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 IV 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 25 465 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 MR. A. BROADDUS LIVINGSTON 12 Carlton, Fields, Ward, Emmanuel, Smith & Cutler, P.A. 13 Attorneys at Law One Harbour Place 14 Tampa, Florida 33601 15 Counsel for Defendant Janis Johnson: MR. RONALD P. HANES 16 Trombley & Hanes Attorneys at Law 17 707 North Franklin Street, 10th Floor Tampa, Florida 33602 18 Also Present: Mr. Michael Garko 19 Ms. Stacy Brooks Mr. Jesse Prince 20 Mr. Michael Rinder Mr. Marty Rathbun 21 Ms. Lara Cartwright Ms. Wendy Beccaccini (via Internet) 22 23 24 25 SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 466 1 I N D E X 2 Volume IV 3 December 21, 1999 4 WITNESS PAGE 5 Called by the Defendant Church of Scientology Flag 6 Service Orangization: 7 ROBERT VAUGHN YOUNG 8 DIRECT EXAMINATION BY MR. WEINBERG......... 468 9 SIGNATURE PAGE................................. 661 10 CERTIFICATE OF REPORTER OATH................... 662 11 REPORTER'S DEPOSITION CERTIFICATE.............. 663 12 13 EXHIBITS 14 (None) 15 16 17 18 19 20 21 22 23 24 25 SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 467 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 IV 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. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 468 1 VIDEOTAPING SERVICES were provided by 2 Thomas Hallahan and Rick Spector. 3 THEREUPON, the following proceedings were 4 had and taken: 5 ROBERT VAUGHN YOUNG, called as a witness 6 by the Defendant Church of Scientology Flag Service 7 Orangization, having been previously duly sworn, 8 continued to testify as follows: 9 DIRECT EXAMINATION 10 BY MR. WEINBERG: 11 Q. Did you remember anything else, any other 12 topics or details from the eyeball?to?eyeball 13 meeting that you and your ex?wife had with Sergeant 14 Andrews and Mr. Strope? 15 A. No. 16 Q. Did either you or your ex?wife explain in 17 terms that would be understandable to a layperson 18 what the religious concept of isolation was in 19 Scientology? 20 A. First of all, she wasn't my ex?wife. 21 Q. She is now though, right? 22 A. When this meeting occurred. 23 Q. She's your ex?wife now, right? 24 A. Yes, but you're referring to a time at the 25 meeting she was ?? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 469 1 Q. I'm referring to a person who is your 2 ex?wife, correct? 3 A. Now. 4 Q. Right. Now, do you understand my 5 question? 6 A. At the time of the meeting she was my wife 7 and ?? 8 Q. That wasn't my question. My question was 9 at the time of the meeting that you and this person 10 who is now your ex?wife, Stacy, had with the FDLE 11 person and the Clearwater Police detective, police 12 sergeant, did either of you explain to them what 13 the religious belief relating to either isolation 14 or the introspective rundown was? 15 MR. DANDAR: Object to the form. 16 Q. Go ahead. 17 A. No. 18 Q. Well, did you or Stacy refer to the book? 19 A. What book? 20 Q. Refer to the tech as it related to either 21 the Scientology belief concerning isolation and/or 22 introspection rundown? 23 A. I didn't have any ?? we didn't have any 24 materials with us. 25 Q. Did they have ?? did the officers have SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 470 1 materials with them? 2 A. No. 3 Q. From the tech? 4 A. No. 5 Q. Did they ?? did you or Stacy refer to the 6 tech? 7 A. No, just other than the explanation I gave 8 you. 9 Q. Well, that's what I want to go back to. I 10 was under the impression that at some point during 11 the conversation either you or Stacy said that she 12 had more experience with the tech than you did, 13 right? 14 A. Yes. 15 Q. And that was in response to their 16 questions concerning isolation or the introspection 17 rundown, correct? 18 A. Yes. Yes. 19 Q. And what they said is that they wanted to 20 know more about what this Scientology belief was 21 concerning isolation or the introspection rundown, 22 correct, that's what they said? 23 A. I didn't say Scientology believe in. They 24 just asked the question if we had a familiarity 25 with it and could explain it. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 471 1 Q. Right. But they told you that they had 2 looked it up in a book? 3 A. No. 4 Q. Well, when you had your first conversation 5 over the telephone, or the second conversation over 6 the telephone, whichever conversation, you referred 7 them to the books, didn't you? 8 A. Yes. 9 Q. Right. And they said they had the books? 10 A. Yes. 11 Q. And you understood that by the books, this 12 is the scripture, correct? 13 A. I don't call it the scripture. I've never 14 considered it the scripture. 15 Q. Well, let me ask you something. There are 16 many people out there that consider themselves 17 Scientologists, correct? 18 A. Yes. 19 Q. And there are many people out there who 20 consider them Scientologists ?? consider themselves 21 Scientologists that refer to these books as the 22 scripture, correct? 23 A. Some do. 24 Q. Now, these books ?? well, tell me, what 25 book was it that you referred Sergeant Andrews to SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 472 1 with regard to isolation or the introspection 2 rundown? 3 A. It's called the technical ?? the HCOB 4 volumes. 5 Q. And HCOB, just so the record is clear, is 6 what? 7 A. Hubbard Communication Office Bulletin. 8 Q. Okay. And which volume did you refer him 9 to? 10 A. I did not refer to a volume. I just said 11 there is an index, cumulative index that one can 12 look up topics in the volumes. 13 Q. And what did you tell him to look up? 14 A. Whatever he wanted to look up. 15 Q. Well, I'm asking you. Was that isolation 16 and the introspection rundown, is that what you 17 referred him to? 18 A. No. I just said there are the technical 19 volumes and you can look up subjects, because this 20 has been written about and there are bulletins 21 about it. There is also ?? I think I may have also 22 referred to there is also PTS, all caps, PTS, 23 policy letters or policy letters about PTS which 24 would be relevant to it and those are in the green 25 volumes. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 473 1 Q. What are the green volumes? 2 A. Those are the policy volumes, 3 administrative volumes. 4 Q. Did he say he had the green volumes? 5 A. I don't remember him saying that. 6 Q. Now, and you said that they would be 7 related to or relevant to what? 8 A. Introspection and isolation deals with PTS 9 III and there are policy letters regarding PTS III 10 and giving the definitions. The red volumes tell 11 more of how to deal with it. The green volumes 12 pretty much define it in an administrative manner, 13 used as in ethics rather than technical matters. 14 Q. Now, technically, when you say how to deal 15 with it, this is how an auditor or a case 16 supervisor would deal with someone who was 17 psychotic? 18 A. Yes. 19 Q. And this is from materials that were 20 written and published by Mr. Hubbard, is that 21 correct? 22 A. Written and issued by him but published by 23 the volumes were not by him. Those were 24 collections of the issues. 25 Q. And these were collected in volumes that SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 474 1 are kept on shelves by many Scientologists, right? 2 A. They are kept. I don't know how many. 3 It's always been an expensive set. 4 Q. Well, what I mean is that when one is 5 studying either ?? studying what Scientologists 6 refer as the technology, one would refer to these 7 volumes, correct? 8 A. They can, but if I just may interject, 9 when you take courses, they are usually loose 10 issues that are gathered that are pertinent to that 11 subject matter. The volumes are just the 12 collection of pretty much all of them together. 13 Q. Right. 14 A. And so a course might consist of 50, 60 15 issues, whereas the volumes contain hundreds and 16 hundreds. 17 Q. Right. So that I might break out an issue 18 that was in one of these volumes, is what you're 19 saying? 20 A. Only if you took a razor blade to it. 21 Q. Well, I mean I take it there are 22 mimeographs or copies of issues that are in the 23 volumes, right? 24 A. Yes. 25 Q. So that a Scientologist might refer to one SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 475 1 of these volumes with regard to an issue, like 2 psychosis or what Scientologists refer to PTS Type 3 III, much like a Christian might refer to the Bible 4 with regard to a particular issue, correct? 5 A. No. 6 Q. No? So that a ?? let's just say a public 7 member of Scientology, all right, they are entitled 8 to have copies of these volumes, right? 9 A. Yes. 10 Q. Right. And they could put them in their 11 library, correct? 12 A. Yes. 13 Q. They can refer to them any time they want 14 to, right? 15 A. Yes. 16 Q. I can go to a store and buy a Bible if I 17 want to, right? 18 A. Yes. 19 Q. And I can refer to it any time I want to, 20 right? 21 A. Yes. 22 Q. And I can either accept it or reject it as 23 much as I want to and that's one of the wonderful 24 things about this country, right? 25 A. Yes. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 476 1 Q. And as a public Scientologist, you know, I 2 can take those volumes and I can read them on my 3 own and I can do with them what I want to do with 4 them, correct? 5 A. Not really. If do you it wrong, then RTC 6 comes after you. 7 Q. I see. Now, the ?? going back to the 8 conversation, did you explain on the telephone 9 conversation that you had with Sergeant Andrews 10 what PTS Type III was? 11 A. I don't think I said anything more than 12 PTS III is what's called a psychotic break, but 13 nothing more than joining those two concepts in 14 words. 15 Q. Now, in this meeting that you and Stacy 16 had with the two law enforcement officers in 17 Seattle, did you explain to them in terms that a 18 nonScientologist could understand what a PTS Type 19 III was? 20 A. No. It was Stacy that pretty much took 21 that over. 22 Q. I meant the collective you. 23 A. Well, just to clarify it. 24 Q. Okay. Did Stacy explain to them that in 25 Scientology a PTS Type III was a psychotic, SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 477 1 basically? 2 A. She probably used words to that effect. 3 Q. And did she explain to them that in the 4 Scientology religion, that psychiatric treatment or 5 psychiatry was verboten? 6 A. I don't recall the subject of psychiatric 7 coming up. 8 Q. Well, did she explain to the officers or 9 did they ?? did they seem to understand that 10 Scientology had a belief that was contained in the 11 technical volumes as to how to deal with 12 Scientologists that were having psychotic 13 experiences, did they understand that or did y'all 14 explain that to them? 15 A. I'm sorry. That was long. Can you read 16 it to me or shorten it? 17 Q. I'll break it down for you. Did Stacy and 18 can you explain during the ?? during this hour or 19 so conversation with the law enforcement officers, 20 that Scientology had a belief as to how to deal 21 with people that were experiencing psychotic 22 breaks? 23 A. Not in that sense of the word. It seems 24 to parallel it when we described what was done, but 25 I don't know how else to describe it, how SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 478 1 Scientology deals with it. It wasn't in that 2 generic sense. Somebody said, you know, asked what 3 is this, what is PTS III. It's a psychotic break. 4 You don't say Scientology calls it. You just give 5 the definition. 6 Q. Well, you're familiar with the Christian 7 Science religion, is that right? 8 A. Well, I don't know. Ask your questions. 9 Q. Well, you understand that Christian 10 Scientists do not believe in medical treatment, 11 right? 12 A. Yes. 13 Q. And you believe, I take it, that they have 14 a right under the constitution of our United States 15 to practice that belief although you may disagree 16 with it, correct? 17 A. To a point. It's a tough legal issue, I 18 know. 19 Q. Right. But you understand that Christian 20 Scientists believe that physical problems or 21 treatment should be dealt with in their religion 22 spiritually as opposed to going to a doctor and 23 getting some sort of medical treatment, you 24 understand that, right? 25 A. That's what they advocate. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 479 1 Q. And it is correct, is it not, that 2 Scientologists advocate dealing with psychiatric 3 problems spiritually as opposed to going to a 4 psychiatrist or a mental health institute, you 5 understand that too, correct? 6 A. I understand your question but I would say 7 they deal with it with Hubbard's technology, not 8 spiritually, which he describes as an exact 9 science. He never described it as a spiritual 10 process, he described it as an exact scientific 11 process. 12 Q. You understand that in the religion of 13 Scientology, that Scientologists believe that 14 psychiatric issues should be dealt with through the 15 religion as opposed to going to a mental health 16 institute or a psychiatrist, correct? 17 A. No. 18 Q. You don't accept that? 19 A. No. 20 Q. What part of what I just said don't you 21 accept? 22 A. Through the religious. That has only been 23 a recent phenomenon that came up, which I was a 24 direct party to. It has always been through the 25 technology, through the Hubbard standard tech, SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 480 1 those are the phrases that are used. 2 Q. So what you're hanging up on is you don't 3 believe that Scientology is a religion, right? 4 A. No. I said that use of religious practice 5 is a very recent PR description. Internally we 6 always used the phrase we handle this by standard 7 tech, we handle this with on?source materials, we 8 handle this with L. Ron Hubbard technology. 9 Internally you never say we will handle this with a 10 spiritual religious practice. We say handle this 11 with standard tech. 12 Q. All right. Now, you left Scientology in 13 1989, correct? 14 A. Yes. Yes. 15 Q. Lisa McPherson died at the end of 1995, 16 correct? 17 A. Yes. 18 Q. Basically six years later? 19 A. Yes. 20 Q. Well, let's leave the word ?? let's 21 approach it a different way. You agree with me, do 22 you not, sir, that Scientologists believe that 23 mental ?? or that psychiatric, mental, psychotic, 24 psychosis issues should be dealt with through the 25 volumes as written by L. Ron Hubbard about SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 481 1 Scientology as opposed to going to a psychiatrist 2 or a mental health institute, is that right? 3 A. I will agree with that statement. 4 Q. Now, did you or Stacy convey that in 5 layterms that any two blokes could understand to 6 Andrews and Strope in the meeting in Seattle? 7 A. Not perhaps directly as much as implied. 8 For example, I could imagine myself saying this is 9 the way PTS III is handled. 10 Q. By Scientology? 11 A. Well, I just ?? this is the way it's 12 handled. It's sort of an assumed subject that 13 we're dealing with and I can't imagine my saying 14 rather than going to a doctor or something else. 15 This is what PTS tech is and that is what is used. 16 There was no discussion of alternative methods of 17 psychiatry, why wasn't she taken to a psychiatrist, 18 et cetera. 19 Q. Is there anything ?? did L. Ron Hubbard 20 make any mystery of his firm belief that 21 psychiatrists and mental health institutes were a 22 bad thing? 23 A. No. 24 Q. Okay. Is there ?? has Scientology made 25 any mystery of its firm belief that one should not SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 482 1 be treated by psychiatrists, go to psychiatrists, 2 or be committed to mental institutes? 3 A. That is correct. 4 Q. So that the ?? it would not take a 5 detective of any merit that was looking at 6 psychiatry to learn what ?? I'm sorry. It would 7 not take ?? strike that. 8 It would not take a detective of any note 9 who was looking at Scientology to learn that 10 Scientologists and Scientology is firmly opposed to 11 psychiatry, mental health treatment, correct? 12 A. It wouldn't be difficult to find. It's 13 very obvious. 14 Q. Right. I mean Mr. Hubbard wrote dating 15 back to the 1950s about his views of psychiatry, 16 right? 17 A. To 1950, yes. 18 Q. Mr. Hubbard made a very strong statement 19 when he announced his solution to how to deal with 20 the psychotic condition Type III through the 21 introspection rundown, correct? 22 A. I don't know exactly what year that 23 phenomenon came up but various statements were 24 being made from 1950. 25 Q. And it was well?publicized when SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 483 1 Mr. Hubbard discovered the introspection rundown 2 and wrote about it, correct? 3 A. Internally, yes. 4 Q. Yeah, I mean within Scientology? 5 A. Yes. 6 Q. For someone that believes in Scientology 7 and the technology of Scientology, there is 8 probably nothing that would be worse that that 9 person could do than to go to a psychiatrist, 10 correct? 11 A. I'll give you one more notch down. That 12 would be committed to a mental institution. 13 Q. Okay. So, just so I understand you, for a 14 person that believed in Scientology, was committed 15 to what Scientologists call the technology, there 16 would be nothing worse that that person could 17 imagine happening to them than being committed to a 18 mental institute, correct? 19 A. That was the ?? that was pretty much the 20 stance that was taken, but ?? 21 Q. Just answer that question. 22 MR. DANDAR: Wait a minute. Don't 23 interrupt him. 24 Q. No, no, no. Just answer ?? 25 MR. DANDAR: Don't interrupt him. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 484 1 Q. Just answer the question and then you can 2 explain. Am I correct? 3 A. There were Scientologists ?? most 4 Scientologists would subscribe to that, I agree to 5 that. 6 Q. Okay. That's all I'm asking. 7 A. May I then add my other footnote? 8 Tempered by his ultimate statement to make sure we 9 seek proper medical treatment. 10 Q. You just felt it necessary that you needed 11 to say that? 12 A. No. I mean the point is he wrote from 13 1950 that most illnesses are psychosomatics, and 14 then at the same time there was put up in the 15 front, when you came in, seek medical help, et 16 cetera. So there was that ?? that was there too. 17 Q. All right. But we're talking about 18 getting committed to one of those places that gives 19 you psychotropic drugs, would put you in a 20 straightjacket, would maybe do some sort of 21 electric shock or whatever happens in a mental 22 institute. There is nothing that would be more 23 offensive to a Scientologist who believed in 24 Scientology tech than that to happen, would there? 25 A. That's a pretty fair description. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 485 1 Q. Now, did, at this meeting or in these 2 conversations with these law enforcement officers 3 with regard to the Lisa McPherson case, did you or 4 Stacy make it clear to them how strongly people 5 that believe in Scientology felt about psychiatric 6 treatment or being committed to a mental institute? 7 A. No. We weren't ask. 8 Q. Did it appear that the officers were aware 9 in asking you about PTS Type III that there was an 10 issue with regard to psychosis or psychiatry in the 11 Lisa McPherson matter? 12 A. I'm not ?? I don't understand what you 13 mean by an issue in the ?? 14 Q. Well, they are the ones that mentioned to 15 you PTS Type III, right? 16 A. Yes. 17 Q. So they already knew about it? 18 A. Yes, they knew the phrase. 19 Q. Right. Did they tell you how they knew 20 about the phrase? 21 A. No. 22 Q. Did they tell you that they believed that 23 Lisa McPherson was psychotic ?? 24 A. I don't ?? 25 Q. ?? prior to her death? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 486 1 A. I don't remember that being said. We were 2 being asked what we knew about these matters. 3 Q. Did they tell you that they believed that 4 Lisa McPherson would be alive today if she had been 5 committed to a mental institute, did they tell you 6 that? 7 A. No. No. 8 Q. Did they infer or imply that? 9 A. No. 10 Q. Did they tell you how they came to know 11 about PTS Type III? 12 A. No. 13 Q. Did they tell you how they came to know 14 about the introspection rundown? 15 A. No. 16 Q. Did you talk to anybody other than Stacy 17 about your meeting or conversations with these law 18 enforcement officers? 19 A. I don't think so. 20 Q. Did you make any record, you or Stacy make 21 any record of this meeting? 22 A. No. 23 Q. Did you tell Mr. Dandar about the meeting? 24 A. I don't remember telling him about that. 25 Q. Did Stacy? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 487 1 A. I don't think she did. 2 Q. Did you do a report of the meeting? Do 3 you know what I mean by that? 4 A. I don't have anybody I report to. 5 Q. Did you go back and go on your computer or 6 Stacy go on her computer and put notes together, 7 you know, of what you told them and what they told 8 you? 9 A. No. 10 Q. So as far as you know, other than the 11 agents' notes, there is no record of this meeting? 12 A. Yes. 13 Q. Or if the agents did a memo after the 14 fact, but you haven't seen it, is that right? 15 A. I have not seen it. 16 Q. No one sent you a copy to sign off on? 17 A. No. 18 Q. Or Stacy, as far as you know? 19 A. As far as I know. 20 Q. Was Stacy present at all times when you 21 were meeting in this restaurant with these agents? 22 A. Yes. 23 Q. As far as you know, she didn't have any 24 separate meeting or conversations with these 25 officers, is that right? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 488 1 A. That is correct. 2 Q. And you didn't have any separate meetings 3 with them either, is that right? 4 A. That's correct. 5 Q. When they called you the first time, did 6 they ask to speak to you and Stacy or just you? 7 A. I think they just asked for me. 8 Q. And you told them about Stacy? 9 A. I might have mentioned it, that she knows 10 ?? she was not there, as best as I recall, she was 11 not there when I took the call and I might have 12 mentioned that she knows about this, and I think 13 that's probably why I referred them to the volumes 14 rather than saying here, talk to her, she can 15 answer your question better than I can. 16 Q. Put another way, why was Stacy at this 17 meeting? 18 A. Because when they called, she was there 19 and I mentioned to her that they had called and 20 they had asked a technical question and when they 21 said they wanted to meet, I said okay, we'll all 22 meet. 23 Q. Didn't ?? when you talked to these 24 officers, either on the phone or in person, didn't 25 they tell you about their meetings with Lisa SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 489 1 McPherson's family, didn't they tell you about 2 that? 3 A. No. 4 Q. Did they mention Fannie McPherson? 5 A. No. 6 Q. Did they mention Ken Dandar? 7 A. No. 8 Q. Did they mention Dell Liebreich? 9 A. No. 10 Q. Did they mention Ann Carlson? 11 A. No. 12 Q. Do you even know who I'm talking about? 13 A. Not Ann Carlson, I don't. 14 Q. Did they tell you about any investigative 15 work that they had done in the case? 16 A. No. 17 Q. Did they tell you what any witnesses said? 18 A. No. 19 Q. Did they tell you what the Scientology ?? 20 the people at staff had said? 21 A. No. 22 Q. They didn't show you any photographs? 23 A. No. 24 Q. You didn't discuss with them the medical 25 examiner's statements? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 490 1 A. No. 2 Q. You didn't discuss with them the autopsy? 3 A. No. 4 Q. Do you have any better recollection of 5 when the meeting took place? 6 A. No. 7 Q. And you have no further recollection as 8 we're sitting here talking about anything else that 9 Andrews and Strope told you, is that right? 10 A. I remember now there was a remark about, 11 well, we've got some sort of cryptic remark that 12 gave me no information that they were going 13 someplace else that seemed to imply they weren't 14 flying back to Florida, but I ?? it gave me no 15 indication as to what, if they were going to 16 downtown Seattle or where, but just that's the only 17 thing I can remember in addition, they got ?? 18 something to the effect, you know, we've got 19 someplace else to go, almost as if that's why they 20 had to pick up and leave as opposed to us sitting 21 and talking for a couple of hours. 22 Q. Did your then wife do most of the talking 23 during this meeting amongst the two of you? 24 A. Probably. 25 Q. See, what I don't understand, and I don't SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 491 1 think I heard, is that you told me that she put it 2 in layterms, basically, put isolation, 3 introspection rundown, PTS Type III in layterms, 4 right, is that essentially what you said? 5 A. Yes. 6 Q. But what I didn't hear from you is, you 7 know, what that laydescription was. So pretend I'm 8 the officers and you're Stacy. Tell me what it is 9 in a layway that you're trying to communicate, that 10 she communicated to them that day. 11 A. PTS III is called a psychotic break, where 12 basically a person goes crazy ?? and I may be wrong 13 but I don't think that Hubbard uses the word crazy 14 right there, he didn't really like the word ?? can 15 go crazy. She said they could exhibit bizarre 16 behavior, the way this is handled is that the 17 person is isolated, supposed to be kept quiet. I 18 think she may have even cited some sort of 19 familiarity that she had with an incident, but my 20 being not familiar with it, I didn't really attach 21 it with anything, that sometimes light drugs can be 22 used, sedatives, that there is different 23 explanations given for PTS III that ranges from ?? 24 different reasons why it occurs that range from bad 25 auditing to ?? I think she said something like SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 492 1 ethics problems, and that's their phrase, you know, 2 of ethics, which is their way to handle morality. 3 Q. Scientologists' way of handling morality, 4 is that what you mean? 5 A. Well, their, we didn't ?? she didn't ?? I 6 don't think she said Scientology but clearly the 7 reference word is Scientologists, which is the 8 organization, because Scientologists don't do it, 9 it's the organization that does it. The rundown is 10 not one that is done in smaller organizations or by 11 field staff, it's something that's done at 12 organizations. 13 Q. Like Flag? 14 A. We didn't say. We just said, you know, 15 other organizations as opposed to somebody local. 16 That's pretty much it. 17 Q. Did she explain what, in layterms, what 18 the introspection rundown was? You said she 19 explained the concept of isolation and quiet. When 20 you say light drugs, you're not talking about 21 psychotropic drugs, you're talking about something 22 that would help you sleep some, right? 23 A. Yes. 24 Q. You know, other than isolation ?? and you 25 explained what that meant, sort of a quiet setting? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 493 1 A. Well, isolated means kept away from all 2 other people. 3 Q. Right. That in the technology people 4 don't talk to a person that is being isolated, 5 right, did she explain ?? did she get into that 6 kind of detail or not? 7 A. I don't think so. 8 Q. All right. So she explained that, you 9 know, isolation, kept quiet, try to get rest and 10 relaxation basically, right? Did she say something 11 like that? 12 A. Might have. 13 Q. But did she explain then what happens on 14 the rundown? I mean that's what happens first. 15 Did she explain what, you know, sort of thing 16 happens in this introspection rundown? 17 A. Well, that once the person gets to a 18 certain point, then their ?? the introspection 19 rundown comes later. I don't think she got into 20 how it was done as much as there was just a series 21 of steps on it until the person feels better. 22 Q. But did she explain that this is the way 23 Scientologists believe that one should deal with a 24 person who is psychotic rather than send her to a 25 ?? him or her to a psychiatrist to get what SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 494 1 psychiatrists believe how they should deal with a 2 psychotic? 3 A. No. 4 Q. But she did say this is the way 5 Scientologists believe or handled, if that was the 6 word, people that have a psychotic condition, 7 right? 8 A. I don't think she put it in those terms. 9 She just described what the ?? 10 Q. Yeah. 11 A. ?? what the isolation rundown is. I don't 12 think she said Scientology or Scientologists, just, 13 you know ?? 14 Q. All right. All right. And that's pretty 15 much the way she explained it in layterms? 16 A. Yes. 17 Q. Now, have you spoken to Doug Crow? 18 A. Doug Crow? 19 Q. Yeah. 20 A. C?r?o?w? 21 Q. Something like that. 22 A. The name is vaguely familiar. 23 Q. Well, let me put it another way. Have you 24 been in communication with anyone from the State 25 attorney's office or from the prosecutor's office SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 495 1 with regard to the Lisa McPherson matter? 2 A. You will have to forgive me. I don't know 3 Florida structure. Is that different from the 4 State office that the gentleman was with? 5 Q. Yes. These people would be prosecutors 6 who are lawyers who, in this jurisdiction, in the 7 State system, they work out of State attorneys' 8 offices, it's possible somebody from the Florida 9 attorney general's office. And my question is do 10 you remember speaking to any person that referred 11 to themselves as a prosecutor from either the State 12 attorney's office or the attorney general's office? 13 A. No, but the name Doug Crow somehow rings a 14 bell. 15 Q. Bill Burgess, does that ring a bell? 16 A. No. 17 Q. You didn't give any interviews to the 18 State attorney's office? 19 A. I don't recall any. 20 Q. I mean you would recall if you were put 21 under oath and testified with regard to an 22 investigation, correct? 23 A. Yes. 24 Q. And that didn't happen? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 496 1 Q. And as long as you were with Stacy, as far 2 as you know that didn't happen with her either, is 3 that right? 4 A. That's right. 5 Q. Have you spoken to Ray Emmons? 6 A. Yes. 7 Q. And who is Ray Emmons? 8 A. The best of my recall, he's with the 9 Clearwater Police Department. 10 Q. You mean so the last time you talked to 11 him he was in the Clearwater Police Department? 12 A. Hang on. Back up. Back up. I've got it 13 confused with the other cult, sir. I retract that. 14 Q. I move to strike. 15 A. Thank you. I did speak with Ray Emmons, 16 yes, on the phone. 17 Q. And when did Ray Emmons call you? 18 A. Some months back. Oh, sort of seems like 19 five, six months ago, maybe. 20 Q. And where did he call you? 21 A. He reached me I believe it was in 22 Columbus. 23 Q. At the Haney apartment? 24 A. Yes. 25 Q. And who did he say he was? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 497 1 A. He identified himself as working with 2 Mr. Dandar. 3 Q. Why did you say the Clearwater Police 4 Department? 5 A. I was confusing it with, for a second I 6 just lose these names, that there was a ?? the 7 detective that I had met once at a conference who 8 just introduced himself as Clearwater Police 9 Department and there was no conversation. 10 Q. You mean at a conference in the '80s? 11 A. No, in the '90s. 12 Q. What type of conference? 13 A. It was a Cult Awareness Network conference 14 up in Cleveland. 15 Q. Where people from all over the country 16 came and talked about things, is that right? 17 A. Cults, and this gentleman was there, tall 18 gentleman, made himself very prominent, standing 19 out, no ?? et cetera, and somebody I was with 20 introduced me to him, hi, this is ?? I don't even 21 remember the name right now. And he says, oh, 22 Clearwater ?? I was just sort of like, oh, okay, 23 hello. He said, yeah, and I just was surprised 24 that somebody was there. 25 Q. From the Clearwater Police Department? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 498 1 A. Yes, and there was no conversation. I 2 just ?? he didn't ask me any questions, I just 3 moved on. 4 Q. Was that Mr. Emmons? 5 A. I don't ?? I don't think so. 6 Q. Have you ever met Paul Naser? 7 A. I don't ?? I don't ?? 8 Q. Did the guy have a beard? 9 A. No. 10 Q. Do you ever remember talking to Paul 11 Naser? 12 A. The name is vaguely familiar but I don't 13 remember speaking to him. 14 Q. Okay. Let's go back to Emmons. He called 15 you a few months ago in Columbus and asked you 16 what? 17 A. I don't remember because it was a question 18 I couldn't answer and it was ?? the conversation 19 was about a minute and a half and he asked me, he 20 says, hey, you know, do you know anything where I 21 can find ?? any idea how I can find ?? it was like 22 the name of a person. I said no, I really don't. 23 I had no idea why I would be asked that but I 24 didn't recognize the name and he says, okay, well, 25 thanks a lot, and that was the end of that. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 499 1 Q. That's the only time you ever talked to 2 Ray Emmons? 3 A. Yes. 4 Q. How can you remember a one?and?a?half 5 minute or a minute phone call from some guy that 6 you've never talked to before or since, how do you 7 remember that? 8 A. Well, because he mentioned that he worked 9 with Mr. Dandar, and this came out of the blue, and 10 I hadn't spoken with Mr. Dandar for quite a while 11 and this was just, you know, not having spoken with 12 him for quite a while, it was just a reminder that 13 Mr. Dandar was still around. 14 Q. So this was before or after you sat down 15 at your computer and whipped off this computer? 16 A. Oh, way before. This is months before. 17 Q. Do you remember anybody else calling for 18 Mr. Dandar? 19 A. No. 20 Q. Now, do you have any records whatsoever 21 anywhere in the world that would, from ?? that 22 would reflect what you've been doing in the last 23 let's just say seven years? 24 A. That's a huge subject. 25 Q. Yeah. The answer is yes or no. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 500 1 A. Yes. 2 Q. Do you have a diary? 3 A. No. 4 Q. Do you have calendars that show when 5 you've met or scheduled to meet people? 6 A. No. 7 Q. Do you maintain anything on your computer 8 with regard to what you've done and where you've 9 been? 10 A. No. 11 Q. Do you maintain any notes of what you've 12 done and where you've been? 13 A. No. 14 Q. What kind of records do you have 15 indicating what you've done and where you've been 16 in the last two years, say? 17 A. I might have thrown into the corner of a 18 box somewhere, you know, a motel receipt, but I 19 don't keep them. It's more of a case where you 20 sort of empty your pockets and you've sort of got 21 something in your pocket and you just don't throw 22 it away, you throw it down. 23 Q. Well, some people, for example, are 24 slightly more organized than that. 25 A. I hope so. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 501 1 Q. And they have files which show their 2 expenses, files that, you know ?? bank records, 3 phone bills, travel receipts, if you're working for 4 somebody, records detailing, you know, the work 5 you've done. Do you have anything like that? 6 A. No. There has been no need for me to keep 7 those. 8 Q. Well, do you have phone records? 9 A. No. 10 Q. You don't keep phone records? 11 A. No. I use phone cards. 12 Q. So you don't have a phone? 13 A. I had a cell phone but I turned it off and 14 it hasn't been workable for a while. 15 Q. When is the last time you filed an income 16 tax return? 17 A. I'm not sure. I think we filed an 18 extension for last year, which would have been 19 Stacy and mine still jointly, it was an extension 20 on that which still has to be filed. 21 Q. Well, but my question is when is the last 22 time you filed an income tax return? 23 A. It would be the year before that, for '97. 24 Q. So you filed a '97 return in April of '98? 25 A. Possibly, but it would be for the year SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 502 1 1997. 2 Q. And did you file every year prior to that 3 time, after you left Scientology? 4 A. I believe so. 5 Q. Okay. 6 A. We might have had one year with an 7 extension also. 8 Q. You filed a joint return? 9 A. Yes. 10 Q. Now, why did y'all file an extension last 11 year or this year? 12 A. Well, with the divorce and things just 13 sort of in a general upheaval, it was records that 14 you've got to gather and talk to an accountant and 15 it was just easier to file an extension. 16 THE WITNESS: What time is it? 17 MR. DANDAR: Quarter after 2:00. 18 Q. I was under the impression, and maybe I'm 19 wrong because I hadn't done this ever, I don't 20 think, that if you file an extension in April, that 21 you had to file the return by September or October. 22 Isn't that right? But we're in December now. 23 A. Well, you're asking the wrong person. 24 Q. What is your understanding of when you 25 have to file this return? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 503 1 A. Right now I'm going to have to plead 2 ignorance. 3 Q. Well, whose responsibility is it to file 4 this return? 5 A. Well, it's hers and mine jointly. 6 Q. How much ?? well, when you ?? even though 7 you file for an extension, you still have an 8 obligation to pay the taxes due and owing in April, 9 correct? You understand that, don't you? 10 A. Sometimes. I'm sorry. I'm one of those 11 people that seeks the advice of professionals. 12 Q. Well, when you sought the advice of the 13 professional accountant, he didn't tell you, did 14 he, that when you file an extension, you can just 15 defer paying Uncle Sam what you owe him, he didn't 16 tell you that, did he? 17 A. He didn't tell me anything. Stacy was the 18 one that dealt with it. 19 Q. Well, did Stacy tell you that the 20 professional had told her that you could defer 21 paying Uncle Sam by just filing an extension? 22 A. She didn't tell me anything. 23 Q. All right. Well, what is the amount of 24 income that you understand that you and Stacy 25 jointly had in 1998? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 504 1 A. I don't know. 2 Q. Well, what's your estimate of what it is? 3 A. I haven't made an estimate. 4 Q. I'm asking you right here. As we sit here 5 today, what was your income in 1998? 6 A. $10,000, $15,000, I don't know. 7 Q. That includes Stacy, too? 8 A. No. You asked for mine. 9 Q. Well, y'all were married all through 1998, 10 right? 11 A. Yes. 12 Q. So ?? 13 A. Well, no. We actually filed and separated 14 much earlier than that. 15 Q. All right. Well, I thought you said 16 yesterday you didn't get divorced until February of 17 this year. 18 A. I said it was finalized. 19 Q. Well, isn't that ?? when it's finalized, 20 that's when you're actually no longer married, 21 right? 22 A. Legally. 23 Q. Legally. When did you separate? 24 A. Oh, off and on, June or July. It was a 25 couple little times there, back and forth until we SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 505 1 finally decided to do the divorce. 2 Q. And how long had you been married? 3 A. Twenty years. 4 Q. And is there any particular reason why you 5 just didn't file separately, you just filed a 6 separate return for your $15,000 or so in income? 7 A. I didn't ask. I just assumed since there 8 was a period of time of shared income, that we 9 would just go ahead and throw it together rather 10 than trying to figure it out. 11 Q. The shared income is through what, July of 12 1998? 13 A. Oh, probably, June, but joint income, 14 where we would claim it jointly. 15 Q. Now, in that period, the first six or 16 seven months of 1998, your total income between you 17 and Stacy was about $15,000, is that your best 18 guess? 19 A. No, just my income. 20 Q. Well, what was her income while y'all were 21 still together in the first six or seven months of 22 1998? 23 A. This is going to sound very strange but I 24 don't really know. 25 Q. Do you remember that she had a job in the SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 506 1 first six or seven months of 1998? 2 A. Well, mostly it was taking care of the 3 cats. 4 Q. Okay. Well, did y'all pay yourselves 5 salaries from the foundation? 6 A. No. 7 Q. So the foundation ?? so Stacy was not 8 authorized by you or anyone else to take money from 9 the foundation and pay it to herself as income, is 10 that right? 11 A. As income, no. 12 Q. Well, you were what, an officer, a 13 director or what of the foundation? 14 A. Yeah, I'm afraid I was. 15 Q. Well, what do you mean by that? 16 A. Well, I have to plead that I ?? you know, 17 you could find a lot better officers in corporate 18 positions than me. I ?? you're sort of like one of 19 those little locals that are sort of putting 20 together, you're not exactly an entrepreneur with 21 strong legal sense, you're certainly going to learn 22 it after the fact. So because it was her and me 23 basically putting this together, when they said, 24 well, who was going to be the president and vice 25 president, we said, well, how about you? Okay. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 507 1 And how about you? All right. And we sort of 2 threw it together without corporate knowledge and 3 figured we would learn it all a little bit later. 4 Q. Okay. As far as you were concerned, 5 neither you nor Stacy could take money that had 6 been donated to the foundation for the cats and use 7 it for your personal expenditures, correct? 8 A. Once we were nonprofit, yes. 9 Q. Well, if you went to somebody and said 10 I've got these homeless cats that I'm giving a home 11 to and I'd like some help to help the cats, and 12 they gave you whatever, $200, $500, $50, $1,000, 13 neither you nor Stacy were going to take that money 14 and go out to eat with it, were you? 15 A. No. 16 Q. Okay. So that whether you were a 17 nonprofit corporation or not, you weren't going to 18 take, you, and I mean the collective you, you and 19 Stacy, weren't going to take the funds that people 20 had donated to help these animals and use it for 21 some personal expense, for your own pleasure, 22 correct? 23 A. True. 24 Q. Now, and you are, as you sit here today as 25 an officer and a director of that foundation, you SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 508 1 are unaware that there was a single dollar that was 2 donated to the organization that either you or 3 Stacy took and used for yourself, correct? 4 A. First of all, I'm not currently an 5 officer. 6 Q. I'm talking about while you were with 7 Stacy. 8 A. That is true. 9 Q. So let's go back to 1998. Since Stacy 10 wasn't getting a salary from the foundation, can 11 you think of any other job, work, source of funds 12 that would be considered income that Stacy had in 13 the first six or seven months while you were still 14 with her in 1998? 15 A. She might have been doing some 16 consultative work. 17 Q. For whom? 18 A. I don't know. We did get to the point 19 that each of our jobs consulting became quite 20 separated. I just would do mine and not even talk 21 to her. One day she just might say to me, you 22 know, I'm doing such and such and that was news to 23 me. While early on we always worked together as a 24 team, it got to the point that we were working 25 independently. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 509 1 Q. But you can't think of what it might have 2 been in the first six or seven months, right? 3 A. No. 4 Q. And whatever she would have brought in 5 would have gone into your joint account, right? 6 A. Yes. 7 Q. And you would have known about it? 8 A. Not necessarily. She could deposit 9 without my knowing it. 10 Q. Whatever she was doing, it wasn't bringing 11 in a lot of money to the table, was it? 12 A. I don't know what she brought in. 13 Q. Well, you all were in financial 14 desperation by June of 1998, weren't you? 15 A. No. 16 Q. That's right, because Mr. Minton had 17 already given you ?? Mr. and Mrs. Minton had 18 already given you a house to live in, right? 19 A. No. 20 Q. Can you tell us how much rent you paid to 21 Mr. and Mrs. Minton? 22 A. Nothing. 23 Q. Ever? 24 A. No. 25 Q. Who paid the electric bills? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 510 1 A. We did. 2 Q. Was there gas or electric, what was it? 3 A. I think there was gas and electric. 4 Q. What else did Mr. Minton, Mr. and 5 Mrs. Minton pay for? 6 A. I don't know. I know what we would pay 7 for. 8 Q. Well, I mean do you know of anything else 9 that they paid for ?? 10 A. No. 11 Q. ?? while you were there? 12 A. No. 13 Q. What was the ?? where did the $15,000 come 14 from that you sort of guesstimated in the first six 15 months of 1998, which case was that? 16 A. As I said, left over from the FACT Net. 17 Q. I guess what confuses me, we can go over 18 it in detail, but in FACT Net that you testified 19 under oath that you were paid from approximately ?? 20 you and Stacy together as a team were paid from 21 approximately November of '96 until March or so of 22 '97 $5,000 a month and at that point the funds ran 23 dry. Do you remember testifying to that? 24 A. No, I don't but I won't contest it. 25 Q. You wouldn't dispute it? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 511 1 A. No need to dispute it. 2 Q. All right. And if I am right, can you 3 think of any other consultive, if that's a word ?? 4 A. That's okay. 5 Q. ?? work that you would have been doing 6 where you would have gotten any money in 1998? I'm 7 saying ?? this is all relating to Scientology, 8 right? 9 A. Yes. 10 Q. Can you think of anything else, sir? 11 A. No, and I don't remember when Mr. Dandar's 12 check for a couple of thousand came in. I remember 13 it was quite after that I worked for him in '97. 14 Q. It didn't amount to $15,000 though, did 15 it? 16 A. No. I'm just trying to think of 17 something. I can't think of anything else. 18 Q. All right. Now, have you been in touch 19 with Alex Soroka, S?o?r?o?k?a, or something like 20 that? 21 A. Yes. 22 Q. And who is that? 23 A. He's a man who lives in Southern 24 California. 25 Q. And when were you in touch with him last, SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 512 1 approximately? 2 A. I believe it was when I was out in 3 Southern California, back when I was visiting my 4 son. 5 Q. So that would be what, within the last 6 couple of months? 7 A. Well, I'll try to say yes on that one for 8 the moment, yeah. 9 Q. Okay. And what documents did you get from 10 him? 11 A. Nothing. It was just purely a social 12 visit. 13 Q. So you didn't discuss Scientology with 14 him? 15 A. No. 16 Q. In the last three years have you discussed 17 Scientology with him? In the last three years have 18 you had any dealings with him? And I'm not talking 19 social, I'm talking with regard to Scientology. 20 A. Yes. 21 Q. And have you gotten documents from him or 22 made copies from documents that he had? 23 A. Yes. 24 Q. And what documents have you gotten from 25 him? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 513 1 A. They were documents I obtained from him in 2 Los Angeles with regard to the FACT Net case that 3 were ?? the nature of the documents weren't by 4 subject or date. They were documents showing ?? 5 regarding copyright notices on the documents. That 6 was the criteria I was working by because there was 7 a copyright issue at hand in the FACT Net case. 8 Q. And he's a former Scientologist? 9 A. Yes. 10 Q. And he had some original documents or 11 what? 12 A. Yes. 13 Q. And he gave you the originals or copies? 14 A. He loaned them to me so I could make color 15 photocopies. 16 Q. Were these some of the upper level 17 materials? 18 A. No. 19 Q. You understand what I mean by that, right? 20 A. Yes. 21 Q. Is that the only time that you've made 22 copies of documents or received documents from him? 23 A. Yes. 24 Q. And you took the documents and gave them 25 to Mr. Leipold? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 514 1 A. No. I'm trying to remember the name of 2 the firm in Los Angeles that I was working out of, 3 where all the boxes of exhibits were. For the life 4 of me, I can't remember the name of the firm there. 5 Q. Okay. How many trips have you made to 6 Tampa?Clearwater in this case? 7 A. In this case? 8 Q. Yes. 9 A. This is my first. 10 Q. And we established yesterday, I guess, 11 that you hadn't been to Clearwater/Tampa for more 12 than ten years before this trip today, is that 13 right, or yesterday? 14 A. Yes. 15 Q. Okay. Have you looked at the PC folders 16 of ?? well ?? strike that. 17 You know what a PC folder is right? 18 A. Yes. 19 Q. Have you looked at the PC folder or 20 folders of Lisa McPherson or copies of documents 21 from the PC folders? 22 A. No. 23 MR. DANDAR: Do you need a break? 24 THE WITNESS: Yeah, I'd like to ?? 25 MR. WEINBERG: Yeah, let's take a break. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 515 1 It's a little stuffy in here. 2 (Recess from 2:40 to 2:56 p.m.) 3 BY MR. WEINBERG: 4 Q. Ready? 5 A. (Witness nodding head.) 6 Q. Has Stacy indicated to you what her income 7 was after y'all split up in 1998? 8 A. No. 9 Q. And after you split up in 1998, what was 10 the amount of your income, if any? 11 A. I don't think there was anything. 12 Q. So your best estimate of what your income 13 was for tax purposes in 1998 was $15,000? 14 A. Best I can do right now, yes. 15 Q. Did anybody make any gifts to you and/or 16 Stacy as far as you know of cash or funds, stocks 17 or securities, anything of value in 1998? 18 A. Not that I know of. 19 Q. And you didn't get any inheritances in 20 1998 other than possibly your mom's $1,000, right? 21 A. That's correct. 22 Q. Now, after y'all were discharged from 23 bankruptcy and you were able to discharge your 24 credit card debts in 1995, did you or Stacy have 25 credit cards? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 516 1 A. No. 2 Q. So you ?? whatever you bought, you bought 3 either with cash or by check from your accounts, is 4 that right? 5 A. Yes. 6 Q. When you left ?? well, you separated from 7 Stacy in what, the middle of 1998, right? 8 A. Yes. 9 Q. Was that what one calls a legal 10 separation, was there some legal document that was 11 filed? 12 A. No. 13 Q. Is there a divorce lawyer that you or 14 Stacy used with regard to either the separation or 15 the divorce? 16 A. For the divorce. 17 Q. And is it one or more than one lawyer? 18 A. I believe it was just one. 19 Q. And what's the name of this lawyer? 20 A. I don't know. 21 Q. Where is this lawyer? 22 A. In Seattle. 23 Q. And who secured the lawyer? 24 A. Stacy did. 25 Q. So is the lawyer Stacy's lawyer or your SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 517 1 lawyer? 2 A. Stacy's lawyer. 3 Q. So you didn't have a lawyer? 4 A. No. 5 Q. Was it a contested divorce? 6 A. No. 7 Q. Was there something filed? 8 A. Well, there is the ?? whatever you call 9 the divorce papers that are filed. There was 10 something that I signed which I remember showing as 11 uncontested. 12 Q. Well, did she sue you? 13 A. No. 14 Q. Usually there is a legal proceeding that 15 is initiated by either one spouse or the other by 16 way of some complaint. 17 A. I only said no because I didn't understand 18 the word because it was uncontested, so I'm not 19 quite sure of the legal term. When I say it's 20 uncontested, it was something we both mutually 21 agreed to and it was stated so in the divorce 22 papers. 23 Q. Well, did the lawyer communicate with you 24 in advance, I'm talking about Stacy's lawyer? 25 A. In advance of what? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 518 1 Q. In advance of whatever they filed? 2 A. Yes. I mean we met and I was shown the 3 papers that she had drawn up and I signed them. 4 Q. She being ?? so the lawyer was a woman? 5 A. Yes. 6 Q. So you, Stacy and the lawyer met in the 7 lawyer's office? 8 A. Yes. 9 Q. And had the papers already been drawn up 10 at that point? 11 A. Yes. 12 Q. Who asked whom for a divorce? 13 A. Well, I think if I remember right, Stacy's 14 name was at the top and when I saw it I said I want 15 to make it clear in the text that just because your 16 name is at the top and it's your attorney, I wanted 17 wording added to show that this was clearly 18 uncontested, there was no dispute and it was 19 mutually agreed upon and so there was nobody ?? 20 boy, that's loud. 21 Q. Yeah, but it's cool. I'm talking about 22 the air conditioning, by the way. 23 A. And it was explained to me, well, 24 somebody's name has got to come first and I guess 25 that's what you possibly are referring to, but I SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 519 1 wanted to make sure in the wording of the papers 2 that it was very clear that just because someone 3 took that position, it was required by law and had 4 nothing to do with our attitude. 5 Q. Well, what I'm really asking you is, I'm 6 not really asking about who filed what first but 7 was it you or was it Stacy that initiated the idea 8 of getting a divorce? 9 A. It was mutual. 10 (Telephone interruption.) 11 MR. WEINBERG: Hold on a second. 12 (Discussion off the record.) 13 BY MR. WEINBERG: 14 Q. Was it ?? I think you just said that it 15 was a mutual decision to get a divorce, is that 16 right? 17 A. Yes. 18 Q. And the divorce was as a result of Stacy's 19 relationship with Bob Minton? 20 A. No. 21 Q. Had nothing to do with it? 22 A. No. 23 Q. Stacy was having a relationship with Bob 24 Minton prior to you getting divorced, correct? 25 A. Yes. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 520 1 Q. And you learned about that? 2 A. Yes. 3 Q. And how did you learn about that? 4 A. She told me. 5 Q. And when did she tell you? 6 A. Early '98, somewhere in there. 7 Q. So a few months after Mr. Minton ?? or the 8 Mintons had purchased the $250,000 house, is that 9 right? 10 A. That's about right. 11 Q. And what did she tell you? 12 A. We had separated before, several years 13 before and ?? in Southern California and we had 14 been struggling with this for years and we had 15 hoped that something like the sanctuary could be 16 used as some sort of mutual effort and it wasn't ?? 17 it wasn't working. And as I said, it had been 18 rocky for years. So it was ?? it was a mutually 19 hard decision after 20 but the one agreement we had 20 always had from day one was any time either one of 21 us wants to step away, just tell the other and we 22 can step away. 23 Q. Right. And that really wasn't what I was 24 asking you and I really wasn't concerned or prying 25 into your previous ?? you know, what the status of SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 521 1 your relationship was over 20 years. What I had 2 asked you was I think you had said that she told 3 you that she was having a relationship with Bob 4 Minton, and what I was asking you is what did she 5 say about that. I'm not talking about 20 years, 6 I'm just, you know ?? how did it come up or what 7 did she say about Bob Minton? 8 A. She just said that she thought he was a 9 great guy, she was falling in love with him, and my 10 remark back to her was I told you that months ago. 11 Q. Told you what months ago? 12 A. That you were falling in love with him. 13 It wasn't a matter of jealousy on my part, it was a 14 matter of open honesty, and we talked about it, 15 that really what it amounted to was it was more a 16 case of our marriage having been born in a very 17 bizarre environment and situation, had been 18 struggling ever since '89, upon leaving, back and 19 forth in, quote, the real world, and it had just 20 finally was just coming, you know, coming to an end 21 and we had seen this coming for five years. 22 Q. Well, let's just talk about Minton because 23 I'm really not interested in the status of your 24 relationship prior to Bob Minton. All right? 25 A. But that's what we discussed and that was SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 522 1 how it came to that conclusion. 2 Q. All right. The ?? Mr. Minton comes into 3 your life by phoning you, right? 4 A. Yes. 5 Q. As far as you know, he had had no previous 6 contact with your wife, is that right? 7 A. Yes. 8 Q. You essentially rejected his calls two or 9 three times, right? 10 A. Yes. 11 Q. And eventually you took his call and told 12 him that you had this cat problem and he said how 13 can I help, correct? 14 A. No. He already knew about the cat problem 15 from the Internet posting. 16 Q. You confirmed that you had a cat problem? 17 A. Yes. 18 Q. And he said how can I help and he told you 19 at that point that he was willing to buy a house, 20 he and his wife were willing to buy a house where 21 you could take the cats and get away from the cat 22 authorities in Seattle, right? 23 A. Basically, yes. 24 Q. Okay. And we didn't go into this 25 yesterday because I intended to get back to it. At SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 523 1 that point he authorized you and Stacy to go out 2 and find a house, is that right, to go house shop? 3 A. Yes. 4 Q. And so you and Stacy had already ?? were 5 already familiar with Vashon Island and, among 6 other places, went to Vashon Island to house shop, 7 is that right? 8 A. Only Vashon. 9 Q. Only Vashon Island? 10 A. No. I take that back. We did go south 11 out of Seattle. I take that back. We did go south 12 out of Seattle and then focused in on Vashon. 13 Q. Did you use a real estate agent to help 14 you house shop? 15 A. At first no, and then on Vashon we did. 16 Q. And who did you use? 17 A. I don't remember. 18 Q. Where are they located? 19 A. On Vashon. 20 Q. What company were they? 21 A. I don't remember. 22 Q. Are there lots of real estate agents on 23 Vashon? 24 A. No. There is not even traffic signals on 25 Vashon. It's very small. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 524 1 Q. So the chances are that you used the one 2 and only real estate agent on Vashon? 3 A. Probably one of three or four. 4 Q. Okay. And is this a woman or a man? 5 A. She was a woman but there was a company, 6 there were several desks. 7 Q. A national company or a local company? 8 A. Just local to Vashon. 9 Q. Okay. And you asked her for help, you and 10 Stacy asked her for help and told her what you were 11 looking for? 12 A. Yeah. 13 Q. Did you give her a price range? 14 A. No, because we had already learned the 15 range on Vashon and it was more a case of giving 16 her the requirements as far as land, space, why we 17 needed it, be nice to have a barn, it would be this 18 and that, so it was more the specifications. 19 Q. Did you have a ?? what's the word? Did 20 you have a limit from Mr. Minton as to what price 21 range you could locate a house in? 22 A. I wasn't given one. 23 Q. Well, did you understand from Stacy that 24 Mr. Minton had said that you could spend a certain 25 amount of money for a house? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 525 1 A. No, I didn't understand that. 2 Q. Well, I mean were y'all looking at $50,000 3 houses, $100,000 houses, $150,000 houses or million 4 dollar houses? 5 A. There is no million dollar houses on 6 Vashon unless you buy 1,000 acres. The price 7 ranges we saw that we were familiar with on Vashon 8 with any property at all, and we needed at least an 9 acre, tended to be in the range of $150,000 to 10 $300,000. So we knew ?? that was already the 11 category. 12 Q. And that had been communicated, as far as 13 you understand, to Mr. Minton? 14 A. Not by me. 15 Q. I said as far as you understood that had 16 been communicated to Mr. Minton by Stacy, right? 17 A. I don't know. 18 Q. Well, let me ask you something. Before 19 you could realistically go out and find a house 20 that somebody else was going to buy, unless you 21 were prepared to waste a whole lot of time, you 22 would have had to have some price range in mind, 23 right? 24 A. Well, it was a price range of Vashon. As 25 I said, she carried on the conversations because I SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 526 1 just didn't want to deal with it. 2 Q. I understand. But I assume if the price 3 range for Vashon is from 150 to 300, that you 4 wouldn't have been over there unless Stacy had a 5 pretty good idea that that was in Mr. Minton's 6 price range, right? 7 MR. DANDAR: Objection; that's 8 speculative. 9 Q. Is that right? 10 A. I don't know. 11 Q. Is that right? 12 A. I don't know. 13 Q. All right. Well, is it your want and her 14 want, Stacy's want to waste a lot of time? I mean 15 are y'all that kind of people? 16 A. I don't know understand the question. 17 Q. Let's go to the next question. In any 18 event, Stacy was carrying on conversations with 19 Mr. Minton, is that right? 20 A. Yes. 21 Q. Was he talking to Mrs. Minton, was she 22 talking to Mrs. Minton? 23 A. I don't know. 24 Q. Did you ever talk to Mrs. Minton? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 527 1 Q. As far as you know, did she ever talk to 2 Mr. Minton ?? Mrs. Minton? I'm sorry. 3 A. I don't know. 4 Q. And you're not suggesting that as of this 5 point in time, where y'all had been authorized to 6 find a house, that Stacy had fallen in love with 7 Mr. Minton, right, you're not saying that, are you? 8 A. I'm sorry. I lost the question. 9 Q. You said that you had told Stacy a long 10 time before she told you that she was in love with 11 Bob Minton that she was already in love with Bob 12 Minton, you had already told her that, you said, 13 right? 14 A. Somewhere, yes. 15 Q. All right. I take it that's somewhere ?? 16 that's sometime after the Mintons bought the house 17 that you were living in, is that right? 18 A. Yes. 19 Q. Okay. Now, at this point in time, when 20 y'all are out looking, house shopping, neither of 21 you had ever met Bob Minton, correct? 22 A. Yes. 23 Q. So y'all go to this island and how many 24 days do you look for a house, how long does it take 25 you to find the dream house? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 528 1 A. Well, as I said, we had already made 2 several trips there. There had already been 3 several weekends prior, just prior to that, and 4 when I say just prior, I mean by a matter of a week 5 or two ?? 6 Q. Excuse me a second. 7 MR. WEINBERG: Ken, it's very distracting. 8 Stacy is at the end looking directly at 9 Vaughn. It's very distracting. She needs to 10 take a seat or go outside, one or the other. 11 All right. I insist that she take a seat at 12 the table like everybody else or she go 13 outside. 14 (Ms. Young left the room.) 15 MR. DANDAR: That distracts you? She's 16 at the coffee table. 17 MR. WEINBERG: She is looking directly at 18 the witness. It is distracting. It is 19 obstructive. Okay. She has gone out. That 20 is fine. 21 A. I wasn't looking at her. 22 Q. Well, you know what, Mr. Young, I'm sorry, 23 but if you're in this room, then one needs to be 24 seated unless they go up and get a drink. She's 25 been there for ?? you know, I didn't say anything SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 529 1 at first but she's been up there for a number of 2 minutes. 3 MR. DANDAR: It's the same as you walking 4 to get coffee ?? 5 MR. WEINBERG: No, it's not. 6 MR. DANDAR: ?? as you ask him a question, 7 you walk away from him to get a cup of coffee. 8 MR. WEINBERG: No, it's not. She's been 9 up there five or ten minutes, Ken. 10 MR. DANDAR: Who cares? 11 MR. WEINBERG: I care. I care. Okay? 12 She couldn't do that in a courtroom and she 13 shouldn't do it in the depo. 14 MR. DANDAR: She certainly could. She 15 certainly could. 16 MR. WEINBERG: She could stand up in the 17 middle of a courtroom and look at the witness? 18 MR. DANDAR: She's out of range of 19 everybody. 20 MR. WEINBERG: No, she isn't. 21 BY MR. WEINBERG: 22 Q. Now, Mr. Young ?? 23 A. Uh?huh. 24 Q. ?? how many days did you look for this 25 house? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 530 1 A. We probably spent four days beforehand and 2 then three or four other trips to Vashon 3 afterwards, and the delineating line being after 4 his call. 5 Q. Okay. And how many houses did you look 6 at, would you say? 7 A. Thirty. 8 Q. Okay. How many with the agent, or were 9 they all with the agent? 10 A. No. There was the first half of that, and 11 I think the first visit to Vashon, were all done 12 without an agent, and then somebody that we spoke 13 to said, listen, you know, this is a very small 14 island and the agents know everybody on the island, 15 and having never worked with an agent, I hadn't 16 really thought about it that much. So somebody 17 recommended this one agent and so we went there, 18 and that was for the last few excursions. 19 Q. And this house that was eventually bought, 20 was shown to you by the agent? 21 A. Yes. 22 Q. And the 30 houses were in the price range 23 of between 150 and 300? 24 A. I don't know the prices of all of them 25 because some of them you just go out there to see SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 531 1 them and you don't care if it's $50,000, it's just 2 ?? it's a piece of rundown junk. Did you get that? 3 Q. Yes. Eventually ?? did you make offers on 4 how many houses? 5 A. Just on that one. 6 Q. And you made the offer, is that the way it 7 worked? 8 A. No. Stacy picked it up at that point. 9 When we both agreed that this was an ideal 10 condition ?? there is not that much property 11 available on Vashon, so it wasn't a case of being 12 able to, I don't know, look for a long list of 13 places that would be capable of carrying a cat 14 sanctuary. 15 Q. Here's what I really mean. Was there a 16 negotiation that you and Stacy or Stacy had with 17 the seller? 18 A. I was not party to that. All I was party 19 to was I like this place, I agree, the property 20 looks good, it can be developed for this purpose, I 21 agree, take it over. 22 Q. Now, do you know if Stacy handled the 23 negotiations or somebody else did? I mean 24 typically what happens when you buy a house is you 25 make an offer. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 532 1 A. I don't know how it was done. 2 Q. Okay. You don't know if Stacy had 3 Mr. Minton's authorization to do that or not? 4 A. I don't know. 5 Q. Do you know if y'all paid asking price or 6 something less than what was being asked? 7 A. I don't know. 8 Q. Did you, after Stacy told you that she was 9 in love with Bob Minton, did you speak to Bob 10 Minton about that? 11 A. No. 12 Q. I mean you must have been angry. 13 A. Well, every breakup of a marriage ?? 14 Q. That's what I mean. 15 A. ?? hurts. 16 Q. I mean it made you ?? it made you 17 obviously unhappy, correct? 18 A. Yeah. 19 Q. It made you depressed? 20 A. That's too clinical for me. Unhappy is 21 enough. 22 Q. Well, did you express to your friends or 23 some friend that you had suicidal thoughts? 24 A. I ?? I've never been suicidal. 25 Q. Did you threaten that to Stacy? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 533 1 A. No. 2 Q. You never had any conversation with 3 Mr. Minton after ?? at any point in time about his 4 relationship with ?? his relationship with your 5 wife? 6 A. There was a conversation on the phones 7 several months later, after we had decided months 8 after on the divorce. 9 Q. Before or after you were divorced? 10 A. Before the divorce was filed. 11 Q. Between you and Mr. Minton? 12 A. Yes. 13 Q. He called you or you called him? 14 A. He called me. 15 MR. DANDAR: Can we get Mr. Rinder to quit 16 going in and out of the door? I mean how 17 destructive and disruptive is that, and 18 Mr. Rathbun. 19 MR. WEINBERG: Just stop. You're being 20 destructive and disruptive. 21 MR. DANDAR: Well, I think the sound will 22 pick up all the doors opening and closing. 23 MR. WEINBERG: Just stop, just stop, Ken. 24 All you're doing is disrupting this. It's in 25 the middle of his answer. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 534 1 MR. DANDAR: Yeah, right. 2 MR. WEINBERG: Yeah, right? It's what 3 you're doing. 4 MR. DANDAR: He's disrupting. 5 MR. WEINBERG: No, you're disrupting. 6 MR. DANDAR: He keeps distracting me 7 every time he comes in and out of the door. 8 It must be five times already. 9 MR. WEINBERG: You are being, as you 10 always are in these depositions, being 11 disruptive and destructive. 12 MR. DANDAR: I can't wait until we get to 13 the Lisa McPherson case. 14 MR. WEINBERG: I don't know, I thought 15 since Mr. Minton has given you $400,000, has 16 given your consultants hundreds of thousands 17 of dollars, I sort of thought that's what we 18 were talking about, Ken. 19 MR. DANDAR: No. We're talking about a 20 divorce. 21 MR. WEINBERG: No. What we're talking 22 about is people that have been paid and 23 bought. 24 MR. DANDAR: By the way ?? 25 MR. WEINBERG: Okay. Paid and bought. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 535 1 MR. DANDAR: ?? you failed to instruct 2 the witness at the beginning this entire 3 deposition is confidential and I want to know 4 who the hell is at the other end of this 5 Livenote because those people are subject to 6 this court's jurisdiction. 7 MR. WEINBERG: You heard ?? you heard 8 what Mr. ?? what Judge Moody said about 9 confidentiality. All right? So let's ?? 10 MR. DANDAR: This entire deposition is 11 confidential. 12 MR. WEINBERG: Oh, baloney. You heard 13 what Judge Moody said about that, and what 14 you're trying to do is keep ?? what you're 15 trying to do is your people, like Mr. Prince 16 and Stacy, go on the Internet and talk about 17 all this stuff, and then what you want to do 18 is when somebody comes, when one of your 19 people come in here and testify under oath, 20 you don't want anybody to know about that, do 21 you? Why not? 22 BY MR. WEINBERG: 23 Q. Now, Mr. Young ?? 24 A. Uh?huh. 25 Q. You had a conversation because you called SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 536 1 Mr. Minton, is that right? 2 A. No. I said he called me. 3 Q. He called you and he said what, I'm sorry 4 that I broke up your marriage? 5 A. No. He just said, hey, listen, you know, 6 sorry sort of the way things turned out, I never 7 really meant it, never meant that it would happen 8 that way. 9 Q. So that made you feel better? 10 A. Well, it was a matter between Stacy and me 11 and I just was like okay. 12 Q. Do you think he ?? I'm sorry. 13 A. I'm not in a position to bless or damn, 14 you know, anybody for their personal life, 15 especially Stacy, on that. So, okay, if it made 16 him feel better to tell me, that's what made him 17 feel better. 18 Q. Do you think Mr. Minton was as charitable 19 with his own wife? 20 A. I have no idea. 21 Q. All right. 22 MR. WEINBERG: Now, you know what, Ken, I 23 can hear you talking and I can hear Mr. Prince 24 talking. 25 Q. Now, did you have a financial settlement SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 537 1 with Stacy? Was there a settlement agreement? 2 A. I have a feeling that's a legal term, so 3 can we maybe break it down. 4 Q. Okay. When one goes through a divorce, 5 when one is divorced ?? there were divorce papers, 6 right? 7 A. Right, and that listed out what we ?? 8 Q. Your assets? 9 A. What she was taking, what I was taking, et 10 cetera. 11 Q. Do you have a copy of that? 12 A. No. 13 Q. Okay. And what were the amount of the 14 assets at the beginning of this year that you and 15 Stacy were dividing up? 16 A. Oh, I don't even remember. 17 Q. Well, give me an estimate. 18 A. I have no idea. 19 Q. Well, are we talking a million dollars? 20 A. If you want to be facetious, you know, I 21 feel like saying why not. Let's not be ridiculous. 22 I said I don't know. I was more interested in 23 being amicable and settling it out, you know. I 24 just said, God, do we really want to ?? because at 25 one point the attorney says ?? was getting into one SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 538 1 of these things, well, the couch goes to, and we're 2 saying no, no, it's not that kind of divorce, we 3 will work out, hey, honey, do you want the TV set 4 or do I take the computer. It was a case of 5 working out between friends. We didn't need to 6 list out every single item as to who gets the baby 7 crib. 8 Q. Right. I guess, you know, without being 9 ?? I'm not trying to be facetious. 10 A. When you say a million dollars ?? 11 Q. Well, I tried to start somewhere. You're 12 obviously much more charitable than I would have 13 been under those similar circumstances, but what 14 I'm asking you is was there any substantial assets 15 in this relationship at the time of the divorce? 16 A. No, not that I ?? not that comes to my 17 mind. 18 Q. Okay. Y'all didn't own any property, 19 correct? 20 A. No. 21 Q. You didn't own a house, right? 22 A. No. 23 Q. You didn't have any funds, any stocks or 24 securities, right? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 539 1 Q. Didn't have any bonds? 2 A. No. 3 Q. Did you have any cash in any accounts? 4 A. Oh, there was a few thousand dollars or so 5 in the checking accounts. 6 Q. So a couple thousand dollars? 7 A. Probably. I didn't really know at the 8 time. I'm just sort of guessing. 9 Q. Well, I mean any ?? what did y'all do, 10 split that? 11 A. It wasn't a matter ?? this may sound 12 strange to you, sort of like me doing a declaration 13 on my own initiative, but our attitude was, you 14 know, what do you need in order to help yourself 15 out, you know, even after the divorce papers, if it 16 said she got the computers and I wanted one, there 17 was not going to be any argument, you know: I'm 18 going to take off. Oh, well, how much money do you 19 need? Well, give me a couple thousand to ?? it was 20 that sort of, you know, between friends ?? 21 Q. Well, let me interrupt for a second. I 22 mean Stacy, obviously, through her relationship 23 with a multimillionaire, was not going to be 24 looking for where the next buck was coming from, 25 correct? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 540 1 A. I resent your accusation to me. 2 Q. Well, I'm asking you. I mean did you 3 understand that Mr. Minton was going to provide for 4 her? 5 A. No. 6 Q. Isn't that what your understanding was? 7 A. No. 8 Q. Well, was there ?? did you receive any 9 cash in the settlement? 10 A. Other than ours? 11 Q. I'm talking about ?? well, we'll start 12 with that. Other than yours? 13 A. There was just our cash. 14 Q. And that was a few thousand dollars, 15 right? 16 A. Perhaps so. I didn't pay attention to it. 17 Q. Well, was it as much as $20,000? 18 A. No. 19 Q. Okay. Was it as much as $10,000? 20 A. I don't know. 21 Q. Well ?? 22 A. I said a few. I wasn't paying attention. 23 And there was a point in July when I took off to go 24 see Jesse and she had the bank account then, and 25 later on she said, here, you can have the rest of SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 541 1 the bank account. 2 Q. She gave you the rest of the bank account? 3 A. Yeah. 4 Q. And how much was that, approximately? 5 A. I think there was a few thousand in it 6 then. 7 Q. And when you say a few, you mean a couple? 8 A. A few is like three or so. 9 Q. Okay. 10 A. More. 11 Q. Now, other than the bank account, was 12 there anything else of any real value that was 13 divided up? I'm talking about monetary value, I'm 14 not talking about memory value. 15 A. Well, the computers, we had the computers, 16 which have always been our most valuable. 17 Q. Those were the old computers, right? 18 A. Yeah. We had picked up another one along 19 the way. 20 Q. Did y'all divide those up? 21 A. Well, I just took the laptop because I 22 wanted to travel and there was no reason to take a 23 desktop with me, so I just took what I needed. She 24 asked me if I wanted to have a PC and I said, you 25 know, I can't really carry it with me so I will SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 542 1 just take the laptop. 2 Q. Anything else? There was no car was 3 there? 4 A. No, not at that time. There was a car 5 that belonged to the foundation. 6 Q. What happened to that? 7 A. It stayed with the foundation, stayed 8 there. 9 Q. That's the one ?? the old van or whatever 10 it was that somebody donated to the foundation? 11 A. Yes. Yes. 12 Q. Where is that now? 13 A. I assume it's with the foundation. I 14 don't know. 15 Q. So that is it a fair statement that as of 16 February of 1999, the total value of the assets 17 that y'all had accumulated was in the single digit 18 thousands? 19 A. I don't know if there was value put on the 20 assets with the divorce. 21 Q. I understand. I'm not trying to argue 22 with you. I'm just trying to get some sense. It's 23 not a lot of money, it's not a lot of value, is it? 24 A. A lot is always, I've found, to be quite 25 relative. I don't know what the computers would be SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 543 1 worth at that point. 2 Q. All right. I will go through it with you 3 then. I was trying to make this easy. 4 A. The computers were what, $12,000 five 5 years before. 6 Q. Well, the laptop certainly wasn't worth in 7 1999 more than ?? I mean you can go buy a laptop 8 right now for what, 1200 bucks? 9 A. No. This laptop was pretty cheap. 10 Q. Okay. So we're not talking about, you 11 know, thousands and thousands of dollars worth of 12 personal property, right? 13 A. Perhaps. 14 Q. Well, did you sell any of it? 15 A. I didn't. 16 Q. Did you take any of it? 17 A. I took the laptop and put some things in 18 storage that I wanted to keep, which is more along 19 the line of personal memorabilia. 20 Q. And what other assets, personal property 21 was there? 22 A. There was furniture. 23 Q. That had been there for a number of years? 24 A. No. There was furniture that we had 25 either brought from West Seattle or had bought SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 544 1 while there. 2 Q. You mean like dining room furniture? 3 A. There was a dining room table we bought 4 because we didn't have one in West Seattle. There 5 was a bed frame that we had bought to switch the 6 bed around. There was ?? what are they called, the 7 things where you open the doors? 8 Q. You got me. 9 THE WITNESS: What? 10 MR. DANDAR: Armoire. 11 A. Armoire. I always have trouble with 12 that, which she kept her computer in that we had to 13 assemble, a couple little pieces of art that we 14 picked up on Vashon, small, that we enjoyed, not 15 expensive, small things. 16 Q. Jewelry, any jewelry? 17 A. No. That's one good thing about her, she 18 wasn't ever into jewelry. 19 Q. And that's pretty much it, what we've just 20 gone through? 21 A. Yeah, pretty much. 22 Q. And where is that stuff now, do you know? 23 A. I don't know. 24 Q. And you just, at that point in time, 25 whenever it was, in June or July of '98, moved out? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 545 1 A. No, not really. As I said, I went back to 2 see Jesse and I hadn't had plans on the moving out 3 point and I went back later on. It was only much 4 later that I started ?? I went back one time to 5 pack up my stuff, to put away what I wanted to keep 6 because I was, at that point, deciding to move out. 7 Q. Where does Stacy live now? 8 A. I don't know. 9 Q. You don't know that she lives ?? do you 10 know that she lives in a dwelling that is provided 11 for her by Mr. Minton? 12 A. No. 13 MR. DANDAR: Can we take a little break. 14 I need to make a phone call? 15 MR. WEINBERG: Real quick. 16 (Recess from 3:30 until 3:37 p.m.) 17 BY MR. WEINBERG: 18 Q. When did you actually move out of the 19 house that Minton bought? 20 A. Well, first of all ?? 21 Q. Hold on. I had agreed to Mr. Young to 22 open these doors if no one has an objection. 23 MR. DANDAR: Yeah, let's do that. 24 Q. If we start getting noise, then we'll 25 shut them. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 546 1 MR. DANDAR: I think we're the only ones 2 up here. 3 Q. Okay. The question was when did you 4 actually move out of the house that the Mintons 5 bought? 6 A. That the Mintons bought. 7 MR. DANDAR: I think that's understood 8 now, so go ahead. 9 A. Probably July. 10 Q. Of '98? 11 A. Of '99, when I took my last ?? got my 12 stuff to be packed up and go. 13 Q. Well, I guess I was thinking the answer 14 might be a little easier and I was hoping I would 15 get to the finish line a little quicker. There 16 comes a point in time when you learn that your wife 17 is having an affair with this guy who has provided 18 a bunch of money to you and your wife, correct? 19 A. I don't understand that. He didn't 20 provide money to me. 21 Q. That's right. You testified you didn't 22 know about the $50,000, right? 23 A. Yes. 24 Q. Okay. I'll rephrase the question. There 25 comes a point in time when you learn that your wife SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 547 1 is having an affair with a person who was part of 2 providing a $250,000 house for your wife and the 3 cats and you, correct? 4 A. Yes. 5 Q. At some point before you took the 6 furnishings out of the house, you effectively moved 7 out of that house, after learning about the affair, 8 right? 9 A. I didn't get furnishings. I did not move 10 the furnishings. 11 Q. I'm really trying to do this, you know, 12 trying to do this as quickly as possible but it's 13 difficult. There comes a point in time after Stacy 14 tells you I'm in love with another man that you 15 take off from the Vashon property, correct? 16 MR. DANDAR: Object to the form. 17 A. Yeah, I don't like the word take off. 18 Q. I'm not asking you whether you like it or 19 not but do you understand what I mean? 20 A. Can I say something that might explain it? 21 Q. No. Let me just, you know ?? the way this 22 works, I ask questions and you give answers and if 23 you don't understand it, then I'll ask another 24 question until I get an answer to it. 25 A. Excuse me. Is there any ice back there? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 548 1 Q. Apparently not. I was looking myself. 2 A. Okay. 3 MR. DANDAR: There is ice down the 4 hallway. 5 MR. GARKO: I'll see if I can get some. 6 Q. You learned about the affair ?? strike 7 that. 8 You suspected that Stacy was having an 9 affair with Mr. Minton before she told you, right? 10 A. No. I just suspected that they were 11 falling in love with each other. 12 Q. And that was based on what? 13 A. Just her attitude, telephone 14 conversations. I know her very well. 15 Q. Well, how many times did Mr. Minton visit 16 your home in Vashon Island? 17 A. Just one. 18 Q. And when was that? 19 A. I don't remember. It was a couple of 20 months maybe, after we moved in. 21 Q. Was it before or after your wife told you 22 that she had fallen in love with him? 23 A. Before. 24 Q. And what was the purpose of his visit to 25 Washington? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 549 1 A. He wanted to see the property that he and 2 his wife had bought. 3 Q. Did he bring his wife with him? 4 A. No. 5 Q. And did you meet ?? you met with 6 Mr. Minton at that point? 7 A. Yes. 8 Q. Did he stay in your house? 9 A. Yes. 10 Q. How many nights? 11 A. Just one night. No, wait. He didn't stay 12 in the house. He was staying ?? I take that ?? 13 yeah, he stayed someplace else. I'm sorry. 14 Because we had this place downstairs that guests 15 would stay but you had to sleep with about nine 16 cats. He stayed at one of the few sort of bed and 17 breakfast places on Vashon. 18 Q. How many days was he there? 19 A. Just the one day. 20 Q. Did you talk about the Lisa McPherson 21 case? 22 A. No. 23 Q. Not at all? 24 A. Not at all. 25 Q. Did you talk about his ?? the money that SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 550 1 he had provided to people that were connected with 2 Scientology or Scientology cases? 3 A. No, not at all. 4 Q. Did you talk about ?? did you talk with 5 him about how much more money or things that he 6 might provide for you? 7 A. No. 8 Q. Did he ask you, I'm talking about you, the 9 collective you, did he ask the collective you what 10 else you might need from him other than a $250,000 11 house? 12 A. No. He inspected the property and was 13 trying to decide what else might be needed to have 14 the property in proper shape. Every time you ?? 15 because, you know, we had signed this thing about 16 the roof and he wanted to see it, if ?? there's a 17 little creek down there that runs, a seasonal creek 18 that runs, but there was nothing particularly 19 specified other than a few little maintenance 20 things. 21 Q. Did he write any checks to you? 22 A. No. 23 Q. Did he give you any cash? 24 A. No. 25 Q. I'm talking about the collective you now. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 551 1 A. Yes. 2 Q. Did you talk to his wife while he was out 3 there? 4 A. No. 5 Q. Did you talk to his wife while he was out 6 there? 7 A. That's what I thought I was answering. 8 No, I didn't. 9 Q. Right. Did he spend any time alone with 10 Stacy while he was out there? 11 A. Not that I know of. I was with her all 12 the time and he came in and visited during the day 13 and left. 14 Q. So it was not during this visit that you 15 got the feeling that there was something going on 16 between Bob Minton and Stacy, right? 17 A. That's right. 18 Q. So it was something that happened after 19 this one visit? 20 A. Yes. 21 Q. Well, did Stacy visit Mr. Minton in New 22 Hampshire? 23 A. I don't know. She made a number of trips 24 as I was making trips and she would tell me where 25 she'd be and what her phone number would be but she SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 552 1 was doing her own work as she had done for quite a 2 while. 3 Q. Work in what, what case? 4 A. She ?? I don't really know what cases she 5 would be working on or who she would be meeting 6 with. As I said, that was her own life. I know 7 she met with some parents. She told me about one. 8 She met with some parents back East who flew her 9 back who wanted to know about Scientology. Well, 10 that's really not my bailiwick, so I just said, 11 okay, well, how was it? Oh, it went good. 12 Q. That's what she told you? 13 A. Yeah. 14 Q. And did she tell you that she was visiting 15 with Bob Minton on any of her trips? 16 A. A couple of times that she had seen 17 Minton, yes. 18 Q. And did she say what the circumstances or 19 the occasion was for seeing Minton? 20 MR. WEINBERG: This is what I was 21 concerned about. 22 MR. DANDAR: I think they are talking 23 about our air conditioning problem. 24 (The question was read by the reporter.) 25 A. I know one was some sort of conference. I SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 553 1 don't remember the name of it, whether it be AFF or 2 a parents' conference, something else. I frankly 3 wasn't interested enough to ask for details. 4 Q. Well, did she tell you that she was 5 participating in protesting or picketing with 6 Mr. Minton? 7 A. No. 8 Q. Did she tell you that she was 9 participating in any picketing or protesting 10 against Scientology? 11 A. No. 12 Q. You haven't done anything like that, have 13 you? 14 A. No. 15 Q. And had you known your wife to do anything 16 like that? 17 A. Had I known? 18 Q. Uh?huh. 19 A. I just answered I did not know she was 20 doing it. 21 Q. Well, I mean in the past, you know, from 22 1989 until you split up with her, is this something 23 that you were aware that your wife was doing, 24 protesting or picketing against Scientology? 25 A. Not that I know of. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 554 1 Q. Did you talk to her every day when she was 2 gone? 3 A. Pretty regular. I managed to always speak 4 to her on a trip and sometimes if the trip is just 5 a couple of days, there would be no reason, but if 6 she was gone for three or four days, I would hear 7 from her. She would usually call in to, you 8 know ?? 9 Q. But you would never quite know where she 10 was then? 11 A. I always had a phone number to reach her 12 if it was more than just an overnight trip. 13 Q. Were any of the numbers in the East? 14 A. Some were in the East, some were in the 15 South and some were in Southern California. 16 Q. Were any in New Hampshire? 17 A. I'm sorry. I don't ?? I just get area 18 codes and I don't even look them up. I just dial 19 them. 20 Q. Do you remember the area codes? 21 A. No. 22 Q. Did you know where Mr. Minton lived? 23 A. Somewhere in New Hampshire. 24 Q. Did you ever go to his house? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 555 1 Q. Do you know whether Stacy went to his 2 house while you were married with him? 3 A. No. 4 Q. With her. I'm sorry. Do you know? 5 A. No. 6 Q. Now, other than the visit that you had 7 with Mr. Minton, and the early communications with 8 regard to the house and locating the house, what 9 other ?? and this one conversation where he called 10 you about the affair, what other conversations or 11 communications do you remember having with Bob 12 Minton? 13 A. I think it was in June of this year. 14 Q. That's '99, right? 15 A. Yes. 16 Q. Tell me about that. 17 A. We phoned up and said, hey, I heard you 18 had a heart attack and, you know, sorry to hear 19 about that, and I said okay, thanks, and, you know, 20 basically just hope you do okay, thanks, that was 21 the end of that. 22 Q. Called you where? 23 A. Well, that would have been in Columbus. 24 Q. At Haney's apartment? 25 A. Yes. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 556 1 Q. How long was the conversation? 2 A. Couple of minutes. 3 Q. Did he ask you whether you needed some 4 money? 5 A. No. 6 Q. Did you talk about his relationship with 7 Stacy? 8 A. No. The entirety of the call was just I 9 heard you had a heart attack, I hope you're doing 10 well, good luck, how is it going, fine, thanks, 11 nothing more than like a telephonic get well card. 12 Q. Well, are you aware that Mr. Minton has 13 bought a $250,000 house for Stacy to live in on 14 Bellaire Beach, are you aware of anything like 15 that? 16 A. No. I don't even know what Bellaire Beach 17 is. 18 Q. I'm just asking you. Or Bellaire or 19 anyplace? 20 A. No. 21 Q. Are you ?? well, Stacy told you that she's 22 still seeing Bob Minton? 23 A. No. 24 Q. Well, do you know what the status of the 25 relationship between Stacy and Bob Minton is as we SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 557 1 sit here today? 2 A. No. We haven't discussed it. 3 Q. Do you know what Stacy ?? you don't even 4 know where Stacy is living now, she hasn't told you 5 that? 6 A. No. I didn't even have a phone number 7 until last night when I, you know, wanted to see if 8 she was going to be here tomorrow and I asked Jesse 9 for the phone number. 10 Q. So Jesse has her phone number then? 11 A. Yeah, he gave it to me. 12 Q. How much money, if any, has ?? did you 13 receive from Bob Minton? 14 A. I have answered that extensively 15 yesterday. 16 Q. Is the answer none? 17 A. None. 18 Q. How much money has Stacy received, as far 19 as you know, from Bob Minton? 20 A. I don't know. 21 Q. Do you know whether she's received any 22 money from Bob Minton? 23 A. You've shown me two checks and that's ?? 24 Q. I've shown you three checks. 25 A. Well, there was one to the Friends of the SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 558 1 Animals Foundation. 2 Q. Which you didn't know about, right? 3 A. That I don't ?? other than what you showed 4 me, I don't know. 5 Q. Well, when Stacy ?? how many trips are you 6 aware of that Stacy took from Seattle during this 7 period of time after you moved into the house that 8 the Mintons bought? 9 A. Five, six. 10 Q. All right. And when she would take the 11 trips, did she fly? 12 A. Yes. 13 Q. And did y'all have money to pay for that? 14 A. No. 15 Q. Who paid for that? 16 A. Well, I know on a couple of occasions that 17 she remarked upon that she was meeting with people 18 they paid for the trip. Like this one family that 19 she was going to meet with that I don't remember, 20 just somewhere ?? somewhere East, South, that she 21 said the family was paying for it and putting her 22 up in a hotel, that they wanted to meet with her 23 for a day or two, because they had a daughter in 24 Scientology and they wanted to understand it. I 25 said, oh, that's cool, I hope it's a nice hotel. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 559 1 She said, yeah, it's nice. 2 Q. Did she tell you that Mr. Minton joined 3 her on that trip? 4 A. No. 5 Q. Did she tell you that Mr. Minton was 6 paying for some of her trips? 7 A. No. 8 Q. Did you understand that Mr. Minton was 9 paying for some of her trips? 10 A. No. 11 Q. Did you understand that some of her trips 12 were to see Mr. Minton? 13 A. No. 14 Q. But you understood that she saw Mr. Minton 15 on some of her trips? 16 A. Yes. 17 Q. And you know that you and Stacy didn't 18 have the money to pay for these trips yourself, is 19 that right? 20 A. Yes. I made this trip and I didn't pay 21 for it. 22 THE WITNESS: Oh, ice. Thank you. 23 Q. How long ?? do you have a recollection as 24 to how many days Stacy was away during this period 25 of time on trips? I mean are we talking about a SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 560 1 total of 30 days or 45 days? I mean what are we 2 talking about here? 3 A. I don't think the trips ever lasted more 4 than maybe four days and if I average them out as 5 three, four and say six, we're talking maybe 24 6 days over a number of months. That's just sort of 7 my multiplying out an average. 8 Q. So that the expenses that Stacy would have 9 on these trips to feed herself and pay for hotels 10 if there were hotels would be money that would be 11 provided to her by someone else, you just don't 12 know who, is that right? 13 A. Yes. 14 Q. Now, in the ?? I think I asked you, 15 obviously, this was not a happy time for you, when 16 you learned about what we've been talking about 17 concerning the state of your marriage, is that 18 right? 19 A. Yes, because it followed just a couple of 20 months after the loss of my mother, which was a 21 very severe, a very severe loss. 22 Q. Because you were close to your mom? 23 A. Yeah. 24 Q. Okay. Did you, as a result of the 25 combination of your mom and the breakup of your SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 561 1 marriage by Mr. Minton, did you ?? 2 A. No, that is not a characteristic I'll 3 accept. The problem is my mom died of cancer and 4 I've got cancer, so it's ?? 5 MR. DANDAR: Well, let's take a break. 6 MR. WEINBERG: No, we don't need to take 7 a break. 8 A. I'm ?? it's okay. 9 MR. DANDAR: Are you all right? 10 MR. WEINBERG: We don't need to take a 11 break. 12 A. I just resent your characterization 13 following the death of my mom. 14 Q. Well, the ?? I didn't characterize 15 anything with regard to the death of your mom. 16 A. You said the breakup of my marriage by 17 Minton after the death of my mom. Please don't 18 string those together, Mr. Weinberg. 19 Q. No. What I said ?? 20 A. Ask your question. Just ask your 21 question. 22 Q. I think that you were telling us that 23 there were a couple of events in your life that 24 caused you to be in a lot of distress, one of which 25 would be your mom's death, which would distress SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 562 1 anyone, and the other of which was the breakup of 2 your marriage, which would distress anyone. So 3 what I'm asking is the combination of those events, 4 did it cause you to ?? did it cause you to have a 5 drinking problem? 6 A. It wasn't the breakup of the marriage. It 7 was the loss of the sanctuary because I was 8 losing ?? I was losing something that I was hoping 9 was going to take me out of the cult work and work 10 on the cats. And she's had her life all of her 11 life, and we agreed from day one, and if she wanted 12 to take off, that was fine, but, you know, a lot of 13 work had gone into the sanctuary, we had talked 14 about it for a long time, and it was the loss of 15 the sanctuary and that's why I had to leave. It 16 wasn't ?? you know, I could go back, I could go 17 back and see her. I can talk to her. She's a good 18 friend. 19 Q. Well, why wouldn't you stay and do the 20 sanctuary? 21 A. Because it was just, you know ?? it's kind 22 of a personal thing. We had started it together in 23 this house in West Seattle and we had fought the 24 fucking, God damn organization to keep the cats 25 alive. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 563 1 THE WITNESS: You sons of bitches. 2 Q. All right. Now, let me ask you 3 something ?? 4 A. And so you sort of bond together to 5 protect these cats, you know. You saved a lot of 6 lives and then you get a place where you think you 7 can do something. We talked about bringing 8 together artists and cats and there was an art 9 gallery straight across the way, and I guess it was 10 the loss of the sanctuary. As far as us, shit, 11 she's my best friend. If she wants to take off and 12 do whatever she wants, all she has to do is ?? 13 she's always had that freedom. 14 Q. All right. Now, as far ?? 15 A. The God damn cult keeps shoving this in, 16 that somebody else broke up my marriage. Nobody 17 broke up my marriage but us. 18 Q. So Mr. Minton has no responsibility for 19 this distress? 20 A. No. 21 Q. All right. You don't hold him accountable 22 whatsoever, is that right? 23 A. No. Well, except that, you know, he ?? if 24 it wasn't for the God damn organization harassing 25 us, he wouldn't have shown up, you know. It was SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 564 1 almost like they gave us the God damn house on 2 Vashon. He wouldn't even have shown up if it 3 wasn't for that. And if he hadn't shown up, then I 4 wouldn't have lost ?? lost the chance. It's an odd 5 combination. 6 Q. All right. Now, as far as the cats are 7 concerned, is there a particular reason why you 8 weren't the one that stayed in the house with the 9 cats as opposed to Stacy? 10 A. Well, she was the one that really 11 initiated it. I remember the time I came back from 12 a trip to West Seattle, she came back ?? we only 13 had about five cats. And I said, now, Stacy, don't 14 take any more in. I came back and she had this 15 funny smile and she says we have 10 more cats. And 16 that was when we crossed the line. There was these 17 little kittens that we put into the bathroom. And 18 I remember that moment. I was thinking I think 19 we're in a different line of enterprise right now. 20 So it was always her initiative. She was 21 the one that met with people, she was the one that 22 organized and she was the one that did the street 23 fairs and talked to people, and she was really good 24 to talk to people and bring them in and bring in 25 volunteers. She could ?? I never got a single SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 565 1 volunteer. She's the one that got the volunteers. 2 So she was such a ?? 3 Q. All right. As far as the cats are 4 concerned ?? 5 A. ?? such an impetus. 6 Q. Where are the cats as we speak right now? 7 A. She worked for a long time ?? 8 Q. I'm just asking where are the cats? 9 A. They were given to different homes over a 10 period of months. 11 Q. By whom? 12 A. By Stacy. 13 Q. All right. So they have ?? are they at 14 animal shelters, is that where they are? 15 A. No. We never ?? we would never give them 16 to animal shelters. We were recusing them from 17 animal shelters. 18 Q. All right. Now, and the reason you had to 19 move to Vashon Island was because neighbors and 20 people where you were living in West Seattle 21 complained to the authorities about you having a 22 bunch of animals running around, right? 23 A. Totally false. We had neighbors out there 24 supporting us. Every neighbor in the neighborhood 25 did it. It was anonymous calls, cell phone calls, SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 566 1 anonymous letters. 2 Q. Did the authorities come out? 3 A. Absolutely. 4 Q. From where? 5 A. From Seattle. 6 Q. But from what bureau? 7 A. Animal control came out. 8 Q. And was that a Scientologist? 9 A. No. 10 Q. Who else came out? 11 A. Zoning came out. 12 Q. Was that a Scientologist? 13 A. Nope. 14 Q. Who else came out? 15 A. Social workers wanting to know whether or 16 not she was mentally unstable. They had an 17 anonymous call, there was this mentally unstable 18 woman in this house. 19 Q. Now, was the social worker a 20 Scientologist? 21 A. No. Are you very ignorant on how this 22 organization works, Mr. ?? 23 Q. Excuse me. Answer my questions. Was the 24 social worker a Scientologist? 25 A. To tell you the truth, I don't know to all SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 567 1 those answers. I don't know what their belief 2 system was, to tell you the truth. I retract my 3 earlier answers to that. 4 Q. Now, did the ?? well, you've had an 5 epiphany then? 6 A. Is this the ?? I heard this epiphany was 7 used around here. I don't know if the animal 8 control person was a Scientologist. I don't know 9 say, you know, if you're a Scientologist or a 10 communist. I don't know if they were anything. 11 They were animal control, zoning and social 12 workers. 13 Q. And those people told you that you could 14 not have those cats in your house, is that what 15 they told you? 16 A. Zoning said ?? 17 Q. What did they tell you? 18 A. Zoning said we had more cats than was 19 available for the zoning law. 20 Q. Okay. Now, what else ?? what did the 21 animal control people tell you? 22 A. They said we've had ?? we've got a report 23 here you've got dead, dying and diseased animals. 24 Q. I'm not asking you about the reports. 25 When they came out and did the inspections ?? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 568 1 A. You just asked what they said and I've 2 told you that. 3 MR. DANDAR: Wait. Objection. I made an 4 objection. 5 MR. WEINBERG: You made an objection. 6 Fine. 7 MR. DANDAR: You interrupted him. 8 MR. WEINBERG: Well, you know what, then 9 we'll go to the next question. 10 MR. DANDAR: No. 11 BY MR. WEINBERG: 12 Q. When they came to your house ?? 13 MR. DANDAR: Don't answer another question 14 until you finish your answer to the prior 15 question that he doesn't want to hear the 16 answer to. 17 MR. WEINBERG: No. We're going to go 18 through this. 19 MR. DANDAR: He will not answer another 20 question ?? 21 MR. WEINBERG: Well, then let's stop and 22 we can continue the deposition at a later 23 time, because you know what, Ken, I can ?? 24 MR. DANDAR: He didn't finish his answer. 25 MR. WEINBERG: He was making a speech. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 569 1 He wasn't answering my question. I want to 2 have answers to my questions. 3 MR. DANDAR: Excuse me. 4 MR. WEINBERG: Excuse me. 5 MR. DANDAR: You were asking a broad 6 question, what did they say. 7 MR. WEINBERG: No, I didn't ask ?? 8 A. Can we get the question off the reporter? 9 Q. No. We're going to go on and I'll let 10 you tell everything. What I want to know is when 11 they came ?? you've told me about all the 12 complaints and I guess you're accusing people, 13 although you don't know, you're saying that the 14 Scientologists made the complaints. That's what 15 you're suggesting. 16 A. No, I didn't say that. 17 Q. That's what you're suggesting, isn't it? 18 A. I said the organization. It's Department 19 20. 20 Q. That's what you're suggesting, isn't it? 21 A. Yes. 22 Q. Okay. But you don't know that, do you? 23 A. Oh, yes, I do. 24 Q. No, you don't? 25 A. Oh, yes, I do. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 570 1 Q. All right. Now, they come and they say 2 we've heard complaints. Now, my question is once 3 they got there, did they make any statements or 4 findings as to whether or not you were in 5 compliance or out of compliance with various 6 ordinances, yes or no? 7 A. Yes. 8 Q. And did they say you were out of 9 compliance with various ordinances? 10 A. One did and one didn't. 11 Q. Okay. The one that did said you were out 12 of compliance with what ordinance? 13 A. Zoning. 14 Q. All right. And you dispute that? 15 A. No. 16 Q. All right. And what did you do to get into 17 compliance? 18 A. We moved the cats out of the house. 19 Q. To the house that the Mintons bought? 20 A. No. 21 Q. Where did you move them to? 22 A. Other houses. 23 Q. In the neighborhood? 24 A. Yeah. 25 Q. All right. Now, you object to officials SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 571 1 from the City of Seattle enforcing ordinances? 2 A. No. 3 Q. Okay. Now ?? 4 A. You didn't want to know about the one that 5 found us in compliance. 6 Q. What difference does it make? 7 A. A serious difference. You wanted to ask 8 what officials came out to inspect. 9 Q. I'm not ?? and you told me what officials? 10 A. And you said you would let me finish. 11 Q. Go ahead. 12 A. Animal control came out and said there was 13 a report of dead, deceased and dying animals. I 14 said come on in the house and look. He walked 15 around and said this is the healthiest group of 16 animals I have. I says ?? he says that's okay, we 17 get this all the time, people want to get somebody 18 else in trouble, they place anonymous calls. I 19 said anonymous call? He says, yeah, anonymous 20 call, good looking animals, see you later. 21 Q. And there are people in this world that ?? 22 well, strike that. It doesn't really matter. 23 Now, these cats that you've expressed such 24 emotion about, is there a particular reason why you 25 didn't stay in Seattle to keep the cats together in SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 572 1 this foundation, you, Vaughn Young? 2 A. Because I wasn't ?? I didn't feel I was 3 the person that had ?? you know, it's like 4 Scientology saying, you now, L. Ron Hubbard. You 5 know, there is people that are founders and sources 6 of things. She was the founder of this thing. It 7 wasn't my idea. I could deal with media stories 8 and I could ?? publicity, but as far as the actual 9 working with volunteers, I wouldn't be able to do 10 it without her. 11 Q. All right. And is there a particular 12 reason, given your statements about the cats, that 13 Stacy didn't stay with the cats in Seattle and run 14 this foundation? 15 A. Because ?? 16 Q. Do you know? 17 A. Because we were getting a divorce, I was 18 leaving, and with the breakup of that, it was like 19 the breakup of a team, and we talked about that. 20 And she says, you know, with us breaking up, I 21 don't think we can do this, and I said I don't 22 think so either. It was a very emotional time for 23 the two of us, and she said I'll take care of it. 24 And so that's why when I went back to see how it 25 was going and she was telling me how it was going SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 573 1 and she said, listen, you can stay here as long as 2 you want. This is even after the divorce is final. 3 She says, you know, we're good friends, you can 4 stay. So I watched her finish some of it and I 5 left and she finished the rest of it and informed 6 me by phone. 7 Q. Now, where is the foundation today, what's 8 the status of the foundation? 9 A. I haven't asked. 10 Q. Well, you were one of the founders, right? 11 A. Well, yes, but I also submitted a written 12 resignation at that point. It was over to them. 13 Q. Written resignation to whom? 14 A. I gave it over to Stacy, a written 15 resignation. 16 Q. Well, what did it say? 17 A. It just said effective this date resigning 18 because I was ?? 19 Q. You resigned as what? 20 A. Resigned my position as president. 21 Q. All right. And what date was that? 22 A. Gosh, early '98. 23 Q. '99 you mean? 24 A. Yeah, maybe early '99 or late '98. 25 Q. And the reason you resigned was what? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 574 1 A. Because I was, despite her offer that I 2 could, you know ?? I was always welcome to stay 3 there in the house with her as long as possible, as 4 long as I needed, until I found some other place to 5 ?? work to do or something, and I said no, I can't 6 be here, I'm on the road, so it's really not good, 7 you guys have to do business, you need board 8 minutes, you know, we can do it by telephone but I 9 think it's best that I just resigned. 10 Q. You guys? Was there somebody else in the 11 foundation? 12 A. Well, there was another girl that was 13 working there that was ?? 14 Q. Who is that? 15 A. The secretary, Judith. 16 Q. Judith, is she a former Scientologist? 17 A. No. 18 Q. So she's just somebody local on Vashon 19 Island? 20 A. Yeah, she had been originally a volunteer. 21 Q. Well, what happened to ?? did Judith take 22 a cat or two? 23 A. She might have. I don't know. She had 24 her own cats. 25 Q. Did she replace you on the board? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 575 1 A. I don't know who replaced me. 2 Q. Well, did ?? was this part of the 3 wind?down of the foundation? 4 A. What part? 5 Q. Your resigning. 6 A. Possibly. When I resigned, I was stepping 7 away and she assured me that ?? 8 Q. She being? 9 A. Stacy ?? that they were all going to find 10 homes and would be taken care of, and she even told 11 me yesterday when we were talking about it, about 12 giving me the names of a few more cats that ?? 13 telling me a couple of cats that we had enjoyed 14 dearly that had found homes. 15 Q. All right. But she told you then that she 16 was winding down the foundation, she was giving 17 away the cats? 18 A. Yes. 19 Q. All right. She wasn't taking any new cats 20 in? 21 A. No. 22 Q. And was this at the same ?? right around 23 the time that you resigned from the whatever it 24 was, president? 25 A. Oh, that was afterwards. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 576 1 Q. Okay. What happened to the account, the 2 Friends of the Cats account or whatever it's 3 called, Friends of the Animal ?? 4 A. Foundation. 5 Q. ?? Foundation account? 6 A. It stayed with her as long as she was 7 doing the ?? doing that, and then wherever it went 8 with the foundation. I don't know. 9 Q. What do you mean foundation? 10 A. I left. 11 Q. Well, the foundation doesn't exist anymore 12 if the cats are all gone, does it? 13 A. Of course it could. 14 Q. Well, do you know? I'm asking if you 15 know. 16 A. You said it couldn't. I'm saying it could 17 because it's a nonprofit 501(C)3. It's got a tax 18 exemption. 19 Q. Well, that's right, but I mean once you 20 give away all the animals, there isn't a lot of tax 21 exempt work that the foundation does, was there? 22 A. Oh, of course it could. We had a hole 23 within our bylaws, educational programs that it 24 could do, spay programs that could be done. 25 Q. Are you aware ?? I'm sorry. Are you aware SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 577 1 of anything that is being done as we sit here today 2 with regard to this foundation? 3 A. Not recently. 4 Q. And has Stacy indicated to you that there 5 is anything being done with regard to the 6 foundation? 7 A. I haven't asked and she hasn't told me. 8 Q. And has she told you what happened to the 9 money that was in the account? 10 A. No. 11 Q. I thought that you said that the 12 foundation had been dissolved before a tax return 13 was due. Maybe I misheard you but I thought you 14 said that. Didn't you say the foundation had been 15 dissolved? 16 A. No. I ?? earlier, when I said about tax 17 return, I said there is some leeway on the filing 18 of your first return. I had not talked about the 19 dates and filings of returns with the dissolution 20 of the foundation. 21 Q. Well, did the foundation ever file a 22 return, do you know? 23 A. It might have. I was not keeping track of 24 it at that point. I forget. I think we had 25 something like three years before we, you know ?? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 578 1 when you first start because they just give it to 2 you and we were in the in?between period, so there 3 was no need for it at that time, so I wasn't 4 keeping track of it. 5 Q. Well, once the foundation was formed, 6 which was sometime when, in '98? 7 A. No. No. It was way earlier. We formed 8 it as a corporation in the state of Washington a 9 couple of years before that. 10 Q. But you didn't seek tax exempt status 11 until after the house was bought by the Mintons? 12 A. No. That's not what I said. I did not ?? 13 I even testified to the contrary yesterday. We had 14 started our tax exemption prior. 15 Q. You didn't have tax exempt status until 16 after the house was bought? 17 A. The tax exemption came in prior ?? I mean 18 after that date of moving to Vashon but it had been 19 filed and worked on prior to that. 20 Q. Okay. 21 A. It just happened to be a coincidence of 22 dates. 23 Q. As far as you know, no return has ever 24 been filed as far as the foundation is concerned? 25 A. I don't know of any. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 579 1 Q. Do you know what the responsibilities are 2 as president and/or director with the foundation as 3 far as filings are concerned with either the IRS or 4 any other agency? 5 A. I have to plead ignorance on that one. 6 Q. Did you have some lawyer that y'all were 7 working with with regard to the foundation? 8 A. She had an accountant, an 9 attorney?accountant that she had worked with to 10 help us get the 501(C)3 who made the application. 11 Q. In Washington? 12 A. Yes. 13 Q. I mean Washington State? 14 A. Yes. And then there was another one that 15 she was going to pick up so she could separate out 16 between the legal and the financial, and she said 17 she was going to have them do it because we were 18 just too naive or too new at it and if we did this 19 wrong, we could screw it up. 20 Q. And do you remember what the names of the 21 lawyers were? 22 A. No. 23 Q. Was it Graham ?? I mean was it Ford 24 Greene? 25 A. No. It was nobody connected to SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 580 1 Scientology cases, sir. It was just somebody that 2 knew ?? from a recommendation of someone that knew 3 about 501(C)3 filings. 4 Q. Okay. Now, did ?? other than the house 5 that was provided for you and Stacy that we talked 6 about, was there anything else, any other personal 7 property, real property, thing that was provided to 8 you and/or Stacy as far as you know that had a 9 monetary value by either Mr. Minton or his wife 10 either directly or indirectly? 11 A. No. 12 Q. Did Mr. Minton have anything to do ?? 13 A. I'm sorry, Mr. Weinberg, for that outburst 14 at you earlier. 15 Q. All right. 16 A. Just personal apology. 17 Q. Did Mr. Minton have anything to do with 18 Mr. Dandar representing you personally? 19 A. Today? 20 Q. No, in the deposition out in Los Angeles. 21 A. No. 22 Q. No? 23 A. No. 24 Q. Is it just coincidental that Mr. Dandar 25 made his way to Los Angeles to represent you SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 581 1 shortly after the Mintons had provided funds to 2 purchase a $250,000 house and had apparently given 3 Stacy three checks totalling $50,000, is that just 4 a coincidence? 5 A. Boy, that's a nice stop beating your wife 6 question. Mr. Dandar ?? Mr. Berry would have 7 represented me as he had before but had fallen out. 8 There were all sorts of political legal disputes 9 going on and Mr. Dandar heard about it and I was 10 working with him on a case and it was one of these, 11 hey, can I help you out. Otherwise, Mr. Berry 12 would have, as he had before in the FACT Net case. 13 Q. I didn't really pursue this yesterday but 14 now that you've ?? now that we've touched on it, 15 it's your recollection that Mr. Dandar called you 16 and said I'll represent you in Los Angeles at the 17 deposition? 18 A. He might have, and also I might have 19 mentioned it along the way in a telephone 20 conversation. It could have actually happened that 21 way, so, you know, hey, you know, like what's 22 happening, because ?? I mean I've just lost Berry 23 on the thing. Well, hell, I could ?? it's almost 24 like that's how it happened, you know. Well, hell, 25 I could represent you. You could? You're from SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 582 1 Florida, can you do that in Los Angeles? Oh, hell, 2 yeah, blah, blah, blah. Okay. Cool. 3 Q. What do you mean you lost Berry on the 4 thing? 5 A. It was something I never understood. 6 There was a ?? the FACT Net case was always 7 embroiled. I'm sorry to say Mr. Wollersheim always 8 seemed to be firing and rehiring somebody, and so 9 there was a point when Mr. Berry was part of it and 10 then suddenly he wasn't. 11 Q. So ?? 12 A. I don't know what all happened. 13 Q. So who was representing FACT Net at this 14 deposition in November of 1997? 15 A. I believe it was Mr. Leipold. 16 Q. And Mr. Leipold, is there any reason why 17 he didn't just represent you during the deposition? 18 A. I didn't ?? I don't know. I haven't 19 thought about it. 20 Q. Do you remember talking to him about it? 21 A. No. 22 Q. Your way was paid to Los Angeles by 23 Mr. Leipold? 24 A. I don't remember who paid for it, whether 25 it was Mr. Leipold or whoever it was at that point, SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 583 1 Bridge or RTC. It depends on who was requesting my 2 deposition. I don't know. You just ask for the 3 ticket. 4 Q. Well, you didn't pay for it though, right? 5 A. No. 6 Q. Is that right? 7 A. Yes, that's correct. 8 Q. Hold on one second. Okay? 9 A. I'm just stretching my legs. 10 MR. DANDAR: How do you feel? 11 THE WITNESS: Stiff. I'm sorry, I didn't 12 mean to go out of range. I'll sit down before 13 the question. 14 Q. You can stand up if you want to. 15 A. That's what I'm doing. 16 Q. Now, did you discuss with ?? did you pay 17 Mr. Dandar for his services for this deposition? 18 A. I don't remember, because we ?? wow, that 19 was why ?? that was the Ford Greene $700, because I 20 was thinking we had paid some attorneys to 21 represent us, contrary to everybody's giving us 22 free service, that was ?? did we do ?? Ford was 23 paid to represent me or Stacy in a deposition and 24 I'm trying to remember if we also paid Mr. Dandar 25 something for that. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 584 1 Q. Well, while you're thinking, it's one 2 thing having a California lawyer represent you in a 3 California deposition, it's another thing flying a 4 Florida lawyer cross?country to come to California 5 to sit for a deposition, correct? 6 A. Well, of course. 7 Q. Right. $750 wouldn't quite cut it for 8 flying a lawyer like Mr. Dandar from Tampa to 9 California for a deposition, would it? 10 A. I don't suppose so. 11 Q. All right. Now, do you remember making 12 any arrangements or anybody making any arrangements 13 for Mr. Dandar, who, as far as I know, prior to 14 this appearance had had no involvement in the FACT 15 Net case, flying from Tampa to California to sit 16 with you during your deposition? 17 A. I don't know what arrangements were made. 18 Q. All right. If any? 19 A. If any. 20 Q. Well, did Mr. Dandar say he was donating 21 his services to you? 22 A. Well, that's what I haven't settled down, 23 is whether or not we agreed upon a fee or whether 24 it was donated. Ford Greene was a good friend and 25 he didn't donate. We paid him. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 585 1 Q. Mr. Dandar wasn't a friend, was he? 2 A. No, not particularly. 3 Q. Certainly not like Ford Greene, right? 4 A. No. We had known Ford for years. 5 Q. In fact, you hadn't even met Mr. Dandar 6 prior to this deposition, had you? 7 A. When was that? 8 Q. The deposition? 9 A. We met him a couple of times in Seattle. 10 Well, no, he came out and met us. 11 Q. So you met Mr. Dandar once when he flew 12 out for ?? 13 A. Maybe twice. 14 Q. ?? for a short meeting? 15 A. For the interview, and I know he came out 16 another time. 17 Q. He came out another time? Maybe my mind 18 is playing tricks on me. I don't remember when he 19 came out another time after that. 20 A. I may not have cited the second time but, 21 you know, it seems like he came out a second time. 22 I'm remembering twice at the same restaurant that 23 he liked. 24 Q. What was the second meeting? How close in 25 time to the first meeting? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 586 1 A. Oh, it was several months apart. 2 Q. What was the purpose of the second 3 meeting? 4 A. The same as the first, he wanted ?? but 5 different ?? actually, no, not the same as the 6 first. The first one was to go over the 7 qualifications. The second one was to, since we 8 had discussed and worked together quite a bit, now 9 he wanted to sit down and sort of strategize, in a 10 sense of a word, in the sense that he was now 11 telling us about the case and we could sort of kick 12 it back and forth, because he had now learned 13 enough about the vocabulary and the structure and 14 we had learned just enough about the case that now 15 it was good for a face?to?face meeting because 16 things had just been over the telephone, and so 17 there wasn't anything ?? I don't think he really 18 had anything in particular in mind as just that 19 it's been months, we've never really sat down and 20 discussed this except for your qualifications and 21 talking about discovery documents, so ?? I remember 22 he used the phrase something like ?? he says I like 23 to just sort of come out and, you know, pick your 24 brains and kick over some things for a few hours, 25 and that's what we did. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 587 1 Q. It was just a few hours in the same 2 restaurant? 3 A. Yes. 4 Q. You and Stacy? 5 A. And Mr. Dandar. 6 Q. No one else? 7 A. No. 8 Q. You didn't review any documents at that 9 meeting? 10 A. No. 11 Q. You didn't give advice as to adding people 12 as defendants to the complaint or anything like 13 that? 14 A. No. I remember making the point at the 15 time, I said by the way, there is one thing that is 16 missing in all of this thing that's missed in every 17 case, and that's the impact of the Sea 18 Organization. 19 Q. And you just remember that? 20 A. I just remember that? 21 Q. No. You just remember telling him that? 22 A. Yes. 23 Q. All right. And you explained to him what 24 about the Sea Organization? 25 A. Pretty much as I explained to a couple of SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 588 1 attorneys. He wasn't the first. 2 Q. Well, just tell me what you explained to 3 him. 4 MR. DANDAR: Well, no, he's not going to 5 talk about our conversations. 6 MR. WEINBERG: Why not? 7 MR. DANDAR: That's our work product. 8 He's not talking about it. I'm instructing 9 him not to answer. 10 MR. WEINBERG: Why, because that's 11 contrary to what you represented to the court, 12 is that what you're concerned about? 13 MR. DANDAR: No. 14 Q. This meeting with Mr. Dandar, this second 15 meeting, what year was that in? 16 MR. DANDAR: Try as you might, you still 17 fall down. 18 MR. WEINBERG: Is that a comment? 19 MR. DANDAR: Yeah. You're just wearing 20 me out. 21 MR. WEINBERG: Is that an objection? 22 MR. DANDAR: Yeah. 23 MR. WEINBERG: Why are you interrupting a 24 question with a gratuitous comment? Do you 25 think that's appropriate? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 589 1 MR. DANDAR: That's what this ?? 2 MR. WEINBERG: Do you think it's 3 appropriate? 4 MR. DANDAR: Yes. I told you ?? 5 MR. WEINBERG: You think it's appropriate 6 to interrupt a question in a deposition by 7 making a gratuitous comment without making an 8 objection? 9 BY MR. WEINBERG: 10 Q. Do you understand the question, Mr. Young? 11 A. I'm sorry to say I lost it. 12 Q. When ?? did this meeting take place in 13 1997, yes or no? 14 MR. DANDAR: Oh, I'm sorry. You can 15 answer that one. 16 A. Latter, in maybe October. 17 Q. Did the meeting take place before 18 Mr. Dandar appeared as your attorney in Los 19 Angeles? 20 A. It seems like it did. 21 Q. All right. Just so the record is clear, 22 the deposition in Los Angeles took place on 23 November 5th, 1997. Is that right? 24 A. Yes. 25 Q. That was the deposition that Mr. Dandar SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 590 1 appeared at as your personal lawyer, right? 2 A. Yes. 3 Q. Now, other than these two meetings that 4 you've described with Mr. Dandar, and the 5 deposition which took place shortly after the 6 second meeting, or after the second meeting, are 7 there any other meetings other than in the last 8 couple of days that you have had with Mr. Dandar? 9 A. He came through ?? boy, I wish I could ask 10 him. He came through on a trip. It was not to see 11 me, it was ?? I seem to recall passing through on 12 vacation and that's when we went down to that 13 little ?? on the Alki, that log cabin restaurant 14 which turned out to be so lousy. 15 Q. All right. So this was ?? 16 A. It was. 17 Q. ?? just a social visit? 18 A. Yeah, just a ?? 19 Q. It's not about the case? 20 A. No. 21 Q. I'm talking about the case. Any other 22 meetings about the case? 23 A. Well, you asked if there were any meetings 24 with him and that happened. 25 Q. I understand. Any other meetings about SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 591 1 the case? 2 A. No. 3 Q. Now, did you reimburse Mr. Dandar for his 4 plane and hotel expenses for flying from Tampa to 5 LA for this deposition? 6 A. No. 7 Q. Do you know who did? 8 A. No. 9 Q. Do you know that somebody did? 10 A. No. 11 Q. You don't know one way or the other? 12 A. No. 13 Q. Do you know whether Mr. Dandar took part 14 of the $100,000 that Mr. Minton had given him in 15 early October 1997 to reimburse himself for 16 representing you at this deposition, do you know? 17 A. I don't know anything about $100,000, so I 18 can't respond to that question. 19 Q. Well, you've read what Mr. Minton said 20 publicly about giving hundreds of thousands of 21 dollars to Mr. Dandar in this case, haven't you, 22 you've read that? 23 A. No, I haven't. 24 Q. And Mr. Minton never told you that either? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 592 1 Q. And Stacy never told you that either, is 2 that right? 3 A. That's right. 4 Q. And ?? okay. Okay. Now, with regard to 5 the ?? what I'll refer to as the Haney library, 6 that may be ?? that may be giving it a little more 7 credit than what it is, but you understand what I'm 8 talking about, the Haney library? 9 A. That will suffice. I won't stipulate to 10 the name. 11 Q. Right. Well, with regard to the Haney 12 library that was in this hotel room that you've 13 described in the Columbus area ?? 14 A. An apartment. 15 Q. In an apartment, I'm sorry, in the 16 Columbus area, you mentioned something about 17 scanning and I just want to make sure. Were any of 18 the documents scanned into a computer as far as you 19 know? 20 A. No. I said I had no scanner. 21 Q. Okay. So you didn't have a scanner? 22 A. No. 23 Q. No Xerox machine, no scanner, no copier, 24 no nothing as far as getting ?? 25 A. I take that back. I had a scanner that SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 593 1 wouldn't work. 2 Q. Okay. But the point is is that you didn't 3 somehow use a device to image any of these 4 documents? 5 A. No. That was asked yesterday and I said 6 no at that time. 7 Q. Okay. You don't know where the documents 8 are now, is that right? 9 A. That's right. 10 Q. Were there any records kept with regard to 11 the foundation, the cat foundation, you know, 12 actually corporate records where there is board 13 meetings, board minutes, ledgers, you know, 14 whatever one does when one is running a 15 corporation? 16 A. All I remember is the checkbook. 17 Q. Okay. So you don't ?? you don't remember 18 any other sort of official or unofficial record 19 that this foundation has? 20 A. Well, it had its tax exempt letter from 21 the IRS, which would be an important document. 22 Q. Okay. Now, where are ?? where is the 23 checkbook, do you know? 24 A. No. 25 Q. And where is the IRS ?? a copy of the IRS SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 594 1 document? 2 A. I don't know. 3 Q. And do you know whether there is any 4 account that still exists with regard to the 5 foundation? 6 A. I don't know. 7 Q. Now, did Mr. ?? did anybody tell you, did 8 you learn from any source, that Mr. Minton gave 9 money to Jerry Armstrong? 10 A. Never heard that. 11 Q. Mr. ?? you haven't talked to Mr. Armstrong 12 about that? 13 A. No. 14 Q. Did anybody tell you or did you learn from 15 any source that Mr. Minton gave money to Arnie 16 Lerma? 17 A. Never heard of him. 18 Q. You know who Arnie Lerma is, right? 19 A. I don't know him personally. I know of 20 him. 21 Q. You know that he's someone that appears on 22 the Internet saying things that aren't too 23 favorable to Scientology, you know that, right? 24 A. I've seen some of his stuff way back when. 25 Q. So neither he nor anyone else has told you SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 595 1 that he received money from Mr. Minton, is that 2 right? 3 A. That's right. 4 Q. You know who Keith Hinson is, right? 5 A. Not really. I know the name and I know he 6 was at some sort of litigation but I've never 7 spoken or corresponded with him. 8 Q. Litigation with Scientology? 9 A. With a Scientology organization or group 10 or company. I don't know. 11 Q. And neither he nor anyone else has told 12 you that he received money from Mr. Minton, is that 13 right? 14 A. I have no such information. 15 Q. You know who Grady Ward is, right? 16 A. I know of him. 17 Q. You've seen some of his work? 18 A. Perhaps. I can't cite anything. 19 Q. You know that he is ?? that he puts out 20 obscene and vulgar work on the Internet, you know 21 that, don't you? 22 A. No, I don't. 23 Q. Now, and do you know that he has received 24 money from Mr. Minton? 25 A. No, I don't know that. Am I the only one SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 596 1 missing out on this? 2 Q. Well, the ?? apparently so, I guess. 3 Mr. Minton hadn't made a big secret of this. 4 A. Okay. 5 Q. You're familiar with FACT Net, correct? 6 A. In a sense of the word. I was brought on 7 to help ?? dependent upon your question, put it 8 that way, yes. 9 Q. Well, you participated as a consultant 10 with regard to litigation between FACT Net and 11 Bridge Publishing? 12 A. Yes. I was only hesitant because I've 13 never worked there with their database, I never 14 went into their database. There was a certain area 15 that I knew about and there was areas I had no 16 knowledge. 17 Q. Well, are you aware that there came a 18 point in time when Mr. Minton and your ex?wife 19 became a director of FACT Net, became directors of 20 FACT Net? 21 A. No. 22 Q. So they never told you that? 23 A. Not ?? I don't know when this might have 24 happened. I haven't worked with FACT Net or been 25 in correspondence with FACT Net for a couple of SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 597 1 years. 2 Q. Well, I'm just asking you. Stacy never 3 told you and you never learned that she became a 4 director of FACT Net? 5 A. That's correct. 6 Q. Mr. Minton never told you and you never 7 learned that he became a director of FACT Net? 8 A. That's right. 9 Q. And I take it that you have no idea how 10 much money Mr. Minton has funneled into FACT Net? 11 A. I have no idea, if any. 12 Q. Now, you know who Larry Wollersheim is? 13 A. Yes. 14 Q. You've actually received money for working 15 on a Larry Wollersheim case, is that right? 16 A. I was on the FACT Net case. 17 Q. I see. And at that time Larry Wollersheim 18 was responsible for running FACT Net, right? 19 A. Pretty much so, yes. 20 Q. So that the money that you received 21 through Graham Berry's law firm, is that where the 22 money came from? 23 A. Faegre & Benson is the one I was working 24 with at that time. 25 Q. I'm sorry. Is that a Colorado firm? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 598 1 A. Yes. That was about five years ago, and 2 then it got moved out to LA. This is why it gets 3 so confusing, because it's been with Berry, it's 4 been ?? I was losing track of who I was sometimes 5 working for. 6 Q. Well, did Larry Wollersheim tell you that 7 he received hundreds of thousands of dollars from 8 Mr. Minton? 9 A. No. 10 Q. Did Larry Wollersheim tell you that 11 Mr. Minton has, in essence, purchased his judgment? 12 A. No. 13 Q. Did Larry Wollersheim tell you that 14 Mr. Minton had a lien on his judgment? 15 A. No. I haven't spoken with Mr. Wollersheim 16 in maybe two and a half years. 17 Q. So that comes as news to you then? 18 A. Yes. 19 Q. Did Mr. Minton offer you any money as a 20 result of the dissolution of your marriage, yes or 21 no? 22 A. No. I can see I should have gotten in 23 line for some money. 24 Q. Excuse me? 25 A. A lot of money floating around here. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 599 1 Q. There certainly is, isn't there? 2 A. According to you. I don't know about it. 3 Q. Well, I showed you three checks that 4 apparently worked their way into Vashon Island but 5 you didn't know about them, right? 6 A. That's right. 7 Q. $30,000 would buy a lot of cat food, 8 wouldn't it? 9 A. Yeah. And I ?? 10 Q. Now, how? 11 A. I'm supposed to be one of these bought 12 consultants. 13 Q. There isn't a ?? there's not a question 14 pending. 15 A. That's true. 16 Q. All right. Let's talk about Jesse Prince. 17 When was the first time after you left Scientology 18 with Stacy in 1989 that you communicated with Jesse 19 Prince? 20 A. Gosh, maybe ?? I'm not ?? I could be wrong 21 on this, maybe in 1996. 22 Q. Well, let's work at it a little bit. 23 You're not very good on dates, right? 24 A. Not unless there is a particular 25 significance. It was a phone call from him. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 600 1 Q. Let's work back. What were the 2 circumstances of you communicating with Jesse 3 Prince? 4 A. Either he called Stacy or Stacy called him 5 and, you know, hey, Vaughn, it's Jesse, and I 6 hadn't seen this ?? you know, this lovable son of a 7 bitch in ages and, hey, Jesse, how are you doing, 8 where are you? I'm up here in the cold ice 9 country, what you doing? What are you doing? I'm 10 doing this and that. So it was a real, you know, 11 old buddy, get together, talk for maybe a half an 12 hour. 13 Q. All right. And you had ?? and this 14 occurred, did it not, sir, after you had moved on 15 to Vashon Island? 16 A. No. 17 Q. Are you sure? 18 A. Best as I can recall. Jesse left in 1989, 19 left Scientology. 20 Q. Well, actually, Jesse left Scientology 21 after that ?? 22 A. Okay. 23 Q. ?? according to his testimony. And 24 according to his testimony, he heard from you 25 sometime in the summer of 1998. All right? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 601 1 A. Boy, time flies when you're having fun. I 2 remember a phone call just kicking, you know, bull 3 shit or whatever. 4 Q. And did he ?? do you remember how it was 5 that he knew how to find you or you knew how to 6 find him? 7 A. No. Stacy had found him or he had found 8 Stacy. 9 Q. And did he find Stacy through Bob Minton? 10 A. I have no idea. 11 Q. Do you know whether Bob Minton had 12 anything to do with your communication with Jesse 13 Prince? 14 A. I have no idea. 15 Q. After this how you doing, old buddy, 16 conversation, what occurred between you, and I say 17 the collective you, and Jesse Prince? 18 A. Then it would have been in I guess it was 19 July, July '98, June, July '98, and Stacy said ?? 20 we were on Vashon and she said Jesse is going to 21 move from Minneapolis and he wants somebody to 22 drive with him, how would you like to take a drive 23 with Jesse cross?country. And I had said, well, if 24 I can take Mack with me, I'd do it, you know. So I 25 talked to Jesse on the phone and he was going to go SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 602 1 to Colorado. So that's how it was set up. 2 Q. All right. Now, why in the world was ?? 3 if you can explain to me ?? was Stacy asking you to 4 go across country to accompany Jesse from 5 Minneapolis to Boulder? 6 A. She wasn't. She was telling me that he 7 was coming out, would I be interested. And so I 8 spoke with Jesse and Jesse was the one that asked 9 me, and she just basically told me that that was 10 his plan. 11 Q. Well, was this part of, as far as you 12 know, Stacy's plan to get you out of the house 13 regarding her relationship with Mr. Minton? 14 A. Oh, please. 15 Q. If you know. 16 A. There was never a plan and I have always 17 resented this thing about how Stacy kicked me out 18 of the house. I returned to that place many times 19 and had invitations to stay. No. 20 Q. Well, why are you ?? well, why is she 21 asking you ?? 22 A. Jesse asked me. 23 Q. Let me finish my question. 24 A. Jesse asked me. 25 Q. What happened was, from what I just heard SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 603 1 you say, is that Stacy came to you and said would 2 you be interested in traveling with Jesse across 3 the country, right? 4 A. That's really sort of the second half of 5 the conversation. 6 Q. Okay. Well, you didn't tell us about the 7 first half. 8 A. The front half of the conversation with 9 her, she said, hey, Jesse wants to come out of the 10 closet, so to speak, and do some things. And I 11 said really? She said yeah, he's going to go out 12 to Colorado and he's going to drive on out and he 13 was interested whether or not you want to just, you 14 know, take a drive with him, because it's a long 15 drive. So she told me about his decision and I 16 spoke with Jesse and he was the one that asked me. 17 Q. What did Jesse tell you? 18 A. He said he's moving from Minneapolis, he 19 says, hey, do you want to help me move? I said 20 what does that mean? He said I'm going to drive 21 from Minneapolis to Chicago, down to Memphis and 22 see my dad, and then head on out to Denver. 23 Q. And you said sure, I'm going to take a 24 cross?country trip with you? 25 A. Not immediately. It was a long trip and I SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 604 1 think I sort of thought about it and probably told 2 him okay the next day. 3 Q. Did you ask him how one was going to pay 4 for this? 5 A. No. 6 Q. Did you ?? how did you get to Minneapolis? 7 A. I flew. 8 Q. Who paid for that? 9 A. I don't know. 10 Q. Well, who arranged for your ticket? 11 A. Jesse told me where the ticket and the 12 flight was. 13 Q. Excuse me? 14 A. Jesse told me. 15 Q. So you just went to the airport and picked 16 up a ticket? 17 A. Yes. 18 Q. Now, Jesse didn't have the funds to pay 19 for you to go cross?country, did he? 20 A. I don't know. I know that he had a very 21 successful art business back there. 22 Q. That's what Jesse told you? 23 A. Yes. 24 Q. That he had a successful art business? 25 A. Oh, he said he was doing well. I didn't SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 605 1 ask him for financial statements. 2 Q. So he didn't tell you about his bankruptcy 3 in 1997, I take it? 4 A. I'm telling you all that he told me. 5 Q. I'm just saying he didn't tell you that he 6 had also filed for bankruptcy, he didn't tell you 7 that, did he? 8 A. No. 9 Q. Now, did he tell you about any job that he 10 was leaving in Minneapolis? 11 A. Just the art business. 12 Q. Did he tell you that Mr. Minton had given 13 him money to travel from Minneapolis to Colorado? 14 A. No. 15 Q. Did he tell you ?? what did you drive in 16 from Minneapolis to Colorado? Can you describe the 17 car? 18 A. A van, SUV type. I'm not very good on 19 models. 20 Q. It was a new car? 21 A. Newish. I don't know if it was new or a 22 couple of years old. 23 Q. Didn't he tell you that he literally just 24 picked up the car new? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 606 1 Q. From the lot? 2 A. No. I remember him talking about all the 3 bumps on the hood from hail. It had a whole bunch 4 of bumps, and he says that's the problem with 5 Minneapolis and it will probably be a problem with 6 Denver, and we talked about the hail bumps on it. 7 Q. All right. Well, he told you that that's 8 the way it was on the lot when the ?? the new car 9 lot when they purchased the car, he told you that, 10 didn't he? 11 A. No. Just ?? 12 Q. So he didn't tell you, I take it, that 13 Mr. Minton gave him 20 plus thousand dollars to 14 purchase the car, he didn't tell you that, right? 15 A. No. 16 Q. That just never came up in the 17 conversation? 18 A. Never came up and I don't ask. 19 Q. Now, how many days did you spend on the 20 road with Jesse Prince? 21 A. Well, there were some layover days, times. 22 Q. Tell me ?? 23 A. The itinerary? 24 Q. ?? from start to finish how many days, 25 first of all. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 607 1 A. Well, we were ?? I stayed a day or two in 2 Minneapolis as he packed up and got rid of his 3 stuff, maybe two days there, then we drove for a 4 day to Chicago, saw his brother, who was a jazz 5 musician, went to see him a couple days at the 6 clubs. So we were maybe three days there. Then we 7 went to Decatur, Illinois, which is where his kids 8 are. I don't know if we stayed over there or went 9 back to Chicago. I lose track of geography up 10 there, but there was definitely a Decatur trip. 11 Maybe it was part of the Chicago stay. 12 Q. That's a day or two? 13 A. I'm saying maybe if Decatur is close 14 enough, maybe we zipped out and came back to 15 Chicago. 16 Q. Okay. 17 A. But then the next major stop was Memphis 18 and we did not stay over there. He just spent the 19 day seeing his dad. 20 Q. But it takes ?? 21 A. No, I'm sorry. We stayed overnight 22 because I stayed in a motel across the street from 23 the Elvis mansion. 24 Q. I take it it takes some time to travel 25 from Chicago to Memphis? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 608 1 A. I don't remember what it took. 2 Q. Well, it's not like around the corner, 3 right, I mean it takes many hours? 4 A. No. We were alternating driving. He 5 would drive and I would drive, so maybe we might 6 put in 12 hours. I don't really remember. 7 Q. So however many days it took to drive down 8 there and then stay there. So it's a day or two 9 more, right? 10 A. Yes. I stayed overnight and left the next 11 day from Memphis, and then headed west and put in 12 some long days at that point. 13 Q. Through what states? 14 A. I think we went through Kansas City, and 15 this is where it gets into a blur. It gets into a 16 blur every time I go slightly west of the 17 Mississippi with Kansas, Missouri and Nebraska, and 18 all that. I think we may have stopped somewhere 19 like Kansas City and then just flat out to Denver. 20 Q. Did you visit anybody else? 21 A. No. 22 Q. And so all of this process from 23 portal?to?portal took what, ten days? 24 A. Maybe. 25 Q. Now, were you paid for this ten days? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 609 1 A. No. 2 Q. By anybody? 3 A. No. 4 Q. But Jesse had cash to cover all the 5 expenses, right? 6 A. Yes. 7 Q. You didn't bring cash? 8 A. Well, I had cash but he covered the 9 expenses. 10 Q. Okay. He didn't have a credit card, 11 right, he wasn't using a credit card, he was using 12 cash? 13 A. I don't know. He checked into the motel 14 and I really didn't pay attention to how he was 15 paying. 16 Q. All right. And you never discussed it 17 with Jesse? 18 A. No. 19 Q. Now, in this ten?day period did you 20 discuss Scientology with Jesse? 21 A. Oh, of course. 22 Q. Did you discuss ?? did you tell Jesse 23 about how much money you and Stacy had made over 24 the years testifying against Scientology? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 610 1 Q. Did you discuss with Jesse all the cases 2 that you had appeared in either by filing 3 declarations or by deposition or being a consultant 4 which you had been paid for, did you tell him that? 5 A. Well, with your proviso been paid for, I 6 don't know about that part. I'm sure I discussed 7 the cases that we had worked on just in our 8 post?cult life, as well as our life inside. 9 Q. Did you tell him that you and Stacy had 10 provided for yourself since 1993 primarily from 11 money received for work in cases involving 12 Scientology, did you tell him that? 13 A. I thought you told me I was going broke 14 all that time. 15 Q. Did you tell him that? 16 A. I was going broke awhile ago and starving. 17 Q. Did you tell him that, yes or no? 18 A. No. 19 Q. Okay. 20 A. I'm glad I was making money now. 21 Q. Did you tell Jesse ?? 22 A. It feels better. 23 Q. Did you tell Jesse that he could make a 24 lot of money if he signed up with the lawyers? 25 A. No. Quite the contrary. I told him it SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 611 1 was a bitch out there, Jesse. 2 Q. Did you tell Jesse that this man, Minton, 3 had bought you and your wife a home that was worth 4 $250,000? 5 A. No. 6 Q. Did Jesse tell you that he knew Minton, 7 did you discuss Minton? 8 A. No. 9 Q. Minton's name never came up in ten days? 10 A. I don't think so. 11 Q. Well, did Jesse tell you that he had been 12 visiting with Minton? 13 A. That's news to me. 14 Q. Did Jesse tell you that he had been in 15 communication with Minton? 16 A. No. You've got some idea of a conspiracy. 17 We are two old buddies that hadn't seen each other 18 in ten years and we spent all of our time catching 19 up. 20 Q. What I'm trying to do is ask you 21 questions, because, remember, we've taken Jesse's 22 deposition, taken Minton's deposition, and we have 23 heard testimony, from Jesse in particular, about 24 this trip and how it was paid for and his 25 relationship with Bob Minton. So I'm asking you SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 612 1 did Jesse give you any indication that he had any 2 relationship whatsoever with Bob Minton? 3 A. No. My assumption was that he ?? and I 4 had no reason to doubt him, that he had had a 5 successful art business because that sort of line 6 of work has always been a good freelance line of 7 work for people that make thousands of dollars a 8 week sometimes. I've seen it happen. And I 9 thought he had basically done well enough to buy 10 it, so there was no question for me to question. 11 He didn't say it. He didn't say I bought this car 12 with artwork or anything else, and I'm not the type 13 of person to pry. I was just happy to see Jesse 14 and be on the road with him. 15 Q. And the reason Jesse was giving up this 16 successful line of work that he had to move from 17 Minneapolis to Boulder was what? 18 A. He was going to go out and work with FACT 19 Net. 20 Q. But the reason that Jesse was giving up 21 this successful line of work that he lead you to 22 believe that he had in Minneapolis was what? 23 A. He had decided to come out of the closet 24 and make a difference. 25 Q. I see. He had decided that he was going SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 613 1 to testify against Scientology? 2 A. No. He didn't say that. He was going to 3 go to work for FACT Net and that wasn't testimony. 4 He was just going to go out there and work for FACT 5 Net. 6 Q. Now, did he ?? did you discuss with Jesse 7 who was running FACT Net in the summer of 1998? 8 A. No. 9 Q. And you didn't know that at that time 10 Mr. Minton was then involved in FACT Net, you 11 didn't know that? 12 A. No. He asked me about FACT Net and I told 13 him what he knew, about how I had testified there 14 and, you know, I never saw the database and what 15 little bit I knew and the things I heard about 16 Wollersheim, but that was just ?? that was very 17 brief. 18 Q. Now, you saw Jesse's apartment in 19 Minneapolis? 20 A. Uh?huh. 21 Q. Describe the furnishings in that 22 apartment. 23 A. Well, it was being sold and stripped out 24 when I arrived. 25 Q. He owned the apartment? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 614 1 A. No. 2 Q. So what do you mean it was being sold? 3 A. Well, he was selling his furnishings, his 4 couch, record collection, kitchen gear. When we 5 got there a friend of his had actually been, you 6 know, working with him to sell it. When I got 7 there there was so much stripped out. In fact, the 8 apartment sale was underway, people were coming in 9 and saying how much for this record collection, 10 Jesse, and how about for this stereo speaker over 11 here? So he was having himself an apartment sale 12 and getting rid of it. 13 Q. And he took the rest of it and put it in 14 the car? 15 A. Basically. I don't know what happened to 16 all of it, if he just told somebody throw the rest 17 away, but we loaded up what he wanted to take with 18 him. 19 Q. Was anything stored? 20 A. I don't know. 21 Q. You didn't see anything stored? 22 A. No. 23 Q. You didn't see any inventory or anything 24 like that? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 615 1 Q. Any art, you didn't see anything like 2 that? 3 A. You mean the stuff that he sold? 4 Q. You didn't see any art that would be ?? 5 you said he had some successful art business. 6 A. They are prints, you know, of different 7 subjects that you can buy usually in street fairs, 8 flea markets. 9 Q. I understand. But you didn't see any of 10 that? 11 A. Yeah. 12 Q. And where ?? and was some of that stored? 13 A. I don't know what happened to it but I did 14 see some of it. 15 Q. Now, when you got out to Colorado, where 16 did you go? 17 A. He dropped me off at the DIA, Denver 18 International Airport. 19 Q. Oh. So then he went on to Boulder? 20 A. Yes. 21 Q. In the car? 22 A. Yes. 23 Q. Why didn't you go to Boulder with him? 24 A. I didn't need to. I didn't want to go to 25 Boulder. To tell you the truth, I didn't want to SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 616 1 go see Lawrence Wollersheim. 2 Q. Why did you think you were going to see 3 Lawrence Wollersheim? 4 A. Because Lawrence Wollersheim was FACT Net, 5 and I ?? 6 Q. But at that point was Lawrence Wollersheim 7 still FACT Net, do you know? 8 A. No. I'm telling you what I thought at the 9 time. 10 Q. Did Jesse tell you that? 11 A. No. 12 Q. Okay. 13 A. This was my assumption. I did not want to 14 see Lawrence Wollersheim. Lawrence Wollersheim and 15 I never got along well. I did not want to go into 16 this thing but I didn't want to get into this with 17 Jesse. As far as I was concerned, my attitude was, 18 Jesse, you're walking into a guy that's really 19 difficult to work with, but my attitude is I never 20 try to influence someone. If he wants to find out 21 how difficult Lawrence Wollersheim is to work with, 22 he can find out on his own. 23 Q. And Jesse never said anything like, well, 24 I don't have to work with Wollersheim, I'm working 25 with Minton? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 617 1 A. Well, you're telling me something I didn't 2 know at the time. 3 Q. You're saying he never told you that? 4 A. No. I didn't say anything. I didn't want 5 to talk about Wollersheim. I just said, well, hey, 6 Jesse, why don't you just drop me off, you know, 7 with the agreement that I ?? he says, yeah, I'll 8 fly you back to Seattle. 9 Q. Now, did he tell you where he was going to 10 live in Boulder? 11 A. He was just going to find a place. 12 Q. So he didn't tell you that a place was 13 being provided for him, much like your house, for 14 example, on Vashon Island, he didn't tell you 15 anything like that? 16 A. No. 17 Q. Okay. Did he tell you whether he was 18 going to get ?? he anticipated being paid by 19 anybody for whatever he was going to do in Boulder? 20 A. No. 21 Q. Did he tell you how he was going to live? 22 A. No. 23 Q. Did he tell you what kind of work he was 24 going to do? 25 A. No. I even got it wrong that it was ?? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 618 1 Wollersheim wasn't even there. That's how much I 2 was out of the loop. 3 Q. But in the ten days you were with him he 4 never discussed with you what he was going to do 5 out in ?? with FACT Net? 6 A. No. We have ?? we spent ten days 7 reconstructing and having a good time together as 8 old buddies, talking about war stories about David 9 Miscavige and RTC and the RPF and, wow, what about 10 this and that, and piecing together the puzzle, and 11 we had a great time, and then there is times you 12 just fell asleep in the car and listened to the 13 music. 14 Q. Did you do drugs on the trip? 15 A. No. 16 Q. Did he do drugs on the trip? 17 A. I didn't see him do drugs. 18 Q. I'm asking did it appear that he was 19 impaired in some way at any time on the trip? 20 A. No. He was a good driver. We had to 21 drive all the time. 22 Q. Did you or he drink on the trip? 23 A. Not on the trip, no. 24 Q. Not at all? 25 A. Well, on the trip, like we stayed in SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 619 1 Chicago, went to the nightclub where his brother 2 played, we had drinks at the nightclub, but on the 3 trip, no, we were driving. 4 Q. Did anybody give Jesse any money on the 5 trip? 6 A. Not that I saw. 7 Q. Did he talk about receiving any money on 8 the trip? 9 A. No. 10 Q. Was Jesse with any women on the trip? 11 A. No. There was women with his brother, 12 that was the only time when there was ?? oh, there 13 was a woman, a girlfriend that he was saying 14 good?bye to in Minneapolis. 15 Q. I'm talking about were there ?? did Jesse 16 arrange or pay for any women on the trip? 17 A. No, not that I know of. We always had 18 adjoining motel rooms. 19 Q. Now, and then you didn't see ?? you then 20 went from Denver to where? 21 A. Well, rather than go to Seattle, I decided 22 I had not seen ?? it felt good to get on the road 23 for all that time. 24 Q. Just the question: From Denver to where? 25 A. So I decided I'm going to go out to San SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 620 1 Francisco and see Ford Greene. 2 Q. And that just came to you when you got to 3 the Denver airport? 4 A. I was thinking about it just before I got 5 there. 6 Q. And had Jesse arranged for transportation 7 for you from Denver to Seattle, had he already 8 arranged for that? 9 A. No. He was going to arrange for it. I 10 don't know if he ?? I'm sorry. I don't know. He 11 had agreed that he would fly me from Boulder to 12 Seattle, and somewhere just before that I said ?? 13 it was, yeah, it was probably just the day before 14 and I said, Jesse, listen, I want to go to San 15 Francisco, I want to go see Ford, what do you 16 think? He says cool, we can change this. So maybe 17 there was a ticket that he changed. 18 Q. So how did you get this new ticket to go 19 from Denver to San Francisco? 20 A. We went into DIA. 21 Q. What's that? 22 A. Denver International Airport, and Jesse 23 was going to arrange it. The best I recall, I hung 24 out with the car rather than parking it and Jesse 25 was going to go arrange it, came back, I grabbed my SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 621 1 gear, see you later, here's your flight, good luck, 2 man, good luck with Lawrence, so much for me. 3 Q. What did the ticket say? 4 A. Denver to San Francisco. 5 Q. To Seattle? 6 A. San Francisco, I was going to San 7 Francisco. 8 Q. All right. But did it provide you with 9 transportation back to Seattle? 10 A. No. 11 Q. And did you ask him for that as well? 12 A. No. 13 Q. All right. And what did the trip cost, do 14 you know? 15 A. I don't know. 16 Q. And is there a particular reason why you 17 didn't go inside with ?? just park Jesse's car, go 18 inside and get the ticket and get on a plane? Why 19 did you wait outside? 20 A. Just, you know, the white zone is for 21 loading and unloading only. 22 Q. He's buying you a ticket to San Francisco 23 but he can't afford to park the car? 24 A. No. It was more of a case of he didn't 25 want his stuff ?? all of his stuff in the car to be SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 622 1 parked. It was all of his valuables and he wanted 2 to protect it. 3 Q. Well, what valuables were in the car? 4 A. The whole back end was backed with boxes 5 of his belongings. 6 Q. But what valuable was in the car? 7 A. I don't know, but you asked me earlier 8 about my personal valuables that I transported. 9 Those were his. 10 Q. Let me ask you something on this ten?day 11 trip, there were times when you and Jesse stayed in 12 the motel, right? 13 A. Right. 14 Q. You parked the car at night, right? 15 A. Yeah. 16 Q. Y'all unloaded it each night? 17 A. No. 18 Q. And you can't park the car at an airport? 19 A. Hey, you know, don't ask me to explain it. 20 Q. All right. Well, did Jesse not want you 21 to know how he was paying for this ticket? 22 A. I don't know. Maybe he got money from the 23 German conspiracy, I don't know. 24 Q. Well, did Jesse tell you that he was 25 interviewed by the German secret police, did he SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 623 1 tell you that? 2 MR. DANDAR: Asked and answered. 3 A. Five ?? in Denver, on the Denver trip? 4 Q. At any time did Jesse tell you that? 5 A. He told me he ?? let's move away from 6 Denver of a couple of years ago, to recently, 7 because from what I understand ?? otherwise, we're 8 going to slam the German thing back into Denver and 9 FACT Net. He told me he had been to Europe and had 10 met with some German government officials. I 11 didn't even want to ask him which ones because when 12 I went, the nature of the government and the fact 13 that they ?? the names of the agencies are in 14 German, I have great trouble. Somebody asked me 15 who you met with and I have trouble putting it 16 together. So I didn't even bother asking him who. 17 I said, oh, I know that routine. 18 Q. Did Jesse tell you that the German 19 government paid for his trip to Germany, did he 20 tell you that? 21 MR. DANDAR: Wait. Are we talking about 22 this trip to Boulder or are we talking about 23 something else? 24 MR. WEINBERG: Well, let's read my 25 question back. I don't think I said anything SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 624 1 about Boulder. Just go read that question, 2 please, when you get an opportunity. 3 MR. DANDAR: Because it's confusing. 4 MR. WEINBERG: No, there was nothing 5 confusing about my question, if you could just 6 read it. 7 (The question was read by the reporter.) 8 A. And I assume this is the trip of 1999? 9 No. 10 Q. Okay. Now, back in 1998 at the Denver 11 airport, you flew then ?? you said good?bye to 12 Jesse ?? well, he came back to the car. You were 13 double parked out there, is that ?? 14 A. No, we said good?bye somewhere. I know I 15 was in the airport by myself at that point and he 16 drove off. 17 Q. So you did park the car with his valuables 18 in it? 19 A. No. I said I was in the airport alone. I 20 just remember I did not say good?bye to him in the 21 airport. I said see you later, Jesse, good?bye, 22 and he left and I went into the airport. 23 Q. All right. He gave you the ticket, you 24 went in the airport, you got on the plane and went 25 to San Francisco? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 625 1 A. Finally, yeah. 2 Q. Met with Ford Greene, visited Ford Greene? 3 A. No. 4 Q. I thought you went to San Francisco to 5 visit Ford Greene. 6 A. I did. 7 Q. All right. So what happened in San 8 Francisco? 9 A. I got to San Francisco, suddenly realized 10 mid flight that I hadn't even called to see if 11 anybody was home. So I dug this phone out of the 12 back of the seat and there is nobody there, Ford is 13 gone off, thinking this is one of the dumbest 14 things I have ever done, to get on a plane to San 15 Francisco to see somebody without even calling from 16 Denver, are you there, Ford? So I landed in San 17 Francisco. So I was going to see him and I never 18 even got out of the airport. 19 Q. What did do you? 20 A. I called Stacy and ?? that's when I called 21 Stacy and I said, Stacy, I am very tired, I have 22 flown to Minneapolis, I've driven across country, 23 I've had a lot of discussions with Jesse, I've had 24 a lot of time to reflect on things, I'd like to go 25 to Well Spring. And she said where are you? I SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 626 1 said I'm in San Francisco, can you help me just set 2 it up? She said yeah. So I spent the night in San 3 Francisco airport because I just wanted to catch 4 the next flight out. There was no sense in, you 5 know ?? I was already landing at midnight. So I 6 just stayed there and caught an eight or nine 7 o'clock flight out in the morning to Columbus with 8 my dog. 9 Q. All right. Well, who ?? well, the dog was 10 with you ?? we neglected to talk about this but I 11 take it the dog was with you and Jesse the whole 12 way, right? 13 A. Yes. 14 Q. So you and the dog flew from San Francisco 15 to Columbus, is that right? 16 A. Yes. 17 Q. And your wife arranged for the ticket? 18 A. Yes. 19 Q. Who gave her the money for that? 20 A. I don't know. 21 Q. Did you ask her? 22 A. No. 23 Q. So you don't know as you sit here today? 24 A. No. 25 Q. All you know is that y'all didn't have SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 627 1 that kind of money, right? 2 A. Maybe. 3 Q. Well, did you say, Stacy, can you check in 4 the bank book and see if we've got, what, $1,000 to 5 book a ticket tomorrow for me to Well Spring? 6 A. No. 7 Q. Okay. 8 A. That's not the relationship we had. 9 Q. Did you ask ?? and had you ever discussed 10 Well Spring with Stacy prior to this time? 11 A. I testified yesterday she had told me 12 about Well Spring. 13 Q. Sometime prior to your trip to ?? trip 14 with Jesse? 15 A. Yeah. We're going over testimony I did 16 yesterday. 17 Q. Well, we didn't have it in any time frame. 18 So prior to your trip with Jesse, Stacy had said 19 something about Well Spring, right? 20 A. Here we go again. Yeah. 21 Q. Okay. Stacy had not been to Well Spring 22 at that point? 23 A. I'm having a weird deja vu. 24 MR. DANDAR: Objection; asked and answered 25 yesterday. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 628 1 A. I've gone over this. She had ?? and we 2 actually went over this, Mr. Wagner, that ?? 3 Q. Weinberg. 4 A. I'm sorry. I'm getting very tired. 5 Remember, she had gone to Well Spring, had spent 6 two weeks, she had urged me and told me it was much 7 better than she had ?? 8 Q. I'm just trying to get the date. So this 9 is prior to the trip with Jesse, right? 10 A. Yes. 11 Q. Okay. So she arranged ?? so you showed up 12 at Well Spring without talking to anybody at Well 13 Spring, is that right? 14 A. That's correct. 15 Q. And Mr. Haney picked you up and took you 16 to Well Spring, is that what happened? 17 A. No. 18 Q. You just took a cab to Well Spring? 19 A. No. 20 Q. How did you get to Well Spring? 21 A. I met somebody at the airport who was 22 picking up somebody or something and they were 23 driving down to Well Spring and our schedule 24 happened to coincide, so I rode with them down to 25 Well Spring. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 629 1 Q. This is not somebody connected with 2 Scientology? 3 A. No. 4 Q. Okay. This had been arranged by Stacy? 5 A. No. This was set up by me. 6 Q. How did you do that? 7 A. I called when I landed in ?? yeah, I 8 called when I landed in Columbus. 9 Q. So it was Stacy that told you that y'all 10 weren't going to have to ?? that you weren't going 11 to have to pay to spend time at Well Spring? 12 A. No. I knew that from earlier. 13 Q. From Stacy's experience? 14 A. Of her telling me. 15 Q. For her own experience you're talking 16 about? 17 A. Yes. 18 Q. And when Stacy, when you asked Stacy to 19 make the arrangements, you assumed that she would 20 make the same arrangements that she had made for 21 herself? 22 A. No. I told you yesterday, I said I'm 23 ready to take that rain check because she had been 24 urging me for a long time and I had been declining 25 for what seemed like a long time, and that's when I SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 630 1 said yesterday, okay, it's time to cash in this 2 rain check that you've been asking about, I'm ready 3 to go. 4 Q. I mean as far as the scholarship. 5 A. Yeah. 6 Q. So it was she that arranged for this ?? 7 for what you've called the scholarship? 8 A. I don't know that. It was she who told 9 me. 10 Q. You didn't arrange for it? 11 A. No. 12 Q. All right. Now, you spent two weeks at 13 Well Spring. When is the next time after that that 14 you see or communicate with Jesse Prince? 15 A. Six months later, during a drive west, and 16 I called in and found out Jesse was living in ?? 17 there in Boulder and that was when I dropped in 18 passing through probably on my way to Seattle. Do 19 you want me to wait? 20 Q. I'm listening to you. Excuse me. That 21 was on your way back to Seattle? 22 A. Probably on a trip to Seattle that I was 23 going to go through Denver, or go through the 24 Denver area and see him in Boulder. 25 MR. WEINBERG: Excuse me one second. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 631 1 MR. DANDAR: Do you need a break? Are 2 you okay? 3 THE WITNESS: Yeah. In about a couple 4 minutes I'm going to. Here comes the $100,000 5 question. 6 Q. And the circumstances that you saw Jesse 7 on that occasion? 8 A. And the circumstances was I was driving 9 west and he was en route. 10 Q. Driving west, this is after the Haney ?? 11 A. Yes. 12 Q. So there was no visit or communication 13 with Jesse Prince between basically the Denver 14 airport and after you quit working for Haney in 15 1999? 16 A. No. I'm sorry. When you said the Haney 17 thing, I misunderstood you when you said that. 18 This was probably just before. Remember I told you 19 beforehand I had driven west with a rental car? 20 Q. That Mr. Haney had provided for you? 21 A. Right. And that was during that trip up 22 to Seattle before I ?? before the whole project 23 that I passed through Boulder and saw Jesse. 24 Q. And what did you do with Jesse there? 25 A. Just caught up again, you know, just ?? I SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 632 1 think I spent just one night there. 2 Q. Do you have any idea what year we're 3 talking about? 4 A. Yeah, this is '99. 5 Q. Okay. Do you have any idea what month? 6 A. Oh, gosh. You know, it might even have 7 been late '98. 8 Q. Okay. How long did you spend with Jesse? 9 A. Just stayed overnight. 10 Q. Did you see anybody else? 11 A. No. 12 Q. And did Jesse tell you what he had been 13 doing at FACT Net? 14 A. No. 15 Q. Did he tell you ?? did he discuss either 16 Stacy or Bob Minton's involvement with FACT Net? 17 A. Never heard any of that. 18 Q. Did he tell you whether he had received 19 any funds? 20 A. Nope. 21 Q. Did he tell you what his state of mind 22 was? 23 A. No. 24 Q. Did you do any drugs? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 633 1 Q. Did he do any drugs? 2 A. No. 3 Q. Now, after that, when is the next time you 4 saw Jesse Prince or communicated with him? 5 A. Whenever I was coming back. 6 Q. You mean on your way from Seattle back to 7 Columbus? 8 A. Yeah, and I'm trying to remember if that 9 was the time I drove Seattle south, because it may 10 have been like a ?? yeah, it may have been. I may 11 have done this ?? yeah, I think I did this in 12 November, and then afterwards I drove ?? I stayed 13 in Seattle for a while, on Vashon, and then drove 14 south, went down and saw my son, then I headed ?? 15 do you want me to wait for you? Are you reading 16 something? 17 Q. No. I'm listening to you. 18 A. So maybe it was a month and a half, two 19 months later when I started heading back. 20 Q. Did Stacy ever tell you that she had 21 arranged for the car to be purchased that you and 22 Jesse drove in to move Jesse from Minneapolis to 23 Boulder? 24 A. No. Nobody told me anything about the 25 source of that car. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 634 1 Q. Did Stacy, as far as you know, travel in 2 that time period to Minneapolis? 3 A. As far as I know, she didn't. 4 Q. Did Jesse indicate to you that Stacy had 5 anything to do with him getting this car that you 6 and he were driving across the country? 7 A. I told you, nobody told me anything about 8 the origin or source or payment of that car. 9 Q. And you don't know of any involvement that 10 your wife would have had in that, is that right? 11 A. I'll repeat. I just said I know nothing 12 about whoever came up with that car. All I know is 13 it had a bunch of dents in the hood. 14 Q. Now, you were together with Jesse Prince 15 at Dan Leipold's office in Orange County in July of 16 1998, is that right? 17 A. That could be right. I was just thinking 18 about the July part. That ?? 19 Q. Well, do you remember that when you 20 learned that Jesse was, as you say, coming out of 21 the closet, that Jesse, the first basic thing that 22 Jesse did was go out to California and with a bunch 23 of people put together an affidavit or a 24 declaration that was to be used in the litigation, 25 do you remember that? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 635 1 A. I remember we were both out there and I 2 was helping Mr. Leipold, and the best I recall it 3 was something regarding the FACT Net. 4 Q. Do you remember ?? 5 A. Maybe not. 6 Q. I'm sorry. Are you done? 7 A. Yeah, I guess so. 8 Q. Do you remember helping Jesse Prince 9 and/or Mr. Leipold or anyone else craft a 10 declaration or affidavit for Jesse Prince? 11 A. I helped somebody edit an affidavit. 12 Q. Of Jesse Prince's? 13 A. I don't remember if it was Jesse's. It 14 was just one of these things where I got it as a 15 printout and it was a purely copy editor function 16 of correcting grammar, having nothing to do with 17 content, noticing that, you know, this is not a 18 clear sentence. It had nothing to do with content. 19 It was a complete copy editor function. 20 Q. That was with regard to an affidavit or a 21 declaration to be filed in the FACT Net case? 22 A. I think so. 23 Q. And that was ?? you were actually 24 physically in Mr. Leipold's office? 25 A. Yes. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 636 1 Q. And you were with Mr. Prince, weren't you? 2 A. Yes. 3 Q. And this was before you ever traveled 4 across country with Mr. Prince, wasn't it? 5 A. It was? 6 Q. Yes. 7 A. Okay. 8 MR. DANDAR: No. No. 9 Q. I'm asking. 10 A. I'm just ?? man, that just doesn't make 11 any sense whatsoever. 12 Q. Well, there are a lot of things in this 13 case that don't make a lot of sense. 14 MR. DANDAR: Just this deposition. 15 A. Well, you can accuse me of a lot of 16 things but ?? 17 Q. Let me just try to put this in some 18 perspective for you. Do you remember that the 19 first thing that occurred ?? go ahead. 20 A. Yeah, it was before Minneapolis. Okay. 21 Q. What makes you ?? what rings a bell there? 22 A. Yeah. Because I was ?? I drank about four 23 glasses of wine that night and Jesse told me, he 24 says, hey, man, you know, you got to cut back on 25 that shit, and I said I know, and that was one of SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 637 1 the reasons why I wanted to go to Well Spring, was 2 I realized that, yeah, that's too much, Jesse, I'm 3 doing that every night, I'd have some wine, and I 4 remember that because Jesse got ?? I remember he 5 got real mad at me, he got really mad at me, and I 6 remember that, and that would not have happened 7 after Well Spring because after Well Spring I dried 8 out. 9 Q. And then as a result of that drinking, you 10 ended up going back to Seattle before you took the 11 cross?country trip to Minneapolis and joined Jesse 12 and drove across the country, correct? 13 A. No. 14 Q. You don't remember that? 15 A. No. You're saying as a result of the 16 drinking. 17 Q. No. I'm saying that as a result of the 18 concern that you, Jesse, Stacy had with what was 19 going on with you, including the drinking, you 20 ended up leaving Los Angeles, or wherever Graham 21 Berry's office is, and going back to Seattle? 22 MR. DANDAR: Graham Berry? 23 A. No. No. 24 Q. I mean Dan Leipold. 25 A. No. I went back when the work was done. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 638 1 I was asked to help out and I went back when the 2 work was done. 3 Q. All right. 4 A. I was only there for about two days. 5 Q. And you were paid for that work? 6 A. I don't remember if I was or not, to tell 7 you the truth. 8 Q. Somebody paid your way down there and paid 9 your way back, right? 10 A. Yes. 11 (Discussion off the record.) 12 (Recess.) 13 MR. DANDAR: Because of this live feed, 14 which I was never provided notice of, it's ?? 15 I think it's appropriate for the court 16 reporter, and she has the e?mail addresses 17 that she's feeding this to, to put on the 18 record these e?mail addresses on the 19 Livenote.com because they are technically 20 making an appearance. 21 MR. WEINBERG: I don't know about the 22 e?mail but I can give you the name of who it 23 is that's on the other end. 24 MR. DANDAR: Well, I'd like that too, but 25 she knows the e?mail addresses. I think SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 639 1 that's technically more appropriate. 2 MR. WEINBERG: I don't think that the 3 e?mail address, in light of the ?? all the 4 allegations that go back and forth in this 5 case, ought to be on any record and I just 6 don't think that that should be the case, but 7 we can tell you who it is and it's the client, 8 on the other end. 9 MR. DANDAR: Who? 10 MR. WEINBERG: And all we're getting is 11 a ?? is what ?? is a feed of the deposition. 12 What's the big deal? 13 MR. DANDAR: Who is at the other end? 14 MR. WEINBERG: Wendy, I think, who has 15 made many appearances in this case and who's 16 last name I cannot spell or pronounce. 17 MR. DANDAR: Beccaccini. 18 MR. HERTZBERG: Beccaccini. 19 MR. WEINBERG: It's no big deal. I mean 20 all they're ?? as I understand it, now, maybe 21 I'm wrong, as I understand it, all they are 22 getting is a live feed of what's in the 23 machine and at some point none of that will be 24 useful because at some point the court 25 reporter will certify to a deposition SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 640 1 transcript which will be the operative 2 document. 3 MR. DANDAR: Well, there is more than 4 that going on because, you know, your 5 consultants here or representatives are 6 getting phone calls and coming in and handing 7 you questions. 8 MR. WEINBERG: Yeah, but, Ken, the reason 9 that we did this is that the court reporter 10 came to us the last time and said are you 11 interested in this program, and we said yeah, 12 I think she went to you too, and we said yeah, 13 we're interested in this program, that would 14 be nice. 15 MR. DANDAR: That's true, but it had 16 nothing to do with ?? 17 MR. WEINBERG: Anyway, we're not giving 18 you the e?mail address. Okay. 19 MR. DANDAR: All right. Just keep it and 20 I'll request it from the court because our 21 discussion had nothing to do with Internet 22 access, only to what goes on in this room. 23 MR. WEINBERG: Well, what do you want to 24 do? Do you want to send harassing messages on 25 the e?mail address, is that what you want to SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 641 1 do? 2 MR. DANDAR: No. We can seal it. I have 3 no intention of telling anybody. 4 MR. WEINBERG: Well, what's ?? 5 MR. DANDAR: It's technically correct. 6 MR. WEINBERG: Technically correct what? 7 What difference does it make? 8 MR. DANDAR: It's an appearance. 9 MR. WEINBERG: No, it's not. We are 10 entitled to ?? 11 MR. DANDAR: All right. Let's go. 12 MR. HERTZBERG: You know, Ken, you talk 13 about paranoia. 14 MR. DANDAR: Shhh. Stop. Let's just go. 15 We don't have to argue this anymore. 16 MR. WEINBERG: It's going to our client. 17 MR. HERTZBERG: It's going to the woman 18 who has appeared at a number of court hearings 19 and who you know to be affiliated with the 20 defendant FSO. 21 MR. WEINBERG: With Flag. 22 MR. HERTZBERG: With Flag. 23 MR. DANDAR: Is there more than one 24 e?mail address? 25 THE COURT REPORTER: (Shaking head.) SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 642 1 MR. DANDAR: Just one? Okay. Let's go. 2 We'll take it up later. 3 (The question and answer were read by the 4 reporter.) 5 BY MR. WEINBERG: 6 Q. The transportation to and from the first 7 Well Spring trip was arranged for by Stacy, is that 8 right? 9 MR. DANDAR: Asked and answered. 10 Q. Is that right? 11 A. Yeah. We did this twice, yesterday and 12 earlier. Yes. 13 Q. Just tell ?? just answer the question. Is 14 that right? 15 A. Yeah, but I've spent so much time doing 16 the same questions. 17 Q. You know what, that's not true. 18 A. It is true. 19 MR. DANDAR: Stop. Vaughn. 20 Q. You've got to understand that when you 21 take a break and we're in the middle of 22 questioning, I don't care how good the lawyer is, 23 it's pretty difficult to just resume, okay, without 24 getting some background. All right? 25 A. I apologize. Let's move on. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 643 1 Q. All right. Now, after ?? did you ?? did 2 Jesse tell you or did you learn that after you saw 3 him at Dan Leipold's office, whenever it was in 4 July of 1998, after he had announced that he was 5 coming out of the closet, and you worked with him 6 on his affidavit, that he then thereafter, or 7 shortly thereafter, went to New Hampshire and spent 8 time with Bob Minton, did he tell you that? 9 A. No. 10 Q. Did anybody tell you that? 11 A. No. 12 Q. So that on this trip, this cross?country 13 trip, this ten?day trip where you were going over 14 old times and new times, I suppose, with Jesse, it 15 just never came up? 16 A. It never came up. 17 Q. No mention of Bob Minton? 18 A. No mention of Bob Minton. 19 Q. You didn't tell him how generous Bob 20 Minton had been with you and the cats, right? 21 A. I probably did mention how the Mintons, if 22 I may correct you, by the fact that we were on 23 Vashon Island. 24 THE WITNESS: I'm sorry, Marty, that you 25 find that amusing but it's the truth. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 644 1 Q. Well, but you don't remember whether you 2 did or not? 3 A. No, but it seems like something I would 4 say, because he asked, you know, what you doing, 5 and we're on Vashon, how did you get there. It's 6 the most natural thing for me to do it was 7 certainly no secret, nothing I would want to hide. 8 I don't remember specifically saying it but it 9 would be something I would say. 10 Q. Well, can you see any reason why 11 Mr. Prince wouldn't tell you if Bob Minton had 12 bought a new car for him? 13 A. That's up to him. 14 Q. I'm just saying can you see any reason why 15 he wouldn't want to tell you that? 16 A. I can't see a reason why he would or 17 wouldn't, either way. 18 Q. Can you see any reason why he wouldn't 19 have told you that the money that was being used to 20 finance his trip for you and him was coming from 21 Bob Minton, can you see any reason why he wouldn't 22 have told you that? 23 A. I can't see a reason either way, for the 24 second time. 25 Q. Now, after the Well Spring visit or stay, SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 645 1 I guess, when was the next time ?? that's not a 2 good question. In point of time, when did you next 3 see or communicate with Jesse Prince? 4 A. The two trips West and back East. 5 Q. Okay. Those are social visits, right? 6 A. Yes. 7 Q. Now, after that, when is the next time you 8 communicated or saw Jesse Prince, communicated with 9 or saw Jesse Prince? 10 A. I drove cross?country back and forth four 11 times. I'm trying to determine which times I saw 12 him. I have so many miles and so many months on 13 the road. 14 Q. Too bad you don't get frequent flyer for 15 that. 16 A. Boy, I tell you, man, if I got anything 17 close to it. I love the road. I want to say I saw 18 him again on one of the trips but either in or out 19 again, which was to southern ?? yeah, there we go. 20 I think it was ?? no, I ?? no, he wasn't there. 21 Sorry. I take that back. That was in August when 22 I drove out to see my son. He wasn't there. It 23 seems like there was one other time I did it, 24 again, just passing through, a social visit. 25 Q. When is the next time that you remember SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 646 1 seeing or talking to Jesse Prince? 2 A. In Columbus, as ?? 3 Q. At the Red Roof Inn? 4 A. Yes. 5 Q. And since the Red Roof Inn, which you've 6 already testified about, when is the next time you 7 saw or talked to Jesse Prince? 8 A. Here. 9 Q. So there has been no other time between 10 the Red Roof Inn where you're working for this 11 unidentified lawyer and the last couple of days, is 12 that right? 13 A. Not that I can ?? no, not that I recall, 14 no. 15 Q. Okay. Now, as far as Stacy is concerned, 16 when prior to the last few days is the last time 17 you saw or communicated with Stacy? 18 A. Prior to these last couple of days? 19 Q. Yes. 20 A. Oh, there was a phone call ?? I don't know 21 if she called me and left a message and I called 22 her or she just called and reached me, oh, maybe a 23 month ago. We talked on the phone. 24 Q. Did this have anything to do with 25 Scientology or a case? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 647 1 A. No. It was just a, you know, what's 2 happening, you know, I want to tell you about a 3 couple of cats and how things went. 4 Q. So it has nothing to do with this case or 5 any other case? 6 A. No. 7 Q. When is the last time you had any 8 communication or contact with Stacy that had to do 9 with any Scientology?related case, other than the 10 last few days? 11 A. Well, the one that she told me that Jesse 12 had filed a declaration. We didn't discuss the 13 case but she was the one that sent me Jesse's 14 declaration. 15 Q. Prior to that? 16 A. Nothing for a year and a half before that. 17 Q. You appeared or were interviewed for the 18 Dateline show that aired in June of 1998 about 19 Scientology, is that right? 20 A. Well, I will assume ?? it was Dateline. 21 I'll accept your date. 22 Q. Well, you remember you and Stacy being 23 interviewed for that show? 24 A. Yes. I just don't remember if it was 25 June. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 648 1 Q. Do you remember talking to Jesse about 2 that show? More specifically, do you remember 3 Jesse saying that's how he was able to find you, by 4 seeing you on that show? 5 A. Yes. 6 Q. That that was the sort of precipitating 7 event that got him to call you and ?? in or about 8 June or July of 1998? 9 A. That may be the case, yeah. 10 Q. Now, that show was all about Bob Minton, 11 wasn't it? 12 A. I don't think so. 13 Q. Well, didn't the show ?? 14 A. I don't remember the content. 15 Q. Well, don't you remember that on the show 16 they talked about him purchasing the house for you 17 and Stacy, do you remember that? 18 A. They may have gotten it as wrong as you 19 about him or the Mintons purchasing it, but that 20 was brought up in the show, yes. 21 Q. And don't you remember that it was brought 22 up in the show about all this money that he had 23 spent against Scientology? 24 A. I don't remember. There is videotapes. I 25 didn't edit or air the shows, I wasn't part of SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 649 1 that. 2 Q. Did you watch it on TV or did they send 3 you a tape or what? 4 A. I don't know. I guess we caught it when 5 it aired. 6 Q. You were with Stacy when you watched it? 7 A. Probably. 8 Q. When were you interviewed for the show? 9 A. A couple of months before. It took quite 10 a while to get it out of the can. 11 Q. I'm sorry. I didn't understand what you 12 just said. You mean for the show after you were 13 interviewed to be on the air? 14 A. Yes. 15 Q. Where were you interviewed? 16 A. On Vashon. 17 Q. What is the source or basis for your 18 continual claim that Mrs. Minton had anything to do 19 with purchasing the house? 20 A. The two of them are the legal owners, they 21 signed and it's on the document that you presented 22 to me. It's your exhibit. 23 Q. So that's the basis of it, it's not 24 something that Bob Minton told you, I take it, 25 right, specifically discussed with you? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 650 1 A. No, but we knew that the property was in 2 their names. 3 Q. I see. Okay. How long was ?? do you 4 remember when you were interviewed by Dateline? 5 A. No. 6 Q. Do you remember who set that up? 7 A. Dateline. 8 Q. What did they tell you they wanted to talk 9 to you about? 10 A. Scientology. 11 Q. You don't remember the name of the 12 reporter? 13 A. Well, I think his name was Hawkenberry but 14 the reporter never sets up the show. It's always a 15 producer that sets up the show. 16 Q. Well, did the reporter come and interview 17 you? 18 A. Yeah. 19 Q. So it was ?? if it was John Hawkenberry, 20 was he in a wheelchair? 21 A. Yes. 22 THE WITNESS: What time is it? 23 MR. DANDAR: 5:30. 24 A. Any estimate how much longer? 25 Q. It's not going to be much longer. I've SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 651 1 got to go to the office. 2 A. You said ten minutes about 20 minutes ago, 3 and then we still want to do another week? 4 Q. Well, I'm not done, I'm not going to get 5 done, but let me ?? 6 A. Well, then why don't we just end all ?? if 7 you're not done, let's just end. I'm getting ?? 8 Q. Can I finish my train of thought? 9 A. I'm really tired, and you said ten minutes 10 20 minutes ago. 11 Q. I understand, but with regard to this ?? 12 MR. DANDAR: Let's try five minutes. 13 Q. Why don't I just finish the thing that 14 I'm doing right now? 15 A. We did ten. I'm really getting tired. 16 We've gone past ?? it's 5:30 and then you now want 17 to continue it on. So if you're going to continue, 18 we just move the questions off into another day. 19 Q. All right. But since we're in the middle 20 of something ?? 21 A. I really fought for you earlier, sir, and 22 I stuck it out and I spoke even on your behalf. 23 Q. What do you mean you fought for me? 24 A. Well, he was objecting and I said come on, 25 I can answer the question, if you remember, and I SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 652 1 said we were on a roll. 2 Q. Just so it's clear ?? 3 A. I really extended my courtesy on this ?? 4 Q. I know, but just so it's clear, you know, 5 I have made myself available at all times to be 6 available ?? 7 A. That's fine. I'm just ?? 8 Q. ?? to try to ask you the questions that I 9 think I'm entitled to ask you. You understand 10 that, right? 11 A. I understand. It's just that I'm getting 12 very tired and it's 5:30. 13 Q. Well, I understand that. That's fine. If 14 you want to stop now ?? well, it's not 5:30, but if 15 you want to stop now, that's fine. 16 MR. DANDAR: Excuse me. It is 5:30. Have 17 the court reporter tell us what time it is. 18 MR. WEINBERG: Okay. It's 5:30. 19 MR. DANDAR: We'll argue about that. 20 A. And you've already said you want to go 21 another day, so move it off on to whatever day ?? 22 Q. All right. Thank you. Okay. I mean you 23 certainly have the right to ask to adjourn the 24 deposition. 25 A. Sir, if it had been ten minutes ?? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 653 1 Q. I'm not arguing with you. I'm not 2 arguing. 3 A. ??I wouldn't have minded, and you just 4 said five, and if I knew it would be five, I could 5 manage it. 6 Q. No, I didn't say five. I said I will go 7 and Mr. Dandar asked me, as did Stacy, how long can 8 I go and I said would try to do as long as I could, 9 but I also need ?? 10 A. Can we do five? 11 Q. There is no reason. I mean I can't get 12 done in five minutes, and I've got to go to the 13 office, too. So we can ?? 14 A. Was there something that was pertaining to 15 Dateline that we can get on the end of a subject? 16 Q. Yeah, I think so. Yes. 17 A. If we can get onto the end of a subject, I 18 don't mind that. 19 Q. Okay. That's what I was going to do since 20 I had the document in front of me. 21 MR. DANDAR: Put your mikes back on. 22 THE WITNESS: I'm right here leaning over. 23 Can you guys here me okay? All right. I feel 24 like I'm back on Dateline. 25 SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 654 1 BY MR. WEINBERG: 2 Q. Do you remember how long the interview 3 lasted, approximately? 4 A. Well, you know, when they do interviews, 5 they do interviews and then B roll, where they 6 shoot you outside, so if you want to say the whole 7 shoot interview, is that what you mean, or just the 8 interview? 9 Q. The interview. 10 A. The interview itself was perhaps half an 11 hour. 12 Q. Did he tell you in advance what he was 13 going to ask you? 14 A. No. They never do. 15 Q. Did he play for you anything that other 16 people had said? 17 A. No. 18 Q. Did he tell you what Mr. Minton had said? 19 A. No. 20 Q. Were you aware that Mr. Minton had already 21 been interviewed or had been interviewed or was 22 going to be interviewed? 23 A. No. They never tell you things. They 24 just tape what you're doing. 25 Q. Did he ask you questions about Mr. Minton? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 655 1 A. I remember some questions about Mr. Minton 2 and the house. 3 Q. Now, was it you and Stacy together or just 4 you alone? 5 A. Me and Stacy together. 6 Q. And it was in the house? 7 A. In the house and outside the house, on the 8 property. 9 Q. Do you remember that on the show there 10 comes a point in the show where the reporter says, 11 I assume this is Mr. Hawkenberry: Not 12 surprisingly, Minton has developed a loyal and 13 passionate following among some former 14 Scientologists. In the home of Vaughn and Stacy 15 Young, the name Bob Minton is practically holy. 16 And then you're quoted as saying: You've 17 heard of these types, people call them angels, that 18 just show up and just do these things. 19 Do you remember saying that? 20 A. Yes. 21 Q. So you considered Mr. Minton to be an 22 angel? 23 A. No. I said ?? that's not what I said. I 24 said people ?? I said exactly what I said but I 25 never called him an angel. I don't believe in SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 656 1 angels. 2 Q. Do you remember that Stacy said: We were 3 about a week?and?a?half away from having to move, 4 we were in the state of catastrophe. 5 And the reporter said: And right around 6 that time Stacy and Vaughn Young got a call. 7 And you said: He says my name is Bob 8 Minton, I read what was happening with your animal 9 sanctuary and I just want to know if there is some 10 way I could help you out. 11 And the reporter said: Out of the blue 12 this Bob Minton, this voice on the phone, came into 13 their lives. He bought the Youngs a new house 14 where they could legally keep the animals for 15 $250,000. Incredibly, he saved the animal shelter. 16 Stacy says she'll never forget the day she picked 17 up her new kitty. 18 Do you remember that being said in the 19 show? 20 A. Sort of. I remember more what we said 21 than what the final show said. Was there a 22 question? 23 Q. I was asking if you remembered that. 24 A. Oh, I answered it. 25 Q. Do you remember that Stacy said that when SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 657 1 you came into the house the first time, we opened 2 the front door and Bob Minton had a huge bouquet of 3 flowers on the table for us, it was incredible, it 4 was real, it was really ?? it really was real, do 5 you remember Stacy said that? 6 A. I remember her saying that, huge. It 7 wasn't huge. It was decent but it wasn't huge. 8 Yeah, I remember her saying that. A few flowers, 9 she considers a few flowers a big bouquet. 10 Q. You didn't express to the reporter your 11 personal feelings with regard to what Mr. Minton 12 had done as it related to your life, correct, you 13 didn't tell him that, did you? 14 A. No. The matter was about the cat 15 sanctuary. 16 Q. All right. 17 A. I already had a house, I just didn't have 18 a place for the cats. 19 MR. DANDAR: It's 5:35. 20 MR. WEINBERG: Okay. Why don't we stop 21 now. 22 THE WITNESS: Thank you. 23 MR. WEINBERG: Just so the record is 24 clear ?? just so the record is clear, we're 25 not done, and Mr. Hanes wanted me to say ?? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 658 1 Hanes, I think ?? 2 MR. DANDAR: Ron Hanes. 3 MR. WEINBERG: Ron Hanes wanted me to say 4 that he intended to ask some questions, as I 5 believe Mr. Titus does too. 6 MR. DANDAR: Well, I'll be moving for a 7 protective order. 8 MR. WEINBERG: Move all you want to. 9 MR. DANDAR: We'll have a hearing on the 10 abuse of this deposition. 11 MR. WEINBERG: You know, Ken, there is 12 nothing abusive about this. 13 MR. DANDAR: I don't need to argue with 14 you. 15 MR. WEINBERG: Well, then why do you say 16 things like that? 17 MR. DANDAR: Because I'm telling you what 18 I'm doing on the record. 19 MR. WEINBERG: Is that like a threat? 20 MR. DANDAR: No, just advising you what's 21 happening. 22 MR. WEINBERG: Then why do you say things 23 like that, just to argue? 24 MR. DANDAR: Because this is an expert 25 witness. You've never asked him one question SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 659 1 about his opinions. 2 MR. WEINBERG: Well, I haven't gotten to 3 questions about his opinions. Is there some 4 rule that I've got to ask him questions about 5 his opinions? I can't ask him about his ?? 6 you know, what the information is that he 7 supposedly knows that could lead to any 8 opinion? I don't have a right to ask him 9 about what his bias is? I don't have a right 10 to ask him whether he's bought and paid for? 11 I don't have a right to ask him what his 12 relationship is with all these other so?called 13 experts in this case? I don't have a right to 14 ask him ?? I haven't got to this yet ?? about 15 all the money that he's gotten over the years 16 from lawyers like you, paid to say things that 17 are untrue, I don't have a right to ask him 18 anything like that, is that what you're 19 telling me? 20 MR. DANDAR: You didn't ask him those 21 questions. You abused the process. 22 MR. WEINBERG: Well, you know what, Ken, 23 I haven't abused the process but you've abused 24 the process by making frivolous objections and 25 by making outrageous statements like that. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 660 1 That's it. 2 MR. DANDAR: Well, have a nice holiday. 3 (Discussion off the record.) 4 MR. DANDAR: We're declaring this whole 5 thing confidential. He will read it. Send it 6 to me and I will get it to him. 7 THEREUPON, the deposition of ROBERT VAUGHN 8 YOUNG was adjourned at 5:45 p.m. 9 NOTE: The original and one copy of the 10 foregoing deposition will be held by Mr. Shaw; copy 11 to Mr. Dandar. 12 ARRANGEMENTS for the reading and signing 13 of the deposition transcript will be handled by the 14 office of Kennan G. Dandar of the firm Dandar & 15 Dandar, 5340 West Kennedy Boulevard, Suite 201, 16 Tampa, Florida. 17 18 19 20 21 22 23 24 25 SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 McPherson v Church of Scientology / 97?01235 661 1 SIGNATURE PAGE 2 Volume IV 3 I, ROBERT VAUGHN YOUNG, have read the 4 foregoing deposition given by me on December 22, 5 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 Subject to the above corrections, if any, 18 my testimony reads as given by me in the foregoing 19 deposition. 20 SIGNED at _________________, Florida, this 21 __________ day of ____________________ , 19___. 22 23 24 ________________________________ 25 ROBERT VAUGHN YOUNG SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 662 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 Susan D. Wasilewski, RPR, CRR 15 Notary Public ? State of Florida 16 My Commission Expires: 10?23?03 17 18 19 20 21 22 23 24 25 SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 663 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