1. That the representations to the Federal Communications Commission on document Nos.1.a, 2, and 3.a., attached, certified as true by David Salniker on December 23, 1987, May 10, 1988, and March 30, 1990, respectively, that certain Pacifica Directors were appointed or elected by Pacifica station boards, were in fact true.

2. That the representations to the Federal Communications Commission, on document Nos. 4.a., 5.a. and 5.b., 6.a., 8.c., 10.c., 11.c., 12.a., and 14.d., attached, certified as true by David Salniker, Patricia Scott, and Lynn Chadwick, respectively, that all Pacifica directors were elected or appointed by the Pacifica National Board, were in fact false.

3. That no Bylaw amendment altering the voting rights of Pacifica station boards was adopted by the Pacifica National Board between March 30, 1990 and August 9, 1991.

4. That the Bylaw amendment purportedly adopted by the Pacifica Board of Directors on February 9, 1991, which added a final sentence to Article Three, Section 2, Election Of Directors, which reads as follows: "Each station board shall nominate at least one person of color as a permanent representative to the National Board," was never approved by a vote of any Pacifica station board.

5. That the following Bylaw amendments purportedly adopted by the Pacifica Board of Directors, on September 28, 1997, were never approved by a vote of any Pacifica station board:

6. That the following Bylaw amendment purportedly adopted by the Pacifica Governing Board on February 28, 1999, was never approved by a vote of any Pacifica station board: