H. Keith Henson P.O. Box 60012 Palo Alto, CA 94306 (650) 325-7533
SUPERIOR COURT OF CALIFORNIA COUNTY OF LOS ANGELES MICHAEL HURTADO ) Case No. BC208227 ) Plaintiff, ) EX PARTE ) MOTION FOR LIMITED v. ) PROTECTIVE ORDER ) GRAHAM E. BERRY ) Defendant. ) ____________________________________ DATE: N/A DEPT: 10
Witness H. Keith Henson applies to this court for a limited protective order regarding a video tape deposition now set for Sept. 15, 2000 in Los Angeles in the above case. Witness requests that the deposition question be limited to his first hand knowledge of events involving Hurtado, and that wide ranging questions outside of this area not be permitted. Also that any material in this deposition not be permitted to be used in other Scientology cases against me. Witness and witness's wife have been abusively deposed a number of times by the law firm of Moxon and Kobrin, within the past two months in a bankruptcy action for several hours (about 500 pages of deposition). This is in keeping with a Scientology policy to use the law as a weapon against critics. I have recently been protesting Scientology policies or practices which resulted in the deaths of two young women at their desert compound near Hemet, California, (www.parishioner.org/osah for one) and to punish me for this political protest, they are using the excuse that I know something in this case against my lawyer, Graham Berry to get yet another deposition on top of the 40 hours or more I have already have subjected to. A brief look at the documents to be produced confirms this. They are asking for communications between me and my lawyer Mr. Berry, Mr. Cipriano, a person who I have met only once, but who was used by Scientology to attack Mr. Berry, Jane Scott and Scott Meyer who worked for Graham as paralegals, and Edith Mattthai, Mr. Berry's lawyer in this case. Note that there is *no* request for communications with Mr. Hurtado. While I have not finished an exhaustive search for communications which are requested, the attached are typical, and involve public matters or legal filings in this or other related cases. There is one class of communications which I will not divulge under attorney/client or law enforcement exceptions unless ordered to do so by this court. (I will provide this material for in camera examination if requested.) These are substantive matters having to do with law enforcement agencies and their activities. The Federal bankruptcy court has exempted me from answering questions of this nature. The court may obtain a fax of this ruling from my bankruptcy attorney Stan Zlottoff, 408-287-1313. Where there are statements of fact in this motion, they are submitted under penalty of perjury.
Respectfully submitted, H. Keith Henson Sept. 26, 2000