UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA RELIGIOUS TECHNOLOGY CENTER, a ) No. C 96-20207 RMW EAI California non-profit corporation, ) Plaintiff, ) DEFENDANT'S FIRST INTERROGATORY ) vs. ) ) GRADY WARD, an individual, ) Defendant ) No. C 96-20207 RMW EAI DEFENDANT'S FIRST SET OF INTERROGATORIES TO PLAINTIFF The plaintiff and all organizations or individuals acting in concert or participation with the plaintiff or under the direction of the plaintiff or plaintiff's attorneys, whether directly or in directly, or in concert or participation with the plaintiff are commanded to produce at the home of Grady Ward, 3449 Martha Ct., Arcata, CA 95521-4884 within 30 days, under oath or affirmation: 1. As used herein, the term "document" includes all hand, machine, or electronically written materials or glyphs, graphics, or codes of whatever kind or nature, including, but not limited to, reports, minutes, marginalia, correspondence, registers, tablets, programs, footnotes, videos, videotape, chronicles, checklists, scrolls, printouts, essays, credentials, holographs, novels, poems, dictation, sound or visual recordings, libraries, diplomas, statements, manuscripts, scriptures, inventories, lists, notes, memoranda, telegrams and cables, telexes, telecopies, panafaxes, publications, contracts, agreements, insurance policies, offers, analyses, projections, studies, books, papers, records, calendars, diaries, statements, complaints, filings with any court, tribunal or governmental agency, corporate minutes, partnerships, agreements, ledgers, transcripts, summaries, agendas, bills, invoices, receipts, estimates, evaluations, personnel files, certificates, instructions, manuals, bulletins, advertisements, periodicals, accounting records, checks, check stubs, check registers, canceled checks, money orders, negotiable instruments, sound recordings, films, photographs, mechanical or electronic recordings, tapes, transcriptions, blueprints, computer programs and data, data processing cards, computer disks, CD-ROMS, computer tapes, software, e-mail, news postings, computer directory listings, access time records, instruction manuals, and computer media of any description, whether in draft or otherwise, whether encrypted or not, or any binary form including but not limited to, copies and non-identical copies, images, electronic mirrors, impressions, carbons, backups, or archives, whether "on site" or "off site." 2. The term "relating" or "related" mean, in addition to their usual and customary meanings, referring to, addressing, concerning, discussing, opining, pertaining to, reflecting, speculating, evidencing, stating, showing, analyzing, contending, regarding, summarizing, recording, or theorizing. 3. The term "Scamizdat" refers to any of several anonymous postings to the Internet which purportedly contains any material claimed as the intellectual property of the plaintiff. 4. The term "RTC" or "plaintiff" includes the responding party, Religious Technology Corporation, its agents, servants, employees and attorneys and all persons in active concert or participation with it. 5. The term "Usenet group" refers to a discussion group which can be accessed via the Internet. 6. The term "cancels" refers to any posting to the the Usenet group control or alt.religion.scientology, or any cross-posting containing either of those Usenet groups whose purpose, intent, or design, or content was in any way related to protecting any intellectual property right whether actual or claimed by RTC or any organization, group, or individuals working on concert or participation with RTC. DOCUMENTS AND THINGS TO BE PRODUCED (1) All documents relating to "cancels" of materials that RTC claims as its Advanced Technology property, whether published or unpublished, whether copyright or trade secret or public domain whether made anonymously or pseudonymously or under the true name by the plaintiff within the time period of January 1, 1995 through March 23, 1996. (2) Any documents relating to proof or the theory that the Exhibit C. NOTs have been continuously maintained under such control since their copyright registration and/or would support a theory that they remain protectable trade secrets. (3) All documents relating to any actions has the plaintiff brought to restrain other parties from disseminating the plaintiff verified complaint Exhibit A, B and C materials. Include the caption of all such actions indicating the jurisdiction and docket number of the case, the parties to the action, copies of each complaint and answer, and state the disposition of each such case. Include any actions brought in jurisdictions outside the United States (4) Any document relating to knowledge plaintiff has of any such restraining actions brought by any other parties. (5) All documents relating to income from each of the plaintiff verified complaint Exhibit A, B and C materials has plaintiff accrued in the period January 1, 1995 through March 23, 1996. (6) All documents relating to the copyrights or trade secrets alleged to be owned, licensed, lent, or any other manner controlled by plaintiff relating to plaintiff verified complaint Exhibit A, B and C materials this lawsuit. (7) All documents relating to SCAMIZDAT. (8) All documents relating to the defendant Grasdy Ward and any other poster to the Usenet group alt.religion.scientology. (9) All documents relating to alt.religion.scientology within the time period January 1, 1995 through March 23, 1996. (10) All documents relating to Internet anonymous remailers within the time period January 1, 1995 through March 23, 1996. (11) All documents relating to proof or theories that Exhibit C. NOTs have "not previously been posted to the Internet". (12) All documents relating to Eugene Martin Ingram or Ingram Investigations relating to Grady Ward and member of Grady Ward's family, or any other poster to the Usenet group alt.religion.scientology. (13) All documents relating to Jeffrey George Quiros of the Church of Scientology, San Francisco relating to Grady Ward and member of Grady Ward's family, or any other poster to the Usenet group alt.religion.scientology. (14) All documents relating to any investigative services that plaintiff directly or indirectly directs or receives information from about Grady Ward or any poster on the newsgroup alt.religion.scientology within the period of time January 1, 1995 through March 23, 1996. (15) Any documents relating to account numbers, holding institutions, amount and kinds of insurance, property, or bank accounts does plaintiff own or control that might be available to pay any judgment under this lawsuit. Disclose the existence, description, nature, custody, condition, and location of any books, documents, or other tangible things and the identity and location of persons having knowledge of this affairs, whether domestic or abroad. (16) All documents relating to any computer equipment, terminals, access points, service providers, or any other method that plaintiff could post to the Internet Usenet group alt.religion.scientology or Usenet group control during the period of time from January 1, 1995 through March 23, 1996. (17) A documents relating to witnesses or experts that plaintiff may use in any aspect of this lawsuit. (18) With respect to all persons whom you intend to call as expert witnesses at trial: a. identify each expert witness b. specify the subject matter on which each expert is expected to testify. c. specify the substance of the facts, opinions, and theories to which the expert is expected to testify and a summary of the grounds for each fact, opinion, and theory. (19) Identify any person or organization consulted in the preparation of the answers or objections to this interrogatory. Include the name, address, and telephone number, and position of every person so consulted. (20) All documents relating damages that the plaintiff claims occurred because of the actions of the defendant. Under FRCivP Rule 26a(1) and/or Rule 26(e) disclose all information or supplementary information as therein required even if not explicitly included in this formal interrogatory. Further, plaintiff is reminded to answer all non-objectionable portions of each interrogatory even if objections are raised to any other portion of the interrogatory. April 11, 1996 ___________________________________ Grady Ward, In Pro Per