Affidavit In Support Of First Addendum To Citizen Complaint Of 02/25/2002

(Martin Ottmann)

Affidavit In Support Of First Addendum To Citizen Complaint Of 02/25/2002

I) Introduction

This affidavit is written in support of the enclosed First Addendum to Citizen Complaint of 02/25/2002 to be filed with the U. S. Attorney's Offices in Boston (Massachusetts), Concord (New Hampshire), Los Angeles (California), and Tampa (Florida).

The affidavit proves that from November of 1997 until January of 2001 the individuals

- Michael J. Rinder, a corporate director of the "Church of Scientology International," a Californian non-profit corporation, and ecclesiastical head of the organization's "Office of Special Affairs" network,

- Elliot J. Abelson, an attorney from California and counsel for the "Church of Scientology International",

and the corporations

- Church of Scientology International, a Californian non-profit organization,

- Church of Scientology of Boston, Inc., a Massachusetts non-profit corporation,

have committed crimes under U. S Title 18, specifically with regards to

- Chapter 13, Section 241.

Secondly the affidavit proves that from May of 2000 until April of 2002 the individual

- Robert S. Minton from Sandown, New Hampshire,

and the corporation

- Lisa McPherson Trust, Inc., a Floridian corporation,

have committed crimes under U. S. Title 18, specifically with regards to

- Chapter 95, Section 1956.

In particular this affidavit shows that two Scientology corporations, the "Church of Scientology International" (CSI) and the "Church of Scientology of Boston, Inc." through their "Office of Special Affairs" network conducted between November 1997 and January 2001 an extensive and concerted harassment and intimidation campaign against its critic Robert Minton of New Hampshire by targeting not only him personally but also his immediate family members, relatives and former business partners. The goal of these campaigns was to stop Minton publicly criticizing Scientology and giving financial aid to other critics of Scientology who at that time were entangled in litigation against the organization.

Two individuals were instrumental in the initiation process and the later supervision of this campaign: Elliot Abelson, a California attorney and general counsel for the "Church of Scientology International" and Michael Rinder, a corporate director of CSI and the head of the organization's intelligence unit "Office of Special Affairs."

This document also shows that Robert Minton himself has laundered money of at least one and a half million U. S. dollars into the United States within the past two years while having lied during depositions and in court about the origins of these funds. Minton additonally pleaded his Fifth Amendment rights against self-incrimination when he was asked if he had committed tax fraud in connection with these monetary transactions.

In two instances Robert Minton did use the Floridian corporation "Lisa McPherson Trust, Inc." to receive alleged "loan re-payments" in the amount of $ 650,000 that allegedly had been sent to the organization by anonymous sources, when these donations had been in fact originated by Minton himself using overseas bank accounts.

Attached to this affidavit is a Compact Disc, which contains the exhibits that are listed in this document. The exhibits are scanned versions of documents, which support the statements of this affidavit. Additionally the CD contains a digital version of this affidavit with direct links to the individual exhibits for the purpose of easier reading.

Background

My name is Martin Ottmann. I am 36 years old and a German citizen, currently living in France. My address is 54, rue Pierre Brossolette, 92300 Levallois-Perret.

In February of this year I filed a Citizen Complaint with the U. S. Attorney's Offices in Los Angeles, California and Tampa, Florida against four Scientology corporations: "Religious Technology Center," "Church of Scientology International," "Church of Scientology of Western United States" and "Church of Scientology Flag Service Organization, Inc." [Exh. No. 1]. The field offices of the Internal Revenue Service in Los Angeles [Exh. No. 2] and in Tampa [Exh. No. 3] are currently revising this complaint.

Three months ago I was notified about certain legal developments in a lawsuit in Pinellas County, Florida ("Estate of Lisa McPherson vs. Church of Scientology Flag Service Organization et al," Circuit Court for Pinellas County, No. 00-5682-CI-11). The lawsuit was brought about by the dependents of a Scientologist, who had died at the headquarters of the Scientology organization in Clearwater in late 1995. The lawsuit alleges that the organization was responsible for the death of Lisa McPherson, who was under the care of Scientology staff members because of a psychotic breakdown she had experienced 17 days prior to her death.

On April 9th, during contempt hearings in a related lawsuit ("Church of Scientology Flag Service Organization vs. Dell Liebreich, Robert Minton & LMT," Circuit Court for Pinellas County, No. 00-002750-CI-20), Robert Minton declared in court that he had previously lied in depositions about several issues in the wrongful death suit including the amount of money he had given to fund the suit on behalf of the estate of Lisa McPherson. He also claimed to have lied upon the request of the estate's attorney, Kennan Dandar. Following Minton's testimony the attorneys of the Church of Scientology submitted motions to the court to remove Dandar from the wrongful death case because of alleged abuse of process and conspiracy.

Subsequently the local media from Saint Petersburg [Exh. No. 4] and Tampa [Exh. No. 5] reported about the sudden turnaround of Minton who had been an outspoken critic of Scientology for the past five years. More court hearings followed during which Minton's allegations against Dandar were examined by the lawyers for both parties and by the court. On this occasion Minton announced that prior to his disclosures in court he had met with representatives of Scientology to discuss a possible settlement with the organization.

During the month of May I received the first court transcripts of Robert Minton's examination and due to the testimony not only with regards to Minton's financial transactions but also to the Church of Scientology's past operations against him, I decided to write an addendum to my prior Citizen Complaint in order to include these recent developments and put them in context with the current and past activities of Scientology.

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