DECLARATION OF
ROBERT J. CIPRIANO
I, Robert J. Cipriano, hereby declare and
state as follows:
1. I
have personal knowledge of the matters set forth herein and, if called upon to
do so, I could and would competently testify thereto under oath.
2. I have primarily drafted and typed this
declaration myself, free of duress, intimidation or inducement.
3. As
of July 12th 1999, a certain set of circumstances and events have
transpired that have caused me to write this Declaration. The events surround
the introduction of Church Of Scientology private investigators, attorneys,
officials and followers into my life since May 4th 1994. The
circumstances and events surround "threats", "bribery",
"intimidation", " "duress", "dead agenting",
"fair game", "black propaganda", "slander", and
"witness tampering".
4. Since May 4th
1994, my personal and professional life have been destroyed due to the acts of
The Church Of Scientology and their Office Of Special Affairs, including the
acts of their lawyers, Mr. Kendrick Moxon of Moxon & Kobrin, Mr. Sandy
Rosen of Paul, Hastings, Janofsky & Walker and numerous officials and
followers including: Kendrick Moxon, Esq.; Gary Soter, Esq.; Steven Hayes,
Esq.; Timothy Bowles, Esq.; Elliot Abelson, Esq.; John Ryan; Eugene Ingram;
Judy Ross; Ken Long; Isadore Chait; Rev. Glenn Barton; Michael Rinder; David
Miscavige; Erla Hawkins and Joanne Weaton.
I cannot be sure how many other Church of Scientology followers and
officials are involved, that have not become known to me as of the date of this
Declaration. I am learning on a weekly
basis of additional individuals who became involved in my life, who were
operatives or in some way working on behalf of Church Of Scientology and/or
their Office Of Special Affairs to monitor, control, influence, harm,
intimidate and tamper with me.
5. More
importantly to the focus of the Declaration is my very real concern for my
safety and physical protection. I have absolutely no doubt that Church of
Scientology and their Office of Special Affairs will attempt further tactics of
intimidation, threatening acts and, eventually attempt to have me silenced. The
information contained in the Declaration provides a very clear and precise
depiction, with over 1000 pages of written proof of my statements and allegations.
It is my personal opinion that once this information is made public through
court filings and media releases, that I will become subject to the full
vengeance, of the Church of Scientology and its operatives.
6. Additionally,
I have written this Declaration to bring an eventual close to what I believe to
be one of the most horrendous, continuous displays of criminal acts perpetrated
in the name of an IRS recognized religion in my life and possibly to bring
awareness to the public about this bogus, fraudulent and extremely dangerous
cult. It is my hope that all proper law
enforcement officials can provide me with capable legal protection and that the
media coverage will become sufficient to dissuade Church Of Scientology from
harming me. Furthermore, I am not a Scientologist; however, I was brought into
their private world and exposed to many of their illegal tactics.
Cipriano
General Background
7. I
have been a businessman since 1980. At age 18 I entered into a business
partnership, Capri Productions, Ltd., with Jerome L. Spiegelman. The primary
focus of this business partnership was the management of entertainment
performers and artists in the New York City vicinity. Over a period that spanned 1980 through February 1985, Mr.
Spiegelman and I opened and managed numerous entertainment and fashion
businesses.
8. In
February 1985, I dissolved my partnership with Mr. Spiegelman for reasons of
heavy drug use by Mr. Spiegelman and numerous legal complaints for fraud placed
by his law clients. I relocated to Los Angeles, California, where I began work
with Parkinson Friendly Productions under the supervision of Griffin
O’Neal. I primarily created programming
and production projects for Parkinson Friendly.
9. In
late 1985 – early 1986, I left the entertainment business and decided to start
a career in real estate. I began work
with R&B Commercial Properties at Wilshire Court Financial Center and
eventually was hired away from R&B by Paramount Group, Inc. at Paramount
Plaza 3550/3580 Wilshire Boulevard as an Assistant Property Manager. In late 1986 – 1987, I moved to Dayton,
Ohio, married Jeanette Lambert and began my first commercial real estate
development, Elmwood Galleria Business Center with Paragon Realtors (Donald
Nordstrom). After completing the design,
financing syndication and “breaking ground”, I sold my interest in the project
and relocated to New York City wherein I sought and was granted a divorce from
Ms. Lambert in 1988.
10. 1988
through 1993 was spent both in New York City and Los Angeles, California,
building Cipriano Development Group (CDG).
I brokered real estate transactions, created real estate syndication,
managed real estate properties, and in general worked particularly in the real
estate business.
11. In
early 1994, after losing CDG in late 1993, I became the subject of a criminal
charge in May's Landing, New Jersey, for Failure Of Required Disposition over a
recently acquired subsidiary of Cipriano Development Group called Artistic
Builders Group. The purported crime was perpetrated by the previous owner, Mr.
Peter Augay. However, because CDG had acquired the company, I was charged with
the crime. The charge was falsified against me and at the time I had no funds
to retain proper legal representation and therefore utilized the services of
the Public Defender who eventually entered a plea bargain that required
restitution and probation. During the
same period, May, 1994, I was approached and threatened by a private
investigator working for the Church of Scientology (COS) regarding a Mr. Graham
E. Berry (see Ingram). This was a very
exhausting and trying period for me.
12. In
January, 1996, I elected to move from New York City back to Los Angeles,
California, where I started work with the Foundation For The Declaration Of The
Rights Of Children (FDRC). As their
Executive Director, I created The Day Of The Child fundraising themed projects
in New York City and Washington D.C. I had decided that, for personal reasons,
I needed to give back to people in need and children had always been a very
serious concern of mine.
13. The
period from 1996 through and including July 1999 are detailed in the remaining
portions of this Declaration as they go to the center of the Church of
Scientology and Office of Special Affairs' circumstances and events concerning
me.
May 4th & 5th, 1994
Eugene Ingram
(P.I. For Church Of Scientology and Moxon
& Kobrin Law Firm)
First Visit With Cipriano
14. On
May 4th 1994, at more or less 2:00 PM, I was paid a visit by a Mr.
Eugene Ingram and his female accessory at my home at 245 East 63rd
Street, Apartment 1617, New York City, New York. Mr. Ingram presented himself as a Los Angeles Police Detective
and presented a Detective’s Shield upon addressing me at my apartment door. Mr.
Ingram had passed through a heavily guarded, high security apartment building
without being noticed. Mr. Ingram stated that he had affairs that he wanted to
talk to me about. I welcomed both of them into my apartment and sat and
listened to him. I was under the impression that I was going to be arrested by
both of them for the May’s Landing, New Jersey, criminal charge, as I had not
surrendered to the New Jersey legal system. I was still seeking an attorney to
answer the charges who would work with me since I had limited funds. Upon
entrance into my apartment, Mr.Ingram immediately established that he was aware
of my situation in New Jersey and stated that, “You should be careful and be
very helpful to me!” It was a natural presumption for me to conclude that if I
did not assist him in any all manners that he would arrest me and take me to
New Jersey before I could retain legal representation.
15. Mr.
Ingram began discussing Mr. Spiegelman, a previous business partner of mine. We
discussed his law firm, our business partnership together and Mr. Spiegelman’s
legal problems, which had landed him in jail after I dissolved my partnership
with him. Mr. Ingram continued with questions surrounding other legal partners
of Mr. Spiegelman’s including Mr. Graham E. Berry. Mr. Ingram was very
interested in Mr. Berry’s legal clients and his personal habits. I asked why
and what this was about. I had not seen Mr. Berry since the beginning of 1985,
and had heard he had moved to Australia or New Zealand. I was aware of an open
question regarding some six million dollars that was not recovered at the time
Mr. Spiegelman was arrested in 1985/1986, and I began to think that Mr. Berry’s
unanticipated departure to Australia or New Zealand was very mysterious. I
began to relax knowing that I really had no data on Mr. Berry beyond the end of
1984, or at best, early 1985, which was prior to my departure from New York
City and arrival in Los Angeles to work for Parkinson Friendly Productions.
16. Mr.
Ingram continued with numerous questions regarding Mr. Berry’s personal conduct,
sexual habits and his legal clients. He asked me what I knew about Mr. Berry’s
gay lifestyle. I stated that I knew he lived a gay lifestyle; that he had
numerous male partners who were young “boy next door” types. That in 1984, I knew and had met a David Lee
who was involved with Mr. Berry. Without warning, the discussion turned
domineering and combative when Mr. Ingram started to ask seriously deranged
questions. For example: “You saw Graham
Berry with underage boys – 12 year olds, right?” “Graham was a cocaine addict, right?” and “Graham Berry was a
really sick faggot, right?” He was not questioning me any further, yet
demanding that this had happened and that that had happened. I asked him to back off and slow down. Mr.
Ingram showed me a picture of Mr. Berry standing in a nightclub and said this a
gay club in West Hollywood.
17. I
thought back to those days in the early 1980’s and recounted my recollections.
"There was cocaine that was being abused during 1984-1985." I told
Mr. Ingram that, "I had done cocaine for about six months in 1984 and had
quit because it just destroys everything." "There were a number of
young boys, I didn’t know or recall how old they were." "Graham Berry
represented Studio 54." Mr. Ingram suddenly dropped it and went back to my
situation in May’s Landing, New Jersey. He questioned me on how long it had
been since I was advised of the charges and that it was only a matter of time
before they would come for me in New York. I stated that I knew that and that I
was moving as fast as I could to get an attorney, that I was not guilty and
that I was set-up by Mr. Spiegelman and Peter Augay, Mr. Ingram stated that he
had spoken to Spiegelman. Mr. Ingram stated that, "Mr. Berry went to the
Anvil, a seedy after hours gay club in New York City and he took boys with
him." I stated that "I have never gone to a place like that, I would
not know if he did or did not."
18. Mr.
Ingram proceeded to ask if I would sign a legal declaration on Mr. Berry. I asked what would it be used for. Mr.
Ingram stated that it would be placed in a file, and most likely never be used.
I agreed and Mr. Ingram stated that he would contact me the following day May 5th
1994, to have me sign it.
19. After
he left my apartment, I went out for a number of hours. I returned home at approximately 10:00 or
11:00 PM that evening to find out from my then wife, Valerie Hayman Cipriano,
that Mr. Ingram came back earlier in the evening and had sat and talk with her
for an hour or so. As my wife had no
part or knowledge of my lifestyle, friends or business associates in the early
1980’s this caused me some serious anxiety.
20. On May 5th
1994, Mr. Ingram visited me at my office at
245 Park Avenue, where he presented a Declaration that had numerous
exaggerated statements and fabrications. He took my basic statements and
painted a different picture than I had presented the day before. I told him
that this was not what I had said, and he instantaneously became furious and
belligerent with me again, because I dared to challenge him on the ages of the
males involved with Mr. Berry. He said, “The next time you open your door at
home it is not going to be me, but New Jersey, now sign it.” I signed it and
asked him if he was going back to Los Angeles and he said yes, he would be
going back to Los Angeles after he spoke with Troy Glick. He left my office. I
immediately called Troy Glick and told him that a Los Angeles Detective had
just been at my home and that he was after Berry and Spiegelman.
Second Visit With Cipriano’s Declaration
Posted To The Internet
21. In
January of 1996, I moved to Los Angeles to start my new life. I started working for FDRC, a 501 c(3)
children's charity, working on Day Of The Child. In early April 1997, a
girlfriend had purchased a computer system and we set it up in our Marina Del
Rey apartment in Mariners’ Village. It had internet access. We subscribed to
America Online (AOL) and I created a Screen Name (CIPGUY). While exploring the
internet through AOL, I came across a Search Engine and started typing in
people and things from my past. Eventually, I typed in my name “ROBERT J.
CIPRIANO”, and became completely and absolutely appalled to see numerous
postings under my name. Each and every one of them involved my Declaration from
1994. I immediately looked up Eugene Ingram’s card from my business card
collection and contacted him. I set up a meeting in Marina Del Rey for lunch.
22. On April 30th
1997, we met at the Warehouse Restaurant and I asked him straight out,
“What the f--k is going on and who are you working for?” Mr. Ingram
said a law firm that had litigation with Mr. Berry. Mr. Ingram stated again
that my situation in New Jersey was not completely over and that I was in
violation of my probation, which was true, but only because I had failed to
make a few restitution payments. I had stayed in touch with my probation
officer trying to work things out. On May 11th 1997, Mr. Ingram came
by my apartment and noticed my professional pictures and awards on my
home-office walls. Mr. Ingram wanted to make copies of all of them. Mr. Ingram
took them to a local copy shop and returned an hour later. Mr. Ingram then
asked me who each and every person was in the pictures and proceeded to write
the info and the back of the copies.
Eugene Ingram’s
Third Visit With Cipriano
Hears Of Law Suit Against Him By Berry
23. Sometime
in January, 1998, Eugene Ingram contact me in my Carpinteria home to advise me
that I might be sued by Graham E. Berry for my Declaration. Mr. Ingram told me
over the phone that he needed to see me right away. He arranged to drive up to
Carpinteria the following day to meet with me. We had lunch at a local
restaurant and Mr. Ingram told me that he worked for the Church of Scientology
and a law firm that represented the Church of Scientology. Mr. Ingram told me
that Mr. Berry was representing numerous people who did not like the Church of
Scientology. Mr. Ingram told me he was on his way to San Luis Obispo where L.
Ron Hubbard's autopsy had been conducted and where Mr. Berry was causing
problems. Mr. Ingram said something about, "getting to the Coroner's
office before Berry did." Mr. Ingram told me that he had a spy in Mr.
Berry’s law office and he or she had gotten a copy of the complaint. I
asked for a copy of it and he refused to provide one to me. Mr. Ingram said
that if I received a copy of it that it could prove that I was served in the
future, if that became an issue. After that, both Christine Gregos and I
decided to move from Carpinteria to her duplex in Van Nuys, California. Mr.
Ingram stated that, "If you moved to Van Nuys, Berry would never find
you".
24. Mr.
Ingram told me that his boss, Kendrick Moxon, wanted to meet me immediately. We
arranged for me to drive down the next day to meet with Mr. Moxon and Mr.
Ingram at an office on Brand Avenue in Glendale, California. Mr. Ingram stated
that I really needed to count on him and Mr. Moxon. I told Mr. Ingram that I
had lost a couple of jobs due to employers reading the Declaration on the
internet and that this whole mess was absurd and preposterous. Mr. Ingram told
me of a computer nerd that had broken into some private computer system while
on the nightshift of some job and that he had broken the guy's cover (I would
later find out that was Keith Henson). Mr. Ingram told me that he had been to
London, England, to investigate a female television reporter who was running a
story on the Church of Scientology in the United Kingdom. That his job was to
convince everyone that she was a prostitute or a stripper in order to convince
her not to do the show. Additionally, the authorities banned him or arrested
him on some charge and asked him to leave the country. I asked Mr. Ingram about
the numerous arrest warrants here in the United States for him that I had read
about on the internet. He said that they were not real and that people can say
anything on the Internet.
Kendrick Moxon’s First Meeting &
Eugene Ingram’s Fourth Meeting With Cipriano
25. On
January 23rd 1998, I arrived at 5:30 P.M. for my appointment with
Kendrick Moxon and Eugene Ingram at 550 North Brand, Suite 700, in Glendale.
Mr. Ingram was waiting for me in the building lobby reception area. He was
nervous regarding something. We entered Mr. Moxon’s office and Mr. Ingram
proceeded, without asking anybody, to a conference room to the right of the
office reception center. We sat inside and he began showing me paper work on
something that Mr. Berry was involved in regarding the Los Angeles Unified
School District and a gay student program.
26. Mr.
Ingram told me about Mr. Berry selling tickets to a Gay Liberation March On
Santa Monica Blvd.; and something about Mr. Berry telling the affluent gay
population that he started AMFAR so as to sell more tickets. Mr. Ingram told me
that Mr. Berry was also filing legal paperwork against Mathilde Krim, the
Chairman of AMFAR, for a Declaration she wrote.
27. Mr.
Ingram told me about a book he wanted me to read, Bag Of Toys. I ask
why. He said that it was about, “. . those days in New York City.” He proceeded
to give me a copy. He told me that the
main character in the book, Bernard LeGeros, also signed a Declaration against
Mr. Berry, but that LeGeros was in jail in New York or New Jersey for a murder
depicted in the book. He told me that LeGeros was completely insane and wanted
Mr. Berry dead.
28. Mr.
Moxon finally arrived, shook my hand and sat down. Mr. Ingram started talking,
completing a narrative of some of the history of the situation. Mr. Moxon
stated that, “Well, certainly, if Berry did sue you, then I would represent
you at no cost. You were helpful to me and we will not leave you alone to fight
this battle . . .Further, we don’t think
Berry is serious and is just bluffing with the lawsuit.” The meeting
with Mr. Moxon was over in ten minutes, and I returned to Carpinteria alone.
Cipriano
Served With Graham E. Berry’s Summons
In Van Nuys, California
29. On
March 9th, 1998, I was served a Summons with Case Number BC184355,
Graham E. Berry, Plaintiff v. Robert J.[1]
Cipriano, Defendant for Libel, Libel Per Se, Slander, Slander Per Se,
Intentional Infliction Of Emotional Distress, Negligent Infliction Of Emotional
Distress, Invasion Of Privacy, Public Disclosure Of Private Facts and
Conspiracy
Cipriano And Graham E. Berry
Email Communication
Cipriano Settlement Letter Offer To
Berry
30. In
the following days and weeks, I received emails from Mr. Berry (See Exhibit 1,
2, &
3 [a]), that I perceived as threats upon
me. I contacted Mr. Moxon to advise him of the emails received from Mr. Berry.
Additionally, I prepared a personal letter to Graham E. Berry that I sent to
Mr. Moxon in an attempt to settle this problem between Mr. Berry and me. I told
Mr. Moxon to send it to Mr. Berry (See Exhibit 4). By Saturday evening March 21st
1998, both my fiancé, Ms. Christine Gregos, and I were intensely apprehensive
and I called Mr. Berry, Mr. Ingram and Mr. Moxon and I told them to meet me at
the Van Nuys Police Station to work this out with the appropriate law
enforcement authorities. Mr. Berry refused to meet at the Police Station and
Mr. Ingram and Mr. Moxon arrived at my home roughly one hour later.
Contacts Office of Special Affairs & Offer
Incentives
Cipriano Signs Retainers With Moxon
31. At
this time, Mr. Moxon took me into our home office while Mr. Ingram worked on
Ms. Gregos. They switched and Mr. Ingram started talking with me while Mr.
Moxon talked with Ms. Gregos. Mr. Moxon, in his attempts at quieting Ms.
Gregos, offered her anything she wanted; a job, money, anything. Ms. Gregos
stated to him that she wanted nothing he had to offer. Ms. Gregos hated both of
them and wanted me to get away from anything having to do with Mr. Ingram.
32. Mr.
Moxon called the Office of Special Affairs at the Church of Scientology and had
them fax over a document for me to read entitled Affidavit of Garry Scarff (See
Exhibit 5). Finally, Mr. Moxon convinced me that if he called Mr. Berry and
told him that I was being represented by Mr. Moxon now, and that Mr. Berry was
to no longer attempt to communicate with me, that this would stop Mr. Berry
from further personal communications. Mr. Ingram offered to give me unlawful
phone tapping equipment to record Mr. Berry when, and if, he called again. Ms.
Gregos demanded that no equipment be involved on our phones, so I refused same
from Mr. Ingram.
33. Mr.
Moxon made it very clear that I would not have to pay a dime in legal fees or
any other fees relating to this matter. Further, that the Church of Scientology
was paying for everything, including Mr. Moxon's fees.
34. The
following Monday, March 23rd 1998, Mr. Moxon sent over a REQUEST FOR
INVESTIGATION OF ATTORNEY GRAHAM E. BERRY. Mr. Moxon asked me to place it on my
personal stationary and send it to the State Bar Of California, located at 1149
South Hill Street Los Angeles, California, (See Exhibits 6 & 7) to harass
Mr. Berry and get him to drop the lawsuit.
35. Due
to Mr. Berry's lawsuit against me and the threat of financial ruin, on March 23rd
1998, Ms. Gregos demanded that I contact Mr. Moxon and have him draw a Quit
Claim Deed on 17232 and 17234 Vanowen Street; a relinquishment on household
items; a relinquishment on jewelry; a relinquishment on my 1997 BMW 328; a
relinquishment on a GMC Sonoma Truck; a relinquishment on a 1995 Grand Cherokee
Laredo Jeep and a relinquishment of any and all rights in our checking accounts
(See Exhibit 8)
36. On
March 25th 1998, Mr. Moxon asked me to meet him at Wasserman, Comden
& Casselman law office at 5567 Reseda Boulevard in Tarzana, California, to
meet with Gary Soter, Esq. I arrived and proceeded to sign a Retainer Agreement
with Mr. Moxon of Moxon & Kobrin (See Exhibit 9) and Gary Soter of
Wasserman, Comden & Casselman (See Exhibit 10) for legal representation in
the Berry v. Cipriano lawsuit. The Retainer Agreement with Moxon &
Kobrin was strangely backdated to March 23rd 1998, so Mr. Berry
could not claim that I was a “free-agent” during that short period of time.
Additionally, the Moxon & Kobrin Retainer stated that Moxon & Kobrin
was responsible for payment to Wasserman, Comden & Casselman regarding my
representation. Equally the Wasserman, Comden & Casselman Retainer stated
that Moxon & Kobrin were responsible for payments for legal services
rendered by their firm.
Mr. Moxon Arranges Job For Cipriano At
Earthlink Network, Inc.
A Church Of Scientology Company
37. On
or about March 26th 1998, Mr. Moxon and I talked about my
re-entering the work force. Mr. Moxon
suggested Earthlink Network, Inc., in Pasadena. Earthlink Network is a Church Of Scientology company. Mr. Moxon
contacted Mr. Sky Dayton, Chairman of Earthlink, who referred him to Mr. George
Williams, Director of Dial-Up Sales. An interview was arranged, and I was hired
March 27th 1998, even though they were not hiring at that time. Earthlink created a new sales management
position for a girl named Jennifer so they could move her up creating an
opening for me in the sales department. On March 28th 1998, I sent
an email to Mr. Moxon thanking him for the introduction (See Exhibit 11 & 12).While
at Earthlink Network in Pasadena, California, I had access to the Internet
Service Provider’s internal operations.
38. I
was befriended the first day of my employment at Earthlink by a Mr. Michael
Hamra, another sales associate. I
quickly started a friendship with Mr. Hamra and spent countless hours talking
about various things including how Earthlink started with investments, by
Kirstie Alley, Tom Cruise, John Travolta and other wealthy Scientologists, into
Sky Dayton's idea of an internet service provider. Mr. Hamra told me how Sky
Dayton had a coffee shop before starting Earthlink and that he, because of
being a Scientologist and his friendships with
celebrity Scientologists, he was able to build a multi-million dollar
company that could, "Watch over the entire internet from within the
internet."
39. Additionally,
Mr. Hamra told me he was one of the founding group of Scientologist who ran
Earthlink out of a Glendale one room office where he made sales calls from a
bathroom in the office. Mr. Hamra said, "The Church of Scientology now had
a database of information on every subscriber which included names, credit card
info., credit reports, telephone info., computer info., who had referred them
to Earthlink and who were their previous ISP providers.” Mr. Hamra told me
about the "other Earthlink building" which was next door on New York
Avenue in Pasadena. Mr. Hamra told me that the other building was high security
and is where Earthlink and the Church of Scientology did all the monitoring of
the internet. Mr. Hamra was always very interested in my testimony in Berry
v. Cipriano. It became clear to me that he was reporting what I was saying
to other in Scientology.
40. I
received many incoming sales calls while at Earthlink from individuals who
would ask, "Are you a bunch of Scientologists?" We were trained to
never admit that we were involved with the Church Of Scientology.
41. On
April 4th 1998, I received an update from Mr. Moxon by email. In this email, Mr. Moxon informed me of the
“. . .fun starting with Berry.” He was also asking me for further Declarations
to substantiate my lack of knowledge regarding the posting of my Declaration on
the internet (See Exhibit 13).
Moxon Introduces Cipriano To
Hubbard’s Holdings In Hollywood, Celebrity Center
Further Defendants In Cipriano Case
42. During
one of the weekends between April 4th and May 12th 1998,
I was asked by Mr. Moxon to join him on a Sunday afternoon at the L. Ron
Hubbard Museum on Hollywood Boulevard. At said time, Mr. Moxon arranged for me
to have a highly private tour of their facilities. A personal escort took me to
areas of the facility that were not open to the public They attempted to have me use their E-Meter
machine, which I aggressively refused. After the tour, Mr. Moxon took me to the
Church Of Scientology Celebrity Center in Hollywood where we were met by a
person I believed to be Isadore Chait. Additionally, I believe that I met a
gentlemen who identified himself as David Miscavige, however, I am not
absolutely positive it was he. On our drive in Mr. Moxon's car, he did not want
to ride in my car, Mr. Moxon asked me what it was in the world that I really
wanted or needed. I thought about it and did not answer right away.
43. Once
at the Celebrity Center, Mr. Moxon repeated his question, referring to a financial incentive of around
$750,000.00. I said that I did not want to be paid for my testimony. On our way
back to Mr. Moxon's car, and on our way in his car back to mine, I said that I
had a dream concept that I had spent quite a long time developing, called DAY
OF THE CHILD, which was a children’s charity concert that would benefit over
500 children’s charities. They could assist with an investment, celebrity
endorsements and personnel if they wanted. Mr. Moxon asked how much would a
video commercial of it cost? How much would it cost for an office with
equipment? How much for various things? Mr. Moxon told me, in plain words, that
he would syndicate the monies needed with some of the wealthy Scientologists
and get it funded. I told him I would email him from Earthlink with information.
Moxon Offers Trip To Cipriano
New York City To Warm-Up New Witnesses
44. April
30th 1998, Mr. Moxon asked me to track down witnesses and convince
them to testify against Mr. Berry. Mr. Moxon wanted me to talk to Suzette and
Richard Holmes, Howard Shafran and Carol Lackenbach, people that worked in and
around Mr. Spiegelman and Mr. Berry back in 1984. Mr. Moxon offered to fly me
back to New York City to soften-up and warm-up the witnesses and prep them for
a new private investigator they had hired in New York City (See Exhibit 14).
This trip never happened.
Icon Entertainment Group/Day Of The Child
SEC Private Placement Offering
45. On
May 14th 1998, I sent an email from Earthlink to Mr. Moxon advising
him of the starting point for the project. I discussed ownership percentages,
Earthlink’s participation, the legal offices being at Moxon & Kobrin’s law
office, etc. (See Exhibit 15)
46. On
May 23rd 1998, as per Mr. Moxon's request, I prepared and presented
a SEC Private Placement Offering for Icon Entertainment Group for Day Of The
Child to solicit and secure funds from Church Of Scientology and Church Of
Scientology members, entertainers, celebrities and officials. I pledged my
personal stock in other companies as collateral. (See Exhibit 16)
Cipriano Receives A $2,500.00 Non-Repayable Loan
From Geoffrey Barton A Relative Of Glenn Barton
A Defendant in Graham Berry’s Cases Against
Church of Scientology
47. On
or about May 25th 1998, Mr. Moxon arranged for and wired $2,500.00
from a Geoffrey Barton into the account of Christine M. Gregos, Accurate
Bookkeeping Company, on my behalf. This loan was to pay off any outstanding
debts between Christine Gregos and me so that I would have no obligations to
her. When the money was given to me, however, Mr. Moxon stated that we needed
to sign a promissory note so that it did not look like Scientology was paying
me while I was a witness. I asked Mr. Moxon was this the same Barton that was
named in Mr. Berry's lawsuit against me? Mr. Moxon told me that it was a
different person and just a coincidence the last name was the same. During this
same time period, Mr. Moxon suggested that I get away from Ms. Gregos, as she
was “toxic” for me. (See Exhibit 17).
Mr. Moxon Informs Cipriano That The Berry v.
Cipriano
Case Has Been Moved From Judge Hiroshigi To Judge
Williams
48. Mr.
Moxon informed me that Judge Hiroshigi was a "lame-judge" who could
never begin to grasp the case and that he had filed a motion to replace
Hiroshigi. The case was transferred to a Judge Williams, who Mr. Moxon told me
was, "A friend of the Church of Scientology."
Cipriano Is Moved Into a Safe House
Church Of Scientology Boarding House In Hollywood
Deposition Of Cipriano Taken
49. Approximately
June 17th 1998, Mr. Moxon moved me into a Scientology boarding
house, free of charge to me, on Franklin Avenue called the Franklin House,
owned and operated by Eugene Ingram’s detective-operative Joanne Weaton, a
known Scientologist. This was done to get me away from Christine Gregos, who
Mr. Moxon thought was “toxic” to me as well as to keep me from bolting to Mr.
Berry’s side of the lawsuit.
50. On
June 29th and 30th 1998, Mr. Moxon invited me to his home
on Vista Verdugo outside of Glendale, California. Mr. Moxon prepared me to
answer questions in my Deposition scheduled for July 1st and 2nd
1998. Mr. Moxon told me to lie about the ages of Mr. Berry's intimate
relationships, and to antagonize him and get Mr. Berry to say things he might
normally not say. Mr. Moxon told me to get Mr. Berry "pissed off" at
the Deposition. It appeared to me that this was a game for Mr. Moxon and it was
more about scaring Mr. Berry than about a real cause of action based on
truthful facts.
51. On
July 1st 1998, I arrived in downtown Los Angeles at the Paul,
Hastings, Janofsky and Walker law firm and met with Mr. Moxon, Mr. Sandy Rosen,
Mr. Michael Rinder, Ms. Barbara Reeves and numerous other Church Of Scientology
and Office Of Special Affairs officials at 8:30 A.M. They were standing around
the conference room, shaking my hand and laughing about Mr. Berry. Mr. Moxon was being extremely smug, like he
had the witness that would bring Mr. Berry to his knees. I was prepared by Mr. Rosen and given a copy
of Mr. Berry’s bankruptcy documents. I
was told by Mr. Rosen to pick the items in the bankruptcy that I thought might
be false and on which Mr. Berry had filed. Mr. Rosen told me that when I was
unsure of an item, to say that it was false.
52. Each
time Mr. Moxon and Mr. Rosen asked for a break we would go downstairs to smoke,
Mr. Rosen & Mr. Moxon would laugh like little kids about how Mr. Berry and
his lawyer, Mr. Lewis, were totally screwing up. Mr. Rosen told me he thought I
was the best witness he had ever had and I should think about being a professional
witness around the country. Both Mr. Moxon and Mr. Rosen showed their true
colors during those two days. I found both of them to be totally repulsive,
unprofessional and homophobic. The case was not about Mr. Berry being a
law-abiding citizen, instead the idea was, "Let's get Berry because he is
lives a gay lifestyle." This was when I first understood what the term
"dead agenting" meant and saw it in action.
53. On
July 2nd 1998, I arrived again and was greeted by Eugene Ingram. Mr.
Ingram asked me when we were alone, “I never showed you a Los Angeles
Detective’s badge when I first interviewed you in New York, did I?" I
found this very strange due to the fact that I had told Mr. Moxon a couple
weeks earlier that Mr. Ingram had, in fact, misrepresented himself to me as a
Detective. I became very concerned after I read an article on the internet
regarding an outstanding warrant for Mr. Ingram’s arrest in Florida for
impersonating an officer and knowing what he had done to me. It was obvious
that Mr. Moxon told Mr. Ingram and Mr. Ingram was, once again, intimidating me.
I was paid a fee of $45.00 per day for my Deposition (See Exhibit 18).
Cipriano Moved To Palm Springs, California By Moxon
Church Of Scientology International Headquarters
54. Immediately
following my Deposition, I was moved to Palm Springs, California, to get me
away from Los Angeles. Mr. Moxon told me this was the Church of Scientology
“witness protection program” and that it was 15 miles from the International
Headquarters for the Church Of Scientology in Gilman Hot Springs. Under the
promise that now Mr. Moxon would cover all expenses and get Day Of The Child
funded and off the ground, I left Ms. Gregos and moved to Palm Springs. I had
delivered the Deposition in the manner that they wanted and everyone was
pleased so, this was a reward.
55. In
early July 1998, after I arrived in Palm Springs, I began work immediately on
preparing budgets for Day Of The Child. In phone conversations with Mr. Moxon I
indicated that the budget numbers for Day Of The Child were coming in around at
about $520,000.00 for the first year. He indicated that he had no problem with
that. At this point, I was staying in Palm Springs with a friend named Donald
Snodgrass waiting for Mr. Moxon to provide what he had promised. Mr. Snodgrass
and I were working extremely hard to obtain back up on the budgets so that we
could get Day Of The Child off the ground. We both waited week after week with
nothing from Mr. Moxon.
Cipriano And Moxon Confrontation
56. Mr.
Snodgrass became very enraged that I had been promised so much by Scientology
and that I was being "jerked off". Mr. Snodgrass contacted Mr. Moxon
by telephone and told him to “get his ass to Palm Springs” or Cipriano would
disappear completely. Mr. Moxon told Mr. Snodgrass that he would be in Palm
Springs within a couple hours. I was very upset with Mr. Moxon, Scientology and
anybody who had anything to do with the whole mess.
57.
At approximately 5:30 P.M.
Mr. Moxon, with Mr. Ingram, arrived in Palm Springs at
Mr. Snodgrass' home. I had hand written a letter (Exhibit 19) for Mr.
Moxon to read:
Lost Relationship
Lost Job
Lost Pay
Lost Promise
You Lost Me
58. Mr.
Moxon, Mr. Ingram and Mr. Snodgrass had a long conversation which ended with
Mr. Moxon telling Mr. Snodgrass to have me get in touch with him as soon as
possible. Additionally, Mr. Moxon wrote a message on my hand written note (See
Exhibit 19) apologizing and promising to fix everything.
Mr. Moxon Rents Cipriano A Palm Springs Condo
And Starts Sending Money Weekly To Cipriano
59. On
or about the last week of July, 1998, Mr. Moxon told me to go and arrange an
apartment or condo for me to live in. I arranged for Palm Springs Rental
Agency's Nancy Zachary to show me 280 South Caballeros Unit 236. On July 27,
1998, Mr. Moxon completed the rental application, sent $1074.00 to Palm Springs
Rental Agency and signed a lease for the premises at $500.00 per month for 7
months. (See Exhibits 20, 21 & 22) Additionally, Mr. Moxon started sending
$200.00 to $400.00 every week or two via Western Union or Money Gram. Every
month thereafter Mr. Moxon would call me to his Los Angeles office and give me
checks drawn on Moxon & Kobrin ranging in amounts between $500.00 to
$1,000.00 for living expenses, groceries and Day Of The Child. The checks would
be made payable to me and I would go into a Wells Fargo bank across the street
from Mr. Moxon's office to cash each one. Mr. Moxon paid the monthly rental on
the condo directly to the Landlord.
Mr. Moxon Arranges For Free Legal Representation
For Cipriano In New Jersey For
Pending Probation Violation
60. On
August 6th 1998, Mr. Moxon sent me a Federal Express with a letter
informing me that Mr. Moxon had retained Lloyd Levenson, Esq., in Atlantic
City, New Jersey, free of charge to me, to handle my problem there and for me
to sign some documents pertaining to same. Mr. Moxon wanted the legal problem
in New Jersey erased and taken care of immediately so as to not help Mr. Berry
in the case Berry v. Cipriano. (See Exhibit 23)
Mr. Moxon Incorporated Day Of The Child
And Names Himself As Director & Treasurer
Starts Paying Day Of The Child-Cipriano Expenses
61. In
an email letter dated September 1, 1998, from Mr. Moxon to me, Mr. Moxon says
that he will pay for the Incorporation of Day Of The Child and indicates that
his investors/donors are definite prospects as soon as the application for
non-profit is filed. Mr. Moxon and Scientology were finally living up to their
agreements with me regarding my testimony in Berry v. Cipriano and all
the other related cases.
62. In
a letter dated September 3, 1998, Mr. Moxon indicated that he had paid the
phone bill and had placed a phone deposit so that Day Of The Child/Cipriano
could stay in business. (See Exhibit 24)
63. In
an email letter dated September 8, 1998, Mr. Moxon made corrections to a
contemplated merger agreement between Children's Charities Of America and Day
Of The Child. Additionally, he requested information so that he/Scientology can
file a tax-exempt application on behalf of Day Of The Child. (See Exhibit 25)
Mr. Moxon never filed for the tax-exempt status. As a result, Mr. Snodgrass and
I retained a local Palm Springs accounting firm, Brabo, Carlsen & Cahill,
to prepare and submit the IRS application at a personal cost of $500.00, which
was paid by Mr. Snodgrass.
Mr. Moxon Directs Cipriano To Star Magazine On
Gay
Relationship Story
64. An
article appeared in Star Magazine regarding John Travolta a and Michael
Pattinson, an ex-Scientologist, wherein Mr. Pattinson claimed that Mr. Travolta
and Scientology deceived him into believing that Scientology could cure him of
his homosexuality. Mr. Berry was representing Mr. Pattinson in the lawsuit
against the Church of Scientology. Mr. Moxon told me to call the reporter,
Martin Gould, and explain to him about Mr. Berry and my previous declaration.
Mr. Moxon went as far as to say magazines like the Star pay good money
for such stories. I did call Mr. Gould and told him about Mr. Berry as per Mr.
Moxon’s instructions but, to my knowledge, nothing came from it.
Paul, Hastings, Janofsky & Walker To Become House
Council
For Children's Charities Of America/Reveals That
Reeves Husband Is A Court Of Appeals Judge
65. In
an email letter dated September 26, 1998, from Mr. Moxon to Ms. Betsy Reinking,
Executive Director of Children’s Charities Of America, Mr. Moxon explained who
Barbara Reeves was and who her husband was, in hopes that Children's Charities
Of America would retain her, because Day Of The Child and Children's Charities
Of America were joining forces to produce a major concert event for charity.
(See Exhibit 26)
66.
Mr. Moxon wanted Betsy
Reinking to know that Barbara Reeves' husband was an appellate judge and that
he was a friend of Scientology. Additionally, that Barbara Reeves would work
for Children Charities Of America for a nominal amount, much less than her
regular fees, because she wanted to do something where she was answering to a
much higher God than the one she had been answering to.
67. On
October 6th 1998, Mr. Moxon called and informed me that I could go
get a new car if I wanted. I immediately went to a Saturn dealer in Palm
Springs and selected the auto that I wanted. The salesperson at Saturn was
given Mr. Moxon's phone number and Mr. Moxon was called. Mr. Moxon arranged and
closed the lease agreement in his name, and I drove the new Saturn off the lot
two hours later. (See Exhibit 27)
Atlantic City Legal Obligation
Moxon Provides Bankwire Information
68. October
8th 1998, and after some numerous phone conversations between Mr.
Moxon and Mr. Snodgrass, Mr. Snodgrass offered to pay off my legal obligation
in New Jersey. Mr. Moxon provided bankwire information to Mr. Snodgrass. The
communication angered Mr. Snodgrass because he had offered only as much as it
could be negotiated down to. Mr. Moxon wanted all the money, $18,500.00, wired
into his trust account. Mr. Snodgrass then refused to help. (See Exhibit 28)
Children’s Charities Of America (CCA) Refuses To Enter
Into Agreement Due To Mr. Moxon's Participation &
Involvement With Day Of The Child
69. CCA
and Day Of The Child had negotiated an agreement and the agreement was being
presented to CCA's Board Of Directors for approval in late November, 1998. One
of the Board members at CCA, Brian Morrison, Executive Director of Grant-A-Wish
in New York City, had discovered the information on the internet regarding Mr.
Moxon and my Declaration. He convinced the Board to stop all activities with
Day Of The Child. He convinced the Board not to work in any manner with Day Of
The Child. Additionally, Virginia Van Zandt, another CCA Board member had had a
horrible experience with Mr. Moxon when Mr. Moxon had attacked actor Wayne
Rodgers (M.A.S.H) because Mr. Rogers had come out publicly against the Church
Of Scientology. (See Exhibit 29, 30 & 31)
Mr. Moxon Arranged For $20,000.00 To Be
Transferred To Lloyd Levinson, Esq., the New Jersey
Attorney Handling Cipriano's Legal Problem In New
Jersey
70. On
November 3rd 1998, Mr. Moxon asked that I come up to Los Angeles to
meet with him at the 6255 Sunset office.
During this visit he told me that he was very excited that we did not
need the Snodgrass money; that he was able to get $20,000.00 from someone whose
identity he could not tell me, but that the person was very famous. Mr. Moxon
said, "If anyone ever found out about this I would be disbarred for
sure." Of course, my being curious, I said, "Tom Cruise and Nicole
Kidman?” He said "No.” I said,
"Kirstie?" He said, "No." I said, "Don't tell
me, Travolta?" He said, "Ok, I won't tell you it was John." I
said, "Jesus, can we get him to be our national spokesperson for Day Of
The Child?" Mr. Moxon said to
write a personal letter to Travolta and make it c/o Steve Hayes, John
Travolta's personal attorney and partner to Kendrick Moxon.
71. Mr.
Moxon received $20,000.00 from John Travolta and wired or sent a check to Lloyd
Levenson, Esq., in Atlantic City, New Jersey for $20,000.00. The outstanding
amount due was $18,500.00.
Mr. Moxon Arranged For Isadore Chait
to give $1,000.00 To Cipriano/Day Of The Child
72. In
early November, 1998, Mr. Moxon called and asked me to send a series of Federal
Express letters (on Moxon & Kobrin’s FedEx Account) to Clearwater, Florida.
One of these was to Timothy Bowles, another to Isadore Chait. The letter
packages were regarding Day Of The Child. On November 20th 1998, I
received a check from Mr. Moxon, from Isadore Chait, in the amount of $1,000.00
made payable to Day Of The Child c/o Moxon & Kobrin 6255 Sunset Boulevard,
Suite 2000, Los Angeles, California. (See Exhibit 32) I immediately opened an
account at Bank Of America in the name of Day Of The Child and with the
corporate address at 6255 Sunset Boulevard, Suite 2000, Los Angeles,
California, and deposited it into same.
Lloyd Levenson Calls Cipriano With Settlement Offer
In Atlantic City, New Jersey Case
73. On
December 22nd 1998, Mr. Levenson of Cooper, Perskie & Levenson
law firm called me and advised me that he was negotiating with the authorities
in Atlantic City, New Jersey, and he thought that he could get them down from
the balance of $18,500.00 to around $12,000.00. He indicated that Rick Moxon
had wired him $20,000.00 and that was more than enough. He indicated he would
call back with the final offer. On
December 23rd 1998, Mr. Levenson called me again and told me he
settled for $9,500.00 and he was happy. I agreed and said settle it. Later that
day, we spoke again and he wired $2500.00 into Day Of The Child bank account.
(See Exhibit 33, 34, 35 & 36) In the following month, on January 11th
1999, and January 25th 1999, he wired an additional $1,400.00 and
$988.55 respectively into Day Of The Child bank account.
Moxon Introduces Famous Scientologist
John Ryan To Cipriano
74. In
early December, 1998, Mr. Moxon introduced Mr. John Ryan to me for the purposes
of joining Day Of The Child. Mr. Moxon explained that Mr. Ryan was a top
executive at Polygram Records. After meeting Mr. Ryan in Mr. Moxon's office, I
realized that he was a record producer, however did not work for Polygram
Records, instead had a home business called Chicago Kid Productions. I learned
that Mr. Ryan had been a record producer for STYX in the 1970's and had been
involved with other projects. Mr. Ryan agreed that Day Of The Child was a great
project, however in our selection process for beneficiary children’s charities
that we needed to select certain charities that stood up against the mental
health establishment. Mr. Ryan demanded that Day Of The Child endorse
Scientology organizations that were supporting the attacks, lawsuits and other
tactics against the use of Ritalin with children. I became very disturbed with
Mr. Ryan's wanting to exchange his services for Day Of The Child supporting
Scientology based causes.
75. During
this same visit to Mr. Moxon’s office with Mr. Ryan, Mr. Steven Lewis called
for Mr. Moxon. Judy Ross advised Mr. Moxon that Mr. Lewis was on the phone. Mr.
Moxon said ok, thank you to Judy Ross and looked to me and said, "Watch
this." From the tone of Mr. Moxon's voice while talking with Mr. Lewis, it
was obvious to me that they were having fun. Mr. Moxon kept looking back at me
and smiling. Mr. Moxon was asking questions regarding Mr. Berry; where he kept
various things, and what was his response to this thing and that thing. After
the telephone conversation ended between Mr. Lewis and Mr. Moxon. Mr. Moxon
said, "I forgot to tell you that Lewis and Scali decided to terminate
their law practice with Berry and they want to work with us." I was truly
amazed at the turn of events. Mr. Moxon indicated that he was getting “dirty
laundry” from Mr. Lewis on Mr. Berry. In fact, Mr. Moxon said Mr. Lewis was
seeking advice from Mr. Moxon on how to get out from under Mr. Berry's request
that Mr. Lewis remain in place as council for Mr. Berry.
76. In
mid December, 1998, Mr. Moxon, Mr. Ryan and I had another meeting, wherein they
both introduced me to the Scientology based "Org. [Organization]
System", Mr. Moxon typed it out and printed a copy which was handed to me.
Mr. Ryan was demanding that Mr. Moxon and he could fill in each of the Org.
departments with Scientology personnel, which would leave me out of the
picture, other than as an ambassadorial representative.
77. In
late December, 1998, I held a Day Of The Child Christmas Party in Palm Springs.
Mr. Moxon and Mr. Ryan attended. Mr. Ryan and Mr. Moxon took me outside for
approximately 30 minutes and berated me on how Scientology could take over Day
Of The Child.
All Financial Activities Between Cipriano & Moxon
Conducted Through Day Of The Child
World Concert, Inc. Bank Of America Account
78. Between
November, 1998, and June, 1999, most if not all of the transactions,
financially and professionally, were handled through Day Of The Child World
Concert, Inc.’s bank account. (See Exhibit 37)
Mr. Moxon Purchases A
Packard-Bell Computer For Cipriano
79. On
December 17th, 1998, Mr. Moxon purchased at Packard-Bell Computer
for me on one of his credit cards from Circuit City in Hollywood. (See Exhibit
38) The charge was approximately $1,000.00 for the CPU, monitor and printer.
Mr. Moxon helped me carry it to my car and I returned him to his office.
Moxon Handled Custody Matter For
Cipriano's Girlfriend Leslie Lamborn
80. In
January, 1999, Mr. Moxon advised and created a Stipulation Of The Parties
between Leslie Keene Lamborn, my girlfriend and Jeff Appel her ex-boyfriend, on
my behalf, free of charge. (See Exhibit 39)
Meeting At Moxon's Office
To Talk About Michael Hurtado And
Other Acts Against Mr. Berry
81. In
early January 1999, I was called to a meeting at Mr. Moxon's office where Mr.
Ingram was waiting for me. At this meeting, I learned from Mr. Ingram, in front
of Mr. Moxon, that he and a group of Scientologists had plastered Mr. Berry’s
neighborhood with hate flyers, advising everyone in his neighborhood that Mr. Berry
was a pedophile. Mr. Ingram also told me about having spies and operatives in a
gay nightclub called Numbers in Los Angeles. He also told me, that there was a
young man named Mr. Hurtado who Mr. Ingram had found who would say that he went
home with Mr. Berry and a couple underage boys one night. Further that Mr.
Berry drugged the boys and had sex with them in front of Mr. Hurtado. Mr.
Ingram also stated that Mr. Berry was exchanging legal services for sex with
this Mr. Hurtado person and that Mr. Ingram was going to file a Bar Complaint.
82. Furthermore,
Mr. Ingram stated that Mr. Berry was trying to sue Mr. Ingram and could not
serve him. Mr. Ingram laughed at that
thought, claiming that Mr. Berry did not know what he looked liked and has been
as close a five inches from Mr. Berry on numerous occasions without Mr. Berry
knowing. Mr. Ingram also said, "The litigation and scare tactics against
Mr. Berry were just to make him go away and leave the Church of Scientology
alone."
83. Mr.
Ingram said that Mr. Berry had a roommate who was on the cover of some gay
porno magazine and that Mr. Ingram was looking for information on the publisher
of that type of magazine to ascertain how old the roommate was when the
pictures were taken.
Moxon & Ingram Have Cipriano
Infiltrate Los Angeles Youth Center
84. As
part of my Day Of The Child day to day activities, I would routinely interview
children's charities to review their operations. This is a process that must be
conducted in order for them to be a beneficiary of the proceeds of our events.
I interviewed a gentleman named Jason Whitman who organized and manages The Los
Angeles Youth Council on Santa Monica Blvd., in West Hollywood The LA Youth
Council works with males who are caught up with gay street prostitution. It
attempts to provide them with a career, housing and guidance.
85. Mr.
Moxon and Mr. Ingram thought it would be a good idea to have Mr. Whitman, who
works with numerous male prostitutes talk to the young men and distribute
flyers with a picture of Mr. Berry around West Hollywood. If anyone knew of Mr.
Berry or had any information on him they were guided to call a number on the
flyer. The information would be passed
on to Mr. Ingram for use by Mr. Moxon against Mr. Berry. A young man came
forward named Anthony Apodaca, who said he knew of or had seen Mr. Berry. This
information was passed on to Mr. Ingram and Mr. Moxon and Mr. Ingram was sent
to meet with Mr. Apodaca to obtain a Declaration. Mr. Whitman told me in a
telephone conversation in May 1999 that Mr. Ingram took Mr. Apodaca to a hotel
room, threatened him and paid him $300.00 for a Declaration. I do not know if a
Declaration was obtained or filed; however, I do know that Mr. Apodaca was
terrified and went in to hiding or disappeared at that same time.
Moxon Rents 5 Bedroom House
For Cipriano & Lamborn In Palm Springs, California
86. On
January 6th 1999, Mr. Moxon moved both Leslie Lamborn and me to 1050
Racquet Club Road in Palm Springs. Mr. Moxon signed the lease, “Kendrick Moxon
for Leslie and Robert Cipriano as occupants.” The rent was $1,295.00 per month
and the lease ran for one year. (See Exhibits 40, 41, 42, 43)
87. In
late January, 1999, Ms. Lamborn and I had serious differences and Mr. Moxon
asked Ms. Lamborn and me to meet him and Mr. Ryan at a restaurant in Malibu and
then proceeded to go to a secluded
beach front in Malibu, California. Mr. Moxon and Mr. Ryan wanted me close to
them and away from Leslie Lamborn and Donald Snodgrass. I moved out of the
house at the request of Mr. Moxon and back to Los Angeles, where I moved into a
friends’ house near Marina Del Rey.
Berry Dismissed Cipriano Case
88. Mr.
Moxon called me in early February, 1999 and advised me that Mr. Berry had
dismissed Krim and was about to dismiss me in his action. I met with Mr. Moxon
the next day and had him discuss the legal jargon regarding the dismissal. Mr.
Moxon said that the lawsuit was over for me. I asked him, "Can Mr. Berry
every come back and re-file?" Mr. Moxon said, "No."
89. I
was also informed by Mr. Moxon that they had attached Mr. Berry's bank accounts
and that Mr. Berry was leaving the country for good. Furthermore, that,
"Scientology finally achieved what they wanted." I said, "Well
then I served my purpose?" He said, "You certainly did."
90. I
had finally come to the conclusion that Scientology had no plan on keeping
their promises to me other than small handouts from time to time. I had come to
terms that it was all a game for Scientology and they had what they wanted.
91. On
March 8th 1999, Mr. Moxon asked me to work as an operative for
Scientology on ECT, a company that manufactures and distributes electro-shock
machines used by mental health facilities. (See Exhibit 44) Mr. Moxon wanted me to
obtain internal documents from The State Department Of Mental Health, VA
Hospital, UCLA, and various other hospitals, these documents included approved
consent forms. I told him, "I will think about it, that I had just about
had it with Scientology and all of its games."
92. On
or about March 12th 1999, I received a call from my friend, in Palm
Springs, Donald Snodgrass. He advised me that he had a partnership with Lassen
Galleries and was ready to open an art gallery in Palm Springs. He asked me to
come back to Palm Springs and assist him in running the gallery. Since I was
receiving no help, calls or any assistance from Mr. Moxon, I decided to take
the offer. I moved back to Palm Springs on or about March 12th 1999,
and began to work with Mr. Snodgrass. Mr. Moxon and I had two or three email
and phone communications between March 12th 1999, and June, 1999. I
advised Mr. Moxon of my move to Palm Springs. I requested that Mr. Moxon give
me and the Board Of Directors an immediate resignation from Day Of The Child
World Concert, Inc. Mr. Moxon provided the resignation.
93. On
March 20th 1999, I emailed Mr. Moxon responding to a phone message
from him. I advised him of my need for monies as per our previous agreement. I
state in the last line, "I also think that I was there for the cause-100%
and by all appearances-everyone should be pretty happy with my
performance." (See Exhibit 45) On March 21st 1999, Mr. Moxon
emailed me in return with, "Got It. Please give me a call so we can handle
the details." (See Exhibit 46).
94. May
and June, 1999, I spent in Palm Springs trying to get out from under the 1050
Racquet Club Road house and keep Day Of The Child up and running. I informed
Mr. Moxon in an email dated May 10th 1999, that I had a possible new
partner named Roy Webb and we were working on an agreement. Mr. Moxon indicated
that the house needed to be resolved. (See Exhibit 47)
95. Finally
on June 7th 1999, I sent my last email to Mr. Moxon begging for food
and gas money. I advised him that Day Of The Child was in Roy Webb's hands and
that I was moving the operation up to Anaheim to keep Day Of The Child alive. I
asked for $500.00. Mr. Moxon sent $195.00 by Western Union. (See Exhibit 48)
Mr. Webb called Mr. Moxon after my move to Anaheim and requested $1,000.00 for
me to restart my life after the past several years, and Ms. Judy Ross, Mr.
Moxon's legal secretary, arranged for a check to be made payable to
Professional Management, Roy Webb's company, in the amount of $800.00.
96. This
was the last communication with Mr. Moxon that we had other than Mr. Moxon’s calling
Mr. Webb in early July and asked him, "How is Robert's health?” In early
to mid July, I was contacted by Joanne Weaton, Eugene Ingram's Scientology
operative, via email. I was contacted and responded to Erla Hawkins, who is
with the IAS (International Association Of
Scientologists) (See Exhibit 49), who requested that I take a position
as head of public relations for a Scientology “crusade” in Europe starting July
22nd 1999. The position was for no pay and only a one-way ticket to
Europe plus accommodations. Ms. Erla Hawkins attempted to have me meet her on a
Saturday afternoon in an old, unmarked apartment in an unmarked building behind
a schoolhouse and L. Ron Hubbard Way. It is my full belief that if I had
attended that phony meeting, I may never have come back.
97. Since
then, I have been under surveillance and am followed daily by various autos. In
conclusion, I cannot stress enough that the acts of this fanatic organization
and its lawyers and officials have caused serious harm to me and to my organization,
Day Of The Child. I organized, created and built Day Of The Child to assist
hundreds of authentic children's charities in the United States. The acts of
Kendrick Moxon and Eugene Ingram as lawyer and operative for the Church of
Scientology and its many divisions have been literally grossly offensive and
illegal. As a result of their actions, Day Of The Child has been refused a
general 501c (3) status, which turned one of the foremost fundraising concert
events into nothing more than a waste of time. The Church of Scientology has
turned 500 children's charities one-chance fortune to share equally in a global
event's income into broken promises to every child in America that depends
on the deeds of people who truly care.
98. Furthermore,
I have learned in the past two to three months that the deepness of
Scientology's terror reaches into the lives of children, which I will never
stand by and tolerate. I have learned that children are held in paramilitary
camps and are forced to suffer cruel and inhuman acts while under the armed
guards of Scientology. This may be a customary practice in Scientology, however
this violates every human rights issue and federal and state law in place today
that protects children in America. It must be stopped immediately.
99. Day
Of The Child may have been defiled, if not devastated by the actions of the
Church Of Scientology, however my resolve to assist any child in need can not
be deterred. It is my most sacred desire that this Declaration will bring
attention by the proper law enforcement agencies to investigate and prosecute
these monsters.
100. I
personally became the subject of a bloodthirsty scheme of “dead agenting” and
“fair game” between the Church Of Scientology and Mr. Graham E. Berry, a lawyer
who subjects himself to the vengeance and destructive actions of Scientology.
It is absolutely obvious that Scientology conducted one of the most severe
“fair game” campaigns upon and to Mr. Berry in order to discourage him from
further anti-Scientology litigation. It is obvious that Mr. Berry has had his
entire personal life, false or not, broadcast across the world by the acts of
Mr. Ingram and Mr. Moxon.
101.
Attached hereto as Exhibit
50 is a true and correct copy of a declaration and exhibits that I executed on
July 16, 1999. I hereby confirm the contents thereof as being true and correct
both then and now, however since that time, and after having reviewed all of my
related files, letters, email communications and financial records, I have
incorporated the July 16, 1999, declaration with this final and complete
Declaration.
I declare under penalty of perjury under the
laws of the United States Of America and the State of California that the
foregoing is true and correct.
Executed this 5th day of August 1999 in Santa Monica, California.
___________________________________
ROBERT J. CIPRIANO