1 IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR HILLSBOROUGH COUNTY 2 CIVIL DIVISION 3 ESTATE OF LISA McPHERSON, by and through the Personal Representative, 4 DELL LIEBREICH, 5 Plaintiff, 6 vs. Case No.: 97?01235 7 CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC.; JANIS 8 JOHNSON; ALAIN KARTUZINSKI; and DAVID HOUGHTON, D.D.S., 9 Defendants. 10 VIDEOTAPED DEPOSITION OF ROBERT VAUGHN YOUNG 11 Volume IV 12 C O N F I D E N T I A L 13 14 15 16 17 18 19 20 21 22 23 24 Susan D. Wasilewski, RPR, CRR December 21 & 22, 1999 25 465 1 APPEARANCES Counsel for Plaintiff: 2 MR. KENNAN G. DANDAR Dandar & Dandar, P.A. 3 Attorneys at Law 5340 West Kennedy Boulevard, Suite 201 4 Tampa, Florida 33609 5 Counsel for Defendant Church of Scientology Flag Service Organization: 6 MR. MORRIS WEINBERG, JR. Zuckerman, Spaeder, Taylor & Evans, LLP 7 Attorneys at Law 401 East Jackson Street, Suite 2525 8 Tampa, Florida 33602 9 MR. MICHAEL LEE HERTZBERG Attorney at Law 10 740 Broadway, 5th Floor New York, New York 10003 11 MR. A. BROADDUS LIVINGSTON 12 Carlton, Fields, Ward, Emmanuel, Smith & Cutler, P.A. 13 Attorneys at Law One Harbour Place 14 Tampa, Florida 33601 15 Counsel for Defendant Janis Johnson: MR. RONALD P. HANES 16 Trombley & Hanes Attorneys at Law 17 707 North Franklin Street, 10th Floor Tampa, Florida 33602 18 Also Present: Mr. Michael Garko 19 Ms. Stacy Brooks Mr. Jesse Prince 20 Mr. Michael Rinder Mr. Marty Rathbun 21 Ms. Lara Cartwright Ms. Wendy Beccaccini (via Internet) 22 23 24 25 SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 466 1 I N D E X 2 Volume IV 3 December 21, 1999 4 WITNESS PAGE 5 Called by the Defendant Church of Scientology Flag 6 Service Orangization: 7 ROBERT VAUGHN YOUNG 8 DIRECT EXAMINATION BY MR. WEINBERG......... 468 9 SIGNATURE PAGE................................. 661 10 CERTIFICATE OF REPORTER OATH................... 662 11 REPORTER'S DEPOSITION CERTIFICATE.............. 663 12 13 EXHIBITS 14 (None) 15 16 17 18 19 20 21 22 23 24 25 SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 467 1 IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR HILLSBOROUGH COUNTY 2 CIVIL DIVISION 3 ESTATE OF LISA McPHERSON, by and through the Personal Representative, 4 DELL LIEBREICH, 5 Plaintiff, 6 vs. Case No.: 97?01235 7 CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC.; JANIS 8 JOHNSON; ALAIN KARTUZINSKI; and DAVID HOUGHTON, D.D.S., 9 Defendants. 10 VIDEOTAPED DEPOSITION OF ROBERT VAUGHN YOUNG 11 Volume IV 12 C O N F I D E N T I A L 13 PURSUANT TO NOTICE for the taking of the 14 deposition of ROBERT VAUGHN YOUNG, upon oral 15 examination in the above?styled cause, at the 16 instance of the Defendant Church of Scientology 17 Flag Service Organization, for the purposes of 18 discovery or use at trial or both, pursuant to 19 Florida Rules of Civil Procedure, proceedings 20 therefor were held before Susan D. Wasilewski, 21 Registered Professional Reporter, Certified 22 Realtime Reporter, and Notary Public in and for the 23 State of Florida at large, at the Wyndham 24 Westshore, 4860 West Kennedy Boulevard, Tampa, 25 Florida, on December 21, 1999. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 468 1 VIDEOTAPING SERVICES were provided by 2 Thomas Hallahan and Rick Spector. 3 THEREUPON, the following proceedings were 4 had and taken: 5 ROBERT VAUGHN YOUNG, called as a witness 6 by the Defendant Church of Scientology Flag Service 7 Orangization, having been previously duly sworn, 8 continued to testify as follows: 9 DIRECT EXAMINATION 10 BY MR. WEINBERG: 11 Q. Did you remember anything else, any other 12 topics or details from the eyeball?to?eyeball 13 meeting that you and your ex?wife had with Sergeant 14 Andrews and Mr. Strope? 15 A. No. 16 Q. Did either you or your ex?wife explain in 17 terms that would be understandable to a layperson 18 what the religious concept of isolation was in 19 Scientology? 20 A. First of all, she wasn't my ex?wife. 21 Q. She is now though, right? 22 A. When this meeting occurred. 23 Q. She's your ex?wife now, right? 24 A. Yes, but you're referring to a time at the 25 meeting she was ?? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 469 1 Q. I'm referring to a person who is your 2 ex?wife, correct? 3 A. Now. 4 Q. Right. Now, do you understand my 5 question? 6 A. At the time of the meeting she was my wife 7 and ?? 8 Q. That wasn't my question. My question was 9 at the time of the meeting that you and this person 10 who is now your ex?wife, Stacy, had with the FDLE 11 person and the Clearwater Police detective, police 12 sergeant, did either of you explain to them what 13 the religious belief relating to either isolation 14 or the introspective rundown was? 15 MR. DANDAR: Object to the form. 16 Q. Go ahead. 17 A. No. 18 Q. Well, did you or Stacy refer to the book? 19 A. What book? 20 Q. Refer to the tech as it related to either 21 the Scientology belief concerning isolation and/or 22 introspection rundown? 23 A. I didn't have any ?? we didn't have any 24 materials with us. 25 Q. Did they have ?? did the officers have SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 470 1 materials with them? 2 A. No. 3 Q. From the tech? 4 A. No. 5 Q. Did they ?? did you or Stacy refer to the 6 tech? 7 A. No, just other than the explanation I gave 8 you. 9 Q. Well, that's what I want to go back to. I 10 was under the impression that at some point during 11 the conversation either you or Stacy said that she 12 had more experience with the tech than you did, 13 right? 14 A. Yes. 15 Q. And that was in response to their 16 questions concerning isolation or the introspection 17 rundown, correct? 18 A. Yes. Yes. 19 Q. And what they said is that they wanted to 20 know more about what this Scientology belief was 21 concerning isolation or the introspection rundown, 22 correct, that's what they said? 23 A. I didn't say Scientology believe in. They 24 just asked the question if we had a familiarity 25 with it and could explain it. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 471 1 Q. Right. But they told you that they had 2 looked it up in a book? 3 A. No. 4 Q. Well, when you had your first conversation 5 over the telephone, or the second conversation over 6 the telephone, whichever conversation, you referred 7 them to the books, didn't you? 8 A. Yes. 9 Q. Right. And they said they had the books? 10 A. Yes. 11 Q. And you understood that by the books, this 12 is the scripture, correct? 13 A. I don't call it the scripture. I've never 14 considered it the scripture. 15 Q. Well, let me ask you something. There are 16 many people out there that consider themselves 17 Scientologists, correct? 18 A. Yes. 19 Q. And there are many people out there who 20 consider them Scientologists ?? consider themselves 21 Scientologists that refer to these books as the 22 scripture, correct? 23 A. Some do. 24 Q. Now, these books ?? well, tell me, what 25 book was it that you referred Sergeant Andrews to SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 472 1 with regard to isolation or the introspection 2 rundown? 3 A. It's called the technical ?? the HCOB 4 volumes. 5 Q. And HCOB, just so the record is clear, is 6 what? 7 A. Hubbard Communication Office Bulletin. 8 Q. Okay. And which volume did you refer him 9 to? 10 A. I did not refer to a volume. I just said 11 there is an index, cumulative index that one can 12 look up topics in the volumes. 13 Q. And what did you tell him to look up? 14 A. Whatever he wanted to look up. 15 Q. Well, I'm asking you. Was that isolation 16 and the introspection rundown, is that what you 17 referred him to? 18 A. No. I just said there are the technical 19 volumes and you can look up subjects, because this 20 has been written about and there are bulletins 21 about it. There is also ?? I think I may have also 22 referred to there is also PTS, all caps, PTS, 23 policy letters or policy letters about PTS which 24 would be relevant to it and those are in the green 25 volumes. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 473 1 Q. What are the green volumes? 2 A. Those are the policy volumes, 3 administrative volumes. 4 Q. Did he say he had the green volumes? 5 A. I don't remember him saying that. 6 Q. Now, and you said that they would be 7 related to or relevant to what? 8 A. Introspection and isolation deals with PTS 9 III and there are policy letters regarding PTS III 10 and giving the definitions. The red volumes tell 11 more of how to deal with it. The green volumes 12 pretty much define it in an administrative manner, 13 used as in ethics rather than technical matters. 14 Q. Now, technically, when you say how to deal 15 with it, this is how an auditor or a case 16 supervisor would deal with someone who was 17 psychotic? 18 A. Yes. 19 Q. And this is from materials that were 20 written and published by Mr. Hubbard, is that 21 correct? 22 A. Written and issued by him but published by 23 the volumes were not by him. Those were 24 collections of the issues. 25 Q. And these were collected in volumes that SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 474 1 are kept on shelves by many Scientologists, right? 2 A. They are kept. I don't know how many. 3 It's always been an expensive set. 4 Q. Well, what I mean is that when one is 5 studying either ?? studying what Scientologists 6 refer as the technology, one would refer to these 7 volumes, correct? 8 A. They can, but if I just may interject, 9 when you take courses, they are usually loose 10 issues that are gathered that are pertinent to that 11 subject matter. The volumes are just the 12 collection of pretty much all of them together. 13 Q. Right. 14 A. And so a course might consist of 50, 60 15 issues, whereas the volumes contain hundreds and 16 hundreds. 17 Q. Right. So that I might break out an issue 18 that was in one of these volumes, is what you're 19 saying? 20 A. Only if you took a razor blade to it. 21 Q. Well, I mean I take it there are 22 mimeographs or copies of issues that are in the 23 volumes, right? 24 A. Yes. 25 Q. So that a Scientologist might refer to one SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 475 1 of these volumes with regard to an issue, like 2 psychosis or what Scientologists refer to PTS Type 3 III, much like a Christian might refer to the Bible 4 with regard to a particular issue, correct? 5 A. No. 6 Q. No? So that a ?? let's just say a public 7 member of Scientology, all right, they are entitled 8 to have copies of these volumes, right? 9 A. Yes. 10 Q. Right. And they could put them in their 11 library, correct? 12 A. Yes. 13 Q. They can refer to them any time they want 14 to, right? 15 A. Yes. 16 Q. I can go to a store and buy a Bible if I 17 want to, right? 18 A. Yes. 19 Q. And I can refer to it any time I want to, 20 right? 21 A. Yes. 22 Q. And I can either accept it or reject it as 23 much as I want to and that's one of the wonderful 24 things about this country, right? 25 A. Yes. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 476 1 Q. And as a public Scientologist, you know, I 2 can take those volumes and I can read them on my 3 own and I can do with them what I want to do with 4 them, correct? 5 A. Not really. If do you it wrong, then RTC 6 comes after you. 7 Q. I see. Now, the ?? going back to the 8 conversation, did you explain on the telephone 9 conversation that you had with Sergeant Andrews 10 what PTS Type III was? 11 A. I don't think I said anything more than 12 PTS III is what's called a psychotic break, but 13 nothing more than joining those two concepts in 14 words. 15 Q. Now, in this meeting that you and Stacy 16 had with the two law enforcement officers in 17 Seattle, did you explain to them in terms that a 18 nonScientologist could understand what a PTS Type 19 III was? 20 A. No. It was Stacy that pretty much took 21 that over. 22 Q. I meant the collective you. 23 A. Well, just to clarify it. 24 Q. Okay. Did Stacy explain to them that in 25 Scientology a PTS Type III was a psychotic, SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 477 1 basically? 2 A. She probably used words to that effect. 3 Q. And did she explain to them that in the 4 Scientology religion, that psychiatric treatment or 5 psychiatry was verboten? 6 A. I don't recall the subject of psychiatric 7 coming up. 8 Q. Well, did she explain to the officers or 9 did they ?? did they seem to understand that 10 Scientology had a belief that was contained in the 11 technical volumes as to how to deal with 12 Scientologists that were having psychotic 13 experiences, did they understand that or did y'all 14 explain that to them? 15 A. I'm sorry. That was long. Can you read 16 it to me or shorten it? 17 Q. I'll break it down for you. Did Stacy and 18 can you explain during the ?? during this hour or 19 so conversation with the law enforcement officers, 20 that Scientology had a belief as to how to deal 21 with people that were experiencing psychotic 22 breaks? 23 A. Not in that sense of the word. It seems 24 to parallel it when we described what was done, but 25 I don't know how else to describe it, how SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 478 1 Scientology deals with it. It wasn't in that 2 generic sense. Somebody said, you know, asked what 3 is this, what is PTS III. It's a psychotic break. 4 You don't say Scientology calls it. You just give 5 the definition. 6 Q. Well, you're familiar with the Christian 7 Science religion, is that right? 8 A. Well, I don't know. Ask your questions. 9 Q. Well, you understand that Christian 10 Scientists do not believe in medical treatment, 11 right? 12 A. Yes. 13 Q. And you believe, I take it, that they have 14 a right under the constitution of our United States 15 to practice that belief although you may disagree 16 with it, correct? 17 A. To a point. It's a tough legal issue, I 18 know. 19 Q. Right. But you understand that Christian 20 Scientists believe that physical problems or 21 treatment should be dealt with in their religion 22 spiritually as opposed to going to a doctor and 23 getting some sort of medical treatment, you 24 understand that, right? 25 A. That's what they advocate. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 479 1 Q. And it is correct, is it not, that 2 Scientologists advocate dealing with psychiatric 3 problems spiritually as opposed to going to a 4 psychiatrist or a mental health institute, you 5 understand that too, correct? 6 A. I understand your question but I would say 7 they deal with it with Hubbard's technology, not 8 spiritually, which he describes as an exact 9 science. He never described it as a spiritual 10 process, he described it as an exact scientific 11 process. 12 Q. You understand that in the religion of 13 Scientology, that Scientologists believe that 14 psychiatric issues should be dealt with through the 15 religion as opposed to going to a mental health 16 institute or a psychiatrist, correct? 17 A. No. 18 Q. You don't accept that? 19 A. No. 20 Q. What part of what I just said don't you 21 accept? 22 A. Through the religious. That has only been 23 a recent phenomenon that came up, which I was a 24 direct party to. It has always been through the 25 technology, through the Hubbard standard tech, SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 480 1 those are the phrases that are used. 2 Q. So what you're hanging up on is you don't 3 believe that Scientology is a religion, right? 4 A. No. I said that use of religious practice 5 is a very recent PR description. Internally we 6 always used the phrase we handle this by standard 7 tech, we handle this with on?source materials, we 8 handle this with L. Ron Hubbard technology. 9 Internally you never say we will handle this with a 10 spiritual religious practice. We say handle this 11 with standard tech. 12 Q. All right. Now, you left Scientology in 13 1989, correct? 14 A. Yes. Yes. 15 Q. Lisa McPherson died at the end of 1995, 16 correct? 17 A. Yes. 18 Q. Basically six years later? 19 A. Yes. 20 Q. Well, let's leave the word ?? let's 21 approach it a different way. You agree with me, do 22 you not, sir, that Scientologists believe that 23 mental ?? or that psychiatric, mental, psychotic, 24 psychosis issues should be dealt with through the 25 volumes as written by L. Ron Hubbard about SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 481 1 Scientology as opposed to going to a psychiatrist 2 or a mental health institute, is that right? 3 A. I will agree with that statement. 4 Q. Now, did you or Stacy convey that in 5 layterms that any two blokes could understand to 6 Andrews and Strope in the meeting in Seattle? 7 A. Not perhaps directly as much as implied. 8 For example, I could imagine myself saying this is 9 the way PTS III is handled. 10 Q. By Scientology? 11 A. Well, I just ?? this is the way it's 12 handled. It's sort of an assumed subject that 13 we're dealing with and I can't imagine my saying 14 rather than going to a doctor or something else. 15 This is what PTS tech is and that is what is used. 16 There was no discussion of alternative methods of 17 psychiatry, why wasn't she taken to a psychiatrist, 18 et cetera. 19 Q. Is there anything ?? did L. Ron Hubbard 20 make any mystery of his firm belief that 21 psychiatrists and mental health institutes were a 22 bad thing? 23 A. No. 24 Q. Okay. Is there ?? has Scientology made 25 any mystery of its firm belief that one should not SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 482 1 be treated by psychiatrists, go to psychiatrists, 2 or be committed to mental institutes? 3 A. That is correct. 4 Q. So that the ?? it would not take a 5 detective of any merit that was looking at 6 psychiatry to learn what ?? I'm sorry. It would 7 not take ?? strike that. 8 It would not take a detective of any note 9 who was looking at Scientology to learn that 10 Scientologists and Scientology is firmly opposed to 11 psychiatry, mental health treatment, correct? 12 A. It wouldn't be difficult to find. It's 13 very obvious. 14 Q. Right. I mean Mr. Hubbard wrote dating 15 back to the 1950s about his views of psychiatry, 16 right? 17 A. To 1950, yes. 18 Q. Mr. Hubbard made a very strong statement 19 when he announced his solution to how to deal with 20 the psychotic condition Type III through the 21 introspection rundown, correct? 22 A. I don't know exactly what year that 23 phenomenon came up but various statements were 24 being made from 1950. 25 Q. And it was well?publicized when SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 483 1 Mr. Hubbard discovered the introspection rundown 2 and wrote about it, correct? 3 A. Internally, yes. 4 Q. Yeah, I mean within Scientology? 5 A. Yes. 6 Q. For someone that believes in Scientology 7 and the technology of Scientology, there is 8 probably nothing that would be worse that that 9 person could do than to go to a psychiatrist, 10 correct? 11 A. I'll give you one more notch down. That 12 would be committed to a mental institution. 13 Q. Okay. So, just so I understand you, for a 14 person that believed in Scientology, was committed 15 to what Scientologists call the technology, there 16 would be nothing worse that that person could 17 imagine happening to them than being committed to a 18 mental institute, correct? 19 A. That was the ?? that was pretty much the 20 stance that was taken, but ?? 21 Q. Just answer that question. 22 MR. DANDAR: Wait a minute. Don't 23 interrupt him. 24 Q. No, no, no. Just answer ?? 25 MR. DANDAR: Don't interrupt him. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 484 1 Q. Just answer the question and then you can 2 explain. Am I correct? 3 A. There were Scientologists ?? most 4 Scientologists would subscribe to that, I agree to 5 that. 6 Q. Okay. That's all I'm asking. 7 A. May I then add my other footnote? 8 Tempered by his ultimate statement to make sure we 9 seek proper medical treatment. 10 Q. You just felt it necessary that you needed 11 to say that? 12 A. No. I mean the point is he wrote from 13 1950 that most illnesses are psychosomatics, and 14 then at the same time there was put up in the 15 front, when you came in, seek medical help, et 16 cetera. So there was that ?? that was there too. 17 Q. All right. But we're talking about 18 getting committed to one of those places that gives 19 you psychotropic drugs, would put you in a 20 straightjacket, would maybe do some sort of 21 electric shock or whatever happens in a mental 22 institute. There is nothing that would be more 23 offensive to a Scientologist who believed in 24 Scientology tech than that to happen, would there? 25 A. That's a pretty fair description. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 485 1 Q. Now, did, at this meeting or in these 2 conversations with these law enforcement officers 3 with regard to the Lisa McPherson case, did you or 4 Stacy make it clear to them how strongly people 5 that believe in Scientology felt about psychiatric 6 treatment or being committed to a mental institute? 7 A. No. We weren't ask. 8 Q. Did it appear that the officers were aware 9 in asking you about PTS Type III that there was an 10 issue with regard to psychosis or psychiatry in the 11 Lisa McPherson matter? 12 A. I'm not ?? I don't understand what you 13 mean by an issue in the ?? 14 Q. Well, they are the ones that mentioned to 15 you PTS Type III, right? 16 A. Yes. 17 Q. So they already knew about it? 18 A. Yes, they knew the phrase. 19 Q. Right. Did they tell you how they knew 20 about the phrase? 21 A. No. 22 Q. Did they tell you that they believed that 23 Lisa McPherson was psychotic ?? 24 A. I don't ?? 25 Q. ?? prior to her death? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 486 1 A. I don't remember that being said. We were 2 being asked what we knew about these matters. 3 Q. Did they tell you that they believed that 4 Lisa McPherson would be alive today if she had been 5 committed to a mental institute, did they tell you 6 that? 7 A. No. No. 8 Q. Did they infer or imply that? 9 A. No. 10 Q. Did they tell you how they came to know 11 about PTS Type III? 12 A. No. 13 Q. Did they tell you how they came to know 14 about the introspection rundown? 15 A. No. 16 Q. Did you talk to anybody other than Stacy 17 about your meeting or conversations with these law 18 enforcement officers? 19 A. I don't think so. 20 Q. Did you make any record, you or Stacy make 21 any record of this meeting? 22 A. No. 23 Q. Did you tell Mr. Dandar about the meeting? 24 A. I don't remember telling him about that. 25 Q. Did Stacy? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 487 1 A. I don't think she did. 2 Q. Did you do a report of the meeting? Do 3 you know what I mean by that? 4 A. I don't have anybody I report to. 5 Q. Did you go back and go on your computer or 6 Stacy go on her computer and put notes together, 7 you know, of what you told them and what they told 8 you? 9 A. No. 10 Q. So as far as you know, other than the 11 agents' notes, there is no record of this meeting? 12 A. Yes. 13 Q. Or if the agents did a memo after the 14 fact, but you haven't seen it, is that right? 15 A. I have not seen it. 16 Q. No one sent you a copy to sign off on? 17 A. No. 18 Q. Or Stacy, as far as you know? 19 A. As far as I know. 20 Q. Was Stacy present at all times when you 21 were meeting in this restaurant with these agents? 22 A. Yes. 23 Q. As far as you know, she didn't have any 24 separate meeting or conversations with these 25 officers, is that right? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 488 1 A. That is correct. 2 Q. And you didn't have any separate meetings 3 with them either, is that right? 4 A. That's correct. 5 Q. When they called you the first time, did 6 they ask to speak to you and Stacy or just you? 7 A. I think they just asked for me. 8 Q. And you told them about Stacy? 9 A. I might have mentioned it, that she knows 10 ?? she was not there, as best as I recall, she was 11 not there when I took the call and I might have 12 mentioned that she knows about this, and I think 13 that's probably why I referred them to the volumes 14 rather than saying here, talk to her, she can 15 answer your question better than I can. 16 Q. Put another way, why was Stacy at this 17 meeting? 18 A. Because when they called, she was there 19 and I mentioned to her that they had called and 20 they had asked a technical question and when they 21 said they wanted to meet, I said okay, we'll all 22 meet. 23 Q. Didn't ?? when you talked to these 24 officers, either on the phone or in person, didn't 25 they tell you about their meetings with Lisa SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 489 1 McPherson's family, didn't they tell you about 2 that? 3 A. No. 4 Q. Did they mention Fannie McPherson? 5 A. No. 6 Q. Did they mention Ken Dandar? 7 A. No. 8 Q. Did they mention Dell Liebreich? 9 A. No. 10 Q. Did they mention Ann Carlson? 11 A. No. 12 Q. Do you even know who I'm talking about? 13 A. Not Ann Carlson, I don't. 14 Q. Did they tell you about any investigative 15 work that they had done in the case? 16 A. No. 17 Q. Did they tell you what any witnesses said? 18 A. No. 19 Q. Did they tell you what the Scientology ?? 20 the people at staff had said? 21 A. No. 22 Q. They didn't show you any photographs? 23 A. No. 24 Q. You didn't discuss with them the medical 25 examiner's statements? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 490 1 A. No. 2 Q. You didn't discuss with them the autopsy? 3 A. No. 4 Q. Do you have any better recollection of 5 when the meeting took place? 6 A. No. 7 Q. And you have no further recollection as 8 we're sitting here talking about anything else that 9 Andrews and Strope told you, is that right? 10 A. I remember now there was a remark about, 11 well, we've got some sort of cryptic remark that 12 gave me no information that they were going 13 someplace else that seemed to imply they weren't 14 flying back to Florida, but I ?? it gave me no 15 indication as to what, if they were going to 16 downtown Seattle or where, but just that's the only 17 thing I can remember in addition, they got ?? 18 something to the effect, you know, we've got 19 someplace else to go, almost as if that's why they 20 had to pick up and leave as opposed to us sitting 21 and talking for a couple of hours. 22 Q. Did your then wife do most of the talking 23 during this meeting amongst the two of you? 24 A. Probably. 25 Q. See, what I don't understand, and I don't SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 491 1 think I heard, is that you told me that she put it 2 in layterms, basically, put isolation, 3 introspection rundown, PTS Type III in layterms, 4 right, is that essentially what you said? 5 A. Yes. 6 Q. But what I didn't hear from you is, you 7 know, what that laydescription was. So pretend I'm 8 the officers and you're Stacy. Tell me what it is 9 in a layway that you're trying to communicate, that 10 she communicated to them that day. 11 A. PTS III is called a psychotic break, where 12 basically a person goes crazy ?? and I may be wrong 13 but I don't think that Hubbard uses the word crazy 14 right there, he didn't really like the word ?? can 15 go crazy. She said they could exhibit bizarre 16 behavior, the way this is handled is that the 17 person is isolated, supposed to be kept quiet. I 18 think she may have even cited some sort of 19 familiarity that she had with an incident, but my 20 being not familiar with it, I didn't really attach 21 it with anything, that sometimes light drugs can be 22 used, sedatives, that there is different 23 explanations given for PTS III that ranges from ?? 24 different reasons why it occurs that range from bad 25 auditing to ?? I think she said something like SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 492 1 ethics problems, and that's their phrase, you know, 2 of ethics, which is their way to handle morality. 3 Q. Scientologists' way of handling morality, 4 is that what you mean? 5 A. Well, their, we didn't ?? she didn't ?? I 6 don't think she said Scientology but clearly the 7 reference word is Scientologists, which is the 8 organization, because Scientologists don't do it, 9 it's the organization that does it. The rundown is 10 not one that is done in smaller organizations or by 11 field staff, it's something that's done at 12 organizations. 13 Q. Like Flag? 14 A. We didn't say. We just said, you know, 15 other organizations as opposed to somebody local. 16 That's pretty much it. 17 Q. Did she explain what, in layterms, what 18 the introspection rundown was? You said she 19 explained the concept of isolation and quiet. When 20 you say light drugs, you're not talking about 21 psychotropic drugs, you're talking about something 22 that would help you sleep some, right? 23 A. Yes. 24 Q. You know, other than isolation ?? and you 25 explained what that meant, sort of a quiet setting? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 493 1 A. Well, isolated means kept away from all 2 other people. 3 Q. Right. That in the technology people 4 don't talk to a person that is being isolated, 5 right, did she explain ?? did she get into that 6 kind of detail or not? 7 A. I don't think so. 8 Q. All right. So she explained that, you 9 know, isolation, kept quiet, try to get rest and 10 relaxation basically, right? Did she say something 11 like that? 12 A. Might have. 13 Q. But did she explain then what happens on 14 the rundown? I mean that's what happens first. 15 Did she explain what, you know, sort of thing 16 happens in this introspection rundown? 17 A. Well, that once the person gets to a 18 certain point, then their ?? the introspection 19 rundown comes later. I don't think she got into 20 how it was done as much as there was just a series 21 of steps on it until the person feels better. 22 Q. But did she explain that this is the way 23 Scientologists believe that one should deal with a 24 person who is psychotic rather than send her to a 25 ?? him or her to a psychiatrist to get what SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 494 1 psychiatrists believe how they should deal with a 2 psychotic? 3 A. No. 4 Q. But she did say this is the way 5 Scientologists believe or handled, if that was the 6 word, people that have a psychotic condition, 7 right? 8 A. I don't think she put it in those terms. 9 She just described what the ?? 10 Q. Yeah. 11 A. ?? what the isolation rundown is. I don't 12 think she said Scientology or Scientologists, just, 13 you know ?? 14 Q. All right. All right. And that's pretty 15 much the way she explained it in layterms? 16 A. Yes. 17 Q. Now, have you spoken to Doug Crow? 18 A. Doug Crow? 19 Q. Yeah. 20 A. C?r?o?w? 21 Q. Something like that. 22 A. The name is vaguely familiar. 23 Q. Well, let me put it another way. Have you 24 been in communication with anyone from the State 25 attorney's office or from the prosecutor's office SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 495 1 with regard to the Lisa McPherson matter? 2 A. You will have to forgive me. I don't know 3 Florida structure. Is that different from the 4 State office that the gentleman was with? 5 Q. Yes. These people would be prosecutors 6 who are lawyers who, in this jurisdiction, in the 7 State system, they work out of State attorneys' 8 offices, it's possible somebody from the Florida 9 attorney general's office. And my question is do 10 you remember speaking to any person that referred 11 to themselves as a prosecutor from either the State 12 attorney's office or the attorney general's office? 13 A. No, but the name Doug Crow somehow rings a 14 bell. 15 Q. Bill Burgess, does that ring a bell? 16 A. No. 17 Q. You didn't give any interviews to the 18 State attorney's office? 19 A. I don't recall any. 20 Q. I mean you would recall if you were put 21 under oath and testified with regard to an 22 investigation, correct? 23 A. Yes. 24 Q. And that didn't happen? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 496 1 Q. And as long as you were with Stacy, as far 2 as you know that didn't happen with her either, is 3 that right? 4 A. That's right. 5 Q. Have you spoken to Ray Emmons? 6 A. Yes. 7 Q. And who is Ray Emmons? 8 A. The best of my recall, he's with the 9 Clearwater Police Department. 10 Q. You mean so the last time you talked to 11 him he was in the Clearwater Police Department? 12 A. Hang on. Back up. Back up. I've got it 13 confused with the other cult, sir. I retract that. 14 Q. I move to strike. 15 A. Thank you. I did speak with Ray Emmons, 16 yes, on the phone. 17 Q. And when did Ray Emmons call you? 18 A. Some months back. Oh, sort of seems like 19 five, six months ago, maybe. 20 Q. And where did he call you? 21 A. He reached me I believe it was in 22 Columbus. 23 Q. At the Haney apartment? 24 A. Yes. 25 Q. And who did he say he was? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 497 1 A. He identified himself as working with 2 Mr. Dandar. 3 Q. Why did you say the Clearwater Police 4 Department? 5 A. I was confusing it with, for a second I 6 just lose these names, that there was a ?? the 7 detective that I had met once at a conference who 8 just introduced himself as Clearwater Police 9 Department and there was no conversation. 10 Q. You mean at a conference in the '80s? 11 A. No, in the '90s. 12 Q. What type of conference? 13 A. It was a Cult Awareness Network conference 14 up in Cleveland. 15 Q. Where people from all over the country 16 came and talked about things, is that right? 17 A. Cults, and this gentleman was there, tall 18 gentleman, made himself very prominent, standing 19 out, no ?? et cetera, and somebody I was with 20 introduced me to him, hi, this is ?? I don't even 21 remember the name right now. And he says, oh, 22 Clearwater ?? I was just sort of like, oh, okay, 23 hello. He said, yeah, and I just was surprised 24 that somebody was there. 25 Q. From the Clearwater Police Department? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 498 1 A. Yes, and there was no conversation. I 2 just ?? he didn't ask me any questions, I just 3 moved on. 4 Q. Was that Mr. Emmons? 5 A. I don't ?? I don't think so. 6 Q. Have you ever met Paul Naser? 7 A. I don't ?? I don't ?? 8 Q. Did the guy have a beard? 9 A. No. 10 Q. Do you ever remember talking to Paul 11 Naser? 12 A. The name is vaguely familiar but I don't 13 remember speaking to him. 14 Q. Okay. Let's go back to Emmons. He called 15 you a few months ago in Columbus and asked you 16 what? 17 A. I don't remember because it was a question 18 I couldn't answer and it was ?? the conversation 19 was about a minute and a half and he asked me, he 20 says, hey, you know, do you know anything where I 21 can find ?? any idea how I can find ?? it was like 22 the name of a person. I said no, I really don't. 23 I had no idea why I would be asked that but I 24 didn't recognize the name and he says, okay, well, 25 thanks a lot, and that was the end of that. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 499 1 Q. That's the only time you ever talked to 2 Ray Emmons? 3 A. Yes. 4 Q. How can you remember a one?and?a?half 5 minute or a minute phone call from some guy that 6 you've never talked to before or since, how do you 7 remember that? 8 A. Well, because he mentioned that he worked 9 with Mr. Dandar, and this came out of the blue, and 10 I hadn't spoken with Mr. Dandar for quite a while 11 and this was just, you know, not having spoken with 12 him for quite a while, it was just a reminder that 13 Mr. Dandar was still around. 14 Q. So this was before or after you sat down 15 at your computer and whipped off this computer? 16 A. Oh, way before. This is months before. 17 Q. Do you remember anybody else calling for 18 Mr. Dandar? 19 A. No. 20 Q. Now, do you have any records whatsoever 21 anywhere in the world that would, from ?? that 22 would reflect what you've been doing in the last 23 let's just say seven years? 24 A. That's a huge subject. 25 Q. Yeah. The answer is yes or no. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 500 1 A. Yes. 2 Q. Do you have a diary? 3 A. No. 4 Q. Do you have calendars that show when 5 you've met or scheduled to meet people? 6 A. No. 7 Q. Do you maintain anything on your computer 8 with regard to what you've done and where you've 9 been? 10 A. No. 11 Q. Do you maintain any notes of what you've 12 done and where you've been? 13 A. No. 14 Q. What kind of records do you have 15 indicating what you've done and where you've been 16 in the last two years, say? 17 A. I might have thrown into the corner of a 18 box somewhere, you know, a motel receipt, but I 19 don't keep them. It's more of a case where you 20 sort of empty your pockets and you've sort of got 21 something in your pocket and you just don't throw 22 it away, you throw it down. 23 Q. Well, some people, for example, are 24 slightly more organized than that. 25 A. I hope so. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 501 1 Q. And they have files which show their 2 expenses, files that, you know ?? bank records, 3 phone bills, travel receipts, if you're working for 4 somebody, records detailing, you know, the work 5 you've done. Do you have anything like that? 6 A. No. There has been no need for me to keep 7 those. 8 Q. Well, do you have phone records? 9 A. No. 10 Q. You don't keep phone records? 11 A. No. I use phone cards. 12 Q. So you don't have a phone? 13 A. I had a cell phone but I turned it off and 14 it hasn't been workable for a while. 15 Q. When is the last time you filed an income 16 tax return? 17 A. I'm not sure. I think we filed an 18 extension for last year, which would have been 19 Stacy and mine still jointly, it was an extension 20 on that which still has to be filed. 21 Q. Well, but my question is when is the last 22 time you filed an income tax return? 23 A. It would be the year before that, for '97. 24 Q. So you filed a '97 return in April of '98? 25 A. Possibly, but it would be for the year SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 502 1 1997. 2 Q. And did you file every year prior to that 3 time, after you left Scientology? 4 A. I believe so. 5 Q. Okay. 6 A. We might have had one year with an 7 extension also. 8 Q. You filed a joint return? 9 A. Yes. 10 Q. Now, why did y'all file an extension last 11 year or this year? 12 A. Well, with the divorce and things just 13 sort of in a general upheaval, it was records that 14 you've got to gather and talk to an accountant and 15 it was just easier to file an extension. 16 THE WITNESS: What time is it? 17 MR. DANDAR: Quarter after 2:00. 18 Q. I was under the impression, and maybe I'm 19 wrong because I hadn't done this ever, I don't 20 think, that if you file an extension in April, that 21 you had to file the return by September or October. 22 Isn't that right? But we're in December now. 23 A. Well, you're asking the wrong person. 24 Q. What is your understanding of when you 25 have to file this return? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 503 1 A. Right now I'm going to have to plead 2 ignorance. 3 Q. Well, whose responsibility is it to file 4 this return? 5 A. Well, it's hers and mine jointly. 6 Q. How much ?? well, when you ?? even though 7 you file for an extension, you still have an 8 obligation to pay the taxes due and owing in April, 9 correct? You understand that, don't you? 10 A. Sometimes. I'm sorry. I'm one of those 11 people that seeks the advice of professionals. 12 Q. Well, when you sought the advice of the 13 professional accountant, he didn't tell you, did 14 he, that when you file an extension, you can just 15 defer paying Uncle Sam what you owe him, he didn't 16 tell you that, did he? 17 A. He didn't tell me anything. Stacy was the 18 one that dealt with it. 19 Q. Well, did Stacy tell you that the 20 professional had told her that you could defer 21 paying Uncle Sam by just filing an extension? 22 A. She didn't tell me anything. 23 Q. All right. Well, what is the amount of 24 income that you understand that you and Stacy 25 jointly had in 1998? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 504 1 A. I don't know. 2 Q. Well, what's your estimate of what it is? 3 A. I haven't made an estimate. 4 Q. I'm asking you right here. As we sit here 5 today, what was your income in 1998? 6 A. $10,000, $15,000, I don't know. 7 Q. That includes Stacy, too? 8 A. No. You asked for mine. 9 Q. Well, y'all were married all through 1998, 10 right? 11 A. Yes. 12 Q. So ?? 13 A. Well, no. We actually filed and separated 14 much earlier than that. 15 Q. All right. Well, I thought you said 16 yesterday you didn't get divorced until February of 17 this year. 18 A. I said it was finalized. 19 Q. Well, isn't that ?? when it's finalized, 20 that's when you're actually no longer married, 21 right? 22 A. Legally. 23 Q. Legally. When did you separate? 24 A. Oh, off and on, June or July. It was a 25 couple little times there, back and forth until we SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 505 1 finally decided to do the divorce. 2 Q. And how long had you been married? 3 A. Twenty years. 4 Q. And is there any particular reason why you 5 just didn't file separately, you just filed a 6 separate return for your $15,000 or so in income? 7 A. I didn't ask. I just assumed since there 8 was a period of time of shared income, that we 9 would just go ahead and throw it together rather 10 than trying to figure it out. 11 Q. The shared income is through what, July of 12 1998? 13 A. Oh, probably, June, but joint income, 14 where we would claim it jointly. 15 Q. Now, in that period, the first six or 16 seven months of 1998, your total income between you 17 and Stacy was about $15,000, is that your best 18 guess? 19 A. No, just my income. 20 Q. Well, what was her income while y'all were 21 still together in the first six or seven months of 22 1998? 23 A. This is going to sound very strange but I 24 don't really know. 25 Q. Do you remember that she had a job in the SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 506 1 first six or seven months of 1998? 2 A. Well, mostly it was taking care of the 3 cats. 4 Q. Okay. Well, did y'all pay yourselves 5 salaries from the foundation? 6 A. No. 7 Q. So the foundation ?? so Stacy was not 8 authorized by you or anyone else to take money from 9 the foundation and pay it to herself as income, is 10 that right? 11 A. As income, no. 12 Q. Well, you were what, an officer, a 13 director or what of the foundation? 14 A. Yeah, I'm afraid I was. 15 Q. Well, what do you mean by that? 16 A. Well, I have to plead that I ?? you know, 17 you could find a lot better officers in corporate 18 positions than me. I ?? you're sort of like one of 19 those little locals that are sort of putting 20 together, you're not exactly an entrepreneur with 21 strong legal sense, you're certainly going to learn 22 it after the fact. So because it was her and me 23 basically putting this together, when they said, 24 well, who was going to be the president and vice 25 president, we said, well, how about you? Okay. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 507 1 And how about you? All right. And we sort of 2 threw it together without corporate knowledge and 3 figured we would learn it all a little bit later. 4 Q. Okay. As far as you were concerned, 5 neither you nor Stacy could take money that had 6 been donated to the foundation for the cats and use 7 it for your personal expenditures, correct? 8 A. Once we were nonprofit, yes. 9 Q. Well, if you went to somebody and said 10 I've got these homeless cats that I'm giving a home 11 to and I'd like some help to help the cats, and 12 they gave you whatever, $200, $500, $50, $1,000, 13 neither you nor Stacy were going to take that money 14 and go out to eat with it, were you? 15 A. No. 16 Q. Okay. So that whether you were a 17 nonprofit corporation or not, you weren't going to 18 take, you, and I mean the collective you, you and 19 Stacy, weren't going to take the funds that people 20 had donated to help these animals and use it for 21 some personal expense, for your own pleasure, 22 correct? 23 A. True. 24 Q. Now, and you are, as you sit here today as 25 an officer and a director of that foundation, you SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 508 1 are unaware that there was a single dollar that was 2 donated to the organization that either you or 3 Stacy took and used for yourself, correct? 4 A. First of all, I'm not currently an 5 officer. 6 Q. I'm talking about while you were with 7 Stacy. 8 A. That is true. 9 Q. So let's go back to 1998. Since Stacy 10 wasn't getting a salary from the foundation, can 11 you think of any other job, work, source of funds 12 that would be considered income that Stacy had in 13 the first six or seven months while you were still 14 with her in 1998? 15 A. She might have been doing some 16 consultative work. 17 Q. For whom? 18 A. I don't know. We did get to the point 19 that each of our jobs consulting became quite 20 separated. I just would do mine and not even talk 21 to her. One day she just might say to me, you 22 know, I'm doing such and such and that was news to 23 me. While early on we always worked together as a 24 team, it got to the point that we were working 25 independently. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 509 1 Q. But you can't think of what it might have 2 been in the first six or seven months, right? 3 A. No. 4 Q. And whatever she would have brought in 5 would have gone into your joint account, right? 6 A. Yes. 7 Q. And you would have known about it? 8 A. Not necessarily. She could deposit 9 without my knowing it. 10 Q. Whatever she was doing, it wasn't bringing 11 in a lot of money to the table, was it? 12 A. I don't know what she brought in. 13 Q. Well, you all were in financial 14 desperation by June of 1998, weren't you? 15 A. No. 16 Q. That's right, because Mr. Minton had 17 already given you ?? Mr. and Mrs. Minton had 18 already given you a house to live in, right? 19 A. No. 20 Q. Can you tell us how much rent you paid to 21 Mr. and Mrs. Minton? 22 A. Nothing. 23 Q. Ever? 24 A. No. 25 Q. Who paid the electric bills? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 510 1 A. We did. 2 Q. Was there gas or electric, what was it? 3 A. I think there was gas and electric. 4 Q. What else did Mr. Minton, Mr. and 5 Mrs. Minton pay for? 6 A. I don't know. I know what we would pay 7 for. 8 Q. Well, I mean do you know of anything else 9 that they paid for ?? 10 A. No. 11 Q. ?? while you were there? 12 A. No. 13 Q. What was the ?? where did the $15,000 come 14 from that you sort of guesstimated in the first six 15 months of 1998, which case was that? 16 A. As I said, left over from the FACT Net. 17 Q. I guess what confuses me, we can go over 18 it in detail, but in FACT Net that you testified 19 under oath that you were paid from approximately ?? 20 you and Stacy together as a team were paid from 21 approximately November of '96 until March or so of 22 '97 $5,000 a month and at that point the funds ran 23 dry. Do you remember testifying to that? 24 A. No, I don't but I won't contest it. 25 Q. You wouldn't dispute it? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 511 1 A. No need to dispute it. 2 Q. All right. And if I am right, can you 3 think of any other consultive, if that's a word ?? 4 A. That's okay. 5 Q. ?? work that you would have been doing 6 where you would have gotten any money in 1998? I'm 7 saying ?? this is all relating to Scientology, 8 right? 9 A. Yes. 10 Q. Can you think of anything else, sir? 11 A. No, and I don't remember when Mr. Dandar's 12 check for a couple of thousand came in. I remember 13 it was quite after that I worked for him in '97. 14 Q. It didn't amount to $15,000 though, did 15 it? 16 A. No. I'm just trying to think of 17 something. I can't think of anything else. 18 Q. All right. Now, have you been in touch 19 with Alex Soroka, S?o?r?o?k?a, or something like 20 that? 21 A. Yes. 22 Q. And who is that? 23 A. He's a man who lives in Southern 24 California. 25 Q. And when were you in touch with him last, SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 512 1 approximately? 2 A. I believe it was when I was out in 3 Southern California, back when I was visiting my 4 son. 5 Q. So that would be what, within the last 6 couple of months? 7 A. Well, I'll try to say yes on that one for 8 the moment, yeah. 9 Q. Okay. And what documents did you get from 10 him? 11 A. Nothing. It was just purely a social 12 visit. 13 Q. So you didn't discuss Scientology with 14 him? 15 A. No. 16 Q. In the last three years have you discussed 17 Scientology with him? In the last three years have 18 you had any dealings with him? And I'm not talking 19 social, I'm talking with regard to Scientology. 20 A. Yes. 21 Q. And have you gotten documents from him or 22 made copies from documents that he had? 23 A. Yes. 24 Q. And what documents have you gotten from 25 him? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 513 1 A. They were documents I obtained from him in 2 Los Angeles with regard to the FACT Net case that 3 were ?? the nature of the documents weren't by 4 subject or date. They were documents showing ?? 5 regarding copyright notices on the documents. That 6 was the criteria I was working by because there was 7 a copyright issue at hand in the FACT Net case. 8 Q. And he's a former Scientologist? 9 A. Yes. 10 Q. And he had some original documents or 11 what? 12 A. Yes. 13 Q. And he gave you the originals or copies? 14 A. He loaned them to me so I could make color 15 photocopies. 16 Q. Were these some of the upper level 17 materials? 18 A. No. 19 Q. You understand what I mean by that, right? 20 A. Yes. 21 Q. Is that the only time that you've made 22 copies of documents or received documents from him? 23 A. Yes. 24 Q. And you took the documents and gave them 25 to Mr. Leipold? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 514 1 A. No. I'm trying to remember the name of 2 the firm in Los Angeles that I was working out of, 3 where all the boxes of exhibits were. For the life 4 of me, I can't remember the name of the firm there. 5 Q. Okay. How many trips have you made to 6 Tampa?Clearwater in this case? 7 A. In this case? 8 Q. Yes. 9 A. This is my first. 10 Q. And we established yesterday, I guess, 11 that you hadn't been to Clearwater/Tampa for more 12 than ten years before this trip today, is that 13 right, or yesterday? 14 A. Yes. 15 Q. Okay. Have you looked at the PC folders 16 of ?? well ?? strike that. 17 You know what a PC folder is right? 18 A. Yes. 19 Q. Have you looked at the PC folder or 20 folders of Lisa McPherson or copies of documents 21 from the PC folders? 22 A. No. 23 MR. DANDAR: Do you need a break? 24 THE WITNESS: Yeah, I'd like to ?? 25 MR. WEINBERG: Yeah, let's take a break. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 515 1 It's a little stuffy in here. 2 (Recess from 2:40 to 2:56 p.m.) 3 BY MR. WEINBERG: 4 Q. Ready? 5 A. (Witness nodding head.) 6 Q. Has Stacy indicated to you what her income 7 was after y'all split up in 1998? 8 A. No. 9 Q. And after you split up in 1998, what was 10 the amount of your income, if any? 11 A. I don't think there was anything. 12 Q. So your best estimate of what your income 13 was for tax purposes in 1998 was $15,000? 14 A. Best I can do right now, yes. 15 Q. Did anybody make any gifts to you and/or 16 Stacy as far as you know of cash or funds, stocks 17 or securities, anything of value in 1998? 18 A. Not that I know of. 19 Q. And you didn't get any inheritances in 20 1998 other than possibly your mom's $1,000, right? 21 A. That's correct. 22 Q. Now, after y'all were discharged from 23 bankruptcy and you were able to discharge your 24 credit card debts in 1995, did you or Stacy have 25 credit cards? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 516 1 A. No. 2 Q. So you ?? whatever you bought, you bought 3 either with cash or by check from your accounts, is 4 that right? 5 A. Yes. 6 Q. When you left ?? well, you separated from 7 Stacy in what, the middle of 1998, right? 8 A. Yes. 9 Q. Was that what one calls a legal 10 separation, was there some legal document that was 11 filed? 12 A. No. 13 Q. Is there a divorce lawyer that you or 14 Stacy used with regard to either the separation or 15 the divorce? 16 A. For the divorce. 17 Q. And is it one or more than one lawyer? 18 A. I believe it was just one. 19 Q. And what's the name of this lawyer? 20 A. I don't know. 21 Q. Where is this lawyer? 22 A. In Seattle. 23 Q. And who secured the lawyer? 24 A. Stacy did. 25 Q. So is the lawyer Stacy's lawyer or your SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 517 1 lawyer? 2 A. Stacy's lawyer. 3 Q. So you didn't have a lawyer? 4 A. No. 5 Q. Was it a contested divorce? 6 A. No. 7 Q. Was there something filed? 8 A. Well, there is the ?? whatever you call 9 the divorce papers that are filed. There was 10 something that I signed which I remember showing as 11 uncontested. 12 Q. Well, did she sue you? 13 A. No. 14 Q. Usually there is a legal proceeding that 15 is initiated by either one spouse or the other by 16 way of some complaint. 17 A. I only said no because I didn't understand 18 the word because it was uncontested, so I'm not 19 quite sure of the legal term. When I say it's 20 uncontested, it was something we both mutually 21 agreed to and it was stated so in the divorce 22 papers. 23 Q. Well, did the lawyer communicate with you 24 in advance, I'm talking about Stacy's lawyer? 25 A. In advance of what? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 518 1 Q. In advance of whatever they filed? 2 A. Yes. I mean we met and I was shown the 3 papers that she had drawn up and I signed them. 4 Q. She being ?? so the lawyer was a woman? 5 A. Yes. 6 Q. So you, Stacy and the lawyer met in the 7 lawyer's office? 8 A. Yes. 9 Q. And had the papers already been drawn up 10 at that point? 11 A. Yes. 12 Q. Who asked whom for a divorce? 13 A. Well, I think if I remember right, Stacy's 14 name was at the top and when I saw it I said I want 15 to make it clear in the text that just because your 16 name is at the top and it's your attorney, I wanted 17 wording added to show that this was clearly 18 uncontested, there was no dispute and it was 19 mutually agreed upon and so there was nobody ?? 20 boy, that's loud. 21 Q. Yeah, but it's cool. I'm talking about 22 the air conditioning, by the way. 23 A. And it was explained to me, well, 24 somebody's name has got to come first and I guess 25 that's what you possibly are referring to, but I SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 519 1 wanted to make sure in the wording of the papers 2 that it was very clear that just because someone 3 took that position, it was required by law and had 4 nothing to do with our attitude. 5 Q. Well, what I'm really asking you is, I'm 6 not really asking about who filed what first but 7 was it you or was it Stacy that initiated the idea 8 of getting a divorce? 9 A. It was mutual. 10 (Telephone interruption.) 11 MR. WEINBERG: Hold on a second. 12 (Discussion off the record.) 13 BY MR. WEINBERG: 14 Q. Was it ?? I think you just said that it 15 was a mutual decision to get a divorce, is that 16 right? 17 A. Yes. 18 Q. And the divorce was as a result of Stacy's 19 relationship with Bob Minton? 20 A. No. 21 Q. Had nothing to do with it? 22 A. No. 23 Q. Stacy was having a relationship with Bob 24 Minton prior to you getting divorced, correct? 25 A. Yes. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 520 1 Q. And you learned about that? 2 A. Yes. 3 Q. And how did you learn about that? 4 A. She told me. 5 Q. And when did she tell you? 6 A. Early '98, somewhere in there. 7 Q. So a few months after Mr. Minton ?? or the 8 Mintons had purchased the $250,000 house, is that 9 right? 10 A. That's about right. 11 Q. And what did she tell you? 12 A. We had separated before, several years 13 before and ?? in Southern California and we had 14 been struggling with this for years and we had 15 hoped that something like the sanctuary could be 16 used as some sort of mutual effort and it wasn't ?? 17 it wasn't working. And as I said, it had been 18 rocky for years. So it was ?? it was a mutually 19 hard decision after 20 but the one agreement we had 20 always had from day one was any time either one of 21 us wants to step away, just tell the other and we 22 can step away. 23 Q. Right. And that really wasn't what I was 24 asking you and I really wasn't concerned or prying 25 into your previous ?? you know, what the status of SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 521 1 your relationship was over 20 years. What I had 2 asked you was I think you had said that she told 3 you that she was having a relationship with Bob 4 Minton, and what I was asking you is what did she 5 say about that. I'm not talking about 20 years, 6 I'm just, you know ?? how did it come up or what 7 did she say about Bob Minton? 8 A. She just said that she thought he was a 9 great guy, she was falling in love with him, and my 10 remark back to her was I told you that months ago. 11 Q. Told you what months ago? 12 A. That you were falling in love with him. 13 It wasn't a matter of jealousy on my part, it was a 14 matter of open honesty, and we talked about it, 15 that really what it amounted to was it was more a 16 case of our marriage having been born in a very 17 bizarre environment and situation, had been 18 struggling ever since '89, upon leaving, back and 19 forth in, quote, the real world, and it had just 20 finally was just coming, you know, coming to an end 21 and we had seen this coming for five years. 22 Q. Well, let's just talk about Minton because 23 I'm really not interested in the status of your 24 relationship prior to Bob Minton. All right? 25 A. But that's what we discussed and that was SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 522 1 how it came to that conclusion. 2 Q. All right. The ?? Mr. Minton comes into 3 your life by phoning you, right? 4 A. Yes. 5 Q. As far as you know, he had had no previous 6 contact with your wife, is that right? 7 A. Yes. 8 Q. You essentially rejected his calls two or 9 three times, right? 10 A. Yes. 11 Q. And eventually you took his call and told 12 him that you had this cat problem and he said how 13 can I help, correct? 14 A. No. He already knew about the cat problem 15 from the Internet posting. 16 Q. You confirmed that you had a cat problem? 17 A. Yes. 18 Q. And he said how can I help and he told you 19 at that point that he was willing to buy a house, 20 he and his wife were willing to buy a house where 21 you could take the cats and get away from the cat 22 authorities in Seattle, right? 23 A. Basically, yes. 24 Q. Okay. And we didn't go into this 25 yesterday because I intended to get back to it. At SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 523 1 that point he authorized you and Stacy to go out 2 and find a house, is that right, to go house shop? 3 A. Yes. 4 Q. And so you and Stacy had already ?? were 5 already familiar with Vashon Island and, among 6 other places, went to Vashon Island to house shop, 7 is that right? 8 A. Only Vashon. 9 Q. Only Vashon Island? 10 A. No. I take that back. We did go south 11 out of Seattle. I take that back. We did go south 12 out of Seattle and then focused in on Vashon. 13 Q. Did you use a real estate agent to help 14 you house shop? 15 A. At first no, and then on Vashon we did. 16 Q. And who did you use? 17 A. I don't remember. 18 Q. Where are they located? 19 A. On Vashon. 20 Q. What company were they? 21 A. I don't remember. 22 Q. Are there lots of real estate agents on 23 Vashon? 24 A. No. There is not even traffic signals on 25 Vashon. It's very small. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 524 1 Q. So the chances are that you used the one 2 and only real estate agent on Vashon? 3 A. Probably one of three or four. 4 Q. Okay. And is this a woman or a man? 5 A. She was a woman but there was a company, 6 there were several desks. 7 Q. A national company or a local company? 8 A. Just local to Vashon. 9 Q. Okay. And you asked her for help, you and 10 Stacy asked her for help and told her what you were 11 looking for? 12 A. Yeah. 13 Q. Did you give her a price range? 14 A. No, because we had already learned the 15 range on Vashon and it was more a case of giving 16 her the requirements as far as land, space, why we 17 needed it, be nice to have a barn, it would be this 18 and that, so it was more the specifications. 19 Q. Did you have a ?? what's the word? Did 20 you have a limit from Mr. Minton as to what price 21 range you could locate a house in? 22 A. I wasn't given one. 23 Q. Well, did you understand from Stacy that 24 Mr. Minton had said that you could spend a certain 25 amount of money for a house? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 525 1 A. No, I didn't understand that. 2 Q. Well, I mean were y'all looking at $50,000 3 houses, $100,000 houses, $150,000 houses or million 4 dollar houses? 5 A. There is no million dollar houses on 6 Vashon unless you buy 1,000 acres. The price 7 ranges we saw that we were familiar with on Vashon 8 with any property at all, and we needed at least an 9 acre, tended to be in the range of $150,000 to 10 $300,000. So we knew ?? that was already the 11 category. 12 Q. And that had been communicated, as far as 13 you understand, to Mr. Minton? 14 A. Not by me. 15 Q. I said as far as you understood that had 16 been communicated to Mr. Minton by Stacy, right? 17 A. I don't know. 18 Q. Well, let me ask you something. Before 19 you could realistically go out and find a house 20 that somebody else was going to buy, unless you 21 were prepared to waste a whole lot of time, you 22 would have had to have some price range in mind, 23 right? 24 A. Well, it was a price range of Vashon. As 25 I said, she carried on the conversations because I SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 526 1 just didn't want to deal with it. 2 Q. I understand. But I assume if the price 3 range for Vashon is from 150 to 300, that you 4 wouldn't have been over there unless Stacy had a 5 pretty good idea that that was in Mr. Minton's 6 price range, right? 7 MR. DANDAR: Objection; that's 8 speculative. 9 Q. Is that right? 10 A. I don't know. 11 Q. Is that right? 12 A. I don't know. 13 Q. All right. Well, is it your want and her 14 want, Stacy's want to waste a lot of time? I mean 15 are y'all that kind of people? 16 A. I don't know understand the question. 17 Q. Let's go to the next question. In any 18 event, Stacy was carrying on conversations with 19 Mr. Minton, is that right? 20 A. Yes. 21 Q. Was he talking to Mrs. Minton, was she 22 talking to Mrs. Minton? 23 A. I don't know. 24 Q. Did you ever talk to Mrs. Minton? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 527 1 Q. As far as you know, did she ever talk to 2 Mr. Minton ?? Mrs. Minton? I'm sorry. 3 A. I don't know. 4 Q. And you're not suggesting that as of this 5 point in time, where y'all had been authorized to 6 find a house, that Stacy had fallen in love with 7 Mr. Minton, right, you're not saying that, are you? 8 A. I'm sorry. I lost the question. 9 Q. You said that you had told Stacy a long 10 time before she told you that she was in love with 11 Bob Minton that she was already in love with Bob 12 Minton, you had already told her that, you said, 13 right? 14 A. Somewhere, yes. 15 Q. All right. I take it that's somewhere ?? 16 that's sometime after the Mintons bought the house 17 that you were living in, is that right? 18 A. Yes. 19 Q. Okay. Now, at this point in time, when 20 y'all are out looking, house shopping, neither of 21 you had ever met Bob Minton, correct? 22 A. Yes. 23 Q. So y'all go to this island and how many 24 days do you look for a house, how long does it take 25 you to find the dream house? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 528 1 A. Well, as I said, we had already made 2 several trips there. There had already been 3 several weekends prior, just prior to that, and 4 when I say just prior, I mean by a matter of a week 5 or two ?? 6 Q. Excuse me a second. 7 MR. WEINBERG: Ken, it's very distracting. 8 Stacy is at the end looking directly at 9 Vaughn. It's very distracting. She needs to 10 take a seat or go outside, one or the other. 11 All right. I insist that she take a seat at 12 the table like everybody else or she go 13 outside. 14 (Ms. Young left the room.) 15 MR. DANDAR: That distracts you? She's 16 at the coffee table. 17 MR. WEINBERG: She is looking directly at 18 the witness. It is distracting. It is 19 obstructive. Okay. She has gone out. That 20 is fine. 21 A. I wasn't looking at her. 22 Q. Well, you know what, Mr. Young, I'm sorry, 23 but if you're in this room, then one needs to be 24 seated unless they go up and get a drink. She's 25 been there for ?? you know, I didn't say anything SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 529 1 at first but she's been up there for a number of 2 minutes. 3 MR. DANDAR: It's the same as you walking 4 to get coffee ?? 5 MR. WEINBERG: No, it's not. 6 MR. DANDAR: ?? as you ask him a question, 7 you walk away from him to get a cup of coffee. 8 MR. WEINBERG: No, it's not. She's been 9 up there five or ten minutes, Ken. 10 MR. DANDAR: Who cares? 11 MR. WEINBERG: I care. I care. Okay? 12 She couldn't do that in a courtroom and she 13 shouldn't do it in the depo. 14 MR. DANDAR: She certainly could. She 15 certainly could. 16 MR. WEINBERG: She could stand up in the 17 middle of a courtroom and look at the witness? 18 MR. DANDAR: She's out of range of 19 everybody. 20 MR. WEINBERG: No, she isn't. 21 BY MR. WEINBERG: 22 Q. Now, Mr. Young ?? 23 A. Uh?huh. 24 Q. ?? how many days did you look for this 25 house? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 530 1 A. We probably spent four days beforehand and 2 then three or four other trips to Vashon 3 afterwards, and the delineating line being after 4 his call. 5 Q. Okay. And how many houses did you look 6 at, would you say? 7 A. Thirty. 8 Q. Okay. How many with the agent, or were 9 they all with the agent? 10 A. No. There was the first half of that, and 11 I think the first visit to Vashon, were all done 12 without an agent, and then somebody that we spoke 13 to said, listen, you know, this is a very small 14 island and the agents know everybody on the island, 15 and having never worked with an agent, I hadn't 16 really thought about it that much. So somebody 17 recommended this one agent and so we went there, 18 and that was for the last few excursions. 19 Q. And this house that was eventually bought, 20 was shown to you by the agent? 21 A. Yes. 22 Q. And the 30 houses were in the price range 23 of between 150 and 300? 24 A. I don't know the prices of all of them 25 because some of them you just go out there to see SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 531 1 them and you don't care if it's $50,000, it's just 2 ?? it's a piece of rundown junk. Did you get that? 3 Q. Yes. Eventually ?? did you make offers on 4 how many houses? 5 A. Just on that one. 6 Q. And you made the offer, is that the way it 7 worked? 8 A. No. Stacy picked it up at that point. 9 When we both agreed that this was an ideal 10 condition ?? there is not that much property 11 available on Vashon, so it wasn't a case of being 12 able to, I don't know, look for a long list of 13 places that would be capable of carrying a cat 14 sanctuary. 15 Q. Here's what I really mean. Was there a 16 negotiation that you and Stacy or Stacy had with 17 the seller? 18 A. I was not party to that. All I was party 19 to was I like this place, I agree, the property 20 looks good, it can be developed for this purpose, I 21 agree, take it over. 22 Q. Now, do you know if Stacy handled the 23 negotiations or somebody else did? I mean 24 typically what happens when you buy a house is you 25 make an offer. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 532 1 A. I don't know how it was done. 2 Q. Okay. You don't know if Stacy had 3 Mr. Minton's authorization to do that or not? 4 A. I don't know. 5 Q. Do you know if y'all paid asking price or 6 something less than what was being asked? 7 A. I don't know. 8 Q. Did you, after Stacy told you that she was 9 in love with Bob Minton, did you speak to Bob 10 Minton about that? 11 A. No. 12 Q. I mean you must have been angry. 13 A. Well, every breakup of a marriage ?? 14 Q. That's what I mean. 15 A. ?? hurts. 16 Q. I mean it made you ?? it made you 17 obviously unhappy, correct? 18 A. Yeah. 19 Q. It made you depressed? 20 A. That's too clinical for me. Unhappy is 21 enough. 22 Q. Well, did you express to your friends or 23 some friend that you had suicidal thoughts? 24 A. I ?? I've never been suicidal. 25 Q. Did you threaten that to Stacy? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 533 1 A. No. 2 Q. You never had any conversation with 3 Mr. Minton after ?? at any point in time about his 4 relationship with ?? his relationship with your 5 wife? 6 A. There was a conversation on the phones 7 several months later, after we had decided months 8 after on the divorce. 9 Q. Before or after you were divorced? 10 A. Before the divorce was filed. 11 Q. Between you and Mr. Minton? 12 A. Yes. 13 Q. He called you or you called him? 14 A. He called me. 15 MR. DANDAR: Can we get Mr. Rinder to quit 16 going in and out of the door? I mean how 17 destructive and disruptive is that, and 18 Mr. Rathbun. 19 MR. WEINBERG: Just stop. You're being 20 destructive and disruptive. 21 MR. DANDAR: Well, I think the sound will 22 pick up all the doors opening and closing. 23 MR. WEINBERG: Just stop, just stop, Ken. 24 All you're doing is disrupting this. It's in 25 the middle of his answer. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 534 1 MR. DANDAR: Yeah, right. 2 MR. WEINBERG: Yeah, right? It's what 3 you're doing. 4 MR. DANDAR: He's disrupting. 5 MR. WEINBERG: No, you're disrupting. 6 MR. DANDAR: He keeps distracting me 7 every time he comes in and out of the door. 8 It must be five times already. 9 MR. WEINBERG: You are being, as you 10 always are in these depositions, being 11 disruptive and destructive. 12 MR. DANDAR: I can't wait until we get to 13 the Lisa McPherson case. 14 MR. WEINBERG: I don't know, I thought 15 since Mr. Minton has given you $400,000, has 16 given your consultants hundreds of thousands 17 of dollars, I sort of thought that's what we 18 were talking about, Ken. 19 MR. DANDAR: No. We're talking about a 20 divorce. 21 MR. WEINBERG: No. What we're talking 22 about is people that have been paid and 23 bought. 24 MR. DANDAR: By the way ?? 25 MR. WEINBERG: Okay. Paid and bought. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 535 1 MR. DANDAR: ?? you failed to instruct 2 the witness at the beginning this entire 3 deposition is confidential and I want to know 4 who the hell is at the other end of this 5 Livenote because those people are subject to 6 this court's jurisdiction. 7 MR. WEINBERG: You heard ?? you heard 8 what Mr. ?? what Judge Moody said about 9 confidentiality. All right? So let's ?? 10 MR. DANDAR: This entire deposition is 11 confidential. 12 MR. WEINBERG: Oh, baloney. You heard 13 what Judge Moody said about that, and what 14 you're trying to do is keep ?? what you're 15 trying to do is your people, like Mr. Prince 16 and Stacy, go on the Internet and talk about 17 all this stuff, and then what you want to do 18 is when somebody comes, when one of your 19 people come in here and testify under oath, 20 you don't want anybody to know about that, do 21 you? Why not? 22 BY MR. WEINBERG: 23 Q. Now, Mr. Young ?? 24 A. Uh?huh. 25 Q. You had a conversation because you called SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 536 1 Mr. Minton, is that right? 2 A. No. I said he called me. 3 Q. He called you and he said what, I'm sorry 4 that I broke up your marriage? 5 A. No. He just said, hey, listen, you know, 6 sorry sort of the way things turned out, I never 7 really meant it, never meant that it would happen 8 that way. 9 Q. So that made you feel better? 10 A. Well, it was a matter between Stacy and me 11 and I just was like okay. 12 Q. Do you think he ?? I'm sorry. 13 A. I'm not in a position to bless or damn, 14 you know, anybody for their personal life, 15 especially Stacy, on that. So, okay, if it made 16 him feel better to tell me, that's what made him 17 feel better. 18 Q. Do you think Mr. Minton was as charitable 19 with his own wife? 20 A. I have no idea. 21 Q. All right. 22 MR. WEINBERG: Now, you know what, Ken, I 23 can hear you talking and I can hear Mr. Prince 24 talking. 25 Q. Now, did you have a financial settlement SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 537 1 with Stacy? Was there a settlement agreement? 2 A. I have a feeling that's a legal term, so 3 can we maybe break it down. 4 Q. Okay. When one goes through a divorce, 5 when one is divorced ?? there were divorce papers, 6 right? 7 A. Right, and that listed out what we ?? 8 Q. Your assets? 9 A. What she was taking, what I was taking, et 10 cetera. 11 Q. Do you have a copy of that? 12 A. No. 13 Q. Okay. And what were the amount of the 14 assets at the beginning of this year that you and 15 Stacy were dividing up? 16 A. Oh, I don't even remember. 17 Q. Well, give me an estimate. 18 A. I have no idea. 19 Q. Well, are we talking a million dollars? 20 A. If you want to be facetious, you know, I 21 feel like saying why not. Let's not be ridiculous. 22 I said I don't know. I was more interested in 23 being amicable and settling it out, you know. I 24 just said, God, do we really want to ?? because at 25 one point the attorney says ?? was getting into one SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 538 1 of these things, well, the couch goes to, and we're 2 saying no, no, it's not that kind of divorce, we 3 will work out, hey, honey, do you want the TV set 4 or do I take the computer. It was a case of 5 working out between friends. We didn't need to 6 list out every single item as to who gets the baby 7 crib. 8 Q. Right. I guess, you know, without being 9 ?? I'm not trying to be facetious. 10 A. When you say a million dollars ?? 11 Q. Well, I tried to start somewhere. You're 12 obviously much more charitable than I would have 13 been under those similar circumstances, but what 14 I'm asking you is was there any substantial assets 15 in this relationship at the time of the divorce? 16 A. No, not that I ?? not that comes to my 17 mind. 18 Q. Okay. Y'all didn't own any property, 19 correct? 20 A. No. 21 Q. You didn't own a house, right? 22 A. No. 23 Q. You didn't have any funds, any stocks or 24 securities, right? 25 A. No. SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 539 1 Q. Didn't have any bonds? 2 A. No. 3 Q. Did you have any cash in any accounts? 4 A. Oh, there was a few thousand dollars or so 5 in the checking accounts. 6 Q. So a couple thousand dollars? 7 A. Probably. I didn't really know at the 8 time. I'm just sort of guessing. 9 Q. Well, I mean any ?? what did y'all do, 10 split that? 11 A. It wasn't a matter ?? this may sound 12 strange to you, sort of like me doing a declaration 13 on my own initiative, but our attitude was, you 14 know, what do you need in order to help yourself 15 out, you know, even after the divorce papers, if it 16 said she got the computers and I wanted one, there 17 was not going to be any argument, you know: I'm 18 going to take off. Oh, well, how much money do you 19 need? Well, give me a couple thousand to ?? it was 20 that sort of, you know, between friends ?? 21 Q. Well, let me interrupt for a second. I 22 mean Stacy, obviously, through her relationship 23 with a multimillionaire, was not going to be 24 looking for where the next buck was coming from, 25 correct? SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 540 1 A. I resent your accusation to me. 2 Q. Well, I'm asking you. I mean did you 3 understand that Mr. Minton was going to provide for 4 her? 5 A. No. 6 Q. Isn't that what your understanding was? 7 A. No. 8 Q. Well, was there ?? did you receive any 9 cash in the settlement? 10 A. Other than ours? 11 Q. I'm talking about ?? well, we'll start 12 with that. Other than yours? 13 A. There was just our cash. 14 Q. And that was a few thousand dollars, 15 right? 16 A. Perhaps so. I didn't pay attention to it. 17 Q. Well, was it as much as $20,000? 18 A. No. 19 Q. Okay. Was it as much as $10,000? 20 A. I don't know. 21 Q. Well ?? 22 A. I said a few. I wasn't paying attention. 23 And there was a point in July when I took off to go 24 see Jesse and she had the bank account then, and 25 later on she said, here, you can have the rest of SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 541 1 the bank account. 2 Q. She gave you the rest of the bank account? 3 A. Yeah. 4 Q. And how much was that, approximately? 5 A. I think there was a few thousand in it 6 then. 7 Q. And when you say a few, you mean a couple? 8 A. A few is like three or so. 9 Q. Okay. 10 A. More. 11 Q. Now, other than the bank account, was 12 there anything else of any real value that was 13 divided up? I'm talking about monetary value, I'm 14 not talking about memory value. 15 A. Well, the computers, we had the computers, 16 which have always been our most valuable. 17 Q. Those were the old computers, right? 18 A. Yeah. We had picked up another one along 19 the way. 20 Q. Did y'all divide those up? 21 A. Well, I just took the laptop because I 22 wanted to travel and there was no reason to take a 23 desktop with me, so I just took what I needed. She 24 asked me if I wanted to have a PC and I said, you 25 know, I can't really carry it with me so I will SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 542 1 just take the laptop. 2 Q. Anything else? There was no car was 3 there? 4 A. No, not at that time. There was a car 5 that belonged to the foundation. 6 Q. What happened to that? 7 A. It stayed with the foundation, stayed 8 there. 9 Q. That's the one ?? the old van or whatever 10 it was that somebody donated to the foundation? 11 A. Yes. Yes. 12 Q. Where is that now? 13 A. I assume it's with the foundation. I 14 don't know. 15 Q. So that is it a fair statement that as of 16 February of 1999, the total value of the assets 17 that y'all had accumulated was in the single digit 18 thousands? 19 A. I don't know if there was value put on the 20 assets with the divorce. 21 Q. I understand. I'm not trying to argue 22 with you. I'm just trying to get some sense. It's 23 not a lot of money, it's not a lot of value, is it? 24 A. A lot is always, I've found, to be quite 25 relative. I don't know what the computers would be SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 543 1 worth at that point. 2 Q. All right. I will go through it with you 3 then. I was trying to make this easy. 4 A. The computers were what, $12,000 five 5 years before. 6 Q. Well, the laptop certainly wasn't worth in 7 1999 more than ?? I mean you can go buy a laptop 8 right now for what, 1200 bucks? 9 A. No. This laptop was pretty cheap. 10 Q. Okay. So we're not talking about, you 11 know, thousands and thousands of dollars worth of 12 personal property, right? 13 A. Perhaps. 14 Q. Well, did you sell any of it? 15 A. I didn't. 16 Q. Did you take any of it? 17 A. I took the laptop and put some things in 18 storage that I wanted to keep, which is more along 19 the line of personal memorabilia. 20 Q. And what other assets, personal property 21 was there? 22 A. There was furniture. 23 Q. That had been there for a number of years? 24 A. No. There was furniture that we had 25 either brought from West Seattle or had bought SCLAFANI WILLIAMS COURT REPORTERS, INC. LAKELAND, FLORIDA (863) 688?5000 544 1 while there. 2 Q. You mean like dining room furniture? 3 A. There was a dining room table we bought 4 because we didn't have one in West Seattle. There 5 was a bed frame that we had bought to switch the 6 bed around. There was ?? what are they called, the 7 things where you open the doors? 8 Q. You got me. 9 THE WITNESS: What? 10 MR. DANDAR: Armoire. 11 A. Armoire. I always have trouble with 12 that, which she kept her computer in that we had to 13 assemble, a couple little pieces of art that we 14 picked up on Vashon, small, that we enjoyed, not 15 expensive, small things. 16 Q. Jewelry, any jewelry? 17 A. No. That's one good thing about her, she 18 wasn't ever into jewelry. 19 Q. And that's pretty much it, what we've just 20 gone through? 21 A. Yeah, pretty much. 22 Q. And where is that stuff now, do you know? 23 A. I don't know. 24 Q. And you just, at that point in time,