CULT LAWYER KENDRICK MOXON AND LEGAL NEMESIS GRAHAM BERRY SUE EACH OTHER OVER A TEN YEAR OLD CASE

 

NEWS  ARCHIVE
BERRY ALSO GOES EX PARTE - NEW DOCUMENT - Ex Parte Restoration Application

March 2010
MOXON GOES EX PARTE - GRAHAM BERRY'S COMMENTS HERE
NEW DOCUMENTS
 Kendrick Moxon Ex Parte Application for Order Staying Cross-Complaint 		Ex Parte documents are treated as a legal "emergency." Which is what Scientology Lawyer Kendrick Moxon had on his hands when at 8:30 AM Monday 3/22 he filed this attempt to stop Graham Berry from deposing him.
Kendrick Moxon Declaration in Supportof Ex Parte Application Tab E - Robert Jeavons v.Church of Scientology, Tab F - Order Finding Graham Berry Vexatious, Tab G- Transcript Graham Berry V. Robert Cipriano, Tab H - CA State Bar Suspension of Graham Berry
Graham Berry's Opposition to Ex Parte Application by Kendrick Moxon Memo of points and authorities, introduction, Summary, Declaration of Graham Berry, Exhibit A - Cross Defendant's Opposition to to Request for Finding of Contempt, Exhibit B - Judge William F. Fahey Denial of Request, Exhibit C - GB Revised Reply in Support of Request to File New Litigation,
Berry Opposition to Contempt Request Graham states that because fellow lawyer Barry Van Sickle is also on the case he is not in contempt for the reasons Moxon alleges.
Motion to Compel Moxon Deposition & Waive Privilege Part  A Graham argues that the legal laundry list of evil Moxon has done over the years is in evidence. Therefore Moxon should be compelled to be deposed. This has never happened before to Moxon. Also, he would be unable to claim attorney/client privilege. Memo of Points & Authorities, Plaintiff Moxon refused to attend his noticed deposition & should be ordered to attend & produce, Crime fraud exception to attorney client privilege applies, attorney client privilege has been waived, info sought is relevant to impeachment, Conclusion, Declaration of Graham Berry
Motion to Compel Moxon Deposition & Waive Privilege Part  B Berry Declaration, Authentication of Exhibits,  "Meet and Confer" events, Additional Matters of General Relevance.  Documents Demanded:  Anything Moxon did or wrote about any of the participants in the various cases in question.
Motion to Compel Moxon Deposition - Exhibits A-E Exhibit A - Deposition Notice for Moxon, Exhibit B -  Email from GB to KM, Exhibit C - Email from GB to KM, Exhibit D - Letter from GB to KM re: why cult protesters like the Angry Gay Pope must be forced to attend deposition yet he does not?, Exhibit E - Letter from KM to GB confirming their argument the day before.
Motion to Compel Moxon Deposition -  Request for Judicial Notice A list of 19 exhibits filed along with the motion to compel Moxon to testify under oath.  These are the same exhibits as listed under Appendix No. 1 Exhibit A and are not duplicated here.
Proposed Order to Compel Moxon's Testimony If the judge sign this order then Moxon must appear by May 28, 2010 to be deposed without attorney client privilege and must bring many documents.
Kendrick Moxon Contempt Request Against Graham Berry Moxon files a Request for Finding of Contempt Against Graham Berry for Filing Amended Cross-Complaint. Charges Graham with filing his cross-complaint before the court allowed him to, not withdrawing it, and amending it to make it even longer. He is attempting to re-try many previous cases that are ten years old.  This document appears to have errors. It appears Moxon no longer even reads the sections he cites, which only apply to the pro se and not the represented, which Graham is now.  No where does the cross-complaint suggest that it is a first amended. It was signed by counsel and 391.7 only applies to pro se litigants (people without counsel).
RELATED CASES PULLED IN:  By pulling in multiple previous Scientology cases Graham is lining them up like dominos to show Moxon's legal harassment over time. The goal is to show a pattern of racketeering and get the cult on RICO.  From CA State Superior Court (LA) Graham Berry v. Robert Cipriano (case# BC 184355), Berry v. Glenn Barton, et al. (case# BC 186168), Berry v. David Miscavige (case# BC 196402). From U.S. District Court (LA) Michael Pattinson v. Scientology Intl., et al. (case# CV 98 3985 CAS) plus several other cases. Graham also believes there is analogous crime/fraud issues in Wollersheim v. Scientology.
JUDGE REJECTED:  This trial is in State Superior Court. Graham is allowed to reject one judge. He immediately rejected Judge Fahey (incompetent and possibly biased) in Dept. 78.  The case has been reassigned to Judge Rolf M. Treu, Dept. 58. . In California every party to a law suit gets one automatic challenge to the assigned judge. After Judge Fahey ruled against Graham’s request to file a new law suit challenging the court orders Kendrick Moxon obtained with crime and fraud, and faxed the denial one day before Graham’s automatic disqualification expired, Graham exercised his peremptory challenge against Judge Fahey. Now Moxon has a chance to reject this judge.
VAN SICKLE ON CASE: Appellate lawyer Barry Van Sickle has joined Graham's case. Because Berry is currently a vexatious litigant his right to file court documents regarding himself are limited.  Van Sickle's name on the case removes this limitation. Barry has worked with Graham fighting Scientology before and currently represents Marc and Claire Headley.
Graham Berry First Amended Answer & Cross Complaint Unverified Answer & Verified Compulsory Cross-Complaint to set aside orders and judgments - Filed 03/09/2010. Sums up case from Berry's point of view. Exhibit A - Recent fair gaming of Berry by Moxon to Australian national media in Feb. 2010, including a list of fees assessed against Berry, Order finding GB vexatious, Article LA Daily Journal 2002 Disciplinary Action, Berry Law Suspension 2002.