I, M B, former schoolteacher, of [address], in the city of Portland, in the State of Oregon, OR [zip code], in the United States of America, MAKE OATH and say as follows:-

2. The facts deposed to herein are within my own knowledge save as where appears otherwise from the context.

3. It has come to my knowledge that in the Winter 1995 issue (Volume 3, Number 1) of the DIGNITY REPORT, published by the "Coalition for Human Dignity" (CHD), the following paragraph appeared on page 3:

Challenging anti-Semitism when British Holocaust-denier David Irving came to Portland, Oregon, to speak on October 10, 1994, CHD research exposed the criminal record of the young neo-Nazi leader responsible for organizing the speaking engagement and uncovered the clandestine site of the meeting &emdash;a Presbyterian church that

had been reserved under false pretenses. Working closely with community, civil rights and religious groups, including the Jewish Federation of Portland, Ecumenical Ministries of Portland and the American Jewish Committee, CHD organized a protest vigil, coordinated joint media statements and led follow-up education efforts.

4. The following are the true circumstances of the above event:

(1) It was not a "young neo-Nazi leader", but I, a middle-aged woman, not politically affiliated with either the left or right, who organized the event - in the defense of the exercise of free speech.

(2) I disclosed the name of the speaker, David Irving, to the church officials in writing in advance, thus there were neither false pretenses nor anything clandestine about the meeting.

(3) The CHD demonstration, organized and attended by Mr. Mozzochi, was anything but peaceful. The demonstrators screamed and hollored, intimidating and frightening a number of attendees. One couple, who had driven all the way from Vancouver, British Columbia, were accosted on the sidewalk and dared not walk to the entrance. One of the CHD demonstrators went as far as spitting into Mr. Irving's face, as he approached the building from the parking lot. Mr. Mozzochi made no attempt to make this protest a peaceful demonstration, let alone a "vigil."

(4) To my certain knowledge Ecumenical Ministries was not involved in the CHD demonstration.

SWORN AT Portland, Or USA    [signed M B]

this day of September 11, 1998

Before me, Michelle English, Notary Public-Oregon omission No. 0618998 [Official seal]

A Public Notary