For your information: This is the notorious Fishman affidavit. Numerous people all over the world were raided because the Church of Scientology claims copyright on parts of this document, and is willing to violate all rules of netiquette to keep it from being spread. Copy this document and put in your homepage, because it will help in letting people find out the truth on this dangerous cult masked as a religion. Thank you for your interest, Joris.

I want to emphasize that the CoS is probably not at all interested in whether the Affidavit is actually copyrighted The strategy of the CoS is probably just to intimidate Internetproviders into removing the documents its users have put on the Net. Unfortunately, this tactic is succeeding.

If you put the Fishman affidavit on your homepage, your internetprovider will probably get a written letter from the CoS legal representatives within a few days. This letter informs your provider that you are guilty of copyright infringement and demands removal of the Affidavit within four working days. So far, nobody has actually been sued; it is doubtful if this will ever be the case. The tactic of the CoS is not to defend, i.e. actually show that the Affidavit is copyrighted, but to attack, i.e. to intimidate people, to threaten them, and sometimes to actually sue them. Whether or not it actually wins the case is not important; the goal is to discourage other people from fighting against the CoS, because these people will probably be unable to get the money necessary to defend oneself against the CoS.

The intimidation strategy works. Many people are afraid of actually going to court against the CoS, because they know it will cost them a lot of money. Even if the Church of Scientology has false claims, it often gets away with them because nobody dares to deny them.

It is therefore more necessary than ever to spread the Affidavit, and to do so in large quantities. We can stop the CoS from suing everybody by starting a guerilla warfare. Put it on your homepage; when threatened, remove it; spread it to other sites to the CoS keeps chasing us, needs to react to us, instead of us needing to react against them.

When you read the OT levels, you probably won't believe the things it says, like the ability to communicate with plants. L. Ron Hubbard has once said that people who see the OT levels before they are ready for it will die. The OT levels are guarded extremely carefully probably not because the CoS believes this, but because somebody who has not sufficiently been brainwashed will realize that the OT is just sillyness, and will realize the magic beans of Scientology don't work. This is why spreading this material is so important. It will convince people that Scientology is bunk, and will thus deplete the streams of customers. This is a more permanent measure than winning a lawsuit or something, because fewer customers means less money. Less money results in less power, and because the CoS is only able to fight other because of its wealth, ultimately in a demise of the Church of Scientology. There will remain other cults, as long as there are people who can be exploited as well as people with enough lack of scrupules to do so, but the most dangerous cult currently in existence will have gone.

And that's a goal worth fighting for, I think.

To learn more about the Church of Scientology, click here.

The affidavit begins now.

(court-stamped page numbers in (parenthesis))
(occassional  descriptions of drawings in ( brackets also))


STEVEN FISHMAN                             filed
Dismas House, Room 324            clerck US District Court
141 N.W. 1st Avenue                    APR - 9 1993
Dania, Florida 33004          central district of california


Defendent Pro Se

GRAHAM E. BERRY
JUDITH M> TISHKOFF
LEWIS, D'AMATO,BRISBOIS & BISGAARD
221 North Figueroa Street, Suite 1200
Los Angeles, California  90012

Attorneys for the Defendant,
UWE GEERTZ, Ph.D

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA


CHURCH OF SCIENTOLOGY          )  CASE NO. 91-6426 HLH (Tx)
INTERNATIONAL                  )
)  DECLARATION OF STEVEN A.
Plaintiff,              )  FISHMAN FILED IN SUPPORT OF
)  DEFENDANTS STEVEN FISHMAN AND
vs.                            )  UWE GEERTZ'S JOINT NOTICE OF
)  MOTION AND MOTIONS TO (1)
STEVEN FISHMAN and UWE GEERTZ, )  RECONSIDER THE COURT'S MARCH
_______________________________)  22, 1993 CHANGE OF VENUE ORDER;
AND (3) FOR EXCERCISE OF THE
COURT'S INHERENT EQUITABLE
POWERS CONNECTION WITH THE
COURT'S MARCH 22, 1993 CHANGE
OF VENUE.

Date:   May 3, 1993
Time:   10:00 a.m.
Place:  Courtroom 7

Discovery Cut-off: July 7,
1993
Pretrial Conf.:    August 6,
1993,
1:30 p.m.

Trial Date:        Sept., 1993

1




DECLARATION OF STEVEN FISHMAN

I, Steven Fishamn, declare as follows:

1. I have personal knowledge of the facts stated herein,
unless stated on information and belief, and if called upon
to testify to those facts I could and would competently
do so.

2. I am a Defendant in the case of Church of Scientology
v. Steven Fishman and Uwe W. Geertz. I am currently serving a
five year sentence for mail fraud and I am under the direct
custody of the Bureau of Prisons. I am currently housed in
Dismas House, a "half-way haouse" run by the Bureau of
Prisons, and under the direct supervision of the Community
Corrections Manager of the Southern District of Florida.
My release date from incarceratyion is June 28, 1993.

3. I am prohibited from leaving the Southern District
of Florida during my incarceration. After my period of
incarceration, I will be under the supervision of the
United States Parole Commission, from June 29, 1993 until
November 28, 1993, and I am prohibited from leaving the
Southern District of Florida. After my period of Parole,
I will be under the supervision of the United

-3-  (0017)




States Probation Office, from November 29, 1993 until
November 28, 1995, and I am prohibited from leaving the
Southern District of Florida, without permission of the
United States Probation Office or as ordered by the Court.

4.   Due to the period  of  incarceration,  parole  and
supervised release, it is very difficult  if  not  impossible
for me to conduct discovery and/or prepare  for  trial  which
is tentatively scheduled to occur in the  summer  of  1993.
The  trial  is  scheduled  to  take  place  in  the  Central
istrict of California.

5.   This  very  Court  in  this  very  action   declared
me indigent  -pursuant  to  a Motion  to  Proceed  in  Forma
Pauperis signed by the honorable Judge Harry L. Hupp  on  May
28, 1992.

6.   My  financial  condition  is  still   indigent.   I
am employed as a receptionist and data entry  clerk  at  the
wage of $ 5.00 per  hour.  My  gross  pay  is  $  200.00  per
week, as  I  work  a  forty  hour  week.  My  net  pay  after
deductions  is  $  164.00  per  week.   Out of  that  check  I
pay $ 50.00 In subsistence  payments  to  the  Dismas  House,
and I make child support payments of $ 41.00 per week to  my
ex-wife, Jaime Lee Nureyev, in order to help  support  my  two
minor  children.   I  further  make  a  monthly  non-committed
fine payment of $ 25.00 to the Debt Collection  Unit  of  the

4   (0018)



Northern District of  California  and  I  contribute  $  20.00
per week to the support of My father, Jack Fishman, who  is
also  destitute  and  has  been adjudicated bankrupt   by   the
Southern District of  Florida,  and  is  living  only  on  his
social security chock.  I wish the Court  to  know  that  I  am
indigent and destitute and besides not being  able  to  afford
the cost of bringing witnesses to testify  at  trial  in  the
Central District  of  Cdlifornia  I  cannot  afford  even  a
plane ticket or money for a hotel  room  to  come  out  there
for the trial myself.

7.   I cannot afford nor have I been able to  afford  to
conduct discovery in  this  case,  nor  to  issue  subpoenas,
hire court  reporters  etc.,  in  the  Central  District  of
California,  a  jurisdiction  which  is  convenient  for  the
Plaintiff but not for myself as a Defendant in this case.

8.   Although  my  ability  to  conduct   discovery   in
either  jurisdiction  is  impossible  due  to  my   financial
circumstances I ask the Court  to  recognize  my  right  to
attend  My  own  trial  as  the  Defendant,  which  would  be
impossible  in  California  unless  my  traveling  and  hotel
expenses were paid for by the Plaintiff or  my  co-Defendant,
and I do not wish to be a burden  upon  either  of  them.  If
the  case  were  transferred  to  the  Southern  District  of
Florida under 28 U.S.C. 1404(m), I would be  able  to  attend
my trial as the Defendant in this case since no  travel  or

5    (0019)


hotel expenses are involved.

90   1 do not  expect  my  financial  situation  to  change
in the foreseeable future.  I  also  still  personally  owe  in
excess of $ 10,000  in  credit  card  debt,  some  of  which  I
used to purchase books  and  tapes  from  bridge  Publications
Inc., the publishing  house  of  the  Church  of  Scientology,
while I was still brainwashed and under  the  mind  control  of
the Scientology cult.

10. I have been  ordered  by  Counselor  Roxana  Boyco  and
Director  Tammy  Jodway  of  Dismas  House,  as  well  as   Mr.
Conrad Lopez of the Bureau of  Prisons  to  begin  My  required
Mental Health  Aftercare  at  the  Henderson  Clinic  South,  a
psychiatric  out-patient   treatment   center   in   Hollywood,
Florida.    My treatment begins  on  March  9,  1993,  and  may
require psychotropic medication,  according to  Ruth  Watkins
at  the  clinic.     I may  not  be  reemitted  by  my  treating
psychiatrist to discontinue  treatment  during  the  period  of
time required for  my  trial  appearance  in  California,  even
if the Court were to order  the  Bureau  of  Prisons  to  allow
me to appear in California, and even if any  expenses  were  to
be Paid for  by  either  the  Plaintiff  or  Defendant  Geertz,
which is not likely-or customary.
I  will  need  to  call  Margery  Wakefield   as   a
witness.  Margery Wakefield is a  Florida  resident.  As  an

6     (0020)



ex-member of Scientology, and As a victim of abuse while a
member of the cult, she will be called upon to testify as
-to the illegal and criminal practices Of the Church of
scientology, as well as information regarding the church's
-policies on suicides, murder and the Church policy known
as "changing history". I cannot afford to bring Margery

Wakefield as a witness to California. Margery wakefield
told me that she is also indigent and destitute but has
Indicated that she would appear as a witness if the case
,were brought to trial in the Southern District of Florida.

She is a key witness in my defense.

12. Dr. Ron Johnson is a doctor of veterinary
medicine and a resident of Fort Lauderdale, Florida.
I wish to be able to call him to trial in order to testify
regarding my membership in the Church of Scientology in the
year 1981, a fact strongly disputed by the Church in their
attempt to cover up their involvement in the crimes for
which I am charged in the criminal case. I cannot afford
to bring this witness to California in order to testify.

13. Dr. Ron Neuhring is a psychologist from Miami,

Florida. He was my Fishman's treating psychologist when I
was first arrested at the Metropolitan Correctional Center,
a Federal prison facility. Dr. Neuhring will be called to
testify regarding my mental state at the time of my arrest,
as well as statements which I made to him regarding my

7        (0021)

involvement with the Church of Scientology.  I cannot
afford to bring this witness to California in order to
testify.
14. Special Agent Angelo Troncoso of the Internal
Revenue Service 'is a resident of the Tampa, Florida area.
I will call him to testify to his knowledge of the criminal
investigation being conducted by the internal Revenue
Service into the Church of Scientology, and to the extent
of knowledge and details supplied to him by myself,
establishing to the Court his understanding of my
familiarity with upper-level Church management decisions
and business. I cannot afford to bring this witness to
California in order to testify.
15. Special Agent Terry R. Kroggel is a Certified
public Accountant with the Internal Revenue Service and a
resident of the St. Petersburg, Florida area. I will call
him to testify to my knowledge of the civil investigation
being conducted by the Internal Revenue Service into the
Church of Scientology, and to the extent of familiarity
with details supplied to him by myself, establishing my the
his understanding of my knowledge of upper-level Church
management decisions and business.  I cannot afford to
bring this witness to California in order to testify.

16. Detective Dennis Angelo is an investigator with

8       (0022)



the Clearwater Police Department, and is a resident of the
Clearwater, Florida area.  I will call him to testify to
his Knowledge of the civil investigation being conducted by
the Clearwater Police Department into the Church of
Scientology, and to the extent of familiarity with details
supplied to him by myself, establishing my knowledge of
upper-level Church management decisions and business.
I cannot afford to bring this witness to California in
order to testify.

17. Dr. Enyin Aksu is a psychiatrist who is a
resident of Broward County Florida.  Dr. Aksu was
my treating physician at the time when I was, an in-patient
at the Hollywood pavilion  psychiatric facility in
Hollywood, Florida, from February 13, 1989 until march 20,
1989.  Dr. Aksu will be called to testify regarding my
mental state at the time of my involuntary commitment in
the mental hospital, as well as statements made to him by
myself Fishman regarding my involvement with this Church of
Scientology.  I cannot afford to bring this witness to
California in order to testify.

18. I will also need to call certain hostile
witnesses  who are staff members of the Church of
Scientology,  including but not limited to Mr. Frank
Thompson, Mr. Ray Jourdain, Mr. Humberto Fontana, Ms.
Beverly Flahan, Mr. Luis Gonzales, Mr. Charles Fox, Mr.

9      (0023)




Mark Witt, Mr. Michael Hambrick, Mr. Peter Letterese, Mrs.
Barbara Fawcett Letterese, Ms. Denise Franklin Monco Mancha
Ms. Fran Hardy Andrews, Ms. Barbara Koster, Ms,. Leona
Littler Grimm, Ms. Celia Alvarez, Mr. Tom Staley, Ma. Karen
Staley, Ms, Shirley Hambrick, Ms. Leah Abady, Ms. Colette
Atzel, Mr. Jamie Gurlaccio, Mr. Bob Levy, Mr. Doug Carr,
Mr. Roberto Naya, Ms. Nancy Witkowski, Mr. Paul Dibble, Ms.
Linda Miller, Ms. Vicki Kirkland, Mr. Roggie Monce, and
others who are residents of either Dade or Broward County,
Florida. These witnesses will be called upon to testify
regarding the physical abuse and hypnosis performed upon
myself, AS well as Church policies regarding these
practices. Some will be asked to testify regarding the
Church policy regarding suicide and murder, as well as
specific orders directing me to assassinate Dr. Geertz and
to have me Defendant commit suicide under the auspices of
an "End of Cycle" order. others will be asked to testify
regarding the Church's involvement and direction in
ordering me to commit securities class action fraud in a
Church operation known an Operation Acting Classes, for
which I was arrested and plead guilty in an Alford Plea (of
Innocent but responsible for the acts alleged), and other
criminal acts which I was directed to commit on behalf of
the cult, including the Ethics Bait Project and Bingoing.
I cannot afford to bring any of these or other similarly
situated witnesses to California for the trial, as they are
nearly all residents of the Southern District of Florida,

10      (0024)




with the exception of Denise Franklin Monce Macha, who may
be residing in Clearwater, Florida to the best of my
recollection.
19. I will also need to call Mrs. Dorli Geertz to
testify  Regarding  psychological tests which  she
administered on me over the Years between 1979-1990 which
will establish my deteriorating state of mind during the
time I was a devotee to and member of the Scientology cult.
I cannot afford to bring this witness to California in
order to testify.

20. Dr. Daniel M. Lipshutz. M.D. is a resident of
Singer Island, Florida, and is my uncle. He is a retired
psychiatrist formerly licensed to practice psychiatry in
New York. He has been familiar with my psychiatric history
during my entire lifetime arid will be called to testify
about how the Scientology cult had adversely affected my
thinking, belief system and my mental condition. I cannot
afford to bring this witness to California in order to
testify.

21. Mr. Samuel J. Kern, is a resident of Plantation,
Florida, and is also my uncle.  He is a retired trial
attorney from Brooklyn New York, and although cannot
represent me an counsel in this case because he is not
admitted to the bar in Florida, he will assist me and act

11        (0025)



as my personal representative if the trial were conducted
in Florida. I cannot afford to bring my uncle to
California in order for him to assist me in the preparation
of my defense as my personal representative.

22. Consequently, and in the interest of justice,
I plead with the Court to transfer the venue to the
Southern District of Florida pursuant to 29 U.S.C. 1404(a).


I declare under penalty of perjury under the laws of
the State of Florida that the above is true and correct to
the best of my recollection and understanding.

Executed March 1, 1993 at Dania, Florida.


(signed steven fishman)
Dated: march 1 1993   Defendant
Pro Se
Register Number 17280-004
Dismas House
Room 324
141 N. W. 1st Avenue
Dania, Florida 33004

12                       (0026)



Exhibit A

(title page no number just Exhibit A)







PROOF OF SERVICE

STATE OF FLORIDA         )
)     ss.
COUNTY OF BROWARD )
)
____________________)


On march 1, 1993, 1 served the following documents
described as MOTION TO CHANGE  VENUE UNDER 28 U.S.C.

1404(a);  DECLARATION    OF STEVEN FISHMAN,  MOTION FOR

PROTECTIVE ORDER FOR COURT TO QUASH DEPOSITION OF CINDY L.

BUSCH, LAW REGISTRAR, PURSUANT TO F.R.C.P.26(4) (c) ;

DECLARATION OF STEVEN FISHMAN, and MOTION FOR PROTECTIVE

ORDER FOR COURT TO DESIGNATE TIME OF DEPOSITION

OF DEFENDANT FISHMAN PURSUANT TO F.R.C.P. 26 (4) (c) ;

DECLARATION OF STEVEN FISHMAN on the following parties in

this action byplacing a true copy thereof in  sealed

envelope and forwarding them to the parties as follows and

in the following manner:


By First Class Mail:  Timothy Bowles or Robert A. Wiener
Bowles & Moxon
6255 Sunset Boulevard
suite 1 2000
Hollywoode California 90028

By Federal Express:  Judith Tishkoff or Graham Berry
Lewis;iD'Amatot brisbois
sgaard
221 North Figueroa Street
Suite 1 1200
Los Angeles, California 90012

Dated; March 1, 1993


(signed Steven Fishman)
STEVEN FISHMAN, Defendant
Pro Se
Dismas House, Room 324
141 N. W. 1st Avenue
Dania, Florida 33004

(0027)







Exhibit B


(title page -no number just 'exhibit B'





nia.         Dismas House, Room 324
141 N. W. 1st Avenue
Dania, Florida 33004

(0027)







Exhibit B


(title page -no number just 'exhibit B'





ON CONTROL AND LYING
____________________


THE ONLY WAY YOU CAN CONTROL PEOPLE IS TO LIE TO THEM.  You can
write that down in your book in great big letters. The only way you
can control anybody is to lie to them. When you find an individual
is lying to you, you know that the individual is trying to control
you. One way or another this individual is trying to control
you. That is the mechanism of control. This individual is lying to
you because he is trying to control you - because if they give you
enough misinformation they will pull you down the tone scale so that
they can control you.  Conversely, if you see an impulse on the part
of a human being to control you, you know very well that that human
being is lying to you. Not "is going to", but "is" lying to you.

[last sentence is underlined in original]

Check these facts, you will find they are always true. That person
who is trying to control you is lying to you. He's got to tell you
lies in order to continue control, because the second you start
telling anybody close to the truth, you start releasing him and
he gets tougher and tougher to control. So, you cant control
somebody without telling them a bunch of lies. You will find that
very often Command has this as its greatest weakness. It will try to
control instead of leading. The next thing you know, it is lying to
the [illegible]. Lie, lie, lie, and it gets worse and worse, and all
of a sudden the thing blows up. Well, religion has done this.
[Following sentence is underlined] Organised religion
tries to control, so therefore must be lying. [end underline]
After a while it figures out (even itself) that it is lying, and then
it starts down tone scale further and further, and all of a sudden
people get down along this spring-like bottom (heresy) and say,
"Are we going into apathy and die, or are we going to revolt?"
and they revolt, because you can only lie to people so long.
Unfortunately there is always a new cycle of lying.

L. Ron Hubbard
Technique 88

(0029)


Letter of Authenticiyy





Exhibit C

(no number just title page  exhibit C)





26 January 1982

WITNESS PREPARATION:HATTING THE WITNESS

Preparation of an individual witness to give evidence for us at trial
can be broken into three steps:

1. The basic witness hat, which is unvarying from one witness to the
next;

2. Full debriefing and resulting understanding of prospective testimony;,
and

3. Finalization of the testimony with the lawyer.

Steps 1 and 2 would be handled by the GO terminal assisting the
lawyer for that portion of the case, and step 3 would be done by the GO
terminal and the lawyer.

There is basic data about being a witness which should be given to
every witness, to give them reality on what It will be like, answer their
questions. etc. Following are the areas which we would cover (for the
IRS case) as basic witness hatting.

1. It is helpful to describe to the person the physical space 'of the
courtroom (and, If possible, to have the person visit the actual
courtroom where he will be giving his evidence).  Tell (or show) the
witness where he will sit; where the judge, the clerk, and the reporter
each sit; and what roles they play. , Tell (or show) him where counsel and
where the audience will be seated. The witness may want to do a little
reach and withdraw on the space of the courtroom, and this can usually be
accomplished during a recess. The witness should be encouraged to 'take
control of the courtroom.

-1-        (0031)


2. The statistic for a witness Is something like 'length of time on the
Stand' (keeping In mind the purpose of each witness to deliver certain
evidence comfortably, persuasively and honestly so the judge can
duplicate and agree with it).  A witness will always experience
discomfort. anxiety, etc., and will have (at first) a strong desire to
get It over with."  The danger here Is that his/her testimony will
become condensed or abbreviated to as to get off the stand as quickly as
possible. The witness should be warned against this phenomenon. We want
a witness to understand that (under ordinary circumstances) they will
have done better to stay on a long time, and they should get their TRO In
and be there comfortably for as long as It takes.  After a time, they
Invariably loosen up and actually begin to enjoy the experience such that
they become willing to stay on and on.

A witness who makes only a brief appearance leaves little or no
Impression on the judge. A trial judge or a juror must, as part of his
hat, determine what degree of credibility each witness possesses, and
accordingly what relative weight to give to that witness' evidence.   A
judge or juror does this by observation of the witness' demeanor as much
as by the testimony given.  A witness who is willing to be there, and
answer in as much detail as necessary (not chopping his evidence short
out of desire to "blow" from the stand), gives the judge or juror more
time to observe, and get to know that witness;. it is a matter of
increasing ARC between witness and Judqe or juror which results In the
judge retaining the data better and also according It more weight as he
will have sussed out that witness for believability.
3. The witness should know that he may be questioned by the judge
directly on some point of Interest or at a lull In the examination being
done by counsel. If that occurs, the witness should give his answer
directly to the judge, respectfully and with high ARC and attention to
fully and actually answering the question asked.

-2-            (0032)




Also there are times, though they Should be rare and sparsely used,
When the Witness may want to address himself to the judge, seeking his
advice or aid.  For example, If witness feels he simply cannot answer a
Cross-exam question both a yes or no, but must make an accompanying
explanation, he may ask the judge for leave to explain or qualify his
answer. 'This comm line can be used to good advantage In a situation
where the line of questioning Is probing an area of the witness'
religious belief (or where, perhaps, the questions are designed to
address or elicit upper level material): The witness can originate that
this question is improper as it seeks Information about his personal
religious belief Or data that he considers confidential as part of his
beliefs, and that he has taken a perpetual vow never to disclose.

Address to the judge Is not to be over-used or relied on by the
witness to any advantage, but the witness should know that he can have a
comm line to the judge, to appeal for protection.

4. Related to point 2 above, a witness should also be told that his
testimony should be calm and reasonable.  Although it Is part of his
purpose to persuade the judge, this is done by creating credibility, not
by acting as an advocate. Advocacy is the lawyers job, and the
representations of a lawyer are not evidence; the statements of a witness
under oath are. Emotional reactions by the witness, argument with a
cross-examining attorney, or attempts to "handle" an  antagonistic
cross-exam by tone scale handling are not OK.  A PR-trained witness may
get Into handing his Interrogator, Instinctively, and this is to be
warned against. One of the judge's chief tools for according weight or
credibility to a witness and his testimony is the presence or absence of
bias: an argumentative witness, or one-who tries to persuade, is seen as
biased, and his testimony is given less weight. . The judge's thinking Is
along the line that this witness has something at stake (money, status,
his job, having to be right, etc.), and would thus be willing to say
almost anything in defense of his position.  Credibility comes about by
being honest, willing to answer/explain, and natural.  (The  useful

-3-        (0033)




exception to this is "righteous Indignation' of a witness questioned

about his personal beliefs, as discussed above).

5. The prospective witness rust be instructed on the actual comm cycle
of giving testimony. If the person is our witness, then direct exam will
be conducted by our lawyer, followed by cross-exam done by the opposition
lawyer. Then comes a redirect exam, done again by our lawyer (followed
possibly by a short recross-exam).

During direct exam our witness will be asked the questions which have
more or less been prepared In advance by ourselves (the witness, the GO
terminal responsible, and the lawyer).  None of these questions should
come as a surprise, though they may be taken up in relatively random
order. In response to these questions, we are usually looking for
relatively detailed answers, with specific points to be made.   These
answers may be fairly lengthy, depending on what the court will allow.
Some judges may allow 'narrative' type answers, where others may demand
that the questioning attorney stick to a strict question-and-answer
format.

6.. During cross-examination (conducted by the opposition lawyer, for the
purpose of unmocking the credibility and consistency of the witness), the
witness should NEVER VOLUNTEER ANTHING. The exact question asked should
be answered, no more, no less.  Q: "When did you read that policy
letter? A: "On the 16th May as best I can recall." NOT A: "I recall
It was the 16th May as I had just returned that morning from a mission."
(The latter would give the lawyer a string to pull--what mission?
Where? Why? Etc.)

Part of answering only the exact question asked Is bearing and
responding to only the words used; the tone level of the question is to
be Ignored. Most cross-exam Is conducted at the tone of covert
hostility, and this Is to be taken into consideration.  A clever
cross-examiner can make any statement sound suspicious and any question

-4-      (0034)





sound accusatory; but our witness, expecting this and listening only to
the words and not the tone, will not take the bait.

A cross-examination proceeds by the opposing attorney  asking
questions designed to (1) expose known or recognized out-points In the
direct testimony of our witness, and (2) lead our witness to volunteer
other data which will become a  'string'  to be pulled.  A good
cross-examiner will pull each and every string In the hope that he will
find the Sherman tank which destroys that witness' credibility.   A good
witness who can answer the questions exactly without volunteering data
or being drawn into argument or acting evasive, will emerge unscathed.
The cross-examining attorney may simply give up after a few failed lines
of questioning.  But the witness must be willing to sit it out
comfortably: we have seen witnesses who gave one day of direct testimony
and then had to sit through four or five days of cross-exam (and they
came out of it quite keyed out and ready to go on for as long as it
took:) but this is the exception and not the rule.

7. By sticking to short, directly responsive answers (basically:   yes,
no, I don't know, I don't remember), the witness will Invariably find
that some of these answers felt incomplete, or sounded unfavorable: they
would like to have explained the answer a bit,, remedying the sense of
" omitted" data with "all related facts known." But cross-exam is not the
time to correct our own outpoints: this is handled on redirect exam. Our
lawyer will have listened carefully to all the cross-exam testimony, and
noted down the points which sounded Incomplete or unfavorable.    These
will each be cleaned up or rehabbed on redirect, so that any negative
effect Is minimized.  Also there Is often a short recess between
cross-exam and redirect exam, so the witness can tell the lawyer any
points which he feels should be cleaned up. Knowing this in advance, the
witness can be willing to have his needle "dirtied" on cross-exam and
"cleaned" on re-direct.
-5-     (0035)



8. When a question is asked of the witness, he should see if there is an
objection forthcoming from the opposite attorney.  This Is especially
true during cross-examination where our attorney will be trying to
protect our witness from Improper lines of questioning.  This does not
mean that the witness pauses and looks at our attorney.. An obvious comm
lag can look like the witness has to "think up an answer" and this hurts
his credibility.
If there Is an objection made, It occurs by the attorney standing up
and stating: "Objection--that question Is Improper because of blah blah
blah." There may be argument back and forth on this by the attorneys for
both sides, then the judge will rule.  The objection will either be
sustained by the court (i.e., the judge agrees that the question is
improper, and the witness Is to ignore the question) or overruled (i.e.,
the objection does not stand, and the witness must now answer.)
If the witness is not paying attention, and simply hurriedly answers
the question, he has cut off our lawyer from making any meaningful
objection. If the witness answers the question while an objection is
being interposed, the court reporter may ignore the objection and record
the answer given by the witness or the judge may say, "Well, the answer's
in. Neither of these situations is optimum, so the witness should see
If there are objections. If the witness sees the attorney start to rise,
he should shut up; otherwise, he should continue measured comm.
9. A small point, perhaps, but the witness should be told that he cannot
expect to be acknowledged while giving testimony.  The comm cycle is
question-answer, next question-next answer, etc. There Is no ack in this
comm cycle, and in fact this is sometimes used as a tool by the
cross-examiner. He may ask a question, then turn and walk away from the
witness, seemingly ignoring him even after completion of his answer. An
uninformed witness might feel uncomfortable, unacknowledged, and feel
compelled to answer further, to fill the silence, to ltsa.  That Is what
the cross-examiner wants. for the witness to run on and on, volunteering
-6-     (0036)



data, giving up strings to pull, and. looking uneasy to the judge.   So
watch out for this phenomenon too.

20. The witness is sworn to tell the truth, And he must, of course, do
no. The scope of his testimony and the patter for certain areas will be
worked out with counsel, so that there can be minimum risk to our case
and to the witness In sensitive areas.  If a witness Is privy to "too
much" sensitive or possibly unfavorable data, he may well have been
eliminated from our witness list early on.
Perjury, i.e., lying under oath, is a crime (and, as we know, Is usually
self destructive for the individual); we want our witnesses to tell the
truth.
Impeachment is a term which just means that this witness is, in the
judge's eyes, unworthy of belief (due to his demeanor, numerous or major
Inconsistencies in the testimony, or bias).  Both these terms (perjury
and impeachment) should be gone over with our witnesses so it is no
mystery or MU if they come up in court. We had one witness who, hearing
the opposition announce that they would try to impeach her, clammed up on
the stand, thinking she would be taken off to jail.  (During a recess we
cleaned up the MU and she then did fine.)
11. Our witness should be Informed that it Is OK that they have talked
with the lawyer (and hit assistants--the GO staff) prior to testifyi ng.
No lawyer would ever put on a witness he had not worked with, and for a
witness to deny this destroys his credibility immediately.   It Is a
Common tactic for the cross-examining lawyer to ask the witness if he had
discussed his testimony with the Church's lawyer; If our witness doesn't
know about this, he will either manifest a "missed withhold of nothing"
(and be enturbulated in his testimony), or worse yet, lie about it (thus
losing all credibility before the judge).
-7-      (0037)



12. The witness should not look at the lawyer for our side or the GO
terminal or the audience when being cross-examined.  He should look at
the cross-examiner, unless our attorney takes an objection.   If the
witness looks continuously at our lawyer, the judge or juror will think
that the witness is seeking guidance from the lawyer and this affects
credibility.  This Is not OK.  Rather, the witness should be natural,
looking at the person originating the comm.

If the above points 1-12 are gone over with each of your witnesses at
the outset, they will be much more comfortable, cooperative and
successful. They need to know what to expect if they are to help.
Answer all their questions, as best you can; some questions the lawyer
may have to answer (e.g., If the particular witness needs independent
advice about claiming a 5th Amendment,, attorney/client, priest/penitent
or other privilege). These points have been taken from notes of witness
hatting sessions done with the trial lawyers for the IRS case; they
should be useful In the circumstances of most US trial work.

That's it.

(0038)





Exhibit D

(Title page no number)




(rubber stamped)
CONFIDENTIAL ATTORNEY CLIENT
Privledged Materials


27.January 1982

Addendum to Hat Writeups re (1) Hatting the Witness and (2) Preparing the
Witness

HATTING


A few additional points should be included in the description of how to
hat a person on what it is to be a witness in a Scientology case. These
are:

1. The witness must have a good feel for what particles, comm lines,
command lines, writings, activities etc., in a Scientology org are
"ecclesiastical" and those that are "secular/corporate/legal." In this
regard, the potential witness should definitely read Bob Harris' short
exposition on the area called "Understanding Corporate Integrity II" and
any disagreements or questions should be handled right away. He must
have a flexible understanding of what things are corporate/legal matters
and what are not. This is an area that will have to be gone over very
carefully in preparing any witness for cross-exam, for it is a very
fertile area for such. The witness must understand the hierarchical
nature of the Church of Scientology and the nature of the relationships
among Scientology terminals and organizations. You might want to show
him a chart to help tin understand the area. Such a chart was put into
evidence in the 70-72 case (but may not be of use to everyone as It
.depicts relationships only during that period. Watch out, however, as
-the witness' understanding and ability to answer questions about this
Area must still and always be realistic, practical, and from the reality
and point of view of that individual: In other words, a person who was
the Mimeo operator at the Hawaii org for six year s will have a general
understanding that comes from being a staff member and a Scientologist,
but his 'personal knowledge' and experience will be vastly different from
that of a person who held high exec positions (e.g., Commodore's Staff
-Aides or WW terminals) . You don't want your witness to appear to have
(0040)




been "briefed," you want him to have his own understanding and personal
knowledge--OR LACK OF IT. You Just want to be sure that he either is
Perfectly equipped to handle this area, by virtue of intelligence,
training, nature of posts and experience and duplication of the concepts
Involved. or you want him to really recognize his limitations In the area
so he cannot be led Into testifying about It. (This approach Is really a
general rule for all witnesses--It Is patently incredible for a comm
runner to tell the court about management activities at Flag, or the
compensation of the Founder, e.g.)
2. The witness, while testifying, should always refer to any particle by
Its exhibit number: whenever he talks about a tangible particle In front
of him, it's not "this" or 'that,' It's always "Exhibit AB," or "the
document marked Exhibit 236," etc. Otherwise the transcript of the
testimony cannot be understood when read. The transcript, together with
the exhibits themselves, are the complete RECORD of the case. It Is what
we will have to refer to in part If we are to appeal any case. Without
an intelligible record, we cannot prove our case. So this particular bit
of admin (marking documents as exhibits by letter or number) was
developed to ensure a readable record. The witness should know this so
that he can be careful to refer to everything by name or number.
3. Another aspect of understanding the comm cycle of the courtroom and
particularly the comm cycle of cross-exam is something I call the
"alter-ack." I have seen the cross-examining IRS attorney use this
technique continually. He will ask the witness a question, and then
appear to not understand the answer given; he will ask further clarifying
questions. still seeming to get It all wrong (when he probably
understands full well what he Is shooting for with that particular
witness). This is of course, very frustrating to the witness: he is
not only not receiving any verbal ack from the lawyer, he is also not
being duplicated at all. There is an eagerness on the part of anyone in
a comm cycle to achieve duplication, and the witness may want to clarify
,the matter. But watch out. The lawyer, after a series of questions that
(0041)



make it seem he simply didn't get it, he will say something Iike, "OK,
let me understand this--you said Blah Blah Blah"; he will almost restate
the witness' words back to him. The witness will then leap to say "Yes!"
and get the relief of having been duplicated. Usually, though, the
lawyer will have restated the testimony with some sort of cunning
alteration in It, some hook in it that is not what the witness would have
said had he really thought about It. but if the witness has agreed, then
there it is on the record. There was an example of this In the IRS 70-72
case where a witness was being asked a series of dumb questions off of an
ASHO ethics order, and the cross-examining attorney was getting it all
mixed up, finally restating part of the witness' words and stretching It
to the conclusion that "ASHO Is a subsidiary of the Sea Org"--to which
our witness said "yes!" Well that is simply untrue, and is even
preposterous to anyone who knows the facts (that ASHO was part of the
corporation CSC, that the SO has never been a corporate entity, and that
there is NO legal relationship between the two--and the term "subsidiary"
is wholly a legal term). The witness was dying for an ack and some
duplication from the lawyer; what he got was a false duplication ("Oh, I
see: ASHO is a subsidiary of the SO") and what we got was a false and/or
damaging statement on the record by someone who had no real knowledge of
the facts of that area.

4. Generalities vs. specifics. 'Scientologists usually try to avoid
dealing in generalities, but there are such things as good generalities.
Entheta and suppressive statements from the cross-examining attorney will
often take the form of generalities.
When confronted by the opposition lawyer by generalities, our witness
should ask for specifics. That will often totally cut the lawyer's line
of cross-exam (as he Is proceeding by generalities and cannot have or use
the specifics). On the other hand, our witness should look for
opportunities to use theta generalities; since It's theta, the
cross-examiner will not ask for specifics--he's stung and he'll want to
Set away from that area. If he does ask for specifics, the witness
should supply them, and chances are It will end up hurting the
(0042)




opposition. Examples: "Every Scientologist knows it would be violative
of the creeds and codes to lie about or falsify recorfd," or "Scientology
has helped thousands of people to better lives," or "We all know, or any
Scientologist who has read and understood the writings of our religion
would surely know, that it is a religion and it deals with the Spirit of
Man," or "We all know that the aim of Scientology is a civilization
without war, crime, Insanity . . . . " An entheta cross-examiner will
steer away from that stuff like a vampire from a cross. Just let him
have it--with theta!!
5. A witness is to testify to things he knows of his personal knowledge
only (except when he's launching a theta generality). He can only
testify to what he did or saw; he cannot say what another told him he saw
or did. This aspect is very useful to our witnesses on cross-exam: when
being questioned about a difficult area, the witness should ask himself,
-How do I know that? Did I see It or do It?" and he won't let himself be
led into an area where he Is not prepared, or isn't competent to testify
or is speculating or making conclusions. Speculation and conclusion are
not usually admissible testimony, but a clever cross-examiner can lead
the witness off into an area where he assumes what the "right" answer is,
but doesn't really have personal knowledge. Example: Q--"What would you
do If LRH ordered you to sell the ship?" The correct answer (if your
-witness never received such an order)-would NOT be: A-'Well,, gosh. I
guess I'd sell the ship..."; the proper answer would be: A--"That never
happened." Period. That answer will alert the judge that the question was
improper, a request for speculation on the part of the witness..
6. Along the line of answering the exact question asked, and not
getting outside of personal knowledge, the witness should keep in mind on
cross-exam this tip: BE LITERAL. If the attorney doesn't know enough to
ask the right question, he won't get the answer he's after. Don't help
the poor, blundering soul. Sit back and answer the questions literally.
7. It Is favorite trick of government lawyers (at least It sure was
In the IRS 70-72 case) to try and Impeach a Scientology witness on the
text of PLs. One can only be Impeached by being led to testify contrary
to what one has previously written or said. One cannot be Impeached (or
shown to be Inconsistent and therefore not cre dible) by being shown a PL
(0043)



which says something different from what one has testified to (unless, of
course, the witness Is the author of the PL and cannot explain
satisfactorily the circumstances and Intent of the Issue). The natural
reaction of most staff members Is to adjust or modify what he has said so
that It does conform to policy letters; as a good Scientologist or staff
member he doesn't want to be accused of disagreement with or
noncompliance to PLs. But the courtroom Is different; no one Is going to
get into trouble for saying they didn't follow a particular PL. The
,witness Is better off sticking to his own reality and previous statement
than by back-pedalling and modifying his testimony to make it "agree"
with a PL he Is confronted with. Don't be intimidated by this tactic! A
PL says what it says, and the witness In not responsible for those words,
nor for whether or not he applied that particular PL. That may sound
heretical at first, but unless the witness understands it and is flexible
enough to be "in court" and not "on post" or before an ethics
Investigation, he can be led Into very uncomfortable situations (and into
making statements that could hurt the Church's case).

B. In summary, the above points to teach a witness regarding
cross-exam are these:
Specifics vs. Generalities
Personal Knowledge
Be Literal
Ecclesiastical vs. Corporate/Legal
Don't Fear "lmpeachment" From PLs
9. The witness will also need to have a thorough understanding
(once again, commensurate with his post, training and experience, and
Intelligence) of the religious nature of Scientology and how this is
evident in many interrelated things.
For example, we all know that the Tech Volumes are clearly religious
In content; but what about the OEC? It contains Issues on how to run an
organization, how to get orders Issued and complied with how to write an
(0044)



Invoice and keep financial records. What's religious about that? well,
take a look at It. We have a 1st dynamic tech In auditing; we also have
a 3rd dynamic tech of dealing with groups/organizations. On the grade
chart there Is also (up the center) an Awareness Scale with awareness
characteristics In an ascending gradient. Those same awareness
characteristics appear on the org board, assigned to each of the 21
departments. Those 7 divisions of the org board are the 7 volumes of the
OEC. What is the org board? It's not a chart of any specific org; it's
a description of relationships and a way of handling life. An org may
operate off an org board, but it's equally applicable to any size group,
ox even to any individual. It's a philosophic machine, not a chart of
some commercial company. It Is based quite exactly on Scientology
doctrinal concepts. The OEC contains ethics PLs. Are they religious?
Certainly. They deal with doctrinal concepts about the being and how to
handle him. Even something as mundane and "secular" as writing an
invoice can be traced to a basic Scientology concept that "Truth Is the
exact time, place, form and event." If one cared to undertake the
project, the entirety of LRH policy could be traced to basic concepts of
communication, ethics, etc., and into the Axioms and Factors. The key
here is that to almost any Scientologist who stops to think about It, the
concepts underlying the org board and the OEC are part of our religion.
to an outsider they may seem "secular," but they carry a different and
deeper meaning for the Scientologist if for no other reason than they are
written by LRH, the Founder.

Understanding this, the witness cannot be caught off guard or put in
an uncomfortable position regarding PLs, org boards, etc. Be can know
they are religious in nature and can believe that to be true. It's
really part of his belief, it can't be questioned beyond that by a civil
court.

10. You will have seen from the points listed in this writeup and
the others about hatting and preparing witnesses that what it comes down
to Is that EVERY SCIENTOLOGY WITNESS CAN AND WILL BE ASKED ANY AND ALL
(0045)




KINDS OF QUESTIONS ON CROSS-EXAM. Don't think that a witness who was
only called to Identify a piece of paper from a file can't and won't (if
the judge is blind enough to allow this) be cross-examined on org boards,
ethics. nature of policy, hierarchical and corporate relationships, etc.
To the opposing attorney, all Scientology witnesses are "Fair Game" for
all entheta cross-exam. So ALL SCIENTOLOGY WITNESSES HAVE TO BE READY TO
HANDLE VIRTUALLY EVERYTHING, regardless of the scope of direct exam.
Prepare them accordingly and they will do well and we will win; leave
them unprepared in any of these areas an they will get caught in
something they can't control. Few Scientology witnesses are naturals at
this; some only take a little work, some take days and days. There is no
substitute for going over direct and expected or-even unexpected
cross-exam with the witness and the lawyer until it Is perfect.
The way we handled witness prep was to work up an outline of the
points to be covered in direct exam (as described In another hat
writeup). We would use this in prepping the witness, and the lawyer
would use it in court (the lawyer cannot work from a script, but he needs
the BC of an outline or list of areas to cover); the staff person working
with the lawyer will then also rely on this outline to ensure the direct
exam Is complete.
Since every Scientology witness must be prepared for cross on a
multitude of areas, we used a checklist as a tool for this. It was
rather like assessing a list with a PC. We had an overall list of areas
To cover. These are some examples:
Corporate vs ecclesiastical
Nature of Policy
Is DEC Religious?
Relationship of Flag to S0
What was 0TC?
Ever asked to backdate a document?
Flag's relationship to CSC
Fair Game

(0046)





We would run down that list with each witness asking a question or
two about the item to see how the witness would handle; perhaps he knew
nothing about corporations or OTC or Flag. When we would hit a "hot"
area (where the witness appeared to have knowledge and could be
questioned but gave an unfavorable answer or otherwise showed he didn't
duplicate the implications of cross-exam In that area), we would take it
up at length, Practicing cross and hatting the witness on the concepts
(e.g. OEC as religious) until he was stable and confident. Once through
the entire list (this might take days), that witness was ready to testify
and only needed brushup on direct and cross on the day before going on
the stand.
The purpose Of going over direct and anticipated cross is not to
inculcate "Pat" answers or robotism, but to nurture understanding and the
ability to handle the cross-exam questions. It goes without saying that
you also have to have a lawyer who (1) Is very experienced at trial work,
And 2) has a very thorough working knowledge of Scientology. For an
experienced lawyer who doesn't really understand Scientology, It will be
unreal to him that every witness has to be able to defend himself in
every area. He will think that he can effectively use the "Rules" (of
Evidence) to prevent improper cross-exam. He could be in for a very
unpleasant surprise about that at trial. There is no other animal on the
face of the Earth like a Scientology trial and he'll have to know
It--or we get another Christo case.

That's It.

DD/GUS
(0047)



Affidavit of Steven Fishman Case # 91-6426 HLH (Tx) Continued


EXHIBIT E

(title page)




EYE'S ONLY

TOPSECRET                  Duke, Here is
plan discussed, love
Bryce




PROJECT QUAKER
(Refer to the persons concerned
as "the friends")


INFORMATION:
It may be deemed necessary for all the DC Staff who
could be pulled in for questioning 'to suddenly leave.
This must be done in such a way So that they never
can be accused of "fleeing prosecution".

MAJOR TARGET

To ensure that all those DC staff concerned are not
available for questioning by Scales yet cannot be
prosecuted for fleeing.

PRIMARY TARGETS

1. US B1 SEUS SEC is responsible for seeing that
this project gets speedily done. He is to work
closely with DC INFQ US and DG US on this project.

2. The purpose of this project is to protect the
Church from Scales actions.

3. D/NAT'L SEC is responsible for the overall
planning of those actions and their debugging as
necessary.

(0049)



VITAL TARGETS

1. To ensure that extremely tight security is
maintained on this project.

2. To ensure that it gets done speedily.

3. To ensure that each aaction is smoothly worked
out so that if evaluation is necessary it will be
done without a 'hitch' or mistake.

4. To get finances quickly for this project.

5. To get approval up lines on this project "super
fast" so that it can be got done really fast.

OPERATING TARGETS

1. Each person to whom this project pertains must
immediately get his/her passport. This must be done
withing security's framework, meaning the person doesn't
mention CofS on the passport. For occupation list
Researcher - Public Relations Consultant - etc. or
houswife for girls that are married. Production
target 2 weeks on this. As assigned.

2. US D1 SEUS SEC is to work up an ED or some such
official type proclamation entitled "Sabbatical Leaves."
This can be worked out with both D/NAT'L
SEC US B1 and DDG US. The above shall basically
state that about 10 GO personnel shall be chosen
for Sabbatical leaves. This shall start with the
Founding Church in Washington DC. This is being
done as an award for upstats who consistently
produce well, and as an experiment to see what an energetic
staff member will do on his own if given 3 to 6 months
to travel and study and use scn tech. The rules are
(0050)


the persons are to:
1) To observe coventry and to not communicate to a
fellow Scientist during this time
2) They are to spend at least some of this time in
"retreat" where they are to study their choice of
topics.
3) They may travel anywhere in the world to do this.
4) They are to produce at the end of this time a
product of use to Scn.
5) They may prepare ahead of time but must start from
scratch.
This project is called "Ten Talents"  after the
biblical tale. A quote should be gotten from the bible
and put into the ED.  US B1 SEUS SEC

3.  When the above Ed is completed, it should be sent
to all GO DC staff wherever needed. It should appear
real to those whom it does not affect.  US B1 SEUS SEC

4. US B1 SEUS SEC is to work out the comm the pertinent
persons are to give on this to thier relatives or fellow
staff. This should be done ahead of time A.S .A.P so
that when and if persons have "to go" it will not
cause any flaps or PTS situations. "All" should be
ready to leave at any time. US B1 SEC

5. US B1 SEC is to ensure that all concerned are
ready to leave at any time and that all personal cycles
finances, 2D, bills, are completely up to PT and
there are no PTPs or stops to immeduate departure.
US B1 SEUS SEC.

6. US B1 SEUS SEC is to see AG DC keeps all staff
actions written up to PT and that machinery exists,
to as best as possible, take over, for each person
(including the AG) if this action were needed to be
done. This should be worked out in liason with DDG US and
(0051)


DG US. US B1 SEUS SEC.

7) US B1 SEUS SEC is to immediately do up a confidential
CS-W for "set-aside" finances for this project. This is for
seven or eight people so the amount should be about
$10,000 for starters. Any help needed on this can come
from DDG US or DG US. These finances should be given
to AG DC to hold in case this actions is implimented.
US SEUS SEC B1

8) SEUS SEC B1 is to ensure that the "need to know"
is strictly followed on this project. No communicators
are to know. The Need to Know is limited to DG US;
DDG US; DG I US, DDG I US; US b1 NAT'L SEC, D/NAT'L
SEC US; any US DG's that must know are told by DG US;
and those DG staff that this concerns.

9) SEUS SEC US B1 is to set up an  "early warning" system
whereby he or DG US can be notified immediately with
any info needed to decide to put 'Failsafe' into action.
SEUS SEC US B1

10. A "safehouse" or "safehouse area" should be chosen
in an out of the way place, like a ski resort - Dude ranch -
farm - Canada - Mexico - etc., This "place" ahould be
investigated to ensure it can be used anytime of the
year by people just "showing up". This "safe
house" is for Sabbaticals to go til it is shown
one way or another that they must stay away or
come back. SEUS SEC US B1

11. A cover story as to why "they" all went there; without
the Church knowing it, must be worked out - as this
breaks Sabbatical rules. SEUS SEC US B1

12. Seven safe different places (or as many as needed)
must be worked out, where the Sabbaticals will go if
they must extend extend their leave. One for each person.
SEUS SEC US B1

(0052)




13. Secure comm lines, codes, etc., must be worked out
for this "safe house" are in  #10, and each different
plave in #12 above. This must be done before any Sabbaticals
are taken. SEUS SEC US B1

14. The entire DC Org should be alerted in some way
to this Sabbatical "cover story". And if needed to be
implimented the DC Org should be informed of this
"award for" those concerned. (The one, two - 10 Talent
analogy should be used). This is to take all the
mystery off the line and make it no surprise as well as
handling any testimony in court by any staff. SEUS SEC US B1

15. When all  of the above actions are worked out
to the DG I/DG US's satisfaction, a chock list, code
words, etc., are to be worked out so that if deemed
necessary the Sabbaticals will go off like clockwork.
SEUS SEC US B1

16. Upon completion of targets 1-15, D/NAT'L SEC is
to fly to DC on mission. His MO's will be the briefing
and any necessary drilling to be done to prepare the
"persons" for thier "Sabbaticals" if necessary to impliment.
MOs to be written by SEUS SEC US B1 and approved by DG I US
and DG US. SEUS SEC US B1.

---------------
(0053)        (written in bottom corner '#37 (illegible initials)
7/8/77)





Exhibit G    (Title page no number)


[THIS HAS BEEN TEMPORARILY REMOVED DUE TO UNCERTAINTY ON THE COPYRIGHT OF
THIS MATERIAL]

OT I
L.Ron Hubbard

There have been three different OT Its put out by Hubbard.  here
they all are.

Earliest OT T

1.  On an E-Meter, find the last 3,000 years of lifetimes.  Plot
out the entire 3,000 year chart as follows:

(a)  Find an overt lifetime.  Get the identity and the
approximate dates of birth and death.  Find the overt
and pull all the justifications to it.

(b)  Find the following motivator lifetime, and follow
procedure as above.  (Identity and dates.)

(c)  Find the postulate from each lifetime and the basic
postulate in each group of lifetimes.

(d)  Continue the first three steps until the entire 3,000
years is charted and the individuals kharma, i.e. (over
motivator sequence) becomes apparent.
-1-
(0060)





(e) In some cases additional benefit could be  obtained  by
locating the basic misunderstood which proceeded the
basic overt on this chain.

Second OT I

(a) Route I ... The entire 15 steps as listed  in  "Creation
of Human Ability".

(b) With an E-Meter, scan out entire present lifetime  to  a
floating needle.

(c)  Mock-up heat until body feels warm.

(d)  Postulating mass: With the use of the E-Meter and  the
command "I have Mass", create a reactive mind.  Put
sufficient significance on to,it to cause the T.A-  to
rise.  Then spot it until the T.A. falls and  the  mass
erases.  Run to an FIN.  Then mock it up again and erase
it each time to a floating needle.  This  procedure  is
repeated until the pre-OT is certain he can create  and
dissipate a reactive mind.

Third OT I

The current OT I is done outdoors and consists solely of one
-2-
(0061)





command run until cognition.



"Spot a person"




concludes OT I
-3-
(0062)


OT II




[THIS HAS BEEN TEMPORARILY REMOVED DUE TO UNCERTAINTY ON THE COPYRIGHT OF
THIS MATERIAL]

OPERATING THETAN



Section Three

[THIS HAS BEEN TEMPORARILY REMOVED DUE TO UNCERTAINTY ON THE COPYRIGHT OF
THIS MATERIAL]

Exterior - OT IV


List of Volcanos

There were two zones of assembly after the thetan was
implanted.  Thetans of volcanos in Asia and the Pacific were
(0097)





taken to Hawaii.  Thetans of Atlantic areas were taken to Las

Palmas.

Asia and Pacific

North Japan                 Mt. Shasta
South Japan                 San Gorgornio
Krakajawia                  Indonesia
Mount Washington            Philippines
Mount Ranier                Himalayas
Mount Hood                  (Hawaii)
Andes
Atlantic

Tangier                     (Las Palmas)
St. Helena                  Canada
Kolomonjero

(Spelling not guaranteed)
(List may be incomplete)

Incident@

75,000,000 years ago on this planet.  Sometimes capture was
on another planet and explosion on this planet, then called
(0098)





Teegeeack. -Locate area of explosion.  Pictures of explosion
follow it.  Get original explosion.  Effort to stop usually
present.

H-BOMB DROPPED ON VOLCNO
EXPLOSION
TERRIFIC WINDS
THETAN CARRIED  OVER PEAK
ELECTRONIC RIBBON CAME UP
HE STUCK TO IT
IT WAS THEN PULLED DOWN AND HE WAS (AS PART OF A GROUP)
IMPLANTED WITH R6
PICTURE OF PILOT SAYING HE IS MOCKING IT UP

(R6 materials follow, then days of pictures of God, Devil,
etc.)

(Thetan usually cognites on pilot or before (or on first
incident) and leaves.)

Incident I

Occurs at start of track (4 quadrillion years ago).

LOUD SNAP
WAVES OF LIGHT
(0099)





CHARIOT COMES OUT, TURNS RIGHT AND LEFT
CHERUB COMES OUT
BLOWS HORN, COMES CLOSE
SHATTERING SERIES OF SNAPS
CHERUB FADES BACK (RETREATS)
BLACKNESS DUMPED ON THETAN
Effort to stop must be gotten off (sometimes to hurry).
Run as an engram.
(0100)





OT IV RUNDOWN


Non-Solo




OT IV Rundown

Symptoms

Has completed OT III

OT IV Warning.

This is in fact a grade.  Therefore to run it without setting
the case up fully is to waste it.

Often the case has to:

(1)  Be discharged with a lot of corrective actions and
(2)  OT ill must be run on the PC by the auditor or at least
cleaned up.  It might not be uncommon to have to do half
or more of the C/Ses in the book before doing the OT IV
Rundown.

If one holds off and really flies the case, then the person
(0101)





winds up at OT Exterior very nicely when one does OT IV.



If you do OT IV and he's still in his head, all is not lost,

you have other actions you can take.  Clusters, Prep-Checks,

failed to exteriorise directions.

OT V and VI are designed for someone already exterior.  If a
person doesn't go exterior after OT IV Rundown you set him up for
V by then seeing he jolly well does go exterior before going on to
V.
__________________________________________

OT IV Rundown
Done only by an Auditor on a Case fully set up by various
Directions.
(0102)





2 April 1978


OT IV SOLO

The end phenomenon of OT IV is "Certainty of Self as a
Being".  The thing that would make a Being uncertain is the
possibility of future implants.  OT iv Solo is designed to "proof
up a Being" against any possibility of being re-implanted now  that
he/she has finished running implants with the completion of OT

The main idea on OT IV Solo is to mock-up (create) each line
of the Cle  aring Course (7's, The Basic End Words, The Confusion
GPM, Objects-Hollow, Objects-Solid) with all the perceptics,
force, impact, and unconsciousness of the original implant (as
much as you are able).  When the line is mocked up (created or
recreated), then unmock it, cease creating it, and blow the  charge
you have recreated or mocked up.  Do this repetitively with each
line of the Clearing Course (including lights) to a floating
needle on each line.  Continue until you feel totally free with
and at cause over this implant sequence; (you may or may  not  need
to complete all 5 parts).  Do it until you can freely and easily
mock-up and blow this implant and can confront implants.

Lastly, scan out all of your auditing early to late adding  up
all the hours in session as you go along.
(103)





Come up with a total number of auditing hours for yourself.


Find and run a havingness process.


Attest to OT IV

(1)  Rudiments or GF (Green Form) to FIN.
(2)  Rehab Drugs.
(3)  Valence Shifter.  "What valence would be safe?"
(4)  Rehab ARC Straight Wire to Grade IV.
(5)  Rehab R6EW - OT II.
(6)  Prepcheck OT Ill.
(7)  Rehab OT V &.VI.
(8)  Run "What has been Overrun?"
(9)  Run "What can you confront?"

(IF THE PRE OT DOES NOT EXTERIORIZE, WE WILL DO 7 CASES NEXT

SESSION AND HANDLE UNTIL HE DOES GO EXTERIOR which is really the

end phenomena of OT IV Audited only by a Class VIII.)
(0104)






OT V



CAUSE OVER MEST





Gain Freedom from Fixated

Introversion into MEST


For eons, man has speculated and guessed about the nature of the
Physical Universe.  There have been many opinions and much
discussion.  Even the modern physicist, with his many names and
labels, is still in the dark when it comes to how it got here and
why.  Before Scientology, the exact truth about the MEST Universe
was lost, and the way out of the trap unknown.  Lies and
misinformation had taken the place of the truth.

In 1967, L. Ron Hubbard released Section V of the Operating Thetan
Course, the most powerful level released up to that time.  On OT V
you learn the truth about the Physical Universe, not the laws of
physical scientists, but the basic considerations about Matter,
Energy, Space and Time.

The tremendous power that this universe -seems to have over thetans
resulting in entrapment, degradation and death, is traced to its
(0105)





source.  As you exteriorize from the Physical Universe at Section
V. you discover exactly what MEST is, and become free of its laws.

At OT V, a Being is re-familiarized as a thetan exterior with the
Physical Universe.  OT drills are done to remarkably increase a
Being's ability to communicate with his environment.  He is now
able to do so, totally free of the mind and body, and free from a
fixated introversion into MEST.

Solo auditing on this level serves as an introduction to the
rehabilitation of his total abilities as a thetan.  He learns to
-use his new abilities Is a thetan with wisdom and judgment.

OT V

Pre OT is to lie down in a comfortable position with eyes shut.

(1)  Spot a spot in the room.
(2)  Spot a spot in your body.

Alternate 1 and 2 until commands are flat then,

(3)  Spot two spots in your body.
(4)  Spot two spots outside.

Alternate 3 and 4 until flat then,
(0106)





(5)  Spot a spot outside.
(6)   Spot a spot  on  the  sun.

(Notice the distance between.)

(7)  Spot  two  spots   outside.
(8)  Spot two spots on the sun.

(Notice what happens.)

The pre OT may exteriorize during these drills but doesn't
necessarily have to.

While still inside with eyes shut in a comfortable position the
pre-OT is to follow the following commands and write down any
major cognitions.

(9)   Spot an object in the-room.
(10)   Spot  an  object  outside.
(11)   Locate  a  moving  object.
(12)   Locate a spot in your body.
(13)   Spot  a  motion.
(14)   Locate  a space.
(15)   Spot  a  Thetan.

Continue   the  above steps until major cognition, very good
(0107)





indicators or exteriorization occurs.

The following steps are done outside.  The pre OT takes a paper
and pencil with him to take notes.

1.  The pre-OT is to put his attention on an object that is ahead
of him like a parked car, lamp post, etc. and walk towards it
noticing the distance between him and it.  He is to continue to do
this until cognition.

2.  Next the pre-OT is to again pick out an object ahead of him
and wrap in energy beam around it and himself and pull himself
toward the object with shortening of the beam.

Notice what happens.

3.  Locate an object, draw energy from it into you.  Repeat at
least ten times.

Note any cognitions.

4.  Locate an object as above and walk toward it.  Notice what is
holding you to it.

5.  Notice a cloud and notice the space between you and it.
(0108)





6.  Notice your body.



7.  Notice the motion of the earth and your relationship to it.


8.  Notice something about 10 people.



Do all the above steps to a cognition.

Note:  Originally it was not necessary to be exteriorized in order
to do OT V or VI 6.  Recently however, it has been changed and the
state of exteriorization is supposed to be achieved by OT 4
thereby leaving OT V and VI to be done while exterior.
END OF OT V
(0109)



OT VI

Each of the following processes are run to a

(1)  Floating needle
(2)  Major cognition
(3)  Regained ability.

(Preferably all three together as the ideal end.  End Phenomena.)

Be  Three feet in back of your head.  Whatever you are looking at,
copy it a dozen times, put it into you.  Find the two back corners
of the room and hold onto them without thinking for two minutes.

Find two corners of the planet Earth, hold onto them for two
minutes.

Find a place where you are not.
Spot three spots in your body.
Spot three spots in the room.

Be in the following places:
The room, the sky, the moon, the sun.

Locate an animal .. postulate him moving from one spot to another.
Observe him doing this.
(0110)





Find a walking man ... postulate his walking faster.  Do this with
20 people.

Find a walking person .. postulate that he will stop, then
continue walking.  Do this 20 times.

Find a person in a distant land.  Notice the time of  day.  Notice
the terrain.  Notice the general environment.  Smell the air.
Locate a thought that is his.  Locate a thought that is yours.
Continue until flat.
'Notice differences between you and your body.

Create in your body a feeling of calmness;  create in your body
sexual desire and turn it off.  Continue that step until you  feel
you have control over the sexual drives.  Create in the body a
feeling of pain.  Create in the body a feeling of serenity.  Do
the above until flat.  Create in the body a feeling of hunger  and
turn it off.  Continue this step until you are in control of
hunger drives.
The end result of these particular drills is the regained ability
to control the body and its sensations.
Now:  Postulate Anger, boredom, grief, cheerfulness and serenity -
-- in that order.  This is continued until you are sure that you
can create any emotion.
(0111)





Finally, exteriorized visit a friend who lives in another state.

Greet him and flow affinity to him.  Ask him to communicate to you

by letter.



End of OT VI
(0112)






OT VII RUNDOWN

June 1979 Revision

1.  Basic Processes Set-up.

OT7-1
What are you willing to cause?
What are you willing to be the effect of?

OT7-2
Decide something.

OT7-3
Clear intention.  (Very thoroughly.)  Have client use word in at
least six sentences.  (If needed.)
*CDP/MCP "Intention"
OT7-4
1.  What is a clear intention.
2.  Give me an example.
3.  What isn't a clear intention.
4.  Give me an example.

OT7-5
2 W/C .. the subject of intention.

(0113)





OT7-6

Recall  an  intention.


OT7-7

invent  (mock-up)  some  intentions.

CDP - Creative Definition Procedure
MCP - Meaning  Control  Procedure
These are both Eductivism procedures for clearing words.

OT7-8
F-2.  Tell me a thought/intention you would be willing to receive
from another..  (Whichever reads.)
F-2.    Tell me a thought/intention another would be willing to
receive from  you.
F-3.    Tell me a thought/intention others would be willing to
receive from others.
F-0.    Tell me a thought/intention you'd be willing to receive from
yourself.

0T7-9
F-1.  What intention of yours has another helped?
What  intention  of  yours   has  another not helped?
F-2.    What  intention  of  another's  have you helped?
What  intention  of  another's  have you not helped?
F-3.    What  intention  of  another's  have others helped?
What  intention  of  another's  have others not helped?
(0114)






F-0.  What intention of yours have you helped?

What intention of yours have you not helped?

OT7-1O
F-1.   What intention of another's could you confront?
What  intention  of  another's would you rather not confront?
F-2.    What  intention  of  yours could another confront?
What  intention  of  yours would another rather not confront?
F-3.    What  intention  of  another's could others confront?
What  intention  of  another's would others rather not
confront?
F-0.   What  intention  of  yours could you confront?
What  intention  of  yours would you rather not confront?
OT7-11
F-1.  What intention of yours could another be responsible for?
F-2.  What intention of another's could you be responsible for?
F-3.  What intention of another's could others be responsible for?
F-0.  What intention of yours could you be responsible for?
OT7-13
Give me an unknown  datum.
OT7-14 (PAB 69)
Tell me some orders you wouldn't mind receiving.
Tell me something that would obey you.
(0115)





OT7-15
Get the idea I can place an intention.
Get the idea I cannot place an intention.

II.  L & N Intention Process
OT7-16
Has an intention been....

Suppressed                       Forgotten
Invalidated                      Hidden
Blunted                          Avoided
Abandoned                        Altered
Denied                           Twisted
Enforced                         Changed
Desired                          Completed
Decided                          Made Wrong

on biggest reading item     L & N ...
What intention has been                ?
R3R Quad if evil intention.

III.  Placing @houghts and intentions (inside Auditing room).

OT7-17
A.  Spot an object.
B.  Locate an object from which you are separate.
(0116)





Locate an object which is separate from you.

OT7-18
Think a thought.
Creatively place that thought in/on that.  (Indicated object.)
]Row creatively get that (indicated object) thinking that thought.
Creatively have that (indicated object) continue thinking that
'thought.
Creatively have that (indicated object) cease thinking that
thought.

OT7-19
Clear intention.

Mock up (invent) an intention.

Get the idea of placing (or place) that intention in that
(indicated object).

OT7-20
>From (indicated point) make a choice between (indicated positions
or objects).

OT7-21
Putting the decision on (in) that (indicted object) make a
decision about it.
(0117)



OT7-22
Decide something.

IV.  Outside Processes with an Auditor (objects).

OT7-23
Spot an object.

OT7-24
Locate an object from which you are separate.
Locate  an object which is separate from you.

OT7-25
Think a thought in (on) that (object or position)
or
Do you see that (     object    )?
Think a thought in (on) it.
Did the thought appear where it is?

OT7-26
>From (indicated point) make a choice between (indicated positions
or objects).

OT7-27
Putting the decision on (in) that (indicated object) make a
decision about it.
(0118)





V.  Outside Processes with an Auditor (people).

OT7-28
Spot an acceptable energy source.

OT7-29
Spot a person.

OT7-30
Locate  a person from whom you are separate.
Locate  a person who is separate from you.

OT7-31
Point out a difference between that person's body and yours.

OT7-32
Tell me something you really know about that person.
What would you permit that person to know about you?

OT7-33
Postulate perfection into that person.
Now postulate perfection into that one.

OT7-34
Tell me something you wouldn't mind knowing about that person.
Tell me something you wouldn't mind that person not-knowing about
you.
(0119)





OT7-35
Think a Thought in (on) that person
or
Do you see that person?
'Think a thought in (on) him/her?
Did t-he thought appear where it is?
OT7-36
>From that person make a choice between (indicated positions or
objects).
OT7-37
Putting the decision on (in) that person, make a decision about
bin/her.
OT7-38
Decide something.
(0120)





OT VII SOLO SECTION

VI    Inside Processes Solo
(On the Meter)

OT7-39
Spot an object.
OT7-40
Mock-up a confusion.
Unmock it;
or
What confusion could you create?

OT7-41
Mock-up a communication terminal.
Mock-up another communication terminal.
Dispose of these mock-ups.

OT7-42
What wouldn't you mind communicating with.

OT7-43
Kock-up your (father, wife, mother, husband).
Mock him (her) up again.
Dispose of these mock-ups.
(0121)





OT7-44
How could you appreciate another as a human Being.
How could another appreciate you as a human Being.
How could you appreciate yourself as a human Being.
How could another appreciate themselves as a human Being.
How could another appreciate another as a human Being.

OT7-45

Find and run a havingness process on yourself.

VIII   Outside Processes Solo
(Off the Meter)
OT7-46
Spot a  person
or
Spot a  Thetan.
OT7-47
1.  Go to a place with lots of people.
2.  Spot them one at a time.
3.  As you spot each person, do the following:

A.  Perceive the individual as a Life Source (Thetan).
B.  Know something about that person.
C.  Be willing to not-know something about that person.
(0122)





D.  Grant beingness to that person (by cognizing the way they
are).
E.  Having that person grant beingness to you.
OT7-48
1.  Find some plants, trees, etc., and communicate to them
individually until you know they received your communication.
2.  Go to a zoo or a place with many types of life and communicate
with each of them until you know the communication is received
and, if possible, returned.
OT7-49
Go out to a park, train station or other busy area.  Practice
placing an intention into individuals until you can successfully
and easily place an intention into or on a Being and/or a body.

Attest to OT7
(0123)




STEVEN FISHMAN
Dismas House, Room 324
141 N.W. 1st Avenue
Dania, Florida 33004

Defendant Pro Se

GRAHAM E. BERRY
JUDITH M. TISHKOFF
LEWIS, DIAMATO, BRISBOIS   BISGAARD
221 North Ficlueroa Street, Suite 1200
Los Angeles, California  90012
(213) 250-1800

Attorneys for Defendant,
UWE GEERTZ, Ph.D-




UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA



CHURCH     OF    SCIENTOLOGY         CASE NO. 91-6426 HLH (Tx)
INTERNATIONAL,
VERIFIED    JOINT     PRELIMINARY
Plaintiff,                       NOTICE OF  MOTION  BY  DEFENDANTS
STEVEN  FISHMAN  AND  UWE  GEERTZ
FOR   RECONSIDERATION   OF   THIS
COURT'S  MARCH  22,  1993  ORDER
TRANSFERRING THE  VENUE  OF  THIS
VS.                                  CASE  TO   U.S.D.C.,     SOUTHERN
DISTRICT OF  FLORIDA  AND  MOTION
FOR RELIEF FROM THAT  SAME  ORDER
PURSUANT TO F.R.CIV.P. 60

STEVEN FISHMAN and UWE GEERTZ,       Date:  April 26, 1993
Time:  10:00 a.m.
Defendants.                       Place: Courtroom 7



PRELIMINARY  NOTICE  IS  HEREBY  GIVEN  that  defendants   Steven
Fishman and Uwe Geertz will  shortly  be  filing  a  joint  notice  of
notion and motion for reconsideration of this court's March  22,  1993
order to transfer  the  venue  of  this  case  to  the  United  States
(0134)





District  Court  for  the  Southern  District  of  Florida  (pursuant   t
Local  Rule  7.16)  and  a  motion  for  relief  from  that   same   order
pursuant to Rule 60 of the Federal Rules of Civil Procedure.
THE PURPOSE OF  THIS  PRELIMINARY  NOTICE  OF  MOTIONS  IS  TO  AVOID
ANY FURTHER INCONVENIENCE OR  EXPENSE  ON  THE  COURTS  PART  WITS  REGARD
TO THE TRANSFER OF THE  FILE  PENDING  THE  FILING  AND  REARING  OF  SAID
MOTIONS   FOR   RECONSIDERATION   AND   F.R.CIV.P.   RULE   60    RELIEF.
DEFENDANTS GEERTZ AND PIS        EXPECT TO FILE  THEIR  JOINT  MOTION  BY
MONDAY, APRIL S. 1993.  THIS DELAY IS OCCASIONED BY FISHMAN,
GEERTZ
AND GEERTZ'S COUNSEL GRAHM E. BERRY,  BEING  ENGAGED  FROM  MARCH  15  TO
APPROXIMATELY MARCH26  IN  VARIOUS  DEPOSITIONS,  FROM  DAY  TO  DAY,  IN
FORT  LAUDERDALE,  FLORIDA,  INCLUDING  THE  DEPOSITIONS  OF  DR.  GEERTZ
AND MR.  FISHMAN.
This motion will be made, inter  alia,  on  the  following  grounds:
A.   AS TO DEFENDANT FISHMAN:
Prior to the March 22, 1993 hearing on  his  motion  for  change  of
venue:
1.   Mr.   Fishman   mistakenly   thought   that   IRS    officials,
(Messrs.   Tronscoso  and  Kroggel)   from   Tampa,   Florida   could   be
compelled  to attend the trial  of  this  matter  in  Miami,  Florida  and
that  they  could  be  compelled  to  testify  about  ongoing  government
investigations;
2.   Mr. Fishman mistakenly  thought  that  Detective  Angelo  could
be  compelled  to  attend  trial  in  Miami,  give  testimony  about   an
ongoing police  investigation  and  Mr.  Fishman  also  did  not  realize
that  statements  by  Detective  Angelo  regarding  what   Fishman   told
Detective Angelo about Scientology would be hearsay;
3.    With  regard  to  "certain  hostile  witnesses  who  are  staff
(0135)






members of the Church of Scientology":
(a) Mr. Fishman had not realized that these  persons  would
have to be subpoenaed for depositions, deposed, subpoenaed for  trial
and paid witness fees, all at an impossible expense to himself;
(b) Mr. Fishman  had  inadvertently  forgotten  that  these
witnesses would have been subjected to Scientology's  TR-L  (training
routine-lying) , witness training program ("hatting the witness") and
security procedures - all to subvert the truth and  so  render  their
testimony futile to the standpoint of Mr Fishman's defense;
4.    Mr. Fishman had  mistakenly  and  inadvertently  failed  to
realize that the witnesses he really needs in this case  are  largely
ex-Scientologists -- most of  whom  are  more  readily  available  to
testify at trial in Los Angeles;
5.    Fishman had mistakenly  filed  his  motion  for  change  of
venue after reviewing his file and  noticing  that  defendant  Geertz
once had filed the same motion, and without  knowing  that  defendant
Geertz had subsequently  made  a  determination  that  the  case  was
better venued in Los Angeles for an assortment of different  reasons.
6.    Mr. Fishman had  mistakenly  and  inadvertently  failed  to
consider the logistical problems he  faced  in  trying  his  case  in
Miami without the support services  of  Lewis,  D'Amato,  Brisbois  &
Bisgaard being available with  regard  to  the  dozens  of  boxes  of
documents that will be introduced into evidence in his case.
7.    Mr. Fishman had not received Lewis, D'Amato's  offers  to:
(a)  provide him  with  law  library,  support  and  office
services during the trial in Los Angeles;
(b) provide him  with  accommodations,  air  transportation
and a per them for food costs during trial in Los Angeles and to  the
(0136)







extent plaintiff Scientology failed to do so;
(c)  pay for the  travel  and  accommodation  of  Marjorie
Wakefield to testify at trial in Los Angeles;
(d)  take videotaped depositions of so  many  of  the  so-
called "Scientology hostile witnesses" in Fort Lauderdale  and  Miami
who could be subpoenad for deposition;
(e) use their best efforts to find Mr. Fishman a pro  bono
trial counsel for a trial in Los Angeles;
(f) file a motion for summary judgment in Los Angeles,  in
which Mr. Fishman would join; and
(g)   transport his over  50  boxes  of  evidence  to  Los
Angeles and store it for him there pending trial and for  six  months
thereafter.
8.   Mr.  Fishman  had   not   developed   the   close   working
relationship he now has with Graham E. Berry of Lewis  D'Amato  as  a
result of the Steven Fishman, Jack Fishman, Jamie Lee  Nuryev,  Keith
Nosetta and Dr.  Geertz  depositions  now  being  conducted  in  Fort
Lauderdale, Florida.
9.   Mr. Fishman had not  realized  that  the  granting  of  his
motion  for  change  of  venue  may  adversely  affect  Dr.  Geertz's
representation by the Lewis D'Amato firm and  threaten  the  informal
assistance now being received by him from  the  Lewis,  D'Amato  firm
including but not limited  to  receiving  copies  of  all  deposition
transcripts, discovery  propounded  and  received  that  he  had  not
hitherto been able to afford himself  and  that  plaintiff  had  been
unwilling to provide him.
(0137)







B.  AS TO DEFENDANT GEERTZ:
10. The defense of defendant Dr.  Geertz  was  "stayed"  by  his
bankruptcy petition until only days  before  the  February  22,  1993
hearing on Fishman's motions.     [Scientology  has  since  moved  to
reconsider the  bankruptcy  court's  exemption  of  Dr.  Geertz  from
personal liability when it partially lifted the stay.)
11. Mark  Augustine  was  originally  responsible  for  handling
this matter on behalf of Lewis, D'Amato.  During the pendency  of  the
automatic stay Mark Augustine resigned from the  Lewis  D'Amato  firm
and was replaced on this matter by Graham Berry.
12. Only hours  after  the  February  22,  1993  continuance  of
Fishman's  motion,  and  this  court  orders  that   Fishman   submit
declarations as to the change of venue, Graham Berry was admitted  to
Cedar  Sinai  Hospital  on  an  emergency  basis.        During    his
hospitalization and recuperation, Mr. Fishman  served  a  new  motion
for change of venue (by Federal Express and not first class  mail  on
Lewis, D'Amato).    Due to  either  mistake  or  inadvertence,  either
Judith Tishkoff, Esq. or her paralegal, failed to ensure that  Graham
Berry saw the new motion and failed to ensure that the date  for  new
opposition papers was properly calendared.      Accordingly,  at   the
March 22, 1993 hearing on Fishman's  motion  for  change  of  venue,
Graham Berry was not aware that Mr.  Fishman  had  filed  new  motion
papers now supported by the  declaration  the  court  had  previously
ordered.
13. Defendant Geertz selected the Lewis,  D'Amato  law  firm  as
his  counsel  partly  because  of  its  considerable  experience   in
handling Scientology litigation.  Over $100,000 has been  expended  on
this defense to date.  Transfer of the  case  to  Florida  would  mean
(0138)






either:
(a)  the appointment of replacement counsel  at  enormous  cost
and expense and the loss of Lewis, D'Amato's general expertise  and
acquired knowledge in this case, or
(b) the appointment of unnecessarily expensive and  duplicative
Miami co-counsel.
14. If defendant Geertz's counsel (Lewis, D'Amato) has  to  try
this case in Miami instead of Los Angeles:
(a)   over 80 boxes of documents in this case will have  to  be
transported and accommodated in Miami;
(b)   selected boxes of  documents  from  over  200  boxes  of
documents acquired from other Scientology  cases  will  have  to  be
transported and accommodated in Miami;
(c) document handling and  logistical  support  services  would
have to be specially hired in Miami;
(d)  The cost  of  trying  this  case  will  vastly  exceed  the
$300,000 already projected because of the travel  and  accommodation
costs that will be incurred by the attorneys and staff  in  contrast
to merely transporting and accommodating Messrs.  Fishman, Geertz and
certain witnesses in Los Angeles.
C.   PLAINTIFF CHURCH OF SCIENTOLOGY INTERNATIONAL
As to plaintiff Church of Scientology  International,  it  would
be argued that it opposed Fishman's motion for change of  venue  now
sought to be set aside.
(0139)








Dated:  March 26, 1993       LEWIS, D'AMATO            BRISBOIS & BISGAARD


By:  (bears signature of)
Graham E. Berry
Attorneys for Defendant
UWE GEERTZ, Ph.





Dated:  March  26      1993             (bears siganture of)
Steven @shman





Dated    March 26      1993            (bears signature of)
Dr     Uwe Geertz








VERJOINT.MOT

(0140)

Fishman Case No 91-6426 HLH (Tx)



HUBBARD COMMUNICATIONS OFFICE
Saint Hill Manor, East Grinstead, Sussex
OT VIII
HCO BULLETIN OF 1 OCTOBER 1969

SECRET


WHY THETANS MOCK-UP

This question has been the most plaguing one in Dianetics and
Scientology.

The ONLY way a thetan ever gets in trouble, the ONLY way he can
get trapped or become part of a cluster is by mocking-up and
inaking pictures of bad experiences.

And why record all bad experiences?  This too is not good sense.

one can explain it by a yearning for eventi by havingness and
other ways, but these do not factually lead to a total solution.

The real reason stems from a characteristic of a thetan.  He never
totally gives up.

There is, seemingly, a streak of resistance or resentment that
makes a thetan wish to persist in the same place.  If he cannot,
(0124)





he will do so covertly.

All power comes from the ability to occupy a point.  The base that
separates two terminals must be firm or there will be no exchange
of energy.
The effort to weaken a thetan is to make him relinquish his point
In space.  covertly or overtly a thetan seeks to assert his
position in space.

If he cannot do so overtly he does so covertly.

When a thetan is moved unwillingly from a point or position, he
even then refuses to give up that point, but MOCKS IT UP.  He also
mocks up the events of his departure as a part of the action of
mocking up the point he is leaving.  This, unwittingly, gives him
a picture, an engram.

Now let us see if this theory holds true in practice.

A.  Just ahead of any engram there must be an effort to
retain a position and there must be a point or  location
being mocked up.
This is true.  You can blow an engram without running  it
by spotting its first point in space and time.  In a
secondary, "Where did you first hear of the loss" is a
vital question.
(0125)





B.  In a Contact Assist getting a person to touch again the
point where he was hurt with what was hurt will blow the
engram.
C.  Getting a person to locate areas (locations) that are not
safe produces blows of engrams without running them.
D.  Exact and accurate dating sometimes blows an engram.
Those times when it does not, it should blow when the
location is exactly spotted.
E.  Implants and traps were done mainly to keep thetans out
of an area.  The thetan, resenting and resisting mocks up
the place anyway and so implants himself.
_____________________________

A thetan too easily substitutes a mock-up for a point in the real
universe.

one could also say that a thetan, by mocking up, warns himself
against certain points in space or areas in the Physical Universe.

Anxiety is solely not being able to be in certain places and not
where one is either.

making people leave is the most unpopular action unless one also
frees them to be anywhere.

Transferring people is a degrading thing to do to them.
(0126)





Jail denies a thetan all spaces except where he has been placed
and note that thetans are made very miserable in Jail.  Jailing is
a sure way to confirm criminals and also to make them crazy as
well.

Any thetan, stuck in an engram, is asserting the effort to be at
the point where he was hit at the beginning of that engram.

An engram therefore is a refusal to leave a place at which force
was exerted to drive one away.

Reversely, one can refuse to be held at a place where one does not
wish to bt, but this is a negation of a place, a not-is of it and
its time.
Power of choice over where one is and where one is not is thus a
key to engrams.

Finally - a thetan mocks up because he covertly refuses to abandon
a location under duress and not-ises the place where he does not
wish to be but must.

Using these facts one can blow engrams without running them.

Some sample questions:

What point (location) is unsafe?
(0127)





What location could you have held absolutely?
Where did you first get an intimation of danger?
What place would you rather not be in?
What effort would it take to hold (that) (a) locatation?


Working with this you will see a door open to a higher level than
Dianetic R3R.  But realize that it is only for a high level
thetan.

This is the road to returned personal power in the Physical
Universe.

L. RON HUBBARD
Founder
LRH:rs
Copyright (c) 1969
By L. Ron Hubbard
ALL RIGHTS RESERVED
(0128)






HUBBARD COMMUNICATIONS OFFICE
Saint Hill Manor.  East Grinstead, Sussex

HCO BULLETIN OF 5 MAY 1980

LIMITED DISTRIBUTION              ISSUE I

OT VIII Course Students
OT OT VIII Auditors
OT VIII CIS*s
AO Review Auditors
AO C/Ses
OT VIII Series I

C O N F I D E N T I A L

STUDENT BRIEFING

By the time you read this I will no longer be occupying the body
and identity
that you have known as Ron.  That identity continues to live in the
hearts and
minds of many as well as in on-Source tech and admin centers around
the planet,
and will inspire for years to come Scientologists and lovers of truth
every-where.

What follows is a story that has been withheld, for reasons which
will soon be
obvious, until such time as there were enough OTs that something
could be done
about it.   That time Is now.   It is not a nice or a pretty story.
but I trust
that having arrived on the OT VIII Course you are ready to hear
it.   You have
undoubtedly heard pieces of data over the years that hinted at the
greater
untold reality of my mission here on Earth. but the story was never
written,
nor spoken. in its entirety due to security problems that have
unfortunately
always plagued the organization.  It is only now that I feel it
safe to release
the information, although the time is rapidly approaching when I
will have no
choice in the matter, the hour draws that near.

I an not going to delve too deeply into specifics as people have a
tendency to
bog themselves down in significance. which would only serve to
delay the
immediacy of the task at hand.  Therefore I will be brief.

Some eighty-odd million years ago Earth time (it actually dates at
78,395,042
but dates are & bit superfluous with this material) plans were
drawn by a
group outside the MEST universe for the eventual takeover of a good
portion of
this universe.  Not a particularly large nor Imaginative crew,
their exterior
perspective. however. gives them considerable advantage over tho
time-bound
beings of the MEST universe.   Borrowing from earlier operations
such as
Helotrobus. they conceived an ongoing implant. some portions of
which have been
fairly faithfully rendered in parts of the Bible.  This implant,
laid in by
carefully controlled genetic mutation at Incident Two of OT Ill and
periodically reinforced by controlled historic events since then,
makes it
effectively impossible for beings on the more heavily affected
planets such as
Earth to become free.  It causes progressive genetic "evolution"
that gives the
subject population greater and greater susceptibility to the telepathic
impingement and direction of the controllers.   In its final stage the
progression becomes almost geometric, and it is this final stage
that we are
rapidly approaching.
(0129)






Another aspect of this GE-line implant is that the  body  becomes
in  effect  a
sort of thats trap that kicks in heavily on the being should he
attempt to
expand his horizons beyond that of pure  physical  universe
reality.  There  can
be temporary key-outs which we have all  experienced  in  varying
degrees.  but
until this area is handled it can honestly be said that there  is
no  hope  for
continued expansion.    The good news is that once this is  run
out.  expansion
becomes rather effortless and almost automatic.

No doubt you are familiar with the Revelations section of the
Bible where
various events are predicted.  Also mentioned Is a brief period of
time in
which an arch-enemy of Christ. reforred to as the  anti-Christ,
will  reign  and
his opinions will have sway.  All this  makes  for  very
fantastic,  entertaining
reading but there is truth in it.  This  anti-Christ  represents
the  forces  of
Lucifer (literally, the "light bearers" or  "light  bringer"),
Lucifer  being  a
mythical representation of the forces of enlightenment, the Galactic
Confederacy.   My mission could be said to fulfill the Biblical
promise
represented by this brief anti-Christ period.     During this
period there  is  a
fleeting opportunity for the whole scenario to  be.  effectively
derailed.  which
would make it impossible for the mass  Marcabian  landing
(Second  Coming)  to  take
place.  The Second Coming is designed, among  other  things,  to
trigger  a  rapid
series of destructive events.

With the exception of the original Buddhism,  virtually  all
religions  of  any
consequence on this planet, mono- and pantheistic  alike.  have
been  instruments
to speed the progress of this "evolution of consciousness"  and
bring  about  the
eventual enslavement of mankind.  As you  know,  Siddhartha
Gautama  never  claimed
to be anything more than a man.  Having caught  on  to  this
operation,  he
postulated his own return as Metteyya, part of which  prophecy
will  have  been
fulfilled upon the passing of L. Ron Hubbard.

For those of you whose Christian toes I may have stepped on.  let
me  take  the
opportunity to disabuse you of some lovely myths.     For
instance,  the  historic
Jesus was not nearly the sainted figure has been made out to
be.      In  addition
to being a lover of young boys and men. he was  given  to
uncontrollable  bursts of
temper and hatred that belied the general message  of  love,
understanding  and
other typical Marcab PR.  You have only to look  at  the  history
his  teachings
inspired to see where it all inevitably leads.     It Is historic
fact and  yet  man
still clings to the ideal. so deep and insidious  is  the
biologic  implanting.

It Is a good joke that the Calactic Confederacy is  associated
with  the  Serpent
in the Garden, the beast and other emissaries of the "Prince of
Darkness".      Yet
in certain passages and esoteric interpretations of the Bible
(much  of  which
has been taken out and effectively suppressed for  centuries)  as
well  as  the
Cabbalah, the truth reveals itself quite nicely for the clever and the
ungullible.

So it really is a race against time and one that we happen to  be
losing  at  the
moment, as the implant drama inexorably plays itself out in spite
of  the
breakneck pace I've managed to keep up these last thirty-five years.

I had an inkling, but only that, of the insidiousness of  this
material  as  far
back as 1945.   Later. in charcteristic over-optimism,  I
thought  that  R6  would
be the end of it.  But that was followed by  NOTs  and  the
Purification  Rundown
and still the string continued to unwind with the ball at the
end  of  it  just
out of sight.   It makes ons wonder about such things as  fate
and  destiny,  such
(0130)






was the resolve with which I managed to cling to that string. not
often knowing
how close I was to falling into the abyss myself.  but  destiny
it  merely  the
rationalization of feeble minds.  Things don't just  happen,
they  are  caused.
And causative beings can undo the plans of madmen  and  would-be
enslavers,  no
matter how long those plans may have been in the making.

I will soon leave this world only to return and complete my
mission with
another Identity.  Although I long to stretch my arms  back  in
repose  on  some
distant star in some distant galaxy.  It appears that  is  one
dream  that  will
have to wait.  But my return depends on people like  you  doing
these  materials
thoroughly and completely so that there will  be  a  genetically
uncontaminated
body for me to pick up and resume where I left off.  A  body
free  of  religious
mania, right/wrong dichotomy and synthetic karma.  The  job
ahead  is  far  too
tough to even contemplate doing with your standard -- courtesy of
certain
other-dimensional players and their Marcab pieces, many of whom
are  right  here
In the general populace -- genetically altered body.

Without the biogenetic meddling of those who stand outside time
(who cannot  yet
directly influence our world and must work through others) the
dwindling  spiral
is not nearly as automatic and self-perpetuating     as it
appears.  There are
regions even in isolated parts of the Milky Way where poets  are
free  to  poet
and magicians can paint reality with their magic wands and
exteriorize  without
body kickback.  But these areas unfortunately are fewer and fewer.

I will return not as a religious leader but a political  one.
That  happens  to
be the requisite beingness for the task at hand.  I will not  be
known  to  most
of you, my activities misunderstood by many, yet along with your
constant
effort in the theta band I will effectively postpone and then halt
a  series  of
events designed to make happy slaves of us all.

So there you have it.  The secret that I have kept close to my
chest  all  these
years.  Now you too are part of this secret and I  no  longer
have  to  shoulder
the burden alone or live with the possibility of body death before
all the  data
could be released.  And with this briefing I entrust to each of
you the
responsibility for this material until such time as I an  able
to  return.  For
we have no help from any other quarter in this matter.  The
handful  of  secret
societies throughout history that have caught on to this game
have  long  since
fallen by the wayside or been taken over and become instruments of
the very
menace they were set up to combat.

The rundown is long and can be arduous, but it must be done
thoroughly if  there
is to be any effect not only on the body of the pre-OT but the
body  of  his  or
her progeny as wall.  There is some danger, but with OT VII
thoroughly  complete
It is not nearly so great as the danger witnessed by assorted
unfortunates  who
happened to stumble into this area in their sleep or in moments
of  reverie  or
anaten, experiencing an hitherto mysterious  phenomenon  known
as  "spontaneous
combustion".

CAUTION:  DO NOT BE PTS WHILE TRAVERSING THIS THIRD AND FINAL WALL
OF FIRE

But the area is well charted. the rundown many years in secret
development,  and
by the time you read this undoubtedly completed on  myself.  The
wins  awaiting
you are like none that you have ever experienced, not just for
you. but for
your children. your children's children and the whole of mankind,
if we
succeed.  And we will.  If we had time we should pity the many
poor  souls,  from
(0131)





1950 to PT, who chose such an exactly inopportune moment to drop
off the road
to truth and disconnect from reality, the full burst and glory of OT
practically within their grasp.  But we haven't the time to "wax
philosophic"
or ponder might have beens.

The rundown follows.  Again I say, do it thoroughly and
completely, for it is
your ticket to the stars.  And beyond!

L. RON HUBBARD
FOUNDER

LRH:lrh
Copyright (c) 1980
by L. Ron Hubbard
ALL RIGHTS RESERVED

(0132)

of  venue  now
sought t                   L. RON HUBBARD
FOUNDER

LRH:lrh
Copyright (c) 1980
by L. Ron Hubbard
ALL RIGHTS RESERVED

(0132)






VERIFICATION
I, STEVEN FISHMAN, hereby declare and state as follows:
I have read the foregoing verified Joint Preliminary Notice
of Motion, etc., and know its contents.
I am a party to this action.  The matters stated in the
foregoing document are true of my own knowledge except as to
those matters which are stated 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.
Executed this 26 day of March, 1993 at Ft.  Lauderdale,
Florida.


(bears signature of)STEVE FISHMAN
(0141)






VERIFICATION
I, UWE GEERTZ, hereby declare and state as follows:
I have read the foregoing Verified Joint Preliminary Notice
of Motion, etc., and know its contents.
I am a party to this action.  The matters stated in the
foregoing document are true of my own knowledge except as to
those matters which are stated 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.
Executed this    26th day of March, 1993 at Ft.  Lauderdale,
Florida.

(Bears siganture of) UWE GEERTZ
(0142)







VERIFICATION
I, GRAHAM E. BERRY, hereby declare and state as follows:
I have read the foregoing Verified Joint Preliminary Notice
of Motion, etc., and know its contents.
I am a one of the attorneys for defendant Uwe Geertz, a
party to this action.  The matters stated in the foregoing
document are true of my own knowledge except as to those matters
which are stated 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.
Executed this  26th  day of March, 1993 at Ft.  Lauderdale,
Florida.

(bears signature of)GRAHAM
E.BERRY
(0143)










PROOF OF SERVICE
1013A (3) CCP Revised 5/1/88



State of California, County of Los Angeles



I am employed in the county of Los Angeles, State of
California.  I am over the age of 18 and not a party to the
within action.


On March 30, 1993 I served the foregoing document described
as: VERIFIED JOINT PRELIMINARY NOTICE OF MOTION BY DEFENDANTS
STEVEN FISHMAN AND UWE GEERTZ FOR RECONSIDERATION OF THIS COURT"S
MARCH 22, 1993 ORDER TRANSFERRING THE VENUE OF THIS CASE TO
U.S.D.C., SOUTHERN DISTRICT OF FLORIDA AND MOTION FOR RELIEF FROM
THAT SAME ORDER PURSUANT TO F.R.CIV.P. RULE 60 on the following:


ROBERT A. WEINER, ESQ.
BOWLES & MOXON
6255 SUNSET BLVD.  Suite 2000
LOS ANGELES, CA 90028


[X] BY PERSONAL SERVICE

I delivered such envelope by hand to the offices of the
addressee.

Executed on March 30, 1993 at Los Angeles, California.

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

[X)  (Federal) I declare that I am employed in the office of
a member of the bar of this court at whose direction
the service was made.





Type or Print Name                     Signature
(0144)







PROOF OF SERVICE
1013A (3) CCP Revised 5/1/88

State of California, County of Los Angeles

I am employed in the county of Los Angeles,.State of
California.  I am over the age of 18 and not a party to the within
action; my business address is 221 N. Figueroa Street, Suite 1200,
Los Angeles, California 90012.

On March 30, 1993, I served the foregoing document  described
as:  VERIFIED JOINT PRELIMINARY NOTICE OF MOTION BY DEFENDANTS
STEVEN FISHMAN AND UWE GEERTZ FOR RECONSIDERATION OF THIS  COURT'S
MARCH 22, 1993 ORDER TRANSFERRING THE VENUE OF THIS CASE TO
U.S.D.C., SOUTHERN DISTRICT OF FLORIDA AND MOTION FOR RELIEF  FROM
THAT SAME ORDER PURSUANT TO F.R.CIV.P. RULE 60 on all interested
parties:


STEVEN FISHMAN
REGISTER NO. 17280-004
DISMAS HOUSE
141 N.W. 1ST STREET
DANIA, FLORIDA, 33004


[x)  by placing [ ] the original [x) a true copy thereof
enclosed in sealed envelopes addressed as follows:

[x) BY MAIL

(x) As follows:  I am "readily familiar" with the firm's
practice of collection and processing correspondence for mailing.
Under that practice it would be deposited with U.S. postal  service
on that same day with postage thereon fully prepaid at Los Angeles,
California in the ordinary course of business.  I am aware  that  on
motion of the party served, services is presumed invalid if  postal
cancellation date or postage meter date is more than one day  after
date  of deposit for mailing in affidavit.

Executed on March 30, 1993, at Los Angeles, California.

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

[X]  (Federal) I declare that I am employed in the office of a
member of the bar of this court at whose direction the
service was made.



Type or Print Name                      signature (illegible)
(0145)





PROOF OF SERVICE

STATE OF CALIFORNIA
SS.
COUNTY OF LOS ANGELES

I am employed  in the County of Los Angeles, State  of
California.  I am over the age of eighteen (18) years  and  not  a
party to the within action; my business address is:  221 North
Figueroa Street, Suite 1200, Los Angeles, California  90012.

On April 9, 1993 I served the foregoing document(s)
described as DECLARATION OF STEVEN A. FISHMAN FILED IN  SUPPORT  OF
DEFENDANTS STEVEN FISHMAN AND UWE GEERTZ'S JOINT ]NOTICE OF  MOTION
-AND MOTIONS TO (1) RECONSIDER THE COURT'S MARCH 22,  1993  CHAMGE  OF
VENUE ORDER; (2) VACATE AND SET ASIDE THE COURT'S CHANGE  OF  VENUE
ORDER; AND (3) FOR EXERCISE OF THE COURT'S  INHERENT  EQUITABLE
POWERS IN CONNECTION WITH THE COURT'S MARCH 22, 1993 CHANGE OF
VENUE ORDER on the interested parties in this action by  placing  a
true copy thereof enclosed in a sealed envelope addressed as
follows:


Robert Wiener
BOWLES & MOXON
6255 Sunset Blvd., Suite 2000
Los Angeles, California 90028


(BY MAIL) I am "readily familiar" with the  firm's  practice
of collection and processing correspondence by  mailing.
Under that practice it would be deposited with U.S.  postal
tervice on that same day with postage fully prepaid at  Los
Angeles, California in the ordinary course of  business.  I
am aware that on motion of the party served, service  is
presumed invalid if postal cancellation date or  postage
meter date is more than one day after date of deposit  for
mailing in affidavit.

(X)    (BY PERSONAL DELIVERY) I caused such envelope to be
delivered by hand to the offices of the addressee.

(STATE) I declare under penalty of perjury under the  laws
of the State of California that the above is true and
correct.

[XI    (FEDERAL) I declare that I am employed in the offices of  a
member of this court at whote direction the service  was
made.

Executed on April 9. 1993, at Los Angeles, California.
(0146)


PROOF OF SERVICE

STATE OF CALIFORNIA
SS.
COUNTY OF LOS ANGELES

I am employed  in the County of Los Angeles, State of
California.  I am over the age of eighteen (18) years and not a
party to the within action; my business address is:  221 North
Figueroa Street, Suite 1200, Los Angeles, California  90012.

pn April 9. 1993 I served the foregoing document(s)
described as DECLARATION OF STEVEM A. FISHMAN FILED IN SUPPORT  OF
DEFENDANTS STEVEN FISHMAN AND UWE GEERTZ"S JOINT NOTICE OF  MOTION
AND MOTIONS TO (1) RECONSIDER THE COURT'S MARCH 22, 1993 CH"GE OF
VENUE ORDER; (2) VACATE AND BET ASIDE THE COURT'S CHANGE OF  VENUE
ORbER; AND (3) FOR EXERCISE OF THE COURTFS INHERENT  EQUITABLE
POWERS IN CONNECTION WITH THE COURTFS MARCH 22, 1993 CH"GE OF
VENUE ORDER on the interested parties in this action by placing  a
true copy thereof enclosed in a sealed envelope addressed as
follows:

Steven Fishman
17280-004
C/N Unit
FCI Tallahassee
PMB 1000 Tallahassee, Florida 32301-3572


IX)   (BY MAIL) I am "readily familiar" with the  firm's  practice
of collection and processing correspondence by  mailing.
Under that practice it would be deposited with U.S.  postal
service on that same day with postage fully prepaid at  Los
Angeles, California in the ordinary course of  business.  I
am aware that on motion of the-party served, service  is
presumed invalid if postal cancellation date or  postage
meter date is more than one day after date of deposit for
mailing in affidavit.

(BY PERSONAL DELIVERY) I caused such envelope to be
delivered by hand to the offices of the addressee.

(STATE) I declare under penalty of perjury under the laws
of the State of California that the above is true and
correct.

Ix]   (FEDERAL) I declare that I am employed in the offices of  a
member of this court at whose direction the service  was
made.

Executed on April 9, 1993, at Los Angeles, California.




(signature by)FARNAZ MORADPOUR

(0147)












PROOF OF SERVICE

STATE OF CALIFORNIA
SS.
COUNTY OF LOS ANGELES

I am employed  in the County of Los Angeles,  State  of
.California.  I am over the age of eighteen (18) years  and  not  a
party to the within action; my business address is:  221 North
Figueroa street, Suite 1200, Los Angeles, California  90012.

On April 9, 1993 I served the foregoing document(s)
described as DECLARATION OF STEVEN A. PIS      FILED IN  SUPPORT  Or
DEFENDANTS STEVEN FISHMAN AND UWE GEERTZ"S JOINT  NOTICE  Or  MOTION
AND MOTIONS TO (1) RECONSIDER tHE COURT'S MARCK  22,  1993  CH"GE  0
VENUE ORDER; (2) VACATE AND SET ASIDE THE  COURT'S  CKMGE  OF  VENUE
ORDER; AND (3) FOR EXERCISE OF THE  COURT'S  INHERENT  EQUITABLE
POWERS IN CONNECTION WITH THE COURT'S MARCH 22, 1993 CHANGE OF
VENUE ORDER on the interested parties in this action  by  placing  a
true copy thereof enclosed in a sealed envelope addressed as
follows:


Robert Wiener
BOWLES & MOXON
6255 Sunset Blvd., Suite 2000
Los Angeles, California 90028


(BY MAIL) I am "readily familiar" with  the  firm's  practice
of collection and processing correspondence by  inailing.
Under that practice it would be deposited with  U.S.  postal
service on that same day with postage fully prepaid  at  Los
Angeles, California in the ordinary course  of  business.  I
am aware that on notion of the party served,  service  is
presumed invalid if postal cancellation date or  postage
meter date is more than one day after date of deposit  for
mailing in affidavit.

[X)    (BY PERSONAL DELIVERY) I caused such envelope to be
delivered by hand to the offices of the addressee.

(STATE) I declare under penalty of perjury under the  laws
of the State of California that the above is true and
correct.

Ix)    (FEDERAL) I declare that I am employed in the offices of a
member of this court at whose direction the service  was
nade.

Executed on April 9, 1993, at Los Angeles, California.


(siganture by) MAURICE HUNTER


PROOF OF SERVICE

STATE OF CALIFORNIA
SS.
COUNTY OF LOS ANGELES

I am employed in the County of Los Angeles, State  of
California.  I am over the age of eighteen (18) years  and  not  a
party to the within action; my business address is:  221 North
Figueroa Street, Suite 1200, Los Angeles, California  90012.

On April 9, 1993 I served the foregoing document(s)
described as DECLARATION OF STEVEN A. FISHMA.N FILED IN SUPPORT  OF
DEFENDANTS STEVEN FISHMAN AND UWE GEERTZ'S JOINT ]NOTICE OF  MOTION
AND MOTIONS TO (1) RECONSIDER THE COURTIS MARCH 22, 1993 CHANGE OF
VENUE ORDER; (2) VACATE AND SET ASIDE THE COURT'S  CIWGE  OF  VENUE
ORDER; AND (3) FOR EXERCISE OF THE COURT'S  INHERENT  EQUITABLE
POWERS IN CONNECTION WITH THE COURT'S MARCH 22, 1993 CH"GE OF
VENUE ORDER on the interested parties in this action by  placing  a
true copy thereof enclosed in a sealed envelope addressed as
follows:


Robert Wiener
BOWLES '& MOXON
6255 Sunset Blvd., Suite 2000
Los Angeles, California 90028


(BY MAIL) I am "readily familiar" with the  firm's  practice
of collection and processing correspondence by  mailing.
Under that practice it would be deposited with U.S.  postal
service on that same day with postage fully prepaid at  Los
Angeles, California in the ordinary course of  business.  I
am aware that on motion of the party served, service  is
presumed invalid if postal cancellation date or  postage
meter date is more than one day after date of deposit  for
mailing in affidavit.

IX)    (BY PERSONAL DELIVERY) I caused such envelope to'be
delivered by hand to the offices of the addressee.

(STATE) I declare under penalty of perjury under the  laws
of the State of California that the above is true and
correct.

[XI    (FEDERAL) I declare that I am employed in the offices of  a
member of this court at whose direction the service  was
made.

Executed on April 9, 1993, at Los Angeles, California.


(not number stamped)

END OF DOCUMENT AS RECEIVED
-- 
Want to find out all about the SeCrEtSkRiPtUrEs of the cult of scientology?
               http://www.cs.cmu.edu/~dst/Fishman




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