UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA RELIGIOUS TECHNOLOGY CENTER, a ) California non-profit corporation, ) Plaintiff, ) ) vs. ) ) No. C 96-20207 EAI RMW GRADY WARD, an individual, ) Defendant ) DEFENDANT'S MOTION ) UNDER RULE 11(b) FRCivP ) ) Under Rule11(b) of FRCivP, I demand that plaintiff correct Page 2 lines 15 through 22 of your MOTION FOR FURTHER EXPEDITED DISCOVERY to show that, in fact, Counsel Hogan was well aware as the deposition of Grady Ward began on April 8, 1996 that the defendant confirmed to Hogan that the total time agreed to his deposition was a total of nine hours, divided over two days in any manner desired by plaintiff. Plaintiff's contention to Judge Infante on April 9 that Defendant Ward "sprung" this objection and that plaintiff's stated belief as as the second days testimony was about to be taken that the defendant was in agreement with any arrangement more than a maximum of nine hours was simply a fabrication of Hogan. ___________________________ May 9, 1996 Grady Ward, in pro per ___________________________ Grady Ward, in pro per