GRAHAM E. BERRY
3384 McLaughlin Avenue
Los Angeles, CA 90066
Phone: (310) 745-3771
Fax: (310) 745-3772

grahameb@aol.com

January 21, 2002

By Fax and Federal Express.

Hon. John Ashcroft
U.S. Attorney General
U.S. Department of Justice
950 Pennsylvania Avenue, NW
Washington, DC 20530-0001

Honorable Attorney General:

I respectfully submit the following information to your office for immediate action:

1. Criminal Complaint;
2. Civil Rights Complaint;
3. Hate Crimes Complaint;
4. Fraud Complaint;
5. Request For Investigation;
6. Request For Grand Jury Proceedings and Criminal Prosecution; against, inter alia, Church of Scientology International, David Miscavige, Mark "Marty" Rathbun, Michael Rinder, Lyn Farny, Eugene M. Ingram, Kendrick L. Moxon, Elliot Abelson, Donald R. Wager, Ava Paquette, Michael Hurtado and Miguel Hurtado; and
7. Request for investigation of apparent public corruption: involving, inter alia, certain employees of the Los Angeles and Riverside District Attorney’s offices, the Los Angeles City Attorney’s Office and the State Bar in California including but not limited to Gerald Chaleff, Esq., of Los Angeles, CA; Robert Schwartz, Esq., of Riverside County, California; Elliot J. Abelson, Esq., of Los Angeles, California; Samuel D. Rosen, Esq., of New York and New Jersey; Gerald Feffer, Esq., of Washington, DC; Kendrick L. Moxon, Esq., of Los Angeles, California and Clearwater, Florida; Eugene Ingram of Los Angeles, California; Fred T. Goldberg, Esq., of Washington, DC., Margaret Milner Richardson, Esq., of Washington, DC; David Miscavige of Hemet and Los Angeles, California; Mark ("Marty") Rathbun of Los Angeles and Hemet, California and Clearwater, Florida; Michael Rinder of Los Angeles and Hemet, California and Clearwater, Florida; Donald R. Wager, Esq., of Los Angeles, California and Hon. Alexander Williams, III of Los Angeles, California.

1) The Los Angeles District Attorney’s Office has recommended that the FBI investigate these matters, Infra, page 79.

2) The current Director of the Office of Management and Budget, Mitch Daniels, has had painful personal experience with Church of Scientology, which he claims is "driven by crass financial motives." Infra, page 110.

3) The Church of Scientology is America’s own "Taliban" using tax-exempt funds in its express totalitarian goals of "taking over the control or allegiance of the heads or the proprietors of all news media…key political figures…those who monitor international finance." Targets Defense, L. Ron Hubbard. Infra, page 27.

4) America’s allies classify the Church of Scientology as a "psycho-terror" criminal cult engaged in financial crime and money laundering. Infra, pages 69, 86-97, 110-111, 117. For example, the Church of Scientology is currently implicated in the largest ever-financial "ponzi" scheme in American history. It involves over $500 million dollars and over 850 investors. Infra, pages 65, 103.

5) Using tax-exempt moneys, the Church of Scientology orders its female para-military Sea Organization staffers to have abortions. Infra, page 97. The Church of Scientology also engages in child abuse and violations of the child labor laws. It has engaged in these as well as other terrifying acts causing permanent damage to entire families. The Church is intent upon the denial and destruction of Christianity and all other religions. Scientology maintains at least three concentration camp type facilities upon American soil and it calls for the extermination of billions of people. Infra, pages 23, 27, 30, 38, 97-102. It has its origins in Satanism and black magic. Infra, pages 98-100. Lying to protect and expand Scientology is considered a holy sacrament. Infra, pages 17, 18, 25, 26, 89, 93, 100.

6) In 1977, the U. S. Department of Justice, through the F.B.I., conducted three massive, simultaneous raids against the Church of Scientology. The FBI seized thousands of documents linking the Church of Scientology to organized crime and the use of the U.S. legal system to harass, frame and destroy those it perceived as "enemies" of Scientology. Infra, pages 20, 21, 47, 48, 118. This complaint also involves Scientology lawyer Kendrick L. Moxon ("Moxon") who was named as an "unindicted co-conspirator" in the resulting criminal proceedings and convictions. Infra, page 24. This was the largest ever known criminal infiltration of the United States Government. Infra, pages 17, 48.

7) Between 1991 and 1993, Moxon was engaged in what appears to be the largest ever-criminal tax fraud perpetrated against the United States government. Infra, pages 35, 47, 88-90, 112-117. In October 1993, Scientology’s para-military "ecclesiastical" leader claimed that the I.R.S. reversal and granting of 501(c)(3) tax-exempt status saved the Church of Scientology over one billion dollars in past due taxes, penalties and interest. Infra, page 113. Concurrently, Moxon was engaged in unsuccessful litigation against Joseph Yanny and Uwe Geertz in which I was one of the defense counsel in the Church of Scientology cases against former church attorney Joseph A. Yanny. I was lead defense counsel for psychologist Uwe Geertz in Church of Scientology v. Fishman & Geertz. Infra, pages 21-24, 34.

8) In Fishman - Geertz, we filed substantial evidence of the Church of Scientology’s involvement in financial frauds, instructions to commit murder and instructions to commit suicide. Infra, pages 22-24, 34. It is now believed that Moxon, Williams & Connolly lawyer Gerald Feffer, Scientology leaders David Miscavige and Marty Rathbun, and certain private investigators, were involved in he blackmail of the then Commissioner of the I.R.S. and of the Chairman of the Senate Finance Committee. Infra, pages 112-118. As a result of the successful defense of the Fishman-Geertz case, the Church of Scientology feared exposure of their billion-dollar continuing tax fraud upon the United States government. Scientology, Moxon and private investigator Eugene Ingram have all testified to launching a ["haunting"] "investigation" of me in 1993. Infra, page 26. In 2000, Scientology attorney Elliot J. Abelson ("Abelson") was continuing with the worldwide ""investigation of me. Infra, page 72.

9) The Church of Scientology, Moxon, Abelson and Ingram pretextual "investigation" of me included the blackmail and bribery of a Robert Cipriano. Cipriano signed a perjured and highly defamatory declaration that I was a child molester. Scientology and its shills disseminated the highly damaging declaration world wide as part of its "Fair Game" Policies and Practices. Infra, pages 26- 33.

10) Despite Church denials, Scientology’s "Fair Game" Policy has been repeatedly and recently recognized in the courts. Infra, page 25. Continuing to this day, the church and its lawyers have used its "Fair Game" practices against me to, in the words of one of the Church’s documents, "ruin [me] utterly." Infra, page 25. As you have read, the Church of Scientology, its lawyers and private investigators have engaged in numerous felonies, which, as was intended, have dramatically changed my life for the worse. Infra, pages 18, 19.

11) The evidence of serious felonies committed by the Church of Scientology, certain of its lawyers and certain of its investigators, is overwhelming. There are over ten witnesses and over sixty corroborating and damning documents, many with Moxon’s own signature. One of Scientology’s other lawyers testified to client/witness solicitation and witness tampering. Infra, page 67.

12) The evidence involves a major R.I.C.O. enterprise that includes, at the least, the Church of Scientology and certain of its outside lawyers and investigators. Infra, pages 17, 21, 25, 36, 56, 63, 84, 93. In addition, it also appears that a number of federal and state officials and employees, federal and state judges, law enforcement officers are also involved. Infra, pages 35-36,44,48,50,54,61-63,66-68,70-72,75-85,93. It is believed that the participation of many of this second group of people has been procured by extortion and other foul behavior that is mandated by the Church of Scientology’s "Fair Game" Policies and Practices. Infra, pages 25-32,45,64,66,116. The known criminal conduct crosses state and national borders, uses the interstate mails and modes of commerce, and violates numerous federal criminal and other laws. Obstruction of justice, witness tampering, perjury and frauds upon numerous courts are the common threads throughout the seven-year history of the Scientology enterprises despicable scheme. Infra, pages 57-61, 69,81,84,90.

13) This obstruction of justice also involves the corruption of justice in different cities, counties, states and nations. Infra, pages 72-74,81, 85 93-95.

14) Numerous victims and others have unsuccessfully requested investigation and other action by authorities, which include the I. R.S. Infra, pages 80-84. I unsuccessfully requested action from former Attorney-General Reno. She did not know what I wanted done with the evidence! Infra, page 83.

15) Under Church of Scientology influence and pressure, the Clinton Administration ignored other evidence and media demands for investigation and prosecution of the Church of Scientology. The Clinton Administration even ignored repeated Wall Street Journal, New York Times and Washington Post editorials calling for an investigation into the fraudulently obtained granting of tax-exempt status (and a one billion dollar "tax relief" package) to the Church of Scientology in 1993. Infra, pages 89, 90.

16) I have repeatedly attempted to have federal and state law enforcement investigate and prosecute the matters complained of in Part One of this letter, so have others. However, at every juncture, Church of Scientology retained lawyers have interfered with and obstructed our efforts. Infra, pages 75-80. The U.S. Department of Justice, during the Clinton Administration, was unable and unwilling to deal with the evidence. Infra, pages 80-84. Both the Los Angeles Police Department and the Los Angeles Sheriff's Department have recommended that criminal proceedings be filed. Infra, pages 77-79. Repeatedly, the Los Angeles District Attorney's Office and the Los Angeles City Attorney's office have refused to prosecute for "political reasons" and because of "political influence." Infra, pages 76, 79. In addition, those local prosecutors have allowed the proposed targets of such prosecutions to participate in the decision making process that most recently concluded that these matters (extortion, perjury, obstruction of justice, etc.) were not serious enough for prosecution. Infra, pages 78-79.

17) This is a classic case of public corruption and obstruction of justice at the local level and it involves my constitutional due process and other civil rights guaranteed by both the U. S. and State of California constitutions. Such matters are properly within the jurisdiction of the U.S. Department of Justice. Of course, the U.S. Department of Justice also has jurisdiction because of the nature of the inter-state and international criminal and corrupt conduct involved and described in Part Two of this letter. Moreover, the apparent corruption of certain aspects of local Los Angeles law enforcement has already been recognized by the fact of continuing U. S. Department of Justice court ordered supervision of justice, law and order in Los Angeles, following the recent Rampart scandals.

18) The constitutional due process and other procedural violations of my civil and human rights include the blatant and brazen corruption and conflicts of interest summarized below. Infra, pages 77-80. Of course, there is also the staggering and stunning corruption of the United States government, by the Church of Scientology. Infra, pages 35, 47, 88-90, 103-110, 112-117. This cannot and must not be ignored. "That men do not learn very much from the lessons of history is the most important of all the lessons that history has to teach." Aldous Huxley, Collected Essays (1959). See generally, U.S. v. Hubbard, 474 F. Supp. 64 (1979). Infra, 21, 103.

19) By way of contrast, Scientology attorneys Abelson, Gerald Feffer (Williams & Connolly) and Samuel D. Rosen (Paul, Hastings, Janofsky & Walker) have also been engaged in corruption with the Riverside County, CA District Attorney’s office. The Riverside Sheriffs Department investigated and recommended against prosecution of Keith Henson for picketing one of the Scientology desert "gulags." Abelson, Feffer and Rosen pressured the District Attorney to ignore the Sheriff's recommendations and to prosecute Henson. The Church of Scientology provided Rosen, Abelson and Feffer as resources for the Riverside District Attorney's Office prosecution of Henson. Infra, page 73. The Church of Scientology and its attorneys have also recently engaged in other demonstrable public corruption and obstruction of justice that includes the Caberta, Cult Awareness Network Bunker, Prince, McPherson, Minton and Ward cases (and the States of Illinois, Florida, Massachusetts and California). Infra, pages 73-75.

20) This is not isolated conduct by the Church of Scientology. There are numerous recent criminal convictions, civil judgments and public settlements that tend to corroborate the evidence of the matters outlined herein. Infra, pages 86 - 88.

21) There is widespread public perception, around the world, that the U.S. government has, in essence, been totally and irreversibly corrupted by the Church of Scientology, its lawyers, lobbyists, public relations and private investigators. Infra, page75. As you read above and below, my own experience at seeking equal justice under law has also been consistently obstructed, corrupted and ignored. Infra, pages 73, 75 -77. Infra, page 74.

22) In addition, Scientology, Abelson, Moxon, Kobrin, Paquette continue to abuse process with an Adversary complaint in United States Bankruptcy Court in Los Angeles. This case will be tried on January 28, 2002, and requests non-dischargeability of Judge William’s order that I pay Barton’s costs in defending the defamation suit I filed (and was forced to dismiss) against Cipriano, Barton, Scientology, Miscavige, Ingram (Abelson and Moxon). Infra, pages 40-44,63,66.

Consequently, I am immediately making this complaint and request letter public, and providing copies of this letter (and many of the enclosures) to other members of the current Administration, certain executive branch officials, members of the Senate and House, the media, certain foreign governments, certain international organizations and certain non-governmental organizations.

This matter involves domestic terrorism and the Church of Scientology which, in a long pattern of criminal behavior escalating over the years, has effectively "hi-jacked the legal system and crashed it through the Constitution." In so doing, the Scientology enterprise has used powerful, greedy and amoral lawyers, sleazy private investigators, Racketeer Influenced and Corrupt Organization Act ("RICO") predicate acts (18 U.S.C. sec.1961 et seq.) and fraud to further its "psycho-terrorism" and intimidation of those who would impede its terrible totalitarian subversive agenda.

Indeed, CNN Cross Fire Co-Host Bill Press has said that the Church of Scientology is, "Very clever, very skilled at media harassment. I was not prepared for that kind of harassment. I never ever received anything like that before from any other source. They’re an untold story. They’ve scared a lot of news off. They’re getting away with murder. I say put on your asbestos suit and charge." emphasis added http://www.lermanet.com/cos/index.html

Commentator Bill Press’s words were closer to the truth than he may have realized. In writing on Church of Scientology "ethics," Scientology’s "spiritual" founder L. Ron Hubbard stated:

"…in any command of mine, you can wear horns and grow a tail if you do your job. If you don’t do your job, you can’t even think sideways without getting disciplined, transferred or demoted." --- Flag Order 4, 13 August 1967, by L.Ron Hubbard.

Similarly, L.Ron Hubbard wrote:

"In short, a staff member can get away with murder so long as his statistic is up and can’t sneeze without a chop if it’s down. To do otherwise is to permit some suppressive person to simply Ethics chit every producer in the org out of existence." emphasis added --- HCOPL, 1 September 1965, Ethics Protection.

On December 2, 2001, you informed the nation of a long-overdue reform of FBI and Justice Department policy. According to the Associated Press, you stated that, "People who hijack a religion and make out of it an implement of war will not be free from our interest." Quite properly, President Bush's Administration has not hesitated to use, as further proof of terrorism, the internal documents of the Taliban and other pseudo-religious terrorist and geo-political groups. Moreover, the FBI and the courts have always used the internal damning documents of the Mafia and other criminal groups. In the case of the Church of Scientology, there is a mountain of such damning internal documents deceptively labeled as unpublished, copyrighted, confidential and sacred "trade secret" scriptures. Two examples suffice to illustrate the fact that, in your own words, the Church of Scientology has "hijacked a religion and [made] out of it an instrument of war." The Church of Scientology has a policy and practice, instituted on February 16,1969, entitled "Confidential: Battle Tactics" which requires the Church to use military tactics and strategy in dealing with the "enemy" which is defined to include American citizens such as I. The Church, and the individuals subject to the criminal complaint that is this letter, are ordered to conduct:

"… wars of attrition on the basis of total attrition of the enemy. So never get reasonable about them. One cuts of enemy communications, funds, connections. He raids and harasses. Seeing it as a battle one can apply battle tactics to thought actions. Intelligence identifies targets and finds out enemy plans and purposes, enemy connections, dispositions, etc. Never treat a war like a skirmish. Treat all skirmishes like war." emphasis added

Similarly, a Hubbard Communications Office Policy Letter of December 2, 1969 entitled "Confidential: Intelligence-Actions: Covert Intelligence: Data Collection, states that:

"Essentially a covert operation is intended to embarrass, discredit or overthrow or remove an actual or probable opponent. It is a small war carried on without its true source being disclosed. It follows all the rules of war but uses propaganda, psychological effect, surprise, shock, etc., to achieve its ends." emphasis added

Scientology’s Office of Special Affairs ("OSA") conducts the Church’s covert operations, intelligence, intimidation and infiltration, an intelligence operation that rivals the FBI.

"In my opinion the church [of Scientology] has one of the most effective intelligence operations in the U.S. rivaling even that of the FBI."

Ted Gunderson, former head of the FBI’s Los Angeles office, quoted in Time Magazine, May 5,1991, as quoted on-line at http://www.factnet.org/Scientology/salmonpayne.html or http://cs.cmu.edu/~Fishman/time-behar.html Scientology intelligence policies on line at http://www.entheta.net/entheta/go/go.html

The matters complained of herein arise from my professional experience as a lawyer with over ten years of litigation against the Church of Scientology in over 15 different cases. My clients prevailed in half of those cases. As you have not been personally involved in those matters, this letter and the events herein may strike you, as they would any rational, law-abiding person, as the paranoid ravings of a person who should be writing mystery novels instead of the cool and rational explanation of an attorney with many years experience pleading sophisticated and complex cases. Nevertheless, I can assure you that this is not so. When considering matters involving Scientology one must put all experience and assumptions aside. For example: that Scientologists and their representatives will tell the truth and act with integrity. On the contrary, and as you will read below, Scientology has an institutional policy and practice of lying and cheating to conceal the truth and advance its global totalitarian agenda and interests. There are no exceptions - even when they are fronted by eminent expensive lawyers and giant law firms of hundreds and thousands of lawyers blindly selling out their professional oaths and civic ethics for fees aggregating thousands of dollars per hour from a Scientology annual litigation budget which exceeded $40M in 1991. Scientology succeeds in these deceits and manipulations because most people, officials and institutions cannot conceive of such an inherently evil "church" fronted by cherished celebrities who are themselves shielded from the real institutional truths, and who are held hostage by "church" "folders" containing written records of their many confessionals ("auditing sessions") given while they were attached to the church’s principal religious artifact the E-meter. The E-Meter is an early form of lie detector that Hubbard found in a London store and purchased for several pounds. Scientology now sells versions of the E-Meter to "parishioners" in "exchange" for "fixed donations" sometimes exceeding $35,000 for some models. See generally: U.S. v. An Article or Device…"Hubbard E-Meter", 333 Supp. 357 (1971). http://www.lermanet.com/case2.htm . Indeed, to paraphrase U.S. Defense Secretary Donald Rumsfeld: We are dealing with people who are world-class, shameless liars. They have a pattern of saying things that aren’t so. Their repeated lying should be taken into account in connection with their allegations and explanations.

Indeed, the facts outlined herein are demonstrable, if seemingly incredible, and I beg your forbearance as you work through this summary, even as your ability to accept these events as having actually occurred may well be stretched to the limit! Indeed, the experience of dealing with all of this complex and convoluted material is, I am certain, much like Alice’s experience in Wonderland. http://www.lermanet.com/exit/FINAL.htm and http://www.angelfire.com/scifi/Scientology/

It is, however, a fact that hundreds of other people, many of whom post to the Alt.religion.scientology Internet newsgroup, have experiences similar to those I am reporting here. For them too, such experiences have been very damaging to their lives. See http://www.xemu.demon.co.uk/clam/lynx/q0.html and http://www.offlines.org/harass/sp962.htm.

Many more citizens have been terrorized into silence. See http://www.xenu.net/ and http://www.lisatrust.net/ and >http://www.lermanet.com/ (deaths section) and Many">http://www.factnet.org/ Many others are lost and missing http://home snafu de/tilman/recon html and http://www.xenu.net/archive/deaths/ and http://www.scientology-kills.org/5353/5353.htm and http//www.xs4all.nl/~kspaink/cos/mpoulter/worst/andre3.html and

http://www.ronthenut.org/courts.htm and http://www.rodi.8m.com/

I ask for your patience in reading this long letter for the underlying matters are complicated, intertwined and involve, as against me, Scientology and its lawyers [including Kendrick Moxon ("Moxon"), Donald R. Wager ("Wager"), Elliot Abelson ("Abelson"), Samuel D. Rosen ("Rosen"), Barbara A. Reeves ("Reeves"), Helena Kobrin ("Kobrin"), Ava Paquette ("Paquette"), etc.] commission of demonstrable and corroborated R.I.C.O. predicate acts, bankruptcy fraud, insurance fraud, frauds upon various courts in various states, blackmail, bribery, solicitation, maintenance and champerty, perjury, use of a third person, illegal wire tapping, obstruction of justice, false criminal reports, false state bar reports and other misconduct too numerous to list. In fact, Scientology’s Abelson’s as well as Moxon & Kobrin’s corroborated felony criminal conduct, hate-filled ideology and agenda, and that of others including former Los Angeles County Criminal Court’s Bar Association President Wager and former Los Angeles Police Department Sergeant Eugene Ingram ("Ingram"), directed exclusively at me, include violations of 18 U.S.C. §§ 1621, 1603, 1503, 1512, 371 2(a), 2(b) (perjury, obstruction of justice, witness and evidence tampering, conspiracy, aiding and abetting and the use of an intermediary). Indeed, oral and written testimony, and corroborating documents include multiple incidents of blackmail, bribery, extortion, witness tampering, perjury, subornation of perjury, wire tapping, obstruction of justice, frauds upon various courts, attorney misrepresentations and lies to various courts, false criminal complaints, false state bar complaints and possible judicial corruption. The evidence trail commences in late 1993, and constitutes an unbroken continuum and R.I.C.O. pattern of criminal, tortious and unethical conduct through to the present day. The recent evidence in one case, the Hurtado v. Berry, is unusually damning because it is corroborated by a lawyer’s testimony/confession (a former Los Angeles County Criminal Courts Bar Association President), over ten different witnesses as well as over sixty different documents - many of which bear Scientology lead lawyer Moxon’s own signature and handwriting. Consequently, I have lost my career, condominium, car, companionship and retirement prospects. I now live on public assistance and charity as I continue my self-defense and search for justice not only for myself, but also for all other victims of Scientology "Fair Game" Policies and Practices.

I urge that you act immediately, before other avoidable atrocities, tragedies and human carnage happen in America and around the world. We have already seen Heaven's Gate, the Branch Davidians and the People’s Temple create mass graves while the government ignored all warnings in the name of the First Amendment, religious freedom and of not provoking poll-impacting attacks from other religious groups and their political lobbyists.

"Much on our minds was the comment to us by an attorney general’s investigator in September, 1978. Referring to the Peoples Temple cult: ‘We knew all about them before they went down to Guyana, but nobody cared enough to do anything.’ " emphasis added --- Dave Mitchell, Cathy Mitchell and Richard Ofshe, The Light on Synanon, p.299.

Moxon commenced his California legal career after a 264-page stipulation and related documents, between the U.S. Department of Justice and the Church of Scientology, named him as an unindicted co-conspirator in the largest ever known criminal infiltration and burglary of the United States Federal Government. This was part of the Church of Scientology’s "Operation Snow White." The massive June 8, 1977, FBI raids upon the Church of Scientology yielded thousands of documents linking the Church to organized crimes. http://www.raids.org/ In addition, the FBI raids exposed the frame-up of journalist Paulette Cooper who had written The Scandal of Scientology. She was indicted by a New York grand jury after Church of Scientology covert agents stole her stationary with her fingerprints on it, mailed themselves a bomb threat, and brought the letter to the FBI. But for the FBI raids the Church’s frame-up of Paulette Cooper would have been successful and she would have likely served time in federal prison. There are other similar examples, such as the former Mayor of Clearwater, Fl., Gabe Cazares who was the victim of a Scientology staged "hit and run" in Washington, DC as well as that of Tom Padgett of Kentucky who recently spent 35 days in solitary confinement as a result of "lost" court papers involving Scientology in a hotly contested child custody case. Another recent Church attempted frame-up involved former deputy Church leader Jesse Prince who was exonerated by a Florida jury. http://www.lisatrust.net/legal/Prince/about.html

As recently as 1989, and contrary to express representations to the IRS, Scientology maintained "Operation Snow White" within the OSA Network. CSI/OSA is the covert operations department of the para-military Church of Scientology. Their very large covert operations group is "Department 20 ("Existence") on the Scientology "Org Board". The Scientology "Org Board" is a seven division and 21-department template detailing "all of the actions encompassed by the [Scientology] organization." The Guardian's Office ("GO") was Department 20 before the 1977 FBI raids on the Church of Scientology. See generally, United States v. Hubbard, 474 F. Supp. 64 (1979); United States v. Kattar, 840 F 2d 118, 125 (1^st Cir. 1988). Indeed, Department 20’s legal budget exceeded $40M per annum in the early 1990’s. The current Department 20 (OSA/CSI) U.S. taxpayer subsidized (tax-exempt) investigation, intimidation, "psycho-terrorism" and litigation budget could easily be double that amount.

Ironically, Moxon and I were admitted to the California State Bar on the very same day in 1987. I had previously been admitted to law practice in New York, Australia and New Zealand and had worked for a New York law firm in London, England. Moxon had been previously admitted to practice in the State of Virginia, after his role in the unprecedented and massive Church of Scientology "Operation Snow White" infiltration and burglaries of the many U.S. government departments that were accidentally discovered in 1977. The Scientology burglaries included the Department of the Treasury, the Internal Revenue Service and the Department of Justice. In that regard, Moxon had submitted forged handwriting exemplars to the FBI as part of a Scientology attempt to obstruct justice. See 1980 documents http://www.lisatrust.net/legal.htm and http:members.tripod.com/cic_ops/posts/court.txt and http://www.raids.org/

In 1991, Moxon and I crossed swords for the very first time. My then employer, Lewis, D’Amato, Brisbois & Bisgaard ("Lewis, D’Amato"), my mentor, David B. Parker, and I were retained to successfully defend Century City (Los Angeles) lawyer Joseph A. Yanny in two breach of fiduciary duty actions that his former client, the Church of Scientology, had filed. In part, the cases related to the mysterious 1986 death of Scientology founder L. Ron Hubbard and the subsequent Miscavige-ordered "concentration camp" internment of perceived leadership threats such as Anne Broeker, Vicki Azneran, Robert Vaughan Young, Stacy Brooks-Young and Jesse Prince.

Seemingly, Annie Broeker still remains interned at the Hemet "Gold" base. Vicki Aznaran escaped with the assistance of a local Indian tribe and sought help from former Scientology lawyer Joseph Yanny. During the retaliatory Church of Scientology v. Yanny litigation, Yanny testified that he stopped representing the Church of Scientology when it requested him to engage in criminal conduct against opposing counsel. Indeed, former church leader Vicki Aznaran has stated "[Scientology] is a criminal organization day in and day out." http://www.freezone.de/english/timetrack/data/cct_3_data-sources.htm Doc.14 (Yanny Decl.) and http://www.freezone.org/timetrack/1997.htm and http://www.lermanet.com/cos/yanny.html and http://www.home.earthlink.net/deathoflrh/FACTnet-death.html

Later, I became involved in one of eight lawsuits that Scientology filed against former L. Ron Hubbard aide Gerry Armstrong. Eventually, Armstrong had to seek refuge from the Scientology litigation juggernaut in Canada. Indeed, there is a lengthening list of people who have had to flee from America’s Scientology corrupted courts and law enforcement. These people include: former Hubbard Archivist Gerald Armstrong; former Hubbard "scripture" co-author David Mayo; Keith Henson and Werner Erhard (the founder of the Scientology influenced "EST" and "The Forum" cults). Scientology has announced that Werner Erhard may now return to the United States. However, Erhard has reportedly said that he is too terrified of Scientology to do so. Last year, Scientology attorney Abelson advised me that Scientology "…wants [me] back in New Zealand where [my] talents will be better appreciated." However, I refuse to allow Scientology "Fair Game" Policies and Practices to terrorize me out my adopted country; one to which I have pledged my loyalty and patriotism.

In 1993, I led a winning team of Lewis, D’Amato lawyers in Church of Scientology International v. Fishman and Geertz ("Fishman-Geertz"). Fishman-Geertz was a defamation case in U.S. District Court. It involved Time Magazine statements that the Church of Scientology was involved in instructions to commit financial fraud, murder and suicide. Time article on-line at http://www-2cs.cmu.edu/~dst/fishman/time-behar.html and http://www.angelfire.com/scifi/Scientology/A_World_Without.html (Appendix 1) and http://home.online.no/~heldal/CoS/archive/time910605.html

We produced overwhelming evidence that those statements were true and/or substantially true. In fact, there was testimony that Moxon and Ingram had been involved in instructions to murder opposing San Francisco area counsel, Ford Greene, as well as the President of the Cult Awareness Network ("CAN") and her daughter in Chicago, IL. Steps in furtherance of this conspiracy to murder were taken. There was also testimony that Moxon had been involved in the drowning of Los Angeles County Superior Court Judge Swearinger’s dog, Duke, during Wollersheim v. Church of Scientology, 212 Cal. App. 3^{r d} 872 (1989). Judge Swearinger later stated that he had refused to let this ["psycho terror"] event affect his handling of the Wollersheim I trial. Subsequently, Moxon was involved in five more Scientology lawsuits against Wollersheim. Church of Scientology v. Wollersheim, 42 Cal.App.4^th 628, 648-649 (1996).

The Church of Scientology also unsuccessfully sued Time Magazine itself for alleging the so-called religion to be, in reality, "a ruthless global scam." Two months ago, the U.S. Supreme Court refused to reverse the granting of a summary judgment motion dismissing the entire Scientology defamation case against Time-Warner Inc. Church of Scientology v. Time-Warner Inc., 00-1683. http://www.supremecourtus.gov/

It is curious and should be noted that CNN, which employs celebrity Scientologist Greta Van Susteren, never mentions Scientology or Time’s victory. However, despite spending at least ten million dollars in legal fees, Time-Warner said that it refused to be "…intimidated by the church’s apparently limitless legal recourses." Those "limitless legal recourses" are the primary fund-raising function of the Church of Scientology’s fully tax-exempt International Association of Scientologists ("IAS") to which most Scientologists must belong. In essence, the IAS aggressively raises funds for the Church of Scientology’s campaign of war, vengeance and hate against humanity. L. Ron Hubbard’s own writings demonstrate his hatred of humanity. Those hate-filled writings are among the Church of Scientology’s "sacred" scriptures. http://www.galacticfederation.homeip.net/admissions.html

A further example is a Hubbard "sacred" scripture on the establishment of concentration camps to deal with those who stand in the way of Hubbard’s global totalitarian goals:

"It is not necessary to produce a world of clears in order to have a reasonable and worthwhile social order; it is only necessary to delete those individuals who range from 2.0 down, either by processing them enough to get their tone scale above the 2.0 line…or simply quarantining them from the society." emphasis added --- L. Ron Hubbard, The Science of Survival, p. 157

During the Fishman-Geertz case, the Church of Scientology business-trade secret protected "scriptures" were filed in court and later published on the Internet. http://www.xs4all.nl/~kspaink/fishman/index2.html and http://www.ex-cult.org/Groups/Scientology/fishman.html What followed is colloquially known as "The Church of Scientology v. The Net." It involved what Australian David Gerard has described as:"... Copyright terrorism - frivolous lawsuits (unwinnable, but designed to ruin the respondent financially), threats of such lawsuits and even raiding people’s homes and seizing their actual computers to obtain the information thereon. This is designed to intimidate others from questioning or criticizing the Church of Scientology in any way."

See generally: http://www.lermanet.com/ and http://www.factnet.org/ and http://www2.thecia.net/users/rnewman/scientology/scientology/home.html and http://www2.thecia.net/users/rnewman/scientology/media/home.html and http://www.-2.cs.edu/~dst/Secrets/index.html

Scientology voluntarily dismissed the Fishman-Geertz case on the eve of trial. Scientology openly blamed me for its retreat and defeat in the Fishman-Geertz case and the Internet publication of its secret scriptures (OT I - OT VIII), which cost approximately $400,000 for Church of Scientology adherents to study in their entirety. Indeed, many ex-Scientologists have spent over a million-dollars to receive these Church of Scientology "scientifically proven" courses, auditing and processing only to reach the top of the Church of Scientology’s "Bridge To Total Freedom" and find that there is nothing there! Consequently, many of them have left after concluding that these are matters of fraud and not of faith. Of course, such "fixed donations" for purported self-improvement courses, and dangerous in sauna "purification" treatments, are now fully tax deductible. The Church of Scientology's Form 1023 misrepresented to the Federal Government that it provides free "processing" to staffers ("volunteers" earning approximately $50 per week) who cannot afford to pay such vast sums of money for "total freedom". However, the Church’s Form 1023 did not add the fact that should such staffers ever wish to leave the Church of Scientology, they must first reimburse the Church for the entire cost of such "free processing" as "free-loader debt." Sea Org staffers earn approximately $50 per week and their "freeloader debt" can exceed hundreds of thousands of dollars. This is an example of a Church of Scientology "sacred scripture" which is described as telling an "acceptable truth." For a brief overview of the Church of Scientology’s tax-exempt and tax-deductible religious "Bridge To Total Freedom" see http://www.lermanet.com/cos/pattinson1.htm paras. 277-283 and http://www.scientology-kills.org/Alien_Tales/alien_tales.htm and http://www.-2.cs.edu/~dst/Secrets/index.html and http://www.mystae.com/streams/gnosis/otiii.html ("The Confidential Doctrine of OT III") and http://www.lermanet.com/cos/exhibita.html ("OT III").

During the Fishman-Geertz case, Scientology retained Moxon and his investigator Eugene Ingram ("Ingram") to "investigate" me. An http://google.com/ search of the names Moxon and Ingram and Eugene Ingram and Kendrick Moxon is particularly chilling. U.S. District Court Judge Harry Hupp, the trial judge, told the Church of Scientology lawyers to stop investigating opposing defense counsel as part of their prosecution of the Church of Scientology v. Fishman-Geertz case. They did not. Scientology’s judicially recognized "Fair Game" Policies and Practices provide, among other things, that anyone impeding Scientology can be, "… tricked, sued, or lied to or destroyed." Elsewhere secret Church of Scientology scripture states that, "… when we want someone ‘haunted’ we investigate."

See http://www.lermanet.com/cos/pattinson1.htm paras. 144 –207 and "Scientology’s Private Investigators," Examples of IRS sanctioned "charitable activity," http;//web.tampabay.rr.com/sp/PI.html and "Scientology’s Private Investigators" http://www.primenet.com/~lippard/pis.html See also: Church of Scientology v. Wollersheim, 42 Cal. App 4^th 628,648-649 (1996); Hart v. Cult Awareness Network, 13 Cal.App. 4^th 777 (1993); Church of Scientology v. Armstrong, 232 Cal.App.3d1060, 1067 (1991); Wollersheim v. Church of Scientology, 212 Cal.App.872, 888-891 (1989); Christofferson v. Church of Scientology, 57 Ore.App.203 (1983); Allard v. Church of Scientology, 58 Cal.App.3d 439, 443n.1 (1976).

The Church of Scientology International, Moxon and Ingram have each testified that their "investigation" of me led to Ingram’s traveling to New York City and preparing a declaration for signature on May 5, 1994, by my former acquaintance Robert Cipriano ("Cipriano"). Cipriano has testified repeatedly that his signature on this document was extorted. This First Cipriano Declaration, under penalty of perjury, falsely stated that during one six-month period in 1984, I had supposedly been involved in acts of pedophilia with 40-60 teenagers and was associated in the activities of one Andrew Crispo, who was involved in a grisly and sensational 1985 murder. Crispo’s friend, Bernard Le Geros, was sentenced to life imprisonment for the murder. Ingram visited Le Geros in a New York prison and obtained another declaration falsely alleging that I was associated with Crispo as well as being involved in numerous other major despicable criminal activities. I was not acquainted with either Crispo or Le Geros. Ingram also obtained three other declarations containing false and defamatory materials. Scientology published these in what they call "dead agent" packs, which Moxon’s investigators use for the purposes of "Black Propaganda" during what the Scientology enterprise terms "Noisy Investigations." See http://www.lermanet.com/cos/pattinson1.htm paras.169, 181,188

Scientology OSA NW Order 15 defines "Black Propaganda" as, "… a covert communication of false data intended to injure, impede or destroy the life of another person…usually issued from a false or removed source from the actual instigator."

http://www.ezlink.com/~perry/Co$/OSANWO/15.htm or http://www.xs4all.nl/~johanw/CoS/black-propaganda.txt.

Indeed, in PR Series 18 Church of Scientology staffers are directed to invent whatever they wish to allege. Significantly, as recently as October 9, 2001, the Moxon & Kobrin law office wrote to a Netherlands resident threatening to enforce the Church of Scientology’s copyrights in connection with the very terms "Dead Agenting" and "Targets Defense" activities used by Moxon & Kobrin in their "investigations" and "handling" of regular opposing counsel such as I. http://www.xtdnet.nl/paul/scientology/xtendednet9octo1email.html

The seditious contents of the "Targets Defense" document that the Moxon & Kobrin October 9, 2001, letter refers to include the "vital targets" of, "T1 Depopularizing the enemy to a point of total obliteration; T2 Taking over the control or allegiance of the heads or the proprietors of all news media; T3 Taking over the control or allegiance of key political figures; T4 Taking over the control or allegiance of those who monitor international finance and shifting them to a less precarious finance standard." emphasis added

http://www.lermanet.com/cos/pattinson1.htm para.175

Another Church of Scientology written policy directs Scientology lawyers to use the courts to harass and ruin people rather than to win.

"The purpose of the law suit is to harass and discourage rather than to win. The law can be used very easily to harass, and enough harassment on somebody who is simply on the thin edge anyway…would generally be sufficient to cause his professional decease. If possible, of course, ruin utterly." emphasis added

See http://www.lermanet.com/cos/pattinson1.htm para.150

In mid-March 1955, Hubbard wrote:

"The DEFENSE of anything is UNTENABLE. The only way to defend anything is to attack … it is an entirely moral duty to be punitive against outsiders who would stop the progress of this [Scientology] civilization." emphasis added.

See http://www.lermanet.com/cos/pattinson1.htm para.148 L. Ron Hubbard’s "Manual of Justice", a "sacred" Church of Scientology "scripture" is even more explicit: "People attack Scientology: I never forget it, always even the score …overt investigation of someone or something attacking us by an outside detective agency should be done more often and hang the expense … Hire them and damn the costs when you need to…the critic will sure shudder into silence … [Scientology] punishment is gruesome to see sometimes and in this instance there are people hiding in terror on Earth because they attacked us. There are men dead because they attacked us - for instance Dr. Joe Winter. There are men bankrupt because they attacked us - Purcell, Ridgeway, Seppos." emphasis added.

See http://www.lermanet.com/cos/pattinson1.htm para.149

In another "sacred" Church of Scientology "scripture" entitled "Critics of Scientology" it is written and mandated:

"Now get this as a technical fact, not a hopeful idea. Every time we have investigated the background of a critic of Scientology, we have found crimes for which that person or group could be imprisoned under existing law. We do not find critics of Scientology who do not have criminal pasts. Over and over we prove this. Politician A stands up on his hind legs in Parliament and brays for a condemnation of Scientology. When we look him over we find crimes-embezzled funds, moral lapses, a thirst for young boys - sordid stuff … We are slowly teaching the unholy a lesson. It is as follows: we are not a law enforcement agency but WE WILL BECOME INTERESTED IN THE CRIMES OF PEOPLE WHO SEEK TO STOP US. IF YOU OPPOSE SCIENTOLOGY WE PROMPTLY LOOK UP- AND WILL FIND AND EXPOSE -YOUR CRIMES. IF YOU LEAVE US ALONE WE WILL LEAVE YOU ALONE. IT’S VERY SIMPLE. EVEN A FOOL CAN GRASP THAT. AND DON’T UNDERESTIMATE OUR ABILITY TO CARRY IT OUT … THOSE WHO TRY TO MAKE OUR LIFE HARD FOR US ARE AT ONCE AT RISK." emphasis added.

See http://www.lermanet.com/cos/pattinson1.htm para. 181

Former Los Angeles Deputy District Attorney, and former Gambino mafia family attorney, Elliot Abelson [http://www.operatingthetan.com/abelson/abelson-porn.txt], Moxon and his law partner, Helena Kobrin, and Scientology executives including Rinder, engaged in extensive correspondence with me, confirming the nature, scope and purported purpose of their ("haunting") "investigation" of me. Scientology front groups and shills published the First Cipriano Declaration, and other Moxon/Ingram procured perjury on the Internet where the false statements remain today. Ingram and other Scientology-Moxon-Abelson retained "investigators" personally disseminated the highly defamatory material to my family, friends, acquaintances, law partners, clients, law firm’s clients, judges, politicians and public officials. This was part of what Scientology Policy and Practice calls a "Noisy Investigation." http://www.lermanet.com/cos/pattinson1.htm para.168, 184, 188, 202. The Scientology policies and practices regarding, for example, "Black Propaganda", "Dead Agenting" and "Noisy Investigations" are specific Scientology scriptures forming part of a larger group of Scientology scripture generically and collectively known as the Church of Scientology "Fair Game" Policies and Practices.

On Sunday, 23 May 1999, German Scientology News wrote: (Subject: Re: OSA info published by German security agency [OSA is Scientology's private intelligence agency. HUBBARD is the founder of Scientology. SO stands for Scientology Organization.] )

"II. The Precursor Intelligence Organizations

There is hardly a means which Scientology does not use in the persecution of its critics and the achievement of it goals, and it is often not satisfied until it has brought about the complete destruction of its critics. This is documented not only by the instructions quoted from HUBBARD, but there are also numerous examples of this from real life. In accordance with the dogma established by HUBBARD that all people who publicly oppose Scientology are 'criminals' and 'suppressive persons,' the Scientology founder's numerous Policy Letters and instructions in regard to the intended special treatment of this group of people become more significant. The selection of the means in use ranges from open or covert data collection for psycho-terrorism, spying, false accusations and charges, slander (‘black propaganda’), theft, and burglary to actual attacks and - at least this was claimed by one former American OSA agent in sworn testimony in 1994 - attempted murder.

HUBBARD assessed the number of so-called 'suppressive persons’ at ‘about 2.5% of the population.’ Another 17.5% were named ‘Potential Trouble Sources’ (PTS); these are people who are under the influence of ‘suppressives.’

HUBBARD further explained: "There are certain characteristics and mental attitudes which cause about 20% of a race to oppose violently any betterment activity or group. (comment: by that is meant the SO) ... As they only comprise 20% of the population and as only 2 1/2% of this 20% are truly dangerous, we see that with a very small amount of effort we could considerably better the state of society. ... Similarly, if society were to recognize this personality type as a sick being, as they now isolate people with smallpox, both social and economic recoveries could occur. The persecution practices of the Scientology intelligence organizations are known by the name of the 'Fair Game' law, which is reminiscent, for good reason, of the Middle Ages practice of "outlaw" declarations. In 1965, HUBBARD stated that he released three Policy Letters which referred to this 'Fair Game' law. Although the Policy

Letters were cancelled, that is, withdrawn from public view, they continued to be used by the SO intelligence service as training policy. In 1980, leading Scientology functionaries had to admit in court that the 'Fair Game' law had never really been done away with. Several high-ranking American former SO members, who themselves were victims of the 'Fair Game' law, independently verified that this law continued to be a binding policy of the SO.

The Policy Letter of 21 October 1968, which allegedly cancelled the 'Fair Game' law, is worded suitably ambiguously. This policy stated that the practice of declaring people ‘Fair Game’ will cease. ‘Fair Game’ may not appear on any Ethics Order. It caused bad public relations. This delicate wording is also interpreted to mean that only the practice of declaring shall cease; the practice of treating someone as 'Fair Game' is not the issue, and is apparently not meant. Just the opposite: it was explicitly emphasized that this Policy Letter did not cancel 'any policy on the treatment or handling of SPs.' The SO continues to issue its so-called 'SP Declares.' Among the Policy Letters which were not affected by the content of this cancellation was one from 18 October, 1967, on 'Penalties for Lower Conditions,' which clearly described the merciless persecution of SPs. Under the ethics condition of 'enemy,' it literally states:

'SP Order. (comment: 'Suppressive Person Declaration'). Fair game. May be deprived of property or injured by any means by any Scientologist without any discipline of the Scientologist. May be tricked, sued or lied to or destroyed.'

In sworn testimony of 22 March 1976, HUBBARD asserted the opposite of this statement, that he had never had the intention to authorize illegal activity or attacks against anyone with the 'Fair Game' policy. The opposite turned out to be the case: Scientology's criminal endeavors occurred over the following years under the direction of the world wide intelligence 'Guardian Office' (GO), which followed the footsteps of its predecessor organization a short time later, when it assumed the 'ethically' legitimized persecution of apostates and Scientology opponents to a previously unknown degree. [After the 1977 FBI raids on the GO it was renamed OSA]." emphasis added

http://cisar.org/trn1050.htm "Scientology’s Intelligence Service."

On May 26, 2001, a St. Petersburg Times editorial expressed its views upon such "fully tax-exempt" religious policies and practices:

"An attorney for the Church of Scientology defended the practice of using private investigators to protect the organization from people who ‘harass it’. Interestingly, Scientology doesn’t want to be criticized or harassed, but it does not hesitate to harass and intimidate others. Again and again in recent years, Scientology has claimed that it has reformed, that it no longer engages in the kind of underhanded or illegal behavior and smear tactics that have earned it a sorry reputation around the globe. Again and again, Scientology has argued that it is a religion and should be treated like any other church. But again and again, stories surface that set Scientology apart. Not only does it have a penchant for secrecy, it will spend virtually unlimited time and money on pursuing setting up and bringing down its critics. That’s not like any church we know." emphasis added

http://www.sptimes.com/News/052601/news_pf/Opinion/Church_behavior.html

False State Bar complaints were filed against me in New York and California. Ingram; Beverly Hills lawyer, Jeffrey Steinberger; and California State Assemblyman, Steven Baldwin, called a major media press conference demanding an LAPD investigation into the false threat that I allegedly posed to the youth of Los Angeles. Ingram and his puppet, California Assemblyman Baldwin, also falsely alleged that I was associated with other prominent Los Angeles "pedophiles" because of my support for an annual fundraiser to benefit the education of gay and lesbian youth. A number of sitting judges and numerous respected attorneys were also present at this fundraiser. Ingram then complained to the LAPD and the Los Angeles Unified School District that 19 of these fundraiser attendees were convicted sex offenders - based solely upon their having names similar to those in the state register of sex offenders. Ingram even warned the Los Angeles Unified School District to watch for me. Incredibly, Moxon unsuccessfully claimed in Berry v. Cipriano that some of this activity meant that Cal. C.C.P Section 425.16 (the "SLAPP" statute) and Cal. Civil Code 47 (b) (the litigation privilege) applied to protect their conduct from civil liability because it was in furtherance of free speech and the right to petition for redress of grievances! Moxon’s defeat on this issue led Barbara Reeves, Esq., of the Los Angeles office of the national law firm of Paul, Hastings, Janofsky & Walker to disqualify Judge Hiroshige for bias, for being a "lame judge," as explained below.

Commencing in 1994, in excess of ten false State Bar complaints, and at least three false criminal complaints were unsuccessfully filed against me by Moxon and other Scientology shills. Defamatory leaflets were distributed in a three-block radius of my then home and the false allegations delivered to foreign governments with which I dealt professionally. Consequently, I experienced the pain of losing most of my friends and acquaintances, including judges, lawyers, other professionals and business people. Ingram visited and disturbed a number of law offices and businesses just to ensure that it was fully understood that associating with me might be prejudicial to employment, career and other relationships. Obviously, these terrorized people were only fair weather friends, but that is irrelevant in this context.

Moxon, Abelson and Ingram also "investigated" my then senior partners at Lewis, D’Amato. On January 5, 1995, Abelson visited Robert F. (‘Bob") Lewis, Esq., "laid out the evidence" from the "investigation" and very quickly extorted Bob Lewis into agreeing that as a Lewis, D’Amato partner I would never handle another case involving Scientology; that the AIG insurance group and Lewis, D’Amato would withdraw from the remaining federal court Fishman-Geertz case matters that primarily involved continuing unsuccessful Scientology efforts to have the Fishman-Geertz case files permanently sealed from public view; that a secret settlement agreement would be entered into transferring Dr. Geertz’s files to Bob Lewis personally and then re-transferring them to a public storage facility near the Scientology-Moxon-Abelson offices. It must be remembered that Bob Lewis was also Dr. Geertz’s lawyer and Dr. Geertz had given specific instructions not to enter into any settlement with the Church of Scientology; additionally, his insurance policy included a "consent to settlement" provision. The Scientology-Lewis secret settlement agreement also provided that only Scientology representatives and Bob Lewis would have access to the stolen Fishman-Geertz files. In addition, it was agreed that Lewis, D’Amato would not oppose the sealing of the Fishman-Geertz court files. Previously, the Ninth Circuit Court of Appeals had twice upheld Judge Hupp’s denial of Scientology motions to seal the record. Moreover, Dr. Geertz had specifically instructed the Lewis, D’Amato law firm to oppose any further attempts to seal the court’s files. However, the Fishman-Geertz court files have been "temporarily sealed" ever since the 1995, Scientology, Abelson, Lewis, D’Amato and AIG chicanery. Scientology still attempts, using tax-exempt funds for very expensive copyright lawyers, to prevent citizens from accessing the same materials, some of which it provides to others who make tax-exempt payments aggregating over $500,000. However, all of the same materials are freely available on the Internet, which has been the Church of Scientology’s own Vietnam, in relation to its attempts to manipulate and litigate its own public relations and image. http://slashdot.org/article.pl?sid=01/03/16/1256226&mode=thread Also see The Wall Street Journal article http://www.rickross.com/reference/Scieno54.html

Consequently, Steven Fishman and Dr. Geertz were forced to file their malicious prosecution case against Scientology and Abelson without their new attorney, Ford Greene, Esq., having the benefit of Dr. Geertz’s files or court records from the underlying dismissed defamation case. Having stolen the client files, secreted the court record, silenced me (the client’s immediate attorney) and concealed the true facts, Abelson was mistakenly named as a defendant. Later, Abelson sued Greene for malicious prosecution and forced a settlement in Abelson’s favor. Dr. Geertz filed a California State Bar complaint regarding the secret settlement, theft and concealment of his attorney client files. The State Bar dismissed the complaint at intake because these opposing counsel did not owe a professional duty to Dr. Geertz! However, the opposing counsel had breached numerous other statutes and ethics rules. The opposing counsel were former LA County Bar President John ("Jack") Quinn, Moxon, Drescher and Abelson. No action has been taken against Bob Lewis or the other involved attorneys directly and supposedly representing Dr. Geertz’s interests. However, all of these attorney and "religious" crimes and frauds were rendered useless by the Internet where many of the sealed files were and are posted.

OSA chief Rinder and Abelson visited me in my Lewis, D’Amato office to unsuccessfully obtain my confirmation that I would never litigate against the Church of Scientology enterprise again. Subsequently, Bob Lewis clarified that the unethical restriction only applied while I remained at the Lewis, D’Amato law firm. The Fishman-Geertz malicious prosecution case was defended by a battalion of Scientology attorneys including Abelson, former L.A. County Bar President Jack Quinn (who was also involved in other aspects of this), Moxon and Gerald Feffer of Washington, D.C.’s Williams & Connolly. Los Angeles County Superior Court Judge Alexander Williams, III, (an acquaintance of Feffer) dismissed the case on summary judgment. See http://www-2.cs.cmu.edu/~dst/Fishman/index.html and http://www.exposingscientology.cjb.net/ (click on reposted classics and see #s 2, 16-20 and 91) At the time, no one knew of the subsequently revealed disqualifying connections between Judge Williams and the Church of Scientology Office of Special Affairs.

As introduced and noted above, in 1991, and shortly before all of this chicanery, Miscavige, Rathbun, Moxon and Williams & Connolly’s Feffer (reputably with total U.S. DoJ access) had instantly convinced the then IRS Commissioner to suddenly reverse the IRS/FBI twenty-year denial of IRS § 501(c)(3) status and finally grant Scientology tax-exempt status in 1993. The U.S. Supreme Court had recently affirmed the IRS position denying Scientology section 501(c)(3) status. Hernandez v. Commissioner, 490 U.S. 680 (1988). A surprise Scientology visit to the IRS Commissioner personally, and the sudden IRS tax status change and billion dollar windfall to the Church of Scientology and certain of its leaders, was upon the express representation and condition that Scientology did not and would not engage in such litigation and related conduct as I am now describing. The Clinton Administration and Church of Scientology Tax Closing Agreement was supposed to remain secret and confidential for reasons of "national security." However, and in truth, the Church of Scientology poses a clear and present danger to our national security. See generally the internal IRS report on the secret IRS Closing Agreement. Also: http://www.lisatrust.net/NYT-030997.htm and http://www.lisatrust.net/archives/forbes9-4-00.html and http://www.lisatrust.net/Media/sptimes-standup.htm and http://www.lisatrust.net/LAT-6D.htm and http://www.xenu.net/archive/IRS/index.html and http://www.lermanet.com/cos/taxanalysts/secretagreement.txt

Soon after the signing of the Closing Agreement for the secret IRS-Scientology tax deal, very senior Scientology officials (direct subordinates to Church of Scientology leader "Captain" Miscavige) visited a number of former Scientology senior officials who had sworn expert witness testimony that was filed in Fishman-Geertz. Three of these former Scientology officials have testified that they were unsuccessfully subjected to great pressure, intimidation and bribes of over $200,000 each to recant their testimony and to sign false declarations alleging that I had suborned and created perjury for filing in Fishman-Geertz. The testimony established Scientology fraud upon the IRS

because it contradicted material responses and misrepresentations by the Scientology enterprise to the IRS. Those material [mis]representations were part of the official basis for the IRS’s one billion dollar tax relief (waiver) package to the Church of Scientology and several of its senior leaders including "Captain" Miscavige.

The three former high-level Scientologists who had held senior management positions in the cult refused to join this blatant criminal conspiracy, obstruction of justice and tax fraud being perpetrated by Scientology and its lawyers. Even Wager, on or about November 21, 1994, met with one of the former Scientology senior executives, expressly in connection with me. Significantly, Abelson had some brief success of his own. A former Scientology covert intelligence operative had been given a grueling 17 - day deposition in Fishman-Geertz while being guarded by off-duty LAPD officers. Many months later, Abelson flew the former Scientology operative from Florida to Los Angeles and, after two days of "persuasion" and suborning of perjury, video-taped the witness and him reading and agreeing to a recant of the witness’ Fishman-Geertz deposition testimony. One month later, the witness reconsidered and testified as to what had just happened with Abelson.

Scientology then obtained Federal court search and seizure orders and, accompanied by armed U.S. Marshals, raided the homes of a number of Scientology critics. They had posted copies of the Fishman Declaration to the Internet. These critics’ computers, records, books and papers were seized with the assistance of the armed U.S. Justice Department marshals. Subsequently, several U.S. District Court judges opined that the Scientology lawyers had misled them. The Washington Post was unsuccessfully sued by Scientology, for publishing part of the Fishman Declaration. The Post had successfully broken Scientology’s blockade of the Fishman-Geertz federal courthouse files. My then senior law partner Bob Lewis refused The Washington Post’s request for my active involvement in the litigation. Bob Lewis also refused another defendant’s request that I represent it even with the benefit of a one million-dollar insurance policy.

The express reason was the Fishman-Geertz [no longer] secret settlement agreement between Bob Lewis, his other client AIG and Scientology and the unwritten agreement that I would not ever again represent a party adverse to the Church of Scientology.

I was professionally and personally outraged by all of these lawyers’ felonies, torts and ethical violations and I refused to be cowed in this manner. I resigned from the Lewis, D’Amato partnership and became a partner at Musick, Peeler & Garrett, a very fine law firm for which I have the utmost enduring professional respect and personal gratitude. I was able to accept defense retentions in a number of other cases filed by Scientology in connection with the alleged unlawful dissemination of its religious "trade secrets," unpublished copyrights, picketing and other expressions of free speech. See generally: http://www.lermanet.com/cos/hensonmotion.htm Scientology responded with Samuel D. Rosen ("Rosen"), Esq., of the New York office of Paul, Hastings, Janofsky & Walker ("Paul, Hastings"). In Denver, Colorado, under despicable circumstances of which he had no personal knowledge, Rosen obtained the first ever monetary sanctions order against me.

Meanwhile, Moxon had also filed over 30 baseless and unsuccessful "cookie-cutter" lawsuits against the Cult Awareness Network ("CAN") in a successful Church of Scientology effort to bankrupt fellow IRS section 501(c)(3) tax exempt CAN and to take it over as a Church of Scientology (false) "front group." It was the "Bowles & Moxon Plan 100." It would seem to contradict the statutory requirements that the "fully tax-exempt" Church of Scientology be acting for the charitable, religious, scientific or educational benefit of the public. Certainly, it flouted numerous criminal and ethical restrictions that applied to the Bowles & Moxon lawyers irrespective of their status as practicing Scientologists. To complete the sinister Scientology program, Moxon had solicited the representation of another cult’s victim, Jason Scott, and filed Scott v. Ross in the State of Washington. At Moxon’s request, the trial judge excluded all references to Scientology’s involvement in the case and Moxon obtained a $4M judgment against CAN, which had referred Jason Scott’s frantic mother to a deprogrammer in a largely successful attempt to recover her three teenage sons from their then cult’s mental manipulators. Instead of compromising and settling the judgment for Scott, Moxon pursued his other and undisclosed client’s (Scientology’s) agenda, refused any settlement, and drove CAN into bankruptcy. Moxon, using Scientology shills, then purchased CAN’s name brand assets from the CAN bankruptcy estate. Scientology now sinisterly and stealthily operates CAN with its terrifying ability to intimidate and silence families and others seeking to communicate with, or rescue, loved ones from Scientology or another cult. For similar reasons, the seizure of the old CAN files, and the pending Church of Scientology access to the Lisa McPherson Trust files, represent the illegitimate use and abuse of the U.S. legal system to acquire "intelligence" information as to the identity and contact information of the family and friends of victims of the Church of Scientology, which then uses its thuggish lawyers, sleazy private investigators and "goons" to "shudder" such persons into submissive silence and "terror."

When Jason Scott finally realized Moxon’s multiple layers of undisclosed non-waivable conflicts of interest, and Moxon’s real loyalty and conflicting agenda, Jason Scott fired Moxon and retained me. This provoked a storm of national media attention. Immediately, the Abelson, Moxon & Kobrin worldwide "investigation" of me became

even more feverish. Ingram and Scientology’s other "investigators" conducted even more "interviews" concerning me. Visits were made to Musick, Peeler & Garrett corporate clients, former Musick, Peeler attorneys and non-profit organization clients that were then required to provide their tax-exempt organization financial records to the Moxon, Abelson and Church of Scientology "investigators." Their "investigators" even spent days in the Musick, Peeler reception area, unsuccessfully insisting that they had packages and photographs of me, which had to be personally shown to and discussed with my senior partners. Understandably, and obviously reluctantly, Musick, Peeler & Garrett gave me a choice; either leave Scientology-related litigation or leave the firm (in which instance they would and did provide me with very generous assistance and support).

I believed that at least a few lawyers had to remain available to provide representation against what a number of European governments have labeled Scientology’s "psycho-terrorism;" criminal fraud; human rights abuses; totalitarian agenda; and litigation abuse. I had seen many lawyers and law firms terrorized out of Scientology-related matters by despicable, illegal and unethical conduct perpetrated by highly paid major law firms and private investigators. I had the specialist knowledge and experience to litigate against Scientology. As importantly, I have always been a single man and have no dependents. Consequently, I did not have the vulnerabilities and terror pressure points of a spouse, significant other, children or their need for financial support.

In other words, I was not as susceptible to a quiet "compromise" as a lawyer with a spouse, children and all of the heinous opportunities those relationships posed to a "psycho-terror" group such as the Church of Scientology and its covert operatives, "out-law"yers and "investigators" engaging in defamation and character assassination by innuendo. At least, I thought so at the time!

Scientology’s Internet shills were goading me to sue if, as I claimed, the First Cipriano Declaration and related allegations were indeed false. Reluctantly, I chose to leave the Musick, Peeler law firm and continue to represent the victims of the Scientology-Moxon & Kobrin-Abelson litigation abuse and terror investigation enterprise. I also decided to sue, for defamation and abuse of process, because of what I had just learned regarding the First Cipriano Declaration. In February 1998, I formed my own solo practice and then merged with three young lawyers to form Berry, Lewis, Scali & Stojkovic.

In April 1998, I again agreed to represent Palo Alto computer engineer Keith Henson. This time it was in the statutory damages phase of Scientology "unpublished" copyright case. The copyrighted document (NOTS 34) evidenced clearly the continuing unlawful practice of medicine by Church of Scientology contrary to a specific 1977 F.D.A. injunction. It was the first of ten lawsuits that the Church of Scientology, Moxon & Kobrin, Abelson and/or Paul, Hastings, Janofsky & Walker filed, maintained or instigated against Mr. Henson at a cost that must exceed five million dollars and now involves the Canadian Government and soon the U.S. State Department. In referring to the earlier grant of summary judgment against the then pro per Henson, and the subsequent statutory damages of $75,000, a Wall Street Journal editorial opined that Northern District Court judge Ronald M. Whyte had "turned copyright law on its head." http://www.rickross.com/reference/Scn54.html

See, Wired News article:http//wired.0com/news/politics/0,1283,12355,00.html and http://xenu.ca/index.html and http://www.operatingthetan.com/

At the conclusion of the Henson I case involving a single alleged copyright infringement, Rosen, Moxon & Kobrin and Eric Lieberman of New York’s Rabinowitz, Standard, Krinsky & Leiberman unsuccessfully sought a contempt order and sanctions of $900,000 against me, claiming that my three week solo court appearance on behalf of Mr. Henson (while charging a flat $5,000 fee) had required Scientology’s use of 28 opposing lawyers from a number of different national law firms at a cost of over $2M. The California Court of Appeals has opined that such aggressive litigation tactics by the Church of Scientology can "have constitutional implications." Church of Scientology v. Wollersheim, 42 Cal. App. 4^th 628, 649 (1996).

Consequently, in 1998, the Church of Scientology forced Mr. Henson into a no-asset bankruptcy where it continues to engage in intensive litigation which, at times, appears to be costing at least $100,000 per month and involves very expensive appearances by New York copyright lawyer Samuel D. Rosen, Esq., of the giant Paul, Hastings law firm, in endless judgment debtor examinations in the San Jose area and interference in attempts by Mr. Henson to find employment. As you will read below, Mr. Henson has now been granted "refugee status" in Canada while his asylum application is being processed.

Five months earlier, in December 1997, and while still a partner at the Musick, Peeler law firm, I had learned for the first time of the whereabouts of the elusive Robert Cipriano and the identity of certain anonymous distributors of the highly defamatory First Cipriano Declaration. They included Scientologists Rev. Glenn Barton, Isadore Chait, Russell Shaw and Donna Casselman. They were all active in the unincorporated and elusive CAN Reform Group, a Scientology "front group" involved in the CAN takeover. Later, there would be testimony and documents, much of it corroborated, that the following had then occurred.

Moxon & Kobrin, through Ingram, had a "plant" in the Musick, Peeler law firm (later I would learn of at least two other Scientology "plants" in my office and home). Moxon and Ingram obtained a draft of my Berry v. Cipriano complaint from their "plant" within Musick, Peeler. Moxon and Ingram then located Cipriano before he moved in a final, but unsuccessful, attempt to avoid service of my defamation lawsuit. Ingram met with Cipriano in Santa Barbara County and had him travel to Los Angeles to meet with Moxon at the Moxon & Kobrin false-front law office. They showed Cipriano the stolen draft Berry v. Cipriano defamation complaint and told him they would provide free representation if I filed. When I did file, Cipriano wanted to immediately settle with me on the reasonable written terms I proposed. However, late on a Saturday night, Moxon and Ingram intervened. Moxon and Ingram raced to the home of Cipriano and his then girlfriend, unsuccessfully offered her benefits, successfully solicited the legal representation of Cipriano, "relocated" him and later promised him up to $750,000 in financial benefits if he co-operated to maintain the perjuries they had earlier extorted for the First Cipriano Declaration. Ingram, Moxon and Abelson knew of my long-time statements that when I finally found and sued Cipriano they would also be defendants as well as being important material witnesses.

Whether as witnesses or defendants, applicable conflict of interest rules precluded Moxon, Kobrin and Abelson from also being the lawyers for any of the other defendants. However, Cipriano was the only "evidence" of "truth/substantial truth" that they had. They had to keep him committing perjury. Later, as Cipriano’s lawyer, and without disclosure or waiver of the multiple and non-waivable conflicts of interest, Moxon would fallaciously and dishonestly misrepresent to the Berry v. Cipriano court that none of my 40-60 alleged victims were "locatable" as they were, "…teenage hustlers who had all died of AIDS." Because of the manner in which the then known facts emerged, I filed three different defamation law suits at three different times, all of which were deemed related and consolidated for all purposes (collectively, "the Berry cases"). Scientology and Moxon assembled a formidable and very expensive army of national and international law firms to defend the consolidated Berry cases. In essence, the Berry cases alleged that the First Cipriano and related Declarations were defamatory, part of an abuse of legal process and had caused me damage. Rev. Barton did not even wait for the lawsuit to be served on him. The Scientology litigation juggernaut launched yet another litigation blitzkrieg.

The Scientology litigation juggernaut included: Paul, Hastings, Janofsky & Walker’s Los Angeles and New York offices (Samuel D. Rosen, Barbara Reeves, Michael Turrill and Brad Pauley); Williams & Connolly of Washington, DC (Gerald Feffer); Zuckert, Scoutt & Rasenberger of Washington, DC (Monique Yingling); Wasserman, Comden & Casselman of Los Angeles (Gary Soter); Simke Chodos of Los Angeles (David Chodos and James Martin); William T. Drescher of Los Angeles; Elliot Abelson of Los Angeles and, of course, Moxon & Kobrin of Los Angeles. Rosen was then billing at $490/hour giving, as he stated, "No discounts to anyone."

The Berry cases were randomly assigned to Los Angeles County Superior Court Judge Hon. Ernest M. Hiroshige. He denied Cipriano’s demurrer and C.C.P.§ 425.16 "SLAPP" motion. On behalf of Scientologist Barton, Rosen and Reeves of Paul, Hastings filed a C.C.P.§ 170.6 peremptory challenge for bias. The Berry v. Cipriano/Barton cases were reassigned and then reassigned again to Hon. Alexander Williams III. Later, Cipriano testified that at the time (June 1998) Moxon informed him that Judge Hiroshige was "a lame judge" and Judge Williams was a "friend of Scientology." The Paul, Hastings law firm, had just hired Judge Williams’ most recent clerk and Judge Williams was socially acquainted with Ms. Reeves’ husband an Appellate Court Justice. New York attorney Rosen improperly persuaded Judge Williams that there was still discovery priority in California, and that I should be precluded from taking any depositions until Scientology-Cipriano’s deposition of me was concluded. Eight months and twelve deposition days later Moxon, Rosen and Reeves claimed my deposition in Berry v. Cipriano, et. al., was still incomplete. Judge Williams denied my C.C.P. § 460.5 (c) preferential defamation trial setting request (ironically, " … because the law disfavors claims for defamation.")! Initially, Judge Williams refused to handle discovery matters himself. He was "too busy." He appointed a retired California Supreme Court justice and required me to pay nearly $9, 000 for the retired judge's initial handling of discovery matters. Eventually, I persuaded Judge Williams that I could not afford such a non-consensual and judicially enforced litigation expense.

In addition, Judge Williams ordered that I could not assert any privacy objections, I had to "…just sit there and take it", and that I had to concurrently, comprehensively and repeatedly respond to: over 2,000 form interrogatories; 289 special interrogatories; 121 Requests for Admission (each accompanied by 5 interrogatories, totaling an additional 605 interrogatories); 532 Requests for Authentication; 316 categories of document demands (responding documents to be carefully organized in accordance therewith). Judge Williams ordered this overwhelming discovery both during and after the twelve days of my uncompleted deposition. At the same time, Judge Williams refused me the opportunity to take any depositions of any defendant. However, he allowed Defendants to take the depositions of at least 12 other persons and noticed the depositions of over 30 others. Scientology and Lewis, D’Amato successfully obstructed the addition (Civ.Code § 1714.10) of Moxon and Abelson as defendants in the case by unsuccessfully removing Berry v. Miscavige to Federal Court (speciously arguing it was related to the pending

Pattinson v. Church of Scientology case where I was plaintiff’s counsel). A former Scientologist and Paul, Hastings employee even testified about certain Paul, Hastings’ attorneys paying $300 for the backdating of certain court documents. Judge Williams was unmoved. During the travesty, Judge Williams commented that because he was a former federal criminal prosecutor the Paul, Hastings lawyers knew much more about the rules of civil procedure than he. One of the Berry v. Cipriano defendants, Mathilde Krim, Ph.D., entered into an early settlement.

In November 1998, Christian J. Scali, one of my then two law partners, volunteered assurances he would never allow the Scientology lawyers’ litigation blitzkrieg to drive him and my other law partner, J. Stephen Lewis, out of the case and out of our fledgling law firm. Then, in late November 1998, on the day of the expiration of the statute of limitations, Scali actually chose not to file a previously prepared summons and complaint against the Los Angeles Police Department ("LAPD.") It arose from Moxon’s "investigator" Edwin Richardson, and then LAPD Scientology "chaplain" Barton, who had physically jumped and battered Scientology critic Keith Henson and falsely arrested him. Proper pre-filing notice had been given. I was furious when several weeks later I enquired of Christian J. Scali, Esq., and learned that the Henson v. LAPD and Barton complaint had not been timely filed as I had instructed. Subsequently, Cipriano testified that at this time he personally observed Moxon directly communicating with Lewis and Scali regarding their subsequent announcement made at the end of December 1998, that they were dissolving the firm and withdrawing from my legal representation with only four days’ notice to me. Later, you will read of further Scientology, Moxon, Kobrin and Paquette ethical wrongdoing in connection with my former partner J. Stephen Lewis.

The Scientology lawyers had scheduled a blistering, daily schedule of depositions, discovery responses and motions for the following thirty days of January 1999. I requested discovery extensions. Judge Williams acknowledged that ordinarily discovery extensions would be granted in these circumstances. However, he denied my requests because I was, "… no ordinary attorney." His faint flattery damned me. Now without my two counsel, I stood alone, and with responsibilities to other clients in other matters. As was intended, I was finally overwhelmed by such tactics, discovery deception and duplication. I was unable to respond to the many hundreds of form interrogatories to the satisfaction of either Moxon or Judge Williams. In early February 1999, on behalf of Berry v. Barton defendant Scientologist Chait, Moxon successfully moved for terminating and monetary sanctions as a discovery sanction in connection with these many hundreds of form interrogatories and related requests. Curiously, Judge Williams expressly invited every other defendant to immediately file similar motions. Barbara Reeves of Paul, Hastings then proceeded to try and schedule the deposition of Michael Hurtado whose involvement and perjury is explained below. Barbara Reeves represented that Hurtado would corroborate Cipriano’s testimony. I knew that to be building perjury upon perjury, to bolster and buttress even more perjury. Ms. Reeves was unmoved by Hurtado’s own voicemail message denial of his subsequently verified allegations. Consequently, I had no practical alternative but to make a strategic withdrawal from Judge Williams’ courtroom. In late February 1999, I immediately and voluntarily dismissed all defendants without prejudice. At least that preserved my ability to return to court at another time and under changed circumstances. Six months later, I would learn that Judge Williams’ fiancée actually worked for defendant Church of Scientology International ("CSI"). Concurrently, CSI also employed Moxon & Kobrin as well as all of the other Scientology lawyers!

Around the same time, the District Court remanded Berry v. Miscavige, Church of Scientology International back to Judge Williams and the consolidated Berry cases that I was voluntarily dismissing in the impossible circumstances explained above. Lewis, D’Amato entered into a settlement in Berry v. Miscavige. Obviously, continuing to prosecute Berry v. Miscavige (and moving to add Moxon and Abelson as Cal. Civ.Code § 1714.10 defendants) was also not viable for me at that time. Consequently, over the course of several days in late February 1999, Barbara Reeves, of the giant Paul, Hastings, Janofsky & Walker law firm, successfully prevailed upon me to also voluntarily dismiss the Berry v. Miscavige, Church of Scientology International case, without prejudice, as a prerequisite to serious settlement discussions. I reluctantly agreed. No serious settlement discussions followed. However, Barbara Reeves obtained a $28,000 prevailing party costs order on behalf of Scientology defendant Barton which, in accordance with the Church of Scientology "Fair Game" Policies and Practices, is still being used to "utterly destroy" me and to limit my right of free speech. Indeed, Moxon, Kobrin and Paquette recently used the related Barton real estate lien to force my condominium into a foreclosure and intentionally deny themselves and my other lien holders (particularly the IRS and Cal. State Franchise Tax Board) the benefits and equity of a favorable pre-foreclosure sale. Scientology’s benefit was continued prosecution of Barton’s non-payment of sanctions claims before the California State Bar and the U.S. Bankruptcy Court (Berry v. Barton), and continuing regular judgment debtor examinations of me (Scientology "Intelligence Operations.").

As a leader of the unincorporated secretive Scientology-front CAN Reform Group, Rev. Glenn Barton had participated in the publication and dissemination of the First Cipriano Declaration. Barton co-defendant, Shaw, executed a mutual general release. He agreed to testify at a future deposition. His counsel represented that Scientologist Shaw’s testimony would be that he merely maintained a certain Internet website as a transmission conduit for the other Scientology defendants’ website content, including the First Cipriano Declaration, which he did not control. In late March 1999, Lieberman and Moxon refiled their motion for Rule 11 sanctions in Pattinson v. Miscavige and on April 5, 1999 Moxon filed Hurtado v. Berry as explained below.

First, allow me to return to the Pattinson I case that was filed in May 1998. Pattinson was a former 25-year Scientology adherent who had paid over $500,000 in "fixed donations", in order to receive the most advanced of Scientology’s "scientifically proven" trade-secret religious "processing". http://www.lermanet.com/cos/pattinson1.htm paras. 277-283. However, he was not cured of his problem or "ruin" as had been (mis)represented by Scientology® and Dianetics® representatives. The Federal and subsequent State Pattinson pleadings were carefully crafted and drafted within the facts, causes of action and opinions of the controlling California Supreme Court authority. http://www.lermanet.com/cos/demurrer.htm . Four of the fraud claims were specifically pleaded within the facts and decisions of other Scientology cases decided against the church in California and upheld upon appeal. Thus, there were strong grounds for the application of collateral estoppel type principles. However, Moxon, Kobrin and Paquette immediately obstructed, delayed and diverted the Pattinson case. They solicited and filed a retaliatory lawsuit, Revelliere v. Pattinson.

Twelve years earlier, in Paris, France, Revelliere loaned Pattinson some money, which was partially repaid. They had been out of touch with each other for five years. Scientology senior staffer Reveillere claimed that he had not known of Pattinson’s whereabouts until Pattinson sued the Church of Scientology and certain of its staff members, etc. Revelliere, living and working for Scientology in Copenhagen, Denmark, speciously claimed that after learning of Pattinson’s whereabouts he then located Moxon, Kobrin and Paquette and retained them to immediately sue Pattinson. The retaliatory and obviously solicited Revelliere v. Pattinson lawsuit was an action on an unpaid note (to which there are few defenses). Revelliere v. Pattinson was filed in Orange County Superior Court, quickly proceeded through very abusive, collateral discovery and onto summary judgment. With the Reveillere v. Pattinson judgment in hand, Moxon proceeded to harass Pattinson regarding his ability to finance and obtain money for the litigation of Pattison v. Church of Scientology International. In addition, Moxon & Kobrin unleashed their "chief investigator" Ingram to conduct the usual defamatory and "haunting" "investigation" of Pattinson pursuant to the Scientology "Fair Game" Policies and Practices. See http://www.lermanet.com/cos/dedicated.htm

Meanwhile, Rosen and Lieberman from New York appeared in the California Central Federal District Pattinson I case along with Barbara Reeves, Moxon & Kobrin and other Scientology counsel. Again, Rosen and Reeves successfully claimed discovery priority, engaged in a never-ending deposition of Pattinson, and obstructed any discovery by the plaintiff, Pattinson. For the next nine months they engaged in such incessant pleading battles that no answers were ever filed. However, Pattinson was required to participate in days of harrasive depositions by Rosen and Moxon.

In March 1999, after the voluntary dismissal of the Berry cases, and after arguing that the dismissals were indicative of meritless and bad faith litigation by me, Moxon and Leiberman successfully filed a Rule 11 sanctions motion against me in Pattinson v. Miscavige ("Pattinson I"). Significantly, the Moxon Rule 11 and Section 1927 order was expressly limited to only one defendant in Pattinson I (Moxon) and the allegations (contained in one single paragraph) asserted against him. In essence, that contrary to the Church’s express and material 1991-1993 [mis]representations to the I.R.S. as to its new and reformed character and conduct, Scientology was still engaging in criminal activity, and it was doing so through stipulated, unindicted co-conspirator Moxon. Some of Moxon’s judicially recognized and stipulated criminal activity is set forth above and in cases such as U.S. v. Hubbard, 474 F.Supp.64 (1979), where Moxon was stipulated by the Church of Scientology to be an unindicted co-conspirator in the 264 page Department of Justice - Scientology Stipulation Of Evidence. See generally: United States v. Kattar, 840 F2d 118,125,126 (1^st Cir.1988); U.S. v. Kember, USDC Dist.Col. Criminal No. 78-401(2) & (3). http://www.members.tripod.com/cic_ops/posts/court.txt

It is also clear and convincing, from the subsequent Cipriano confession and testimony summarized below, that at the very same time as Moxon was inside the Federal Court obtaining Rule 11 sanctions against me for alleging that Moxon was involved in criminal conduct on behalf of the Church of Scientology, Moxon was outside the same federal courtroom, concurrently engaged in major felony crimes with CSI/OSA, Abelson, Ingram and Wager. In other words, at the very same time as he was swearing to the Federal Court in the Pattinson I case that he was not engaged in criminal conduct and successfully obtaining Rule 11 sanctions against me, Moxon was simultaneously committing serious felony crimes against me, as plaintiff Pattinson’s lawyer, together with CSI/OSA, Wager, Abelson, Ingram, Cipriano, Apodaca and Hurtado. In addition, Moxon obtained the Rule 11 and Section 1927, $28,000 costs order against me with an express finding that it was reasonable for him/CSI/OSA to incur the expense of retaining New York counsel Lieberman to defend him in Los Angeles against such a "frivolous" and "vexatious" allegation. The next month, in May 1999, Moxon-CSI then used this Rule 11 order as principal factual support in filing for Judge Williams’ August 20, 1999, "vexatious litigant" order against me.

On March 19, 1999, the month before Judge Snyder granted the CSI-Moxon Rule 11 motion, and after constant carping by the Scientology attorneys, the Pattinson I case was voluntarily dismissed in Federal Court and simultaneously refiled in State Court (Pattinson II) without any federal question causes of action (R.I.C.O., etc.). Church of Spiritual Technology ("CST") was one of the Pattinson II case defendants. CST is a little known Scientology corporation operating from a post office box. On the basis of my knowledge, experience, investigation and research into Church of Scientology matters, I honestly believed CST to be a necessary and proper party for both liability and judgment collection purposes, alter ego purposes, and for numerous matters relevant to the two Pattinson cases. I was one of the relatively few who knew that CST was the very apex of the Scientology corporate pyramid and that it was the ultimate owner of all of the most valuable Scientology property, the Scientology intellectual property registrations.

http://clever.net/webworks/veritas/cst/copygrab.htm

CST’s ownership is vested in four very low profile individuals: Sherman D. Lenske, Esq., of Woodland Hills, CA; former IRS Assistant Commissioner Meade Emory, Esq., of Lane, Powell, Spears, Lubersky LLP of Seattle, WA; Leon C. Misterek, Esq., of Kirkland, WA; and Scientology central reserves money man Lyman D. Spurlock. Curiously, CST Special Trustee Meade Emory, Esq., was the Assistant IRS Commissioner at the very same time in the 1970's that Moxon and the Church of Scientology were committing the largest ever known criminal infiltration and massive burglary of the IRS and numerous other U.S. Federal Government Departments. This was part of Scientology’s "Operation Snow White". CST Special Trustee Lyman Spurlock is an accountant and the only Scientologist among the four who it appears may be the actual owners of the corporations and Churches of Scientology. Alternatively, and contrary to applicable law, one person (David Miscavige) is the only person who ultimately controls and owns the entire churches and corporations of Scientology. Additional support for this conclusion is the documentation indicating that some single person has the sole and absolute power to dismiss all of the trustees and directors, etc., of CST and reappoint new ones. Consequently and contrary to applicable law, this single individual, probably David Miscavige, has total control and ownership of all of the approximately 150 tax-exempt "corporations" and Churches of Scientology,. The Scientology organizational hierarchy, and its associated maze of mirrors, is examined in detail in Church of Spiritual Technology v. United States, 26 Cl.Ct. 713,730-732 (1992), and the various Church of Scientology cases cited therein. It is even more interestingly examined and dissected on the Internet. For example see, http://www.nots.org/cst.htm and http://clever.net/webworks/veritas and

http://wpxx02.toxi.uni-wuerzburg.de/~cowen/essays/corporate.html

CST filed a spurious but successful C.C.P.§ 425.16 "SLAPP" motion in the State Court Pattinson II case. The "SLAPP" statute permits dismissal of lawsuits filed to chill the exercise First Amendment and other constitutional rights. CST had retained expensive Washington, D.C., tax counsel (Monique Yingling, Esq.) and several expensive New York counsel (Paul, Hastings’ Samuel D. Rosen and veteran Scientology attorney Lieberman) to appear with Kendrick L. Moxon, Esq., on the motion. The "SLAPP" motion relied heavily and expressly upon the August 20, 1999, vexatious litigant order of Judge Williams in the Berry consolidated cases and Judge Snyder’s July 16, 1999, ruling in the Federal Court Pattinson case. Under C.C.P.§ 425.16(c) a "… prevailing party… shall be entitled to recover his or her attorney’s fees and costs." On November 16, 1999, attorneys’ fees and costs were awarded against my client, Pattinson, and me in the amount of $12,500.

For the sake of clarity, I now return to the Berry cases. One year earlier, in late 1998, in the Berry v. Cipriano consolidated cases, Judge Williams had ordered me and my prior law firms to produce all malpractice insurance policies extending back many years. Interestingly, I was the plaintiff. There were no cross-complaints to merit such an unusual order in those circumstances. On November 25, 1998, on day twelve of my deposition, and stripped of any "privacy objections," Moxon and Rosen questioned me about my prior sexual relationship with subsequent pro bono client, 24-year-old Michael Hurtado. Rosen demanded his address. At the time, I was Hurtado’s counsel of record in an active pending criminal case in Santa Monica Court. Immediately, Moxon, Abelson and Ingram started interviews of Hurtado’s extended family based on information obtained by Rosen in deposition of me and also found in the Santa Monica court files. Less than one month later, in December 1998, Abelson told then LA County Criminal Courts Bar Association President Wager about Hurtado, who himself had not met with any of the Scientology attorneys or investigators at that time. Wager immediately opened his Hurtado client file and began billing in connection with his representation of Hurtado. Wager had never met Hurtado and Hurtado was still my client. Hurtado himself would not be solicited and become Wager’s client for another six weeks! Wager then spoke with Ingram about Hurtado at least three times. Wager understood that Ingram was working for Scientology because Ingram told him he was working for Moxon at the time. Moxon, acting as Scientology's counsel, also contacted Wager regarding Hurtado. Indeed, Wager had at least six Hurtado related conversations with Moxon before he ever met Hurtado. In mid-January 1999, Ingram first appeared at the Hurtado’s home, once again unannounced and uninvited. Ana and Vanessa Hurtado (Michael’s mother and sister) have testified that Ingram told them that I was a "child molester." Ingram said he was investigating me from New York and, "… had been investigating Berry [me] for a long, long time." Ingram suggested to the Hurtados that I had taken "advantage" of the clearly adult Michael.

When Ingram showed them the videotape of my November 25, 1998, deposition testimony in the Berry cases, regarding my sexual relationship with Michael Hurtado, Mrs. Hurtado did not want to see it, or look at it, and she refused to keep it, saying, "Forget it. Take it." The entire Hurtado family had long believed that homosexual conduct was inappropriate. Yet, Ingram showed them the First Cipriano Declaration, as well as multiple other documents. Ingram wanted the Hurtados "… to see a lawyer because of this matter," and suggested that there was a possibility that there could be a civil suit against me. Within a very few days, Ingram took Ana, Miguel (Michael’s father), Vanessa Hurtado and a Cuban writer friend of theirs to see then Los Angeles County Criminal Courts Bar Association President Wager at Wager's office. There they were also introduced to lead Church of Scientology in-house lawyer Moxon. Both Ana and Vanessa Hurtado thought the purpose of the meeting was to find a lawyer who would represent Michael in a sexual molestation lawsuit against me. Neither of them knew about the then pending drug paraphernalia charges against Michael on which I was then still his counsel of record and which became the basis of a specious claim that I had engaged in legal malpractice. Surprisingly, no one in the Hurtado family discussed my relationship with him with Michael Hurtado himself at any time before they attended the meeting with Wager and Moxon and agreed to participate in the lawsuit being planned, by at least Moxon and Wager, for filin