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Filing # 33393380 E-Filed 10/19/2015 02:08:04 PM

IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT


IN AND FOR PINELLAS COUNTY, FLORIDA
REF NO.: 99-007430-CI-8
UCN: 521999CA007430XXCICI

CHURCH OF SCIENTOLOGY FLAG


SERVICE ORGANIZATION, INC.,
Petitioner,
vs.
LISA MCPHERSON TRUST INC., a
Florida for-profit corporation,
JESSE PRINCE, GRADY WARD,
ROBERT S. MINTON, JR., STACY BROOKS,
JEFF JACOBSON, PATRICIA GREENWAY,
PETER ALEXANDER, MARK BUNKER and
TROY BEZAZIAN,
Respondents.
_____________________________________________/
INTERVENORS RESPONSE TO
PLAINTIFFS REQUESTS FOR ADMISSIONS
Intervenor Alex Hageli (Intervenor), files this Response to Plaintiffs Request for
Admissions:
1.

You regularly protest the activities of Flag in Clearwater, Florida.

RESPONSE: Intervenors Motion to Intervene and Motion to Dissolve Permanent


Injunction speaks for itself and is restated here: Intervenor, an Illinois resident and Pinellas
County property owner, visits the Clearwater area approximately three to four times a year.
While visiting Intervenor frequently protests Petitioner Church of Scientology Flag Service
Organization, Inc. (FSO).
2.

Attached to this request as Exhibit B is a document entitled Dates Alex Hageli Has

Picketed in Clearwater, showing a total of 82 days between June 27, 2011, and August 25, 2015.
With regard to this list, please admit that it is an accurate listing of 82 separate instances when you

have protested, picketed, photographed, videoed or otherwise been present in the vicinity of Flags
properties in downtown Clearwater, Florida.
RESPONSE: Admit, except the exhibit incorrectly identifies date of service of the
injunction as May 8, 2014, when in fact service occurred on May 10, 2014.
3.

The screen name that you use when posting items on the internet is Darth Xander.

RESPONSE: Intervenor admits that he occasionally post items to the internet under
the alias Darth Xander.
4.

Attached as Exhibit C is a genuine copy of a posting made on the internet in

connection with your co-sponsorship of an Anti-Scientology Cult Conference, May 2014 held
in Clearwater, Florida, between May 5 and May 10, 2014.
RESPONSE: Admit, but Intervenor disagrees with Plaintiffs characterization of him
as a co-sponsor.
5.

All of the facts and matters recited in Exhibit C are true.

RESPONSE: Admit.
6.

Attached as Exhibit D is a genuine copy of a posting entitled Flag Down 2014 Full

Schedule, that you made on the internet on May 4, 2014, using your screen name, Darth Xander.
RESPONSE: Admit.
7.

All of the facts and matters recited in Exhibit D are true.

RESPONSE: Deny.
8.

Attached as Exhibit E is a genuine copy of a photograph posted on Facebook

accurately depicting you (center) and defendant, Mark Bunker (left) together with a third person
at the Flag Down conference of May, 2014.
RESPONSE: Admit.

9.

Attached as Exhibit F is a genuine copy of a transcript of some remarks you made

at the Flag Down Conference on May 9, 2014, together with some remarks of other attendees at
the conference, regarding the injunction that was issued in this case.
RESPONSE: Admit.
10.

In Exhibit E you introduce another participant in Flag Down, Pete Griffiths, as [a]

guy [who is] more obsessed with Scientology than I am and that is fucked up.
RESPONSE: Admit.
11.

Attached as Exhibit G is a genuine copy of a transcript of some remarks that

defendant, Mark Bunker, made at the Flag Down conference on May 9, 2014, after being
introduced by Pete Griffiths.
RESPONSE: Admit.
12.

You and defendant, Mark Bunker, both actively participated in the Flag Down

conference in May, 2014.


RESPONSE: Admit as to Intervenor. Admit that Intervenor is aware that defendant
Mark Bunker was initially denied entry to the Flag Down conference but subsequently
attended two events, the second of which he spoke to attendees for approximately 10 minutes.
13.

In your posting attached as Exhibit C, you accurately and truthfully describe

yourself as an anti-Scientology activist and protester since 2010


RESPONSE: Admit.
14.

It was only after your participation in the Flag Down event in Clearwater in May,

2014, that Flag served you with a copy of the permanent injunction in this matter.
RESPONSE: Admit.

15.

On your Facebook page, you list Mark Bunker and Tory Christman a/k/a Tory

Bezazian, both of whom are defendants in this case, as friends.


RESPONSE: Intervenor admits that he occasionally accepts friend requests on
Facebook from individuals he either does not know or with whom he communicates with
infrequently, including Mark Bunker and Tory Christman a/k/a Tory Bezazian.

DATED: October 19, 2015

Respectfully submitted,

s/ Alex Hageli
Alex Hageli
435 South Cleveland Avenue, Apt. 306
Arlington Heights, IL 60005
(847) 630-5710
ahageli@yahoo.com

CERTIFICATE OF SERVICE
I HEREBY CERTIFY, on this 19th day of October, 2015, I caused the foregoing Intervenors
Response to Plaintiffs Requests for Admissions, to be filed electronically, and served same, by
electronic service, upon the following counsel of record:

F. Wallace Pope, Jr.,


Johnson, Pope, Bokor, Ruppel & Burns LLP
911 Chestnut Street
Clearwater, Florida 33756
wallyp@jpfirm.com

s/ Alex Hageli