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GRAHAM E. BERRY (SBN: 128503)
CHRISTIAN J. SCALI (SBN: 19378)
BERRY, LEWIS, SCALI & STOJKOVIC
One Wilshire Boulevard
Twenty-First Floor
Los Angeles, California 90017-3383
Telephone:(213) 833-5900
Facsimile:(213) 833-5909

Attorneys for Plaintiff
GRAHAM E. BERRY



	SUPERIOR COURT OF THE STATE OF CALIFORNIA

	COUNTY OF LOS ANGELES



GRAHAM E. BERRY,

                 Plaintiff,

     vs.

GLENN BARTON, an individual, the CAN Reform Group, an unincorporated
association of individuals, Cult Awareness Network, an organization
whose
legal status is currently unknown, Cult Awareness Network Corporation,
a
California corporation, Nancy O'Meara, an individual, Robert Lippman,
an
individual, Isadore "Izzy" Chait, an individual, Donna Casselman, an
individual, W. Russell Shaw, an individual, and DOES 1 through 400,
inclusive,

                 Defendants.
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                                        )	Case No. BC 186188

FIRST AMENDED COMPLAINT FOR INJUNCTIVE RELIEF AND DAMAGES FOR:

(1)	LIBEL
(2)	SLANDER
(3)	INVASION OF PRIVACY
(4)	INVASION OF PRIVACY (PRIVATE FACTS)
(5) 	INVASION OF PRIVACY (FALSE LIGHT)
(6)	OUTRAGE - PRIMA FACIE TORT
(7)	INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
(8)	NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS
(9)	CONSPIRACY

JURY TRIAL DEMANDED



	COMES NOW Plaintiff, GRAHAM E. BERRY, an individual, and
alleges as follows:
 	INTRODUCTION

	1.	This Complaint involves possibly the most egregious,
extensive and
permanent defamation, invasion of privacy and conspiracy in legal
history.
Among other things, Defendants have directly or implicitly accused
Plaintiff
of participating in murder, torture, kidnapping, slavery, illegal baby
brokering, criminal sexual activity, prostitution, the production and
importation of snuff movies, public sexual activity, scatological
sexual
practices, lewd conduct, art fraud, financial fraud, lying,
dishonesty,
assault, violent behavior, threatening behavior, aggressive behavior,
obnoxious behavior, drug running, loan sharking, fencing stolen art,
sado-
masochistic sexual activity, sexual perversion, associating with mafia
mobsters, establishing fraudulent businesses with lascivious intent,
creating
a hostile and abusive work environment, giving cocaine to 40-60 14-16
year old
boys in exchange for their unlawful employment services, academic
incompetence, professional incompetence and having H.I.V. or AIDS.

	The defamatory statements are defamatory per se directed to
persons known to
be associated with the Plaintiff including to persons such as
Plaintiff's
friends, acquaintances, professional partners, the clients of his
professional
partners, opposing counsel, clients, potential clients, former
clients,
legislators (as far afield as New Zealand), members of the judiciary,
members
of the media (as far afield as Germany) neighbors and others.  In
addition,
these defamatory publications have been directed to charitable
organizations,
to the entire Board of Education and many other officials of the Los
Angeles
Unified School District, accompanied by statements and innuendoes, for
example, that the Plaintiff is a child molester, under investigation
for child
molestation, under investigation for other criminal conduct, and a
thief of
monies raised for charity, and that the various organizations and
others
should have nothing to do with the Plaintiff.

	These publications have also been made, on a continuous daily
basis and
continue forever to be made, through numerous 'sites' and 'postings'
on the
"electronic superhighway" commonly known as "the Internet." 
Consequently, the
most outrageous, salacious, defamatory and damaging statements
imaginable have
been intentionally and broadly disseminated worldwide as extensively
and
permanently as has ever occurred before in the history of any legal
system
anywhere. Indeed, as a result of certain electronic internet
transmissions
being conducted via satellite, these defamatory and damaging
statements are
being constantly published throughout the universe and will continue
to be
published into infinity.

	Therefore actual damages are enormous, and, as a matter of
law, damages are
presumed.  Defendants' defamatory and other statements have been used
by
persons unknown, but presumed to be associated with the tax-exempt,
dangerous
and paranoic cult, commercial enterprise and political organizations
trading
as the corporation(s) and church(es) of scientology and its/their
agents and
representatives, including Kendrick L. Moxon, Esq. and private
investigator
Eugene M. Ingram, and others particularly skilled in the low art of
guilt by
association, in breach of the Church of Scientology's relevant and
material
representations to the Internal Revenue Service regarding its pre and
post-1991 litigation and harassing conduct, in an unprecedented
"operation" or
"project" to "destroy" and "to utterly ruin" the Plaintiff through the
application of certain writings of the late science fiction writer,
paranoid
schizophrenic, fraud and charlatan L. Ron Hubbard such as "The Manual
of
Justice"; "fair game," "black propaganda," noisy investigation," "on
control
and lying" and "dead agenting." Despite Church of Scientology claims
that the
"Fair Game" policy was cancelled in 1966, Scientology's "Fair Game"
policy has
been judicially recognized (during the 1980's and 1990's) in a number
of
judicial decisions in California and elsewhere.

	The Church of Scientology also conducted a similar
character-smear
"operation" against a Canadian lawyer resulting in two recent
multi-million
dollar damage awards against the church.  Furthermore, these were the
two
largest ever defamation awards in Canadian history.  The Church of
Scientology
recently became the first so-called religious organization to be
convicted of
criminal conduct in Canada.

	The conspiracy continues, for example, through its instigators
Kendrick L.
Moxon, Esq.  and his clients such as the Church of Scientology
soliciting, and
paying for, the legal representation of defendant Cipriano in related
litigation (Berry v. Cipriano, et al., L.A.S.C. Case No. BC 184355)
notwithstanding the obvious non-waivable conflict of interest that
exists
between defendant Cipriano and material witness and potential
defendant
Kendrick L. Moxon, Esq.  Moreover, after the filing of this lawsuit,
Kendrick
L. Moxon, Esq. retained and directed Scientology investigator Eugene
Ingram to
continue to engage in the dissemination of the perjured statements
originally
obtained by Eugene Ingram at the request of Kendrick Moxon, Esq. and
the
Church of Scientology's Office of Special Affairs.  During said
continued
investigation/dissemination Eugene Ingram has alleged concern that I
will drug
into a coma, and then homosexually rape, my 22 year old housemate with
whom I
have a platonic and mentor/mentee __________.  Eugene Ingram's
telephone
number includes the #'s 666, the number of the anti-Christ beast given
in
Revelation's Chapter 13.

	In furtherance of this conspiracy, inter alia, each
Defendant's defamatory
and other damaging statements have been published, and to this very
day
continue to be published, orally and in writing, mechanically,
electronically
and telephonically, through the mails, telephone lines, cable lines,
airwaves
and satellite transmissions. This action is one of three related cases
to be
filed, or to be filed, in this courthouse.


	GENERAL ALLEGATIONS COMMON TO ALL CAUSES OF ACTION

	2.	At all times mentioned herein, Plaintiff Graham E.
Berry (hereinafter
"Plaintiff") was a resident of the County of Los Angeles, State of
California,
and engaged in the practice of law. He had previously been engaged in
the
practice of law in New York, New York; London, England; Sydney,
Australia; and
Christchurch, New Zealand.  At all times mentioned herein, Plaintiff
has
enjoyed a good reputation generally and specifically in his occupation
as an
attorney.  Moreover, Plaintiff has enjoyed a reputation as a person
possessing
traits of honesty, integrity, truthfulness and veracity, both within
the
relevant social community, and within the professional community of
Los
Angeles area lawyers, judges and others involved in the judicial
system.  At
the time of the initial publication of the various defamatory
statements
alleged herein, Plaintiff was not a public figure and/or was a public
figure
only for limited purposes.

	3.	At all times mentioned herein, Defendant Glenn Barton
("Barton") was a
resident of the State of California and conducting his business
activities in
the County of Los Angeles.

	4.	At all material times mentioned herein, defendant
Barton was a member of,
and/or associated with, defendant CAN Reform Group, and its affiliates
and
successors, and was actively engaged and participating, either
directly or
indirectly, in its activities directed at, or concerning Plaintiff, as
alleged
herein.

	5.	At all times mentioned herein, defendant CAN Reform
Group ("CAN Reform
Group") was/is an association of persons believed to include members
of the
unincorporated organization known as the Scientology Sea Organization
("Sea
Org"), staff members of the various corporations and church of
scientology,
public members of the church of scientology, and attorneys and private
investigators retained by, or working for, one or more of the numerous
corporations and church(es) of scientology.

	6.	At all material times, defendant Cult Awareness
Network Corporation ("Can-
Corp.") Can-Corp and/or "New Can" was a California corporation
incorporated on
or about February 12, 1997 by one Nancy O'Meara and having its
registered
address at 1015 Oneonata Drive, Los Angeles, CA 90065 and doing
business at
such locations, etc. as alleged in Paragraph 8 hereunder.

	7.	Upon information and belief, sometime during 1996 and
1997, persons
associated with, or involved with defendants Barton, CAN Reform Group,
New
Can, CAN-CORP., O'Meara, Lippman, Chait, Casselman and Shaw and Does 1
through
400 inclusive, acquired certain name brand assets of the Cult
Awareness
Network ("Old Can") the IRS section 501(c) (3) corporation which had
filed
bankruptcy in the State of Illinois as a result of the activities of
persons
associated with, or involved with, defendants Glenn Barton, CAN Reform
Group,
New Can, CAN-CORP., O'Meara, Lippman, Chait, Group and Does 1 through
400, and
such persons have merged and integrated the activities, objectives and
operations into the Cult Awareness Network or ("New Can") in such a
manner and
to such an extent that defendants CAN Reform Group and New Can and/or
CANCORP., along with defendants Barton, Lippman, O'Meara, Chait,
Casselman and
Shaw, can be considered and deemed the alter egos of each other and
one entity
or association for all legal purposes including but not limited to the
allegations and claims asserted by Plaintiff herein.

	8.	At all material times mentioned herein, Defendants CAN
Reform Group and
Cult Awareness Network and New Can were either incorporated or
unincorporated
associations or entities conducting their/its activities from
locations within
the County of Los Angeles through persons including, but not limited
to,
defendants O'Meara, Lippman, Chait, Casselman and Shaw.  The exact
legal
status of CAN Reform Group and/or New Can cannot be ascertained from
the
appropriate public files.  However, New Can does maintain an internet
web site
(www.cultawarenessnet.com) and conducts business through (800)
556-3055, (213)
468-0567 and telephonically lists its address as being at 1680 Vine
Street at
Los Angeles, California.

	9.	At all times mentioned herein, Defendant Nancy O'Meara
("O'Meara") was a
resident of the State of California and conducting business activities
in the
County of Los Angeles through, inter alia, Can Reform Group and New
Can.

	10.	At all times mentioned herein, Defendant Robert
Lippman ("Lippman") was a
resident of the State of California and conducting business activities
in the
County of Los Angeles through, inter alia, Can Reform Group and New
Can.

	11.	At all times mentioned herein, Defendant Isadore
(a/k/a Izzy Chait") was
a resident of the State of California and conducting business
activities in
the County of Los Angeles through, inter alia, Can Reform Group, New
Can and
Izzy Chait Galleries.

	12.	At all times mentioned herein, Defendant Donna
Casselman ("Casselman")
was a resident of the State of California and conducting business
activities
in the County of Los Angeles through, inter alia, Can Reform Group and
New
Can.

	13.	At all times mentioned herein, Defendant W. Russell
Shaw ("Shaw") was a
resident of the City of Phoenix in the State of Arizona and
responsible for
posting the internet website "Rogues Gallery of ARS Bigots" located at
http://www.dancris.com/~rshaw/hotnews2.htm.

	14.	Defendants Does 1 through 400, inclusive, are
fictitious defendants sued
pursuant to Code of Civil Procedure, Section 474. Plaintiff is
informed and
believes, and on that basis, alleges that each of the fictitious
Defendants
was in some way responsible for, participated in, and contributed to
the
matters and things of which Plaintiff complains herein, and in some
fashion,
has legal responsibility therefore.  When Plaintiff ascertains the
exact
nature and identity of the Defendants who are also responsible for,
participated in, and contributed to, the matters and things herein
alleged,
Plaintiff will seek to amend this Complaint and all proceedings herein
to set
forth the same.

	15.	At all times mentioned herein, each and every
Defendant was the
authorized agent, servant and/or employee of each and every other
Defendant
and was acting within the scope of his/her/their authority as agents,
servants
and employees with the permission and consent of their co-Defendants.
Reference to "Defendants" shall mean Defendants and each of them.

	16.	Plaintiff is informed and believes and based thereon
alleges that the
officers and/or managers of all corporations, partnerships,
associations,
entities and/or businesses named in this lawsuit confirmed, directed,
authorized, instructed, were aware of, encouraged and/or ratified the
acts and
omissions of all remaining defendants herein.

	17.	At all times mentioned herein, each and every
Defendant was the alter ego
of the other such as to constitute a unity of interest among them all,
severally and collectively.

	18.	At all times mentioned herein, each and every
Defendant was the co-
conspirator of the other and acting to further the acts alleged
herein,
pursuant to same relationship.

	19.	Venue is proper in that publication of the false and
defamatory
statements made by each of the defendants has occurred, and continues
to
occur, within the City of Los Angeles, County of Los Angeles and
within the
Central District of the Los Angeles Superior Court.  Subject matter
jurisdiction vests in the Superior Court by virtue of Code of Civil
Procedure,
? 410.50, and in that equitable relief is sought and the amount in
controversy
exceeds the jurisdictional limits of the Municipal Courts under Code
of Civil
Procedure, ? 86(a) (1).


	FIRST CAUSE OF ACTION

	(Defamation By Libel, Libel Per Se, Slander,
	Slander Per Se Against All Defendants
	And Does 1 Through 400)

	20.	Plaintiff repeats, re-alleges and incorporates herein
by reference each
and every allegation contained in Paragraphs 2 through 19 inclusive,
of the
general allegations of this Complaint, as if fully set forth herein.

	21.	On February 11, 1998, Plaintiff discovered that Glenn
Barton, and the
other individual defendants except Shaw, had been responsible, at all
relevant
times herein, in whole or in part, for the activities and publications
of the
CAN Reform Group.

	22.	The objectives of the CAN Reform Group included the
destruction of the
Cult Awareness Network, Inc. ("Old CAN") and all those believed by the
CAN
Reform Group, CAN-CORP and/or New Can, to be associated with it, or
opposed
to, the objectives of the group or combination conducting the
activities of
the corporations and churches of scientology.  In pursuing these
objectives,
the CAN Reform Group, New Can and CAN-CORP applied the policies,
bulletins,
issues and other sacred scriptures of the Church of Scientology, as
authored
by L. Ron Hubbard, such as the "Fair Game" policy and related
anti-societal
policies including but not limited to "Black Propaganda", "Noisy
Investigation" and "Dead Agenting".

	23.	During 1996 and 1997, associates and/or members of the
CAN Reform Group
through one Steven Hayes, Esq., acquired certain name-brand assets of
the Old
CAN and now operate it as the New Can and/or CAN-CORP.

	24.	Upon information and belief, the New Can and/or
CAN-CORP is front group
of organizations constituting a dangerous cult, commercial enterprise
and
seditious political movement intent upon world-wide totalitarian rule
and
trading as the corporations and churches of scientology.

	25.	Upon information and belief, the composition,
activities and objectives
of the CAN Reform Group, CAN-CORP, and the New Can, and that of the
other
defendants herein, have been so merged, commingled and intertwined
that each
may be deemed, at law, the alter ego of the other and treated for all
legal
purposes, as one and the same group of individuals associated
therewith
without separation of legal identity for the purposes of liability
herein.

	26.	Upon information and belief, CAN-CORP and/or the New
Can is/are the
successor(s) in law, interest and liability to the CAN Reform Group.

	27.	Upon information and belief, certain officers and
personnel of the
Scientology Sea Organization, and at least one of the corporations
and/or
churches of scientology, along with certain scientology retained
attorneys and
private investigators, are responsible, in whole or in part, for the
activities of the CAN Reform Group, CAN-CORP, and subsequently New Can
at all
relevant times herein.

	28.	At various times between 1993 and the present day, as
further alleged in
Paragraph 28 herein, Defendants have published, caused to be published
and/or
permitted to be published, unprivileged, false, defamatory and
malicious
claims ("the publications and/or the claims") of and concerning
Plaintiff,
specified below, including but not limited to the following:

		(a)	That Plaintiff engages in unscrupulous
activities;

		(b)	That Plaintiff paid thousands of dollars to
former Church of Scientology
members to sign false statements making numerous false claims about
the
church(es) of scientology;

		(c)	That Plaintiff paid former church of
scientology member Andre Tabayoyon
$17,000 for a sworn statement consisting of numerous falsehoods;

		(d)	That Plaintiff paid over $70,000 to other
witnesses for false testimony;

		(e)	That Plaintiff committed the crime of
extortion in connection with
financial demands made upon the Church of Scientology;

		(f)	That Plaintiff created the Tabayoyon
Declaration which contained false
and/or perjurious statements lacking in credibility;

		(g)	That Plaintiff engaged in unconscionable
litigation tactics;

		(h)	That Plaintiff tampered with evidence;

		(i)	That Plaintiff made extortionate demands for
money;

		(j)	That Plaintiff engaged in sinister conduct;

		(k)	That Plaintiff engaged in scams;

		(l)	That Plaintiff has a history replete with
underhanded deals;

		(m)	That Plaintiff was an individual of dubious
character and that all
persons would do well to avoid him and not do business with him;

		(n)	That Plaintiff, through his then partners'
alleged activities, had
sparked off the insurance reform law of New York State;

		(o)	That Plaintiff had left the United States to
avoid criminal indictment;

		(p)	That Plaintiff was engaged in insurance fraud
and scams with Lawrence
Wollersheim and R. Vaughn Young;

		(q)	That Plaintiff, R. Vaughn Young, F.A.C.T. Net
and Wollersheim were
engaged in a scheme to commit fraud upon F.A.C.T.Net's insurance
company;

		(r)	That Plaintiff, and other F.A.C.T Net
co-conspirators, had conspired to
frame the Church of Scientology for certain criminal activity
allegedly
involving one Steven Fishman;

		(s)	That Plaintiff and one Lawrence Wollersheim
conspired to commit fraud
upon or otherwise make false misrepresentation to, an insurance
carrier, in
connection with certain copyright violation litigation;

		(t)	That Plaintiff improperly solicited one
Lawrence Wollersheim's legal
business and intended to improperly obtain money from an insurance
company to
pay for such work;

		(u)	That in the Fishman libel case, Plaintiff and
other co-conspirators,
tried to frame the church(es) and corporations of scientology for
Fishman's
criminal activity;

		(v)	That Plaintiff used client-insurance carrier
monies to pay for
fraudulent testimony and/or lies in the Fishman-Geertz libel case;

		(w)	That Plaintiff has a long history of
involvement with criminals;

		(x)	That Plaintiff has a long history of
involvement with criminal
activities;

		(y)	That Plaintiff was involved in a law
partnership famous in law
enforcement circles for bilking out clients of millions of awards they
were to
receive.

		(z)	That Plaintiff fled the jurisdiction of New
York to avoid a felony
complaint for first degree fraud and forgery;

		(aa)	That Plaintiff had concealed his
quasi-limited-partnership with a
certain subsequently convicted felon, from New York Bar and law
enforcement
authorities;

		(bb)	That Plaintiff abused cocaine in his law
office;

		(cc)	That Plaintiff is an avowed homosexual who has
a penchant for young
boys;

		(dd)	That Plaintiff committed statutory rape and/or
acts of indecency and/or
acts of lewd conduct;

		(ee)	That Plaintiff engaged in at least 50 to 60
acts of statutory rape,
acts of indecency and/or acts of lewd conduct;

		(ff)	That Plaintiff had taken a twelve year old boy
to a notorious gay,
sado-masochistic club in Greenwich Village in New York City, for the
purpose
of introducing him to gay sex;

		(gg)	That Plaintiff frequented the Anvil Club, a
notorious gay, sado-
masochistic club in Greenwich Village, New York City;

		(hh)	That Plaintiff was associated with Andrew
Crispo, who was involved in
the brutal and sadistic kidnapping and murder of a male model in 1985,
and
that Andrew Crispo was either one of Plaintiff's clients or part of
Plaintiff's entourage;

		(ii)	That Plaintiff was associated with Bernard
LeGeros who was convicted of
a brutal sadistic kidnapping and murder of a male model in 1985;

		(jj)	That Plaintiff was involved with the
importation of gay "Snuff" movies
(which contain actual sex/murders on film);

		(kk)	That Plaintiff was involved with a game called
"knockoff" which was a
pyramid scheme engineered by Andrew Crispo and Sandi Franklin;

		(ll)	That Plaintiff's then law partner was involved
with mafiosi and engaged
in art fraud, illegal brokering of infants (baby brokering), and the
enticement and drugging of females in the United States and their sale
as
white slaves to clients in Tunisia and Morocco;

		(mm)	That Plaintiff purchased testimony to support
the allegations of his
clients;

		(nn)	That Defendants' had conducted an
investigation of Plaintiff which had
revealed shocking evidence of homosexuality with underage boys,
perversion,
associates dying of AIDS, financial crimes ... and a host of other
acts;

		(oo)	That Plaintiff preferred underage boys for his
sexual gratification;

		(pp)	That Plaintiff was so perverted that he makes
former CAN President
Michael Bohos look like a Sunday school teacher;

		(qq)	That Plaintiff was into perverted practices; 

		(rr)	That Plaintiff had described an incident in
which Plaintiff paid a kid
$200.00 to have the kid defecate upon him;

		(ss)	That Plaintiff frequented a sleazy male
prostitute bar called the
Haymarket;

		(tt)	That Plaintiff frequented the company of Andy
Warhol and Ray Cohn;

		(uu)	That there has not been a single witness used
by Plaintiff who was not
paid an exorbitant sum for his testimony;

		(vv)	That Plaintiff's entire stock in trade
consisted in the purchase of
perjured testimony;

		(ww)	That Plaintiff paid thousands of dollars, from
insurance backers, for
perjured testimony about the Church of Scientology;

		(xx)	That Plaintiff falsified and/or tampered with
affidavits sworn by Vicki
and Richard Aznaran;

		(yy)	That another witness complained that the
Plaintiff had complained of
the same type of unethical behavior as alleged immediately above;

		(zz)	That Plaintiff's unethical conduct goes back
for years;

	    (aaa)	That Plaintiff had fled the United States in
early 1986 around the
time that his law partner was being arrested (and later convicted) of
one of
the largest embezzlement schemes in the history of New York law and
that
Plaintiff had filed bankruptcy in connection with his alleged
liability for
said embezzlement scheme;

	    (bbb)	That Plaintiff engaged in the commission of a
massive insurance
fraud in excess of $900,000.00;

	    (ccc)	That Plaintiff engaged in a conspiracy to
commit perjury with one
Steven Fishman, R. Vaughn Young and Stacy Young;

	    (ddd)	That Plaintiff paid R. Vaughn Young and Stacy
Young for perjured
testimony;

	    (eee)	That Plaintiff conspired with others,
including but not limited to
Andre and Mary Tabayoyon, and Vaughn and Stacy Young, to fabricate
anti-
scientology testimony in exchange for the payment of money;

	    (fff)	That Plaintiff operated F.A.C.T.Net in cahoots
with Lawrence
Wollersheim and that therefore Plaintiff was involved in the
fraudulent
activities and other illegal activities that Defendants allege of
Lawrence
Wollersheim;

	    (ggg)	That Plaintiff was possibly a patient of Dr.
A. Sonnabend, M.D. who
was researching AIDS and was a virologist and microbiologist who
specialized
in infectious loathsome diseases, especially sexually transmitted
diseases;

	    (hhh)	That Plaintiff was not involved in the
day-today operations of the
[AIDS Medical] Foundation;

	    (iii)	That Plaintiff was merely the attorney
selected by Dr. Sonnabend
and Dr. Mathilde Krim to draw up the [AIDS Medical] Foundation's
incorporation
papers;

	    (jjj)	That the friendly relationship between
Plaintiff and Dr. Mathilde
Krim "quickly turned very ugly";

	    (kkk)	That the Plaintiff thought he could push Dr.
Mathilde Krim around
and treated her without respect;

	    (lll)	That Plaintiff became very obnoxious and
aggressive towards Dr.
Mathilde Krim;

	    (mmm)	That Plaintiff threatened Dr. Mathilde Krim;

	    (nnn)	That Plaintiff thought he could push Dr.
Mathilde Krim around and
treated her without respect;

	    (ooo)	That Dr. Mathilde Krim brought in a senior
partner of the law firm
of Phillips, Nizer, Benjamin, Krim & Ballen, Eugene Klein to
straighten out
Plaintiff;

	    (ppp)	That Plaintiff has either asserted or
insinuated that he had been
involved in AmFAR;

	29.	Defendants made these statements with the intent and
knowledge that such
statements were likely to be published and republished that such
publication
was not only reasonably foreseeable but would result in immediate and
severe
loss of reputation for Plaintiff.

	30.	Defendants' false claims have in fact been published
in the State of
California and throughout the entire world, and continue to be
published on a
continuing daily basis to Plaintiff's friends, acquaintances, business
partners and associates, professional associates, professional peers,
legislators (as far afield as New Zealand), members of the judiciary,
clients,
former clients, prospective clients, and others not even known to him
through
personal delivery of the Publications to such persons, publication of
the
claims in magazines and newsletters, publication of the claims on
different
web sites (such as the Website of ARS Bigots located at
http://www.dancris.com/~rshaw/hotnews.2htm, chat lines and news groups
of what
is commonly called the Internet and to the directors, officers and
volunteers
of charities which have/had sought Plaintiff's involvement.  Said
publications
have been broadly distributed, and continue to be distributed, on a
daily
basis in the geographic areas in which Plaintiff conducts his personal
and
professional activities, including Los Angeles County, California and
throughout the entire world.  A copy of one such publication of
Defendants is
attached hereto as Exhibit A, and the contents thereof expressly
incorporated
herein in their entirety.  A copy of another such publication of the
Defendants, recently downloaded from an internet site, is also
attached hereto
as Exhibit B, and the contents thereof are expressly incorporated
herein in
their entirety.

	31.	The statements set forth in Paragraph 28 above, and in
the publications,
were accurately quoted and republished as set forth in Paragraph 30
above.

	32.	The false and defamatory statements made by Defendants
as set forth in
Paragraph 28, above, inter alia, were of and concerning Plaintiff.

	33.	In the Publications, by the use of the particular
words set forth in
Paragraph 28 above, Defendants conveyed the following false and
defamatory
implications, innuendo and meanings of and concerning Plaintiff:

	(a)	That Plaintiff was/is unscrupulous in his practice and
profession as an
attorney and counselor at law.  The common and customary meaning of
unscrupulous is to be lacking in high standards of ethics, excellence
or
principles;

	(b)	That Plaintiff habitually and frequently paid numerous
persons
significant sums of money for perjured testimony.  The common and
customary
meaning of perjury is to swear to what is untrue.  Perjury is a felony
crime.

	(c)	That Plaintiff had paid a person(s) money to provide
perjured testimony.
The common and customary meaning of perjury is to swear to what is
untrue.
Perjury is a felony crime.

	(d)	That Plaintiff had engaged in unconscionable
litigation tactics, contrary
to law.  The common and customary meaning of unconscionable includes
conduct
that is shockingly unfair, harsh, unjust and outrageous;

	(e)	That Plaintiff had tampered with evidence, contrary to
law; and had
therefore engaged in serious criminal conduct.

	(f)	That Plaintiff had committed the crime of extortion;

	(g)	That Plaintiff engaged in sinister conduct, as part of
his practice of
law.  The common and customary meaning of sinister conduct includes
conduct
that is evil, dishonest, wicked and fraudulent;

	(h)	That Plaintiff engaged in scams as part of his
practice of law.  The
common and customary meaning of scam includes financial fraud;

	(i)	That Plaintiff was a person of bad character,
individually and as a
practicing lawyer and by innuendo, that plaintiff was a dishonest
lawyer;

	(j)	That Plaintiff's professional character was so dubious
that no person
should engage his professional services or share his acquaintanceship,
friendship or charitable activities.  The common and customary meaning
of
dubious includes a person characterized by qualities that occasion
suspicion,
mistrust, disparaging suggestion or hesitation;

	(k)	That Plaintiff has been involved with many underhanded
deals for a very
long time and, by innuendo, was involved in many fraudulent business
deals and
activities;

	(l)	That Plaintiff had been involved in fraudulent
insurance activities that
caused the insurance reform law in New York State;

	(m)	That Plaintiff was involved in insurance fraud and
financial scams with
Lawrence Wollersheim and R. Vaughn Young;

	(n)	That Plaintiff, F.A.C.T. Net, R. Vaughn Young and
Lawrence Wollersheim
were involved in a conspiracy to commit insurance fraud upon F.A.C.T.
Net's
Insurance Company;

	(o)	That Plaintiff had conspired to frame the Church of
Scientology for
certain criminal activity allegedly involving one Steven Fishman and,
by
innuendo, that Plaintiff was engaged in criminal conduct such as the
subornation of perjury;

	(p)	That Plaintiff and Lawrence Wollersheim were engaged
in insurance fraud,
fraud upon insurance companies, and making false representations to
insurance
companies;

	(q)	That Plaintiff improperly solicited legal business
and, by innuendo,
violated the canons of Professional Conduct;

	(r)	That Plaintiff improperly obtained money from
insurance companies to pay
for the legal services he provided to Lawrence Wollersheim;

	(s)	That Plaintiff was famous in law enforcement circles
for bilking his
clients out of millions of awards they were to receive and, by
innuendo, had
stolen millions of dollars from his clients;

	(t)	That Plaintiff was involved with an illegal pyramid
scheme called
"knockoff" and, by innuendo, was involved with criminal and securities
fraud;

	(u)	That Plaintiff was involved with mafiosi and engaged
in art fraud,
illegal baby brokering, kidnapping and white slavery;

	(v)	That Plaintiff had a long history of associating with
criminals;

	(w)	That Plaintiff had a long history of associating with
criminal
activities;

	(x)	That Plaintiff had fled the country and evaded felony
prosecutions for
fraud and forgery in the State of New York;

	(y)	That Plaintiff had intentionally deceived the New York
State Bar and
State of New York law enforcement authorities;

	(z)	That Plaintiff is an avowed homosexual with a penchant
for young boys
and, by innuendo, engaged in serious unlawful sexual activity;

	(aa)	That Plaintiff's conduct was many times more perverted
than that
defendants alleged of one Michael Bohos who was formerly President of
Old CAN
and, by innuendo, Plaintiff was engaged in the commission of serious
felonies.

	(bb)	That Plaintiff had committed one/numerous act(s) of
statutory rape,
pedophilia, indecency, lewd conduct or otherwise had violated the
criminal and
moral code(s) in connection with his alleged sexual relationships, and
alleged
relationships, with minors;

	(cc)	That Plaintiff is involved in sado-masochistic sexual
acts;

	(dd)	That Plaintiff was involved in a brutal sadistic
kidnapping and murder; 

	(ee)	That Plaintiff associated with a person(s) involved in
a brutal sadistic
kidnapping and murder;

	(ff)	That Plaintiff was involved with the importation of
gay "snuff" movies,
which involved sex and actual murder on film;

	(gg)	That Plaintiff frequented the Anvil Club, a notorious
gay sado-
masochistic club in Greenwich Village, New York City, and engaged in
sado-
masochistic activities.

	(hh)	That Plaintiff had committed the serious crime of
perjury and, by
innuendo, he had sworn to that which was not true;

	(ii)	That Plaintiff's entire professional practice involved
the purchase of
perjured testimony and by innuendo, all of his clients and witnesses
extending
back 25 years had sworn to that which was not true;

	(jj)	That Plaintiff had never called a witness who had not
been paid, and/or
paid exorbitant sum for his testimony.

	(kk)	That Plaintiff is engaged in insurance fraud; 

	(ll)	That Plaintiff had been engaged in a massive insurance
fraud;

	(mm)	That Plaintiff had conspired to commit, and had
committed, perjury with
Steven Fishman, R. Vaughn Young, Stacy Young, Andre Tabayoyon, Mary
Tabayoyon
and others.

	(nn)	That Plaintiff had paid for R. Vaughn Young, Stacy
Young, Andre
Tabayoyon and Mary Tabayoyon to commit perjury.

	(oo)	Plaintiff was under the medical care of a virologist
and microbiologist
who specialized in infectious, contagious and otherwise loathsome
diseases,
particularly infectious diseases and who was engaged in AIDS research
and that
therefore, Plaintiff had HIV, AIDS or some other vile, infectious and
loathsome disease;

	(pp)	Plaintiff was not involved in the day-to-day
operations of the [AIDS
Medical] Foundation and had therefore, lied about his involvement
therein;

	(qq)	Plaintiff was merely an attorney selected by Dr.
Sonnabend and Dr. Krim
to draw up the [AIDS Medical] Foundation's incorporation papers and,
by
innuendo, that Plaintiff was a liar;

	(rr) Plaintiff attempted to oust Dr. Krim as Chairman, and to
take over as
Chairman, of the Board of the [AIDS Medical] Foundation and, by
innuendo,
Plaintiff was a meglamaniac;

	(ss)	Plaintiff engaged in ugly, obnoxious and aggressive
behavior towards Dr.
Krim.  The common and customary meaning of obnoxious is offensive,
odious,
forming an object of dislike or disgust.  The common and customary
meaning of
aggressive is culpable, unprovoked, overt and hostile conduct;

	(tt)	Plaintiff threatened Dr. Krim.  The common and
customary meaning of
directing is to express the intention to inflict evil, injury, damage,
loss,
harm, bodily harm to another, or to threaten another's welfare through
coercion, duress, menace, promises and threats of reprisals and
punishment;

	(uu)	Plaintiff met with Phillips, Nizer, Benjamin Krim &
Ballen, senior
partner Eugene Klein who convinced Plaintiff to change his conduct as
alleged
above;

	(vv)	Plaintiff has asserted and insinuated that he was
involved with AmFAR
and that by innuendo, Plaintiff is a liar;

	(ww)	Plaintiff had introduced to Dr. Krim Andrew Crispo and
that therefore
Plaintiff was an associate of Andrew Crispo who was alleged by the
press to
have been involved in a brutal sadistic kidnapping and murder of a
homosexual
fashion model and that, by innuendo, Plaintiff had also been involved
in that
kidnapping and murder and the other alleged criminal and despicable
activities
of Andrew Crispo.

	(xx)	Plaintiff was wanted for criminal fraud and
embezzlement and was a
fugitive from justice and State Bar disciplinary proceedings;

	34.	The false and defamatory implications, innuendoes and
meanings of and
concerning Plaintiff, as alleged in Paragraphs 28 and 33 above, were
also
conveyed by the combination of individual statements contained in the
relevant
statements, including the juxtaposition of words and statements to
each other,
which in the aggregate, produced the false and defamatory inferences
from
which said meanings and implications were conveyed.

	35.	The false and defamatory statements, implications,
innuendoes and
meanings of and concerning Plaintiff, as alleged in Paragraphs 28 and
33
above, have also been published to those involved in the Foundation
for
Educational Research, the Labor Day LA organization, the Board of
Education of
the Los Angeles Unified School District and other officials thereof,
the Gay
and Lesbian Education Commissioners of the Los Angeles Unified School
District, and others, as evidential support for allegations and/or
implications and innuendo that Plaintiff would misappropriate monies,
and
engage in pedophilia and other criminal sexual activity, and should
therefore
be barred from participation in the fund raising activities of those
and other
organizations, should not be retained as an attorney at law and should
not
otherwise be associated with or befriended.

	36.	Contrary to the aforesaid false and defamatory
statements, implications
and meanings

		(a)	Plaintiff did not engage in unscrupulous
activities and was a
professional and attorney who had been held in such high regard that
he had
represented the Disciplinary Committee for the United States District
Court
for the Central District of California 

		(b)	Plaintiff has never paid a single witness,
anytime, anywhere or
anything, for false testimony, false statements, false claims and/or
any other
statement that was not either believed by him, in good faith, to be
the truth
or a proper expert opinion being given in good faith;

		(c)	Plaintiff had never committed the crime of
extortion whether in
connection with the Church of Scientology or otherwise;

		(d)	Plaintiff did not create the Tabayoyon
Declaration, with or without
false, perjurious statements lacking in credibility;

		(e)	Plaintiff did/does not engage in
unconscionable litigation tactics;

		(f)	Plaintiff has never ever tampered with
evidence;

		(g)	Plaintiff has never ever made extortionate
demands for money;

		(h)	Plaintiff never engaged in sinister conduct;

		(i)	Plaintiff had never engaged in scams;

		(j)	Plaintiff did not have any history of
involvement with underhanded
deals;

		(k)	Plaintiff was not involved in a law
partnership famous for bilking
clients out of millions of dollars they were to receive;

		(l)	Plaintiff is a person of professional
integrity who was held in good
repute;

		(m)	Plaintiff is a person who people would do well
not to avoid in
appropriate circumstances;

		(n)	Plaintiff is a person who people would do well
not to avoid doing
business with in appropriate circumstances;

		(o)	Plaintiff had not engaged in any activities
that had sparked off the
insurance reform law of New York State;

		(p)	Plaintiff never conspired with anyone to frame
the church of scientology
for certain criminal activity allegedly involving Steven Fishman;

		(q)	Plaintiff does not have a long involvement
with criminals;

		(r)	Plaintiff does not have a long history of
involvement with criminal
activities;

		(s)	Plaintiff never fled the jurisdiction of New
York to avoid a felony
complaint for first degree fraud or perjury;

		(t)	Plaintiff never fled the jurisdiction of New
York, or any other
jurisdiction, to avoid any kind of felony or misdemeanor complaint,
and/or any
other kind of disciplinary or administrative action;

		(u)	Plaintiff voluntarily, actively and fully
cooperated with all
prosecutorial and disciplinary authorities to ensure that they had all
necessary information within Plaintiff's knowledge that pertained to
the
subject(s) of their investigation(s);

		(v)	Plaintiff did not ever abuse cocaine in his
law office;

		(w)	Plaintiff is not an avowed homosexual with a
penchant for young boys;

		(x)	Plaintiff does not prefer underage boys for
his sexual gratification;

		(y)	Plaintiff is not so perverted that he makes
former CAN President Michael
Bohos look like a Sunday School teacher;

		(z)	Plaintiff had never committed statutory rape,
acts of lewd conduct and
or acts of lewd or criminal sexual conduct with minors contrary to
law;-

		(aa)	Plaintiff did not frequent the Anvil Club, or
any other sado-
masochistic club notorious or otherwise in Greenwich Village, New York
City or
anywhere else;

		(bb) Plaintiff had never taken a twelve year old boy
to a notorious, gay,
sado-masochistic club in Greenwich Village in New York City, for the
purposes
of introducing him to gay sex, or for any other purpose;

		(cc)	Plaintiff has never been engaged in
sadomasochistic activities;

		(dd)	During the six and a half years Plaintiff
lived in New York, New York,
the Plaintiff does not recall having any friendships or intimacies
with any
male under the age of 18;

		(ee)	Plaintiff was never associated with Andrew
Crispo and does not recall
ever meeting him at any time anywhere;

		(ff)	Andrew Crispo was never one of Plaintiff's
clients, entourage or circle
of friends and acquaintances;

		(gg)	Plaintiff had not been involved in the
sadistic kidnapping and murder
of a male model in 1985;

		(hh)	Plaintiff had never met or spoken with the
said male model, who was
murdered in 1985;

		(ii)	Plaintiff has never been involved with any
murder, or other kind of
killing whether sadistic, accidental or otherwise;

		(jj)	Plaintiff has never been associated with any
Bernard LeGeros, whether
as a client, friend, acquaintance or otherwise;

		(kk)	Plaintiff was not involved with an illegal
pyramid game called
"knockoff";

		(ll)	Plaintiff was not involved with Mafiosi;

		(mm)	Plaintiff was not involved with art fraud,
baby brokering (legal,
illegal or otherwise); kidnapping or white slavery;

		(nn)	Plaintiff has never been involved in any kind
of snuff movie in any way
whatsoever including viewing the same;

		(oo)	Plaintiff has never purchased testimony from
any one for any reason,
except as otherwise properly constitutes "expert testimony";

		(pp)	Plaintiff has never falsified affidavits or
declarations;

		(qq)	Plaintiff is not engaged in unethical conduct
going back for years;

		(rr)	Plaintiff has never ever used a single witness
who had been paid an
exorbitant sum for his testimony;

		(ss)	Plaintiff's entire stock in trade did not
consist in the purchase of
perjured testimony;

		(tt)	Plaintiff had not been engaged in the
commission of a massive insurance
fraud in excess of $900,000.00;

		(uu)	Plaintiffs' stock in trade does not consist in
any manner in the
purchase or knowing use of perjured testimony;

		(vv)	Plaintiff had never been engaged in the
commission of any kind of
insurance fraud;

		(ww)	Plaintiff had never engaged in any conspiracy
to commit perjury with
Steven Fishman, Vaughn Young, Stacy Young, Andre Tabayoyon and Mary
Tabayoyon;

		(xx)	Plaintiff had never engaged in any conspiracy
to commit perjury;

		(yy)	Plaintiff had never paid anyone for perjured
testimony;

		(zz)	Plaintiff was not in cahoots with Lawrence
Wollersheim and had not been
involved with the fraudulent and other illegal activities that
Defendants
alleged of Lawrence Wollersheim;

		(aaa)  Plaintiff had never conspired with anyone to
fabricate anti-
scientology testimony, or any other kind of testimony for the payment
of
money;

		(bbb)  Plaintiff had never conspired with anyone to
fabricate any testimony.

		(ccc)  In 1983 Plaintiff was not a patient of Dr.
Sonnabend and at no time
thereafter on any regular basis;

		(ddd)  At all times Plaintiff has tested negative for
the HIV and AIDS
virus;

		(eee)  Plaintiff was intensively and extensively
involved in the day-to-day
operations of the [AIDS Medical] Foundation for approximately the
first
fifteen months of its existence;

		(fff)  For approximately the first 12 months of [AIDS
Medical] Foundation's
existence, the Foundation operated out of the office/apartment of
Plaintiff
and occupied almost one-third of the space.  The Foundation used
Plaintiff's
office equipment.  The Foundation's Executive Director and employees
also
worked out of Plaintiff's apartment-office. The Foundation also used
Plaintiff's telephonic, computer, photocopying and postal facilities;

		(ggg)  As a director and secretary of the [AIDS
Medical] Foundation,
Plaintiff regularly met with Dr. Krim in meetings at his
apartment-office;

		(hhh)  As a director and secretary of the [AIDS
Medical] Foundation
Plaintiff was engaged in frequent Board meetings at Dr. Krim's
residence;

		(iii)  Plaintiff was the [AIDS Medical] Foundation's
first Chairman of
Development and was extensively involved (and expended many hundreds
and
perhaps thousands of hours) in its early fund raising activities and
the press
also photographed and reported him in that capacity;

		(jjj)  During the first 12 months of the Foundation's
existence, Plaintiff
met most mornings with the Foundation's Executive Director and staff,
often at
a restaurant near his apartment office, and discussed the long range,
short
range and day-to-day activities of the Foundation in the capacity of a
director and officer of the Foundation responsible for the supervision
and
coordination of its fundraising activities;

		(kkk)  For approximately the first 15 months of the
Foundation's existence,
Plaintiff extended many hours, each and every day, on the day-to-day
operations and activities of the Foundation to the extreme detriment
and
ultimate prejudice of his professional practice, personal finances and
personal relationships;

		(lll)  Plaintiff never attempted, unsuccessfully or
otherwise, to oust Dr.
Krim from her position as Chairman of the Board of the Foundation;

		(mmm)  Plaintiff never engaged in ugly, obnoxious and
aggressive behavior
toward Dr. Krim;

		(nnn)  Plaintiff never threatened Dr. Krim;

		(ooo)  Plaintiff never met with a Eugene Klein, either
to be straightened or
otherwise;

		(ppp)  Plaintiff resigned from the [AIDS Medical]
Foundation's Board of
Directors after dissolving his law partnership with Frank Hoffey and
relocating his residence and office;

		(qqq)  After Plaintiff resigned as a Director and
Officer of the Foundation,
it passed a resolution commending his extensive service to the
Foundation and
gave him a testimonial-type letter reflecting that resolution;

		(rrr)  Plaintiff has never asserted or insinuated that
he was involved in
AmFAR at any time or in any manner;

		(sss)  Plaintiff did not know Andrew Crispo, was not
acquainted or friendly
with him; had never visited his apartment or business premises; and
never
introduced Dr. Krim to Andrew Crispo;

		(ttt)  Plaintiff has never misappropriated monies
whether raised by charity
or otherwise;

		(uuu)  Plaintiff has never engaged in pedophilia or
other acts of child
abuse or molestation;

		(vvv)  Plaintiff has never been on premises
administered by the L.A. Unified
School District for any purposes whatsoever.

	37.	Defendants knew and intended that the particular
statements set forth in
Paragraph 28, and in the publications attached hereto as exhibits, as
a whole,
would convey each and every false and defamatory innuendo, implication
and
meaning set forth in Paragraphs 28 and 33 above, and elsewhere herein,
of and
concerning Plaintiff and such false and defamatory meanings were
conveyed by
the particular statements set forth in Paragraph 28 and by the
inferences and
innuendo, including but not limited to those, drawn from Paragraph 33
herein
and the Defendants' statements in the aggregate.

	38.	The aforesaid false and defamatory statements,
innuendoes, implications
and meanings, as set forth in Paragraphs 28 and 33 above, were
intended by
Defendant(s) and understood by the reading public to be of and
concerning
Plaintiff.

	39.	The statements, innuendoes, implications and meanings
alleged in
Paragraphs 28 and 33 and elsewhere herein, were published by
Defendant(s) with
bad motives.

	40.	At the time of the publication of the statements,
implications and
meanings alleged in Paragraphs 28 and 33, and elsewhere herein
Defendant(s)
acted with actual malice and/or hatred or ill-will towards the
Plaintiff in
that Defendant(s) knew that the aforesaid defamatory statements,
implications
and meanings were false and published them, or caused them to be
published, in
reckless disregard of their truth or falsity and/or published them or
caused
them to be published without reasonable grounds for believing them to
be true.
Moreover, Defendants' overlooked the fact that information regarding
Plaintiff
had been collected, in furtherance of Scientology's Fair Game and
related
policies, through the activities of private investigator Eugene
Ingram, who
they knew, or should have known, to be an unreliable source of true
statements
and who they knew, or ought to have known, to be engaged in unlawful
conduct
and activity dating back to his employment with the Los Angeles Police
Department.  Furthermore, that scientology entities had employed
scientologist
Kendrick Moxon  (further to their 'Mission Corporate Category
Sort-Out') to
"run" Eugene Ingram well knowing that Kendrick Moxon, Esq. was an
unindicted
co-conspirator in the largest ever known criminal infiltration of the
United
States Government.  Among other things, Defendant(s) knew and
recklessly
disregarded contradictory facts that Plaintiff from time to time
brought to
the attention of defendants' professional advisors, peers, friends,
acquaintances and fellow employees, scientologists and their attorneys
and
agents.

	41.	The aforesaid defamatory statements, implications and
meanings were
published or caused to be published by Defendant(s) intentionally
having full
knowledge of their lack of truth and falsity.

	42.	The publication of the said defamatory statements,
implications and
meanings was motivated by ill will and Defendant(s) desire to damage
and
"utterly destroy" the professional and personal relationships,
activities and
prospects of the Plaintiff and/or his participation in the activities
of
others with those intentions.

	43.	Defendant(s) and those with whom he/she/they
conspired, were motivated to
and did publish each of the said defamatory statements, implications
and
meanings with the purpose of discrediting Plaintiff in his
professional,
personal and charitable activities and in his relationships with his
professional associates, peers, friends, acquaintances and others who
either
knew him, knew of him or who might do business or have political,
social and
charitable relationships with him, without regard to the falsity of
the said
publications.

	44.	By the aforesaid statements, innuendoes, implications
and meanings,
defendants have falsely charged plaintiff of being involved with
unscrupulous
activities including but not limited to being involved with art fraud;
baby
brokering; the enticement and drugging of females and their sale as
white
slaves in North Africa; paying for false statements; paying for false
claims;
paying large sums of money for false testimony; extortion; created
perjured
statements; engaging in unconscionable litigation tactics; tampering
with
evidence; making extortionate demands for money; causing the enactment
of
insurance reform legislation in New York State; engaging in sinister
conduct;
engaging in scams; engaging in pyramid scheme; being of dubious
character;
being a person whom others should avoid; being a person with a long
history of
involvement with criminals; being a person with a long association
with
criminal activities, being a person who had fled the State of New York
to
avoid felony complaints for first degree fraud and forgery, being a
person who
abused cocaine in his law office; being a person who had committed
statutory
rape, acts of indecency and other acts of lewd conduct on one and many
occasions; being a person who had committed statutory rape and/or
other
unlawful sexual acts on at least 50-60 occasions; being a
sado-masochist
frequenting sado-masochistic clubs; being a person who took
significantly
underage males to notorious sadomasochistic clubs in New York City for
the
purpose of introducing them to gay sex; being involved with a person
allegedly
involved with the sadistic kidnapping and murder of a male model and
having
that person as, either a client or part of his entourage; being
associated
with the kidnapper and murderer of a gay model; being involved with
the
importation of 'snuff' movies; framing the church of scientology for
the
alleged criminal conduct of Steven Fishman; being involved with he
purchase of
testimony; being involved with the purchase of testimony for
exorbitant sums
of money; being a lawyer whose entire stock in trade consisted in the
purchase
of perjured testimony; being involved in a massive insurance fraud;
being
involved in numerous insurance frauds; engaging in a conspiracy to
commit
perjury and engaging in a conspiracy to fabricate testimony; lying;
fraudulent
misrepresentations; despicable conduct; loathsome diseases; abusive
conduct;
assault; power-seeking megalomania; association with alleged
murderers;
participation in murder; being involved in all manner of other
criminal,
despicable, immoral and unethical conduct.

	45.	By the aforesaid statements, implications, innuendoes
and meanings,
defendant(s) has caused Plaintiff to be exposed to hatred, contempt,
ridicule
and/or obloquy which has caused Plaintiff to be shunned and avoided
and has
tended to injure Plaintiff in his occupation.

	46.	The aforesaid statements, implications, innuendoes and
meanings are
libelous and slanderous per se and actionable without proof of special
damage
as a proximate result thereof.

	47.	Prior to, and at the time of the publication of said
statements,
implications, innuendoes and meanings, Plaintiff had enjoyed a good
reputation
as a professional who had practiced law in four different countries
and in
five different jurisdictions, a gentleman, and as a person who had
dedicated
an extensive amount of his professional and personal energy and
resources to
the incorporation, organization and launching of charitable
activities,
environmental activities, medical research activities; church
activities;
scouting activities and other good projects generally.

	48.	Defendant(s) statement(s) have also been published to
directors of
charitable organizations, the Board of Education and other officials
of the
Los Angeles Unified School District, and others, engaged in raising
money for
youth, political AIDS-related organizations, and other charitable
organizations for the purpose of discrediting Plaintiff and causing
such
organization(s), its/their directors, officers, employees and
volunteers to
shun Plaintiff and to disassociate themselves from him because, inter
alia, he
may misappropriate monies raised and exploit opportunities to engage
in
pedophilia;

	49.	Defendant(s) statements have been published to those
persons described
herein, including but not limited to those persons described in
Paragraphs 30
and 35, for the purpose of destroying, or otherwise adversely
affecting
Plaintiff's professional activities, his political associations, his
social
relationships, his finances, achievements, respect and his life
generally.
Defendant(s) have done these activities, and published their
statements, among
reasons, in accordance with the "Attack", "Fair Game", "Black
Propaganda",
"noisy investigation" and other related sacred scriptures of the
corporations
and churches of scientology, as allegedly authored by the late L. Ron
Hubbard.

	50.	The statements, allegations, implications and innuendo
set forth in
Paragraphs 28 and 33 herein were published or spoken to try and shame
and/or
intimidate Plaintiff into ceasing the representation of defendants in
litigation filed by the dangerous cult, tax-free commercial enterprise
and
seditious political movement intent upon world-wide totalitarian rule,
known
as the corporations and churches of Scientology and, in accordance
with
various of the so-called scriptural writings, policies, bulletins and
issues
of the late L. Ron Hubbard to, inter alia, "ruin him utterly", to
"destroy
him" and to cause his "decease" and "demise" through the application
of
certain so-called religious scriptural writings of the late science
fiction
writer, paranoid schizophrenic, fraud and charlatan L. Ron Hubbard,
such as
"The Manual of Justice", "The Fair Game Law", "Black Propaganda",
"noisy
investigation", "on control and lying" and "dead agenting." Despite
the cult's
claims that the Fair Game Law was cancelled in the 1960s, during the
1980s and
'90s, Scientology's "fair game" policy has been repeatedly and
judicially
recognized in this judicial district and elsewhere.  These writings
form part
of the so-called sacred scriptures of the alleged Church of
Scientology.  Said
activity is in blatant breach of express material representations made
to the
United States Internal Revenue Service in the Church of Scientology's
1991
Section 501(e) (3) applications, and related documents, regarding the
previous
and future litigation and harassment activity of the so-called Church
of
Scientology, and as also set forth in the I.R.S. conditional approval
letter
issued in 1993.

	51.	As a direct and proximate result of Defendant(s)'
conduct as aforesaid,
Plaintiff has been damaged by loss of reputation, loss of goodwill,
loss of
professional opportunities, etc. in an amount to be proven at trial.

	52.	Defendant's statements, and the publications thereof,
were the product of
an intent to injure Plaintiff for the sake of injury, itself, and were
evil
and malicious.  Furthermore, Defendant's conduct was cruel,
despicable,
willful, wanton, malicious and oppressive, beyond the bounds of
decency,
calculated to deceive the public and for the purpose of injuring
Plaintiff for
Defendant's own financial and strategic gain, or those with who he
associated
and conspired with thereby entitling Plaintiff to an award of
exemplary and/or
punitive damages against defendant(s) in a sum sufficient to punish
him for
their wilful and unprivileged injury to Plaintiff and make an example
of
him/them to others.


	SECOND CAUSE OF ACTION

	(Defamation By Libel, Libel Per Se,
	Slander, Slander Per Se
	Against Defendant Shaw and Does 1 Through 400)

	53.	Plaintiff repeats, re-alleges and incorporates herein
by reference each
and every allegation contained in Paragraphs 2 through 19, inclusive,
of the
general allegations of this Complaint, as if fully set forth herein.

	54.	Sometime between 1994 and the present day, defendant
Shaw created and
posted an internet web site called Rogues Gallery of A.R.S. Bigots and
located
on the internet at http://www.dancris.com/~rshaw/ (a copy of which is
attached
hereto as Exhibit "C" and the contents of which are expressly
incorporated
herein) which compared Plaintiff to some of history's vilest human
monsters,
and blackest deeds, and made unprivileged, false, defamatory and
malicious
claims of and concerning plaintiff, including but not limited to the
following.

		(a)	On May 1, 1984, Mr. Berry moved his office
furniture to the law office
of Jerome Spiegelman, 303-305 East 53rd Street, New York City.  Mr.
Spiegelman, a gay man, and Mr. Berry became companions;

		(b)	On May 15, 1984, Mr. Berry and Mr. Spiegelman
became law partners at
303-305 East 53rd Street, New York City.  They named their firm
Spiegelman &
Berry;

		(c)	On December 13, 1984, Berry's partner, Mr.
Spiegelman, stole $18,785.57
from the account of a client (deceased 12/4/84), Eugene Brigati, by
forging a
bank withdrawal slip on Mr. Brigati's bank account;

		(d)	On December 14, 1984, Berry's partner, Mr.
Spiegelman, stole $4,390.83
from the account of a client (deceased 12/4/84), Eugene Brigati, by
forging
two IRA withdrawal slips on Mr. Brigati's bank account;

		(e)	On December 14, 1984, Berry's partner, Mr.
Spiegelman, stole 41,050.00
from the account of a client (deceased 12/4/84), Eugene Brigati, by
forging a
bank withdrawal slip on Mr. Brigati's bank account;

		(f)	On January 22, 1985, Berry's partner, Mr.
Spiegelman stole $2,217.00
from the account of a client (deceased 12/4/84), Eugene Brigati, by
forging
and cashing a check from Mr. Brigati to Mr. Spiegelman;

		(g)	On May 20, 1985, Berry's partner, Mr.
Spiegelman, embezzled $75,000.00
from a client, Miguel Padilla, by settling his case and stealing the
money
without the knowledge or consent of Mr. Padilla;

		(h)	On August 6, 1985, Berry's partner, Mr.
Spiegelman stole $13,333.33 from
the account of a client, the infant son of Valerie Walker, by forging
a check
and a bank approval for payment stamp for a check due Ms. Walker from
the
Group Council Mutual Insurance Company;

		(i)	In about August 1985, Mr. Berry and Mr.
Spiegelman first learned about
the New York District Attorney's Office investigation of Mr.
Spiegelman for
embezzling millions of dollars from client's settlements, forging
clients
signatures, etc.  Numerous of these thefts occurred during the time
that Mr.
Berry and Mr. Spiegelman were partners.  Mr. Berry and Mr. Spiegelman
immediately closed their offices at 303-305 East 53rd Street, New York
City at
this time;

		(j)	On September 4, 1985, Mr. Berry filed for
personal bankruptcy.  He
claimed $6,498.45 in personal property and $181,869.00 in liabilities;

		(k)	On November 14, 1985, Mr. Berry and Mr.
Spiegelman signed a paper
dissolving their law partnership;

		(l)	On or about January 20, 1986, Mr. Berry fled
the United States for
Australia;

		(m)	On January 24, 1986, the New York's District
Attorney's Office filed a
felony complaint against Mr. Spiegelman, Berry's former law partner,
charging
him with Grand Theft, Forgery, Possession of Forged Instruments,
Possession of
Stolen Property and Schemes to Defraud - many of these committed
during the
time that Berry was his partner.  An interview with the prosecutor
involved in
this case revealed the fact that they were unable to interview Mr.
Berry
because they believed that he was in Australia.  The prosecutor stated
that he
researched the legal requirements necessary to extradite Mr. Berry
from
Australia and concluded that it would have been very difficult. 
(However, new
information provided to the prosecutor has prompted a review of the
investigation and a probable re-opening of the case.  Additionally,
recent
information from the NY bar indicates that there is no statute of
limitations
on bar complaints.);

		(n)	On January 31, 1986, Berry's now former
partner, Mr. Spiegelman, was
suspended from the practice of law in New York.  The bar had received
23
complaints against him.  The complaints were for fraud,
misrepresentation,
conversion, deceit, dishonesty and for failing to communicate;

		(o)	On February 5, 1986, Mr. Spiegelman was
arrested in New York;

		(p)	On April 17, 1986, Mr. Spiegelman pled guilty
to Grand Theft;

		(q)	On April 29, 1986, Mr. Spiegelman was
disbarred in New York;

		(r)	On May 8, 1986, Mr. Spiegelman was sentenced
to between 2 1/3 years to 7
years imprisonment in the state prison.  (Mr. Spiegelman served 4
years in
prison.);

		(s)	Sometime near the end of 1986, Mr. Berry moved
to Los Angeles and began
practicing law with the Lewis, D'Amato, Brisbois & Bisgaard law firm
and on
July 21, 1990, Mr. Berry purchased his current residence, 1228 11th
Street,
Unit #202, Santa Monica, California  90401 for $384,000.00.  The
mortgage was
$301,500.00.  However Berry, who was still within the seven years of
his
bankruptcy, did not take out the original mortgage directly but
through a
middle man who had qualified for the loan but never paid anything for
the
condo.  Berry as part of a scheme to defraud the bank assumed the loan
shortly
after the purchase.  This loan fraud is currently under criminal
investigation;

		(t)	On November 9, 1992, Mr. Berry took out a
second mortgage on his
residence for $25,000.00;

		(u)	"Mr. Berry was a classic example of a 'Chicken
Hawk' which in street
vernacular is a term for an adult male who has sex relations with boys
under
the age of sixteen";

		(v)	"Mr. Berry would routinely tell Mr. Cipriano,
in graphic detail, about
his sexual exploits with boys under the age of 16.  Mr. Berry told Mr.
Cipriano that he would sodomize these boys and have them orally
copulate his
penis";

		(w)	"Between May 1984 and February 1985, Mr.
Cipriano personally observed at
least 50 to 60 boys between the ages of 14 and 16 in the company of
Mr. Berry
at the law firm on East 53rd Street.  Mr. Berry frequently pointed out
which
boy he had had sex with and would tell Mr. Cipriano all about it in
detail.
Mr. Berry would also frequently have these boys perform odd jobs at
his law
firm, usually in exchange for cocaine, which he would provide them;

		(x)	Mr. Cipriano stated Mr. Berry used to frequent
the Anvil Club, a
notorious gay S&M Club in Greenwich Village in New York City. 
Homosexual
males at the club would orally copulate and sodomize each other in
open view
of the other patrons.  The patrons also engaged in sadistic and
masochistic
sex acts upon each other, including inserting their greased hands and
arms up
the rectum of the other and placing their penis through a hole in the
wall,
commonly called a "glory hole" where an anonymous male would orally
copulate
it";

		(y)	"Mr. Berry once told Mr. Cipriano about taking
a boy of twelve years of
age to the Anvil Club for the purpose of introducing him to gay sex";

		(z)	"Mr. Cipriano stated that Mr. Berry was
frequently surrounded by young
attractive male models, some below the age of sixteen who he used for
sex.
Because Mr. Spiegelman also enjoyed engaging in sexual acts with these
young
men and boys and because he wanted also to practice entertainment law,
he
agreed to let Mr. Berry become his partner;"

		(aa)	Mr. Cipriano stated that he was aware that Mr.
Berry had set up some
talent agencies, however, they never conducted business and were only
used as
a ruse for Mr. Berry to meet pretty boys and young men in order to
make dates
for himself, the ultimate objective of fulfilling his sexual desires.
Separate confirmation verified that Berry incorporated the following
businesses, listing his New York office as the address:  Michelle
Lianne
Corporation, Portfolio Model Management Corporation and Urban Male
Productions, Inc.;

		(bb)	Mr. Cipriano stated that Mr. Berry was
associated with Andrew Crispo, a
New York City art gallery owner and gay who was allegedly involved in
the
sadistic murder of a male model in 1985.  Mr. Cipriano stated that Mr.
Crispo
was either one of Mr. Berry's clients or one of the homosexuals that
was part
of Mr. Berry's entourage;

		(cc)	Mr. Cipriano stated that Mr. Spiegelman also
arranged illegal
adoptions.  Mr. Spiegelman would pay $7,000 to $8,000 to girls in
Florida to
get pregnant.  He would purchase their babies for $15,000 to $20,000
and re-
sell them;

		(dd)	Mr. Cantwell stated that Mr. Berry was gay and
into perverted sexual
practices;

		(ee)	Mr. Cantwell recalled hearing Mr. Berry
describe an incident in which
Mr. Berry paid a kid $200 to have the kid defecate on Mr. Berry's
chest;

		(ff)	Mr. Cantwell also stated that Mr. Berry hung
out at the Haymaker,
possibly in the company of Andy Warhol and Roy Cohn;

		(gg)	Although Mr. Glick never observed Mr. Berry
ingest cocaine, he assumed
he abused cocaine in his office based on the fact that Mr. Berry had
every
visible a cocaine user exhibits when under the influence;

		(hh)	Mr. Glick stated he observed a total of at
least 20 boys between the
ages of 16 and 20 years of age in the company of Mr. Berry in Mr.
Berry's
office during the time he worked for Spiegelman and Berry.  Mr. Glick
stated
Mr. Berry had been having sexual relations with these boys and young
men;

		(ii)	Mr. Long stated that he had a friend who
worked in the New York theater
named Gilbert Jones who was then Mr. Berry's roommate;

		(jj)	Mr. Long stated that Mr. Berry would come to
work and always brag about
the young males he had picked up the previous night and described the
type of
sex they had together;

		(kk)	Mr. Long stated that Mr. Berry would arrange
for young males to come to
the law office and show them off and that it was obvious that the
young males
were just male prostitutes after Mr. Berry's money and that they
really
weren't in love with Mr. Berry;

		(ll)	Mr. Long stated that he suspected Mr. Berry
must have paid for the
sexual service of his young male friends because he wasn't attractive
and the
young males probably would never have had sex with him for free;

		(mm)	Mr. Long described Mr. Berry as a
"bullshitter;"

		(nn)	Mr. Long considered Mr. Berry to be
incompetent as an attorney and was
surprised to learn that he had passed the California bar;

		(oo)	Mr. Spiegelman stated that Mr. Berry was his
law partner for 1 1/2
years at 3035 East 53rd Street, New York City;

		(pp)	Mr. Spiegelman stated that Mr. Berry was his
partner until November
1985;

		(qq)	Mr. Spiegelman stated that when they completed
the dissolution of the
partnership paper, they falsely indicated that they had ceased being
partners
in January 1985.  They did this in an attempt to distance Mr. Berry
from Mr.
Spiegelman at the same time that Mr. Spiegelman was being investigated
for
embezzling money from his clients;

		(rr)	Mr. LeGeros stated that he first met Mr.
Berry, at Mr. Crispo's
penthouse residence in the early 1980's.  Mr. LeGeros stated he
personally
observed Mr. Berry inside Mr. Crispo's penthouse at 381 West 12th
Street, New
York City, on three or four occasions.  On each of these occasions, he
observed Mr. Berry and Mr. Crispo ingest Cocaine together;

		(ss)	Legeros stated he also observed Mr. Berry at a
1983 party held at the
top of the Time-Life Building in New York City.  This was a party for
a game
called Knock-Off.  The party was actually a pyramid scheme engineered
by Mr.
Crispo and his friend, Sandi Franklin;

		(tt)	Mr. LeGeros stated he assumed that, because
Mr. Berry and Mr. Hoffey
were law partners, that Mr. Berry knew about an illegal scam involving
the use
of lithographic plates of artists Lowell Nesbitt's drawings to make
prints of
those drawings as part of an illegal scam;

		(uu)	Mr. LeGeros said that Mr. Crispo also told him
about Mr. Hoffey's
involvement in a Brooklyn baby factory at the same time he was law
partners
with Mr. Berry.  Mr. LeGeros assumed Mr. Berry also knew about this. 
Mr.
Hoffey illegally brokered it, infants sold by their mothers to persons
unable
to give birth to children of their own;

		(vv)	Mr. LeGeros stated at the same time Mr. Hoffey
was law partners with
Mr. Berry, Mr. Hoffey was very close friends with Frank Rossi, an
Italian
attorney who practiced law in England.  On one occasion, Mr. Rossi
told Mr.
LeGeros that he ran ads for female models in the United States and
Asia.  When
women responded to the ads, they would be drugged and sold as White
slaves to
Mr. Rossi's clients in Tunisia and Morocco;

		(ww)	Mr. Berry lied in a May 13, 1994 declaration
when he denied knowing Mr.
Crispo because Mr. Crispo is one of the sickest, most sexually
perverted
individuals [Shaw had] ever heard about;"

		(zz) Berry was possibly a patient of Dr. Joseph A.
Sonoband, M.D., who was a
virologist and microbiologist who specialized in infectious diseases,
particularly sexually transmitted diseases;

		(yy) Although Mr. Berry had been listed as an initial
director of the A.I.D.
Medical Foundation on March 22, 1983, he was merely the attorney
selected by
Dr. Sonnabend and Dr. Krim to draw up the Foundations' and corporation
papers
and he was not involved in the day-to-day operations of the
foundation;

		(zz) Mr. Berry unsuccessfully attempted to oust Dr.
Mathilde Krim from her
position as chairman of the board of the AIDS Medical Foundation;

		(aaa) Mr. Berry unsuccessfully attempted to oust Dr.
Sonnabend from his
position as chief of research of the AIDS Medical Foundation;

		(bbb) The friendly relationship between Mr. Berry and
Dr. Krim quickly
turned very ugly after the incorporation of the AIDS Medical
Foundation;

		(ccc) Mr. Berry became very obnoxious and aggressive
toward Dr. Krim;

		(ddd) Mr. Berry threatened Dr. Krim;

		(eee) Mr. Berry thought he could push Dr. Krim around
and treated her
without respect;

		(fff) Dr. Krim brought in a senior partner of the law
firm of Phillips,
Nizer, Benjamin, Krim & Ballen, Eugene Klein, to straighten out Mr.
Berry;

		(ggg) That Mr. Berry had either asserted or insinuated
that he had been
involved in AmFAR;

	55.	Defendant Shaw, and the other defendants, specifically
intended the
statements would be injurious to plaintiff, and subject him to hatred,
contempt and ridicule, particularly within the legal, political,
charitable
and social communities in which plaintiff mixed, and in which would
cause him
to be shunned and avoided, and injured in his occupation as an
attorney.
Defendant Shaw, and the other defendants, intended that the statements
would
be, and they were, widely published and broadly disseminated as
alleged
herein.

	56.	Defendant Shaw's false claims have in fact been
published in the State of
California, County of Los Angeles, City of Los Angeles, and throughout
the
entire world, and continue to be so published on a daily basis.

	57.	The false and defamatory statements made by Defendant
Shaw, as set forth
in Paragraph 10 above, inter alia, were of and concerning Plaintiff.

	58.	By the use of the particular words set forth in
Paragraph 54 above, and
on the ARS Bigots Page, by the use of the particular words set forth
in
Paragraph 54 above, Defendant Shaw conveyed the following false and
defamatory
implications, innuendos and meanings of and concerning Plaintiff:

		(a)	Plaintiff was involved in the commission of
felonious, immoral, criminal
and unlawful sexual activities with numerous underage males;

		(b)	Plaintiff was exchanging illegal narcotic
substances for unlawful sex
with underage males and therefore was engaging in serious criminal
behavior;

		(c)	Plaintiff was exchanging illegal narcotic
substances for employment
services rendered by 14-16 year old males and therefore was engaging
in
serious criminal behavior;

		(d)	Plaintiff was frequently surrounded by males
below the age of 16 whom he
used for sex and therefore was engaging in serious criminal behavior;

		(e)	Plaintiff was a frequent participant in public
sexual acts, performed on
licensed premises, including oral copulation, sodomy, sadistic and
masochistic
sex acts, inserting greased hands within the rectums of other males
and
anonymous public sex;

		(f)	Plaintiff took a twelve year old boy to a
night club, as allegedly
described by defendant Cipriano in Paragraphs 10(d) and 15(e) above,
intending
to introduce the boy to homosexual acts on said premises and therefore
was
engaging in serious criminal behavior;

		(g)	Plaintiff and Mr. Spiegelman entered into a
law partnership on the basis
of mutual acts of interest in sex with underage males, and therefore
had
engaged, and intended to engage, in serious criminal behavior;

		(h)	Plaintiff set up some talent agencies not to
conduct business but as a
ruse to meet pretty boys and young men in order to make dates for
himself with
the ultimate objective of fulfilling his sexual desires, and therefore
was
engaging in serious criminal and fraudulent behavior;

		(i)	Said talent agencies included Michelle Lianne
Corporation, Portfolio
Model Management Corporation, and Urban Male Productions, Inc., and,
by
innuendo, that Plaintiff owned said corporations and was using them as
alleged
in Paragraph 15 (i) above;

		(j)	That Plaintiff was living in a gay
relationship with a 22-year old gay
man by the name of David Lee, and, by  innuendo, that Plaintiff has
either HIV
or AIDS because Mr. Lee later died of AIDS;

		(k)	Plaintiff was a freeloader and otherwise a
cheapskate, because he and
his guests would never have to pay anything they consumed at Studio
54;

		(l)	Plaintiff was involved with murderers, and
participated in the
activities of murderers, because he was associated with Andrew Crispo,
a New
York City art gallery owner and gay who was allegedly involved in the
sadistic
murder of a male model in 1985 and who was either one of Plaintiff's
clients
or one of the homosexuals that were part of Plaintiff's entourage,
and,
therefore, Plaintiff engaged in serious criminal behavior;

		(m)	Plaintiff was involved in illegal adoptions
because Mr. Spiegelman
allegedly had arranged such illegal adoptions.

	59.	The false and defamatory implications, innuendoes and
meanings of and
concerning Plaintiff, as alleged in Paragraphs 54 and 58 above, were
also
conveyed by the combination of individual statements contained in the
Shaw web
site, including the juxtaposition of words and statements to each
other, and
the inclusion of references to the Inquisition, Nazi storm troopers,
Hitler,
Stalin, Mussolini and other historical monsters, which in the
aggregate,
produced the false and defamatory inferences from which said meanings
and
implications were conveyed.

	60.	Contrary to the aforesaid false and defamatory
statements, implications
and meanings

		(a)	Plaintiff was not involved in any way in
sexual activities with males
aged 14 to 16 years;

		(b)	Plaintiff was not involved in any way in the
exchange of illegal
narcotic substances to males aged 14-16 years for sex or otherwise;

		(c)	Plaintiff did not have 14 to 16 year old boys
perform odd jobs at his
law firm at all, either in exchange for illegal drugs, sex or
otherwise;

		(d)	Plaintiff never went to the Anvil with
defendant Cipriano;

		(e)	Plaintiff did not "frequent" the Anvil Club in
Greenwich Village, New
York City, New York;

		(f)	Plaintiff was not engaged in oral copulation
and sodomy in open view of
patrons of the Anvil Club;

		(g)	Plaintiff was not engaged in sadistic and
masochistic sex acts either in
public or in private;

		(h)	Plaintiff was not involved in the insertion of
greased hands up the
rectums of other males;

		(i)	Plaintiff was not involved in placing his
penis through a hole in the
wall commonly called "glory hole" where an anonymous male would orally
copulate it;

		(j)	Plaintiff never took a boy of 12 years of age
to the Anvil Club for the
purpose of introducing him to gay sex, or for any other purpose;

		(k)	Plaintiff was not frequently surrounded by
young attractive male models
below the age of sixteen who he used for sex;

		(l)	Plaintiff never told defendant Cipriano any of
the things Cipriano
states, under penalty of perjury, in his declaration attached hereto
as
Exhibit "A" and referred to in Paragraph 10 herein;

		(m)	Plaintiff did not enter into a partnership
with Mr. Spiegelman because
of any mutual interest in sexual activity with underage males;

		(n)	Plaintiff's name does not appear anywhere in
the book title "A Bag of
Toys" and there are no references to him therein;

		(o)	Plaintiff has never engaged in pedophilia or
other acts of child abuse
or molestation;

		(p)	Plaintiff has never been on premises
administered by the L.A. Unified
School District for any purposes whatsoever;

		(q)	Plaintiff incorporated businesses named as
Michelle Lianne Corporation,
Portfolio Model Management Corporation, and Urban Male Productions,
Inc., as
attorney for different clients and said businesses showed their
location as
his New York law office purely for corporate and service purposes. 
Plaintiff
was never a director, officer, stockholder, or employee of said
businesses and
was never involved with said corporations other than as attorney and
incorporator;

		(r)	Plaintiff has never operated a talent agency
and has never conducted a
talent agency as a ruse for him to meet new pretty boys and young men
in order
to make dates for himself with the ultimate objective of fulfilling
his sexual
desires;

		(s)	Plaintiff never lived in a gay relationship
with a 22-year old gay man
by the name of David Lee, and, Plaintiff has always tested negative
for the
HIV virus;

		(t)	Plaintiff and his guests regularly paid for
refreshments at the Studio
54 nightclub in New York City;

		(u)	Andrew Crispo was not an associate of
Plaintiff, he was not one of
Plaintiff's clients and was not part of any alleged entourage of
Plaintiff's;

		(v)	Plaintiff had absolutely no involvement in any
manner in the sadistic
model of a male model in 1985;

		(w)	Plaintiff had a limited and separate law
partnership with Jerome
Spiegelman.  That separate law partnership conducted its activities on
separate premises to the Law Offices of Jerome Spiegelman.  Plaintiff
had no
involvement or participation in any manner with the business and
clients of
the Law Offices of Jerome Spiegelman;

		(x)	Plaintiff has never been involved in illegal
adopt ions whether with
Jerome Spiegelman or any other person.

	61.	Defendant Shaw knew and intended, or should have
reasonably - known, that
the particular statements set forth in Paragraph 54, and in the Rogues
Gallery
of A.R.S. Bigots attached hereto as Exhibit C, as a whole, would
convey each
and every false and defamatory innuendo, implication and meanings set
forth in
Paragraphs 54 and 58, and elsewhere herein, of and concerning
Plaintiff and
such false and defamatory meanings were conveyed by the particular
statements
set forth in Paragraph 54 and 58 by the inferences and innuendo as
drawn from
Paragraph 58 herein and Defendant's statements in the aggregate.

	62.	The aforesaid false and defamatory statements,
innuendoes, implications
and meanings, as set forth in Paragraphs 54 and 58 above, were
intended by
Defendant Shaw and understood by the electronic public and others, to
be of
and concerning Plaintiff.

	63.	The statements, innuendoes, implications and meanings
alleged in
Paragraphs 54 and 58 and elsewhere herein, were published by Defendant
Shaw
out of spite, hatred, ill will and with bad motives and with the
intent that
they would be injurious to Plaintiff, as alleged in Paragraph 11
herein.

	64.	At the time of the publication of the statements,
implications and
meanings alleged in Paragraphs 54 and 58, and elsewhere herein
Defendant Shaw
acted with actual malice and/or hatred or ill-will towards the
Plaintiff in
that Defendant Shaw knew, or should have known, that the aforesaid
defamatory
statements, implications and meanings were false and published them,
or caused
them to be published, in reckless disregard of their truth or falsity
and/or
published them or caused them to be published without reasonable
grounds for
believing them to be true.

	65.	The aforesaid defamatory statements, implications and
meanings were
published or caused to be published by Defendant Shaw intentionally
having
full knowledge of their lack of truth and/or falsity and without the
benefit
of any applicable privilege.

	66.	The publication of the said defamatory statements,
implications and
meanings was motivated by ill will and Defendant Shaw's desire, and
willing
complicity with those to whom he made the Rogues Gallery of A.R.S.
Bigots
available to damage and destroy the professional and personal
relationships,
activities and prospects of the Plaintiff and/or his participation in
the
activities of others with those intentions.

	67.	Defendant Shaw, and those with whom he conspired
and/or acted in willing
complicity with, were motivated to and did publish each of the said
defamatory
statements, implications and meanings with the purpose of discrediting
and
destroying Plaintiff in his professional, personal and charitable
activities
and in his relationships with his professional associates, peers,
friends,
acquaintances and others who either knew him, knew of him or who might
do
business or have social and charitable relationships with him, without
regard
to the falsity of the said statements and/or publications.

	68.	By the aforesaid statements, implications, innuendo
and meanings,
Defendant Shaw has charged Plaintiff with serious criminal acts and
immoral
conduct, all or any of which constitute Defamation, Libel and Slander
as
defined by California Civil Code ?? 44,45,44(a) and 46, and all of the
provisions of each of the aforesaid sections are expressly
incorporated
herein, as allegations where appropriate, as if specifically set forth
herein.

	69.	By the aforesaid statements, implications, innuendoes
and meanings,
defendant Shaw has caused Plaintiff to be exposed to hatred, contempt,
ridicule and/or obloquy which has caused Plaintiff to be shunned and
avoided
and has tended to injure Plaintiff in his occupation and other
relationships.

	70.	The aforesaid statements, implications, innuendoes and
meanings are
libelous and slanderous per se and actionable without proof of special
damage
as a proximate result thereof.

	71.	Prior to, and at the time of the publication of said
declaration,
Plaintiff had enjoyed a good reputation as a professional who had
practiced
law in four different countries and five different jurisdictions, a
gentleman
and as a person who had dedicated an extensive and significant amount
of his
professional and personal energy and resources to the pursuit of
truth,
justice, the American way and the alleviation of social, medical,
environmental and other problems within our society.

	72.	Defendant Shaw's declaration has been published to
those persons
described in Paragraphs 54, 56 and 73 herein for the purposes of
"utterly
destroying," or otherwise adversely affecting Plaintiff's professional
activities, his political associations, his social relationships, his
finances, achievements, respect and his life generally.

	73.	The statements, allegations, implications and innuendo
set forth in
Paragraphs 54 and 58 herein were published or spoken to try and shame
and/or
intimidate Plaintiff into ceasing the representation of defendants in
litigation filed by the dangerous cult, tax-free commercial enterprise
and
seditious political movement intent upon world-wide totalitarian rule,
known
as the corporations and churches of Scientology and, in accordance
with
various of the so-called scriptural writings, policies, bulletins and
issues
of the late L. Ron Hubbard to, inter alia, "ruin him utterly", to
"destroy
him" and to cause his "decease" and "demise" through the application
of
certain so-called religious scriptural writings of the late science
fiction
writer, paranoid schizophrenic, fraud and charlatan L. Ron Hubbard,
such as
"The Manual of Justice", "The Fair Game Law", "Black Propaganda",
"noisy
investigation", "on control and lying" and "dead agenting." Despite
the cult's
claims that the Fair Game Law was cancelled in the 1960s, during the
1980s and
'90s, Scientology's "fair game" policy has been repeatedly and
judicially
recognized in this judicial district and elsewhere.  These
anti-societal
writings form part of the so-called sacred scriptures of the alleged
Church of
Scientology.  Said activity is in blatant breach of express material
representations made to the United States Internal Revenue Service in
the
Church of Scientology's 1991 Section 501(e) (3) applications, and
related
documents, regarding the previous and future litigation and harassment
activity of the so-called Church of Scientology, and as also set forth
in the
I.R.S. conditional approval letter issued in 1993.

	74.	As a direct and proximate result of Defendant's
conduct as aforesaid,
Plaintiff has been permanently and irreparably damaged by loss of
reputation,
loss of goodwill, loss of professional opportunities, etc. in an
amount to be
proven at trial.

	75.	Defendant's statements, and the publications thereof,
were the product of
an intent to injure Plaintiff for the sake of injury, itself, and were
evil
and malicious.  Furthermore, Defendant's conduct was cruel,
despicable,
willful, wanton, malicious and oppressive, beyond the bounds of
decency,
calculated to deceive the public and for the purpose of injuring
Plaintiff for
Defendant's own financial and strategic gain, or those with who he
associated
and conspired with thereby entitling Plaintiff to an award of
exemplary and/or
punitive damages against defendant(s) in a sum sufficient to punish
him for
their wilful and unprivileged injury to Plaintiff and make an example
of
him/them to others.


	THIRD CAUSE OF ACTION

	(Invasion of Privacy Against All
	Defendants and Does 1 through 200)

	76.	Plaintiff repeats, re-alleges and incorporates herein
by reference to
each of the allegations contained in Paragraphs 2 through 19,
inclusive, of
the general allegations, and contained in Paragraphs 21 through 52,
inclusive,
of the First Cause of Action, and Paragraphs 54 through 75, inclusive,
of the
Second Cause of Action, as though set forth in detail below.

	77.	In doing the above acts, Defendant(s) intentionally
invaded Plaintiff's
right to privacy and interfered with Plaintiff's "right to be left
alone" and
otherwise violated his civil rights with such disclosure and
statements to a
large number of people.

	78.	The disclosure by Defendant(s), and each of them, of
the above-described
facts was offensive and objectionable to Plaintiff and to a person of
ordinary
sensibilities in that no legitimate public concern was served by
disclosure of
such "facts."

	79.	Defendant(s)'s statements, implications and innuendoes
continue to be
published throughout the State of California, and the entire world, on
a daily
basis.  Unless and until enjoined and restrained by order of this
Court,
Defendant(s) continued publication will cause Plaintiff great and
irreparable
injury in that Plaintiff will suffer continued humiliation,
embarrassment,
hurt feelings and mental anguish.  Plaintiff has no adequate remedy at
law in
that a judgment for monetary damages alone will not and the end the
invasion
of Plaintiff's privacy.

	80.	As a direct and proximate result of Defendant's
conduct as aforesaid,
Plaintiff has suffered extreme humiliation, embarrassment, and
distress, all
of which have caused him mental and emotional anguish and suffering,
all to
his general damage.  The exact amount of damages has not yet been
ascertained.
Plaintiff will seek leave to amend this complaint when said sum has
been
ascertained.

	81.	Defendant's statements and the publications thereof,
were the product of
an intent to injure Plaintiff for the sake of injury itself and were
evil and
malicious and exhibited a conscious disregard for Plaintiff's rights.
Furthermore, Defendant's conduct was cruel, despicable, beyond the
bounds of
decency, calculated to deceive the public and for the purpose of
injuring
Plaintiff for Defendant's own financial and strategic gain, or those
with who
he associated and conspired with hereby entitling Plaintiff to an
award of
exemplary and/or punitive damages against Defendant(s) in a sum
sufficient to
punish him/them and make an example of him/them to others.


	FOURTH CAUSE OF ACTION

	(Public Disclosure of Private Facts - - Against
	All Defendants and Does 1 through 200)

	82.	Plaintiff repeats and re-alleges each and every
allegation set forth in
Paragraphs 2 through 19, inclusive, of the general allegations,
Paragraphs 21
through 52 inclusive, of the First Cause of Action, and Paragraphs 54
through
75 of the Second Cause of Action, as though set forth in detail below.

	83.	Defendants knew, or should have known, that the giving
of publicity of
inherently private matters concerning the private life of Plaintiff
would be
highly objectionable to the reasonable person and was not of
legitimate
concern to the public.

	84.	Defendant(s)'s statements, implications and innuendoes
continue to be
published throughout the State of California, and the entire world, on
a daily
basis.  Unless and until enjoined and restrained by order of this
Court,
Defendant(s) continued publication will cause Plaintiff great and
irreparable
injury in that Plaintiff will suffer continued humiliation,
embarrassment,
hurt feelings and mental anguish.  Plaintiff has no adequate remedy at
law in
that a judgment for monetary damages alone will not and the end the
invasion
of Plaintiff's privacy.

	85.	As a proximate result of the said acts of Defendants,
Plaintiff suffered
serious mental anguish, emotional distress, loss of economic
expectation, loss
of professional advancement, and has been injured in mind and body in
an
amount according to proof at trial.

	86.	Defendant's statements and the publications thereof,
were the product of
an intent to injure Plaintiff for the sake of injury itself and were
evil and
malicious and exhibited a conscious disregard for Plaintiff's rights.
Furthermore, Defendant's conduct was cruel, despicable, beyond the
bounds of
decency, calculated to deceive the public and for the purpose of
injuring
Plaintiff for Defendant's own financial and strategic gain, or those
with who
he associated and conspired with hereby entitling Plaintiff to an
award of
exemplary and/or punitive damages against Defendant(s) in a sum
sufficient to
punish him/them and make an example of him/them to others.


	FIFTH CAUSE OF ACTION

	(Invasion of Privacy - Publicity Placing
	Person in False Light in Public Eye
	Against All Defendants, Including Does)

	87.	Plaintiff repeats and re-alleges each and every
allegation set forth in
Paragraphs 2 through 19, inclusive, of the general allegations, and
Paragraphs
21 through 52, inclusive, of the First Cause of Action, and paragraphs
54
through 75, inclusive of the Second Cause of Action, as though set
forth in
detail below.

	88.	The statements, allegations, implications and innuendo
set forth in
Paragraphs 28, 33, and 58 herein were published by Defendant(s)
without
Plaintiff's consent and invaded Plaintiff's right to privacy by
creating
publicity, by publishing the said statements, to a person(s) who/which
used
said publication to falsely portray Plaintiff as more fully described,
inter
alia, in Paragraphs 28, 33, 36, 54, 58 and 60 herein.

	89.	The publicity created by Defendant(s) was offensive
and objectionable to
Plaintiff and to a reasonable person of ordinary sensibilities for,
inter
alia, the reasons set forth in Paragraphs 36 and 60 herein.

	90.	The publicity created by Defendant(s) was done with
malice in that it was
made either with knowledge of its falsity or in reckless disregard of
its
truth and were calculated falsehoods for, inter alia, the reasons set
forth in
the Paragraphs enumerated inter alia, in Paragraphs 36 and 60 herein.

	91.	Defendant(s)'s statements, implications and innuendoes
continue to be
published throughout the State of California, and the entire world, on
a daily
basis.  Unless and until enjoined and restrained by order of this
Court,
Defendant(s) continued publication will cause Plaintiff great and
irreparable
injury in that Plaintiff will suffer continued humiliation,
embarrassment,
hurt feelings and mental anguish.  Plaintiff has no adequate remedy at
law in
that a judgment for monetary damages alone will not and the end the
invasion
of Plaintiff's privacy.

	92.	As a proximate result of the aforementioned acts,
Plaintiff has suffered
and been damaged by loss of reputation, loss of goodwill, lose of
professional
opportunities, humiliation, mental anguish, distress, etc. in an
amount to be
proven at trial.

	93.  Defendant's statements, and the publications thereof,
were the product
of an intent to injure Plaintiff for the sake of injury, itself, and
were evil
and malicious.  Furthermore, Defendant's conduct was cruel,
despicable,
willful, wanton, malicious and oppressive, beyond the bounds of
decency,
calculated to deceive the public and for the purpose of injuring
Plaintiff for
Defendant's own financial and strategic gain, or those with who he
associated
and conspired with thereby entitling Plaintiff to an award of
exemplary and/or
punitive damages against defendant(s) in a sum sufficient to punish
him/them
for their wilful and unprivileged injury to Plaintiff and make an
example of
him/them to others.

	SIXTH CAUSE OF ACTION

	(The Tort of Outrage -- Prima Facie Tort --
	Against All Defendants, Including Does)

	94.	Plaintiff repeats, realleges and incorporates herein
by reference each of
the allegations contained in Paragraphs 2 through 19 inclusive, of the
Common
Allegations, Paragraphs 21 through 52, inclusive, of the First Cause
of
Action, Paragraphs 54 through 75, inclusive of the Second Cause of
Action,
Paragraphs 77 through 81, inclusive of the Third Cause of Action, and
Paragraphs 83 through 86 of the Fourth Cause of Action, and Paragraphs
88
through 93, inclusive of the Fifth Cause of a Action, as though set
forth in
detail below.

	95.	The aforementioned acts of Defendants, as alleged in,
inter alia
Paragraphs 28, 31, 32, 33, 34, 35, 36, 42, 46 and 48 above, were and
are so
outrageous as to totally shock the conscience of a reasonable person
of
ordinary sensibilities and thus they constitute the tort of outrage.

	96.	As the proximate result of the aforementioned acts,
Plaintiff has
suffered loss of professional opportunities, clients, lost
acquaintances and
friends, humiliation, mental anguish, distress and other damages in an
amount
to be proven at trial.

	97.	Defendant(s), and each of them, did the things herein
alleged maliciously
and to oppress Plaintiff, and this constitutes despicable conduct. 
Plaintiff
is therefore entitled to exemplary or punitive damages in an amount to
be
determined at trial.


	SEVENTH CAUSE OF ACTION

	(Intentional Infliction Of Emotional Distress)
	Against All Defendants, Including Does)

	98.	Plaintiff repeats, re-alleges and incorporates herein
by reference to
each of the allegations contained in Paragraphs 2 through 19,
inclusive, of
the general allegations, Paragraphs 21 through 52, inclusive, of the
First
Cause of Action, Paragraphs 54 through 75 inclusive, of the Second
Cause of
Action, Paragraphs 77 through 81 inclusive of the Third Cause of
Action,
Paragraphs 83 through 86 inclusive of the Fourth Cause of Action,
Paragraphs
88 through 93 inclusive of the Fifth Cause of Action, and Paragraphs
93
through 95 of the Sixth Cause of Action, inclusive, as though set
forth in
detail below.

	99.	Defendant's conduct as set out in the First, Second,
Third, Fourth, Fifth
and Sixth Causes of Action above was intentional and malicious and
done for
the purpose of causing Plaintiff to suffer humiliation, mental anguish
and
emotional and physical distress.  Such conduct was not privileged and
was done
with a wanton and reckless disregard of the consequences to Plaintiff.

	100.	As the proximate result of the aforementioned acts,
Plaintiff suffered
humiliation, mental anguish and emotional and physical distress, and
has been
injured in mind and body in an amount according to proof at trial.

	101.	Defendant's statements and the publications thereof,
were the product of
an intent to injure Plaintiff for the sake of injury itself and were
evil and
malicious and exhibited a conscious disregard for Plaintiff's rights.
Furthermore, Defendant's conduct was cruel, despicable, beyond the
bounds of
decency, calculated to deceive the public and for the purpose of
injuring
Plaintiff for Defendant's own financial and strategic gain, or those
with who
they associated and conspired with thereby entitling Plaintiff to an
award of
exemplary and/or punitive damages against Defendant(s) in a sum
sufficient to
punish them and make an example of them to others.


	EIGHTH CAUSE OF ACTION

	(Negligent Infliction of Emotional Distress
	Against All Defendants, Including Does)

	102.	Plaintiff repeats, re-alleges and incorporates herein
by reference to
each of the allegations contained in Paragraphs 2 to 19 inclusive, of
the
general allegations, Paragraphs 21 through 52 inclusive, of the First
Cause of
Action, Paragraphs 54 through 75 inclusive, of the Second Cause of
Action,
Paragraphs 77 through 81 inclusive, of the Third Cause of Action,
Paragraphs
83 through 86 inclusive of the Fourth Cause of Action, Paragraphs 88
through
93 inclusive of the Fifth Cause of Action, Paragraphs 95 through 97 of
the
Sixth Cause of Action inclusive, and Paragraphs 99 through 101
inclusive, as
though set forth in detail below.

	103.	Defendant(s) knew or should have known that in
carrying out the
activities referred to in the First, Second, Third, Fourth, Fifth,
Sixth and
Seventh Causes of Action, and in otherwise engaging in the conduct
mostly
described hereinabove, that he/she/they may cause Plaintiff mental
anguish and
emotional distress.

	104.	Plaintiff repeats, re-alleges and incorporates herein
by reference to
each of the allegations contained in Paragraphs 2 to 19 inclusive, of
the
general allegations, Paragraphs 21 through 52 inclusive, of the First
Cause of
Action, Paragraphs 54 through 75 inclusive, of the Second Cause of
Action,
Paragraphs 77 through 81 inclusive, of the Third Cause of Action,
Paragraphs
83 through 86 inclusive of the Fourth Cause of Action, Paragraphs 88
through
93 inclusive of the Fifth Cause of Action, Paragraphs 95 through 97 of
the
Sixth Cause of Action inclusive, and Paragraphs 99 through 101
inclusive, as
though set forth in detail below.

	105.	Defendant's statements, and the publications thereof,
were the product
of an intent to injure Plaintiff for the sake of injury, itself, and
were evil
and malicious.  Furthermore, Defendant's conduct was cruel,
despicable,
willful, wanton, malicious and oppressive, beyond the bounds of
decency,
calculated to deceive the public and for the purpose of injuring
Plaintiff for
Defendant's own financial and strategic gain, or those with who he
associated
and conspired with hereby entitling Plaintiff to an award of exemplary
and/or
punitive damages against defendant(s) in a sum sufficient to punish
him/them
for their wilful and unprivileged injury to Plaintiff and make an
example of
him/them to others.


	NINTH CAUSE OF ACTION

	(Conspiracy Against All Defendants including Does)

	106.	Plaintiff repeats, re-alleges and incorporates herein
by reference to
each of the allegations contained in Paragraphs 2 through 19,
inclusive, of
the general allegations, Paragraphs 21 through 52, inclusive, of the
First
Cause of Action, Paragraphs 54 through 75 inclusive, of the Second
Cause of
Action, Paragraphs 77 through 81 inclusive of the Third Cause of
Action,
Paragraphs 83 through 86 inclusive of the Fourth Cause of Action,
Paragraphs
88 through 93 inclusive of the Fifth Cause of Action, Paragraphs 95
through 97
inclusive of the Sixth Cause of Action, Paragraphs 99 and 101 of the
Seventh
Cause of Action, and Paragraphs 103 through 105 of the Eighth Cause of
Action,
as though set forth in detail below.

	107.	Defendant(s), and each of them, knowingly and
willingly conspired and
agreed among themselves to engage in tortuous activities and wrongful
schemes
set out in the allegations above.

	108.	Defendant(s) and each of them, did the acts and things
herein alleged
pursuant to, and in furtherance of, the conspiracy and above alleged
agreement.

	109.	Defendant (s), and each of them, furthered the
conspiracy by cooperating
with each other and/or lending aid and encouragement to, and/or
ratifying and
adopting the acts of each other in perpetrating the conspiracy herein
alleged.

	110.	Upon information and belief, Plaintiff alleges that
the conspiracy
herein alleged commenced sometime in 1994 and is ongoing as of the
date of the
filing of this Complaint.

	111.	Upon information and belief, Defendants'
co-conspirators included the
Office of Special Affairs of the Church of Scientology International,
other
Scientology entities, executives, employees, volunteers, attorneys,
private
investigators and scientology public members including Church of
Scientology
attorney Kendrick L.  Moxon, who was an unindicted co-conspirator in
the case
of U.S. v. Hubbard, which involved the Church of Scientology and the
largest
ever known criminal infiltration of the United States Government, and
Eugene
Ingram, a former Los Angeles police department officer who resigned
facing
gun, prostitution and drug related charges and who has outstanding
arrest
warrants issued against him by at least three different jurisdictions. 
Eugene
Ingram's telephone number includes the numbers 666 the number of the
anti-
Christ beat in Revelations Chapter 13.  The conspiracy continues, for
example,
through its instigators, such as Kendrick L. Moxon, Esq. and his
conspiring
clients such as the Church of Scientology International soliciting,
and paying
for, the legal representation of defendant Cipriano in a related case
(Berry
v. Cipriano, LASC Case No. BC184355) notwithstanding the obvious
non-waivable
conflict of interest that exists between defendant Cipriano and
material
witness and potential defendant Kendrick L. Moxon, Esq. and the clear
breach
of the Church of Scientology's section 501(c)(3) tax status that
result from
such payments, conduct and activity.  Moreover, after the filing of
this
lawsuit, Scientology hired investigator Eugene Ingram continued to
conduct an
investigation/character assassination of Plaintiff and has alleged
concern
that Plaintiff will drug into a coma his 22 year old housemate and
mentee and
then homosexually rape him!

	112.	As a proximate result of the wrongful acts herein
alleged, Plaintiff has
been generally damaged in an amount to be determined according to
proof at
trial.

	113.	Defendant's statements and the publications thereof,
were the product of
an intent to injure Plaintiff for the sake of injury itself and were
evil and
malicious and exhibited a conscious disregard for Plaintiff's rights.
Furthermore, Defendant's conduct was cruel, despicable, beyond the
bounds of
decency, calculated to deceive the public and for the purpose of
injuring
Plaintiff for Defendant's own financial and strategic gain, or those
with who
they associated and conspired with hereby entitling Plaintiff to an
award of
exemplary and/or punitive damages against Defendant(s) in a sum
sufficient to
punish them and make an example of them to others.

	AS TO THE THIRD, FOURTH, AND FIFTH CAUSES OF ACTION

 	1.	For a preliminary injunction and a permanent
injunction enjoining each
Defendant and his/her/its agents, servants, and employees, and all
persons
acting under, in concert with, or for him/her/it/them from continuing
to
publish the above described false statements, implications and
innuendoes
about Plaintiff.

	AS TO ALL CAUSES OF ACTION

	2.	For general damages according to proof at trial;

	3.	For special damages according to proof at trial;

	4.	For exemplary or punitive damages in an amount to be
awarded at trial;

	5.	For costs of suit incurred herein;

	6.	For such other and further relief as the court may
deem just and proper.


	PLAINTIFF DEMANDS TRIAL BY JURY.

Dated:	April __, 1998
BERRY, LEWIS, SCALI & STOJKOVIC



________________________________
CHRISTIAN J. SCALI
Attorneys for Plaintiff
GRAHAM E. BERRY

 	VERIFICATION

	I, Graham Edward Berry, am the plaintiff in the above-entitled
action.  I
have read the foregoing Complaint and know the contents thereof. The
same is
true of my own knowledge, except as to those matters which are therein
alleged
on information and belief, and as to those matters, I believe them to
be true.

	I declare under penalty of perjury under the laws of the State
of California
that the foregoing is true and correct.

	Dated this ___ day of April, 1998 at Los Angeles, California.

							_______________________________
							Graham Edward
Berry