Sworn Statement of Debra Jean Cook

Date:August 25, 1997

Captain in Charge, FLAG Service Org


      IN RE:


      DATE:           August 25, 1997

      TIME:           Began:  9:30 a.m.
                      Ended: 11:45 a.m.

      PLACE:          Criminal Justice Center
                      Office of the State Attorney
                      Room 1000
                      Clearwater, Florida

      REPORTED BY:    Ruth M. Martin, CSR, CP, RNR
                      Registered Merit Reporter
                      Notary Public
                      State of Florida at Large

          TAMPA AIRPORT MARRIOTT - (813) 224-9500
         ST. PETERSBURG/CLEARWATER - (813) 821-3320


      1    APPEARANCES:

      2               MARK McGARRY, ESQUIRE
                      Office of the State Attorney
      3               Criminal Justice Complex, Room 1000
                      Clearwater, Florida 33760
      4                   Attorney for State of Florida

      5               ROBERT P. POLLI, ESQUIRE
                      Robert P. Polli, P.A.
      6               Barnett Bank Plaza, Suite 1130
                      101 East Kennedy Boulevard
      7               Tampa, Florida 33602
                          Attorney for the Witness
           ALSO PRESENT:
                      LEE STROPE, Special Agent
      10              Florida Department of Law Enforcement

      11              WAYNE C. ANDREWS, Detective Sergeant
                      City of Clearwater Police Department
      18                              INDEX
      19   EXAMINATION

      20         BY MR. McGARRY                                  3
                 BY DETECTIVE SERGEANT ANDREWS                  66
      21         BY SPECIAL AGENT STROPE                        89
      23    CERTIFICATE OF OATH                                 97
                      KANABAY COURT REPORTERS - (813) 821-3320


      1               The deponent herein,
      2                    DEBRA JEAN COOK,
      3          being first duly sworn to tell the truth, the
      4          whole truth, and nothing but the truth, was
      5          examined and testified as follows:
      6                       EXAMINATION
      7     BY MR. McGARRY:
      8          Q.   All right. Your name for the record, please.
      9          A.   Debbie Cook. Debra Jean Cook.
      10         Q.   All right.
      11              MR. McGARRY: Would you like to place
      12         something on the record?
      13              MR. POLLI: Thank you.
      14         I'm Robert Polli. I represent Miss Cook in
      15         this matter.
      16              We are here today pursuant to a
      17         State Attorney Investigation subpoena. I've talked to
      18         Miss Cook about the Statutory protections inherent in
      19         one of these subpoenas. She understands what her
      20         obligations are, she also understands what her
      21         protections are, and we are ready to proceed
      22         accordingly.
      23   BY MR. McGARRY:
      24         Q.   All right. My name is Mark McGarry. I'm going to
      25   be asking you some questions about your involvement with the


      1    Church of Scientology as well as some specific questions in
      2    reference to a parishioner, Lisa McPherson.
      3               Some background information I'm going to need:
      4    Your date of birth?
      5          A.   X, 1961.
      6          Q.   And you're a U.S. citizen?
      7          A.   Yes.
      8          Q.   Where do you live?
      9          A.   I live in Clearwater, Florida, at the Hacienda.
      10         Q.   Hacienda, we're familiar with the place.
      11              The position that you hold now at the Church?
      12         A.   I'm the Captain or the In Charge of the
      13   Flag Service Org.
      14         Q.   We're going to have to go into that in a second,
      15   find out exactly how that fits into the hierarchy thing.
      16         A.   Okay.
      17         Q.   How long have you been in Clearwater?
      18         A.   Since 1979.
      19         Q.   All right. And have you been a member of the
      20   church since '79?
      21         A.   I was a member of the Church prior to that. I've
      22   been on Staff here since 1979.
      23         Q.   Okay.
      24         A.   I was a member of the Church since 1976.
      25         Q.   And where was that?


      1          A.   That was in Charlotte, North Carolina.
      2          Q.   All right. Is that where you grew up?
      3          A.   Yes.
      4          Q.   How did you become acquainted with the
      5    Church of Scientology?
      6          A.   My brother, actually, introduced me to
      7    Scientology. And there was a -- a smaller -- a Mission
      8    there in North Carolina that we went to.
      9          Q.   Okay.
      10         A.   Did some courses.
      11         Q.   And were you a member of Staff in North Carolina
      12   or is that not till you came to Clearwater?
      13         A.   No, I was actually also Staff there at the Mission
      14   in -- let me see. About 1977, '78.
      15         Q.   Okay. And how did you come to move to Clearwater?
      16         A.   I wanted to -- well, Flag was sort of the top
      17   organization, and I wanted to come work here. So I came
      18   down -- drove down here to find out if I could work here at
      19   Flag.
      20         Q.   All right. And they said yes?
      21         A.   They said yes.
      22         Q.   And that was in 1979?
      23         A.   Yes.
      24         Q.   All right. And how far does your education go?
      25         A.   High school diploma.


      1          Q.   Okay. What position did you start out -- you
      2    started out with training courses, I assume, in '79 to
      3    prepare you for Staff?
      4          A.   Yes.
      5          Q.   What was your first Staff post?
      6          A.   I was -- actually worked out in the nursery where
      7    we had the Staff children and helped care for the Staff
      8    children, that was my first position.
      9          Q.   And why don't you go through your posts for me, if
      10   you can remember them. Just the highlights, if you would.
      11         A.   Okay. Well, mostly I have been in like a
      12   technical line. I was Auditor for many years, and I was
      13   also a Supervisor, where we had our course rooms and I would
      14   supervise students who were training in Scientology. And --
      15   and then I -- then I was sort of like the
      16   Director of Training.
      17              And then I went to an executive position. I was
      18   like the Deputy -- Deputy Captain for a couple of years.
      19   And then I held Captain temporarily while the Captain -- the
      20   one guy who had been the Captain went off for training. And
      21   then after he finished his training, it was determined to
      22   keep me on as Captain and he actually went into an even
      23   higher position.
      24         Q.  And who is that person?
      25         A.  Ron Norton.


      1          Q.   Who?
      2          A.   Ron Norton.
      3          Q.   Is he still in Clearwater?
      4          A.   No, he's in L.A.. He went to L.A. -- oh, I don't
      5    know. Let's see. That was 1990. I've been the Captain for
      6    about almost eight years.
      7          Q.   All right. Who is your Senior in Clearwater?
      8          A.   I don't actually have one in Clearwater. My
      9    Senior is in L.A.
      10         Q.   Who is?
      11         A.   Her name is Caroline Spatta.
      12         Q.   Caroline?
      13         A.   Yes.
      14         Q.   S-p --
      15         A.   S-p-a-t-t-a.
      16         Q.   And her title?
      17         A.   She's the FLB Programs Chief, stands for Flag Land
      18   Base Programs Chief.
      19         Q.   Now, on the board, it's been drawn up for us a
      20   couple times, but I'll let the -- the technical people here
      21   handle that in their questions, but Brian Anderson would
      22   be -- I know he's got a different position now.
      23              Back in '95, when we're talking about this
      24   Lisa McPherson thing, he would be where on the board for --
      25   as far as in relationship to you? Could he tell you what to


      1    do or vice-versa, or were you just in two separate
      2    organizations? You're in OSA and he's -- why don't you
      3    explain it.
      4          A.   Okay. He's in OSA, Office of Special Affairs, and
      5    we actually don't have a command over each other at all.
      6          Q.   Right.
      7          A.   The way the Church is set up is somewhat where
      8    there are -- there's like the major organization that
      9    delivers the Scientology services, which is what I run. And
      10   then there are some additional networks that are considered
      11   separate, so that, you know, the organization can always
      12   stay in check, so that there's not like just one dictator or
      13   something.
      14              So that's kind of how it's set up, is that the --
      15   the Office of special Affairs is a separate network that I
      16   don't have command over, but they also don't have command
      17   over me.
      18         Q.   So you're more on the services end of it all?
      19         A.   That's right.
      20         Q.   Which is training and all that?
      21         A.   And auditing, yes.
      22         Q.   Let's talk about your spiritual level now. How
      23   far have you attained on the spiritual side of training?
      24         A.   OT-V. That's --
      25         Q.   That's pretty high, right?


      1          A.   Yes.
      2          Q.   How far passed Clear is that?
      3          A.   That's basically five levels passed Clear.
      4          Q.   Okay. Clear, and then you go OT levels after
      5    that?
      6          A.   Right.
      7          Q.   Till what? How far do they go, VIII?
      8          A.   Up to VIII, right.
      9          Q.   Up to VIII.
      10              I've met an OT-VIII. Dr. Minkoff --
      11         A.   Right.
      12         Q.   -- is an OT-VIII.
      13         A.   That's right.
      14      .  Q.   Do you know him?
      15         A.   Yes, I do.
      16         Q.   How do you know him?
      17         A.   He does courses at -- at Flag.
      18         Q.   Okay.
      19         A.   I've also been to him as a doctor twice when I had
      20   the flu.
      21         Q.   Does he service parishioners and Staff members as
      22   well on a regular basis?
      23         A.   I don't know if they call it regular basis, but he
      24   does -- I do know that there are Staff that have gone to him
      25   as a local doctor. He -- he now has -- has a place that's


      1    pretty near Flag, which makes it --
      2          Q.   His office, you mean?
      3          A.   Yeah.
      4          Q.   He's moved it from one place to another?
      5          A.   Yes.
      6          Q.   He's still the resident emergency room physician
      7    up in New Port Richey, right, or do you know?
      8          A.   I think so. I'm actually not sure, yeah.
      9          Q.   Is there some kind of written agreement or
      10   document that he has on file at the Church that makes him
      11   available for services --
      12         A.   No.
      13         Q.   -- that you're aware of?
      14         A.   No, not that I'm aware.
      15         Q.   You're saying no, you're not aware of it or no,
      16   there isn't one?
      17         A.   No, I'm not aware of any.
      18         Q.   Okay. Who works for you in your -- your end of
      19   the organization?
      20         A.   Well, I have about 650 staff under me.
      21         Q.   Right. Let's start with somebody more immediate
      22   underneath you. Who is your immediate assistant?
      23         A.   Well, I have four people that are very directly
      24   under me. Which is Janet Herring, Triston Bucannon.
      25         Q.   All right.


      1          A.   Guy named Biseal, it's kind of a funny name, and
      2    the President, which is Mary Voegeding.
      3          Q.   Mary, spell the last name?
      4          A.   V-o-e-g-e-d-i-n-g.
      5          Q.   And you called her President?
      6          A.   Yes.
      7          Q.   That sounds important. Is that -- what does she
      8    do?
      9          A.   She mostly handles any VIP or celebrities that we
      10   have that come for service, and she kind of takes the extra
      11   special care to, you know, make sure that they're taken care
      12   of. I -- it's also a point where I -- I am not really sort
      13   of -- she's kind of like a front lines -- front person so
      14   that, you know, people that want to talk to the top dog can
      15   talk to her as opposed to me, so that I can get on with
      16   running things.
      17         Q.   When did you first meet Lisa McPherson?
      18         A.   The first time that I met her was when her -- the
      19   company that she works for moved to Clearwater and they were
      20   taken on a tour of the Flag facilities, some of the -- some
      21   of the staff. I think it  was about ten of the staff.
      22         Q.   What company was that, do you remember?
      23         A.   I know it's the company that Benetta Slaughter
      24   runs. Actually, I don't know the name of it. I know it's a
      25   printing --


      1          Q.   Publishing company?
      2          A.   -- or publishing company, right.
      3          Q.   Benetta Slaughter, is she in charge of that
      4    company?
      5          A.   I believe so.
      6          Q.   Okay. And that was Lisa's boss, correct?
      7          A.   Right.
      8          Q.   All right. So that is when you first met
      9    Lisa McPherson?
      10         A.   Yes. I mean, I met them as a group, welcomed
      11   them.
      12         Q.   How many people came with that company, do you
      13   remember?
      14         A.   I don't know. I know that when I -- I saw them
      15   touring, it was about ten of them.
      16         Q.   Ten?
      17         A.   I don't know how many total. I know that together
      18   as a group when they were at Flag touring that day there was
      19   ten. I don't know how many total staff they have.
      20         Q.   All right. And they relocated the business in
      21   Clearwater?
      22         A.   Right.
      23         Q.   From Dallas?
      24         A.   Yes.
      25         Q.   Okay.


      1          A.   Or -- I'm not sure. Texas, I know, but --
      2          Q.   Texas?
      3          A.   Yeah.
      4          Q.   Texas somewhere?
      5          A.   Yeah.
      6          Q.   So other than just saying, nice to meet you,
      7    that's as far as the first meeting with Lisa McPherson?
      8          A.   Right.
      9          Q.   Okay. Do you remember when this was, what year it
      10   was?              .
      11         A.   I don't know exactly. Yeah, I don't know, I
      12   couldn't tell you really.
      13         Q.   Okay. Let's narrow it down just by time frame.
      14   She went into the Cabana for isolation or for a watch in
      15   November of '95.
      16         A.   Okay.
      17         Q.   Would it have been in '95, earlier in '95, or
      18   would it have been before that, or do you know?
      19         A.   I would --
      20         Q.   If you don't remember, that's fine.
      21         A.   I could guess it was early '95.
      22         Q.   Okay. Did you have any further contact with her
      23   after that initial  introduction with her?
      24         A.   I awarded her cert on stage. Every -- every week
      25   I do graduation, and anybody who's completed a course or a


      1    major auditing action gets awarded a cert. So every week we
      2    probably --
      3          Q.   "Cert" is short for certificate?
      4          A.   Sorry. Yes, that's correct.
      5          Q.   Okay.
      6          A.   Every week we probably award over 100
      7    certificates. And there was, you know, one week where she
      8    came up and she was awarded a certificate.
      9          Q.   Do you remember which level she had attained?
      10         A.   Clear.
      11         Q.   She was Clear. That's a biggy, right?
      12         A.   Yeah.
      13         Q.   That's the first major certificate that you get
      14   before you move on to the upper level courses?
      15         A.   That's right.
      16         Q.   All right. Do you remember when that was that she
      17   attained that certificate?
      18         A.   I think it was maybe mid -- I don't know. No, I
      19   don't remember exactly. It seems like it was a few months
      20   before everything happened.
      21         Q.   Well, - I have some references here.
      22              MR. McGARRY: When was that, guys?
      23              DETECTIVE SERGEANT ANDREWS: September.
      24              MR. McGARRY: September?
      25              DETECTIVE SERGEANT ANDREWS: I think


      1    September.
      2          Q.   Does that sound correct?
      3          A.   Yes.
      4          Q.   No tricks here.
      5          A.   Okay.
      6          Q.   Is that awards thing for Clear, is that bigger
      7    than your regular certificate or regular course level
      8    achievement?
      9          A.   Is it bigger in size or a bigger deal?
      10         Q.   Bigger deal. Both, I mean.
      11         A.   I mean -- I would say that, yes, it's -- it's not
      12   like -- there are a number of things that are considered
      13   a -- a big deal. But yeah, it's definitely considered an
      14   achievement of, you know, importance.
      15         Q.   Right.
      16              Were you aware that sometime following that she
      17   had her -- a bit of a problem mentally that, I think, was
      18   addressed by the Church that summer?
      19              DETECTIVE SERGEANT ANDREWS: It would have
      20   been prior to it.
      21              MR. McGARRY: It was prior to Clear?
      22              DETECTIVE SERGEANT ANDREWS: Prior to
      23   September. June or July somewhere.
      24              MR. McGARRY: Oh, I'm sorry.
      25   Oh, you're right. Sure enough.


      1          Q.   Were you aware of that, she had a mental break
      2    prior to September being found Clear or attaining Clear?
      3          A.   I wasn't.
      4          Q.   You weren't privy to that information?
      S          A.   No.
      6          Q.   All right. We'll move more towards November.
      7               Did you have any contact with her after she
      8    attained the status of Clear --
      9.         A.   No.
      10         Q.   -- until she was given the room at the Cabana
      11   section of the hotel?
      12         A.   No.
      13         Q.   You didn't?
      14         A.   (Witness shakes head negatively.)
      15         Q.   All right. When did you first learn that she was
      16   going to be provided a room at the Cabana section of the
      17   hotel for some relaxation?
      18         A.   Well, I heard that -- that she'd had a minor
      19   accident and that she had taken her clothes off on -- I
      20   think it was maybe Highway 19. And then -- and that she was
      21   at the hospital. And then probably a day or two later. I
      22   heard that she was staying at the Fort Harrison.
      23         Q.   So you weren't involved in the commotion that was
      24   stirred up when she actually was at Morton Plant Hospital?
      25   Were you involved in any of that?


      1          A.   No, I was not.
      2          Q.   Was anybody in your staff that worked for you
      3    involved in that?
      4          A.   Well, I do -- I am now since aware of the fact
      5    that Al in and Judy Goldsberry-Weber were down there.
      6          Q.   Okay. They work for you, right?
      7          A.   Yes, they do.
      8          Q.   So you learned that they went down there?
      9          A.   Yes.
      10         Q.   And you also learned that some members of the OSA
      11   side of things were also down there?
      12         A.   Actually, I was not aware of that.
      13              MR. McGARRY: Is there anybody from OSA that
      14   went down there?
      15              DETECTIVE SERGEANT ANDREWS: Yeah.
      16   Humberto Fontana, Annie Mora.
      17              MR. McGARRY: Right.
      18              DETECTIVE SERGEANT ANDREWS: I think some
      19   others, but those are the two kind of main characters
      20   that were there.
      21         Q.   You weren't aware of them going down there?
      22         A.   I wasn't.
      23         Q.   All right. What position did Alain Kartuzinski
      24   have underneath you?
      25         A.   He was -- at the time he was the Senior Case


      1    Supervisor.
      2          Q.   And Judy Weber, her position was what?
      3          A.   She worked in the Medical Liaison Office.
      4          Q.   All right. Were they given instructions to go
      5    down to Morton Plant or did they act on their own, or do you
      6    know?
      7          A.   I don't know. I mean, they weren't given
      8    instructions from me, but I actually don't know if they
      9    were.
      10         Q.   Who was Mr. Kartuzinski's immediate supervisor?
      11         A.   At the time -- I'm not sure.
      12                     (Pause.)
      13         A.   I mean, the -- I mean, the positions above him are
      14   the Director of Correction, and then there's the -- the
      15   Qual Sec, the Qualifications Sec. Those are the -- the two
      16   positions above him. I'm trying to remember who was
      17   actually holding those at the time.
      18              DETECTIVE SERGEANT ANDREWS: Maybe to help
      19   you a little bit, somebody brought up Mr. Reese.
      20              THE WITNESS: No, Richard Reese actually is
      21   the Senior CS. And he went for training and Alain was
      22   temporarily holding that position while Richard
      23   trained...
      24              DETECTIVE SERGEANT ANDREWS: Okay.
      25              THE WITNESS: So Richard really --


      1               DETECTIVE SERGEANT ANDREWS: He wasn't the
      2    Director of Correction then?
      3               THE WITNESS: No, unh-unh.
      4          Q.   If you can think of it, would you --
      5          A.   Yes, I definitely will.
      6          Q.   -- bring it up?
      7          A.   Okay.
      8          Q.   How about Judy Weber, her supervisor?
      9          A.   Let's see. I know that -- well, in the MLO area
      10   was Judy, Janice, Laura. I guess above them would have been
      11   A.J. Sprecher, yeah.
      12         Q.   In the MLO office?
      13         A.   No, I mean the department she was in. The
      14   department -- the head of the department was A.J. Sprecher.
      15              In terms of who was overall in charge of the --
      16   But A.J. was an assistant to Mr. Kartuzinski
      17   though, correct?
      18         A.   No.
      19         Q.   She's under Kartuzinski; is that right?
      20         A.   No.
      21              DETECTIVE SERGEANT ANDREWS: that was
      22   Lacy Spencer. We talked to A.J.
      23              MR.McGARRY: Right.
      24              DETECTIVE SERGEANT ANDREWS: She sort of was
      25   the boss that's kind of a technical boss, she really


      1    wasn't involved in the medical.
      2               THE WITNESS: That's right. She's like the
      3    head of the department. Medical is kind of like a
      4    section, and there's about five different sections.
      5          Q.   The answer to who sent Kartuzinski and Judy Weber
      6    down to Morton Plant you don't know. And if it was somebody
      7    else, it might have been Security who says, hey, there's a
      8    problem?
      9          A.   Yeah. Just as a point, if a Staff member or
      10   Public goes -- gets rushed to the hospital or something,
      11   that's generally who would go down to find out, you know,
      12   what's happening, is there any assistance that we can give,
      13   that type of thing. So the MLO area would generally act on
      14   its own on that.
      15         Q.   Right. Well, that's -- that's kind of where I'm
      16   going, is that we talked to some MLO people and they said
      17   that typically a member from the Medical Liaison Office goes
      18   down there and meets with the parishioner or Staff, but this
      19   is kind of unusual because Lisa McPherson shows up down
      20   there and two or three members from OSA show up and two or
      21   three members from your end of it show up, and by the time
      22   it's all said and done with there's probably eight or more,
      23   ten --
      24              SPECIAL AGENT STROPE: Eight to ten, right.
      25         Q.   -- eight to ten members of the Church that are


      1    down there fussing over Lisa McPherson.
      2               And I was -- my question is, is that a normal
      3    scenario as far as you're concerned?
      4          A.   No, that wouldn't be a normal scenario.
      5          Q.   Why was that an exception to the general rule?
      6          A.   Well, I mean, I can only -- you know, I can
      7    suppose what it would have been.
      8          Q.   Right.
      9          A.   Which is, No. 1, I know that there was some
      10   concern about her being admitted into a psychiatric facility
      11   of some sort. And I also think that it's not usual that a
      12   Church member takes off their clothes and walks down the
      13   street. And so it was also probably a little bit
      14   concerning, you know.
      15         Q.   Okay. That's -- that's what I thought.
      16   So the following day is when you found out about
      17   this car accident?
      18         A.   Yes.
      19         Q.   And did you talk to Mr. Kartuzinski about what his
      20   plans were going to be for Lisa McPherson?
      21         A.   I didn't, no.
      22         Q.   Who did? Who -- my question is, who's -- who's
      23   keeping check on Kartuzinski's plan here? Who's his Senior?
      24   We're back to that again.
      25         A.   Well --


      1          Q.   Who does he report to, Kartuzinski? Anybody on
      2    the OSA side of things? Anderson, any of those people?
      3          A.   No.
      4          Q.   None of them?
      5          A.   I mean, the -- the way -- part of the way things
      6    are set up a little bit is that he's -- he, the Senior CS,
      7    is sort of the Senior technical person. I run more of the
      8    sort of organizational runnings of the -- the organizational
      9    operations. And he was sort of really considered -- I mean,
      10   that position is the chief -- chief technical guy.
      11         Q.   All right. Well, I've been told by numerous
      12   people that he's the guy that was in charge of bringing
      13   Lisa McPherson back down to earth. Would you agree with
      14   that statement?
      15         A.   Yes.
      16         Q.   All right. My question is, who did he report to
      17   directly in reference to -- if somebody above him in your
      18   organization wants to know, hey, how about that nut we got
      19   down the Cabana, how's she doing, who is that person asking
      20   him? Who is that person, you?
      21         A.   No. I mean, I wouldn't be dealing with Alain
      22   directly. There are -- there's basically a whole
      23   organizational chart. I mean, above him is -- there's a
      24   Director of Correction, there's a Qualifications Secretary,
      25   there's a Chief Officer and then there's me.


      1          Q.   And he reports to those people?
      2          A.   Yeah. I mean, generally you would report to your
      3    next Senior and they would report up, you know, to their
      4    next Senior.
      5          Q.   Okay. Well, she was there for, we now know,
      6    services rather than rest and relaxation. Would you agree
      7    with that statement?
      8          A.   (Witness shakes head negatively.)
      9          Q.   You would not agree with that statement?
      10              MR. POLLI: You have to answer yes or no.
      11         A.   No.
      12              THE WITNESS: Sorry.
      13              MR. McGARRY: For Ruth here.
      14         A.   Not -- not to my knowledge. I -- what I knew that
      15   she was there for was rest, to rest and recuperate.
      16         Q.   Well, I just asked you if Mr. Kartuzinski was in
      17   charge of bringing her back to earth and I kind of was under
      18   the opinion that that involved some type of procedure.
      19         A.   Okay.
      20         Q.   So it did not involve a procedure? There was not
      21   going to be a procedure run on her?
      22         A.   Yes.
      23         Q.   I don't want to look like I'm tricking you. I've
      24   had people tell me -- I've interviewed, dozens, dozens of
      25   Scientologists. Many of them said, yeah, she was there for


      1    an isolation watch, we're going to stabilize her and we're
      2    going to put her through an Introspection Rundown.
      3          A.   Yeah, that's the idea.
      4          Q.   She was there for services? The answer to the
      5    question, that's a yes or no?
      6          A.   I don't feel like it's a yes or a no. She flipped
      7    or whatever. The idea is, what I understand, is the rest
      8    and relaxation would ideally bring you back down to the
      9    ground, because you can't get auditing in that kind of
      10   state.
      11         Q.   I've heard that. Many people that said that.
      12         A.   I don't know that anyone ever discussed with her,
      13   okay, this is the plan. It was kind of like, okay, you
      14   know, let's sleep, let's eat. And that -- that was
      15   certainly the intention, was to --
      16         Q.   Well, she was paying for it. It's not a free
      17   service.
      18         A.   Well, she wasn't -- she didn't receive any
      19   service.
      20         Q.   They didn't get to it because she didn't clear
      21   enough -- she didn't stable enough to receive it.
      22         A.   That's right.
      23         Q.   But the plan was she was going to get services.
      24         A.   Yes.
      25         Q.   And the original service was rest, relaxation,


      1    stabilization, 'cause you can't get auditing until you get
      2    that, right?
      3          A.   (The witness nods affirmatively.)
      4          Q.   And then after that, the next step?
      5          A.   Right.
      6          Q.   And you've got to pay for that
      7    Introspection Rundown, that ain't a free course?
      8          A.   Right.
      9          Q.   Is. that correct?
      10         A.   That's correct.
      11         Q.   So she was there for services, ultimately for
      12   services? Yes? No?
      13         A.   Yeah, ultimately that was our intention, would be
      14   to-- to help sort matters out.
      15         Q.   All right. So this plan was ultimately being
      16   implemented by who?
      17         A.   I mean, I -- I'll say that Alain would have been
      18   the -- was the one who --
      19         Q.   Implements this procedure?
      20         A.   That's right.
      21         Q.   That's what his job does, correct?
      22         A.   That's correct.
      23         Q.   Okay. And who -- who follows his orders to do
      24   that? My understanding is he ain't down there every day.
      25         A.   That's correct.


      1          Q.   Do you know -~ did he go down there, do you know,
      2    to see her?
      3          A.   I don't know.
      4          Q.   You don't know the answer to that?
      5          A.   Don't know.
      6          Q.   Who would know the answer to that?
      7          A.   I don't know. I mean, Alain or the -- the people
      8    on the watch would have, you know.
      9          Q.   Okay. All right. Who did he entrust with
      10   implementing this service plan, stabilization plan? Who's
      11   in charge of that from him? If he wasn't down there every
      12   day, then there had to be somebody in charge of that. Who's
      13   that?
      14         A.   I don't know of anyone that was in charge of it.
      15              I know that -- I don't even know exactly who set up the
      16   different staff to watch her. I know that -- I know that
      17   something was organized originally to -- to have someone
      18   with her at all times, and staff were somehow named to --
      19   you know, females that could do this. And I know that they
      20   wrote, you know, periodic reports on how she was doing that
      21   went to Alain.
      22         Q.   Okay. So you're not aware of the organizational
      23   implementation of the -- of the watch or schedules or who
      24   did any of that?
      25         A.   No. I mean --


      1          Q.   But you became aware that it was done that way,
      2    right?
      3          A.   Yes.
      4          Q.   And who would the reports go to, Mr. Kartuzinski?
      5          A.   That's right.
      6          Q.   And then who?
      7          A.   I don't know of anybody else that they went to
      8    other than him.
      9          Q.   Okay. The person that we can't remember the name
      10   of, the Director over -- what was his title,
      11   Director of something or other, over Kartuzinski? What's
      12   his title?
      13         A.   Director of Correction.
      14         Q.   Director of Correction?
      15         A.   That's right.
      16         Q.   Give me his job description. What does that guy
      17   do?
      18         A.   Well, that's -- that's another department and it
      19    handles -- it has a section for the Senior CS section, it
      20    also has a section that's called Cramming, which is where --
      21         Q.   I'm familiar with the term.
      22         A.   Okay. And then it's also got another section
      23    which is the internship, where someone who has done an
      24    Auditor course can then intern, basically similar to how
      25    a -- you know, other internships would be, where basically


      1    you audit and perfect your skills.
      2          Q.   Who does that now?
      3          A.   The Director of Correction?
      4          Q.   Yes.
      5          A.   Her name is Inbal Sheer. She's from Tel Aviv.
      6          Q.   How long has she been employed in that position?
      7          A.   Really, only a few months.
      8          Q.   Do you remember who it was that did it before her?
      9          A.   Prior to that was Linda Thames, T-h-a-m-e-s. But
      10   I don't know if she was on at that time.
      11         Q.   Well, that's what --
      12         A.   I'm not sure.
      13         Q.   Thinking it though, I bet if I asked Linda who did
      14   it before her,  we might get all the way back who did it for
      15   Alain Kartuzinski, do you think?
      16         A.   Could be.
      17              I'm sorry, I really would tell you if I could
      18   remember.
      19         Q.   All right. So now my questions are going to focus
      20   a little bit on some of this recordkeeping business, because
      21   I think you being on this side of the service oriented end
      22   of the scale here, you probably, of all the people that I've
      23   talked to, have more knowledge about how folders are
      24   organized and kept, because that's more towards your end of,
      25   it, right?


      1          A.   That's right.
      2          Q.   As opposed to the. Brian Andersons and people on
      3    that side of it, correct?
      4          A.   That's correct.
      s          Q.   Okay. Good. 'Cause we talked with -- last Friday
      6    we talked with Annie Mora. She works for you, right?
      7          A.   No, Annie Mora is on the Brian side.
      8          Q.   That's right, she's on the OSA side. But she did
      9    a few things in reference to those folders that were kind of
      10   curious.
      11              Who -- well, before we go to that, back to the
      12   Cabana section period here. The period of time that Lisa
      13   was staying at the Cabana section, were you being updated on
      14   how she was doing?
      15         A.   Yes, I was, very periodically. I mean, not an
      16   every day report, but periodically updated on things that
      17   were happening.
      18         Q.   And that communication was verbal or written?
      19         A.   Verbal.
      20         Q.   And by whom?
      21         A.   Well, different people, really. I mean, there was
      22   a couple of times that I talked to Alain. There was a
      23   couple of times that I talked to Janet. And a few times I
      24   talked to Marcus.
      25         Q. Quirino?


      1          A.   That's right.
      2          Q.   And Janet or Janice?
      3          A.   Janet, Janet Herring.
      4          Q.   Okay. And those reports consisted of, she's not
      5    doing so good, she's beating up caretakers, et cetera?
      6          A.   Yeah. I mean, they varied. Some reports seemed
      7    positive, you know, that she seemed to be doing better, she
      8    ate better that day or she slept a bit more or -- then there
      9    were some reports of, you know, her beating up or punching a
      10   staff member, you know, violence, some violence, that type
      11   of thing.
      12         Q.   All right. Since you're the Captain, if -- if
      13   Lisa wanted to leave or go see her mom or go to the hospital
      14   or do something contrary to what was happening there at the
      15   Cabana, who would make that decision?
      16         A.   Well, she could make that decision. I mean, she
      17   was not forceably held there. Nobody's forceably held.
      18         Q.   Are you aware of her ever making that request?
      19         A.   No, I'm not.
      20         Q.   Would Kartuzinski have to come to you to see that
      21   that occurred, if she wanted to leave?
      22         A.   No, definitely not.
      23         Q.   He could do it?
      24         A.   Yes.
      25         Q.   How about the head of Security, Baxter,


      1    Kellerhaus, any of those guys?
      2          A.   As far as I understand, it's not a decision that
      3    any one of us would have necessarily made. I mean, I guess,
      4    of course, if she was naked and had a knife or something,
      5    you know, I'm sure that Security probably wouldn't have let
      6    her just run wild.
      7          Q.   Okay. All right. When did you first realize or
      8    when was the information passed on to you that there was --
      9    that she had passed away or she died?
      10         A.   The day that it happened. That night. I got -- I
      11   was told -- trying to even remember who told me. I think it
      12   as either -- it was either Marcus or Janet who told me.
      13   Someone had just received a call from Janice.
      14         Q.   Up at the New Port Richey Hospital?
      15         A.   Right.
      16         Q.   You don't remember who that was?
      17         A.   I -- I don't know that I knew who it was. I know
      18   that she'd called in and reported that --
      19         Q.   What time was that?
      20         A.   It was in the evening. I don't know exactly what
      21   time.
      22         Q.   Well, was it --
      23              MR. McGARRY: She died what time, fellows?
      24              SPECIAL AGENT STROPE: About 9:30.
      25         Q.   So it was after 9:30?


      1          A.   Yeah.
      2          Q.   Okay.
      3          A.   I mean, I know she had died. When we got the call
      4    it was already done.
      5          Q.   Being the Captain, did you take some action from
      6    that? Did you give any orders out? What was -- what was
      7    your -- what procedures did  you take from there?
      8          A.   Well, it was, of course, very shocking. I --
      9    actually, I -- I ran across the street from the building I
      10   was in to the -- the building where OSA is and where Brian
      11   was to find out what he knew and look into -- start looking
      12   into what had happened.
      13         Q.   Okay. Who's over there when you get there? Is
      14   Brian there?
      15         A.   Yes.
      16         Q.   Was Marcus Quirino there?
      17         A.   No. No. I mean, I think Marcus may have come
      18   over after that.
      19         Q.   How about the Fontanas, Judy or Humberto?
      20         A.   I believe -- it seems like Humberto was there.
      21   I'm not a hundred percent positive.
      22         Q.   Kellerhaus? Baxter?
      23         A.   No. I mean, this was pretty immediate. I guess
      24   as soon as we heard I ran over there. So there wasn't that.
      25   many people there yet.


      1    And then shortly after that Brian got a call
      2    from -- I think it was Brian got a call from Janice, which
      3    brought up -- Janice felt convinced that Lisa had meningitis
      4    or had died of meningitis. Somehow she felt very alarmed
      5    that this was what had caused her death. And so then
      6    shortly after that really what proceeded was majorly an
      7    evolution to isolate -- find out who she'd been in contact
      8    with and isolate any of the staff or anybody who had been
      9    with her until this was checked out.
      10         Q.    Whose office is this conversation taking place in?
      11         A.    This -- well, initially it was in Brian's office.
      12   And then we ran -- then I ran back across the street to the
      13   Coachman  Building, which was where we started to organize
      14   the isolation cycle.
      15         Q.    Did Brian Anderson go with you?
      16         A.    No.
      17         Q.    Who did?
      18         A.    I don't know if anyone physically went with me.
      19   Up -- in  the Coachman there was Marcus and Janet, yeah, and
      20   they were -- I don't know, I guess we had other staff that
      21   had to be -- we grabbed some other staff to help round up
      22   the other - the people that had to be found and located.
      23         Q.    All right. I'm not sure I got the answer. When
      24   you first went and heard that Lisa had died and you went
      25   over to Anderson's office --


      1          A.   Yes.
      2          Q.   -- that's over at OSA --
      3          A.   Yes.
      4          Q.   -- who, was there besides Brian Anderson? I think
      5    you said Quirino was there?
      6          A.   Yeah, I think he came --
      7          Q.   Anderson was there?
      8          A.   Marcus came afterwards. I'm pretty sure Humberto
      9    was there. Judy Fontana might have been there, I'm not
      10   totally positive.
      11         Q.   Okay. Were you physically present when -- when
      12   Brian had the conversation with Janice on the phone?
      13         A.   I was -- let me think about that. I know that
      14   Brian was on the -- got off the phone. I'm -- I mean, I
      15   guess I assumed that he talked to Janice. It was a little
      16   bit -- you know, everyone was a little bit freaked out. It
      17   was sort of different, you know, what was going on, you
      18   know. I assumed that he was speaking to Janice, although it
      19   was a little bit slightly distant away from where I was.
      20              And after he got off the phone, that was when he
      21   brought up this point about the concern about meningitis.
      22   And then we started to get, more information about this,
      23   what -- what -- you know, what is this, what does it entail,
      24   who would have to be isolated, how dangerous is this.
      25         Q.   Okay. Do you recall him having a conversation


      1    with Dr. Minkoff while you were standing there?
      2          A.   No, I do not.
      3          Q.   Okay. So you don't know whether he did or not?
      4          A.   No. I recall -- I recall later that he did have
      5    a -- he told me of a conversation that he had with Minkoff
      6    about the meningitis tests that were being done and how long
      7    it would take.
      8          Q.   That was later on that night?
      9          A. From what I recall, that was -- actually, it was
      10   either later that night or the very next day. That might
      11   have been the next day. 'Cause I remember somehow it
      12   took -- there was a time lapse that -- you know, before we
      13   would even know what -- if that was the case or what was the
      14   cause of the death.
      15         Q.   So you went over the Coachman Building. What time
      16   was that?
      17         A.   I don't know. It was probably around midnight.
      18   Maybe 11:00, midnight. Maybe 11:00, maybe 10:30, I don't
      19   know. I don't know exactly. It was towards the -- pretty
      20   close to the end, you know, end of the night.
      21         Q.   End of the day?
      22         A.   Yeah.
      23         Q.   And who was there with you, Quirino and who else?
      24         A.   Marcus Quirino, Janet Herring, yeah.
      25         Q.   All right. And the purpose of going over there


      1    was to do what?
      2          A.   To organize the isolation.
      3          Q.   Of the people that had contact with Lisa?
      4,         A.   That's right.
      5          Q.   Okay. Who provided you with the list of names
      6    that had been watching Lisa?
      7          A.   Well, we got --we started to -- to get some --
      8    immediately we got any of the people who had been working in
      9    the MLO area up first.
      10         Q.   They were summoned immediately?
      11         A.   Yeah. Because what -- well, we knew that -- I
      12   guess to find out who had -- who all had been with her.
      13         Q.   Okay. So some of the MLO --
      14         A.   Like Emma. Emma and Judy.
      15         Q.   And they gave you the names of people that were on
      16   the watch?
      17         A.   Yes.
      18         Q.   And then what did you do when faced with that
      19   information?
      20         A.   Well, I know that -- I remember that Marcus
      21   interviewed -- interviewed them to find out about what
      22   contact they had had, what contact they had with other
      23   people in order to find that out, find out the information.
      24         Q.   Yes. And did he also -- was this done in your
      25   presence?


      1          A.   Well, I mean, it was all up on the same floor. He
      2    was in the -- I think he was in the conference room. I
      3    mean, I was sort of more across the hall, but maybe a little
      4    bit in and out. So there was maybe a couple minutes of, you
      5    can, hearing some of it. Very much so in and out, running
      6    around, making sure that people were doing their various
      7    parts of this.
      8          Q.   And this communication that he was getting from
      9    the caretakers, did he write this stuff down himself?
      10         A.   I think he was taking notes, yeah.
      11         Q.   All right. Did he also require them to write down
      12   what they observed in their contact that they had with Lisa?
      13         A.   I don't know on that. I know that he was --
      14         Q.   All right.
      15         A.   I know that he was interviewing people and
      16   taking -- I think I saw him taking notes.
      17         Q.   Was Brian Anderson over there too?
      18         A.   Yeah, Brian came over briefly. Yeah, he came over
      19   briefly.
      20         Q.   Yes?
      21         A.   Yeah.
      22         Q.   And what was his role?
      23         A.   I don't know exactly. I don't know. He was, I
      24    guess -- I know that our major concern at that point was
      25    whether or not -- I also -- before I went through having to


      1    isolate some, I don't know how many staff, I wanted to know
      2    if this was really necessary, you know, if we had gotten any
      3    more conclusive information. That was really all I remember
      4    talking to him about.
      5          Q.   Did he ever read these summations from
      6    Marcus Quirino or look at the caretakers' reports that you
      7    know of?
      8          A.   I don't know specifically. I know that pretty
      9    much everything that we had was -- was turned over to OSA,
      10   so it's highly probable.
      11         Q.   Everything you had?
      12         A.   No, I didn't have anything myself. But everything
      13   that --
      14         Q.   Everything from your department?
      15         A.   Yeah.
      16         Q.   Did you read or look at any of these documents
      17   that were created by Marcus Quirino and/or the caretakers
      18   and their summations?
      19         A.   I never saw Marcus' write-ups. I saw a summary
      20   there he wrote up after -- after the interviews.
      21              In terms of caretaker reports, initially when I
      22   first learned that Lisa had died and when I first ran over
      23   across the street, the folder was brought over there and I
      24   did start to look through it to find out, you know, what --
      25         Q.   Which folder?


      1          A.   Her PC folder.
      2          Q.   Okay. From your department where the PC folder
      3    was located?
      4          A.   I didn't understand that.
      5          Q.   Her auditing folder?
      6          A.   But I didn't understand the question.
      7          Q.   Folders are very complicated subject matter for
      8    you guys, you have so many folders for so many things in the
      9    Church.
      10         A.   Right.
      11         Q.   The folder that you're talking about that you took
      12   over to the Coachman Building, that was her PC folder?
      13         A.   That was her PC folder.
      14         Q.   That contains her auditing sessions?
      15         A.   That's right.
      16         Q.   And notes from the people that audit her, correct?
      17         A.   That's correct.
      18         Q.   And that file also is where I've been told that
      19   the caretakers' notes were directed to after
      20   Alain Kartuzinski reviewed them.
      21         A.   That's right.
      22         Q.   Is that correct?
      23         A.   That's right.
      24         Q.   Okay. Now, is that one folder? Or when you say
      25   "folder," that may comprise a stack of folders that are all


      1    PC folders?
      2          A.   I -- I saw her one -- the one folder, which is the
      3    most -- was the most recent folder, I mean.
      4          Q.   Okay. And that would contain the caretakers'
      5    notes of their observations of Lisa during her stay at the
      6    Cabana?
      7          A.   That's correct. And I did see some of those.
      8          Q.   All right. Now, that folder, where is that kept?
      9    Where did you get that folder in your building?
      10         A.   I don't know where the folder came from exactly.
      11   I had assumed that -- I mean, I think the folder mostly
      12   stayed in Alain's office. I had assumed it came from
      13   Alain's office.
      14         Q.   Because it was an open file and he was actively
      15   working on it, I assume?
      16         A.   Right.
      17         Q.   And so that it wouldn't be in a warehouse --
      18         A.   That's right.
      19         Q.   -- because he's receiving daily reports in it,
      20   correct?
      21         A.   That's correct.
      22         Q.   All right. So who is the person that actually
      23   retrieved the folder and handed it to you? Do we know that
      24   person's name? Was it Mr. Kartuzinski or was it an
      25   assistant or was it somebody else?


      1          A.   (No response.)
      2          Q.   This occurred December 5th, right, the night she
      3    died?
      4          A.   That's right. That's correct.
      5               I don't know. I mean, we have people who their
      6    whole job is to simply move folders around.
      7          Q.   You've got runners and all kinds --
      8          A.   Yeah. It was -- from what I remember --
      9          Q.   You had the power to say get me her PC folder and
      10   whoever's standing around's going to do that, correct?
      11         A.   That's correct.
      12         Q.   And that was done and it was handed to you?
      13         A.   That's correct.
      14         Q.   Okay. Now, you carried that folder where, you
      15   personally, over to where?
      16         A.   No, I -- I was in the OSA office when I asked for
      17   the folder and it got brought to me.
      18         Q.   Oh, somebody ran over and got it and brought it
      19   back?
      20         A.   That's correct.
      21         Q.   So being Clear, you're able to look in that folder
      22   and see what's in there?
      23         A.   That's correct.
      24         Q.   Anybody else that's not Clear, that would probably
      25   not be such a good idea, right?


      1          A.   That's correct.
      2          Q.   Contained within that folder, her most recent
      3    folder, was nothing but caretaker notes or caretaker notes
      4    plus her last auditing session or what? Can you describe it
      5    to me?
      6          A.   Yes. There is sort of an administrative way that
      7    these folders are kept. Like, for example, always in the
      8    most recent folder you'll have any auditing programs like
      9    clipped to the left side. So, you know, any -- any auditing
      10   that she's had ever, there will be a record of that on
      11   the -- the left side. In the -- also there's, on the other
      12   side, in the back you'll always have what's called a folder
      13   error summary. And that would be, you know, any earlier
      14   auditing that gets reviewed, and any errors that have been
      15   made are noted on this.
      16              And then otherwise there was really -- I mean, I
      17   didn't make it through the whole folder. I flipped through
      18   the folder, I read the recent -- flipped through, you know,
      19   the recent caretaker reports, basically, was majorly what I
      20   looked at.
      21         Q.   And how thick would you describe that folder?
      22         A.   The total folder was probably, I don't know,
      23   couple inches.
      24         Q.   Couple inches thick?
      25         A.   Uh-huh.


      1          Q.   And my question -- did you answer my question
      2    about whether or not it contained just caretakers' notes or
      3    there were also auditing notes in there from her last
      4    session auditing?
      5               I know you just explained what the run sheets were
      6    on both sides as far as her programs are concerned and the
      7    FES side of it and all, but were there other items in there
      8    in reference to her last auditing session or was it just
      9    predominantly caretakers' reports?
      10         A.   It -- to be honest, I don't know. I didn't go
      11   through the whole folder. But it didn't look to me like it
      12   was only caretaker reports, because they're generally single
      13   file and it didn't seem like the whole folder was single
      14   file reports.
      15         Q.   And Annie Mora was there or not there?
      16         A.   I don't recall Annie Mora being there. I don't
      17   know. I don't recall her being there.
      18         Q.   Did you see her that night?
      19         A.   Probably. Kind of an elusive answer. Probably,
      20   but I don't know for sure. I mean, there wasn't anything
      21   significant that happened with her that I remember.
      22         Q.   Okay. Do you if she ever looked at the PC folder?
      23         A.   I don't know. I didn't see her.
      24         Q.   Is she Clear? .
      25         A.   I actually don't know.


      1          Q.   Okay. Did Kartuzinski make it over there to the
      2    OSA offices in the Coachman Building? Was he there with
      3    you?
      4          A.   Not while I was there.
      5          Q.   He wasn't?
      6          A.   I mean, I was only there for probably 15, 20
      7    minutes before I went running back over to the Coachman.
      8          Q.   Oh, I thought OSA was in the Coachman?
      9          A.   No. It's right across the street.
      10         Q.   Okay.
      11         A.   The Coachman Building is a separate building that
      12   we rent.
      13         Q.   What did you do with the PC file?
      14         A.   I left it there in OSA.
      15         Q.   And whose trust was that given to?
      16         A.   I mean, I guess it's a -- it's a very secure area.
      17   Brian Anderson. I guess Brian Anderson.
      18         Q.   He was entrusted with it?
      19         A.   Well, it wasn't like I said, Here, I'm entrusting
      20   you  with this.
      21         Q.   You wouldn't just walk off and leave it?
      22         A.   No.
      23         Q.   Who was it given to?
      24         A.   Well, I mean, it was -- it wasn't handed to
      25   anybody, it was right there. Brian was right there. And it


      1    was, okay, I'm running over to the Coachman to, you know,
      2    organize this up.
      3          Q.   Okay. What was your understanding they were going
      4    to do with it?
      5          A.   I don't know. I didn't -- wasn't even a concern.
      6          Q.   Why did you go back across the street now? What
      7    was your next thing?
      8          A.   To organize this isolation.
      9          Q.   And who did you call to do that or did you do it
      10    yourself?
      11         A.   I got ahold of Janet and Marcus. Janet and Marcus
      12    were -- are sort of more, you know, junior execs rather than
      13    me.
      14         Q.   I thought you were over there with Marcus while he
      15    was organizing this thing?
      16         A.   Yeah, I don't remember exactly. I think that
      17    Marcus came over -- I don't know.
      18         Q.   Well, I'm confused. Completely confused.
      19              So I'm going to give you a piece of paper. You
      20    show me your office, Anderson's office, Quirino's office,
      21    and  let's see if we can reconstruct this thing from where
      22    you went, where the PC folder went.
      23              We'll get a pen for you. There's one.
      24         A.   Thank you.
      25              Okay. So this is Cleveland Avenue. This


      1    Fort Harrison Avenue. This is Fort Harrison.
      2    Fort Harrison's probably here. And the -- this is what we
      3    call the Clearwater Bank Building is here. And that's where
      4    OSA is, up in here.
      5          Q.   All right.
      6          A.   This here is a big building, is the
      7    Coachman Building. And this is -- mostly we have a lot of
      8    the course rooms, this is mostly a training building. Up on
      9    the 5th floor is where the exec offices are. And then it's
      10   like a big, wide, huge hallway. And there's -- my office is
      11   here and there's a conference room here. Janet and Marcus'
      12   office is right here, right across the hallway.
      13              So there was kind of isolation. Whole evolution
      14   was kind of happening here. Marcus was interviewing people
      15   here. You know, kind of running around in here basically.
      16         Q.   All right. So you when you said you went over
      17   here with the PC folder -- -
      18         A.   No, I didn't take the PC folder.
      19         Q.   You ordered the PC folder when you were here?
      20         A.   Right.
      21         Q.   I was under the assumption Quirino was over here
      22   gathering up the information to get the watch together.
      23         A.   No, he was over here.
      24         Q.   Okay.
      25         A.   I get told Lisa McPherson is dead, whatever. Ah,


      1    run over here. I want to know who knows what's happening.
      2    I call for the PC folder, start to look into it. Then
      3    Janice -- I know Brian got the word Janice was concerned she
      4    had meningitis or died of meningitis.
      5               So then pretty much immediately I -- I go running
      6    back over here to start organizing this up here. 'Cause
      7    I -- now I need to -- now I need to get staff to help me to,
      8    find these people. It's late, some of them have gone home.
      9    So it's quite an evolution to round up all these people. So
      10   this all takes place over here.
      11         Q.   All right. So all that interview and stuff that
      12   Quirino,was doing --
      13         A.   Was over here.
      14         Q.   -- was over here.
      15              And he created the summary that I've got here --
      16         A.   Okay.
      17         Q.   -- from caretakers.
      18              Is this the summary you said you looked at?
      19         A.   Yes.
      20         Q.   Okay. And when did you read that?
      21         A.   I guess the next day.
      22         Q.   And in what office was that in, his office over
      23   there?
      24         A.   I don't know. I -- I mean, in terms of -- more to
      25   the point on the answer to that question is, as it was


      1    happening, we were getting this information from him.
      2    Because part of the major purpose of his interviews was to
      3    find out if they themselves had possibly been contaminated
      4    and if they had talked to anybody else or been in contact
      5    with anybody else who could possibly be contaminated or
      6    whatever you call it, you know. And so mostly as he was
      7    interviewing we were getting the information from him. So
      8    that report -- that summary didn't have a tremendous amount
      9    of significance to me after it was written up. But anyway,
      10   I remember seeing the report, maybe I was in my office.
      11         Q.   Okay. Did you have any further meetings with
      12   Brian Anderson about this that night?
      13         A.   Yes. I -- after I kind of had this -- after a
      14   while and this seemed to be coming under control, my next
      15   concern was, how does the family get notified or did she
      16   have any family or, you know, this type of thing. And I --
      17   somehow I was hooked back up -- I got -- talked to Brian
      18   about that concern. And I later went back over, to the CB
      19   and we called Benetta Slaughter to find out -- basically to
      20   tell her and to find out from her, you know, whether Lisa
      21   had any family, how the family could be contacted, that type
      22   of thing.
      23         Q.   What time was this phone call made?
      24         A.   I don't know. I know it was late. I'm not sure
      25   exactly. It was -- I know it was late in the night.


      1          Q.   Who talked to her on the telephone?
      2          A.   I did.
      3          Q.   What did you tell her?
      4          A.   I -- basically, I told her I had something that I
      5    needed to go over with her and I wanted to know if she would
      6    come -- come here to see me, 'cause I didn't want to really
      7    tell her on the phone.
      8          Q.   Did she do that?
      9          A.   Yes.
      10         Q.   Did she do that?
      11         A.   She did. Her and her husband came.
      12         Q.   They both came to your building?
      13         A.   Yeah.
      14         Q.   Was that in the early morning hours or was that
      15   around midnight, do you remember?
      16         A.   It was -- I'm not sure. It was maybe around
      17   midnight, maybe early -- I'm not sure.
      18         Q.   Okay. And what occurred?
      19         A.   I told her Lisa had died. She cried a lot. I
      20   tried to, you know, comfort her some. They asked, you know,
      21   a lot of questions, which I had no answers to. Like how,
      22   what happened, you know. And then I -- I mostly asked her,
      23   like, does she have any family, how would -- you know, how
      24   would -- how should they be contacted or whatever.
      25              And -- and Benetta told me that there were --


      1    there was one -- she actually lived with another girl in
      2    her -- in an apartment here. So we also -- David Slaughter,
      3    I think, went out and-- and picked her up and brought her
      4    also here to the CB. And I also told her. That was Gloria.
      5          Q.   Cruz?
      6          A.   Cruz, that's right.
      7               So I told her. She was crying, you know.
      8               Anyway, so -- and then Benetta told me about
      9    Lisa's mother. And basically Lisa's mother was the only
      10   real family that she had. I asked her if she knew Lisa's
      11   mother herself and she -- she did, she knew her lightly.
      12   And so she felt it would be best if she spoke to her and
      13   told her.
      14         Q.   And did she do that?
      15         A.   She didn't want to call her at whatever time it
      16   was, 2:00 or 3:00 in the morning, so she -- as far as I
      17   know, first thing -- well, yeah, she did first thing in the
      18   morning call her mother and tell her.
      19         Q.   All right.
      20         A.   So by that point it was -- when that was all
      21   finished, it was probably, I don't know, 4:00 in the morning
      22   or something like that.
      23         Q.   Where did the PC folder go the next day?
      24         A.   I have no idea.
      25         Q.   Did you order it to go anywhere?


      1          A.   No, I didn't.
      2          Q.   Did anybody?
      3          A.   I don't know. Yeah, I don't know.
      4          Q.   Well, it was entrusted, last time you saw it, with
      5    either one of the Fontanas or Brian Anderson possibly?
      6          A.   Right.
      7          Q.   Did Brian Anderson read that file?
      8          A.   I don't know. I did not see him looking at it.
      9          Q.   Did you go to the funeral?
      10         A.   No.
      11         Q.   Who did?
      12         A.   Mary Voegeding did.
      13         Q.   Why did she go?
      14         A.   Because she basically went on behalf of me. I
      15   know that Benetta went and some other people that worked in
      16   her company, yeah.
      17         Q.   There was some concerns about this death making --
      18   creating some negative publicity in the Church; is that
      19   correct?
      20         A.   Well --
      21              MR. POLLI: You have to say yes or no.
      22         A.   I don't know. I mean; to be honest, it wasn't
      23   some major concern. I mean, some concern, I guess I'd have
      24   to say yes.
      25         Q.   Okay. When did you become aware the Clearwater


      1    Police Department was, becoming involved in an investigation
      2    relating to the circumstances surrounding her death?
      3          A. Seems like -- I don't know. Seems like some days
      4    afterwards.
      5          Q. Okay. Were there ever any meetings between you
      6    and Mr. Anderson or anybody else in the upper echelon of the
      7    Church in order to discuss whatever possible damage control
      8    you might have from this scenario?
      9          A.   (Witness shakes head negatively.)
      10         Q.   No?
      11         A.   Unh-unh.
      12         Q.   Never happened?
      13         A.   Between myself and Brian Anderson, no.
      14         Q.   Or anybody in OSA or your department.
      15         A.   To discuss?
      16         Q.   Well, Lisa McPherson died on Church property.
      17         A.   Right.
      18         Q.   At a bare minimum, that's not a pleasant thing.
      19         A.   That's right.
      20         Q.   And knowing the relationship that you -- or not
      21   you, that the Church has with The Trib and the
      22   St. Petersburg Times, obviously you're aware that that can
      23   create a problem?
      24         A.   Right.
      25         Q.   Because they can make it a problem, correct?


      1          A.   That's correct.
      2          Q.   And was that discussed? Was that discussion ever
      3    had between you and Mr. Brian Anderson or anybody else in
      4    reference to the circumstan6es surrounding Lisa McPherson's
      5    death in the hotel?
      6          A.   No.
      7          Q.   It was not?
      8          A.   No.
      9          Q.   Okay.
      10         A.   I mean, we -- you know, similarly in terms of what
      11   you're asking about, we've certainly discussed precautions
      12   that would be taken to prevent, you know, anyone who's a
      13   lunatic or whatever from staying there at the Fort Harrison.
      14   We haven't -- I haven't had -- I haven't talked with
      15   Brian Anderson particularly about it. I mean, internally
      16   within our -- my own organization, I certainly would never
      17   want that to -- anything like that to ever happen again.
      18   There's --
      19         Q.   Well, it was perceived by you and the upper
      20   echelon of the ,Church as a -- what's the word that would
      21   best describe that? Embarrassment?
      22         A.   Right. Right.
      23         Q.   Fair enough?
      24         A.   Fair enough.
      25         Q.   All right. An embarrassment such to the extent


      1    that Kartuzinski lost his position, correct?
      2          A.   Well, I mean, Kartuzinski didn't lose his position
      3    as a result of that. Kartuzinski, No. 1, was temporary from
      4    Day 1. And No. 2, we were happy that Richard was back.
      5    guess I could say, you know, we were happy that he was back.
      6    Alain was not considered stellar on the position.
      7          Q.   All right. Brian Anderson lost his position?
      8          A.   Yeah.
      9          Q.   And I believe he went through what's called a
      10   Committee of Evidence also?
      11         A.   Right.
      12         Q.   Correct?
      13         A.   I don't -- to be honest, Brian Anderson is not
      14   my-- under my charge, but --
      15         Q.   Well, let's not beat around the bush.
      16         A.   I know Brian Anderson --
      17         Q.   You're at the top of the heap over there.
      18         A.   Right.
      19         Q.   It's not like you don't know what's going on.
      20         A.   That's correct.
      21         Q.   Let's not bury our,head in the sand here. You
      22   know what's going on in the Church, if anybody does.
      23              I've talked to a lot of people.
      24         A.   Right.
      25         Q.   Some of these people can say that, you can't say


      1    that.
      2          A.   Yes.
      3          Q.   Would you agree with that statement?
      4          A.   Yeah.
      5          Q.   If anybody knows what's going on, you and Brian
      6    do. Nothing's kept from you. Fair enough?
      7          A.   Yes. I'm -- I'm not going to say -- there are
      8    certainly things that go on in OSA that he doesn't tell me
      9    about. They're not obligated to inform me of everything
      10   they do.
      11              But Brian -- I don't know how to say it. You
      12   know, Brian, I think, was put on what he sort of does best.
      13   He -- he's a community -- you know PR kind of guy. He's
      14   not -- he's not a sharpy that you would have run an
      15   organization, basically, he's -- you know, anyway.
      16         Q.   Well, if he's a spokesman though, then you would
      17   have to think he has to be at least entrusted with all of
      18   the information --
      19         A.   Yeah.
      20         Q.   -- otherwise he can't be a spokesman?
      21         A.   That's correct.
      22         Q.   Because reporters ask a lot tougher questions than
      23   I do.
      24         A.   Right.
      25         Q.   Agreed?


      1          A.   That's agreed.
      2          Q.   So he's entrusted with all the information?
      3          A.   Right.
      4          Q.   Whose decision was it to consult an attorney, an
      5    outside attorney? Not what was said, just whose decision
      6    was it to consult an attorney?
      7          A.   I assume it was -- it was OSA's decision. It's
      8    something that we always -- we always do, I mean.
      9          Q.   Well, I'm not blaming you, I think it's a wise
      10   move.
      11         A.   Right.
      12         Q.   And that was Bob Johnson?
      13         A.   Right.
      14         Q.   Okay. Did you speak with him?
      15         A.   No.
      16         Q.   Okay. When did the -- let's just call them --
      17   what's a good word for the higher up people in L.A.? What
      18   do you call them, the people that come immediately from L.A
      19   to Clearwater to say we need to check this out? What were
      20   they described as?
      21              That occurred, correct?
      22         A.   I don't know what -- who you're talking about.
      23         Q.   People from L.A. showed up in Clearwater going,
      24   hey, this Lisa McPherson thing ain't looking so good, right?
      25         A.   Like OSA people?


      1          Q.   I don't know.
      2          A.   I guess.
      3          Q.   People from L.A.
      4          A.   Oh.
      5          Q.   People from the big shot organization in L.A.
      6          A.   Okay. I think you're talking about OSA people.
      7          Q.   Yeah, I guess.
      8               MR. McGARRY: Give me some names.
      9               SPECIAL AGENT STROPE: Lynn Farney,
      10   Elliott Abelson, Glen Steilo.
      11         A.   That's OSA Legal.
      12         Q.   And they would be deemed as having the ability to
      13   tell everybody in Clearwater what to do? I mean, they're
      14   Senior to the Clearwater people?
      15         A.   They're Senior to the Clearwater OSA people.
      16         Q.   But I understand you're in a different --
      17         A.   Yeah.
      18         Q.   -- section or division.
      19              When did they show up? They've been here more
      20   than one time I'm sure.
      21         A.   Yeah.
      22         Q.   Because this thing, once it got restarted up after
      23   the Medical Examiner's report came out, busted loose, they
      24   were back here, correct?
      25         A.   Right.


      1          Q.   Okay. Well, when were they first here after
      2    December 5th?
      3          A.   I'm not -- I don't know totally. I'm not totally
      4    sure. It seems -- seems like some days afterwards. I'm
      5    really guessing, I don't know.
      6          Q.   Did you meet with any of them?
      7          A.   No, I did not.
      8          Q.   Who did?
      9          A.   I'm assuming that they met with OSA, the -- like
      10   Brian Anderson and those guys here.
      11         Q.   Okay. Who decided that all of the PC reports were
      12   going to go to L.A., the folders?
      13         A.   I do not know.
      14         Q.   Who's Annie Mora's boss?
      15         A.   I think she was under Brian at the time, I guess.
      16         Q.   All right. Well, we just talked to her and she
      17   said she boxed them all up and sent them, and they were sent
      18   to L.A., but she didn't know whose request that was.
      19              Do you know whose request that was?
      20         A.   I' don't know.
      21         Q.   Do you know why -- I mean, this is kind of under
      22   your area, right? Those folders are your -- under your
      23   division?
      24         A.   Well, at this point --
      25         Q.   They're not from OSA, they came from you?


      1          A.   That's correct.
      2          Q.   So nobody told you, we're taking your folders to
      3    L.A.?
      4          A.   No.
      5          Q.   Why wouldn't they tell you that?
      6          A.   Well, first of all, we have enough folders to fill
      7    Maas Brothers, you know what I mean.
      8          Q.   I know that. But this is a special folder, this
      9    is Lisa's folder.
      10         A.   Yeah.
      11         Q.   Filled a banker's box.
      12         A.   Really, at that point, you know, after the --
      13   after she had died, the family or whatever were informed,
      14   you know, the medical precautions were taken to protect
      15   anybody who might have been infected and whatnot, after that
      16   point it's pretty much over to -- to OSA to sort out the --
      17   and deal with the Lisa McPherson cycle.
      18              I mean, we, you know, made personnel -- some
      19   organizational changes in terms of, you know, certainly who
      20   would be allowed at -- to stay at Flag, things like that
      21   were done from my part, but in terms of sorting out the --
      22   handling the Lisa McPherson cycle, it's pretty much over to
      23   OSA at that point.
      24         Q.   So you don't know -- you don't know who gave the
      25    authority to send all the -- or asked for all these files to


      1    be sent to L.A., that's the bottom line?
      2          A.   Right.
      3          Q.   Who would you surmise?  Would it be Brian Anderson
      4    would have the authority to do that, or would it be from
      5    somebody in L.A. to tell him, hey, we want the files, we
      6    want the PC -- her PC folder in L.A.? I mean, guessing, you
      7    know the structure better than I do, who would make the
      8    call?
      9          A.   Just guessing, which is -- OSA Int, which is where
      10   these big guys came from or whatever, would be the ones to
      11   have them sent. I would assume to be able to look at the
      12   caretaker reports and what had happened.
      13         Q.   I'm not surprising you with the information that
      14   those folders went to L.A., am I? You knew that, correct?
      15         A.   No, I guess I didn't, really. I guess I didn't.
      16         Q.   So you don't even know.
      17              Do you know where they are now?
      18         A.   No, I don't know.
      19         Q.   Who does? Who knows where the folders are now?
      20         A.   I don't know. I would assume Brian or -- not
      21   Brian, but OSA Int or OSA would know.
      22         Q.   So I've got -- to get that answer I have to go to
      23   L.A.?
      24         A.   No.
      25              MR. POLLI: Are you saying OSA Int? What are


      1    you  saying?
      2               MR. McGARRY: International.
      3          A.   OSA, or even OSA Flag would know where the folder
      4    is.
      5          Q.   We obtained, through a subpoena, a number of
      6    caretaker documents that were removed, I assume from what
      7    you've said, her PC folder. Okay?
      8          A.   Which were removed from her PC folder?
      9          Q.   And given to the lawyers and then given to me.
      10         A.   Okay.
      11         Q.   That's how it works. I subpoena them, I've been
      12   going through the lawyers, and then they comply with the
      13   subpoenas.
      14         A.   Okay.
      15         Q.   I asked for all those caretaker notes and I got
      16   them. I got -- well, I got a lot of them. There's some
      17   missing.
      18              Are you aware that some are missing?
      19         A.   Yes.
      20         Q.   I mean, there's a big search going on in your
      21   building looking for these things.
      22         A.   I'm aware of that.
      23         Q.   And I believe there's been a guy who has been
      24   specifically employed to take that task on, and his name is
      25   Glen.


      1          A.   That's right.
      2          Q.   Glen Steilo.
      3          A.   That's right.
      4          Q.   Did he approach you in reference to this PC folder
      5    and talk to you? And if he did, when?
      6          A.   No, he didn't speak to me directly. I know that
      7    he -- I know that he has been working on collecting any --
      8    finding any papers or any write-ups or anything on Lisa.
      9          Q.   But you never had any contact with him?
      10         A.   No.
      11         Q.   He just came on-board kind of recently, correct?
      12         A.   Fairly recently, yeah.
      13         Q.   All right. As a matter of fact, my recollection
      14   is the subpoena that I filed or served upon the Church to
      15   get those caretakers' notes occurred before he was here from
      16   California.
      17              My question, is, as being Captain over there, who
      18   is the person that gathered up the caretakers' reports out
      19   of that PC folder and handed them to Sandy and Lee Fugate?
      20              You know Sandy and Lee Fugate, correct?
      21         A.   I've --
      22         Q.   Sandy Weinberg.
      23         A.   I've met them, yes.
      24         Q.   Who from your organization did that?
      25         A.   I don't know.  It probably would have been -- I'm


      I    assuming it was OSA that did that. Annie Mora maybe.
      2          Q.   She says no.
      3          A.   Okay. I don't know.
      4          Q.   All right. Who is the person that when -- I don't
      5    want to know any privileged conversations between lawyers
      6    and  people from the Church, but who is the person that
      7    answers the phone over there when Sandy or Lee calls up
      8    saying I need something, I need this, blah, blah, blah?
      9    Who's that person? Is it Ben Shaw?
      10         A.   I -- I believe so.
      11         Q.   Now it's Ben Shaw?
      12         A.   Yes.
      13         Q.   Ben Shaw is kind of new too, correct?
      14         A.   That's correct.
      15         Q.   February --
      16         A.   Except Ben was here many years ago.
      17         Q.   Well, I know. But he wasn't here November of '95
      18   through --
      19         A.   That's correct.
      20         Q.   -- well, till the beginning of '97?
      21         A.   That's right.
      22         Q.   When did he get here?
      23              He took over Brian Anderson's spot?
      24         A.   That's right.
      25         Q.   When did he get here?


      1          A.   I think it was -- I don't know. Maybe early this
      2    year.
      3          Q.   Who picked up the phone in that building when Lee
      4    or Sandy called prior to Ben Shaw?
      5          A.   I mean, any time I've called over there, they have
      6    a line, you call and various people pick it up.
      7          Q.   You know what I'm saying. I want to know who
      8    their contact person is with the State. Who do they deal
      9    with when they say, the State's done it again, I got another
      10   subpoena, they want some more documents? Who is it they're
      11   calling to get them? Who is that person? You're the
      12   Captain, you should know.
      13              MR. POLLI: Before Ben Shaw and after Brian.
      14         Q.   It might have been Brian?
      15         A.   Humberto, I guess. Humberto or Annie or Judy.
      16   Would have been one of those.
      17         Q.   All right. You never -- did you ever see that PC
      18   folder again after you saw it that night when you had it
      19   ordered up over there --
      20         A.   No, I did not.
      21         Q.   -- December 5th?
      22         A.   No.
      23         Q.   Never seen it again?
      24         A.   (Witness shakes head negatively.)
      25         Q.   And other than the document that you indicated you


      1    read that was Marcus Quirino's summary from caretakers'
      2    notes, have you read any other documents in reference to
      3    Lisa's care, well-being -- let me be real broad -- any other
      4    documents, have you ever read any other documents in
      5    reference to Lisa McPherson?
      6               MR. POLLI: Excluding what I gave her?
      7               MR. McGARRY: Yeah. We're not talking about
      8    your attorney-client stuff here.
      9          A.   No.
      10         Q.   Okay. Were you ever aware of any destruction of
      11   documents, either by accident or intentionally, in reference
      12   to Lisa McPherson's notes or reports?
      13         A.   No.
      14         Q.   Did you ever discuss with Brian Anderson his
      15   destruction of caretakers' summaries?
      16         A.   No.
      17         Q.   Are you aware that that occurred?
      18         A.   I only became aware because he told me about it.
      19   (Indicating Mr. Polli)
      20         Q.   Okay. That's fair.
      21              Are you aware when Marcus did that summary? When
      22   did he do this, actually type them up on his own -- in his
      23   own fashion?
      24         A.   I believe he did it that night. I thought he did
      25   it that night. Could have been the next morning.


      1               MR. McGARRY: Do you need a break by any
      2    chance? Because we're going to be here a little bit
      3    longer.
      4               MR. POLLI: I have to be back in Tampa at
      5    1:30. I know we were a half an hour, 20 minutes late.
      6    I want to cut that as close as I can.
      7               MR. McGARRY: All right. We'll work with you
      8    on that.
      9               MR. POLLI: Janet ought to be little less.
      10              MR. McGARRY: Why don't I turn it over to the
      11   Detectives. I know I have other notes I might want to
      12   address. Why don't we give it to them and if you'll
      13   indulge them, we'll continue.
      14                       EXAMINATION
      16         Q.   Debbie, have you ever been a Case Supervisor?
      17         A.   I have.
      18         Q.   Okay. How about a Senior Case Supervisor?
      19         A.   No, I have not.
      20         Q.   Okay. So as a Case Supervisor, did you ever
      21   handle any isolation watches like Lisa went through?
      22         A.   No, never.
      23         Q.   So you just did auditing type of  stuff?
      24         A.   That's right.
      25         Q.   RTC, Religious Technology --


      1          A.   Center.
      2          Q.   Center, okay.
      3               My understanding so far, which is very limited,
      4    that is sort of an organization in the Church to make sure
      5    that everything is being done correctly. Is that -- is that
      6    sort of, you know, like a police the police type of thing?
      7          A.   Basically -- that's basically it. I mean, they
      8    don't police everything, they police majorly the proper use
      9    of...
      10         Q.   Okay. Now, would they have jurisdiction or
      11   authority over you and OSA at the same time? I mean, is
      12   this an upper level organization?
      13         A.   Yes. They -- they hold the trademarks, basically.
      14   And if -- if they find that an organization is misusing the
      15   trademarks in some way, then they have -- they definitely
      16   have certain rights to, you know, give warning, demand that
      17   it be corrected.
      18         Q.   Would they have -- would they have the authority
      19   to investigate the Lisa case of her dying at the Church
      20   property?
      21         A.   Would they have the authority? It's not something
      22   that, to my understanding, is -- I mean, yeah, I mean -- I
      23   don't know how to say this.
      24         Q.   I'll tell you we're getting back to Mr. McGarry's
      25   question. Apparently someone in the Church launched an


      1    investigation into Lisa, and he was asking about the big
      2    guys in California.
      3          A.   Right.
      4          Q.   And the people -- eventually all of us answer to
      5    somebody at the top.
      6               Now, my understanding is RTC came here to
      7    Clearwater. Are you familiar with that?
      8          A.   RTC is here. We have RTC people here in
      9    Clearwater at all times. -
      10         Q.   I'm referring to people like Jane Jenczh.
      11   Jane Jenczh --
      12         A.   She's not RTC, she's OSA Int Staff.
      13         Q.   She's OSA International?
      14         A.   That's correct.
      15         Q.   Okay. So she would have been somebody -- one of
      16   the big guys from California?
      17         A.   That's right.
      18         Q.   Okay. Now, are you aware of her paying a visit
      19   here?
      20         A.   Yes, I am.
      21         Q.   Okay. What was that visit for?
      22         A.   I know that there was some people that came here
      23   from OSA International, that came to the OSA area here to
      24   basically  -- I think that, you know, included Brian coming
      25   off his position. They were working on getting the unit set


      1    up better. I  know that they put a couple people on, you
      2    know, into the -- the OSA unit.
      3          Q.   Sort of a shake-up, would that kind of --
      4          A.   I wouldn't describe it as a shake-up. I would
      5    describe it as an upgrading of the OSA operations.
      6          Q.   Okay. Jane Jenczh was apparently some type of an
      7    Auditor. It's been explained to me that she has -- she came
      8    here and she did a Sec Check in reference to
      9    Lisa McPherson's case.
      10              Now, what would that mean? Could you explain
      11   that?
      12         A.   I don't know exactly what she did. I can tell you
      13   what a Sec Check is.
      14         Q.   Well, how about explaining -- if I was told that
      15   Jane Jenczh from OSA Int came here and did a Sec Check in
      16   reference to Lisa McPherson, explain that. That's what I've
      17   been told under oath.
      18         A.   I don't know. I mean a Sec Check is something
      19   that is a confessional, that is part of the auditing
      20   procedures that we do. And, you know, it's one where you
      21   can -- you -- you are able to relieve yourself of things you
      22   -- feel you have done wrong or done bad that, you know, were
      23   not right. If you cheated on your wife or whatever.
      24         Q.   But those aren't things that you go ahead and you
      25   ask Jane Jenczh to give you a Sec Check for. This is a


      1    Sec Check ordered by Jane Jenczh of people. This is a
      2    little different. You know, if I want absolution from my
      S    priest, I go in and I explain to him that I've been cheating
      4    on my wife and ask for forgiveness. My priest doesn't knock
      5    on the door and say, sit down, you're going to get a
      6    Sec Check right now, we're going to find bad things you've
      7    done. I would consider that more of an interrogation.
      8          A.   It's not like that though. First of all, Jane is
      9    an Auditor. She wasn't -- to my knowledge, I don't know of
      10   her ordering Sec Checks. She's an Auditor, and she -- I do
      11   know that she audited people.
      12         Q.   In reference to Lisa McPherson?
      13         A.   I don't know that it was in reference to
      14   Lisa McPherson. I know that -- from my understanding of it,
      15   it was in reference to OSA and, you know, basically
      16   making -- I mean, it's something we do -- we do all the
      17   time. We are continuously -- you know, people come --
      18   people come to my organization as well and, you know, do
      19   things to get it improved, to better set up something, to
      20   put some more people on different positions, audit people,
      21   train people.
      22         Q.   Okay. Are you aware as the Captain that RTC came
      23   here or was here to Clearwater and RTC ordered the demotion
      24   of everyone?
      25         A.   No. That is -- I do not know of that happening.


      1          Q. Okay. How do you explain that anyone and
      2    everyone, with probably the exception of yourself right now,
      3    that, had any responsibility in the Lisa McPherson case has
      4    been demoted? Whether you want to call it demotion or not,
      5    they're in a lesser of a job.
      6          A.   Right.
      7          Q.   How do you explain that? It's been explained to
      8    me that was RTC's doing when they came here. Now, how do
      9    you explain that?
      10         A.   Well, first of all, RTC is here all the time.
      11   They didn't -- I do not know of somebody coming for that
      12   reason.
      13         Q.   Okay. They have an office here?
      14         A.   That's right.
      15         Q.   Okay.
      16         A.   I do not know of any involvement that they had in
      17   it. I do know that Alain -- Alain Kartuzinski was temporary
      18   from the beginning --
      19         Q.   Okay. Stop right there.
      20         A.   Okay.
      21         Q.   I read an article in the Source magazine that was
      22   two and a half pages long that said Alain Kartuzinski was
      23   the Senior Case Supervisor of Flag Land Base -- and in fact,
      24   I have both of the articles, in English and German. And not
      25   one place in the article did it say Alain was a temporary


      1    Senior Case Supervisor. In fact, the article praised him.
      2               Are you familiar with the article? Did you see it
      3    in Source magazine?
      4          A.   Yeah, I guess.
      5          Q.   Okay. Nowhere in that article did it talk about
      6    Alain Kartuzinski being temporary.
      7          A.   Yes. But you would never promote someone as
      8    temporary. I mean, I think -- Richard Reese is the
      9    Senior CS and he had been so for many years. Richard went
      10   onto training. I'm not trying to -- also at the same time
      11   I'm not saying that Alain was perfect in every respect or
      12   something, had nothing to do with it.
      13         Q.   And you have -- let me clarify so you feel a
      14   little more comfortable. I know you're feeling
      15   uncomfortable right now.
      16              You have no responsibility for Alain Kartuzinski
      17   other than you were his boss, actually, at the top?
      18         A.   Right.
      19         Q.   But from the day-to-day operations it's apparent
      20   you were not kept very aware.
      21         A.   Right.
      22         Q.   So you don't have to justify Alain Kartuzinski.
      23              All I'm saying to you, I find it very unusual,
      24   you're the second person that said Alain-Kartuzinski was
      25   temporary, yet I read this glorifying article in the Source


      1    magazine that said he was the man. And that was pretty
      2    impressive when I read that, this guy is really up there,
      3    according to the Source article.
      4          A.   Right.
      5          Q.   But Richard Reese, you're saying, was the person.
      6    So Alain just simply went back to being an Auditor or
      7    training because Richard came back, or was it from the
      8    Lisa McPherson thing?
      9          A.   Well, we have been doing a pretty major training
      10   evolution on all of our technical staff. This has been
      11   something that's been being worked on since May. I don't
      12   know -- it was something that was -- it was announced
      13   internationally throughout Scientology. It was something --
      14   a whole new sort of training program that began.
      15              And, you know, Richard -- Richard went off to do
      16   it intensively full-time for many months. And Alain, you
      17   know, covered for him while he was doing that. Shortly
      18   after Richard came back, then Alain himself went onto
      19   full-time training.
      20              You know, I mean, I also feel that Alain was
      21   pretty overtaxed. We were certainly happy to have Richard
      22   back.
      23         Q.   Okay. Back to originally, I know I cut you off,
      24   back to originally I asked you, if you know, how is it that
      25   everyone involved with Lisa McPherson has been demoted? And


      1    I mean everybody. I mean, we've -- every time we talk to
      2    somebody, it's all the way down the line. And basically --
      3          A.   I only know -- I know of Alain, Brian and -- I
      4    don't know. I know of Alain and Brian.
      5          Q.   Okay. Alain and Brian.
      6               Okay, you have Judy Goldsberry-Weber.
      7          A.   She's the same -- I thought she's on the same --
      8          Q.   She went from Deputy MLO to being a seamstress.
      9               We have Janice Johnson from being MLO to
      10   Word Clear. It may not be a demotion, but it's a different
      11   post.
      12         A.   Yeah. She never wanted to be particularly --
      13         Q.   MLO?
      14         A.   Yeah. She wanted to be technical.
      15         Q.   You don't have an answer for that; is that
      16   correct?
      17         A.   That's correct.
      18         Q.   And you're not aware of seeing any documents
      19   saying that RTC ordered that, all of them?
      20         A.   No, I've never heard of that.
      21              I mean, we also -- I can tell you also, even
      22   with -- with Janice, we -- one of the things -- I mentioned
      23   that we kind of did some things organizationally to make
      24   sure this never happened again.
      25              One of the things, we didn't -- we wanted to make


      1    sure that a Medical Liaison Officer actually didn't have any
      2    medical training, because the Medical Liaison Officer is
      3    supposed to -- supposed to, you know, deal with doctors and
      4    not -- they're a liaison, they're not themselves someone
      5    that would practice. So that was also partly the
      6    consideration with Janice.
      7          Q.   Okay. Now, since you mentioned that, what is the
      8    new -- what is the new ruling as far as handling
      9    PTS Type III personalities with the Church now?
      10         A.   We don't have -- anybody who is, you know,
      11   unstable like that is not allowed at Flag, basically. They
      12   can -- they're recommended to go to a proper medical doctor,
      13   you know.
      14         Q.   So basically, if -- if someone goes crazy this
      15   afternoon at 2:10 and runs out and runs down the street and
      16   the police pick her up, she's going to go to Morton Plant?
      17         A.   That's correct.
      18         Q.   Okay. Do you know what the Hubbard technology or
      19   writings or scriptures say in reference to dealing with a
      20   violent PTS Type III, if you have any?
      21         A.   Yes.
      22         Q.   Okay. Do you know what they are? What -- how are
      23   you supposed to deal with a violent PTS Type III?
      24         A.   Well, from my understanding of it, you're supposed
      25   to, basically, attempt to get the person to, you know, sleep


      1    and good -- better nutrition and in -- in an environment
      2    that's very calming until they come out.
      3          Q.   Okay. Now, I understand from my research that
      4    would be the Technology for dealing with a PTS Type III.
      5    added the word -- maybe you didn't pick it up, the "violent"
      6    word I added in there. Because from our findings Lisa was
      7    violent. I'm adding the "violent" word in there.
      8               Is that the same thing, just to try to calm them
      9    down?
      10         A.   Yes.
      11         Q.   Earlier you said that Lisa could leave if she
      12   wanted to leave.
      13              Now, you were getting briefings from Alain and
      14   Janet Herring, verbal briefings. At any time did they tell
      15   you that Lisa asked to leave or tried to leave or any of
      16   that?
      17         A.   No.
      18         Q.   Did they ever tell you that she was punching out
      19   caretakers and that they were forceably holding her down on
      20   the bed?
      21         A.   No. I didn't -- I mean, I do know that she
      22   punched a caretaker. I saw the person with the black eye,
      23   asked her what happened. And that's when I found out that
      24   she had punched her. But I wasn't aware of anybody holding
      25   her down.


      1          Q.   Okay. Now, that kind of -- we have that in
      2    testimony under oath and we have it in caretaker reports.
      3               Now, that seems --
      4          A.   Okay.
      5          Q.   Now, that seems to be a big difference from what
      6    you earlier testified to, you know, as far as your handling
      7    of this.  You know, if Lisa wanted to go, my God, we'd let
      8    her go.
      9          A.   Yet we wouldn't let her run down the street naked.
      10         Q.   But if we look at the things I just told, holding
      11   her down forceably on the bed, punching out caretakers,
      12   attempting to leave, that's a big difference from what you
      13   said earlier.
      14              Now, do I take it. that's not the usual situation,
      15   the Lisa  McPherson case is not the normal isolation watch?
      16         A.   I mean, we definitely -- I don't know. I mean,
      17   I've been here for 18 years and I don't know of anyone --
      18   anyone being quite that state.
      19         Q.   Right.
      20         A.   So yes, I mean, I would say that I think that my
      21   staff didn't know exactly what --
      22         Q.   That's why I asked you about the violent.
      23   Remember I asked what's the technology to deal with a
      24   violent PTS? Apparently this was a different type
      25   situation.


      1          A.   Well, I think that most -- we've dealt with some
      2    people that have been, you know, unstable and even -- even
      3    maybe slightly, you know, wild --
      4          Q.   Crazy?
      5          A.   -- like that, you know.
      6          Q.   Yeah.
      7          A.   But usually after they sleep -- and sometimes, you
      8    know, they'll sleep like for 10, 14 hours or something --
      9    you know, and eat something and drink and whatever, they'll,
      10   you know, come out, of it and seem, you know -- so that --
      11   the -- when I say I don't think they knew, you know, I don't
      12   think anyone quite knew what to do with -- that this
      13   situation kept going on and on and, you know, she wasn't
      14   sleeping and things like that.
      15         Q.   Were you ever updated as the boss by these people
      16   or anyone to tell you that while Lisa was staying at the
      17   Cabanas that she was receiving prescription drugs, herbs,
      18   vitamins and assorted potions?
      19         A.   I'm not aware of prescription drugs. I do know
      20   that there was, you know, attempt to give her vitamins,
      21   calcium magnesium mixture.
      22         Q.    Do you know what those things medically do,
      23   calcium magnesium and all that?
      24         A.    Yeah, it's supposed to -- it's supposed to relax
     25    you.


      1          Q.   Like a sedative?
      2          A.   Magnesium -- it's not really a sedative, but
      3    magnesium is -- you know, you relax from it, basically.
      4          Q.   Okay.
      5          A.   And I know that there was some -- there is an
      6    herbal thing that, you know, supposedly helps you sleep.
      7          Q.   Velarian root?
      8          A.   Yeah.
      9          Q.   If you were aware of the conditions I just
      10   explained to you, and I'll read -- I'll bring them up again,
      11   Lisa's in a motel room, Room 174, she's receiving
      12   prescription drugs, herbs, Velarian root, vitamins,
      13   et cetera, she's attempted to leave, she's punching out
      14   caretakers, she's being held down in the bed, would you have
      15   intervened into this and said, you know, hey, time out,
      16   something's wrong here, we need to move to something else?
      17   I mean, now you're talking about medical care if they're
      18   really violent. Would you have intervened into this as the
      19   boss?
      20         A.   Yeah. I mean, I certainly would have -- I
      21   certainly would have looked into it.
      22         Q.   The reason I ask you, you're one of the few people
      23   we've talked to who apparently had jurisdiction and
      24   authority over the situation. So you would have intervened
      25   into this?


      1          A.   Yeah. I would say I would have looked into it,
      2    more closely.
      3          Q.   Okay. As the boss, did you -- after this all
      4    happened, did you investigate into this or was that, somebody
      5    else's job?
      6          A.   Well, I --I would say it got kind of split in
      7    half. I -- I investigated into, you know, what exactly --
      8    what exactly is our policies on this, what -- you know, what
      9    should they have been, how could any of this have been
      10   prevented.
      11         Q.   And that led to your new changes, organizational
      12   changes?
      13         A.   That's right.
      14         Q.   Okay. Now, in those organizational changes, is
      15   that -- I don't want to say demotions again, but in those
      16   organizational changes, have you -- is that the reason why
      17   some of the people were moved out?
      18              You said Janice --
      19         A.   That was definitely with Janice.
      20         Q.   -- who's an M.D., now no longer is going to be an
      21   MLO?
      22         A.   Right.
      23         Q.   The person that is MLO is just that person who
      24   can--
      25         A.   Call a doctor.


      1          Q.   -- call a doctor?
      2          A.   Right. Exactly.
      3          Q.   All right. Have you been involved at all or had
      4    any knowledge of the clean up of Room No. 174 the night of
      5    or the morning after Lisa died?
      6          A.   A little bit.
      7          Q.   Okay. Could you tell me about that?
      8          A.   I know that it was part of this whole sort of
      9    meningitis scare, in that it was -- it was -- she was -- I
      10   know that there was -- I was actually there when the
      11   instructions were issued to disinfect it and find out
      12   exactly what exact materials to use to make sure it's
      13   disinfected.
      14         Q.   Okay. Did you -- did you witness the room, what
      15   it looked like before it was cleaned up?
      16         A.   No.
      17         Q.   Okay. Now, you said that you looked in Lisa's PC
      18   folder and that you -- you had an opportunity and you kind
      19   of breezed through some of the caretakers' reports?
      20         A.   That's right.
      21         Q.   Did you look at any of the last three days of the
      22   caretakers' reports? I'm just thinking, as an investigator,
      23   I would like to, if something happened, I would like to
      24   start from there and go backwards. Did you look at any of
      25   the last three days?


      1          A.   I certainly looked at the most recent reports.
      2          Q.   Can you remember reading -- can you give me any
      3    substance of that at all?
      4          A.   Let's see. I guess I -~- I really only -- I
      5    remember reading, you know, points about whether or not
      6    she -- I guess that it seemed like she was -- she was
      7    sleeping more. She definitely didn't seem to be violent in
      8    the more recent reports. You know, tried to get her to
      9    drink a protein drink, wouldn't.
      10              Trying to sort out the different things that I've
      11   seen since and -- you know, it was pretty much, you know,
      12   mostly about --
      13         Q.   Anything about weight loss by the caretakers?
      14         A.   No. No.
      15         Q.   Do you remember any of the authors on those last
      16   three reports, any of the people who wrote them, the names?
      17         A.   No. No, I don't.
      18         Q.   Okay. The reason I ask is, we're missing the last
      19   three days.
      20         A.   Right.
      21         Q.   And that's going to go to my next question.
      22              In my research on auditing folders, which is --
      23   this, is from the book. An auditing folder being a PC
      24   folder.
      25         A.   Right.


      1          Q.   I've highlighted that first line there. It says
      2    omissions from the folders and complete loss of folders is a
      3    very serious matter.
      4          A.   It is a very serious matter.
      5          Q.   Now, it appears to us that we're missing several
      6    days, not only the last three days, but several other days
      7    of reports, these caretakers' reports that were in the PC
      8    folders. Do you know of any investigation started by the
      9    Church as to who lost these folders?
      10         A.   I know that -- I know that this has been a matter
      11   of great search to try and find these, because I know this
      12   is a big point and that, you know --
      13         Q.   Do you know if they've started a
      14   Committee of Evidence on that at all?
      15         A.   I don't know that a -- a Committee of Evidence --
      16   I don't know of a Committee of Evidence being called,
      17   because I don't think they know even who or --
      18         Q.   How?
      19         A.   It was --
      20         Q.   Who to charge?
      21         A.   That's right. That's right.
      22         Q.   Because I read in the last paragraph, it says a
      23   Committee of Evidence shall be called because it's a serious
      24   offense.
      25         A.   Right. But we haven't found --


      1          Q.   Who's responsible?
      2          A.   That's right.
      3          Q.   Okay, Security. I want to make this my last
      4    question.
      5               Paul Kellerhaus was some type of
      6    Director of Inspections, is that right?
      7          A.   That's right.
      8          Q.   He was in charge of Arthur Baxter, who was the
      9    Security Chief at the time?
      10         A.   That's right.
      11         Q.   Those, of course, are two, more of my names on the
      12   list who are no longer in their positions. But anyway,
      13   where did they fall in the chain of command?
      14              Paul Kellerhaus, did he eventually answer to you?
      15         A.   No.
      16         Q.   Okay.
      17         A.   He's in another one of these networks that's
      18   separate to me. But he -- I do know that Paul, we call him
      19   PK, was pretty much full-time Security Chief anyway, and
      20   that was how -- to my knowledge, I don't recall him being
      21   demoted as, you know, like a Com Ev and demoted. It was
      22   more, that's all he did all day anyway, and so basically it
      23   was just decided to have him be it.
      24         Q.   All right. So if Alain Kartuzinski,
      25   Janice Johnson -- Alain Kartuzinski in auditing, and he was


      1    getting the reports because of being the Senior Case
      2    Supervisor, and then Janice Johnson is the MLO, she's
      3    apparently taking an active role in Lisa's care, and that's
      4    from the caretakers' reports, and Paul Kellerhaus in
      5    Security, okay, running this watch, and we've had people
      6    testify that the watch responsibility was Security's, are
      7    those the three people, short of anybody above them, that
      8    are running this thing, I mean in the organizational flow?
      9          A.   Yeah.
      10         Q.   Now, they're not answering to anyone though?
      11         A.   Well, I mean, first of all, from my understanding,
      12   I thought that the -- the watch was initially set up -- was
      13   not a security -- was not set up for security, to my
      14   knowledge, it was set up to have someone with her at all
      15   times.
      16         Q.   And that was the Kartuzinski deal?
      17         A.   Right.
      18         Q.   With Gaby Sanchez, Gabriella Sanchez, and she sets
      19   up the watch, but that was on Kartuzinski's technical side?
      20         A.   Right. Right.
      21         Q.   Okay.
      22         A.   Kartuzinski was considered the top technical
      23   person, so he doesn't really answer up to somebody.
      24         Q.   Especially, in that auditing, that auditing type of
      25   field?


      1          A.   That's correct.
      2          Q.   Okay. Then Paul Kellerhaus, who would he answer
      3    to if he had to answer to somebody? But I understand from
      4    talking to everyone he wasn't answering to anyone either.
      5    But who -- he doesn't answer to you. Who does he answer to?
      6          A.   He answers to -- well, he's under a network
      7    that's -- I guess the In Charge overall here locally is --
      8    her name is Monica Quirino. She's Marcus' mother, actually.
      9          Q.   Okay.
      10         A.   And, you know, there's --
      11         Q.   What division is that? Or just give me a name.
      12         A.   Well, I'll just draw out one thing. I'll make it
      13   easy.
      14         Q.   Okay.
      15         A.   Like I have the Flag Service Organization, and
      16   under that there's several divisions. Mostly this is like
      17   technical services, auditing and training services, and
      18   there's other administrative areas, whatever. Then
      19   there's -- well, you have like Division 7. Division 7 has
      20   in it two departments that are separate. One is
      21   Department 21 and one is Department 20. Department 20 is
      22   OSA. That's the whole -- all of -- Brian Anderson and all
      23   those guys.
      24         Q.   Okay. And they deal with external issues with the
      25   Church?


      1          A.   Yeah.
      2          Q.   Okay.
      3          A.   And then Department 21 is called the
      4    Office of the LRH Communicator, and that's -- Monica Quirino
      5    is the LRH Communicator for the Flag Land Base. And then
      6.   underneath her there's Security, there's, you know, some
      7    other -- some other networks that have a sort of supervisor
      8    or policing kind of function.
      9          Q.   Okay. Policing as far as Staff?
      10         A.   Yeah.
      11         Q.   Security, I think, deals with like the externals
      12   and Clearwater Police Department and all of that, but
      13   underneath them would be some people that would deal with
      14   policing of Staff or where they're supposed to be?
      15         A.   It's not really like under Security. It's like
      16   Security is one section, then there's other, like, people,
      17   that --
      18         Q.   Okay. So Kellerhaus' position at the time of Lisa
      19   being there was this Director of Inspections. Now, is that
      20   over everything there or was that just over Security?
      21         A.   Just over Security. It would be also over -- you
      22   know, they have -- they would police and make sure that any
      23   kind of internal ethics matters, matters of ethics or
      24   justice would be --
      25         Q.   Like somebody stealing cookies from --


      1          A.   From the Staff, yeah.
      2          Q.   I have one last question: It's been told to me
      3    that Benetta Slaughter, the night that Lisa McPherson was at
      4    Morton Plant Hospital, she called Arthur Baxter, the
      5    Chief of Security, and told Arthur Baxter to get a room for
      6    Lisa at the Cabanas, and Arthur went to Janet Herring and
      7    got the room.
      8               Now, how does that happen? I know
      9    Benetta Slaughter is up there as OT-VIII, I think, or
      10   whatever, but she's not part of the Staff, she's not part of
      11   the Church other than --
      12         A.   Unh-unh.
      13         Q.   I find that very unusual. Do you have any
      14   explanation for that?
      15              As a matter of fact, when Arthur gave the
      16   testimony, it was a matter of fact, yes, I got a call from
      17   Benetta Slaughter, she told me to get a room for Lisa. I
      18   went to Janet Herring and she assigned Room 174. And it was
      19   like Debbie Cook talking. And I was going, geez, how does
      20   Benetta Slaughter call up -- is that just respect for the
      21   OT-VIII position or how does that happen?
      22         A.   Benetta definitely does not have any command
      23   over --
      24         Q.   Anybody?
      25         A.   -- us, right.


      1               I don't know really. Doesn't really -- that data
      2    doesn't make any sense.
      3          Q.   Okay.
      4          A.   It's possible that she called in to ask for
      5    assistance to set up a room or something like that.
      6          Q.   All right.
      7               DETECTIVE SERGEANT ANDREWS: I'm done. I'm
      8    sorry it took so long.
      9                          EXAMINATION
      11         Q.   But she couldn't order a room, she didn't have any
      12   authority to order a room?
      13         A.   She wouldn't order Security or -- or one of the
      14   executives. I mean, she could certainly call up the hotel
      15   and say I'd like to book a room, but, you know ...
      16         Q.   I've just got a couple of questions.
      17              You touched on the Sec Checks with
      18   Sergeant Andrews. What does Sec Check stand for? Is that
      19   Security Check?
      20         A.   Security Checking.
      21         Q.   What would be the reason to Security Check people
      22   who are scheduled to give testimony in this case in
      23   particular?
      24              MR. POLLI: I'm sorry. Ask your question
      25   over again, please. I don't want to stretch this out,


      1    but--
      2          Q.   What would be the reason to Security check people
      3    who are scheduled to give testimony in these proceedings
      4    today?
      5          A.   If it were done -- you know, like, I don't know
      6    the reason that you Security Check anyone that is -- which
      7    is done a lot. I mean, the confessional technology is used
      8    a lot. It's not like, you know, certain people screw up or
      9    something and they get Security Checking. It's something --
      10   like, you know, I probably myself had, oh, I don't know, 30
      11   Security Checks. Any Staff member has had many
      12   Security Checks. They're not -- it really -- and I can even
      13   show you in the bulletin where it changes --
      14         Q.   But why would it be done to people who are
      15   scheduled to testify in. this matter?
      16         A.   Who are scheduled to testify in this matter?
      17         Q.   Specifically those people. Not general
      18   descriptions of that procedure, but why would it be done to
      19   people who are going to testify in this subpoenaed manner?
      20         A.   You want me to suppose, right? I can only say
      21   that would be, I don't know, to make sure that there wasn't
      22   something that, you know, they were killing themselves
      23   about, you know. I know that -- for example, I do know that
      24   a couple of staff, you know, felt very bad about what had
      25   happened, you know. I think that --


      1          Q.   Of course, that wouldn't fit into Security Check.
      2          A.   That is --
      3          Q.   Is it a possibility that maybe the organization
      4    wanted to assure that there was no damaging information
      5    would come out of these hearings?
      6          A.   No. I mean --
      7          Q.   If you have someone supposed -- just possibly
      8    someone wants to get out of the Church or has something
      9    negative to say, something negative about the Church, is
      10   that somebody you would Security Check, somebody that
      11   maybe --
      12         A.   I guess if someone felt dissension, yeah. I guess
      13   it would be something that we feel when someone has done
      14   things wrong that are withheld, that they tend to feel --
      15   that tends to be the cause of dissension and so, yes,
      16   someone is --
      17         Q.   So you can order a Security Check?
      18         A.   Yes.
      19         Q.   Can you order Security Checks on anybody?
      20         A.   I can. It's a technical procedure so, therefore,
      21   it -- it won't always be done, because it's a point of
      22   whether or not it's technically the correct thing to do for
      23   the person. So I may suggest one be done, it's up to a -- a
      24   Case Supervisor or a technical person to --
      25         Q.   I don't want to belabor the point then.


      1               Who was in charge of the watch as far as you're
      2    concerned? Who could have said, It's over, it's done; had
      3    all the knowledge what was going on, could have said it's
      4    over?
      5          A.   Alain Kartuzinski.
      6          Q.   So he was looking in on Lisa, he knew what was
      7    going on, he ultimately could have said it's over?
      8          A.   Right.
      9          Q.   And that was more the spiritual end of it.
      10              Who as far as the medical end of the watch could
      11   have said, Things are getting out of hand here, it's over?
      12         A.   Well, I mean, any -- frankly, any of the people
      13   that were on watch could have -- could have reported that,
      14   you know. The impression that I got was that there didn't
      15   seem to be a realization of -- of a physical condition.
      16   But, you know, I mean, as far as I -- as far as I
      17   understand, any of the watchers could have said, look,
      18   there's something really wrong with her or I think she
      19   should go to a doctor or -- and certainly Janice.
      20         Q.   All right.
      21         A.   You know, Janice or Laura would have been even --
      22   the even more responsibility ones to say, hey, she doesn't
      23   look good or something like that.
      24         Q.   You mean more responsibility in the fact that they
      25   both have medical training, they're both doctors?


      1          A.   Yeah, they both worked in the Medical Liaison
      2    Office.
      3          Q.   Was it coincidental that Laura and Janice are both
      4    doctors and they're assigned to this watch? Is that
      5    something that was pre-planned?
      6          A.   No, I think it was coincidental that -- no, I'm
      7    sorry, I think it was intentional that they were -- that
      8    they were originally posted in the Medical Liaison area.
      9    Later we decided that that was a bad idea, but, you know,
      10   initially -- you know, in terms of like, we're talking about
      11   caring for, you know, making sure she bathes and goes to the
      12   bathroom and whatever, so it tended to be a
      13   Medical Liaison -- you know, that she's given vitamins, the
      14   proper nutrition and that type of thing; therefore, it was
      15   sort of on that the Medical Liaison people were used.
      16         Q.   Have you discussed your testimony here today with
      17   anyone other than Mr. Polli?
      18         A.   No, I have not.
      19         Q.   Have you discussed the McPherson case with anyone
      20   from Los Angeles?
      21         A.   No.
      22         Q.   Have you discussed the files --
      23         A.   Well, I've talked -- I have talked to Ben Shaw.
      24    mean, I say no because he's actually here, but he was
      25    originally from Los Angeles.


      1          Q.   Have you discussed the moving of files with
      2    anybody from Los Angeles?
      3          A.   No, I haven't.
      4          Q.   Who did you -- you said you assigned someone to
      5    disinfect this room of Lisa's. Who was in charge of that?
      6          A.   I didn't personally assign it, but I did hear -- I
      7    did hear of the instructions being issued to -- to get the
      8    room disinfected. And the people were, as I understand,
      9    to -- oh, yeah, the maid who cleans up that area.
      10         Q.   What was her name, do you know?
      11         A.   Wow. It's on the tip of my tongue.
      12                    (Pause.)
      13         Q.   Does her daughter also work at the organization in
      14   the cafeteria? I think I know the name.
      15              She would have been the maid at that --
      16         A.   Yeah.
      17         Q.   -- Cabana during this stay of Lisa's?
      18         A.   or like a chief maid or something. You know, she
      19   was like a -- one of the --
      20         Q.   Is she still there today?
      21         A.   Yes.
      22         Q.   And you can't remember her name?
      23         A.   No, but I could get it.
      24         Q.   Why don't you give -- would you get it and give it
      25   to  Mr. Polli?


      l          A.   Sure. Definitely.
      2          Q.   Did you see these reports prior to their being
      3    shipped to Los Angeles? I think they were in Annie Mora's
      4    office.
      5          A.   I saw the PC folder before, I don't --
      6          Q.   What about the whole package that she shipped out
      7    to Los Angeles?
      8          A.   No.
      9          Q.   You didn't see that --
      10         A.   No.
      11         Q.   -- on her office floor before it left?
      12         A.   (Witness shakes head negatively.)
      13         Q.   No.
      14              Have you discussed this at all with Janice Johnson
      15   since it happened, anything at all?
      16         A.   The only thing I discussed with Janice was
      17   concerns about meningitis, why did she feel that it was
      18   meningitis, did she go over that with Dr. Minkoff. That was
      19   all late that night.
      20         Q.   Did you have -- you haven't discussed it since
      21   then?
      22         A.   No.
      23         Q.   How about with Dr. Minkoff?
      24         A.   No, I never spoke to Mr. Minkoff about it.
      25         Q.   You've never spoken to him about it?


      1          A.   No. Brian was already talking to Dr. Minkoff, so
      2    he became sort of the -- so we didn't have 20 people calling
      3    him, Brian became the, you know, terminal, the person to
      4    talk to him.
      5               SPECIAL AGENT STROPE: I don't have anything
      6    else.
      7               MR. McGARRY: All right.
      9    CONCLUDED AT 11:45 A.M.)


      1                        CERTIFICATE OF OATH
      3    STATE OF FLORIDA   )
      5            I, the undersigned authority, certify that the
      af   oresaid deponent personally appeared before me and was
      6    duly sworn.
      7            WITNESS my hand and official seal this __2nd__ day
      of   ___September_______, 1997.
      10                        RUTH M. MARTIN, R.M.R.
                 Notary Public- State of Florida
      11                        Commission No. CC 643284
                 Commission Expires: 4/29/2001
      ST   ATE OF FLORIDA   )
           I, RUTH M. MARTIN, Registered Merit Reporter,
      16   certify that I was authorized to and did stenographically
      re   port the sworn statement of the aforenamed deponent and
      17   that the transcript is a true and complete record of my
      st   enographic notes.
      18               I further certify that I am not a relative,
      em   ployee, attorney, or counsel of any of the parties, nor am
      19   I a relative or employee of any of the parties' attorney or
      co   unsel connected with the action, nor am I financially
      20   interested in the action.
      DA   TED this __2nd__ day of ___September___, 1997.
                RUTH M. MARTIN, RMR
       K   ANABAY COURT REPORTERS - (813) 821-3320