VS. CASE NO. 00-002750-CI-20

DELL LIEBREICH, individually and
as Personal Representative of

the Estate of Lisa McPherson,


BEFORE: The Honorable W. Douglas Baird
Circuit Judge

PLACE: 315 Court Street
Clearwater, Florida
DATE: August 29 - August 30, 2002

REPORTED BY: Susan M. Valsecchi, RPR

Registered Professional Court Reporter
Sixth Judicial Circuit



Pages 292 - 468 (Excluding Index.)

(727) 443-0992


Post Office Box 1368
4 Clearwater, Florida 33757
(727) 461-1818
5 and
600 Peachtree Street, NE, Suite 2400
7 Atlanta, Georgia 30308-2222
8 Attorneys for Plaintiff
11 P.O. Box 24597
Tampa, Florida 33623
12 Attorneys for Dell Liebreich







3 BY MR. ROSEN 310























1 P R O C E E D I N G S
2 (Thereupon, the transcript continues directly
3 from Volume II.)
5 MR. DANDAR: Judge, do you want us to
6 proffer after Mr. Rosen is finished his
7 cross-examination?
8 THE COURT: Proffer what?
9 MR. DANDAR: Mr. Prince's testimony on the
10 written policies of the Church of Scientology
11 on manufacturing -­
12 THE COURT: Yeah, let's do that
13 afterwards. Let's get through the testimony
14 first.
15 MR. ROSEN: Your Honor, two preliminary
16 things.
17 With respect to what I handed up to you
18 yesterday, Volume II, Mr. Dandar has informed
19 me that he has no objections to any of these
20 other than relevance; and rather than take up
21 the Court's time, we will put it in a brief if
22 he wants to argue why it's not relevant.
23 The second thing is, with respect to the
24 designations - and I will be real brief with
25 this last item.
1 With respect to the designations that
2 Mr. Dandar wants to put in from the testimony
3 before Judge Schaeffer, so he told us, it was
4 in his closing argument. Here is his written
5 closing argument.
6 We took some time to go through these.
7 Let me tell you what the problem is. I don't
8 even know what the designations are. In some
9 places; the designations have no pages. It's a
10 designation that says, "Minton deposition,
11 January 18th."
12 There's no page designations.
13 And he's quoting in his brief from the
14 deposition, not from the testimony before Judge
15 Schaeffer, but from some deposition that had
16 been taken. That's one problem.
17 THE COURT: So he wants to put in argument
18 where he's quoting from a deposition -­
19 MR. ROSEN: Yeah.
20 THE COURT: -- that's not in the record.
21 MR. ROSEN: Right.
22 THE COURT: Well, why can't he just put in
23 the record itself, rather than his -­
24 MR. ROSEN: He could if he would give us a
25 designation, when I said yesterday, in terms of


1 page and line.
2 Now, let me tell you what we have. Apart
3 from some of this stuff is deposition, it's not
4 trial testimony, this thing is a mess.
5 There are references, he has quotes,
6 references, to testimony given with a date,
7 with no page number in his brief. I can't deal
8 with that.
9 THE COURT: Well, first of all, I don't
10 understand, Mr. Dandar, why I should let you
11 put in as evidence an argument that you made in
12 front of Judge Schaeffer.
13 MR. DANDAR: It's not an argument.
14 THE COURT: Well, isn't that your final
15 argument?
16 MR. DANDAR: Yeah, but I'm not asking you
17 for argument -­
18 THE COURT: Well, that's what it is, then.
19 MR. DANDAR: No. It's the quotes of
20 testimony.
21 THE COURT: It's you quoting testimony,
22 right?
23 MR. DANDAR: No. These are copies right
24 out of the transcript. It's not paraphrasing.
25 THE COURT: Why is it, you know, in this

case continually we have people talking like they're on two different pages, I mean, black is white. What the hell is going on?
That's either an argument where you're writing down words and saying what somebody else said or it's actual copies of depositions or evidence.
MR. DANDAR: Right.
THE COURT: Is that it? Don't come up here to the bench.
What is it, Mr. Rosen?
MR. ROSEN: Mr. Dandar told you yesterday that what he wanted were the quotations set forth in this document, that, they were trial testimony before Judge Schaeffer.
We go back and say, okay, we'll do our fairness designations. He said that we had page and line. We look at this.
Some of the, quote, quotations in here are not from trial testimony before Judge Schaeffer. They're from a deposition where we don't even have a page and line.
It's just that there's a quotation attributed to Mr. Minton with a citation that says, "January 18th, 2000 deposition of
1 Mr. Minton."
2 We then have quotations, which purport to
3 be from the trial before Judge Schaeffer with
4 no page numbers.
5 THE COURT: That's it, okay? I'm not
6 taking anything out of that, nothing. Okay?
7 If you have evidence that you want to
8 present, present the evidence, testimony
9 itself, transcripts of testimony, transcripts
10 of depositions, that's all. Nothing out of
11 that. I'm not doing that.
12 MR. DANDAR: Judge, I'm not asking to do
13 that.
14 THE COURT: Okay.
15 MR. DANDAR: I don't know why he's making
16 this argument.
17 THE COURT: Well, then forget it. We
18 don't have a problem.
19 MR. DANDAR: I excused all of my live
20 witnesses for the day based upon what we said
21 yesterday.
22 I want to file with the Court in the file
23 the hearing testimony of witnesses before Judge
24 Schaeffer, and then I want to file a closing
25 argument with the Court where I pull out the

1 pertinent passages of that testimony before
2 Judge Schaeffer of witnesses you have not heard
3 live, rather than have you read all of it.
4 I mean, why should you read all of the
5 transcript testimony that has nothing to do
6 with the issues in this case?
7 Let me just pull it out, put it in a
8 closing argument like I did for Judge
9 Schaeffer, and I will have the pertinent
10 passages -- not me arguing, but the passages of
11 the testimony.
12 THE COURT: You can do whatever you want.
13 I'm just telling you that in terms of evidence,
14 the evidence I'm going to receive is the sworn
15 testimony of witnesses at deposition or in
16 trial.
17 MR. DANDAR: That's fine.
18 THE COURT: That's it. I'm not accepting
19 your recitation of that in some other document,
20 okay?
21 MR. DANDAR: I never asked you to do that.
22 THE COURT: Good. Then we don't have a
23 problem.
24 MR. DANDAR: We don't have a problem.
25 THE COURT: And in terms of placing in the
1 record portions of testimony, I don’t want you
2 to just take the whole record and throw it in
3 the file and then refer to portions of it.
4 If you want to put some testimony in, put
5 in that testimony, those pages; you know, maybe
6 a page before and a page after to make sure
7 that it's in context.
8 But there's no sense in crapping up the
9 record any more than it already is with a bunch
10 of testimony that I'm never going to read that
11 has no significance.
12 MR. DANDAR: Well, for instance -- let me
13 just give you a for instance.
14 If I have testimony of like Brian Haney,
15 you don't know who Brian Haney is. I will have
16 to put in some of that testimony so you know
17 THE COURT: I was blissfully unaware of
18 who Brian Haney was until he called me on the
19 telephone this morning and tried to talk to me.
20 MR. DANDAR: No.
21 THE COURT: Yeah. So, you know…
22 MR. DANDAR: Can you tell me what he said?
23 THE COURT: I didn't let him say anything.
24 I said, "I can't listen to anything you want to
25 say. If you want to come in and testify and

1 subject yourself to cross-examination, that's
2 up to you and the attorneys. I don't want to
3 hear it."
4 MR. DANDAR: I would be shocked if Brian
5 Haney called you. I would be absolutely
6 shocked.
7 THE COURT: I believe that's who it was.
8 MR. ROSEN: Your Honor, my problem is as
9 follows: If Mr. Dandar does what he says he's
10 going to do -- let's take as an
11 example -- let's say he's using Haney.
12 So Mr. Haney testified before Judge
13 Schaeffer. If he puts it in evidence here as
14 what he wants to try to offer as excerpts from
15 that testimony, then I can rebut it, I can
16 object on relevance, I can give you fairness
17 designations. I can say, wait a minute, two
18 lines later he corrected himself. I can do all
19 of those things you do when you're confronted
20 with evidence.
21 If he's going to walk out of here today
22 and file a post-trial brief and put this in for
23 the first time, you know, I'm going to be
24 screaming unfair.
25 THE COURT: Well, then, you would be
1 right.
2 MR. DANDAR: Then I need more time. I
3 cannot go through six or seven witness
4 testimony -­
5 THE COURT: Today is the day. We're doing
6 the hearing today. Whatever you need to do to
7 finish up, you need to put it in.
8 MR. DANDAR: Then I don't have the time to
9 go through six witnesses and pull out excerpts.
10 THE COURT: What do you want me to do?
11 MR. DANDAR: I want you to let me file the
12 testimony, and I'll pull out the excerpts in a
13 closing so you don't have to read all of it,
14 you just read the excerpts, and then he can
15 make a reply to that.
16 He thinks it's not relevant, fine, he can
17 say that. He can put it in writing, it's not
18 relevant, or I misquoted it or there was
19 something two pages later that I forgot to put
20 in.
21 MR. ROSEN: This is the reason we raised
22 this issue a week ago. We said, give us the
23 page and line designations that you want to
24 offer, and we will give you a response before
25 this hearing starts, you know, we have no

1 objection, we object on relevance, fairness,
2 whatever it may be.
3 Mr. Pope wrote to this man a week ago and
4 told him that, and he decided to stonewall him.
5 MR. DANDAR: No, I responded to that.
6 MR. ROSEN: We have never gotten a single
7 page and line reference.
8 THE COURT: I don't want to hear it. This
9 is an evidentiary hearing. I'm going to
10 receive the evidence at this hearing, and then
11 you can argue about what that evidence means,
12 but we're not going to just make it some sort
13 of a summary judgment hearing where you include
14 portions of the record and argue about it and
15 let them do the same thing. That's just not
16 what it is. This is an evidentiary hearing.
17 That's why we're here.
18 MR. DANDAR: And that's why I'm requesting
19 to put in all of the evidence because if you
20 just have the excerpt, that's-all you see and
21 you don't see the benefit of who this witness
22 is, what his bias may be, her bias may be, the
23 experience they have, then you're not going to
24 have the full picture, and that's not going to
25 be fair.
1 THE COURT: I guess you're just going to
2 have to -- I don't know what to tell you, you
3 know. I mean, that's just -- that's nuts, just
4 throwing a bunch of testimony in and then
5 arguing about it later. I mean, this is why we
6 have a hearing, so things are subject to
7 cross-examination, subject to objection.
8 You know, it's not just throw it all on
9 the table and let me sort it out.
10 MR. DANDAR: No, I want to sort it out in
11 a written closing for you so you don't spend
12 wasteful hours reading things that have nothing
13 to do with the issues that they now say are the
14 issues in the case pursuant to their motion to
15 limit the evidence filed in this case.
16 That's what I'm going by. I'm going by
17 their August 24th motion to limit the evidence.
18 There's six issues they raised now for the
19 first time that now I know what their grounds
20 are, and I'm going to respond to that.
21 And quite frankly, Judge, the only issue
22 that they raise that has anything to do with
23 this case and testimony in this case is
24 Mr. Minton's October 2001 deposition, and
25 they're claiming that Mr. Minton lied in that
1 deposition when he said he didn't have a
2 meeting with all of these people in my office
3 to talk about adding on David Miscavige.
4 MR. ROSEN: Okay. If that's what he
5 wants, I stipulate to put in the entire
6 deposition transcript of that day. You can
7 have it in evidence. Done.
8 THE COURT: That's what you want, right?
9 You want the transcript of all of the testimony
10 in front of Schaeffer, all 35 days' worth,
11 right?
12 MR. DANDAR: No, that's not what I'm
13 saying.
14 THE COURT: What are you saying?
15 MR. DANDAR: I'm saying Monique Yingling's
16 testimony, I went through it last night until
17 12:30 in the morning and I couldn't go any
18 further. I got up at 5 a.m. and I just
19 couldn't get it done.
20 It's like almost every other page I'm
21 highlighting on things that I want for you to
22 consider.
23 I want to be able to put in all of her
24 testimony and pull out the pertinent passages
25 for your consideration, along with John
1 Merrett, Dan Leipold, and there's just a few
2 portions of Bob Minton's testimony and just a
3 few portions of Stacy Brooks', and there's
4 Teresa Summers and Peter Alexander, small
5 portions, because Judge Schaeffer was concerned
6 with a lot more issues than what's in this
7 court, and I don't want to bring all of those
8 other issues in. I don't want to hand you
9 something like this.
10 Your issues are -- and tell me if I'm
11 right or wrong, Judge. Their Motion to
12 Disqualify concerns whether or not I suborned
13 perjury of anybody in this case, not what
14 happened in Judge Schaeffer's case, so I'm
15 saying, the only thing that they raised about
16 subornation of perjury is whether or not there
17 was this special meeting called by me where
18 Mr. Minton attended in 1999 to add on parties.
19 Mr. Minton said it didn't happen in his
20 deposition. Now he says it did happen. Of
21 course, he's the only one, along with Stacy
22 Brooks.
23 THE COURT: I think there's more to it
24 than that. I think it also involves
25 Mr. Minton's financing of the case and

1 statements he made at the deposition regarding
2 money that he provided and so on.
3 MR. ROSEN: Yes, and his ability to
4 disclose the bank checks, the Swiss bank
5 checks.
6 THE COURT: There's more to it than just
7 that.
8 MR. DANDAR: Judge, I beg to differ.
9 Their motion to limit the evidence says -- on
10 those areas -- I suborned perjury in filing
11 affidavits of myself and my client and
12 Mr. Minton in the wrongful death case.
13 On the UBS check, it's Mr. Minton's
14 deposition of May 2000 in the wrongful death
15 case.
16 THE COURT: Well, it's going to be
17 whatever it's going to be. Just go ahead and
18 submit the transcripts of those witnesses'
19 testimony. I don't want to argue with you
20 about it anymore, okay? Just submit it. Just
21 do it.
22 MR. DANDAR: Will you give me permission
23 to file a written closing argument?
24 THE COURT: If it's evidence, it's
25 testimony given under oath, submit it, and then

1 you've got to argue about it, right?
2 MR. DANDAR: Well, may I please have the
3 opportunity to submit a closing written
4 argument where I pull out the excerpts?
5 THE COURT: I'm going to require that
6 anyway.
7 MR. DANDAR: Pardon me?
8 THE COURT: I'm going to require that
9 anyway.
10 MR. DANDAR: Thank you.
11 MR. ROSEN: Your Honor, I was going to
12 suggest something.
13 If there's anything we can salvage here,
14 the parties had agreed before Judge Schaeffer
15 to a briefing schedule in that case, which I'm
16 going to propose the same briefing schedule.
17 And that is, as the moving party, we file
18 our brief. I don't call it a closing
19 statement; I call it a post-trial brief. And
20 then pursuant to the same agreement before
21 Judge Schaeffer, Mr. Dandar has a week to file
22 his opposition, I have a week to file a reply.
23 THE COURT: We will talk about it later.
24 I'm not going to worry about it right now.
25 MR. ROSEN: Okay.

1 THE COURT: Let's get Mr. Prince up here
2 and let's get moving.
3 MR. ROSEN: Sure.
4 THE COURT: Mr. Prince, you're still under
5 oath.
8 Q. Mr. Prince, will you tell the Court what your
9 occupation is.
10 A. I'm a student at St. Pete College.
11 Q. Full time?
12 A. Partially, part-time.
13 Q. How part-time? One course a semester?
14 A. You want a pie chart?
15 Q. What?
16 A. Do you want me to do a pie chart?
17 THE COURT: Mr. Prince, just listen to the
18 questions and answer them if you can. We don't
19 need to have any bantering back and forth,
20 okay?
21 THE WITNESS: Doesn't part time mean part
22 time? That's what I said. He asked me twice.
23 I answered it twice. What else can I say?
25 Q. Mr. Prince, are you presently taking courses at

1 that college?
2 A. Yes.
3 Q. How many hours a week do you attend?
4 A. Approximately six.
5 Q. And have you taken -- did you take courses there
6 in the last semester, the semester that ended approximately
7 May of this year or have you just enrolled?
8 A. I began this semester.
9 Q. In the summer, the semester being the summer
10 semester, right, or is it the fall semester here?
11 A. This semester that just started?
12 Q. Yes, sir. When did it start?
13 A. August, this month.
14 Q. Okay. So when I asked you a moment ago what your
15 occupation is, you told me you were a student, which
16 started a month ago, for six hours a week.
17 What's your occupation other than being a
18 part-time student, Mr. Prince?
19 A. I have no other occupation.
20 Q. You have none.
21 Mr. Prince, when was the last time you had an
22 occupation?
23 A. I guess I don't understand the question.
24 Q. Well, let me ask it another way. You testified
25 yesterday to being paid by various people -- Mr. Minton,
1 LMT, Mr. Dandar -- to provide services relating to
2 Scientology, right?
3 A. No, I did not testify to that at all.
4 Q. Did you testify to being paid by anybody yesterday
5 to provide services for Mr. Dandar in connection with the
6 Scientology cases?
7 A. I think the record will speak for itself, what I
8 testified to.
9 MR. ROSEN: Your Honor; can I ask that the
10 witness be instructed to answer the question?
11 THE WITNESS: Well, then, I don't
12 understand your question. If the record
13 doesn't speak for itself; I don't know what to
14 say.
15 THE COURT: That's not your decision to
16 make, Mr. Prince. You're to answer the
17 question, okay?
18 THE WITNESS: I'm doing the best I can,
19 Your Honor.
20 THE COURT: Well, try a little harder, all
21 right?
22 THE WITNESS: I will do the best that I
23 can.
24 THE COURT: See that you do.
25 THE WITNESS: I will.
2 Q. Mr. Prince, before you began providing assistance
3 or affidavits or whatever in Scientology cases, did you
4 have an occupation before that?
5 A. I guess I don't understand your question,
6 Mr. Rosen.
7 Q. Which part don't you understand, Mr. Prince?
8 A. All of it.
9 Q. Mr. Prince, did you ever -- tell me the last time
10 you had a job. How is that? Do you understand the word
11 job, sir? Tell me the last time you had a job.
12 A. I have a job now.
13 Q. What's your job now?
14 A. Answering your questions.
15 MR. ROSEN: Your Honor, I move to strike
16 this. This is ridiculous. I'm going to ask to
17 strike this witness's entire testimony.
18 THE COURT: Well, we're not going to
19 strike his testimony, but if he doesn't start
20 responding to your questions, I'm just going to
21 have him taken into custody and he can spend
22 some time with the county, all right?
23 I'm going to hold you in direct contempt
24 if you do not start responding to these
25 questions, okay?
1 THE WITNESS: Your Honor, I will answer
2 the questions as best I can.
3 THE COURT: All right.
4 THE WITNESS: If I understand the
5 question, I will answer it. If I don't, I'm
6 going to say I don't understand the question.
7 If that puts me in jail, then I guess that's
8 where I'm going.
9 THE COURT: Well, I guess it does. We'll
10 just have to see.
12 Q. I will repeat the question. When was the last
13 time you had a job?
14 A. I was last employed by the Lisa McPherson Trust.
15 Q. As in connection with the
16 Scientology -- McPherson/ Scientology case, right?
17 A. No.
18 Q. In connection with what? What were you employed
19 to do, Mr. Prince?
20 A. To help people that had been abused and deceived
21 by your clients, Church of Scientology.
22 Q. Okay. So you were some sort of counselor, right?
23 A. You can paraphrase it that way if that simplifies
24 it.
25 Q. Mr. Prince, in the time that you have been paid to
1 provide services, whether it be counseling people or
2 providing services and testimony in connection with the
3 McPherson case, during this period of time, have you had
4 any other job?
5 A. Oh, my God, you know -­
6 MR. DANDAR: Objection to the form of that
7 question.
8 THE WITNESS: I just don't get it. It
9 runs on and on, and I can't answer the
10 question. There's too many questions in the
11 question.
13 Q. I will try to help you out, Mr. Prince.
14 When was it that you first began receiving any
15 money? I don't care whether you call it wages or a
16 retainer or handouts. When was it you first started
17 receiving money from Mr. Minton, a place to live, a car?
18 A. I don't think I have ever received money from
19 Mr. Minton or there's been a consecutive period of time.
20 Maybe there's isolated instances of that, but there's been
21 no repetitious or routine of me receiving money from
22 Mr. Minton.
23 Q. I'm going to make it easier for you.
24 MR. DANDAR: Judge, I object. Can we have
25 Mr. Rosen not make these editorial comments.
MR. ROSEN: I apologize, Your Honor. I won't do that.
Q. Mr. Prince, when is it that you first met Mr. Minton?
A. I think as I testified yesterday, I first met him in the summer of 1998.
Q. And that was through Ms. Brooks who you first resumed contact with when, the same year?
A. You lost me. I don't understand what you're trying to ask me.
Q. You told us yesterday that the way you hooked up
with Mr. Minton was you first renewed contact with
Ms. Brooks and then that led to then meeting Mr. Minton; do
you remember that?
A. Yes.
Q. Good. Okay. When was it that you hooked up again with Ms. Brooks?
A. I guess I don't understand your question. I don't understand what you're asking me. Do you mean when did I talk to her again after she introduced me to Minton or --
Q. No, before she introduced you to Minton.
A. So when did I hook up with her before she introduced me to Mr. Minton? I guess the time period would have been maybe a couple of months.
1 Q. And still in the year 1998?
2 A. Correct.
3 Q. Okay. Let's take from that period to today.
4 Other than being paid to provide services in
5 the wrongful death case or this case or some other
6 Scientology case, and other than being paid by LMT to
7 counsel people, have you had any other job?
8 MR. DANDAR: Objection. What time frame are we
9 talking about?
10 MR. ROSEN: I just defined it. Since --
12 Q. Since you resumed contact with Ms. Brooks in 1998,
13 have you had any job, Mr. Prince?
14 A. I've owned my own businesses. I have had a
15 business, sure.
16 Q. Mr. Prince, are you telling me that you have
17 operated your own businesses since 1998?
18 A. No, I'm not telling you that at all.
19 Q. Oh, let's start all over again.
20 From the time that you resumed
21 contact -- reconnected with Ms. Brooks at sometime in 1998,
22 a few months before meeting Mr. Minton, until today, as you
23 sit here today, have you had any job, other than with the
24 Scientology stuff and counseling? Have you had any job,
25 sir?

1 A. Again, like I said, I did have a business
2 that I -- I'm sorry if that's unacceptable.
3 Q. Tell me what years it was that you operated the
4 business after meeting Ms. Brooks in 1998.
5 A. From 1998 to 1999.
6 Q. And what business was that, sir?
7 A. Art dealership.
8 Q. And was that a business that you operated in
9 Minneapolis?
10 A. Yes.
11 Q. Yeah?
12 Now, Mr. Prince, my desire here is not to trap
13 you, so let me see if I can help refresh your memory.
14 MR. DANDAR: Objection. That's improper, the
15 comments not to trap you.
16 THE COURT: Overruled. Let's just see if
17 we can get through this, all right, Mr. Dandar?
19 Q. Mr. Prince, you filed for bankruptcy in that
20 business in Minneapolis in 1997; didn't you?
21 A. No.
22 MR. ROSEN: May I approach, Your Honor?
23 THE COURT: Yes.

25 Q. I show you what's been marked for identification

1 as Exhibit 169, Mr. Prince.
2 MR. DANDAR: Can I have a copy of the exhibit,
3 please?
5 Q. Can you tell me what that is?
6 MR. DANDAR: Can I have a copy, please?
8 Q. What is it, Mr. Prince?
9 A. If you will give me a moment --
10 Q. Sure. Well, let me see if I can help you. Turn
11 to Page 2 of the document. Is that your signature?
12 A. I can just do one thing at a time, please.
13 Now, you asked me what this was. This looks
14 like a statement of personal bankruptcy, and I think the
15 issue was a business bankruptcy. I have never filed for
16 bankruptcy as a business, but this is as an individual. I
17 did not file the business that I had for bankruptcy.
18 Q. Mr. Prince, is this a bankruptcy petition filed in
19 Minneapolis in 1997?
20 A. Yes, it is.
21 Q. And you say it's personal, it's not a business,
22 but your business that you operated in Minnesota, you
23 didn't have a corporation. You operated it in your own
24 name, right? Yes or no, sir?
25 MR. DANDAR: Argumentative.

1 THE COURT: Overruled.
3 Q. Yes or no?
4 A. We're talking about a period from 1998 to
5 1997 - to 1999.
6 Q. No, sir.
7 A. In 1997, this was not the business that I had.
8 We're not talking about the same business.
9 Q. Hold it.
10 A. We're not talking about the same thing here.
11 Q. Hold it, Mr. Prince. You're not listening to my
12 question.
13 A. Okay.
14 Q. In 1997, were you operating an art business in
15 Minneapolis in the state of Minnesota?
16 A. I was an independent contractor in 1997.
17 Q. Were you operating an art business?
18 A. I was an independent contractor in 1997.
19 Q. Did you own the business?
20 A. I was an independent contractor in 1997.
21 MR. ROSEN: Your Honor --
23 Q. Were you an employee?
24 A. I was an independent contractor in 1997.
25 THE COURT: Mr. Prince, let me ask you

1 something. Who were you an independent contractor for?

2 THE WITNESS: Various art manufacturers.
3 THE COURT: So you were like an agent?
4 THE WITNESS: A representative agent, yes,
5 correct.
6 THE COURT: Okay. And that was your
7 business, was being a rep for various art
8 people?
9 THE WITNESS: That was my means of income;
10 yes, it was.
11 THE COURT: And was that incorporated?
12 THE WITNESS: No, it was not.
13 THE COURT: That was just you personally.
15 THE COURT: Okay.
17 Q. Now, as part of that un-incorporated business, did
18 you include in your filing in bankruptcy in 1997 debts that
19 you incurred in operating that business as opposed to
20 personal debts?
21 A. I'm not sure. I don't remember.
22 Q. Well, why don't I direct your attention to the
23 third page of the document -­
24 A. Okay.
25 Q. -- your list of creditors.
1 G.E. Capital, you had some personal obligation
2 to G.E. Capital as opposed to a business debt?
3 A. Yes.
4 Q. What was that personal obligation?
5 A. Car lease.
6 Q. Okay. And all of these creditors here have
7 nothing to do with your independent contractor business?
8 A. Correct.
9 Q. Okay. Now, after this, did you then -- are you
10 saying that after this you had a business of
11 being -- continued to have a business or resumed the
12 business of being an art dealer?
13 A. I actually formed my own business and
19 operated -- hired employees and operated in art shows,
15 kiosks in malls, this type of thing.
16 Q. And what was the name of that corporation?
17 A. The Art Guy.
18 Q. Huh?
19 A. The Art Guy.
20 Q. The Art Guide?
21 A. No, the Art Guy, G-u-y.
22 Q. G-u-y?
23 A. Correct.
24 Q. Was that a corporation, sir?
25 A. No.
1 Q. When did you form that business?
2 A. As best as I can tell or recall, sometime shortly
3 after I filed bankruptcy, within six months of the filing
4 of this document.
5 Q. Okay. So it was sometime in 1997?
6 A. Within six months of the filing of this document
7 is the best of my recollection.
8 Q. And you formed that business in Minneapolis?
9 A. Correct.
10 Q. What was the address of that business?
11 A. My own personal address where I lived.
12 Q. Your house? Your apartment?
13 A. Correct.
14 Q. Uh-huh. (Affirmative.)
15 And the employees that you say you had, they
16 were in Minneapolis, I assume, right?
17 A. Some of them were.
18 Q. When did you stop operating that business,
19 Mr. Prince?
20 MR. DANDAR: Judge, relevancy.
21 THE COURT: Overruled.
22 THE WITNESS: I would say sometime in
23 1999.
25 Q. Mr. Prince, when did you leave Minneapolis and

1 move to Colorado? Do you remember the day you set out in a
2 van that Mr. Minton bought for you?
3 A. No, I have no recollection of that, and what
4 you're saying is false. Mr. Minton never bought me a van.
5 Q. Okay. I will take it one step at a time.
6 A. Okay.
7 Q. When did you leave Minneapolis -­
8 MR. DANDAR: Can we have Mr. Rosen not
9 interrupt the.wi.tness while he's answering?
10 THE COURT: Yes.
11 MR. ROSEN: Sorry.
13 Q. When did you leave Minneapolis and relocate
14 yourself to Colorado?
15 A. I would have to say in the late summer or early
16 fall, to the best of my recollection.
17 Q. I didn't hear. What year did you say?
18 A. I thought we were talking about 1998. Now, you
19 asked me when in 1998, and my answer was I believe it was
20 the late summer, maybe early fall.
21 Q. Okay. So in 1998 you packed up your belongings
22 and moved to Colorado, right?
23 A. Correct.
24 Q. And the reason you moved to Colorado was that
25 Mr. Minton and Ms. Brooks were involved with
1 Mr. Wollersheim in an anti-cult, for lack of a better term,
2 group called FACT Net?
3 A. That's incorrect.
4 Q. Why did you move to Colorado?
5 A. Because by the mere fact of even talking to Stacy
6' Brooks, I received a letter from Scientology's attorney,
7 Elliot Abelson, threatening to sue me.
8 Then a horde of private investigators just
9 started following me wherever I went, and I literally had
10 no one, no place, to be protected or to even freely
11 associate with the people that would understand what the
12 problem was I was having.
13 Q. Well, let me see if I understand this.
14 Mr. Abelson is in Los Angeles?
15 A. I couldn't tell you where Mr. Abelson was.
16 Q. You said you got a letter from him.
17 A. Correct, in 1998.
18 Q. He was in Los Angeles?
19 A. I don't recall where he was.
20 Q. So let's see if I get this right:
21 Now, he sent you a letter in Minneapolis with
22 some sort of a threat, and you decided that the best way to
23 hide from Scientology was to move to Colorado; is that
24 right?
25 A. I think you're mischaracterizing my testimony. I
1 said that private investigators were hired and they started
2 following me around and taking pictures and on and on and
3 on. That was a part of their drill.
4 Q. I see. So you decided that in order to get rid of
5 private investigators that were following you in
6 Minneapolis, you should move to Colorado?
7 A. I felt that I would be better protected there,
8 yes.
9 Q. Who was going to protect you there, Colorado State
10 Troopers? Who was going to protect you there better than
11 you were protected in Minneapolis?
12 A. I can answer your question or you can keep
13 answering them yourself and I will just sit here.
14 Q. Who was going to protect you in Colorado better
15 than the police or whoever could protect you in
16 Minneapolis?
17 A. I went to Colorado specifically because there were
18 people there that understood the problem, had dealt with it
19 before.
20 I think it's a matter of court record, judges
21 have found that in this particular instance that
22 Scientology certainly had run its fair game campaign, you
23 know, pursuant to its prime directive to utterly destroy
24 people, and they had figured out a defense for that,
25 Mr. Wollersheim in particular. That's who I'm talking
1 about. So I went there to seek that kind of shelter.
2 MR. ROSEN: I'll move to strike everything
3 except, "I went to Colorado to seek the shelter
4 of Mr. Wollersheim."
5 MR. DANDAR: Judge, he asked an open -­
6 THE COURT: Denied. Move on.
8 Q. Okay. So the reason you moved to Colorado, then,
9 was because these private detectives that were harassing
10 you in Minneapolis, you were looking to Mr. Wollersheim to
11 protect you from these private detectives in Colorado,
12 right?
13 A. That's quite a long statement, but the reason I
14 moved to Colorado specifically is because your client,
15 Church of Scientology, enacted its prime directive to
16 destroy me utterly.
17 MR. ROSEN: Your Honor, I move to strike
18 this. This is not responsive. This witness is
19 giving speeches.
20 MR. DANDAR: Judge, he's-answering the
21 question. He asked him why. And when you ask
22 the witness why -­
23 THE COURT: I think we've been over this,
24 so let's see if we can get -­
25 MR. ROSEN: Okay.
2 Q. So now let's go to the next step.
3 Now, when you packed up your belongings in
4 Minneapolis, you went to -- was it Boulder Colorado?
5 A. Yes.
6 Q. And that's where Mr. Wollersheim lived?
7 A. Correct.
8 Q. That's where FACT Net was?
9 A. That's correct.
10 Q. That's where at the time Mr. Minton and Ms. Brooks
11 were directors of FACT Net, right?
12 A. Not necessarily, not to my knowledge.
13 Q. You didn't know that?
14 A. No.
15 Q. Did you know they had any connection with FACT
16 Net?
17 A. I thought that Mrs Brooks did -- Ms. Brooks did.
18 Q. How did you physically get from Minneapolis to
19 Colorado?
20 A. I drove.
21 Q. What did you drive, your car?
22 A. If you want to keep answering the questions, I
23 will just sit here.
24 THE COURT: He asked if you drove your car.
25 Can you answer that?

1 THE WITNESS: No, I did not drive my car.
2 THE COURT: All right. That's an answer.
4 THE COURT: Let's just move.on. Okay?
7 Q. What did you drive?
8 A. I drove a vehicle owned by FACT Net.
9 Q. Bought for you in Minneapolis, right?
10 A. No.
11 Q. Okay. It's a vehicle owned by FACT Net?
12 A. Correct.
13 Q. All right. So what was it, an SUV or something?
14 A. Yes.
15 Q. Where was the vehicle bought? FACT Net is in
16 Colorado. Where was the vehicle bought, Mr. Prince?
17 A. I'm not entirely sure what the name -- I don't
18 remember the name of the city where the vehicle was
19 purchased.
20 Q. Mr. Prince, do you remember-the state in which the
21 vehicle was purchased?
22 A. Sure.
23 Q. Where?
24 A. Minnesota.
25 Q. And did some representative of FACT Net go down to
1 a car dealer in Minnesota and buy this vehicle?
2 A. I have no knowledge of that.
3 Q. Mr. Prince, sir, you've already testified under
4 oath, FACT Net paid for it, you went to the dealer, you
5 picked out the car, you told them what options you wanted,
6 you picked it up and took it away. Now, am I wrong?
7 A. I don't know. If you have testimony of me saying
8 that, show it to me.
9 Q. No, sir. I'm asking you if that's wrong.
10 A. And I'm saying I don't know. If you have
11 testimony, show it to me.
12 MR. DANDAR: Objection, form. He should show
13 him the deposition that lie's trying to impeach
14 him with, or the testimony.
15 THE COURT: I don't think he's trying to
16 impeach him. I think he's trying to get some
17 information from him.
19 Q. Mr. Prince, am I correct that you went down to the
20 dealer in Minnesota and picked up the car?
21 A. No, you're not.
22 Q. Huh?
23 A. No, you're not correct.
24 Q. Who did?
25 A. Who went to the dealership to pick out the --

1 Q. Yeah.
2 A. I don't think anyone did. I don't know. As I
3 said, this is not my vehicle. I don't understand why you
4 have to put me through this.
5 Q. Mr. Prince, this car, was this a brand-new car?
6 A. It was a car that was on a -- to my knowledge, a
7 hail damage -- a car that had been in a hail storm, had
8 some damage on it, and it was purchased at a reduced price
9 for that reason.
10 Q. Was it purchased from a dealer?
11 A. Yes.
12 Q. Who went down to the dealer and picked out the
13 car, sir?
14 A. And, again, I will tell you, I don't know who went
15 down to the dealer and picked out the car, okay?
16 Q. Now, I presume, sir, that somehow that car got
17 you.
18 A. I went and picked it up.
19 Q. You picked it up at the dealer?
20 A. Yes.
21 Q. Gosh, okay. So you picked up the car from the
22 dealer and the car already had license plates on it?
23 A. I don't recall.
24 Q. Well, you wouldn't drive a car without license
25 plates; would you, Mr. Prince?

1 A. No, I wouldn't.
2 Q. Okay. So this is a car that you packed up your
3 belongings in and off you went to Colorado, right?
4 A. Okay, yes.
5 Q. Huh?
6 A. Yes.
7 Q. Okay. Now, at the time, you were dead broke
8 weren't you?
9 A. No.
10 Q. How much money did you have, Mr. Prince, at that
11 time?
12 A. I don't recall, but I wasn't broke.
13 Q. Well, okay. Did you have less than $500 to your
14 name?
15 A. No.
16 Q. You had more?
17 A. Correct.
18 Q. Okay. So when you got to Colorado, you took the
19 money that you had and you went out and you rented an
20 apartment, a place to live, right?
21 A. I did get an apartment there.
22 Q. You paid for it, right?
23 A. Correct.
24 Q. You had money in your pocket, right?
25 A. Correct.

1 Q. And that money was money that you had before ever
2 talking to Ms. Brooks and Mr. Minton; they didn't give you
3 that money for the apartment; did they
4 A. No.
5 Q. This was money that you had saved up between the
6 time that you had filed bankruptcy in 1997 and the time
7 that you went off to Colorado the next year, right? This
8 is money you saved.
9 THE WITNESS: You know, Your Honor, I'm
10 trying to be cooperative here. I'm trying to
11 answer these questions, but I just do not
12 understand why I'm going through this with,
13 okay, was it your money -­
14 THE COURT: Well, it's not really your
15 place to wonder about why. Just listen to his
16 question and answer the question, and then
17 we'll all get out of here a lit quicker. Okay?
18 THE WITNESS: Okay. But you understand,
19 he's asking me questions that I don't know -­
20 THE COURT: If you don't-know an answer,
21 you say you don't know. It's that simple.
22 THE WITNESS: Okay. I don't know.
23 THE COURT: It's that simple.
24 THE WITNESS: I don't know.
25 MR. ROSEN: I'm sorry. I forgot the

1 question. Can I ask the court reporter to read
2 it back?
3 THE COURT: I think the question was he
4 went out there with money that he'd earned
5 and/or saved between the 1997 bankruptcy and
6 when he got to Colorado, and he said he doesn't
7 know.
8 MR. ROSEN: Okay. Thank you.
10 Q. So you went to Boulder. Did you sign a lease for
11 an apartment?
12 I said, did you sign a lease for an apartment,
13 sir?
14 MR. DANDAR: He was answering the question,
15 Judge.
17 Q. Oh, I'm sorry. I thought he didn't hear me. I
18 was repeating it.
19 A. I don't recall signing a lease.
20 Q. Was the apartment leased in some other name?
21 A. You know, when you speak about the apartment, I
22 think that's probably what's causing the confusion here.
23 When I first moved to Colorado, a person owned
24 a house, and I rented the basement part of the house, and
25 that's where I stayed, and I had the use of, you know, the
1 kitchen and things like that.
2 Q. And that person's name was Lawrence Wollersheim?
3 A. No.
4 Q. Who was it?
5 A. It was a woman, and I do not recall her name.
6 Q. So you happened to find her by, what, an ad in the
7 paper or a real-estate broker?
8 A. No.
9 Q Huh?
10 A. I said no.
11 Q. How did you happen to find this opportunity to
12 rent this basement?
13 A. A person that worked at FACT Net informed me about
14 it.
15 Q. FACT Net. Okay. And you paid this person each
16 month for rent, right?
17 A. Correct.
18 Q. How much did you pay?
19 A. I don't recall.
20 Q. Give me an approximation. I won't hold you to an
21 exact amount.
22 A. I don't recall. That's my answer.
23 Q. You have no recollection at all as to --
24 MR. DANDAR: Asked and answered twice.
25 THE COURT: Overruled.

2 Q. You have no recollection at all, can't even give
3 me a range, an estimate, huh?
4 A. Correct.
5 Q. How long did you stay there?
6 A. Probably, I would say, maybe a couple months.
7 Q. And then where did you go? Did you rent your own
8 place, an apartment?
9 A. I rented my own place.
10 Q. Did you sign a lease?
11 A. Yes.
12 Q. How much was that rent?
13 A. $1,500 a month.
14 Q. Now, between the time you arrived in Colorado and
15 those few months you were living in a basement, were you
16 working?
17 A. Yes.
18 Q. What was your job?
19 A. I still had my businesses operating in Minneapolis
20 and other places and --
21 Q. Okay. So -­
22 MR. DANDAR: Objection. He's interrupting the
23 witness again.
24 THE COURT: I didn't think so, but don't
25 do that if that's what you're doing.
1 THE WITNESS: I wasn't done answering the
2 question.
3 THE COURT: Okay. Finish the answer,
4 then, if you would.
5 THE WITNESS: Well, I lost my train of
6 thought, so go ahead.
8 Q. Okay. You were starting to say that when you
9 moved to Colorado, you were still operating your
10 businesses. What businesses were you operating?
11 A. The one that I mentioned earlier, the Art Guy.
12 Q. So you were in Colorado and you were operating a
13 business in Minnesota, right?
14 A. Yes.
15 Q. And you got money from this?
16 A. Correct.
17 Q. So you had some employees running this business
18 for you and they sent you checks.
19 A. Correct.
20 Q. How much was it? .
21 A. How much was what?
22 Q. How much did you get from this business? Was it a
23 hundred dollars a month? Was it $5,000 a month? Give me
24 your best approximation as to how much business this was
25 generating while you were in Colorado.


1 A. Well, during the time that I was in Colorado,
2 which I think was probably a little less than one year, I
3 would say I got about $20,000 from that business.
4 Q. And who was the person that sent you those checks?
5 A. Employees.
6 Q. Can you tell me the names of the people in
7 Minnesota who were your employees who sent you those checks
8 being the proceeds of the profits of your business?
9 A. I don't remember.
10 MR. DANDAR: Relevance. Relevance, Judge.
12 Q. What, you don't remember?
13 A. That's what I said.
14 Q. How many employees did you have?
15 A. Probably three or four.
16 Q. Well, sir, if they were your employees and I
17 presume that-each year -- excuse me -- that you paid them
18 and that you withheld taxes and remitted it to the United
19 States government, right?
20 A. No.
21 Q. You didn't.
22 At the end of the year, you issued some sort of
23 statement as to how much money you had paid each of these
24 employees, right?
25 A. That wasn't the business arrangement.
1 Q. You didn't do that, right?
2 A. Did you understand what I just said? I said that
3 was not the business arrangement.
4 Q. Okay. It was not your business arrangement with
5 your employees in Minnesota. I understand.
6 Okay. Let's see. If you got $20,000 in that
7 year, that would appear on your tax returns, right?
8 Your United States Federal Income Tax Return,
9 does the 20 grand appear on those income tax returns?
10 A. I don't remember.
11 Q. You don't remember, okay.
12 Do you remember if you even filed tax returns
13 for the years '98 and '99?
14 A. No, I do not.
15 Q. You don't remember if you filed.
16 Okay. So we got on to this because you said
17 you were getting an income from your, quote, businesses.
18 So apart from the Art Guy business in
19 Minnesota, what other of your businesses were generating
20 income?
21 A. I had no other income-producing source.
22 Q. That was it? And just so I understand, how long
23 was the -- had you operated the Art Guy?
24 A. I think, as I've testified, about six months after
25 I filed the bankruptcy I started this other operation, and

1 it carried on until mid 1999.
2 Q. Until 1999. Okay.
3 Mr. Prince, do you recall being deposed on
4 August 19th, 1998 in Denver, Colorado?
5 A. I recall being deposed in Denver, yes.
6 Q. Okay. And do you recall you were -- at that
7 time you had moved to Colorado, August 19th, 1998?
8 A. That could have been.
9 Q. And you recall I asked you about your prior
10 business -- your art business in Minneapolis. Do you
11 recall being asked questions about that?
12 A. Not particularly.
13 Q. Okay. Do you recall being asked the following
14 questions and giving the following answers on August 19th,
15 1998 -­
16 MR. DANDAR: Objection. I would like to have
17 a copy of this deposition.
18 MR. ROSEN: Sure.
19 MR. DANDAR: I would like the witness to
20 have a copy of the deposition:
21 MR. ROSEN: No, I will read it. Question,
22 "So you intend -­
23 MR. DANDAR: Do I get a copy?
24 MR. ROSEN: I don't have another one. You
25 can look with me and make sure I read it right.
2 Q. Question, "So you intend to have that moved out
3 and resume your occupation as an art dealer?"
4 Answer, "I haven't made a decision about that
5 one way or the other as yet."
6 Question, "Okay. So I take it at the moment
7 you are presently unemployed."
8 Answer, "Yes."
9 MR. DANDAR: Objection, Judge. That's totally
10 different subject matter. That's about
11 employment, not about a business.
12 THE.COURT: Okay.
14 Q. Do you remember giving those answers?
15 A. No, I do not.
16 Q. Okay. Other than the business of this $20,000
17 that you received, you say, from your employees in
18 Minneapolis or Minnesota, did you have any other job,
19 source of income, business, since moving to Colorado in
20 1998?
21 A. I received some money from FACT Net.
22 Q. To be a witness for them in the copyright case in
23 Denver, right?
24 A. No.
25 Q. What did you receive it for?
A. Because I did volunteer work for FACT Net similar, again, with what I did in the Lisa McPherson Trust, which is helping people that have been robbed and pillaged by your client Scientology, help them get their lives back on track.
Q. Got you. So you were a volunteer, but not a true volunteer, because you were getting paid for this, right?
A. Occasionally I would receive some money, yes.
Q. Okay. And other than that, you have had no source of income of any kind since '98, have you, other than being a witness or a consultant or whatever you want to call it against Scientology, right?
A. I don't understand the compound question. You've asked me many questions in that question.
Q. Have you had any other source of income since 1998 other than what you've just told us about?
A. Yes, I had a job.
Q. What?
A. I had a job at the Lisa McPherson Trust.
Q. You already told us about that. You were counseling people, et cetera. Other than what you've already told us, did you have any job, any employment, any source of income, other than what you've already testified to since 1998, sir?
A. Yes. I worked as a consultant in the Wollersheim
1 case.
2 Q. Right, a consultant in another Scientology case.
3 A. Can I talk? I mean, if you let me finish saying
4 what I'm saying, then you will save the Court and yourself
5 a lot of time here.
6 MR. DANDAR: Objection, interruption again.
7 THE WITNESS: I worked as a consultant to
8 Mr. Dandar -- not Mr. Dandar -- Mr. Dan
9 Leipold.
10 I started working with him in, I believe
11 it was, 1998, and I worked with him
12 continuously until this -- I think maybe last
13 month or the month before.
15 Q. How much did he pay you to be a consultant?
16 A. Total?
17 Q. Yeah. Add it all up
18 A. I would say approximately $30,000.
19 Q. Mr. Prince, do you recall being deposed in Denver
20 in August of 1998 and testifying that when you went there
21 you went right to -- excuse me -- that before going there
22 to Denver you would travel to Mr. Leipold's office in
23 California to provide an affidavit in the FACT Net case?
24 A. No, I do not recall that.
25 Q. Let me strike that. You do not recall.

1 Before moving to Colorado, did you go to
2 Mr. Leipold's office in California to assist him and
3 provide an affidavit in the FACT Net litigation?
4 A. It's possible, yes.
5 Q. You don't remember if you were in California?
6 You're telling me it's possible, sir?
7 MR. DANDAR: Objection, yelling at the witness.
8 THE COURT: Oh, sit down, Mr. Dandar.
9 MR. ROSEN: Are you saying you don't
10 remember?
11 THE WITNESS: I don't remember it as the
12 way you've characterized it. This is why I'm
13 struggling with the questions, because you're
14 mischaracterizing it.
16 Q. Tell me how you remember it.
17 A. How do I remember it?
18 Q. How do you remember being in Mr. Leipold's office
19 in Santa Ana, California?
20 A. I don't remember whether or not I met with
21 Mr. Leipold before or after the 24 August 1998 date that
22 you're speaking about here. I don't recall whether it was
23 before or after.
24 Q. I'm not asking you any date. No date, Mr. Prince.
25 The question- has no date.

1 Do you recall going to Mr. Leipold's office
2 before moving to Denver, his office in Santa Ana,
3 California, and working with him and preparing an affidavit
4 to submit against Scientology in the FACT Net case?
5 Does that have any recollection for you at all,
6 sir?
7 A. You know, I don't know if this is after I moved to
8 Denver or before, but that did happen. I did go and
9 provide and work with Mr. Leipold and provide him an
10 affidavit. That did happen.
11 Q. And, sir, at that time, you told Mr. Leipold, as
12 you were sitting in his office preparing an affidavit, that
13 you were broke and you needed, quote, some walking-around
14 money, closed quote, right?
15 A. I have no knowledge of what you're speaking about
16 of me exclaiming or having a conversation, but, you know,
17 it stands to reason that if I'm working, if I am operating
18 as an independent contractor, if I'm operating as a
19 consultant, one would expect to be paid, so I'm looking for
20 the sinister element here, Mr. Rosen; or at least, you
21 know, I'm trying to find out what you're asking me.
22 THE COURT: I'll tell you what, Mr. Prince,
23 just look for the honest element, okay? Just
24 listen to the question and just answer it and
25 don't worry about any sinister element, okay?

1 Just give an answer, okay?
2 THE WITNESS: I'm trying.
3 THE COURT: I really appreciate that.
4 THE WITNESS: I'm doing that. Each time I
5 speak, Your Honor, I'm giving an honest answer.
6 THE COURT: That's very commendable
7 Mr. Prince. Try again.
8 THE WITNESS: Thank you.
10 Q. Did you tell Mr. Leipold that you were short on
11 cash and that you needed, quote, walking-around money?
12 A. I recall saying something about or mentioning
13 something about needing some walking-around money during
14 some point in time.
15 I don't know whether or not it was when I was
16 working on that particular affidavit or preparing for a
17 deposition or getting ready to go to a hearing or a trial.
18 At some point, that conversation did happen.
19 Q. Can you tell me what year that happened?
20 A. To the best of my recollection, it happened in
21 1998. It could have been 1999. I'm not sure.
22 Q. You testified to it in the August 19th, 1998
23 deposition. Does that help refresh your recollection?
24 A. If you say I testified to it, show it to me. Let
25 me see what you're talking about.


1 Q. I'm going to do this. I'll make an exception to
2 my own rule about doing this. Let me show you Page 123 of
3 the August 19th, 1998 deposition.
4 MR. DANDAR: What page are you showing him?
5 MR. ROSEN: 123 I think I just said,
6 Mr. Dandar.
7 MR. DANDAR: Did you? Okay.
9 Q. 123, Mr. Prince.
10 A. Yes.
11 Q. Do you see it?
12 A. Yes.
13 Q. "Walking-around money," does that help refresh
14 your memory, sir?
15 A. I see -- I was never confused about walking-around
16 money. It says it right here, so...
17 Q. Does that refresh your memory as to when it was
18 that you had told Mr. Leipold, that it was before August
19 19th, 1998 that you were sitting there in his office and
20 you told him I needed some walking-around money?
21 A. No, this doesn't refresh my memory about that at
22 all.
23 Q. Can we agree, Mr. Prince, that it must have
24 happened before August 19th, 1998 if you're testifying to
25 it on that date?



1 A. Correct.
2 Q. Okay. And he gave you $500, right?
3 A. I'm not sure. I don't remember how much he gave
4 me.
5 Q. You have no idea how much he gave you?
6 A. I said I don't remember.
7 Q. Okay. And, of course, you paid him back when you
8 got the 20 grand that you were sent in 1999 -- in '98 and
9 '99 -- from your employees in Minneapolis, right?
10 A. I don't think that's a correct statement of what
11 happened.
12 Q. So you never paid him back, right?
13 A. I think I did pay him back.
14 Q. Okay.
15 A. I think I paid him back through -- that was taken
16 off from services provided to him from myself.
17 Q. Mr. Prince, you testified yesterday -- I'll
18 withdraw that.
19 Mr. Prince, isn't it true that from 1998 right
20 up until the last payment from Ms. Brooks in April of 2002
21 you have been paid and your sole source of income hasf
22 either been from Mr. Minton, Ms. Brooks, LMT or the
23 attorneys like Mr. Dandar in cases against Scientology;
24 isn't that right?
25 A. You know, I guess I really don't understand the



Q. What part don't you understand, Mr. Prince?
A. I will explain it to you. The part that I don't understand is I've sat here and I've testified -- we've gone through specifically every job, every consulting job, how much money that I had.
So, now, how this equates to, "Oh, Mr. Minton and Mrs. Brooks and that's all you did," you know, that's the part I don't understand, Mr. Rosen. We've talked about it in detail, everything I've done.
Q. That's fine.
Okay. I'll tell you what, Mr. Prince, we started this by my asking you your occupation. Would it be correct to say that since 1998 your occupation has been providing services in connection with lawsuits against some Scientology church?
A. No, that would be incorrect.
Q. Uh-huh. (Affirmative.)
So during the time that you have been providing
services in connection with the Lisa-McPherson wrongful death case, have you received money for services -- I'm not' talking about somebody buys you a drink -- have you received money from anybody other than Dandar, Minton, Brooks and LMT?
A. Since when again now?


1 Q. Since you started providing services in the
2 wrongful death case.
3 Or have they been your sole source of funds
4 from employment, if you will?
5 A. My employment has been the source of my income. I
6 mean, you know, I go to work, I do a job, and I get paid.
7 That's been the source of my income.
8 Q. My question was: Have you received any money, any
9 income, from any other source --
10 A. Yes.
11 Q. -- during this period of time that I've
12 identified?
13 A. Yes.
14 Q. Who?
15 A. As I testified to earlier, Mr. Leipold.
16 Q. He paid you since you started becoming a
17 consultant here in the wrongful death case?
18 A. Here isn't the wrongful death case, is it?
19 Q. Do you want to answer my question, please, sir?
20 MR. DANDAR: I object to the form. It's not a
21 proper form. Is he talking about this case or
22 the wrongful death case?
23 THE COURT: Overruled. Try and restate
24 the question, if you would, Mr. Rosen.

1 Q. Mr. Leipold has engaged you and paid you for
2 services since the point in time that you were engaged to
3 provide services in connection with the wrongful death
4 case?
5 A. Yes.
6 Q. How much did he pay you?
7 A. I certainly am reticent to speak about that unless
8 I'm instructed to by the Court because unless this has some
9 relevance, I would rather not discuss my personal finances
10 in an open forum in the courtroom.
11 MR. DANDAR: Objection, relevance and personal
12 privilege.
13 THE COURT: Overruled. Answer the
14 question.
15 THE WITNESS: As I testified, I would say
16 about $30,000.
18 Q. Since 1998, $30,000?
19 A. Yes.
20 Q. Okay. And that was all in connection with
21 services relating to the Wollersheim litigation against the
22 church?
23 A. Correct.
24 Q. Any other sources of income you've had since you
25 began providing services in connection with the Lisa

1 McPherson wrongful death case?
2 A. Not that I recall, not that I haven't already
3 spoken about.
4 Q. Now, Mr. Dandar asked you yesterday -­
5 A. Oh, I'm sorry, yes. Mr. Dandar has also paid me.
6 Q. Oh, he has? When was that?
7 A. It started in, I think, maybe June, July, August
8 of 1999. And the last time I was paid by Mr. Dandar I
9 think was maybe six, seven weeks ago.
10 Q. Okay. Let me turn to that for a moment.
11 You testified yesterday that in April of this
12 year -- up until April of this year, Ms. Brooks had been
13 paying you after LMT closed.
14 A. Correct.
15 Q. And in April of this year, she stopped paying you,
16 right?
17 A. Correct, correct.
18 Q. So since April of this year, for the last five
19 months, have you had a job?
20 A. Yes.
21 Q. What?
22 A. Well, I'm self-employed.
23 Q. Well, tell me your business now.
24 A. Well, it's the same business. As I said, as
25 recent as six or seven weeks ago, I was paid by Mr. Dandar

1 for services rendered in the wrongful death case.
2 Q. All right. So wait a minute. Since Ms. Brooks
3 stopped paying you in April of this year, for the last five
4 months you've continued to be employed by Mr. Dandar.
5 A. That's not what I testified to. I said that I
6 have been paid by him. I never made the statement about
7 continuous employment. I said I've rendered services and
8 I've been paid for those services.
9 Q. Mr. Prince, when Ms. Brooks stopped paying you in
10 April -- if I have to do this one step at a time, I will.
11 THE WITNESS: I just have to ask the Court,
12 Your Honor, am I doing this wrong? I really
13 think I'm sitting here answering the question.
14 THE COURT: Nobody said anything. Just
15 listen to the questions and answer them.
16 THE WITNESS: Okay. Because, you know,
17 the reason I asked am I doing this wrong -­
18 THE COURT: Mr. Prince, just listen to the
19 question and answer it, okay? We don't have to
20 have a conversation about this at this point.
21 All right, Mr. Rosen.
23 Q. Mr. Prince, the last time you were paid by
24 Ms. Brooks was in the beginning of April, right?
25 A. Correct.

1 Q. After that month of April, May, did you have a
2 job?
3 A. I did, and I will answer the question. I have
4 worked -- I have rendered services in the wrongful death
5 case, and I have been paid for that.
6 Q. In the month of April and May of this year you
7 rendered services to Mr. Dandar in the wrongful death case?
8 A. I wouldn't say April and May.
9 Q. Mr. Prince, I asked you about the months of April
10 and May.
11 A. Okay.
12 Q. I'm going to say it again.
13 In the months of April and May after Ms. Brooks
14 stopped paying you -- April and May of this year -- did you
15 have any work?
16 A. No. I was unemployed.
17 Q. You were looking for a job?
18 A. I was unemployed.
19 Q. You were looking for a job?
20 A. No.
21 Q. No. Okay. And in the month -- so you received no
22 money in those months, right?
23 A. Correct.
24 Q. And how about the month of June; were you employed
25 that month?

1 A. No.
2 Q. Okay. And were you looking for a job?
3 A. I filed for unemployment.
4 Q. Unemployment from your last job with LMT, right?
5 A. You know, I'm not sure if that's how it works.
6 From anyplace. I mean, I filed for unemployment. I went
7 down to unemployment, I told them the last place I worked,
8 I had paid x amount of dollars to make me eligible to
9 receive unemployment, so, yes, that's, you know...
10 Q. Okay. So if I'm understanding you, in June of
11 this year, you went down to some local unemployment office
12 in Pinellas County and applied for unemployment?
13 A. That's incorrect.
14 Q. Did you do it by phone or by mail?
15 A. No. I don't do it by either of those ways.
16 Q. Tell me how you applied for unemployment benefits
17 in Pinellas County.
18 A. Over the internet.
19 Q. Huh?
20 A. Over the internet.
21 Q. Okay. So you went on the net and they have some
22 sort of a form you complete, right?
23 A. They have a web page. They give you instructions.
24 Q. Did you submit a request for unemployment payment
25 over the internet?

1 A. Correct.
2 Q. Okay. And in that form -- is there a form on the
3 Internet that you have to fill out on the web page?
4 A. Yes, there is.
5 Q. And does the form ask, for example, who was your
6 last employer?
7 A. Correct. Yes, it does.
8 Q. And what did you write?
9 A. The Lisa McPherson Trust.
10 Q. Okay. Now, when did you make that application?
11 A. I think we were just talking about June here;
12 weren't we?
13 Q. I'm asking you. When did you do it?
14 A. I guess I will answer the same, June.
15 Q. Okay. And did you receive unemployment benefits?
16 A. Excuse me, Mr. Rosen.
17 THE WITNESS-: Your Honor, my mouth is
18 getting really dry. I need some water.
19 THE COURT: Okay.
20 THE WITNESS: I'm getting uncomfortable
21 here.
22 THE COURT: We'll get you some water.
23 Don't worry about it.
24 THE WITNESS: Thank you.


1 Q. Got the question, Mr. Prince?
2 A. I'm sorry. Would you repeat the question,
3 Mr. Rosen.
4 Q. Did you receive unemployment benefits?
5 A. Yes, I did.
6 Q. When?
7 A. June, part of July, possibly.
8 Q. What do you mean possibly, sir? Do you remember?
9 I'm only asking about last month.
10 A. You know, I answered the question. You know, if
11 the answer is unacceptable, I'm sorry. But, you know, the
12 answer was June, possibly part of July.
13 Q. Uh-huh. (Affirmative.)
14 And you received these benefits once a month?
15 Once a week? How often?
16 A. Every other week.
17 Q. And does the check come in the mail?
18 A. Yes.
19 Q. When was the last time you received such a check?
20 A. To the best of my recollection, maybe the first or
21 second week of July.
22 Q. So how many checks did you get all together?
23 A. Maybe three.
24 Q. Three.
25 And you cashed those checks, right?

1 A. Yes.
2 Q. All of them, right?
3 A. Yes.
4 Q. Did you tell the Florida unemployment office that
5 you had been hired by Mr. Dandar and paid by him in June?
6 Did you tell them that, Mr. Prince?
7 A. I don't know that June is when that happened.
8 Q. Well, okay. Let's back up for a second.
9 A. But I will say this -- I will say this. It will
10 save us both some time.
11 Q. No, I don't want you to save me time. I want you
12 to answer my questions.
13 A. Okay. From the time when Mr. Dandar paid me, I
14 stopped receiving unemployment.
15 Q. Okay. Well, let's go back. You say you don't
16 know it's June when it happened. When did Mr. Dandar
17 re-hire you? When was it?
18 A. I'm not sure. I'm not sure.
19 Q. Sir, yesterday you testified here that you at one
20 previous time had been employed by Mr. Dandar back, what,
21 in 1998 or 1999?
22 A. I think I said 1999.
23 Q. '99. And then you stopped being employed by
24 Mr. Dandar and you were paid by others, LMT or Ms. Brooks,
25 whoever. I don't care.

1 So now we're in the year 2002 and you're now
2 resuming being paid by Mr. Dandar, right?
3 A. No, that's incorrect.
4 Q. Well, did there come a time after April of 2002
5 when you were employed again by Mr. Dandar?
6 A. There came a time since then that I provided
7 service to him and I was paid one time since then.
8 Q. Well, what was incorrect? I asked you if you were
9 employed by Mr. Dandar again. You were re-employed, right?
10 A. And, again, I will say, I did a specific thing. I
11 worked for him doing -- providing a specific service. That
12 service was rendered, and it was over. It's not a
13 continuing employment. It's not a routine, you know, where
14 every day I show up here. That's not the way it works.
15 Q. What was the date that you were engaged by
16 Mr. Dandar, whether you call it employment or continuous or
17 otherwise. When?
18 A. You know, I don't recall specifically, but I do
19 know that it is a matter of the record in a court because I
20 testified to it at the time it happened. As I sit here
21 today, I cannot recall the dates.
22 MR. ROSEN: Your Honor, can I move to
23 strike this? I asked a very simple question,
24 when. The answer is either a date or I don't
25 know.

1 THE COURT: I think he said he didn't
2 know.
4 Q. You said you don't remember the specific date.
5 I'm not asking you for specific dates, sir. I'm asking you
6 for your best approximation of events that occurred within
7 the last couple months.
8 So tell me your best approximation of when it
9 was -- your best recollection of when it was -- that you
10 were engaged by Mr. Dandar again?
11 A. And, again, as I stated earlier, I do believe that
12 it was six or seven weeks ago.
13 Q. In the month of July?
14 A. You know, I don't know how else to answer the
15 question. You said when, and I said I think it was six or
16 seven weeks ago.
17 Q. Was it in the month of June or the month of July?
18 What's your best recollection?
19 A. It could be either. I don't remember.
20 Q. You don't remember.
21 Okay. And would you describe the services that
22 Mr. Dandar engaged you to perform.
23 A. That's attorney/client privilege.
24 Q. You were a client of Mr. Dandar's?
25 A. No, but my relationship with him is work product.

1 Q. You're an attorney too?
2 THE COURT: Answer the question, Mr. Prince.
5 Q. What services were you engaged to perform?
6 A. Of consultant.
7 Q. I want to be more specific. What did you do for
8 Mr. Dandar?
9 A. Research.
10 Q. Legal research?
11 A. Research that led to -- I don't know -- legal
12 motions or whatever.
13 Q. What kind of research? Are you talking about
14 going to the library? Are you talking about reading law
15 books? I want you to be more specific, Mr. Prince. What
16 kind of research did Mr. Dandar hire you to do?
17 A. Research concerning the subject of Scientology.
18 Q. He just said, "I want you to go out and do some
19 research on the subject of Scientology," those were your
20 marching orders, huh?
21 MR. DANDAR: Objection. Now, if he's getting
22 into specifics, that is work product.
23 THE COURT: Okay. Yeah, I agree.
24 MR. ROSEN: I'm sorry. Did Your Honor say
25 you agree?

1 THE COURT: Yeah, uh-huh. (Affirmative.)
3 Q. Mr. Prince, didn't you testify already, forget
4 this work product claim, didn't you testify already before
5 Judge Schaeffer as to what Mr. Dandar hired you to do?
6 MR. DANDAR: Objection. Now he's instructing
7 the witness to forget the work product claim.
8 That's improper.
9 THE COURT: Well, he may have waived it if
10 he testified about it before, so that's what
11 we're exploring right now.
12 MR. DANDAR: I'm just objecting to the
13 phrase that Mr. Prince could forget the work
14 product claim. Just ask the questions.
16 Q. You testified before Judge Schaeffer as to what
17 Mr. Dandar hired you to do?
18 A. You know, I testified in front of Judge
19 Schaeffer --
20 THE COURT: Do you recall testifying in front
21 of Judge Schaeffer as to what you were hired to
22 do?
23 THE WITNESS: Not specifically; no, I do
24 not.

1 Q. Let me see if I can refresh your recollection.
2 Do you recall testifying that Mr. Dandar hired
3 you to come to his office to work with him to assemble
4 documents in preparation for or to help him in the
5 disqualification hearing then in progress before Judge
6 Schaeffer?
7 A. No, I do not recall.
8 Q. None of that sounds at all familiar to you?
9 A. No, it does not.
10 Q. Okay. Now, did you have some sort of agreement
11 with Mr. Dandar as to compensation for whatever it is you
12 did?
13 A. I have a business relationship with Mr. Dandar
14 that has existed since 1999 that -­
15 Q. You think I'm asking you about '99? Are you
16 confused? I'm asking you about 2002.
17 A. And my answer is I've had a continuing business
18 relationship with Mr. Dandar that was discussed in 1999
19 where I am paid an hourly rate for my services.
20 Q. Okay. And what is that hourly rate?
21 A. $150 an hour.
22 Q. Mr. Dandar pays you $150 an hour?
23 A. And everyone else that hires me for that does the
24 same, yes.
25 Q. Okay. And so you keep track of the hours that you

1 spend and then you give Mr. Dandar a bill, right?
2 A. Correct.
3 Q. Can I see the bills you've given Mr. Dandar?
4 MR. DANDAR: Objection. No request to produce
5 has been made.
7 Q. Do they exist, Mr. Prince? Do those bills exist?
8 A. I bill for my work, yes.
9 Q. Do you have bills -- I'm talking about a piece of
10 paper that you could show us. Do you have bills that
11 you've submitted to Mr. Dandar for your services in the
12 last few months?
13 A. That I can give you today? No.
14 Q. You can't because you never generated the bills,
15 right?
16 A. No.
17 Q. Am I right?
18 A. No, you're not right.
19 Q. Have you -- well, have you given Mr. Dandar a bill
20 in tangible form?
21 A. When? When are you asking me? I have, yes. I
22 mean, he's paid me. So when are we talking about now?
23 Q. Where do I look if I want to see a copy of the
24 bill that you gave Mr. Dandar showing the number of hours
25 that you worked in connection with this engagement in 2002?

1 Where would I look for that?
2 A. That I just did -- that I just testified to that
3 he gave me a check five or six weeks ago?
5 THE WITNESS: I guess you would have to
6 look at me for that. I'm the person. And the
7 answer to the question is I have not given him
8 a bill for -­
9 THE COURT: Let's move on.
10 THE WITNESS: -- for what has happened
11 because it's not done.
12 MR. ROSEN: Fine, okay. It's not done.
13 You're still working for him?
14 THE WITNESS: I still on occasion
15 do -- when he calls me and he asks me to do
16 things, I work and I note it, you know, for
17 billing purposes, and then I will send him a
18 bill when it's done.
20 Q. Okay. So I guess if you're being paid by the
21 hour, you've got some kind of records of how many hours
22 you've worked, right?
23 A. Correct.
24 Q. Where are they?
25 A. I keep it at home. I keep a log.

1 Q. Describe it to me. What does it look like?
2 A. It looks like -- in its current form, it looks
3 like a yellow pad, you know, one of those yellow legal pads
4 with just hours noted, what the work was, how many hours it
5 took.
6 Q. And you would be able to produce that over the
7 lunch break because you live here in Clearwater, right?
8 A. No, I would not produce it.
9 Q. Why not?
10 A. Because that has nothing to do with anything.
11 Okay. I'm sorry, Mr. Rosen. Let me answer
12 that question. The reason why I don't produce financial
13 records to you is because your client takes them and
14 parades them all over the internet and up and down the
15 street and makes a mockery of that, and that's why I don't
16 do it.
17 MR. ROSEN: Your Honor, I move to strike
18 this.
19 THE COURT: All right. Why don't we get
20 back to asking questions and getting answers,
21 okay?
23 Q. Okay. Now, did Mr. Dandar give you a retainer for
24 the services you were going to perform?
25 A. Recently?

1 Q. Unless I tell you otherwise, my questions are in
2 the year 2002. How is that? Do we understand each other?
3 A. Yes.
4 Q. I will repeat my question.
5 Did Mr. Dandar give you a retainer payment?
6 A. Yes.
7 Q. How much was it?
8 A. $4,000.
9 Q. And this was not a payment of a bill. This was a
10 retainer for services that you were to perform, right?
11 A. Correct.
12 Q. Okay. And these were services assisting
13 Mr. Dandar in research about Scientology, correct?
14 A. Correct.
15 Q. Without disclosing, sir, the particulars of
16 anything else, would you tell us whether your activities
17 for Mr. Dandar in this engagement, have they included
18 anything other than, quote, research?
19 A. Yes.
20 Q. What else did they include ?-
21 A. Well, I wrote an affidavit or two.
22 THE COURT: I'm sorry. What was that?
23 THE WITNESS: I authored an affidavit or
24 two.

1 Q. Okay. So that was part of what you were paid for,
2 right?
3 A. Please let me finish because you wanted to know
4 activities. I have also sat in the courtroom with him as a
5 consultant on behalf of the estate.
6 Q. Which courtroom?
7 A. Judge Schaeffer's courtroom.
8 Q. So, let's see, research and the time you spent in
9 that affidavit that we went over yesterday or Mr. Dandar
10 went over with you yesterday, the time you spent putting
11 that together -­
12 A. Yes.
13 Q. -- and sitting in Judge Schaeffer's courtroom. I
14 assume you mean sitting over there, not in the witness
15 chair, right?
16 A. No, I mean sitting where Mr. Pope is sitting.
17 Q. Okay. This was before or after you testified
18 before Judge Schaeffer?
19 A. After.
20 Q. So you spent how many days on the stand before
21 Judge Schaeffer?
22 A. I don't recall.
23 Q. You don't remember? Well, was it more than one?
24 A. Yes.
25 Q. Was it four or five?

1 A. It could have been.
2 Q. Could have been.
3 And part of your retainer and the log that you
4 keep on the yellow pad in terms of the number of hours that
5 you spend includes the time you were testifying before
6 Judge Schaeffer, whatever it is.
7 A. Correct.
8 Q. Okay. And, in fact, in relation to when -- strike
9 that, in relation.
10 I want to ask you a question about sequence.
11 Mr. Dandar contacted you and engaged you to do this work,
12 right, that you've described. In the year 2002 --
13 A. You know, in some form of that, yes, that's kind
14 of the way that came about. He contacted me and asked me
15 that he needed specific work to be done.
16 Q. Okay. We know that one event in the year 2002 is
17 Mr. Dandar contacted you to do this work that you
18 described. And we know a second event is that he gave you
19 a check for a retainer.
20 Can you tell me, did they come at about the
21 same time? Were they a month apart? Did the check come
22 first? Whatever.
23 A. You know, I don't recall the sequence. I'm sorry.
24 I don't recall.
25 Q. Well, when Mr. Dandar engaged you, did you meet

1 with him in his office?
2 A. Yes.
3 Q. And you've got a notation as to what date that is
4 on your yellow pad, right?
5 A. I may.
6 Q. And it was at his office, then, that he gave you a
7 check?
8 A. Yes.
9 Q. Let me show you what's been marked as Exhibit 191.
10 THE COURT: Just a second, Mr. Rosen. We're
11 going to take a short break here. We've been
12 going for an hour and a half. I think it's
13 time to take a break.
14 All right. We'll take five minutes.
15 THE BAILIFF: Court stands in recess until
16 10:30 by the courtroom clock.
17 MR. ROSEN: 10:35?
18 THE BAILIFF: 10:35.
19 (Thereupon, a brief recess was held.)
20 MR. ROSEN: May I approach, Your Honor?
22 Q. I show you what's been marked as Exhibit 191,
23 Mr. Prince. Is that the retainer check -- not the first
24 one on the page, the one that's attached to it. Is that
25 the retainer check?

1 A. Yes, it is.
2 Q. Yeah. It says June 28th, right? Does that help
3 refresh your recollection?
4 A. Yes.
5 Q. Do you recall, Mr. Prince, if that happened just
6 perhaps by coincidence to be after your first day of
7 testimony before Judge Schaeffer on the stand and before
8 your second day?
9 A. No, I do not have that recollection.
10 MR. ROSEN: Your Honor, Exhibit 192.
12 Q. This is a list we prepared from the transcripts
13 before Judge Schaeffer. I will represent to you it shows
14 on the transcripts the dates that you testified. Does that
15 refresh your recollection, sir?
16 A. Somewhat, yes.
17 Q. Okay. So is it a coincidence that you got paid
18 this check for four grand by Mr. Dandar after your first
19 day of testimony and before your second day of testimony
20 before Judge Schaeffer?
21 A. This -­
22 Q. Yes or no? Does it refresh your testimony -- I
23 mean your recollection?
24 A. I'm sorry. I guess I just don't understand the
25 question. This check says June 28th. This list you just

1 handed me says June 18th is the first time I testified.
2 Q. Let me repeat the question.
3 Does the check refresh your recollection that
4 you received payment from Mr. Dandar after you testified
5 the first day before Judge Schaeffer and before you resumed
6 your testimony before her on the second day?
7 A. Yes. I was paid between the first day and the
8 second day.
9 Q. And does this refresh your recollection as to the
10 date Mr. Prince retained you for the research, preparing
11 the affidavit, testifying before Judge Schaeffer and then
12 sitting with him after your testimony to assist him in that
13 hearing?
14 Does this refresh your recollection of when
15 Mr. Dandar retained you?
16 A. I'm sorry. I just don't understand what you're
17 saying. I just don't understand it.
18 Q. Looking at these documents I put in front of you,
19 I will ask you again. When was it that Mr. Dandar retained
20 you to do all of these services you described?
21 A. From the records here, it looks like it happened
22 from June until the present.
23 Q. When did Mr. Dandar, in the year 2002, talk to
24 you, pick up the phone, whatever, contact you and say,
25 Jesse -- in words or substance -- "Jesse, I need to retain



1 you"?
2 A. That happened shortly after I met with him after
3 Mr. Minton tried to, you know, get me to go along with
4 blackmail and coercion, and then I testified to it
5 yesterday when I met with Mr. Dandar.
6 Q. I think me question is when did he do that. That
7 usually is answered by a date, an approximate date?
8 A. The approximate date I think is on that affidavit
9 that I gave you.
10 THE COURT: Just can you tell me the date.
11 THE WITNESS: No, I can't tell you the
12 date.
14 Q. Were you retained by Mr. Dandar before the month
15 of June to provide these services that you've described?
16 A. Correct.
17 Q. Okay. But he hadn't gotten around to giving you a
18 check until the 28th of June after you testified the first
19 day, right?
20 A. You know, I wouldn't characterize it in that way.
21 Q. I will withdraw the question.
22 A. Thank you.
23 Q. I will withdraw the question.
24 Now, you testified before Judge Schaeffer you
25 were subject to a sequestration order, right? You couldn't

go in the courtroom until after you testified, right?
A. Correct.
Q. And you had testified as a fact witness as to conversations you had with Mr. Minton or Ms. Brooks or whatever, right?
A. That's incorrect. I testified as a fact witness and an expert witness.
Q. Mr. Prince, did Mr. Dandar even attempt to qualify you in the hearing before Judge Schaeffer as a, quote, expert witness?
A. It is my understanding that she's already qualified me as an expert witness and she knows that I work in that capacity in this case.
Q. Sir, you were on the witness stand. Did you hear anybody say, in words or substance, "We offer Mr. Prince as an expert witness"?
A. Yes.
Q. Who?
A. Mr. Dandar.
Q. In the hearing in June before Judge Schaeffer, huh?
A. To the best of my recollection, yes, Mr. Rosen.
Q. Okay. Well, then, can you tell me why you were sequestered in that hearing, although the other experts were not? Why were you sequestered?

1 A. What other experts are we talking about?
2 Q. Can you tell me why you were sequestered?
3 A. Yes, because not only was I an expert witness, but
4 I was a fact witness as well.
5 Q. Okay. And you're also testifying here as a what?
6 What are you here as? Fact witness? Expert witness?
7 What?
8 A. Both.
9 Q. Both, okay. Did you have a conversation with
10 anybody during the break?
11 A. This break right here that we just took five
12 minutes ago?
13 Q. Fifteen minutes ago. Did you have a conversation
14 with anyone?
15 A. Yes.
16 Q. Who?
17 A. Mr. Dandar.
18 Q. Did you have a discussion on the subject that
19 we're talking about in terms of getting paid to be an
20 expert?
21 A. No.
22 Q. What did you say to Mr. Dandar or what did he say
23 to you?
24 MR. DANDAR: Objection. He's here as a fact
25 witness and as my expert witness. I would
1 object to the conversations.
2 I think he can ask the general question,
3 if I talked to him about his testimony or what
4 he might say; but if it's not that, then he
5 should not be allowed to ask the question.
6 MR. ROSEN: There is no privilege here.
7 There's no work product.
8 And, besides, this is a blatant fraud, and
9 I will say it on this record. This witness is
10 not an expert witness. He never was an expert
11 witness in this proceeding.
12 He was excluded by you on sequestration on
13 consent of Mr. Lirot as a fact witness.
14 And now as soon as I establish before the
15 break that he was paid for his testimony, both
16 the affidavit and the testimony before Judge
17 Schaeffer, which is illegal under Florida
18 law -- and we're going to give you some cases
19 on this -- all of the sudden he's an expert
20 when the break resumes. Your Honor, this is
21 blatant.
22 MR. DANDAR: Judge, Judge Schaeffer
23 recognized Mr. Prince as an expert witness.
24 THE COURT: We're not talking about Judge
25 Schaeffer. We're talking about right in this

1 courtroom today. He wasn't qualified as an
2 expert, didn't testify as an expert.
3 MR. DANDAR: Not yet. You told me on the
4 subject matters of Scientology practices you
5 said it's inadmissable and you can proffer it.
6 That's what I'm going to be proffering, his
7 expertise on Scientology practices.
8 MR. ROSEN: You never asked him his
9 questions for his qualifications. Forget his
10 testimony. You never even tried to qualify him
11 as an expert.
12 MR. DANDAR: Because the Judge said it's
13 going to be a proffer only, so I didn't waste
14 the Court's time.
15 MR. ROSEN: But you asked him the
16 substantive question about Scientology
17 practices.
18 THE COURT: All right. Where are we?
19 MR. ROSEN: I would like to know the
20 conversation that Mr. Prince and Mr. Dandar had
21 during the recess a few moments ago.
22 THE COURT: Okay. All right. Answer the
23 question.
24 THE WITNESS: I told him his secretary
25 that's here was talking or wanted me to come

1 over to speak to me.
2 And I told her, "I don't want to talk to
3 you. I can't talk to you."
4 And I mentioned that to Mr. Dandar in the
5 hallway because the Judge specifically told me
6 not to have conversations with people while I'm
7 testifying up here until I'm finished.
8 So I just simply told him that it happened
9 and I don't want to talk to anybody and let her
10 know not to talk to me because it would be
11 improper in the courtroom.
13 Q. Mr. Prince, is it your testimony you did not speak
14 to Mr. Dandar at all during the recess?
15 MR. DANDAR: Judge, he just answered the
16 question.
17 THE COURT: He just said that's what he
18 told Dandar.
19 MR. ROSEN: No, I thought he said he told
20 that to Mr. Dandar's secretary.
21 THE COURT: No. He said he told
22 Mr. Dandar about the secretary.
23 MR. ROSEN: Oh, I see.
25 Q. And is that it?

1 A. Correct.
2 Q. That's the entirety of your conversations?
3 A. Correct.
4 Q. Now, if you will look at the exhibits, sir, the
5 check, which is part of Exhibit 191, you will see it says,
6 "McPherson v. Flag, expert fee."
7 That's what Mr. Dandar caused to write on it,
8 right?
9 A. It looks like this check was made out to or by
10 Donna M. West. There's no evidence of Mr. Dandar authoring
11 this check, but it surely does say, "McPherson versus Flag,
12 expert fee."
13 Q. And it's signed by Diane West?
14 A. Donna West.
15 Q. Huh?
16 A. Donna.
17 Q. Oh, Donna?
18 A. D-o-n-n-a.
19 Q. Donna.
20 A. Yes.
21 Q. And who is she?
22 A. That's the woman sitting to the left of
23 Mr. Dandar.
24 Q. That's his secretary.
25 A. Correct.
1 Q. Okay. And is it your testimony, sir, that the
2 testimony you gave before Judge Schaeffer for which you
3 were paid here was a, quote, expert witness fee?
4 A. I guess I don't understand the question.
5 Q. Is the testimony you gave before Judge Schaeffer
6 for which this check was payment, was it, quote, expert?
7 Was it expert testimony?
8 A. You know, I don't understand the question because
9 I don't understand what testimony you're speaking about;
10 therefore, I'm unable to understand what you're asking me.
11 Q. You don't understand the testimony I'm speaking
12 about?
13 A. Correct.
14 Q. You don't understand I'm asking you about your
15 testimony in the year 2002 before Judge Schaeffer? You
16 don't understand that?
17 A. Well, you know, as you correctly pointed out,
18 Mr. Rosen, you have shown me 1, 2, 3, 4, 5, 6 days of
19 testimony here. So, you know, you're being a little
20 generic here.
21 If you want to specifically talk about some
22 specific testimony that I have given over the course of
23 these days, I will answer any question you ask me.
24 Q. Mr. Prince, on the first day you testified before
25 Judge Schaeffer, did you provide expert witness testimony?

1 Yes or no.
2 A. I would have to see the testimony. I don't know
3 if I was testifying as a fact witness that day or as an
4 expert. I'm not sure.
5 Q. On the second day that you testified before Judge
6 Schaeffer, did you provide fact testimony or expert
7 testimony, sir? Yes or no.
8 A. In answer to -- so we save ourselves the whole
9 list, unless I look at the testimony, it may have been one
10 or the other or both. I'm not sure.
11 Q. And you recall that in your testimony or while you
12 were on the witness stand before Judge Schaeffer, somebody
13 offered your testimony -- Mr. Dandar or whoever -- as a,
14 quote, expert witness, right?
15 A. You know, I don't know.
16 Q. You don't know?
17 A. I don't understand your question.
18 Q. Do you recall any time in which Judge Schaeffer -­
19 MR. DANDAR: He's interrupting the witness's
20 answer.
21 MR. ROSEN: I thought he was finished. He
22 said he didn't know.
23 THE COURT: He was still talking.
24 MR. ROSEN: Oh, I'm sorry. I didn't hear
25 him, Judge. Go ahead, Continue your answer.

THE WITNESS: I lost my train of thought. I'm trying to keep up with you, Mr. Rosen.
Q. At any time during any of those days you testified before Judge Schaeffer, did you ever hear Judge Schaeffer say, in words or substance, "Mr. Prince is an expert," expert witness?
A. Yes.
Q. You recall that? When was it?
A. During the course of these days that you so graciously supplied, she said that. On which day? I'm sorry; I can't tell you.
Q. Let's see if we understand each other. What she said was not something like Mr. Prince -- Mr. Dandar says Mr. Prince is an expert. Judge Schaeffer said, "You're an expert witness"?
A. Correct.
Q. Okay. Now, how many hours have you spent since you've been engaged by Mr. Dandar?
A. As a result of the recent blackmailing and coercion?
Q. Huh?
A. As a result of the recent blackmailing of
Mr. Minton? Are we talking about that time period or an
earlier time period?
1 I don't know, Mr. Rosen. I'm just asking you
2 for a specific question.
3 Q. Please, Mr. Prince.
4 How many hours have you spent since you have
5 been engaged by Mr. Dandar? We're talking about the year
6 2002.
7 A. I don't know.
8 Q. How many hours?
9 A. I don't know:- I'm not sure.
10 Q. Huh?
11 A. As I sit here, I can't tell you. I know it's been
12 quite a bit.
13 Q. But you've got them all written down on your
14 little yellow pad at home, right?
15 A. More than likely.
16 Q. Huh?
17 A. More than likely.
18 Q. Is that yellow pad at home,-- what's the date of
19 the last entry on that yellow pad for the time you spent
20 working for Mr. Dandar?
21 A. As I sit here, I couldn't tell you.
22 Q. Well, Mr. Prince, you were on this witness stand
23 yesterday. Is there a note on your yellow pad for the time
24 you spent here yesterday?
25 A. No, I made no notes from yesterday.
1 Q. Why not?
2 A. I just haven't gotten around to it.
3 Q. Oh, you intend to when you get some time?
4 A. Yes.
5 Q. Okay. So when you get your notes updated, it will
6 have whatever amount of time you spent yesterday here in
7 court, right?
8 A. It could, yes.
9 Q. It could. Okay. How much was that? How much was
10 that time?
11 A. You know, I don't know. I mean, I was
12 here -- what time did -- well, it wasn't that much,
13 actually.
14 I think I came on at four o'clock. I sat and
15 waited in the hallway. I was here all day just waiting in
16 the hallway. And then at four o'clock, I came in here and
17 I think I testified until five.
18 MR. ROSEN: Your Honor, I'm going to ask
19 what the Court order Mr. Prince during the
20 luncheon recess to retrieve those notes or his
21 records for the time he spent working for
22 Mr. Dandar and bring them back here after
23 lunch.
25 MR. ROSEN: I'm sorry?
3 Q. Mr. Prince, I want to go back just quickly over
4 your history in Scientology. You were an official of RTC
5 until 1987, right?
6 A. Correct.
7 Q. And that's when Mr. Miscavige became the head of
8 RTC, right?
9 A. Correct.
10 Q. And when he became the head of RTC, he removed
11 you, right, from your position?
12 A. Yeah. He demanded that I relinquish my position.
13 Q. Okay. And so for the next five years while you
14 continued to be a parishioner, if I may call it, in the
15 adherence of the Scientology religion, you didn't have any
16 position in RTC; is that right?
17 A. Correct.
18 Q. And you were very upset with Mr. Miscavige about
19 the fact that he had removed you, right?
20 A. No, that's incorrect.
21 Q. Mr. Prince, is it correct to say that from 1998
22 when you first hooked up with -- reconnected with
23 Ms. Brooks and Mr. Minton, et cetera -- that your life has
24 been spent largely attacking Scientology and attacking
25 Mr. Miscavige?

1 A. Incorrect.
2 Q. Mr. Prince, as you sit here today, do you harbor
3 feelings of resentment or hatred against your former
4 religion?
5 A. No.
6 Q. As you sit here today, do you harbor any feelings
7 of hatred or resentment against the head of your former
8 religion, Mr. Miscavige?
9 A. I don't hate anyone. I'm a person of God. I
10 don't hate anyone. I resent -- I do have some resentment
11 concerning the actions and activities, but not the people,
12 not institutions.
13 Q. Okay. So you may resent activities, but you don't
14 harbor any resentment against Mr. Miscavige, do you?
15 A. I harbor resentment against actions that I
16 perceive he does, but not against him as an individual or
17 as a person.
18 Q. Okay. Have you -- when you left Scientology, did
19 you harbor resentment against your former religion?
2 0 A. No.
21 Q. So you never have, from the time you left in '92?
22 A. As I sit here today.
23 Q. And from the time you left in '92 you have not
24 harbored any personal animosity against Mr. Miscavige,
25 right?

1 THE WITNESS: Correct.
2 MR. ROSEN: Can we prepare the tape,
3 please?
4 MR. DANDAR: Judge, I anticipate that the
5 tape he's going to show -­
6 MR. ROSEN: I'm going to ask Mr. Prince a
7 question. This will make it easy. You won't
8 have to anticipate.
10 Q. Mr. Prince, did you appear regularly here in terms
11 of demonstrations against the Church of Scientology?
12 A. I have demonstrated, yes.
13 Q. And was one of those demonstrations in or about
14 November of 1998?
15 A. It's possible.
16 Q. Do you recall being filmed and making some remarks
17 to the video camera operator during that demonstration?
18 A. Yes.
19 Q. Okay. I'm going to show a tape and ask the
20 witness if he can identify it.
21 MR. DANDAR: I object, because what they're
22 going to show you is just a piece of a
23 videotape, and they have not produced the whole
24 videotape.
25 And I think you should -- in order to be

1 fair to Mr. Prince and the Court, they should
2 be required to play the whole videotape or at
3 least ten minutes or so before the section they
4 want you to concentrate on, Judge, to see what
5 Mr. Prince is reacting to.
6 MR. ROSEN: This is not a deposition. If
7 Mr. Dandar wants to play any part of this
8 videotape, he can. This is the part I want to
9 play which goes directly to the witness's
9 testimony and his bias.
11 THE COURT: Well, we'll go ahead and play 12 it. That portion of the videotape will come
13 into evidence. And then if there's additional
14 portions you want to show, that's fine. You
15 can do that. Okay?
17 Q. Can you see it from here, Mr. Prince?
18 A. Yes, I can. I'm pretty sure I know what it is
19 anyway. We've seen it a few times in courts, over and over
20 and over and over.
21 (The following is a portion of a videotape
22 published to the Court. The transcription of
23 the tape may not be verbatim, as some of it was
24 inaudible to the reporter.)
25 VIDEOTAPE: "I just want to make sure you
1 get all of the data, all of the data. Tell
2 David I'm coming with a dick so big I'm going
3 to knock his God damn spine out. Because I'm
4 black; I've got a big dick.)
6 Q. Is that you?
7 A. Yes, it is.
8 Q. I think I heard, "I'm coming to get you. I'm
9 going to knock your spine out because I'm black and I got a
10 big dick," right?
11 A. I think -- I don't think you got it right. I can
12 tell you exactly what it said.
13 Q. Go ahead. You correct me.
14 A. Well, the video speaks for itself. I never said
15 you tell David I'm coming.
16 Q. You used the word David in that video?
17 A. Yes, I did. I think I did.
18 Q. You were referring to David Miscavige, correct?
19 A. Correct.
20 Q. And this is an example of your -- tell me if I'm
21 wrong, Mr. Prince.
22 This is an example of your love as a child of
23 God, that you have no personal animosity towards
24 Mr. Miscavige; is that right? As a child of Gods is that
25 right?
1 A. You know, taken out of context -- I guess you can
2 characterize it any way you would like to, but the fact is
3 that I'm having that feeling about him because
4 Mr. Miscavige -- who is the head of Scientology and who I
5 know, you know, how they practice and do, carry out their
6 directive to destroy their enemies utterly -- had taken
7 priest/penitent information that I had talked about while
8 I'm thinking I'm talking to a minister in Scientology and
9 spread it all over to staff members around the world so
10 that when I walk down the street, they whisper
11 sweet-nothings in my ear about things I told in confidence
12 to a priest.
13 You know what, that is disgusting. So you
14 think this video is disgusting? Put that next to it and
15 let's look at it, Mr. Rosen.
16 Q. Mr. Prince, Mr. Dandar asked that certain other
17 parts of the rest of this video be played.
18 If we look at the entire video, is there
19 anything on here that prompted these remarks? Did somebody
20 come down the street and whisper sweet nothings at you?
21 A. No. I am there because of what happened already.
22 You see, I'm protesting because that's my right.
23 Q. My question is: Did anybody whisper sweet
24 nothings to you, sir?
25 A. Maybe not that time, but it happened very closely

1 around that. I'm doing this in response because I'm upset.
2 You know why I'm upset? Because I'm tired of
3 getting Scientology's fair game. I'm tired of being
4 cheated. I'm tired of being threatened with suit. I'm
5 tired of being tricked. I'm tired of being destroyed.
6 MR. ROSEN: Your Honor, I move to strike this
7 tirade. I asked a question.
8 THE WITNESS: That was my reaction to that
9 activity.
11 Q. Mr. Prince, that was in November of 1998. Do you
12 remember the date, November 5?
13 A. Uh-huh. (Affirmative.)
14 Q. Whether it is on the video or not, did anything
15 happen which prompted you to make the statements we've just
16 looked at --
17 A. Yes.
18 Q. -- on that day?
19 A. Yes.
20 Q. Okay. Tell us what it is that caused you to tell
21 Mr. Miscavige you were coming after him with your big dick.
22 A. A private investigator blocked -- I was trying to
23 leave the parking lot. A private investigator hired by
24 Scientology pulled in behind me --
25 Now, this is three o'clock in the morning. He

1 pulled in behind me, ran up, beating on my window -- scared
2 me half to death because I don't know -- I was in L.A. -- I
3 don't know these people -- and he told me he was going to
4 blow my black nigger head off. He was upset with me.
5 Okay. That's one thing, Mr. Rosen. And be
6 patient because this is going to take a while, okay?
7 Q. Sir -­
8 A. This is going to take a while.
9 MR. ROSEN: Your Honor, I asked the
10 question witness if anything happened on this
11 day that prompted this.
12 THE COURT: I know. So let's just
13 restrict it to that day. Did anything happen
14 on that day that precipitated that?
15 THE WITNESS: It very well could have. I
16 don't recall from 1998.
17 THE COURT: Okay. Let's move on.
19 Q. Okay. Now, Mr. Prince, last time you were here,
20 yesterday, in response to a question by Mr. Dandar, you
21 testified that in conversation with Mr. Minton this year
22 about what was going on with the settlement, just to be
23 generic, you told him that you wouldn't lie because, "I
24 believe in the system of justice. I will not commit
25 perjury. It is evil."

1 Do you recall saying that yesterday?
2 A. Paraphrased, yes, I do.
3 Q. Okay. And, in fact, Mr. Prince, you have been a
4 long believer in the system of justice and morality, right?
5 A. I think so, yes.
6 Q. Mr. Prince, when did you first join Scientology?
7 A. 1976.
8 Q. And you joined Scientology in San Francisco,
9 California, right?
10 A. Correct.
11 Q. Now, you grew up in Illinois, the Chicago area?
12 A. Right.
13 Q. And you had just moved from Chicago to the San
14 Francisco area when you got hooked up with Scientology in
15 '76?
16 A. Yeah, kind of. I guess you could say that.
17 Q. And you were, what, about 21 years old at that
18 time?
19 A. Yes.
20 Q. And you moved to San Francisco, what, for a job
21 opportunity?
22 A. No, I just wanted to see California.
23 Q. So you picked up, moved out of where you had grown
24 up in Chicago and moved to San Francisco because you wanted
25 to see California; is that it? That's the only reason you

moved, right?
A. Well, no. I think that kind of mischaracterizes it and does not actually -- it's true. I mean, I just ended up there.
I just wanted to see more of the United States. California was one place that I went to that I liked when I landed there, but it certainly isn't the only place that I traveled to during that time.
Q. I'm not talking about going on a vacation or sight-seeing. You moved to California at that time, right?
A. Again, I've answered your question the best I can.
Q. Did you move to California at that time or not?
MR. DANDAR: Objection. He's interrupting the
witness. I'm also objecting to relevance.
THE COURT: Overruled. Go ahead.
THE WITNESS: I don't understand what you're asking me.
Q. Did you move to California at that time or did you just take a plane here for a few days to be a visitor, go look at the sights?
A. You know, it was more of a vacation, for sure, because, number one, my car was still in Illinois. Number two, my furniture, all of my earthly possessions,

everything that I owned was still in Illinois. As I said, I was just traveling to these places, and California was a place that I ended up going to and liking.
Q. Mr. Prince, are there any other reasons that you came from Illinois to California?
A. No.
Q. And you eventually moved your car and your personal belongings to California, right?
A. No.
Q. Can you think, sir, of any other reason why you left Chicago and came to California at that time?
A. I never left Chicago and came to California.
Q. Okay. Well, let's see if I can help refresh your recollection, Mr. Prince. Did you leave Chicago because you were under charge of committing crimes and you jumped bail?
A. No.
Q. Sir, were you charged in Chicago or in Illinois with two counts of -- I don't know what they call it. In New York they call it statutory rape. I think in Illinois it's called having sexual relations with a minor.
MR. DANDAR: Objection, Judge.
MR. ROSEN: Were you charged with those things?
MR. DANDAR: This is an improper
1 impeachment attempt under the evidence code
2 unless there is a conviction.
3 THE COURT: Overruled. I think he's
4 impeaching the witness on his prior testimony.
5 MR. DANDAR: Wait a minute. Unless these
6 are all public records -­
7 THE COURT: He's just asking questions,
8 okay?
9 MR. DANDAR: I'm just afraid, concerned,
10 that the Plaintiff may try to delve into
11 Mr. Prince's priest/penitent documents still
12 contained within the Church of Scientology, and
13 that would not be proper for them to start
14 asking him questions about things that he told
15 them under a priest/penitent auditing session.
16 THE WITNESS: That's exactly what's going
17 on here. That's exactly what's going on here.
18 THE COURT: What do you think about that,
19 Mr. Rosen?
20 MR. ROSEN: Well, I'm just amazed because
21 I will read to you of a deposition I took of
22 Mr. Prince in a federal case in Denver in 1998
23 where I not only asked him these same
24. questions, but we produced the Chicago blotter
25 showing bail jumping, arrest warrant and the

1 charges.
2 THE COURT: Well, he answered those
3 questions then?
4 MR. ROSEN: He did, sir.
5 THE COURT: Okay.
6 MR. DANDAR: I said it's a public record.
7 That's a different story.
8 THE WITNESS: Your Honor, this doesn't
9 negate the fact that this information still
10 came from priest/penitent, whether it was
11 yesterday or whether it was 1998. It's the
12 same tactic, trick, sue, lie to or destroy,
13 same tactic.
15 Q. You know, I don't want to destroy you. I just
16 want to know if it's true, so let's, take it nice and
17 simple.
18 Were you charged with whatever that crime is,
19 whatever they call it in Illinois, of having sex with two
20 13-year-old girls?
21 A. No. That is blatantly and insanely false, and
22 it's a lie and it's inflammatory.
23 Q. What were you charged with?
24 A. I'm sure you have the record right there,
25 Mr. Rosen?

1 Q. Mr. Prince, tell me what you were charged with.
3 THE COURT: One at a time. I will ask the
4 question. Tell him what you were charged with.
5 THE WITNESS: I don't recall this.
7 Q. But you recall it that -- you don't recall
8 specifically. Do you recall approximately?
9 A. I recall that I have had no convictions
10 whatsoever, no criminal convictions whatsoever about
11 anything, so...
12 MR. ROSEN: Your Honor, my question is
13 what he was charged with, and this witness is
14 not responding.
15 THE COURT: I'm just going to take into
16 consideration his response. Let's move on,
17 okay?
19 Q. Mr. Prince, the reason that you came -- you left
20 Chicago and came to California, was that you jumped bail,
21 and a felony arrest warrant was issued for you in Illinois;
22 isn't that true?
23 A. No, it is not.
24 Q. Okay. We offer Exhibit 163. This is the exhibit
25 that was -- same exhibit when we examined Mr. Prince in
1 August of 1998 in Denver. It goes on, three different
2 bails were -- jumped three different bails. Did you ever
3 see this document before, Mr. Prince?
4 A. I may have.
5 Q. Does this help refresh your recollection that you
6 jumped bail, sir? That's why you left Chicago and came to
7 California?
8 A. No.
9 Q. Huh?
10 A. I didn't leave Chicago to go to California.
11 Q. Well, okay. Forget whether you left Chicago.
12 Does this refresh your recollection that you jumped bail?
13 A. If that's what it says. I mean, does it say that
14 anywhere, what you're saying?
15 Q. Does it? Can you testify, sir, yes or no? Did
16 you jump bail?
17 A. You know, again, that could have happened, but I
18 think this document speaks for itself.
19 THE COURT: Okay. That's fine.
20 THE WITNESS: Okay. Good.
21 THE COURT: It speaks for itself.
23 Q. And, Mr. Prince, you were asked about this very
24 thing when I deposed you in Denver in a federal case on
25 August 19th, 1998. Do you remember being asked about this

1 very thing by me?
2 A. No, I do not.
3 Q. Okay. Reading from Page 318.
4 Question, by me, "Mr. Prince, didn't you, in
5 fact, jump bail in Chicago?"
6 Answer, "No. For what?"
7 Question, "Mr. Prince, do you recall being
8 arrested and charged with statutory rape
9 Answer, "No."
10 Question, "Do you recall being arrested and
11 charged with some crime in connection with having sex with
12 a girl underage?"
13 Answer, "Yes, contributing to the sexual
14 delinquency of a minor."
15 Continuing on -- well, let me stop there for a
16 moment. Do you recall being asked those questions and
17 giving those answers?
18 A. You just read from it. If it happened, it
19 happened. I stand by my testimony.
20 Q. My question is not whether it happened. My
21 question is do you recall giving those answers under oath
22 four years ago?
23 A. I stand by any testimony I have given.
24 Q. Mr. Prince, if you want me to continue reading, I
25 will. You were advised that jumping bail is a felony --


1 A. By who?
2 Q. -- in Illinois, right?
3 A. By who?
4 Q. I don't know.
5 A. I was advised by who?
6 Q. Sir, were you aware that jumping bail was a
7 felony?
8 MR. DANDAR: I object. I would like to see a
9 copy of what he's reading from. I think the
10 witness is due to see the page he's reading
11 from to make sure it's not all taken out of
12 context and it's not Mr. Rosen who's claiming
13 he was advised that it was a felony, which is
14 probably -- well, I don't know what it is, but
15 I would like to see what he's reading from
16 the witness should be given an opportunity
18 Q. Page 320, question, "Well, you tell me when it
19 was.
20 24 years ago. This is the jumping bail.
21 Answer, "24 years ago."
22 Question, "Okay. Was it a felony?"
23 Answer, "Like I said, I have never been charged
24 with a felony."
25 Question, "Do you know whether jumping bail is

1 a felony, Mr. Prince?" '
2 Answer, "Yes."
3 Page 321, "Yes, it is. Yes, you know, I did
4 that. I made a mistake in my life."
5 Does that sound at all familiar to you?
6 A. I stand behind the testimony. Any testimony that
7 I have given, I stand behind it.
8 Q. So this testimony is truthful. Okay.
9 THE COURT: Okay. Let's move on.
11 Q. In addition, sir, on the subject of your belief in
12 the sanctity of the system of justice and morality, do you
13 recall during that same testimony you provided us with an
14 account of some of your experiences growing up in Chicago?
15 A. Mr. Rosen, I stand behind any testimony that I
16 have given. There's nothing else I can say. Do I recall
17 the conversations that I've had many years ago? I'm sorry,
18 I do not. I don't have that capacity. But I do have the
19 capacity to sit here today and tell you I stand behind any
20 prior testimony I have given.
21 Q. Mr. Prince, do you recall that your testimony in
22 1998 was before you joined Scientology and they
23 straightened you out, when you were in Chicago you were a
24 drug abuser?
25 A. That's blatantly false. Scientology didn't
1 straighten me out.
2 Q. Okay. Forget straighten you out. Were you a drug
3 abuser in Chicago?
4 A. If you have testimony from me -­
5 Q. Mr. Prince -­
6 THE WITNESS: Excuse me: Your Honor, this
7 information that he's speaking about is
8 something that specifically is asked of each
9 person when they go into church in Scientology.
10 It is asked in confidence.
11 He is clearly advised by his criminal
12 client to do this to me to make a mockery even
13 of their system. And you know what? I'm
14 getting a little tired of it.
15 MR. DANDAR: Judge, I object to the line
16 of questioning, that he's violating the
17 priest/penitent privilege that the Church of
18 Scientology insists -­
19 THE COURT: So the only reason that anyone
20 would ever know that this man has been engaged
21 in drugs is because he told somebody at
22 Scientology about it?
23 MR. DANDAR: Absolutely.
24 MR. ROSEN: Your Honor, since I was there
25 and Mr. Dandar knows not of what he speaks,
1 this very same argument was presented before
2 the federal judge in Denver.
3 And we said, "This isn't a PC folder.
4 We'll show you. He wrote it in his own hand.
5 This is not a confession."
6 I will represent to you, as I did to the
7 judge in Denver, I have never seen his PC
8 folder; I have never gotten any information
9 from it.
10 But he wrote things to people, including
11 people in Scientology, that are not
12 priest/penitent. And the judge in Denver ruled
13 this was not priest/penitent.
14 THE COURT: Well, did he testify about it
15 in Denver?
16 MR. ROSEN: And he testified about it.
18 Q. So I will ask you again. Did you relate stories,
19 Mr. Prince, about your being a drug user in Illinois?
20 A. I stand behind any testimony.
21 MR. DANDAR: What's the relevance of what
22 happened in 1975 or before?
23 MR. ROSEN: This man told you -- I mean, this
24 is pure credibility. This man said, "I was
25 outraged at Mr. Minton; he wanted me to lie. I

1 gave him a speech about the system of justice
2 and perjury and it's evil. I'm a law-abiding
3 citizen."
4 THE COURT: All right. I think we're
5 getting a little far afield here.
6 MR. ROSEN: All right. Let me ask one
7 more subject on this.
9 Q. In terms of your morality, Mr. Prince, did you
10 testify in that deposition in Denver in 1998 about growing
11 up, [XXXXX removed by Jeff]
12 MR. DANDAR: Objection. This is just to
13 humiliate the witness.
14 MR. ROSEN: No, it's to undercut his
15 credibility.
16 THE WITNESS: Mr. Rosen-­
17 THE COURT: Wait a minute, Mr. Prince.
18 We're just not going there. Let's just move
19 on.
21 Q. All right. Now, Mr. Prince, I want to go over
22 some of your testimony from yesterday, sir.
23 You testified to a meeting you had on, I
24 believe, Sunday the 14th of April with Mr. Dandar and
25 Mr. Lirot. Do you recall that?

1 A. Yes.
2 Q. Prior to that meeting, had you ever spoken to
3 Mr. Dandar, either met with him or spoke to him on the
4 phone, about any events, any conversations you supposedly
5 had with Minton or Brooks from March 28th of this year on?
6 A. No.
7 Q. When was the first time that in any
8 way -- e-mailed, telephone, in person -- when was the first
9 time that you ever informed Mr. Dandar of these
10 conversations that you had been having with Minton and
11 Brooks about the events of the settlement?
12 A. On the exact date that I wrote the handwritten
13 notes, which is attached to my declaration, on that day was
14 the first time that I had the conversation with Mr. Dandar
15 about that.
16 Q. And that's August of -- excuse me -- April the
17 14th?
18 A. If that's what the date says.
19 Q. So all of this -- and you were having
20 conversations, if I-understand your testimony, March 28th,
21 29th, all of this time, conversations, telephone and in
22 person, with Mr. Minton and Ms. Brooks about what was going
23 on in the, quote, settlement, right?
24 A. The Mary Carter agreement? Is that what you're
25 talking about?
2 testify to a Mary Carter agreement yesterday?
3 MR. DANDAR: Objection, compounded question.
4 Which question does he want him to answer?
5 THE COURT: Let's start over.
7 Q. I will. What's a Mary Carter agreement?
8 A. It's an illegal agreement made through coercion
9 and blackmail to get a person to perjure themselves.
10 Q. Got you. And how does it have the name Mary
11 Carter?
12 MR. DANDAR: Objection, calls for a legal
13 opinion.
14 THE COURT: Well, I mean, he's the one
15 that used the term, okay?
16 MR. DANDAR: I know.
17 THE WITNESS: Well, I read it in a
18 pleading. You know, from what I read, Mary
19 Carter was the wife of a person that was being
20 blackmailed or coerced or something. I don't
21 know.
23 Q. Okay. So you read in some pleading that Mary
24 Carter of the Mary Carter Paint Company, Inc. was the wife
25 of, what, someone that was blackmailing her?

1 MR. DANDAR: That's just another attempt to
2 humiliate the witness, and I object. I mean,
3 come on. We don't need to have his
4 understanding of what it is.
5 THE WITNESS: Humiliation is the key here.
6 It doesn't matter. Come on.
7 THE COURT: Let's get back to the issue at
8 hand, okay?
9 We're talking about the discussions that
10 he had with Mr. Minton and Ms. Brooks regarding
11 the settlement with Scientology, all right?
12 Mr. Prince, don't characterize it as a
13 Mary Carter agreement, all right, because that
14 confuses the issue. It's something entirely
15 different that you don't understand, okay, and
16 that's why everybody's laughing, because it
17 doesn't have anything to do with that, but what
18 we're talking about are those discussions you
19 had with Mr. Minton and Ms. Brooks, okay?
20 That's what we're talking about.
23 Q. Mr. Prince, in fact, you were told by Mr. Dandar
24 that these conversations that you have been describing
25 yesterday on the witness stand were Mary Carter; Mr. Dandar
1 told you that, right?
2 MR. DANDAR: Objection as to what
3 expert.
4 MR. ROSEN: He's not an expert.
5 THE COURT: It's just irrelevant. Let's
6 just move on.
8 Q. Okay. Now, on the 14th of April, are you sure
9 that as of that date you had never in any way informed
10 Mr. Dandar about all of these events that had been
11 occurring up until then?
12 A. That's correct.
13 Q. You didn't, for example, have a meeting with
14 Mr. Dandar in which he asked you to go down to the Florida
15 Department of Law Enforcement and try to get a criminal
16 action started because Mr. Minton was about to walk into
17 this court and commit perjury; you never had that
18 conversation, Mr. Prince?
19 A. After, after, after.
20 Q. When?
21 A. After 14 April.
22 Q. When?
23 A. Sometime shortly thereafter.
24 Q. When? April 14th was a Sunday. When did you have
25 that conversation with Mr. Dandar?
A. You know, I don't know how else to answer the question, Your Honor. It was sometime shortly thereafter. You know, you want to ask me when --
THE COURT: Well, was it a day? A week? A month?
THE WITNESS: Shortly -- no, it was like within a week.
THE COURT: Within a week, okay.
Q. If I tell you that Mr. Minton showed up here to testify on April 19th, was it before April 19th?
A. I guess I don't understand what you're asking me about.
Q. The conversation that you had with Mr. Dandar about you going down to the FDLE, was it before April 19th? What don't you understand, Mr. Prince?
A. I don't remember. I don't understand your questions. Is that so amazing to you? If I don't understand the question, I don't understand it.
THE COURT: Let me ask you this: Between April 14th and April 19th when Mr. Minton came in and testified regarding the concerns that you apparently had that he was going to perjure himself, did you go down to the FDLE and try to
1 start a criminal action regarding that prior to
2 the time he testified?
3 THE WITNESS: Yeah, that very well could
4 have happened.
5 THE COURT: Okay. Thank you.
7 Q. And you did that at the request of Mr. Dandar,
8 right? He suggested it.
9 A. No, not entirely.
10 Q. Wait a minute. Did you a discussion with
11 Mr. Dandar before you went down there?
12 A. I can make this simple for you. I can explain to
13 you what happened.
14 Q. Answer my questions. Did you have a discussion
15 with Mr. Dandar on the subject of you going to the FDLE
16 before you went there? Yes or no.
17 A. Yes.
18 Q. And Mr. Dandar even said to you, "I will call Lee
19 Strope and see if I can get him to be available to talk to
20 you," right?
21 A. I know Lee Strope.
22 Q. Did Mr. Dandar say that or not?
23 A. Yes, he said that.
24 Q. Okay, good. And Mr. Dandar told you, "Go down and
25 talk to Mr. Strope and tell him that you believe that
1 Mr. Minton is about to get on the witness stand and about
2 to commit perjury," right?
3 A. No, no, no, no.
4 Q. Did you tell Mr. Strope that?
5 A. I told him he had already done it. From the
6 moment I sat in this courtroom and walked out, because he
7 was sitting on the stand lying already, then I went to
8 Dennis de Vlaming, asked him for an FBI contact because
9 this criminal RICO activity was going on, which you were a
10 criminal participant in. You know, you're telling me about
11 my moral character. You're a criminal --
12 Q. Where does this all end?
13 THE COURT: Just listen to his questions.
14 THE WITNESS: I'm sorry. I had an
15 emotional outburst there.
16 THE COURT: I know.
18. Q. Mr. Prince, didn't you go down to the FDLE and
19 tell them that Mr. Minton was about to take the witness
20 stand and commit perjury? Yes or no.
21 A. I told them he had already done it.
22 Q. Okay. Let me see if I can refresh your
23 recollection. Didn't you ask that before Mr. Minton
24 testifies that the FDLE call Mr. Minton and advise him that
25 perjury is a crime?
1 A. No, I did not.
2 Q. And, sir, didn't you request or invite or whatever
3 word you want to use, a representative of FDLE to be in
4 this courtroom, in Judge Baird's courtroom, sitting here,
5 when Mr. Minton was testifying on the 19th of April?
6 A. No, I did not.
7 Q. Was there somebody here?
8 A. Yes, there was.
9 Q. Who was it?
10 A. Lee Strope.
11 Q. And can you tell us how Lee Strope happened to
12 wander into this courtroom and sit here right there while
13 Mr. Minton is testifying? How did that happen?
14 A. Because he wanted to see the faces of the people
15 that are soon to be indicted, yours, Yingling -­
16 Q. How did he know that Mr. Minton was going to be on
17 the witness stand, sir?
18 A. I told him.
19 Q. Oh, you did. Okay. When did you tell him that?
20 A. When I told him about the blackmail and coercion
21 that you, Yingling and Rinder -­
22 Q. Mr. Prince, you're not listening. The question is
23 when, w-h-e-n. When did you tell him? That is, I told him
24 on Tuesday, I told him on April blank, whatever the answer
25 is.
A. That's one way to answer the question, sure.
Q. When did you tell him?
A. Prior to the day of that testimony, some date prior to that.
Q. Okay.
A. I submitted a report to the FDLE about the criminal nature of the activities that you and your cohorts were involved in.
Q. And after you spoke to Mr. Strope, sir, Mr. Strope said to you, "You give Bob Minton a message, that if he commits perjury when he appears before Judge Baird, we're going to bring charges against him," right?
A. He will be charged with perjury. If it's proven that he lied, he will be charged with perjury, correct.
Q. And your testimony, sir, is that Lee Strope
deputized you to go tell Mr. Minton that if he lies, he's
going to be charged with perjury. That's the way the FDLE
operates. They deputized you to tell him that, right?
A. I think your ignorance shows, and you're being silly here. Of course no one deputized me, okay. We can stop the grandstanding any time.
Q. Since I'm so ignorant, sir, I will read from your testimony of July 9th, 2002 before Judge Schaeffer and ask you if this is correct:
The question, which is long separated from the
1 answer by colloquy, you talked about Mr. Minton and Brooks.
2 "I pretty much gave Mr. Strope a complete
3 rundown of the meetings with the dates, similar to how I
4 laid it out there in the affidavit and after Strope --"
5 "What agency?"
6 "FDLE."
7 And here comes the rest of your answer:
8 "And after speaking with him, he asked me to
9 give Bob Minton a message, and the message was that if it
10 was determined that you have perjured yourself on the
11 witness stand, that he would see to it that charges would
12 be brought against you."
13 MR. DANDAR: Objection that's not an
14 impeachment. That's not inconsistent
15 testimony. The word deputized does not appear
16 in -­
17 THE COURT: Okay. We'll forget the
18 deputized part.
20 Q. You testified to that, right?
21 A. Again, I will say, I stand by --
22 Q. No, no did you testify to this?
23 A. I stand by my testimony.
24 THE COURT: You did.
25 MR. ROSEN: Yeah, you did. Okay.

1 THE WITNESS: I stand by my testimony.
2 THE COURT: Okay. Good.
4 Q. So I guess if I'm understanding your testimony,
5 then, Mr. Strope from the FDLE asked you to give Mr. Minton
6 a message, right?
7 A. I stand by my testimony.
8 Q. Did you give him the message?
9 A. I stand by my testimony.
10 MR. ROSEN: Judge, I'm going to ask for an
11 instruction for him to answer the question.
12 THE COURT: Okay. Answer the question.
13 Did you pass that message on to Mr. Minton?
14 THE WITNESS: Me personally, no, but I had
15 someone do it.
16 THE COURT: Yeah. You arranged to have
17 the message passed on?
19 THE COURT: All right.
21 Q. And who was it that you arranged to have pass that
22 message on to Mr. Minton?
23 A. My girlfriend.
24 Q. And what's her name?
25 A. Deneen.

1 Q. And she passed that on, as far as you know, to
2 Mr. Minton before he took the witness stand in this court
3 on April 19th.
4 A. That very well may have happened, sure. Yes, yes,
5 yes. The answer is yes.
6 Q. And you were present when your girlfriend -- you
7 witnessed your girlfriend giving this message to
8 Mr. Minton, right?
9 A. No, I was not present.
10 Q. Did she give this message to Mr. Minton in person
11 or by phone?
12 A. By phone.
13 Q. And weren't you standing there next to your
14 girlfriend?
15 A. No, I was not.
16 Q. Weren't you writing down what your girlfriend was
17 saying to Mr. Minton?
18 A. I previously had written it down.
19 Q. You previously had written it down and gave it to
20 her to read?
21 A. Correct.
22 Q. Okay. And that was a threat that if he got on the
23 witness stand, that he was going to be arrested if he
24 committed perjury, right?
25 A. I would hardly characterize that as a threat,
1 Mr. Rosen. If I tell you that, you know, if you take a gun
2 and shoot somebody, you're going to jail, am I threatening
3 you or am I informing you?
4 Q. Okay. The part that your fiance read from the
5 message that you wrote down for her to read, it included
6 that this message was from Mr. Strope of the FDLE, right?
7 A. Correct. I mean, I have given testimony about
8 that, and I stand behind it.
9 Q. There's no question before you. You're not
10 listening to me.
11 So this was something that you had discussed
12 doing with Mr. Dandar, right?
13 A. No.
14 Q. Did you tell Mr. Dandar you had done this?
15 A. After I did it, yes.
16 Q. So Mr. Dandar told you or suggested to you that
17 you go down to the FDLE, but he didn't suggest to you that
18 you have Strope call Minton?
19 A. No.
20 Q. Okay. Well, let's back up a minute. When
21 Mr. Dandar told you or you discussed with him you going
22 down to the FDLE, what did he say to you?
23 A. It's a good idea. You know, criminals -- as a
2,4 citizen, you turn in criminals. If you know about criminal
25 activity, you turn them in.
1 Q. And he suggested you use the words criminal RICO,
2 right?
3 A. No, he did not. Those were my words, because I
4 understand a little bit -- you know, and you can laugh all
5 day about this if you want to, but I know a little bit
6 about RICO, and I know that the criminal conspiracy started
7 in New York, continued in New Hampshire and was brought
8 here to Clearwater, and the fraud continues.
9 Q. Mr. Prince, the situation you were confronted with
10 in April was you had been -- your entire income had been
11 derived for the last several years, except for something
12 from Mr. Leipold, from work performed in connection with
13 the wrongful death case, right?
14 A. Now, you see, we have gone over this.
15 Q. Yes or no, sir.
16 A. I'm sorry. I have to say, we have gone over
17 specifically all of my income, how much I made, when it
18 was. And then for you to say that, I mean, why am I here?
19 Why am I even talking if you're going to mischaracterize
20 what happened.
21 Q. Mr. Prince, when you were facing -- when you had
22 these conversations in March or April of this year, was
23 your income sources going away because there was going to
24 be no more funding, there was going to be no more Minton
25 money, there's no more Stacy money, there's no more LMT

1 money. You're broke. You've got nobody to pay you
2 anymore. Isn't that right?
3 A. You know what? Like I testified to yesterday, I
4 would rather lay in the street and piss as a pauper than to
5 be paid as a king to lie and help your client destroy or
6 hurt one more person in this world.
7 Q. Got you.
8 THE COURT: That's real commendable,
9 Mr. Prince, but it doesn't answer the question,
10 okay? So try to listen to the question, answer
11 the question. All right?
13 Q. Mr. Prince, you were facing the end of this
14 financial assistance, if I can call it, that you had been
15 experiencing since 1998 or 1999 in connection with the Lisa
16 McPherson case; weren't you?
17 A. I think you're falsely characterizing financial
18 assistance. Is it financial assistance when you get hired
19 as a lawyer to represent someone?
20 THE COURT: Your Honor, can I ask -- I think
21 this witness needs to be reminded again about your
22 instructions.
23 THE COURT: We can just banter about words if
24 you want; but in the end, we're just going to
25 drag this out, and sooner or later the
1 information is going to come out.
2 So all you need to do is answer the
3 question, okay? Don't worry about how he
4 characterized it. Just answer the question.
5 THE WITNESS: Okay. The question is, I'm
6 a professional at what I do.
7 THE COURT: No. The question is this:
8 All the money you got from the time you got
9 down here came from the Lisa McPherson-related
10 matters, correct?
11 THE WITNESS: The answer is no.
12 THE COURT: Okay.
14 Q. Other than the money you testified you got from
15 Mr. Leipold.
16 THE COURT: Other than you testified to this
17 guy out in California.
18 MR. ROSEN: Right?
19 THE WITNESS: The answer to the question
20 is still no.
21 THE COURT: Okay. We've got to start over
22 again.
24 Q. Where else did you receive money from the time you
25 got involved in the McPherson case other than in connection
1 with the case?
2 A. Let's go through it.
3 Q. There's Dandar, Minton, Brooks, LMT and the lawyer
4 in California, Leipold.
5 Did you get any other money from any other
6 source since being involved in this case?
7 A. And the art stuff, as I testified to earlier.
8 Q. Was the art stuff here in Clearwater?
9 A. No. You said since being involved in this case,
10 okay? And, see, this is how it gets confusing, you see.
11 THE COURT: No, it's not confusing. Let's make
12 it the last three years.
13 THE WITNESS: Okay. Good.
14 THE COURT: The last three years.
15 THE WITNESS: The last three years, I have
16 derived income from my art dealership business,
17 from doing legal work in the Wollersheim case
18 as an expert, doing legal work in the Lisa
19 McPherson case as an expert and working at the
20 Lisa McPherson Trust.
22 Q. Okay. So in the last three years, meaning between
23 1999 and 2002, you have received income from your art
24 business?
25 A. I guess I'm just not understanding this.
1 THE COURT: Well, that's easy enough.
2 In the last three years, have you received
3 any income from your art business?
4 THE WITNESS: Yes. Didn't I just say
5 that?
6 THE COURT: Well, I don't know, but you
7 said you didn't understand.
8 THE WITNESS: I don't. How can I say the
9 same thing over and over -­
10 THE COURT: I don't know. Just answer the
11 damn question, okay?
12 THE WITNESS: I'm trying, Your Honor.
13 THE COURT: Try a little harder.
14 THE WITNESS: I will.
16 Q. Are you still operating your art business as you
17 sit here today?
18 A. No.
19 Q. When did you stop operating it?
20 A. I think the last monies that I received from that
21 business was sometime late 1999.
22 Q. Okay. Since late 1999 to today, other than
23 Dandar, Minton, Brooks, LMT and Mr. Leipold, did you
24 receive money from any other source?
25 A. No.

1 Q. Okay. Now, Mr. Dandar made a point yesterday to
2 bring out from you that you are a resident of Clearwater,
3 Pinellas County, right?
4 A. Correct.
5 Q. You own a house here, right?
6 A. I mortgage a house, yes. I have a mortgage on a
7 house.
8 Q. You mortgage your house?
9 A. I have a mortgage on a house.
10 Q. No. I said you own a house here, right?
11 A. Yes.
12 Q. Okay. When did you move down here?
13 A. I think it was about the 24th or 25th of February
14 2000.
15 Q. And when you bought a house here, were you
16 required to put down a down payment?
17 A. Yes.
18 Q. Where did you get the money?
19 A. Part of it I got from Bob Minton.
20 Q. How much was the down payment?
21 A. $70,000.
22 Q. How much of it did you get from Mr. Minton?
23 A. $50,000.
24 Q. Where was the $20,000
25 A. My money.
1 Q. Huh?
2 A. My money.
3 Q. From your art business?
4 A. Oh, God. You know, I would have to go back and do,
5 accounting. You know, people save money. They accumulate
6 money over a period of time. You know, I don't know what
7 to tell you, Mr. Rosen, besides the fact that it was my
8 money.
9 Q. Okay. So let's see if I understand this. You've
10 been living here since about two and a half years now in
11 Pinellas County?
12 A. I've been living here since the 24th or 25th of
13 February 2000.
14 Q. Yeah, about two and a half years. Okay.
15 A. Thank you.
16 Q. Sorry, I won't make you add.
17 Okay. And you like it here. You like living
18 in Pinellas, right?
19 A. I hate it.
20 Q. You hate it. When did you put your house up for
21 sale?
22 A. Summer -- this summer, I did.
23 Q. Midsummer of 2001, right?
24 A. No, no. You're right.
25 Q. Yeah, I know.

1 A. I put it up for sale in October, I think maybe
2 around October or November of 2001.
3 Q. You put it up for sale when Mr. Minton shut down
4 LMT last fall, right?
5 A. You know, I answered your question. You know, if
6 you want to keep doing this, okay; but I've answered the
7 question. I don't know what else to say. I put it up for
8 sale. I made a contract sometime in October or November of
9 2001, okay? That's what I did.
10 Q. Is the reason you put it up for sale because
11 Mr. Minton was closing down LMT and your income was going
12 away?
13 A. The reason I put the house up for sale is because,
14 yes, my employment was through. It was over.
15 Q. Okay. All right. Let's go on, sir.
16 You testified yesterday that in a meeting you
17 had with Mr. Minton in 2002, you reminded him of a
18 conversation you and he and Ms. Brooks had in April or May
19 of 2000 on the roof, on the garage roof across from LMT.
20 And in this conversation in 2002 you reminded
21 him, hey, we had this conversation in April or May of 2000
22 on the roof, and then you related that you had told him
23 that there was discussion at that time about there was
24 money coming in for the case from Europe.
25 Is that a fair summary of what your testimony

1 was yesterday?
2 A. See, this is why I have a hard time answering your
3 question.
4 Q. How about just answering my questions.
5 A. I can't. You tell a story. There's so many
6 questions connected with it, I don't know what to answer.
7 Can you ask me a simple question? I swear to God I will
8 answer it. And I'll work real hard, just like I've been
9 instructed to by the Court.
10 Q. I'm going to take this one part at a time. You
11 testified you had a meeting with Mr. Minton and Ms. Brooks
12 on the top of the roof on the garage structure, right?
13 A. Correct.
14 Q. In March of 2002 or in April?
15 A. No, no, 2000.
16 Q. No. Sorry.
17 You had a conversation in March or April of
18 2002 with Minton and Brooks, right?
19 A. About?
20 Q. In which you said, "Don't you remember the
21 conversation we had in April or May of 2000?"
22 A. Yes.
23 Q. Okay. And the conversation you were referring to
24 in April or May of 2000 that you're reminding him about in
25 2002 is the conversation that occurred up on the roof of
1 the garage across from LMT, right?
2 A. Correct.
3 Q. And you reminded them, in that conversation of
4 April or May of 2002, that Mr. Minton had said something to
5 the effect of there will be money coming in from friends in
6 Europe or something like that. Did you say that?
7 A. Yes, something about money coming in from people
8 in Europe, yes.
9 Q. Okay. Now, your affidavit, sir -- withdraw that.
10 Before you provided that testimony, did you
11 talk to Mr. Dandar or anyone on his behalf on the subject
12 of changing the date of a conversation to back-date it to
13 May or April of 2000?
14 A. No, I did not.
15 Q. So when you gave that testimony here and when you
16 told Mr. Minton, "Let me remind you about that conversation
17 in April or May, money coming in, rooftop," et cetera, you
18 had not discussed this with Mr. Dandar, right?
19 A. See, I got confused. I got confused. I was
20 trying to follow it.
21 Q. When you had the conversation with Mr. Minton in
22 which you were reminding him about the meeting in April or
23 May of 2000 on the top of the garage, you had not had any
24 conversation with Mr. Dandar about that subject; had you?
25 A. I don't recall.
1 Q.You don't recall. Okay. Well, let me refresh
2 your recollection. You testified a few moments ago that
3 you didn't have any conversation with Mr. Dandar until the
4 14th of April.
5 Does that help refresh your memory?
6 A. Correct, yes.
7 Q. Okay. So when you were having this conversation
8 with Minton and Brooks reminding them about the
9 conversation you had in April and May of 2002 on the roof,
10 you hadn't spoken to Mr. Dandar?
11 A. That is correct.
12 Q. And he hadn't told you to manufacture a story to
13 cover the event of a Swiss bank check for $500,000 which
14 happened to be in May of 2000. That's not what happened,
15 right, Mr. Prince?
16 A. Mr. Dandar has never, asked me to manufacture
17 anything.
18 Q. Okay. So when you testified to this, you weren't
19 trying to tailor your testimony based on the fact that a
20 Swiss bank check was delivered to Mr. Dandar in May of
21 2000. You weren't trying to do that, right?
22 A. You know, I got confused because you lost me
23 there.
24 But, you know, when I gave that testimony or
25 when I did the affidavit and stuff about that, you know, I

1 spoke in the room with them in May of 2002. This was one
2 of the issues that came up that they wanted me to even lie
3 about.
4 And I said, well, how can I say this when this
5 other thing happened when we were all on the roof? Now,
6 how am I going to now say that Ken knew about this check,
7 that Ken, you know, was getting this check and we were all
8 keeping it, how can I say that when what happened when we
9 were all sitting there was this.
10 So I was asking him, please tell me how to
11 reconcile this new thing you're telling me to say on
12 Scientology's behalf to make the case go away as opposed to
13 what actually happened on the roof, which is what I
14 testified to.
15 MR. ROSEN: Mr. Dandar, do you have a copy
16 of Defendant's Exhibit 7 for the witness? I
17 have my copy.
18 THE COURT: What's that, the affidavit?
19 MR. ROSEN: This affidavit. Do you have a
20 copy, Your Honor?
21 THE COURT: I think I do.
22 MR. ROSEN: May I approach, Your Honor?
23 THE COURT: Yeah.
25 Q. Okay, Mr. Prince. Let me give you a copy of what

1 was marked for identification as Defendant's Exhibit 7.
2 Can I direct your attention, please, to Page 11.
3 A. Okay.
4 Q. Now, here you are describing this -- actually the
5 bottom of Page 10 and going on to 11 -- you're describing
6 this 2002 meeting with Mr. Minton and Ms. Brooks, right?
7 And it is in that meeting that you say,
8 starting on Line 2, in this meeting in 2002, "I reminded
9 them of an incident."
10 A. Uh-huh. (Affirmative.)
11 Q. Do you see that?
12 A. Yes, I do.
13 THE COURT: What line was that?
14 MR. ROSEN: Line 2, Your Honor, on Page
15 11.
16 THE WITNESS: Yes. This is a
17 typographical error. .
19 Q. So here you are talking about a conversation you
20 had with Minton and Brooks sometime in 2002, and you're
21 relating the conversation. And what you had said to them
22 in this conversation is you reminded them of an incident
23 that happened in August of 'O1.
24 A. Yeah, that was a typographical error.
25 Q. Wait a minute.I didn't ask you that.
1 A. Oh, okay. I will save you a lot of time.
2 Q. See, there was a Swiss check in May of 2000, but
3 there weren't any Swiss checks in August of 2001 at all.
4 So you just made a mistake, typographical, when you said
5 August 2001; is that your testimony?
6 A. Yes, it is, Mr. Rosen.
7 Q. Well, let's see if I understand this. You typed
8 this yourself, right?
9 A. Yes.
10 Q. So you actually made two mistakes, two
11 typographical errors. First of all, in the year. It was
12 2000, not 2001, right? That's what you're telling me.
13 A. 2000, that's correct.
14 Q. Of course, the second mistake you made is this
15 says August.
16 So do you want to tell me -- explain to the
17 Judge how you could be sitting at a typewriter fixing to
18 type the word April or, quote, May, and somehow your hands
19 get all fumbled up and it comes out August. Is that a
20 typographical error?
21 A. Again, Mr. Rosen, you know, I can't speak on the
22 grandstanding aspect of what you're asking me, but what I
23 can say is -­
24 Q. Is August a typographical error?
25 A. What I can say is I wrote this from the best
1 recollection that I had from the best memory that I had.
2 THE COURT: Okay. So your recollection at the
3 time you wrote it was August.of 2001.
4 THE WITNESS: No. It was August of 2000;
5 2001 is a typographical error. I know it
6 wasn't -­
7 THE COURT: So you just hit the one
8 instead of a zero?
9 THE WITNESS: Correct.
10 THE COURT: Okay.
11 THE WITNESS: And I thought it was August.
12 It wasn't. It was May. Okay.
14 Q. This affidavit is signed May 1, 2002, right?
15 A. I believe you.
16 Q. Turn to the signature page, May 1, 2002.
17 A. Yes.
18 Q. Now, you typed this affidavit in Mr. Dandar's
19 office; didn't you?
20 A. For the most part, yes.
21 Q. And you did it yourself. You didn't get any help
22 from Donna or Mr. Dandar?
23 A. Well, you know,.Donna put it on the paper
24 that -- you know, by paragraph.
25 Q. Now, was Mr. Dandar present kind of helping you to
1 remember events as you typed this?
2 A. No, sir.
3 Q. So you did this all on your own, you sat down at a
4 keyboard in Mr. Dandar's office and with some technical
5 help from Donna, you just whipped out -- you typed up this
6 entire thing.
7 A. Correct.
8 Q. When?
9 A. Oh, God. Come on. It's signed and dated, now.
10 You know, days following -- okay. Four or five days prior
11 to it actually being signed. This was something that I
12 worked on for maybe two or three days.
13 Q. So you worked on it for two or three days, and you
14 finished it five days before it was signed, and it was
15 signed on May 1, right?
16 A. See, you lost me, there. You finished it five days
17 before it was signed? You know, what sense does that make?
18 What are you saying, you know?
19 MR. ROSEN: Judge, this testimony should
20 just be stricken.
21 THE COURT: Let's just move on. Ask
22 another question.
24 Q. The signature date is May 1, right?
25 A. Correct.
Q. When was it that you typed it?
A. A day or two or three before May 1.
Q. Okay. So it was the end of April. And how long did it take you? Was it over one day, t,wo days, three days, that you sat in Mr. Dandar's office and typed this?
MR. DANDAR: Asked and answered.
THE-COURT: Overruled. How many days did it take you to write this?
THE WITNESS: As I said, two or three days prior to me signing it.
THE COURT: Okay. Two or three days.
Q. Okay. And all of this time that you're sitting in Mr. Dandar's office for two or three days typing this affidavit, Mr. Dandar is not. around? Is that right?
A. Yes, he's around. He's in his office. I'm in the conference room.
Q. But you never had any discussions with him as you're sitting there typing this affidavit for three days, right?
A. I don't know what you mean by discussions. I mean, that's too generic.
Q. About the content of the affidavit.
A. I discussed with him the fact that I was doing an affidavit, what this affidavit clearly is about are the
1 blackmail meetings about, you know, being brought into the
2 loop.
3 I mean, this is what this whole thing is
4 clearly about. So from the best of my recollection, I am
5 writing because I'm getting daily phone calls from Bob
6 Minton and Stacy Brooks, and they're telling me what's
7 going on. And from memory, I sat and composed this
8 document.
9 Q. Well, let's see. You sat down two or three days
10 before, so somewhere around -- I'm not going to hold you to
11 the exact date -- somewhere around April 27th is when you
12 sat down in Mr. Dandar's office and started the task of
13 typing this affidavit, okay?
14 Now, you're relating events that occurred a
15 month before. Were you typing it from memory or did you
16 have any notes?
17 A. Well, one note is attached to the affidavit itself
18 and -­
19 Q. Okay. And any other notes that you -­
20 A. Could I finish? You've got to stop this. You
21 asked me a question and you don't let me answer it. I said
22 one is this. One is on the back page. And there's others.
23 Now, can I answer the question or not?
24 Q. Did you have any other notes available to you when
25 you typed this -- other than what's attached to
this -- that you had when you typed this affidavit in Mr. Dandar's office at the end of April?
A. Yes, I did.
Q. What other notes did you have?
A. I had started writing down the dates, you know, just making a minor notation like date of phone call or something like that. You know, like the yellow pads that are sitting on every attorney's desk? I mean, that was kind of something that was there as well. You know, I had a calendar, and I looked at the calendar and this kind of thing and, you know, tried to remember what happened.
Q. Mr. Prince, when you sat there in Mr. Dandar's office to begin the process of typing this affidavit, did you have available any notes that you had made at about the time of these conversations in March and April?
A. Not at the time of those conversations, but shortly thereafter.
Q. At the time that you were having these conversations and meetings in March and April with Minton and Brooks, did you make any notes?
A. No.
Q. So that when it comes to around the 27th of April as you're sitting down at the typewriter to relate these events, other than the handwritten thing of April 14th that's attached to this, you had to do this from memory?
A. Correct.
Q. Okay. So you must have a pretty good memory because you were able to recall for us conversations you had in March 28th and -- excuse me -- going back to the beginning of March and February, right? You have a pretty good memory, right, Mr. Prince?
A. See, the grandstanding is going to have to stop, you know. Do I have a good memory? I have a good enough memory. I stand behind my testimony. That's all I can say, Mr. Rosen.
Q. Okay, good. Let's read off of your testimony in your affidavit, Line 2 of the affidavit, still on Page 11.
A. Okay.
Q. "I reminded them of an incident that happened in August of '01 where Bob said the case was costing too much
and Ken had to cut costs: Part of the cost-cutting was not to pay Garko until the case was over."
Do you see that?
A. Yes.
Q. So what you're telling me now and what you're telling this Court under oath is that the discussion about not paying Mr. Garko -- Dr. Garko -- occurred in April or May of 2000.
A. Correct.
Q. Well, sir, you're aware that Mr. Garko continued
1 to get paid through August or September of 2001?
2 A. Not particularly. I mean, I don't know about
3 him -- I have never asked anyone about him getting paid.
4 I'm simply stating what was said on the, garage, okay?
5 This is from Mr. Minton. So, you know, if you
6 want to challenge the veracity of that statement, then ask
7 Mr. Minton. This is what he told me. All I'm doing is
8 saying what he told me. Do you understand?
9 Q. Actually, Mr. Prince, if the date of August '01 is
10 not a typo, then that's precisely with the event of
11 Dr. Garko -­
12 THE COURT: Let's not be argumentative. Just
13 ask him some more questions.
14 MR. ROSEN: Okay.
15 THE WITNESS: Thank you.
17 Q. So it's your testimony, sir, that August '01 -both
18 of that is a typo, the month and the year, and that, in
19 fact, this meeting happened in April or May of 2000 on the
20 rooftop, right?
21 A. Correct. This meeting happened the day -- you
22 know, I can give you an exact date the meeting happened.
23 It was given on the exact date Mr. Minton gave the check to
24 Mr. Dandar. That's the exact date this conversation on the
25 rooftop in the garage happened, the $500,000 check.
1 Q. Okay. How do you know that?
2 A. Because he told me, "I'm going to give Ken a
3 check."
4. I mean, read the affidavit. This is how I know
5 it. This is what it says.
6 Q. So, in other words, on the rooftop, the exact day
7 of that conversation, then, is the day that Mr. Minton said
8 to you, "I'm going to give Dandar a bank check for
9 $500,000," is that right?
10 A. No, it's not right. See, now you're confusing it.
11 No, it's not right.
12 What is right is the day that he had it -- not
13 the date of the check, okay? The day that he gave him the
14 check, okay? There is a distinction, Mr. Rosen. I'm sorry
15 if you're impatient with that, but, you know, that's the
16 exact answer.
17 Q. Mr. Prince, when you're standing on the rooftop
18 that day, Mr. Minton is saying to you, "I am going to give
19 the check, the $500,000 bank check, to Mr. Dandar."
20 "I'm going to do it," right?
21 A. He didn't say a bank check. He said, "Ken is
22 getting $500,000."
23 Q. Is getting, not has gotten, right?
24 A. Right.
25 Q. So, therefore, if the check is dated May 1, would
you agree with me that it can ‘t have been given to him before May 1, right?
A. Oh, please. I don't know. I don't know. You know, all I know is what I've testified to, what I've written, okay? I can't go done these other roads.
Q. And you said a moment ago that on this rooftop, then, Mr. Minton said something that made you understand it was the same day, he was giving the check to Mr. Dandar that very day.
A. Yeah, and that was my understanding, yes.
Q. Right. Well, not that he had given it to him that day but he was going to give it to him that day; is that right?
A. You know, I don't know, Mr. Rosen, you know.
Q. Okay. Is there some reason that you forgot to mention that this money was going to Dandar that same day, you forgot to mention that in your affidavit?
A. You know, what I mentioned in this affidavit --
Q. Did you forget when you typed the affidavit --
A. Forget what?
Q. Did you forget, when you were typing the affidavit, about this?
A. Forget what, Mr. Rosen?
Q. Forget that the conversation on the rooftop occurred on the same day that Mr. Minton was giving
1 Mr. Dandar the $500,000 check, what you just testified to.
2 A. Did I forget that? Is that the question, did I
3 forget that?
4 Q. Yes.
5 A. You know, whether or not that's pertinent
6 obviously was not -­
7 THE COURT: That's not the issue. The question
8 is: Did you forget to put that in your affidavit?
9 THE WITNESS: I can't say I forgot to put it in
10 there because I don't see how it's important. To me, that
11 is not what is important to me. If I would have thought
12 that that was important -­
13 THE COURT: Okay. So you didn't put it in
14 there because it wasn't important.
15 THE WITNESS: Right.
16 THE COURT: Okay.
18 Q. And Mr. Minton said, "And that's all Ken's going
19 to get, $500,000," right? That's what he had said on the
20 rooftop.
21 A. I stand behind this testimony, the thing you gave
22 me --
23 Q. You know, I'm asking you a question. Don't tell
24 me what you stand behind. Is it correct that --
25 A. You're reading it for me and you're saying it says
1 that and I'm saying I stand behind --
2 MR. ROSEN: Your Honor, this is a fiasco.
3 MR. DANDAR: Objection. He's arguing with
4 the witness.
5 THE COURT: The witness is not being
6 responsive.
7 MR. DANDAR: But I would rather that you
8 instruct the witness than Mr. Rosen.
9 THE COURT: I know what you would rather
10 have, but I'm not running the case.
11 MR. DANDAR: He's yelling at the witness.
12 If the witness is out of line, let me object or
13 you instruct him. I don't think Mr. Rosen -­
14 THE COURT: Well, you haven't objected yet
15 if the witness is out of line.
16 MR. DANDAR: Well, I do object to
17 Mr. Rosen -­
18 THE COURT: Yeah, I know. Okay.
20 Q. At no time did Mr. Minton ever tell you that the
21 $500,000 was a check of foreign funds, came from a foreign
22 country?
23 A. He told me that people from Europe, you know, were
24 where the money was coming from. How that money was to
25 appear, whether it was to be a check or whatever, you know
I didn't know. I didn't know those details; therefore, I
didn't report about that when I wrote this. What I
reported was what I thought was important, Mr. Rosen.
Q. So Mr. Minton told you on the rooftop in April or
May of 2000 that he was getting money for Mr. Dandar from
some friends in Europe; is that what he said?
A. People in Europe, correct.
Q. Did he tell you who they were?
A. No.
Q. You said yesterday you traveled to Europe with
Mr. Minton, right?
A. Correct.
Q. How many times?
A. Once, actually.
Q. Did he ever introduce you to any of his friends in
A. Yes .
Q. Who?
A. Jeff Schmidt.
Q. In Germany?
A. No, London.
Q. Did he ever introduce you to any people -- any
conversation about contributing money?
A. I think it was discussed with Mr. Schmidt.
Q. In your presence? He was one of the people that
1 were sending money from Switzerland? Is that it?
2 A. Who was one of the persons you were saying?
3 Q. The gentleman you just identified from London, was
4 he one of the people that he said to you or you heard him
5 say that he was going to contribute money?
6 A. Mr. Minton never said that to me, no.
7 Q. When was it that you visited with him in London?
8 How about starting with the year?
9 A. '99, I believe, '99.
10 Q. Got you. All right. Let's go on with your
11 testimony, sir. Did Mr. Minton ever tell you that he was
12 providing funds to Mr. Dandar from a Swiss account?
13 A. No.
14 Q. Did he ever tell you he was providing funds
15 through a Swiss bank?
1 6 A. No.
17 Q. And he did say that the money was going to come
18 from some friends in Europe, right?
19 A. For the third time, yes.
20 Q. Okay. Well, you know what, for the first time,
21 let me read you your testimony of yesterday, Page 227:
22 Question by Mr. Dandar, "And what did
23 Mr. Minton tell you on the rooftop of this parking garage?"
24 Answer, "He explained to myself and Ms. Brooks
25 they were going to be receiving a check. He did not know
where it came from, and he didn't tell us where it came from, but he said this check -- this check was being given to -- I believe he said, you know, because he said this to me, as well, about people in Europe:"
"As well about," not that money was coming from Europe, but, "as well."
Do you remember testifying to that yesterday?
A. Yes.
Q. So he didn't say anything about this $500,000 coming from Europe, did he?
A. I will state it again. What he said -
Q. Are you going to stand on your testimony? Is that, what you're going to tell me?
A. No, I will answer the question if you will give me an opportunity, Mr. Rosen. He said to me -- and I'm paraphrasing this, okay? I'm paraphrasing it. There was no court reporter there when we had this conversation on the rooftop; therefore, the exact words I don't remember.
But paraphrased, he told us that Mr. Dandar was getting a check. He didn't know where --,Mr. Dandar did not know where the check was coming from. He wasn't telling me or Ms. Brooks where the money was coming from. He just simply said people in Europe, contributors in Europe are doing this.
I know that, you know, Ms. Brooks and

Mr. Minton have mentioned people in Europe. I thought it was Thomas Gandow, a fellow in France that had organized it. I had suspicions about it, but I had no knowledge about it. It was just people in Europe.
I've traveled with Mr. Minton again to Europe, to France, and Ms. Brooks was there. We went to Paris. That's correct. Because we had a case involving Scientology slandering myself, Ms. Brooks and Mr. Minton in France, so we traveled there.
So I'm thinking, you know, you put two and two together, I'm thinking, yeah, okay, these people here.
Q. Okay. Let me move on to something else, Mr. Prince.
It was in March of this year that Mr. Minton first told you that he was going to have conversations with Scientology about settling, getting together, talking, settling, whatever?
A. With Rinder.
Q Huh?
A. With Rinder.
Q. With Rinder.
A. Correct.
Q. When was this that he first told you that?
A. He told me this in March of this year.
Q. When?

1 A. You know, I said it here. Please, let's not do
2 this. You know, I gave it as close a date as I can.
3 Q. You gave us no date. If you gave us a close date,
4 that's one thing. You gave us no date other than March.
5 March has 31 days. Can you give us a hint? Beginning of
6 March? Is it the Ides of March?
7 A. Yes. As a matter of fact, my birthday is the Ides
8 of March, and it was around that period of time.
9 Q. You suddenly remember that?
10 A. Quit your grandstanding, okay? Quit it.
11 MR. DANDAR: Mr. Prince -- objection.
12 THE COURT: Thank you, Mr. Dandar.
14 Q. During the conversations you had all this time
15 starting around your birthday in March and continuing
16 through March and then the conversations in April by phone
17 and then down here in person, all of these things and all
18 of these statements that you say Mr. Minton was making
19 about he has to get Mr. Dandar, he has to end the case, the
20 wrongful death case, not once did you pick up the phone and
21 call Mr. Dandar to advise him to alert him of what was
22 going on; is that right?
23 A. Was that supposed to be a question? You speak for
24 like fifteen minutes
25 Q. Yeah, it's a question.
1 A. Could you ask me a simple question.
2 Q. Yeah. Not once did you pick up the phone prior to
3 April 14th and tell Mr. Dandar what was going on.
4 A. Correct.
5 Q. What made you do it on April 14th?
6 A. Because the first -- Mr. Dandar was not my
7 solution to a remedy to this problem.
8 My first thing was to go to Mr. de Vlaming
9 because , a criminal act had occurred. I went to him and
10 asked him to put me in contact with somebody in the FBI,
11 because I did not think that this was a state matter,
12 because this went from one state -- this at least happened
13 in three states, criminal activity, that it would have to
14 be the FBI that would prosecute it.
15 He then pursued that and spoke to someone in
16 the FBI, and they basically said they weren't interested in
17 the case because Mr. Minton was an admitted perjurer. And
18 if he lied then and then he turns around and says, well,
19 they made me lie, is he still lying now? No one is
20 interested.
21 MR. ROSEN: Your Honor, do you think
22 somewhere in our future I'm going to get an
23 answer to this question?
24 THE COURT: I have no idea.
25 MR. ROSEN: I don't think I'm going to get

1 one unless we focus the witness and maybe
2 remind him of the alternative.
3 THE COURT: Well, let's try it again.
4 What was the question?
6 Q. The question was: Throughout all of this time,
7 why did you not advise Mr. Dandar before the 14th of April?
8 A. Now, that's the question, Your Honor. He asked me
9 why, and then I answered it, and then I'm being
10 unresponsive.
11 THE COURT: He answered it. He went to the
12 FBI.
13 THE WITNESS: Yeah, I went to the FBI first.
15 Q. All right. Now on the 14th of April, you did
16 contact Mr. Dandar, right?
17 A. Correct.
18 Q. Why did you contact him at that time? What
19 happened then --
20 A. What happened then is that
21 Q. -- that made you do that?
22 A. Mr. De Vlaming told me that the person he spoke to
23 in the FBI was not particularly interested in the case
24 because, as I was saying, Mr. Minton, if he's already
25 perjured himself and then he's lying and then he starts
1 lying about lying, you know, they said that -- the way it
2 was explained to me was what jury even wants to hear about
3 a person that lies to one side and then the next over and
4 over and over. It wasn't a good case. So -- let me finish
5 because, you know, this is going to save you some time.
6 So because the FBI couldn't do it, then I
7 thought, well, it's not going to happen statewide. The
8 only other person that can do something about this, the
9 only other person that has an opportunity to put this in
10 front of some judge or some court is Mr. Dandar.
11 Q. Okay, now I got it. So you went to Dennis, he
12 said it's not a federal matter, and now you don't know
13 where to go. It's a state matter. So the only one who can
14 take care of it is Mr. Dandar. That's why you went to him
15 on the 14th of April, right?
16 A. No, that's not why I went to him. I went to him
17 because he was being affected by it.
18 Q. He was being affected before the 14th of April;
19 wasn't he?
20 A. What do you mean by affected?
21 Q. Well, do you know something, Mr. Prince? I mean
22 what you mean by it. You just used the word.
23 A. Okay. Yes, he was being, but you know
24 what -- okay. And now we're getting somewhere. You're
25 right. You're right. Do you want to know why I didn't
1 tell Mr. Dandar?
2 Q. I'm waiting with baited breath.
3 THE COURT: You have already said one reason
4 why. Is there another one?
5 THE WITNESS: This is another reason, okay, and
6 let's stop the clowning. Let me talk, okay? Because this
7 is my turn. I'm on the stand.
8 I put my house up for sale in October or
9 November of 2001. I wanted to leave this crappy town. You
10 know what, I hate this place. You know what, I was
11 through -­
13 Q: Pinellas County? You hate it? Oh.
14 A. Excuse me. Let me talk. I'm on the stand. I
15 wanted to leave. I wanted nothing more to do with the
16 wrongful death case, I wanted nothing more to do with
17 being an activist or helping people concerning Scientology.
18 I wanted nothing to do with it anymore.
19 But you know what? That wasn't good enough for
20 your client. We had to get the fair game going. We had to
21 do the blackmail. And now it just put me right back into
22 it, and I'm literally forced to do this.
23 I don't want to do this. I don't want to sit
24 here and be subjected to, you know, donkeys asking me
25 questions over and over and over. I don't want this.

1 Q. Mr. Prince, let's see if perhaps we can cut
2 through this and be a little candid.
3 You're not being forced to do this, Mr. Prince,
4 this is why you're doing it. Four grand, man. That's why
5 you're doing it. Isn't that true?
6 A. No, it's not.
7 Q. Mr. Prince, how much walking-around money you got
8 in your pocket today?
9 MR. DANDAR: Objection. That's a humiliating
10 question.
11 11 THE COURT: Is that the objection?
12 MR. DANDAR: And it's irrelevant.
13 THE COURT: Overruled.
15 Q. Can you answer my question?
16 A. I don't know.
17 Q. Could you look?
18 A. No, I don't want to. It's not your business.
19 Q. Okay. I don't really care how much.
20 A. Okay. Then why are you asking me about it?
21 Q. I just want to know if $4,000 is a significant
22 amount of money to a man of your means, Mr. Prince. Is it
23 significant?
24 A. Okay. Let's go on.
25 THE COURT REPORTER: Before we do that, Your
1 Honor -­
3 Q. You testified yesterday to a series of
4 conversations you had in which you were being told by
5 Mr Minton -­
6 A. She doesn't have any paper in her thing. She's
7 trying to tell you.
8 MR. ROSEN: Is that what you're trying to
9 tell me?
10 THE COURT REPORTER: Yeah, I need to take
11 a quick break.
12 MR. ROSEN: Okay.
13 MR. DANDAR: Good time for a lunch break.
14 MR. ROSEN: I've got about 15 more
15 minutes.
16 THE COURT: Is that what you've got?
17 MR. ROSEN: Other than heartburn?
18 THE COURT REPORTER: Go ahead, I'm ready.
20 Q. Is $4,000 a lot of money for you, Mr. Prince.
21 A. I thought we were going to move on to something
22 else in this case.
23 Q. Yeah, let's move on.
24 So now you've relayed these various
25 conversations in which Mr. Minton and/or Ms. Brooks are
basically telling you what's been going on in the discussions with Scientology, right, a series of conversations in meetings, right? Right?
A. Yeah, go on.
Q. And one of the things you testified to yesterday was that Mr. Minton had showed you this complaint that he had just been served with where he was made a defendant in the Armstrong case in California, he showed it to you, there it was, he was being sued for 80 million dollars, right?
A. I think when you totaled all of the -- you know, there's a dollar amount to each time Mr. Armstrong --
Q. I'm not talking about the meeting in March. I'm talking about --
A. What are you talking about a meeting now? You asked me about a specific document, and I'm trying to comment about that, and then you start talking about a ­meeting, man. Do you need lunch? Are you getting sick? Are you light-headed?
Q. Mr. Prince, did Mr. Minton show you a copy of the Armstrong complaint you had been served with?
A. Yes.
Q. When was that?
A. This was when they were at the Harbor Bay Hotel in Tampa. He showed it to myself, he showed it to another LMT
1 staff member.
2 Q. And he show you that that complaint, in which he
3 was now named as a defendant, in addition to Mr. Armstrong,
4 was asking for 80 million dollars against him, right?
5 A. What the Complaint had in there -- what Mr. Minton
6 said is after he added up all of the violations, because
7 the Complaint itself alleges certain violations that
8 Mr. Armstrong made concerning his contract with the Church
9 of Scientology in the settlement agreement. And every time
10 that he violated that agreement, it had a specific dollar
11 amount.
12 And Mr. Minton estimated that given the charges
13 and allegations in the Complaint itself and the value -- or
14 the dollar amount of the value each time there was a breach
15 of that contract, roughly came to about 80 million dollars.
16 That's what he said.
17 Q. 80 million.
18 A. Yes.
19 Q. Didn't you testify yesterday that Mr. Minton not
20 only showed you the Armstrong complaint but said, "Look at
21 it, they're suing me for 80 million dollars."
22 Didn't you say that yesterday?
23 A. In paraphrasing essence, and I'm saying the same
24 thing today. How is it different what I'm saying today?
25 Q. Okay. Well, then, if the Armstrong complaint

1 doesn't claim 80 million dollars, would you be able to tell
2 us why you made that mistake? We're getting the complaint,
3 by the way.
4 MR. DANDAR: Objection. He didn't make a
5 mistake. He's only telling the Court what
6 Mr. Minton told him.
7 THE WITNESS: Thank you. That's exactly
8 it.
10 Q. I will withdraw the question for a moment. Did
11 Mr. Minton show you a copy two inches thick, according to
12 your testimony, of the draft RICO complaint given to him?
13 A. Yes.
14 Q. And you read it?
15 A. No.
16 Q. Well, did he show it to you in a way that you
17 could see what was on it?
18 A. It never left his hand. He had it like this. He
19 did it like this. (Indicating.) .
20 Q. Without leaving his hand, he could hold this up
21 and you can see the front page, right?
22 A. Right.
23 Q. What was on the front page of the document? What
24 did it say, RICO?
25 A. I don't recall. He just said, hey, here's a RICO

1 suit that they're suing me for. He held up the paper and
2 then he too this and he said, "Look, look at this thing,"
3 you know, and he says, "At the end of it, this one asks for
4 110 million dollars. So let's see. That's 80 million.
5 That's 110 million. They're already into me for over 200
6 million. I'm the only person sitting here with money. Who
7 do you think is going to be responsible? They're also
8 adding me on as a defendant in the breach of contract case.
9 It's never going to stop."
10 Q. Mr. Prince, when he showed that to you, when he
11 held it up, that RICO complaint, were you able to see that
12 it was in the form of a court pleading, you know, like a
13 caption, just like some of these papers before you? Was
14 there a caption on it?
15 A. Yes.
16 Q. Yeah. And who was the Plaintiff? I forget.
17 A. Well, you know, as I said, he had it in his hand.
18 He didn't show me the whole thing.
19 Q. I'll tell you what, I don't want the whole thing.
20 You tell me, as you're holding it right there, so the Judge
21 can see, you tell me what it is that you saw on that first
22 page?
23 A. I saw something that looked like;
24 Q. Tell us if it was the court, tell us the name of
25 the plaintiff. Tell us anything you remember about that
1 first page?
2 A. I saw something that looked like a complaint that
3 he held up and showed -- held in his hand and spoke about.
4 Q. Mr. Prince, you know -- ', `
5 A. Why don't you ask Ms. Brooks this question.
6 Q. You know, I'm asking you the questions, sir.
7 Today you tell us that you didn't have it, he
8 just held it for you to see, yet in your affidavit you
9 testified that, "He gave it to me."
10 A. I don't think so.
11 Q. No? Okay.
12 This is your affidavit that's Exhibit 7. Let's
13 look --
14 A. I think it says that he showed me a RICO suit.
15 Q. Let's look at Page 10, Mr. Prince.
1 6 A. Okay.
17 Q. Let's look at Lines 6, 7, 8.
18 "He pulled out a stack of paper at least two
19 inches thick and gave it to me. What he had given me was a
20 RICO suit."
21 Now, what is it, Mr. Prince? Are we ever going
22 to get the truth out of you, sir?
23 MR. DANDAR: Objection, move to strike.
24 THE WITNESS: You know, I object to that.
25 This is outrageous. You know, Mr. Minton gave
1 me a copy of the Armstrong suit: He had a copy
2 of the RICO suit. We sat there like -- we were
3 sitting at a table.
4 THE COURT: Let me ask you something.
5 Just hold it just a second here. Okay?
7 THE COURT: This affidavit says, "What he
8 had given me was a RICO suit Scientology had
9 put together that named him as a defendant."
10 Is that a true statement?
11 THE WITNESS: Yes, Your Honor, it is.
12 THE COURT: Okay. At the end of the suit
13 it asks for 110 million dollars' damages.
14 THE WITNESS: Yes, Your Honor.
15 THE COURT: So that's a true statement.
16 He gave it to you?
17 THE WITNESS: Yes, Your Honor.­
18 THE COURT: He gave it to you and you
19 looked at it and it said 110 million dollars.
20 THE WITNESS: I didn't see that it said
21 that. These were words coming from him, Your
22 Honor. And I'm trying to explain to you how it
23 happened. We were sitting at like a coffee
24 table and -­
25 THE COURT: Okay. So when it says that he


1 gave it to me and it asked for 110, that isn't
2 true, then. What is true is he told you it was
3 110; is that right?
4 THE WITNESS: What is true is this. What
5 is true is what is written right there.
6 THE COURT: Oh, okay.
7 THE WITNESS: Because we sat at the table.
8 He had it like this. I'm sitting next to him
9 like this. We're both looking at this thing
10 and he's flipping through it.
11 And to be quite honest with you, my
12 concern was whether my name was on it. I
13 wanted to know if I was getting sued in RICO,
14 and he told me no.
15 THE COURT: Well, did you see your name
16 when he gave it to you?
17 THE WITNESS: No, I didn't see any other
18 the names on there.
20 Q. What names did you see? You were looking in the
21 caption to see if your name was there. Well, you saw your
22 name was not there. What names did you see there?
23 A. I was in shock that there was -­
24 Q. Hold it. I asked you a question, sir.
25 A, I don't recall.
1 Q. You don't remember, okay. So let's see.
2 So now we've got one possibility that you
3 testified to and swore is true is that he never gave it to
4 you; he just held it and you didn't read it.
5 Possibility number two, according to this
6 affidavit, is, quote -­
7 A. The thing is this -­
8 Q. -- quote, and gave it to me. And now possibility
9 number 3 in response to the Judge's question is, he held
10 it, we held it, we read it together.
11 A. You know, how long did he give it to me? Like
12 maybe a second. You know, he slammed it on the table,
13 "Look at this," you know.
14 Q. He slammed it?
15 A. Yes.
16 Q. I thought he held it up, Mr. Prince?
17 A. He said, "And look at this, what they've got on
18 me."
19 And then I said, "What is this?"
20 - "A RICO suit."
21 And then he grabs it, "Here, let me show you."
22 And we sat down and we went through it. Look,
23 let's not play games here, Mr. Rosen, okay?
24 What happened is your client blackmailed him,
25 okay, and you can try to make that my fault and you can try

1 to say I'm not credible. But you know what? You're the
2 criminal. Your client is the criminal here; not me.
3 Q. Good. Okay. Now, let's go over your testimony
4 from yesterday.
5 THE COURT: That sure clears it up for me. I
6 don't know if we need anything else.
8 Q. I do need to ask one more thing on a personal
9 note. We do have this little problem, and that is, you
10 testified that Mr. Minton told you that he and Rosen -- he
11 was meeting with Rinder and Rosen and Yingling; he had met
12 with them down here in Florida, right?
13 Did he tell you that?
14 A. I think -­
15 Q. Don't look at the affidavit.
16 A. Look, don't you tell me what to do, okay? You're
17 not here to tell me that. You don't tell me, "Don't do
18 this."
19 You can ask questions -­
20 Q. You're lucky I don't have the gavel, Mr. Prince,
21 because you'd be enjoying the pleasure of county food.
22 A. If I had the gavel, you'd be in federal prison.
23 MR. DANDAR: Time out. Time out.
24 THE COURT: All right.
1 Q. Mr. Prince, come on. Let's get done with this.
2 A. Yeah, please.
3 Q. So your testimony is Mr. Minton told you that he
4 was down here in Florida -- we're not talking about the
5 meetings in New York, but in April -- and he had been
6 meeting with me and Yingling and Rinder; yes or no?
7 A. I testified to the fact that he was meeting with
8 Ms. Yingling and Mr. Rinder. I know that Mrs. Yingling was
9 there. I don't know -- you know, I specifically remember
10 about you in New York.
11 Q. He said he was meeting with me down here?
12 A. He did?
13 Q. Yeah, okay.
14 A. No, I'm asking. Did he say that?
15 Q. And, in fact, one of those places that you
16 testified about this yesterday at Page 260, starting on
17 Line 20, "He," Mr. Rinder --excuse me -­
18 Mr. Minton -- "Informed me of at least three meetings he
19 had with Rosen, Rinder and Yingling with no attorneys
20 present."
21 A. Correct.
22 Q. He told you about that. Those are down here in
23 Florida, right?
24 He's having three meetings with me, Yingling
25 and Rinder down here in Florida, and there were no
attorneys. Mr. Minton doesn't have any attorneys present.
He told you that. You swore to it yesterday, right?
A. Where's it at? Let me see it.
Q. If I show it to you, then you admit it? And if I don't --
A. No, because, you know, this Boston Harvard education that you think you have, how you can like trick people with words and admit things that didn't happen, just show me my testimony.
Q. Can I ask you a question? How do you know about my education?
A. Maybe I don't. I just assumed that. It's just an assumption, Mr. Rosen.
Q. You just made a statement about Boston. How do you know about my education?
A. If you have testimony that you want me to look at --
Q. How do you know about where I went to school?
A. You know, I guess I just got a little bit of Dionne Warwick in me; don't I? I just got the psychic hotline going here. Hey, it was just something that I said, okay?
Q. Let me see if I can help refresh your recollection, since the first time Mr. Dandar would ever have learned about my background was on the witness stand

1 here yesterday while you were being sequestered, does that
2 help refresh your memory as to how you learned about my
3 education?
4 A. Did you go to Harvard? I mean, I just said that.
5 Q. Okay.
6 A. Psychic hotline. We're in sync, Mr. Rosen.
7 Q. Okay. So let's see if we've got this right.
8 THE COURT: Mr. Rosen, your 15 minutes are up.
9 I'm just wondering if this is the last question
10 or next to the last.
11 MR. ROSEN: It's the next to the last. I
12 promise.
13 THE COURT: All right.
15 Q. So Mr. Minton tells you that he was meeting with
16 Rinder, Yingling and Rosen down here in Florida three
17 times, no attorney present for Mr. Minton. So help me-out.
18 I forgot. Where did I meet with him?
19 A. Show me the testimony you're referring to.
20 Q. And that will help you remember where I met with
21 him?
22 A. No. It will make it clear that you're fabricating
23 and making it up as you go along. If you say I said that,
24 show it to me. Show me where I said, you know, all of
25 these --
1 THE COURT: Mr. Prince, look. Maybe you have
2 lost track of what we're doing here. He's
3 asking you a question about your recollection.
5 THE COURT: Okay? All you have to do is
6 answer it. Either you recall it or you don't
7 or you can tell him what you recall.
8 THE WITNESS: I don't recall it.
9 MR. ROSEN: You testified to it yesterday.
10 You don't remember it?
11 THE WITNESS: So you want to challenge me
12 on what I recall.
13 MR. ROSEN: Your Honor, it is my pleasure
14 to pass the witness.
15 THE COURT: All right. Do you have some
16 more you want to ask this witness?
17 MR. DANDAR: Yes, I do.
18 THE COURT: Is it going to be extensive?
19 MR. DANDAR: It's going to be about 15 to
20 20 questions.
21 THE COURT: Well, that's another two or
22 three hours.
23 MR. DANDAR: I hope not.
24 THE COURT: So we'll come back after
25 lunch.
1 MR. DANDAR: What time?
2 THE COURT: I would say about 1:15. Okay?
3 MR. ROSEN: Is this witness going to be
4 instructed not to talk to anyone?
5 Well, you know what, what's the
6 difference?
7 THE COURT: Yeah. You're not to discuss
8 your testimony with anybody. Do you understand
9 that?
11 THE COURT: Okay. Good. He understands
13 (Thereupon, the lunch recess was held and
14 this transcript continues to Volume IV.)

6 I, Susan M. Valsecchi, Registered Professional
7 Reporter, in and for the Sixth Judicial Circuit, State of
8 Florida:
9 DO HEREBY CERTIFY that I was authorized to and
10 did stenographically report the foregoing proceedings and
11 that the transcript is a true and complete record of my
12 stenographic notes.
13 DATED this 1st day of , 2002, at
14 Clearwater, Pinellas County, Florida.
18 Susan M. Valsecchi, RPR
19 Registered Professional Reporter



VS. CASE NO. 00-002750-CI-20

DELL LIEBREICH, individually and
as Personal Representative of
the Estate of Lisa McPherson,


BEFORE: The Honorable W. Douglas Baird
Circuit Judge
PLACE: 315 Court Street
Clearwater, Florida

DATE: August 29 - August 30, 2002

REPORTED BY: Susan M. Valsecchi, RPR
Registered Professional Court Reporter
Sixth Judicial Circuit



Pages 469 - 519 (Excluding Index.)

(727) 443-0992

Post Office Box 1368
4 Clearwater, Florida 33757 .
(727) 461-1818
Attorney for Plaintiff
8 600 Peachtree Street, NE, Suite 2400
Atlanta, Georgia 30308-2222
Attorney for Witness Samuel Rosen
P.O. Box 24597
13 Tampa, Florida 33623
14 Attorney for Dell Liebreich
16 442 W. Kennedy Boulevard, Suite 280
Tampa, Florida 33606
Attorney for Witness Michael Garko















(Thereupon, this transcript continues directly from Volume III.)
MR. ROSEN: I'm reminded once again I fell down on my duties and did not formally offer into evidence 187a, which is the video that we played, 191, 192, and there was one other one that I gave to Mr. Prince during his examination.
MR. ROSEN: 169. And 163 also, the criminal record from Illinois. I offer those into evidence.
MR. DANDAR: The criminal record is not properly authenticated.
MR. ROSEN: It's certified.
MR. DANDAR: Is it? I don't see the certification on it.
MR. ROSEN: I'm sorry. It's an exhibit to the deposition of Mr. Prince previously or previously identified.
MR. DANDAR: It wasn't previously identified there either.
THE COURT: Well, he admitted to it, though.

1 MR. DANDAR: He admitted to this document.
2 He didn't admit to any previous charges.
3 THE COURT: He did in the previous
4 deposition; didn't he?
5 MR. DANDAR: No. It's something they want
6 it to say -- it doesn't say what they want it
7 to say.
8 THE COURT: Right, okay. That’s fine.
9 Is Mr. Prince going to testify?
10 MR. DANDAR: Yes, right now.
11 THE COURT: Okay.
14 Q. Mr. Prince, this Exhibit 163 that Mr. Rosen said
15 you skipped out on bail and there was a warrant out for
16 your arrest --
17 THE COURT: Wait a minute. I thought that
18 we weren't accepting that into evidence because
19 it was not authenticated and didn't have any
20 value.
21 Now, are you going to question him about
22 this xhibit?
23 MR. DANDAR: I want the record to reflect
24 that Mr. Rosen's questions were inaccurate. I
25 want the record to reflect that this is a

1 thousand-dollar default judgment and the
2 warrant was quashed by the state. And that's
3 all I needed to point out. Then I'm not going
4 to ask him any questions about it. If this is
5 a genuine document --
6 THE COURT: I mean, are you going to offer
7 that into evidence?
8 MR. DANDAR: No. I'm just going to ask
9 him a question.
10 THE COURT: Okay. Well, ask him a
11 question.
12 MR. DANDAR: So is this 163, then, not part of
13 the record?
14 THE COURT: No, because it's not
15 authenticated.
16 MR. DANDAR: All right.
18 Q. Mr. Prince, did you ever skip out on a bond for a
19 criminal charge in Chicago?
20 A. No.
21 Q. And did you ever check to see if there were any
22 warrants out for your arrest?
23 A. Yes, I have.
24 Q. Did you ever discover any warrants for your
25 arrest?
1 MR. ROSEN: Objection. This is the best
2 evidence rule. A printoff the NCIC computer is
3 the best evidence.
4 THE COURT: Overruled.
5 MR. DANDAR: I have no other questions on
6 that subject matter.
8 Q. Mr. Prince, when you were in RTC, were you an
9 auditor?
10 A. Yes.
11 Q. Can you tell the Court what an auditor is?
12 MR. ROSEN: Objection, Judge. This isn't
13 redirect.
14 MR. DANDAR: He asked him about RTC. He
15 asked him about being demoted out of RTC, so
16 I'm following up on my redirect because he
17 asked those questions on cross.
18 MR. ROSEN: I asked him nothing about
19 being in RTC. I just said, RTC, you were
20 removed from post in 1987.
21 THE COURT: What's the relevance?
22 MR. DANDAR: The relevance is to show that
23 Mr. Prince did have a high position in RTC.
24 THE COURT: Well, he testified to that.
25 MR. DANDAR: Yes, he did. But he was also
1 an auditor, and I don't know if the Court is
2 aware of what an auditor is, which is another
3 high position.
4 THE COURT: Well, you had an opportunity
5 to bring that out on direct, and there was
6 nothing brought out on cross about that, so
7 MR. DANDAR: His demotion from RTC was
8 brought out by Mr. Rosen on cross.
9 THE COURT: Okay. Go ahead. Go ahead.
11 Q. What is an auditor?
12 A. An auditor is a minister in Scientology that does
13 counseling, pseudo-psychological counseling, on its
14 members.
15 Q. Were you an auditor of the leader of the Church of
16 Scientology, Mr. Miscavige?
17 A. I was at a point in time, yes.
18 Q. And a case supervisor is above an auditor,
19 correct?
20 MR. ROSEN: Your Honor, I object to this.
21 This is not only beyond the scope, it's a back
22 doorway of general pattern stuff, et cetera,
23 everything you said he couldn't do.
24 THE COURT: Well, this isn't going very
25 far. Isn't that right, Mr. Dandar?
1 MR. DANDAR: Yes.
2 THE COURT: Let's just move on.
3 MR. DANDAR: I have -­
4 THE COURT: Let's just move on.
5 MR. DANDAR: Can I just tell you -­
6 THE COURT: No, you don't tell me. Just
7 move on.
8 MR. DANDAR: Okay.
10 Q. Now, Mr. Prince, Mr. Rosen showed you a videotape.
11 MR. DANDAR: And, Judge, I need to let the
12 record reflect that I objected to that when it
13 was played, what happened before that snippet,
14 and you said I could.
15 Unfortunately, the Plaintiff, the Church
16 of Scientology, only brought the snippet rather
17 than the full unedited tape, so I'm not able to
18 play that.
20 Q. Mr. Prince, did you participate in pickets with
21 Mr. Minton in front of property owned by the Church of
22 Scientology?
23 A. Yes.
24 Q. Did the Church of Scientology in any way provoke
25 you or Mr. Minton during those pickets?
1 A. Yes.
2 Q. In which way?
3 A. There is -­
4 MR. ROSEN: I object. The issue is
5 November of 1998, the day on the tape. The
6 question was whether he was provoked into that
7 remark. We're going to talk about L.A. again
8 and some PI on his car?
9 MR. DANDAR: No. We're going to talk
10 about Boston, September 10th, 1998.
11 THE COURT: No, we're not. We're talking
12 about the day on that tape. That was the
13 question.
14 MR. DANDAR: They didn't produce the full
15 tape. You don't have a full picture of what
16 was going on before that tape. We don't have
17 it either.
18 THE COURT: I want to know what was going
19 on that day. If you want to get some testimony
20 about that day, I'm happy to listen to it.
22 Q. Mr. Prince, how long were you picketing with
23 Mr. Minton on that date Mr. Rosen showed you on the
24 videotape?
25 A. Probably a half-hour, hour.
1 Q. What was going on before the picketing, before
2 that segment of the videotape?
3 A. PI's following me, just general annoyance and
4 aggravation I suffered from Scientology.
5 Q. Were there any conversations or any words
6 exchanged between you and members of the Church of
7 Scientology 20 minutes to a half an hour before that
8 segment that Mr. Rosen showed to the Court?
9 A. Yes.
10 Q. Do you recall what that was?
11 A. Not specifically; no, I do not.
12 Q. Was it a pleasant exchange of communications?
13 A. No. All of -- you know, the general gist is that
14 the Scientology staff had been briefed to repeat to me
15 things that I've said in confidence to an auditor, things
16 that are personal to my life. This is a part of the
17 Scientology practice called reverse auditing.
18 MR. ROSEN: I object, Your Honor.
19 THE COURT: Yeah, sustained.
21 Q. What types of things were they saying, without
22 getting into the specific content, because I don't want to
23 violate your priest/penitent privilege any more than it has
24 been.
25 MR. ROSEN: Your Honor, I think we need a

1 foundation here. This witness testified before
2 lunch that nothing happened the day of the
3 video.
4 THE COURT: I think he just said he
5 couldn't remember anything in particular, so
6 why don't you try something else.
7 MR. DANDAR: I will.
8 THE COURT: All right.
10 Q. Now, Mr. Prince, were you a pauper before you met
11 Robert Minton in 1998?
12 A. No.
13 Q. Were you working by yourself or with others in
14 1998 before you met Mr. Minton?
15 A. With others.
16 Q. When you left the Church of Scientology in 1992,
17 did you continue to be a Scientologist?
18 A. For a time thereafter.
19 Q. Did you work for a Scientology company, a company
20 run by the public Scientologists?
21 MR. ROSEN: Your Honor, this is redirect.
22 I don't remember asking any of these questions,
23 who he worked for in 92.
24 THE COURT: Go ahead.

2 Q. Is the first time that -- when was the first time
3 that you participated in consulting with anyone on the
4 Church of Scientology after you officially left as a staff
5 member in 1992?
6 MR. ROSEN: Objection. Misstates the
7 testimony. He didn't leave as a staff member
8 in 1992. He left as a staff member in '87.
9 THE WITNESS: Not true. I left in 1992.
11 Q. When did you first consult with anyone about
12 Scientology after you left in '92?
13 A. I didn't consult with anyone concerning
14 Scientology, you know, not in any capacity to offer insight
15 or do research and documentation. That started in '98.
16 Q. Okay. Did you meet with any attorneys
17 representing the Church of Scientology after you left in
18 1992?
19 A. Yes, I did, Earl Cooley in '95.
19 MR. ROSEN: Your Honor, again, this is not
20 redirect. I'm lost to understand how this
21 could possibly be justified.
22 THE COURT: Well, it's all going to become
23 clear to us. Continue.
25 Q. Mr. Cooley is an attorney for the church?
A. He was the lead counsel for Scientology conglomerate.
Q. When he asked you to meet with him, what did he tell you as to the purpose of the meeting?
MR. ROSEN: Judge, now is this witness going to testify as to what Mr. Cooley said?
THE COURT: He thinks he is.
MR. DANDAR: He's in-house counsel, Judge.
MR. ROSEN: He is not in-house counsel. He's a senior partner in a law firm in Boston. How do you make these representations? You know better. You have seen his letterhead. He is the senior partner of a law firm in Boston. He has never been an in-house for any church entity, and I just don't understand why Mr. Dandar just recklessly makes these representations to the Court. BY MR. DANDAR:
Q. Mr. Prince, is Mr. Cooley a long-time attorney for many corporations of the Church of Scientology?
MR. ROSEN: Objection, irrelevant, beyond the scope.
THE COURT: If we're leading up to hearsay testimony regarding what this attorney may have told him, then I'm going to have to hear why

1 there's an exception.
2 I mean, I'm just trying to get past the
3 current stuff and get right to the essence of
4 what you're trying to do, okay?
6 Q. Mr. Prince, what was your understanding of the
7 purpose of your meeting with Mr. Cooley?
8 A. To find out -- well, what I thought it was about?
9 Q. Yeah, originally.
10 A. They told me one thing, but it turned out to be
11 something entirely different, you know, just to check on me
12 and see how I was doing and updating me on the progress
13 they had made in some legal cases, this type of thing.
14 Q. When you were an officer in the Religious
15 Technology Center, were you involved in litigation?
16 A. Yes.
17 MR. ROSEN: Objection. Not a word of this
18 in cross-examination, Your Honor. I think
19 Mr. Dandar said he had 15 or 20 questions
20 before the lunch break.
21 MR. DANDAR: I would have already been
22 finished if I didn't get interrupted all the
23 time. It's very short. I'm just trying to
24 establish some background here.
25 THE COURT: Okay. Proceed.

2 Q. Were you involved in litigation?
3 A. Yes.
4 Q. What was your duties in reference to litigation
5 while you were at RTC?
6 A. I was responsible for successfully prosecuting
7 Scientology's enemys.
8 Q. Now, Mr. Prince, when you were working for the
9 Lisa McPherson Trust, did you get paid any money by the
10 Lisa McPherson Trust to do work on the wrongful death case
11 or any other case involving the estate of Lisa McPherson?
12 A. No.
13 Q. When you were working for the Lisa McPherson Trust
14 and getting paid by the Trust, was that money for anything
15 other than -- anything -- other than the work that you were
16 doing for the Trust?
17 A. No. The money that I got paid solely had to do
18 with the activities of the trust.
19 Q. How much did you get paid monthly by the Lisa
20 McPherson Trust?
21 A. $5,000.
22 Q. Now, you said the Lisa McPherson Trust was shut
23 down in about October of 2001?
24 A. Correct.
25 Q. And you continued to get paid after that?
1 A. Yes.
2 Q. And that was by whom?
3 A. Ms. Brooks.
4 Q. How much?
5 A. $5,000.
6 Q. Every month?
7 A. Until April of this year, yes.
8 Q. And why were payments stopped?
9 MR. ROSEN: Objection. This sounds like a
10 direct examination, no relationship at all to
11 cross-examination.
12 MR. DANDAR: Mr. Rosen talked about his
13 pay ad nauseam and talked about the fact that
14 the pay was stopped in April of 2002, and
15 that's what I'm picking up on.
16 THE COURT: Okay. Go ahead.
18 Q. Why was the pay stopped?
19 A. Because I wouldn't have participated in the
20 blackmail.
21 Q. And are you independently wealthy?
22 A. No, hardly.
23 Q. Okay. Were there any promises or inducements made
24 to you by Mr. Minton in reference to continuing to pay you?
25 MR. ROSEN: Same objection, Judge. Is


Mr. Dandar going to say this is following up on something I asked?
MR. ROSEN: What is it that I asked that this follows up on?
MR. DANDAR: You talked about his pay in the year 2002. That's where I'm at right now, right in the critical time zone.
THE COURT: Critical time zone?
THE COURT: Okay. Go ahead.
Q. Did Mr. Minton make any promises to you if you would join his plan of action?
A. Yes.
Q. What?
A. He told me that we would leave Scientology far behind us, that I would never want for money again, and, you know, we would just basically fly around visiting islands and vacation and be happy people.
MR. DANDAR: I appreciate the humor. Thank you, Mr. Rosen.
Q. Well, Mr. Prince, why didn't you take him up on his offer?
1 A. Because -­
2 MR. ROSEN: Judge, can I just have a -- I
3 hate even to object to this because I know that
4 Your Honor is capable of giving it the weight
5 it's entitled to; but for the record, can I
6 just have a continuing objection?
8 MR. ROSEN: Thank you.
10 Q. Did he say those words to you, by the way, or is
11 this -­
12 A. Yeah, he said those words to me. This was a
13 discussion between Mr. Minton, Ms. Brooks and myself.
14 Q. Okay. And based upon your experience and
15 knowledge of Mr. Minton, was he capable of fulfilling that
16 promise?
17 A. Yes.
18 MR. ROSEN: I need to object to that even
19 despite my continuing objection.
20 THE COURT: Okay.
22 Q. Mr. Prince, you met with me on April 14th of 2002
23 at the mall, and that handwritten statement that we
24 identified, did I pay you for that?
25 A. No.

1 Q. Did I pay you to write the April 2002 affidavit
2 which was actually dated May 1st of 2002?
3 A. No.
4 MR. DANDAR: That's this Defense Exhibit 7. I
5 want to make sure, Judge, that it's in
6 evidence, if I moved it in evidence. I would
7 like to do so at this time.
8 THE COURT: It's in evidence.
10 Q. Mr. Prince, did I come and assist you at all in
11 any degree in composing the Exhibit 7?
12 A. No.
13 Q. Are you being paid to testify here?
14 A. No.
15 Q. Mr. Prince, when is the last time -- before I gave
16 you a retainer check in June of 2002 for $4,000, when is
17 the last time I paid you anything?
18 A. It had been years.
19 Q. And when is the last time -- was there a point in
20 time when you resigned as the expert-for the Estate of Lisa
21 McPherson?
22 A. Yes.
23 Q. And why was that?
24 MR. ROSEN: Objection. When did I ask
25 this question?

1 THE COURT: You've got a continuing
2 objection.
3 MR. ROSEN: I'm sorry, Your Honor.
4 THE COURT: Go ahead, Mr. Dandar.
5 THE WITNESS: Because of the last time
6 Scientology perpetrated a fraud on the court
7 that affected me directly, they came into this
8 court and lied.
9 They lied to a police officer who then
10 came into this court and said that I was a
11 marijuana/cocaine dealer, and my house was
12 raided by the DEA.
13 People were running around with
14 semiautomatic weapons around my children and
15 looking for cocaine, on and on and on.
16 And they walked out of the back with a
17 plant -- a marijuana plant -- this big that was
18 planted by their agents.
20 Q. Agents of whom?
21 A. Scientology.
22 Q. When you say this court, you're talking about
23 Judge Baird when he signed the search warrant?
24 A. Correct.
25 Q. And did that result in Judge Schaeffer entering an

order on tampering with a witness?
A. Yes, they did, sanctions and tampering, yes.
Q. What is the reason why -- tell the Court the reason why I paid you a retainer of $4,000 in June of 2002.
MR. ROSEN: We're now up to mind reading, I guess, right?
THE COURT: No. Answer the question, Mr. Prince.
THE WITNESS: I guess the simple answer is my time is valuable, and I work very hard to show, through Scientology's own policies, which the volume -- the length and breadth of the
ramblings of L. Ron Hubbard --
THE COURT: Mr. Prince,the question was:
Why did he pay you? What did he pay you for?
In other words, what was it that you were being
hired by him to do?
THE WITNESS: To go through the voluminous volumes of Scientology information to prove his case on different issues concerning the case. Should I be more specific, Your Honor?
THE WITNESS: I'm trying not to because of work product.
MR. DANDAR: At this time I would like to

1 either mark this as a composite -- and this
2 will be part of the proffer that I told you
3 about before. I would hope the Court would
4 reconsider and make it part of the evidence in
5 the case.
6 THE COURT: Is this the proffer or is this
7 going to be part of this evidence?
8 MR. DANDAR: I would like the Court to
9 reconsider and have it part of the evidence.
10 THE COURT: I'm not going to reconsider.
11 MR. DANDAR: Okay. Then I will ask some
12 more questions and make it a proffer.
14 Q. Mr. Prince, was there ever a meeting with
15 Mr. Minton in my office to discuss the addition of David
16 Miscavige where Dr. Garko and Stacy Brooks --
17 THE COURT: Wait a minute. Are you testifying?
18 MR. DANDAR: No.
19 THE COURT: Well, it sounds to me like you
20 are, okay?
21 Why don't you just ask him if he remembers
22 meeting with you and what was the nature of
23 that meeting and what was it about and who was
24 there.
25 You know, I have sat through and watched

1 him evade questions from Mr. Rosen for hours,
2 and then all of the sudden, the only answers
3 that you get out of him is yes and no, and I
4 think that that's mostly because you're doing
5 most of the testifying and he's just assenting
6 to it.
7 So, you know, if you want to have this
8 examination have some credibility with me
9 regarding this witness and what he's testifying
10 to, it would be of great help if it came out of
11 his mouth, okay?
12 MR. DANDAR: Okay.
14 Q. Mr. Prince, can you tell the Court all of the
15 occasions you recall meeting -- having any meetings
16 discussing the addition of parties to the wrongful death
17 case?
18 MR. ROSEN: Your Honor, I know I have a
19 continuing objection, but this is so far
20 beyond -- there isn't even anything remotely
21 Mr. Dandar can -­
22 THE COURT: I agree with that, okay. I
23 agree with that.
25 Q. Mr. Prince, after you heard Mr. Minton lie in this
hearing on April the 9th and you said you left the courtroom, what's the first attorney you went to see?
MR. ROSEN: Objection as to form.
It's unbelievable. Could Counsel perhaps ask the witness the question, without testifying and giving his opinion that Mr. Minton was lying? Is it possible to have that kind of a question?
Q. Mr. Prince, what is the first attorney you contacted after April 9th?
A. Dennis de Vlaming.
Q. And why did you go see him?
A. Because of the criminal nature of the act that I was asked to be a part of and what I saw occurring.
Q. So it wasn't -- it was -- what did you see occurring?
A. The full -- from beginning to end, I saw people that used to be my close friends, Bob Minton and Stacy Brooks, go to New York, get demanded of by Mr. Rosen and Mr. Rinder that they cause the dismissal of the Lisa McPherson case and the Lawrence Wollersheim case, and, you know, to take back affidavits, this that and the other thing, through the meetings mentioned in my affidavits, you know, of bringing me in the circle and, you know, my
1 needing to be part of it.
2 And the strategy to get rid of the wrongful
3 death case was, of course, to attack you and falsely accuse
4 you.
5 And I witnessed the documents that were
6 provided to Minton when he specifically told the lie about
7 and we discussed how he felt about telling those lies.
8 Q. The affidavit that you referred to, the Exhibit 7
9 affidavit, how long did that take you to compose?
10 A. I think about three days.
11 Q. All right. Can you tell the Court, that three
12 days, how many hours a day and things like that.
13 A. I think three days and maybe four to five hours a
14 day.
15 Q. Did you actually make contact with the FBI?
16 A. Not directly.
17 Q. Okay. Did you make contact with Agent Strope?
18 A. Yes, I did.
19 MR. DANDAR: That's all the questions I have
20 for the redirect. And the only thing I have
21 left is the proffer.
22 MR. ROSEN: Approach, Your Honor.
25 Q. Mr. Prince, I show you what's marked for
identification as Exhibit 206. I will represent that that is the complaint filed in the Armstrong case. It is dated, I believe, the 2nd of April, and it's the one that I handed -- served -- I served --
MR. DANDAR: Objection.. There was nothing on my redirect that has anything to do with the Armstrong case.
THE COURT: Overruled. Go ahead.
Q. Is this document this Armstrong complaint that Mr. Minton showed to you?
A. I can't say that it is.
Q. Do you notice that there's,a caption and
Mr. Armstrong is a defendant, Mr. Minton is a defendant?
Do you see that?
A. Yes.
Q. Uh-huh. (Affirmative.)
Can you point out where it is in there that the demand against Mr. Minton is 80 million dollars? Just tell us what page it's on, sir.
MR. DANDAR: Objection. The witness has not identified the document. He said he couldn't.
MR. ROSEN: I will identify the document, and I will withdraw the question and move for its introduction into evidence.

1 THE COURT: Okay.
2 MR. ROSEN: No further questions.
3 THE COURT: All right. Okay. You want to
4 proffer some additional stuff with him or can
5 we have him step down?
6 MR. DANDAR: I need him to identify the
7 documents.
8 THE COURT: Okay.
9 MR. DANDAR: Our next is Number 8.
10 THE COURT: I'm sorry. What Exhibit
11 Number was this?
12 MR. ROSEN: I wrote it on the bottom, Your
13 Honor.
14 THE COURT: Oh, 206?
15 MR. ROSEN: 206, yeah.
16 MR. DANDAR: Is that in evidence, Judge?
17 THE COURT: Yep.
18 Okay. All right. What do you want to
19 proffer?
20 MR. DANDAR: There's these documents and
21 Mr. Prince's testimony concerning these
22 documents.
23 Do you want me to just give them to you as
24 a composite since it's a proffer?
25 THE COURT: Sure.

1 MR. ROSEN: This is the proffer that
2 Mr. Dandar was going to present orally as to
3 the evidence of general pattern or practice of
4 not being nice?
5 THE COURT: I don't know what the purpose
6 of this is, but --
7 MR. ROSEN: I think he told you, Judge.
8 He said it yesterday. He wanted to make this
9 because we have a practice of not being nice.
10 THE COURT: Well, I don't think he said
11 that, Mr. Rosen.
12 MR. ROSEN: Well, I was being polite.
13 THE COURT: Just a general, you know,
14 pattern of activity on the part of the Church
15 of Scientology.
16 It shows a pattern of conduct or something
17 along those lines; is that right?
18 MR. DANDAR: Yes, Your Honor. Is this
19 Composite Number 8?
20 THE COURT: Yes.
21 MR. DANDAR: All right.
22 Mr. Prince, let me show you -
23 MR. ROSEN: Wait a second. You made your
24 proffer.
25 THE COURT: He needs to ask him some

1 questions about it also, apparently. That's
2 part of the proffer too; is that right?
3 MR. DANDAR: Yes, Your Honor.
4 MR. ROSEN: He's not going into the
5 substance of these things, is he?
6 MR. DANDAR: Yes, we are.
7 MR. ROSEN: Well, this is just a back
8 door. He's going to ask him what the document
9 says?
10 THE COURT: You know, you're not going to
11 ask him what they say, right?
12 MR. DANDAR: I'm going to ask him some
13 specific points of the document rather than
14 having the whole document sit there without any
15 significance.
16 MR. ROSEN: I object, Your Honor.
17 MR. DANDAR: It's a proffer. He can't
18 object during a proffer. It's a proffer for
19 the record to preserve the record.
20 THE COURT: Well, this is the record,
21 though, right?
22 MR.DANDAR: It is.
23 MR. ROSEN: You make the proffer from
24 here, Counsel, as to what this would show.
25 MR. DANDAR: Mr. Prince's testimony is

1 part of the proffer, because of his background
2 and expertise in Scientology.
3 MR. ROSEN: Your Honor, that proffer comes
4 from here to you, that if the witness were
5 allowed to testify, he would testify as
6 follows. That's a representation by Counsel.
7 He doesn't get it through a witness.
8 THE COURT: No, he can do it either way.
9 He can either suggest it, in court what the
10 proffer would be if it were allowed or he could
11 offer it, but I don't see any reason to go, you
12 know, through the testimony.
13 Why don't you just go ahead and put on the
14 record what you suggest would be shown by all
15 of this, okay?
16 MR. DANDAR: In Exhibit 8 there is a
17 document entitled -- the last document. It's
18 entitled, "Battle Tactics."
19 Battle Tactics shows that in order to
20 fight the enemy of Scientology, the policy
21 letters of the Church of Scientology in this
22 particular document says, quote, "Cuts off
23 enemy communications, funds connections,
24 deprives the enemy of political advantages,
25 connections and power.

"He takes every enemy territory. He raids
2 and harasses.
3 "Legal is a slow if often final battle
4 arena. It eventually comes down to legal in
5 the end. If intelligence and PRO have done
6 well, then legal gets an easy in."
7 MR. ROSEN: I object to this.
8 MR. DANDAR: The problem is I don't have
9 the testimony from Mr. Prince to help the Court
10 or help the record show what PRO means.
11 MR. ROSEN: I object to this. Yesterday
12 Your Honor ruled that this general evidence of
13 pattern/practice was not acceptable, that
14 Mr. Dandar should stick to is there anything in
15 here that involves Mr. Minton or the acts that
16 you're accused of of subornation of perjury, et
17 cetera.
18 I'm sure Mr. Dandar is not going to tell
19 you that there's anything in this proffer which
20 deals with any of his conductor of
21 Mr. Minton's conduct or what Mr. Dandar stands
22 accused of. I would ask Your Honor, this
23 proffer is wasting our day.
24 THE COURT: Well, I've accepted the
25 proffer of this material. If you're telling me

1 what that material says, I mean, it's there.
2 So, you know, what more other than
3 material itself is it that you want to proffer?
4 MR. DANDAR: I just want to point out to
5 the Court and emphasize that these policy
6 letters from the Church of Scientology are the
7 policy letters that were employed against
8 Mr. Minton over five years, and he finally
9 succumbed to those policy letters.
10 The one on department of government
11 affairs -­
12 THE COURT: Wait a minute. I can read
13 this and learn about something that was
14 employed against Mr. Minton?
15 MR. DANDAR: Yes. You can read about
16 this to see the policy that was employed
17 against Mr. Minton.
18 THE COURT: And where does it talk about
19 what they're going to do to Mr. Minton in here?
20 MR. DANDAR: Well, of course it doesn't
21 mention Mr. Minton's name. I don't know if I
22 understood your question correctly.
23 It talks about if someone attacks us, like
24 the Lisa McPherson wrongful death case -­
25 THE COURT: Does it talk about the Lisa
1 McPherson wrongful death case?
2 MR. DANDAR: No, of course not.
3 THE COURT: Well, I don't know.
4 MR. DANDAR: No, sorry.
5 These are published copyrighted materials
6 of the Church of Scientology for the last 40
7 years, and Mr. Prince, if he would have
8 testified, would have testified that these
9 policy letters, no matter if they're written in
10 1969, 1968 -­
11 THE COURT: So Prince is going to tell us
12 that this is the way Scientology acts, right?
13 MR. DANDAR: Correct.
14 THE COURT: Okay. What else you got?
15 MR. DANDAR: But I wanted to point out -­
16 THE COURT: Don't point it out. He's
17 going to tell us this is the way Scientology
18 acts, that they've acted that way towards
19 Mr. Minton, that they've acted that way towards
20 the Lisa McPherson Trust. That's what he's
21 going to say, right?
22 MR. DANDAR: Yes.
23 THE COURT: Okay. What else?
24 MR. DANDAR: That's all.
25 THE COURT: There you go. You can step
1 down.
2 THE COURT: Now, you wanted to submit the
3 testimony of some witnesses?
4 MR. DANDAR: Yes, sir, and I would like to
5 do that all at one time.
6 THE COURT: That's fine. Who are they and
7 where are they?
8 MR. DANDAR: I'm going to file the
9 transcript from Judge Schaeffer of the
10 following: John Merrett, Monique Yingling.
11 THE COURT: Wait a minute. This is
12 testimony that was before Judge Schaeffer in a
13 similar hearing that she held?
14 MR. DANDAR: Yes.
15 THE COURT: Okay. And it is the testimony
16 of John Merrett.
17 MR. DANDAR: Yes.
18 THE COURT: Ms. Yingling.
19 MR. DANDAR: Yes.
20 THE COURT: Who else?
21 MR. DANDAR: Brian Haney, Teresa Summers,
22 Peter Alexander, Frank Oliver, Mr. Pope and
23 Mr. Leipold.
24 Mr. Pope was a witness called by the
25 Church of Scientology. The other two --

1 there's three attorneys.
2 Mr. Leipold is the attorney in the
3 Wollersheim case in California. Mr. Merrett,
4 of course, is the former attorney for
5 Mr. Minton in the Lisa McPherson Trust. And
6 Monique Yingling is the -­
7 THE COURT: Yeah, I know.
8 Now, this is the complete testimony that
9 they gave in front of Judge Schaeffer.
10 MR. DANDAR: Yes.
11 THE COURT: Okay. You're not just taking
12 a portion of it. You're submitting the whole
13 thing.
14 MR. DANDAR: Yes, I want to submit the
15 whole thing and then highlight for the Court
16 the excerpts.
17 THE COURT: Well, you will do that in your
18 argument, I would presume.
19 MR. DANDAR: I will do that in my argument
20 as well.
21 MR. ROSEN: I object. This is the same
22 thing if there's a procedure if it were a
23 deposition rather than trial testimony.
24 Mr. Dandar has to provide page and line.
25 I have to be given an opportunity to object on

1 relevance grounds.
2 THE COURT: I'm going to give you that
3 opportunity in your response to his argument,
4 okay?
5 If he refers to something in the testimony
6 of one of these witnesses that you feel is
7 either irrelevant or is improper for whatever
8 reason, I will give you an opportunity in your
9 response to object to it.
10 MR. ROSEN: Okay. And I also have a right
11 to object that the witness is not here. I
12 never examined these witnesses.
13 THE COURT: Well, I know, but these
14 witnesses were testifying about matters that
15 apparently have some significance to this case,
16 and they were subject to cross-examination at
17 the time, and they can be used for that
18 purpose.
19 MR. ROSEN: Just for my own edification,
20 when Mr. Dandar says he's filing these, he's
21 offering these, he's going to physically put in
22 all of this testimony before Your Honor so that
23 he can cite what he wants, and then if I have
24 to cite fairness, I can cite what I want,
25 right?

1 THE COURT: That's right.
2 MR. ROSEN: How many volumes of testimony
3 is this?
4 THE COURT: He just got though telling
5 you that it was the testimony of those
6 witnesses.
7 MR. ROSEN: No. I said how many volumes
8 is it?
9 THE COURT: I don't know.
10 MR. ROSEN: Oh, okay.
11 THE COURT: But that's what it is.
12 MR. ROSEN: Okay.
13 THE COURT: All right. What else do you
14 have?
15 MR. DANDAR: Then that's all. We rest.
16 THE COURT: Great. There you go.
17 MR. DANDAR: Does the Plaintiff rest?
18 MR. ROSEN: No, brief rebuttal.
19 THE COURT: Who you calling?
20 MR. ROSEN: Well, I'm going to offer some
21 exhibits. If I need Mr. Dandar to authenticate
22 them because he objects, then I will call him,
23 but I would hope he wouldn't.
24 THE COURT: All right. You can always
25 hope.

1 MR. ROSEN: Okay. Let's start with what
2 we've marked -­
3 MR. DANDAR: Do you want me on the stand?
4 THE COURT: No. We're going to see if we
5 need you on the stand. Apparently there's
6 going to be some exhibits offered, and if you
7 object to them, we may have to have you
8 authenticate them. And if you don't, then
9 apparently they'll just come in.
10 MR. ROSEN: Exhibit 221 is the draft
11 of the -- a draft of the Fifth Amended
12 Complaint that was sent by Mr. Dandar to
13 Mr. Minton.
14 MR. DANDAR: Well, I object to this. This
15 was in Judge Schaeffer's. This was not
16 authenticated.
17 MR. ROSEN: It wasn't?
18 MR. DANDAR: It was not authenticated.
19 MR. ROSEN: Is it admitted?
20 MR. DANDAR: It was not admitted.
21 MR. ROSEN: Then if it's not been admitted
22 or authenticated, I won't offer it.
23 MR. ROSEN: Number two is -- what's the
24 next exhibit?
25 Can I have a second, Your Honor?

1 (Thereupon, a brief discussion was held
2 off the record.)
3 MR. ROSEN: Well, Your Honor, I have a
4 problem. I'm at a disadvantage: To my right
5 stands Mr. Shaw, the head of Flag, who says, "I
6 was present at the Judge Schaeffer hearings,
7 and this affidavit was admitted into evidence."
8 Excuse me. Not affidavit. This draft
9 complaint that Mr. Minton says Mr. Dandar said
10 to him was admitted into evidence.
11 So my client is saying it was admitted.
12 Mr. Dandar says it wasn't. I guess what I'll
13 do is I will -­
14 THE COURT: I'll tell you what, why don't
15 you just go ahead and admit it and it will be
16 subject to the confirmation that it was
17 admitted.
18 MR. DANDAR: No, it wasn't, but that's
19 fine.
20 MR. ROSEN: Okay.
21 MR. DANDAR: If he can find the transcript
22 that says it's admitted, then I stand
23 corrected.
24 MR. ROSEN: The next one is Exhibit 224,
25 which is a posting by Mr. Dandar. Oh, that's

1 already in? Then I don't need to do that.
2 I'll withdraw that, and my comments.
3 That's Exhibit 225, a posting from
4 Mr. Dandar pleading for funds saying, "We're
5 running out of funds for the litigation of the
6 wrongful death case," and it is dated the 10th
7 of January 2002.
8 MR. DANDAR: Procedurally, this is not
9 correct. This is not rebuttal. They're
10 pulling exhibits out of Judge Schaeffer's
11 courtroom that has a lot of testimony that goes
12 with this to try to explain fit, and I object to
13 the procedure.
14 They've already rested, I rested. And
15 this is not rebuttal to the issues that they
16 stated this week are the issues, the six issues
17 that -­
18 THE COURT: What's the purpose of this
19 being offered, to show that Mr. Dandar was
20 asking for money?
21 MR. ROSEN: Yes.
22 THE COURT: Okay. Well, he admits that,
23 right?
24 MR. DANDAR: Yes.
25 THE COURT: Where you were posting, making

1 public pleas for money, saying, "We've run out
2 of money for the case."
3 If he admits it, then I don't need the
4 document.
5 MR. DANDAR: Well, actually, this is an
6 encrypted message. This doesn't say anything
7 except it has my e-mail address on it. It's
8 addressed to Bob Minton.
9 MR. ROSEN: Judge, I don't want to be out
10 of line, but I propose a stipulation, sir, that
11 would obviate this.
12 You were making public pleas for
13 contributions saying that you were running out
14 of money for the case.
15 MR. DANDAR: I can't stipulate to that
16 because I cannot imagine what he's talking
17 about.
18 THE COURT: You never did that?
19 MR. DANDAR: I don't recall as I'm
20 standing here right now.
21 THE COURT: Wait a minute, Mr. Dandar.
22 MR. DANDAR: Yes, sir.
23 THE COURT: Are you meaning to tell me
24 that you don't recall placing something on the
25 internet suggesting that you're running out of


1 funds and that you need money? You never did
2 that or you just can't remember doing that?
3 MR. DANDAR: I just can't remember doing
4 that.
5 THE COURT: You just can't remember doing
6 that?
7 MR. DANDAR: No, sir.
8 THE COURT: And this would have been back
9 in April or May of this year?
10 MR. DANDAR: Oh, no.
11 MR. ROSEN: January of this year.
12 THE COURT: January of this year.
13 MR. DANDAR: See, I don't remember doing
14 that.
15 THE COURT: You just don't remember doing
16 that at all?
17 MR. DANDAR: I don't. If I could see
18 something to refresh my memory -­
19 MR. ROSEN: Here it is.
20 MR. DANDAR: My office is -­
21 THE COURT: Take a look at that. I
22 haven't seen it, but take a look at it if it's
23 on there.
24 MR. DANDAR: This is not a public plea for
25 money.

1 THE COURT: Don't tell me what it is.
2 MR. DANDAR: Okay. It's not.
3 THE COURT: If it's not you asking for
4 money for the case, then fine.
5 MR. DANDAR: No, it's not.
6 THE COURT: Okay. What is it? You tell
7 me what it is.
8 MR. DANDAR: It is an e-mail to Mr. Minton
9 confirming his reservation at the Nashville
10 Vanderbilt Marriott on January 18th, 2002.
11 THE COURT: Okay.
12 MR. ROSEN: The first page of this does
13 not include a request for money?
14 MR. DANDAR: No. You can see it's all
15 encrypted.
16 MR. ROSEN: 224. This is from Mr. Dandar
17 to Mr. Minton, quote, "Help is needed now. Is
18 there any hope at all? Please let me know for
19 sure. If not, I must do something very
20 different, Ken."
21 Perhaps Mr. Dandar will remember that one.
22 MR. DANDAR: I remember this one. This
23 was to Mr. Minton. This was not on the
24 internet.
25 THE COURT: Okay. Well, you don't have a


1 problem with that one.
2 MR. DANDAR: I do not want to waive my
3 objection to the procedure that Mr. Rosen is
4 going through. Other than that­
5 THE COURT: Do you want to get up there
6 and testify to it? Is that what you want to
7 do?
8 MR. DANDAR: No, no, but I don't think
9 this is rebuttal.
10 MR. ROSEN: And my last exhibit, Your
11 Honor, is Exhibit 105, which is a transcript of
12 the proceedings before Judge Greer on the 2nd
13 of May 2002, and in particular Page 25 of that
14 exhibit from Mr. Dandar's statements from Line
15 9 to Line 18. I have the other pages in there
16 so you can see it in context.
17 THE COURT: Well, just as he's submitting,
18 you know, the transcripts of testimony of
19 various folks in front of Schaeffer, I presume
20 that he's got no objection to you submitting a
21 transcript of the things in front of Judge
22 Greer.
23 MR. DANDAR: As long as I can respond to
24 it, it's fine.
25 THE COURT: It's in evidence.

1 MR. ROSEN: Do you want to respond to
2 this? I call Mr. Dandar.
3 THE COURT: Don't start this. You're
4 going to get to argue about this.
5 MR. ROSEN: Okay.
6 MR. DANDAR: Are you done? I thought you
7 said that was your last one.
8 MR. ROSEN: Let me just check with my
9 client. Yes, that's it, Your Honor.
10 MR. DANDAR: There's one more person I
11 forgot, and I found it last night at midnight.
12 It's Mr. Minton's testimony before Judge
13 Schaeffer on this meeting that he alleges
14 happened to discuss adding on parties.
15 It was subsequent to his testimony here.
16 I, of course, didn't have the opportunity to
17 question him about it until I got to Judge
18 Schaeffer when it was new testimony from him
19 contradicting the testimony he gave you. I
20 want to be able to supply that to the Court.
21 MR. ROSEN: I assume this is part of what
22 you're offering including on grounds that you
23 knew about it and you cross-examined him and
24 you didn't ask him any questions.
25 MR. DANDAR: I did. It's my cross of
1 Mr. Minton.
2 MR. ROSEN: You didn't ask him any
3 questions here about the 19th of April. Look,
4 I don't want to fight with you.
5 MR. DANDAR: I know.
6 MR. ROSEN: It's coming in the same
7 category of you designate and then I'll make my
8 objections.
9 THE COURT: (Nods head up and down.)
10 MR. ROSEN: Your Honor, we have agreed,
11 Mr. Dandar and I, during the recess, subject to
12 Your Honor's approval, to a briefing schedule,
13 and it is the same one that's before Judge
14 Schaeffer.
15 Mr. Dandar will have one week to respond
16 to our brief. And I don't care if he calls it
17 a closing argument. I'm calling mine a
18 post-trial brief.
19 THE COURT: Call it what you want.
20 MR. ROSEN: He will have-one week to
21 respond to ours and we will have one week to
22 reply to his.
23 And I assume that with this brief he will
24 include these excerpts that he's talking about.
25 And in our reply brief or with it in a


1 separate document, we'll set forth our
2 objections or fairness designations to what
3 he's submitting.
4 THE COURT: Okay.
5 MR. ROSEN: Oh, I'm sorry, I forgot. Is
6 that right, Mr. Dandar?
7 MR. DANDAR: Yes, that's right.
8 MR. ROSEN: The only thing I left out
9 is -- so he gets one week after we submit ours.
10 You will have ours in an hour.
11 And, Your Honor, we will also be
12 submitting -- at some point I should tell
13 Mr. Dandar this -- proposed findings and
14 conclusions from the substantial record in this
15 case.
16 If it assists Your Honor -- we hope it
17 will; that's the reason for submitting it. If
18 not and Your Honor chooses to write his own, I
19 certainly understand that.
20 MR. DANDAR: You're going to hand-deliver
21 that in an hour?
22 MR. ROSEN: Yeah. It will be here in
23 Court in an hour and hand-delivered to your
24 office.
25 MR. DANDAR: That's a good way to spend

1 your Labor Day weekend.
2 THE COURT: So the other good news,
3 besides the fact that we're ending at two
4 o'clock today, of course, is that not only has
5 the baseball strike settled, but your favorite
6 team, the New York Yankees, has agreed to give
7 our favorite team a lot of money.
8 (Thereupon, a brief discussion was held
9 off the record.)
10 MR. DANDAR: Judge, there's one thing I
11 wanted to point out. You said I could object
12 to these late filing of exhibits, which is
13 Volume II of the church's exhibits
14 There is a bunch of exhibits were starting
15 with 44A through 47A concerning my parents'
16 real property deeds, my sister's property
17 deeds, my property deeds.
18 There is no evidence to link any of this
19 exhibits to any of their claims that they made
20 in this case.
21 MR. ROSEN: I thought I said earlier -- if
22 I misspoke, please correct me -- that I
23 reported to Your Honor that Mr. Dandar had
24 agreed that subject to any objection is he had as
25 to relevance, these documents were authentic
1 and can be received. And he can object in his
2 brief.
3 THE COURT: You can object to the
4 relevance of anything they suggest regarding
5 these documents, the same way he's going to
6 object to anything they think is irrelevant
7 regarding what you're going to pull from the
8 Schaeffer transcripts and all of the other
9 evidence.
10 MR. ROSEN: Thank you, Judge.
11 THE COURT: Okay.
12 (Thereupon, the hearing was concluded)


4 )
6 I, Susan M. Valsecchi, Professional
7 Reporter, in and for the Sixth Judicial Circuit, State of
8 Florida:
9 DO HEREBY CERTIFY that I was authorized to and
10 did stenographically report the foregoing proceedings and
11 that the transcript is a true and complete record of my
12 stenographic notes.
13 DATED this 1st day of September 2002, at
14 Clearwater, Pinellas County, Florida.
17 ~ C(.~J~CI~
18 Susan M. Valsecchi, RPR
19 Registered Professional :;porter