UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA RELIGIOUS TECHNOLOGY CENTER, a ) Case No. C-96-20271RMW California non-profit corporation, ) Plaintiff, ) AFFIDAVIT IN ) SUPPORT OF ) REPLY TO PLAINTIFF'S ) OPPOSITION TO MOTION TO ) RECUSE (WAS "DISMISS") v. ) ) H. KEITH HENSON, an individual, ) Defendant. ) ) ____________________________________ 1. Defendant incorporates defendant's filing of April 12 as if April 12 filing were fully set forth herein. 2. Defendant places objection on the record to Plaintiff's failure to notify re related cases. Had defendant known the location and time of Grady Ward deposition in a case Plaintiff related, defendant would have attended as pro se for defendant's related case. 3. Defendant calls the Court's and council's attention to an error in plaintiff's motion to relate. The motion has an incorrect party named in case C-96-20291 RMW. 4. Defendant further calls the Court's and council's attention to the postmark time and date of the notification by mail of related cases sent by plaintiff. 5. Defendant requests that Grady Ward be notified as to time and place of defendant's deposition. Mr. Ward's attendance at that deposition (if Mr. Ward chooses to attend) will not be considered to be the person of defendant's choice whom the court has permitted to attend defendant's deposition. 6. Defendant seeks the Court's indulgence to call the Court's attention to the words RTC President Warren McShane spoke before witnesses, including plaintiff's council Thomas Hogan after April 12 hearing. Defendant spoke at April 12 hearing of deposing person defendant believes to be the *real* head of RTC, David Miscavage. Mr. McShane approached defendant at the point defendant and plaintiff's council Thomas Hogan had agreed upon a time for defendant's deposition stating: "You're dreaming if you think you will depose Miscavage!" Defendant immediately had Mr. McShane confirm these words before witnesses, including a journalist and a law student. Affidavits will be obtained from these persons if the Court finds these affidavits are required to establish this event on the record. 7. Defendant's ex-wife reports contact with plaintiff's investigative operatives who were attempting to obtain "dirt" on defendant. An affidavit will be obtained from defendant's ex-wife if the court finds an affidavit is required to establish this event on the record. 8. Plaintiff's family of organizations is well known for attacking defendants outside the legal system, a policy of unknown name, formerly known as "fair game." That this policy exists or has existed in the past is a fact well established in a long list of court cases. Defendant would quote from court documents the copyrighted policy letters of plaintiff on plaintiff's "fair game" policy within this affidavit if defendant were not concerned about possible violations of the preliminary injunction issued against defendant by this Court. Defendant feels the need to request a protective order from this Court that plaintiff, and those acting in concert with plaintiff, particularly Gene M. Ingram and those under his control, refrain from harassing defendant, organizations profit and non-profit in which defendant is an officer or board member, defendant's friends, defendant's neighbors, defendant's clients, defendant's family members, including but not limited to parents, children minor and adult, and former wife, and from engaging in character assassination of defendant during the pendency of this case. Defendant is confused by the bewildering array of legal forms and does not wish to make legal errors. Thus defendant seeks the indulgence of the Court as to the name of the appropriate form recognized by this Court for this purpose which defendant should file to obtain such a protective order. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Signed this 16th day of April, 1996 at San Jose, California. H. Keith Henson