Title: Table of Contents for Reply to Opposition Motion of CSI to renewed motion to amend judgement---Wollersheim
Author: LMT News <info@lisatrust.net>
Date: Mon, 31 Jan 2000 18:34:39 -0500

Table of Contents
1.	PRELIMINARY NOTE...................................1
2.	CSI'S BULKY SUBMISSION CONTAINS DUBIOUS ASSERTIONS 
THAT ARE EXPOSED AS FOLLY BY ASTONISHING NEW 
EVIDENCE SHOWING HOW CLOSELY CSI GUIDED CSC'S
DEFENSE............................................4

	A.	Respondents' Suggestions That Jesse 
Prince And Stacy Young Lack Credibility 
Contradict Scientology's Own Prior 
Recognition Of Their Knowledge And 
Expertise.....................................7

B.	Respondents' Ineffectual Attempt To 
Repudiate Vicki Aznaran's Prior Sworn 
Testimony Ignores The Substantial 
Historical Base That Corroborates It..........8

C.	Respondents' Self-Serving Declarations 
Do Not Vitiate The Weight Of Evidence
Showing Scientology's Corporate Re-
Organization Was Calculated Only To 
Frustrate The Government And Judgment 
Creditors Like Lawrence Wollersheim..........11

3.	CSI MISCONSTRUES THE LAW AND OFFERS UNAVAILING 
ARGUMENTS AS A RESULT.............................14

A.	The Case On Which CSI Relies In Suggesting Plaintiff's Alter Ego
Theory Is "Unsound" 
Is Wholly Distinguishable....................14

B.	CSI's Footnoted Reference To Due Process 
Concerns Presents No Viable Argument For 
Conducting This Proceeding In A Bifurcated 
Fashion......................................16

C.	Respondents' Collateral Arguments Invoking
The Doctrine Of Laches Fail Because They 
Are Judicially Estopped And Because The 
Court Had No Jurisdiction To Amend The 
Judgment While It Was On Appeal..............19

		1.	As Late as December 1994, CSI's 
Lawyer Argued There Was No Judgment.....19
		
2.	Judicial Estoppel Prevents Litigants 
From "Playing Fast and Loose with the 
Courts."................................21

		3.	The Court Lacked Jurisdiction To 
			Amend The Judgment Until All Appeals 
			Were Final..............................23

4.	CONCLUSION........................................27