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In his August declaration, Cipriano describes wavering in his resolve. At one point, he wanted to involve police in the dispute between the two sides. But Moxon and Ingram, he writes, "worked on" him, asking Cipriano what he wanted in return for staying the course.
Cipriano says Moxon then began a program to make Cipriano a more formidable court combatant. Out of work at the time, Cipriano still had the New Jersey felony debt hanging over him, and his girlfriend was skeptical about Scientology. Cipriano says Moxon knew Berry would try to take advantage of weaknesses in court.
First, Cipriano needed a steady job.
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Cipriano says that Moxon arranged for him to work at Earthlink, the major Internet service provider started by Scientologist wunderkind Sky Dayton in 1994. In its early days, Earthlink's employees and the majority of its subscribers were Scientologists. But today the company serves more than a million customers, and Scientologists have less presence on its staff.
Cipriano says Moxon seemed to have unusual pull at the company. After Moxon's recommendation, Cipriano says Earthlink employee George Williams took him to the company's human resources department and told a woman there to hire him. Seemingly stunned, the woman said they had no jobs at the time in dial-up sales. "'Who the hell do you know in the company?' she as ked me. I said something about Kendrick Moxon being my attorney, and she said, 'Oh, that explains it.' " Cipriano worked at Earthlink for little more than a month.
Earthlink's George Williams acknowledges that Cipriano was referred by Moxon. "Rick Moxon did refer him to our company, but that's not unusual," he says. Williams says he's shocked that Cipriano would suggest he was hired as a favor to Moxon. "That statement is false. I interviewed [Cipriano] myself. He had a very impressive list of accomplishments....Cipriano brought in five letters of recommendation, and he probably had the most impressive series of r'sum's that I've ever seen."
In June 1998, Cipriano says Moxon moved him into a Scientology boardinghouse to get him away from his meddling girlfriend. Moxon also began preparing him for a deposition that was scheduled for July. "Mr. Moxon told me to lie about the ages of Mr. Berry's intimate relationships....Mr. Moxon told me to get Mr. Berry 'pissed off' at the deposition. It appeared to me that this was a game for Mr. Moxon, and it was more about scaring Mr. Berry than about a real cause of action based on truthful facts," Cipriano states in his August declaration.
Moxon denies that he encouraged Cipriano to do anything other than tell the truth: "I believed Cipriano's  declaration to be accurate when he came to me and told me he was being sued by Berry and affirmed the accuracy of the declaration; I believed him when he affirmed it under oath in his deposition; I believed him when he affirmed it in an e-mail to Berry; I continue to believe in its accuracy based on corroborating evidence I have received."
In a new declaration Cipriano signed in September 1999, he writes: "It was my understanding from Mr. Ingram and now Mr. Moxon that they wanted a fabricated story about Mr. Berry, and they were willing to do anything, including pay me, for it to get it. This was what they called fair game....As the months past [sic], I met with Mr. Moxon almost weekly and Mr. Ingram every couple months. Both of them repeated [sic] told me of their plans to destroy Mr. Berry."
Cipriano says Moxon and Ingram filled him in on the rest of their harassment campaign against Berry. In his September declaration, he reports that Ingram and Moxon told him that flyers calling Berry a child molester had been posted in his neighborhood; investigators had gone through Berry's trash looking for things "that might hurt him"; complaints about Berry had been sent to the California Bar Association; Berry was under 24-hour surveillance; operatives were posted at Berry's favorite restaurants and bars; physicians were solicited for information on Berry; friends, business associates, former clients, bank officials, and other attorneys were fed damning information about Berry to poison his relationships with them; and legal proceedings were filed to grind Berry "into the ground financially."
Meanwhile, Cipriano alleges that Moxon had a plan for improving his finances. Cipriano says Moxon gave him tours of an L. Ron Hubbard museum and took him by the Hollywood Celebrity Center. There, Cipriano says, Moxon offered him $750,000. "I said I did not want to be paid for my testimony," Cipriano states in the August declaration. Moxon denies that he made the offer. Cipriano says he mentioned to Moxon that he'd long had a dream of putting on a 24-hour worldwide charity concert to benefit children's groups, which he called "Day of the Child."
"Moxon told me, in plain words, that he would syndicate the monies needed with some of the wealthy Scientologists and get it funded," Cipriano writes in his declaration. Besides incorporating his "Day of the Child" company for him, Cipriano writes that Moxon also helped him out with his debts. And he attaches a document to show that a man named Geoffrey Barton lent Cipriano $2,500. Cipriano writes that Moxon arranged for the man to send the money so Cipriano could pay off obligations he owed his girlfriend. "Moxon statedthat we needed to sign a promissory note so that it did not look like Scientology was paying me while I was a witness."