Title: Table of Contents for Reply to Opposition Motion of RTC to renewed motion to amend judgement---Wollersheim
Author: LMT News <info@lisatrust.net>
Date: Mon, 31 Jan 2000 18:35:29 -0500

Table of Contents

1.	PRELIMINARY NOTE..................................1

2.	SUMMARY OF THE FUNDAMENTAL FALLACIES OF RTC'S
OPPOSITION........................................1

3.	RTC'S FACTUAL ASSERTIONS ARE CONTRARY TO THE
EVIDENCE..........................................4

A.	Among RTC's Most Odious And Incorrect 
Contentions Is That "No Evidence Of Bad 
Faith" Supports The Motion To Amend The 
Judgment.....................................4

	B.	RTC's Own Prior Veneration of Jesse 
		Prince's Expertise Means The Current 
		Effort to Discredit Him Fails................7

	C.	RTC Fails To Overcome The Evidence 
		Demonstrating Its Integral Role In The 
		Management Of CSC's Defense..................10

	D.	The Competent Evidence Continues To 
		Show That, As Puppets Of The Sea Org 
		And Its Leader, David Miscavige, 
		Respondents Were Intimately Involved 
		In Determining CSC's Defense.................12

4.	RTC CANNOT PRECLUDE SCRUTINY OF ITS IMPROPER
EXTRA CORPORATE ACTIVITIES BY HIDING BEHIND A 
VEIL OF "ECCLESIASTICAL" PRIVILEGE................18

	A.	The Doctrine Of Ecclesiastical Abstention 
		Does Not Preclude Imposition Of Alter Ego 
		Liability On Religious Liberty Grounds.......20

B.	There Exist At Least Three Separate Bases 
For Rejecting RTC's Effort To Assert A 
Religious Liberty Deference Defense To 
Trump Alter Ego Liability....................23

1.	Lack Of Standing: Respondents Cannot 
Rely On The Ecclesiastical Defense 
Because They Claim The Sea Org 
Possesses No Ecclesiastical Or 
Corporate Authority.....................23
		2.	Respondents' Fraud And Collusion 
Precludes Them From Invoking The 
Protection, If Any, Offered By The Ecclesiastical Abstention
Doctrine......24

a.	Ascribing The Fraud And Collusion 
To Respondents By Way Of Their 
Sea Org Connection Finds Authority 
In Published Case Law..............28

		3.	The Absence Of An Intra-Sectarian 
Controversy Means There Is No Risk Of 
An Improper Judicial Determination And 
No Basis To Abstain From Deciding This 
Controversy.............................29

5.	CONCLUSION........................................40