Proposed 2nd amendment and addition to pretrial order filed by defendant's FACTNet and Lawrence Wollersheim

[December 11, 1998]

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 95-K-2143

BRIDGE PUBLICATIONS, a California non-profit corporation,

    Plaintiffs,

V.

F.A.C.T.NET, INC., a Colorado nonprofit corporation; LAWRENCE WOLLERSHEIM, an individual; and ROBERT PENNY, an individual,

    Defendants.


PROPOSED 2ND AMENDMENT AND ADDITION TO PRETRIAL ORDER FILED BY DEFENDANT'S F.A.C.T.NET AND LAWRENCE WOLLERSHEIM

(B)    NON-EXPERT WITNESSES TO BE CALLED BY DEFENDANTS

1.    Mark Plummer, Austin, Texas, testifying in person. Mr. Plummer is an ex-Scientology staff member who will be called to testify as to the authenticity of documents. The documents in question are "Originals" of documents that Plaintiff BPI has submitted to the court as the Deposit copies that were filed with the copyright office. Mr. Plummer will testify that he obtained the documents in question while he was on staff with Scientology as separate issue documents prior to the date that the BPI submitted Deposit copies were registered with the copyright Office.

2.    Vicki Aznaran, Dallas, Texas, testifying by deposition. Ms. Aznaran is a former member of the board of Directors and President of Religious Technology Center, Inc. (RTC) the original plaintiff in this matter. She has been identified as having been present at a conferences held in the offices of Author Services, Inc. in 1983. Ms. Aznaran will testify as to her knowledge as to whether certain copyrights at issue herein were registered with the copyright office despite the fact that they were known to have already fallen into the public domain. Ms. Aznaran will also testify as to her knowledge as to whether Scientology ever engaged in a practice of altering documents to add backdated copyright notices and whether or not Scientology engaged in the practice of altering or destroying
evidence. (Ms. Aznaran will be deposed and testify subject to the court granting defendant's motion to reopen discovery.)

3.    Person Most Knowledgeable (or Custodian of Records) for Church of Spiritual Technology (CST) with reference to CST's collection, verification and preservation of 500,000 pages of L. Ron Hubbard original documents. This witness will testify by deposition. This witness will be called to verify whether or not the documents filed with this court and the copyright office accurately reflect the contents of documents as originally published and the method by which CST has verified the authenticity of the documents at issue. (This witness will be deposed subject to the court granting
defendants' motion to reopen discovery.)

D.    EXPERT WITNESSES TO BE CALLED BY THE DEFENDANTS

1.    Steven Kent, Doctor of Sociology, University of Alberta, Canada. Dr. Kent will testify in person.

In addition to the areas that he has already been elected to testify in, Dr. Kent will authenticate a large number of "Original"
documents that have been collected and archived over a number of years by the University of Alberta and compare these documents to the deposit copies of the same documents filed with the copyright office and submitted to the court by the plaintiff's herein. Dr.
Kent will also testify Scientology's method for publishing
documents.

2.    Howard Rile, forensic document examiner, Long Beach,
California. Mr. Rile will testify in person.

Mr. Rile is a qualified forensic document examiner who served as question document examiner for the State of Colorado at the Colorado Bureau of Investigation in Denver. Mr. Rile will testify to his examination of documents to determine their age and authenticity.

DATED:

BEEM & MANN


(signed) CLIFFORD BEEM