Editing Steven Fishman (section)

==Libel case==
{{main|Fishman Affidavit}}
In 1991, while Fishman was still incarcerated, ''[[Time (magazine)|Time]]'' magazine published a [[The Thriving Cult of Greed and Power|highly critical cover story]] on Scientology by [[Richard Behar]]. The story mentioned Fishman's fraud conviction and the alleged plot to eliminate him and Geertz.<ref name="behar"/> The church responded by filing [[libel]] lawsuits against [[Time Warner]], Behar, and Fishman and Geertz jointly.

In support of his contention that he had been [[brainwashing|brainwashed]] and ordered to murder Geertz, Fishman attached a series of documents to a motion to reconsider [[Venue (law)|venue]]. This filing has since become known as the [[Fishman Affidavit]]. It included purported Scientology documents describing obstructionist tactics to use in the event of an arrest, as well as versions of [[Operating Thetan]] levels I through VII and purported excerpts of [[OT VIII]]. Fishman's filing placed the advanced materials on record at the district court, available for viewing by the general public. Despite an unsuccessful church motion to [[record sealing|seal]] the court record and efforts to keep the court files continuously checked out, former Scientologist [[Arnaldo Lerma]] obtained the affidavit and posted it on the [[internet]], after which it spread uncontrollably. In the process of suing Lerma for [[copyright infringement]], the church confirmed that the copies of levels I through VII were accurate.

A federal district court [[summary judgement|summarily dismissed]] the church's claims against Time Warner and Behar, finding that they had not acted with [[actual malice]] insofar as the church was concerned. The church dropped its claims against Fishman and Geertz after Geertz's legal team served [[subpoena]]s upon such Scientologist celebrities as [[Kelly Preston]], [[Juliette Lewis]] and [[Isaac Hayes]].<ref name="ortega">{{cite web |first=Tony |last=Ortega |author-link=Tony Ortega |title=Double Crossed |date=December 23, 1999 |work=[[Phoenix New Times]] |url=https://www.phoenixnewtimes.com/news/double-crossed-6431852 <!--reprint version omits original photographs--> |url-status=deviated |archive-url=https://web.archive.org/web/20070312025501/http://www.phoenixnewtimes.com/1999-12-23/news/double-crossed/full |archive-date=March 12, 2007 |accessdate=2008-05-17}}</ref> The court record in the Fishman case remained open to the public.