Uwe W. Geertz, Ph.D.


Telephone (305) 434-5643
Associates in Psychology and Psychiatry
18000 Southwest 57th Street
Fort Lauderdale, Florida 33331


Mr. Matthew Berger
Lewis, D'Amato, Brisbois & Bisgaard
221 North Figueroa Street, Suite 1200
Los Angeles, California 90012


Dear Mr. Berger,

With regard to the hearing that you will be attending on my 
behalf on Monday 31, 1994 at 10:00 A.M., I wanted to state my 
position on the "trade secret" issue, so that you can communicate 
it to the Court.

	(1)	In Religious Technology Center v. Scott, 869 F.2d 
1306, 1309-10 (9th Cir. 1989) and in Bridge Publications Inc. 
v. Vien, 827 F.Supp. 629 (S.D. Cal. 1993), both of the plaintiffs 
were for profit corporations.  This is entirely distinct from 
the case at bar, wherein the Church of Scientology International 
claims to be a Church (and a non-profit entity).

		Since the finding of the Court in Religious Technology 
Center v. Scott held that "upper level materials might be 
protectable as trade secrets if Scientology could prove it 
obtained actual economic advantage over competitors", we now 
invite the Court to determine who the actual competitors of 
the Church of Scientology International are.  Are their competitors 
other churches, such as the Roman Catholic Church, the United 
Methodist Church, or the Beth Israel Congregation?  If so, 
how would these upper level materials be either protectable 
as trade secrets or even needing of protection?  The test 
fails quickly if one views other churches as "competitors."

		However, if the Church's competitors are other cults, 
does the test now apply?  Not even here, because each cult 
has its own dogma and other cults would never accept the "upper 
level materials" of Scientology as their own "sacred scriptures."

		So therefore, who are the competitors of the Church 
of Scientology International wherein they require protection 
from the Court for "trade secrets?"

		The Church has always acted on the false assumption 
that psychologists and psychiatrists are the "competitors" 
of Scientology.  They have attacked the psychological professionals 
with a Mafia-like vengeance.  This is due to the fact that 
psychologists and psychiatrists treat their patients by skilled 
professionals, whereupon Scientology auditors are unskilled 
and unschooled in psychology or psychiatry.  Even if the Court 
were to grant that psychologists and psychiatrists were in 
some way competitive in that they are therapeutic (as Dianetic 
auditors claim to be), the upper level materials are not relevant 
to the practice of the traditional psychological sciences 
which require licensing prior to practice.

		Consequently, there are no viable "competitors" to whom 
the Church of Scientology can refer which require protection 
from the Court.

	(2)	The disputed documents or upper level materials are 
indeed relevant to my defense and the defense of my patient/co-defendant 
Mr. Fishman, in that the dogma contained in these materials 
were part of an extended process used to misdirect and manipulate 
my patient into committing crimes of stock fraud, as well as 
contemplating carrying out Church orders to murder me and to 
commit suicide.

		The disputed documents are further relevant in that 
it is the very issue of "trade secrets" which has been raised 
by the Church of Scientology International which cuts to the 
heart of the matter ~~~~ whether the Church of Scientology 
International is a church at all, but, as we have argued throughout 
this case, is a business which must rely on the protection 
of the court for such matters as "trade secrets."

	(3)	It is my position that the "trade secret" argument 
is a ruse.  What the Church fears the most is quite clear.  
Once the "upper levels materials" are widely known to the public, 
the empty, vacuous mystery of these poorly fashioned science 
fiction writings and behavior modification techniques will 
serve to educate Scientologists into making informed, cognitive 
decisions based on their ability to think, analyze and hold 
this bizarre dogma up to scrutiny.  The Church does not fear 
competition from competitors, but instead fears the stupidity 
of its own doctrine, and the influence such writings would 
have on its followers if they were to have proper access to 
the data before the Church had a chance to influence them to 
a point where they can no longer think, analyze or make cognitive 
decisions.

	(4)	Briefly stated in conclusion, the need for public 
disclosure outweighs Scientology's need for privacy when the 
only basis for privacy is predicated upon the need of Scientology 
management to protect themselves from the disclosure of these 
materials to their own parishioners.  Scientology has failed 
to make a showing in any way as to (a) who their "competitors" 
are that they need protection from and (b) why they need such 
protection, and moreover (c) how the upper level materials 
fall into the category of a "trade secret", and finally (d) 
how a Church could be entitled to trade secret protection.

Please contact me when your brief is prepared so that I can 
be assured that all of the arguments contained here are adopted 
and incorporated therein.

Very Truly Yours,


Uwe W. Geertz, Ph.D.


cc:	Graham Berry, Esq.
	Lawrence Wollersheim, F.A.C.T.
	A.P.A. Legal Defense Fund