Berry Letters Drescher

18 Aug 2001

GRAHAM E. BERRY (SBN 128503)
ATTACHMENT "A" TO
SUBPOENA
3384 McLaughlin Avenue
Los Angeles, CA 90066
Telephone: (310) 745-3771
Facsimile: (310) 745-3772

Email: grahameb@aol.com

Respondent Pro Per

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 WILLIAM T. DRESCHER AND THE LAW OFFICES OF DRESCHER & DRESCHER (Numbered 1- 32)

RESPONDENT, GRAHAM EDWARD BERRY ("Berry"), hereby propounds his Demand to Produce Documents, Records, Books or Things, Set No. One (Numbers 1- 32), to the Custodian (s) of Documents of William T. Drescher and the Law Offices of Drescher & Drescher ("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 24, 2001, at 10:00 a.m. at the offices of William T. Drescher, Drescher & Drescher,23679 Calabasas Road, PMB 338,Calabasas,CA 91302, 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).

DEFINITIONS AND EXPLANATIONS

A. "Document" and or "document" shall in all instances mean the original and duplicate (s), including without limitation carbon copies or photo (Xerox) copies, of each "writing" or other tangible thing within the meaning of C.C.P. з 2031, California Evidence Code з 250 and Federal Rule of Evidence 1001(1).

B. "Document" and or "document", in addition to the definitions above [and in accordance with the definitions, policies, bulletins, customs, practices and other directives of the Church of Scientology as defined hereunder], without limitation, shall also include any and all Red Box

Data or Red Box Type Data, Divisional Directives, Flag Representatives or LRH Comm orders, all data, cycles, cycles of action, routing lists, lists of ccs, distribution copies, lists of recipients, Mercury Messages, INCOMM ARCHIVES FILES, INCOMM logs, data analysis, situation analysis, knowledge reports, overt write-ups, O/W write ups, ethics reports, ethics assignments, ethics orders, Comm Evs, Boards of Investigation, Courts of Ethics, conditions assignments, condition write-ups, Sea Org or OSA Mission files and debriefs, letters, pamphlets, newsletters, brochures, flyers, leaflets, goals, purposes, evals, plans, strategic plans, tactical plans, policies, programs, programmes, program files, program debugs, projects, project orders, project files, ideal scenes (including detailed descriptions of the results to be achieved in all matters touched by the purpose),orders, orders logs, cross orders, cross orders logs, statistics (and all statistics counted for the post),valuable final products, worksheets, advices and dispatches relating to any matter or op reports, "D" Line compliance reports, daily reports, weekly reports, debriefs, Why Finding (s), stat analyses , chits, policy letters, bulletins, Board Technical Bulletins, instructs, Battle Plans, cramming log, examiner's log, treasury files, central files, ethics folders, white files, gray or grey files, black files, Dead Agent or DA packs and Black Propaganda.

C. "Communication" or "Comm" shall include any transmission of information from one person or entity to another person or entity, whether by document or otherwise, including, without limitation, by personal meeting, telephone, radio, video, modem, telegraph, teletype, electronic mail or other transmission, teleconference, or other mode of Communication.

D. "And" as well as "or" shall be construed either conjunctively or disjunctively so as to bring within the scope of this request any document that might otherwise be construed outside its scope.

E. As used herein, the singular of any word or phrase includes the plural and the plural includes the singular.

F. "Refer" or "referring" includes relating to, referring to, describing, evidencing or constituting.

G. "Relate" or "relating" means and includes relating to, referring to, reflecting, pertaining to, describing, evidencing or constituting.

H. The terms " William Drescher ", "you" or "your" as used herein shall mean the responding party herein, the custodian(s) of documents, books and records for William Drescher and the Law Offices of Drescher & Drescher ("Drescher") and shall include his/her/its present and former partners, associates, assistants, handlers, employees and representatives and every Document Request herein is directed to "you" and /or "your" as so defined, unless expressly indicated otherwise.

I. The term "Church of Scientology" includes all corporations and Churches of Scientology and Missions thereof, including, but not limited to, Sea Org Reserves, Ltd.; the Sea Organization ('the Sea Org"); the Commodores Messenger Organization International ("CMO Int."); the Commodores Messenger Organization ("CMO"); Church of Spiritual Technology ("CST"); Religious Technology Center ("RTC"); Church of Scientology International ("CSI"); Building Management Services ("BMS"); Golden Era Studios; Gold; Gold Base; Author Services; Inc., ("ASI"); The L. Ron Hubbard Library; and "Administrative" organizations including, but not limited to, Continental Liaison Offices (CFOs); INCOMM; "INT Management"; The International Justice Chief; The Finance Dictator; The Finance Police; "The International Finance Police Network"; " The Finance Banking Officer (FBO) Network; The Director of Special Affairs ("DSA") Network and each of their legal owners, beneficial owners, managing agents, special directors, directors, trustees, trustors, beneficiaries, officers, employees, staffers, volunteers, attorneys, agents, service providers (including, but not limited to, storage facilities, safe deposit boxes and storage vaults ["nuclear bomb proof"' or otherwise]) and representatives including, but not limited to, those which are the subject of any Internal Revenue Service single or group section 501(c) (3) exemption.

J. (a) If any documents requested herein are withheld from production on grounds of privilege, please provide with your response a complete privilege log including for each such document: (i) the date and number of pages of the document; (ii) its title (if any); (iii) its general subject matter; (iv) the identity of attachments or appendices to the document; (v) the name and address of each person who received a copy thereof; (vi) the name and address of each person to whom the document was distributed, shown, described to or explained; (vii) the name and address of the person or persons by whom it was written; (viii) its present custodian and/or location; (ix) the particular privilege claimed and a full description of the factual grounds upon which it is being withheld; (x) the relationship of the author to each addressee and each person who received, was shown, or was informed of the contents of the document; and (xi) all facts which, objectively viewed, show or may tend to show a waiver of the privilege asserted, and

(b) In connection with any assertions of privilege and /or attorney work product herein it is, and will be, Respondent's contention and argument that California Evidence Code section 956 (the crime-fraud exception) applies and prevails.

K. When this Document Request calls for a document which, while known to you is not, or is no longer in, your possession, custody or control, you shall identify, in your written response hereto, the document's present location(s) and custodian(s), or otherwise its last known location(s) and custodian(s) and the identity of the person(s) or entity(s) most likely to have relevant and responsive knowledge and/or information.

L. If any document called for by this Document Request has been destroyed, lost, altered, discarded, transferred elsewhere, or stored elsewhere, please include in your written response separately for each such document: (i) the identity of all authors, addressees and recipients; (ii) the date, subject matter, and number of pages of the document; (iii) a description of any attachment or appendices to the document; (iv) the names and identification of all persons to whom the document was distributed, shown or explained; (v) the date when it was destroyed, lost, altered, transferred, stored or discarded, the manner and circumstances in which same occurred, and the reason for same; (vi) the names and addresses of all persons who authorized or effectuated such conduct; and (vii) the names and addresses of all persons and/or entities who/which might still have a copy of the document or any part of it,(viii) the current location and custodian of the document and the identity of all managing agents and custodians of document(s) thereat.

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; Jesse Prince; Mark Bunker; 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.з 2023 (9).

REQUEST FOR PRODUCTION OF DOCUMENTS

1. All documents and communications that refer to or constitute any retainer or employment agreement between you and the Church of Scientology.

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 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.

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

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, Riverside District Attorney Grover Trask, Deputy DA Robert Schwarz, Alan C. Oberstein, Gerald Feffer, Samuel D. Rosen, Hon. Robert H.Wallerstein, Alternative Resolution Centers, Graham Berry, 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 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.)

11. 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.

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 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; 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; Kendrick Moxon; Helena Kobrin; Sarira Alexander; Laurie Bartilson; Timothy Bowles; Earle Cooley; Bert Fields; Lavely & 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.

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 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.

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, 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.

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 the Church of Scientology internal guiding policies, advices, special tech and dispatches 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 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; any employee of the State Bar of California, Office of Chief Trial Counsel; Hon. Keith G. Wisot (Ret.); Tom Hefferman; Frank Nowicki; Michael Perry; Daniel Lantz; Lumin-oZ, LLC; Lumin-oZ, Inc.; Michael Wech; Paul Strabala; Ursula Caberta; Ida Camburn; 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.

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 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 entity or member(s).

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 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.

19. 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(s) or person(s) relating to Graham Berry and Associates.

20. 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.

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

22. 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.

23. 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.

24. 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.

25. 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.

26. 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. 27. All documents and communications including, but not limited to, 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].

28. 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.

29. 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.

30. 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].

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

32.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.

33. All documents and communications that refer or relate to Jeavons v. Church of Scientology International, LASC Case No.BC 207363

DATED: July 31, 2001 Respectfully Submitted, Graham E. Berry

NOTICE 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 William T. Drescher, et al. (Numbered 1- 32).

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 William T. Drescher, et al. (Numbered 1- 32).

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

The Custodian of Documents for William Drescher and the Law Offices of
Drescher & Drescher,
23679 Calabasas Road,
PMB 338
Calabasas, CA 91302

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

By leaving the papers at the officially designated offices of William T. Dresher, 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 its receipt. CCP з 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:

WILLIAM T. DRESCHER, ESQ.
LAW OFFICES OF DRESCHER & DRESCHER,
23679 CALABASAS ROAD, PMB 338,
Los Angeles, CA 91302

URGENT AND IMPORTANT TIME SENSITIVE SUBPOENA DUCES TECUM ENCLOSED.

PLEASE IMMEDIATELY ADVISE MR. DRESCHER OF RECEIPT.

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

EXHIBIT A