Q. Is that why he was of interest to you?
A. That and he was a security person.
Q. What words did he voice to you?
A. I think he had -- he had yelled something at me a couple of weeks prior to
that. It was along the lines of, you need to get out of here or something like
that, which was followed by another assault or stalking complaint.
(At this time Plaintiff's Exhibit No. 14 was marked for identification.)
BY MR. POTTER:
Q. Let me hand you what's been marked as Exhibit 14. Did you take that photograph?
A. Uh-huh (nods affirmatively).
Q. Did you mean to say yes?
A. Yes.
Q. Why did you take that photograph?
A. Security.
Q. Is it the same individual that's in photograph 13?
A. Well, I can't tell because his back is turned in the second one, but it appears
to be a similar likeness.
Q. And why did you take two pictures of that individual?
A. I have no idea.
Q. Did you post that picture?
A. I would assume so.
Q. And why did you feel that that was newsworthy?
A. For the same reason as all the others, Scientology security.
(At this time Plaintiff's Exhibit No. 15 was marked for identification.)
BY MR. POTTER:
Q. Let me hand you what I've marked as Exhibit 15. Did you take that picture?
A. Uh-huh (nods affirmatively).
Q. Did you mean to say yes?
A. Yes.
Q. Why did you find that to be of interest?
A. Same as the rest, security.
Q. Security?
A. Yes.
Q. Did you post that picture on the Internet?
A. Sure.
(At this time Plaintiff's Exhibit No. 16 was marked for identification.)
BY MR. POTTER:
Q. Let me hand you what I've marked as Exhibit 16. Did you take that photograph?
A. Yes.
Q. Why did you find it to be of interest?
A. It appears to be almost the same as the one previous to it.
Q. And why was it of interest to you?
A. Security.
Q. And did you post that picture?
A. Yes.
(At this time Plaintiff's Exhibit No. 17 was marked for identification.)
BY MR. POTTER:
Q. Let me hand you what I've marked as Exhibit 17. Did you take that picture?
A. Yes.
Q. Why was that picture of interest to you?
A. Security.
(At this time Plaintiff's Exhibit No. 18 was marked for identification.)
BY MR. POTTER:
Q. Let me hand you what I've marked as Exhibit 18. Did you take that picture?
A. Yes.
MR. FLASTERSTEIN: I don't think we have Exhibit 18.
BY MR. POTTER:
Q. I know. I'm getting it for you. I'm sorry, did you say yes?
A. Yes.
Q. And why was that picture of interest to you?
A. It's another one of the Church of Scientology's unfinished projects.
Q. What's unfinished about it?
A. Well, if you were to look at the color photo and actually some of the other
exhibits you're probably going to give me you'll see plywood in the windows,
that it's a decrepit looking structure.
MR. POTTER: Sorry. It's my only copy.
BY MR. POTTER:
A. Sits supposedly for a long period of time now for -- I don't know. It's supposed
to be used for another purpose, but of course that has yet to be
realized. Aren't there any more exhibits?
Q. Oh, I have some more.
A. I was going to say there's one of the -I think I posted some of the plywood
in the windows. Actually I think they even have some pictures that I posted
of what appears to be the interior of the unfinished Super Power Building or
the interior of somE sort of building that's housed in the first -- I believe
it's only the first level of this building.
Q. Have you posted all the pictures that you have taken or just some of the
pictures?
A. Some of the pictures.
Q. And what about the pictures that you have not posted, what have you done
with them?
A. Nothing, actually.
Q. Are they part of your project?
A. Yeah. Actually the reason for taking pictures -- well, due to the fact that
also saves videotape is to create a story board so maybe you can get a better
aspect of the whole scenario, like properties, security, who's and what's scenarios.
You can get a broad look at what you might want to use to tell a story.
Q. Now, you mentioned that you had originally obtained some amount of black
and white filn from the store in downtown Clearwater. Is that the
same film you're using or have you acquired more film? A. Most of these were
color, yeah.
Q. Where were you getting the money to buy the film and to buy -
A. Well, it's funny I bought 80 rolls of 35-millimeter film for 10 cents apiece
at one of these close-out stores on Missouri Avenue.
Q. Then what about developing it?
A. Incredible. When you develop them, the good thing about developing now is
I can take a roll of 35-millimeter film and get it put on disk. I don't
have to get the individual photograph printed. And to get a disc made up it's
like 5.65 and that's, you know, forty -- 35 pictures.
Q. Do you have any -- any people that are funding your efforts or helping you
financially?
A. I wish.
Q. In your project? A. No.
Q. Are you -- do you expect to receive any payment for your filming that you're
engaged in?
A. Oh, absolutely not. That's half the reason why, you know, Pinellas Access,
I mean. I got everything as far as the credentials and the help and the use
of all these facilities for free so I couldn't ever possibly try to gain money
for doing it, you know. That just wouldn't be right.
Q. Now, more recently you've began videotaping, have you not? Pardon me?
A. Yes.
Q. How did you get the -- where did the video camera come from?
A. Pawn shop.
Q. Did you -- did you purchase it?
A. Yes.
Q. Did you purchase it with your own money?
A. Yes.
Q. Did anybody assist you in purchasing that equipment?
A. No.
Q. And what about the videotape that you used to shoot that video, where does
that come from?
A. No, it's cheap, I bought it. You can buy it like three and four packs I think
for ten bucks.
Q. And then what, if anything, are you doing with that videotape?
A. Nothing at the moment.
Q. Is that part of the project?
A. Oh, I still have to sift through it and see what exactly I have and what
I can use for certain things to tell the story, whatever story remains to be
told.
Q. Is it your intent to tell this story through some sort of videotape or video
movie or something or film?
A. Yeah. There's a half-an-hour spot and I plan to run a series on Pinellas
Access, Channel 96.
Q. And when -- when do you plan to do this?
A. As soon as I'm financially able to.
Q. Do you have to pay for access to the -
A. No. For Pinellas County residents you take a free 10-week course and -- or
it depends if you don't want to use the -- one of it's the remote course which
is just for the remote cameras. One of it's a studio course. The remote course
is -- I think it's three weeks of one day a week and it's for three hours and
they teach you how to use their remote cameras. And the other one is a studio
class and they teach you how to use studio facilities, the cameras and how to
put up a story and how to basically put a show on.
Q. Have you taken those courses -
A. Yes.
Q. Have you begun to use what you have learned in those courses to put together
some sort of-
A. Well, it depends on what you're trying to do. I mean, they try to help you
out if you're doing like a traditional show. Like there's some shows where you
would want to put like maybe four people on a panel and discuss a subject. There
are some shows where you would just want to show public scenes. Like that
one guy has a show called Gulf Boulevard. Excuse me. And he just shows nothing
but people out on the boardwalk and, you know, Pier 60 and things going on or
the beach.
Q. My question is have you started to produce a movie, have you started to put
together -have you begun editing your videotape -
A. Begin editing? Not yet. I don't have the technical ability yet.
Q. I'm sorry?
A. I don't have the technical ability yet.
Q. And I assume that if you are successful in putting together some sort of
a film or video you'rE going to display it through Access Pinellas?
A. Oh, yeah, yeah.
Q. Do you intend to distribute it any other way or fashion?
A. You'd probably be able to find it on the Internet somewhere, but it would
be not for profit, though.
Q. Is your movie going to consist of just the videotape and the pictures that
we've been talking about here today or -
A. It depends. It depends on where it goes. This is part of it. It depends.
I might use some of this footage, I might use none of this footage.
Q. Have you talked to other Scientologists or non-Scientologists about the film
or the process of putting it together?
A. I'm sure at some point in time.
Q. Who have you talked to?
A. It depends on what you mean who have I talked to. I mean, if I've just discussed
it as a means of trying to solicit information to put it or get it done properly,
or have I just mentioned it offhandedly in other conversations or if a person
was even a Scientologist because I have no proof that some of these people are
even Scientologists that I've talked to. It's hard to mean what you -- it's
hard to determine what you mean by that.
Q. Have you talked to anyone about your project and getting them to help you
with your project: A. Getting them to help me, no.
Q. Have you asked any people about their views of Scientology?
A. Yeah, I'm sure many. I imagine, yeah.
Q. Have you asked anyone to help you with your film, your project?
A. It depends what you mean by help.
Q. Well, what do you mean by that? Have you gone to anyone and said, hey, can
you help?
A. Not that I remember, possibly. It depends on what -- I don't know, it depends
what you mean by help. I've never asked anybody for technical help like as far
as helping me put it together or putting it on the air or anything like that.
Q. How about for financial help? A. No.
Q. Are you collecting unemployment or anything like that right now?
A. Unemployment, yes.
Q. So you've got some savings that you mentioned and you've also got unemployment
compensatior. that you're receiving?
A. Uh-huh (nods affirmatively). I'm sorry,
yes.
Q. Any other sources of support -
A. No.
Q. Friends, family?
A. No.
Q. Do you have -- do you solicit donations or anything over the Internet?
A. No.
Q. Do you have like a Pay Pal account that you ask people to deposit money into
to support your endeavors?
A. No.
Q. Let me hand you a copy of the permanent injunction. We'll mark that as -
A. Is this the same as this one?
(At this time Plaintiff's Exhibit No. 19 was marked for identification.)
BY MR. POTTER:
Q. It most likely is. We'll mark it -- let me mark it as Exhibit 19 so that
I don't lose track of it.
Now, that document was served on you by my office I think last week, is that
correct?
A. Yes.
Q. I guess you have that copy in front of you?
A. Yes.
Q. Prior to my office serving that document upon you, had you previously seen
it?
A. Had I previously seen this document?
Q. The injunction.
A. No.
Q. I direct your attention to the very first page where it lists the names of
the people. The first name it lists as a defendant or a respondent, rather.
It's the Lisa McPherson Trust, Inc. Have you ever had any dealings with the
Lisa McPherson Trust, Inc.?
A. No.
Q. Do you know what it is or what its purpose was?
A. Sort of, I think.
Q. Tell me what you know.
A. I think back in the day of Lisa McPherson's death these -- I think it was
Mr. Minton had some sort of a business in town for this to - actually I don't
even know what it was for to tell you the truth. It was for -- the only thing
I know that they did was protest I think.
Q. Were you ever a part of their protest?
A. No. Actually I don't even think I was living here at the time. I think I
was living in Dunedin.
Q. How about the next name, Jesse Prince, do you know Jesse Prince?
A. Only from what I've read on the Internet.
Q. What do you know of Jesse Prince?
A. That he was part of some sort of protest down here and that he was a former
high-level member I think.
Q. How about the next name, Grady Ward, do you know Grady ward?
A. No.
Q. How about the next name, Robert S. Minton, Jr.?
A. Just from what I recognize on the Internet.
Q. What do you recognize on the Internet about Robert S. Minton, Jr.?
A. Just that he was involved in these protests I think back in that period of
time. I think it was '99 or 2000 or something.
Q. How about Stacy Brooks, do you know her?
A. Just from that she was part of it, too. These people are actually shown on
a lot of videotapes from Xenu TV, X-e-n-u TV.
Q. Have you ever spoken to Stacy Brooks?
A. No.
Q. Have you ever had -- exchanged e-mails with her?
A. No.
Q. Have you ever exchanged postings with her on any Internet posting site?
A. No. Not unless it was somebody that I didn't know as Stacy Brooks.
Q. How about Jeff Jacobson, do you know him?
A. Just from what, you know, I've seen on the Internet.
Q. Again, what have you seen on the Internet about Mr. -
A. Videos. There's videos from I guess those protest periods of him on the street.
Q. Have you exchanged e-mails with Jeff Jacobson?
A. No, not that I know of.
Q. Have you exchanged Internet postings with Jeff Jacobson?
A. No.
Q. I take it you've never met Jeff Jacobson face to face?
A. No.
Q. How about Patricia Greenway?
A. Have I ever met her?
Q. Do you know Patricia Greenway?
A. Well, it depends on what you mean by know. Yeah, I met her so I guess I do
know her in a way.
Q. Okay. When did you first meet her?
A. Actually it was about two weeks ago. I think it was two weeks ago. I was
right before my -while I was on the street out there in downtown.
Actually I didn't know who she was at first, though, so.
Q. Well, tell me how you met her. Did she walk up and say, hi, I'm Patricia
Greenway or -
A. Yeah. Well, no, she didn't say that. Her and Peter walked up and they said,
hi. We read about -- I think they said we read about you in the paper or something
-- or read about what you're doing, something like that. And, of course, at
first I thought I recognized I guess Peter. His face looked very familiar. But
I thought at first he was a town official for some reason. And a gentleman that
was actually handling me. He was a Scientologist that had been out there handling
me for several days prior to this event by the name of -- what was his name
again. He puts on a production on Pinellas Access. Ron Savelo, S-a-v-e-1-o.
He is a fellow producer. Actually he produces all the Scientology programs on
Pinellas Access. I think there's six of them now.
Anyway, he was down here and -- he had been harassing me for -- I don't know
if you want to call it harassing or not since -- well, yeah, I guess you would
call it harassing. He was verbally cussing at me in my face and saying things
like he was going tc keep my show off the air, and what my problem -- what':
my problem and all this stuff.
Anyway, that had gone on days with this guy. But these two, I guess Patricia
Greenway and Peter Alexander happened to walk up as he was doing it. And she
-- before she even said a word to me, Patricia, at the time I didn't even know
who she was. She said, Why are you bugging this guy? Why don't you just let
him -- leave him be. Don't you have anything better tc do, something like that.
And he was -- he got in theiz face in a very -- actually a very rude way and
was like what the hell, what the "F" is your problem. You need to
just keep on going. Which I guess Peter -- Peter Alexander took offense to and
stepped up as if to say, hey, you don't talk to my girl like that or something.
And Patricia sort of separated the two and I was telling Ron, because I didn't
know who these two people were, but I recognized Peter's face. I thought he
was a town official.
I was like, geez, dude, you know, you just stepped into the wrong face, you
know what I mean because I thought he was assistant mayor or something,
I don't know. I thought he was a higher position in the city somehow. And the
way -- the way he immediately attacked him verbally I was like, oh, great, you
know, this is just -- dude, why you got to -- you know, this is the general
public walking up to the street corner that I happened to be on, you know, and
one of the -- one of the very own producers of the place that I'm doing -- you
know, my show to be aired on has to jump into these unknown people's faces and
g on like that. I was just like oh, dude, man, you don' know what you're doing,
you now, just chill out.
And anyway, they were like, we're going to go across the street and we'll talk
to you later an blah, blah, blah. And of course at the time I didn't know who
they were. So they went across the street an I guess had a cup of coffee at
Starbucks or something. Then I think it was maybe an hour or two later they
came back over after Mr. Ron Savelo was done with me and asked me out to lunch
actually.
At the time I was like well, that's nice, but I don't really know who you are.
And they were like my name is -- and I was like, yeah, well, I recognize the
names, but -- for some reason. And they were like well, we're the producers
of the Prophet. And I was like oh, the Prophet, of course. You know, the Prophet
was a very well-known attempt at putting i out a movie based on the whole story
of Scientology I believe.
I think during the -- during the Lisa McPherson years it for some reason was
not allowed to be released or it was only limited release. There was some sort
of injunction on it I think. I don't know i this is it. I don't think this is
it. But for some reason it was not able to be released on a grand scale after
an initial showing or something like that, but it's rumored on the Internet
to be a pretty telling piece, but nobody has been able to really see it so.
recognized the Prophet, though. I was like, oh, wow. You know, maybe -- yeah,
sure, I'll go to lunch with you.
Q. Now, did you go and have lunch with them?
A. Yeah.
Q. What did you talk about?
A. Basically the movie. I was -- you know, that and actually -- the funny thing
is we -- I guess Peter is an ex-member and we discussed -- I can't remember
what level he was at, but I had -- I had a copy of -- well, a supposed copy
off the Internet of one of their higher levels which is called OT-8, and actually
we were describing a very weird part of it. In part of their confidential student
briefing it was actually a read for those of you whose Christian toes, I may
have stepped on let me take the opportunity to disabuse you of some lovely myths.
For instance -Q. What are -- what are you reading?
A. We discovered a -- we discussed a paragraph in OT-8 that actually L. Ron
Hubbard supposedly wrote that goes on to say, for instance, thE historic Jesus
was not nearly the sainted figure he'd been made out to be. In addition to being
a lover of young boys and men, he was given to uncontrollable bursts of temper
and hatred that the belied the genera: message of love, understanding and other
typical macabre P.R. You have only to look at the history of his teachings inspired
to see where it all inevitably leads. And I thought that was, you know, since
he was supposedly a former high-level member that he could shed some light on
that whole part of it. Because I was wondering if that was, you know, was, of
course on( of the higher teachings in the Church.
Q. What is it that you're reading, sir? Is this a -- what is that?
A. Some of the stuff we were discussing at the -- at the lunch.
Q. Okay. Slow down a little bit. You've gone way ahead of me. This is something
that Mr. Alexander wrote or Mr. Hubbard wrote or someone else?
A. Supposedly Mr. Hubbard wrote and I was just, you know, seeing as I had a
higher -- supposed former higher-level member in front of me I was just asking,
you know -- we were discussing whether it was actually true or not, you know.
If this type of stuff was something he had seen or was it even in the Prophet
and stuff, you know.
Q. The stuff that you were reading or referring to, is that something that you
found on the Internet or -
A. Yeah.
Q. Okay. And you asked Mr. Alexander at lunch?
A. About any -- if he had seen it.
Q. Did you show this particular document to him?
A. Actually I think I did. Well, I think I had it with me. I'm not sure if I
showed it to him or not.
Q. All right. So you asked him about the document, the wording, and you asked
him if it was accurate, is that correct?
A. Yeah. Well, if he had -- yeah, if he had come in contact with it or not.
Q. And what was his response?
A. I don't think he had been at this level. He didn't say he recognized it.
Of course we discusse Xenu which is evidently the secret of OT-3.
Q. Well, let's -- let's stick with one thing at a time. There's the thing that
you were reading before was something I think you said you found on the Internet.
Was that a yes?
A. Yes, I'm sorry, yes.
Q. And your understanding is that that's a writing of Mr. Hubbard or not?
A. Yes. Well, supposedly, depending on -put it this way. I didn't -- I haven't
bought it or attained the level within the Church itself to see if that's what
they would have given me if I was to get tc such a level.
Q. You're saying that it's supposedly a writing of Mr. Hubbard?
A. Uh-huh (nods affirmatively).
Q. Upon what basis do you make that statement?
A. On what former members that have been on the level and have said in relation
to it I guess.
Q. What former member has told you that that's a writing of L. Ron Hubbard?
A. Actually not one in particular. There's far too many to ever be able to give
you a specific name.
Q. And are these communications that you've received through the Internet?
A. Received, no.
Q. Well, you understand that this particular document that you just read is
an L. Ron Hubbard writing, correct?
A. Supposedly.
Q. And you understand that it's his writing upon information that you have received
from I think you said former Scientologists?
A. That had posted in other areas on the Internet, yes. Not that I had received.
Q. That's my question. You received this information through postings that you
have seen on the Internet, is that correct?
A. Not postings, but other people's sites I should say. Other Scientology-related
sites, ex-Scientology-related sites or critical Scientology-related sites.
Q. Is it fair to say that you've learned about these writings through the Internet
and things that you have seen on the Internet or read on the Internet?
A. Yes.
Q. Do you have any knowledge as to the authenticity of the writings?
A. Personally, no.
Q. Now, I think you said that you also discussed something else with Mr. Alexander
and I forget now what it was.
A. Xenu story, of course, which is another one of the supposed secrets I guess
in OT-3.
Q. Again, did you ask Mr. Alexander if he ,
was familiar with that or aware of it?
A. Yeah.
Q. Did he have any information to share on that?
A. No.
Q. What else did you discuss at lunch?
A. The Prophet. What they, you know -- how technically the process -- you know,
how the process -how they came about and did the process technically. I was
just sort of trying to find out more about the video making -- the movie-making
process and who they were and stuff like that.
Q. And did they provide you that information?
A. Yeah, pretty much.
Q. Were they helpful?
A. No. Because it's not really the same -doing what I'm doing and doing what
they did as a moviE isn't -- doesn't even closely resemble it.
Q. How is it different, though?
A. Well, first of all, they did a full-fledged production, movie production.
This is basically home camera stuff, you know what I mean. I'n not at even close
to the level where I would be able tc use anything that they would have used
in a movie format. Put it this way, I mean, it's like a kid playing catch with
his dad in the front yard as opposec to a professional ballplayer going out
every Friday ant playing, you know, big league games in the stadium. It's just
two totally different realms.
Q. Did they offer you any of the materials that they had acquired to their -
A. Oh, no.
Q. -- film productions?
A. Their area I think was more or less a production that they put on that re-told
the story, you know what I mean. So the stuff that they dealt with
isn't -- isn't like the realty genre that, you know, I'm shooting for. It's
more or less props and stage setups and stuff like that they're specifically
doing to tell a story rather than just letting the story tell itself.
Q. Did they buy lunch?
A. Yes.
Q. Have you had any other conversations with a them?
A. A couple times on the telephone concerning, you know, what on earth this
was all about since they were named in it, but...
Q. Tell me about those conversations.
A. Just that why would they -- why would the Church assume that I was part of
it for some reason.
Q. And what did they say?
A. They have no idea why that would be.
Q. Have they in any way encouraged you to continue your activities?
A. Encouraged me?
Q. Yes.
A. Well, yeah, I guess. They were like, you know, verbally encouraging.
Q. What did they say?
A. Well, they said, you know, don't -- the worst thing you can do with the project
is drop it. It's always good to finish the thing you start and stuff like --
even though sometimes you may be in the middle of something that seems too big
for you to tackle or you run into problems that seem insurmountable, you know,
it's about finishing the stuff you start basically anyway.
Q. Did they offer you any financial assistance or financial help in continuing
the project? A. For the project? Patricia gave me a
hundred dollars. I
Q. And what was that for?
A. I think it was for editing help if I needed to buy any software or something
like that for my computer. I didn't have that -- I didn't have any of that stuff
to edit on, my own editing.
Q. And did you use the hundred dollars to buy editing equipment?
A. Actually I did.
Q. What did you buy?
A. A fire wire card.
Q. What is that, is that a card -
A. In order to -- in order to download digital video on your computer you need
a certain type of connection. And my computer hadn't -- didn't come with it
so.
Q. So you bought that and put it into your computer?
A. Uh-huh (nods affirmatively).
Q. Does that now give you the ability to -to download, what, video?
A. Digital video. Supposedly, but I don't have the memory. I don't have the
memory to hold it. Your system needs to have a lot of memory to process i and
edit it, you know, and hold it so you can leaf through it and stuff like that.
But seeing as my computer didn't come with it originally, it obviously didn't
come with it originally for a reason because it didn't have the memory to support
it.
Q. Was the cost of that card approximately a hundred dollars or -
A. Yeah, I think it was $80 -- 88, 80 plus tax. So it was pretty close to a
hundred bucks.
Q. What kind of computer do you have?
A. Actually it's a clone. It doesn't have like a specific name on it. It's --
I forget what the referred to it as. It runs a Windows XP system, I know that.
Q. When did you obtain it?
A. When I left my former employer.
Q. When did you leave your former employer?
A. Whenever my termination date was.
Q. When was that? You know better than I do.
A. You would think so. It was like I think four months ago.
Q. I'm sorry.
A. It was like around four months ago.
Q. And why did you leave?
A. Our business was no longer there to sustain my position.
Q. Were other people let go at the same time?
A. No, I don't believe so.
Q. You say you obtained the computer at that', time, is that correct?
A. Yes.
Q. Did you buy it or did you take it with you from your employer?
A. My employer said I could have it and gave it to me. It was an extra that
they had in the closet so.
Q. You mentioned that Patricia had given you a hundred dollars. How about Peter,
did Peter give you any money?
A. No.
Q. Has Patricia given you any other money other than a hundred dollars?
A. No.
Q. You had lunch with them. You met them on the street corner. You had lunch
with them and you said several phone calls, is that correct?
A. Uh-huh (nods affirmatively).
Q. Was that a yes?
A. Yes.
Q. And the phone calls were about the injunction, is that correct?
A. Yes.
Q. Did you discuss anything else in those phone calls other than the injunction?
A. No.
Q. And how many phone calls were there?
A. I think approximately three by the time I received -- I think the first one
was this. Each time I received a serving. I think the original one was this.
Q. So when you see the injunction, did you call them or did they call you?
A. Actually I called her.
Q. How did you get her phone number?
A. She had called me when I wasn't home, and it was on my call waiting or call
log on my telephone.
Q. And what was the purpose of her call to you?
A. Just to see how I was doing and how the project was progressing. I think
she had probably seer the Bay News 9 article -- I think it was the Bay News
piece on the guy who assaulted me downtown.
Q. All right. So she called you after she read about the assault?
A. I believe so, yeah.
Q. Did you speak to her or did she just leave a message?
A. The first time she just left a -actually she didn't leave a message. She
just left -the number was on my caller ID and the name.
Q. Did you call her back?
A. Yes.
Q. When you called her back, was that before or after you had been served with
the injunction?
A. After.
Q. Okay. Tell me about that conversation.
A. Basically I think I asked her what -what was it about and why are they --
why -- seeing asi i I didn't think it was in the -- even the LOH -- Lisa McPherson
Trust, rather, didn't exist any longer and why they would be serving me with
something like this. Because her name and Pete's name were on it.
Q. And what did she tell you?
A. That she didn't know either. And assumed that it was some sort of -- had
something to do with me filming out there.
Q. How long did that telephone conversation last?
A. A couple minutes.
Q. What was the next telephone call?
A. I think it was when I received the second thing that you guys sent me.
Q. Would that be the subpoena?
A. If that's what it was. Yeah, the subpoenas were duces tecum.
Q. And why did you call her?
A. Wondering what it was, why would they -because they were named on it.
Q. What did she say?
A. That it probably had something to do with me recording, and you know.
Q. What did she suggest you do, if anything?
A. She didn't know actually because since I wasn't named on it she didn't think
I would need to do anything. But of course I'd need to look into that for myself,
so.
Q. And did you look into that for yourself?
A. Tried to. I mean there is so many avenues you can punch up on the Internet.
Sort of told me what a deposition was about and stuff, but.
Q. What did you do? Did you look for information on the Internet?
A. Yeah. Just for reference as to what a subpoena for a deposition meant, what
type of deposition it could be, you know, stuff like that. What you have --
what some of the rules are involved and what they consist of.
Q. Did you talk to anyone other than looking on the Internet?
A. Talk, no. Couple of friends maybe.
Q. All right. The next -- was there a next phone call with Miss Greenway?
A. I think the last one was when I got the videotape one.
Q. What did you-all talk about that time?
A. Well, if it was -- she knew that I could videotape it or not and it was --
if she knew I couldn't videotape it.
Q. And what did she tell you?
A. She thought I could.
Q. What did you do after that?
A. Nothing.
Q. Did you contact Mr. Lirot at some point?
A. Well, yes.
Q. Did you contact him or did he contact you?
A. Actually I contacted him. I had found his phone number on the Internet and
realized that he had an'office here in Clearwater and gave his office a call.
Q. And have you retained Mr. Lirot to represent you in this matter?
A. Yes.
Q. Are you paying for his services or is someone else?
A. That has yet to be determined I believe.
Q. Have you reached an agreement with Mr. Lirot on how he is to be compensated?
A. Not at this time, no.
Q. All right. After receiving the injunction, did you go back down to downtown
, Clearwater?
A. Yes.
Q. Did you read the injunction before going back downtown?
A. Yes.
Q. Did you read the injunction and read and understand those portions that talked
about prohibited areas?
A. Yes. Well, they were kind of hard to understand, but, yeah, I read them.
Q. Did you go into those prohibited areas after reading the injunction?
A. I think so.
Q. Why?
A. It all depends on what I was filming at the time. There were a couple instances
where I was -actually one where I was filming, one in particular I think which
was a violation, which I was filming on Waterson Street. And the reason -- the
first reason I was there was because it was raining and there was an overhang
right on that corner. So I think being on the opposite -- I can't remember if
being on the opposite corner or not is a violation. But I think there was some
sort of interest in it because all the Church security came out with security
cameras to film me.
Q. Were you hoping to provoke that type of reaction?
A. Hoping? Hardly. I can't, you know -- I can't help what other people do. I
mean, if I'm downtown in a public place on a public street corner and that happens
to provoke somebody into something. You know, I have no way of knowing that
nor no way of going and doing that beforehand as a purpose so.
Q. Is that something that you'd like to achieve?
A. It depends on if that happens or not. I don't go there with a specific --
a specific plan I guess you could say in advance. You go downtown and you get
what you can get. I mean, if people are going to, you know, of their own volition
do things. I can't, you know, predetermine that nor can I preempt i so.
Q. Did you have any reaction from security prior to going into the prohibited
areas?
A. Well, no, I guess not. If you call filming me or stuff like that a reaction.
I don't kno what you mean by that.
Q. What were you filming before you went into the prohibited areas?
A. I think the first instance was there was a lot of kids, and I think they
were pre-teen in some cases emptying the.garbage at one of the meal times I
believe on Waterson Street. They evidently after the meal times are the last
to eat, and they do all the dumping of the garbage and cleaning up of the dining
hall evidently because they're always out there -- wer always out there lifting
like these really heavy garbage cans and stuff and dumping them into the dumpster
which sits at like a five-foot level, the top of it. So it was is a very, very,
very telling scene.
Q. What was it telling of?
A. Telling of why on earth would there be kids out there doing this type of
work.
Q. You don't think kids should empty the garbage cans?
A. Well, if you saw the garbage cans and you saw what they were emptying and
how they were doing it, this was definitely not a kid's job, but, you know.
Q. What was it that made it not a kid's job?
A. Well, first of all, the things must have weighed more than 100 pounds because
it took three kid to bring them -- to try to get them to such a level
where they could dump them over the lip of the garbage bin.
Q. All right. So you were filming the kids dumping the garbage cans?
A. Uh-huh (nods affirmatively). Plus, they, you know, of course, weren't dressed
the way the rest of the Sea Org. were dressed. They were all in dirty disheveled
jeans and old T-shirts, most of which looke like they had been stained for quite
a period of time. Q. And is this part of your project?
A. Not necessarily. It depends on what makes itself readily seen on any given
day that I'm down there.
Q. All right. When you went into the prohibited areas, were you filming?
A. Yes.
Q. What were you filming?
A. The second instance I think was the gentleman who assaulted me had pulled
down Waterson Street, and I had gone over to the corner to get exactly what
he was doing down that corner just because it might be of some -- relevant,
and it turns out he was meeting with Church security on the side of the sidewalk.
That was Michael Fitzgerald, by the way, thE gentleman who previously the Church
didn't consider a member for some odd reason or at least that's what the media
had stated.
Q. And did you film him at meeting with security? I'm sorry, was that a yes?
A. Yes.
Q. And what was the purpose of that?
A. You never know what the future holds with them. It could prove some sort
of collision -collusion between the Church and this gentleman who assaulted
me surprisingly enough which actually was overseen by one of the gentlemen here
at the table. Actually I think his name was Peter Mansell which is also the
same gentleman that verbally assaulted me after the assault.
Q. Let's go to the assault, let's talk about what were you doing.
THE COURT REPORTER: Excuse me, Bob, I need to change paper.
THE WITNESS: Actually let me get a cup of coffee, too.
THE VIDEOGRAPHER: We're going to go off the video record at 12:35.
(At this time a brief recess was taken.)
BY MR. POTTER:
Q. All right. Mr. Lonsdale, we were just starting to talk about the altercation
between you and Mr. Fitzgerald.
Can you tell me what you were doing immediately prior to that altercation?
A. Filming.
Q. What were you filming?
A. Street scenes.
Q. Street scenes of what?
A. Downtown corners, whatever was going on. Actually I don't even think I was
actively filming. I had my camera set up, but I'm not sure I was -
actually had it turned on and filming at the moment.
Q. When you say you had it set up, did you