3384 McLaughlin Avenue
Los Angeles, CA 90066
Phone: (310) 745-3771
Fax: (310) 745-3772

January 21, 2002

By Fax and Federal Express.
Hon. John Ashcroft
U.S. Attorney General
U.S. Department of Justice
950 Pennsylvania Avenue, NW
Washington, DC 20530-0001

Honorable Attorney General:

I respectfully submit the following information to your office for immediate action:

(1) Criminal Complaint;

(2) Civil Rights Complaint;

(3) Hate Crimes Complaint;

(4) Fraud Complaint;

(5) Request For Investigation;

(6) Request For Grand Jury Proceedings and Criminal Prosecution;

(7) against, inter alia, Church of Scientology International, David Miscavige, Mark "Marty" Rathbun, Michael Rinder, Lyn Farny, Eugene M. Ingram, Kendrick L. Moxon, Elliot Abelson, Donald R. Wager, Ava Paquette, Michael Hurtado and Miguel Hurtado; and


(9) Request for investigation of apparent public corruption:

(10) involving, inter alia, certain employees of the Los Angeles and Riverside District Attorney’s offices, the Los Angeles City Attorney’s Office and the State Bar in California including but not limited to Gerald Chaleff, Esq., of Los Angeles, CA; Robert Schwartz, Esq., of Riverside County, California; Elliot J. Abelson, Esq., of Los Angeles, California; Samuel D. Rosen, Esq., of New York and New Jersey; Gerald Feffer, Esq., of Washington, DC; Kendrick L. Moxon, Esq., of Los Angeles, California and Clearwater, Florida; Eugene Ingram of Los Angeles, California; Fred T. Goldberg, Esq., of Washington, DC., Margaret Milner Richardson, Esq., of Washington, DC; David Miscavige of Hemet and Los Angeles, California; Mark ("Marty") Rathbun of Los Angeles and Hemet, California and Clearwater, Florida; Michael Rinder of Los Angeles and Hemet, California and Clearwater, Florida; Donald R. Wager, Esq., of Los Angeles, California and Hon. Alexander Williams, III of Los Angeles, California.



EXECUTIVE SUMMARY……………………………………………………………………..…..9

PART ONE……………………………………………………………………………………...….15


I. INTRODUCTION……………………………………………………………………………….15

1. Scientology’s own scriptures condone serious crime………………………………..……..15

2. Scientology has hijacked a religion and created an instrument of war…………………….16

3. Scientology’s intelligence operations rival the FBI’s……………………………….….….17

4. Scientology is terrorizing the lives of countless citizens…………………………………..18


1. Scientology’s lead lawyer-unindicted co-conspirator in largest burglary of US Govt…....20

2. Huge FBI raids exposed Scientology’s criminal frame-up of author Paulette Cooper.

Scientology frames others too……………………………………………………………..20

3. Scientology’s "Operation Snow White" still exists…………………………………....….20

4. In 1991, I was retained to /successfully defended a former Scientology lawyer …………21

5. In 1993, I led the successful Scientology v. Fishman-Geertz defense ……………….…...22

6. The related Scientology v. Time Magazine case was also successfully defended………...23

7. Scientology has limitless tax-exempt litigation terrorism budgets…………………….….23

8. Scientology "sacred" scripture mandates concentration or "quarantine"camps……….….23


1. Scientology’s religious "trade secrets" were published during Fishman-Geertz………....24

2. Scientology v. The Net was copyright and litigation terrorism……………………….…...24

3. Scientology blamed me for the publication of its religious "trade secrets"……………....24

4. Scientology committed fraud in its 1993 IRS Form 1023 applications…………………...25

5. In 1993, Scientology hired lawyers etc., to "investigate" me-it continues………..………25

6. Scientology’s investigation of me is part of its "Fair Game" Policies and Practices…..…25

7. Scientology and its lawyers have admitted the continuing "haunting" "investigation".…26

8. Scientology used blackmail and extortion to suborn perjury that destroyed my career……………………………………………………………………………………...26

9. Scientology’s "Targets-Defense" includes global government takeover……………..….27

10. Scientology’s lawsuits are intended to "harass" and terrorize…….……………………...27

11. Scientology used its suborned perjury to "utterly destroy" me…………………………..27

12. Extensive Scientology correspondence and testimony confirms the "investigation" of me……………………………………………………………………………………….….29

13. Scientology’s "psycho-terrorism" is part of "Fair Game"…………………………….29, 30

14. Scientology’s "psycho-terrorism" destroyed my employment, career and relationships………………………………………………………………………………..29

15. Scientology "investigated" and blackmailed my senior law partner……….……………...33

16. A secret Scientology settlement agreement included stealing client files…………………33

17. The secret settlement agreement also obstructed justice………………………….……….34

18. Several prominent lawyers were involved in those criminal activities…………….………34

19. Trial Judge Williams was later shown to be corrupted by Scientology…………………....35


1. Scientology’s "Fair Gaming" of me materially breaches the 1993 IRS secret


2. Offering massive bribes, Scientology attempted to suborn perjury from three others…….36

3. Scientology lawyer, Abelson, engaged in demonstrable subornation of perjury………….36

4. Scientology and armed US Marshals raided homes, seized computers, confiscated


5. Scientology’s secret Lewis, D’Amato/AIG agreement - used to obstruct justice…….…...36

6. I refused to be criminally and unethically restrained-changed law firms………………....37


1. "Bowles & Moxon Plan 100"; Scientology files 30 frivolous lawsuits to destroy


2. Bowles & Moxon solicit Jason Scott’s legal representation as part of conspiracy...……..37

3. Scientology’s Bowles & Moxon had numerous conflicts of interest-breach duties

to Scott……………………………………………………………………………………..38

4. Scott fired Bowles & Moxon and retained me…………………………………………….38

5. Scientology’s "Fair Gaming" of me, my new law firm and its clients escalated……………………………………………………………………………………38


1. I refused to be intimidated-only a few lawyers willing to oppose Scientology……………39

2. I file my own litigation against Scientology-I represent Keith Henson in

Internet case………………………………………………………………………………..39

3. Scientology "needed" 28 lawyers against Henson and me - cost them over $2M………..40

4. Scientology abuses bankruptcy process in the Henson bankruptcy………………………..40

5. Henson flees the U.S. and Canada grants Henson "refugee"status………………….…….40


1. I filed the Berry cases in connection with Scientology’s published perjuries re me……….41

2. Moxon and Ingram to be defendants-they solicit and bribe representation of Cipriano.…..41

3. Moxon promised Cipriano up to $750,000 to co-operate in the RICO conspiracy…….…..41

4. Scientology counsel had non-waivable conflicts of interest………………………………..41

5. Scientology "re-located" Cipriano as part of the conspiracy to obstruct justice…………...41

6. Scientology assembled a massive national legal team to further the RICO conspiracy..41, 42

7. Scientology "judge shopped" the case to their "friend" Judge Williams…………………..42

8. Judge Williams permitted massive abuse of process - ignored evidence of

crime-fraud……………………………………………………………………………..42, 43

9. Scientology intimidated-subverted my two law partners………………………………….43

10. Scientology then over-whelmed me with its litigation juggernaut………………………...44

11. Concurrently, Scientology solicited my client Hurtado, suborned perjury, etc…………...44

12. Non-Scientology defendants settled in the Berry cases………………………………..43, 45

13. Scientology’s lawyers engaged in fraud - obtained costs and sanctions orders……………44

14. Scientology also obstructed justice and engaged in fraud in the Pattinson cases………….46

15. All of this criminal conduct further breached the 1993 IRS-Scientology settlement……...47

16. Scientology may be owned by four individuals - three non-Scientologist lawyers………..48


1. Judge Williams deprived me of due process and civil rights in Berry v. Cipriano, etc…..50

2. Scientology lawyers, etc., solicited my client Hurtado, suborned perjury, etc…………....50

3. Scientology’s lawyers stated they had "been after" me for a very long time……………..50

4. Scientology engaged in illegal wire tapping of me………………………………………..51

5. A LA County Bar leader committed fraud upon Judge Haber’s court……………………52

6. Scientology lawyers submitted fraudulent insurance demands to my carrier……………..53

7. Scientology lawyers used their own suborned perjury for a false criminal complaint……53

8. A LA County Bar leader solicited perjury from a stranger in the LA County jail………..53

9. The stranger testified to bribery and the subornation of perjury…………………………..54

10. Scientology lawyers use their own suborned perjury to pressure State Bar to disbar me…54

11. Scientology lawyers used their own suborned perjury in two fabricated Hurtado cases…54

12. Scientology retained the President of the LA Police Commission to use fraud

against me…………………………………………………………………………………56

13. Cipriano confessed to the perjury and obstruction of justice-50 corroborating documents…………………….……………………………………………………………. 56


1. Moxon and Paquette attempted to obstruct Cipriano’s deposition in Hurtado v. Berry…………………………………………………………………………………...……57

2. Moxon cross-examined his own former client in Hurtado v. Berry ………………………..57

3. Cipriano testified to numerous felonies involving Moxon and other lawyers………………57

4. Many documents and other evidence corroborate Cipriano’s testimony…………………57-61


1. Judge Williams ruled the Cipriano confession /exhibits irrelevant - held me vexatious……61

2. Judge Williams refused to disqualify himself-his fiancée worked for Scientology…….61, 62

3. Scientology’s former deputy leader has detailed Scientology’s "judge tampering"………...63

4. Scientology has a long history of corrupting American judges……………………………..63


1. The California Court of Appeal refused to consider Judge Williams conflicts of interest………………………………………………………………………………………63

2. Scientology filed Adversary Proceedings in Bankruptcy Court……………………………63

3. Scientology engaged in fraud upon the Bankruptcy Court…………………………………63

4. Scientology also abused process/committed fraud against me and upon other courts……..64

5. Co-operative opposing counsel now retained in huge Scientology-related "Ponzi" fraud………………………………………………………………………………………...65

6. I was diagnosed with severe depression and left active practice status………………….…66

7. Scientology further abused process, prevented my paying the IRS and other creditors……………………………………………………………………………………..66

8. Scientology’s County Bar leader continued to pressure the State Bar to disbar me………..66

9. The same lawyer testified that he had engaged in witness tampering in Hurtado………….67

10. Scientology’s lawyers continued to engage in fraudulent insurance demands……………..67

11. After their lawyer’s confession, Scientology dismissed the State Court Hurtado case….…68

12. In July 2000, the Bankruptcy Court ordered the Hurtado case dismissed there too………..68

13. The corroborated evidence against Scientology and its lawyers, etc., is extensive………...68

14. Scientology and its lawyers never had any non-perjured/suborned evidence against me.….69

15. Hurtado is now serving an unrelated five-year prison sentence…………………………….69

16. Scientology engaged in extortion during the Hurtado criminal prosecution…………….….70

17. Significant circumstantial evidence indicates corruption of Los Angeles law enforcement…………………………………………………………………………………….70

18. Scientology’s worldwide investigation of me continued despite the RICO evidence…………72

19. There are dozens of other victims of Scientology RICO conduct, frame-ups, terrorism………72


A. Scientology’s lawyers obstructed local law enforcement………………………………………75

B. Scientology has corrupted the Federal Government……………………………………………80

C. The Clinton Administrations Responses Were Outrageous………………………………….…83

D. The evidence is beyond a reasonable doubt…………………………………………………….84

PART TWO………………………………………………………………………………………….…86



Scientology and "psycho-terrorism"………………………………………………………….……..86

Scientology blackmailed the Clinton Administration-huge tax fraud…………………………….....88

The Clinton Administration actively promoted Scientology abroad………………………………..90

Scientology’s President was a fleeing fugitive……………………………………………………...91

Scientology’s sacred scriptures mandate criminal conduct……………………………………..…...91

Numerous experts have written on Scientology terrorism, crime and abuse……………..…………92

Scientology has been recently convicted in foreign countries……………………………..………..93

Scientology regularly defames, terrorizes and criminally frames people…………………………...93

Scientology’s founder was convicted of criminal fraud twice………………………………………95

Scientology is a "church" with a "body-count"………………………………………….…………..96

Scientology engages in terrorism as defined by Secretary of State Powell, etc……………….…….96


Scientology orders female staffers to have abortions……………………………………….….……97

Scientology engages in illegal child labor and other family abuses……………………..…..……....97

Scientology secret sacred scripture denies the existence of Christ………………………….……....98

Scientology intends the elimination of all religions…………………………………………………98

Scientology plans worldwide takeover and totalitarian rule…………………………………….…..99

Scientology engages in coercive mind control and brainwashing…………………………………..99

Scientology’s origins are in Satanism……………………………………………………...………..99

Scientology "sacred scriptures" teach lying and perjury………………………..………………91,100

Scientology operates taxpayer-subsidized concentration camps on U.S. soil……………….…….100

A multi-volume police report concludes Scientology is a R.I.C.O. enterprise…………………100,101


Scientology is America’s own "Taliban"…………………………………………………………102

Scientology resembles the Nazi and Communist operational structure…………………………..102

Scientologists are taught to tell the Goebels-like "big lie"……………………………….……….102

The U.S. erroneously tolerates Scientology crime and terror under the 1st Amendment…………102

U.S. European allies do not grant religious exemption to Scientology crime and terror…………102

The Scientology-Clinton Admin. initiated annual State Dept. Religious Freedom


Germany considers Scientology a criminal, psycho-terror and commercial crime sect…………..103

The Clinton and Bush Administration are ignoring the biggest Ponzi scheme in history………...103

Scientology committed the largest ever criminal infiltration of the U.S. government……………103

Scientology’s Hemet "base" is "heavily armed and dangerous"………………………………….105

Scientology is intent upon taking over the U.S. Government………………………………..…...105

Scientology has infiltrated the Russian nuclear industry…………………………………….…105,106

Scientology is involved in foreign weapons plants……………………………………………….106

Scientology has access to chemical and biological weapons………………………………….….106

Scientology’s contrived religiosity is a facade……………………………………………………106

Scientology is infiltrating American and foreign businesses……………………………………..106

Scientology intersects with global terrorism………………………………………………………107

Scientology is monitoring electronic and Internet communications…………………….……..…108

Germany deems Scientology a threat to national security and democracy……………………….108

Scientology is engaged in 9-11 WTC fraud and deception…………………………………….…109

Scientology tax-exempt income targets the destruction of the mental health profession………...110

OMB Director Mitch Daniels was sued and harassed by Scientology. He spoke out………….110

Scientology is terrorizing old ladies and military veterans in Hemet, California…………………111

Scientology preaches blackmail, the use of assassins and police bribery…………………………111


Pre-Clinton Administrations steadfastly resisted the Scientology litigation juggernaut………….112

The pre-Clinton IRS successfully defended denials of Scientology tax-exempt applications……112

Scientology blackmailed the IRS Commissioner to obtain a reversal of a 20-year IRS


The "new" Scientology form 1023 application is full of fraud and misrepresentation…………...113

The Clinton Administration gave Scientology a one billion-dollar tax relief package…………...113

The Clinton IRS even gave Scientology’s tax lobbying front group full tax-exempt status……...113

Scientology blackmailed a Federal Senator-obstruct a Senate investigation into the tax issue……113

Payments for Scientology "processing", often costing over $1M, is now fully tax-exempt………114

Scientology hid twelve sea containers of documents from IRS inspection………………………..114

Scientology uses tax-exemptions in its marketing materials……………………………………....115

Scientology feared my legal defense of the Fishman-Geertz case threatened its tax status…….…116

Scientology stores evidence of its criminal activities in "Red Data Boxes"………………………117

Scientology has judicially recognized "Fair Game" Policies/Practices to terrorize its "enemies"…………………………………………………………………………………………..117

Scientology used dishonest lawyers and "Fair Game" to destroy my career, home and future…...117

XVII. RECENT DEVELOPMENTS………………………………………………………………..117

1. Lopez v. Church of Scientology settles. Financial fraud/abuse involving ostrich egg investments...117

2. Scientology moves to dismiss Barton v. Berry. Third consecutive voluntary dismissal……………119

3. Slatkin fraud may extend to financing Berry v. Barton. Possible ENRON and WISE connection…120

4. Scientology claims not to be a church in Belgium………………………………..…………………120

5. German courts uphold state electronic surveillance of Scientology - threat to democratic state……121

6. Scientologists are supporting treason, sedition and genocide……………………………………….126

7. Police opine, "It will take a federal effort with lots of money and manpower"…………………….127


1. The Administration has a public duty to investigate the $1B Scientology-IRS secret deal………....128

2. Courts have rejected Scientology claims that its conduct can be justified as self-defense………….128


1.This is a multi-pronged complaint and request………………………………………..…………….130

2.A related petition has gathered nearly 1,000 signatures……………………………………………..130

XX. CONCLUSION…………………………………………………………………...…….131

1. The evidence satisfies all applicable standards of proof……………….…..……...………131

2. Countless citizens look to the Attorney General to do the right thing here……………..………....132









Ø The Los Angeles District Attorney’s Office has recommended that the FBI investigate these matters, Infra, page 79.

Ø The current Director of the Office of Management and Budget, Mitch Daniels, has had painful personal experience with Church of Scientology, which he claims is "driven by crass financial motives." Infra, page 110.

Ø The Church of Scientology is America’s own "Taliban" using tax-exempt funds in its express totalitarian goals of "taking over the control or allegiance of the heads or the proprietors of all news media…key political figures…those who monitor international finance." Targets Defense, L. Ron Hubbard. Infra, page 27.

Ø America’s allies classify the Church of Scientology as a "psycho-terror" criminal cult engaged in financial crime and money laundering. Infra, pages 69, 86-97, 110-111, 117. For example, the Church of Scientology is currently implicated in the largest ever-financial "ponzi" scheme in American history. It involves over $500 million dollars and over 850 investors. Infra, pages 65, 103.

Ø Using tax-exempt moneys, the Church of Scientology orders its female para-military Sea Organization staffers to have abortions. Infra, page 97. The Church of Scientology also engages in child abuse and violations of the child labor laws. It has engaged in these as well as other terrifying acts causing permanent damage to entire families. The Church is intent upon the denial and destruction of Christianity and all other religions. Scientology maintains at least three concentration camp type facilities upon American soil and it calls for the extermination of billions of people. Infra, pages 23, 27, 30, 38, 97-102. It has its origins in Satanism and black magic. Infra, pages 98-100. Lying to protect and expand Scientology is considered a holy sacrament. Infra, pages 17, 18, 25, 26, 89, 93, 100.

Ø In 1977, the U. S. Department of Justice, through the F.B.I., conducted three massive, simultaneous raids against the Church of Scientology. The FBI seized thousands of documents linking the Church of Scientology to organized crime and the use of the U.S. legal system to harass, frame and destroy those it perceived as "enemies" of Scientology. Infra, pages 20, 21, 47, 48, 118. This complaint also involves Scientology lawyer Kendrick L. Moxon ("Moxon") who was named as an "unindicted co-conspirator" in the resulting criminal proceedings and convictions. Infra, page 24. This was the largest ever known criminal infiltration of the United States Government. Infra, pages 17, 48.

Ø Between 1991 and 1993, Moxon was engaged in what appears to be the largest ever-criminal tax fraud perpetrated against the United States government. Infra, pages 35, 47, 88-90, 112-117. In October 1993, Scientology’s para-military "ecclesiastical" leader claimed that the I.R.S. reversal and granting of 501(c)(3) tax-exempt status saved the Church of Scientology over one billion dollars in past due taxes, penalties and interest. Infra, page 113. Concurrently, Moxon was engaged in unsuccessful litigation against Joseph Yanny and Uwe Geertz in which I was one of the defense counsel in the Church of Scientology cases against former church attorney Joseph A. Yanny. I was lead defense counsel for psychologist Uwe Geertz in Church of Scientology v. Fishman & Geertz. Infra, pages 21-24, 34.

Ø In Fishman - Geertz, we filed substantial evidence of the Church of Scientology’s involvement in financial frauds, instructions to commit murder and instructions to commit suicide. Infra, pages 22-24, 34. It is now believed that Moxon, Williams & Connolly lawyer Gerald Feffer, Scientology leaders David Miscavige and Marty Rathbun, and certain private investigators, were involved in he blackmail of the then Commissioner of the I.R.S. and of the Chairman of the Senate Finance Committee. Infra, pages 112-118. As a result of the successful defense of the Fishman-Geertz case, the Church of Scientology feared exposure of their billion-dollar continuing tax fraud upon the United States government. Scientology, Moxon and private investigator Eugene Ingram have all testified to launching a ["haunting"] "investigation" of me in 1993. Infra, page 26. In 2000, Scientology attorney Elliot J. Abelson ("Abelson") was continuing with the worldwide ""investigation of me. Infra, page 72.

Ø The Church of Scientology, Moxon, Abelson and Ingram pretextual "investigation" of me included the blackmail and bribery of a Robert Cipriano. Cipriano signed a perjured and highly defamatory declaration that I was a child molester. Scientology and its shills disseminated the highly damaging declaration

world wide as part of its "Fair Game" Policies and Practices. Infra, pages 26- 33.

Ø Despite Church denials, Scientology’s "Fair Game" Policy has been repeatedly and recently recognized in the courts. Infra, page 25. Continuing to this day, the church and its lawyers have used its "Fair Game" practices against me to, in the words of one of the Church’s documents, "ruin [me] utterly." Infra, page 25. As you have read, the Church of Scientology, its lawyers and private investigators have engaged in numerous felonies, which, as was intended, have dramatically changed my life for the worse. Infra, pages 18, 19.

Ø The evidence of serious felonies committed by the Church of Scientology, certain of its lawyers and certain of its investigators, is overwhelming. There are over ten witnesses and over sixty corroborating and damning documents, many with Moxon’s own signature. One of Scientology’s other lawyers testified to client/witness solicitation and witness tampering. Infra, page 67.

Ø The evidence involves a major R.I.C.O. enterprise that includes, at the least, the Church of Scientology and certain of its outside lawyers and investigators. Infra, pages 17, 21, 25, 36, 56, 63, 84, 93. In addition, it also appears that a number of federal and state officials and employees, federal and state judges, law enforcement officers are also involved. Infra, pages 35-36,44,48,50,54,61-63,66-68,70-72,75-85,93. It is believed that the participation of many of this second group of people has been procured by extortion and other foul behavior that is mandated by the Church of Scientology’s "Fair Game" Policies and Practices. Infra, pages 25-32,45,64,66,116. The known criminal conduct crosses state and national borders, uses the interstate mails and modes of commerce, and violates numerous federal criminal and other laws. Obstruction of justice, witness tampering, perjury and frauds upon numerous courts are the common threads throughout the seven-year history of the Scientology enterprises despicable scheme. Infra, pages 57-61, 69,81,84,90.

Ø This obstruction of justice also involves the corruption of justice in different cities, counties, states and nations. Infra, pages 72-74,81, 85 93-95.

Ø Numerous victims and others have unsuccessfully requested investigation and other action by authorities, which include the I. R.S. Infra, pages 80-84. I unsuccessfully requested action from former Attorney-General Reno. She did not know what I wanted done with the evidence! Infra, page 83.

Ø Under Church of Scientology influence and pressure, the Clinton Administration ignored other evidence and media demands for investigation and prosecution of the Church of Scientology. The Clinton Administration even ignored repeated Wall Street Journal, New York Times and Washington Post editorials calling for an investigation into the fraudulently obtained granting of tax-exempt status (and a one billion dollar "tax relief" package) to the Church of Scientology in 1993. Infra, pages 89, 90.

Ø I have repeatedly attempted to have federal and state law enforcement investigate and prosecute the matters complained of in Part One of this letter, so have others. However, at every juncture, Church of Scientology retained lawyers have interfered with and obstructed our efforts. Infra, pages 75-80. The U.S. Department of Justice, during the Clinton Administration, was unable and unwilling to deal with the evidence. Infra, pages 80-84. Both the Los Angeles Police Department and the Los Angeles Sheriff's Department have recommended that criminal proceedings be filed. Infra, pages 77-79. Repeatedly, the Los Angeles District Attorney's Office and the Los Angeles City Attorney's office have refused to prosecute for "political reasons" and because of "political influence." Infra, pages 76, 79. In addition, those local prosecutors have allowed the proposed targets of such prosecutions to participate in the decision making process that most recently concluded that these matters (extortion, perjury, obstruction of justice, etc.) were not serious enough for prosecution. Infra, pages 78-79.

Ø This is a classic case of public corruption and obstruction of justice at the local level and it involves my constitutional due process and other civil rights guaranteed by both the U. S. and State of California constitutions. Such matters are properly within the jurisdiction of the U.S. Department of Justice. Of course, the U.S. Department of Justice also has jurisdiction because of the nature of the inter-state and international criminal and corrupt conduct involved and described in Part Two of this letter. Moreover, the apparent corruption of certain aspects of local Los Angeles law enforcement has already been recognized by the fact of continuing U. S. Department of Justice court ordered supervision of justice, law and order in Los Angeles, following the recent Rampart scandals.

Ø The constitutional due process and other procedural violations of my civil and human rights include the blatant and brazen corruption and conflicts of interest summarized below. Infra, pages 77-80. Of course, there is also the staggering and stunning corruption of the United States government, by the Church of Scientology. Infra, pages 35, 47, 88-90, 103-110, 112-117. This cannot and must not be ignored. "That men do not learn very much from the lessons of history is the most important of all the lessons that history has to teach." Aldous Huxley, Collected Essays (1959). See generally, U.S. v. Hubbard, 474 F. Supp. 64 (1979). Infra, 21, 103.

Ø By way of contrast, Scientology attorneys Abelson, Gerald Feffer (Williams & Connolly) and Samuel D. Rosen (Paul, Hastings, Janofsky & Walker) have also been engaged in corruption with the Riverside County, CA District Attorney’s office. The Riverside Sheriffs Department investigated and recommended against prosecution of Keith Henson for picketing one of the Scientology desert "gulags." Abelson, Feffer and Rosen pressured the District Attorney to ignore the Sheriff's recommendations and to prosecute Henson. The Church of Scientology provided Rosen, Abelson and Feffer as resources for the Riverside District Attorney's Office prosecution of Henson. Infra, page 73. The Church of Scientology and

its attorneys have also recently engaged in other demonstrable public corruption and obstruction of justice that includes the Caberta, Cult Awareness Network Bunker, Prince, McPherson, Minton and Ward cases (and the States of Illinois, Florida, Massachusetts and California). Infra, pages 73-75.

Ø This is not isolated conduct by the Church of Scientology. There are numerous recent criminal convictions, civil judgments and public settlements that tend to corroborate the evidence of the matters outlined herein. Infra, pages 86 - 88.

Ø There is widespread public perception, around the world, that the U.S. government has, in essence, been totally and irreversibly corrupted by the Church of Scientology, its lawyers, lobbyists, public relations and private investigators. Infra, page75. As you read above and below, my own experience at seeking equal justice under law has also been consistently obstructed, corrupted and

ignored. Infra, pages 73, 75 -77. Infra, page 74.

Ø In addition, Scientology, Abelson, Moxon, Kobrin, Paquette continue to abuse process with an Adversary complaint in United States Bankruptcy Court in Los Angeles. This case will be tried on January 28, 2002, and requests non-dischargeability of Judge William’s order that I pay Barton’s costs in defending the defamation suit I filed (and was forced to dismiss) against Cipriano, Barton, Scientology, Miscavige, Ingram (Abelson and Moxon). Infra, pages 40-44,63,66.

Consequently, I am immediately making this complaint and request letter public, and providing copies of this letter (and many of the enclosures) to other members of the current Administration, certain executive branch officials, members of the Senate and House, the media, certain foreign governments, certain international organizations and certain non-governmental organizations.















This matter involves domestic terrorism and the Church of Scientology which, in a long pattern of criminal behavior escalating over the years, has effectively "hi-jacked the legal system and crashed it through the Constitution." In so doing, the Scientology enterprise has used powerful, greedy and amoral lawyers, sleazy private investigators, Racketeer Influenced and Corrupt Organization Act ("RICO") predicate acts (18 U.S.C. sec.1961 et seq.) and fraud to further its "psycho-terrorism" and intimidation of those who would impede its terrible totalitarian subversive agenda.

Indeed, CNN Cross Fire Co-Host Bill Press has said that the Church of Scientology is, "Very clever, very skilled at media harassment. I was not prepared for that kind of harassment. I never ever received anything like that before from any other source. They’re an untold story. They’ve scared a lot of news off. They’re getting away with murder. I say put on your asbestos suit and charge." emphasis added

Commentator Bill Press’s words were closer to the truth than he may have realized. In writing on Church of Scientology "ethics," Scientology’s "spiritual" founder L. Ron Hubbard stated:

"…in any command of mine, you can wear horns and grow a tail if you do your job. If you don’t do your job, you can’t even think sideways without getting disciplined, transferred or demoted."

Flag Order 4, 13 August 1967, by L.Ron Hubbard.

Similarly, L.Ron Hubbard wrote:

"In short, a staff member can get away with murder so long as his statistic is up and can’t sneeze without a chop if it’s down. To do otherwise is to permit some suppressive person to simply Ethics chit every producer in the org out of existence." emphasis added

HCOPL, 1 September 1965, Ethics Protection.

On December 2, 2001, you informed the nation of a long-overdue reform of FBI and Justice Department policy. According to the Associated Press, you stated that, "People who hijack a religion and make out of it an implement of war will not be free from our interest." Quite properly, President Bush's Administration has not hesitated to use, as further proof of terrorism, the internal documents of the Taliban and other pseudo-religious terrorist and geo-political groups. Moreover, the FBI and the courts have always used the internal damning documents of the Mafia and other criminal groups. In the case of the Church of Scientology, there is a mountain of such damning internal documents deceptively labeled as unpublished, copyrighted, confidential and sacred "trade secret" scriptures. Two examples suffice to illustrate the fact that, in your own words, the Church of Scientology has "hijacked a religion and [made] out of it an instrument of war." The

Church of Scientology has a policy and practice, instituted on February 16,1969, entitled "Confidential: Battle Tactics" which requires the Church to use military tactics and strategy in dealing with the "enemy" which is defined to include American citizens such

as I. The Church, and the individuals subject to the criminal complaint that is this letter, are ordered to conduct:

"… wars of attrition on the basis of total attrition of the enemy. So never get reasonable about them. One cuts of enemy communications, funds, connections. He raids and harasses. Seeing it as a battle one can apply battle tactics to thought actions. Intelligence identifies targets and finds out enemy plans and purposes, enemy connections, dispositions, etc. Never treat a war like a skirmish. Treat all skirmishes like war." emphasis added

Similarly, a Hubbard Communications Office Policy Letter of December 2, 1969 entitled "Confidential: Intelligence-Actions: Covert Intelligence: Data Collection, states that:

"Essentially a covert operation is intended to embarrass, discredit or overthrow or remove an actual or probable opponent. It is a small war carried on without its true source being disclosed. It follows all the rules of war but uses propaganda, psychological effect, surprise, shock, etc., to achieve its ends." emphasis added

Scientology’s Office of Special Affairs ("OSA") conducts the Church’s covert operations, intelligence, intimidation and infiltration, an intelligence operation that rivals the FBI.

"In my opinion the church [of Scientology] has one of the most effective intelligence operations in the U.S. rivaling even that of the FBI."

Ted Gunderson, former head of the FBI’s Los Angeles office, quoted in Time Magazine, May 5,1991, as quoted on-line at Scientology intelligence policies on line at

The matters complained of herein arise from my professional experience as a lawyer with over ten years of litigation against the Church of Scientology in over 15 different cases. My clients prevailed in half of those cases. As you have not been personally involved in those matters, this letter and the events herein may strike you, as they would any rational, law-abiding person, as the paranoid ravings of a person who should be writing mystery novels instead of the cool and rational explanation of an attorney with many years experience pleading sophisticated and complex cases. Nevertheless, I can assure you that this is not so. When considering matters involving Scientology one must put all experience and assumptions aside. For example: that Scientologists and their representatives will tell the truth and act with integrity. On the contrary, and as you will read below, Scientology has an institutional policy and practice of lying and cheating to conceal the truth and advance its global totalitarian agenda and interests. There are no exceptions - even when they are fronted by eminent expensive

lawyers and giant law firms of hundreds and thousands of lawyers blindly selling out their professional oaths and civic ethics for fees aggregating thousands of dollars per hour from a Scientology annual litigation budget which exceeded $40M in 1991. Scientology succeeds in these deceits and manipulations because most people, officials and institutions cannot conceive of such an inherently evil "church" fronted by cherished celebrities who are themselves shielded from the real institutional truths, and who are held hostage by "church" "folders" containing written records of their many confessionals ("auditing sessions") given while they were attached to the church’s principal religious artifact the E-meter. The E-Meter is an early form of lie detector that Hubbard found in a London store and purchased for several pounds. Scientology now sells versions of the E-Meter to "parishioners" in "exchange" for "fixed donations" sometimes exceeding $35,000 for some models. See generally: U.S. v. An Article or Device"Hubbard E-Meter", 333 Supp. 357 (1971). . Indeed, to paraphrase U.S. Defense Secretary Donald Rumsfeld: We are dealing with people who are world-class, shameless liars. They have a pattern of saying things that aren’t so. Their repeated lying should be taken into account in connection with their allegations and explanations.

Indeed, the facts outlined herein are demonstrable, if seemingly incredible, and I beg your forbearance as you work through this summary, even as your ability to accept these events as having actually occurred may well be stretched to the limit! Indeed, the experience of dealing with all of this complex and convoluted material is, I am certain, much like Alice’s experience in Wonderland. and

It is, however, a fact that hundreds of other people, many of whom post to the

Alt.religion.scientology Internet newsgroup, have experiences similar to those I am reporting here. For them too, such experiences have been very damaging to their lives.

See and Many more citizens have been terrorized into silence. See and and (deaths section) and Many others are lost and missing http://home snafu de/tilman/recon html and and

and http:www.// and and

I ask for your patience in reading this long letter for the underlying matters are complicated, intertwined and involve, as against me, Scientology and its lawyers [including Kendrick Moxon ("Moxon"), Donald R. Wager ("Wager"), Elliot Abelson ("Abelson"), Samuel D. Rosen ("Rosen"), Barbara A. Reeves ("Reeves"), Helena Kobrin ("Kobrin"), Ava Paquette ("Paquette"), etc.] commission of demonstrable and corroborated R.I.C.O. predicate acts, bankruptcy fraud, insurance fraud, frauds upon various courts in various states, blackmail, bribery, solicitation, maintenance and champerty, perjury, use of a third person, illegal wire tapping, obstruction of justice, false criminal reports, false state bar reports and other misconduct too numerous to list. In fact, Scientology’s Abelson’s as well as Moxon & Kobrin’s corroborated felony criminal conduct, hate-filled ideology and agenda, and that of others including former Los Angeles County Criminal Court’s Bar Association President Wager and former Los Angeles Police Department Sergeant Eugene Ingram ("Ingram"), directed exclusively at me, include violations of 18 U.S.C. §§ 1621, 1603, 1503, 1512, 371 2(a), 2(b) (perjury, obstruction of justice, witness and evidence tampering, conspiracy,

aiding and abetting and the use of an intermediary). Indeed, oral and written testimony, and corroborating documents include multiple incidents of blackmail,

bribery, extortion, witness tampering, perjury, subornation of perjury, wire tapping, obstruction of justice, frauds upon various courts, attorney

misrepresentations and lies to various courts, false criminal complaints, false state

bar complaints and possible judicial corruption. The evidence trail commences in late 1993, and constitutes an unbroken continuum and R.I.C.O. pattern of criminal, tortious and unethical conduct through to the present day. The recent evidence in one case, the Hurtado v. Berry, is unusually damning because it is corroborated by a lawyer’s testimony/confession (a former Los Angeles County Criminal Courts Bar Association President), over ten different witnesses as well as over sixty different documents -

many of which bear Scientology lead lawyer Moxon’s own signature and handwriting. Consequently, I have lost my career, condominium, car, companionship and retirement prospects. I now live on public assistance and charity as I continue my self-defense and search for justice not only for myself, but also for all other victims of Scientology "Fair Game" Policies and Practices.

I urge that you act immediately, before other avoidable atrocities, tragedies and human carnage happen in America and around the world. We have already seen Heaven's Gate, the Branch Davidians and the People’s Temple create mass graves while the government ignored all warnings in the name of the First Amendment, religious freedom and of not provoking poll-impacting attacks from other religious groups and their political lobbyists.

"Much on our minds was the comment to us by an attorney general’s investigator in September, 1978. Referring to the Peoples Temple cult: ‘We knew all about them before they went down to Guyana, but nobody cared enough to do anything.’ " emphasis added

Dave Mitchell, Cathy Mitchell and Richard Ofshe, The Light on Synanon, p.299.



Moxon commenced his California legal career after a 264-page stipulation and related documents, between the U.S. Department of Justice and the Church of Scientology, named him as an unindicted co-conspirator in the largest ever known criminal infiltration and burglary of the United States Federal Government. This was part of the Church of Scientology’s "Operation Snow White." The massive June 8, 1977, FBI raids upon the Church of Scientology yielded thousands of documents linking the Church to organized crimes. In addition, the FBI raids exposed the frame-up of journalist Paulette Cooper who had written The Scandal of Scientology. She was indicted by a New York grand jury after Church of Scientology

covert agents stole her stationary with her fingerprints on it, mailed themselves a bomb threat, and brought the letter to the FBI. But for the FBI raids the Church’s frame-up of Paulette Cooper would have been successful and she would have likely served time in federal prison. There are other similar examples, such as the former Mayor of Clearwater, Fl., Gabe Cazares who was the victim of a Scientology staged "hit and run" in Washington, DC as well as that of Tom Padgett of Kentucky who recently spent 35 days in solitary confinement as a result of "lost" court papers involving Scientology in a hotly contested child custody case. Another recent Church attempted frame-up involved former

deputy Church leader Jesse Prince who was exonerated by a Florida jury.

As recently as 1989, and contrary to express representations to the IRS, Scientology maintained "Operation Snow White" within the OSA Network. CSI/OSA is the covert operations department of the para-military Church of Scientology. Their very large covert operations group is "Department 20 ("Existence") on the Scientology "Org Board". The Scientology "Org Board" is a seven division and 21-department template detailing "all of the actions encompassed by the [Scientology] organization." The Guardian's Office ("GO") was Department 20 before the 1977 FBI raids on the Church of Scientology. See generally, United States v. Hubbard, 474 F. Supp. 64 (1979); United States v. Kattar, 840 F 2d 118, 125 (1st Cir. 1988). Indeed, Department 20’s legal budget exceeded $40M per annum in the early 1990’s. The current Department 20 (OSA/CSI) U.S. taxpayer subsidized (tax-exempt) investigation, intimidation, "psycho-terrorism" and litigation budget could easily be double that amount.

Ironically, Moxon and I were admitted to the California State Bar on the very same day in 1987. I had previously been admitted to law practice in New York, Australia and New Zealand and had worked for a New York law firm in London, England. Moxon had been previously admitted to practice in the State of Virginia, after his role in the unprecedented and massive Church of Scientology "Operation Snow White" infiltration and burglaries of the many U.S. government departments that were accidentally discovered in 1977. The Scientology burglaries included the Department of the Treasury, the Internal Revenue Service and the Department of Justice. In that regard, Moxon had

submitted forged handwriting exemplars to the FBI as part of a Scientology attempt to obstruct justice. See 1980 documents and and

In 1991, Moxon and I crossed swords for the very first time. My then employer, Lewis, D’Amato, Brisbois & Bisgaard ("Lewis, D’Amato"), my mentor, David B. Parker, and I were retained to successfully defend Century City (Los Angeles) lawyer Joseph A. Yanny in two breach of fiduciary duty actions that his former client, the Church of Scientology, had filed. In part, the cases related to the mysterious 1986 death of

Scientology founder L. Ron Hubbard and the subsequent Miscavige-ordered "concentration camp" internment of perceived leadership threats such as Anne Broeker, Vicki Azneran, Robert Vaughan Young, Stacy Brooks-Young and Jesse Prince.

Seemingly, Annie Broeker still remains interned at the Hemet "Gold" base. Vicki Aznaran escaped with the assistance of a local Indian tribe and sought help from former Scientology lawyer Joseph Yanny. During the retaliatory Church of Scientology v. Yanny litigation, Yanny testified that he stopped representing the Church of Scientology when it requested him to engage in criminal conduct against opposing counsel. Indeed, former church leader Vicki Aznaran has stated "[Scientology] is a criminal organization day in and day out." Doc.14 (Yanny Decl.) and and and

Later, I became involved in one of eight lawsuits that Scientology filed against former L. Ron Hubbard aide Gerry Armstrong. Eventually, Armstrong had to seek refuge from the Scientology litigation juggernaut in Canada. Indeed, there is a lengthening list of people who have had to flee from America’s Scientology corrupted courts and law enforcement. These people include: former Hubbard Archivist Gerald Armstrong; former Hubbard "scripture" co-author David Mayo; Keith Henson and Werner Erhard (the founder of the Scientology influenced "EST" and "The Forum" cults). Scientology has announced that Werner Erhard may now return to the United States. However, Erhard has reportedly said that he is too terrified of Scientology to do so. Last year, Scientology attorney Abelson advised me that Scientology "…wants [me] back in New Zealand where [my] talents will be better appreciated." However, I refuse to allow Scientology "Fair Game" Policies and Practices to terrorize me out my adopted country; one to which I have pledged my loyalty and patriotism.

In 1993, I led a winning team of Lewis, D’Amato lawyers in Church of Scientology International v. Fishman and Geertz ("Fishman-Geertz"). Fishman-Geertz was a defamation case in U.S. District Court. It involved Time Magazine statements that the Church of Scientology was involved in instructions to commit financial fraud, murder

and suicide. Time article on-line at and

(Appendix 1) and

We produced overwhelming evidence that those statements were true and/or substantially true. In fact, there was testimony that Moxon and Ingram had been involved in instructions to murder opposing San Francisco area counsel, Ford Greene, as well as the President of the Cult Awareness Network ("CAN") and her daughter in Chicago, IL. Steps in furtherance of this conspiracy to murder were taken. There was also testimony that Moxon had been involved in the drowning of Los Angeles County Superior Court Judge Swearinger’s dog, Duke, during Wollersheim v. Church of Scientology, 212 Cal.

App. 3r d 872 (1989). Judge Swearinger later stated that he had refused to let this ["psycho terror"] event affect his handling of the Wollersheim I trial. Subsequently, Moxon was involved in five more Scientology lawsuits against Wollersheim. Church of Scientology v. Wollersheim, 42 Cal.App.4th 628, 648-649 (1996).

The Church of Scientology also unsuccessfully sued Time Magazine itself for alleging the so-called religion to be, in reality, "a ruthless global scam." Two months ago, the U.S. Supreme Court refused to reverse the granting of a summary judgment motion dismissing the entire Scientology defamation case against Time-Warner Inc. Church of Scientology v. Time-Warner Inc., 00-1683.

It is curious and should be noted that CNN, which employs celebrity Scientologist Greta Van Susteren, never mentions Scientology or Time’s victory. However, despite spending at least ten million dollars in legal fees, Time-Warner said that it refused to be "…intimidated by the church’s apparently limitless legal recourses." Those "limitless legal recourses" are the primary fund-raising function of the Church of Scientology’s fully tax-exempt International Association of Scientologists ("IAS") to which most Scientologists must belong. In essence, the IAS aggressively raises funds for the Church of Scientology’s campaign of war, vengeance and hate against humanity. L. Ron Hubbard’s own writings demonstrate his hatred of humanity. Those hate-filled writings are among the Church of Scientology’s "sacred" scriptures.

A further example is a Hubbard "sacred" scripture on the establishment of concentration camps to deal with those who stand in the way of Hubbard’s global

totalitarian goals:

"It is not necessary to produce a world of clears in order to have a reasonable and worthwhile social order; it is only necessary to delete those individuals who range from 2.0 down, either by processing them enough to get their tone scale above the 2.0 line…or simply quarantining them from the society." emphasis added

L. Ron Hubbard, The Science of Survival, p. 157


During the Fishman-Geertz case, the Church of Scientology business-trade secret protected "scriptures" were filed in court and later published on the Internet. and What followed is colloquially known as "The Church of Scientology v. The Net." It involved what Australian David Gerard has described as:

"… Copyright terrorism - frivolous lawsuits (unwinnable, but designed to ruin the respondent financially), threats of such lawsuits and even raiding people’s homes and seizing their actual computers to obtain the information thereon. This is designed to intimidate others from questioning or criticizing the Church of Scientology in any way."

See generally: and and and and

Scientology voluntarily dismissed the Fishman-Geertz case on the eve of trial. Scientology openly blamed me for its retreat and defeat in the Fishman-Geertz case and

the Internet publication of its secret scriptures (OT I - OT VIII), which cost approximately $400,000 for Church of Scientology adherents to study in their entirety. Indeed, many ex-Scientologists have spent over a million-dollars to receive these Church

of Scientology "scientifically proven" courses, auditing and processing only to reach the top of the Church of Scientology’s "Bridge To Total Freedom" and find that there is nothing there! Consequently, many of them have left after concluding that these are matters of fraud and not of faith. Of course, such "fixed donations" for purported self-

improvement courses, and dangerous in sauna "purification" treatments, are now fully tax deductible. The Church of Scientology's Form 1023 misrepresented to the Federal Government that it provides free "processing" to staffers ("volunteers" earning approximately $50 per week) who cannot afford to pay such vast sums of money for "total freedom". However, the Church’s Form 1023 did not add the fact that should such staffers ever wish to leave the Church of Scientology, they must first reimburse the Church for the entire cost of such "free processing" as "free-loader debt." Sea Org staffers earn approximately $50 per week and their "freeloader debt" can exceed hundreds of thousands of dollars. This is an example of a Church of Scientology "sacred scripture" which is described as telling an "acceptable truth." For a brief overview of the Church of Scientology’s tax-exempt and tax-deductible religious "Bridge To Total Freedom" see paras. 277-283 and and and ("The Confidential Doctrine of OT III") and ("OT III").

During the Fishman-Geertz case, Scientology retained Moxon and his

investigator Eugene Ingram ("Ingram") to "investigate" me. An search of the names Moxon and Ingram and Eugene Ingram and Kendrick Moxon is particularly chilling. U.S. District Court Judge Harry Hupp, the trial judge, told the Church of Scientology lawyers to stop investigating opposing defense counsel as part of their prosecution of the Church of Scientology v. Fishman-Geertz case. They did not.

Scientology’s judicially recognized "Fair Game" Policies and Practices provide, among other things, that anyone impeding Scientology can be, "… tricked, sued, or lied to or destroyed." Elsewhere secret Church of Scientology scripture states that, "… when we want someone ‘haunted’ we investigate."

See paras. 144 –207 and "Scientology’s Private Investigators," Examples of IRS sanctioned "charitable activity,"

http;// and "Scientology’s Private Investigators" See also: Church of Scientology v. Wollersheim, 42 Cal. App 4th 628,648-649 (1996); Hart v. Cult Awareness Network, 13 Cal.App. 4th 777 (1993); Church of Scientology v. Armstrong, 232 Cal.App.3d1060, 1067 (1991); Wollersheim v. Church of Scientology, 212 Cal.App.872, 888-891 (1989); Christofferson v. Church of Scientology, 57 Ore.App.203 (1983); Allard v. Church of Scientology, 58 Cal.App.3d 439, 443n.1 (1976).

The Church of Scientology International, Moxon and Ingram have each testified that their "investigation" of me led to Ingram’s traveling to New York City and preparing a declaration for signature on May 5, 1994, by my former acquaintance Robert Cipriano ("Cipriano"). Cipriano has testified repeatedly that his signature on this document was extorted. This First Cipriano Declaration, under penalty of perjury, falsely stated that during one six-month period in 1984, I had supposedly been involved in acts of pedophilia with 40-60 teenagers and was associated in the activities of one Andrew Crispo, who was involved in a grisly and sensational 1985 murder. Crispo’s friend, Bernard Le Geros, was sentenced to life imprisonment for the murder. Ingram visited Le

Geros in a New York prison and obtained another declaration falsely alleging that I was associated with Crispo as well as being involved in numerous other major despicable

criminal activities. I was not acquainted with either Crispo or Le Geros. Ingram also obtained three other declarations containing false and defamatory materials. Scientology published these in what they call "dead agent" packs, which Moxon’s investigators use

for the purposes of "Black Propaganda" during what the Scientology enterprise terms "Noisy Investigations." See paras.169, 181,188

Scientology OSA NW Order 15 defines "Black Propaganda" as, "… a covert communication of false data intended to injure, impede or destroy the life of another person…usually issued from a false or removed source from the actual instigator."$/OSANWO/15.htm or

Indeed, in PR Series 18 Church of Scientology staffers are directed to invent whatever they wish to allege. Significantly, as recently as October 9, 2001, the Moxon & Kobrin law office wrote to a Netherlands resident threatening to enforce the Church of Scientology’s copyrights in connection with the very terms "Dead Agenting" and "Targets Defense" activities used by Moxon & Kobrin in their "investigations" and "handling" of regular opposing counsel such as I.

The seditious contents of the "Targets Defense" document that the Moxon & Kobrin October 9, 2001, letter refers to include the "vital targets" of,

"T1 Depopularizing the enemy to a point of total obliteration; T2 Taking over the control or allegiance of the heads or the proprietors of all news media; T3 Taking over the control or allegiance of key political figures; T4 Taking over the control or allegiance of those who monitor international finance and shifting them to a less precarious finance standard." emphasis added para.175

Another Church of Scientology written policy directs Scientology lawyers to use the courts to harass and ruin people rather than to win.

"The purpose of the law suit is to harass and discourage rather than to win. The law can be used very easily to harass, and enough harassment on somebody who is simply on the thin edge anyway…would generally be sufficient to cause his professional decease. If possible, of course, ruin utterly." emphasis added

See para.150

In mid-March 1955, Hubbard wrote:

"The DEFENSE of anything is UNTENABLE. The only way to defend anything is to attack … it is an entirely moral duty to be punitive against outsiders who would stop the progress of this [Scientology] civilization." emphasis added.

See para.148

L. Ron Hubbard’s "Manual of Justice", a "sacred" Church of Scientology "scripture" is even more explicit:

"People attack Scientology: I never forget it, always even the score …overt investigation of someone or something attacking us by an outside detective agency should be done more often and hang the expense … Hire them and damn the costs when you need to…the critic will sure shudder into silence … [Scientology] punishment is gruesome to see sometimes and in this instance there are people hiding in terror on Earth because they attacked us. There are men dead because they attacked us - for instance Dr. Joe Winter. There are men bankrupt because they attacked us - Purcell, Ridgeway, Seppos." emphasis added.

See para.149

In another "sacred" Church of Scientology "scripture" entitled "Critics of Scientology" it is written and mandated:

"Now get this as a technical fact, not a hopeful idea. Every time we have investigated the background of a critic of Scientology, we have found crimes for which that person or group could be imprisoned under existing law. We do not find critics of Scientology who do not have criminal pasts. Over and over we prove this. Politician A stands up on his hind legs in Parliament and brays for a condemnation of Scientology. When we look him over we find crimes-embezzled funds, moral lapses, a thirst for young boys - sordid stuff … We are slowly teaching the unholy a lesson. It is as follows: we are not a law enforcement agency but WE WILL BECOME



See para. 181

Former Los Angeles Deputy District Attorney, and former Gambino mafia family attorney, Elliot Abelson [], Moxon and his law partner, Helena Kobrin, and Scientology executives including Rinder,

engaged in extensive correspondence with me, confirming the nature, scope and

purported purpose of their ("haunting") "investigation" of me. Scientology front groups and shills published the First Cipriano Declaration, and other Moxon/Ingram procured perjury on the Internet where the false statements remain today. Ingram and other Scientology-Moxon-Abelson retained "investigators" personally disseminated the highly defamatory material to my family, friends, acquaintances, law partners, clients, law firm’s clients, judges, politicians and public officials. This was part of what

Scientology Policy and Practice calls a "Noisy Investigation." para.168, 184, 188, 202. The Scientology

policies and practices regarding, for example, "Black Propaganda", "Dead Agenting" and "Noisy Investigations" are specific Scientology scriptures forming part of a larger group of Scientology scripture generically and collectively known as the Church of Scientology "Fair Game" Policies and Practices.

On Sunday, 23 May 1999, German Scientology News wrote: (Subject: Re: OSA info published by German security agency [OSA is Scientology's private intelligence agency. HUBBARD is the founder of Scientology. SO stands for Scientology Organization.] )

"II. The Precursor Intelligence Organizations
6. The ‘Fair Game’ Law
There is hardly a means which Scientology does not use in the persecution of its critics and the achievement of it goals, and it is often not satisfied

until it has brought about the complete destruction of its critics. This is documented not only by the instructions quoted from HUBBARD, but there are also numerous examples of this from real life. In
accordance with the dogma established by

HUBBARD that all people who publicly oppose Scientology are 'criminals' and 'suppressive persons,' the Scientology founder's numerous Policy Letters and instructions in regard to the intended special treatment of this group of people become more significant. The selection of the means in use ranges from open or covert data collection for psycho-terrorism, spying, false accusations and charges, slander (‘black propaganda’), theft, and burglary to actual attacks and - at least this was claimed by one former American OSA agent in sworn testimony in 1994 - attempted murder.

HUBBARD assessed the number of so-called
’suppressive persons’ at ‘about 2.5% of the population.’ Another 17.5% were named ‘Potential Trouble Sources’ (PTS); these are people who are under the influence of ‘suppressives.’

HUBBARD further explained:

"There are certain characteristics and mental
attitudes which cause about 20% of a race to
oppose violently any betterment activity or group.

(comment: by that is meant the SO) ... As they only comprise 20% of the population and as only 2 1/2% of this 20% are truly dangerous, we see that with a very small amount of effort we could considerably
better the state of society. ... Similarly, if society were to recognize this personality type as a sick being, as they now isolate people with smallpox, both social and economic recoveries could occur.
The persecution practices of the Scientology intelligence organizations are known by the name of the 'Fair Game' law, which is reminiscent, for

good reason, of the Middle Ages practice of "outlaw" declarations. In 1965, HUBBARD stated that he released three Policy Letters which referred to this 'Fair Game' law. Although the Policy

Letters were cancelled, that is, withdrawn from public view, they continued to be used by the SO intelligence service as training policy. In 1980, leading Scientology functionaries had to admit in court that the 'Fair Game' law had never really been done away with. Several high-ranking American former SO members, who themselves were victims of the 'Fair Game' law, independently verified that this law continued to be a binding policy of the SO.

The Policy Letter of 21 October 1968, which allegedly cancelled the 'Fair Game' law, is worded suitably ambiguously. This policy stated that the practice of declaring people ‘Fair Game’ will cease. ‘Fair Game’ may not appear on any Ethics Order. It caused bad public relations. This delicate wording is also interpreted to mean that only the practice of declaring shall cease; the practice of treating someone as 'Fair Game' is not the issue, and is
apparently not meant. Just the opposite: it was explicitly emphasized that this Policy Letter did not cancel 'any policy on the treatment or handling of SPs.' The SO continues to issue its so-called 'SP Declares.' Among the Policy Letters which were not affected by the content of this cancellation was

one from 18 October, 1967, on 'Penalties for Lower Conditions,' which clearly described the merciless persecution of SPs. Under the ethics condition of 'enemy,' it literally states:

'SP Order. (comment: 'Suppressive Person
Declaration'). Fair game. May be deprived
of property or injured by any means by any
Scientologist without any discipline of the
Scientologist. May be tricked, sued or lied to
or destroyed.'

In sworn testimony of 22 March 1976, HUBBARD
asserted the opposite of this statement, that he had never had the intention to authorize illegal activity or attacks against anyone with the 'Fair Game' policy. The opposite turned out to be the case: Scientology's criminal endeavors occurred over the

following years under the direction of the
world wide intelligence 'Guardian Office' (GO), which followed the footsteps of its predecessor organization a short time later, when it assumed the 'ethically' legitimized persecution of apostates and Scientology opponents to a previously unknown degree. [After the 1977 FBI raids on the GO it was renamed OSA]." emphasis added "Scientology’s Intelligence Service."

On May 26, 2001, a St. Petersburg Times editorial expressed its views upon such "fully tax-exempt" religious policies and practices:

"An attorney for the Church of Scientology defended the practice of using private investigators to protect the organization from people who ‘harass it’. Interestingly, Scientology doesn’t want to be criticized or harassed, but it does not hesitate to harass and intimidate others. Again and again in recent years, Scientology has claimed that it has reformed, that it no longer engages in the kind of underhanded or illegal behavior and smear tactics that have earned it a sorry reputation around the globe. Again and again, Scientology has argued that

it is a religion and should be treated like any other

church. But again and again, stories surface that set Scientology apart. Not only does it have a penchant

for secrecy, it will spend virtually unlimited time and money on pursuing setting up and bringing down its critics. That’s not like any church we know." emphasis added

False State Bar complaints were filed against me in New York and California. Ingram; Beverly Hills lawyer, Jeffrey Steinberger; and California State Assemblyman, Steven Baldwin, called a major media press conference demanding an LAPD investigation into the false threat that I allegedly posed to the youth of Los Angeles. Ingram and his puppet, California Assemblyman Baldwin, also falsely alleged that I was

associated with other prominent Los Angeles "pedophiles" because of my support for an annual fundraiser to benefit the education of gay and lesbian youth. A number of sitting judges and numerous respected attorneys were also present at this fundraiser. Ingram then complained to the LAPD and the Los Angeles Unified School District that 19 of these fundraiser attendees were convicted sex offenders - based solely upon their having names similar to those in the state register of sex offenders. Ingram even warned the Los Angeles Unified School District to watch for me. Incredibly, Moxon unsuccessfully claimed in Berry v. Cipriano that some of this activity meant that Cal. C.C.P Section 425.16 (the "SLAPP" statute) and Cal. Civil Code 47 (b) (the litigation privilege) applied to protect their conduct from civil liability because it was in furtherance of free speech and the right to petition for redress of grievances! Moxon’s defeat on this issue led Barbara Reeves, Esq., of the Los Angeles office of the national law firm of Paul, Hastings, Janofsky & Walker to disqualify Judge Hiroshige for bias, for being a "lame judge," as explained below.

Commencing in 1994, in excess of ten false State Bar complaints, and at least three false criminal complaints were unsuccessfully filed against me by Moxon and other Scientology shills. Defamatory leaflets were distributed in a three-block radius of my then home and the false allegations delivered to foreign governments with which I dealt professionally. Consequently, I experienced the pain of losing most of my friends and acquaintances, including judges, lawyers, other professionals and business people. Ingram visited and disturbed a number of law offices and businesses just to

ensure that it was fully understood that associating with me might be prejudicial to employment, career and other relationships. Obviously, these terrorized people were only fair weather friends, but that is irrelevant in this context.

Moxon, Abelson and Ingram also "investigated" my then senior partners at Lewis, D’Amato. On January 5, 1995, Abelson visited Robert F. (‘Bob") Lewis, Esq., "laid out the evidence" from the "investigation" and very quickly extorted Bob Lewis into agreeing that as a Lewis, D’Amato partner I would never handle another case involving Scientology; that the AIG insurance group and Lewis, D’Amato would withdraw from the remaining federal court Fishman-Geertz case matters that primarily involved continuing unsuccessful Scientology efforts to have the Fishman-Geertz case files permanently sealed from public view; that a secret settlement agreement would be entered into transferring Dr. Geertz’s files to Bob Lewis personally and then re-transferring them to a public storage facility near the Scientology-Moxon-Abelson offices. It must be remembered that Bob Lewis was also Dr. Geertz’s lawyer and Dr. Geertz had given specific instructions not to enter into any settlement with the Church of Scientology; additionally, his insurance policy included a "consent to settlement" provision. The Scientology-Lewis secret settlement agreement also provided that only Scientology representatives and Bob Lewis would have access to the stolen Fishman-Geertz files. In addition, it was agreed that Lewis, D’Amato would not oppose the sealing of the Fishman-Geertz court files. Previously, the Ninth Circuit Court of Appeals had twice upheld Judge Hupp’s denial of Scientology motions to seal the record. Moreover, Dr. Geertz had specifically instructed the Lewis, D’Amato law firm to oppose any further attempts to seal the court’s files. However, the Fishman-Geertz court files have been "temporarily sealed" ever since the 1995, Scientology, Abelson, Lewis, D’Amato and AIG chicanery. Scientology still attempts, using tax-exempt funds for very expensive copyright lawyers, to prevent citizens from accessing the same materials, some of which it provides to others who make tax-exempt payments aggregating over $500,000. However, all of the same materials are freely available on the Internet, which has been the Church of Scientology’s own Vietnam, in relation to its attempts to manipulate and litigate its own public relations and image. Also see The Wall

Street Journal article

Consequently, Steven Fishman and Dr. Geertz were forced to file their malicious prosecution case against Scientology and Abelson without their new attorney, Ford

Greene, Esq., having the benefit of Dr. Geertz’s files or court records from the underlying dismissed defamation case. Having stolen the client files, secreted the court record, silenced me (the client’s immediate attorney) and concealed the true facts, Abelson was mistakenly named as a defendant. Later, Abelson sued Greene for malicious prosecution and forced a settlement in Abelson’s favor. Dr. Geertz filed a California State Bar complaint regarding the secret settlement, theft and concealment of his attorney

client files. The State Bar dismissed the complaint at intake because these opposing counsel did not owe a professional duty to Dr. Geertz! However, the opposing counsel had breached numerous other statutes and ethics rules. The opposing counsel were former LA County Bar President John ("Jack") Quinn, Moxon, Drescher and Abelson. No action has been taken against Bob Lewis or the other involved attorneys directly and supposedly representing Dr. Geertz’s interests. However, all of these attorney and "religious" crimes and frauds were rendered useless by the Internet where many of the sealed files were and are posted.

OSA chief Rinder and Abelson visited me in my Lewis, D’Amato office to unsuccessfully obtain my confirmation that I would never litigate against the Church of Scientology enterprise again. Subsequently, Bob Lewis clarified that the unethical restriction only applied while I remained at the Lewis, D’Amato law firm. The Fishman-Geertz malicious prosecution case was defended by a battalion of Scientology attorneys including Abelson, former L.A. County Bar President Jack Quinn (who was also involved in other aspects of this), Moxon and Gerald Feffer of Washington, D.C.’s Williams & Connolly. Los Angeles County Superior Court Judge Alexander Williams, III, (an acquaintance of Feffer) dismissed the case on summary judgment. See and (click on reposted classics and see #s 2, 16-20 and 91) At the time, no one knew of the subsequently revealed disqualifying connections between Judge Williams and the

Church of Scientology Office of Special Affairs.



As introduced and noted above, in 1991, and shortly before all of this chicanery, Miscavige, Rathbun, Moxon and Williams & Connolly’s Feffer (reputably with total U.S. DoJ access) had instantly convinced the then IRS Commissioner to suddenly reverse the IRS/FBI twenty-year denial of IRS § 501(c)(3) status and finally grant Scientology tax-exempt status in 1993. The U.S. Supreme Court had recently affirmed the IRS position denying Scientology section 501(c)(3) status. Hernandez v. Commissioner, 490 U.S. 680 (1988). A surprise Scientology visit to the IRS Commissioner personally, and the

sudden IRS tax status change and billion dollar windfall to the Church of Scientology and certain of its leaders, was upon the express representation and condition that Scientology did not and would not engage in such litigation and related conduct as I am now describing. The Clinton Administration and Church of Scientology Tax Closing Agreement was supposed to remain secret and confidential for reasons of "national security." However, and in truth, the Church of Scientology poses a clear and present danger to our national security. See generally the internal IRS report on the secret IRS Closing Agreement. Also: and and and and and

Soon after the signing of the Closing Agreement for the secret IRS-Scientology tax deal, very senior Scientology officials (direct subordinates to Church of Scientology leader "Captain" Miscavige) visited a number of former Scientology senior officials who had sworn expert witness testimony that was filed in Fishman-Geertz. Three of these former Scientology officials have testified that they were unsuccessfully subjected to great pressure, intimidation and bribes of over $200,000 each to recant their testimony and to sign false declarations alleging that I had suborned and created perjury for filing in Fishman-Geertz. The testimony established Scientology fraud upon the IRS

because it contradicted material responses and misrepresentations by the Scientology

enterprise to the IRS. Those material [mis]representations were part of the official basis for the IRS’s one billion dollar tax relief (waiver) package to the Church of Scientology and several of its senior leaders including "Captain" Miscavige.

The three former high-level Scientologists who had held senior management positions in the cult refused to join this blatant criminal conspiracy, obstruction of justice and tax fraud being perpetrated by Scientology and its lawyers. Even Wager, on or about November 21, 1994, met with one of the former Scientology senior executives, expressly in connection with me. Significantly, Abelson had some brief success of his own. A former Scientology covert intelligence operative had been given a grueling 17 - day deposition in Fishman-Geertz while being guarded by off-duty LAPD officers. Many months later, Abelson flew the former Scientology operative from Florida to Los Angeles and, after two days of "persuasion" and suborning of perjury, video-taped the witness and him reading and agreeing to a recant of the witness’ Fishman-Geertz deposition testimony. One month later, the witness reconsidered and testified as to what had just happened with Abelson.

Scientology then obtained Federal court search and seizure orders and, accompanied by armed U.S. Marshals, raided the homes of a number of Scientology critics. They had posted copies of the Fishman Declaration to the Internet. These critics’ computers, records, books and papers were seized with the assistance of the armed U.S. Justice Department marshals. Subsequently, several U.S. District Court judges opined that the Scientology lawyers had misled them. The Washington Post was unsuccessfully sued by Scientology, for publishing part of the Fishman Declaration. The Post had successfully broken Scientology’s blockade of the Fishman-Geertz federal courthouse files. My then senior law partner Bob Lewis refused The Washington Post’s request for my active involvement in the litigation. Bob Lewis also refused another defendant’s request that I represent it even with the benefit of a one million-dollar insurance policy.

The express reason was the Fishman-Geertz [no longer] secret settlement agreement between Bob Lewis, his other client AIG and Scientology and the unwritten agreement that I would not ever again represent a party adverse to the Church of Scientology.

I was professionally and personally outraged by all of these lawyers’ felonies, torts and ethical violations and I refused to be cowed in this manner. I resigned from the

Lewis, D’Amato partnership and became a partner at Musick, Peeler & Garrett, a very fine law firm for which I have the utmost enduring professional respect and personal gratitude. I was able to accept defense retentions in a number of other cases filed by Scientology in connection with the alleged unlawful dissemination of its religious "trade secrets," unpublished copyrights, picketing and other expressions of free speech. See generally: Scientology responded with Samuel D. Rosen ("Rosen"), Esq., of the New York office of Paul, Hastings, Janofsky & Walker ("Paul, Hastings"). In Denver, Colorado, under despicable circumstances of which he had no personal knowledge, Rosen obtained the first ever monetary sanctions order against me.



Meanwhile, Moxon had also filed over 30 baseless and unsuccessful "cookie-cutter" lawsuits against the Cult Awareness Network ("CAN") in a successful Church of Scientology effort to bankrupt fellow IRS section 501(c)(3) tax exempt CAN and to take it over as a Church of Scientology (false) "front group." It was the "Bowles & Moxon Plan 100." It would seem to contradict the statutory requirements that the "fully tax-exempt" Church of Scientology be acting for the charitable, religious, scientific or educational benefit of the public. Certainly, it flouted numerous criminal and ethical restrictions that applied to the Bowles & Moxon lawyers irrespective of their status as practicing Scientologists. To complete the sinister Scientology program, Moxon had solicited the representation of another cult’s victim, Jason Scott, and filed Scott v. Ross in the State of Washington. At Moxon’s request, the trial judge excluded all references to Scientology’s involvement in the case and Moxon obtained a $4M judgment against CAN, which had referred Jason Scott’s frantic mother to a deprogrammer in a largely successful attempt to recover her three teenage sons from their then cult’s mental manipulators. Instead of compromising and settling the judgment for Scott, Moxon pursued his other and undisclosed client’s (Scientology’s) agenda, refused any settlement,

and drove CAN into bankruptcy. Moxon, using Scientology shills, then purchased CAN’s name brand assets from the CAN bankruptcy estate. Scientology now sinisterly and stealthily operates CAN with its terrifying ability to intimidate and silence families and others seeking to communicate with, or rescue, loved ones from Scientology or another cult. For similar reasons, the seizure of the old CAN files, and the pending Church of Scientology access to the Lisa McPherson Trust files, represent the illegitimate use and abuse of the U.S. legal system to acquire "intelligence" information as to the identity and contact information of the family and friends of victims of the Church of Scientology, which then uses its thuggish lawyers, sleazy private investigators and "goons" to "shudder" such persons into submissive silence and "terror."

When Jason Scott finally realized Moxon’s multiple layers of undisclosed non-waivable conflicts of interest, and Moxon’s real loyalty and conflicting agenda, Jason Scott fired Moxon and retained me. This provoked a storm of national media attention. Immediately, the Abelson, Moxon & Kobrin worldwide "investigation" of me became

even more feverish. Ingram and Scientology’s other "investigators" conducted even more "interviews" concerning me. Visits were made to Musick, Peeler & Garrett corporate clients, former Musick, Peeler attorneys and non-profit organization clients that were then required to provide their tax-exempt organization financial records to the Moxon, Abelson and Church of Scientology "investigators." Their "investigators" even spent days in the Musick, Peeler reception area, unsuccessfully insisting that they had packages and photographs of me, which had to be personally shown to and discussed with my senior partners. Understandably, and obviously reluctantly, Musick, Peeler & Garrett gave me a choice; either leave Scientology-related litigation or leave the firm (in which instance they would and did provide me with very generous assistance and support).





I believed that at least a few lawyers had to remain available to provide representation against what a number of European governments have labeled Scientology’s "psycho-terrorism;" criminal fraud; human rights abuses; totalitarian agenda; and litigation abuse. I had seen many lawyers and law firms terrorized out of

Scientology-related matters by despicable, illegal and unethical conduct perpetrated by highly paid major law firms and private investigators. I had the specialist knowledge and experience to litigate against Scientology. As importantly, I have always been a single man and have no dependents. Consequently, I did not have the vulnerabilities and terror pressure points of a spouse, significant other, children or their need for financial support.

In other words, I was not as susceptible to a quiet "compromise" as a lawyer with a spouse, children and all of the heinous opportunities those relationships posed to a "psycho-terror" group such as the Church of Scientology and its covert operatives, "out-law"yers and "investigators" engaging in defamation and character assassination by innuendo. At least, I thought so at the time!

Scientology’s Internet shills were goading me to sue if, as I claimed, the First Cipriano Declaration and related allegations were indeed false. Reluctantly, I chose to leave the Musick, Peeler law firm and continue to represent the victims of the Scientology-Moxon & Kobrin-Abelson litigation abuse and terror investigation enterprise. I also decided to sue, for defamation and abuse of process, because of what I had just learned regarding the First Cipriano Declaration. In February 1998, I formed my own solo practice and then merged with three young lawyers to form Berry, Lewis, Scali & Stojkovic.

In April 1998, I again agreed to represent Palo Alto computer engineer Keith Henson. This time it was in the statutory damages phase of Scientology "unpublished" copyright case. The copyrighted document (NOTS 34) evidenced clearly the continuing unlawful practice of medicine by Church of Scientology contrary to a specific 1977 F.D.A. injunction. It was the first of ten lawsuits that the Church of Scientology, Moxon & Kobrin, Abelson and/or Paul, Hastings, Janofsky & Walker filed, maintained or instigated against Mr. Henson at a cost that must exceed five million dollars and now involves the Canadian Government and soon the U.S. State Department. In referring to the earlier grant of summary judgment against the then pro per Henson, and the subsequent statutory damages of $75,000, a Wall Street Journal editorial opined that Northern District Court judge Ronald M. Whyte had "turned copyright law on its head."

See, Wired News article:http//wired.0com/news/politics/0,1283,12355,00.html and and

At the conclusion of the Henson I case involving a single alleged copyright infringement, Rosen, Moxon & Kobrin and Eric Lieberman of New York’s Rabinowitz, Standard, Krinsky & Leiberman unsuccessfully sought a contempt order and sanctions of $900,000 against me, claiming that my three week solo court appearance on behalf of

Mr. Henson (while charging a flat $5,000 fee) had required Scientology’s use of 28 opposing lawyers from a number of different national law firms at a cost of over $2M. The California Court of Appeals has opined that such aggressive litigation tactics by the Church of Scientology can "have constitutional implications." Church of Scientology v. Wollersheim, 42 Cal. App. 4th 628, 649 (1996).

Consequently, in 1998, the Church of Scientology forced Mr. Henson into a no-asset bankruptcy where it continues to engage in intensive litigation which, at times, appears to be costing at least $100,000 per month and involves very expensive appearances by New York copyright lawyer Samuel D. Rosen, Esq., of the giant Paul, Hastings law firm, in endless judgment debtor examinations in the San Jose area and interference in attempts by Mr. Henson to find employment. As you will read below, Mr. Henson has now been granted "refugee status" in Canada while his asylum application is being processed.



Five months earlier, in December 1997, and while still a partner at the Musick, Peeler law firm, I had learned for the first time of the whereabouts of the elusive Robert Cipriano and the identity of certain anonymous distributors of the highly defamatory First

Cipriano Declaration. They included Scientologists Rev. Glenn Barton, Isadore Chait, Russell Shaw and Donna Casselman. They were all active in the unincorporated and elusive CAN Reform Group, a Scientology "front group" involved in the CAN takeover. Later, there would be testimony and documents, much of it corroborated, that the following had then occurred.

Moxon & Kobrin, through Ingram, had a "plant" in the Musick, Peeler law firm (later I would learn of at least two other Scientology "plants" in my office and home). Moxon and Ingram obtained a draft of my Berry v. Cipriano complaint from their

"plant" within Musick, Peeler. Moxon and Ingram then located Cipriano before he moved in a final, but unsuccessful, attempt to avoid service of my defamation lawsuit. Ingram met with Cipriano in Santa Barbara County and had him travel to Los Angeles to meet with Moxon at the Moxon & Kobrin false-front law office. They showed Cipriano the stolen draft Berry v. Cipriano defamation complaint and told him they would provide free representation if I filed. When I did file, Cipriano wanted to immediately settle with me on the reasonable written terms I proposed. However, late on a Saturday night, Moxon and Ingram intervened. Moxon and Ingram raced to the home of Cipriano and his then girlfriend, unsuccessfully offered her benefits, successfully solicited the legal representation of Cipriano, "relocated" him and later promised him up to $750,000 in financial benefits if he co-operated to maintain the perjuries they had earlier extorted for the First Cipriano Declaration. Ingram, Moxon and Abelson knew of my long-time statements that when I finally found and sued Cipriano they would also be defendants as well as being important material witnesses.

Whether as witnesses or defendants, applicable conflict of interest rules precluded Moxon, Kobrin and Abelson from also being the lawyers for any of the other defendants. However, Cipriano was the only "evidence" of "truth/substantial truth" that they had. They had to keep him committing perjury. Later, as Cipriano’s lawyer, and without disclosure or waiver of the multiple and non-waivable conflicts of interest, Moxon would fallaciously and dishonestly misrepresent to the Berry v. Cipriano court that none of my 40-60 alleged victims were "locatable" as they were, "…teenage hustlers who had all died of AIDS." Because of the manner in which the then known facts emerged, I filed three different defamation law suits at three different times, all of which were deemed related and consolidated for all purposes (collectively, "the Berry cases"). Scientology and Moxon assembled a formidable and very expensive army of national and international law firms to defend the consolidated Berry cases. In essence, the Berry cases alleged that the First Cipriano and related Declarations were defamatory, part of an abuse of legal process and had caused me damage. Rev. Barton did not even wait for the lawsuit to be served on him. The Scientology litigation juggernaut launched yet another litigation blitzkrieg.

The Scientology litigation juggernaut included: Paul, Hastings, Janofsky & Walker’s Los Angeles and New York offices (Samuel D. Rosen, Barbara Reeves, Michael Turrill and Brad Pauley); Williams & Connolly of Washington, DC (Gerald Feffer); Zuckert, Scoutt & Rasenberger of Washington, DC (Monique Yingling); Wasserman, Comden & Casselman of Los Angeles (Gary Soter); Simke Chodos of Los Angeles (David Chodos and James Martin); William T. Drescher of Los Angeles; Elliot

Abelson of Los Angeles and, of course, Moxon & Kobrin of Los Angeles. Rosen was

then billing at $490/hour giving, as he stated, "No discounts to anyone."

The Berry cases were randomly assigned to Los Angeles County Superior Court Judge Hon. Ernest M. Hiroshige. He denied Cipriano’s demurrer and C.C.P.§ 425.16 "SLAPP" motion. On behalf of Scientologist Barton, Rosen and Reeves of Paul, Hastings filed a C.C.P.§ 170.6 peremptory challenge for bias. The Berry v. Cipriano/Barton cases were reassigned and then reassigned again to Hon. Alexander Williams III. Later, Cipriano testified that at the time (June 1998) Moxon informed him that Judge Hiroshige

was "a lame judge" and Judge Williams was a "friend of Scientology." The Paul, Hastings law firm, had just hired Judge Williams’ most recent clerk and Judge Williams was socially acquainted with Ms. Reeves’ husband an Appellate Court Justice. New York attorney Rosen improperly persuaded Judge Williams that there was still discovery priority in California, and that I should be precluded from taking any depositions until Scientology-Cipriano’s deposition of me was concluded. Eight months and twelve deposition days later Moxon, Rosen and Reeves claimed my deposition in Berry v. Cipriano, et. al., was still incomplete. Judge Williams denied my C.C.P. § 460.5 (c) preferential defamation trial setting request (ironically, " … because the law disfavors claims for defamation.")! Initially, Judge Williams refused to handle discovery matters himself. He was "too busy." He appointed a retired California Supreme Court justice and required me to pay nearly $9, 000 for the retired judge's initial handling of discovery matters. Eventually, I persuaded Judge Williams that I could not afford such a non-consensual and judicially enforced litigation expense.

In addition, Judge Williams ordered that I could not assert any privacy objections, I had to "…just sit there and take it", and that I had to concurrently, comprehensively and

repeatedly respond to: over 2,000 form interrogatories; 289 special interrogatories; 121

Requests for Admission (each accompanied by 5 interrogatories, totaling an additional 605 interrogatories); 532 Requests for Authentication; 316 categories of document demands (responding documents to be carefully organized in accordance therewith). Judge Williams ordered this overwhelming discovery both during and after the twelve days of my uncompleted deposition. At the same time, Judge Williams refused me the opportunity to take any depositions of any defendant. However, he allowed Defendants

to take the depositions of at least 12 other persons and noticed the depositions of over 30

others. Scientology and Lewis, D’Amato successfully obstructed the addition (Civ.Code § 1714.10) of Moxon and Abelson as defendants in the case by unsuccessfully removing Berry v. Miscavige to Federal Court (speciously arguing it was related to the pending

Pattinson v. Church of Scientology case where I was plaintiff’s counsel). A former Scientologist and Paul, Hastings employee even testified about certain Paul, Hastings’ attorneys paying $300 for the backdating of certain court documents. Judge Williams was

unmoved. During the travesty, Judge Williams commented that because he was a former federal criminal prosecutor the Paul, Hastings lawyers knew much more about the rules of civil procedure than he. One of the Berry v. Cipriano defendants, Mathilde Krim, Ph.D., entered into an early settlement.

In November 1998, Christian J. Scali, one of my then two law partners, volunteered assurances he would never allow the Scientology lawyers’ litigation blitzkrieg to drive him and my other law partner, J. Stephen Lewis, out of the case and out of our fledgling law firm. Then, in late November 1998, on the day of the expiration of the statute of limitations, Scali actually chose not to file a previously prepared summons and complaint against the Los Angeles Police Department ("LAPD.") It arose from Moxon’s "investigator" Edwin Richardson, and then LAPD Scientology "chaplain" Barton, who had physically jumped and battered Scientology critic Keith Henson and falsely arrested him. Proper pre-filing notice had been given. I was furious when several weeks later I enquired of Christian J. Scali, Esq., and learned that the Henson v. LAPD and Barton complaint had not been timely filed as I had instructed. Subsequently, Cipriano testified that at this time he personally observed Moxon directly

communicating with Lewis and Scali regarding their subsequent announcement made at the end of December 1998, that they were dissolving the firm and withdrawing from my legal representation with only four days’ notice to me. Later, you will read of further Scientology, Moxon, Kobrin and Paquette ethical wrongdoing in connection with my former partner J. Stephen Lewis.

The Scientology lawyers had scheduled a blistering, daily schedule of depositions, discovery responses and motions for the following thirty days of January 1999. I

requested discovery extensions. Judge Williams acknowledged that ordinarily discovery

extensions would be granted in these circumstances. However, he denied my requests

because I was, "… no ordinary attorney." His faint flattery damned me. Now without my two counsel, I stood alone, and with responsibilities to other clients in other matters. As was intended, I was finally overwhelmed by such tactics, discovery deception and duplication. I was unable to respond to the many hundreds of form interrogatories to the satisfaction of either Moxon or Judge Williams. In early February 1999, on behalf of Berry v. Barton defendant Scientologist Chait, Moxon successfully moved for terminating and monetary sanctions as a discovery sanction in connection with these

many hundreds of form interrogatories and related requests. Curiously, Judge

Williams expressly invited every other defendant to immediately file similar motions. Barbara Reeves of Paul, Hastings then proceeded to try and schedule the deposition of Michael Hurtado whose involvement and perjury is explained below. Barbara Reeves represented that Hurtado would corroborate Cipriano’s testimony. I knew that to be building perjury upon perjury, to bolster and buttress even more perjury. Ms. Reeves was unmoved by Hurtado’s own voicemail message denial of his subsequently verified allegations. Consequently, I had no practical alternative but to make a strategic withdrawal from Judge Williams’ courtroom. In late February 1999, I immediately and voluntarily dismissed all defendants without prejudice. At least that preserved my ability to return to court at another time and under changed circumstances. Six months later, I would learn that Judge Williams’ fiancée actually worked for defendant Church of Scientology International ("CSI"). Concurrently, CSI also employed Moxon & Kobrin as well as all of the other Scientology lawyers!

Around the same time, the District Court remanded Berry v. Miscavige, Church of Scientology International back to Judge Williams and the consolidated Berry cases that I was voluntarily dismissing in the impossible circumstances explained above. Lewis, D’Amato entered into a settlement in Berry v. Miscavige. Obviously, continuing to prosecute Berry v. Miscavige (and moving to add Moxon and Abelson as Cal. Civ.Code § 1714.10 defendants) was also not viable for me at that time. Consequently, over the course of several days in late February 1999, Barbara Reeves, of the giant Paul,

Hastings, Janofsky & Walker law firm, successfully prevailed upon me to also voluntarily dismiss the Berry v. Miscavige, Church of Scientology International case,

without prejudice, as a prerequisite to serious settlement discussions. I reluctantly agreed. No serious settlement discussions followed. However, Barbara Reeves obtained a $28,000 prevailing party costs order on behalf of Scientology defendant Barton which, in accordance with the Church of Scientology "Fair Game" Policies and Practices, is still being used to "utterly destroy" me and to limit my right of free speech. Indeed, Moxon,

Kobrin and Paquette recently used the related Barton real estate lien to force my condominium into a foreclosure and intentionally deny themselves and my other lien holders (particularly the IRS and Cal. State Franchise Tax Board) the benefits and equity of a favorable pre-foreclosure sale. Scientology’s benefit was continued prosecution of Barton’s non-payment of sanctions claims before the California State Bar and the U.S. Bankruptcy Court (Berry v. Barton), and continuing regular judgment debtor examinations of me (Scientology "Intelligence Operations.").

As a leader of the unincorporated secretive Scientology-front CAN Reform Group, Rev. Glenn Barton had participated in the publication and dissemination of the First Cipriano Declaration. Barton co-defendant, Shaw, executed a mutual general release. He agreed to testify at a future deposition. His counsel represented that Scientologist Shaw’s testimony would be that he merely maintained a certain Internet

website as a transmission conduit for the other Scientology defendants’ website content, including the First Cipriano Declaration, which he did not control. In late March 1999, Lieberman and Moxon refiled their motion for Rule 11 sanctions in Pattinson v. Miscavige and on April 5, 1999 Moxon filed Hurtado v. Berry as explained below.

First, allow me to return to the Pattinson I case that was filed in May 1998. Pattinson was a former 25-year Scientology adherent who had paid over $500,000 in "fixed donations", in order to receive the most advanced of Scientology’s "scientifically proven" trade-secret religious "processing". paras. 277-283. However, he was not cured of his problem or "ruin" as had been (mis)represented by Scientology® and Dianetics® representatives. The Federal and subsequent State Pattinson pleadings were carefully crafted and drafted within the facts, causes of action and opinions of the controlling California Supreme Court authority. . Four of the fraud claims were specifically pleaded within the facts and decisions of other Scientology cases decided against the church in California and upheld upon appeal. Thus, there were strong grounds for the application of collateral estoppel type principles. However, Moxon, Kobrin and Paquette immediately obstructed, delayed and diverted the Pattinson case. They solicited and filed a retaliatory lawsuit, Revelliere v. Pattinson.

Twelve years earlier, in Paris, France, Revelliere loaned Pattinson some money, which was partially repaid. They had been out of touch with each other for five years. Scientology senior staffer Reveillere claimed that he had not known of Pattinson’s whereabouts until Pattinson sued the Church of Scientology and certain of its staff members, etc. Revelliere, living and working for Scientology in Copenhagen, Denmark, speciously claimed that after learning of Pattinson’s whereabouts he then located Moxon, Kobrin and Paquette and retained them to immediately sue Pattinson. The retaliatory and obviously solicited Revelliere v. Pattinson lawsuit was an action on an unpaid note (to which there are few defenses). Revelliere v. Pattinson was filed in Orange County Superior Court, quickly proceeded through very abusive, collateral discovery and onto summary judgment. With the Reveillere v. Pattinson judgment in hand, Moxon

proceeded to harass Pattinson regarding his ability to finance and obtain money for the litigation of Pattison v. Church of Scientology International. In addition, Moxon & Kobrin unleashed their "chief investigator" Ingram to conduct the usual defamatory and "haunting" "investigation" of Pattinson pursuant to the Scientology "Fair Game" Policies and Practices. See

Meanwhile, Rosen and Lieberman from New York appeared in the California Central Federal District Pattinson I case along with Barbara Reeves, Moxon & Kobrin and other Scientology counsel. Again, Rosen and Reeves successfully claimed discovery priority, engaged in a never-ending deposition of Pattinson, and obstructed any discovery by the plaintiff, Pattinson. For the next nine months they engaged in such incessant pleading battles that no answers were ever filed. However, Pattinson was required to participate in days of harrasive depositions by Rosen and Moxon.

In March 1999, after the voluntary dismissal of the Berry cases, and after arguing that the dismissals were indicative of meritless and bad faith litigation by me, Moxon and Leiberman successfully filed a Rule 11 sanctions motion against me in Pattinson v. Miscavige ("Pattinson I"). Significantly, the Moxon Rule 11 and Section 1927 order was expressly limited to only one defendant in Pattinson I (Moxon) and the allegations

(contained in one single paragraph) asserted against him. In essence, that contrary to the Church’s express and material 1991-1993 [mis]representations to the I.R.S. as to its new

and reformed character and conduct, Scientology was still engaging in criminal activity, and it was doing so through stipulated, unindicted co-conspirator Moxon. Some of Moxon’s judicially recognized and stipulated criminal activity is set forth above and in cases such as U.S. v. Hubbard, 474 F.Supp.64 (1979), where Moxon was stipulated by the Church of Scientology to be an unindicted co-conspirator in the 264 page Department of Justice - Scientology Stipulation Of Evidence. See generally: United States v. Kattar, 840 F2d 118,125,126 (1st Cir.1988); U.S. v. Kember, USDC Dist.Col. Criminal No. 78-401(2) & (3).

It is also clear and convincing, from the subsequent Cipriano confession and testimony summarized below, that at the very same time as Moxon was inside the Federal Court obtaining Rule 11 sanctions against me for alleging that Moxon was involved in criminal conduct on behalf of the Church of Scientology, Moxon was outside the same federal courtroom, concurrently engaged in major felony crimes with CSI/OSA, Abelson, Ingram and Wager. In other words, at the very same time as he was swearing to the Federal Court in the Pattinson I case that he was not engaged in criminal conduct and successfully obtaining Rule 11 sanctions against me, Moxon was simultaneously

committing serious felony crimes against me, as plaintiff Pattinson’s lawyer, together with CSI/OSA, Wager, Abelson, Ingram, Cipriano, Apodaca and Hurtado. In addition, Moxon obtained the Rule 11 and Section 1927, $28,000 costs order against me with an express finding that it was reasonable for him/CSI/OSA to incur the expense of retaining New York counsel Lieberman to defend him in Los Angeles against such a "frivolous"

and "vexatious" allegation. The next month, in May 1999, Moxon-CSI then used this Rule 11 order as principal factual support in filing for Judge Williams’ August 20, 1999,

"vexatious litigant" order against me.

On March 19, 1999, the month before Judge Snyder granted the CSI-Moxon Rule 11 motion, and after constant carping by the Scientology attorneys, the Pattinson I case

was voluntarily dismissed in Federal Court and simultaneously refiled in State Court (Pattinson II) without any federal question causes of action (R.I.C.O., etc.). Church of Spiritual Technology ("CST") was one of the Pattinson II case defendants. CST is a little known Scientology corporation operating from a post office box. On the basis of my

knowledge, experience, investigation and research into Church of Scientology matters, I honestly believed CST to be a necessary and proper party for both liability and judgment collection purposes, alter ego purposes, and for numerous matters relevant to the two Pattinson cases. I was one of the relatively few who knew that CST was the very apex of the Scientology corporate pyramid and that it was the ultimate owner of all of the most valuable Scientology property, the Scientology intellectual property registrations.

CST’s ownership is vested in four very low profile individuals: Sherman D. Lenske, Esq., of Woodland Hills, CA; former IRS Assistant Commissioner Meade Emory, Esq., of Lane, Powell, Spears, Lubersky LLP of Seattle, WA; Leon C. Misterek, Esq., of Kirkland, WA; and Scientology central reserves money man Lyman D. Spurlock. Curiously, CST Special Trustee Meade Emory, Esq., was the Assistant IRS Commissioner at the very same time in the 1970's that Moxon and the Church of Scientology were committing the largest ever known criminal infiltration and massive burglary of the IRS and numerous other U.S. Federal Government Departments. This was part of Scientology’s "Operation Snow White". CST Special

Trustee Lyman Spurlock is an accountant and the only Scientologist among the four who it appears may be the actual owners of the corporations and Churches of Scientology. Alternatively, and contrary to applicable law, one person (David Miscavige) is the only person who ultimately controls and owns the entire churches and corporations of Scientology. Additional support for this conclusion is the documentation indicating that some single person has the sole and absolute power to dismiss all of the trustees and directors, etc., of CST and reappoint new ones. Consequently and contrary to applicable law, this single individual, probably David Miscavige, has total control and ownership of all of the approximately 150 tax-exempt "corporations" and Churches of Scientology,. The Scientology organizational hierarchy, and its associated maze of mirrors, is examined in detail in Church of Spiritual Technology v. United States, 26 Cl.Ct. 713,730-732 (1992), and the various Church of Scientology cases cited therein. It is even more interestingly examined and dissected on the Internet. For example see, and and

CST filed a spurious but successful C.C.P.§ 425.16 "SLAPP" motion in the State Court Pattinson II case. The "SLAPP" statute permits dismissal of lawsuits filed to chill the exercise First Amendment and other constitutional rights. CST had retained expensive Washington, D.C., tax counsel (Monique Yingling, Esq.) and several expensive New York counsel (Paul, Hastings’ Samuel D. Rosen and veteran Scientology attorney Lieberman) to appear with Kendrick L. Moxon, Esq., on the motion. The "SLAPP" motion relied heavily and expressly upon the August 20, 1999, vexatious litigant order of Judge Williams in the Berry consolidated cases and Judge Snyder’s July 16, 1999, ruling

in the Federal Court Pattinson case. Under C.C.P.§ 425.16(c) a "… prevailing party… shall be entitled to recover his or her attorney’s fees and costs." On November 16, 1999, attorneys’ fees and costs were awarded against my client, Pattinson, and me in the amount of $12,500.





For the sake of clarity, I now return to the Berry cases. One year earlier, in late 1998, in the Berry v. Cipriano consolidated cases, Judge Williams had ordered me and my prior law firms to produce all malpractice insurance policies extending back many years. Interestingly, I was the plaintiff. There were no cross-complaints to merit such an unusual order in those circumstances. On November 25, 1998, on day twelve of my deposition, and stripped of any "privacy objections," Moxon and Rosen questioned me about my prior sexual relationship with subsequent pro bono client, 24-year-old Michael Hurtado. Rosen demanded his address. At the time, I was Hurtado’s counsel of record in an active pending criminal case in Santa Monica Court. Immediately, Moxon, Abelson

and Ingram started interviews of Hurtado’s extended family based on information obtained by Rosen in deposition of me and also found in the Santa Monica court files. Less than one month later, in December 1998, Abelson told then LA County Criminal

Courts Bar Association President Wager about Hurtado, who himself had not met with any of the Scientology attorneys or investigators at that time. Wager immediately opened his Hurtado client file and began billing in connection with his representation of Hurtado. Wager had never met Hurtado and Hurtado was still my client. Hurtado himself

would not be solicited and become Wager’s client for another six weeks! Wager then spoke with Ingram about Hurtado at least three times. Wager understood that Ingram was working for Scientology because Ingram told him he was working for Moxon at the time. Moxon, acting as Scientology's counsel, also contacted Wager regarding Hurtado. Indeed, Wager had at least six Hurtado related conversations with Moxon before he ever met Hurtado. In mid-January 1999, Ingram first appeared at the Hurtado’s home, once again unannounced and uninvited. Ana and Vanessa Hurtado (Michael’s mother and sister) have testified that Ingram told them that I was a "child molester." Ingram said he was investigating me from New York and, "… had been investigating Berry [me] for a long, long time." Ingram suggested to the Hurtados that I had taken "advantage" of the clearly adult Michael.

When Ingram showed them the videotape of my November 25, 1998, deposition testimony in the Berry cases, regarding my sexual relationship with Michael Hurtado,

Mrs. Hurtado did not want to see it, or look at it, and she refused to keep it, saying, "Forget it. Take it." The entire Hurtado family had long believed that homosexual conduct was inappropriate. Yet, Ingram showed them the First Cipriano Declaration, as well as multiple other documents. Ingram wanted the Hurtados "… to see a lawyer because of this matter," and suggested that there was a possibility that there could be a civil suit against me. Within a very few days, Ingram took Ana, Miguel (Michael’s father), Vanessa Hurtado and a Cuban writer friend of theirs to see then Los Angeles County Criminal Courts Bar Association President Wager at Wager's office. There they were also introduced to lead Church of Scientology in-house lawyer Moxon. Both Ana and Vanessa Hurtado thought the purpose of the meeting was to find a lawyer who would

represent Michael in a sexual molestation lawsuit against me. Neither of them knew about the then pending drug paraphernalia charges against Michael on which I was then still his counsel of record and which became the basis of a specious claim that I had engaged in legal malpractice. Surprisingly, no one in the Hurtado family discussed my relationship with him with Michael Hurtado himself at any time before they attended the meeting with Wager and Moxon and agreed to participate in the lawsuit being planned, by at least Moxon and Wager, for filing against me. Instead, Vanessa, Ana and Miguel Hurtado, without Michael Hurtado’s knowledge met with Wager and Moxon and agreed that the unconsulted adult son, Michael, would fire me as his lawyer, and then file the fabricated Hurtado v. Berry legal malpractice and sexual battery lawsuit against me. After the meeting, the elder Mr. Hurtado told Michael that Wager would now be replacing me and representing Michael in the criminal matter. Interestingly, at this time, Wager was about to be honored by the Los Angeles County Criminal Courts Bar Association for his "… significant contributions to the criminal justice system."

The Hurtados went along with whatever the lawyers, Wager and Moxon, and Scientology’s investigator Ingram told them to do. The Hurtados even went so far as to allow Ingram to tap their phone to entrap me. I had similarly found Abelson and Scientology illegally tapped into my telephone line on December 11, 1996. The FBI did nothing on that occasion either. Illegal wiretapping is par for the course for the Church of Scientology: "The Scientology Guardian’s Office Group [now renamed

"OSA"] illegally wiretapped several federal agencies, including the Internal Revenue Service ("IRS"), a perennial Scientology foe."

In fact, Michael Hurtado did not agree with Wager and Moxon to sue me because of what was allegedly done to him. Instead, Michael Hurtado testified he had (only) sued for money (as opposed to something I had done to him) and because of the contents of the perjured First Cipriano Declaration, which Moxon showed him and discussed with him. Accordingly, Moxon was using perjury he had been instrumental in extorting to procure yet more perjury to file a meritless lawsuit with which to intentionally obstruct justice in Berry v. Cipriano, Barton, Miscavige, Church of Scientology International, Ingram (Moxon, Abelson) and later to file two frivolous lawsuits, a federal bankruptcy claim and numerous (fraudulent) insurance demands starting at $750,000.

Wager did not meet with Michael Hurtado until January 22, 1999, after Wager had met with Abelson, Ingram, Moxon and the Hurtado family. Michael Hurtado has testified that he was told by Ingram that Moxon was "an attorney watching Berry for a long time because Berry is a bad person." Moxon had "been trying bury the guy [Berry] for his wrongdoings [against the Church?] for a long time".

Wager and Hurtado did not sign a retainer agreement until January 27, 1999. Wager immediately filed a pack of perjury upon the Los Angeles (Santa Monica) County Courthouse files. Amazingly, Wager even had the guile and chutzpah to represent to Presiding Judge Haber that, " . . . it is obvious from the declaration of Michael Hurtado and Donald R. Wager that the [legal] representation by Mr. Berry was unlawfully

procured." Motion To Set Aside Defendant’s Plea of No Contest And To Reinstate Plea of Not Guilty, etc., dated February 9, 1999, p.4: 1-3. People v. Hurtado, LAMC Case No. 8SM04976. At the same time, the Paul, Hastings law firm took the Hurtado statements and, through Barbara Reeves, tried to take Hurtado’s deposition in the still pending Berry v. Cipriano-Barton-Miscavige-CSI-Ingram (Moxon, Abelson) case for the obvious purpose of using Hurtado’s perjury that he had personally witnessed me engage in acts of pedophilia with several teenagers simultaneously and that he was a "virgin" with men before meeting me. I had provided rebuttal material to Barbara Reeves but she was adamant that Hurtado was relevant, honest, credible and very convincing. However, before the Paul, Hastings firm could actually proceed with the Hurtado deposition, I was forced to dismiss the Berry v. Cipriano cases in the over-whelming circumstances described above.

On April 5, 1999, Moxon & Kobrin filed a Los Angeles County Superior Court lawsuit, Hurtado v. Berry, asserting causes of action for legal malpractice and sexual battery and seeking damages in excess of my available insurance coverage. An hour after filing Hurtado v. Berry, Moxon himself personally served me inside U.S. District Court Judge Snyder’s courtroom. He did so as I took to my feet to unsuccessfully argue against his Rule 11 and Section 1927 sanctions motion in the Pattinson I case. Moxon’s Rule 11

and Section 1927 sanctions motion successfully claimed sanctions against me for having alleged that Moxon had been engaged in criminal activity on behalf of Scientology. Judge Snyder held, before even permitting any discovery by Pattinson, that the allegation against Moxon was frivolous, without any merit and asserted in bad faith. Subsequently, Wager substituted into the Hurtado v. Berry case as one of Hurtado’s counsel of record.

After Moxon & Kobrin filed the Hurtado v. Berry State Court case, then LA County Criminal Courts Bar Association President Wager went to the West Hollywood

station of the Los Angeles Sheriff's Department with Abelson and Moxon’s "chief investigator," Ingram. For a period of weeks, they unsuccessfully pressured the Sheriff's Department (and an Los Angeles Deputy District Attorney) to criminally prosecute me on the basis of the Hurtado perjury that they had suborned. Then, they promptly, but unsuccessfully, made a (fraudulent) $750,000 legal malpractice insurance policy demand upon my insurance carrier. This was followed by successively lower demands culminating in a $15,000 demand on November 28, 2000. By this time, Thomas S. Byrnes, Esq., had replaced Wager as co-counsel to Moxon, Kobrin and Paquette in the Hurtado v. Berry state court case.

Although then Los Angeles County Courts Criminal Bar Association President Wager had never met or represented Anthony Apodaca, on April 13, 1999, Wager visited this transvestite drug addicted streetwalker in Los Angeles County jail and left between $100 and $300 for him. Moxon reimbursed Wager. Apodaca was not a witness to

anything relating to the Hurtado drug paraphernalia case. In fact, as Apodaca later testified, that on April 13, 1999, " . . .there was a real question in [Apodaca’s] mind as to who Berry was." However, on April 22, 1999, Ingram, Moxon and Wager met with Apodaca at which time he was videotaped. Apodaca may also have been given money on April 22, 1999. Using a photograph of me in an American Lawyer magazine article on Scientology’s-Moxon’s destruction and takeover of the Cult Awareness Network, Apodaca was now able to identify me as a man he had been with four to five years earlier. In the videotape, Apodaca falsely stated that while he was underage he had engaged in sadomasochistic activities with me. On April 26, 1999, Moxon noticed Apodaca's deposition in the Hurtado v. Berry State Court action. On cross-examination by my attorney, Edith Matthai, currently President of the Association of Southern California Defense Counsel, Apodaca testified that he was "high" on drugs at the time of the videotaping, that he had no recollection of it and that he could not even recognize me. Apodaca said he was pressured (by Moxon and Ingram) into giving his videotaped false statement. According to Apodaca, a lawyer (Wager) came to L.A. County Jail and gave him $200. He was given the money, McDonald’s food certificates and clothing to testify against me. He refused. According to Apodaca, "All this stuff about this plaintiff [Wager] trying to bribe me to testifying -- okay? -- I don’t go for that."

At the same time Wager was visiting Apodaca, an investigation by the California State Bar was being commenced against me, arising out of then Los Angeles County Criminal Courts Bar Association President Wager’s and Hurtado’s allegations and perjury to Judge Haber in the Santa Monica Court. Commencing with their jointly signed correspondence to the California Sate Bar dated July 12, 1999, and for the next 18 months, Wager and Gerner wrote numerous other jointly signed letters urging my immediate summary disbarment on the basis of the Hurtado perjury, and the Cipriano, Pattinson, and other charges the State Bar (under its brand new Chief Trial Counsel) filed earlier this year. Wager and Gerner even met with former California Supreme Court Justice Liu (then supervising the Office of Chief Trial Counsel) and unsuccessfully urged my immediate discipline on the basis of the Hurtado, Cipriano and

other allegations against me. At the very least, former Bar Association President Wager had direct personal knowledge that he was willfully making a very serious and false State Bar complaint using perjury he had participated in suborning from Hurtado, whose legal representation he had solicited in the most despicable and unethical of circumstances. Most lawyers would be disbarred for one single such act of solicitation!

Moxon & Kobrin, through Paquette, met with, prepared for deposition, and then deposed, my former partner and counsel, J. Stephen Lewis, in Hurtado v. Berry.

J. Stephen Lewis and Christian Scali had represented me in the Berry cases and had also represented Pattinson and Henson. Indeed, J. Stephen Lewis was representing me in deposition when Rosen and Moxon obtained the information about Hurtado as well as his address. Furthermore, he was my law partner when Hurtado entered his no-contest plea in connection with his negotiated participation in a drug diversion program. Thus,

J. Stephen Lewis had potential joint and several partnership liability in connection with

Hurtado v. Berry and could have been a named defendant or sued for contribution. Curiously, neither the former firm nor any of its former partners were named! You may also recall the earlier reference to Cipriano’s testimony that Moxon, Lewis and Scali were in direct communication about the subsequent termination of the Berry, Lewis & Scali

partnership upon four days’ effective notice.

Ignoring the obvious breaches of fiduciary duty owed to a former client and partner, particularly in a "substantially related" matter, J. Stephen Lewis (now a West Hollywood City Council Hearing Officer) testified to Ava Paquette, Esq., that it was legal malpractice for me to recommend that Hurtado plead to a drug diversion and rehabilitation program instead of making a motion to suppress statements and evidence obtained by three arresting police officers. Such a strategy, if unsuccessful, would have excluded Hurtado from potential participation in the drug diversion program. However, upon cross-examination by Edith Matthai, Esq., J. Stephen Lewis conceded that in similar circumstances he had made the same recommendations to a client named "John". Ironically, "John" was later deposed in Hurtado v. Berry. "John" impeached part of Hurtado’s verified complaint. Contrary to the verified complaint that Hurtado was a "virgin" with regard to men, "John" testified that he and Hurtado, working as male

prostitutes, had engaged in a homosexual three-way liaison before Hurtado even knew me. Then, after their interaction with their mutual "client", they had spent the night having sex with one another. Two employees of a well-known establishment specializing in male "hustlers" also testified that Hurtado "worked" out of their bar-restaurant. However, none of this evidence caused Wager, Byrnes, and/or Moxon & Kobrin to file an amended verified complaint in Hurtado v. Berry. At the same time Wager, Moxon, Abelson and Ingram were suborning perjury and witness tampering with Cipriano, Hurtado and Apodaca, Moxon was commencing proceedings that would effectively terminate my career as an attorney.

In May 1999, then Los Angeles Police Commission President Gerald Chaleff of Orrick, Herrington & Sutcliffe; Samuel D. Rosen and Michael Turrill of Paul, Hastings, Janofsky & Walker; Gary Soter of Wasserman, Comden & Casselman; and David Chodos of Simke Chodos filed a Petition to Find [me] a Vexatious Litigant upon the

grounds of Judge Snyder’s Rule 11 and Section 1927 order in the Pattinson I case, and the dismissals of the Berry v. Cipriano, Barton, Miscavige, Church of Scientology International, Ingram (Moxon, Abelson) cases. The Scientology vexatious litigant petition was filed before Scientology’s "friend," Judge Williams, in the previously

dismissed Berry v. Cipriano case. (I would not discover the above matters regarding the Hurtado and Apodaca solicitations, perjuries and obstructions of justice for another 18 months!) However, after the Vexatious Litigant Petition was filed and opposed, but before the hearing on August 20, 1999, then former Moxon client Cipriano contacted me. He confessed to the fabrication and defamation of the First Cipriano Declaration as well as to a mountain of associated attorney felony crime, fraud and obstruction. Incriminating documents bearing Moxon’s own signature and handwriting corroborated much of it. There were cancelled checks, original signatures, lease agreements, handwritten notes and even his computer's hard drive. Since then, they have all been in a bank safe deposit vault which I jointly control with another person (not Cipriano). See and http:/ and (includes video/audio) and and and (see ScienoSuits/CivilSuits by Scientology, click on "Double Crossed" by New Times LA) and and (type "graham berry" into search site box) and (type "graham berry" into Pico search) and (type "graham berry" into search oc) and (type "graham berry" into search/by date).



For the sake of clarity I must now briefly direct your attention from the vexatious litigant petition and bring you forward one year to August 2000. Cipriano’s deposition finally had been court ordered in Hurtado v. Berry. Moxon repeatedly attempted to stop the Cipriano deposition in Hurtado by threatening a protective order suspending the deposition on June 12, 2000, and attempting to again suspend the deposition on August 7, 2000. Then Hurtado and his Moxon & Kobrin attorneys repeatedly attempted to stop the deposition of their former client and "seal" Cipriano’s testimony regarding their criminal activity against me. In his deposition, Cipriano recanted all of the damaging statements contained in the First Cipriano Declaration. Cipriano testified he wanted "the truth to come out".

Cipriano also testified that his former lawyer, Moxon, provided him (and his soon-to-be former girlfriend) with a variety of free legal and other services as well as financial benefits. Moxon also paid Wasserman, Comden & Casselman to represent Cipriano, as co-counsel, in Berry v. Cipriano, Barton, Miscavige, Church of Scientology International, Ingram (Moxon & Abelson) in exchange for Cipriano’s "cooperation" in litigation against me. Moxon and Scientology’s paying Cipriano for his continuing perjury in the amount of $750,000 was "not a problem" according to Cipriano’s August 1999 and 2000, testimony. In fact, Cipriano’s testimony and damning

documentary evidence, proved that Moxon’s corroborated felony criminal conduct, and that of others including Wager, and directed exclusively at me, included violations of 18 U.S.C. §§ 1621, 1603, 1503, 1512, 371 2(a), 2(b) (perjury, obstruction

of justice, witness and evidence tampering, conspiracy, aiding and abetting and the use of an intermediary).

Specifically, Moxon's felonies and fraudulent acts, and those of other lawyers, included: (1) The May 5, 1994, presentation of the First Cipriano Declaration with numerous fabrications and exaggerated statements regarding my alleged sexual history to Robert Cipriano, which Cipriano was forced to sign under duress and the coercive threats of attorney Moxon’s agent Ingram; (2) The use of less-than-candid investigators to obtain information and the subsequent use of that information obtained through uncontroverted

evidence of intimidation and coercion; (3) The deposition preparation of Cipriano by Moxon on June 29,1998, during which Moxon (and later Samuel D. Rosen, Esq.) instructed Cipriano to lie about the ages of my perjuriously alleged sexual relationships, violated of Rule 3-210 of the Rules of Professional Conduct and Cal. C.C.P. §1209(8) [18 U.S.C. §§371, 1512, 2(B), 1503, 1621 and 1623 (conspiracy, obstruction of justice, witness and evidence tampering, perjury); (4) The further testimonial preparation of

Cipriano by Moxon comprised of instructions to lie on June 30, 1998, also in violation of Rule 3-210 of the Rules of Professional Conduct and Cal. C.C.P. §1209(8); (5) Violating the oath taken by all attorneys at law under Business and Professions Code §6067, in

which attorneys promise, "… faithfully to discharge the duties of any attorney at law to

the best of [their] knowledge and ability," violating C.C.P. §1209(3); (6) The unlawful business dealings between attorney and client prohibited by Rule 5-200 of the Rules of Professional Conduct and Cal. C.C.P. §1209 (8), undertaken in order to maintain Cipriano's livelihood in exchange for perjurious testimony against me; (7) the promise of up to three quarters of a million dollar ($750,000) donation to the Moxon/Scientology-founded and funded charity, Day of the Child (incorporated in Nevada and

trading unregistered in California as part of Moxon’s related criminal conduct);

(8) The provision of a $2,500 loan to Cipriano; (9) The provision for Cipriano's room and board at Joanne Wheaton's Franklin House; (10) The rental of a Palm Springs

condominium, a five-bedroom Palm Springs home complete with swimming pool and

monthly provisions for Cipriano's board, living and business expenses by the law firm of Moxon & Kobrin; (11) The provision by Moxon, at no cost to Cipriano, of a $20,000 lawyer in New Jersey to clear and expunge Cipriano's criminal record, and to pay off the restitution order, so that it could not be used to impeach him in the Berry cases; (12) The subsequent provision to Cipriano of the balance of those monies in the amount of $1,500; (13) Moxon's provision of free legal services to incorporate Cipriano's-Moxon’s-Scientology’s "Day of the Child" Charity in Nevada (to serve as vehicle for the commission of some of the applicable criminal, civil and unethical conduct herein); (14) Moxon's provision of a new Saturn automobile for Cipriano on October 6, 1998; and

(15) Moxon's provision of a Packard-Bell computer for Cipriano at a cost of $1,000. Interestingly, Moxon seized and "recovered" the new Saturn automobile as soon as he learned that Cipriano had finally told the truth about me.

In fact, one year later at his August 2000, deposition in Hurtado v. Berry, Cipriano testified under his former counsel Moxon’s withering cross-examination, "You were providing the funds to run a company [the tax-exempt IRS § 501 (c) (3) Day of the Child] so I would testify on your side." The State of California Department of Justice initially expressed interest in pursuing the use of this charity in this manner. (Letter Supervising Deputy Attorney General James M. Cordi to Edith Matthai, Esq., dated May 1, 2000.) However, it quickly backtracked although it has pursued similar matters. As also indicated elsewhere in this letter, the real reasons for State Attorney General Lockyer’s reversal of interest maybe more disturbing and insidious. Supra, page 107. A photograph of California Attorney General Bill Lockyer with Church of Scientology W.I.S.E. business officials and members can be viewed at

In December 1999, Moxon had visited Cipriano uninvited/unannounced and negotiated an $800 payment to sign a unethical settlement, a release and waiver from any potential malpractice, breach of fiduciary duty or other wrong, and a declaration, which Cipriano now contends is inaccurate and was signed in the shadow of even more

intimidation. In August 2000, in Hurtado v. Berry, the following testimony was elicited

from Cipriano, by his former lawyer Moxon on cross-examination:

"Q: Did you make any representation to anyone when -- that you signed this declaration, it was inaccurate?

A: That it was inaccurate . . . let me ask a question. If it was accurate, then why was I being paid $800.00?

Q: Would you answer my question?

A: It was understood. You don’t pay people to write affidavits unless you’re doing something . . .. I didn’t have intent one-way or the other. You presented two documents to me, a settlement agreement and an affidavit, offered me $500 out of nowhere. I did not solicit it. That number settled at $800. I signed in return for the $800."

Again, under Moxon's withering and abusive cross-examination, Cipriano testified:

"Well, you kept providing money. And based on the fact that our whole relationship started with your agent, Mr. Ingram, threatening and intimidating me to give the false declaration in 1994. It was just a continuation of all that, Sir."

Under further cross-examination, Cipriano told Moxon:

"That is what you wanted to hear. That is what you coached me to do. That is what I was threatened and intimidated to do. And that's what I was paid to do."

Cipriano described the procedure Moxon used in preparing declarations in Berry v. Cipriano:

"Every declaration that you prepared for me to sign was what you wanted to hear, and what you wanted written, and what you wanted to file in court, and what you wanted for everything. . .. I signed what you prepared with the commencement of the threat and intimidation and the payments thereafter. Almost every time you gave me something to sign, you look at the same date or day after and there is a payment of some sort."

Cipriano’s claims that he was paid by Moxon, and that he received multiple items and services of value from Moxon, are very well documented. However, put simply, why else would Cipriano make false statements about me? Cipriano was paid for perjury.

Cipriano also testified that in December 1998, Moxon and Ingram told him that they had located a person named Hurtado who purportedly, "… had exchanged sexual favors for legal services by Mr. Berry." Ingram told Cipriano that the information regarding Hurtado would be used to file a State Bar complaint against me and was to be include in leaflets to be left on cars around my neighborhood. In fact, a false State Bar complaint was initiated against me. It was dismissed on January 3, 2001. It originated as part of that June 1999, false Hurtado State Bar Complaint pursued by Wager and Gerner as lawyers for Scientology. Leaflets have, in fact, been left in my neighborhood falsely identifying me as a child molester. This is standard Scientology "technology" for

handling church "enemies". See para.169, 181, 188, 194, 202, 206, etc.


One year earlier, I had submitted Cipriano’s similar Declaration testimony to Judge Williams, accompanied by fifty corroborating exhibits. The August 9, 1999, Cipriano Declaration detailed a pattern and practice of criminal conduct that includes, but is not limited to, harassment, coercion, bribery, intimidation, solicitation, witness tampering, subornation of perjury, perjury, mail fraud, wire fraud, stalking and other criminal violations in connection with the Berry v. Cipriano, Barton, Miscavige, Church of Scientology International, Ingram (Moxon & Abelson) and Hurtado cases. Judge Williams, at my request, confirmed on the record that he had read the recanting Cipriano testimony describing all of the felonies and attaching the fifty corroborating documents. Judge Williams then ruled that it was all "irrelevant" to the Church of Scientology International Petition to Find [me] A Vexatious Litigant for having filed and maintained the consolidated Berry v. Cipriano cases and the Pattinson I case. Judge Williams even refused to allow Cipriano to address the court, despite Cipriano having filed a written opposition to the Petition of his own former attorneys in the Berry v. Cipriano litigation. Moxon had, and still does, refuse to return Cipriano’s files. Cipriano filed a motion requesting Judge Williams to order their immediate return. The Judge refused to do so. Judge Williams also refused to hear and consider a joint motion by both Cipriano and me for a Cal. CCP§ 877.6 "good faith" settlement determination. We had signed and filed the motion papers. See, both documents:

Earlier, a hearing transcript alteration had emerged. Six months into the Berry v. Cipriano case, Judge Williams suddenly remembered that his fiancée worked as an independent contractor for a Scientology-related company (Bridge Publications, Inc.), which was not one of the involved parties or entities. No objection was made. However, just before the Church of Scientology International vexatious litigant petition was heard and determined against me, Moxon filed a portion of an earlier hearing transcript. It

contained a surprising statement that the Scientology corporation for which presiding

Judge Williams’ fiancée worked was not Bridge Publications, but the Church of Scientology International ("CSI") itself! CSI was the actual moving party on the pending vexatious litigant petition. CSI had retained Police Commission Chairman Chaleff and Orrick, Herrington & Sutcliffe to file the vexatious litigant petition against me. CSI also regularly retained the other moving counsel Paul, Hastings, Janofsky & Walker; Wasserman, Comden & Casselman; and Simke Chodos. CSI was Moxon & Kobrin’s actual employer and client. CSI had been one of the defendants in the Berry v. Cipriano consolidated cases. Accordingly, and for a number of reasons, the grounds for disqualification had never been timely, properly or even accurately disclosed by Judge Williams, and therefore had never been waived. In fact, Judge William’s particular conflict of interest was probably non-waivable as a matter of law. Even if Judge William’s conflict of interest had been fully disclosed and properly waived in the consolidated Berry v. Cipriano, Barton, Miscavige, Church of Scientology International, Ingram (Moxon & Abelson) cases, the vexatious litigant proceeding was a new action reviving the Cal. C.C.P.§ 170.6 right of peremptory challenge for bias to the judge.

Moreover, the employment of the presiding Judge Williams’ fiancée by the moving party CSI, CSI’s employment of all of the moving counsel, was a non-waivable ground for disqualification of the judge. On August 19, 1999, and pursuant to Cal. CCP §§ 170.1 and 170.3, Cipriano and I filed our Verified Statements of Disqualification. The very next day,

Judge Williams struck the Verified Statement pursuant to Cal. CCP § 170.4(b), but also improperly and concurrently filed his Verified Answer to the Statement of Disqualification

pursuant to Cal. CCP § 170.3(c)(3). Judge Williams then granted CSI’s pending vexatious litigant petition. In so doing, Judge Williams ignored the express applicable mandatory statutory procedures for referring such disqualification motions to a randomly selected judge for impartial decision. Of course, had Judge Williams followed the mandated statutory procedure, lead Scientology lawyer Samuel Rosen of Paul, Hastings, Janofsky & Walker would have flown back to his New York office empty handed. In concluding the vexatious litigant proceeding, Judge Williams stated:

"I happen to be re-elected and I’m in my final term. I can retire in this term, but more importantly, as a judge I was brought up [sic] you could be run out of office doing the right thing, and you can stay in office doing the wrong thing. So I am, as god is my witness, I am like a federal court in a state court." emphasis added

Former Scientology Deputy Leader Jesse Prince has provided a detailed explanation of how the Church of Scientology tampers with judges, blackmails and corrupts judges and avoids detection in the process. "Scientology’s foolproof method of judge tampering".!!!FactNet!!!/Scientology/judge_tampering

This is not news to those who are familiar with the Church’s criminal modus operandi. The American Lawyer has published a landmark article "Scientology’s War Against Judges." There are numerous more recent examples, provided by judges themselves.

On the other hand, many judges here and abroad have resisted Scientology's intimidation. A long list of their damning comments and opinions can be reviewed at


The Court of Appeals summarily rejected my Petition for Mandate in connection with Judge Williams’ refusal to recuse himself and his refusal to follow the mandatory statutory procedure upon the filing of a motion for disqualification. My subsequent appeal to the Second District Court of Appeals was similarly dismissed. There appears to be no effective right of appeal from a vexatious litigant ruling of a single rogue judge. At the time, I was unable to proceed further. I did not even have the funds (approximately $4,000) to pay for the photocopying of the writ of mandate and supporting exhibits I had previously and unsuccessfully filed.

Moxon, Kobrin & Paquette then proceeded against me in U.S. Bankruptcy Court. Moxon appeared there on behalf of himself, Church of Scientology International, Barton, Revelliere (who had no claim at all) and Chait. He filed the adversary proceedings Moxon v. Berry and Barton v. Berry and obtained a ruling that Judge Snyder’s Pattinson I sanctions to Church of Scientology International and him were non-dischargeable in bankruptcy despite the alleged fraud upon the courts. I moved to vacate the Moxon $28,000 sanctions order against me in Pattinson I under F. R. Civ. P. Rule 60 (b) (1), (3) and (6). Very little attention was given to the Rule 60 (b)(1) argument in my moving papers. The majority of the motion and all of the evidence was addressed to the "fraud upon the court" arguments in connection with Rule 60 (b)(3) and (6). Surprisingly, Judge Snyder even quoted language from Judge Williams’ vexatious litigant ruling. She denied my motion as being improper under Rule 60 (b)(1). Judge Snyder totally ignored the majority of my motion and evidence under Rule 60 (b)(3) and (6).

By now it was late in the summer of 1999, and Wager had just been "honored" for his "…[these] significant contributions to the criminal justice system". In accordance with the Church of Scientology’s written "Fair Game" Policies and Practices, Wager, Chaleff, Rosen, Chodos, Soter and Moxon had, with regard to me, effectively "caused [my] successful demise." I was devastated, destroyed, obviously having an emotional breakdown and under treatment for severe depression. However, the Scientology litigation blitzkrieg continued. I had not been "utterly destroyed" yet in accordance with the Church’s written "Fair Game" Policies and Practices. I had ghost written a complaint for a pro per litigant in Jeavons v. CSI. In this case, Scientology had retaliated against the pilot of a helicopter media related fly-over of its California desert base, described as an "armed and dangerous gulag" by former Scientologists. See Andre Tabayoyon Declaration The media fly-over was part of a German ARD documentary on "The Dark Side of Scientology" which included many photos of numerous dead bodies being removed from Church of Scientology facilities in Clearwater, Florida. Tragically, similar images would be seen again in relation to the death of Scientologist Lisa McPherson who, just prior to her death, had been "trying to leave".

In the ARD-Jeavons' fly-over of the Scientology desert base and International Headquarters at Hemet, California, CSI/OSA had made material misrepresentations to the FAA in support of a complaint seeking suspension of the helicopter pilot’s license. I was too busy in the Berry and Pattinson cases to represent Jeavons, but I ghost wrote his complaint, sheparded it through the filing process and had it served. I had indicated I might later enter an appearance in the case. Moxon filed a Cal. CCP § 425.16 "SLAPP" motion. He successfully argued that the SLAPP statute and the Cal. Civ.Code § 47(b) litigation privilege protected CSI’s FAA complaint about Jeavons, no matter how false the evidence or how foul CSI’s motives might have been. Because I had drafted the complaint and might appear as counsel, Moxon argued that both Jeavons and I should be subject to the automatic cost shifting provision of the statute. The judge said it was a very

difficult call, but agreed on balance. A German media description of the incidents leading to the Jeavons matter can be read at Also see: and

Regrettably, my life had now fallen apart under the sustained Scientology bombardment of the legal system in the execution of its "Fair Game" Policies and Practices. My performance in other cases had become predictably abysmal. There was a motion to sanction me for a discovery default in a case with no connection whatsoever with Scientology or any of its counsel (Anders v. Northwestern Life). Despite that,

Moxon filed a declaration in support of the sanctions motion. Moxon detailed and urged reliance upon the orders issued by Judges Snyder, Williams and Minning. In another unrelated case (Kaleel v. Nardi), I did not have the personal resources to oppose a motion that, as special counsel to the Kaleel bankruptcy estate, I had an alleged (and nebulous) conflict of interest with opposing litigation parties who I had never represented. The underlying business litigation case (Nardi v. Kaleel) had been tried a year before. Once again, neither Scientology nor any of its counsel had any conceivable connection with the Kaleel case. Kaleel was a six-week jury trial in Los Angeles Superior Court. Inexplicably, Moxon was often in the courtroom, positioned so I could see him smirking at me. There seemed never a moment when a Scientology representative was not present

in the courtroom and hallway. Very quickly, the Scientology representatives befriended opposing counsel, Bradley Brook, Esq. Subsequently, the trial judge questioned the jury as to whether any jury tampering or other improper Scientology contact was occurring. Even the trial judge expressed his surprise at the jury’s decision, totally and illogically, against Kaleel. In what is not likely a mere coincidence, Scientologist financier and Earthlink founder Reed Slatkin recently came under federal investigation for running a $500 million "ponzi" scheme. The largest ever known "ponzi" and international investment fraud scheme in U.S. history. It is of particular interest, that representing Scientologist Slatkin is attorney Bradley Brook, who met Scientology in-house attorney Moxon during the Kaleel trial. Additionally, and not likely coincidently, Bradley Brook has been sharing the same office suite as State Bar complainant Gerner and former Los Angeles County Criminal Bar Association President Wager.

See: and

Overwhelmed by the Moxon, Abelson, Wager, Rosen, Reeves, Ingram and Scientology attack from every point of the compass, and nearly immobilized by depression as well as emotionally and financially devastated by the perceived failures and corruption of the legal system, I withdrew from active legal practice. However, Wager, Gerner, Moxon, Kobrin and Paquette did not withdraw from active "Fair Game" harassment of me. Moxon, Kobrin and Paquette pursued me relentlessly in bankruptcy

court, seeking non-dischargeability of the sanctions orders in the Berry, Pattinson and Jeavons cases. They filed frequent motions, conducted regular deposition/examinations at an expense which obviously exceeding their claims by many multiples despite its being a no-asset bankruptcy. They even pro hac viced $490 per hour Paul, Hastings’s New York office copyright lawyer Rosen into the Moxon v. Berry adversary case in Los Angeles Bankruptcy Court. The Bankruptcy Trustee had already reported that it was a "no asset" matter. Concurrently, Moxon, Kobrin and Paquette actively prevented me from selling my real estate to pay their sanctions and from collecting upon a past due debt which would have also satisfied the Barton sanctions order and real estate lien. Had they not done so, I could have paid money that I owe the IRS and California Franchise Tax Board,

but cannot pay because of the events described in this letter.

At the same time, that I withdrew from actual "active" legal practice, Gerner and then Los Angeles County Criminal County Bar Association President Wager were regularly telephoning the California State Bar and were repeatedly signing joint letters demanding that I be summarily suspended and disbarred in connection with their complaints that it was I who had committed wrongdoing in my representation of Hurtado, and by filing the Berry, Pattinson and Jeavon’s cases, and by failing to pay the Moxon, Barton, Jeavons and Kaleel sanctions orders. Wager cannot have missed the irony that at the same time as he was being honored for his "…significant contributions to the criminal justice system" he was committing some of the most serious hate crimes and ethical breaches as part of a seven-year-long interstate and international R.I.C.O. conspiracy to

corrupt and obstruct justice and to deny constitutional rights, civil rights and human rights to me, then a fellow Los Angeles lawyer. There clearly was a reason that then Los Angeles County Criminal Courts Bar Association President Wager had co-signed each of the Gerner letters urging immediate California State Bar disciplinary action against me, at the behest of their joint client the Church of Scientology International.

After an eighteen-month investigation, the State Bar dismissed the Hurtado portion of the joint Wager and Gerner complaint on January 3, 2001. On January 19, 2001, Wager testified in Hurtado v. Berry, before a retired superior court judge, that he had unlawfully solicited the representation of Hurtado (away from me) and had

engaged in witness tampering in connection with both Hurtado and Apodaca. Consequently, Retired Los Angeles Superior Court Judge Stephen Lachs, acting as discovery referee in Hurtado v. Berry, ruled that there was no attorney-client privilege protection as to any of the communications between then Los Angeles County Criminal Bar Association President Wager, Hurtado, Moxon, Kobrin, Paquette, Abelson, Byrnes and the Church of Scientology. Cipriano had already waived his attorney-client privilege. Judge Lachs ruled that, pursuant to Cal. Evidence Code § 956, the services of the lawyers (expressly including Wager, Moxon, Abelson and Byrnes) had been sought or obtained (by Scientology and Hurtado) to enable the commission of a crime or fraud. The judge also noted the deceptive misrepresentations, by counsel, that

Scientology had nothing to do with the Hurtado v. Berry cases. Amazingly, Wager (despite his confession under oath) and "ethics specialist" Gerner continued to jointly pressure the State Bar to discipline me. The California State Bar quickly obliged former Los Angeles County Criminal Courts Bar Association President Wager. On January 31, 2001, it initiated the recently settled proceedings, dropping only the Hurtado portion from the demands of the voluminous joint Wager and Gerner 18 months of correspondence and their numerous telephone calls. Further (fraudulent) insurance proceeds settlement demands by Byrnes, Moxon and Abelson (and obviously based upon the felonies and perjury they and Wager and Ingram had engaged in with Hurtado) were rejected by my legal malpractice insurance carrier and my counsel, Edith Matthai, Esq. On February 6, 2001, Moxon and Thomas S. Byrnes, Esq., (another Hurtado lawyer) filed a voluntary dismissal of the verified complaint in Hurtado v. Berry in State Court. Amazingly, Moxon, Kobrin and Paquette maintained the perjured Hurtado v. Berry case upon the federal court record. Six months later, the federal court ordered Moxon, Kobrin and Paquette to file a motion to dismiss there too. At my request, it was ordered dismissed "with prejudice" on July 10, 2001. Applicable Federal Rule of Procedure 41(a) expressly deems the Scientology dismissal of Hurtado in Federal Bankruptcy Court "an adjudication upon the merits" in my favor.

Wager’s and Gerner’s two years of constant joint pressure, commencing with the obviously baseless Hurtado v. Berry complaint, premised upon Wager’s own unlawful

solicitation and subornation of perjury, at the same time as he was President of Los Angeles County Criminal Courts Bar Association, was the genesis of the stipulated California State Bar settlement. In that regard, Gerner represented to the California State Bar Court that he was retained by the Church of Scientology to jointly initiate, pursue and

monitor (with Wager) the recently settled State Bar proceedings. Incredibly, the California State Bar refuses, at least to date, to take any action against Abelson, Wager, Moxon, or any of the other Church of Scientology attorneys who participated in the litany of serious criminal, tortious and unethical conduct described above. This year alone, State Bar representatives (including the new Chief Trial Counsel’s own Special Assistant) have written on three different occasions to at least three different people stating that

there is insufficient evidence of any wrongdoing by any of the Moxon & Kobrin and

other Church of Scientology attorneys. Is the State Bar merely calling these people and enquiring whether they have engaged in any illegal and/or unethical conduct? On the contrary, the evidence is clear, convincing and beyond any reasonable doubt. There is the deposition testimony of at least ten different witnesses; many corroborating each other. There is the declaration testimony of another half dozen witnesses; again, some of it corroborated by other witnesses and there are over sixty different documents, many in Moxon’s handwriting or bearing his signature. In addition, the contents of the First Cipriano Declaration are still being distributed and published around the world.

On December 1, 2001, Rev. Lyn Farny of OSA told me that he thought (Cipriano’s extorted perjury) had been "a very good idea." Similarly, it is clear that for seven years Scientology and these lawyers have been engaged in a concerted R.I.C.O. enterprise to corrupt and obstruct justice in the civil and criminal courts and that these R.I.C.O. predicate acts were intentionally directed at me specifically. Concurrently, the Scientology R.I.C.O. enterprise, and many of these same lawyers were directing similar R.I.C.O. predicate acts against others who they perceived as "enemies" for impeding the Church of Scientology’s secret totalitarian, evil agenda.

Significantly, despite my alleged blatantly illegal conduct on both coasts; Paul, Hastings, Janofsky & Walker (Rosen, Reeves, et. al.), Williams & Connolly (Feffer), Abelson, Wager, Moxon, Kobrin, Paquette, Byrnes, Soter and Scientology-Abelson’s-

Moxon’s "investigator", Eugene Ingram, and a battery of other "investigators," have produced only three witnesses to my falsely alleged pedophilia: (1) Robert Cipriano, who has testified he was paid by Moxon to give false testimony; (2) Anthony Apodaca who testified he too was paid and pressured (by Wager) to give false testimony; and

(3) Michael Hurtado who was unlawfully solicited by Wager and Moxon, and signed a false verified complaint claiming $8 million in damages, based on perjured testimony, and who has received substantial, valuable legal and investigative services in his several criminal cases in connection with his perjured testimony and vexatious prosecution of the Hurtado v. Berry state court civil action which he dismissed on February 6, 2001, upon the eve of trial.

Hurtado has not fared well since allowing Ingram, Moxon and Wager to unlawfully solicit his legal representation away from me. Ingram, Abelson and the Moxon & Kobrin law firm had kept Hurtado under close supervision during the Hurtado v. Berry case(s). Despite that, Hurtado was arrested and then arrested again and again. Hurtado is now serving five years in Los Angeles County Jail for what might have been a murder. Hurtado (whose mother testified that he had brought a transvestite home to dinner insisting that the transvestite was actually a woman) began dating a young woman with a transvestite roommate. She quickly broke up with Hurtado. He retaliated. While the young lady was at work, Hurtado gained unlawful entry to her apartment. He took a large knife and bottle of liquor into her bedroom closet and awaited her return. Eventually the ex-girlfriend did return. She opened her closet door and there was Hurtado

passed out with an empty bottle of liquor and a butcher’s knife. She called the L.A.P.D. which responded, dragged the drunken and stupefied Hurtado out of the closet and off to L.A. County jail where he claimed to be gay, but failed what he testified is the L.A. County Jail's "gay test." He thus entered the general prison population where he remains.

However, Moxon, Kobrin, Paquette, Abelson and Wager were brazenly undeterred by Hurtado’s continuing criminal activity. Moxon & Kobrin’s "chief" investigator Ingram was dispatched to the scene of the latest Hurtado crime. Ingram did some "research" on the victim, Hurtado’s former girl friend. She had an old and resolved stolen check conviction. When she refused Ingram’s demand to withdraw her criminal

complaint against Hurtado, Ingram threatened her with disclosure of the stolen check conviction to her employer. Hurtado’s victim refused to be extorted by Ingram. However, Ingram made good on his threat. Hurtado’s nearly butchered victim was fired from her job. The prosecuting Los Angeles Deputy District Attorney and her investigator were enraged at such blatant obstruction of justice. Nevertheless, nothing has been done about Ingram’s rampant witness tampering, extortion and intimidation. Perhaps there is a reason?

A further word about Scientology's "chief" investigator Eugene Ingram is in order. In 1981, then L.A.P.D. Sergeant Eugene M. Ingram resigned from the police force because of an alleged medical disability. He claimed to have received a sniper’s bullet wound to the back of his shoulder while driving his car to the Police Academy. Earlier

the same day, he had learned that he was being investigated, and would be prosecuted, on 11 charges of serious misconduct involving organized prostitution activities, supplying guns and selling confidential information to narcotics dealers (as to impending arrests and the like). Ingram had false Florida license plates on his car at the time. The vehicle was registered to a non-existent "Robert Miller." Some of the prostitutes were illegal aliens threatened with deportation unless they went along with Gene Ingram’s prostitution scheme. On January 29, 1980, the L.A.P.D. raided the Ingram house of prostitution. The only furniture was beds and nightstands on which were condoms and Vaseline. Then Deputy District Attorney, Gil Garcetti, had headed the L.A.P.D. Special Investigations Division probe and decision to prosecute. Deputy D.A. Jay Lipman had prepared a tight case against Ingram. Amazingly, the prosecution of Ingram was dropped and dismissed for "insufficient evidence." However, two of Ingram’s co-conspirators, "Rocky" Ward and Grunwald pled guilty to pimping and pandering. It appears that the reason that Ingram was the only defendant not to be prosecuted was Scientology-style blackmail, perjury and intimidation. Indeed, it is speculated that Ingram was concurrently employed by both the L.A.P.D. and the Church of Scientology. Elliot Abelson, Esq., and Donald Wager, Esq., were also Deputy District attorneys around the same time. Elliot Abelson, Esq., then became counsel to the Gambino Mafia family before becoming in-house counsel to the Church of Scientology sharing the same CSI/OSA offices as Drescher, Moxon & Kobrin. Ingram became Kendrick Moxon’s "chief" investigator for the Church of Scientology and its other lawyers. Ultimately, Deputy D.A. Garcetti himself became the Los Angeles District Attorney. During his watch, the L.A.P.D. entered into a continuing consent supervisory decree with the Civil Rights Division of the U.S. Department of Justice. Significantly, the L.A.P.D. and the Los Angeles Sheriff’s Department have both failed to take immediate action in connection with these clear and very serious crimes, acts of "psycho-terrorism" and blatant civil rights violations.

In 1985, Scientology’s "investigator" Ingram prepared a letter for an L.A.P.D. officer to sign. It invalidly authorized Ingram to engage in electronic eavesdropping of former Scientologist Gerry Armstrong. The incident was reported in the media. On April 23, 1985, then L.A.P.D. Police Chief, Daryl F. Gates issued a press statement:

"The Los Angeles Police Department has not co-operated with Eugene Ingram. It will be a cold day in hell when we do…Internal Affairs Division is now investigating the entire incident."

However, nothing further happened. In August 1999, I submitted the August 9, 1999, Cipriano Declaration and its fifty damning exhibits to the personal office of then Los Angeles District Attorney, Gil Garcetti. As noted above, D.A. Garcetti, while a Deputy D.A. had headed the 1981 investigation and aborted prosecution of Ingram. An

acquaintance of mine, then one of the District Attorney’s chief assistants, informed me that the "District Attorney will not do anything for political reasons… One day I may be able to tell you why." Supra, page 76

Like Ingram, Moxon & Kobrin, Abelson has also spent years "investigating" me. By way of example, on September 13, 2000, Abelson wrote to an attorney friend of mine in New Zealand:

"I am writing to you in connection with an investigation I am conducting into Graham E. Berry. The purpose of my investigation is to uncover unethical or illegal conduct committed by Mr. Berry. I understand you may be of help in my investigation. Specifically, I would appreciate any information you can provide concerning Mr. Berry’s motives for embarking upon a course of action which would seem, to any objective

observer, to be contrary to his own best interests, and a blatant attack on an international religion."

emphasis added.

Abelson sent a copy of his letter and enclosures to many other people, numerous Bar Associations and my 77-year-old parents for whom the publication of the First Cipriano Declaration and the subsequent saga have been terrifying events. Indeed, consistent with the objectives of the Scientology’s "Fair Game" Policies and Practices, I have now been "utterly destroyed." I have lost my career, condominium, car and retirement prospects. I now live on general public relief. Tellingly, in successfully urging Judge Snyder not to consider my Rule 60 (b) (3) and (6) motion, Lieberman wrote: "Like Lazarus, Berry has risen from the dead." Even more tellingly, Moxon, Wager, Abelson and the rest of the Scientology lawyers engaged in this saga, have never denied (under oath or otherwise) a single iota of the misconduct described above. In fact, they continue with the same pattern of R.I.C.O. activity against others who the Scientology enterprise considers to be "enemies". At any one time, there are many dozens of citizens being intimidated by the Church of Scientology’s domestic "psycho-terrorism." Then too there are the regular, on going "frame-ups".

Indeed, last year in People of Florida v. Prince, a Florida jury heard evidence that the Church of Scientology paid $300,000 to private investigators in connection with the arrest of former Church second in command Jesse Prince on charges of marijuana cultivation. Apparently, the jury concluded that the evidence had been planted, that the Church of Scientology had framed Jesse Prince and acquitted him. Indeed, some of the offensive conduct by Moxon and Scientology representative Ben Shaw mirrors the tactics used against me, including criminal witness tampering, private investigators engaging in illegal conduct, the filing of false police reports, the manufacture of evidence and other felonies intended to create false impeachment and the obstruction of justice in the Lisa McPherson civil litigation. These matters are now being addressed in sanctions motions before the Pinellas County, Fl. Sixth District Circuit Court. Similarly, two years

ago Mark Bunker was acquitted by an Illinois court of "trumped up" Church of Scientology charges. See generally: "Bunker Found Innocent" and and "Set up of Mark Bunker"

Unfortunately, this year a retired California private judge excluded all of Keith Henson’s "Fair Game" policy evidence and he was convicted of "interfering with the practice of a religion" through picketing alone outside the heavily fortified, high security Scientology desert "base" or "Gold" outside of Hemet, California. The Church of

Scientology’s shills claimed that they were "terrorized" by Henson’s mere presence outside the "Base." "Gold" masquerades as a Church of Scientology media production facility. Recently, the trial judge sealed part of the trial evidence without notice, motion or other accepted procedure! The trial judge also indicated he would sentence Henson to significant prison time. Henson then received word that Scientology operatives were

spreading false rumors in the prisons that Henson was coming and that Henson was a child molester. Fearing for his life in prison, Henson fled to Canada where he has applied for political asylum. However, Scientology had Henson’s appeal against conviction dismissed upon the Church of Scientology submission, through Abelson, that Henson is now a fleeing felon.

" [June 8,2001] in Toronto, California free speech activist Keith Henson won a stunning victory in the first stage of his application for refugee status in Canada. Henson, an American, fled the U.S. fearing he would be persecuted in prison after being convicted for his public criticism of the Church of Scientology. He was convicted under an obscure clause of California law that forbids ‘interfering with a religion.’ … Henson was detained for more than a week after Church of Scientology officials in Toronto complained to Immigration about his presence in Canada and [falsely] depicted him as ‘dangerous’. Today [June 8, 2001] he was released and his application for refugee status was accepted."

See generally: and and and and and

One man, Robert Minton, has been the subject of a particularly aggressive international "Fair Game" operation. He is surely the current Church of Scientology "enemy" number one. Chilling accounts of the Church of Scientology’s harassment of Bob Minton, his wife and young daughters, and thrilling reports of his achievements in response and self-defense, can also be read on-line. See generally, http:www/ and and

Indeed, the Church of Scientology tried to enter into a secret settlement with Mr. Minton in 1999. Revealingly, the proposed agreement included the following provision:

"You have agreed that on behalf of You and any person or entity You control or may influence…You will, effective as of the date hereof and forever hereafter, cease to and refrain from providing any financial support, directly or indirectly, whether in the form of money or other tangible thing of value, whether as a gift, loan, payment for goods or services, or otherwise, to any person or entity who is

now or may hereafter be adverse to Scientology Related Entities in any actual or threatened judicial, quasi-judicial, administrative, or legislative action or proceeding, including but not limited to …Graham Berry." emphasis added


The Church of Scientology’s intentional, intensive and extensive corruption of the United States federal and state legal systems, as described throughout this letter, is exemplified and reflected by what Scientology and its lawyers have done to me. In addition to corrupting and/or misleading various courts, and the State Bar of California, the Church and its lawyers have also corrupted and obstructed the prosecutorial process at every point at which I have sought "Equal Justice Under Law." This has demonstrably occurred at both the State and Federal levels, as in the Caberta case now involving the German government and the U.S. State Department, the Henson case now involving the Canadian government and the U.S. State Department and the Minton matters involving various European and African governments (and probably the U.S. State Department).


In June 1999, Robert Cipriano could no longer live with the guilt of the obstruction of justice and personal ruination that he had been extorted to participate in with Judge Williams and the Church of Scientology, Ingram, the Moxon & Kobrin lawyers and the Paul, Hastings, Janofsky & Walker lawyers. He provided detailed testimony and supporting documents to establish the serious crimes and frauds upon the court that had been associated with the publication of the First Cipriano Declaration and the ensuing litigation in the form of the Berry v. Cipriano, Berry v. Barton and Berry v. Miscavige, Church of Scientology and Ingram (Abelson and Moxon) cases. However, and as you have read above, Judge Williams ignored Cipriano’s evidence of serious crimes being permitted within his courtroom and in connection with legal proceedings pending in his courtroom. Significantly, the judge refused to even listen to Cipriano and ignored his request for the turnover of his legal files from Moxon & Kobrin (whose operating office is within Scientology’s Office of Special Affairs). As you have read, Moxon and Abelson had successively thwarted my efforts to add them to the litigation as defendants pursuant to the mandatory Cal.Civ.Code § 1714.10 procedure.

The Church of Scientology International (which employed Judge Williams' fiancée as well as all of the opposing counsel in the judge's courtroom) had retained then Los Angeles Police Commission President and subsequently major national law firm partner Gerald Chaleff to present a petition to have me declared a vexatious litigant. The vexatious litigant petition was filed before Judge Williams in connection with my attempts to clear my reputation, and to obtain compensation for the permanent damage done to me by the publication of the defamatory and perjured First Cipriano Declaration and the associated abuses of process. Supra, pages 25-72.

At the same time, the Church of Scientology also retained then Los Angeles County Criminal Courts Bar Association President Donald R. Wager and "ethics specialist" Michael Gerner to seek my disbarment as an attorney on the basis of alleged abuse of process by me in filing frivolous litigation in the form of the Berry v. Cipriano, Berry v. Barton, Berry v. Miscavige, Church of Scientology (Ingram, Moxon and Abelson) cases. In particular, relying upon Samuel D. Rosen’s discovery abuse, they had solicited Hurtado's and Apodaca's representation and perjury. All this was presented to, and unquestioningly relied upon by, the State Bar of California in finally suspending me from actual legal practice for nine months. Supra, pages 66-67. Ironically, in light of the following, the President of the State Bar is a Deputy District Attorney.

In August 1999, I personally spoke with then District Attorney Gil Garcetti at a public function and very briefly described Cipriano’s revelations. He recommended that I submit the documents through one of his senior aide who happened to be a long-time personal and professional acquaintance of mine. After I provided the District Attorney’s office with Cipriano’s testimony and documentary evidence, the senior aide left me a telephone message that, "The District Attorney [would not] do any thing for political reasons." Adding that, "One day I may be able to tell you why."

In July 2000, Cipriano traveled to Los Angeles to have his deposition taken in the Hurtado v. Berry state court case. He also wanted to provide a deposition to the California State Bar in both my defense and in connection with Mr. Henson’s then pending, but subsequently dismissed, complaint. The State Bar only wanted Cipriano’s testimony for one case and used this excuse to refuse to participate in Cipriano’s efforts to provide the State Bar with testimony regarding what had occurred. Supra, pages 57-61. At the same time, Cipriano and I both engaged in extensive taped interviews with the Los Angeles Sheriff's Department and provided it with supporting evidence and documents. The matter was investigated and presented to the Beverly Hills branch of the Los Angeles District Attorney's Office for prosecution. The District Attorney's Office ignored all of my requests for communication, engaged in no communication with me and apparently stonewalled the matter, which by then also involved the evidence as to the activities of Scientology and its corrupt lawyers obstructing justice in the Hurtado cases. The Los Angeles Sheriff’s Department officers and detectives were excellent in their efforts and communications. They were obviously perplexed and frustrated by the stonewalling/corruption at the District Attorney's Office. Indeed, one of the Sheriff’s Lieutenants warned me that my life may be in danger.

Indeed, twice I have been flown to Germany to provide advice and information to the German government in connection with the Scientology enterprise. On each occasion, I have been provided with German Secret Service protection. However, here in Los Angeles, my freedom of movement and association is now quite limited because of concerns for my physical safety. Indeed, I narrowly avoided being run-down, and then was repeatedly chased and nearly run-down by the same vehicle, which then parked within Church of Scientology premises. Others have had similar experiences. This is classical "psycho-terrorism." In fact, I have been requested to travel to Europe next month to address the contents of this letter on international television with European officials.

In April 2001, there was significant expression of public outrage at the Church of Scientology using its own criminally procured perjury (Cipriano, Hurtado, etc.) to seek my disbarment by the California State Bar, now derisively called the Scientology State Bar by some. Numerous people from around the world mailed, faxed and e-mailed their outrage to various public officials including the President of the California State Bar, the Los Angeles District Attorney and the Los Angeles Police Chief. The Los Angeles Police

Chief, Bernard Parks, ordered an investigation. I was treated with great courtesy, respect and sympathy by the investigating senior detective. Voluminous records were reviewed by the L.A.P.D. The records dealt with, among other things, the activities of former Deputy District Attorneys Wager and Abelson and former L.A. Police Commissioner Chaleff. Mayor Riordan had fired Chaleff as President of the Los Angeles Police Commission soon after his single appearance in the Berry v. Cipriano, Berry v. Barton, Berry v. Miscavige (Abelson, Moxon and Ingram) cases to have Judge Williams declare me to be a vexatious litigant for having filed those various same cases on the basis of the evidence and events described above. The Los Angeles Police Department investigation resulted in a recommendation to file certain felony indictments. The District Attorney is reported to have decided that the conduct involved (Supra, pages 25-86) was not serious enough to be prosecuted as felonies. Apparently, this decision was made after staff meetings were held at both the medium and very highest levels of the Los Angeles District Attorney’s office. The fact of such meetings having occurred merely adds weight to the Los Angeles Police Department's recommendation that indictments be filed. Reportedly, Abelson participated in the decision making process. He is a primary participant in the on-going R.I.C.O. activities and violations.

The Los Angeles Police Department's indictment recommendations were then submitted to the Los Angeles City Attorney's Office, which prosecutes misdemeanor offenses. Generally, misdemeanors are crimes specifying a maximum prison sentence of twelve months or less. Please remember, the conduct being investigated involved a criminal complaint specifically naming former Deputy District Attorney Abelson and former Police Commission President Gerald Chaleff.

On December 11, 2001, a local Los Angeles NBC affiliate reported that, "Criminal defense lawyer and former Police Commission President Gerald Chaleff …will leave the private sector to help [new] City Attorney Rocky Delgadillo to help trim city liabilities and lead a new risk management effort." Chaleff was described as, "…a specialist in City Hall operations." and

On December 23, 2001, the Los Angeles Police Department advised me that neither the Los Angeles District Attorney’s Office nor the Los Angeles City Attorney’s Office would file criminal proceedings against any of the participants in any of these matters. .

Subsequently, I was separately and independently informed that the L.A.P.D. and L.A. Sheriff’s Department recommendations that felony indictments be filed had been rejected by both the District Attorney’s Office and the City Attorney’s Office as a result of the exercise of "political influence." Significantly, it my current understanding that the relevant reports exist as microfiche records. It is also reported that steps have been taken (at least within the L.A.P.D.) to try and ensure that the Church of Scientology does not remove the copies of those recent L.A.P.D. reports, as Scientology did within the Department of Justice, the Department of Treasury, the IRS, the FBI and at least ten other Federal governmental departments before being exposed by the massive, simultaneous 1977, FBI raids upon the church of Scientology in Washington, DC and Los Angeles, CA. Supra, pages 20-21. Parenthically, it was clear that the L.A.P.D. recognized the potential for Church of Scientology instigated corruption from the manner in which the L.A.P.D. has handled their communications with me.

However, I know that there are also many good and honorable public servants in the District Attorney's and City Attorney’s Offices. For example, on December 18, 2000, and February 16, 2001, information regarding these matters was submitted to new Los Angeles District Attorney Cooley. After all, he had won office upon a public pledge that he would end the public corruption in which he had accused former District Attorney Garcetti of being engaged. On June 1, 2001, Robert H. Hausken, Lieutenant, Bureau of Investigation, Central Investigations wrote to me as follows:

"We are in receipt of the documents you presented. After a careful review by both the investigative and legal staff of all of the materials you provided, it was determined that your concerns fall more appropriately within the jurisdiction of the Federal Bureau of Investigation. Since the information you provided alleges potential crimes which occurred in California and other states, in addition to allegations of wrongdoing by practicing attorneys, the aforementioned organization is best

equipped to investigate these issues. If you wish to pursue this matter further, please submit your complaint to the Federal Bureau of Investigation, Fraud Detail, 11000 Wilshire Boulevard, Los Angeles, CA 90024, telephone (310) 477-6565." emphasis added

However, to date, my experience with Federal law enforcement’s consistent unwillingness to investigate a very small but very powerful, corrupting and wealthy religious mafia has been discouraging.


As you have read in this letter, since 1991, the Federal government and United States Congress have been corrupted and misled by the Church of Scientology, its "investigators", lawyers and lobbyists. The Congress has been misled, with fabricated claims of religious bigotry in Europe, into passing legislation and resolutions directed against European governments struggling against the Church of Scientology’s "psycho-terrorism," subversion and financial scams. The Church of Scientology has extorted, corrupted and compromised the U.S. Federal government. See generally, pages 88-90, 112-119.

Indeed, if you review the Internet on these matters you will observe that many citizens have concluded that the United States government has sold out to (and has been totally corrupted by) the Church of Scientology R.I.C.O. enterprise, hence the blatant arrogance and impunity with which the cult corrupts and obstructs the administration of justice in this country. Not only does the FBI consistently refuse to investigate the Church of Scientology no matter who, where and what the complaint concerns, but also the IRS Exempt Organizations Division has failed to act upon numerous and detailed letters complaining of various aspects contained herein. As stated above, the senior responsible official of the Exempt Organizations Division, Mr. Rotz, handled the sudden IRS reversal and has handled (and seemingly ignored) the subsequent complaints and information of the sorts of activities described herein. The Western Division of the IRS has behaved just as disgracefully. Accordingly, there is a wider than usual immediate distribution list for this letter. Nonetheless, I still hope that the relatively new Bush Administration will be more responsive and responsible than the Clinton Administration

when it comes to dealing with this domestic "psycho-terror" group engaging in such demonstrable felony crime committed by both it and the lawyers and private investigators it employs.

Certainly, it seems pointless to try and seek true justice at the local Los Angeles level.

"The criminal-justice system in Los Angeles is broken. No spin-doctor can mask the institutional breakdown at the Los Angeles Police Department. The Rampart scandal could not have occurred without the district attorney and the judiciary looking the other way for years… The reasons for this near-chaos in the local enforcement of the law have been exposed by the Rampart scandal. Police Chief Bernard C. Parks. District Attorney Gil Garcetti and the Los Angeles Criminal bench, collectively, have made decisions that inevitably led

us to Rampart…The judiciary has turned a blind eye to police perjury." emphasis added

Charles L. Lindner (Past President Los Angeles Criminal Bar Assn.), "The System Has Become Dysfunctional"

Clearly, Scientology and its lawyers exploited the alleged Los Angeles judiciary’s "blind eye to police perjury" when they hired then President of the Los Angeles Police Commission Chairman Gerald Chaleff to present a Petition to have me declared a vexatious litigant by a judge they had corrupted. Judge Williams himself was a former Assistant U. S. Attorney (criminal division) in Los Angeles. In addition, as I have indicated above, the FBI and Department of Justice seem also to be intimidated by, or tolerant of, the Church of Scientology’s domestic terrorism. Numerous agents show no willingness to offer more than condolences and apologies for being unable to do anything. For example, Mr. Henson has provided substantial materials to FBI Agent Glen Milner of San Jose without any follow-up action on Agent Milner’s part. Indeed, on March 29, 2001, Mr. Henson even advised the FBI San Jose office that Assistant U.S. Attorney David Callaway had said that what the Scientologists were reported to be doing (faking crimes, organizing false arrests, using the justice system against critics, etc.) was extortion, not of money, but buying silence from people. "He mentioned Title 18, Sec. 1952 (b) (2) [extortion, bribery, or arson, etc.]. Section 1512 [witness tampering]. Section 1513 [retaliating against a witness, victim or informant] and sections 1503, 1510, 1511, 1425, 1426, 1427, 1546 and perhaps 1581-1588."

The FBI’s apparent post-1993 indifference, along with the rest of law enforcement’s, to domestic crime connected to "religion," in this case the Church of

Scientology was also alluded to by Congresswoman Mary Bono in an interview, in the August 1999, edition of George magazine ("Proud Mary", pp 76, 90-92), regarding the late Congressman Sonny Bono. In addition, she commented that, "Sonny did try to break away at one point, and they made it very difficult for him. Extremely difficult." In that regard, Lyle Stuart, a courageous New Yorker who published both Jon Atack’s A Piece of Blue Sky and Bent Corydon’s L. Ron Hubbard, Messiah or Madman, has written that:

"Nothing in our legal tradition requires us to tolerate a racket simply because it masquerades as a religion and claims immunity under our First Amendment."

In Great Britain, the situation is clearly different. On December 6, 2001, new anti-terrorism measures were being debated in the British Parliament, including a proposal to ban "religious hatred", which Scientology has suggested it will use to eliminate its public critics in Britain. Former Conservative government cabinet minister John Gimmer stated

to the House of Commons:

"Some organizations, such as Scientology, masquerade as religions … I say Scientology is a fraud. It is a mechanism for money raising, a damaging and hateful thing. Under this measure, however, I should not be able to talk about that outside this House, and that is wrong. The Government should have no part of it." - 11119-22_para15

Indeed, it seems pertinent to ask you, as our nation's most senior law enforcement official: Why is America virtually alone in the world in considering Scientology to be a fully tax-exempt religion? Why is the U.S. Government virtually alone in the world in taking its current, permissive hands off approach to Scientology’s corruption, crime,

human rights abuses, "psycho-terrorism" and sedition? In fact, the U.S. Government's current hypocrisy in the face of both domestic and global Scientology "psycho-terrorism" is even more perplexing given the trade secret Scientology scriptural manuals directing the commission of serious criminal conduct to advance Scientology’s worldwide totalitarian agenda. Indeed, there is a clear and convincing institutional basis, incapable of change after Hubbard’s 1986 death (i.e., Hubbard is considered to be the "source" of all Scientology technology and at his death what was written by him became immutable "scripture"), for Scientology’s long history of "psycho-terrorism" and its quiet war upon the United States and its citizens from within our homeland.


The conduct and events described herein, the applicable laws and the applicable legal arguments are different only in detail from what the Starr Report and Congress dealt with concerning alleged obstruction of justice, subornation of perjury and other crimes that comprised the impeachment investigation of William Jefferson Clinton. The Church of Scientology’s lawyers, and others, should not be held to any lower standards of professional and other conduct. However, the Church of Scientology not only expressly considers itself to be above the law but also has engineered a reputation for ruthlessness resulting in it being fearfully treated as being, in effect, above the law. Supra, pages 128, 129.

In 1994, I presented the Fishman-Geertz materials to then Assistant U.S. Attorney Richard Drooyan, Chief of the Criminal Division, Los Angeles. He advised me that the matters were too big for the local Department of Justice office and they would have to be handled by Washington resources. He returned the box of documents to me.

On August 11, 1999, the August 9, 1999, Cipriano Declaration and its fifty Moxon-damning exhibits were provided to the Los Angeles office of the FBI. Both Cipriano and I met at length with FBI Agent David Cloney (Violent Crimes). After not knowing of the relevant unit to handle the matter, on August 17, 1999, Agent Cloney finally referred it to the Obstruction of Justice Unit which took no action and failed to contact me.

On the same day, August 17, 1999, I also faxed the U.S. Attorney General, Janet Reno. Her amazing response was, in effect, "I do not know what you would want me to do with the matter." I should not have been surprised. She had been in office in 1993 when the Clinton Administration yielded to what appears to be a Scientology/Moxon million-dollar blackmail, discharged the IRS’s one billion dollar tax claim against the Church of Scientology and entered into a secret settlement agreement. The Clinton Administration, of which Attorney-General Janet Reno was then a senior Cabinet officer, designated the IRS-Church of Scientology settlement as "secret" on the grounds of national security!

On December 18, 2000, much of the information herein, and supporting documents, was also provided to the Agent In Charge, FBI, US Bankruptcy Court, Los Angeles. No action was taken. Law enforcement indifference and inaction is even more surprising in light of Cipriano’s own personal participation in my attempts to obtain justice for myself. He has voluntarily, bravely come forward, admitted his own role in all of this chicanery, and sought his personal redemption and peace with God.


As I describe below, the available evidence meets all applicable standards including establishing the various crimes beyond reasonable doubt. Infra, page 130. As noted above, the evidence trail commences in late 1993, and constitutes an unbroken continuum and R.I.C.O. pattern of criminal, tortious and unethical conduct through to the present day. The recent evidence in one case, Hurtado v. Berry, is unusually damning because it is corroborated by a lawyer’s testimony/confession (a former Los Angeles County Criminal Courts Bar Association President!), over ten different witnesses as well as over sixty different documents - many of which bear Scientology lead lawyer Moxon’s own signature and handwriting. That evidence proves and corroborates R.I.C.O. predicate acts, bankruptcy fraud, insurance fraud, frauds upon various courts in various states, blackmail, bribery, solicitation, maintenance and champerty, perjury, use of a third person, illegal wire tapping, obstruction of justice, false criminal reports, false state bar reports as well as other misconducts too numerous to list. Clearly, the conduct include violations of 18 U.S.C. §§ 1621, 1603,

1503, 1512, 371 2(a), 2(b) (perjury, obstruction of justice, witness and evidence tampering, conspiracy, aiding and abetting and the use of an intermediary). Indeed, oral and written testimony, and corroborating documents include multiple incidents of blackmail, bribery, extortion, witness tampering, perjury, subornation of perjury, wire tapping, obstruction of justice, frauds upon various courts, attorney misrepresentations and lies to various courts, false criminal complaints, false state bar complaints and possible judicial corruption.

It has been suggested that the Los Angeles District Attorney's office considered there would be prosecutorial problems because, as argued by the Church of Scientology, Cipriano, Hurtado and Apodaca are not credible witnesses. However, it was the Church of Scientology that had recruited these individuals and used them in various legal proceedings and process. At the time, the Church and its attorneys (having solicited and extorted the numerous perjuries) argued that the three were very reliable, credible and should be believed. Now the Church of Scientology and its lawyers argue that their partners in crime (Cipriano, Hurtado and Apodaca) should not be considered credible witnesses because they have changed their testimony (and told the truth) and because they have criminal records. However, the courts regularly rely on the evidence of felons and others who have changed their testimony. The critical issue is corroboration. Here there are mountains of corroboration. Over sixty documents and at least ten currently available witnesses corroborating various aspects of the subsequent testimony of Cipriano, Hurtado and Apodaca. Significantly and despite their seven year world-wide investigation of me, the Church of Scientology has only been able to provide the perjury of Cipriano, Hurtado and Apodaca to support their defamatory publications about me, their defenses of law suits filed by me and their allegations in lawsuits generated by them against me. If prosecutions could only rely upon the testimony of persons without criminal records, there would be relatively few prosecutions!

It also seems that there is clear and convincing evidence of corruption within the Los Angeles District and City Attorney’s Offices. The corruption has violated my human rights, civil rights and constitutional rights. It all the more outrageous because of the apparent involvement of Abelson and Chaleff (and perhaps other Scientology

representatives) in the prosecutorial process at the Los Angeles District Attorney's Office and the Los Angeles City Attorney's Office. Of course, this was not isolated corruption involving the Church of Scientology and its generously paid lawyers. They have also blatantly corrupted the Riverside District Attorney's Office and the Hemet, California court. Supra, page 73.

The conflict and corruption is no different from the situation we would have if Enron's lawyers were permitted to be a part of any decision making process in connection with any prosecutions resulting from the Enron investigations, or if President Clinton’s lawyers had participated in the actual decision of the House Judiciary Committee to file Articles of Impeachment with the U.S. Senate. These procedural and due process issues alone mandate that the Department of Justice commence immediate investigations into the matters addressed in this letter.





On October 5, 2001, President Bush’s White House Spokesman, Ari Fleischer, commented, "Terrorism exists in this world, and in the United States, in all kinds of shapes and forms." For example, in an article "Scientology: A History of Terror and Abuse", Craig Branch of the independent Christian research group and ministry The Watchman Fellowship writes:

"Scientology has been called a terroristic, criminal cult. Much evidence exists to demonstrate the validity of these charges made against Scientology. There are "immutable," internal, policy letters or "scriptures" of Scientology. There are numerous civil and criminal convictions of the Church itself and various leaders and members, in the United States and other nations. All of the above combine with testimonials of many people abused by Scientology, to establish a history of institutionalized harassment and suppression of its critics." emphasis added

See also: and and related pages and

Leading cult expert, Steve Hassan, has written of the September 11, 2001, World Trade Center tragedy:

"Terrorist cult organizations apparently employ many of the same mind control techniques used by such destructive groups as Scientology…These include isolation, hypnosis, sleep deprivation, dietary manipulation and the programming of phobias in the minds of members." emphasis added

Steve Hassan, "Cult Mind Control Techniques May Have Fueled Terrorists," a

In a December 18, 2001 WBUR Boston interview, Mr. Hassan explained further:

"…[E] very group influences its members, but when we talk about destructive mind control, we’re basically talking about an authoritarian, pyramid structured group that uses deception and control of behavior, information, thoughts and emotions to reshape a person’s identity and make that new identity dependent and obedient on the leadership

… destructive mind control groups literally program people so that they don’t have a free choice and they don’t have access to alternative points of information. They’re often sleep deprived, they’re induced into hypnotic states of consciousness… and my criticism of destructive cults in general is focused on their behaviors, not on their beliefs. And the focus is loss of control, whether or not someone is choosing to have these new beliefs or whether or not it’s being forced upon you."

In the same interview, Mr. Hassan commented upon the possible shortcomings of the current Administration’s new worldwide "War on Terrorism."

"We went on a military engagement to end terrorism, but anyone who knows anything about terrorism knows that this is just the first phase, and what we have to deal with in the next phase is millions of people who have been indoctrinated into this totalistic, black/white, us-versus-them hatred of America. And so we’re in a psychological war, and

therefore we should be using every knowledge, every technique at hand to rescue people. I can also go out on a limb and say that in the United States I feel we are subsidizing with taxpayer money destructive cults that are defrauding the public and infringing on people’s human rights here. Everything from the Moon organization which has achieved incredible power, owning the Washington Times, Insight magazine, UPI. Scientology, which did not have tax-exempt status for 25 years until the Clinton Administration. And I may say one more point, that since 9-11,destructive cults are recruiting like crazy, because the public is fearful, because the economy is in a slump, and they’re playing on people’s minds and insecurities…" emphasis added

In addition to the domestic "psycho-terrorism" referred to in this letter, these matters also involve the largest ever known tax fraud in the United States, resulting in a secret blackmailed Clinton Administration tax relief package to the Scientology enterprise and Miscavige personally. According to Scientology’s leader, the so-called "Captain" David Miscavige, the Clinton Administration relieved the church and its leaders from over one billion dollars in past due taxes, penalties and interest. and At the same time, the Clinton Administration "religious recognition" and "full tax exemption" permitted the Church of Scientology to determine its own future tax compliance, and that of its members, through the IRS sanctioned Scientology Tax Compliance Committee headed by Scientology "ecclesiastical" leader Captain David Miscavige. This can be compared to putting Al Capone in charge of Fort Knox!

Church of Scientology "sacred" scripture confirms this:

"Taxes exist only to destroy business. Be impudent. Get rich and to hell with them. Governments are just a reactive bank we have to live with for a while…Still try and use the above system. But if you can’t, pay it and retard other bills accordingly. And thereafter, don’t pay that

outfit’s bills on any other terms than threatened trouble."

[Hubbard Communications Office Policy Latter, 28 January 1965]

The secret IRS-Scientology billion dollar tax relief package was clearly procured by both extrinsic and intrinsic fraud. The extrinsic fraud was the serious criminal conduct, litigation terrorism and abuse of process. The internal fraud is set forth on the various pages of the Church’s Form 1023 application of 1993. The enclosed Scientology responses to IRS questions 3a, 3b and 10 exemplify this. Those responses obfuscate, misrepresent, omit, divert and gloss over the truth. Scientology’s responses to the IRS questions 3a and 3b deal with the "hierarchical management structure" and "Command Channels" of the church as opposed to its "ecclesiastical structure". The pivotal and fundamental management tyranny and role of the Sea Organization is totally misrepresented even though it is the basic means of exerting power through the hundreds of separate Scientology corporations without regard to corporate formalities and boundaries. The dominant role of production, money and statistics can be clearly observed. The Scientology responses to the IRS’s Question 10 is equally outrageous to any non-Scientologist with even a mere cursory knowledge of these hundreds of different lawsuits being described, under penalty of perjury. Indeed, this should have been quickly evident to a mere cursory IRS review of the Form 1023 itself, thus raising the specter of Clinton Administration misuse of the IRS, and the flouting of applicable law and litigation history. All of the evidence of Scientology litigation abuse, and abuses revealed through litigation, is swept under the carpet by Scientology counter-attacks upon CAN, numerous biased, vindictive and bigoted IRS officials opposing lawyers such as Toby Plevin and Michael Flynn, and stolen documents. However, Scientology does not explain why the IRS should not rely upon incriminating documents allegedly "stolen" from Scientology, the evidence of "apostates" or former Scientologists who often held senior executive positions and served Hubbard personally, various jury decisions against it and certain criminal convictions. Indeed, the true facts concerning many of Scientology’s responses to the IRS questions are diametrically opposed to the massive misrepresentations made by the Church of Scientology and its lawyers.

The New York Times came into possession of a copy of the secret IRS-Church of Scientology tax settlement and provided the first comprehensive review of the secret agreement. "Scientology’s Puzzling Journey From Tax Rebel to Tax Exempt." A comprehensive timeline, analysis and hyper linked list of extensive other media and critical comment are available and . See also, for example: Scientology’s Tax Exemption Should Be Rescinded and Piercing The Corporate Veil and Second In Command Tells All and the Affidavit of Stephen A. Kent sworn January 6, 2000.

Part of the same secret tax agreement required the Clinton Administration to actively participate in the Church of Scientology’s dissemination, copyright infringement litigation, "tax exempt" agenda and lobbying concerning foreign tax authorities, Interpol

and foreign governments, particularly in Europe. U.S. Government trade sanctions were threatened against nations, Sweden for example, which did not comply with the Clinton Administration's demands made on behalf of the Church of Scientology. This billion dollar federal tax relief package to a R.I.C.O. enterprise and "religious" corporation engaging in domestic "psycho-terrorism" has, among other things, and according to the written Scientology policies and practices collectively referred to as "Fair Game," funded the harassment and "utter destruction" of me, a New York and California attorney, and other American citizens and entities too numerous to list herein. It is apparent that Clinton-era "ethics" have become the rule of law in the State of California. Indeed, on July 18, 1998, The Wall Street Journal examined the Church of Scientology’s use of its celebrity representatives (particularly Tom Cruise and John Travolta) to influence the Clinton Administration, particularly President Clinton himself and his National Security Advisor, Sandy Berger. Sandy Berger even gave "security briefings" to John Travolta who reportedly agreed to tone down the purportedly Clinton-esque movie Primary Colors. Outrageously, and thumbing its nose at the numerous exposés of the blackmailed "secret" 1993 Scientology-IRS tax deal, during the turbulent 1999 political year, the Clinton IRS quietly renewed the church’s fully tax exempt status.

Amazingly, the President of the Church of Scientology, Rev. Heber Jentzsch, was until recently a fugitive from justice. He was on "the lam" within the United States. He had forfeited an $800,000 dollar bail bond in Madrid, Spain when he had failed to appear for trial on serious charges of Church of Scientology criminal fraud. The Government of Spain had requested he be sentenced to a sixty-year prison term. The apparent Spanish government requests for his extradition appear to have fallen upon deaf ears at the U.S. Department of Justice. It has publicly commented that it cannot locate the fugitive since he is hiding - the fugitive being the high profile President of the high profile tax-exempt Church of Scientology. and

I have the fleeing fugitive Church of Scientology President’s very confidential job description or "Hat Pack." I examined him on its contents in deposition on January 13, 1994. He testified that it was his "full hat sheet checksheet" or job description as of 28 January 1988, and that certain pages bore his initials and signatures. There are three volumes aggregating 3 inches in thickness. The first page of each volume is a Church of Scientology United States Guardian Office ("GO") Coat of Arms. "Information Full Hat. Confidential Pack 1(2, 3) of 3." Interestingly, they also bear the stamp of the United States District Court of Columbia and "Government Exhibit 236." The contents are mainly GO issues such as, to name a few: Intelligence Course (GO 1314 1974); The Information Bureau (to be read with 1. Brainwashing (A Synthesis of the Russian Textbook on Psycho-Politics); 2. Hidden Story of Scientology, 3. Part 1 South African Submission; Numerous GO Intelligence, Attack and what are part of the "Fair Game" Issues; TERROR STALKS; FDA raids; Project Psychiatry; Intelligence Section; Intelligence Actions; Intelligence Stat; Covert Operations; Black Propaganda; KSW 1; Suppressive Person Declares; Operating Targets (including the use of ethics and processing files); Internal Security, etc. There are dozens and dozens of such issues. Few, if any, post-date the 1977 raid and they were attested to, in 1994, as being the President of CSI’s job description. The potential implications of such a criminal and hate-filled

manifesto upon the IRS Tax ruling are obvious. Just to remove any question as to the genuine "religiosity" of this Church, I also have The Volunteer Minister’s Handbook by L. Ron Hubbard (1979). It contains 21 different "packs," each with checksheets. These include the: Investigations Pack; PTS/SP Pack; Ethics and Justice Pack; Third

Party Pack; Targets; and, Public Relations Pack. For example, "Item 22 requires him to demonstrate his understanding of Scientology’s goal of ‘obliterating’ psychiatry, psychology, the media, political figures and bankers." (emphasis added) There is a copy of many of these and related documents, and expert analysis, at Scientology’s Secret Service:

A CD copy of fugitive Church of Scientology President’s job description and study documents, those of Church of Scientology Intelligence Officers ("The Intelligence Officer’s Hat Pack") and other related documents, are also enclosed with this letter

[pursuant to copyright "fair use" and Cal. Civil Code section 47(b)].

In addition, an excellent historical account of "Scientology: Religion or Intelligence Agency?" has been written by Scientology expert and author Jon Atack. The Scientology Secret Service operates from the Office of Special Affairs ("OSA") currently commanded by Australian born Michael Rinder. (Interestingly, in 1947 the intelligence division of the CIA was known as the OSS). Prior to the massive 1977, FBI raids on the Church of Scientology, OSA was called the "Guardian’s Office" ("GO"). The same Internet Archive has the most instantly accessible and comprehensive set of numerously hyperlinked Church of Scientology’s intelligence and terror agency documents relating to the criminal complaints and requests herein. In addition, although outdated (1998), it has a very comprehensively indexed hyerlinked summary of many of the Church of Scientology’s terror documents, stories and descriptive Internet sites. As you will see, OSA can readily be compared to Hitler’s Gestapo. It is self-evident that Scientology’s "Fair Game" Policies and Practices are ultimately intended to coerce OSA’s "targets" into wishing they were dead and to cause them to commit suicide. For example, as a further, horrendous practical example, you are referred to the frame-up and campaign of terror against courageous author Paulette Cooper known as Scientology’s "Operation Freakout". and

Moreover, you are also referred to the extensive and authoritative Internet archived work of Scientology expert and former senior Church public relations executive Robert Vaughn Young. and and and (affidavit).

Mr. Jesse Prince gives another chilling account of Scientology’s R.I.C.O. enterprise. Mr. Prince is the former second-in-command of Scientology’s then most senior corporation, Religious Technology Center.

Recently, Victoria "Tory" Bezazian defected from the Scientology enterprise after 30 years of involvement. Recently, that involvement included participation in Church of Scientology Internet crime, fraud and the illegal, sometimes pornographic, spamming of certain Internet news groups. and and

The Church of Scientology, and a number of its senior executives, have been the subject of a number of relatively recent police raids and criminal convictions in Canada and Europe; for example, France; Greece; Belgium; Spain and Russia. Some of the incriminating documents seized in those raids can be viewed on the Internet.

Indeed, you may conclude by the end of this letter that there is good reason why much of this Internet information is available from European Internet websites and not from the United States where the Church of Scientology has been instrumental in successfully lobbying Congress to increase the duration of its copyright protections of its "secret" hate-filled "sacred" scriptures and to enact legislation to protect them from public view upon Internet web sites within U.S. jurisdiction.

As you have read above, the genesis of these matters, as concerns me, is in Church of Scientology defamatory publications that have effectively destroyed my life. They were based on perjury the Church of Scientology suborned against me as a result of

my representation of litigants it had sued. Unlike the United States government, the Canadian Parliament was so outraged by the Church of Scientology’s harassment and defamation of an opposing attorney that, in 1998, it enacted special legislation intended to prevent the Church of Scientology using lawyers to engage in "falsehood, deceit, prevarication, and subornation in court proceedings." An attorney, Casey Hill, also received approximately $4M in civil damages. As you have also read in this letter, in 1977, the FBI simultaneously raided the Church of Scientology’s premises in Washington, DC and Hollywood, California. The FBI seizure included documents (personnel folders) the Church of Scientology had stolen through infiltration of the Ontario Provincial Police. Both it and the Royal Canadian Mounted Police took action culminating in the criminal conviction of the Church of Scientology as a corporate entity. See The involved staffers had been carrying out written Church of Scientology policy manuals such as Hubbard Communications Office Policy Letters and Bulletins. The Church of Scientology set about destroying the reputation of the lead Canadian Government prosecutor, Barrister Casey Hill, just as they did with me. He successfully sued for defamation. The Canadian judge had not been corrupted like so many California and Florida judges have been compromised by Scientology’s OSA. Ultimately, the Casey Hill defamation case reached the Supreme Court of Canada where one of the justices described the Church of Scientology’s conduct as "…recklessly high-handed, supremely arrogant and contumacious…There seems to have been a continuing conscious effort on Scientology’s part to intensify and perpetrate its attack on Casey Hill without any regard for the truth of its allegations." The Canadian Government, unlike our own to date, was outraged by the Church of Scientology’s abuse of process in the civil courts by Church of Scientology lawyers engaged in criminal and civil abuse of process on behalf of a client. It reacted with special legislation to address

the problem. and and (at the top of the page insert scientology and select page 3 of 11 [dated March 26]).

Again, and unlike the corrupted and compromised American political and legal system, the Church of Scientology recently had to apologize and settle in the British

courts for defaming former Scientologist, the American born Mrs. Bonnie Woods. She had been represented (largely pro bono) by one of London’s largest and most prestigious law firms. Our large American law firms [or law mega-businesses] have, to date, been less charitable, professional and public spirited, at least concerning victims of the Church of Scientology. On June 8,1999, Mrs. Wood’s counsel appeared in the British High Court of Justice (Case 1993 W No.2079) and stated:

"The defendants [Church of Scientology, et al] have now acknowledged that the allegations against Mrs. Woods were untrue. They are here by their Counsel today to withdraw them and to

apologize to the Plaintiff [Mrs. Woods]. They have agreed to pay Mrs. Woods a substantial sum of money in respect of her claim for damages for libel, and to undertake to the Court that they will no longer make these untrue accusations against her." emphasis added

The Church of Scientology’s counsel stated:

"On behalf of the Church of Scientology and all of the Defendants I wish to associate myself with all that has been said by counsel for the Plaintiff [Mrs. Woods]. The defendant’s regret that when responding to Mrs. Wood’s criticisms of the Church of Scientology, they went too far in attributing to her conduct and motives which they now accept were not correct. Through me they apologize to Mrs. Woods and undertake (in the terms of the draft order before Your Lordship) not to make any such allegations again." emphasis added

Not surprisingly, the Church of Scientology’s founder, L. Ron Hubbard, was convicted of check fraud in San Luis Obispo, California in 1948, and of fraud in France in 1978 (sentenced in absentia to fours years' prison and 30,000 francs fine). Shortly afterwards, and to avoid service of legal process, L.Ron Hubbard went into hiding for the rest of his life. Significantly, only two years ago, Great Britain again denied the Church of Scientology’s application for religious recognition and tax-exempt status because of the absence of any [true] redeeming charitable activities by the Church. Other countries do not consider Scientology to be a religion, tax-exempt or otherwise. Some of these include Belgium, Canada, France, Germany, Ireland, Italy, Luxembourg, Spain, Israel and Mexico.

Other extensive hyper-linked media and litigation resources regarding the harassment, intimidation, abuse and terror carried out by the fully tax exempt Church of Scientology can be found at: and and and at a Church of Scientology affiliated website:

Indeed, Scientology is a church with a body count! The death of Lisa McPherson is particularly chilling and outrageous. The St. Petersburg Times, December 7, 1997, pp.1, 8A, published an extensive story by Pulitzer Prize winning investigative journalist Lucy Morgan. The story details how "… seven other Scientologists in apparently sound health died suddenly after coming to Clearwater for training and counseling." Several of the Scientologists died after using Scientology’s regime of vitamins and minerals in lieu of prescribed medicine. Another man was found dead in a bathtub "with water so hot that it burned his skin off." Ibid. The subsequent litigation history of the McPherson case is also outrageous. The Wall Street Journal even urged Attorney General Reno to investigate the horrific and ugly death of Scientologist Lisa McPherson. However, as you have read, the Clinton Administration was as "thick as thieves" with the Church of Scientology and nothing was done. and and

Ironically, President Clinton’s idol, President John F. Kennedy, said of the civil rights debate on June 11, 1961: "We are confronted principally by a moral issue. It is as old as the Scriptures and is as clear as the American Constitution." The moral issue here is the right to be free of terror and other human rights abuses perpetrated in the name of religion. Significantly, the Administration that you serve has declared war on terror, including terror in the name of religion. In fact, on November 18, 2001, Secretary of State Colin Powell stated: "Terror and violence must stop, and must stop now."

Terror takes many forms. One form is fear. The Random House Dictionary of the English Language defines "terror" to include "…intense, sharp, overmastering fear." In fact, "Scientology is quite likely the most ruthless, the most classically terroristic, the most litigious, and the most lucrative cult the country has ever seen." and and

Similarly, on October 1, 2001, U.K. Ambassador Jeffrey Woolcock said to the United Nations General Assembly: "What looks, smells and kills like terrorism is terrorism." Terrorism in all of its shapes and forms is evil. And, as has been written about other totalitarian horrors, "The only thing necessary for the triumph of evil is for good people to do nothing."



One example alone illustrates the hypocrisy of the U.S. Federal government's approach to this cult. The Scientology organization’s treatment of staff members’ (Sea Organization) families and unborn children.

The federal government now denies foreign aid to countries that permit abortion. However, the U.S. section 501 (c)(3) fully tax-exempt, para-military Scientology enterprise orders (Sea Organization) staff women to have abortions (likely because, according to Hubbard, "Children are expensive inconveniences who interfere with production" [of money]). Put another way, the U.S. Federal government denies aid to foreign countries that even permit abortions while at the same time, it grants U.S. federal tax-exempt status to a California "religious" corporation that orders certain of its woman employees ("religious" volunteers) to have "church" funded, U.S. Government subsidized, abortions.

Scientology’s human rights abuses in the United States are not limited to the unborn. There is extensive evidence of the unlawful use of child labor, children doing

forced heavy labor, and parents being denied even limited "family time" with their children residing within Scientology’s "Cadet Org". Flag Order 293 (canceling one-hour-per-day "family time" for Sea Org members; Flag Order 3905 (no more children): and and and and and and and and and and and and and and and and and and and

Accordingly, the Church of Scientology has not only "hijacked the legal system and crashed it through the Constitution." It has also hijacked religion and crashed it through the very concept of morality and God. It uses the satanic "double cross" to sell an alleged "bridge to total freedom" to the mentally manipulated. In fact, Scientology "secret scripture," and Scientology’s "secret" totalitarian agenda mandates the takeover and elimination of all of the world’s religions. Hubbard teaches that he had been to heaven twice and found it "…a scruffy kind of place." He also teaches that Jesus Christ was merely a mental "implant " and never existed. Indeed, you can hear for yourself, Hubbard lecturing, "There was no Christ." emphasis added ndex.html (click Hubbard’s picture). Also see: and and$/Christian/intro.htm and and

(Christian Research Journal) and (Christian Research Journal) and

Terrifyingly, the Church of Scientology acts an apex predator (rather like the great white shark), kidnapping the minds, hearts, dreams, bodies and lives of young adults; in reality, even entire families. It does so by coercive mind control. Contrary to its claims and denials, Scientology also uses psychosis inducing "technology" such as "reverse processing" and "Black Dianetics." See

The roots of the Church of Scientology lie in post-World War II Pasadena, California where L. Ron Hubbard and J.P.L. scientist, Jack Parsons, engaged in

Satanic worship and were followers of the infamous Satanist Alistair Crowley. For information on the Satanic roots of the Church of Scientology search with the key words "scientology, Satanism, Parsons, whore of

Babylon, OTO, ruin utterly". For comment and conjecture as to why the U.S. Government appears to support the Church of Scientology add the following words to the search: " SRI, NSA, CIA, espionage, long island, CST". In addition, view "Hubbard and Black Magick". and "A Secret Satanic Cult and the Hollywood Movie Industry:"!!!FactNet!!!/headlines/

Indeed, the Church of Scientology cross is the Satanic eight-pronged or double cross which it has trademarked. Deceptively, the Church of Scientology’s explanation is that its double-cross represents the eight dynamics of Scientology: self; family; groups; humanity; other life forms; physical universe; spiritual universe and infinity.

Like Al Capone who once said that he robbed banks because, "That is where the money is!" Hubbard reportedly said in 1948 that he would form a church because, "That is where the real money is."

More than anything, the Church of Scientology is based and built upon lies and deception and teaches its members how to lie as well as how to tell "acceptable

truths" "for the greater good of Scientology." In his "On Control and Lying", Hubbard writes that, "The only way to control people is to lie to them". Similarly, a Church of Scientology scripture trains Scientologists, particularly those who deal with governments, media and the legal system, how to lie ("outflow false data effectively"). and [Scientology Chia Pet]. Scientology public relations are also total deception and deceit. For example, the church will even doctor the photos of its PR events. "Scientology’s Funny Photos:"

Professor Stephen A. Kent has written a number of major research papers on the Church of Scientology, its religiosity, brainwashing, concentration camps

("Rehabilitation Project Force" or "RPF"), "Fair Game" practices, etc., along with other excellent books and articles, some of which can be read on-line. and and and and RPF paper.htm

Cult specialist Rick Ross opines that "[Scientology] is a multi-faceted transnational [business] that has religion as one of its many components." An interesting review of some of "Scientology’s Religious Practices" is at "The Scientology Comparative Theology Page."$/Christian/scnpract.htm A large number of similar materials from The Watchman Expositor can also be read on line at . In particular, you are referred to the papers entitled "Church of Scientology: A Religious Mafia?" and "Scientology’s Concentration Camps." For comprehensive review see the hyperlinked lists of materials at: and and ("Special Resources").

In 1982, the City of Clearwater, Florida held public hearings into the Church of Scientology’s arrival in that city. See http://www/ . In addition, former Clearwater Police Lieutenant Ray Emmons prepared a multi-volume report supported by 40 boxes of documents, which the Church of Scientology is attempting to have destroyed. http://www/ . It is Police Lieutenant Ray Emmons’ conclusion that the Church of Scientology is a R.I.C.O. enterprise. Many illustrative court and FBI records, and over 200 other web sites, are listed or can be viewed at and Indeed, many now refer to the Scientology strongholds in Clearwater, Florida and Hemet, California as "Occupied Clearwater" and "Occupied Hemet." Their residents have been terrorized into silence and their police, prosecutors, judges and public officials corrupted. Scientology’s next U.S. urban take-over target appears to be Battlefield, Illinois, which was formerly a Kellogg’s company town.

Former scientologist Jon Atak has written the definitive expose on Scientology: A Piece of Blue Sky, Scientology, Dianetics and L.Ron Hubbard Exposed. It too can be read on-line at Recently, the Church of Scientology initially succeeded, but ultimately failed to stop distribution of this book in the United States. ("Virtual Book Burning"). Indeed, Scientology has regularly used the U.S. courts, and the threat of expensive litigation in U.S. courts, to block publication of numerous books and articles exposing Scientology even though the same publications are freely available

elsewhere in the world. What is not judicially suppressed is often "culled" or stolen from libraries, court records, and newspaper boxes. In addition, the church requires its parishioners to install computer software (the Scientology "net nanny") that censors and filters out access to all persons and sites considered critical of or hostile to Scientology.

"The court record is replete with evidence that Scientology is nothing in reality but a vast enterprise to extract the maximum amount of money from its adepts by pseudo scientific theories … and to exercise a kind of blackmail against persons who do not wish to continue with their sect

… The organization clearly is schizophrenic and

paranoid, and this bizarre combination seems to be a reflection of its founder, L. Ron Hubbard."

Judge Paul Breckenridge, Los Angeles Superior Court, Armstrong v. Church of Scientology (1984).


Masked behind a contrived, slick public relations façade of acceptability and religiosity, the Scientology enterprise has a very checkered and tawdry fifty-year history. In fact, the Church of Scientology may accurately be deemed to be America’s own Taliban. The Church of Scientology closely resembles the structure and operation of the Taliban, as well as the Nazi and Communist movements. http://www/ , "The Art of Deception," and comparisons between Scientology and Nazism are found at In that regard, Scientology’s founder adopted the teaching of Nazi propaganda minister Joseph P. Goebbels. Like Goebbels, L. Ron Hubbard teaches his followers to tell such a big lie, so complex and so often, that it becomes perceived as the truth. See generally: http://www/

Numerous European governments refuse to follow the United States government’s currently implicit, but fallacious, position that Scientology’s "psycho terrorism," criminal conduct and civil rights abuses must be ignored and endured in the name of First Amendment religious freedom. However, this is not the law, at least not in the State of California. See generally, Molko v. Holy Spirit Ass., 46 Cal.3d 1092 (1988) (Findlaw: Findlaw California: Case Law: California Case Law: 46 Cal. 3d 1092)

In part, the open disgust of various European governments at our continuing Clinton-era reversal and subsequent hypocrisy in regard to this issue was reflected in their recent vote to replace the United States on the U.N. Human Rights Commission. After intense Church of Scientology celebrity lobbying of the Clinton Administration and Congress in 1999, the U.S. State Department began issuing an annual International Religious Freedom Report that severely criticizes a number of European countries including Germany and France. See: (search term "scientology") and and (Europe Resists American Religious Cults-Secular Society at Stake).

In fact, over ten years ago, at a conference of the Ministers of the Interiors and Senators of the German Federal States, a resolution was passed entitled "Surveillance of the Scientology Organization by the Office for the Protection of the Constitution (the German Secret Service and Police)." The resolution read as follows:

"The Scientology organization, at this time presents itself to the appropriate authorities of ‘protection against threats’ and Criminal Prosecution of the Department of the Interior as an organization which under the disguise of a religious group combines elements of business crimes and psycho-terror against its own members with economic activities in sectarian traits. The focal point of their activities appears to be in the areas of economic crimes. Therefore, the protective efforts on the state level should be continued." emphasis added

Later, in September 1994, the German Federal Labor Minister said he regarded, "… the sect as a money laundering organization which, under the cover of religion, wants to spread its blinded ideology world-wide and stops at nothing to do so." emphasis added

In fact, Earthlink co-founder and Scientologist Reed Slatkin is currently under an outrageously weak and insipid SEC and FBI investigation in connection with, "… a huge international investment fraud, bilking what now appears to be as many as 850 creditors out of over $500 million." The largest "ponzi" scheme in U.S. history. Scientology also holds the dishonor of being involved in the largest case of domestic spying in U.S. history. See U. S. v. Mary Sue Hubbard, et. al., and U.S. v. Jane Kember, et. al., "Scientology Caught in Espionage Campaign," Clearwater Sun, November 3, 1979, on-line at

In the current Slatkin "Ponzi" scheme (similar to Scientology’s American Express ["The Amex Cycle"] and other Scientology credit card, stock market, securities, real estate and gold mining scams) suspiciously, in light of the Church of Scientology’s obvious involvement, the U.S. DoJ, FBI and SEC (even under the Bush Administration) appear to have back-pedaled regarding the matter despite the evidence of Slatkin’s lying to Federal authorities. In fact, the clear evidence is that the SEC and FBI (during the Clinton Administration) ignored evidence of Slatkin’s financial crimes (and concurrent payments for Scientology "processing" or "auditing") until his April 2001, bankruptcy filing forced the FBI to belatedly heed earlier evidence. As serious as the Slatkin "Ponzi" scheme is, it is just another in a long list of Scientology-related financial, tax and bankruptcy fraud both in the U.S. and in Europe. However, regrettably and all too typically, the post-Clinton FBI appears to be similarly intimidated by the fraudulent Scientology front of religiosity and constant, but largely tactical, Scientology complaints of religious bigotry and religious persecution.

See: and and and

On October 21, 2001, The Los Angeles Times published its Sunday Report entitled "European Network had Paris in Mind."

"Today, the archaic sect-like movement to which the suspects in Europe belonged sees violence as a sacred duty…the profile of the Paris plotters also recalls a cult French and U.S. officials say, comparing the indoctrination techniques in Europe to the Western religious sects that prey on promising young people left vulnerable by frustrations, family problems, drugs…There’s mind control here, someone preying on the psychological weaknesses of bright kids. There’s a whole group of people pulling people into the network." emphasis added

Not likely coincidentally, Hubbard’s "Manual on Brainwashing" is reputedly the best mind-control text in the coercive indoctrination business.

On-line at and

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". (Scientology’s Concentration Camps) and (Brainwashing In Scientology’s Rehabilitation Project Force [RPF]) and and and (Reposted Classics #16, Declaration of Andre Tabayoyon).

If the Church of Scientology is really the peaceful, law abiding religious organization it (mis)represents itself to be, then why does it need a multi-million dollar intelligence organization, para-military operations and

hundreds of (unregistered) automatic weapons, machine guns, rockets, explosives and a heavily armored residence for its leader at a highly fortified desert compound on American soil? Why does it need to engage in gunnery practice? On September 14, 2001, Scientology’s former second in command Jesse Prince provided one answer:

"By policy, Scientology is anti American government and seeks to take over the American government and make it a Scientology government. Similar to terrorists, Scientology will target, attack and try to destroy anyone, any government, person or organization that does not bend to its will…Is it necessary for American citizens to wait for a major disaster caused by Scientology before something is done? I sure hope not, but Scientology is well on its way to doing something extremely stupid. Just look at

what Reed Slatkin did. Reportedly, the World Trade Center was built at a cost of $400 million. Slatkin robbed investors of $600 million. Scientology’s open attack on American citizens as well as anyone else with their ‘fair game’ is nothing less than practical terrorism." emphasis added

According to the directory of Scientology’s (false) front business arm (the World Institute of Scientology Enterprises ["WISE"]), it has even infiltrated the Russian nuclear industry. The Smolensk Nuclear Power Station is affiliated with Scientology through Mihail Durmanov, 2 Mikrorayon D@ Fl. 42, 216532 Desnogorsk Smolenskaya, Russia, It has also been reported that Scientology-WISE shills have controlling interests in supposedly converted Russian weapons plants and is involved with people who have access to weapons grade materials, including Adnan Kashoggi as noted below. Kashoggi

is known also to have access to biological and chemical weapons. Indeed, Russian economist Tatyana Koryagina stated in an interview by Rick Wilde on the Alex Jones Show that "Scientology has infiltrated almost every top government position in pretty much every country in the world."

When L. Ron Hubbard founded Dianetics ® and Scientology ® it was initially an "applied philosophy". The contrived Scientology façade of religiosity really evolved in

the mid-1970’s. One reason was to defend against U.S. government concerns regarding Scientology’s unlawful practice of medicine, the 1962 FDA raid on the Church of Scientology, the seizure of the Scientology "religious artifact" called the E-Meter (a

primitive circa1946 lie detector) and Scientology’s refusal to pay taxes on its "fixed donations" and "doctrine of exchange" for auditing, E-Meter processing, courses and other self-help type "services." and and

L. Ron Hubbard also introduced the Dianetics and Scientology religious façade at the time the now former Justice Department and FBI rules restricting the investigation and monitoring of religions were imposed as a result of the then perceived excesses of

J. Edgar Hoover during the turbulent 1960's and early 1970's. "Indeed, there is overwhelming testimony that, in essence, the Church of Scientology has, in your own words of December 2, 2001, … "hijacked…religion and made out of it an instrument of war…"

In fact, the finances of Scientology and violent terrorism appear to intersect in Albania where Scientology’s business front, WISE, tried to compromise the banking system with its "Project Albania." The IRS ordered the Church of Scientology to disband WISE by 1995, as a condition of the 1993 secret IRS-Scientology Tax Exempt Closing Agreement. Scientology has ignored the mandatory IRS condition. Despite the public and media uproar in 1997, over the disclosure of the secret IRS-Church of Scientology Closing Agreement, it was quietly renewed by the Clinton Administration during 1999, and WISE remains a recruitment and financing conduit for Scientology and its psycho-terroristic policies and practices. See generally: A photograph of California Attorney General Bill Lockyer with Scientology W.I.S.E. officials and members can be viewed at and . At the bottom of the aforenoted page you will see high-level Scientologists left, right and center with California State Attorney General Lockyer. One is a Mr. Pearson, formerly of the infamous "laundry ball" scam, who now brings Scientology to the California and Florida State Governments and their electronic communications courtesy of Scientology's business arm WISE. Indeed, the use of WISE to infiltrate corporate America is exemplified by the introduction of Scientology Technology into the Sears’ Allstate Insurance Company. The Wall Street Journal examined this in an article "Allstate Applied Scientology Methods To Train Its Management." See also:

Other Church of Scientology corporate and professional recruitment "fronts" include Hollander Consulting and Sterling Management. Another Church of Scientology "front" is Narconon. Its primary treatment method is the often physically dangerous Church of Scientology "Purification Rundown" which, when done by either adults or children, involves spending much of the day, week after week, in super-heated saunas

while taking dangerously high doses of niacin and other vitamins and minerals. Criminon is another such Church of Scientology "front" group. See: The Narconon Story in Oklahoma" .

Scientology and violent global terrorism also intersect in Hamburg, Germany where Scientology’s largest European Scientology organization has long existed. Bin

Laden and Scientology also intersect in Toronto, Canada where Al Qaeda’s main location for the making of all of the counterfeit documents they used was apparently a mere 100 yards from the Church of Scientology’s main building or "Org." Indeed, the Scientology enterprise has been well known for sharing information with other terrorist organizations as well as with the CIA. Indeed, CIA agents have reportedly been seen entering and exiting foreign Church of Scientology "missions" and "orgs". Moreover, Scientology’s Nigerian lobbyist in certain matters involved with its attempt to destroy American Banker Bob Minton, Dr. Rilwanu Lukman, is the former secretary general of O.P.E.C. and its new President. As mentioned above, Middle Eastern arms dealer Adnan Kashoggi and his family are also involved with Scientology.

See and

The potential for Scientology electronic communications monitoring (through the Scientology WISE corporation "e-republic") of California and Florida governmental communications, is even more disturbing when viewed against the Scientologist- established Earthlink Internet Service Provider and Scientologist owned Executive Software. Indeed, the Government of Germany was openly concerned about the potential

for Scientology Internet "intelligence" monitoring through Microsoft’s inclusion of Executive Software components in the Windows 2000 operating system. Microsoft was forced to reveal its source codes in Germany and allow deletion of the defragmentation program inserted by Scientology’s Executive Software into Windows 2000; such was the Church of Scientology security threat as perceived by the German Government. It may be too late for the U.S. Federal and State Governments to protect themselves from such electronic infiltration, monitoring and misuse of America’s vital secrets.

Recently, when the State of Hamburg’s chief investigator of Scientology, former Hamburg parliamentarian Ursula Caberta, arrived in Clearwater, Florida, she was served with one of Scientology lawyer, Kendrick Moxon’s contrived lawsuits. Once, in my office, Moxon confronted her with a goose-step and Nazi salute. A transcript of the

enlightening July 15, 2000, Ursula Caberta/Lisa McPherson Trust Press Conference can be read on-line at$/Christian/Caberta1.htm. See generally: "Understanding the German View of Scientology" In fact, in early December 2001, the German Embassy sent the U.S. State Department a "Note Verbale" asserting immunity through sovereign immunity and requesting dismissal of the case. In fact, many openly wonder whether it is not too late to curb Scientology’s evil agenda, now that it has successfully infiltrated the information superhighway with global covert electronic "intelligence" monitoring of whomever and of whatever it wishes. Scientology’s "Fair Game" Policies and Procedures can then be used to "handle" persons involved in intercepted electronic communications of interest to the Church of Scientology and its various (false) front groups. See and

http://www/ paras. 144-207. In this regard, you are

urged to read an excellent although disturbing essay on related recent revelations: "Are players in the largest domestic spying case in U.S. history still at it?" http://www/

Indeed, the first media corporation targeted by Anthrax-laden mail was allegedly working on a story relating to Scientology’s insidious attempts at "ground zero" to economically benefit from the World Trade Center tragedy of September 11, 2001. In fact, during President Bush’s National Memorial Service in Washington's National Cathedral and repeatedly appearing at the bottom of the TV screen during the service, the Church of Scientology advertised, on the Fox News TV channel, an 800 number for "National Mental Health Assistance." This 800 number rang the Scientology Dianetics Center in Los Angeles. There was no mention of Scientology or Dianetics on the scrolling message under the President as he spoke. and

This was a particularly deceptive and despicable ride on President Bush’s coattails and a recruiting fraud upon our nation in mourning. The National Mental Health Association has publicly "Accused the Church of Scientology of attempting to recruit members under the guise of providing mental health counseling after [the September 11] terrorists attacks." (September 18, 1991).

On December 31,1993, Scientology "ecclesiastical" leader Captain David Miscavige said, during the videotape enclosed with this letter:

"As you all know, if we [the Church of Scientology] have any real enemy which must be dealt with it is the psyches and the reasons are simple. We work to save lives while they engage in practices that destroy lives. And from day one they have done everything in their power to stop us - lest they lose the millions they receive in government grants and pharmaceutical kickbacks on exchange for perpetrating the biggest fraud of the twentieth century.1993 was a very good year for us and a very bad year for psychiatry. In the year-end issue of their publication, The Psychiatric Times, they have a feature article and here is what the headline

says: ‘Scientology Receives Tax Exemption.’ Yes, and we are coming right after you.As we continue to remove suppression [opposition to Scientology] in society it is vital that we move in with the real tech. In fact, all of our actions would be for naught except that we ourselves do have the tech. That tech must however be applied." emphasis added

Mitch Daniels, current Director of the Office of Management and Budget, has unique Bush Administration experience with the Church of Scientology. It sued him personally - and his then employer Eli Lilly. Church of Scientology v. Daniels, 992 F. 2d 1329 (1993), cert. denied, _U.S. _. Eli Lilly’s best selling drug, Prozac, is a major and continuing target of the Church of Scientology, which believes that its "scientifically proven" tax-exempt "technology" and "religious artifact," the E-Meter, should replace the entire Mental Health profession and pharmaceutical industry. Mr. Daniels’ participated in an aggressive and successful defense and settlement of the case. As Mr. Daniels told USA Today, "Any vulnerable patient saved by psychiatry or therapy of any kind is one less potential victim for them [the Church of Scientology]" which he had also argued was driven by "crass financial motives." (emphasis added) Mr. Daniels is also receiving a copy of this letter and I urge you to discuss its contents with him. Indeed, his Office of Budget and Management (and the entire federal government) could surely use 1993 back taxes of approximately one billion dollars plus fines, penalties, interest as well as eight years of subsequent taxes, fines, penalties and interest.

Twenty-three years ago, just several weeks before being gunned down by another religious cult in Jonestown, United States Congressman Leo J. Ryan wrote to a friend of mine:

"Thank you for your very detailed letter regarding Scientology. We haven’t yet found a way to attack these jackals who feed on children and young adults who are too emotionally weak to stand by themselves when they reach the age of consent."

The recipient, this now 79-year-old Hemet, California grandmother, whose home is a mere five miles from the Scientology cult’s armed compound at Gilman Hot Springs, is regularly harassed, and her mobile home retirement neighborhood kept under blatant, intimidating surveillance, through both stationary and mobile car patrols, by roving

groups of private investigators hired by Scientology’s lawyers such as Moxon and Abelson. She now flies the Stars and Stripes daily at half-mast - in mourning of the loss of equal justice as well as in mourning of Scientology’s subversion of all three branches of our system of government, the Constitution and the Bill of Rights. Amazingly, this elderly woman, assisted by military veterans and other retirees, shows more courage against such domestic "psycho-terrorism" than do most of our much younger police, prosecutors, government employees and politicians. Like the three proverbial monkeys their constant mantra, often paid for or corrupted by Scientology special interest groups, is, "See no evil, hear no evil, speak no evil." Even The Los Angeles Times was shuddered into silence by the threat of litigation following the best newspaper investigation of Scientology ever written. See ttp://www/

L. Ron Hubbard himself saw the possibility that his clandestine takeover of the world and elimination of all governments, religions, corporations, media and individuals may not endure forever. He wrote:

"When you move off a point of power, pay all of your obligations on the nail, empower all your friends completely and move off with your pockets full of artillery, potential blackmail on every erstwhile rival, unlimited funds in your private account and the addresses of experienced assassins and go live in Bulgravia and bribe the police." emphasis added

L. Ron Hubbard, HCOPL 1967-02-12 "The Responsibilities of Leaders."

Bulgravia is one of Hubbard’s numerous acronyms. It refers to the geographic region of BULgravia, GReece, Albania and YugoslaVIA. Apparently, Hubbard considered the region to be easily infiltrated and corrupted.



The U.S. government has not always had its current, permissive attitude to tax-exempt Scientology domestic "psycho-terrorism," crime and fraud. In fact, under Presidents Nixon, Ford, Carter, Reagan and George H. Bush, the U.S. government

strongly, steadfastly and successfully resisted Scientology’s tax-free status because of the long history of such conduct as is described in this letter. The old IRS, FBI and DoJ were not even deterred by Scientology filing over 2,000 lawsuits against the U.S. government

and its individual employees. Indeed, some of the relevant legal cases are searchable on the Department of Justice Internet Web Site. However in 1991,

Moxon, through OSA staffer Ben Shaw, allegedly paid over one million dollars to a Maryland private investigator who then "investigated" I.R.S. Commissioner Goldberg. This and related information was uncovered by Doug Frantz, National Correspondent for The New York Times, who explained how he developed the leads and story in a speech to The Nieman Foundation For Journalism at Harvard University.

According to The New York Times, Maryland private investigators Thomas Krywicki and Michael Shomers (and others) were hired and spent 18 months gathering

information on IRS officials who missed meetings, drank excessively, had extra-marital affairs, etc. The Church of Scientology "investigation" was followed by a surprise, unannounced visit by Church of Scientology leaders David Miscavige and Mark ("Marty") Rathbun to then Commissioner Goldberg’s office. According to Mr. Goldberg’s then secretary, they

just barged in and showed him the results of their "investigation" of him, conducted through Moxon. There is widespread public and media speculation that the Scientology leaders brazenly blackmailed the IRS Commissioner. A new Scientology IRS Form 1023, approximately 100,000 pages long, was filed and dated August 18, 1993. Six weeks later, on October 1, 1993, the IRS granted retroactive IRS section 501(c)(3) tax-exempt status "… based on information supplied, and assuming [Scientology’s] operations will be as stated in [its] application for recognition of exemption." Subsequently, also under President Clinton, the IRS announced a sudden, 180-degree turn in IRS policy toward Scientology. Thus the 20-year Scientology "War Against The IRS" was over. Moxon and Feffer were publicly feted and honored at a 1993, Nuremberg-style Scientology rally. A videotape copy of this event is enclosed with this letter.

According to "Captain" Miscavige, his surprise visit to the IRS, and the subsequent IRS actions, saved Scientology from having to pay the IRS over one billion dollars. Captain Miscavige made particular note that even the Church of Scientology front group The Citizens For An Alternative Tax System, a political lobbying group intent upon abolishing the U.S. tax system, "…got full tax exemption." See generally: (The Wall Street Journal: "The Scientology Problem") and (The Wall Street Journal: " Scientologists and IRS settled for $12.5 million.") and ("Will IRS abuse investigations probe the IRS Scientology fiasco?").

New York Times Reporter Doug Frantz found that there was no one in Congress with the courage to investigate the IRS granting of tax exemption. "I had some contact with a staff member on Senate Finance, a guy who worked for Bill Roth, and he was really hot to go, and had one conversation with Roth and the thing was over. Nobody gave a damn." emphasis added There is another version of this event. According to Bryan Haney (who has financially supported some private research of these matters), he had spoken with a Bill Nixon, Senator Roth’s Chief of Staff, who had said to the Senator that hearings had to be held. Allegedly, Senator Roth refused because, "The Church of Scientology has blackmail material on me [the Senator]." Mr. Haney could confirm this matter. However, and partly as a result of Scientology’s investment fraud through a WISE company, Scientology entered into a "gag" settlement with Mr. Haney who now spends much of his time out of this country.

Consequently, the payments for Scientology’s "scientifically proven" processing and auditing, often costing in excess of one million dollars, are now fully tax deductible, contrary to the position taken by the IRS and upheld by the courts for over twenty years.

Hernandez v. Commissioner, 490 U.S. 680 (1988). There was a Department of the

Treasury Inspector General report (TIGTA 9-9801-0002) on these matters but F.O.I.A. requests for it have been denied along with requests for "additional investigative documentation both public and private which covers allegations both confirmed and suspected of blackmail, extortion, and other traditional racketeering activities instigated by the Church of Scientology which may have motivated the Closing Agreement". (FOIA ROI 8-901-0002, mentioned in IRS Press Release 31 Dec 1997, IR 97-50). In a November 27, 2001, response to Frederick L. Rice, the Inspector General for Tax Administration stated:

" A review of the TIGTA indices revealed that one (1) file is responsive to your to your request for a copy of TIGTA report "8-9801-0002 … TIGTA Report of Investigation (ROI) # 8 -9801 - 0002 consists of one hundred and twenty-three (123) pages. Sixty-two (62) of those pages constitute information which originated with the IRS; we are therefore referring those pages to the IRS for a release determination and direct reply to you."

Although the multi-volume IRS Form 1023 is publicly available, it is said that there is an entire room of IRS-Church of Scientology tax exemption documents, which are not publicly available. The Church of Scientology has repeatedly claimed that its new form 1023 application was subjected to the most rigorous review and inspection ever conducted by the IRS. However, the IRS review and inspection was not nearly as rigorous and comprehensive as it should and could have been. The Declaration of Andre Tabayoyon, a former Scientology Sea Organization staffer explains:

"148. In December of 1992, Miscavige directed that we hide a large number of sea containers of financial records relating to the Church and himself. The sea containers were to be hidden from the Internal Revenue Service ("IRS") IRS investigators were scheduled to visit the Hemet base to inspect the records of various Scientology organizations in connection with the IRS's investigation of the various church of Scientology entities that had applied for Section 501(c)(3) tax exempt status. (A sea container is a large transferable metal storage container, measuring approximately 40' x 8' x 8'6". These containers can be transported on flat bed trucks, flat bed railroad cars and container ships.)

149. The procedures for concealing the information contained in the sea container were set out in a written TRS handling program. It outlined the steps to be taken to secure the Hemet base and make sure that the IRS examiners did not see any information that Miscavige did not want the examiners to see.

150. There were a total of 20 sea containers involved in this concealment. We consolidated them down to 12 sea containers. I was also ordered to grade the land on which these containers had sat so that there was no proof of them ever having been there.

151. One of these sea containers of documents was mistakenly removed from the base unbeknownst to either me or Miscavige. At the time unused sea containers were being shipped from Gold base to their owners. Inexplicably, one of the sea containers containing concealed tax information was picked up and taken from the Gold base by the owner's employees who believed that the sea container was empty. When Miscavige learned that there had been a mistake in connection with the hiding of this sea container of financial documents, he was outraged. He flew into a tirade. He blamed me for the error and accused me of trying to destroy him. It ended up on a ship at San Pedro and was off- loaded before the ship's departure."

The Scientology "scientifically proven" claims have never been peer-reviewed by any independent agency. However, now the Scientology enterprise includes tax relief as part of its glossy incessant marketing. For example:

"Donations for most Scientology auditing and training services qualify for charitable deductions on your personal income tax returns…in some cases Uncle Sam will back you up-with up to 50c on each dollar-to go up The Bridge to full OT. Now that’s an offer you can’t refuse. Believe it or not, it’s true."

Church of Scientology marketing brochure received November 9, 2001 (U.S. Post Non-Profit Org Permit No.32280)

"Donations for most auditing and training services qualify for charitable contribution donations on your personal United States income tax returns. Donate before December 31 and you could SIGNIFICANTLY reduce the amount you need to pay in taxes for this year. This enables you to donate for more services and thus make it up The Bridge® grade chart FASTER! So make your income tax work for YOU in the best way possible, by using it to secure your tax-deductible SCIENTOLOGY© services now…Going up THE BRIDGE® is such a good idea, the US government will allow you to deduct your [fixed price] donations."

As is apparent from the 1994 declaration of Andre Tabayoyon above, (Reposted Classics #16, Declaration of Andre Tabayoyon), court-ordered discovery (of Church related financial and tax fraud) in the Church of Scientology v. Fishman -Geertz case threatened to unravel and expose Scientology’s one billion dollar tax fraud upon the U.S. Federal Government. I was the lead lawyer for the successful defense of the Fishman-Geertz defamation case. Apparently, the Church’s "Fair Game" Policies and Practices had to be employed to "utterly destroy" and neutralize the threat that I posed to the billion-dollar charade being played by Scientology and the compromised U.S. Federal Government. "Fair Game" is a once secret written Scientology Policy that was publicly exposed when the FBI simultaneously raided various Church of Scientology facilities in 1977. "Utterly destroying" a Church critic is required and how to do this is described in the Church of

Scientology "Fair Game" Policies and Practices. "Fair Game" is intended to terrorize critics and victims of the Church of Scientology into silence; to deter and disable any opposition or vocal criticism. Its purpose is to haunt, terrorize and shudder into silence, those with knowledge of the Church’s wrongs. As the documents seized by the FBI in 1977, demonstrate internal evidence of criminal activity by the Church and its members must be stored in the Church’s "Red Data Boxes" likely insuring its ready availability should it be needed for future "Fair Game" activities against would-be former adherents.

See and paras. 144-207 and and and

As you have read, the Church of Scientology’s "Fair Gaming" of me, and its use of influential attorneys engaged in demonstrably and directly related criminal conduct, has just culminated in my nine month suspension from active California legal practice.


A recent U.S. example of Scientology’s financial frauds and human abuse has just been swept under the carpet by yet another secret settlement agreement in the case of Lopez v. Church of Scientology Mission of Buenaventura, Los Angeles Superior Court Case No. BC 200852. See generally, and In essence, the Lopez case alleges that Scientology knowingly and intentionally defrauded mentally impaired Raul Lopez of over $1.7M during an eleven-year association with the church. In 1985, when he was 19, Raul Lopez had a head-on collision with a big-rig and suffered irreversible brain trauma. The brain trauma caused a nervous tremor as well as an inability to reason and interact with others. The accident resulted in litigation and a $1.7M settlement payment to Mr. Lopez. In 1987, Mr. Lopez stumbled upon the Church of Scientology at a Ventura County, California swap meet. The Church promised him that he would be cured of the tremor and would be his old self again if he purchased $30,000 worth of Scientology’s religious services including auditing on the E-meter. In 1971, it was held that:

"There is absolutely no scientific or medical basis in fact for the claimed cures attributed to E-meter auditing. Unfortunately the Government did not move to stop the practice of Scientology and a related "science" known as Dianetics when these activities first appeared… Had it done so, this tedious litigation would not have been necessary. The government did not sue to condemn the E-meter until the early 1960’s, by which time a religious cult known as the Founding Church of Scientology had appeared." U.S. v. An Article or Device "Hubbard Electrometer," 333 F. Supp. 357 (1971).

Over time, Scientology separated Mr. Lopez from his conservator and guardians, persuaded him to keep his financial payments to the Church a secret from them, surrounded him with church-associated professional advisors, took over every aspect of his life while lying to him and even persuaded him to "invest" $30,000 in the purchase of two Ostrich eggs. The two eggs hatched and later the two birds died. Needless to say, they never did make Mr. Lopez wealthy. In 1997, Mr. Lopez’s guardian sued the Church and its associated professional advisers. Typically, Scientology fielded an expensive army of legal talent that included then Los Angeles Police Commission President Chaleff who you have read about above in connection with my own matters. Supra, pages 25-86. At times, the Church’s expensive legal counsel was serving Mr. Lopez’s lawyers with a new court motion every day. They were hell bent on obstructing any adjudication of Church liability. However, several of the Church-associated professionals were being provided insurance funded defenses and indemnity. Apparently, faced with potential exposure to punitive damages, the various insurance companies tired of the scorched earth, never settle litigation style of Scientology and its lawyers such as Chaleff and New York lawyer Eric Lieberman, who you have also read about in connection with my own cases above. Supra, pages 25-86. Apparently, late last year, the various insurance companies forced a settlement of the case. This settlement enabled Chaleff to announce on December 11, 2002, that he had joined the Los Angeles City Attorney’s office which, as you have read above, then decided that the Scientology/Moxon/Abelson/Ingram, et. al., criminal conduct against me (in which Chaleff had also participated) should not be prosecuted. Supra, pages 56, 76-78. Indeed, there is much speculation, and numerous reports, that Chaleff is a Scientologist himself.

Recently, Scientology has not been faring as well against me in the civil courts as it once had. During the past year, Scientology has voluntarily dismissed three civil law suits against me on the eve of trial. As you have read above, on February 6, 2001, Scientology dismissed Hurtado v. Berry in the California State court. On July 10, 2002, Scientology dismissed Hurtado v. Berry in the Federal Bankruptcy Court. On January 17, 2002, a mere ten days before trial, Scientology moved to dismiss Barton v. Berry in Federal Bankruptcy court. As you have read above, the Scientology litigation juggernaut overwhelmed me in February 1999, and forced me to dismiss the Barton v. Cipriano, Barton, Miscavige, Ingram (Abelson, Moxon) cases. The Cipriano confessions had not been made at that time. Relying upon the undisclosed fraud upon the court, Scientology/Barton/Paul, Hastings obtained a $28,000 prevailing party costs order from their "friend" Judge Williams. After I filed for bankruptcy in June, 1999, Scientology/Barton/Moxon filed the Barton case as one of the three Bankruptcy Court Adversary actions to dismiss my bankruptcy and render the Moxon, Jeavons and Barton costs and sanctions orders ruled non-dischargeable. Indeed, the Federal Bankruptcy Court has ruled that the Moxon Rule 11 order of $28,000 in the Pattinson case and the Jeavons’ prevailing party costs order of $3,000 in the Jeavons case are non-dischargeable and must be paid by me to Moxon and the Church of Scientology. In Barton, Scientology was again seeking that I not be discharged in bankruptcy and that I be found guilty of bankruptcy fraud. Scientology had tried to settle the case with a tentative agreement that permanently prevented me from ever walking on the public street in Los Angeles, once called "Berendo Street" and now tellingly renamed "L. Ron Hubbard Way" after Scientology's founder.

Hubbard wrote, and Scientologists fervently believe, that, "What is true is what is true for you." In other words, if you believe that telling fabrications and lies to the court is the moral and proper thing to do if it protects Scientology &/or Scientologists, then it is the moral and proper thing to do (even if the rest of the world thinks that such behavior is immoral, outrageous, perjurious and illegal). According to the founder of Scientology L.Ron Hubbard, "That’s what producing, high-statistic staff members are -- kha-khans. They can get away with murder without a blink from ethics." However, this ecclesiastical mandate to lie and commit perjury was on a collision course with the January 28, 2002, trial date in Barton v. Berry. Objective reality "challenged" Scientology lawyers Abelson and Paquette filed a vitriolic Ex Parte motion to dismiss. Amazingly, the two Scientology lawyers wrote that, "Thus far plaintiff’s counsel [Abelson and Paquette] had kept the cost of this litigation down at Plaintiff’s [Barton’s/Scientology’s] request." However, the record amply demonstrates that in my no-asset bankruptcy Scientology employed the New York office of the giant national law firm of Paul, Hastings; the three lawyers of the Moxon & Kobrin, legal unit of OSA; the law firm of Bregman & Associates; and Elliot J. Abelson, additionally, they litigated the bankruptcy cases for nearly three years raising some questions about their use of the phrase, "… kept the cost of this litigation down!" Finally, ten days before a one-day trial, they decided that the case was no longer "economically viable." Scientology’s massive over-litigation and abuse of the judicial system was also documented and discussed in Church of Scientology v. Wollersheim, 42 Cal.App.4th 628, 648-649 (1996). Finding that Scientology had engaged, "…in a course of oppressive litigation conduct" the court stated that, "When one party to a law suit continuously and unsuccessfully uses the litigation process to bludgeon the opponent into submission, those actions must be closely scrutinized for constitutional implications." emphasis added. Costs of $500,000 were upheld against Moxon and others in this decision.

Moxon’s representation of Scientologist and CAN Reform Group member Isadore Chait, in the Berry v. Cipriano, Barton, Miscavige, Church of Scientology, Ingram (Abelson, Moxon) may have wider implications. Supra, pages 25-86. In the massive Slatkin (Scientology related) "ponzi" fraud (Supra, page103), the Trustee’s lawyers (Kirkland & Ellis) have prepared a chart illustrating how Isadore Chait and his family may have laundered Slatkin investor’s money through Art for Investment Services.

Scientology, through its World Institute of Scientology Enterprises ("WISE") may also have links to the Enron debacle. In that regard, it appears that at least one Enron natural resource joint venture is with a group of hi-profile members of WISE. Supra, pages 105 -107.

Interestingly, the government of Belgium is now implementing a new law that effects religious organizations. Not wanting to be subject to the new Belgian law, Scientology has argued that should not be treated as a religion or church in that country!

The German government has been engaged in the electronic surveillance of the Church of Scientology for a number of years. German government’s investigations have concluded that the Church of Scientology is a totalitarian terrorist group and commercial fraud masquerading under the false facade of religiosity. Supra, page 103. In 1994, the Church of Scientology sued the German State of Saarland "…for a restraining order against government observation using means of intelligence surveillance." The Saarland Administrative Court denied the Scientology lawsuit. In 1999, the Church of Scientology requested another injunction against the German government’s electronic monitoring. Relatively recently, it was again denied. The German court opinion included the following factual and legal conclusions:

"Defendant [the German government] observes efforts on the part of Plaintiff [the Church of Scientology] which are directed against a liberal democratic order. Efforts in this context … are politically determined, objective and purpose- orientated modes of conduct in or for a union of persons, which are intended to remove or invalidate one of the constitional principles listed in para. 2 of the aforementioned provisions…

The following elements are part of a liberal democratic order or system of government:

1. The right of the people to exercise the powers of state in elections and votes taken by and by means of special organs of legislature, powers of enforcement and jurisdiction and to elect the people’s representatives in general, direct, free, equal and secret ballots;

2. Committing the legislature to a constitutional order and committing the powers of enforcement and jurisdiction to statutes and laws in general;

3. The right to forming and exercising a parliamentary opposition;

4. The replaceability of the government and its responsibility to the people’s representatives;

5. The independence of the courts;

6. The exclusion of any form of rule by violence and arbitrariness; and

7. The human rights entrenched in the Basic Law, or constitution.

Based on these considerations, actual evidence giving rise to suspicions of unconstitutional efforts on the part of [Scientology] was correctly assumed by [the German government]. An evaluation of the available material shows that [Scientology] partly endorses objectives which militate against (Germany’s) liberal democratic political order.

For instance, the writings of [Scientology] contain sources indicating actual evidence giving rise to suspicion of efforts on the part of [Scientology] to abolish or restrict the human rights entrenched in the constitution along with other constitutional principles belonging to the liberal democratic order.

In concrete terms, inter alia, the following evidence was noted:

An evaluation of the available materials suggests that there is evidence that in a scientological society, rights (in particular, human rights but also civil rights) are not available to all members of the society (or at least not equally). In a significant number of works and statements, not everyone should be or is entitled to rights in general, civil rights or even the right to marry and "put children into this world." These rights are only to be made to "non-aberrees" or "honest" persons. The emphasis on the entitlement for a group of persons characterized in general terms defined by [Scientology] itself (cf. Exhibit B 17 and B 2) also means that persons not belonging to the group are not entitled to the same rights, or not to the same extent as the members thereof. …[evidentiary references omitted]

In addition, the materials also contain references to suspicion of efforts implying the abolition of other key constitutional principles belonging to a liberal democratic order.

There are references indicating that in a scientological social order the right of forming and exercising a parliamentary opposition does not exist. [Scientology] claims to have absolute control. This is reflected in attempts to eliminate any contrary or unlike ideologies and achieve total discipline; in particular, however, critics are dealt with ruthlessly. In a scientological society therefore, there is no room for opposition, let alone a parliamentary [or congressional] one. A dominant principle of [Scientology’s] ideology is to exercise a comprehensive form of control to prevent "misconduct" and "unethical behavior". Materials to justify this assessment include the "HCO Policy Letter" of July 22, 1982 (Exhibit B 12, p. 18ff.) and the "HCO Policy Letter" of February 13, 2965, corrected and re-issued on October 7, 1985 (Exhibit B 32)… By applying for membership of the IAS [the International Association of Scientologists]… the applicant declares that he or she will support the annihilation of all groups etc. which have the purpose of preventing the application of the Scientology technology and liberty for humankind (Exhibit B 4, ibid.). …

In addition, there are concrete references for the objective of abolishing the link of legislation to the constitutional order and executive force as jurisdiction to law and order.

The wording used e.g. in the HCO Executive Letter of March 19, 1965 (Exhibit B 27), in the Manual of Justice (Exhibit B 16, p. 2 and 3 ff.) give rise to suspicion that the Scientology organization wants to establish an own legal system applicable to all of mankind with own organizational norms without a guarantee of access to the courts and no guarantee of a legal hearing and without an administration established by law. The courts are not to be independent but will have to implement the detailed parameters laid down by the leadership of the organization (‘Scientology technologies’) … Moreover, in the ‘Manual of Justice’ (Exhibit B 16) the methods of arriving at justice are listed. Specifically, the manual contains explanatory notes on intelligence surveillance, examinations of evidence, sentencing or punishment and rehabilitation. Briefly, the following is worthy of emphasis: there are no references to independent courts, an intelligence service not bound to law and order investigates the circumstances and takes preventative measures; the guilt of a suspected person is proved by using an E-meter similar to a polygraph, or lie detector; vigilantism is called for.

… The presence of the characteristic of ‘political’ motivation within the scope of factual circumstances cannot already be negated simply because [Scientology] is no political organization (such as a party) and no other group that participates in political events … there are sufficient actual references to support the assumption that [Scientology] is making concrete endeavors to acquire political power and influence. This is deduced on the one hand from the Scientology’s ideology’s claim to absolute power, which not only relates to having possession of the sole and exclusive truth but also extends to include the personal (mental, emotional and spiritual) as well as areas in life relating to personal interaction and society in general. …

The lack of political motivation in terms of [Scientology’s] conduct cannot be said to prevail simply because [Scientology] considers itself a religious organization. Whether indeed [Scientology] is a religious organization is disputed in jurisprudence. The German Federal Labor Court … held that the Hamburg Scientology organization was no church. In particular, the reason for this was that it was the organization’s avowed aim to increase its assets with all ways and means possible. Religion and philosophy were merely a pretext. …[The court then describes two German Federal Administrative Court decisions finding that Scientology has religious links but leaving the issue of its religious status ‘open.’

Citing from a Hamburg OVG (Higher Administrative Court) judgment of 1994), the Court held that it could also leave the issue open of whether or not Scientology was a religion or whether ‘the teachings were only a pretext to operate for gain.’]

The relevant fundamental rights and guarantees, to the extent that they can be available to [Scientology] at all in view of Art. 19 par. 3 of the constitution, reach their limits where the fundamental rights of others or the liberal democratic order are affected. Accordingly, the assumption that [Scientology] also follows religious or philosophical objectives does not militate against the political orientation of its conduct either. …

According to the ‘Hubbard Directive of March 13,1961’ (Exhibit B 9) a Department of Government Affairs is to exert constant pressure on governments to create a pro-Scientology legislative environment and prevent anti-Scientology legislation from groups opposing Scientology. In addition, this writing contains a description of how this objective can be achieved.

Moreover, there are references indicating that it is the objective of [Scientology] to systematically integrate the "Clear campaigns" in key positions in society (justice, administratation, politics, business etc.) of a country. Plans of [Scientology] to conduct such campaigns in Germany in the past are detailed in the ‘Final Report of the Workgroup Scientology of the constitutional protection authorities on the observation of the Scientology organization by the constitutional protection authorities’. …

The political orientation of [Scientology’s] efforts is already apparent in the above-mentioned HCO Executive Letter of March 18, 1965, in which reference is made to an expansion into society, that society will ‘move under our influence’ and even that it will be possible by expanding to achieve that highest sovereignty.

[Scientology’s] objectives as outlined above, which represent references of points of evidence of anti-constitutional efforts, are also supported by all those active on behalf of the organization and, therefore, are attributable to [Scientology].

… the Scientology organization is hierarchically structured on a centralized basis. (Citations omitted). The fact that members of [Scientology] identify with the objectives of Scientology is clear … Accordingly, any innocent person can become a member of the church. The basic condition for acceptance is a self-declared acceptance of the objectives and beliefs of the Scientology religion and the applicant’s willingness to promote these within the directives and guidelines of the church. A precondition for such membership is that the person must be in good standing in the church of scientology, i.e. the applicant must neither actively attack the objectives, the actual worship of the religion of Scientology nor any institutions of church thereof nor support or endorse such attacks. The member must make a declaration to this effect when joining the organization. On acceptance, the member is expected to make a positive contribution to the objectives and tasks of the church in order to remain in good standing in the future. It follows from this that the devotees and members of [Scientology] are to be attributed to the organization’s activities and objectives as their orientation is based on [Scientology’s] programs, and they must subject themselves to the latter.

The court upheld the government’s continued electronic surveillance of the Church of Scientology because of the threat it poses to democracies around the world. Accordingly, it is reasonable to think that those Americans supporting Scientology should be treated in the same manner as those Americans who supported the Nazis before and during World War II, the Communists during the Cold War, and Taliban-adherent John Walker. Such people were and are shunned and scorned for supporting those who would harm our democratic way of life. Charles Lindberg became a pariah for supporting the Nazis. The Rosenberg’s became pariahs for assisting the Russian communist regime. John Walker is a pariah for supporting the Taliban - in the name of both American religious freedom and of global rule by radical Islamists. It is not outrageous to assume that Greta Van Susteran, Tom Cruise, John Travolta, Reed Slatkin, Sky Dayton, Donald Pearson, Gerald Chaleff, Eugene Ingram, Kendrick Moxon, Sam Rosen, the Paul, Hastings and Williams & Connolly law firms, and all of the other Scientology celebrity spokespersons, financiers and mercenaries should be treated equally and in exactly the same manner as we have and are treating those who intend to subvert our freedom. Whether or not they knew, before now, of Scientology’s dark and secret side is irrelevant, they must now be deemed to know. Moreover, their protectors and apologists, such as Pat Kingsly, Bert Fields and Michael Ovitz should assume the responsibility to ensure that the celebrities who they represent are able to make fully informed decisions whether or not to remain in Scientology and whether or not to continue to support what is clearly, at the very least, treason, sedition and genocide.

These matters can no longer be ignored by the United States Federal Government as being mere expressions of First Amendment freedoms. However, the truth is that the our Federal Government is ignoring these matters and has done so for at least the last ten years.

"I want to know. Where is our government?" demanded Toby Plevin, a Los Angeles attorney who once represented victims (of Scientology). "It shouldn’t be left to private litigators, because God knows most of us are afraid to get involved." Because of her willingness to represent their victims, Scientology engaged in constant and horrific "psycho-terrorism" directed at the late Los Angeles attorney Toby Plevin who was quoted in the Time Magazine exposé. Eventually, Ms. Plevin became so terrified that she stopped being willing to appear in litigation against the Church of Scientology. However, her desperate public plea for a Federal Governmental investigation still rings as loudly and as clearly as it did ten years ago. As Ms. Plevin said then, and countless families and victims have said since, " Where is our government?" Must we await another Jonestown, Waco, Heavensgate or September 11?

Law-enforcement agents are also wary. "Every investigator is very cautious, walking on eggshells when it comes to the church," says a Florida police detective who has tracked the cult since 1988. "It will take a federal effort with lots of money and manpower." (emphasis added) "Scientology: The Thriving Cult of Greed and Power," Time Magazine, May 6, 1991, page 50.

On January 20, 2002, you appeared on CNNs "Late Edition" with Wolf Blitzer and spoke of terrorists as being dangerous individuals determined to destroy our way of life. The request for immediate action herein concerns individuals and entities just as dangerous to our democratic way of life as the Taliban. What is described above is American homegrown terrorism. These "psycho-terrorists" and "litigation terrorists" must be properly and immediately investigated. All appropriate action must be taken irrespective of the various participants being lawyers, prosecutors, public officials and judges. As you also stated on the same "Late Edition", " Justice has to be antiseptically clean in the way it operates and is achieved." However, in the matters described above, justice has been hijacked and raped with impunity either by or before public officials in all three governmental branches. Thus, it should hardly be surprising that we Americans are thought to be hypocrites throughout much of the world. It is time we remembered and returned to the concept of equal justice practiced upon a level playing field that the founding fathers incorporated into our Constitution and our institutional framework.


This complaint and requests, as described below, involves individuals, entities and facts that the U.S. Department of Justice has already successfully prosecuted. As the inimitable Yogi Berra has said, "This is déjà vu all over again." Therefore, it goes without argument that the Church of Scientology has not been rehabilitated as it so strenuously, but fraudulently set forth in the Church of Scientology IRS Form 1023 submitted August 18, 1993. The numerous fraudulent representations and serious breaches should be cause enough for review of the 1993, Secret IRS-Church of Scientology Closing Agreement. Interest, penalties and fines on over one billion dollars should be a public duty of the Administration to recover and for the Congress, the Senate and media to insure that it does so. Indeed, over the past seven years, many dozens of complaints

have been mailed to Mr. Jay Rotz, Executive Assistant, Exempt Organizations Division, Department of the Treasury, Internal Revenue Service, Washington, DC. He has been a responsible supervisory IRS official during the Church of Scientology corruption of the Clinton Administration and the IRS and has remained in the role ever since. Interestingly, the FBI records on L. Ron Hubbard, the founder of Scientology, date back to the mid 1940’s.

Moreover, Moxon, Kobrin, Paquette, Abelson, Rosen and Ingram have consistently alleged that their activities directed against me are to protect the Church of Scientology from harassment. However, Moxon, Kobrin, Paquette, Abelson, Rosen and Ingram know, or ought to have known, that this defense was resoundingly rejected in U.S. v. Kattar, 118,126 (1988 1st Cir.), where the US Department of Justice Sentencing Memorandum was incorporated into the Court’s opinion as follows:

"The defendants’ [the Church of Scientology’s leaders] contention that they committed the crimes of which they stand convicted in order to protect their church from government harassment collapses when one reviews a sample of the remaining documents seized by the FBI during the execution of the two Los Angeles search warrants. If anything, these documents establish beyond

question that the defendants, their convicted codefendants, and their unindicted co-conspirators [which expressly included Commodore Hubbard and current Scientology counsel Kendrick L. Moxon, Esq.], as well as their organization [the Church of Scientology], considered themselves above the law. They believe they had carte blanche to violate the rights of others, frame critics in order to destroy them, burglarize private and public

offices and steal documents outlining the strategy of individuals and organizations that the church had sued. The church filed these suits for the sole purpose of financially bankrupting its critics and in order to create an atmosphere of fear so that critics would shy away from the First Amendment Rights secured them by the Constitution. The defendants and their cohorts [such as unindicted named co-conspirator Moxon] launched vicious smear campaigns, spreading falsehoods against those they perceive to be enemies of Scientology in order to discredit them and, in some instances, to cause them to lose their employment ... To these defendants and their associates, however, anyone who did not agree with them was considered to be an enemy against whom the so-called ‘Fair Game’ doctrine could be invoked...’ (emphasis added) ‘... It is interesting to note that the founder of their

organization, unindicted co-conspirator, L. Ron Hubbard, wrote in his Modern Management Technology that, ‘ ... truth is what is true for you,’ and ‘illegal’ is that which is, ‘contrary to Scientology policy’ and not pursuant to Scientology's ‘approved program.’ Thus, with the Commodore's blessing they could

wantonly commit crimes as long as it were in the interests of Scientology. These defendants rewarded

criminal activities that ended in success and sternly

rebuked those that failed. In view of this, it defies the imagination that these defendants have the unmitigated audacity to seek to defend their actions in the name of religion." emphasis added





I trust that, unlike your most immediate predecessor Hon. Janet Reno, you will understand what needs to be done. As set forth on page one, this is a request for action, criminal complaint, civil rights violations complaint, hate crimes complaint, request for criminal investigation, request for grand jury proceedings and vigorous criminal prosecution against persons and entities including, but not limited to: "Captain" David Miscavige; Mark "Marty" Rathbun; the Church of Scientology International Office of Special Affairs and certain of its employees and agents including: CSI-OSA chief Michael Rinder; Lyn Farny; Eugene Ingram; Kendrick L. Moxon, Esq., Helena Kobrin, Esq., Ava Paquette, Esq., Elliot Abelson, Esq., William T. Drescher, Esq., Samuel D. Rosen, Esq., Gerald Chaleff, Esq., Donald Wager, Esq., Miguel Hurtado and Michael Hurtado. Supra, page 1 (6).

In addition, inter alia, it is a request for a broad ranging Department of Justice, Department of Treasury and Congressional investigation into these and related matters including the suspicious circumstances surrounding the Church of Scientology’s sudden and fraudulent one billion dollar tax windfall from the Clinton Administration in 1993. A number of those involved are listed herein. Supra, page one (7).

The Constitution only protects religious beliefs held in good faith. It does not protect criminal conduct, criminal policies and practices and civil torts, whether religiously motivated or not. See generally, Molko v. Holy Spirit Ass., 46 Cal.3d 1092 (1988)

In that regard, I note that an Internet petition has gathered nearly one thousand verifiable signatories demanding an immediate Department of Justice investigation into the alleged and demonstrable criminal activities, human rights violations, civil rights violations and financial frauds being committed by the Scientology enterprise and its agents. In addition, I understand that other members of the public are also communicating with you and making requests similar to those as are made in this letter.


The evidence regarding the matters which are the subject of my own personal criminal and other complaints, request for grand jury proceedings and request for criminal prosecution clearly exceeds both the "probable cause" indictment standard and the "beyond reasonable doubt" conviction burden and standard of proof applicable to these R.I.C.O. and other criminal matters. Similarly, with respect to the request for investigation of the criminally procured Scientology tax-exempt status and other abuses, the evidence also exceeds the low "probable cause" standard, particularly upon the more relaxed rules of evidence (including "hearsay") applicable to preliminary hearings and indictments. In addition, the evidence meets the objective standard of proof that would be applied in the International Court of Justice in connection with the Church of Scientology’s "psycho-terrorism" and crimes against humanity. Certainly, the evidence meets the "show me" standard of another great man from Missouri!

On July 3, 1986, I was one of the 250 specially honored new U. S. citizens who were sworn in on Ellis Island as part of the Statute of Liberty celebrations. Presidents Reagan and Mitterand relit the statue. Minutes before, U.S. Attorney General Edwin Meese moved my admission as a American citizen. Then, Chief Justice Warren E. Burger administered the oath of allegiance immediately before the statue was re-lit. It was an unforgettable experience. Standing in the shadow of Lady Liberty, illuminated in red, white and blue, I believed with all my heart that this was the land of liberty, of equal justice and of constitutional protections. Indeed, I had even observed President Nixon having to painfully acknowledge these truths. The experiences, nay the nightmare that I have described above, have tarnished the luster of the contract of protections, responsibilities and allegiance that I had entered into with my new country of citizenship on that July third surrounded by the pomp and pageantry of that great celebration and national recommitment to the ideals that the Statue of Liberty. However, to paraphrase Anne Frank, I believe that somewhere there are still good people of good will and integrity who will stand up and be counted when confronted by evil, corruption and

wrongdoing. Accordingly, I trust that my faith in you, in the United States Department of Justice and in the current Administration is not misplaced. The matters of which I write do not concern me alone; rather they also concern the shattered dreams and families of countless people both in the United States and around the world. Those people also look to you and the Department of Justice to do the right thing. Indeed, in announcing your nomination as U.S. Attorney General, President George W. Bush stated that you are, "A man of deep convictions and strong principles."

Finally, in response to those judges, lawyers and public officials who have allowed themselves to be corrupted by the Scientology enterprise, I paraphrase Benjamin Franklin who in 1784, said that those who give up another’s, "… essential liberty to obtain a little temporary safety for themselves, deserve neither liberty nor safety themselves."

Very truly yours,


Graham E. Berry




1. Compact Disc containing:

(a) Law Enforcement. Ashcroft. Hyperlinked copy of this letter for ease of Internet access and review.

(b) Authdecl. Copy of a declaration of Graham Berry describing some of the 1993-1997, documentary evidence herein. It attaches 147 exhibits.

(c) Chronology. Copy of a partial chronology of events herein and reference to supporting evidence.

(d) heber hat pack. Copy of the Job description of the President of the Church of Scientology International, Heber Jentzsch. It is criminal manifesto.

(e) frank oliver. Copy of the Job description Church of Scientology Intelligence Officer. It is also a criminal manifesto.

(f) Pattinson. Copy of the March 17, 1999, Declaration of Michael Pattinson describing his experiences in the Church of Scientology and it’s religious de-programming of his "other" [Christian] beliefs (para. 113).

(g) Moxon. Copy of various Internet documents relating to the Church of Scientology’s lead in-house lawyer Kendrick L. Moxon, Esq.

(h) Ingram. Copy of various Internet documents relating to the Church of Scientology and Moxon & Kobrin’s chief private investigator Eugene Ingram.

2. Letter and criminal complaint, etc. dated November 29, 2001, from Arel Lucas to Hon.

John Ashcroft. (frank oliver)

3. Letter and criminal complaint, etc. dated January 7, 2001, from Michael Pattinson to Hon. John Ashcroft.

4. Scientology: Thriving Cult of Greed and Power, May 6, 1991.

5. David Miscavige IAS speech, 8 October 1993.

6. David Miscavige Tape Summary New Year Event - 1993/1994.

7. Videotape: David Miscavige New Year Event 1993.

8. Scientology is a criminal organization, Internet, January 13, 2002.

9. Is Scientology Breaking the Law? Internet.

10. Why Are These People Dead Scientology?

11. ARD (Germany), April 2, 1997, Die dunkle Seite von Scientology

11. Don Wright/Palm Beach Post.

12. Knowledge Report to Church of Scientology Ethics Officer Chuck Anderson from Denise Licciardi, the Marketing Manager at Digital Lightwave. This company pays license fees to the Church of Scientology through the World Institute of Scientology Enterprises. As a result of her Knowledge Report, Church of Scientology International or Religious Technology Center could raid the company ("fire in a mission") impose fines, impose changes or even close the company down for alleged misuse of the licensed Hubbard Administrative Technology (which is also within the Hubbard Religious Technology).

13. Anatomy of Scientology, A Psycho - political terrorist organization.

14. Alison H. Eaton, Can The IRS Overrule The Supreme Court?

15. [week in review] A.r.s Week In Review - 12/16/2001 NB. "Affidavit of Kennan G. Dandar, Esq., Reply Memorandum of Robert S. Minton and Germany.

16. Copy, letter, Arel Lucas to Arianna Huffington, dated March 14, 01.