DECLARATION OF STACY BROOKS 1. My name is Stacy Brooks. I have personal knowledge of the matters set forth in this declaration, and could testify competently to them if called upon to do so.

2. In the days leading up to his scheduled deposition in the case of Scientology vs. Liebreich, Robert Minton informed me of his intention to attend his deposition in Florida on August 3, 2001.

3. On Mr. Minton's behalf, I made airline reservations for him to travel to Florida on August 2, 2001, leaving New England at approximately 2:00 p.m. Over the course of the events of the afternoon and evening of August 2, 2001 described below, I revised those reservations to provide departure times at approximately 6:00 p.m. and 9:30 p.m. Shortly before Mr. Minton and his therapist informed me of their decision, I had determined the availability of a flight leaving New England at approximately 6:00 a.m. on August 3, 2001.

4. On August 2, 2001, I was contacted by Mr. Minton and informed that he had seen on the internet the posting attached to his Response as Exhibit 3. Mr.

Minton was seriously upset by the invasion of his and his children's privacy by Scientology or its agent and by the obviously illegal means used by Scientology to obtain such private information.

5. Soon after I had that discussion with Mr. Minton, he learned that the neighborhood where his minor daughters live had been papered by Scientology with fliers as shown in Exhibit 4 to Mr. Minton's response. This information caused Mr. Minton to become further upset as he felt that the posting of his and his children's personal information, some of which was inaccurate, on the internet and the distributing of fliers in his children's neighborhood in which he and their mother were accused of criminal actions were deliberate assaults on his privacy and on the privacy of his children.

6. I spoke to Mr. Minton several times over the course of the evening of August 2, 2001. From these conversations it was clear to me that he was extremely upset and that he felt his privacy and the privacy of his children had been profoundly and criminally violated by Scientology agents.

7. I encouraged Mr. Minton to travel to Florida for his deposition. It was my opinion that the harassment by Scientology agents had been specifically timed to interfere with the next day's deposition and I told him so. At first he decided that he would attend the deposition, despite the harassment. I was also aware that Mr. Minton had been in communication with a therapist during the afternoon and evening. During the evening of August 2, I spoke to the therapist myself.

8. In conversation, the therapist confirmed my own assessment of Mr. Minton's state of mind and stated in the strongest terms that he should not travel to Florida for deposition on August 3, for the reason that the stress and distress of such activity would further exacerbate his condition, because Mr. Minton had been attacked at such a fundamental level, with Scientology assaulting the privacy and sanctity of his own health care and attacking his family, especially his minor children. I knew from my conversation with Mr. Minton that he felt strongly that Scientology's actions should be the subject of an Order to Show Cause for a contempt citation under the Permanent Injunction issued by a Pinellas County Circuit Court Judge with effect from August 1, 2001, and it was my understanding that the therapist felt that Mr. Minton should be assured of some protection from further harassment in the deposition before he should attend.

9. Finally, at about midnight on the night of August 2, 2001, Mr. Minton advised me that, based on the recommendation of his therapist, he was not willing to travel to Florida for deposition on August 3, 2001, but would appear at a later time, when he could be confident that he was no longer subject to an immediate assault on himself and his family.

10. In the days following the foregoing events, I repeatedly contacted the therapist, asking that the therapist testify by affidavit, deposition, or in person concerning Mr. Minton's state of mind on August 2 and the therapist's recommendations concerning the deposition. It became clear to me that the therapist was well aware of the vicious attacks Scientology has mounted on the mental health profession generally, and the horrifying assaults launched on anyone, regardless of profession, who actually opposes Scientology. The therapist was unwilling to take the risks involved in being publicly named as a mental health professional assisting an opponent of Scientology. The therapist would not cooperate in any way with Mr. Minton's request to come forward to confirm the events of the night of August 2.

Under penalties of perjury, I declare that I have read the foregoing declaration and that the facts stated in it are true.

________________________________ STACY BROOKS Date: August 22, 2001




From: Stacy Brooks <stacybrooks@lisatrust.net>
Subject: Declaration of Robert Minton -- 08-22-01
Date: Sun, 26 Aug 2001 11:04:32 -0400
Organization: Lisa McPherson Trust, 33 N. Fort Harrison Ave., Clearwater, FL 33755 Tel: (727) 467-9335
Message-ID: <rv3iotks9etbai9lmn3jb9tjc8j0u1f16r@4ax.com>
DECLARATION OF ROBERT MINTON 1. My name is Robert Minton. I have personal knowledge of the matters set forth in this declaration, and could testify competently about them if called upon to do so.

2. In the days leading up to my scheduled deposition in the case of Scientology vs. Liebreich, I had every intention of attending my deposition in Florida on August 3, 2001.

3. I had airline reservations made for me to travel to Florida on the afternoon/evening of August 2, 2001. Over the course of the events described hereafter, my travel plans were revised several times until I determined, in consultation with my therapist, that it was not possible for me to attend the deposition.

4. On the afternoon of August 2, 2001, I became aware of the internet posting attached as Exhibit 3 to my Response. I was, to say the least, shocked by Scientology's grotesque, abusive, and invasive action. I was extremely distraught, not only by Scientology's attack, but by their apparent illegal access to such private information.

5. Later that day, I learned that the neighborhood where my minor daughters live, including their home, had been papered by Scientology with fliers as shown in Exhibit 4 to my response, falsely accusing their mother and me of criminal and/or unethical behavior.

6. I spoke at length to a therapist, because of the severe anguish I felt, and the importance of complying with the Court's order if at all possible. As I talked to my therapist and considered the facts, I grew more rather than less agitated, and eventually accepted my therapist's unequivocal advice that I not travel to Florida to be deposed by Scientology on August 3.

7. In the following days, I asked that the therapist agree to give evidence about the events of the afternoon and evening of August 2, 2001. The therapist refused to cooperate, because of Scientology's history and reputation for abusive attacks on members of the mental health profession, and on its opponents.

8. I am aware that Scientology's policy is to do everything in its power to have anyone who is critical of Scientology branded as a criminal. I myself have twice been set up by Scientology on false assault charges, once in Boston and once in Clearwater. In the Boston incident, the judge threw the charges out before it ever went to trial after being made aware of the fact that it was actually a Scientologist who had assaulted me rather than the other way around.

In the Clearwater incident, I went through a two-day trial on the criminal misdemeanor charge of battery. My lawyer, Denis deVlaming, produced evidence of Scientology's fair game policy that calls for anyone who is critical of them to be branded a criminal. He showed the jury how Scientology operatives set me up to be arrested for battery so that they could brand me as a criminal and thereby discredit me as a source of information about Scientology. After the jury had heard all the evidence they unanimously voted to acquit me, and later some jurors told the media that they felt I had been set up.

9. Last year, on September 15, 2000, two days before my deposition in this case was scheduled, I was peacefully protesting in front of Scientology's Fort Harrison Hotel in Clearwater, when a Scientology operative named Joe Neal ran toward me and assaulted me with a camera, severely bruising the ribs over my heart. I had to go to the emergency room at Morton Plant Hospital, where the attending physician recommended that I not attend the deposition until I was physically able to do so.

10. There are many instances in which critics of Scientology have been set up as I have been. Lisa McPherson Trust staff member Mark Bunker, the Lisa McPherson Trust's multi-media coordinator, was arrested in Chicago for criminal trespassing as he stood on a public sidewalk to film two dentists who were requesting their money back from the Scientology organization in downtown Chicago. Mr. Bunker was filming the dentists outside the entrance when two off-duty Chicago police officers hired by Scientology burst out of the building, grabbed his camera from him and handcuffed him. Mr. Bunker was taken to jail, booked, and charged with criminal trespassing despite two eyewitnesses who swore he was standing on the public sidewalk. Mr. Bunker would later be acquitted, but not before Scientology distributed his mug shot on fliers all over Clearwater, describing him as a criminal not only on fliers but also on the internet.

11. On August 11, 2000, at 8:00 in the morning a SWAT team of 12 Largo police officers burst into Lisa McPherson Trust staffer Jesse Prince's house with instructions to search for drugs and drug paraphernalia, clearly expecting to find evidence that Mr. Prince was a major drug dealer. They found no drugs and no paraphernalia in the house; however, they found one plant growing out of the dead roots of a rubber plant in the back yard. Based on this Mr. Prince was arrested for felony drug cultivation and spent the day in jail. The charge was later downgraded to misdemeanor possession of marijuana. Mr. Prince stood trial on this charge in March 2001. Three Scientology private investigators testified under oath that they were hired by Scientology to follow Mr. Prince and keep him under surveillance constantly. One of the private investigators, Barry Gaston, was specifically hired to get Mr. Prince arrested on drug trafficking charges. Gaston, acting as an agent for Scientology, lied to the Largo police that he had witnessed Mr. Prince selling cocaine and marijuana to minors. Under oath on the witness stand, Gaston admitted that he had never seen anything of the kind. The trial resulted in a hung jury, 5-1 for acquittal. The jurors were quoted in the media saying they felt Mr. Prince was set up by Scientology. The judge called a mistrial, and the prosecutor dropped the charges against him.

12. In June 1998, Dateline NBC aired a program about my work concerning Scientology called "The Crusader," which highlighted my worldwide campaign to expose the evil of Scientology. Mike Rinder, head of Scientology's Office of Special Affairs, appeared on the program as a spokesman for Scientology. The Office of Special Affairs is the intelligence branch of Scientology that is specifically responsible for harassing, intimidating and neutralizing critics of Scientology. Rinder stated on national television, for an audience of twenty million, that "anyone who attacks Scientology is a criminal." When John Hockenberry asked him if he thought I was a criminal, Rinder replied, "I think in time we will find that that is the case." Since then, Scientology has done everything in its power to make Mike Rinder's wish come true, to brand me as a criminal and to force me to be imprisoned. This is precisely what Scientology founder L. Ron Hubbard's written polices call for. This is how Scientology deals with anyone who criticizes them.

Under penalties of perjury, I declare that I have read the foregoing declaration and that the facts stated in it are true.

________________________________ ROBERT S. MINTON Date: August 22, 2001

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