Declaration of Robert Vaughn Young in support of defendants' motion to amend the pretrial order to name additional witnesses and to reopen discovery
[December 11, 1998]
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO
Civil Action No. 95-K-2143
BRIDGE PUBLICATIONS, INC., 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.
DECLARATION OF ROBERT VAUGHN YOUNG IN SUPPORT OF DEFENDANTS' MOTION TO
AMEND THE PRETRIAL ORDER TO NAME ADDITIONAL WITNESSES AND TO REOPEN DISCOVERY
I, Robert Vaughn Young, am a resident of Vashon, Washington. I am not a
party to this action. I am over 18 years of age and if called upon to testify thereto, I
could and would competently do so.
1. I have been asked to serve as an expert consultant
in this action, on behalf of Defendants. I have so served and testified before Judge Kane
in 1996 and my testimony was incorporated into the Court's ruling at that time.
2. On July 26, 1998, I submitted a declaration to the
court with regard to my capability of reviewing Scientology material, based on my 21 years
in various Scientology organizations, from 1968-89. That declaration contained the results
of my conducting a spot check of the approximately 1900 exhibits filed by Plaintiff. I
stated that the 57 documents randomly inspected showed that Plaintiff was making
fraudulent claims to the court as to the validity of these materials and their purported
ownership, authorship and originality. I have reread my declaration of that date and
reaffirm it and attached a copy hereto as Exhibit RVY1.
3. Since that declaration, I have personally
inspected each of the approximately 1900 exhibits filed by Plaintiff. I have inspected
what Plaintiff claims is a copy of the "L. Ron Hubbard Original," the material
found at FACTNet, and the copyright registration.
4. I have also since undertaken a search for actual
originals of the material in question to make a more extensive comparison to what the
Plaintiff has filed and upon which they are making their claims.
THE INHERENT COMPLEXITY USED BY THE PLAINTIFF
5. The Scientology organization is a labyrinth of
such complexity that even staff members get lost. This is because in the early 1950's, its
inventor L. Ron Hubbard ("Hubbard") created one organization after another and
fired off directives and material with a variety of names and headings and from several
locations. These locations would appear at the top of the document along with a date,
title or name of the piece, the type of directive it was meant to be (a bulletin, policy,
information letter, directive, etc.) and usually the distribution, or who it was to go to.
He would write it by hand or on a typewriter or he would dictate it for transcription. The
material would then be retyped (with the typist's initials usually on the last page) and
sent to mimeograph for copying and distribution. Sometimes the date of his dictation and
the date of the transcription even appeared on the material.
6. In the early decades of Scientology, Hubbard
sought the widest possible distribution of his ideas. Mailings of material were often sent
by postal service directly to the field. It was only as the organization began to assume
more form and size did he implement key distribution points where material was sent to be
recopied and redistributed.
7. Thus an "original" is what was
distributed at the time, even if through a re-copying point, because there was little lag
between the time that Hubbard wrote the material and when it was distributed. This was
because such value was put onto his latest "discovery" that customers wanted the
material, plus it was Hubbard's orders were to get this material out as quickly as
possible.
8. Thus the best way to find what might constitute an
"original" is to find material issued at that time, rather than a re-issue which
could have been done decades later, with alterations from the "original."
COLLECTIONS OF "ORIGINALS"
9. In those early decades, there was no question as
to the "authenticity" of material from Hubbard. Recipients also recognized the
format and even the types of paper. Because of the value people gave to this material, it
was saved. Even when the same material was re-issued by the organizations, these first
individual copies had greater value to members and were not readily discarded. If nothing
else, they had a "collector's" value as being part of the history of the
organization, when the members were more directly in contact with Hubbard. (The most
valuable are those that came from the UK, on UK-sized paper and with staples unique to
that country.) To that degree, there are collections of these "originals" that
date back decades. It was some of these that I found and was able to study and copy and
provide to the court in comparison to the Plaintiff's claims, and more can be found.
10. These documents substantiate even further my assertion that the
Plaintiff has sought to defraud this court. I now extend it further to say there is
evidence that they have also defrauded the U.S. Copyright Office.
HOW SCIENTOLOGY DIRECTIVES WERE MADE
11. Besides my familiarity with Scientology material
from handling and reading it for 21 years, I also had experience in copying and
distributing it to others.
12. From 1971-73, I worked in Department 20 at the
Church of Scientology in San Francisco. During that time, I had many occasions to recopy
Scientology material or directives as it was done in other organizations. The reason this
was done was either than new material had been received and was to be recopied and
distributed to staff and/or to the general public or material in our possession had to be
newly distributed. The reason for the latter might be because there was a program sent
down from an upper echelon that had to be implemented in the U.S. or internationally, for
example, a push to sell books. In such an instance, a particular directive or policy or
bulletin written by L. Ron Hubbard or another had to be widely re-issued as containing
information to be in the hands of staff and/or the public. This was often done as a step
on the program.
MIMEO FILES
13. That portion of the organization where
republication was done was called "Mimeo" which was short for
"mimeograph." At that time, recopying was done on a mimeograph machine.
14. Mimeo consisted of basically three types of
files. There was the "master" file, which contained the "originals",
or those received from a higher echelon. Then there was the files of the copies made from
the originals, from which someone would take a copy for their use. Then there was the
actual stencil that had been made and used to run off the copies. It was retained so that
if more copies were needed, a new stencil did not have to be made.
"BURNING" STENCILS
15. Stencils were made by "burning." This
was done on a machine with a double drum. The material to be copied was placed on one drum
and a fresh stencil on the other. The machine then turned and the impressions from the
"original" was transferred (or "burned") into the stencil. This would
include any marks or imperfections, especially dirty keys on the typewriter on which the
"original" was made. In recognizing material from the first decades, this is
important and should be stressed for the court. Electric typewriters were at a premium.
Much material in the early decades were typed on manual typewriters and this can be seen
through uneven keystrokes, dirty keys and even strikeovers. Only if the material was so
faint that it could not be "burned" or if it was a third-generation and it was
starting to blur was it ever retyped. Retyping also required permission because the orders
were to reproduce this material exactly as received. Hence, the "burning" of
stencils and the passing on of imperfections, not unlike photocopying.
16. After "burning," the "original" was then filed
and the stencil used to make the copies. We had several mimeograph drums, each with the
appropriate color, because Scientology material was issued according to "flash
colors." An HCOB (Hubbard Communications Office Bulletin) was red ink on white paper.
An HCOPL (Hubbard Communications Office Policy Letter) was green ink on white paper. An
HCO Ethics Order was black ink on goldenrod paper, etc.
17. Some of this material would be issued to staff.
Some would be made part of instructional course packs that were bought by people taking
that course. Some material was mailed out to general Scientologists or even to the media
and government agencies.
MIMEO FILES AT SAINT HILL MANOR
18. In 1975 and 1977, I spent months at Saint Hill
Manor, in Sussex, England, then the visible headquarters of Scientology. (The actual
"headquarters" was on the ship "Apollo" where Hubbard resided, mainly
sailing the Mediterranean.) Saint Hill then served as the primary distribution point of
Scientology materials and that location will be found at the top of most directives. At
Saint Hill was the "world-wide" mimeo files. It was located in a small building
near the Manor. I spent time working with this unit in 1975 and 1977 and thus became
familiar with how material was received, copied and distributed and learned that it was
basically the same as that in San Francisco. The main difference was their size and that
they also distributed material to other points for re-copying and re-distribution, as well
as to students, staff and public.
19. Thus, I submit, I have ample experience to
adequately identify an "L. Ron Hubbard Original" or, if need be, to provide it
to a document expert who can verify the type of paper and its age, right down to the
original staples that are rusting into the paper.
COMPARING PLAINTIFF'S EXHIBITS TO ORIGINALS
20. As stated, I undertook a search for
"originals" of the exhibits submitted to the court by Plaintiff. I then compared
the "original" to Plaintiff's copy. I also took note when Plaintiff had claimed
that their copy was "identical" or when it was "merely re-typeset" but
otherwise "identical" or when they admitted there was a "difference"
but failed to fully explain. I used a 47-page compilation submitted to the Court by
Plaintiff titled "Originals Filed with Summary Judgment Motion" and is attached
as Exhibit RVY2.
PLAINTIFF'S MISREPRESENTATIONS TO THE COURT
21. Plaintiff has misrepresented to this court the
nature of some of their exhibits. They have presented exhibits with copyright notices that
do not appear on the material when it was originally issued, while telling the court their
exhibit is a "copy" of the original or is "identical." This is not
true.
22. Defendant is submitting examples, in blue folders, but following the
original numbering system of Plaintiff's Exhibits. The blue folders contain, on the left,
a copy of an "original" that was originally issued by Scientology. On the right
side of the folder is a copy of Plaintiff's exhibit. The form of dating shifts because it
shifts in the material. For example:
B-4. HCOPL 2 June 1959 Purchasing Liability of Staff Members. Plaintiff represented to the
court that this was a document that was merely, "Retyped & adopted as Church
policy by CSI" (Exhibit RVY2, Bates page 002763) but this is false because they added
a copyright notice. Defendant submits an "original" that does not have a
copyright notice.
B-5. HCO Policy Letter 4 June 1959, Invoicing and Collection of Money.
Plaintiff told the court this is a copy "as originally published" (Exhibit RVY2,
Bates page 002726) as part of a compilation in 1974, per the attached copyright
certificate. This is false. Defendant submits a copy that was issued prior to 1974 which
has no copyright notice.
B-199. HCO Policy Letter 17 June 70, Technical Degrades. When Plaintiff
submitted a listing to the court as to which of their exhibits were "originals"
or those that were merely "retyped" etc., B-199 was listed (Exhibit RVY2, Bates
page 002747) as HCOPL 17 June 70RB. An "R" after a date means the original was
revised. "RA" means the revision was revised. "RB" is two revisions
from the original issue. Their exhibit is not RB but defendant found a copy or RA, which
has no copyright notice, so this exhibit is at issue.
B-322. HCO Bulletin March 8, 1957, Goal of Indoctrination Course.
Plaintiff told the court this material was merely "retypeset" but is
"otherwise identical." (Exhibit RVY2, Bates page 002747) This is false.
Defendant submits a photocopy of an original which shows a line at the bottom (ISSUED
TOOTHESEHIN [sic] LONDON Mar.18. RDS") that was removed and there is no copyright
notice on the original. But one was added to Plaintiff's copy.
B-323, HCO Bulletin April 8, 1957, Group Auditing. Plaintiff
represented to the court this document is the same as the original. (Exhibit RVY2, Bates
page 002730) This is false. The original has no copyright notice, compared to the version
submitted to the court.
B-326. HCO Bulletin May 3, 1957, Training - What It Is Today - How We
Tell People About It. Defendant claims this material was merely re-typeset but is
identical to the original. (Exhibit RVY2, Bates page 002748) This is flase. Plaintiff
added a copyright notice to the copy submitted to the court. No copyright is on the
original found.
B-332, HCO Bulletin November 13, 1957, Project Clear Check Sheet.
Plaintiff represents to the court their copy is merely re-typeset and is otherwise
identical. (Exhibit RVY2, Bates page 002748) This is false. They added a copyright to
their copy as well as Hubbard's signature. Defendant submits a photocopy of an original
that lacks a copyright notice and Hubbard's name as the author.
B-333. HCO Bulletin #1 of Dec. 3, 1957 Clear Procedure. Plaintiff told
the court their copy is the same as the one "originally published." (Exhibit
RVY2, Bates page 00273). This is false. Note the copyright mark on page 2 of their
exhibit. It is done by a word processor, which was not available in 1957. Meanwhile,
defendant has found a copy from the organization that does not have a copyright notice but
merely typist's initials.
B-336. HCO Bulletin December 18, 1957, Psychosis, Neurosis and
Psychiatrists. Plaintiff has told the court their copy is merely "re-typeset"
and is "otherwise identical." (Exhibit RVY2, Bates page 002748) This is false.
Defendant found and submits a photocopy of an original from 1957, which shows no copyright
notice. Plaintiff added it to their copy.
B-340. HCO Bulletin 26 January AD8 [1958], Future Plans. Plaintiff told
the court this document differed only because of a "Note at end indicating some
issues published w/different date."(Exhibit RVY2, Bates page 002764) What they also
added was a copyright, possibly for the copyright filing, which was done in 1983.
Defendant has found an original and it has no copyright notice.
B-344. HCO Bulletin 2 April 1958, ARC in Comm Course. Plaintiff told
the court this material was merely "re-typeset" but is "otherwise
identical." (Exhibit RVY2, Bates page 002748) This is false. Defendant submits a
photocopy of an original without the copyright notice.
B-350. HCO Bulletin 22 May 1958, Enemies of The PC. Plaintiff told the
court this was merely "re-typeset" but is "otherwise identical."
(Exhibit RVY2, Bates page 002748) This is false. They added a copyright line and it could
not be from 1958 because it is in word processing. Defendant submits a photocopy of an
original and it has no copyright notice.
B-374. HCO Bulletin 20 December 1958, Processing a New Mother.
Plaintiff claims it is merely "re-typeset" and is "otherwise
identical" to the original. (Exhibit RVY2, Bates page 002748) This is false. They
added a copyright line that was submitted with their application in 1983. Defendant
submits a photocopy of an original that has no copyright notice.
B-375. HCO Bulletin 22 December 1958, New HGC Process. Plaintiff claims
it is merely "re-typeset" and is "otherwise identical" to the
original. (Exhibit RVY2, Bates page 002748) This is false. They added a copyright line
that was submitted with their application in 1983. Defendant submits a photocopy of an
original that has no copyright notice.
B-378. HCO Bulletin 28 December 1958, Short Sessioning. Plaintiff
claims it is merely "re-typeset" and is "otherwise identical" to the
original. (Exhibit RVY2, Bates page 002748) This is false. They added a copyright line
that was submitted with their application in 1983. Defendant submits a photocopy of an
original that has no copyright notice.
B-384. HCO Bulletin 3 February 1959, Flattening a Process Plaintiff
claims it is merely "re-typeset" and is "otherwise identical" to the
original. (Exhibit RVY2, Bates page 002749) This is false. They added a copyright line
that was submitted with their application in 1983. Defendant submits a photocopy of an
original that has no copyright notice.
B-388. HCO Bulletin 3 April 1959, HAS Co-Audit and Comm Course
Plaintiff claims it is merely "re-typeset" and is "otherwise
identical" to the original. (Exhibit RVY2, Bates page 002749) This is false. They
added a copyright line that was submitted with their application in 1983. Defendant
submits a photocopy of an original that has no copyright notice.
B-391. HCO Bulletin 23 April 1959, Definitions. Plaintiff claimed
(Exhibit RVY2, Bates page 002764) that the only change was adding "L. Ron Hubbard
Library 1976," which appears in the copyright line. But defendant submits a copy of
an original that has no copyright line.
B-392. HCO Bulletin 3 May 1959, Solution to Solutions. Plaintiff claims
it is merely "re-typeset" and is "otherwise identical" to the
original. (Exhibit RVY2, Bates page 002749) This is false. They added a copyright line
that was submitted with their application in 1983. Defendant submits a photocopy of an
original that has no copyright notice.
B-1292. PAB No. 6, Professional Auditor's Bulletin (1953, ca. End July)
[sic], Case Opening. Plaintiff claims theirs is an exact copy of the original. (Exhibit
RVY2, Bates page 002741) This is false. PABs were not originally issued in this format.
Defendant submits a photocopy of an original that has two additional pages that were
deleted by Plaintiff. Additionally, the photocopy by Defendant that has no copyright
notice.
B-1305. PAB No. 72, Professional Auditor's Bulletin (21 Feb 1956),
Changes for the PABs. Plaintiff claims theirs is an exact copy of the original. (Exhibit
RVY2, Bates page 002741) This is false. PABs were not originally issued in this format.
Defendant submits a photocopy of an original that has no copyright notice. Plaintiff has
added a copyright notice.
B-1347. HCO Bulletin February 24, 1959, Technical Bulletins. Plaintiff
claims it is "identical" to the original. (Exhibit RVY2, Bates page 002767) This
is false. They added a copyright line that was submitted with their application in 1983.
Defendant submits a photocopy of an original that has no copyright notice.
B-1415. PAB No. 13, Professional Auditor's Bulletin (1953, ca.
mid-November) [sic] On Human Behavior. Plaintiff claims theirs is an exact copy of the
original. (Exhibit RVY2, Bates page 002743) This is false. PABs were not originally issued
in this format. Defendant submits a photocopy of an original that has no copyright notice.
B-1417. PAB No. 14, Professional Auditor's Bulletin (1953, ca. Late
November)[sic], On Human Character. Defendant makes the same assertion as in B-1305 and
also calls the court's attention to page 3 of the Defendant's photocopy of the original.
It has a drawing of how the PABs could be preserved, in specially made binders, with
prices. This is not in Plaintiff's purported "exact copy." But Plaintiff did add
a copyright notice, when there is none in the original.
C-4. HCO Policy Letter 13 April 1959, HAS Co-Audit Courses. There is no
copyright notice on Plaintiff's "original" which purports to be covered by the
compilation certificate filed in 1974. Defendant submits a photocopy of the bulletin from
1959, which has no copyright notice, showing it was published far earlier than 1974.
C-36. HCO Bulletin July 31, 1957, Staff Auditors Washington Only.
Plaintiff claims this was re-typeset only and is identical to the original. (Exhibit RVY2,
Bates page 002771) For the first time, Defendant concurs, having found an original and
there is no copyright notice on either. But Plaintiff claims it was first published as
part of a 1976 compilation, according to their copyright filing. Defendant challenges
this, saying it was published, which is how Defendant could find an original from 1957.
C-118. L. Ron Hubbard Executive Directive, LRH ED 102 INT, 20 May 1970,
The Ideal Org. Plaintiff submits a compilation certificate from 1986 but this material was
published in 1970 and Defendant submits a photocopy of an original, with no copyright
notice.
C-148. L. Ron Hubbard Executive Directive, LRH ED 258 INT, 17 January
1975, How You Are Limiting The Size and Income of Your Org. Plaintiff submits a
compilation certificate from 1986 but this material was published in 1975 and Defendant
submits a photocopy of an original, with no copyright notice.
REASSIGNMENT OF RIGHTS
23. In my declaration of July 26, 1998 (Exhibit
RVY1), I noted the oddity that 13 of the 57 exhibits showed that rights had been
reassigned to Mary Sue Hubbard. I have been advised that since that declaration, Plaintiff
has suddenly come forward with needed documentation to authorize the inclusion of this
material. It should be pointed out to the court that Mary Sue Hubbard was jailed by the
federal government for directing a campaign to break into government offices to steal
documents. It was her section that also committed other felonies, all directed to
rewriting or destroying any documentation that could prove to be detrimental to
Scientology. Thus I would immediately suspect her, of all people, in providing any
document to this court, let alone the very organization that ran this campaign to deceive
the government as well as the courts in direct compliance with L. Ron Hubbard's
still-extant policies.
24. Meanwhile, my inspection of the 1900 exhibits
found that more than 300 were reassigned to Mary Sue Hubbard. In fact, and oddly, all 120
in Box 49 are reassigned to her. There are another 101 from Box 48 and 66 from Box 50, as
well as 6 from Box 55. This comes to about 16% of Plaintiff's exhibits.
AUTHORS OTHER THAN HUBBARD
25. As stated in my declaration of July 26, 1998
(Exhibit RVY1), I authored material that was issued under Hubbard's name, even when I was
not hired to do so because it was issued under the aegis of another corporation.
26. It was Hubbard's orders and policies that all
Scientology material be issued under his name and copyrighted to him. The manner in which
this was done can be found in the Plaintiff's exhibits. In some cases, the
other-authorship is blatant. For example, Plaintiff's Exhibit C-199 (Box 58) is First
Edition copy of the book Child Dianetics. On the title page, authorship is not given to
Hubbard. Instead it says, "Written and edited by the staff of The Hubbard Dianetic
Foundation, Inc." Copyright in the book says, "Copyrighted October 1951 by The
Hubbard Dianetic Foundation, Inc." On page 4, it says,
Grateful acknowledgment is hereby made to the
Following researchers and contributors:
William H. Wood...
Idella Stone...
William T. Powers...
Henry Mauerer...
Edward A. Reese...
John Ross...
Julia Lewis...
Waldo T. Boyd...
L. Ron Hubbard
Wichita, Kansas
August, 1951
27. On page 7 is an "Introduction" that is
bylined by Hubbard in which he says the book is "staff collected and staff written
except for this Introduction..."
28. In the back of this exhibit is a copyright
registration dated March 1951, five months earlier than Hubbard's note and seven months
before the copyright in the book, assigning the rights to Hubbard. It says copies were
publicly distributed in December 1950. A renewal of copyright to Hubbard dated May 1978,
is also part of the exhibit.
29. More oddly, also included in Plaintiff's Exhibit
is a sheet from Hubbard's probate file. (He died in 1986.) It says that Child Dianetics is
among his "unpublished works." Yet the book has been on sale in Scientology
organizations for more than 40 years. Further, an inspection of modern editions will show
that the names of the actual authors have been removed, making it appear that Hubbard
wrote the entire book.
30. This is a classic example, and with a book, of
how Hubbard and the Scientology organization have falsely claimed him to be the author of
works published under his name. ADDITIONAL EXAMPLES OF HUBBARD NON-AUTHORSHIP
31. Plaintiff's Exhibit B-85 is HCO Policy Letter of 21 June 1985,
"Distribution Division (Div 6)". The signature line says plainly, "Written
for L. Ron Hubbard by Reg Sharpe." Sharpe's name was later deleted and this is
reflected in the FACTNet copy, with credit being given only to Hubbard.
32. Plaintiff's Exhibit B45 is HCO Policy Letter of
May 25, 1964, "Press Relations." Even in Plaintiff's copy it shows Peter Hemerey
wrote it. Like Sharpe's, Hemerey's name was later deleted, giving credit only to Hubbard,
when seen in the FACTNet copy.
33. The colloquial phrase most used by the
organization to mask that Hubbard was not the author was "assisted by" with the
name of the author or merely the name of the position the author held at the time or even
an entire organization. The point is that authorship is at best questionable. Nor is it
known if it was written for hire or even accepted by Hubbard. With many of these, the
names of the authors disappeared from later reprints of the same issue, leaving only
Hubbard's name as the author. Examples from Plaintiff's own exhibits include:
B-45 by Peter Hemerey
B-85 by Reg Sharpe
B-88 by Watchdog Committee
B-168 by Tony Dunleavy
B-206 by Tracy Holmes
B-247 by Lt. Brian Livingson
B-272 by CSC [Church of Scientology of California]
B-273 by Melanie Murry
B-285 by Peter Warren
B-521 by ACC Instructors
B-616 by Mary Sue Hubbard
B-902 by Personnel Enchancing Chief Flag
B-963 by Training & Services Bureau
B-975 by Flag XII's
B-993 by CS-4
B-1020 by LRH Technical Expeditor
B-1079 by LRH Technical Compilations Project Ops
B-1104 by Maggie Sibersky
B-1127 by Kathy Stewart
B-1137 by Tech Pjt i/c
B-1203 by Mike Eldrige
B-1204 by Snr C/S FLB
B-1274 by Marilyn Routsong
B-1321 by CS-4
B-1326 by CS-8
B-1327 by Arden Hanson
B-1328 by Ed Devine
B-1356 by Kima Jason and Gene Denk, MD
B-1357 by Kima Jason
B-1361 by CS-4
C-27 by WDC [Watchdog Committee] Reserves
C-79 by Commodore's Staff Capt
34. Other exhibits showing other authors include:
By Sherry Anderson
B-239
B-241
B-251
B-252
B-279
B-280
B-281
B-282
B-1346
B-1350
By LRH Technical Research & Compilations
B-259
B-297
B-298
B-304
B-312
B-320
By CMO Mission Issues Revision (2nd)
B-1135
B-1139
B-1144
By Susan Kreiger
B-1134
B-1142
B-1143
B-1145
B-1152
B-1199
B-1370
By Senior C/S INT
B-1192
B-1193
B-1194
B-1195
B-1196
B-1197
B-1123
B-1126
B-1158
B-1184
B-1185
B-1208
C-80
By Research & Technical Compilations Unit
B-1059
B-1062
B-1070
B-1128
B-1138
B-1153
B-1155
B-1156
B-1157
B-1159
B-1160
B-1161
B-1162
B-1163
B-1164
B-1165
B-1166
B-1167
B-1168
B-1169
B-1170
B-1171
B-1172
B-1173
B-1174
B-1175
B-1176
B-1177
B-1178
B-1179
B-1180
35. Some of Plaintiff's Exhibits show others share the copyright, for
example,
B-1255 Copyright shared with Mathison and Hart
B-1256 Copyright shared with Tom Esterbrook
B-1257 Copyright shared with HASI
B-1261 Copyright shared with Korzybski
SUMMARY OF FINDINGS
36. Plaintiff has clearly made a number of fraudulent
claims to this court. They have submitted, as evidence of their allegations, documents
that have been altered and changed from the originals. They cannot claim that such
"originals" were not available. Defendant was able to find some and they
certainly have greater resources, not to mention the archives of the Church of Spiritual
Technology (CST). While CST is not a party to this case, CST holds the copyrights and
licenses them to Plaintiff via Religious Technology Center and is a repository for all
originals. CST has further made representations to the courts and the Internal Revenue
Service that archiving is its sole function and that millions of dollars are spent to find
and save these "originals."
37. Plaintiff has also relied on the enormity of its
exhibits and the arcane system that is used to date and name the material. It is my
conclusion that they assumed that no one, let alone the court, would take the time to wade
through 1900 exhibits and decipher their claims. However even a thorough spot check will
reveal that they have defrauded the court again.
I declare under penalty of perjury under the laws of the United States that the foregoing
is true and correct and that this document was executed this 30th day of November, 1998 at
Santa Ana, California.
(signed) Robert Vaughn Young
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