Henson on Berry communications. -- State Bar

28 Jul 2001

hkhenson@home.com (Keith Henson)

I am not sure I expect anyone to read this through, it read more like a phone book than anything else. If you know the players, it makes more sense. But it is important for it to be on google groups and indexed. Of course, if they did respond to this thing, the firm of Moxon and Kobrin, not to mention corporate scientology, would be our of business and lots of people in jail.

Keith Henson

*************

THE STATE BAR COURT
OF THE STATE OF CALIFORNIA
HEARING DEPARTMENT - LOS ANGELES

In the Matter ofGRAHAM EDWARD BERRYNo.128503A Member of the State Bar ))))))))))))))))) Case No.: 99-0-12791ATTACHMENT A TO SUBPOENA DUCES TECUM ISSUES BY PARTY- RESPONDENT GRAHAM E.BERRY AND BEING HIS FIRST DEMAND TO PRODUCE DOCUMENTS, RECORDS, BOOKS OR THINGS DIRECTED AT THE CUSTODIAN (s) OF DOCUMENTS OF MOXON & KOBRIN, et al. (Numbered 1- -).

RESPONDENT, GRAHAM EDWARD BERRY ("Berry"), hereby propounds his Demand to Produce Documents, Records, Books or Things, Set No. One, to the Custodian (s) of Documents of Moxon & Kobrin, Kendrick Moxon, Helena Kobrin and Ava Paquette ("You" as defined hereunder). This Request for Documents, Records, Books or Things is propounded, inter alia, pursuant to C.C.P. зз 94, 1011(a) - 1013 (a), 1987.3, 2016 to 2031 (specifically з 2020 (d)), Cal. Evidence Code з 1560 (e) and Rules 151 to 187 of the Rules of Procedure of the State Bar of California. Inspection and copying of the documents, records, books and things produced in response to this request shall take place on August 14, 2001 at 10:00 a.m. at the offices of Moxon & Kobrin, 3055 Wilshire Boulevard, Suite 900, Los Angeles, CA 90010, or as may be noticed by amended notice and/or a letter agreement signed by both the propounding and responding party (s); e.g. to adopt the provisions of C.C.P. 2020 (d) (4).

snip boilerplate

REQUEST FOR PRODUCTION OF DOCUMENTS 1. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to the [job description] Full A-I hat write-up for your [job] post and posts including but not limited to your post, per HCO PL 22 September 1970, Personnel Series 9, Org Series 4, An Urgent Important and Starrate PL, HATS. Per this policy, this will include the purpose of your post, its relative position on the org board, your hat write-up, your hat checksheet and pack, a copy of the org board of the portion of the org to which your post belongs, a flow chart showing what particles are received by your post and what changes your post is expected to make in them and to where your post routes them, your terminal (s), the product of your post, and the statistic of your post (and all statistics counted for your post) as well as the statistic of the section, department and division to which your post belongs, success stories written after completing (comp'ing) your hat and any cramming orders related to your hat [job].

2. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to Moxon & Kobrin's relationship to all or any of the corporations and churches of Scientology including but not limited to the org board and/or command chart (s) that show your relationship (s) to the Church of Scientology, OSA Int, OSA US, CST, RTC, CSI, "Flag", ASI, CMO Int. and the Watch Dog Committee.

3. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to your commitment first, foremost and above all else and all other oaths of allegiance, loyalty and/or duty to serve the Church of Scientology and the policies and goals of L.Ron Hubbard as set forth in his writings (for example only, HCO Bulletins and Policy Letters) including but not limited to your billion year contract, your duty and commitment to the policies and goals of L.Ron Hubbard, the Church of Scientology, a clear planet, a world without war, crime and insanity and a planet where scientology has got ethics in including but not limited to Scientology's War on Psychiatry .

4. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology],whether or not initiated from, by or involving the Church of Scientology, that refer or relate to commendations or awards you have received in connection with your [job] post (s).

5. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to bonuses you have received as a result of any [good result] "up" statistics, as well as any other forms of monetary compensation over and above standard pay that resulted as a reward for doing your job.

6. All documents and communications which refer or relate to and/or comprise LRH Policies, Flag Orders (FOs), Central Bureaux Orders (CBOs), Scientology Policy Directives (SPDs), Executive Directives (Eds), CLOs, LRH advices and orders, Guardian Orders, OSA Orders, orders (directly or via command lines) from Captain David Miscavige, Norman Starkey, Marty Rathbun, Michael Rinder, Kurt Weiland, Heber Jentzsch or any CST, RTC or OSA seniors or members, and any other publications or issues that define and/or discuss the duties, responsibilities and/or functions of Moxon & Kobrin and/or your duties, responsibilities and/or functions.

7. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to the command chart (s) on which the Church of Scientology, CST, the Sea Org, Sea Org Reserves, Ltd., CMO Int., CMO, RTC, BMS, CSI, CSI OSA, the OSA Legal Unit, Moxon & Kobrin, you and/or the Watch Dog Committee are identified.

8. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to Evals, Strategic Plans, Tactical Plans, programs and projects on which you and/or the attorney unit are named or have targets.

9. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to Keith Henson and Riverside District Attorney Grover Trask, Deputy DA Robert Schwarz, Alan C. Oberstein, Gerald Feffer, Samuel D.Rosen, Alternative Resolution Centers and James Harr.

10. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to Moxon's application and documents in support of his request for admission to the California State Bar.

11. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to those two draft declarations, relating to Graham Berry, and presented for execution to Robert Vaughan Young and Stacy Brooks Young in or about July 8-16,1994.)

12. All documents and communications, including but not limited to those that refer or relate to, or concern in any way, Graham Berry and Associates including but not limited to those relating to or mentioning Berry; Lewis, D'Amato, Brisbois & Bisgaard LLP; Musick, Peeler & Garret LLP; Law Offices of Graham E. Berry; Berry, Lewis, Scali & Stojkovic.

13. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to: the CAN Reform Group [and/or any participant in its activities, ops, projects, targets, publications, funding, operations and meetings]; CAN; The 'Bowles & Moxon Plan 100' [to destroy CAN]; Mary Sue Hubbard; Captain David Miscavige; Mark (Marty) Rathbun, Michael (Mike) Rinder; Michael Sutter; Heber Jentzch ; Kurt Weiland; Ken Hoden; Muriel Dufresne; Greg Ryerson; Lisa Goodman; Alan Cartwright; Ken Long; Ed Parkin; Lynn Shipe aka Lyn Shape; Lynn Farny; Michel Revelliere; Aaron Mason; Howie Gutfeld; Ingram Investigations, Eugene Ingram, Joanne Weaton or Wheaton; Russell Andrews, Donald Cooper, Tri State Investigations; Barry Silver, Talon Executive Services; Hank Batterton;Tom Blane; John J.Gaw; Edwin Richardson; Lawrence Heller; Sherman Lenske; Lenske & Lenske; Michael Gerner; Gerner, Donald Wager; Thomas Byrnes, Thomas C. Spring, Gerald A. Feffer; Monique Yingling; Eric Lieberman; John J. Quinn; Samuel Rosen, Barbara Reeves, Michael Terrill, Bradley Pauley; Elliot Abelson; Gerald Chaleff; Gary Soter; David Chodos; William Drescher; of William ; Kendrick Moxon; Helena Kobrin; Sarira Alexander; Laurie Bartilson; Timothy Bowles; Earle Cooley; Bert Fields; Lavelly & Singer; Evan Spiegel; Michael Stoller; Marcello D'Mauro; Jerry Bregman; Lloyd Levinson; Lyman Spurlock, Barry Waterman, Robert Cipriano, Glenn Barton, Donna Casselman, Isadore ("Izzy Chait"), Nancy O'Meara, W. Russell Shaw, Bernard Le Geros, Andrew Crispo, Dennis Cantwell, Wilbur ("Bill Long"), Dr. Mathilde Krim, Danny Fumagali, Laura Terrapin aka Jolie Steckart, Donna Casselman, Robert Lippman, Thomas Gerard Rummelhart,Linda Woolard, Nigel Hunter, Michael ("Mike") Ferris, Phoenix Investigations, Scott Mayer, Jeffrey W. Steinbrenner, Assemblyman Steven Baldwin, Richard Mason, Los Angeles Unified School District, General Counsel's Office of The Los Angeles Unified School District, Dale Reynolds, Richard Davis, Mike or Michael Ferris, Bart Verry, Mark Ortega, Guy White, Citizens Commission for Human Rights (CCHR), Sandee Oglivie, Minutes of meetings where Graham Berry and Associates have been discussed including but not limited to Staff meetings, Advisory Council Meetings, Executive Council Meetings, "Battle Plan" meetings and any meetings of the Board of Directors or Corporate Officers, Day of the Child, Children's Charities of America, Icon Entertainment Group, Donald Snodgrass, Leslie McMillan, Joan Varanelli, Ian Westwood Booth, Michael Hamra, Earthlink, Leslie Lamborn, Dawn Rene Oates, Day of the Child World Concert, Jenny Berosteguy, Eloisa Gonzales, Miguel Hurtado, Ana Marina Hurtado, Jason Whitman, LA Youth Center, Anthony Apodaca, Robert (Bob) and Debbie Sweezy, Detective Petz, Deputy D.A. Paul Turley, Deputy D.A. Norm Wakener, Roy Webb, Professional Management Services, International Association of Scientologists, Erla Hawkins, Mariah Rivera, DA Investigator Kevin Freeth, Wesley Berosteguy, Antoine Hage, MD.

14. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to payments made to or for any and all persons, lawyers, businesses, private investigators, investigators, surveillance personnel and surveillance, in connection with or relating to Graham Berry and Associates.

15. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to payments made to or for, services provided to or for, benefits given/provided to and for, and agreements made with or for or relating to: Vicki Azneran; Richard Azneran; Phoenix Investigations; Garry Scarff; Robert Cipriano; Christine M. Gregos; Accurate Book-keeping Company; Anthony Apodaca; Michael Hurtado; Miguel Hurtado; Day of the Child; J. Stephen Lewis; Christian J. Scali; Danny Fumagali; Laura Terrapin aka Jolie Steckart; Scott Mayer; Roy Webb; Professional Management Services; and any other person or entity in connection with or relating to Graham Berry and Associates.

16. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to the Church of Scientology internal guiding policies, advices, special tech and dispatches relating to Graham Berry and Associates.

17. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to communications with all former employers, colleagues, acquaintances of, and/or any other person/entity, and relating in any manner to Graham Berry and Associates including but not limited to: Vicki Azneran, Richard Azneran, Robert Vaughan Young, Stacy Brooks Young aka Stacy Brooks, Andre Tabayoyan, Garry Scarff, Steven Fishman, Robert F. Lewis, Gordon Calhoun, Jana Lubert, Jerome Spiegelman, Spiegelman & Berry, John Blair, Studio 54, James Kershaw, Peter Mills, John Lauricella, Kim Tudor, Berry & Hoffey, Geoff Brodie, Ruth Gordon, any resident (former to 1989 or current) of 1228 11th Street condominiums, Santa Monica ,CA 90401 and any ( former to 1993 or current) resident of any premises within a three block radius of that address and the owners of any cars leafleted thereabouts, Tristan (Robert) McManaman,Ted Kozak, Marsha George, Frank Keegan, Bill Lloyd, Hon. David Caygil, Angie Tunagdon, Sandt Litchfield, Jacques Howlett, Justin Nobriga, Patricia Nell Warren, Tyler St.Mark, Michael Blaha, Robert Schwartz, Vanessa Tamirez, Robert Barron, David France, Joseph Sonnabend, AIDS Medical Foundation, AMFar, Michael Grantham, Wayne Elias, Steve Tyler, Jamie Schloss, David Amkraut, Douglas Hart, Daniel Garcia, John Durkin, Robert (Rob) Sloane, Lynne Atkins, Ronald J. Palmiere, David Hunt, Nicholas Poshkus, Sam Collins, Robert Krissel, Charles Collier-Wright, Jonathan Canno, Troy Glick, Deputy DA Larry Morrison, Matthew Fitzpatrick, Gary Knight, Paul Middlemiss, John Matthews, Richard Burtt, Nancy Zeltzer, James (Jim ) McIntyre, Joe Lynn, Landmark Insurance Company, American Insurance Group ("AIG"),The Mirror Group, The Daily Mirror, Tony Ortega, New Times LA, George Rush, the New York Daily News, The Daily Journal, The American Lawyer, The National Lawyer, The Washington Post, The New York Times, The St.Petersburg Times, The Star Tabloid, A&E, CNN, Sixty Minutes, Esquire magazine, ARD Network, Los Angeles Times, Channel Nine Los Angeles, Channel 4 Los Angeles, Raymond Benkozcy, Monica Smith, Bill Lloyd, D'Amato & Lynch, David Gibson, Mark Trilling, Steven Gaines, Mark Lemmer, Laura Gomez ( Imperial Bank), Imperial Bank, Glendale Federal Bank, California Federal Bank, Fleet Mortgage Company, ARM Financial Corporation, Washington Mutual, Ford Greene, Joseph De Briyn, Michael Andrunas, Geoffrey Brown, Joel Feldman, Jenny Stevens, Bradley Brook, Rodney Nardi, Peter Reichelt, Brenda Barnes, Brian Any employee of the State Bar of California Office of Chief Trial Counsel, Hon. Keith G. Wisot (Ret.), Tom Hefferman, Frank Nowicki, Nancy Thompson, the Inmate Phone Company, Robert Cephail & Associates, Michael Perry, Daniel Lantz, Lumin-oZ, LLC, Lumin-oZ, Inc., Michael Wech, Paul Strabala , Ursula Caberta, Ida Camburn, Thomas ("Tom") Klemesrud, Grady Ward, Lisa McPherson Trust, Jesse Prince, Mark Bunker, Greg Schulman, Models of Pride, Metropolitan Art Storage, Celeste Downey, Patricia McSweeney, Hons. Ronald Swearinger, James Ideman, Ernest Hiroshige, Manuel Real, Alexander Williams, III, Eagleson, Weissbrodt, Ray Hart, David Doi, Dianne Wayne, Stephen M. Lachs, Margaret Morrow, Christina Snyder, Ernest Robles, Arthur S. Weissbrodt, Robert H. Wallerstein and Ronald Whyte.

18. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to sources of funding for OSA ops or your activities, representation and/or cycles of action against or relating to Graham Berry and/or Associates including but not limited to: the International Association of Scientologists ("IAS"); any World Institute of Scientology Enterprises ("WISE") entity or member (including any documents relating to your membership of WISE and IAS); and any Church of Scientology enitity or member (s ).

19. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to the Church of Scientology International, Moxon, Bowles, Farny and Ingram "investigation" of Graham Berry that commenced in late 1993 and early 1994 including but not limited to all photographs, phone tap logs, audio and video recording machines or devices, and all other related documents, books, records and things.

20. All documents [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to communications with any international, national, federal, state or local government entity, supervisory and /or professional organization (including national security [e.g. the German government Office (s) for the Protection of the Constitution], security, law enforcement entities and their representatives) bar associations and law societies, professional organizations, media, entity or person (s) relating to Graham Berry and Associates.

21. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to the legal and beneficial owners and/or ownership of the Church of Spiritual Technology ("CST"), its principals, trustees, directors, officers, premises, staffers, securities, records, property and assets.

22. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to operational documents on the destruction of Graham Berry, Graham Berry and Associates, the Law Offices of Graham E. Berry and Berry, Lewis, Scali & Stojkovic.

23. All documents and communications that refer or relate to the application and processing of Michael Pattinson's application for permanent residency ("green card") status in the United States.

24. All documents and communications that refer or relate to Moxon's role in the immigration and/or entry of the crew of the Scientology ship Apollo into the United States in 1975 and any other immigrant or worker/employee/volunteer into the United States.

25. All documents and communications that refer or relate to Moxon's role as an unindicted co-conspirator in U.S. v. Hubbard.

26. All documents and communications [and in addition to the definition of documents above, in accordance with the following words meanings, definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology] that refer or relate to Plan (s) for Erlich raid, Lerma raid, Wollersheim raid, FactNet raid, Penny raid.

27. All documents and communications of the Church of Scientology that refer or relate to various Internet nom-de-plumes, including but not limited to nobody @replay.com, nobody@huge.cajones.com, wgert@loop.com, which mention the name Berry or Graham Berry and all internet or newsgroup postings you have made, either under your own name or a nom-de-plume,and/ or in association or supervision of others, and which mention the names Graham and Berry, and/or Cipriano, Hurtado and Apodaca including but not limited to the ARS Bigots Home Page.

28. All documents and of the Church of Scientology that refer or relate to the current location and contact information for Eugene Ingram, Dr.Denk, Heber Jentzch, Pat Broeker, Annie Broeker, former Pinellas County, Fl. Coroner Dr. Joan Wood, Gregory Willardson, Sharon Thomas, Cindy Raymond, Mitchell Hermann, Gerald Bennett Wolfe, Michael Meisner, Brian Andrus, Joe Lisa, Don Alverzo aka Jerry Levin, Bruce Ullman, Herbert Parkhouse, Mary Rezonico, Jimmy Mulligan, Peggy Tyson, Lynn McNeil, Bruce Raymond, Michael Taylor, Michael Baum, Herman Brendel, Charles Parselle and David Mayo.

29. All documents and communications that refer or relate to all motions and requests for sanctions, costs and/or contempt, made by you or any other attorney representing the Church of Scientology and/or any of its members, employees and related entities, against Graham Berry.

30. All documents and communications, including but not limited all transcripts (deposition, hearing and other), that refer or relate to any of the allegations, contentions, defenses and/or causes of action set forth in any of the original or amended complaints, responsive pleadings, discovery requests, discovery responses, motions, dismissals, appeals, submissions to the Court (s) or Special Master/Referee in the consolidated cases principally captioned Berry v. Cipriano, Barton and Miscavige [LASC Case Nos. BC 184 355, BC 186 168,BC 196 402, USDC CD CA Case No. 98, CV 8097 AHM] and Berry v. Rosen [LASC Case No. BS 051330].

31. All documents and communications that refer or relate to Hurtado v. Berry, LASC Case No. 208 227 and USBC CD CA Case No. LA 99-32264 ER/Adv. No. AD 99-02559 ER.

32. All documents and communications that refer or relate to In re Graham E. Berry, USBC CD CA Case No. LA-99-32264 ER and all adversary, motion and collection proceedings filed in connection therewith including, whether in the federal or state courts, including but not limited to Moxon v. Berry [LA 99-32264/Adv. 99- 02615 ER], CSI [Jeavons v. CSI], Barton v. Berry [Adv. 00-2817-ER], Benkozcy v. Berry [USDC LA 99-32264 ER and LASC Case no.99-AO1528], and all purported creditors including but not limited to CSI, Michel Reveillere and Isadore Chait.

33. All documents and communications that refer or relate to the U.S.D.C. and L.A.S.C. cases principally captioned Pattinson v. Miscavige [USDC CD CA Case No. 98-3985 CAS] and Pattinson v. CSI [LASC Case No. BC 207364].

34. All documents and communications that refer or relate to Reveillere v. Pattinson, OCSC Case No. 800981.

35. All documents and communications that refer or relate to the Casey Hill v. Church of Scientology and the Ontario Operation Snow White litigation, in the Dominion of Canada.

36. All documents and communications that refer or relate to Jeavons v. Church of Scientology International, LASC Case No.BC 207363 DATED: July 25, 2001 Respectfully Submitted,

_______________________

Graham E. Berry

PROOF OF PERSONAL SERVICE

I, Graham E.Berry, certify and declare as follows:

I am over the age of 18 years, I am an officer of this court and I am the respondent herein.

On July 8, 2001, I personally mail served the following documents described as

SUBPOENA DUCES TECUM AND ATTACHMENT A TO SUBPOENA DUCES TECUM ISSUES BY PARTY- RESPONDENT GRAHAM E.BERRY AND BEING HIS FIRST DEMAND TO PRODUCE DOCUMENTS, RECORDS, BOOKS OR THINGS DIRECTED AT THE CUSTODIAN (s) OF DOCUMENTS OF MOXON & KOBRIN, et al. (Numbered 1 - -).

On the interested parties in this action addressed as follows:

By placing one copy in an envelope and personally depositing it at a United State Postal Service facility, on the date shown below, first class postage affixed and addressed to:

The State Bar of California
Office of the Chief Trial Counsel
Terrie L.Goldade, Esq.
Agustin Hernandez, Esq.
1149 South Hill Street,
Los Angeles, CA 90015 -2299

I declare under penalty of perjury under the laws of the United States and the State of

California that the foregoing is true and correct.

Executed on this 25TH day of July 2001, at Los Angeles, California. __________________________

Graham E. Berry