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APPENDIX

ADDITIONAL SUBMISSIONS FOR THE RECORD

SUPPLEMENTAL SUBMISSIONS OF SUN MYUNG MOON

Casey, Scott & Canfield, P. C.
Attorneys at Law

August 13, 1984

420 Washington Building 1435 G Street. N. W Washington, D. C. 20005

(202) 783-6490

Honorable Orrin G. Hatch

Subcommittee on the Constitution

Committee on the Judiciary

of the Senate of the United States Russell Building

Suite 135

United States Senate

Washington, D.C.

Dear Mr. Chairman:

The enclosed analysis of the record of the trial of Reverend Sun Myung Moon is submitted on behalf of the Unification Church of America in order to address various issues raised during the June 26, 1984, hearings of the Subcommittee concerning Religious Liberty in the United States.

Recently, it has been suggested that Reverend Moon's testimony at your hearing "totally misstated what was involved in the prosecution." We believe that the enclosed memorandum presents a fair and objective description of what happened in Reverend Moon's prosecution, using quotations from seven thousand pages of trial transcripts.

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We appreciate this opportunity to contribute to consideration of an issue most important to the majority of Americans religious freedom under the U.S. Constitution. We also are thankful for the very helpful and thoughtful consideration extended by your staff.

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Oversight Hearing on Religious Liberty
Before the Subcommittee on the Constitution
United States Senate Committee on the Judiciary

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B.

The Highly Prejudicial Publicity
Surrounding the Unification Church and
Reverend Moon Precluded Any Possibility
That a Panel of Jurors Free From Bias
or Prejudice Could be Selected . .

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14

34

377

C.

The Government's Prosecution of This
Case on the Basis of Whether the Unifi-
cation Church Was a True Religion, Deprived
Reverend Moon of the Opportunity For a
Fair Trial

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39

41

2.

The Government Attempted to Discredit
Church Members Who Appeared to Testify
By Focusing its Questions Upon the
Issue of "Brainwashing" ..

51

3.

The Government Introduced Irrelevant
and Highly Prejudicial Evidence in
Order to Support the Vague and
General Conspiracy Alleged in the
Indictment. . .

65

4.

The Government Convicted Reverend
Moon on the Novel Theory That "If It
Is Moon's Money and He Used All of
It For the Church That Doesn't Make
It Not His Money"

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72

77

Oversight Hearing on Religious Liberty
Before the Subcommittee on the Constitution
United States Senate Committee on the Judiciary

INTRODUCTION

SUPPLEMENTAL COMMENTS ON BEHALF
OF THE

UNIFICATION CHURCH OF AMERICA

This document is presented to the Subcommittee in response to an invitation extended by the Chairman, Senator Orrin G. Hatch, at the conclusion of its hearings concerning Current Issues in Religious Liberty on June 26, 1984.

Reverend Sun Myung Moon ("Reverend Moon") the

spiritual leader of the worldwide Unification Church movement and the Unification Church of America, was convicted of filing false Federal income tax returns on July 16, 1982, in the United States District Court for the Southern District of New York. This conviction followed a six-week trial, during which the Government sought to

buttress its vague and novel theories of taxability with

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