Berry Letters Gerner

15 Aug 2001

M. The term "Associates" as used herein shall include: Lewis, D'Amato, Brisbois & Bisgaard; Robert F. Lewis; David Parker; Gordon Calhoun; Theodore Monroe; Eduardo Brito; Matthew Berger; Michael Silk; Ali Abdullah aka Ali Shapur; Maria Baquiran; Musick, Peeler & Garrett; Kevin Lacy; Peter Kravitz; Berry, Lewis, Scali & Stojkovic; J. Stephen Lewis; Christian J. Scali;

David Gregoire; Scott Mayer; Will (" O.C.") Greene; Law Offices of Graham E.Berry; Ray Benkozcy; Justin Soberdash; Cheryl Nelson aka Cheryl O'Brien; Kathleen Ham; Daniel Harris; Lawrence Wollersheim; Gerry Armstrong; Joseph Yanny; Dr. Uwe Geertz; Steven Fishman; Robert Vaughan Young; Roxanne Friend; Gloria West; Peter Alexander; Stacy Brooks; Robert Minton; Keith Henson; Arel Lucas; Michael Pattinson; Robert Jeavons; Jane Scott; Jason Scott; FACTNet; Arnaldo Lerma; William ("Bill") Jordan and Tory Bezazian.

N. The attention of responding party(s) herein is/are directed at the "meet and confer" provisions of State Bar Rule of Procedure Rule 185 and C.C.P.§ 2023 (9).

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 legal and beneficial owners and/or ownership of the Church of Spiritual Technology ("CST"), its principals, trustees, directors, officers, premises, staffers, securities, records, meetings, property and assets.

2. All documents and communications that refer to or constitute any retainer or employment agreement between you, all other trustees, directors and officers of CST, CST and/or the Church of Scientology.

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 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.

4. 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) to or 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 your duties, responsibilities and/or functions in relation to the Church of Scientology.

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 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; Elliot Abelson, William T.Drescher, you and/or the Watch Dog Committee are identified.

6. 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 and any of their current of former partners, associates or employees.

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 death of L.Ron Hubbard, the Estate of L.Ron Hubbard, 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; Pat Broeker; Mark (Marty) Rathbun, Michael (Mike) Rinder; Eugene Ingram, Lawrence Heller; Sherman Lenske; Lenske & Lenske; Thomas C. Spring; Gerald A. Feffer; Monique Yingling; Eric Lieberman; John J. Quinn; Samuel Rosen; Elliot Abelson; Gerald Chaleff; William Drescher; Kendrick Moxon; Earle Cooley; Michael Stoller; Marcello Di Mauro; Lloyd Levinson; Lyman Spurlock; Thomas Gerard Rummelhart; Linda Woolard; Nigel Hunter; Assemblyman Steven Baldwin; Guy White; 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 Special Trustees, Trustees, Special Directors, Directors , Corporate Officers or Employees of Church of Spiritual Technology ("CST").

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 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.

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 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.

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 the Church of Scientology internal guiding policies, advices, special tech and dispatches relating to Graham Berry and Associates.

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 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 ormember (including any documents relating to your membership of WISE and IAS); and any Church of Scientology entity or member(s).

12. 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/or 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.

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 operational documents on the destruction of Graham Berry, Graham Berry and Associates, the Law Offices of Graham E. Berry and Berry, Lewis, Scali & Stojkovic.

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 Plan(s) for the Erlich raid, Lerma raid, Wollersheim raid, FactNet raid, Penny raid.

15. All documents and communications 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; Florida 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.

16. 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].

DATED: July 31, 2001 Respectfully Submitted,

Graham E. Berry

PROOF OF MAIL 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 31, 2001, I 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 Sherman D. Lenske, et al. (Numbered 1- 16).

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 31st day of July 2001, at Los Angeles, California.

__________________________ 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 25, 2001, I personally 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 Sherman D. Lenske, et al. (Numbered 1- 16).

On the responding entity and/or person (s) named therein, addressed as follows:

The Custodian of Documents for Sherman D. Lenske and the Law Offices of Lenske, Lenske & Abramson, 6400 Canoga Avenue, #315 Woodland Hills, CA 91367

A copy of such addressed being attached hereto as Exhibit A.

By leaving the papers at the officially designated offices of Sherman D. Lenske, in an envelope clearly labeled to identify the attorneys being served, with a receptionist and/or with a person having charge thereof, and requesting that person to immediately advise the addressees with notice of it's receipt. CCP § 1011(a).

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 31st day of July 2001, at Los Angeles, California.

__________________________
Graham E. Berry

The Custodian of Documents for:

SHERMAN D.LENSKE
LENSKE, LENSKE & ABRAMSON,
6400 CANOGA AVENUE, #315
WOODLAND HILLS, CA 91367

URGENT AND IMPORTANT TIME SENSITIVE SUBPOENA DUCES TECUM ENCLOSED.

PLEASE IMMEDIATELY ADVISE MR. LENSKE OF RECEIPT.

THIS SUBPEONA IS SERVED PURSUANT
TO CCP § 1011 (a)

EXHIBIT A