July 9th, 1998 - Another article of the "Boston Globe" summarized the campaign the Church of Scientology had launched against Minton and its effects upon his family. It also included comments on Minton made by the president of CSI, Heber Jentzsch [Exh. No. 36]:

" [ ... ] Since last fall Minton has been greeted with anti-Minton fliers written by Scientologists and dropped on his and his neighbors' doorsteps or pinned to trees lining the quaint streets of his upscale urban neighborhood. He's looked out his windows to see groups from the church picketing his house. And he's had detectives hired by the Scientologists checking every phase of his background both here and abroad - and this has affected the relationship between Minton and his mother and son. [ ... ]

"But what he found most disturbing were the anti-Minton fliers distributed while he was vacationing with his family on the Caribbean island of St. Barts in March. After a day at the beach, Minton returned to his car to find the church's calling cards on his and more than a dozen other windshields. [ ... ]

"He wonders, for example, if the Scientologists are responsible for a dead cat he found on his doorstep in New Hampshire. And he wonders if they stole his laptop computer and address book from the trunk of his rental car in California, where he'd gone to picket the church's April celebration of Hubbard's birthday.

"Jentzsch acknowledges that the church hired detectives to look into Minton's past, had an attorney contact him, and that Scientologists did distribute fliers in Boston. But he denies any church involvement in the cat and computer incidents. [ ... ]

"But it was the fliers that have been the most public and vitriolic. Some of the accusations: ‘Robert Minton, of ... West Cedar Street, has given $ 1.25 million to complete strangers to destroy a religion while his own mother lives on Social Security.'

"'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.'

"'Mr. Minton refuses to help his own son with a loan to purchase a house, yet forked over $ 1.5 million to fund the members of a known hate group in a campaign to create intolerance & hatred.' Mr. Minton acts like a bully to anyone he can manipulate with his money. His second wife left him rather than put up with his brutal beatings.'

"The first of these fliers was unsigned, succeeding ones, with the exception of the St. Barts missive, carried the following identifier: ‘This is written as a public service of STAND (Scientologists Taking Action for Non-Discrimination).' [ ... ]

"Jentzsch says he does not know anything about the fliers in St. Barts but does confirm that ‘individual Scientologists have distributed fliers in Boston to draw attention to what they felt was Minton's religious bigotry.'

"Minton's wife, Therese, says she supports her husband. His dedication does not surprise her, she says, because her husband has always had strong beliefs. But does she hope his involvement will end?

"'Oh God, I hope so,' she says during a short telephone interview. ‘But I know he has made a commitment and I feel my job is to protect my family and not let all this have a negative effect on our lives. I've tried to make it a positive experience for our girls. That their dad has strong beliefs and it's important to have such beliefs and to stand up for what he believes is right.'

"She says they don't thrash it out at the dinner table but talk about other things. ‘But I guess I do exercise more caution than the girls know about,' says Therese, whose family in England was contacted by Scientologists looking into her background. ‘I look at who's walking down our street when I go out the front door and take other little precautions. But I want everyone to know that we are truly there for him.'

"Jentzsch confirms that church attorneys retained ‘qualified investigators' to try to ‘discover the man's true agenda.' [ ... ]

"What Minton has found most disturbing is that his mother, son, and brother talked to detectives after he'd warned them to keep silent. He has little contact with them and is openly upset by what he sees as their betrayal.

"Detectives ‘went to where my family works or to their homes and told them that I was being accused of hate crimes against the Scientologists,' says Minton. ‘They said I was giving millions to people who are out to destroy the Scientologists. They told my mother that if I wasn't putting all these millions into a war against the Scientologists, maybe she could have a nicer home. They used the same tactic with my son and he began to question how I was spending my money.'

"He says his mother probably sat down with the detectives because, like any mother, she likes to talk about her sons. His younger brother, he says, was probably shaken after being told his big brother was under investigation for an extortion attempt against the church. He probably thought, says Minton that somehow he might get in trouble if he kept silent.

"'I guess I didn't do a good enough job preparing my family for the tactics of these people,' says Minton, who grew up in Nashville. ‘My family is Southern and they're not used to dealing with strangers in a forceful way.'

Minton's mother, Catherine Minton, says she is surprised by her son's involvement with the Scientologists because she didn't think ‘he was interested in these sorts of things.' She agreed to talk with two Scientology members who arrived on her doorstep, but now regrets that she did.

"'I was really upset when they left,' says his mother, during a phone conversation from her room in a Florida nursing home. ‘They wanted to know everything about Bob and it really was none of their business. I wish I'd never let them into my house. I wish I hadn't talked to them.'"

July 25th, 1998 - Michael Rinder wrote the first of three letters to Therese Minton in order to interfere in her relationship with her husband. Robert Minton later posted the letters on the Internet [Exh. No. 38]:

" [ ... ] I write to you directly because I have asked Bob to allow us to meet together to discuss the current situation, but he has declined.

"I am certain you are unaware of the real activities and nature of the people Bob is involved with, and I do not believe you would want your family engaged in these matters if you knew the character of these people or their agenda with respect to the ‘Minton money.'

"While Bob claims that the Church has sought to upset his family, in truth it is his activities that are the source of the turmoil that now surrounds his life and yours. It comes about as a result of his relationship with a group of morally bankrupt individuals who are taking money from him while they are engaged in unethical and even criminal activities. [ ... ]

"Courts have found several of this group of low-lifes [sic] guilty of violating the Church's rights and yet Bob gives them money to continue. A couple of them are wife abusers and child molesters. None are fit to be in the presence of you or your children, yet Bob is playing Santa Claus to them with your money. Bob's irresponsible, if not outright malicious acts, are damaging my church and individual Scientologists as well as you and your children.

"I believe a face-to-face meeting between us would be helpful. This is a serious matter. What is occurring is causing a great deal of damage. If you were aware of all the facts, I am sure you would not support what is happening.

"You can contact me at 213-960-3500 or 213-960-3508 (fax). I look forward to hearing from you."

July 30th, 1998 - Rinder wrote a second letter to Therese, in which he tried to use the information about Minton's affair with Stacy Young to turn Therese Minton against her husband [Exh. No. 39]:

" [ ... ] You are probably under considerable stress and you need to understand that my interests at this point are similar to yours. I want to inform you of facts and assist you, and I think I am in a position to do so. [ ... ]

"Mrs. Minton, I have never met you, and your only information about me is what you have heard from your husband and Stacy Young who would have nothing but the worst things to say about me.

"I reiterate the request of my earlier letter. I wish to make you aware of information through a face-to-face meeting at your convenience. Again, I believe that if you were aware of all the facts you would not support what is happening.

"You can contact me at 213-960-3500 or by fax at 213-960-5308. [ ... ] "

August 24th, 1998 - Scientologists picketed and distributed leaflets at the "Turan Corporation" in Boston. Its owner, Robert Smith had been identified as a former business partner of Minton. The distributed leaflets stated [Exh. No. 88]:

"Turan Corp. Connection to the Religious Bigotry of Robert S. Minton

"Robert Minton, a man with links to Turan Corporation's Robert Smith, has blatantly lied to the American public and media about our church, its members, its goals and actions. We refuse to allow our religion to be smeared and maligned any longer.

"Minton has held himself out on national television and to the press to be an upstanding citizen, but he is using his many millions of dollars to force his bigoted views onto our church and its parishioners to ‘reform it' [ ... ] He promotes an agenda of bigotry.

"Minton and Smith did business in Nigeria. Minton made a lot of his money, he says, by helping the country's dictatorial leadership to successfully default on multi-million dollar loans. Everyone with the inside knowledge benefited but as events and statistics show, the people suffered.

"While millions were siphoned off in ‘commissions,' and lenders had to write off huge losses, the leaders of the country completely ignored the human suffering and misery of its citizens. Is this how a man of principal acts? [ ... ]

"By the Free Speech & Religious Freedom Committee of the Parishioners of the Church of Scientology of Boston."

August 26th, 1998 - Rinder wrote a third letter to Therese Minton, again trying to use Robert Minton's affair with Stacy Young to pursue his agenda [Exh. No. 40]:

" [ ... ] I imagine that by this time you have probably become aware that some of the things I said in my earlier letters have now proven true. As a matter of fact, I can show you a great deal of information supporting the statements in those letters. I believe there is much more information that you do not have concerning the activities of Bob and the people he has gotten hooked up with. Clearly, Bob's involvement with Stacy Young and others has not had a positive effect on your family.

"While I am sure you have been told various lies about me and the Church of Scientology, you have no downside in hearing what information I have to offer. I would like the opportunity to speak with you face to face. You can call (213 960-3500) or fax me (213 960-3508). [ ... ] "

August 31st, 1998 - According to an Internet posting of Minton, Scientologists distributed on this day leaflets about Minton's affair with Stacy Young in the neighbourhood of Therese Minton's home. He also stated that private detectives had been following Therese while she had been on vacation in England [Exh. No. 89].

October 9th, 1998 - In another Internet posting Minton reported that Scientology private investigator Peter Franks had given his former business partner Jeffrey Schmidt a package with documents containing negative material on Minton during a conference of the IMF conference [Exh. No. 44]. Minton additionally quoted a leaflet that was distributed by Scientologists outside the home of another former business partner, Selwyn Lewis:

"WHY ARE WE PROTESTING HERE?

"WHAT IS SELWYN LEWIS' CONNECTION TO ROBERT S. MINTON?

"THE TRUTH BEHIND THE LIES

"Robert Minton, a wealthy American with past business ties to Mr. Selwyn Lewis of 232 Keoff Road, Clifford, Cape Town, South Africa, is a director and the main financial supporter of an anti religious hate group which mindlessly attacks minorities.

"Mr. Minton, along with Mr. Selwyn Lewis, accumulated his wealth through conducted business transactions with Nigeria while it was under the tight grip of military dictatorship. This same dictatorship has actively prevented Nigeria from creating a democratic system in the country and has siphoned billions of dollars from its people through criminal deals.

"Although one of the richest nations in Africa due to its petroleum output, Nigeria yet suffers from economic repression because of the greed and blatant financial mismanagement by its rulers and their international banker friends.

"The economic plight of the Nigerian people was created through a crushing debt to foreign banks as a result of the criminal actions of foreign capitalists who sought to exploit the people of Nigeria.

"Persons such as Mr. Minton and Mr. Lewis later profited handsomely from Nigeria's economic woes by further manipulation of the financial situation, creating a secondary market to trade the huge debt of the country. These secondary market financial dealings has not brought about an increase in prosperity for the citizens of the country and the economic crisis is acute. However, Minton and Mr. Lewis profited nicely and got out ‘while the going was good.' [ ... ]

"Although Mr. Lewis is not involved in Mr. Minton's anti-religious hate group, he has not been willing to disclose the full truth about Mr. Minton's unethical behavior and shady exploits. Why not? This is not how honest businessmen act, not how men of principle conduct themselves. [ ... ]

"We demand that Mr. Minton and anyone who may be assisting him, such as Selwyn Lewis, cease their unlawful acts and to use their wealth to help, not create hate.

"Free Speech and Religious Freedom Committee of the Parishioners of the Church of Scientology"

On the same day a similar sounding leaflet was distributed during a picket outside of "Hillsleigh International Ltd," a company of which Minton and Schmidt were investors. The leaflet stated [Exh. No. 90]:

"WHY ARE WE PROTESTING OUTSIDE HILLSLEIGH INTERNATIONAL LTD?

"WHAT IS JEFFREY SCHMIDT'S CONNECTION TO THE RELIGIOUS BIGOTRY OF ROBERT S. MINTON?

"THE TRUTH BEHIND THE LIES

"Robert Minton, a wealthy American with past business ties to Jeffrey Schmidt of Hillsleigh International Ltd., has blatantly lied to the public and media about our Church, the Church of Scientology, its members, its goals and actions [ ... ].

Minton and Jeffrey Schmidt made a lot of money through Mr. Schmidt's contacts, by helping the dictatorial leadership of Nigeria and other third world countries to successfully default on multimillion-pound loans. Those who had the inside knowledge benefited in the debt trading business but, as events and statistics show, while millions of pounds were siphoned off in ‘commissions' and lenders had to write off huge losses, the leaders of Nigeria ignored the human suffering and misery of its citizens. Is this how men of principle act? [ ... ]

"Free Speech & Religious Freedom Committee of the Parishioners of the Church of Scientology"

December 16th, 1998 - Minton posted on the Internet that two Scientologists picketed in front of Therese Minton's house in Boston on the previous day [Exh. No. 91].

December 23rd, 1998 - In another Internet posting Minton stated that during the previous day Scientologists had distributed leaflets in the neighbourhood of Therese Minton's home, which mentioned Robert Minton's affair with Stacy Young [Exh. No. 92]. The leaflets said [Exh. No. 93]:

"We Call It Adultery - Stacy Young and Robert S. Minton

"On, August 25, 1998, Robert Minton proclaimed on the Internet, ‘Stacy and I are not having an affair! We are getting married. If it really bothers anybody that I love Stacy and she loves me, that is too f***ing bad, because I don't care what Scientology or anybody else thinks.'

"There is one ethical consideration: Minton is married and has two young daughters who live on Beacon Hill. Stacy also had a husband. If this sounds bizarre, consider the statement Minton made to a member of the Church of Scientology as Minton picketed in front of a church building:

"‘Yo, mama. I've been f***ing your mama for a long time, that's why you've got curly hair.' - Robert Minton, November 30, 1998 "This is his idea of ‘free speech.'

"Minton has spent over $ 2 million of his family's wealth creating hatred and bigotry towards members of our religion. Minton's behavior is socially obnoxious and morally impaired.

"Distributed by: FRIENDS OF RELIGIOUS FREEDOM"

December 29th, 1998 - Minton reported that all the residents of the town of Sandown had received a letter written and signed by Scientologist Maureen O'Keefe [Exh. No. 94]. The letter was allegedly sponsored by the "Parishioners of the Church of Scientology of Boston." It was dated December 26th and stated [Exh. No. 95]:

"COMMITTEE ON CONSTITUTIONAL RIGHTS - AN OPEN LETTER TO SANDOWN RESIDENTS

"My name is Maureen O'Keefe and I am a parishioner of the Church of Scientology. While you may be aware of the on-going conflict between Scientologists and Robert S. Minton, Jr. of 137 Fremont Road here in Sandown, I realized that most have never been told the truth of what this conflict is all about. The purpose of this letter is -to-provide you with some basic facts of what the situation is and why we have been demonstrating against Mr. Minton here in your town.

"About a year ago, I first became aware of Robert Minton when, seemingly out of nowhere, he began verbally attacking my Church and spreading vicious lies via the media and the Internet about Scientology and its founder, L. Ron Hubbard. Since that time, Mr. Minton has become increasingly vocal and violent in his attacks on my Church and parishioners, myself included. He has poured millions of dollars into funding what is nothing less than a massive anti-religious hate campaign. The latest fact sheet is enclosed.

"On August 13, 1998, however, Robert Minton crossed the line as far as I was concerned. On that day, while professing to be a Scientologist, Mr. Minton tried to force his way into my Church on Beacon Street in Boston. After I refused to allow him to enter, Mr. Minton emphatically stated, ‘I am going to destroy Scientology!' At that moment I decided that I was not going to allow him to impede my Constitutional Right to freely practice the religion of my choice.

"Religious freedom is not contingent upon whether or not Robert Minton happens to agree with my religious beliefs. It is my right as an American just as it is every American's right, including yours. All I have asked of Mr. Minton is that he respects the religious beliefs of others. Our message to him is quite simple: ‘You leave us alone. We'll leave you alone.' It is simply a matter of defending one's Constitutional Rights.

"I'd like to thank you for listening and wish you and your family a very happy holiday season and a prosperous 1999. If you have any questions or would like to know what you can do to help protect religious freedom, please feel free to write me at the address below."

October 26th, 1999 - Another Internet posting by Minton announced that he had received calls from five residents in Sandown who had informed him of a letter they had received. At a later point Minton learned that the same letter had also been sent to the school that his daughter attended [Exh. No. 96]. The letter, which had attachments of his Internet postings, appeared to be a public warning about Minton:

"If you have any dealings with Mr. Minton of 137 Fremont Rd., Sandown, New Hampshire, please be aware of his activities on the internet. "This sort of behavior by Mr. Minton has occurred repeatedly and he has acted out some of his expressions in the form of violence at various times. He appears to be incapable of controlling himself; thus you are being alerted."

October 30th, 1999 - A leaflet with the headline "Trick or Treaters beware," which featured a photo of Minton was distributed in the neighbourhood of Minton's home in Sandown [Exh. No. 97].

January 16th, 2000 - Minton reported in an Internet posting that Scientologists had demonstrated in front of Therese Minton's house for three days in a row [Exh. No. 98].

January 29th, 2001 - An Internet posting of Minton stated that since September 2000 two Scientologists had distributed leaflets in the neighbourhood of Therese Minton three to four times a week [Exh. No. 99]. The leaflets contained negative information about Minton's prior business deals with the government of Nigeria. One of these flyers stated:

"The World Bank and the Nigerian secret debt buy-back schemes

"In two complex frauds, involving over US $ 6 billion in Nigerian funds between the years 1987-1998, Nigerian officials and American banker Robert Minton filled their own pockets at the expense of unsuspecting debt holders, financial institutions and Nigerian creditors. Minton defended his criminal actions by claiming that he had the tacit approval of the IMF and World Bank.

"Mr. Caio Koch-Weser headed the African desk of the World Bank at the time. His appointment as Managing Director of the IMF was vetoed by the US early in 2000; he is currently the Deputy Finance Minister of Germany.

"If Minton is right it could catapult the World Bank into the midst of an explosive situation because one of the biggest deals Minton carried out was with the Paris Club of creditors which lost billions of dollars.

"The scheme itself was kept secret with debt holders, financial institutions and Nigerian creditors not being informed by Minton that he was buying the debts with Nigerian funds. [ ... ] "

May 29th, 2002 - During the cross-examination in the McPherson civil court hearings Minton was asked by the estate's attorney Kennan Dandar for the "worst thing" the Scientologists had done to him. Minton then recounted an incident, which had happened in February of 2000 when his wife Therese had applied for a membership in a tennis club in Boston.

The application for the club membership was denied after the members of the admissions committee had received documents with negative information about Robert Minton and Therese. The document had apparently been sent by Scientologists:

[ ... ] Dandar: "What was the worst thing they did to you?"

Minton: "You know, I don't - well, it wasn't actually something they did to me. It was something they did - at least I thought they did, and it wasn't denied, it wasn't admitted either. But my children like to play tennis. And my wife was being sponsored by a man who was the president of Fidelity Investments in Boston to join Longwood Tennis Club, sort of a country club in Brooklawn. And somebody sent to all of the members of this admissions committee or acceptance committee copies of all of this stuff concerning Nigeria, and that Therese was under indictment in Nigeria and Minton was - I was under indictment. And, you know, that was - that was hurtful to me that, you know, I couldn't help her deal with that in any way."

Q: "What year was this?"

A: "I would imagine it would have been in 2000."

Q: "What is the worst thing they said that you did ... "

The Court: "Did this cost her membership in this club?"

The Witness: "She didn't get in."

By Mr. Dandar: "What is the worst ... "

The Witness: "I mean, everybody sort of backed away."

A: "Sorry, what was the question?"

By Mr. Dandar: "What did they tell you was the worst thing you did?"

The Court: "Wait a second. You were not indicted in Nigeria, were you?"

The Witness: "No, your Honor."

The Court: "So whatever it was that was being sent was not even true, was it?"

The Witness: "That's right." [ ... ]

The above listed incidents from 1997 until 2001 were not the only operations that the Church of Scientology undertook to intimidate Robert Minton. Apparently there were even more pickets by Scientologists in front of the home of Therese Minton than the ones I have listed. And the private investigators certainly followed up more business partners of Minton than I could document in this affidavit.

These particular activities by the Church of Scientology were of abusive nature and were clearly designed to eventually discourage Minton to speak out against Scientology and therefore to deprive him of his First Amendment rights.

The operations that I have described targeted not only Minton but as well innocent by-standers that were used by the Scientologists and their private investigators as pawns to pressure Minton for an unilateral surrender in his conflict with the organization.

CSI's president Heber Jentzsch declared in an interview with the "Boston Globe" that the leaflets that criticized Minton had been distributed by "individual Scientologists." Strangely enough, several of these flyers contained information that had been gathered by the private investigators hired by CSI, which proves that the distribution of these leaflets was in fact orchestrated by the Church of Scientology, respectively by its "Office of Special Affairs" network.

For these reasons and exemplary for all the individuals who were eventually involved in the harassment of Robert Minton's family, I have included Michael Rinder, the head of all intelligence operations within CSI, Elliot Abelson, who initiated the overall campaign with his letter from November 1997, the "Church of Scientology International", which hosts the strategic and executive branch of its intelligence network, the "Office of Special Affairs International," and finally the "Church of Scientology of Boston," which ultimately was responsible for the picketing and leafleting of the homes of Minton and his family.