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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)
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