Art Schreiber, 22 juni 1999

Gentlemen:

As the General Counsel of Landmark Education Corporation, I am Writing to advise you that the information on your Website (steIling.nl/simpos/est.htm) includes links to Sites that contain a number of false and libelous statements regarding Landmark Education and its program The Landmark Forum.
I am therefore providing you with information and enclosing materials which set forth the accurate facts so that you have the accurate facts on your Website.

Art Schreiber

Landmark Education Corporation

June 22, 1999

SIMPOS, p/a Koppenhinksteeg 2, 2312 HX, Leiden. The Netherlands

The information and materials are as follows:

A. Landmark Education is an employee-owned company that delivers educational programs to the public in the United States, The Netherlands and thirteen other countries. Landmark Education offers a four-part Curriculum For Living, with the basic program being The Landmark Forum, together with several other programs on subjects including communication and productivity.

The Landmark Forum is a philosophical inquiry which deals with the fundamental questions and issues which are key to shaping and determining people's effectiveness, creativity and satisfaction. As a result of participation in The Landmark Forum, people have the opportunity to create new possibilities for effective action in all aspects of their lives, and to act upon these possibilities.

1. I am enclosing material containing general background information regarding Landmark Education and its programs. Included in this information are the results of a study of more than 1,300 people who participated in The Landmark Forum. A noted U.S. social scientist and public opinion analyst analyzed the study and commented as follows:
"Several of the study's findings surprised me quite a bit, especially the large number of participants for whom The Landmark Forum proved to be 'one of the most valued experiences of my life'. This is not a sentiment that people, particularly successfull, well-educated people, express lightly. More than seven out of ten found The Landmark Porum to be one of their life's most rewarding experiences. To me, this suggests that it addresses many of people's most profound concerns - how to improve their personal relationships, how to be a more effective person, how to think productively about their lives and goals.

I can understand why people recommend The Landmark Forum to their associates, relatives and friends."

2. Harvard Business School Case Study - In response to your interest in Landmark Education, I am enclosing a copy of the Case Study on Landmark Education which was recently published by Harvard University Business School, one of the most prestigious institutions of higher education in the United States. Harvard Business School prepares cases to serve as a basis for classroom discussion rather than to illustrate the effective or ineffective handling of an administrative setting. These cases do not in any way constitute an endorsement or statement of official position, positive or negative, regarding their subject matter.
The Case Study, which is currently being used in classes in Harvard's Master of Business Administration program, was prepared based on extensive independent research on Landmark Education and its programs, including The Landmark Forum, done by several Harvard professors and their assistants The Case Study is copyrighted by Havard University and if you intend to reprint any portion of the Case Study, you must obtain their prior permission.

3. Packet of materials which Landmark Educaccion provides to the media

B. Sect or Cult The facts are clear that Landmark Education and The Landmark Forum are not a sect or cult (the term used for sect in the United States and other countries).
To this end, I am enclosing the following materials which make clear that Landmark Education and The Landmark Forum are not a sect or cult:
1. The Decision by C.J.J. van Maanen, acting President of the District Court in Haarlem, issued on May 4, 1999 regarding an article published about Landmark Education in Panorama Magazine. Judge van Maanen stated in Sections 3,3,3.4 and 3.6: "It is unmistakable that in Panorama's publication Landmark is qualified as a cult, a word which, according to the first lines of the publication, 'in usage has obtained a very negative image'." "This qualification is unfounded because Panorama could not even subsequently quote a definition of the term 'cult' which is met by Landmark, and left it undisputed that Landmark in any event does not even meet any of the characteristics listed at the beginning of the article in the frame 'how to recognize a cult' . . Panorama simply called Landmark a cult, using a definition of 'cult' in its publication which is not met by Landmark. Thus, Panorama has acted wrongfully."
2. Numerous cult experts, psychiatrists, psychologists, clergy members, judges and other qualified professionals have participated in The Landmark Forum and have given their Opinion that The Landmark Forum is not a cult. These include the following:
(a) Raymond Fowler, Ph.D., the executive Vice President and Chief Executive Officer of the American Psycliological Association, in a letter dated February 22, 1995, stated his personal opinion that The Landmark Forum in no way resembles a cult and has no cultlike characteristics. Dr. Fowler stated:
"The Forum, in my personal opiaion, does not remotely resemble a cult and it puzzles me that any reasonable person could think that it does,"
(b) Lowell Streiker, Ph.D., a recognized expert in the United States on cults, in a letter dated Februay 15, 1993, identified common characteristics of cults and concluded as follows: "None of these characteristics is to be found in The Forum or Landmark Education Education. The Forum is not a cult in any sense of the word, religious or otherwise."
(c) Judge Shiomo Shoham, who is the Legal Advisor on cult matters for the Israeli Knesset and charged with addressing the cult issue on behalf of the State of Israel, participated in The Landmark Forum and other Landmark Education programs and stated in a letter dated April 23, 1996: "I must emphasize that The Forum and the other related workshops have none of the characteristics found in the definition of a cult."
(d) Bishop Otis Charles, a Bishop of the Episcopal Church (Anglican) in the United States and the former Dean of the Episcopal Divinity School in Boston, Massachusetts, stated in a letter dated September 24, 1992: "By no definition that I know of can The Forum or Landmark Education's programs be considered part of a cult. In fact, quite the opposite, the organization and courses are conducted in a way that is entirely consistent 'with any accredited educational intitution."
(e) Letters from 6 ranking law enforcement officers, including the Assistant Chief of the Los Angeles Police Department, all of whom have participated in The Landmark Forum.
(f) Letters from 6 psychiatrists and psychologists who have participated in The Landmark Forum.

3. Anti-cult organisations and their experts, after having reviewed the facts, changed their previous position and concluded that Landmark Education and The Landmark Forum are not a cult. These include the following:
(a) Landmark Education reached an Agreement in November, 1997 with the Board of Directors of the Cult Awareness Network ("CAN"), the most prominent anti-cult organization in the United States, in settlement of Landmark Education's lawsuit brought in Chicago, Illinois in 1994 for statements made and materials distributed that alleged or implied that Landmark Education and The Landmark Forum are a cult. The Settlement Agreement was reached with the Board of Directors of the original CAN, the organization against which Landmark Education's lawsuit was brought, NOT with the new organization holding itself out as the Cult Awareness Network Hotline whichis operated by the Foundation for Religious Freedom and in some way related to Scientology.

Under the Settlement Agreement signed by the Board of Directors of the original CAN, CAN agreed that:
(a) "CAN does not hold the position that Landmark Education or any of the programs of Landmark Education, including The Landmark Forum, is a cult."
(b) "CAN has never had evidence that would justily taking the position that either Landmark Education or any program of Landmark Education has the charcteristics of a cult."

I am enclosing a copy of the Resolution adopted by the Board of Directors of the original CAN which reflects this Agreement

(b) Dr. Margaret Singer, a well-known cult expert in the United States and author of the book "Cults in our Midst", stated in writing in May, 1997 that "I do not believe that either Landrnark Education or The Landmark Forum is a cult or sect or meets the criteria of a cult or sect."
(c) Herbert Rosedale, the President of the Board of Directors of the American Family Foundation ("AFF"), a prominent anti-cult organization of long-standing in the United States, confirmed in writing on April 10, 1997 that AFF does not consider Landmark Education as a cult.

4. Retractions were published by major publications in response to Landmark Education objections to their having erroneously referred to Landmark Education or The Landmark Forum as a cult. The publications are as follows:

(a) Panorama Magazine, a major magazine in the Netherlands
(b) Hervormd Nederland, a major magazine in the Netherlands
(c) FACTS Magazine, a major magazine in Switzerland
(d) Self Magazine, a major magazine for women in the United States
(e) Redbook Magazine, a major magazine for women in the United States
(f) Guidepost, the publication of the American Counseling Association.

I am enclosing copies of such retractions.

5. This is to advise you that Landmark Education and The Landmaik Forum do not meet any of the following major characteristics of cults:
(a) The members are required to give over to the organization ownership of all or a substantial portion of their assets.
(b) The members are separated from their families and friends, often to the point excluding any contact with such people.
(c) There is a theology or dogma or doctrine that the members are required to believe in and follow and in some cases worship.
(d)The members are restricted in their actions so as to no longer be involved in activities outside tile cult.

People who participate in The Landmark Forum do not give over the ownership of their personal assets to Landmark Education other than payment of tuition for the program (f 895). In contrast to a cult having its members cut themselves off from their families and friends, many people who have participated in The Landmark Forum have reported stronger relationships with their families, friends and work associates as one of the major results of their participation. There certainly is no communal living situation involved people participate in The Landmark Forum over three full days and one evening and return to their homes at the end of each part of The Landmark Forum and when the program is completed. In direct contrast to being encouraged not to be involved in outside activities, people who participate in The Landmark Forum are empowered to participate in their communities, organizations, and institutions. In fact, many thousands of people who participated in The Landmark Forum have reported that, on their own initiative, they have taken on projects that make a difference in their communities, organizations, churches and other institutions.

Landmark Education does not use coercive pressure or deception to get people to join. There is nothing in Landmark Education for people to join. Landmark Education offers The Landmark Forum and other programs to the public, and people pay tuition for the programs as they would for adult education programs offered at any other educational organization Landmark Education has a strict policy that participation in The Landmark Forum and its other programs must be voluntary, and coercion is inconsistent with such policy.

Based on all of the extensive evidence, including thc enclosed letters from cult experts, clergy members, judges, psychiatrists, government representatives and other people of esteem, that Landmark Education and The Landmark Forum are not a cult or cultlike, it is inconceivable that any responsible person would raise the allegation of cult or even mention or imply such allegation.

As evidence of this, I am enclosing the article on Landmark Education published in the March 16, 1998 issue of "TIME Magazine. The reporters undertook an extensive investigation of all of the facts and allegations about Landmark Education and concluded that there was no factual basis to even mention the cult allegation.

C. Brainwashing - The facts are clear that The Landmark Forum and Landmark Education's other programs do not involve brainwashing, mind control, thought reform or anything that remotely resembles such techniques. As evidence of this, I refer to the letter from Edward Lowell, M.D., included in the material enclosed in B, above. Dr. Lowell, a medical doctor specializing in psychiatry and licensed to practice medicine since 1955 in New Jersey, New York and California, in a letter dated November 14, 1996, stated the following:
"I am certified by the American Board of Psychiatry and Neurology since 1962 and have spent 39 years practicing general psychiatry and psychotherapy... My psychiatric trauning included a residency in a U.S. Army Hospital in 1955 during which time, in order to deal with American military men who were mentally manipulated by their Chinese captors, I was trained specifically about the technology and techniques of 'brainwashing', 'mind-control', and 'thought reform'.

"I am familiair with The Landmark Forum and have personally experienced and examined closely the work and programs of Landmark Education. Furthermore, I have spoken professionally and personally to over two thousand people of all sorts: patients, neighbors, friends, relatives and medical and psychiatric coileagues about their actual personal experience with The Landmark Forum... After my careful observation, I have seen nothing at all that would lead me to the conclusion that The Landmark Forum or any other Landmark Education program or Landmark Education itself does or even attempts to engage in any sort of brainwashing, thought reform, hypnosis or thought modification whatsoever."

The Landmark Forum does not tell participants what to think. Instead, it encourages people to think for themselves.

Your Site links to several Sites in Germany regarding the book by Martin Lell that was published in Germany. The facts are as follows:

(a) Landmark Education did not bring legal action to stop the publication of the book. Rather, Landmark Education's action for injunction was to eliminate the use of the word "brainwashing" in the sub-title of the book since such statement was totally false and defamatory. At the Hearing, the Court decided that the term "brainwashing" was a matter of opinion, which I consider to be a highly questionable result. The Court therefore denied Landmark's request for an injunction and the book was allowed to be published with the full sub-title. Landmark Education never intended to stop the publication of the contents of the book.

(1) Mr. Lell was not "brainwashed". As the record at the Hearing indicated, following completion of The Landmark Forum Mr. Lell did not see a doctor; was not hospitalized; did not seek or obtain medication; and was not diagnosed by a medical professional as being brainwashed or having any mental problem. In fact, Mr. Lell did not even say he was brainwashed; apparently his parents, after his speaking with them following The Landmark Forum, stated they thought "he sounded like someone who was brainwashed". Given Mr. Lell was not in fact brainwashed, Landmark Education brought its action to seek the injunction against the use of such word in the sub-title of the book.

(c) In an interview on June 15, 1997 on SWF TV in Germany, Mr. Lell stated that Landmark Education and The Landmark Forum were not a sect or psycho-group and Landmark Education has no connection to Scientology.

D. Psychotherapy - The facts are clear that The Landmark Forum as well as the other programs offered by Landmark Education do not constitute psychology or psychotherapy. The Landmark Forum is not based in psychology or upon any psychotherapeutic model. It is not therapeutic in design, intent or methodology; is not a substitute for psychotherapy or any health program; and does not address issues which are best dealt with by psychotherapists or other health professionals.

Dr. Raymond Fowler, the Executive Vice President and Chief Executive Officer of the American Psychological Association, in his letter enclosed in B, above, stated that as a psychologist for 40 years who has studied psychotherapy extensively, his personal opinion is that The Forum "was nothing remotely like psychotherapy". In his letter Dr. Fowler stated:
"I want to point out that what I experienced was nothing remotely like psychotherapy . ..It certainly was not probing or intrusive or demanding. It did not expose old wounds, make interpretations or inferences about motivations and early experiences and it was not strongly confrontive. There was no psychological transference in evidence and there hardly could have been in such a large group with such distant relationships with the workshop leader."

Dr. Fowler further stated:
"In my opinion, anyone conducting such program and calling it psychotherapy would be guilty at least of false advertisement and perhaps of fraud. No one seeking psychotherapy should expect to find it in a Forum session ..."

E. Religion - The facts are clear that Landmark Education and The Landmark Forum are not a religion or religious in nature, are not contrary to religion and do not interfere with the religious beliefs of participants in The Landmark Forum. As stated in B, above, The Landmark Forum provides no theology, dogma or docrine to believe in and follow, there is nothing to worship and there are no practices to repeat. In addition, many participants in The Landmark Forum have reported that their participation in fact enhanced their own religious beliefs and practices.

I am enclosing letters from several of the many clergy members from major religious denominations who have participated in The Landmark Forum and have recommended it to others. It is inconceivable such clergy members would do that if they considered Landmark Education or The Landmark Forum to be a religion or otherwise religious in nature. The letters are as follows:
1 Bishop Otis Charles, of the Episcopal Church (Anglican) in the United States, stated in his letter of September 24, 1992, referred to in B, above:

"While I have never known Landmark's programs to deal with God, worship, divinity or theology, each person's religious preference and practice is considered his or her private concern and is completely respected. At the same time, these programs have actually allowed me to enhance my own grasp of faith tradition, and to be more effective in my religious responsibilities and practice."

2. Father Basil Pennington, a well respected Trappist monk, participated in The Landmark Forum and stated in a letter dated March 8, 1993:

"While The Forum is not religiously oriented, the full human enlivenment which it brings about leads to the person becoming more lively in the practice of his or her particular faith. It is a purely natural or human program but can be used by the faithful Christian in service of living a more lively Christian life. I have therefore without hesitation encouraged persons to take advantage of this excellent course."

3. Letters from 7 other respected clergy from major religious denominations who have participated in The Forum and have endorsed participation by other members of the clergy.

F. Damaging - As reflected in the letters included in the material enclosed in B, above, the facts are clear that The Landmark Forum and other Landmark Education programs are not damaging to people. In particular, I refer to the letter from Dr. Raymond Fowler which sets forth his personal opinion about The Landmark Forum based on his participation in The Landmark Forum and his 40 years as a psychologist. Dr. Fowler stated:

"I did not experience any personal sense of harm, danger, threat or coercion at any time and I saw no evidence that anyone else did."

Dr. Fowler also stated:

"I have talked to psychotherapists who encouraged certain of their patients to attend a Forum session when they felt they were ready to do so and they uniformly felt that the experience was non-harmful and perhaps encouraged insight."

G. est - The facts are clear that Landmark Education is not formerly est. Landmark Education, an employee-owned company, was organized in February, 1991, more than 6 years after the est Training ceased being delivered and est ceased operations. In addition, The Landmark Forum is not the est Training. The Landmark Forum is a completely different program from the est Training in both content and methodology.

H. Werner Erhard - Mr. Erhard created part of the technology that was acquired by Landmark Education and is utilized in programs delivered by Landmark Education. However, Mr. Erhard has never been a stockholder, officer, director or employee of Landmark Education and has never been involved in the

management or operation of Landmark Education. Nevertheless, given the close identification of Mr. Erhard with Landmark Education's programs in the public's mind, Landmark Education considers that false and libelous statements which are made regarding Mr. Erhard are libelous to

Landmark Education and its programs. Your Site has links to several Sites which contain false statements regarding Mr. Erhard. To provide you with the accurate facts, I am enclosing the following documents and providing the following information:

(a) Materials conceing Mr. Erhard.

(b) As stated in the TIME Magazine article which is enclosed under B, above, the allegations against Mr. Erhard regarding family and income tax matters were false.

(c) The Correction published earlier this month in Elsevier Magazine.

(d) Mr. Erhard was never a member of the Church of Scientology. More than 30 years ago, he took 2 Scientology courses as well as over 50 other courses offered by many different organizations as part of a program of self education on various disciplines. These included courses on Gestalt Therapy and Eastern philosophy.

4. Landmark Education has no connection or association with Scientology. This is confirmed by the following documents which are enclosed:

(a) Correction published in FACTS Magazine, which is enclosed under B, above.

(b) Retraction broadcast on Fox Television Station WTTG in Washington, D.C.

Conclusion

Based on the infonnation set forth above and inl the materials enclosed, I demand that you remove the links to the Sites containing characterization of Landmark Education and The Landmark Forum as a sect or cult, as well as any of the other false and libelous statements regarding Landmark Education and The Landmark Forum identified in my letter. Your inclusion of links to the Sites containing these false and libelous statements has damaged the reputations of Landmark Education, its program The Landmark Forum and the more than 400,000 people around the world, including several thousand people in the Netherlands, who have participated in The Landmark Forum. I also demand that you agree to refrain from publishing such false and libelous statements elsewhere in your Website.

This is to put you on notice that in the event you fail to remove the links to the Sites containing these false and defamatory statements, Landmark Education will instruct its attorneys in The Netherlands to take appropriate legal action against your organization and your officers for the damage that has resulted form your Website. I trust that after reading the information and materials I have provided, you will act responsibly and remove the links to the Sites containing these false and defamatory statements so that such action will not be necessary, and also agree to refrain from publishing such statements elsewhere in your Website.

Please let me know by fax (at 1-415-616-2411) whether you will remove the links to the Sites containing these false and defamatory statements regarding Landmark Education and The Landmark Forum from your Website, and will refrain from publishing such statements elsewhere in your Website. I will await receipt of your fax response at your earliest opportunity.

Sincerely, Art Schreiber, General Counsel