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 UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

RELIGIOUS
TECHNOLOGY
CENTER, a
California non-profit
corporation,
        Plaintiff,
        vs.
GRADY WARD, an
individual,
        Defendant
)
)
)
No. C-96 20207 RMW
(EAI)
FIRST MOTION TO
COMPEL PLAINTIFF

Date:
Time:
Courtroom:  Hon.
Edward A. Infante

After failing to reach compromise with the adverse counsel as
required by L.R.37-1(b), the defendant hereby asks the Court to compel the
plaintiff to answer defendant's interrogatories number 1, 2, and 3, served
upon the plaintiff on August 13, 1996.

The Interrogatories are as follows:

1.  List each and all whereabouts and safekeeping arrangement of each and
all components of the "Advanced Technology" materials since the
earliest of the inception, dissemination or reduction to tangible from of
such material to the present.

2.  Identify all persons and organizations who have had or could have had
access to any of the "Advanced Technology" materials -- whether
authorized or not -- since the earliest of the inception, dissemination, or
reduction to tangible form of such material to the present.  This
includes, but is not limited to, custodians and guards of such materials
in addition to parishioner and anyone else who could have perceived the
contents of the materials.
3.   Identify each and every confidentiality agreement executed by any
person or organization who has had or could have had access to any of
the "Advanced Technology."

The reason why the defendant needs the information for all these
propounded Interrogatories is similar: the plaintiff has alleged that the
defendant has misappropriated the plaintiff's alleged trade secrets and the
defendant wishes to prove that the plaintiff has not taken reasonable
precautions under the circumstances to protect those alleged trade secrets.
        Unlike other enterprises deriving value from their alleged trade
secrets, the plaintiff and Churches of Scientology do not simply create an
independant product or service from their alleged trade secret method or

process, they actually deliver the trade secret method or process itself to the
final consumer that they label a "parishioner."
        Compare this practice to, say, a manufacturer such as Intel
Corporation.  Intel also maintains trade secrets in it methods and processes
of its wafer fabrication and other tooling for semiconductors.  However
Intel does not sell the tooling, methods, or processes themselves, only the
products such as microprocessor chips that are derived from such trade
secret processes.
        Since each and every customer (or "parishioner") of the plaintiff
obtains the "service" that is the essence of the Hubbard exorcism of
murdered space aliens ("body thetans" or "clusters") described the public
portion of the OTIII Advanced Technology, the burden of the plaintiff in
maintaining adequate and reasonable safeguards on confidentiality of the
alleged trade secrets is highly enhanced in scope.  Rather than ensuring the
security of a small group of technicians and a relatively limited physical
plant in the case of the Intel Corporation, the plaintiff and related
Scientology Enterprises must ensure that each and every "parishioner" or
customer sign confidentiality agreements an that each and every licensee of
the Advanced Technology material has itself taken such reasonable and
necessary precautions to reasonably maintain the confidentiality and
secrecy of the material from its very beginning.
        And, of course, trade secrets can fall with the weakest link. If at any
time since their inception and dissemination the plaintiff or predecessor
organizations failed to take such reasonable or adequate precautions to
enforce the confidentiality of their alleged trade secret Advanced
Technology and thereby the material was lawfully generally known, then
the plaintiff loses any such trade secret protection according to California
law.
        It very well may be burdensome to provide the defendant with this
crucial information that the chain of confidentiality and reasonable efforts
to maintain secrecy under the circumstances has been met by the plaintiff
for works that compose the "Advanced Technology."  But it is a burden
that the plaintiff has brought on upon itself by the very nature of it
delivering the essence of  the alleged trade secrets to each and every
customer or parishioner through its large number of licensee churches of
scientology.
        By not providing this information to the defendant, he will not
fairly be able to show that the material claimed as trade secret is in fact not
entitled to such protection and will be thus irrevocably prejudiced in his in
forma pauperis pro per defense against a wealthy and litigious cult.

                                                        Respectfully
submitted,


Dated: October 11, 1996
        ______________________________
                                                        Grady Ward, in pro per


1
FIRST MOTION TO COMPEL PLAINTIFF
No. C 96-20207