Grady Ward
In Pro Se
3449 Martha Ct.
Arcata, CA 95521-4884
grady@northcoast.com
http://www.northcoast.com/~grady/Welcome.html
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
RELIGIOUS TECHNOLOGY CENTER, a ) No. C 96-20207
California non-profit corporation, )
) OBJECTIONS AND RESPONSES
Plaintiff, ) TO REQUEST FOR PRODUCTION
) OF DOCUMENTS AND THINGS;
v. ) ACKNOWLEDGE NOTICE OF
) DEPOSITION
GRADY WARD )
)
Defendant. )
____________________________________)
TO ALL PARTIES AND THEIR ATTORNEYS OF
RECORD:
PLEASE TAKE NOTICE THAT pursuant to
written stipulation, Rule 30 of the Federal Rules of Civil Procedure,
and the Court's order, plaintiff RELIGIOUS TECHNOLOGY CENTER does
hereby notice the deposition of GRADY WARD to be taken at Crnich
Deposition located at 626 "H" Street, Eureka, California
95501, commencing at 9:00 a.m. on April 8, 1996, and continuing
from day to day thereafter, as approved by the Court, excluding
Saturday, Sunday and holidays, until completed before a notary
public authorized to administer the oath. The deposition will
be recorded stenographically and may be recorded by sound and
visually.
ACKNOWLEDGE AS PER COMPROMISE WITH
JUDGE WHYTE THAT DEPOSITION WILL BE LIMITED TO ONE EIGHT HOUR
SESSION, WITH AND ADDITIONAL HOUR GRANTED BECAUSE OF EUREKA LOCATION.
THIS TIME MAY BE DIVIDED OVER TWO DAYS IN ANY PROPORTION DESIRED
BY PLAINTIFF.
PLEASE TAKE FURTHER NOTICE THAT Mr.
Ward is hereby requested, pursuant to Rule 34 of the Federal Rules
of Civil Procedure, written stipulation, and the Court's order,
to
produce at the Law Offices of Thomas
R. Hogan, Esq., 60 South Market Street, Suite 1125, San Jose,
California 95113, on April 6, 1996, or as otherwise specified
herein, the documents
and things requested in Exhibit A attached
hereto which are in the possession, custody, or control of Mr.
Ward. Should the deposition be postponed for any reason, you
will remain obligated to produce documents on this date.
UNCONTESTED DOCUMENTS AND THINGS WILL
BE PRESENTED FRIDAY, APRIL 5, 1996 IN ARCATA, CALIFORNIA AS ARRANGED
BY PLAINTIFF AND DEFENDANT.
Dated: April 4, 1996
Grady Ward
In Pro Se
___________________________________
DOCUMENTS AND THINGS TO BE PRODUCED
1. All copies of the OT III documents
which were posted to the Internet in or about February, 1995 under
the header attached hereto as Exhibit 1.
NO DOCUMENTS POSSESSED
2. All copies of NED for OTs Series
1 which was posted to the Internet in or about February, 1995
under the header attached hereto as Exhibit 2.
NO DOCUMENTS POSSESSED
3. Any and all documents relating to
posting, reproduction, distribution, or display of works of L.
Ron Hubbard, including but not limited to, the Works.
NO DOCUMENTS POSSESSED
4. Any and all documents relating to
your solicitation from others of copies of works of L. Ron Hubbard,
including but not limited to, the Works.
NO DOCUMENTS POSSESSED
5. All documents which you have received
as a result of your solicitation of NOTs materials, OT materials,
or other Scientology materials.
NO DOCUMENTS POSSESSED
6. All documents relating to posting
of Scientology materials on the Internet, including without limitation,
ftp sites, web sites, or newsgroups.
NO DOCUMENTS POSSESSED
7. Any and all documents relating to
acquisition of any Advanced Technology documents.
NO DOCUMENTS POSSESSED
8. Any and all document relating to
the identify of any individual who has posted any of the Advanced
Technology to the Internet, either under that person's own name
or via an anonymous remailer.
NO DOCUMENTS POSSESSED
9. Any and all documents relating to
postings made by you, whether under you own name, a pseudonym,
or anonymously to the USENET newsgroups entitled alt.religion.scientology,
alt.2600, alt.activism, comp.org.eff.talk, or any other newsgroup
relating to the Advanced Technology.
NO DOCUMENTS POSSESSED
10. Any and all documents relating to
the posting of Advanced Technology documents to the USENET newsgroup
entitled alt.religion.scientology, including, without limitation,
copies of such postings or discussions of such postings, whether
actual or planned.
NO DOCUMENTS POSSESSED
11. Any and all documents relating to
postings of Advanced Technology materials, including, but not
limited to, actual postings or discussions of such postings, whether
actual or planned, made through the following servers:
a. freezone.remailer
b. nately.ucsd.edu
c. penet.fi
d. replay.comm
e. utopia.backtic.nl
NO DOCUMENTS POSSESSED
12. All documents relating to communications
between you and anyone regarding your posting of works by or alleged
to be by L. Ron Hubbard, whether under your own name, a pseudonym,
or anonymously, including, but not limited to, discussions prior
to or following such postings.
NO DOCUMENTS POSSESSED
13. Any and all documents relating to
communications with the following individuals relating to the
Advanced Technology:
a. Alex DeJoode
b. Dennis Erlich
c. Steven Fishman
d. Johan Helsingius
e. Jeff Jacobsen
f. Keith Henson
g. Tom Klemesrud
h. Arnaldo Lerma
i. Peter Mante
j. Ron Neuman
k. Robert Penny
l. Felipe Rodriquez
m. Karin Spaink
n. Shelly Thomson
o. David Touretzky
p. Lawrence Wollersheim
OBJECT BECAUSE OF 18 U.S.C. 2700,
et sqq. (E.C.P.A.)
14. All documents showing the name,
address, and/or telephone number of anyone to whom you have sent
Advanced Technology materials, whether in hard copy or electronic
form.
NO DOCUMENTS POSSESSED
15. All documents showing the name,
address, and/or telephone number of anyone who has sent Advanced
Technology materials to you, whether in hard copy or electronic
form.
NO DOCUMENTS POSSESSED
16. All documents sent to you by Arnaldo
Lerma related to the Advanced Technology, including, but not limited
to, transmissions or discussions of such documents.
NO DOCUMENTS POSSESSED
17. Any and all documents relating to
the licensing or customer agreement between you and any Internet
access provider.
OBJECT BECAUSE OF NON-RELEVANCE; any
event it would be identical to the customer agreement currently
in force as on file with the provider.
18. Any and all documents regarding
Netcom On-Line Communication Services, Inc. or any other Internet
access provider warning you regarding the posting of copyrighted
materials on the Internet or any other activity by you through
that access provider's facilities.
OBJECT BECAUSE OF NON-RELEVANCE
19. Any and all documents relating to
Netcom On-Line Communication Services, Inc. or any other Internet
access provider taking disciplinary action against you regarding
the posting of copyrighted materials on the Internet or any other
activity by you through that access provider's facilities.
OBJECT BECAUSE OF NON-RELEVANCE
20. Any and all documents relating to
Scamizdat, including, without limitation, persons in active concert
or participation with Scamizdat, acting on its behalf, or controlling
its activities.
WILL PROVIDE GROUP INDICES TO USENET
VIEWING APPLICATION, possible e-mails OBJECT BECAUSE OF 18 U.S.C.
2700, et sqq. (E.C.P.A.), for all other categories, NO DOCUMENTS
POSSESSED.
21. Any and all documents relating to
postings by Scamizdat on the Internet, including, without limitation,
the posting themselves, predictions of such postings, and references
to Scamizdat.
NO DOCUMENTS POSSESSED
22. All documents relating to the First
Electronic Church of SCAMIZDAT.
NO DOCUMENTS POSSESSED
23. All documents on which you based
your posting of August 1, 1995 which stated that "SCAMIZDAT
#10 is going to post the complete Fishman appendices, including
all the OT levels I-VIII."
NO DOCUMENTS POSSESSED
24. All documents upon which you based
your "suspicions," as referenced in The Recorder
of March 25, 1996, about the identity of SCAMIZDAT.
NO DOCUMENTS POSSESSED
25. Any and all documents relating to
confidentiality agreements pertaining to the Works.
NO DOCUMENTS POSSESSED
26. All documents relating to communications
you have received from or sent to any representative of Religious
Technology Center or any Church of Scientology, including any
attorney acting on their behalf.
WILL PROVIDE "Lanham Act"
LETTER; "Service" LETTER
27. All documents relating to your attempts
to discredit Helena Kobrin as an attorney acting on behalf of
Religious Technology Center in protecting its intellectual property
rights.
OBJECT BECAUSE OF INCOMPREHENSIBILITY
OF QUESTION and, without prejudice to the first objection, OBJECT
BECAUSE OF NON-RELEVANCE
28. All documents relating to telephone
records from July 1, 1994 to the present.
OBJECT BECAUSE OF NON-RELEVANCE
29. All documents concerning the use
by you, or anyone acting directly or indirectly under your control
or in concert or participation with you, of storage facilities
away from your primary residence.
NO DOCUMENTS POSSESSED
30. All documents discussing your scanning
of any writings by L. Ron Hubbard, including, but not limited
to, Advanced Technology materials, books, policy letters, bulletins,
and transcripts of any audio or video taped materials, or any
other materials related to the Church of Scientology, on your
computer.
NO DOCUMENTS POSSESSED
31. All documents relating to software
programs which you have created regarding any of the following:
anonymous remailers, USENET news, Internet access, scanning of
documents onto computer media, uploading or downloading of documents
onto computer media, encryption of computer transmissions or files,
lexicons, Scientology materials, or copyrights.
WILL PROVIDE LEXICON SOFTWARE; otherwise,
NO DOCUMENTS POSSESSED
32. All documents relating to software
programs which you use regarding any of the following: anonymous
remailers, USENET news, Internet access, scanning of documents
onto computer media, uploading or downloading of documents onto
computer media, encryption of computer transmission or files,
lexicons, Scientology materials, or copyrights.
COMPUTER MANUALS, BOTH ELECTRONIC
AND PAPER WILL BE PROVIDED ON
FRIDAY, APRIL 5, 1996 FOR INSPECTION,
AS PER APRIL 3, 1996 HOGAN CONVERSATION
33. All documents relating to any works
which you have written regarding any of the following: anonymous
remailers, USENET news, Internet access, scanning of documents
onto computer media, uploading or downloading of documents onto
computer media, encryption of computer transmission or files,
lexicons, Scientology materials, or copyrights.
LEXICON MATERIAL PROVIDED AS PART
OF 31.; otherwise NO DOCUMENTS POSSESSED
34. All shredders.
TO BE PROVIDED FOR INSPECTION; WILL
BE PROVIDED ON FRIDAY APRIL 5, 1996 FOR INSPECTION, AS PER APRIL
3, 1996 HOGAN CONVERSATION
35. All scanning equipment.
TO BE PROVIDED FOR INSPECTION; WILL
BE PROVIDED ON FRIDAY APRIL 5, 1996 FOR INSPECTION, AS PER APRIL
3, 1996 HOGAN CONVERSATION
36. All locks which you place on any
cabinet or other container in which you have placed Scientology
materials.
NONE SATISFY REQUEST
37. All documents relating to procedures
for shredding documents, either hard copy or in electronic form.
EXCEPT FOR USER'S MANUAL, NO DOCUMENTS
POSSESSED