||||| From: ptsc Newsgroups: alt.religion.scientology Subject: FACTnet Requests for Admission Date: Tue, 18 Dec 2001 13:18:23 -0500 Organization: ARS: Perhaps the Most Malignant Newsgroup on Usenet Message-ID: <132v1u0oj0rhsg1d1d33ndju5clh3flecp@4ax.com> X-Newsreader: Forte Agent 1.8/32.553 MIME-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-Complaints-To: newsabuse@supernews.com Lines: 248 Path: corp.newsgroups.com!propagator-maxim!feed.newsfeeds.com!newsfeed.direct.ca!look.ca!cyclone.bc.net!newsfeed.stanford.edu!sn-xit-01!sn-post-01!supernews.com!corp.supernews.com!not-for-mail Xref: newsfeeds alt.religion.scientology:1273494 From: rkeller@netaxs.com (Rod Keller) Subject: Factnet Requests for Admission Date: 1997/04/18 Message-ID: <5j8605$ifv@netaxs.com> Organization: Philadelphia's Complete Internet Provider Newsgroups: alt.religion.scientology I thought this was timely. The non-sequential numbering of the paragraphs is from the original, and the pages are numbered sequentially. I believe these are the complete documents. ---------------------------------------------------------- IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 95-K-2143 RELIGIOUS TECHNOLOGY CENTER, a California non-profit corporation, and BRIDGE PUBLICATIONS, INC., a California non-profit corporation, Plaintiff, v. F.A.C.T.NET, INC., a Colorado corporation; LAWRENCE WOLLERSHEIM, an individual; and ROBERT PENNY, an individual, Defendants. DEFENDANT F.A.C.T.NET, INC.'S THIRD SET OF REQUESTS FOR ADMISSIONS FROM PLAINTIFF RELIGIOUS TECHNOLOGY CENTER, INC. Pursuant to Fed. R. Civ. P. Rule 36, defendant F.A.C.T.NET, INC. ("FACTNET") hereby propounds the following requests for admission to plaintiff Religious Technology Center, Inc. ("RTC"). Defendant FACTNET requests that RTC serve its responses to these request no later than May 9, 1997. Definitions For purposes of these requests: 1. The words "you" and "your" refer to plaintiff and to any director, officer, employee, agent, licensee or anyone acting on plaintiff's behalf or in concert with plaintiff. 2. The phrase "Complaint" refers to the document filed in this action styled "Verified Complaint for Injunctive Relief and Damages For: (1) Copyright Infringement; and (2) Trade Secrets Misappropriation (C.R.S. 7-74-102 et seq.) and/or any subsequent operative complaint herein." 3. The phrase "Disputed Works" refers to the various works identified in the operative complaint filed in this action and any other works which plaintiffs claim constitute a trade secret and/or copyright work which has been allegedly infringed by defendants. 4. "LRH" shall mean Lafayette Ron Hubbard a/k/a/ L. Ron Hubbard. 5. "POST" shall mean and include a position or a job title within the Scientology organization. 6. "Scientology Organization", "Churches of Scientology", "Corporations of Scientology" and "Churches of Scientology" shall include all those listed on the Scientology Command Chart, all those which were part of the Church of Scientology International's Group I.R.S. 501(c) (3) tax exempt application, Religious Technology Center, Inc., Church of Scientology International, Inc., Church of Scientology of California, Church of Spiritual Technology, Author Services, Inc. and Bridge Publications, Inc. REQUESTS FOR ADMISSION [Operation Snow White/Fair Came Foundation Unclean Hands/Misuse of Copyright, R. Vaughn Young Experience, etc.] You are requested to Admit or Deny the following: 28. That LRH wrote a document initiating the Snow White Program, ordinarily known as Snow White or Operation Snow White, and issued it to Department 20 for implementation. 29. That Robert Vaughn Young worked in the Snow White Program from 1973 until 1977. 30. That every Scientology Organization Board with 21 departments has a Department 20. 31. That in 1977 Department 20 was known as the Department of the Controller. 32. That in 1977, the Guardians Office was in Department 20. 33. That in 1977 Mary Sue Hubbard held the Scientology post of "Controller". 34. That in 1977, the FBI obtained a Search Warrant (the "Search Warrant") for simultaneous searches of Guardian's Office premises located in Washington, D.C. and Los Angeles, California. 35. That the Search Warrant included any material relating to Snow White. 36. That in September and October of 1979, counsel for various Scientology officials, including but not limited to Mary Sue Hubbard, Henning Heldt, Duke Snider, Richard Weigand, Gregory Willardson, executed a 262 page document entitled Stipulation of Evidence in the case United States of America v. Mary Sue Hubbard, United States District Court for the District of Columbia, Criminal No. 78-401 (the "Stipulation of Evidence"). 37. That at footnote 91, and on pages 123 and 124, the Stipulation of Evidence referred to the Snow White Program. 38. That David Miscavige was instrumental in removing Mary Sue Hubbard from her post as Controller or seeking her resignation. 39. That after Mary Sue Hubbard was removed as 'The Controller' David Miscavige claimed that he had abolished the Guardian's Office. 40. That the Office of Special Affairs ("OSA") was created after the abolition of the Guardians Office. 41. That OSA is located within Department 20 of the Church of Scientology International. DATED this 2nd day of April, 1997. MUSICK, PEELER & GARRETT LLP By: Graham E. Berry One Wilshire Boulevard Suite 2100 Los Angeles, California 90017 (213) 629-7854 ---------------------------------------------------------- IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 95-K-2143 RELIGIOUS TECHNOLOGY CENTER, a California non-profit corporation, and BRIDGE PUBLICATIONS, INC., a California non-profit corporation, Plaintiff, v. F.A.C.T.NET, INC., a Colorado corporation; LAWRENCE WOLLERSHEIM, an individual; and ROBERT PENNY, an individual, Defendants. DEFENDANT F.A.C.T.NET, INC.'S SECOND SET OF REQUESTS FOR ADMISSIONS FROM PLAINTIFF RELIGIOUS TECHNOLOGY CENTER INC. Pursuant to Fed. R. Civ. P. Rule 36, defendant F.A.C.T.NET, INC. ("FACTNET") hereby propounds the following requests for admission to plaintiff Religious Technology Center, Inc. ("RTC"). Defendant FACTNET requests that RTC serve its responses to these request no later than May 6, 1997. Definitions For purposes of these requests: 1. The words "you" and "your" refer to plaintiff and to any director, officer, employee, agent, licensee or anyone acting on plaintiff's behalf or in concert with plaintiff. 2. The phrase "Complaint" refers to the document filed in this action styled "Verified Complaint for Injunctive Relief and Damages For: (1) Copyright Infringement; and (2) Trade Secrets Misappropriation (C.R.S. 7-74-102 et seq.) and/or any subsequent operative complaint herein." 3. The phrase "Disputed Works" refers to the various works identified in the operative complaint filed in this action and any other works which plaintiffs claim constitute a trade secret and/or copyright work which has been allegedly infringed by defendants. 4. "LRH" shall mean Lafayette Ron Hubbard a/k/a/ L. Ron Hubbard. 5. "Post" shall mean and include a position or a job title within the Scientology organization. 6. "Scientology Organization", "Churches of Scientology", "Corporations of Scientology" and "Churches of Scientology" shall include, but not be limited to, Scientology Command Chart, all those which were part of the Church of Scientology International's Group I.R.S. 501(c)(3) tax exempt application, Religious Technology Center, Inc., Church of Scientology International, Inc., Church of Scientology of California, Church of Spiritual Technology, Author Services, Inc. and Bridge Publications, Inc. 7. "ASI" shall mean Author Services, Inc. REQUESTS FOR ADMISSION [Regarding Notarization] You are requested to Admit or Deny the following: 28. That in 1983, during Ronald DeWolf's probate case against his father LRH, in an action entitled IN RE THE ESTATE OF L Ron Hubbard, No. 47150, evidence was filed in the relevant court, by Scientology representatives, to the effect that no one in the Sc ientology organization knew how to communicate to or from LRH. 29. That Sherman D. Lenske, Esq., has testified that he was LRH's attorney from April 1981 until his death on January 24, 1986 and was involved in communications with LRH during the years 1981 to 1986 concerning, among other things, the pre and post testa mentary disposition of the Disputed Works. 30. That between 1981 and 1986 Sherman Lenske, Esq. and others from his law firm were meeting with representatives of ASI. 31. That as an employee of ASI, Robert Vaughn Young gave briefings to Sherman D. Lenske, Esq. and others from his law firm, about LRH. 32. That David Miscavige was a notary public during the years 1981 through 1986. 33. That during the years 1981 to 1986, ASI, and/or representatives thereof, possessed sheets of paper which were blank except for the signature of LRH for the purported purpose of being inserted into bound works making them autographed editions. 34. That between approx. 1981 and 1986 David Miscavige notarized at least one document signed by LRH, in which LRH appeared before him. 35. That David Miscavige never turned his notary public logs, for the years 1982 to 1986, into the Los Angeles County Records' office and such other authorities as may be required by law. DATED 2nd this day of April, 1997. MUSICK, PEELER & GARRETT LLP By: Graham E. Berry One Wilshire Boulevard Suite 2100 Los Angeles, California 90017 (213) 629-7854 --end--