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From: William Bardwell <wbardwel+@CMU.EDU>
Newsgroups: alt.religion.scientology
Subject: CO FACTNet plaintiffs answer to defendants counterclaim
Date: Thu, 11 Jan 1996 01:54:49 -0500
Organization: Computer Science Department, Carnegie Mellon, Pittsburgh, PA
Lines: 134
Message-ID: <gkx=EtG00YUr4SN2c_@andrew.cmu.edu>
NNTP-Posting-Host: andrew.cmu.edu

OCRed but clean, symbols translated to text...
You need the 1st verified complaint answer (from defts.) to decifer
this...
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						[stamped]FILED
						U.S. DISTRICT COURT
						DISTRICT OF COLORADO
						'95 Nov-1 P4:19
						JAMES R. MANESPEAKER CLERK
						BY [handwritten]B?? DEP. CLK
		IN THE UNITED STATES DISTRICT COURT
		FOR THE DISTRICT OF COLORADO
			
Civil Action No. 95-K-2143 7

RELIGIOUS TECHNOLOGY CENTER, a California non-profit orporation;
and BRIDGE PUBLICATIONS, INC., a California non-profit corporation,

	Plaintiffs,

	v.

F.A.C.T.NET, INC., a Colorado corporation; LAWRENCE WOLLERSHEIM, an
individual; and ROBERT PENNY, an individual,

	Defendants.

	RELIGIOUS TECHNOLOGY CENTER'S REPLY TO
	DEFENDANTS' COUNTERCLAIM FOR DECLARATORY JUDGMENT

	For its Reply to defendants F.A.C.T.NET, INC. ("FACTNET"),
Lawrence Wollersheim ("Wollersheim") and Robert Penny's ("Penny")
Counterclaim for Declaratory Judgment, plaintiff Religious
Technology Center ("RTC") alleges as follows:

	1. RTC denies the allegations set forth in the first
sentence of paragraph 1 of defendants' Counterclaim.  RTC is
without sufficient knowledge or information to form a belief as to
the truth or accuracy of the allegations set forth in the second
sentence of the first paragraph of defendants' Counterclaim, and
hereby denies same.

	2. RTC admits the allegations set forth in paragraph 2 of
defendants' Counterclaim.

[page 2]
	3. As set forth in paragraph 3 of defendants'
Counterclaim, RTC admits that it owns trade secrets and
that defendants have misappropriated and have threatened to
continue misappropriating those trade secrets in violation
of CUTSA.  All other allegations set forth in paragraph 3 of
defendants' Counterclaim, not specifically admitted, are
hereby denied.

	4. As to the allegations set forth in the first
sentence of paragraph 4 of defendants' Counterclaim
relating to defendants' wishes, RTC is without knowledge or
information sufficient to form a belief as to the truth or
accuracy of the allegations and therefore denies same.  All
other allegations set forth in paragraph 4 of defendants'
Counterclaim are denied.  In particular, RTC states that
defendants Wollersheim and Penny, as former Scientologists,
are fully aware of what information RTC claims is a trade
secret, and as a result of their knowledge, defendant
FACTNET is also fully cognizant of RTC's trade secrets.

			AFFIRMATIVE DEFENSES

	5. Defendants' Counterclaim fails to state a claim
upon which relief can be granted.

	6. Defendants' Counterclaim is barred, in whole or in
part, by the doctrine of unclean hands.

	7. Defendants' Counterclaim is barred, in whole or in
part, by estoppel.

	8. Defendants' Counterclaim is barred, in whole or in
part, by contract.

9. RTC owns valid and subsisting trade secrets.

				- 2 -
[page 3]
10. Defendants have and likely will continue to
misappropriate RTC's valid and subsisting trade secrets.

Dated: November [handwritten]1 , 1995.

					Respectfully submitted,
					SHERIDAN ROSS & McINTOSH, P.C.

					By: [signed John Posthumus]
					Todd P. Blakely
					Rdbert R. Brunelli
					John R. Posthumus
					1700 Lincoln Street
					Suite 3500
					Denver, Colorado 80203
					Telephone: (303) 863-9700
					Facsimile: (303) 863-0223

					Earle C. Cooley
					COOLEY, MANION, MOORE &
					JONES, P.C.
					21 Custom House Street
					Boston, MA 02110
					Telephone: (617) 737-3100
					Facsimile: (617) 737-3114

					Jeffrey A. Chase
					Ann B. Frick, Esq.
					Jacobs Chase Frick
					Kleinkopf & Kelley
					1050 17th Street, Suite 1500
					Denver, Colorado 80265
					Telephone: (303) 685-4800
					Facsimile: (303) 685-4869

					Helena K. Kobrin
					7629 Fulton Avenue
					North Hollywood, CA 91605
					Telephone: (213) 960-1933
					Facsimile: (213) 960-3508

					ATTORNEYS FOR PLAINTIFFS
					RELIGIOUS TECHNOLOGY CENTER and
					BRIDGE PUBLICATIONS, INC.

				- 3 -

---
William Bardwell
wbardwel+@[cs.]cmu.edu

ÿ