New court filings

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: _________________________