IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, 
STATE OF FLORIDA CASE N0: 99-7430-CI-08 

CHURCH OF SCIENTOLOGY FLAG COPY SERVICE 
ORGANIZATION, INC. Plaintiff 

vs LISA McPHERSON TRUST, INC. a Florida for-profit 
corporation, ET AL Defendants 

VIDEO DEPOSITION DEPONENT: SHAWN LONSDALE DATE: 
JULY 19, 2006 10:00 A.M. - 1:59 P.M. LOCATION: D & D REPORTING SERVICE 915 
CHESTNUT STREET CLEARWATER, FL REPORTER: DENISE ANN HERROLD NOTARY PUBLIC STATE 
OF FLORIDA AT LARGE \ D & D REPORTING SERVICE, INC. 915 CHESTNUT STREET 
CLEARWATER, FL 33756 (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. JOHNSON, POPE, ET AL P.O. BOX 
1358 CLEARWATER, FL 33617 For the Defendant: LUKE LIROT, ESQ. NOEL FLASTERSTEIN, 
ESQ. 2240 BELLEAIR ROAD STE 190 CLEARWATER, FL 33764 ALSO PRESENT: HELENA 
KOBRIN, ESQ. MICHAEL HARGETT PETER MANSELL I N D E X 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 WAS CALLED AND AFTER BEING DULY SWORN WAS 
EXAMINED AND TESTIFIED AS FOLLOWS: DIRECT EXAMINATION BY MR. POTTER: Q. Mr. 
Lonsdale, would you state your name for the record, please, sir. A. Shawn, 
S-h-a-w-n, Lonsdale, L-o-n-s-d-a-1-e. 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. BY MR. POTTER: 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 unemployed? 
A. Well, it's pretty hard, but I got a couple bucks saved up. Q. So you're 
currently living off of savings? 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 employed? 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 restoration. 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 know? 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 them? 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 I 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, okay. 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. BY MR. POTTER: 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 Scientology. 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 Scientology? 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 millimeter. 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 photos? 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, 
anyhow... 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, Tozer? 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 guess. 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 into. 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 name. 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 
enlightenment. 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 incredible. 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 organization? A. Well, if you mean I'm paying the money, 
no. Q. No, no. I mean from a philosophical standpoint you seem to have a 
disagreement with the organization? 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 Scientology? 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 
Scientology? 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 guess. 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 project? A. No. That's the funny thing about being poor. 
Unless there's money in it, nobody wants to help you. 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 
changed. 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. BY MR. POTTER: 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 website? 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 post? A. Well, he was former number two in the 
organization. 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, but. 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. BY MR. POTTER: 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 visually. 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. Rathbun? 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, flyers? 
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 people? 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 videotape? 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, yeah. 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 nature. 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 
that. 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 ! i 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' I 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 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 somebody? 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 members? A. 
Because they're a newsworthy item at the moment. 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 individual? 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 question. 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 gum. 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.) BY MR. POTTER: 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 you. BY MR. POTTER: 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