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IN THE CIRCUIIT COURT FOR PINELLAS COUNTY, FLORIDA

IN RE: ESTATE OF
File No. 97-0589-ES

LISA	McPHERSON Deceased.

Division:	003	

_______________________________________/

PETITION FOR APPOINTMENT OF ADMINISTRATOR AD LITEM

ROBERT S. MINTON ("MINTON"), by and through his undersigned counsel, hereby 
requests that this Court appoint an administrator ad litem for the purpose 
of taking charge of all pending litigation for which the Estate is presently 
engaged, and in support therefore, states as follows:

1.	MINTON made a series of loans to the Estate for the express purpose 
of funding litigation expenses relating to the decedent's wrongful death; 
and as such, is a creditor and an "interested person" pursuant to Rule 
5.120, Fla. Probate Rules.

2.	The MINTON loans, which remain unpaid, were to be satisfied through 
potential recoveries from the wrongful death action prosecuted by the duly 
appointed personal representative, DELL LIEBREICH. It is now evident, 
however, after five years of service, that the personal representative is 
severely mishandling the Estate litigation, thereby jeopardizing MINTON's 
interest in being repaid his loans if an administrator ad litem is not 
immediately appointed to take over the course of said litigation.

3.	Moreover, in December 1997, the Estate, through the personal 
representative and counsel, agreed with MINTON that the Estate would 
distribute a substantial portion of any recovery from the wrongful death 
action to an organization controlled by MINTON. In sworn deposition 
testimony given in 1999, the personal representative, in the presence of the 
Estates counsel, confirmed the existence of that agreement with MINT ON. 
Also in 1999, each of the personal representative's siblings, who are also 
beneficiaries of the Estate, similarly confirmed the existence of that 
agreement with MINTON, again in the presence of the Estate's counsel. [n 
April 2002, the personal representative again testified that this agreement 
with MINTON existed, but stated that she had "changed her mind" about it. 
The personal representative's recent testimony that she intended to renege 
on the agreement with MINTON is a further basis to believe that the personal 
representative is acting in contradiction to her duties to preserve the 
Estate's assets for the benefit of interested person MINTON, while 
continuing to squander the funds he has invested in the Estate's litigation.

4.	The personal representative, instead of maximizing recoveries as is 
her charge, has caused through her actions multiple judgments to be entered 
against the Estate for breaching a covenant not to sue certain entities and 
individuals. One such judgment in the United States District Court for the 
Eastern District of Texas totals over $500,000. In addition, counsel 
retained by the personal representative was personally sanctioned nearly 
$100,000 for conducting frivolous and vexatious litigation.

5.	Judge Baird recently entered another judgment for liability against 
the Estate in a related breach of contract action filed in the Circuit Court 
of the Sixth Judicial District for Pinellas County, Florida. The damages and 
attorneys' fees claimed are expected to exceed $600,000. The Estate and its 
attorneys were further sanctioned by the court in the amount of $l1,824.26.

6.	In the wrongful death action currently pending in the Pinellas 
County Circuit Court, there is a motion, which Judge Schaeffer presently has 
under submission, to dismiss the action and to disqualify the personal 
representative's counsel for allegedly suborning perjury and for the filing 
and prosecution of a sham pleading. In that case, there has been a 
counterclaim asserted against the Estate that is tantamount to "abuse of 
process." Said counterclaim has already withstood the Estate's motion to 
dismiss and therefore must be viewed as another potential Estate liability 
unless corrective action is instituted.

7.	Florida Probate Rule 5.120(a) expressly provides for the appointment 
of an administrator ad litem where the "necessity arises..." In this instant 
matter, it is absolutely imperative that an independent and objective 
administrator ad litem be appointed to take over all pending litigation, as 
it is readily apparent from the record that the personal representative is 
not acting in the best interests of the Estate in prosecuting the wrongful 
death litigation to maximize a recovery, and if she is permitted to continue 
in this capacity, her direction will likely create more liabilities.

8.	The personal representative has also recently filed a First 
Accounting that causes MINTON great concern. Among other things, the 
personal representative failed to account for the MINTON loans, nor did she 
disclose any Estate assets on hand (not even the wrongful death action). The 
First Accounting contains many other serious and significant material 
defects, deficiencies, errors and omissions and potentially discloses 
improper conduct with respect to the personal representative and/or her 
counsel. MINTON has filed an objection to the First Accounting with this 
Court and hereby incorporates said objection herein by reference.

9.	Moreover, after receiving the wholly deficient First Accounting, 
MINTON made a statutory request for a copy of the probate inventory, but for 
some unknown reason was denied said request by the Estate. MINTON thus filed 
with this Court a motion to compel a copy of the inventory and hereby 
incorporates said motion herein by reference.

10.	It appears that the personal representative and her counsel are 
acting to conceal assets of the Estate. They have most recently concocted a 
story, presumably in order to skirt the probate court's control and 
jurisdiction, that the MINTON loans were not made to the Estate, but were 
"personal" loans to the Estate lawyer to use for whatever purpose he 
chooses including personal matters. This new found position of the personal 
representative is directly in contradiction of her duty to preserve Estate 
assets for the benefit of interested persons, including creditors such as 
MINTON.

11.	Further creating an adversarial interest is the fact that the 
personal representative and her siblings are the beneficiaries of the 
Estate. Florida Probate Rule 5.120(a) authorizes the appointment of an 
administrator ad litem where the personal representative is also a survivor 
of the decedent and therefore may have an adverse interest to the Estate. 
See Continental National Bank v. Brill, 636 So. 2d 782, 783-4 (Fla. 3d DCA 
1994) (in such a case, the court may appoint an individual without self-
interest as administrator ad litem).

12.	Based upon the forgoing, MINTON believes that the personal 
representative is properly administering the Estate, wasting assets of the 
Estate, acting in contravention of law and equity, promoting the interests 
of beneficiaries and others above the rights and interests of other 
interested persons such as MINTON, all of which rises to the level that 
requires this Court to immediately appoint an administrator ad litem.

WHEREFORE, ROBERT S. MINTON would respectfully request that this Court 
immediately appoint an administrator ad litem for the purpose of taking 
charge of all pending litigation for which the Estate is presently engaged, 
and for such other and further relief that this Honorable Court deems 
appropriate under the circumstances.

	

	CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has

been furnished by U.S. Mail to: 

F. WALLACE POPE, SR., ESQUIRE, Johnson, Blakely, et al., 
P.O. Box 1368, Clearwater, Florida 33757-1368; 

KENNAN G. DANDAR, ESQUIRE, Dandar & Dandar, P.A., 
P.O. Box 24597, Tampa, Florida 33623-4597	

and WILLIAM RAMIBAUM, ESQUIRE, 
28960 U.S. Highway 19 North, Suite 100, Clearwater, Florida 33761, 

this day of September, 2002.

Fla. Bar No. 4173 SPN 1923
STEPHEN J. WEIN, ESQUIRE
Fla. Bar No. 212814 SPN 43400
BATTAGLLIA, ROSS, DICUS & WEIN, P.A.

P.O. Box 41100
St. Petersburg, Florida 33743-1100
Telephone No. (727) 381-2300
Facsimile No. (727) 343-4059
	ATTORNEYS FOR MINTON

	IN THE CIRCUIT COURT FOR PINELLAS COUNTY, FLORIDA
PROBATE DIVISION

In Re: Estate of Lisa McPherson,

Deceased.

	_______________________________/	CASE NO. 97-0589-ES-003

CHURCH OF SCIENTOLOGY FLAG
SERVICE ORGAMZATION, INC.,
ADVERSARY PROCEEDING #4
Petitioner/Plaintiff

vs.

DELL LIEBREICH, Individually and as
Personal Representative,

Respondents/Defendant.

__________________________________________________________/

JOINDER OF CREDITOR RELIGIOUS TECHNOLOGY

CENTER TO PETITION FOR APPOINTMENT OF

ADMINISTRATOR AD LITEM

Religious Technology Center ("RTC") a creditor and "interested person" 
herewith joins in with Petition for Appointment of Administrator Ad Litem, 
("Petition"), filed by the Church of Scientology Flag Service Organization 
pursuant to Rule 5.120 Fla. Probate Rules, for the limited purpose of taking 
charge of and resolving litigation that is wasting the remaining assets of 
the Estate.

1.	The Estate is liable for judgments totaling $548,010.87, plus post-
judgment interest for breach of contract in the case entitled, Religious 
Technology Center v.

Liebreich, in the United States District Court, for the Eastern District of 
Texas, Case No. 6:00 CV503. (Exs. A & B). RTC has also been awarded 
$98,296.00 in sanctions against the Estate's counsel for conducting 
frivolous and vexatious litigation on behalf of the Estate. (Ex. C). RTC is
accordingly an "interested person" to this action.

2.	RTC joins the Petition for Appointment of Administrator Ad Litem for
all the reasons set forth in the Petition.

I HEREBY CERTIFY that a true copy hereof has been furnished by facsimile and
regular U.S. mail to

Kennan G. Dandar, Esq., Dandar & Dandar, P.A.,
1715 N. Westshore Blvd., Suite 750, Tampa, FL 33607;

Anthony Battaglia, Esq., Ross, Dicus & Wein, P.A.,
P.O. Box 41100, St. Petersburg, FL 33743-1100;

and William Rambaum, Esq., 28960
U.S. Hwy. 19 North, Suite 100, Clearwater, FL 33761-2403,

this day of September, 2002.

JOHNSON, BLAKELY, POPE, BOKOR,
RIYPPEL & BURNS, P.A.

	By:

F. Wallace Pope, Jr.

Post Office Box 1368
	Clearwater, Florida 33757
(727) 461-1818
(727) 441-8617 fax
SPN# 00002797

Attorneys for Religious
Technology Center
275331