Henson on Berry communications. -- Subpoena
28 Jul 2001
GRAHAM E. BERRY (SBN 128503)
ATTACHMENT "A" TO
3384 McLaughlin Avenue
Los Angeles, CA 90066
Telephone: (310) 745-3771
Facsimile: (310) 745-3772
Respondent Pro Per
THE STATE BAR COURT
OF THE STATE OF CALIFORNIA
HEARING DEPARTMENT - LOS ANGELES
In the Matter ofGRAHAM EDWARD BERRYNo.128503A Member of the State Bar ))))))))))))))))) Case No.: 99-0-12791ATTACHMENT A TO SUBPOENA DUCES TECUM ISSUED BY PARTY- RESPONDENT GRAHAM E. BERRY AND BEING HIS FIRST DEMAND TO PRODUCE DOCUMENTS, RECORDS, BOOKS OR THINGS DIRECTED AT THE CUSTODIAN (S) OF DOCUMENTS OF DONALD R. WAGER AND THE LAW OFFICES OF DONALD R. WAGER (Numbered 1- 7)
RESPONDENT, GRAHAM EDWARD BERRY ("Berry"), hereby propounds his Demand to Produce Documents, Records, Books or Things, Set No. One, to the Custodian (s) of Documents of Donald R. Wager and the Law Offices of Donald R. Wager ("You" as defined hereunder). This Request for Documents, Records, Books or Things is propounded, inter alia, pursuant to C.C.P. §§ 94, 1011(a) - 1013 (a), 1987.3, 2016 to 2031 (specifically § 2020 (d)), Cal. Evidence Code § 1560 (e) and Rules 151 to 187 of the Rules of Procedure of the State Bar of California. Inspection and copying of the documents, records, books and things produced in response to this request shall take place on August 15, 2001, at 10:00 a.m. at the offices of Donald R. Wager, 10100 Santa Monica Boulevard, 8th Floor, Los Angeles, CA 90067, or as may be noticed by amended notice and/or a letter agreement signed by both the propounding and responding party (s); e.g. to adopt the provisions of C.C.P. 2020 (d) (4).
(mass snip boilerplate)
REQUEST FOR PRODUCTION OF DOCUMENTS
1.All documents and communications relating to or referring to Michael Hurtado, including but not limited to those that refer or relate to, or concern in any way Graham Berry, Jenny Berosteguy, Eloisa Gonzales, Miguel Hurtado, Ana Marina Hurtado, Jason Whitman, LA Youth Center, Anthony Apodaca, Detective Petz, Deputy D.A. Paul Turley, Deputy D.A. Norm Wakener, Erla Hawkins, Mariah Rivera, DA Investigator Kevin Freeth, Wesley Berosteguy, Antoine Hage, MD, Robert Cipriano, the Church of Scientology, Eliot Abelson, Kendrick Moxon, Helena Kobrin, Ava Paquette, Samuel Rosen, Barbara Reeves, Michael Terrill, Bradley Pauley, Gerald Chaleff, Thomas Byrnes, Donald Wager, Michael Gerner, Eugene Ingram , and the various criminal prosecutions and civil lawsuits involving Michael Hurtado.
2.All documents and communications that refer or relate to payments made to or for any and all persons, received from any and all persons and entities, including but not limited to lawyers, businesses, private investigators, investigators, surveillance personnel and surveillance, in connection with or relating to Michael Hurtado, the representation of Michael Hurtado, Miguel Hurtado, Anthony Apodaca (and all jail receipts and other documents relating thereto), and Graham Berry.
3. All documents and communications that refer or relate to the Church of Scientology International, Moxon, Bowles, Farny and Ingram "investigation" of Graham Berry that commenced in late 1993 and early 1994 including but not limited to all photographs, phone tap logs, audio and video recording machines or devices, and all other related documents, books, records and things.
4. All documents and communications that refer or relate to communications with any international, national, federal, state or local government entity, supervisory and /or professional organization (including national security [e.g. the German government Office (s) for the Protection of the Constitution], security, law enforcement entities and their representatives) bar associations and law societies, professional organizations, media, entity or person (s) relating to Graham Berry .
5. All documents and communications, including but not limited all transcripts (deposition, hearing and other), that refer or relate to any of the allegations, contentions, defenses and/or causes of action set forth in any of the original or amended complaints, responsive pleadings, discovery requests, discovery responses, motions, dismissals, appeals, submissions to the Court (s) or Special Master/Referee in the consolidated cases principally captioned Berry v. Cipriano, Barton and Miscavige [LASC Case Nos. BC 184 355, BC 186 168,BC 196 402, USDC CD CA Case No. 98, CV 8097 AHM] and Berry v. Rosen [LASC Case No. BS 051330].
6.All documents and communications that refer or relate to Hurtado v. Berry, LASC Case No. 208 227 and USBC CD CA Case No. LA 99-32264 ER/Adv. No. AD 99-02559 ER.
6.All documents and communications that refer or relate to In re Graham E. Berry, USBC CD CA Case No. LA-99-32264 ER and all adversary, motion and collection proceedings filed in connection therewith including, whether in the federal or state courts, including but not limited to Moxon v. Berry [LA 99-32264/Adv. 99- 02615 ER], CSI [Jeavons v. CSI], Barton v. Berry [Adv. 00-2817-ER], Benkozcy v. Berry [USDC LA 99-32264 ER and LASC Case no.99- AO1528], and all purported creditors including but not limited to CSI, Michel Reveillere and Isadore Chait.
DATED: July 26 2001
Graham E. Berry
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