1. My name is Stacy Brooks. I have personal knowledge of the matters set forth in this declaration, and could testify competently to them if called upon to do so.

2. In the days leading up to his scheduled deposition in the case of Scientology vs. Liebreich, Robert Minton informed me of his intention to attend his deposition in Florida on August 3, 2001.

3. On Mr. Minton's behalf, I made airline reservations for him to travel to Florida on August 2, 2001, leaving New England at approximately 2:00 p.m. Over the course of the events of the afternoon and evening of August 2, 2001 described below, I revised those reservations to provide departure times at approximately 6:00 p.m. and 9:30 p.m. Shortly before Mr. Minton and his therapist informed me of their decision, I had determined the availability of a flight leaving New England at approximately 6:00 a.m. on August 3, 2001.

4. On August 2, 2001, I was contacted by Mr. Minton and informed that he had seen on the internet the posting attached to his Response as Exhibit 3. Mr. Minton was seriously upset by the invasion of his and his children's privacy by Scientology or its agent and by the obviously illegal means used by Scientology to obtain such private information.

5. Soon after I had that discussion with Mr. Minton, he learned that the neighborhood where his minor daughters live had been papered by Scientology with fliers as shown in Exhibit 4 to Mr. Minton's response. This information caused Mr. Minton to become further upset as he felt that the posting of his and his children's personal information, some of which was inaccurate, on the internet and the distributing of fliers in his children's neighborhood in which he and their mother were accused of criminal actions were deliberate assaults on his privacy and on the privacy of his children.

6. I spoke to Mr. Minton several times over the course of the evening of August 2, 2001. From these conversations it was clear to me that he was extremely upset and that he felt his privacy and the privacy of his children had been profoundly and criminally violated by Scientology agents.

7. I encouraged Mr. Minton to travel to Florida for his deposition. It was my opinion that the harassment by Scientology agents had been specifically timed to interfere with the next day's deposition and I told him so. At first he decided that he would attend the deposition, despite the harassment. I was also aware that Mr. Minton had been in communication with a therapist during the afternoon and evening. During the evening of August 2, I spoke to the therapist myself.

8. In conversation, the therapist confirmed my own assessment of Mr. Minton's state of mind and stated in the strongest terms that he should not travel to Florida for deposition on August 3, for the reason that the stress and distress of such activity would further exacerbate his condition, because Mr. Minton had been attacked at such a fundamental level, with Scientology assaulting the privacy and sanctity of his own health care and attacking his family, especially his minor children. I knew from my conversation with Mr. Minton that he felt strongly that Scientology's actions should be the subject of an Order to Show Cause for a contempt citation under the Permanent Injunction issued by a Pinellas County Circuit Court Judge with effect from August 1, 2001, and it was my understanding that the therapist felt that Mr. Minton should be assured of some protection from further harassment in the deposition before he should attend.

9. Finally, at about midnight on the night of August 2, 2001, Mr. Minton advised me that, based on the recommendation of his therapist, he was not willing to travel to Florida for deposition on August 3, 2001, but would appear at a later time, when he could be confident that he was no longer subject to an immediate assault on himself and his family.

10. In the days following the foregoing events, I repeatedly contacted the therapist, asking that the therapist testify by affidavit, deposition, or in person concerning Mr. Minton's state of mind on August 2 and the therapist's recommendations concerning the deposition. It became clear to me that the therapist was well aware of the vicious attacks Scientology has mounted on the mental health profession generally, and the horrifying assaults launched on anyone, regardless of profession, who actually opposes Scientology. The therapist was unwilling to take the risks involved in being publicly named as a mental health professional assisting an opponent of Scientology. The therapist would not cooperate in any way with Mr. Minton's request to come forward to confirm the events of the night of August 2.

Under penalties of perjury, I declare that I have read the foregoing declaration and that the facts stated in it are true.

________________________________
STACY BROOKS

Date: August 22, 2001

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