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
                                     )     EXPEDITED MOTION FOR FURTHER
                                     )     DEPOSITION OF DEFENDANT GRADY
                                     )     WARD


The defendant opposes further expedited deposition because the plaintiff
has indulged in extremely abusive behavior in their first expedited
deposition by ignoring this court's admonition on March 29, 1996 to
plaintiff counsel Hogan to treat the defendant pro per professionally, as
well as untruthfully representing to Magistrate Judge Infante that I had
"sprung" my objection to a second full day of deposition on the plaintiff
on April 9, 1996.

The enclosed audio tape shows me confirming the nine hour limited as agreed
to by counsel at the beginning of the first day of deposition on April 8th.
Counsel Hogan's voice is clear in his acknowledgment of my confirmation.
This exchange took place just ten minutes before the court reporter began
recording the first day's testimony.


The court will also hear Hogan calling me a "liar" when I protested his
disregard of your 6 hour limit and our agreement between counsels to limit
the deposition to nine hours. However, as the tape proves Counsel Hogan
deliberately uttered a falsehood to the court of Magistrate Infante as well
as contemptuously ignoring this court's advice. The plaintiff wishes to
excuse itself from its falsehood and breach of the peace committed by
Attorney Hogan on April 9th by asking the court to compare his shouting
"liar" at me from a distance of two feet to my stylized printed vulgarity
from a thousand miles away.

The counsel's behavior creates the strong inference that the plaintiff
intends to conduct further abusive discovery in spite of this court's
admonishments.

Plaintiff has also not made it clear why the defendant's deposition must
continue to be expedited. Whatever harm can befall the plaintiff's
intellectual property has apparently already occurred. In fact this harm
seriously questions plaintiff's assertions that in fact that material ever
enjoyed trade secret status.

I deny being connected in any way with the "NOTs" postings in May, 1996, or
at any other time.

The flurry of ex parte and expedited motions on the part of the plaintiff
has made it difficult for the defendant to articulate his counterclaims --
which I have moved this court to amend -- and to defend myself from the
seemingly continuous onslaught of declarations based upon unauthenticated
hearsay and other non-evidence that the plaintiff has produced to support
their allegations. The schedule of accelerated discovery has severely
prejudiced me since I have no paralegals to do research for me nor do I
have a clear concept of legal procedure to guide my pleadings. The
plaintiff has challenged my counterclaim and in fact virtually all of my
motions. To continue to permit them intrusive discovery while I try to
learn legal principles, learn how to read case law, and understand pleading
format is patently unfair.

Further, the plaintiff has other means of conducting discovery such as
deposition by written question and interrogatories that would not have the
same potential for the abuse suffered by the defendant in the first
expedited deposition.

Moreover, Attorney Kobrin abusively communicated with me barely a week ago
in which she promised to file a Motion for Contempt because she alleged I
violated my Preliminary Injunction. Where is that Motion? No -- her
barratry was simply meant to oppress an individual whose sole offense was
to personally and repeatedly insult her in front of thousands of people on
the internet.

How much more abuse and untruths will this court accept from the plaintiff?
This pattern of abuse must not be rewarded.

Finally, the character of the plaintiff is best represented in their own
word's as they state in RTC's reply for further accelerated deposition that
"Defendant is attempting to take advantage of his pro se status to block
plaintiff's discovery".

I have never heard of a more cynical attempt by a plaintiff consisting of
two prestigious New York law firms along with a San Jose and a Los Angeles
law firm to trample the rights of an individual who lacks the money and
training to competently defend himself from an organization of proven
discovery abuse in this circuit.

And even the Expedited Motion that this brief is in opposition to was filed
in bad faith as the plaintiff did not comply with Local Rule 7-10(b).
Contrary to its assertion, plaintiff did not inform the defendant that it
was filing this Expedited Motion nor did it offer to meet and confer as
required. While Magistrate Judge Infante ruled that the plaintiff must seek
an order for further expedited deposition from this court, I did not learn
that the plaintiff had actually filed an expedited motion until the
defendant received mail on Saturday, May 25, 1996.

Plaintiff's Motion for further expedited deposition should be DENIED.

I declare under the penalty of perjury that the facts above are true and
correct to the best of my knowledge.

May 25, 1996

____________________________

Grady Ward, in pro per