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a rae so ne i , letter, a copy of which is attached hereto and is marked "Exhibit A' the effect of which procedure was a further designed intimidation of prospective witnesses for the piaintiffs. . : 16d Ninety percent of the inmates to whom the form referred to in the preceding paragraph was submitted, because of fear for their personal safety at the hands of defendants, and because of fear of the possibility of having ~ their paroles denied because of known and threatened repri- sals by defendants, refused to indicate a willingness to be interviewed by counsel for plaintiffs; counsel for plein- tiffs, nevertheless, pursued their duty to interview such inmates, and of some 40 such inmates interviewed, 38 gave information to counsel for plaintiffs which ids relevant for plaintiffs' defense; during such interviews counsel for plaintiffs were told that inmates did not want to sign tne form submitted by prison officials because they were afraid that if they did so, their chances for parole would be ended, and that they were in fear for their safety and lives; some ‘of the inmates so interviewed reported that they have been kept in maximum security facilities since the death of John V. Mills, without disciplinary charges having been brought against them; several inmates who possess information which is relevant and helpful for the defense of plaintiffs, have been told by defendants that if they offer helpful informa- tion to the plaintiffs or their counsel, they (the inmates) will not leave prison alive; as one inmate wrote to counsel for one of the plaintiffs, I was in Y wing in Soledad when officer Mills died and I know some things that are helpful... One of the reasons why I aid -7- 4