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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
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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
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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
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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.