---

DR. WILLIAM Z.,
called as a witness On behalf of the Defendant herein, after having been first duly sworn, was examined and testified as follows:

DIRECT EXAMINATION
BY
MR. DE VLAMING :

Q State your name, please?

A My name is Dr. William Z______. I live in Chicago, Illinois.

Q What are you a doctor of?

A Dentistry.

Q Dr. Z., back on January 25th of 2000, did, you have an occasion on that date to meet with a man named Mark Bunker, the Defendant in this action?

A Yes, I did.

Q Earlier on that date, did you have occasion to be in his presence when Mr. Bunker had with him what appeared to be a video camera?

A Yes.

Q And, did you watch him load that video camera with any cassette or film?

A Yes, he did.

Q Did you actually see him put film in the camera?

A I actually saw him put it in the camera.

Q Did he video any tape of you and your wife?

A Yes he did. He had an interview with us over an hour.

Q Did he affix to you some device that allowed your voice to be picked up and transmitted to his camera?

A It was a little microphone on my tie.

Q That was a cordless mike?

A Yes.

Q Did you go with Mr. Bunker with his camera to 3011 North Lincoln Avenue, in Chicago?

A yes, I did.

Q And, is that the location of the; Church of Scientology?

A Yes,I did.

Q The purpose of going there was what?

A We invited him to go there with us to film an interview, so we could get our money back at the Church of Scientology.

Q You were going to get an application to get about $100,000 back from the Church of Scientology for monies you had given them?

A yes.

Q And, Mr. Bunker had agreed to help with that endeavor with you and your wife?

A Yes, sir.

Q As you came up to the building of Scientology, who was first, second, and third, or were you all together?

A I was in front, and I was walking up to the door, and my wife was behind me, and Mark Bunker was ten to fifteen feet behind them, and he was filming.

Q And, what was the purpose when you going up to the Church of Scientology, what were you going there for?

A We were going together at 7:30 p.m., and we were asking them for permission for Mr. Bunker to videotape the interview.

Q Did you have to open the door to the Church of Scientoloqy?

MS. WRONKIEWICZ: This is beyond the scope of these hearings.

THE WITNESS: I walked up to the door and I opened the door.

MR. DEVLAMING: Q Did you qo to the building?

A I (entered on the carpeting, and I turned around because there was a commotion on the sidewalk, and I saw these two men attacking Mr. Bunker.

WRONKIEWICZ: Objection to the characterization.

THE COURT: Overruled.

MR. DE VLAMING: Q Where was Mr. Bunker at the time these men came up to him?

A On the public sidewalk.

Q Were the men clothed in any type of police uniform?

A No, they were not.

Q Did they have any badges on?

A. NO, they did not.

Q And, what did you see, in relation to the camera that Mr. Bunker had when he was in the presence of those two men?

A The cell phone dropped out of his pocket, and my wife picked that up, and they were trying to handcuff him, so he took the camera and he sat it down on the ground next to his right foot. I was standing on his riqht side.

Q What did you do?

A I reached down and picked up the camera, and the light was sti1l on the camera and the camera was still filming, and I continued to film.

MS. WRONKIEWICZ: Objection to continuing to film.

THE COURT: Overruled.

MR. DE VLAMING: Q You said that the light was still on. What do you mean?

A There was a red light on. When the cassette is in the camera, the camera is operating

MS. WRONKIEWICZ: I am going to object to him testifying as an expert.

THE COURT: Overruled.

MR. DE VLAMING Q Did you actually see this red light on?

A I sure did.

Q And, it was in your custody when the light was on ?

A The light was on, and it was filming these officers.

Q Did you aim the camera towards the individual that were arresting Mr. Bunker?

A Yes.

Q And, do you believe that the tape would have shown were the officers and Mr. Bunker were on the sidewalk at the time?

A Absolutely. Yes.

Q When did that camera leave your person?

A The shorter of the two policemen took the camera from me. He said, "Give me the camera." I said, "What are you going do with that?" He said, "I will take it."

Q Did the shorter of the two officers take the camera?

A Yes.

Q Was the red light on when he took the camera?

A The light was still on.

Q What did you see happen to the camera next?

A He took the camera, and I was trying to turn off the light, and I was turning in the camera, looking at it to turn the camera off.

Q When was the last time you saw the camera?

A lady officer walked up with him, and they walked up with they walked up with the camera. I saw the lady officer carrying the camera and put it in the front seat of the police vehicle.

MR. DE VLAMING: No further questions.

THE COURT; State?

Cross.

CROSS EXAMINATION
BY
MS. WRONKIEWICZ:

Q What time was this interview that you had with Mr. Bunker, prior to going to the Church of Scientology7

A 7:30.

Q What time was the interview that interviewed you and your wife?

A That was, at 4:00 o'clock in the afternoon.

Q Now, you testified you had not called the Church of Scientology to ask their permission to bring Mr. Bunker, is that correct?

A That's right.

Q But, you had arranged this meeting at the Church of Scientology prior to arriving, correct?

A That's right.

Q Sir, since it's true that when you arrived at the Church of Scientology, you were there with your wife and Mr. Bunker correct?

A. That's correct

Q And, at some point, you saw Mr. Bunker placed under arrest, is that correct?

A. That's correct

Q And, Mr. Bunker was trying to use his cell phone while being placed under arrest, correct?

A I did not see that I know it fell out of his pocket.

Q In addition, while the defendant was being placed under arrest, his video camera actually fell to the ground, correct?

A No, that is not correct.

Q Sir, in addition to yourself, Mr. Bunker, and your wife, there were other individuals around in front of the Church of Scientology, correct? .

A Yes.

Q And, there were about five or ten people outside the Church of Scientology correct?

A I believe so, yes

Q When Mr. Bunker was being placed under arrest, you and your wife, you were present when your wife was speaking to these officers, correct?

MS. AIMEN: You said that when Mr. Bunker was being placed under arrest you were having a conversation with the officer?

THE WITNESS: yes.

MS. KRONKIEWICZ: Q Your wife was screaming at the officer, correct?

MS. AIMEN: Objection.

THE COURT: Overuled.

THE WITNESS: She had shown no ID .

MS. KRONKIEWICZ: Q Her voice was raised when she was asking to see the identification?

A Yes .

Q In fact, she was saying that she did not believe they were police officers, is that correct?

A True.

Q At the same time, Mr. Bunker was placed under arrest, right?

A Yes

Q In addition, there is a bar located across the street from the Church of Scientology?

A I think so.

Q Several patrons from the bar came out onto the scene, correct?

A I did not see anybody from tbe bar.

Q In addition to the two police officers that were there, a single female officer arrived in a squad car, correct?

A Yes.

Q In addition to the officers, there were at least one of two more squads that arrived on the scene?

A That's right.

Q Would it be fair to describe this as a chaotic night?

A No.

Q While the Defendant was being placed under arrest, the Defendant's wife was screaming at the officer. "where is my video camera? Where is my video camera?" Correct?

A I did not hear that, no.

Q In fact, one of your officers, the shorter one, came up to you that you must give over the defendant's video camera, correct?

A He said "Give me the camera."

Q He also told you that that's because Mr. Bunker was being placed under arrest and his property, correct?

A He said that was his property. Mr. Bunker "What are you going to do with it" and the police officer said, "Take it to the station."

Q And, you would not give that officer the video camera, correct?

A That's not true. I gave him the camera.

Q Initially, you would not qive it to him, correct?

MS AIMEN: Objection to the term "initially"

THE COURT: Sustained.

MS WRONKIEWICZ: Q You did not just hand over the video camera to the officer?

A I had the camera in my hand. He said, "Give me the camera. I said, "What are you going to do with it? And, he said, take it to the station." And, I let him have it.

Q You saw that police officer hand that video camera to another police officer, and it was immediately placed in a police vehicle?

A When I saw her walk with the camera in her right hand and then
put the camera in the vehicle.

Q At some point, the video camera was on the ground, correct?

A It was set on the ground for a second.

Q While the camera was on the ground, the people frome the Church of Scientology had access to it?

A I don't think so. It was right at my feet, between myself and Mr. Bunker. for around for a second.

MR. DE VLAMING: Indicating, for the record, he is pointing to the ground to the space between himself and Mr. Bunker as he stands in the courtroom.

MS. WRONKIEWICZ: Q One of the officers who arrived on the scene was a short female officer with brown hair, who you had met two weeks before, correct?

A Yes.

Q Two weeks before, you had a conversation with her, correct?

A Yes.

Q And, she also told you that she could not come to the Church of Scientology without makinq an appointment?

A We made an appointment, yes.

Q Is that why she had told you to make an appointment?

A Yes.

Q One of the officers who placed Mr. Bunker under arrest, he was also present on the scene when you were talking to this officer, correct?

A Yes .

Q Did you tell the officer that you had called the police before you had even come to the Church of Scientology?

A Yes.

Q At some point, did the officers show their badges? Correct?

MS AIMEN: Objection, as to which officer.

THE COURT; Sustained.

MS. WRONKIEWICZ: Q The two officers that placed Mr. Bunker under arrest did show you some badges, correct?

A I saw no badges .

Q Well, sir, did you hear your wife yelling, "Those are not real badges those are fake badges"?

A I know that one officer presented her a card .

MS. AIMEN: I would object that she said she saw no badqe

THE COURT: Overruled.

MS. WRONKIEWICZ: Q So, the officer handed your wife some type of identification, correct?

A Yes

Q Your wife was questioning the identification that she had been handed by the officer?

A Yes.

Q Sir, it is your testimony that you had possession of Mr. Bunker's video camera the whole time he was being placed under arrest, correct?

A No.

Q But, you did have the Defendant's video camera in your possession when the police were looking for it, correct?

A I sat it down on the ground, and I was being handcuffed. I put the camera down, and he picked it up.

Q So, you did not have the Defendant's camera in your possession, correct?

A For fifteen seconds, yes.

Q This microphone that had been used on you earlier for in interview, were you wearing this microphone when you arrived at the Church of Scientology?

A No.

Q Did your wife have this microphone on when she you arrived at the Church of Scientology?

A Not to my knowledge.

Q Did you have a type of interview that you and your wife did as you are having here in court today?

A No.

Q Do you know how many hours of videotape Mr. -- first of all, from the time that Mr. Bunker interviewed you and your wife earlier in the day, did you ever ask --

Judge, I have to strike that for a second.

A.The interview that you and your wife gave to Mr. Bunker, you testified that that lasted an hour, correct?

A That's correct .

Q Do you have any personal knowledge of how many hours of videotape that videotape could hold?

A No.

Q And what time did you say that videotape was?

A It was in the afternoon, at 4:00 o'clock.

Q You never saw Mr. Bunker load the videotape with the video camera prior to going to the Church of Scientology at 7:30, did you?

A No.

MS. WRONKIEWICZ: I have nothing further, Judge.


REDIRECT EXAMINATION
BY
MR. DE VLAMING:

Q The purpose of bringing the tape to the Church of scientology was what?

A To interview us outside the church on the front sidewalk.

Q And, when you picked the camera up, did there appear to be any damage to the camera, as if it had been dropped?

A No.

Q When the Officer had the camera in his hand, looking for the light, whether be even found the off button in your presence turn the light off --

MS. KRONKIEWICZ: Objection .

THE COURT: Overrule.

THE WITNESS: I did not see him turn off the light.

MR. DE VLAMING: Thank you.

RECROSS EXAMINATION
BY
MS. WRONKIEWICZ:

Q You are not an expert in the use of video cameras, correct?

A That's correct.

MS. WRONKIEWICZ: I have nothing further

THE COURT:Anything else?

MR. DE VLAMING: Nothing of this witness.

---

Bill Z. Trial Testimony

MR. DE VLAMING: Yes, we are ready, Judge. I will call Dr. William Z. to the stand, please.

THE COURT: Sir, step up here, will you please. Face me, if you would.
(Witness sworn.)

THE COURT: Proceed.

MR. DE VLAMING: Tell us your name, please.

THE WITNESS: Dr. William R. Z. Z________.


DR. WILLIAM R. Z.,
called as a witness on behalf of the Defendant, having been first duly sworn, was examined and testified as follows:

DIRECT EXAMINATION
BY MR. DE VLAMING:

Q. Where do you reside, Dr. Z.?

A. In Chicago, Illinois.

Q. And you are a doctor of what?

A. Dentistry.

Q. How long have you been a doctor of dentistry?

A. 35 years.

Q. And are you married?

A. Yes, I am.

Q. And your wife's first name is?

A. Barbara.

Q. She is also a doctor of dentistry?

A. Yes, she is.

Q. You practice that specialty together?

A. Yes, we do.

Q. Dr. Z., were you one time a member of the Church of Scientology?

A. Yes.

Q. And can you tell me approximately over what span of time you were a member of the church?

A. Since '97, '96, '97.

Q. Was there a time that you wanted to leave the Church of Scientology?

A. Yes.

Q. And specifically, had you given that church a certain amount of money?

A. Yes, we did.

Q. For what purpose was the money given?

A. For courses.

Q. For courses?

A. And training.

Q. Approximately, how much money are we talking about?

A. $130,000.

Q. Was there a time that you had made a request for the return of money from the Church of Scientology?

A. Yes.

Q. And approximately how long did you make an effort to return of money that was due to you?

MS. WRONKIEWICZ: Objection.

THE COURT: Sustained.

THE WITNESS: About '97, about three years.

THE COURT: Sustained.

BY MR. DE VLAMING:

Q. Were you able to get your money back?

A. Yes. Now, we did.

Q. Let me rephrase the question. Up until the time of the 25th of January, 2000, before Mr. Bunker came to town, were YOU able to get the money back?

A. No.

Q. In an effort to be able to get money back that was due to you, did you take any action or make any phone calls?

A. Yes, we did.

Q. And who did you contact?

A. We contacted Mr. Jim Bebe from the network.

Q. From the what?

MS. WRONKIEWICZ: I am sorry. I did hear it.

THE WITNESS: Cann, which is Warner network.

BY MR. DE VLAMING:

Q. HOW did you eventually get to Mr. Bunker?

A. Through his referral.

Q. Did you have a conversation with the organization that Mr. Bunker works for?

MS. WRONKIEWICZ: Objection, Judge.

THE COURT: Sustained.

By MR. DE VLAMING:

Q. Well, how did you contact Mr. Bunker, tell us that?

A. 1 was given his phone number from Mr. Jim Bebe.

Q. And did you make contact with him?

A. Yes, I did.

Q. And was -- were there any arrangements made for Mr. Bunker to come to the City of Chicago?

A. Yes. We had asked him to come to Chicago.

Q. For what purpose was that?

A. To help us get our money back.

Q. And did you meet with Mr. Bunker on the 25th of January?

A. Yes.

Q. Had you met with him before that time?

A. No. That was the first time that I met him.

Q. Okay. And on the 25th of January, did he have equipment with him; that is, photographic equipment, videotaping equipment?

A. Yes, he did.

Q. Was there a time that day that you were -- they had a microphone placed upon You?

A. Yes. We did an interview earlier.

Q. That's what I was getting to. Earlier in the day, You did an interview or Mr. Bunker did of you and your wife?

A. That's right.

Q. And did he have with him a video camera for that purpose?

A. Yes, he did.

Q. What was the purpose of that interview?

MS. WRONKIEWICZ: Objection.

THE COURT: Sustained.

BY MR. DE VLAMING:

Q. After the interview -- first of all, did you see him load the camera with tape for that purpose?

A. Yes, I did.

Q. And when he was taping, did you notice anything about the camera whether it was turned on?

A. The red light was turned on.

MS. WRONKIEWICZ: Objection.

THE COURT: Overruled.

BY MR. DE VLAMING:

Q. He was filming. I didn't hear you?

A. The red light was on when the camera was on.

Q. And had YOU had a prearranged meeting to be able to go to the Church of Scientology in order to discuss this money issue?

A. Yes, I did.

Q. And approximately what time was that?

A. 7:30 in the evening.

Q. Were You going to bring Mr. Bunker with you?

A. Yes.

Q. Why?

A. We were going to ask permission if it was all right if he came to tape the interview.

Q. The interview. You mean, the interview so that you could obtain the money back?

A. I asked for the money back, yes.

Q. Did you -- and your wife accompany you?

A. Yes.

Q. Did you, in fact, did Mr. Bunker go to the area of 3011 North Lincoln Avenue?

A. Yes, we did.

Q. Tell US what happened when you first arrived?

A. There were people on the street uP and down South Port and Lincoln Avenue and we drove by and there was no place to park. All the parking places were filled so we went around the block and parked on the next street on Wellington.

The three of us got out of the vehicle and walked towards the church and crossed Lincoln Avenue and walked up on the sidewalk in front of the Church of Scientology.

Q. Okay. To your knowledge, is that the first time that Mark Bunker had been at that location?

A. Yes.

Q. As you walked towards the church to the entrance of Church of Scientology, would you tell the jury who was -- in what order you walked up to the entrance of the church?

I was in front and my wife was behind me and Mark Bunker was back further filming us as we approached the door.

MS. WRONKIEWICZ: Objection.

THE COURT: Overruled.

BY MR. DE VLAMING:

Q. And did you -- did you, Dr. ZiZiC, actually get to the front door of the organization?

A. Yes, I did.

Q. Tell US what happened at that point, as you reached the front door, what happened?

I reached the -- I got to the front door and 1 reached for the door and I pulled the door open and I stepped back. It opens out into the vestibule. And then, my wife was behind me and Mark Bunker was on the sidewalk and I turned around like this and the next thing I saw was two men jump Mr. Bunker and push him back.

Q. Will you describe these men?

A. One was tall and big and the other one was shorter, both had black jackets and looked like black pants.

Q. Did they have any identifying words on their clothing?

A. No, they did not.

Q. What did you say when you -- now, you said they jumped Mr. Bunker. Describe what you actually saw?

Well, they rushed up to him and grabbed him on the arms and pushed him back.

Q. Did you hear what either Mr. Bunker were saying or what the men were saying to him?

A. Not until later.

Q. All right. SO what did you do with the door at that point in time?

I let go of the door and I started walking towards the sidewalk.

Q. Tell me what you saw and heard?

A. I stood behind my wife and she was having a conversation, a loud conversation with this police officer. He said that he was, you know, she asked who are you and she didn't believe that he was a police officer and he pulled out some kind of a badge.

It looked like a license and the picture was smudged off she said and I stood there and observed that. And then, they were yelling back and forth. And then, he turned around towards Mr. Bunker.

Q. Was your wife challenging who this man was challenging?

A. She wanted to know his identification.

Q. Did she say in your presence, did she say anything towards the officer when he produced this document, this identification document?

She said, you are not an officer because I can't see your picture. This is fake.

Q. All right. What did you see next. You incidentally, at this point in time, are you in the vestibule or are you on the sidewalk?

A. I walked out on the sidewalk.

Q. And Mr. Bunker was standing where?

A. In the middle of sidewalk, even further towards the street.

Q. When you opened that door and turned around, was Mr. Bunker in the vestibule or on the public sidewalk?

A. On the public sidewalk.

Q. Tell me what you saw next where the two men are holding Mr. Bunker. What did you see?

My wife was standing there on this one side and I walked around to the right hand side of Mr. Bunker by the curb, by the coin meter and by the poles on the curb.

Q. Okay.

A. On the sidewalk.

Q. And tell us what you saw?

A. I stood there and these two officers were on Mr. Bunker and they had their hands on him. They were restraining him.

MS. WRONKIEWICZ: Objection to the narrative.

THE COURT: Sustained.

THE WITNESS: They were --

THE COURT: Hold on. Your lawyer will ask you a question.

THE WITNESS: All right.

BY MR. DE VLAMING:

Q. Did you see both of the officers you say still had a hold of Mr. Bunker?

A. Yes.

Q. Did you hear anything that they were saying towards Mr. Bunker from your vantage point?

A. They said, put the camera down.

MS. WRONKIEWICZ: Objection.

THE COURT: Overruled.

THE WITNESS: Stop filming.

BY MR. DE VLAMING:

Q. Put the camera down, stop filming?

A. uh-huh.

Q. Did you hear anything that Mr. Bunker said towards the officers at this time?

A. He said, why are you doing this to me? Who are you?

MS. WRONKIEWICZ: Objection.

THE COURT: Overruled.

THE WITNESS: Why are you doing this. Who are you.

BY MR. DE VLAMING:

Q. I am sorry.

A. He said, why are you doing this to me. Who are you.

Q. Did they respond to him in your presence?

A. I didn't hear that, no.

Q. Was Mr. Bunker still in possession of the camera during this struggle?

A. Yes.

Q. Did you ever see what happened with the camera?

A. The one officer, the shorter officer, forced him to put the camera down on the ground.

Q. How did he do that?

A. He grabbed his hand.

Q. For the record, you seem to be holding your thumb or the area of the hand?

A.Yes. He grabbed his hand. Mr. Bunker had his right hand on the camera and he grabbed the hand, Mr. Bunker's hand.

Q. Okay.

A. And forced him to put the camera On the ground.

Q. Did Mr. Bunker put the camera on the ground?

A. Yes, he did.

Q. Did he ever drop it to the ground?

A. No, he did not.

Q. Did you see it lay where Mr. Bunker placed it?

A. It was sitting right where he placed it, yes.

Q. Did you do anything in relationship to the camera?

A. Yes. I picked the camera up then.

Q. It was in your possession?

A. Yes. The red light was still on.

MS. WRONKIEWICZ: Objection.

THE COURT: Sustained. Ask another question.

MR. DE VLAMING: All right.

BY MR. DE VLAMING:

Q. When you picked the camera up, was the red light on or off on the camera?

A. The red light was on.

Q. What did you do with the camera at that point in time?

A. I had camera and I was trying to film this officer who was holding Mr. Bunker and he let Mr. Bunker go and he came to me for the camera. He
said, give me the camera.

Q. Let me stop you. You seem to be holding your hand. Did you have the camera up on your shoulder?

A. No. I was holding it down at my knees trying to angle up.

Q. You said angle up?

A. Angle up.

Q. And the officer came over to you at that point?

A. Yes, he did.

Q. At some point. And what did he say to you?

A. He put it --

Q. If you don't know names, you can state the larger of the two officers or the smaller of the two officers?

The smaller of the two officers, he put his hand on the camera and he told me to let go of the camera. And I said, what are you going to do with the camera. He said, we are going to take it to the station and I let the camera go and he took the camera.

Q. Was the red light on when he took possession?

A. The red light was still on.

Q. You are sure of that?

A. Yes. Because I didn't how to turn it off.

Q. Say that again?

A. I did not know how to turn it off.

Q. Okay. Did you know, to this day, do you know how to take the cassette out of this camera?

A. No, I don't.

Q. Did you ever remove a cassette from that camera?

A. No, I did not.

Q. So he takes the camera from you. What is Mr. Bunker doing with either of two officers at this point?

A. He is being handcuffed by the other officer.

Q. By the larger?

A. The larger of two officers.

MS. WRONKIEWICZ: Objection to the leading, Judge.

THE COURT: Overruled.

BY MR. DE VLAMING:

Q. When the smaller of the two officers took the video camera from you, did you see where he took it?

A.He took the camera and he was turning it over and the red light was on and he walked over to a lady officer who walked up, a Schloss, I think, her name was.

Q. Okay. Did he do anything with the camera in relation to that officer?

A. I didn't see. They walked away together.

Q. And that's the last you saw of the camera?

A. No.

Q. Okay.

A. I saw the camera. I walked around the car back out to the street and I turned around to look and I could see that the light was off on the camera when they were taking the camera to the squad car.

Q. YOU noticed that?

A. The light was off, yes.

Q. IS that the last that you saw of it that day?

A. That's the last that I saw of the camera.

Q. Dr. Z., did you ever hear any member of the Church of Scientology tell Mr. Bunker that day that he could not come onto their property?

A. No.

Q. You know who a Mary Anne Ahmad is?

A. Yes. I have met her.

Q. Do you know her to be a member of the Church of Scientology?

A. Yes.

Q. Did you ever hear Ms. Ahmad instruct Mr. Bunker or tell him in any fashion that he could not come onto church property?

A. No.

Q. Was Mr. Bunker taken away in the squad car?

A. Yes.

Q. Was there any effort -- and you were not arrested?

A. No, I was not.

Q. Your wife was not arrested?

A. No.

Q. Was there any effort to get you to go into the Church of Scientology after he was taken away?

A. They invited us --

MS. WRONKIEWICZ: Objection.

THE COURT: Sustained.

BY MR. DE VLAMING:

Q. Dr. Z., when you turned around from the front door of that organization and you saw the two men, were they left and right of Mr. Bunker?

A. Yes. They were on either side of him, yes.

Q. Did you ever hear, at that point in time, them identifying by what authority they were holding him or telling him that he could not go inside of that building?

MS. WRONKIEWICZ: Objection to the leading.

THE COURT: Overruled.

THE WITNESS: No. I didn't hear what they said.

MR. DE VLAMING: One moment, Judge.

BY MR. DE VLAMING:

Q. Dr. Z., let me show you what's been marked as Defendant's Exhibit No. 6, which appears to be a photograph. Do you recognize that?

A. Yes.

Q. Is that the front of the Church of Scientology?

A. Yes, it is.

Q. And is this the door that you opened on that day?

A. That is correct.

Q. Did Mark Bunker ever enter inside of the building of the Church of Scientology?

A. No.

Q. Did you he ever enter even in the vestibule area marked by the tile?

A. No.

Q. He was always on the sidewalk?

A. Yes.

MR. DE VLAMING: I have no further questions.

THE COURT: You may proceed.

CROSS EXAMINATION
BY MS. WRONKIEWICZ:

Q. Mr. Z., you were previously a member of the Church of Scientology, correct?

A. Yes.

Q. That's your testimony. So is your wife, correct?

A. Yes.

Q. And you said that was in approximately '96?

A. I think so, yes.

Q. And that would have been for approximately how long were you a member?

A. Maybe a year.

Q . So it would be fair to say then in January of the year 2000, you were no longer a member of the Church of Scientology?

A. Right.

Q. And you felt that the Church of Scientology owed you some money, correct?

A. Yes.

Q. So you had arranged a meeting with the Church of Scientology at 7:30 on January 25th, correct?

A. Yes.

Q. And you had called ahead to make arrangements for you and your wife to be at that meeting, correct?

A. We had the meeting set up the week before.

Q. So you called. Is that a yes or a no. You called ahead to make arrangements for your wife and you to be at a meeting, correct?

A. The week before we made the arrangements, yes.

Q. So you arranged a meeting for 7:3O on January 25th, correct?

A. Right.

Q. All right. You did not ask for permission for Mark Bunker to come with you, correct?

A. Right.

Q. It's your testimony that you invited Mark Bunker to go with you to help you get your money back, correct?

A. Right.

Q. But you didn't call Russ Ewing to go with you on that date, correct?

MS. WRONKIEWICZ: Objection.

THE COURT: Sustained.

BY MS. WRONKIEWICZ:

Q. So you flew Mark Bunker in from Florida to come with you to get your money back, is that correct?

MS. AIMEN: Objection. No facts in evidence.

THE COURT: Overruled. He can answer.

THE WITNESS: No.

BY MS. WRONKIEWICZ:

Q. Well, Mark Bunker flew in from Florida, correct?

MS. AIMEN: Objection. Beyond the scope of the personal knowledge.

THE COURT: Overruled. If he knows.

THE WITNESS: He was in Chicago. I assume that he came from Florida.

BY MR. WRONKIEWICZ:

Q. Okay. Well, you brought the video camera. Let me rephrase that. When you went to this meeting on January 25th, Mark Bunker had a camera with him, correct?

A. Yes.

Q. And the purpose of bringing that video camera was to be interviewed outside of the Church of Scientology, correct?

A. We were going to be -- we asked -- we were going to ask permission for him to come in and interview and film the interview that we were going to have with the Church of Scientology.

Q. But you previously testified in this matter, correct?

A. Yes.

Q. And that was actually on November 17th of this year, correct?

A. Last year.

Q. November 17th of the year 2000, correct?

A. Uh-huh.

Q. And that was in front of this same courtroom, correct?

A. Yes.

Q. And there was a court reporter on that date taking down your testimony, correct?

A. Uh-huh.

Q. Page 18.

THE COURT: You have to answer yes or no.

THE WITNESS: Yes.

BY MS. WRONKIEWICZ:

Q. And you were asked a series of questions by an attorney on that date, correct?

A. Yes.

Q. Sir, were you asked this question and did you give this answer.

Q. The purpose of bringing the tape to the Church of Scientology was what?

To interview us outside on the church on the front sidewalk.

Sir, were you asked that question and did you give that answer?

A. Yes.

Q. Now, Mr. Bunker did not carry with him a tripod on January 25th, correct?

A. Right, yes.

Q. And he did not have with him or you didn't have with you a hand-held microphone, correct?

A. Correct.

Q. And you didn't set up any like free standing lights for this interview, correct?

A. That's correct.

Q. And the front of that camera does not have like a big bright spotlight on it, correct?

A. That's right.

Q. And you didn't have a cordless microphone with you, correct?

A. That's right.

Q. And, sir, isn't it true that you called the police before you arrived at the Church of Scientology on January 25th?

A.That was our arrangement with the police the previous week. We were to call them ten minutes before our point of time.

Q. So, sir, did you call the police before you arrived on January 25th?

A. Yes.

Q. And you are saying that the police told you to call them before you went?

A. Yes.

Q. So you walked up to the church entrance and you opened the door, correct?

A. Yes.

Q. You didn't have to walk around two officers to get to that door, correct?

A. That's right. There was no one in the vestibule.

Q. And your wife was also with you, correct?

A. She was behind me, yes.

Q. And Mr. Bunker, according to you, Mr. Bunker was behind her, correct?

A. That's correct.

Q. So you have no idea what Mr. Bunker was doing behind you as approached the church, correct?

A. He was filming. I assume that he was filming.

Q. But you are assuming that, correct?

A. Uh-huh.

Q. Now, the two individuals who arrived on the scene, they were two males, correct?

A. Yes.

Q. And there was a taller one and a shorter one, correct?

A. That's right.

Q. And these two individuals told Mr. Bunker that he had to leave, correct?

A. I didn't hear that.

Q. You didn't hear that. Well, sir, isn't it true that they could have told him
that he had to leave and you wouldn't have heard it?

A. Yes.

Q. And, sir, isn't it true that these two individuals identified themselves as police officers?

A. After awhile, yes.

Q. And when these individuals identified themselves as police officers, Mr. Bunker did not leave, correct?

A. He was being restrained. He couldn't leave.

Q. He couldn't leave, that's your testimony. Now, your wife was standing next to Mr. Bunker, correct?

She was standing -- Mr. Bunker was being confronted between - he was behind the police officer, a big police officer was standing there and my wife was standing facing him.

Q. Your wife was facing the big police officer, is that what you are saying?

A. Uh-huh.

Q. And your wife was questioning the police officer's identification, correct?

A. That's right.

Q. And she was saying -- her voice was raised, correct?

A. She was upset, yes.

Q. When you say she was upset, was she yelling?

A. Her voice was raised.

Q. And as she was yelling, was she flailing her arms in the air?

A. No. She was saying, who are you, who are you.

Q. And you saw your wife was handed an identification, correct?

A. I saw him hold up a piece of paper. It looked like a paper card or drivers license.

Q. And that card or drivers license was actually in a black wallet, correct?

A. I didn't see that.

Q. Your wife -- you heard your wife say that's not a real badge, correct?

A. Right.

Q. At that time, you didn't see Mr. Bunker leave, correct?

A. The other police officer was standing holding Mr. Bunker.

Q. Is that a yes or no, did you see Mr. Bunker leave?

A. No.

Q. Now, at some point, you heard the police tell Mr. Bunker that's it. You are under arrest, correct?

A. Yes.

Q. And Mr. Bunker -- Mr. Bunker started backing up, correct?

A. I think, he was in the middle of the sidewalk and he had been pushed off but he didn't step off the curb.

Q. When the police said, that's it, you are under arrest, he was backing away from the police officer, correct?

A.I don't think he was backing away from the police officer. He was setting down his camera.

Q. Now, in addition to having his camera, he also had his cell phone on that date, correct?

A. Yes.

Q. And when Mr. Bunker was being placed under arrest, you saw him with this cell phone in his hand, correct?

A.I don't remember too much about the cell phone but I know he had one, yes.

Q. Well, you know that he had a cell phone and you saw the defendant drop his cell phone and your wife picked it up, correct?

A. Yes. I know he dropped a cell phone, yes.

Q. And you also know that your wife picked it up, correct?

A. Yes.

Q. Now, at some point, you admit that the defendant's video camera is on the ground, correct?

A. Yes.

Q. And at that point, the defendant signaled to YOU to pick up the camera, correct?

A. No, he didn't. I just did it on my own.

Q. You did not see the defendant look at you and signal to you to pick up that camera?

A. No.

Q. When you had that camera in your hand, it was down at your side, correct?

A. That's right.

Q. And when you had that camera in your hand, you were not standing in the original entrance that you had walked into, correct?

A. That's right.

Q. You were actually in the second entrance over, correct?

A. No. That's not correct. I had walked --

Q. Sir, there is no question.

A. Okay.

Q. Now, you just testified that earlier in the day, the defendant came over to your house for some type of interview, correct?

A. Yes.

Q. On that date, YOU watched the defendant load the video camera, that's your testimony?

A. Yes.

Q. Now, you had talked to the defendant about your testimony today here in court, correct?

A. I mentioned it to him.

Q. And you talked to his attorneys about your testimony here?

A. We discussed it.

Q. And have you talked to your wife about your testimony here today in court?

A. We have talked about it.

Q. Now, you earlier testified that the officer, the shorter officer, came and
took that video camera from you, correct?

A. That's right.

Q. That shorter police officer then gave it to a female officer, Sergeant Schloss, I believe you testified her name was, correct?

A. Right. She was in front of me. He was in front of me. That's what I recall.

Q. And then, that sergeant actually took that video camera and put it into the police vehicle that the defendant was in, correct?

A.They walked away out of my sight and then walked to the Street and behind me.

Q. But you did see them put that video in the trunk of the car, correct?

A. Yes.

Q. You saw the female officer put that in the trunk of the car, correct?

A. Yes.

Q. And the shorter officer wasn't with her?

A. That's right.

Q. Now, the shorter officer, you never saw him remove anything from the camera, correct?

A. No.

Q. And you saw that lady officer just -- actually, Judge, I will withdraw that question.

MS. WRONKIEWICZ: May I am a moment?

THE COURT: Sure.

MS. WRONKIEWICZ: Judge, I would tender the witness.

MR. DE VLAMING: A few more questions, Judge.

REDIRECT EXAMINATION
BY MR. DE VLAMING:

Q. Dr. Z., the prosecutor had brought up a prior meeting with the police. They were called for the following week?

A. uh-huh.

MS. WRONKIEWICZ: Objection. I didn't bring that up.

MR. DE VLAMING: Sure, she did.

THE COURT: She didn't say anything about a meeting. There was a conversation with the police so ask the question.

MR. DE VLAMING: All right.

BY MR. DE VLAMING:

Q. Was there a prior attempt to get the money the week before?

A. Yes, there was.

Q. And was it successful or unsuccessful?

A. It was unsuccessful.

Q. Why?

A. We were banned from entering.

MS. WRONKIEWICZ: Judge, I am going to object.

MR. DE VLAMING: Judge, I think it goes to why the phone call was made.

THE COURT: Overruled.

BY MR. DE VLAMING:

Q. Go ahead.

A. There was a bouncer or sergeant of arms at the door who said that we could not enter.

Q. And from there, was arrangements then made for the week after for the 25th of January?

We had called the police there on the street and the police came and we asked the police to help us make this appointment and they did. They said that, you know, that they would.

Q. And was it then arranged that you would come the next week?

A. That's right.

Q. And that's why Mr. Bunker was called to ease this ability to get your money back?

A. Right.

MS. WRONKIEWICZ: Objection.

THE COURT: Sustained as to that.

BY MR. DE VLAMING:

Q. The prosecutor asked you if felt that the church owed you some money. Tell us why?

A. There was money that we gave for courses that we hadn't received. We wanted our money back. It was free payment. It was, you know, payment for courses and we never received, the courses.

Q. And they refused and barred you?

A. Right.

MS. WRONKIEWICZ: Objection.

THE COURT: Sustained.

MR. DE VLAMING: That's all.

THE COURT: Anything else?

RECROSS EXAMINATION
BY MS. WRONKIEWICZ:

Q. All right. Sir, you just testified that YOU went to the Church of Scientology the week before, correct?

A. Yes.

Q. And it's your testimony that there was some bouncer at the door the week before, correct?

A. Yes.

Q. So you knew that you couldn't go to the Church of Scientology without making an appointment, correct?

A. Right.

Q. And it's your testimony that there were police officers there on that date, correct?

A. We called the police. That's right.

Q. And the police officer arrived, her name was Officer Cuddy, correct?

A. Yes.

Q. It's your testimony that the officer made an appointment with the Church of Scientology for you?

A.They said that they would help us make the appointment so we could come by safe conditions.

Q. What do you mean by -- but the officer did not make that appointment for you. That's not what are you saying?

A. No. We made the appointment, the 7:30 the following week.

Q. You called to make the appointment?

A. We made it right then and there in person.

Q. But the officer did not make the appointment for you?

A. No.

Q. And the officer never told you to call the police when you went there the next week, correct?

A.They said to call ten minutes ahead of time before we had our appointment.

Q. The officer told you to call the police department before you went to your meeting?

A. Uh-huh.

Q. That's your testimony?

A. Yes.

MS. WRONKIEWICZ: Nothing further.

MR. DE VLAMING: Two questions, Your Honor.

THE COURT: Okay.

REDIRECT EXAMINATION
BY MR. DE VLAMING:

Q. Before you made the request for the money, could you in the past, could you walk right into the Church of Scientology?

MS. WRONKIEWICZ: Objection. Beyond the scope.

THE COURT: Overruled.

THE WITNESS: Yes.

BY MR. DE VLAMING:

Q. And this sergeant of arms that you described, was that a police officer sergeant in arms or somebody that's a Scientology?

A. Scientology.

MR. DE VLAMING: That's the only questions I have.

THE COURT: Anything else?

MS. WRONKIEWICZ: No, Judge.

---

Barbara Z. Trial Testimony

BARBARA R. Z.
called as a witness herein, was examined and testified as follows:

DIRECT EXAMINATION
BY MR. de VLAMING

Q. Please tell us your name.

A. Dr. Barbara R. Z..

Q. What city do you reside in?

A. Chicago.

Q. Are you employed?

A. Yes, I am.

Q. What do you do for a living?

A. I am a dentist.

Q. Is William Z. your husband?

A. Yes, he is.

Q. And do you practice dentistry together?

A. Yes, we do.

Q. How long have you been a dentist?

A. A dentist, since 1980.

Q. Was there a time, Dr. Z., when you were a member of the Church of Scientology?

A. Yes, there was.

Q. Approximately what time period was that?

A. 1994 or '96. I don't remember. In the early '90's 'til 1997. So 1994 'til 1997.

Q. And was there a time when you were trying to get out of the Church of Scientology?

A. Oh, yes, there was.

Q. And in that effort to get out, was there a request for a refund of a substantial sum of money you had given the Church?

A. Oh, yes, there was.

Q. What was the purpose of the money given?

A. It was to buy courses.

Q. All right. Had some not been taken and so you had requested money back?

A. Oh, definitely. A lot.

Q. And in your -- well, first of all, was it returned to you immediately?

A. No.

Q. About how long a time did you make that effort?

A. Couple years, a year. Over a year, well over a year.

Q. And was there at least on one occasion that you placed that request in writing?

A. Yes, there was.

Q. And do you know a Mary Anne Ahmad?

A. Yes, I do.

MR. de VLAMING: May I approach the witness, your Honor?

THE COURT: You may.

MS. KING: We object to the point showing a letter.

THE COURT: Well, he can show it to her.

BY MR. de VLAMING:

Q. Dr. Z., do you recognize what's been marked Defendant's Exhibit No. 2?

A. Yes.

Q. Are you the author of that letter?

A. Yes, I am.

MS. KING: Your Honor, I want to know is he doing this to refresh her recollection?

THE COURT: Let's see if he asks another question. Then you may make an objection.

BY MR. de VLAMING:

Q. And did you send this letter to Miss Ahmad?

A. Yes, I did.

Q. Was there a time, Dr. Z., where you had gone to the Church of Scientology, let's say approximately a week before January 25 of the year 2000, with your husband in order to obtain monies back?

MS. KING: Objection, your Honor.

THE WITNESS: Yes.

THE COURT: Overruled.

THE WITNESS: Yes.

BY MR. de VLAMING:

Q. Were you successful?

A. No.

Q. Why not?

A. We weren't allowed --

MS. KING: Objection, your Honor.

THE COURT: Overruled. She can answer.

THE WITNESS: We weren't allowed to -- we had a scheduled appointment and we weren't allowed to go in and have that appointment.

BY MR. de VLAMING:

Q. On the basis of that, was there arrangements made with any agency to come back the week later?

We had the Chicago police, the squad car that came, that we called over to go inside and make the appointment for the following week at the Church of Scientology.

Q. So you discussed with the police that you would come back the following week on the 25th?

A. Yes.

Q. And that was also scheduled with the organization itself as well?

A. Oh, yes. That was the time that they said we should come.

Q. Now did you make any efforts to contact anyone during that week's period of time to bring them with you on January 25?

A. Yes, we did.

Q. What did you do?

A. We contacted Mark Bunker.

Q. Okay. How did you reach Mr. Bunker?

A. We were given the name of Mark Bunker through Patty Sullivan who --

Q. Who is Patty Sullivan?

A. She is the wife of a dentist that sold his practice and gave all his money to the Church of Scientology.

MS. KING: Objection, your Honor.

THE COURT: Sustained. Stricken.

BY MR. de VLAMING:

Q. So you reached Mr. Bunker's name through a third party and contacted Mr. Bunker, what, to come with you?

We wanted the whole event documented. We were afraid to go in by ourselves.

MS. KING: Objection, your Honor. It's non-responsive.

THE COURT: Overruled.

BY MR. de VLAMING:

Q. Why were you afraid to go in?

A. Because we know -- I had another friend tell me that they will keep you down in the basement --

MS. KING: Objection, your Honor.

THE COURT: Sustained. Sustained.

BY MR. de VLAMING:

Q. So Mr. Bunker agreed to come in and document the discussions you would have with the Church about the return of your money?

A. Right. We wanted witnesses and documentation.

Q. And did you know Mr. Bunker to be a man capable of video taping? Was he a videographer?

Yes, yes, he is a video -- he has a Zenu TV and he is a video reporter. (phonetic)

Q. And when he arrived in town on or about the 25th, were there any interviews done of you and your husband by Dr. -- excuse me, by Mr. Bunker that day?

A.Yes, he interviewed my husband and he interviewed me, yes, and he interviewed us together.

Q. And did you have a microphone or wireless mike placed upon you for that purpose?

A. At my house at the interview.

Q. Okay.

A. Yes.

Q. Approximately how long did that interview last?

A. I don't remember exactly because it could have been a long time, like an hour, half-hour to an hour because I started telling my whole tale and I got talking and I don't remember exactly.

Q. Okay.

A. But it was long.

Q. So he documented your -- what was bringing up to the time that you were going to go to the Church to discuss the matter?

A. Yes.

Q. Could you tell me when -- well, strike that. Was there a particular time that you had agreed to go to the Church of Scientology on the 25th of January?

A. I think 7:30.

Q. In the evening?

A. Yes.

Q. Go ahead and tell us, when you arrived, tell us what you did and how you arrived at the Church door?

A. We parked on the street parallel to the Catholic church there. I don't know the name of the street. And then there is a little diner called S and W on the corner. So first we drove by and there were people standing all over the street on both sides. The street itself that the Church of Scientology is on comes to a diagonal and there is a restaurant here and then the Church is inner from that from that first restaurant. So we parked. We drove by first and everyone was outside.

MS. KING: Objection to the narrative at this time.

THE COURT: Sustained.

BY MR. de VLAMING:

Q. What do you mean everybody was outside?

A. Well, Church members that I recognized were posted outside every maybe six feet.

MS. KING: Objection to the term posted.

THE COURT: Sustained.

BY MR. de VLAMING:

Q. Did you recognize these individuals as being members of the Church of Scientology?

A. Some of them, yes.

Q. Now at some point in time you got out of your vehicle. Was it you, your husband and Mr. Bunker?

A. Yes, we did.

Q. Did you walk towards the Church of Scientology in the street or sidewalk or what?

MS. KING: Object.

THE WITNESS: We walked on sidewalk and then we had to cross the street and then we were walking up the sidewalk.

BY MR. de VLAMING:

Q. Who, if you could tell us, as you walked up the sidewalk, who was first? How did you do that? In what order were you?

A. Bill is in front of me. I was behind Bill. Mark was behind me. I think it was filming us. I don't remember exactly, but I think he was filming us while we were walking up.

Q. Okay. Did Bill get to the front door?

A. Well, he was filming us when we were at the front door. Bill put his hand on the door. I was behind Bill. Mark was behind me and he said, before you go in, I want to talk to you --

MS. KING: Objection, hearsay, your Honor.

THE COURT: Sustained.

BY MR. de VLAMING:

Q. Okay. When your husband got to the front door, did Mr. Bunker get your attention by saying anything to you?

A. Yes.

Q. And did you then turn around?

A. Yes, I turned around.

Q. Based upon his voice?

A. Yes.

Q. How was he holding the camera at that point?

A. He was filming me so he was holding it up.

Q. Did you see anything on the camera that lead you to believe that he was filming?

A. It's got -- it's got a red light. I don't know where, but it had a red light on. So then you know the camera is on.

Q. Okay. When he said something to you and you turned around, what did you see next?

A. I saw two men rush from an acute angle. Like if I am standing here and Mark is here, they came from an acute angle and just ran and just jumped him like that. They just ran and jumped him.

Q. When you say jumped him, describe that. What do you mean by that?

A. They ran and grabbed him.

Q. Okay. They didn't take him to the ground?

A. No, no. He was standing with the camera trying to hold on to it.

Q. Okay. And let me show you what's been marked as Defendant's Exhibit No. 7.

A. Okay.

Q. Do you recognize this photograph?

A. Yes, I do.

Q. What does it show?

A. It shows the north door. There is two entrances. It shows the north entry way to the Church of Scientology on Lincoln.

Q. Could you use this photograph and showing to the jury where your husband was, where you were and where Mr. Bunker was at the time that those two men came up to him?

A. I could, but, you know, I need -- if could if I had to, yeah.

Q. Well, let me ask you this. Let's do this. Showing you what's been marked Defendant's Exhibit 5 for identification. Would that help even more?

A. Yeah.

MR. de VLAMING: Judge, may the witness step down?

THE COURT: Sure. You may step down.

BY MR. de VLAMING:

Q. All right, if you could, the lower of the two which is Defendant's Exhibit 7 shows the actual entry way. This shows the sidewalk on No. 6. Is that correct?

A. Hm-hmm.

Q. I want you to stand so that you are not blocking the view here. Could you show us where your husband was, where you were and where Mr. Bunker was at the time the two men came out and from what area you saw the men come to?

A. I just want to make sure, this is the north door. This is the south door. My husband had his hand on the door. I am behind my husband about here in the vestibule because he is going to open the door.

I am here, kind of like right here and then Mark is right here, back here, filming. And I turned around. The two men ran. It seemed like somewhere in here. They ran out and they had black jackets.

Q. They had black jackets on. Is this the area where they originally met Mr. Bunker?

A. Oh, yeah, uh-huh.

Q. Okay, you can have a seat. Did either of the two men identify themselves?

A. No.

Q. What did you do when you saw Mr. Bunker with the camera on his shoulder being approached by those two men very quickly?

A. I was upset. I was frightened. I didn't know who they were and he came to document this meeting and I was afraid. I mean, I was shocked. They just --

Q. What did --

A. I yelled. I said, who are you? What are you doing here? Who are you? Why are you doing this? What's the matter?

Q. Did you know who they were or what they were at that point in time?

A. No. They just came black clothes, jumped him. I didn't know. So you can imagine, you know, how frightened you get. You don't know who that is, who they are.

Q. Did either one of the men say anything to you when you said who are you?

A. Well, I asked for identification. I said, who are you? Who are you? They said, we are police. I said, well, I need to see identification. You know, because I am used to the uniforms. We had asked the other police to meet them there, the ones with the squad cars and the uniforms and these didn't have. They said they were police. I said I need to see a badge. So one showed me a badge, but the face was scraped off.

Q. Scraped off the badge or the identification?

A. By badge, I mean the picture badge, the picture of him, his identification. So I said, no, I don't believe that you are a real police. And so the other - do you want me to say?

Q. Go ahead.

A. I asked the other one, what's your name? And he told me, Joe Blow.

Q. Let me stop you here. Can you identify them by name or by one being larger or smaller?

A. The tall policeman had the badge on his hip and he showed it to me and that's the one that had the face scratched off. So I said to the other one, I want to see a badge. He wasn't showing me a badge or an ID. I wanted to see his ID, you know, to see if he had a picture.

He said, no. And I said, what's your name? And he said, Joe Blow. So I was very frightened because what kind of a name is Joe Blow? That's not a
real name.

Q. What was happening then when you were talking to the two of them?

A. They were holding Mark trying to get his camera and holding him and telling him to turn it off. You know, you're going to be arrested. Turn it off. We are police.

Q. What happened next? What did Mark do?

A. Mark set the camera down because one pried his thumb back. So he set it down.

Q. Do you know what happened to the camera after that?

A. No.

Q. Okay.

A. I know it's -- I know that one of the two policemen had it.

MS. KING: Objection, your Honor. She already said she didn't know what happened to the camera.

THE COURT: Sustained.

BY MR. de VLAMING:

Q. After you saw it on the ground, that was in the course of events when you saw it?

A. Yes.

Q. Who had it next time you saw it?

A. The next time I saw it, it was -- I am not going to say the name he told me, but it was the short policeman that had it. That's what I remember.

Q. Okay. When you arrived on the sidewalk area, did anyone from the Church of Scientology, in your presence, tell Mark Bunker that he had to leave the premises?

A. No.

Q. Was there anything posted on the outside of the building that told -- instructed Mark Bunker that he was not welcome there?

A. Nothing. Can I say something?

THE COURT: Ma'am, wait for your lawyer to ask a question.

BY MR. de VLAMING:

Q. Did you see Mr. Bunker being handcuffed?

A. Yes, I did.

Q. Tell us what happened in that regard.

A. Well, the policeman took out his handcuffs and Mark put out his hands and he handcuffed him.

Q. And did you hear Mr. Bunker say anything in relation to his camera?

By then the other squad car came up and I was telling those policemen my story. So I don't remember.

Q. Up until the time that Mr. Bunker was handcuffed, did you know those two men to be law enforcement officers?

A. No.

MR. de VLAMING: One moment, Judge.

Q. Dr. Z., when your husband was at the front door opening it or attempting to open it, were you behind him and you said Mr. Bunker was behind you?

A. Hm-hmm.

Q. Did you ever see Mr. Bunker get to the area of the vestibule and step on even the tiling?

A. No. I was on it.

Q. Did he ever enter Church property inside the building?

A. No.

MR. de VLAMING: That's all.

CROSS EXAMINATION
BY MS. KING

Q. Good afternoon, Dr. Z.. You testified you were formerly a member of the Church of Scientology?

A. Hm-hmm.

Q. Both you and your husband didn't want to be members of the Church any more?

A. Right.

Q. And you had given them some money and wanted a refund?

A. Right.

Q. You were having some problems receiving that refund?

A. Yes.

Q. And it took you a while to get the refund?

A. Yes.

Q. It's fair to say you weren't happy with the Church at that time?

A. Right.

Q. Okay. And you had been there previously about a week before. Correct?

A. Hm-hmm.

Q. And you were told you had to make an appointment?

A. I had an appointment for that evening.

Q. You were told you had to make another appointment and you made an appointment for January 25?

A. The police made the appointment. I didn't.

Q. The officer you talked about that night was Officer Cuddy, correct?

A. I don't remember.

Q. And that officer, it's your testimony an officer there made an appointment for you?

A. Yes.

Q. So you knew that you needed an appointment to go to the Church, right, you and your husband for the next week? You were aware of that?

A. I was aware that I had an appointment.

Q. Okay. And you were aware that the appointment was for you and Dr. Z., correct, Dr. William Z. your husband, correct? For the two of you?

A. Yes.

Q. And you were aware that it was not for Mark Bunker, correct?

A. No.

Q. In fact, you also called the police before you came that day, correct?

A. Yes, we did.

Q. So you were expecting some trouble?

A. No.

Q. Even though you had an appointment?

A. I wanted witnesses that we were there.

Q. So you called the police ten minutes before just to have witnesses that you were there?

A. The police that we talked to the week before?

Q. Uh-huh.

A. They said they would come again.

Q. Those police officers said they would come again?

A. Yes.

Q. Did they tell you to call them before coming?

A. Yes.

Q. You don't remember their names of who they were?

A. I think -- I don't. I might have it written down at home.

Q. You said that you wanted this whole event documented on what was happening, right?

A. Yes.

Q. And so you called Mr. Bunker as a videographer. Correct?

A. Hm-hmm.

Q. He is not a member of the press to your knowledge, right?

A. Right.

Q. And you didn't call an attorney to come with you, right? Just Mr. Bunker?

A. I spoke to attorneys, but I didn't have them come with me.

Q. Your testimony was that you were walking northbound, right, on Lincoln Avenue towards the Church?

A. Hm-hmm.

Q. The order went your husband, yourself and Mark Bunker. Correct?

A. My husband, me, Mark, yes.

Q. Okay. You all arrived and parked the car together. Right?

A. Hm-hmm.

THE COURT: Ma'am, you have to answer yes or no.

THE WITNESS: I'm sorry, yes.

BY MS. KING:

Q. But you walked up Lincoln Avenue in a single file line?

A. Yes.

Q. Okay. And how wide is the sidewalk at about that area?

A. I don't know.

Q. Could it be approximately 12 feet wide?

A. I don't know.

Q. As you were walking, you parked on -- did you park on Wellington? Do you recall that street?

A. It's the street that's parallel to the Catholic church.

Q. Okay.

A. If that's Wellington, I don't know.

Q. That's where you parked is that street so the three of you had to walk up to the Church. Were you talking as you walked up to the Church?

A. We were looking around.

Q. Okay. You were looking around, but you weren't talking to each other?

A. We might have been.

Q. You might have been. You weren't talking about why Mr. Bunker was going to be taping that night?

A. I don't remember.

Q. So as you are walking up and might have been talking, you are still walking in a single file line?

A. I think so.

Q. Okay. And when you got to the front of the building, you stated your husband was all the way at the door, right?

A. Hm-hmm.

Q. And you were just inside the little vestibule and Mark Bunker was behind you?

A. Hm-hmm.

THE COURT: You have to answer yes or no.

THE WITNESS: Yes, yes.

BY MS. KING:

Q. You do have to say yes or no.

A. Yes.

Q. When you were walking in a single file line, you guys are about four feet from each other as well. Your husband is at the door. You are at the entrance and Mr. Bunker is back on the sidewalk?

A. I don't know the exact measurements.

Q. But there was a distance between you as you were walking single file to the Church?

A. Yes.

Q. Suddenly -- you also testified you saw members of the Church standing around, right?

A. When we drove by before.

Q. But when you walked up?

A. No one was there.

Q. And as you were walking single file with space between you, suddenly two men came out and grabbed Mr. Bunker?

A. That's right.

Q. And you don't know which direction they were coming?

A. I know which direction.

Q. Which direction?

A. They ran out from the north at an acute angle.

Q. But you don't know what angle but they were running from the street?

A. They weren't running from the street.

Q. Down the sidewalk?

A. They ran across the sidewalk and just jumped him.

Q. Okay. And did you hear these men say anything to him? Did they ever ask him, are you Mark Bunker? They just grabbed him?

A. I don't remember them asking him that. Maybe they did. I don't remember that.

Q. Okay. But they didn't grab your husband, right?

A. He was up in the vestibule.

Q. They only grabbed Mark Bunker?

A. He was out on the sidewalk.

Q. And you wanted to see ID of these police officers, right?

A. Yes, I did.

Q. In fact, you stated you were upset and you were scared. Correct?

A. Correct.

Q. When you were asking for this identification, you were loud, correct?

A. Yes, I was.

Q. Isn't it fair to say you were giving these police officers a hard time only because you didn't know who they were?

A. I was giving the two men that rushed Mark a hard time because I didn't know who they were.

Q. These two men were handcuffing Mark, right?

A. That was after.

Q. Okay.

A. That was quite a while after.

Q. While they were handcuffing him, you were still asking questions and wanting to know what's going on, right?

A. I wouldn't say that.

Q. What were you doing then?

A. Well, how long are you saying the handcuffing took place?

Q. I am asking you while they were handcuffing him, what were you doing?

A. Watching.

Q. Just watching him handcuff him. You weren't saying anything?

A. I don't remember.

Q. Okay. They never asked you to leave the premises, correct?

A. Correct.

Q. They never said a word to you. They never arrested you, right?

A. Right.

Q. They never said a word to your husband either, right?

A. Well, they threatened to arrest me. Yes, they did.

Q. Oh, they threatened to arrest you?

A. Hm-hmm.

MS. AIMEN: Objection, Judge, to repeating narrative.

THE COURT: Overruled.

BY MS. KING:

Q. Your testimony is also when these men came out of nowhere and jumped on Mark Bunker he just put his hands out and let them handcuff him. Is that your testimony?

A. No.

Q. Wasn't that your testimony on direct when asked that Mark just let him put his hands out and let them handcuff?

A. You said more than that. It's the prior statement I said no to.

Q. My statement was it's your testimony that these men came out of nowhere. That's your testimony, right?

A. Hm-hmm.

Q. And then they jumped him. You didn't know what was going on?

A. Right.

Q. And at one point Mark just put his hands out and let them arrest him?

A. After he saw the handcuffs.

Q. Okay. After he saw the handcuffs. At this time had you seen any ID?

A. No.

Q. So men that haven't shown him ID just took out handcuffs and Mark put his hands out and let them arrest him?

A. He said they had handcuffs so they were police.

Q. So he knew they were police because they had handcuffs?

A. Hm-hmm.

THE COURT: Ma'am, you have to answer yes or no.

THE WITNESS: Yes.

BY MS. KING:

Q. Okay. Okay. And you saw that Mr. Bunker had a video camera with him that night. Is that right? That was the whole purpose of him coming there?

A. Correct.

Q. Did you see what happened to the video tape when they were placing these handcuffs on Mr. Bunker?

A. No.

Q. Okay. And you -- do you know -- you did testify that you saw the video tape in the shorter officer's hands, right?

MR. de VLAMING: I am going to object.

THE WITNESS: I don't remember.

THE COURT: Sustained. Are you talking about video tape or video camera?

MS. KING: I apologize.

Q. You said you saw the video camera in the shorter officer's hands?

A. I don't remember which one. It was one of them, but I don't remember which one.

Q. Did you see it in a police officer's hands?

A. Yes.

Q. You don't know how that camera got in his hands?

A. No.

Q. Did you see your husband with the video camera?

A. Hm-hm. I was --

Q. When you saw the video camera in the police officer's hands, did you see the police officer remove anything from that camera?

A. No.

MS. KING: Nothing further, your Honor.

THE COURT: Anything else?

MR. de VLAMING: Couple questions.

REDIRECT EXAMINATION
BY MR. de VLAMING

Q. Prosecutor asked you or she said to you they never asked you to leave the premises. Do you recall her question when she said they never asked you to leave the premises?

A. Right.

Q. After Mark was taken away, were you asked to come into the Church of Scientology then?

A. Yes, I was.

MS. WRONKIEWICZ: Objection.

BY MR. de VLAMING:

Q. Would you go?

THE COURT: Overruled.

THE WITNESS: No. I wouldn't go because I was afraid. If I go down there, who is going to know?

BY MR. de VLAMING:

Q. You also indicated on cross examination that the reason you called the police the week before --

A. Hm-hmm.

Q. -- you said to the prosecutor, I wanted witnesses that you were there. What do you mean witnesses that you were there?

A. I wanted -- I wanted to do things in a lawful way so I could have the police there to witness whatever might go on. The fact if I decided to go down into the Church, I wanted a witness that I went in and a witness that we came out. That's what I wanted.

Q. In point of time, when did the police, the squad car police, when did they get there? What was going on when the squad car police, uniformed police, came up?

MS. KING: I am objecting to beyond the scope of cross at this time.

THE COURT: Sustained.

BY MR. de VLAMING:

Q. Last question, Dr. Z.. When you were watching the activity between the two men with Mr. Bunker, was Mr. Bunker ever given the opportunity to walk away?

A. No.

Q. Why?

A. They were holding him. They were holding

on to him.

Q. So if he even wanted to walk away, he couldn't?

A. No, he couldn't walk away.

MR. de VLAMING: Thank you. That's all.

THE COURT: Anything else?

MS. KING: I have nothing based on that, your Honor.

THE COURT: Thank you. You may step down.

---