I, KAREN BRONK FROMING, Ph.D., declare as follows:

1. I am a clinical psychologist licensed to practice in the State of California. I specialize in clinical neuropsychology and neuropsychological assessment. I have received training in this speciality in accordance with the standards of the American Psychological Association (APA), Division 40. I am a member in good standing of the APA, and its subspecialty division of clinical neuropsychology. I am board certified and credentialed by the American Board of Professional Psychology - American Board of Clinical Neuropsychology, having passed their written, work sample and oral examinations. I am also a member of the National Register of Health Service Providers in Psychology. In addition, I serve as an oral commissioner for the Board of Psychology in the State of California licensing examination for psychologists.

2. I am a member of the International Neuropsychological Society, the National Academy of Neuropsychology, American Psychological Society and Divisions 40 and 41 (Clinical Neuropsychology and Psychology and Law), and the California Psychological Association. I am the former chair of the Education Committee of the Northern California Neuropsychology Forum, a position I held in 1993-1994 and in 1990-1991, and a past president (1991-1992) of that organization as well.
3. In 1979, I received my B.A. degree in psychology from the University of Florida. Shortly after my graduation, I received training in neuropsychological assessment at the Shands Teaching Hospital and J. Hillis Miller Center Psychological Clinic. As a trained neuropsychological technician, I administered and scored neuropsychological tests and provided neuropsychological services to over 300 patients.

4. In 1984, I received my M.S. in psychology from the University of Florida. From 1986 through 1987, following two years at Shanda Teaching Hospital, I completed my pre-doctoral internship training at the San Francisco Veteranís Administration Center. In 1988, I successfully defended my dissertation and received a Ph.D. in psychology from the University of Florida. I was awarded a post-doctoral fellowship in neuropsychology in the Department of Clinical and Health Psychology at the University of Florida and received advanced training in behavioral neurology, behavioral brain syndromes, neuroanatomy, neurophysiology, memory disorders, and aphasiology or language disorders.

5. My past positions included the following duties: Director, Behavioral Medicine Unit, in the Division of General Internal Medicine at the University of California-San Francisco School of Medicine; Staff Psychologist III and Triage Coordinator; Consulting Neuropsychologist with the Langley Porter Psychiatric Instituteís Psychological Assessment Unit; Assistant Clinical Professor of Medicine and Psychiatry at the University of California-San Francisco; and Adjunct Faculty Member at the Pacific Graduate School of Psychology.

6. In connection with my duties at the University of California-San Francisco School of Medicine, I was responsible for accepting, evaluating and assigning for treatment patients suffering from organic and/or psychiatric complaints. The department for which I was responsible handles several thousand patient visits per year. I established the first neuropsychological assessment subspecialty service within our department.

7. I am currently in private practice in San Francisco, California. I have continued faculty appointments in the Department of Psychiatry at the University of California-San Francisco. I continue to teach both at the Langley Porter Psychiatric Institute and at San Francisco General Hospital.

8. I have been asked by the attorneys representing Damien Echols to administer neuropsychological testing to determine the nature of any neurologic deficits Mr. Echols may have and to opine whether neurological deficits are consistent with Mr. Echolsí psychiatric clinical presentation.

9. In order to complete the requested tasks I have reviewed relevant life history data about Mr. Echols, including but not limited to the case file of Dr. John Moneypenny who evaluated Mr. Echols shortly before the commencement of his trial, psychiatric records covering Mr. Echolsí hospitalization and treatment from 1992 to 1993, Mr. Echolsí academic records, medical records, Social Security Administration records, and excerpts of trial proceedings, and consulted with George W. Woods, M.D. I also administered a comple Halstead-Reitan Battery and additional neuropsychological tests December 18 - 19, 2000, and spent in excess of 16 hours administering and scoring these tests.

10. Test findings are consistent with serious psychiatric disorder such as DSM-IV, Axis I, psychotic disorders such as Bipolar Affective Disorder. Mr. Echolsí patterns of performance are atypical for acquired brain lesion. Nevertheless, there are deficit areas and atypical findings for normal, non-neuropsychiatrically impaired individuals.

11. Evaluation was begun with mental status examination revealing mild evidence of continued depression. There is relatively good judgment, insight, but impaired mood and affect. Mr. Echolsí facial expression was flat with minimal shifts in mood throughtout two days of testing. There were two occasions in which Mr. Echolsí performance was interrupted by obvious inattention and distraction by what appeared to be internal stimuli, although he denied any auditory hallucinatory experience. Thought processes were slowed but predominantly goal oriented. Content of thought was mildly dysphoric but not inconsistent with his current life circumstances.

12. Mild deficiencies and slowing were noted on tasks of attention, inattention with errors of omission, commission, and occasional impulsivity. These types of difficulties were also demonstrable on groos and fine motor tasks, visuomotor tasks, and motor impersistence. On motor tasks there was an atypical reversal of motoric skill, with left hand performance exceeding right hand performance, in a strongly right handed individual.

13. There were relatively greater difficulties with visuospatial over verbal material, although slowing and mild interference effects were noted for all material. Recall of paragraph material after a delay period exceeded 80% of the original material while visual material recalled was 59% of the original recall.

14. In general, anterior brain and right hemisphere functions are more deficient. The pattern of findings is consistent with the types of deficits found in Bipolar Affective Disorder.

15. Mr. Echolsí performance on the Wechsler Memory Scale 3 (WMS3) indicates that his intellectual functioning is most likely higher than it appeared at the time of his trial. His WMS3 scores were the following: Auditory Immediate (verbal memory) 114; Visual Immediate (visual memory-faces) 115; Immediate Memory (combined) 118; Delayed Verbal 111; Visual Delayed 112; Auditory Recognition Delay 120; General Memory 117. Given that these scores are mildly depressed from depression and his trial scores were in the 100-106 range on previous testing, it is probable that his scores on IQ testing at the time of trial were lowered as a result of psychiatric illness. Mr. Echolsí achievement scores on the Wide Range Achievement Test-3rd edition are Reading 107, Spelling 108, and Math 96, consistent with his impaired educational achievement. These educationally based tasks are likely lower than his native abilities could produce. It is typical in Bipolar patients who experience their first episodes during adolescence, that school performance and sebsequent achivement are impaired.

I declare under penalty of perjury, under the laws of the United States of America and the State of California, that the foregoing is true and correct. Executed on this 10th day of January, 2001, at San Francisco, California.

Karen B Froming Ph.D. (signature)