UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

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

FIRST REQUEST FOR ADMISSIONS

DEFINITIONS

"Plaintiff" means Religious Technology Center, Inc. or its agents,
servants, employees, partners, privies or attorneys, or persons acting or
purporting to act under their authority, direction or control, or persons
in active concert or participation with R.T.C.

"Poster" is a person or an organization whether anonymous, pseudonymous, or
under their true name that contribute articles to the Internet Usenet
discussion group called alt.religion.scientology or other Usenet discussion
groups.

"Cancel" refers to a special Usenet posting that attempts to remove a prior
post.

"Forging" means to create all or a portion of a Usenet post that falsely
attribute a statement or a "Cancel" post to another person or organization.

ADMISSIONS

(1) Plaintiff does admit that the investigator known as Eugene Martin
Ingram was in fact an agent, servant, employee, partner, privy or attorney,
or a person acting or purporting to act under the authority, direction or
control, or a person in active concert or participation with the Plaintiff
during a portion or all of 1995.

(2) Plaintiff does admit that Eugene Martin Ingram did obtain photographs
from Rubye K. Ward in Tacoma, WA in May, 1995.

(3) Plaintiff does admit that the poster known as "Vera Wallace" was in
fact an agent, servant, employee, partner, privy or attorney, or a person
acting or purporting to act under the authority, direction or control, or
persons in active concert or participation with the Plaintiff during a
portion or all of 1995.

(4) Plaintiff does admit that the poster known as "Chris Miller" was in
fact an agent, servant, employee, partner, privy or attorney, or a person
acting or purporting to act under the authority, direction or control, or a
person in active concert or participation with the Plaintiff during a
portion of all of 1995.

(5) Plaintiff does admit that the poster known as "Andrew Milne" was in
fact an agent, servant, employee, partner, privy or attorney, or a person
acting or purporting to act under the authority, direction or control, or a
person in active concert or participation with the Plaintiff during a
portion or all of 1995.

(6) Plaintiff does admit that the poster known as "David Talbot" was in
fact an agent, servant, employee, partner, privy or attorney, or a person
acting or purporting to act under the authority, direction or control, or a
person in active concert or participation with the Plaintiff during a
portion or all of 1995.

(7) Plaintiff does admit that the poster known as "Cory Brennan" was in
fact an agent, servant, employee, partner, privy or attorney, or a person
acting or purporting to act under the authority, direction or control, or a
person in active concert or participation with the Plaintiff during a
portion or all of 1995.

(8) Plaintiff does admit that the poster known as "Helena Kobrin" was in
fact an agent, servant, employee, partner, privy or attorney, or a person
acting or purporting to act under the authority, direction or control, or a
person in active concert or participation with the Plaintiff during a
portion or all of 1995.

(9) Plaintiff does admit that the person known as Jeffrey George Quiros was
in fact an agent, servant, employee, partner, privy or attorney, or a
person acting or purporting to act under the authority, direction or
control, or a person in active concert or participation with the Plaintiff
during a portion or all of 1995

(10) Plaintiff does admit that it does not know with a reasonable certainty
whether the so-called NOTs in the Plaintiff's verified complaint against
Grady Ward have been published generally on the Internet or on portions of
it.

(11) Plaintiff does admit that Helena Kobrin did in fact issue a RMGROUP
command to remove the Internet Usenet discussion group called
alt.religion.scientology.

(12) Plaintiff does admits that Netcom may have only recited its general
terms of service rather than "warned Grady Ward of copyright infringement"
as asserted by Helena Kobrin.

(13) Plaintiff does admit that one or more of the attached cancels were
accomplished by the Plaintiff during a portion or all of 1995.

(14) Plaintiff does admit that it or Eugene Martin Ingram did impersonate
Grady Ward to obtain his telephone records during a portion or all of 1995.

(15) Plaintiff does admit that it or Eugene Martin Ingram did telephone the
Austin Code Works on to inquire into the affairs of Grady Ward during a
portion or all of 1995.

(16) Plaintiff does admit working in concert or participation with Church
of Scientology International, Church of Scientology California, Church of
Spiritual Technology, and/or David Miscavige during a portion or all of
1995.

(17) Plaintiff does admit that its controls of the alleged trade secrets
NOTs material has not been as carefully controlled as it is today.

(18) Plaintiff does admit that the HCO on the policy previously known as
"fair game" is still scientology scripture, even if named differently.

(19) Plaintiff does admit that was working in concert and participation
with the Church of Scientology when it signs were made, for example,
calling Grady a "copyright terrorist" on March 9, 1996.

(20) Plaintiff does admit that it did in fact forge the Usenet posting of
the OT3 and other "Advanced Technology" documents that it has attributed to
Grady Ward in 1995.

(21) Plaintiff does admit that it did in fact forge the line "Bomb the
church of scientology today" in a Internet Usenet posting to
alt.religion.scientology in 1995.

April 18, 1996
_______________________________

Grady Ward, In Pro Per

ATTACHMENTS

A selection of Internet Usenet group alt.religion.scientology "cancel"
forgeries.