1                DECLARATION OF PETER LADEFOGED

2         I, PETER LADEFOGED, declare and say:

3         1.   I am a Professor of Phonetics in the Department of

4     Linguistics at the University of California at Los Angeles.

5     I specialize in, among other areas of Phonetics, voice iden-

6     tification and have testified on many occasions as an expert

7     in this field. Attached to this declaration is a six page

8     curriculum vitae detailing my educational, professional and

9     publishing background and expertise.

10        2.   On January 6. 1983, I was asked to make a

11    comparison of two tapes entitled "1983 New Years Message"

12    with other tapes which are, I am advised, known to be the

13    voice of L. Ron Hubbard, in order to determine whether or

14    not the same person who made the "1983 New Years Message"

15    tapes also made the tapes known to be the voice of

16    Mr. Hubbard.

17        3.   The questioned tapes which I was to examine,

18    identified as the "1983 New Years Message" tapes, were two

19    in kind. One was identified as a high quality direct copy

20    of the original of this tape, and the second was identified

21    as a copy of the edited version of the same tape. (I am

22    told that these tapes are also known as Ron's Journal, or

23    R.J. #36.)

24        4.   The tapes to which I was to compare the questioned

25    tape were three tapes, identified to me as being the voice

26    of L. Ron Hubbard. These were: (1) LRH Voice On R.J. #28

27    tape (henceforth "Ron's Journal #28"), (2) "LRH at the First

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1 Standard Dianetics Graduation" tape (henceforth "Graduation 2 Lecture"), and (3) "LRH voice on TR. #2 Film" tape 3 (henceforth Training film voiceovers"). 4 5. 1 was informed that all of the tapes listed in the 5 above paragraph are known to be the voice of L. Ron Hubbard. 6 I was asked to ascertain whether the two voices on the ques- 7 tioned tapes of the original and edited "1983 New Years 8 Message" contains the same voice as the voice on the tapes 9 known to be Mr. Hubbard's voice, so that it would be 10 possible to say whether these two "1983 New Years Message" 11 tapes were also made by Mr. Hubbard. 12 6. During the period January 6-15, 1983, I 13 investigated all of these tape recordings using the faci- 14 lities of the U.C.L.A. phonetics laboratory. These facili- 15 ties include professional quality cassette recorders and 16 tape recorders, and a digital sound spectrograph that 17 enables me to select portions of a recording for copying and 18 for spectrographic analysis with a great deal of precision. 19 7. I have established that, apart from the addition 20 of some music, the "Edited 1983 New Years Message" tape is 21 indeed a copy of part of the "Original 1983 New Years 22 Message" tape. Thus, these two tapes are of the same voice, 23 with the edited tape containing a portion of the original 24 tape. This can be shown most readily by comparison of sound 25 spectrograms from the two recordings. For example, the 26 attached pair of spectrograms marked (1) and (2) in the 27 28 2
1 upper right hand corner show what are obviously identical 2 phrases in the two recordings. The timing of each sound is 3 exactly the same in each of the two recordings although the 4 overall speed of the original recording is slightly slower. 5 Thus, there are exactly 10 glottal pulses in each example of 6 the syllable "and", marked on the attached spectrograms. The 7 differences between the two tapes are only in that the 8 edited tape has been edited for public use. As a result of 9 this editing process, the "Edited 1983 New Years Message" 10 tape has a less high frequency spectrogram than the 11 "Original 19B3 New Years Message" tape. Another difference 32 between these two recordings is that all the distracting 13 noises, such as the speaker's intakes of breath and repeti- 14 tions of different versions, have been removed from the 15 "Edited 1983 New Years Message" tape. 16 8. Since it was apparent that the "Original 1983 New 17 Years Message" tape was the original tape made by the 18 speaker, I used that tape for my comparisons. I compared 19 the voice on the "Original" with the voice on other 20 recordings, principally with that on "Ron's Journal #28," and 21 with that on the "Graduation Lecture." in making the compa- 22 risons, I listened to large portions of these tapes a consi- 23 derable number of times. I also used the computer text 24 processing system at U.C.L.A. to produce alphabetized lists 25 of all the words in the "Original 1983 New Years Message" 26 tape and in the "Ron's Journal 128" tape, and thus was able 27 to find all polysyllabic lexical items (i.e., words other 28 3
1 than grammatical items such as "have", "and", etc.) that 2 occur in both recordings. I made copies of the phrases 3 containing these items, usually taking four repetitions of 4 the phrase from each recording and copying them onto another 5 tape, so that I could conveniently listen to them one imme- 6 diately after the other. I listened to each pair of phrases 7 a large number of times, on the order of 50 times each. I 8 also listened very carefully to the breathing patterns on 9 the "Original 1983 New Years Message" tape and on the 10 "Graduation Lecture" tape. 11 9. As a result of all of these comparisons, I was 12 able to form a professional opinion as to the degree of 13 similarity of the voices in question, insofar as this can be 14 determined by skilled listening. I have engaged in such a 15 procedure on many occasions in the past, and expressed an 16 expert opinion as a result of such a process on many 17 previous occasions. On the basis of this examination, it is 18 my opinion that the voice on the questioned "1983 Now Years 19 Message" tapes is the same as the voice on the other six 20 tapes which have been previously identified as the voice of 21 L. Ron Hubbard. 22 10. In expressing this opinion, I wish to advise the 23 court of the other possibilities which exist and discuss 24 them. There are only two other conceivable possibilities as 25 to the source of the voice on the questioned "1983 New Years 26 Message" tapes. The first is that it is conceivable that 27 this voice could be the voice of an immediate male relative 28 4
1 of L. Ron Hubbard, such as a father, a brother, or a son. I 2 am advised that the only two living male relatives of L. Ron 3 Hubbard who fit this category are Mr. Hubbard's son, Arthur 4 Hubbard, and the petitioner in this case, Ronald DeWolf. 5 Assuming that these are the only such living male relatives, 6 and further assuming that it is established that neither of 7 these men made this tape, then the possibility of a close 8 male relative can be completely discounted. 9 11. The other conceivable possibility is that the 10 voice on the "1983 New Years Message" tapes is that of a 11 very skilled imitator of the voices on the other tapes. 12 While I cannot totally exclude this as a possibility, it is 13 my opinion that the voice on the "1983 New Years Message" 14 tapes is not that of an imitator of the voice on the other 15 tapes. I base this opinion on the fact that in my 30 years 16 of study of the characteristics of different voices, I have 17 never heard a mimic who could produce an imitation this 18 close over such a long stretch of speech and with such 19 attention to detail in things not normally noticed, such as 20 the breathing patterns. 21 12. Aside from the analysis which I made above, based 22 upon listening to the tapes as I have described I have also 23 made a number of spectrograms of the words in the tape. 24 These spectrographic analyzes show that there are many close 25 similarities in the particular words in these recordings. 26 For example the word "prosperous" is pronounced on both 27 occasions with very similar voice onset times (slightly 28 5
1 shorter than those commonly used); it is also pronounced as 2 a two syllable word (i.e., leaving out the syllable "er"). 3 The word "people". which is spoken very rapidly on the tapes 4 in question, has very similar formant frequencies (the 5 acoustic correlates a vowel quality). The formant 6 frequencies are also very similar in the words "tech" and 7 "ethics", both of which appear on the two recordings. The 8 fricative sounds of the "s" in the word "research" are 9 nearly identical. 10 13. There are certain differences between some words 11 which appear on the "1983 New Years Message" tapes and on 12 the identified tapes. For example, the word "Scientology" 13 on "Ron's Journal #28" and the "Original 1983 New Years 14 Message" tape appear to be somewhat dissimilar. However, 15 these dissimilarities are to be expected and are no greater 16 than those which regularly occur when the same word is said 17 by the same person on two separate occasions. Thus, the 18 word "Scientology" on Training Film Voice Overs" is also 19 somewhat different from that on "Ron's Journal #28" and the 20 "Original 1983 New Years Message" tapes. The first half of 21 the word on "Training Films Voice overs" has formant 22 frequencies like those on the "Original 1983 New Years 23 Message" tape, and the second half has formant frequencies 24 more like that on "Ron's Journal #28." Taken all together, 25 the spectrographic evidence is consistent with and indepen- 26 dently supports my conclusions stated above. 27 28 6
1 14. In summary, assuming the accuracy of the facts of 2 which I have been advised and which I have previously 3 described, it is my opinion that the voice on the "1983 New 4 Years Message" tapes is that of L. Ron Hubbard. 5 I declare under penalty of perjury that the foregoing 6 is true and correct. 7 Executed at Los Angeles, California on February 12, 8 1983. 9
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10 PETER LADEFOGED 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 7 3E:DWLF:III:DCL:PL