Gerald L. Chaleff, SBN 39552
ORRICK, HERRINGTON & SUTCLIFFE LLP
777 South Figueroa Street, Suite 3200
Los Angeles, California 90017-5832
Telephone: (213) 629-2020

William T. Drescher, SBN 93737
LAW OFFICES OF WILLIAM T. DRESCHER
PMB 338
23679 Calabasas Road
Calabasas, California 93102-1502
Telephone: (818) 349-8100

Attorneys for Non-Party
CHURCH OF SCIENTOLOGY INTERNATIONAL

Samuel D. Rosen, pro hac vice
PAUL, HASTINGS, JANOFSKY & WALKER LLP
399 Park Avenue, 31 st Floor
New York, New York 10022-4697
Telephone: (212) 318-6000

Alan K. Steinbrecher, SBN 79201
PAUL, HASTINGS, JANOFSKY & WALKER LLP
555 South Flower Street, 23rd Floor
Los Angeles, California 90071-2371
Telephone: (213) 683-6000

Attorneys for Non-Party
RELIGIOUS TECHNOLOGY CENTER

SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES

I, NEIL LEVIN, declare and state:

1. I am the President of Church of Scientology of California ("CSC"), the defendant in this action. I was a staff member of CSC from 1984 through 1992. I have served as CSC's President since 1993.

2. Auditing is one of Scientology's core religious practices. It is a form of one-to-one counseling that is conducted in a precise manner strictly in accordance with the Scientology Scripture and under the ethical guidelines of the Auditor's Code. The person receiving auditing is called a pre-clear, abbreviated as "pc." The "pc file" is a confessional formulary and contains a record of the parishioner's spiritual progress through his or her auditing. The pc file is maintained in strictest confidence by the auditor and the church.

3. In June 1985, approximately two weeks before this case was scheduled for trial, Wollersheim's counsel moved to have CSC produce his pre-clear file at trial. CSC opposed Wollersheim's attempt to compel the disclosure of the priest-penitent material contained in these files despite the fact that this material could have helped CSC to discredit Wollersheim as a witness during trial.

4. Wollersheim's motion was granted and CSC was ordered to produce his pre-clear files. (A true and correct copy of the Order is attached as Exhibit A.) The trial transcript confirms that the requested files were turned over to the Court. A banker's box containing Wollersheim's pre-clear files was turned over to Judge Swearinger who later stated in court, "I have been through them twice." He in turn provided Wollersheim's counsel with the opportunity to review them. (A true and correct copy of the relevant pages is attached as Exhibit B.)

5. CSC gave Judge Swearinger the originals (not copies) of Wollersheim's pre-clear files and they have remained in the custody of the Court ever since. CSC has retained a copy of the files it produced, which consists of approximately 2,000 pages.

I declare under penalty of pedury under the laws of the State of California that the foregoing is true and correct.

Executed this 19th day of September 1999 at Los Angeles, California.

Neil Levin