1.

I am the Plaintiff herein save otherwise expressly stated

I depose of the following matters within my own personal knowledge

and belief.

2.

In 1979 and 1980, large numbers of Vietnamese refugees

came to Hong Kong by boats. Refugees camps were set up by the Hong

Kong Government and other voluntary agencies (including the United

Nation High Commission for Refugees), Everyday there were news

reports on these Vietnamese Refugees, both on television and in

newspapers. Stories and problems concerning these Vietnamese

Refugees were definitely of news value then.

3.

In view of their news value then, I decided to produce a

film on those Vietnamese Refugees and their lives in the Refugee

camps. This was the film entitled

"Without A Promised Land"

(hereinafter called "the said movie").

It was completed in

mid 1980. The actual shooting of the said movie took about 90 days

and its production costs was about HK$1.2 million.

After that,

the film was edited and was sent to the Film Censorship Authority

(which was then under the Television and Entertainment Licensing

Authority) (hereinafter called "the said Authority") for censor

under the Film Censorship Regulations of Cap. 172 on the 9th of

September 1980 by my company, Seasonal Film Corporation.

now produced and shown to me marked "NSY-1" a copy letter from my

company to the Television and Entertainment Licensing Authority to

that effect.

4.

There is

By a letter dated the 30th September 1980, the said

Authority informed my company that the said movie was viewed by

the Censors that day and the Censors "had refused to approve the

film for exhibition in Hong Kong. There is now produced and

shown to me marked "NSY-2" a copy of the said letter.

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