Declaration of Robert J.

Cipriano - August 5, 1999

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 ONeal. 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 Detectives 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 Mays 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. Spiegelmans 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. Spiegelmans including Mr.
Graham E. Berry. Mr. Ingram was very interested in Mr. Berrys 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. Berrys 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. Berrys personal
conduct, sexual habits and his legal clients. He asked me what I knew about Mr. Berrys 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 1980s 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 didnt know or recall how old they were." "Graham
Berry represented Studio 54." Mr. Ingram suddenly dropped it and went back to my situation in
Mays 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 1980s 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.
Eugene Ingrams
Second Visit With Ciprianos 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 Ingrams 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 Ingrams
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. Berrys 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 Moxons First Meeting &

Eugene Ingrams 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. Moxons 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 dont 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. Berrys 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[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 fianc, 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.

Mr. Moxon And Mr. Ingram

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 Providers 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

Hubbards 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 childrens charity concert that would benefit
over 500 childrens 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
th
44. April 30 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.
Cipriano Responds To Moxons Offer
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, Earthlinks participation,
the legal offices being at Moxon & Kobrins 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 Berrys 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 Ingrams 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. Berrys 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.
Berrys 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 Detectives 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. Ingrams 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 Home
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

World Concert, Inc. In Nevada For Cipriano
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

John Travolta & Michael Pattinson
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. Moxons instructions but,
to my knowledge, nothing came from it.
 Mr. Moxon Attempts To Arrange For Barbara Reeves Of
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 Childrens 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.
Mr. Moxon Leases a 1999 Saturn For Cipriano
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)
Mr. Snodgrass Offers To Pay Cipriano's
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)
Childrens 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 & Kobrins 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 childrens 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. Moxons 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)
Mr. Ingram, Mr. Moxon And Cipriano Have
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. Berrys 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.
Moxons 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