Lisa McPherson Files - Sworn Statement of Jeanne Decuypere

Lisa's Chiropractor

From the Clearwater Police Department files on the investigation into Lisa McPherson's death:

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             IN THE CIRCUIT COURT FOR PINELLAS COUNTY, FLORIDA




             IN RE:
                   INVESTIGATION                     ORIGINAL



             STATEMENT OF:  JEANNE DECUYPERE, D.C.

             DATE:          September 30, 1997
             TIME:          Began:    9:15 a.m.
                            Ended:   10:45 a.m.

             PLACE:         Criminal Justice Center
                            Office of the State Attorney
                            Room 1000
                            Clearwater, Florida

             REPORTED  BY:  Ruth M. Martin, CSR, CP, RMR
                            Registered Merit Reporter
                            Notary Public
                            State of Florida at Large






                             KANABAY COURT REPORTERS
                    TAMPA AIRPORT MARRIOTT - (813) 224-9500
                   ST. PETERSBURG/CLEARwATER - (813) 821-3320

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      1    APPEARANCES:
      2             MARK McGARRY, ESQUIRE
                    Office of the State Attorney
      3             Criminal Justice Complex, Room 1000
                    Clearwater, Florida 33760
      4                   Attorney for State of Florida

      5              ROCHELLE A. REBACK, ESQUIRE
                     405 West Azeele Street
      6              Tampa, Florida 33606
                          Attorney for the Witness
      7
           ALSO PRESENT:
      8
                    LEE STROPE, Special Agent
      9                  Florida Department of Law Enforcement

     10             WAYNE C. ANDREWS, Detective Sergeant
                    City of Clearwater Police Department
     11

     12

     13

     14

     15

     16
     17                              INDEX
                                                              PAGE
     18    EXAMINATION
     19          BY MR. McGARRY                                  3
                 BY DETECTIVE SERGEANT ANDREWS                  52
     20          BY SPECIAL AGENT STROPE                        67
                 BY MR. McGARRY                                 75
     21

     22
           CERTIFICATE OF OATH                                  78
     23

     24

     25



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      1                      The deponent herein,
      2                          JEANNE DECUIPERE; D.C.,
      3           being first duly sworn to tell the truth, the
      4           whole truth, and nothing but the truth, was
      5           examined and testified as follows:
      6                            EXAMINATION
      7    BY MR. McGARRY:
      8          Q.   State your name, please, for the record.
      9          A.   Dr. Jeanne Decuypere.
     10                     MR. McGARRY: Before we begin, is there
     11          anything you'd like to place on the record before we
     12          start the statement?
     13                     MS. REBACK: I'm present, I'm her attorney,
     14          Rochelle Reback.
     15                     MR. McGARRY: She's here pursuant to a
     16          subpoena?
     17                     MS. REBACK: Correct.
     18                     MR. McGARRY: Has been afforded all the
     19          protections by that subpoena, right?
     20                     MS. REBACK: That's correct.
     21    BY MR. McGARRY:
     22          Q.   I'd like to get some background, if I could.
     23               First, my name is Mark McGarry. I'm a prosecutor.
     24    I'm investigating the circumstances surrounding the death of
     25    Lisa Mcpherson. You've met everybody else in the room.

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      1               I'm going to be asking you some questions
      2    involving those circumstances. Your name has come up as
      3    being at least peripherally involved during that time
      4    period. I think you showed up at the hospital,
      5    Morton Plant. So I just wanted to get that information from
      6    you.
      7               We can start out by asking your birth date, not
      8    meaning to pry.
      9          A.   X49.
     10          Q.   Okay. And your residence is located where?
     11          A.   In Clearwater.
     12          Q.   Clearwater?
     13          A.   Uh-huh.
     14          Q.   Okay. Where is that? .
     15          A.   Well, I don't actually have a residence, but it
     16    used to be on X. I just -- I didn't really
     17    sell it,  but I didn't renew my lease.  So now I'm just
     18    staying with some friends until my condo's finished.
     19          Q.   So you're moving?
     20          A.   Yes.
     21          Q.   In the process of moving?
     22          A.   Yes.
     23          Q.   Where is your office located?
     24          A.   X, Clearwater.
     25          Q.   Are you a sole practitioner or do you have a

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      1    partner?
      2          A.   Sole.
      3          Q.   And how long have you been doing that?
      4          A.   Three years.
      5          Q.   All right. How long have you lived in Clearwater,
      6    total?
      7          A.   Since 1991.
      8          Q.   Okay.  Where did you live prior to that?
      9          A.   Michigan.
      10         Q.   Michigan?
      11         A.   Uh-huh.
      12         Q.   Okay.  How long have you been a member of the
      13   Church?
      14         A.   I think that was 1986 or `87.
      15         Q.   Okay.  And I assume you joined the Church in
      16   another state, in Michigan?
      17         A.   No, I don't -- I don't think I quite understand
      18   the question now.
      19         Q.   How did you become involved in the Church?  When
      20   was your first involvement with the Church and where was
      21   that?
      22                  MS. REBACK:  Excuse me.  I'm not sure that
      23         that's relevant to the inquiry into -- that we're here
      24         for, her -- how she became involved with the Church
      25         initially.

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      1          MR. McGARRY: Why not?
      2          MS. REBACK:  Well, I mean, I'm just not sure
      3    that it is.  I don't know whether she's comfortable or
      4    not answering those questions.  But it just seems to me
      5    that that's a little far afield.
      6          MR. McGARRY:  Well, after we get going, I
      7    think you'll realize that most of these questions will
      8    be relevant.
      9          MS. REBACK: Well, how she initially became
     10    involved with the Church?
     11          MR. McGARRY: Well, let me ask you this:
     12    She's here pursuant to subpoena, right?
     13          MS. REBACK: Right.
     14          MR. McGARRY: She's got immunity?
     15          MS. REBACK: Right.
     16          MR. McGARRY: I'm not asking her any
     17    privileged information, I'm not asking prying
     18    information, other than birth date so far.  This is
     19    just background to get me started.
     20          If you've got a problem, we can back this
     21    thing up and go see a judge, and we can make this
     22    adversarial right now. I'm not trying to be prying,
     23    I'll just starting out my interview with her background
     24    with the Church, because that's where Lisa belongs,
     25    that's where she belongs.

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      1          MS. REBACK: Okay. Why don't we do it like
      2    this:  Let me just suggest, she's a little bit
      3    concerned that there will be questions relating to her
      4    participation with the Church or Church functions or
      5    Church issues that she may or may not have participated
      6    in that may or may not be relevant to your inquiry.  So
      7    that's the only concern. I'd like --
      8          MR. McGARRY: Let me put this on the record:
      9    I will make the determination what's relevant under my
     10    subpoena for a State Attorney Investigation. And if
     11    it's -- you've got an objection to that, we'll just --
     12    we'll settle it up with a judge.
     13          MS. REBACK: Okay. Why don't we do that.
     14          MR. McGARRY: We haven't even started the
     15    interview, you've got an objection to me asking her
     16    where she got involved with the Church of Scientology.
     17    That's not getting very far.
     18          MS. REBACK: Right. That's true. Because I
     19    don't see the relevancy. -
     20          MR. McGARRY: My relevancy in the question
     21    is, the Church of Scientology is where they're both
     22    members of. Do you agree with that?
     23          MS. REBACK Yes.
     24          If you asked her, are you a member of the
     25    Church, I think she should answer that. But you're

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      1    asking what the processes were when she initially
      2    became involved.
      3               MR. McGARRY:  No, I didn't. I asked her
      4    where she joined the Church.
      5               MS. REBACK: But initially, not around the
      6    time of your -- the area that you're inquiring into.
      7    That's my concern.
      8               MR. McGARRY: Do you have a problem with that
      9    question, where -- when you joined the Church? Is
     10    that --
     1l               MS. REBACK: No. She answered that one.
     12               MR. McGARRY: Is that a problem?
     13               MS. REBACK: She answered that. She answered
     14    when she joined the Church.
     15               MR. McGARRY: Your problem is what state it
     16    was?
     17               MS. REBACK: No. My problem is, generally
     18    are we going to go through her involvement with the
     19    Church from the very beginning up until the present?
     20    That's my problem or question.
     21               MR. .McGARRY: I really didn't think it was
     22    going to be a problem, asking her where she joined the
     23    Church. If that's a -- I'll skip that. But I have a
     24    feeling we're going to end up in front of a judge
     25    sooner or later.

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      1               MS. REBACK: No. Listen, Mark, my only
      2    problem -- that's why I asked you -- is, are we going
      3    to go through all of her -- because you asked
      4    "initially" -- are we going to go through all of her
      5    involvement with the Church from initially to the
      6    present? If we are, then I think we do have a problem.
      7    If we're not, then we don't.
      8               MR. McGARRY: I'm just trying to set the
      9    stage, how she got to Clearwater in the first place.
      10              MS. REBACK: . Okay. That's the question you
      11   might want to ask her then.
      12              MR. McGARRY:  I did. I asked her where she
      13   joined the Church, in what state.  She moved to
      14   Clearwater what, `91?
      15              THE WITNESS:  Yes.
      16              MR. McGARRY:  Okay. Moved from Michigan?
      17              THE WITNESS:  Yes.
      18              MR. McGARRY:  Prior to Michigan you lived in
      19   another state?
      20              THE WITNESS:  No.
      21              MR. McGARRY:  Okay. So you joined the Church
      22   in  Michigan?
      23              THE WITNESS:  I became familiar with the
      24   Church.
      25              MR. McGARRY:  That's my question. She joined

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      1    the Church prior to coming to Clearwater.
      2               MS. REBACK: Fine.
      3               MR. McGARRY: Because she said she joined in
      4    1986.
      5               MS. REBACK: And that's fine. I asked you,
      6    are we going to go -- start with her involvement with
      7    he Church initially and go through all of her
      8    involvement with the Church up to the present. If
      9    we're not, I don't have a problem.
     10    BY MR. McGARRY:
     11          Q.   You joined the Church somewhere prior to 1986 or
     12    somewhere during the year of 1986?
     13          A.   Yes.
     14          Q.   Member of the Church in Michigan?
     15          A.   No, I never participated with anything.
     16          Q.   Moved to Clearwater, participated with the Church?
     17          A.   Yes.
     18          Q.   Still are a practicing Scientologist?
     19          A.   Yes.
     20               MR. McGARRY: Is that okay?
     21               MS. REBACK: Fine. Thank you.
     22          Q.   I understand you are of a level of OT-VIII; is
     23    that correct? .
     24          A.   Yes.
     25          Q.   Okay. And have you ever been a member of Staff --

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      1          A.   No.
      2          Q.   -- in reference to the Church?
      3          A.   No.
      4          Q.   You've always been a parishioner?
      5          A.   A Public, uh-huh.
      6          Q.   Public is what it's called?
      7          A.   Yeah.
      8          Q.   Thank you.
      9               When did you first meet Lisa McPherson?
     10          A.   In 1994.
     11          Q.   Okay. And what reference was that in?
     12          A.   As a patient.
     13          Q.   Did she come to you -- how were you recommended to
     14    her?  I mean, did you know her as a member of the Church or
     15    did she come to you as a recommendation or how did you get
     16    referred to her?
     17          A.   She was referred to me by Benetta Slaughter.
     18          Q.   Okay.  And she had a chiropractic problem?
     19          A.   Yes.
     20          Q.   Okay.  And you ended up treating her for that
     21    problem?
     22          A.   Yes.
     23          Q.   And that was what month?
     24          A.   I'll have to look at my records.
     25               It was August 24th, 1994.

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      1          Q.   Of `94?
      2          A.   Yep.
      3          Q.   Okay. Do you remember or do your records reflect
      4    how many sessions you had with Lisa during that period of
      5    time?
      6          A.   I don't. But if you want me to look at --
      7          Q.   Well, just give me an estimate. That's not that
      8    big a thing.
      9          A.   20 or 30.
     10          Q.   Okay. Did she get improvement from that?
     11          A.   She had her -- her moments of improvement, yes.
     12          Q.   What exactly were her symptoms? I mean, what were
     13    her complaints?
     14          A. - When she first came to me she complained of dizzy
     15    spells for the last few months.  She also wanted to verify
     16    the effectiveness of her supplements and wanted to know if
     17    she was salt deficient, as well as a history of this lower
     18    back.
     19          Q.   Okay. Those are interesting topics for, if I
     20    might say, for inquiring from a chiropractor.  I mean, are
     21    you -- are you trained in other areas other than just
     22    chiropractic medicine?
     23          A.   Nutrition is involved in that.
     24          Q.   It is involved in that in the normal application
     25    of a chiropractic practice?

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      1          A.   Yes.
      2          Q.   That's interesting.
      3               So how did the -- how did those issues come up?
      4    Did you make those diagnoses or did she come to you and say,
      5    I've got a deficiency in some type of potassium or salt?
      6          A.   She originated that.
      7          Q.   She did?
      8          A.   Uh-huh, yes.
      9          Q.   Was that -- that information was given to you how?
     10    Did she tell you that -- that she had gotten that from
     11    somebody else or did she just tell you, I think I'm salt
     12    deficient or potassium deficient?
     13          A.   She just said that that's what she thought.  She
     14    didn't mention that it came from any other source. She just
     15    wrote it down as her chief complaints, that she was having
     16    these dizzy spells, she wondered if she was salt deficient.
     17          Q.   Did you go over with her what her supplement
     18    program was?
     19          A.   At that time she -- she told me what she was
     20    taking, yes.
     21          Q.   Okay. And is that -- was that supplement
     22    program -- when you say "supplement program," that is, in
     23    addition to your everyday diet, food diet, she was taking
     24    what extra? Did you know that? -
     25          A.   Yes.

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      1          Q.   What was that?
      2          A.   She was taking blue-green algae, Super Q-10, she
      3    was taking salt and iron, folic acid, some nutritional packs
      4    that come with Bs and Cs and Es and Ds.
      s          Q.   How did she -- did you gain the knowledge of how
      6    she had come to get into that, how she -- is that a
      7    scientology program that was implemented or was that
      8    something she did at a health food store or how did that
      9    become implemented in her diet?
     10          A.   Yes, that was something she did at a health food
     11    store. It seems like today many people have been doing a
     12    lot of reading and they're familiar with different types of
     13    nutrients. And so this was her program that she had somehow
     14    come up with.
     15          Q.   Devised for herself?
     16          A.   Uh-huh.
     17          Q.   Did you advise her on any of that or did you
     18    comment on that, how that combination was working for her?
     19          A.   Well, I did a type of technology that uses muscle
     20    testing, it's like applied kinesiology. And so she didn't
     21    happen to bring those that day, but I test those things to
     22    see if they work well with the body or not.
     23          Q.   Okay. And did you do that?
     24          A.   Yes.
     25          Q.   And what was your finding?

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      1          A.   She needed salt.
      2          Q.   She needed salt?
      3          A.   Uh-huh.
      4          Q.   I'm not a doctor, but what is the byproduct of her
      5    lack of salt with her physiological well-being?
      6          A.   Well, what I find clinically is people who are
      7    salt deficient then become dehydrated, and with that you can
      8    have headaches, you can have dizziness, you can have
      9    disorientation, weakness.  Sometimes people, I find, throw
     10    up, nausea.
     11          Q.   Okay. Did you recommend a change or were you
     12    satisfied with her supplemental program?
     13          A.   I recommended a change.
     14          Q.   And what recommendations were made?
     15          A.   Well, there was a -- there's a salt that I'm very
     16    aware of, it's considered an acid salt, that's closer to the
     17    salt that's found in the body, and I suggested she take
     18    that.
     19          Q.   Okay. Do you know if she did?
     20          A.   Yes, she did. -
     21          Q.   She did supplement with that?
     22          A.   Yes.
     23          Q.   Okay.  Did you make any other observations as her
     24    chiropractor during that period of time that you noted in
     25    your file about her physical well-being, about whether or

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      1    not she was -- had any other medical deficiencies that you
      2    might note?
      3          A.   Well, she did have this back problem, but she also
      4    had some allergies. She was complaining about her eyes and,
      s    basically, seasonal allergies.
      6          Q.   All right.  Were any supplements recommended for
      7    the treatment of any of those problems?
      8          A.   Yes, uh-huh.  Yes, I gave her two -- suggested two
      9    supplements that are very specific for eyes and -- and
      10   natural antihistamine.
      11         Q.   And what were those?
      12         A.   It's called Antrinex, this comes from
      13   Standard Process Labs, that's its name, Iplex, and then a
      14   Basic 4 that feeds the adrenals and heart, there are four,
      15   two B-6, B-6 with Niacin, something called R&D and
      16   organic iodine.
      17         Q.   Okay. Did she appear the type of person that was
      18   diligent about taking those on a regular basis?  Was she one
      19   of these hit or miss persons or do you feel that she was
      20   pretty consistent with her -- with her regimen of taking
      21   these supplements?  Is it something she did every day?
      22         A.   At that point it seems to be diligent.  It didn't
      23   stay consistent.
      24         Q.   It didn't stay consistent?
      25         A.   No.

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      1          Q.   When did you observe some inconsistency with that
      2    particular program?
      3          A.   Well, just in the course of time she seemed to
      4    keep having, you know, different types of problems that she
      5    would then come with.  And I'd ask, Are you still taking
      6    your supplements? And she'd say, No, not necessarily. And
      7    then I would just repeat to her that she should, and I would
      8    test her for -- for other things.
      9          Q.   Okay. Can you give me a little bit of chronology
     10    of how that was going as far as her dropping off the
     11    supplement program, if you can?
     12          A.   Yes. She was -- she was good for about two
     13    months, and then she started having trouble with her back.
     14    She had moved a dresser and that created some problems.  And
     15    then the next notation I have is in November, and she was
     16    having some trouble with her period, so we changed --
     17          Q.   November of `94?
     18          A.  `94, uh-huh.
     19               And we changed her program then. And then she
     20    stayed pretty consistent until probably the following year,
     21    like in January, things were changing for her.
     22          Q.   In what respect?
     23          A.   She didn't seem very happy.
     24          Q.-  Okay.  So I take it that she was not only -- this
     25    may be an assumption, correct me if I'm wrong -- she was not

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      1    only coming to you for chiropractic work, some nutritional
      2    advice, but you also confided -- she confided in you as well
      3    how she was doing emotionally and as far as her emotional
      4    well-being?
      5          A.   Yes.
      6          Q.   Were you on that level with her?
      7          A.   Most patients, that is the level I have with them,
      8     and she was too.
      9          Q.   That's what I'm asking. I didn't know what level
      10    you got with her.
      11         A.   Uh-huh.
      12         Q.   Did you become friends through all of this, more
      13    than just a doctor/patient?               -
      14         A.   Well, I -- I try not to become friends with my
      15    patients at all. But I would see her occasionally. She and
      16    I were involved with the Winter Wonderland, and so --
      17         Q.   Which is Benetta's big project, right?
      18         A.   Right.
      19         Q.   Does that project go on every year?
      20         A.   It had been. I don't know if it's going to happen
      21    this year.
      22         Q.   Okay. And that was -- we'll get to that, but that
      23    was what she -- she apparently was working on that this
      24    November that she ended up having her problem?
      25         A.   Uh-huh.

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      1          Q.   Okay. So tell me about what was troubling Lisa as
      2    best you can recall during that period of time in January of
      3    `95.
      4          A.   Well, she -- she had trouble with boyfriends. And
      5    I know that she had -- I just make occasionally some
      6    notations about what is happening in people's lives to see
      7    if it's affecting their health or no.
      8               But she had -- in February she was back with
      9    this -- her boyfriend at that time. His name was Kurt.
     10          Q.   Payne, right.
     11          A.   And -- and she emotionally had some ups and downs,
     12    it seemed like, with that. -
     13               And then she had hurt her back in February 24th
     14    and was in quite a bit of pain. So it seemed like
     15    everything in her life was more intense at that time.
     16               And then we -- in March I have a notation here
     17    saying that she needed some salt. She never did, in the
     18    whole time I saw her, did well with salt, with the heat.
     19               And in April -- on April 4th I have a notation
     20   here saying she was very unhappy with basically everything
     21   in life. And to me there was definitely some change in her.
     22   She was not as outgoing, she seemed to be withdrawn. And --
     23          Q.   Were you aware that she was trying to correct that
     24   through some various programs that the Church offered?
     25          A.   Yes.

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      1          Q.   Courses?
      2          A.   Yes.
      3          Q.   Okay. How far through that summer did you
      4    continue to treat Lisa, the summer of `95?
      5          A.   The last time I saw her was the 11th of July.
      6          Q.   Of July?
      7          A.   Uh-huh.
      8          Q.   Okay. That was a particularly bad period for her,
      9    correct?
      10         A.   Yes.
      11         Q.   Okay.
      12         A.   The notations that I have around that time was, in
      13   addition to what was happening in her -- to her personal
      14   life, she was having a problem with salt.  That was a big,
      15   big problem for her.  She was taking lots and lots of sea
      16   salt, lots of this Calamo.  She always seemed like people
      17   that are dehydrated.  She always looked anxious.  And people
      18   that were about to pass out, that kind of look.  She just
      19   never looked good that summer to me.
      20              And then the 11th she was having trouble sleeping.
      21   And then our last real communication was on the 14th,
      22   because she was having trouble with salt, and she was dizzy,
      23   and she wasn't -- she had no appetite, and she wasn't
      24   sleeping.  And so she had called me on the phone and asked
      25   me for a particular formula to give her over the phone, and

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      1    I suggested some salt and potassium. And then she called
      2    back, said that helped. Then a couple days later,
      3    apparently, if the amount I told her helped at that time.
      4    then twice the amount would be better, and that's what she
      5    did.
      6               But our last -- the reason she -- she stopped
      7    coming --
      8          Q.   Did that result in a problem for her, doubling up
      9    on the --
     10          A.   Yes.
     11          Q.   What was the result of that?
     12          A.   Well, she felt sick.
     13          Q.   Of course.
     14          A.   And it didn't resolve the problem of her appetite
     15    or her sleep or her ability to --
     16          Q.   Right.
     17          A.   So on the 14th she called me at my office and said
     18    that she had gone to another doctor who had been recommended
     19    to her, who had this -- somebody had had a similar problem.
     20    And so she -- she went there to get it resolved and it
     21    didn't resolve. And I just told her that I probably
     22    couldn't take care of her any longer.
     23          Q.   Okay. So your relationship with her
     24    professionally terminated in the end of July -- middle of
     25    July, I guess, right?

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      1          A.   Yes, uh-huh.
      2          Q.   How would you describe the termination of that
      3    relationship? Was there any animosity that built up between
      4    the two of you or was it generally pleasant?
      5          A.   It was pleasant. It was just that, you know, when
      6    I have a patient who's non-compliant/or is deciding, you
      7    know, to be their own doctor, then I feel that my hands are
      8    basically tied.
      9               I saw her once or twice after that, at one of
      10    these meetings to -- to talk about Winter Wonderland, and we
      11    said hello, but we didn't have any lengthy conversation.
      12         Q.   Okay. Who was the doctor that she ended up being
      13    referred to, if you know?
      14         A.   Jere Jarrett.
      15         Q.   Jere Jarrett?
      16         A.   Uh-huh.
      17         Q.   Is he a Clearwater doctor?
      18         A.   Uh-huh, chiropractor.
      19         Q.   He also is a chiropractor?
      20         A.   Right.
      21              And it was my understanding she saw him that one
      22   time, he gave a recommendation for Bs, Vitamin Bs and stuff,
      23   but then she didn't go back, as far as I understand.
      24         Q.   So best you know, she went there one time?
      25         A.   Right.

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      1          Q.   All right. Well, were you aware that apparently
      2    that summer she had a pretty tough time with -- with several
      3    things that she was dealing with?   And some of the other
      4    Church members described the June period as a -- as her
      5    first psychotic break or first real mental problem that she
      6    had and she actually sought treatment or some courses, I
      7    guess, at the Church, in which she was spending the night on
      8    numerous days, or I think she spent a week at the Church
      9    receiving courses or counseling or something.
     10               Were you aware of that period, that June/July
     11    period?
     12          A.   I knew that things were pretty intense.  I didn't
     13    know exactly what was happening in June, but I felt it
     14    started well before then, in April.  Because we didn't
     15    socialize outside of my -- my practice.
     16               I saw her one time, and I think it was around in
     17    April, over at the Church at a restaurant.  And she looked
     18    pretty unhappy.  And she was sitting by herself. And I,
     19    since I hadn't seen her and really discussed anything with
     20    her, I sat down with her for a little while.  And at that
     21    time she had talked about suicide.  And she had never
     22    mentioned that in the course of any of the times that she
     23    was ever in my office, but she was that unhappy.
     24          Q.   That's pretty serious.
     25          A.   Yes.

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      1          Q.   Can you -- that probably isn't reflected in your
      2    records, but can you describe when that was, as best you
      3    can?
      4          A.   I have an idea that it was in the early spring,
      5    like April or so, because when she did come into my office
      6    during that time, she was -- she just didn't look happy.
      7          Q.   Were you aware that she had some -- a history in
      8    her family of some mental instability?
      9          A.   I actually didn't know that until the night of the
     10    accident.
     11          Q.   Okay. How did you gain that information?
     12          A.   I was working in my office, and I knew that she
     13    had been -- because I take care of other patients from AMC,
     14    that she was having very erratic behavior.
     15               And so that particular weekend there was some kind
     16    of convention or seminar in Orlando.  And I'm pretty sure
     17    this was a Saturday, I should find out, whenever the
     18    accident was.  Brenda Hubert, who is also a patient of mine
     19    and was at the seminar with her, called my office because
     20    she needed to be adjusted.  She said she had a very bad
     21    weekend.  I don't remember whether she had a headache or --
     22    so since I was working in the office, that was fine for her
     23    to come over.
     24               So she came over. And she was distraught at the
     25    behavior of Lisa that weekend.

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      1          Q.   Over in Orlando?
      2          A.   Yes.
      3               So during the course of that evening Brenda told
      4    me what had happened, about her family situation, her father
      5    and --
      6          Q.   Brother.
      7          A.   -- brother both had committed suicide and her
      8    mother had a little drinking problem.  So that's the first I
      9    knew anything about her personal history.
     10          Q.   Okay. So that information came to you from
     11    Brenda.  And was that prior to her car wreck or after the
     12    car wreck?
     13          A.   It was that -- that night, that evening.  It
     14    was -- it was dark outside.  I don't know what the time was.
     15               But Brenda left after the adjustment and her
     16    telling me all this.  And within five or ten minutes Benetta
     17    called me and said that Lisa had been in an accident.  And
     18    Brenda wasn't even aware of that had happened.
     19          Q.   Oh, is that right?
     20               So she hadn't communicated with Benetta at the
     21    time?
     22          A.   No.
     23          Q.   What time was that that Benetta called you?
     24          A.   I don't know.
     25          Q.   About.

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      1          A.   Eight-ish. I don't know.
      2          Q.   And what action did you take upon that phone call?
      3          A.   Well, she had asked me if I would go over to the
      4    hospital.  She didn't know what had occurred or what
      5    condition Lisa was in, and would I go.  So I said yes, I
      6    would.  So I did.
      7          Q.   And the reason why you were called is because you
      8    were at least at one time her physician?
      9          A.   Yes.
      10         Q.   Okay.  Is that a common practice, that you would
      11   show up for patients?
      12         A.     (The witness nods affirmatively.)
      13         Q.   And did you go over there by yourself
      14         A.   Yes.
      15         Q.   -- or did you take anybody?
      16         A.   By myself.
      17         Q.   Okay.  Can you describe who was there when you
      18    arrived and what you did?
      19         A.   When I went through the emergency, I saw
      20    David Slaughter, Benetta's husband.  I don't recall if he
      21    was with someone or not, sthying with someone, I think not.
      22    And I said -- asked him where Lisa was.  And he said, In the
      23    emergency.
      24              I asked permission to go back there and they said
      25    I could.  And when I got to the room she happened to be in,

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      1    there was another woman there whose name was Mary, and I --
      2    maybe it's DeWitt, I don't -- I don't know what her last
      3    name  was.
      4          Q.   Okay.
      5          A.   But she at that time was an assistant to Benetta.
      6          Q.   To Benetta?
      7          A.   Uh-huh.
      8          Q.   Is she still there, do you know?
      9          A.   I think not.
      10         Q.   Do you know Judy Goldsberry-Weber?
      11         A.   Judy who?
      12         Q.   Judy Goldsberry-Weber.
      13         A.     (Witness shakes head negatively.)
      14         Q.   Older woman, works in the MLO Office.
      15         A.   Oh, yes, I do.  I did not know what her name was.
      16         Q.   Was she there?
      17         A.   Not when I got there.
      18         Q.   You were there prior to her arrival?
      19         A.   Yes.
      20         Q.   What did you do when you got back to the
      21   emergency, you got in contact with Lisa?
      22         A.   Yes. I got right in there and I just walked up to
      23   her and held her hand.  She responded to me, but she was --
      24         Q.   Were you briefed on exactly what the circumstances
      25   of her --

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      1          A.   No.  I had no idea.
      2          Q.   So you didn't know about that?
      3          A.   No.
      4          Q.   Okay.
      5          A.   And for me it was a matter of -just, you know,
      6    looking around and seeing what was -- trying to figure out
      7    what was going on and what was needed.
      8          Q.   So you hadn't gained the information she was
      9    running around the streets --
     10          A.   No.
     11          Q.   -- without any clothes on?
     12          A.   I didn't know what the accident was.  And to this
     13    day, I don't think I've gotten any of the details, whether
     14    it was behind a car or a -- somebody pulling a boat, is
     15    that -- might have been what I heard too, I don't know.
     16               But the fact that she was there in the hospital, I
     17    just basically told her--- you know, trying to be very light
     18    about it, that what -- what do you discuss in hospitals?
     19          Q.   Right. . -
     20          A.   And I just told her that, you really screwed up.
     21    Whatever got her to that point, she was ...
     22          Q.   Well, how did she appear then?  Were you able to
     23    look at her and make an assessment as to whether or not she
     24    should be admitted or not admitted?
     25          A.   Well, my own assessmen  in looking at her, there

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      1    was no contusions, there was no lacerations, there, was no
      2    blood.  She seemed somewhat like anybody might be if they're
      3    in an accident, somewhat bewildered or shocked.
      4          Q.   How was she clothed at that time, do you know?
      5          A.   She was in a gown.
      6          Q.   Oh, something from the hospital --
      7          A.   Yeah, uh-huh.
      8          Q.   Did you have any conversations with anybody in the
      9    hospital itself?
     10          A.   Not at that time, no.
     11          Q.   Did you ever?
     12          A.   Yes.
     13          Q.   Who was that?
     14          A.   Well, there was a -- a psychiatric nurse and an
     15    attending nurse of some sort that would come in
     16    occasionally, and then there was Dr. Lovett, who was the
     17    emergency medical doctor. And during the course of the time
     18    that I was standing there, they came in to observe her and
     19    ask her questions.
     20          Q.   So mostly you were just a bystander at this time
     21    listening to what's going on?
     22          A.   Yes.
     23          Q.   Okay.  Did you interject or participate in any
     24    way?
     25          A.   No. I didn't know anything that was

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      1          Q.   So at the time there was -- I assume they were all
      2    assessing her ability to leave on her own accord?
      3          A.   Yes.
      4          Q.   Okay.  Was that assessment eventually made?
      5          A.   Yes.
      6          Q.   Okay.  Who made that assessment?
      7          A.   Well, Dr. Lovett had to.
      8          Q.   He's the one?
      9          A.   Yeah.
     10          Q.   Okay.  And what input did he receive from anybody
     11    else other than Lisa to help him make his decision that you
     12    know of?
     13          A.   Well, my own personal understand -- thinking on it
     14    now, after the fact, is that the biggest problem was
     15    wondering about her mental state --
     16          Q.   Right.
     17          A.   -- and are they -- when -- at one time I came put
     18    into the hall, and I believe it was the psychiatric nurse
     19    that I spoke with at that time, and they couldn't understand
     20    why a person -- because at this time they told me that she
     21    had taken her clothes off, and they couldn't understand what
     22    that was.  Well, that was at the time that I mentioned that
     23    she had this history.  And he said, well, that was
     24    information that they didn't have.
     25          Q.   The history of what you just, gave me?

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      1         A.   Pretty much -- no, about the -- they were -- it
      2    looked as though they were viewing her from her mental
      3    state.
      4         Q.   Oh, okay.  Her history, family history?
      5         A.   Family history.
      6         Q.   Okay.  Thank-you.
      7         A.   I also told them that there was a salt depletion
      8    thing that I had been struggling with with her for some
      9    months.  And then after that -- so it seemed to make more
     10    sense to him for some reason.  And then after that he came
     11    back in and said to her, okay, I'm going to ask you the
     12    64-million-dollar question.  And he said, What does it mean
     13    to you that people in glass houses shouldn't throw stones?
     14    And she said -- you know, gave the appropriate response.  He
     15    was satisfied with that.  And then he left and there was
     16    some conferring out in the hallway.
     17               One of the nurses came back in.  She said that she
     18    was going to be released and we'd have to get her clothed.
     19    And then that nurse left and shortly after Dr. Lovett came
     20    in.  And he was -- I think he was the one that came in,
     21    perhaps with the nurse, with this release form.  And wanting
     22    Lisa to sign it and then I signed as a witness.
     23               And he was upset of the fact `that, you know, she
     24    had taken her clothes off and couldn't quite understand that
     25    and -- and asked her if she thought it was normal.  And then

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      1    said he was releasing her.
      2          Q.   Do you recall Alain Kartuzinski being there?
      3          A.   Yes, at some point while I was there he came.  And
      4    he walked in, I think there was a -- Dr. Lovett may have
      5    been there at the time at the bed, by the bed, and he asked
      6    who he was.  And he said he was her Minister.  And he held
      7    her hand and just, you know, did the kind of social talk one
      8    talks.
      9          Q.   If I told you he was not crazy about releasing
     10    her, Dr. Lovett I mean, is that the position he was taking
     11    at that time?
     12          A.   Well, he seemed angry.  I don't know why he was
     13    angry.  And I -- I don't have any data about that.  But he
     14    just seemed angry.
     15          Q.   Okay.  You don't know why?
     16          A.   No.
     17          Q.   All right.  We know now that he was convinced or
     18    at least the decision was made to release Lisa.  Can you
     19    tell me what conditions that he required or whether there
     20    were any in reference for him to sign out on her?
     21          A.   No, he said nothing about that.
     22          Q.   All right.  There's a release form that I have
     23    somewhere in all these papers in front of me.  Did you sign
     24    on that?
     25         A. I signed a piece of paper, yes.

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      1          Q.   Okay.
      2          A.   And I assumed it was a release paper.
      3          Q.   Right.
      4               Do you recall how that went?  Did he ask you to do
      5    that or was that something you said you would do?
      6          A.   Well, I was standing there next to her, so I just
      7    signed.
      8          Q.   Who else signed it, do you know?
      9          A.   Just her and I, as far as I know.
     10          Q.   Okay. Did you ever have any conversations with
     11    Benetta while you were at Morton Plant?
     12          A.   No.
     13          Q.   Are you familiar with the circumstances of her
     14    actually leaving and who she left with?  "Her" being Lisa.
     15          A.   Yes.
     16          Q.   And how did that go?
     17          A.   Well, when they -- when they said that -- when
     18    Lovett left, then I helped her get dressed.  And she had no
     19    shoes, so they brought in -- apparently they can't release
     20    someone without something on their feet, so they brought in
     21    these little greenpaper things.  And -- and I -- I -- I
     22    just walked out with her.  There was no one else there.  And
     23    I walked out.
     24               And I remember as we were walking out, Dr. Lovett
     25    was standing back a bit with somebody else talking. And he

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      1    made a comment about her shoes.  And we acknowledged his
      2    comment.  And we walked out.  And I -- I actually walked her
      3    right out the door.
      4               And Mr. Kartuzinski was outside as well.  And
      5    he -- I was walking on one side of her, and then he came on
      6    the other side.  And they -- you know, the social thing,
      7    How's it going?  She says, fine.  And he said, Well, you can
      8    ride with me.
      9               And so I walked with them to the car and helped
     10    her get in, because I -- I didn't know if she was still a
     11    little disoriented about that.  So she got in the car.  I
     12    put the seat belt on her.  They drove to the Fort Harrison,
     13    and I followed.
     14          Q.   You followed them there?
     15          A.     (The witness nods affirmatively.)
     16          Q.   Did you know what the plan was from that point
     17    when you left Morton Plant, why she was going there rather
     18    than home?
     19          A.   No, I don't.
     20          Q.   I mean, you didn't have a conversation where
     21    anybody said, hey, let's just take her to the hotel, that
     22    would be the best place for her right now, we'll look after
     23    her?
     24          A.   No.
     25          Q.   Or you were not privy to that conversation?

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      1          A.   No, I was not privy.
      2          Q.   Okay.  Why did you follow them to the hotel?
      3          A.   I felt responsible that I saw her to bed.  I
      4    wanted to  make sure that she would either get in bed or, you
      5    know, be safe.
      6          Q.   And did you go straight to the Church hotel?
      7          A.   Uh-huh.  I parked the car, and by the time I then
      8    got out, she -- the car had been pulled up.  And she wasn't
      9    out of the car yet.  So there were a couple of people, I
      10   don't know who they were, that arrived there by the car too.
      11   And when the car opened, I unbuckled her, I took her hand
      12   and helped her out.
      13              Mr. Kartuzinski took the car away, as far as I
      14   remember, and then we walked -- I just started walking with
      15   her, because she did seem somewhat still not sure of
      16   where -- you know, her orientation.  So I just walked with
      17   her.  And someone said that they had a room available for
      18   her.  And I walked in with her to the room.
      19         Q.   So somewhere along here you realized, hey, she's
      20   checking in, she's checking in here, she's not going home?
      21         A.   Yeah. That they had a room for her, yes.
      22         Q.   Okay.
      23         A.   So we took her into this room.
      24         Q.   Who's "we"?
      25         A.   I don't know who the other two people were.

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      1          Q.   Kartuzinski and you?
      2          A.   No, Kartuzinski was parking the car.  I never saw
      3    Kartuzinski after he dropped her off.
      4          Q. Okay. Could it have been Judy, maybe, or somebody
      5    else from the MLO Office?
      6          A.   I don't think it was Judy, because I saw her once
      7    at the hospital --
      8          Q.   Right.
      9          A.   -- but I don't think I. saw her after that.
      10         Q.   Okay.
      11         A.   And then we walked to this room and we went in.
      12   And then I --
      13         Q.   Do you remember where that room was?
      14         A.   It was what they call a Cabana, and it's -- I
      15    don't know what room number or anything.
      16         Q.   Yeah.
      17         A.   So then we were -- you know, we're just sitting.
      18    I'm thinking, now -- now what?  I think about all the times
      19    I've ever been to an emergency room, what to do with the
      20    patient afterwards.
      21               So at some point she said she had to go to the
      22    bathroom.  So I walked with her to the bathroom, she sat
      23    down.  And then I was out talking to one person.  She was a
      24    dark haired woman, I don't even know what her name was.  And
      25    we were chatting for a while and -- nothing about Lisa,

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      1    because I don't think this woman knew and I certainly didn't
      2    have all the details.
      3               But it seems as though it was some time had
      4    elapsed, so I called to Lisa and asked her if she was okay.
      5    She said yes.  And more time elapsed and I said, Are you
      6    finished?  And she said, I found a nail here. And I said
      7    okay.
      8               So then I came to -- around to where she was, and
      9    there was this -- the door frame and saw a spot where there
     10    was a nail, and she had been interested in that nail,
     11    apparently.  And I said, Are you finished going to the
     12    bathroom?  And she said she didn't have to go.  So she got
     13    up, we walked out, and then sat on the bed until somebody
     14    else came.  And I felt my -- at that point my job was done.
     15    But I did suggest that --
     16          Q.   Do you know who the person was that came?
     17          A.   No.
     18          Q.   Okay.
     19          A.   But then as I was leaving, I suggested that she
     20    get something to eat, 'cause I didn't know when she'd eaten
     21    last.  And under the circumstance, with the condition she
     22    seemed to be in, that she should have a protein drink.  That
     23    way she'd be able to get enough protein without having a
     24    heavy meal, it might be more palatable to her.
     25          Q.   Your assessment of this bathroom situation with

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      1    the nail, is that -- when you look back on that now, are you
      2    of the opinion that she was not quite right right there at
      3    that moment?
      4          A.   It seemed that way. Something was --
      5          Q.   Amiss?
      6          A.   Yeah.
      7          Q.   Okay.  Her physical well-being, can you describe
      8    that at that moment?  I mean, this is apparently the last
      9    time you saw her, right?
      10         A.   Yes.
      11              She seemed to me, especially in the course of the
      12     time that I took care of her with the salt issue, sometimes
      13     she would look thin to me and sometimes she wouldn't.  And
      14     sometimes she would look with her eyes sunken and kind of a
      15     sweaty kind of a thing, like some people get when they're
      16     having trouble with salt, potassium.  And that's the way she
      17     seemed that night.  She seemed like that.
      18         Q.   All right.  And that was November 18th in the
      19     evening, approximately what time, do you know?  Do you know
      20     what time it was she got in there?
      21         A.   I think -- I don't know what time she got over
      22     there.
      23         Q.   Late evening, probably, right?
      24         A.   Uh-huh.
      25         Q.   Did you talk to anybody when you left?

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      1          A.   No. My last -- my last suggestion was the protein
      2    drink, and then I -- I left.
      3          Q.   Did you discuss with anybody what particular
      4    course or program or course of action was going to be
      5    implemented for Lisa?
      6          A.   No.
      7          Q.   Okay.  Did you tell Benetta -- did you brief
      8    Benetta on what you observed and what you saw?
      9          A.   Not that night, but probably sometime after.
      10         Q.   You and Benetta are close, correct?
      11         A.   We're friends, yes.
      12         Q.   Benetta was Lisa's employer, right?
      13         A.   Right.
      14         Q.   Was -- if you know, were Lisa and Benetta close?
      15         A.   Yes.
      16         Q.   Were they good friends?
      17         A.   Very good friends.  They came from Texas together.
      18              They had worked together a lot and built a business
      19   together.
      20         Q.   Oh, that's where AMC started?
      21         A.   Uh-huh.
      22         Q.   And they moved the business to Clearwater?
      23         A.   Yes.
      24         Q.   Okay.  Lisa ever express any -- anything about her
      25   pressures from the business end of it all?  Was she under a

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      1    lot of strain to produce for AMC or maybe from the
      2    Scientology aspect of it for the Winter Wonderland project?
      3    or do you think any of those aspects of her life played a
      4    role with what was happening with her at this point?
      5          A.   No, I don't think the pressure was from this.  She
      6    was a very -- very able and very much a high producer with
      7    what she did, and she was very good at it.
      8          Q.   High producer meaning business-wise?
      9          A.   Uh-huh, business-wise.
      10              The only thing that she'd ever mentioned was that
      11   she felt she was letting people down in the course of 1995,
      12   early, because she was unhappy and sometimes, in my opinion,
      13   could be considered despondent in a lay -- from a lay point
      14   of view.  I think she felt that she was letting people down.
      15         Q.   And that was, you said, during that summer period
      16   that we talked about earlier?
      17         A.   Well, I think even earlier.  I think that was part
      18   of that --
      19         Q.   Earlier than that?
      20         A.   Uh-huh.
      21         Q.   There's something I was going to ask you about,
      22   you might know about this:  Do you know Katie Chamberlain?
      23         A.   Yes.
      24         Q.   She's an AMC employee, right?
      25         A.   Yes.

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      1          Q.   Lisa was working on that ethics program through
      2    AMC?
      3          A.   Uh-huh.
      4          Q.   During -- it was this period right before this car
      5    accident.  Must have been October/November.  And I guess
      6    Katie was handling that program for her.
      7               Were you aware of that, what that was all about?
      8          A.   No.
      9          Q.   Okay. Being an OT-VIII, what does that mean, when
     10    she's handling an ethics program for Lisa?
     11          A.   I don't --
     12          Q.   I mean --
     13          A.   I don't know what it pertains to with AMC, but
     14    there are certain conditions at any time in a person's life
     15    when, you know, they're either doing very, very well or
     16    they're not.  And so if you're not doing as well as you
     17    could, then it's a matter of trying to figure out what it
     18    would take to have you do very well again.
     19          Q.   As I understand, AMC runs their business with the
     20    Hubbard tech in mind. I mean, they implement all his
     21    theories and business programs that he -- he's written,
     22    right?
     23        A. His management program, uh-huh.
     24        Q. Yes, ma'am.
     25        A. Yeah.

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      1          Q.   So this would have been an aspect of that; if she
      2    was having a tough time over there at AMC, then that Hubbard
      3    tech would have been applied from that aspect of the
      4    business?
      5          A.   I would think so, but I don't know how --
      6          Q.   I know you don't know, you don't work there or.
      7    anything.   So you didn't know about that aspect of her --
      8          A.   No.
      9          Q.   -- troubles?
     10               I get this from-- Brenda Hubert wrote a
     11     Knowledge  Report --
     12          A.   Oh.
     13          Q.   -- and some of that was --
     14          A.   Oh, I see.
     15          Q.   -- detailed in there.
     16               The reason why I brought that up is because you
     17    had the conversation with her that night after they got back
     18    from Orlando, which is when she wrote this.
     19          A.   Oh, really?
     20          Q.   Yes.  So some of this information was probably
     21    given to you on that night.
     22               Did she give you information about bizarre
     23    behavior that Lisa was exhibiting in Orlando?
     24          A.   Yes.
     25          Q.   Okay.  Would it be normal for somebody to write

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      1    something like that down?
      2          A.   Yes.
      3          Q.   I mean, within the practice of Scientology
      4          A.   Uh-huh.
      5          Q.   If it gets written down, where does that go?
      6          A.   Well, most people have an ethics folder.
      7          Q.   So if anybody sees any other -- any member of
      8    Scientology can write a Knowledge Report about any other
      9    member of Scientology and that would go to their ethics
     10    folder?
     11          A.   Exactly.
     12          Q.   Okay. And the purpose of that is what?  Who reads
     13    that ultimately?
     14          A.   An Ethics Officer.
     15          Q.   An Ethics Officer does.
     16               Would that be a Minister or would that be somebody
     17    other than a Minister?
     18          A.   It could be somebody other than a Minister.  I
     19    think perhaps that's the position Katie was holding.
     20          Q.   Oh, the Ethics Officer?
     21          A.   Uh-huh, yes.
     22          Q.   At AMC?
     23          A.   Uh-huh.
     24          Q.   I gotcha.
     25               So were you ever made aware, after Lisa began her

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      1    stay at the Cabana, as to her progress?  Was anybody giving
      2    you any updates on that?  Did you ever think to say, hey,
      3    better check up on Lisa and see how she's doing?
      4          A.   No, I did not initiate that, because I felt that
      5    she was in good hands.  And at one point I did see
      6    Mr. Kartuzinski and he said that she was doing well.
      7          Q.   Okay. What point was that, if you can recall?
      8               I know we're asking about stuff that happened two
      9    years ago.  I'm not going to hold you to anything.
     10               Would it have been the weekend of her stay?  A
     11    week, two weeks into it?  Best you can remember.
     12          A.   Oh, I don't know. September maybe.  It wasn't --
     13    I don't think it was real early on.  May have been a month
     14    afterwards, I went --
     15          Q.   No, no, I'm talking about while she was staying at
     16    the Cabana for the two and a half weeks.
     17          A.   No, no, I didn't get any report.
     18          Q.   This conversation didn't take place then?
     19          A.   No.
     20          Q.   You were relating the Kartuzinski conversation
     21    before she went into her --
     22          A.   Yeah.
     23          Q.   We'll call that a spin. Isn't that what it's
     24    called, psychotic break?
     25         A.   It's called something. I don't know.

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      1          Q.   Now, my question is more specific:  During the
      2    period of time that she was staying at the Cabana section of
      3    the hotel, did you have any conversations with anybody as to
      4    her well-being and how she was progressing?
      5          A.   No.
      6          Q.   Okay.  How about Benetta, was she getting reports?
      7          A.   I don't know.
      8          Q.   Okay.  Did you have any conversations with Benetta
      9    in reference to those periods -- those days that she stayed
      10   there?
      11         A.   No.
      12         Q.   Were you ever made aware that she was -- are you
      13   familiar, being an OT-VIII, let me ask you this, are you
      14   familiar with the term "isolation watch"?
      15         A.   I've heard the term, but I don't know by
      16   definition what it entails.
      17         Q.   Okay. Are you familiar with the term
      18   "Introspection Rundown"?
      19         A.   No.
      20         Q.   You've never heard that before?
      21         A.   There are many rundowns, and I know that it's
      22   probably one of them, but I don't know anything about it.
      23         Q.   I've been told from members of Staff that she was
      24   there under an isolation watch, she never got to the
      25   Introspection Rundown.  Apparently you have to be quite

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      1    stable for that particular program to be run.
      2          A.   You know more about it than I do then.
      3          Q.   I'm learning.
      4    But the isolation watch is a practice that you
      5    basically try -- they try to keep that person very calm and
      6    very sedate and very passive.  And they, further, don't
      7    speak to that person.  That person is allowed to talk, of
      8    course, but there's no communication.
      9               Are you familiar with that practice?
     10          A.   No.
     11          Q.   Okay.  So any questions that I might have in
     12    reference to that two-week, two-and-a-half-week period she
     13    stayed at the hotel, you're basically -- after that accident
     14    night that you left her there, that was it for your
     15    information about how she was doing at the Cabana?
     16          A.   Yes.
     17          Q.   Okay. When did you learn that she had passed
     18    away?
     19          A.   One day I -- I had stopped at the -- the
     20    Fort Harrison and -- doing something else. And Benetta
     21    apparently saw me, came to me. Said, I need to tell you
     22    something, okay, and then she told me that Lisa died.
     23          Q.   Okay.  Do you know when in relationship to the
     24    death that was? I mean, was that the day after, the week
     25    after, two weeks after or when was that?

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      1          A.   I don't even know what day she died. Was that a
      2    weekday or weekend?
      3          Q.   I can tell you. It was a -- it was a Tuesday, the
      4    5th of December, in the evening, afternoon/evening.
      5          A.   Well, then I would think that it might have been
      6    the next day.  Because I think that's when Benetta might
      7    have just heard about it, 'cause it looked like from --
      8    'cause her husband then was there too, David.
      9          Q.   At the Church?
     10          A.   Uh-huh.  And I think they must have just heard
     11    about it.
     12          Q.   Okay.  And the reason they were at the Church is
     13    because of what?
     14          A.   I don't know.
     15          Q.   And do you know why you were there?
     16          A.   No, I don't recall why I went there, but it
     17    wasn't --
     18          Q.   You weren't there for the Lisa McPherson thing --
     19          A.   No.
     20          Q.   -- or meeting or --
     21          A.   No.
     22          Q.   Just happened to be there?
     23          A.   Yes.
     24          Q.   What did Benetta tell you?
     25          A.   That she had died. That she had -- something had

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      1    happened suddenly and they rushed her up to, I don't know if
      2    it was New Port Richey or some hospital north of there, and
      3    she died and they didn't know why.
      4          Q.   All right.  Did you act upon that information in
      5    any way or was, that just retained?  Would you do anything on
      6    that?
      7          A.   No, there wasn't anything I could --
      8          Q.   I mean, did you go to the funeral?  Did you talk
      9    to anybody else?
     10          A.   I did go to the funeral.
     11          Q.   Did you talk to the hospital?  Did you talk to any
     12    doctors?
     13          A.   In the course of this occurring, then I felt I
     14    wanted to be very supportive of Benetta too, and Benetta and
     15    Brenda were going to go to the funeral.
     16          Q.   That would have been where?
     17          A.   In Texas.
     18               Because Brenda -- those three girls were very,
     19    very close.  And so -- and they knew Lisa's family.  And so
     20    I asked Benetta if it would be a help to her if I went,
     21    because both of those girls were my patients, and she said
     22    yes, so I went.
     23          Q.   Okay. So who are the people from Clearwater that
     24    went to Dallas that you're aware of?  The three of you.
     25    Anybody else?

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      1          A.   There was also somebody from the Church.
      2    Brian Anderson, I think.
      3          Q.   Uh-huh.
      4          A.   And I think those are the only --
      5          Q.   He was the chief -- he was the head guy for OSA,
      6    right, at the time?
      7          A.   I don't know really what his post is, but he's
      8    from OSA, yes.
      9          Q.   All right.  Are you familiar with Dr. Minkoff?  Do
     10    you know him?
     11          A.   I know him.
     12          Q.   Okay. How do you know him?
     13          A.   I have just met him several times at different
     14    Church functions.
     15          Q.   Okay.  He -- my understanding, he's also an
     16    OT-VIII.  Is there a fraternity of OT-VIII people?  That's a
     17    big thing.  I mean, OT-VIII is a very -high level for the
     18    Church.  Do you know all the other OT-VIlls?
     19          A.    (Witness shakes head negatively.)
     20          Q.   You know what I'm saying.
     21          A.   No, I don't know all the other OT-VIIIs.  Patients
     22    will ask me, do you know blah, blah, blah, and they say
     23    they're an OT-VIII, but I don't know them all.  It's kind of
     24    a personal thing, like the schools today, where you can
     25    learn at your own pace, and that's the thing with this.

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      1          Q.   It's definitely graduate studies?
      2          A.   It's a little higher level, yes.
      3          Q.   Okay.  Did you ever have a conversation with
      4    Dr. Minkoff about his involvement in this case?
      5          A.   No.
      6          Q.   You knew he was -- he was the treating physician,
      7    ultimately?
      8          A.   That's what I heard, yes.
      9          Q.   Actually, he didn't get to treat her, but
     10    pronounced I guess is what he did.
     11               Did you write any reports for this -- for the
     12    Church in reference to your involvement with Lisa Mcpherson?
     13          A.   No.
     14          Q.   Have you had any other conversations with anybody
     15    else with the Church in reference to Lisa McPherson since
     16    this investigation began with the Clearwater
     17    Police Department back in the beginning of `96?
     18          A.   No. Prior to the police wanting to speak with,
     19    me --                                                  -
     20          Q.   You spoke to one of these guys way back when?
     21                    DETECTIVE SERGEANT ANDREWS:  No, Ron Sudler.
     22                    MR. McGARRY:  Sudler did that?
     23                    DETECTIVE SERGEANT ANDREWS:  Yeah.
     24          A.   That's the first that I knew that there was any --
     25  any concern about the whole thing.

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      1          Q.   Right.
      2               How about any other lawyers other than the lawyer
      3    sitting here with you here?
      4          A.   Church's lawyers.
      5          Q.   That would be Sandy Weinberg and Lee Fugate and
      6    Laura Vaughan?
      7          A.   Uh-huh.
      8          Q.   And that would have occurred when?
      9          A.   I don't recall the first time I spoke with Sandy.
     10    I don't know if that was around the time of the
     11    investigation and when the police interviewed me.
     12          Q.   Okay. Are you familiar with an OSA representative
     13    named Jane Jenczh?
     14          A.   Who. -
     15          Q.   Jenczh.
     16          A.   Oh, Hebert Jenczh -- no, I don't think that's him.
     17                   DETECTIVE SERGEANT ANDREWS: No. I think
     18    this is his wife, Jane.
     19          A.   No, I don't know.
     20                   MR. McGARRY:  Okay. We can take a break if
     21:   you'd like.  I don't think we have much more. The
     22    Detectives always pick up questions I neglected to ask.
     23    We can plunge on through and finish up or you're
     24    welcome to take a break.
     25                   THE WITNESS: I'm ready to plunge.

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      1               MR. McGARRY:  Okay. Gentlemen, if you have a
      2    couple of questions, you can wrap it up.
      3                       EXAMINATION
      4    BY DETECTIVE SERGEANT ANDREWS:
      5          Q.   You said you diagnosed the salt and potassium
      6    problem with Lisa, and I missed how you diagnosed that.
      7          A.   It's called muscle testing or applied kinesiology,
      8    where you actually -- are you familiar with that?
      9          Q.   No.  My familiarity would be if you had an
     10    electrolyte problem or some type of problem, you go get a
     11    blood test and the laboratory would tell you you were, you
     12    know, iron deficient, whatever.
     13               You're using a different method to do it.  No
     14    blood test was done on Lisa?
     15          A.   No blood test.
     16          Q.   Is that -- is that a well known procedure?
     17          A.   Yes, applied kinesiology is very well known. It's
     18    called AK for short.
     19               There's another technology in chiropractic called
     20    CRA, which stands for contact reflex analysis, and there was
     21    a reflex point on the body that is very specific for salt
     22    deficiency.
     23          Q.   Did you bring any records for us today?  We issued
     24    subpoenas.
     25          A.   This is her folder. Do you want it?

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      1          Q.   Yeah. We're going to need to get copies of it.
      2               Could we go back over your medical background as
      3    far as training and education?           -
      4          A.   I went to college, Michigan State University,
      5    graduated in `73.
      6          Q.   With?
      7          A.   Degree in -- BA in psychology.
      8          Q.   Psychology?
      9          A.   Uh-huh.
     10          Q.   Strange.
     11          A.   Strange?  Why is that strange?
     12          Q.   Well, knowing the Church's opinion of
     13    psychologists.
     14          A.   I know their opinion of psychiatry.
     15          Q.   Go ahead.
     16          A.   And then I got my degree from chiropractic college
     17    in December of -- December of `79.
     18          Q.   And that was from?
     19          A.   Palmer College in Iowa.
     20          Q.   Okay.  Now, have you had practices since `79?
     21          A.   1980, I think, I started my practice in Michigan.
     22          Q.   1980?
     23          A.   Uh-huh.
     24          Q.   And that was your own company or did you work for
     25    somebody?

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      1          A.   My own.
      2          Q.   Okay. And when did that last, from 1980 till?
      3          A.   Till 1990.
      4          Q.   Okay.  And then in `91 --
      5          A.   Came to Florida.
      6          Q.   -- you came to Clearwater and then applied here?
      7          A.   Well, I already had my -- my license here.
      8          Q.   Oh, okay.  I noticed in your previous statement
      9    you had said that Lisa -- to Lisa that "you screwed up."
     10    Tell me about that.  It's kind of a strange thing for
     11    someone consoling someone, you know what I'm saying.  Almost
     12    Dr.  Lovett's -- your representation of Dr. Lovett's comments
     13    about her taking her clothes off.  But tell me about that
     14    "you screwed up" thing.
     15          A.   I think anybody -- I think people should have
     16    control over their cars, for one thing.  And if they get in
     17    accidents, somebody screwed up.  And so here she was in a
     18    hospital, and then with this information, you know, about
     19    the  possibility of having taken off her clothes, and I
     20    didn't know the sequence of all of that, but I'd say that's
     21    a bad combination.
     22          Q.   Judy Goldsberry-Weber, did you ever see her at the
     23    hospital?
     24          A.   Uh-huh.
     25          Q.   Tell me about that.  When did she show up?  What

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      1    was  the time frame?
      2          A.   It was, I don't know, mid-way.  All I know, I had
      3    spent the whole time there next to Lisa.
      4          Q.   Okay.
      5          A.   And then at one point they asked us to leave
      6    the -- the room so that they could have a personal
      7    interview, Lovett and I think the psychiatric nurse.  And so
      8    I stepped out.  And at that time I saw Judy in the hall.
      9          Q.    Now, that description by other people of that, did
     10    you  go -- could you still hear what was going on?
     11          A.   No.
     12          Q.   Okay.  I noticed you mentioned blue-green algae.
     13    Did you prescribe that for Lisa?
     14          A.   No.
     15          Q.   She was taking that on her own?
     16          A.   Yes.
     17          Q.   Do you prescribe that?
     18          A.   No.
     19          Q.   What was wrong with her back?
     20          A.   She had had a problem earlier in Texas, and I
     21    don't have all the specific details of that, at fifth lumbar
     22    and  sacrum.
     23          Q.   So you were making adjustments on that to make her
     24    feel better?  She was experiencing pain, I guess?
     25          A.   Well, at that time it was just her history. When

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      1    she first came to me it was not what she was complaining
      2    about, it was this dizziness.  But that was -- that was part
      3    of her history, that she had a problem back in Texas with
      4    her back.
      5          Q.   Okay. At the hospital, could you just give me an
      6    estimate of Lisa's hekght and weight?
      7          A.   I'm the worst one at that.
      8               Well, she was taller than I was, so she might have
      9    been five eight.  And she was a little leaner than I for her
     10    height, so maybe 140 pounds.
     11          Q.   I know people have described her as bubbly.
     12          A.   As what?
     13          Q.   Bubbly. You know, a bubbly personality. I know
     14    that changed, according to some of the things that you've
     15    indicated.
     16               How about -- what I'm looking at is, could you
     17    describe her fitness level?  I mean, some people at
     18    five eight, 140 pounds could be, you know, overweight or not
     19    in good shape.  Was she in good shape, you know, according
     20    to what you could tell?
     21          A.   Well, she was lean.  She had her periods of
     22    sometimes she exercised, sometimes she wouldn't.  Sometimes,
     23    like especially in 1995, she seemed leaner to me in '95
     24    because of the -- her loss of appetite.  And I don't know,
     25    she could have even been 130 for her heighth too, because

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      1    she didn't have full hips, she have a very flat tummy.  She
      2    always seemed just lean to me.
      3          Q.   All right.  She wouldn't have weighed 108 pounds
      4    though?
      5          A.   No, she was more than 108.
      6          Q.   Did Lisa pay you for, services?
      7          A.   Yes.
      8          Q.   She would write you checks or --
      9          A.   Yep.
     10          Q.   What is your understanding of the handling of
     11    PTS-III people by the Church?
     12          A.   I don't have an understanding of it.
     13          Q.   Okay.
     14          A.   I've never had any personal experience with it, so
     15    I don't know.
     16          Q.   Okay.  And in your studies up to OT-VIII, that's
     17    not discussed at all or anything?
     18          A.   Well, there is -- there are plenty of books about
     19    it, but it's not -- hasn't anything to do with OT-VIII.
     20          Q.   Okay.  So basically, when Lisa was at the Church,
     21    you weren't sure what was gonna happen?
     22          A.   In terms of being sure, I did not know what was
     23    going to happen, no.
     24          Q.   In April of `95 Lisa talked about suicide. How
     25    did she talk about that?

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      1          A.   We -- that was when I -- and I think it's around
      2    April.  I saw her at this -- at the restaurant at the
      3    Fort Harrison.  She was eating by -- alone. And all that --
      4    that early year she was -- she was just never happy looking.
      5    And she definitely wasn't happy there.
      6               And because she was sitting by herself, I decided
      7    to sit down with her, just to see how she was doing.  During
      8    the course of that time she -- she started talking about
      9    suicide.  And she said, you know, That's something that I've
      10   looked at as a possibility.
      11         Q.   Okay. So she didn't give you any method?
      12         A.   No.
      13         Q.   She just said suicide?
      14         A.   Uh-huh.
      15         Q.   Do you use Hubbard tech and management in your
      16   business?
      17         A.   Yes.
      18         Q.   While you were at the hospital, did you ever hear
      19   Lisa ask to leave the hospital or ask to go to the
      20   Fort Harrison Hotel?
      21         A.   No. I didn't hear her ask any questions --
      22         Q.   Okay.
      23         A.   -- of any sort.
      24         Q.   Maybe you don't know, but did taking her clothes
      25   off have anything to do with her religion?  Did you make

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      1    any -- you know, a comparison to the studies at the Church
      2    as far as her taking her clothes off?
      3          A.   Let me understand your question here.
      4          Q.   I have a little bit -- you know, I've been
      5     studying too a little bit about Scientology, and my
      6     understanding is, if you go Clear, okay -- which is before
      7     you get to OT-VIII, so you must be Clear, right?
      8          A.   Uh-huh.
      9          Q.   There's some idea that your body's not needed,
     10    your clothes are not needed, all operating Theatines don't
     11    need those things.  Does that -- that doesn't --
     12          A.   No, I-- that doesn't make any sense to me. I've
     13    never seen it written pr had any experience with taking your
     14    clothes off in public as a -- is a good thing or a religious
     15    thing.
     16          Q.   But doesn't the religion say -- in fact most of
     17    her friends use this term, that Lisa really didn't die, she
     18    just dropped her body?
     19          A.   I'm sure -- I can understand where people would
     20    say that, yes.          -
     21          Q.   She just dropped her body?
     22          A.   But it doesn't have anything to do with socially
     23    taking your clothes off. That's not consistent with our
     24    religion, no.
     25          Q.  That's not consistent with your religion.

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      1    Were you aware of any pressure on Dr. Lovett to
      2    release her?
      3          A.   No.
      4          Q.   Did you read the form that you signed?
      5          A.   No.
      6          Q.   Okay.  You did not read the form you signed?
      7          A.   No.  He just said, you know, they needed a
      8    witness, I think the nurse said if you could sign here, and
      9    since -- they told Lisa where to sign, told me where to
     10    sign, so I signed it.
     11          Q.   You weren't aware that was a release against
     12    medical advice?
     13          A.   No.
     14               Was it?
     15          Q.   Yes.
     16               Dr.Lovett --
     17          A.   Oh, okay.
     18          Q.   Dr. Lovett -- if you look at the form, it's a
     19    release against medical advice.
     20          A.   Oh.
     21          Q.   And I was wondering, you know, here we have you,
     22    the doctor sitting next to her, and then Dr. Lovett saying
     23    no, I'm not going to release her, she's going to have, to
     24    sign herself out against medical advice, and you go ahead
     25    and you witness that form.

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      1          A.   No, I didn't know that was against medical advice.
      2    I thought it was standard hospital procedure, you need
      3    somebody to sign you out.  My impression of Dr. Lovett is,
      4    he wouldn't let her out if he felt that she shouldn't.
      5          Q.   These protein drinks, cal mag, the vitamins,
      6    velarian root, all of these things, can these things in
      7    themselves add to dehydration?
      8          A.   Not that I know of.
      9          Q.   It's been described by some people that these
     10    thing are concentrated drinks, protein drinks and cal mag,
     11    they're concentrated drinks and that in order for a body to
     12    absorb them, more moisture is needed, so therefore, these
     13    things would add to dehydration.
     14               Does that fit in with your understanding?
     15          A.   No, it does not.
     16          Q.   Okay.  What about prescription drugs?  There were
     17    prescription drugs given to Lisa.  Now, in your practice, as
     18    far as a nutritionist and stuff, do you believe in
     19    prescription drugs?
     20          A.   I believe if they're necessary, absolutely.  If
     21    they need an antibiotic, if they need something like that.
     22          Q.   How about sedatives?
     23          A.   I'm not -- my personal belief is, I'm against
     24    sedatives.
     25          Q.   If you had to use a sedative, would you use

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      1    velarian root or magnesium, I guess it's been described?
      2          A.   Well, I know in nature calcium is considered a
      3    natural tranquilizer, if you're looking at the more natural
      4    form of things.  And velarian root is also something that is
      5    used to help a person sleep, but I don't --
      6          Q.   Do you use that?
      7          A.   No, I don't like velarian root.
      8          Q.   Is there ,a reason you don't like it?
      9          A.   What I find clinically many patients who use it
      10   feel a little drugged by it.  Some people say they swear by
      11   it and think that's the best thing to go to sleep.
      12         Q.   Who paid for your trip to Texas to go to the
      13   funeral?
      14         A.   I think I did. I would have to look at my
      15   records.
      16         Q.   I mean, who else would pay for it?
      17         A.   Benetta could have, I imagine.  But I shared rooms
      18   with Benetta and Brenda, so that -- that was paid for.  But
      19   I think that I paid for my ticket myself.
      20         Q.   Okay. Where did you earn your OT-VIII?  Was that
      21   here in Clearwater?
      22         A.   Yes.
      23         Q.   How did you end up with Bob Johnson as an attorney
      24   in the first interview?
      25         A.   I'm trying to see how that went. Somebody from

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      1    the Church said that that was an attorney that could --
      2    should be present probably for me.
      3          Q.   All right.  So it was not your request for an
      4    attorney, it was the Church's request for an attorney?
      5          A.   I don't know that it even was a request.  They
      6    just thought, well, if you're going to, you know, be sitting
      7    there, perhaps you would want one.
      8          Q.   Little strange?
      9          A.   No, not necessarily.
     10          Q.   I don't see him here today.
     11          A.   No.
     12          Q.   Someone mentioned that you had brought up the word
     13    "treason" as far as Lisa, I guess, going to see this other
     14    doctor or something.  Would that be something you would use,
     15    a word like that?
     16          A.   Yes.  Only again, if you look at this -- this
     17    question brought up about ethics.  We had a normal -- what's
     18    considered a normal condition as patient and doctor.  And
     19    then she was choosing the amounts and the supplements and
     20    that sort of thing that she was taking, and she was going to
     21    this person for advice and that person for advice.  And my
     22    opinion, our relationship as a doctor/patient had changed
     23    and, therefore, there was some betrayal of loyalties, if,--
     24    if you want to put it that way.  And so I felt that because
     25    of that she and I could never -- could not at that point

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      1    have a doctor/patient relationship.
      2          Q.   Were you handling any ethics for Lisa?
      3          A.   No.
      4          Q.   Do you often -- or do you mix religion with your
      5    practice?
      6          A.   Nope.
      7          Q.   So you keep them two separate too?
      8          A.   Yes.
      9          Q.   Have you had any auditing or a Sec Check involving
     10    Lisa's case?
     11               MS. REBACK: I'm going to object to that:
     12    I'm not sure that that question doesn't invade some
     13    religious practices that --
     14               DETECTIVE SERGEANT ANDREWS:  My only
     15    clarification was, I'm not asking specifically about
     16    what they discussed, which would be privileged --
     17               MS. REBACK:  No, you in fact did.
     18               MR. McGARRY:  The answer may be no. Can we
     19    handle that?
     20               MS. REBACK:  No, I don't think so.  I think
     21    the form of your question was, have you had any
     22    auditing or Sec-Check about Lisa or with regards to
     23    that effect.
     24               DETECTIVE SERGEANT ANDREWS: Yeah,
     25    Lisa McPherson, this case.

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      1               MS. REBACK:  Right.  Right.  Which I think
      2    contains within it the content of any auditing she may
      3    have had would be about Lisa.  That would refer to what
      4    it would be about.  And I just don't think -- that's
      5    like suggesting, you know, did you discuss with your
      6    priest about Lisa or something.  And I just don't feel
      7    it's appropriate.  And as to that question, I think
      8    we'll kind of stick with that.
      9               DETECTIVE SERGEANT ANDREWS:  You're going to
     10    object?
     11               MS. REBACK:  I'm objecting to --
     12               MR. McGARRY:  Let's ask this:  Did you have a
     13    Sec Check in reference to Lisa McPherson?
     14               MS. REBACK:  Same objection.
     15               MR. McGARRY:  I'm not asking what was done.
     16    I'm asking if the procedure was done, I'm not asking
     17    what transpired in the conversation.
     18               MS. REBACK:  Let me ask this:  Are you
     19    comfortable answering that question?
     20               THE WITNESS:  Whether I had a Sec Check?
     21               MS. REBACK:  Regarding Lisa McPherson.
     22               Did you have a Sec Check regarding
     23    Lisa McPherson, is that your question?
     24               MR. McGARRY:  Yeah.
     25               THE WITNESS:  No, I wouldn't have a problem

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      1    answering that. No.
      2               DETECTIVE SERGEANT ANDREWS:  Still haven't
      3    answered my auditing question.
      4               MS. REBACK: Do you feel uncomfortable
      5    answering that question?
      6               THE WITNESS: I do.
      7               MS. REBACK: So we're not going to answer it.
      8               DETECTIVE SERGEANT ANDREWS:  So we split
      9    hairs on what's a Sec Check and what's auditing.
      10   BY DETECTIVE SERGEANT ANDREWS:
      11         Q.   Have you discussed your testimony with anybody
      12   other than your attorney?
      13              MS. REBACK:  This testimony? I think she --
      14   I'm sorry, this testimony.
      15              DETECTIVE SERGEANT ANDREWS: Yes, today,
      16   coming here today to testify.
      17         A.   No.
      18         Q.   When you left Lisa at 210 South Fort Harrison
      19   Avenue, did you tell anybody there about her problems?
      20         A.   No. I assumed everyone knew what her problems
      21   were.
      22         Q.   And in your assumption, what were those problems?
      23         A.   What problems were you talking about?
      24         Q.   I'm talking about the salt problem or potassium
      25   problem or things like that.

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      1          A.   No, I didn't tell anyone about that.
      2          Q.   Is there a reason why?
      3          A.   Well, at that time I wasn't acting as a doctor
      4    there.  And at that time she was not my patient.  And at
      5    that time it was how many months from when I last worked
      6    with her, with her salt situation.
      7               DETECTIVE SERGEANT ANDREWS: I think that's
      8    all I have.  Thank you very much.
      9               SPECIAL AGENT STROPE:  I just have a couple.
      10                       EXAMINATION
      11   BY SPECIAL AGENT STROPE:
      12         Q.   Did you write a Knowledge Report on this treason
      13   issue with Lisa?
      14         A.   No.
      15         Q.   Would that be normal procedure for you to do that?
      16         A.   No.
      17         Q.   You said to the prosecutor that the usual practice
      18    is that one Scientologist can write a Knowledge Report on
      19    another for any issue, right?
      20         A.   Uh-huh.
      21         Q.   Is there a parameter for those issues?
      22         A.   No.
      23         Q.   Now, if you have -- if I have a friend of mine who
      24    starts discussing things like suicide, I'm obviously going
      25    to tell somebody.  That's something that you should relay to

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      1    someone.
      2               Would you write a Knowledge Report if another
      3    scientologist were going to commit suicide or thinking abou?
      4    committing suicide?
      5               MS. REBACK:  Do you understand his question?
      6               THE WITNESS:  No.
      7          Q.   Well, we write Knowledge Reports about minuscule
      8    things, that's been the testimony here for six months,
      9    wouldn't you write Knowledge Reports for suicide?
     10               MS. REBACK:  Do you agree with the first part
     11         of his question? --
     12               THE WITNESS:  No, I don't.
     13          Q.   Do you agree Knowledge Reports are written by
     14    Scientologists on other Scientologists on whatever they feel
     15    may be an important issue?'
     16          A.   There's a very -- that's not true.
     17          Q.   No?
     18          A.   There's very specific reasons.
     19          Q.   My question is, a Scientologist can write a
     20    Knowledge Report about another Scientologist?
     21          A.   You can write a Knowledge Report, yes.
     22          Q.   Okay.  Is that true?  That's true, you'll give me
     23    that?
     24          A.   You can write a Knowledge Report, yes.
     25          Q.   About whatever you feel to be an important issue?

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      1          A.   See, I can't quite agree with that.
      2          Q.   Okay. So do you feel that someone discussing the
      3    idea that they may kill themselves, knowing that they have
      4    parents and brothers that did so, is not an important issue
      5    that should have been maybe written up?
      6          A.   If you'll recall from this, I didn't know she had
      7    this history at the time that she spoke to me about suicide.
      8    And no, that's not necessarily something that a
      9    Knowledge Report would be written for.
     10          Q.   So you wouldn't write that up?  You wouldn't
     11    necessarily write that up?
     12          A.   Right.
     13          Q.   Okay. What training do you have in nutrition?  Is
     14    there a part of your medical background that trains you to
     15    say which vitamin does what and which nutrient does what?
     16          A.   We have some in chiropractic college, plus this
     17    CRA, contact reflex analysis, is all about nutrition.
     18          Q.   Is there ever a point in your relationship with a
     19    patient that you send that patient for blood tests to a
     20    medical doctor?
     21          A.   Yes.
     22          Q.   You didn'treach that point with Lisa?
     23          A.   No.
     24          Q.   And you're familiar with blue-green algae?
     25          A.   Uh-huh.

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      1          Q.   Do you have a lot of patients that use that?
      2          A.   I have some that come that use it, yes.
      3          Q.   Is that a Scientology thing?
      4          A.   No.
      5          Q.   I've never heard of it before, so I --
      6          A.   It started in the Clearwater area, not
      7    Scientologists, but as a multi-level and it -- there are
      8    certain waves of nutritional things that hit the market,
      9    like Melatonin is the hottest thing now, but blue-green
      10   algae was the thing some years ago.
      11         Q.   So the manufacture or invention, or whatever you
      12   call them, blue-green algae began in Clearwater?
      13         A.   No.
      14         Q.   I thought you said it began in Clearwater?
      15         A.   No, when it hit Clearwater as a happening thing.
      16         Q.   Oh, I see.
      17                SPECIAL AGENT STROPE: Bear with me here.
      18                THE WITNESS: That's okay.
      19                  (Pause.)
      20   BY SPECIAL AGENT STROPE:
      21         Q.   Did Benetta ever tell you why she didn't go to
      22   Morton Plant;  why she wanted you to go?
      23         A.   I know that when she called she had been -- I
      24   think she was actually working on Winter Wonderland and was
      25   painting something, and she said she was covered with paint.

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      1    I don't recall exactly if she said that David went over
      2    there.  But I know that just talking about different medical
      3    things and blood and stuff like that, that's not her thing.
      4          Q.   Who -- we have testimony indicating there were
      5    probably between six to ten Scientologist personnel at the
      6    hospital.  Do you remember who they are?
      7          A.   Really?  Geez, since I spent most of my time in
      8    with Lisa -- I saw Kartuzinski.  I saw Judy at some point.
      9    David Slaughter.  Then there was another fellow, only when
     10    we were -- when we came out did I see him, and I don't know,
     11    what his name was.  So one, two, three, four.  Four only,
     12    four Scientologists that I know of.
     13          Q.   And Brian Anderson, who's a member of OSA?
     14          A.   Didn't see him.
     15          Q.   He was there.
     16          A.   Oh, was he?
     17          Q.   Yes.
     18               Is that a usual procedure when a Scientologist is
     19    involved in a minor accident, to send all these people to
     20    the hospital?
     21          A.   I don't know what the procedure is over there.
     22          Q.   Doesn't seem kind of peculiar to you?  Was that a
     23    little overkill, maybe?
     24          A.   I don't know anything about --
     25          Q.   Don't know?

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      1          A.   I was wearing the hat of a doctor.
      2          Q.   Did Lisa speak to you?
      3          A.   Uh-huh.
      4          Q.   Did she tell you what she wanted to do, what her
      5    plans were, she wanted to go home, she wanted to go here?
      6          A.    (Witness shakes head negatively.)
      7          Q.   Nothing?
      8          A.   Nothing.
      9          Q.   Did she say, I want to get out of the hospital?
     10          A.    (Witness shakes head negatively.)
     11          Q.   Did she say anything at all?
     12          A.   No.
     13          Q.   I'm jumping around, because I have to take notes
     14    on two conversations, so it's not a smooth train of thought.
     15               Were salts a problem as a result of Florida heat?
     16          A.   I believe so.
     17          Q.   So the more time she spent outside was the more
     18    problem she had.
     19               That was a problem that happens with people that
     20    move from Michigan, right?
     21          A.   And some bodies just don't do as well as other
     22    bodies.
     23          Q.   Were you under the impression that when Lisa was
     24    signed out of the hospital there was an agreement that the
     25    Scientologists would take care of her and see that she had

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      1    proper care?  Did you hear any or all of that agreement?
      2          A.   No.
      3          Q.   What was your opinion of what was going to happen
      4    with Lisa?  Did you know?
      5          A.   No.  I thought she was just going to, you know,
      6    get some rest.
      7          Q.   Was -- was it pre-arranged that there was a room
      8    at the hotel or was that something that was arranged at the
      9    hospital?
     10          A.   I don't know anything about it.
     11          Q.   You don't know anything about it?
     12          A.   No.
     13          Q.   When Benetta told you that Lisa was taken to
     14    Dr. Minkoff in New Port Richey, did she say why she wasn't
     15    taken to Morton Plant --
     16          A.   She didn't tell me.
     17          Q.   -- just a few blocks away?
     18          A.   She didn't tell me she was taken there.
     19          Q.   Were you aware or were you told what Lisa's cause
     20    of death was by anybody?
     21          A.   No.  What I was told is that she didn't know what
     22    it  was.  And that was even the problem when we went to
     23    the -- to Texas, the Coroner or the Medical Examiner hadn't
     24    given the reason yet.
     25          Q.   The day that you were told by Benetta, did she

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      1    tell you what her idea was as far as cause of death?
      2          A.   No.  She said she didn't know what it was.
      3          Q.   She didn't mention diseases or infections or
      4    anything?
      5          A.   There was this -- I don't remember where this came
      6    from, but there was like some -- a virus, I think is what I
      7    was initially told, and I don't even know where I heard that
      8    first.  But it became, I felt, very difficult for the family
      9    because we -- we went to support them and yet we didn't --
     10    hadn't at that time even been told what the cause was.
     11          Q.   Did you talk to Lisa's mother?
     12          A.   Uh-huh.
     13          Q.   Did you?
     14          A.    (The witness nods affirmatively.)
     15          Q.   Were you invited out there by the family, is that
     16   why everybody went out there?
     17          A.   I wasn't invited by the family.
     18          Q.   Did you know Susanne Schnurrenberger?
     19          A.   No.
     20          Q.   Never met her?
     21          A.   Unh-unh.
     22          Q.   Who is she?
     23          Q.   One of the caretakers.
     24          A.   Oh.
     25          Q.   If you didn't meet her, doesn't matter.

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      1               SPECIAL AGENT STROPE: I don't have anything
      2    else.
      3               MR. McGARRY:  Couple of questions and we'll
      4    be done.
      5                         EXAMINATION
      6    BY MR. McGARRY:
      7          Q.   Obviously, you know I'm going to ask you a
      8    question about this phone call here.
      9          A.   And that was --
     10          Q.   Is that a receptionist that wrote that down?
     11          A.   Uh-huh.
     12          Q.   The date of that is July 11th?
     13          A.   It's the 14th.
     14          Q.   14th, excuse me.
     15          A.   Yeah.
     16          Q.   So do you know what that was all about?
     17          A.   Well, if you'll look at my notes from that day,
     18    that was the day that she called me and said that --
     19          Q.   Yeah.
     20          A.   -- she'd been to Jerry, and -- and I was starting
     21    to --
     22          Q.   I gotcha.  That's the 14th.
     23          A.   Yeah.
     24          Q.   This is the last -- last day that you saw her.
     25               But she came in and bought supplements from you

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      1    one other time?
      2          A.   Did she?
      3          Q.   See if that's what that means.
      4          A.   Well, supplements were paid for, doesn't
      5    necessarily mean she came in.
      6          Q.   Oh, okay.  I see.  So this doesn't mean -- this
      7    isn't a contact, necessarily?
      8          A.   No.
      9          Q.   She was getting at least some of her supplements
     10    from you, right?
     11          A.   Right.
     12          Q.   You didn't happen to make a copy of all this
     13    stuff, did you?
     14          A.   I did.
     15          Q.   You did.  Oh, thank you so much.
     16          A.   Do you want the copies?
     17          Q.   That would be nice, yes.  Save me the trouble of
     18    doing all that.
     19               MS. REBACK: In fact, it was my suggestion
     20    that we make copies.
     21               DETECTIVE SERGEANT ANDREWS: Somebody needed
     22    a couple extra points.
     23               MS. REBACK: I just want that on record.
     24               MR. McGARRY: I think that will do it.
     25           (WHEREUPON, THE TAKING OF THE SWORN STATEMENT WAS

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      1     CONCLUDED AT 10:45 A.M.)

      2                         CERTIFICATE OF OATH

      3
      4     STATE OF FLORIDA   )
            COUNTY OF PINELLAS )
      5

      6               I, the undersigned authority, certify that the
            aforesaid deponent personally appeared before me and was
      7     duly sworn.

                      WITNESS my hand and official seal this __2nd__ day
            of  ___October___, 1997.


                               ___________________________________
      11                       RUTH M MARTIN, R.M.R.
                               Notary Public - State of Florida
      12                       Commission No. CC 643284
                               Commission Expires: 4/29/2001
      13

            STATE OF FLORIDA    )
      15    COUNTY OF. PINELLAS )


      16
                      I, RUTH M. MARTIN, Registered Merit Reporter,
      17    certify that I was authorized to and did stenographically
            report the sworn statement of the aforenamed deponent and
      18    that the transcript is a true and complete record of my
            stenographic hotes.
      19              I further certify that I am not a relative,
            employee, attorney, or counsel of any of the parties, nor am
      20    I a.relative or employee of any of the parties' attorney or
            counsel connected with the action, nor am Lfinancially
      21    interested in the action.

      22              DATED this __2nd__  day of   ____October____, 1997.


                                            _______________________
                                            RUTH M MARTIN, RMR


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