AFFIDAVIT OF Mrs M B
I, M B, former schoolteacher, of [address], in the city of Portland, in the State of Oregon, OR [zip code], in the United States of America, MAKE OATH and say as follows:-
2. The facts deposed to herein are within my own knowledge save as where appears otherwise from the context.
3. It has come to my knowledge that in the Winter 1995 issue (Volume 3, Number 1) of the DIGNITY REPORT, published by the "Coalition for Human Dignity" (CHD), the following paragraph appeared on page 3:
Challenging anti-Semitism when British Holocaust-denier David Irving came to Portland, Oregon, to speak on October 10, 1994, CHD research exposed the criminal record of the young neo-Nazi leader responsible for organizing the speaking engagement and uncovered the clandestine site of the meeting &emdash;a Presbyterian church that
had been reserved under false pretenses. Working closely with community, civil rights and religious groups, including the Jewish Federation of Portland, Ecumenical Ministries of Portland and the American Jewish Committee, CHD organized a protest vigil, coordinated joint media statements and led follow-up education efforts.
4. The following are the true circumstances of the above event:
(1) It was not a "young neo-Nazi leader", but I, a middle-aged woman, not politically affiliated with either the left or right, who organized the event - in the defense of the exercise of free speech.
SWORN AT Portland, Or USA [signed M B]
this day of September 11, 1998
Before me, Michelle English, Notary Public-Oregon omission No. 0618998 [Official seal]
A Public Notary