IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT

IN AND FOR PINELLAS COUNTY

STATE OF FLORIDA,
Plaintiff,
vs Case No: 99-21857
MMANO-E

ROBERT S. MINTON,
Defendant.

THE COURT: Counsel for Defendant, where do we go from here?

MR. DENIS DE VLAMING: Judge, we are going to rest. We can go through instructions.

THE COURT: That's probably a good thing to do. Okay, so you are going to rest, and you would probably like to do that in the presence of the jury or
not?

MR. DENIS DE 1/LAMING: And we can go right into our closings as far as I am concerned.

THE COURT: That sounds good. Have you all had a chance to review the instructions that I gave you?

MR. TYSON: Yes, Judge, I have them.

THE COURT: That being the case, Mr. de Vlaming, do you want to go first and comment on them?

MR. DENIS DE VLAMING: Yes, Judge, I don't have -- I want to let Ms. Rivellini take a look at this and see if I missed anything. I think the Court
chronicled it correctly, with the exception I don't see any single fact evidence that was introduced about common

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scheme or plan, and therefore we are not requesting it. So are you?

MR. TYSON: No.

MR. DENIS DE VLAMING: No.

THE COURT: Nobody wants it, that certainly makes that it easy. I am going to move a couple of things around in here. Nobody cares too much
about the order I would imagine, but after the battery charge I would do the self -- the lawful use of non-deadly force instruction right there. I'd follow the battery charge with that.

Then, of course, I have taken out the part about the Defendant not testifying, because that clearly is not the case here.

MR. DENIS DE VLAMING: Correct.

THE COURT: What about weighing the evidence? Do you all want all those items in? I circled a few that may be questionable, 6,8,9, and 10.

MR. TYSON: Judge, I would like 6 to be in.

THE COURT: I can understand that. I can understand that. I will leave 6 in.

MR. TYSON: I don't believe that we have an inconsistent statement that we are aware of, 8,9 and 10 are out?

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THE COURT: 8,9, and 10 out?

MR. DENIS DE 1/LAMING: 8 is inconsistent statements, no convictions -- you are right 8, 9, and 10 out.

THE COURT: 8,9, and 10 are out. Okay.

MR. DENIS DE 1/LAMING: Judge, I think Defendant's statements --

THE COURT: I took that out also.

MR. DENIS DE VLAMING: Oh, you did?

THE COURT: Yes, I did. I knew there was something else that I took out and I couldn't find it. But there were no out of court statements that I am aware so I see no need to give that instruction unless, Mr. Tyson, you saw something or heard something we didn't. Anything else?

MR. TYSON: You are taking out the Williams' Rule, correct?

THE COURT: I am, yes, because both of you have asked me to.

MR. DENIS DE VLAMING: Judge, quite obviously the closing argument statement that is what you give in advance of closing arguments, obviously not as a jury instruction at the time you give the rest of them.

THE COURT: You must have an earlier edition. That's not part of mine, and you are right.

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That is absolutely correct.

MR. DENIS DE VLAMING: Judge, I haven't tried a case this Court, do you send the instructions back or not?

THE COURT: I do.

MR. DENIS DE VLAMING: You do.

THE COURT: I am going to have these changed as per what we have just discussed, my judicial assistant is standing by to do that now. I will have
them changed. I will give each of you copies as changed. I will give one copy to go back with the jury when they retire.

MR. DENIS DE VLAMING: Okay, do you have them read it while you read it, or not?

THE COURT: No, I do not. I read it to them. I then explain to them, I then explain to them after I am through that I realize they don't do these things everyday, and that some of these things they want to reflect on. If they would like to do that they will have the opportunity to that, and if they don't feel the need to that, they have to. But they will have them if they want to use them. Okay.

MR. DENIS DE VLAMING: Judge, how do you handle the aspect of the videotapes? Obviously, the equipment --

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THE COURT: That will go back. Tapes will go back.

MR. TYSON: Judge, that one tape, since I don't have the box for it, and since we showed it and stopped it, I believe we ought to leave it in here. If they jury wants to watch they will have to come back and watch it.

MR. DENIS DE VLAMING: Which one is that?

MR. TYSON: That's the one with Frank Oliver with the laser pen.

THE COURT: Is there other things on that tape, is that the concern?

MR. TYSON: Just some picketing, but I would prefer --

THE COURT: How do you all want to handle that, because all the rests of the tapes are going to go back. That one can't go back because of this. I will explain to them that, and if they would feel the need to review that tape they will have to let us know, and we will reconvene in the courtroom and they will get to see that section of the tape.

MR. TYSON: Judge, if you would instruct them, if you would, that there is stuff on that tape that is irrelevant to today?

THE COURT: I will. Does anybody have a

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problem with that procedure? It is awkward, but that is probably the best we can do, unless somebody wants to redact that tape.

MR. DENIS DE VLAMING: So that it doesn't look clumsy from my standpoint, is there are very limited aspects of certain tapes that I would like to play in my final argument, you know literally four or five seconds, I think if I had to try to find them after Mr. Tyson has rewound them it's going to take an inordinate period of time. So I have the identical tapes, you know, last night I went ahead and found the areas so -- is that all right with you?

MR. TYSON: Yes.

THE COURT: Pretty much like you did opening, right?

MR. DENIS DE VLAMING: Yes, sir.

THE COURT: Yes, that's fine. What else do we need to talk about? How much long do we need?

MR. DENIS DE VLAMING: Judge, I am not a big windbag. Forty-five minutes, but I don't intend to take it all.

THE COURT: Forty-five a side?

MR. TYSON: Forty-five.

THE COURT: The State opens and closes, defense is in the middle?

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MR. TYSON: Yes.

THE COURT: Mr. Tyson, what I customarily do is whoever speaks second as they approach the podium let you know by my calculations how much time you have left. If you want me to do that I will. If you would
like me not to --

MR. TYSON: I would ask you to. What I want to do is take ten minutes and
get these changed, let you all kind of get your thoughts together. We will bring the jury in. The defense will rest. I will give them closing argument instruction and we will proceed. Okay. We are adjourned.

(Brief break)

THE COURT: Everybody has seen the verdict form I presume?

MR. DENIS DE VLAMING: Yes, your Honor.

MR. TYSON: Yes.

THE COURT: And no objections to the verdict form?

MR. DENIS DE VLAMING: Right, no objections.

MR. TYSON: No.

THE COURT: Why don't you all take just a second to scan them to make sure that it happened just the way you expected it to happen and then we will bring

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the jury in.

I see that we still have a paragraph on the very last page that shouldn't be there. I will have that eliminated. We can go forward though.

MR. DENIS DE VLAMING: The closing argument?

THE COURT: Yes, I can't seem to get rid of it. Anything else that any saw?

MR. DENIS DE VLAMING: No.

THE COURT: Let's bring in the jury.

(Whereupon, the jury was brought in.)

THE COURT: What says the defense?

MR. DENIS DE VLAMING: Your Honor, the defense rests.

THE COURT: Counsel, approach just briefly.

(Whereupon, a bench conference was held outside the hearing of the jury.)

MR. DENIS DE VLAMING: At this time I renew my motion for directed judgment of acquittal and incorporate the arguments previously made.

THE COURT: My ruling will be the same. Denied, thank you.

Ladies and gentlemen of the jury, both the State and Defendant have now rested their cases. You

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have heard all the evidence you will ever hear in this
case. The attorneys now will present their final or
closing arguments. Please remember that what the
attorneys say is not evidence. They will be commenting
on the testimony that you have heard and the evidence
that's been presented, and they as you, will be recalling
the evidence that has been presented. They will not
intentionally try to mislead you. However, if their
recollection of the evidence differs from what your
recollection is you must follow your own recollection.

Please listen closely to their arguments. They
are intended to aid you in understanding this case. Each
side will have equal time, and we have agreed on forty-
five minutes a side. Counsel for the State is entitled
to divide this time between opening remarks and he may
follow counsel for the Defendant after they are through
speaking. So counsel for the State will speak first, he
will use whatever portion of their forty-five minutes
that they choose to use in their opening remarks, after
which counsel for the Defendant will speak for up to
forty-five minutes, when they sit down counsel for the
State may then return to the podium and use whatever
portion of their forty-five minutes remains.

Okay. Mr. Tyson, are you ready?

MR. TYSON: Good afternoon, ladies and

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gentlemen. Now trial is over except for closing
arguments, there is one thing that you need to go back
there to decide, and that's did Robert S. Minton
intentionally touch or strike Richard W. Howd against his
will on October 31, 1999. That's what you are deciding.

There has been some defense issues raised,
one of them was self-defense. Of course, now we saw on
the video that Mr. Minton told the police that Mr. Howd
walked into the sign. I'm not sure how you want to
square out that with self-defense. And according to Mr.
de Vlaming, Mr. Howd took one for the team. He took one
for the team that night, that's the defense. He wanted
to set him up.

I submit to you Mr. Minton is on a
crusade. He doesn't know where the line is. I think it
is obvious by his testimony. It is a contentious
relationship between the Scientologists and Mr. Minton.
That's not in dispute. Nobody disputes that. They don't
like each other. Just because you don't like each other
doesn't mean that the law doesn't apply. I told you
before the law applies to everyone. It is there to
protect everyone. No one is above the law.

To believe the defense in this case, and
it boils down to this if you really think about it, to
believe the defense you have to believe that a multi-

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millionaire, worldwide banking investor, that's some
heavy-duty stuff, I can't handle that. That's some
heavy-duty stuff. He's a smart guy, no doubt about it.
No doubt about it. A lot of intelligence there. A lot
of intelligence. He has spent millions of dollars of
discretionary income fighting this thing. That's just
his choice and that's fine. That's his right. But you
have got to believe to believe their defense that Mr.
Howd, a man, no disrespect to him, of ordinary
intelligence, outsmarted him. You've got to believe that
to buy their defense.

And not only do you have to believe that,
you've got to also to understand the fact that Mr. Minton
because of these activities, in the past year or two,
you've got to believe that he didn't know any better, to
know something like this would possibly happen. To buy
their defense that is what you have got to believe. That
a multi-millionaire, early retirement, international
investment banker, worldwide traveler was outsmarted on
the street corner in Clearwater by Mr. Howd.

According to Mr. Minton he doesn't like
the way they think, they don't know any better. That was
a comment on Mr. Howd's intelligence that he doesn't know
any better, to belong to them, and be a slave to them,
that's what his statements were.

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Mr. Howd took one for the team and
outsmarted Mr. Minton. That's what you have got to
believe. That's a huge hurdle in this case. That's a
gigantic mountain to jump. You will be asked to weigh
the credibility of the evidence and the witnesses. Mr.
Minton, you saw him testify. I saw your faces when he
played the Boston video. I have seen that a plenty of
times. I don't have to see that anymore. I looked at
everyone of your faces, and everyone of you was disgusted
at the Scientologists when you saw that video.
Rightfully so. Rightfully so. Then you learned what Mr.
Minton's activities were. It changed things a little
bit. I was watching your faces too when you learned what
else happened that you didn't see on that video.

His actions were bad also. That's not
what we're here for. Okay. Mr. Howd wasn't in Boston
two years ago, 1,500 miles away. He wasn't there. Okay.
Mr. Howd was not there. Those two ladies, who according
to Stacy Brooks, "Is that the best you can do?" Are
saying "Go home. Go home." That video has one purpose
only, to inflame you against Scientology. I want you to
understand something. I don't represent Scientology, I
know nothing about Scientology, and I don't need to know
anything about Scientology.

I don't need to know anything about them.

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I don't care. It doesn't matter. It doesn't matter at
all. This is a contentious relationship. But you don't
need to see what they stand for, you can see with your
own two eyes what is on those videos because that is what
we are here for. Okay. If they are provoking each other
elsewhere that's fine. I don't care. But this is
Pinellas County. This is Pinellas County and they are
both going to abide the law. And on that night Mr.
Minton broke the law.

Another day, another time we may prosecute
them. And you better believe we will. You better believe
we will. Another day, another time. Today it is that
incident. And on that date, you know they were
following, but now I think you know why. Now you now why,
why would they do that? Why would this organization,
this cult, as they call it, follow these people, get all
of these documents on him? They think he is a danger,
they think he is a threat. Quite honestly hearing his
statements up here, you've got to admit it sounds like he
has gone over the edge now. There is a difference
between believe your cause and throwing everything to the
side because of your cause. There's a difference, a huge
difference. You got to see it. You got to see him go to
a church member's house that night. Now what purpose is
that for? The church isn't there. What is the purpose

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of that? Provocation, that's what it is for. The same
thing that he is accusing them of. Provocation. Why
when he is walking around the side of the building, he is
telling them to run and go hide like cockroaches, why is
he doing that, provocation.

Look at the videos. How did they provoke
this man that night? Richard Howd is close with the
video. I already told you, that's not a problem, he is
close. I admit that. You will see it on the tapes. The
women, the man with his hands in his pockets, does that
look like a bunch of goons set out to rough Mr. Minton
up? I don't think so. Mr. Minton is a competent man.
Mr. Minton is a successful man. Mr. Minton goes there.
He is not in fear. You watch those videos. He is in no
fear whatsoever, none.

He provokes them when he is there. He
walks around the side of the building, in the dark. Tell
me what kind of protest that is? Why is he doing that?
Watch the video, he was going around the side of the
building, no one else is there, that's when he grabs at
Mr. Howd's camera strap. Provocation. If he is so
scared of them why is he going around the side of the
building. He says I was thinking about leaving at the
time. Believe that if you want to. If you want to buy
that, buy that. I was thinking about leaving at the time

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I walked around the side the building.

Mr. Minton and defense team go over the
facts. It's a contentious relationship, how they sue
people to silence them. He hasn't been sued. Nobody is
suing him. Yet he has financed -- I am sorry, he has
given money to a family to continue a lawsuit, which he
has no interest in. He has no legal interest in that
lawsuit, other than it is against Scientologists. You
can consider that when you consider of the parties here.
Motive. He is there to stir them up. No doubt about it.

It's hard to argue self-defense when
you're the one there picking the fight. It's hard to
argue self-defense when you are the one there picking the
fight. Mr. Minton even admitted on cross examination
that he did not have to hit him. He did not have to hit
him. When he hit him with that video rolling right up to
his eye, how was Richard Howd a threat to Robert Minton
at that time?

The judge is going to read you a jury
instruction on self-defense. I want you to think about
that. He had to reach out to hit him with the sign. He
didn't hit with his hand. He had to use an extension of
the sign to get him. The Defendant, Robert S. Minton,
must have reasonably believed that such conduct was
necessary to defend himself against the eminent, eminent

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use of unlawful force against himself. The eminent use
of unlawful force. That's quite a stretch to buy that,
isn't it? I man with a video camera up to your face and
you have to reach out with a sign to hit him.

Remember Mr. Minton came to them. We have
heard all this evidence about "Fair Game" and dirty
tricks. Realize they follow him when he is in town
because, as you now know, he is going to their houses
looking for trouble. Makes sense doesn't it? He is
doing the same thing. He is with the people shining
laser lights in everybody's eyes. I am not going to go
into the obscenities that were called, because it is not
necessary anymore. You all heard them. Okay. I have
already been through that. I'm not going to do that
anymore. There's no sense in it. But you know what he
is doing. He is accusing them of doing that to them.
Find me not guilty because look what they are doing.

If you want to hate them for what they did
before. It doesn't matter. What matters is that night.
Regardless of how contentious that relationship may be
for the past two or three years, that night Mr. Minton
crossed the line. I think when he took the stand you saw
what his attitude really is about all of this. They
don't think the right way. He doesn't agree with their
religion, they don't think the right way. He is there to

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change them.

Is anybody trying to silence Mr. Minton?
I don't care if he goes out there tonight. He can't get
his sign back, it's already in evidence, but he can make
another one. He can go out there tonight. I don't care.
You have already heard about the injunction. He can't
come within ten feet of the buildings. He can still
picket. He is not enjoined from going out there and
picketing, he can go all he wants, but his right to
picket doesn't trump their right to practice their
religion, which means you can't start messing with them.
That's exactly what he did on October 31st.

What was his message that night. And if
you think about it, think about, when you talk about
suppressing free speech, think about that for a minute,
all that does is stir the undercurrent. There is an
undercurrent of hate. Wouldn't you rather have Mr.
Minton on the street protesting after you heard his
message in here? You hear his message in here and you
discard it. You understand that it is bigotry. It is
well known what his message is. Everybody can take him
for what he is and what you saw. No, I don't want to
shut him up. No, no. I want him out there tonight. I
want him out there every night, and every night after
that, and every night after that so people can listen to

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him and judge for themselves what they think of him, and
what they think of what his team is doing. Because in
this country you can stand for whatever you want. You
can practice whatever religion you want.

He has the right to protest, but the one
thing that he doesn't have the right to do is break the
law. And that's exactly what happened on October 31st.
Manage to keep your eye on the ball. You have got to
keep your eye on the ball. If you are at a ballgame you
have got to figure what is happening in the game is where
is the ball at. Keep your eye on the ball on October
31st. This is what happened. Thank you.

MR. DENIS DE VLAMING: If it please the
Court, Mr. Tyson. It looks like we are going to be
ending a bit earlier than what the possibility of a
Wednesday end. This is my opportunity to give a closing
statement to you about the facts of this case, which you
learned, and also put together the what the law is that
establishes the defense.

As I told you in the opening statement,
the State is going to have to prove -- before you can
find the Defendant guilty of Battery the State must prove
the following element beyond a reasonable doubt, it's
part of the jury instructions that you will have an
opportunity to take back with you. That Robert S. Minton

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did intentionally struck Mr. Richard W. Howd against his
will. Now, does that always mean that if somebody says I
didn't want him to touch me, that a crime always occurs?
It's funny how we bring our experiences into a courtroom.
And those of who are parents know that when kids are
growing up, you have little kids, and one is heckling the
living daylights out of the other kid, poking on him,
getting in their face, calling them names until finally
that one child, who wants nothing to do with the other,
pushes the kid. The little kid that falls down on the
living room floor goes running to his mother and says,
"Mommy, mommy, he hit me." And the mother said, "You
know, I heard the whole thing. You want to know
something, (son or daughter), you deserved it. I saw the
way you treated your sister, your brother, and guess
what, I would have done the same thing to you. I would
have pushed you and put you right down on your fanny."
Which is exactly what Mr. Minton did. He had it. He had
it. He had it in Boston, he had it from the Office of
Special Affairs. He knew the way they operated.

He knew very well what was going to come
up. He knew that he was being provoked. Mr. Howd, did
you Mr. Howd set this up and practice it, knowing this
was what you were going to provoke. No, I didn't. Mr.
Howd, are you wearing glasses? Yes, I am. Mr. Howd, we

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can see on these videotapes you weren't wearing those
glasses when you were videotaping. I don't wear glasses
when -- I have two video cameras, Mr. de 1/laming, and one
has an eyepiece, which this one did, I don't usually wear
my glasses. I wear my glasses when I use the other
videotape, which has the little screen that would cause
someone to need the glasses. Are you sure, Mr. Howd?
Yes, I'm sure. Because you see, Mr. Howd, if you would
have put those glasses where they were it would have been
obvious what he was trying to provoke.

Mr. Howd, from seeing him in this
courtroom needed those glasses. Nobody wants to get hit
with glasses. This is Mr. Howd in Ybor City.

(Whereupon, the video was played for the jury.)
MR. DENIS DE VLAMING: There he is. There he is.
Eyepiece on the camera, that's the digital camera.
We are going to talk about the digital camera in a minute. That's him videotaping, glasses and all, because there is no program. There is no practice. There was no intent to throw him into a confrontation.
He can wear the glasses and not clip them in the shirt
the way he did. This is the one that Mr. Minton said
that Mr. Howd was filming. There is Mr. Minton, Howd
following him Ybor City, Howd following him to the

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Belleview Biltmore, Howd waiting for him.

Don't think for one minute, ladies and
gentlemen, that Howd didn't encourage this conduct. And
yes, he did take one, just like the basketball player
takes one for the cause. Just like Mr. Oliver said, you
get credit when you can carry something else like this.
What else tells us the whole thing was a setup? What
other evidence shows us that he knew it was practiced so
well. Do you remember what those women said, they never
answered one question, the Office of Special Affairs
women, do you remember that? "Go home, Bob. Go home,
Bob." Over and over, almost robotic.

That's all they were allowed say, and
according to Mr. Oliver that's exactly the way it was
programmed and practiced. Do you remember when Mr. Minton
asked them questions, Why don't you tell us about -- "Go
home, Bob." They never ever ever answered any questions.

How orchestrated is it? Let me show you how orchestrated it was. And this will all make sense to you.

This is re-wound just to a particular
area. This is Stacy Brooks' video, and I have rewound it
the area where you are going to see all the members of
the Office of Special Affairs just before Howd rounded
that corner. Watch what they do just before he rounds

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that corner. I am going to play another segment to you.
Watch where they go, and then we will show how they come
back. I am going to show you just five or six seconds.

(Whereupon, the video was played for the jury.)

MR. DENIS DE VLAMING: They didn't hear
that. Now, it's time to call the police. So they are
not going in because of that. They are leaving, look at
how they are leaving, the three of them, you see the man
and the two women.

This is just before Howd walks around that
corner. I ask you to use your common sense. Was there a
signal, was there a sign? Why did three of them at that
very time decide to this.

Now, here is that stationary video. Watch
what happens after he gets hit. Watch where these same
three people come out all together, as if they were in
just a little cubby hole, having practiced that. Watch
this.

(Whereupon, the video was played for the jury.)

MR. DENIS DE VLAMING: Watch. This has
got sound. Do you hear anything, no. Now watch this.
The same three people. The same three people come out at
the identical time after having gone back in that

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building and run down there and stand over him. Not one
of them say how are you doing. Not one of them said a
word. What they wanted to say was congratulations.

Now, Howd hits the ground. Look. Before
I show you, let me. tell you the significance of this.
Howd hits the ground. I used a basketball analogy
before. There is a great football one, anybody who
watches football, and the kicker that kicks the punts,
what he would love nothing more is to have the other team
and interfere with his kicking. And sometimes you see
these people, they kick, they fall to the ground, they
grab their knee. When you look at the replay the guy
wasn't anywhere near them, because he would love to have
that foul, so he can take it over again. That's exactly
what he did in that case. He wanted to dramatize it as
much as possible. But watch what happens. He knows that
Crock, now that is the other Scientologist, was standing
over him. He knew it. Watch what he does with his eye.
Watch what he does with his eye as he pretends to be out
cold.

(Whereupon, the video was played for the
jury.)

MR. DENIS DE VLAMING: Opens it, takes a
look at Crock, shuts it, and I could let it go on for
awhile because he doesn't -- he said on the stand that he

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left it open, now all of the sudden it is closed. Opens
up takes a look at him, eyes closed. At some point an
officer says do you got any ID? And with his eyes closed
as if he is unconscious he reaches in his left pocket.
Look at him, out cold. Need an ambulance. Boston needed
an ambulance too for the balsa wood.

Now, why, why was it that those other
members of the Office of Special Affairs decided to go
back into the Church of Scientology when they did? Did
they get a signal, get a sign? Did they get something?
Something caused them all to leave, because something was
going to happen around that corner. Howd was going to do
something at that time.

What I want you to look at next, and I
want you to pay attention is when Mr. Minton turns around
says, How would you like me to grab this, or something
like that, and he has it in his thumb. He turns around
to continue to walk. Listen to what he says.

(Whereupon, the video was played for the jury.)
MR. DENIS DE VLAMING: Did you hear that?
Oh, you think so. Right after that, you are attacking
me. What caused Minton to say, Oh, you think so? He has
already turned around. He said, Oh, you think so? I
think this is a fair comment from the evidence, when

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Officer Beaudette was the following questions, he was
asked about the videotapes, they were all given to him,
except one. Was Mr. Howd's videotape handed over to you
immediately, as was Mr. Minton's, they couldn't seem to
find it. How long did it take to find it? A
considerable amount of time. The only videotape running
was Howd's around that corner. The only one that could
have picked up what caused this man to say, Oh, you think
so, was Mr. Howd's. Not orchestrated, not encouraged,
not expected, not wanted, oh, no.

Mr. Tyson said that he is such a smart man
and he is intelligent and he made a good living, all
those things are true. But you want to know what else he
is? He is a human being. He is a human being like the
rest of us that if we are pushed to the limit, that if we
are harassed, that if things are said to us to provoke us
then he is going to act like a human being, regardless of
what he does in life.

Mr. Tyson obviously had listened to the
entire Boston tape because he cross examined Mr. Minton
about the foul language on it. He could have played that
tape if he wanted to play that tape, and frankly, so
could have I played that whole tape if necessary, but we
chose not to do that. Again, if he thought it was
necessary, he certainly could have done it. Do you

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really need to hear the profanity that Mr. Minton might
have said to make a decision in this case. Did you
really need to hear a minister, a minister of the church
say to him, are you f'ing your twelve year old daughter.
He brought it up. Okay, fine that is what was said. And
we didn't want to play that for you.

There was no need to play that for you.
How shocking it is. Even more shocking than someone who
claims to be a minister of the church to be acting that
way. To kill psychiatric funding, one minister said,
because they are against the use of psychiatry in the
Church of Scientology. Who in the world could condone
the conduct of that man, that other minister in Boston
that was in this man's face. He showed the perseverance
of Job not have done something to get in his face.

The reason that we played that for you is
so that you realized that that's what he can expect the
Office of Special Affairs to act like. That's what he is
in for. They want to make it as miserable as they can.
And they want to get one thing. They have got to get one
thing, and they need you to do it. Remember what the
edict of the Church of Scientology is, you've got to make
your critics a criminal. You've got to make them a
criminal.

What happened in Boston, that guy that got

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hit with a balsa stick, that did nothing to him, called
an ambulance to come out. Asked the police to arrest him
and prosecute him. Of course, the prosecutor took a look
at the tape and we know what happened with that case, but
they were trying to get him declared a criminal so that
they can get the word out, don't listen to him.
Everything he says about our organization is false
because he is a criminal. That's what they want you to
do.

Everyone has space. Everyone has an
opportunity to say, back off, leave me alone, get away
from me. I ask rhetorically, how far does a woman have
to go who was followed by another man who finally decides
to leave an area and as she says, leave me alone, I'm
going to call the police, the man follows, she reaches
into her purse, puts her finger on the mace. Does the
man have to come into contact with him for use to use
self-defense? Does he have to grab the woman by the
throat or by the hair? Or can she say, that's enough and
let him have it.

That's exactly the type of situation that
we had. He was pushed, he was pushed, he was setup, and
they got what they wanted. Do you want to know
something? He got what he deserved, just like those
little six year olds that argue in their parents' house.

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They got what they deserved.

How much evidence is necessary to convict
a citizen on a criminal charge? And make no mistake
about this is a criminal trial. This isn't a lawsuit
about money or about staying away, or an injunction.
This is a criminal trial. The decision here is whether
he is convicted of a crime.

That's what this case is about, and that's
what they want. It's a conviction, a unanimous conviction
for a crime. Before you can get to that, the Defendant
has entered a plea of not guilty. This means you must
presume or believe the Defendant is innocent. The
presumption stays with the Defendant as to each material
allegation as to each material allegation in the charge
through each stage of the trial, unless it has been
overcome by the evidence to the exclusion of, and beyond
all reasonable doubt. In other words there can't be any
reasonable doubt whatsoever that he didn't act in self-
defense. There can't be any doubt, any reasonable doubt
whatsoever that Mr. Howd didn't invite the conduct.

We didn't introduce Boston to trash
Scientology, both of the witnesses we called to the
stand, as much as he cross examined them about
Scientology and about the people that are members of that
church, if it is a church, have said I have said I have

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no quarrel with its members. I have a quarrel with its
practices, its deceptive practices. Because the majority
of the people in that organization don't know what is
going on, and that is what he is here to do.

You know, ladies and gentlemen, in the
1930's there was something incredibly insidious that was
happening in another part of our world. It was just
beginning and it came as perhaps the biggest black eye
that this world has ever known, and I don't know the
author of this statement, and I don't know if I have it
completely correct, but after Nazi Germany was exposed,
he made the comment, "First they came for the trade
unions, and I did not stand up because I was not a trade
unionist. Then they came for the Protestants, and I did
not stand up because I was not a Protestant. Then they
came for the Jews, and I did not stand up because I was
not Jewish. Then they came for me, and there was no one
left to stand up." This case is not about Scientology.
I am not here to put a boutonniere in this man's lapel.

All he wanted to do when he came to this
town was to be let alone, to conduct his constitutional
right to protest, walk up and down that street, do so
without people in his face invading his face, following
him from an airport, going to the place where he is
staying. How can anybody say that wouldn't bring some

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fear to you. How can somebody say that if somebody
follows your children or your family that that would not
bring some fear to you. You can keep the stiff upper
lip, and say I am going to continue on, but in the back
of your mind always you are asking yourself is it worth
it, is it worth it.

All the money he has spent and the time,
and exposure to his family, is it worth it. And he has
said the word, yes, it is. He knows how this
organization works, and hopefully this was a very brief
trial, you got a glimpse of that from a man who left that
organization. Sure he made a promise that he wouldn't
divulge this information. But the necessity to divulge
it was more important than the promise he made, he
conceded. He told about "Fair Game" that you can lie,
you can cheat, you so all the things in order to destroy
another person, if they are a suppressive person, someone
who speaks out against Scientology.

Here is the number one suppressive person
to the church. He is the number one person they want to
get. He is the number one person they need you to
convict. Don't let them do it. Don't let them do it.
Richard Howd invited this conduct, and for that reason
alone you should find him not guilty. Richard Howd's
conduct, if taken in the light of Boston and the rest of

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the stalking of this man and his family, shows that he
acted in self-defense. Listen to one aspect of the self-
defense instruction. If you find that victim had a
reputation of being violent and dangerous, now you could
easily say that the victim in this case is Richard Howd,
alleged victim is Richard Howd. But don't forget the
reason that we brought in Boston too was to show what his
state of mind was. The people from OSA, what reputation
did they have for this conduct. If you find that the
victim had reputation of being violent and dangerous
person, and that his reputation was known to the
Defendant, certainly the practices of OSA was known to
him. He knew how far they would go. He knew how far
they had already gone with his family. You may consider
this fact in determining whether the actions of the
Defendant were those of a reasonable person in dealing
with an individual with that reputation.

So for either one of those reasons this
man should be found not guilty. In closing I will tell
you that for two centuries we have agreed to a
constitution and to live by the law. And not any one of
us has the right to violate rules we all share. Perhaps
the greatest constitutional guarantee this country has is
the right of protest, the right to be heard. The first
amendment that was ever drafted by our forefathers was

194

that right, that constitutional right. No one has the
right to violate those rules of our constitution. Not
even Richard Howd.

THE COURT: Mr. Tyson, you have thirty
minutes of your time remaining.

MR. TYSON: It won't take that long.
According to that first amendment is the right to
practice religion, freedom of religion. Kids pushing
kids, he is fifty-four years old. Some of you have kids,
on a long car trip in the backseat fighting. He is
fifty-four years old. This isn't kids pushing kids. The
women never answered Mr. Minton.

So, does that mean that they are robots,
or trained to not answer. What if somebody is saying
something to you that you don't like. According to Mr.
Oliver I guess I am Scientologist. Let's talk about
those ladies who were there, and the guy with his hands
in pockets. There are two middle-aged women, you've got
a guy very docile with his hands in his pockets. When do
they walk away. They are telling Minton to go home, but
when do they walk away? They walk away when Mr. Minton
became physical.

Now, to them that is a conspiracy brewing.
Use your common sense. When is the time to leave? To
walk away, is that unusual? No, that's a conspiracy.

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That plays right into everything they are doing. Could
it be that they were afraid of Minton? He showed no fear
that night. You can see it. I think it is obvious they
weren't afraid of him when he first showed up, but that
changed.

And when they're inside, is it natural
when you are inside to seek protection, and to keep an
eye outside to see what is happening, or was that a
conspiracy. You have to got understand something, to buy
that theory also, besides having to buy the international
investment banker was duped by Mr. Howd, to buy that you
have to understand or buy the fact that those women were
clairvoyant. That they knew that Mr. Minton was going to
hit him. When Mr. Minton hit him, we all know that he is
a distance away. He had to use the sign to hit him.
Does that make any sense?

It gets to the point that some people
start seeing a conspiracy in everything. Everything is a
conspiracy. He is so ingrained in this, so focused they
start looking at the world through a straw. That's all
they see. They don't get the big picture. Everything is
a conspiracy.

Let me ask you a question, tell me the
right way to fall down on your head. Have you stubbed
your toe, I mean really wacked it good, your wife wacked

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it, your kids? You jump around. They don't like the way
he fell. Okay, there is nothing I can do about that.
Minton grabbing the strap, the point I made on cross
examination, Mr. Minton, who took the first offensive act
that night? Regardless of going to a parishioner's
house, regardless of calling them cockroaches, regardless
of calling them all that other stuff, who first took the
first offensive physical action. They are denying that,
they can't deny that. They cannot deny it. It was him.
Of course, now we have got a little twist in this game.
We saw the videos, there's a lot of people out there, a
lot of people with cameras. So it took the police awhile
to get Mr. Howd's camera. Well, if you look there's a
woman holding it. She didn't know how to turn it off.
Yeah, they are supposed to have gone in there, and you
know, they are hinting to you that that video was
changed. It's accurate, it's accurate for their
purposes, when they say look how close Mr. Howd is to Mr.
Minton's face.

But they are hinting to you that it has
been changed when Mr. Minton is grabbing the strap, very
subtly Mr. de Vlaming did it, very subtle during the
trial. He said we will talk about that later. Very,
very subtle. Very, very subtle.

The one thing about in the court, did you

197

bring evidence in? Look at it all, it's all sitting up
there. Is there any evidence, any evidence, other than a
hint from the defense that that video was doctored? Ask
yourselves that questions, because that is what he wants
you to go back there and talk about.

Mr. de Vlaming is talking about that
Boston tape, there is no reason to play that tape. What
did you learn by that tape? They hate each other. Why
did they play it? I submit to you that they wanted to
inflame you. You don't need those tapes. Watch them if
you want. Watch it if you want, there's more, it doesn't
matter. We all know now that Mr. Minton was saying it.
And we know on his copy that it is not only edited, but
is narrated for whatever reason. I am not sure that it
is going to be published or what, it is narrated,
professionally done. I don't know what the reason for
that is, but the things that Mr. Minton was saying aren't
on there. Like I said, I am not going to go into what he
said. I've done beat a dead horse in cross examination,
you don't need to hear it anymore. That's not on there.

It was brought up again to inflame you.
You don't need to play anymore of those tapes, you have
heard enough. You were inflamed enough until you heard
what the other side was doing. If you think about it,
it's different people, different date, time, different

198

place. Remember I told you about keeping your eye on the
ball? You are in the stands watching the game, Mr. de
Vlaming said, hey, look back here. You have done missed
the play. You done missed the play. That's what they
are doing. That's exactly what they are doing. Take
their eye off the ball and shift the focus.

Scientologists don't need to make Minton a
criminal, he did himself. He is only charged with a
misdemeanor battery, that's all this is. This is a
misdemeanor. This thing has mushroomed in huge
proportions, but it is a misdemeanor battery. The State
of Florida is prosecuting him, not Scientologists. The
State of Florida is not being duped with this Mission
Impossible scenario that he defense has come up with. I
am not being duped. Yes, they gave us things to look at.
Do you think that is the only thing we knew about Mr.
Minton? Do you think the only thing we go with is what
they gave us?

This stuff has been going on for a long
time, very contentious. A woman being followed by a man,
now that's supposed to inflame you, too. You have to
understand Mr. Minton and Mr. Howd, Mr. Minton, and the
Scientologists always very close in the videos. You saw
the other ones, with the laser lights, they are all
walking around. That is the way that game is played.

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But a woman being followed by a man. That's meant to
inflame you. That's what it is meant for. It is not an
accurate analogy. That's why that was used, exactly why
that was used. They all know each other videotapes.
You've seen they were videotaping each other back and
forth.

Mr. de Vlaming said that both his witness,
Mr. Minton and Mr. Oliver have no quarrel with the
Scientologists, then why the name calling? Why the laser
in the face? Why are they doing that? If according to
Mr. Minton they don't any better, they don't know they
are slaves, why mess with them? Why mess with those
people?

Mr. Oliver, you can judge his credibility,
he was out there playing games, too. You saw him with
the laser light. He didn't really remember that, but
yeah, that was him with the little laser pen right in
somebody's eye. He doesn't think that is a provocative
thing to do. Right in somebody's eye, putting that laser
dot right there.

You can consider that when you judge Mr.
Oliver's credibility. Does Mr. Oliver have a grudge
against Scientology, oh, yeah. Does he have a grudge
against them, yeah. Should he, I don't know. That was
eight years ago.

200

Whether you believe Scientology is a
religion or not, it doesn't matter. They tried to put it
on trial. And a religion is something that is very very
easy to put on trial. If I was to tell you that there is
a man who agrees to take vow of celibacy, and a vow of
poverty, a vow of celibacy and a vow of poverty for the
rest of his life, I could make him look pretty silly,
couldn't I? We all know that's a Catholic Priest, don't
we. I am not trying to equate any religion together. I
am not trying to be sanctimonious. It doesn't matter.
The people who believe that, have a right to believe
that, whether you agree with it or not.

People that believe in Judaism have a
right to believe in that. People that believe in
Scientology have a right to believe in it. Mr. Minton
has a right to get the word out, but he doesn't have a
right to break the law.

What I want you do to is go back there and
talk about it. You already know the contentious nature
between the parties, but look at what happened that
night. Who is provoking who? Who is telling him to go
home? Mr. Howd wants him to go home. These people want
to go in for the night. It's 10:30 on Sunday night. Who

was provoking who?
Mr. de Vlaming would like to substitute

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the conduct of the gentleman in Boston for Mr. Howd.
That's what he wants you to do. He has asked you to do
that. Because a member there, 1,500 miles away, how that
guy acted, and it was offensive, and Mr. Minton's actions
were offensive. They are both offensive. You can't
justify what either one them did that on that tape.
Nobody can justify it. I hope both parties are ashamed
of it. Both parties should be ashamed of it.

Mr. Howd has to be painted like that, when
you consider the reputation. That is what he is asking
you to do. Like I told you before, Mr. Minton went there
for one purpose, he had already picketed during the day,
you want people around so they can hear his message. He
can go out there, like I said, tonight, and the next
night, and the next night, and I don't care if I go right
down to Clearwater ten years from now, if he is out there
doing it again, there is nothing wrong with that. There
is nothing wrong with that. You go out there and do what
you have got to do, everyday, and the State will protect
you. The State will protect him, much like the State
protects Mr. Howd.

On that day he committed a crime. Thank you.

THE COURT: Members of the jury, I thank
you for your attention during this trial. Please pay

202

attention to the instructions that I am about to give you.

The Defendant in the case has been accused
of the crime of Battery. Before you can find the
Defendant guilty of Battery the State must prove the
following element beyond a reasonable doubt.

Robert S. Minton intentionally touched or
struck Richard W. Howd against his will.

At issue in this case is whether the
Defendant acted in self-defense. It is defense to the
offense with which the Defendant is charged if the injury
to the victim resulted from the justifiable use of force
not likely to cause death or great bodily harm.

The Defendant would be justified in using
force not likely to cause death or great bodily harm
against the victim if the following two facts are proved:

One, the Defendant must have
reasonable believed that such conduct was necessary to
defend himself against the victim's imminent use of
unlawful force against the Defendant.

Two, the use of unlawful force by the
victim must have appeared to the Defendant ready to take
place.

In deciding whether the Defendant was
justified in the use of force not likely to cause death

203

or great bodily harm, you must judge him by the
circumstances by which he was surrounded at the time the
force was used. The danger facing the Defendant need not
have been actual, however, to justify the use of force
not likely to cause death or great bodily harm, the
appearance of danger must have been so real that a
reasonably cautious and prudent person under the same
circumstances would have believed that the danger could
have been avoided only through the use of that force.
Based on appearances the Defendant must have actually
believed that the danger was real.

If you find that the victim had a
reputation of being a violent and dangerous person and
that his reputation was known to the Defendant you may
consider this fact in determining whether the actions of
the Defendant were those of a reasonable person in
dealing with an individual of that reputation.

In considering the issue of self-defense,
you may take into account the relative physical abilities
and capacities of the Defendant and the victim.

If in your consideration of the issue of
self-defense if you have a reasonable doubt on the
questions of whether or not the Defendant was justified
in the use of force not likely to cause death or great
bodily harm, you should find the Defendant not guilty.

204

However, if from the evidence you are
convinced that the Defendant was not justified in the use
of force not likely to cause death or great bodily harm,
then you should find him guilty if the all the elements
of the charge are proved.

The Defendant has entered a plea of not
guilty. This means you must presume or believe the
Defendant innocent. The presumption stays with the
Defendant as to each material allegation in the
information through each state of the trial unless it has
been overcome by the evidence to the exclusion of and
beyond a reasonable doubt.

To overcome the Defendant's presumption of
innosense the State has the burden of proving the
following: The crime with which the Defendant is charged
was committed and the Defendant is the person who
committed the crime.

The Defendant is not required to present
evidence or prove anything.

Whenever the words "reasonable doubt" are
used you must consider the following:

A reasonable doubt is not a mere possible
doubt, a speculative, imaginary, or forced doubt. Such a
doubt must not influence you to return a verdict of not
guilty if you have an abiding conviction of guilt. on

205

the other hand, if after carefully considering, comparing
and weighing all the evidence, there is not an abiding
conviction of guilt, or, if having a conviction one which
is not stable but one which wavers and vacillates, then
the charge is not proved beyond every reasonable doubt
and you must find the Defendant not guilty because of the
doubt is reasonable.

It is to the evidence introduced into this
trial, and to it alone, that you are to look for that
proof.

A reasonable doubt as to the guilt of the
Defendant may arise from the evidence, a conflict in the
evidence, or the lack of evidence.

If you have a reasonable doubt you should
find the Defendant not guilty. If you have no reasonable
doubt you should find the Defendant guilty.

It's up to you decide what evidence is
reliable. You should use your common sense in deciding
which evidence in the best evidence and which evidence
should not be relied upon in considering your verdict.
You may find some of the evidence not reliable, or less
reliable than other evidence.

You should consider how the witnesses
acted, as well as what they said. Some things you should
consider are:

206

Did the witness seem to have an
opportunity to see and know the things about which the
witness testified?

Did the witness seem to have an
accurate memory?

Was the witness honest and
straightforward in answering the attorney's questions?
Did the witness have some interest in
how the case should be decided?

Does the witness' testimony agree
with other testimony and other evidence in the case?
Has the witness been offered or
received any money, preferred treatment, or other benefit
in order to get the witness to testify?

Had any pressure or threat been used
against the witness that affected the truth of the
witness' testimony?

You may rely upon your own conclusion
about the witness. A juror may believe or disbelieve all
or any part of the evidence or testimony of any witness.

The Defendant in this case has become a
witness. You should apply the same rules to
consideration of the Defendant's testimony that you apply
to the testimony of the other witnesses.

There are some general rules that apply to

207

your discussion. You must follow these rules in order to
return a lawful verdict:

You must follow the law as it is spelled
out in these instructions. If you fail to follow the
law, your verdict will be a miscarriage of justice.
There is no reason for failing to follow the law in this
case. All of use are depending upon you to make a wise
and legal decision in this matter.

This case must be decided only on the
evidence that you have heard from the testimony of the
witnesses (and have seen in the form of exhibits in
evidence) and these instructions.

This case must not be decided for or
against anyone because you feel sorry for anyone, or are
angry with anyone.

Remember, the lawyers are not on trial.
Your feelings about them should not influence your
decision in this case.

Your duty is to determine if the Defendant
has been proven guilty or not, in accordance with the
law. It is the judge's job to determine a proper
sentence if the Defendant is found to be guilty.

Whatever verdict you render, it must be
unanimous, that is, each jury must agree to the same
verdict.

208

It is entirely property for a lawyer to
talk to a witness about what testimony the witness would
give if called to the courtroom. The witness should not
be discredited by talking to a lawyer about his or her
testimony.

Your verdict should not be influenced by
feelings of prejudice, bias, or sympathy. Your verdict
must be based on the evidence and the law contained in
these instructions.

Deciding a verdict is exclusively your
job. I cannot participate in that decision in any way.
Please disregard anything that I may have said or done
that made you think that I preferred one verdict over the
other.

In just a few moments you will be taken to
the jury room. The first thing that you need to do is is
to elect a foreperson. The foreperson presides over your
deliberation like a chairperson of a meeting. It is the
foreperson's job to sign and date the verdict form when
all of you have agreed on a verdict in this case. For
your convenience we have prepared one for you. You will
take it back with you. It read, "We, the jury finds as
follows as to the Defendant in this case." You have two
choices. A choice "A" the Defendant is guilty of
Battery as charged. Choice "B" the Defendant is not

209

guilty. The foreperson will sign his or her name, then
print his or her name under their signature. This will
be dated and brought back when you reach a verdict.

Your verdict finding the Defendant either
guilty or not guilty must be unanimous. The verdict must
be verdict of each juror, as well as the jury as a whole.

In closing, let me remind you that it is
important that you follow the law spelled out in these
instructions in deciding your verdict. There are no
other laws that apply to this case. Even if you do not
like the laws, it must be applied, you must use them.
For two centuries we have agreed to a constitution and to
live the law. None of us has the right to violate the
rules that we all share.

Counsel, any objections to the
instructions as given?

MR. TYSON: No, your Honor.

MR. DENIS DE VLAMING: No, your Honor.

THE COURT: Ladies and gentlemen of the
jury, I recognize that you don't do this everyday. These
instructions come at the end of two long days. For that
reason I reduce them verbatim to writing. You will have
them to take back with you the jury room, if you would
like to refer to them, you do not need to unless you want
to, but you do not need to unless you want to, but you

210

will have them. You will get the verdict form as well.
You are going to get all the items that

went into evidence. You will get a television and a 1/CR
to review these items. There is one tape that you will
not get to take back with you, because there are other
things on that tape that are not appropriate for you to
see. If you want to see that tape you will need to let
the bailiffs know, we will come back into the courtroom
and play that part of the tape with all of us present.

Did I forget anything?

MR. TYSON: Judge, may we approach?

THE COURT: Sure.

(Whereupon, a bench conference was held
out of the hearing of the jury.)

MR. DENIS DE VLAMING: Why don't you tell
them that the tape in question, because you have probably
got their curiosity up on what that is.

THE COURT: The tape that will stay here
is the one involving Frank Oliver and the laser light,
just so that you are able to sort that out. Just so that
you know which one that you don't have. That's the one
we have, you may see, just tell the bailiffs and we will
make it available to you. Okay. At this time you may
retire to deliberate your verdict. Mr. X, you
stay with us. You are the alternate. Please remain with

211

us.

(Whereupon, the jury was retired for
deliberation of their verdict.)

THE COURT: Mr. X, the job of the
alternate juror sometimes is a long job and a difficult
job. It's difficult because you have sat here for two
days and listened attentively and you do not get to now
deliberate a verdict. But I want you to understand how
important your role is to this process. If we did not
have an alternate juror and something happened to one of
the other jurors that they could not finish for whatever
reason, they get called away, we would have to start all
over again. So your service is very valuable to us. We
are very grateful for your service. I guess a fair way
to put it is, the good news is that you get to home now,
but they still have to stay. But we very much appreciate
your service. You are free to go, sir. Have a nice day.

(Whereupon, the alternate juror was
excused.)

THE COURT: Counsel, this trial reflected
the very highest quality of lawyering I expected. All of
you worked very hard. I am very grateful for the very
hard work put in by both sides.

We are adjourned.

(Whereupon, the jury was brought in.)

212

THE COURT: If the jury has reached a
unanimous verdict in this case I would ask the foreperson
to please hand the verdict form to the bailiff and then
take a seat please.

Madam Clerk, if you would please publish
the verdict. The Defendant please stand.

THE CLERK: The State of Florida versus
Robert S. Minton. We the jury find as follows as to the
Defendant in this case, the Defendant is not guilty, so
say we all, foreperson of the jury Tina X.

THE COURT: Does either counsel wish the
clerk to poll the jury?

MR. TYSON: No, sir.

THE COURT: Ladies and gentlemen of the
jury you have been with for two days. You have worked
hard. It is never proper for a judge to comment on a
jury's verdict and I deliberately avoid doing that now.
What I want to do though is thank you for your hard work
and your good efforts. Justice in America basically is
what a jury does, just like you did in this case. You go
back and you deliberate, and you make a decision. I
appreciate that very much. You work is done now,
however, we have kept you long enough. You are free to
go. As you go I just want to make you aware of one
thing. Many times jurors are confused about whether or

213

not they can talk about their experience that they had in
this matter. Now that this case is concluded you can
choose to either discuss with whomever you want, or
discuss it with no one. The choice is yours. Thank you
very much. Have a good day, and be careful going home.

(Whereupon, the jury was dismissed.)

THE COURT: If you would stand once again.
Robert S. Minton based on a jury finding you not guilty
of the charge in this case, this Court now adjudges you
not guilty and you may go hence without day.

This court is adjourned.

(Whereupon, at 3:30 p.m. the trial in the
above-entitled matter was concluded.)

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Certificate of Reporter

I, Pamela S. Jenkins, do hereby certify that I
took the audio graphic notes of the foregoing proceedings
and the same were reduced to typewriting under my
direction; that the foregoing is a true record of said
proceedings; that I am neither related to nor employed by
any of the parties to the action herein; and, further,
that I am not a relative or employee of any attorney or
counsel or employed by the parties hereto, nor
financially or otherwise interested in the action.


Pamela S. Jenkins

I PAMELA S. JENKINS

MY COMMISSION # CC 935535
EXPIRES: May 10, 2004
Bonded Thru Notary Public Underwriters
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