Article 63405 of alt.religion.scientology: Path: news.cybercom.net!news.netzone.com!news.rtd.com!ddsw1!news.mcs.net!godot.cc.duq.edu!toads.pgh.pa.us!news.pgh.net!newsfeed.pitt.edu!bb3.andrew.cmu.edu!andrew.cmu.edu!wb24+ From: William Bardwell Newsgroups: alt.religion.scientology Subject: CO FACTNet search terms letter Date: Wed, 10 Jan 1996 19:57:24 -0500 Organization: Computer Science Department, Carnegie Mellon, Pittsburgh, PA Lines: 145 Message-ID: <0kx61o600YUrENc29y@andrew.cmu.edu> NNTP-Posting-Host: po8.andrew.cmu.edu [letterhead] DAVID F. ZINGER GEORGE G. MATAVA SHERIDAN ROSS & McINTOSH THOMAS R. MARSH A Professional Corporation CRAIG C. GROSETH ATTORNEYS AND COUNSELORS AT LAW GARY J. CONNELL SEVENTEEN HUNDRED LINCOLN STREET PATENTS SABRINA C STAVISH DENVER, COLORADO 80203-4501 TRADEMARKS SUSAN PRYOR WILLSON ----------- COPYRIGHTS CHRISTOPHER J. KULISH KERMITH F. ROSS JAMES L. JOHNSON TELEPHONE (303) 863-9700 1910 - 1986 LEWIS D. HANSEN FACSIMILE (303) 863-0223 ROBERT R. BRUNELLI OF COUNSEL KENT A. FISCHMANN PHILIP H. SHERIDAN DOUGLAS W. SWARTZ MICHAEL D . McINTOSH JOHN R. POSTHUMUS ----- ROSS E. BREYFOGLE TECHNICAL SPECIALISTS MARK H. SNYDER CAROL TALKINGTON VERSER. Ph.D. BRUCE A. KUGLER DENNIS J. DUPRAY, Pb.D. JEFFREY A. DIVNEY NADINE C. CHIEN, Ph.D. DAVID F. DOCKERY DAVID K. PURKS JOHN C. SCOTT August 24, 1995 Thomas Kelley, Esq. VIA FACSIMILE FAEGRE & BENSON 820-0600 370 17th Street Suite 2500 Denver, CO 80202-4004 Re: Religious Technology Center v. F.A.C.T.Net, Wollersheim and Penny Civil Action No. 95 B 2143 Our File No. 3360-1 Dear Mr. Kelley: We enclose a list of the key words we are using to search the files. Please be advised that any files or documents containing communications between defendants and their counsel have not been reviewed by Church personnel. We propose that copies of these documents be provided to you, as counsel, under a Protective Order, and that they be reviewed solely by counsel for plaintiff and counsel for defendants to determine whether plaintiff wishes to make a claim of infringement and whether defendant wishes to make a claim of privilege. To the extent there are conflicting claims, such issues should be judicially resolved before any such documents or files are released to any of the parties. We are aware that some of the key words will reveal communications between defendants and various attorneys. As stated above, we have taken precautions that such documents not be reviewed by plaintiff's representatives. There are two reasons for including such names. First, substantial evidence already exists that Mr. Wollersheim worked together with various attorneys, including Dan Leipold, Graham Berry, and Ford Greene, to violate plaintiff's trade secrets and copyrights by gratuitously filing them in the court file in the Fishman case, [page 2] Thomas Kelley, Esq. FAEGRE & BENSON August 24, 1995 Page 2 and perhaps other cases. Thus, there is a high likelihood that such communications evidence infringement of plaintiff's intellectual property rights. Second, each name included in the list has had some participation in misuse of or efforts to misuse these confidential, copyrighted materials and communications with those individuals are also likely to evidence infringement of plaintiff's intellectual property rights. We believe the procedure outlined above will protect against improper or premature disclosure of attorney-client communications to plaintiff's representatives. With respect to other documents which reveal potential or actual copyright or trade secret infringement, we will accept your request that we provide you as counsel with copies of same, subject to a Protective Order against release to your client, until and unless otherwise agreed to by the parties or so ordered by the court. We are preparing a proposed Protective Order for your consideration. We must reach an immediate understanding as to whether you will agree to an extension of the TRO. Only by such an agreement can we agree to any delay in the preliminary injunction hearing, since we have been informed that the Court is not available next week. We believe that such an extension should be stipulated to and that all other disputes about the handling of the seized materials should be separately addressed, either by agreement or judicial resolution. Sincerely, SHERIDAN ROSS & McINTOSH [signed] Todd P. Blakely TPB\scr cc: Mr. Warren McShane Helena K. Kobrin, Esq. NET\3360\-1\KELLEY.LTR 8/24/95 [page 3] SEARCH TERMS OT FISHMAN HUBBARD LERMA THETAN LEIBY GPM ERLICH GRADE V KLEMESRUD GRADE VA VEGA POWER ATACK POWER PLUS KIM BAKER GRADE VI BERRY CLEARING COURSE LEIPOLD OT I YOUNG OT II WARD OT III ARMSTRONG OT IV JACOBSON OT V GREENE OT VI WHITFIELD OT VII BEHAR NOTs KISSER NED FOR OTs CAN//CULT AWARENESS NETWORK SOLO NOTs LAWLEY CONFIDENTIAL TERMS: ROGUE AGENT 1. ___________________ CAPRICORN 2. ___________________ RAY RUSS/RRUSS 3. ___________________ DAMON CHETSON 4. ___________________ COATES SCAMIZDAT ABRAMS UNIXER CABERTA NOBODY@REPLAY.COM CARTO COCHRAN SWEARINGER O'REILLY LRA\NET\3360\-1\SEARCH.TRM William Bardwell wbardwel+@[cs.]cmu.edu