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." [ ... ]