"The Defendants have committed deliberate overt acts against the Plaintiff amounting to a course of action designed to, and in fact causing, injury to the Plaintiff by laying false criminal charges against the Plaintiff, harassment against the Plaintiff and his religion, and disseminating false and derogatory information with regard to the Plaintiff's religion.

"The Plaintiff states that the Defendants have deprived him of fundamental freedoms guaranteed by virtue of Sections 2 and 15 of the Canadian Charter of Rights and Freedoms, Section 1 of the Canadian Bill of rights, and those rights that exist in common law.

"The Defendant, Janice 'Kelly' Gariepy, maliciously and without reasonable and probably cause, caused to be filed a false information resulting in the Plaintiff being charged with two counts of sexual assault, two counts of sexual interference, and one court of unlawful confinement. These charges were acted upon by the City of Edmonton Police and the Plaintiff was arrested and detained in jail overnight with bail set at $1,500 This action by the Defendants also caused this incident to be reported in the media, thereby causing irreparable damage to the Plaintiff's reputation, caused his ex-wife to deny access to his children and unduly distressed them, caused problems with his job, and created a threat to his future advancement and employment in his chosen profession, and has distressed several of the Plaintiff's parishioners, interrupting both the Plaintiff's and their free exercise of their religious beliefs."

"It is obvious that the Tabayoyon declaration was created and filed solely to provide material to feed the tabloid press. Fortunately no publications in the United States have printed the allegations contained in the Tabayoyon declaration, although a story did appear in two of the more notorious foreign tabloids.

"All of Tabayoyon's bizarre allegations about the Church and its relationships with its parishioners are false and defamatory. Specifically, Tabayoyon was never the head of Church security as he claims. He was member of a construction crew. He now is part of a small stable of witnesses who have been paid over $100,000 in less than a year while occupying themselves in producing the false statements such as those contained in the Tabayoyon declaration.

"Tabayoyon's claims about weaponry are absolutely and completely false. The Church's facilities are not 'armed to the teeth,' with assault rifles, automatic weapons and explosive devices. Such an assertion is not only totally false, it is dangerous and irresponsible.

"There are absolutely no 'inmates' or 'slave labor' on the property, as is falsely claimed by Tabayoyon. The vast majority of the Church staff work at the property, but commute on a daily basis to their homes in a neighboring city.

"The food served at the Church's facilities is high quality and the Church takes pride in the abilities of its chefs. In fact, our chefs cook the food for the frequent events held here by local community groups and the local high school. When Mr. Cruise (or any guest for that matter) has been to our property, he has eaten the same food as everyone else."

"Critical posts have remained in the 'Church of Scientology' folder, where in the past they would have been deleted without comment. Dissenting views of the 'church' were being addressed, to a point. In some cases dialog has been occurring.

"And then...BAM!!!! Two new folders in the 'Religion & Ethics' boards are deleted in their entirety. This was done without comment. These folders were indeed very much 'on topic' for the area they were placed. 'Scientology Is not a religion' and 'Germany Religious Persecution' came up missing Sunday, August 10th.

"Both folders were enjoying a fair amount of traffic. Discussion was lively and interesting. Critic of the cult and $cieno alike participated. $cienos who swore they ignored critics posts did in a fashion reply to critic's posts in both folders."

"City Manager Mike Roberto said he hopes to increase the tax base, encourage businesses to open in the other parts of downtown and offer residents more incentive to visit downtown. 'I agree with it 100 percent,' Commissioner Karen Seel said. 'While we're glad they (non-profits) are in the downtown area, we've been having problems keeping our downtown vital for years.'

"Under the plan being developed, the city would restrict non-profit organizations to southwest downtown, roughly the area south of Cleveland Street, north of Turner Street and west of Myrtle Avenue. That area already includes government buildings; churches; medical office buildings, including Morton Plant Mease Hospital; Church of Scientology and Calvary Baptist Church buildings; and Pinellas County buildings.

"Scientology spokesman Brian Anderson said the church has no expansion planned beyond a large office building project on Fort Harrison Avenue. The project is in the designated area that would allow tax-exempt buildings. 'We agree with the idea,' he said. 'We're fully willing to back up whatever plans (Roberto) has. We feel like everybody should contribute in some way. A revitalized area is good for everyone.'"

"MoFo will argue for a motion to compel the scienos to produce the following documents, originals and people for deposition:

"May 1982 Family Trust Agreement
May 1982 Advanced Tech License
1993 IRS letter
Originals of all the works at issue in Elrong's own hand
RTC works at issue in the course packs first issued without copyright notice
NOTs indoc materials
all agreements with David Mayo
Notary Logs for transfers

"[O]ther original documents the scienos produced bad copies of: Depositions of Sherman Lenske, Norman Starkey, Ryland Hawkins, and Mary Sue Hubbard.

"The Summary Judgment opposition motion filed today was the result of a massive round-the-clock effort by a whole team of fine, dedicated lawyers at MoFo. The out of pocket costs that MoFo has laid out in RTC & BPI vs Erlich for copying, transcribing, plane tickets, and real expenses have at this point out-paced donations to the defense fund by $42,099.20.

"Donations can be made by mail, make checks payable to:
Morrison & Foerster
425 Market St.
San Francisco, CA 94105
Attn: Carla Oakley - Dennis Erlich Defense Fund"

"My present guess is that the Church has failed to get the German Internic to put the name on hold, as they did with scientologie.org. Scientology.org was hosted at the US internic and the Church got them to place the name on hold, where it remains on hold.

"It should be pointed out, that the Church has not shown us convincing evidence that they own the copyright or trademark to the term SCIENTOLOGIE, and we have been shown evidence that they do not in Germany. The term 'Scientologie' was coined by A. Nordenholz, a German Philosopher in the early 1900's, predating L. Ron Hubbard's use of the term.

"Dear Mr. Smith,

"Our client, Religious Technology Center, recently became aware of the registration of the subject domain name (scientologie.de) by the organization identified as Freie Zone E.V. ((sic)) in Germany. As in the case of SCIENTOLOGIE.ORG, Bernard ((sic)) Luebeck is identified as 'Administrative Contact' and you are identified as 'Technical Contact'.

"As you well know, SCIENTOLOGY and SCIENTOLOGIE are registered trademarks and service marks of our client. Despite our earlier demands that you stop servicing domain names that are identical for these marks, you are presently supporting the subject domain name. The SCIENTOLOGIE.DE domain name is registered through DE-NIC to access your computer servers.

"Your actions in this respect will lead to litigation unless you act immediately to stop supporting the domain name in question."

"Just one day after EarthLink Network Inc. spooked investors by disclosing it may run out of cash by year-end, the Internet service provider said Thursday it likely will have enough money to keep operating. 'We'll probably do a private placement in the $10 million range before the end of the year,' said Garry Betty, EarthLink chief executive. 'We do have enough capital to operate.'

"EarthLink set off a panic Wednesday when it disclosed in a Securities and Exchange Commission filing that 'management does not believe available cash will be sufficient to meet operating expenses through the end of this fiscal year.' Since the report came out, EarthLink's stock has fallen 8.3 percent. EarthLink shares fell 5/8 to 11 Thursday. It fell 3/8 to 11-5/8 on Wednesday."

"Earthlink Network Inc. is not running short on cash, contrary to what it said in its Securities and Exchange Commission filing. The Pasadena, Calif., Internet service provider late Wednesday retracted that filing, issuing a statement saying Earthlink's liquidity 'is within the control of management.'

"The 10-Q stated that Earthlink's cash position -- down to around $6 million according to reports -- would not last them through the year. According to the company's quarterly report, if financing cannot be obtained, it may have to reduce the scope of its operations or its anticipated expansion. But earlier Wednesday, Chief Financial Officer Barry Hall said that the company is in discussion to secure additional funds, although he would not elaborate. That statement was repeated in the retraction. 'We've never had problems raising money. A lot of times people are throwing it at us,' Hall said. 'Personally, I'm very confident. Our stockholders have always been willing to stand behind us and I expect they will in the future.'"

"The Berlin state court has confirmed the conviction (for violation of the data protection law) of the scientologist cop who had forced job applicants to take a 'personality test' and had forwarded the data to the cult. The fine was lowered to DM 9000 (instead of DM 12,000 of the first court, instead of DM 16,000 as out-of-court fine). The cop says he wants to appeal."

"Howie Siegel: Gerry Armstrong was born in Chilliwack, and he is one of the Scientologist's greatest enemies, at least that is how he is perceived by Scientology as a great enemy, he is an ex-Scientologist. Gerry, thank you for coming over from the Mainland.

"Gerry Armstrong: The initial course, which I took, was what's called a Communication Course, and I was a young guy at the time and having trouble with communication, and that's what they sell: you can have the ability to communicate with people; you can get a better job, have a great life. It's a sales pitch in communication, and so that initially was a mere $40, and you sit and look at someone else, and then you learn how to deliver a communication to someone else, and you learn how to acknowledge that communication, and then you have learned in the course of doing this over a period of time the basic what's called the auditor's comm cycle, the communication cycle of Scientology which is basic to all Scientology psychotherapy; auditing is really psychotherapy. You're primed, in this initial course, for then going on to the processing or auditing - psychological processing of Scientology which all Scientologists go through.

"I was recruited into what's called the Sea Organization, which still exists to day, and the recruits are required to sign, of all things, a billion-year contract. So that by the time that I left Vancouver at the beginning of 1971, I had essentially bought the whole package, and I had sold my soul to Scientology and L. Ron Hubbard.

"Howie Siegel: But Gerry, you became involved in Scientology and were so enamored with Scientology because it promised you this vast human potential; and yet, once you joined Hubbard's Sea Organization and came aboard the ship, seemingly you stopped taking the Scientology courses that would enable you to reach that potential. Was there a contradiction there?

"Gerry Armstrong: Which were essentially the saving of mankind from destruction. We called it various things, 'clearing the planet', 'getting in ethics on the planet', but it was essentially a totalitarian goal of complete domination in order to save mankind.

"From the threats of nuclear holocaust. From the threats of the 'Merchants of Chaos'; the enemies of Scientology, those who would bring about the destruction of Mankind. Hubbard viewed that there was some two and a half percent of the population that he called 'Suppressive Persons' who were truly dangerous, and who were the source of all the difficulties of mankind. Those were the enemies that the Sea Org was there to control and 'put ethics in on.'

"Howie Siegel: What happened in 1976 with the Rehabilitation Project Force, and please define that term.

"Gerry Armstrong: The Rehabilitation Project Force is commonly known by its initials, RPF, is really the Scientology or Sea Org prison system. It is a system of punishment and lock up and cheap labour source for the Sea Organization. Prior to my being assigned, and I was assigned by L. Ron Hubbard himself, I was making $17.20 per week.

"I was assigned as I say on Hubbard's order, he said for 'insubordination'; essentially I had told Mary Sue Hubbard's, Mary Sue his wife was in charge of the Guardian's Office, which is another story in Scientology, but I had gotten in a bit of a scrap with Mary Sue Hubbard's secretary and had told her where to get off, and for that I was assigned to the RPF, and spend the next 17 months inside. You, in the RPF you must run everywhere, you are required to wear a black boiler suit, you may not speak to any crew member in the organization unless spoken to, as I said you get one quarter wages."

"I've read some of the educational books written by or associated with L. Ron Hubbard, and to be honest, they do not have any overt promotion of Scientology. They are, for the most part, just based on common sense, which most educators know instinctively. Scientologists, of course, want these texts included in public schools because this validates Hubbard's name and prestige. Opponents opposed this for the same reason. But let's be honest--wouldn't there be an outcry if textbooks written by the pope were being used in public schools, even if they had no overt religious content? There are plenty of excellent texts on the market. Public schools should steer clear of any with such an obvious agenda.

"STEPHEN MILLS
Glendale

"It is understandable that the Los Angeles Unified School District Board of Education should be concerned about the separation of church and state when it comes to the taxpayers supporting a public school with a religious agenda. However, several members of the school board and the media seem to be jumping to an erroneous conclusion that this proposed charter school will be some front for Scientology religious training.

"As a parent of two children who attend a school that uses the study techniques developed by Hubbard, I have not seen or heard of one instance of any parent or student being talked to about Scientology. What I have seen is my kids learning the basics, reading well and loving it and generally doing very well in school. Maybe school board members should look a little closer before they make any final decision.

"JOHN MILLSAP
Tujunga"

"[Kristiane Backer] What is ultra controversial, and links Tom Cruise, Nicole Kidman, John Travolta and Kelly Preston? Well, they are all members of the church of Scientology, one of the most powerful religious organizations in the world. Some have called it a dangerous cult, and there have been calls in Germany for it to be banned. So what's it all about? Well, we went to L.A to find out.

"[Nick Clark] While this might seem like every other star studded party with guests including Kelly Preston, Kirstey Alley, and Isaac Hayes, actually it's not. It is in fact an annual event for celebrity members of the church of Scientology, in Hollywood.

"But despite all the glamour, Scientology is no stranger to controversy. It's been called one of the most dangerous cults in existence. And last month in Germany, Chancellor Kohl won a court ruling, banning Scientologists from his Party. Despite that, it has still attracted Hollywood celebrities from John Travolta and his wife Kelly Preston, to Tom Cruise and Nicole Kidman.

"[Mary Ann Norbom, LA Bureau Chief, The Globe] Scientologists talk about scientology as a religion. And for most of us, it is very hard to consider an organization that was begun by a bad science fiction writer as a religion that should be taken seriously. I think most of us consider it a high profile cult.

"[Kelly Preston] This is the celebrity center, we're in the heart of Hollywood. This is actually where I first came. I did the Purification Rundown. Everything happens here, it's very cool. You can do auditing, you can do courses. It's kind of a wonderful sanctuary within the chaos of Hollywood.

"[Nick Clark] Critics of the church may believe there's a network of Scientology celebrities, who help each other out when it comes to scooping those top roles. But the 'Jerry McGuire' star says it not like that at all.

"[Kelly Preston] I guess I wish it was more like that... no... uhh... I wouldn't say that it ever has helped me that way. Cause even with Tom ... Tom Cruise being a Scientologist, that played no part in me getting the film. I mean, it took them two and a half, three months to cast me.

"[Nick Clark] Even with big names behind them, the Scientologists seem to have a long way to go to convince the public they are a genuine religion. But if you want to rub shoulders with Kelly Preston and John Travolta, the doors to the celebrity center are always open."

"The 18-month campaign is being sold to existing Scientologists as a turning point that could increase membership and bring the controversial church within reach of its ideal: a 'cleared planet,' where Scientology's goals prevail. Skeptics of the campaign say it is more likely an effort by Scientology to counteract some recent bad publicity.

"While church officials would not disclose the cost of the campaign, they do reveal in a brochure that individual Scientologists are being asked to help finance it with donations ranging from $600 to $100,000. The church has mailed thousands of books profiling Scientology founder L. Ron Hubbard to 'people from all cross sections' in Pinellas, said Brian Anderson, a church spokesman in Clearwater, where Scientology has its spiritual 'mecca' and is a major presence downtown.

"Also, a group of Clearwater Scientologists is working door-to-door to distribute a booklet containing Hubbard's moral code, The Way to Happiness. Organizers have delivered about 45,000 copies so far and hope to get it into 126,000 households in Clearwater, Largo and Dunedin."

"Right now, the Sea Org is engaged in the biggest assault on those that seek to suppress man. As the Commanding Officer of a Sea Org organization I can tell you that we will win to the degree that upstat Scientologists like yourself put their shoulder to the wheel and _push_.

"Let me make a few facts real to you. There is currently a $30,000,000 PR campaign the Eli Lilly has launched that is promoting the 'benefits' of Prozac. They are telling America that depression is the result of a chemical imbalance in the brain and that the solution is their wonder-drug. And the upstat people who are looking for answers turn to drugs as the solution.

"I do know that as a Scientologist you do a lot. More than any other people in the country. That is the truth. But the reality is that we must do more, faster. But we are winning. And we will win to the degree that you agree to bear the burden of responsibility for the 5.8 Billion on this world and countless trillions beyond. Join the Sea Org and help make LRH's postulate of a freed civilization stick."

"Their telephone number now directs you to the CoS in Austin. I've mapped it as 'dead' at http://pharos.uwc.edu/~dcleek/cos/oktex.html"

"On Dec. 5, 1995, after spending 17 days at the hotel, longtime Scientologist Lisa McPherson was pronounced dead at a New Port Richey hospital. The cause, according to the medical examiner: a blood clot in her lung that was caused by bed rest and severe dehydration. McPherson, in good physical health when she arrived at the Fort Harrison, was gaunt and covered with bruises when she was carried out, according to the medical examiner.

"For the church, the death of Lisa McPherson is much more than a legal problem. It's a PR problem. Scientologists may regard themselves as worshipers, but they are also customers. And as the church surely knows, it's bad for business when a customer turns up dead. Scientology makes money by charging members thousands of dollars for 'auditing,' a peculiar form of counseling that is supposed to rid people of 'engrams,' or lingering psychic injuries. Some church members eventually 'go clear'; others just go broke.

"McPherson -- a good customer who spent tens of thousands of dollars each year on Scientology services -- lived her last days under strange and sad circumstances. After a minor traffic accident, she apparently became mentally unstable and took off her clothes. She was taken to a hospital but left with fellow Scientologists who promised they would take care of her.

"McPherson's helpers -- actually, her pallbearers -- drove past closer hospitals to take her to one where a Scientologist was on staff. 'On the way to the hospital, Lisa's breathing became labored and then got fainter and fainter just before they arrived,' according to staff member Paul Greenwood. Lisa McPherson was DOA.

"Yes, it's quite a hotel, the Fort Harrison. Librarians are on call and other staffers are always eager to serve you (as they served McPherson) by jamming herbs and mashed bananas into your mouth and pinching your nostrils shut until you swallow. And should the Scientologists figure out that you need medical help, they will carry your limp body to a van and take you to a doctor who knows a corpse when he sees one.

"There's no word on whether this sickening story has affected bookings from other customers at the Fort Harrison, but this much is clear: The Church of Scientology won't be getting any more money from Lisa McPherson."

"Particularly upsetting for Mr. Al Buttnor was the silent, dignified presence on our picket, of Nan Maclean, Toronto Orgs arch foe and victim of over 17 Co$ lawsuits. Nan may not voice criticism or help in anti-Cos court cases apparently due to a 'peace settlement' some time ago, but to the chagrin of Buttnor and senior org members Nan is able to utilise a Picket as an expression of her situation with impunity. Appropriately Nan Maclean carried a sign stating 'Scientology persecutes and harasses critics'.

"Our Picket Staff consisted of six Picketers: Myself, Nan Maclean, Artemis, Cerebrus, Burbank, V-Tech and a remote observer called Othello. Plus the approximately 400 citizens who picked off 250 Xenu flyers and 250 DYIN'ETHICS Pamphlets. (Some wanted both.)

"A lame attempt at sending a Co$ pamphleteer upstream and downstream from us and from the front of the org didn't pan out. By three o'clock the org had abandoned pamphleteers and some familiar faces were appearing to take photos and videotape us.

"They turned up the sound on the exterior speaker so that it was loud enough to drown out normal conversation and attempt to overwhelm my harangue. I approached Mr. Yukayuk (who thrust a tape recorder in my face, a new and standard practice for the day) and I informed him that I considered the overloud playing of the 'Animal' ad sound track to constitute an attempt to interfere with our information Picket and that if this was not addressed shortly then the consequence would be the use of Bull Horns on our next demonstration, as was our right. Mr. Yukayuk seemed to think this statement was a great victory and some sort of threat. He did not have the sound level lowered.

"At about 3:30 I called Ted Mayett in Vegas to give a live Picket Report for IRC. Just then I spotted a MP Cruiser so I finished off with Ted and tried to flag the cops down. At that moment the sound was cut by two thirds, and down to a reasonable level. Then my cell phone rang. It was Ted. He said he had called the org and asked for Buttnor. He told me he had identified himself to Buttnor and mentioned that I had talked to Ted shortly before and I was going to complain to the cops on the sound. Buttnor had hung up on him. And then cut the sound level.

"They hauled out their E meter table in front of the org in the sleight alcove there and tried a little body routing. I walked over and asked the Passerby if he wanted to know just how much the CoS wanted adherents to pay for a cheap voltmeter. At the same I was asking this Yukayuk was speaking into his tape recorder saying I was harassing him. But I was on the sidewalk and so was the mark. Yukayuk pulled out a chair for the mark and told me not to interfere. But the chair was on the sidewalk and so was the mark and so I kept talking.

"The 'Nazi' Sea Orger jumped into my face. He shouted at me that I was interfering with their business. I noticed that Yukayuk had his tape thrust forward to catch every word. I noticed another Sea Orger videotaping the scene. I thought this Sea Orger was going to strike me. Point Blank I tone 40'd right into his face, 'the chair is on the sidewalk and therefore I can talk to this guy and I have the right to speak freely Mister, and if you have a problem with that then you have a *real* problem, because like it or not 'wog' law rules over Scieno law. Especially in this country, get it?'

"He was staring fixedly at me from about three inches away. So I said 'Are you trying to use TRs on me? Ok, let us see just who can stare the longest'. (I am told at this point that every org member in sight was watching this confrontation and so were the Picketers and many curious passersby.) The staring match lasted about a count of five and then the 'Nazi' Sea Orger blinked. 'FLUNK!' I tone 40'd and he actually turned his head away. 'AGAIN!' I snapped in my best parade ground command and he engaged me again. But he only lasted about another 5 seconds and he blinked. 'FLUNK!' I yelled. But before I could challenge him again Yukayuk chips in, 'OK, we have enough on tape, we got what we want, its over lets go in' And the Sea Orger stepped back."

"'Maureen' She was a fascinating combo, saying she was calling from Connecticut. She said that she saw I was commenting on the rude calls and she wasn't going to be rude (the voice had that reassurance of the nurse who tells you the shot won't hurt just before she hits you with that horse needle) but she had been asked to call me. In that now-now voice, she reassured me she wasn't afraid of me and that I shouldn't be afraid of her but I should just calm down. She ended up telling me I sounded PTS III.

"An anonymous message from someone who talks through their nose with a twinge of New England accent, telling me something about committing overts."

"'Jerrod/Gerrod' He calls me and says he used to work in the GO with me. I didn't know no Jerrod/Gerrod. Where, I ask? When? No reply. He just goes into some spiel about my overts, talking as if he either has had too much to drink or didn't put his teeth in his mouth. He mumbles on, in a pattern that is so routine now that it is apparent that the drilling is ghastly! So I tell him that if he is going to lie to me and not reply, no go, and I hang up.

"'Joe' The guy calls up asking for Stacy and tries a local angle, wanting to talk to her. Oh, I say, where do you live? Uhhh....the Alki, he says quickly. (The Alki is a beach up the road.) Well, what's your phone number so she can call you back? Uhhh...never mind! Hangs up.

"Anonymous - This guy left a message telling me to stop committing overts and something else but his TRs were so bad and it was such a bad connection that I didn't even listen to the rest of it.

"'John Goddard' Better but too rote and too arrogant. He obviously had been given a script and HE WAS GOING TO RUN IT! Oh, I could just see his report later how he delivered this scathing attack but you know what it sounded like? Some fast-talking late-night cable show where they are pushing make-money-easy schemes.

"'Allen/Alan' - Now this guy was pretty good. We almost had a comm cycle! But he let me control it too much when we started to talk about the psych drug Vistaril found in LRH's blood stream so he had to blow.

"I don't remember his name but this one was so bad! He comes on and says how I said blah-blah in the SP Times. No, I didn't, I say. Oh, you didn't? Nope. Well, he said, then you said blah-blah. No, I didn't, I said. Oh, you didn't? Nope. Look, I said, why don't you go get the paper and read what parts you want to talk about, okay? Oh, okay, he said. Never heard from him again."