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From: martinottmann@yahoo.com (Martin Ottmann)
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Subject: Federal Complaint II - Violations (a)
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IV) Violations Of U. S. Title 18

Chapter 13 - Civil Rights
Sec. 241 - Conspiracy against rights

"If two or more persons conspire to injure, oppress, threaten, or
intimidate any person in any State, Territory, Commonwealth,
Possession, or District in the free exercise or enjoyment of any right
or privilege secured to him by the Constitution or laws of the United
States, or because of his having so exercised the same; [ … ]

"They shall be fined under this title or imprisoned not more than ten
years, or both;"

Count 1: A four year campaign of harassment and intimidation conducted
by the Church of Scientology's "Office of Special Affairs" network
that targeted American citizen Robert Minton, his immediate family
members and his former business partners and that was designed to stop
Minton's exercise of his First Amendment rights.

From November 1998 until January 2001 the Church of Scientology's
"Office of Special Affairs" network (OSA) under the guidance of its
head and CSI's corporate director Michael Rinder has engaged in a
campaign to eventually intimidate Robert Minton from publicly
criticizing the organization and from financially aiding other critics
of Scientology.

Rinder and his subordinate members of OSA executed this campaign by
targeting in particular Minton's wife Therese, his two underage
daughters, his neighbours, his former business partners, his parents
and other relatives.

The harassment campaign against Minton consisted of four different
operations:

1. Private investigators hired by the "Church of Scientology
International" (CSI) conducted "noisy investigations" among Robert
Minton's parents, relatives and former business partners to spread
negative and derogatory information about Minton. The purpose of these
activities was to alienate Minton from his relatives, friends and
business partners.

2. Members of the OSA network, staff members and "parishioners" of the
Church of Scientology branch of Boston picketed numerous times the
home of Robert Minton in Boston knowing that his underage daughters
were living there as well. This was even done well after the time when
they were aware that Robert Minton had separated from his wife, that
he was living in Sandown, New Hampshire and that his daughters
continued living with their mother in Boston. The purpose of these
demonstrations was to increase the moral pressure on Robert Minton to
discontinue his activities directed at Scientology by harassing his
wife and his daughters.

3. Private investigators hired by CSI, members of the OSA network,
staff members and public members of the Church of Scientology branch
of Boston distributed leaflets and flyers with negative and derogatory
information about Robert Minton to the residents of the neighbourhood
in which he and his wife were living in with the purpose of alienating
him and his family from their neighbours and friends.

4. From the start and until the end of these operations against Robert
Minton, senior executives of CSI and the OSA network publicly
portrayed him in the worst possible manner in order to execute a
character assassination of Minton. These executives discussed apparent
embarrassing details of Minton's private life in a public forum and
even tried to interfere in Minton's relationship with his wife.

The following is a chronological list of selected incidents of the
above-mentioned operations, which were designed to intimidate Robert
Minton in such a way that he would finally cease criticizing the
Church of Scientology.

November 18th, 1997 - Elliot Abelson, general counsel for CSI sent a
letter to Minton, in which he threatened Minton with legal action by
the organization should he further financially support other critics
of Scientology [Exh. No. 81]. In the letter Abelson stated
specifically:

" [ … ] You appear to have undertaken the financial maintenance of a
significant number of litigants adverse to Scientology Churches in the
United States. [ … ] You're now even financing the travel of
hate-filled individuals, some of whom have already been prohibited by
courts from committing further acts of violence against members of the
Churches of Scientology, from across the United States to the Church
of Scientology's premises in Clearwater, Florida.

"You are, in this manner, a responsible party in fostering a climate
of hatred in Clearwater, which endangers our staff and parishioners
who work and live there. [ …]

"Association with lawbreakers such as these, combined with the
monetary demands that inevitably accompany their involvement in
litigation or similar fertile areas for attempts of extortion, make
your actions of interest to the prosecutors to whom such conduct has
been referred. My client holds you, your associates and backers,
financial or otherwise, personally responsible for any and all damages
it has suffered or will continue to suffer as a result of your
tortious officious intermeddling in Church litigation.

"The Church will not tolerate such conduct. I demand that you
immediately withdraw all financial support for such matters and am
warning you that you and those you're financing have crossed the
threshold of legality. I advise you to inform me forthwith what you
have done to cease fomenting and financing unlawful attacks against my
client. [ … ] "

December 9th, 1997 - On this day the "Boston Globe" reported about the
leafleting of Minton's Boston neighbourhood by Scientologists and on
comments of Scientology's senior executives about Minton's activities
[Exh. No. 30]:

" [ … ] Church officials accuse Minton of harboring hatred toward
Scientology and attempting to foment internal dissent. On Friday while
Minton was in Florida, several church members passed out fliers on
Beacon Hill with his picture, denouncing him.

"Frank Ofman, a spokesman for the Boston-area branch of the Church of
Scientology, said church members distributed the leaflets to highlight
Minton's bias.

"'The face of religious bigotry your neighbor, Robert Minton is not
all what he seems,' read the fliers, which were not identified as
coming from the Church of Scientology.

"'This week he is leading a KKK-style rally against peaceful members
of a religion. When he's not stirring up hatred in the streets, Minton
is poisoning the Internet by filling it full of religious bigotry and
intolerance.' [ … ]

"Church officials acknowledged that they have conducted their own
investigation into Minton's funding practices. ‘This is an extremely
shady character because he covertly engages in a campaign to harm our
religion,' said Kurt Weiland, director of external affairs for the
church. ‘It's immoral and quite frankly perverse.' [ … ] "

On the same day the "Associated Press" published also a story on
Minton. The article included statements of Scientology officials about
the organization's motive to investigate Minton [Exh. No. 32]:

" [ … ] ‘Who's behind this guy?' said Kendrick Moxon, an attorney for
the Church of Scientology. ‘The man is going to be sued because he has
committed torts all over the country and I want to know why is he
trying to destroy religion and create chaos.'

"Kurt Weiland, a Los Angeles-based spokesman for the Scientologists,
accused Minton of ‘covertly funding, and in this way, manipulating
litigation.'

"Members of the Boston-area branch of the church passed out flyers on
Beacon Hill last Friday, denouncing Minton. ‘This week he is leading a
KKK-style rally against peaceful members of a religion,' read the
flyer. [ … ]

"Weiland admitted the group's lawyers had hired at least one private
investigator to look into Minton's private life. ‘If it takes five to
get to the bottom of it to find out what are the hidden motives of
this man, I will gladly endorse our lawyers to hire five.' [ … ] "

January 6th, 1998 - On the Internet Minton reported that
Scientologists had distributed leaflets in the immediate neighbourhood
of his residence [Exh. No. 82]. The leaflet, which was issued by the
"Church of Scientology of Boston," stated [Exh. No. 83]:

"Hatred Hidden Behind ‘Free Speech'

"The face of religious bigotry: Your neighbor, Robert Minton of 39
West Cedar Street, is not all that he seems.

"He is leading a KKK-style attack against peaceful members of a
religion. When he is not stirring up hatred in the streets, Minton is
poisoning the Internet by filling it full of religious bigotry and
intolerance.

"Minton's hatred puts families at risk."

January 8th, 1998 - In another posting on the Internet Minton reported
that during the course of an investigation of his family background
the private detective David Lee had visited Minton's mother, two
brothers and his uncle [Exh. No. 84].

January 26th, 1998 – On this day a new flyer was distributed in the
area of Minton's home in Boston [Exh. No. 85]. The flyer read:

"MANY OF THIS MAN'S NEIGHBORS ARE ASKING WHAT'S YOUR REAL AGENDA?

"ROBERT MINTON, OF 137 FREMONT ROAD, SANDOWN, NH HAS GIVEN $ 1.25
MILLION TO COMPLETE STRANGERS TO DESTROY A RELIGION WHILE HIS MOTHER
LIVES ON SOCIAL SECURITY. HE EVEN PUT A LIEN ON HER HOUSE AND CHARGED
HER 10% INTEREST AS THE PRICE OF A LOAN.

"WHY IS HE SO MEAN AND CHEAP TO HIS OWN FAMILY WHILE SHOWERING RICHES
ON RELIGIOUS BIGOTS TO FUND THEIR HATE CAMPAIGNS? LIKE MANY HATE
MONGERS, HE HAS A HISTORY OF PSYCHIATRIC PROBLEMS.

"BUT A TROUBLED PAST IS NO EXCUSE FOR LEADING KKK-STYLE RALLIES AND
SPREADING POISON ON THE INTERNET ABOUT A PEACEFUL RELIGION KNOWN FOR
ITS HELPFUL LITERACY AND DRUG REHABILITATION PROGRAMS.

"WHAT'S YOUR GAME, ROBERT MINTON?

"This was written as a public service of STAND (Scientologists Taking
Action for Non- Discrimination)"

February 11th, 1998 - Minton reported about a picket in front of of
his Boston home on the previous day, where two Scientologists
demonstrated and handed out leaflets [Exh. No. 86]. On this occasion
Minton photographed the picketers [Exh. No. 87].

June 16th, 1998 - NBC aired a feature on Minton's "crusade" against
Scientology in its program "Dateline." The broadcast also discussed
the pickets by the Scientologists and the investigations of Minton by
the organization's private investigators [Exh. No. 33]:

[ … ] Hockenberry: (Voiceover) "There are plenty of critics of
Scientology against whom the church takes no action. But the
investigation of Robert Minton started last November, and it started
with his family back in Tennessee."
Ms. Carolyn Medwedef: "He came in and he said, ‘I am David Lee, and
handed me his card. I am an investigator and I want to talk to you
about Bob.'"

Hockenberry: (V) "Carolyn Medwedef is Bob Minton's aunt. She works as
a receptionist in her husband's dental office. And when investigator
David Lee, working on behalf of the church, just showed up one day in
the office waiting room, she says he wasn't just asking for
information, he was also giving it out."

Ms. Medwedef: "He was just trying to say that Bob had been terrible to
his mother, and that he thought Bob should help his mother and get off
of this Scientology kick."

Hockenberry: (V) "Lee then tracked down Bob's brothers, his father,
his son from a previous marriage, and both of his ex-wives."

Mr. Rinder: "You know, these people don't have nice things to say
about Bob Minton. His former wives talk about how he beat them up, and
his son is pretty upset about how he was mistreated by his father."

Hockenberry: (V) "Bob Minton denies beating his ex-wives, although his
first wife told DATELINE Bob hit her once. But there's no denying that
Scientology has managed to stir up a lot of old animosities. For
instance, Bob's son Rob says he's always had money issues with his
father. But learning from a Scientology investigator that his dad
spent a quarter of a million dollars to buy some strangers a house was
deeply upsetting. He told DATELINE this the last straw between him and
his father."

Mr. Minton: "The Church of Scientology destroys families. They know
how to stir those issues up. You know, they clearly were trying to do
the same types of things with the relationship between me and my son,
which is clearly a button that they saw I was vulnerable on and would
like to push."

Hockenberry: "And they pushed it."

Mr. Minton: "And they did."

Mr. Rinder: "His mother is upset about the fact that he's dishing off
hundreds of thousands of dollars to people whom he doesn't even know."

Hockenberry: "Now, we - let's …"

Mr. Rinder: "And yet, she does - has a mortgage on a house and he
gives her a loan rather than gives her money."

Hockenberry: "OK. A cynical view would say, if your investigator is
going to Bob Minton's mom and saying, ‘Did you know he's giving away
money?,' and she gets outraged, and that gets back to Bob, that sounds
more like harassment to me.

Mr. Rinder: "It sounds more like an investigation to me. But,
certainly, let - let's put the shoe on the other foot for a minute.
Bob Minton is going around to the media saying, ‘Did you know
Scientologists do this, did you know Scientologists do that?' You
know, he characterizes that as free speech."

Hockenberry: "Well, it is free speech."

Mr. Rinder: "Well, certainly it's no different."
Hockenberry: (V) "But Bob Minton says there's a significant
difference. Scientology is a powerful organization that seeks out the
powerless, to stir up trouble. Bob's mother has severe emphysema and
dementia, and Bob's aunt Carolyn says the investigator took advantage
of her, confusing her, putting words in her mouth and taking other
statements out of context."

Mr. Medwedef: "She has been in the hospital emergency twice since
then. She's in a nursing home. It devastated her when she found out
what David Lee did."

Hockenberry: (V) "And Bob's current wife, Therese, says the church has
brought its campaign right to her doorstep. Leaflets about Bob arrived
on their daughter's birthday."

Hockenberry: "Which said what?"

Mrs. Therese Minton: "Oh, Bob's a member of the Ku Klux Klan, he's a
religious bigot, he's suppressing - the most un-, unbelievable
garbage."

Hockenberry: (V) "Therese Minton says hate leaflets, that church
leaders deny having anything to do with, also found their way to the
family's vacation this past spring. On the beaches of the Caribbean,
Minton was accused of having ‘exploited the people of the third-world
countries' to make millions, of brutally beating his ex-wives, and of
and ‘supporting a ring which includes wife beaters, child molesters
and a pornography editor.' In fact, by this April, Minton says church
investigators had managed to badmouth him to most of the people he had
ever worked with or known, going back decades and on four continents."

Mr. Minton: "It is pure and simple harassment. You know, they've tried
to turn my family against me, they've tried to paint me as some insane
person."

Hockenberry: (V) "An associate of Minton says the investigators
chillingly dropped hints that he was unstable, worried that Bob would
suddenly walk into a church and begin shooting Scientologists."      [
… ]

When asked for a comment during an interview for the show, OSA chief
Michael Rinder denounced Minton as a criminal:

[ … ] Mr. Rinder: "Bob Minton falls into a category similar to those
anti-Semites who are out to make it seem like there is something wrong
with being a Jew."

Hockenberry: (V) "Senior Scientology Official Mike Rinder and his
colleagues at the church think Minton is an impressionable man who's
been manipulated by the critics and misinformed." [ … ]

Hockenberry: "L. Ron Hubbard says, ‘we do not find critics of
Scientology who do not have criminal pasts. Over and over we prove
this. We have this technical fact: Those who oppose us have crimes to
hide.' Do you believe that?"

Mr. Rinder: "Sure."

Hockenberry: "People who oppose you are undoubtedly criminals?"

Mr. Rinder: "I believe that, yeah."

Hockenberry: "Is Bob Minton a criminal?"

Mr. Rinder: "I think that we will - we will discover that at some
point." [ … ]