27 Aug 2000

Keith Henson <hkhenson@netcom3.netcom.com>

H. Keith Henson
P.O. Box 60012
Palo Alto, CA 94306
(650) 325-7533

                      SUPERIOR COURT OF CALIFORNIA
                         COUNTY OF LOS ANGELES

MICHAEL HURTADO                    )  Case No. BC208227
                                   )
        Plaintiff,                 )    EX PARTE
                                   )    MOTION FOR LIMITED
        v.                         )    PROTECTIVE ORDER
                                   )
GRAHAM E. BERRY                    )
        Defendant.                 )
____________________________________     DATE: N/A
                                         DEPT: 10


    Witness H. Keith Henson applies to this court for a
limited protective order regarding a video tape deposition now
set for Sept. 15, 2000 in Los Angeles in the above case.

    Witness requests that the deposition question be
limited to his first hand knowledge of events involving Hurtado,
and that wide ranging questions outside of this area not be
permitted.  Also that any material in this deposition not be
permitted to be used in other Scientology cases against me.

    Witness and witness's wife have been abusively deposed
a number of times by the law firm of Moxon and Kobrin, within
the past two months in a bankruptcy action for several hours
(about 500 pages of deposition).  This is in keeping with a
Scientology policy to use the law as a weapon against critics.

      I have recently been protesting Scientology policies
or practices which resulted in the deaths of two young women at
their desert compound near Hemet, California,
(www.parishioner.org/osah for one) and to punish me for this
political protest, they are using the excuse that I know
something in this case against my lawyer, Graham Berry to get
yet another deposition on top of the 40 hours or more I have
already have subjected to.

    A brief look at the documents to be produced confirms
this.  They are asking for communications between me and my
lawyer Mr. Berry, Mr. Cipriano, a person who I have met only
once, but who was used by Scientology to attack Mr. Berry, Jane
Scott and Scott Meyer who worked for Graham as paralegals, and
Edith Mattthai, Mr. Berry's lawyer in this case.  Note that
there is *no* request for communications with Mr. Hurtado.

    While I have not finished an exhaustive search for
communications which are requested, the attached are typical,
and involve public matters or legal filings in this or other
related cases.

    There is one class of communications which I will not
divulge under attorney/client or law enforcement exceptions
unless ordered to do so by this court.  (I will provide this
material for in camera examination if requested.)  These are
substantive matters having to do with law enforcement agencies
and their activities.  The Federal bankruptcy court has exempted
me from answering questions of this nature.  The court may
obtain a fax of this ruling from my bankruptcy attorney Stan
Zlottoff, 408-287-1313.

    Where there are statements of fact in this motion,
they are submitted under penalty of perjury.


Respectfully submitted,
H. Keith Henson Sept. 26, 2000