Dr. Uwe Geertz

central district of californiaDefendent Pro SeGRAHAM E. BERRYJUDITH M> TISHKOFFLEWIS, D'AMATO,BRISBOIS & BISGAARD221 North Figueroa Street, Suite 1200Los Angeles, California 90012Attorneys for the Defendant,UWE GEERTZ, Ph.D

UNITED STATES DISTRICT COURT
...
) MOTION AND MOTIONS TO (1)STEVEN FISHMAN and UWE GEERTZ, ) RECONSIDER THE COURT'S MARCH ) 22, 1993 CHANGE OF VENUE ORDER;

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 StevenFishman and Uwe Geertz will shortly be filing a joint notice ofnotion and motion for reconsideration of this court's March 22, 1993order 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.
...
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.
...
Fishman, Geertz and certain witnesses in Los Angeles.
...
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.

Time: 10:00 a.m. Courtroom: 7 STEVEN FISH AND UWE GEERTZ, Defendants.
...
2. I have been retained as an expert consultant and expert witness by Dr. Geertz's counsel in the case captioned Church cf Scientology International v. Steven Fishman and Uwe Geertz, No. CV 91-6426-HLH (Tx) currently pending in the United States District Court, Central District of California.
...
2. I have been retained as an expert consultant and expert witness by Dr. Geertz's counsel in the case captioned Church cf Scientology International v. Steven Fishman and Uwe Geertz, No. CV 91-6426-HLH (Tx) currently pending in the United States District Court, Central District of California.
...
3. This declaration is submitted in support of defendant Dr. Uwe Geertz's motion for costs, attorneys' fees and sanctions.
...
It is my opinion that Fishman was the victim of Black Dianetics and was only saved, by the intervention of Dr. Geertz, from an imminent suicidal incident.

Time: 10:00 a.m. Courtroom: 7 STEVEN FISH AND UWE GEERTZ, Defendants.
...
2. I have been retained as an expert consultant and expert witness by Dr. Geertz's counsel in the case captioned Church cf Scientology International v. Steven Fishman and Uwe Geertz, No. CV 91-6426-HLH (Tx) currently pending in the United States District Court, Central District of California.
...
2. I have been retained as an expert consultant and expert witness by Dr. Geertz's counsel in the case captioned Church cf Scientology International v. Steven Fishman and Uwe Geertz, No. CV 91-6426-HLH (Tx) currently pending in the United States District Court, Central District of California.
...
It is my opinion that Fishman was the victim of Black Dianetics and was only saved, by the intervention of Dr. Geertz, from an imminent suicidal incident.