DECLARATION OF GRAHAM E. BERRY

I, GRAHAM E. BERRY, hereby declare and state as follows:

1. I am over the age of 18, resident and domiciled in the State of California. I have personal knowledge of the matters set forth herein and, if called upon to do so, would so testify.

2. On October 17, 2002, at approximately 11:15 am I departed from my home in Mar Vista, Los Angeles, California for Ida Camburn's home in Hemet, California. My purpose was to visit my 79-year-old friend and to respond to the concerns of others as to her safety in light of certain recent events appearing to be further Church of Scientology ("the Cult") harassment of her. I took the 10 Freeway to Highway 79 near Beaumont, CA. I then took Highway 79 to State Street in Hemet, thence to Stetson, Elk and finally to Vista Grande where Ida resides. It is the route upon which I do not get lost on. Usually, when I take the alternate route via Sanderson Avenue in Hemet I get lost trying to find Vista Grande and the Retirement Community in which Ida resides.

3. I drove past the Church of Scientology's Golden Era Productions ("the Base") at Gilman Hot Springs, I lowered the car's sun visors so that the Cult's remote controlled surveillance cameras would not see my face. The Cult's remote controlled surveillance cameras record the faces and license plates of all vehicles that pass the Base. This also happens on Sunset Boulevard, L. Ron Hubbard Way and Fountain Avenue in Los Angeles in front of the Cult's facilities there. Additionally, it also happens along Hollywood Boulevard in Los Angeles where more than seven major Cult buildings are located, such as on the corner at Hollywood Boulevard and Ivar Avenue. Consequently, all pedestrians on Hollywood Boulevard are under continuous Scientology remote controlled camera surveillance. Further information regarding the Cult can be located and read at: http://www.xenu.net/ and http://www.lermanet.com/ and http://www.factnet.org/ and http://www.gerryarmstrong.org/ and http://holysmoke.org/

4. While driving past the Cult's Base (their "heavily armed" international headquarters) I noticed heavy earthworks and what appeared to be defensive berms being constructed around what is reported to be a heavily armored building being constructed so as to be able to withstand a "Waco" style ATF or other armed assault. Indeed, in my January 21, 2002, pending criminal complaint against the Cult and others, I stated my personal opinion and personal belief as to the dangerous activities at the Cult's international base at Hemet, CA:

"Indeed, the Church of Scientology engages in brutal brainwashing in its three coercive re-indoctrination 'gulags' on American soil. These 'gulags' are located at Gilman Hot Springs and Happy Valley near Hemet, CA; Hollywood, CA; and, Clearwater, FL. The Gilman Hot Springs facility or 'base' is 'heavily armed and dangerous'. http://www.watchman.org/sci/scientologycamps.htm (Scientology's Concentration Camps) and http://www.innernet.net/joecisar/rpf1000.htm (Brainwashing In Scientology's Rehabilitation Project Force [RPF]) and http://www.lermanet.com/cos/andre.html andhttp://www.freezone.org/gilman_hot_springs.htm and http://www.exposingscientology.cjb.net/ (Reposted Classics #16, Declaration of Andre Tabayoyon)."

http://www.lermanet.com/reference/GrahamBerry/criminalcomplaint.htm (page 105)

5. I arrived at Ida's at 1:35 pm. Soon after that time, Ida began receiving reports from neighbors in the retirement community that a white SUV-type vehicle was parked as though it had Ida's house and guest arrivals/departures under surveillance. In the past, the Cult had hired private investigators and used its own employees to do this. A large thirty-foot plus long recreational vehicle with sophisticated listening equipment had once been parked nearby. Two years previously, a Cult employee then believed to be Frank Petty had also been parked outside a neighbor's house at night. When asked by the elderly neighbour what he was doing there he claimed to be an FBI agent.

6. When Ida (who lives alone) and I departed to go to a copy store, she discovered that her security lock had had a piece of metal jammed into it so as to render it inoperable. Subsequently, there were further telephone reports from neighbours of a white SUV(s) patrolling and parking nearby. When I retired to bed at 9 pm, a further telephone report was received that there were now two white SUVs with their drivers sitting in them parked nearby on the street and apparently keeping Ida's house under surveillance.

7. The next morning, at approximately 9:30 am (October 18, 2002), the neighborly phone calls reported that two white SUV s were again cruising the area. One of the SUVs, the one with a brown stripe around the lower body panels was the same as one of the ones from the previous evening. Several times I looked out window and saw a white SUV going slowly past on what is a very quiet retirement community street. At approximately 2:10 pm, I happened to be on the street, outside Ida Camburn's home, preparing to depart for my return drive home to Los Angeles. A white SUV with a brown stripe around the lower body panels slowly cruised around the corner, turned and went in the other direction when the driver saw us standing on the curb. I waved to the driver to let him know that I was aware of his presence and obvious harassment.

8. At approximately 2:15 pm I departed for Los Angeles. I retraced the same route from Vista Grande to Elk to Stetson to State Street and into Highway 79. As I approached the base, I decided to stop and photograph the earthworks I had observed the previous day. I parked within sight of the new reputedly armored building and a few feet away from what appeared to be workers' vehicles. I was on the side of Highway 79 and behind a small red car. As I walked past I noticed a woman in the driver's seat. She had dark hair. Her general appearance suggested to me that she might be Latina. As I walked past, she made a call on her cell phone.

9. I then walked about 100 yards down the mountainside of Highway 79 and took several photos of the big new Cult building as I did so. When I passed the transformer room of the huge new building I took another photo. I then crossed to the opposite side of Highway 79 to a point on the public side of the highway just before one reaches the new barracks or "berthing" being slowly built for the Cult's staff. At all times, I was on the public roadway. I saw no other people except for hired construction workers up the hill and around the Cult's new building that are undergoing final construction. My intention was to proceed little farther, take a few more photographs and then to return to my car and drive onto Los Angeles.

10. All of a sudden I was forced to jump to one side. A white pickup truck had appeared from nowhere and nearly ran me down. Although it was not long lived this action terrified me. This had happened once before on L. Ron Hubbard Way in Los Angeles when I was all alone carrying a picket sign protesting the Cult's human and civil rights abuses. On that occasion, there were three attempts to run me over, after which the little red car had driven into the large Church of Scientology parking lot at Sunset and L. Ron Hubbard Way.

11. A uniformed man jumped out of the white pick up truck and approached me. He yelled that I was violating "the injunction." I said, "What injunction?" He said, "The injunction against you [me]." I said, "There is no injunction against me." He said, "There is. Here it is. It is on Elliot Abelson's letterhead." I said that I had never received it. With that he started reading from a piece of paper while I took another photograph, maybe two. He was reading words to the effect that Keith Henson and his "agents" and all persons acting in concert with him were enjoined from being within 500 yards of "the Base." I am familiar with the Henson civil and criminal cases in Hemet, California and it is my personal opinion, in the exercise of my freedom of speech rights, and upon the evidence and facts known to me, that the criminal and civil judgments against Keith Henson were obtained by Cult related crime, unethical conduct by lawyers and prosecutors, prosecutorial corruption, judicial corruption and/or judicial intimidation and/or judicial incompetence, perjury, abuses of process and frauds upon the court (s) and prosecutorial agencies. I had not been given an opportunity to be heard upon the injunction being read to me, I thought it subject to both federal and state court collateral challenge and to be constitutionally defective, because of its vague and imprecise language and scope, and its chilling impact upon otherwise proper constitutional rights. I also believe it, and the interference with my activity, to be a furtherance of the Cult's RICO activity that that has been conducted since at least November 1993. Further information regarding this RICO activity can be located and read as follows:

http://www.google.com/ [click on Groups then type in graham berry and select Search by date] and at

http://www.lermanet.com/reference/GrahamBerry/criminalcomplaint.htm http://www.lermanet.com/reference/GrahamBerry/lettertoAndrewCard.htm http://www.lermanet.com/reference/GrahamBerry/senatejudiciary.doc

12. I noticed that the man intimidating me wore a uniform that had a nametag on it. I took a notepad from my pocket and began noting the details. He then tore his nametag off his chest pocket to try and prevent my reading his name. I said, "You are reading me an injunction, but trying to prevent me from knowing who gave me notice of its contents?" He scowled at me. However, I had the information; "SECURITY FORCES PO2, Danny Dunagan I/C." I then told Scientology Security Chief Dunagan that Elliot Abelson would be hearing from me about this violation of my civil rights.

13. Next, I turned on my heels and proceeded to walk back towards my car, along the public portion of Highway 79 on the golf course side of the Highway. My photographs will establish approximately where I was at all times. As I walked away, the Cult's Security Forces Officer was shouting into his walkie-talkie: "Call the Sheriff, he's not co-operating!" I said that that was not so. He said, "Don't commit any acts of violence on church members." I laughed and said that I never had. He said, "Who's going to believe you. You're just a suspended lawyer." I made no response and continued to walk back to my vehicle. On the way back to my vehicle I took at least two more photographs. I crossed over to the other side of Highway 79. As I walked past the little red car parked in front of mine the young lady was slumping in her seat, cell phone in her hand, the window open. I observed a baby lying on the rear seat. I said nothing to her and made no gestures.

14. I immediately got into my vehicle and made a safe U turn and proceeded back to the Ramona Expressway and left Hemet by that route. After hearing Security In Charge Duggan I had concluded that I was unable to continue along Highway 79 and past the Base because of the terms of the injunction, as driving on public Highway 79, I would have been within 500 yards of the Base as I drove past it. As I drove south down Ramona Expressway and towards the hill beyond Gilman Hot Springs Road, I noticed a Sheriff's car, which appeared to be heading towards the Base.

15. I have not been Keith Henson's attorney or "agent" for nearly two years. I did not discuss my intention to photograph several Cult-owned buildings with him before I did so. Materials describing the Cult's campaign against Keith Henson can be found, among other places, at: http://freehenson.da.ru and www.operatingthetan.com.

16. At 1:30 pm on October 19, 2002, Ida Camburn informed me that the same or a similar white SUV(s) had made several more "passes" around her home that morning.

I declare under penalty of perjury, under the laws of the United States of America and the State of California, that the foregoing is true and correct.

Executed on this 20 th day of October 2002 at Los Angeles, California.

/s/ _________________________ Graham E. Berry