Judge Brinkema
US District Court
200 South Washington Street
Alexandria VA  22314

October 25, 1995


re: Religious Technology Center v. Arnaldo Pagliarini Lerma, et al,
case # 95-1107-A

Judge Brinkema,

   I was subpoenad in the above mentioned case at 6:10pm on October
15, 1995.  In it I was ordered to appear at 10am on October 20, 1995. 
With this short notice I had a hard time arranging for representation
and compiling the requested documentation.
   As for representation, I felt I had an attorney lined up on
Tuesday, but then on Wednesday afternoon I learned he was called out
of town.  On Thursday I was speaking to another attorney, but it
turned out he could not appear at the prescribed time.
   As for the order to produce documents; I filed a Rule 45 objection
based on my opinion that the request was overly broad and would have
required me to rent a pickup truck in order to comply.  I therefore
brought the documentation that I believed pertained to the above
case, as much as time permitted me to collect.

   I am writing you to complain about the outrageous treatment I
received from Mr. Kendrick Moxon and his associate.  Mr. Moxon, in my
opinion, asked many questions that were of a personal nature and that
had no connection to the above case.  As I was unrepresented and this
was my first experience being deposed, I was unsure how to object but
did what I felt was reasonable.
   As I was leaving I asked Mr. Moxon's associate for a floppy disc I
had brought and they had copied. He refused, stating that it
contained the church's sacred teachings and in fact he then ordered
me to give him the hard copies of the sacred teachings that I had
also willingly brought and which they had copied.  I refused to do so
and as I turned to walk away, Mr. Moxon's associate yelled "we will
raid you and sue you; you are on notice!"  I have a witness to this,
and in fact he yelled it so loudly I am sure many in the law office
heard it as well.
   Your Honor, I wish to be cooperative with the court and obey the
subpoena.  I was asked during the deposition to bring some CD-roms
that I acquired from FACTNet in Colorado for Mr. Moxon's inspection. 
I agreed to do so. However, this was before I was threatened with
being raided and  sued, and before Mr. Moxon's associate refused to
return my floppy disc.  I fear that should I turn over these CD-roms
that I will never see them again.  This fear is also based on what I
have read concerning the FACTNet and the above mentioned cases,
wherein the Church of Scientology has refused to comply with a court
order to return all hardware and software to defendants.
   Therefore, I am turning the requested CD-roms over to the court,
and they are enclosed herein.

Sincerely,



Jeffrey J. Jacobsen
PO Box 3541
Scottsdale AZ  85271
home (602) xxx-xxxx
fax (602) xxx-xxxx

cc: Kendrick Moxon, Duane W. Krohnke