Amendment rights by proxy. First Amendment rights are, by
their very nature, personal rights. If my wife pickets
Scientology, she can’t, by definition, be my agent. She’s
acting in the fulfillment and the exercise of her rights
and no one else’s, as is anybody who protests against any
organization.

The case that has been presented to you today
is legally woefully inadequate. And in other litigation
that is flying around the bay at present, we hear
repeatedly arguments and statements about a certain case
being a scam, being a sham, somebody else not being the
real party.

Well, Judge, I would urge you, I would beg you
to consider this: Richard Howd was never certified as a
class representative for anybody. Richard Howd has never
been recognized as a proxy for any organization. Richard
Howd has no standing, according to the testimony you heard
from that stand today, no standing in any supervisory
capacity over anybody in any Scientology organization.

He is an individual. He is a peon at the
bottom of the Scientology totem pole. And, somehow, this
case has, as I said, metastasized until Richard Howd’s
demand for relief from getting poked in the nose turns into
a prohibition of other people offending Scientology at
large.