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From: William Bardwell
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
OCRed but clean, symbols translated to text...
You need the 1st verified complaint answer (from defts.) to decifer
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,
F.A.C.T.NET, INC., a Colorado corporation; LAWRENCE WOLLERSHEIM, an
individual; and ROBERT PENNY, an individual,
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
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
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.
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.
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10. Defendants have and likely will continue to
misappropriate RTC's valid and subsisting trade secrets.
Dated: November [handwritten]1 , 1995.
SHERIDAN ROSS & McINTOSH, P.C.
By: [signed John Posthumus]
Todd P. Blakely
Rdbert R. Brunelli
John R. Posthumus
1700 Lincoln Street
Denver, Colorado 80203
Telephone: (303) 863-9700
Facsimile: (303) 863-0223
Earle C. Cooley
COOLEY, MANION, MOORE &
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.
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