CASE NO. 00-5682-CI-11
                DELL LIEBREICH, as Personal
                Representative of the ESTATE OF
                LISA McPHERSON,
                vs.                                     VOLUME 1
                                                        TESTIMONY OF
                CHURCH OF SCIENTOLOGY FLAG              NANCY MANY
                and DAVID HOUGHTON, D.D.S.,
                PROCEEDINGS:        Defendants' Omnibus Motion for
                                    Terminating Sanctions and Other Relief
                DATE:               July 12, 2002.  Morning Session
                PLACE:              Courtroom B, Judicial Building
                                    St. Petersburg, Florida
                BEFORE:             Honorable Susan F. Schaeffer
                                    Circuit Judge
                REPORTED BY:        Debra S. Turner
                                    Deputy Official Court Reporter
                                    Sixth Judicial Circuit of Florida
                                  KANABAY COURT REPORTERS
                        TAMPA AIRPORT MARRIOTT HOTEL (813) 224-9500
                        ST. PETERSBURG - CLEARWATER (727) 821-3320
                                                   Volume 1, Page 2
            1   APPEARANCES:
            2   MR. KENNAN G. DANDAR
                DANDAR & DANDAR
            3   5340 West Kennedy Blvd., Suite 201
                Tampa, FL 33602
            4   Attorney for Plaintiff
                MR. LUKE CHARLES LIROT
            6   LUKE CHARLES LIROT, PA
                112 N East Street, Street, Suite B
            7   Tampa, FL 33602-4108
                Attorney for Plaintiff
            9   MR. KENDRICK MOXON
                MOXON & KOBRIN
           10   1100 Cleveland Street, Suite 900
                Clearwater, FL 33755
           11   Attorney for Church of Scientology Flag Service Organization
                MR. LEE FUGATE and
           13   MR. MORRIS WEINBERG, JR.
                ZUCKERMAN, SPAEDER
           14   101 E. Kennedy Blvd, Suite 1200
                Tampa, FL 33602-5147
           15   Attorneys for Church of Scientology Flag Service
           17   MR. ERIC M. LIEBERMAN
           18   740 Broadway at Astor Place
                New York, NY 10003-9518
           19   Attorney for Church of Scientology Flag Service Organization
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 3
            1                  (The proceedings began at 9:05 a.m.)
            2                  THE COURT:  You may be seated.
            3                  MR. LIEBERMAN:  We're just trying to get
            4        Mr. Weinberg in.
            5                  THE COURT:  Okay.
            6                  (Mr. Weinberg entered.)
            7                  MR. WEINBERG:  I'm sorry.
            8                  THE COURT:  That's all right.
            9                  Okay.  I have the four packages of
           10        information that I was given.  I made notes on all of
           11        it.  This one says, on the outset -- I can't tell
           12        whose writing this is.  It may be -- it may be
           13        Mr. McGowan's.
           14                  But anyway, one of them says 7/9/02,
           15        Attorneys Dandar and Merrett, and Greenway.  However,
           16        here is my note of last night:  I don't know why these
           17        are listed in this way; no Greenway in here or
           18        attorneys' stuff -- or, legal.  It is letters, e-mail
           19        from LMT -- to LMT from outsiders, non-witnesses, and
           20        some returns.  One is a weekly update from Mr. Prince
           21        to Bob Minton on persons they were working for and
           22        cases they were working on.  None were witnesses in
           23        this case.  Clearly non-discovery e-mails.
           24                  So I have no idea what -- why he raised it,
           25        why he's raised it.
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            1                  MR. DANDAR:  That should be destroyed or
            2        returned.
            3                  THE COURT:  It will be returned.
            4                  MR. WEINBERG:  Destroyed?
            5                  THE COURT:  Or it will be sealed if you all
            6        would like.
            7                  MR. WEINBERG:  It's the LMT's records.
            8                  THE COURT:  I don't care whose it is.  These
            9        are people that have written to LMT.  There's not a
           10        witness in there.
           11                  MR. WEINBERG:  No, Mr. Dandar said destroy
           12        them.  They should be returned --
           13                  THE COURT:  Yes.
           14                  MR. WEINBERG:  -- to LMT.
           15                  THE COURT:  I've got "Return to McGowan."
           16                  MR. DANDAR:  I thought they were just copies
           17        of originals.  If they're originals, yes, return them.
           18                  THE COURT:  I don't know what they are.  I
           19        presume --
           20                  MR. DANDAR:  Sure.
           21                  THE COURT:  -- they were copies to me.  But
           22        there's no reason to have these --
           23                  MR. DANDAR:  No.
           24                  THE COURT:  -- in the court file sealed all
           25        up.  I'm going to return these to Mr. McGowan.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 5
            1                  This is one that does say "Dandar and
            2        Greenway, privileges asserted by the Estate."  So I
            3        suspect they put that kind of on both envelopes.
            4                  Anyway, I wrote:  "Received and found one
            5        attorney-consultant document, which I gave back to
            6        McGowan.  The rest I copied and gave to each side.
            7        One was a duplicate of another already provided.  It
            8        was destroyed by Greenway," which is one -- it's a
            9        page.  I gave it to you like two times, but it's a
           10        third time.  It's just a duplicate.
           11                  That's why I assume that's all right.
           12        Nobody needs three copies of the same thing.
           13                  MR. DANDAR:  Don't need three copies.
           14                  THE COURT:  Okay.  Also found one that had a
           15        Greenway/Minton message, that it was unrelated, very
           16        short.  I returned it because it had -- the length --
           17        the big one was a non-discoverable letter from an
           18        outsider to LMT, but it would be non-discoverable.
           19        This Greenway/Minton message was irrelevant to the
           20        proceeding.
           21                  Then I have this Minton attorney-client
           22        privilege.  These are the ones I told you about
           23        yesterday.  "I reviewed the enclosed e-mail.
           24        Returned.  They're covered by attorney-client
           25        privilege.  Both sides agreed I could return to
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 6
            1        McGowan yesterday."
            2                  And this is the packet that has got the
            3        attorney bills in it and also the one big declaration
            4        of Stacy Brooks --
            5                  MR. WEINBERG:  Stacy Brooks.
            6                  THE COURT:  -- that's already in evidence.
            7                  So now I've been through all the e-mails
            8        that were provided to me.  Mrs. Rudd is making copies
            9        this morning.  Frankly, in the packet of stuff that
           10        I'm providing, there are Greenway e-mails.
           11                  They would have nothing to do with any
           12        consulting she might be doing for you.  So -- and
           13        she's apparently someone that's being listed as a
           14        witness, potential witness, something or other, so I'm
           15        going to provide it.
           16                  MR. DANDAR:  Patricia Greenway is not a
           17        witness.
           18                  THE COURT:  I don't care if she is.  If she
           19        is, those are going to be provided.  There's no reason
           20        not to provide them.  She is a -- she is a principal
           21        on a movie that is the subject of this hearing.  If
           22        for no other reason than that, based on all the orders
           23        that were entered in this case, they're going to be
           24        turned over.
           25                  So you'll get your copy.  If you want to
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                                                   Volume 1, Page 7
            1        object, you can.  If you can convince me that it's a
            2        valid objection, I'll ask for them to be returned.
            3                  MR. DANDAR:  You mentioned this the other
            4        day, the First Amendment right to privacy, individuals
            5        who are not witnesses in this case on subject matters
            6        that have nothing to do with this case --
            7                  THE COURT:  Quite frankly, these are very
            8        critical letters of Ms. Greenway, where they're
            9        talking about problems that she's caused in LMT and
           10        why Mr. Minton is mad at her, and these are her
           11        responses to those.  They're not -- they were copied
           12        to everybody under the sun.
           13                  MR. DANDAR:  Oh, well, if they're copied,
           14        that's different.
           15                  THE COURT:  I mean, this is -- I don't even
           16        know who the person was that did the gossip letter.
           17        There's a big gossip letter in there about things
           18        Patricia Greenway said to them.  Whoever that is is
           19        ratting on Patricia Greenway.  And there's this big
           20        response from somebody in LMT as to each thing and how
           21        untrue it is.  Then there's a response from Patricia
           22        Greenway.
           23                  It is not, by any stretch of the
           24        imagination, private.  And because she has been, you
           25        know, a principal in the movie, it's just easier to
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 8
            1        give them.  You'll get your copy if you want.
            2                  There is one in there -- I can't think what
            3        it was.  There was one in there from Teresa Summers to
            4        you or you to Teresa Summers.  I can't read the
            5        headings.  These headings get so long and confused; I
            6        don't know who is who.  Something about you can have
            7        the books, they're -- mixed in the library or
            8        something.  I gave it rather than not.
            9                  MR. DANDAR:  I don't care about -- that's
           10        not privileged.
           11                  Judge, I have a witness that we announced
           12        yesterday, Nancy Many, in court.  I'm asking the Court
           13        to permit me to put her on out of turn right now at
           14        9 o'clock.  She flew in.  She's out of state.  She's
           15        in the middle of a college course.  She needs to be
           16        back.  She doesn't want to take the risk that
           17        Mr. Oliver may run over and then she won't be able to
           18        leave today and go back.
           19                  THE COURT:  I have no problem with --
           20                  MR. WEINBERG:  But I do have a problem
           21        with --
           22                  THE COURT:  All right.
           23                  MR. WEINBERG:  -- it, your Honor.  This case
           24        has been going on, as you know, since 1997.  The first
           25        time we heard this name was last night at whatever
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                                                   Volume 1, Page 9
            1        time it was, 4:00, 4:30.  That's the first time.
            2                  We -- I can't say that I can be through with
            3        her.  I don't know who she is.  If she has something
            4        relevant to say about this case, she should have been
            5        disclosed in discovery years ago.  Years ago.  I mean,
            6        we're in the middle of Mr. Oliver.  That's what I've
            7        been preparing for.  I mean, we should --
            8                  THE COURT:  I could care less about that,
            9        Counselor.  I've given everybody the privilege to call
           10        witnesses out of turn if there's some reason for it.
           11                  I don't know what she has to say either.
           12        This is -- I gather she has nothing to say relevant to
           13        the case; she has something relevant to this motion.
           14        If she doesn't, why, we'll exclude her.  If she
           15        does --
           16                  MR. WEINBERG:  Mr. Dandar told me she was
           17        going to testify yesterday afternoon about an
           18        introspection rundown.  Now, if that's the case,
           19        leaving everything else aside, that should have been
           20        disclosed years ago.
           21                  And if he'd been in communication with
           22        her -- because he told me he had this secret
           23        witness -- he could have arranged it for a time where
           24        she could come in, you know, at a convenient time, you
           25        know, with appropriate notice to counsel so that we
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                                                   Volume 1, Page 10
            1        could get prepared.
            2                  Yesterday afternoon, at 4 o'clock or
            3        whatever time it was, for the first time he mentioned
            4        the name of this, quote, secret witness that he's been
            5        talking about for a number of days now.  It's baloney.
            6                  MR. DANDAR:  This -- I abided by the Court's
            7        instructions yesterday after court to provide them
            8        with the name of the witness I'm going to call the
            9        next day.  I did that.
           10                  THE COURT:  I don't know of any requirement
           11        under the rule that requires a witness to a motion be
           12        listed ever.  So your objection is overruled.
           13                  Let's go.
           14                  Here are these e-mails.
           15                  MR. MOXON:  Your Honor, I have a very brief
           16        motion --
           17                  THE COURT:  All right.
           18                  MR. MOXON:  -- if I may.  I provided this to
           19        Mr. Dandar and Mr. Lirot.  And the reason I'm bringing
           20        it up now is because it concerns Mr. Jacobsen and some
           21        additional --
           22                  THE COURT:  Who is Mr. Jacobsen?
           23                  MR. MOXON:  Mr. Jacobsen is one of the
           24        employees of LMT.  You may recall on the videotapes
           25        outside of LMT where it had people walking out with
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 11
            1        the files, with the boxes?
            2                  THE COURT:  Yes.
            3                  MR. MOXON:  Mr. Jacobsen was the main person
            4        that was shown, along with Dee Phillips, in those
            5        videos.  And he's been an employee of LMT since, I
            6        believe, January of 2000.  He and Mr. Bunker shared
            7        the video responsibilities at LMT.  In fact, I think
            8        he probably did more videos than anyone else.
            9                  I'll let you read those.
           10                  THE COURT:  Okay.
           11                  Okay.  All this is, is a request for an
           12        out-of-state commission to take his deposition.  Is
           13        that it?
           14                  MR. MOXON:  That's right.  We understand he
           15        lives in Arizona.
           16                  THE COURT:  Did he -- I, of course, don't
           17        even know who he is, so I don't know what he did on
           18        the videos.  Was he putting the boxes in somebody
           19        else's car?
           20                  MR. MOXON:  I think he was putting some in
           21        his car, and he was definitely putting some in
           22        Ms. Phillip's car.  But it's the videos, is what I'm
           23        more interested in.  He may have some paper records.
           24        But definitely he's been -- for the past two and a
           25        half years, he's been making videos while an employee
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 12
            1        of LMT.
            2                  I spoke to Mr. McGowan yesterday and asked
            3        him why Mr. Jacobsen's videos were not produced along
            4        with the other LMT videos.  And he told me that he had
            5        contacted Mr. Jacobsen.  Mr. Jacobsen says he no
            6        longer works for LMT.  And as far as he's concerned,
            7        the videos that he took while he was at LMT are his
            8        own property, and so he wouldn't produce them pursuant
            9        to the Court's orders.
           10                  So I'm simply asking for an out-of-state
           11        commission so we can take his deposition so we can
           12        explore that issue.  If he's got some further
           13        evidence, then obviously we'll try to get ahold of it
           14        relative to this hearing and the counterclaim.
           15                  I talked to Mr. Dandar before this, and he
           16        said if we can arrange it, if he's willing to, we'll
           17        pay to have him to come out here for his deposition.
           18                  THE COURT:  All right.
           19                  MR. DANDAR:  I have a telephone number for
           20        him.  I've been in contact with him.  But I believe
           21        way back, years ago, he did some work for me on this
           22        case, so I would want that protected.  I just can't
           23        remember what it was right now.
           24                  And Mr. Jacobsen, I think from the testimony
           25        you heard, is the one that called to the attention of
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 13
            1        the Clearwater police department or the Tampa Tribune
            2        the death of Lisa McPherson, and that's when it became
            3        a PR flap, a year after her death.  That's when things
            4        started appearing in the newspaper.
            5                  But Mr. Jacobsen, I'm sure -- I have no
            6        control over him, but I'm sure he will cooperate, of
            7        course, with the subpoena of the Court.
            8                  THE COURT:  Okay.
            9                  MR. DANDAR:  But there's a list on there --
           10        there's a search list, same search for Mr. McKeane,
           11        and we have agreed --
           12                  THE COURT:  Mr. who?
           13                  MR. DANDAR:  King, I'm sorry.
           14                  THE COURT:  Not McKeane.
           15                  MR. DANDAR:  King, I'm sorry.  We had agreed
           16        that the six individuals, which include myself and my
           17        brother, will be sealed and delivered to the Court
           18        this -- under the same order of the Court that went to
           19        Mr. King.  That's correct.  We've agreed to that.
           20                  THE COURT:  All right.  Then I have no
           21        problem with this.  Might as well sign it.
           22                  MR. LIEBERMAN:  Your Honor, I just want to
           23        correct Mr. Dandar again.  Mr. Jacobsen is not the
           24        person that called the matter to the attention of the
           25        Clearwater police a year later.  The Clearwater police
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 14
            1        investigation began immediately.  Once again, a
            2        misstatement.
            3                  MR. DANDAR:  We'll let Mr. Jacobsen tell us
            4        that under oath then, how that happened.  I'll stand
            5        corrected --
            6                  THE COURT:  You folks don't agree on
            7        anything, so I don't need to hear it today.  That's
            8        fine.  You had your say and he had his say.
            9                  MR. MOXON:  If I may, your Honor, I'll take
           10        that to your judicial assistant and I'll have copies
           11        made so I can get it out to Arizona.
           12                  THE COURT:  All right.
           13                  MR. DANDAR:  And --
           14                  THE COURT:  Did you all get the e-mails that
           15        I just handed out?
           16                  MR. DANDAR:  I did.
           17                  MR. MOXON:  I didn't.
           18                  THE COURT:  Well, I handed out -- this is my
           19        copy.
           20                  MR. MOXON:  I didn't get a copy.
           21                  MR. FUGATE:  I don't think so.
           22                  THE COURT:  Well, I just handed them out.
           23                  MR. MOXON:  Just a second.
           24                  MR. DANDAR:  Do we have more than one?
           25                  MR. PRINCE:  Yes, we do.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 15
            1                  THE COURT:  Wasn't I up here doing this?
            2        Did I hand them all to one side?
            3                  MR. DANDAR:  We had duplicates.
            4                  THE COURT:  Okay.  There's yours.
            5                  MR. FUGATE:  And, Judge, I put the
            6        transcripts from the 10th in your transcript binder on
            7        the far left.
            8                  THE COURT:  All right.
            9                  MR. DANDAR:  This morning, we started off on
           10        a bad note when Mr. Weinberg called our witness,
           11        Mr. Oliver, a punk while Mr. Oliver was in the
           12        courtroom, and I ask Mr. Weinberg to apologize for
           13        that remark.
           14                  MR. WEINBERG:  I was discussing it with you.
           15                  THE COURT:  Pardon me?
           16                  MR. WEINBERG:  I was discussing the matter
           17        with Mr. Dandar.  I did not know that Mr. Oliver was
           18        in the room.
           19                  THE COURT:  Okay.
           20                  MR. WEINBERG:  Now, although I do see
           21        Mr. Oliver in the room now, if he's not going to be
           22        testifying, he needs to leave.
           23                  THE COURT:  Mr. Oliver, will you --
           24                  I'm not going to make a witness [sic]
           25        apologize.  However, lawyers have to be real careful
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 16
            1        about what they say about people when they're present.
            2                  Mr. Oliver, if you would step outside until
            3        such time as we take this witness out of order.
            4                  MR. OLIVER:  Thank you.
            5                  MR. DANDAR:  Okay.  The plaintiff calls
            6        Nancy Many.
            7                  THE COURT:  What's her name again?
            8                  MR. DANDAR:  Many, M-a-n-y.
            9                  (The Court swore in the witness.)
           10                  THE WITNESS:  Yes.
           11                  THE COURT:  You may lower your hand.
           12                  THE BAILIFF:  Step this way.  Watch your
           13        step.  Speak loud and clear for the Court.
           14                  THE COURT:  You may proceed.
           15                           NANCY MANY
           16   being first duly sworn or affirmed, was examined and
           17   testified as follows:
           18                       DIRECT EXAMINATION
           19   BY MR. DANDAR:
           20        Q    Please state your full name and spell your last
           21   name.
           22        A    Nancy Many, M-a-n-y.
           23        Q    And currently you're a resident of what state?
           24        A    California.
           25        Q    Okay.  And at what point in time did you make a
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                                                   Volume 1, Page 17
            1   decision that you would testify in this case?
            2        A    Pretty much decided Saturday morning, but didn't
            3   actually tell you until Sunday.
            4        Q    Okay.  What is -- what is your date of birth?
            5        A    12/10/52.
            6        Q    And what is the extent of your education?
            7        A    Scientology or regular?
            8        Q    Regular.
            9        A    Well, I'm back to college now.  I had two years
           10   before I joined Scientology.
           11        Q    Okay.  And when did you join the Church of
           12   Scientology?
           13        A    1972.
           14        Q    Okay.
           15        A    January of '72.
           16        Q    And did you join it as a public member or a staff
           17   or something else?
           18        A    Pretty much joined the Sea Organization within a
           19   month.
           20                  THE COURT:  I'm sorry?
           21                  THE WITNESS:  I joined the Sea Organization
           22        within a month.
           23   BY MR. DANDAR:
           24        Q    Okay.  And in doing so, did you sign the Sea Org
           25   contract?
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            1        A    Yep.
            2        Q    Okay.  Is there anyone in particular who asked
            3   you or persuaded you to join the Sea Org?
            4        A    Bill Franks.
            5        Q    And that was up in Boston?
            6        A    Yes.
            7        Q    Okay.  And how long were you a Sea Org member?
            8        A    Until December 1982, so pretty much almost ten
            9   years.
           10        Q    Okay.  What organizations did you work with as a
           11   Sea Org member?
           12        A    I worked at Boston FOLO, which is like a relay
           13   office for Eastern United States in New York.  I worked at
           14   Flag, which is here in Clearwater.  I worked in the
           15   international management section.
           16        Q    What was your highest position in -- as a Sea Org
           17   member?
           18        A    Commodore's staff aide for Division 6.
           19        Q    What were your responsibilities?
           20                  THE COURT:  I'm sorry, what was that
           21        position again?
           22                  THE WITNESS:  Commodore staff aide for
           23        Division 6.  I was LRH's assistant for international
           24        marketing and expansion of Scientology.
           25   BY MR. DANDAR:
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                                                   Volume 1, Page 19
            1        Q    And when you say "LRH," you're talking about
            2   Mr. Hubbard himself?
            3        A    Yes.
            4        Q    And did you ever work for a section called the
            5   Guardian's Office?
            6        A    I was a volunteer for the Guardian's Office in
            7   the Boston area in '74, I think.
            8        Q    How many years?
            9        A    About two.
           10        Q    Okay.  What types of things did you do for the
           11   Guardian's Office?
           12                  THE COURT:  That does seem to be a little
           13        far removed from this case.  1974 through 1976?
           14                  MR. DANDAR:  It's all predicate, Judge.
           15        I'll show you -- I'll show you a connection real soon.
           16                  THE COURT:  All right.
           17        A    I did basically undercover work, pretty much what
           18   a private -- what I feel a private investigator would do.
           19   In fact, my husband at that time at one time was a private
           20   investigator, and it wasn't that much different.
           21             People would work at companies, myself included.
           22   If things came up about Scientology, I would report them.
           23   If reports were thrown in the trash, I would take them
           24   home.  If reports were there that might be of interest, I
           25   would Xerox them.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 20
            1                  THE COURT:  Was this a Scientology-run
            2        business?
            3                  THE WITNESS:  Oh, no.  These were like
            4        government offices or companies.
            5                  THE COURT:  Specifically, like what
            6        government offices do you remember?
            7                  THE WITNESS:  The attorney general's office
            8        a friend of mine was at.  I was at the Consumer
            9        Council.  They handled consumer complaints.
           10   BY MR. DANDAR:
           11        Q    And did you tell your employer you were a
           12   Scientologist?
           13        A    No.
           14        Q    So you were undercover?
           15        A    Yes.
           16        Q    And the people who also were either working for
           17   the Guardian's Office or volunteers, they did the same
           18   things in other government offices?
           19        A    Yes.
           20                  MR. WEINBERG:  Your Honor, objection.  Are
           21        we going to now go through the entire Guardian -- we
           22        heard all about this from Mr. Frank.  We heard how
           23        they were disbanded.  We heard how they were thrown
           24        out of the Church, the leaders of the Guardian, by
           25        Mr. Miscavige and Mr. -- and others.  Why are we
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                                                   Volume 1, Page 21
            1        going -- why is Mr. Dandar going back to 1976, when he
            2        knows that the Guardian's Office hasn't existed since
            3        1981?
            4                  THE COURT:  Well, because I suppose there
            5        has been some testimony that the Office of Special
            6        Affairs does the same things the Guardian's Office
            7        does.  You may dispute that, but there's testimony of
            8        that.
            9                  MR. WEINBERG:  We more than dispute that.
           10                  THE COURT:  I understand that.
           11                  MR. WEINBERG:  And he hasn't put on evidence
           12        of that.
           13                  THE COURT:  Well, you know --
           14                  MR. WEINBERG:  He had a lot of background --
           15        I'm sorry.
           16                  THE COURT:  Sometimes your side doesn't seem
           17        to see what I see, and sometimes his side,
           18        Mr. Dandar's side, doesn't seem to see what I see.  It
           19        seems like that's the case.  I guess that's why you
           20        have a judge.
           21                  I think there has been some evidence to
           22        that.  Whether or not it's been -- it certainly has
           23        been refuted.
           24   BY MR. DANDAR:
           25        Q    How long did you remain a volunteer for the
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 22
            1   Guardian's Office?
            2        A    Just those two years.
            3                  MR. WEINBERG:  She answered that.
            4   BY MR. DANDAR:
            5        Q    And did you ever work for the Office of Special
            6   Affairs?
            7        A    Well, first it was RTC and then a special mission
            8   by RTC and then that got transferred down, because RTC was
            9   higher than OSA.  Then it got bumped down to the Office of
           10   Special Affairs International.
           11        Q    When did you start working for RTC?
           12        A    Probably early '83, 1983.
           13        Q    And what was your first position at RTC?
           14        A    Well, I wasn't in RTC.  I worked on a special
           15   project for them.  I was public.  I was just, you know, out
           16   in the world.
           17        Q    Oh, when did you -- so when you quit the Sea
           18   Org --
           19        A    I went out and got a job.
           20        Q    You went outside of Scientology?
           21        A    Yes, basically.
           22        Q    Okay.  And then you became -- but you maintained
           23   a membership as a public?
           24        A    Exactly.
           25        Q    Okay.  And is that what -- is that the word
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 23
            1   that's used to describe people who are not Sea Org or staff
            2   but members of the Church of Scientology, "public"?
            3                  THE COURT:  I don't need to hear that.  I've
            4        heard that a bunch of times, unless she's going to say
            5        something different.
            6                  MR. DANDAR:  Okay.  Well, I just wanted
            7        to -- because Mr. Weinberg made an objection about
            8        that a couple days ago.
            9                  MR. WEINBERG:  Excuse me?
           10                  THE COURT:  I don't really need it.
           11   BY MR. DANDAR:
           12        Q    Okay.  So when you became a public member of the
           13   Church of Scientology, explain how you were working for
           14   RTC.
           15        A    Well, first -- for the first six months or
           16   whatever after I stopped being on staff, after a while they
           17   did put me on the list of people that were declared.  I was
           18   thrown out and -- which means I would be shunned.  But then
           19   that got corrected.  And at the same time that that got
           20   corrected, some friends sent me down to RTC, that the
           21   person in charge of the mission there at that time wanted
           22   to interview me.
           23             And the first thing that he had me do was go to
           24   David Mayo, who had been -- one of the technical heads of
           25   Scientology, had started a splinter group.  And there was
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 24
            1   concerns about copyrights.  And they wanted to see if I
            2   could get connected in there, which I did.
            3        Q    As an undercover?
            4        A    Undercover.
            5        Q    And you were a public --
            6                  THE COURT:  Could I --
            7   BY MR. DANDAR:
            8        Q    -- member?
            9                  THE COURT:  Pardon me.  When you indicated
           10        you were a Sea Org member until 1982, I take it you
           11        were a public member thereafter until some point in
           12        time?
           13                  THE WITNESS:  Exactly.
           14                  THE COURT:  When would that have been?
           15                  THE WITNESS:  The real final parting?
           16                  THE COURT:  Right.
           17                  THE WITNESS:  It's really kind of cloudy,
           18        but I'd say -- '96, '97 -- I mean, really in my head,
           19        where I said, "You know what?  I'm not a member
           20        anymore," probably not until '97.
           21                  THE COURT:  So from 1982 until 1997, you
           22        were a public member --
           23                  THE WITNESS:  Basically.
           24                  THE COURT:  -- except for this period of
           25        time when you were --
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 25
            1                  THE WITNESS:  Yes, exactly.
            2                  THE COURT:  But even then, you perceived
            3        yourself a member.  Is that correct?
            4                  THE WITNESS:  Yes.
            5   BY MR. DANDAR:
            6        Q    So --
            7                  THE COURT:  You say -- I'm sorry,
            8        Mr. Dandar.
            9                  Did you say '97 or '98?
           10                  THE WITNESS:  1996, 1997 -- either/or, to be
           11        honest.
           12                  THE COURT:  Okay.
           13                  THE WITNESS:  It was a real kind of fade.
           14                  THE COURT:  All right.  Thank you.
           15   BY MR. DANDAR:
           16        Q    When you were a public member of the Church of
           17   Scientology, you were also working as a volunteer for RTC?
           18        A    Correct.
           19        Q    Okay.  And then in your capacity as working as a
           20   volunteer for RTC, you worked for OSA?
           21        A    Well, after RTC.  See, I was -- you have
           22   handlers; you have case officers.  So initially my case
           23   officer wasn't RTC; it was a mission --
           24        Q    Okay.
           25        A    -- a group of people assigned specifically.  And
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 26
            1   they were my people.  And then as that group was shifted --
            2   which I do not know why; I wasn't privy to that -- then my
            3   case handler became somebody more significant.
            4        Q    How long did you stay working, volunteering,
            5   working as a volunteer, for RTC slash OSA slash OSA Int?
            6        A    Probably two and a half years.
            7        Q    And was there any difference between the work in
            8   the Guardian's Office when it was called the Guardian's
            9   Office and the work for OSA when you were volunteering to
           10   work for OSA?
           11        A    As I knew at that time?  The differences were
           12   with OSA they used a lot more private investigators and
           13   they ran things through the attorneys.  You would get
           14   like -- there would be an operation or you would get
           15   briefed to go do something.  And they would say, "Oh, we
           16   have to run this through the attorneys first."  There was a
           17   lot more of that.
           18             But otherwise in terms of the day-to-day, "Go
           19   pretend you're a friend and tell us what they're doing" or
           20   "Go here and tell us what they're doing," that was all the
           21   same.  The information and the intelligence-gathering was
           22   the same.
           23        Q    So -- so your activities of spying on people in
           24   the Guardian's Office was the same as your spying for OSA?
           25                  MR. WEINBERG:  Objection to the form.  Could
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 27
            1        he just ask questions?
            2                  THE COURT:  Sustained.  She uses the term
            3        "gathering information."  She's not yet used the word
            4        "spying," so I don't think you ought to use it here.
            5                  MR. DANDAR:  Okay.  All right.
            6   BY MR. DANDAR:
            7        Q    When you went undercover, as you said, in David
            8   Mayo's organization, what was your assignment?
            9        A    To befriend, to be -- to find out what was going
           10   on.  Sometimes there would be something specific for me to
           11   do.  Other times it was just to be there and find out what
           12   they were doing and report back.
           13        Q    Okay.  And what -- did you tell this organization
           14   run by Mr. Mayo that you were a -- a worker -- a
           15   Scientologist?
           16        A    An agent for the Church?  No, I did not.
           17        Q    What did you tell them about your affiliation
           18   with the Church?
           19        A    Because I had been on that list in writing that I
           20   was thrown out of the Church, that was my -- you know, at
           21   that time there was a very large schism within the Church.
           22                  THE COURT:  What date was that?  I mean,
           23        what year was that?
           24                  THE WITNESS:  1983 I started.
           25                  THE COURT:  No, I'm sorry.  This list that
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 28
            1        you were on, this schism, where you're talking about a
            2        lot of folks were on the list, was this --
            3                  THE WITNESS:  I don't have a copy right to
            4        hand, but it was back in '80 to '83 I was on the list.
            5        It was a very long list.
            6                  THE COURT:  Okay.
            7                  THE WITNESS:  Very long list.
            8   BY MR. DANDAR:
            9        Q    Did that list have anything to do with the power
           10   struggle between David Miscavige and Pat Broeker?
           11        A    Yes, well -- yes.  Some of the people did -- the
           12   first time I saw some of the names that were to be removed
           13   from their positions, most of them were very, very high,
           14   and I thought that this was written by a non-church member,
           15   that somebody had written -- it was so bizarre at that
           16   time.  This was so amazing, that these senior executives
           17   would be all removed together and said they were like bad
           18   people, that I thought that was a made-up thing by some
           19   anti-Scientologist.
           20        Q    When you were undercover in the David Mayo group,
           21   did you submit to a deposition?
           22        A    No.
           23        Q    Were you deposed about your working in the David
           24   Mayo group?
           25        A    An affidavit at the very end.  That's what --
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 29
            1   that's when I became a potential witness in a court case,
            2   and they had me submit an affidavit.
            3        Q    Did there come a point in time when you gained
            4   knowledge that there was a court order prohibiting
            5   Scientology from having anybody working for David Mayo?
            6        A    Correct.  They -- during this time, when I was
            7   still going in there, there was at one time a court order
            8   that said all people -- all agents of the Church, all
            9   members of the Church, have to stay within a certain, you
           10   know, feet order.  You know what I mean?
           11        Q    An injunction?
           12        A    Yes, it was an injunction.
           13        Q    And to your knowledge, personal knowledge, was
           14   that order honored?
           15        A    No, it was not.
           16        Q    How was it broken?
           17        A    Well, first I was asked to go up there.  And I
           18   said:  Well, how can I go up this weekend?  Isn't there an
           19   injunction?
           20             And I honestly don't remember.  I know there was
           21   hesitation and "I'll get back to you and I've got to check
           22   with the lawyers," because everything was checked by the
           23   lawyers.  So whether I came up or not, I can't honestly
           24   say.
           25             But I do know that they had at least two agents
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 30
            1   in there on a permanent basis that were agents of the
            2   Church, reporting regularly to the Church, that had staff
            3   jobs there.  They were there all the time.  And they were
            4   left just doing their business as usual.
            5        Q    Did they report to the attorneys or to someone
            6   else?
            7        A    No.  They reported to the same person that I
            8   reported to.
            9        Q    Was that an attorney?
           10        A    No, it was not.
           11        Q    What post did that person have?
           12        A    Well, initially he was in RTC.  There was an RTC
           13   mission there.
           14        Q    Was this before OSA was formed?
           15        A    No.  This was after OSA.  This was during that
           16   transition period.
           17        Q    Okay.
           18                  THE COURT:  Who did you report to?  Are we
           19        not going to find out?
           20   BY MR. DANDAR:
           21        Q    Who did you report to?
           22        A    His name?
           23        Q    Yes.
           24        A    Gary Klinger.
           25        Q    Klinger?
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 31
            1        A    M'hum (affirmative).
            2        Q    K-l-i-n?
            3        A    Yes.
            4                  THE COURT:  And Mr. Klinger was where in the
            5        organization?
            6                  THE WITNESS:  He was on mission from RTC.  I
            7        do not know if he was an official RTC staff member,
            8        because sometimes they pull people from other
            9        organizations to do work for them.  But that was his
           10        position while he was my case officer.
           11                  THE COURT:  Okay.
           12   BY MR. DANDAR:
           13        Q    Do you know who his senior was?
           14        A    I know now, yes.  I didn't at that time.
           15                  MR. WEINBERG:  Well, excuse me, your Honor.
           16        She knows now based on something somebody has told
           17        you?
           18                  THE WITNESS:  No.  I read it on the
           19        Internet.
           20                  MR. WEINBERG:  Well, I object to her
           21        testifying as to who the senior was if she read it on
           22        the Internet.
           23                  THE COURT:  Sustained.
           24                  MR. DANDAR:  Okay.
           25   BY MR. DANDAR:
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 32
            1        Q    But his senior would have been somebody in RTC,
            2   right?
            3        A    Correct.
            4                  THE COURT:  What was the man's name?  I
            5        got --
            6                  THE WITNESS:  Klinger.
            7                  THE COURT:  Klinger.
            8                  THE WITNESS:  Gary Klinger.
            9                  THE COURT:  Thank you.
           10                  THE WITNESS:  We weren't allowed, when we
           11        were doing it -- like I was spied upon.  There were
           12        people that I never knew who they were who would check
           13        back on what I was doing.
           14   BY MR. DANDAR:
           15        Q    So what do you mean?  You weren't allowed to know
           16   what?
           17        A    It's on a need-to-know basis.  That's what they
           18   call it, a need-to-know basis.  So you would only know the
           19   little, tiny part that you were involved in.
           20        Q    Okay.  And then you had people that -- from RTC
           21   who were spying on you?
           22        A    I don't know who they were.  But I would come
           23   back and people had watched me and observed me and they had
           24   reported in on what I had done.
           25        Q    And how would you find that out?
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 33
            1        A    I would be told by my case officer.
            2        Q    Okay.
            3                  THE COURT:  In other words, you were -- you
            4        were -- they wanted you to know that folks were
            5        watching what you were doing?
            6                  THE WITNESS:  Exactly.
            7                  THE COURT:  So they weren't hiding that from
            8        you; they were telling you.
            9                  THE WITNESS:  That I was being watched, but
           10        I never knew who that person -- those people were.
           11                  THE COURT:  But I guess what I'm saying is
           12        you were being made aware that you were being
           13        watched --
           14                  THE WITNESS:  Right.
           15                  THE COURT:  -- so that you knew this when
           16        you were making your report.
           17                  THE WITNESS:  Exactly.
           18   BY MR. DANDAR:
           19        Q    Who else did you go undercover for in addition to
           20   David Mayo?
           21        A    A lot, actually.  I would just happen into things
           22   sometimes.  I went to go get a job at what I thought was a
           23   normal computer company, and it ended up being someone
           24   connected with the European squirrels at that time.
           25   Squirrels are people that leave the Church but still
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 34
            1   practice the Church.
            2             But a gentleman named Captain Bill, Captain Bill
            3   Robertson -- he was a major force in the Sea Org.  And
            4   during the split with David Mayo and David Miscavige and
            5   whatnot, he ended up in the Org.
            6             And this little computer company that I thought
            7   was a regular computer company ended up being like run by
            8   him.  You know, he was -- his deputy ran the company.
            9        Q    Were you -- were you undercover in that company?
           10        A    Well, then I reported in to my case officer, and
           11   I said, "Oh, my god, I got this job," you know.
           12             And he said, "Well, go ahead and just report
           13   whatever you have."
           14             And he would feed it back to -- I think it was --
           15   he would feed it back to the person who was -- actually
           16   handled the European operations.
           17        Q    And the people at the computer company, did they
           18   know you were a Scientologist?
           19        A    Yes.  They thought -- I'm trying to get this
           20   straight.  They thought that I was -- see, there were
           21   regular Scientologists in the company.  And this was at a
           22   higher level of the organization.  The executives were the
           23   ones connected with the European squirrel group, right?
           24                  THE COURT:  I'm getting real confused.  The
           25        word "squirrel," I don't know what that is.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 35
            1                  MR. WEINBERG:  It's people that have left
            2        the Church that are trying to put on a -- trying to
            3        use Scientology as a -- their own --
            4                  MR. DANDAR:  (To Mr. Prince)  Shh.
            5                  MR. WEINBERG:  It's an altered version of
            6        Scientology, in other words.  And so they are
            7        squirrels and they are disaffected and they are -- you
            8        know, they are enemies of the Church of Scientology.
            9        They're people that have essentially --
           10                  THE WITNESS:  Yep.
           11                  THE COURT:  You agree with that?
           12                  THE WITNESS:  Yes, I do.
           13                  THE COURT:  Okay.  So this would be like
           14        this David Mayo --
           15                  THE WITNESS:  Exactly.
           16                  THE COURT:  -- was using the Church's
           17        literature, supposedly was sued for trademark
           18        violations --
           19                  MR. WEINBERG:  Exactly.
           20                  THE COURT:  -- or whatever?  That would be
           21        considered a squirrel group?
           22                  MR. WEINBERG:  That's a squirrel group.
           23        They take the copyright and then try to open up their
           24        own organization --
           25                  THE WITNESS:  Exactly.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 36
            1                  MR. WEINBERG:  -- with it, violating all
            2        kinds of law.
            3                  THE COURT:  Okay.  When you say this was a
            4        squirrel group --
            5                  THE WITNESS:  It was like the European
            6        version of David Mayo.
            7                  THE COURT:  Okay.
            8                  THE WITNESS:  They went a little different
            9        in Europe.
           10                  THE COURT:  Okay.
           11                  MR. DANDAR:  Mr. Hubbard's dictionary
           12        defines it like that.  And there's many definitions,
           13        actually, but one of them says:  "Going off into weird
           14        practices or altering Scientology.  Only comes about
           15        from non-comprehension."  And it goes on and on.
           16                  Anyway.
           17                  THE WITNESS:  So I was involved in that.  I
           18        was involved in just about anything else that would
           19        kind of come my way.  And there would be little minor
           20        things that would be given to me.  You know:  "Oh,
           21        there's going to be a meeting over here.  Could you go
           22        and tell us what happens?"
           23                  THE COURT:  I'm sorry, I think I interrupted
           24        your train of thought.  You had been asked whether or
           25        not they knew you were with the Church of
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 37
            1        Scientology --
            2                  THE WITNESS:  Oh, yes.
            3                  THE COURT:  -- and you started to talk about
            4        that.
            5                  THE WITNESS:  Yes, because it was very
            6        complicated, because I went and got their job -- I was
            7        hired by their general membership as I was a regular
            8        Scientologist.  And they did not know I was spying for
            9        OSA and going to David Mayo's.  Right?  But then I
           10        found out that the leadership, the executives --
           11                  THE COURT:  In the company?
           12                  THE WITNESS:  -- in this company --
           13                  THE COURT:  Okay.
           14                  THE WITNESS:  -- who were keeping it hidden
           15        from the regular staff -- right? -- were in actual
           16        fact connected with both David Mayo's in America and
           17        Captain Bill in New York.
           18   BY MR. DANDAR:
           19        Q    Okay.  All right.
           20        A    So because I was at David Mayo's, okay, then I
           21   can't have a regular job here because they know.  And then
           22   I became a conduit for European information.
           23                  MR. WEINBERG:  And the date of this is?
           24                  THE WITNESS:  This would be '84, '83.  It
           25        would be -- yes, '83, '84.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 38
            1   BY MR. DANDAR:
            2        Q    Okay.  Did there -- did there come a -- well, any
            3   other operations that you participated in with OSA or RTC?
            4        A    Well, I remember -- I mean, like there would be
            5   like little things, like say, for example, this woman -- I
            6   don't even remember her name -- but she would be in
            7   deposition with Scientology all day.  And then I would get
            8   a call like, "Hey, she's going to be over at this friend of
            9   a friend's house after the deposition," and I would go
           10   there just to get their reaction from the deposition.
           11        Q    And would you go --
           12                  THE COURT:  I don't understand that.
           13                  THE WITNESS:  A witness --
           14                  THE COURT:  A witness for whom?
           15                  THE WITNESS:  She would be against
           16        Scientology.
           17                  THE COURT:  In a case?
           18                  THE WITNESS:  Yes.  She was a witness in a
           19        case that Scientology was deposing.
           20                  THE COURT:  Okay.  She was a witness against
           21        Scientology?
           22                  THE WITNESS:  Against Scientology.  And
           23        after the day's deposition, they wanted me there to
           24        get her reaction, to get some feedback.
           25                  THE COURT:  Did she know that you were doing
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 39
            1        this?
            2                  THE WITNESS:  For Scientology?  Absolutely
            3        not.  Absolutely not.
            4                  MR. WEINBERG:  Could we have a name?
            5                  THE WITNESS:  I can't remember her name.
            6   BY MR. DANDAR:
            7        Q    A date?  Year?
            8        A    Well, it would be between that period, '83, '84.
            9        Q    Okay.
           10                  THE COURT:  Can you tell me how -- two
           11        questions I would have, maybe.  One is, How did you
           12        just end up at somebody's house?  I mean, normally you
           13        have to be invited.
           14                  THE WITNESS:  Because it would be a friend
           15        of a friend.  They knew that I knew somebody who was
           16        friends with her.
           17                  THE COURT:  Okay.  So you'd just try to be
           18        at -- end up at the same place where she was --
           19                  THE WITNESS:  Exactly.
           20                  THE COURT:  -- and listen in?
           21                  THE WITNESS:  Exactly.
           22                  THE COURT:  See if she said anything, and if
           23        so, report back.
           24                  THE WITNESS:  Exactly.
           25                  THE COURT:  Okay.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 40
            1   BY MR. DANDAR:
            2        Q    Before you left the Sea Org, did you ever work at
            3   the Celebrity Center?
            4        A    Yes, I did.
            5        Q    Where at?
            6        A    Celebrity International in Los Angeles.
            7        Q    And what was your position there?
            8        A    President.
            9        Q    How long did you have that?
           10        A    At least a year.  I was only there for two years.
           11        Q    And this Celebrity Center in Los Angeles, that's
           12   where all the movie stars are?
           13        A    They -- some of them, yes.
           14        Q    And when you became a public member, did you ever
           15   go to Flag in Clearwater?
           16        A    Yes.
           17        Q    In fact, when you were a Sea Org member, you were
           18   at Flag in Clearwater?
           19        A    Yes, I was.
           20        Q    Okay.  And do you recall when you went to Flag in
           21   Clearwater as a public member?
           22        A    I don't have at hand the exact dates, but it
           23   would be most definitely after 1986.  Okay?  And I think my
           24   last trip was whenever the L.A. earthquake was.  What was
           25   that, '94?
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 41
            1                  THE COURT:  The what, ma'am?
            2                  THE WITNESS:  Earthquake, the big earthquake
            3        in Los Angeles.  That would be, I believe, 1994.
            4   BY MR. DANDAR:
            5        Q    So you were at Flag in Clearwater in '94?
            6        A    In '94.
            7        Q    Where did you stay?
            8        A    In '94 I stayed at the Sandcastle.  In earlier
            9   trips --
           10                  MR. MOXON:  May I interrupt?  Mr. Oliver is
           11        standing right outside, kind of listening at the door.
           12        I just walked by, and it's very easy to hear.  For
           13        some reason, he's standing right there.
           14                  THE COURT:  Mr. Dandar or Mr. Lirot, would
           15        you --
           16                  MR. DANDAR:  We'll take care of it, your
           17        Honor.
           18                  (Mr. Lirot briefly left the courtroom.)
           19   BY MR. DANDAR:
           20        Q    Did you ever stay at the Fort Harrison Hotel?
           21        A    Yes, I did.
           22        Q    And where in the hotel?
           23        A    Cabana.
           24        Q    And the cabana that you stayed in, can you tell
           25   us what type of floor it had?
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 42
            1        A    Tile.
            2        Q    Do you know --
            3                  MR. WEINBERG:  Could we date this?
            4                  THE COURT:  1994.
            5                  MR. WEINBERG:  No, no.
            6                  THE WITNESS:  No, '94 --
            7                  MR. WEINBERG:  She was at Sandcastle in '94.
            8        Then she asked -- could we date it?
            9                  THE WITNESS:  So this would have been like
           10        '88, '88.
           11                  MR. DANDAR:  Okay.
           12                  THE WITNESS:  Maybe '90.
           13                  THE COURT:  I'm sorry, I didn't pick that
           14        up.  You were in Flag in 1988 and again in 1994?
           15                  THE WITNESS:  I do believe I had three
           16        trips.
           17                  THE COURT:  You were going to Flag as other
           18        parishioners do --
           19                  THE WITNESS:  Exactly.
           20                  THE COURT:  -- to get the technical --
           21                  THE WITNESS:  Exactly.
           22                  THE COURT:  -- improvement.
           23                  THE WITNESS:  Exactly.
           24                  THE COURT:  Okay.  And so one of the times
           25        you were there in '88, you stayed in the cabana,
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 43
            1        that's when the floor of the cabana was tiled.
            2                  THE WITNESS:  Exactly.
            3                  THE COURT:  The last time you were there --
            4                  THE WITNESS:  I was in the Sandcastle.
            5                  THE COURT:  -- you were in the Sandcastle.
            6        Okay.
            7   BY MR. DANDAR:
            8        Q    And that was in 1994?
            9        A    Correct.
           10        Q    Were you volunteering for any organization of
           11   Scientology in the '90s?
           12        A    No.  I would still get phone calls, though, to do
           13   things, but I never did them.
           14        Q    Who would you get phone calls --
           15        A    Except for once, I did do one thing.  After --
           16   after I came forward with the affidavit -- there were a few
           17   other things.  I was having a lot of trouble with what was
           18   going on, truthfully.
           19             I couldn't resolve for myself who was right, who
           20   was wrong, what side, this side -- I mean, it was really
           21   difficult to go back and forth between people that had left
           22   the Church and then back to people in OSA.
           23             And it was -- I -- I -- truthfully, I think I
           24   lost myself in there and I lost my opinions in there,
           25   because it gets very confusing when people -- when people
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 44
            1   are black and white, you know.  I'd go to David Mayo or any
            2   of the critics, I mean, I didn't -- you know, and they
            3   would be like the Church is all bad.  And then you would go
            4   to the Church, and it would be like the critics are all
            5   bad, just this -- you know, and both sides, to be honest, I
            6   think from my perspective of going back and forth, to me
            7   they're equally as bad.  I mean, they're just -- they do
            8   things that are --
            9                  MR. WEINBERG:  Your Honor, objection.  Is
           10        there a question?
           11                  MR. DANDAR:  Yes.
           12                  THE COURT:  I don't remember what it was.
           13                  MR. WEINBERG:  I think what it was is
           14        whether she had volunteered to do anything in the
           15        '90s --
           16                  THE WITNESS:  So what I'm answering is, yes,
           17        I was asked to do things.
           18                  THE COURT:  Counsel, don't be so -- I mean,
           19        this lady is about as fair-minded as I've heard yet.
           20        This is a lady that really thus far hasn't said
           21        anything other than both sides seemed to be equally
           22        rabid, although she didn't quite say it that way,
           23        about the other --
           24                  MR. WEINBERG:  I'm not quibbling --
           25                  THE COURT:  -- black and white --
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 45
            1                  MR. WEINBERG:  I was just asking for
            2        questions and answers.
            3                  THE COURT:  Well, I understand.  But I found
            4        it rather interesting.  It was my observation as well.
            5   BY MR. DANDAR:
            6        Q    Did -- when was the last time that you were
            7   asked --
            8                  THE COURT:  When you say black and white,
            9        ma'am, that's what you mean, that they're fairly stuck
           10        on their position?
           11                  THE WITNESS:  Exactly.  I call it
           12        black-and-white thinking: all good, all bad.  And I
           13        saw that because I did have that experience of going
           14        back and forth.
           15                  THE COURT:  And the Church felt like the
           16        anti- -- their critics were out to hurt them and they
           17        were all bad, and the critics thought that the Church
           18        was all bad and out to hurt them.
           19                  THE WITNESS:  Exactly.
           20                  THE COURT:  And nobody wanted to waver off
           21        of that.
           22                  THE WITNESS:  Exactly, exactly.  And my very
           23        last thing before they pulled me into the court case
           24        to do an affidavit was a weekend with this woman who
           25        had been LRH's personal PR, and she --
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 46
            1                  THE COURT:  What is a PR?
            2                  THE WITNESS:  Public relations.  But she was
            3        a personal.  Right?
            4                  THE COURT:  His personal public relations
            5        person?
            6                  THE WITNESS:  And she --
            7                  MR. WEINBERG:  Are we back in the '80s,
            8        ma'am?
            9                  THE WITNESS:  I'm sorry.  We are in '85.
           10        We're in 1985.  And she -- before I had a weekend with
           11        her, I was given a briefing, because that's normally
           12        how it works.  And they brief you on these various
           13        different things.  It's just individually it had taken
           14        a toll on me, what side was what.  And I remember in
           15        the briefing being told things that I felt I shouldn't
           16        know.
           17   BY MR. DANDAR:
           18        Q    Such as?
           19        A    Personal, private, intimate things about this
           20   woman.
           21        Q    Such as?
           22        A    Sexual practices.
           23        Q    And why did you spend the weekend with her?
           24        A    I had befriended her.  She was somebody that -- I
           25   had never been close to her when we were in the Sea Org and
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 47
            1   she had actually been quite a not-nice executive.  She had,
            2   I thought, hurt several of my friends.  And I thought it
            3   was a little over the top to go testify -- to be LRH's
            4   personal public relations officer and go testify against
            5   him.  So I didn't have qualms about spying on her.
            6             But through this weekend, this woman actually
            7   gave me a way out, which was a third kind of view of it,
            8   which was not black-and-white thinking.  And it was --
            9   actually ended up being quite a gift for me from that
           10   woman.
           11             And after that weekend with her, I did not report
           12   in to OSA.  I could not report on that woman.  And within a
           13   week, I was pulled in to make an affidavit.
           14        Q    Do an affidavit about her?
           15        A    No.  It was about the David Mayo case, which I
           16   didn't understand, really, why -- I mean, it was an
           17   affidavit and I was a potential witness, but I really
           18   didn't have the knowledge of that particular case.
           19        Q    Okay.
           20                  THE COURT:  What was the David Mayo case,
           21        which of these cases?
           22                  THE WITNESS:  Copyright violations.
           23                  MR. WEINBERG:  It was a copyright.  He had
           24        taken the Church --
           25                  THE COURT:  I'm sorry, what is it as far as
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 48
            1        the names?  Is it one of these names that I've heard
            2        of?
            3                  MR. WEINBERG:  No.
            4                  MR. DANDAR:  It's known as Wollersheim II.
            5                  MR. WEINBERG:  No, it's not.
            6                  THE WITNESS:  The NOTs case.
            7                  MR. LIEBERMAN:  I believe it's Religious
            8        Technology Center against Advanced Ability Center,
            9        David Mayo, et cetera, et cetera.  And it involved the
           10        use by the Advanced Ability Center, headed by David
           11        Mayo, of NOT materials which --
           12                  THE COURT:  Okay.
           13                  MR. LIEBERMAN:  -- had been stolen and
           14        people had been convicted in Denmark for stealing the
           15        materials, bringing them --
           16                  THE COURT:  I just simply wanted to know
           17        what was the name of the case.  I now remember reading
           18        something about this in some document.
           19                  MR. WEINBERG:  And it was in the early '80s.
           20                  THE COURT:  Right.  Okay.  I'm sorry, I just
           21        was trying to --
           22                  THE WITNESS:  That's okay.
           23                  THE COURT:  -- put myself into what case we
           24        were talking about here.
           25   BY MR. DANDAR:
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 49
            1        Q    So I'd like to -- let's get into the '90s, okay?
            2                  THE COURT:  Who did you give an affidavit
            3        for in that case?
            4                  THE WITNESS:  The Church.
            5                  THE COURT:  For the Church?
            6                  THE WITNESS:  Oh, yes.
            7                  THE COURT:  They asked you to come in and
            8        give an affidavit?
            9                  THE WITNESS:  I was a potential witness.  I
           10        was on standby to be a witness.
           11                  THE COURT:  You gave an affidavit that was
           12        true?
           13                  THE WITNESS:  Yes, absolutely.
           14                  THE COURT:  They didn't try to get you to
           15        lie or anything like that?
           16                  THE WITNESS:  No.
           17                  THE COURT:  So you gave an affidavit -- or I
           18        don't know whether it's called an affidavit or
           19        declaration.
           20                  THE WITNESS:  Oh, maybe it was a
           21        declaration.
           22                  THE COURT:  They're the same thing.
           23                  THE WITNESS:  Okay.
           24                  THE COURT:  Different states call them
           25        different things.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 50
            1                  THE WITNESS:  Okay.
            2                  THE COURT:  But you were asked to tell
            3        something about what you knew about --
            4                  THE WITNESS:  Exactly.
            5                  THE COURT:  -- this case?
            6                  THE WITNESS:  Right.
            7                  THE COURT:  And you did that.
            8                  THE WITNESS:  Absolutely.
            9                  THE COURT:  Okay.
           10   BY MR. DANDAR:
           11        Q    Did you admit in the affidavit that you were
           12   undercover?
           13        A    Yes.
           14        Q    Did you admit in the affidavit that there were
           15   other undercover agents of Scientology in the David Mayo
           16   organization that no one knew about?
           17        A    No.
           18        Q    Did that concern you, that you might be called to
           19   court to testify about that?
           20        A    Yes.
           21                  THE COURT:  You didn't say in this affidavit
           22        that there weren't such people either.
           23                  THE WITNESS:  No.
           24                  THE COURT:  In other words, you did not
           25        perceive to give any false --
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 51
            1                  THE WITNESS:  Exactly.
            2                  THE COURT:  -- testimony in your affidavit,
            3        nor do you believe you were asked to.  Is that right?
            4                  THE WITNESS:  Correct.
            5                  THE COURT:  You just knew if you were called
            6        as a witness, the lawyer might --
            7                  THE WITNESS:  Might say --
            8                  THE COURT:  -- ask you questions --
            9                  THE WITNESS:  Exactly.
           10                  THE COURT:  Okay.
           11   BY MR. DANDAR:
           12        Q    There is something in Scientology called the
           13   bridge.  How high up on the bridge did you go?
           14        A    Well, I basically had both personal auditing
           15   level -- it was the original OT VII, which then changed,
           16   and I did the OT V.  Okay?  So I didn't do the solo NOTs,
           17   but I did the audited NOTs of OT V.  But I had previously
           18   done up to OT VII.
           19             On the administrative side of it, I'm very highly
           20   trained.  I've done pretty much every course that there is,
           21   the FEBC course, OEC course, and the DSEC course, the
           22   evaluator's course.
           23                  THE COURT:  What is that?  That's the
           24        technology part of it?
           25                  THE WITNESS:  Of the administration.  That's
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 52
            1        how you run organizations.  It's not the personal
            2        counseling.
            3                  THE COURT:  The OT part of it is --
            4                  THE WITNESS:  Is the personal counseling
            5        that I received.
            6                  THE COURT:  Okay.
            7                  THE WITNESS:  So I received a lot of that.
            8        And then I trained on how to run organizations.
            9   BY MR. DANDAR:
           10        Q    So you went, of course, past the state of Clear?
           11        A    Yes.
           12        Q    And you -- when you were in, OT VII was the
           13   highest you could go?
           14        A    Yes.
           15        Q    All right.
           16        A    No, OT VIII had started before --
           17        Q    Okay.
           18        A    -- when I was still in, yes.
           19        Q    All right.  Now, being administratively trained
           20   as high as you were, you, of course, heard the phrase
           21   "greatest good for the greatest number"?
           22        A    Correct.
           23        Q    What does that mean?
           24        A    That means that when you sit down to make a
           25   decision, a moral choice, that you take a look at -- you
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 53
            1   have a paradigm of life, which is called the eight
            2   dynamics, which is you just basically break down your life
            3   into these eight parts:  First, which is yourself --
            4                  THE WITNESS:  Do I need to describe what
            5        these are?  Do you want to know?
            6                  THE COURT:  I don't know how much of an
            7        explanation you want.  I frankly have not heard this.
            8        I just heard -- that's fine with me.
            9        A    See, you break your life into these eight parts.
           10   And, you know, it's yourself; there's a part that's your
           11   family; there's a part that's your group; a part that's
           12   mankind; a part that's animals and flowers; there's a part
           13   that's -- you know, matter, your things that you have;
           14   there's a part that's spirits -- spiritual world; and then
           15   there's a final part, which is like infinity or God.
           16   That's a change in definition.
           17             But anyway, there's eight of them.  And when you
           18   make a moral choice, you figure out would it benefit -- if
           19   it's going to benefit five of these areas of your life,
           20   that would be the greatest good, to go forward in that
           21   direction because it is the best good for the greater
           22   number of dynamics.
           23   BY MR. DANDAR:
           24        Q    The phrase "the greatest good for the greatest
           25   number," does it, in your understanding and your 20 years
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 54
            1   in Scientology, have anything to do with whether or not you
            2   should or should not tell the truth?
            3        A    Well, there is like acceptable truths.
            4        Q    And what's that?
            5        A    That's when you don't outright lie, but you just
            6   sort of twist it.  You slant it.  Public relations people,
            7   I think, do that a lot.
            8             In the Sea Organization, when you would go on a
            9   mission, for example, you were going into another
           10   organization and you were there to help.  I mean, you're
           11   there to, I don't know, build up their course work or
           12   whatever.  You might have what they call a shore story, is
           13   what it's called.
           14             And at the bottom of these mission orders is a
           15   shore story.  And while you're there to remove the
           16   executive director from the board who is having sex with
           17   somebody he shouldn't and you're removing him from
           18   position, you wouldn't tell that to the staff.  You would
           19   then say you're there to better the organization.  It's not
           20   a lie; you're there to better the organization.  But you
           21   don't concentrate on the negative.
           22             And, you know, people do this all the time.  I
           23   mean, that's a very common slant.
           24        Q    Well, when you went undercover for -- in the
           25   David Mayo organization and told everyone you're not a
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 55
            1   Scientologist, what do you call that?
            2        A    I was pretty trapped in there.  But, yes, I was
            3   lying.  I was lying.
            4                  THE COURT:  Would that -- that would not be
            5        what you just defined as an acceptable --
            6                  THE WITNESS:  No.
            7                  THE COURT:  -- truth, right?
            8                  THE WITNESS:  No, that's just --
            9                  THE COURT:  That's just a --
           10                  THE WITNESS:  But I'm trying to fill --
           11                  THE COURT:  -- lie?
           12                  THE WITNESS:  -- my lie with a cover --
           13                  THE REPORTER:  I'm sorry, when the Judge is
           14        asking questions, if you would go --
           15                  THE WITNESS:  One at a time?
           16                  THE REPORTER:  -- one at a time.  Thank you.
           17                  THE WITNESS:  What was I saying?
           18                  THE COURT:  I don't know.
           19                  Madam Court Reporter --
           20                  MR. WEINBERG:  What she said was, but I was
           21        trying to fill my lie with my cover, or something like
           22        that.
           23                  THE COURT:  Okay.
           24                  THE WITNESS:  Exactly.  I would try to fill
           25        it with as much truth as possible.  I mean, I was
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 56
            1        really Nancy Many.  I really did have a husband.  I
            2        really did have a child.  You know what I mean?  There
            3        was as much truth as I could have and as few lies as I
            4        needed to maintain the cover.
            5                  THE COURT:  So you did not believe that you
            6        were trained in the Church of Scientology -- excuse
            7        me -- the Church of Scientology to lie when it was
            8        convenient for the good of the Church.
            9                  THE WITNESS:  Well, you did have to protect
           10        the Church at all costs.  And that was my moral
           11        dilemma, sitting there in the witness room potentially
           12        going on the stand.  That was a personal very, very
           13        difficult moment for me.
           14                  THE COURT:  Okay.
           15                  THE WITNESS:  And I was very lucky.  I never
           16        got called to the witness stand, and no one ever asked
           17        me the question.
           18                  THE COURT:  The dilemma being --
           19                  THE WITNESS:  Would I protect --
           20                  THE COURT:  -- would you protect the --
           21                  THE WITNESS:  -- the Church.
           22                  THE COURT:  -- Church, whether you would
           23        protect the Church.
           24                  THE WITNESS:  Exactly.
           25   BY MR. DANDAR:
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 57
            1        Q    With all your training in Scientology, was the
            2   answer to that question pursuant to Scientology?
            3                  MR. WEINBERG:  Her understanding of that?
            4                  MR. DANDAR:  Her understanding.
            5        A    Could you give me that question again?  I'm
            6   sorry.
            7   BY MR. DANDAR:
            8        Q    With your understanding -- in your training in
            9   Scientology for 20 years, what is your understanding, if
           10   you had been called to testify, how you would resolve that
           11   moral dilemma?
           12        A    Like I said, I'm very thankful I was not called
           13   to testify.
           14                  THE COURT:  Yes.  That's a hypothetical.
           15        She doesn't know the answer to that.
           16        A    I don't know what I would have done.  I really
           17   don't.
           18   BY MR. DANDAR:
           19        Q    Okay.  While you were a member in good
           20   standing --
           21                  THE COURT:  If I could just follow up with
           22        one question about that.  In order to protect
           23        Scientology, there would be times you would tell a
           24        lie?
           25                  THE WITNESS:  Yes.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 58
            1                  THE COURT:  Okay.  Now, what I'm having
            2        trouble with, when I hear this definition of
            3        "acceptable truth," I don't know whether that's an
            4        acceptable truth or whether the term "acceptable
            5        truth" has something to do with what you just
            6        described, which would be an acceptable truth is
            7        telling an organization something more positive --
            8                  THE WITNESS:  Exactly.
            9                  THE COURT:  -- than some negative thing that
           10        would just hurt people.
           11                  THE WITNESS:  Exactly.
           12                  THE COURT:  Okay.  Is that what you think of
           13        as an acceptable truth?
           14                  THE WITNESS:  In the majority --
           15                  THE COURT:  Or --
           16                  THE WITNESS:  -- of cases, because it can
           17        also be used destructively.  It can also be used
           18        destructively.
           19                  THE COURT:  When you lie to protect -- to
           20        protect Scientology, what is that?  Is that an
           21        acceptable truth?  Or is that just a lie to protect
           22        Scientology?
           23                  THE WITNESS:  In some cases -- I mean, I'm
           24        just looking back on when did I do that.  I would --
           25                  THE COURT:  I mean, I understand about your
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 59
            1        job.
            2                  THE WITNESS:  When --
            3                  THE COURT:  Somebody who is going to go do
            4        undercover work, you can't do effective -- I mean,
            5        people do it all the time --
            6                  THE WITNESS:  Exactly.
            7                  THE COURT:  -- not just Scientology and the
            8        government folks, but, you know, anybody that's going
            9        to do any undercover work, including the government or
           10        what have you.  They are not effective if they go in
           11        and say, "I'm here from the FBI," you know.  So I
           12        understand that.  So that's -- we're not talking about
           13        that.
           14                  THE WITNESS:  But I am -- all right.  Say,
           15        for example, like you would -- you would not -- you
           16        would never forward negative information about
           17        Scientology.  I mean, you just -- you just wouldn't do
           18        that.  You wouldn't.  I mean, it wouldn't matter what
           19        it was, because that was the senior thing.
           20                  Per the moral definition, if you go
           21        backwards to what I was saying of the greatest good
           22        for the greatest number, that therefore, when you are
           23        a member of this group, they are the greatest good for
           24        the greatest number.  You see?
           25                  So under that umbrella, you would always
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 60
            1        veer towards the protection of them almost at any
            2        cost.  And that is where I got into big personal
            3        trouble.
            4                  THE COURT:  Here again, this is the first
            5        time I've heard "the greatest good for the greatest
            6        number" defined in the fashion you defined it.  Now
            7        I'm not sure what -- in other words, you told me that
            8        there are eight --
            9                  THE WITNESS:  Areas.
           10                  THE COURT:  -- areas, dynamics.
           11                  THE WITNESS:  Right.
           12                  THE COURT:  And of these eight dynamics,
           13        these would be personal dynamics --
           14                  THE WITNESS:  Right.
           15                  THE COURT:  -- personal to you --
           16                  THE WITNESS:  Right.
           17                  THE COURT:  -- your family, your spirit,
           18        your -- I don't know.
           19                  MR. WEINBERG:  God.
           20                  THE COURT:  God.
           21                  THE WITNESS:  God.  Infinity.
           22                  THE COURT:  Infinity.
           23                  THE WITNESS:  Right.
           24                  THE COURT:  All those things.  And you would
           25        decide -- make decisions based on what was the
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 61
            1        greatest good for the greatest number of those eight
            2        things.
            3                  THE WITNESS:  Right.
            4                  THE COURT:  Now, how does that then comport
            5        to --
            6                  THE WITNESS:  To Scientology?
            7                  THE COURT:  -- Scientology?  Because --
            8                  THE WITNESS:  Because if you are -- when you
            9        are a very, very good member, as I was for many years,
           10        it is the ultimate.  It is -- you could not look at
           11        your eight dynamics without seeing how Scientology
           12        would be good for all of them and how more Scientology
           13        in the world would be good for everyone.
           14                  THE COURT:  So if Scientology would be
           15        adversely affected, then this one dynamic would
           16        likewise be adversely affected.
           17                  THE WITNESS:  Absolutely, absolutely.
           18                  THE COURT:  And that would come into your --
           19                  THE WITNESS:  As a person --
           20                  THE COURT:  -- thinking as you would be
           21        thinking on what to do in an individual case.
           22                  THE WITNESS:  Exactly.
           23                  THE COURT:  Okay.  This is, of course --
           24        this is her speaking --
           25                  MR. WEINBERG:  Right.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 62
            1                  THE COURT:  -- from her perspective.
            2   BY MR. DANDAR:
            3        Q    Was there anything in your 20 years -- was there
            4   anything that you were asked to do that you didn't do
            5   because it would hurt you rather than protect Scientology?
            6                  THE COURT:  That's an odd question.
            7                  MR. DANDAR:  It is.
            8                  THE WITNESS:  It is.
            9                  MR. DANDAR:  It's a bad question.
           10                  THE COURT:  Yes.  I don't know what you're
           11        talking about.
           12   BY MR. DANDAR:
           13        Q    Was there -- was there any point in your 20-year
           14   experience where you didn't do something even though it
           15   would serve the greatest good for the greatest number?
           16                  MR. WEINBERG:  Well, I object to the way
           17        that was -- if he -- if he wants to ask, "Is there
           18        anything that you didn't do," fine.  But didn't do
           19        because of the greatest good for the greatest number,
           20        I object to that.
           21   BY MR. DANDAR:
           22        Q    Is there any point in your career, your 20-year
           23   membership, where you decided not to protect the Church?
           24        A    I would say it was a gradual thing, but, yes,
           25   where I became more and more -- I tried to reconcile.  This
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 63
            1   goes back to when I did all my work for OSA and I was
            2   exposed to both sides and felt both sides were rabid, is a
            3   word I've used before -- I have -- black-and-white
            4   thinking, both sides are black-and-white thinking.  You go
            5   to the critics, and Scientology is all bad.  You go to
            6   Scientology, and the critics are all bad.  It's just very
            7   volatile.
            8             And I couldn't reconcile this with a definition
            9   of greatest good for greatest number versus do unto others
           10   as you want done to you.  Basically you get what you sow,
           11   you -- that basic rule, right?  I couldn't resolve that
           12   with the greatest good for greatest number, because if I
           13   tracked greatest good for greatest number, it could turn
           14   into the ends justify the means and it is okay to violate a
           15   court order because it's for Scientology.
           16             I mean, it's so easily -- it's that slippery
           17   slope that I saw myself doing and I saw my group doing it.
           18   And it became a --
           19                  THE COURT:  Your group was?
           20                  THE WITNESS:  Scientology.  This is at the
           21        time that I'm still very much a member.
           22                  THE COURT:  Well, your group, you're talking
           23        about your Org or your --
           24                  THE WITNESS:  The whole of Scientology.
           25                  THE COURT:  The whole of Scientology.  Okay.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 64
            1   BY MR. DANDAR:
            2        Q    How do you -- how do you view Scientology today?
            3        A    I view Scientology as something that has a
            4   tremendous amount of good and at the same time has some
            5   areas that are really, really flawed, basically.
            6        Q    Are you an anti-Scientologist?
            7        A    No.
            8        Q    Have you ever been?
            9        A    No.  I mean, you know, when you say that, I get
           10   this picture of these people that I used to hang out with
           11   as a spy, and I just -- I cannot go there, could not go
           12   there.  And I do have people in my life who do feel that
           13   strongly.  And the difference now from being a
           14   Scientologist is that I can have people in my life and be
           15   friends with them and very much disagree with how their
           16   views are.
           17        Q    Your husband used to be a Scientologist also?
           18        A    Yes.
           19        Q    And you're both out of the Church now?
           20        A    Now.
           21        Q    All right.  Do you recall a set of
           22   circumstances -- and I'm just going to ask you a very vague
           23   question -- a set of circumstances where you discovered one
           24   of your private e-mails had somehow been intercepted?
           25        A    Yes.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 65
            1                  THE COURT:  Do you want to date this?
            2                  THE WITNESS:  Nineteen -- when did Lisa die,
            3        '95?
            4   BY MR. DANDAR:
            5        Q    December '95.
            6        A    I keep getting confused.  January 1996.
            7        Q    What happened?
            8        A    Well, first, I wrote the e-mail in the fall of
            9   1995.
           10        Q    Who did you write it to?
           11        A    A woman named Kim Baker, who was on the Internet,
           12   and she was very much confused.  And she struck a chord
           13   with me, because she was going back and forth:  I'm in
           14   Scientology.  No, I'm not in Scientology.  Scientology is
           15   good.  No, Scientology is bad.
           16             You know, she was just a very confused woman and
           17   having a very hard time with it.  And I do believe she
           18   posted some things that were negative about Scientology.
           19   This was all in Africa.  And I knew --
           20                  THE COURT:  Africa?
           21                  THE WITNESS:  Yes, South Africa.
           22                  THE COURT:  Okay.
           23        A    But it was on Internet communication.  I
           24   privately sent her an e-mail, just that I understood.  And
           25   she wrote back, "How could you possibly write to me because
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 66
            1   I am on the list?"  You know, the declared people list.
            2   And if you're a Scientologist --
            3                  THE COURT:  Who was that?  You were on the
            4        list?
            5                  THE WITNESS:  No.  She was on the list.  I
            6        was not on the list at the time.
            7   BY MR. DANDAR:
            8        Q    You were still in good standing --
            9        A    I was still in good standing, absolutely.  And
           10   she was saying:  "How could you write to me?  I'm on the
           11   list."
           12             And I wrote back to her saying that I was not
           13   concerned about her, talking with her.  I was concerned
           14   about the people that OSA would place near her to spy on
           15   her.
           16             And that was the content of the e-mail.  And I
           17   wrote that in the fall.  And in January 1996, I got a call
           18   from the last case officer that I had had at OSA Int --
           19             Who had called periodically throughout the years
           20   to ask me to volunteer for different things.  I mean, it
           21   wasn't like I would move; five years later.  I mean, I had
           22   had talks with her.
           23             -- to come and meet her.  And when I did at OSA
           24   Int, I was handed this private e-mail that I had sent her.
           25        Q    And what was your reaction?
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 67
            1        A    How ironic.  I mean, obviously, they had somebody
            2   close to her or -- I mean, it was -- just the irony was
            3   unbelievable to me.  And I had signed my real name.  I
            4   mean, I said, you know, I'm not -- I wasn't trying to even
            5   be covert on the Internet, you know.  And I told her at
            6   that time, because she had been my case officer, that --
            7        Q    You're talking about OSA Int now?
            8        A    OSA Int now.
            9        Q    Okay.
           10        A    This is 1996, January of 1996, and I am in the
           11   office of OSA Int with the person who had been my case
           12   officer throughout these years that I worked for them,
           13   towards the end.
           14             And she hands me this e-mail.  And I'm telling
           15   her that it was funny that it came up now because I had
           16   recently resolved for myself my moral dilemma.  And I said
           17   to her that I felt that what OSA Int did to some degree in
           18   different things that I was involved in were not morally
           19   correct.  They might not have been illegal, okay, because
           20   we're not talking illegal.  And I know most of these things
           21   are done by PIs and other -- Scientology is not the only
           22   one that does these kind of things, manipulative things.
           23   But I said it doesn't change the fact that it's not right.
           24                  And I mentioned Laurel, that woman.  And I
           25        said if I ever saw her again, I would apologize,
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 68
            1        because what was done to her was not right.
            2                  THE COURT:  "To her."  Now, who is this
            3        "her"?
            4                  THE WITNESS:  Her name is Laurel Sullivan.
            5                  THE COURT:  Oh, this is not Kim Baker you're
            6        talking about.
            7                  THE WITNESS:  No.
            8                  THE COURT:  Who is Laurel Sullivan?
            9                  THE WITNESS:  Laurel Sullivan was the person
           10        that came to my house.  The weekend overnight person?
           11                  MR. WEINBERG:  Back in the '80s.
           12                  THE WITNESS:  Back in the '80s.  I'm just
           13        saying -- I'm just saying -- I'm telling this person
           14        that we had spied on this woman.  And now in 1995, I'm
           15        saying:  You know what?  That wasn't right.  It wasn't
           16        right.
           17                  THE COURT:  And if you saw that woman, you
           18        would apologize.
           19                  THE WITNESS:  I would apologize to her.
           20                  And I went on to say that I had had a
           21        tremendous amount of trouble over the past five years.
           22        This is -- now we're getting into major trauma, and --
           23                  MR. DANDAR:  Take some water.  Or do you
           24        want to take a little break?
           25                  THE COURT:  Do you want to take a little
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 69
            1        break?
            2                  THE WITNESS:  No.
            3                  THE COURT:  All right.
            4                  THE WITNESS:  Not yet.  But then I might.
            5                  And then I had worked at trying to get this
            6        resolved for myself.  And I just wanted to go back to
            7        feeling like I used to feel before I was a spy for
            8        Scientology in OSA and was exposed to all these
            9        different things that kind of jumbled my mind, you
           10        know, in terms of right, wrong.  You know what I mean?
           11        And she offered help there --
           12   BY MR. DANDAR:
           13        Q    Who offered help?
           14        A    Two women at OSA Int.  One's name is Donna, and
           15   the other one is Kirsten.  And they didn't know this other
           16   stuff about me.  They only knew the e-mail.
           17                  THE COURT:  What is the "other stuff"?  What
           18        do you mean?
           19                  THE WITNESS:  Well, that I had been in touch
           20        with Arnie Lerma.  That name might kind of ring a bell
           21        for them because they were in the middle of litigation
           22        with him and other people.  I mean, they didn't know
           23        that I was sitting there with this moral dilemma.
           24        They only knew that e-mail.
           25                  THE COURT:  You had been in touch with some
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 70
            1        folks that might be considered critics?
            2                  THE WITNESS:  Exactly.
            3                  THE COURT:  And they knew you had been in
            4        touch with them.
            5                  THE WITNESS:  Exactly.
            6                  THE COURT:  Here was OSA Int offering you
            7        help.  And you had this dilemma that they didn't
            8        know --
            9                  THE WITNESS:  No, no.  I told them.
           10                  THE COURT:  Oh, you did tell them.
           11                  THE WITNESS:  Oh, yes.  I did not --
           12                  THE COURT:  All right.
           13                  THE WITNESS:  I was very upfront about it.
           14                  THE COURT:  Okay.
           15                  THE WITNESS:  And they offered me help, and
           16        I was very happy to take that help.
           17   BY MR. DANDAR:
           18        Q    And what help did they offer you?
           19        A    They offered me some counseling --
           20        Q    Okay.
           21        A    -- to help me sort out, you know, right or wrong
           22   or, you know, the feelings of doubt.
           23        Q    And what happened next?
           24        A    I went in for counseling.  And you also need to
           25   understand I had had 20 years of counseling that was good,
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 71
            1   very good.  I had no reason to doubt that this wouldn't be
            2   of help.
            3        Q    Okay.
            4        A    When you're in this kind of counseling, you are
            5   trained -- this is not like a bad thing.
            6                  (Mr. Dandar handed the witness Kleenexes.)
            7        A    The auditor, the counselor, sits by the door so
            8   you don't leave until the auditor -- the auditor is in
            9   control.  In other words, you're allowing this person to be
           10   in control to help you dig through personal issues.  Right?
           11                  THE COURT:  So when you talked about you
           12        were counseling in the Church of Scientology, that's
           13        auditing?
           14                  THE WITNESS:  Yes.
           15                  THE COURT:  Okay.
           16                  THE WITNESS:  Yes, auditing.
           17                  THE COURT:  So when you go into an auditing
           18        session, it's the auditor that controls the session --
           19                  THE WITNESS:  Absolutely.
           20                  THE COURT:  -- not the --
           21                  THE WITNESS:  Not the Pre-Clear.
           22                  THE COURT:  -- Pre-Clear.
           23                  THE WITNESS:  And the auditor sits by the
           24        door.  And --
           25                  THE COURT:  Can I ask you a question?  When
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 72
            1        you left Sea Org and became a public member, did you
            2        lose your Clear status?  Or are you still a Clear?
            3                  THE WITNESS:  No, you're still a Clear.
            4                  THE COURT:  Okay.
            5                  THE WITNESS:  I'm still a Clear.
            6                  THE COURT:  I guess in my own head I never
            7        understood Lisa McPherson was a Clear and then she
            8        wasn't a Clear.  She was a Pre-Clear.  So I --
            9                  MR. WEINBERG:  No, no.  That -- a Pre-Clear
           10        is just something that covers people, you know, that
           11        are -- it's a sort of -- with regard to folders.  But
           12        it can include people anywhere on the bridge.
           13                  MR. DANDAR:  So --
           14                  MR. WEINBERG:  In other words, lower, upper
           15        levels.
           16                  THE COURT:  So she was Clear still.
           17                  MR. WEINBERG:  Yes.
           18                  MR. DANDAR:  Yes.
           19                  THE COURT:  Okay.  And you were Clear --
           20                  THE WITNESS:  Right.
           21                  THE COURT:  -- at this time.
           22                  THE WITNESS:  Correct.
           23                  THE COURT:  So the fact that you would go to
           24        Sea Org and become a public member does not stop --
           25                  THE WITNESS:  Exactly.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 73
            1                  THE COURT:  -- your position on the bridge
            2        or --
            3                  THE WITNESS:  Exactly.
            4                  THE COURT:  -- whatever.
            5                  THE WITNESS:  It just costs you more money.
            6        You have to pay for it now.
            7                  MR. DANDAR:  And the fact that you were --
            8                  THE COURT:  And the reason for that is
            9        because, as Sea Org members, you're devoting sort of
           10        your life --
           11                  THE WITNESS:  Exactly.  That's your
           12        exchange.
           13                  THE COURT:  That's your exchange.  And
           14        you're getting therefore free -- I guess free.
           15                  THE WITNESS:  Exactly.
           16                  THE COURT:  But you devote your life and
           17        work very hard as a staff person.  If you're a public,
           18        you have to pay for that.
           19                  THE WITNESS:  Right.
           20                  THE COURT:  Okay.
           21   BY MR. DANDAR:
           22        Q    So when you quit Scientology, you're still Clear?
           23        A    Yes.
           24        Q    Okay.
           25        A    I have whatever I got.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 74
            1        Q    Right, right.  And the 20 years of auditing,
            2   training courses, in your experience, were all good?
            3        A    Well, I had bumps in the road.  I'm not saying
            4   there weren't bumps in the road.  But I'm saying overall,
            5   it was not a harmful experience for me.  It was not.
            6        Q    Okay.  So you weren't --
            7        A    It was not.  And there was a lot that I still use
            8   today, a lot.
            9        Q    So in January '96, the OSA person sent you to get
           10   some auditing?
           11        A    Correct.
           12        Q    Okay.  And what happened then?
           13        A    It was not like any kind of auditing I had ever
           14   had before.  It was invasive.  It was -- I mean, there were
           15   times when the auditor was standing, screaming at me.  And
           16   it went on for day after day after day, for hours and hours
           17   at a time.
           18             And emotionally I was just getting worse.  And I
           19   knew after day one, after day one, I knew that this was not
           20   meant to help me and that it wasn't helping me.  But
           21   because in Scientology, if I didn't go back in, they would
           22   have put me back on that list.  I would have lost my job,
           23   my association with them --
           24                  MR. WEINBERG:  Objection, your Honor.
           25        A    -- as a Scientologist.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 75
            1                  MR. WEINBERG:  What is the relevance of
            2        this?  How -- I mean, we're in a position now --
            3        Mr. Dandar is having her talk about religious
            4        counseling.  It's not -- it's not supposed to be a
            5        trial about -- about the religion of Scientology,
            6        whether or not counseling is good or not good.
            7                  There is no way that I would or could
            8        cross-examine her about this experience.  I'm
            9        certainly not going to bring an auditor in here.  This
           10        is a priest-penitent session.  And so now he is --
           11                  THE COURT:  If it is, it's hers to waive.
           12                  MR. WEINBERG:  Well, it may be, but it has
           13        nothing to do with this hearing or this trial as to
           14        whether this affects her job or anything like that.
           15                  THE COURT:  I would agree with you.  He
           16        tells us he's going to bring out the relevance.
           17                  MR. WEINBERG:  Well, then maybe I would urge
           18        him to do that, because it is -- I think it is
           19        inappropriate.
           20                  MR. DANDAR:  It would have been done
           21        already.
           22                  MR. WEINBERG:  Could I finish, please?
           23                  MR. DANDAR:  I think we need to stop this.
           24                  THE COURT:  Yes, I do too.  I think it's
           25        relevant, I guess.  He says it's relevant.  I'm going
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 76
            1        to let him go.  There's been a lot of stuff that we've
            2        let in.  This is her privilege.  If she wants to waive
            3        it, she can waive it.  It's not yours to claim.
            4                  MR. WEINBERG:  I understand.  Just that last
            5        remark, and I'll sit down.
            6                  MR. LIEBERMAN:  Your Honor --
            7                  MR. DANDAR:  Now we have two.
            8                  MR. LIEBERMAN:  -- it is the Church's to
            9        claim.
           10                  THE COURT:  No, it is not the Church's to
           11        claim.  The priest-penitent privilege can be waived by
           12        the penitent at any time.  It cannot be waived by the
           13        priest.  I'm quite clear about that.  Sit down.  We're
           14        moving on.
           15                  MR. WEINBERG:  I'm making another point just
           16        for the record, just to comment on the last comment
           17        that your Honor made.  It is true that a lot has been
           18        let in -- I just wanted the record to be clear -- that
           19        over our objection there have been many of these
           20        things that have to do with the religion of
           21        Scientology.
           22                  THE COURT:  That's true.  And I believe that
           23        what I said was that I would make a ruling on that at
           24        some time after we had legal argument.
           25                  MR. WEINBERG:  You had said that "we" had
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 77
            1        let in.  I just wanted to make sure that wasn't --
            2                  THE COURT:  There's a lot of stuff that I
            3        let you let in that I'm going to rule probably at the
            4        end of this hearing is absolutely irrelevant to these
            5        proceedings, from both sides.  I have let in a lot of
            6        stuff that I am probably going to determine has
            7        nothing to do with the decision that I'm going to
            8        make.  It's been kind of a wide open hearing.  I let
            9        it go that way.  I'm going to sort it all out.
           10                  But this is her privilege, and Mr. Dandar
           11        said it has some relevance.  That's the way I've been
           12        ruling.  Let it end.  If it doesn't have any
           13        relevance, I'm going to eliminate it.  Thus far --
           14                  MR. WEINBERG:  Fine.  Fine, your Honor.
           15                  THE COURT:  Okay.  But go ahead.
           16                  MR. LIEBERMAN:  Your Honor, I just want to
           17        say that in California, where I think this took place,
           18        the law is that the privilege is both of the Church
           19        and the minister, as well as the parishioner.  So that
           20        it is not hers to waive.
           21                  THE COURT:  This is Florida, Counselor.
           22                  MR. LIEBERMAN:  I know, but the auditing
           23        took place in California.
           24                  THE COURT:  This is Florida, and this case
           25        is taking place in Florida.  And in the State of
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 78
            1        Florida, the priest-penitent privilege can be waived
            2        by the penitent.  This is a Florida case.  I don't
            3        care where the auditing took place.  What I care about
            4        is where this trial is taking place.
            5                  MR. LIEBERMAN:  Well, your Honor, I think
            6        the law in California would govern an auditing session
            7        that took place --
            8                  THE COURT:  Well, then suppose you brief
            9        that for me at the end of this hearing, just like
           10        you're going to brief all the other religious issues,
           11        and I'll make a ruling.  But for right now I'd like to
           12        move on.
           13   BY MR. DANDAR:
           14        Q    So how long did this different type of auditing
           15   take place?
           16                  THE WITNESS:  I just want to make sure here,
           17        Judge, that if I say like one thing that happened in
           18        that session that I'm not now waiving, that they can
           19        go take my 20 years worth of private Pre-Clear -- do
           20        you understand what I mean?  That they can now freely
           21        expose whatever I told them in private.
           22                  THE COURT:  I would not assume that a Church
           23        would want to do that.  If this has some relevance to
           24        this hearing, I would assume you can talk about this.
           25                  THE WITNESS:  Okay.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 79
            1                  THE COURT:  They would be able to fully
            2        explore this.
            3                  THE WITNESS:  Okay.  Good.
            4                  THE COURT:  I would assume they would not
            5        violate the rest of it.
            6                  THE WITNESS:  Okay.  Okay.
            7                  THE COURT:  I cannot promise you that,
            8        however.
            9                  MR. WEINBERG:  Well, I'll promise you that.
           10                  THE COURT:  Okay.
           11                  MR. WEINBERG:  And I'll promise you that was
           12        the reason I stood up and objected in the first place,
           13        because it puts us in an untenable and impossible
           14        position, because we would never -- I would never
           15        take the Pre-Clear information from an audit --
           16        from --
           17                  THE COURT:  See, you confuse me.  Why do you
           18        call it Pre-Clear?
           19                  MR. WEINBERG:  Because that's what it's
           20        called.
           21                  MR. MOXON:  Your Honor, I can explain.
           22                  MR. WEINBERG:  It's called a PC folder --
           23        remember that PC folder?
           24                  THE COURT:  Right.
           25                  MR. WEINBERG:  That's Pre-Clear.  And even
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 80
            1        though she was at the high level, she is still called
            2        a Pre-Clear.
            3                  MR. MOXON:  A Pre-Clear is just a
            4        generalized name for someone that's receiving
            5        auditing.  I mean, a person can be a Clear and still
            6        be generically called a Pre-Clear or a -- you could
            7        say a counselee.  A Pre-Clear would be a counselee if
            8        you're looking at it in terms of counseling.  So a
            9        Pre-Clear folder or a PC folder is just a generic name
           10        for a folder --
           11                  THE COURT:  So a Pre-Clear folder proceeds
           12        way past the time the person becomes --
           13                  MR. MOXON:  Yes.
           14                  THE COURT:  -- Clear, through OT and all
           15        that.
           16                  MR. MOXON:  Yes.  It's still called a
           17        Pre-Clear.
           18                  THE COURT:  Okay.
           19                  MR. DANDAR:  And please note there's been no
           20        question nor discussion of the contents of these
           21        auditing sessions.
           22                  THE COURT:  The fact of the matter is,
           23        Counselor, you would not be violating any privilege to
           24        get her folder and look at this particular counseling
           25        session.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 81
            1                  MR. WEINBERG:  I understand that.
            2                  THE COURT:  You can cross-examine on it.
            3                  MR. WEINBERG:  I understand.  But I --
            4                  THE COURT:  She hasn't said anything yet --
            5                  MR. WEINBERG:  No, no --
            6                  THE COURT:  -- that's any big deal.
            7                  MR. WEINBERG:  But I wanted to respond to
            8        what she said --
            9                  THE COURT:  Okay.
           10                  MR. WEINBERG:  -- her concern.  And that is
           11        the dilemma that having this kind of testimony would
           12        put any lawyer -- and I just wanted to -- to, you
           13        know, make that point for the record and tell you that
           14        that's not what I intend to do.
           15                  THE WITNESS:  Okay.
           16                  MR. WEINBERG:  And I don't intend to do
           17        that.
           18                  THE WITNESS:  I appreciate that.
           19                  THE COURT:  I do -- I want you to understand
           20        this, however, that that -- I don't want you to, but
           21        maybe -- I don't want to put you in a situation where,
           22        because I've said this, that that means that
           23        somebody -- I have no idea.  This is one lawyer in
           24        this case, and it has to do with what his
           25        cross-examination is going to be.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 82
            1                  THE WITNESS:  Right.
            2                  THE COURT:  At some other time, would
            3        somebody say that you have waived your entire
            4        privilege?  I would seriously doubt it.
            5                  THE WITNESS:  Okay.  Thank you.
            6                  THE COURT:  But I can speak for me and my
            7        little, limited knowledge that I've got right now.  I
            8        would say that what you're about to talk about, this
            9        session, that once you talk about it, that any
           10        privilege that you have is waived.
           11                  THE WITNESS:  Understood.
           12                  THE COURT:  But as far as other sessions, I
           13        would doubt that a judge would say that you have
           14        waived that.
           15                  THE WITNESS:  Okay.  Good.
           16                  THE COURT:  Okay?
           17                  THE WITNESS:  Good.
           18                  THE COURT:  But I -- I'm just one judge in
           19        this courtroom.
           20                  THE WITNESS:  Right.
           21                  THE COURT:  Judges make strange calls.
           22        Sometimes judges make calls that I don't agree with.
           23                  THE WITNESS:  Okay.
           24                  THE COURT:  That's what I think would
           25        happen, but I'm not allowed to give you legal advice.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 83
            1                  THE WITNESS:  I understand.
            2                  THE COURT:  You need to get a lawyer if
            3        you're really concerned about it.
            4   BY MR. DANDAR:
            5        Q    Well, just tell us, how long did this unusual
            6   session go on?
            7        A    It went on for very lengthy times, about five or
            8   six hours each day, and it went on for, if I remember
            9   correctly, about a week and a half, at the end of which I
           10   lost my mind.
           11        Q    How do you know that?
           12        A    Because -- if you haven't lost it, you really
           13   don't know what it's like, to be perfectly honest with you.
           14   It's -- but when you do lose it, you will know.  You will
           15   know you have lost your mind.
           16        Q    Well, let me ask you --
           17                  THE COURT:  Let's go ahead and take a break.
           18        It's our morning time.  It's 10:25, so it's that time.
           19        We'll be in recess until about a quarter of 10:00.
           20                  MR. DANDAR:  Okay.
           21                  THE BAILIFF:  All rise, please.
           22                  MR. DANDAR:  Judge, can we give the witness
           23        an instruction, please?
           24                  THE COURT:  Oh, yes, ma'am.  Since you're
           25        testifying, you're not allowed to talk with anybody,
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 84
            1        even the lawyers, about your testimony.
            2                  THE WITNESS:  Oh, okay.
            3                  THE COURT:  You can talk about anything
            4        else, but about your testimony when you're on the
            5        stand, you're precluded from talking to anybody, even
            6        lawyers, about it.
            7                  THE WITNESS:  Okay.
            8                  THE COURT:  Okay?
            9                  MR. DANDAR:  Thank you.
           10                  THE COURT:  Mostly the lawyer who called
           11        you.  In other words, if you speak to Mr. Dandar and
           12        you say, "Are you going to be asking --"
           13                  At this point, he's going to be saying, "I
           14        really can't discuss that with you --"
           15                  THE WITNESS:  Okay.
           16                  THE COURT:  "-- while you're testifying."
           17                  THE WITNESS:  Okay.
           18                  (A break was taken at 10:25 a.m.)
           19                  (Mr. McGowan came in during the break.)
           20                  (The proceedings resumed at 10:55 a.m.)
           21                  THE COURT:  Okay.  Mr. McGowan came.  I gave
           22        him those folders.  I signed off --
           23                  Did I sign off on all of those when I gave
           24        them to you?
           25                  MR. McGOWAN:  No, your Honor.  There's one
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 85
            1        you didn't.
            2                  THE COURT:  Okay.
            3                  MR. McGOWAN:  Just the one you reviewed on
            4        7/8.
            5                  THE COURT:  Okay.  Are those your
            6        signatures, by the way, on there?
            7                  MR. McGOWAN:  The one on 7/8 is not.  That's
            8        Mike Keane's signature.  Mine is on the one of 7/9.
            9        Neither -- neither me nor Mike Keane is on another one
           10        dated 7/8, which says, "Dandar and Greenway,
           11        privileges asserted by the Estate."
           12                  THE COURT:  That's the one you and I went
           13        through and I showed you -- well, that's the one that
           14        I turned over.
           15                  MR. McGOWAN:  You turned that over and you
           16        signed it.  And that's my handwriting --
           17                  THE COURT:  Okay.
           18                  MR. McGOWAN:  -- on the envelope.  And then,
           19        again, there's no signature on the April 26th one.
           20        Your Honor has signed it.  But that's my handwriting,
           21        where it says, "LMT, Scientology, attorney-client."
           22                  THE COURT:  And that's the one where I told
           23        you they seemed to be letters written to the Trust and
           24        from the Trust.  And you and I looked at them, and you
           25        thought they were perhaps mislabeled in an envelope or
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 86
            1        something like that?
            2                  MR. McGOWAN:  That's another envelope, I
            3        think.  This one is -- says "attorney-client bills."
            4                  THE COURT:  Oh, okay.
            5                  MR. McGOWAN:  One document was something
            6        that's already been admitted -- a declaration that's
            7        already been admitted.  But there is another document
            8        that you indicated it was not attorney-client
            9        privilege -- not relevant.
           10                  THE COURT:  Right.  Okay.  The -- that's all
           11        being returned to Mr. McGowan.  I have instructed
           12        him -- and I'm now telling you all -- that I'm
           13        instructing him to instruct his client that if in fact
           14        any of those are released to one side in this case,
           15        they should be released to both sides, the reason
           16        being that I've reviewed them and I've elected not to
           17        turn them over, thinking that some privilege or
           18        whatever applies.
           19                  So I don't want to be in a position later of
           20        saying that I somehow provided one side without the
           21        other side.
           22                  I don't -- you know, it's her business what
           23        she wants to do with the documents.  But for those
           24        documents that I reviewed, if she releases them, I've
           25        asked her to ask Mr. McGowan to tell her that if she
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 87
            1        wants to release them, she should tell him, and he
            2        should make a copy for both sides.
            3                  MR. WEINBERG:  All right.
            4                  MR. McGOWAN:  And I will so instruct
            5        Ms. Brooks.  Thank you, your Honor.
            6                  THE COURT:  Now, the other thing is I had a
            7        call -- you can go ahead and go.
            8                  MR. McGOWAN:  Thanks, your Honor.
            9                  THE COURT:  Sure.
           10                  (Mr. McGowan left.)
           11                  THE COURT:  Nancy, who is one of the jury
           12        coordinators, called about the trial for August, and I
           13        told her that was off.  But we got to talking about it
           14        a little bit during the break.
           15                  They both suggest that, rather than do it
           16        during a regular trial week, which I thought I was
           17        doing them a favor, it would not be a favor, the
           18        reason being the parking situation, for one.  And,
           19        number two, they don't even have a place to put them.
           20                  MR. WEINBERG:  I was going to say, what
           21        parking?
           22                  THE COURT:  Yes, "what parking" is right.
           23        They don't have a place to put these people.  They can
           24        only accommodate like 15 in the jury room.  And when
           25        you have all four judges in a courtroom, there's no
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 88
            1        courtroom to put them in.  So she suggested I do a
            2        non-trial week.  So that's fine.
            3                  She reminded me, the second week -- the next
            4        week after the week we had -- the regular trial week
            5        is the 16th.  She reminded me that Monday is Yom
            6        Kippur, which is not only a Jewish holiday but also a
            7        court holiday.  And I would like to -- I don't ever
            8        work on those religious days.
            9                  So we could, however, start on the 17th,
           10        which would be a Tuesday, and go Tuesday, Wednesday,
           11        Thursday, Friday.  Or we could start the 23rd, on a
           12        Monday.
           13                  So whatever date that I set, I'm going to
           14        change it either to the following week, beginning on
           15        Tuesday, or September 23rd.
           16                  MR. WEINBERG:  Because, you know, we have
           17        asked that it be as far removed as possible.  And, you
           18        know, I still think that it should be removed further
           19        because of the length of this proceeding and what's
           20        going on.  So --
           21                  THE COURT:  Well, we're going to finish this
           22        proceeding it looks like next week, maybe.
           23                  MR. WEINBERG:  That's true.  But all of us
           24        have a lot to do, because of this record, to somehow
           25        try to get our hands around it for purposes of
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 89
            1        briefing it for you.
            2                  THE COURT:  I understand that.  But luckily
            3        on your side, probably one of the other lawyers will
            4        write most of the --
            5                  MR. WEINBERG:  Well, I don't know if that --
            6        that's necessarily the case, your Honor.
            7                  THE COURT:  I'll bet it is.
            8                  MR. WEINBERG:  He might write the legal
            9        argument, but I don't think he's going to be making a
           10        closing argument.  But in any event -- you know, as to
           11        the factual --
           12                  THE COURT:  I'll go ahead and set it then
           13        for the week of the 23rd.
           14                  MR. DANDAR:  That would be absolutely
           15        excellent.  Then I don't have to continue my other
           16        trial.
           17                  THE COURT:  Okay.  She's also tells me --
           18        this is good news too -- that I do not have to -- in
           19        other words, that she will not send out the notices
           20        until 30 days before.
           21                  MR. WEINBERG:  Okay.
           22                  THE COURT:  So if it's the 23rd, we have up
           23        until August the 23rd.  Also, once the notices go out,
           24        they're easily cancelled.  They tell them to call in
           25        to a certain number, and as long as we can call them
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 90
            1        off --
            2                  MR. WEINBERG:  And I think that we may be,
            3        you know, filing a motion with regard to the trial
            4        date, which we will -- but first I want to see when
            5        this hearing is over.
            6                  THE COURT:  Right.  And that's fine, and
            7        I'll hear that.  Like I told you, I have got to assume
            8        for the work that we need to do that this motion will
            9        be denied and it will be tried and I've got to set --
           10        you know, as I said, they're calling me, wanting to
           11        know what we're doing here.  So I can't just wait
           12        until a month or two down the road when I might rule.
           13                  So anyway, she made another suggestion.  And
           14        put this in the back of your -- of your heads if we
           15        end up in a trial posture.  She suggested that we
           16        could -- she says that she has been given some
           17        statistics which turn out to be pretty accurate.  And
           18        that is if you have a trial that lasts any length of
           19        time, right off the bat you're usually down to about
           20        18 to 20 percent of those you summonsed.  So if you
           21        summons 100 -- not summons, but if you get 100 people
           22        here, we'll lose 80 of them just for inability to sit
           23        that long.
           24                  MR. WEINBERG:  It's easier to get into
           25        Harvard.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 91
            1                  THE COURT:  Pardon me?
            2                  MR. WEINBERG:  It's easier to get into
            3        Harvard, I think.
            4                  THE COURT:  Right.  So she suggested -- one
            5        thing that she's always wanted to try that she hasn't
            6        done is summons a group for the morning and a group
            7        for the afternoon.
            8                  And I thought that might work because,
            9        frankly, I'd like to narrow the jury pool, if we have
           10        a trial on either end of this, to those -- you know,
           11        get rid of all of those who can't serve because of
           12        length of time, get rid of all those for publicity
           13        that need to be removed.
           14                  Then if there's a questionnaire, we'll let
           15        them fill out the questionnaire, you know, if there is
           16        a questionnaire, then make them available for the pool
           17        to be questioned by the lawyers -- and further
           18        questioned by me, quite frankly.
           19                  And so what I normally would do is I get
           20        five or six that are eligible.  I tell them to go on
           21        home, call in, we'll tell them when to come back.
           22        Then we get the next group.  And then when I get about
           23        50, then we can actually go into voir dire.
           24                  But what you have before you get those 50,
           25        they're all eliminated for work problems and all
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 92
            1        eliminated for publicity problems.  So then you're
            2        down to your normal -- and that seems to work pretty
            3        well.  But that's a thought, that she could bring some
            4        in in the morning and some in the afternoon.  I don't
            5        know why I'm telling you.  This is my call.  I'll make
            6        all these decisions.  But I'm just rattling by you all
            7        some ideas.
            8                  So for now I'll set this for the 23rd, and
            9        I'll call her back that that is the tentative date.
           10        If you have a motion to file, why, certainly we'll
           11        hear it.
           12                  MR. WEINBERG:  Okay.
           13                  THE COURT:  Oh, that does remind me, before
           14        we finish, I had Judge Beach call.  He was at the
           15        airport getting ready to fly to Reno.  He's going to
           16        be on vacation, I believe he told me, this week --
           17        this is Friday -- next week.  Naturally, he would be
           18        very interesting in flying from Reno to California if
           19        any of those depositions could possibly be set the
           20        following week.
           21                  So if you could call whoever those witnesses
           22        are and see if any of them are available, it would be
           23        nice for him.  That's a long flight.  So --
           24                  MR. DANDAR:  What week is that?
           25                  THE COURT:  I don't know.  Not next week.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 93
            1        The following week, I presume.
            2                  MR. DANDAR:  Okay.
            3                  THE COURT:  So if -- if there's anybody
            4        that's available out there, he would love it, because
            5        he's there and all he has to do is fly from Reno to
            6        San Francisco.  So check these people out.
            7                  I just remembered you all mentioning some
            8        depositions were going to be taken in California.  If
            9        he can be accommodated, I'm sure he would appreciate
           10        it.  I mean, he didn't insist on it.  He'll fly out
           11        again.  But he just wanted you all to know that.
           12        Okay?
           13                  You may continue.
           14                  MR. LIEBERMAN:  Before we continue, your
           15        Honor, I would like to address the last part of the
           16        testimony, where the witness is now testifying that,
           17        based upon her auditing, she suffered not only severe
           18        emotional distress, but she lost her mind.
           19                  We are now in the process of litigating the
           20        Scientology religion and auditing and having testimony
           21        that is bad and has negative effects.  And this is --
           22        this came up -- there are allegations like this in the
           23        complaint in the intentional infliction of emotional
           24        distress count.  We briefed these.  We argued them.
           25        You indicated you weren't going to hear those.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 94
            1                  We now have testimony about this.  And it's
            2        not sufficient to say, "Well, we'll deal with them
            3        later," because if there's a possibility that your
            4        Honor -- if this isn't being introduced to convince
            5        your Honor of something -- it's not just passing
            7                  If we have -- if this is an issue in this
            8        case, then we have a heresy trial, and then we have to
            9        put on evidence that people have different experiences
           10        in Scientology.  And I submit that that is -- if
           11        anything is clear under the First Amendment and RFRA,
           12        this kind of testimony is not permissible.
           13                  THE COURT:  Overruled for now.
           14                  Continue.
           15                  I'm not going to change horses in the middle
           16        of the stream from what I've been doing.
           17                  MR. DANDAR:  Now --
           18                  THE COURT:  I am happy to seal this if you
           19        want to seal it.
           20                  MR. LIEBERMAN:  We would like that at the
           21        least, your Honor.  But in the meantime, the Church is
           22        now in a position --
           23                  THE COURT:  I don't care.
           24                  MR. LIEBERMAN:  -- of how to respond to
           25        this.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 95
            1                  THE COURT:  If you want to respond, bring in
            2        30 witnesses.  I don't care.  This is a hearing.  It's
            3        your hearing.  This is my 32nd day.  We are going to
            4        finish it.  If you want to bring in 30 more days of
            5        hearing, do it.
            6                  Continue.
            7   BY MR. DANDAR:
            8        Q    How many days did this different type of
            9   counseling go on?
           10        A    About --
           11                  MR. WEINBERG:  It was asked and answered,
           12        your Honor.  Objection.  She already said that.
           13                  MR. DANDAR:  I'm trying to get us to where
           14        we left off.
           15                  MR. WEINBERG:  Well, it's in the record.
           16                  THE COURT:  True.
           17                  THE WITNESS:  I lost my mind -- that's where
           18        we were -- and how did I know I lost my mind.
           19   BY MR. DANDAR:
           20        Q    Right.
           21        A    And I said if you ever lose your mind, you'll
           22   know.
           23        Q    Okay.
           24        A    And it is a most horrible thing to no longer be
           25   in this place, to no longer understand the difference
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 96
            1   between imagination and reality, to no longer tell the
            2   difference between a dream or the day.  It is a most
            3   horrible thing.  And it happened after that counseling.
            4        Q    Where were you?
            5        A    I was at home.  At the time it was very late,
            6   around 1 a.m. in the morning.  And I felt something shift
            7   in my head.  And I got up and started -- things started
            8   coming out of my mouth.
            9        Q    Did you report this?
           10        A    Yes.  We called OSA Int.  My husband called OSA
           11   Int.
           12        Q    Why did you call OSA Int?
           13        A    Because they were in charge of my handling at the
           14   time and they happened to be up working late.
           15        Q    And what happened?
           16        A    Basically they sent me to a Scientology doctor.
           17        Q    A medical doctor?
           18        A    A medical doctor.
           19        Q    Do you remember the name?
           20        A    Megan Shields.
           21        Q    Megan Shields?
           22                  THE COURT:  I'm sorry?
           23                  THE WITNESS:  Megan Shields.  They sent
           24        me -- she was a Scientologist.
           25   BY MR. DANDAR:
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 97
            1        Q    And a licensed medical doctor?
            2        A    Yes, as far as I know.  She's a general
            3   practitioner.
            4        Q    Make sure we're clear.  You explained to the
            5   person at OSA Int what was happening to you?
            6        A    Yes.
            7        Q    And that person sent you to Megan Shields.  Did
            8   they make the appointment or did you?
            9        A    They did.
           10        Q    And when did you see Dr. Megan Shields?
           11        A    Probably the next day or later on that next day.
           12        Q    Now, she -- is she on staff at OSA Int or --
           13        A    No, not at all.  But she is a doctor who is a
           14   Scientologist.  So they use her to get reports and feedback
           15   back on medical things of -- because they're not medical
           16   doctors.  So they rely on other outside medical doctors.
           17        Q    Okay.
           18        A    And she gave me some prescriptions, and she gave
           19   me some different vitamins to take.
           20        Q    What prescriptions?
           21        A    Chloral hydrate and some herbs, valerian root and
           22   something else.
           23        Q    And --
           24        A    Melatonin.  I was taking melatonin.
           25        Q    What's that for?
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 98
            1        A    Sleep.
            2        Q    Okay.
            3        A    Or at that time it was thought to help sleep.
            4                  THE COURT:  That really isn't a
            5        prescription.
            6                  THE WITNESS:  No, no.  But she told --
            7        that's what she told me.
            8   BY MR. DANDAR:
            9        Q    Did she tell you to take any vitamins?
           10        A    She checked that I was already taking vitamins,
           11   Cal Mag and Vitamin B-1, a lot of.
           12        Q    Okay.  What happened next?
           13        A    I deteriorated every day.  It got worse and
           14   worse.  And I would call these people at OSA Int and say,
           15   "Help me."  Basically it was like being on a Ferris wheel.
           16   And as I would come up for air and have these moments of
           17   clarity or a time period of clarity, I would call and I
           18   would say:  "Help me.  Do something.  I'm just getting
           19   worse."
           20             And I was just repeatedly told:  "They're looking
           21   into it.  Your folders are on line.  It's -- something will
           22   happen soon.  Just hold on."
           23        Q    What is that --
           24        A    But it went --
           25        Q    I'm sorry, what does that mean, your folders --
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 99
            1        A    Your folders are up line?
            2        Q    Yes.
            3        A    It means somebody is looking for what help to
            4   give you.  They don't know what help to give you.
            5        Q    Let me interrupt.  When -- as a Scientologist, if
            6   you see someone who is what's known as PTS Type III, what
            7   are you supposed to do?
            8        A    Isolate them.  There is a thing -- but I wasn't
            9   at that point.  I knew that I had had a break.  I knew I
           10   was seeing things that weren't there.  I knew people that
           11   weren't there were talking to me.  I mean, I knew -- when I
           12   was up at the top of the Ferris wheel, I had clarity that
           13   this is not the way it's supposed to be.
           14        Q    But --
           15        A    But --
           16        Q    -- in your experience in Scientology, were you --
           17                  MR. WEINBERG:  Your Honor, could she finish
           18        her answer?  She was trying to explain.
           19                  THE COURT:  Yes.
           20        A    I was not expecting an introspection rundown in
           21   those early days.  I figured -- I'd never had this kind of
           22   a bump in the road.  Remember, sometimes I said in
           23   counseling I would have a bump in the road and they always
           24   can fix it.  Right?
           25             But this was a very mountain in the road, but I
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 100
            1   still had a lot of trust and a lot of faith that this was
            2   going to get repaired, that I was not going to be cuckoo,
            3   that just something had technically -- whatever, I don't
            4   know, had gone wrong and they could fix it.  It wasn't
            5   until, as it progressed each day getting worse and I
            6   deteriorated worse and worse, that I started to think other
            7   thoughts.
            8        Q    Did they give you --
            9                  THE COURT:  Can I stop you here for just a
           10        minute?
           11                  Did you say your folders -- I guess that's
           12        PC folders?
           13                  THE WITNESS:  Correct.
           14                  THE COURT:  Were on line?
           15                  THE WITNESS:  Up line.
           16                  THE COURT:  What does that mean?
           17                  THE WITNESS:  That means they went to a
           18        higher organization.  Whenever there is something not
           19        at the lower organization that kind of, "God, it
           20        didn't go well," it would go up lines for review.
           21                  THE COURT:  So your folder had been at OSA
           22        Int?
           23                  THE WITNESS:  Correct.
           24                  THE COURT:  And it was up line from OSA Int?
           25        Where would that be?
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 101
            1                  THE WITNESS:  I thought RTC, the Watchdog
            2        Committee.  They had technical flood catch units,
            3        where they're meant to correct mistakes and to find
            4        mistakes.  That's what I assumed.
            5                  THE COURT:  Looking to see what had gone
            6        wrong --
            7                  THE WITNESS:  Exactly.
            8                  THE COURT:  -- and they could fix it?
            9                  THE WITNESS:  Exactly.
           10                  THE COURT:  Okay.
           11   BY MR. DANDAR:
           12        Q    Are you aware of any requirements to report
           13   people who are PTS --
           14                  THE COURT:  Oh, let me ask a question here.
           15                  While you were at home and all of this you
           16        were revealing to us, you were not on any type of
           17        program?
           18                  THE WITNESS:  Like a baby watch --
           19                  THE COURT:  Right.
           20                  THE WITNESS:  -- or vitamins?
           21                  THE COURT:  No.  I mean, there was no
           22        Scientologist auditor there?
           23                  THE WITNESS:  No, no, there wasn't.
           24                  THE COURT:  You were by yourself?
           25                  THE WITNESS:  Basically, yes.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 102
            1                  THE COURT:  All right.
            2   BY MR. DANDAR:
            3        Q    In your 20 years of Scientology, were you aware
            4   of any requirement to report people who are PTS Type III?
            5        A    Well, yes.  It's not a good result.  And, yes, it
            6   is supposed to be reported so it gets fixed.  I mean,
            7   that's -- it's not that mistakes don't happen.  What's
            8   important is that they don't get repeated.
            9        Q    To whom are you --
           10        A    That's what's important.
           11        Q    To whom are you supposed to report PTS Type III?
           12        A    When I was in, it would have been Int.  And then
           13   when this happened to me, it would have been the RTC, who
           14   at that point was that senior review organization.
           15        Q    Okay.  Now, did you follow Dr. Shields' advice on
           16   what to take?
           17        A    At that time, yes.
           18        Q    Okay.  And you started to get worse?
           19        A    I continued to get worse.
           20        Q    Okay.  Did you have any physical problems as --
           21   following those orders or suggestions?
           22        A    I still wasn't sleeping or eating.  I wasn't
           23   sleeping or eating.
           24        Q    And when -- you called OSA Int to let them know
           25   that?
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 103
            1        A    I would call them -- now, when I know a little
            2   bit more, maybe I did call them a lot.  I mean, I was
            3   pretty out of it.  And I know -- I know that I called every
            4   day.  I know I called every day and probably was quite
            5   annoying and called a lot more than that.
            6        Q    Did they --
            7        A    I --
            8        Q    Did they send anyone to help you?
            9        A    One time people came.  And I had -- it was like
           10   in A Beautiful Mind, where the guy tries to make everything
           11   make sense.  And I wasn't getting any help.  I mean, there
           12   weren't -- so I kind of went, "Well, okay, I'll figure it
           13   out."
           14             And so I started to pull together different
           15   things.  I had a dream journal and I had another journal
           16   and I found -- I mean, stuff that now doesn't make any
           17   sense but at the time it made complete sense, that if they
           18   just had this information, then they could help me and get
           19   my mind back.
           20             And I called them to tell them this.  And I said,
           21   "And by the way, I found some e-mails from Arnie Lerma,"
           22   who at that time was the big court case.  And they were at
           23   my house within 15 minutes.  And -- to take the stuff and
           24   go back, which I was --
           25                  THE COURT:  What is this "stuff," ma'am?
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 104
            1                  THE WITNESS:  That I gave?  It was a journal
            2        and a book that I had been reading.  I mean, it's just
            3        bizarre.  When you're crazy, odd things make sense to
            4        you.
            5                  THE COURT:  Did they take the e-mails too?
            6                  THE WITNESS:  Absolutely.
            7   BY MR. DANDAR:
            8        Q    Did they stay and watch you?
            9        A    No.  They got the e-mails and they left.
           10        Q    What happened next?
           11        A    I continued to deteriorate.  And then there was a
           12   shift at one time in my mind, where they weren't coming,
           13   I'm calling, they keep telling me to wait, and I'm getting
           14   worse and it's getting worse.
           15             And there was a shift in my mind, because when I
           16   had done my spying work, especially for the European
           17   contingent -- right? -- Captain Bill was a big promoter
           18   that the reason -- I can't even say this with a straight
           19   face.  The reason why there was a schism in the Church was
           20   because the alien race, the Marcabians, had come and taken
           21   over David Miscavige and the other people at OSA Int and
           22   anybody that was left was really being controlled by
           23   aliens.  And that was their thought.
           24                  THE COURT:  This was the European --
           25                  THE WITNESS:  The European squirrels.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 105
            1                  THE COURT:  Okay.
            2                  THE WITNESS:  That's what they thought.
            3        That made sense to them.
            4        A    So at that point -- which this had never made
            5   sense to me, okay, ever, until I'm crazy.  I'm totally
            6   nuts, and it's getting worse.  And every time I call, to me
            7   it was cold and inhuman.  And I went:  "Captain Bill was
            8   right.  They have been taken over by aliens."
            9   BY MR. DANDAR:
           10        Q    Why was it cold and inhuman?
           11        A    Because there was no -- there was no help.  There
           12   was no help.
           13        Q    Did you finally get help?
           14        A    Yes.
           15        Q    How?
           16        A    This day after the aliens -- and then it went
           17   into like an "opposite" thing.  And it was very
           18   complicated, but it all made sense at the time.  But I
           19   thought that this was the peak or whatever.  And I ended up
           20   collapsing on the street, totally out of it.
           21        Q    Where?
           22        A    In Burbank, not far from my house.
           23        Q    Okay.
           24        A    And the ambulance came.  And because I wasn't
           25   making any sense and I was quite combative because I could
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 106
            1   see the aliens were taking them and I could see different
            2   Sea Org members that were from OSA, they were -- the aliens
            3   have really taken over.  And they put me in restraints and
            4   took me to the hospital.
            5        Q    Did OSA show up at the hospital?
            6        A    Yes.
            7        Q    And what happened?
            8        A    There's a state law -- I think in California it's
            9   called the Baker Act -- and there are certain questions you
           10   have to answer.  You have to know what day it is, where --
           11   something like that.  And I had not -- when my husband
           12   showed up at the hospital, I did not recognize him.  That's
           13   how out of it I was.  And I didn't really answer those
           14   questions correctly.
           15             But my husband said the people from OSA were
           16   there so that I didn't get placed in a psychiatric unit.
           17        Q    Because it was against your religion?
           18        A    Well, psychiatry was bad.
           19        Q    Okay.
           20        A    And during that time, there was a moment -- how
           21   OSA found out about it is this prescription drug I had been
           22   given.  The hospital said, "Are you on --" "Is she on
           23   drugs?" to my husband.  And he brought the bottle, and they
           24   called the doctor.  And the doctor called OSA, and then OSA
           25   sent a woman straight -- you know, who lived close, and
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 107
            1   then they got in their car and came.
            2             But in my state of mind, when I'm there and I'm
            3   in restraints and I'm thinking they're all -- things, there
            4   was a nurse in the corner who picked up the little bottle
            5   of pills of the chloral hydrate.  And I remember she
            6   started laughing.
            7                  MR. WEINBERG:  Objection, your Honor.  This
            8        is hearsay.
            9                  THE COURT:  Sustained.
           10                  MR. DANDAR:  Okay.
           11                  THE WITNESS:  What's the hearsay?
           12                  MR. DANDAR:  You just can't tell us what she
           13        said.
           14                  THE WITNESS:  It had a big effect on me.
           15                  MR. DANDAR:  Well, it goes to the state of
           16        mind exception then, and I would ask the Court to
           17        reconsider.
           18                  THE COURT:  I don't know what she's going to
           19        say, but it's certainly a hearsay statement.  So I
           20        can't --
           21                  MR. DANDAR:  Okay.
           22                  THE WITNESS:  Okay.
           23   BY MR. DANDAR:
           24        Q    So anyway, as a result of that, did you stay in
           25   the hospital or get out?
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 108
            1        A    I got out.
            2        Q    Okay.  And where did you go?
            3        A    Home.
            4        Q    All right.  Were you ever -- did you ever have an
            5   experience of a baby watch?
            6        A    It was a sort of baby watch.  I had people come
            7   and stay with me and watch me, but it wasn't one of
            8   those -- you know, where they can't talk to you.  There was
            9   very muzzled talking.
           10        Q    But they still talked to you?
           11        A    Yes.
           12        Q    And these were people who were your friends?
           13        A    Yes.
           14        Q    And they were all Scientologists?
           15        A    Yes, except my husband did get one friend to come
           16   stay with me, but I think that was after OSA was involved.
           17        Q    And were this -- these OSA people, were they --
           18   I'm sorry.
           19        A    I mean, they weren't OSA; they were
           20   Scientologists.
           21        Q    That's my question.  I'm sorry.  I'll stop.  Were
           22   they OSA?
           23        A    No.
           24        Q    Okay.  But they were Scientologists?
           25        A    Correct.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 109
            1        Q    Were they on staff?
            2        A    No.
            3        Q    Okay.  So they were public like you?
            4        A    Exactly.
            5        Q    All right.  And how long did that last?
            6        A    Just a day or two.  And then my husband came to
            7   me and said -- like really got in there to really
            8   communicate to me and said:  "We are on our own.  There is
            9   no help coming.  There is no anything, but we will get
           10   through this."
           11        Q    Now -- and I'm asking you questions to try to see
           12   if we can go through this right now.
           13        A    Well, the very next thought that I had, other
           14   than the relief of some support, some support -- this was
           15   the first feeling of support that had gotten through to me
           16   since this all happened.  I went:  "Oh, my God.  I need to
           17   do the exact opposite of everything that OSA Int told me to
           18   do."
           19             And so I stopped the pills.  I stopped the
           20   vitamins.  I stopped, you know, pretty much everything that
           21   they said to do.  I stopped, because the day that wound me
           22   up in the hospital was an "opposite" day.  It -- it doesn't
           23   make any sense.  But at the time when you're crazy, it made
           24   total sense, that we would be safe if everything was in
           25   opposites.  And I went out a window instead of a door, and
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 110
            1   I, you know, did things as an opposite.
            2             So it went into that same theory when he said to
            3   me that they are -- there is no help, there is no OSA,
            4   there is no Scientology.  I went:  "Okay.  Good.  Then he
            5   must know they're aliens, and we are going to do the
            6   opposite."
            7             And I'd like to say that magically I got better,
            8   but it wasn't like that.  It was horrific.  And eventually
            9   I got to a point where I would appear normal.  I -- I would
           10   pretend to be normal.
           11             And I used to get up in the morning and read the
           12   paper, so I would start to pretend to read the paper.  And
           13   I would sit there with the paper and figure, okay, this is
           14   enough time to turn the page.
           15        Q    Okay.
           16        A    And I would do that, figuring that if I just kept
           17   creating normalness --
           18        Q    How long did it take you to, what you believe, to
           19   get over this and get back to being normal?
           20        A    I will never be normal.  You do not ever fully
           21   recover from something this traumatic.  But it was in June.
           22   This happened in January, February.  I remember in June --
           23                  THE COURT:  Of what year, ma'am?
           24                  THE WITNESS:  1996.
           25                  MR. DANDAR:  '96.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 111
            1        A    It was in June that I felt -- and I remember the
            2   day -- that the walls came back in my mind, meaning like a
            3   separation between I would know for sure when I was
            4   dreaming and the walls were going to stay there.
            5   BY MR. DANDAR:
            6        Q    When you took the Cal Mag, did it have any effect
            7   on you?
            8        A    None of these vitamins and stuff helped.  And it
            9   wasn't until later that I felt that they had an impact in
           10   my treatment and in my recovery.
           11        Q    What impact did Cal Mag have?
           12        A    Well, it is a dehydrating -- I mean, it can
           13   dehydrate you, like coffee.  It can dehydrate you.
           14        Q    And what about the Vitamin Bs that you took?
           15        A    B-1.  And I was taking handfuls, because kind of
           16   like more is better, right?  Actually, it can make it so
           17   you don't sleep.  I mean, I didn't know this at the time.
           18             But it was -- the thing is, back in March, I
           19   started to feel a little better.  And truthfully, I
           20   shouldn't have been driving.  But I wasn't letting people
           21   know what was going on in my head, so I was driving.
           22             And I got a call.  And I'm thinking -- and it was
           23   from somebody from OSA.
           24        Q    What month was this?
           25        A    It would be March.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 112
            1        Q    Of '96?
            2        A    '96.
            3        Q    Now, up until that time, after OSA knew that
            4   you're in the hospital, in restraints, and --
            5        A    They did send one person to the house after the
            6   hospital and restraints.  One person came.
            7        Q    And what did that person do?
            8        A    Kirsten.
            9        Q    What did she do?
           10        A    I mean, I was hallucinating at that time.
           11        Q    Okay.  All right.
           12        A    I was --
           13        Q    Did you ever --
           14        A    You interrupted her, Counselor.
           15                  MR. DANDAR:  I'm sorry.
           16                  THE COURT:  You were hallucinating?
           17        A    I was hallucinating at the time.  I mean, she
           18   came to just say, you know, that maybe, you know, that --
           19   my husband said I should leave town or go away, and maybe
           20   that was a good idea.  Maybe that was what I should do.
           21                  THE COURT:  She was there to try to help you
           22        or to talk to you?
           23                  THE WITNESS:  Basically, yes -- basically
           24        she was there to give me a message.  And the message
           25        was, "Maybe you should go away."
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 113
            1                  It wasn't like:  "We'll help you.  We'll
            2        send somebody with you."
            3                  It was like, "Maybe some time at a mountain
            4        retreat might be nice."  And that was the message.
            5                  And my husband went, "We're not getting any
            6        help from these people, so we're just not going to --"
            7                  And it went into my -- you know, they're
            8        Marcabians anyway, so let's just do the opposite.
            9                  Around March, I got a phone call from some
           10        friends, and they said somebody wanted to interview me
           11        and find out what had gone wrong, why there was such a
           12        bump in the road and that maybe it might help other
           13        people.
           14                  And I thought:  "Of course.  They care.
           15        They care what happened and why."
           16                  But I later found out, when I got a call the
           17        next day from OSA legal, that what they wanted me to
           18        do was sign papers that what happened to me was not
           19        their fault.
           20                  And in one of the papers, they called what
           21        happened to me "a stressful incident," in quotation
           22        marks.
           23                  And I said, "What's a stressful incident?"
           24                  And they said, "Well, that's what we call
           25        what happened to you."
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 114
            1                  And I still thought that they had the
            2        Marcabian thought police things, machines on top of
            3        the building.  They're called tepaphones.  And I
            4        thought that if I signed these papers that they would
            5        shut those machines off and stop bothering me.
            6                  So I signed them.  And they somewhat left me
            7        alone.  I don't remember right offhand exactly how
            8        long, but it was months later I got a call out of the
            9        blue from some guy at OSA Int saying:  "Oh, this is
           10        Joe Blow.  You didn't get very far in your SEP check.
           11        You need to come back in."
           12                  And I was like, "Do you know what happened
           13        to me?"
           14                  And he said Scientology doesn't give any bad
           15        results and that there must be something wrong with
           16        me.  And at that point, my husband took the phone.
           17        For that first year, which is 1990 --
           18   BY MR. DANDAR:
           19        Q    Six?
           20        A    I didn't talk about it.  I tried not to even
           21   think about it, because if I think about it, I could go
           22   psycho again.  I mean, it was like really hold it together.
           23             And after maybe eight months, maybe ten months or
           24   whatever, I called Donna at OSA Int, who was the person
           25   with the e-mail who brought me in.  And I'm thinking --
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 115
            1   because when I ended up in the hospital, I got flowers from
            2   my non-Scientology friends, and from my -- what was my
            3   family at that time, I got legal papers for me to sign.
            4   And that really bothered me.
            5             And I said to Donna -- I said, well, maybe she
            6   just didn't know -- you know, maybe she just didn't know
            7   what happened to me.  And then I had her on the phone.  And
            8   I said, "You know, Donna, maybe you just didn't know."
            9             She said, "Oh, no, I knew exactly what happened
           10   to you, and my advice to you is you should just get over
           11   it" and kind of like "just suck it up."
           12             And that was a big moment for me with my group,
           13   because, you know, I was never a person that needed a lot
           14   of help, you know?  I was fairly -- what they call a
           15   Cadillac PC, you know?  It was like I was just, you know,
           16   don't do much and I get better, you know?  And this was a
           17   time I really, really, really needed help, and I did not
           18   get it.
           19             And during this year when I was pretending --
           20   there's somebody called an FSM, which is your bridge
           21   between you and Services Int Organization, and mine's name
           22   was Barry.  And even during this year he would call me
           23   every couple weeks and say, "Hey, Nance, how are you
           24   doing?"
           25             And I would say, "Okay," because I was in my "be
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 116
            1   normal" time.
            2             And he would say, "Well, call me if you need me,"
            3   click.
            4                  THE COURT:  I'm sorry, this is a real --
            5        this is a real person?
            6                  THE WITNESS:  Real person.
            7                  THE COURT:  And this is a part of the --
            8                  THE WITNESS:  Of the services.
            9                  THE COURT:  -- services.
           10                  THE WITNESS:  And he would do this.  And
           11        this was his job, to make sure I got good service.  So
           12        finally after about a year of this periodic phone
           13        calls and me pretending "Everything is fine, bye," and
           14        he says, "Call me if you need me," finally after about
           15        a year and a half or a year -- I don't know exactly --
           16        I said, "Barry, when this happened to me" -- because
           17        he was one of the people that I called when I was
           18        crazy.
           19                  I said, "You say in these phone calls, you
           20        say, 'Call me if you need me,'" and I said, "there was
           21        one time that I really needed you and I called you and
           22        you were not there."
           23                  And he told me that he had tried, and OSA
           24        Int told him that they had it under control --
           25                  MR. WEINBERG:  Objection, hearsay, your
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 117
            1        Honor.
            2                  THE WITNESS:  -- and for him to stay out of
            3        it.
            4                  THE COURT:  That objection is overruled.
            5                  MR. WEINBERG:  Because it's not hearsay?
            6                  THE COURT:  Because I overruled it.
            7                  MR. WEINBERG:  I know, but for the record --
            8                  THE COURT:  Because I don't have to tell you
            9        why.  I overruled it, Counselor.
           10        A    He told me that he was told to stay out of it,
           11   but then he never called me again after that conversation.
           12   BY MR. DANDAR:
           13        Q    Did anyone ever offer you the introspection
           14   rundown?
           15        A    At one point, I actually packed my bags because I
           16   thought I was going to go, you know, to have a formal baby
           17   watch.
           18        Q    Is that what they call an introspection rundown,
           19   a baby watch?
           20        A    Well, a baby watch would be kind of part of it.
           21        Q    Okay.
           22        A    Yes, that would be the step for somebody who is
           23   hallucinating.  You know, you don't do the other steps.
           24        Q    What's involved in the baby watch?
           25                  MR. WEINBERG:  Personal knowledge, your
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 118
            1        Honor?  Is she --
            2                  THE COURT:  It's about as personal as it
            3        gets, I assume.  She was there.
            4                  MR. WEINBERG:  No.  She said she wasn't on
            5        one.
            6                  THE WITNESS:  Only on a light one, a muzzled
            7        one.  It wasn't a formal baby watch, no.
            8   BY MR. DANDAR:
            9        Q    Within your 20 years and the highest on the
           10   bridge that you can go, do you know what a baby watch is?
           11        A    Yes.
           12        Q    And could you tell us what your understanding is.
           13        A    A baby watch is when --
           14                  THE COURT:  Who threw that?
           15                  MR. WEINBERG:  I just put it on the desk.
           16                  THE COURT:  Well, I hope it wasn't thrown.
           17                  MR. WEINBERG:  It wasn't thrown.
           18                  THE COURT:  It better not have been.
           19                  MR. WEINBERG:  It was not.
           20                  THE COURT:  All right.
           21        A    A baby watch is when people are troubled,
           22   stressful incidents, and they --
           23                  THE COURT:  Let me see if I can narrow this
           24        into what I might need to know.  In the introspection
           25        rundown, there are some preliminary steps, part of the
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 119
            1        rundown perhaps, perhaps not.  I perceived it as part
            2        of the rundown, okay?  That's Step 000, which is
            3        rest --
            4                  THE WITNESS:  Right.
            5                  THE COURT:  -- vitamins --
            6                  THE WITNESS:  Quiet.
            7                  THE COURT:  -- quiet, preparing one for
            8        auditing --
            9                  THE WITNESS:  Correct.
           10                  THE COURT:  -- which is where the real
           11        rundown, I take it, starts.
           12                  THE WITNESS:  Exactly.
           13                  THE COURT:  When you talk in terms of baby
           14        watch, are you talking --
           15                  THE WITNESS:  Those --
           16                  THE COURT:  -- before 0 --
           17                  THE WITNESS:  -- steps.
           18                  THE COURT:  You're talking 0 --
           19                  THE WITNESS:  Right.
           20                  THE COURT:  -- 00.
           21                  THE WITNESS:  Right.
           22                  THE COURT:  So in your mind, you were --
           23        what was going on at your house was not really 000?
           24        Or it was?
           25                  THE WITNESS:  No, it wasn't --
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 120
            1                  THE COURT:  Okay.
            2                  THE WITNESS:  -- because --
            3                  THE COURT:  Because it was not muzzled.
            4                  THE WITNESS:  Well, there was some talking.
            5                  THE COURT:  Right.  And in 000, there's no
            6        talking.
            7                  THE WITNESS:  Right.
            8                  THE COURT:  So you perceived you were -- it
            9        was some -- something not part of the introspection
           10        rundown.
           11                  THE WITNESS:  Right.  But it's still called
           12        baby watch.
           13                  THE COURT:  Okay.
           14                  THE WITNESS:  There's other kinds of baby
           15        watches.  There's other reasons people would be on
           16        baby watch.
           17                  THE COURT:  If you had packed your bags and
           18        if they -- it had been determined that you needed the
           19        introspection rundown, you would have started with the
           20        Step 000.
           21                  THE WITNESS:  Exactly, which was to be
           22        isolated.
           23                  THE COURT:  Which was to be isolated,
           24        muzzled, rest --
           25                  THE WITNESS:  Exactly.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 121
            1                  THE COURT:  -- prepared for auditing.
            2                  THE WITNESS:  Exactly.
            3                  THE COURT:  So that's not a baby watch.  You
            4        would call that part of the introspection rundown
            5        or --
            6                  THE WITNESS:  But when you're watched, it's
            7        also called baby watch.
            8                  THE COURT:  Is that a terminology --
            9                  THE WITNESS:  That's a slang term.
           10                  THE COURT:  Slang term.
           11                  THE WITNESS:  I don't think that "baby
           12        watch" is in any of the dictionaries.
           13                  THE COURT:  So 000 is what slangly you call
           14        baby watch.
           15                  THE WITNESS:  Correct.
           16                  THE COURT:  When it gets into formal
           17        auditing, that's no longer baby watch?
           18                  THE WITNESS:  Right.
           19                  THE COURT:  Okay.
           20   BY MR. DANDAR:
           21        Q    Did -- when you were taking chloral hydrate, did
           22   it have any effect on you besides making you go to sleep?
           23        A    It really didn't totally make me go to sleep, but
           24   I learned later that it's a hypnotic drug.  The
           25   manifestations that I found during it was that there were
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 122
            1   some sequence of dog barking and then an ambulance siren --
            2   I mean, it just became -- and that would trigger me off
            3   into another thing.  There were things that -- patterns.  I
            4   guess sort of like A Beautiful Mind.  When you're
            5   psychotic, you try and make things into patterns.  You try
            6   and make things make sense.
            7        Q    And when you say A Beautiful Mind, you're
            8   referring to the movie?
            9        A    The movie, I'm sorry, yes.
           10        Q    Okay.  And did the chloral hydrate have any
           11   effect on your psychosis?
           12        A    No.  I just know when I was taking that stuff I
           13   was getting worse every single day, and when I stopped
           14   taking it, I started to get better.
           15        Q    All right.  Now --
           16                  THE COURT:  Did you ever go for any type
           17        of -- you were still in the Church at the time this --
           18                  THE WITNESS:  Absolutely.
           19                  THE COURT:  And at the time of your
           20        recovery.
           21                  THE WITNESS:  The initial recovery --
           22                  THE COURT:  Whatever.
           23                  THE WITNESS:  -- because I was -- right.
           24                  THE COURT:  The March, June --
           25                  THE WITNESS:  Exactly.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 123
            1                  THE COURT:  -- time frame.  All right.  So
            2        therefore, you never sought any type of psychiatric
            3        help --
            4                  THE WITNESS:  No.
            5                  THE COURT:  -- because that was not --
            6                  THE WITNESS:  Exactly.
            7                  THE COURT:  -- permitted --
            8                  THE WITNESS:  Exactly.
            9                  THE COURT:  -- or not believed in.
           10                  THE WITNESS:  Right.
           11                  THE COURT:  So when you say --
           12                  THE WITNESS:  No, not because it was not
           13        believed -- it was feared.  But I will tell you in
           14        that state of mind if somebody had said, "Here is a
           15        pill, and it will make these hallucinations go away,"
           16        I would have taken it, even though I was not a
           17        supporter of psychiatry.
           18                  THE COURT:  You mean like a psychotropic
           19        drug --
           20                  THE WITNESS:  Exactly.
           21                  THE COURT:  -- what a psychiatrist --
           22                  THE WITNESS:  Exactly.
           23                  THE COURT:  -- might have prescribed.  The
           24        drugs that -- as I understand them -- that you were
           25        given by the doctors were not what I would perceive to
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 124
            1        be prescription drugs.  They were --
            2                  THE WITNESS:  Chloral hydrate is a
            3        prescription drug.
            4                  THE COURT:  Is that a prescription drug?
            5                  THE WITNESS:  Yes.
            6                  THE COURT:  Okay.  But the others, like the
            7        melatonin is --
            8                  THE WITNESS:  Vitamin store.
            9                  THE COURT:  Right.  I guess I should finish
           10        my thought.  That's something I could go out to a
           11        health store and buy --
           12                  THE WITNESS:  Exactly.
           13                  THE COURT:  -- supposedly has some sleep
           14        help to it.
           15                  THE WITNESS:  Right.
           16                  THE COURT:  I think they also take it for --
           17        I took it one time for a time zone change.
           18                  THE WITNESS:  Right, time drop.
           19                  THE COURT:  Yes.
           20                  MR. DANDAR:  I didn't know that.
           21                  THE COURT:  It does help you sleep too.
           22                  MR. WEINBERG:  Which one was that?
           23                  THE COURT:  Melatonin.
           24                  THE WITNESS:  Melatonin.
           25                  THE COURT:  It's really something a lot of
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 125
            1        people take every day.  I talked to my court
            2        administrator about it back when I was chief judge
            3        because I found it to have a very good sleep effect.
            4        I didn't need that, but it did.  I mean, I would take
            5        it and I was sleepy.  So I told him.  He started
            6        taking it daily, and he uses it to this very day.  A
            7        lot of people do.  It promotes a sleep habit.
            8        Naturally.  It's not a drug.  It's a natural
            9        put-you-to-sleep aid.
           10   BY MR. DANDAR:
           11        Q    Did you --
           12                  MR. WEINBERG:  I have to try that.
           13                  THE COURT:  Try it.  Let me tell you, it
           14        takes about a week for it to work, but a lot of people
           15        swear by it.  If I needed a sleep aid, I'd try it
           16        again.
           17                  MR. WEINBERG:  You get it at a vitamin
           18        store?
           19                  THE COURT:  Yes.  Or I think now you can get
           20        it at an Eckerd's.  It's become very popular.
           21                  THE WITNESS:  It's very common now.
           22                  THE COURT:  Back when she was talking about
           23        it, it was not.
           24                  THE WITNESS:  It was the latest fad.
           25                  THE COURT:  Right, it was the latest fad.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 126
            1        Then it became a very popular thing.  A lot of people
            2        take melatonin.
            3   BY MR. DANDAR:
            4        Q    Before this experience that you just told us
            5   about in 1996, had you ever -- were you ever asked to
            6   participate in a baby watch?
            7                  THE COURT:  Can we call this an
            8        "introspection rundown" in this court, rather than a
            9        slang term?
           10                  THE WITNESS:  No, because it was
           11        communicated to me as a baby watch, and I don't know
           12        if it was an official --
           13                  THE COURT:  Okay.
           14                  THE WITNESS:  -- introspection rundown.
           15        A    Yes, I was.  It was the last request I had from
           16   OSA Int.
           17   BY MR. DANDAR:
           18        Q    When was that?
           19        A    So that would have been in early 1995.
           20        Q    Did you participate in one?
           21        A    No.  I was asked to take someone into my home who
           22   had been a spy for OSA and had gotten himself kind of
           23   tangled up in terms of, you know, his head and that they
           24   just wanted him watched, but that they had a -- you know,
           25   they would pull him out of it.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 127
            1        Q    When -- when you were visiting the Fort Harrison
            2   Hotel on those three occasions you talked about, did you
            3   ever go to the basement?
            4                  MR. WEINBERG:  Excuse me?  Which hotel are
            5        we talking about?
            6                  THE COURT:  Fort Harrison.
            7                  MR. WEINBERG:  Fort Harrison?
            8        A    I have been to the basement, yes.
            9   BY MR. DANDAR:
           10        Q    Did you ever see people kept in the basement?
           11        A    Years ago, yes.
           12        Q    In the basement of the Fort Harrison?
           13        A    Yes.  I actually was supposed to be sent there
           14   once.
           15        Q    For what reason?
           16        A    RPFs, RPF.
           17                  MR. WEINBERG:  Your Honor, the relevance of
           18        this is what?  Because that's not the evidence in this
           19        case.
           20                  THE COURT:  I have no idea.  I would assume
           21        it's not relevant.
           22                  MR. WEINBERG:  Thank you.
           23   BY MR. DANDAR:
           24        Q    Now, did you ever get any type of counseling --
           25                  THE COURT:  "Counseling" being auditing?
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 128
            1   BY MR. DANDAR:
            2        Q    Auditing, any type of program from the Church of
            3   Scientology in 1996, '97, '98 --
            4        A    After that point?  No.
            5        Q    Did you ever go back as a member of the Church of
            6   Scientology?
            7        A    I didn't -- I didn't leave right away.  Like I
            8   said, that first year I was just trying to pretend to be
            9   normal.  I mean, who cared about Scientology and the
           10   critics and who was right and who was wrong?  I wanted to
           11   live.
           12             Donna's phone call when she told me to just --
           13   she knew what happened but just get over it.  And then I
           14   heard about Lisa McPherson.  It started to hit the press
           15   about a year after what had happened to me.
           16             And I remember there was one TV show where some
           17   expert witness was saying --
           18                  MR. WEINBERG:  Objection, your Honor.  What
           19        does this have to do with anything?  She watched a TV
           20        show in 19 --
           21                  THE COURT:  I don't know, but I'm going to
           22        let her tell it because I have no idea what she is
           23        going to say.  It was a TV show that caused her to do
           24        something.
           25                  MR. WEINBERG:  Just so Mr. Dandar is not
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 129
            1        going to ask her to speculate as to Lisa McPherson.
            2                  THE COURT:  Right.
            3                  THE WITNESS:  No.
            4        A    It caused me to write a letter to David
            5   Miscavige.  Even what had happened to me -- I mean, even
            6   now, last year, I wrote a letter to Mike Rinder.  This did
            7   not make me become an anti-Scientologist or a major critic,
            8   although I am extremely critical of how they handle people
            9   in this kind of a state of mind, which is why I'm here.
           10             But I wrote to David Miscavige, because my
           11   handling happened at OSA Int, so who was -- you know what I
           12   mean?  It was like go higher.  And just told him that like:
           13   "Hey, you know, this happened to me and when I took all
           14   these -- when I stopped taking all these vitamins, I got
           15   better.  And you need to know that so that this does not
           16   happen to someone else.  This might be related.  Please
           17   look into it."
           18   BY MR. DANDAR:
           19        Q    Did you assist anyone else that this happened to?
           20        A    Yes.
           21        Q    Who?
           22                  THE COURT:  Did you write a similar letter
           23        to Mr. Rinder?
           24                  THE WITNESS:  My letter to Mr. Rinder was
           25        actually right before the similar thing.  It was last
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 130
            1        year.  I was trying to think.  It was five years since
            2        this happened to me, and I wanted to move forward.  I
            3        was doing a lot better.  I knew I didn't want to be a
            4        Scientologist, but I wanted to let this go.
            5                  I had thought about contacting Bernie McCabe
            6        when he was doing that trial.  And then --
            7                  THE COURT:  You're talking now about the --
            8                  THE WITNESS:  The civil -- I mean the
            9        criminal case.
           10                  THE COURT:  -- the criminal case?
           11                  THE WITNESS:  Right.  And I never could go
           12        through with it for a variety of different reasons.  I
           13        had already processed through the thought.  It was
           14        like was I going to sue them for damages for myself
           15        personally.  And --
           16                  THE COURT:  "Them" meaning the Church of
           17        Scientology.
           18                  THE WITNESS:  The Church of Scientology,
           19        yes, for what happened to me.  And what I came to feel
           20        was what I wanted was an apology.  And if you have to
           21        sue and end up in this kind of a courtroom to get an
           22        apology, it doesn't really have a lot of meaning.
           23                  So five years ago, I went:  "Okay.  I have
           24        to let this go."  And I went on a retreat with the
           25        purpose of what do I need to totally let this go and
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 131
            1        just move forward with my life.
            2                  THE COURT:  A retreat.  A Scientology
            3        retreat --
            4                  THE WITNESS:  No.
            5                  THE COURT:  -- or your own retreat?
            6                  THE WITNESS:  No.  It was a Catholic Church
            7        retreat.
            8                  THE COURT:  Okay.
            9                  THE WITNESS:  It was a spiritual retreat.
           10                  THE COURT:  Okay.
           11                  THE WITNESS:  And I did end up at the end
           12        with clarity.  I'm like, "I just want to talk to
           13        somebody."  I don't think you intentionally at OSA Int
           14        got up in the morning and said, "Today we're going to
           15        drive Nancy crazy."  I really don't think these people
           16        intended that result, although there are some people
           17        in my life that differ from me in that regard.  But I
           18        don't hold that.
           19                  And I just would like to know what was
           20        happening on the other end.  I was crazy.  What did
           21        these people that got these phone calls from me, what
           22        were they thinking?  Why didn't they come or give
           23        help -- I just wanted to know that.  And --
           24                  THE COURT:  This was the purpose of your
           25        letters was, number one, to tell them --
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 132
            1                  THE WITNESS:  Exactly.
            2                  THE COURT:  -- what you thought helped you,
            3        that maybe they would want to know; and, number two --
            4                  THE WITNESS:  For me --
            5                  THE COURT:  -- to say what was going on.
            6                  THE WITNESS:  Exactly.
            7                  What occurred after that retreat was I had
            8        two people come into my life.  The other thing was at
            9        that time at that retreat all I knew about was Lisa
           10        and myself that this had happened to.  After that
           11        retreat, I contacted -- two people contacted me.
           12                  One's name is Greg Bashaw, and the other one
           13        is a woman in L.A.  And I talked with both of them.  I
           14        had at some point during these earlier years posted on
           15        the Internet my story under an assumed name.  And
           16        these people -- their families read it and got in
           17        touch through the anonymous people, because I was
           18        really trying to keep myself anonymous, such as like,
           19        "Hey, this is what's going on."
           20                  And so here's two people that I got in touch
           21        with that were quite in the same place as me, and Greg
           22        was the first one that I talked to.  And Greg was very
           23        similar to me.
           24                  MR. WEINBERG:  Objection as to hearsay, your
           25        Honor.  I don't know if she's going to go into the
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 133
            1        details of some conversation.
            2                  THE COURT:  True.  I don't think we need to
            3        get into the conversations with other people.
            4   BY MR. DANDAR:
            5        Q    What happened to Greg?
            6        A    He's dead.
            7        Q    How?
            8                  MR. WEINBERG:  Judge, I object.  I mean, if
            9        whatever she's about to say is based on something that
           10        she learned from someone else or read, it's hearsay.
           11        And beyond that, it's not relevant to this proceeding.
           12                  THE COURT:  It may not be and it probably
           13        isn't.  However, I certainly don't think that it's
           14        hearsay.
           15                  MR. WEINBERG:  It --
           16                  MR. DANDAR:  Okay.
           17                  MR. WEINBERG:  It's based -- I mean, if
           18        she's about to --
           19                  THE COURT:  If this man was a member of a
           20        corporate defendant, there is such a thing called a
           21        corporate exception.
           22                  MR. WEINBERG:  He's not, your Honor.  He's
           23        not a member of any --
           24                  THE COURT:  Apparently he was.
           25                  MR. WEINBERG:  Greg Bashaw?
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 134
            1                  THE COURT:  I guess.
            2                  MR. WEINBERG:  No.
            3                  THE WITNESS:  No.
            4                  MR. WEINBERG:  No.
            5                  THE WITNESS:  He was public.
            6                  THE COURT:  Well, public --
            7                  MR. WEINBERG:  It's like saying -- I mean,
            8        it's like saying there's some Catholic in New York
            9        that goes to the Catholic Church and then we're going
           10        to let hearsay --
           11                  THE COURT:  The fact that he's dead can't
           12        come into a court of law?
           13                  MR. WEINBERG:  No.  He asked -- he asked,
           14        How did he die?  And I objected.  How could she say
           15        that?  She doesn't have personal knowledge of that,
           16        unless she was with him when he died.
           17                  THE COURT:  That seems like a really silly
           18        objection.  It's overruled.  I mean, there's only
           19        several ways a person can die.  They either die from
           20        heart attack --
           21                  If that's what you're asking.  Is that what
           22        you're asking?
           23                  MR. DANDAR:  Yes.
           24                  THE COURT:  All right.
           25   BY MR. DANDAR:
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 135
            1        Q    How did he die?
            2        A    Suicide.
            3        Q    And the other person you helped, is she alive?
            4        A    Yes.  Yes, she is.
            5        Q    And did you help her?
            6        A    Yes, I did.
            7        Q    Okay.  Now, before you had these -- this
            8   experience of being -- did you use the word "psychotic"?  I
            9   don't want to --
           10        A    Yes.
           11        Q    Okay.  And you had that experience with this
           12   special type of auditing that took -- how many days?
           13                  THE COURT:  I really want -- I really want
           14        to ask you if that's true, that you would want --
           15        before somebody in this courtroom could say that
           16        somebody died of a suicide, you would want, before it
           17        wasn't hearsay, for them to have been present --
           18                  MR. WEINBERG:  No.
           19                  THE COURT:  -- when they killed themselves.
           20                  MR. WEINBERG:  The testimony has nothing to
           21        do with this proceeding.  And I don't think --
           22                  THE COURT:  And I am asking you, Counselor,
           23        whether or not you were serious about not allowing
           24        somebody to say how somebody died unless they were
           25        present.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 136
            1                  MR. WEINBERG:  No.  My objection was it
            2        would be based on hearsay.
            3                  THE COURT:  Well, it would be.  But you know
            4        what?  I suppose that's true about a lot of causes of
            5        death, and normally people are allowed to say --
            6                  MR. WEINBERG:  I just don't see the
            7        relevance.
            8                  THE COURT:  It may not be relevant.  I'm not
            9        suggesting anything she has said is relevant to this
           10        proceeding.  But we are going to get through this.
           11                  MR. WEINBERG:  I understand that.  I
           12        wouldn't think that this man's family would be all
           13        that enthusiastic about this testimony.  And it
           14        doesn't have anything to do with this proceeding.
           15                  THE COURT:  Well --
           16                  MR. WEINBERG:  And Mr. Dandar knows that.
           17        And what he's trying to do is somehow tarnish and put
           18        this Church on trial.
           19                  THE COURT:  You know, I think this witness
           20        has been one of the more favorable witnesses that
           21        Mr. Dandar has put on to the Church.  I have heard her
           22        say very little -- number one, she said very little
           23        about an auditing session --
           24                  MR. WEINBERG:  I'm not disagreeing with
           25        that.  But I know -- I don't believe that Mr. Dandar
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 137
            1        put her on to be favorable to the Church.
            2                  THE COURT:  Maybe he put her on to be a
            3        truthful witness, which is what apparently she's been
            4        thus far.  I'd like to get through this -- I'd like to
            5        get through this about as quickly as we can --
            6                  MR. DANDAR:  I'm almost --
            7                  THE COURT:  -- because it does have very
            8        little to do with this case.  However, this lady has
            9        come at great expense to this courtroom, and I'm going
           10        to let her finish.
           11   BY MR. DANDAR:
           12        Q    I just want to jump back.  When you became an
           13   officer at -- when you were on the Sea Org and you became
           14   that commodore staff aide, Division 6, did you have to sign
           15   a resignation letter?
           16        A    What happened is with certain positions you
           17   became automatically on the board of directors of different
           18   corporations of the Church of Scientology.
           19        Q    All right.
           20        A    And this was the corporate sortout, so this would
           21   have been in 1978.  So they've changed certain things, but
           22   I don't think that this has changed.  But it was just
           23   common practice when you signed onto the board, you signed
           24   an undated resignation letter at the same time so that
           25   when --
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 138
            1                  THE COURT:  Any board.  This is -- you went
            2        on --
            3                  THE WITNESS:  Corporate boards.
            4                  THE COURT:  -- corporate boards --
            5                  THE WITNESS:  These are corporate minutes,
            6        and you signed your undated resignation at the same
            7        time you signed on.
            8                  THE COURT:  Okay.
            9   BY MR. DANDAR:
           10        Q    And what about when you went to RTC?  Did you
           11   have to do the same thing there?
           12        A    No.
           13        Q    You were now a public member, so . . .
           14        A    No.
           15        Q    Okay.  All right.  Now, this --
           16                  THE COURT:  You were not on the board, I
           17        take it.
           18                  THE WITNESS:  No, I wasn't.
           19   BY MR. DANDAR:
           20        Q    Or OSA?
           21        A    No.
           22        Q    Because you were public?
           23        A    Correct.
           24        Q    Now, this episode that you talked about that
           25   happened in January of '96 --
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 139
            1        A    Yes.
            2        Q    All right.  Did you have an episode of being
            3   psychotic or not with it prior to you going to see the OSA
            4   Int where they talked about your e-mail to Kim Baker?
            5        A    No, not at all.
            6        Q    You only became that way after this special type
            7   of handling --
            8        A    Exactly.
            9        Q    -- auditing?
           10        A    Exactly.
           11        Q    Now, let me --
           12        A    And I also just -- I would like to clarify -- can
           13   I clarify something?
           14                  THE COURT:  Sure.
           15        A    I just want to clarify that my problem is not
           16   with the fact that that result happened.  It is with the
           17   way that I was treated after it happened.
           18   BY MR. DANDAR:
           19        Q    Were you treated?
           20                  THE COURT:  The way that you felt, ma'am,
           21        that you should have gotten help and that nobody was
           22        helping you.
           23                  THE WITNESS:  Exactly.
           24                  MR. DANDAR:  I wanted to ask that, but that
           25        was a leading question.
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 140
            1   BY MR. DANDAR:
            2        Q    All right.  Now, have you had any association or
            3   contact at all with Bob Minton or Stacy Brooks?
            4        A    Yes.
            5        Q    And what is that?
            6        A    With regards to the woman in L.A., I --
            7                  THE COURT:  If we're getting ready to go
            8        into a totally different area here, it seems like it
            9        would be a good time to break for lunch.
           10                  MR. DANDAR:  Okay.
           11                  THE COURT:  I've got about --
           12                  When is your plane, ma'am?
           13                  THE WITNESS:  Tomorrow morning.
           14                  THE COURT:  Tomorrow morning, okay.
           15                  Let's go ahead and take our lunch break.
           16        We'll be in recess until 1 o'clock.
           17                  (A lunch break was taken at 11:55 a.m.)
           18              ____________________________________
                                  KANABAY COURT REPORTERS
                                                   Volume 1, Page 141
            1   STATE OF FLORIDA
            2   COUNTY OF PINELLAS
            3        I, Debra S. (Laughbaum) Turner, Registered Diplomate
            4   Reporter, certify that I was authorized to and did
            5   stenographically report the foregoing proceedings and that
            6   the transcript is a true record.
            7        WITNESS MY HAND this 12th day of July, 2002, at
            8   St. Petersburg, Pinellas County, Florida.
           10                      _________________________________
                                   Debra S. (Laughbaum) Turner, RDR
           11                      Court Reporter
                                  KANABAY COURT REPORTERS

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