AFFIDAVIT

BEFORE ME, the undersigned authority, personally appeared KENNAN G.

DANDAR, who after being first duly sworn deposes and says:

1. Affiant is an attorney and a member of the Florida bar since 1979, practicing civil litigation in the Tampa Bay area with offices located in Tampa, Florida, and is over the age of eighteen years.

2. Affiant represents the Estate of Lisa McPherson in a wrongful death case brought against the Church of Scientology Flag Service Organization, Inc. now pending in Pinellas County, Florida.

3. On or about the 25th day of July, 2000, the Church of Scientology Flag Service Organization, Inc. took the deposition of Ursula Caberta, a German government official vacationing in Florida, in the wrongful death case.

4. Affiant attended the deposition of Ursula Caberta.

5. Deposition questioning was conducted by Kendrick Moxon, Scientologist, and the attorney for the Church of Scientology Flag Service Organization, Inc.

6. At the conclusion of the deposition as Ms. Caberta was leaving, in front of Ms. Caberta, Ms. Caberta's counsel, John Merrett, and myself, Atty. Moxon not just once, but twice saluted Ms. Caberta with the "Hitler salute" of Nazi Germany and said "Hiel [sic] Hitler!" The gesture greatly upset Ms. Caberta and insulted her as obvious by the expression on her face, as well as the statements made to affiant.

7. Attached hereto as Exhibit A is an excerpt of the transcript where Affiant placed this information on the record of the deposition.

FURTHER AFFIANT SAITH NOT

[Signature] KENNAN G. DANDAR

Sworn to and subscribed before me this 21st day of May, 2001

[Signature] NOTARY PUBLIC

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