Martin Garbus, Esq. (MG 6261) Edward Hernstadt, Esq. (EH 9569) FRANKFURT, GARBUS, KLEIN & SELZ, P.C. 488 Madison Avenue New York, New York 10022 (212) 826-5582 Attorneys for Defendants Eric Corley a/k/a Emmanuel Goldstein and 2600 Enterprises, Inc. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X UNIVERSAL CITY STUDIOS, INC., PARAMOUNT PICTURES CORPORATION,. METRO-GOLDWYN-MAYER STUDIOS INC., TRISTAR PICTURES, INC., COLUMBIA PICTURES INDUSTRIES, INC., TIME WARNER ENTERTAINMENT CO., L.P., DISNEY ENTERPRISES, INC., and TWENTIETH CENTURY FOX FILM CORPORATION, Plaintiffs, - against - ERIC CORLEY a/k/a "EMMANUEL GOLDSTEIN" and 2600 ENTERPRISES, INC., Defendants 00 Civ. 0277 (LAK) DECLARATION OF EDWARD HERNSTADT IN SUPPORT OF DEFENDANTS' OPPOSITION TO PLAINTIFFS' MOTION FOR A PROTECTIVE ORDER X I, EDWARD HERNSTADT, hereby declare under penalty of perjury that the following is true and correct. 1. I am associated with Frankfurt, Garbus, Klein & Selz, P.C. I have personal knowledge of the matters to which I attest herein, except where otherwise stated. 2. Attached hereto as Exhibit A is a MPAA press release dated November 9, 1999 about the "CSS hack," which asserts that it is "fairly useless" and that persons should not download DeCSS because the "individuals who enjoy creating and distributing viruses that can destroy hard drives and critical data." 3. Attached hereto as Exhibit B is the "Macrovision Analysis of the Recent DVD 'DeCSS' Hack," which states that the "hack as proven to be more difficult and complicated to use than the average consumer is willing to put up with" and that "Macrovision and most content owners do not anticipate any serious market effect" from the DeCSS utility. See http://www.macrovision.com/whats_new.html Dated: New York, New York June 19, 2000 __________________________________ EDWARD HERNSTADT