If anyone wants this as a Word file to try to make it look better, ask in email, Keith

JULY 18, 2001 DRAFT:       
.

Criminal and fraudulent conduct directed at the courts and defendant
in the underlying, related, concurrent and current matters.	This
R.I.C.O. list, relating to CSI, Barton, Moxon, Kobrin, Paquette,
Abelson, Ingram, Miscavige, et al. criminal conduct directed
specifically at Graham E.  Berry (and not other victims such as
Henson, Mayo, Bunker, Prince, Ward, Minton, the United States Govt.,
et al.) is approx. 75 % complete. Further versions will be modified to
include tortious and ethical misconduct by the Church, it's
parishioners, employees, agents and operatives. Criminal conduct will
be in regular type, tortious conduct in italics and unethical conduct
underlined (at least in part). A third column will specifically
identify the relevant crimes, torts and ethical breaches. 
December 20,1993:  U.S.District Court Judge Harry Hupp tells Bowles &
Moxon to stop "investigating" Graham Berry.	Church of Scientology
v Fishman & Geertz hearing transcript.

March 31,1994:Berry complains to Bowles & Moxon that it is ignoring
Judge Hupp's instruction to stop investigating Berry.	Berry letter
to Bowles, March 31,1994.
April 1,1994 (approx.):Church of Scientology International Office of
Special Affairs ("CSI") retain counsel Bowles & Moxon and Investigator
Eugene Ingram ('Ingram") to " investigate" Berry.	Timothy Bowles
Declaration (May 6,1998);  Eugene Ingram Declaration (May 6,1998).
April 21,1994:Scientology leader Michael Rinder and lawyers Elliot
Abelson and Michael Hertzberg (New York) meet with Berry and advise
him that they have Berry under investigation and surveillance because
they were "aware" it upset Berry. [Former LA Deputy District attorney
Abelson is "in house" counsel to the Church of Scientology and former
counsel to the Gambino crime family in New York.]	 Theodore
Monroe Declaration executed June 6,1994. 
April 24,1994:Scientology "investigator" Russell Andrews interviews
Peter Mills in Maryland, who concludes, " this investigation was a
gross intrusion and invasion of Graham Berry's privacy and was
intended to harass him."	Peter Mills Declaration executed May
10,1994.
April 28,1994:Abelson informs Berry that CSI had instructed Ingram to
continue the Berry investigation in New Zealand, Australia, England,
New York and California. Abelson also states that "in April…he had
found nothing that…was particularly negative in those [Ingram,
etc.investigation] reports"	Berry letter to Abelson, April
28,1994; Abelson letter to Berry, May 24,1994.
May 2,1994:Abelson confirms that the Ingram investigation of Berry
will continue.	Abelson letter to Berry, May 2,1994.
May 4,1994:The CSI/Moxon/Ingram investigation "led to obtaining the
May 5,1994 Declaration of Mr.Cipriano." (" the First Cipriano
Declaration.")	CSI corporate officer LynnR. Farny Declaration (May
6,1998, 4).
May 4,1994:The First Cipriano Declaration was obtained in New York
through criminal impersonation of a Los Angeles Police Department
Detective and extortion. Ingram had gained access to Cipriano's high
security New York apartment building. Cipriano had known Berry for 6
months in New York, 1984-85.Ingram (accompanied by an unidentified
woman) told Cipriano that Berry was doing illegal things in Los
Angeles, as a Lewis, D'Amato, Brisbois & Bisgaard partner. Ingram said
Berry was also involved in seedy sexual encounters with underage gay
males and that he had been involved in the activities of Andrew
Crispo, a notorious/infamous New York alleged murderer.a)	Ingram
told Cipriano that he knew there was a State of New Jersey arrest
warrant for Cipriano and that he could be arrested very easily.
Cipriano felt intimidated by an LAPD detective acting in this
manner.b)	Ingram told Cipriano he would return the next day with
a declaration for Cipriano to sign.c)	Later, when Cipriano was
absent, Ingram returned, again obtained access to the high security
building, and visited Cipriano's wife. This further intimidated
Cipriano because Ingram knew embarrassing details about his
pre-marital gay life in New York (1980-1986), which his wife did
not.d)	Cipriano believed that if he did not do as Ingram demanded
then his wife would be informed of his pre-marital gay history and he
would also be arrested and returned to the New Jersey authorities.e)
No one had ever told Cipriano that Berry had had sex with an underage
male and Cipriano had no personal knowledge of any. Cipriano never
spoke to Ingram about the Anvil. It was Ingram himself who created
those statements in the May 5,1994 First Cipriano Declaration.f)
Ingram prepared the First Cipriano Declaration. g)	The First
Cipriano Declaration was extorted, perjured and false. Berry v.
Cipriano arose out of it.h)	 There was never any independent
evidence to corroborate the First Cipriano Declaration.i)	During
Berry v. Cipriano, Cipriano had conversations with Moxon during which
he told Moxon that most of the First Cipriano Declaration was an
exaggeration by Ingram. Moxon's response was to go for 'corroborating
witnesses'. It was also because of Cipriano's historical credibility
problems, said Moxon.	Robert Cipriano Declaration dated August
9,1999, 14 ("Cipriano Decl. III,  14, Ex__."), Cipriano Depo.T.
Vol.II, 64:16-65:4,66:21- 76:21,89:2-106:1.Berry, with corroboration,
has denied ever knowing Crispo or his convicted murderer employee
Bernard Le Geros, recruited by Ingram and covertly represented by
Moxon & Kobrin. _______Cipriano Depo.T.Vol.II, 50:25-51:8.Ingram
Declaration 3,4; Cipriano Decl. III,  18-20.   Cipriano Decl. III,
14-20.Cipriano depo.T.Vol.II, 144:23: -154:3.Jonathan S. Canno and
John Lauricella Declarations; Moxon representations to Judge Williams
("It was in the 1980's.They must have all [40-60] been gay hustlers
who all died of AIDs. That is why we cannot find anyone other than
Cipriano."Cipriano depo.T.Vol.II, 147:17-148:6.
May 6,1994:Berry puts Abelson, CSI and it's other attorneys on notice
of the illegal and unethical "investigation" against him.	Berry
letter to Abelson, May 6,1994.
May 9,1994:Berry again advises and complains of the Ingram
investigation and details it's abuse.	Berry letter to Abelson, May
9,1994.
May 19,1994:Rinder/CSI meet in Texas with former scientology leader
Vicki Azneran and former CSI/Hemet Base Chief of Security Richard
Azneran.CSI pays est.$250,000.00 to the Azneran's to settle Azneran v.
Scientology (filed 1998). At the same time they execute a Declaration
accusing Berry of criminally altering pages in their declarations in
the Fishman/Geertz case. Previously, Vicki Azneran was widely quoted
as saying "scientology is a criminal organization day in and day out."
May 6,1991,Time magazine.	Vicki Azneran Declaration and
agreements, dated May 19,1994.
May 23,1994:Moxon writes extortion letter to Berry. The
"investigation" will be expanded if Berry files a certain document
with the court and/or does not stop litigating against CSI and it's
attorneys.	Moxon letter to Berry, May 23,1994  1, 4,6,8,10,11.
May 23,1994:Scientology leader Kurt Weiland "demands" Berry stop
people spreading lies about the church and not to file certain
declarations with the courts.	Weiland letter to Berry, May 23,1994.
May 24,1994:Scientology leader Michael Rinder objects to Berry's
"evolving declaration" describing the CSI and scientology attorney
harassment of Berry.	Rinder letter to Berry, May 24,1994.
May 24,1994:Abelson writes to Berry:" I can now state that I have
received subsequent [to April] information that would not please you."
[Referring to the First Cipriano Declaration].	Abelson letter to
Berry, May 24,1994,p.6 3.
June 3,1994:Former Scientologist Andre Tabayoyan testifies that he was
offered $25,000, in Arizona, to commit perjury against Berry and that
"the Scientologists have a plan to disbar Graham Berry…"	Andre
Tabayoyan Decl., executed June 3,1994.
June 8,1994:The State of Florida issues an arrest warrant against
Eugene Ingram for "falsely impersonating [police] officer". 	Copy
of Warrant.
July 8 - 16,1994:Robert Vaughn Young and Stacy Brooks Young meet, for
8 days, in Seattle, Wa. with Scientology leaders Michael Rinder and
Michael Sutter who attempt to extort them with threats and offer them
$200,000 to commit perjury and allege that Berry had fabricated their
expert witness declarations in the CSI v. Fishman / Geertz case.
Declaration of Stacy Brooks Young executed December 14,1994
13,15,16,18,19,27 and 36.Declaration of Robert Vaughn Young executed
December 14,1994 4,5,6,7,8 and 15). 
September 30,1994:State of Florida charges Ingram with "Falsely
Personating an Officer." a 3rd.degree felony. The charge was not
prosecuted within the mandatory three years and was dismissed on
October 9,1998 upon motion of CSI representatives.	Motion to
Dismiss Information and Supporting Papers. [Not included due to
volume].
November 7,1994:Bowles writes to Garry Scarff, in Florida, and
confirms extortionate demand that he recant prior testimony [in
Fishman/Geertz] or the Church and its counsel would file criminal and
civil proceedings against Scarff.	Bowles letter to Scarff,
November 7,1994.
November 9,1994:Scientology leader Weiland writes to the New York
Daily News and states "whereas people have sent [CSI] information over
the last year about Graham Berry's illegal sexual activities,the
Church has never released any such information or made any public
comment about it."	Weiland letter to New York Daily News,
November 9,1994, p.6, para.3.
November 17,1994:Scarff testifies that Bowles had been pressuring
Scarff, in Florida, to totally recant his testimony in the CSI v.
Fishman/Geertz case alleging defamation in connection with the May
6,1991 Time Magazine best selling cover story: "Scientology, Thriving
Cult of Greed and Power [successfully defended by Berry]
Declaration of Garry Scarff executed November 17,1994.
November 29,1994:Dr. Geertz, of Florida, advises Berry that Bowles &
Moxon are using Ingram to "disrupt his relations with his neighbors,
professionals in his field [and his employer] by defaming him by
disseminating falsehoods."	Dr. Geertz letter to Berry, November
29,1994.
November 29,1994:Berry complains to Bowles that Ingram's publicly
subsidized [tax free]  "investigation" is causing Berry "irreparable
and continuing damage".	Berry letter to Bowles, November 29,1994.
November 30,1994:Berry details the on-going Ingram intimidation/
harassment/extortion to Helena Kobrin, Esq. of Bowles & Moxon.	Berry
letter to Kobrin, November 30,1994.
December 1,1994:Kobrin states that the CSI/Bowles & Moxon/Ingram
investigation of Berry is "lawful" and not "harassment of opposing
counsel." Kobrin later denied writing this letter.	Kobrin letter
to Berry, December 1,1994.Kobrin letter to Berry, January 20,1997.
    January 3,1995:CSI "published" the First Cipriano Declaration to
the New Zealand Government.	Declaration of Kendrick Moxon,May
6,1998 2,Exh.A. 
January 18,1995:CSI (via Rinder, Abelson & Drescher), Robert F. Lewis,
Esq., and A.I.G. sign [secret] agreement to steal the Fishman/Geertz
legal files and declarations.	Settlement Agreement dated January
18,1995; Berry Declaration, executed October 23,1996.
January 18,1995:Robert Lewis, Esq. signs letter CSI/Rinder/Abelson
demand be sent to England's Daily Mirror newspaper, then a Berry
client, disavowing the Tabayoyan declaration.	Lewis letter to Daily
Mirror, dated January 18,1995 
February 2,1995:Dr. Geertz's new attorney attempts to retrieve his 200
plus boxes of documents stolen by AIG, CSI and Lewis, D'Amato,
Brisbois & Bisgaard.	Ford Greene, Esq. letter to Lewis, D'Amato,
Brisbois & Bisgaard; Ford Greene fax and enclosures to Berry, dated
February 26,1997.
March 13,1995:New Zealand Deputy Opposition Leader (a friend of Berry)
mails Berry the "highly defamatory" January 3,1995 Moxon/ Farny/ CSI
package containing First Cipriano declaration.	Caygill letter to
Berry, dated March 13,1995.
June 9,1995:Dr. Geertz continues to try and retrieve his files from
Lewis, D'Amato. His new attorney faces a successful CSI Motion for
Summary Judgment before Judge Alexander H.Williams, III in Fishman &
Geertz v. CSI (malicious prosecution). The new attorney does not have
access to the relevant Dr.Geertz files, which CSI/Lewis/AIG have
seized and secreted near the Church's Intelligence Department (OSA)
[Annual litigation and investigation budget exceeds $40M].	Lewis
letter to Daniel A. Liepold, Esq., June 9,1995.
July 6,1995: Lewis, D'Amato release the remaining "stolen Geertz files
and CSI v. Fishman/Geertz declarations to Dr.Geertz's new attorney in
Fishman & Geertz v. CSI.	Robert F. Lewis, Esq. letter to
Metropolitan Art Storage, Inc. near CSI premises.
July 11,1995:Dr. Geertz's remaining files are transferred from storage
under scientology (Helena Kobrin, Esq.) surveillance. CSI objects.
Helena K. Kobrin Decl., Esq. and enclosures, executed October
18,1996.Lynn R. Farny Decl., executed October 18,1996.
July 20,1995:Abelson and CSI are  "shocked" at Lewis releasing Dr.
Geertz's files to Dr. Geertz's lawyers in Fishman & Geertz v. CSI.
Abelson letter to Lewis, July 20,1996.
August 1995:Esquire magazine publishes article on CSI "investigation"
of Berry.	Esquire magazine, August 1995.
August 18,1995:Abelson faxes Berry's partner Lewis, August 18,1995
Internet posting by Berry, seeking "information that can be of
assistance in various law suits involving the cult."[It breaches the
Secret Agreement restraining Berry from ever litigating against the
Church again.]	Abelson fax to Robert F. Lewis, Esq. dated August
18,1995.
August 23,1995:Berry complains of the continuing CSI/Moxon "defamation
by innuendo" investigation.	Berry letter to Talon Executive
Services Inc., dated August 23,1995.
September 1995:BARTON/CAN Reform Group widely publishes "Perversion,
Criminality and Lies" and the contents of the First Cipriano
Declaration. [In February 1998 Berry learns Barton, Chait, et al.
comprise the CAN Reform Group.]	CAN Reform Group newsletter, September
1995.
October 2,1995:CSI and BARTON/CAN Reform Group continue anon.
defamatory Internet posting campaign against Berry, by publishing
allegations that Dr. Geertz provided his [28 year old physician] son
to Berry in exchange for legal services.	Theta.com internet
posting transmitted 2 Oct 1995. 
January 5,1996:Berry requests CSI provide factual support for the
"highly defamatory" contents of it's January 2,1995 letter to the New
Zealand Government.	Berry letter to Farny, dated January 5,1996.
February 29,1996:Berry puts CSI, et al on "notice" of its
investigatory defects, abuse and potential liability.	Berry letter
to Farny, January 5,1996.
July 19,1996:CAN Reform Group [Barton, Chait, et al.] publishes
further defamatory allegations, and the contents of the First Cipriano
declaration, to the permanent World Wide Internet where it remains.
Internet posting transmittal, July 19,1996.
October 10,1996:Scientology litigation expert Lawrence D. Wollersheim
opines and testifies that CSI is attempting to "eliminate…Graham
Berry…consistent with Scientology' past practice and published policy
of attempting, through any means, to deny their opponents access to
the courts."	Affidavit of Lawrence D.Wollersheim executed October
10,1996.
October 23,1996:Wollersheim testifies "there are very few attorneys in
the entire country that have the ability, knowledge and guts to
litigate with scientology."	Affidavit of Lawrence Wollersheim
dated October 23,1996.
October 29,1996:Dr. Geertz files California State Bar complaint
against Jack Quinn, Abelson, Kobrin, and his attorneys Lewis, Gordon
Calhoun and Jana Lubert, in connection with the theft, seizure and
secretion of his files. The State Bar summarily rejects the complaint
at "intake" because Quinn, Abelson and Kobrin were not Geertz's
attorneys.	Dr. Geertz letter to California State Bar, October
29,1996.California State Bar letter to Dr.Geertz_______.
December 11,1996:CSI is discovered "tapping" Berry's telephone.
Abelson is on the "tapped" line.	Transcript of telephone
conversation, December11, 1996;Abelson letter to Berry, dated December
11,1996;Berry letter to Abelson, dated December 13.1996;Abelson letter
to Berry, dated December 16,1996;Berry letter to Abelson, dated
December 17,1996;Berry letter to Abelson, December 19,1996;Berry
letter to Moxon, December 26,1996.
January 1997:Russell Shaw's ARS Bigots Home Page publishes the First
Cipriano Declaration to the Internet. Shaw [a scientologist working
with OSA operations ("Ops")] is sued by Berry as part of Berry v.
Cipriano, Barton, Miscavige [Abelson, Moxon and Ingram]. After
assisting CSI, Moxon, etc., to overwhelm and force Berry's dismissal,
Shaw's counsel settles with Berry for mutual releases and an agreement
to testify at deposition. His attorney (David Chodos) tells Berry,
Shaw would testify that his Internet site was maintained as a
publishing vehicle for an undisclosed third party.	Rogues Gallery
of ARS Bigots.Berry Decl._______.
January 9,1997:Berry complains to Helena Kobrin (Moxon & Kobrin) about
her continuing allegedly "lawful investigation" of opposing counsel.
Berry letter to Kobrin, January 9,1997.
January 14,1997:Berry puts Scientology Colorado counsel [in
Scientology v. FactNet] on notice of Scientology harassment of
opposing party and his employees in Boulder, Colorado.	Berry letter
to Jeffrey A. Chase, Esq. dated January 14,1997
February 27,1997:Dr. Geertz executes declaration describing the theft
of his files by CSI, Moxon & Kobrin, Lewis, D'Amato and AIG.
Declaration and enclosures of Dr. Geertz sworn February 27,1997. 
April 3,1997:New counsel for Dr. Geertz advises Lewis D'Amato that
they caused the filing of Elliot Abelson v. Ford Greene by stealing
Dr.Geertz's documents.	Ford Greene letter to Mary Whitaker dated
April 3,1997.
April 30,1997:Cipriano meets with Ingram after discovering the First
Cipriano Declaration on the World Wide Web of the Internet. Ingram
tells Cipriano that his conviction and probation in New Jersey is
"completely over."	Cipriano Decl. III, 21-22.
May 5,1997:Berry Booklet Part I published on the Internet by nobody
@REPLAY.COM (Anonymous). It republished the contents of the First
Cipriano Declaration.	Deja News Retrieved Document.
May 11,1997:Ingram visits Cipriano, copies his personal photographs
and takes information as to the identities of those in the
photographs.	Cipriano Decl. III,  22.
July 3-5,1997:Elliot Abelson, Esq., CSI, Michael Rinder and Ken Long
fly former CSI/OSA covert operative Garry Scarff from Orlando, FL. to
Los Angeles, CA. They intimidate, extort and suborn perjury from him,
accusing Berry of falsifying evidence in the CSI v. Fishman/ Geertz
case and recanting his testimony in that case. Scarff had testified
that he was involved with a Seattle bank theft [for Bowles?], the
theft of opposing counsels files and rolodex for Moxon, and a Moxon,
Ingram conspiracy to murder opposing counsel Ford Greene and Cult
Awareness Network President Cynthia Kisser and her daughter. Overt
acts (witnessed by Kisser and anor.) had been taken in furtherance of
the conspiracy to murder. Abelson instructs Scarff to fire his
attorney Berry.	Declarations of Garry Scarff sworn July 4,1997 and
August 12,1997;Videotape of Abelson suborning perjury taken July
4,1997.Garry Scarff Depo.T. ________,Garry Scarff Declarations_____.
January 21-22,1998:Ingram telephones Cipriano.They meet in a
Carpinteria Restaurant. Ingram jokes about the postings, photos and
copies of arrest warrants against him on the Internet and claims none
of it is true. Advises that Berry may sue Cipriano. Ingram insists
that he meet with Cipriano the following day. Ingram discloses that he
worked for the Church of Scientology and it's lawyers. Ingram states
their spy in Berry's office has obtained a copy of a libel and slander
complaint to be filed against Cipriano. Ingram advises Cipriano to
avoid service and insists that Cipriano meet with Moxon the next day.
.Cipriano Decl. III,  23.Cipriano Depo.T.Vol.II, 122:10-126:14.
January 23, 1998:Cipriano meets Moxon and Ingram at Moxon's law office
Brand Avenue, Glendale "false front" law office. Ingram misrepresents
to Cipriano that Berry is taking children out of the Los Angeles
Unified School District and introducing them to the gay lifestyle
through millionaire or rich gay affluent males in Hollywood and the
Beverly Hills area. He showed Cipriano a "Pride" flyer. Ingram shows
Cipriano the draft Berry v. Cipriano lawsuit they have stolen from the
Musick, Peeler & Garrett law offices.  Cipriano Moxon offers to
represent Cipriano at no fee or cost because Cipriano had been helpful
to Moxon.In fact, Moxon [a material witness and known probable
defendant] does represent Cipriano for free.	Cipriano Decl. III,
25 - 28.Cipriano Depo.T. Vol. II, 132:16 -139:3
March 9,1998:Cipriano is served in Berry v. Cipriano, LASC Case No. BC
184355.	Cipriano Decl. III,  29.
March 15,1998: Ingram impersonates a police officer in Hollywood,
California and makes a false bomb allegation.	Neal Hamel internet
post made March 15,1998.
March 21,1998:Cipriano telephones Berry. Requests an immediate meeting
at Van Nuys Police Station. Berry is at dinner and declines. Cipriano
telephones Moxon and Ingram and also requests an immediate meeting at
the Van Nuys Police Station.Cipriano had wanted to " crack heads" in
front of law enforcement and settle the defamation and libel matter re
the First Cipriano declaration [Berry v. Cipriano, Barton]. Ingram
tells Cipriano not to go to the Police. Ingram and Moxon immediately
visit Cipriano and then fiancée Christine Gregos at home. CSI OSA
faxes the perjured Scarff declaration (July 4,1997) and Moxon offers
totally free legal representation to Cipriano in Berry v. Cipriano.
Moxon offers Ms. Gregos whatever she wanted to cooperate. Ingram
suggests taping any telephone calls from Berry. Moxon leaves message
on Berry's answering machine that he is now Cipriano's attorney and
Berry is to have no communication with either him or fiancée Christine
Geros.	Cipriano Decl. III,  30 -33.Cipriano Depo.T.Vol.II,
51:16-52,59:8-17,61:7- 63:25.Another reason Berry did not respond was
to avoid any suggestion of discouraging Cipriano from going to the
Police-which would have been 'obstruction of justice.'
March 23,1998:Moxon faxes Cipriano a California State Bar complaint
against Berry for Cipriano to sign and send to the California State
Bar. It was for the purpose of harassing Berry and causing him to
dismiss the Berry v. Cipriano and related lawsuits.	Cipriano Decl.
III,  34, Exh. 6,7.
March 23,1999:Christine M. Gregos (Accurate Bookkeeping Company) fears
Berry will win a judgment against their assets. Cipriano requests
Moxon prepare quit claim documents transferring assets into her name
only.	Cipriano Decl. III,  32, Exh.8.
March 25,1998:Cipriano and Moxon meet Gary Soter at Wasserman, Comden
& Casselman. Cipriano signs retainer agreements with both Moxon &
Kobrin and the Wasserman, Comden & Casselman law firm. [David
Casselman being related to Donna Casselman who, as part of the CAN
Reform Group, published the First Cipriano Declaration.] Cipriano
understood that Soter was retained because of his 'SLAPP' action
expertise. Subsequently, they filed an unsuccessful 'SLAPP' motion to
dismiss the Berry v. Cipriano lawsuit. In addition, that Moxon likes
to use tall, big, heavyset lawyers who are prepared to try and
intimidate Berry. The Moxon & Kobrin retainer agreement was backdated
to ensure that there was no gap in the attorney client privilege. Both
retainer agreements expressly provide that Moxon & Kobrin were
responsible for the entire cost of Cipriano's representation. Cipriano
meets Soter only once. He next sees him at the vexatious litigant
hearing. At no time was there any discussion as to Cipriano being
represented by counsel other than Moxon & Kobrin given the connection
with CSI. Cipriano saw one invoice for $5,000.00 from Soter to Moxon.
Cipriano Decl. III,  36, Exh. 9,10.Cipriano Depo.T.Vol.II,
138:4-145:17.
March 26,1998:Moxon arranges for Earthlink Network, Inc., a Church of
Scientology related corporation [including Slatkin], to employ
Cipriano.	Cipriano Decl. III,  37 - 40.
April 4,1997: (approx)Cipriano meets with Moxon and tours certain
Scientology facilities in Hollywood. Cipriano and Moxon also meet with
two others believed to be Isadore Chait and David Miscavige. Moxon
offers Cipriano $750,000.00 to co-operate with him in the defense of
the Berry v. Cipriano, Barton, Miscavige [Moxon, Abelson, Ingram]
case. They discussed wealthy scientologists providing [laundering] the
money through a children's charity ('Day of the Child') that would be
incorporated. Moxon would assist with funding.	Cipriano Decl. III,
42-43.Cipriano Depo. T. Vol. II, 185:20-188:19.
April 30,1998:Moxon requests Cipriano to locate 'witnesses' in New
York and convince them to testify against Berry.	Cipriano Decl.
III,  44.
May 14,1998:Cipriano emails Moxon with details regarding their
incorporation of the Icon Entertainment Group .It was to have its
office at Moxon & Kobrin.	Cipriano Decl. III,  45,Ex.15.
May 23,1998:Cipriano prepares, for Moxon, a SEC Private Placement
Offering for Icon Entertainment Group and Day of the Child. It is to
solicit funds [for Cipriano] from the Church of Scientology and Church
of Scientology members and celebrities.	Cipriano Decl. III,  46,Ex.16.
May 25,1998:Moxon arranges for Geoffrey Barton to wire Cipriano
$2,500.00 .The transaction was intentionally structured to avoid the
appearance that Moxon was paying for witness testimony.	Cipriano Decl.
III,  47,Ex.17.
June 1,1998 (approx.):Moxon advises Cipriano that Judge Hiroshige is
lame and that the Berry v. Cipriano / Barton case has been moved to
Judge Williams, " a friend of the Church of Scientology." [in fact the
Judge's fiancée works with CSI, as does Moxon, Barton, Ingram et.al]
Cipriano Decl. III,  48.Declaration of Judge Williams______[refusing
to recuse himself].
June 17,1998:Moxon wants to disconnect Cipriano from Christine Geros
and prevent him from "bolting to the Berry side of the [Berry v.
Cipriano/Barton] lawsuit." Moxon moves Cipriano into a Hollywood
scientology boarding house owned by an employee of Ingram.
Cipriano Decl. III,  49.
June 28-30,1998:Moxon coaches Cipriano to commit perjury at his
deposition, taken by Barton, in Berry v. Cipriano/Barton. The
deposition is to be at the Paul, Hastings, Janofsky & Walker law
offices.	Cipriano Decl. III,  50.
July 1,1998:Samuel D.Rosen of Paul, Hastings, Janofsky & Walker
coaches Cipriano to commit perjury at his deposition. Barbara Reeves,
Esq., and Scientology leader Michael Rinder are present. Cipriano
alleges they are engaged in "hate based" conduct against Berry.
Cipriano Decl. III,  51,52.
July 2,1998:Ingram meets with Cipriano before Day 2 of the Cipriano
deposition in Berry v. Cipriano/ Barton. Ingram wanted Cipriano to
deny that Ingram had shown Cipriano a LAPD Detective shield when he
obtained the first Cipriano Declaration on May 4/5 1994.
Cipriano Decl. III,  53.
July 2,1998:Immediately following the completion of Day 2 of the
Cipriano deposition in Berry v. Cipriano/Barton, Moxon moves Cipriano
to the "Church of Scientology Witness Protection Program" at Palm
Springs, near CSI's 'Gold Base' paramilitary heavily armed
International HQ. Moxon promised Cipriano he would cover all of
Cipriano's expenses and fund the Day of the Child charity. Cipriano
believed it was also a reward for his [perjured] deposition testimony
in Berry v. Cipriano / Barton.	Cipriano Decl. III,  54.Tabayoyan
Decl.__________.
July 3,1998:Moxon tells Cipriano that there is no problem with
$520,000.00 for the first year cost of operating Day of the Child.
Moxon does not communicate with Cipriano for several weeks. Cipriano's
friend Snodgrass tells Moxon to immediately meet in Palm Springs or
Cipriano will "disappear." Moxon handwrites an apology.	Cipriano Decl.
III,  55 -58, Ex.19.Cipriano Depo.T.Vol.II, 158:18-160:13.
July 26,1998 (approx.):Moxon instructs Cipriano to rent a Palm Springs
apartment at Moxon's expense.	Cipriano Decl. III,  59.
July 27,1998:Moxon completes rental application, signs 7-month lease
["Kendrick Moxon and occupant Robert Cipriano"], to rent Unit 236, 280
South Caballeros, Palm Springs, CA for $500.00 per month. Moxon pays
the initial $1,074.00.Moxon also directly pays each months rent to the
landlord.	Cipriano Decl. III,  59, Exs.20, 21,22.
July 28,1998:Most weeks, Moxon uses Western Union or Money Gram to
send Cipriano expenses" of  $500.00 - $1,000.00 for living expenses,
groceries and Day of the Child. Checks would be payable to Cipriano
and be deposited at the Wells Fargo bank opposite Moxon's office.
Cipriano Decl. III,  59.
August 6,1998:Moxon federal expresses a letter to Cipriano advising
that New Jersey attorney Lloyd Levinson, Esq. had been retained to
expunge Cipriano's New Jersey felony conviction so that it could not
be used in Berry v. Cipriano/ Barton/ Miscavige [Moxon, Abelson and
Ingram]. Levinson is paid $20,000.00. Moxon implies he obtained the
money from actor John Travolta.	Cipriano Decl. III,  60, --, Ex. 23.
September 1,1998:Moxon tells Cipriano that he will incorporate Day of
the Child as a non-profit corporation and obtain IRS § 501 (c) (3)
tax-free status. After that, Moxon's investors/donors are definite
prospects. Cipriano believes this is return for his [perjured]
testimony in Berry v. Cipriano/Barton/Miscavige [Moxon, Abelson &
Ingram]. Moxon pays for the Nevada incorporation costs. The offices
were at the Moxon leased condo in Palm Springs and also the Moxon
"false front" 622 Sunset Blvd.office.Mail was received there.
Negotiotions (involving scientologist John Ryan) ceased when Berry
dismissed Berry v.Cipriano.No documents were filed with the California
Secretary of State. Eventually, Cipriano and Snodgrass pay for the
§501 (c) status to be filed by the Palm Springs accounting firm Brabo,
Carlson & Cahill.	Cipriano Decl. III,  61,63,Ex.25.Cipriano
Depo.T.Vol.II, 188:22-198:7
September 3,1998:Non-profit Day of the Child World Concert, Inc.
incorporated in Nevada. Cipriano is President, Leslie Lamborn is
Secretary and Moxon is Treasurer. Each are Directors. Moxon uses the
same Palm Springs address as Cipriano and Lamborn. Moxon signs the
Bylaws on October 5,1998 and Cipriano and Lamborn do so October
26,1998.	Cipriano Decl. III,  22,Ex.25.
September 3,1998:Moxon writes to Cipriano stating that he has paid
Cipriano's telephone bill and paid a deposit for the Day of the Child
telephone.	Cipriano Decl. III,  62.Ex.24.
September 8,1998:Moxon revises a proposed merger agreement between Day
of the Child and Children's Charities of America.	Cipriano Decl.
III,  63,Ex.25.
September 10,1998 (approx.):The Star tabloid publishes a report of
Berry filing the CSI v. Pattinson lawsuit naming John Travolta as a
defendant. Moxon requests Cipriano to contact the Star and provide the
First Cipriano declaration and other information regarding Berry.
Cipriano does so.	Cipriano Decl. III,  64.
September 26,1998:Moxon emails Children's Charities of America and
urges them to retain Barbara Reeves, Esq. of Paul, Hastings, Janofsky
& Walker as counsel. "Her husband is a Court of Appeals judge."
[Hiring her enabled the Church to move the then pending Wollersheim
appeal to another panel.] The Paul Hastings law firm will not make
money on the retention. At the time Samuel D.Rosen, Barbara Reeves,
Michael Turrill and the Paul Hastings law firm were representing
Barton in Berry v. Cipriano, Barton, Miscavige (Moxon, Abelson &
Ingram) and____ and Religious Technology Center in Pattinson v.
Miscavige.	Cipriano Decl. III,  65,66, Ex.26).
October 6,1998:1)	Moxon telephones Cipriano and tells him to
lease himself a new Saturn motorcar. His own vehicle had been
"repossessed" by former fiancée Christine Geros.The lease is in the
name of both Cipriano and Moxon. They both use Moxon and Cipriano's
Palm Springs address. The car invoice shows Moxon as the owner and
uses his residential address and business and residential telephone
numbers.2)	Moxon leased Cipriano the car for person use, for his
business use, and to travel between Los Angeles and Palm Springs.3)
Cipriano understood that these things were being provided [by Moxon et
al] to stay the course of the litigation and not to tell the truth.
Cipriano Decl. III,  67, Ex.27.Cipriano Depo.T.Vol.II, 153:6-Cipriano
Depo.T.Vol.II, 155:13-156:15.
October 8,1998: Moxon provides Don Snodgrass with wire transfer
information for transferring $18,500.00 to attorney Lloyd Levinson,
Esq. in New Jersey to expunge Cipriano's felony conviction before
trial in Berry v. Cipriano, Barton, Miscavige [Moxon, Abelson,Ingram].
Cipriano Decl. III,  68,Ex.28.
October 26,1998:Moxon and Cipriano hold a special meeting of the Day
of the Child directors. They accept Leslie Lamborn's resignation and
approve an annual salary of $50,000.00 for Cipriano retroactive to May
1,1998 when he assumed his duties as Executive Director (this was
prior to his testimony in Berry v. Cipriano /Barton / Miscavige
[Moxon, Abelson and Ingram]). Scientologists Leslie McMillan, Joan
Varanelli and Ian Westwood-Booth are elected to the Board of
Directors.	Cipriano Decl. III, Ex.25.
November 3,1998:Moxon requests Cipriano to meet him at his LA law
office. He has obtained $20,000.00 to pay the Lloyd Levinson, Esq.
felony expungment fee. Moxon implies that it has been paid by John
Travolta and suggests Cipriano write and thank Travolta for the money.
Cipriano Decl. III,  70,71.
November 5,1998 (approx.):Moxon requests Cipriano to federal express
Day of the Child information packages to Timothy Bowles, Esq. and
Isadore Chait (a defendant in Berry v. Cipriano, Barton, Miscavige
[Abelson,Moxon, Ingram] in Clearwater, FL. [a Scientology 'Land Base']
using the Moxon & Kobrin Federal Express account.	Cipriano Decl.
III,  72.Cipriano Depo.T.Vol.II, 194:21-195:4,203:21-205:4.
November 20,1998:1)	Isadore Chait, scientologist and CAN Reform
Group defendant in Berry v. Barton, Chait, Shaw, et al., writes a
$1,000.00 check to Day of the Child c/o Moxon & Kobrin. It is used to
open the Day of the Child bank account with its address at the Moxon &
Kobrin law offices. Moxon is Chait's lawyer in Berry v. Cipriano,
Barton [Chait], Miscavige [Moxon, Abelson, Ingram].2)	Other than
Moxon & Kobrin, Chait, Barton, the only other Day of the Child funds
were some payments by Cipriano's Palm Springs friend Don Snodgrass and
the settlement of a bar tab.	Cipriano Decl. III,  72,Ex.32.Cipriano
Depo.T.Vol.II, 194:21-195:4.Cipriano Depo.T.Vol.II, 194:21-195:4.
November 23,1998:Moxon and Cipriano hold a Day of the Child directors
meeting. They approved the opening of a corporate bank account, the
removal of Leslie McMillan as a director and the election of
scientologist John Ryan in her place.	Cipriano Decl. III, Ex. 25.
November 23,1998:1)	Day of the Child is issued an employer ID
number 88-0404499. Initially there were problems with the 501(c) (3)
.It went to the Deputy Director of the Dept. of the Treasury because
of Moxon's involvement as incorporator and director and the role he
may have in day to day operation and the handling of funds. Moxon's
eventual resignation resolved some of the IRS's problems but the 501
(c) (3) is still unresolved.2)	 The Day of the Child IRS Form 1023
lists: Cipriano, President, $95,000.00 pa. Donald Snodgrass, Vice
President, $60,000.00, Leslie McMillan, Vice President,
$40,000.00,Michael Hamra, Director of Internet Sales, $40,000.00 [at
the time he was as senior Earthlink executive]. Leslie Labor is listed
as Secretary /Director. Moxon is Treasurer/Director. All of them,
including Moxon, use Moxon/Cipriano's Palm Springs apartment as their
address for IRS purposes.3)	 Between November 1998 and June 1999
all of Cipriano's financial and professional transactions (all being
monies from Moxon, Kobrin, Paquette, CSI and scientologists (John
Travolta?) were passed [laundered] through Day of The Child World
Concert's bank account c/o the Moxon & Kobrin law office."Moxon… was
the main donor or provider of funds for Day of the Child. There were
Moxon & Kobrin law firm checks, Western Union Money grams and money
from Moxon (CSI-OSA) personally. 	Cipriano Decl. III, 78, Ex.
25,37.Cipriano Depo.T.Vol.II, 206:11-208:5.Cipriano Depo.T. Vol. II,
195:10-198:11.
Insert re Rosen and Moxon Depo questioning, in Berry v.
Cipriano/Barton/Miscavige [Moxon, Abelson, Ingram] of all Berry's pro
bono representation, eliciting the name and location of Hurtado, and
the fact that there had been a pre-representation relationship.
Scientology has a scriptural policy called the doctrine of exchange
under which nothing is given, by the church or others. There must be
money or value traded in exchange for everything, especially church
products, processing and "services". The church was outraged tat Berry
had provided some of those it was using the law to harass, with free
legal representation if they could not afford counsel to defend him or
herself against the church.
December 1998:1)	Ingram makes first uninvited visit to Jenny
Berosteguy, Michael Hurtado's maternal aunt and Eloisa Gonzales,
Michael Hurtado's maternal grandmother. [Ingram also makes a second
visit.]2)	Ingram's purpose is to discuss the domestic violence
restraining order Jenny had obtained against nephew Michael
Hurtado.She "refuses to be his [Hurtado's] victim."3)	Ingram shows
her some papers about an attorney [Berry] who had mentioned Michael's
name. He had [successfully] represented Michael on her restraining
order [it was dismissed].4)	Ingram wanted a photograph of Michael
so she loaned him one, which he had copied. Ingram shows her a copy of
a Michael Hurtado note to his then girlfriend offering to "suck her
daddy's dick."The girlfriend's parents also obtained a restraining
order against Michael.5)	Ingram tells her Berry is an attorney
who is "interested in young "boys. He shows her a magazine cover
picture to of Berry's room-mate [age 22] who Ingram says is a 14 year
old model.6)	Subsequently she spoke with Moxon twice [AC/AWP
Priv.]. See May 2,2000 below.7)	Berosteguy did/does not know of any
affiliation between Ingram and Moxon.8)	Ingram and an unidentified man
(not Moxon) pay surprise visit to Hurtado's parents Miguel and Ana
Marina Hurtado, his sister Vanessa and a family friend (Thomas?).9)
Until Ingram's visit, Michael had never discussed Berry or said
anything about him. No-one else but Ingram has said Berry "likes young
boys." Before Ingram came to the house Michael had not mentioned any
sexual relationship with Berry.10)	Ingram told them" Berry is a
bad guy, he likes young kids, he likes molesting young people.11)
Ingram (and his companion) had "investigated Berry for along time."
They had followed him from New York where they had investigated him
there. A second floor where Berry had young kids 12, 13, 14."He
molested young kids. He was a child molester." He may have taken
advantage of (23 yr. old) Michael. 12)	They wanted to leave a video
of Berry 'talking to Police about Michael" [a depo. tape from Berry v.
Cipriano, Barton, Miscavige (Abelson, Moxon, Ingram)].13)	She
(Hurtado's mother) never discussed Ingram's allegations with Michael
who she thinks may be bi-sexual. Michael never told her Berry had
molested him. Indeed, Michael had brought a cross-dresser home and
taken his mother to a transvestite show in West Hollywood at Santa
Monica and Robertson. Ingram also told her that a Michael had a friend
Mirella who had a cross-dresser friend, David Percy.14)	Michael has
problems with drink, drugs and becomes aggressive, violent and
abusive. He has stolen things from family and has numerous arrests and
police contacts.15)	Before they could discuss what Ingram had said
with Michael, the very same day Ingram took her, Michael's Dad and the
family friend to see lawyer Wager. It was Ingram who asked them to
meet with lawyers Moxon and Wager.16)	No-one spoke with Michael
Hurtado between Ingram's first visit and the meeting with Moxon, Wager
and Ingram and the agreement that Michael would fire Berry as his
lawyer, replace him with Wager and have Moxon sue Berry on Hurtado's
behalf.17)	Michael Hurtado's mother has met Moxon 3-4 times. The
first time was the day of Ingram's first visit when he took her,
Miguel, Vanessa and the family friend to meet with Moxon and Wager. At
Wager's office, Wager and Moxon discussed Moxon and Ingram replacing
Berry as Hurtado's lawyer. Nobody spoke of fees and they have never
received a bill for representation on that drug paraphernalia case.
The meeting lasted 1hr.45 mins. Michael was not there [and did not
know of the meeting]. It was agreed that Wager would replace Berry, as
Michael's lawyer and Miguel Hurtado would tell his son Michael.18)
Ingram told her in 1998 that Michael will get money as a result of his
case against Berry.19)	Ingram visited Hurtado's house and parents 3-4
times. Michael met with Ingram on his second or third visit to the
house.20)	On the second visit to the house it was the same
theme. Berry taking advantage of little boys. Ingram was still
investigating Berry from New York, a child molester who may have taken
advantage of Michael. Most of the conversation was between her husband
and Michael. [Moxon and CSI have always blocked deposition of, or
questioning of, Hurtado's father because of his heart problems.]21)
Moxon has spoken with Miguel Hurtado by telephone on a number of
occasions.22)	Abelson communicates with former LA Deputy DA Wager re
Hurtado. Between late 1998 and 1/22/99 Wager and Ingram discuss 'the
Hurtado matter' approx. three times.23)	Abelson was representing
CSI.24)	Ingram was working for Moxon, CSI and Hurtado's father.25)
CSI was Moxon's client.26)	Moxon first consulted Wager 5 -10
years ago. Wager has worked on at least two cases "referred" by Moxon.
One was a 1999 "juvenile" matter [AC/AWP Priv.]a)	Moxon did not
have an attorney client relationship with Hurtado at the time.b)
Although Wager does not meet with Michael Hurtado until___ or sign a
retainer agreement until 1/27/99, he begins billing for Hurtado
representation in December 1998.	Eloisa Gonzales Depo.
9:17-12:17.Jenny Berosteguy Depo.10:
12-14,21:17-24,25:13-14.Berosteguy Depo.21: 17-24.Berosteguy
Depo.T.23: 11-14,24:1-13.Berosteguy Depo.T.24: 20-25:5.Berosteguy
Depo. T. 25:6-12.Berosteguy Depo.28: 23-30.Berosteguy Depo.T.31:
9.Berosteguy Depo.T. 36:20-22.Ana Marina Hurtado Depo.T.28: 18-Ana
Marina Hurtado Depo.T.26: 24-27:14, 29:25-30-20,50:1-12.Ana Marina
Hurtado Depo.T.26: 24-27:11.Ana Marina Hurtado Depo.T.31:
14-34:16,37:2-38:8.Ana Marina Hurtado Depo.T.39: 21-40:6.Ana Marina
Hurtado Depo.T.13: 10-26:1.Ana Marina Hurtado Depo.T.34:
18-35:8,59:6-17.Ana Marina Hurtado Depo.T.83: 3-85:12.Ana Marina
Hurtado Depo.T.45: 4 - 48:6.Ana Marina Hurtado Depo.T.95: 14-21.Ana
Marina Hurtado Depo.T.36: 21-23,38:15-17.Ana Marina Hurtado Depo.T.38:
19-39:11,97:17-23.Ana Marina Hurtado Depo.T.94: 20-95:14.Wager Depo.
T.26: 6-20.Wager Depo. T.26: 1-18.Wager Depo. T.19: 20 - 20:5.Wager
Depo. T.27: 6-15; 32:7-34:20; 35:1.Wager Depo.T.43: 18 - 45:15.Robert
Vaughan Young letter_____.Wager Depo. T.6: 21-15:4.Wager Depo. T.33:
11-34.Wager Depo. T.6: 21-15:4.
December 5,1998 (approx.):Cipriano is present when Moxon is conversing
with Berry's then law partner Steven Lewis who is allegedly providing
Moxon with personal and private information about Berry. Moxon is
advising Lewis how to terminate his retention as Berry's law partner
and counsel in the Berry v. Cipriano/ Barton/ Miscavige [Moxon,
Abelson & Ingram] litigation. Moxon claims Lewis and Scali have been
discussing working with Moxon & Kobrin. [see below___]	Cipriano Decl.
III,  75.
December 15,1998 (approx.):Polygram record executive and scientologist
John Ryan and Moxon unsuccessfully demand of Cipriano (Moxon's own
client) that scientologists take-over Day of The Child.	Cipriano Decl.
III,  74,76,77.
December 17,1998:Moxon uses his credit card to purchase a $1,000.00
Packard Bell computer system, as a 'gift' for Cipriano, from Circuit
City in Hollywood; CA. Moxon carries it to Cipriano's car. Cipriano
returns Moxon to his office. The computers hard drive is now secure in
a bank safe deposit box, rented by Berry. [It was never used for
anything remotely connected to the defense of Berry v. Cipriano,
Barton, Miscavige (Moxon, Abelson & Ingram)].	Cipriano Decl. III,
79, Ex.38.
December 22,1998:New Jersey attorney Lloyd Levinson, Esq. informs
Cipriano that Moxon had wired him $20,000.00 to pay the restitution
balance of $18,500.00 and that he had Levinson refunded unused fees to
Day of the Child. He wired payments of $2,500.00, $1,400.00 and
$988.55 into the Day of the Child bank account.	Cipriano Decl. III,
73, Ex. 33-36.
January,   1999:1)	Hurtado did not have any thought of suing
Graham Berry before Ingram went to his house.2)	Hurtado first met
Ingram when Ingram came to his house. Hurtado's grandmother, parents
and two sisters were also there.3)	Ingram showed Hurtado and his
parents a videotape of part of Berry's deposition testimony in Berry
v. Cipriano, Barton, Miscavige [Abelson, Moxon & Ingram] re his
representation of, relationship with, Hurtado. 4)	Hurtado was
very upset after Ingram told his family he had had sex with Berry. He
does not recall if Ingram threatened to tell other people too.
[Berry responded to Hurtado: "I was under oath and had to tell the
truth"]5)	Ingram told Hurtado that Berry [then Hurtado's legal
counsel] had sex with minors, seduced people on the Internet, was not
a man of his word, cheated people and was a bad guy.6)	Ingram told
Hurtado that he had been investigating Berry having sex with minors
for a long, long time. 7)	Ingram showed Hurtado and his family
the First Cipriano Declaration saying Berry was a pedophile or liked
little boys.8)	Hurtado "figured…a person like this doesn't deserve
anything good; so I just don't believe in a person in a career that
should be able to have sex with minors, and do drugs and offer drugs
to minors. I don't believe in that; so that is why I am suing."9)
Ingram was working on behalf of Moxon & Kobrin.10)	Ingram told
Hurtado he could file a civil law suit against Berry and possibly get
money.11)	Ingram [misrepresented] to Hurtado that Berry had been
previously sued. for having sex with minors. 12)	Ingram told
Hurtado that Berry's conduct could affect Hurtado really bad
physically and mentally, cause Hurtado to feel hate," and it's a great
opportunity…to sue him."13)	 Ingram told Hurtado: Moxon was an
attorney watching Berry for a long time because Berry is a bad person.
Moxon had "been trying to bury the guy" [Berry] for his wrongdoings
for a long time.	Michael Hurtado Depo.T.161: 16-162:6.Michael
Hurtado Depo.T.118: 16-120:16.Michael Hurtado Depo.T.123: 5-22.Michael
Hurtado Depo.T.193: 11-194:7.Michael Hurtado Depo.T.131:
16-132:6.Michael Hurtado Depo.T.131: 16-.Ana Marina Hurtado Depo.T.65:
13-67:1.Michael Hurtado Depo.T.131: 11-16.    Statement of Ava
Paquette, Esq. Michael Hurtado Depo.T.128: 16-18.    Hurtado Depo.T.
________.    Michael Hurtado Depo.T.129: 24-131:4.Michael Hurtado
Depo.T.132: 10-18.  Michael Hurtado Depo.T.134: 3-9.  Michael Hurtado
Depo.T.133: 19-137:1.

January  1999:1)	Hurtado's father takes Hurtado to see Wager.2)
Ingram takes Hurtado to meet with Moxon.3)	Ingram introduces
Hurtado to Moxon and a civil attorney [Wager].4)	Hurtado fires
Berry as his attorney and hires Wager and Moxon.	Michael
Hurtado Depo.T.126: 22-127:12.Michael Hurtado Depo.T.137:
24-25.Michael Hurtado Depo.T.124: 12-23Michael Hurtado Depo.T.126:
22-127:12; 137:4-14.
January 4,1999 (approx):1)	Cipriano is summoned to Los Angeles to
meet with Moxon and Ingram at Moxon's "false front" 6255 Sunset Blvd.
Office.2)	Ingram had found a picture of Berry's roommate [aged
22] on a magazine cover and were investigating his age.3)	Ingram
also said they had leafleted all of the cars in Berry's home
neighborhood in connection with Hurtado's allegations.4)	They
were using Hurtado's allegations for another State Bar complaint
against Berry.5)	Moxon and Ingram tell Cipriano that Ingram and
some scientologists had plastered Berry's neighborhood with flyers
advising everyone that Berry was a pedophile. They also tell Cipriano
that Ingram has found a young man, Michael Hurtado, to allege that
Berry had sex with a group of underage boys.6)	Hurtado was to be used
as [corroborating witness] for Cipriano's [perjury] in Berry v.
Cipriano, Barton, Miscavige [Moxon, Abelson, Ingram].7)	Ingram joked
about Berry not being able to serve Ingram in the Berry v. Cipriano,
Barton, Miscavige [Moxon, Abelson, Ingram] case." The litigation and
scare tactics against Mr. Berry were just to make him go away and
leave the Church of Scientology alone." Ingram is continuing to
investigate Berry's relationships.8)	 Moxon and Ingram instruct
Cipriano to meet with the Los Angeles Youth Council, an entity within
the City of Los Angeles administration. It deals with teenage runaways
and underage male prostitutes.	Cipriano Decl. III,   81 - 83.
Cipriano Depo.T.Vol.II, 106:22-111:11.Cipriano Depo.T.Vol.II,
150:18-151:4.Cipriano Depo.T.Vol.II, 111:2-114:21.
January 5,1999 (approx.):1)	Moxon calls Cipriano in Palm Springs
and advises that Jason Whitman of the LA Youth Council and young male
prostitutes distributed flyers around West Hollywood, with a picture
of Berry, seeking information on him. The flyers stated that Berry is
a pedophile who preys upon underage male prostitutes and drugs them.
The information was to be given to Ingram for Moxon to use against
Berry. A transvestite named Anthony Apodaca was willing to testify
that he had been with Berry. Arrangements were made for Ingram to
interview Apodaca.2)	 Subsequently, Jason Whitman expresses anger
at what had been done with Apodaca who had tearfully informed Whitman
that Moxon and Ingram had put him in a Santa Boulevard area hotel,
paid him $300.00 and given clothes. "Scientology is very evil. They
hurt a lot of kids. We do not want that organization or any of those
people involved with [the Youth Center programs]."	Cipriano Decl.
III,   84,85.Cipriano Depo.T.Vol.II, 114:22-115:10.Cipriano
Depo.T.Vol.II, 115:11-120:7Apodaca Depo.T. _________.
January 11, 1999:Last possible date by which Wager first had contact
with Moxon re Hurtado. They conversed at least six times before Wager
first met Michael Hurtado.	Wager Depo. T.27: 19-28:4.
January 22,1999:Wager, Moxon and Ingram communicate and meet with
Michael Hurtado's father, mother and family friend. Wager has not met
with or talked to Michael Hurtado.	Wager Depo.T.24: 15-25.
January 25,1999:1)	A/C-AWP Confidential document from Hurtado to
Ingram.2)	Wager replaces Berry as counsel for Hurtado in People
v. Hurtado.3)	Hurtado leaves voicemail firing Berry and denying he
ever had sex with Berry.	Wager Depo.T: 6:21-15:4.Wager Depo.
T.128: 11-13.Michael Hurtado Depo.T.181: 20-182:23.
January 26,1999:Wager receives probation report in People v. Hurtado.
Wager Depo. T.128: 17-22.
January 27,1999:1)	Wager and Hurtado execute attorney-client
retainer agreement.2)	Ingram provides Wager with a declaration sworn
by Hurtado. Wager did not prepare it. Wager filed it in Santa Monica
Court. The Presiding Judge refers the Hurtado allegations as against
Berry, and presented by L.A.County Criminal Bar Association President
Wager, to the California State Bar, and an investigation is opened.
[______]	Wager Depo. T.6: 21-15:4.Wager Depo. T.133: 3-21.
January 29,1999:Hurtado/ Wager/ Moxon/Ingram, etc. Interview Notes
signed by Hurtado [AC/AWP Priv.]	Wager Depo.T.6: 21-15:4.
January 30,1999(approx.):Moxon and scientologist John Ryan meet
Cipriano and Leslie Lamborn and take them to secluded beach near
Malibu. Moxon and Ryan persuade Cipriano to separate from Lamborn and
move back into Los Angeles, closer to them. Cipriano moves in with
friends in Marina Del Rey. Moxon provides the friends with free
litigation representation.	Cipriano Decl. III,  87.
February 5,1999(approx): Moxon tells Cipriano that Berry had dismissed
Cipriano co-defendant Krim (but did not disclose the $75,000.00
settlement) and said that Berry was about to dismiss Cipriano.[At no
time did he disclose the $25,000.00 settlement with the Lewis, D'Amato
law firm in Berry v. Miscavige [Moxon, Abelson & Ingram].
Cipriano Decl. III,  88.
February 6.1999 (approx):Moxon tells Cipriano that the [Berry v.
Cipriano, Barton, Miscavige (Moxon, Abelson, Ingram)] lawsuit was over
and misrepresents that Berry could not sue him again. Moxon tells
Cipriano that they have attached Berry's bank accounts and that Berry
was leaving the country for good." Scientology finally achieved what
they wanted…you certainly did serve your purpose."	Cipriano Decl.
III,  88 - 89.
March 8,1999:Moxon asks Cipriano to become a covert scientology
operative. Cipriano was steal internal documents from hospitals. The
documents would relate to E.C.T.'s electro-shock machines [which the
Church of Scientology wanted, removed from hospitals and the market
place, as part of the Church's plan to destroy and eliminate the
entire mental health profession and to replace it with Scientology.]
Cipriano Decl. III,  92.
March 12,1999: 1)	Cipriano moves back to Palm Springs. There are
irregular emails with Moxon between March 12,1999 and June 1999.At
Cipriano's request, and because of IRS problems, Moxon resigns as a
Day of the Child director and the Treasurer.2)	Moxon & Kobrin
attorney Ava Paquette, Esq. states that she 'has just come into this
[Hurtado v. Berry] case and, in the evening, is "told to [go] to Robie
& Matthai and represent Eloisa Gonzales, for free, at deposition in
Hurtado v. Berry.	Eloisa Gonzales Depo: 8:8-18; 59:20-25;
63:2-5.
March 16,1999:Wager, Abelson and Ingram meet with LA County Sheriff's
Detective Petz to [unsuccessfully] seek Berry's arrest and indictment
for alleged "pandering" in connection with Hurtado. Abelson was
representing the Church of Scientology as "in house" attorney (which
claims AC Priv. on communications between Wager and Abelson).	Wager
Depo. T.103: 9-107:10.
March 20,1999:Cipriano emails Moxon that he needed money in accordance
with their agreement. He "was there for the cause-100%…" Moxon
responds: "Got it. Please give me a call so that we can handle the
details."	Cipriano Decl. III,  93,Ex. 45,46.
March 29, 1999:Wager leaves message with LA Deputy DA Paul Turley
regarding meeting to discuss prosecuting Berry in connection with the
Hurtado pandering claim.	Wager Depo. T.103: 22-23.
April, 1999:Deputy DA Norm Wakener in Santa Monica is handling the
Hurtado drug paraphernalia prosecution.	Wager Depo. T.108: 14-20.
April 1,1999:Wager meets with LA Deputy District Attorney Paul Turley
to request that Berry be prosecuted for pandering in connection with
Hurtado's claims.	Wager Depo. T.103: 9-109:9.
April 5,1999:Moxon files Hurtado v. Berry in Cal. State Court and
within the hour serves Berry, inside a federal courtroom, as he is
about to rise to his feet and address U.S.D.C. Judge Snyder in
opposition to Moxon's Rule 11 motion for sanctions for alleging Moxon
to be engaged in CSI criminal activity in Pattinson v. Miscavige, CSI,
et al.	
April 12,1999:$50.00 deposition witness fee prepared for Apodaca's
deposition in Hurtado v. Berry.	Wager Depo. T.62: 19-63:1.
April 13,1999:1)	Wager meets Apodaca for the first time at L.A.
Men's Central Jail. Cannot remember if Ingram present.2)
Hurtado has never met Apodaca.3)	Apodaca was not a witness in
the People v. Hurtado drug paraphernalia case.4)	There was a
real question in Apodaca's mind as to who Berry was.5)	Wager
deposited $300.00 in Apodaca's jail account "so he would have money".
Wager 'thinks" it was his money but Moxon may have re-imbursed him.
Wager was not Apodaca's lawyer. Judge Lachs recommends this invokes
the crime/fraud exception to the AC/AWP Priv. Wager Depo.T.55: 3-4]6)
Deposition of Hurtado's mother, Ana Marina Hurtado, in Hurtado v.
Berry. Ava Paquette represents her.	Wager Depo. T.45: 16-46:6;
48:7-19.Michael Hurtado Depo.T.25: 14-16.Wager Depo. T.64: 22-25.Wager
Depo.T.53: 10-59:18.
April 21,1999:Wager's final communication with LA Sheriff's Detective
Petz about Petz's recommendation that there is insufficient evidence
on which to indict Berry for pandering.	Wager Depo. T.115: 18-21.
April 22,1999:1)	At the second meeting between Wager and
Apodaca, Apodaca could make no statement that would confirm any
activity between Hurtado and Berry.2)	The second Apodaca meeting was
at Moxon's office. 3)	Moxon and Ingram were present at the second
Apodaca meeting.4)	Apodaca was wearing female makeup.5)	Wager
did not pay for the video taping of the second Apodaca meeting.6)
There may have been money given to Apodaca at the second meeting, but
not by Wager. [A/C as to who]7)	The witness fee in Hurtado v. Berry
was paid at the second Apodaca meeting.	Wager Depo. T.58: 10-11; 65:
11-17.Wager Depo. T.50: 12-15.Wager Depo. T.48: 17:22; 58:7-16.Wager
Depo. T.50: 5-8.Wager Depo. T.52: 16-21.Wager Depo. T.60: 6-20.Wager
Depo. T.60: 16-61:1.
April 23,1999:Wager's last communication with LA Deputy DA Turley
regarding the requested [false] criminal complaint against Berry in
connection with Hurtado's allegations re pandering.	Wager Depo. T.
___.
May 1999:1)	Wager recalls communicating with a Service
organization re Apodaca.2)	Jason Whitman of the LA City Los
Angeles Youth Council informs Cipriano that Ingram had taken
transvestite Anthony Apodaca to a hotel written, threatened him and
paid him $300.00 for a declaration to use against Berry [in Berry v.
Cipriano, Barton, Miscavige (Moxon, Abelson, Ingram)].	Wager Depo.
T.66: 6-15.Cipriano Decl. III,  85.
May 10 1999:Cipriano emails Moxon that he may have a new partner, Roy
Webb of Anaheim, CA. Moxon replies that the Palm Springs house, being
leased and paid for by Moxon & Kobrin, needed to be resolved.
Cipriano Decl. III,  94,Ex.47.
June 7,1999:Cipriano sends his last email to Moxon requesting $500.00.
Moxon sent $195.00 by Western Union. Moxon also sends $800.00 to
Professional Management, owned by Roy Webb.	Cipriano Decl. III,
95.Ex.48.Cipriano Depo.T.Vol.II, 210:13-211:20.
July 5,1999 (approx.):Moxon calls Roy Webb and asks: "How's Robert's
health?" Cipriano interpreted this as a threat.	Cipriano Decl. III,
96.
July 15,1999(approx.):Ingram's employee, Joanne Weaton, and
International Association of Scientology staffer Erla Hawkins try to
persuade Cipriano to accept a one way fare to Europe to accept a
volunteer position with a Scientology crusade in Europe starting July
22,1998. Cipriano is asked to meet in 'an old unmarked apartment in an
old building behind a schoolhouse' on L.Ron Hibbard Way in Hollywood,
CA. Cipriano is concerned for his safety and does not attend.
Cipriano Decl. III,  96,Ex.49.
July 16,1999:Cipriano executes his third declaration with Exhibits.
Cipriano expresses his fear and terror of Moxon and Ingram but
describes what has happened and admits that the First Cipriano
declaration and his testimony by declarations and deposition in Berry
v. Cipriano/ Barton/ Miscavige (Moxon, Abelson and Ingram) is perjury
extorted by Ingram and suborned by Ingram, Moxon and Rosen.
Cipriano Decl. III,  101,Ex.50.
August 1999:1)	Wager 20-page timesheet for representation of Michael
Hurtado between December 1998 and August 1999.2)	Moxon pays
Wagers bills for representing Hurtado.3)	There were lots of
billings during times there were no court appearances.4)
However, Hurtado claims he paid Wager some money to represent him and
was going to pay him in full. Hurtado paid Wager in cash at the end of
the case. He got the money from doing extra work. Hurtado does not
know how much he paid Wager in cash!5)	Wager also works for Moxon in
the      Hurtado v. Berry civil case.	Wager Depo. T.6: 21-15:4.Wager
Depo. T. ______.Wager Depo. T.90: 10-21.Michael Hurtado Depo.T.140:
22-141:24.Wager Depo. T.92: 18-93:13.
August 12,1999:Wager appears again for Hurtado in People v. Hurtado
(drug paraphernalia case.) [where 8 months previous he was represented
by Berry with a drug diversion and probation sentence until withdrawn
by Wager].	Wager Depo. T.62: 1-11; 116:1-13.
December 7,1999:Moxon deposes Berry in Hurtado v. Berry before Hon.
Diane Wayne (Ret.). Lynne Shape, Scientology Sea Org. member and CSI
OSA staffer, attends to assist Moxon.[She reports to Church of
Scientology "ecclesiastical leader and pope" Captain David Miscavige.
Berry denies and contradicts Hurtado's material allegations.]	Berry
Depo.Transcript.
December 23/24,1999:Following Cipriano's August 9,1999 Declaration and
50 exhibits (the Fourth Cipriano Declaration], Moxon pays a surprise
visit to Cipriano in Palm Springs.Moxon presents Cipriano with two
documents. One is an agreement that Cipriano would never sue Moxon &
Kobrin and that he indemnified them for all wrong done! The other
recanted certain statements in the Fourth Cipriano Declaration. Moxon
offered to pay Cipriano $500.00 if he would sign both documents. They
bargained and eventually agreed that Moxon would pay Cipriano $800.00
if he signed the two documents. Moxon paid the $800.00 to Cipriano
directly and not Day of The Child.Cipriano was "financially
destitute", "shattered emotionally". He had been selling valuable
possessions just to live. Cipriano thought that just signing it would
make Moxon, Ingram and Berry just go away. The $800.00. would be a
security deposit on an apartment and Cipriano could then get on with
his life.[Moxon also told Cipriano that he had them under audio/video
surveillance from a large white cargo van parked opposite on the
street.]	Cipriano Depo.T.Vol.II, 211:21-213:8,214:17-215:15.
January 21,2000:1)	Deposition of Santa Monica Police Sergeant
Alfred Acosta in Hurtado v. Berry as to the arrest, with Officer
Fenochio, of Hurtado for the possession of Drug paraphernalia, and the
basis for any motion to suppress evidence to alleged lack of consent.
Moxon is present and engages in aggressive objections to the Officer's
evidence.2)	Deposition of Santa Monica Police Officer Adam Barry
in Hurtado v. Berry. He had joined Officers Acosta and Fenochio at the
Hurtado drug paraphernalia arrest. He corroborates Acosta's testimony
that Hurtado consented to the search. Officers Murphy and Flores were
also involved. Moxon is present at the deposition.	Alfred Acosta
Deposition Transcript.Adam Barry Deposition Transcript.
January 6,2000 - May 8,2000:Wager enters an appearance as co-counsel
of record in Hurtado v. Berry State Court civil action.	
January 11,2000:1)	Hurtado arrested/charged again, with
residential burglary and stalking. Pleads no contest. Sentenced to one
year in LA County Jail where Hurtado is classified as a homosexual, at
his own request, but later de-classified after failing the LA County
Jail "homosexual test."2)	Hurtado had broken into his
ex-girlfriends apt. He was found passed out drunk in her bedroom
closet grasping a large knife. He had been stabbing her bed and had
sliced the bedding from head to foot.3)	Wager declines to represent
Hurtado    on new criminal charges. Hurtado was    represented by
Thomas Byrnes, Esq.4)	He got the name from another jail inmate.5)
Hurtado's father and grandmother    [actually?] paid Byrne's legal
fees!	Michael Hurtado Depo.T.16: 14-19:20. Ana Marina Hurtado
Depo.T.9: 18-25,14:18-23.Ana Marina Hurtado Depo.T.88: 13-91:15.Wager
Depo. T. 116:1-13.Michael Hurtado Depo.T.148: 2-15. Ana Marina Hurtado
Depo.T.16: 11-16.Michael Hurtado Depo.T.174: 6-12. Ana Marina Hurtado
Depo.T.15: 24-16:1.
January   ,2000:1)	Mariah Rivera was the victim of the
residential burglary and stalking charge.2)	Ingram conversed with
Hurtado about his residential stalking and burglary charge and Mariah
Rivera.3)	Ingram was willing to testify for Hurtado in the new
prosecution. He had met Mariah Rivera.4)	Hurtado, in jail,
asked Ingram to investigate some checks that Mariah Rivera had stolen.
Nobody paid Ingram for doing it. Hurtado was going to pay Ingram after
he got out of jail.5)	Ingram visits Mariah Rivera, a people's
witness in People v. Hurtado. She refuses to co-operate with Ingram
and his pressure that she not testify against Hurtado. Ingram reports
the stolen check matter to her employer and she is fired.
Michael Hurtado Depo.T.150: 3-5.Michael Hurtado Depo.T.171:
5-11.Michael Hurtado Depo.T.171: 12-172:3.Michael Hurtado Depo.T.173:
4-174:5.
March 12,2000: 1)	Moxon & Kobrin attorney Ava Paquette, Esq.
states that she 'has just come into this [Hurtado v. Berry] case and,
in the evening, is "told to [go] to Robie & Matthai, the next day, and
represent Eloisa Gonzales, for free, at deposition in Hurtado v.
Berry.2)	On_____, 1999, Berry sent Paquette a detailed letter
putting her on notice of the wrongful conduct (criminal, tortious and
ethical) being perpetrated by her principals, partners, employees,
agents and co-counsel in these matters.	Eloisa Gonzales Depo: 8:8-18;
59:20-25; 63:2-5.
March 13,2000:Eloisa Gonzales (Hurtado's grandmother) is deposed in
Hurtado v. Berry. Moxon & Kobrin (Paquette) provide "free" legal
representation.	Eloisa Gonzales Depo.T.8: 8-18.
April 13,2000:1)	Amy Esther Garcia (ex de facto of Joseph
Gonzales, Michael Hurtado's uncle, deposed in Hurtado v. Berry. Ava
Paquette represents her.2)	November 1999 Michael Hurtado and
cousin Wesley stole 2 VCRs from her and Joseph. Michael has stolen
from others too.3)	She has heard him threatening arson, murder
and being aggressively confrontational, and arrested for violating
restraining orders.4)	Michael has been abusing alcohol and drugs
since he was 17.5)	Michael's sister Vanessa has told her that
Michael and his cousin /best friend Wesley are bi-sexual and "will
sleep with anything."6)	Ana Marina Hurtado (Hurtado's mother) deposed
in Hurtado v. Berry. Ava Paquette meets with her two weeks previously
and provides free representation. " They would not be able to afford a
lawyer!" She understood that Paquette worked for Moxon.	Amy Esther
Garcia Depo.T.1, 7:1-4.Amy Esther Garcia Depo.T.9: 23-15:24.Amy Esther
Garcia Depo.T.14: 25-15:17.Amy Esther Garcia Depo.T.22: 17-25:13.Amy
Esther Garcia Depo.T.27: 12-28:23,32:5-34:14.Ana Marina Hurtado
Depo.T.61: 18-62:17.
May 2,2000:Jenny Berosteguy (Hurtado's aunt) deposed in Hurtado v.
Berry. Ava Paquette provides free legal representation. Moxon & Kobrin
are not her attorneys.	Berosteguy Depo.T.31: 9-35:20.
May 3,2000:Deposition of John James [Doe], III as to Hurtado's active
involvement in homosexual prostitution, and sex with Hurtado, at the
time Hurtado first met Berry and was later solicited by Ingram, Moxon
and Wager to allege, under oath, that he had never had sex with a male
and had been raped by Berry. Ava Paquette also attends.	John James
[Doe] III Depo.T.10: 14-21:18,27:19-28:11.
June 12,2000:First day of Cipriano's deposition in Hurtado
v.Berry.Paquette appears for Hurtado.After the first hour of
deposition, Paquette calls her partner Moxon at the Church of
Scientology Land Base in Clearwater, Fl. Moxon calls back and suspends
the deposition because he is party (!) and is entitled to be there.
His motion for a protective order is denied and the deposition resumes
on August 7,2000.	Cipriano Depo.T.Vol.I. ___.
July 17,2000:Berry's former law partner Stephen Lewis deposed in
Hurtado v. Berry. He is represented by Ava Paquette of Moxon & Kobrin
with whom he has earlier met and prepared (scripted) his testimony.
[See Dec.5, 1999]	Stephen Lewis Depo: ________
July 26,2000:Miguel Hurtado's heart specialist, Antoine Hage, M.D.
deposed in Hurtado v. Berry on the claim that Miguel Hurtado is too
ill to be deposed. The deposition of Miguel Hurtado does not get
taken. He is represented by Ava Paquette of Moxon & Kobrin.
Antoine Hage, MD, Depo.Transcript.
August 7,2000:1)	Cipriano's deposition in Hurtado v. Berry
resumes. Moxon and Paquette appear on behalf of their client Hurtado
to conduct (withering) cross-examination of their former client
Cipriano, and without waiver of conflict, in matters [substantially
similar] identical to those they had represented Cipriano on.2)	The
deposition is attended by Lynne Shipe, a Church of Scientology Sea
Org.member and senior CSI Office of Special Affairs Staffer. She
apparently reports to Captain David Miscavige, the "Pope" of the
Church of Scientology! Asked whether she is a member of the Church of
Scientology.Moxon expressly represents that she is just a para-legal
who works in his office.3)	 Moxon continues to obstruct
questioning.4)	 Moxon even threatens Matthai with a State Bar
proceeding unless she stops deposing Cipriano.5)	That morning,
outside the deposition building Moxon confronted Cipriano who told
Moxon he wanted "this to end and the truth will come out."6)	It was
Cipriano's understanding that Moxon & Kobrin were providing him with
benefits and money in order to "stay the course" and not tell the
truth. These benefits and payments included the Saturn motor car, the
Day of the Child incorporation and program, the Palm Springs
apartment, the Palm Springs house (five bedrooms and pool), paying off
the $28,000 felony restitution order (and expungement of same) in New
Jersey, the payment of his food and living expenses for a year and the
$2,500.00 'disconnect' payment to former fiancée Christine Geros.7)
Cipriano had [been] moved from Los Angeles to Palm Springs to get away
from Christine Geros, from Berry, the Berry v. Cipriano, Barton,
Miscavige (Moxon, Abelson, Ingram) lawsuit. Cipriano prepared budgets
for Day of the Child expenses (including Cipriano's personal, living
and business expenses) and sent them to Moxon.8)	Cipriano
complains that Moxon still [refuses] to return Cipriano's files in
Berry v. Cipriano, Barton, Miscavige (Moxon, Abelson, Ingram) to him
[still unreturned 24 months later].	Cipriano Depo.T.Vol.II,
48:5-14.Cipriano Depo.T.Vol.II, 44:25-45:12.Cipriano Depo.T.Vol.II,
52:12-55:3,57:1-58:16,59:22-60:5,122:24-125:24, (Paquette 127:6-13),
127:12-135:19,136:1-8,139:9-140:21,141:18-142:16,145:9-13,149:22-150:12,156:7-9,163:7-16,176:21-177:11(untrue
statements on record), 179:14-24(Paquette),Cipriano Depo.T.Vol.II,
131:17-24.Cipriano Depo.T.Vol.II, 54:13-17,56:22-24.Cipriano
Depo.T.Vol.II, 155:13-177:14 (and underlying exhibits).Cipriano
Depo.T.Vol.II, 157:18-158: __.Cipriano Depo.T.Vol.II, 183:3-14.
January 19,2001:1)	Thomas Byrnes, also  Hurtado's       counsel,
submits brief to LASC Judge   Lachs (Ret.) that the Church of
Scientology had and has nothing to do   with Hurtado v. Berry.2)
Judge Lachs opines/recommends that  all of these people [CSI, Abelson,
Moxon, Ingram, Wager, Hurtado,  Apodaca] "seem connected."3)
Retired  Judge Stephen Lachs recommends to  LASC Judge Hart in Hurtado
v. Berry that the Cal. Evidence Code § 956 crime/fraud exception
applies to claims of Attorney-client privilege as between, at least,
between Church of Scientology, CSI, Moxon, Abelson, Ingram, Wager,
Hurtado, Apodaca.	Wager Depo. T.29: 8-30:1; 33:3-10.Wager Depo.
T.35: 3-5.
February 6,2001:Thirty days before a jury trial, Hurtado voluntarily
dismisses Hurtado v. Berry, Case No. LASC BC 208227. Berry's motions
to bar assertion of the attorney client privilege on the ground of the
crime/fraud exception (Evidence Code §956), to compel Moxon & Kobrin
to produce the supoena evading Ingram for deposition,compel other
discovery responses and production by Hurtado, are fully briefed and
pending before the trial court.As a matter of law, it is an
adjudication upon the merits in favor of Defendant Berry.	
July 10,2001:Hurtado voluntarily dismisses Bankruptcy Court Adversary
action, Hurtado v. Berry, U.S.B.C. CD Ca Case No. LA 99-32264 ER, AD
99-002559 ER.The Court orders it dismissed 'with prejudice.'	
July 17,2001:1)	Berry receives information, originally from inside
OSA, that CSI is "going after him" again because of his State Bar
defense. Did they ever stop!2)	Berry does quick internet search and
finds the First Cipriano Declaration and it's contents (now
demonstrably false and defamatory) still being published 3 ½ years
after first filing Berry v. Cipriano, Barton, Miscavige (Moxon,
Abelson & Ingram).