IN THE MATTER OF:-
IRVING AIR CHUTE OF GREAT
BRITAIN LIMITED v LEMERCIER
FRERES.

I, WALTER E. LEES, of 3275 Dakota Street, Oakland, California, United States of America, do hereby solemnly and sincerely declare as follows:-
1. In 1924 I held the rank of Lieutenant, United States Air Corps Reserve. I was employed at that time as a test pilot by Johnson Airplane Company of Dayton, Ohio.
2. Before making a test flight on the 13th June 1924 and being desirous of having available very reliable parachute equipment, I applied to the appropriate Government Department at McCook Field, Dayton, asking them to lend me such equipment. This request was at first refused as at that time the only equipment available was under test by the Air Corps and was of a very secret nature. Upon my explaining however that I was a Reserve Officer of the Air Corps, I suceeded in obtaining on loan, and under conditions of strict confidence, equipment including a harness made by Irving Air Chute Co., Inc., of Buffalo, New York, and with this equipment I saved my life on the following day, as I was obliged to make a parachute jump two minutes after taking off.
3. The only witnesses of my said jump were the mechanics at Johnson Field. This field was a private one and not open to the public as it was being used for Government work. My use of the said harness did not therefore in any sense make available to the public any particulars of that harness.
4. There was no publication of the equipment I employed in making the jump mentioned in paragraphs 2 and 3 hereof until some time in the month of September 1926 when a photograph showing said equipment worn by me first appeareed in a catalogue issued by the said Irving Air Chute Co., Inc.

AND I make this solemn declaration conscientously believing the same to be true.

Declared at
this ______day of________, 1947

______________________ Walter E. Lees

Before me:

______________________ Notary Public