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scratch. might f you subpoe qoud I ali conducive to my ad qnoqr protect? Certainly no inmate. 161 There are many other r inmates who were present at the Soledad Training Facility who possess information heip- ful and necessary to the defense of laintiffs. The and conduct of the defendants have' so intimidated them. parole if they give testimony for the plaintiffs at the trial of the cause referred to herein. lt In an effort to obtain truthful testimony for the plaintiffs, and to afford some protection to inmate witnesses, attached hereto and made a part hereof are Exhibits D and E which represent the corresp ndence referred to; the State Bar of California indicated its refusal to assist in the protection of witnesses in any way as appears more particu- larly from said Exhibits. 18. Because of the acts and conduct of defendants above described, testimony on behalf of plaintiffs may b or is forever lost; testimony which may be available is 11