1989 and
6 ask you if you can identify that transcript and identify
7 that as your testimony on that day under oath, and at the
8 end you'll see an errata sheet which I believe also has your
9 signature on it.
10 A What is this on? On September '89? Okay.
11 Then --
12 Q At the end is an errata sheet. Do you see that?
13 A Uh-huh.
14 Q And you see that you -- do you recognize your
15 signature on there dated --
16 A 12 December, '89. Yes, I do.
17 Q Obviously -- I'll leave this here because I have a
18 few questions on it. Obviously you testified as a witness
19 in 1989 and were given the opportunity to review that
20 testimony and make corrections. Correct?
21 A I don't -- Mmm -- recall that, Mr. Weinberg, but
22 since I did sign the errata sheet, I'll say okay.
23 MR. DANDAR: I would like to have a copy of
24 that, Judge. If they're going to start using it,
25 pulling things out of context, I would like to be
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1 able to review it.
2 MR. WEINBERG: Well, it's amazing I'm being
3 accused of pulling something out of context.
4 MR. DANDAR: We all do, we pull something out
5 and say, "Did you say this?"
6 THE COURT: If you are going to use a
7 deposition and he doesn't have a copy of it, he
8 ought to have a copy of it.
9 MR. WEINBERG: Do we have an extra copy of it?
10 Do we have copies of these?
11 THE COURT: I tell you what, go ahead and use
12 it and then get him a copy before Mr. Dandar --
13 Mr. Dandar, please listen if you care, maybe you
14 don't care. If you care, I'll have them provide you
15 a copy of the deposition before your redirect.
16 MR. DANDAR: Thank you.
17 THE COURT: If anything was pulled out of
18 context, you can correct it.
19 MR. DANDAR: Okay. Thank you.
20 MR. WEINBERG: Now, in addition --
21 THE COURT: You-all provide him a copy.
22 MR. WEINBERG: Yes.
23 BY MR. WEINBERG:
24 Q Now, in addition to your testimony in this
25 proceeding that you had participated in the destruction of
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1 PC folders, you also, in your August 20, 1999 affidavit,
2 that is the -- the affidavit where you made the accusation
3 about David Miscavige, in that affidavit, in Paragraph 22
4 you swore that you had participated in the destruction of
5 Wollersheim's PC folder. Correct?
6 A Correct.
7 Q Now, if you will turn, Mr. Prince -- when I get
8 the right folder here -- to Page 153 of your Yanny
9 deposition. You find Page 153?
10 A Mmm, just about. I have it here.
11 Q I want you to read Line 5, 6 and 7.
12 "Question: Were you ever involved in the
13 destruction of PC folders?
14 "Answer. No."
15 Okay. That was your sworn testimony then,
16 correct?
17 A Yes, it was.
18 Q And when you go to that errata sheet, does it say
19 anything about you making any mistakes with regard to that
20 sworn answer where you swore under oath in 1989 that you had
21 not been involved in the destruction of PC folders?
22 A Mr. -- you know, I don't recall this errata sheet,
23 to answer the question that quickly. I don't even recall
24 the errata sheet.
25 THE COURT: The real question is that was your
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1 testimony on that date, is that right?
2 THE WITNESS: Yes, this was the testimony I had
3 given on that date.
4 BY MR. WEINBERG:
5 Q And you previously testified that all your prior
6 sworn testimony was true. Correct?
7 A Correct.
8 Q So you lied here in court when you said that you
9 had participated in PC folders being destroyed?
10 A Well, you know, I have to at least look at a
11 couple pages earlier here to kind of get an idea what was
12 going on here to orient myself to 1989.
13 Q Look at a couple pages earlier.
14 THE COURT: Might I just ask, where he was
15 reading, was he testifying for plaintiff, or
16 defendant?
17 MR. WEINBERG: He was testifying for the
18 Church. For RTC.
19 A Okay.
20 BY MR. WEINBERG:
21 Q That was certainly -- you wouldn't have had a
22 recollection problem back in 1989, would you, as to what had
23 occurred a year or so or two or three before that, as
24 opposed to 2002, talking about things that supposedly
25 happened?
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1 A Mmm, Mr. Weinberg, I -- I don't think I would have
2 had a recollection problem, but maybe I would have had a
3 problem with coercion.
4 Q Let's see now --
5 A Or -- or manipulation.
6 Q Excuse me. I'm sorry. I didn't mean to
7 interrupt.
8 A Or manipulation. This was a very bad time for me.
9 This was shortly -- well, let's see, this was a couple years
10 after I had been away from any position of authority. I was
11 still being asked to -- Mmm -- participate in the courts,
12 for whatever reason, God only knows. And I was not in a
13 very good state of mind.
14 Q Well, I thought you said you were relieved
15 yesterday to leave your post at RTC and that you were in a
16 better state of mind as a result of being relieved and not
17 having to do all those things that you swore yesterday and
18 the day before that you had participated in.
19 A Certainly in that regard, Mr. Weinberg, I was
20 relieved. But I didn't have a lot of direction for my life.
21 I think I was pretty suicidal at that point. And I had
22 written about that, as well.
23 Q All right. So you started saying these things
24 about destroying PC folders after people started paying you,
25 like Mr. Minton and Mr. Leipold and through Mr. Dandar, that
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1 is when you started saying these things, not when you
2 weren't being paid.
3 A No, Mr. Weinberg, quite the contrary. I -- this
4 came out because I decided that it was no longer an
5 operating principle of mine that the greatest good is for
6 Scientology. I kind of -- you know, just kind of got away
7 from that.
8 Q So it's a principle now the greatest good for
9 Jesse Prince, whoever will put the money in your pocket,
10 that is what you'll say?
11 A No, Mr. Weinberg, the greatest good is the truth
12 and justice and equity.
13 Q All right. So what you're saying, just so I get
14 this right, you lied back in 1989?
15 A Yes -- yes. According to these documents, I lied
16 on behalf of Scientology.
17 Q All right. And you lied in -- I'll just refresh
18 your recollection about being asked about this before -- do
19 you remember giving a deposition in this case when -- when I
20 deposed you?
21 A I think you and I have been at it a time or two.
22 Q And do you remember that I asked you the questions
23 on Page -- I'll refer now to Page 465 of your deposition
24 of -- of November 17, November 18, 1999.
25 "Question: Now, when you testified -- how many
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1 times have you testified in your entire career, life?
2 "Answer: In a courtroom or deposition setting?
3 "Question: Both.
4 "Answer: Possibly five.
5 "Question: All right, and each time you
6 testified, whether in deposition or in court, you were under
7 oath, right?
8 "Answer: Correct.
9 "You raised your hand and swore to tell the truth.
10 "Answer: Correct.
11 "Question: Nothing but the truth, right?
12 "Answer: Correct.
13 "And you testified truthfully on those five
14 occasions.
15 "Answer: Correct.
16 "Question: You didn't perjure yourself.
17 "Answer: Correct.
18 "Question: So if you were asked the questions in
19 a deposition that I asked and those were your answers then
20 when you gave those answers, it is your testimony that they
21 were truthful answers, correct?
22 "Answer: Well, you know, yeah, okay. I'll say
23 yeah, okay, yeah."
24 Then later in the deposition -- do you remember
25 being asked those questions and giving those answers?
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1 A No, I do not, Mr. Weinberg.
2 Q Do you remember being asked on Page 469 of your
3 deposition two years ago, "You testified in the Yanny case
4 we've already talked about, was that deposition and trial or
5 just deposition?
6 "Answer: I believe it was just deposition. And
7 again, I was never afforded the opportunity -- well, no, I'm
8 sorry, I'll answer the direct question, I won't tell
9 stories. Yes."
10 Do you remember being asked that question and
11 giving that answer?
12 A No, Mr. Weinberg. But if it's there, then I
13 believe it.
14 Q So apparently three years ago when we took your
15 deposition you remembered the Yanny case testimony but today
16 you don't?
17 A I -- Mr. Weinberg, I think that is a bit of
18 mischaracterization to say I would have remembered the Yanny
19 testimony. You know, this document here is a couple hundred
20 pages long. I -- I don't think any of us are capable of
21 remembering a couple hundred pages of something that
22 happened ten years ago.
23 Q Is there a particular reason why, in all these
24 accusations you made against Scientology, you didn't say,
25 "And they told me to perjure myself in 1989 in the Yanny
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1 deposition"? Why didn't you do that?
2 A Well, the fact of the matter is, Mr. Weinberg,
3 again, like I -- I was damaged goods during that time. I
4 had gone through a lot of stress, a lot of -- Mmm --
5 decisions to change my life. Mmm, didn't have certain --
6 you know, a certainty on where I was going with my life. I
7 felt pretty hopeless.
8 But let's talk about the perjury here since this
9 is the subject here. What I have testified to before
10 concerning preclear folder destruction is the fact that
11 because these preclear folders of Mr. Wollersheim were being
12 asked to be produced and ultimately the whole folders were
13 turned over, the order to destroy the folders came from
14 Mr. Miscavige with Mr. Rathbun present, myself, Vicki
15 Aznaran. It became my responsibility to report when that
16 fact was done.
17 I myself was not the person that destroyed the
18 preclear folders or had -- or pulped them. Rick Aznaran is
19 the person, along with another current Office of Special
20 Affairs, Charlie Earl, rented a truck, took these folders;
21 Vicki Aznaran -- Lawrence Wollersheim, possibly Bill Franks,
22 Gerry Armstrong and others took them to the recycling plant,
23 and when Mr. Aznaran came back, he showed me a liquid bottle
24 with paper on -- with the pulp paper on the bottom.
25 So technically did I know about it? Yes.
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1 Technically did I do it? No.
2 Q Oh, I see.
3 A But I sanctioned it and I went along with it.
4 Q So perjury -- the question was: "Were you ever
5 involved in the destruction of PC folders?
6 "Answer: No."
7 That is not perjury because you have somehow
8 justified in your mind that you really weren't involved
9 because you didn't actually pull the switch? Is that what
10 you're saying?
11 A No, I'm saying that I'm not the person that
12 actually did it myself, but I knew about it. And reported
13 about it.
14 Q Is that --
15 A I didn't stop it. So, you know, the fact of the
16 matter is I won't beat around the bush with you,
17 Mr. Weinberg. Right here I was not being truthful.
18 Q Now, did somebody tell you to perjure yourself?
19 Is this something that somebody told you to do? Or you just
20 did this on your own?
21 A No, I was told to do it. Mr. Earle Cooley, who
22 was lead counsel for the Church of Scientology at the time,
23 wanted me to do it. Mr. Rathbun, who was -- was again and
24 always responsible for church legal, wanted me to do it.
25 Mmm, I was being a good Scientologist and protecting
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1 Scientology.
2 Q That is amazing. So when this started out you
3 didn't have any recollection of the Yanny deposition, you
4 don't remember having even signed the errata sheet, and now
5 you have this clear recollection that -- that Mr. Cooley, a
6 lawyer who is on the board of trustees of Boston College --
7 or Boston University, and Mr. Rathbun told you to lie? Is
8 that what you're saying now?
9 A Mr. -- Mr. Weinberg, I mean, because we are
10 talking about this, because you have presented me with
11 documentation, we've discussed it, I think I do have a mind
12 and I can have some recollection about this. And I'm just
13 telling you what happened here.
14 Mmm, there are other things that I have written
15 specifically about my relationship with Earle Cooley, and
16 because you have all of those E-Mails, I'm sure you have
17 those in evidence, too. That is not the only thing that I
18 thought was unethical that happened with Mr. Cooley,
19 irrespective of where he sits.
20 Q So the way it works is, if we can catch you at it
21 and if we can show you a video or show you some testimony
22 where you perjured yourself, then it's an indiscretion,
23 essentially, you sort of caught me. Is that the way it
24 works?
25 MR. DANDAR: Objection, argumentative.
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1 THE COURT: Sustained.
2 A Mmm --
3 BY MR. WEINBERG:
4 Q It was sustained, Mr. Prince.
5 THE COURT: You don't have to answer the
6 question.
7 BY MR. WEINBERG:
8 Q Now, you said your life was hopeless?
9 A Correct.
10 Q When was this deposition, 1989?
11 A Correct.
12 Q But having been hopeless, you stayed another three
13 years?
14 A I stayed another five years after my life was
15 pretty much hopeless. You know, I fell into the
16 hopelessness -- you know, right in 1987 when that whole
17 thing happened I was ready to leave Scientology at that
18 point. All I wanted to do was walk away. I had to escape
19 to leave because I was in the RPF, walking through the
20 desert, on and on, and I'm sure you don't want to hear that
21 story.
22 Q That story? Is that what you said? Do I want to
23 hear the story?
24 A Let's please maintain civility here, Mr. Weinberg.
25 Q All right, I asked you --
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1 A I'm trying to explain this to you. I had escaped.
2 I had helped Vicki Aznaran escape. We were being kept in
3 the RPF in a -- behind a -- Soboba Indian Reservation in the
4 most horrid conditions. All I wanted to do was walk away.
5 I had to threaten to go to the press, threaten to go to the
6 police, the same thing I suspect Lisa had to do when she
7 tried to leave, as well.
8 And ultimately because the woman that I was
9 married to, who had no idea what I had been involved in,
10 what my position really was in the Church of Scientology,
11 what my participation was, it came down to Mr. Mithoff,
12 Mr. Miscavige specifically talking to my wife and telling
13 her what a horrible person I was and that I'm blowing and
14 I'm psychotic and I'm crazy because I want to leave and this
15 kind of thing.
16 So then I was faced with even a bigger problem.
17 And my bigger problem was now am I just going to walk out of
18 Scientology and leave this person that I love, that I'm
19 married to, because she hasn't woke even up, because she
20 doesn't understand, because I haven't been with her and let
21 her know what's going on. And that is kind of a problem in
22 Scientology in and of itself because the right hand doesn't
23 know what the left hand is doing. You are not allowed to
24 talk about your case, you're not allowed to talk about
25 secret this, secret that. So we had had a breach of
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1 communication for many years.
2 But in my mind at that time I was thinking, you
3 know, I'm not going to desert another person in my life, I'm
4 not going to desert this woman for Scientology. I will sit
5 here with her until she sees what I see. And I was
6 actually, therefore, there for another five years.
7 And these are points I have written about as well.
8 I felt almost like an animal, I had no mind, no brain, no
9 will, nothing. And this is what happened to me and I went
10 and did this and it was wrong. And yeah, I did that and you
11 have pointed it out and here we are.
12 Q Now, in 1989 when you perjured yourself --
13 A Uh-huh?
14 Q -- according to your testimony now, or didn't,
15 depending upon whether you perjured yourself in this
16 hearing, you weren't on the RPF, were you, in 1989? You
17 were working in the Golden Era studio, correct?
18 A I think in 1989 I was on what is considered --
19 what is called the DPF, the Deck Project Force. The reason
20 I say that is because in 1987 when I was removed from my
21 position and I went to the RPF -- Mmm -- I think I was there
22 for -- until December of '87.
23 In December of '87 I got off the RPF, I started
24 trying to practice auditing again. I did that for some time
25 and really didn't want to do it anymore.
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1 Toward the end of '88, I believe, a security guard
2 at Golden Era Productions got kind of rough with my wife.
3 THE COURT: You know, this really doesn't
4 matter where he was. You weren't in RPF.
5 A No, I was in DPF. I wasn't in Golden Era
6 Productions, I mean, working in the studios, as you
7 suggested. I was actually on the DPF. And this is the same
8 period I did that watch with Mrs. Brooks, Terese or -- or
9 Teresita --
10 BY MR. WEINBERG:
11 Q That was in '88?
12 A That was in '88?
13 Q Yes. You say things were hopeless for you?
14 Things were hopeless for you in 1997 and 1998, as well,
15 wasn't it?
16 A I wouldn't say that.
17 Q You filed for bankruptcy and went bankrupt in
18 November of -- filed in what, May of '97, and it was
19 finalized in November of '97, correct?
20 A I believe there are documents to that effect that
21 have the correct dates.
22 Q But -- but you went bankrupt in 1997, correct?
23 A Mmm --
24 Q Yes, or no?
25 A Yes, I did. I believe that is correct.
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1 Q So you were broke in 1997?
2 A I filed for bankruptcy in 1997, but I -- I wasn't
3 able to pay my bills adequately in 1997.
4 Q And except for Mr. Minton coming like an angel
5 from heaven in June of 1998, you didn't know what you were
6 going to do?
7 A Utterly and completely false.
8 Q After Mr. Minton appeared on the scene you then
9 hooked up with Stacy Brooks, you hooked up with Dan Leipold,
10 you hooked up with Ken Dandar, and since that time this is
11 what you have been doing, getting paid to testify, write
12 affidavits and work against Scientology, correct?
13 A No, that is absolutely incorrect and it is false.
14 Q Now, let's go back to the deposition for a moment.
15 Now, you testified under oath a lot about the GO and OSA and
16 all that. Do you remember that, here in this proceeding?
17 You said you had all this knowledge about the kinds of
18 activities that had gone on. Do you remember that?
19 A No, I think you are mischaracterizing my earlier
20 testimony. I don't think that the words Guardian's Office
21 exited my lips during these proceedings. I have spoke about
22 OSA and I have -- I have presented Mr. Hubbard's eternal
23 words on -- on what intelligence is expected to do, what
24 legal is expected to do and some of what public relations is
25 supposed to do. I think that better characterizes --
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1 Q Well, let me refresh your recollection, if you
2 remember on June 18 saying, "Question, was there any
3 carryover from the Guardian's Office to OSA?
4 "Answer: Yes, there was, there was a carryover of
5 some of the staff and some of the policies.
6 Then you went on to say, "Question, was OSA still
7 Department 20 like the Guardian's Office was?
8 You said, "Yes, OSA wanted to make sure they
9 didn't make the same mistakes as the past Guardian Office
10 was. One of the mistakes was putting in writing and
11 detailing some of the operations."
12 A Yes, I did.
13 Q Do you remember that?
14 A Yes.
15 Q Now, turn to Page 149, please, of the Yanny
16 deposition.
17 A Okay.
18 Q I want you to read Line 5 through Line 16 -- Line
19 5 through Line 13 -- 16, I'm sorry.
20 A To 16?
21 Q Yes, just read it out loud.
22 MR. DANDAR: Objection, that is not the way you
23 do it.
24 THE COURT: That is true.
25 A I have read it.
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1 BY MR. WEINBERG:
2 Q I'll read it. Did you give -- were you asked
3 these questions and give these answers?
4 MR. DANDAR: Objection, that is not the way
5 you --
6 THE COURT: Yes, it is the way you do it.
7 Overruled.
8 BY MR. WEINBERG:
9 Q "You ever heard of the GO?
10 "Answer: Yes.
11 "Question: What was the GO?
12 "It was Guardian's Office.
13 "Question: And Mary Sue Hubbard was in charge of
14 that for a period of time?
15 "Answer: I have no knowledge of the Guardian's
16 Office. I was never associated or affiliated with it in any
17 way.
18 "Answer (sic): You do know that a number of
19 Guardian's Office people went to jail?
20 "Answer: I don't --"
21 Then there was objection.
22 A Okay.
23 Q Were you asked those questions and give those
24 answers?
25 A Yes, that is correct.
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1 Q And that was true or was that perjury, as well,
2 that you had no knowledge of the Guardian's Office?
3 A Well, that was true then and it is true now.
4 Prior to my association with going to Gilman Hot Springs, I
5 had -- you know -- you know, I had done protests at the
6 behest of the Guardian's Office where all Scientologists got
7 together, and I think did a demonstration of the courthouse
8 down there at a point in time on -- Hebert would -- what
9 they do is they have a thing in Scientology called a call to
10 arms --
11 Q Really, all I asked you, was that true or not and
12 you said it was true that --
13 A Okay.
14 Q Using your words, you had no percipient
15 knowledge --
16 A Well, I don't want to play --
17 Q Can I ask my question first?
18 A I told you that there was -- you know, was some
19 association with the Guardian Office, and I tried to clarify
20 that. So you know, I don't want to get into word games here
21 where you say, well, you said you never did it but suddenly
22 now you have me picketing at the behest of Scientology. I
23 mean, little activities like that, I mean, I popped out of a
24 coffin across the park doing a skit based on something
25 that --
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1 Q I understand, but you waxed eloquent about the GO
2 and how it's the same -- OSA was the same, and under oath
3 here you said you didn't know, didn't have information about
4 the GO. You didn't know anything about it.
5 A No, I think you are confused on that issue,
6 Mr. Weinberg.
7 Q Now, do you remember testifying in this proceeding
8 that -- that you were -- had responsibility for legal,
9 intelligence and PR activities of OSA? Do you remember
10 that?
11 A Yes.
12 Q Particularly intelligence activities of OSA, that
13 was your testimony?
14 THE COURT: Could you define or tell him -- I
15 don't remember, was it here in this hearing?
16 MR. WEINBERG: That is what I said. I was just
17 reading from his testimony.
18 THE COURT: Here?
19 MR. WEINBERG: Yes.
20 THE COURT: Okay.
21 BY MR. WEINBERG:
22 Q I'll read -- this is the dirty -- when I say
23 dirty, this is the --
24 THE COURT: Dirty copy, I know.
25
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1 BY MR. WEINBERG:
2 Q The dirty copy, but on my Page 71 of the dirty
3 copy, which is obviously not the actual transcript, what it
4 says is, "As I mentioned --" this is your answer -- "we used
5 to do the technology side of Scientology. Then there was a
6 separate area, areas that I also had responsibility for.
7 And those were legal, intelligence and PR activities of OSA
8 which is a separate network in Scientology."
9 That was your testimony, right?
10 A Yes. Yes.
11 Q Now, I want you to turn, if you will, Mr. Prince,
12 to Page 77, first, of your Yanny depo.
13 While you are looking for it, you were deputy
14 inspector general of RTC, correct?
15 A Correct.
16 Q And it was deputy inspector general external was
17 your actual -- DIG external, right?
18 A Right.
19 Q Did you -- if you go to the bottom of the page,
20 Line 22, were you asked this question and did you give this
21 answer.
22 "Question: Back when you were the DIG external,
23 did you have any responsibility for intelligence?
24 "Answer: Not particularly.
25 "Question: Is there a group or subgroup within
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1 Scientology organization referred to as Intel?
2 "Answer: No, not that I know of.
3 "Question: Has Intel ever been part of your job
4 description?
5 "Answer: No.
6 "Have you ever had any responsibility for Intel?
7 "Answer: No."
8 Were you asked those questions and did you give
9 those answers?
10 A Yes, I did.
11 Q And was that truthful testimony?
12 A Yes, it was. And you know, in -- inasmuch as
13 it -- that it was deceptive testimony because we've sat here
14 and we've gone over all of these Scientology issues, now
15 that says intelligence action, this, that and other thing,
16 but when the GO was gotten rid of, the section that was
17 called intelligence was no longer called intelligence; it
18 was called the information bureau. And I think if you look
19 at a current organization chart for the Office of Special
20 Affairs, you will find that it says information bureau. It
21 doesn't say intelligence bureau. But if you look at the
22 materials that the persons are trained on in the information
23 bureau, it is intelligence.
24 Q It is sort of like your testimony yesterday where
25 I asked you about the picket sign, you know, in front of
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1 Mr. Minton's house and you said you didn't own a sign?
2 A You know, I don't know about that, Mr. --
3 Q Was that truthful but deceptive testimony, or is
4 that sort of like an example of what you're talking about?
5 A I don't know about that analogy, Mr. Weinberg. I
6 think you are confused on that issue and you are mixing
7 apples and oranges. But I pretty much answered your
8 question with this.
9 Q All right. So this is truthful but -- and so what
10 is -- by the way, just so -- it's not perjury when you tell
11 the truth but you are deceptive? In your mind, that is
12 okay?
13 A Well, you know, I'm --
14 Q Just answer the question.
15 A I'm not going to draw a legal conclusions. You
16 are the trained lawyer here. I'm the trained Scientologist.
17 Q You are the trained witness.
18 A I can tell you about that. I can't tell you about
19 the lawyering so much. I can't explain the law to you. You
20 can explain that to me.
21 Q Explain to me how you are being truthful when you
22 are being deceptive?
23 A By the mere fact being deceptive, you are not
24 being totally honest. But then again, as I understand the
25 law, you are not obligated to answer but an exact question,
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1 and the exact question here was about intelligence and --
2 and again, I'll tell you, when the GO was changed, the word
3 "intelligence" was gotten rid of and the word "information"
4 was put in there; information bureau, information
5 department.
6 So if they would have said information department,
7 I could have answered these questions a little differently.
8 But I didn't say, oh, you know, well, they changed
9 intelligence to information because no person wants a
10 witness walking in just blah-blah-blah, blah-blah-blah.
11 Answer the question you are asked and that is it, okay.
12 THE COURT: Sort of like you are doing now?
13 THE WITNESS: Okay.
14 BY MR. WEINBERG:
15 Q So why did you use the word "intelligence" when
16 you testified for Mr. Dandar? I just read you the
17 testimony. "In those areas that I was responsible for,
18 legal, intelligence and PR activities of OSA," why did you
19 use the word "intelligence"?
20 A Because I was able to take the eternal words of L.
21 Ron Hubbard that had that on there and show it. I used it
22 because that is what the issue says.
23 Q And by the way, that is acceptable to you to give
24 truthful but deceptive testimony? That is acceptable to you
25 as you sit here as a so-called expert in Scientology?
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1 A It is acceptable to me to answer -- answer the
2 question that is asked.
3 Q So I have got to ask the absolutely right question
4 or you can deceive me and there is no problem here? You can
5 deceive me and the Court? And everybody else that is --
6 that is in this room?
7 A Mmm, well, you know, you can call it deception or
8 you can call it inadequate lawyering. I mean, I don't know.
9 What do you want to say about it?
10 Q Well, have you had any of those answers while you
11 have been on the stand, those truthful but deceptive
12 answers? Can you think of a couple where we just missed the
13 question a little bit?
14 A You know, Mr. Weinberg, I think I'm making a
15 valiant effort here to keep perspective and keep things in
16 perspective. And I think I have gone overboard in
17 explaining my rationale.
18 THE COURT: The question is, Mr. Prince, is
19 there any time in this hearing you have not told the
20 absolute whole truth, that is what the oath is, the
21 truth, whole truth and nothing but the truth?
22 THE WITNESS: No, there is not.
23 THE COURT: All right.
24 BY MR. WEINBERG:
25 Q Now, you testified, I think -- correct me if I'm
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1 wrong -- a number of times that -- that Mr. Miscavige was
2 deeply involved in the activities of you and Ms. Aznaran at
3 the RTC and that -- and that you and her reported to
4 Mr. Miscavige when you were there. Is that right?
5 A Mmm, partially right. I -- I don't -- don't
6 remember saying Miscavige was deeply involved with me and
7 Mrs. Aznaran in RTC. I don't remember --
8 THE COURT: He did say he reported --
9 THE WITNESS: Yes, but the other part, I --
10 BY MR. WEINBERG:
11 Q Let's make it clear because that is actually the
12 question I wanted to ask you. You said -- you testified
13 under oath you reported to David Miscavige while you were
14 DIG external at RTC?
15 A I -- ultimately, I did report to him, yes.
16 THE COURT: Frankly, I think he said he
17 reported to Vicki Aznaran.
18 MR. WEINBERG: I'm just asking him now --
19 we'll, I'll read you what he said.
20 THE COURT: You have to read him what he says
21 because I can't even remember, myself.
22 BY MR. WEINBERG:
23 Q This is actually the real transcript, Page 342,
24 lines 19 through 25. And this is in response to a question
25 from Mr. Dandar. And you say: "Answer: So you know from
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1 the --"
2 THE COURT: Read the question.
3 MR. WEINBERG: That is what I'm trying to find.
4 There was a lot of interruptions.
5 MR. DANDAR: Well, that is surprising!
6 BY MR. WEINBERG:
7 Q Mr. Prince just starts talking. There was --
8 there was dialogue about the Clearwater Police Department.
9 THE COURT: Well, let me hear what it is you
10 are wanting to read to him, then we'll see if he can
11 remember this testimony.
12 BY MR. WEINBERG:
13 Q Okay.
14 "Answer: So you know from the limited time that I
15 was there in Religious Technology Center myself, I know
16 that -- you know, there wasn't much about the Flag Service
17 Organization I didn't know about and also had
18 responsibilities for to make sure the whole thing ran
19 smoothly, and the person that I reported to was certainly
20 the -- ultimately was Mr. Miscavige."
21 That is what you said?
22 A Correct. That doesn't mean to the exclusion of
23 Mrs. Aznaran who was my direct --
24 Q No, I didn't -- wasn't suggesting that.
25 A Okay.
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1 Q Now, if you'll go to -- by the way, did you also
2 report to Marty Rathbun back then?
3 A Yes. Yes.
4 Q If you go to Page 52 of the Yanny deposition,
5 please --
6 A Was that 52, Mr. Weinberg?
7 Q Yes, 52.
8 A Okay.
9 Q Look at Line 15 through 19.
10 "Question --" were you asked these questions and
11 gave these answers under oath.
12 "Question: Back in this '84, '86 time period did
13 you ever have an occasion to report to Marty Rathbun?
14 "Answer: No.
15 "Question: Did you ever report to David
16 Miscavige?
17 "Answer: No."
18 A Right.
19 Q Were you asked those questions, did you give those
20 answers?
21 A Yes, I did.
22 Q Were those truthful answers?
23 A No, they were not.
24 Q So you perjured yourself?
25 A Correct.
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1 THE COURT: I honestly don't want you to use
2 the word "perjury." Perjury is a term of law.
3 MR. WEINBERG: Okay.
4 THE COURT: Lie would be fine.
5 MR. WEINBERG: Well, I have had judges tell me
6 not to use lie because it is inflammatory.
7 THE COURT: If that were in front of a jury,
8 that may be true, but for me in this particular
9 proceeding perjury is a term of law.
10 MR. WEINBERG: Fine.
11 THE COURT: If you say is that a lie, that
12 would be fine.
13 BY MR. WEINBERG:
14 Q Was that a lie?
15 A Yes, it was.
16 Q And did somebody instruct you to lie?
17 A Yes. Again, Mr. Earle Cooley, Mr. Rathbun.
18 Again, I'm being a good Scientologist and I'm protecting
19 Scientology.
20 Q And you're not being a good anti-Scientologist as
21 you sit on the stand in this proceeding and write affidavits
22 and stuff like that, correct?
23 A I'm sorry, I didn't understand the question.
24 Q Well, is there a code of ethics for people like
25 you that are part of the anti-Scientology movement?
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1 MR. DANDAR: I'll object to the phrase
2 "Anti-Scientology movement." I don't know if that
3 has been established anywhere.
4 THE COURT: I think you need to save that for
5 another time.
6 MR. WEINBERG: Okay.
7 BY MR. WEINBERG:
8 Q Is there a code of ethics, did you and members of
9 the A team and those people that were carrying the signs for
10 the Lisa McPherson Trust that we saw that video yesterday,
11 was there some code of ethics as to what you guys were going
12 to do when you were under oath?
13 A Mr. Weinberg, no one carried a sign for the Lisa
14 McPherson Trust. You know, you make it impossible for me to
15 answer these questions when you draw these conclusions and
16 inferences that simply are just not true.
17 Q Well --
18 THE COURT: So the question is, was there a
19 code of ethics that you and Mr. Minton and --
20 MR. WEINBERG: Ms. Brooks.
21 THE COURT: -- Ms. Brooks developed when you
22 were to testify?
23 THE WITNESS: No.
24 THE COURT: In this proceeding?
25 THE WITNESS: No. The answer to the question,
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1 your Honor, is no.
2 BY MR. WEINBERG:
3 Q Now, you have testified again today about the RPF
4 and I believe that on direct -- and I'll read you your
5 testimony if you don't remember it, but I believe that you
6 have referred to the RPF as being a concentration camp or
7 something like that, correct?
8 THE COURT: Prison camp.
9 A Prison camp.
10 MR. WEINBERG: Actually, in this transcript it
11 says concentration camp on Page 456.
12 THE COURT: I heard prison camp for sure.
13 Prison, concentration camp, I guess they're all the
14 same.
15 MR. WEINBERG: Well, actually --
16 THE COURT: They're not.
17 MR. WEINBERG: In my mind a concentration camp
18 brings images of Nazi Germany, and a prison camp,
19 you know, we have them in Florida. But --
20 MR. DANDAR: Well, Japanese had concentration
21 camps in the United States. We had --
22 MR. WEINBERG: I'm not even going there.
23 MR. DANDAR: There must be a difference.
24 THE COURT: Maybe not to this particular
25 witness. He may not -- not make a distinction.
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1 THE WITNESS: Well, actually, your Honor, I
2 think there is a distinction in that I think the
3 Rehabilitation Project Force is more akin to a
4 concentration camp in that part of the program is to
5 have not -- not only to have a mind-altering
6 experience, but to have a total revamping of the way
7 you were before.
8 THE COURT: Okay. So you refer to it as a
9 concentration camp?
10 THE WITNESS: Yes.
11 BY MR. WEINBERG:
12 Q By the way, did you lose a lot of weight when you
13 were in the RPF?
14 A Which time?
15 Q I mean, did you get meals?
16 A Which time?
17 Q You said you were in twice, I believe.
18 A Right. So you mean both times?
19 THE COURT: Either time.
20 BY MR. WEINBERG:
21 Q Either time.
22 A The first time I lost weight dramatically. I
23 think I got down to 144 pounds because we weren't allowed to
24 eat regular food, we had to eat fruit and -- and protein
25 supplement called Progest. Then we had to run around with
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1 plastic suits on our body to, quote/unquote, get the
2 impurities out. This is all we were allowed to eat is fruit
3 and Progest.
4 Q That was in the '70s?
5 A That was '77.
6 Q So then in '87 when, you know, everything came
7 down on you and you got --
8 A I lost weight there, too, yes.
9 Q Were you running around drinking protein drinks
10 and wearing sweat suits?
11 A No, not the second time.
12 Q Now, you testified that you were -- let me
13 quote -- "forcibly," quote/unquote, that is what you said
14 here, "removed from the RTC." That is what you said on the
15 stand.
16 A Yes.
17 Q Do you remember that? Now, when you said
18 forcibly, what -- what were you referring to?
19 A Well, I was referring to a couple of things.
20 Prior to assuming any position as a board member in the
21 Scientology conglomerate, the one thing that you're asked to
22 do in order to have this position is to sign an undated
23 resignation.
24 After signing an undated resignation, then you are
25 allowed to be a corporate officer, on the board of directors
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1 or -- or some such like that, you know, having to do with
2 corporate matters.
3 So I was a -- on the board of directors of the
4 Religious Technology Center. I was the treasurer. But when
5 I was graced with that position I also at that time had to
6 sign an undated resignation.
7 Again, I was woken up at I guess 5 o'clock in the
8 morning with 12 people in -- security guards wearing
9 uniforms like they're on a mission, and I was told that I
10 was removed, I was shown my undated resignation so that, you
11 know -- and this is a legal process. And apparently this is
12 a problem that they had, but I won't diverge, but this and
13 this, and I was told, "You stand up, you call me sir."
14 Miscavige wanted me to do that, and I didn't want to do it.
15 So they grabbed me and they started jumping me.
16 Q All right. That is the gun thing?
17 A Right.
18 Q The gun thing?
19 A Right. We talked about that yesterday.
20 THE COURT: Are you also talking about the fact
21 your resignation was filled in, is that what you
22 considered part of forcible removal? Or not?
23 THE WITNESS: Yes.
24 THE COURT: So when you mentioned that, that is
25 also part of your forcibly removed because it was
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1 filled in and, therefore, you were removed?
2 THE WITNESS: Yes.
3 BY MR. WEINBERG:
4 Q Now, you understood when Scientology reorganized
5 in the early '80s and created RTC and CSI and a variety of
6 other corporations, you understood that there was a
7 corporate structure then that was very clear and defined in
8 corporate documents, correct?
9 A Before --
10 Q You understood that?
11 A Before or after -- I guess -- there was a
12 corporate structure before they created RTC, CSI, all these
13 other corporations?
14 Q No, I said you understood in the early '80s, the
15 Church of Scientology reorganized with a new corporate
16 structure --
17 A Right.
18 Q -- including the RTC, CSI, which was the mother
19 church, and all the churches under them. You understood
20 that, right?
21 A Yes. Yes.
22 Q And there was a very detailed corporate structure
23 with -- with articles of incorporation and various
24 agreements that set forth clearly the corporate way in which
25 various -- Scientology would be run, correct?
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1 A Correct.
2 Q And that was the wish and desire of L. Ron
3 Hubbard, who was still alive that that happened, that there
4 be this reorganization of the church?
5 A You know, I can't say that that is true. I
6 can't --
7 THE COURT: Who would care? The idea there was
8 a corporate reorganization, surely this is going
9 somewhere.
10 MR. WEINBERG: It is going somewhere.
11 THE COURT: Get there.
12 BY MR. WEINBERG:
13 Q The RTC was composed of a board of directors.
14 Correct?
15 A That was part of it, sure.
16 Q And there were trustees?
17 A Correct.
18 Q In fact, there were trustees in every Scientology
19 corporation, correct?
20 A Well, I came to learn that in 1987. But you are
21 correct.
22 Q Well, you learned when you joined RTC that there
23 were trustees, there were three trustees?
24 A No. No. No.
25 Q Well, what you learned is that the trustees had
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1 one function, correct, and that is to -- that is to -- to
2 name or remove directors. You understood that, didn't you?
3 A No, sir.
4 Q And you were removed in 1987, along with
5 Ms. Aznaran, by the trustees of RTC, one of which was
6 Mr. Miscavige, correct?
7 A Incorrect. I was removed by one person, only one
8 person's will, on one person's authority, and that was
9 Mr. Miscavige.
10 Q Was he one of the trustees of RTC?
11 A Yes. And this got explained to me as he was doing
12 this. You know, he -- you know, and I guess I was a bit
13 naive, you know, I didn't know. I wasn't a corporate
14 person. I'm not trained, you know.
15 And he explained it to me very well. He said,
16 "Look, I am a trustee. Norman is a trustee." I think Marty
17 may have been a trustee or Steve Marlowe may have been a
18 trustee. I'm not sure. And he explained to me how it
19 worked.
20 And he said, "Here is your undated resignation and
21 you have officially resigned and this is how it works and we
22 have the authority to do that." And at that point I was
23 cognizant of how it worked.
24 Q Are you saying that for the five years that you
25 were in RTC and for the three or so that you were a board
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1 member and, you said, the number two person at RTC, you
2 didn't know that there were trustees that had the ability
3 to -- to remove you?
4 A Correct.
5 Q But you are an expert on the corporate structure
6 of Scientology?
7 A I have never said I am an expert on the corporate
8 structure of Scientology, Mr. Weinberg. I said that I am an
9 expert in the -- in the policies, bulletins and issues that
10 are Scientology. That is Scientology.
11 Q If you go to Page 16 of your deposition --
12 THE COURT: Which deposition?
13 MR. WEINBERG: I'm sorry, the Yanny deposition.
14 BY MR. WEINBERG:
15 Q The --
16 A I'm not quite there.
17 Q Okay.
18 A Okay. I'm there.
19 Q Okay, Line 4, question -- were you asked these
20 questions and did you give these answers -- and you will see
21 there is one date that is wrong, but it is wrong in the
22 transcript, and I think you -- it didn't affect the
23 question.
24 "Question -- Line 4 were you asked this question,
25 "October of '83 to March of '87 you were deputy inspector
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1 general for external affairs.
2 "Answer: That's right.
3 "Question: Was Vicki Aznaran your senior during
4 that entire course of time?
5 "Answer: Yes.
6 "Question: Were you out at Gilman Hot Springs?
7 "Answer: Gilman Hot Springs and Los Angeles.
8 "Question: What was your next position then in
9 March of '83." That would be obviously March of '87, I
10 think you understand that by your answer. And did you give
11 this answer.
12 "Answer: Then I went to the RPF for three months,
13 probably three and a half. Then I was an auditor. I was an
14 auditor at Golden Era, the same place at Gilman Hot Springs,
15 for a while.
16 "Question: For about three and a half months
17 starting in March of '83 --" but it is '87 -- "you were in
18 the RPF again?
19 "Answer: Yes."
20 Then I'll skip to Page 17. Top of the page. Line
21 3 were you asked this question and gave this answer: "What
22 were the circumstances of your transferring from RTC to
23 Golden Era Productions?
24 "Answer: Well, when I was in RTC I wanted to go
25 to the RPF because I needed more training. I needed -- I
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1 just needed more skill than I presently had. And that
2 afforded me an opportunity to do that because I could go
3 five hours a day, so I did that and also got auditing,
4 co-audited and life audited, because I audited practically
5 my whole career in Scientology. So I decided to audit for a
6 while."
7 Do you see that?
8 A Yes, I do.
9 Q Were you asked those questions, did you give those
10 answers?
11 A Yes, I did.
12 Q So that was false testimony?
13 A This was coached testimony by Mr. Earle Cooley,
14 Mr. Rathbun, for the purpose of deposition with Mr. Yanny.
15 Q So is that a definite category --
16 THE COURT: That was also false, correct?
17 THE WITNESS: Yes, yes, your Honor.
18 THE COURT: You were coached by who?
19 THE WITNESS: Mr. Earle Cooley and Mr. Marty
20 Rathbun.
21 BY MR. WEINBERG:
22 Q Now, that deposition -- you were asked questions
23 by whom in that deposition?
24 A You know, I don't know. I -- I don't know.
25 THE COURT: Take a look at the front. It
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1 should say who was representing Mr. Yanny. Did you
2 give him the front page?
3 MR. WEINBERG: I gave him the whole deposition.
4 If I could approach, I think I could show him.
5 THE COURT: Okay.
6 A Cummings & White. Is that who it was?
7 BY MR. WEINBERG:
8 Q Barry VanSickle. Do you remember Barry VanSickle?
9 A Not really.
10 Q But do you remember this was a deposition, now
11 that we refreshed your recollection, the questions were
12 being asked by Mr. Yanny's lawyer, not by Mr. Cooley, the
13 ones we went over.
14 A Okay.
15 MR. WEINBERG: Just one second, your Honor. I
16 need to move some stuff and get some other stuff.
17 BY MR. WEINBERG:
18 Q Now, going to a different subject now, Mr. Prince.
19 A Are we finished with this?
20 Q Yes, let me take that back.
21 THE COURT: Why don't you go ahead and give
22 that, then, to Mr. Dandar.
23 MR. WEINBERG: I will.
24 THE COURT: That will save you all from having
25 to copy it.
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1 MR. WEINBERG: Is this our only copy? No, we
2 have other copies.
3 MR. DANDAR: You do have another copy?
4 MR. WEINBERG: Apparently, somewhere back at
5 the ranch.
6 THE COURT: But you can go ahead and make
7 yourselves a copy and he can have that one?
8 MR. WEINBERG: Right. Right.
9 BY MR. WEINBERG:
10 Q Now, let's go back to the LMT now. And I think
11 you said a minute ago that I had some misconception of the
12 LMT and picketing. Did I hear you say that?
13 A Mmm, that is quite possible, yes.
14 THE COURT: What he said, Counselor, was that
15 you were suggesting that they were picketing on
16 behalf of LMT, and that wasn't exactly correct.
17 THE WITNESS: That is right. That's right.
18 BY MR. WEINBERG:
19 Q But the -- part of the purpose -- part of what the
20 LMT did in 1999 and 2000 was to picket various buildings of
21 the Church of Scientology?
22 A You know, Mr. Weinberg, I hear you saying that.
23 But with every video that you have shown here and you have
24 related to the LMT, there are LMT staff that have never
25 picketed, never wanted to, never would, and would not
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1 participate --
2 THE COURT: Mr. Prince, this is really simple.
3 Really the question is here, and I don't think it is
4 that difficult, one of the things that LMT did,
5 those folks who were at LMT, was to picket when they
6 thought it appropriate.
7 THE WITNESS: Yes, occasionally they would.
8 THE COURT: Exercising their rights, whatever
9 you want to call it.
10 THE WITNESS: Yes.
11 THE COURT: They would at times organize a
12 picket and go picket the Church.
13 THE WITNESS: Correct.
14 BY MR. WEINBERG:
15 Q Now, in January of 2000 you were the consultant,
16 expert, working with Ken Dandar in this case, right?
17 A Correct.
18 Q And you were also working in the Wollersheim case,
19 as well, at that time?
20 A Mmm, more than likely, yes.
21 Q And you were also vice-president at the LMT?
22 A Well, we already did LMT. You said I was at the
23 LMT. And I was working with Mr. Dandar. There are two
24 things.
25 Q I'm focusing on the time, January of --
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1 A Okay.
2 Q -- 2000, you were the expert for Mr. Dandar --
3 A Yes, I was the expert for Mr. Dandar, but I don't
4 think that I immediately assumed work at the Lisa McPherson
5 Trust. I don't think that is how it happened.
6 Q Now, I asked you yesterday about you being the big
7 boss at the LMT?
8 A Yes.
9 Q And you said no.
10 A Correct.
11 MR. WEINBERG: Could we play that video,
12 please.
13 BY MR. WEINBERG:
14 Q By the way, do you remember a situation where
15 Mr. Minton handed out parrots to various members at the LMT
16 as Christmas gifts so that -- indicating -- rather, whether
17 you are a big parrot or little parrot, squawking at
18 Scientology, do you remember that happening?
19 A I think you are referring to a newspaper -- a
20 press that Mr. Minton had -- had done and that came up --
21 THE COURT: Did he give you all parrots?
22 THE WITNESS: Yes.
23 THE COURT: Okay.
24 THE WITNESS: Little ones.
25 MR. WEINBERG: All right, could we play this?
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1 This is from the film library, January 5, 2000.
2 ______________________________________
3 (WHEREUPON, the video was played.)
4 "I have a little presentation, a little sort of
5 Christmas present for the people who are associated
6 with the Lisa McPherson Trust who have made all this
7 possible. Some of you may be aware that back in
8 December a guy named Dave -- no, Rick Barry wrote an
9 article in the Tampa Tribune about -- I think the
10 headline was 'Bob Minton, will he rouse the
11 gorilla?'
12 "Yes. Yes.
13 "But the real headline is 'Lisa McPherson
14 Trust, will they rouse the gorilla.' And in that
15 article, he referred to -- in terms of the gorilla,
16 first of all, he was talking about how this gorilla
17 came to Clearwater 25 years ago, 800-pound gorilla,
18 set himself down in the middle of Clearwater, began
19 buying influence, began buying property, and for the
20 last 25 years they have basically made themselves a
21 force in this community by buying people off one at
22 a time.
23 "And the -- the question that Mr. Barry raised
24 in this article was whether, you know, this small
25 band of parrots would be able to, you know, make a
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1 difference here in terms of changing the way that
2 this -- that this organization is perceived in this
3 community and in terms of the way this organization
4 behaves in this community.
5 "Well, I remember a good friend of mine, Mark
6 DeLarma, who you all know, said, 'You thought that
7 was a good article? He, like, called you guys
8 parrots.' I said, 'I thought it was a great
9 article.'
10 "So did I.
11 "Because it really expressed in a very vivid
12 way how the Lisa McPherson Trust was going to change
13 the way this community interacts and perceives
14 Scientology. And how Scientology will have to -- if
15 they want to be healthful here, start acting like an
16 organization that is a church if they want to be
17 called a church.
18 "So I figured that the first thing that the
19 Lisa McPherson Trust had to do is we had to set up a
20 little -- Mmm -- mascot for this organization. And
21 everybody who is part of it. So for the first --
22 the first group of -- of Christmas presents are for
23 those people who will be based here as part of the
24 organization day in and day out.
25 "And so the first of those goes -- goes to --
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1 this is my little parrot that we want to have, the
2 staff members of the Lisa McPherson Trust, and the
3 most famous staff member of all is -- is Stacy
4 Brooks.
5 "There you go.
6 "The president and chief operating -- executive
7 officer.
8 "The next one -- the next one, the same parrot,
9 you know, the same parrot, goes to Jesse Prince, the
10 boss of the whole thing. Who we all love.
11 "Thank you, Bobby.
12 "And the -- and the third -- the third of the
13 fifth parrots goes to Mark Bunker, the multimedia
14 king of the world.
15 "Sweet.
16 "Who is doing everything he can to keep a
17 straight face while this is going on.
18 "There is one for me. I want to keep that.
19 "And then when David gets here, this is for
20 David Cecere. And I have another parrot which is
21 not currently in waiting here, but that is for Kim
22 Baker when she arrives.
23 "So we've got plenty of parrots.
24 "We're not done.
25 "We're not done. You know -- you know, I mean,
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1 so I would like to make a recommendation that we
2 adopt this parrot as the mascot of the Lisa
3 McPherson Trust so that everybody knows that we are
4 going to make a lot of noise, we're going to be
5 squawking about what Scientology does in terms of
6 harming people and their abusive and deceptive
7 practices, and we're going to, as little parrots,
8 we're going to make a lot of noise and drop a lot of
9 stuff that parrots -- come out the back end and help
10 these guys learn the way to behave. Okay?
11 "So --
12 "Bravo.
13 "So now -- now -- now we have little parrots.
14 We have little parrots for all of the big people who
15 have made all this possible. And the first and most
16 important little parrot goes to Patricia because --
17 because what Patricia has done, to help everybody
18 who is down here, get themselves down here and get
19 them settled in and make them feel comfortable in
20 this -- in this whole environment, which is not an
21 easy place for -- for former Scientologists to come
22 to. You know, they have been willing to stick their
23 neck out and come down here and really make this
24 organization happen. And so Patricia has really
25 made everybody feel comfortable, she's -- she's sort
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1 of like --
2 "She chased PIs into the bathroom for me.
3 "Yes, and you -- you know -- so I -- I want
4 Patricia to have a parrot.
5 "Thank you. Thank you. Thank you very much.
6 "Ray Emmons has been teaching us all for -- and
7 a lot of people didn't listen for a long time, how
8 this organization really operates. And he did this
9 in Clearwater. He made himself known nationwide in
10 terms of his opposition to Scientology. And the
11 type of organization that they really are underneath
12 the surface. And so I want Ray to know that he's a
13 parrot, as well. You have been a parrot for a long
14 time.
15 "Okay.
16 "Let me have a kiss here, Patricia, because I
17 didn't do that. Thank you so much.
18 "The order of the parrot.
19 "The order of the parrot. This is like the
20 highest award that the Lisa McPherson Trust can
21 bestow upon somebody.
22 "Now, you know, Peter Alexander has been
23 squawking about Scientology for a long time, even
24 when he was in it, especially toward the end of the
25 time he was in it, when he was -- when he was --
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1 when he was being squawked at by Patricia -- you
2 know, rather regularly. So -- and Peter has allowed
3 Patricia particularly to devote so much time and
4 energy into helping this organization get off the
5 ground.
6 "And I just want you to know, Peter, that we're
7 totally thankful for your help and support in this
8 organization, your being on the board. And I really
9 want all of us to know that this is an incredibly
10 tight-knit little group, and got a lot of hard work
11 to do here in Clearwater. But with people like all
12 of us here and you, Peter, thank you so much for
13 doing this. And I want to present you with a little
14 parrot.
15 "Yes.
16 "Thank you, sir. Thank you.
17 "And I want to -- I want to --
18 "The order of the parrots.
19 "The order of the parrots.
20 "I want to talk to you about a theme park.
21 "Yeah. Yeah.
22 "Now, the next parrot -- the next parrot is for
23 Duncan Pierce, you know, our national coordinator.
24 Our national coordinator.
25 "Oh, my God.
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1 "Duncan has been abused by Stacy so much in the
2 last few months that he really deserves a big
3 parrot. But because he's not here on the staff in
4 the office every day, he can't get a big parrot, you
5 know, it's just not part --
6 "The big parrot --
7 "Look at Peter.
8 "It's -- you know, the problem is --
9 "Patricia? Look at Patricia.
10 "The problem is it is not in the tech. He
11 can't have a big parrot. But --
12 "The standard tech.
13 "Yeah. Yeah. But -- but Duncan has done so
14 much to get us off the ground, as well.
15 "I don't know what I would do without him.
16 "It is amazing. The thing is there are so many
17 people that have really pushed so hard to get this
18 thing going. And, you know, there is no recognition
19 for us. You know, we get abused a lot on the
20 Internet. Our demise has already been scripted by,
21 you know, anti-cult and Diane Richardson. Fine, let
22 them squawk all they want. But the real squawking
23 will be done here in Clearwater by a bunch of
24 parrots. And Duncan is one of those parrots.
25 (Inaudible.)
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1 "Then for the -- and the person who lives the
2 furtherest from Clearwater, Grady Ward, who is
3 standing right here, we have another parrot, because
4 Mr. Ward -- Mr. Ward is -- is our security expert
5 here. And already -- and already during the course
6 of this day he has learned a lot about security.
7 (Inaudible.)
8 "Yeah, don't tell me about it. But I can tell
9 you some things about Grady personally because --
10 (Inaudible.)
11 "Because one of the things that really got me
12 involved in this thing was Grady Ward. And Grady's
13 stand against Scientology, you know, back in 1995
14 or -- early '96 when he started going after them
15 directly after they sued him, he went after them as
16 his own attorney, you know. You know what they say
17 about guys who are their own attorney.
18 "It is perfectly true.
19 "And it is perfectly true. Grady will be the
20 first to tell you he had no expertise, no competence
21 whatsoever. But he -- he studied the law. He
22 studied what Scientology was doing. He -- he
23 learned so much about it. And has become a really
24 good legal man in terms of fighting Scientology.
25 And I -- you know, I -- I can't -- I can't imagine
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1 somebody having the patience to understand and go
2 through and traveling back and forth from Arcadia,
3 California, eight hours to San Francisco in his car
4 and memorizing the Rules of Civil Procedure. You
5 know, while he's going back and forth. And I mean
6 memorizing so he knows every paragraph, every
7 subparagraph, whatever. And --
8 (Inaudible.)
9 "You know, if you talk about a parrot, then
10 this guy is a parrot. And I want to give -- I want
11 to give this guy who is a shining example for many
12 people on the Internet in terms of standing up to
13 somebody who is trying to curtail free speech on the
14 Internet, I want Grady to have this parrot as a
15 symbol of our love for him and his contribution to
16 this whole battle.
17 "Thank you very much.
18 "Thank you, Grady. Thank you.
19 "And -- and now.
20 (Inaudible.)
21 "And now this other parrot, I forgot to tell
22 you. I told you this was mine. And this parrot is
23 mine because all of you gave me this parrot and I
24 really appreciate it. So --
25 "Something about Rob and why he gets a parrot,
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1 because if it weren't for him, none of us would be
2 here.
3 "Absolutely.
4 "None of us.
5 "For sure.
6 "There is nothing else to say.
7 "Bob is the big parrot.
8 "Definitely.
9 "Oh, but this is not all. Oh, some of the best
10 stuff is -- some of the best is saved for last.
11 Well, what I would like everybody --
12 "He's big with presents, you can see that.
13 "What I would like everybody to do, if you put
14 the parrots around in a little circle here, if you
15 put the parrots around in a little circle there.
16 (Inaudible.)
17 "Right, don't anybody forget -- don't anybody
18 forget -- don't anybody forget. But, you know what
19 the parrots are supposed to do, don't you? We're
20 going to get the gorilla. And I didn't want you to
21 think I forgot about that gorilla. So this gorilla
22 is going to sit right there.
23 "Whew.
24 "Don't dump on the gorilla. Come on. But --
25 but that is what this is all about here. All of us
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1 little parrots and some of us big parrots here,
2 we're going to be here and we're going to make sure
3 this gorilla behaves.
4 "We're going to educate this gorilla and --
5 "We're going to put the -- we're going to put
6 the gorilla in the cage or the jungle, wherever it
7 belongs.
8 "We're going to turn this gorilla into a
9 parrot.
10 "Yeah, this gorilla is going to be cooperating
11 with us.
12 "In any case, everybody can take their parrot
13 back now. And I'll keep the gorilla, so when we
14 have it on the desk out there, it will be --
15 "Yes, a constant reminder.
16 "Yes, as a constant reminder of what we need to
17 do."
18 BY MR. WEINBERG:
19 Q Bring back memories, Mr. Prince?
20 A Very fond memories. I'm so sorry that that place
21 doesn't exist anymore.
22 MR. DANDAR: I'll object because we just went
23 through that long video and with the -- the question
24 was -- to Mr. Prince, "Mr. Prince, were you called
25 or did you call yourself a big boss at the LMT," and
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1 that is not what that video showed. Mr. Minton
2 called Mr. Prince a boss of the whole thing. So --
3 so whatever Mr. Weinberg's question was was not
4 supported by the video.
5 THE COURT: Well, it certainly is a video that
6 he could play at some other time so he played it
7 now.
8 MR. WEINBERG: Right.
9 THE COURT: But it is true, he was not called a
10 big boss --
11 MR. WEINBERG: He was called the boss of the
12 whole thing.
13 THE COURT: But I think Mr. Minton made it
14 clear he was the big boss.
15 MR. WEINBERG: Right.
16 BY MR. WEINBERG:
17 Q Now, Mr. Prince, I asked you a lot of questions
18 about what the Lisa McPherson Trust was about. That meeting
19 there was initially the start-up meeting of the Lisa
20 McPherson Trust, wasn't it? It is essentially right at the
21 beginning?
22 A I think so. You know, I think you are right about
23 that.
24 Q Right. And Mr. Minton made it very clear what it
25 was about, squawking about Scientology. That is what the
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1 Lisa McPherson Trust was about, wasn't it?
2 A No, sir. It was about making Scientology behave.
3 I think that was also part of this video. Just to behave.
4 Be decent.
5 Q Putting the gorilla in the cage? Was that what it
6 was about?
7 A Or in the jungle, wherever it belonged.
8 Q What does that mean, "or in the jungle, wherever
9 it belonged"?
10 A Well, it means everything has its place,
11 Mr. Weinberg. And there is hardly anything sinister about
12 what we just watched here.
13 Q "We're going to make a lot of noise," that means
14 you are going to disrupt the activities of the Church of
15 Scientology in Clearwater, right?
16 A No, Mr. Weinberg. That means that we're going to
17 expose the deceptive and abusive practices of Scientology
18 and help those who have been victimized by it. That is what
19 we were talking about there.
20 Q And at that time when you got the second parrot
21 for being the boss of the whole thing, you were supposedly
22 the full-time expert for Ken Dandar, correct?
23 A I was working for Mr. Dandar as his expert. I
24 wouldn't go as far as to say full-time. I mean, even you
25 brought up the fact I was working on the Wollersheim case,
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1 as well, simultaneously.
2 Q We'll get to the -- we'll get -- I'll ask you one
3 question. From June of '99 until May of 2000 you were
4 getting $5,000 a month from Dandar & Dandar?
5 A I think the record reflects that, Mr. Weinberg.
6 Q And this was in that period of time, wasn't it,
7 this parrot thing?
8 A I believe it was.
9 Q Now, you saw this meeting and you were at a number
10 of meetings with Mr. Minton, correct, over the years? You
11 have been with him a lot?
12 A Yes, I have been with him a lot.
13 Q And in this particular meeting and others that you
14 were in, Mr. Minton was pretty outspoken, outgoing, he would
15 take over, right? He would speak his piece? He was in
16 control?
17 A No. Mr. Minton is not that way. That is the
18 biggest myth. You know, Mr. Minton has exact things that he
19 likes to do and he does them. I mean, I learned a lot from
20 him myself. You know, I have never had millions upon
21 millions of dollars myself. I have never been able to help
22 people the way he has been able to help people. He has a
23 different agenda, a different track. Unfortunately, in some
24 instances he has a very short attention span.
25 And he never, in any instance, ever wants to be
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1 the person that is the leader. I mean, he doesn't -- he
2 doesn't do that. You know, if you want to do it, great. If
3 what you want to do makes sense, great, he'll support you.
4 But he's not going to tell you how to do it.
5 Q So this was just an aberration?
6 A No, this was -- it was clear what this was.
7 Mr. Minton was showing his appreciation to persons like
8 Patricia Greenway, myself, Peter Alexander, Duncan Pierce,
9 for helping organize and make the people feel welcome at the
10 Lisa McPherson Trust and helping us be a social -- be a
11 social reform group, if nothing else, in order to ultimately
12 help Scientology.
13 Q By the way, did he look harassed? Did he look
14 like a man that was under some wave of harassment unknown to
15 mankind?
16 A Actually, he looked like a man giving a speech to
17 a group of people.
18 Q It looked like he was -- that was in the Lisa
19 McPherson Trust building, correct?
20 A Correct.
21 Q It looked like all of you, Ms. Greenway, you,
22 Mr. --
23 THE COURT: What difference does that make they
24 were having fun at the LMT? When gifts were given
25 out?
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1 MR. WEINBERG: All right. I'll go on.
2 BY MR. WEINBERG:
3 Q Let me ask you a question about Ray Emmons, the
4 guy that put the parrot on his head.
5 A I know Ray Emmons well.
6 Q Now, Mr. Emmons had been a Clearwater police
7 officer and had done an investigation of the Church of
8 Scientology in the '80s, is that right?
9 A Yes, I believe that is correct.
10 Q And Mr. Emmons has been and continues to be the
11 investigator for Ken Dandar in this case, you know that?
12 A I know that Mr. Dandar has used him to do service
13 of process or locate witnesses and things like that.
14 Q Now, what was Mr. Emmons' position at the Lisa
15 McPherson Trust?
16 A I don't think he had a position. He may have been
17 on the board of directors, which was huge and basically was
18 a friends list. But as far as an official position or
19 coming into that office on a daily basis to work or
20 accomplish a specific task, that was never anything that he
21 did.
22 MR. WEINBERG: I have a couple E-Mails -- or
23 postings I was going to put in, your Honor.
24 THE COURT: All right. I want to take a break
25 here in five minutes, so if it will take more than
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1 that, break now. If not, go ahead and do those and
2 we'll take a break.
3 MR. WEINBERG: I think we can do those in five
4 minutes. I mean, it is just identifying them.
5 THE COURT: Okay.
6 MR. WEINBERG: These are actually E-Mails, I'm
7 told. I have trouble telling the difference.
8 THE COURT: Yes, I don't know the difference,
9 either. If they're up there on the screen and
10 people can read it, to me, it's an E-Mail.
11 MR. WEINBERG: Okay, your Honor, this is 223.
12 I didn't write the number on it.
13 THE COURT: Okay, I'll do it.
14 MR. WEINBERG: And this is 224.
15 THE COURT: All right.
16 BY MR. WEINBERG:
17 Q I'm going to hand you the originals. We'll put
18 them back when we're done.
19 A Okay.
20 Q All right. If you'll look at first, Mr. Prince,
21 223.
22 A 223? Which one is 223?
23 Q That is the --
24 A Okay, I have it here.
25 Q That is the Jeff Jacobsen --
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1 THE COURT: It is the long one.
2 THE WITNESS: Yes, okay.
3 MR. WEINBERG: I'm really only referring to --
4 I -- we just received these from the Lisa McPherson
5 Trust. I have attached the whole thing, your Honor,
6 but the only page that -- that -- this is part of
7 the E-Mails that were produced.
8 THE COURT: All right.
9 MR. WEINBERG: But really what I'm focusing on
10 is the first page.
11 BY MR. WEINBERG:
12 Q Mr. Prince, you can look at it all, but I don't
13 know if the rest -- sometimes it comes off the computer
14 and --
15 THE COURT: Who is this from?
16 BY MR. WEINBERG:
17 Q If you look at this, Mr. Prince, this is from Jeff
18 Jacobsen to you and Mr. Bunker and Stacy Brooks. Who is
19 Karen Case?
20 A She used to be a person hired specifically to work
21 as public relations.
22 Q And this is dated August 2, 2000. Is that right?
23 A Well, you know, okay.
24 Q Do you see that?
25 A Yes. I do.
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1 Q And this is -- do you remember having meetings
2 about things that needed to be done at the Lisa McPherson
3 Trust?
4 MR. DANDAR: Well, Judge, I have to object.
5 This is not Mr. Prince's E-Mail so I don't know how
6 he can question him about some hearsay document
7 authored by somebody that is not here.
8 THE COURT: Well, I think he can state whether
9 or not this is accurate or not.
10 MR. WEINBERG: It is to him.
11 BY MR. WEINBERG:
12 Q You received this, right, Mr. Prince?
13 A I have no memory of this.
14 MR. DANDAR: Which one are you on?
15 MR. WEINBERG: He's copied on the E-Mail, it is
16 addressed to him.
17 THE WITNESS: I don't even know what this is.
18 BY MR. WEINBERG:
19 Q It is an E-Mail to you.
20 A Okay.
21 Q Among other people. All right?
22 A Okay.
23 Q What it says, "This is a list of things we talked
24 about, elaborated on by me."
25 Now, Mr. Jacobsen was also part of the Lisa
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1 McPherson Trust, correct?
2 A Yes, he was.
3 Q In fact, in some of those videos yesterday you saw
4 Mr. Jacobsen in it with a camera himself?
5 A No, I did not see that yesterday, but --
6 Q Oh. He did take -- he took videos from time to
7 time, didn't I?
8 A Yes.
9 Q Do you know why those videos haven't been turned
10 over, by the way, his, Mr. Jacobsen's?
11 A No, I do not. Were they asked for?
12 THE COURT: Don't ask him what he knows or
13 doesn't know about something like that.
14 MR. WEINBERG: I'll ask it a different way.
15 BY MR. WEINBERG:
16 Q Do you know where the videos that he took are?
17 A No, I do not.
18 Q Were they kept at the Lisa McPherson Trust?
19 A I don't know what he did with his personal videos.
20 Q But, anyway, this -- this -- this E-Mail talks
21 about a list of things we talked about, 1, speeches, radio
22 talk shows. 2, picket. 3, press releases. 4, press
23 conferences. 5, help with investigations by EEOC, DEB. 6,
24 the library open for public use. 7, concert November 11.
25 8, newsletter. 9, attend city council meetings,
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1 participate. 10, put up a sign for the office outside. 11,
2 ads in local newspaper. 12, support group. 13, radiofree
3 Clearwater."
4 Now, that is 13 things that the Lisa McPherson
5 Trust, I assume, prioritized to do. Not one says anything
6 about counseling, does it?
7 A You know, I think you are mischaracterizing this
8 E-Mail to somehow reflect or -- or be a staple for the
9 activities of the Lisa McPherson Trust, and what this is is
10 just simply an E-Mail of Jeff writing. I have no
11 recollection of it whatsoever and I don't even remember what
12 it relates to at this point in time.
13 I mean, I literally have had thousands of E-Mails,
14 Mr. Weinb