New court filings by Factnet against Scientolology on Scientology's copyright fraud.
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,
		Plaintiffs,
	v.
F.A.C.T.NET, INC., a Colorado corporation; LAWRENCE WOLLERSHEIM, an

individual; and ROBERT PENNY, an individual,
		Defendants.
_________________________________________________________________
DECLARATION OF LAWRENCE D. WOLLERSHEIM

_________________________________________________________________


		I, Lawrence D. Wollersheim, declare as follows:

		1.	I am a director and officer of Defendant F.A.C.T.Net herein and I

am also one of the individual defendants herein.  This Declaration is

submitted in support of Defendants' Motions (a) to Strike the Renewed

Summary Judgment Motion of Bridge Publications, Inc. and/or for a F. R.

Civ. P. Rule 56(f) continuance for further discovery; and (b) to amend

the scheduling order herein to permit further discovery and to compel

the deposition of David Miscavige.  I have personal knowledge of the

matters set forth herein and, if called upon to do so, could and would,

competently testify thereto under oath.

		2.	Factnet, Bob Penny , Arnie Lerma, and myself were involved with

Scientology in Factnet case settlement discussions for a period of about

7 weeks from May to early July, 1997.  During this period both parties

agreed that all Factnet litigation actions would be on hold until the

settlement discussions were concluded.  This agreement to put all

Factnet litigation actions on hold was made to set up a good faith

environment to hopefully resolve the litigation through these settlement

discussions.  The settlement discussions were not successful.  I

published a report of why we refused Scientology's bizarre settlement

package on the Internet.  (A copy of that publication is included with

this declaration as exhibit A.)

		3.	On January 20, 1986 Earl Cooley, an attorney for Scientology,

prepared and filed a Certificate of Religious Belief which precluded a

autopsy being performed on L. Ron Hubbard by the coroner.  I am familiar

with almost all of the religious beliefs of Scientology and nowhere in

the millions of words of written Scientology, or statements by L. Ron

Hubbard, is it stated that autopsies could not be performed on

Scientology members or that members must be cremated.  Based on my 27

years experience with Scientology, I believe that this last minute

Certificate of Religious Belief was concocted to prevent the California

coroner from doing a full and proper autopsy on L. Ron Hubbard and the

circumstances surrounding his death.  I am well qualified as an expert

on Scientology practices to make the preceding statement.  My

credentials are as follows:

		(a)	I was a member of the organization of shell corporations commonly

referred to as "Scientology" from 1969 through approximately late 1979.

		(b)	As a result of my membership in Scientology, I obtained personal

knowledge of what Scientology purported to be,what it really was, how it

functioned and how it was structured.

		(c)	Over the past fourteen (14) years, in addition to being a litigant

myself, I have assisted my attorneys and other parties and counsel

involved with litigation with Scientology in Canada, England, South

Africa, Germany, Spain, Denmark, Greece, and Israel.

		(d)	As a result of my over twenty-five (25) years "relationship" with

Scientology, I have personal knowledge and expertise on a broad range of

Scientology's ongoing litigation tactics, human rights abuses, and

operating policies.  Specific areas that I have detailed knowledge of

relating to Scientology are crimes, harmful psychological practices like

the RPF or Rehabilitation Project Force, dangerous trance inducing

auditing practices, sham corporate structures, financial fraud,

financial practices, the false religious mantle of Scientology, covert

operations, the care and treatment of Scientology staff and their

children, the operation of the Guardians Office as it was once known,

and as it is now known, the Office of Special Affairs, and how

Scientology materials and procedures can induce psychotic, suicidal and

criminal tendencies in its victims.

		(e)	Over the past fourteen (14) years, I have participated in the

compilation of perhaps the largest computerized data base collection of

information on Scientology (6 gigabytes) and other cults.  I also

possess one of the largest non-computerized collections of professional

studies, litigation histories and other related documents from legal

cases involving Scientology and other cults.

		(f)	I have been mentored in this work over the last 16 years by

University of California at Berkeley, Professor Emeritus, Dr. Margaret Singer .  Dr. Singer is recognized as the world's leading authority on

cults.

		(g)	I maintain a global contact network of over 1,100 former

Scientology members from whom I regularly receive related or updated

materials.

		(h)	I am also one of the two directors of a global non-profit victim's

rights organization called "FACTNet."  FACTNet provides information to,

and assists, victims of mind control and cult abuse.  FACTNet has

information on hundreds of cult organizations world-wide, including

Scientology.

		(i)	While in Scientology, I worked for Scientology as a staff member,

a recruiter for the "Sea Organization" or "Sea Org" ["Sea Org" is that

para-military part of Scientology that runs the entire organization.  I

held numerous "Sea Org" positions, including, among other posts,

recruiter, and as a "nanny" for "Sea Org" children.  I also worked as a

"sales registrar" where I was responsible for the receipt of millions of

dollars for Scientology from both new and then current members.  I

additionally held such "mid-level" positions such as the "Public

Executive Secretary" ("PES") and the "Director of Promotion".  As PES, I

was in charge of "non-intelligence" related public relations at the

Scientology "Celebrity Center" in Hollywood, California.  As Director of

Promotion, I worked on all aspects of creating and distributing

Scientology promotional materials including "Celebrity" magazine.  As

Director of Promotion, I worked on budgets and financial planning using

the Scientology expenditure control system.

		(j)	Regrettably, I also have first hand knowledge of the secret dark

side of Scientology, having been through, among many other unpleasant

things as a result of my membership in Scientology, the Rehabilitation

Project Force" or "RPF".  As a part of RPF I was imprisoned at a

debilitating concentration/work camp because I did not follow orders

unquestioningly.  While on the RPF, on board a Scientology ship, I was

held as a virtual prisoner.

		(k)	I also have extensive personal knowledge of most of Scientology

services, having received those services.  I advanced through the ranks

of Scientology to some of its highest secret levels.
 	FURTHER DECLARANT SAYETH NAUGHT
		I declare under penalty of perjury under the laws of the United States

of America, the State of California and the State of Colorado that the

foregoing is true and correct.
		Executed in Denver, Colorado, this _____ day of August, 1997.




	______________________________

							LAWRENCE A. WOLLERSHEIM




STATE OF COLORADO				)

							)  SS.

							)
		Subscribe and sworn to before me this ____ day of August, 1997,

Lawrence A. Wollersheim.
		WITNESS my hand and official seal.


		My commission expires:  _________________________