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3. Activities a. According to the Defendant organization's publications "Family" and "Blessing" from 1982 to 1989, it is admitted that Sun Sen Moon ordered, inter alia, his followers to support financial activities by giving him their entire estates and to obey him absolutely. Also, according to the Defendant organization's publications "Family" and "Blessing" from 1980-1990,it is admitted that the director of the Defendant's headquarters repeatedly instructed followers to carry out "Ban Butsu Fukki" (described below). b. According to the Defendant organization's publications "Seiyaku no Kane (Bell of Promise) and "Kyokai no Katsudo Hoshin" (Plan of Church Activities),in addition to fundamental missionary work, the ideal way in which one may achieve "Ban Butsu Fukki" is to sell "mana" (pure, high quality Ginseng rootextract) and to establish and distribute mana on sales routes. Again in "Seiyaku no Kane" of the same year, the results of mana sales activities in each district are listed. Moreover, according to 1971-1989 editions of the Defendant organization's publication titled "family," it is admitted that believers of the Defendant pursued financial activities such as selling vases and Ginseng tea and carried out financial activities at churches in various districts throughoutJapan. c. At national and central "Block" leader conferences (which began in 1984) - acting on the instructions of Moon - the necessity of collecting donationsof considerable sums for the unification movement and the amount of money aimed for via donation collecting in Japan (e.g. 10 billion yen per month from 1985-86) were projected and this information was passed on by each block president to believers in each respective district. d. According to the 1971 edition of the Defendant's magazine "Seiyaku no Kane " ( Bell of Promise), the Defendant's secondary business sector is listed asproduct sales to be carried out by Shiawase (meaning is "Happiness") Shoji corporation. e. Although the Nara city home ( a place where believers of the Defendant lead a communal life-style), a list of persons who were to be "evangelised,"their weak points, needs and the like and a list of business showings which recorded the number of persons and the amount of their donation(s) were posted. f. Unified activities throughout Japan Various types of manuals exist which describe the Defendant's methods of evangelism or missionary work such as: (1) Praying and having heart to heartexchanges; (2) Using questionnaires, family names, palmistry, family trees and so on, and listening to people's problems; (3) Speaking about the spiritual world and destiny in reference to the ill fate of one's ancestors being passed; (4) Making prospective believers come to the video center and showing them videos of the teachings of the Defendant; (5) Having persons purchase products and/or solicit their donations when they join the Defendant. The manuals state that these methods should be followed in order that weight should be placed on after care. The Defendant's activities have all these points in common. Concretely, the manuals for roadside missionary use of Aichi and Nara prefectures have the same content. The talk series of Aichi prefecture and the Matsue church follow similar formats. The way of reading a person's destiny by implementing and passing judgement on his or her family name (name analysis) is nearly the same in content at the Higashi Osaka Church and the Matsue church. Then after one is brought to a video center and inculcated with the teachings, etc. of the defendant, she/he is informed that the donation will go directly to the Defendant and Sun Sen Moon. g. Statements submitted by former believers According to the statements submitted by former believers (names omitted)as well, it is admitted that the Defendant's activities consisted, inter alia, of 1) deciding a goal amount of money and the pursuing financial activities; 2) of carrying our missionary work in accordance with methods described in manuals; 3) causing or encouraging feelings of insecurity in others by telling them stories of destiny and ill fate in conjunction with their known anxieties; 4) of soliciting donations and the purchase of products after having learned the financial situation of prospective believers; 5) of soliciting without clarifying the relationships of the Defendant and Sun Sen Moon; and 6) of relentlessly soliciting prospective believers. Further, the weight placed on knowing the financial situation of prospective followers prior to them making donations is common to all of theDefendant's operations in Japan. Methods for finding out the financial situations of persons being evangelised are recorded on the lecture video concerning methods for soliciting donations at the Niigata video center and in the West Tokyo Block Donation Talk manual. For example, at the Matsue church, the Turtle Shell form questionnaire ( a 6 column special format questionnaire which resembles the pattern on the shell of a turtle) is used at the 7th district in Tokyo. The summit list - a reference list of mortgagevalues of real estate owned by property owning believers was compiled. Donations and the like from others were solicited relentlessly. At the final stage of making prospective donators resolve to give donations, a group of members of the Defendant worked together to solicit the donation. At the first stage of solicitation, the role or involvement of the Defendant and Moon is unclear. That the Defendant is a religious group is denied unambiguously. B The Defendant and the organization of Believers It goes without saying that the organization of believers is comprised of members of the Defendant. The Defendant came to pursue vigorously fund-raisingactivities by systematic product sales - as a practice based on its teachings.Through this process, the distinction between the Defendant and the organization of its believers is not made clear. Manuals exist for the Defendant's missionary work - which follows almost the methodology throughout Japan. In light of the Defendant's religious teachings, activities of and related to soliciting donations - which are at issue in this case - are the most fundamental and important of the defendant's religious activities. In reality,that the Defendant accepted donations collected through its believers suggeststhat acts of soliciting donations in this case were acts of and conducted by the Defendant. Regarding this point, it is uncertain whether or not, the charts of each organization (presented by both parties to this suit) correctly illustrate theactual situation of the Defendant's organization. However, provisionally, it may be said that from the substance of the above recognition, even upon accepting that the formal organizational framework is as the defendant has asserted, if the acts of soliciting donations are evaluated as unlawful acts, then the Defendant is the primary organ which bears responsibility for those unlawful acts.
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