Attention OSA Monitors: NOTICE of Pending Legal Action.

16 Feb 2001

Gregg <elrond1@home.com>

Attention: David Miscavige

Re the Infringing Activities Mr. Peter Ramsay at the direction of Office of Special Affairs of the Criminally Convicted Church of Scientology of Toronto, a wholly owned subsidiary of the Parent Corporation of CSI.

Dear Mr David Miscavige, Head of the Church of Scientology:

RE: Hagglund vs. Ramsay , The Church of Scientology of Toronto
[CoST] & The Church of Scientology International [CSI]
Trademark Infringement
Trademark: Temple of AT'L'AN

My name is William Hagglund and by Canadian and International Treaty I am the legally recognized and rightful owner of the trademark TEMPLE OF AT'L'AN (the.'Trademark').

See: http://strategis.ic.gc.ca/SSG/1051/trdp105117800e.html

I have been using the trademark, Temple of AT'L'AN in association with the operation of a Church, conducting seminars on religion, the providing of religious services and educational materials, and the creation and distribution of audio tapes, printed publications, and jewelry. Temple of At'l'an and Temple of At'l'an & Design have been used, advertised or displayed extensively in Canada and abroad by myself and my religious partners in association with the aforesaid wares and services since January of 1994.

Be advised the preponderance of the evidence available clearly demonstrates the wilful and malicious activities of Mr. Peter Ramsay are at the direction of and solely for the benefit of CSI and CoST {Regina vs the Church of Scientology of Toronto} and are specifically infringing on my Trademark. In particular, the preponderance of the evidence and legal precedent strongly indicates Mr. Ramsay, at the direction of and solely for the benefit of CSI/CoST, to have proceeded to incorporate an Ontario corporation with the name "Temple of At'l'an Inc." on January 24, 2000, notwithstanding the fact that CSI/CoST et al, were aware of the fact that I, William Hagglund was already using this trademark.

This infringing action constitutes a deliberate form of harassment by Mr. Ramsay, amongst others, at the direction of and solely for the benefit of CSI/ CoST. I personally informed Mr. A. Buttnor, Director of Special Affairs of the CoST, by registered letter on September 19, 1997, of my prior use of Temple of At'L'An, amongst others, as a Mark. Shortly thereafter this letter was reproduced in its entirety in a Usenet posting made by myself and recorded by members of the Office of Special Affairs at the direction of David Miscavige.{See RTC vs Grady Ward} Also, as evidence of maliciousness, is the letter sent to me by Mr. Peter Ramsay and dated February 14, 2000 in which it would appear that Mr. Ramsay is mocking or taunting me with respect to the fact that he had incorporated an Ontario company utilizing my exclusive Mark notwithstanding the previous knowledge of Messrs Ramsay and Buttnor, as well as CSI/CoST, that I was already operating under this Mark. Maliciousness is further evidenced by a videotaped exchange between myself and Mr. Ramsay in which he refers to "our shared Temple", by numerous taunting Usenet Postings traceable to Mr. Ramsay and other CSI/CoST members and agents, as well as a further letter from Mr. Ramsay inviting legal action.

Furthermore, the nature of the business associated with the Trademark Infringing Corporation can be shown to be very similar to the designated activities of the actual holder of the Mark: myself. It would appear that Mr. Ramsay is acting as an agent of CSI/CoST and is carrying on business as "Temple of At'l'an" in association with and as an extension of, CSI/CoST operation of an apparent religious enterprise and/or the carrying on of apparent religious practices and teachings or at the least for the purpose of implementing CSI/CoST doctrines regarding the treatment of so called "Suppressive Persons".

Notwithstanding the above, the use of "Temple of At'l'an" is phonetically confusing with my trademark forming the subject matter of my Trademark and is the predominant aspect of the business name deliberately and maliciously infringed upon by Mr. Ramsay at the direction of and solely for the benefit of CSI/CoST. Please be advised that the aforesaid actions amount to an infringement of my Trademark and constitute 'passing off'. Accordingly, the usage of the Trademark by CSI/CoST through their Agent Mr. Peter Ramsay, are likely to be confused by the public as religious teachings etc. originating from myself, not to mention the fact that it will cause damage to myself and the nascent Religious Faith I teach.

By reason of the distinctiveness of the Temple of At'l'an trademarks, and the usage of "Temple of At'l'an" as a business name by CSI/CoST through their Agent Mr. Peter Ramsay, they have infringed, and are deemed to have infringed, my exclusive rights contrary to Sections 19 and 20 of The Trade Marks Act.

["19. Subject to sections 21, 32 and 67, the registration of a trade-mark in respect of any wares or services, unless shown to be invalid, gives to the owner of the trade-mark the exclusive right to the use throughout Canada of the trade-mark in respect of those wares or services.

R.S., 1985, c. T-13, s. 19; 1993, c. 15, s. 60.

Infringement

20. (1) The right of the owner of a registered trade-mark to its exclusive use shall be deemed to be infringed by a person not entitled to its use under this Act who sells, distributes or advertises wares or services in association with a confusing trade-mark or trade-name...."]

Please be advised, that on my behalf, on or about December 1, 2000, I had already instructed my solicitors to demand of CSI/CoST acting agent Mr. Peter Ramsay the following assurances, undertakings and agreements:

"(1) You will provide a Declaration to the Ministry that Temple of At'l'an Inc. is not carrying on business as Temple of At'l'an Inc. vis a vis Articles of Dissolution or Articles of Amendment;

(2) Your advice that your corporation has discontinued the use of the words "temple of At'l'an or any word or words confusingly similar with the trade mark, Temple of At'l'an;

(3) Your corporation's and your personal undertaking not to use or in any way infringe our client's rights in the future. "

My solicitors further informed CoST and CSI acting agent Mr.Ramsay:

"Please be advised that unless we are in receipt of written confirmation from either you or your solicitor within fourteen (14) days of this letter that you will immediately begin completing the above-noted requests. In the event that you do not provide us with such assurances or undertakings in writing, we will seek such further instructions as we may be advised, including the commencement of proceedings in the Federal Court of Canada (Trial Division) for damages for trademark infringement and passing off. Please be advised that not only will we be seeking actual damages but we will be claiming for all legal costs on a solicitor client basis, pre judgement interest, and punitive damages in light of your aforesaid letter to our client.

Please govern yourself accordingly.

Yours very truly,

MARKS & CIRACO
Barristers, Solicitors & Trademark Agents "

Please be advised that as of this date, February 16, 2001 the agent of CoST and CSI, Mr. Peter Ramsay, who resides at 32 Allenwood Crescent North York, Ontario, M2J 2R2 has failed to comply with the assurances, undertakings and agreements demanded above. Indeed CSI/CoST acting agent Mr. Ramsay has further infringed within the body of numerous Usenet postings on and after the first week of January, 2001. Accordingly, at my convenience and instruction, my solicitors may begin legal actions by filing pleadings with the Federal Court of Canada in Toronto.

Given in part: the undeniable deliberate Infringements by CSI/CoST and its acting agent Mr. Ramsay (including infringing URL "cyber squatting"]; the legal precedent in the prior criminal convictions of members and agents of CSI/CoST as well as the "Church of Scientology of Toronto" itself; the GO/OSA internal documents as well as HCOPL and HCOB directives written by L.Ron Hubbard and implemented by the Guardian Office and its successor the Office of Special Affairs; available expert testimony concerning internal policies, objectives and methods of CSI/CoST; the extensively documented CSI/CoSTcampaign of harassment, libel, slander and innuendo directed at myself and my wife and the audio and videotaped participation of convicted Scientology felons Matz and Wheeler in part of said harassment; it is therefore highly unlikely Mr. Ramsay will be held to be acting on his sole discretion and initiative in any rational Court in Ontario.

CSI/CoST will ultimately bear the complete costs of this action and resulting permanent injunctions, which is estimated to be in excess of $70,000. Punitive damages, in light of a previous award, will likely be substantial given the continued deliberate acts of malice of CSI/CoST and its acting agents: Mr. Ramsay and others. I believe it will readily become clear to the court CSI/CoST and its agent Mr. Ramsay, have, in accordance to CSI doctrine, deliberately engaged in a punative course of action designed to financially harass myself, my family and my Faith, by aggressively inviting a costly and burdensome lawsuit in which CSI/CoST and its agent Mr. Ramsay would have no possibility of prevailing.

Govern yourself, Mr. Miscavige, Head of the Church of Scientology, accordingly.

Yours very truly,

William G. Hagglund,
Temple of At'L'An (TM)
2237 Munns Ave West,
Oakville Ontario
Canada
L6H 3M9

"Evil Incompetent Financial Genius and Spiritualist"

Gregg Hagglund SP7
Free Toronto