SCI
page 1 / 37
berry
---
title: "Fishman Declaration — berry"
source: https://www.cs.cmu.edu/~dst/Fishman/Declaration/berry.html
retrieved: 2026-06-28
---
'''
=================================================================
CHURCH OF
SCIENTOLOGY ) Case No. CV 91 6426 HLH (Tx)
INTERNATIONAL,
a California )
on-profit religious ) DECLARATION OF GRAHAM E.
organization, ) BERRY RE DEPOSITION TESTIMONY
) OF GARRY SCARFF IN SUPPORT OF
Plaintiff, ) COST BILL FOR DR. GEERTZ'S
) MOTION FOR AWARD OF COSTS,
vs. ) EXPENSES, ATTORNEY'S FEES AND
) SANCTIONS
STEVEN FISHMAN
AND UWE GEERTZ, )
) Date: APRIL 4, 1994
Defendants. ) Time: 10:00 a.m.
) Courtroom: 7
[Filed and served
concurrently with Dr.
Geertz's Bill of Costs.]
DECLARATION OF GRAHAM E. BERRY
I, GRAHAM E. BERRY, declare as follows:
1. I am an attorney at law licensed to practice before all the
Courts of the State of California and before this District
Court. I am a partner of Lewis, D'Amato, Bristois & Bisgaard,
attorneys of record for defendant Uwe Geertz, Ph.D.
("Dr. Geertz"). I have personal knowledge of all the matters set
forth herein and if called upon to do so I could and would
competently testify thereto under oath.
2. This declaration Concerns the deposition testimony of Garry
Scarff and is offered in support of the motion for costs, fees,
expenses and sanctions filed by Dr. Geertz.
3. I attended the deposition of Gerry Scarff taken in this action
over the course of 17 days during July and August 1993. Attached
hereto as Exhibit "A" is a true and correct copy of the exceprts
of Mr. Scraff's deposition testimony. The excerpts of testimony
are organized into subjects and a table of contents has been
prepared and is attached as part of Exhibit "A". In his
deposition, Mr. Scraff testified about various criminal and
wrongful activities directed by or discussed in the presence of
attorney's from the law offfices of Bowles & Moxon including:
death threats, Scientology's Fair Game doctrine, plans to kill
Cult Awareness Network presidnet Cynthia Kisser and attorney Ford
Greene, Threats against witnesses, instructions to commit
suicide, misdirecting and misleading investigations and
prosecutions of Scientology, the filing of frivolous lawsuits,
financial scams, lies and fraud by Scientology and similar
activities, all as set forth in Exhibit "A" hereto.
4. The testimony of Garry Scarff is offered to establish that
this action is frivolous and that CSI and its counsel have
engaged in a pattern of filing frivolous lawsuits to harass and
oppress their perceived opponents. I declare under penalty of
perjury that the foregoing is true and correct, and that this
declaration is executed under the laws of the State of California
on March 8, 1994 at Los Angeles, California.
Signed Graham E Berry
TABLE OF CONTENTS
[** :: This section of Scarff's full deposition is included here]
CRIMINAL ACTIVITIES DIRECTED BY OR DISCUSSED IN THE PRESENCE OF
ATTORNEYS FROM THE LAW OFFICES OF BOWLES & MOXON
** Death Threats for Testimony Critical of Scientology.... 1
** Death Threats by Eugene Ingram-Fair Game Doctrine 2
** Plan 100 Scheme-SLAPP Suits Against Cult Awareness Network 3
** Campaign to Incriminate Without Merit Cult Awareness Network 4
** Office of Special Affairs Operation attempting to get Criminal
Charges Reinstated Against Rick Ross ...............5
** Description of "Terminal" - Person in Chain of Command To Whom
One Reports..... 6
** Overt Operation Against Cult Awareness Network. Run
Conncurrently With Covert Operations Against CAN .... 7
** Deliberate Creation of False Declarations to be Used in
Litigation Against CAN. 9
** Substantiation of Scarff's Relationship With
Scientology............. 11
** Scarff's Scientologv Operations Against CAN; Scarff Defects
from Scientology. ...............12
** Ingram Paid Employee of Bowles & Moxon. Scarff Threatened
Because of operations against CAN 13
** Ingram Threatens Scarff if He Reveals Information About the
Church of Scientology: Family Threatened as Well ............15.
** Al Post? Threatens Scarff: Scarff Describes Fair Game Doctrine
and its current use 19
** Scarff Uses His Access to Law Enforcement Data Systems and
National Crime Information Computer to Run Names of Perceived
Enemies for CSI: Criminal Records Stolen and Destroyed on CSI
Orders; Records First Reviewed by Office of Special Affairs-Gwen
Mayfield 22
** Operation Snow White 26
** Operations Against CAN Described. 27
** Stolen Criminal Documents to be Used to get Cynthia Kisser and
Anne Greek Arrested 28
** Gwen Mayfield, Director of Special Affairs for the Mission of
Davis in Portland. Directs Scarff to go to Courthouse and Steal