Subject: From the Grady Ward archive, DECLARATION OF CHERYL NELSON

DECLARATION OF CHERYL NELSON

I, Cheryl Nelson, declare as follows:

1. I am over the age of 18 years and a resident of Los Angeles County. I have knowledge pertaining to the instant action and if called upon to be a witness, 1 could and would competently testify thereto.

2. I was employed as a legal secretary by the law firm of Paul, Hastings, Janofsky & Walker, LLP ("Paul, Hastings"), between April 27, 1953, and October 10, 1998.

3. During the course of my employment as a legal secretary with Paul, Hastings I had conduct with many levels of personnel. One in particular was Mike Fort, court services specialist.

4. Mr. Fort informed me, sometime during the summer of 1998, that certain attorneys at Paul, Hastings had a practice of instructing him to persuade the court clerks to backdate Paul, Hastings documents that were given to him untimely to file, so that the documents would appear timely filed. He did not name which attorneys participated in this practice.

5. Mr. Fort further told me that he did not like this practice and that in an effort to discourage the practice (without losing his job), he told the relevant attorneys that it would cost $300 each time for him to accomplish this. However, his tactic backfired when the involved attorneys willingly paid the money.

6. Mr. Fort did not say whether he kept the money or if he gave the money the court clerks to accomplish the backdating of the unlimely documents.

I declare under penally of perjury under the laws of the Stale of California that the foregoing is true and correct to the best of my knowledge.

Executed this 9th day of December, 1998, at Los Angeles, California.