EXHIBIT 31
Case 2:OO—cv—O1118—NVW Document 111-3 Filed O3/28/2007 Page1 012
DECLARATION
of
GARY T. LOWENTHAL
1. 1 interviewed Winnie James in 2001 and 2002 at her home in Glendale. 1 was
present when Susan Cedar, an early childhood behavior specialist, interviewed her
0n another occasion in 2002.
2. l took notes during these interviews in 2001 and 2002, then drafted a
1 "Memorandum to the Steven James File," dated May 22, 2002, memorializing my
interview notes. The memorandum accurately described the information Mrs.
James provided during the three interviews.
3. l was also present when Dr. Jack Potts, a forensic psychiatrist, interviewed Mrs.
James in September 2005. l believe that Dr. Potts reviewed my May 22, 2002
memorandum, as well as a memorandum prepared by Bob Dauber (relating to a
1993 interview of Mrs. James), before Dr. Potts interviewed her.
1 declare under penalty of perjury that the foregoing is true and correct.
{ //0
Executed on { { " TL , 2007 LAP
GARY;51. WENTHAL
Case 2:OO—cv—O1118-NVW Document 111-3 Filed O3/28/2007 Page 2 of 2
Case 2:00-cv-01118-NVW
Document 111-3
Filed 03/28/2007
Page 1 of 2
Case 2:00-cv-01118-NVW
Document 111-3
Filed 03/28/2007
Page 2 of 2