1. I have personal knowledge of the facts stated in this declaration unless stated on information and belief. If called upon to testify to these facts I could and would competently do so.

2. I reside in Hallandale, Florida.

3. I was acquainted with Steven Fishman from 1976 through 1988. Subsequently, Fishman was convicted of mail fraud and obstruction of justice and I was convicted of mail fraud for my actions in assisting Fishman in a stocks scam. I have not seen Steven Fishman since.

4. I first became involved in Fishman's mail fraud activities in late 1983, after my father's death, when Fishman asked me to help him out by signing a paper for one of his purported clients that he claimed had to be in the mail by the next morning. Fishman said that he didn't want to go out to Pompano where this client was supposed to live at that time and he didn't want to wait for the person to come there. The paper involved some kind of litigation which I didn't understand. Although I thought his request was odd, I signed the paper.

5. At the time of this first transaction, Fishman was working for a stock company, which I believe was Merrill Lynch, under a man named Hank. Fishman was acting as an investment counselor and based upon his large home and extravagant lifestyle, I thought that he had credibility. I thus invested approximately $10,000 of my father's inheritance money with Fishman which was later lost.

6. During the 1983 time period, I signed two or three similar documents for Fishman. I didn't realize until the end of 1984 that I had been assisting Fishman in a criminal scam. At that time, Fishman started explaining the scam to me and what he had actually done. It essentially involved Fishman sending in backdated verifications of stock purchases by fictitious names, for the purpose of making them plaintiffs in class action suits advertised in the Wall Street Journal. He obtained these forms from his job as a stock broker. He would send in the forms, then wait for the case to come to trial and payments to be disbursed to these fictitious plaintiffs. He told me that some money would be coming to me for what I had signed for him back in 1983. He described the scam as stealing pennies from insurance. At that time I was co-dependent on Fishman who was driving me around in a Cadillac, taking me out to eat, and giving me work. So I continued cooperating with his activities.

7. Fishman described himself to me as a “farmer.” He said that he planted the seeds, nurtured them and they grew eventually. I was one of his “seeds.” Another thing that Fishman told me is that it was important in perpetuating his deception and fraud that every lie had to have some aspect of truth in it.

8. A primary part of Fishman's scheme was the creation of false identities who could receive the final class action settlement checks at actual addresses. He did this by filling out subscription cards for magazines and mailing lists with fictitious names, using his and others' addresses. The postman would then get used to delivering mail to the name care of that address. Then when the checks arrived for that name, the postman would deliver it without question. Fishman would then put in a change of address for the fictitious name after the check had come. He would often act in collusion with the person whose address was used by the fictitious person.

9. On various occasions I signed documents for Fishman at different addresses that he had. Two such names I signed were Murray Leeds (a fictitious name) and Edward P. Solomon.

10. Edward P. Solomon was a black man Fishman met who was a pimp for a prostitute named Mary, whom Fishman was seeing. This occurred around 1985. I signed Edward Solomon's name on some initial paperwork for a transaction, but never saw the check which presumably came in at a later time.

11. When I was arrested, the FBI showed me the records they had concerning Fishman's stock scam. There were several transactions I remember which they didn't have records of. I believe the FBI's records showed that Fishman made between 2 and 2 1/2 million dollars off the stock scam. My recollection is that he made closer to 4 million dollars. Also I know that the scam started earlier than what the FBI had records for. I think that for two years Fishman had money coming in from the scam which the FBI didn't know about. I have no knowledge of what Fishman did with the money that the FBI didn't locate.

12. Fishman used to keep his money in corporate accounts, as they were harder to trace than personal accounts. I don't know where those accounts were, but I know that his father's shoe business, Cyprus Shoes, established many corporate accounts during the time I knew Fishman.

13. There was a time when Fishman used to pick up lists of names and social security numbers from employment agencies and from schools for summer employment at his father's shoe store, Cyprus Shoes.

14. Although Fishman's father, Jack Fishman, had knowledge of and involvement in Fishman's stock frauds, he was not prosecuted. The reason the FBI didn't prosecute him was because Fishman got a class one attorney who convinced authorities that his father was an old man with ulcers who shouldn't be put away.

15. Fishman told me that his long time psychologist, Uwe Geertz “was paid to give him an excuse.” I recall one time when Fishman was discussing how mad he was at his wife Jaime, he told me that he could get away with killing her because he had a psychologist establishing that he was insane. The impression I got from hearing Fishman discuss Geertz was that Geertz was basically treating Fishman for anything at all so that he could collect whatever insurance monies were available from Fishman's carrier.

16. Fishman's former wife Jaime, who is since deceased, had knowledge of Fishman's stock scam, as, for one thing, she was in the room and watched me sign the first transaction.

17. Jaime initiated divorce proceedings against Fishman before he was arrested, claiming that Fishman was abusive, perverted, and had engaged in criminal acts.

18. Fishman had a self-professed sexual attraction towards children. He had a collection of child pornography books in his home. After a trip to Korea, he related to me that he had sexually indulged with Korean children. I had one conversation with Fishman in which he told me that he'd picked up a 15 year old male prostitute. I know that he had a relationship with a 16 year old prostitute named Dusty Hipps.

19. Although Fishman was often abusive on the phone to Jaime in front of me, I believe this was a show that was staged for my benefit in order to document his “abuse” of her and bring about an uncontested divorce.

20. Once the divorce between Jaime and Fishman was final, Jaime took possession of the house and proceeded to “wash out” some of the the money that Fishman made through his scam. She sold the house for a profit, bought and sold other houses, and eventually ended up back in the Davie area, where she had originally come from.

21. I think that Jaime and Steve Fishman were aware of the fact that Fishman's scam had been compromised before he got arrested and arranged the divorce so that she could continue to have control over some of the assets.

22. My first introduction to the Church of Scientology was in 1985 when a woman named LaVenda Van Schaick visited Fishman at my house and discussed her earlier involvement with the Church. She gave negative information on the Church to Fishman. Although I didn't pay close attention to the conversation between Fishman and her, I later found out that she had sued the Church of Scientology and had settled out of court. To my knowledge, this was also Fishman's introduction to Scientology, as he had never mentioned the subject to me before that time.

23. Around the time of his affiliation with LaVenda Van Schaick, Fishman became involved with the Scientology Church in Coral Gables. He bought a library of Scientology books which he kept in his condo, took a couple courses and attended their public events at hotels in the area. He tried to interest me in the Church or wanted to appear to try to get me interested and took me to a couple of their public events. I got the impression that Fishman's interest in Scientology and his efforts to get me into Scientology were other trails he was creating, similar to the false identity, “Simon Lantos” which he set up at his house, as an illusion to throw people off. Scientology was something for Fishman to blame down the road by saying that Scientology put him up to it if and when he got caught on his stocks scam.

24. A few months ago, I called Patrick Salt, who runs a plumbing business in Dade, as I needed plumbing work. Salt had been a mutual friend of Fishman and mine before Fishman went to jail. Patrick Salt informed me that Fishman was out of prison, that he had met Fishman in Miami Beach a few months ago and Fishman had told him I was “underground” (which means dead). I took this as a death threat of sorts.

25. In the many years I was associated with Steven Fishman, I never knew him to acquire money through any means other than illegal scams, other than his notary work, and commission for stockwork, or to live anything other than an extravagant lifestyle. I doubt that this has changed and suspect that he still has money hidden away from his stocks scam in his ex-wife's assets, with his father or in some other hiding place.

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.

Executed this 10 day of July, 1994 at Hnd, Florida.

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STEVEN GOLDBERG