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GRAHAM E. BERRY

ATTORNEY & COUNSELOR AT LAW

3384 McLAUGHLIN AVENUE

LOS ANGELES, CA90066

Telephone and Facsimile: (310) 745-3771

Email:

September 13, 2008

BY FAX AND EMAIL

MEET AND CONFER LETTER

Kendrick L. Moxon, Esq.

Moxon & Kobrin

3055 Wilshire Boulevard, Suite 900

Los Angles, CA 90010

Re: Lewis Miranda and Lissa Uvizl v. REDACTED, L.A.S.C. Case Nos. BS 11639 and BS 116340.

Dear Mr. Moxon:

Reference is made to your letter dated September 12, 2008 regarding your refusal to present your clients for their duly noticed depositions in these matters.

I shall address the contents of letter in the same order as they appear in your letter:

1. If there are no documents to produce (which I doubt), or if you have valid objections, then the proper response is serve the proper notice of objection;

2. As for your ad hominen attack upon me, you know, and the world knows, that you secured all of which you write with bribery, blackmail, perjury, obstruction of justice, frauds upon the courts and several compromised judges (one even engaged to an employee of your office within Scientology). There are a trail of over 50 documents in your own handwriting, the incriminating deposition testimony of the participants (including a lawyer), the observations of two judges damning the conduct of both you and Ms. Paquette, an L.A.P.D. six month investigation recommending your indictment, and a District Attorney’s letter recommending an F.B.I. investigation of your conduct. Your organization’s on-going public corruption blocking that will not last much longer. The truth always comes out eventually. Incidentally, I stipulated to the nine month actual suspension rather than spend two years fighting and appealing. At that time my mother was dying of cancer and my family needed my assistance. It was more important to me that I help ease my mother’s pain and passing than to fight your shills at the State Bar. After she died I returned to active legal practice. As I wrote above, what was done then by your, your associates, accomplices, shills and surrogates (including Judges Alexander Williams and Judge Snyder) is now in the process of being fully exposed. Even your office and its Operation Snow White can no longer keep the evidence and complaints from action by law enforcement, the administration and congress. The involvement and responsibility of David Miscavige, using I.A.S. monies in part from Tom Cruise and John Travolta, is helping to fuel the review of these matters involving on-going conduct as the first paragraph of your letter demonstrates. Both Miscavige and you have ignored your many past opportunities to undo the wrongs that were done to me and to do the appropriate things to correct the damage. This has merely aggravated the consequences for you.

3. If you “cannot therefore easily appear on the 16th” for the depositions of your two clients (one in the morning and the other one in the afternoon) then the usual solution and accommodation is to choose a different and mutually convenient date. Accordingly, please provide me with some alternate dates for me to consider.

4. You are correct that a C.C.P. §425.16 motion “stays discovery.” However, the statute provides that the stay takes effect “upon the filing of a [C.C.P. §425.16] motion and that will not take place untilSeptember 19, 2008. The deposition of your clients, for potential evidence to be used in connection with that motion, was intentionally scheduled for September 16, 2008 (three days before).

5. Regarding your “show me” request, I refer you to Thomas v. Quintero, 125 Cal.App. 4th 635 (2005). Among other things it holds that: (A)C.C.P. § 527.6 “is a cause of action.” Accordingly, the right to discovery exists however truncated or expedited; and (B) After the filing of a C.C.P. § 425.16 motion discovery can proceed by mutually agreed court ordered stipulation.

Please advise me whether or not you and your clients will appear for their duly noticed depositions on September 16, 2008.

Finally, it is hypocritical for you to talk of harassment here after flying to Hamburg the same day as me, and then attempting to gate crash my speech there by threatening two HamburgState employees with a law suit if they did not let you enter. “Give me your passports and identification. I am going to sue you,” was what you told them.

Very truly yours,

Graham E. Berry

cc REDACTEDa/k/a Angry Gay Pope