1 IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR HILLSBOROUGH COUNTY 2 CIVIL DIVISION 3 ESTATE OF LISA McPHERSON, by and through the Personal Representative, 4 DELL LIEBREICH, 5 Plaintiff, 6 vs. Case No.: 97?01235 7 CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC.; JANIS 8 JOHNSON; ALAIN KARTUZINSKI; and DAVID HOUGHTON, D.D.S., 9 Defendants. 10 VIDEOTAPED DEPOSITION OF ROBERT VAUGHN YOUNG 11 Volume I 12 C O N F I D E N T I A L 13 14 15 16 17 18 19 20 21 22 23 24 Susan D. Wasilewski, RPR, CRR December 21 & 22, 1999 25 2 1 APPEARANCES Counsel for Plaintiff: 2 MR. KENNAN G. DANDAR Dandar & Dandar, P.A. 3 Attorneys at Law 5340 West Kennedy Boulevard, Suite 201 4 Tampa, Florida 33609 5 Counsel for Defendant Church of Scientology Flag Service Organization: 6 MR. MORRIS WEINBERG, JR. Zuckerman, Spaeder, Taylor & Evans, LLP 7 Attorneys at Law 401 East Jackson Street, Suite 2525 8 Tampa, Florida 33602 9 MR. MICHAEL LEE HERTZBERG Attorney at Law 10 740 Broadway, 5th Floor New York, New York 10003 11 MS. NANCY FAGGIANELLI 12 Carlton, Fields, Ward, Emmanuel, Smith & Cutler, P.A. 13 Attorneys at Law One Harbour Place 14 Tampa, Florida 33601 15 Counsel for Defendant Alain Kartuzinski: MR. DOUGLAS J. TITUS 16 Attorneys at Law George & Titus, P.A. 17 100 South Ashley Drive, Suite 1290 Tampa, Florida 33601 18 Counsel for Defendant Janis Johnson: 19 MR. RONALD P. HANES Trombley & Hanes 20 Attorneys at Law 707 North Franklin Street, 10th Floor 21 Tampa, Florida 33602 22 Also Present: Mr. Michael Garko Ms. Stacy Brooks 23 Mr. Jesse Prince Mr. Michael Rinder 24 Mr. Marty Rathbun Ms. Lara Cartwright 25 Ms. Wendy Beccaccini (via Internet) SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 3 1 I N D E X 2 Volume I 3 December 21, 1999 4 WITNESS PAGE 5 Called by the Defendant Church of Scientology Flag 6 Service Organization: 7 ROBERT VAUGHN YOUNG 8 DIRECT EXAMINATION BY MR. WEINBERG......... 5 9 SIGNATURE PAGE................................. 164 10 CERTIFICATE OF REPORTER OATH................... 165 11 REPORTER'S DEPOSITION CERTIFICATE.............. 166 12 13 14 EXHIBITS 15 (None) 16 17 18 19 20 21 22 23 24 25 SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 4 1 IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR HILLSBOROUGH COUNTY 2 CIVIL DIVISION 3 ESTATE OF LISA McPHERSON, by and through the Personal Representative, 4 DELL LIEBREICH, 5 Plaintiff, 6 vs. Case No.: 97?01235 7 CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC.; JANIS 8 JOHNSON; ALAIN KARTUZINSKI; and DAVID HOUGHTON, D.D.S., 9 Defendants. 10 VIDEOTAPED DEPOSITION OF ROBERT VAUGHN YOUNG 11 Volume I 12 C O N F I D E N T I A L 13 PURSUANT TO NOTICE for the taking of the 14 deposition of ROBERT VAUGHN YOUNG, upon oral 15 examination in the above?styled cause, at the 16 instance of the Defendant Church of Scientology 17 Flag Service Organization, for the purposes of 18 discovery or use at trial or both, pursuant to 19 Florida Rules of Civil Procedure, proceedings 20 therefor were held before Susan D. Wasilewski, 21 Registered Professional Reporter, Certified 22 Realtime Reporter, and Notary Public in and for the 23 State of Florida at large, at the Wyndham 24 Westshore, 4860 West Kennedy Boulevard, Tampa, 25 Florida, on December 21, 1999, at 9:10 a.m. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 5 1 VIDEOTAPING SERVICES were provided by 2 Thomas Hallahan and Rick Spector. 3 THEREUPON, the following proceedings were 4 had and taken: 5 MR. TITUS: For the record, Mr. Polli, 6 who represents Dr. Houghton, who is a 7 defendant in the case, could not be present 8 today because of a scheduling conflict. He's 9 not waiving his right to be present, just 10 could not attend today. 11 ROBERT VAUGHN YOUNG, called as a witness 12 by the Defendant Church of Scientology Flag Service 13 Organization, having been first duly sworn, 14 testified as follows: 15 DIRECT EXAMINATION 16 BY MR. WEINBERG: 17 Q. Mr. Young, my name is Sandy Weinberg. I 18 represent Flag, Church of Scientology Flag Service 19 Organization. I know you've gone through this a 20 number of times in the past. I do understand from 21 Mr. Dandar ?? he's made representations that you 22 are not in good health, and feel free at any time 23 to ask for a break. We'll take periodic breaks to 24 make sure that you are as comfortable as possible. 25 With regard to your health and the reason SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 6 1 we're here today is that Mr. Dandar has made 2 representations with regard to it. Can you 3 describe to us what your health condition is as we 4 sit here today? 5 A. I've been diagnosed with an aggressive and 6 advanced cancer. 7 Q. And what kind of cancer is that, where? 8 A. It started as prostate and it's into bone 9 cancer now. 10 Q. So it's ?? it's in the bones now? 11 A. Yes. 12 Q. And do you have a prognosis with regard to 13 your cancer? 14 A. What do you mean, life expectancy? 15 Q. Well, what ?? is it treatable? 16 A. Well, I was supposed to meet with my 17 oncologist this week, which is why I was trying to 18 get the deposition last week, so I won't meet with 19 my oncologist until next week. 20 Q. So have you had any meetings with your 21 oncologist? 22 A. I've had some meetings and treatments but 23 I would treat that as confidential. 24 Q. Well, but see, there have been 25 representations made that we have to go forward SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 7 1 today with your deposition because of your 2 condition, and so I think I'm entitled to ask some 3 questions about it. Where are you being treated? 4 A. I don't care to discuss that. 5 Q. You don't care to discuss that why? 6 A. I consider that privileged. I'm not going 7 to put that on the record. If you want to, try to 8 argue with the court on that but I consider my 9 medical treatment ?? I'm here, I'm capable of doing 10 this deposition, I'm not on any drugs that are 11 affecting my ability to respond to the questions. 12 Q. Did I ask you that question? No, I 13 didn't. Now, I think I have an opportunity to make 14 a determination as to ?? as to whether you are in 15 that condition. 16 MR. DANDAR: I don't think you do. 17 MR. WEINBERG: Oh, I think I do. 18 MR. DANDAR: I think it's entirely 19 inappropriate and evasive. 20 MR. WEINBERG: No, no, what's being 21 evasive is Mr. Young in not answering my 22 questions. 23 MR. DANDAR: As we did in Jesse Prince, 24 let's reserve the question for the judge to 25 consider. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 8 1 MR. WEINBERG: Not this. I need to be 2 able to inquire as to ?? as to what it is that 3 he's suffering from, how it affects him, 4 whether ?? 5 MR. DANDAR: Why don't you ask him those 6 questions? 7 MR. WEINBERG: Well, he's making 8 speeches. 9 MR. DANDAR: You're asking what doctor, 10 what hospital. 11 MR. WEINBERG: I didn't ask him what 12 doctor. I said where was he being treated. 13 He ?? I mean I ?? is it in Canada, is it in 14 Puerto Rico, is it in Europe, is it in the 15 United States? I mean I asked him where he's 16 being treated. I didn't say who is treating 17 him. I didn't say what hospital is treating 18 him. I didn't get to those questions yet. 19 Then he gave me this privilege thing. And 20 where he's being treated isn't privileged and 21 you know it's not privileged. 22 BY MR. WEINBERG: 23 Q. Now, in addition to the ?? 24 MR. DANDAR: His medical condition is 25 privileged. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 9 1 MR. WEINBERG: Well, I ?? I beg to differ 2 with you. 3 MR. DANDAR: That certainly doesn't go to 4 bias and credibility. 5 MR. WEINBERG: Oh, it may well go to his 6 ability to ?? to function, to testify, to 7 think. 8 MR. DANDAR: Tell him what country you're 9 being treated in. 10 BY MR. WEINBERG: 11 Q. Now, in addition to this aggressive cancer 12 that you've described, what else are you being 13 treated for? 14 A. That's all. 15 Q. Were you recently or in the past year or 16 so hospitalized as a result of a heart condition? 17 A. I had a mild heart attack. 18 Q. When was that? 19 A. In May. 20 Q. May of this year? 21 A. Yes. 22 Q. 1999? 23 A. Yes. 24 Q. Were you hospitalized as a result of that? 25 A. I went to an ER for a couple of days but SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 10 1 I'm not being treated for that now. 2 Q. Do you take any medication as a result of 3 your heart? 4 A. No. 5 Q. Did you ?? did it render you unconscious 6 when you had the heart attack? 7 A. No. 8 Q. In addition to the heart this year and the 9 cancer, have you been treated for anything else? 10 A. No. 11 Q. Now, what medication are you taking with 12 regard to your cancer? 13 A. I'm ?? I don't ?? I don't care to discuss 14 my medication. 15 Q. Well, you know, I'm sorry that you don't 16 care to discuss it but I'm asking you about it. 17 A. I've responded. 18 Q. I haven't heard a ?? I haven't heard an 19 objection, haven't heard an instruction. 20 A. That's my response. 21 Q. That's not a response. 22 A. It's an answer. 23 Q. It's not an answer to my question. What 24 medication are you taking? 25 MR. DANDAR: That's all the answer he's SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 11 1 going to give you. 2 MR. WEINBERG: Are you instructing him 3 not to answer the question? 4 A. I've responded, sir. 5 MR. DANDAR: He's responded and I'm not 6 going to argue with you. 7 MR. WEINBERG: No, no, no. Are you 8 instructing him not to answer the question? 9 MR. DANDAR: Privilege. 10 MR. WEINBERG: What medication he's 11 taking is privileged? 12 MR. DANDAR: Why don't you ask him if 13 he's on any medication now, then you can ask 14 him ?? 15 MR. WEINBERG: No, no, no. Look, I'm 16 going to form the questions the way I want to 17 form them. Don't tell me how to ask the 18 question. 19 MR. DANDAR: Let's get the judge on the 20 phone. I see we're not going to get anywhere 21 today. Is this part of your tactics just to 22 keep asking an objectionable question? 23 MR. WEINBERG: Look, is it your tactic ?? 24 this is an objectionable question to ask him 25 what medication he's on? I don't believe I've SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 12 1 ever been in a courtroom where I was deprived 2 the opportunity to ask a witness whether he 3 was on medication, if he had been taking 4 medication, and what medication that was and 5 whether that medication was impacting on him. 6 Are you telling me that you are instructing 7 this ?? 8 MR. DANDAR: Are you on medication now? 9 MR. WEINBERG: Hey, no, this is my 10 question. 11 MR. DANDAR: Why don't you ask him that 12 question, not what he's been taking. 13 MR. WEINBERG: I'm sorry, I'm sorry, Ken. 14 Don't tell me what questions to ask. I ask 15 the question that I asked. Can you ?? can you 16 repeat the last question that Mr. Young 17 refused to answer? 18 (The question was read by the reporter.) 19 Q. And your answer? 20 A. Well, give me your definition of 21 medication. 22 Q. No, no, I'm asking you what medication 23 you're taking. 24 A. I will then define it for you. 25 Q. Excuse me? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 13 1 A. I will then define medication as I'm using 2 it. 3 Q. Go ahead. 4 A. Anything that's a pain killer or narcotic. 5 Will that suffice? 6 Q. Will what suffice? 7 A. As a definition for medication. 8 Q. Not necessarily, no. That's medication? 9 I mean are you taking chemo, are you taking ?? are 10 you taking some sort of drugs, some sort of 11 antidepressants? Are you taking psychotropic 12 drugs? Are you taking drugs to ?? to relieve your 13 pain if you've an aggressive form of cancer? There 14 are all kinds of drugs that one would take and all 15 of those drugs, either individually or in 16 combination with one another, may well impact on 17 your ability to think, to answer questions, to sit 18 here and listen, to pay attention. 19 A. Good, then I will answer the question you 20 just asked, sir. The answer to that question is 21 no, and that's the end of the issue. 22 Q. So you are taking ?? you have taken no ?? 23 A. You can read back what you just said and 24 you gave me the question. 25 Q. No, no, no. Let's get something very SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 14 1 clear. 2 A. Don't argue with me. 3 Q. Let's get something very clear. 4 A. I'm answering your question. 5 Q. I'm asking the questions and you're 6 answering them. 7 A. I answered the question. You listed four 8 items. You said ?? you gave four items and I just 9 answered no and that's the end of it. 10 MR. WEINBERG: This clearly, Ken, is going 11 to be a very long deposition because all he's 12 doing is making speeches. 13 Q. Now, let's just ?? have you taken any 14 pain medication at all with regard to your cancer? 15 A. As needed. 16 Q. What medication is that? 17 A. I'm not going to discuss my medical 18 condition. You can ask me specifically if I've 19 taken anything that is affecting my deposition. I 20 will respond. 21 Q. And how ?? what ?? I'm just supposed to 22 rely on you as to whether it's affecting your 23 deposition? 24 A. I'm under oath and I'm the witness. Who 25 else is answering the questions? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 15 1 Q. Now, when were you diagnosed with cancer? 2 A. About a month ago. 3 Q. And in the last month, have you taken 4 medication with regard to that cancer? 5 A. Yes. 6 Q. Have you taken pain medication with regard 7 to that cancer? 8 A. Yes. 9 Q. Have you taken any antidepressants with 10 regard to that cancer? 11 A. No. 12 Q. What pain medication have you taken with 13 regard to the cancer? 14 A. Asprin. 15 Q. Do you consider asprin a pain medication? 16 A. No. 17 Q. Okay. What other pain ?? what prescribed 18 medicine have you taken with ?? with regard to the 19 cancer? 20 A. My prescribed medicine I consider to be 21 privileged. 22 Q. When was the last time you took a 23 prescribed drug? 24 A. Couple of weeks ago. 25 Q. Well, Mr. Dandar made the representation SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 16 1 to me that you were in so much pain that you 2 couldn't sit in a normal chair and that we 3 absolutely had to go forward with your deposition 4 today, and your testimony is you haven't taken any 5 pain medication for two weeks? 6 A. Yes. Would you care to have an 7 explanation? 8 Q. No. 9 MR. DANDAR: Only answer the question. 10 THE WITNESS: Okay. 11 Q. Are you in pain today? 12 A. Yes. 13 Q. What pain are you in today? 14 A. There is always pain with cancer, sir. 15 Q. Just ?? it's a simple question. What pain 16 do you have today? Does your head hurt, does your 17 body hurt, what is it that hurts? 18 A. Just in the bones. 19 Q. Now, are you able to sit for long periods 20 of time? 21 A. This ?? this chair is comfortable. It 22 should do pretty well. 23 Q. No, my question was are you able to sit 24 for long periods of time. 25 A. That's the best I can respond, sir. It SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 17 1 depends upon the chair. 2 Q. Now, do you have a prognosis? 3 A. I responded to that earlier. I was 4 supposed to meet with my oncologist and I meet with 5 him next week. 6 Q. Are you going to take chemotherapy? 7 A. I ?? I'm going to meet with my oncologist 8 next week. 9 Q. Are you going to be operated on? 10 A. I'm going to meet with my oncologist next 11 week. 12 Q. When was the last time you met with your 13 oncologist? 14 A. A week ago. 15 Q. Are ?? are you weak? 16 A. Weak is a relative term. I'm not sure 17 what you mean by that. 18 Q. Do you understand what the word weak 19 means? 20 MR. DANDAR: Objection. 21 MR. WEINBERG: What's objectionable about 22 that, Ken? 23 MR. DANDAR: He said it's a relative 24 term. I think he understands what the word 25 weak means. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 18 1 MR. WEINBERG: Well, you know what, Ken, 2 I asked him, it's not exactly a ?? a 3 complicated word. It's a four?letter word, 4 weak. 5 BY MR. WEINBERG: 6 Q. Are you weak? 7 A. I walked here, nobody wheeled me in. I 8 can walk places, I walked to the mall last night. 9 I don't know what you mean by weak. 10 Q. Well, I'm ?? look, we're here today 11 because Mr. Dandar basically said that this was it, 12 that if you didn't testify today there would be no 13 other opportunity for you to testify. 14 A. I'm sorry, sir. Cancer is a mobile 15 condition. It comes and goes. There is days and 16 there is weeks when it's quite serious, there is 17 days and weeks when it can back off. Any cancer 18 patient will tell you that. One does not know day 19 by day, week by week how it's going to affect them. 20 Q. Have you been sick for a long time? 21 A. I told you I was diagnosed a month ago. 22 Q. I understand that but have you been sick 23 for a long time? Have you been feeling ill for a 24 long time? 25 A. I had symptoms that I now recognize were SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 19 1 cancer. 2 Q. That was the pain? 3 A. Yes. 4 Q. How old are you, sir? 5 A. Sixty?one. 6 Q. Where do you live? 7 A. I'm a resident of the state of Washington. 8 Q. Where do you live? 9 A. I've been traveling. I'm not ?? I don't 10 have ?? right now I'm not at my residence. 11 Q. So you live out of a car? 12 A. No, I've been traveling around the United 13 States for about a year and a half. 14 Q. Well, where is the last place that you 15 resided where you actually had an apartment or a 16 home? 17 A. Vashon Islands in Washington. 18 Q. That's where you lived with your ex?wife, 19 Stacy? 20 A. Well, she wasn't my ex?wife. 21 Q. I said that's where you lived with your 22 ex?wife, Stacy, is that right? 23 A. Yes. 24 Q. And that's in the house we'll get to later 25 that Mr. Minton bought for you and Stacy, is that SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 20 1 right? 2 A. No. 3 Q. So you didn't live in the house that 4 Mr. Minton bought for you and Stacy? 5 A. That's correct. 6 Q. Mr. Minton never bought you a house, is 7 that right? 8 A. That's correct. 9 Q. And he never gave you, you or your wife at 10 that time, wife, any money either, is that right? 11 A. That's correct. 12 Q. So you and your wife never received any 13 money in any form from Mr. Minton, is that right? 14 A. I never received any money from 15 Mr. Minton. 16 Q. The question was you and your wife never 17 received any money from Mr. Minton, is that right? 18 A. I ?? as far as I know, she didn't either. 19 Q. Now ?? well, in the last ?? where have you 20 been in the last year and a half? What locations 21 have you been to on your road trip for the last 22 year and a half? 23 A. You want the states? 24 Q. I want the cities, yes. 25 A. Well, when you're driving you go through a SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 21 1 lot of cities, so states might be shorter. 2 Q. Well, I assume that ?? that this isn't 3 like Charles Kuralt, okay, and that there were 4 times that you spent more than a couple of days in 5 a location, like months. Is that right? 6 A. You want me to respond to Charles Kuralt 7 or what part? 8 Q. You didn't understand my question? 9 A. No, I don't. I offered to give you the 10 states. 11 Q. You do know ?? well, I didn't ask you for 12 the states, I asked you for the cities, and I asked 13 you for cities where you actually lived in. Now ?? 14 now, you're telling me that the last place that ?? 15 you're a resident, as you sit here today, of 16 Seattle, Washington, right? 17 A. No, Vashon Island. 18 Q. Outside of Seattle, Washington, right? 19 A. It's in Puget Sound. 20 Q. Outside of Seattle, Washington, right? 21 A. Yes. 22 Q. Okay. Now, when was the last time you 23 were in that location? 24 A. Maybe five months ago or so. 25 Q. Okay. So in the last five months, even SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 22 1 though you were a resident in Vashon Island outside 2 of Seattle in the Puget Sound area, you haven't 3 been there for the last five months, right? 4 A. True. 5 Q. And when you were there five months ago, 6 how long were you there for? 7 A. If it was then, it was, you know, probably 8 a couple of weeks. 9 Q. All right. And then ?? and then before 10 that, when was the last time you were in the 11 Seattle area? 12 A. A few months before that. 13 Q. Okay. Now, where have you been in the 14 last five months? 15 A. Ohio, Kentucky, Iowa, Kansas, Idaho, 16 Wyoming, Oregon, Washington, California, Nevada, 17 New Mexico, Arizona, Colorado. I guess that's the 18 last five months. 19 Q. Okay. Let's just start with ?? with Ohio. 20 You lived somewhere in Ohio? 21 A. Various places. 22 Q. What cities? 23 A. Columbus and Cincinnati. 24 Q. When did you move to Ohio? 25 A. When did I first arrive in Ohio? I've SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 23 1 never moved to Ohio. I was first in Ohio maybe 2 August of like a year and a half ago. 3 Q. What's that, August of what, '98? 4 A. '98. 5 Q. And that was after Stacy kicked you out of 6 the house? 7 MR. DANDAR: Objection. 8 Q. Is that right? 9 A. I wasn't kicked out of the house so I 10 can't respond to your question. 11 Q. You were asked to leave? 12 A. No. 13 Q. She split up with you? 14 A. No. 15 Q. How would you describe it? 16 A. Are we on Ohio or which subject am I on 17 now? 18 Q. We're on you and Stacy. 19 A. Okay. What's your question? 20 Q. How would you describe what happened to 21 cause you to leave Washington to go to Ohio in the 22 summer of 1998? 23 A. I went back to Minnesota first to see 24 Jesse, who wanted to move to Colorado, and we 25 drove, oh, gosh, Minnesota, Illinois, Tennessee. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 24 1 We drove around a lot and that's when I first left 2 Vashon was to go see Jesse. 3 Q. It had nothing to do with the relationship 4 between Stacy and Bob Minton? 5 A. It had nothing to do with me and Stacy. 6 That's the subject we were on. 7 Q. The move from Washington to Ohio, did that 8 have anything to do with the relationship between 9 Stacy and Bob Minton? 10 A. No, it didn't have anything to do with me 11 and Stacy. 12 Q. All right. Now, when you moved to Ohio, 13 did you take up a residence somewhere? 14 A. No. 15 Q. How long ?? well, you moved to Ohio in 16 August of '98? 17 A. No. I said I first went to Ohio. 18 Q. Okay. You ?? you took your body and 19 transported yourself from Washington to Ohio in 20 August of '98, right? 21 A. No. 22 Q. You did that sort of spiritually or what? 23 A. You are the one that keeps injecting those 24 other things. You said I went Washington to Ohio. 25 I did not say that. I said I went to Ohio. You SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 25 1 are presuming I went from Washington. 2 Q. All right. The last place that you said 3 that you were a permanent resident of was Vashon 4 Island, Washington, right? 5 A. Yes. 6 Q. And you were a permanent resident of 7 Vashon Island, Washington as late as the summer of 8 1998, correct? 9 A. I would still consider myself a resident. 10 Q. All right. In the summer of 1998, you 11 moved, you transported yourself, whatever you want 12 to call it, from Washington and you ended up in 13 Ohio, correct? 14 A. Traveled. I don't want to use the word 15 move as in relocating my residence. I transported, 16 traveled, but as far as moved for change of 17 residence, no. 18 Q. Is there some tax reason for this? I mean 19 what is ?? what is so difficult for you to say that 20 I moved? 21 A. Because if you want to make that change of 22 address as far as residence, because that was the 23 point you were asking and hammering on was change 24 of residence. I went to Ohio from San Francisco. 25 I was traveling about and simply flew to Ohio. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 26 1 Q. You ?? you were living out of your car in 2 the summer of ?? 3 A. No. 4 Q. Didn't you tell some people that you were 5 living out of your car in the summer of 1998 as a 6 result of the marital problems you were having with 7 Stacy, yes or no? 8 A. No. No, I just told you I flew to Ohio. 9 I wasn't ?? I didn't even drive. I flew to Ohio 10 from San Francisco. 11 Q. All right. And who paid for that? 12 A. I did. 13 Q. And where did you get the money? 14 A. Savings. 15 Q. Bob Minton didn't have anything to do with 16 that? 17 A. No. 18 Q. Now, you flew to Ohio from where? 19 A. San Francisco. 20 Q. And what were you doing in San Francisco? 21 A. I had dropped off Jesse in Denver, flew to 22 San Francisco to try to hook up with a friend there 23 to just drop in and see him, Ford Greene, I've 24 known him for years. Ford wasn't around so I 25 decided ?? I didn't even ?? I didn't even stay in SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 27 1 San Francisco. I just turned around the next day 2 and flew back and flew to Ohio. 3 Q. Flew back to ?? what do you mean flew 4 back? 5 A. Back east, since I had just come from an 6 easterly direction. 7 Q. And where were all your worldly 8 possessions at that time? 9 A. Cute phrase. My stuff was in Vashon. 10 Q. And where, at the house you're talking 11 about? 12 A. Yes. 13 Q. So you were traveling light? 14 A. Yes. 15 Q. And you went to Columbus, is that where 16 you went? 17 A. Well, the airplane went to Columbus, yes. 18 Q. Well, you stayed in Columbus, didn't you? 19 A. No. 20 Q. Where did you stay? 21 A. See, if you would ask me rather than 22 presume, it goes faster. 23 Q. No, no, no. If you would answer my 24 question rather than argue with me it'll go faster, 25 okay? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 28 1 A. I didn't stay in Columbus, no. 2 Q. Okay. Where did you stay? 3 A. I went down to Well Spring, which is south 4 of Columbus. 5 Q. All right. So ?? so you spent some time 6 in Well Spring. Now, when ?? when was that? 7 A. August '98. 8 Q. How long were you there? 9 A. Two weeks. 10 Q. And who arranged for you to go to Well 11 Spring? 12 A. I did. 13 Q. Who paid for it? 14 A. They did. 15 Q. They who? 16 A. Well Spring. 17 Q. Didn't Bob Minton pay for that? 18 A. No, I ?? Well Spring has scholarships that 19 they provide if the person gets there and that's 20 how I got in. 21 Q. You weren't able to afford it? 22 A. I didn't ask. They just said they had a 23 scholarship and I can do it. 24 Q. Well, were you there when Jesse Prince was 25 at Well Spring? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 29 1 A. No. 2 Q. You know that Mr. Minton paid for Jesse 3 Prince to be at Well String. You know that, don't 4 you? 5 A. No, I don't. 6 Q. Jesse never told you that? 7 A. No. 8 Q. Stacy never told you that? 9 A. No. 10 Q. What did it cost for you to be at Well 11 Spring? 12 A. Nothing. It was a scholarship. 13 Q. And you got some certificate that says I 14 got a scholarship from Well Spring? 15 A. No. It's what they just ?? the language 16 they used for it. I never asked. 17 Q. You got some correspondence? 18 A. No. 19 Q. Some paper at home? 20 A. No. 21 Q. You just sort of showed up one day and 22 said I want a scholarship or what? 23 A. No, I just showed up and started. 24 Q. Were you there for an alcohol problem? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 30 1 Q. You do have an alcohol problem, don't you? 2 A. No. 3 Q. You've never had an alcohol problem? 4 A. I did once. 5 Q. And when was that? 6 A. Oh, '98. 7 Q. Well, this is '98 we're talking about. 8 You went to Well Spring in August of '98, so when 9 in '98 did you have an alcohol problem? 10 A. Oh, probably the summer of '98. 11 Q. Okay. August of '98 is the summer of '98. 12 So was this before or after you went to Well Spring 13 that you had an alcohol problem? 14 A. Well, alcohol problem is ?? again, is a 15 relative term. I didn't like the ?? the fact that 16 I was having to drink a glass or two of wine each 17 day and that was what I considered to be my alcohol 18 problem. 19 Q. Oh, so ?? so you're ?? when you said you 20 had an alcohol problem, it was just because you 21 were drinking a glass or two of wine each day? 22 A. Too much wine each day, yes. 23 Q. You think a glass or two is too much wine 24 each day? 25 A. If you start doing it each day ?? I SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 31 1 realized later it was ?? it was having to be like 2 some people need their martini at five o'clock, you 3 know. That ?? you're on the fringe of an alcohol 4 problem. 5 Q. Wasn't it more like a few bottles a day? 6 A. I never drank a bottle a day. 7 Q. Did you drink more than a bottle a day? 8 A. Never, no. 9 Q. Did ?? well, what did you go to Well 10 Spring for? 11 A. It was just time to get some help, just on 12 my general recovery process. 13 Q. What did you go to Well Spring for? 14 A. I just responded, my general recovery 15 process. 16 Q. Well, was it as a result of the breakup of 17 your marriage? Is that why you went to Well 18 Spring? 19 A. No, Well Spring ?? Well Spring's main 20 publics are either ex?cult members or abused women, 21 and I went there basically to get some professional 22 therapy with regard to my 21 years in Scientology. 23 Q. Okay. So what kind of psychotropic drugs 24 did you take while you were at Well Spring? 25 A. You guys are ridiculous. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 32 1 Q. It's a simple question. What's the 2 answer? 3 A. It's ?? it's an accusive. You say what 4 type? It's like when did you stop beating your 5 wife? You want to ask me if I took ?? why don't we 6 ask if I took any? 7 Q. You know what, Mr. Young, this will go a 8 lot simpler ?? I'll form the questions and ask 9 them, you give the answers. All right? 10 A. Not all questions have answers, sir. Go 11 ahead and ask your question. 12 Q. Well, with you apparently very few 13 questions have answers. I asked the question ?? 14 MR. DANDAR: You're wasting time. 15 MR. WEINBERG: We're wasting time because 16 of him. 17 MR. DANDAR: He's right. Your form was 18 incorrect. 19 MR. WEINBERG: You know what, I didn't 20 hear an objection. I didn't hear an objection 21 from you and this is cross examination so 22 don't tell me my form is incorrect. 23 MR. DANDAR: This is direct examination. 24 MR. WEINBERG: This is a discovery 25 deposition, Mr. Dandar. He's supposedly your SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 33 1 expert. 2 MR. DANDAR: There's nothing supposedly 3 about it. Are you taking a break? 4 MR. WEINBERG: I'm getting a cup of 5 coffee. Is that okay? 6 MR. DANDAR: All right. You should 7 announce it on the record. 8 (Discussion off the record.) 9 Q. Did you take psychotropic drugs at Well 10 Spring? 11 A. No. 12 Q. Did you take any drug, were you prescribed 13 any drugs at Well Spring? 14 A. No. 15 Q. Did you get psychiatric counseling at Well 16 Spring? 17 A. No. 18 Q. Did you meet with psychiatrists at Well 19 Spring? 20 A. No. 21 Q. Did you meet with psychologists at Well 22 Spring? 23 A. Yes. 24 Q. How many times ?? had you been to Well 25 Spring prior to that time? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 34 1 A. No. 2 Q. Stacy went to Well Spring as well? 3 A. Yes. 4 Q. And when was she there? 5 A. I don't remember. It was a month or two 6 earlier. I don't have an exact date. 7 Q. And did Mr. Minton pay for Stacy to go to 8 Well Spring? 9 A. I don't know. 10 Q. Well, did she get a scholarship too? 11 A. I don't know. 12 Q. Well, did y'all pay for it out of your 13 household funds? 14 A. I didn't. 15 Q. What does ?? what does ?? if you were not 16 on this thing that you describe as a scholarship, 17 how much would two weeks at Well Spring cost? 18 A. I actually don't know. 19 Q. Well, is there a particular course of 20 study that one does at Well Spring? 21 A. Do you mind if I give a longer answer than 22 yes or no? 23 Q. First tell me yes or no, if you can. 24 A. No. 25 Q. All right. Then describe to me, okay ?? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 35 1 since you went to Well Spring, Mr. Prince went to 2 Well Spring, your ex?wife went to Well Spring, Well 3 Spring seems to be a place where the expert 4 witnesses in this case end up. Describe to me what 5 goes on at Well Spring. 6 MR. DANDAR: Object to the form. 7 Q. Can you do that? 8 A. I can describe my structure and that's the 9 only way I can really do it. Because when I was 10 there in August '98, I was the only person there at 11 the time, so I don't have anybody else's 12 experience. 13 Q. The only person in the whole ?? is it a 14 campus? 15 A. No, there is just two buildings. One is 16 an administrative building and the other one is 17 like the lodge, which is a two?story, A?frame 18 building with just bedrooms, you know. 19 Q. Where is it? 20 A. It's just south of Athens, Ohio, which is 21 where the Ohio University is. 22 Q. Oh, it's where ?? is it connected with ?? 23 with the University? 24 A. I don't think so. 25 Q. Is it ?? is it ?? do you know how long has SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 36 1 it been around? 2 A. I don't know, I can't answer that 3 question. 4 Q. How did you first hear about it? 5 A. Well, Stacy told me about it, about her 6 own time there and said it was beneficial to her. 7 I had heard the word loosely somewhere before but 8 it ?? never really knew much about it. 9 Q. Had you ?? had you spoken to anyone else 10 that had been there before you went other than 11 Stacy? 12 A. No. 13 Q. Did somebody other than Stacy recommend 14 that you go there? 15 A. No. 16 Q. Did you communicate with someone there 17 before you went there or did you just show up? 18 A. Well, I was in San Francisco and I asked 19 her if she could give a call since she knew how to 20 reach them. I didn't have their phone number, that 21 I'd like to come back, and so she placed the call. 22 Q. So Stacy arranged for it? 23 A. Technically, she made the call if you want 24 to call that the arranging, yes, since I didn't 25 have the phone number. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 37 1 Q. Well, is it ?? do you believe ?? is it 2 Stacy the one that arranged for the ?? for the 3 payment as well or for, you know, for whatever it 4 was that ?? 5 A. No. Because she had told me earlier that 6 there were these scholarships and it would be 7 available for me if I were to take it up and I 8 just ?? 9 Q. Stacy told you that? 10 A. Yes. 11 Q. But ?? 12 A. And I was about to finish my sentence. 13 Q. I'm sorry. Go ahead. 14 A. It had been several months and I just said 15 well, I'm just traveling I'm not in the mood yet, 16 maybe the time will come up. And the time came and 17 I said okay, I'll, you know, sort of take that rain 18 check and do it, give them a call. 19 Q. Well, I'm a little bit confused. You try 20 to be precise, I try to be precise. I thought what 21 you had said a few minutes ago was that Stacy had 22 gone there about a month before you went there, 23 then a minute ago you said there were a couple of 24 months that went by. So which ?? which was it? 25 A. Well, she might have been there two, three SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 38 1 months before, and then since she was only there 2 for I guess the two weeks, that would give me 3 another month or two in between when we might talk 4 about it. As I said, I don't remember exactly when 5 she went. 6 Q. Well, is there some event of which you can 7 date when it was that Stacy went, I mean some case 8 that y'all were working on, some event? 9 A. Not really. All I can say is just the 10 summer. 11 Q. Well, was there a particular event or 12 series of events that, as far as you know, that 13 caused Stacy to recommend that you go there or to 14 suggest that you go there in the summer of 1998? 15 A. Events? No, I think it was just her 16 personal experience and satisfaction with the 17 place. 18 Q. Well, but at that point, if I'm 19 understanding you correctly ?? when I say at that 20 point, in the summer, you know, June, July of 1998, 21 you're not spending a lot of time in Washington, 22 right? 23 A. No, I was in Washington. 24 Q. I thought you were in San Francisco. 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 39 1 Q. I thought you had ?? had described some 2 trip that you were going to take with Jesse Prince, 3 or did take with Jesse Prince across the country. 4 A. I think that was in July when I went back 5 to see Jesse, probably July. Until then I had been 6 in Vashon, and then August was Well Spring. 7 Q. All right. So when was it that Stacy 8 suggested or recommended that you go to Well 9 Spring, before or after the Jesse Prince trip? 10 A. It might have been before and even during 11 because we spoke even while Jesse and I were on the 12 road. 13 Q. But you were away from Stacy for what, a 14 good month, as a result of the Jesse Prince trip 15 flying cross?country and ending up at Well Spring 16 or more than a month, right? 17 A. That's ?? that's approximate, perhaps. 18 Q. Now, was it over the telephone or in 19 person that you discussed or she suggested to you 20 Well Spring? 21 A. I don't ?? I don't remember, probably in 22 person. 23 Q. Did she have material with regard ?? you 24 know, literature with regard to Well Spring? 25 A. No. Let me put it this way. She did not SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 40 1 show me or give me any. 2 Q. Had ?? had you accompanied her when she 3 had gone to Well Spring? 4 A. No. 5 Q. Did she tell you in advance that she was 6 going to Well Spring? 7 A. Yes. 8 Q. And was it at that point that you learned 9 something about Well Spring and what it was and 10 what ?? what it was designed to do? 11 A. A little bit but neither one of us knew 12 personally what it was, so it was just up to her if 13 she wanted to do that, that was okay. 14 Q. Do they advertise or something, do you 15 know? 16 A. I don't know. 17 Q. Do you know how she found out about Well 18 Spring, do you remember what she said? 19 A. No, I don't know how she decided. 20 Q. Was there any discussion as to whether or 21 not y'all could afford it at that point in time? 22 A. No. 23 Q. Before you went there, what, you know, 24 what did she tell you about what was going to 25 happen at Well Spring or what you might think would SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 41 1 happen and how it could help you? I'm talking 2 about before you went there. 3 A. Before I went? 4 Q. Uh?huh. 5 A. She told me that it was ?? she told me 6 about the locale, she told me about the lifestyle, 7 which would be sort of like the schedule. She told 8 me about nearby Athens, and then she told me, you 9 know, basically what happens, which was still our 10 unanswered question from before, which was what 11 sort of the regimen is. And she thought it was 12 highly valuable and I think she was ?? she said she 13 was, you know, pleasantly surprised at how ?? how 14 beneficial she found it to be. 15 Q. When you got there, there was no one else 16 there? 17 A. No one ?? you call them in terms of the 18 client or something. 19 Q. Patient? 20 A. They don't call them patients. We're 21 not ?? we're not, you know, under a doctor's care, 22 but anybody else there as a client. 23 Q. Well, you're a resident when you go there? 24 I mean y'all stay there? 25 A. You ?? you can stay there, there is the SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 42 1 option. Some people, if they choose ?? I had that 2 option. I could stay at a motel in Athens but it's 3 about a nine ?? nine?mile trip in, so it's more 4 convenient to stay there, but you have the option 5 to not stay there. 6 Q. I mean is Well Spring like a ?? like a 7 resort where you can go and work out and eat good 8 food and sort of, you know, relax, or is it 9 something other than that? 10 A. Well, there is great food and there is 11 some workout equipment if you want, bicycle and 12 these ?? 13 Q. Like a gym of some sort? 14 A. Yeah, those bow spring things, you can do 15 that, and lots of great roads that you can walk on 16 or if you have a bike to bike on. A lot of rest, 17 it's pretty quiet. 18 Q. Did you stay on campus or did you stay in 19 the hotel or the motel off campus? 20 A. I stayed on the property. 21 Q. And what are the living quarters like? 22 A. They are ?? there is rooms ?? it's a 23 two?story building that you come in on the middle 24 floor because the land slopes away, so then you 25 have a downstairs ?? from one side it's three and SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 43 1 the other side is two. 2 The downstairs has a bedroom and a large 3 sort of a rec room, and then the third floor has 4 two bedrooms and each room is large enough for a 5 single bed, dressers and the like. 6 Q. So they are private rooms? 7 A. Yes. 8 Q. And how many private ?? I mean how many 9 people are they equipped to handle at any given 10 time? 11 A. Actually, there is two bedrooms 12 downstairs. There would be one, two, three, four, 13 five, six ?? I guess there is eight beds there. 14 Q. And when you were there, you were the only 15 one that was staying there? 16 A. Yes. 17 Q. How big is the staff or was the staff when 18 you were there? 19 A. The staff will vary according to the 20 number of clients, I was told. There is one 21 resident who stays on the property, cooks the food, 22 prepares your dinners, and I suppose if there were 23 eight people there they might have more than one 24 resident. Then there is the administrative staff 25 in the other building. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 44 1 Q. Well, how do they ?? is this a nonprofit 2 organization, a for?profit organization? How do 3 they ?? how do they finance themselves, as far as 4 you know? 5 A. I don't really know. I did learn that 6 it's a ministry and attached to a church, but that 7 came as a surprise to me because I didn't receive 8 any ?? any instruction or direction that it was 9 part of the church, but I don't know how they get 10 their money. 11 Q. Which church is it attached to? 12 A. I don't know. 13 Q. You don't remember which ?? whether it's 14 Baptist or Christian or what? 15 A. It's Christian but I don't know which 16 denomination. 17 Q. The staff themselves, what ?? what is 18 their training, what are they? 19 A. I didn't ask for their training, sir. 20 Q. Well, what are they? Are they ?? are they 21 doctors, are they psychologists, are they ?? are 22 they, you know, nutritionists? I mean what ?? what 23 are they? 24 A. I don't know the particular training, I 25 didn't ask. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 45 1 Q. When you go there, do they do some ?? 2 before you go there, do you have to do some sort of 3 a work?up to be accepted? Do you have to submit an 4 application? 5 A. I didn't, that's all I can respond to. 6 Q. When you got there, did you fill out an 7 application? 8 A. You fill out basic, you know, a basic form 9 as to name, address and ?? 10 Q. I mean do they ?? did they ask you what ?? 11 what it is that ails you? 12 A. Yes, I suppose so. I was asked, you know. 13 Q. Does that end up on some form somewhere? 14 A. No. 15 Q. Are these one?on?one sessions, is that 16 what occurs? 17 A. Mine were. 18 Q. More than one person with you at any given 19 time? 20 A. No. 21 Q. How much of the day is spent in session? 22 A. Again, all my responses have to be 23 regarding me because your question sort of ?? 24 Q. I'm talking about you. 25 A. If I can back up and tell you how the day SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 46 1 is broken up, may I do that? 2 Q. That's fine. 3 A. Because we never answered that. My day 4 was broken up, one was just therapy and the other 5 one was what they call workshop, where you get to 6 see videos, read material that you may feel pertain 7 to whatever it is that you're dealing with. They 8 have a large library and my ?? I took the choice of 9 having my ?? my therapy in the afternoon ?? I'm 10 sorry, in the morning and the workshop in the 11 afternoon. So the therapy is usually about two 12 hours a day, mine were, and the workshop is the 13 same. 14 Q. Okay. 15 A. Then the rest of the day is just free. 16 Q. Okay. So four hours a day you're doing ?? 17 you're addressing the issue which we haven't gotten 18 to yet, but you're addressing whatever the issue 19 is, why you're there? 20 A. I'd say only just the two hours. The 21 other two hours are just basically educating 22 yourself, I was. 23 Q. Okay. Well, therapy, what ?? therapy ?? 24 can you describe for us what do you mean by 25 therapy? I know when I got a bad knee and I'm SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 47 1 rehabilitating it, I know what therapy is. I know 2 if I'm sick and I'm prescribed something, I know 3 what therapy is. But what is ?? when you say two 4 hours a day in therapy, are you talking about on a, 5 you know, on a couch talking to a psychologist? 6 What exactly are you talking about? 7 A. No, we just sat across a table with 8 somebody else and the day was pretty much 9 structured to what I wanted to talk about and go 10 over. I don't have any other comparison other than 11 21 years of Scientology therapy, so I've got no 12 other comparison as to what constitutes therapy. 13 Like I've never stretched out on a couch so I don't 14 know what that means other than movies. So ?? but 15 this was just sitting across the table with 16 somebody and talking about it and just back and 17 forth conversations. And he had a little sort of 18 chalkboard and he might write down something or 19 diagram something or I might do something. It 20 was ?? it was a very freeform sort of discussion 21 where you can just talk. 22 Q. Do you know what deprogramming is? 23 A. I know what Scientology has defined it as. 24 Q. I'm asking you, how would you define 25 deprogramming? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 48 1 A. I would say getting rid of a bad program, 2 as in a computer program. 3 Q. All right. What do you call ?? what do 4 you call people that are out there trying to 5 convince people to get out of organizations that 6 they've described as ?? some people describe as a 7 cult? What do you call that process? Is that 8 deprogramming? And if not, what word would you use 9 to describe that? 10 A. Can you give me that one again? 11 Q. Well, let's ?? you said, I think, when you 12 first talked about Well Spring, that this was a, 13 you know, was an anticult place. 14 A. I never used that word. 15 Q. Didn't you use that word? Didn't you use 16 the word cult when you ?? when you spoke with 17 regard to Well Spring? 18 A. I did not use anticult. 19 Q. You used cult, did you not? 20 A. Yes. 21 Q. And what does cult have to do with Well 22 Spring? 23 A. It happens to be the ?? I said cult 24 members and abused women are the two largest 25 numbers and percentages of people that they deal SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 49 1 with as clients. 2 Q. Okay. 3 A. Excult members. 4 Q. So you got to be an excult member to go 5 there? 6 A. This is pretty much what I gathered. 7 Q. Okay. And how do you demonstrate or 8 document that ?? that you fall into one of these 9 categories? Is there some sort of examination 10 process? 11 A. No. I would consider myself an excult 12 member so that's about the best criteria ?? 13 Q. You just told them that? 14 A. Yes. 15 Q. How many people do you know that have gone 16 through this program at Well Spring? 17 A. Jesse and Stacy is the only two people 18 that I know that have been there other than ?? no, 19 those are the only two, those are the only two. 20 Q. Well, do you know that Stacy and Bob 21 Minton convinced Mr. Minton's wife, Teresa, to go 22 there? Do you know that? 23 A. No. 24 Q. Anybody ever say anything like that to 25 you? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 50 1 A. No. 2 Q. Did ?? did the fact that you had learned 3 that your wife, Stacy, was having an affair with 4 Bob Minton have anything to do with you being at 5 Well Spring? 6 A. No. I ?? see, you're making me ?? 7 Q. I'm just asking you a question, it's 8 simple. If the answer is no, then answer no. 9 A. Your question is loaded with other things. 10 You're having me to admit to one thing to an answer 11 in another thing. 12 MR. DANDAR: I object to the form of the 13 question. 14 A. You know, you're having me say ?? all I 15 say is I went there to Well Spring because I deemed 16 it was time for me to get some professional help 17 that other people had urged on me for a number of 18 years. 19 Q. Didn't you go to Well Spring, at least in 20 part, to get professional help with regard to the 21 breakup of your marriage? Didn't you go there for 22 that purpose? 23 A. No. 24 Q. Had nothing to do with you being at Well 25 Spring? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 51 1 A. I went there because life ?? 2 Q. Just answer that question. It had nothing 3 to do with you being at Well Spring, is that right? 4 A. If you're going to insist upon that form 5 of the question, I'll say no. 6 Q. Okay. Now, did you discuss the anger, the 7 concern, the distress, the depression that you were 8 having in the summer of 1998 as a result of the 9 affair between your wife and Mr. Minton, did you 10 discuss that while you were at Well Spring? 11 A. I think that would be considered 12 doctor/patient confidential. 13 Q. Who was the doctor at Well Spring? 14 A. I had a therapist, I would consider that 15 to be confidential and you can contest that. What 16 I discuss with a therapist, a minister or a doctor, 17 I would consider to be confidential. 18 Q. Well, was there any doctor at Well Spring 19 as far as you know, yes or no? 20 A. I don't know the degrees. I had a 21 therapist, that's all I can respond to. 22 Q. Well, what's this therapist's name? 23 MR. DANDAR: Asked and answered. 24 MR. WEINBERG: Asked and answered? 25 MR. DANDAR: He said he's not going to SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 52 1 divulge any information. 2 MR. WEINBERG: He did not say that. 3 Q. What's the therapist's name? I have a 4 right to determine whether this person is somebody 5 who would qualify for some privilege. What's her 6 name or his name? Is it a man or a woman? 7 A. His name is Ron. 8 Q. And do you know what Ron's training was or 9 is? 10 A. No. 11 Q. Did you ever see any diplomas on the wall? 12 A. No. 13 Q. Do you know how many clients, if that's 14 the right term, that Well Spring has a year? 15 A. No. 16 Q. Or a month? 17 A. No. 18 Q. Did you see anybody else there while ?? 19 while you were there? 20 A. No. 21 Q. Do they go and solicit clients, do you 22 know? 23 A. Not that I know of. 24 Q. Okay. So the therapy has to do with 25 sitting and talking to Ron, basically, is that SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 53 1 right? 2 A. Yes. 3 Q. About whatever you want to talk about? 4 A. It was whatever I wanted to talk about. 5 Q. Okay. So he didn't have some program that 6 he put you through? 7 A. No. 8 Q. I mean did he have you filling out, you 9 know, doing psychological tests and things like 10 that? 11 MR. DANDAR: Privileged, don't answer the 12 question. 13 Q. Did he have you doing that? 14 MR. DANDAR: Privileged, don't answer the 15 question. 16 A. I'm going to follow the advice of 17 counsel. 18 Q. So Mr. Dandar is your lawyer today? 19 MR. DANDAR: Absolutely right. 20 MR. WEINBERG: You represent him 21 personally? 22 MR. DANDAR: I'm representing him for 23 this deposition. 24 MR. WEINBERG: No. I'm just asking the 25 question, do you represent him personally? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 54 1 MR. DANDAR: For this deposition, yes. 2 BY MR. WEINBERG: 3 Q. Now, the afternoon, which is the ?? what 4 do you call that, the ?? 5 A. Workshops. 6 Q. The workshops, what ?? what kind of videos 7 would you watch? 8 MR. DANDAR: Privileged, don't answer the 9 question. 10 MR. WEINBERG: It's not privileged. He's 11 been answering questions about this for the 12 last 15 or 20 minutes. 13 MR. DANDAR: He gave you broad 14 generalizations. You're not going to get any 15 specifics ?? 16 Q. Did you watch videos that have to do with 17 the Church of Scientology? 18 MR. DANDAR: Don't answer the question. 19 A. No. I would like to answer that 20 question. No. 21 Q. Well, what kind of videos? 22 A. Actually, I will respond to the workshop 23 part because I don't consider that as therapy. 24 MR. DANDAR: Okay. It's up to you. 25 A. For example, the first ?? the first video SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 55 1 I saw was a special that was done on ABC TV called 2 The Wave, which was about an experimental program 3 that was done in California by a teacher that 4 created this sort of campus cult that got away from 5 him, and it was based upon a true story and that 6 was one. 7 And ?? I was allowed also on some of my 8 workshops to browse the libraries to just go 9 looking for stuff to see how it would apply. I 10 read stuff on ?? you know, I was finding stuff on 11 anger, just basically browsing to see if there was 12 anything that I felt sort of fit the bill. They 13 allowed me the freedom because ?? possibly because 14 I, you know, college education and I'm familiar 15 with academic books, et cetera. That's ?? that's 16 sort of workshop. It's just basically I have a 17 chance to go through the library and find material 18 and read it as I feel I need it. But no, they 19 never gave me anything regarding Scientology. 20 Q. Was there a regimen as to when you got up 21 and when you went to bed at this place? 22 A. No. 23 Q. And was it a short staff because you were 24 there by yourself? 25 A. Yes. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 56 1 Q. How many people were there while you were 2 there, staff?wise? 3 A. Well, there was the one resident. I don't 4 know how many staff take care of the ?? over the 5 administrative building. 6 Q. Does it have like a ?? is this out in the 7 country or something? 8 A. Yes. 9 Q. How much property do they have? 10 A. I don't know but it seems to be more than 11 a few acres. 12 Q. So when you would eat, you would just be 13 there by yourself, you wouldn't have visitors? 14 A. No, the resident was there. 15 Q. Did you have visitors while you were 16 there? 17 A. No. 18 Q. So Jesse didn't visit you while you were 19 there? 20 A. No. 21 Q. Stacy didn't visit you while you were 22 there? 23 A. No. 24 Q. Did anybody, as far as you know, visit 25 Stacy while she was at Well Spring? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 57 1 A. I don't know. 2 Q. Did you talk ?? 3 MR. WEINBERG: Is there a problem? 4 MR. DANDAR: Do you want to take a break? 5 THE WITNESS: No, that's okay. 6 Q. Now, prior to ?? you left the staff of 7 the Church of Scientology along with your then 8 wife, Stacy, in or about June, July of 1989, is 9 that right? 10 A. No. 11 Q. When did you leave the staff of the Church 12 of Scientology? What date, just the date? 13 A. See, you're presuming in your questions. 14 I have to say ?? you're presuming I left the Church 15 of Scientology staff in '89. I did not. I was not 16 staff of the Church of Scientology when I left. 17 Can I rephrase your question? 18 Q. No. 19 A. Okay, then you don't get an answer. 20 Q. That's fine. It will just take a little 21 longer. You left the Sea Organization in or about 22 June, July of 1989, is that right? 23 A. Yes. 24 Q. As did your then wife, Stacy, is that 25 right? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 58 1 A. Yes. 2 Q. And since you left the Sea Organization in 3 June, July of 1989, you have not taken any 4 religious courses, auditing, or the like in 5 Scientology, have you? 6 A. Well, other than your inserting the word 7 religious, I haven't taken any Scientology courses. 8 Q. All right. You have not ?? since you left 9 the Sea Organization in June, July 1989, you have 10 not practiced Scientology as a public, have you? 11 A. I don't know what you mean by practiced. 12 Q. You don't understand the word practice? 13 A. As you are inserting this, no. 14 Q. Well, explain to me ?? well, there is a 15 difference between a person that is on staff with 16 the Church of Scientology and a person who is not 17 on staff, right? That's a simple question, should 18 be a simple answer, yes, right? 19 A. Well, one is staff and one isn't but I 20 don't know what you mean. 21 Q. There are people in the United States and 22 in the world who are not part of the staff of any 23 of the Churches of Scientology and yet consider 24 themselves Scientologists, right? 25 A. Yes. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 59 1 Q. Those people are described by Churches of 2 Scientology as members of the public, aren't they, 3 or publics? 4 A. Sometimes. 5 Q. And a member of the public is not a member 6 of the Sea Organization, correct? 7 A. No, that's not true. 8 Q. So there are members of the public that 9 are ?? that are actual practicing members of the 10 Sea Org? 11 A. Who have been given Sea Org status, such 12 as Chick Corea. 13 Q. Putting aside Chick Corea, the vast 14 majority of people that are publics who consider 15 themselves Scientologists are not members of the 16 staff of any Church of Scientology and are not 17 members of the Sea Org, is that correct? 18 A. Yes. 19 Q. Now, you've done a lot of writing over the 20 years and at some point during this deposition 21 we'll go through all the various declarations and 22 depositions that you've given, and amongst the 23 things that you describe in those depositions and 24 declarations is RPF, right? 25 A. Yes. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 60 1 Q. And the RPF is the Rehabilitation Project 2 Force, is that what it's called? 3 A. That's what RPF stands for. 4 Q. All right. And that is for members of the 5 Sea Org, is it not, sir? 6 A. Yes, basically. 7 Q. That is not for members of the public, is 8 it, sir? 9 A. No, but ?? 10 Q. Just ?? it's not for members of the 11 public, correct? 12 A. Not intended for, no. 13 Q. Okay. The ?? between the time that you 14 left the Sea Organization and today, you have 15 not ?? you do not and have not held yourself out as 16 a practicing Scientologist, have you, sir? 17 A. I ?? 18 Q. Is that a hard ?? is that a hard question? 19 A. Yes, it is. 20 Q. Okay. What is hard about that question? 21 A. It seems to imply that I made a public 22 statement to someone and represented myself as 23 such, as opposed to did I consider myself to be, 24 when you said held myself out. 25 Q. Well, you mean there is something ?? you SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 61 1 don't consider yourself to be a Scientologist as 2 you sit here today, right? 3 A. Right now today as a practicing 4 Scientologist, no. 5 Q. Okay. And you were not a practicing 6 Scientologist in 1992 or '93 or '94 or '95 or '96 7 or '97 or '98 or this year, is that right? 8 A. No. 9 Q. That's correct, correct? 10 A. That is correct. 11 Q. Now, in the ten years now that it's been 12 since you left the Sea Organization and were no 13 longer a practicing Scientologist, were there other 14 occasions other than this one two?week period in 15 August of '98 where you sought professional therapy 16 with regard to anything? 17 A. Can you ?? can you give me that one again? 18 Q. She'll read it to you. 19 (The question was read by the reporter.) 20 A. Oh, okay. I went back to Well Spring in 21 September of this year. 22 Q. All right. So before we get to September, 23 between 1989 when you left the Sea Org and August 24 of '98, the only time you sought professional 25 therapy for anything was at Well Spring, is that SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 62 1 right? 2 A. There was one other therapist I sought 3 while I was in Columbus, I just remembered, which 4 was maybe, what, a year ago. 5 Q. Okay. Well, I'm trying to be precise 6 about the dates. Okay? A year ago would be after 7 August of '98. So what I'm asking you is between 8 June of '89 when you left the Sea Org and August of 9 '98 when you went to Well Spring, was there any 10 other occasion where you went to a professional 11 therapist? 12 A. As I said, this ?? this therapist in 13 Columbus. 14 Q. Yeah, but I was under the impression that 15 was after the Well Spring experience. 16 A. Between these two Well Spring experiences. 17 Q. What I'm asking you is between '89 when 18 you left the Sea Org and the first Well Spring 19 experience, was there any other experience with a 20 professional therapist? 21 A. I went to a therapist a couple of times in 22 Seattle, this was several years ago. Wasn't too 23 impressed with him, just went a couple of times. 24 Q. Was that a psychiatrist? 25 A. No, it was a psychologist who was SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 63 1 recommended from a friend and I was just ?? I 2 wasn't having any personal problems at the time and 3 I thought it would just be interesting and went a 4 couple of times and didn't particularly like his 5 style and stopped. 6 Q. Did you go by yourself or you went with 7 your wife? 8 A. Just by myself. 9 Q. And was there something that occasioned 10 you to go? 11 A. Not really. It was just more my curiosity 12 and the friend just said it's just nice to talk to 13 somebody and I thought, okay, Scientology is so 14 antitherapy that you feel like you're doing some 15 horrible thing that's ingrained into you as a 16 flinch. So I just thought well, this might be sort 17 of interesting to just go talk to a therapist and 18 just do the horrible evil thing by talking to one 19 of these dastardly, evil, sinister, devilish 20 psychologists. It sounded delicious so I decided 21 to go. 22 Q. Did it have anything to do with marital 23 problems? 24 A. No. 25 Q. Did it have anything to do with alcohol SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 64 1 problems? 2 A. No. 3 Q. Did it have anything to do with the Church 4 of Scientology that you went to this therapist. 5 A. No, no. 6 Q. The fact of the matter is ?? is that 7 Scientologists do believe that going to a mental 8 hospital or getting psychiatric treatment is a bad 9 thing, don't they? Scientologists believe that? 10 A. Worst than bad, a crime. 11 Q. Scientologists believe that mental 12 problems should be dealt with spiritually as 13 opposed to seeking mental health treatment at a 14 psychiatric hospital or a psychiatrist, correct? 15 A. No. 16 Q. In the period of time after the first Well 17 Spring experience to the second Well Spring 18 experience, you saw some therapist? You said there 19 was somebody in Columbus that you went to? 20 A. Yes. 21 Q. And when was that, approximately? If the 22 first Well Spring experience was around August of 23 '98 ?? 24 A. Early, mid '99. 25 Q. So what ?? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 65 1 A. March, April, May, within that period. 2 Q. Okay. And is this a psychiatrist that you 3 went to? 4 A. I think she is, or was. 5 Q. Is she dead or ?? 6 A. No, I just haven't, you know ?? was in 7 that period of time that I saw her. 8 Q. Okay. How many times did you see this 9 therapist? 10 A. Maybe eight or ten times. 11 Q. And did you go with anybody or is this by 12 yourself? 13 A. By myself. 14 Q. Did she have a couch? 15 A. Well, there was a couch but I sat on it. 16 Q. Okay. And the reason that you sought 17 psychiatric counseling in whatever that time frame 18 was was what? 19 A. To understand my cult experience. 20 Q. You didn't get that understanding at Well 21 Spring in the summer of 1998? 22 A. Only Hubbard has the one shot clear. I've 23 come to realize that understanding one's self is a 24 long, arduous process. It does not come in a 25 sudden, blue flash. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 66 1 Q. Did this ?? did you seek the psychiatric 2 counseling as a result, at least in part, of the 3 breakup of your marriage? 4 A. No. 5 Q. How did you come upon this particular 6 psychiatrist? I mean did you ?? 7 A. A friend ?? 8 Q. I'm sorry. Go ahead. 9 A. A friend had gone there, mentioned having 10 a good time at the place, had mentioned me, and 11 they were just intrigued and they said, you know, 12 come on in. I said, you know, I'm not ready to go 13 pay professional therapy rates on something like 14 that, you know, and they said no, this will just 15 be ?? just be gratis, so ?? 16 Q. So you got a scholarship to this 17 psychiatrist, too? 18 MR. DANDAR: Object to the form. 19 A. We never used the word scholarship. 20 Q. Who is we? 21 A. Me or the therapist. 22 Q. So you found a psychiatrist that didn't 23 charge you for eight to ten visits? 24 A. Right. 25 Q. And the reason she didn't charge ?? is it SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 67 1 a she or a he? 2 A. It was a she. 3 Q. And the reason she didn't charge you was 4 what? 5 A. My friend said just pretty much intrigued 6 with me having spent 21 years in a cult and just 7 the effect of it. 8 Q. Excuse me? 9 A. Just 21 years in a cult and the cult 10 experience. I don't know, maybe I was being 11 studied for a paper, I don't know. 12 Q. You were living with this friend? 13 A. No. 14 Q. After that did you live with this friend? 15 A. No. 16 Q. Have ?? did the friend have any experience 17 with Scientology? 18 A. Yes. 19 Q. Had been a Scientologist? 20 A. Yes. 21 Q. Had the friend been to Well Spring? 22 A. No. 23 Q. Is the friend Jesse Prince? 24 A. No. 25 Q. Who is the friend? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 68 1 A. Brian Haney. Oh, everybody take notes. 2 Q. Well, we were going to get to Brian Haney. 3 A. Oh, I know that. 4 Q. Eventually. So Brian Haney paid for the 5 eight to ten visits? 6 A. No. 7 Q. He didn't make any arrangements for that? 8 A. No. I specifically asked him. I said 9 Brian, are you paying for this, he says no. He 10 said they ?? I've known these people, I just 11 mentioned and they were just curious and they 12 just ?? and like the Well Spring thing, he offered 13 it and I said no, that's okay, I just kept it away. 14 And then I said okay, I think I'll give it a shot. 15 Q. Well, the ?? were you treated with any ?? 16 did they ?? did this psychiatrist put you on any 17 drugs? 18 A. No. 19 Q. Without going into the details, I mean is 20 this just a normal psychiatric counseling session, 21 is that what would happen? 22 MR. DANDAR: Object to the form. 23 A. I don't know what a normal psychiatric 24 counseling session would be. All I can do is give 25 you the structure of mine. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 69 1 Q. What do you mean the structure? 2 A. In a room, I sat on a couch, she sat over 3 there on a chair and we would just talk. 4 Q. She would make notes? 5 A. No. 6 Q. Did she have a practice? 7 A. Well, it was part of a ?? of a group, like 8 a little ?? you know, a group of psychiatrists, 9 psychologists, et cetera, several there and so she 10 was just one of the few. 11 Q. And how long would you spend in a session? 12 A. An hour, or I guess maybe it's what they 13 used to call the 50?minute hour. 14 Q. Sort of like college? 15 A. Maybe so. 16 Q. The ?? but ?? and it's your testimony that 17 she, in essence, donated to you ten hours worth of 18 therapy? 19 A. I ?? the best way for me to respond is 20 since she was part of a clinic, I guess that's sort 21 of a collective thing, so maybe the clinic was 22 donated. I don't know that she was. I just know 23 that I was told that there was no reason for me to 24 pay. 25 Q. During what period of time did this take SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 70 1 place, over what, you know, what span of time? 2 A. I mentioned the ?? 3 Q. You told me the ?? you told me, you know, 4 that it was in the spring but are you going daily 5 or is it weekly? 6 A. Oh, just once a week. 7 Q. All right. So we're talking about over a 8 two? to three?month period you went once a week? 9 A. Yeah, roughly, and missed a couple of 10 times. 11 Q. When is the last time you've had a visit 12 with the psychiatrist? 13 A. Maybe six, seven months ago. 14 Q. Why did you quit going? 15 A. I don't know, maybe I just got tired of 16 it. I really don't think ?? I really can't think 17 of a reason. 18 Q. When did you go to Well Spring for the 19 second time? 20 A. September. 21 Q. Of 1999? 22 A. Yes. 23 Q. And had you stopped your psychiatric 24 sessions or not? 25 A. Yes. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 71 1 Q. How long after you stopped your 2 psychiatric sessions did you go to Well Spring for 3 the second time? 4 A. I just love this psychiatric timetrack 5 you're building. Oh, I don't know, maybe four or 6 five months. As I said, it was back somewhere 7 maybe June, July that I last went there and then I 8 went in September. I wasn't keeping a notebook on 9 it. 10 Q. What was the reason that you went to Well 11 Spring again in September of '99? 12 A. The ?? I had given a lot of thought to it 13 after the heart attack of May, and I was thinking, 14 you know, it might be nice to go back and sort of 15 get, you know, the 100,000 mile check?up, you know, 16 get the oil changed, speaking metaphorically and 17 just sort of go back. It's been a year, I've 18 learned a lot about myself. 19 Rinder is just laughing down there so 20 much. 21 MR. DANDAR: Is that bothering you? 22 THE WITNESS: No, he's having a good 23 time. He's trying to do something to me. 24 MR. DANDAR: It's totally inappropriate. 25 MR. WEINBERG: You know what, Ken, what's SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 72 1 inappropriate is during every deposition you 2 make these outrageous and wrong and 3 inappropriate comments, okay? I'm tired of 4 it. This witness here has been chuckling and 5 laughing the whole time and the camera will 6 show it. And he looks at Mr. Rinder and he 7 looks at Mr. Rathbun and he's just having a 8 big old time. And here is Jesse over here 9 looking at him and he's laughing the whole 10 time, but I don't say anything about that and 11 you shouldn't either because what you're doing 12 is you're trying to pollute the record, and 13 you've been doing this week after week and 14 month after month in this case and I'm tired 15 of it. 16 MR. DANDAR: Jesse Prince hasn't laughed 17 at anybody. Mr. Rathbun and Mr. Rinder ?? 18 MR. WEINBERG: Oh, yes he has. What 19 Mr. Prince has been doing the entire time is 20 smirking and laughing. Okay? That's what 21 he's been doing. 22 MR. DANDAR: Then you should point it out 23 because I look at it ?? 24 MR. WEINBERG: You know what, I think 25 it's childish. I think what you do is SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 73 1 childish and I think this whole ?? this whole 2 process is childish. 3 MR. DANDAR: How many more minutes do you 4 want to waste on your scolding? 5 MR. WEINBERG: Hey, look. I'm not 6 wasting any time, Ken. 7 THE WITNESS: I'm sorry. Mike and I go 8 back years. What was our last question? 9 MR. WEINBERG: See, that's the problem. 10 When ?? when Mr. Dandar, you know, makes one 11 of his, you know, inappropriate and sort of 12 outrageous statements, we have to go back. So 13 let's go back to Mr. ?? let's find out what 14 Mr. Young was saying. 15 (The question was read by the reporter.) 16 A. And I was just saying metaphorically 17 speaking it was ?? I had learned a lot about myself 18 and I just ?? I just wanted to go back. And also, 19 now knowing what the process was, because the first 20 time I went there I spent a week just getting over 21 my fear of the place, having been told about the 22 horrors of deprogramming and, you know, hearing 23 stories about barbed wire and electroshock and 24 psychotropic drugs, you know, you just don't know 25 what you're going to get. So now learning that SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 74 1 they were nice people, the food was great, the 2 woods are beautiful, Athens is an incredibly 3 darling university town, going out to see a good 4 movie, I decided to go back now that I could really 5 relax and spend the full two weeks with myself, so 6 I decided to do that. 7 Q. Now, were you a paying customer this time? 8 A. No, I ?? I did the same thing. I just 9 called up and I said hey, guys, we did this before, 10 what's the chances of doing ?? of doing this? I 11 gave a call up and spoke to Ron and he says hey, 12 let me check, I'll get back to you. He called back 13 the next day and he says come on out. 14 Q. And Mr. Haney didn't have anything to do 15 with paying for your way? 16 A. I didn't even tell Mr. Haney I was going. 17 Q. I thought a few minutes ago you said that 18 you had talked to Mr. Haney about going to Well 19 Spring again. No? 20 A. No. 21 Q. Mr. Minton have anything to do with paying 22 your way? 23 A. No. 24 Q. Mr. Dandar have anything to do about 25 paying your way? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 75 1 A. No. 2 Q. Mr. Leipold have anything to do about 3 paying your way to Well Spring? 4 A. No, and the only way I say is I called up, 5 I asked him hey, you guys got a scholarship? He 6 says I'll call you back, he says yes, he did and 7 money was never discussed again. 8 Q. And you were there by yourself again or 9 were there some other scholarship people at ?? at 10 Well Spring? 11 MR. DANDAR: Object to the form. 12 A. You're loading the question with 13 scholarship. 14 Q. I'm using your word. 15 A. I can't answer your question. If you want 16 to ask if there was anybody else there I can answer 17 that question. I can't answer a scholarship. 18 Q. All right. Did you meet anybody else that 19 was on scholarship at Well Spring? 20 A. I don't know. I don't discuss ?? 21 Q. I'm just asking you. 22 A. I don't know. 23 Q. The answer is either yes or no. 24 A. I don't know. 25 Q. Okay. Now, did ?? did the people at Well SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 76 1 Spring tell you that anybody else ever went there 2 on, quote, scholarship, quote, unquote? 3 A. Yes. That's how I learned about ?? about 4 the availability for me. 5 Q. Did they indicate to you that ?? that Bob 6 Minton made a donation to Well Spring? Did they 7 indicate that to you? 8 A. No. 9 Q. Did they indicate to you that Mr. Haney 10 made a donation to Well Spring? 11 A. No. 12 Q. What was the session like the second time, 13 a year later? 14 A. Do you mean the regimen? 15 Q. The therapy as you call it. 16 A. Oh, it was similar, just same guy, same 17 table, same room. 18 Q. Same videos? 19 A. I didn't do workshop this time. I ?? I 20 didn't do the workshop thing. I said, you know, 21 I'll do my own reading as I see fit, so no workshop 22 was scheduled for me. I could just do my own. 23 Because I ?? there were some ideas that I wanted to 24 pursue with regard to the ?? you know, the control 25 of Scientology, et cetera, and I wanted to do my SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 77 1 own reading. 2 Q. Do you know who Dr. Margaret Singer is? 3 A. Yes. 4 Q. Who is that? 5 A. She's a doctor up in Berkley who did a lot 6 of work regarding prisoners of war and mind control 7 and the subject like that. I've read a little bit 8 of her stuff. 9 Q. You met with her, didn't you? 10 A. I met her in Berkley. 11 Q. And you met with her in the last couple of 12 years? 13 A. No. 14 Q. Did you speak with her with regard to the 15 breakup of your marriage? Did you speak with her 16 about that? 17 A. No. 18 Q. So you have not seen Dr. Singer or talked 19 to Dr. Singer since after 1997 at all? 20 A. Maybe a year ago she ?? I spoke to her for 21 15 minutes on the phone. One time she just called 22 up and said hey, I haven't talked to you in ages, 23 how are things going? Oh, pretty good, how are 24 things with you, Margaret? Oh, pretty good, I'm 25 doing a book about blah blah. It was, you know, SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 78 1 that type, okay, take care, all right, take care, 2 one of these casual little calls that, you know, 3 you sometimes just feel like you haven't called 4 somebody for a while and you just call them up. It 5 was like a 10, 15 minute call. 6 Q. You called her or she called you? 7 A. She called me. 8 Q. How could she find you since you had been 9 on the road for the last year and a half? 10 A. I ?? no, this is ?? oh, I don't know. 11 Q. You said in the last year. 12 A. Oh, maybe about a year ago. Maybe she 13 caught me while I was at Vashon. It seemed like 14 about a year ago. 15 Q. You didn't get counseling from Margaret 16 Singer then? 17 A. No, no shock treatment and no psychotropic 18 drugs either. 19 Q. Well, I didn't ask you those questions. I 20 asked you whether you got counselling from 21 Dr. Singer. 22 A. No. 23 Q. All right. Now, how long did you stay at 24 Well Spring this second time just a couple months 25 ago? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 79 1 A. Two weeks. 2 Q. Was this before or after your cancer was 3 found? 4 A. Before. 5 Q. Now, do you know the exact dates that you 6 were there, is it the beginning of September, end 7 of September, do you know? 8 A. Sort of the first half of September, I 9 think. 10 Q. Were there any other clients there? 11 A. One other ?? one other girl was there. 12 Q. And did she have anything to do with 13 Scientology? 14 A. No. 15 Q. Was she an abused spouse? 16 A. Yes. It turned out I asked somebody if 17 she was ?? you kind of like to know because you 18 want to see what topics you maybe should avoid 19 discussing, and they just said she was a young girl 20 that had been in a serously abusive marriage, 21 beaten, et cetera. I said okay, then we won't talk 22 about marriage and love life and that type of stuff 23 and so ?? 24 Q. Did you have joint sessions or solo 25 sessions? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 80 1 A. No, I never had ?? all the sessions as far 2 as I know were just private. 3 Q. Did you have visitors while you were there 4 the second time? 5 A. No. 6 Q. Mr. Haney didn't visit you? 7 A. No. 8 Q. Mr. Prince didn't visit you? 9 A. No. 10 Q. Now ?? 11 A. I spent my free time going into town. 12 Q. Town being Athens? 13 A. Athens, yeah. 14 Q. What did you review before your 15 deposition? 16 A. Nothing. 17 Q. Have you seen Mr. Prince's deposition? 18 A. No. 19 Q. You never reviewed his deposition? 20 A. No. 21 Q. Have you reviewed any of the depositions 22 in this case? 23 A. No. 24 Q. Ever? 25 A. Gosh, I haven't reviewed any material in SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 81 1 this case in a couple of years. The best of my 2 recollection, no, I haven't. 3 Q. You did an affidavit in this case, didn't 4 you? 5 A. Yes. 6 Q. We'll get to that in more detail later. 7 Did you review anything before that ?? before you 8 wrote your affidavit? 9 A. No. 10 Q. Did you meet with anybody before your 11 deposition? 12 A. Well, I met with Mr. Dandar and Michael 13 and I saw Jesse. 14 Q. Did you talk to Jesse about what the 15 testimony might be? 16 A. No. 17 Q. Why is that funny? 18 A. We were talking about language, about 19 whether or not words really exist, and I can't 20 remember the word right now that we had. It was 21 hardly, morally, or I don't know what it was. 22 Q. All right. But the answer to my question 23 is that you didn't speak with Mr. Prince about what 24 your ?? about your deposition? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 82 1 Q. Did you meet with Stacy with regard to 2 your deposition? 3 A. No. 4 Q. Did you have any communication whatsoever 5 with regard to anyone other than Mr. Dandar about 6 your deposition? 7 A. No. 8 Q. Now, going back to ?? were there places in 9 Ohio where you were actually living in the last 10 couple of years? 11 A. I was staying at a place just north of 12 Columbus for about five, six months. 13 Q. What kind of place? 14 A. It was a little two?bedroom apartment. 15 Q. You rented it? 16 A. No, Mr. Haney was renting it. 17 Q. So you were a roommate of Mr. Haney's? 18 A. No. 19 Q. So he rented it for you? 20 A. Yes and no. 21 Q. You didn't pay him rent? 22 A. No. 23 Q. And you were the only one living in the 24 apartment? 25 A. Yes. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 83 1 Q. So he rented it for you? 2 A. He rented it for me to work out of, as 3 opposed to a living space. It was a working space. 4 Q. Did you have a bed in there? 5 A. Yes. 6 Q. So you lived there as well? 7 A. Yes. 8 Q. And where ?? you don't live there anymore, 9 right? 10 A. No. 11 Q. What is that, can you give me the address, 12 what's the address? 13 A. I don't remember. 14 Q. What city were you in? 15 A. Lewis Center, L?e?w?i?s, Center. 16 Q. Was it in a building or a complex? 17 A. It's one of these large complexes of 18 buildings that has apartments and houses. 19 Q. This was an apartment? 20 A. Yes. 21 Q. One bedroom, two bedroom? 22 A. Two bedroom. 23 Q. Did anybody else stay there while you were 24 there at any point in time? 25 A. A kid came through on his way to Well SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 84 1 Spring that I had never met. 2 Q. What was that person's name? 3 A. God, I don't remember, he was from 4 Copenhagen. 5 Q. Lorenzen, Lorenzen? 6 A. Yeah, see, they keep up with it better 7 than I do. You can ask them. 8 Q. You said from Copenhagen, there was a 9 person of that ?? from there that testified, 10 Mr. Dandar called as a witness in this case. Is 11 that who that was? 12 A. That sounds right. I can't remember his 13 first name but that rings a bell, Lorenzen, yeah. 14 Q. And he went to Well Spring too? 15 A. Yes, he did. 16 Q. Who paid for that? 17 A. I don't know. 18 Q. Did Mr. Haney arrange for that? 19 A. I don't know. 20 Q. Why did he stay in the apartment? 21 A. Because he arrived a couple of days 22 before ?? see, your schedule at Well Spring usually 23 starts on a Monday and I think he arrived like a 24 Friday or a Saturday. And so he was flying into 25 Columbus, which is the nearest airport, and Brian SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 85 1 said this guy is coming through, you know, can he 2 stay over there? And I said yeah, and so he stayed 3 over and then I drove him down to ?? down to Well 4 Spring. 5 Q. You drove the young man? 6 A. Yeah. So I drove him down on Monday, 7 dropped him off and drove back. 8 Q. Did you pick him up when he was done? 9 A. Yes. 10 Q. And then where did you go after that? 11 A. He stayed at my place overnight and then 12 he flew out. 13 Q. And did ?? do you know whether or not ?? 14 do you know how he paid for the Well Spring 15 experience? 16 A. No. 17 Q. Did he get a scholarship? 18 A. I don't know. 19 Q. Did Mr. Haney spend time at Well Spring? 20 A. I don't know. 21 Q. I mean did he ever tell you that he spent 22 time at Well Spring? 23 A. You mean as a client. 24 Q. Yeah, as a patient, a resident there? 25 A. No, I don't think so. He never told me SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 86 1 anything about it. 2 Q. Now, how ?? other than this Danish fellow, 3 did anybody else connected with Scientology stay in 4 your apartment? 5 A. Martin Ottman came through, O?t?t?m?a?n. 6 Q. And who is that? 7 A. Some kid from Germany. 8 Q. And he went to Well Spring too? 9 A. No. 10 Q. So he ?? he came for what purpose? 11 A. He was passing through, traveling in the 12 United States and wanted to see New York or 13 something or other and he stayed over and visited 14 Columbus and ?? 15 Q. And how did he find your apartment, is 16 that Mr. Haney again? 17 A. I guess so, yes. 18 Q. All right. Other than Martin Ottman and 19 the kid from Denmark, who else stayed in your 20 apartment? 21 A. That was all. 22 Q. What about Jesse? 23 A. I think Jesse did stay over, come in for a 24 day or two one time, yeah. 25 Q. What was the occasion of Jesse being SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 87 1 there? 2 A. Hey, passing through. I hadn't seen Jesse 3 for a long time, so just hanging out. 4 Q. You hadn't seen Jesse for a long time when 5 he was passing through? 6 A. You know with good friends a few months 7 can be a long time. 8 Q. So you just had a good time with Jesse? 9 A. Just hung out for a couple of days, yeah. 10 Q. Does that mean went out on the town? 11 A. No. No. We went to ?? we went down to 12 the Dick Clark American Bandstand place just to 13 show Jesse what a really upscale, quote, nightclub, 14 end quote, was like. And we just sat there and 15 watched people dance and hung out and had dinner 16 and went back, and that was the end of our night on 17 the town. We were back by, I think, eleven o'clock 18 at night. 19 Q. Have you ever done drugs with Jesse? 20 A. No. 21 Q. Have you ever seen Jesse do drugs? 22 A. No. 23 Q. Get drunk with Jesse? 24 A. No. 25 Q. Drink alcohol with Jesse? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 88 1 A. I think we had a drink, maybe a beer at 2 the nightclub. 3 Q. Anyone else that comes to mind that stayed 4 in that apartment that Mr. Haney was renting? 5 A. No. 6 Q. Now, other than the apartment north of 7 Columbus, what other places did you stay in in 8 Ohio? 9 A. Does that count the motels? 10 Q. Yes. 11 A. I stayed at some motels in Ohio. 12 Q. Was that before or after the apartment in 13 Ohio? 14 A. Both. 15 Q. And when you stay in a motel, it would be 16 for what, a month at a time? 17 A. No, maybe for a day, maybe for a few days, 18 depends upon what I'm doing, where I'm going, 19 what's happening. 20 Q. Were there any other places, any other 21 apartments or houses that you stayed in in Ohio? 22 A. Staying with a friend right now in 23 Cincinnati. 24 Q. How long have you been there? 25 A. A couple of months. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 89 1 Q. And did Mr. Haney arrange for that? 2 A. No. 3 Q. Is this a longtime friend or somebody that 4 you've just met? 5 A. I've known him for about a year and a half 6 maybe. 7 Q. Are you paying rent? 8 A. Not really but helping to pay expenses, 9 you know, heating bills and things like that. 10 Q. All right. What are some of the hotels or 11 motels? 12 A. Motel Six, Red Roof, those are the main 13 ones. I travel with my dog, so it's ?? I'm 14 restricted to the ones that take dogs and they are 15 pretty good, Microtel. 16 Q. Did Mr. Haney pay for these hotels? 17 A. When I was traveling, doing some research 18 for him, he paid for some. Otherwise, I paid for 19 them myself. 20 Q. Which ones did Mr. Haney pay for? 21 A. Oh, the early '99, late '98 ones, I guess. 22 Q. Do you remember, is that Microtel and Red 23 Roof Inn? 24 A. I really don't remember. You just sort of 25 grab what's available that takes a dog. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 90 1 Q. How did he pay for them? 2 A. When I was traveling, he gave me expenses 3 to take care of it. 4 Q. What do you mean he gave you expenses? 5 A. Gave me some money to take care of it. 6 Q. What form was the money? 7 A. Cash. 8 Q. Do you have a record of what kind of cash 9 you received from Mr. Haney? 10 A. No. 11 Q. How much money did you receive from 12 Mr. Haney? 13 A. I don't ?? I don't know. 14 Q. What period of time have you worked for 15 Mr. Haney? 16 A. Maybe seven, eight months in '99. 17 Q. Did you know Mr. Haney ?? when did you 18 first meet Mr. Haney? 19 A. Oh, I first met Mr. Haney via the phone 20 when I was living on Vashon. 21 Q. So when you were still married to Stacy 22 you first met Mr. Haney? 23 A. Yes. 24 Q. And what was the occasion of talking to 25 Mr. Haney on the phone when you were in Seattle? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 91 1 A. She knew him, by whatever case I don't 2 know, and said, you know ?? she had mentioned his 3 name a couple of times as just chatting with this 4 guy, and one time she said hey, Brian would like to 5 talk to you sometime. So she was on the line and 6 she turned the phone over to me and Brian and I 7 chatted and ?? so we did that ?? that was on and 8 off for months. 9 Q. Can you date when you first talked to 10 Brian Haney? 11 A. Gosh, no. 12 Q. Was it ?? 13 A. A couple of years ago. 14 Q. Was it before or after Mr. Minton bought 15 the house? 16 A. Mr. Minton did not buy the house, so I 17 can't answer your question that way. 18 Q. You bought the house? 19 A. No. 20 Q. Stacy bought the house? 21 A. No. 22 Q. Who bought the house? 23 A. Mr. and Mrs. Minton bought the house. 24 Q. Okay. There you go. So let me correct 25 myself. This was before or after Mr. and SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 92 1 Mrs. Minton bought the house? 2 A. The Brian Haney phone call? 3 Q. Yes. 4 A. I think it was before. 5 Q. So where were you living then? 6 A. West Seattle. 7 Q. In a house? 8 A. Yes. 9 Q. Did you own the house? 10 A. No, we rented. 11 Q. What was the address of that house? 12 A. It was on Beach Drive. I don't ?? 1031. 13 Q. And how long did you live there? 14 A. Couple years, year and a half. 15 Q. You said that Stacy said that she knew 16 Mr. Haney from some case? 17 A. No, I said she just ?? she knew Mr. Haney 18 and I didn't know why. 19 Q. I thought you said something about a case. 20 A. No, I didn't. 21 Q. Well, how did she know Mr. Haney? 22 A. I just said I don't know. 23 Q. Well, did you know Mr. Haney while you 24 were in Scientology? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 93 1 Q. Did she know Mr. Haney while she was in 2 Scientology, as far as you know? 3 A. I don't think so. 4 Q. So it's your belief that she came to know 5 Mr. Haney at some point in time after you and she 6 left Scientology, is that right? 7 A. Yes. Yes. 8 Q. But you don't know how? 9 A. No. 10 Q. Was Mr. Haney ever in your house, in 11 either one of your houses in Seattle? 12 A. No. 13 Q. Well, what did you talk to him about on 14 the telephone? 15 A. Really not much of anything and that's 16 what's sort of odd. There are some people that 17 sometimes you start talking with them on the phone 18 and you just ?? you just hit it off, you just get 19 along fine, and I think we were talking about ?? 20 about computers because Brian is big on computers, 21 and we started talking about it and it was just 22 casual chitchat. We did not talk about 23 Scientology. I did not even know he had been in 24 Scientology and ?? because Stacy said I just think 25 it's somebody you would enjoy chatting with. So we SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 94 1 just chatted and ?? 2 Q. Well, did Stacy tell you what she talked 3 to Brian Haney about? 4 A. No. 5 Q. Well, how long was this conversation 6 several years ago? 7 A. Oh, I don't know, maybe 10, 15, 20 8 minutes. 9 Q. And this was the only conversation or were 10 there a series of conversations at that time? 11 A. No, there ?? there were starting to be 12 sporadic conversations. Sometimes he would just 13 call me up. 14 Q. And say what? 15 A. How you doing, what's happening? 16 Q. This is a guy you, at that point, had 17 never met before? 18 A. Never met him. 19 Q. If you ran into him you wouldn't know who 20 he was? 21 A. Not at all. 22 Q. And Stacy hadn't met him either? 23 A. As far as I know. 24 Q. Okay. Well, when did they cease being 25 sporadic? When did they ?? when did the SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 95 1 conversations cease being sporadic? 2 A. They were always sporadic. There was 3 no ?? 4 Q. When did you first meet Mr. Haney eyeball 5 to eyeball? 6 A. August of ?? after my first Well Spring 7 experience. 8 Q. August of '98? 9 A. Yes. 10 Q. And you met him where? 11 A. Up in Columbus. 12 Q. You stayed with him? 13 A. No. 14 Q. Who was at the meeting? 15 A. Just him and me. 16 Q. Where was the meeting? 17 A. I think at his house. 18 Q. Is that where he lives? 19 A. At his house. 20 Q. I mean he lives in Columbus then? 21 A. Yes. 22 Q. Okay. 23 A. Well, I don't know if it's Columbus city 24 limits. 25 Q. Well, I'm talking about he lives in Ohio? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 96 1 A. He lives in the Columbus area. 2 Q. I mean did he have a wife there or 3 anything or was it just you and him? 4 A. No, he has a wife and a couple of kids. 5 She may have been there but it was just Brian and I 6 meeting. 7 Q. And what was the occasion of you meeting 8 with Brian Haney? 9 A. I called him and I said hey, I'm in Ohio, 10 we've never met, I'd like to see what you look 11 like. 12 Q. Did you call him and tell him before you 13 went to Well Spring that you were going to Well 14 Spring? 15 A. No. 16 Q. So you went and met him in August of '98. 17 Did you have meetings with him after that time? 18 A. Yeah. 19 Q. Can you describe the regularity of those 20 meetings? 21 A. It fluctuated with what went on. 22 Q. What do you mean with what went on? 23 A. Well, early on there was no particular 24 reason and then other times we saw each other 25 pretty regularly. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 97 1 Q. And what was the reason to see him 2 regularly? 3 A. Oh, it might be anywhere from a church 4 dinner party, kids birthday, talking about some 5 research, the project that he wanted me to work on, 6 it fluctuated. Sometimes there would be ?? even 7 when I stayed at Columbus there would be weeks that 8 I never saw him, and I might see him several times 9 in one week. It was very ?? it was very flexible. 10 Q. What church dinner party? 11 A. His church. 12 Q. Which is what? 13 A. I don't know the denomination. I never 14 went. 15 Q. Now, did Mr. Haney give you money? 16 A. Yes. 17 Q. And how much money did Mr. Haney give you? 18 A. When I was doing the work for him he was 19 giving me $200 a week. 20 Q. Plus he provided the apartment or the 21 hotels? 22 A. Yes. 23 Q. What did that amount to? 24 A. I don't know what the rent on the 25 apartment was. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 98 1 Q. Well, I mean what ?? I mean can you give 2 us a, you know, your best estimate as to the value 3 of what it was that Mr. Haney was providing for you 4 as a result of whatever it was that you were doing 5 for him? 6 A. I think the apartment rented in the range 7 of $400, $500. I'm from California and I'm used to 8 much higher rents and when I ?? I think when I saw 9 that it sounded preposterous because it was 10 incredibly low. But I think that was the range of 11 that apartment, $400, $500. He signed the lease 12 and paid for it so I didn't really handle it. 13 Q. How much did he give you before you 14 started working for him? 15 A. Just some travel expenses whenever I 16 needed to do something. 17 Q. How much was that, how much was that? 18 A. A few hundred dollars but there was no 19 personal money for me, just expense money. 20 Q. Are you still working for him? 21 A. No. 22 Q. When did you stop working for him? 23 A. Back around August, I think, yeah, August 24 of this year. 25 Q. Why did you stop working for him? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 99 1 A. Because I just wanted to just travel some 2 more and we were wrapping up my end of the project 3 and I wanted to get back on the road. I just 4 didn't care to sit for much longer in Columbus. 5 Q. Well, where did you work, was there some 6 office you worked in? 7 A. No. This two bedroom apartment in 8 Columbus. 9 Q. What did you have in the apartment that 10 allowed you to work? 11 A. Computers. 12 Q. What kind of computers? 13 A. I don't know the brand name. It's got a 14 keyboard and a screen and a hard drive. 15 Q. Mr. Haney provided those for you? 16 A. They were his ?? yeah, they were his. 17 Q. Did he buy you a computer? 18 A. No. 19 Q. Did you take it with you? 20 A. No. 21 Q. One of them with you? 22 A. No. They both went back to him. There 23 were two but I never ?? I never brought up the 24 second one. They were computers that had been 25 sitting in his basement that he had ?? that he said SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 100 1 they had been his kids and they had outgrown them, 2 and so he brought them over and I just ?? 3 Q. How many hours did you work for Mr. Haney, 4 how many hours did you work? 5 A. Per day, per week? 6 Q. I'm asking. Well, let's start ?? let's 7 make it simple. When did you start working for 8 him, approximately? 9 A. Oh, probably March of '99. 10 Q. When did you stop working for him? 11 A. Maybe February, then I stopped in August. 12 It was just six months, seven months. 13 Q. All right. So you may have started in 14 February and you stopped in ?? 15 A. August. 16 Q. The end of August or the beginning of 17 August or what? 18 A. Maybe mid August. 19 Q. Okay. Mid August. Was this a ?? an eight 20 hour a day job? 21 A. Basically, yeah, but it was very, very 22 loose. It wasn't a case of punching a clock. 23 There was just things to do and so ?? 24 Q. Eight hours a day, seven days a week? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 101 1 Q. Eight hours a day, five days a week? 2 A. Roughly. As I said, it was a very loose 3 schedule. 4 Q. And all Mr. Haney paid you was $200 a week 5 for eight hours a day, five days a week? 6 MR. DANDAR: Object to the form. 7 Q. Is that ?? is that what you're saying? 8 A. The way you sort of couched it ?? I mean I 9 was getting paid $200 a week for what I was doing, 10 yes, because as I said it was a very loose day. If 11 I decided I wanted to take off for a day or two or, 12 you know, just ?? he didn't object. 13 MR. DANDAR: Could we take a break? 14 MR. WEINBERG: Sure. 15 (Recess from 10:42 to 10:56 a.m.) 16 BY MR. WEINBERG: 17 Q. Now, you were ?? we were talking and I got 18 to tell you, I don't have total recall, so we may 19 repeat a couple things to try to get back to where 20 we were, but we were talking about Mr. Haney and 21 you and how much money Mr. Haney had paid you. All 22 right? And what I'm really asking you is, without 23 being cute or technical about it, can you tell us 24 or give us an estimate as to the value of whatever 25 it is that Mr. Haney gave you or provided for you SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 102 1 with regard to anything from him? 2 A. Other than what I've described, that's as 3 best as I can ?? like, for example, I don't know 4 what the utility bills were. 5 Q. But he paid those? 6 A. Yes, I assume so. They didn't come to me, 7 that's all I know. 8 Q. Did he pay the phone bills? 9 A. Yes. 10 Q. Did you make phone calls? 11 A. A few. 12 Q. Did you make long distance calls? 13 A. I assume so, yes. 14 Q. He paid for those? 15 A. Yes. 16 Q. Did he ?? did he pay for your food? 17 A. No. I bought my own food out of my own 18 allowance. 19 Q. So out of $200 a week you bought enough 20 food for yourself? 21 A. Yes. 22 Q. And did you eat out? 23 A. Sometimes. 24 Q. Did he give you a credit card? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 103 1 Q. Did he pay ?? when you went out, would he 2 pay for that? 3 A. No. 4 Q. Did you go out with him from time to time? 5 A. Sometimes. 6 Q. And he would pay for that, obviously? 7 A. Yeah. 8 Q. Was there anybody else that Mr. Haney was 9 paying with regard to this work? 10 A. Not to my knowledge. 11 Q. Did anybody else work with you? 12 A. No. 13 Q. Did you ever sit down with anyone in that 14 room that you were working out of, or any other 15 room that you were working out of with regard to 16 the Haney work? 17 A. I'm sorry. I thought you didn't finish 18 your sentence. No. 19 Q. Well, was Mr. Prince ever there? 20 A. Yes. 21 Q. And did you work with Mr. Prince on 22 whatever it was that you were working for Mr. Haney 23 on? 24 A. No. 25 Q. Well, what was Mr. Prince doing there? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 104 1 A. I told you he came in and hung out. 2 Q. Well, didn't that kind of interrupt your 3 work? 4 A. I ?? I tried to explain, it was a very 5 loose schedule and I had weekends off and I think 6 Jesse was even there during the weekends, and so it 7 was just a nice break. 8 Q. How did Mr. Haney pay you? 9 A. Cash. 10 Q. You mean actual cash? 11 A. Yes. 12 Q. No checks? 13 A. No. 14 Q. Did you get a 1099 from him? 15 A. No. 16 Q. Do you expect a 1099 from him? 17 A. No. 18 Q. Why not? 19 A. Because he explained that there was a 20 certain amount that I could just receive as a gift 21 and so I will deal with that ?? I'm not even to the 22 end of the year. I'll deal with that later. 23 Q. All right. So this was a gift from 24 Mr. Haney? 25 A. Yes. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 105 1 Q. So you really weren't working for 2 Mr. Haney then? 3 A. I was not, as you would say, an employee. 4 That's why my time was my own. I did not log in, I 5 did not report any time to him, et cetera. 6 Q. You didn't have to account for your time? 7 A. No. 8 Q. You didn't have to account for your 9 expenses? 10 A. No. 11 Q. You were not hired by Mr. Haney? 12 A. Not in the usual sense of the word, no. 13 Q. Well, what's the unusual? I mean I ?? 14 when you say not in the usual sense of the word ?? 15 you understand when I hire you, I'm either hiring 16 you as my employee or I'm hiring you as an 17 independent contractor, right? You understand 18 that? 19 A. Maybe so. 20 Q. And when I pay you for that work, those 21 are wages, correct? 22 A. I'm not going to get into a legal tussle. 23 All I can describe to you is how I got paid and 24 we'll leave it at that. 25 Q. Well, do you consider what Mr. Haney paid SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 106 1 to you to be income? 2 A. No. 3 Q. And can you explain ?? can you describe to 4 us why not? 5 A. I don't feel I was holding down a 6 scheduled job and that I was doing this and he was 7 basically covering ?? as I said, I paid for my own 8 food. The apartment ?? the purpose of the 9 apartment was to give me a place to work more than 10 it was a place for me to live, so I was there doing 11 that. It wasn't ?? I wasn't being hired in the 12 normal sense of the word. All I can do is describe 13 the situation and let somebody else characterize 14 it. 15 Q. You paid for your own food out of what 16 Mr. Haney gave you? 17 A. Yes. 18 Q. All right. Were there times when he would 19 give you more than $200 a week? 20 A. No. 21 Q. Were there times he would give you less 22 than $200 a week? 23 A. There was a couple of times he forgot and 24 I would ?? wouldn't even bother to mention it to 25 him because I wasn't, you know, in dire need. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 107 1 Q. Did you have a bank account there? 2 A. No. 3 Q. So you just kept it in a jar or something 4 or what? 5 A. No, I did not keep it in a jar, sir. 6 Q. Well, what other cash did you have 7 available to you other than the money that was 8 given to you by Mr. Haney during that period of 9 time? 10 A. I had cash that I would keep in my wallet. 11 I mean the way you characterize these questions, 12 that's the only way I know to respond to them. I 13 had cash in my wallet. 14 Q. How much cash outside of what Mr. Haney 15 gave you did you have? 16 A. I don't understand your question. 17 Q. All right. Well, let's make it really 18 simple. 19 A. Please. 20 Q. You ?? I don't have the dates. Well, I do 21 have the dates. Between February of '99 and mid 22 August of '99, you were receiving money on a weekly 23 basis from Mr. Haney, right? 24 A. Yes. 25 Q. And during that period of time, you were SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 108 1 living in an apartment and/or hotels that were 2 provided to you by Mr. Haney, right? 3 A. Sometimes. I said I also sometimes paid 4 for my own motels. 5 Q. Right. Now, Mr. ?? and with the ?? now, 6 did you have any other jobs during that period of 7 time for which you were paid? 8 A. In 1999? I don't think so. 9 Q. Did you have any other ?? did you have 10 investment income that you received between 11 February and mid August of '99? 12 A. No. 13 Q. All right. Well, was there any other 14 source of money that you had between February of 15 '99 and mid August other than what Mr. Haney gave 16 you? 17 A. No, not really. 18 Q. Did anybody else give you money during 19 that period of time? 20 A. No. 21 Q. Anybody else provide for you during that 22 period of time by whether it was providing you a 23 place to stay or providing you food or providing 24 you clothing or what not? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 109 1 Q. Did Mr. Haney provide you a car? 2 A. He had a car that was his car that he 3 allowed me to drive. 4 Q. And what kind of car was that? 5 A. A little Mazda. 6 Q. And you drove it for ?? during what period 7 of time did you drive his car? 8 A. '99. 9 Q. Are you still driving it? 10 A. Yeah. 11 Q. Is it registered in your name? 12 A. No. 13 Q. Whose name is it registered in? 14 A. Mr. Haney's. 15 Q. When did he first give you that car? 16 A. He did not give it to me. I explained, 17 he ?? it is his car and he's allowing me to drive. 18 Q. Okay. When did he give you the car to 19 allow you to drive it? 20 A. I think it was March or April, when we 21 were setting up the apartment. 22 Q. And what did you need a car for? 23 A. Basically, because where the apartment 24 was, you couldn't even get a bus from there. It 25 was because of the location. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 110 1 Q. Okay. Has he given you more than one car? 2 A. No. 3 Q. As far as you know, has he let anybody 4 else use his cars? 5 A. No. 6 Q. Why ?? why are you still driving his car? 7 A. I asked him if I could use it for a while 8 and he said sure. 9 Q. What's the understanding as to how long 10 you're able to use his car? 11 A. There is really no understanding. We 12 haven't discussed a time period. 13 Q. When I asked you whether there was any 14 other source of income that you had or source of 15 money or source of funds, source of living expenses 16 in 1999, you said not really. Does that mean no, 17 there was no other source? Is that what that 18 answer means? 19 A. Well, you had it during that period that I 20 was working with Mr. Haney, et cetera, and that's 21 what I was responding to, that there was no other 22 period of income. 23 Q. No other source of income at that time? 24 A. Right. 25 Q. And when I say source of income ?? or when SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 111 1 you say source of income, you understand that that 2 means funds of any kind. You understand that don't 3 you? 4 A. Yes. 5 Q. Now, did Mr. Haney provide you with any 6 vacations? Do you know what I mean by that? Did 7 he pay for air fare? 8 A. No. 9 Q. Ever? 10 A. No. I don't remember flying anywhere for 11 him. I was always just driving around. 12 Q. How about the furnishings in the 13 apartment, were there furnishings in it? 14 A. Yes, it was a furnished apartment. 15 Q. And he ?? he furnished it? 16 A. No, he did ?? I don't know how to answer 17 your question. The furniture was rented with the 18 apartment. 19 Q. Well, typically, you know, an apartment 20 wouldn't be rented furnished with, for example, a 21 television or a stereo. Did this have a television 22 and a stereo in it? 23 A. No. 24 Q. Did he own the furniture in the apartment, 25 as far as you know? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 112 1 A. No, he did not. 2 Q. Did he provide you with clothes? 3 A. No. 4 Q. Or funds for clothes? 5 A. No. 6 Q. How about entertainment? 7 A. Did he entertain me? 8 Q. No, did he provide, you know, provide you 9 with entertainment, give you ?? 10 A. Like he took off his top and wiggled? No, 11 I don't know what you mean. 12 Q. You thought that was funny? 13 A. Yeah. You said did he provide me with 14 entertainment. I don't know what you mean. 15 Q. Well, did he fly you to New York for a 16 weekend? 17 A. No. 18 Q. Did he provide you with professional 19 sports tickets? 20 A. No. 21 Q. Did he ?? you know, that's entertainment. 22 A. Did he spend any money for which I went 23 some place other than us going to lunch together? 24 No. We didn't even go to a movie together. 25 Q. Now ?? so during ?? so in the period of SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 113 1 1999, you haven't received any money from 2 Mr. Minton? 3 A. No. 4 Q. You haven't received any money from ?? 5 from your ex?wife, Stacy? 6 A. No. 7 Q. You haven't received any money from 8 Mr. Prince? 9 A. No. 10 Q. In that period of time, have you ?? have 11 you received any money from Mr. Dandar? 12 A. No. 13 Q. Have you received any money during that 14 period of time from Mr. Leipold? 15 A. I have ?? I've done some work for 16 Mr. Leipold but I'm going to have to refrain from 17 that, discussing it, because that's attorney work 18 product. 19 Q. The amount of money that you've received 20 is attorney work product? 21 A. I am ?? not been named yet and so I 22 have ?? from what I understand, I don't need to 23 testify any further on that. 24 Q. You understand from whom? I don't hear an 25 instruction from your attorney, Mr. Dandar. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 114 1 MR. DANDAR: Thank you for reminding me. 2 I'm instructing him not to answer. That is 3 work product. 4 MR. WEINBERG: All right. So ?? so let's 5 just make this clear because you're the one 6 that wants to go forward with this deposition. 7 So you're taking the position that funds that 8 Mr. Young has received with regard to working 9 against Scientology, working on Scientology 10 related cases, testifying against Scientology, 11 that that is work product and that I can't 12 inquire as to ?? as to that in this 13 deposition? Is that your position? 14 MR. DANDAR: You didn't ask that 15 question. 16 MR. WEINBERG: Is that your ?? sure I 17 did. 18 MR. DANDAR: No, you didn't. 19 MR. WEINBERG: That's what I asked. 20 MR. DANDAR: No, you didn't. 21 MR. WEINBERG: Yes, I did. 22 MR. DANDAR: Read it back. 23 MR. WEINBERG: Let's read it back. 24 THE WITNESS: You asked if I received 25 money from Mr. Leipold and that was the end of SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 115 1 it. 2 BY MR. WEINBERG: 3 Q. And you said that you had to exercise 4 your ?? your work product exception as to whether 5 you received money from Mr. Leipold. 6 MR. WEINBERG: You're telling me that 7 you're instructing him not to answer that 8 question? 9 MR. DANDAR: What, do you think 10 Mr. Leipold has only Scientology cases? Is 11 that what you're assuming in your question? 12 MR. WEINBERG: So what? I have a right 13 to ask him if he received money from somebody 14 that has dedicated the last, you know, six or 15 seven years of his life to try to destroy the 16 religion, yeah, yeah, I do. 17 MR. DANDAR: Who are you talking about? 18 MR. WEINBERG: Mr. Leipold. I have a 19 right to ask him whether ?? whether he's 20 received money from you. I have a right to 21 ask him whether he's received money from 22 anybody that's been working against 23 Scientology. You know what, Ken ?? 24 MR. DANDAR: You didn't ask that 25 question. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 116 1 MR. WEINBERG: I did ask that question. 2 Read the answer back. 3 MR. DANDAR: Yeah, read it back. Let's 4 get to the question. 5 (The question was read by the reporter.) 6 MR. DANDAR: That is not anything to do 7 with Scientology. 8 MR. WEINBERG: Give me a break. 9 BY MR. WEINBERG: 10 Q. Are you going to answer that question or 11 not? 12 A. No. 13 Q. And the reason you're not answering the 14 question as to whether you've received any money in 15 1999 from Mr. Leipold is what? 16 A. Attorney work product. 17 MR. WEINBERG: Ken, I don't see how you 18 think that this deposition is going to be 19 usable at any point when ?? when your witness 20 refuses and you instruct him, which you have 21 no right to do, not to answer a question that 22 absolutely goes to the heart ?? 23 MR. DANDAR: Adjourn the deposition ?? 24 MR. WEINBERG: Can I finish? 25 MR. DANDAR: Call the judge. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 117 1 MR. WEINBERG: Can I finish? 2 MR. DANDAR: Follow the rules. 3 MR. WEINBERG: You know what, we're 4 not ?? follow the rules? You follow the 5 rules. 6 MR. DANDAR: That's attorney work 7 product. 8 MR. WEINBERG: You don't have any ?? as 9 to what he received is attorney work product? 10 MR. DANDAR: Absolutely. 11 MR. WEINBERG: You are so ?? you are so 12 wrong that it's pitiful. 13 BY MR. WEINBERG: 14 A. He did not instruct me, sir. I answered 15 before any instruction. 16 Q. Well, what was your answer? 17 A. She just ?? she can read it back. 18 Q. Just tell me now, what was your answer? 19 A. You told me what my answer was. 20 Q. Which is what? 21 A. That I declined to answer. That was not 22 an attorney?instructed response, it was mine. 23 Q. No, I wanted to make sure that your 24 attorney was instructing you not to answer because, 25 you know what, under the rules he has no right to SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 118 1 instruct you not to answer a question like that and 2 he knows that. Every lawyer in this room knows 3 that. 4 Now, during what period of time did you 5 work for Mr. Leipold in 1999? 6 A. Attorney work product, please. 7 MR. WEINBERG: Now, are you instructing 8 him not to answer that question, Mr. Dandar? 9 MR. DANDAR: I agree with him, it is 10 attorney work product. 11 MR. WEINBERG: Are you instructing him 12 not to answer that question? 13 MR. DANDAR: Absolutely, work product, 14 objection. 15 MR. WEINBERG: Okay. 16 BY MR. WEINBERG: 17 Q. What meetings have you had with 18 Mr. Leipold in 1999? 19 MR. DANDAR: Objection, work product. 20 MR. WEINBERG: Fine, you objected. 21 A. Same response. 22 Q. Same response, what? You're not the 23 lawyer. The question is ?? 24 A. I'm not responding as attorney work 25 product. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 119 1 MR. WEINBERG: Are you instructing him not 2 to respond? 3 MR. DANDAR: Do you understand the 4 objection? Work product, it mean he doesn't 5 answer the question. 6 MR. WEINBERG: No, no. You can ?? you 7 know what, you can object all you want to. I 8 want on the record that you're instructing him 9 not to answer the question. 10 MR. DANDAR: I'm instructing him not to 11 answer on the basis of work product. 12 MR. WEINBERG: So just say that when you 13 object. 14 MR. DANDAR: That's what it means. 15 MR. WEINBERG: You know what, it doesn't 16 mean that. You can object all you want to but 17 unless you instruct him not to answer it, he 18 has to answer. 19 MR. DANDAR: Fine, if that's the rules 20 you want to lay down for this deposition, he's 21 not answering any work product questions. 22 MR. WEINBERG: Then we're going to spend 23 a long time going through this, Ken. 24 MR. DANDAR: That's your intent. 25 MR. WEINBERG: No, my intent is ?? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 120 1 MR. DANDAR: I can tell. 2 MR. WEINBERG: Look, here is a man that 3 by ?? when we go through it, has filed, has 4 probably filed ?? I'm not going to go through 5 it yet but has filed, by my last count, 22 6 declarations in cases involving Scientology or 7 Scientologists since 1993, has given ?? has 8 given sworn testimony on 13 or 14 occasions in 9 cases involving Scientology or against 10 Scientologists during that period of time. 11 THE WITNESS: Did that include 12 depositions? 13 MR. WEINBERG: Could I ?? that's what I 14 just said. 15 THE WITNESS: You said sworn testimony. 16 I just want to clarify as opposed to in court 17 testimony. 18 MR. WEINBERG: Both. That includes that. 19 THE WITNESS: Okay. 20 MR. WEINBERG: Has received tens of 21 thousands of dollars, which we will go 22 through, and I guess you can instruct him not 23 to answer it because it's work product for 24 this work, and you're offering him as some 25 sort of expert witness that you want to use SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 121 1 and I can't inquire into it because it's work 2 product? 3 MR. DANDAR: No, I don't know how you ?? 4 I know you think better than what you're 5 saying, but you can ask him all the questions 6 about all the filed declarations, depositions 7 and trial testimony, how much he was paid in 8 all those cases in which he was disclosed as 9 an expert. But when there is something 10 pending that he's not disclosed as an expert, 11 that is work product, and you're not allowed 12 to inquire into any matter about that. 13 MR. WEINBERG: But you know what, you're 14 wrong, because if he's getting money from 15 people that are working against Scientology 16 and that's how he's supporting himself in 17 these ?? you know, while he's traveling out of 18 a suitcase or whatever he's doing according to 19 his testimony, I have a right to know that, 20 particularly in 1999 as we're sitting here 21 right now. That's not work product. As to 22 what he's getting paid, that's work product? 23 MR. DANDAR: That's work product. 24 MR. WEINBERG: You are ?? you are so 25 wrong. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 122 1 MR. DANDAR: Get the judge on the phone. 2 MR. WEINBERG: I'm not going to get the 3 judge on the phone right now but I just can't 4 even believe what you're saying. Work product 5 might be what he's doing, but as to what he's 6 getting paid, that's work product? As to 7 whether he had a meeting, that's work product? 8 As to whether he did something for him, that's 9 work product? No. 10 BY MR. WEINBERG: 11 Q. Now, did you receive any money from Mr. 12 and Mrs. Minton either directly or indirectly ever 13 in your life? 14 A. No. 15 Q. Neither directly nor indirectly, is that 16 right? 17 A. That's correct. 18 Q. Have you ever received any money from 19 Mr. Leipold in your life, or Mr. Leipold's firm? 20 A. Yes. 21 Q. When was the last time you received money 22 from Mr. Leipold or his firm? 23 A. A couple of years ago when I was working 24 on the FACT Net case. 25 Q. When was the last time you received money SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 123 1 from any lawyer or law firm with regard to any work 2 that involved Scientology or Scientologists? 3 A. A couple years ago. 4 Q. A couple years ago, approximately when? 5 A. A couple of years ago, two years ago. 6 Q. That's like ?? two years ago is 1997. Is 7 that when it was? 8 A. That's fair enough. 9 Q. And which case did that have to do with, 10 the last time you received any money from any 11 lawyer or law firm with regard to any work that had 12 anything to do with Scientology or Scientologists? 13 A. Maybe two and a half years ago, maybe a 14 little bit longer. It probably would have been the 15 FACT Net case. 16 Q. We'll go into that in more detail later. 17 Probably the FACT Net case. Is there any other 18 case during that period of time, this last period 19 of time, that you would have received money from a 20 lawyer or a law firm? 21 A. No. 22 THE VIDEOGRAPHER: One minute, 23 Mr. Weinberg. 24 MR. WEINBERG: Why don't you change the 25 tape right now? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 124 1 (Recess from 11:22 to 11:25 a.m.) 2 BY MR. WEINBERG: 3 Q. Now, other than the $200 a week, the 4 apartment, various expenses related to the 5 apartment and the car, did you receive anything 6 else directly or indirectly from Mr. Haney and/or 7 his family? 8 A. No. 9 Q. Now, we're in December of 1999 now, and my 10 question is, have you received any other funds, 11 income, money, from anyone in 1999 other than what 12 you've received from Mr. Haney? 13 A. No. 14 Q. Now, you said ?? I'm not quite through 15 with this but you said when I asked you what your 16 address is, you said the state of Washington, I 17 think. Like my first question, where do you live, 18 you said I'm a resident of Washington, is that 19 right? 20 A. Washington state. 21 Q. Okay. Is there an address in Washington 22 state that you're a resident? 23 A. Not right now, just a PO box. 24 Q. And what is that PO box? 25 A. 2698. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 125 1 Q. What city? 2 A. Vashon. 3 Q. And what's the ZIP code? 4 A. 98070. 5 Q. When is the last time you actually lived 6 in Washington? 7 A. Well, I gave you the account of the last 8 time I was there. 9 Q. Right, but I mean ?? I'm not trying to 10 quibble with you but when one says ?? 11 A. I think you are. 12 Q. When one says that they are a resident of 13 the state of Washington, that connotes that one is 14 residing there, at least for some period of time. 15 A. Unless you're a traveller, unless you're 16 an airline pilot. There is many other enterprises 17 in which one may not be at their residence that one 18 can legally claim. 19 Q. When is the last time there was a 20 residence, you know, a structure, whether it's an 21 apartment or a house, that you lived in in 22 Washington? 23 A. I told you I was there some months ago on 24 Vashon. I consider the state of Washington to be 25 my legal residence, and if I want to travel and SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 126 1 move and be in 24 states, I have the total freedom 2 to do that. I don't need to have a quote, 3 residence. 4 Q. No, no. But it's a simple question. What 5 was the last residence that you lived in in 6 Washington, the last structure, the last building? 7 A. Vashon Island. 8 Q. That's ?? but the last structure, what ?? 9 what was the address of it? 10 A. I don't remember the street address 11 because we use the PO Box so much, but there on 12 Vashon Highway. 13 Q. Is this the house that the Mintons bought? 14 A. Yes. 15 Q. All right. Now, when was that house sold? 16 A. I don't know. 17 Q. You didn't have anything to do with it? 18 A. No. 19 Q. You know it's been sold, right? 20 A. I assume so. 21 Q. Well, the last time you were in it was 22 when, approximately? 23 A. Five, six months ago maybe, hard to say. 24 I was there for about a week, maybe six months ago. 25 Q. What were you doing in it six months ago? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 127 1 A. Passing through, wanted to pick up some 2 stuff. I was going to head south to see my son. 3 Q. And you were there for a few hours? 4 A. No, for about a week. 5 Q. And who was there when you were there? 6 A. Stacy. 7 Q. Anyone else? 8 A. No. 9 Q. And that was this year? 10 A. Yes. 11 Q. While you were still working for 12 Mr. Haney? 13 A. It may have been, it may have been. It 14 was either just before or right when we started. 15 Q. Has anybody promised to give you any 16 further funds or support? 17 A. No. 18 Q. Where are you residing now? 19 A. I told you I'm residing with a friend. 20 Q. So you're back in Ohio then? 21 A. Yes. 22 Q. And you are still using the car of 23 Mr. Haney? 24 A. Yes. 25 Q. Is there any ?? any timetable for giving SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 128 1 that back to Mr. Haney? 2 A. I said that before, no, there was nothing 3 set up. 4 Q. Does he pay for the gas? 5 A. No. 6 Q. Where do you get the money to pay for gas 7 and expenses? 8 A. My own personal money. 9 Q. Well, how much of your own personal money 10 do you have? 11 MR. DANDAR: Objection, privileged. He 12 will not answer that question. 13 MR. WEINBERG: And that's privileged 14 because of what? 15 MR. DANDAR: Because it's none of your 16 business how much money he has. 17 MR. WEINBERG: What's the legal 18 objection? 19 MR. DANDAR: It's a privilege, it's 20 privacy, it's privileged. 21 MR. WEINBERG: Is there ?? do you have a 22 problem? Are you trying to ?? 23 MR. DANDAR: Do you not understand the 24 word privileged? That's what I said. That's 25 all I'm going to say. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 129 1 MR. WEINBERG: Are you trying to be 2 sarcastic? 3 MR. DANDAR: No, he's not answering the 4 question. 5 MR. WEINBERG: And the reason he's not 6 answering is because of what privilege? Is it 7 attorney client privilege, is it a work 8 product privilege, what privilege are we 9 talking about? 10 MR. DANDAR: It's his private life. How 11 much money he has is not an appropriate 12 question of an expert witness. 13 MR. WEINBERG: Well, you know what, it is 14 when one is desperate and is looking for funds 15 and will say anything over the years 16 to ?? to make a buck. I think it is, I think 17 it's very relevant and I think we're going to 18 be able to show that in the next two days as 19 to where, you know, what is motivating 20 Mr. Young. 21 MR. DANDAR: Well, you might ask him that 22 question. 23 MR. WEINBERG: But I'm not asking him 24 that question, am I, Ken? 25 MR. DANDAR: He's not answering the SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 130 1 current pending question. 2 BY MR. WEINBERG: 3 Q. Now, do you have any bank accounts now? 4 A. Yes. 5 Q. What kind of an account? 6 A. Checking account and a savings account. 7 Q. And what city are those accounts in? 8 A. In Vashon. 9 Q. In Seattle? 10 A. Yes. I told you I'm a resident of 11 Washington. 12 Q. So those are accounts that you've had for 13 years then? 14 A. Yes. 15 Q. Do you have any accounts in ?? in Ohio 16 where you live? 17 A. In Ohio where I'm staying, no. 18 Q. Now, what work were you doing for 19 Mr. Haney? 20 A. He wanted to create a library of material 21 and asked me if I was able to deal with a large 22 number of documents and I said yeah, it's one of my 23 fortes, so he wanted me to help him with that. 24 Q. What kind of a library? 25 A. It was their library with regard to L. Ron SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 131 1 Hubbard. 2 Q. I mean is there some ?? is this a 3 computer?based library? 4 A. No, it was a hard copy, paper. 5 Q. And all this was in this room in Ohio that 6 you were staying in? 7 A. Yes. 8 Q. So the room was filled with what? 9 A. Well, there was bankers boxes of 10 documents. 11 Q. Where did the documents come from? 12 A. Mr. Haney. 13 Q. Where did he get them? 14 A. I don't know. 15 Q. Well, did you ask him? 16 A. No. 17 Q. What were in the documents? 18 A. It ranged from everything from court cases 19 to newspaper clippings, variety of things. 20 Q. Dating back how far? 21 A. I think I saw some as early as 1950. 22 Q. So it all had to do with Scientology? 23 A. No, I said it all had to do with 24 Mr. Hubbard. 25 Q. And the purpose of this, as explained to SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 132 1 you by Mr. Haney, was what? 2 A. Because this material had ?? that he had 3 collected had been in unusable in the sense of 4 retrievable form, and he would like to get this 5 into a form where he could find something and 6 that's what he wanted me to help with. 7 Q. And so you were acting as a librarian? 8 A. In a sense of the word, yes. 9 Q. Did you put together some sort of 10 retrieval system? 11 A. No. 12 Q. Well, what did you do? 13 A. Well, since some boxes were just piles of 14 papers with no order or rhyme or reason, the idea 15 was to see if one could sort of put them into an 16 order, like put newspaper articles together or put 17 court cases in one file. So the idea was, with any 18 librarian or archivist is that you first see what 19 you've got and then you have to decide what 20 ordering system you want to use with it. 21 Q. So you spent most of your time reading 22 documents then? 23 A. Well, I wouldn't say read in the sense of 24 sit down and read every one. Sometimes you could 25 just look at it and know what it is. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 133 1 Q. Were any of the court cases ones that you 2 had been paid as a ?? as either a witness or a 3 consultant in? 4 A. There ?? I think there was one declaration 5 by somebody from the Mr. Fishman case in Los 6 Angeles but he didn't even have my material there. 7 Q. Did you add material once you were there? 8 A. No. 9 Q. And ?? 10 A. Yes, I'm sorry, I take that back, yes. 11 Q. What did you add while you were there? 12 A. I added the tax exemption papers of 13 Scientology that were on file in Washington, D.C. 14 with the IRS. 15 Q. Where did you get those? 16 A. I went to Washington, D.C. and copied 17 them. 18 Q. When did you go to Washington? 19 A. I don't know the month but it would just 20 be early '99. 21 Q. And who did you go with? 22 A. Nobody, me and my dog. 23 Q. And your dog traveled to Washington with 24 you? 25 A. Yes. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 134 1 Q. Did you drive or fly? 2 A. Drove. 3 Q. And who paid for that trip? 4 A. Mr. Haney. 5 Q. Where did you stay? 6 A. I stayed at the Red Roof. 7 Q. In Washington, D.C.? 8 A. Yes. 9 Q. Was that in Alexandria or something or 10 where? 11 A. No, it was just on the edge of Chinatown. 12 Q. How long were you in Washington? 13 A. Maybe five days, maybe six days, I don't 14 recall. 15 Q. Who did you meet with in Washington? 16 A. Nobody. 17 Q. Did you meet Arnie Lerma while you were in 18 Washington? 19 A. No. 20 Q. Do you know Arnie Lerma? 21 A. I know of Arnie Lerma. 22 Q. Do you know he lives in the area? 23 A. I think he lives in Virginia. 24 Q. Did you talk to him while you were there? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 135 1 Q. Did he make any contact with you while you 2 were there? 3 A. No. 4 Q. Did you communicate with anyone either by 5 phone or fax or computer or in person while you 6 were in Washington that had anything to do with 7 Scientology? 8 A. Sorry to disappoint you but I didn't. 9 Q. Oh, it doesn't disappoint me. I'm just 10 asking the question. 11 A. It disappoints them. 12 Q. Now, did you report on a daily basis to 13 Mr. Haney while you were in Washington? 14 A. No. 15 Q. Did you do any written reports to 16 Mr. Haney? 17 A. No. 18 Q. Did you do any written reports to anyone? 19 A. No. 20 Q. Did you keep notes of what you were doing? 21 A. No. 22 Q. While you were working for Mr. Haney over 23 the six? or seven?month period, did you keep 24 records? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 136 1 Q. Did you maintain notes? 2 A. No. 3 Q. So there is no record of what you've done? 4 A. Well, if you're just alphabetizing a bunch 5 of papers, what you end up is the alphabetized 6 papers. 7 Q. All right. So ?? and so the reason you go 8 to Washington is to do what? 9 A. To get a full and complete copy of their 10 1023 and other tax exemption papers. 11 Q. And what is the 1023? 12 A. It's what an organization files in order 13 to get a tax exemption. 14 Q. And the reason you did that is what? 15 A. Wanted to see what representations they 16 were making, especially in their response to 17 questions from the IRS. And it was an important 18 document to the degree of ?? of the history and 19 development of Hubbard's ideas. 20 Q. Well, what did that have to do with what 21 Mr. Haney was doing? 22 A. That I said I thought there would be some 23 valuable information in those files and ?? and I 24 suggested it. 25 Q. What's that got to do with a library? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 137 1 A. Well, if you're going to have some sort of 2 building library of a complete ?? or try to make a 3 complete library of the development and influence 4 of Hubbard's thoughts, I would say, you know, six 5 feet of documents filed with the federal government 6 making representations as to the nature of your 7 organization and belief system are fairly crucial 8 since it's filed under penalty of perjury. 9 Q. And you're testifying under penalty of 10 perjury today, too, right, you understand? 11 A. Thank you. 12 Q. You understand that? 13 A. I raised my hand and I answered ?? 14 Q. So you understand? 15 A. Yes, I do, thank you. 16 Q. Now, you ?? was this an effort to 17 replicate what FACT Net had done? Is that what 18 this project of ?? that you were helping Mr. Haney 19 on? 20 A. No. I don't even know what that means. 21 Q. Well, you know what FACT Net was? 22 A. Yes, but replicate something, I don't 23 know. 24 Q. Do you understand the word replicate? 25 A. I ?? it was my idea, knew that the 1023s SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 138 1 were there, I phoned into the IRS, they said yes ?? 2 Q. No, no, I'm sorry. What I meant was is 3 the project that you were ?? that Mr. Haney was 4 working on, this library, was this library meant to 5 be basically a replacement or replication or 6 recreation of what FACT Net had done before they 7 went down the tubes? 8 A. No, we never discussed FACT Net. 9 Q. Now, was there some sort of computer 10 element to your work? 11 A. No. 12 Q. What were the computers doing in there? 13 A. Well, whether or not I would ?? I have the 14 option of seeing if there was a database system 15 that you could use for indexing and cataloging, and 16 also used it for e?mail. And I played around with 17 some ideas and decided I really didn't want to play 18 with a computer database, so it turns out the 19 computers really weren't needed. 20 Q. Did you create or did anybody create a 21 database while you were there? 22 A. No. No. 23 Q. Was there one that existed when you got 24 there? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 139 1 Q. Who did you communicate with on e?mail 2 there? 3 A. Well, with Brian or anybody else that 4 might be a friend, you know. 5 Q. Well, who else? Who were some of the 6 people you communicated with on ?? did you 7 communicate with Mr. Prince? 8 A. I might have. 9 Q. Your recollection, did you or didn't you? 10 A. That's the best I can say, sir, I might 11 have. 12 Q. Did you communicate with Mr. Minton? 13 A. No. 14 Q. Why are you sure about that? 15 A. I just know I didn't. 16 Q. Did you communicate with Mr. Dandar by 17 e?mail? 18 A. I don't think so. 19 Q. Did you communicate with Mr. Leipold from 20 there via e?mail or the Internet? 21 A. Maybe, maybe not. It's ?? it's possible 22 but nothing comes to mind. 23 Q. Did you communicate with anyone else that 24 has taken a position, you know, as an 25 exScientologist against Scientology, anyone else? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 140 1 A. No. 2 Q. Now, I'm talking about while you were in 3 this room with these computers that were provided 4 by Mr. Haney. You understood that? 5 A. I understood that. 6 Q. Now, so were you and Mr. Haney attempting 7 to put together information to ?? to defeat the tax 8 exempt status of the Church of Scientology? Is 9 that what you were really about with Mr. Haney? 10 A. No, because I told you there was stuff 11 going back to 1950, which has got nothing to do 12 with it. 13 Q. No, no, that's not my question. My 14 question is ?? 15 A. I heard your question, the answer is no. 16 Q. Excuse me? 17 A. The answer is no. 18 Q. So the ?? you were not receiving money 19 from Mr. Haney or anyone else in 1999 to work on a 20 project to defeat the tax exempt status of 21 Scientology, is that right? 22 A. That is correct. 23 Q. So you went to Washington to get the ?? 24 the tax filings purely to fill out this library? 25 A. To be part of the library. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 141 1 Q. Now, did you have to copy these records? 2 A. Yes. 3 Q. By hand? 4 A. Yes. 5 Q. And how many records did you copy? 6 A. Oh, I don't know, maybe ?? I was there for 7 days. 8 Q. Well, how many days were you there? 9 A. Copying? Four days. 10 Q. And where were you doing this copying? 11 A. In the IRS public ?? it's the FOI office, 12 which is their Freedom Of Information office, where 13 they put out material that is most frequently 14 requested under FOI so they don't have to go back 15 and dig it up and you can just come in and get it. 16 Q. Did ?? was there any particular contact 17 person there that ?? that you dealt with? 18 A. Well, there is a person in charge of the 19 office. I'm not sure what you mean by that. 20 Q. Now, when I asked you about working with 21 regard to the tax exempt status, I want to make 22 sure that we're not playing semantics here. All 23 right? Because semantics seems to be important to 24 you. I want to make sure that when I ask you 25 whether you had anything to do with any effort to SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 142 1 defeat the tax exempt status of Scientology in 2 1999 ?? by that I mean any effort to reverse, to 3 overturn, to do away with the tax exempt status. 4 Did you understand that? 5 A. Yes. 6 Q. Okay. So your answer is no, Vaughn Young 7 had nothing to do with that and was paid nothing 8 for that in 1999, is that right? 9 A. That is correct. 10 Q. Now, was there any particular contact ?? 11 you may have answered this and I've forgotten. Was 12 there any particular contact person at the IRS that 13 you dealt with in this office? 14 A. I said there was somebody at this office. 15 I'm not sure what you mean dealt with. 16 Q. You don't remember a name? 17 A. No, you just walk in and there is somebody 18 at the desk and ?? 19 Q. Do you have to sign in? 20 A. You sign in at the front, at the front 21 door when you enter the building, but you don't 22 sign in at the FOI office. 23 Q. Well, do you have to make a written 24 request for stuff? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 143 1 Q. So what do you do, you just go up and say 2 give me what? 3 A. You walk in and you say where is the blah 4 blah and they show you where in this big room you 5 can find it, and you say okay, and they point out 6 the Xerox machine, the photocopy machine and off 7 you go. 8 Q. How much did you spend in Xeroxing, or 9 should I say how much did Mr. Haney spend in 10 Xeroxing? 11 A. Nothing. 12 Q. So that was gratis as well? 13 A. The IRS doesn't charge for it, if that's 14 what you mean. 15 Q. So they gave you these records free? 16 A. All the FOI records are free. You can go 17 in there and make any copies you want in the FOI 18 room and there is no charge. 19 Q. So ?? so you don't have to pay for copying 20 then, is that right? 21 A. Not me. Nobody pays for the copying as 22 long as you do your own copying. 23 Q. That's what I'm saying. All right. If 24 they do it for you, you have to pay? 25 A. I didn't ask that part. I just know if I SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 144 1 did my own copying ?? 2 Q. How many pages did you copy, 3 approximately? You can do it by inches, by feet, 4 by numbers. 5 A. Couple of linear feet. 6 Q. And what did you do with these records 7 once you copied them? 8 A. Well, if they were distinguishable by 9 organization, I put them into a little binder. And 10 when I was done, I just put them on the shelf. And 11 when I got all done they went back to Mr. ?? with 12 the rest of the material to Mr. Haney. 13 Q. Did you send them to anybody else, copies 14 to anybody else? 15 A. No. 16 Q. Did you give them to Mr. Dandar? 17 A. No. 18 Q. To Mr. Leipold? 19 A. Gave them to nobody else. 20 Q. Now, did you ?? did you do any of your own 21 research in Washington beyond what's in the FOI 22 room? 23 A. No. 24 Q. Do you know what I mean by that? 25 A. Yes. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 145 1 Q. Did you actually go digging for documents? 2 A. No. 3 Q. So you copied whatever they gave you, 4 whatever they brought out, is that the way it 5 works? 6 A. No. 7 Q. How does it work? 8 A. They are on the shelves, you can find it 9 yourself. 10 Q. All right. So they direct you where it is 11 and then you go and go through it. Did you use 12 your discretion? 13 A. Yes. 14 Q. So you didn't copy everything that was 15 there? 16 A. Everything relating to ?? no, there was 17 like magazines that, you know, promotional 18 material, so I had to use some discretion. 19 Q. Did you go anywhere else in Washington or 20 the Washington area to do the work for Mr. Haney? 21 A. No. 22 Q. You didn't go to, for example, the justice 23 department or the FBI or any other government 24 agency? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 146 1 Q. Is that right? 2 A. No. 3 Q. Were you interviewed by anybody while you 4 were there? 5 A. No. 6 Q. Did you meet with anybody while you were 7 there? 8 A. No. 9 Q. So you just stayed in the Red Roof Inn, if 10 that's what it was, and would go and do your 11 copying and go back to the hotel? 12 A. Or go out to dinner. 13 Q. But not with anybody? 14 A. No, just me and my dog. 15 Q. What kind of dog is it, by the way? 16 A. It's a short?haired shepherd. 17 Q. You got your dog with you down here today, 18 too? 19 A. No. His name is McPherson. 20 Q. So he's a ?? you've had the dog for how 21 long? 22 A. A few years. 23 Q. When did you get the dog, approximately? 24 A. Oh, gosh, about four years ago. 25 Q. So 1995 you got the dog? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 147 1 A. Maybe, yeah. 2 Q. And in 1995 when you got the dog you named 3 it McPherson? 4 A. No, the woman that had him before me, she 5 named him McPherson. That was the name he came ?? 6 had when he came from the pound. It wasn't until 7 about a year ago somebody mentioned to me and said, 8 you know, your dog is named McPherson, does that 9 got anything to do with ?? and I said I never even 10 thought about that. 11 Q. All right. So the name has nothing to do 12 with the case? 13 A. Complete coincidence. I always call him 14 Mac anyway. 15 Q. Okay. While you were in this room ?? 16 A. The FOI room? 17 Q. No, in Ohio, the room in Ohio that Mr. ?? 18 that had the computers, that had the bed and the 19 furnishings that Mr. Haney provided for you. 20 A. Okay. 21 Q. Did you do any other work other than this 22 work that you have described as the librarian or 23 the archivist for Mr. Haney? 24 A. No. 25 Q. Were you doing any other work during that SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 148 1 period of time that related to Scientology other 2 than the archivist/librarian work? 3 A. No. 4 Q. Did you work at all during that period of 5 time in any fashion, and when I say that period of 6 time I'm talking about 1999, with Jesse Prince? 7 A. I don't think so. 8 Q. Have you ever worked in any capacity since 9 you left Scientology with Jesse Prince? 10 A. No. I guess this is about as close as 11 it's come. 12 Q. This being what? 13 A. In the same room in a deposition. Usually 14 we just sort of, you know, hang out as good 15 friends. 16 Q. Now, you mentioned a whole bunch of states 17 that ?? in your journey, I guess, in the last 18 however long it's been since you were living ?? 19 physically living in Washington. Other than Ohio, 20 in any of those states that you named, have you 21 spent, you know, any substantial period of time? 22 A. In southern California visiting my son. 23 Q. And a substantial period of time is a few 24 weeks, is that what you're talking about? 25 A. A couple weeks. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 149 1 Q. Okay. But any of those other states, and 2 just to refresh your recollection you said ?? in 3 addition to Ohio you said Kentucky, Iowa, Kansas, 4 Idaho, Wyoming, Colorado, New Mexico, Nevada, 5 Arizona and California. Any of those other states 6 other than Ohio have you spent more than a couple 7 of weeks in since you left Washington? 8 A. No. 9 Q. So is it fair to say that ?? that with 10 regard to those other states, other than Ohio, you 11 were just passing through? 12 A. Loosely, I guess, you know, visiting. I 13 spent about a few days, maybe five days in New 14 Mexico because I thought it was beautiful. 15 Q. You weren't doing work in any of those 16 other states, is that right? 17 A. No, just whether or not I thought it was 18 beautiful, and spent a week in San Diego, you know, 19 visited the beaches. 20 Q. So Nevada, is that like Las Vegas or were 21 you looking at a national park or what are you 22 doing ?? what were you doing there? 23 A. A national park? I don't understand your 24 question. 25 Q. Nevada, were you visiting ?? were you SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 150 1 gambling, were you visiting a national park, what 2 were you doing in Nevada? 3 A. No, passing through, visiting an old 4 friend there. 5 Q. Scientologist? 6 A. Mark Fisher. 7 Q. And how long did you stay with Mr. Fisher? 8 A. I didn't stay with Mr. Fisher. 9 Q. How long did you visit with Mr. Fisher? 10 A. Oh, couple hours, we just went out. 11 Q. That didn't have anything to do with any 12 case then? 13 A. No. 14 Q. Arizona, were you visiting somebody in 15 Arizona or were you just passing through? 16 A. Arizona, I was just passing through. 17 Q. So that's sort of the Grand Canyon thing? 18 A. No, didn't even see the Grand Canyon, just 19 passed through the northern part. 20 Q. New Mexico? 21 A. Santa Fe, it's a pretty area. 22 Q. But not visiting anybody? 23 A. Visited an old friend there that I knew 24 from Seattle, I'm sorry, knew from San Diego. 25 Q. But not a Scientologist? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 151 1 A. No. 2 Q. And just ?? still just visiting, had 3 nothing to do with any case? 4 A. No. 5 Q. How about Colorado? 6 A. Colorado, I ?? one time I stopped and 7 visited Jesse there in Boulder and spent a couple 8 of days there, me and Mac. In fact, that's when 9 I brought my ?? oh, that's when Jack was with me, 10 my cat. I was bringing Jack back with me. That's 11 right. We had Jack there and that was a carful, a 12 dog and a cat and me. I wanted to bring my cat out 13 with me, so we stayed there for a few days and just 14 hung out. 15 Q. And when was that? 16 A. Oh, gosh, eight, nine months ago. 17 Q. So this was while you were staying in 18 Mr. Haney's apartment? 19 A. No, it was just beforehand because I 20 wanted to bring Jack in. I don't ?? I don't 21 remember exactly when. If I got ?? yeah, I think I 22 had set up the apartment and I went off to get 23 Jack, so it would be early '99. 24 Q. This is after you had left Vashon? 25 A. No, no. I said I went back to Vashon and SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 152 1 I still consider myself to be a resident of the 2 state of Washington. I went back to Vashon after 3 that period of time. No, I went ?? that was one of 4 the trips where I wanted to pick up Jack, the cat. 5 Q. You mean you went back to Vashon and 6 picked up your cat? 7 A. Yeah. 8 Q. And then you, the cat and the dog were on 9 the road heading to Ohio and stopped in Denver or 10 Boulder to visit Jesse, is that about how it 11 happened? 12 A. Yeah. 13 Q. And did that have anything to do with any 14 case? 15 A. No, that had to do with getting Jack to 16 Ohio. 17 Q. All right. And were you staying ?? what 18 kind of facility were you staying in in Boulder? 19 A. Stayed at Jesse's place. 20 Q. And was Jesse there by himself? 21 A. I think there was a roommate at that time, 22 some other guy that was renting it. I don't know. 23 Q. This was a house, right? 24 A. Yes. 25 Q. You understood that the house was being SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 153 1 provided to Jesse by either FACT Net or Mr. Minton? 2 A. No. 3 Q. Jesse didn't tell you that? 4 A. No. 5 Q. Jesse tell you whether he was paying rent 6 or not? 7 A. No. 8 Q. Jesse tell you whether he had a job then? 9 A. No. 10 Q. Was Jesse working while you were there? 11 A. I don't know. 12 Q. Well, how long were you there? 13 A. Just a couple of days. 14 Q. Well, was it during the week or was it on 15 the weekend? 16 A. I don't remember. 17 Q. Well, do you remember seeing Jesse do any 18 kind of working for a living while you were there? 19 A. He said he could set aside some time and 20 see me. I told him I was coming in and I said you 21 got some free time? He said hey man, for you I can 22 always set aside some time, come on in. 23 Q. Do you know whether ?? I'm sorry, I didn't 24 mean to interrupt you. 25 A. So he just said come on in so I just came SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 154 1 on in. 2 Q. And y'all partied while you were there? 3 A. I ?? I sort of resent the 4 characterization. We, you know, we went out, we 5 saw Boulder, we walked downtown, we hit some gift 6 shops. I don't know if you would call that 7 partying. 8 Q. Well, was Jesse testifying at any point 9 during this period of time? 10 A. Not that I know of. 11 Q. Did Jesse tell you what ?? what his source 12 of funds were? 13 A. No. 14 Q. Did Jesse tell you that the car he was 15 driving had been given to him by Mr. Minton? 16 A. No. 17 Q. Did you talk to Jesse about Mr. Minton? 18 A. No. 19 Q. Did you tell Jesse what your feelings 20 about Mr. Minton were? 21 A. No. 22 Q. Did you discuss the breakup of your 23 marriage by Mr. Minton with Jesse? 24 A. No. 25 Q. Did you discuss that with him? You knew SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 155 1 that Jesse had been in touch with Mr. Minton, 2 didn't you? 3 A. I didn't ask. 4 Q. Well, you knew that, though, didn't you? 5 A. No. 6 Q. From your own experience you knew that, 7 didn't you? 8 A. I suppose so but that was not the purpose 9 of my and Jesse talking. Jesse and I go back 10 years, we were just personal friends hanging out. 11 Q. Well, we'll get back to Jesse again in due 12 course? 13 A. I'm sure. 14 Q. What about ?? is that the only ?? is that 15 the only time in Colorado that you're talking 16 about? 17 A. Yeah, well, I ?? I passed through one 18 other time, coming or going. I don't know which 19 way. I think I passed through going. 20 Q. This is in '99? 21 A. Yeah. 22 Q. Who did you stay with then? 23 A. I think I ?? I think I stayed at Jesse's 24 twice coming and going. 25 Q. And did he have anybody in his house then? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 156 1 A. No. 2 Q. And you don't know what he was doing for a 3 living, if anything, then? 4 A. No, I just stayed overnight that time. 5 Q. My question is you don't know whether he 6 was doing anything for a living then, is that 7 right? 8 A. That's true. 9 Q. Okay. What about Wyoming? You said 10 Wyoming was one of the places that you had 11 sojourned through in the last ?? since you left 12 Washington. 13 A. Right. 14 Q. What did you do in Wyoming and how long 15 were you there and when were you there? 16 A. Oh, I passed through that I think early 17 '99. Depends if I take the northern route west or 18 if I take the southern route west. I can't 19 remember. I've done it four times. 20 Q. You were driving Mr. Haney's car? 21 A. Yes. 22 Q. And was this just to, again, to see the 23 sights, basically? 24 A. Well, that was, you know, you sort of got 25 to go through Idaho, Wyoming and Utah to get to SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 157 1 Seattle if you take the northern route. 2 Q. Right. But I mean the question was you 3 didn't spend any period of time in Wyoming other 4 than to travel through it? 5 A. No, I didn't even stay overnight in 6 Wyoming. 7 Q. So you didn't see anybody there? 8 A. No. 9 Q. You weren't doing any work there? 10 A. No. 11 Q. What about Idaho, is that the same? 12 A. Yeah. 13 Q. Just passing through? 14 A. Just passing through. 15 Q. What about Iowa? 16 A. I can't get through Iowa fast enough. 17 Q. All right. So you weren't visiting 18 anybody or doing any work there, is that right? 19 A. No. 20 Q. What about Kansas? 21 A. That's even worse than Iowa. 22 Q. So as quick as you could get through 23 Kansas, you were through Kansas? 24 A. It takes forever, nothing there. 25 Q. You weren't visiting anybody there? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 158 1 A. No. 2 Q. And what about Kentucky? 3 A. No, just passing through. 4 Q. Okay. So the only ?? the only real 5 places ?? the only real place that you have stayed 6 for any period of time since you left Washington is 7 Ohio? 8 A. And Washington and California. 9 Q. How ?? when did you actually leave living 10 in Washington, approximately? Is that the summer 11 of '98? 12 A. No, I still consider myself ?? 13 Q. No, but you know what ?? 14 A. No, you're playing with words here that 15 have me leaving Washington. 16 Q. Well, there is not even a house that you 17 have to live in in Washington. 18 A. I don't care how you want to characterize 19 it. I don't need a house to be a resident of 20 Washington if I'm traveling. 21 Q. Are you ?? are you living in your car? 22 A. No. We have gone over this and you're 23 just badgering me about this now. 24 Q. No, I'm not badgering you. 25 A. Yes, you are. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 159 1 Q. No, what you're doing is ?? 2 MR. DANDAR: Stop. Ron. Wait for a 3 question. 4 Q. What you're doing, it's a semantic game 5 here, and what I'm asking you is when was it, when 6 was it in the period of time that you ?? that you 7 left living on a regular basis in a structure in 8 Washington and moved to Ohio, when was that? Was 9 that the summer of '98, is that approximately when 10 it was? 11 MR. DANDAR: Object to the form of the 12 question. Don't answer the question. 13 A. I have not ?? 14 MR. DANDAR: Don't answer it. Stop. It's 15 been five times now. Don't answer that 16 question anymore. 17 THE WITNESS: I know, I know. 18 MR. WEINBERG: Why are you instructing 19 him not to answer that question? 20 MR. DANDAR: Five times is enough. 21 MR. WEINBERG: It's not five times. 22 BY MR. WEINBERG: 23 Q. Just when, approximately? 24 A. I have not moved to ?? you keep trying to 25 get me to admit to moving to Ohio. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 160 1 MR. DANDAR: Stop. 2 Q. I could care less whether you moved or 3 not. I just want to know the date that you went to 4 Ohio. 5 A. I have given you dates. We have covered 6 this several times, sir. 7 Q. Well, I ?? I'm confused now, okay? 8 A. Fine. 9 Q. Do you want to ?? do you want to elucidate 10 or enlighten me as to when it was? 11 MR. DANDAR: Don't answer the question. I 12 agree with you. I'm instructing him not to 13 answer the question. 14 MR. WEINBERG: What you're doing is 15 obstructing the deposition. 16 MR. DANDAR: Then get the judge on the 17 phone. 18 MR. WEINBERG: That's always your 19 response, isn't it, Ken? 20 MR. DANDAR: Very appropriate response. 21 MR. WEINBERG: No, it's not. 22 BY MR. WEINBERG: 23 Q. Where are your life possessions located, 24 if you have any? 25 A. What are life possessions? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 161 1 Q. Well, I don't know. In my house in the 2 attic I've got records, I've got memorabilia, I've 3 got pictures, I've got photo albums, I've got 4 possessions that ?? that relate to my life, and do 5 you have any of those and where are they? 6 A. I have a lot in storage in California. 7 Q. Where your son is then? 8 A. Yeah. 9 Q. Anywhere else? 10 A. I have some stuff with me that ?? 11 Q. You mean in the car as you travel around? 12 A. I resent that. 13 Q. I'm not trying to be ?? 14 A. No, you're characterizing me as living out 15 of a car, thank you. I've got ?? I've got some 16 stuff that was sent to me because I wanted to get 17 my winter clothes, et cetera, because I'm going to 18 be in the winter, some stuff came to me. 19 Q. You mean from Stacy? 20 A. No. From my son. 21 Q. So you mean in this house in Cincinnati 22 you have some stuff, is that what you're saying? 23 A. Yes. 24 Q. Is there anywhere else? Any records, do 25 you have any records? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 162 1 A. I don't even have a CD player. 2 Q. Do you have any documents, records with 3 regard to all your years of testifying? Do you 4 have any of that anywhere? 5 A. No. 6 Q. Where ?? did you ever have any, did you 7 ever keep any? 8 A. Yeah. 9 Q. And where are they now? 10 A. I think most of them were trashed. 11 Q. And the reason they are in the trash is 12 what? 13 A. Well, I just, you know ?? first of all, I 14 like to get rid of a lot of old stuff because they 15 are so bulky. And then when I decided to go on the 16 road, I just wanted to lighten the load and I got 17 rid of a bunch more. I gave some over to Stacy, 18 some of the basic records. 19 Q. What did you give to Stacy? 20 A. Oh, just, you know, like the admin 21 dictionary, the tech dictionaries, you know, the 22 policy volumes. 23 Q. You mean books and things like that? 24 A. Yeah. 25 Q. What about copies of declarations, drafts, SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 163 1 notes with regard to all this work you've ?? we're 2 going to go over that you've done with regard to 3 Scientology cases since 1993? 4 A. I haven't kept it. 5 Q. You got anything on a CD or a disk or a 6 floppy or stored in a computer? 7 A. Nope. 8 Q. Database? 9 A. No. 10 MR. DANDAR: Take a break for lunch? 11 MR. WEINBERG: Yeah. 12 (Recess from 12:03 to 1:16 p.m.) 13 PLEASE REFER to Volume II for further 14 deposition testimony. 15 NOTE: The original and one copy of the 16 foregoing deposition will be held by Mr. Shaw; copy 17 to Mr. Dandar. 18 ARRANGEMENTS for the reading and signing 19 of the deposition transcript will be handled by the 20 office of Mr. Kennan G. Dandar of the firm Dandar & 21 Dandar, 5340 West Kennedy Boulevard, Suite 201, 22 Tampa, Florida. 23 24 25 SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 McPherson v Church of Scientology / 97?01235 164 1 SIGNATURE PAGE 2 Volume I 3 I, ROBERT VAUGHN YOUNG, have read the 4 foregoing deposition given by me on December 21 & 5 22, 1999, in Tampa, Florida, and the following 6 corrections, if any, should be made in the 7 transcript: 8 PAGE LINE CORRECTION AND REASON THEREFOR 9 10 11 12 13 14 15 16 17 18 Subject to the above corrections, if any, 19 my testimony reads as given by me in the foregoing 20 deposition. 21 SIGNED at _________________, Florida, this 22 __________ day of ____________________ , 19___. 23 24 ________________________________ 25 ROBERT VAUGHN YOUNG SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 165 1 CERTIFICATE OF REPORTER OATH 2 3 STATE OF FLORIDA 4 COUNTY OF POLK 5 6 I, the undersigned authority, hereby 7 certify that the witness named herein personally 8 appeared before me and was duly sworn. 9 WITNESS my hand and official seal this 10 24th day of December, 1999. 11 12 13 14 ________________________________ 15 Susan D. Wasilewski, RPR, CRR 16 Notary Public ? State of Florida 17 My Commission Expires: 10?23?03 18 19 20 21 22 23 24 25 SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 166 1 REPORTER'S DEPOSITION CERTIFICATE 2 STATE OF FLORIDA 3 COUNTY OF POLK 4 I, Susan D. Wasilewski, Registered 5 Professional Reporter, Certified Realtime Reporter 6 and Notary Public in and for the State of Florida 7 at large, hereby certify that the witness appeared 8 before me for the taking of the foregoing 9 deposition, and that I was authorized to and did 10 stenographically and electronically report the 11 deposition; and that a review of the transcript was 12 requested; and that the transcript is a true and 13 complete record of my stenographic notes and 14 recordings thereof. 15 I FURTHER CERTIFY that I am neither an 16 attorney nor counsel for the parties to this cause, 17 nor a relative or employee of any attorney or party 18 connected with this litigation, nor am I 19 financially interested in the outcome of this 20 action. 21 DATED THIS 24th day of December, 1999, at 22 Lakeland, Polk County, Florida. 23 _______________________________ 24 Susan D. Wasilewski, RPR, CRR My Commission Expires: 10?23?03 25 Transcript ordered: 12?22?99 SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000