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venue
---
title: "Fishman Declaration — venue"
source: https://www.cs.cmu.edu/~dst/Fishman/Declaration/venue.html
retrieved: 2026-06-28
---
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