Affidavit By Expert Witness Joseph Farah
on Jay Campbell and Kirk Lane
vs.
Citizens for Honest Government, Inc., d/b/a Integrity Films;
Jeremiah Films, Inc., and Pat Matrisciana

May 28, 1998

Joseph Farah is an author, veteran newsman and media consultant. His company, Farah & Associates, has included among its varied individual and corporate clients the Herald Tribune, Jacobs Engineering Inc., New World Entertainment, the Institute for Contemporary Studies and NBC. His latest book, "This Land Is Our Land," a history of property rights co-authored with U.S. Rep. Richard Pombo (R-CA), was released by St. Martin's Press in the fall of 1996. Earlier, he collaborated on the best-selling non-fiction book of 1994, Rush Limbaugh's "See, I Told You So.

The former editor of the Sacramento Union, then the oldest daily newspaper in the West, founded and edits WorldNetDaily.com, an Internet daily newspaper, as well as Dispatches, the bi-weekly national investigative newsletter. Both are projects of his Western Journalism Center, a non-profit, tax-exempt foundation promoting journalism education and investigative reporting, for which Farah serves as executive director.

Farah has 20 years of experience as a daily newspaperman. Prior to his time at the helm of The Union, Farah was executive editor of the Glendale Newspapers, a group of dailies and weeklies in Southern California. He also served as executive news editor of the Los Angeles Herald Examiner, running the news department of that metropolitan daily for more than six years. Farah has taught journalism at the University of California Los Angeles.

He has written for the Los Angeles Times, Wall Street Journal, Boston Globe, the San Francisco Chronicle, San Francisco Examiner, Orange County Register, the Sacramento Bee, National Review, Reason, TV Guide and dozens of other national and regional publications.

In 1996, Farah received the first Washington Times Foundation's National Service Award for his work creating the Western Journalism Center. In 1994, he was honored by the American-Swiss Foundation as one of 20 "Young Leaders" who traveled to Europe to meet with distinguished counterparts for a week of intense and spirited dialogue. He has also collected awards for headline writing from the Hearst Newspapers, for honesty in journalism, for writing and editing and for newspaper design.

Farah has served as an expert witness in several high-profile First Amendment cases, including Selleck vs. the Globe. His expertise is in journalistic standards and practices and his testimony in this case will be limited to that specialty.

Having reviewed the video documentary "Obstruction of Justice" and the depositions provided in the above-named case, Farah concludes the producers of the video acted well within the confines of accepted journalistic standards and practices.

"Obstruction of Justice" is clearly an effort to provide Linda Ives, a nationally recognized expert and activist with regard to the case of "the boys on the tracks," a platform to have her say. The video story is not substantially different than the one Linda Ives was permitted to tell in the pages of the Wall Street Journal and elsewhere in the print media. But the video medium can sometimes be more compelling, more shocking.

The producers of the video have, in effect, provided Linda Ives and Jean Duffey a soapbox -- a great American institution. The information conveyed in the film is readily available in other forms -- on the Internet, in talk radio discussions around the country and in alternative news journals. What the producers did was simply to take this information to a new medium.

Furthermore, it is clear that the producers made every effort to verify and substantiate the claims of Ives and Duffey. Law enforcement records and interviews were used to confirm the essence of the story wherever possible.

It is also clear that the producers of the film, as well as the participants in its making, absolutely believe their work represents the truth about the deaths of Don Henry and Kevin Ives.

Furthermore, it is important from a First Amendment perspective to remember that the subject matter of this video documentary is very serious -- the deaths of two young boys. As a veteran investigative reporter myself, and the executive director of an organization of investigative journalists, I believe the circumstances of these deaths have been covered up by government officials.

The very first responsibility of a free press in a free society is to serve as a watchdog on government fraud, waste, abuse, corruption and cover-up. If journalists must fear frivolous lawsuits from government officials for such critically important reporting, then our republic will not long remain free. The Founding Fathers repeatedly emphasized the important role played by the press as a "Fourth Estate."

For this reason, journalists have traditionally been given wide latitude in making allegations and raising charges that may reflect negatively on government officials. It is my assessment, based on my review of the case and the video, that the producers were well within their First Amendment-protected rights. In addition, from all indications, they seem to have upheld the highest journalistic standards and practices in their search for the truth.

I swear under penalty of perjury under the laws of California that the facts in this affidavit or" true.

[Signature]
Joseph Farah, Rancho Cordova, CA, May 28, 1988

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