Declaration of Carol Spooner

in Support of Plaintiffs’ Motion for Remand and for Costs

I, CAROL SPOONER, do declare:

1. I am one of the plaintiffs in this matter.

2. Over the past year my husband has extensively researched the governance structures of various non-commercial radio stations. To assist him in his research he and I have requested various radio stations to send us their corporate bylaws. Attached as "Exhibit A" is a true and correct copy of the bylaws provided to us by KQED, Inc., located in San Francisco, California. Attached as "Exhibit B" is a true and correct copy of the bylaws provided to us by KBOO Foundation, located in Portland, Oregon. Attached as "Exhibit C" is a true and correct copy of the bylaws provided to us by Back Porch Radio Broadcasting, Inc., licensee of radio station WORT located in Madison, Wisconsin. Attached as "Exhibit D" is a true and correct copy of the bylaws provided to us by Double Helix Corporation, licensee of radio station KDHX in St. Louis, Missouri.

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

____________________________________

CAROL SPOONER