Berry Letters Gerner
15 Aug 2001
GRAHAM E. BERRY
3384 McLaughlin Avenue
Los Angeles, CA 90066
Phone: (310) 745-3771
Fax: (310) 745-3772
August 14, 2001
By Fax: (310) 772-2207
Michael G. Gerner, Esq.
10100 Santa Monica Boulevard
Los Angeles, CA 90067
Re: STATE BAR v. BERRY, Case No. 99-0-12791, Complainants: Michael Gerner, Esq., and Donald Wager, Esq.
[Real Parties In Interest: Church of Scientology International Office of Special Affairs; Kendrick L. Moxon, Esq.; Helena Kobrin, Esq.; Ava Paquette, Esq.; Elliot Abelson, Esq.; Samuel D. Rosen, Esq.; Donald Wager, Esq.; Thomas Byrnes, Esq.; Eugene Ingram]
Dear Mr. Gerner:
You have untimely served motions to quash subpoenas duces tecums served upon the Law Offices of Moxon & Kobrin, Elliot J. Abelson, Michael G. Gerner and Lenske, Lenske & Abelson. No motions, timely or otherwise, have been served on behalf of the individually served and named Kendrick L. Moxon, Helena Kobrin, Ava Paquette, Elliot Abelson, Michael Gerner and Sherman D. Lenske. No appearance has been made on behalf of any of these individuals. By copy of this letter, I request letter notification by them and you, no later than 5 pm on Friday, August 17, 2001, of a date and time for a telephonic "meet and confer" as required by State Bar Rule of Procedure Rule 185 (a).
On another note, it has been brought to my attention that Kendrick L. Moxon, Esq., continues to be involved in the obstruction of justice and directly in connection with these and other pending matters. This time through Sandee Oglivie who is also named in certain of the discovery requests. The matter is being appropriately referred.
I assume that your fees and costs are being paid by either the Church of Scientology International Office of Special Affairs or its litigation and harassment funding vehicle the International Association of Scientologists. Accordingly, I urge you to remind the church, and its individual officers and directors, of their continuing defaults under California Corporations Code Sections 35000 - 35302 ("the Subversive Organization Registration Law"). If you wish, I shall set forth the passages of scientology "scripture" directed at "clearing the planet", or taking over both the United States and the world by force and violence. Surely, you would agree that "force and violence" would include the confinement, internment and extermination ("quietly and without sorrow") of the estimated 2 ½ % (sixty million-many more than Hitler's six million) of the world's population, who Hubbard/the church believe will remain opposed to the church's take over of all of the "heads of government, business, media." and therefore must be rounded up and eliminated so that the church may rule all aspects of life on this planet and throughout this sector of the galaxy! At the very least, Sherman D. Lenske, Esq., would appear to be in continuing violation of these provisions of California law. Of course, the involved attorneys should also consider the relevance of State Bar Act (Business & Professions Code) section 6064.1.
I await your response.
Very truly yours,
Terrie Goldade, Esq. Augustin Hernandez, Esq.
Deputy Trial Counsel The State Bar of California Office of the Chief Trial Counsel Enforcement 1149 South Hill Street Los Angeles, CA 90015-2299
Kendrick L.Moxon, Esq. Helena Kobrin, Esq. Ava Paquette, Esq.
Elliot J.Abelson, Esq.
Sherman D.Lenske, Esq.
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