13 th September 2002 Luigi Cascioli lodges the present formal complaint at the Seat of the Court of Justice in Viterbo, Versus don Enrico Righi, parish priest in Bagnoregio, as representative of ministers of religion, for abuse of popular credulity and impersonation. TO THE PUBLIC PROSECUTOR'S OFFICE COURT OF JUSTICE OF VITERBO The undersigned Luigi Cascioli, resident in Roccalvecce (Viterbo) Via delle Province no. 45/b EXPOUNDS WHAT FOLLOWS After long and deep studies consisting of (and not only) textual exegesis of the Old and New Testament and other Sacred Scriptures, the undersigned has come to the conclusion that many of the facts produced and presented as if being true and historical in the so called “Holy Scriptures”, are in reality false, first of all the historicization of the figure of Jesus Christ, for the most part based on the figure of John of Gamala, son of Judas, downright descendant of the Asmoneian stock. The grounds that have led the undersigned to such conclusion are expressed in detail in the book that is alleged to the official complaint and of which is integrant and substantial part. This complaint does not wish to contest the freedom of Christians to profess their faith, sanctioned by art. 19 of the Italian Constitution, but wishes to denounce the abuse that the Catholic Church commits by availing itself of its prestige in order to inculcate – as if being real and historical – facts that are really just inventions. A plain example of such abuse, has been perpetrated by don Enrico Righi (parish priest of Borgoregio) when he had falsely sustained, in the parish gazette of St. Bonaventura in Borgoregio, ? 245 of March-April 2002, that the historic figure of Jesus was the son of Joseph and Mary (two totally imaginary characters and therefore historically non existing); of having the same Jesus been born in the village of Bethlehm and of having grown up in Nazareth. That the figure of Jesus has been fully constructed over a certain John of Gamala , son of Judas from Gamala, known as the Galilean, is irrefutably known by such a great number of proofs as to remove whatever doubts about the falsifications carried out by the compilers of the Gospels. It would suffice that concerning the transformation of the appellation Nazireo, as was usually called John of Gamala as inhabitant of Nazareth , to show in the most absolute manner the impersonation stated. From the penological point of view, these historical falsifications can integrate cases in point of two offences: the abuse of popular credulity, and impersonation (in the case of Jesus Christ). According to article 661 of the Italian Penal Code, there is an abuse of popular credulity when someone, by means of fraud, deceives a great number of people. In this particular case, the ministers of religion of the Catholic Church, like Righi in the present case, by committing historical falsity, therefore presenting invented facts as if true and actually occurred – but useful to religious doctrine – they deceive all the people that come into contact with the teachings of such religion, by inducing them to believe in that religion, not on the basis of purely theological reasoning (totally legitimate and admissible), but on the basis of a deceptive representation of the facts. The offence is of transgressive and contraventional nature for which the psychological element of the offence suffices, which certainly is to be found in all ministers of the Catholic Church, (therefore also in don Enrico Righi) in view of the fact that it is not credible that educated people, whom by vocation and profession continually study the Bible and the Gospels, have not been aware of the numerous and repeated falsehoods (even gross) contained in those writings. As to the offence of impersonation, this occurs when a party gains benefits by attributing to it, or to others, a fallacious name. In the case in question, the book “ The fable of Jesus Christ ” (to which I refer for more detailed explanations) demonstrates that Jesus Christ never existed, and that under that name there hides John Gamala. Therefore the ministers of the Catholic Church who proselytise (in order to gain benefits from the number of more believers, and the more there are the more will be the economic income derived from their offering and donations – among which the 8 per thousand combined to the incometax return) – on the basis of this falsehood, mislead those who receive their message and therefore, commit offence called for and punished by the article 494 of the Italian Penal Code. Among other things, to integrate the offence in question, “it is not necessary that the goal proposed by the offender is in itself illegal or aimed at profit, since it may well be legitimate and not aimed at gaining profit.” (Cassation; Section V - 9.02.1973 ? 164; in conformity with Cassation, Section V – 17.02.1967, ?340). The subjective element requested is the specific malice, which exists in all these subjects that are consciously aware of such falsity, still have no scruples about continuing to divulge them, as don Righi is doing. The responsibility of the Pope may only be of a moral nature, considering his immunity granted by the Article 3 - 1 st comma of the Italian Penal Code, whereas all the other Ministers of the Catholic religion (among which don Righi) may be faced with the responsibility of penal nature. The continual presentation and description and divulgation of false facts passed off as true, also harms the moral tranquillity and serenity of the petitioner with the consequential emotional distress, for which he will request damages in the proper seat by means of timely filing a civil action in criminal proceedings. The undersigned, at disposal of the Judiciary Authorities for any further explanations about the merits of the question, reserves, as from now, the right to integrate what has been denounced, and expressly asks to be heard on the above facts. Such being stated and considered, the undersigned Luigi Cascioli presents formal DENUNCIATION-LAWSUIT Towards and against don Enrico Righi, parish priest of Bagnoregio (VT), residing in Matteotti Road no. 45, and eventually towards other ministers of the Church – with him in concurrence and joinder of offence – called for in articles 494 and 661 of the Penal Code, as well as for any other offence that Your Honour wishes to advise in the behaviour above described. The undersigned reserves the right to file legal action against offences in the manner and time established by the law, and asks, ex art. 408 Penal Code, to be informed in the case of dismissal of the matter criminis. The book enclosed in the file constitutes alleged part of the complaint. Yours respectfully The denouncer Luigi Cascioli Translated from Italian into English by Enrico Laganà – Via Crispi 133 17027 Pietra Ligure, Italy.