Part 2 HERE

part 3 HERE

CASE N0: 99-7430-CI-08
a Florida for-profit corporation, 
DATE:	JULY 19, 2006
10:00 A.M. - 1:59 P.M. 
(727) 468-2002 1800-468-2003 FAX 727-468-2003 
A P P E A R A N C E S:
For the Plaintiffs:	ROBERT POTTER, ESQ. 
P.O. BOX 1358 
For the Defendant:	LUKE LIROT, ESQ.
Direct Examination by Mr. Potter........	4 
Cross-Examination by Mr. Lirot.......... 142 
Redirect Examination by Mr. Potter...... 145
E X H I B I T 
Plaintiff's	Marked for 
Exhibit No.	Description	Identification
1	Photo	47
2	Photo	52
3	Photo	52
4	Photo	53
5	Photo	55
6	Photo	57
7	Photo	57
8	Photo	61
9	Photo	62
10	Photo	63
11	Photo	66
12	Photo	67
13	Photo	68
14	Photo	69
15	Photo	70
16	Photo	70
17	Photo	71
18	Photo	71
19	Permanent Injunction	79
20	Clambake Website	122
21	Postings by Proflex	141
22	Photo	147
S H A W N	L 0 N S D A L E
Q.	Mr. Lonsdale, would you state your name 
for the record, please, sir.
A.	Shawn, S-h-a-w-n, Lonsdale, 
Q.	As I introduced myself earlier, my name 
is Bob Potter. I represent the Church of Scientology 
here today.
A.	Actually, you know what, could you do me 
a real big favor. I know Helena Kobrin and this 
gentleman and the two on the end, please.
Q.	Peter Mansell is sitting next to Helena 
and Mr. Mike Hargett is sitting next to --

A.	Can I use your pencil?
Q.	Next to Mr. Mansell.
A.	Actually, you know what, does somebody 
have an extra pen.
THE COURT REPORTER: There you go, sir. 
Q.	The purpose of today's deposition is to
ask you some questions about recent activity that you 
have engaged in.
A. Uh-huh.
Q.	If at any time I ask you a question that 
you don't understand, please let me know. I'll be 
happy to rephrase it or restate it. There's only a feu 
rules that we have to abide by. Number one, it's very 
important that we don't both try to talk at the same 
time. If we talk at the same time, it gets very, very 
difficult --

A.	Because we're using -- difficult for the 
Court Reporter.
Q.	Yes. So please try not interrupting me 
and I will try to avoid interrupting you. The other 
rule we need to kind of pay attention to is if you mear 
to say yes or no, it's very important that you say yes 
or no. If you say uh-huh or huh-uh, it's very 
difficult sometimes to understand what you mean.
Having said that, can you tell me what 
your address is.
Q.	510, 5-1-0, North Lincoln, L-i-n-c-o-1-n, 
Avenue, Clearwater, Florida.
Q.	And what is your occupation? 
A. Unemployed.
Q.	How do you make your living if you're
A.	Well, it's pretty hard, but I got a 
couple bucks saved up.
Q.	So you're currently living off of 
A.	Yeah. Actually I had a yard sale about 
-- I think it was about three weeks ago and that helpeD 
out a little bit.
Q.	When was the last time that you were 
A.	I'd say maybe five months, three months, 
three to five months we'll put it that way.
Q.	And what was your occupation when you 
were employed?
A.	I was a clerk at a title company, real 
estate title company.
Q.	And what sort of work would you do there? 
A.	Basic clerical.
Q.	And how long had you been employed there? 
A.	Six plus years.
Q.	Do you own the home that you live at out 
on Lincoln?
A. No.
Q.	Do you rent that home?
A.	Uh-huh (nods affirmatively).
Q.	Do you pay rent or do you otherwise --

A.	I would assume that a rental means that I 
pay rent.
Q.	Pardon me?
A.	Yes, I pay rent.
Q.	Do you pay rent in cash or do you pay it 
through work and services?
A.	Cash, yes, cash.
Q.	Who is your landlord?
A.	Joseph R. Critchley.
Q.	Where does Mr. Critchley live?
A.	Wow, I don't know actually. I think 
they're in town.
Q.	Where do you pay your rent?
A.	You mean the amount?
Q.	No. Where do you pay it? How do you pay 
it? Do you pay it --

A.	Oh, no. Yeah, I take it to their offices 
here in town.
Q.	You take it to his office? 
A. Yeah.
Q.	Okay. And where is his office?
A.	Down the street here. It's on -- it's 
right adjacent to the Church's sawmill or furniture 
Q.	The Church of Sawmill (sic)?
A.	The Church's sawmill.
Q.	The Church's sawmill?
A.	The name of the street is --

Q.	What's the name of the office, do you
A.	I just believe Critchley & Associates.
Q.	Okay. When did you first become familiar 
with Scientology?
A.	It's got to be a couple of years ago now.
Q.	And how was it you became familiar with
A.	Actually they became familiar with me, 
and that was -- I was doing a -- I went to a yard sale 
a long time ago, and I found this really neat --

actually that can -- that camera right over there. It 
was $5, and the poor lady assumed that it was broken 
evidently, and she was like, here, just five bucks. 
You know, I was like, you sure? And I mean I could se 
right on the side -- right on the base of it it had 
over a $200 lens on it, and of course I was under the 
assumption it was broken. So -- but sometimes with 
things like that, you know, you get to -- it may be a 
battery or something simple.
So I went -- took it to the store and
just bought a new battery for it and put a new battery 
in it and bingo, it worked. And I was like, wow, you 
know, so what am I going to do with this beautiful 
camera that I have. I mean, I'm a snapshot guy 
basically, you know.
So I took it back to her because it just, 
you know -- it just didn't seem right to get a 
five-dollar deal like that with her thinking it was 
broken. So actually she told me, you know, I don't 
care. It's somebody that had stiffed her on rent or 
something a long time ago, and she had found it in the 
possessions in preparing for a yard sale. So she goes, 
just do something good with it. I was like, well, 
So I went down to one of the only film 
places still in town. It's right next to the Hess 
station downtown. The name escapes me. But he had a 
lot of black and white film that he had cheap. So I 
was like, you know, maybe I can do some sort of 
artistic project with it. So in doing that I picked it 
up and I was like, you know, walking downtown and I'm 
like, what the heck am I going to do.
And the one thing at the time that stood 
out amongst everything downtown was the enormous 
homeless problem. I mean we had people sleeping on the
sidewalk right out in the open. I mean, it was really, 
really ridiculous. Actually living in certain areas 
and one lady I even passed by had urinated on herself 
and sat next to the street with a sign that said, help 
me, for three days running. And I was like, you know, 
this story needs to be told. You know, especially 
since a lot of charity groups in the area were trying 
to do their best, you know, in other areas to try to 
help the homeless.
And surprisingly enough, you know, in the 
downtown core, you know, with all the good supposedly 
that's going on down there, I didn't -- I didn't really 
see that anybody was actually helping these people. S 
I decided, you know, maybe if I could do some sort of 
project with it, I might be able to shine some light o 
the -- on the situation.
And in doing that I took like a crap load 
of photos thinking that maybe I could use one of these 
self-publishing deals on the Internet, you know, where 
you can make your glossy-covered book and you don't 
have to go to a big printing house to do it, and I was 
going to try to put it in a format that was easy to 
read with a paragraph on how the person might have 
gotten there, what their daily life that they perceive 
it now to be and how their future looked to them as
well. But in doing that I realized that, you know, a 
lot of these people are in real need of other help, you 
know, with substance abuse. Some of them actually are 
doing it because they prefer the lifestyle for some 
reason, but I guess maybe it's the freedom of it.
But anyway in doing that I was able to at 
least compile enough photographic evidence to take to 
one of the City commission meetings and present them
with the photos that they pass by every day on their 
way downtown and to go to offices and stuff and I was 
wondering -- I posed the question to them, Why isn't 
something being done about this? You know, this is 
what I have to pass by and live through every time I go 
down on a daily basis, you know. Why isn't this being 
taken care of, et cetera, et cetera.
And in doing that I noticed, of course, 
being downtown with a camera with a big lens on it I 
guess it was just a little too conspicuous for, you 
know, Church security not to notice. So I originally 
noticed a lot of security-garbed individuals around me 
on a regular basis, and I started noticing the same 
faces and white vans and stuff seemed to be around 
every time I was like going to my car or certain just 
out of the ordinary things.
And at first I was like, well, you know,
seeing as they occupy the majority of our downtown 
core, maybe there's really nothing to it. You know, 
maybe it's just nothing. And I didn't really know who 
the Church was at the time anyway.
So it was like, you know, here was this 
big organization which I knew was supposedly a church, 
but I didn't really know much about it. And of course 
in being downtown I tried to find some of their -- how 
would you call it. What do you call it when you go 
into a Christian church and go in for the services? 
What is that one -- is that the main church building 
for parishioners?
Q.	I'm not sure.
A.	Can somebody help me here? It's a 
worshipping center maybe.
MR. HARGETT: Fellowship hall. 
A.	Well, anyway, the church building where 
you go to receive your spiritual services. It's funny 
couldn't find one. And I was -- I was surprised that, 
you know, here was a church downtown that I thought 
maybe I could gain some more knowledge from and 
especially to answer my questions as maybe you guys are 
around or maybe I could notice some more faces that ha 
been following me and stuff, but I couldn't find like
their center for the general public.
And so I sort of let it sit on the back 
burner for a while, and was just content to do my 
homeless thing. But each time I was out it just
started to get more and more obvious, you know, the 
watching and then I noticed cameras. There were a lot 
of cameras downtown and stuff, and that sort of piqued 
my curiosity so I started looking into the Church of 
Q.	So you -- you felt that people were 
watching you?
A.	It was a suspicion, but it wasn't a total 
one. I mean, it was open to consideration of course.
Q.	All right. so as a result of that I 
think you said you started paying more attention to 
A.	Uh-huh (nods affirmatively).
Q.	What did you do --

A.	Well, I was just paying more attention to 
when I was downtown, seeing if there was really an 
overwhelming amount of it as the days mounted as I was 
down there of that attention.
Q.	Now, this -- this -- I'm sorry, let's go 
back to this camera for a second. Was it a snapshot 
camera or was it a video camera?
A.	It's sitting right there on the -- 35 
Q.	35-millimeter camera as opposed to a 
video camera?
A.	Yes, sir.
Q.	Okay. Approximately how many days would 
you say you were downtown photographing the homeless?
A.	Wow. Well over a thirty-day period. It 
was so long ago that it's hard to tell you exactly.
Q.	When you say it was over a thirty-day 
period, was it 30 days or was it a --

A.	Yeah. It was a continuous running 
project. I mean every time I'd have a free hour or a 
couple hours after work I'd go out and try to take some 
shots. Or every time I'd see a compelling scene, I 
guess I'd try to capture it.
Q.	And what happened with all these photos?
A.	Actually I presented them to the 
Clearwater Commission in attempts to have them go over 
them before I was to do a project with them. Hopefully 
they would be able to use them, you know, in some sort 
of a way to document, you know, the severity of the 
situation down there.
Q.	Now, you said you were going to do a 
project with them. Is this with the City Commission?
A.	No. With the photographs.
Q.	Oh, with the photographs? 
A. Yeah.
Q.	Did you end up doing a project with the
A.	No. I ran into too many financial 
problems at the time.
Q.	And were those financial problems related 
to developing the photos and --

A.	Yeah, that's where it got --

Q.	So were the vast majority of these photos 
developed or not?
A.	Yeah. No, I managed to get them 
developed, but in doing that it sort of wiped out my 
bank account pretty quickly which didn't really consist 
of much anyway.	But then of course the next step with 
dealing with those photos is getting them into the 
format that you need to present them in a 
portfolio-type situation so even that was a little more 
expensive and technical than I had originally thought. 
Because at the time I didn't have a computer or 
anything, so I was not really well aware of what it 
took financially to get something like that done, or 
technically I should say.
Q.	Did you develop them into a portfolio?
A.	No, pseudo portfolio.
Q.	So are you -- are these photos 
essentially in a stack, a stack today?
A.	A stack. Yeah. Well, they're divided 
into categories and stuff, you know.
Q.	Now, what was the attitude or reaction of 
the City Commission when you presented them?
A.	Basically they just -- the first -- the 
first time they just tried to pass me off on the police 
chief I think to try to get me convinced that they were 
actively involved in ongoing -- how did they put it --
not investigations, but ongoing problem-solving 
discussions in trying to do something with the downtown 
core and the homeless problem in it.
Q.	You said that that's the first thing that 
they did. What did they do ultimately?
A.	Of course, I inquired several times after 
that, you know, as to what was being done on a 
continuous basis, and they really didn't have much to 
say on that matter. They just sort of we'll get back 
to you.
Q.	Okay. And did you -- did you pretty much 
let the matter drop as a result of those communication 
or not?
A.	Yeah, pending. While, you know, I was
pending answers, and when you can't get any answers an 
you wait and you wait and you're continually told to 
wait. You can only wait so long before another 
interest or other things in life pop up that you need 
to take care of before such a project.
Q.	Okay. Let's go back to the Scientology 
subject. How -- How did this lead to your next 
involvement or your next interest in Scientology?
A.	Of course doing the study on what 
Scientology consisted of and stuff like that, I ran 
into a lot of stories also being put in the newspaper 
guess at the time and stuff about how the property 
downtown was a lot of development. Avenues were being 
explored I guess, so to speak, with the new --
including the now and finished Super Power Building or 
S.P. Building. I think that's how it's referred to. 
It's just been -- you know, it's an interest in 
Clearwater in general and reading the paper and stuff 
like that. You know, you just sort of get more 
involved in it as you read and do a study.
Q.	So you did a study of Scientology and was
that primarily through reading newspaper stories?	
A.	No. Reading newspaper stories. Some of 
their own paraphernalia. I had -- one of my landlords 
at the time was -- what's his name now. Imre, I-m-r-e,
Tozer, T-o-z-e-r. And we'd talk on a regular basis. I 
rented a house from him at the time at I think it was 
914 Lotus Path. I'm not sure if the number was 
correct, but it's something like that. You guys 
probably have the address.
He was relating a lot of old stories to 
me and stuff when he used to be part of the -- he was 
evidently head treasurer in East Greensted back in the 
day when L. Ron Hubbard was still alive and kicking. 
He would, you know, talk to incidents of -- or answer 
those questions, you know, of things that went on 
within the organization at the time, and a lot of 
financial problems that they were facing and in some 
cases even financial misdeeds that I found to be a 
little too curious for me not to look into.
So of course with his little short 
stories he piqued my interest and sort of got into it 
now that I knew somebody who was such a high-level 
member because supposedly he was OT-8 at the time, 
which is, you know, the top level. It takes many years 
and many dollars to get to it and it's supposedly 
secret. So I was of course more than interested.
So I went to the library and I picked up 
a copy of Piece of Blue Sky. I think Jon, J-o-n, 
Atack, A-t-t-a-k (sic). And in reading that, you know,
I came -- of course there was some time -- time-logged 
tales in it of certain periods within the organization 
before, you know, the split with the new leader. But I 
wondered, since he had been in the organization so 
long, that maybe he would be able to shed some light or 
whether, you know, this gentleman's tale in the book 
was, you know, historically correct or not.
So he came over to my house -- he came 
over to his house one day which I rented. And he came 
in and I was like, hey, you know, I was reading this 
book. And I was like do you know anything about, and I 
read him a couple of names that were mentioned in it. 
And he was like what are you reading from. And I 
showed him the book and he immediately freaked out, 
poor guy. I mean, he must be 70 something years old.
And he was like this is all garbage and 
"F" this and "F" that and what the "F" are you doing 
with this and what the "F" are you doing with that. 
And he just literally freaked out which, you know, is 
something I've been noticing. So a lot of these -- a 
lot of so-called or self-proclaimed high-level members 
that I've been bumping into on a recent basis, they 
seem to follow a same pattern of lack of control. Just 
an observation on my point, but -- and since the Church 
is in here they might want to do some studies of that,
Q.	What was the name of this book again that 
you mentioned?
A.	Piece of Blue Sky by Jon Atack. Actually 
if you'd like to read it there is a copy right in the 
Clearwater Library.
Q.	All right. So you read this book and you 
had some more conversations with Mr. -- was it with Mr, 
A.	Tozer, yes. He's an area landlord. He 
specializes in low-income properties.
Q.	Approximately what time frame is this? 
Was this recently or last year or the year before?
A.	Oh, this was -- yeah, this was right 
after the time period where of course I was doing the 
homeless project.
Q.	When was that, though, what --

A.	Well, I'd like to say two years ago, but 
I think it was a lot earlier than -- well, maybe not a 
lot earlier. The time frame of maybe three years I 
Q.	So you're talking 2003 --

A.	Yeah, you have a tendency --
Q.	2004 --

A.	Yeah. You have a tendency to say two
years maybe sometimes too long.
Q.	All right. So this -- when you read this 
book, was that around 2004, maybe 2005?
A.	Yeah. I would assume so. I'd have to do 
a little bit of research to find out when the exact 
dates and stuff, but we're in the ballpark somewhere.
Q.	You mentioned that you saw some -- you 
heard some stories about financial issues that you 
needed to look into?
A.	That I would -- that I'd like to look
Q.	My question was --

A.	Or needed looking into.
Q.	Did you look into those?
A.	Somewhat just, you know, as far as 
hearsay would be able to tell you, and instances 
like --

Q.	Well, what did you do to look into those?
A.	Actually I asked him a lot of questions 
since he was one of the head treasurers, which he 
revealed a lot of telling information about how the 
organization is structured as far as he knew, how many 
people were and were not paying their debts to other 
Scientologists or handing -- handling Scientology's 
financial angle I guess at East Grinstead, and I don't
know if that concerned, you know, money coming in or 
going out, course case structures, stuff like that. 
Q.	All right. Other than reading the book 
and talking to Mr. Tozer, what else did you do, if 
anything, to study Scientology?
A.	Basically I read everything I could find 
on it, which is way too diverse to get into technically 
here, but Church pamphlets. Of course, whatever I was 
able to glean from the Church angle from Mr. Tozer 
which was evidently an authority since he was such a 
high-level member, a public member I should say. He 
wasn't part of the guardian -- I mean, I'm Sea Org.
Q.	All right. Anything other than reading 
Church pamphlets, newspaper articles, the book and 
speaking with Mr. Tozer?
A.	Of course Internet connections at the 
library helped a lot, too, library research. They havE 
a lot of materials at the library of their own.
Q.	What sort of Internet connections would 
you refer to or read or study?
A.	Oh, geez, there's countless. Just 
countless Internet connections that you can read 
historic accounts on basically almost everybody that's 
out of the organization that was anybody.
Q.	Did you ever read any of the books that
were written by Mr. L. Ron Hubbard?
A.	Yeah, I read Dianetics. History of Man. 
And, you know, early on in life I think I read a couple 
of his sci-fi novels, but they were under a different 
Q.	Have you ever tried to join the Church or 
participate in the Church of Scientology?
A.	That's a serious question?
Q.	Yes, it is.
A.	Oh, okay. Absolutely not, no. I don't 
see why I would have to pay money for a spiritual 
Q.	Is that why you -- you say that that's 
not a serious question or you kind of laughed at it.
A.	Well, actually, yeah. I mean, it's been 
posed to me as a joke several times already. Maybe 
that's why I referred to it as maybe not being serious.
Q.	But you think it's a joke because it 
requires a financial commitment?
A.	Well, not only that, but it consists of a 
great deal of common sense. I mean, in order to pay 
for common sense, I mean, one would have to be -- have 
no common sense I would imagine.
Q.	Well, you're wearing a shirt that 
indicates a Scientology minister?
A.	I know, it's brand-new. Actually it does 
have a back to it.
Q.	Chicago Scientology Volunteer Minister?
A.	Yeah. And if you'll notice, it's 
actually an older version. Somebody sent it to me for 
good luck. The anonymous mail I get is just 
Q.	Well, normally if I see someone wearing a 
Scientology minister shirt, I would think that they 
were a member of that organization or a supporter of 
that organization?
A.	Good P.R.
Q.	Are you -- are you a member or a 
supporter of the organization?
A.	No. Obviously not.
Q.	Why do you wear the shirt?
A.	Basically to get your goat today. 
Q.	Get my goat?
A.	I thought a lot of people would find it 
ironic that I would wear such a thing.	I 

Q.	All right. So I take it -- I'm getting  
the drift that you're not a supporter of the 
A.	Well, if you mean I'm paying the money,
Q.	No, no. I mean from a philosophical 
standpoint you seem to have a disagreement with the 
A.	Well, no. I wouldn't call it a 
disagreement. They have a disagreement with me. I 
mean, people are free to follow whatever they want in 
life. I just think it would be rather criminal to try 
to hold that, you know, as an unknown to somebody in 
order for them to pay for higher enlightenment on a 
plateau basis. Like a pyramid type-scheme.
Q.	I'm sorry. I didn't understand what you 
meant by that.
A.	Well, why don't we go back to ask your 
question again.
Q.	Well, my question was do you have a 
philosophical disagreement with the Church of 
A. No.
Q.	Apparently you have a disagreement with 
some of their payment schemes or their financial --

A.	No. In my opinion I would -- I would 
think that anybody who was trying to find what they 
offered, you know, would be much more satisfied 
mentally and emotionally if they were to find it in a 
way which they did not have to financially have an
exchange for.	I
Q.	What's your understanding of the 
financial exchange that is required in Scientology?
A.	Well, in order to be anything or do 
anything in Scientology costs -- well, there are some 
levels that are common sense that you don't have to pay 
for, but those more or less lead you into stuff that 
you have to pay for, whether it be an exchange for 
services within the Sea Org. as an adult and, you 
know, foregoing possibly your children's higher 
education in a normal manner for -- or a normal life. 
Or it could be such a thing as being a public member 
and being involved in some sort of investment type 
deals, as well as paying for the courses that you need 
to take. Or you can even -- you know, there's several 
different ways to do it, but the ironic thing about it 
is none of them, you know, consist of being free which 
the majority of the major religions in the world tend 
to rely on.
Q.	So you object to that portion of 
A.	Well, I object to the fact that you can't 
learn it supposedly outside for free, yeah, according 
to the Church. I mean you can, but.
Q.	Now, recently -- when I say recently, I
mean the last six months, you apparently have been 
photographing the Church and Church people walking 
around the Church. Why have you done that?
A.	Why have I done that? 
Q. Why?
A.	I would like to refer to exhibit question 
mark over in the corner.
Q.	Well, I'd appreciate it if you would just 
tell me why you're photographing people.
A.	Well, that's the whole point of it. The 
funny thing about it is people kept asking me over and 
over why I was doing it, and it tended to be like a 
broken record. Because evidently nobody took that 
information and put it up lines, so to speak. So I was 
left to stand out on the street corner and do my 
business and have to field numerous calls to the police 
department of stalking and harassing from the Church. 
Even though in every single instance the reason why I 
was out there was made perfectly clear, not only to the 
police officer, but to their own security that I was 
doing a project.
So eventually I was like, well, you know, 
I've had it with that. I've had it with the fact that 
everybody supposedly does not know what I'm doing out 
here and has to resort to such underhanded tactics as
that rather than coming right now and saying, what are 
you doing, which they had done several times through 
other public agents I guess we'll call them.
Q.	But what --

A.	So I decided to come up with, you know, 
an easy-to-read board that described it all in one 
quick easy read.
Q.	Tell me what project you were working on.
A.	Cult Watch, Pinellas Access Studios.
Q.	Can you tell me what that project is?
A.	Wow, it's still morphing. I mean, it's, 
you know -- I guess you could call it a documentary, 
but the more I get footage, the more the whole basis of 
what it is changes. So I can't really -- it's a tale 
-- a tale of -- a tale of the Church in our community I 
Q.	What did the project start out as?
A.	I didn't start it out with anything 
specific. I knew I was going to do a project, and I 
was content to let, you know, the subject matter take 
me in a direction that it needed to take me to tell a 
story so.
Q.	When did you start the project?
A.	About maybe a year ago, maybe.
Q.	And what was your idea in terms of this
project when you started?
A.	That was the funny thing about it. I 
didn't really have an idea about it. I mean, it was 
something big in our community that needed to be looked 
at. Basically maybe that's the only thing.
Q.	And what -- what was it that needed to be 
looked at?
A.	Well, that was the specific thing I 
didn't have in mind. I mean I didn't have an idea of 
-- it's so broad and, you know, big it was like, well, 
how do you focus on one part of it or how do you focus 
even on it as a whole. You know, it's way too much to 
tell a story on.
So in order for me to maybe be taking in 
a direction scene as I was lost for a direction on it, 
I decided just to go out and try to get as much
factual background footage that I would be able to use, 
not using a story, knowing that, you know, some day it 
would fit in like with background or whatever. In 
doing that of course certain things, you know, 
presented themselves. It sort of took you in a 
direction of where the story, I guess you could say, 
put it or led it.
Q.	Did you discuss this project with anyone?
A.	Several people at work I think. I think
I might have -- people in passing if they asked what I 
was doing with the camera, but I think it was more or 
less something very vague.
Q.	If someone stopped and asked you what you 
were doing with the camera, what would you tell them? 
A.	Taking pictures.
Q.	If they asked you why you were taking 
pictures, what would you say?
A.	Working on a project.
Q.	If they asked you what project, what 
would you say?
A.	Well, the basis of it is unknown at the 
moment, but has to do with the downtown.
Q.	Were other people assisting you with this 
A.	No. That's the funny thing about being 
poor. Unless there's money in it, nobody wants to help 
Q.	At the time you were -- you started 
working on this project, were you still employed at thE 
title company?
A.	Yeah. Yes, I was.
Q.	So has the project changed over time?
A.	Oh, yeah, many times. Actually, you know 
what, can I get a refill?
Q.	Sure. Can you tell me how the project 
has changed over time?
A. Specifics? 
Q. Yes.
A.	I think it's way too complex to get 
into. I don't think I can even relate for myself. I 
guess -- I guess I have so much going on with it that 
it's so hard to remember even some of the instances 
involved with what --

Q.	Would you give me a general overview of 
how it's changed --

A.	Turns, you know, and when -- well, early 
on of course it was security. They seemed to be very 
interested in me on a daily basis. And then the more 
interested they got in me, the more interested of 
course I got as to why they were interested in me. So 
after awhile I just sort of said, well, I can't really 
be bothered with what other people are thinking about 
it. I just got to go try and do what I need to do to 
get enough background shots and stuff like that that 
are unhindered. And that's one instance that's 
The next would be of course all the 
countless police complaints on me over and over again. 
That took a long period of time. Then, of course, it
changed with -- wait a minute, you know what. I did 
have a spot in time where I -- I had -- I thought I waE 
going to be able to do a specific segment on a couple 
of missing people. And I made up a quick missing 
poster. The two people on the poster were -- who were 
they now. Warren McShane and Marty Rathbun.
MS. KOBRIN: Marty Rathburn? 
THE WITNESS: R-a-t-h-b-u-n. 
A.	Those were the two. I thought I had a 
copy with me here today, but I guess I don't.
Q.	And these were people -- these were 
missing people?
A.	Well, you know, there was an Internet 
rumor that they were missing.
Q.	Missing from where?
A.	Missing from their post at the Church of 
Scientology and I believe it was Hemmet.
Q.	What's hemmet? Is that a person or a 
A.	Actually it's one of the compounds that 
they have in I believe it's California. Actually maybE 
a couple of the Church representatives might be able tc 
elaborate on that. But there was a rumor that Marty ir 
particular was down here at the sawmill and maybe doinc
like -- I think they call it the RPF, although I think 
they changed that to Estate Project Forest, one of 
those things.
Q.	What do you mean by RPF?
A.	I think it was short for Rehabilitation 
Project Forest.
Q.	Why were you interested in Marty being at 
the sawmill and doing an RPF?
A.	Let's put it this way. If I'm taking --
if I'm out there taking photos and stuff, getting a 
picture of a missing person would be like a really goo( 
angle to a story. You know, I mean it could be 
something that maybe I could use as a story.
Q.	And the fact that Mr. Marty Rathbun is 
missing is based upon an Internet rumor?
A. Yeah.
Q.	And I'm sorry. He's missing from his 
post is what you said?
A.	At the time both of them were.
Q.	What does that mean, missing from his
A.	Well, he was former number two in the 
Q.	Mr. Rathbun or Mr. McShane?
A.	I think Rathbun was former number two and
McShane was former number three. Actually I think 
Helena right next to you knows both of those 
individuals personally. Maybe she can shed some light 
on the fact that maybe they are or aren't missing since 
I was never able to.
Q.	Well, you learned from Internet postings 
that they were potentially missing from their posts.
A.	Internet websites put up there with 
supposed information that they were missing.
Q.	This would be their posts from within 
Scientology, correct?
A.	Evidently there was a lot of people 
claiming that they had inside information of the fact 
that these people were missing seeing as the Church - 
a lot of Church disseminators, or that's what they 
would call themselves, and critics, tend to like to sa5 
that they monitor all sorts of activity by the Church 
as far as the Internet goes and their policies and 
their new material that comes out, and essentially it': 
a lot of insiders basically that feed the outside. But 
in doing that the rumor came up that the Church was 
starting to take his name off of, you know, a lot of 
the Internet websites for some reason.
Q.	And why did you feel that that was a 
potential story or something of interest?
A.	Why? Geez, okay. Let's say the vice 
president is missing, all right, and he happens to be 
rumored to be down two miles from you, you know, in a 
work camp environment. And you just happen to be doinc 
a story, you know, on downtown or the area and entitieE 
in the area. Don't you think that might be something 
little too juicy that you can't -- wouldn't ignore 
something like that? This was too good to not check 
out. So, you know, I mean it was so close. If it was 
something that was in another state or something like 
that, yeah, I would be like, yeah, so what, you know, 
Q.	I take it that the rumor that Mr. Rathbun 
was missing was not a police report or a report from 
his family?
A.	Actually there has been several police 
reports filed evidently in the origin -- originating 
state. Although as far as I'm able to tell nothing wa: 
ever made about it. And supposedly also both of their 
wives filed for -- filed for divorce, I think even on 
the same day in California. And it's funny, but they 
weren't able to find their husbands to serve the paper: 
on them at the time.
Q.	Is it your understanding that any law 
enforcement personnel are looking for Mr. Rathbun?
A.	If they aren't, they certainly should be. 
I mean, the guy has been missing almost a year now, 
unless of course the Church can cough him up to dispel 
some of these rumors.
Q.	Did you -- did you -- did you report to 
the police that you had heard that Mr. Rathbun might be 
at sawmill?
A.	Of course not. I don't have any 
firsthand information of that, no. If I did, I 
definitely would have.
THE COURT REPORTER: You're going to have 
to let him finish his question.
A.	Oh, I'm sorry. Was I doubling up on him?
Oh, ok.
Q.	That's one of those rules that we talked 
about --

A.	Yeah. Actually, you know what, if you 
were to put your finger up and when you're done, if yo 
were to go like that, it might help me a little bit 
Q.	I'll try that. We just have to be 
cautious, and she hopefully will remind us because she 
notices it before you and I do.
All right. So did you -- did you do
anything further in terms of trying to locate Mr. 
A.	Of course. And being of interest of it I 
tried to put out, you know, a feeler in the community 
which consisted of both of their pictures and a brief 
description of their rundown and a brief message of the 
people that were -- might be looking for them, 
concerned members of their family possibly. And I went 
downtown with them and passed a couple of them out in 
the local restaurants.
Q.	So you put posters together or something,
A.	Yeah, uh-huh. I figured that would be a 
good way to find out whether, you know, any of them 
were around or not. Get some good leads.
Q.	You said that you had put out feelers in 
the community. What does that mean?
A.	That -- that's what they consisted of.
Q.	That's what you meant by feelers?
A.	Yes, those were feelers.
Q.	And you passed those out in restaurants?
A.	Actually, no. I took them to a 
restaurant and asked if the people would put them in 
their window.
Q.	Did they?
A.	Yeah, I think several did.
Q.	Did you speak to any of the members of 
Mr. Rathbun's family or Mr. McShane's family?
A.	Actually, I tried several times to 
contact them, and each time came up a dead end.
Q.	They refused to speak to you or you were 
not able to make contact?
A.	I was not even able to make contact with 
them surprisingly enough. Of course, you know, there'E 
only so much you can do by mail.
Q.	Let's go back. You mentioned that -- I 
had asked you to walk me through how your project had 
changed. The first thing you said was security. 
Apparently at one time your focus changed to security 
or that's what the original focus was?
A.	I never had that focus.
Q.	Okay. When you said that the project had 
changed and made reference to security, what were you 
talking about?
A.	They changed it by stepping up I guess or 
the constant haranguing of security.
Q.	The constant haranguing?
A.	Yeah. Like -- you might even call it 
harassment, you know.
Q.	How did they harass or harangue you?
A.	Every time I was downtown I was getting 
these strange calls to the police from Church security 
saying that I was like harassing people in some way, 
doing that type of stuff, stalking people.
Q.	Do you believe that you ever harassed
A.	No, absolutely not. I took great pains 
to be in -- not only in view of their own Church 
security cameras, but to be in public view at all 
times. Public streets.
Q.	And while you were in these public areas, 
what were you physically doing?
A.	Filming sometimes, sometimes reading the 
paper, sometimes not filming at all. Just enjoying the 
downtown area.
Q.	When you say filming, were you taking 
still photographs with the camera or were you taking 
A.	First the still. I didn't have video at 
the time.
Q.	And at the time that you were taking 
these photographs, did any security person ever ask you 
why you were taking the pictures?
A.	Directly, security? 
Q. Yes.
A.	I think there were a couple of instances,
Q.	And what did you tell them?
A.	That I was doing a project.
Q.	Did you tell them basically the same 
thing you've told me here today?
A.	No. They would immediately, I don't 
know, for some odd reason become scared at the fact 
that I might be either taking pictures of them or 
something and would immediately cut contact once the 
first sentence was said so. They seemed to be scared 
of the lens for some reason.
Q.	When they came over to talk to you, would 
you take their picture?
A.	Oh, absolutely.
Q.	Why would you do that?
A.	I have to document things like that in 
case something were to happen, or if I was to have 
somebody bear false witness against me, I'd at least 
have a face to put to a name to and maybe tell the 
story of what happened, you know, during the situation 
Q.	All right. You mentioned that your 
project has changed over time from security, from 
police complaints and to missing people. Any other 
changes or revisions to the project?
A.	Well, here we go again. Well, it was 
just more of that type of weird stuff. I mean I was 
just trying to get a hand on where the whole thing was 
flowing as far as the result of putting the posters out 
got me four death threats for God's sake on a phone 
number that I provided. So -- I mean that's a telling 
part of the story. That takes you in an area that you 
don't originally intend on.
Q.	Tell me about the four death threats.
A.	Well, I perceived them as being death 
threats because they were along the lines of, you know, 
you're going to get hurt downtown, things of that 
Q.	Well, tell me -- people have called and 
left messages on your phone or what?
A.	No. Actually it was on a cell phone that 
number that I had provided.
Q.	Tell me what happened.
A.	In one instance a person told me that he 
was from my cell phone provider, and they needed to 
re-update my information and needed me to go ahead and 
give it to them. Well, I told the gentleman that, 
well, you should already have it so why don't you read 
it to me and I'll tell you if there's any changes on 
it. And he must have been a high-level member because
there he goes, you know, somebody snapped and it was --
he started cussing me out, and said, you know, you're 
going to be six feet under if you continue this stuff. 
We know who you are. Then it was a hang-up. 
Unfortunately, you know, the cell phone I was so 
financially strapped at the time, you know, of course 
can't do things like trace phone calls and things like 
that. The cell phone I had couldn't even record. That 
was one of them. The other one was, of course, you 
know, if you continue this downtown, you'll I think 
they said be hurt.
Q.	This is another phone call?
A.	Yes. Another one was vans hit people 
downtown every day, I think was the specific message. 
You should be careful crossing the street.
Q.	What was the fourth one?
A.	I don't remember the specific words, but 
the gist of it was you don't live very long in this 
town doing things like you're doing, something like 
Q.	And do you know who any of these phone 
calls were from?
A.	Absolutely none of them.
Q.	All right. We're going back to the 
project. We've talked about security, police reports,
missing people, death threats. What else has your 
project encompassed?
A.	What has it encompassed? All sorts of 
stuff. Mostly visual, though. I mean, it's so broad 
it's hard to -- it's hard to explain what you mean -- I 
mean what you want the information for. Can you be a 
little more specific or --	' 
Q.	Well, I'm simply trying to find out what ! 
your project is and I'm having a hard time --	I
A.	Same here. Just imagine if I knew.	'
Q.	It's your project, though.	,
A.	It would be up on the screen. The story 
is yet -- still to be finished, you know. This is part 
of it so. Basically, you know, the whole gist of the 
thing now -- of course it's morphed so much it's become 
this, you know, that since I didn't have a story it's , 
more or less I'm a static entity holding a camera, youl 
know, and whatever happens happens. You know, if
certain people feel offended by that or by the -- in II' 
the instance of Exhibit A, Cult Watch, which evidently 
is a big stickler in this town for some odd reason,	' 
then that's their prerogative. But, you know, at the 
same time I can't go out there with a predetermined 
story, you know what I mean. It would be too unfair tc 
an individual whom, you know, might become part of the
story line. So I have to let others do their talking 
and their walking for me so.
Q.	Now, some of these pictures that you have 
taken you've posted on the Internet, correct?
A.	For the project?
Q.	Sir, I have no idea if it's part of your 
project or not. I'm just asking you if some of the 
pictures you've taken apparently you've posted on the 
Internet, is that correct?
A.	Yeah, but what do you mean by pictures? 
I mean any pictures?
Q.	Have you posted pictures that you have 
taken on the Internet?
A.	Sure, yeah.	'i 
Q.	Can you tell me why?
A.	Why? I can answer that with a why not. 
For the same reason somebody takes a picture I guess, 
so people can see it.
Q.	Is posting pictures on the Internet part 
of your project?
A.	Not necessarily. It could be part of it 
I guess.
Q.	Have you -- have you photographed 
pictures of Church staff or Church parishioners? 
A. Yeah.
Q.	Have you posted them on the Internet? 
A. Probably.
Q.	Again why?
A.	Probably to describe the scenario or some 
sort of scene that might involve my project.
Q.	Do you feel that that's of interest to 
A.	Oh, obviously.
Q.	Who is of interest to?
A.	The general public I would assume.
Q.	Why do you assume the general public is 
interested in Church members, pictures of Church 
A.	Because they're a newsworthy item at the
Q.	Why are they a newsworthy items?
A.	It depends whether you read the newspaper 
or not, and there's untold millions of different ways 
that they could be newsworthy.
Q.	Can you give me one?
A.	One? The assault on me downtown. That 
was by a Church member. That's a newsworthy article.
Q.	So have you posted a picture of that 
A.	Oh, definitely.
Q.	Have you posted pictures of individuals 
that were not involved in that assault?
A. Yes.
Q.	Why were those people's pictures 
published or posted?
A.	Well, some of them they might have been 
witnesses to it.
Q.	What about people who were not witnesses 
to the assault, have you posted any of their pictures 
on the Internet?
A.	Yeah. I think I already answered that 
Q.	And, again, that's because you feel that 
those people are newsworthy for some reason?
A.	Yeah. This whole town and the relation 
to Scientology and the inner workings in Scientology 
and who follows it and what their exposure or not 
exposure to the general public or freedom of 
information or freedom of the First Amendment, all that 
relates to why I posted the pictures. Guess that's wh~ 
I didn't play basketball.
Q. Huh?
A.	Missed the garbage can with my piece of
Q.	Oh, well, it's gum.
A.	I was like that's why I never played 
basketball. I wasn't good at basketball. I had a pack 
of gum around here somewhere. Did somebody steal it? 
You're not sitting on my gum, are you?
Q.	No. I can assure you I'm not sitting on 
your gum.
A.	This is too weird.
(At this time Plaintiff's Exhibit No. 1 
was marked for identification.)
Q.	Let me hand you a picture that I've 
marked as Exhibit Number 1, sir. Is that a picture 
that you posted on the Internet?
A.	Yeah, it sure is.
MR. LIROT: May I see that?
MR. POTTER: Yeah. I've got a copy here 
for you, Luke. Go ahead. I have an extra one 
here, but I just haven't pulled it out here for 
Q.	Is that -- why is that picture 
newsworthy, sir?
A.	Well, because I went to the Clearwater 
City Commission prior to that picture being taken, as 
well as some video, and inquired as to whether or not

Part 2 HERE

part 3 HERE