DECLARATION OF LYNN R. FARNY I, Lynn R. Farny, hereby declare: 1. I am over the age of eig

                                DECLARATION OF LYNN R. FARNY

       I, Lynn R. Farny, hereby declare:

       1.     I am over the age of eighteen and a resident of Los
Angeles, California. I have personal knowledge of the facts set forth
below, and if called upon to do so, could and would testify competently
thereto.

       2.     On Monday, March 6, 1995, 1 discovered some messages from
Dennis Erlich on the alt.religion.scientology newsgroup (public
discussion group) on Usenet which is one of the networks comprising the
Internet. I downloaded one of Erlich's messages which is attached
hereto as Exhibit A.

       3.     To verify if this message existed on Netcom's databases, I
logged on to Netcom's system and typed a command which provided a path
directly to the alt.religion.Scientology newsgroup.  Once in that
newsgroup, I saw a long list of dozens of messages to which I could
obtain access. I located the one from Dennis Erlich identified in
paragraph 2 above and downloaded it to a disk, and then printed it off.
A true and correct copy of that print-off is attached hereto as Exhibit
B.

       4.     On the same date, I also accessed Tom Klemesrud's L.A.
Valley College BBS (support.com). In that system, I followed the prompts
from the Main Menu, which provided me a list of the 'alt." newsgroups
available on that BBS.  The list included alt.religion.Scientology,
which I then accessed.  Again, I scrolled down the dozens of messages
available, found the same message from Dennis Erlich, downloaded it to a
disk and then printed it off.  A true and correct copy of that print-off
is attached hereto as Exhibit C.

       I have compared all three messages and have found the text of all
three to be identical, except for the material at the top of each
message showing the routing of the message, which is different for each
computer system.

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

       Executed at Los Angeles, California the 7th day of March 1995.

                                    /s/ Lynn R. Farny