142
           1        IN THE CIRCUIT COURT FOR PINELLAS COUNTY, FLORIDA
           2                      CASE NO. 00-5682-CI-11
           3
           4
           5
                DELL LIEBREICH, as Personal
           6    Representative of the ESTATE OF
                LISA McPHERSON,
           7
           8              Plaintiff,
           9    vs.                                     VOLUME 2
          10    CHURCH OF SCIENTOLOGY FLAG
                SERVICE ORGANIZATION, JANIS
          11    JOHNSON, ALAIN KARTUZINSKI
                and DAVID HOUGHTON, D.D.S.,
          12
                          Defendants.
          13
                _______________________________________/
          14
          15
          16    PROCEEDINGS:        Defendants' Omnibus Motion for
                                    Terminating Sanctions and Other Relief.
          17
                CONTENTS:           Testimony of Nancy Many.
          18
                DATE:               July 12, 2002.  Afternoon Session.
          19
                PLACE:              Courtroom B, Judicial Building
          20                        St. Petersburg, Florida.
          21    BEFORE:             Honorable Susan F. Schaeffer,
                                    Circuit Judge.
          22
                REPORTED BY:        Lynne J. Ide, RMR.
          23                        Deputy Official Court Reporter,
                                    Sixth Judicial Circuit of Florida.
          24
          25
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           1    APPEARANCES:
           2
                MR. KENNAN G. DANDAR
           3    DANDAR & DANDAR
                5340 West Kennedy Blvd., Suite 201
           4    Tampa, FL 33602
                Attorney for Plaintiff.
           5
                MR. LUKE CHARLES LIROT
           6    LUKE CHARLES LIROT, PA
                112 N East Street, Street, Suite B
           7    Tampa, FL 33602-4108
                Attorney for Plaintiff
           8
           9    MR. KENDRICK MOXON
                MOXON & KOBRIN
          10    1100 Cleveland Street, Suite 900
                Clearwater, FL 33755
          11    Attorney for Church of Scientology Flag Service
                Organization.
          12
          13    MR. LEE FUGATE
                MR. MORRIS WEINBERG, JR.
          14    ZUCKERMAN, SPAEDER
                101 E. Kennedy Blvd, Suite 1200
          15    Tampa, FL 33602-5147
                Attorney for Church of Scientology Flag Service
          16    Organization.
          17
                MR. ERIC M. LIEBERMAN
          18    RABINOWITZ, BOUDIN, STANDARD
                740 Broadway at Astor Place
          19    New York, NY 10003-9518
                Attorney for Church of Scientology Flag Service
          20    Organization.
          21
          22
          23
          24
          25
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           1              THE COURT:  All right, continue.
           2    BY MR. DANDAR:
           3         Q    I think we left off with talking about Bob Minton
           4    and Stacy Brooks.
           5         A    Uh-huh.
           6         Q    When is the first time you talked to either one of
           7    them?
           8         A    I don't recall.
           9         Q    Okay.
          10         A    I don't recall.  I do -- I do remember -- I don't
          11    recall.
          12              THE COURT:  Can you give us a year?
          13              THE WITNESS:  It would have been around the
          14         time Tory Bezazian left the Church and went down
          15         there.  So that is just within the last two years.
          16    BY MR. DANDAR:
          17         Q    Okay.  Were you ever part of or associated with
          18    the Lisa McPherson Trust?
          19         A    No.
          20              THE COURT:  Is this when the Lisa McPherson
          21         Trust was up and --
          22              THE WITNESS:  It was up and running, yes.
          23              THE COURT:  That is when you first --
          24              THE WITNESS:  Yes.  And Tory had been a friend
          25         of mine, and neighbor, actually.  And when she
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           1         suddenly left Scientology, that is where she went.
           2              THE COURT:  Then you contacted her?
           3              THE WITNESS:  I contacted her.  I had concern
           4         for her.
           5    BY MR. DANDAR:
           6         Q    And have you and Tory -- how do you say her name?
           7         A    Bezazian.
           8         Q    Do you know how to spell that last name?
           9         A    B-E-Z-A-Z-I-A-N.
          10         Q    Okay.  Are you and Tory still friends?
          11         A    Yeah.  As far as I know.  As far as I know.
          12         Q    Are you aware that after I announced yesterday in
          13    this courtroom that --
          14              MR. WEINBERG:  Objection --
          15    BY MR. DANDAR:
          16         Q    -- you would be called as a witness --
          17              MR. WEINBERG:  "Are you aware that," and he's
          18         about to make a statement.  I object to the form.
          19              THE COURT:  That is true.  That sounds leading.
          20              MR. DANDAR:  Okay.
          21              THE COURT:  Well, I don't know, "are you
          22         aware," I guess she could say yes or no.
          23              MR. WEINBERG:  Except what he's doing, he's
          24         testifying.  I mean, it's -- it's -- in my opinion,
          25         it's a leading question.
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           1              THE COURT:  Okay.
           2    BY MR. DANDAR:
           3         Q    In your 20 years in Scientology, and when you were
           4    in the Sea Org 10 years of that, is there a head of the Sea
           5    Org?
           6         A    Currently?
           7         Q    While you were in it for 20 years, was there a
           8    head of the Sea Org?
           9         A    Yeah.  When I was in, it was L. Ron Hubbard.  And
          10    then it ended up being David Miscavige.  And I don't think
          11    there was anybody in the middle.
          12         Q    Okay.  All right.  Now, did you ever go and meet
          13    with Bob Minton?
          14         A    Yes.  I met with Bob Minton and Stacy once last
          15    year.
          16         Q    When was this?
          17         A    Last year at this time of year.
          18         Q    Summer?
          19         A    Yes.
          20         Q    All right.  In the summer of 2001, where did you
          21    meet them?
          22         A    In Sandown, New Hampshire.
          23         Q    At Mr. Minton's house?
          24         A    Yes.  At his house.
          25         Q    What was your reason to go there?
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           1         A    Mmm, Greg had just died.  And I had contact with
           2    another woman who had been -- well, actually she still
           3    considered herself, even though she was quite psychotic at
           4    the time, she was crazy, and I was concerned that I -- I
           5    didn't know of anyone who had valid help to offer someone in
           6    this state of mind, having come out of the Church of
           7    Scientology where traditional psychiatry is not an option.
           8    And it's not the time or place to try and talk to somebody
           9    about, "Oh, yeah, come to the psychiatrist."  It's not the
          10    time or the place to do that.
          11              And so what I was confronted with was -- Mmm --
          12    having been a survivor, having known that Lisa didn't
          13    survive and now Greg didn't survive, I -- first of all, I
          14    didn't understand why I survived.
          15              And, second of all, I wanted to make sure that if
          16    we ever, ever, ever heard of somebody else in this
          17    condition, that we could give them help.
          18         Q    How did you -- why would you choose to see Bob
          19    Minton or Stacy Brooks about that?
          20         A    It was not a planned event at all.  I was on my
          21    way to Vermont.  I -- it was a lot of synchronicity and
          22    serendipity.  And I happened to be driving by and I didn't
          23    even know if he was home.  It was just, "I'm on my way to
          24    Vermont" and "Are you there?"
          25              We had had phone contact before that, after Greg
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           1    died.  Stacy did not even know I had been in touch with
           2    Greg, let alone that I was hysterical about this.
           3              Mmm, and so we spent a few hours at his home.  And
           4    we -- and we communicated about this and really sat down
           5    and -- and Stacy and I mostly, not much of Bob, went through
           6    step by step what help did I get that Lisa McPherson and
           7    Greg did not, what were the differences, what were the
           8    similarities, what were the things that were the same, to
           9    try and piece together some sort of help.
          10              I just felt like somewhere on the Internet,
          11    someplace, there had to be some -- something.
          12         Q    But my question is why pick them out, out of all
          13    of the hundreds of other millions of people in the United
          14    States?  I mean, why them, Minton and Brooks?
          15         A    Well, I really wasn't choosing Minton.  Minton --
          16    I didn't even know, up to that time, if I had ever talked to
          17    him.  I may have never talked to him up until that point.
          18              Stacy was somebody I knew from the trust, had been
          19    in touch with Greg's family.  I knew --
          20              THE COURT:  You mentioned the trust --
          21              THE WITNESS:  The Lisa McPherson --
          22              THE COURT:  You knew about the Lisa McPherson
          23         Trust?
          24              THE WITNESS:  Yes.  And I knew Greg's family
          25         contacted them for help.
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           1              THE COURT:  So that is how you first got in
           2         touch with them?  Through the trust?
           3              THE WITNESS:  Through the trust.  Yes.
           4    BY MR. DANDAR:
           5         Q    And did you know that anyone from the trust had --
           6    was trying to help Greg Bashaw?
           7         A    No.  I -- I don't know.  I don't know.
           8         Q    All right.  So --
           9         A    But I did know that they had had -- that they were
          10    in touch with Lori, his wife, and Jesse was out there.  This
          11    would have been in early July.  So I did know the trust was
          12    involved with that.
          13              And I knew that -- like I said, I am not one to go
          14    to the critics, and I have never wanted what I considered to
          15    be high-profile people in my life that I did not already
          16    befriend.
          17              MR. WEINBERG:  Your Honor, I -- I missed one
          18         thing.  She said somebody had been out there with
          19         Greg's family.  And she said who --
          20              THE COURT:  Mr. Prince.  I believe that is what
          21         she said, is that --
          22              THE WITNESS:  Yes, Mr. Prince was out there.
          23    BY MR. DANDAR:
          24         Q    How did you find out about the Lisa McPherson
          25    Trust?  Was that through Tory?
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           1         A    No.  It was already up when Tory went there.
           2    Possibly the Internet.
           3         Q    Did you ever visit the Lisa McPherson Trust?
           4         A    No.
           5         Q    Did you ever engage in picketing against the
           6    Church of Scientology?
           7         A    No.
           8         Q    Okay.  And did Ms. Brooks offer you any -- any
           9    help for this woman you were concerned about?
          10         A    At that particular moment when I was there, I -- I
          11    kind of thought she was doing better at that time.  But we
          12    did come to some agreement on -- that she would search and I
          13    would search, and if I found something, I would let her know
          14    and vice versa.
          15              And we also did come to the conclusion that it
          16    could not be mainstream psychiatry, that it just would --
          17    there would have to be something outside of what is
          18    considered mainstream.
          19         Q    Okay.  After that, did you have any other
          20    conversations with Mr. Minton?
          21         A    A couple of times, on the phone.
          22         Q    Okay.
          23         A    Never -- that was the only in-person meeting.
          24         Q    What did you talk about with Mr. Minton on the
          25    phone?
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           1         A    Mmm, I had --
           2              MR. WEINBERG:  Your Honor, I just want to pose
           3         an objection, hearsay.  I mean, conversations with
           4         Mr. Minton --
           5              THE COURT:  What did she discuss with
           6         Mr. Minton?
           7              MR. WEINBERG:  Yeah.  What did -- well, what he
           8         asked is what was the -- the discussions with
           9         Mr. Minton.  I mean, it cannot have anything to do
          10         with this hearing.
          11              MR. DANDAR:  Don't be so surprised.  Let me go
          12         down there, and then you can rule after you hear
          13         what she has to say.
          14              MR. WEINBERG:  It is still hearsay.
          15              MR. DANDAR:  He's their witness so --
          16              MR. WEINBERG:  He's somebody that --
          17              THE COURT:  Sit down.
          18    BY MR. DANDAR:
          19         Q    So tell us about the next time --
          20              THE COURT:  I'm going to assume the
          21         relevance -- or the reason why it is admissible to
          22         this hearing is some sort of impeachment or --
          23              MR. WEINBERG:  But this would be hearsay.
          24         And --
          25              THE COURT:  If it is impeachment, then it is
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           1         impeachment.
           2              MR. WEINBERG:  He didn't ask Mr. Minton about
           3         this, about conversations with this woman, because I
           4         never --
           5              THE COURT:  It could be something very
           6         different from what Mr. Minton said in court.  I
           7         don't know, I think we'll just have to hear it
           8         first.
           9              MR. WEINBERG:  All right.  Can I preserve my
          10         objection to --
          11              THE COURT:  You may.
          12              MR. WEINBERG:  -- to hearsay?
          13              THE COURT:  Yes.
          14    BY MR. DANDAR:
          15         Q    What was the first conversation about?
          16         A    Well, like I said, it might have been when I met
          17    them there.  Over that course of that year, as I did find
          18    help for that girl -- alternative forms of therapy that are
          19    very -- it's not that they never use psychiatric drugs, but
          20    they try not to.  They are a holistic approach to
          21    psychiatric problems.
          22              And when I got back to Los Angeles, this girl was
          23    not doing well.  And the day she was going to the railroad
          24    tracks, while she was still talking to her FSO, I had her
          25    come to my house.  And I --
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           1              THE COURT:  I think this has to do with some
           2         conversation with Mr. -- Mr. Minton?
           3              MR. DANDAR:  Right.
           4         A    So then she got better.
           5    BY MR. DANDAR:
           6         Q    The conversation with Mr. Minton --
           7         A    Okay.  So this woman got better.  During this
           8    year, there were some conversations.  I cannot say
           9    specifically that Bob Minton was in on them or it was Stacy,
          10    but that was the phone number that I would call every once
          11    in a while.  And --
          12              MR. WEINBERG:  I'm sorry to interrupt, could we
          13         just date the year she's talking about?
          14              THE WITNESS:  This past year.
          15    BY MR. DANDAR:
          16         Q    2001?
          17              MR. WEINBERG:  2002.
          18              THE WITNESS:  2001 and 2002.
          19              MR. WEINBERG:  Okay.
          20    BY MR. DANDAR:
          21         Q    But it was about this woman?
          22         A    Mainly.  Mainly.  They were in touch with her, I
          23    believe, Stacy.  I know Jesse was in touch with her
          24    repeatedly.
          25         Q    Okay.
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           1         A    She required a lot of hand-holding.
           2         Q    All right.  And she was still a Scientologist.
           3    Correct?
           4         A    Well, it took a while.  I wouldn't call her that
           5    now.
           6         Q    Then?
           7         A    I don't know --
           8         Q    All right.
           9         A    I don't know what time she stopped being one.  I
          10    can't say that.
          11         Q    Let's go to this year.  Did you have a
          12    conversation on the telephone with Bob Minton?
          13         A    Yes, I did.
          14         Q    All right.  Approximately when was it?
          15         A    Mmm, between April 6 and April 13, either
          16    April 6 -- no, no, no, March, February -- March 6 or 12.  In
          17    that week or either of those two days, I can't remember
          18    exactly.
          19         Q    Okay.  Who called whom?
          20         A    I called for Stacy.  But he was there and she was
          21    not.
          22              THE COURT:  Between April 6 and the 12?
          23              THE WITNESS:  Either April 6 or 12.
          24              MR. WEINBERG:  I thought she said March.
          25              MR. DANDAR:  She corrected it to March.
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           1              THE WITNESS:  No -- yes, March.  Not April.
           2         March.
           3              THE COURT:  March?
           4    BY MR. DANDAR:
           5         Q    Okay.  So between March 6 and March 12 of 2002 --
           6              THE COURT:  I think what she's saying, March 6
           7         or March 12.
           8              THE WITNESS:  Or March 12.  I'm pretty sure it
           9         was March 12 but I can't --
          10    BY MR. DANDAR:
          11         Q    Thank you.
          12         A    -- can't say specifically.  But it was not sooner
          13    than the 6th and not really after the 12th.
          14         Q    Okay.  What was the conversation about?
          15         A    Mmm, I was a bit upset because I had put a posting
          16    on the Internet, which I hardly ever do.  And I had --
          17    because this girl was doing better, she was stable -- Mmm --
          18    my story of what had happened to me under an assumed name
          19    was already out on the Internet.
          20              And what I did was I did a posting to the Internet
          21    that updated my story and added that now there is some help
          22    for anyone else who reads the story or family member.  And I
          23    created -- to maintain my anonymity, I created a new screen
          24    address just for that -- any of those kind of
          25    communications.  And I posted that to the Internet.
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           1              And -- Mmm -- then I got some -- I was followed
           2    around L.A. and someone placed PI cards on my car.
           3              And this concerned me.  And -- and after, I really
           4    got paranoid and stayed in the house for four or five days.
           5              Then I decided to call Stacy and see if there was
           6    something about Greg Bashaw or about Laura Bashaw that maybe
           7    I didn't know, that putting this on the Internet created
           8    some sort of repercussion, or was there something going on
           9    with the Lisa case I didn't know.  I mean, you know, in
          10    other words, what does this mean?
          11         Q    Okay.
          12         A    And he said to me --
          13         Q    He meaning?
          14         A    Bob Minton said to me that Ken Dandar had just
          15    been there, the Lisa case is going well, he had just been
          16    there two weeks before --
          17              THE COURT:  Been there?
          18         A    Been to Sandown, New Hampshire, to his place in
          19    Sandown, New Hampshire; that the trial date was set for
          20    early June; and they, meaning the Scientologists, were going
          21    nuts and would stop at nothing to prevent that trial from
          22    happening.
          23              And he said that it was -- that he was in
          24    negotiations with the Church, settlement negotiations, and
          25    that that also was going well, but the sticking point had
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           1    been that no more money was to go to Ken Dandar.
           2    BY MR. DANDAR:
           3         Q    From the Church -- the Church was saying this to
           4    him?
           5         A    The Church was saying this to him, that we could
           6    settle but no more money to Ken.
           7         Q    Any other part of that conversation?
           8         A    And that was a sticking point which made me feel
           9    that at that point this was not something that he was going
          10    to do.
          11         Q    Okay.  Is that the end of the conversation?  Or is
          12    there any more?
          13         A    That was the end of that conversation.
          14         Q    Did you have any more conversations with him?
          15         A    Mmm, one.
          16         Q    When was this?
          17         A    I think one.
          18         Q    When was this?
          19         A    A couple weeks ago.
          20         Q    What was that about?
          21         A    I called him to remind him and Stacy that the
          22    anniversary of Greg's death was coming and Laura would
          23    appreciate a card or phone call, I was sure.
          24         Q    Okay.  And Mr. Minton said?
          25         A    "Thanks."  And, "Do you remember exactly what the
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           1    date was?"
           2              I mean, I didn't get into any of this.  I did not
           3    get into this.
           4         Q    And even at that time had you decided to come here
           5    and be a witness?
           6         A    Absolutely not.
           7              MR. DANDAR:  That is all I have.
           8              THE COURT:  You may inquire.
           9              Frankly, I think for the purpose of this
          10         hearing, that whatever that auditing session was
          11         would not be relevant.
          12              MR. WEINBERG:  Okay.
          13              THE COURT:  So as far as I'm concerned, you
          14         know, you can go forward, unless you just want to,
          15         it is out there, but I don't think it is relevant.
          16              MR. WEINBERG:  Just give me a moment.
          17              THE COURT:  That doesn't mean it wasn't
          18         relevant to you.
          19              THE WITNESS:  I understand.
          20              THE COURT:  It means it has no relevance to
          21         what is going on here and now.  Okay?
          22              THE WITNESS:  Okay.
          23                        CROSS-EXAMINATION
          24    BY MR. WEINBERG:
          25         Q    Now, you just said that you remembered pretty
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           1    clearly that you had had a conversation with Mr. Minton on
           2    March 12, correct?  It could have been March 6 but probably
           3    March 12?
           4         A    Correct.
           5         Q    And what makes it clear in your mind, by the way,
           6    as to the date March 12?
           7         A    It was where I was when I made the call; I was at
           8    a particular place that I don't go very often.
           9         Q    All right.  Now, in that conversation where
          10    Mr. Minton said that what the Church wanted was for him not
          11    to pay any more money to Mr. Dandar, did he tell you that a
          12    few days before he had sent Mr. Dandar $250,000?
          13         A    Nope.
          14         Q    He didn't sound distressed in that phone call, did
          15    he?
          16         A    I wouldn't -- per my definition of distress, no.
          17         Q    He said the case was going really well.  Right?
          18         A    He -- no.  The case was moving.  He didn't say
          19    going really well.  It was moving okay.  It had a trial
          20    date.
          21         Q    Now -- and he didn't tell you that he was going to
          22    cut off Ken Dandar from money, did he?
          23         A    No.
          24         Q    Now, you said that there might be -- I think that
          25    earlier in your testimony you said something to the effect
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           1    that there might be times when -- when -- I think this was
           2    in response to a question Judge Schaeffer posed to you, that
           3    there might be times in your mind when you might have lied
           4    to protect the Church?
           5         A    Uh-huh.
           6         Q    Might have thought about lying to protect the
           7    Church.
           8              Now, you were never in a position --
           9              THE COURT:  Excuse me.  Excuse me.  You have to
          10         say yes or --
          11              THE WITNESS:  Oh, I'm sorry.  Yes.  Was that
          12         yes?
          13    BY MR. WEINBERG:
          14         Q    You never did perjure yourself for the Church of
          15    Scientology, did you?
          16              THE COURT:  If she knows what that word means.
          17              THE WITNESS:  I know what that means.  That
          18         means lying under oath.
          19              THE COURT:  It really means a lot more than
          20         that.  But for this hearing, we'll assume that is
          21         what it means.  Okay.
          22         A    No, because that is the only thing I ever said
          23    under oath.
          24    BY MR. WEINBERG:
          25         Q    Now, you -- this view that you have that there
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           1    might be times you could lie or not tell the truth to
           2    protect the Church is your opinion, right?  That is your
           3    opinion?
           4         A    What do you mean?  That --
           5              THE COURT:  Your opinion, as opposed to
           6         somebody else's opinion?
           7    BY MR. WEINBERG:
           8         Q    Do you understand, you are just expressing your
           9    opinion?
          10         A    Oh, okay.
          11              THE COURT:  In other words, is it part of a
          12         policy letter, or is it just your opinion as to --
          13              THE WITNESS:  I would definitely, as a member
          14         of that group -- felt to protect that group at all
          15         costs, I definitely felt that, and I felt that was
          16         required of other members.
          17    BY MR. WEINBERG:
          18         Q    Well, you can imagine that there -- there may well
          19    be people in the Church of Scientology who might just
          20    utterly disagree --
          21         A    Uh-huh.
          22         Q    -- with the opinion that you just expressed.
          23    Right?
          24              THE COURT:  Is that a yes?
          25         A    I really don't know how to answer that.
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           1              THE COURT:  I thought I heard you say "uh-huh,"
           2         and that is what I'm saying, you can't -- you can't
           3         say uh-huh because --
           4              THE WITNESS:  Okay.  Okay.  Could you repeat
           5         that?  That people would not agree --
           6    BY MR. WEINBERG:
           7         Q    I mean, you can imagine that there are people --
           8    there are thousands of people -- millions of people that are
           9    in Scientology.  Correct?
          10         A    Right.
          11         Q    And you can imagine that some of those -- a number
          12    of those millions of people would -- would bitterly disagree
          13    with your -- with your opinion that it's appropriate to
          14    perjure themselves, lie under oath to protect --
          15         A    I have never said it was appropriate to perjure
          16    yourself or to -- perjury, I think, is different than an
          17    acceptable truth or keeping a PR flap under control or not
          18    letting the public know certain things.
          19         Q    So --
          20         A    I think that is different.
          21         Q    So you are not saying it is a tenet -- you are not
          22    saying any more than it is a tenet of the Catholic Church
          23    that it is a tenet of the Church of Scientology that its
          24    members lie under oath?  You are not suggesting that, are
          25    you?
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           1         A    Absolutely --
           2              MR. DANDAR:  Objection.  My question about this
           3         was referenced only to RTC and OSA.
           4              THE COURT:  Overruled.  But I do think this
           5         needs to be her opinion, just as the other opinion
           6         was hers.
           7              MR. WEINBERG:  That is what it is.
           8    BY MR. WEINBERG:
           9         Q    Right?
          10              THE COURT:  I think what you are saying, you
          11         are making a distinction between lying under oath
          12         and lying otherwise?
          13              THE WITNESS:  Exactly.
          14              THE COURT:  You are not suggesting that there
          15         is -- when he says --
          16              THE WITNESS:  Concerted effort to get people to
          17         lie under oath?  No, I'm not.
          18    BY MR. WEINBERG:
          19         Q    Now, when you were in the Church -- and I can use
          20    the word "squirrel" now because it has been explained --
          21    working with regards to squirrels, you were aware, were you
          22    not, that the Church and people in the Church like you felt
          23    that they had been subjected to a great deal of unwarranted
          24    attacks by these squirrels.  Right?
          25         A    I -- no.  No.  No.  I mean, it wasn't unwarranted
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           1    attacks by these squirrels.
           2         Q    So you thought they were warranted, that it was
           3    okay for the squirrels to steal or alter the technology of
           4    Scientology?  You thought that was appropriate?
           5              THE COURT:  That is a different thing than --
           6         than attack.
           7              THE WITNESS:  Exactly.
           8    BY MR. WEINBERG:
           9         Q    Well, didn't some of these groups slander, say
          10    very negative things, about the Church of Scientology?
          11         A    People can have opinions about everything.
          12         Q    No, I understand that.  I'm just asking you, when
          13    you were in the Church --
          14         A    Right?
          15         Q    -- you were not happy about what squirrels were
          16    doing to your church, were you?
          17         A    It wasn't a matter of squirrels doing to my
          18    church.  It was a matter of what people were doing to
          19    people.  And these people, both sides, weren't being
          20    respectful or treating people decently, and they were both
          21    trying to get away with things.
          22         Q    When you were in the Church, back in the '80s when
          23    you were working with regard to the squirrels, you were
          24    aware that the Church -- people in the Church felt that
          25    these squirrels, when they were put under oath in cases
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           1    involving Scientology, were lying?  That is what people in
           2    the Church believed?
           3              MR. DANDAR:  Objection as to what people in the
           4         Church believed.  Now I think he's trying to make
           5         her an expert witness.  If he wants to go there,
           6         then, of course, we'll redirect her on expert
           7         witness opinions.
           8              THE COURT:  Ask her what she believed.
           9    BY MR. WEINBERG:
          10         Q    That is what you believed, didn't you?  When you
          11    were there, that --
          12              THE COURT:  Let me ex- --
          13         A    I know that some people --
          14              THE COURT:  Wait.  Stop.
          15              THE WITNESS:  I'm sorry.
          16              THE COURT:  Let me explain something to you.  I
          17         get the distinct impression you think somehow or
          18         another he's here to trick you or to somehow or
          19         another -- he's the enemy or something.
          20              THE WITNESS:  Put words in my mouth.
          21              THE COURT:  Put words in your mouth.  Don't
          22         assume that.  If he's out of line, I'll tell you.  A
          23         lot of times, he's just trying to gain information,
          24         just like the other side is.
          25              THE WITNESS:  Okay.
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           1              THE COURT:  In other words, you can answer his
           2         question, "No, I don't think that is right," or,
           3         "Yes I do."
           4              THE WITNESS:  Yes.
           5              THE COURT:  Sometimes the right answer is yes.
           6         Sometimes it may be no.
           7              THE WITNESS:  All right.
           8              THE COURT:  Sometimes an answer can be "I don't
           9         know."  But you must not assume --
          10              THE WITNESS:  That that is the case?
          11              THE COURT:  -- that this guy is here to try to
          12         harm you, hurt you, make you lie or -- or confuse
          13         you.
          14              THE WITNESS:  Okay.
          15              THE COURT:  That is not necessarily true.
          16              THE WITNESS:  Okay.
          17              THE COURT:  I'm here if that happens.
          18              THE WITNESS:  Okay.
          19              MR. WEINBERG:  Thank you.
          20              THE COURT:  Go ahead.
          21         A    So, yes, I do know that, that critics did
          22    sometimes lie.  And I know that for a fact.
          23              THE COURT:  And, obviously, when you were
          24         working undercover, because -- because of a squirrel
          25         group, you must have thought there was something
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           1         going on there you needed to report back because
           2         there was some harm coming to the Church?
           3              THE WITNESS:  Exactly.
           4              THE COURT:  Maybe not an attack --
           5              THE WITNESS:  Exactly.
           6              MR. WEINBERG:  I probably used the wrong word.
           7    BY MR. WEINBERG:
           8         Q    The point is, is that this man, David Mayo and his
           9    group, the Advanced -- what was it called --
          10         A    Abilities --
          11         Q    The Advanced Abilities Center, AAC --
          12         A    Right.
          13         Q    -- were using stolen materials, upper-level
          14    materials of Scientology.  Correct?
          15         A    Which were copyrighted.
          16         Q    Right, which were copyrighted?
          17         A    Uh-huh.
          18         Q    And what you were doing and the Church was doing
          19    was trying to protect itself and protect its copyrighted
          20    materials that had been stolen.  Right?
          21         A    Uh-huh.  Exactly.
          22              THE COURT:  And both of those uh-huhs were yes?
          23              THE WITNESS:  Yes.  I'm sorry.  Yes.
          24              THE COURT:  Okay.
          25
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           1    BY MR. WEINBERG:
           2         Q    Now, you obviously cannot recall exactly what
           3    occurred during those times that you were -- how can I put
           4    it -- out of your mind or --
           5         A    Crazy.
           6         Q    -- crazy.  Is that okay?
           7         A    Uh-huh.
           8         Q    You obviously can't recall with any clarity what
           9    was going on when you were crazy.  Right?
          10         A    Uh-huh.
          11              THE COURT:  That is yes?
          12         A    There are bits of clarity -- I'm sorry, there are
          13    bits of clarity in the midst of --
          14    BY MR. WEINBERG:
          15         Q    A lot of confusion?
          16         A    Exactly.
          17         Q    And that is part of the problem when one has a
          18    psychotic break, whether it is being delusional or
          19    hallucinations, things seem real that aren't real and vice
          20    versa.  Correct?
          21         A    Exactly.
          22         Q    All right.  So when you were describing what
          23    occurred when you were -- I don't really like the word
          24    "crazy" -- but when you were crazy --
          25         A    Disabled.
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           1         Q    -- whatever.  When you were psychotic --
           2         A    Okay.
           3         Q    -- whatever you said today for the most part
           4    you -- it is recounted from, what, conversations with your
           5    husband and other people --
           6         A    No.
           7         Q    -- telling you what occurred?
           8         A    No.
           9         Q    All right.  So --
          10              THE COURT:  Some of her conversations came, she
          11         believes, from phone calls where she called -- you
          12         remember the phone calls?
          13              THE WITNESS:  Exactly.  I do remember those
          14         phone calls.
          15    BY MR. WEINBERG:
          16         Q    Now, during this period of confusion, you saw
          17    aliens or believed that people were aliens and stuff like
          18    that?
          19         A    Just the OSA people.
          20         Q    Okay.  And -- but -- and this period of confusion
          21    lasted -- do you have a sense of how long it lasted?  I
          22    mean, is it months?
          23         A    There is gradient scales.  And what I'm saying is
          24    at the point I stopped with the vitamins is the point it
          25    started to get better.  But there are some areas by June I
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           1    had -- for the most part, I was like okay, I was still very
           2    shaky but I was here.
           3              THE COURT:  How long was the period before
           4         March?  I remember in March you said there was this
           5         period where you stopped taking the drugs or
           6         medicines.
           7              THE WITNESS:  Several weeks.
           8              THE COURT:  What was --
           9              THE WITNESS:  Several weeks worse, several
          10         weeks better.  It went several weeks worse, then
          11         several weeks better.
          12              THE COURT:  So it was at least a couple of
          13         weeks or more where you were in this very confused
          14         psychotic state?
          15              THE WITNESS:  Yes.  Yeah.  Toward that bottom
          16         point that -- that point of their graph.
          17    BY MR. WEINBERG:
          18         Q    And then now, from time to time, you still get
          19    confused at times?
          20         A    No.  I don't get confused.
          21         Q    Well, how does -- you said that --
          22         A    That I still have effects of it?
          23         Q    Yes, that you are not well, I think you said?
          24         A    I didn't say I wasn't well.  I just said that the
          25    effects of it I will have.  I have got to keep myself in
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           1    balance and -- everybody has to take care of their mind.
           2    Whether you know it or not, you can't lose your mind.  And
           3    that is what I really have to do, which is not more or less
           4    than other people.
           5         Q    And the effects of it manifest itself in your --
           6    the effects of it manifest itself from time to time in your
           7    ability to remember things and -- can you give us an idea?
           8         A    It's not my ability to remember things.  It's my
           9    ability to feel here in this universe.
          10              THE COURT:  Feel like emotions?  Feeling
          11         emotions?  Or feel like a physical --
          12              THE WITNESS:  Stability.  Stability and not
          13         like a balloon going to float away.
          14    BY MR. WEINBERG:
          15         Q    So sometimes you might feel like you are losing
          16    that touch with reality, is that what you're saying?
          17         A    Mmm, yeah.  Yeah.  I bump into that every now and
          18    again.
          19         Q    Now, are you being treated by a psychiatrist or a
          20    physician for this condition that you have described?
          21         A    No.
          22         Q    Are you being medicated in some way for this
          23    condition?
          24         A    No.
          25         Q    So you are not receiving any counseling for --
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           1         A    I --
           2         Q    Let me finish my question.  Okay?
           3         A    I'm sorry.
           4         Q    So you are not receiving any counseling or
           5    treatment of any kind to address this continuing --
           6         A    Yes.
           7         Q    -- lack of stability?
           8         A    Yes.  Yes, I am.
           9         Q    What is that?
          10         A    I have different people that I go to for different
          11    kinds of support.
          12         Q    Well, I don't care about the names but --
          13              THE COURT:  Is that this holistic group you
          14         found?
          15              THE WITNESS:  No, because they are not local to
          16         where I live.
          17              I will never go into therapy as people say go
          18         into therapy when you go and you have a therapist.
          19         I do have different therapists I have been to that
          20         if I feel the need, I will go to on a -- on an
          21         as-needed basis, not like on a regular basis.
          22              But I also have spiritual advisors that I have
          23         gone to, as well, for help and therapy.
          24    BY MR. WEINBERG:
          25         Q    Well, without -- well, let's take those one at a
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           1    time.  You will never go into therapy?  Is that because from
           2    your 20 years of being a Scientologist, that you are opposed
           3    to the concept of psychoanalysis or psychiatry?
           4         A    I'm opposed to the concept of traditional
           5    psychiatry, for not having anything to do -- before not
           6    having anything to do with Scientology -- it was a feeling I
           7    had before I became a member, and it is a feeling I continue
           8    to hold.
           9              That does not mean I'm against holistic
          10    psychotherapy or even psychotropic drugs.  I will never go
          11    into a -- into a therapy situation because I feel, myself,
          12    and I feel most people, need to listen to themselves as
          13    their primary guide and not another person.
          14              And if I had done that, I would not have continued
          15    in that environment that I didn't feel was healthy to me
          16    that then ended up me losing my mind.  So I'll never put
          17    myself in that position again.
          18         Q    How many -- now, a Scientologist -- a
          19    Scientologist would be opposed to being treated by a
          20    psychiatrist or being in a mental hospital getting
          21    psychiatric treatment, is that correct?
          22         A    Some might.
          23         Q    Some might?
          24         A    Uh-huh.
          25         Q    That is one of the fundamental precepts of
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           1    Scientology --
           2         A    I wouldn't --
           3         Q    I need to be able to --
           4         A    I'm sorry.
           5         Q    -- finish my question.
           6              One of the fundamental precepts of Scientology, is
           7    it not, is an aversion to psychiatry?
           8         A    I never considered it fundamental.  I did consider
           9    it to be something that -- Mmm -- grew.
          10         Q    What do you mean, something that grew?
          11         A    I want to -- I remember a tape by LRH where he
          12    talked about this, but I don't think we want to go there.
          13              THE COURT:  Basically, all of the testimony
          14         that has been presented in court is the Church of
          15         Scientology does not believe in the traditional
          16         psychiatrists, psychologists, psychotropic drugs,
          17         that type of thing.
          18              THE WITNESS:  That is the official position.
          19              THE COURT:  The official position?
          20              THE WITNESS:  That does not mean all your
          21         members -- like I could be -- I don't think that all
          22         your members -- well, maybe they do.  Maybe they do.
          23    BY MR. WEINBERG:
          24         Q    Well, I mean, the fact is that Scientologists can
          25    choose to believe whatever they want to believe.  Correct?
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           1         A    With restrictions.
           2         Q    Now, how many different spiritual advisors do you
           3    have?
           4         A    With regard to this particular issue, really one.
           5         Q    Well, are there other issues that you have that
           6    you have to go to spiritual advisors for?
           7         A    No.  But I just wanted to clarify that is what we
           8    were talking about.
           9         Q    I thought you told the judge -- and I might have
          10    misunderstood you -- that you saw more than -- you have seen
          11    more than one what you described as a spiritual advisor.
          12         A    Mmm, oh, yeah, there were two.  Okay, two.
          13         Q    And do they have -- can you -- can you tell us
          14    what are they?
          15         A    Nuns.
          16         Q    So this is in a Catholic church?
          17         A    They are in the Catholic church.  They are nuns in
          18    the Catholic church.
          19         Q    You know there are nuns in the Buddhist --
          20         A    These are in a Catholic church.
          21         Q    They are not Scientologists or ex-Scientologists?
          22         A    No.
          23         Q    Have you received any counseling from any people
          24    that were former Scientologists?
          25         A    No.
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           1         Q    Now, and I apologize if I asked you this question
           2    and I assume -- I don't think I did -- but I assume that
           3    from your answer what the answer is, you never did go to a
           4    psychiatrist or got psychiatric treatment, is that right?
           5         A    Psychiatrist or psychiatric treatment?
           6              THE COURT:  He wants to know, to recover --
           7              THE WITNESS:  Yes?
           8              THE COURT:  -- if you ever went to see a
           9         psychiatrist.
          10              THE WITNESS:  No.
          11    BY MR. WEINBERG:
          12         Q    And you were not put in a mental hospital?
          13         A    No.
          14         Q    In fact, on the first day of your break, you were,
          15    I guess, in restraints, taken to, what, the psychiatric wing
          16    of a hospital?
          17         A    They wanted to admit me to the psychiatric wing.
          18         Q    But your husband came down, among others, and made
          19    sure that you didn't go into the psychiatric wing.  Correct?
          20         A    Correct.
          21         Q    And that was your choice as well as his choice
          22    that you not be committed to a psychiatric hospital?
          23         A    No.  No.  At that point, as I said before, at that
          24    point if someone had said, "Here is a pill that will stop
          25    you from seeing things and get you back into the world," I
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           1    don't care, Scientology or whatever, I really don't care, at
           2    that point, when you lose your mind, you just want your mind
           3    back and you can't think the judgment -- you can't punch a
           4    number, let alone think a thought through of God, is this in
           5    my philosophy or not or is this how I feel.  You want to
           6    arrive back on the earth.  Then you might say, "Whoa, get me
           7    out of here," or not, but you'll be back.
           8              THE COURT:  Did you have to sign yourself out?
           9              THE WITNESS:  Yes.
          10              THE COURT:  And did they want to keep you
          11         there?
          12              THE WITNESS:  Yes.
          13              THE COURT:  So you signed out against medical
          14         advice?
          15              THE WITNESS:  Exactly.
          16              THE COURT:  So whatever state you were in, you
          17         signed the paper?
          18              THE WITNESS:  I did sign the paper.
          19              THE COURT:  Whether you were thinking straight
          20         or not --
          21              THE WITNESS:  Exactly.
          22              THE COURT:  -- you signed the paper and said,
          23         "I don't want to stay here"?
          24              THE WITNESS:  Right.
          25
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           1    BY MR. WEINBERG:
           2         Q    And you went home with your husband?
           3         A    Yes.
           4         Q    Now, when you said something like you want to be
           5    back on this earth, when do you believe you arrived back on
           6    the earth?  Was that June of '96?
           7         A    Mmm, it's a cyclical thing, it is not I'm back and
           8    I'm not.  It's a cyclical thing.  I don't --
           9              THE COURT:  You had lucid moments and non-lucid
          10         moments?
          11              THE WITNESS:  Exactly.
          12              THE COURT:  When did you feel like you came
          13         back where you were lucid almost all of the time
          14         except for an occasional bout, maybe?
          15              THE WITNESS:  Maybe after a year.  After a
          16         year.
          17              THE COURT:  And this started when?
          18              THE WITNESS:  January, 1996.
          19              THE COURT:  What is this June date that you
          20         told us about?
          21              THE WITNESS:  That was when I felt the
          22         compartments in my mind come back.
          23              THE COURT:  But you didn't feel you were still
          24         quite back until about six more months?
          25              THE WITNESS:  Correct.
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           1    BY MR. WEINBERG:
           2         Q    Then since then, there is an occasional bump?
           3         A    There -- this past year when I have dealt directly
           4    with people in the state of mind that I was in, you know, a
           5    Scientologist would call it restimulation, or you could call
           6    it a trigger situation where that is brought back.  What
           7    happened to me is brought back to the now, if you can follow
           8    me, talking with people in this state has -- did bring it
           9    back during this year.
          10         Q    And when it got brought back in 2002, then you
          11    wouldn't be lucid for a period of time?
          12         A    Hopefully very briefly.  But, no, it is not -- it
          13    is not about lucidity.  I don't know how to explain it,
          14    but --
          15         Q    Well, you are not right?
          16         A    That is a good way, right.  You are not right.
          17         Q    All right.  Now, you mentioned in the questions
          18    that Mr. Dandar asked you, that there had been a big schism
          19    in the Church, and you said in the early '80s.  Do you
          20    remember that?
          21         A    Uh-huh.
          22              THE COURT:  That is a yes?
          23         A    Oh, I'm sorry.  Yes.  Yes.
          24    BY MR. WEINBERG:
          25         Q    And you said that that -- there was a big power
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           1    struggle between Pat Broeker and David Miscavige.  Right?
           2         A    Pat Broeker was later.
           3         Q    But that is what you said.  So --
           4         A    I don't think I mentioned Pat Broeker.
           5         Q    I'm -- I don't want to argue with you but you did,
           6    so --
           7         A    If I did, it would only be because he was the
           8    interim supposed head for a brief period of time.
           9         Q    In the early '80s?
          10         A    But that would have been at -- LHR died in '86.
          11              THE COURT:  That is the -- when the schism
          12         between Mr. Miscavige and Broeker took place.
          13              THE WITNESS:  Exactly.
          14              THE COURT:  What was the early '80s?
          15              THE WITNESS:  Between David Mayo and people in
          16         RTC and other executives.  There was a whole list of
          17         them that were at that level that left in 1982.
          18              THE COURT:  Okay.
          19    BY MR. WEINBERG:
          20         Q    Now, you subscribed to the beliefs of the Church
          21    of Scientology -- to Scientology for a number of years.
          22    Correct?
          23         A    I did.
          24         Q    You were a committed -- you were a person who was
          25    committed to the religion of Scientology.  Correct?
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           1         A    I was committed to the beliefs of Scientology.
           2         Q    Okay.  And you -- I mean, things like man is a
           3    spiritual being, I mean, that is something that you believed
           4    and --
           5         A    I did before.  I did during.  I do now.
           6         Q    And -- and there are many, many people in the
           7    world, as we sit here today, that continue to be committed
           8    to the beliefs of Scientology as their religion.  Correct?
           9              THE COURT:  I don't think that is a particular
          10         belief that only the Scientologists believe.  Man is
          11         a spiritual being is a belief I hold, myself.
          12              MR. WEINBERG:  And I hold it myself, and I was
          13         raised that way.
          14    BY MR. WEINBERG:
          15         Q    But you would agree, if anything, that is one of
          16    the fundamental principles --
          17         A    That man is a spiritual being, yes.
          18         Q    And that the problems like, for example, problems
          19    that -- that I might describe as mental problems --
          20         A    Correct.
          21         Q    -- are spiritual in nature.  Right?
          22         A    Exactly.  They --
          23              THE COURT:  They can be.  Certainly.
          24              THE WITNESS:  They can be.
          25
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           1    BY MR. WEINBERG:
           2         Q    And, therefore, their belief is that they should
           3    be addressed spiritually, as opposed to going to a
           4    psychiatrist?
           5         A    But there are other alternatives.  I'm just saying
           6    I don't know it's that black and white.
           7              THE COURT:  He's just simply saying the Church
           8         of Scientology belief is that if you have a problem
           9         with the mind, if you address it spiritually as
          10         opposed to, perhaps, somebody that would address it
          11         medically --
          12              THE WITNESS:  Okay.
          13              THE COURT:  -- that is the Church's belief.  Is
          14         that true?  I mean, I don't mean to put words in
          15         your mouth.
          16              THE WITNESS:  Yes.  Possibly.  Yes.
          17    BY MR. WEINBERG:
          18         Q    Now, going back to the squirrels for a moment,
          19    when you were working in cases involving the squirrels, you
          20    certainly did not think that they were being objective, that
          21    is the squirrels, in their views about Scientology, did you?
          22         A    No.  They were as black and white as Scientology
          23    is.
          24              THE COURT:  She made that pretty clear on her
          25         direct testimony.
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           1              MR. WEINBERG:  Okay.
           2              THE COURT:  She said they were both very black
           3         and white.
           4    BY MR. WEINBERG:
           5         Q    Now, when you were in the Church of Scientology,
           6    you never saw anyone be given an order to kill someone in
           7    counseling, did you, auditing?
           8         A    No.
           9         Q    And -- and I think you said, what -- well, strike
          10    that.
          11              Now, when did you first start communicating,
          12    either by phone or in person or over the Internet, with
          13    folks that were expressing opinions anti to the Church of
          14    Scientology?
          15         A    Mmm, end of '94, early '95.  And I -- they were
          16    not -- see, I want to clarify.  Are you considering Kim
          17    Baker to be anti-Scientology?
          18              THE COURT:  The question is what do you
          19         consider Kim Baker?
          20              THE WITNESS:  Well, I don't -- the only person
          21         that I consider to be -- to be anti-Scientology is
          22         Arnie Lerma I was in touch with.
          23              THE COURT:  When did you come in contact with
          24         him?
          25              THE WITNESS:  On the Internet, possibly in
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           1         1995.
           2    BY MR. WEINBERG:
           3         Q    And what -- and you came to learn that -- that --
           4    well, strike that for a second.
           5              Kim Baker was on the board of directors of
           6    FACTNet.  You knew that, didn't you?
           7         A    I don't think, when I talked to her, she was.  If
           8    she was, I didn't know it.
           9         Q    So you know what FACTNet is?
          10         A    Yes.
          11         Q    And what is FACTNet?
          12         A    FACTNet is an organization that Larry Wollersheim
          13    started.  And how I found out about it is I got a call from
          14    Linda Sarkovich at OSA Int who told me Larry was starting
          15    this organization, and that was how I knew about it being on
          16    the Internet, that she wanted me to join it and tell her
          17    what was happening there.
          18              And I told her I didn't know about the Internet.
          19    And then I learned about the Internet.
          20              THE COURT:  This was -- this was an activity
          21         for the Church?
          22              THE WITNESS:  Exactly.  She wanted me to --
          23              THE COURT:  Who is she?
          24              THE WITNESS:  Linda Sarkovich, another OSA Int
          25         person.
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           1    BY MR. WEINBERG:
           2         Q    And you were on the Internet in your own name?
           3         A    Mmm --
           4         Q    You don't have to give a name, you just had some
           5    Internet name.  Right?
           6         A    No, I never -- I hardly ever, ever, ever have
           7    posted on the Internet, ever.  That just wasn't something
           8    that I did.
           9         Q    Well, didn't the people at OSA have the same
          10    ability to go on the Internet that you did?  Why did they
          11    need your help?
          12         A    I don't know.  Private conversations with Larry?
          13    I don't know.
          14         Q    So you had --
          15         A    I told her I was too busy.
          16         Q    So you haven't had any private conversations with
          17    Larry Wollersheim?
          18         A    No.
          19         Q    But you did meet and visit with Arnie Lerma on the
          20    Internet?
          21         A    On the Internet Arnie Lerma and I chatted back and
          22    forth.  But it was more of a personal nature, as opposed to
          23    any kind of anti-Scientology or whatever.  He had been a
          24    very dear friend of mine I lost touch with.
          25         Q    You know that Arnie Lerma was in litigation
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           1    against the Church of Scientology.  Correct?
           2         A    I don't know if -- I don't think that -- when I
           3    started communicating with Arnie, that was not the case.
           4    When -- when January, 1996 happened, that was the case.  And
           5    I did not talk or chat with Arnie, between those times,
           6    until actually two years ago.
           7         Q    Well, you knew that there was a federal injunction
           8    against Arnie Lerma with regard to his violating copyrights,
           9    correct, of the Church of Scientology?
          10         A    No.
          11         Q    So he didn't -- this dear friend of yours didn't
          12    tell you that?
          13         A    I don't even know when that was --
          14         Q    Did he -- were you aware that Mr. --
          15         A    -- that he had -- that he was raided.  I was aware
          16    there was a raid at his home.  And I believe there was an
          17    injunction afterwards or some sort of a court case
          18    afterwards.  Am I correct?
          19         Q    And you were aware that he had become very much a
          20    part of the anti-Scientology movement?  Did you know that?
          21         A    Not when I initially contacted him.
          22         Q    Well, at some point as this relationship
          23    progressed, you became aware that Mr. Lerma was part of the
          24    anti-Scientology movement.  Correct?
          25         A    Mmm, probably when I read in the paper that he was
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           1    raided, which would have been the summer of 1995.
           2         Q    All right.  And how frequently did you communicate
           3    with Mr. Lerma?
           4         A    After that point?
           5         Q    Yes.
           6         A    I don't believe I did at all.
           7         Q    You knew that Mr. Lerma was also on the board of
           8    directors of FACTNet, didn't you?
           9         A    No.
          10              THE COURT:  Are you speaking now about the time
          11         she was communicating with him?
          12              MR. WEINBERG:  Yes.
          13              THE COURT:  At the beginning of this
          14         communication?
          15    BY MR. WEINBERG:
          16         Q    Well, throughout the communication --
          17         A    I don't know that he was on the board of FACTNet.
          18         Q    I guess that is the answer.
          19         A    Before I talked to him.
          20         Q    But you know that while you were communicating
          21    with him, whatever the period of time you have been
          22    communicating with him, that he was at some point on the
          23    board of FACTNet?
          24         A    No.  I believe that that was much later.  I think
          25    that he came on the board of FACTNet after I was
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           1    communicating with him.  I could be wrong.
           2         Q    And did you continue to communicate with Mr. Lerma
           3    after January of 1996, this incident that you described
           4    where you went crazy?
           5         A    No.
           6         Q    So since -- so the last time you have talked with
           7    Mr. Lerma or communicated with him is sometime before
           8    January of '96?
           9         A    January of '96 -- the last time I E-mailed him was
          10    before he got raided.  I do not believe I communicated with
          11    him after the raid happened.
          12              When OSA was interviewing me, they were very,
          13    very, very interested in my relationship with Arnie Lerma.
          14    When I posted my story under an assumed name I did have
          15    Arnie post it for me but he did not know it was me.  But I
          16    figured OSA wouldn't know that.
          17         Q    My question is, is that after that, after you left
          18    the Church of Scientology, did you --
          19         A    Communicate --
          20         Q    -- communicate with Arnie Lerma?
          21         A    I did, two years ago, go to Washington, D.C. and I
          22    did see him.
          23         Q    All right.  And have you stayed in touch with him
          24    since?
          25         A    Maybe periodically.  A card or --
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           1         Q    And --
           2         A    What was what.
           3         Q    What was the purpose of your trip to Washington?
           4         A    Sightseeing.
           5         Q    And did you see anybody else with Mr. Lerma that
           6    had to do with his activities involving the Church of
           7    Scientology?
           8         A    No.
           9         Q    Now, in addition to Mr. Lerma, who else have you
          10    been in communication with since 1996 who would be
          11    considered a critic of Scientology?
          12         A    Mmm, I have -- I don't know what you consider -- I
          13    mean, I do consider Spanky Taylor a critic.  Tory Bezazian
          14    has picketed.  And I --
          15              THE COURT:  Stacy Brooks, Bob Minton, at one
          16         point?
          17              THE WITNESS:  Yes.  I talked to them but --
          18              THE COURT:  Surely you are talking about other
          19         than people she mentioned here already?
          20              MR. WEINBERG:  No -- I am talking about other
          21         people.  Right.
          22              THE COURT:  Is there anybody you have been in
          23         touch with that you have communicated with that you
          24         haven't told us about in the courtroom already?
          25              THE WITNESS:  I don't think so.  I mean, I do
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           1         pretty much freely keep my communications.  So if
           2         there are some communications somewhere to a critic,
           3         there you go.
           4    BY MR. WEINBERG:
           5         Q    How about Frank Oliver?
           6         A    No.  Not until last night.
           7         Q    Well, what happened last night?
           8         A    I met him.
           9         Q    Met him where?
          10         A    Here.
          11              THE COURT:  What difference does it make,
          12         Counsel?
          13              MR. WEINBERG:  Well, your Honor, Mr. Oliver is
          14         on the stand.
          15              THE COURT:  So what?
          16              MR. WEINBERG:  He's an anti-Scientologist.
          17              THE COURT:  I wouldn't keep him off the stand
          18         if they had a conversation.
          19              MR. WEINBERG:  I would just like to know what
          20         the nature of the meeting was.
          21              THE WITNESS:  Social.
          22    BY MR. WEINBERG:
          23         Q    And who was there?
          24         A    Well, everybody.
          25         Q    Well, what do you mean, everybody?  Jesse Prince?
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           1         A    Uh-huh.
           2              THE COURT:  If it was a social meeting -- was
           3         anything discussed about the case?
           4              THE WITNESS:  Not in front of Frank Oliver, no.
           5         I said, "Hi, how are you?"  He started to talk
           6         about, "Do you know this person?  Do you know this
           7         person?"  Do I know that person.  That was -- how do
           8         we know each other.  And that was it.
           9    BY MR. WEINBERG:
          10         Q    And when is the first time you talked to Jesse
          11    Prince?
          12         A    Mmm, about a year -- let's see, a year ago with
          13    regards to the woman.  And I may have met him earlier or
          14    later, I don't remember, but it was when Tory Bezazian came
          15    back to Los Angeles after having come down to Clearwater,
          16    she left the Church, went to Clearwater.  And when she came
          17    back, I picked her up, and Jesse was with her.  I do not
          18    know if that was before or after this past year, with the
          19    girl.
          20         Q    And how did you know Jesse Prince?
          21         A    Mmm, at that point, I didn't until we had lunch
          22    and I discovered he had been the boss of my case officer at
          23    RTC.
          24         Q    So that was the first time you'd met or even heard
          25    of Jesse Prince?
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           1         A    Heard of -- I heard of him when I was a
           2    Scientologist, yes.
           3         Q    That is the first time you met Jesse Prince?
           4         A    Yes.
           5         Q    You have never met David Miscavige, have you?
           6         A    Yes.
           7         Q    What, back in the early '80s?
           8         A    After the David Miscavige court case was the last
           9    time that I met him -- I mean -- I mean after the David Mayo
          10    court case.
          11         Q    It was a social --
          12         A    He shook my hand.
          13         Q    Okay.  Have you had any contact with Grady Ward?
          14         A    Who?
          15         Q    Grady Ward?
          16         A    No.  I think he's on the Internet.
          17         Q    Or Keith Henson?
          18         A    No.
          19         Q    Or Gerry Armstrong?
          20         A    No.
          21         Q    Did you ever visit the Lisa McPherson Trust?
          22         A    No.
          23         Q    Now, when did you first have any communication
          24    with Mr. Dandar?
          25         A    Mmm, that he knew who I really was?  Or just any
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           1    communication?
           2         Q    Any communication?
           3         A    I have it written down.  It is when my story was
           4    revised and it was put on the Internet for the second time.
           5    I updated my story.  But that was not my real name.
           6              And the purpose of that was because I did not want
           7    press or attorneys or whatever.  And I got -- I got a
           8    message, an E-Mail message, from him.
           9         Q    From Mr. Dandar?
          10         A    Uh-huh.
          11         Q    And --
          12              THE COURT:  Is that a yes?
          13         A    I'm sorry.  Yes.
          14    BY MR. WEINBERG:
          15         Q    And when was that, approximately?
          16         A    Several years ago.
          17         Q    Several is more than two?
          18         A    Two.  Say two and a half years.  I don't know
          19    exactly.
          20         Q    All right.  And what did the E-Mail message say?
          21         A    Mmm, would I be interested in being a witness, or
          22    he was interested in me being a witness, or something about
          23    being a witness in this case.
          24         Q    And did you -- did you respond back?
          25         A    I said I would think about it.
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           1         Q    And then when was the next communication?  Or tell
           2    us about the other -- can you just summarize what other
           3    communications or contact that you have had with Ken Dandar
           4    since that first E-Mail?
           5         A    Maybe a couple weeks ago I contacted him; a week
           6    and a half ago.
           7         Q    What?
           8         A    Not that long ago.  And I said, "Are you still
           9    interested in me being a witness?"
          10         Q    And what about when you met Jesse Prince, whatever
          11    it was, several years ago, did Jesse Prince tell you that he
          12    was working for Mr. Dandar?
          13         A    No.
          14         Q    Did the Lisa McPherson case come up when you
          15    talked to Jesse Prince?
          16         A    Well, he worked at the Lisa McPherson Trust.  And
          17    the Lisa McPherson -- I wouldn't say specifically the Lisa
          18    McPherson case, but what happened to Lisa McPherson most
          19    definitely would have come up, especially over the past
          20    year.
          21         Q    And, of course, Bob Minton and Stacy Brooks knew
          22    who you were.  Correct?
          23         A    They knew who I was.
          24         Q    All right.  And --
          25         A    They are mutual friends between me and a lot of
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           1    people.
           2         Q    When did Mr. Dandar learn who you were?
           3         A    Who I really was?
           4         Q    Yes.
           5         A    This past Sunday.
           6         Q    Well --
           7         A    Or Monday.
           8         Q    Well, were you not aware that Mr. Prince was his
           9    consultant?
          10         A    Mmm --
          11              THE COURT:  What difference does it make?  The
          12         question is -- the question --
          13         A    People that --
          14              THE COURT:  -- is when did you agree to
          15         testify?
          16              THE WITNESS:  I think Monday or Tuesday.
          17    BY MR. WEINBERG:
          18         Q    Why did you call him?
          19         A    Why did I call who?  Mr. Dandar?
          20         Q    Yes.
          21         A    Or contact him again?
          22         Q    Yes.
          23         A    Mmm, I don't know if I'm right or wrong, but I
          24    think that this is a hearing -- because somebody has
          25    presented that there is going to be a summary judgment,
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           1    which means no trial.  Am I correct?  I hope.  Because that
           2    is why I'm here.
           3              THE COURT:  That is one -- one of the two
           4         things that I'm considering.  Yes.
           5         A    Okay, so forgive me if I get emotional.  I don't
           6    need a break.  I have to get through this.
           7              I needed to decide whether I was going to come
           8    forward or not.
           9    BY MR. WEINBERG:
          10         Q    But you'd already come forward with your story on
          11    the Internet several years ago.
          12              THE COURT:  There is quite a difference,
          13         Counselor, between putting a story on the Internet
          14         and coming into court and testifying and being
          15         cross-examined and the whole business.
          16              MR. WEINBERG:  I'm not arguing with her.
          17    BY MR. WEINBERG:
          18         Q    Had you been following the hearing on the
          19    Internet?
          20         A    Just bits and pieces that have come out.
          21         Q    The transcript is on the Internet.
          22         A    Uh-huh.
          23         Q    You need to answer that yes or no.
          24         A    I'm sorry.  Yes.  Yes.
          25         Q    So you have been reading the transcript?
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           1         A    I read Bill Frank's -- parts of Bill Frank's,
           2    because I knew him.
           3         Q    What other testimony did you read?
           4         A    Mmm, I read, Mmm, occasionally someone would post
           5    little parts of testimony.
           6         Q    Like Mr. Minton's testimony?
           7         A    Some of his.  Some of both sides.
           8         Q    Ms. Brooks'?
           9         A    Yeah.
          10         Q    Mr. Dandar's testimony?
          11         A    No.  Mmm, and I don't know about Stacy Brooks.  I
          12    don't know if I read any of that exact testimony.
          13         Q    Now, did you send a letter -- changing subjects
          14    now.
          15              Did you send a letter to the private doctor, Megan
          16    Shields, complaining about her prescription and advice to
          17    you?
          18         A    No.
          19         Q    Why not?
          20         A    Why?  Why?  I never would have gone to Megan
          21    Shields.  She was not my doctor.
          22         Q    Well, no one forced you to go to Megan Shields,
          23    did they?
          24         A    Yeah.  I mean, it wasn't like they picked up my
          25    arms and had me go.  But it was clearly that is where I had
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           1    to go.
           2         Q    Now, you realize -- I just want to make this
           3    clear -- that we sort of had this discussion while you were
           4    on the stand, but you realize that I am not privy to your PC
           5    folders and that -- I mean, you understand that, don't you?
           6         A    I wish I did.
           7         Q    So let me ask you this as a layperson, because I'm
           8    not a Scientologist, I'm not -- I haven't become proficient
           9    as to all of the scriptures of Scientology.
          10         A    Okay.
          11         Q    When -- as a layperson, when the Church -- when
          12    you are a member, whether public or staff, of Scientology
          13    seeking counseling, and at the same time you have been
          14    communicating with or associating with anti -- people that
          15    are adverse to Scientology, you know, someone like an Arnie
          16    Lerma, you are not eligible under the -- under the code of
          17    ethics of Scientology to get counseling, are you?
          18         A    That is not necessarily -- Mmm -- no, it would
          19    have to be addressed.  That issue would have to be
          20    addressed.
          21         Q    Right.  And part of the conflict that you had in
          22    your mind leading up to 1996 was that you were having these
          23    communications with people like Arnie Lerma and Kim Baker
          24    that -- that --
          25         A    No.  That wasn't -- the confusion wasn't Arnie
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           1    Lerma or Kim Baker.
           2         Q    I didn't finish my question.
           3         A    Oh.  Sorry.
           4         Q    Let me try it again.
           5         A    Okay.
           6         Q    Did it create any conflict in your mind that you
           7    were having a communications cycle with Arnie Lerma as to
           8    whether or not, as a result of that, you were eligible to
           9    receive auditing and counseling from the Church of
          10    Scientology pursuant to the Church's code of ethics?
          11         A    No -- was that a concern of mine?
          12         Q    Yes.
          13         A    No.
          14         Q    Now, you have mentioned --
          15              THE COURT:  Was this ever communicated to you
          16         by the Church in any fashion that you weren't going
          17         to get any auditing because you had seen or talked
          18         to Arnie Lerma?
          19              THE WITNESS:  No.  Not Arnie Lerma
          20         specifically.  If a person is on a list -- there is
          21         a list of people that you can get into trouble if
          22         you communicate to them.
          23              THE COURT:  When you were -- when you were in
          24         your psychotic state and were calling and asking for
          25         help, were you ever told, "We're not going to give
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           1         you any because you talked to Arnie Lerma," or, "You
           2         talked to Kim Baker," or anything of the sort?
           3              THE WITNESS:  No.
           4    BY MR. WEINBERG:
           5         Q    Now, when you were -- when you had your psychotic
           6    break, you went to the hospital.  And before you were
           7    released, you got some sort of an examination from a doctor
           8    at the hospital?
           9         A    Correct.
          10         Q    And the Judge already asked you, against their
          11    medical advice you checked yourself out.  Right?
          12         A    Correct.
          13         Q    And you didn't have any kind of -- the doctor for
          14    the medical examination didn't indicate that you had any
          15    kind of disease or virus or illness.  Right?
          16         A    My blood levels were out of whack.  And he -- he
          17    thought that I had had a seizure.
          18         Q    You mean like an epileptic seizure?
          19         A    I guess.  "Seizure" was his word.
          20         Q    And did you go and did your husband then take you
          21    to a doctor to check on the blood and all that?
          22         A    Mmm --
          23         Q    To your private doctor?
          24         A    Later I did.  I did, because I had to -- the
          25    hospital reported me as a possible seizure, which means you
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           1    get a notice on your -- I didn't know this -- but on your
           2    driver's license.  You then need clearance to drive that you
           3    don't have epilepsy.
           4         Q    And did it turn out you had it, or not?
           5         A    I didn't have it.
           6         Q    I'm sorry, I couldn't hear you.
           7         A    I did not have epilepsy.
           8              THE COURT:  When you went to the doctor who had
           9         been a member of the Church of Scientology, did she
          10         check you out for these things?
          11              THE WITNESS:  Mmm, no.  The Scientology doctor?
          12              THE COURT:  Right.
          13              THE WITNESS:  No.  Not for those things.
          14    BY MR. WEINBERG:
          15         Q    Well, you had an examination of sorts.  Right?
          16         A    An examination of sorts.
          17         Q    And what did she do?
          18         A    Mmm, at that point, I have to tell you that I was
          19    petrified of her.
          20         Q    But that wasn't my question.  What I asked you is
          21    what did she do?  Did she check your blood pressure and look
          22    in your eyes and your ears and your throat and do what
          23    happens when one goes to the doctor for a general check-up?
          24         A    Some of those things, yes.
          25              THE COURT:  Did she take blood work-ups, put a
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           1         needle in your arm, take blood out?
           2              THE WITNESS:  I do not think so.
           3              THE COURT:  But you were in a state you might
           4         not be sure?
           5              THE WITNESS:  Exactly.
           6              THE COURT:  All right.
           7    BY MR. WEINBERG:
           8         Q    And then she gave you -- I mean, by the way, I
           9    think this was clear on direct but I just want to make sure
          10    it is clear, she was not a staff member of the Church of
          11    Scientology?
          12         A    No, she was not.
          13         Q    She's a private doctor?
          14         A    Private doctor.
          15         Q    Okay.  All right.  And bottom line was she told
          16    you to get to -- to try to rest and take vitamins.  Right?
          17         A    Basically.
          18         Q    All right.  And then you were taking, you said,
          19    handfuls of --
          20         A    The doses I was taking were directed more by an
          21    OSA Int person, "How many vitamin B1 did you take?  Take
          22    more.  How many Cal Mag did you have?  Take more."
          23              THE COURT:  The doctor gave you chloral
          24         nitrate?
          25              THE WITNESS:  Chloral hydrate.
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           1              THE COURT:  You said the doctor gave you
           2         something else?
           3              THE WITNESS:  Valerian root.
           4    BY MR. WEINBERG:
           5         Q    And the other thing the Judge takes?
           6         A    No, melatonin didn't come from her.
           7         Q    Who did that come from?
           8         A    I heard of it and mentioned it to someone from OSA
           9    Int.  They said yes, that is a really good idea.
          10         Q    You mentioned a number of times now Greg -- is his
          11    name Bashaw?
          12         A    Bashaw.
          13         Q    B-A-S-H-A-W?
          14         A    B-A-S-H-A-W.
          15         Q    And you are aware that before he committed
          16    suicide, he was in touch with the Lisa McPherson Trust.
          17    Correct?
          18         A    I don't know for sure if he was.  I know his
          19    father was.  I know he was in touch with different people.
          20         Q    And -- and you know that just before he committed
          21    suicide, a few days before, he was with Jesse Prince.
          22    Correct?
          23         A    I do not know that.
          24         Q    Do you know that when he did commit suicide, he
          25    was in a mental hospital?  Do you know that?
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           1         A    He was not in a mental hospital when he committed
           2    suicide.
           3         Q    Was he in a hospital?
           4         A    No.  He was not.
           5         Q    Had he been in a hospital -- in a mental hospital?
           6         A    Yes.  He had been in a mental hospital.
           7         Q    And his family had put him into a mental hospital?
           8         A    The police put him in the mental hospital.
           9         Q    Is it your belief that for -- your own personal
          10    belief, that traditional psychiatry is destructive?  Is that
          11    your personal belief?
          12         A    My personal belief?
          13         Q    Yes.
          14         A    My personal belief, it can be destructive, yes.
          15    It does need reform.  That is my personal belief.
          16         Q    Now, the Church of Scientology has not, did not,
          17    sue you, correct?
          18         A    Did they sue me?
          19         Q    Yes.
          20         A    No.  For what?
          21         Q    And you haven't sued them?
          22         A    No.
          23              THE COURT:  For what?  What are we talking
          24         about here?
          25              MR. WEINBERG:  Well, I don't know.  I am just
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           1         asking her.
           2    BY MR. WEINBERG:
           3         Q    Nobody has sued either side.  Correct?
           4         A    No.
           5              THE COURT:  Correct, yes?  I think the answer
           6         is yes.
           7              THE WITNESS:  Yes.  You are right.
           8              THE COURT:  Okay.  We get confusion.  Sometimes
           9         lawyers add that magic word "correct" on the end of
          10         it.
          11              MR. DANDAR:  I'm glad I don't do that.
          12    BY MR. WEINBERG:
          13         Q    How did you know to contact -- I mean -- strike
          14    that.
          15              Did you find out about Bob Minton from being on
          16    the Internet?  Is that how you found out about him?
          17         A    Possibly mutual friends.
          18         Q    Now, this alternative therapy that this other girl
          19    you were talking about was -- was that in a Buddhist
          20    religious retreat, is that what that was?
          21         A    No, it was not.
          22         Q    Some sort of other -- what kind of retreat,
          23    generally?
          24         A    It wasn't a retreat.
          25         Q    Well --
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           1         A    It was -- there is a group of -- actually, it was
           2    started -- the one she went to -- and there are more and --
           3    there are more resources.
           4              The one she went to was actually started by a
           5    psychiatrist.  He's written a book.  His name is Podvall,
           6    P-O-D-V-A-L-L.  And it is about handling a psychotic person
           7    in the home; compassionate handling of a psychotic person.
           8              THE COURT:  Written by a psychiatrist who
           9         recommended --
          10              THE WITNESS:  He's a psychiatrist himself, yes.
          11              THE COURT:  Who recommends an alternative?
          12              THE WITNESS:  He found that mental institutions
          13         could actually create more damage.
          14    BY MR. WEINBERG:
          15         Q    So it's -- how would you describe it then?  It's
          16    an alternative approach, I guess?
          17         A    It's an alternative approach.  And -- yes.  Do you
          18    want me to tell you what it is?
          19              THE COURT:  No.  Honestly.
          20              MR. WEINBERG:  No.
          21    BY MR. WEINBERG:
          22         Q    And you would agree that there are many different
          23    approaches to dealing with mental problems, including
          24    through one's religion, through, apparently, traditional
          25    psychiatry and other alternatives.  Right?  There are a
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           1    variety of ways people in this world deal with mental
           2    problems?
           3              THE COURT:  That is so obvious you don't even
           4         need to ask this witness that.
           5              MR. WEINBERG:  All right.
           6              Could I have a moment?
           7              THE COURT:  You may.
           8    BY MR. WEINBERG:
           9         Q    Going back to Mr. Minton for a moment, this
          10    conversation that you date on March 12 --
          11         A    Most likely.
          12         Q    Most likely on March 12 of this year.  At the time
          13    that you talked to Mr. Minton, had he already testified in
          14    court in front of one of the judges?
          15         A    On March -- I have no idea.
          16         Q    No?  But when you talked to him, had he told you
          17    that he had already testified?
          18         A    No.  He didn't say one way or the other.  It
          19    didn't even come up.
          20         Q    Okay.  So he didn't tell you that he --
          21              THE COURT:  Counselor, he didn't tell her one
          22         way or another, so he didn't tell her anything about
          23         testifying.
          24              MR. WEINBERG:  All right.  Those are all my
          25         questions.
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           1              THE COURT:  All right.  Redirect.
           2                       REDIRECT EXAMINATION
           3    BY MR. DANDAR:
           4         Q    Mr. Weinberg asked you about Greg Bashaw being
           5    taken to a mental hospital by the police.  Isn't it true
           6    that he got out of that mental hospital and --
           7              THE COURT:  You really should never ask your
           8         witness a question that starts with "isn't it true
           9         that."  That is a classic leading question.
          10    BY MR. DANDAR:
          11         Q    Are you aware Mr. Bashaw was subsequently visited
          12    by OSA?
          13              MR. WEINBERG:  Your Honor, that is also a
          14         leading question.
          15              THE COURT:  Well, I guess "are you aware," she
          16         can say yes or no.  But "isn't it true," that is a
          17         clear one-answer type question.
          18              MR. WEINBERG:  For whatever it is worth, what
          19         people taught me at one point was that if I asked
          20         the question are you aware that something, that is
          21         leading; if you were to say do you know whether or
          22         not something --
          23              THE COURT:  That is a much better question.
          24              MR. WEINBERG:  All right, so --
          25
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           1    BY MR. DANDAR:
           2         Q    Was Mr. Bashaw ever visited by OSA?
           3              MR. WEINBERG:  -- I object as to the basis -- I
           4         mean, if she had a conversation with Mr. Bashaw, if
           5         she had a conversation with somebody else I would
           6         object she wouldn't be competent to give that
           7         testimony, it would be hearsay.
           8              THE COURT:  I guess the same might be true of
           9         yours where she was asked whether or not he went to
          10         a mental hospital.  Unless she asked who?  The
          11         mental director?
          12              MR. WEINBERG:  I didn't hear an objection.  And
          13         I am objecting to this.
          14              MR. DANDAR:  I think you opened the door.
          15              THE COURT:  I'm going to allow it.
          16              THE WITNESS:  Could you repeat the question?
          17    BY MR. DANDAR:
          18         Q    Was Mr. Bashaw visited by OSA?
          19              THE COURT:  If you know.
          20              MR. WEINBERG:  What period of time?
          21    BY MR. DANDAR:
          22         Q    Before he died?
          23         A    Mr. Bashaw and I did discuss OSA, because he had
          24    also done work for OSA at a different time in his life.  And
          25    we did discuss that --
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           1              MR. WEINBERG:  Well, objection, your Honor.
           2              THE COURT:  Sustained.  I think what -- are you
           3         asking like right immediately before he died?
           4              MR. DANDAR:  Right.
           5    BY MR. DANDAR:
           6         Q    Immediately before he died, committed suicide, was
           7    he visited by OSA?
           8              THE COURT:  If you know.
           9         A    I do not know.
          10              MR. DANDAR:  That takes care of that.
          11    BY MR. DANDAR:
          12         Q    Now, you said on cross that if you had -- if you
          13    contacted a person on this list of suppressive people, you
          14    would be in trouble?
          15         A    Correct.
          16         Q    What kind of trouble?
          17         A    Ethics trouble.
          18         Q    What does that mean?
          19         A    Mmm --
          20              THE COURT:  Surely you have learned enough from
          21         this hearing to know the answer.  I know the answer
          22         and I'm not a Scientologist.  I would think you do.
          23         Don't you know the answer to this?
          24              MR. DANDAR:  Well, this is from --
          25              THE COURT:  You want to see if she knows?
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           1              MR. DANDAR:  I want to see if she knows because
           2         I anticipate -- well, I don't want to say.
           3    BY MR. DANDAR:
           4         Q    But is ethics something that is a good experience,
           5    or a bad experience?
           6              MR. WEINBERG:  Objection, your Honor.
           7              THE COURT:  I'm going to allow her to answer
           8         what she thinks.
           9    BY MR. DANDAR:
          10         Q    All right.
          11         A    I have had both.
          12         Q    Okay.  Now, when you went to the hospital, you
          13    said that you were told your blood levels were out of whack?
          14         A    Yeah.
          15         Q    What do you mean by that?
          16         A    Whatever that blood work test that they do.
          17         Q    Okay.  That is as much as you know?
          18         A    Correct.
          19         Q    All right.  Did you ever find out why the Church
          20    of Scientology did not offer you any type of program like
          21    introspection rundown after you told them that you were
          22    crazy?
          23              MR. WEINBERG:  Objection, your Honor.  It is
          24         beyond the scope.  I didn't ask her about that.
          25              Plus he already -- objection.  Beyond the
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           1         scope.
           2              MR. DANDAR:  I think he asked about her
           3         psychotic state and what was going on in the --
           4              THE COURT:  I'll allow it.
           5              MR. WEINBERG:  Then I object to the basis, you
           6         know, that it would be hearsay.
           7              THE COURT:  If you found out, before you tell
           8         us what you found out, tell us who you found it out
           9         from.
          10    BY MR. DANDAR:
          11         Q    Did you ever find out why you weren't offered any
          12    type of program like the introspection rundown?
          13         A    No.
          14         Q    Okay.
          15              THE COURT:  That is a lot of to do about
          16         nothing.
          17    BY MR. DANDAR:
          18         Q    Would you have made it through this psychotic
          19    state if it weren't for your husband?
          20         A    No, I would not.
          21              THE COURT:  Well, that calls for -- that is a
          22         weird question to ask.  How would she know?  The
          23         truth of the matter is even a doctor might not know
          24         the answer to that.
          25              Obviously your husband was very helpful to you
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           1         getting through this?
           2              THE WITNESS:  Very helpful.
           3              THE COURT:  As far as you are concerned, he's
           4         the one that helped you through this?
           5              THE WITNESS:  Right.
           6              THE COURT:  Plus some strong will of your own,
           7         I'm sure.
           8              THE WITNESS:  Yes.
           9    BY MR. DANDAR:
          10         Q    After you declined the request by OSA Int to be a
          11    spy against Mr. Wollersheim and FACTNet, were you asked to
          12    be a spy for anyone else?
          13         A    Mmm, after FACTNet?  I was asked -- that was at
          14    the time that alt.religion.scientology was just starting.
          15    And there were Scientologists that were taking assumed names
          16    and going on there and, you know, pretending -- you know,
          17    you can be, on the Internet, whoever you want to be.  Get a
          18    fake name and you can do whatever you want, whatever.
          19              Their intention was to stir things up or make a
          20    ruckus, basically, and find out information or whatever.
          21              And I did, in fact, join that newsgroup for my own
          22    purposes.
          23         Q    Were the people who were pretending -- who were
          24    really Scientologists and not telling anybody about that on
          25    ARS, alt.religion.scientology?  Were they talking for, or
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           1    against, Scientology?
           2         A    Either way.  Depending upon whatever would suit
           3    their purposes.
           4              MR. DANDAR:  That is all I have.
           5              THE COURT:  Anything further?
           6              MR. WEINBERG:  No.
           7              THE COURT:  Thank you, ma'am, for coming.  You
           8         may step down.  You may be excused.  If you have a
           9         plane to catch, you are excused and you may leave.
          10              THE WITNESS:  Thank you.
          11              THE COURT:  You may call your next witness or
          12         you may bring back --
          13              MR. LIROT:  Mr. Oliver, please.
          14              THE COURT:  Mr. Oliver.
          15              Did the little break last night cut our time
          16         down maybe?
          17              MR. LIROT:  Yes.
          18              THE COURT:  Everybody seems to have appreciated
          19         the break, even the men downstairs said how happy
          20         everybody was that they got to leave a little early.
          21              Is it time for a break?  When did we start up?
          22              MR. DANDAR:  One o'clock.
          23              THE COURT:  Let's break now.  It is about an
          24         hour and a half.  We'll be in recess for fifteen
          25         minutes.  I never get back until twenty so let's say
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           1         quarter to three.
           2        (WHEREUPON, a recess was taken from 2:25 to 2:45.)
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                              Pinellas (727)821-3320 Hillsborough (813)224-9500
                            Tampa Airport Marriott Deposition Suite (813)224-9500
                                                                        216
           1                      REPORTER'S CERTIFICATE
           2
           3    STATE OF FLORIDA         )
           4    COUNTY OF PINELLAS       )
           5              I, LYNNE J. IDE, Registered Merit Reporter,
                certify that I was authorized to and did stenographically
           6    report the proceedings herein, and that the transcript is
                a true and complete record of my stenographic notes.
           7
                          I further certify that I am not a relative,
           8    employee, attorney or counsel of any of the parties, nor
                am I a relative or employee of any of the parties'
           9    attorney or counsel connected with the action, nor am I
                financially interested in the action.
          10
          11              DATED this 12th day of July, 2002.
          12
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          14                              ______________________________
                                              LYNNE J. IDE, RMR
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                            Kanabay Court Reporters; Serving West Central Florida
                              Pinellas (727)821-3320 Hillsborough (813)224-9500
                            Tampa Airport Marriott Deposition Suite (813)224-9500






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