UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA RELIGIOUS TECHNOLOGY CENTER, a ) California non-profit corporation, ) Plaintiff, ) ) vs. ) ) No. C-96 20207 RMW EAI GRADY WARD, an individual, ) Defendant ) ) ) ) OPPOSITION TO PLAINTIFF'S EX PARTE MOTION TO SEAL EXHIBIT A TO DEFENDANT'S MOTION TO DISSOLVE PRELIMINARY INJUNCTION (1) The entirety of the NOTs have been posted by the internet by parties unknown on May 6, 8, and 9th, but not by defendant Grady Ward nor parties working in concert or participation with him. (2) Plaintiff admits on page 3 line 1 that defendant did not violate his preliminary injunction by posting the title of the NOTs, as asserted in the threatening letter by Counsel Kobrin of May 11, 1996 faxed to this court two days ago. (3) Section 3426.1 of the California Uniform Trade Secrets Acts only applies to trade secrets that have not been vitiated by general publication, as ruled by this court and by Judge Brinkema's court. (4) Since the plaintiff does not allege these titles reveal plaintiff's trade secrets (page 3 line 5), it argues inconsistently that it needs to seal them in order to prevent revealing their trade secrets during this litigation. (5) It will certainly hurt the defendant by sealing these records because then the plaintiff will insist that internet WEB sites that have been documenting the on-going litigation will be harassed into removing these materials, as I have been harassed by Counsel Kobrin by being told falsely that she was going to file a motion for contempt and that I had violated my preliminary injunction. (6) I take the orders of this court very seriously as I do keeping an open and communicative atmosphere among all interested parties in these litigations. Permitting the plaintiff further means of intimidating a free and open exchange of ideas on the internet does not promote justice. For these reasons I pray that the court DENY plaintiff's ex parte request to seal the exhibit A. Respectfully submitted, May 17, 1996 5:01 pm. Grady Ward Grady Ward, in pro per