IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, STATE OF FLORIDA
GENERAL CIVIL DIVISIONESTATE OF LISA McPHERSON, by and through the Personal Representative, DELL LIEBRECH,
PlaintiffVS.
CHURCH OF SCIENTOLOGY FLAG SERVICE ORGANIZATION, INC.; DAVID MISCAVIGE, JANIS JOHNSON; ALAIN KARTUZINSKI; and DAVID HOUGHTON,
Defendants.CONFIDENTIAL
FILED UNDER SEALCase No. 97-01235
Section “H”AFFIDAVIT OF JESSE PRINCE
ON THE 1995 PC FOLDERS OF LISA McPHERSONIN SUPPORT OF PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT ON THE ISSUE OF CONSENT
AND
IN OPPOSING DEFENDANTS’ MOTIONS FOR SUMMARY JUDGMENT ON THE ISSUE OF CONSENT 1
STATE OF FLORIDA
COUNTY OF HILLSBOROUGHBEFORE ME, personally appeared JESSE PRINCE who, after being duly sworn, deposes and says:
1. I am over 18 years of age and currently reside in the state of Florida, Pinellas County. This declaration is of my own personal knowledge and if called upon to testify to the facts herein I could and would be competently able to testify thereto.
2. I file this affidavit in response to the Motions for Summary Judgment filed by the Defendants in this matter concerning the consent of Lisa McPherson.
3. It is important for the Court to know that I was handpicked by Scientology Founder L. Ron Hubbard as a technical expert in Scientology. I had many thousands of hours of experience reviewing pre-clear files, ethics files, and personnel files during my sixteen years as a technical expert in Scientology.
4. The following is a report and summary of Lisa McPherson’s “auditing files” (consultation records) for Lisa McPherson for the year 1995. As part of the administration of “auditing” as defined in Scientology, exact records are kept of each “auditing” (consultation) session.
5. Auditing records represent a written account of what the “preclear” (person being audited) says and how they respond during the auditing sessions. According to the written instructions of L. Ron Hubbard (Case Supervisor series 97) to persons engaged in auditing, “Probably the most covert and vicious crime in auditing is falsifying an auditing report’.
6. This same written instruction carried a heavy penalty of cancellation of all certificates and awards as well as expulsion should an auditor alter or falsify auditing records. For these reasons auditors are trained to report exactly what happens in the sessions.
7. For the whole year of 1995, Lisa was not satisfied with her auditing in Scientology and tried to leave. Each time Lisa complained of her auditing and asserted that she did not want any more, she was coerced to get more “handlings”. Telling your auditor you don’t want auditing or that it is not working for you, is a crime in Scientology. Based on my experience in Scientology, once the preclear makes these type of disparaging remarks concerning auditing, the Director of Processing retrieves the preclear and places the preclear in an auditing repair program. This program is designed to repair past auditing mistakes. Lisa McPherson had several of these programs, yet they did not work. Therefore, the continuing of auditing can only be accomplished by exerting more and more coercive pressure on the preclear. Lisa McPherson is a prime example of this tactic based upon my review of her 1995 PC folders. By my reading of Lisa McPherson’s comments in her auditing sessions, Lisa became increasingly desperate and distressed mentally. Below are quotes of Lisa taken from Lisa McPherson’s 1995 auditing files and my interpretation of terminology only Scientologists understand. Other statements are my summations of what she said during her 1995 auditing sessions.
Date: 22/2/95
Bates Stamp: LMPC-015716
Lisa tells her auditor she didn’t think she needed any more auditing.Date: 2/3/95
Bates Stamp: LMPC-015435
Again, Lisa says “I never really ran an engram and Dianetics was anti climatic for me.”
[Translated, Lisa is telling her auditor that Dianetics has never worked for her and she got nothing from it]Date: No date
Bates Stamp: LMPC-016661
In a D of P interview, Lisa says, “I have not been stable for weeks” and is crying about it. “… can’t seem to find myself.”Date:
Bates Stamp: LMPC-017222
Lisa is crying and states, “Three months ago I was alive. [I] had people who meant something to me. I had work. I was strong. I was operating off postulates. I was so alive… I realized… my life’s been over for three months. [I] want it to stop. I can’t do this anymore. [I] don’t want to wake up another morning and have to go through this.”
[Lisa said these words in response to being told she needed to get more auditing to ‘handle” her. Lisa is talking to a Director of Processing. In Scientology this is the person who schedules auditing for paying clients.]Date:
Bates Stamp: LMPC-017224
“God damn it I feel so desperate… [I] don’t want to do this anymore.”
[Again, Lisa is referring to the auditing she is being told she needs to “get handled”.]Date: 12/3/95
Bates Stamp: LMPC-016720
Lisa tells her auditor she wants to be back out in life.Date: 6/4/95
Bates Stamp: LMPC-016514
Lisa’s auditor notes in her report that Lisa wants to blow (leave) and has lots of problems at work.
[In Scientology terms, “blow” is defined as an unexpected departure. In Scientology as written in its policy, it is a crime to “blow” (leave) Scientology and every effort is made to prevent a “blow” from occurring.]Date: 20/4/95
Bates Stamp: LMPC-016241
Lisa says she got nothing out of her Power auditing.
[Lisa is referring to a different auditing program she was put on to get “handled”.]Date: 1/5/95
Bates Stamp: LMPC-016082
Lisa says she wants to blow (leave) so bad. She goes on to say she wants to kill herself.Date: 3/5/95
Bates Stamp: LMPC-016018
Complains of not being herself, feels she has lost herself.Date: 13/5/95
Bates Stamp: LMPC-017149
Lisa states that she and Bennetta have reviewed her condition and determined that Lisa is in “Power.”Date:
Bates Stamp: LMPC-017150
Lisa is crying. On the next page Lisa states, “I feel like my life is over. If I go in session I don’t think it’s the best thing for me. I am confused.”
[The words “session” and “auditing” are the same in Scientology]Date:
Bates Stamp: LMPC-017152
Lisa states, “I want to die.”Date: 17/5/95
Bates Stamp: LMPC-017027
Lisa states, “…recently I want to kill myself…” ” I have these thoughts about wanting to die. That’s the only solution.”Date:
Bates Stamp: LMPC-017031
Lisa is crying and states, “I feel like I am going into this black hole, like I am already dead.”Date: 18/5/95
Bates Stamp: LMPC-016967
Lisa states, “I feel like I am going more and more the effect.”Date: 22/5/95
Bates Stamp: LMPC-016845
Lisa states, “I get this feeling I am afraid.”Date:
Bates Stamp: LMPC-016846
Lisa states, “… I feel I want to leave.” ” I really feel like I want to leave.”Date:
Bates Stamp: LMPC-016847
Lisa states, “These questions on Power, I found them stupid.”Date: 26/5/95
Bates Stamp: LMPC-016742
Auditor states that Lisa’s attention is, “fixated on killing herself as solution to this unknown problem.”Date:
Bates Stamp: LMPC-016747
Lisa states to her auditor, “I feel disconnected.” She is crying. She states, “I don’t want to go on living this way.” She is crying throughout the entire session.Date:
Bates Stamp: LMPC-016752
Lisa states, “…there is some command saying I must kill myself.”Date:
Bates Stamp: LMPC-016755
In response to a question from her auditor, Lisa states, “Nothing is coming to mind except that I want to kill myself.”Date:
Bates Stamp: LMPC-016756
Lisa states, “I feel like I got to get out.”Date:
Bates Stamp: LMPC-017568
Lisa states, “It feels like the only thing is to kill myself. My life is over. My life is stopped.”Date: 28/5/95
Bates Stamp: LMPC-017637
Lisa states, “Yesterday I got very concerned because I felt I want to kill myself.”Date: 29/5/95
Bates Stamp: LMPC-017557
Lisa is crying and states, “I don’t belong anywhere… my life is over.”Date: 30/5/95
Bates Stamp: LMPC-017528
Lisa states, “I just want to handle my feelings of suicide.”Date: 7/6/95
Bates Stamp: LMPC-017220
Lisa states, “[I] don’t want anyone to know—[I was] afraid to tell [my] auditor [that] my brother and father committed suicide.” “… gotta handle whatever this is—I feel dead.”Date: 9/8/95
Bates Stamp: LMPC-19563
[Note: The following entry is a transcript of a handwritten note sent by Lisa to the C/S.]Hi! Okay—so one thing I’ve learned is no matter what—communicate! Whether or not I feel it is significant or not I’m just going to keep in comm.
Something I’ve noted—and this has been going on since ‘whatever is going on’ began it seems, is that I’m tired but have a very rough time sleeping (as you well know). My body gets hungry but I want nothing to eat. I sit and want to stand. I stand and want to sit. I lay down and want to get up. I want to rest and the body feels very tired but I can’t make it sleep. I am in a rush all the time but I have nowhere to be especially and nothing demanding that I be in such a rush. Anything I seem to be the least bit interested in as soon as I approach it is now something to be rejected. I think of music I’d like to hear (some of my favorites) but as soon as it begins I want to turn it off. I see a film and think it will be good and then I don’t want to watch it. I think of food that would taste good then get close to it and change my mind. I am in an almost constant state of ‘maybe’ or ‘I don’t know.’ I cannot seem to go very far mentally on any subject or thought. I cannot seem to get comfortable mentally or physically. “I want to go and I want to stay and I don’t want either. It is quite insane. I have no tolerance and everything annoys me. So that’s about all I have to report on that. “Love, Lisa”Date: 9/8/95
Bates Stamp: LMPC-19571
Kartuzinski is the auditor. Lisa is still experiencing grief and frustration at not being able to answer the questions that the auditor is asking her. The auditor is attempting to “rehab” a point in the past when Lisa was feeling good about herself and her auditing.Date:
Bates Stamp: LMPC-19576
Lisa states, “I hate this because I hate losses trying to rehab this.”Date: 16/8/95
Bates Stamp: LMPC-21293
Folder # 33Date: 16/8/95
Bates Stamp: LMPC-21761
According to Kartuzinski, Lisa is “Doing fine now.”Date: 21/8/95
Bates Stamp: LMPC-21624
Kartuzinski feels that Lisa is still making progress.Date: 26/8/95
Bates Stamp: LMPC-21573
Lisa again feels as if she is “exterior.”Date: 8/9/95
Bates Stamp: LMPC-20670
(This is the last auditing date provided by FLAG) Kartuzinski has been assigned as Lisa’s auditor again. His note to the C/S states, 1 don’t want to do anything on this pc… (she’s exterior)…” He recommends that Lisa be allowed to attest to the state of Clear.
[Note: The term “exterior’ is used here to indicate that Lisa has attained a spiritual state where she is exterior to her physical body.]8. From as early as March of 1995, Lisa complained about her Scientology auditing. She also stated that she wanted to leave as stated in her own words but each time she was not able to find the back door. She was put on an ethics program at her job at AMC, which was very stressful for her. The recent testimony of Bennetta Slaughter and Brenda Spencer concerning the ethics program Lisa was doing is so opposite to what Lisa was saying that one could suppose Bennetta and Brenda were talking about someone other than Lisa McPherson. Lisa was continually made to do ethics because she was no longer in agreement with her job and her auditing. Below are my summaries of Lisa McPherson’s comments concerning her Ethics program at AMC and FLAG in 1995.
Folder #24
Date: 14/2/95
Bates Stamp: LMPC-015890
Lisa says she is in trouble because her stats were crashed. She is doing ethics conditions and o/w write-ups.Date:
Bates Stamp: LMPC-015892
Lisa mentions getting into a fight with Bennetta. She says she and Bennetta are friends but something comes between them.Date: 20/2/95
Bates Stamp: LMPC-015745
Per a note from Lisa’s auditor, Lisa is PTS to Bennetta.
[Translated, Lisa is saying she feels oppressed by Bennetta.]Date: 28/2/95
Bates Stamp: 015511-12
Lisa says she has to pretend to do ethics conditions, she says its just bullshit and she has no interest in conditions.Date: 4/3/95
Bates Stamp: LMPC-015333
Lisa says she is in fear of Bennetta. She says she has been assigned extra work to do by the OT Committee.Date: 7/3/95
Bates Stamp: LMPC-015187
Per Lisa, Brenda ordered Lisa to go to a “Woman’s Association.Date: 8/3/95
Bates Stamp: LMPC-015121
Note from Lisa’s auditor that Lisa is fixated on Bennetta.Date: 12/3/95
Bates Stamp: LMPC-015066
Interview, Lisa is sent to attest to “Power” but says she is she is having trouble doing what she is doing. Says she finds herself talking to herself and it drives her crazy.Date: 2/4/95
Bates Stamp: LMPC-016673
Lisa is in ethics again for poor performance on her job and appears to be on an ethics program. Lisa says the ethics is not working and she feels like she should be left alone. She says she does not believe in the product she is being asked to sell and is faking it at work.Date: 5/4/95
Bates Stamp: LMPC-016588
In tears again in auditing. She says she feels like she has to trick her clients to making a sale and she is not honest.Date: 6/4/95
Bates Stamp: LMPC-016514
Lisa’s auditor notes in her report that Lisa wants to blow (leave) and has lots of problems at work.Date: 8/4/95
Bates Stamp: LMPC-016472
Complains of doing ethics with DeDee Cage.Date: 9/4/95
Bates Stamp: LMPC-016355
Says she is PTS to Kurt and her job.Date: 18/4/95
Bates Stamp: LMPC-015263
Auditor notes Lisa is PTS to Bennetta, C/S says no.Date: 26/4/95
Bates Stamp: LMPC-016221
More ethics handling by DeDee. Lisa says something in her snapped and she was not the same.Date: 1/5/95
Bates Stamp: LMPC-016082
Lisa says she wants to blow (leave) so bad. She goes on to say she wants to kill herself.Date: 10/5/95
Bates Stamp: LMPC-017188
Lisa states, “There is a missed withhold somewhere. It has something to do with Bennetta.” Lisa is doing “conditions” at work under the direction of Dedee Cage.Date: 13/5/95
Bates Stamp: LMPC-017046
Lisa states, regarding Dedee Cage, “I am thinking she is trying to drive me crazy.”Date:
Bates Stamp: LMPC-016971
Lisa is crying about a conversation that she had with Bennetta. Lisa feels invalidated by Dedee Cage.Date:
Bates Stamp: LMPC-016986
Regarding Dedee Cage, Lisa states, “There was something in her manner that broke me. I just went into apathy.”Date:
Bates Stamp: LMPC-016994
Regarding Dedee Cage, Lisa states, “I am thinking I am going to kill her, get rid of her.” “I have to get rid of her.”Date:
Bates Stamp: LMPC-017002
Regarding Dedee Cage, Lisa states, “I was thinking of how ineffective she is, ‘You are so robotic, so ineffective.'”Date: 20/5/95
Bates Stamp: LMPC-016922
Lisa tells the D of P that she feels that she is still struggling and that she is having trouble sleeping and that she has no appetite. Lisa states that she is unhappy at her job and feels that she should leave AMC. Lisa is still upset with Dedee Cage and another woman named Katie.Date: 21/5/95
Bates Stamp: LMPC-016908
This session concentrates on Lisa’s belief that Bennetta is ordering her to do actions that are not correct or helpful. Bennetta had ordered Lisa to report her action and her ethics condition twice daily—apparently to Dede whom she does not like. Lisa states that she cannot stand up to Bennetta.Date: 22/5/95
Bates Stamp: LMPC-016806
Lisa’s auditor writes to the C/S that Lisa is in lowered conditions at work and that she should see the MAA to get the matter handled. The C/S agrees.
[Translated, this means the ethics program that Lisa was doing at AMC Publishing is now transferred to the Flag Service Organization.]Date: 3/6/95
Bates Stamp: LMPC-017421
I just don’t feel like doing anything… I do feel shut off from my life. I’m not interested in creating the 2nd Dynamic…”
[Note: Lisa is probably referring to her love life above since she had recently ended her relationship with Kurt.]… or in creating which is the 2nd Dynamic. At work I am not in comm[unication] with people or my clients. [I] don’t want to be with anyone. No interest in the OT Committee which I loved to death. I don’t want to go to the movies or the grocery store. I used to love that. I am interested in nothing. I live in a shell—don’t want to talk to anyone—want no one to talk to me. I cringe at the idea of having to talk to someone. I just want to be left alone. I am thinking of everything I can tell you about it—it’s the most awful feeling in the world. Nothing matters anymore—how I look, what I do. I don’t really consider I can have any effect on anyone’s life except to mess it up. It’s like I want to hide. It’s real yucky and I hate it. I just feel shut off from the world—from life—not able to participate. I have no reach, no desire to reach. [I] have to force myself to do everything—brush my teeth and wash my face—it’s the worst predicament I’ve been in all my life, this lifetime. I go around in circles—start things, try to get interested when I am not and I feel small.
Date: 5/8/95
Bates Stamp: LMPC-19842
Alain Kartuzinski is Lisa’s auditor. Lisa is still upset about Dedee Cage asking Lisa what condition Lisa is in.
[Note: This session is extremely difficult to read due to the auditor’s bad handwriting. Lisa appears to be discussing her ongoing problems at work and the fact that she feels that she has not been “herself’ for many months.]9. There is vital information missing from Lisa’s pre-clear files. The last three days of her isolation in December 1995 are missing. There is no valid reason for any items to be missing or “lost” from her auditing files. For example, upon attesting to Clear and after the graduation of September 15, 1995, a Sec Check should have been done and placed in her PC folder. If the Sec Check was done, there is no explanation for it not to be in her PC folders. The examination and attestation to the State of Clear is missing. All of the sessions reports for the Sunshine Rundown, which is down immediately following the Clear attest is missing. Below is a list of other items missing from the files:
MISSING FOLDER ITEMS
Missing Items: Folder 21
Date:
Notes: Pg 38 of folder summary states that ‘folder 21 contains various admin”Missing Items: OCA graphs
Date: 82-95
Notes: Only one OCA dated September 10, 1995, is in the admin folder. Per auditor and C/S statements there were others done during 1995.Missing Items: IQ tests
Date: 82-95
Notes: None appear.Missing Items: Grade I-IV process sheets (BTB 15 Nov. 1976.)
Date: 6/86- 5/87
Notes: Only ARC S/W and a portion of Grade 0 appear in the admin folder.Missing Items: Sec checks
Date: 10/88, 3/91, ?/95
Notes: The folder summary indicates that a leaving staff sec check done in March ’91 and a tailor-made was done in ’88 for drug historyMissing Items: O/W write ups
Date: 87,88, 90, 94, 95
Notes: Folder summary shows write ups were done. None appear in the folder.Missing Items: 3 May PL
Date: 5/95
Notes: Lisa states that she received a 3 May handling at AMCMissing Items: Repair Program for Introspection RD
Date:6/95
Notes: Per the folder summary, Lisa was started on the RD on June 19. No program appears in the folder.Missing Items: Knowledge Reports
Date: 1995
Notes: It seems likely that Krs were being written by AMC staff. None appear in the folderMissing Items: PC folders
Date: 9/95-12/95
Notes: Folder 33 is the latest folder Plaintiff has in its possession – folders stop at Sept. 7, 1995.Missing Items: Kartuzinski Reports
Date: 9/95-12/95
Notes:Kartuzinski states that he wrote a number of reports during Lisa’s psychosis. None appear in folders.Missing Items: Folder summaries
Date: 9/95-12/5
Notes: The folder summaries stop on Sept. 7, 1995.10. The words of Lisa McPherson speak for themselves. She wanted to leave Scientology, as it was not working for her yet she was not allowed to, as that would have been a “Crime”. For months, day after day Lisa made known her innermost feelings and the auditing files reflect exactly how Lisa felt about what was happening to her. Nothing written by myself or anyone else could be more accurate than Lisa McPherson’s own words.
11. There is no legitimate reason why the records outlined in Paragraph 9 are missing from the PC folders.
FURTHER AFFIANT SAITH NOT.
[Signed:] Jesse Prince
JESSE PRINCESworn to and subscribed before me this 4th day of April, 2000.
[Signed:] Donna M. West
NOTARY PUBLIC
My commission expires:Personally Known [checked]
Produced ID___
Type of ID Produced____[Stamp:]
Donna M. West
MY COMMISSION EXPIRES
October 31, 2003
BONDED THRU TROY FAIN INSURANCE, INC.
Notes
- PDF Format: Affidavit of Jesse Prince (2000-04-04). ↩