------------------------------------------------------------------- F.A.C.T.Net, Inc. (Fight Against Coercive Tactics Network, Incorporated) a non-profit computer bulletin board and electronic library 601 16th St. #C-217 Golden, Colorado 80401 USA BBS 303 530-1942 FAX 303 530-2950 Office 303 473-0111 This document is part of an electronic lending library and preservational electronic archive. F.A.C.T.Net does not sell documents, it only lends them according to the terms of your library cardholder agreement with F.A.C.T.Net, Inc. ===================================================================== 1 Daniel Leipold Hagenbaugh & Murphy 2 701 South Parker Street, Suite 8200 Orange, California 92668 3 (714) 835-5406 4 Mark Goldowitz 1611 Telegraph Ave., Suite 1200 5 Oakland, California 94612 (510) 835-0850 6 Special Counsel for Defendant Lawrence Wollersheim 7 8 Lawrence Wollersheim P.O. Box 10910 9 Aspen, Colorado 81612 (303) 650-3336 10 In Pro Per 11 12 13 SUPERIOR COURT OF THE STATE OF CALIFORNIA 14 COUNTY OF LOS ANGELES 15 CHURCH OF SCIENTOLOGY OF No. BC 074815 16 CALIFORNIA, SUPPLEMENTAL EXHIBITS IN 17 Plaintiff, SUPPORT OF DEFENDANT'S RENEWED SPECIAL MOTION TO 18 vs. STRIKE 19 LARRY WOLLERSHEIM, , Date: December 9, 1993 20 Defendant. Time: 9:00 a.m. Dept: 14 21 NO TRIAL DATE 22 SUPPLEMENTAL EXHIBITS: 24 25. Supplemental Declaration of Steven Fishman 25 26. Supplemental Declaration of Mark Goldowitz 27. Stipulation of Evidence, United States v. Hubbard 26 28. Impact Magazine (#13, 1987) and authentication by Garry Scafff 27 28 EXHIBIT 25 1 Daniel Leipold Hagenbaugh & Murphy 2 701 South Parker Street, Suite 8200 Orange, California 92668 3 (714) 835-5406 4 Mark Goldowitz 1611 Telegraph Ave., Suite 1200 5 Oakland, California 94612 (510) 835-0850 6 Special Counsel for Defendant Lawrence Wollersheim 7 8 Lawrence Wollersheim P.O. Box 10910 9 Aspen, Colorado 81612 (303) 650-3336 10 In Pro Per 11 12 13 SUPERIOR COURT OF THE STATE OF CALIFORNIA 14 COUNTY OF LOS ANGELES 15 CHURCH OF SCIENTOLOGY OF ) No. BC 074815 16 CALIFORNIA, ) ) SUPPLEMENTAL DECLARATION OF 17 Plaintiff, ) STEVEN FISHMAN IN SUPPORT OF ) DEFENDANT'S RENEWED SPECIAL 18 vs. ) MOTION TO STRIKE ) 19 LARRY WOLLERSHEIM, ) , ) 20 Defendant. ) Date: December 9, 1993 ) Time: 9:00 a.m. 21 ) Dept: 14 22 NO TRIAL DATE 23 24 25 26 27 28 Supplemental Declaration of Steven Fishman Page i 1 SUPPLEMENTAL DECLARATION OF STEVEN FISHMAN 2 I, Steven Fishman, declare as follows: 3 1. I have personal knowledge of the facts stated herein, 4 unless stated on information and belief, and if called upon to 5 testify to these facts I could and would competently do so. 6 2. I have reviewed the declarations of Kendrick Moxon, 7 Deborah Truax Gillion, and Kenneth Shapiro, which respond to my 8 original declaration in this action (which I signed on November 9 15, 1993). I stand by the truth of everything in my original 10 declaration. Moxon, Truax Gillion, and Shapiro are lying when 11 they say that the statements in my declaration are false. But I 12 expected them to do this: lying to protect Scientology and 13 fellow Scientologists is a common tactic, and Scientologists are 14 trained to do this, in a routine called TR-L, for Training 15 Routine - Lie. 16 3. I wish to correct a typographical error in paragraph 17 14 of my original declaration. The declaration should read in 18 lines 11-14 as follows: "Mr. Leibowitz informed me that in 1985 19 he was ordered to drown the dog by Kendrick 'Rick' Moxon of the › 20 Office of Special Affairs of the Church of Scientology." In my 21 original declaration I inadvertently and inaccurately placed the 22 phrase "in 1985" before, instead of after, the word "that". As 23 I explained in paragraph 9 of my original declaration, my 24 training at ASHO and the "twinning" with Leibowitz occurred in 25 late summer or early fall of 1986. Letters which I wrote during 26 that time period which Scientology attached to its opposition 27 have refreshed my recollection that I flew to Los Angeles on 28 Supplemental Declaration of Steven Fishman Page 1 1 August 27, 1993. 2 4. Scientology claims in its opposition memorandum that 3 my own letters demonstrate that I was not even in Los Angeles at 4 the time I was counselling Leibowitz (Opposition, p. 8, lines 25 4). In fact, the very letters Scientology refers to when it 6 makes this claim (which it attaches as Exhibit J) show that I 7 was telling the truth about this: that I had gone to Los 8 Angeles in late August 1986 to help work on Scientology's 9 "Wollersheim Crusade": its campaign against Lawrence 10 Wollersheim. My August 8, 1986, letter to Kathy Edrich tells 11 her that "I am going to L.A. on August 27th to help with the 12 crusade out there". My August 26, 1986, letter to Kathy Edrich 13 begins with "Tomorrow I leave for L.A. to join the Crusade:" My 14 September 9, 1986, letter to Kathy Edrich tells her "I just got 15 back from L.A. [~] The Crusade was very exciting and 16 memorable." 17 5. My letters during this period which Scientology 18 attaches as Exhibit J also support the statements in my original 19 declaration regarding my having interactions with Deborah Truax 20 and being present at the American Saint Hill Organization during 21 this time. In my August 26, 1986, letter to Margie Vives, I 22 said that I was "going to visit Deborah Truax". My September 9, 23 1986, letter to Kathy Edrich told her that I met "Deborah Truax 24 who I have been writing to quite often" and that "I loved 25 visiting Saint Hill", which referred to the American Saint Hill 26 Organization, where Leibowitz told me about Moxon's order to 27 drown Judge Swearinger's dog. 28 Supplemental Declaration of Steven Fishman Page 2 1 6. Scientology claims that when I was indicted, I tried 2 to blame Scientology for the fraudulent scheme. This is false. 3 I did pay Shane Johnson $40 to read a telephone script which 4 contained threats from a fictional Scientology operative named 5 "Scott". However, I did this specifically upon instructions 6 from Frank Thompson, my Scientology "Ethics Officer", as part of 7 a "reverse sting" which was intended to (and did) get the FBI to 8 stop investigating Scientology for my crimes. I followed 9 Thompson's instructions because I wanted to get back in 10 Scientology's good graces and not be considered a traitor by 11 Scientology. 12 7. Kenneth Shapiro's declaration states that there are no 13 records at ASHO of me, Lenny Leibowitz, or Jay Grossfeld ever 14 being at ASHO. This is not surprising and does not prove 15 anything, because a standard practice used by Scientology to 16 protect itself is the "culling" or "vetting" (removal or 17 destruction) of files to eliminate information which could 18 compromise Scientology to'support a cover story to attack the 19 credibility of "enemies" of Scientology. This is also why 20 Scientology claims it can not find any record of my being a 21 Scientologist before February 1986. 22 8. In support of its claim that I have only been a 23 Scientologist since 1986, Scientology has produced a letter 24 addressed to my uncle, Daniel Lipschutz, dated April 21, 1986, 25 and signed by me. This letter was written by me (but never 26 sent) under instructions from Beverly Ann Flahan, then the 27 Director of Special Affairs of Miami for the Church of 28 Supplemental Declaration of Steven Fishman Page 3 Scientology. She told me to prepare documents indicating that I became a Scientologist on the date when I converted my HASI membership to an IAS membership, which was February 8, 1986. The purpose of these documents was to cover up my involvement with Scientology before February 1986, so Scientology could not be linked to a covert Scientology operation which I participated in during the fall of 1985 against LaVenda van Schaick. My role in the covert operation was to attempt to undermine her ability to sue Scientology. 9. In August 1988, just after my arrest in July 1988 (and release on bail), I was ordered by Ray Jourdain, then the "Body Registrar" of Miami for the Church of Scientology, to turn over to him all documents I had which'in any way implicated Scientology in any criminal acts. On August 4, 1988, I delivered three cartons of documents to him, which included my only copy of evidence of my having paid for auditing during July/August 1986 at ASHO in Los Angeles. 10. In addition to the documents described above in 8, I have attached true copies of additional documents which support › my statements in my original declaration. These include: Exhibit A, a 7/2/86 letter I wrote to Jan Harris, which noted my intention to take the Class VI Saint Hill Special Briefing Course (in par. 1) and noted that I would "not be coming out to Los Angeles to do the Saint Hill Special Briefing Course until mid-August...because I alsol want to be very active in the Battle of L.A." Supplemental Declaration of Steven Fishman Page 4 1 Exhibit B, a 8/14/86 letter I wrote to Barbara Lee, which 2 referred to my "wanting to see Wollersheim very dead" and 3 predicting that "We are going to win the Battle of L.A.". 4 Exhibit C, a 8/18/86 letter I wrote to Margie Vives, 5 stating that I was going out to L.A. to go to take the Sain Hill 6 Special Briefing Course and to go on staff for the Battle of 7 L.A. Crusade (against Wollersheim). 8 Exhibit D, a 9/6/86 letter I wrote to Maggi Scott at AOLA 9 (Scientology's Advanced Organization of Los Angeles), while I 10 was in L.A., which notes that I was taking C Level of Class VI 11 training at Asho Day and that my auditor was Ken Shapiro. 12 Exhibit E, a 10/17/86 letter I wrote to Kathy Edrich, 13 telling her I was back from L.A.'after having completed the 14 Saint Hill' Special Briefing Course, and mentioning Ken Shapiro, 15 my auditor for the course. 16 Exhibit F, a Scientology Sea Organization survey I filled 17 out on 12/12/83, which indicated that I had been in Scientology 18 for 4 years. 19 Exhibit G, a Commodore's Messenger Org Gold Questionnaire I 20 filled out on 1/27/85, which stated that I had experience 21 working in investigations under Fred Hard as Scientology 22 Guardian Office (GO) Agent from 1980 to 1982. 23 Exhibit H, an Enrollment form for the Church of Scientology 24 of Florida, signed by botrh me and Ray Jourdain (on behalf of 25 Scientology) on 3/5/85. 26 Exhibit I, a staff application form I filled out for 27 Scientology's Miami Organization (MM) on 1/3/85, which noted 28 Supplemental Declaration of Steven Fishman Page 5 1 that I have previousluy worked in Scientology's "Guardian's 2 Office as a fully hatted Agent" (p. 2) and lists details of 3 numerous Scientology trainings I received, including trainings 4 from 1979-1981 (p. 3). 5 I declare, under penalty of perjury under the laws of the 6 State of California, that the foregoing is true and correct. 7 Executed this 6th day of December, 1993. 8 Steven Fishman 9 10 11 12 13 14 15 16 18 19 20 21 22 23 24 25 26 27 28 Supplemental Declaration of Steven Fishman Page 6 I tha~ I have previouslu~ worked in Suœsntology's "Guardlan's 2 O~ice as % ~ul!y ~tted Agent" (~. 2) and lis~s details of 3 n~erous Suientolo~ trainings I received, including trainings 4 fr~ 1979-1e81 (p. 3), 5 I declare, under ~nalty of ~rjury under the ~aws of the ~ State of california, that the foregoing is true an~ correct. 7 Executed thil 6th . n 9 10 11 12 13 14 15 16 ú 17 18 19 20 21 22 23 24 25 26 27 28 X Y Z COMPANY 100 ANY STREET, ANYWHERE, USA 00O00 (600) 888-0000 2 JULY 86 Jan Harris Letter Registrar AOLA 1306 North Eierendo Street Los Angeles, California 90027 Dear Jan, I am a NED Level V completion, and I will be ~ing my Class VI Saint Hill Special Briefing Course and hopefully get my Hubbard Senior Scientologlst Gold .Seal as 11 Class Vi Graduate Auditor, if I can fit the interneship into my schedule. i will be at ASHO DAY. Do you know Ken Shapiro? it iS ClifflCult for me to be away for too long at a 'time, because I am also the FP MIAMI, and the representative to the F. IELDS EXEC SEC INT. \.. Further~ i also have a wog Job-as"a Justtce~of The Peace in Fort Laurietrials, WhiCh I use as a dissemination tool,. getting.'people into the , jrt Lauderdale Miterid Miami Or9 by handling out free. personality tests and Way to Happiness Booklets. ! am also an IAS FSM.' The reason that I will not be coming out to los Angeles to do the Saint Hill Special Brieflag Course until mid-August is because I also want to be very active in the Battle of L.A.~ if you krlow my frlencl Freddie Ulan from CCHR, he will tell you how I feel about Jolly West, the psychiatrist who killed an elephant with LSD, and how I am looking forwarcl to workIn9 on the campaign to neutralize him in the battle.- I am certain after he has gotten' a few calls at 3 in the morning, his already weakened ability tO QI;A with his lies and eathera will slightly reduce his wellhess! in any case~ I am looking forward to making cannon fodder out of them, to use one of Li~HJs expressions. I will create an effect in L.A. that the SP bastards will never forget! We must all work to get ethics in on the planet through the expansion of LRH~S tech, pollc7 and ethtci. But we cannot just work on the first dynamic. it takes a world of OTs to do the Job, ! am IooKltlg forward to meeting you at the crusade. Do you know my frienCl Deborah Truax I She works at GOLD. We are in co-,m nearly once a week. I will be staying at the Manor, at CC ORG, and I have asked my I;aison, Claudla Phelps, to arrange my accomodatlons. Perhaps you know her. She is a very upstat dedicated Sea Org member and ts a personal friend of Captain Mark Yager. 300884 Please ask Barbara Lee or one of the senior registrars to be certain to my folders over from Flag. With Love and ARC, /-/'~~ Steve Fishman, FP MIAMI ((~ 201b. GILBERT BOND - 25% COTTON - COCKLe. EXHIBIT A X Y Z COMPANY 100 ANY STREET, ANYWHERE, USA 00000 (600) 888-OOOO 141 AUG 86 Barbara Lee AOLA Re9tstrar AOLA 1306 North Berendo Street Los Angeles, California 90027 Dear Barbara, Think you for C/SIng my survey and queaUonnaire. My Case Level NED Level V completion; I attested to this it FIle in November of laSt year. I am tndeed interested in seeing your bookstore. You are somewhat familiar with my battle pin to be "Public Person of the Planete and have the largest collectloft of LRH data, outside of Ardlives. ...., AM, yes, my LRH cassette Iib~*ary obtllrmble. It hl~ been a realized I have allked Claudla hlp~ ti~/~fti14_/3, I~O_l-ovlerLt~'mlr eccoemdatt.{.~!! ace=urn at Cli~brit7 Cer~tter from .myRA~tlTt"Clas-lUnaiamtssion Account. If you need ~te on thla, egk t:l/udla,\~Sb'e~ ]~lhj~omm with th, FIELDS EXEC SEC INT, II Well B Ronrlr"e:JljlCl~ltl'la,"wh~ w. il~ brtef you, I enume Cl~udl, will be my Illllort officer ilLC~,~ I~iOUl(l. 11h'~'nice rlrgrv,ttd room this tim. Last ttm, I Spent a week WPItif~Ktlqrl to 'Sue McCla~t Ibout the horrid conditions In some of the olcl rooms, Tl~Jrk thi soap, fop example, No soap In the Manor! I am certain ~fter a few heldflhrted to roll-intO the RPF this was dramatically upstattKI. I m looking forwlrd to working with tyro FP INT, and with john Stockeirodt at BRIDGE. After I C0mpbmte the admiA targets, I w~nt to .settle in and atart my CIIII Yl course. I have poltglltld that be able to completg the course, plus g~t my well. I &lso want to tllk to .you about =~curing my Clan Vlll cmjrse and int,rneshtp. but that will be orl the table' el part of mlf httle Plen. Ifi ther Intertnt, I' wouicl like to know If C:budla knows anyone who can talk someone et .Archives or Compilations Into coplfing some missing LRH reel to r,els thllt I Ittll do ~ hive, {Confldentillly~ LRH did over 5,000 lectures, and there are prol~ly 3,000 that t ~tlll do not havet) Puffing III perlmtal pins Illdo, I have to start mobilblng for .the Crusede. I will be rapresenting CCHR MIAMI ~nd FORT LALIDEPr)ALE, ~nd I hart vtry perlonli reasonl on th, whole trld< for wanting te sere 'Wollermh,im yet7 dead- It has to do with my own cm, is well al 5Ps In. general pulling stopt In on my lines We am going te win the BItill.of L,A. I expect your halp In getting the candl~!ight vigil organize41, We are perlonllly going even/one of the baltard $P psltchs and Klulrrels tl~t lee In leagu, wl~ 3800 Gait Ocean Dr!re, 7. artmerit # 1102 Port Lauderdale, Florida 33308-7617 18 August 86 Ms. Margie Vives FLAG LETTER REGISTRAR Church of Sclentolocjy Flag Service Organization Post Office Box # 23751 Tampa, Florida 33623-375! Dear Margie, I received your letter of 7 August 86. Sorry ! blew up at you in my last letter. But at least you know now that the handling of the psych is on Standard Lines under the direction of the DSA MM. ! am glad you had the opportunity to talk to Bey Fiehen about it, 5he told me that you called her because you were concerned due to the fact that my letter to you was so I. 5. Well, we are both big thetans and we can handle little upsets. The ARC break is now patched up, and I hope we are still friends. Actually, i went over your suggestion about the false data stripping with Frank Thompson, the E(:) MM, and he agreed with you that it would be a 'good idea to do that in order to raYjew any false data which the psych could have put.into my head while I was there at his office gatherin9 data to expose him. So I am going to begin doing the false data stripping at Miami Org today. It involves a few 5ec Checks and I have.an appointment with the QUAL SEC to handle that tomorrow. Very well done on your suggestion. I can anticipate blowing off a large ~rnount of case in doing the ethics handling. By 'the way,' ! have always found that the best way to handle the psyche is to bust them and bash their heads in.. So I have volunteered to go on staff for the Battle of L. A. Crusade. I originally planned to go to ASHO DAY just for my Class VI training, but I am going out a week earlier to help organize the Crusade. That will also give me a good opportunity to connect with the terminals at ASHO who will be working with me during the training of the Saint Hill Special Briefing Course. I know that the Crusade will fill me with the extra purpose, I need to handle this sit. And the false data stripping will pr, epare me to do a better job at the Crusade! Scientology is a game wh~re everybody wln~! By the way, I am also going to be working on my'tape cycle with a terminal at GOLD named Deborah Truax. I intend to see her when 1 arrive at L.A. After ! get back, the Ethics Officer Miami wants me to do a goals assessment, and an objectives assessment. I should then be ready to do my CCRD at Flag and make some real progress up the Bridge! W_c l~f patched up ARC. teve 'Fishman 304~89 EXHIBIT 3800 Gait Ocean Drive, Apartment # ~102 Fort Lauderdate, Florida 33308. 7617 17 OCT AD36 Ms. Kathy Edrich FLAG REGISTRAR Church of Seientolo›Jy Flag Service Orcjanization Post Office Box # 23751 Tampa, Florida 33623-3751 Dear Kathy, Well, I am back from LoA., and I did my Class Vl, and I also am now a Hubbard Senior Sctentologist, with a Gold Seal! I am a Saint Hill 5pectal Briefin›:] Course Graduate Auditor now! Do you know Ken Shapiro? He is a great auditor, and tie is really on-source! In answer to your question in the letter you sent, I plan to do my L's at Flag, but as you know, I must first do the CCRD through OT3 package, because I am in the Non-interference Zone, and I have to attest to Clear, other*wise I could be at risk. Unfortunately, your rates are higher than AO~s. But we shall see how my income flows go as I boom my state.' I really have been getting major wins on my training, but I have to concentrate more on my past# which is r ~atlng income. I h"ve really Jet that go while I was in L.A., and my senior at INT is quite ARC broken becaust I have not pushed that hard during the last month. To compound the matter, I still have targets to meet for'the CO RTC to get 1,000 reels by yearns end, so I am leaving foP, Copenhagen! I want to buy every tape that I do not have at NEP.' However, to get the exchange in, .I have agreed to show them how to organize their tape inventory, and put their tape llbrar7 in chronological order, in size place, and to redo their lebelln9 system. I can just imagine what condition It is in! I have heard some very bad reviews of it from the NEP rap at FLAG, But, I can do it,' I wear the mighty hat as e thetan, and I represent LRH in planetary archives, and there is nothing that will stop me: If I can destroy a few more psyche along the way, then that will be gravy, and so be it'. So off I am to Copenhagen, and then, I shall return, and get myself In line and get my FP work up to date, so that I do not get asslgn~ a lower ethics condition from the FIELDS EXEC SEC INT! I have never disappointed her, and I hope that I never will! I am so happy now, that life is so exciting, and full of p; pose and intention' I am going to keep my state in screaming affluence~lifet~ forever! ARC, Steve Fishman~)l~ 303858 EXHIBIT SEA O~GA~:IZA~TION ~dPVEY "In all the. Broad Universe. there is no other hope for man then ourselves. This is a tremendous responsibi!ity. I have borne 15 myMlf with me now." -LRH ~0~ ~, ~ 7~-7 ~ 7 ~ ' ~lsC ~ienCology Courses you ~ve complsted~ List ~lentology auditing you ~ve ~ngth of time in ~ien~logy? ~t are ~our ~o8ls in ~ientolo~y? To FR~e CN~RT 7- ~hat are your ~oals in lits? 8. Is anything prevenCin~ ~u from contributing full time in ScienCology? '9. Have you aver taken 5SD or Angel ~U~? "' ........ 10, Nave you ever. had any. pysch. trea:men$? ú - .. ~; . ,, . ú 11,. Do you ~ve a criminal record? arrive ? , / /-"~ '~', ~' ~ve ,~o .. ~nk you very much. Plea~ return ~his to the ~a 0rg Mls~onaire. '~ ú ' ~ ~0~727 ~H~BIT F C6mmodore's Messenger Org Gold QUESTIONNAIRE_.. Dear Scfentologist"; This questionnaire follows the CMO Gold Briefing Sheet that you should have already received. Please fill this out and rctum it to me-. CMO Gold Recruiter '4751 Fountain Ave. Los Angeles, CA 90029 Tel: (213) 663-6746 NAME ur. Steve Fishman ~)A"~ 27 January !985 ADDRESS 3600 Gait Ocean Dr. C,rTy Ft. Lauderdalee FL7_.IP ('FIDE 33308 TEL: (HOME) (3..05) 566-7917 ..... (WORK) . (305} 739-8500 EXHIBIT 302131 A. Do you have any interest in the folk~ving areas which CMO Gold deals with? Messenger Training D Auditing Investigations / C/Sing Evaluations [ Broad Dissemination Sound [] Film Making B. Do you have any experience in lhnse field.s? If so, which ones? Investigations: I worked under Fred Hare as GO Agent 191t0-19.'2 C. Do you qualify for the Sea-Organization? YES f NO [] If no. why? If yes, have you already signed a Sea-Org contract? When? With whom? D. Do you have any glueslions about CMO Gold or our Bfiefin~ Sheet? would be well qulilifiecl to w6rK in the Office of Special Affairs GOLD as I am a professional ps}rchOuster and I have a very strong goal of attacking our enemies with purpose, E. If you J/fialify, do you want to join CMO Gold either soon or in the future? YES 50 NO [] MAYBE [] (I am currently under contract with INT and the contract expires on this comincl 9 November, But I want to be way through OT3 by that time /am concerned thai moves T/tankyou)ror~7[ing out ttii~ questionnaire/CMO up the Bridge slower than INT'staff on income tines, I have a very special case and I need to get pushed up the Brtdcje as quickly as possible, › Enrollment form CHURCH OF SCIENTOLOGY OF FLORIDA F. smm~Jam*_~t Faroins (PItt Oresre) ' Tob~cc~nl)klBdbyapl~, / L . .__~'j/~u,-~ .. ~:c/~ 4,,-,: . .... ú ú ~ F~ ~m Twa) 305171 ~*~,~ ~ copF ~HIBI~ H STAFF APPLICA. TION ~'ORM NAME: Mr. Steven Fishman ORG: MM DATE: 3 January 1985 Give details when answerinE the following ques~.~on~. Take as long as you need to complete :his form. Be thorough. Fill ~;his fopm out in duplicate. FULL NAME: Mr. Steven Fishman CURRENT ADDRESS: 3800 Cal~ Ocean Dr~ve, Apartment ~ ~102 CITY: Fort Lauderdale, TOWN: Broward County STATE: Florida COUNTRY: United States ZIP: 3330a FHONE: (305J 566-7917 I'L~LIi (X) FEMALE ( ) DATE OF BIRTH:. 26...November 19119 WHERE BORN - TOWN:: New York CIty COUNTRY: United States NATIONALITY: American NEXT OF KIN:.. Sack Fishman ....... ( name RELATION: Father ADDRESS: 8851 Sunrise Lakes Boulevard, Apartment # 116, Sunrise, Florida 3332Z FULL NAME OF MOTMER: Rose LIpehutz Fishman ' (including Maid'in Na~e) "' OCCUPATION: Part Time Legal Secre.tary FULL NAME OF FATHER: Jack Fishman OCCUPATION: Shoe Store Owner /LDDRESS OF PARENTS: Mother's A(~dress is q33q Northwest 9th Avenue, Apartment N PompaM Beach, Florida 3306q EDUCAT!O,N AN.D TRAINING; Sfa=e what education yoG have had including achooling~ unive~siry education, pPofessional or ot)leP tPaining. Give complete de~ails including dates and skills attained (ex~Pa shee=s can be pz~ovided), Please include any deETees, ce~l:ificates you hold. 196q Attende~ the 5ands Point County D.y School for Gifted Children 3966 Graduated from Bayside High School, B.yside, New York 1970 Greduated from the University of Miami, 8achelot of Arts ]971 Attended 1 Year of Law School at the University of Miami 306542 EXHIBIT PRESENT jO6 HEbD: Name 0f firm~ how long have you been employed ~ this firln~ what iS your work schedule. I work ~s a Commodity Broker at Paine Webbar, 556~4 West Oakland Perk i~olJlevard, ~uder~lllt Florida 33313, from Monday through Frld~y, 8:30-~:30. I work on Saturday as a b~kkeeptr for Cypress Shoes, 719 South Cypress ~o~d, Pompan~' ~ea~h, F'lOrt~a" 33~0.. i a~;; perform marttag'e, p,rt time. ~AST ~OBS H~LD: ;nc~de da~e and ~e~ o~ t~me of ma~n h~Zd~ ~&~h he, yo~ e~oyed e~ch, and why you le~t. [ us~ to worg at Dean Witter Reynolds, as a 5t~k and Commodity Broker, at 3800 Inverrary Boulevard~ ~Uderhlll, Florida 333~9. The firm closed down a~ my partner transferred to hine Webbar, so I went with him. But I intend to leave shortly~ bemuse I can't get any blank scripts. They are all generated out of ~w York, There Is no point in my staying there, therefore, as I told Peter tn a K/~ last month. . I have no interested In any of these w~ jobs, although I enjo~ the weddinBs. I have put in a r~Uest to ~me on staff full time via this application once my reslgnation at hl~e Webbar is in for~. I am doing no 9~d to the third dynamic by staying in a job that offers no ussistance to my post as Financial Planner Fort ~uderdal~ rap to FIELDS EXEC SEC INT. I want to transfer to Miami Org, as Financial Planner Miaml rap to FIELDS EXEC SEC INT at this time. SPECIAL SKILLS: Can type - YES (X) NO ( ) If yes, how many wovds pep minute? pon:~ know LanEua~es: English and S~an~sh .. OTHER SKILLS: I have worked In the Guardian'S Office as a.fully hatred Agent, doing 5P enturbulatlon, document rescue, enemy downstatting,. data create, and lots of psychbustlng. ANY CHILD_R.~_N? YES (X) NO ( ) If so, give detailS: NAME: Arialie Haze Fishman SEX:. F AGE: 74~ LIVES WITH Y01l? No Elyeta Skye Fishman F 3« No Put an x by ~he ones joining ~h]s opganiza~ion wi~h _you. E~H{~IT~ PHYSICAL CONDITION: APe you in good physical condition? YES ( X)" NO ( ) If no, give details: Any chronic illness or handling? Y~S ( ) NO ( X ) If yes, give details: All my a!!e.~ies were audited out in 7980. I have no Somatic II|s of any kind. Ape you cuz-ren~ly taking any drugr-?' YES ( ) NO (X) If yes, what dPugs and for how long have you been taking them? .~.NTERESTB AND MOBB!E..S: LiST any inter'ears and hobb.4 Destroying psychiatrists, torturincj our SP enemies, crestlncj income 5ctentology to win and for me to 9o up the Bridge to Total Freedom, dissemlnating for' the Fort Lauderdale Mission, and helping to make it into a Celebrity Center. performin9' weddings, computer ioro9rammlng, What Diane~ics and/ol~ Scientolo~y training have you reoeived? Give complete details including whez'e? When? Name of supePvisors ~ e~c. TRAINING LEVEL 0RG/FRANCHISE COURSE NAME OF SUPER WHEN ATTAINED Fort Lau(~erdale Mission: Ups and.Downs, Financla'l Rescue, ITSE, BSM, Dianetlcs Workshop, Success Through Comm.~anlcat!on, Personal Integrity, HQS, Executive Finance HattlDg, Ho~ tu Get Along with Others, HDAC, }979-198}, Peter Letteregg. Mlami Org: Pr'o TRs, Student Hat, E-Meter, Method One, GO Preps, Management Status Checksheet, Staff Status One, Auditors Drlll..C~..u. rse, K ~F.!ng .~.clentology v'-rkin~ 3&Z, Financial Planning Full Hat, ..Academ[ Level~ 0-3 ~1 am workj.n~ on l.eve| ~ now). On 27 March ~ I paid through NED Level V. which I will (~o at Mtami Or9 too. What auditing h~ve you had? Wha~ Grade or' 0T Level ape you cuPz'ently? LJfe Upset Intensive, LIfe Repair, Happiness ..~undown, Objectives, ARC Stsrightwire All Grades (Communication, Problems, Relief, Freedom and Ability); Confessional O/W Pr'OCe6sj~g .(at Flag), Word Clearing; Student Booster Rundown, et~. 306544 EXHIBIT OTHER LIFLOYMENT CONTRACT: A~'› you currently undep cor.'trac% '~c any D~anetiC~ or $cie~tology 0z.ganization, Franchise, Cfficc or :~jSs~c"? "-- , X) NO ( ) If yes, give de~ail~: am the FP rep to FIELDS EXEC SEC INT~ under a renewable five year contr2ct dat~ 10 November 80r renews on 9 November 85. (Through CO) rOOMeR SCZ~OLOG~ ~NFL0~NgNT: Have you eve~ worked bEEo~e &n a Dian~t~cs o~ Scientology 0~ oz- ~chis~? YgS ( X ), NO ( ) yes> ~ive ~11 details ~cludin~ where? when? who &n cha~ge? ~nd c~cumstonces of yo~=' The ~ntract listed above Is Interned at the Mission of Fort Lauderdale. (It has ~n Supd by Peter ~tterese). DEBTS: Do you have ~ny debts? YES X) NO ( ) If co give ~m~leTe delails including to w]~o~a? amounts? when due? how ycu ~pose to pay ~hem off, YeS, I owe about $ 130,000 d~e to the marnage I h~d to Jaime Lee Nurey~v, However, ~ exact the Natlona} Student Marketing case to come in within several days and I have to pay off all the marital debt~ with this check, as part of my Ethics Handling. However, I signed a pmmlssory note to make up this loss to my ~St ~y cretin9 in~me twice the amount of thls.chgk within 2q months and ~ssign it tO the Wit Chest without accruing b{nefit in auditing, training or product. As a St~k Broker with both Dean' Wittar and Ppine Webbar .1' had to be bonded. A~ you a m~no~ accordjn~ ~.o you are from? YES ( ) NO ( X) If yes, do you have your p~pesi~' cx' Bu~:-dlan's consen~ to join ~his opganizat_on? Ape you subject TO mandatol-y mili%ary sepviae~ YES ( ) WO ( x ) if ye$~ give de%ails on when and 306546 Du you hav~ a drive~'s license? YES (x) NO ( ) !'o? wha% state? Florida A]>y moving violations? YES ( X ) NO ( ) If SO when an~ pieriSe deSCPibe:~ Three speeding tlcket-s since 1981. [ have written them all up .s O/Ws and they are in m7 PC folder', Do you own an automobile? YES (X) NO ( ) 1980 Cadillac Eldorado Bierritz ,, . . . /.~ YOUR SIGNAI~RE:' ~ ~. I 306546 EXHIBIT I-; ~H11~1T 26 1 Daniel Leipold Hagenbaugh & Murphy 2 701 South Parker Street, Suite 8200 Orange, California 92668 3 (714) 835-5406 4 Mark Goldowitz, #96418 1611 Telegraph Ave., Suite 1200 5 Oakland, California 94612 (510) 835-0850 6 Special Counsel for Defendant Lawrence Wollersheim 7 Lawrence Wollersheim 8 P.O. Box 10910 Aspen, Colorado 81612 9 (303) 650-3336 10 In Pro Per 11 12 SUPERIOR COURT OF THE STATE OF CALIFORNIA 13 COUNTY OF LOS ANGELES 14 15 CHURCH OF SCIENTOLOGY OF No. BC 074815 CALIFORNIA, 16 SUPPLEMENTAL DECLARATION OF Plaintiff, MARK GOLDOWITZ IN SUPPORT OF 17 DEFENDANT WOLLERSHEIM'S RENEWED vs. SPECIAL MOTION TO STRIKE 18 LARRY WOLLERSHEIM, 19 Defendant. Date: December 9, 1993 20 Time: 9:00 a.m. 21! Dept: 14 22~ 23 24 25 26 27 28 Sup~o. Declaration of Mark Goldowitz, gollersheimms SpeciaI. Motion to Strike Page { 1 SUPPLEMENTAL DECIj~RATION OF MARK GOLDOWITZ IN SUPPORT OF DEFENDANT 2 WOLLERSHEIM'S RENEWED SPECIAL MOTION TO STRIKE 3 I, Mark Goldowitz, hereby declare: 4 1. I am an attorney, duly admitted to practice in California, 5 and am special counsel for defendant Lawrence Wollersheim in this 6 action. I have personal knowledge of the facts set forth in this 7 declaration. 8 2. The evidence and analysis on the meaning and legislative 9 history of U 425.16(e) which was contained in defendant Wollersheim's 10 supplemental memorandum in support of his renewed special motion to 11 strike resulted from additional research which occurred after the 12 July 1993 hearing on defendant's motion, and it directly addresses 13 the concern expressed by the Court at that hearing as to whether U 14 425.16 applies to this case. 15 I declare, under penalty of perjury under the laws of the State 16 of California, that the foregoing is true and correct. 17 Executed this 6th~o~cemb , 1993. Mark Goldowitz 19 20 21 22 23 24~ 25 26 27 28 Supp, Declaration of Mark Go[dowitz, &~ollersheim's Special Moti~ to Strike ' Page 1 EXHIBIT 27 ~. Mille~ ftnd~ It "~roblbl%m thi~ the lnl~llla a~ ~a%e I)ee~ allrented to Plans ~, ,_. IN'IERNATIONAL ASSOCIATION OF SCIENTOI,OGISTS Sam! ilill Manor ~'a.~t G>~tstead .S~.~c'.~, Engta~d R/[19 4BR ISSUE 13 I,ETTERS From the Editor ......................... 5 The Membership Speak~ .................. 6 ARTICLES CODEOFASCIENTOLOGIST ............ 11 DIANETICS AND SClENTOLOGY ARE NEW by L. Ron Hubbard ....................... 12 TIlE MARKETING OF DIANETICS ....... 14 BOOI($ ARE DISSEMINATION byL. Ron Hubbard ....................... 20 INTERVIEW jetf Hawkins: CeneralMarketfng/nternat/onal ............. 24 NEWS OfficialNcwsSecfion ..................... 28 Re[igi~usFr~domAmuncith~W~ki ......... 41 UpciaLe ................................ 44 MembersinAction .................... .'.. 38 EXCLUSIVE SERIES Ili~toryoikicnt~o~9,0rgamzada~s(Part12) .. 46 REGULAR ITEMS G~cralMembershipRul~s ................. 50 I{on~r RoLl .............................. 30 Patrer~t. heAssocjai'ion .................. 32 ListolPa~rons ........................... 36 ListofSponsors .......................... 48 Benefit~ of Member~hlp ................... Sl DefiniLior, s .............................. 52 C~t~t~ ~ l~*~!~ll~l~Ae~,~.~.~l~-Al~l ~f~'~,l~r~i~U.S,.~, -~,~,~.~I)~.~,~,,O-*,~E~'~t~*.F.~.C-.~,~.~.~. ljt}I ~dt lla,lla~d &n, tri~i~Fi, k~d ~.e c,~l~ ~J b~' Reir~l T~IM~M~t C~,~. . ~,,d~v,S ~ a ts~a~,, ,,sr,,jy:,v~ sek 4,~a~m~l mee,k~a el W at51a~ C~y. kes.N M~ee, ei Sc~a.a~ [ClrlI}~l Ca~e MII~)~IL PmiK'Iiee~.CN~ITm& ~a~alf~ }C~ll ~ J~. H~s~'s~ ~p~: ~d~ ~ .~4~rtJCl~,'T~&~.-f,~s~[~.~ll~b~-'~,~.,'~s~l~ ~n4~tel~&~G,l~'nnin~P~llIlxasas~/~'~'Ca~W-?t4'~,'t ~N~~IMP~I~~, ~M~f~e~~~-r ~m~N~.~e~ ~k~l/~~w~lmm~ ~~~1~ ~l~/i~~ ~~~m~l~ ~?~.~M~~~ ~Llm~ ~l~wt~..tl II .... .::.'. ~.: ~a~ ~[~A~ ~-- kl~. ~ ~ ~m~ R~ R~ II ~ N~IM~N~Z;~,~ i~MM~ ~e~l~- Patrons of the I~l~ '~'~l~." TI~%.1OTt-IY BOWLISS Association ~rtot't~y [a~ ~hc Cl~ur~'h 0~ Sc:en~t~l~6~ and ~t, rks ~n t];c Office of Sp~l Affairs (OS.'X}. ~e is New OTIV and a Hubbar~ Sta,dard D~netic$ Alldi~or and ~xeculivc 5[aLus [. He has been a [a~er for 10 yearn und is now a Patron of There are a num~r Of vei'y A~iation that ~arantees out' the A$~ation. s~cial public individuals wi~o future as &l~'ntOlo~f8. "The A~on vi~ay tleeda at~d d~ the have greatly a~isted the "The ~ Mans ra~ was a [nter~tiona{ A~iatio~t of real exampte of w~t members ixxc~cd sup~ of eve~ ~ientoiogis~ by aki/sg ~n a~ieve. Tlxis x~n was ~t~td~t w~ld~de. contributions ro its "war tnade p~sibte By r~e "I ha~ redsted the chest". This "war chest" is Ass~iation. Chu~h~ of S~entolo~ in t~s~ ~o het~ ~a~ntee the "Xt~ wanted to ~come dcfe,,sc of our religious Ilbe~y in Ainurio aide 197B_ t now lucre oi religious fi-e~om on Patrons ~ that others coukl ~e work full time h~ this fight with this phneL tim it coutd be done. These individuals {~ve ~en "koming a Parro~ is a vo~ the Uni/d Stat~ Office of awarded the 2mma of Patrons theta dc~ision. One d~des to S~iat Airalas. o{ the Inee~tlo~l A~iation take r~nsibility to ~ u~stat. "Fo~lo~ng ~d~tion from of Scientolog~t~ In ~ch issue. One taR~ a position of power a California ~w sch~l in 1977, IMPACT {n~Muc~ the and hu the res~nsibili~ ro my ~f~ Ro~ and 1 movd ro Patrons Io t~ merebeatifiC. hold t~t ~/tion a~ it appti~ O~on Io ~urk on staff at the Their su~ and ~n aa ~e dy~xni~. l~ttm.' pt~ a~ e,~ ~l~m, ~ con~butio~ a~ greatly "It ~ nothing to do with l'at~ [.-- P~ a~r~ial~. m~am~. It is s mount .~'1~1: '1v~ ~a~ PIERRE AND EVA when~ea~s~anO~a~ t'at~qt~a.t~ LEPEVRE Pica and Eva ~›v~ a~ Patrons f~m Pa, Fraa. Pi~e has compk~t N~ 8m D~t~ a~ is a D~i~ Audi~r. Eva is auditing on New OTVII. Pi~e o~ and mamges a ~m~ny whi~ ~tn aM distfibet~ M~ aM s~a~ ior micr~~om~len and x~m~ a + tnf~Gr~ O(fi~. Pierre a~d ~ a~ ~ involv~ in ~ny ~n~ acti~.ities ~ncluding ~ing Fie~ - Di~mimton for ~e A~ia~n a~ S~al ~di~fion a~i~fies. '~ w~a~ ~n ot ~ r~nt pmj~ ~ ~ut ~e "Diam~" ~r in the k Ms~ nee. On ~miug ~oas. Pie~ s~e f~ h~H ~d h~ ~fe. "We ~me Pa~ ~u~ we ~nt~ to fully 5u9~fl the A~fion, ~ it is the l)elph~an 5clmol, A year later, 1 was asked to help on the delen~ ot a ~wsuit brought a~in~t vadou~ S~'~tol~ C~urch~ in Portland, 0regon. "The ~ seeff~ insi~fiant at the ~imc as i~ was no~ conceivable ~bat the Church of 5~enioloff w~ld nol ~ ~iven d~ p~reeliun p~vid~ alI religions by tB~ First Amendm~ ~ the ~nstitution 6f the Unh~ S~t~. Ir,~ead, ~be judge ~n tt~t~se ignor~ d~r First'~ Ame~m~t p~n~p~ a~ ~n the summ~ of 1979 p~id~ o~er a full blo~n her~y trial. "~at judge's e~ were even~lly co~e~ by an ap~l to a senior judge in a higher c~ 51nee then, the figh~ for our rcHgi~s fre~om has of cour~ ~n~nu~ on many diiferent [ron~. Through all of Chic m~ent battles, theAssociation ~ been tP~m a~ an ind~p~ible tor~ d ~ a~ p~cc~n dour ~i~ous faiffi. "1 have r~en~ly ~come a Patron lmus I it tht no ,~ller II~ l~'cl ot cu~ent cuuttlbution one ~n a~ sho~d always do mo~ 1oa~u~ thl spifilual frc~om i p~ed and ex~qnded for all of Man~h~d. L. Ron IIub~ set t~t stal~ ehr~gh~t hls life. ! ~lieve that his i~ an cxampJe of c,~ng ~nd contnhudoa~ Ilxat oil o{ ~ ~n only ho~ to ~uaL ~v~ ~e~ss. For ~, ~in~ a . htron is one ve~ signifiant step along tht r~d. "~gal ~ne/eel gr~L We at OSA intend to ~e t~t a ~blt] En~g t~ ~ of ~r rcJ[~on c~ough toni Hbutlon co the A~iation 'above the call ol duty' {cets ]~› as ~o~e~L" ANDY, TARA, CI,i'~RE AN1) tCRIN t{ITT Andv i~ New OT VII and a C33ss VI auditor a~t} Y~a works in ~les and marlieting for many years. Tan ia also New OT VII and a Cla~ Iv auditor. Tam ~s a S~ntoto~ S~h~l. AMy and Tara are ~h d~u~tc PQ~o~ m~ning that each }mS donated 0v~r ~O,~O to l~e As~iatioa. Erin a~ Chre. their two ~ughtcr& are al~o deN~ Poisons of the Aa~iation. A ndy MM of m~er.~hip: "I1 I hd n~l di~ov~d Sdentolo~ I d~bt tim I w~ld ~ alivv i,, this ~7 t~ay, [ had a chm~,ic illness which according to exerts was 'incurable: As a ~uit of the apptic~li~ of ~nda~ t~hnot~y I ~ou~ b~me ~fter and more able. "My wile al/d ~ a~ both avid ~d~. I ~s ve~ a~ of w~mt hx~/~H~n~ tO ~U~ a~d ~ligiomq in :he ~tand f ~w many i~tic~ in t~ay's ~eW. I was ~wxic t~ il someone d~ ~t do s~ething ~n we w~ld M, a ~i~ sm~ a~ atl tht tht enuiis. "1 didn't kn~ the~e was anythin~ I cou~ do a~t it until the International A$~ial~m sia~ t~. Tht was ú e initial Ihing ttml nleln~ship in this group gave me. 'Fh~e wls solllething t~t [ could doa~ut the thin~ i ~w ~p~ing ar~nd mc a~ a {Hclti~f Of tll~ grip. "~aming a ~ble Patron was n~ j~t a miter af ma~ing do~t~ It was a whole change of levtt of living~ and awarene~ of wllat ~nsfi~$ a ~me. As a mem~r I was d~ng v~ well on a day to day and w~k to w~k ~is. ~t 1 k~w t~t l rally atd do mo~ for Run than 1 ~doing. I r~ a ~int w~re I hd w~ the ~me of ~ing an able. successful ~y and a g~ ~ientolo~st. NOON & PRATT 14 1 UNITED STATES DISTRICT COURT 2 CENTRAL DISTRICT OF CALIFORNIA 3 5 CHURCH OF SCIENTQLQ~Y 7 nOn-profin religious ) 8 organization, 9 Plainziff, ) 10 v3. )No. 93-3843-HL~(TX) 1~ STEVEN FISHMAN and UWE GEERTZ,)VQLUME t2 Defendan;s. 14 1S Continued deposition of GA~Y ~. SCARFF, 16 a~ 22~ North Fi~ueroa S~reet, Suite 1200, 17 Los Ang'eles, California, commencing a~ 18 10:05 A.M., Tuesday, July 27, 1993, !9 before Lee Brenneman, CSR No. 5222. 20 21 22 23 25 PAGES 14 ~65 Lo~ Angeles. California S 213.38H000' 8~722. Fax: 213-3~ NOON & D.~ATT ~ GARRY L. SCARFF, 2 having been first. duly sworn, ~e~_~if~ed 3 follows: 5 MR. BERRY: I understand, Co~]ns~l, ~.ha~- you' 6 wis~ to deal with some preliminary matters before 7 we proceed with ~he deposition. 8 MR. WEINER: Ye~. I:~ order to do a video 9 deposition I think we are going to need a l0 stipulation on the record as to how we do i~ ~rld 1~ so forth. i think we are very close and I wanued 12 ~o confirm some of the details and do ~his on ~he 13 record and also get Mr. Fishman's acquiescence 14 thiS. 1S AS I understand i~, we have agreed 16 that the deposition will be videoSaped. That 17 there will be~a split screen, one camera for the 1~ witness, one camera for examining counsel. and 19 that we will atlso have another camera for any 20 other counsel that's present. 3! We will, in lieu of Mr. ingram being 22 present a= the deposition, we will pay the cost of 23 a regular ~ranscript, and defendant Geer~ and/or ~4 his counsel will pay for the additional cost of 25 expeditin~.[ the transcript. And by expedited we NOON & PRATT ~ aaswer is lack of foundal_ion. 2 BY MR. BERRY: 3 Q~ Mr. Scarff, are you familiar with the 4 signature oE Mr. Bowlee? 5 A. Yes, i am. 6 Q. Does that appear Uo you no be ~e ~ signature of Mr. Bowlee on the ~econd page 8 Exhibit-20? 9 A. -- It looks like his signazure fror~ 10 o~her documents that I have seen his signa[ure on, 11 yes. 12 Q. [xhibiz-21, what is Exhibit-21? 13 A. 21 is a copy of an in~ernal magazine 14 ,]of Scientology{which has an arzic.]e abou~ Tim 15 Bowlee. 16 Q. And Cha~ i8 on -- and does 17 article comme'nce on the z~ird page of nha~ i8 document? 19 A. Yes. 20 Q. And coricludes on the fourth ~age, the 21 ~hira page being ?age 32 and Pa~e 33 being the 22 fourth page7 23 A. That is correct. 24 (Defenda~t's Exhibit-No. 2~ was marked for iden~ificamion and NOON ~ 243 , 1 VIDEO OPERATOR; We will 9u oij[ the record. 2 The date is July 27, 1993. The ~ime is 5:08 3 This is end of Tapc ~.h re~ in ~he cont i. ziuin~ 4 deposition oE Mr. Scar~f. 5 (Defendan~'s Exhibit-No. 97 6 was marked for identi~icanion and is 7 bound separately. ) 8 (TIME NOTED: 5:08 9 I declare under penalty of perjury 10 ~nder ~he laws of ~he S~a~e of California 11 that the foregoing is true and correct. 12 Executed on _~_~% ........ , 13 19_~, an _ , California. 14 INDIVID~k ~KN~DGMENT ]9~e ~ty ~ u~ N ~ ================================================================= If this is a copyrighted work, you are acknowledging by receipt of this document from FACTNet that on the basis of reasonable investigation, you have not been to obtain a copy elsewhere at a fair price, and that you are and will abide by the following copyright warning. WARNING CONCERNING COPYRIGHT RESTRICTIONS: The copyright law of the United States (Title 17, United States Code) governs the making of photo copies or other reproductions of copyrighted material. 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