1 Q. Did you bring these notes with you to the meeting
2 with Mr. Minton on March 28th?
3 A. Yes, I did.
4 Q. And what was the reason why you had the dollar
5 figures next to each item listed, the 13 items?
6 A. The purpose of this presentation was to give both
7 Mr. Minton and his counsel an idea of how much money
8 Mr. Minton had cost the church -- churches, each different
9 one -- in litigation expenses by virtue of his conduct in
10 controlling litigation, funding litigation, providing
11 witnesses to provide affidavits, et cetera.
12 And the purpose here was just to give
13 Mr. Minton something he did not know in terms of how much
14 the church has spent, for example, in the wrongful death
15 case, and also to give Mr. Jonas, who was not involved in
16 any of these cases, more of a picture of what -- how much
17 damage, financial damage, Mr. Minton had done and would
18 continue to do in these cases.
19 Q. And were these figures given to him as a measure
20 of damages for a future RICO suit to be filed against
21 Mr. Minton?
22 A. There was no future RICO suit to be filed against
23 Mr. Minton.
24 Q. Did you tell Mr. Minton at that meeting that you
25 were preparing a RICO suit to file against him as soon as

1 the church won the wrongful death case in Lisa McPherson?
2 A. No. I will tell you what I said to him. If you
3 look at the litigation matters, when we get down to the
4 third page, Roman 12, my handwriting, if you can't read it,
5 is, "Our planned RICO case."
6 And I said to Mr. Minton -- I was really
7 talking to Mr. Jonas, my counterpart across the table -- I
8 said, "In the interest of full disclosure -- we're trying
9 to get a global settlement -- I want to put our cards on
10 the table. You know, you know the cases that Mr. Minton is
11 either involved in or is about to be involved in; for
12 example, in the case before Judge Schaeffer. But I want
13 you to understand that we're acting in good faith here, and
14 I'm going to lay out for you not only what you know about,
15 but what you don't know about."
16 And I said to him that several of the churches
17 had looked at -- had paid counsel -- and that's what the
18 words are, "we've spent," to research, legal research, on
19, the question of whether a federal RICO claim lied -- civil
20 RICO claim lied against Mr. Minton.
21 The research had never been completed. The
22 clients, including Flag, were planning on proceeding with
23 that if the attorneys said okay, because the practice we
24 follow is we research a case before we bring it, and we're
25 basically researching our opposition to a motion to

1 dismiss.
2 And I told them that the research had been
3 stopped in the middle because the determination had been
4 made that any RICO case -- and they were certainly hoping
5 to file one -- would not be filed until after the wrongful
6 death case had been completed.
7 And that is the reason why you will notice
8 that, with respect to all of the pending litigation, there
9 are two lines on my notes: "We've paid," and, "We will
10 pay."
11 If you go up to the very top, Page 1, wrongful
12 death case, "We've paid," and, "To be paid."
13 And I gave the figures both for any pending
14 case as to how much the particular church clients had paid
15 and how much they had budgeted or estimated that they would
16 have to pay.
17 When it came to the RICO one, as you can see,
18 sir, on the third page, the only entry is, "We've spent,"
19 and that's the $40,000.
20 And the reason for that was the decision of
21 whether to bring that case -- the client wanted to bring it
22 for sure -- but the decision whether to bring it was
23 postponed so far into the future that it was not even a
24 discussion of or an estimate of, if we would bring it, how
25 much it would cost.

1 Q. Do you recall holding up, in the presence of
2 Ms. Brooks and Mr. Minton, what you termed or stated was a
3 draft of a RICO suit?
4 MR. HILL: Objection as to time, Your Honor.
5 Are we still talking about the March 28th and 29th
6 meetings?
7 MR. DANDAR: Yes.
8 MR. HILL: Which one, the 28th or 29th?
10 Q. 28th.
11 A. I recall that it never happened and it was not
12 possible, because no draft complaint, RICO complaint, was
13 ever prepared.
14 The research was stopped in the middle when the
15 client made a decision that they do not want to consider
16 bringing that case until after the wrongful death case had
17 been tried.
18 And I can tell you, not one word, not even a
19 caption, had been drawn, so there was no draft for me to
20 show Mr. Minton about it.
21 Q. My question is: Did you show a piece of paper to
22 Mr. Minton and Ms. Brooks that you purported and you
23 represented to be a draft of a RICO suit?
24 A. Of course not.
25 Q. Did you present to them a copy of the Armstrong
1 case where the church is suing Mr. Jerry Armstrong and now
2 Mr. Minton in excess of a hundred million dollars?
3 A. If you will refer to Item Number 3 on the first
4 page, one of the litigations I spoke about is Armstrong.
5 And you will see, "We've paid," and, "We will have to pay."
6 Again, when we came to the Armstrong matter, I
7 said, "In the interest of full disclosure -- I don't want
8 you thinking that I'm going to sandbag you -- you don't
9 know this yet, Mr. Jonas, but we have a case against
10 Mr. Armstrong in Wren County, California, and we are
11 amending or adding Mr. Minton as a defendant.
12 That motion or that pleading to add Mr. Minton
13 as a defendant was well under way, and I think it was close
14 to final, because I know I served it on him on April 5.
15 So if you're asking me whether or not I
16 referred to that in the meeting, I certainly made a
17 disclosure of what they did not know, and that was,
18 "Mr. Minton, you're about to be sued by one of the church
19 entities in California in the Armstrong case."
20 He didn't know that. And, in fact, they were
21 very thankful that I was candid enough to put the cards on
22 the table and tell him what was coming.
24 Q. Did you make any notes of the meetings on March
25 28th or 29th?

1 A. No.
2 Q. Now, isn't it true, sir, that Mr. Rinder told
3 Mr. Minton at that meeting on March 28th that before the
4 church would enter into any discussions with him on
5 disengagement, that Mr. Minton first had to make the Lisa
6 McPherson wrongful death case and the Larry Wollersheim
7 case in California go away?
8 A. Absolutely not. Never said that.
9 Mr. Rinder expressed a strong preference for a
10 global settlement and expressed in the strongest possible
11 terms his preference that all of the litigation go away.
12 Mr. Jonas, I believe, asked if we were willing
13 to let Mr. Minton out of the breach case and out of the
14 wrongful death case.
15 And Mr. Rinder's response was, "Your client's
16 not getting out of any case until the case is over. We're
17 not letting you out and then continuing to litigate with
18 the others.
19 "So if what you want is to get out of the
20 wrongful death case where you're about to, be added as a
21 defendant, then we're telling you, you're not getting out
22 until the case is over," and that's what Mr. Rinder said.
23 Q. Isn't it true, sir, that Mr. Rinder told
24 Mr. Minton that the declarations and affidavits of Jesse
25 Prince, Stacy Brooks and Vaughn Young would have to be

141 withdrawn in the McPherson case and the Wollersheim case
before the Church of Scientology would consider
disengagement from Mr. Minton?
A. Absolutely not.
Q. Isn't it true, sir, that Mr. Rinder told
Mr. Minton that the Lisa McPherson Trust web site and any
domain names that has her name on it, Lisa McPherson, would
have to be taken off of the internet before the Church of
Scientology would consider disengagement from Mr. Minton?
A. To the contrary.
If you look at my notes, you will see, on page -- let me
see where it is -- top of Page 3, Roman 11.

Let me translate, because my handwriting is not that good,
"Internet and trademark disputes."

That had nothing to do with Lisa McPherson web sites. That
had to do with Mr. Minton had registered as domain names
the words Orthodox Scientology, Reformed Scientology and
some other name that included the registered trademark
Scientology, and we presented that we had already paid
$32,000, we were expecting to pay $150,000, we were going
to sue or go through ICANN, which is the dispute-resolution
group for the internet, to have those registrations cancelled.

There was no demand that Mr. Minton not have a Lisa McPherson
web site or anything like that, certainly
1 not by us.
2 Q. Have you read the testimony of Monique Yingling in
3 the case before Judge Schaeffer?
4 A. I have not, sir.
5 Q. Have you looked at her typed notes that she
6 produced?
7 A. I have not, sir.
8 Q. Did you also tell Mr. Minton in this meeting on
9 March 28th that he was going to be added onto the Texas
10 breach case?
11 A. No. I told him -- and when we came -- as we came
12 to each one of these items, I gave a little bit of
13 background, because some of them Mr. Minton was unfamiliar
14 with. All of them Mr. Jonas was unfamiliar with. So I was
15 really talking in the sense more for Mr. Jonas's
16 edification.
17 If you go down to Item Number 9, RTC/Liebreich,
18 that's the Texas case you're referring to.
19 When I came to that, I told Mr. Minton that
20 Ms. Liebreich had testified in that case in deposition that
21 she expected Mr. Minton to pay any judgment that was
22 entered against her or against the estate and that she
23 expected Mr. Minton to pay the expenses -- costs, if you
24 will -- that were awarded or would be awarded against her
25 in the favor of RTC.
1 That was the context in which it came about.
2 It wasn't that we were suing Mr. Minton.
3 And, Mr. Dandar, of course, you know that we
4 didn't do that, because you tried the case, and it was
5 tried two months before this meeting. We tried that case
6 to a jury in January of 2002. So Mr. Minton wasn't a
7 party.
8 Q. Mr. Rosen, isn't it true during this March 28th
9 meeting you told Mr. Minton that if he could get the
10 affidavits supplied by the, quote, Minton camp, closed
11 quote, removed from the Wollersheim case in California, the
12 motion to dismiss by the Church of Scientology would be
13 granted and the Wollersheim case would go away?
14 A. No, sir. That was not what was said on that
15 subject.
16 Q. Isn't it true, sir, that Michael Rinder told
17 Mr. Minton in your presence on March 28th that before there
18 would ever be disengagement between him and the Church of
19 Scientology, Mr. Minton had to get the Lisa McPherson
20 wrongful death case dismissed?
21 A. Absolutely false. And the events of March 29th
22 proved it to be false.
23 Q. Didn't you tell Mr. Minton on March 28th that he
24 caused it, and therefore he can make it go away?
25 A. No. That comment was made by Mr. Rinder in the


1 following context:
2 There was a discussion about Mr. Minton
3 bringing about a resolution, a settlement of the wrongful
4 death case.
5 Mr. Jonas asked, "Well, I don't know anything
6 about this case. What's involved? You know, what are the
7 numbers? What's the Plaintiff's demand? What's the
8 offer?"
9 And Mr. Rinder said, "I can't tell you that.
10 It's confidential. It was a mediation."
11 And Mr. Jonas said, "Well, is the question here
12 that you want Mr. Minton to make Ms. Liebreich withdraw the
13 case or do you want this case settled?"
14 And Mr. Rinder said, "I want this case
15 settled."
16 And Mr. Jonas said, "Well, okay, tell me
17 confidentially, how much are you willing to pay to settle
18 the case?"
19 Mr. Rinder said, "Nothing."
20 Mr. Jonas said, "Well, why not?"
21 And Mr. Rinder said, "Look, this is Minton's
22 case, he's funding it, all of the people who are the
23 witnesses are his people, he pays them to testify."
24 And most importantly, Ms. Liebreich is only a
25 nominal Plaintiff, because there is an agreement that we

145 1 were told and aware of that the substantial portion of any
2 proceeds of that case would be, given by the estate to some
3 anti-cult, for lack of a better term, or anti-Scientology
4 organization that Mr. Minton would choose.
5, So, in reality, we were looking at Mr. Minton
6 being the real party in interest in the case, Ms. Liebreich
7 being a nominal party.
8 And the statement made to Mr. Jonas was, "If
9 Liebreich needs some money to go away to resolve this, you
10 pay her; you're the one who owns this case. You pay her."
11 Q. Isn't it true, sir, that Mr. Minton was told by
12 either you or Mr. Rinder that he had to stop funding the
13 wrongful death case of Lisa McPherson before Scientology
14 would consider disengagement of him?
15 A. No, sir, at least not when I was in the room.
16 Q. Were you in the room at all times?
17 A. I was in the room throughout the entire sessions
18 of March 28th except for two periods that I was not at the
19 meeting.
20 Q. And who was left in the meeting?
21 A. The other five people.
22 Q. So Ms. Yingling engaged in conversation with
23 Mr. Minton and Mr. Jonas while you were not there?
24 MR. HILL: Objection. Calls for speculation.
25 THE WITNESS: Well, sir, obviously the

146 1 answer to your question is: How would I know
2 if I wasn't there? I don't mean to be
3 sarcastic, Mr. Dandar, but...
5 Q. All right. In your presence -­
6 A. No.
7 Q. -- there was never a demand made to Mr. Minton on
8 behalf of the Church of Scientology that before there would
9 be disengagement, he had to stop funding the wrongful death
10 case?
11 A. To the contrary. It was -- we were told that
12 Mr. Minton had already stopped funding the wrongful death
13 case, and he announced in August or September of 2001 that
14 he was no longer going to provide any funds for the
15 wrongful death case.
16 I was also told -- I didn't know it firsthand
17 at the time, because I'm not involved in the wrongful death
18 case, that at that time you posted a plea on the internet
19 for money saying, "Mr. Minton is no longer funding; I need
20 money," that Ms. Liebreich posted a plea for money needed
21 to cover the case.
22 So there was no demand that he stop it because
23 our understanding was exactly the contrary, he had already
24 stopped seven months earlier, and he publicly announced it.
25 Q. Isn't it true, sir, that you or Mr. Rinder made a

147 demand of Mr. Minton on March 28th that the Jesse Prince and Stacy Brooks affidavits in the Lisa McPherson case would have to be withdrawn and they would not testify in the Lisa McPherson case before the church would consider disengagement?
A. Mr. Dandar, I think you asked me that before, but let me say it as clearly as I can.
The answer is no, number one.
The answer is, number two, as you know, I am not involved in the wrongful death case. I did not attend a single minute of the hearings you recently had before Judge Schaeffer. I represent nobody. I would not even know what affidavits you were referring to when you said something about withdrawing your Jesse Prince affidavit. I would have no idea what it is.
Q. Did you hear Mr. Rinder say that?
A. No, sir.
Q. Do you remember telling Mr. Minton and Mr. Jonas about trying to exert influence over Dandar and Liebreich to get rid of the Lisa McPherson case?
A. No, that's exactly what they said. Mr. Minton said -- I'm not sure he used the word, "exert influence," but Mr. Minton said, in words or substance, that he would talk with you and with Dell, and he was not without influence with you in terms of bringing about -- not a
withdrawal of the case -- a resolution, a settlement.

As I said earlier, the contemplation was that she was a nominal Plaintiff so she needs some money to resolve the case, and our demand was, "Mr. Minton, you pay her; we're not."

Q. Do you remember Mr. Jonas telling you that Mr. Minton cannot commit to making the Lisa McPherson wrongful death case go away?

A. Yes.
Q. What did you say back to Mr. Jonas when he said that?

A. Nothing. He said, "I can't give you a guarantee that we can bring about a resolution of the case."
Fine. You know, I probably just nodded and said, "I hear you."

Q. Isn't it true, sir, that in response to Mr. Jonas saying he can't commit to making the case go away, you said, "I hope this is not a harbinger of things to come because I would be extremely disappointed."?

A. No, sir. First of all, the word is harbinger, not

I harbinger. (Pronunciation.)
Q. Thank you. It's not a word that I use.

A. Okay.
What I said was, in the context of that we were
getting bogged down on this issue and their position was

149 1 that we would have to pay; and it was in that context, the
2 demand that we have to pay to settle the case that I said,
3 "Gee, I hope this is not a harbinger of things to come
4 because we've got x-number of other disputes to talk about;
5 and if we're going to bog down on that kind of a demand,
6 we're not going to get anywhere."
7 Q. Now,do you recall giving a list of demands to
8 Mr. Jonas and Mr. Minton on March 28th?
9 A. I'm sorry. I didn't hear the question.
10 Q. In addition to Exhibit 5 of the 13 items that you
11 listed with the monetary figures next to each one of
12 those -­
13 A. That's background information.
14 Q. -- did you make a further demand on other things
15 that Mr. Minton had to do before there would be
16 disengagement?
17 A. No, sir.
18 Q. Isn't it true the word disengagement is a word
19 Mr. Rinder used?
20 A. Several times.
21 Q. What does that mean?
22 A. It means total disengagement. In fact, if I
23 remember correctly, that word was in Mr. Rinder's statement
24 within the first five minutes of when the meeting started
25 on the 28th,and it was in the context of, "What we would

150 1 prefer, if we can get it, is a global settlement, total
2 disengagement.
3 "We understand, Bob, you want the same thing.
4 If we can't do it, maybe we can talk about resolutions of
5 individual matters, but we would prefer a total
6 disengagement of all areas and matters in which we are
7 adversary to each other, either directly or through your
8 funding or whatever."
9 And I remember Mr. Minton nodded his agreement,
10 and somebody on their side of the table -- it might have
11 been Mr. Jonas -- said, "You mean we can't even send you
12 Christmas cards?"
13 And Mr. Rinder said, "That's right. We reach
14 total disengagement. I don't want to get any Christmas
15 cards from you."
16 Q. Do you remember Mr. Rinder adding onto that
17 definition of disengagement to include investigations of
18 Mr. Minton and his wife and his two daughters?
19 A. That was a demand that was made by Mr. Jonas.
20 That was his agenda as to what he wanted, his set of
21 demands on behalf of Mr. Minton for what would constitute a
22 disengagement. That's correct. Mr. Jonas said that much
23 later in the meeting.
24 Q. Did Mr. Rinder also say that he believed
25 Mr. Minton didn't want any further hassles in his life from

151 1 the Church of Scientology?
2 A. Yes. He said, "I believe you want the same thing
3 we do, total disengagement, complete global peace."
4 Q. Now, the next day on March the 29th, the meeting
5 continued, correct?
6 A. Yes.
7 Q. The meeting on the 28th lasted about all day?
8 A. Well, on and off. We met for a while, then there
9 was a caucus and we met again, and then we took a long
10 lunch. Then we resumed in the afternoon. Then we had
11 another caucus. And then we had, I think it was, a fourth
12 session. It was either four or five all together that day.
13 And then it ended, you know, late in the afternoon, maybe
14 4:30, five o'clock, something like that, on Thursday.
15 Q. Isn't it true on Friday, March 29th you told
16 Mr. Minton that if he wanted disengagement, he would have
17 to meet the demands that were placed on him by Mr. Rinder
18 by April the 9th, the following Friday?
19 A. Sir, there weren't any demands placed by -- there
20 was no proposal for a settlement by Mr. Rinder ever
21 presented, so I don't know what you're talking about.
22 It's not like -- we didn't even give him a
23 dollar amount. We told him how much he had cost us. We
24 didn't even make a demand. We didn't say x-number of
25 dollars we want to get paid or whatever. There was never

152 1 any specific demand. We weren't up to that point.
2 Q. Well, you didn't expect Mr. Minton to add up all
3 of the figures that you're representing to him in his 13
4 items?
5 A. Actually, you reminded me, as another bit of
6 levity, I did not add them up, as you can see. And when we
7 got all done, Mr. Minton laughed and said, "It sounds like
8 a lot of money? How much is it?"
9 And I said, "I don't know; I didn't add it up."
10 And Mr. Jonas said, "I've got something of a
11 running total. I think it's about 40 million."
12 Q. Did you tell Mr. Minton that you intended to get
13 him back in a deposition and delve into his personal
14 financial matters on the 28th or 29th?
15 A. No. I told him that we already had a deposition
16, scheduled for April 8th in this case, that I was to depose
17 Mr. Minton. And, yes, I was going to seek the answers-to
18 the financial matters, questions that I had tried to ask
19 him earlier, he had refused to answer or in many cases
20 invoked Fifth Amendment privilege. Absolutely.
21 MR. DANDAR: I would like to move Exhibit 5,
22 the notes of Mr. Rosen, into evidence.
23 MR. HILL: Your Honor, no objection, so
24 long as the record reflects that in the upper
25 right-hand corner there seems to be a

153 1 handwritten notation in a bracket; "Rosen 3-28
2 notes, hand del,"I guess that's delivered,
3 "6/10/02."
4 Those are not parts of Mr. Rosen's -­
5 THE COURT: Do you acknowledge that?
6 MR. DANDAR: So stipulated.
7 THE COURT: All right. It will be
8 received. Do you have the original one that I
9 marked?
10 MR. DANDAR: Mr. Rosen does.
11 MR. ROSEN: Do you have them, Bill?
12 MR. HILL: No, I don't have them. I've
13 got a copy.
14 MR. DANDAR: That's it.
16 Q. Mr. Rosen, did you meet with Mr. Minton after
17 March 29th?
18 A. No.
19 Q. Do you know how many times Mr. Minton has met with
20 either Mr. Rinder or Ms.Yingling after March 29th?
21 A. I have no idea.
22 The only word I ever said to Mr. Minton after
23 the morning of 29th was when I nodded hello to him if I saw
24 him in a courtroom or when I had,quote, a conversation
25 with him on this witness stand and I examined him, or in

154 1 deposition.
2 I never had a word, outside of the deposition
3 or a courtroom, with Mr. Minton after the morning of the
4 29th of March.
5 Q. And, Mr. Rosen, you were involved in the
6 Wollersheim case in California, correct?
7 A. Yes, sir.
8 Q. And isn't it true, sir, that you used the
9 recantation affidavit of Stacy Brooks in the Wollersheim
10 case in California in an attempt to get Mr. Leipold, the
11 attorney representing Mr. Wollersheim, disqualified from
12 the case?
13 A. Sir, I don't know what you're talking about, I
14 really don't.
15 MR. HILL: Your Honor, I hesitate to rise to
16 object, but I understood Mr. Rosen was on the witness stand
17 to question him in reference to March 28th and March 29th.
18 THE COURT: That's what I understood.
19 MR. DANDAR: I apologize, Judge. I don't
20 think I announced that I was restricting my
21 questions just to the 28th and the 29th.
22 THE COURT: I'm announcing it, okay,
23 because it's about your case. Now, it isn't
24 about what Mr. Rosen does in some other case.
25 It's about what he did in this case.

155 1 And I don't see what the relevance of what
2 Mr. Rosen does in some other case has to do
3 with this, unless you can explain to me why it
4 is significant or relevant of what he's done in
5 some other case that doesn't involve
6 Mr. Minton.
7 MR. DANDAR: Ms. Brooks is Mr. Minton's
8 mistress. She used to be my consultant on the
9 wrongful death case.
10 Her affidavit in this case and in the
11 wrongful death case was used by Mr. Rosen in
12 the Wollersheim case in California accusing
13 Mr. Leipold of suborning perjury, the same
14 thing they're trying to do here against me.
15 He said that they didn't try to get this
16 wrongful death case dismissed or the
17 Wollersheim case dismissed, but there's
18 correspondence between Mr. Minton and
19 Mr. Leipold and testimony by Ms. Brooks and
20 Mr. Minton to the contrary. There's testimony
21 by Ms. Yingling to the contrary.
22 So I didn't know Mr. Rosen was going to
23 agree with the statements and testimony of
24 Ms. Yingling, but apparently he's in direct
25 opposite of what she said before Judge

156 Schaeffer and what her notes say that are in evidence before Judge Schaeffer. I would like to offer -

THE COURT: See, since her testimony and anything that she's going to say is not here, I just don't know, you know, what the significance of all of that is. You know, we're here to find out if you suborned perjury, you know, and that's what I would like for you to kind of concentrate on.


Q. Mr. Rosen, during March 28th and March 29th, did you or Mr. Rinder ever say to Mr. Minton, "You have to set the record straight in the wrongful death case"?

A. That's half right, Mr. Dandar, so let me help you. Mr. Rinder made a presentation towards the beginning of the meeting as follows:

The churches have a long history of having suffered as follows: Somebody puts in an affidavit or provides deposition testimony in one case which is false. Years later, that affidavit, that deposition, is provided in some other case to say look what somebody else said about RTC, for example, earlier.
What Mr. Rinder said is, your people have put

1 in affidavits. To the extent those affidavits are
2 incorrect -- and I believe his words were -- "I want you to
3 correct the record."
4 And it didn't apply to one particular case.
5 Clearly one of the cases involved was Wollersheim where
6 there were affidavits filed in that case by people paid by
7 Mr. Minton, but it was also Ward, the Ward case. It was
8 also the wrongful death case. It was also the case that
9 had been completed in Denver, the FACTNet case.
10 And what Mr. Rinder said -- and he wasn't
11 talking about any particular affidavit. He never mentioned
12 any particular affidavit at all.
13 All he said was, "Your people have put in a lot
14 of affidavits, and all I want you to do is correct the
15 record to the extent that they are incorrect."
16 There was not even a discussion of any
17 particular affidavit or of what was wrong with it, you
18 know, like Paragraph 3 is incorrect.
19 It was just a general, "Correct the record,"
20 because we don't want to have to deal with two years from
21 now we'll be litigating some case in Omaha and somebody
22 will walk in with an affidavit that you paid for,
23 Mr. Minton, that was put in in some case in California or
24 Florida or Denver and say, "Here's what Ms. Brooks or
25 Mr. Prince said about those Scientology people two years
1 ago."
2 That was the issue. And he said, "Just correct
3 the record; whatever it is."
4 Q. So Mr. Rinder -- neither Mr. Rinder nor you told
5 Mr. Minton or Ms. Brooks that they had perjured themselves
6 in their prior depositions in the Lisa McPherson case or
7 the case before Judge Baird?
8 A. Is that a question?
9 Q. That's a question.
10 A. The answer is, no, I did not, nor did Mr. Rinder,
11 accuse anybody of perjury.
12 In fact, to the contrary, this meeting was
13 cordial, it was civil, there was a lot of bantering and
14 jokes. I mean, I couldn't believe it. It was encouraging
15 that these people who had been at war with each other for
16 so many years could sit for so many hours, you know, and
17 have a pleasant civil conversation to try and resolve their
18 differences.
19 There were never any threats. And certainly
20 words like, "You committed perjury," would never have been
21 used.
22 MR. DANDAR: That's all I have.
24 Q. One other question.
25 Did you ever hear Mr. Minton say that

158 1 Mr. Michael Rinder was the trigger on the gun, and
2 Mr. Moxon, the attorney, the in-house attorney for the
3 Church of Scientology, was aiming the gun at him?
4 MR. HILL: Objection, temporal as to time. Are
5 we back at any time or are we back on these two days of
6 meetings?
7 MR. DANDAR: Any time.
8 THE COURT: Is this during these two days?
9 MR. DANDAR: I don't know. It could be.
10 I don't know. It's a broad question. It's at
11 any time.
12 MR. HILL: Well, Your Honor, my objection
13 is this: Mr. Rosen is Counsel in this case.
14 It's an unusual procedure where you let one
15 Counsel call another Counsel.
16 It's solely for the purpose of delving
17 into these two days of meetings. And if the
18 question relates to those two days, then I'll
19 withdraw my objection; but outside of those two
20 days, I object.
21 MR. DANDAR: My question is very broad.
22 It goes beyond the two days.
23 MR. HILL: I object.
24 THE COURT: I don't see the relevance of
25 it if it goes beyond the two days.

160 1 BY MR. DANDAR:
2 Q. Then I will rephrase it to the two days of March
3 28th and 29th. Did you ever hear Mr. Minton say that?
4 A. No, sir.
5 MR. DANDAR: That's all I have.
8 Q. Mr. Rosen, can you state your complete name for
9 the record, please.
10 A. Samuel David Rosen.
11 Q. Mr. Rosen, can you tell us something about your
12 educational background. Start with college and walk us
13 through law school.
14 A. I'm going to try to be real quick, bachelor of
15 arts in philosophy, Boston University, 1966, twenty
16 something credits, I think, towards a master's --
17 MR. DANDAR: Relevance, Judge. You wanted-to
18 hurry up and get through this, and I didn't ask
19 him anything about his qualifications.
20 THE COURT: You were the one who called
21 him. You're the one that's putting his
22 credibility and apparently his testimony on,
23 you know, before this Court, okay?
24 I think it's important -- apparently it's
25 important to him to get across this