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DECLARATION OF G. DONALD GALE I, G. Donald Gale, state under criminal penalty of the State of Utah that the following is true and correct: 1.

I am over 18 years of age, and I make this declaration based on my personal knowledge.

2.

I have been a professional journalist for over 40 years. I was for many years an executive and commentator for KSL radio and television in Salt Lake City, Utah.

3.

I have written and broadcast six thousand on-air commentaries for KSL, more than two hundred newspaper columns, a thousand speeches, four television documentaries, and countless reports, booklets, and brochures. I was awarded a Ph.D. in communication by the University of Utah and an honorary doctorate by Southern Utah University. I taught journalism at the University of Utah and Weber State University. I was president of the National Broadcast Editorial Association and am an honorary Life Member of the National Council of Editorial Writers. I am founder and president of Words, Words, Words, Inc.

4.

Prior to my retirement, I was Vice President for News and Public Affairs at Bonneville International Corporation. For 22 years, I wrote, produced, and broadcast daily editorial comments for KSL -- six thousand editorials, a million and a half words. My editorials earned state, regional, and national honors.

5.

Over the more than 40 years of my journalism career, I have interacted with literally thousands of consumer of news in Utah, including thousands of readers of both the Salt Lake Tribune and the Deseret News.

6.

I am member of the Utah Broadcasters Hall of Fame.

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7.

I continue to be involved in professional journalism by submitting editorials to the Salt Lake Tribune.

8.

I am familiar with the two local daily newspapers that are read in the Salt Lake Valley, the Salt Lake Tribune and the Deseret News.

9.

I recently wrote an opinion editorial in the Salt Lake Tribune. It is attached to this declaration as Exhibit A. The editorial accurately reflects my views regarding the importance  of  the  Salt  Lake  Tribune’s  contribution  to  Utah  society  and  diversity.

10.

I have not been asked to review any of the pleadings in this matter and state no opinion or conclusion regarding the allegations made therein.

11.

The  Tribune  is  Utah’s  most  important  written news organization for reporting on civil rights and governmental conduct.

12.

If Utahns were to lose access to the type of local news coverage now undertaken by the Tribune it would seriously weaken public awareness of critical local issues, such  as  the  ongoing  investigations  into  Utah’s  former  Attorney  General.

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13.

If local events in the Salt Lake Valley and Utah were covered only by a sectarian daily newspaper such as the Deseret News, Utahns would have limited access to a professional, objective, investigative, and secular source of daily news about Utah issues. This would likely result  in  irreparable  harm  to  Utahns’  access  to  objective   and thorough news content regarding Utah events, and to the Utah economic and political institutions that rely on objective journalism to ensure fairness, candor and transparency in business and government.

DATED this 15th day of June, 2014, in Salt Lake County, Utah.

_/s/ Donald Gale______________________ G. DONALD GALE

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EXHIBIT A

Op-ed: Tribune should go on; LDS scripture requires it By Don Gale May 30 2014 05:23 pm We should all be concerned about challenges facing the Salt Lake Tribune. Leaders of the LDS Church should be especially concerned. It would not look good . . . indeed, it would not be good for church headquarters to be in a city with zero newspapers. The negative image would be compounded if the church is perceived to play a role in the demise  of  the  city’s  only  newspaper. The  Deseret  News  appears  to  be  a  newspaper,  but  it  does  not  fulfill  this  journalist’s  definition.  Someone   said the role of a good newspaper is to "comfort the afflicted and afflict the comfortable." The function of  today’s  Deseret  News  is  to  patronize  the  afflicted  and  affirm  the  comfortable.  That’s  a  legitimate  role   for a church-owned publication, but it does not serve the community in the same capacity as traditional journalism. LDS scripture includes this sentence: "For it must needs be, that there is an opposition in all things." Opposition is not only desirable; it is necessary. It "must needs be." The Tribune is not the opposition, but it gives voice to those who think differently from the establishment, whether "establishment" means church, government, business, or any other institutional influence. (By the way, the phalanx of those who "think differently" includes many active members of the LDS Church.) At the same time, the Tribune moderates opposition by publicizing positive establishment activities (such as humanitarian relief), by printing summaries of church conference sessions for those who would otherwise ignore conference, and by giving those who "think differently" a respected source of information about local issues. If the Tribune editorially disagrees with LDS Church officials about selected  issues  such  as  liquor  laws  and  legislative  influence,  that’s  probably  a  good  thing.  Those  who   want examples of criticism leading to positive developments around here need not look very far. In this community, more than half the population will never subscribe to the Deseret News, on principle. That has been true for a long while – even when the Deseret News met higher journalistic standards. If the Tribune goes away, that leaves more than half the population without access to a local newspaper. (Journalistic standards at the Tribune have also suffered lately due to economic pressures, but new owners will have a chance to halt or reverse the trend.) Community leaders should also consider the economic benefits of a mass circulation newspaper. Many local businesses depend on newspaper advertising to build and maintain their customer base.

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Misinformed observers think the digital media can fill that role. But digital media are not the answer for local  economic  growth.  They  don’t  replace;  they  augment.  They  target  specific  individual  interests,  not  a   mass audience. Local businesses achieve a surprisingly good "reach" by advertising in both the Tribune and the Deseret News, thanks to the Joint Operating Agreement. If the Tribune closes, the advertising "reach" is considerably diminished, not only in quantity but in diversity. Of course, big box stores will find another way to distribute their pervasive ad inserts. But local advertisers may be excluded. Most importantly, Thomas Jefferson said: "If a nation expects to be ignorant and free . . . , it expects what never was and never will be." The Tribune helps counter some of the political ignorance in our community  and  state.  Malfeasance  at  the  state  attorney’s  office  would  not  have  been  corrected  without   Tribune reporting. The Tribune may be annoying to some, but it is an annoyance founded on traditional journalism values. The question is whether church leaders prefer one thoughtful voice governed by traditional journalism values . . . or a thousand shrill voices driven by ignorance, rumor, and prejudice.