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)









                           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)