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A common way by which Scientology handles criticism is by attacking its source. It is not a persons' arguments that are addressed, it is the integrity of the person itself. This technique is called "Dead Agenting".

What follows are some example of Dead Agenting material that Scientology has published on Graham Berry, an attorney who has been involved in several cases against the Church of Scientology in the U.S.

1. Statement of the CAN reform group
2. Affidavit of Robert Cipriano
   (retracted by another affidavit in 1999)
3. Affidavit of Bernard LeGeros
4. Affidavit of Mathilde Krim
5. DA pack which sums it all up

It has come to our attention that Los Angeles attorney Graham E. Berry has been attempting to perpetrate a hate campaign against the Church of Scientology International and thus we are writing to inform you of the real motives and unscrupulous activities of Mr. Berry's activities so that you are not misled and deceived by him.

Mr. Berry, an attorney with the Los Angeles firm of Lewis D'Amato Brisbois & Bisgaard, represented hypnotist Uwe Geertz and his patient, convicted felon Steven Fishman. Fishman was convicted by a federal court in San Francisco of fraud and obstruction of justice and was sentenced to five years in prison. The obstruction of justice conviction arose after Fishman lied to the Federal Bureau of Investigation (FBI), falsely blaming that the Church for his fraud crimes.

Mr. Berry paid thousands of dollars to a few disgruntled former Church members in exchange for these former members signing sworn statements which made numerous false claims about the Church. Mr. Berry used these written statements to generate prejudice against the Church of Scientology International in an unsuccessful effort to collect attorneys' fees. The trial court refused to consider the falsely sworn statements, described them as "junk" and denied Mr. Berry's motion.

What was not known at the time was that some of the sworn written statements Mr. Berry filed had been altered. According to two of Mr. Berry's own paid witnesses, Vicki and Rick Aznaran, Berry filed statements on their behalf which they never authorized. Vicki Aznaran stated in a sworn statement of May 19, 1994 that she prepared an eight page sworn statement for Mr. Berry for which she was paid $2,500. However, Mr. Berry altered this statement and turned it into a nineteen page statement with her original signature page attached to it without her knowledge or consent and he then filed it in court. Likewise, Rick Aznaran has testified in a sworn statement of May 19, 1994 that Mr. Berry modified a declaration from him by adding in allegations of which he had no personal knowledge. I have enclosed a copy of the May 1994 declarations of Vicki and Rick Aznaran.

When the Aznarans wrote to Mr. Berry's lawfirm demanding that the ninteen page false statement be withdrawn, Gordon Calhoun, Mr. Berry's partner, refused to do so. As a note, in 1992 a $1.5 million fine - perhaps the largest sanction ever imposed against a lawyer in California - was imposed against Mr. Calhoun for pursuing a frivolous lawsuit on behalf of his client.

Mr. Berry paid $17,000 to another former Church member, Andre Tabayoyon, for a sworn statement consisting of numerous falsehoods, on matters of which Tabayoyon had no knowledge whatsoever. Several other witnesses were paid over $70,000 for similarly false testimony.

The statements filed by Mr. Berry had only one real purpose, as they were irrelevant to any legal proceedings. In February 1994, Mr. Berry sent a letter demanding that the Church pay him approximatelly $70 million dollars so as to "minimize public relations problems." Berry's letter was even written unbeknownst to many of the individuals on whose behalf he was supposedly writing. Two individuals included on the list, when contacted later, were surprised to learn that Berry had asked the Church for $3 million in exchange for their "silence" about Scientology.

After the Church refused this extortionate demand, Mr. Berry created the Tabayoyon declaration and engineered its publication in the tabloid press. Mr. Berry then attempted to generate articles in the tabloid press using the false statements in the declaration. Every United States newspaper which at first expressed interest in doing a story, including the Washington Post and even two tabloid newspapers, decided NOT to publish anything after learning the truth. They realized that the allegations were baseless and obviously false and the source for them just not credible.

Because of the unconscionable tactics used by Berry in litigation - tampering with evidence and extortionate demands for money - his background was examined to determine what might explain his sinister conduct and attempted scams. What we found shows an individual of such dubious character that your office would do well to avoid him, as his recent activities are not something new - he has a long history of involvement with criminals and criminal activities.

In 1985, Berry's law partner was a man by the name of Jerome L. Spiegelman, who is infamous in New York State for being imprisoned for the crime of embezzling settlement checks intended for his client. In fact, a law was created specifically after Mr. Spiegelman's conviction to prevent attorneys from defrauding their clients and it is colloquially referred to as the "Spiegelman Law."

According to media reports, Spiegelman embezzled close to one million dollars from clients. The assistant district attorney from Manhattan who investigated and convicted Spiegelman, John A. Bicks, said the figure was closer to $3 million. According to the investigator on this case for the New York Bar, Patricia Smillie-Scaveli, the Bar investigation and the Special Prosecutors Office investigation intensified around August 1985. At some point after mid-August 1985, according to Scaveli, Spiegelman went into hiding and eventually was lured out of hiding and arrested by a DA's office sting operation.

Berry fled the United States for New Zealand or Australia in early 1986, right around the same time that the New York District Attorney's Office filed a felony complaint against Jerome Spiegelman for first degree fraud and forgery, on January 24, 1986. Investigator Scaveli noted that had the Bar and the Special Prosecutors Office known about Berry's partnership with Spiegelman, Mr. Berry would have been a subject of their investigation, too. Berry filed for bankruptcy at the end of August 1985, claiming debts of $181,000.

I think you should be apprised of some other background information which came to light in the course of dealing with Mr. Berry.

One former associate, Robert Cipriano, has executed a declaration describing some of Mr. Berry's habits. According to this declaration, Berry abused cocaine in his law office and preferred underage boys for his sexual gratification. Mr. Cipriano stated that between May 1984 and February 1985, he personally observed at least 50 to 60 boys between the ages of 14 and 16 in the company of Berry at his New York lawfirm.

On one instance, according to this declaration, Mr. Berry told him about taking a boy of twelve years of age to the Anvil Club, a notorious gay, sado-masochistic club in Greenwich Village in New York City which Berry used to frequent.

According to Cipriano's declaration, Berry was associated with Andrew Crispo, a New York City art gallery owner 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. Crispo was never convicted for this murder but an associate, Bernard LeGeros, was convicted in February 1985 and has been in custody since that time.

When LeGeros was interviewed earlier this year, he stated that he first met Graham Berry at Andrew Crispo's penthouse residence in the early 1980s, and that he had personally observed Berry at this residence on three or four occasions. Crispo had another close associate by the name of John Mammano, reportedly a member of the mafia, who imported gay "snuff" movies into the United States from Mexico. ("Snuff" movies are pornographic movies which some claim contain actual murders on film).

Several other witnesses interviewed have stated that Berry used to frequent the gay nightclub called "Rounds" which was located directly below Berry's lawfirm of Spiegelman & Berry in New York City, that Berry was frequently in the company of young males, and that he bragged about homosexual experiences with these young males.

Keeping this background in mind, and the false declarations described above, it became clear that Mr. Berry's entire stock in trade consisted of purchasing testimony to support the allegations of his clients. There has not been a single witness used by Berry who was not paid an exorbitant sum for his testimony. To pay for this testimony, Berry used insurance monies which were $900,000 beyond the insurance policy limit, in what may be the worst example of leakage (a term which refers to overexpenditure of insurance funds) ever suffered by the insurance company in question.

The truth, which it is only fair to make known to any recipients of Mr. Berry's letters, is that the people paid by Mr. Berry for their testimony are not believeable.

Editor's note: I snipped the Fishman dead-agenting material. Follow the link.

Steven Fishman

Vaughn and Stacy Young

A couple by the name of Vaughn and Stacy Young were approached by Berry about a year ago. Berry asked them for declarations to support various allegations that Steve Fishman had made against the Church. However, the information about Fishman which Berry gave the Youngs proved beyond doubt that Fishman was a fraud. An unpublished manuscript Fishman had written purporting to describe his experiences in the Church of Scientology contained descriptions of alleged incidents that the Youngs knew, from their own experience in the Church, could not possibly have occurred. A video Fishman had made to demonstrate his "expertise" in Scientology contained errors so elementary and obvious that upon viewing it, the Youngs spontaneously burst out laughing.

The Youngs, desperate for money, constructed their declarations for Berry by twisting the words and concepts so as to create the impression that Fishman knew what he was saying about Scientology, without their having to say so directly. The Youngs had left the Church of Scientology four years previously, and until mid-1993, had neither contacted the Church or indicated any hostility to it.

The Church had in fact received an indication of the Youngs' intentions a few months before, when a Church attorney had been contacted by Vaughn Young with a request that the Church pay him $50,000 to buy the "rights" to anything he might write about Scientology. Young stated that he was hard up financially and had just lost his job. Underlying his offer was a veiled threat that if the Church did not pay up, he would "make trouble" by taking his writings elsewhere. The Church of course turned his proposal down.

Trying to solve their financial problems, the Youngs aligned with Berry, and embarked on careers as paid witnesses as a solution to huge debts they had accumulated.

Exactly how Graham Berry and the Youngs made use of one another became apparent during a series of July 1994 meetings between the Youngs and two Church representatives. These meetings had been originated by the Church to resolve any problems the Youngs had with Scientology and so bring their practice of concocting anti-Scientology testimony to an end. Although, as will be seen, this purpose was not accomplished due to the Youngs' amoral greed, the solemnity of the meetings in Seattle, Washington, encouraged the Youngs to give forth a more truthful account of their motives.

During these meetings, Stacy Young tearfully admitted that she was so desperate for money, she agreed to make whatever statement Berry asked of her under oath so long as it would result in her being paid. According to Vaughn, it was "a great way to utilize twenty years [in the Church]" and he could make what in any job would be a weekly salary with one afternoon of work. Vaughn was paid $120 an hour for testimony and $100 an hour for consultation.

The Youngs, after consulting with Berry, decided not to resolve their differences with the Church. Instead, they demanded the Church pay them $540,000 - enough money to live on for five years without having to work. Although they have both admitted in deposition that they have no claims against the Church of Scientology, they told the Church representatives that they earned a good living fabricating anti-Scientology testimony, and if the Church wanted them to stop, it should pay up. When challenged on the morality of their position, they responded that it was not a matter of right and wrong, but merely a matter of money.

Even putting aside the evidence of their own statements, plenty of proof exists of their mendacity. So much so, that no court has accepted the Youngs' credentials as expert witnesses, a status they have long coveted because it would enable them to charge more for their "services."

For documentation on the above statements, write to:

CAN Reform Group
6201 Sunset Boulevard #21
Hollywood, Ca. 90028

Editor's note: The header is only shown for one of the messages.

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******######******

In July 1979, Mr. Berry was living with a gay companion, Frank Hoffey, at 10 East 13th Street, Suite LD, New York City. Mr. Hoffey was also an attorney from New Zealand.

On January 1, 1983 Mr. Berry and Mr. Hoffey officially became law partners and named their firm Berry & Hoffey. Their apartment was at the same location as their law practice: 10 East 13th Street, Suite LD, New York City.

On March 2, 1983 Mr. Berry signed, under the penalty of perjury, the Certificate of Incorporation of A.I.D. Medical Foundation. Paragraph 7 of the certificate of incorporation read as follows:

"The names and addresses of the initial directors of the corporation are as follows:

Frank Hoffey
10 East 13th Street, Suite LD
New York, New York 10003

Mathilde Krim
33 East 69th Street
New York, New York 10021

Graham E. Berry
10 East 13th Street, Suite LD
New York, New York 10003"

On June 3, 1983, Mr. Berry received a $12,940.00 loan from John Mammano. (On September 4, 1985, Mr. Berry filed for personal bankruptcy and listed the loan on the list of his creditors. In one letter Mr. Berry referred to Mr. Mammano as a loan shark.)

On December 14, 1983 Mr. Hoffey wrote a partner dissolution letter to Mr. Berry accusing him of numerous improprieties.

On March 8, 1984 Mr. Hoffey wrote another partner dissolution letter to Mr. Berry accusing him of numerous improprieties.

On March 12, 1984 Mr. Berry wrote a partner dissolution letter to Mr. Hoffey accusing him of numerous improprieties.

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.

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.

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.

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.

On December 14, 1984, Berry's partner, Mr. Spiegelman, stole $1,050.00 from the account of a client (deceased 12-4-84), Eugene Brigati, by forging a bank withdrawal slip on Mr. Brigati's bank account.

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.

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.

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.

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.

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

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

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

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 investigtion 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.)

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.

On February 5, 1986, Mr. Spiegelman, was arrested in New York.

On April 17, 1986, Mr. Spiegelman pled guilty to Grand Theft.

On April 29, 1986, Mr. Spiegelman was disbarred in New York.

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.)

In mid-1986, Mr. Hoffey, Berry's former partner, dying of AIDS, returned home to New Zealand to live out the last months of his life.

On July 3, 1986, Mr. Berry became a citizen of the United States during bicentennial ceremonies on Liberty Island in New York.

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 in part of a scheme to defraud the bank assumed the loan shortly after the purchase. This loan fraud is currently under criminal investigation.

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

The following a brief summary of additional information was learned primarily from witnesses interviewed in New York City:

ROBERT CIPRIANO told stated that he was a partner with attorney Jerome Spiegelman in an entertainment-talent agency-management company called Cipriano Enterprises between 1980 and 1985. Between 1984 and 1985 the company was located at 303-305 East 53rd Street, New York City. Mr. Cipriano's primary responsibility was running Cipriano Enterprises while Mr. Spiegelman ran his law practice.

Mr. Cipriano stated that beginning in May 1984, Mr. Spiegelman formed a law partnership with attorney Graham Berry, formerly from New Zealand. They called their law practice Spiegelman & Berry and operated out of 303-305 East 53rd Street, New York City. Mr. Cipriano stated that the law officers were on the second floor, directly above a gay nightclub called Rounds, which Mr. Berry and Mr. Spiegelman frequented..,, Rounds was frequented by young male gay hustlers and older gay Johns.

Mr. Cipriano stated that between May 1984 and February 1985, when Mr. Cipriano left New York for California, he had numerous contacts, conversations and observations of Mr. Berry and Mr. Spiegelman. Mr. Cipriano stated he observed Mr. Berry and Mr. Spiegelman frequently abuse cocaine in their law offices, many times while they were performing legal duties for clients.

Mr. Cipriano stated that Mr. Berry and Mr. Spiegelman were promiscuous gays. They each preferred young under age boys for their sexual gratification. Mr. Cipriano stated that Mr. Berry was a classic example of a Chicken Hawk, which in street vernacular is a term for an adult male who has sexual relations with boys under the age of sixteen.

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 new pretty boys and young men in order to make dates for himself with the ultimate objective of fulfilling his sexual desires. Separate confirmation verified that Berry incorporated the following businesses, listing his NY law office as the address: Michelle Lianne Corporation, Portfolio Model Management Corporation and Urban Male Productions Inc.

Mr. Cipriano stated that Mr. Berry routinely told him, in graphic detail, about Mr. Berry's sexual exploits with boys under the age of sixteen. Mr. Berry told Mr. Cipriano that Mr. Berry would sodomize those boys and had them orally copulate his penis.

Mr. Cipriano stated that between May 1984 and February 1985, he 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 in East 53rd Street. Mr. Berry would frequently point out which boy he had had sex with and would tell Mr. Cipriano all about the sexual activity in detail. Mr. Berry frequently had these young boys perform odd jobs at the law firm, usually in exchange for cocaine that Mr. Berry provided them.

Mr. Cipriano stated that Mr. Berry used to frequent the Anvil Club, a notorious gay S&M club, in Greenwich Village in New York City. Gay male patrons of the Anvil 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.

Mr. Cipriano stated that Mr. Berry once told him about taking a boy of twelve years of age to the Anvil Club for the purpose of introducing him to gay sex.

Mr. Cipriano stated that in about 1984 either Mr. Berry or Mr. Spiegelman introduced him to David Lee, a 22 year old gay man who was living in a gay relationship with Mr. Berry. Mr. Lee was working as a production assistant for Coast to Coast Productions in New York City. Mr. Cipriano hired Mr. Lee to work for Cipriano Enterprises at the offices on East 53rd Street.

Mr. Cipriano stated he recalled that immediately prior to Mr. Berry becoming a partner with Mr. Spiegelman, he had just broken up his relationship and law partnership was another gay man, a New York City attorney named Frank Hoffey. Mr. Cipriano recalled Mr. Spiegelman represented Mr. Berry in a subsequent law suit brought by Mr. Berry against Mr. Hoffey. This lawsuit and the alleged injustices Mr. Hoffey brought upon Mr. Berry were frequently discussed in the office by Mr. Berry.

Mr. Cipriano stated that Mr. Berry represented the owners of Studio 54 nightclub in New York City on slip and fall type cases. As a result, Mr. Berry never had to pay for anything he or his guests consumed at Studio 54. Mr. Berry frequently invited Mr. Cipriano and Mr. Spiegelman to be his guests at Studio 54 and they too were treated like VIPs. Mr. Cipriano stated the patrons of Studio 54 were approximately 50% gay.

Mr. Cipriano stated that Mr. Spiegelman agreed to let Mr. Berry become his partner because Mr. Berry promised to bring to their law firm his existing clients that were in the entertainment, male modeling and night club scene, such as Studio 54 in New York City. Mr. Berry was also frequently surrounded by young attractive male models, some below the age of 16, that Mr. Berry used for sex. Because Mr. Spiegelman also enjoyed engaging in sexual acts with these type of boys and young men and because he also wanted to add entertainment law to his practice, he and Mr. Berry formed Spiegelman & Berry. Their offices were both at the same address. The only thing that separated their offices was the common wall.

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. Barry's entourage.

Mr. Cipriano stated that Mr. Spiegelman also arranged illegal adoptions. Mr. Spiegelman would pay $7,000.00 to $8,000.00 to girls in Florida to get pregnant. He would purchase their babies for $15,000.00 to $20,000.00 and resell them.

DENNIS CANTWELL -in Greenwich Village in New York City stated that he used to be a bartender at Studio 54 in New York City. I showed him a recent photograph of Mr. Berry. Mr. Cantwell stated that he recognized Mr. Berry and recalled that Mr. Berry was an attorney for, and an associate of, Steve Rubell and Ian Schrager, the owners of Studio 54. Mr. Berry frequented Studio 54 on a regular basis. Mr. Cantwell stated that Mr. Berry was gay and into perverted sexual practices. Mr. Cantwell recalled hearing Mr. Berry describe an incident in which Mr. Berry paid a kid $200.00 to have the kid defecate on Mr. Berry's chest. Mr. Cantwell also stated that Mr. Berry hung out at the Haymarket, possibly in the company of Andy Warhol and Roy Cohn. He described Mr. Berry as a John for straight macho type young male prostitutes.

TROY GLICK stated that he's not gay. He stated that when he was around seventeen years of age his best friend was Austin Spiegelman, attorney Jerome Spiegelman's son. He used to live with Austin and Jerome in a flat on East 83rd by 3rd Avenue around 1984. At that time, Mr. Glick was attending Brooklyn College. He used to work for Spiegelman & Berry at their office at,, 303-305 East 53rd Street. He was the office manager and designed a computer data base for Mr. Berry. Although Mr. Glick never observe Mr. Berry ingest cocaine he assumed he abused cocaine in his office based on the fact that Mr. Berry had every visible sign a cocaine user exhibits when under the influence.

Mr. Glick stated that he observed a total of at least twenty boys between the ages of sixteen and twenty years of age in the company of Mr. Berry in Mr. Berry's office during the time he worked for Spiegelman & Berry. Mr. Glick stated Mr. Berry had been having sexual relations with these boys and young men.

Note by the web page maintainer:
I received an email by Troy Glick (tglick@sentinelinteractive.com) which states:

"I would like to correct this. I never made these statements."

Mr. Lauricella stated that he and Mr. Berry have never had sex with each other. They used to go together to dinner and plays. Mr. Lauricella stated that it was possible that Mr. Berry hung around with him because he was well connected in the gay community and because he was well known as a theatrical producer. He said it was possible that Mr. Berry took advantage of Mr. Lauricella's status in order to make friends of Mr. Lauricella's friends.

Mr. Lauricella stated that Mr. Berry preferred to have sex with young male body builders and young male model types. Mr. Lauricella stated that he perceived Mr. Berry as being sexually promiscuous with many young males.

Mr. Lauricella stated that Chick Metzendorf used to live with him. Mr. Metzendorf used to be very close friends with Mr. Berry. Mr. Metzendorf was bisexual and was very promiscuous. Mr. Lauricella stated that Mr. Metzendorf would have sex with anyone. Mr. Metzendorf is now deceased.

Mr. Lauricella used to own a home on Fire Island that was frequented by Mr. Berry and other gays.

Mr. Lauricella stated that Mr. Berry told him he left New York City in 1986 to visit his family in New Zealand.

Mr. Lauricella stated that he'd been inside Rounds, a gay bar at 303-305 East 53rd Street, New York City, on numerous occasions with Mr. Berry, Mathilde Krim, the late Roy Cohn and even Elizabeth Taylor. (Rounds was the bar directly below the offices of Spiegelman & Berry. It is still in business at the same location.)

Mr. Lauricella stated that Mr. Berry is very strange at times and is very selfish. Mr. Lauricella also described Mr. Berry as being arrogant and that this offends a lot of people.

Mr. Lauricella would not answer questions about drug dealing. However it is a matter of public record that on April 24, 1985 Mr. Lauricella was convicted in Federal District Court in New York for conspiracy to distribute hashish and marijuana and for distributing hashish. He was one of a group of persons convicted in a $45,000,000.00 drug smuggling operation. He was sentenced to 15 years in federal prison.

WILBUR LONG of Greenwich Village in New York City stated that he worked as a paralegal for the Berry & Hoffey law firm from 1983 until 1984 and then worked as a paralegal at the Spiegelman & Berry law firm from 1984 until 1985.

Mr. Long stated that at the same time he was taking a paralegal course in 1983 he had a friend who worked in the New York theater named Gilbert Gib Jones who was then Mr. Barry's roommate. Mr. Jones introduced him to Mr. Berry and Mr. Berry hired him to work as a paralegal at the Berry & Hoffey law firm in New York City. Mr. Long stated that he, Mr. Jones, Mr. Hoffey and Mr. Berry were all gay. He thought that Mr. Hoffey was in love with Mr. Berry.

Mr. Long stated that Mr. Berry would come to work and always bragged about the young males he had picked up the previous night and described the type of sex they had together. Mr. Berry frequently told him that the young males fell in love with him and would arrange for them to come to the law office and show them off. It was obvious to Mr. Long that the young males were just male prostitutes after Mr. Berry's money and that they really weren't in love with Mr. Berry.

Mr. Long stated that Mr. Berry's young male friends were always good looking, usually with blond hair and blue eyes. He suspected Mr. Berry must have paid for their sexual service because Mr. Berry wasn't attractive and the young males probably would never have had sex with him for free. He recalled Mr. Berry dated one young male for six to eight weeks and stated that was the longest he knew Mr. Berry had ever spent with one lover.

Mr. Long stated he enjoyed going out with Mr. Berry because Mr. Berry had a lot of celebrity friends who he introduced to Mr. Long. He accompanied Mr. Berry to Studio 54 once or twice and knew that Mr. Berry represented the owners, Steve Rubell and Ian Schrager. Both Mr. Rubell and Mr. Schrager later served time in prison for tax evasion. Mr. Rubell is now dead.

Mr. Long stated that when he worked for Spiegelman & Berry it was always Mr. Spiegelman who paid him because Mr. Berry could never afford to. He described Mr. Berry as a bullshitter however he liked Mr. Berry as a friend.

Mr. Long stated that he used to receive a Christmas card from Mr. Berry almost every year, however, the last time he received one was about two or three years ago. They last spoke about four years ago. Based upon his observations of Mr. Berry in New York, he thought that Mr. Berry was incompetent as an attorney and was surprised to learn that he had passed the California bar.

JEROME SPIEGELMAN and Larry Kwan, Mr. Spiegelman's current gay roommate and companion were spoken with. Mr. Spiegelman stated that Mr. Berry was his law partner for one and one-half years at 303-305 East 53rd Street, New York City. Mr. Spiegelman stated that Mr. Berry was his partner until November 1985. Mr. Spiegelman stated that when they completed the dissolution of 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. He said that Mr. Berry was neither arrested nor charged for any of the crimes for which Mr. Spiegelman subsequently plead guilty. Mr. Spiegelman served four years in prison for these crimes.

Mr. Spiegelman stated that Mr. Berry came to him after Mr. Berry had broken up his law partnership with Mr. Hoffey. Mr. Berry told him that the owners of Studio 54 were his clients and that he knew other celebrity types that frequented Studio 54. He told Mr. Spiegelman that he could bring celebrity clients to the firm if Mr. Spiegelman agreed to become a partner with him. Mr. Spiegelman agreed to this, however, Mr. Berry's promises never materialized.

Mr. Spiegelman stated he paid Mr. Berry a weekly draw of $300.00. He stated that he paid Mr. Barry with funds Mr. Spiegelman had embezzled from his clients.

Other than going five or six times with Mr. Berry to Studio 54 and socializing with him at Rounds, the gay bar situated below the Spiegelman & Berry offices, he didn't spend too much time outside the office with Mr. Berry.

Mr. Spiegelman stated that he knew Mr. Berry liked to have sex with the young, good looking, pretty-boy, male model types.

Mr. Spiegelman stated that Mr. Berry fled the United States for either New Zealand or Australia just prior to Mr. Berry's arrest because Mr. Berry was afraid of the criminal investigation that was actively being investigated at the time.

ANDREW CRISPO of 381 West 12th Street, New York City at first lied and said he was someone else. He then became very upset and started screaming after admitting that he was in fact Andrew Crispo. Crispo started yelling obscenities and said he didn't want to talk about any relationship he had with Graham Berry. He then threatened physical harm.

BERNARD LeGEROS, an inmate, located at Clinton Correctional Facility in Dannemora, New York stated: "he was convicted for the February 1985 murder of Eigil Vesti, a gay fashion student and model from Norway. He was arrested one month after the murder and has been in custody since. He stated that Andrew Crispo, a gay man was also involved in the Mr. Vesti's death. Mr. LeGeros stated he has never been a gay."

Mr. LeGeros stated he first met Mr. Crispo in 1977 when Mr. LeGeros was about fifteen years of age. He started to become involved in Mr. Crispo's criminal activities about 1982. By 1984 he was directly involved in, and knowledgeable about, most of Mr. Crispo's criminal activities. Mr. LeGeros also worked for Mr. Crispo at his art gallery in New York. Mr. LeGeros frequently went to Mr. Crispo's penthouse residence at 381 West 12th Street in Greenwich Village, New York City, and socialized with Mr. Crispo and his friends. As such, he stated he had personal knowledge of many aspects of Mr. Crispo's personal life. Mr. Crispo frequently abused cocaine and furnished Mr. LeGeros with cocaine on numerous occasions. Mr. LeGeros also observed Mr. Crispo engage in homosexual sadistic and masochistic sexual acts with a variety of men.

Mr. LeGeros stated that he first met Mr. Berry, at Mr. Crispo's penthouse residence in the early 1980's. He was introduced to Mr. Berry and was told that he was an attorney and the law partner of attorney Frank Hoffey. Mr. LeGeros stated that previously he met Mr. Hoffey on several occasions and knew that he was a close friend of Mr. Crispo's. Mr. Hoffey also gave legal advice to assist Mr. Crispo carry out his illegal enterprises. Mr. LeGeros stated that he also observed Mr. Hoffey and Mr. Crispo ingest cocaine together on several occasions.

Mr. LeGeros stated he personally observed Mr. Berry inside Mr. Crispo's penthouse residence 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.

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 Knockoff. The party was actually a pyramid scheme engineered by Mr. Crispo and his friend, Sandi Franklin.

Mr. LeGeros said that one of Mr. Crispo's closest friends was Sam Collins. He believed that Mr. Berry was also a close friend of Mr. Collins. During 1983 and 1984 Mr. LeGeros heard that Mr. Crispo and Mr. Collins frequented Rounds, a gay bar on East 53rd Street in New York City where they would pick-up young males, furnish them cocaine and have sex with them.

LeGeros stated that Mr. Hoffey and Mr. Crispo were also good friends with John Mammano, who was supposed to be a member of the Mafia. Mr. LeGeros knew that Mr. Crispo, Mr. Hoffey and Mr. Mammano were involved in an illegal scam involving the lithographic plates used to make prints of artist Lowell Nesbitt's drawings. Mr. LeGeros stated he assumed that Mr. Berry also knew about this because it occurred at the same time that Mr. Berry and Mr. Hoffey were law partners.

Mr. LeGeros stated that Mr. Crispo told him that Mr. Mammano was a loan shark who loaned several thousand dollars to Mr. Crispo in late 1984. In 1985, when it was time to repay Mr. Mammano, Mr. Crispo gave a cashier's check to Mr. LeGeros for him cash. When Mr. Mammano came for his cash, Mr. Crispo thought Mr. Mammano was going to kill him and had Mr. LeGeros hide in an adjoining room armed with a loaded shotgun, however the money was repaid without incident. According to Berry's bankruptcy, he had also received a loan from Mr. Mammano. Mr. LeGeros recalled that Mr. Mammano seemed to always be at Mr. Crispo's art gallery. Mr. Mammano drove a Jaguar XJ6 painted a light color.

Mr. LeGeros stated that Mr. Crispo told him that Mr. Mammano was fencing stolen art work, including sculptures, for him. Mr. Crispo also told him that Mr. Mammano sold cocaine to Mr. Crispo and that Mr. Mammano imported gay and straight snuff movies into the United States from Mexico. Snuff movies are obscene movies in which a person is actually murdered on film. Mr. LeGeros said that he heard that a man from Texas named John produced the snuff movies in Mexico and that John was subsequently arrested and convicted for committing a crime in Texas.

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 infants sold by their mothers to persons unable to give birth to children of their own.

Mr. LeGeros stated that 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.

Mr. LeGeros stated that Mr. Crispo once tried to have sex with him in 1982 or 1983, however, he refused to do this and he threatened to harm Mr. Crispo if he ever tried it again.

Mr. LeGeros stated that details of his association with Mr. Crispo and Mr. Crispo's relationship with several of his close gay friends, including Sam Collins, were extensively written about in BAG OF TOYS, a book written by David France published in 1992. He suggested I read the book for additional information.

In paragraph 54 of a declaration written by Mr. Berry on May 13, 1994, he confirmed his long time friendship with Sam Collins as follows:

"On or about April 27, 1994 I received a telephone call from Sam Collins. Sam Collins resides in Cincinnati, Ohio. He used to reside in New York and has been a friend of mine since 1979."

Mr. Berry's declaration also contains three separate instances where Berry denied knowing Mr. Crispo. He denied ever meeting Mr. Crispo; he denied ever being in his residence or with for any time socially; he also declared he had never been to his residence or spent any time. After reading the book, BAG OF TOYS, and after attempting to interview Mr. Crispo I understand why Mr. Berry lied in his declaration and said he didn't know Mr. Crispo; Mr. Crispo is one of the sickest, most sexually perverted, individuals I've ever heard about.

However a declaration from Mathilde Krim showed this to be untrue. In her declaration, Krim stated the following:

[full quote of declaration snipped]

After Berry left the Hoffey partnership, he formed one with Jerome L. Spiegelman. Shortly after their partnership was formed, Spiegelman became infamous in New York State for being the first lawyer ever to go to jail for ripping off his clients in an amount estimated to be in excess of $3 million. Before Spiegelman was arrested, he and Berry dissolved the firm and Berry filed for bankruptcy on 31 August 1985 claiming $181,869.60 in liabilities. He went through with his bankruptcy that year but at present he has three Federal tax liens which total more than $100,000 for not paying his taxes.

Last year, Berry left another major LA law (Lewis D'Amato) firm then threatened to sue them as well.

Berry has threatened to sue Faegre and Benson, the firm Wollersheim fired; Ross Dixon, the firm which Lerma fired; Lewis D'Amato, the firm he quit last summer; the CAN bankruptcy trustee's firm; attorneys for the Church, etc, etc, etc.

Just like his repeated dire predictions - none have materialized.

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