142 1 IN THE CIRCUIT COURT FOR PINELLAS COUNTY, FLORIDA 2 CASE NO. 00-5682-CI-11 3 4 5 DELL LIEBREICH, as Personal 6 Representative of the ESTATE OF LISA McPHERSON, 7 8 Plaintiff, 9 vs. VOLUME 2 10 CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, JANIS 11 JOHNSON, ALAIN KARTUZINSKI and DAVID HOUGHTON, D.D.S., 12 Defendants. 13 _______________________________________/ 14 15 16 PROCEEDINGS: Defendants' Omnibus Motion for Terminating Sanctions and Other Relief. 17 CONTENTS: Testimony of Nancy Many. 18 DATE: July 12, 2002. Afternoon Session. 19 PLACE: Courtroom B, Judicial Building 20 St. Petersburg, Florida. 21 BEFORE: Honorable Susan F. Schaeffer, Circuit Judge. 22 REPORTED BY: Lynne J. Ide, RMR. 23 Deputy Official Court Reporter, Sixth Judicial Circuit of Florida. 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 143 1 APPEARANCES: 2 MR. KENNAN G. DANDAR 3 DANDAR & DANDAR 5340 West Kennedy Blvd., Suite 201 4 Tampa, FL 33602 Attorney for Plaintiff. 5 MR. LUKE CHARLES LIROT 6 LUKE CHARLES LIROT, PA 112 N East Street, Street, Suite B 7 Tampa, FL 33602-4108 Attorney for Plaintiff 8 9 MR. KENDRICK MOXON MOXON & KOBRIN 10 1100 Cleveland Street, Suite 900 Clearwater, FL 33755 11 Attorney for Church of Scientology Flag Service Organization. 12 13 MR. LEE FUGATE MR. MORRIS WEINBERG, JR. 14 ZUCKERMAN, SPAEDER 101 E. Kennedy Blvd, Suite 1200 15 Tampa, FL 33602-5147 Attorney for Church of Scientology Flag Service 16 Organization. 17 MR. ERIC M. LIEBERMAN 18 RABINOWITZ, BOUDIN, STANDARD 740 Broadway at Astor Place 19 New York, NY 10003-9518 Attorney for Church of Scientology Flag Service 20 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 144 1 THE COURT: All right, continue. 2 BY MR. DANDAR: 3 Q I think we left off with talking about Bob Minton 4 and Stacy Brooks. 5 A Uh-huh. 6 Q When is the first time you talked to either one of 7 them? 8 A I don't recall. 9 Q Okay. 10 A I don't recall. I do -- I do remember -- I don't 11 recall. 12 THE COURT: Can you give us a year? 13 THE WITNESS: It would have been around the 14 time Tory Bezazian left the Church and went down 15 there. So that is just within the last two years. 16 BY MR. DANDAR: 17 Q Okay. Were you ever part of or associated with 18 the Lisa McPherson Trust? 19 A No. 20 THE COURT: Is this when the Lisa McPherson 21 Trust was up and -- 22 THE WITNESS: It was up and running, yes. 23 THE COURT: That is when you first -- 24 THE WITNESS: Yes. And Tory had been a friend 25 of mine, and neighbor, actually. And when she Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 145 1 suddenly left Scientology, that is where she went. 2 THE COURT: Then you contacted her? 3 THE WITNESS: I contacted her. I had concern 4 for her. 5 BY MR. DANDAR: 6 Q And have you and Tory -- how do you say her name? 7 A Bezazian. 8 Q Do you know how to spell that last name? 9 A B-E-Z-A-Z-I-A-N. 10 Q Okay. Are you and Tory still friends? 11 A Yeah. As far as I know. As far as I know. 12 Q Are you aware that after I announced yesterday in 13 this courtroom that -- 14 MR. WEINBERG: Objection -- 15 BY MR. DANDAR: 16 Q -- you would be called as a witness -- 17 MR. WEINBERG: "Are you aware that," and he's 18 about to make a statement. I object to the form. 19 THE COURT: That is true. That sounds leading. 20 MR. DANDAR: Okay. 21 THE COURT: Well, I don't know, "are you 22 aware," I guess she could say yes or no. 23 MR. WEINBERG: Except what he's doing, he's 24 testifying. I mean, it's -- it's -- in my opinion, 25 it's a leading question. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 146 1 THE COURT: Okay. 2 BY MR. DANDAR: 3 Q In your 20 years in Scientology, and when you were 4 in the Sea Org 10 years of that, is there a head of the Sea 5 Org? 6 A Currently? 7 Q While you were in it for 20 years, was there a 8 head of the Sea Org? 9 A Yeah. When I was in, it was L. Ron Hubbard. And 10 then it ended up being David Miscavige. And I don't think 11 there was anybody in the middle. 12 Q Okay. All right. Now, did you ever go and meet 13 with Bob Minton? 14 A Yes. I met with Bob Minton and Stacy once last 15 year. 16 Q When was this? 17 A Last year at this time of year. 18 Q Summer? 19 A Yes. 20 Q All right. In the summer of 2001, where did you 21 meet them? 22 A In Sandown, New Hampshire. 23 Q At Mr. Minton's house? 24 A Yes. At his house. 25 Q What was your reason to go there? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 147 1 A Mmm, Greg had just died. And I had contact with 2 another woman who had been -- well, actually she still 3 considered herself, even though she was quite psychotic at 4 the time, she was crazy, and I was concerned that I -- I 5 didn't know of anyone who had valid help to offer someone in 6 this state of mind, having come out of the Church of 7 Scientology where traditional psychiatry is not an option. 8 And it's not the time or place to try and talk to somebody 9 about, "Oh, yeah, come to the psychiatrist." It's not the 10 time or the place to do that. 11 And so what I was confronted with was -- Mmm -- 12 having been a survivor, having known that Lisa didn't 13 survive and now Greg didn't survive, I -- first of all, I 14 didn't understand why I survived. 15 And, second of all, I wanted to make sure that if 16 we ever, ever, ever heard of somebody else in this 17 condition, that we could give them help. 18 Q How did you -- why would you choose to see Bob 19 Minton or Stacy Brooks about that? 20 A It was not a planned event at all. I was on my 21 way to Vermont. I -- it was a lot of synchronicity and 22 serendipity. And I happened to be driving by and I didn't 23 even know if he was home. It was just, "I'm on my way to 24 Vermont" and "Are you there?" 25 We had had phone contact before that, after Greg Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 148 1 died. Stacy did not even know I had been in touch with 2 Greg, let alone that I was hysterical about this. 3 Mmm, and so we spent a few hours at his home. And 4 we -- and we communicated about this and really sat down 5 and -- and Stacy and I mostly, not much of Bob, went through 6 step by step what help did I get that Lisa McPherson and 7 Greg did not, what were the differences, what were the 8 similarities, what were the things that were the same, to 9 try and piece together some sort of help. 10 I just felt like somewhere on the Internet, 11 someplace, there had to be some -- something. 12 Q But my question is why pick them out, out of all 13 of the hundreds of other millions of people in the United 14 States? I mean, why them, Minton and Brooks? 15 A Well, I really wasn't choosing Minton. Minton -- 16 I didn't even know, up to that time, if I had ever talked to 17 him. I may have never talked to him up until that point. 18 Stacy was somebody I knew from the trust, had been 19 in touch with Greg's family. I knew -- 20 THE COURT: You mentioned the trust -- 21 THE WITNESS: The Lisa McPherson -- 22 THE COURT: You knew about the Lisa McPherson 23 Trust? 24 THE WITNESS: Yes. And I knew Greg's family 25 contacted them for help. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 149 1 THE COURT: So that is how you first got in 2 touch with them? Through the trust? 3 THE WITNESS: Through the trust. Yes. 4 BY MR. DANDAR: 5 Q And did you know that anyone from the trust had -- 6 was trying to help Greg Bashaw? 7 A No. I -- I don't know. I don't know. 8 Q All right. So -- 9 A But I did know that they had had -- that they were 10 in touch with Lori, his wife, and Jesse was out there. This 11 would have been in early July. So I did know the trust was 12 involved with that. 13 And I knew that -- like I said, I am not one to go 14 to the critics, and I have never wanted what I considered to 15 be high-profile people in my life that I did not already 16 befriend. 17 MR. WEINBERG: Your Honor, I -- I missed one 18 thing. She said somebody had been out there with 19 Greg's family. And she said who -- 20 THE COURT: Mr. Prince. I believe that is what 21 she said, is that -- 22 THE WITNESS: Yes, Mr. Prince was out there. 23 BY MR. DANDAR: 24 Q How did you find out about the Lisa McPherson 25 Trust? Was that through Tory? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 150 1 A No. It was already up when Tory went there. 2 Possibly the Internet. 3 Q Did you ever visit the Lisa McPherson Trust? 4 A No. 5 Q Did you ever engage in picketing against the 6 Church of Scientology? 7 A No. 8 Q Okay. And did Ms. Brooks offer you any -- any 9 help for this woman you were concerned about? 10 A At that particular moment when I was there, I -- I 11 kind of thought she was doing better at that time. But we 12 did come to some agreement on -- that she would search and I 13 would search, and if I found something, I would let her know 14 and vice versa. 15 And we also did come to the conclusion that it 16 could not be mainstream psychiatry, that it just would -- 17 there would have to be something outside of what is 18 considered mainstream. 19 Q Okay. After that, did you have any other 20 conversations with Mr. Minton? 21 A A couple of times, on the phone. 22 Q Okay. 23 A Never -- that was the only in-person meeting. 24 Q What did you talk about with Mr. Minton on the 25 phone? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 151 1 A Mmm, I had -- 2 MR. WEINBERG: Your Honor, I just want to pose 3 an objection, hearsay. I mean, conversations with 4 Mr. Minton -- 5 THE COURT: What did she discuss with 6 Mr. Minton? 7 MR. WEINBERG: Yeah. What did -- well, what he 8 asked is what was the -- the discussions with 9 Mr. Minton. I mean, it cannot have anything to do 10 with this hearing. 11 MR. DANDAR: Don't be so surprised. Let me go 12 down there, and then you can rule after you hear 13 what she has to say. 14 MR. WEINBERG: It is still hearsay. 15 MR. DANDAR: He's their witness so -- 16 MR. WEINBERG: He's somebody that -- 17 THE COURT: Sit down. 18 BY MR. DANDAR: 19 Q So tell us about the next time -- 20 THE COURT: I'm going to assume the 21 relevance -- or the reason why it is admissible to 22 this hearing is some sort of impeachment or -- 23 MR. WEINBERG: But this would be hearsay. 24 And -- 25 THE COURT: If it is impeachment, then it is Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 152 1 impeachment. 2 MR. WEINBERG: He didn't ask Mr. Minton about 3 this, about conversations with this woman, because I 4 never -- 5 THE COURT: It could be something very 6 different from what Mr. Minton said in court. I 7 don't know, I think we'll just have to hear it 8 first. 9 MR. WEINBERG: All right. Can I preserve my 10 objection to -- 11 THE COURT: You may. 12 MR. WEINBERG: -- to hearsay? 13 THE COURT: Yes. 14 BY MR. DANDAR: 15 Q What was the first conversation about? 16 A Well, like I said, it might have been when I met 17 them there. Over that course of that year, as I did find 18 help for that girl -- alternative forms of therapy that are 19 very -- it's not that they never use psychiatric drugs, but 20 they try not to. They are a holistic approach to 21 psychiatric problems. 22 And when I got back to Los Angeles, this girl was 23 not doing well. And the day she was going to the railroad 24 tracks, while she was still talking to her FSO, I had her 25 come to my house. And I -- Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 153 1 THE COURT: I think this has to do with some 2 conversation with Mr. -- Mr. Minton? 3 MR. DANDAR: Right. 4 A So then she got better. 5 BY MR. DANDAR: 6 Q The conversation with Mr. Minton -- 7 A Okay. So this woman got better. During this 8 year, there were some conversations. I cannot say 9 specifically that Bob Minton was in on them or it was Stacy, 10 but that was the phone number that I would call every once 11 in a while. And -- 12 MR. WEINBERG: I'm sorry to interrupt, could we 13 just date the year she's talking about? 14 THE WITNESS: This past year. 15 BY MR. DANDAR: 16 Q 2001? 17 MR. WEINBERG: 2002. 18 THE WITNESS: 2001 and 2002. 19 MR. WEINBERG: Okay. 20 BY MR. DANDAR: 21 Q But it was about this woman? 22 A Mainly. Mainly. They were in touch with her, I 23 believe, Stacy. I know Jesse was in touch with her 24 repeatedly. 25 Q Okay. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 154 1 A She required a lot of hand-holding. 2 Q All right. And she was still a Scientologist. 3 Correct? 4 A Well, it took a while. I wouldn't call her that 5 now. 6 Q Then? 7 A I don't know -- 8 Q All right. 9 A I don't know what time she stopped being one. I 10 can't say that. 11 Q Let's go to this year. Did you have a 12 conversation on the telephone with Bob Minton? 13 A Yes, I did. 14 Q All right. Approximately when was it? 15 A Mmm, between April 6 and April 13, either 16 April 6 -- no, no, no, March, February -- March 6 or 12. In 17 that week or either of those two days, I can't remember 18 exactly. 19 Q Okay. Who called whom? 20 A I called for Stacy. But he was there and she was 21 not. 22 THE COURT: Between April 6 and the 12? 23 THE WITNESS: Either April 6 or 12. 24 MR. WEINBERG: I thought she said March. 25 MR. DANDAR: She corrected it to March. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 155 1 THE WITNESS: No -- yes, March. Not April. 2 March. 3 THE COURT: March? 4 BY MR. DANDAR: 5 Q Okay. So between March 6 and March 12 of 2002 -- 6 THE COURT: I think what she's saying, March 6 7 or March 12. 8 THE WITNESS: Or March 12. I'm pretty sure it 9 was March 12 but I can't -- 10 BY MR. DANDAR: 11 Q Thank you. 12 A -- can't say specifically. But it was not sooner 13 than the 6th and not really after the 12th. 14 Q Okay. What was the conversation about? 15 A Mmm, I was a bit upset because I had put a posting 16 on the Internet, which I hardly ever do. And I had -- 17 because this girl was doing better, she was stable -- Mmm -- 18 my story of what had happened to me under an assumed name 19 was already out on the Internet. 20 And what I did was I did a posting to the Internet 21 that updated my story and added that now there is some help 22 for anyone else who reads the story or family member. And I 23 created -- to maintain my anonymity, I created a new screen 24 address just for that -- any of those kind of 25 communications. And I posted that to the Internet. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 156 1 And -- Mmm -- then I got some -- I was followed 2 around L.A. and someone placed PI cards on my car. 3 And this concerned me. And -- and after, I really 4 got paranoid and stayed in the house for four or five days. 5 Then I decided to call Stacy and see if there was 6 something about Greg Bashaw or about Laura Bashaw that maybe 7 I didn't know, that putting this on the Internet created 8 some sort of repercussion, or was there something going on 9 with the Lisa case I didn't know. I mean, you know, in 10 other words, what does this mean? 11 Q Okay. 12 A And he said to me -- 13 Q He meaning? 14 A Bob Minton said to me that Ken Dandar had just 15 been there, the Lisa case is going well, he had just been 16 there two weeks before -- 17 THE COURT: Been there? 18 A Been to Sandown, New Hampshire, to his place in 19 Sandown, New Hampshire; that the trial date was set for 20 early June; and they, meaning the Scientologists, were going 21 nuts and would stop at nothing to prevent that trial from 22 happening. 23 And he said that it was -- that he was in 24 negotiations with the Church, settlement negotiations, and 25 that that also was going well, but the sticking point had Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 157 1 been that no more money was to go to Ken Dandar. 2 BY MR. DANDAR: 3 Q From the Church -- the Church was saying this to 4 him? 5 A The Church was saying this to him, that we could 6 settle but no more money to Ken. 7 Q Any other part of that conversation? 8 A And that was a sticking point which made me feel 9 that at that point this was not something that he was going 10 to do. 11 Q Okay. Is that the end of the conversation? Or is 12 there any more? 13 A That was the end of that conversation. 14 Q Did you have any more conversations with him? 15 A Mmm, one. 16 Q When was this? 17 A I think one. 18 Q When was this? 19 A A couple weeks ago. 20 Q What was that about? 21 A I called him to remind him and Stacy that the 22 anniversary of Greg's death was coming and Laura would 23 appreciate a card or phone call, I was sure. 24 Q Okay. And Mr. Minton said? 25 A "Thanks." And, "Do you remember exactly what the Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 158 1 date was?" 2 I mean, I didn't get into any of this. I did not 3 get into this. 4 Q And even at that time had you decided to come here 5 and be a witness? 6 A Absolutely not. 7 MR. DANDAR: That is all I have. 8 THE COURT: You may inquire. 9 Frankly, I think for the purpose of this 10 hearing, that whatever that auditing session was 11 would not be relevant. 12 MR. WEINBERG: Okay. 13 THE COURT: So as far as I'm concerned, you 14 know, you can go forward, unless you just want to, 15 it is out there, but I don't think it is relevant. 16 MR. WEINBERG: Just give me a moment. 17 THE COURT: That doesn't mean it wasn't 18 relevant to you. 19 THE WITNESS: I understand. 20 THE COURT: It means it has no relevance to 21 what is going on here and now. Okay? 22 THE WITNESS: Okay. 23 CROSS-EXAMINATION 24 BY MR. WEINBERG: 25 Q Now, you just said that you remembered pretty Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 159 1 clearly that you had had a conversation with Mr. Minton on 2 March 12, correct? It could have been March 6 but probably 3 March 12? 4 A Correct. 5 Q And what makes it clear in your mind, by the way, 6 as to the date March 12? 7 A It was where I was when I made the call; I was at 8 a particular place that I don't go very often. 9 Q All right. Now, in that conversation where 10 Mr. Minton said that what the Church wanted was for him not 11 to pay any more money to Mr. Dandar, did he tell you that a 12 few days before he had sent Mr. Dandar $250,000? 13 A Nope. 14 Q He didn't sound distressed in that phone call, did 15 he? 16 A I wouldn't -- per my definition of distress, no. 17 Q He said the case was going really well. Right? 18 A He -- no. The case was moving. He didn't say 19 going really well. It was moving okay. It had a trial 20 date. 21 Q Now -- and he didn't tell you that he was going to 22 cut off Ken Dandar from money, did he? 23 A No. 24 Q Now, you said that there might be -- I think that 25 earlier in your testimony you said something to the effect Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 160 1 that there might be times when -- when -- I think this was 2 in response to a question Judge Schaeffer posed to you, that 3 there might be times in your mind when you might have lied 4 to protect the Church? 5 A Uh-huh. 6 Q Might have thought about lying to protect the 7 Church. 8 Now, you were never in a position -- 9 THE COURT: Excuse me. Excuse me. You have to 10 say yes or -- 11 THE WITNESS: Oh, I'm sorry. Yes. Was that 12 yes? 13 BY MR. WEINBERG: 14 Q You never did perjure yourself for the Church of 15 Scientology, did you? 16 THE COURT: If she knows what that word means. 17 THE WITNESS: I know what that means. That 18 means lying under oath. 19 THE COURT: It really means a lot more than 20 that. But for this hearing, we'll assume that is 21 what it means. Okay. 22 A No, because that is the only thing I ever said 23 under oath. 24 BY MR. WEINBERG: 25 Q Now, you -- this view that you have that there Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 161 1 might be times you could lie or not tell the truth to 2 protect the Church is your opinion, right? That is your 3 opinion? 4 A What do you mean? That -- 5 THE COURT: Your opinion, as opposed to 6 somebody else's opinion? 7 BY MR. WEINBERG: 8 Q Do you understand, you are just expressing your 9 opinion? 10 A Oh, okay. 11 THE COURT: In other words, is it part of a 12 policy letter, or is it just your opinion as to -- 13 THE WITNESS: I would definitely, as a member 14 of that group -- felt to protect that group at all 15 costs, I definitely felt that, and I felt that was 16 required of other members. 17 BY MR. WEINBERG: 18 Q Well, you can imagine that there -- there may well 19 be people in the Church of Scientology who might just 20 utterly disagree -- 21 A Uh-huh. 22 Q -- with the opinion that you just expressed. 23 Right? 24 THE COURT: Is that a yes? 25 A I really don't know how to answer that. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 162 1 THE COURT: I thought I heard you say "uh-huh," 2 and that is what I'm saying, you can't -- you can't 3 say uh-huh because -- 4 THE WITNESS: Okay. Okay. Could you repeat 5 that? That people would not agree -- 6 BY MR. WEINBERG: 7 Q I mean, you can imagine that there are people -- 8 there are thousands of people -- millions of people that are 9 in Scientology. Correct? 10 A Right. 11 Q And you can imagine that some of those -- a number 12 of those millions of people would -- would bitterly disagree 13 with your -- with your opinion that it's appropriate to 14 perjure themselves, lie under oath to protect -- 15 A I have never said it was appropriate to perjure 16 yourself or to -- perjury, I think, is different than an 17 acceptable truth or keeping a PR flap under control or not 18 letting the public know certain things. 19 Q So -- 20 A I think that is different. 21 Q So you are not saying it is a tenet -- you are not 22 saying any more than it is a tenet of the Catholic Church 23 that it is a tenet of the Church of Scientology that its 24 members lie under oath? You are not suggesting that, are 25 you? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 163 1 A Absolutely -- 2 MR. DANDAR: Objection. My question about this 3 was referenced only to RTC and OSA. 4 THE COURT: Overruled. But I do think this 5 needs to be her opinion, just as the other opinion 6 was hers. 7 MR. WEINBERG: That is what it is. 8 BY MR. WEINBERG: 9 Q Right? 10 THE COURT: I think what you are saying, you 11 are making a distinction between lying under oath 12 and lying otherwise? 13 THE WITNESS: Exactly. 14 THE COURT: You are not suggesting that there 15 is -- when he says -- 16 THE WITNESS: Concerted effort to get people to 17 lie under oath? No, I'm not. 18 BY MR. WEINBERG: 19 Q Now, when you were in the Church -- and I can use 20 the word "squirrel" now because it has been explained -- 21 working with regards to squirrels, you were aware, were you 22 not, that the Church and people in the Church like you felt 23 that they had been subjected to a great deal of unwarranted 24 attacks by these squirrels. Right? 25 A I -- no. No. No. I mean, it wasn't unwarranted Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 164 1 attacks by these squirrels. 2 Q So you thought they were warranted, that it was 3 okay for the squirrels to steal or alter the technology of 4 Scientology? You thought that was appropriate? 5 THE COURT: That is a different thing than -- 6 than attack. 7 THE WITNESS: Exactly. 8 BY MR. WEINBERG: 9 Q Well, didn't some of these groups slander, say 10 very negative things, about the Church of Scientology? 11 A People can have opinions about everything. 12 Q No, I understand that. I'm just asking you, when 13 you were in the Church -- 14 A Right? 15 Q -- you were not happy about what squirrels were 16 doing to your church, were you? 17 A It wasn't a matter of squirrels doing to my 18 church. It was a matter of what people were doing to 19 people. And these people, both sides, weren't being 20 respectful or treating people decently, and they were both 21 trying to get away with things. 22 Q When you were in the Church, back in the '80s when 23 you were working with regard to the squirrels, you were 24 aware that the Church -- people in the Church felt that 25 these squirrels, when they were put under oath in cases Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 165 1 involving Scientology, were lying? That is what people in 2 the Church believed? 3 MR. DANDAR: Objection as to what people in the 4 Church believed. Now I think he's trying to make 5 her an expert witness. If he wants to go there, 6 then, of course, we'll redirect her on expert 7 witness opinions. 8 THE COURT: Ask her what she believed. 9 BY MR. WEINBERG: 10 Q That is what you believed, didn't you? When you 11 were there, that -- 12 THE COURT: Let me ex- -- 13 A I know that some people -- 14 THE COURT: Wait. Stop. 15 THE WITNESS: I'm sorry. 16 THE COURT: Let me explain something to you. I 17 get the distinct impression you think somehow or 18 another he's here to trick you or to somehow or 19 another -- he's the enemy or something. 20 THE WITNESS: Put words in my mouth. 21 THE COURT: Put words in your mouth. Don't 22 assume that. If he's out of line, I'll tell you. A 23 lot of times, he's just trying to gain information, 24 just like the other side is. 25 THE WITNESS: Okay. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 166 1 THE COURT: In other words, you can answer his 2 question, "No, I don't think that is right," or, 3 "Yes I do." 4 THE WITNESS: Yes. 5 THE COURT: Sometimes the right answer is yes. 6 Sometimes it may be no. 7 THE WITNESS: All right. 8 THE COURT: Sometimes an answer can be "I don't 9 know." But you must not assume -- 10 THE WITNESS: That that is the case? 11 THE COURT: -- that this guy is here to try to 12 harm you, hurt you, make you lie or -- or confuse 13 you. 14 THE WITNESS: Okay. 15 THE COURT: That is not necessarily true. 16 THE WITNESS: Okay. 17 THE COURT: I'm here if that happens. 18 THE WITNESS: Okay. 19 MR. WEINBERG: Thank you. 20 THE COURT: Go ahead. 21 A So, yes, I do know that, that critics did 22 sometimes lie. And I know that for a fact. 23 THE COURT: And, obviously, when you were 24 working undercover, because -- because of a squirrel 25 group, you must have thought there was something Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 167 1 going on there you needed to report back because 2 there was some harm coming to the Church? 3 THE WITNESS: Exactly. 4 THE COURT: Maybe not an attack -- 5 THE WITNESS: Exactly. 6 MR. WEINBERG: I probably used the wrong word. 7 BY MR. WEINBERG: 8 Q The point is, is that this man, David Mayo and his 9 group, the Advanced -- what was it called -- 10 A Abilities -- 11 Q The Advanced Abilities Center, AAC -- 12 A Right. 13 Q -- were using stolen materials, upper-level 14 materials of Scientology. Correct? 15 A Which were copyrighted. 16 Q Right, which were copyrighted? 17 A Uh-huh. 18 Q And what you were doing and the Church was doing 19 was trying to protect itself and protect its copyrighted 20 materials that had been stolen. Right? 21 A Uh-huh. Exactly. 22 THE COURT: And both of those uh-huhs were yes? 23 THE WITNESS: Yes. I'm sorry. Yes. 24 THE COURT: Okay. 25 Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 168 1 BY MR. WEINBERG: 2 Q Now, you obviously cannot recall exactly what 3 occurred during those times that you were -- how can I put 4 it -- out of your mind or -- 5 A Crazy. 6 Q -- crazy. Is that okay? 7 A Uh-huh. 8 Q You obviously can't recall with any clarity what 9 was going on when you were crazy. Right? 10 A Uh-huh. 11 THE COURT: That is yes? 12 A There are bits of clarity -- I'm sorry, there are 13 bits of clarity in the midst of -- 14 BY MR. WEINBERG: 15 Q A lot of confusion? 16 A Exactly. 17 Q And that is part of the problem when one has a 18 psychotic break, whether it is being delusional or 19 hallucinations, things seem real that aren't real and vice 20 versa. Correct? 21 A Exactly. 22 Q All right. So when you were describing what 23 occurred when you were -- I don't really like the word 24 "crazy" -- but when you were crazy -- 25 A Disabled. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 169 1 Q -- whatever. When you were psychotic -- 2 A Okay. 3 Q -- whatever you said today for the most part 4 you -- it is recounted from, what, conversations with your 5 husband and other people -- 6 A No. 7 Q -- telling you what occurred? 8 A No. 9 Q All right. So -- 10 THE COURT: Some of her conversations came, she 11 believes, from phone calls where she called -- you 12 remember the phone calls? 13 THE WITNESS: Exactly. I do remember those 14 phone calls. 15 BY MR. WEINBERG: 16 Q Now, during this period of confusion, you saw 17 aliens or believed that people were aliens and stuff like 18 that? 19 A Just the OSA people. 20 Q Okay. And -- but -- and this period of confusion 21 lasted -- do you have a sense of how long it lasted? I 22 mean, is it months? 23 A There is gradient scales. And what I'm saying is 24 at the point I stopped with the vitamins is the point it 25 started to get better. But there are some areas by June I Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 170 1 had -- for the most part, I was like okay, I was still very 2 shaky but I was here. 3 THE COURT: How long was the period before 4 March? I remember in March you said there was this 5 period where you stopped taking the drugs or 6 medicines. 7 THE WITNESS: Several weeks. 8 THE COURT: What was -- 9 THE WITNESS: Several weeks worse, several 10 weeks better. It went several weeks worse, then 11 several weeks better. 12 THE COURT: So it was at least a couple of 13 weeks or more where you were in this very confused 14 psychotic state? 15 THE WITNESS: Yes. Yeah. Toward that bottom 16 point that -- that point of their graph. 17 BY MR. WEINBERG: 18 Q And then now, from time to time, you still get 19 confused at times? 20 A No. I don't get confused. 21 Q Well, how does -- you said that -- 22 A That I still have effects of it? 23 Q Yes, that you are not well, I think you said? 24 A I didn't say I wasn't well. I just said that the 25 effects of it I will have. I have got to keep myself in Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 171 1 balance and -- everybody has to take care of their mind. 2 Whether you know it or not, you can't lose your mind. And 3 that is what I really have to do, which is not more or less 4 than other people. 5 Q And the effects of it manifest itself in your -- 6 the effects of it manifest itself from time to time in your 7 ability to remember things and -- can you give us an idea? 8 A It's not my ability to remember things. It's my 9 ability to feel here in this universe. 10 THE COURT: Feel like emotions? Feeling 11 emotions? Or feel like a physical -- 12 THE WITNESS: Stability. Stability and not 13 like a balloon going to float away. 14 BY MR. WEINBERG: 15 Q So sometimes you might feel like you are losing 16 that touch with reality, is that what you're saying? 17 A Mmm, yeah. Yeah. I bump into that every now and 18 again. 19 Q Now, are you being treated by a psychiatrist or a 20 physician for this condition that you have described? 21 A No. 22 Q Are you being medicated in some way for this 23 condition? 24 A No. 25 Q So you are not receiving any counseling for -- Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 172 1 A I -- 2 Q Let me finish my question. Okay? 3 A I'm sorry. 4 Q So you are not receiving any counseling or 5 treatment of any kind to address this continuing -- 6 A Yes. 7 Q -- lack of stability? 8 A Yes. Yes, I am. 9 Q What is that? 10 A I have different people that I go to for different 11 kinds of support. 12 Q Well, I don't care about the names but -- 13 THE COURT: Is that this holistic group you 14 found? 15 THE WITNESS: No, because they are not local to 16 where I live. 17 I will never go into therapy as people say go 18 into therapy when you go and you have a therapist. 19 I do have different therapists I have been to that 20 if I feel the need, I will go to on a -- on an 21 as-needed basis, not like on a regular basis. 22 But I also have spiritual advisors that I have 23 gone to, as well, for help and therapy. 24 BY MR. WEINBERG: 25 Q Well, without -- well, let's take those one at a Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 173 1 time. You will never go into therapy? Is that because from 2 your 20 years of being a Scientologist, that you are opposed 3 to the concept of psychoanalysis or psychiatry? 4 A I'm opposed to the concept of traditional 5 psychiatry, for not having anything to do -- before not 6 having anything to do with Scientology -- it was a feeling I 7 had before I became a member, and it is a feeling I continue 8 to hold. 9 That does not mean I'm against holistic 10 psychotherapy or even psychotropic drugs. I will never go 11 into a -- into a therapy situation because I feel, myself, 12 and I feel most people, need to listen to themselves as 13 their primary guide and not another person. 14 And if I had done that, I would not have continued 15 in that environment that I didn't feel was healthy to me 16 that then ended up me losing my mind. So I'll never put 17 myself in that position again. 18 Q How many -- now, a Scientologist -- a 19 Scientologist would be opposed to being treated by a 20 psychiatrist or being in a mental hospital getting 21 psychiatric treatment, is that correct? 22 A Some might. 23 Q Some might? 24 A Uh-huh. 25 Q That is one of the fundamental precepts of Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 174 1 Scientology -- 2 A I wouldn't -- 3 Q I need to be able to -- 4 A I'm sorry. 5 Q -- finish my question. 6 One of the fundamental precepts of Scientology, is 7 it not, is an aversion to psychiatry? 8 A I never considered it fundamental. I did consider 9 it to be something that -- Mmm -- grew. 10 Q What do you mean, something that grew? 11 A I want to -- I remember a tape by LRH where he 12 talked about this, but I don't think we want to go there. 13 THE COURT: Basically, all of the testimony 14 that has been presented in court is the Church of 15 Scientology does not believe in the traditional 16 psychiatrists, psychologists, psychotropic drugs, 17 that type of thing. 18 THE WITNESS: That is the official position. 19 THE COURT: The official position? 20 THE WITNESS: That does not mean all your 21 members -- like I could be -- I don't think that all 22 your members -- well, maybe they do. Maybe they do. 23 BY MR. WEINBERG: 24 Q Well, I mean, the fact is that Scientologists can 25 choose to believe whatever they want to believe. Correct? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 175 1 A With restrictions. 2 Q Now, how many different spiritual advisors do you 3 have? 4 A With regard to this particular issue, really one. 5 Q Well, are there other issues that you have that 6 you have to go to spiritual advisors for? 7 A No. But I just wanted to clarify that is what we 8 were talking about. 9 Q I thought you told the judge -- and I might have 10 misunderstood you -- that you saw more than -- you have seen 11 more than one what you described as a spiritual advisor. 12 A Mmm, oh, yeah, there were two. Okay, two. 13 Q And do they have -- can you -- can you tell us 14 what are they? 15 A Nuns. 16 Q So this is in a Catholic church? 17 A They are in the Catholic church. They are nuns in 18 the Catholic church. 19 Q You know there are nuns in the Buddhist -- 20 A These are in a Catholic church. 21 Q They are not Scientologists or ex-Scientologists? 22 A No. 23 Q Have you received any counseling from any people 24 that were former Scientologists? 25 A No. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 176 1 Q Now, and I apologize if I asked you this question 2 and I assume -- I don't think I did -- but I assume that 3 from your answer what the answer is, you never did go to a 4 psychiatrist or got psychiatric treatment, is that right? 5 A Psychiatrist or psychiatric treatment? 6 THE COURT: He wants to know, to recover -- 7 THE WITNESS: Yes? 8 THE COURT: -- if you ever went to see a 9 psychiatrist. 10 THE WITNESS: No. 11 BY MR. WEINBERG: 12 Q And you were not put in a mental hospital? 13 A No. 14 Q In fact, on the first day of your break, you were, 15 I guess, in restraints, taken to, what, the psychiatric wing 16 of a hospital? 17 A They wanted to admit me to the psychiatric wing. 18 Q But your husband came down, among others, and made 19 sure that you didn't go into the psychiatric wing. Correct? 20 A Correct. 21 Q And that was your choice as well as his choice 22 that you not be committed to a psychiatric hospital? 23 A No. No. At that point, as I said before, at that 24 point if someone had said, "Here is a pill that will stop 25 you from seeing things and get you back into the world," I Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 177 1 don't care, Scientology or whatever, I really don't care, at 2 that point, when you lose your mind, you just want your mind 3 back and you can't think the judgment -- you can't punch a 4 number, let alone think a thought through of God, is this in 5 my philosophy or not or is this how I feel. You want to 6 arrive back on the earth. Then you might say, "Whoa, get me 7 out of here," or not, but you'll be back. 8 THE COURT: Did you have to sign yourself out? 9 THE WITNESS: Yes. 10 THE COURT: And did they want to keep you 11 there? 12 THE WITNESS: Yes. 13 THE COURT: So you signed out against medical 14 advice? 15 THE WITNESS: Exactly. 16 THE COURT: So whatever state you were in, you 17 signed the paper? 18 THE WITNESS: I did sign the paper. 19 THE COURT: Whether you were thinking straight 20 or not -- 21 THE WITNESS: Exactly. 22 THE COURT: -- you signed the paper and said, 23 "I don't want to stay here"? 24 THE WITNESS: Right. 25 Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 178 1 BY MR. WEINBERG: 2 Q And you went home with your husband? 3 A Yes. 4 Q Now, when you said something like you want to be 5 back on this earth, when do you believe you arrived back on 6 the earth? Was that June of '96? 7 A Mmm, it's a cyclical thing, it is not I'm back and 8 I'm not. It's a cyclical thing. I don't -- 9 THE COURT: You had lucid moments and non-lucid 10 moments? 11 THE WITNESS: Exactly. 12 THE COURT: When did you feel like you came 13 back where you were lucid almost all of the time 14 except for an occasional bout, maybe? 15 THE WITNESS: Maybe after a year. After a 16 year. 17 THE COURT: And this started when? 18 THE WITNESS: January, 1996. 19 THE COURT: What is this June date that you 20 told us about? 21 THE WITNESS: That was when I felt the 22 compartments in my mind come back. 23 THE COURT: But you didn't feel you were still 24 quite back until about six more months? 25 THE WITNESS: Correct. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 179 1 BY MR. WEINBERG: 2 Q Then since then, there is an occasional bump? 3 A There -- this past year when I have dealt directly 4 with people in the state of mind that I was in, you know, a 5 Scientologist would call it restimulation, or you could call 6 it a trigger situation where that is brought back. What 7 happened to me is brought back to the now, if you can follow 8 me, talking with people in this state has -- did bring it 9 back during this year. 10 Q And when it got brought back in 2002, then you 11 wouldn't be lucid for a period of time? 12 A Hopefully very briefly. But, no, it is not -- it 13 is not about lucidity. I don't know how to explain it, 14 but -- 15 Q Well, you are not right? 16 A That is a good way, right. You are not right. 17 Q All right. Now, you mentioned in the questions 18 that Mr. Dandar asked you, that there had been a big schism 19 in the Church, and you said in the early '80s. Do you 20 remember that? 21 A Uh-huh. 22 THE COURT: That is a yes? 23 A Oh, I'm sorry. Yes. Yes. 24 BY MR. WEINBERG: 25 Q And you said that that -- there was a big power Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 180 1 struggle between Pat Broeker and David Miscavige. Right? 2 A Pat Broeker was later. 3 Q But that is what you said. So -- 4 A I don't think I mentioned Pat Broeker. 5 Q I'm -- I don't want to argue with you but you did, 6 so -- 7 A If I did, it would only be because he was the 8 interim supposed head for a brief period of time. 9 Q In the early '80s? 10 A But that would have been at -- LHR died in '86. 11 THE COURT: That is the -- when the schism 12 between Mr. Miscavige and Broeker took place. 13 THE WITNESS: Exactly. 14 THE COURT: What was the early '80s? 15 THE WITNESS: Between David Mayo and people in 16 RTC and other executives. There was a whole list of 17 them that were at that level that left in 1982. 18 THE COURT: Okay. 19 BY MR. WEINBERG: 20 Q Now, you subscribed to the beliefs of the Church 21 of Scientology -- to Scientology for a number of years. 22 Correct? 23 A I did. 24 Q You were a committed -- you were a person who was 25 committed to the religion of Scientology. Correct? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 181 1 A I was committed to the beliefs of Scientology. 2 Q Okay. And you -- I mean, things like man is a 3 spiritual being, I mean, that is something that you believed 4 and -- 5 A I did before. I did during. I do now. 6 Q And -- and there are many, many people in the 7 world, as we sit here today, that continue to be committed 8 to the beliefs of Scientology as their religion. Correct? 9 THE COURT: I don't think that is a particular 10 belief that only the Scientologists believe. Man is 11 a spiritual being is a belief I hold, myself. 12 MR. WEINBERG: And I hold it myself, and I was 13 raised that way. 14 BY MR. WEINBERG: 15 Q But you would agree, if anything, that is one of 16 the fundamental principles -- 17 A That man is a spiritual being, yes. 18 Q And that the problems like, for example, problems 19 that -- that I might describe as mental problems -- 20 A Correct. 21 Q -- are spiritual in nature. Right? 22 A Exactly. They -- 23 THE COURT: They can be. Certainly. 24 THE WITNESS: They can be. 25 Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 182 1 BY MR. WEINBERG: 2 Q And, therefore, their belief is that they should 3 be addressed spiritually, as opposed to going to a 4 psychiatrist? 5 A But there are other alternatives. I'm just saying 6 I don't know it's that black and white. 7 THE COURT: He's just simply saying the Church 8 of Scientology belief is that if you have a problem 9 with the mind, if you address it spiritually as 10 opposed to, perhaps, somebody that would address it 11 medically -- 12 THE WITNESS: Okay. 13 THE COURT: -- that is the Church's belief. Is 14 that true? I mean, I don't mean to put words in 15 your mouth. 16 THE WITNESS: Yes. Possibly. Yes. 17 BY MR. WEINBERG: 18 Q Now, going back to the squirrels for a moment, 19 when you were working in cases involving the squirrels, you 20 certainly did not think that they were being objective, that 21 is the squirrels, in their views about Scientology, did you? 22 A No. They were as black and white as Scientology 23 is. 24 THE COURT: She made that pretty clear on her 25 direct testimony. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 183 1 MR. WEINBERG: Okay. 2 THE COURT: She said they were both very black 3 and white. 4 BY MR. WEINBERG: 5 Q Now, when you were in the Church of Scientology, 6 you never saw anyone be given an order to kill someone in 7 counseling, did you, auditing? 8 A No. 9 Q And -- and I think you said, what -- well, strike 10 that. 11 Now, when did you first start communicating, 12 either by phone or in person or over the Internet, with 13 folks that were expressing opinions anti to the Church of 14 Scientology? 15 A Mmm, end of '94, early '95. And I -- they were 16 not -- see, I want to clarify. Are you considering Kim 17 Baker to be anti-Scientology? 18 THE COURT: The question is what do you 19 consider Kim Baker? 20 THE WITNESS: Well, I don't -- the only person 21 that I consider to be -- to be anti-Scientology is 22 Arnie Lerma I was in touch with. 23 THE COURT: When did you come in contact with 24 him? 25 THE WITNESS: On the Internet, possibly in Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 184 1 1995. 2 BY MR. WEINBERG: 3 Q And what -- and you came to learn that -- that -- 4 well, strike that for a second. 5 Kim Baker was on the board of directors of 6 FACTNet. You knew that, didn't you? 7 A I don't think, when I talked to her, she was. If 8 she was, I didn't know it. 9 Q So you know what FACTNet is? 10 A Yes. 11 Q And what is FACTNet? 12 A FACTNet is an organization that Larry Wollersheim 13 started. And how I found out about it is I got a call from 14 Linda Sarkovich at OSA Int who told me Larry was starting 15 this organization, and that was how I knew about it being on 16 the Internet, that she wanted me to join it and tell her 17 what was happening there. 18 And I told her I didn't know about the Internet. 19 And then I learned about the Internet. 20 THE COURT: This was -- this was an activity 21 for the Church? 22 THE WITNESS: Exactly. She wanted me to -- 23 THE COURT: Who is she? 24 THE WITNESS: Linda Sarkovich, another OSA Int 25 person. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 185 1 BY MR. WEINBERG: 2 Q And you were on the Internet in your own name? 3 A Mmm -- 4 Q You don't have to give a name, you just had some 5 Internet name. Right? 6 A No, I never -- I hardly ever, ever, ever have 7 posted on the Internet, ever. That just wasn't something 8 that I did. 9 Q Well, didn't the people at OSA have the same 10 ability to go on the Internet that you did? Why did they 11 need your help? 12 A I don't know. Private conversations with Larry? 13 I don't know. 14 Q So you had -- 15 A I told her I was too busy. 16 Q So you haven't had any private conversations with 17 Larry Wollersheim? 18 A No. 19 Q But you did meet and visit with Arnie Lerma on the 20 Internet? 21 A On the Internet Arnie Lerma and I chatted back and 22 forth. But it was more of a personal nature, as opposed to 23 any kind of anti-Scientology or whatever. He had been a 24 very dear friend of mine I lost touch with. 25 Q You know that Arnie Lerma was in litigation Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 186 1 against the Church of Scientology. Correct? 2 A I don't know if -- I don't think that -- when I 3 started communicating with Arnie, that was not the case. 4 When -- when January, 1996 happened, that was the case. And 5 I did not talk or chat with Arnie, between those times, 6 until actually two years ago. 7 Q Well, you knew that there was a federal injunction 8 against Arnie Lerma with regard to his violating copyrights, 9 correct, of the Church of Scientology? 10 A No. 11 Q So he didn't -- this dear friend of yours didn't 12 tell you that? 13 A I don't even know when that was -- 14 Q Did he -- were you aware that Mr. -- 15 A -- that he had -- that he was raided. I was aware 16 there was a raid at his home. And I believe there was an 17 injunction afterwards or some sort of a court case 18 afterwards. Am I correct? 19 Q And you were aware that he had become very much a 20 part of the anti-Scientology movement? Did you know that? 21 A Not when I initially contacted him. 22 Q Well, at some point as this relationship 23 progressed, you became aware that Mr. Lerma was part of the 24 anti-Scientology movement. Correct? 25 A Mmm, probably when I read in the paper that he was Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 187 1 raided, which would have been the summer of 1995. 2 Q All right. And how frequently did you communicate 3 with Mr. Lerma? 4 A After that point? 5 Q Yes. 6 A I don't believe I did at all. 7 Q You knew that Mr. Lerma was also on the board of 8 directors of FACTNet, didn't you? 9 A No. 10 THE COURT: Are you speaking now about the time 11 she was communicating with him? 12 MR. WEINBERG: Yes. 13 THE COURT: At the beginning of this 14 communication? 15 BY MR. WEINBERG: 16 Q Well, throughout the communication -- 17 A I don't know that he was on the board of FACTNet. 18 Q I guess that is the answer. 19 A Before I talked to him. 20 Q But you know that while you were communicating 21 with him, whatever the period of time you have been 22 communicating with him, that he was at some point on the 23 board of FACTNet? 24 A No. I believe that that was much later. I think 25 that he came on the board of FACTNet after 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 188 1 communicating with him. I could be wrong. 2 Q And did you continue to communicate with Mr. Lerma 3 after January of 1996, this incident that you described 4 where you went crazy? 5 A No. 6 Q So since -- so the last time you have talked with 7 Mr. Lerma or communicated with him is sometime before 8 January of '96? 9 A January of '96 -- the last time I E-mailed him was 10 before he got raided. I do not believe I communicated with 11 him after the raid happened. 12 When OSA was interviewing me, they were very, 13 very, very interested in my relationship with Arnie Lerma. 14 When I posted my story under an assumed name I did have 15 Arnie post it for me but he did not know it was me. But I 16 figured OSA wouldn't know that. 17 Q My question is, is that after that, after you left 18 the Church of Scientology, did you -- 19 A Communicate -- 20 Q -- communicate with Arnie Lerma? 21 A I did, two years ago, go to Washington, D.C. and I 22 did see him. 23 Q All right. And have you stayed in touch with him 24 since? 25 A Maybe periodically. A card or -- Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 189 1 Q And -- 2 A What was what. 3 Q What was the purpose of your trip to Washington? 4 A Sightseeing. 5 Q And did you see anybody else with Mr. Lerma that 6 had to do with his activities involving the Church of 7 Scientology? 8 A No. 9 Q Now, in addition to Mr. Lerma, who else have you 10 been in communication with since 1996 who would be 11 considered a critic of Scientology? 12 A Mmm, I have -- I don't know what you consider -- I 13 mean, I do consider Spanky Taylor a critic. Tory Bezazian 14 has picketed. And I -- 15 THE COURT: Stacy Brooks, Bob Minton, at one 16 point? 17 THE WITNESS: Yes. I talked to them but -- 18 THE COURT: Surely you are talking about other 19 than people she mentioned here already? 20 MR. WEINBERG: No -- I am talking about other 21 people. Right. 22 THE COURT: Is there anybody you have been in 23 touch with that you have communicated with that you 24 haven't told us about in the courtroom already? 25 THE WITNESS: I don't think so. I mean, I do Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 190 1 pretty much freely keep my communications. So if 2 there are some communications somewhere to a critic, 3 there you go. 4 BY MR. WEINBERG: 5 Q How about Frank Oliver? 6 A No. Not until last night. 7 Q Well, what happened last night? 8 A I met him. 9 Q Met him where? 10 A Here. 11 THE COURT: What difference does it make, 12 Counsel? 13 MR. WEINBERG: Well, your Honor, Mr. Oliver is 14 on the stand. 15 THE COURT: So what? 16 MR. WEINBERG: He's an anti-Scientologist. 17 THE COURT: I wouldn't keep him off the stand 18 if they had a conversation. 19 MR. WEINBERG: I would just like to know what 20 the nature of the meeting was. 21 THE WITNESS: Social. 22 BY MR. WEINBERG: 23 Q And who was there? 24 A Well, everybody. 25 Q Well, what do you mean, everybody? Jesse Prince? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 191 1 A Uh-huh. 2 THE COURT: If it was a social meeting -- was 3 anything discussed about the case? 4 THE WITNESS: Not in front of Frank Oliver, no. 5 I said, "Hi, how are you?" He started to talk 6 about, "Do you know this person? Do you know this 7 person?" Do I know that person. That was -- how do 8 we know each other. And that was it. 9 BY MR. WEINBERG: 10 Q And when is the first time you talked to Jesse 11 Prince? 12 A Mmm, about a year -- let's see, a year ago with 13 regards to the woman. And I may have met him earlier or 14 later, I don't remember, but it was when Tory Bezazian came 15 back to Los Angeles after having come down to Clearwater, 16 she left the Church, went to Clearwater. And when she came 17 back, I picked her up, and Jesse was with her. I do not 18 know if that was before or after this past year, with the 19 girl. 20 Q And how did you know Jesse Prince? 21 A Mmm, at that point, I didn't until we had lunch 22 and I discovered he had been the boss of my case officer at 23 RTC. 24 Q So that was the first time you'd met or even heard 25 of Jesse Prince? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 192 1 A Heard of -- I heard of him when I was a 2 Scientologist, yes. 3 Q That is the first time you met Jesse Prince? 4 A Yes. 5 Q You have never met David Miscavige, have you? 6 A Yes. 7 Q What, back in the early '80s? 8 A After the David Miscavige court case was the last 9 time that I met him -- I mean -- I mean after the David Mayo 10 court case. 11 Q It was a social -- 12 A He shook my hand. 13 Q Okay. Have you had any contact with Grady Ward? 14 A Who? 15 Q Grady Ward? 16 A No. I think he's on the Internet. 17 Q Or Keith Henson? 18 A No. 19 Q Or Gerry Armstrong? 20 A No. 21 Q Did you ever visit the Lisa McPherson Trust? 22 A No. 23 Q Now, when did you first have any communication 24 with Mr. Dandar? 25 A Mmm, that he knew who I really was? Or just any Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 193 1 communication? 2 Q Any communication? 3 A I have it written down. It is when my story was 4 revised and it was put on the Internet for the second time. 5 I updated my story. But that was not my real name. 6 And the purpose of that was because I did not want 7 press or attorneys or whatever. And I got -- I got a 8 message, an E-Mail message, from him. 9 Q From Mr. Dandar? 10 A Uh-huh. 11 Q And -- 12 THE COURT: Is that a yes? 13 A I'm sorry. Yes. 14 BY MR. WEINBERG: 15 Q And when was that, approximately? 16 A Several years ago. 17 Q Several is more than two? 18 A Two. Say two and a half years. I don't know 19 exactly. 20 Q All right. And what did the E-Mail message say? 21 A Mmm, would I be interested in being a witness, or 22 he was interested in me being a witness, or something about 23 being a witness in this case. 24 Q And did you -- did you respond back? 25 A I said I would think about it. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 194 1 Q And then when was the next communication? Or tell 2 us about the other -- can you just summarize what other 3 communications or contact that you have had with Ken Dandar 4 since that first E-Mail? 5 A Maybe a couple weeks ago I contacted him; a week 6 and a half ago. 7 Q What? 8 A Not that long ago. And I said, "Are you still 9 interested in me being a witness?" 10 Q And what about when you met Jesse Prince, whatever 11 it was, several years ago, did Jesse Prince tell you that he 12 was working for Mr. Dandar? 13 A No. 14 Q Did the Lisa McPherson case come up when you 15 talked to Jesse Prince? 16 A Well, he worked at the Lisa McPherson Trust. And 17 the Lisa McPherson -- I wouldn't say specifically the Lisa 18 McPherson case, but what happened to Lisa McPherson most 19 definitely would have come up, especially over the past 20 year. 21 Q And, of course, Bob Minton and Stacy Brooks knew 22 who you were. Correct? 23 A They knew who I was. 24 Q All right. And -- 25 A They are mutual friends between me and a lot of Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 195 1 people. 2 Q When did Mr. Dandar learn who you were? 3 A Who I really was? 4 Q Yes. 5 A This past Sunday. 6 Q Well -- 7 A Or Monday. 8 Q Well, were you not aware that Mr. Prince was his 9 consultant? 10 A Mmm -- 11 THE COURT: What difference does it make? The 12 question is -- the question -- 13 A People that -- 14 THE COURT: -- is when did you agree to 15 testify? 16 THE WITNESS: I think Monday or Tuesday. 17 BY MR. WEINBERG: 18 Q Why did you call him? 19 A Why did I call who? Mr. Dandar? 20 Q Yes. 21 A Or contact him again? 22 Q Yes. 23 A Mmm, I don't know if I'm right or wrong, but I 24 think that this is a hearing -- because somebody has 25 presented that there is going to be a summary judgment, Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 196 1 which means no trial. Am I correct? I hope. Because that 2 is why I'm here. 3 THE COURT: That is one -- one of the two 4 things that I'm considering. Yes. 5 A Okay, so forgive me if I get emotional. I don't 6 need a break. I have to get through this. 7 I needed to decide whether I was going to come 8 forward or not. 9 BY MR. WEINBERG: 10 Q But you'd already come forward with your story on 11 the Internet several years ago. 12 THE COURT: There is quite a difference, 13 Counselor, between putting a story on the Internet 14 and coming into court and testifying and being 15 cross-examined and the whole business. 16 MR. WEINBERG: I'm not arguing with her. 17 BY MR. WEINBERG: 18 Q Had you been following the hearing on the 19 Internet? 20 A Just bits and pieces that have come out. 21 Q The transcript is on the Internet. 22 A Uh-huh. 23 Q You need to answer that yes or no. 24 A I'm sorry. Yes. Yes. 25 Q So you have been reading the transcript? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 197 1 A I read Bill Frank's -- parts of Bill Frank's, 2 because I knew him. 3 Q What other testimony did you read? 4 A Mmm, I read, Mmm, occasionally someone would post 5 little parts of testimony. 6 Q Like Mr. Minton's testimony? 7 A Some of his. Some of both sides. 8 Q Ms. Brooks'? 9 A Yeah. 10 Q Mr. Dandar's testimony? 11 A No. Mmm, and I don't know about Stacy Brooks. I 12 don't know if I read any of that exact testimony. 13 Q Now, did you send a letter -- changing subjects 14 now. 15 Did you send a letter to the private doctor, Megan 16 Shields, complaining about her prescription and advice to 17 you? 18 A No. 19 Q Why not? 20 A Why? Why? I never would have gone to Megan 21 Shields. She was not my doctor. 22 Q Well, no one forced you to go to Megan Shields, 23 did they? 24 A Yeah. I mean, it wasn't like they picked up my 25 arms and had me go. But it was clearly that is where I had Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 198 1 to go. 2 Q Now, you realize -- I just want to make this 3 clear -- that we sort of had this discussion while you were 4 on the stand, but you realize that I am not privy to your PC 5 folders and that -- I mean, you understand that, don't you? 6 A I wish I did. 7 Q So let me ask you this as a layperson, because I'm 8 not a Scientologist, I'm not -- I haven't become proficient 9 as to all of the scriptures of Scientology. 10 A Okay. 11 Q When -- as a layperson, when the Church -- when 12 you are a member, whether public or staff, of Scientology 13 seeking counseling, and at the same time you have been 14 communicating with or associating with anti -- people that 15 are adverse to Scientology, you know, someone like an Arnie 16 Lerma, you are not eligible under the -- under the code of 17 ethics of Scientology to get counseling, are you? 18 A That is not necessarily -- Mmm -- no, it would 19 have to be addressed. That issue would have to be 20 addressed. 21 Q Right. And part of the conflict that you had in 22 your mind leading up to 1996 was that you were having these 23 communications with people like Arnie Lerma and Kim Baker 24 that -- that -- 25 A No. That wasn't -- the confusion wasn't Arnie Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 199 1 Lerma or Kim Baker. 2 Q I didn't finish my question. 3 A Oh. Sorry. 4 Q Let me try it again. 5 A Okay. 6 Q Did it create any conflict in your mind that you 7 were having a communications cycle with Arnie Lerma as to 8 whether or not, as a result of that, you were eligible to 9 receive auditing and counseling from the Church of 10 Scientology pursuant to the Church's code of ethics? 11 A No -- was that a concern of mine? 12 Q Yes. 13 A No. 14 Q Now, you have mentioned -- 15 THE COURT: Was this ever communicated to you 16 by the Church in any fashion that you weren't going 17 to get any auditing because you had seen or talked 18 to Arnie Lerma? 19 THE WITNESS: No. Not Arnie Lerma 20 specifically. If a person is on a list -- there is 21 a list of people that you can get into trouble if 22 you communicate to them. 23 THE COURT: When you were -- when you were in 24 your psychotic state and were calling and asking for 25 help, were you ever told, "We're not going to give Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 200 1 you any because you talked to Arnie Lerma," or, "You 2 talked to Kim Baker," or anything of the sort? 3 THE WITNESS: No. 4 BY MR. WEINBERG: 5 Q Now, when you were -- when you had your psychotic 6 break, you went to the hospital. And before you were 7 released, you got some sort of an examination from a doctor 8 at the hospital? 9 A Correct. 10 Q And the Judge already asked you, against their 11 medical advice you checked yourself out. Right? 12 A Correct. 13 Q And you didn't have any kind of -- the doctor for 14 the medical examination didn't indicate that you had any 15 kind of disease or virus or illness. Right? 16 A My blood levels were out of whack. And he -- he 17 thought that I had had a seizure. 18 Q You mean like an epileptic seizure? 19 A I guess. "Seizure" was his word. 20 Q And did you go and did your husband then take you 21 to a doctor to check on the blood and all that? 22 A Mmm -- 23 Q To your private doctor? 24 A Later I did. I did, because I had to -- the 25 hospital reported me as a possible seizure, which means you Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 201 1 get a notice on your -- I didn't know this -- but on your 2 driver's license. You then need clearance to drive that you 3 don't have epilepsy. 4 Q And did it turn out you had it, or not? 5 A I didn't have it. 6 Q I'm sorry, I couldn't hear you. 7 A I did not have epilepsy. 8 THE COURT: When you went to the doctor who had 9 been a member of the Church of Scientology, did she 10 check you out for these things? 11 THE WITNESS: Mmm, no. The Scientology doctor? 12 THE COURT: Right. 13 THE WITNESS: No. Not for those things. 14 BY MR. WEINBERG: 15 Q Well, you had an examination of sorts. Right? 16 A An examination of sorts. 17 Q And what did she do? 18 A Mmm, at that point, I have to tell you that I was 19 petrified of her. 20 Q But that wasn't my question. What I asked you is 21 what did she do? Did she check your blood pressure and look 22 in your eyes and your ears and your throat and do what 23 happens when one goes to the doctor for a general check-up? 24 A Some of those things, yes. 25 THE COURT: Did she take blood work-ups, put a Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 202 1 needle in your arm, take blood out? 2 THE WITNESS: I do not think so. 3 THE COURT: But you were in a state you might 4 not be sure? 5 THE WITNESS: Exactly. 6 THE COURT: All right. 7 BY MR. WEINBERG: 8 Q And then she gave you -- I mean, by the way, I 9 think this was clear on direct but I just want to make sure 10 it is clear, she was not a staff member of the Church of 11 Scientology? 12 A No, she was not. 13 Q She's a private doctor? 14 A Private doctor. 15 Q Okay. All right. And bottom line was she told 16 you to get to -- to try to rest and take vitamins. Right? 17 A Basically. 18 Q All right. And then you were taking, you said, 19 handfuls of -- 20 A The doses I was taking were directed more by an 21 OSA Int person, "How many vitamin B1 did you take? Take 22 more. How many Cal Mag did you have? Take more." 23 THE COURT: The doctor gave you chloral 24 nitrate? 25 THE WITNESS: Chloral hydrate. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 203 1 THE COURT: You said the doctor gave you 2 something else? 3 THE WITNESS: Valerian root. 4 BY MR. WEINBERG: 5 Q And the other thing the Judge takes? 6 A No, melatonin didn't come from her. 7 Q Who did that come from? 8 A I heard of it and mentioned it to someone from OSA 9 Int. They said yes, that is a really good idea. 10 Q You mentioned a number of times now Greg -- is his 11 name Bashaw? 12 A Bashaw. 13 Q B-A-S-H-A-W? 14 A B-A-S-H-A-W. 15 Q And you are aware that before he committed 16 suicide, he was in touch with the Lisa McPherson Trust. 17 Correct? 18 A I don't know for sure if he was. I know his 19 father was. I know he was in touch with different people. 20 Q And -- and you know that just before he committed 21 suicide, a few days before, he was with Jesse Prince. 22 Correct? 23 A I do not know that. 24 Q Do you know that when he did commit suicide, he 25 was in a mental hospital? Do you know that? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 204 1 A He was not in a mental hospital when he committed 2 suicide. 3 Q Was he in a hospital? 4 A No. He was not. 5 Q Had he been in a hospital -- in a mental hospital? 6 A Yes. He had been in a mental hospital. 7 Q And his family had put him into a mental hospital? 8 A The police put him in the mental hospital. 9 Q Is it your belief that for -- your own personal 10 belief, that traditional psychiatry is destructive? Is that 11 your personal belief? 12 A My personal belief? 13 Q Yes. 14 A My personal belief, it can be destructive, yes. 15 It does need reform. That is my personal belief. 16 Q Now, the Church of Scientology has not, did not, 17 sue you, correct? 18 A Did they sue me? 19 Q Yes. 20 A No. For what? 21 Q And you haven't sued them? 22 A No. 23 THE COURT: For what? What are we talking 24 about here? 25 MR. WEINBERG: Well, I don't know. I am just Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 205 1 asking her. 2 BY MR. WEINBERG: 3 Q Nobody has sued either side. Correct? 4 A No. 5 THE COURT: Correct, yes? I think the answer 6 is yes. 7 THE WITNESS: Yes. You are right. 8 THE COURT: Okay. We get confusion. Sometimes 9 lawyers add that magic word "correct" on the end of 10 it. 11 MR. DANDAR: I'm glad I don't do that. 12 BY MR. WEINBERG: 13 Q How did you know to contact -- I mean -- strike 14 that. 15 Did you find out about Bob Minton from being on 16 the Internet? Is that how you found out about him? 17 A Possibly mutual friends. 18 Q Now, this alternative therapy that this other girl 19 you were talking about was -- was that in a Buddhist 20 religious retreat, is that what that was? 21 A No, it was not. 22 Q Some sort of other -- what kind of retreat, 23 generally? 24 A It wasn't a retreat. 25 Q Well -- Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 206 1 A It was -- there is a group of -- actually, it was 2 started -- the one she went to -- and there are more and -- 3 there are more resources. 4 The one she went to was actually started by a 5 psychiatrist. He's written a book. His name is Podvall, 6 P-O-D-V-A-L-L. And it is about handling a psychotic person 7 in the home; compassionate handling of a psychotic person. 8 THE COURT: Written by a psychiatrist who 9 recommended -- 10 THE WITNESS: He's a psychiatrist himself, yes. 11 THE COURT: Who recommends an alternative? 12 THE WITNESS: He found that mental institutions 13 could actually create more damage. 14 BY MR. WEINBERG: 15 Q So it's -- how would you describe it then? It's 16 an alternative approach, I guess? 17 A It's an alternative approach. And -- yes. Do you 18 want me to tell you what it is? 19 THE COURT: No. Honestly. 20 MR. WEINBERG: No. 21 BY MR. WEINBERG: 22 Q And you would agree that there are many different 23 approaches to dealing with mental problems, including 24 through one's religion, through, apparently, traditional 25 psychiatry and other alternatives. Right? There are a Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 207 1 variety of ways people in this world deal with mental 2 problems? 3 THE COURT: That is so obvious you don't even 4 need to ask this witness that. 5 MR. WEINBERG: All right. 6 Could I have a moment? 7 THE COURT: You may. 8 BY MR. WEINBERG: 9 Q Going back to Mr. Minton for a moment, this 10 conversation that you date on March 12 -- 11 A Most likely. 12 Q Most likely on March 12 of this year. At the time 13 that you talked to Mr. Minton, had he already testified in 14 court in front of one of the judges? 15 A On March -- I have no idea. 16 Q No? But when you talked to him, had he told you 17 that he had already testified? 18 A No. He didn't say one way or the other. It 19 didn't even come up. 20 Q Okay. So he didn't tell you that he -- 21 THE COURT: Counselor, he didn't tell her one 22 way or another, so he didn't tell her anything about 23 testifying. 24 MR. WEINBERG: All right. Those are all my 25 questions. Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 208 1 THE COURT: All right. Redirect. 2 REDIRECT EXAMINATION 3 BY MR. DANDAR: 4 Q Mr. Weinberg asked you about Greg Bashaw being 5 taken to a mental hospital by the police. Isn't it true 6 that he got out of that mental hospital and -- 7 THE COURT: You really should never ask your 8 witness a question that starts with "isn't it true 9 that." That is a classic leading question. 10 BY MR. DANDAR: 11 Q Are you aware Mr. Bashaw was subsequently visited 12 by OSA? 13 MR. WEINBERG: Your Honor, that is also a 14 leading question. 15 THE COURT: Well, I guess "are you aware," she 16 can say yes or no. But "isn't it true," that is a 17 clear one-answer type question. 18 MR. WEINBERG: For whatever it is worth, what 19 people taught me at one point was that if I asked 20 the question are you aware that something, that is 21 leading; if you were to say do you know whether or 22 not something -- 23 THE COURT: That is a much better question. 24 MR. WEINBERG: All right, so -- 25 Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 209 1 BY MR. DANDAR: 2 Q Was Mr. Bashaw ever visited by OSA? 3 MR. WEINBERG: -- I object as to the basis -- I 4 mean, if she had a conversation with Mr. Bashaw, if 5 she had a conversation with somebody else I would 6 object she wouldn't be competent to give that 7 testimony, it would be hearsay. 8 THE COURT: I guess the same might be true of 9 yours where she was asked whether or not he went to 10 a mental hospital. Unless she asked who? The 11 mental director? 12 MR. WEINBERG: I didn't hear an objection. And 13 I am objecting to this. 14 MR. DANDAR: I think you opened the door. 15 THE COURT: I'm going to allow it. 16 THE WITNESS: Could you repeat the question? 17 BY MR. DANDAR: 18 Q Was Mr. Bashaw visited by OSA? 19 THE COURT: If you know. 20 MR. WEINBERG: What period of time? 21 BY MR. DANDAR: 22 Q Before he died? 23 A Mr. Bashaw and I did discuss OSA, because he had 24 also done work for OSA at a different time in his life. And 25 we did discuss that -- Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 210 1 MR. WEINBERG: Well, objection, your Honor. 2 THE COURT: Sustained. I think what -- are you 3 asking like right immediately before he died? 4 MR. DANDAR: Right. 5 BY MR. DANDAR: 6 Q Immediately before he died, committed suicide, was 7 he visited by OSA? 8 THE COURT: If you know. 9 A I do not know. 10 MR. DANDAR: That takes care of that. 11 BY MR. DANDAR: 12 Q Now, you said on cross that if you had -- if you 13 contacted a person on this list of suppressive people, you 14 would be in trouble? 15 A Correct. 16 Q What kind of trouble? 17 A Ethics trouble. 18 Q What does that mean? 19 A Mmm -- 20 THE COURT: Surely you have learned enough from 21 this hearing to know the answer. I know the answer 22 and I'm not a Scientologist. I would think you do. 23 Don't you know the answer to this? 24 MR. DANDAR: Well, this is from -- 25 THE COURT: You want to see if she knows? Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 211 1 MR. DANDAR: I want to see if she knows because 2 I anticipate -- well, I don't want to say. 3 BY MR. DANDAR: 4 Q But is ethics something that is a good experience, 5 or a bad experience? 6 MR. WEINBERG: Objection, your Honor. 7 THE COURT: I'm going to allow her to answer 8 what she thinks. 9 BY MR. DANDAR: 10 Q All right. 11 A I have had both. 12 Q Okay. Now, when you went to the hospital, you 13 said that you were told your blood levels were out of whack? 14 A Yeah. 15 Q What do you mean by that? 16 A Whatever that blood work test that they do. 17 Q Okay. That is as much as you know? 18 A Correct. 19 Q All right. Did you ever find out why the Church 20 of Scientology did not offer you any type of program like 21 introspection rundown after you told them that you were 22 crazy? 23 MR. WEINBERG: Objection, your Honor. It is 24 beyond the scope. I didn't ask her about that. 25 Plus he already -- objection. Beyond the Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 212 1 scope. 2 MR. DANDAR: I think he asked about her 3 psychotic state and what was going on in the -- 4 THE COURT: I'll allow it. 5 MR. WEINBERG: Then I object to the basis, you 6 know, that it would be hearsay. 7 THE COURT: If you found out, before you tell 8 us what you found out, tell us who you found it out 9 from. 10 BY MR. DANDAR: 11 Q Did you ever find out why you weren't offered any 12 type of program like the introspection rundown? 13 A No. 14 Q Okay. 15 THE COURT: That is a lot of to do about 16 nothing. 17 BY MR. DANDAR: 18 Q Would you have made it through this psychotic 19 state if it weren't for your husband? 20 A No, I would not. 21 THE COURT: Well, that calls for -- that is a 22 weird question to ask. How would she know? The 23 truth of the matter is even a doctor might not know 24 the answer to that. 25 Obviously your husband was very helpful to you Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 213 1 getting through this? 2 THE WITNESS: Very helpful. 3 THE COURT: As far as you are concerned, he's 4 the one that helped you through this? 5 THE WITNESS: Right. 6 THE COURT: Plus some strong will of your own, 7 I'm sure. 8 THE WITNESS: Yes. 9 BY MR. DANDAR: 10 Q After you declined the request by OSA Int to be a 11 spy against Mr. Wollersheim and FACTNet, were you asked to 12 be a spy for anyone else? 13 A Mmm, after FACTNet? I was asked -- that was at 14 the time that alt.religion.scientology was just starting. 15 And there were Scientologists that were taking assumed names 16 and going on there and, you know, pretending -- you know, 17 you can be, on the Internet, whoever you want to be. Get a 18 fake name and you can do whatever you want, whatever. 19 Their intention was to stir things up or make a 20 ruckus, basically, and find out information or whatever. 21 And I did, in fact, join that newsgroup for my own 22 purposes. 23 Q Were the people who were pretending -- who were 24 really Scientologists and not telling anybody about that on 25 ARS, alt.religion.scientology? Were they talking for, or Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 214 1 against, Scientology? 2 A Either way. Depending upon whatever would suit 3 their purposes. 4 MR. DANDAR: That is all I have. 5 THE COURT: Anything further? 6 MR. WEINBERG: No. 7 THE COURT: Thank you, ma'am, for coming. You 8 may step down. You may be excused. If you have a 9 plane to catch, you are excused and you may leave. 10 THE WITNESS: Thank you. 11 THE COURT: You may call your next witness or 12 you may bring back -- 13 MR. LIROT: Mr. Oliver, please. 14 THE COURT: Mr. Oliver. 15 Did the little break last night cut our time 16 down maybe? 17 MR. LIROT: Yes. 18 THE COURT: Everybody seems to have appreciated 19 the break, even the men downstairs said how happy 20 everybody was that they got to leave a little early. 21 Is it time for a break? When did we start up? 22 MR. DANDAR: One o'clock. 23 THE COURT: Let's break now. It is about an 24 hour and a half. We'll be in recess for fifteen 25 minutes. I never get back until twenty so let's say Kanabay Court Reporters; Serving West Central Florida Pinellas (727)821-3320 Hillsborough (813)224-9500 Tampa Airport Marriott Deposition Suite (813)224-9500 215 1 quarter to three. 2 (WHEREUPON, a recess was taken from 2:25 to 2:45.) 3 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 216 1 REPORTER'S CERTIFICATE 2 3 STATE OF FLORIDA ) 4 COUNTY OF PINELLAS ) 5 I, LYNNE J. IDE, Registered Merit Reporter, certify that I was authorized to and did stenographically 6 report the proceedings herein, and that the transcript is a true and complete record of my stenographic notes. 7 I further certify that I am not a relative, 8 employee, attorney or counsel of any of the parties, nor am I a relative or employee of any of the parties' 9 attorney or counsel connected with the action, nor am I financially interested in the action. 10 11 DATED this 12th day of July, 2002. 12 13 14 ______________________________ LYNNE J. IDE, RMR 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