Declaration of Daniel Robert Bartley

in Support of Plaintiffs’ Motion for Remand and for Costs

I, DANIEL ROBERT BARTLEY, do declare:

1. I am the attorney for plaintiffs in this matter, and I am admitted to practice before this Court.

2. Attached as "Exhibit A" are true and correct copies of the proofs of service of the Summons and Complaint served upon defendants Pacifica Foundation, Mary Frances Berry, Leslie Cagan, Valrie Chambers, Ken Ford, Bertram Lee, Beth Lyons, Frank Millspaugh, Tomas Moran, John Murdock, Rob Robinson, Micheal Palmer, and Karolyn van Putten, on September 17, 2000, at Arlington, Virginia.

3. I served the Summons and Complaint by certified mail, return receipt requested, upon defendants Pete Bramson and Aaron Kriegel on September 22, 2000. Attached as "Exhibit B" is a true copy of the return mail receipt signed by Pete Bramson on September 23, 2000. I have not received a return mail receipt signed by Aaron Kriegel as of this date.

4. On or about October 13, 2000, I received telephone calls from legal counsel for defendants Tomas Moran, Pete Bramson, Leslie Cagan, Rob Robinson and Aaron Kriegel, each of whom requested a two-week extension of time to file responsive pleadings in the state court, which extension was granted to them.

I declare under penalty of perjury under the laws of the state of California that the foregoing is true of my own personal knowledge. Executed at Novato, California, this 26^th day of October, 2000.

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DANIEL ROBERT BARTLEY