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From : “Alberto Rafallo" <arafallo@hotmail.com>
To: Bob@Minton.org
Subject: conflict of Interests
Date: wed, 18 Au 1999 l0:43:ll MST

Dear Mr. Minton,

Here is some information, which I can't verify is 100% accurate. certainly most of it is and I will post it onto ARS, but first wanted to give you an opportunity to respond to any of these factual allegations. Here is my posting:

My understanding is that Mr. Minton loaned attorney Dan Leipold an estimated $l00,000 (not sure on the figure) so that Dan Leipold and two partners, who worked with him in the Orange County office of Hagenbaugh and Murphy, could break off from that firm and start their own.

I don't know what sort of a tax write off Mr. Minton may have gotten (if any ). It may be interesting to look into this and whether he is deriving any other benefit such as profit sharing in the firm. If so, does he (Mr. Minton) have any say in the actions that the firm takes with regard to the litigation and their clients? I believe he does.

Please note that Dan Leipold and his partners could not have gotten their firm off the ground without Minton's money. They were CAN's main attorneys and defended CAN out of business once CAN'S insurance policy ran out.

Where this gets complicated is Mr. Minton loaned Lawrence Wollersheim (also Dan Leipold's client) about $750,000 over the past couple of years. This does not include the money Mr. Minton contributed to FACTNet to run it - which I believe was substantial.

Mr. Minton has a lien (or liens) on Lawrence Wollersheim's judgment against church of Scientology of California. Mr. Minton, also Leipold's client, was involved in the settlement which was made between FACTNet and Scientology. Mr. Minton expressed his position in the settlement on ars i.e. that FACTNet was guilty of infringement and was likely to lose, therefore it was time to cut FACTNet's losses.

What may not be known is that there was a serious conflict of interest on Dan Leipold's part. On the one hand, Dan Leipold was representing FACTNet and Lawrence Wollersheim in the copyright infringement case, which was a loser, and the collection of Lawrence's judgment. At the same time, he has been representing Mr. Minton who from what I understand has been trying to get back the $750,000 he loaned to Lawrence Wollersheim and is probably not too happy about being conned by Lawrence.

Dan Leipold would have to be beholden to Mr. Minton for a loan to his firm. He also knows that any money that comes to cover FACTNet's fees comes from Mr. Minton whether it is laundered through FACTNet's accounts or not. (Mr. Minton apparently just paid off $110,000 FACTNet/Wollersheim owed Dan Leipold).

Dan Leipold also represents Mr. Minton's interests to pursue collections for Lawrence Wollersheim on the judgment get back Minton's $750,000 which Mr. Minton probably now thinks Lawrence Wollersheim defrauded him on. If this is the case, this has conflict written all over it, and I predict an eventual lawsuit - possibly for malpractice not to mention the circumstances of the loan.

FACTNet was guilty of copyright infringement, as Mr. Minton has admitted. How then can contributions to FACTNet or to the litigation be considered charitable contributions? Mr. Minton said he felt a moral obligation to pay FACTNet's attorney fees. I say this is more of Bob Minton's double talk. He uses his money to pay for people to break the law reference each of the copyright infringement cases were lost: Ward, Henson, FACTNet and Lerma which Minton contributed funds to defend. But more importantly, he has his $750,000 investment (probably more now that he paid $110,000 for FACTNet's legal fees) to protect, not to meantion whatever loan he may have given to Dan Leipold's firm.

I guess a case could be made that Jesse Prince, Stacy Brooks, Lawrence Wollersheim and Dan Leipold are nothing more than Minton's whores. :)"

Please let me know as soon as possible.

Sincerly,

Alberto Rafallo