Canada
Province of Quebec
District of Montreal

Superior Court

(Administrative Division)

No: 500-05-069317-012

CONSENT TO SAFEGUARD ORDER

1. THE PETITIONERS AND THE RESPONDENTS CRESCENT CHAU AND LA PRESSE CHINOISE EASTENER INC. AGREE TO THE FOLLOWING SAFEGUARD ORDERS WITHOUT prejudice to their respecting rights and under reserve of their recourses and without admission by either party of the facts alleged in the motion.
2. The aforesaid respondents undertake not to accept for publication and not to publish articles or advertisements emanating from the co-respondent Bing he with respect to Falun Gong as alleged in the petitioners' motion and exhibits or articles or advertisements of a similar nature from any other person, it being understood that the above restriction does not limit the respondents aforementioned from accepting for publication or publishing articles or advertisements on the falun gong that constitute legitimate and lawful comment as is permitted under Canadian law and Quebec law.
3. The petitioners' motion shall be postponed to January 7, 2002 at 9:00 am in room No 216 for the purposes of establishing an echeancier, should counsel for the parties have been unable to agree to an echeancier prior to that date.
4. The safeguard orders rendered on this consent shall be served by bailiff on the respondents, in respect of the respondent chau and la presse chinoise at the address of la presse chinoises. In the case of service of the order on the respondent chau valid service may be made on a reasonable person at the offices of la presse chinoise.
5. The safeguard orders herein consented to shall remain in full force and effect until 5:00pm jan 7, 2002, subject however to any renewal thereof either by consent or by order of the court.
6. Costs to follow suit

Montreal, Dec. 10. 2001
Attorneys for petitioners
Attorney for respondents
Crescent chau and
La presse chinoise eastern inc
10/12/01
(signature)