Found this on a fax machine...
Law offices of GRAHAM E, BERRY
ONE Wilshire Boulevard
TWENTY - FIRST FLOOR
LOS ANGELES, CALIFORNIA @OOt7-~383
VIA TELECOPIER (213)487-5335
Kendnck L Moxon? Esq.
Your former client, Mr. Robert Cipriano, has requested that I assist him in certain limited ways in connection with certain matters. Accordingly, he has asked me to write you and advise that he stil] has had no response to his several requests for his files and documents Unless Mr. Cipriano receives the entirety of his files and documents immediately, he will retain counsel to file suit, and take such other appropriate steps, in order to protect his interest in his property now being held by you and contrary to his requests and instructions. I urge you to avoid this by communicating with me immediately for the purpose of making arrangements for the immediate delivery of Mr. Cipriano's property to him.
Very truly yours,
GRAHAM E. BERRY
CC: Robert ]. Cipriano
Three and a half hours later Graham got this back.
MOXON & KOBRIN
Attornys At LAW
3055 Wilshire BOULEVARD
September 3, 1999
Re; Robert Cipriano
Dear Mr Berry;
I am in reccipt of your letter dated today reguarding Robert Cipriano, in which you purport to represent him "in certain limited ways in connection with certain matters."
You must be confused. You recandy filed a declaration purportedly signed by Mr Cipriano stating that you do not and have never represented him, and you filed a similar declaration yourself. I can only assume that the prior latter you sent to me purporting to be from Mr Cipriano were forgeries. In any event I will not now select which purported communications to believe and which to reject when a former client's rights are at stake - particularly from a man who previously threatened in writing to "ruin" him.
As to Mr Cipriano allegedly relaying a message to me through you, I cannot accept the truth of that representation for several reasons.
- First, he called me last week stating that you tried to kidnap him and that through the intercession of the police he was able to leave your apartment. This was the last communication I have had from Mr Ciprinno directly
- Second, you have a confict of interest that cannot be waived, and I have no interest in attempting to deal with you with respect to a former client-- particularly one who I represented successibily against you.
- Third, when I saw you at your bankruptcy examination just two days ago, you were obviously under the influence, and asserted a Fifth Amendment right not to incriminate yourself with respect to the use of illegal drugs.
September 3, 1999
- Fourth, last month you were assessed $28,000 for the filing of "bad faith" claims against me; in the past two weeks, you have bee found to be a Vexatious litigant with respect to your ittigation against Mr. Cipriano, among others and to have filed a SLAPP action against other parties; on August l7th you admitted to making false statements under penalty of perjury in your bankruptcy filings; on September 2, 1999, you admitted to bankruptcy fraud in your 2004 examination
- Fifth, today your utterly nonsequitur writ of mandate was denied by the court of appeal, upholding the vexatious litigant ruling against you.
- Sixth, even your letter itself is suspect. It is on stationary for an office address from which you were evicted months ago
In light of the above facts and cirtunuznstanccs, I must assume that your letter does not reflect the truth.
If Mr, Cipriano wishes to contact me, I'm certain he will do so himself
Kendrick L. Moxon.
cc: Gary Soter