Part 1 HERE

part 3 HERE

or why the famous S.P. Building or Super Power Building was not finished out there. I think it's now three ant a half years past its completion date. And in doing so I also mentioned that, you know, the outside of it looked like it was deserted, and it was -- put it this way, the grounds weren't landscaped and it was actually an eye sore. Can I keep that or do you want that?

Q. No. It's going to become part of the deposition. So tell me again why this is newsworthy?

A. Well, because the other part of the story reveals that after that the City again inquired as to why the Church seemed to find itself at such a position. that they didn't need to abide by their original -what do you call it when somebody -- oh, permit. The original permits had expired on the piece of property and such and evidently being such a big property owner in the area, I know the Church usually prides themselves on the fact that their properties look nice. And I was wondering, you know, why the Church felt that -- obviously that this one didn't deserve the same attention seeing as it was such a big project.

So I was like to the City, I'm like, you know, what the heck is going on here? We've got first of all the project is three and a half years past due. Of course some of the numbers I had received or looked

into on the Internet as far as donations went way past the original 40 million dollars I think was their stated completion price. And of course I was like plus it doesn't -- you know, the outside is just like they had the iron -- they had these big gates up, these big chain link fences that were falling down. And they had old plywood and stuff like that that was in some part of the facade. It was just laying -- I mean it just looked terrible.

So I mentioned to the City, you know, can we get them maybe to do something out there. And of course in doing that their response was, you know,

we're trying to get the City -- I mean, we're trying to get the Church to be a better neighbor downtown. So I was like well that's good enough for me I guess and blah, blah, blah. I just wanted to raise my opinion or it.

And in doing so I decided to, you know, of course, go out and see what the progress, if any, was -- if the progress was going to be made and sure enough, I was downtown keeping an eye on the piece of property. And they had four -- I think it was four -four teenaged girls doing the landscaping which was like in the hot sun. It was laying sod. I mean it was planting plants. It was hard work for me. I mean, I

used to do landscaping, and I was like wow, this is an awful telling scene. Why would they need to have teenaged girls out there doing this? Don't they have landscaping crew that's maybe a little more ruggedly able to handle such a, you know, long-term project. Because obviously it took I think even a month to get all the grass in and stuff.

But once they were in the process of doing that I noticed this poor elderly lady. She's evidently part of the grounds crew and has been for quite sometime. And -- and right before this photo was taken, I was talking to her actually, and they probably) have the footage if you need it. I was talking to her right on Fort Harrison and I was asking, you know, why -- actually I pointed out to the fact that it did -- it looked a lot better than it used to, and also I wanted to know why she was watering in the middle of the day. You know, if you know anything about landscaping, you should never water in the middle of the day because the droplets that are left after you water, you know, they become magnification glasses basically on the grass and it burns them rather than -- anyway.

We shot that idea back and forth and stuff, and I thought it was awful telling also that now, you know, she has the -- she didn't seem in very good health. She seemed awful old to be out there doing that. So I thought, you know, maybe somebody needs to document this just in case she has a heart attack or something out there. You never know. You know, I'd hate to see somebody disappear like that, you know, without having any pictures to say that this is what the person was doing. And as you can see in this photo I think she's -- by the looks of it she's got to be in her upper '60s. You know, and here she is pushing a full wheelbarrow in the middle -- in the hot sun.

And I think I -- this was the second time I had stopped by the scene. The first she almost looked, you know, as if she was able to collapse because she wasn't in the shade or anything. And I was like well, maybe it was the end of her shift or something. I came back later on and sure enough she was still out there in the hot sun. So then -- that was a couple of hours later. So I was like somebody has got to at least take a picture of this scene.

Plus, she was right out in public property right out in the middle of the street anyway. As far as I know, I wasn't invading anybody's property by doing that.

The funny thing about it is I saw her last week. And it looks like she has this big cancerous growth right underneath her chin, and I'm wondering if maybe during this deposition we can shed some light on the fact that maybe she might need some medical attention. It wasn't there then and that wasn't too long ago. And for something to grow to a golf ball size on the side of your basically chin area or lower jaw area, I think that maybe, you know, something might need immediate attention.

(At this time Plaintiff's Exhibit No. 2 was marked for identification.)


Q. Let me hand you what I've marked as Exhibit 2 which appears to be a photograph of the same lady -

A. That was probably two seconds after that.

Q. Can you tell me what's newsworthy about that photograph?

A. Just another photograph in the series. This shows that she was able to make it across the street on her own validity. There's even some better ones than that.

(At this time Plaintiff's Exhibit No. 3 was marked for identification.)


Q. Let me hand you what I've marked as Exhibit 3. Can you tell me what's interesting or newsworthy about that photograph?

A. The amount of people crossing the street.

Q. Was that also a photograph that you posted -- is that a photograph that you took and posted?

A. Evidently.

Q. And why is the number of people crossing the street of interest?

A. Well, if you'll notice, they're the only people in the street and for a semi-thriving downtown core, I find that awful telling that there would only be a certain amount of uniformed individuals crossing the street when it was obviously at a heightened point during the day. I mean, the sun seems to indicate that it was early afternoon the way the shadows are placed. So I would assume there should be a lot of shoppers and stuff downtown. So actually you could say that it alsc points to the desertion of our downtown for anything except Scientology parishioners.

(At this time Plaintiff's Exhibit No. 4 Was marked for identification.)


Q. Let me hand you what I've marked as Exhibit 4. Is that a photograph that you took and posted on the Internet?

A. Oh, yeah. Hey, that's Ben. This is particularly newsworthy.

Q. And why is that physically newsworthy?

A. Well, because prior to this picture Ben had the common sense enough to say some pretty nasty words to me in Clear -- or in Coachman Park during a - I think it was an L. Ron Hubbard-sponsored -- although he's dead -- L. Ron Hubbard-sponsored Easter Egg Festival I think they do every year. This one actuall) had Elvis in attention -- in attendance, as well as several celebrities which I consider Ben to be one of.

Q. Why is this particular photograph newsworthy?

A. Well, he's a spokesman for the Church. It's a good little scene of him holding court.

Q. Isn't that sitting outside the Starbucks coffee shop?

A. Yes, on a public sidewalk.

Q. How is that Mr. -- how is that Ben holding court?

A. He's like a celebrity, what are you kidding me.

Q. He's a celebrity?

A. Sure.

Q. Where is he a celebrity?

A. He's a celebrity in the newspaper every time you have a story about Scientology. Hey, the Church holds him up to that. I don't. If he was a nobody, I probably wouldn't have taken the photograph, but since he's somebody. Plus he's a former G.O.'s office member, you know what a G.O.'s office is.

Q. Tell me about the conversation at the park. You said he had the common sense to say something to you about -

A. Yeah. You know it's the funny thing about Ben, you know, I thought he was such a level-headed individual, but when he saw me out there with a camera, you know, documenting the great Easter day they were having out there and I was having out there, as well as the kids and everybody else in Clearwater, he seemed to find it just totally too -too attractive to ignore to come up to me and try to actually verbally harass me I believe. Said something to the words of, Don't ruin it for the kids, in a very, very mean tone. I guess it pretty much it was more or less how he presented it to me rather than...

Q. So it was the tone more than the words that you found unpleasant?

A. The tone and the accompanying facial expressions, yeah. Actually I might need a refill on that.

MR. POTTER: Let's take a break.

(At this time a brief recess was taken.) (At this time Plaintiff's Exhibit No. 5 was marked for identification.)


Q. All right. Let me hand you what I've marked as Exhibit 5, sir. Is that a photograph that you took and posted?

A. Probably, although there's been so many I can't -- I would assume it would be.

Q. And can you tell me, sir, what is newsworthy or interesting about this picture?

A. Actually it's one of the individuals who was making -- I don't know if you would call it stalking or not, but he was very interested in me for long period of time.

Q. Is he a person that you associated with security?

A. Yeah. Judging by the uniform and the overladen security belt, I would assume he was security.

Q. Why do you say that he was possibly stalking you?

A. Well, he paid me a lot of attention when I would be out with the camera and stuff.

Q. Did you ever speak to him?

A. No, I don't think he ever was directly close enough for me to speak to him.

(At this time Plaintiff's Exhibit No. 6 was marked for identification.)


Q. Let me hand you what I've marked as Exhibit 6. Did you take and post that picture?

A. Actually I think that's the same picture.

Q. I think that's a slightly different picture.

A. Actually it appears like the same one to me.

Q. You could be right.

A. Actually it's not as good a quality. Didn't change the ink in the printer.

(At this time Plaintiff's Exhibit No. 7 was marked for identification.)


Q. How about the picture that I have marked as Exhibit 7. Did you take and post that picture?

A. Yeah. Actually I think that's the same person later on.

Q. And why did you take that picture?

A. To establish, of course, that he was security for the Church.

Q. Why are you establishing that he is security for the Church?

A. Well, because he was particularly interested in me on an almost constant basis earlier. I would, of course, need to know who he was.

Q. Why?

A. Why? Wouldn't you like to know who people are that dress like security officers downtown that are watching you intently?

Q. I assume they're security officers. A. For who?

Q. Who did you assume they were security for?

A. Of course the Church, but I can't just jump to conclusions.

Q. You think that Photograph 7 and Photograph 6 are the same individual?

A. Actually I believe so.

Q. Are they in the same location or different locations?

A. No, different locations.

Q. Did you have to follow this individual from the position -- from the location in Exhibit 6 to the location in Exhibit 7?

A. No, but they appear to be dressed the same, carrying a bag. They appear at first glance to be the same person.

Q. Were these pictures taken on two different days or were they taken moments apart? A. I have no way of knowing that.

Q. Why did you follow the individual from the location of Exhibit 6 to the location in Exhibit 7' A. Why did I follow him?

Q. Yes, sir.

A. I don't remember saying that I did?

Q. You took the two pictures, didn't you?

A. Yeah.

Q. You necessarily had to get to two locations, did you not?

A. Yeah, but I don't see anything suggesting that they're even on the same day.

Q. Okay. I take it you were at the location in Exhibit 6 when you took the photograph?

A. Actually, you know what, you might want to look at the shadows in the photographs because they don't even appear to be in the same time period so I seriously doubt they would be.

Q. So this would be the same -

A. The same night and the same day.

Q. Do you believe that this is the same individual on two different days?

A. I'm just saying it looks like it would be. I mean, they look similar in body size and uniform. They're both carrying what appears to be a bag of some sort.

Q. Can you tell me why -

A. -- he's got a tool belt on.

Q. Can you tell me why you photographed this individual on two different days?

A. Security, he's a security guard. Some of the same security guards that are supposedly the ones that are responsible for the stalking and harassment charges that were erroneously called into the police o numerous occasions.

Q. Did these two photographs help establish that those were erroneous calls or erroneous claims?

A. They could. That's still as yet to be determined.

Q. How would these two photographs help establish that those claims were erroneous?

A. Well, because somebody on the police force -- I mean, somebody on their security force lodged those complaints.

Q. How do these two photographs demonstrate that those claims are erroneous?

A. Well, it depends on the day.

Q. How does it depend on the day?

A. Because if it depends on the day, it depends on where they called from. And if they called from a certain area, they would be -- further to be determined whether these persons were in close proximity to the areas in which those calls were made. So they could be one of many people actually, but the only way to narrow that down is to take pictures of security.

(At this time Plaintiff's Exhibit No. 8 Was marked for identification.)


Q. Let me hand you what I've marked as Exhibit 8. Did you take and post this photograph?

A. Uh-huh (nods affirmatively).

Q. Did you mean to say yes?

A. I'm sorry, yes.

Q. And can you tell me why you took that photograph?

A. Another security guy.

Q. Can you tell me why that was important to you?

A. Because he could be another one of the guys that were making these accusations via telephone or radio.

Q. And you posted this on the Internet as well, correct? I'm sorry?

A. I would assume so, yeah. It looks like he got it from the Photo Bucket, yeah.

Q. And can you tell me why that was newsworthy to the general public?

A. Well, because you have a private security officer on a public street going back and forth betweer probably Scientology properties. That's newsworthy.

Q. Why is that newsworthy?

A. I don't know how many other security officers you see downtown. That's the question.

Q. So that makes it newsworthy?

A. Of course.

(At this time Plaintiff's Exhibit No. 9 Was marked for identification.)


Q. Let me hand you what I've marked as Exhibit 9. Did you take and post this photograph?

A. Yeah. Actually I think that's the same guy. Yeah, it goes like this. This one was first.

Then it goes to this one.

Q. Number 9 is first and Number 8 was later?

A. Yeah.

Q. Were those taken on the same day?

A. Yeah, probably. Judging by the shadows,


Q. Were those taken moments apart?

A. Probably, yeah.

Q. Can you tell me why you took two photographs moments apart of the same individual?

A. No. Probably wasn't sure that one of them was focused or something.

Q. And again, why is this of interest to you?

A. It's newsworthy. He's one of the security officers.

Q. So any security officer would be newsworthy?

A. Oh, absolutely.

Q. Would that be any security officer of any organization or just security officers for the Church?

A. Well, it depends on how many security officers are out in public making calls to the police on the Church's behalf that I was stalking or harassing people.

Q. Were you stalking or harassing these gentlemen?

A. Not that I'm aware of. You might want to ask them, but.

(At this time Plaintiff's Exhibit No. 10 was marked for identification.)


Q. Let me hand you what I've marked as Exhibit 10. Did you take and post that photograph? Is that the same guy?

A. Yeah, it's the same guy.

Q. Did you take that photograph?

A. Obviously.

Q. So now we have three photographs of the same individual on the same day, is that correct?

A. Uh-huh (nods affirmatively).

Q. I'm sorry. Did you mean to say yes?

A. Yeah, I'm sorry. Yes.

Q. So why are you taking three photographs of the same guy on the same day moments apart?

A. Why not? First of all I don't -- the only one I do see a broad face shot of is this one. SC the other two could be anybody.

Q. Is there any reason that you took the picture from the rear of the person as opposed to the front of the person?

A. In these two cases probably because, you know, sometimes it's not a good -- it's not a good idea to run into somebody's face and stuff like that.

Q. Why do you say that?

A. Because sometimes it's -- people are quite uncomfortable about it.

Q. Do some people react to that?

A. I suppose.

Q. Would you anticipate that some people might react to that?

A. It depends on the individual, but, no, not usually.

Q. But in this particular case is that why you took the photograph from the rear of this individual because you did not want to provoke a reaction?

A. No. I just don't -- it was -- no, basically I don't think it was -- because I couldn't have gotten ahead of him to get his face properly. Seeing as he was already down the street.

Q. Did you say anything such as excuse me, sir, may I take your picture?

A. No. It looked like he was out of range for voice contact.

Q. How far -- what range is -

A. It looks like 40 yards or so, 30.

Q. Was this taken with a telephoto lens or a standard -

A. Well, seeing as the telephoto lens is the only lens I have, it would obviously had to have been.

Q. I thought you had a 35-millimeter lens?

A. Well, that's the camera.

Q. Does it have a telephoto lens on it?

A. You tell me.

Q. You're the photographer.

A. Yes, it does. Sitting right on it.

(At this time Plaintiff's Exhibit No. 11 was marked for identification.)


Q. Let me hand you what I've marked as Exhibit 11. Did you take that photograph?

A. Yes.

Q. Can you tell me why?

A. Security guard.

Q. Did you post that picture on the Internet?

A. Uh-huh (nods affirmatively).

Q. Did you mean to say yes?

A. Yes.

Q. And why did you feel that that picture was newsworthy?

A. He's a security guard. The newsworthy angle with security guards is that they have such a high presence downtown and of course, you know, the specific -- the specific relation to me in general seeing as every time I'm downtown with a camera, I get some sort of police response to somebody accusing me from the security department of like harassing and stalking individuals. Although they never, you know, are saying I'm stalking security. They always have some unknown person that I'm stalking that they're unable to give a name or a face to.

(At this time Plaintiff's Exhibit No. 12 was marked for identification.)


Q. Let me hand you what I've marked as Exhibit 12. Did you take that photograph?

A. Uh-huh (nods affirmatively).

Q. Did you mean to say yes?

A. Yes.

Q. Why?

A. Another crowd shot of downtown Dunedin -I mean downtown Clearwater.

Q. Why is that of interest to you?

A. Well, if you look at the picture, there is no other pedestrians in sight.

Q. And why is that of interest to you?

A. Why is -- why is that of interest to me?

Q. Yes.

A. Well, I don't know any other downtown you go to where there's -- there's got to be 85 people in this crowd, all uniformed individuals, all appearing tc be going in one direction only. And nobody else is on the streets in a thriving downtown community supposedly. So that would be the reason for taking it (At this time Plaintiff's Exhibit No. 13 was marked for identification.)


Q. Let me hand you what I've marked as Exhibit 13. Did you take that photograph?

A. Uh-huh (nods affirmatively).

Q. Did you mean to say yes?

A. Yes.

Q. Why was that photograph of interest to


A. Actually I think this particular gentleman had voiced several words to me actually.

Q. Is that why he was of interest to you?

A. That and he was a security person.

Q. What words did he voice to you?

A. I think he had -- he had yelled something at me a couple of weeks prior to that. It was along the lines of, you need to get out of here or something like that, which was followed by another assault or stalking complaint.

(At this time Plaintiff's Exhibit No. 14 was marked for identification.)


Q. Let me hand you what's been marked as Exhibit 14. Did you take that photograph?

A. Uh-huh (nods affirmatively).

Q. Did you mean to say yes?

A. Yes.

Q. Why did you take that photograph?

A. Security.

Q. Is it the same individual that's in photograph 13?

A. Well, I can't tell because his back is turned in the second one, but it appears to be a similar likeness.

Q. And why did you take two pictures of that individual?

A. I have no idea.

Q. Did you post that picture?

A. I would assume so.

Q. And why did you feel that that was newsworthy?

A. For the same reason as all the others, Scientology security.

(At this time Plaintiff's Exhibit No. 15 was marked for identification.)


Q. Let me hand you what I've marked as Exhibit 15. Did you take that picture?

A. Uh-huh (nods affirmatively).

Q. Did you mean to say yes?

A. Yes.

Q. Why did you find that to be of interest?

A. Same as the rest, security.

Q. Security?

A. Yes.

Q. Did you post that picture on the Internet?

A. Sure.

(At this time Plaintiff's Exhibit No. 16 was marked for identification.)


Q. Let me hand you what I've marked as Exhibit 16. Did you take that photograph?

A. Yes.

Q. Why did you find it to be of interest?

A. It appears to be almost the same as the one previous to it.

Q. And why was it of interest to you?

A. Security.

Q. And did you post that picture?

A. Yes.

(At this time Plaintiff's Exhibit No. 17 was marked for identification.)


Q. Let me hand you what I've marked as Exhibit 17. Did you take that picture?

A. Yes.

Q. Why was that picture of interest to you?

A. Security.

(At this time Plaintiff's Exhibit No. 18 was marked for identification.)


Q. Let me hand you what I've marked as Exhibit 18. Did you take that picture?

A. Yes.

MR. FLASTERSTEIN: I don't think we have Exhibit 18.


Q. I know. I'm getting it for you. I'm sorry, did you say yes?

A. Yes.

Q. And why was that picture of interest to you?

A. It's another one of the Church of Scientology's unfinished projects.

Q. What's unfinished about it?

A. Well, if you were to look at the color photo and actually some of the other exhibits you're probably going to give me you'll see plywood in the windows, that it's a decrepit looking structure.

MR. POTTER: Sorry. It's my only copy.


A. Sits supposedly for a long period of time now for -- I don't know. It's supposed to be used for another purpose, but of course that has yet to be

realized. Aren't there any more exhibits?

Q. Oh, I have some more.

A. I was going to say there's one of the -I think I posted some of the plywood in the windows. Actually I think they even have some pictures that I posted of what appears to be the interior of the unfinished Super Power Building or the interior of somE sort of building that's housed in the first -- I believe it's only the first level of this building.

Q. Have you posted all the pictures that you have taken or just some of the pictures?

A. Some of the pictures.

Q. And what about the pictures that you have not posted, what have you done with them?

A. Nothing, actually.

Q. Are they part of your project?

A. Yeah. Actually the reason for taking pictures -- well, due to the fact that also saves videotape is to create a story board so maybe you can get a better aspect of the whole scenario, like properties, security, who's and what's scenarios. You can get a broad look at what you might want to use to tell a story.

Q. Now, you mentioned that you had originally obtained some amount of black and white filn from the store in downtown Clearwater. Is that the

same film you're using or have you acquired more film? A. Most of these were color, yeah.

Q. Where were you getting the money to buy the film and to buy -

A. Well, it's funny I bought 80 rolls of 35-millimeter film for 10 cents apiece at one of these close-out stores on Missouri Avenue.

Q. Then what about developing it?

A. Incredible. When you develop them, the good thing about developing now is I can take a roll of 35-millimeter film and get it put on disk. I don't

have to get the individual photograph printed. And to get a disc made up it's like 5.65 and that's, you know, forty -- 35 pictures.

Q. Do you have any -- any people that are funding your efforts or helping you financially?

A. I wish.

Q. In your project? A. No.

Q. Are you -- do you expect to receive any payment for your filming that you're engaged in?

A. Oh, absolutely not. That's half the reason why, you know, Pinellas Access, I mean. I got everything as far as the credentials and the help and the use of all these facilities for free so I couldn't ever possibly try to gain money for doing it, you know. That just wouldn't be right.

Q. Now, more recently you've began videotaping, have you not? Pardon me?

A. Yes.

Q. How did you get the -- where did the video camera come from?

A. Pawn shop.

Q. Did you -- did you purchase it?

A. Yes.

Q. Did you purchase it with your own money?

A. Yes.

Q. Did anybody assist you in purchasing that equipment?

A. No.

Q. And what about the videotape that you used to shoot that video, where does that come from?

A. No, it's cheap, I bought it. You can buy it like three and four packs I think for ten bucks.

Q. And then what, if anything, are you doing with that videotape?

A. Nothing at the moment.

Q. Is that part of the project?

A. Oh, I still have to sift through it and see what exactly I have and what I can use for certain things to tell the story, whatever story remains to be told.

Q. Is it your intent to tell this story through some sort of videotape or video movie or something or film?

A. Yeah. There's a half-an-hour spot and I plan to run a series on Pinellas Access, Channel 96.

Q. And when -- when do you plan to do this?

A. As soon as I'm financially able to.

Q. Do you have to pay for access to the -

A. No. For Pinellas County residents you take a free 10-week course and -- or it depends if you don't want to use the -- one of it's the remote course which is just for the remote cameras. One of it's a studio course. The remote course is -- I think it's three weeks of one day a week and it's for three hours and they teach you how to use their remote cameras. And the other one is a studio class and they teach you how to use studio facilities, the cameras and how to put up a story and how to basically put a show on.

Q. Have you taken those courses -

A. Yes.

Q. Have you begun to use what you have learned in those courses to put together some sort of-

A. Well, it depends on what you're trying to do. I mean, they try to help you out if you're doing like a traditional show. Like there's some shows where you would want to put like maybe four people on a panel and discuss a subject. There are some shows where you would just want to show public scenes. Like that

one guy has a show called Gulf Boulevard. Excuse me. And he just shows nothing but people out on the boardwalk and, you know, Pier 60 and things going on or the beach.

Q. My question is have you started to produce a movie, have you started to put together -have you begun editing your videotape -

A. Begin editing? Not yet. I don't have the technical ability yet.

Q. I'm sorry?

A. I don't have the technical ability yet.

Q. And I assume that if you are successful in putting together some sort of a film or video you'rE going to display it through Access Pinellas?

A. Oh, yeah, yeah.

Q. Do you intend to distribute it any other way or fashion?

A. You'd probably be able to find it on the Internet somewhere, but it would be not for profit, though.

Q. Is your movie going to consist of just the videotape and the pictures that we've been talking about here today or -

A. It depends. It depends on where it goes. This is part of it. It depends. I might use some of this footage, I might use none of this footage.

Q. Have you talked to other Scientologists or non-Scientologists about the film or the process of putting it together?

A. I'm sure at some point in time.

Q. Who have you talked to?

A. It depends on what you mean who have I talked to. I mean, if I've just discussed it as a means of trying to solicit information to put it or get it done properly, or have I just mentioned it offhandedly in other conversations or if a person was even a Scientologist because I have no proof that some of these people are even Scientologists that I've talked to. It's hard to mean what you -- it's hard to determine what you mean by that.

Q. Have you talked to anyone about your project and getting them to help you with your project: A. Getting them to help me, no.

Q. Have you asked any people about their views of Scientology?

A. Yeah, I'm sure many. I imagine, yeah.

Q. Have you asked anyone to help you with your film, your project?

A. It depends what you mean by help.

Q. Well, what do you mean by that? Have you gone to anyone and said, hey, can you help?

A. Not that I remember, possibly. It depends on what -- I don't know, it depends what you mean by help. I've never asked anybody for technical help like as far as helping me put it together or putting it on the air or anything like that.

Q. How about for financial help? A. No.

Q. Are you collecting unemployment or anything like that right now?

A. Unemployment, yes.

Q. So you've got some savings that you mentioned and you've also got unemployment compensatior. that you're receiving?

A. Uh-huh (nods affirmatively). I'm sorry,


Q. Any other sources of support -

A. No.

Q. Friends, family?

A. No.

Q. Do you have -- do you solicit donations or anything over the Internet?

A. No.

Q. Do you have like a Pay Pal account that you ask people to deposit money into to support your endeavors?

A. No.

Q. Let me hand you a copy of the permanent injunction. We'll mark that as -

A. Is this the same as this one?

(At this time Plaintiff's Exhibit No. 19 was marked for identification.)


Q. It most likely is. We'll mark it -- let me mark it as Exhibit 19 so that I don't lose track of it.

Now, that document was served on you by my office I think last week, is that correct?

A. Yes.

Q. I guess you have that copy in front of you?

A. Yes.

Q. Prior to my office serving that document upon you, had you previously seen it?

A. Had I previously seen this document?

Q. The injunction.

A. No.

Q. I direct your attention to the very first page where it lists the names of the people. The first name it lists as a defendant or a respondent, rather.

It's the Lisa McPherson Trust, Inc. Have you ever had any dealings with the Lisa McPherson Trust, Inc.?

A. No.

Q. Do you know what it is or what its purpose was?

A. Sort of, I think.

Q. Tell me what you know.

A. I think back in the day of Lisa McPherson's death these -- I think it was Mr. Minton had some sort of a business in town for this to - actually I don't even know what it was for to tell you the truth. It was for -- the only thing I know that they did was protest I think.

Q. Were you ever a part of their protest?

A. No. Actually I don't even think I was living here at the time. I think I was living in Dunedin.

Q. How about the next name, Jesse Prince, do you know Jesse Prince?

A. Only from what I've read on the Internet.

Q. What do you know of Jesse Prince?

A. That he was part of some sort of protest down here and that he was a former high-level member I think.

Q. How about the next name, Grady Ward, do you know Grady ward?

A. No.

Q. How about the next name, Robert S. Minton, Jr.?

A. Just from what I recognize on the Internet.

Q. What do you recognize on the Internet about Robert S. Minton, Jr.?

A. Just that he was involved in these protests I think back in that period of time. I think it was '99 or 2000 or something.

Q. How about Stacy Brooks, do you know her?

A. Just from that she was part of it, too. These people are actually shown on a lot of videotapes from Xenu TV, X-e-n-u TV.

Q. Have you ever spoken to Stacy Brooks?

A. No.

Q. Have you ever had -- exchanged e-mails with her?

A. No.

Q. Have you ever exchanged postings with her on any Internet posting site?

A. No. Not unless it was somebody that I didn't know as Stacy Brooks.

Q. How about Jeff Jacobson, do you know him?

A. Just from what, you know, I've seen on the Internet.

Q. Again, what have you seen on the Internet about Mr. -

A. Videos. There's videos from I guess those protest periods of him on the street.

Q. Have you exchanged e-mails with Jeff Jacobson?

A. No, not that I know of.

Q. Have you exchanged Internet postings with Jeff Jacobson?

A. No.

Q. I take it you've never met Jeff Jacobson face to face?

A. No.

Q. How about Patricia Greenway?

A. Have I ever met her?

Q. Do you know Patricia Greenway?

A. Well, it depends on what you mean by know. Yeah, I met her so I guess I do know her in a way.

Q. Okay. When did you first meet her?

A. Actually it was about two weeks ago. I think it was two weeks ago. I was right before my -while I was on the street out there in downtown.

Actually I didn't know who she was at first, though, so.

Q. Well, tell me how you met her. Did she walk up and say, hi, I'm Patricia Greenway or -

A. Yeah. Well, no, she didn't say that. Her and Peter walked up and they said, hi. We read about -- I think they said we read about you in the paper or something -- or read about what you're doing, something like that. And, of course, at first I thought I recognized I guess Peter. His face looked very familiar. But I thought at first he was a town official for some reason. And a gentleman that was actually handling me. He was a Scientologist that had been out there handling me for several days prior to this event by the name of -- what was his name again. He puts on a production on Pinellas Access. Ron Savelo, S-a-v-e-1-o. He is a fellow producer. Actually he produces all the Scientology programs on Pinellas Access. I think there's six of them now.

Anyway, he was down here and -- he had been harassing me for -- I don't know if you want to call it harassing or not since -- well, yeah, I guess you would call it harassing. He was verbally cussing at me in my face and saying things like he was going tc keep my show off the air, and what my problem -- what': my problem and all this stuff.

Anyway, that had gone on days with this guy. But these two, I guess Patricia Greenway and Peter Alexander happened to walk up as he was doing it. And she -- before she even said a word to me, Patricia, at the time I didn't even know who she was. She said, Why are you bugging this guy? Why don't you just let him -- leave him be. Don't you have anything better tc do, something like that. And he was -- he got in theiz face in a very -- actually a very rude way and was like what the hell, what the "F" is your problem. You need to just keep on going. Which I guess Peter -- Peter Alexander took offense to and stepped up as if to say, hey, you don't talk to my girl like that or something. And Patricia sort of separated the two and I was telling Ron, because I didn't know who these two people were, but I recognized Peter's face. I thought he was a town official.

I was like, geez, dude, you know, you just stepped into the wrong face, you know what I mean because I thought he was assistant mayor or something,

I don't know. I thought he was a higher position in the city somehow. And the way -- the way he immediately attacked him verbally I was like, oh, great, you know, this is just -- dude, why you got to -- you know, this is the general public walking up to the street corner that I happened to be on, you know, and one of the -- one of the very own producers of the place that I'm doing -- you know, my show to be aired on has to jump into these unknown people's faces and g on like that. I was just like oh, dude, man, you don' know what you're doing, you now, just chill out.

And anyway, they were like, we're going to go across the street and we'll talk to you later an blah, blah, blah. And of course at the time I didn't know who they were. So they went across the street an I guess had a cup of coffee at Starbucks or something. Then I think it was maybe an hour or two later they came back over after Mr. Ron Savelo was done with me and asked me out to lunch actually.

At the time I was like well, that's nice, but I don't really know who you are. And they were like my name is -- and I was like, yeah, well, I recognize the names, but -- for some reason. And they were like well, we're the producers of the Prophet. And I was like oh, the Prophet, of course. You know, the Prophet was a very well-known attempt at putting i out a movie based on the whole story of Scientology I believe.

I think during the -- during the Lisa McPherson years it for some reason was not allowed to be released or it was only limited release. There was some sort of injunction on it I think. I don't know i this is it. I don't think this is it. But for some reason it was not able to be released on a grand scale after an initial showing or something like that, but it's rumored on the Internet to be a pretty telling piece, but nobody has been able to really see it so. recognized the Prophet, though. I was like, oh, wow. You know, maybe -- yeah, sure, I'll go to lunch with you.

Q. Now, did you go and have lunch with them?

A. Yeah.

Q. What did you talk about?

A. Basically the movie. I was -- you know, that and actually -- the funny thing is we -- I guess Peter is an ex-member and we discussed -- I can't remember what level he was at, but I had -- I had a copy of -- well, a supposed copy off the Internet of one of their higher levels which is called OT-8, and actually we were describing a very weird part of it. In part of their confidential student briefing it was actually a read for those of you whose Christian toes, I may have stepped on let me take the opportunity to disabuse you of some lovely myths. For instance -Q. What are -- what are you reading?

A. We discovered a -- we discussed a paragraph in OT-8 that actually L. Ron Hubbard supposedly wrote that goes on to say, for instance, thE historic Jesus was not nearly the sainted figure he'd been made out to be. In addition to being a lover of young boys and men, he was given to uncontrollable bursts of temper and hatred that the belied the genera: message of love, understanding and other typical macabre P.R. You have only to look at the history of his teachings inspired to see where it all inevitably leads. And I thought that was, you know, since he was supposedly a former high-level member that he could shed some light on that whole part of it. Because I was wondering if that was, you know, was, of course on( of the higher teachings in the Church.

Q. What is it that you're reading, sir? Is this a -- what is that?

A. Some of the stuff we were discussing at the -- at the lunch.

Q. Okay. Slow down a little bit. You've gone way ahead of me. This is something that Mr. Alexander wrote or Mr. Hubbard wrote or someone else?

A. Supposedly Mr. Hubbard wrote and I was just, you know, seeing as I had a higher -- supposed former higher-level member in front of me I was just asking, you know -- we were discussing whether it was actually true or not, you know. If this type of stuff was something he had seen or was it even in the Prophet and stuff, you know.

Q. The stuff that you were reading or referring to, is that something that you found on the Internet or -

A. Yeah.

Q. Okay. And you asked Mr. Alexander at lunch?

A. About any -- if he had seen it.

Q. Did you show this particular document to him?

A. Actually I think I did. Well, I think I had it with me. I'm not sure if I showed it to him or not.

Q. All right. So you asked him about the document, the wording, and you asked him if it was accurate, is that correct?

A. Yeah. Well, if he had -- yeah, if he had come in contact with it or not.

Q. And what was his response?

A. I don't think he had been at this level. He didn't say he recognized it. Of course we discusse Xenu which is evidently the secret of OT-3.

Q. Well, let's -- let's stick with one thing at a time. There's the thing that you were reading before was something I think you said you found on the Internet. Was that a yes?

A. Yes, I'm sorry, yes.

Q. And your understanding is that that's a writing of Mr. Hubbard or not?

A. Yes. Well, supposedly, depending on -put it this way. I didn't -- I haven't bought it or attained the level within the Church itself to see if that's what they would have given me if I was to get tc such a level.

Q. You're saying that it's supposedly a writing of Mr. Hubbard?

A. Uh-huh (nods affirmatively).

Q. Upon what basis do you make that statement?

A. On what former members that have been on the level and have said in relation to it I guess.

Q. What former member has told you that that's a writing of L. Ron Hubbard?

A. Actually not one in particular. There's far too many to ever be able to give you a specific name.

Q. And are these communications that you've received through the Internet?

A. Received, no.

Q. Well, you understand that this particular document that you just read is an L. Ron Hubbard writing, correct?

A. Supposedly.

Q. And you understand that it's his writing upon information that you have received from I think you said former Scientologists?

A. That had posted in other areas on the Internet, yes. Not that I had received.

Q. That's my question. You received this information through postings that you have seen on the Internet, is that correct?

A. Not postings, but other people's sites I should say. Other Scientology-related sites, ex-Scientology-related sites or critical Scientology-related sites.

Q. Is it fair to say that you've learned about these writings through the Internet and things that you have seen on the Internet or read on the Internet?

A. Yes.

Q. Do you have any knowledge as to the authenticity of the writings?

A. Personally, no.

Q. Now, I think you said that you also discussed something else with Mr. Alexander and I forget now what it was.

A. Xenu story, of course, which is another one of the supposed secrets I guess in OT-3.

Q. Again, did you ask Mr. Alexander if he ,

was familiar with that or aware of it?

A. Yeah.

Q. Did he have any information to share on that?

A. No.

Q. What else did you discuss at lunch?

A. The Prophet. What they, you know -- how technically the process -- you know, how the process -how they came about and did the process technically. I was just sort of trying to find out more about the video making -- the movie-making process and who they were and stuff like that.

Q. And did they provide you that information?

A. Yeah, pretty much.

Q. Were they helpful?

A. No. Because it's not really the same -doing what I'm doing and doing what they did as a moviE isn't -- doesn't even closely resemble it.

Q. How is it different, though?

A. Well, first of all, they did a full-fledged production, movie production. This is basically home camera stuff, you know what I mean. I'n not at even close to the level where I would be able tc use anything that they would have used in a movie format. Put it this way, I mean, it's like a kid playing catch with his dad in the front yard as opposec to a professional ballplayer going out every Friday ant playing, you know, big league games in the stadium. It's just two totally different realms.

Q. Did they offer you any of the materials that they had acquired to their -

A. Oh, no.

Q. -- film productions?

A. Their area I think was more or less a production that they put on that re-told the story, you know what I mean. So the stuff that they dealt with

isn't -- isn't like the realty genre that, you know, I'm shooting for. It's more or less props and stage setups and stuff like that they're specifically doing to tell a story rather than just letting the story tell itself.

Q. Did they buy lunch?

A. Yes.

Q. Have you had any other conversations with a them?

A. A couple times on the telephone concerning, you know, what on earth this was all about since they were named in it, but...

Q. Tell me about those conversations.

A. Just that why would they -- why would the Church assume that I was part of it for some reason.

Q. And what did they say?

A. They have no idea why that would be.

Q. Have they in any way encouraged you to continue your activities?

A. Encouraged me?

Q. Yes.

A. Well, yeah, I guess. They were like, you know, verbally encouraging.

Q. What did they say?

A. Well, they said, you know, don't -- the worst thing you can do with the project is drop it. It's always good to finish the thing you start and stuff like -- even though sometimes you may be in the middle of something that seems too big for you to tackle or you run into problems that seem insurmountable, you know, it's about finishing the stuff you start basically anyway.

Q. Did they offer you any financial assistance or financial help in continuing the project? A. For the project? Patricia gave me a

hundred dollars. I

Q. And what was that for?

A. I think it was for editing help if I needed to buy any software or something like that for my computer. I didn't have that -- I didn't have any of that stuff to edit on, my own editing.

Q. And did you use the hundred dollars to buy editing equipment?

A. Actually I did.

Q. What did you buy?

A. A fire wire card.

Q. What is that, is that a card -

A. In order to -- in order to download digital video on your computer you need a certain type of connection. And my computer hadn't -- didn't come with it so.

Q. So you bought that and put it into your computer?

A. Uh-huh (nods affirmatively).

Q. Does that now give you the ability to -to download, what, video?

A. Digital video. Supposedly, but I don't have the memory. I don't have the memory to hold it. Your system needs to have a lot of memory to process i and edit it, you know, and hold it so you can leaf through it and stuff like that. But seeing as my computer didn't come with it originally, it obviously didn't come with it originally for a reason because it didn't have the memory to support it.

Q. Was the cost of that card approximately a hundred dollars or -

A. Yeah, I think it was $80 -- 88, 80 plus tax. So it was pretty close to a hundred bucks.

Q. What kind of computer do you have?

A. Actually it's a clone. It doesn't have like a specific name on it. It's -- I forget what the referred to it as. It runs a Windows XP system, I know that.

Q. When did you obtain it?

A. When I left my former employer.

Q. When did you leave your former employer?

A. Whenever my termination date was.

Q. When was that? You know better than I do.

A. You would think so. It was like I think four months ago.

Q. I'm sorry.

A. It was like around four months ago.

Q. And why did you leave?

A. Our business was no longer there to sustain my position.

Q. Were other people let go at the same time?

A. No, I don't believe so.

Q. You say you obtained the computer at that', time, is that correct?

A. Yes.

Q. Did you buy it or did you take it with you from your employer?

A. My employer said I could have it and gave it to me. It was an extra that they had in the closet so.

Q. You mentioned that Patricia had given you a hundred dollars. How about Peter, did Peter give you any money?

A. No.

Q. Has Patricia given you any other money other than a hundred dollars?

A. No.

Q. You had lunch with them. You met them on the street corner. You had lunch with them and you said several phone calls, is that correct?

A. Uh-huh (nods affirmatively).

Q. Was that a yes?

A. Yes.

Q. And the phone calls were about the injunction, is that correct?

A. Yes.

Q. Did you discuss anything else in those phone calls other than the injunction?

A. No.

Q. And how many phone calls were there?

A. I think approximately three by the time I received -- I think the first one was this. Each time I received a serving. I think the original one was this.

Q. So when you see the injunction, did you call them or did they call you?

A. Actually I called her.

Q. How did you get her phone number?

A. She had called me when I wasn't home, and it was on my call waiting or call log on my telephone.

Q. And what was the purpose of her call to you?

A. Just to see how I was doing and how the project was progressing. I think she had probably seer the Bay News 9 article -- I think it was the Bay News piece on the guy who assaulted me downtown.

Q. All right. So she called you after she read about the assault?

A. I believe so, yeah.

Q. Did you speak to her or did she just leave a message?

A. The first time she just left a -actually she didn't leave a message. She just left -the number was on my caller ID and the name.

Q. Did you call her back?

A. Yes.

Q. When you called her back, was that before or after you had been served with the injunction?

A. After.

Q. Okay. Tell me about that conversation.

A. Basically I think I asked her what -what was it about and why are they -- why -- seeing asi i I didn't think it was in the -- even the LOH -- Lisa McPherson Trust, rather, didn't exist any longer and why they would be serving me with something like this. Because her name and Pete's name were on it.

Q. And what did she tell you?

A. That she didn't know either. And assumed that it was some sort of -- had something to do with me filming out there.

Q. How long did that telephone conversation last?

A. A couple minutes.

Q. What was the next telephone call?

A. I think it was when I received the second thing that you guys sent me.

Q. Would that be the subpoena?

A. If that's what it was. Yeah, the subpoenas were duces tecum.

Q. And why did you call her?

A. Wondering what it was, why would they -because they were named on it.

Q. What did she say?

A. That it probably had something to do with me recording, and you know.

Q. What did she suggest you do, if anything?

A. She didn't know actually because since I wasn't named on it she didn't think I would need to do anything. But of course I'd need to look into that for myself, so.

Q. And did you look into that for yourself?

A. Tried to. I mean there is so many avenues you can punch up on the Internet. Sort of told me what a deposition was about and stuff, but.

Q. What did you do? Did you look for information on the Internet?

A. Yeah. Just for reference as to what a subpoena for a deposition meant, what type of deposition it could be, you know, stuff like that. What you have -- what some of the rules are involved and what they consist of.

Q. Did you talk to anyone other than looking on the Internet?

A. Talk, no. Couple of friends maybe.

Q. All right. The next -- was there a next phone call with Miss Greenway?

A. I think the last one was when I got the videotape one.

Q. What did you-all talk about that time?

A. Well, if it was -- she knew that I could videotape it or not and it was -- if she knew I couldn't videotape it.

Q. And what did she tell you?

A. She thought I could.

Q. What did you do after that?

A. Nothing.

Q. Did you contact Mr. Lirot at some point?

A. Well, yes.

Q. Did you contact him or did he contact you?

A. Actually I contacted him. I had found his phone number on the Internet and realized that he had an'office here in Clearwater and gave his office a call.

Q. And have you retained Mr. Lirot to represent you in this matter?

A. Yes.

Q. Are you paying for his services or is someone else?

A. That has yet to be determined I believe.

Q. Have you reached an agreement with Mr. Lirot on how he is to be compensated?

A. Not at this time, no.

Q. All right. After receiving the injunction, did you go back down to downtown , Clearwater?

A. Yes.

Q. Did you read the injunction before going back downtown?

A. Yes.

Q. Did you read the injunction and read and understand those portions that talked about prohibited areas?

A. Yes. Well, they were kind of hard to understand, but, yeah, I read them.

Q. Did you go into those prohibited areas after reading the injunction?

A. I think so.

Q. Why?

A. It all depends on what I was filming at the time. There were a couple instances where I was -actually one where I was filming, one in particular I think which was a violation, which I was filming on Waterson Street. And the reason -- the first reason I was there was because it was raining and there was an overhang right on that corner. So I think being on the opposite -- I can't remember if being on the opposite corner or not is a violation. But I think there was some sort of interest in it because all the Church security came out with security cameras to film me.

Q. Were you hoping to provoke that type of reaction?

A. Hoping? Hardly. I can't, you know -- I can't help what other people do. I mean, if I'm downtown in a public place on a public street corner and that happens to provoke somebody into something. You know, I have no way of knowing that nor no way of going and doing that beforehand as a purpose so.

Q. Is that something that you'd like to achieve?

A. It depends on if that happens or not. I don't go there with a specific -- a specific plan I guess you could say in advance. You go downtown and you get what you can get. I mean, if people are going to, you know, of their own volition do things. I can't, you know, predetermine that nor can I preempt i so.

Q. Did you have any reaction from security prior to going into the prohibited areas?

A. Well, no, I guess not. If you call filming me or stuff like that a reaction. I don't kno what you mean by that.

Q. What were you filming before you went into the prohibited areas?

A. I think the first instance was there was a lot of kids, and I think they were pre-teen in some cases emptying the.garbage at one of the meal times I believe on Waterson Street. They evidently after the meal times are the last to eat, and they do all the dumping of the garbage and cleaning up of the dining hall evidently because they're always out there -- wer always out there lifting like these really heavy garbage cans and stuff and dumping them into the dumpster which sits at like a five-foot level, the top of it. So it was is a very, very, very telling scene.

Q. What was it telling of?

A. Telling of why on earth would there be kids out there doing this type of work.

Q. You don't think kids should empty the garbage cans?

A. Well, if you saw the garbage cans and you saw what they were emptying and how they were doing it, this was definitely not a kid's job, but, you know.

Q. What was it that made it not a kid's job?

A. Well, first of all, the things must have weighed more than 100 pounds because it took three kid to bring them -- to try to get them to such a level

where they could dump them over the lip of the garbage bin.

Q. All right. So you were filming the kids dumping the garbage cans?

A. Uh-huh (nods affirmatively). Plus, they, you know, of course, weren't dressed the way the rest of the Sea Org. were dressed. They were all in dirty disheveled jeans and old T-shirts, most of which looke like they had been stained for quite a period of time. Q. And is this part of your project?

A. Not necessarily. It depends on what makes itself readily seen on any given day that I'm down there.

Q. All right. When you went into the prohibited areas, were you filming?

A. Yes.

Q. What were you filming?

A. The second instance I think was the gentleman who assaulted me had pulled down Waterson Street, and I had gone over to the corner to get exactly what he was doing down that corner just because it might be of some -- relevant, and it turns out he was meeting with Church security on the side of the sidewalk. That was Michael Fitzgerald, by the way, thE gentleman who previously the Church didn't consider a member for some odd reason or at least that's what the media had stated.

Q. And did you film him at meeting with security? I'm sorry, was that a yes?

A. Yes.

Q. And what was the purpose of that?

A. You never know what the future holds with them. It could prove some sort of collision -collusion between the Church and this gentleman who assaulted me surprisingly enough which actually was overseen by one of the gentlemen here at the table. Actually I think his name was Peter Mansell which is also the same gentleman that verbally assaulted me after the assault.

Q. Let's go to the assault, let's talk about what were you doing.

THE COURT REPORTER: Excuse me, Bob, I need to change paper.

THE WITNESS: Actually let me get a cup of coffee, too.

THE VIDEOGRAPHER: We're going to go off the video record at 12:35.

(At this time a brief recess was taken.)


Q. All right. Mr. Lonsdale, we were just starting to talk about the altercation between you and Mr. Fitzgerald.

Can you tell me what you were doing immediately prior to that altercation?

A. Filming.

Q. What were you filming?

A. Street scenes.

Q. Street scenes of what?

A. Downtown corners, whatever was going on. Actually I don't even think I was actively filming. I had my camera set up, but I'm not sure I was -

actually had it turned on and filming at the moment.

Q. When you say you had it set up, did you