UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

SUNIL EAPPEN, as administrator of
the estate of MATTHEW EAPPEN,

Plaintiff,

v.

LOUISE WOODWARD,

Defendant.

I, Fredric L. Ellis, on oath state and affirm that:

1. I am a member of the bar of the Commonwealth of Massachusetts, BBO #542075, and I represent the plaintiff, Sunil Eappen, as administrator of the Estate of Matthew Eappen ("Plaintiff"), in the above-captioned lawsuit.

2. Attached as exhibits to this affidavit are copies of published reports obtained as a result of a search of published databases, including newspapers and wire service reports.

3. Attached as Exhibit A to this affidavit is a copy of an article published in The Boston Globe on November 26, 1997, which reports that Louise Woodward and her family "were asked to sign over most movie and book rights ... to an affiliate of EF Au Pair, the agency that placed her in the United States, ... ."

4. Attached as Exhibit B to this affidavit is a copy of an article published in The Boston Globe on November 27, 1997, which reports that Louise Woodward issued a statement in which she recognized fully her "moral obligation to repay EF Au Pair to the extent [she is] able, and this moral obligation has naturally been the subject of informal discussions between my family and EF Au Pair."

5. Attached as Exhibit C to this affidavit is a copy of an article published in The Patriot Ledger on November 27, 1997, which reports that Louise Woodward "turned down six-figure offers for interviews ... ."

6. Attached as Exhibit D to this affidavit is a copy of an article copyrighted by Associated Newspapers Ltd. (England) and appearing on December 14, 1997, which reports that $200,000 in donations raised by supporters of Louise Woodward has been transferred to "The Louise Woodward and Family Trust" and that the trust funds "[i]nitially ... will provide travelling and living expenses for Louise and her parents and family."

7. Attached as Exhibit E to this affidavit is a copy of an article copyrighted by MGN, Ltd., and published in the The Mirror of London on May 29, 1997, which reports an allegation made by Louise Woodward's attorney, Elaine Whitfield-Sharp, that Louise Woodward and her mother, Susan Woodward, have "negotiated secret book and newspaper deals."

8. Upon information and belief, Louise Woodward is now free to return to England, as both her criminal sentence and her visa have expired. Accordingly, because of the urgency of this matter and because the complaint was not filed (or possible) until today, I have not previously conferred with Woodward or any attorney on her behalf concerning Plaintiff's motion for preliminary injunction.

Signed under the pains and penalties of perjury this 16th day of June, 1998.

Fredric L. Ellis