Archive Message - 1995
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From braintree!news.sprintlink.net!cs.utexas.edu!uwm.edu!lll-winken.llnl.gov!enews.sgi.com!sgigate.sgi.com!swrinde!gatech!newsfeed.pitt.edu!bb3.andrew.cmu.edu!andrew.cmu.edu!wb24+ Thu Jan 18 10:20:24 1996 Path: braintree!news.sprintlink.net!cs.utexas.edu!uwm.edu!lll-winken.llnl.gov!enews.sgi.com!sgigate.sgi.com!swrinde!gatech!newsfeed.pitt.edu!bb3.andrew.cmu.edu!andrew.cmu.edu!wb24+ 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... --- [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

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