||||| From: Niemand Nirgendwo Date: 3 Sep 2002 10:43:19 -0000 Message-ID: Subject: (amicus) C, MAIN BRIEF II Newsgroups: alt.religion.scientology,comp.org.eff.talk,misc.legal References: <20020903072001.30984.qmail@nym.alias.net> Comments: * PLEASE REPORT ABUSE to abuse@cotsebay.cotse.net *** *** PLEASE REPORT ABUSE to abuse@cotsebay.cotse.net *** *** PLEASE REPORT ABUSE to abuse@cotsebay.cotse.net *** *** PLEASE REPORT ABUSE to abuse@cotsebay.cotse.net *** X-Remailer-Contact: admin@cotsebay.cotse.net Mail-To-News-Contact: postmaster@nym.alias.net Organization: mail2news@nym.alias.net Lines: 222 Path: news2.lightlink.com!news.lightlink.com!news.mv.net!newsreader.wustl.edu!stl-feed.news.verio.net!news.cmnh.org!phl-feed.news.verio.net!iad-feed.news.verio.net!iad-peer.news.verio.net!news.verio.net!newsfeed.stueberl.de!newsfeed.Austria.EU.net!newsfeed.kpnqwest.at!anon.lcs.mit.edu!nym.alias.net!mail2news-x3!mail2news-x2!mail2news Xref: news2.lightlink.com alt.religion.scientology:1550440 comp.org.eff.talk:105629 misc.legal:433654 038. PRESSURE ON JUDGES. There certainly have been public attacks on the Judge in the present case.... A Times Editorial, Court needs better judgment St. Petersburg Times May 21, 2002 For a circuit court judge, Charles Cope is severely lacking in good judgement. New revelations about the way the Pinellas-Pasco judge tried to cover up his arrest in California suggest he doesn't belong on the bench, regardless of the validity of the criminal charges against him. Records show he conspired with then-Chief Judge Susan Schaeffer to keep the fact of his arrest from the Judicial Qualifications Commission, the body charged with policing judicial ethics. While it is impossible to prove, it certainly has the appearance of a Dead-Agenting attack to discredit or recuse an unfavourable Judge, by the alleged Church. The Cope affair is old news which was thoroughly aired when it happened, over a year ago; Judge Schaeffer is the FORMER chief judge, nearing retirement, and it is hard to fathom why anyone not connected with this case would see her as a particularly important target for attack compared to e.g. rising stars with political ambitions. 039. Attacks on judges are certainly nothing new for the alleged Church; the following is a press article rather than best evidence, but cites primary sources (and the American Lawyer is a fairly reputable magazine) The American Lawyer, December 1980 SCIENTOLOGY'S WAR AGAINST JUDGES BY JAMES B. STEWART, JR. On July 16, Richey issued his opinion. Evidently referring to the upcoming Anderson column, which Richey might have known about from reporters' calls and messages, Richey characterized the recusal motion as "this latest effort in the escalating attack on the court" and found the grounds for the motion to be "insufficient as a matter of law," resting only on "hearsay, rumor and gossip." But, the judge continued, "defendants and their counsel have engaged in groundless and relentless attacks on this court. Their motive is transparent. It is an attempt to transform the trial ... into a trial of this judge." Though he labelled the attempts to remove him a "classic example" of abuse of the recusal statutes, he wrote that "the time has come for the proceedings in this case to proceed on the merits with the attention of all directed at the real issues in this case." As a result, Richey withdrew from the case in a state of exhaustion and near-collapse, according to associates. The following affidavit was entered by Judge Ideman (I believe in Fishman and Geertz vs CofS, but it is easily found) after his recusal: DECLARATION OF HON. JAMES M. IDEMAN, 17 October 1994 I, James M. Ideman, declare as follows: 1. Portions of this petition will become moot because I have decided to recuse myself from this case. Plaintiff has recently begin to harass my former law clerk who assisted me on this case, even though she now lives in another city and has other legal employment. This action, in combination with other misconduct by counsel over the years has caused me to reassess my state of mind with respect to the propriety of my continuing to preside over the matter. I have concluded that I should not. I have delayed the effective date of my recusal, however, so that I could respond on behalf of my court to allegations in the petition. The alleged Church has never feared to attack public officials in the last resort, framing Clearwater Mayor Gabe Cezares for hit and run, and trying to remove from office Provincial Crown Prosecutor Casey Hill. 040. TESTIMONY ON FAIR GAME. The oath that Ms Brooks swore, and Mr Fugate is bound by as an officer of the court, is to "tell the truth, the whole truth" as well as "nothing but the truth". It does not merely forbid specific falsehoods. It also requires witnesses to give a full and complete answer to questions put, without attempting to misdirect by use of half-truths. But both Brooks and Fugate did exactly that. They falsely implied that the actual practices known as Fair Game have been cancelled, when in fact only use of the WORDS "Fair Game" has been cancelled. We mention this because it is a second blatant and provable perjury, along with the denials of rank and hierarchy in the Sea Org, by Brooks in particular. As usual, she lies like a cheap rug. 041. OTHER FALSE STATEMENTS. We are aware of, and commend to you, the sworn statement of David Rice that he rather than Mr Henson took any GPS readings of Scientology's fenced camp at Hemet(CA): It has come to my attention that the sinister commercial enterprise that calls itself "The 'Church' of Scientology" has once again provided to a Court a false statement concerning Mr. Keith Henson. I must therefore once again set the record Straight in this matter. On the request of several Human Rights activists (communicating via the Internet) who are observing Scientology Inc.'s crimes and human rights abuses, I took GPS readings of Scientology's compound at Gilman Springs. I then posted the results on the Internet, fulfilling that request. GPS readings constitute the geographic latitude and longitude of a location upon Earth. The commercial enterprise known as "The 'Church' of Scientology" has repeatedly falsely asserted that Mr. Keith Henson took these "GPS readings." Scientology Inc.'s assertion in this matter is completely false. To my sure, certain, and definitive knowledge, Mr. Keith Henson did not do so. Nor did Mr. Henson cause anyone to take said GPS readings. Nor did Mr. Henson have any awareness before the fact that GPS readings would be taken. The Scientology business knows Mr. Keith Henson did not take the GPS readings. The Scientology business knows Mr. Keith Henson had no knowledge or awareness the GPS readings would be taken. The Scientology business is therefore knowingly falsely asserting a lie. We concur that (a) the assertion Henson took these readings is false, and (b) the defendant knew it was false and had been reminded in writing it was false, and (c) any such statement by the defendant or his witnesses is deliberate perjury. It very least it calls for the summoning of Mr rice as a witness to determine, as a finding of fact, who is telling the truth here. 042. STIPULATIONS. We believe the facts speak for themselves to the extent that the defence should simply stipulate the following. 1 (a) The Sea Org is a uniformed elite group of dedicated scientologists permeating all or its organisations and forming the entire staff of the most senior ones, while the RTC is an corporation intended to enforce the purity of the Hubbard writings; they are not the same body, Mr Miscavige's leadership role in them is not the same. (b) Mr Miscavige, as the only person with the highest personal rank, Captain, is leader of the Sea Org. (c) Any denials of the above by Stacy Brooks are deliberate falsehoods. 2 (a) The substance of the policy for handling enemies remains the same, although use of the phrase "fair game" has been cancelled. (b) Any denials of the above by Stacy Brooks are deliberate falsehoods. 3 (a) The second affidavit of Minton was signed by him on 24/apr and of Brooks signed by her on 28/apr prior to the settlement meeting on 29/arr; these affidavits were written for them by the same member of the defence team, and put before them to sign. 043. IMMUNITIES. We believe at some stage there need to be prosecutions for perjury, witness tampering, and so forth, and that this would require immunising some people so that there is no longer a fifth amendment right to silence once there in guaranteed no risk of prosecution. Probably (a) Brooks and Minton should plead to perjury with a maximum penalty, perhaps 2 years sentence and one year served, in low-security conditions since they are not violent criminals, also repayment of any debts for tax with interest at bank rate, but be immunised against all other crimes and penalties; in exchange for (b) disclosure of all demanded financial information, in closed session and under seal to the court and the IRS, plus disclosure of all perjuries and who suborned or counselled them and what threats or inducements were made for them and testifying thereto. 044. In sum, Scientology has never hesitated to conduct any lawsuit as an all-out war of personal attack on the opposing party, his witnesses, his attorneys and, as a last resort, any unfavourable judge. They have done it in this case, they have done it in a long history of earlier cases, and it is entirely in line with the policies laid down in writing by their insane founder L Ron Hubbard. We believe the alleged Church have exposed themselves to investigation and prosecution for criminal activities to subvert justice in this aces, such as the framing of Jesse Prince on improper charges aimed at his removal as a plaintiff's witness. Such a case would, of course, have to be dealt with on the merits of present conduct. Nevertheless we believe the alleged Church has opened itself up to examination of a long pattern of systematic tactics. In particular, by naming attorneys Berry, Green, Liepold etc in its testimony and attacking their reputations as an attempt to prove a long-standing conspiracy to do down the alleged Church for reasons of mere prejudice, it has opened up examination of its own conduct in the past cases it names and of its harassment of those persons. Finally, if such a prosecution were launched, it is very likely the alleged Church would then systematically attempt to bring down the judges in it, by tactics such as setting up judges or their grown-up children prostitutes for blackmail purposes, as they have done before. CONCLUSIONS. We write here, after a long recital of analysis and evidence, what we would hesitate to say simply as unsupported opinion. The key feature of the wrongful death case has been the ignominious turn-around of plaintiff's witnesses Bob Minton and Stacy Brooks. Under whatever blackmail pressure, very likely over funds in foreign banks on which tax is due and evaded, they have been forced to sign affidavits drafted for them by others. According to Brooks testimony, first Bob wrote an affidavit saying what Scientology wanted on 24/april, then Stacy signed a supporting affidavit on the 28th, then they negotiated with Scientology what they were going to sign on the afternoon of the 29th, then they told Ken Dandar they were about to enter negotiations with Scientology. The new affidavits are designed to frame plaintiff's attorney Ken Dandar on false charges of perjury, and admit an insane conspiracy theory so that everyone helped or funded by Bob Minton in various cases can be set up for a false RICO suit. But this is not an isolated incident. The alleged Church has written Policy Letters by its founder, L Ron Hubbard, saying that just criticism is to be treated as persecution and met with counterattack not defence. In particular, lawsuits are to be treated as a military campaign to harass and ruin the opponent, and the method is always to ignore the issues and launch an all-out "Dead Agent" attack on the opponent. This has been the pattern in the abortive MacPherson prosecution and in the MacPherson civil suit, as it has been in a long string of earlier cases. An exchange of letters between Scientology leader David Miscavige and District Attorney Bernie McCabe offers to "pay off" the prosecution with a donation to local charities. When that failed, pressure on his chief witness the Medical Examiner Joan Woods drove her to change testimony, drove her from office, and ultimately drove her into the psychiatric ward of Morton Plant Hospital. Relentless discovery in the civil case was designed to identify families seeking help, and supporters offering funds, so they could be targeted for harassment; as discovery has been systematically abused in other cases e.g. to humiliate attorney Graham Berry over his admitted homosexuality. The next step was to blackmail the defendants main supporters into reversing their testimony, and use this to bring false charges to remove the plaintiff's attorney Kennan Dandar. The defendant has, we believe, planted at least one hostile press story against the present Judge, and has a long history of attacking unfavourable Judges. What is to be done about this? We believe that Brooks and Minton should, automatically, serve the maximum six months less one day for their contempt of court. We also feel it would be better to immunise them for their perjuries on condition they make full disclosure on those who suborned their perjury, and for any and all crimes they are concealing under fifth amendment immunity (but not from full disclosure of taxable finances and payment of taxes due) in order to sort out the whole business of blackmail. We believe the alleged Church has systematically engaged in a long course of actions designed to subvert the course of justice in this case, as it has in many others. It is important to see the whole sweep of their corrupt behaviour, and the whole extent of their utter rottenness. It is crucial that, this time, they neither benefit from it by depriving the dead girl's family of remedy for her death, nor get away without a full criminal investigation into their systematic conduct. VALEDICTORY. We are not parties entitled to address the court in this matter, but we ask that our letter be entered in the file as correspondence received, and that the Court or the parties raise for us any issues in it they feel it is proper to raise. Thank you for your time spent reading our brief. --the Amicus group ||||| From: Nomen Nescio Comments: This message did not originate from the Sender address above. It was remailed automatically by anonymizing remailer software. Please report problems or inappropriate use to the remailer administrator at . References: <20020903072001.30984.qmail@nym.alias.net> Newsgroups: alt.religion.scientology,comp.org.eff.talk,misc.legal Subject: (amicus) F, Minton Affidavit Message-ID: Date: Tue, 3 Sep 2002 12:50:18 +0200 (CEST) Sender: remailer@dizum.com Mail-To-News-Contact: postmaster@nym.alias.net Organization: mail2news@nym.alias.net Lines: 198 Path: news2.lightlink.com!news.lightlink.com!news-xfer.mccc.edu!newspump.monmouth.com!newspeer.monmouth.com!news-feed.ifi.uio.no!uio.no!feed.news.nacamar.de!newsfeed.Austria.EU.net!newsfeed.kpnqwest.at!anon.lcs.mit.edu!nym.alias.net!mail2news-x3!mail2news-x2!mail2news Xref: news2.lightlink.com alt.religion.scientology:1550443 comp.org.eff.talk:105631 misc.legal:433656 F. SECOND AND THIRD AFFIDAVITS OF BOB MINTON In (2) there is nothing, as this implies, improper about an attorney discussing ways to bring his current opponent to settlement;=20 or about paying expert witnesses for their expert testimony. In (3) the real drafter again uses this odd idea of "theories" to deconstruct the validity of expert testimony. In (4) we have the confession which the lunatic had his doctor=20 sign at gun-point again. In other words, even if Minton regretted his past help of Scientology's victims, it is unlikely he would=20 write that the Lisa MacPherson was to be a "centerpiece for me" as a piece of vanity. Nor was it a "vehicle to attack Scientology on a broad scale", which again puts the cart before the horse: it seems to forget that Scientology killed someone's daughter, and that this case is to determine whether and to what extent they are culpable for her death. She did not maliciously commit suicide at Scientology headquarters just to create a way of suing Scientology. In (5) we might have a reasonably true account that donations of money for litigation costs were to be treated as an interest free loan, and recovered from any award of costs if the case was won. This contradicts the idea in (17) of Brooks about "investment". Investment implies profit, and interest free loans are without profit: both cannot be true at once. In (6) readers will simply have to decide who they believe about case control; in (28) of Brooks it is clearly possible to believe that attempts to control the case began with attempts to shut it down when Brooks and Minton caved in to Scientology pressure. In (7), post hoc ergo propter hoc: if Minton says it is going to rain soon, and it rains, even so Minton may not have made it rain. In (8) perhaps Minton should be asked how "it was a way for me to recover the funds I had invested in the litigation" [if they were=20 put into an anti-cult group]. The original arrangement was supposed to be a loan repayment without interest. If they go into an organisation then, clearly, they do NOT go back to Minton himself; surely. In (9) Dandar allegedly raises with Minton the possibility of offshore funds - perhaps Dandar thinks it was the other way round? In (10) it is alleged that the Estate wanted the Lisa Trust, and wanted it to be controlled by Minton. In (11), "the case had now been turned into a broad attack on Scientology". How, exactly? had other incidents of death or injury been dragged in? In what way had the case been broadened beyond the wrongful death of Lisa MacPherson, by their own admission both in the scientology headquarters and during a scientology procedure? The following is also arrant nonsense: "All of these witnesses were ex-Scientologists who had left Scientology years before Lisa McPherson died, and had no personal knowledge of any facts surrounding her death." It wilfully mis-represents the nature of an expert witness, who is not meant or expected to have personal knowledge of the specific case facts. In (12), the reader will have to decide for themselves whether this is true about Dandar's attitude to Bob's publicity seeking. In (13) frankly the person who showboats, who seeks and initiates publicity, who want to be the personal hero and collect the awards, is not Kennan Dandar. In (14), the idea of the movie being intended to or succeeding in having wide public effect is contradicted by Minton's statement that "The only place in the United States the movie was ever screened was in Clearwater and Tampa. The movie was of such poor quality that distribution became impossible." In (15) this reflects (12) of Brooks, that Scientology should become "more involved". Same question: this phrase is without substance, how precisely was it meant to become more involved than it already was? In (16) likewise, even when expanded, the statement has little meaning: "Mr. Dandar was willing to shift the emphasis of the case from a simple wrongful death suit to a case against the beliefs and practices of Scientology". But Lisa MacPherson WAS on the Introspection Rundown by Scientology's own admission (Mike Rinder on German TV). This is a key question in determining whether what happened was done according to systematic policy rather than by the misdeeds of maverick individuals. There is nothing untoward in emphasising this aspect of the case. =20 In (17) "he focus of the discussion was not what the facts were concerning Mr. Miscavige, but how to pressure him" sounds like the fantasies scientology has about those who seek redress for injury against them being a conspiracy of persecution, not anything Minton would originate for himself. In (18) exactly echoing the corresponding passage signed by Brooks, and probably drafted by the same person, we get the defendants contention that there was no evidence concerning Miscavige, put into the mouths of blackmailed opponents. In (19) there is a "pattern", there is a "theory", there is conspiracy, there is a sky-full of flying pigs. This is simply not credible. In (20) there is again an agreement to keep this meeting secret because, it is implied, something improper took place. In (21) it is again said that secrecy was maintained. There seems to be a remarkable unanimity between the Brooks and Minton affidavits, which seem to say pretty much the same things at the same point in each affidavit. There are several possible reasons for this. Perhaps is the same because it is the truth. After we stopped falling about laughing, we came up with two other reasons. It is the same because Minton and Brooks discussed with each other what to put. Or it is the same because the same person drafted the new affidavit for each of them to sign.=20 In (22) the allegation of suborning perjury is plain enough, and the reader will just have to decide who they believe. In (23) and (24) it echoes corresponding passages of Brooks where the Lisa MacPherson Estate is said to be fully supportive of, and virtually synonymous with, the Lisa MacPherson Trust. At least up to the point where the Trust tried to control the case in order to shut it down, and withdrew as witnesses and funders when they failed to do so. In (25), much the same. In (26) it states the defendants fantasy and contention that "the wrongful death case and the LMT became virtually interchangeable". Readers will have to decide for themselves if this is true. In (27) it lists how various people were paid. Armstrong launched a virulent persecuting "attack" on scientology, and entirely innocent organisation which should be left alone or rewarded when it wrongfully kills people. =20 In (28) we have financial arrangement allowing the Church of Scientology the "opportunity to characterize the relationship as an inappropriate 'business deal' (which is exactly what it was, a 'business deal') between the Estate and myself". This sounds a wonderful phrase, but where's the beef: what exactly was the business deal, and where was the profit to be made? The whole thing collapses on close examination. In (29) it is again asserted that the winnings will go into the Trust. In (30) Minton alleges that this agreement existed, but affidavits were filed denying it. It is really a matter for examination of these witnesses whether any such agreement existed or not. In (31) Minton again says that false denials of such an agreement were sworn. In (32) Minton says, or has been made under threat to say, that there was something improper in the Lisa MacPherson Trust resisting intrusive deposition and discovery. However there were at the time said to be many good reasons for this e.g. protecting the privacy of employees and clients against Scientology, which is known for harassing opponents. In (33) much the same statements are made about videos, which may be for the same various reasons: because it is true, because they discussed it with each other, or because it was drafted for both of them by the same hand. The two affidavits would bear side-by-side examination. They contain the same items, in the same order and, especially, in the same wording to an extent which could not be coincidence. Choices about construction of the text are far more closely similar than could occur merely through Brooks and Minton discussing it, unless they did so a great many times. Almost the only conclusion is that the same hand drafted both affidavits, then set them before Brooks and Minton to sign. In (34) and (35), Minton alleges that it was Dandar who wanted funds to arrive as untraceable cashier's cheque - Dandar may say differently. In (36) the interesting question is, how were the Union Bank of Switzerland paid for the amount on the cashier's cheque they issued. Was it sent from some other account Mr Minton had at the UBZ? Or where else did the payment come from, and had all due taxes been collected on it? In (37) we have only Minton's word that it was not he himself who wanted an anonymous source, and who also wanted concealment at deposition. In (38) similarly. In (39) Minton says he was becoming reluctant to fund in the August of last year, 2001. In (40) he says there was a final funding approach in February this year, 2002. =20 In (41) Minton says he refused to go see Dandar in the Cayman islands; in (42) he says a meeting happened in New Hampshire on Dandar's return. In (43) he says he used a code for foreign money in Garko's presence. In (44) he says the meeting started making clear he was opposed to future funding, and in (45) he again mentions the codeword. In (46) he reckons he said there might be additional funds, but wanted criticism of him on the Internet silenced. In (47) he alleges that Dandar connived at perjury in answers about funding; in (48) Dandar says citing some anonymous foreign donor would not be believed. In (49) he got a thank- you letter from Dandar, and in (50) he again alleges there was an unwritten secret agreement which nobody but Minton and Brooks will testify ever existed. =20 In (51) Dandar supposedly arranged phone scrambling for future calls. In (52) he says he received this device at the start of March this year, 2002; in (53) he says he received further calls soliciting funds.=20 In (54) he says he sent a cheque for a further $250,000 cheque enclosed in the pages of an essay. This was so late into his refusal to fund that he may well have agreed with Scientology to do this=20 so as to set Mr Dandar up with apparent wrong-doing. =20 In (55) he alleges that he received various confidential case information from Mr Dandar. In (56) he talks about the contact with Dell Liebrich to make her drop the case or, failing that, for Brooks and Minton to drop out as funders. In (57) Minton repeats Brooks lies about the reasons for Jesse Prince's withdrawal, failing to mention that Prince had been framed for drug possession. In (58) he says that during February 2002 - i.e. before the final payment of =A3250,000 during March mentioned in (54) - he entered settlement negotiations with Scientology. =20 In (59) he describes a final break with Dandar in April 2002, and in (60) he says that it was Dandar who did not want the cashier's cheques revealed - Dandar may say otherwise. In (61) he says "I hereby recant any false statement I have made under oath that may contradict my sworn statements in this affidavit," though it may be there are a whole load of new falsehoods in this one. Minton entered a THIRD AFFIDAVIT on the 24th of April, thankfully of only ten paragraphs: this is almost entirely concerned with blackening the name of Jesse Prince for his refusal to co-operate with Minton's turnaround in the wrongful death case. ||||| From: A.Melon Comments: This message did not originate from the Sender address above. It was remailed automatically by anonymizing remailer software. Please report problems or inappropriate use to the remailer administrator at abuse@melontraffickers.com. Please read http://melontraffickers.com/remailer.html before contacting the remailer administrator. References: <20020903072001.30984.qmail@nym.alias.net> Newsgroups: alt.religion.scientology Subject: (amicus) C, MAIN BRIEF I Message-ID: <0a9d50193c5665b6dbe0c5ee143dff7f@melontraffickers.com> Date: Tue, 3 Sep 2002 04:03:27 -0700 (PDT) Mail-To-News-Contact: postmaster@nym.alias.net Organization: mail2news@nym.alias.net Lines: 1000 Path: news2.lightlink.com!news.lightlink.com!news-out.visi.com!hermes.visi.com!eusc.inter.net!fr.clara.net!heighliner.fr.clara.net!news-hub.siol.net!newsfeed.Austria.EU.net!newsfeed.kpnqwest.at!anon.lcs.mit.edu!nym.alias.net!mail2news Xref: news2.lightlink.com alt.religion.scientology:1550441 C. Brief THIRD PARTY BRIEF ON THE LISA MACPHERSON WRONGFUL DEATH CASE 001. We are not sure whether this is in proper form to be an amicus curiae brief. We are sorry it is long, but hope that the amount of valid content justifies the amount of wordage. We ask that you enter it in the court file as correspondence received and treat it with as much, or as little, seriousness as it deserves. We do not represent that we are properly interested persons with a right to address the hearing, and do not put ourselves forward as being either direct or expert witnesses. Whether the Court or the parties wish to raise any part of this text in hearing, and whether the Court would then allow it as admissible, is therefore a matter for them. 002. Any facts or arguments we raise stand on their own merit, not on our characters. We have therefore sent this anonymously, and ask that you destroy the envelope and do not identify the city or country of origin. We have no intention of answering long defamatory rants from Mr Lieberman; or of armed police units in our country being set up, on false information, to raid our homes with the hope we get shot, as with Hagglund and Henson. What we say stands or falls on its independent merits: who we are is therefore irrelevant. TURNING OF MAIN WITNESSES 003. Two of the complainant's main witnesses, Ms Brooks and Mr Minton, have since changed sides and entered new affidavits favouring the defendant "Church" of Scientology. We aim to marshal, below, facts which persuasively suggest that they (a) signed material which clearly was - on examination of the words and concepts used - drafted for them by others without their input, (b) that this contained statements which were false and which they knew to be false, and (c) that they had their change of heart under extreme, possibly improper, pressure. 004. We wanted to find a way in which the Court or the jury could apply simple commonsense criteria to confirm, grounded in objective observations, a change of authorship between early and later material. We therefore took a close look a the style, vocabulary, and punctuation of the documents concerned, in a way that stands or falls by commonsense evaluation without requiring credence in us as experts. We analysed the second affidavits supposedly-by Brooks and Minton, in relation to affidavits in this and other cases which we are satisfied are really-by Brooks and Minton. We were looking to see whether faux- Brooks and faux-Minton are very similar to each other yet dissimilar to other Brooks and Minton writings. Both are similarly heavy on periods and light on commas, indicating short sentences with fewer subclauses, and are much less likely to use "less standard" marks such as colons/semicolons, question/exclamation-marks, or parentheses. They typify a kjnd of dumbed-down, ultra-clear writing style taught to those who professionally produce tabloid journalism or legal briefs. Analysis of vocabulary usage shows a very clear pattern. In simple grammatical connectives, and in such verbs or nouns or adjectives as are used regularly with fairly general meaning (talk, job, simple), about half of them are much closer in occurrence between faux-Brooks and faux- Minton than with any other file. The other half are so close as to be almost exactly the same. The interpretation of this result is ultimately a matter of advice or fact-finding, but its existence stands out a mile. With a more sophisticated program then, where the occurrence is low enough to be 4 or 5 time per five, we could print out a list of three-word contexts and see whether the word was being used in a s similar manner as well as with a similar frequency. The next step for anyone evaluating the evidence is, having looked at these figures, to give the two documents another close reading and see whether their common sense, having a few numerical measurements to go on, confirms or refutes the idea that they are by the same author. The computer programs we used could be easily duplicated by any professional with a couple of weeks work; there is no need to supply ours, which are really nothing special. The Court or the Estate could likewise bring in their own text-analysis experts. We believe the attached document shows, on a commonsense basis, that the faux-Brooks and faux-Minton affidavits withdrawing their earlier evidence were drafted by the same person, who is not either Minton or Brooks but most likely a Scientology lawyer. Indeed this is so brazenly obvious that the defendant "Church" should, if necessary, stipulate it as true, without putting the court to the trouble of lengthy argument on an un-winnable point. 005. We also felt it was important to confirm the above by examining the concepts and references used in the documents, to show again that they are written from the viewpoint of a Scientology attorney and are not anything Minton or Brooks would normally say, even had they undergone a genuine change of heart in deciding to withdraw earlier testimony. 006. On examining the second Brooks affidavit, it sounded very much like what Scientology would say about their opponents but no sane person would say i.e. that everything is one great anti-scientology conspiracy and they seriously intend to sue all the critics, all the lawyers, and the dead girl's family in one big RICO for daring to oppose them. They have had this written and the somehow pressured Ms Brooks into signing it, though it is nothing like what she would say herself even had she undergone a genuine change of heart and regretted helping people hurt by the Church of Scientology to sue it for redress. A content analysis of this document forms ENCLOSURE 2 007. Given the overwhelming evidence of style and content we believe that the defendant should, if the issue arises, simply stipulate that the second affidavit was written by CofS attorneys on their own and brought to Ms Brooks to sign. She then read and signed it to attest that it reflected the truth as she understood it. Whether it contained material which was false and which she knew to be false, and whether they knew they were inducing her to sign false documents, is a separate issue to be determined on other evidence. Please bear with us if some of our comments are covered in the witness exam-nation, as we are close- reading the documents one by one and commenting as we go. 008. WE therefore select for examination the most egregious piece of knowing falsehood, stated at (15) in the second affidavit. The first question is whether Mr Miscavige has a different role in the Sea Org to his corporate role in the RTC. It would first be sensible to ask whether the Sea Org is something different to the RTC. If they are different then being leader of each does sound like two separate roles. The RTC is a registered corporation whose role is to preserve and defend the Scientology writings of L Ron Hubbard. It publishes a website with the following introduction: The philosophy and technologies of Dietetics and Scientology were discovered and developed solely by L. Ron Hubbard. It is a fundamental belief of Scientologists that, if the technologies are applied exactly as he recorded them in Scientology scripture, they are universally workable and will improve conditions and result in greater spiritual awareness and ability for everyone. For this reason, Scientologists emphasize the orthodox and standard application of the Scientology scripture. Thus, Scientologists never interpret scripture for each other but always refer to the original source materials. A Course Supervisor in a Scientology church is not a teacher in that he does not lecture or give his own opinions because to do so, even if well-intentioned, would inevitably enter alterations, even if slight, into the technologies which would lessen their effectiveness. This alteration could accumulate over time to the point where Scientologists could never achieve the full spiritual benefits of the religion. For these reasons the Church and its members want, above all else, to preserve and apply the Scriptures exactly as set forth by Mr. Hubbard. Again, Scientology itself publishes a "what is scientology" web-site which, in chapter 26, says the following about the Sea Org: The core of every great religion in history has been a group of individuals dedicated to achieving the goals of the religion. In Scientology, these individuals are part of a fraternal religious order known as the Sea Organization, or Sea Org. While relatively few in number, its members play a crucial role in virtually every aspect of the ministry and expansion of Scientology. And, like their counterparts in other faiths, Sea Organization members occupy the most essential and trusted positions in the senior churches in the Scientology ecclesiastical hierarchy. The Sea Organization derives its name from its beginnings in 1967 when Mr. Hubbard, having retired from his position as Executive Director International, set to sea with a handful of veteran Scientologists to continue his research into the upper levels of spiritual awareness and ability. The first Sea Org members, who were all Clears and OT, formulated a one-billion-year pledge to symbolize their commitment to the religion as immortal spiritual beings. It is signed by all members today. They dedicate themselves to the goal of bringing spiritual freedom to all beings through the full application of Mr. Hubbard's technologies. The Sea Organization was born of a concern for the welfare of mankind - and it is with this viewpoint that members of the Sea Org continue to operate. We need not accept Scientology's self-serving high opinion of this group to see that, in their own words, it is neither a corporation nor specifically dedicated to preserving and defending the Scientology copyrights. Any assertion that they are the same body with the same leader is just silly. The Sea Org is a group forming about 10% of Scientology staff who wear paramilitary naval uniforms and were originally the scientology branch (org) based around L Ron Hubbard on his converted ferry the Apollo, therefore the most senior branch which in practice commands all others. If they are different, it is likely being leader of each is different. As to whether there is a such a position as 'head (or Captain) of the Sea Org' and whether Miscavige holds it, they have frequently touted him in Public as precisely that. 009. The question then arises whether Ms Brooks length, recency, and seniority of service in Scientology is such that she would have known the true position. She says in her testimony: (P28) 1 A Well, my husband and I left Scientology in 1989[...] 16 I'd been in for 15 years so -- and my 17 husband had been in for 20 years, (P29) 14 Both of 15 us had, at various times in our careers in 16 Scientology, held high management positions. While this is over a decade ago, it is after the effective takeover by Mr Miscavige in 1982 and his actual installation as head of the organisation on Hubbard's death in 1986, when the present corporate structure including RTC was established. The Youngs were writers and publicists for Department 20, then known as the Guardian's Office, which deals in propaganda to friends and harassment of enemies. After the Operation Snow White case in 1984 (five years before they left) in which eleven senior Scientologists were convicted of stealing government files, department 20 was renamed the Office of Special Affairs and OSA International became "a Sea Org" i.e. an organisation totally staffed by Sea Org members; the Youngs must then have been Sea Org. As both members of the Sea Org, and tasked with writing main national press releases for Scientology, they would have known whether they would have had a clear knowledge of its corporate structure and whether there was a 'Head of the Sea Org.' Ms Brooks-Young is therefore telling a knowing and deliberate lie, in a new affidavit supposed to clear up her former perjured testimony. We feel this goes beyond the point where penalties for contempt and perjury can any longer be waived. 010. We now turn to the second and third Minton affidavits. There is not an obvious perjury which contradicts known facts on record. Rather, when the truth or falsity of various matters is determined on the evidence, it may then be felt that certain matters here are knowing falsehoods. The most striking feature of these affidavits is the overlap with that signed by Ms Brooks in style, sequence, and wording, which goes beyond what could have arisen by them discussing the matter a few times then writing independent affidavits. Either they saw each others affidavits while composing them, or both affidavits were drafted for them to sign by the same third party. 011. BACKGROUND ON THE INTERNET. A few basic facts could usefully be stipulated about the Internet. Computer networks usually allowed two kinds of message, electronic mail to specific persons and "discussion boards" or newsgroups where anyone can reply to any article in one of the debates. Inter-networking joins the networks up so that a person on one network can email a person on another, also they have a shared set off noticeboards of which all networks have a copy (they "gossip" to each other about any new articles so these get spread round every network's set of newsgroups). Another system called the world wide web allows documents to be held on one computer but all the networks can call up that document from its location info, and one document can send you straight to another it is referring to on another computer so this is all one big web. All the Court needs to know is that, given the identifying information on an article or web-page, it can send a computer knowledgeable clerk to print off a copy. Because these are only text files anyone could have typed in, it is often difficult to prove for certain that a given person wrote them. However this is best dealt with by examination such as "to the best of your recollection did you write this," "if you can't remember then is it at least the sort of thing you would write," and "can we go ahead and question you about the views expressed in this article on the safe assumption they are your views." Some authors, including Bob Minton, often include at the bottom a digital signature -- a screed of numbers that verifies both that the article text is unchanged and the author was Bob Minton. It is not relevant to know how this works, merely that the aforesaid computer- knowledgeable clerk can be asked "is that article signed by Bob Minton" and will be able to answer with certainty yes or no. 012. BACKGROUND ON SCIENTOLOGY WRITINGS. A key question in the case is to what extent do scientology writings need to be admitted as evidence. The first amendment would say that a secular court cannot rule on what scientology beliefs should be, nor how the church should run its own internal business not involving the rights of others. Scientology practices *do* come into question when -- to the extent, not that scientology claims, but the extent the court rightly finds on fact -- they determine secular behaviour amounting to a civil wrong. The conduct of scientology both spiritually and practically is mainly based on a large collection of dated instruction letters from its now-deceased founder L Ron Hubbard, perhaps analogous to the epistles from Paul to the early Christian churches. One division is ADMIN(-istration), comprising HCOPLs -- Hubbard Communication Office Policy Letters -- in green ink on white paper. These are collected together in about twenty Green Volumes, complete with an Admin Dictionary giving definitions of Hubbard's jargon words culled from the various HCOPLs. The other division is TECH(-nology), which outsiders would call religious doctrines, as HCOBs -- Hubbard Communication Office Bulletins -- in red ink on white paper. These are collected together in twenty or so Red Volumes, complete with a Tech Dictionary. However some areas are described as Tech which outsiders would consider organisational policy such as forcefully harassing opponents, disconnecting members from relatives who oppose their membership, or locking up members who go crazy on courses and demand to leave. It might be useful if a set of green and red volumes were available; not, heaven help us, to enter the whole shelf-ful as evidence, but as a source to check any issues of scientology writings which legitimately arose. A lot of scientology consists of paid-for courses either in scientology "tech", or to carry out particular "hats" (job functions) in the organisation: these are in practice mostly HCOBs or HCOPLs collected together in a folder. Finally, it is specious to make the excuse that some policies are old; why does Scientology collect them together, and still cite them, if so? Policy asserts that L Ron Hubbard is Source of all scientology knowledge and that nothing is over-written unless he personally alters it. It should be made clear that Hubbard was both prophet and chief executive of the Scientology movement, but Miscavige is only the chief executive: he has no power to say "Hubbard was wrong so I am altering this." All he is supposed to do in complete Hubbard's attention by perhaps gathering together and re-editing unfinished works, or amplifying on what Hubbard has already done. All Tech folders begin with an HCOPL "Keep Scientology Working" which demands that the student smash aside all unauthorised variation of Scientology, and the policy called Tech Degrade makes it an offence to downplay a bulletin simply because it is older. All Hubbard instructions continue in effect indefinitely, unless Hubbard himself made a later alteration. The same attitude also applies to administrative policies: no variation or deviation. 013. LEVELS WITHIN SCIENTOLOGY. There are several aspects to someone's position in Scientology. Generally you ask about their "processing level", which means what (tech) courses have been done on them. It goes through grades 0 to 7, to Clear, and then OT-Levels 1 to 8. They would then know about the scientology tech in those courses: when someone is OT3 or above, they are fairly advanced in the tech. But they probably have also learned to audit, i.e. teach material to others, and describe themselves as a Class so-and-so auditor. Someone who can TEACH OT3 is a class 8, and they know more about the tech in that level than someone who has simply been taught it. But these things are not the same as rank or job status. The Sea Org is a hierarchical body with military style personal ranks. If somebody is say, a Lieutenant Commander, that is a fairly high rank. This is separate from the job they do. They might have a post as say, Head of Public Relations in OSA International. If they were only a Petty Officer and the job Required a Lt Cmdr, then they would be given a temporary job rank (brevet rank) of Lt Cmdr lasting only so long as they held that job, so they had the necessary rank to give orders to their subordinates in that department. Questions about "did you how that department was managed" or "were you on Miscavige's personal staff" relate to job seniority rather than anything else. 014. BROOKS TESTIMONY. We have analysed a sample day of Ms Brooks testimony for inconsistencies against itself or against facts on public record. Many of the problems with it are the same as those with her affidavit, such as persistently mischaracterising the role of an expert witness. The one outright falsehood is her statement that Mr Miscavige is not "Head" of the Sea Org, which can only be sensibly parsed as saying he is not it's personal leader. He is. Scientology has many times touted him as the Captain (i.e. leader of a large ship) of the Sea Org which is the highest rank in it, though Hubbard later promoted himself as Commodore (i.e. leader of a battle group). He is the supreme leader of the sea Org, undoubtedly: the defendant has said this many times, and is estopped from denying it in this trial. At(P126) Mr Brooks extends her earlier false answer by saying the Sea Org is not the kind of Organisation which has hierarchy or a leader... 1 Q You indicate there, "I knew there really was no 2 such thing as head of the Sea Org, but Dandar thought it 3 would work as a legal maneuver." What did you mean by that? 4 A Well, the Sea Org is a -- is not a hierarchal 5 thing. The Sea Org is -- the Sea Org is something that 6 people join in Scientology when they want to dedicate their 7 whole life to Scientology. And they sign a million-year 8 contract, and it's a very strong commitment. It is a uniformed paramilitary group with pseudo-naval ranks, for Xemu's sake. How much more hierarchical can it get? The hierarchical structure of the Sea Org is discussed in recent testimony of Robert Vaughan Young in the Wollersheim case (ATTACHED), where the personal and brevet Sea Org ranks of senior CofS officials are tabulated, showing that it is a hierarchical group. Miscavige is the only one with the highest personal rank of Captain, though he denies in testimony that he uses this to give orders to others with a lesser personal, rather than brevet, rank. So Ms Brooks is lying like a cheap rug, and should be sanctioned for it. 015. WHAT KIND OF BODY IS THE SEA ORG? I think the best explanation for the nature of the Sea Org is -- meaning no disrespect to the Third Reich here by comparing it with Scientology -- that it is an Elite Corps. The Third Reich was meant to be under the personal command of its Fuhrer (meaning Leader), and working to the ideology of the NSADP. The way this was done is that Hitler has around him an S.S. or ShultzStaffel (meaning Elite Corps). These were an elite group, in their own special uniforms, of the people most fanatically dedicated to the ideology of the Party and the person of the Leader. The thing was that -- apart from a few celebratory rallies -- the Elite Corps didn't get together in one place and do practical Elite Corps tasks, the way the Army gets together in one place and does practical Army Tasks or a City Hall gets together in one place and does City Hall tasks. Rather, the way he made sure things were done according to the will of the Leader and the ideology of the Party was that there was a leavening of these fanatically dedicated Elite Corps everywhere in each City Hall or Police HQ or whatever, making sure things were done the Leader's way and per Party ideology. If somewhere wasn't doing this efficiently or according to instruction, he fired off a bunch of Elite Corps people to go down there and get them back on track. This is exactly how the Sea Org works. In time there were also entire Elite Corps Police units, and Armed Elite Corps regiments of the Party parallel to the official army of the nation. In Scientology these are called Sea Orgs, organisations staffed entirely by Sea Org members. Scientology has something called the Office of Special Affairs, i.e. the Inquisition (for harassing apostates and critics), which has a section in each org. But the Office of Special Affairs International in Los Angeles, which is presumably here Ms Brooks worked, is a Sea Org i.e. staffed entirely be members of the sea organisation. An Org is a branch of Scientology in a particular location or carrying out a particular function like OSA-INT. Originally the Sea Org where the trusted people gathered around him in the Org on his ship, the converted cattle-ferry Apollo. They were sent off from the ship to be a leavening of dedicated people in each of the big Orgs elsewhere, making sure things were done per the Leader's will and per Scientology ideology. Some people call them the "Damnation Navy" because they are like the uniformed Salvation Army, only instead of befriending people and giving help they are about controlling people and extracting money. 016. CONCLUSIONS ON BROOKS. Around pages 40 to 78 she tries to forward the idea there was improper control of the case and, on the whole, fails to substantiate it. At 79 she raises the idea of End-Of-Cycle in the Prince affidavit, and at 91 the fifth amended complaint based on it. At 107 she perjures herself about the nature of the Sea Org, re the addition of Miscavige to the complaint. At 112 she discusses whether Miscavige was likely to have been told of Lisa's detention. We argue that step zero of the Introspection Rundown has secular implications which go to corporate responsibility for the death. At 136 she discusses the purported secret agreement which only Brooks and Minton even say existed. At 143 there is a recess ending VOL.1. At 149 she continues about this purported agreement, and at 159 its concealment in deposition. Particularly at 161 onwards we need to separate events related from her self-serving interp- retation of them. At 166 she talks about removing hard drives, so that abusive discovery could not gather intelligence to harass everyone who approached LMT as client or donor. At 171 they have given such hostages to fortune that they cannot just withdraw cleanly. At 173 Ms Brooks pressures the dead girl's family to drop their case in order to save her ass, and when at 177 they refuse she orders herself, Minton and Prince out of the case. Mr Dandar reacts by filing a motion for sanctions over the framing of Jesse prince on a drugs charge. Minton continues paying Prince, until Prince falls out with him over Minton testifying further to his second affidavit. At 186 the concealment of cashier's cheques is discussed. At 194 Brooks advances the silly view that Minton made further funding to shut up tittle-tattle on the Internet which hurt his ego. At 206 the code-name "fat man" is raised, and Dandar's purported role in coaching Minton to make false denials of the cheques. At 216 Brooks and Minton have settlement talks with Mr Rosen. When timelined the events look as follows: on March 24th Minton signs a second affidavit written for him by Scientology, and on the 28th Brooks does likewise. They then have settlement talks with Scientology. On the 29th they tell Dandar they are going to talk to Scientology. On the 30th, the second affidavits are filed, and at hearings on the 6th and 9th testified to; on the 10th they go to Wally Pope's office to discuss what further they must do. On the 12th, there is a row with Mr Prince, and they cease to pay his monthly expenses. That brings us to the present hearing on May 6th, about three weeks later. The signing of the second affidavits before the meeting which supposedly arranged them is rather suspicious. 017. MINTON TESTIMONY. We have analysed a sample day of Minton's testimony for inconsistencies against itself or against facts on public record. Minton's testimony closely follows the affidavit someone wrote for him and he signed. He is supposedly making a true admission of some grand conspiracy against Scientology which he has somehow been induced to sign; Minton signed the affidavit written for him five days before Brooks signed the affidavit written for her (which seems largely an afterthought designed to corroborate the main fabrication). The Minton version straightforwardly parades a list of people in legal conflict with Scientology whom he helped, a series of payments to the wrongful death case, a list of people who assisted him at LMT and so forth, as if all these lists added up to something. And indeed they can be trumped up into a RICO action by a Corporations with deep pockets and evil but efficient lawyers, which would take a lot of time and money to defend -- were Mr Minton not persuaded against defending it by, in his own admission, threats that his wife and children will be killed or injured if he does not roll over to it. 018. WHAT IS THE CONTENT OF THEIR TESTIMONY? It is worth first considering the affidavit written for Ms Brooks and the testimony she gave based on it, because this takes us forward into specifics. What shines through it is the devious and unscrupulous character of Ms Brooks as it is directed, first against the alleged Church then for the alleged Church, but always toward what currently advantages Ms Brooks. She is always trying to manipulate someone, or failing that to have someone else manipulate her current target: will Bob please persuade Dell to drop the case to save her (and Bob)? will Ken please persuade Bob to stop funding to save her ass? will Dell give up legal redress to get her (and Bob) out of trouble? And so forth. But earlier, if anyone is keen to polish the truth to make the likely but unproven involvement of Miscavige more provable than it really was, it was Ms Brooks. Not only that, she manipulated someone else she found pliable -- Jesse Prince -- until he was prepared to say, and believe, things Brooks was clear in her own belief were false, i.e. she suborned perjury. To put the cap and bells on it, she was then the one least scrupulous in how far she would lie to reverse that testimony: that is, she knew for personal participation (as Bob did not) that Miscavige was the sole individual of the highest personal rank, that of Captain, in the Sea Org and was its personal leader. She even goes so far as to say that the Sea Org, an organisation with personal and brevet ranks, does not even have hierarchy. Would she know a scruple if one bit her on the ass? Probably not. Close reading this stuff after a while induces, so I am grateful to the newsgroup for spotting how, in yet another piece of manipulation, she went to Bob Minton's lawyer behind his back and started a settlement which she then induced Minton to endorse (p22): 7 And I got in touch with his attorney, Bruce Howie, 8 in -- I think probably as early as January -- 9 Q Of this year? 10 A And -- of this year, of 2002. And told Bruce that 11 I wanted to have him approach Scientology for a settlement 12 with Bob Minton, and asked him for his opinion about that, 13 or whatever. We had several conversations about it. 14 And AFTER TALKING TO BRUCE, THEN I approached Bob 15 Minton and I told him that I wanted him to authorize me to 16 have Bruce Howie to approach Wally Pope -- 019. So, where does Lady MacBeth's testimony lead us? First of all, Bob Minton made some donation's with cashier's cheques, which he paid for and caused to be issued on disbursement accounts held by a foreign bank rather than on his own personal or corporate accounts (and which therefore having nothing on the face of the document to say who paid for them). This alone is not illegal, though the most likely scenario is that the money came from foreign accounts on which tax was due and deliberately unpaid. Nobody will get to the truth of this, and hence of the perjuries grounded in it, until the tax authorities are prepared to immunise Minton from penalty on condition of full disclosure and payment, so that the fifth amendment no longer applies. Anyway, it is logical that the impulse to conceal the origin of these payments came solely from Minton and Brooks. Because of pressure to disclose these payments, Minton and Brooks eventually made statements admitting the existence of these cheques which exist, and of a "secret agreement" which does not exist. At least the court says so: 19 MR. DANDAR: Move to strike. 20 THE COURT: Granted. 21 I'm going to tell you it doesn't. I'm going 22 to tell you that there's no court in this world, 23 including this Court or any other court, that is going 24 to suggest that whatever was going on here was an 25 agreement. So there. 020. The connection between the two is as follows. The alleged Church and its evil but efficient attorneys had material written for Minton and Brooks to sign in which the list of cheques, and the concealment of the cashier's cheques, is purported to be improper control of the case. This purported control, on examination, centres around the same two meetings where nothing improper happened. It is like scenery flats on a movie set: the biggest problem for liars is that they cannot invent more and more depth of consistent detail to back up their few prepared assertions. Especially when there are two liars to co-ordinate, who are not supposed to consult with each other. At any rate, the sequence seems to be that Stacy is alarmed about the risks to Stacy (and Bob) of continued involvement and tries to drive Bob out of it... when that doesn't happen, she tries to manipulate the dead girl's family to drop their case to get Stacy (and Bob) out of trouble... when that doesn't happen, she orders all her minions out of the case. The culmination of this is that they not only recant earlier testimony but Bob writes his second affidavit, then five days later Stacy writes her second affidavit to back it up, then they negotiate with Scientology about what will go into their new affidavits, then they tell Dandar they are about to negotiate with Scientology; or at least, this is what date-lining Stacy's testimony seems to suggest. Stacy makes obviously false statements about Miscavige and the Sea Org. Bob testifies to a secret agreement which the court determines does not exist. The overall purpose is to frame Dandar with perjury and improper conduct; the cheek of it all is breathtaking. 021. What could be the nature if the settlement between those two and the alleged Church? Fortunately we have it as an exhibit: "NOTES FOR MEETING IN SANDY ROSEN'S OFFICE [Exhibit 191]". Every assistance to a person in legal conflict with the alleged Church is considered an attack: first testimony must be withdrawn, second contrary (false) new testimony must be entered to harm the case, third and every penny put into the case -- hence causing a similar cost to the alleged Church in countering it -- is to be repaid to the alleged Church. Beyond that, Minton is to make false admissions to substantiate the Church's insane contention that there is a grand conspiracy against them, which it will pursue with RICO action: that is, Minton will facilitate with perjury the pursuit of false RICO charges against each of the people he has assisted, as well as bending over and admitting to false RICO charges against himself. 022. What can have induced such Minton to make such an ignominious turnaround? Well, circumstances strongly suggest it has something to do with tax. For the avoidance of doubt, (1) European countries will often release citizens living abroad from liability to tax if they are taxable in their current country of residence, but (2) a U.S. citizen is never released from the duty to report income and pay tax. In order to remove any competitive disadvantage, citizens are discounted tax liability to balance what they have paid in foreign taxes at least up to $80,000. It seems likely Minton has earned far more than that without declaring it. The only way to get the truth of this is if the tax authorities will immunise him from penalty, in return for full disclosure of income and full payment of tax due, so there is no longer a 5th amendment privilege. Mr Minton has also said that the lives of his wife and children are at risk, and it would not beyond the alleged Church to arrange for third parties to have the assassinated if he does not cooperate. 023. Seems a propitious number to conclude this section. Brooks and Minton have overall, under whatever pressure, signed new affidavits written for them, now truthfully admitting the existence of the cashier's cheques and falsely purporting to admit a secret agreement which does not exist, in order to frame Dandar with charges of perjury and improper conduct to sink the case. In sum, it stinks. They should not get away without at least their 6 months less a day in jail for it. SCIENTOLOGY'S OVER-ALL CONDUCT IN THE MATTER OF LISA MACPHERSON. 024. The first part of our analysis was specifically about how the alleged Church obtained an ignominious pants-down turn-around from two of the plaintiff's main witnesses or supporters. In the second part we want to establish a pattern of conduct by the alleged Church in the whole matter of Lisa MacPherson's death under their care at their headquarters building, which fits in with their general conduct in other cases and ultimately with the policies laid down by their insane founder L Ron Hubbard. Where there is cause to examine conduct in the present case, we will therefore at least point out for information sample instances of similar behaviour in earlier cases. 025. In order to show the whole picture, we will sometimes refer to press or television reports. We are aware that any attempt to bring such material as evidence would be laughed out of court: not simply because there are questions about accuracy, but because it is not best evidence (to prove the content, one would have to summon the writer's firsthand sources to attend as witnesses). Nevertheless, it has a role at least for information in showing the whole picture, and is indicative what areas need to be explored. 026. How did the Scientology Corporation react to the death of Lisa MacPherson under their care at one of their main facilities? To get a clear view, we need to compare it with what the reaction might be if this happened to a travel corporation on one of their holidays, or a building corporation if one of their designs had fallen down and killed people. Even the most mendacious corporation would generally realise that the public expect it to appear genuinely sorry about causing someone's death, and eager to make amends, albeit their attorneys would have an agenda of paying what they can get away with to get the matter settled and forgotten soon with minimum harm to them, while also pushing to keep the damages no higher than needed for this and talking sorrowfully about how nobody would benefit if the matter was pushed to lengthy trial. This is not the way Scientology handled it. Their whole approach has been to treat any criminal or civil complaint about Lisa's death as an unjustified attack, and respond with all-out war upon the complainants to bully their way out of suffering any consequences for Lisa's death. 027. SCIENTOLOGY'S USUAL RESPONSE TO CENSURE. If Scientology us taken to task by external sources for injuring people or taking their money, the alleged Church's response is that (a) its actions are by definition right, and (b) any censure is to be met by furious counter-attack. For example... HCO POLICY LETTER OF 15 FEBRUARY 1966 ATTACKS ON SCIENTOLOGY (Additional Pol Ltr)[....] This is correct procedure: (1) Spot who is attacking us. (2) Start investigating them promptly for FELONIES or worse using own professionals, not outside agencies. (3) Double curve our reply by saying we welcome an investigation of them. (4) Start feeding lurid, blood sex crime actual evidence on the attackers to the press. Don't ever tamely submit to an investigation of us. Make it rough, rough on attackers all the way. You can get "reasonable about it" and lose. Sure we break no laws. Sure we have nothing to hide. BUT attackers are simply an anti-Scientology propaganda agency so far as we are concerned They have proven they want no facts and will only lie no matter what they discover. So BANISH all ideas that any fair hearing is intended and start our attack with their first breath. Never wait. Never talk about us - only them. Use their blood, sex, crime to get headlines. Don't use us. This is clearly the approach applied to Lisa MacPherson's surviving relatives and to the Lisa MacPherson Trust, as can be discerned throughout the affidavits written for Brooks and Minton to sign. Please note that a Policy Letter is not "religious doctrine" but organisational policy; nor is it a matter of a religious organisation carrying out its own business in its own way, but is an expressed intention to harm the rights of others by carrying out unlawful acts. 028. In a follow-up HCOPL of 18 FEBRUARY 1966, Hubbard identifies actions which have had poor, moderate, or strong effectiveness against criticism of its wrongdoing, top of the poll being.... G.3.1. Investigating noisily the attackers. "Noisy Investigation" is a piece of Scientology jargon with a fairly specific meaning, and it would be interesting to see how their own admin dictionary defines it. It is mentioned in the testimony or Mr Liepold on 19/may 2002, page 390, as follows... 1 Trust website under the description: "Declaration of Stacy 2 Young dated December 14, 1994. Two high-level 3 Scientology --" I guess "-- Rinder and Mike Sutter, offer to 4 pay Stacy, and her husband at the time, Robert Vaughn, for 5 their silence. When they refused, Scientology starts the 6 fear game attacks, et cetera. They do a noisy investigation It is defined in.... HCO EXECUTIVE LETTER OF 5 SEPTEMBER 1966 Further to HCO Executive Letter of 3 August 1966, Cathy Gogerly, HCC Area Sec, Adelaide, Australia, has given details of how to go about dealing with attackers of Scientology. " ... Here's what you do. Soon as one of these threats starts you get a Scientologist or Scientologists to investigate noisily. You find out where he or she works or worked, doctor, dentist, friends, neighbours, anyone, and 'phone 'em up and say, "I am investigating Mr/Mrs .......... for criminal activities as he/she has been trying to prevent Man's freedom and is restricting my religious freedom and that of my friends and children, etc". You say now and then, "I have already got some astounding facts," etc., etc. (Use a generality.) It doesn't matter if you don't get much info. Just be NOISY - it's very odd at first, but makes fantastic sense and WORKS." Best and love, Ron. In other words, you go round implying on no evidence at all that your victim has committed the worst crimes you can think of; what charming behaviour for an alleged Church which hides behind its religiosity. Again, it is not doctrinal but administrative, and not private internal arrangements but a deliberate policy of unlawful behaviour impinging on the rights of others. 029. Scientology's favourite method of dealing with any rebuke for its wrongdoing is to ignore the content of the reproof and attempt to destroy the reputation of the speaker by personal attacks. The reference (actually from a press article, but it names the primary source material for checking) is in: Scientology: A Long Trail of Controversy, By Robert Gillette and Robert Rawitch, Los Angeles Times, 27aug1978 "Don't ever defend. Always attack ...Only attacks resolve threats," Hubbard advised his expanding worldwide organization in a policy laid down Aug. 15, 1960. "If attacked ... always find or manufacture enough threat against them to cause them to sue for peace." "People who attack Scientology are criminals," Hubbard wrote in later church documents. "Politician A stands up on his hind legs in a parliament and brays for condemnation of Scientology. When we look him over we find crimes -- embezzled funds, moral lapses, a thirst for young boys -- sordid stuff." [......] A subsequent May 30, 1974, confidential Scientology board policy letter entitled "handling hostile contacts/dead agenting," incorporates part of the church's earlier policies regarding attacks and specifically attributes to Hubbard: "If there will be a long-term threat, you are to immediately evaluate and originate a black PR campaign to destroy the person's repute and to discredit them so thoroughly that they will be ostracized." In particular with respect to lawsuits... In a 1955 publication by Hubbard still sold in the church's bookstores, he said the purpose of a lawsuit [...] "is to harass and discourage rather than to win." The U.S. legal system in particular believes that people are equal in the courts if they can spend as much or as little as they have, without significant state assistance for a poor defendant to ensure equal justice, and Scientology exploits this to the maximum. They have a long history of fighting courtcases -- whether suing or defending -- as pitched battles, which are stretched out with endless motions and documents to run the opponent out of money rather than get a just outcome, and which are fought out not on the issues but by attacking the opponent, his witnesses and his attorneys in an attempt to discredit and professionally destroy them as persons able to act against the alleged Church. Often the method is to find OR MANUFACTURE evidence of crimes, such as having a blackmailed witness sign a false affidavit framing the opponent's attorney for perjury. Note that it is specifically cited as legitimate to target a hostile member of congress or parliament and investigate them for blackmail material on adulterous affairs (moral lapses), or if they are homosexual to create material alleging sex with under-age boys. Needless to say these matters are not doctrine but policy, and not private conduct but public policy of acting unlawfully; as is the Introspection Rundown. Both of those also absolutely have application to the present case. 030. PRESSURE PUT ON PROSECUTORS. Our contention, which we hope the Court or the plaintiff may wish to raise, is that in the whole matter of Lisa MacPherson both criminal and civil there has been a systematic pattern of conduct, based in the written policies of their founder and consistent with their behaviour in other cases, where Scientology have conducted the case like a war by first putting improper pressure on an opponent's witnesses to change testimony, then using this to bring down the opponent's attorney and secure an unjust dismissal of valid suits against them. In such a context, we raise interaction between Mr Miscavige as leader of the alleged Church and Mr McCabe as District Attorney as demonstrated in the exchange of letters between them: we believe these letters should be entered in evidence of this, and enclose them for reference. Incidentally it is Church policy that a crisis such as potential criminal charges against FLAG should be dealt with at the most senior possible level and, if Mr Miscavige is not personal leader of the Church, it is a strange coincidence that he is the official selected to deal with the District Attorney. 031. Near in mind that what follows is a letter to the State Prosecutor, from the Chief Executive Officer of a wealthy corporation which has just killed one of its customers by neglect at its Headquarters building and seeking to get criminal charges dropped. The approach is entirely consistent with that outlined in (25, 26, 27); there is not a word of contrition. The prosecution is simply treated as an unjustified attack, and Miscavige seeks "a peaceful resolution to the charges your office has brought against my religion": he wants to "pursue peace." This letter of jan/29 1999 follows two earlier meetings pressuring for settlement on 18 and 23/nov 1998. Indeed he had been trying to "bring an end to counter-productive hostilities and prejudicial treatment of the Church and Scientologists" and regarded various criticism by the City of Clearwater as a conspiracy to persecute the alleged Church. He quotes an interview he gave the Saint Petersburg Times where he felt "that Clearwater is the scene of 'possibly the last long-running conflict' for Scientology. He said he wants to take 'big steps' to end hostilities there." He does wish to, in effect, buy off prosecution by a large donation to local charities. He says "The seriousness with which the religion takes on that responsibility is best exemplified by my personal participation"; the implication being, "as personal leader of the alleged Church." He concludes that he "can understand the need in some criminal proceedings to leave a person with a 'guilty' record, the purpose being to taint the person with a stain he can never remove. That is precisely why the Church cannot accept a plea as a form of justice. A church is not like another corporation" But Scientology is precisely a dodgy pyramid-selling corporation disguised with a thin veneer of religion. These are not the words of his enemies: Miscavige condemns himself, and his money-grubbing alleged Church, out of his own mouth. I doubt that anyone would even dare address a State Prosecutor with this kind of contempt in other countries. But the DA's office is under-funded and under pressure to go for the easy targets, which makes it precisely open to this kind of corrupt pressure. 032. The District Attorney rejected this approach as follows: "I have received your letter of January 22, 1999 as well as the memor andum from Williams & Connelly to which your letter refers. While I do not agree with all your comments concerning our prior discussions, I will concentrate on responding to the primary issues raised in your written proposal. You suggest that your intent is "peaceful" and, in deciding to respond in detail, we have taken you at your word. The initial "offer" made to Mr. Crow and Mr. Burgess, however, requested outright dismissal of the charges in exchange for a $500,000 donation to a local emergency medical care trust fund, repayment of investigative costs, enactment of certain corporate policies, and a somewhat ambiguous amount of "restitution" which was intended as some sort of reimbursement to my office rather than payment for the permissible financial losses, if there are any, suffered by the victim or her estate. Your oral proposal made clear that if we failed to accede to the requested dismissal, a "holy war" of litigation would result, lasting years and winnowing our office's human and financial resources." [This, in particular, reveals the main threat of running the DA's office out of money, as the CofS have since tried with plaintiff]. "I rejected this proposal but acceded to your request for a more direct discussion between you and your attorneys and me and my staff. Your offer in this second meeting restated essentially the same proposal with the caveat that only one charge (the second degree felony of abuse of a disabled adult) need be immediately dismissed. You were willing to accept Pre- Trial Intervention on the lesser felony of practicing medicine without a license, which, if successfully completed, would result in dismissal of that charge as well. After reflection, I also rejected that offer, and thoughtfully considered whether I should make a counter proposal. Ultimately, I decided not to do so." 033. This conduct of attacking a State Prosecutor to get rid of valid charges simply embodies the "Dead Agent" tactic of trying to demolish the critic rather than enter into the issues of just criticism, and it is a systematic pattern of conduct they have carried out in other cases before now. While this is both abroad, and initially indicated by press stories rather than primary sources, the most striking example is that of regional Crown Prosecutor Casey Hill: Canada court upholds libel suit against Scientology North American News Report, July 20, 1995 17:53 E.T. OTTAWA (Reuter) - Canada's Supreme Court Thursday upheld a million-dollar libel award against the Church of Scientology in a case that saw writers and news organizations siding with the church. Casey Hill, a former Ontario prosecutor, sued the Church of Scientology for accusing him of acting improperly in connection with a raid on church offices in Toronto in 1983. Careful examination of the facts show a systematic campaign to professionally destroy the regional prosecutor (roughly equivalent to a deputy state attorney general) in accordance with the Church's Dead- Agenting. Which is not doctrine but policy, and not internal but a systematic intent to unlawfully attack the rights of others. 034. PRESSURE ON THE PROSECUTION WITNESSES. Scientology's next move was to pressure the opponent's main witness into changing her testimony: [press story] Bay News 9 - Tampa Bay News Station Title:Criminal Charges Dropped Pinellas/Pasco County Greg Davis (Voiceover): The charges stem from the 1995 death of church member Lisa McPherson. She died at the Fort Harrison Hotel. McPherson's relatives and vocal critics of the church organization say she died because she did nor receive proper medical care. Court records show the medical examiner originally shared that opinion. Leading the Pinellas/ Pasco State Attorneys Office to file the criminal charges. But the medical examiner recently changed her opinion about the cause of death. In court documents filed Monday, the Assistant State Attorney prosecuting the case dropped the charges because of the quote, "inability to prove critical forensic and causation issues beyond and to the exclusion of a reasonable doubt, as a consequence of the medical examiner's change of opinion." Scientology put considerable pressure on the prosecutor's main witness. While there is no evidence they made threats of force, they badgered her regularly with inches thick of opinions bought from their own experts to make her once express a doubt that Lisa MacPherson's death by blood clot to the lungs might not be definitely caused by the dehydration when she was held for 17 days without food and drink. Once this was said, the prosecutor's case collapsed. But that was not the end of the consequences for Joan Wood. First, she lost the election to continue the job of Medical Examiner. Then she disappeared from public view. Our understanding is that members of the plaintiff's legal team have talked to members of medical and administrative staff at Morton Plant Hospital who have dealt with Joan Woods is currently on the psychiatric ward. We also have a very good idea of how, in reality, her psychiatric breakdown was caused. Unfortunately there is little or no chance of finding any supporting evidence for this so it would not be proper, even though it is god's own truth, to raise it in the hearing. Sometimes that happens: in reality people carry out wrongdoing, but there is no evid- ence to prove it, so they are not found guilty and not punished for it. This appeared recently on the Internet: Date: 26 Aug 2002 03:35:57 GMT Subject: On Joan Wood ( from anonymous source) Message-ID: <20020825233557.01759.00002638@mb-de.aol.com> No doubt you have read the article in the SPT about Joan Wood surfacing. Her story is all a lie. She has a mother in an institution, I don't know which one but it was a mental type as I remember, and the Co$ was using the mother as the leverage. Somehow they had found a way to meddle with Joan's mother and it was fear for her that turned the daughter. Joan also spent a number of months at the Morton-Plant hospital in Clearwater. She was in the pych ward, she must have had some friends pull some strings for her to stay there because normally that ward is for short durations only. I wish I knew more but anyway this is the way it went down regardless of who says what. We cannot vouch for whether or not the new information is accurate. 035. THE WRONGFUL DEATH CASE, Next we come to the present, wrongful death, case. This was also carried out like a war which ignored the issues and set out to destroy the dead girl's family, their witnesses, and their attorneys as a credible force against Scientology. Part of this strategy is endless abusive discovery. Removing the hard drives from the Lisa MacPherson Trust saved a lot of people from being given up to Scientology attack. Names of anyone who ever offered them assistance or funds would have exposed those people to harassment by such tactics as noisy investigation. Names of every family who ever sought help -- a topic Mr Fugate was quick to move Bob Minton off -- would have exposed all those families to pressure, and threats that their relative in the cult would have been ordered to Disconnect from them. Finally, the Trust was almost certainly in touch with senior whistle-blowers inside the alleged Church, who could be in serious danger if given up to the tender mercies of current management. Abusive discovery is a regular feature of Scientology litigation. They have repeatedly sought to undermine Graham Berry as an attorney for some of their opponents. When he sued one of their officers for defamatory statements, the response was a discovery request for all sexual materials he owned... Re: Berry v. Barton, et. al., LASC; Case Number 186168 Dear Ms. Reeves: This letter is to serve as the meet and confer on the issue Of your First Set of Requests for Documents Propounded to Plaintiff Graham E. Berry. [....] I realize that truth is a defense to a claim of defamation. However, the disputed statements in Mr. Berry's complaint are much more limited than your requests. For instance, several of the disputed statements involve alleged sexual activity with underage boys and alleged sexual activity in public. Yet you are seeking "All sexual paraphernalia, including, but not limited to, toys, manikins, riding crops, whips, dildos, collars, straps or similar devices in your possession, custody or control" [Defendant Barton's First Set of Requests for Documents, No. 65]. I regard this request highly unprofessional and am appalled that a partner in as prestigious a firm as Paul, Hastings, Janofsky & Walker, L.L.P. would act in such an indecent manner. Assuming my client owns any of the foregoing requested items (I am sure that he does not), my client is not seeking damages against your client for statements regarding the fact that my client may or may not have sex. The disputed statement, specific- ally accuses my client of committing statutory rape. The purpose of discovery is not to entertain your own personal prurient interests in the sexual activities of others. Despite any other prejudices you may have, whether or not my client owns toys of a sexual nature is completely irrelevant and not likely to lead to the discovery of admissible evidence on the issue whether or not your client said that my client had sexual relations with underage boys. The case is not being fought on the issues but to personally destroy the opponent; discovery is being used, not to uncover relevant facts, but to humiliate and belittle the other side's personal life. 036. PRESSURE ON OPPOSING WITNESSES. In the abortive criminal charges, the People's witness Ms Woods was pressured into changing her testimony so the People's case would not stand up. When the dead girl's family then launched a civil suit, the defendant then proceeded to blackmail Ms Minton into Ms Brooks into singing new, false, testimony designed to frame the Plaintiff's attorney for perjury. The testimony of Brooks shows that Minton signed the affidavit written for him, then four days later she signed the affidavit written for her, then they held negotiations with Scientology as to hat they were going to sign, then they told Mr Dandar they were about to go into negotiations. Again, pressure on an opponent's witness to change testimony is not a new feature of Scientology litigation. We do not know exactly what was done to Minton to obtain his present ignominious turn-around, but his own TIME-LINE OF HARASSMENT OF BOB MINTON gives some clues. Likewise there was an attempt to remove Mr Prince as a witness, by planting drugs in his house to set him up for an improper prosecution. To this we add that Dr Garko changed sides and became a witness for the defence, though not very fruitfully for them, in exchange for a release that they would not sue him; the logical inference is that they threatened he would be driven into bankruptcy with lawsuits whose purpose was "to harass and bankrupt, not to win" if he did not comply. 037. PRESSURE ON OPPOSING ATTORNEYS. The next target, after opposing witnesses have been got at, is to professionally destroy the opposing attorney. In this case, the false testimony got from Brooks and Minton by blackmail is being used to set up Kennan Dandar on false charges. Few attorneys will dare to take on the Scientology Corporation, because it pursues opposing attorneys to utter destruction. A small piece of its harassment of Graham Berry is quoted above, and he could witness to years of assorted attacks, including one where a senior attorney on the other side admitted in deposition that he paid a male prostitute for false testimony, yet that attorney was not sanctioned and Mr berry was. Certainly attorneys Dan Liepold and Ford Greene, who are witnesses in the present case. It is not a matter of one improper action in turning Brooks and Minton by blackmail: it is a consistent course of action carried on through the whole issue of Lisa MacPherson, as it has been through many earlier lawsuits, and is ultimately mandated in the official policy letters laid down by L Ron Hubbard. ||||| From: Anonymous Comments: This message did not originate from the Sender address above. It was remailed automatically by anonymizing remailer software. Please report problems or inappropriate use to the remailer administrator at . References: <20020903072001.30984.qmail@nym.alias.net> Newsgroups: alt.religion.scientology,comp.org.eff.talk,misc.legal Subject: (amicus) Z, Index Message-ID: <6593708272ee0fc7c02d9655df35beee@remailer.privacy.at> Date: Tue, 3 Sep 2002 13:04:05 +0200 (CEST) Mail-To-News-Contact: postmaster@nym.alias.net Organization: mail2news@nym.alias.net Lines: 27 Path: news2.lightlink.com!news.lightlink.com!news-out.visi.com!hermes.visi.com!eusc.inter.net!feed.news.nacamar.de!newsfeed.Austria.EU.net!newsfeed.kpnqwest.at!anon.lcs.mit.edu!nym.alias.net!mail2news-x3!mail2news-x2!mail2news Xref: news2.lightlink.com alt.religion.scientology:1550442 comp.org.eff.talk:105630 misc.legal:433655 INDEX: Am(A) Introduction Am(B) Source Documents [not included in print out, see court file] Stacy Brooks, second affidavit Stacy Brooks, testimony volume one Stacy Brooks, testimony volume two Stacy Brooks, our own summary of vols one and two Bob Minton, second affidavit Bob Minton, testimony volume one Bob Minton, testimony volume two Bob Minton, our own summary of vols one and two Am(C) MAIN BRIEF Am(D) Text Examination of second affidavits Am(E) Brooks Affidavit analysed Am(F) Minton Affidavit analysed Am(G) Brooks Testimony day one analysed Am(H) Minton Testimony day one analysed Am(I) Exhibits list Am(J) Sea Org ranks and hierarchy - R V Young testimony Am(K)"Long Trail of Controversy" - press articles worth skimming Am(L) Letter, from David Miscavige to District Attorney in full Am(M) Letter, from District Attorney to David Miscavige in full Am(N) On the issue of "Fair Game" Am(O) Scientology's War on the Judges, American Lawyer Magazine Am(Z) Over-all document list. ||||| From: Anonymous Comments: This message did not originate from the Sender address above. 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References: <20020903072001.30984.qmail@nym.alias.net> Newsgroups: alt.religion.scientology,comp.org.eff.talk,misc.legal Subject: (amicus) D, Text Analysis IV Message-ID: <9b0fbabb74d20d9974bfbbe60971e0bc@paranoici.org> Date: Tue, 3 Sep 2002 22:14:01 +0200 (CEST) Mail-To-News-Contact: postmaster@nym.alias.net Organization: mail2news@nym.alias.net Lines: 285 Path: news2.lightlink.com!news.lightlink.com!gail.ripco.com!fu-berlin.de!newsrouter.chello.at!newsfeed.Austria.EU.net!newsfeed.kpnqwest.at!anon.lcs.mit.edu!nym.alias.net!mail2news-x3!mail2news-x2!mail2news Xref: news2.lightlink.com alt.religion.scientology:1550575 comp.org.eff.talk:105632 misc.legal:433657 N woods, V that's, V regarded, V reaching, O predictably, N people's, O none, N motive, N merits, V looking, N legality, J latest, V intimidated, N ground, V granted, J formal, V express, V embarrass, N edge, V drawn, V dispatched, N decease, V crossed, N conspirators, N consent, N commonwealth, V challenge 0 0 0 0 0 0 0 0 0.02 0 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implicates, V implicate, V impinges, J identical, N homes, N hirsch, N hilton, N higgs, N heels, J harshest, V greeted, N grant, N gen, N furtherance, J frozen, J freestanding, N flyers, V fishing, J fertile, O fairly, V fails, V extends, N expedition, V exercising, V exceeds, N event, N equity, N entries, N eisen, J eastern, V dressed, N doors, N dissent, N displeasure, N dirt, N dimension, V dig, V determines, N determination, N destruction, V demands, V demand, V delve, N defenses, N debit, V dare, N curtailment, N cultinfo, V creates, J countervailing, N counselor, N core, O conveniently, V contend, J containing, J constitutional, N conservatorship, J comprising, N commissioner, N colleagues, J civic, N citations, N ch, N certiorari, N ceremony, N cazares, V cancelled, J callous, N calderbank, N brothers, V brings, N blanket, N berkeley, J belonging, V believes, V balancing, N backers, N aunts, V associated, V asserts, N ass'n, N arass, N antics, N analysis, V allows, J aggressive, J adverse, N accountant, V accompany, J absent, J abhors 0 0 0 0 0 0 0 0 0.02 0 0 0 J vast, N tuesday, N sic, V recover, J principal, V played, N pack, O overnight, N larry, N item, N image, O four, V forced, V extricate, V ensure, N distribution, V distribute, J dark, V cutting, V creating, V covered, J content, N confirmation, V conceal, V coming 0 0 0 0 0 0 0 0 0 0.02 0 0 V works, N wog, N wife, N veil, N uwe, N trustee, N treasury, V transferred, N terror, N sums, N sources, J solo, V sleep, J sick, V screamed, V runs, N rehabilitation, V refer, N pr, N positions, J orthodox, V organizing, N negligence, N moment, N messenger, J manual, J mad, N jim's, N integrity, V induced, N illness, J huge, N hemet, N governments, N gold, N gamboa, N fran, N failures, J external, N expansion, N empire, N earth, V drive, N directives, J defensible, N crusade, V connected, N commodore's, V commanding, N circle, N camp, J calm, N books, J blue, N bill, N beings, V audited, N assets, N aspect, N approval, N annie, J afraid 0.02 0 0 0 0 0 0 0 0 0 0 0 V wouldn't, V withdrew, N wire, N wilson, N voice, J vocal, N visit, N views, N videographer, J upcoming, J uneasy, J uncertain, N umbrella, N town, N tom, N suspicion, V suck, J stronger, J stern, N stephen, N starbucks, N spring, V speculating, N spector's, J skeptical, N skelton, V shred, N shirley, V shift, V setting, N segment, V screened, V scrambling, N scale, N saturday, V satisfy, N salary, N rsa, J ridiculous, J revealing, N retirement, N renege, J reluctant, V reincorporate, V reconfirmed, V reassure, V realizing, N reaffirmation, N radio, N quality, V purchased, N prize, N privilege, O privately, O privatel, V pressing, J predicated, J postmarked, N postings, J poor, N po, N photos, N phones, V phoned, V organize, O onto, O ok, J offshore, N observation, N obligation, N noses, N mute, N motel, N model, V misunderstood, J mired, O mine, J messy, N mediation, N masquerade, N manhattan, N manchester, V maintained, N lunch, N lmt's, N liebreich's, N leipold's, N lee, V learn, V laughed, V justify, N johnson's, N investors, V introduced, N interviews, J interchangeable, N innuendo, V initiate, V indicate, V increase, J impossible, V imparted, V ignore, N howard, N honor, N holmes, V hold, O hi, O henceforth, N hearings, N haverty, N greenway's, V gets, V gathered, V frustrate, V frightened, O formally, N fee, V featured, O favorably, J favorable, N fat, V extract, V expanding, N excitement, N examiner's, N examination, J european, V earning, N dollar, V dissolve, J disrelated, V disguise, J disaffected, J digital, N devices, N desperation, N deana, V cross, N criticisms, N coverage, V couriered, V couched, N couch, N contrast, N contradictory, N contingency, V consulting, V consulted, V congratulated, N concerns, J complicated, V complained, N club, O closely, N checkup, V chase, V characterize, N centerpiece, N cell, N caribbean, N cambridge, N bombay, N bicycle, N beneficiary, N beliefs, N bedore, V backtracked, V backtrack, N autopsy, J appreciative, N anybody, J anxious, O anonymously, N ann, V alleviate, V affecting, N advisors, O adequately, O adamantly, V accommodate 0 0 0 0 0 0 0 0 0 0.02 0 0 N writer, J worth, N wogs, V wields, N wdc, N warrant, J violent, V viewed, N version, J unincorporated, V trap, V transfers, N ties, N thousands, N tenure, N taught, O suddenly, N successor, O successfully, N stories, N statistic, N star, N soul, V screaming, N science, J sane, J ruthless, V reverse, N restraint, V refuses, V qualified, V pulled, N publication, V protest, N profanities, N posts, N pole, J painful, V oversaw, J organizational, N ops, J nineteenth, N newspapers, O near, N morrow, N meter, O maybe, J massive, V manipulate, V maintain, J loyal, V locked, J literary, V investigate, V invented, V induce, V includes, N heber, N harm, N hand, N guillaume, N guardian, N greed, N gordon, N geary, O furthermore, N function, N exterior, V exist, N executives, V edited, N dm, V dismissed, V discovered, N disaster, N deviation, N degree, V cuts, V criticized, V consisted, V confess, V comprise, N compound, J complex, V commands, V coerced, N choice, N calhoun, V busted, N bulletin, N branches, N bound, N booklet, N bomb, V blown, N aznaran, V audit, V appointed, N amnesty 0.01 0 0 0 0 0 0 0 0 0 0 0 V you've, V yell, N weiland, O weekly, N warfare, V walked, J vulnerable, N volcanoes, N victoria, N vicki, V verify, V vanish, J utmost, O unfortunately, O undoubtedly, V turning, V transported, V tow, V touch, N tolerance, O thoroughly, V thinking, N therapy, V terrified, N temper, O systematically, N symptoms, V surrounded, V suppressing, N sunset, V summoned, N subordinates, V studied, N sterling, N step, N stats, V spotted, V speaking, V snap, V sleeping, J significance, N shield, V sell, N sector, N sec, N scrutiny, N scripture, V scream, N scientoloay, N sandi, N sacred, N route, N robbery, V rising, V retained, V reserve, V researched, V remaining, N rebuttals, V realized, V reading, V reach, N ranks, V punished, N publics, J promotional, N projects, N programs, N professions, N problem, J precise, N practitioner, N population, N photograph, N passage, V parted, V overwhelmed, V overwhelm, V ousted, J original, V ordering, N orange, V operates, N ones, V observe, V obey, O normally, N news, N newport, N mistake, J militaristic, N middle, N method, N mayo, N match, N marlowe, N manipulation, V manifest, N lungs, N lrh, J loose, V located, V living, N lifetime, N liaison, V letting, N lesevre, N lawsuits, N labels, N kurt, V knows, N kitchen, V kills, J junior, N joyce, N jon, N jobs, N jentzsch, V investing, V interviewed, N interrogation, V interrogated, N internes, V injure, V increasing, N implant, V imagined, N hubbards, J hostile, N homo, V hit, V hiding, O herself, V hallucinate, N hall, V gutting, V letting, N guard, O geographically, J generic, N gears, N gang, V freeing, N foot, N finger, V fell, N federation, V feared, N expulsion, N explosive, N expertise, J excellent, N examples, N evils, N eulogy, N establishment, N epstein, V ended, N emptiness, J eligible, V educated, J ecclesiastical, V eating, N dogs, N dissemination, N disloyalty, J disembodied, N dictation, V dictates, V dictated, N diabetics, N details, V demoted, V degraded, N defamation, V dealt, N danger, O currently, N cswus, J crazy, N cover, N courses, N coup, V correcting, O corporately, V convince J coercive, N class, J civilized, N christofferson, V chooses, V changing, V change, N category, N catalina, N cards, N car, V can't, N broker, V breaks, N benefit, V behave, N contrivance, N contracts, J considerable, N comments, N collection, V becomes, N bang, N atom, N atack, V assumed, N associations, V arose, N arms, V approved, J animal, N aide, N advantages, N ads, N admission, N admin, V acquired, V accuse, N accusations, N acceptance 0.01 0 0 0 0 0 0 0 0 0 0 0 ENDS. ||||| Date: 3 Sep 2002 20:25:21 -0000 References: <20020903072001.30984.qmail@nym.alias.net> Newsgroups: alt.religion.scientology,comp.org.eff.talk,misc.legal Subject: (amicus) D, Text Analysis II Message-ID: Comments: Please report problems with this automated remailing service to . The message sender's identity is unknown, unlogged, and not replyable. From: Secret Squirrel Mail-To-News-Contact: abuse@dizum.com Organization: mail2news@dizum.com Lines: 920 Path: news2.lightlink.com!news.lightlink.com!gail.ripco.com!central.cox.net!cox.net!kibo.news.demon.net!demon!shale.ftech.net!news.ftech.net!peernews.cix.co.uk!news.itconsult.net!news.dizum.com!sewer-output!mail2news-x3!mail2news-x2!mail2news Xref: news2.lightlink.com alt.religion.scientology:1550577 comp.org.eff.talk:105633 misc.legal:433658 COMMENTS: In the next section on vocabulary usage, the most obvious fact which emerges is that faux-Brooks and faux-Minton are written in the same very consistent style. The following pattern is visible for small grammatical connectives (to, of, and, in that, was, he, on, for, by...) and for actions, objects, and qualities of a rather abstract kind (knew, told, number, person, clear, false). It conspicuously goes away for actions, objects, and qualities of a specific practical kind (employ, violate, letter, agreement, intentional, confidential). The word occurrences are listed as percentages of total. With simple connective words, nearly all of them have faux-Brooks and faux-Minton within one or two tenths or a percent yet the spread among the other files being two or three times as large; about half of them are bang on within one or two hundredths of a percent, with a much wider spread among the other files i.e. even between one genuine Brooks utterance and another. Several things could be done with a more sophisticated program. It would be interesting to calculate a correlation value between, say, faux- Minton and each of the other files. Perhaps this could be divided into correlations for Verbs, Nouns, adJectives, and Others (pronouns, conjunctions, prepositions...) then Total, as the Others are likely to show a particularly strong correlation. Even better would be to take Verbs+Nouns+Adjectives and Others for only the first 3 or 4 pages of very frequent occurrence, because the pattern is particularly striking there. Another might be to takes cases where [1] S2ND and B2ND are each nonzero but <= 0.08 and are <= 0.02 apart, and [2] StFm and/or BoPr are each <=1.2 and a further below the lower of the two or further above the higher of the two, then print out the 3 word contexts together with the preceding parenthesized paragraph number e.g. StFm: similarly S2ND: (18) only way out; (19) only people able; (47) only course of... B2ND: similarly BoPr: similarly This might show a pattern of particular words being used in, not just similar frequencies, but also similar contexts between S2ND and B2ND. CONCLUSION. Faced with this data, it is then possible for a lay person to make a second close reading of the documents and work out for themselves whether they feel -- grounded in such objective measures such as sentence lengths and word frequencies -- they feel fauxBrooks and fauxMinton are (OR ARE NOT!) by a single author who is neither Brooks nor Minton. 4. Vocabulary usage: Word Occurrences as Percent of Total O the 5.20 3.65 6.84 5.56 4.91 5.61 7.70 5.67 5.97 6.11 4.79 4.54 O to 3.03 4.30 3.29 3.21 4.12 4.93 4.04 3.39 4.06 4.08 2.89 4.35 O of 3.79 2.90 4.30 4.70 2.07 3.79 4.80 3.30 4.27 2.30 3.64 1.13 O and 2.76 3.55 3.16 1.50 3.07 2.31 3.62 2.12 2.55 2.71 2.94 3.78 O in 1.79 2.15 2.03 0.85 2.57 2.49 2.36 2.54 2.15 2.48 2.21 1.98 O that 1.26 2.90 2.66 1.28 2.00 1.01 1.68 1.78 1.08 2.30 1.23 2.17 O I 0.92 0.84 1.90 4.70 2.96 0.08 0.93 2.29 0.17 2.98 0.03 3.02 N mr 0.04 0 2.15 0.64 4.98 2.99 0.04 0.85 1.82 2.57 0.62 2.17 O a 1.78 1.22 1.01 1.71 1.22 1.27 1.64 1.78 1.98 1.44 1.65 1.51 V was 1.50 1.22 1.52 1.28 2.05 0.55 0.55 1.44 0.12 1.71 0.64 1.70 N minton 0 3.37 1.65 0.85 1.88 1.53 0.46 0.42 1.32 0.03 0.59 0.09 N scient...1.57 1.03 1.27 0 1.00 0.49 0.17 2.29 1.34 0.82 1.46 0.38 O he 0.80 1.22 1.77 0 1.62 0.31 0.34 0.51 0.17 1.29 0.42 3.02 O on 0.58 0.47 2.15 0 0.88 0.83 0.42 1.78 0.71 1.10 1.21 1.23 O for 0.90 0.65 0.76 0.85 0.88 0.80 0.80 1.19 0.80 0.88 1.32 0.66 O by 0.56 0.84 1.27 1.92 0.41 0.67 1.22 0.76 1.04 0.44 0.95 0 O his 0.54 0.94 2.78 0 0.52 0.55 1.01 0.17 0.33 0.53 0.62 0.47 O as 1.07 1.03 0.51 0 0.64 0.29 1.35 1.02 0.92 0.66 0.50 0.09 O this 0.71 0.75 0.25 0.21 0.88 0.39 1.30 0.51 0.85 0.99 0.36 0.57 O with 0.68 0.75 1.01 0 0.64 0.55 0.84 0.59 0.40 0.72 0.42 1.04 O not 0.42 1.31 0.38 1.28 0.55 0.49 0.51 0.51 0.50 0.58 0.67 0.38 V had 0.48 0.37 1.01 0.64 1.02 0.21 0.42 0.76 0.14 1.11 0.28 1.04 O at 0.44 0.47 0.89 1.07 0.50 0.75 0.55 0.34 0.42 0.42 0.17 1.04 O it 0.70 0.75 0.63 1.07 0.60 0.49 0.17 0.34 0.38 0.72 0.64 0.57 V be 0.54 1.22 0.38 0.64 0.48 0.39 0.72 0.42 0.54 0.53 0.53 0.38 O or 0.65 0.19 0.25 1.92 0.29 0.73 1.18 0.08 0.64 0.30 0.53 0 V is 1.30 0.47 0.13 0.43 0.10 0.80 0.46 0.85 1.06 0.09 0.95 0.09 O me 0.17 0.19 0.63 0.21 0.67 0 0.13 1.02 0 1.74 0 1.80 V have 0.43 0.37 0.25 2.14 0.36 0.18 0.34 0.51 0.31 0.31 0.20 0.66 V would 0.35 1.40 0.51 0.64 0.60 0.10 0.46 0.08 0.12 0.75 0.25 0.38 N dandar 0 0 0 0.64 1.74 0.03 0 0 0.17 2.20 0 0.38 O him 0.29 0.19 0.25 0.43 0.69 0.36 0.04 0.51 0.07 0.58 0.34 1.32 O from 0.59 0.56 0.51 0.21 0.43 0.31 0.21 0.17 0.31 0.75 0.28 0.57 O my 0.25 0 0.63 0.64 0.41 0 0.29 1.27 0.02 0.69 0.06 0.47 O an 0.32 0.56 0.38 0.43 0.45 0.34 0.29 0.17 0.42 0.47 0.53 0.28 N case 0.17 0.56 0.13 0 1.43 0.23 0.04 0.34 0.21 1.30 0.14 0 O any 0.29 0.94 0.13 0.64 0.33 0.26 0.21 0 0.42 0.38 0.34 0.09 O which 0.45 0.47 0.25 0.85 0.38 0.29 0.13 0.17 0.40 0.09 0.20 0.09 N mcpherson0.28 0 2.35 0.19 0 0 0.25 0.17 0.28 0.03 0 N deposi...0.01 0 1.27 0 0.24 0.78 0 0.42 0.02 0.36 0.39 0 N court 0.02 0.09 0.13 0 0.05 0.62 0.97 0 1.04 0.13 0.39 0 N lisa 0 0.09 0 2.35 0.21 0 0 0.25 0.17 0.27 0.03 0 V were 0.46 0.56 0.25 0.43 0.29 0.05 0 0.34 0.07 0.34 0.20 0.28 N prince 0 0 0 0 0.55 0 0 0.59 0 0.27 0.03 1.70 V has 0.29 0.19 0.13 0 0.07 0.39 0.59 0.08 0.78 0.08 0.50 0 O about 0.23 0.09 0.13 0 0.48 0.18 0.04 0.34 0.07 0.55 0.08 0.85 N ward 0 1.50 0 0 0.02 1.45 0 0 0 0.02 0 0 N august 0.01 0 1.77 0 0.05 0 0.04 0.59 0 0.08 0.25 0.09 N these 0.32 0.28 0.13 0.85 0.10 0.18 0.29 0 0.24 0.19 0.31 0 O no 0.28 0.19 0.13 0.43 0.29 0.23 0.21 0.17 0.42 0.27 0.17 0.09 O exhibit 0.17 0 0.25 0 0 0 0.38 0.17 0.14 0 1.63 0 O its 0.13 0.09 0.13 0.43 0.05 0.57 0.17 0.25 0.50 0.08 0.34 0 O they 0.60 0.47 0 0.21 0.14 0.08 0 0.59 0.07 0.14 0.39 0 V been 0.29 0 0.63 0.21 0.12 0.03 0.13 0.42 0.21 0.24 0.22 0.19 O who 0.64 0.28 0.13 0 0.12 0.13 0.04 0.59 0.24 0.13 0.39 0 N minton's 0 0.09 0.63 0 0.10 0.93 0.08 0 0.80 0 0.03 0 V said 0.03 0.28 0 0.21 0.24 0.03 0.08 0 0 0.44 0.14 1.13 N florida 0.01 0.09 0.63 0.21 0.02 0.13 0.42 0.25 0.61 0.08 0.11 0 N trust 0 0.09 0 1.92 0.02 0 0 0.17 0.14 0.11 0.08 0 O when 0.26 0 0.13 0.64 0.26 0.08 0 0.25 0.05 0.16 0.11 0.57 N time 0.19 0.28 0.13 0.85 0.24 0.05 0.29 0.08 0.05 0.13 0.14 0 V made 0.07 0.28 0.13 0.85 0.14 0.16 0.08 0.17 0.14 0.14 0.06 0.19 V are 0.51 0 0.13 0.21 0.02 0.21 0.04 0.17 0.54 0 0.45 0.09 O we 0.24 0.28 0 0 0.31 0 0 0.08 0.02 0.33 0.22 0.85 O up 0.13 0.09 0.13 0.21 0.21 0.03 0 0.51 0.07 0.17 0.11 0.66 N brooks 0.01 0.28 0.38 0.43 0 0 0 0 0 0.38 0 0.85 V could 0.22 0.65 0.25 0 0.45 0 0 0.17 0.02 0.25 0.08 0.09 O but 0.20 0.28 0.13 0 0.29 0.10 0.08 0.25 0.14 0.11 0.11 0.47 J other 0.22 0 0 0.64 0.14 0.44 0 0.08 0.19 0.17 0.08 0.19 N order 0.05 0 0.13 0.21 0.07 0.60 0.42 0.08 0.28 0.03 0.25 0 O all 0.63 0.19 0 0 0.14 0.13 0.13 0.25 0.24 0.16 0.08 0.19 N rtc 0.18 0 0 0 0.07 1.64 0 0 0.14 0 0.08 0 O so 0.22 0.09 0.25 0 0.24 0.13 0 0.25 0.33 0.13 0.36 0.09 N factnet 0 2.06 0 0 0 0 0 0 0 0.03 0 0 O against 0.08 0.09 0 0 0.17 0.65 0.17 0.08 0.14 0.19 0.31 0.19 N discovery0 0 0.21 0.14 0.57 0 0 1.01 0.09 0 0 O one 0.36 0.09 0 0.64 0.10 0.08 0.17 0.17 0.09 0.11 0.20 0 O also 0.19 0.37 0.13 0 0.31 0.08 0.21 0.08 0.07 0.27 0.08 0.19 O such 0.11 0.09 0.38 0.21 0.07 0.10 0.21 0.08 0.54 0.08 0.08 0 N robert 0.06 0.09 0.13 0.43 0.02 0.10 0.42 0.25 0.26 0.02 0.08 0.09 N therapist0 1.39 0 0 0 0 0.42 0 0 0.14 0 N litiga...0.05 0.75 0 0 0.24 0.29 0 0 0.26 0.34 0 0 N death 0.01 0.09 0 0.21 0.67 0.08 0 0 0.17 0.58 0.08 0 O if 0.23 0.37 0.13 0 0.17 0.08 0 0.25 0.09 0.22 0.06 0.28 N inform...0.03 0 0.38 0.43 0.05 0.26 0.17 0.17 0.19 0.11 0.08 0 O because 0.18 0.28 0.13 0 0.29 0.08 0.04 0.17 0.12 0.30 0.17 0.09 N scien....0.04 0 0.13 0 0.05 0 0 0.59 0.42 0.05 0.56 0 N ms 0 0 0 0 0.21 0 0.04 0 0 0.61 0.03 0.95 O then 0.09 0.47 0 0 0.19 0 0.08 0.08 0.02 0.09 0.08 0.66 V do 0.19 0.09 0.13 0 0.24 0.10 0 0.25 0.07 0.13 0.17 0.38 N letter 0.02 0.65 0 0 0.02 0 0.88 0 0 0.14 0 0 N d 0.01 0.19 0 0.21 0.02 0.34 0.13 0 0.24 0 0.59 0 V did 0.11 0.09 0 0.64 0.17 0.13 0.13 0 0 0.19 0.17 0.09 O their 0.28 0.09 0.25 0 0.07 0.21 0 0.34 0.09 0.09 0.28 0 O under 0.15 0.28 0.25 0 0.02 0.21 0.21 0.34 0.07 0.06 0.11 0 V told 0.07 0 0.13 0 0.36 0 0.04 0.08 0 0.55 0 0.47 J criminal 0.10 0 0.13 0 0.02 0 0.17 0.93 0.02 0 0.22 0.09 O there 0.23 0.37 0 0.21 0.21 0.05 0 0.08 0.07 0.16 0.06 0.19 N rathbun 0.05 1.59 0 0 0 0 0 0 0 0 0 0 N miscavige0.80 0 0 0 0.52 0 0 0 0 0.09 0 0.19 N affidavit0 0.47 0.13 0.21 0.19 0 0.17 0 0.07 0.20 0.06 0.09 O before 0.05 0.09 0.25 0 0.07 0 0.13 0.25 0.07 0.20 0.08 0.38 O over 0.16 0.09 0.25 0.21 0.12 0.03 0.04 0.25 0.05 0.06 0.11 0.19 N rinder 0 1.31 0 0 0 0 0 0.25 0 0 0 0 N money 0.10 0.28 0 0.21 0.14 0.13 0 0.08 0.02 0.41 0.08 0.09 N respon...0 0 0 0 0 0 1.56 0 0 0 0 0 N office 0.21 0 0 0.64 0.10 0 0 0.17 0 0.05 0.06 0.28 V testified0 0 0 1.07 0 0.05 0.04 0.08 0 0.05 0 0.19 N s 0.02 0 0 0.21 0 0.21 0.46 0.08 0.17 0.03 0.20 0.09 V should 0.04 0.09 0.51 0 0.07 0.23 0.21 0 0.17 0.09 0.03 0 J wrongful 0 0.09 0 0 0.52 0.05 0 0 0.17 0.52 0.06 0 O you 0.10 0 0 0 0.02 0.10 0 0 0.19 0.14 0 0.85 O further 0.01 0.28 0.38 0 0.17 0.03 0.34 0 0.02 0.14 0.03 0 N probation0 0 0 0 0 0 1.39 0 0 0 0 0 V called 0.17 0 0.13 0 0.14 0 0 0.25 0 0.22 0 0.47 V am 0.04 0.09 0 0.64 0.10 0 0.17 0.08 0.02 0.05 0 0.19 N testimony0.01 0 0 0.85 0.07 0.23 0 0 0.02 0.05 0.03 0.09 O two 0.07 0 0 0 0.12 0.10 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0.03 0 0 V quash 0 0 0 0 0 0.03 0 0 0.17 0 0 0 V assist 0 0 0 0 0.05 0.10 0 0 0.02 0.02 0 0 ||||| From: Niemand Nirgendwo Date: 3 Sep 2002 20:26:10 -0000 Message-ID: Subject: (amicus) G, Brooks Testimony first day only C Newsgroups: alt.religion.scientology,comp.org.eff.talk,misc.legal References: <20020903072001.30984.qmail@nym.alias.net> Comments: * PLEASE REPORT ABUSE to abuse@cotsebay.cotse.net *** *** PLEASE REPORT ABUSE to abuse@cotsebay.cotse.net *** *** PLEASE REPORT ABUSE to abuse@cotsebay.cotse.net *** *** PLEASE REPORT ABUSE to abuse@cotsebay.cotse.net *** X-Remailer-Contact: admin@cotsebay.cotse.net Mail-To-News-Contact: abuse@dizum.com Organization: mail2news@dizum.com Lines: 285 Path: news2.lightlink.com!news.lightlink.com!gail.ripco.com!central.cox.net!cox.net!news-hub.cableinet.net!blueyonder!newsfeed.icl.net!newsfeed.fjserv.net!news.itconsult.net!news.dizum.com!sewer-output!mail2news-x3!mail2news-x2!mail2news Xref: news2.lightlink.com alt.religion.scientology:1550578 comp.org.eff.talk:105634 misc.legal:433659 At (P225)... 1 Q A judgment -- 2 A But -- 3 Q -- of acquittal. It had to be. 4 A But as far as we were concerned, it was a miracle. 5 Q Okay. 6 A Because if that technicality hadn't happened, he'd 7 be in jail. You tell me now you don't put people in jail, 8 but -- 9 Q No. I never have. I was not happy with 10 Mr. Minton. 11 A Well, we believed with all our heart that you 12 would have put him in jail. 13 Q Okay. 14 A And we -- and at that point, after that hearing 15 before you, and you admonished him that you -- he was -- I 16 don't think you said this exactly, but what you meant was, 17 "You got away with it this time, but you better not try it 18 again." That's what I heard. 19 Q Sounds like me. 20 A Yeah. And that's what Mr. Minton heard too. And 21 so the next day we went over to Wally Pope's office, and we 22 spoke to Mr. Rinder and Ms. Yingling. And we told them that 23 we were ready to start the process of correcting the record. Let is separate the events described from the interpretation the witness gives them. I hear "the Court has now told you plainly that it will not tolerate any false denial, or any withholding at all in disclosure or deposition. You know what will come out if full disclosure and deposition goes ahead, don't you. If you don't want that, you will start giving the answers we want." At(P226) Ms Brooks feels they are taking a very serious step in testifying for the defence at all, even on minor matters. 5 You know, because -- you know, here we are, now 6 we're talking to Scientology, you know, these people that we 7 have been fighting for so long, that -- you know, or these 8 horrible, evil people. And you know, now we're -- we're 9 going in there and now we're going to start telling them the 10 truth about what's been going on. I mean, it was like -- 11 you know, it was -- it was just almost unbearable. And -- 12 Q Well, we've already established that what [you say] 13 you were going to tell them the truth about were two things 14 that were fairly insignificant except for the fact that Mr. 15 Dandar was 15 a part of it. You were going to tell them about 16 an agreement that was perfectly all right. You were going to 17 tell them about a -- some checks that were perfectly all 18 right. Stripping the interpretation she gives from the events she relates, she was going to tell hearings the answers Scientology told her to give; that the answers were true is not established. This is about two matters which in themselves are fairly minor for those two, namely denial of a purported secret agreement which may or may not exist (but does not of itself involve illegality), and of donations by cashier's cheque (which of themselves do not involve illegality, though the source of those funds might do). Any false denial of these matters would be illegal, but they have now confessed to that and any consequences of that are now inevitable. The really serious implication is that they have testified, as Scientology asked them - and whether or not truthfully - that Mr Dandar was involved in these falsehoods. Scientology will use this to say Mr Dandar should be removed and sanctioned as complainant's attorney, and ultimately that this has tainted the complainant's case so much that it should be dismissed without going to jury trial. If not it is likely a jury trial will take a very dim view of the circumstances of Lisa's death, and the Church's involvement in it. Especially if the jury gets to hear all the relevant facts i.e. that there was a deliberate written policy, in step zero of the Introspection Rundown, of detaining people in this way. In that case the damages will be much higher, and against the Corporation itself rather than purported "mere rogue employees." At(P226), the mere fact of changing sides would have been pretty traumatic, whatever the particular evidence concerned. 19 A Well, it may seem that simple to you now, but to 20 us at that time, what we were about to do was change sides, 21 totally turn our backs on all the people that we had been 22 working with so hard, admit to perjury, admit to discovery 23 abuse. I mean, pretty serious discovery abuse. And we 24 were -- we really had no idea what was going to happen to 25 us. But we didn't feel that there was any other choice that 0227 1 we had. What was the date? 5 happened was that Saturday -- 6 Q That would have been March 30th? 7 A No. That was after the day after your hearing, so 8 it was April 6th. 9 Q Okay. 10 A Really what happened was that Saturday we went 11 outside in the front parking lot of Wally Pope's office and 12 said, "We have no choice but to recant our testimony and put 13 ourselves on the mercy of these courts." Separating the events from the interpretation, "we have no choice but to testify the way Scientology said" (whether that was the truth is a separate issue). Further down, it is proposed to take a break and the witness is cautioned against discussing the case with anyone during it. At(P228) Mr Lirot remind the court of discovery requests made: 25 MR. LIROT: Yes, Judge, we just as a reminder 0229 1 ask her to comply with all the requests for 2 production and all the documents that were shown to 3 her at those meetings. 4 THE COURT: I'm sorry. 5 MR. LIROT: Meetings with Scientology. We'd 6 like her to bring those with her on Monday. 7 THE COURT: What? I don't know what you're 8 talking about? 9 MR. MCGOWAN: Your Honor, there was a request 10 to produce that was filed as a request to produce -- 11 THE COURT: In the other case? 12 13 MR. MCGOWAN: Pardon? 14 THE COURT: In the other case or in this case? 15 MR. MCGOWAN: No, in this case. 16 THE COURT: Oh, okay. 17 MR. MCGOWAN: But it's a request to produce, 18 like a 30-day request to produce, that asks for all 19 the documents that admits extortion and blackmail 20 and so forth. 21 THE COURT: I saw that, but I thought that 22 was -- honestly I thought that was in the other 23 case. 24 MR. MCGOWAN: It was in this case. But in 25 either case, it was a 30-day request to produce. The Court instructs production of these documents on Monday. At(P230), the start time on Monday is discussed. At(P231), the witness is further instructed not to consult. At(P232), the hearing adjourns until Monday. ++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ ADDENDUM --- EVENTS ARRANGED IN DATE ORDER. 1982 Miscavige takes effective control of Scientology 1986 Miscavige succeeds as leader on Hubbard's death 1989 Stacy Brooks-Young leaves Scientology 1993(p80)she is engaged by Mr Berry as an expert in the Fishman case. 1995/dec 5th, death of Lisa MacPherson at FLAG Land Base. 1997/may (P43), Mr Minton begins funding this case, and Mr Dandar replies thanking him but pointing out the rules on no case control; the letter was entered into evidence as defence exhibit 73 (p112). 1998, ?month, Ms Brooks works as a paralegal or expert witness in Mr Dandar's office, her salary paid by Mr Minton. 1999, august(p46), Philadelphia: first alleged case-control meeting 1999, august/20th (p74), filing of Jesse Prince affidavit. In hindsight, the allegation of something improper at the Philadelphia meeting may simply be a fabrication designed to attack this affidavit, and attack the basis of the Trust. At the end of the meeting a donation of $250,000 was made (#12 of second affidavit). 1999, fall(p137), incorporation of the Lisa MacPherson trust. 1999. October, (#13 of 2nd affidavit), Judge Moody denies motion to add Miscavige as defendant in any of his corporate capacities. 1999, later in October(#15), 2nd purported case-control meeting discusses alternative ways to bring Miscavige in. In hindsight the allegation there was something improper at this meeting, and hence an agreement to conceal the meeting, may simply be a fabrication to undermine the brining in of Miscavige in his undoubted capacity as Captain (Leader) of the Sea Org. 2000, January(p91): filing of 5th amended complaint, grounded in the Prince affidavit. 2000, late summer or early fall(P157), alleged first attempts to conceal the secret agreement. 2000, December(p157), Mr Minton signs an affidavit denying the existence of a secret agreement. Ms Brooks says that (p161) she then put pressure on Minton to withdraw from the case, and on Mr Dandar to make Minton withdraw from the case. 2001, early (p165), the position is becoming untenable. She quotes Judge Beach as endorsing vast discovery into LMT which would reveal material on clients/donors and case strategy. Brooks and Minton respond (p167) by removing hard drives from LMT computers before an order can be made upon them. 2001, august/15, deposition of Ms Brooks by Mr Moxon in Tampa FLA (p171), before Judge Beech, with extensive discovery orders, and threats of jail for contempt on non-production. 2001, in New Hampshire after the deposition (p173), Ms Brooks tells Mr Minton that she is going to ask the dead girl's family to drop their wrongful death case, as it puts Ms Brooks at risk of jail; Mr Minton says the family already know what risks those two face, and will not drop the case to save Stacy's ass. In the early evening, Ms Brooks phones asking to meet Ms Liebrich in Texas for unspecified purposes. Soon afterwards (it is implied the same evening), having consulted Kennan Dandar and been told by him the likely purpose of the meeting, Ms Liebrich phones back declining to meet. Brooks and Minton discuss the situation. In the morning, Ms Brooks (a) withdraws herself as a witness, (b) orders Mr Minton to withdraw as a witness and stop funding the case, and (c) says she will also order Mr Prince to withdraw. 2001, early September, Mr Prince withdraws as witness, it may be partly because he was brought up on a judge charge which the court has ruled involved impropriety (p178), it may be partly because Mr Minton threatened to stop paying Mr Prince's monthly living expenses if Mr Prince did not comply. Mr Dandar files a motion for sanction because Mr Prince has been forced to withdraw by being framed for a drugs offence. Ms Brooks says she is simply acting to protect herself from harm and therefore her intentions were (p177) that she and Minton "were going to try to distance ourselves from [the case] so that we could get protection so that it could move forward without hurting us." 2001, October (p185), at a deposition with Judge Beech, Minton comes close to being jailed for contempt over non-disclosure. 2001, December (p191), Mr Minton is coming under criticism for ceasing to fund because, inevitably, some critics close to the case know in private what is going on, though it is not public knowledge at the time. Mr Minton has had to post $20,000 bond in deposition. Brooks says Dandar is pressing Minton for more money, and she is pressing Minton not to pay. 2002, January (p193), Dandar wants Minton to come and meet him in various locations, which Mr Minton declines to do. 2002, February(p194), Minton finally goes ahead with a meeting, where Dandar and Garko come to Minton's house in New Hampshire. 2002, March, order disputed: this is when Brooks says that she and Minton began settlement talks with the alleged Church. At around the same time, in her version before the talks, another cashier's cheque was issued (p216). 2002, March/24th. This is the date on which the second affidavit of Robert Minton was signed, though it may not have been filed with the court until a few days later. 2002, March/28th, (afternoon) second affidavit of Stacy Brooks signed; (evening) Brooks phones Dandar saying she and Minton are in settlement talks with Scientology. Those two want to meet Dandar in Cleveland, and push back the date of the contempt hearings so they have more room to manoeuvre(p219). 2002, March 30th, Monday, second affidavits are filed for upcoming hearings. What was the date of the $250,000 cashier's cheque? 2002, april/4th (p182), last monthly cheque paid by Minton to Prince. 2002, april/6th, Judge Schaeffer's contempt hearing. 2002, april/9th Judge Baird's contempt hearing. (#2 in third affidavit of Bob Minton), "Jesse Prince attended the hearing on April 9, 2002, during which I testified before Judge Baird to purge myself of contempt. I later was told that Mr. Prince became very upset when he saw me testifying" [to the content of the second affidavit, which seeks to frame Mr Dandar for perjury]. Both hearings hearing makes plain any withholding at all at disclosure or discovery will not be tolerated in future. 2002, april/10th, Brooks and Minton go to Wally Pope's office and agree to testify his way. This is further to their second affidavits, which were already sworn days earlier. It may be that the need for them to also testify in person has now become clear, so the meeting is to fix details of what they will say i.e. be coached what to say in this hearing. 2002, april/12th, (#3 of 3rd aff), there is a loud argument between Prince and Minton at the hotel in Clearwater where Minton is staying, and an irreconcilable breakdown in their professional relationship. 2002, may/04: no monthly payment to Mr Prince, then or thereafter. 2002, may/06: date of the current testimony. +++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ ENDS. ||||| From: Anonymous Comments: This message did not originate from the Sender address above. It was remailed automatically by anonymizing remailer software. Please report problems or inappropriate use to the remailer administrator at . References: <20020903072001.30984.qmail@nym.alias.net> Newsgroups: alt.religion.scientology,comp.org.eff.talk,misc.legal Subject: (amicus) G, Brooks Testimony first day only A Message-ID: <26ee03294147ab9a6553c9531cbba2d3@remailer.privacy.at> Date: Tue, 3 Sep 2002 22:33:05 +0200 (CEST) Mail-To-News-Contact: postmaster@nym.alias.net Organization: mail2news@nym.alias.net Lines: 1184 Path: news2.lightlink.com!news.lightlink.com!gail.ripco.com!fu-berlin.de!newsfeed.vmunix.org!newsfeed.Austria.EU.net!newsfeed.kpnqwest.at!anon.lcs.mit.edu!nym.alias.net!mail2news-x3!mail2news-x2!mail2news Xref: news2.lightlink.com alt.religion.scientology:1550580 comp.org.eff.talk:105635 misc.legal:433660 G. TESTIMONY OF STACY BROOKS (FIRST DAY ONLY - VOLS ONE AND TWO) Further to analysing the document, we analysed one sample day of testimony for falsehoods or inconsistencies. At(P24) Ms Brooks and Mr Minton they are recanting earlier statements which they swore falsely and, she says with the knowledge and at the urging of Kennan Dandar, falsely denied the existence of two things. The first is several "cashiers cheques" in the name of foreign bank branches which Bob Minton had paid them to issue, so that these did not bear his name and he could if necessary not reveal that the funds were his. Nothing so far suggests that these payments were in them- selves illegal, although a false sworn denial of them is. We believe we can plausibly show the wish to hide and deny the source of payment was entirely Bob Minton's and nobody else's. The second is a purported "secret agreement" that the estate would, over and above their repaying personal loans for case costs, make further payments of case winnings into the LMT. Nothing suggests such a purported agreement would, if it existed, be illegal, although making a false sworn denial of it is. We believe that any such agreement or need to deny it, if it existed at all, was entirely the creation of Bob Minton. However, nobody except Minton and Brooks can testify to this agreement, which we believe is a convenient fantasy of the defendant "Church" that Brooks and Minton has been induced to tout for them. At(P26) Ms Brooks approvingly quotes the CofS idea that the LMT was 25 "basically a business deal; that he had 0026 1 invested in the lawsuit and that he was therefore expecting 2 to make a lot of money from the lawsuit." The "Church" frequently gets sued by people who have paid it large sums of money and found what they got to be in the end worthless, or who have been in some way injured. It then reacts with psychopathic fury and accuses these people who have e.g. have their daughter killed by neglect in a church facility of being "in it for the money." Which it adds "they will certainly never see." In the Wollersheim litigation mentioned passim, it took twenty years of litigation to finally get the judgment paid over. The contention Scientology is advancing is as follows. Mr Minton has loaned personal money for case costs as an interest free loan, and will be personally repaid from the case proceeds if it wins. However, it is a business deal for profit in the following way: more money than was lent will come back, not into his personal pocket by inurnment (because he has quite a large house already and doesn't want to spend it on private possessions), into a pet project controlled by him viz of campaigning against Scientology. In this way they have convinced themselves that the estate, and its sinister backer, are exploiting this tragic death "which of course was none of out fault" to turn a profit. At(P31) she continues to purport there is something improper in an attorney trying to get a case he is defending dropped, or in trying to get his client as complainant a large settlement. At(P35) she deliberately misrepresents the meaning of "personal knowledge" in an expert witness; i.e. it is perfectly proper for one to say "from my long experience in that organisation the procedure used was mostly thuswise and so, although I was not there in the present case, it is my belief based on experience that it went thuswise then too." She also misrepresents that there is something improper in being paid to do this. She and Mr Fugate for the Church almost sing along in chorus here: 3 Q Well, are you saying that if there was a -- a need 4 to establish something in a pleading, you would set about to 5 author a declaration that would fit that scenario, as you 6 called it, so that the pleading could be filed? 7 A That was my job. She is back at the same thing later at(P59)...... 21 I hadn't 22 ever known Lisa and I had left before -- I mean, I'd never 23 known her. But so what? Her witness is as to long personal experience of how scientology operates in general, not based on a claim to have witnessed the actual occurrences of the instant case. At(P43) she further purports that Mr Minton not only funded the case as is perfectly proper, but gave instructions how it should be run which is not. She acknowledges that Mr Dandar wrote back saying 21 "Pursuant to the rules, your donation does not 22 entitle you to control the litigation nor the 23 disclosure of the client's confidential 24 information." But then she alleges, for which we only have her word, that control did in fact take place. And how did it take place? At(P44) the outwardly-seen relationship was that Mr Minton paid for her to be a paralegal in Mr Dandar's office advising on these issues. She says, for which we only have her word, that she was there to report everything back to Mr Minton, and Mr Dandar knew this. Actually in the affidavit which someone wrote for her and she signed she says somewhat more i.e. at para(22)... "I was, in fact, Mr. Minton's agent, directing Mr. Dandar" The word 'directing' is quite plain: it means she could give or relay an order herself, not merely observe if orders were obeyed. At(P46)she is asked to name meetings where Mr Minton exerted case control. Strangely enough she can name exactly two, those meetings purported in her affidavit to be case-control meetings; the first in Philadelphia in aug/1999. The instruction supposedly give was to 24 interject [more] 25 Scientology into the case. How are we to understand improper control of the case? Well, presumably something is made to happen in the case without the complainant knowing, or worse against the complainant's instruction, or worst flatly against the complainant's interest: the case is made to so something which suits the funder's need and hurts the complainant's. For example, the funder could instruct the attorney to seek a maximum settlement however late because they expected some of it, when the complainant wished a moderately high settlement fairly soon because of need. In this case it is strongly implied that Kennan Dandar is being directed to trash Scientology as much as possible as Bob Minton wants, to the detriment of plain getting damages as the Estate wants. So we believe it matters whether the Scientology issues introduced are relevant to outcome. This is returned to at(P52). The first Scientology issue mentioned is, at(P53), that Lisa MacPherson died on the Isolation step of the Introspection Rundown. We deal later on whether this goes relevantly to outcome or damages; we think it does. At(P55) she mentions asking 6 "During this security check, have you 7 told me an untruth? During this security check, have you 8 told me a half truth?" There is a valid reason to do this. Senior Scientologists doing publicity or court-cases are usually drilled in something called TR-L (Training Routine Lie), or Technique88 which is like "the ultimate technique" (8, infinity on its side, is a sort of good luck or completeness number in Scientology). This teaches them to create and defend more and more complex lies. Asking scientology-type questions about lies and half-truths, which the scientologist may feel obliged to answer truly, is a way of countering this. At(P58) the Court's own examination shows that Ms Brooks was not saying Dandar should include anything untrue; was simply saying what she thought might well have happened in this case based on her long personal experience of how Scientology did things in general; and believed this to be true when she suggested it. When at(P60) Ms Brooks uses the tendentious word "fabricate", the Court extracts from Ms Brooks that she did not in fact know from experience that A happened, but falsely said her experience was that B happened; in fact 17 at the time I felt 18 that everything I was saying was quite true i.e. intentional falsehood was absent. At(P62) even if Mr Fugate purports that Ms Brooks was trying to take a good practice and "make it somehow bad", the Court establishes that, good or bad, it was still a true practice. I'm skipping ahead at(P134), and quoting a long chunk..... 20 Mr. Minton was very adamant about making sure that the focus 21 stayed on Scientology. 22 There were phone calls in which he reiterated 23 that. I can't tell you more specific than that. I just -- 24 you know, over a period of time there were a number of phone 25 calls in which that same desire on the part of Mr. Minton 0135 1 was reiterated. 2 Q Keep the emphasis on Scientology, not the workers. 3 A Right. [.....] 8 Q [....] was it just where the emphasis was to be? 9 A The emphasis. 10 Q Keep the emphasis on the church, less on the 11 workers. I mean, I don't mean to put words in your mouth, 12 but I'm -- 13 He wanted this to make the church hurt. 14 A He wanted -- 15 Q Mr. Minton did. 16 A Yes. Yes. The real core of the defense portion is that they say there was wrongful control to put more emphasis on Scientology materials with the intention of blaming the defendant Church rather than the individual employees; and that there is something very improper in the Church getting the blame, for anything, ever. Well, there are reasons why this isn't so. Suppose it is the Ford Motor Company instead of the Scientology Corporation which is on trial, along with a couple of negligent employees, for causing someone's death in their local factory. Now the corporation would like to be sure the blame is on the individuals. It is one thing if rogue employees acting contrary to instruction caused a death on the premises. At most, the corporation is to blame for hiring incompetents and not supervising them sufficiently. But if the corporations own rules mandated by its highly paid executives led to the death, by ordering people to skimp on safety or whatever, that is a very different kettle of fish. For a start lawsuits are not unconnected with money, and the injured party is entitled to go after the defendant with deep pockets. Apart from that, there are different and much more serious issues of public interest and justice served. The dangerous policies themselves come into question; perhaps they should be ordered to stop carrying out such a dangerous policy and risking other lives in future. As a smokescreen, however, the Scientology Corporation believes that any criticism of its behavior is an attack on its religious practices, for example at(P65)..... 19 BY MR. FUGATE: 20 Q When you're saying Mr. Minton was dealing with the 21 most vocal critics of Scientology and he didn't quite 22 understand Scientology, do we take that to mean that he was 23 even more critical of Scientology? 24 A Yes. 25 Q And was it his purpose, as you understood it, 0068 1 regardless of what your position was, and Mr. Minton's 2 position was, to attack the religion, to attack the 3 religious beliefs -- 4 A Yes. 5 Q -- and practices? To be quite clear, their practice was to unlawfully lock up anyone driven psychotic by their courses, and they killed someone's daughter by carrying out this practice. Nevertheless, anyone who calls them on this is "attacking a religion" and will soon get called an "anti-religious bigot." It is as if the mafia declared omerta to be a religious practice, and the FBI to be carrying out anti-religious persecution of them. At(P72) it is clear from the Court's own examination that Ms Brooks then believed the practices she included to be true, and that it was true these practices had probably, based on her long previous experience of Scientology, led to Lisa MacPherson's death. At(P74) a RECESS is taken, following which she raises the filing of the 5th amended complaint based on the 20/aug/1999 affidavit of Jesse Prince. At(P76) we begin a number of queries about how much Ms Brooks had to do with the preparation of this affidavit: 23 Q Did you have anything to do with it at or about 24 the time it was prepared? 25 A Yes. 0077 1 Q Okay. And what did you have to do with the 2 preparation of it? 3 A Well, Mr. Prince and I had a number of 4 discussions. Which is returned to.... AT(P81) 16 Q And did you assist in the crafting of this portion 17 of this affidavit describing the end cycle? 18 A Well, I assisted in getting Mr. Prince into the 19 proper frame of mind in which he could then write this. "Getting someone into the proper frame of mind" or "talking someone round into making a statement" is hardly drafting the words of it; this and all sounds very nebulous. At(79) Ms Brooks raises the idea of and End-Of-Cycle. She is broadly correct that this means completing any sequence of actions, and that it may have been fancifully used to mean "Departing This Lifetime" in the belief that other lifetimes follow. We have don't know but we have only ever read of Mr Fishman saying that someone was "ordered to End Cycle", meaning "commit suicide". There are two senses in which this can be read. Hubbard, for instance, would occasionally issue orders to kill or possibly to commit suicide, see if anyone was rash enough to do it and, if they did not, claim that his words were only exaggeration. It is possible that a Scientology leader might issue an order for someone to commit suicide, and might well use a common Scientology term in describing it. However there is not any specific policy which says in such-and-such cases operatives can be ordered to commit suicide; or, if there is, we have never seen it. When asked her level in the organisation, Ms Brooks said that her processing level was OT5 (fairly high), and that her training level was a Class 4, Extended Diabetics Auditor (not that high). This refers to what she has learned, and can pass to or practice on others, in the Tech i.e. doctrine. We don't know whether any purported End Cycle policy is supposed to be Tech or Admin i.e. administrative policy. Regarding how much she knew about what went on in the organisation, it would be worth asking what her Sea Org rank was and to list the "high management positions" she had held. To estimate based on experience whether Miscavige had given such an order, one would need to ask how well she knew Miscavige, how much she knew about his behavior, and whether she served on his personal staff. At(P82) when asked whether the idea of letting Lisa die instead of be examined by proper doctors to avoid publicity is brought up: 18 A The idea that they would have let her die to avoid 19 a PR flap. 20 Q Did you -- did you come up with that idea thinking 21 it was true, or did you come up with that idea knowing it 22 was false and thinking it just would hurt them? 23 A I -- 24 Q Or something in between? 25 A I would say it was something in between. She cannot exactly deny that she came up with the idea thinking it was true, but makes some feeble gloss about exaggeration. At(P83) Mr Fugate is trying to manufacture the idea of some improper conspiracy again..... 18 Was there a 19 fraternity-like atmosphere among those of you that were 20 critics of Scientology? Prompted by Mr Dandar, she goes onto say at(P84)that.... 14 the 15 people who are within that fraternity called critics of 16 Scientology feel so strongly a hatred for Scientology One of the pet words used by the Church is "hate". You will see it throughout there propaganda as Communist propaganda is full of "Capitalists", "Hegemony", and "Running Dogs" (a phrase few people even know the historical roots of these days). Now the "Church" carries out activities such as dunning someone out of $thousands for courses which, when the inner secrets are finally revealed to them, they feel are nonsense, and then not repaying. Or perhaps they lock up someone's daughter without proper food and drink until she dies consequent on dehydration. And people reprove them for this, they dislike them for this, they may even come to a feeling of justified fury against the "Church" and all its works if it acts like this. But the "Church" means something quite different by this. Rather like the Gambino Crime Family saying "we have done nothing wrong they just hate us because we are Italians," so the alleged Church says "we have done nothing wrong, they just hate us because we are Scientologists." And when this is done over a wrongful killing, it is pretty sickening behavior. Continuing down the line.... 17 they feel that the end justifies the means, no matter what 18 it takes, to destroy Scientology. As people occasionally counted in that group, we vehemently deny that we would lie, cheat, steal, perjure, wreck property, kill persons, or whatever else is meant here. Nor would the dead girl's grandmother and aunts, their attorney, or various other people defamed in the above lines. At(P87)... 3 A And it's not because I've been extorted by 4 Scientology. ....Methinks the lady doth protest too much. At(P88) when examined by the court, she says she talked over various possibilities with Mr Prince until he came to believe as true that, based on his experiences in Scientology, it was likely the leaders of Scientology had personally ordered Lisa's death. Ms Brooks did not, so far as I can make out, believe this to be true when she convinced Mr Prince to say it: in other words it is probably true that she suborned perjury from Mr Prince (induced him to say what SHE knew to be false), even though there was not deliberate falsehood by Mr Prince. She did not tell Mr Dandar she knew it was false, so Mr Dandar acted in good faith on the lies she had told him; as had Mr Prince. At(P89) the only way she can imply dishonesty by Dandar is... 2 A [...] I told Mr. Dandar the obvious, which was that 3 I wasn't there and neither was Jesse, so we couldn't 4 possibly know. 5 Q But you didn't say what you said in court, which 6 is this is false. 7 A No. But this misrepresents the role of an expert witness. It is irrelevant she said she did not have personal witness of what happened to Lisa, because she was not expected to.... 8 Q Okay. Thank you. 9 A I said this could have happened. 10 Q This -- so in other words, you told him that based 11 on your experience -- and obviously you weren't there, but 12 based on your experience -- 13 A This could have -- 14 Q -- this could have happened. 15 A -- happened. 16 Q And did Jesse tell him the same thing? 17 A Yes. And I think when Jesse testifies he'll tell 18 you that it did happen. A further affirmation that Mr Prince himself believes it in good faith. At(P91) Mr Fugate then raised the 5th Amended Complaint, based on the Prince Affidavit, which was filed in jan/2000. At(P92) the concept of End Cycle, in the sense of ordering a suicide, is present in the complaint. At(P96) the disputed parts of the amended claim have been gone through and it is clear that, if Mr Dandar used lies which originated with Ms Brooks, then he did do in good faith not knowing them to be lies..... 3 THE COURT: Sustained. And -- 4 Well, I mean, she's already told us that he 5 didn't know the -- they didn't tell him the 6 affidavit was false, so how in the world could he 7 know that the complaint was false? Asked if she told Mr Dandar the allegations were lies, she says something subtly different: that she told him "do not use that, it is not CREDIBLE, people will just not be convinced Scientology is as evil as that" i.e. evil enough to order people into suicide. The clear picture she left him with was "well, yes, they are as evil as that, but if we just come out with it absent detailed proof then people aren't going to believe us." At(P97), apparently she was not present to take part in the drafting either of the Prince affidavit or the amended complaint based on it. 20 Q I don't want to confuse you either. 21 I had asked you, did you take part in the drafting 22 of the fifth amended complaint? 23 A No. And with regard to the drafting of 24 Mr. Prince's affidavit -- 25 Q Mm-hmm. 0098 1 A -- I wasn't -- I don't believe that I was at the 2 office for its drafting. I may be wrong about that. At(P99), she was asked... 15 Q All right. And were you present at any meetings 16 between Mr. Dandar and Mr. Minton where including this 17 language specifically charging intentional death on orders 18 of ecclesiastical leaders of the church was discussed and 19 agreed to? She was not present at meetings. She was in the room when Mr Minton answered phonecalls and heard Mr Minton's side of the story. Mr Minton, it appeared from his responses, was given news of the new allegations in the complaint, and expressed approval of them. He was given news and commented: he did not instruct. At(P100) her influence on Jesse Prince was.... 24 Q -- you were helping him get to this state of mind 25 where he could write that, believing it. 0101 1 A Yes, your Honor. 2 Q And -- 3 A And -- 4 Q -- he passed that information on to Mr. Dandar. 5 A Yes. And I think that Jesse will testify that he 6 believes it to this day. Although Mr Dandar was not told the information was false, Ms Brooks says she thinks he knew it to be false -- because he made some sort of shrug or other gesture not fully descried in the transcript. At(P102), it's all done by sign language.... 17 A Well, when I read Jesse's affidavit, I thought it 18 was a little over the top, to say the least. In that I 19 thought the language was so dramatic that it wasn't very 20 credible. And I told Mr. Dandar that. And he said, "Well, 21 I'm using it. And it says what I need to have -- you know, 22 whatever -- says what I needed to say." 23 Q Okay. 24 A And then he did this sort of thing that he does. 25 I can't -- I can't repeat it, but it's just -- 0103 1 Q I'm sorry. I don't know what it is either. He 2 has a gesture -- 3 A He has a gesture where he kind of goes like that. 4 (indicating). Ho hum, tenuous stuff indeed. At(P104) Mr Fugate is trying to show there is something improper in introducing Mr Miscavige as a defendant as leader, not of the Scientology corporations that the complainant has signed a contract not to involve, but of the Sea Org. But the question is, are they actually trying to breach what they contracted to do? No. Have they done anything false or fraudulent to get round the contract? No, Mr Fugate cannot produce anything convincing on this. So they are trying to find a lawful alternative path to get round, without breaching, an unfortunate contractual obligation they wish they hadn't entered? Well, this is precisely the sort of thing people pay lawyers to: and there is nothing improper in it. At(P106)... 4 THE COURT: I don't get it. Like problem what? 5 A legal problem? I mean, this is what lawyers do. 6 MR. FUGATE: Pleading problem. 7 THE COURT: Well, isn't that what lawyers do? 8 If they weren't able to do something one way and 9 they want to try to do it, they try to figure out a 10 way? At P(107) this is a false and perjured answer: 1 BY MR. FUGATE: 2 Q And was there a -- in your mind, was that a 3 legitimate way to put him in the lawsuit? Was that true? 4 A Well, I thought it would probably work. But there 5 isn't really a thing called the head of the Sea Org. This could be parsed two ways. She could be saying his title is not the "Head" -- they have a leader, but the leader is not called Head, he is called Chief or General or Foot or something. That would make nonsense of an obligation to tell the whole truth. Or you can parse it as "the Sea Org is not the sort of association which has any one person as leader." That is a flat out lie. The Church of Scientology have many times paraded Mr Miscavige or photos and videos of him around in public, identifying him as the Captain (i.e. supreme leader, highest rank) of the Sea Org. This is on public record. Mr Miscavige is personal leader of the Sea Org. Ms Brooks, as a former member of the Sea Org during his leadership tenure, knows it. She is willfully lying. By the way, whenever someone forgets who "whatshisname" is, you can just refer to him as the Lawn Ornament (a Terry Pratchett reference). He will enjoy reading that. At(P109) she represents it to be false that whathisname was the personal leader of the Sea Org, yet strangely she never discussed with Kennan Dandar whether this statement is true, only whether it was believable. Now, this might be something you could say of the statement that scientology is so evil that it orders operatives to commit suicide, "whether or not it's true you just won't be able to get people to believe it." But in relation to whether the Sea Org has a leader? It's a fact -- it's either true or false -- a discussion of its credibility in similar terms is absurd. Also at(P109)... 24 Q And did you ever have discussions with Mr. Dandar 25 at any time about ways to increase damages or to increase 0110 1 Scientology's desire to settle the case for large numbers, 2 in your judgment? This is just what lawyers do, and it is absurd to imply there is anything (absent a specific fraud) improper in them doing so. 13 THE COURT: Counselor, is there something 14 nefarious about trying to get good damages when you 15 file a lawsuit? 16 MR. FUGATE: I think that's -- 17 THE COURT: If not, let's move on Now at(P111), let's examine this improper attempt by Bob Minton to control the case in exchange for his funding. 25 A Basically Mr. Dandar said, "Listen, I want to get 0112 1 some feedback from you guys about whether or not I ought to 2 add -- whether or not I -- try again to add Miscavige." At the end of the meeting, Mr Minton was actually against this course of action. And did Mr Dandar say "Yes Sirree Bob, I will follow your instructions to the letter?" 16 A Mr. Dandar said, "Hmm, well, I'll think it all 17 over. Thanks for your input." So he asked some people who might know, including two of his expert witnesses, what they thought about a strategy. Then he said "thanks for your input guys" and went away to make him mind up, presumably in discussion with his client, what to do. What is improper about that? Also at(P112) Mr Fugate raises a letter sent by Kennan Dandar to Ms Brooks in may/1997. After some discussion, the letter itself is entered as evidence. At(P118) it is numbered as defendant's exhibit 73. At(P119) a paragraph is read from the letter asking whether she could say, based on her years of experience in Scientology, that whathisname would generally be told if someone is held in Isolation. At(P120)... 13 Q How did you answer Mr. Dandar, would Mr. Miscavige 14 have personal knowledge of those in isolation and their 15 condition? 16 A I said he could have. 17 Q Yeah. So you told him the answer to that is -- is 18 yes or could have or something like that? At(P121)... 18 BY THE COURT: 19 Q Well, I mean, I've read something -- and I've 20 read, as I said, an awful lot about the church's procedures, 21 but I've read something somewhere, and good Lord knows where 22 it could be, that said somebody that is in PTS-III 23 condition -- Now, when somebody freaks out -- goes PTS3 -- a number of things can be done. They might be just thrown out. But if they are held in Isolation for a period of days it is a serious matter, and the Commanding Officer of that location will be told. In this case, the Captain of Flag Land Base would certainly be told. But Flag is an important place so it could well be that the overall leader of the Church would be told as well. At(P122)... 21 I mean, that's the 22 church's position, that she was in an introspection rundown, 23 which is why none of that gets to be looked at by a jury. 24 A Right. Right. 25 Q And I'm protecting that. So I mean, I'm 0123 1 protecting a religious practice of the church. Our opinion on this might not be welcome or appropriate but here goes anyway. The first amendment position is that a secular court can't tell a religious group what it's spiritual beliefs are or whether they are true, or how to govern its own private business which does not bear on the rights of others. We believe this ruling should be revisited or reconsidered. The reason is that here we have the Scientology Corporation, a large and powerful commercial enterprise with some religious elements, in many ways no different from the Ford motor corporation. Someone has died on their premises in what is alleged to be a wrongful death caused by negligence. They say this was done by rogue employees acting contrary to instruction, and the most they did wrong is hire stupid people or fail to supervise them sufficiently. But it could also be that this happened because the employees were, according to instruction, carrying out the leadership policies of that corporation. The Introspection Rundown is the unsafe policy this turns upon. It doesn't matter that the Scientology Corporation CLAIMS it to be religious. In fact it is instructing practical, secular behavior which determines whether or not a crime or wrong has been committed. The Introspection Rundown was issued in the context that many people were freaking out on upper level courses. In this context Hubbard wrote a letter saying he had figured out the causes of psychosis, so orgs could deal with it themselves by Scientology processes and psychiatry is no longer needed. That clearly implies an order, "if someone freaks out then don't take them to a psychiatrist but deal with them by the Scientology methods included below." Step 0, and step 00, of that method are an instruction to lock them up and only release them when they calm down, not before. That's why they locked Lisa up until she became responsive again or, if she couldn't, until hell froze over, and did not release her. Now what is contained in the following steps says what kind of scientology counseling to apply after they calm down: identify issues that concern them on a number of areas and in each area see how they feel that concern in what others do to them, they do to others, they do to themselves, and others do to others. It's gobbledygook to a non-Scientologist, and should be excluded for all the usual first amendment reasons. But the letter and the isolation step(s) go absolutely to corporate responsibility, and we believe the jury should see them. Would Miscavige have been told? At(P123).... 15 But I do not think that on a routine basis 16 everybody who freaks out is reported to Miscavige. 17 Q But we're talking about someone here who was in 18 this state for 17 days. 19 A Right. 20 Q And I presume that's a fairly long time. 21 A I -- I would say so. 22 It was based on the fact that she was in that 23 state for a long time, you know, that we speculated that he 24 might have been told about it. And at Flag Land Base, which is a very important place in Scientology, second only to Miscvige's administrative HQ in Los Angeles. It is very likely he would have been told. At(P126) Mr Brooks extends her earlier false answer..... 1 Q You indicate there, "I knew there really was no 2 such thing as head of the Sea Org, but Dandar thought it 3 would work as a legal maneuver." What did you mean by that? 4 A Well, the Sea Org is a -- is not a hierarchal 5 thing. The Sea Org is -- the Sea Org is something that 6 people join in Scientology when they want to dedicate their 7 whole life to Scientology. And they sign a million-year 8 contract, and it's a very strong commitment. This is discussed in the main text of the brief, point 014. Again at(P126)... 9 THE COURT: It's a nonpublic member. 10 A It's for sure a nonpublic member. It's the 11 most -- it's the people in Scientology who are the most 12 dedicated to furthering the aims of Scientology, basically. It's a subset of nonpublic members (public members work in their ordinary job and buy Scientology teaching, nonpublic members are fulltime staff for Scientology but still usually living at home), a group of the most dedicated ones. Only Sea Org wear uniforms, and generally work at distant locations living in Church quarters. 13 And it's a bit amorphous, really. In other words, it 14 doesn't really have a shape; it doesn't really have an 15 organization in and of itself. Here she lies by mis-representation. The Sea Org is "amorphous" in the sense that it is not a corporation gathered together in one unit to carry out a practical task, but is instead an Elite Corps leavening every major location and function of the Scientology business. In other words... 16 BY MR. FUGATE: 17 Q And it's not a corporate entity. 18 A And it's not a corporate entity. But she uses this to falsely imply that it is not the sort of body which has hierarchy or a single leader. Not so. It is a uniformed paramilitary group with rank, hierarchy, and formal structure. At(P127), again there is nothing improper going on.... 21 THE COURT: It was a pretty tight contract. 22 And she knew, and Mr. Dandar knew. But was 23 anybody trying to do anything illegal here? Was 24 this kind of a manipulation to see if there was 25 another way to add David Miscavige, who might have 0128 1 known what happened to Lisa McPherson -- 2 Isn't that what was going on? 3 THE WITNESS: Yeah. I mean, what was going on 4 was trying to figure out a way to add Miscavige that 5 wouldn't violate that contract. Now in fact she is lying about Miscavige, he is widely on record as being Captain i.e. personal Leader of the Sea Org, and the defendant is estopped from saying otherwise. But, were there a falsehood, then she originated it -- Dandar believed it - and Dandar used it in good faith. Oh no, I forgot: he told her he knew it was false, in sign language, with a funny sort of shrug. At(P131)... 13 Q -- and ask you, you indicate that the meeting 14 ended, everybody went down in an elevator and there was a 15 comment made by Mr. Dandar. What was the comment and how 16 did you take that? 17 A He said, "By the way, this meeting never 18 happened." If one believes there was nothing improper at the meeting, it seems likely there was no need or agreement to keep it concealed either, but that this is something else Minton and Brooks have fabricated in their present intriguing change of heart. At(P133)... 3 A There was the meeting that I have already talked 4 about in Philadelphia. 5 Q Mm-hmm. 6 A There were some phone calls when Mr. Minton was up 7 in New Hampshire where Mr. Dandar would update him on what 8 was happening. When asked to back up the allegation of case control with specifics, she produces only the exact same two meetings described in the affidavit which was written for her, and adds a few phonecalls where, on examination of detail, it turns out Mr Minton was informed of developments and expressed approval. Ho hum. At(P134) the question is... 7 BY THE COURT: 8 Q I think what he's asking, frankly, what's 9 important in this particular piece of this puzzle, is 10 whether -- there's been an allegation Mr. Minton, because he 11 paid money, was somehow or other directing the litigation. 12 So when he's saying strategy session, is what he's 13 talking about, was there any more strategy sessions where 14 Mr. Minton was there making suggestions and telling 15 Mr. Dandar how to run the lawsuit? 16 A Your Honor, I think I've pretty much covered 17 that -- 18 Q Okay. 19 A -- earlier in the sense of talking about how 20 Mr. Minton was very adamant about making sure that the focus 21 stayed on Scientology. 22 There were phone calls in which he reiterated 23 that. I can't tell you more specific than that. No, she can't. Because there are no specifics to back it up. And it is a proper consideration whether the Scientology Corporation, through its formal policies, encouraged or instructed those workers to behave in the unsafe manner which led to Lisa's death. At no time did this involve falsehoods. Likewise it is not maliciously about generating publicity (though that may result), but about corporate responsibility and whether those policies will kill anyone else in future. At(P136) she returns to another tack. The Lisa MacPherson Trust was set up on the basis of this secret agreement which only Minton and Brooks will testify either existed or was secret. It was to was supposedly an "anti-scientology" organisation of people who just wanted to be against something and saw Scientology as a convenient target... no, it was (as its mission statement says) against the abuses of Scientology, which include a killing alleged to be wrongful death. It is insulting and arrogant to dismiss this and say opposition arises only from prejudice. "What we do is never wrong," says the Church, "they are prejudiced against us because we are Scientologists." Like "What we do is never wrong" says the Mafia, "they are prejudiced against us because we are Italian-Americans." Beyond that, they usually believe all their opponents are part of a conspiracy against them, probably led by psychiatrists, probably based in Germany. At(P137) here is Mr Fugate fabricating a RICO conspiracy... 13 Q Did he, Mr. Minton, discuss that plan with 14 Mr. Dandar, to your knowledge? 15 THE COURT: What plan? 16 MR. FUGATE: The plan -- 17 THE COURT: Where to put LMT? 18 MR. FUGATE: Where to put LMT, the purpose -- 19 THE COURT: What do you care and what's the 20 relevance of that to this hearing? At(P140) he is trying to construct a seamless conspiring connection between the dead girl's family, their attorney, and Minton as a financial contributor. They were all nefariously conspiring together to do down Scientology, an entirely wonderful organisation which is entitled to kill people's daughters and should not be reproved for it. 16 A Because Mr. Minton wanted -- you know, she had 17 become a symbol of -- the wrongful death case had become a 18 symbol for the critic community all over the world, the 19 Scientology critic community all over the world, for the 20 abuse of Scientology. And he wanted that symbol to be the 21 name of the organization. But there is nothing wrongful in this. Many folk were annoyed with Scientology because it had cheated people out of money, or sued and raided people to stop them revealing the materials which were the instrument of its cheating. They knew it sometimes locked people up in Isolation, but that was about the worst. A wrongful death, by starving or parching someone to death, was an extreme of evil behaviour not often seen from Scientology, so naturally became the focus of attention. At(P141)... 2 THE COURT: [...], what difference does 3 it make? I mean, I can assume that the LMT -- I can 4 assume that the idea of the LMT was to put Lisa 5 McPherson, the dead person that they said 6 Scientology caused, right there in the forefront. I 7 mean, this is obvious, what it was all about. This 8 is what Mr. Minton wanted it to be all about. Maybe 9 this is what Mr. Dandar wanted it to be all about. 10 And I mean, what -- so what. What we need to 11 know is whether there was an agreement to pay the 12 money from the lawsuit into there and what in the 13 world, if anything, she knew about it. At(P143) A RECESS was taken; what follows refers to VOLUME TWO, the second half of her testimony on the afternoon of 03/may/2002. ++++++++++++++++++ At(P149) pictures are produced to show that Mr Dandar attended at least one protest of some sort, possibly the annual vigil on the anniversary of Lisa's death (the Court recalls that another picture shows Mr Dandar holding a protest sign). At(P151) this picture is entered as defence exhibit #74. At(P152) we return to the secret agreement. 6 Q Now, in your affidavit, you -- you have a term, 7 the secret agreement. And to go right to the heart of that 8 issue, can you describe what you mean -- what you're 9 describing in your affidavit as the secret agreement and how 10 it differs from the other funding agreement as you 11 understood it? [...] 23 A Okay. I said before, that there was an agreement 24 between Mr. Minton, Mr. Dandar and the estate that the bulk 25 of the proceeds from the wrongful death case would go to the 0153 01 LMT. To make clear what the defendant thinks this is: large amounts of money have been paid by Mr Minton personally to cover the Estate's cost of suing which, if the Estate recovers winnings, will be repaid in full to Mr Minton personally as an interest-free loan. The purported other agreement is that, beyond repaying money loaned, the dead girl's family will make a further large payment (as the defence would see it, a "profit"), into an organisation in her memory which campaigns to stop further abuses and deaths at the hands of her killers the Scientology Corporation (as the defence would se it, an organisation controlled by Mr Minton and whose charter purpose is to do certain things Mr Minton happens to want done). It becomes a little clearer at(P154)... 4 Q And was there an understanding in that discussion 5 that there would be a payback of the moneys that had been 6 put into the case? 7 MR. LIROT: Objection. Competency. 8 BY MR. FUGATE: 9 Q If you know. 10 THE COURT: With that, if she knows. I mean, 11 it seems like we started off talking about the 12 proceeds from recovery. 13 MR. FUGATE: No. The -- 14 THE COURT: Talking about something else now? 15 THE WITNESS: The secret agreement, your Honor, 16 wasn't that he would get -- that he would get the -- 17 his loan back; the secret agreement -- I mean, that 18 was just a regular loan agreement that he had made 19 with the estate and Mr. Dandar at the beginning; 20 that, you know, he would be repaid the money that he 21 had loaned them from the proceeds of the case. The recovery pf money put in for case costs as an interest free loan was one thing. The purported secret agreement, which only Minton and Brooks have testified exists, was that there would be a further payment of proceeds over and above that, albeit into the LMT to be spent for campaigning purposes not into Bob's personal pocket to be spent for personal purposes. The defence contention is, to parody it only slightly, that Bob Minton and the LMT are one of the same thing, that the LMT embodies Bob's hobby of campaigning against Scientology, which arose because he likes campaigning against things and happened to stumble upon Scientology (and not at all because he was outraged that the Scientology Corporation had just parched someone's daughter to death and were trying to bully their way out of the consequences). If LMT simply embodies Bob's hobby, then the dead girl's family have -- in return for his loan -- handed him a free lien on the winnings, so that his hobby stands to recoup three or four times the original loan amount as compensation for the risk of losing. In other words it is a speculative investment, with a high return if it succeeds but no 100% guarantee of success. That is how we believe the defence sees matters. Of course, there is another way to analyse the new affidavits of Brooks and Minton, which they say recant previous perjured testimony falsely denying the existence of (a) certain cashier's cheques Bob had paid foreign back branches to issue for him, and (b) the existence of a secret agreement that the LMT as his hobby would, on top of the loan being repaid, be paid three or four fold the loan amount to compensate him for his risk of the case losing. That is, Minton caused these payments to appear from foreign banks and not explicitly bear his name because there was something dodgy about them, probably because he paid for them from funds in foreign accounts on which tax was due and had been evaded. He was the one who wanted this kept secret. He was the one who denied their existence. Scientology found out how matters lay, threatening him with exposure and prosecution if he did not testify their way. Their way was for him to admit that the cheques had existed, and further "admit" that the LMT was an unlawful conspiracy to attack the Scientology Corporation out of sheer malice -- rooted in a pretended secret agreement, that Bob had made a risk-investment in the case, whereby Bob would be repaid the loan amount but LMT would bag many-fold the loan amount on top of that as profit. At(P155) the interesting contention is that an arrangement LMT would get much of the winnings, nett repayment of money loaned, was widely published at the time and only became a secret later. At(P156) she says the defence made roughly the contention outlined: 10 A And then -- then what happened was Scientology 11 started to interject an argument into the wrongful death 12 case saying that, you know, this was all a business deal; 13 Minton was going to benefit from this case; this was -- you 14 know, he was -- you know, doing all these things for 15 business reasons. [by what stretch of weird though processes the defendant could actually say or believe this is outlined above]. At(P157) it is Mr Dandar who wants this agreement denied: 1 But Mr. Dandar was really concerned about it. You 2 know, the Scientology attorneys were really turning this 3 into a major issue. And so Mr. Dandar told us that we were 4 going to have to stop talking about this agreement about the 5 bulk of the proceeds. And -- and then -- [...] 7 Q And when did that occur? [...] 10 A 11 -- in the 12 fall of 2000. Of course an alternative interpretation is that they denied any such agreement because it did not exist. 19 [...] fall of 2000. And 20 then it -- December, 2000 is when the secret agreement 21 became a real serious issue because that was when Mr. Minton 22 signed the false affidavit about it. At(P158) it is still supposedly Mr Dandar saying about such a purported agreement, if it exists at all, that it was still in force but simply no one would disclose its existence to outsiders. At(P159) apparently this agreement was raised at deposition where Ms Brooks first evaded then outright lied bout its existence: 10 subsequently, I lied about this in a deposition; Mr. Minton 11 lied about this in a deposition. 12 Q About this -- 13 A About the fact that -- 14 Q The bulk of the proceeds were going -- 15 A Right. 16 Q -- to be -- 17 A That was asked -- that was specifically asked, I 18 think it was by Mr. Moxon, I think. You know, I -- and 19 first he asked me about it and I tried to get around it by 20 distracting him in another direction, but you know, that 21 didn't work. And so then he asked me again, you know, "Is 22 there an agreement for the bulk of the proceeds?" And I 23 said, "No." Well, you know, I was lying. And Mr. Minton 24 started lying about it. And -- 25 Q Why, for heaven sakes? Why indeed, when the purported terms of the purported agreement would not, had they existed, have been in themselves illegal? Especially when the existence of some-such arrangement had apparently been publicised in earlier times? At(P160) it seems that wicked Mr Dandar was behind it all... 4 A I know, but Mr. Dandar felt very, very strongly 5 that it was important that we do this. And -- 6 Q Did he ever say why? Other than they were just 7 making a big deal about it and -- 8 A Because they -- because -- 9 Q It was derailing the case? 10 A Yeah. Because Scientology was using this 11 agreement to turn the case into a case about Mr. Minton and 12 not about Lisa McPherson. That was basically the -- the way 13 that he spoke about it. So, what this sounds like is, CofS were making a big deal of this whole incredible idea that the Lisa MacPherson Trust was just one big conspiracy that was only in it for the money, and trying to find and attack everyone who had ever written to it for help or donating money -- and Judges in other courts were co-operating with this witch-hunt. Now the reason Minton and Dandar needed a denial of this purported agreement was, not that in fact there was anything improper in the purported agreement, but that in practice the theory of such an agreement was successfully being used to wreck the complainant's case and therefore had to be got out of the way. Thus, Ms Brooks says, they got into the position where they had an agreement which was not of itself unlawful, but were forced into making a sworn false denial of it which was. Further down... 18 Now, you can imagine this was a little difficult 19 to do after he'd gone on the radio and posted things on the 20 Internet saying that there was. And of course, Mr. Moxon 21 was bringing these things out at his deposition and saying, 22 "There's no agreement? Well, then why did you say there was 23 an agreement?" You know, it was -- it was -- it was just so 24 obvious. I can imagine it might be. Perhaps I have not been exercising my imagination enough, but I cannot imagine anyone as articulate and educated as Ms Brooks or Mr Minton course of action. undertaking such an utterly foolish course of action. At(P161)... 1 Q Well, you knew that -- you knew -- you've been in 2 this Church of Scientology. You knew they had fine lawyers. 3 A The best -- 4 Q And you knew that they absolutely would have known 5 what was out on the Internet said by Mr. Minton. 6 A In a heartbeat. 7 Q And surely, surely, you knew therefore there would 8 be a deposition where Mr. Minton would be asked about, 9 "Well, look here what you said." Did you talk to him about 10 this? 11 A Yes, I did. 12 Q Did you say, "We're crazy to do this"? 13 A Yes, your Honor, I certainly said that. 14 Q Did you tell Mr. Dandar, "I can't believe you're 15 asking us to do such a stupid thing"? 16 A Yes, I did. Now it is Ms Brooks position that Kennan Dandar is under pressure by these tactics so needs, and demands, from Bob Minton a false denial of the theories troubling him. But we only have her word for this. It is at least conceivable that it is Mr Minton whose personal and financial conduct is under pressure, who urges on the Estate's attorney that by goodness he will have to deny this to protect his own interests. So how did Mr Dandar react? 17 Q And what did he say? What did -- 18 A Well -- 19 Q -- Mr. Dandar say? [...] 162 [...] 4 Q What did he say? 5 A "Stop asking him for money." 6 Q What did Mr. Dandar say? 7 A He went like this. 8 Q That same -- 9 A The same thing. 10 MR. FUGATE: The gesture, for the record? 11 THE WITNESS: It was a gesture. 12 BY THE COURT: 13 Q But he didn't say anything? 14 A He said, "That's up to Bob." He did that little shrug again: more sign language. Ho hum. There is a technique in fiction called the "unreliable narrator". It means the reader is presented by some sort of a tale told by an idiot, not so much in being full of sound and fury, as in the teller not being willing or able to make a correct interpretation of events. So, she might see something as people praising her, when we might read the same events as people humouring her. And what we readers have to do here is grab hold of the events she tells but discard her interpretation, then evaluate what remains using our own wits. So, let's strip Ms Brooks interpretation of events in the above passage leaving just the events, and make our own evaluation. What do we get from the above passage with just the events? (a) It may or may not be Kennan Dandar who wants Bob to deny stuff - the cheques which exist, if not the secret agreement which doesn't -- but certainly Ms Brooks is putting pressure on Kennan Dandar prevent Bob from denying it; quite probably because she has herself first tried and failed to prevent Bob doing so. (b) Just before and after the deposition in which the purported agreement is denied, there is a difference of agreement between Brooks and Minton about whether it is worth taking whatever risks there are in continuing to oppose Scientology abuses. Mr Minton is brave, perhaps foolhardy, and determined to push ahead. Ms Brooks is more cautious and, perhaps knowing the true viciousness of the Scientology Corporation from the inside, wants Minton to stop: "Stop funding this case" (P161 L21). Failing that, she wants Dandar to make him stop: "Stop asking him for money" (P162 L05). She wants lots of people to give up their own interest and ensure her safety or control others for her. Dandar rightly refuses to be used as her tool to control Minton: He said, "That's up to Bob" (P162 L14). (c) What happens next is consistent with the same clinging, manipulative personality that demands everyone else give up their interests to ensure her comfort and security: she directly contacts the dead girl's family, and says they must drop their case for compensation over her death because otherwise she and Bob are at risk, and that comes first. In the lines which follow we must, particularly, set aside her incomprehension as to how people are reacting to her, and simply consider how they are reacting to her: 15 You know, this whole thing came up that -- then it 16 came about that Mr. Dandar and his group of people were 17 feeling that I was manipulating Mr. Minton and that I was, 18 you know, having some sort of sinister influence over him, 19 for reasons which I -- have never really been clear to me. 20 But there was this whole thing and, you know, that I was 21 doing something really bad to be trying to get Mr. Minton to 22 stop his funding of the case There is a concept in psychology called "denial". When people are doing something rotten and manipulative, they resist seeing the nature of their own actions. It is painful for them to see what is really going on, it hurts their head to lead the idea in, so they keep it out. She "cannot possibly understand why people think she is being manipulative." She cannot, because it hurts her to do so. The reason they think she is being manipulative is the obvious one: she is. It is hard otherwise to understand what is going on here. Really, There are two alternatives. One is that Dandar and co grant Ms Brooks less say than Mr Minton wants her to have, for a number of reasons but maybe just simple anti-female prejudice. Especially when things have moved from first Ms Brooks being Mr Minton's professional assistant to them living together as man and wife: some males might take this automatically to mean she was there as a hanger-on rather than an important deputy. But this does not square with the defendant Church's contention that Bob paid the piper, so Bob called the tune and controlled the case, and everyone said "Yes Sirree Bob" and jumped to his word. In that case this situation is untenable, Bob would say "how dare you, Ms Brooks is also my professional deputy and you will treat her command as mine." The alternative is that Bob did not originate Stacy's important role at meetings: Stacy originated demands to be at meetings and Bob, having a soft spot for her, gave in to her wheedling. She would smile at him ingratiatingly with the teeth he had bought her, and his rugged masculine heart would melt like raspberry jello. There must be some reason people find Ms Brooks attractive... though we cannot for the life of us, seeing her character as it shines through this testimony, work out what it is. At(P162) there is certainly perjury going on, if only over the very real cheques and not the imaginary agreement. The people doing it are Brooks and Minton, probably Brooks pushing Minton to do it, and -- according to her -- they have told Dandar. 24 this perjury was going on, because I certainly wasn't saying 25 a word about it to anybody else except for Mr. Minton and 1 Mr. Dandar. It is helpful that, as a witness for the defendant Church, Brooks still does not accuse anyone on the complainant's side, except possibly their attorney -- remember this testimony is part of a malicious and perjured attempt to get their attorney removed from the case -- of being party to their perjury. This goes to whether the dead girl's family themselves should suffer sanctions, up to and including dismissal of their case, (which is probably what the defendant Church is ultimately aiming for) over Brooks and Minton's perjured denial of the cashiers' cheques. At(P163) when, in dec/2000, Mr Dandar filed affidavits that there was no secret agreement, and motions based upon them, she felt Mr Minton was particularly put at risk by this. At(P165) Brooks tells us how she and Minton are under pressure because the alleged Church was in practice succeeding in its tactic of pressing -- irrespective whether in fact it was actually true - the grand conspiracy theory, and engaging in vast abusive deposition: 2 A And then -- okay, this is into -- now we're -- now 3 we're moving into 2001. Now things are falling apart to 4 such a degree that it's a nightmare. Because now 5 Scientology has started to, you know, depose me and demand 6 documents out of the Lisa McPherson Trust because 7 Scientology has now made the connection between the Lisa 8 McPherson Trust, all the witnesses that are, you know, being 9 paid at the Lisa McPherson Trust, all the people that are on 10 the advisory border(sic) (should be "board") She forwards, if we are to believe her, the usual Scientology line that it is all a conspiracy against them. Undoubtedly other courtrooms have both gone along with this conspiracy line, and with abusive discovery which exposes anyone who gave money or sought help to Scientology harassment: 22 [Judge Beech] said, "There's no difference between Mr. Minton 23 and the LMT, the Lisa McPherson case -- it's all the same." Endless abusive discovery was a large part of the pressure: 24 And so now they started to be able to - {CofS] 25 started making document demands at the LMT and -- At(P166) why destroy records or avoid discovery...? 2 A Scientology. And I started evading discovery and 3 lying about our records, and -- 4 Q Why? 5 A -- and at that point -- 6 Q I mean, why? 7 A Why? 8 Q Why were you lying about your records? I mean, 9 was there anything -- 10 A Because I'll tell you why. 11 Q -- was there anything illegal about LMT? 12 A You know what? I wasn't sure if there was 13 anything in those records that could hurt the case or not. 14 And if there was any possibility that it would hurt the 15 case, we had to not give it to them. Looking at this without a Scientology spin, discovery of everything LMT or Brooks and Minton know about the case can be used to gather intelligence to destroy the case. If it identifies a potential witness then they can be intimidated out of testifying by a "noisy investigation" i.e. going round saying "we are investigating this person for drug trafficking", which they are, but without any evidence of drug trafficking or authority to investigate, merely saying to sow suspicion because there's no smoke without fire. If it identifies potential funders, they can be dissuaded from funding. If it identifies levels of funds, the strategy can be set to string the case out long enough to exhaust them. Thus there are legitimate reasons to refuse intelligence via abusive discovery. ||||| From: Anonymous Comments: This message did not originate from the Sender address above. It was remailed automatically by anonymizing remailer software. Please report problems or inappropriate use to the remailer administrator at . References: <20020903072001.30984.qmail@nym.alias.net> Newsgroups: alt.religion.scientology,comp.org.eff.talk,misc.legal Subject: (amicus) I, Exhibits List Message-ID: <829ee8d867b158fcad85d7274cb94389@paranoici.org> Date: Wed, 4 Sep 2002 23:13:23 +0200 (CEST) Mail-To-News-Contact: abuse@dizum.com Organization: mail2news@dizum.com Lines: 13 Path: news2.lightlink.com!news.lightlink.com!news-out.visi.com!hermes.visi.com!out.nntp.be!propagator-SanJose!news-in-sanjose!in.nntp.be!news.dizum.com!sewer-output!mail2news-x3!mail2news-x2!mail2news Xref: news2.lightlink.com alt.religion.scientology:1550898 comp.org.eff.talk:105654 misc.legal:433682 I. EXHIBITS LIST Here is a list of documents mainly by others (press articles, court judgments, etc) which we have referred to, and enclose herewith. Am(J) Sea Org ranks and hierarchy - R V Young testimony Am(K)"Long Trail of Controversy" - press articles worth skimming Am(L) Letter, from David Miscavige to District Attorney in full Am(M) Letter, from District Attorney to David Miscavige in full Am(N) On the issue of "Fair Game" Am(O) Scientology's War on the Judges. American Lawyer Magazine ||||| From: Frog Date: 4 Sep 2002 21:17:10 -0000 Message-ID: Subject: (amicus) D, Text Analysis III Newsgroups: alt.religion.scientology,comp.org.eff.talk,misc.legal References: <20020903072001.30984.qmail@nym.alias.net> Comments: This message probably did not originate from the above address. It was automatically remailed by one or more anonymous mail services. You should NEVER trust ANY address on Usenet ANYWAYS: use PGP !!! Get information about complaints from the URL below X-Remailer-Contact: http://www.privacyresources.org/frogadmin/ Mail-To-News-Contact: abuse@dizum.com Organization: mail2news@dizum.com Lines: 1168 Path: news2.lightlink.com!news.lightlink.com!gail.ripco.com!central.cox.net!cox.net!ps01-sjc1!news.webusenet.com!news.itconsult.net!news.dizum.com!sewer-output!mail2news-x3!mail2news-x2!mail2news Xref: news2.lightlink.com alt.religion.scientology:1550899 comp.org.eff.talk:105655 misc.legal:433683 N road, N peter, N courtroom, J angry, N alexander 0 0 0 0 0 0 0 0 0 0 0 0.19 N conditions0 0 0 0 0 0 0.17 0 0 0.02 0 0 N consultant0.01 0 0 0 0.14 0 0 0 0 0.03 0 0 V loaned 0 0 0 0 0 0 0 0 0 0.09 0 0.09 O simply 0.03 0 0 0 0 0.03 0 0 0.12 0.02 0 0 N opponents 0 0 0 0 0 0.05 0 0.08 0.02 0 0.03 0 N lerma 0 0 0 0 0.02 0.08 0 0 0.07 0.02 0 0 O below 0.01 0 0.13 0 0 0 0 0 0.05 0 0 0 O really 0.06 0 0 0 0.05 0 0 0 0.02 0.03 0.03 0 N behavior 0.02 0 0 0 0 0 0 0.08 0 0 0.08 0 J vicious 0 0 0.13 0 0 0 0 0 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man's, J lurid, J lower, N loathing, V investigating, N interview, J institutional, N ills, J honest, N hatred, V happen, N germany, N fraud, N felonies, V excuse, N eve, V escape, J elaborate, O effectively, N education, J double, J domineering, N directive, V destroying, N cv, N curve, V cure, V curb, N crackpots, O continually, M campaigns, V assign, N articles, N ama, J alert 0 0 0 0 0 0 0 0 0 0 0.03 0 N york, J untrue, N union, J truthful, V traced, N switzerland, V serving, J sensational, V reaffirmed, N pool, V planned, J overseas, N nickname, N messrs, V invested, J frantic, N email, V dropping, J deeper, N concessions, N caroline, N carlson, N awareness 0 0 0 0 0 0 0 0 0 0.03 0 0 J undue, V stick, J secure, V refusing, O reasonably, V purchase, V moving, N meetings, V measures, J married, V makes, V inquire, V identify, J final, V examine, V establishing, N energy, N del, V declaring, O collectively, V bears, V barred 0 0 0 0 0 0.03 0 0 0 0 0 0 N status, N land, N dollars 0.01 0 0 0 0 0 0 0 0 0.02 0 0 N steven, V running, N prison, N ot, N lines, N lectures, N lecture, N hypnosis, N hollywood, N girl, N francisco, N echelons, N doctor, N bts, J black 0.03 0 0 0 0 0 0 0 0 0 0 0 N wording, V won't, N texas, O supposedly, V stunned, V remain, V putting, J particular, V open, V needs, V i'll, V holding, J furious, N flow, V enabled, N ego, J deep, N chris, N bit, V becoming, V authored, N accident 0 0 0 0 0.02 0 0 0 0 0 0 0 ||||| From: Nomen Nescio Comments: This message did not originate from the Sender address above. It was remailed automatically by anonymizing remailer software. Please report problems or inappropriate use to the remailer administrator at . References: <20020903072001.30984.qmail@nym.alias.net> Newsgroups: alt.religion.scientology,comp.org.eff.talk,misc.legal Subject: (amicus) D, Text Analysis I Message-ID: <62caf68d14ec0ea1eed799c06012d4a0@dizum.com> Date: Wed, 4 Sep 2002 23:30:26 +0200 (CEST) Sender: remailer@dizum.com Mail-To-News-Contact: postmaster@nym.alias.net Organization: mail2news@nym.alias.net Lines: 146 Path: news2.lightlink.com!news.lightlink.com!news-out.visi.com!hermes.visi.com!eusc.inter.net!newsfeed.stueberl.de!newsfeed.eunet.at!newsfeed.austria.eu.net!anon.lcs.mit.edu!nym.alias.net!mail2news-x3!mail2news-x2!mail2news Xref: news2.lightlink.com alt.religion.scientology:1550901 comp.org.eff.talk:105656 misc.legal:433684 D. TEXT ANALYSIS OF BROOKS AND MINTON AFFIDAVITS. 1. Files from left to right are: Stacy 1994/oct/13 (Fishman Case) ) earlier materials 1999/jun/06 (Ward Case) ) for a comparison baseline 2001/aug/26 first affidavit 2002/apr/17 recantation 2002/apr/29 2ND AFFIDAVIT Bob 1999/dec/13 (Ward Case) ) ditto 2001/aug/02 re probation 2001/aug/22 re attendance 2001/dec/12 re protective-order 2002/apr/24 2ND AFFFIDAVIT 2001/aug/26 re Show-Cause 2002/apr/29 SHORT SUPPLEMENTARY 3RD AFFIDAVIT ================================================================ 2. Punctuation usage: Mark Occurrences per 10,000 Characters: . 104 96 120 128 178 198 90 103 135 145 122 162 , 79 64 85 103 69 79 132 98 87 79 87 95 ; 2 0 0 0 0 8 0 2 2 0 3 0 : 2 3 10 3 0 2 1 2 5 0 5 3 ? 0 0 0 0 0 2 1 0 0 0 0 0 ! 0 0 0 0 0 0 0 0 0 0 0 0 ( 11 6 0 0 1 22 9 0 18 2 16 1 ) 11 6 0 18 1 22 9 0 18 2 16 1 " 34 3 0 0 20 27 10 8 25 30 50 63 ' 14 19 22 7 13 37 15 17 29 10 40 26 COMMENT: How are these figures translated into observations about the text? First, let's exclude the last columns (third affidavit) as only a very short sample of text perhaps untypical in style. Brooks-2nd and Minton-2nd are heavy on periods i.e. full of short, plain sentences. They are lighter on commas than Brooks or Minton i.e. less parenthetical subclauses. It is striking that they simply never use a colon or semicolon as Brooks and Minton do, or terminate with a question or exclamation mark as Brooks and Minton do, and that there are very few parentheses: this typifies a kind of "plained down" writing taught for tabloid journalism and legal briefs, as opposed to more expressive writing. The same tendency is seen in the next section be examining the spread of sentence lengths. The author of the false-Brooks and false- Minton documents is much more likely to use very short sentences of 3, 4, 5 or 6 words long. She / he also noticeably has an absolute cut-off for no sentences above 65 words; whereas in writings really by Brooks or Minton, a few sentences sporadically occur at lengths of ninety or over. ======================================================================== 3. Sentence lengths: Len Occurrences as Percent of Total 1 0.2 0 9.8 3.7 15.3 21.1 3.4 6.6 12.7 10.2 7.2 8.5 2 0.4 2.0 7.8 0 3.4 7.6 0 0 8.9 2.4 7.2 2.4 3 0.8 2.0 3.9 0 6.1 5.4 1.7 0 4.1 5.0 1.0 4.9 4 0.9 0 7.8 0 5.3 3.7 1.7 1.6 4.1 5.0 1.9 6.1 5 1.3 2.0 2.0 3.7 6.6 4.8 0 1.6 5.1 5.0 1.0 3.7 6 1.7 0 2.0 7.4 3.9 5.9 1.7 4.9 2.1 5.9 1.0 7.3 7 2.6 4.0 3.9 7.4 5.0 4.5 1.7 3.3 3.8 4.6 2.4 2.4 8 3.4 2.0 3.9 7.4 3.4 4.5 5.2 1.6 3.4 3.9 4.3 11.0 9 2.9 4.0 0 7.4 4.5 2.3 1.7 1.6 2.7 3.3 5.3 2.4 10 3.4 2.0 5.9 0 3.2 3.1 0 3.3 2.7 2.8 4.3 3.7 11 3.2 10 3.9 0 5.0 4.8 0 1.6 2.7 3.7 1.9 4.9 12 3.4 0 0 3.7 3.7 1.4 1.7 3.3 2.7 3.1 5.7 1.2 13 3.2 0 5.9 7.4 2.9 2.3 0 6.6 1.0 3.7 3.8 0.0 14 4.4 0 2.0 0 4.5 1.7 1.7 1.6 4.5 2.4 4.8 1.2 15 4.4 0 2.0 0 1.8 1.1 0 1.6 1.4 2.6 2.9 4.9 16 3.6 4.0 2.0 7.4 3.2 2.8 1.7 3.3 1.7 1.7 2.4 1.2 17 3.0 4.0 2.0 7.4 2.1 2.3 1.7 6.6 2.1 3.3 4.3 6.1 18 3.9 2.0 2.0 3.7 1.6 1.7 1.7 4.9 3.4 2.6 1.9 0 19 4.1 6.0 0 3.7 2.4 2.5 0 3.3 2.1 2.6 3.8 6.1 20 3.0 6.0 2.0 0 1.1 2.0 0 1.6 0.3 2.2 1.4 1.2 21 2.8 2.0 0 0 2.1 0.3 3.4 0 3.1 2.0 1.9 2.4 22 3.4 8.0 2.0 3.7 0.3 2.5 0 1.6 2.7 2.0 2.9 1.2 23 3.3 0 3.9 3.7 1.3 1.7 1.7 4.9 0.7 2.0 1.4 4.9 24 2.6 6.0 3.9 0 1.6 1.4 3.4 1.6 1.0 1.5 1.9 0 25 2.7 4.0 2.0 0 1.1 0.3 0 4.9 2.4 1.7 2.4 1.2 26 2.8 2.0 3.9 0 0.5 1.4 0 3.3 2.1 1.3 1.9 0 27 1.9 2.0 0 0 0.3 0.3 0 1.6 0.3 1.3 2.9 1.2 28 1.8 6.0 0 0 1.3 0.3 1.7 0 1.0 1.3 1.9 2.4 29 1.5 0 2.0 3.7 1.3 0.8 0 4.9 1.4 1.1 1.9 0 30 2.4 2.0 0 0 0.3 0 1.7 0 1.0 0.4 0.5 1.2 31 1.5 2.0 0 3.7 0.5 0.8 0 3.3 0.7 0.4 1.0 0 32 1.2 0 2.0 3.7 0.3 0 1.7 1.6 1.0 1.5 1.4 1.2 33 1.9 4.0 0 0 0.3 0 1.7 0 1.4 0.4 0 0 34 1.0 4.0 2.0 0 0.3 0.3 3.4 1.6 0.7 1.5 0 1.2 35 1.5 0 0 0 0.3 0.6 3.4 1.6 0.3 0.9 0.5 0 36 0.3 0 0 0 0.5 0.6 1.7 0 0 0.2 1.0 1.2 37 1.0 0 0 3.7 0.3 0 0 1.6 1.0 0.2 1.0 0.0 38 1.3 0 2.0 0 0.5 0.6 0 1.6 1.4 0.2 1.0 0.0 39 1.2 2.0 2.0 0 0.3 0 0 1.6 0 0.4 1.4 1.2 40 1.0 0 0 3.7 0 0 1.7 0 0.3 0 0.5 0.0 41 0.4 0 0 0 0.5 0.3 0 1.6 0.7 0.2 0.5 0.0 42 1.1 0 0 0 0.3 0.3 1.7 0 0.3 0 0 0.0 43 0.9 2.0 0 0 0.3 0 5.2 0 0.3 0.2 0 0.0 44 0.2 0 0 0 0 0 1.7 0 1.0 0.4 0.5 0.0 45 0.2 0 0 0 0.3 0 1.7 1.6 0.3 0.4 0 0.0 46 0.2 0 0 0 0 0.3 3.4 0 1.0 0.4 0 0.0 47 0.3 0 0 3.7 0 0 0 0 0.3 0.2 0 0 48 0.5 0 0 0 0 0 1.7 0 0 0 0 1.2 49 0.3 0 2.0 0 0.3 0 1.7 0 0 0.2 1.0 0 50 0.2 0 2.0 0 0 0 1.7 1.6 0.3 0 0 0 51 0.2 0 0 0 0 0 1.7 0 0 0 0 0 52 0.4 2.0 0 0 0 0 3.4 0 0 0 0 0 53 0.6 0 0 0 0 0.3 0 0 0.3 0 0 0 54 0.2 2.0 0 0 0 0 0 0 0 0.4 0 0 55 0.2 0 0 0 0.3 0.3 0 0 0 0.2 0 0 56 0.5 0 0 0 0 0 5.2 0 0 0 0 0 57 0 0 0 0 0 0.3 1.7 0 0 0 0.5 0 58 0.4 0 0 0 0 0.3 0 0 0.3 0.2 0.5 0 59 0.2 0 2.0 0 0 0 0 0 0.3 0 0 0 60 0.2 0 0 0 0 0 0 0 0 0 0 0 61 0.2 0 0 0 0 0 0 0 0 0 0 0 62 0.1 0 0 0 0 0 0 0 0 0 0 0 63 0 0 0 0 0 0 1.7 0 0 0.2 0.5 0 64 0.1 0 0 0 0 0 0 0 0 0.2 0 0 65 0 0 0 0 0 0 0 0 0 0 0.5 0 66 0.2 0 0 0 0 0 0 0 0 0 0 0 67 0 0 0 0 0 0 0 0 0 0 0.5 0 68 0.1 0 0 0 0 0 0 0 0 0 0 0 69 0.1 0 0 0 0 0 0 0 0 0 0 0 70 0 0 0 0 0 0.3 0 0 0.3 0 0 0 71 0 0 0 0 0 0 1.7 0 0 0 0 0 72 0 0 0 0 0 0 1.7 0 0 0 0 0 76 0.2 0 0 0 0 0 0 0 0 0 0 0 77 0 0 0 0 0 0.3 0 0 0 0 0 0 82 0 0 0 0 0 0 3.4 0 0 0 0 0 86 0 0 0 0 0 0 1.7 0 0 0 0 0 88 0 0 0 0 0 0 3.4 0 0 0 0 0 90 0 0 0 0 0 0.3 0 0 0 0 0 0 93 0.1 0 0 0 0 0 0 0 0 0 0 0 ||||| Date: Wed, 4 Sep 2002 16:43:31 -0500 From: xganon Comments: This message did not originate from the Sender address above. It was remailed automatically by anonymizing remailer software. Please report problems or inappropriate use to the remailer administrator at . References: <20020903072001.30984.qmail@nym.alias.net> <0aa3a86084cdb58a3b5251d78bd92d8b@dizum.com> Newsgroups: alt.religion.scientology,comp.org.eff.talk,misc.legal Subject: (amicus, source docs) Brooks -- Testimon B Message-ID: <06adac2bb53b1f256e12a69636b6b1cd@xganon.com> Mail-To-News-Contact: abuse@dizum.com Organization: mail2news@dizum.com Lines: 1298 Path: news2.lightlink.com!news.lightlink.com!news-out.visi.com!hermes.visi.com!feed2.news.rcn.net!rcn!howland.erols.net!cyclone2.usenetserver.com!news.webusenet.com!news.itconsult.net!news.dizum.com!sewer-output!mail2news-x3!mail2news-x2!mail2news Xref: news2.lightlink.com alt.religion.scientology:1550906 comp.org.eff.talk:105658 misc.legal:433686 0046------------------------------------------------------------------ 1 MR. FUGATE: Let me see if I can answer that. 2 BY MR. FUGATE: 3 Q Was your presence in Mr. Dandar's office as you've 4 described -- or in the affidavit as the eyes and ears for 5 Mr. Minton -- was that known, to your observation and 6 knowledge and the best of your belief, to Mr. Dandar? 7 A Mr. Dandar and Dr. Garko. 8 Q Okay. And there was no question about that -- 9 A We talked it. 10 Q -- in your mind. 11 Were there conversations that you were present at 12 between Mr. Minton and Mr. Dandar about the direction, 13 scope, et cetera, of this wrongful death litigation? 14 A Yes. 15 Q Can you tell us about those? 16 A Well, there were a number of discussions, but one 17 that I described in my affidavit is one that happened in 18 Philadelphia in, I believe, August of 1999. I had been -- 19 THE COURT: I'm sorry, August -- 20 THE WITNESS: August, 1999, I think. 21 A Anyway, I had been working with Mr. Dandar and 22 Dr. Garko over that summer. And I had told Mr. Minton that 23 I was very concerned because I didn't feel that Mr. Dandar 24 was really getting it about how he could interject 25 Scientology into the case. I'd had a number of 0047------------------------------------------------------------------ 1 conversations with Dr. GarKo in which Dr. Garko said he 2 didn't want to inject Scientology into the case, and 3 Dr. Garko was Mr. Dandar's main consultant. So I had told 4 Mr. Minton that I felt like he really needed to set this 5 straight with Mr. Dandar; that he was funding a case about 6 Scientology causing Lisa McPherson's death, not just a 7 simple wrongful death case. 8 So Mr. Dandar wanted -- wanted Mr. Minton to meet 9 him in Philadelphia -- I think he had a deposition there or 10 something. I'm not sure why he was going to be there. But 11 he wanted to meet Mr. Minton in Philadelphia because he 12 wanted to ask him for more money in August of '99. And he 13 really preferred to meet with Mr. Minton alone, without me 14 there, 'cause -- 15 BY MR. FUGATE: 16 Q He being -- 17 A Mr. Minton -- Mr. Dandar. 18 Q Okay. 19 A Because he and I just didn't have a very good 20 relationship. 21 Q And he would be Mr. Dandar. 22 A Yeah. Mr. Dandar. 23 But I did go with Mr. Minton to this meeting, at 24 Mr. Minton's request, and at my request, that he let me. 25 And we did meet with Mr. Dandar, and Mr. Minton told him -- 0048------------------------------------------------------------------ 1 I mean, this is in my presence, so -- this was in my 2 presence. 3 Q Okay. 4 A -- that -- what I just said; that, you know, he 5 was funding a case about Scientology's involvement in Lisa 6 McPherson's death, not just a simple wrongful death case. I 7 think he mentioned that he knew that Dr. Garko was not in 8 favor of this. You know, because I had said so. And he 9 said that he really wanted to see Mr. Dandar taking more of 10 an active interest in, you know, understanding Scientology's 11 practices and beliefs and you know, listening to me and 12 listening to Jesse Prince about, you know, how to litigate 13 this case. 14 Q And when you say that -- and I'm going to stop you 15 here and we'll go back to where you were -- but do you mean 16 how to interject, into the litigation, attacks on the 17 beliefs or practices of Scientology? 18 A Yeah. 19 Q And you've -- have you read the fifth amended 20 complaint -- I don't mean today, but have you read it 21 recently? 22 A Yes. 23 Q And the language that's in there about the 24 Scientology technology, about the introspection rundown, 25 about -- that the murder, if you will, or letting Lisa 0049------------------------------------------------------------------ 1 McPherson die to avoid a public relations flap -- are those 2 the sorts of things that you're talking about that needed to 3 be emphasized in the litigation? 4 A Yes. 5 THE COURT: Honestly, this is the very thing 6 that really ought to come from her as opposed to -- 7 when -- I had no idea what she meant when she said 8 bring Scientology into it. 9 MR. FUGATE: I'm sorry, your Honor. 10 THE COURT: So this is your witness. Why don't 11 ask you her what she means. 12 MR. FUGATE: Okay. Well, actually, I was going 13 by the affidavit, but I apologize. 14 THE COURT: Okay. Well -- 15 BY MR. FUGATE: 16 Q What did you -- what did you mean? 17 A When I -- you mean when I said that it needed to 18 be brought -- 19 THE COURT: I don't mind the leading when we're 20 going through all the preliminary stuff. When we 21 get to things I would presume would be critical, 22 rather than saying, "Is this what you mean --" 23 MR. FUGATE: I'm sorry, Your Honor -- 24 THE COURT: -- for all the parties, when we get 25 there, let's let the witness testify. Stick to the 0050------------------------------------------------------------------ 1 critical areas. 2 BY MR. FUGATE: 3 Q Let me back up. Let's go back to Mr. Prince a 4 moment. Did you know, at that time, Jesse Prince? 5 A At what time? I mean, well -- 6 Q The Philadelphia meeting, you just mentioned it 7 for the first time. 8 A Yes. 9 Q And how did you know Jesse Prince? 10 A Well, I knew Jesse Prince when we were both in 11 Scientology. I had known him since 1976, actually. And 12 after I left Scientology, I hadn't seen him until the summer 13 of 1998 when he contacted Mr. Minton and mentioned my name 14 in his e-mail. And then I called him. And that -- at that 15 point Jesse Prince started working with us. 16 Q Okay. And when you say at that point Jesse Prince 17 started working with us, what do you mean? 18 A Well, Mr. Minton started paying him; he sent him 19 out to Los Angeles to help Mr. Leipold with a case -- with a 20 Scientology litigation case that he was working on at that 21 time. And from that point forward, that was what Mr. Prince 22 did. 23 Q And to your knowledge -- and I'm directing it to 24 your knowledge -- was his sole source of income in the 25 period of time we're discussing up to, I guess, the present 0051------------------------------------------------------------------ 1 to be a Scientology critic or to do what you just described? 2 MR. LIROT: Objection. Competency. 3 MR. FUGATE: I asked if she knew -- 4 THE COURT: I got it. Overruled. 5 A Yes. 6 BY MR. FUGATE: 7 Q And -- 8 A Since July of '98. 9 Q And do you know that for any particular reason? 10 A Well, I know that because for a lot of the time I 11 was either directing that he be paid or paying him myself. 12 Q And do you recall -- 13 A For Mr. Minton. 14 Q -- as you sit here what he was paid on a month's 15 basis from approximately '98 to whenever that payment 16 ceased? 17 A I would say -- well, starting in probably early 18 '99, I think -- I can't remember exactly when he started 19 being paid by Mr. Dandar as a consultant, but at least 20 starting at that point he was paid $5,000 a month up until 21 just last month. And before that, it wasn't as regular of a 22 payment, like a salary or something, but it was -- I would 23 say, you know, he was -- Mr. Minton was making sure he had 24 enough money every month to live. So 4- to $5,000 a month 25 probably. 0052------------------------------------------------------------------ 1 Q Now, I interrupted you on the meeting that you 2 were about to discuss in Philadelphia. Can you tell us what 3 happened at that meeting? 4 A Well, I think I started to say that Mr. Minton 5 told Mr. Dandar that he wasn't happy about the direction the 6 litigation was taking; he wasn't happy that -- specifically 7 he wasn't happy because both Jesse Prince and I had told 8 Mr. Minton that we didn't feel that Mr. Dandar really 9 understood Scientology; that he was paying lip service to us 10 about it, but that he wasn't really taking the time to grasp 11 it himself. 12 And for example, you know, I would write questions 13 or Jesse would write questions for him of a deposition of a 14 Scientologist, and Mr. Dandar wouldn't really listen to us 15 about how to ask the questions or what questions to ask or 16 whatever. And -- and we were very frustrated 'cause we felt 17 that Mr. Dandar was not competently addressing the 18 Scientology issues of it. 19 So Mr. Minton told Mr. Dandar that, and so did I, 20 at this meeting. 21 EXAMINATION 22 BY THE COURT: 23 Q That's what -- that's the question I have. What 24 are Scientology issues? 25 A Well -- 0053------------------------------------------------------------------ 1 Q What exactly were you concerned about? 2 A Well, for example, Lisa McPherson died while on 3 step zero of a -- of a process that is called the iso- -- 4 the introspection rundown. It's a Scientology practice. 5 And it's a -- it's a -- 6 Q Believe it or not, I know what it is. I do. 7 'Cause I -- 8 A Okay. 9 Q -- I've learned a lot about the introspection 10 rundown and step zero, and zero-zero. 11 A Okay. Well, then -- you know, this is a -- this 12 is a procedure that is the way a person who basically has 13 gone into a full-blown psychotic episode -- that's -- this 14 is what -- this is how they're treated for that in 15 Scientology. 16 And you know, I have been on an isolation watch, 17 as they call it. Mr. Prince had been on an isolation watch, 18 or more than one. I don't know. And so we -- we had some, 19 you know, experience ourselves in what Lisa McPherson had -- 20 what -- what had been happening for her. 21 Q What you believe -- 22 A Yeah. 23 Q -- would have happened to her. 24 A Would have happened, yes. 25 Q In an introspection rundown -- 0054------------------------------------------------------------------ 1 A Right. 2 Q -- step zero. And you had conveyed this to 3 Mr. Dandar? 4 A Right. 5 Q And you didn't think that he had adequately -- 6 A Well -- 7 Q -- expressed that. 8 A Well, yeah. And specifically -- 9 Q Here I am asking -- I'm sorry. I need you to tell 10 me. 11 A Well, at the time, as I recall, there were some 12 depositions of some of the people who had been involved in 13 her care, some Scientologists. And with other attorneys 14 that I have worked with, one of the things that I would do, 15 is I would actually compose questions for deposition and 16 actually interject some Scientology procedure into the 17 wording of the questions. 18 Like -- like there's a procedure in Scientology 19 which is called a security check or a confessional, and 20 that's a procedure where a person is asked a lot of 21 questions about various criminal things or unethical things 22 or, you know, in some other way things that they don't feel 23 good about having done. 24 And the whole point of the procedure for -- 25 according to the Scientology belief, is that this will help 0055------------------------------------------------------------------ 1 the person to sort of purge themself of all of these bad 2 things that they've done. And at the end they'll feel a lot 3 better 'cause now they've confessed all this stuff. 4 And so there's certain questions that during the 5 course of a security check the person will from time to time 6 ask the person. Like, "During this security check, have you 7 told me an untruth? During this security check, have you 8 told me a half truth?" You know, this kind of thing. To 9 just sort of make sure that the person's really, you know, 10 coming clean as you go along. 11 Well, I had worked with other attorneys and I had 12 suggested to them that whenever they're deposing a 13 Scientologist, they should pepper the deposition with these 14 kind of questions, because it would -- it would be very 15 startling for a Scientologist to have an attorney from the 16 other side asking him things that obviously indicated that 17 he understood something about Scientology. And it would 18 perhaps, you know, cause the person to be more likely to 19 tell him things that they might not otherwise be willing to 20 tell him. 21 Anyway, that was my idea. 22 Q Okay. 23 A So that's an example of what I meant. 24 Q So when -- but I still am -- I'm still not 25 clear -- and I think this is somewhat critical -- is when 0056------------------------------------------------------------------ 1 you -- when Mr. Minton was there and you were there and you 2 said we want you to inject Scientology issues into the case, 3 you said that, you know, you had told Mr. Dandar about step 4 zero -- I'm not maybe saying step zero -- but zero, and what 5 would have happened there. And I guess you didn't feel he 6 had adequately covered that? 7 A Right. We didn't feel that he was really 8 understanding how -- you know, just how terrible all this 9 Scientology stuff really was. That was my feeling at the 10 time. That he -- you know, here he is and he's supposed to 11 be litigating this case about this woman who died in 12 Scientology's hands and he's not even learning enough about 13 Scientology to really understand about how to go about, you 14 know, putting the Scientology part in his pleadings or -- or 15 in the depositions or -- or in his responses to the 16 Scientology stuff that was, you know, going back and forth 17 and -- 18 Q So at least at the time in Philadelphia, on 19 whatever date it was in October of '99 -- 20 MR. FUGATE: August, I think it said. 21 THE COURT: August, I'm sorry, of '99. 22 BY THE COURT: 23 Q -- you were not suggesting anything that he put in 24 anything that was untrue. You were suggesting that he deal 25 with Scientology issues that you had told them were 0057------------------------------------------------------------------ 1 accurate, I gather. Is that it? 2 A Well, you know I felt -- you know, I had been -- 3 it had been my job since 1993 -- this is now 1999 -- and it 4 had been my job to litigate against Scientology. And so, 5 you know, my whole -- my whole perspective was to view all 6 of the things that were involved in Scientology as harmful, 7 and that, you know, Lisa McPherson's involvement in 8 Scientology had been harmful, and that -- from the beginning 9 of getting into Scientology I -- you know, I was going 10 through a lot of papers having to do with her history in 11 Scientology and whatever. 12 And I was doing what I had always been doing, 13 which was going through and finding, you know, all the 14 negative aspects of her experience in Scientology, you know, 15 that -- so that Mr. Dandar could use that as part of the 16 background for his attack on Scientology as part of the 17 case. 18 Q So that I'm clear -- and I'm not sure that I am -- 19 the step zero, that being the isolation, for lack of a 20 better word, part of the introspection rundown -- 21 A Right. 22 Q -- that you were very familiar with, you had 23 participated in one -- 24 A Yes. 25 Q -- you therefore thought you had some insider 0058------------------------------------------------------------------ 1 information about what Lisa McPherson probably went through 2 based on your own experience. 3 A Exactly. 4 Q What you told Mr. Dandar or your frustration with 5 Mr. Dandar or what you and Mr. Minton told Mr. Dandar about 6 the fact that he wasn't exploring this adequately, was the 7 information you had given him about step zero on the 8 introspection rundown that you wanted him to include true 9 from your perspective? 10 A Yes. From my -- 11 Q That's what you believed had -- had happened to 12 her, and he wasn't -- he wasn't exploring it. 13 A That's right. 14 Q Okay. 15 A That's right. 16 Q So that was at that meeting. 17 A Right. 18 Q Was there anything else about Scientology issues 19 that you all talked about at that meeting? When Mr. Minton 20 was there and you were there? 21 A You know, your Honor, I think we spoke about it in 22 fairly general terms. I was -- as I said, I was concerned 23 about the fact that his main trial consultant was directly 24 at odds with what Mr. Minton wanted and what I wanted. And 25 I was feeling that Mr. Dandar was being counseled away from 0059------------------------------------------------------------------ 1 the direction that Mr. Minton wanted Mr. Dandar to be going 2 in. And so we were speaking in more general terms about 3 that situation that we saw; that -- that Mr. Minton was 4 funding the estate in order to bring a case against 5 Scientology's practices that caused Lisa McPherson's death. 6 He wasn't funding a wrongful death case in which somebody 7 just died because of negligence or something. 8 Q Some workers just didn't do a good job. 9 A Right. He wasn't -- I mean, you know, that wasn't 10 what he was doing. He was engaged in a very specific 11 anti-Scientology campaign, and that's -- you know, 12 everything that he was funding was to further that. 13 Q At -- what the practices of Scientology were; 14 what -- all of that. 15 A Yes. 16 Q Okay. And once again, all of that against the 17 Scientology -- were those all things that you had told 18 Mr. Dandar were probable in light of the fact that you were 19 there? 20 A Well, yes, they were -- they were probable in 21 light of the fact that I had been in Scientology. I hadn't 22 ever known Lisa and I had left before -- I mean, I'd never 23 known her. I'd left before anything ever happened to her. 24 But -- but as I said before, it was my job to basically 25 fabricate some areas based on my experience. 0060------------------------------------------------------------------ 1 Q Well, I -- 2 MR. FUGATE: Your Honor -- 3 BY THE COURT: 4 Q That's my problem. How do you fabricate a 5 scenario based on your experience? Was your experience one 6 thing and you were fabricating some -- fabricating means 7 that this is your experience, A, and you know that that's 8 what would have happened, and you are fabricating B. 9 A All right. 10 Q Or are you saying that your experience was A and 11 you were -- or won't use the word fabricate, but you were 12 expressing A -- in other words, was the truth A and you were 13 coming up with B, or were you suggesting the truth is A and 14 you need to exploit it? 15 A I think I'd have to say it was a little bit of 16 both. 17 You know, of course, at the time I felt that -- 18 that everything I was saying was quite true. I think I'd 19 have to say that because of -- because of the responsibility 20 I felt I had to the attorneys that I was working for, I 21 think I would have to say that I took A and used A to 22 extrapolate -- extrapolate into B. In other words, I took 23 what had been my experience and then kind of hypothesized, 24 based on that, into situations that were maybe not quite 25 exactly the same as what I experienced or, you know, maybe I 0061------------------------------------------------------------------ 1 could interject my experience into it, but -- but then I 2 also went a little bit further than that too. 3 THE COURT: Could I just have one more 4 question? I'm sorry to interrupt your flow here. 5 MR. FUGATE: Go right ahead, Judge. 6 BY THE COURT: 7 Q When you're saying it's something that the untruth 8 of it is, are you suggesting that the untruthfulness was a 9 little bit like those declarations where you're saying you 10 have personal knowledge of something or you know something 11 is true, have reason to believe something's true, that you 12 didn't? 13 A Yes. 14 THE COURT: Okay. 15 MR. FUGATE: Can I ask a question? 16 THE COURT: Sure. I'm sorry. Yes, you can. 17 DIRECT EXAMINATION (Resumed) 18 BY MR. FUGATE: 19 Q Were you mixing fact and fiction? Is that what 20 you're saying? 21 A That would be one way to put it. I think I'd try 22 to be a little kinder to myself and say I was mixing facts 23 and hypothesis. 24 Q All right. But the purpose of the hypothesis 25 was -- was it to attack religious beliefs and practices? 0062------------------------------------------------------------------ 1 A Well, yes, in furtherance of the goals of whatever 2 litigation I was working on. 3 Q In other words, you -- you weren't trying to 4 say -- ask these questions 'cause it's going to eliminate a 5 great practice; you were trying to take a practice and make 6 it somehow bad? Is that what you're saying? 7 A Yes. 8 EXAMINATION 9 BY THE COURT: 10 Q But was it a true practice; whether it was good or 11 bad, whoever might be the beholder, was it a practice that 12 you knew to be true? 13 A Yes. But it was a practice that when I was in 14 Scientology I knew to be good, but then when I got out of 15 Scientology, I knew it to be bad. So -- 16 Q But -- 17 A That's what I mean by the perspective of it. 18 Q I guess what would be important for me to 19 understand is that you obviously were in the Church of 20 Scientology, you knew a lot about it -- 21 A Yes. 22 Q -- and whatever you thought when you were in it 23 was good and when you were out of it was bad. Were you, 24 when you were telling others who didn't have a clue, like 25 me -- 0063------------------------------------------------------------------ 1 A Mm-hmm. 2 Q -- and like Mr. Dandar, I take it at some point in 3 time, were you relating truthful information as far as what 4 had happened in Scientology or were you saying to them, 5 "This is what happens in Scientology, but that actually 6 doesn't sound so bad, so I'm going to tell you about this 7 and I can testify to it, but it really isn't true --" 8 I mean, I guess what I'm trying to say is were you 9 passing on what you learned that you had decided at one time 10 was good and now you've decided it was bad? 11 A That's how I felt about it at the time. 12 Q So you didn't feel like you were lying to all 13 these people, did you? 14 A I didn't feel like I was. 15 Q You felt like you were passing on the expert 16 testimony that -- the consulting ability that you had having 17 been at one time an insider -- 18 A Yes. 19 Q -- and that you were giving them the information 20 as an insider that they needed to know to pursue whatever 21 they were pursuing. 22 A Yes. And -- but taking it a little bit further 23 than that 'cause they were asking me for a little bit more 24 than that -- 25 Q Okay. 0064------------------------------------------------------------------ 1 A -- they were asking me for help in putting a spin 2 on it that would further the -- the particular goals that 3 they had for the litigation. 4 THE COURT: Okay. And that might be important 5 to follow up, and I'm going to let you follow up on 6 that because I've been going far too long. Like the 7 spin on this case that she was asked. 8 MR. FUGATE: That's where I would -- 9 THE COURT: Well, let's have it. Then we'll 10 take a break. 11 DIRECT EXAMINATION (Resumed) 12 BY MR. FUGATE: 13 Q All right. Using the word spin, if we can 14 complete the Philadelphia meeting, then I'm going to come 15 back to what you were doing. But was the spin what 16 Mr. Minton was looking for and what he was paying for, to 17 your observation and knowledge? 18 A Well, I would say yes, but I have to explain that 19 a little bit. 20 Mr. Minton was never in Scientology. 21 Q Mm-hmm. 22 A So Mr. Minton's understanding of Scientology was 23 not as good as he thought it was. 24 Q Okay. 25 A He thought he had a very good understanding of it. 0065------------------------------------------------------------------ 1 But he didn't have as good an understanding of it as he 2 felt. 3 Mr. Minton's education about Scientology came from 4 the Internet. And he had learned what he knew about 5 Scientology from, I guess you'd have to say, the most vocal 6 critics of Scientology. And the most disaffected 7 Scientologists, I guess. 8 And so he -- he had a -- he didn't -- he didn't -- 9 he didn't look at it as a spin. You know, he looked at it 10 as the truth, you know; that Scientology was a bad thing. 11 It was an evil thing and it had to be gotten rid of and that 12 was his job. I mean, that was his, you know, crusade, I 13 guess. 14 Q And was that the subject matter of the meeting 15 that you're talking about; was that sort of the attitude of 16 what was being -- 17 A Yeah. 18 Q -- conveyed in the August of 1999 Philadelphia 19 meeting? 20 A Yes. 21 EXAMINATION 22 BY THE COURT: 23 Q I think you're going to have to be more specific. 24 I want to know -- I mean, I know one specific now. What's 25 specific? Because that's what we need to get down here to. 0066------------------------------------------------------------------ 1 A Are you asking me what's specific? 2 Q Yeah. In mean, in this meeting, we know that 3 there was some discussion about the isolation and zero -- 4 A Well -- 5 Q -- whatever. I don't even recall the terminology. 6 A You know, I'm not sure that we specifically talked 7 about step zero. 8 Q Okay. I'm sorry. 9 A You know, like I said, we were talking about it in 10 pretty general terms. 11 Q Okay. Then tell us what those were. In other 12 words, I need to know, really, what you all told Mr. Dandar 13 at that meeting. 14 A Okay. 15 Q To the best of your recollection, and I do 16 understand that it was some time ago. 17 A Yeah. 18 Mr. Minton started out saying, "Look, I realize 19 that I'm not supposed to be controlling this litigation, but 20 I got to tell you, that if you don't start emphasizing 21 Scientology more than you've been doing and if you don't 22 start focusing on the -- on the destructive practices that 23 led to Lisa McPherson's death in this litigation, I really 24 don't understand why I'm funding it. So I understand that, 25 you know, I'm not supposed to control it. But I'm telling 0067------------------------------------------------------------------ 1 you that it's not going in a direction that I'm going to 2 want to still fund." 3 So that was sort of how it started. And then -- 4 and then I talked about, you know -- and I mean, it was an 5 uncomfortable meeting because I was -- you know, I told him 6 that I didn't feel like he was really -- you know, I told 7 him that I didn't feel like he was really concentrating on 8 the Scientology practices in the case, and that the whole 9 case was about the Scientology practices. You know, it 10 wasn't just a plain wrongful death case; it was a woman who 11 was -- who was killed by Scientology. 12 Q And you believed that to be the case? 13 A I did. 14 Q And you passed that information on to Mr. Dandar 15 and said that's what needed to be explored here based on 16 your experience as a Scientologist? 17 A Right. 18 DIRECT EXAMINATION (Resumed) 19 BY MR. FUGATE: 20 Q When you're saying Mr. Minton was dealing with the 21 most vocal critics of Scientology and he didn't quite 22 understand Scientology, do we take that to mean that he was 23 even more critical of Scientology? 24 A Yes. 25 Q And was it his purpose, as you understood it, 0068------------------------------------------------------------------ 1 regardless of what your position was, and Mr. Minton's 2 position was, to attack the religion, to attack the 3 religious beliefs -- 4 A Yes. 5 Q -- and practices? 6 And is that what he was talking to Mr. Dandar 7 about? 8 A Yes. 9 Q And was there -- were there any conversations -- 10 and tell us if there were or weren't, what they were -- 11 about how he wanted to have that done, how he wanted the 12 practices attacked? 13 A Well, he wanted -- he -- specifically he wanted 14 Mr. Dandar to start doing what -- what Mr. Prince and I were 15 advising him to do. And like I said, you know, it was sort 16 of -- it was sort of, generally speaking, for him to stop 17 worrying about, you know, experts, about vitreous fluid and 18 all these other things that he was doing and start putting 19 his attention on -- on educating the court about the 20 destructive practices that had led to Lisa McPherson's 21 death. 22 Q And what did Mr. Dandar say? 23 A He said -- you know, he said, "Okay, I see your 24 point." He said, "Okay, I see your point." And then Bob 25 gave him a check for $250,000. 0069------------------------------------------------------------------ 1 Q And after he got the check for $250,000 -- do you 2 know, by the way, whether it was made out to Ken Dandar as a 3 loan or if it was made out to Lisa McPherson litigation? 4 MR. LIROT: Objection. Competency. 5 THE COURT: He asked if she knew. 6 A I don't know. 7 BY MR. FUGATE: 8 Q And the check would speak for itself? 9 A I -- 10 Q Whatever it says. 11 THE COURT: If you're done with that 12 conversation, this would be a good time to take a 13 break. 14 MR. FUGATE: Let's take a break, Judge. 15 THE COURT: I want you to finish with what went 16 on in October. And I have -- 17 18 MR. LIROT: August. 19 THE COURT: -- one question to ask -- 20 MR. LIROT: August. 21 THE COURT: I'm sorry. I keep saying October 22 and you keep correcting me. It's August. 23 MR. FUGATE: It just seems like it. 24 THE COURT: I'm sorry. 25 0070------------------------------------------------------------------ 1 BY MR. FUGATE: 2 Q There was a check that was given to Mr. Dandar by 3 Mr. Minton at the meeting? 4 A Yes. 5 Q Okay. And you just didn't see the check, is that 6 where we -- 7 A Well, I mean, I saw him write it, but I -- 8 Q Didn't pay any attention to what it said. 9 A I didn't really. 10 Q And after that check was given to Mr. Dandar, did 11 the -- were there other iterations or other complaint 12 renditions filed in shortly thereafter? 13 A I believe shortly thereafter -- I can't remember 14 which amended complaint it was, but there was an amended 15 complaint filed pretty -- pretty soon after that. 16 Q And who participated in the drafting of that 17 complaint to your knowledge? 18 A Well, I did, Jesse Prince did -- I mean, that was 19 the complaint that was based on Jesse Prince's affidavit. 20 MR. FUGATE: This would be a good time to 21 break, Judge. 22 THE COURT: Okay. I have a couple questions 23 about that. 24 25 0071------------------------------------------------------------------ 1 EXAMINATION 2 BY THE COURT: 3 Q When you say you participated in the drafting of 4 the complaint, this was at -- I guess you were a consultant 5 at that time of the firm of Mr. Dandar? 6 A Well, I wasn't being paid by Mr. Dandar anymore. 7 Q Were you being considered his expert or his 8 consultant, either one? 9 A I'm not sure what he was considering me to be. I 10 was basically there to make sure that Mr. Minton's -- 11 Q Okay. 12 A -- instructions were being followed. 13 Q Mr. -- Mr. Prince, I take it, was their -- 14 A Mr. Prince was -- at that time -- 15 Q -- consultant or an expert -- 16 A -- was being -- 17 Q -- or something. 18 A -- paid by Mr. Dandar, yes. 19 Q Okay. And the destructive practices that led to 20 the death of Lisa McPherson -- in other words, you said 21 Mr. Minton said, "I want the destructive practices that led 22 to the death of Lisa McPherson included" -- did he believe 23 and did you believe those, whatever they are, to be the 24 truth as far as what had happened, based on your knowledge 25 and his, "I don't like Scientology." 0072------------------------------------------------------------------ 1 A Yes. 2 Q Okay. And -- and so in the participation in the 3 drafting, whether it was you and/or Mr. Prince, or you, 4 Mr. Prince, Mr. Dandar, Dr. Garko, and the complaint was 5 done, did you believe it contained those practices that you 6 felt led to the death of Lisa McPherson? 7 A Well, your Honor, I didn't know -- 8 Q I understand that. 9 A -- what led to the death of Lisa McPherson. But 10 it contained a very plausible scenario. 11 Q That based on your experience you thought was 12 plausible -- 13 A It was possible. 14 Q -- and Mr. Dandar learned this, I take it, at 15 least to some extent, from you, Jesse Prince, all the people 16 he had consulted with about Scientology practices. 17 A Yes. 18 Q Is there anything you told him to include in his 19 complaint that you knew to be false? 20 A No. 21 THE COURT: Okay. That's all I have. Let's 22 take a break. 23 And by the way, you're on the stand and you 24 need to understand that while -- I didn't do this 25 with Mr. Dandar because he's the lawyer in the 0073------------------------------------------------------------------ 1 litigation -- you really can't consult with anybody 2 or confer with anybody even about your testimony 3 while you're a witness. 4 THE WITNESS: Not even -- I can't even talk to 5 my own attorney? 6 THE COURT: I don't know the answer to that. I 7 know a defendant can. And I mean a defendant in a 8 criminal case. I don't think anyone else can. 9 MR. LIROT: I think you're correct. 10 THE COURT: So the answer is no. 11 THE WITNESS: Okay. 12 THE COURT: You can't. I think I'm right on 13 that. You check it. A criminal defendant, they 14 finally said, if it's too long a break and you don't 15 let a criminal defendant talk, it's error. Other 16 than that, nobody gets to talk to their lawyer. So 17 you're not a criminal defendant, so you do not get 18 to. 19 THE WITNESS: All right. Your Honor. 20 THE COURT: All right. But that doesn't mean 21 you have to sit there. You're free to go. You're 22 free to go have water; you're free to use the rest 23 room, take a smoke, whatever you want to do. 24 THE WITNESS: All right. Thank you. 25 THE BAILIFF: What time, your Honor? 0074------------------------------------------------------------------ 1 THE COURT: Oh, what time is it? It's 20 2 minutes till 3. 3:00. 3 MR. FUGATE: Yes, your Honor. 4 (A recess was taken.) 5 THE COURT: Okay. Mr. Fugate. 6 MR. FUGATE: Ready to proceed? 7 THE COURT: I sure am. 8 MR. FUGATE: May I approach the witness, your 9 Honor? I'm going to hand her up, Counsel, the 10 affidavit of Jesse Prince that she just made 11 reference to in the filing of the fifth amended 12 complaint. 13 MR. LIROT: What's the date of the affidavit, 14 Mr. Fugate? 15 MR. FUGATE: It's sworn and subscribed the 20th 16 day of August, 1999. 17 THE COURT: Is that the one that you all 18 provided me yesterday? 19 MR. LIROT: No. That one -- 20 MR. FUGATE: Oh, they provided. No. 21 THE COURT: Somebody provided me. 22 MR. FUGATE: I promise you I didn't provide you 23 the one yesterday. 24 THE COURT: Okay. 25 MR. FUGATE: May I approach, your Honor? 0075------------------------------------------------------------------ 1 THE COURT: Remember yesterday I said I have 2 not seen the affidavit -- 3 MR. WEINBERG: Yes, I did. 4 THE COURT: -- of Jesse Prince? 5 MR. WEINBERG: I did. 6 THE COURT: Is that it? 7 MR. FUGATE: Listen, I'm sorry. I thought it 8 was the one that they had just -- 9 MR. WEINBERG: I'm pretty sure, your Honor, 10 it's the August 20th one I gave you yesterday. 11 THE COURT: Okay. 12 MR. FUGATE: Sorry, Judge. 13 THE COURT: That's all right. 14 Let me make sure I have the same one. I've got 15 it -- I say it's first affidavit of Jesse Prince 16 'cause I don't know if it's true, but it's the first 17 one I know about. 18 MR. FUGATE: The one that I -- may I approach, 19 your Honor? 20 THE COURT: You may. 21 MR. FUGATE: I'm talking about the one at -- 22 sworn and subscribed the 20th day of August, Donna 23 West, notary -- 24 THE COURT: Yes. 25 MR. LIROT: May I approach and make sure we're 0076------------------------------------------------------------------ 1 looking at the same document? 2 THE COURT: Sure. 3 MR. FUGATE: 18 pages, stops at 45 -- 4 THE COURT: 18 pages dated the 20th day of 5 August of '99, signed by Jesse Prince, notarized by 6 Donna West. 7 MR. LIROT: That looks to be the document that 8 I have, Judge. 9 THE COURT: Okay. 10 MR. FUGATE: We're all on the same page? 11 THE COURT: We're all on the same page. 12 BY MR. FUGATE: 13 Q Is this the affidavit that you made reference to 14 which was filed to support the fifth amended complaint 15 engaging a more direct attack on Scientology? 16 MR. LIROT: Objection. Foundation. I don't 17 know if she ever looked at the affidavit at that 18 point in time. 19 THE COURT: Yeah. If she knows. 20 BY MR. FUGATE: 21 Q Do you recognize the affidavit? 22 A Yes. 23 Q Did you have anything to do with it at or about 24 the time it was prepared? 25 A Yes. 0077------------------------------------------------------------------ 1 Q Okay. And what did you have to do with the 2 preparation of it? 3 A Well, Mr. Prince and I had a number of 4 discussions. 5 Q I didn't hear you, I'm sorry. 6 A I'm sorry. Maybe this is off. 7 THE COURT: I think it is. Can we turn the 8 system on? Let's see if we can get the system on. 9 It'll help. 10 BY MR. FUGATE: 11 Q If we can't, just speak up. 12 A Okay. I'm sorry. What was the question? 13 THE COURT: It's obviously on now. 14 MR. FUGATE: It's on. 15 A What was the question again? 16 BY MR. FUGATE: 17 Q Did you take part and assist in the preparation of 18 this affidavit? 19 A Yes. 20 Q Now, if you flip to page 17, I'm going to ask you 21 to read paragraph 43 to yourself. 22 THE COURT: Tell me again, which one? 23 MR. FUGATE: Page 17 of the Prince affidavit. 24 It's the paragraph enumerated 43. 25 THE COURT: Okay. 0078------------------------------------------------------------------ 1 BY MR. FUGATE: 2 Q Have you had a chance to read it? 3 A Yes. 4 THE COURT: I haven't quite, so let me just -- 5 MR. FUGATE: Oh, I'm sorry, Judge. 6 THE COURT: Give me just another couple 7 seconds. 8 Okay. I've finished it. 9 BY MR. FUGATE: 10 Q What it says, "It's apparent to me that these 11 individuals, Mithoff, Rathbun, Miscavige, had no option 12 other than permit her to die in isolation rather than take 13 her to a hospital for emergency medical treatment and risk 14 embarrassing questions from attending physicians, etc." Was 15 that true? 16 MR. LIROT: Objection. Competency. It's not 17 her affidavit. 18 THE COURT: Well, she said she assisted in it 19 and I think, therefore, that she can say whether or 20 not they discussed this and that type of thing. So 21 I'm going to overrule the objection. 22 BY MR. FUGATE: 23 Q Was that true? 24 A No. 25 Q When it says that, "Scientology provides an option 0079------------------------------------------------------------------ 1 called end cycle, which is permitting and ordering a person 2 to die," was that true? 3 A No. 4 Q Is there such a thing as an end cycle, as it's 5 portrayed here? 6 A No. 7 I know where it started. 8 MR. LIROT: Excuse me. Objection, based on 9 competency. 10 THE COURT: Overruled. If she was in the 11 church, she says she was -- 12 MR. LIROT: We don't know to what level. We 13 don't know if she was on the same level as 14 Mr. Prince, Judge. 15 THE COURT: Well, I don't know that. 16 EXAMINATION 17 BY THE COURT: 18 Q Would you know if there was -- 19 What level were you at? 20 A Well, I was a Class 4, XDn auditor, OT5. 21 Q Doesn't mean a thing to me. Would you -- have you 22 ever heard of anything called end cycle? 23 A Yes. 24 Q Did you know what it was? 25 A Yes, your Honor. Actually, that term first began 0080------------------------------------------------------------------ 1 being used in this context in the first case that I worked 2 on in 1993. Because the man -- 3 Remember when I was saying about Graham Berry, the 4 attorney? 5 Q Right. 6 A Well, the person that was his client was a man 7 named Steve Fishman, who was being sued by Scientology for 8 libel because he had been quoted in a TIME magazine article. 9 You remember that 1991 -- okay, well -- 10 Q I don't, I'm sorry. 11 A There was a big article about Scientology in TIME 12 magazine in 1991. And one of the things in the article was 13 Steve Fishman saying that he had been ordered by Scientology 14 to commit a murder and then to commit suicide. And this is 15 where this started. And he used this term, he was ordered 16 to do an end of cycle. 17 DIRECT EXAMINATION (Resumed) 18 BY MR. FUGATE: 19 Q Who used the term? 20 A Steve Fishman. 21 And so one of the first things that Mr. Berry 22 asked me was, what I knew about this ordering people to die 23 by end of cycle. And I told him that there was no such 24 thing in Scientology. 25 THE COURT: Okay. So whatever level you were 0081------------------------------------------------------------------ 1 at -- and somebody will have to explain whatever she 2 said, because I wouldn't know what level that was -- 3 But whatever -- is that a high level? Were you a 4 high level -- 5 THE WITNESS: It was a high level. 6 THE COURT: You know enough at your level to 7 know there was no such thing when you were in 8 Scientology called end of cycle or end cycle. 9 THE WITNESS: Right. 10 THE COURT: Okay. Your objection's overruled. 11 BY MR. FUGATE: 12 Q But did you craft a declaration that described end 13 cycle as something like this we see in Mr. Prince's 14 affidavit? 15 A Yes. 16 Q And did you assist in the crafting of this portion 17 of this affidavit describing the end cycle? 18 A Well, I assisted in getting Mr. Prince into the 19 proper frame of mind in which he could then write this. 20 Q And write this, paragraph 43 that I've just read 21 the two sections of, is not true, is it? 22 A Not to my knowledge. 23 Q Would you take a moment and read paragraph 44? 24 Are the allegations as set out in there, to your 25 knowledge, true? 0082------------------------------------------------------------------ 1 A No. 2 Q And would those allegations as set out in there, 3 to your knowledge, then be false? 4 A To the best of my knowledge. 5 Q And did you have any information at all that 6 Misters Mithoff, Rathbun or Miscavige had ordered the death 7 of Lisa McPherson? 8 A No. 9 Q Or that they had wanted to prevent what's 10 described here as a public relations flap and said, "Let her 11 die"? 12 A No. But that idea came from me. 13 EXAMINATION 14 BY THE COURT: 15 Q I'm sorry? 16 A I said no, but that idea came from me. 17 Q What idea? 18 A The idea that they would have let her die to avoid 19 a PR flap. 20 Q Did you -- did you come up with that idea thinking 21 it was true, or did you come up with that idea knowing it 22 was false and thinking it just would hurt them? 23 A I -- 24 Q Or something in between? 25 A I would say it was something in between. I 0083------------------------------------------------------------------ 1 certainly knew it would hurt them. 2 Q I think we can agree on that. 3 A Yeah. The -- but your Honor, I know for sure -- 4 Q Take your time. 5 A Sorry. 6 Q It's all right. 7 A I know for sure that these people didn't sit by -- 8 Q Who are these people? 9 A Scientology. 10 Q Okay. 11 A They didn't sit by and let her die. 12 THE COURT: Okay. Thank you. 13 DIRECT EXAMINATION (Resumed) 14 BY MR. FUGATE: 15 Q When you said a moment ago -- and I'm going to 16 come back to this -- that you -- words to the effect as -- 17 if I recall -- don't even trust my memory, I guess -- that 18 there was anti-Scientology critics. Was there a 19 fraternity-like atmosphere among those of you that were 20 critics of Scientology? 21 A Yes. 22 MR. LIROT: Objection. 23 THE COURT: Overruled. 24 BY MR. FUGATE: 25 Q And when you embarked on the career, at least that 0084------------------------------------------------------------------ 1 we've had described here from '93 to a couple of months ago, 2 your income was derived from being an anti-Scientologist and 3 a critic of Scientology, is that correct? 4 A Yes. 5 Q And are you saying to the court that you believed 6 in that period of time that what you were doing was right? 7 Is that what you've been saying to Judge Schaeffer? 8 A Yes. 9 Q But having said that, are these allegations that 10 are set out in Mr. Prince's affidavit true or false that I 11 just read to you -- had you read? 12 A They're false. But within that fraternity of 13 critics, I have come to feel now that -- and I have come to 14 feel that Mr. Dandar feels this way, and that -- well, the 15 people who are within that fraternity called critics of 16 Scientology feel so strongly a hatred for Scientology that 17 they feel that the end justifies the means, no matter what 18 it takes, to destroy Scientology. And I think that -- I 19 think that Mr. Dandar knew that to be the case with 20 Mr. Minton, and I think that he played on that and that 21 he -- 22 THE COURT: Who -- we've got two "he's" there. 23 We talking about -- 24 THE WITNESS: Mr. -- 25 THE COURT: -- Mr. Minton -- 0085------------------------------------------------------------------ 1 THE WITNESS: Mr. Dandar knew that Mr. Minton 2 felt that strongly against Scientology. And I think 3 that Mr. Dandar felt that he could play on that 4 animosity that Mr. Minton had, and that he did play 5 on that animosity that Mr. Minton had to encourage 6 Mr. Minton to lie under oath for the good of his 7 case. I have felt that I needed to lie under oath 8 for the good of this case. I have seen others -- 9 BY MR. FUGATE: 10 Q Have you lied under oath, as you say, for the good 11 of -- 12 A Yes, I have. 13 Q -- Mr. Dandar's case? 14 A Yes, I have. And I've seen others in this 15 proceeding lying under oath for the good of this case. 16 EXAMINATION 17 BY THE COURT: 18 Q Who? 19 A Ms. Liebreich and Mr. Dandar. 20 Q So you -- you believe that -- I believe you 21 believe that all of these people feel, as you indicated, the 22 critics of Scientology feel -- I think you said the means 23 ju- -- I think is -- 24 A The end -- the end justifies the means. 25 Q I think is the means justifies the end or -- isn't 0086------------------------------------------------------------------ 1 it? 2 A The end justifies the means. 3 Q Well, whatever -- we know -- 4 A You know what I mean. 5 Q I do. 6 A You would do anything to achieve the goal because 7 the goal is so righteous. 8 Q I think that would be the means justify the end, 9 which would be to abolish Scientology -- 10 A Okay. 11 Q -- or to get rid of Scientology -- 12 A Yeah. 13 Q -- or to -- 14 A Right. 15 Q -- make them look -- 16 A Yes. 17 Q And this is because of the -- what did you call 18 it, the hatred? 19 A The hatred. 20 Q And you were there at one time? 21 A Yes, I was. 22 Q Or maybe you still are? 23 Mr. Minton was there -- 24 A Yes, he was, but he's not anymore. 25 Q Okay. 0087------------------------------------------------------------------ 1 A And neither am I. 2 Q And you -- 3 A And it's not because I've been extorted by 4 Scientology. 5 Q Whoa, whoa. We're going to let someone else talk 6 about that. 7 But for now you believe and why you think that 8 this occurred is you think Mr. Dandar also hates Scientology 9 and so does Ms. Liebreich? 10 A I would say that Mr. Dandar thinks that he can 11 make a whole lot of money by using people who hate 12 Scientology. 13 Q So you think that this is a monetary thing for him 14 rather than -- 15 A Yes, I do, your Honor. 16 Q -- rather than a hatred of Scientology; rather 17 than sort of a -- what do we call that, sort of a strange 18 moralistic view. 19 A That's what I believe. 20 Q You think to him it's money. 21 A Yes. Yes, your Honor. 22 THE COURT: Okay. Thank you. 23 MR. FUGATE: May I approach the witness, your 24 Honor. 25 THE COURT: You may. 0088------------------------------------------------------------------ 1 I've got to go back to one thing 'cause this is 2 kind of important. 3 BY THE COURT: 4 Q You indicated that in 43 and 44, that in the 5 affidavit, that those items that were read to you by 6 Mr. Fugate were not true. And that you -- you had indicated 7 before that you and Mr. Prince had worked on them. I think 8 you even said you got him into the mood -- 9 A Yes, ma'am. 10 Q -- or whatever that meant, I don't know. Maybe 11 some of it's -- 12 A Into the state of mind. 13 Q What does that mean? 14 A In other words, I had many conversations with 15 Mr. Prince in which we discussed this scenario, in which she 16 was held against her will and these leaders of Scientology 17 were orchestrating this. And we talked about how 18 Mr. Miscavige would have been getting reports every day 19 about her -- about what was happening to her because it was 20 going to be such a PR flap. And I mean, you know I -- I 21 helped Jesse -- 22 Q Believe this? 23 A Believe this. 24 Q Okay. Did you ever -- this is what is important 25 to me. Did you ever tell Mr. Dandar that this information 0089------------------------------------------------------------------ 1 was false? 2 A No. I told Mr. Dandar the obvious, which was that 3 I wasn't there and neither was Jesse, so we couldn't 4 possibly know. 5 Q But you didn't say what you said in court, which 6 is this is false. 7 A No. 8 Q Okay. Thank you. 9 A I said this could have happened. 10 Q This -- so in other words, you told him that based 11 on your experience -- and obviously you weren't there, but 12 based on your experience -- 13 A This could have -- 14 Q -- this could have happened. 15 A -- happened. 16 Q And did Jesse tell him the same thing? 17 A Yes. And I think when Jesse testifies he'll tell 18 you that it did happen. 19 THE COURT: Okay. 20 DIRECT EXAMINATION (Resumed) 21 BY MR. FUGATE: 22 Q Well, let's talk about what you mean by it did 23 happen. 24 THE COURT: No. She said Jesse will say it did 25 happen. 0090------------------------------------------------------------------ 1 MR. FUGATE: No -- 2 BY MR. FUGATE: 3 Q Did Jesse Prince accurately describe something 4 called an end cycle in this affidavit or is that a false 5 statement as you said? 6 A It's my belief that it's a false statement, but 7 I'd like to talk about that for a minute -- 8 EXAMINATION 9 BY THE COURT: 10 Q Okay. 11 A -- if I could. 12 There is -- there is a series of procedures in 13 Scientology which is called a series of assists. An assist 14 is a procedure that's used to help a person when they're 15 sick. Various procedures to try to deal with what the 16 Scientologists believe is the cause of illness. And in one 17 of those issues about assists, I believe that I did see at 18 one point in my Scientology career an instruction when a 19 person was dying to help them be at peace about dying. And 20 I don't remember exactly 'cause this was a long time ago. 21 Q Sort of what Hospice might do? 22 A Kind of a Hospice thing. 23 And I believe that term, end of cycle, was used in 24 the description of that. Because -- because in 25 Scientology -- you know, a Scientologist believes that you 0091------------------------------------------------------------------ 1 live many lifetimes, and when you die, they call it an end 2 of cycle. Because when you finish -- you know, when you 3 finish breakfast, it's an end of cycle. It's an end -- an 4 ending of something. And I do believe that in -- there was 5 an assist instruction in which that term was used to 6 describe that process of helping a person die at peace. 7 Q Okay. 8 A And -- 9 MR. FUGATE: May I approach the witness, your 10 Honor? 11 THE COURT: You may. 12 MR. FUGATE: I'm showing her, Counsel, the 13 fifth amended complaint, which is filestamped -- 14 well, I can't read it without my glasses -- January 15 of 2000, I think. 16 BY MR. FUGATE: 17 Q I'm going to ask you to look at that -- 18 THE COURT: I take it this is the one we all 19 agree that -- that I've got in my book. 20 MR. LIROT: Yeah. Yes. 21 THE COURT: Okay. 22 Q I'm going to ask you to take a look at that and 23 flip to, if you would -- whatever -- 24 MR. LIROT: This is -- if I could ask the court 25 to verify I have the correct document, this is on 0092------------------------------------------------------------------ 1 page 18 of 18, with a certification dated 2 December 21st, 1999? 3 THE COURT: That's the one I have. 4 Ma'am, is that the one you have? 5 THE WITNESS: Let me see. Says 21 December. 6 MR. LIROT: Very good. 7 THE COURT: Now, where did -- 8 A You wanted me to read what? 9 BY MR. FUGATE: 10 Q If you would go to page 12, where it says count I, 11 statutory wrongful death. 12 A Okay. 13 Q And read paragraph 34 to yourself. 14 A Okay. 15 Q I'm sorry. Did you have an opportunity to read 16 it? 17 A Paragraph 34? 18 Q Yeah. 19 Now, is that description of end cycle in there a 20 description of an end of the cycle as you just described it, 21 an assist; or is it the concept that you imported and that 22 you had talked to Mr. Prince about putting into the wrongful 23 death complaint? 24 A It's the latter. It's the concept that I had 25 talked to Mr. Prince about putting in. 0093------------------------------------------------------------------ 1 Q And were you aware of your involvement with 2 Mr. Dandar of any information -- any fact that would support 3 that allegation in this lawsuit? 4 A No. 5 Q And was Mr. Prince aware of any, as far as you 6 knew, when he drafted the end cycle portion of the affidavit 7 that supported this allegation and allowed the complaint to 8 be filed? 9 MR. LIROT: Objection. Speculation. 10 THE COURT: Sustained. 11 MR. LIROT: She doesn't know what Mr. Prince 12 knew. 13 THE COURT: Sustained. 14 BY MR. FUGATE: 15 Q Well, the end cycle as described here is what you 16 said was your concept that you talked to and told Jesse 17 Prince about, is that correct? 18 A Yes. This was the use of end cycle that was 19 started by Steve Fishman. 20 Q And it's not a true concept, is it? 21 A No. 22 Q And it's not portrayed to be a true concept in the 23 affidavit or the complaint, is it? 24 MR. LIROT: Objection. Competency. She 25 doesn't know what was true.