Part 1 HERE
Part 2 HERE
have it on some sort of a tripod?
A. Yeah, yeah.
Q. And it was pointing towards what area?
A. The intersection of Cleveland and Fort Harrison.
Q. All right. At some point did you see Mr. Fitzgerald approaching you?
A: Well, first I saw Mr. Mansell who is sitting at the table here. He was across the street.
Q. What was Mr. Mansell doing across the street?
A. I don't know. He seemed pretty intent on what I was doing.
Q. Was he watching you?
A. Yeah. He was hanging out in front of Starbucks on the sidewalk. And of course, you know, I noticed his face because he was -- seemed to be around a lot when either security or people like that would come out. Seems to be in some sort of -- serve in some sort of security capacity as a supervisor or something,
Q. What was he doing in front of Starbucks?
A. I don't know. He's actually -- he's at the table. You might want to ask him.
Q. What did you observe him doing at Starbucks?
A. Discussing something with somebody on the cell phone.
Q. He was talking on his cell phone?
A. Uh-huh (nods affirmatively).
Q. And what was it that caused you to notice him? What caused -- what attracted your attention to him?
A. I noticed who -- of course, I recognized his face, that he was in some sort of security capacity. He usually just goes from what I was able to notice either back and forth or hangs out around the corners with security. He doesn't really stand too long in a broad open public area like that, especially' whenever I'm around. He just sort of does a lot of peeking around corners and stuff like that with the security details. This time he seemed to be intent on me and standing out in the open and focused on me while he was talking on his cell phone.
Q. If he's talking on his cell phone, why do you feel he's focused on you?
A. Well, I guess when somebody stares at you for more than a minute long, I guess you would think somebody to be focused on you.
Q. So he was staring at you?
A. Yeah.
Q. You were across the street or the same side of the street?
A. No, I was across the street, yes.
Q. He was in front of Starbucks?
A. Uh-huh.
Q. And you were where?
A. Across the street on the opposite corner. North corner. He was on the southwest. I was on the northwest.
Q. Your camera is set up and it's pointing into the intersection or -
A. Yeah, cross corner to -- here's the camera, cross corner. Here's Mr. Mansell, here's me or the same actual side of the street sort of. West side I guess you could say.
Q. He's on the southwest corner, you're on the northwest corner?
A. Northwest corner.
Q. Your camera is on the northwest corner?
A. Uh-huh.
Q. And your camera is pointing towards what?
A. Southeast.
Q. Southeast corner?
A. Yeah.
Q. Okay. So what happens next after you notice Mr. Mansell speaking on his cell phone looking at you?
A. He briefly hung up. Of course I'm, you know, trying to be as well aware of my surroundings as I can be. Seeing as he knows -- evidently I'm the focus of attention by a lot of current high-level members that seem to be curious on a daily basis for hours on end and try to get in discussions with me about what I'm doing over and over. So of course I'm trying to, you know, keep aware of my facilities.
This gentleman comes -- he had a cup of coffee in his hand, but I didn't see him go into Starbucks first, Michael Fitzgerald. I saw him briefly pass Mr. Mansell and walk across the street in a heated -- well, he walked across the street in a fast way. He was double stepping I should say. And when he was like halfway across the street, he started -- he started yelling something like I was a religious bigot. Something to the effect of -- I don't like to use the word, but, Why aren't you at the Baptist Church calling all the blacks niggers, and why aren't you at the -what do they call the church for the Jewish people, Taber -- why aren't you at a Tabernacle calling Jews kikes and stuff. And I knew this was a problematic individual.
So I had a hand cam, the one that actually is filming us now. And I raised it and the gentleman appeared to be very agitated by that and came right at me and tried to block me filming him or something so.
Q. Did you have your sign with you?
A. Yeah, actually my sign was prominently displayed.
Q. And that's the sign that says "Cult Watch"?
A. Uh-huh.
Q. Why -- why -- why do you display that sign -
A. So people know exactly what's going on. Otherwise, you know, if you're out there with a camera it might -- people might tend to ask you too many time: what's going on, you know. It's problematic trying to tell people what's going on over and over and over and over and over and over again. So I figured, you know, the best way to cut through all the crap is just go ahead and try to tell everybody on the poster board, you know, what the name of the show is, where it's going to air, where you can find some information about it and that I'm filming.
Q. Do you -- do you think that the words "Cult Watch" might be offensive to Scientologists? A. It's funny, it's funny you said that. Because, geez, if I was a Scientologist and considered myself to be part of a religion that was not a cult, I wouldn't find it offensive.
Q. Do you think it's similar to calling a Jewish person a kike?
A. Actually, no. But, you know, more revealing, what would be your opinion on that.
Q. Well, Mr. Fitzgerald apparently thought it might be somewhat similar to calling a black person a nigger. Isn't that kind of what he conveyed to you?
A. Well, what's your take on it? That's why -- actually that's why I brought it in as an exhibit to ask, you know, what would be any normal-headed person': particular take on that sign.
Q. I would think that a Scientologist would see that as being offensive?
A. Oh, really?
Q. Yeah.
A. Wow.
Q. You don't think so?
A. No.
Q. Do you think that Mr. Fitzgerald found it offensive?
A. Obviously.
Q. In fact, he compared it to calling a black person a nigger, didn't he?
A. Yeah. That's awful telling, don't you think?
Q. I would think so. Have you displayed this sign across from the Scientology building since the assault with Mr. Fitzgerald?
A. Yeah. Two days afterwards, yeah.
Q. Did you think that Mr. Fitzgerald might still find it to be offensive two days later?
A. Sure. If he did the first time, you know, hey.
Q. And was that -- was that part of your purpose was to cause offense to the people down there?
A. Of course not. Do you think I'd -- I was assaulted by the gentleman.
Q. So why did you go back two days later with the same sign?
A. Because I wasn't done filming.
Q. Did you have to have the sign in order to film?
A. I don't see why not.
Q. Did you have to have the film -- the sign in order to film?
A. Basically, what do you mean like by law or -
Q. No. To make your camera work, do you have to have that sign?
A. Oh, to make my camera work, do I have to have the sign there? No.
Q. All right. So Mr. Fitzgerald apparently communicates that he finds something offensive about the situation?
A. Uh-huh (nods affirmatively).
Q. What, if anything, do you do?
A. I raised my camera.
Q. And do what?
A. Film him.
Q. Film him?
A. Yeah.
Q. Okay. And what was his reaction to that?
A. He immediately got in my face over it.
Q. What do you mean by got in my face?
A. Charged me. Put his hand up and grabbed my camera.
Q. And what did you do?
A. I tried to get him not -- well, we both had ahold of the camera. He had -- I don't know if you can view the camera there. It has a flip-out screen on it. He immediately grabbed the screen as I held it to my face. I was in like this type of a manner and this being the screen, this being the camera. He immediately grabbed, you know, ahold of the camera and leave. He tried to pull it away and push it down to the ground, and if I remember correctly, I tried to release grip of it, but I was caught in the -- there's a hand strap on it.
And rather than have -- because that little screen is very, very sensitive, you know. If you twist it, it breaks very easy. It's only plastic. So I tried to give him as much leeway with the camera since my hand was attached to it so it wouldn't break. We went to the ground with it, and he was, you know, adamant on holding onto it, and I tried to get him not to by not giving him as much of a resistance as I could so he would sort of release his grip. We went to the ground on it and sort of separated after that. Because I released my pullback I guess you could say and he let it go. And I was trying to tell him, you know, let go of the camera, let go of the camera.
And afterwards we -- I raised back up, got the camera again, backed up and started filming again because this is, you know -- put it this way. Ii this is on tape, then my butt is covered, you know what I mean. I need to document as much of this that's going on as possible. So I'm not erroneously accused of assaulting this gentleman, which ironically turned out to be the case later on.
Q. You said you got back up and started filming again. Were you filming Mr. Fitzgerald?
A. Uh-huh. I was filming in Mr. Fitzgerald's direction.
Q. What happens then? What happens next?
A. He yelled back and forth at me that I don't want you -- I think something like I don't want you to take my video or my photo or something like
that. I said, you're on a public street, you know, and basically you're attacking or you're -- something to that effect. And he went for the camera again when I raised it and started filming. And this time it was up towards my face. I mean I was up here with it. Seeing as it was up here when he went for it, it was right against my face.
Q. What happened next?
A. He was -- since it was right up against my face, he went with both hands. One hand here and I think he had one hand right here on the side of my face. And I went up with one hand, I think I went down with one hand and tried to drive him backwards. And we ended up going to the ground. I believe I was wrapped up in the strap somehow since it was on my hand and I couldn't get -- get off of the camera and we got back up and we were tied together and we spun around and flung into the front door of the building, whichever is -- whatever it's called. It's vacant now. The old Mooko -
Q. The one on the northwest corner?
A. Yeah. The one on the northwest corner. He slammed into the front door and slid down. I was able to get -- he released something. He must have been tangled up in the strap, too, or something, I don't know. We released at that point, though. Immediately I think it was three Scientologists that were in the area immediately stated that, you know, I had assaulted him. So I mean they came right out and yelled, you know, I can't believe you assaulted him, man. I saw it, You assaulted him, right to me. And it was like, excuse me.
Q. Okay. What happened next?
A. I think we argued for a little bit. Somebody called the police and the police came. I was able to show them the video I had, and they ended up arresting him.
Q. Who called the police? Did you call the police or did someone else?
A. A gentleman that had pulled up on a bicycle with a -- he had a blue flag, blue T-shirt with a flag on it. It said flag, f-l-a-g.
Q. The video that you were shooting, this was a video that you were shooting during this process, right, it wasn't -
A. The video was running, yes.
Q. Well, what happened to that videotape?
A. The police are in custody of it. Actually the funny thing about it I think the Church was able to come up with their own copy and submit it for evidence as well.
Q. Now, what is Mr. Mansell doing during this?
A. He was still across the street feverishly talking on his cell phone. Didn't seem to be like he was too happy with the whole situation the way it turned out evidently.
Q. And what causes you to say he didn't seem to be too happy?
A. His facial expressions and mannerisms led me to believe that he was agitated.
Q. Now, you and he are still on opposite sides of the street, are you not? Pardon me?
A. Yes, sir.
Q. Did you have any discussions with Mr. Mansell?
A. After -- after it was done, I had to go to the police office. My car was parked opposite side of him on the back parking lot. So I had to walk past him to get to my car. And along the way I stopped and I asked him, I said, Did you know that that guy was a Scientologist? He looked at me and he told me to get the fuck out of there, you asshole, and then to get the fuck out of there again. He said it twice. The first time was get the fuck out of there -- get the fuck out of here, you asshole. And the second time was, get the fuck out of here, you son of a bitch I think, or something to that effect.
Q. Did you leave?
A. I was on my way to leaving anyways so I just continued to proceed to my car.
Q. Then you went to the police station, is that what you did?
A. Yes.
Q. The -- the videotape that you said the police have, is that the original or is that a copy? A. Oh, the original.
Q. I take it you have not made a copy?
A. No.
Q. Have they given you a copy?
A. They cannot give me a copy because it was sealed in an evidence bag evidently. They supposedly were to give me a copy, but they didn't have the technical ability at the police office to copy a DV tape evidently. So they sealed it in an evidence bag to take it to another station to make the copy, and in doing that they sealed it in an evidence bag, you know. So much for the explanation that they were going to get me a copy.
Q. So this is a DVD as opposed to a -
A. No. A DV tape.
Q. A DV tape?
A. Yeah. Digital videotape, mini DVD tape.
Q. So it's actually on tape, it's not on a disk?
A. Yeah, yeah.
Q. Mr. Lonsdale, you mentioned that prior to the assault Mr. Mansell did not look happy or seemed agitated. Did you videotape Mr. -
A. That was after the assault. Prior to the assault he was just talking on his cell phone.
Q. Well, I -- you're right. Prior to the assault you said that he seemed to be focused on you?
A. Uh-huh.
Q. He was watching you intently. Did you get any videotape of Mr. Mansell watching you intently:
A. Yes.
Q. And would that be on the same DV tape that the police now have?
A. Yes.
Q. And I take it the communication between you and Mr. Mansell after the assault is not on the tape, is that correct?
A. Correct.
Q. The camera was not running -
A. No, it was not running.
Q. Now, are you familiar with some sort of an Internet posting site called Operation Clambake?
A. Xenu.net. That's on my sign.
Q. And do you make postings on that website under the name of Proflex?
A. Yes, I do.
Q. What does the name Proflex mean?
A. It's a screen name.
Q. How did you come up with it? I mean, was it -
A. Actually it's the type of bike I have.
Q. Okay. Are you -- are you a biker?
A. Was.
(At this time Plaintiff's Exhibit No. 20 was marked for identification.)
BY MR. POTTER:
Q. Was. Let me hand you what I'm going to mark as Exhibit 20. I believe that's a print off of the Clambake website. Do you recognize that as some of the postings that you made under the name of Proflex?
A. It appears to be so.
Q. And the one that I've handed you, is that the posting that you made I guess shortly after the physical altercation with Mr. Fitzgerald?
A. Yes.
Q. Now, I want to direct your attention to the second page. It's about three-quarters of the way down approximately where my thumb is. And I think
you're talking about the conversation with Mr. Mansell. You say, I saw the -- I saw the whole wildest OSA suit across the street frantically on his cell. Is the reference to OSA suit, is that Mr. Mansell? Is that a yes?
A. Yes.
Q. You go on to say, "As I left to go to the police station, I passed him and asked him if he knew that guy was a Scientologist just to get his goat."
Why were you trying to get Mr. Mansell's goat?
A. Well, it appeared to me that he was there for a specific reason, and that reason was what I assumed to be the whole incidence of being assaulted.
Q. You assumed that Mr. Mansell was there to assault you?
A. No. I assumed Mr. Mansell was there to oversee the operation of assaulting me.
Q. And so -- then why did you feel that it was necessary to get his goat after the assault was over?
A. Well, because it didn't happen the way it was supposedly, according to my own belief, orchestrated to happen.
Q. How do you think it was orchestrated to happen?
A. I'll put it this way. I had been out there for I think this was day, what, 14, day 13, 13 days with no incident. Then all of a sudden this particular day I go out there, and there's no handlers Every day I have four or five high-level Scientologists, public members out there. Sometimes three, sometimes two. They take shifts trying to hit me from different angles with, you know, I'm curious why would you do this. Why would you do that. What are you trying to gain from all this. Where are you getting your money from.
All sorts of different weird and bizarre angles to try to get me to engage in a conversation of a demeaning nature usually and to get wrapped up in these conversations. It's a handling attempt they call it. One usually stands in front of the sign. It's usually around the times where the Scientologists publicly are going back and forth from the dining hall and are exposed to my Cult Watch sign which is supposedly some kind of bad thing. Excuse me. And in doing that this day, though, there was nobody out there. It was just all too perfect.
Q. So, what, if the handlers were there, you think Mr. Fitzgerald would not have been able to assault you, is that what you're suggesting?
A. No. If the handlers were there, I don't believe that I would have noticed anything out of the ordinarily that was going on. Something obviously tipped me to the fact that something was going on.
Q. And because you were tipped, what were you able to do that you would not otherwise have been able to do?
A. Who knows, just be aware of whatever, just be in an aware state. Even more so than I, you know, normally would have been if I had three conversations ongoing at the same time, you know. All around me. See when I'm out there, the handling process consists of one person usually to my right, on( person to my left and one or two people on whatever angle is left to be exposed to, including one person from my side. So, you know, sometimes it varies, two or three people, sometimes it varies to four. Some days one and two come, sometimes they take off, switch, go get a cup of coffee while somebody else handles, you know. Case in point being Drew Sweet.
THE COURT REPORTER: What was his name?
BY MR. POTTER:
A. Drew, D-r-e-w, Sweet, S-w-e-e-t. Which is one of the Church's -- or one of the witnesses that were out there at the time. This gentleman had been on the street with me numerous days prior to that in a handling fashion along with Mr. Savelo, Ron Savelo, including some of our downtown business owners, one being -- he owns the Rabbit Hole there, Ian Shilington Mr. Richard Hearst (phon), and two other individuals. Actually possibly even three other individuals that I haven't been able to get their names yet so.
Q. So these people come out and try to engage you in conversations?
A. Uh-huh.
Q. And you find -- do you find that to be offensive?
A. Sometimes.
Q. Is it insulting because they talk to you in a demeaning tone or because of what they say to you?
A. Both.
Q. What sort of things do they say to you that is demeaning?
A. All sorts of different stuff. From anywhere from what do I know about Scientology to what my project consists of to who I am, where am I from,
what crimes do I have in my background. Have I -- what were some of the other ones. Have I -- some of the weird ones were, have I molested people, what crimes dc I do not know of, you know, or does the public not know of about me, what am I hiding. Where does my family live. Do I have any family. Who my employer is, where am I getting my money to be out there.
Actually, you know what, if you really wanted to know what all these questions and answers consisted of, you can probably refer to their own files because these people aren't out there of their own volition. They -- all this information is rehashed back and I'm sure detailed in some sort of a file somewhere. So I'm sure the Church will be able to more correctly answer some of these questions than I would be, but -- as to what was exactly asked and why.
Q. Well, most of what you just said sounds remarkably similar to the questions that I have asked you here today.
A. Oh. And you asked me how many children I have molested or people I've molested or -- you've asked me where my family came from.
Q. I don't think I asked you those questions.
A. Well, then how come you would state that they are remarkably similar to the questions that you're asking me. Because in no way have you asked me those types of questions.
Q. So it's those particular questions that you find to be demeaning or insulting?
A. Actually I find the person to be asking them. I think that demeans them more than it does me. You know, I have to be comfortable with what people as me in order to stay relatively calm on the street, you know. You can't be the type of person that would want to assault somebody for no apparent reason for the I instance of having a sign or videotaping in public.
Q. Is your sign intended to be a protest of any kind?
A. How do you view it?
Q. My question is how you view it?
A. I put it together to be informative. You take it to be some sort of a protest?
Q. Well, again, the question is not what I think it is. My question is -
A. Well, the question goes to determining what it actually means. I mean and you can come to your own conclusion based on reading it.
Q. I asked you if you thought it was insulting and you said no?
A. Well, I don't think it is. But then again that's my own opinion.
Q. Right. And so I'm asking if you think it's a protest of some sort?
A. I don't.
Q. Apparently no. Would you consider it picketing of any kind?
A. No. Would you?
Q. You consider this to simply be informative of what you're doing on the street corner, is that right?
A. I think it's pretty self-explanatory.
Q. And you don't feel that it would be insulting or offensive to Scientologists, correct?
A. Not unless they were -- in some way thought they were involved with a cult.
Q. So you think that a Scientologist would see that sign and think you're watching something othei than Scientology?
A. Perhaps. Although there's Scieno Times at the bottom. I guess Scieno may have been some reference to science. I don't know how that would relate to -
Q. I guess you could mean that perhaps you're watching the people at Starbucks, that the people that go to Starbucks are somewhat of a cult, correct?
A. Many different cults. Many different groups.
Q. I take it no one from Starbucks has come over and asked you why you're watching them?
A. I'm not watching Starbucks.
Q. Who are you watching?
A. I'm watching the intersection.
Q. Are you watching the Scientologists as they cross through the intersection?
A. Them plus whoever crosses between the intersection that is a newsworthy content. Is that supposed to be closed?
Q. It doesn't necessarily have to be latched. Have you -- have you conducted cult watching: of any other group other than Scientology or possibly the people at Starbucks?
A. No. I'm still new to the game. Plus I don't really live in proximity to a group that could be-
THE COURT REPORTER: You don't really live where?
BY MR. POTTER:
A. Close proximity to a group that could be considered of cult-like fashion.
Q. Other than Scientology you mean?
A. Other than Scientology.
Q. Why do you consider Scientology to be a cult?
A. Basically because of the way their processes are delivered.
Q. What is it about the way their processes are delivered that makes it a cult?
A. Well, if you look at actually the TR routine in particular. If you were to give those to a professional hypnotist, I'm sure he would find a direct correlation between how those are delivered and how to get a person into a hypnotic trance.
Q. How do you know about TR routines?
A. TR routines are -- they're on the net -they're on the Internet in like eight different areas I'm sure. If not more, 30. Listed in their entirety. I believe it's one through twelve.
Q. And have you primarily learned about TR routines and things of that sort by reviewing the postings on Operation Clambake?
A. No. Operation Clambake doesn't have all that stuff. They have references to it and people discuss it and stuff like that, but there's never
really usually any concrete stuff that you find as far as original documentation I don't think. There's a lot of other websites like Scientology Kills is one I believe. I'm not sure if that's up anymore. But that was -- had some pretty telling stuff back in I think a year ago.
Q. It sounds to me like you spend a lot of time reading about Scientology on the Internet, is that true?
A. Yeah.
Q. Approximately how much time do you think you've spent reading about Scientology?
A. I don't know. A lot of time I guess.
Q. When you're not reading about Scientology on the Internet and you're not filming the intersection of Cleveland and Fort Harrison, what do you do with your time?
A. Ride my bike whenever I have it and it's not in the pawn shop. I read other books, watch TV, listen to the radio.
Q. What kind of books do you read? Scientology books?
A. No, philosophy books mostly. Anything that really interests me that I find at either yard sales or in thrift stores.
THE COURT REPORTER: That what, sir? BY MR. POTTER:
A. And either interests me from yard sales or thrift stores.
Q. What's your educational background?
A. High school diploma.
Q. Where?
A. Melbourne, Florida.
Q. Any college?
A. No.
Q. How about jobs, are you looking for jobs?
A. Yes.
Q. What kind of jobs are you looking for?
A. Service oriented or hopefully anything that would hire me for any type of video-related work. Q. What have you done to look for a job?
i i A. Applications mostly. ' I Q. What kind of places? I
A. Lowe's, Home Depot, most of the convenience stores in the area. Online I sent one to II believe it was Channel 8. I think 13 about four month ago was looking for a video editor. Of course I didn'~ i have any experience in the realm, but numerous.
Q. Let's talk about Mr. Lirot some more. He's my favorite topic anyway. How did you -- how did you find his name or his phone number in reference to this case?
A. It was on the Internet.
Q. What kind of search did you run to find Mr. Lirot on the Internet?
A. I didn't run a search particularly for attorneys. I ran a search particularly for Mr. Lirot.
Q. And why did you run a search for Mr.Lirot?
A. Somebody in an e-mail had told me that he was a First Amendment attorney in the area.
Q. Who was it? Who was the e-mail from that suggested Mr. Lirot?
A. I don't know her name. Just a screen name.
Q. Was it Patricia Greenway?
A. No. Well, at least I don't think it was.
Q. Was it Peter Alexander?
A. No.
Q. Was it any of the individuals on the face of the injunction?
A. No. Well, no.
Q. What was the name of the e-mail person?
A. The name of the e-mail person?
Q. Yeah. Screen name or whatever?
A. Magi or Magi, M-a-g-i.
Q. Was it Magi Magoo?
A. Magi Magoo, no. She got the name wrong actually.
Q. Well, Magru?
A. Tori Magoo is supposedly her name.
Q. Tori Magru, was it Tori Magru?
A. No. It wasn't Tori Magru. Magoo, M-a-g-o-o.
Q. It was not Terry Magru, is that correct?
A. No.
Q. It was someone named Magi?
A. Yeah.
Q. The e-mail that came to you suggesting or referring you to Mr. Lirot, was it from a person who was using the screen name Magoo, M-a-g-o-o?
A. No, no, no. Actually, you know what, I think it was -- it wasn't in an e-mail. You can see it. I believe it's on ARS.
Q. What is ARS?
A. Art Religion Scientology.
Q. So you received an e-mail or a posting about something that Mr. Lirot was a First Amendment lawyer, is that correct?
A. Yeah. It's from -- it's from a woman -well, I believe it to be a woman since that's the screen name, Magi. I think it's either M-a-g-i or M-a-g-g-i. It's not Tori Magoo, though.
Q. All right. You say you haven't figured out how you're going to compensate Mr. Lirot at this point. Has anyone else suggested that they would pay Mr. Lirot for his services in representing you? A. No.
Q. Pardon me. Has Mr. Lirot suggested that someone else might cover those services?
A. No.
MR. POTTER: Let's take a quick break. :
think we're done, but let's take a quick break so we can make sure.
(At this time a brief recess was taken.)
BY MR. POTTER:
Q. Mr. Lonsdale, we've talked about your four or five telephone communications with Patricia Greenway. Have you had any communications with either Patricia Greenway or Peter Alexander other than what we have talked about today?
A. No.
Q. Mr. Lonsdale, in one of your Clambake postings you make reference to I think something callec an IAS T-shirt?
A. Yeah, yeah, yeah.
Q. What is that?
A. International Association of Scientologists.
Q. And apparently you were wearing that T-shirt at some point while you were filming downtown, is that correct?
A. Uh-huh. Actually I don't think I was -yeah, maybe I was filming that day, although it wasn't a corner film. Actually the second time it was a
corner film. The response was from the corner film. The original -- the situation posted was one in which an individual came up to me on the street. I did have my camera, and I was inquiring as to -- a couple of individuals were dressed in dirty jeans garb. They were young kids. They were at the stop light crossing from the east-north to east-south side of Fort Harrison and Cleveland.
I was inquiring to one of these people that are there in the RPF. There was a gentleman standing next to them who was a -- linen shirt, no tie, slacks, well dressed, preferably well dressed as opposed to those two. And he -- of course the two that I was asking the question of were ignoring me. So I turned and he said, no, those guys aren't in the RPF. They're in the EPF, which is -- refers I believe to estate project forest, which is I believe a group that does work on properties, I believe.
And these -- this gentleman went on to say oh, hey, you know, we're having a big wing-ding down at the Fort Harrison -- I forget what he called it. But he asked if I had been invited or not. And he assumed that I was from out of town. And I was like, no. I said would you like to invite me because he had a pad of paper I believe in his clipboard in his hands. It didn't look like documents. It looked like blank paper and he goes, let me have your name. I'll write you down and get you on the list to get in. And I was like really. And he was like yeah.
So I gave him my name and he wrote it down and he said it was for Saturday, but it didn't appear that anything was going on that Saturday. So I assumed he meant another Saturday and then another Saturday. And it turns out I think he was referring tc what they call a maiden voyage event which is I believe held on four Fridays in a particular month to -- I think it was originally to signify the maiden voyage of either the Apollo or the Freeland (phon) or something like that. And now it's mainly used to I think update the Sea Org. On ongoing events and projects that are breaking news we should say within the Scientology organization.
And in doing that earlier later on I was wearing -- actually I'm not sure if I was wearing the T-shirt then or not. I might have been. But he had come up to me, you know, with the security guard with him, shadowing him, so to speak. And I was filming at the corner at that time. And he came up to me and obviously recognized or put two and two together because he went and put my name on the list and realized that, you know, my name for the invitation wa: not supposed to be on an invitation. Came in a really heated manner and cussed me out over it. He was like, you know -- I think he said something to the effect of I can't believe you would try to pass yourself off as an IAS member or something like that or some really bizarre bad word, paragraph of something to that effect.
And immediately when it turned like into something that he said more than he should, the security guard behind him tapped him on the shoulder and he immediately stopped and stood blankly and he turned and walked away.
But it was one of the only times that I had seen a security guard actually with another individual and-bringing him across to my side of the street to physically talk to me. Because in previous events leading up to this, as well as afterwards, I have a lot of footage of the security guards keeping people from actually crossing the street to my side in either sense. In one case even going as far as to gra: at a lady who was unknowing that she shouldn't be crossing to my side of the street for whatever reason she wanted to cross to either talk to me or maybe even make a shortcut to another building or maybe even get cup of coffee over at Starbucks. The security was jumping out trying to keep people directly going from back and forth on the other side of the street and for their attention not to be paid in my direction I guess. I thought that was very interesting.
Q. Well, what was your purpose in wearing the IAS T-shirt?
A. Actually an ex-member had given it to me, a former high-level member or I should say old member. He was in the organization for a long time back in the day it started. I think he was on the Apollo. I can't recollect his name. Anyway he had given it to me for good luck.
Q. What was your purpose in wearing that T-shirt?
A. It was clean.
(At this time Plaintiff's Exhibit No. 21 was marked for identification.)
BY MR. POTTER:
Q. Let me show you what I've marked as Exhibit 21, which is one of the postings that you made under the name of Proflex on the Clambake website.
Does it indicate that communication really flows when you wear that T-shirt?
A. It sure does. Well, not so much now I would imagine, but -
Q. Does that mean that people come over and talk to you?
A. No. They don't come over and talk to me. If I happen to be in a situation where I'm like next tc somebody who doesn't recognize who I am because the Church has posted -
Q. What does it mean when it says "communication really flows"?
A. Somebody would talk -- somebody that normally wouldn't talk to me probably would talk to me as far as a Sea Org. member I should say.
Q. Did you find that when you wore the IAS T-shirt more people would talk to you?
A. Just in that one instance. So it's one nothing, I guess.
MR. POTTER: All right. I don't think I have any further questions. Your witness, Mr. Lirot.
MR. LIROT: Thank you, sir.
CROSS-EXAMINATION BY MR. LIROT:
Q. Mr. Lonsdale, have you ever been a member of the Lisa McPherson Trust in any manner, shape or form?
A. No.
Q. And other than the discussions with Ms. Greenway and Mr. Alexander that you testified to, have you ever had any discussions with Jesse Prince, Grady Ward, Robert Minton, Jr., Stacy Brooks, Jeff Jacobson, Mark Bunker or Troy Bezazian?
A. No.
Q. In any of your conduct that's been the subject of your testimony today, have you ever engaged in shouting?
A. Oh, no.
Q. Any yelling?
A. No.
Q. Any act of violence that threatened the health and safety of individuals or other persons utilizing public ways?
A. No.
Q. Ever get involved in any instances of wrestling, grappling, groping or rolling on the public sidewalk?
A. Yes.
Q. And that was the issue involving Mr. Fitzgerald?
A. Yes.
Q. Anything other than that?
A. No. I think there was some shouting in that as well, though.
Q. Were you the initiator of that shouting?
A. No.
Q. Have you ever engaged in any surreptitious videotaping or spying of anyone in your activities?
A. No.
Q. Have you ever engaged in picketing, protesting or demonstrating at any Scientology facilities in Clearwater or any place else?
A. No.
Q. Did you have an opportunity to review the copy of the permanent injunction that was served on you?
A. Yes.
Q. Did you believe that it applied to you ir any way?
A. No.
Q. Have you ever acted as an agent of any of the people that are listed as the defendants in that particular injunction?
A. No.
Q. Did Peter Alexander or Patricia Greenway direct you to engage in any course of conduct whatsoever?
A. No.
Q. Do you have any intent in taking photographs or video, of using that for any kind of commercial gain?
A. No.
Q. And is your project as you call it generally something that's done in the form of a documentary?
A. Yes.
Q. I think your testimony was you view it as a tale of the Church in our community?
A. Yeah, yes.
Q. Do you think that's an issue of public importance?
A. Oh, yes.
MR. LIROT: That's all I have.
REDIRECT EXAMINATION BY MR. POTTER:
Q. Mr. Lonsdale, let me show you a picture that purports to be taken on July 13. Is that picture of you and your Cult Watch sign?
A. Yes.
Q. What's that green thing in your arms?
A. That's my companion. He's an -- actually it's a stuffed alien.
Q. A stuffed alien?
A. Uh-huh (nods affirmatively). Stuffed toy.
Q. Why? Why are you carrying that stuffed alien with you?
A. Good luck.
Q. Why is a stuffed alien good luck to you?
A. It's always been good luck for me. Actually it sits in my car at this very moment.
Q. Where did you obtain your stuffed alien from?
A. Thrift store, fifty cents.
Q. I didn't hear your answer, sir.
A. Thrift store, fifty cents he cost me. As well as -- actually I have two.
Q. When did you obtain your stuffed alien?
A. Couple of years ago actually.
Q. So you display a stuffed alien along with your Cult Watch sign while you're engaged in your filming activity in the vicinity of the Church buildings, is that correct?
A. Correct.
Q. Do you consider carrying a stuffed alien something that may be offensive to members of the Scientology Church?
A. I don't see why it would be.
Q. It's never occurred to you that it might be?
A. Not particularly. Although I do believe, now that you mention it, you know what, there is an alien mentioned in OT Level 3 I believe.
Q. You had not mentioned that? You had not noticed that before?
A. Well, he doesn't really look like the same alien.
Q. What does the alien mentioned in OST look like?
A. OST? You mean OT-3?
Q. Yes, OT-3, I'm sorry.
A. Well, there's been many different -actually it doesn't even -- it doesn't describe him in particular or what he looks like rather.
Q. Is your testimony that the stuffed alien that you carry has nothing to do with OST (sic)?
A. Well, if it were, it would be pure coincidence, but -- seeing as I've had the alien longer probably than I've been doing this project.
(At this time Plaintiff's Exhibit No. 22 was marked for identification.)
MR. POTTER: Let's mark that photograph as Exhibit 22. Do you want to see the pictures of a stuffed alien? I don't think I have any further questions. You got anymore, Luke?
MR. LIROT: No.
MR. POTTER: Do you want to explain reading and signing?
MR. LIROT: Yes. If a request is made tc have this transcribed, you'll have the opportunity to read the transcript. You can't change any of your answers, but if you feel that there have been any errors or there's any explanation necessary, you can certainly do so. Would you like to read?
THE WITNESS: Yes.
(At this time the deposition in the above-captioned matter was concluded at 1:59 p.m.)
STATE OF FLORIDA ) COUNTY OF PINELLAS)
I, DENISE HERROLD, Court Reporter, certify that I was authorized to and did stenographically report the foregoing deposition; and that the transcript is a true record of the testimony given by the witness.
I further certify that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorney or counsel connected with the action, nor am : financially interested in the action.
I, the undersigned authority, certify that SHAWN LONSDALE personally appeared before me and was duly sworn.
WITNESS my hand and official seal this 31ST DAY OF JULY, 2006.
(~ ~Swd-DENISE A. HERROLD
NOTARY PUBLIC - STATE OF FLORIDA COURT REPORTER
.~.~.e
DENISE A. HERROLD
* ~~ = MY COMMISSION # DD 334069
EXPIRES; June 29, 2008 Bonded ihru Notary Public Undenvriters
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