VICKI J. GREENE, hereby declares as follows:
1. Declarant is an attorney duly licensed to practice law in the State of California and attorney of record for Respondent in this dissolution proceeding. I have personal knowledge of the following facts and if called upon could and would testify compentently thereto. I submit the following in support of Respondent's request for relief:
2. On April 18, 2007, I appeared before this Court for the hearing on Petitioner's Motion. After that Motion was ruled upon in open Court, the Court obtained an ex parte application. However, over Petitioner's objection, the court closed the courtroom for the protection and privacy of the minor child (pursuant to Family Code 214) and conditionally sealed certain pleadings.
3. On April 19, 2007, Harvey Levin of TMZ.com, a celebrity online gossip website, admitted to me that he intended to publish a tape recording of a voice-mail message he had between Respondent and the minor child. He also told me that he obtained the tape from a source whom he would not disclose to me. He also told me he had information he believed came from the April 18 hearing. I told Mr. Levin that I had no idea what he had, but that what he purported to have had to have come from an improper source. I also told Mr. Levin that the court proceedings had been closed to the public and sealed.
4. I urged Mr. Levin not to go public with the tape recorded message and that the dissemination of what he claimed to have could result in Respondent taking legal action against him or TMZ.com.
5. During my conversation with Mr. Levin, I told him that it was my intention to send a letter to him confirming the subject of our conversation. He provided his address and fax number. A copy of my letter is attached hereto, incorporated herein by this reference and marked "Exhibit A".
Are you saying that leaking the tape of him abusing the child has the same moral weight as abusing the child?
Okay, but how does any of that make Baldwin less of a pathetic little man? Did he leave the voice mail message to his daughter or not?