IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division RELIGIOUS TECHNOLOGY CENTER, Plaintiff, v. Civil Action No. 95-1107-A ARNALDO PAGLIARINI LERMA, Defendant. PLAINTIFF'S EX PARTE MOTION TO STRIKE OR SEAL SPECIFIED PORTIONS OF THE COURT'S OPINION Plaintiff Religious Technology Center ("RTC") hereby moves the Court ex parte to strike two sentences, plus a few words of its October 4, 1 996 opinion (the "Opinion"), or in the alternative, to seal those specified portions pending the outcome of its appeal of the earlier trade secrets ruling by the Court. This motion addresses a total of three sentences--all of which are in a background portion of the Opinion, and thus not integral to the Court's analysis--which purport to discuss or refer to beliefs ofthe Scientology religion. Two of those sentences are at page 2, lines 11-16, beginning with the words "Scientologists believe." The few words are contained in the first sentence of the next paragraph, namely "through the creation of'free zones."' The one additional sentence is at page 7, lines 11-13. The discussion and references contained in those sentences are prejudicial to RTC because (a) they make references to information which is a part of the trade secrets at issue in this case; (b) while they purport to state the religious beliefs of Scientologists, they incorrectly state those beliefs, and irrespective of trade secret status, they are unpublished works the context of which the owner has never permitted to be published. Specifically, RTC requests that the Court delete the language set forth above, which is unnecessary to the Court's decision. Alternatively, the Court should not distribute the decision as currently worded, but rather, pending resolution of RTC's appeal on the trade secret issues, that the Court redact the three sentences referenced above with asterisks or some other notation so that a misrepresentationof RTC's beliefs is not circulated and RTC's appeal of its trade secret claim is not compromised. This motion is based on the attached memorandum of points and authorities submitted herewith. It is filed ex parte in light of the urgency of dealing with the requested relief. Notice is being furnished simultaneously to defendant Arnaido Lerma. Religious Technology Center By counsel J. FREDERICK SINCLAIR, P.C. 910 King Street Alexandria, VA 22304 Signature Sinciair Helena K. Kobrin 7629 Fulton Avenue North Hollywood, CA 9 05 Arnaldo Pagliarini Lerma Pro-Se 6045 N 26th Road, Arlington Virginia 22207