Ava M. Paquette, SBN 165375
Helena K. Kobrin, SBN 152546
MOXON & KOBRIN
3055 Wilshire Blvd., Ste. 900
Los Angeles, CA 90010
Telephone: (213) 4874468
Attorneys for Plaintiff
MICHAEL HURTADO
                        SUPERIOR COURT OF THE STATE OF CALIFORNIA
                                FOR THE COUNTY OF LOS ANGELES
MICHAEL HURTADO,


                         Plaintiff,
         vs.


GRAHAM E. BERRY,


                         Defendant.
Case No.  BC 208227
Honorable Ray L. Hart
SUPPLEMENTAL DECLARATION OF AVA M. PAQUETTE REGARDING DEPOSITION OF KEITH 
HENSON




Date:   September 14, 2000

Time:  9:00 a.m.
Dept:   10      I, Ava Paquette, declare:
         1.      I am an attorney at law duly licensed to practice law 
before all of the
courts of the State of California.  The facts contained herein are true of 
my own personal knowledge and if called upon to testify, I could and would 
competently testify thereto.
         2.      During the last couple of weeks I was visiting my mother 
who has been very ill.  During that time period, I received an email from a 
Frederic Rice, which I inadvertently overlooked when checking my email 
which is attached hereto as Exhibit A.
         3.      Upon investigation and reviewing Mr. Rice’s Internet web 
site called "skeptictank.org", I found out that Frederic Rice is a hater of 
religions.  On his Internet web site he espouses views that are 
emphatically against all religion.  For example, he states that there are 
almost no distinctions between Nazism and Christianity.  He has advocated 
violence against parishioners of the Scientology religion and has posted 
global positioning coordinates for various Scientology churches on the 
Internet in the context of bombing them.  Mr. Henson has participated in 
these activities with Mr. Rice and has a background in bomb making.
         4.      As reflected in the attached email, Mr. Rice refers to 
himself as "Reverend" and claims that he will be representing Mr. Henson’s 
"spiritual interests" by videotaping and audiotaping Mr. Henson’s 
deposition on September 15, 2000 in the Moxon & Kobrin offices.
         5.      Mr. Henson’s deposition will not be videotaped by my 
office.  I view this as just another harassment ploy by the defendant for 
the purpose of creating obstruction, harassment and annoyance at the 
deposition so he can disseminate it on the Internet.
         6.      I also believe that it is highly probable that Mr. Henson, 
along with defendant Graham Berry, intends to make speeches at the 
deposition so that Mr. Rice can videotape and post them for his Internet 
cronies.  I say this based upon conversations I have had with Mr. Berry in 
the past, where he inevitably threatens me with lawsuits, arrest and the 
media.  I am counsel of record in the bankruptcy adversary matter entitled 
Moxon v. Berry, Case No. ADV 9902615ER and am thoroughly familiar with the 
facts in that case.  One of the grounds that Judge Snyder gave for imposing 
a $28,000 F.R.Civ.P. Rule 11 and 28 U.S.C. §1927 sanction upon Mr. Berry 
arose out of his actions in filing frivolous pleadings in court for the 
purpose of disseminating them to the media and on the Internet.
         7.      For these reasons and for good cause shown, I request that 
the Court issue an order to permit only the deponent, Mr. Henson, his 
attorney, if he has one (and he has indicated that Mr. Berry may appear as 
his attorney), the court reporter and plaintiff’s and defendant’s attorneys 
to attend Mr. Henson’s deposition.
         I declare under penalty of perjury for the foregoing is true and 
correct.  Executed this 11th day of September, 2000 at Los Angeles, California.


                                                 ______________________________
                                                 Ava M. Paquette
PROOF OF SERVICE
             I am employed in the City and County of Los Angeles, State of 
California. I am over the
age of 18 and not a party to the within action.  My business address is 
3055 Wilshire Blvd., Suite 900, Los Angeles, California 90010.
         On September 11, 2000, I served the foregoing document described as
SUPPLEMENTAL DECLARATION OF AVA M. PAQUETTE REGARDING DEPOSITION OF KEITH 
HENSON
[x]     VIA FACSIMILE
on the interested parties to the below as follows:
Edith Matthai, Esq.
fax number: (213) 6242563


Keith Henson
fax number: (650) 3255246


               I declare under penalty of perjury under the laws of the 
State of California that the
above is true and correct and was executed on September 11, 2000, at Los 
Angeles, California.