INSLAW CASE: AFFIDAVIT OF MICHAEL J. RICONOSCIUTO

UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF COLUMBIA


IN RE:                        )
                              )    Case No. 85-00070
INSLAW, INC.,                 )    (Chapter 11)
                              )
           Debtor.            )
______________________________)
                              )
INSLAW, INC.,                 )
                              )
           Plaintiff,         )
                              )
     v.                       )    Adversary Proceeding
                              )    No. 86-0069
UNITED STATES OF AMERICA,     )
and the UNITED STATES         )
DEPARTMENT OF JUSTICE,        )
                              )
         Defendants,          )
______________________________)


AFFIDAVIT OF MICHAEL J. RICONOSCIUTO

STATE OF WASHINGTON     )
                        )    ss:
                        )

I, MICHAEL J. RICONOSCIUTO, being duly sworn, do hereby 
state as follows:

1. During the early 1980's, I served as the Director of Research 
for a joint venture between the Wackenhut Corporation of Coral Gables, 
Florida, and the Cabazon Band of Indians in Indio, California. The joint
venture was located on the Cabazon reservation.

2. The Wackenhut-Cabazon joint venture sought to develop and/or
manufacture certain materials that are used in military and national security 
operations, including night vision goggles, machine guns, fuel-air
explosives, and biological and chemical warfare weapons.

EXHIBIT 1

3. The Cabazon Band of Indians are a sovereign nation. The sovereign
immunity that is accorded the Cabazons as a consequence of this fact made it 
feasible to pursue on the reservation the development and/or manufacture of 
materials whose development or manufacture would be subject to stringent
controls off the reservation. As a minority group, the Cabazon Indians also
provided the Wackenhut Corporation with an enhanced ability to obtain
federal contracts through the 8A Set Aside Program, and in connection with
Government- owned contractor-operated (GOCO) facilities.

4. The Wackenhut-Cabazon joint venture was intended to support 
the needs of a number of foreign governments and forces, including forces
and governments in Central America and the Middle East. The Contras in
Nicaragua represented one of the most important priorities for the joint
venture.

5. The Wackenhut-Cabazon joint venture maintained close liason 
with certain elements of the United States Government, including 
representatives of intelligence, military and law enforcement agencies.

6. Among the frequent visitors to the Wackenhut-Cabazon joint 
venture were Peter Videnieks of the U.S. Department of Justice in Washington, 
D.C., and a close associate of Videnieks by the name of Earl W. Brian.
Brian is a private businessman who lives in Maryland and who has maintained
close business ties with the U.S. intelligence community for many years.

7. In connection with my work for Wackenhut, I engaged in some 
software development and modification work in 1983 and 1984 on the 
proprietary PROMIS computer software product. The copy of PROMIS on which I 
worked came from the Department of Justice. Earl W. Brian made it available
to me through Wackenhut after acquiring it from Peter Videnieks, who was
then a Department of Justice contracting official with responsibility for
the PROMIS software. I performed the modifications to PROMIS in Indio,
California; Silver Spring, Maryland; and Miami, Florida.

8. The purpose of the PROMIS software modifications that I made in 1983
and 1984 was to support a plan for the implementation of PROMIS in 
law enforcement and intelligence agencies worldwide. Earl W. Brian was 
spearheading the plan for this worldwide use of the PROMIS computer software.

9. Some of the modifications that I made were specifically 
designed to facilitate the implementation of PROMIS within two agencies of 
the Government of Canada: the Royal Canadian Mounted Police (RCMP) and the 
Canadian Security and Intelligence Service (CSIS). Earl W. Brian would check
with me from time to time to make certain that the work would be completed
in time to satisfy the schedule for the RCMP and CSIS implementations
of PROMIS.

10. The proprietary versions of PROMIS, as modified by me, 
was, in fact, implemented in both the RCMP and the CSIS in Canada. It was
my understanding that Earl W. Brian had sold this version of PROMIS to the
Government of Canada.

11. In February 1991, I had a telephone conversation with Peter 
Videnieks, then still employed by the U.S. Department of Justice. Videnieks 
attempted during this telephone conversation to persuade me not to cooperate
with an independent investigation of the government's piracy of INSLAW's
proprietary PROMIS software being conducted by the Committee on the
Judiciary of the U.S. House of Representatives.

12. Videnieks stated that I would be rewarded for a decision not 
to cooperate with the House Judiciary Committee investigation. Videnieks 
forecasted an immediate and favorable resolution of a protracted child
custody dispute being prosecuted against my wife by her former husband, if I
were to decide not to cooperate with the House Judiciary Committee
investigation.

13. Videnieks also outlined specific punishments that I could 
expect to receive from the U.S. Department of Justice if I cooperate with the 
House Judiciary Committee's investigation.

14. One punishment that Videnieks outlined was the future 
inclusion of me and my father in a criminal prosecution of certain business
associates of mine in Orange County, California, in connection with the
operation of a savings and loan institution in Orange County. By way of
underscoring his power to influence such decisions at the U.S. Department of
Justice, Videnieks informed me of the indictment of these business associates
prior to the time when that indictment was unsealed and made public.

15. Another punishment that Videnieks threatened against me if I 
cooperate with the House Judiciary Commitee [sic] is prosecution by the U.S. 
Department of Justice for perjury. Videnieks warned me that credible
witnesses would come forward to contradict any damaging claims that I made
in testimony before the House Judiciary Committee, and that I would
subsequently be prosecuted for perjury by the U.S. Department of Justice
for my testimony before the House Judiciary Committee.

FURTHER AFFIANT SAYETH NOT.

[Signed]: Michael J. Riconosciuto

Signed and sworn to before me this 21st day of March, 1991.
John M. Rosellini 
Notary Public
My Commission Expires: Sept 19, 1993 

The INSLAW CASE: AFFIDAVIT OF ARI BEN-MENASHE

UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF COLUMBIA


IN RE:                        )
                              )    Case No. 85-00070
INSLAW, INC.,                 )    (Chapter 11)
Debtor.                       )
____________________________  )
                              )
INSLAW, INC.,                 )
Plaintiff,                    )
v.                            )
                              )    Adversary Proceeding
UNITED STATES OF AMERICA,     )    No. 86-0069
and the UNITED STATES         )
DEPARTMENT OF JUSTICE,        )
                              )
              Defendants,     )
____________________________  )


AFFIDAVIT OF ARI BEN-MENASHE

STATE OF KENTUCKY   )
                    )    ss:
CITY OF LEXINGTON   )

I, ARI BEN-MENASHE, being duly sworn, do hereby state as 
follows:

1. Between August 1977 and September 1987, I was employed by 
the Israel Defense Forces (IDF)/Military Intelligence External Relations 
Department.

2. In my above capacity, I had contacts with the Office of the 
Israeli Prime Minister's Anti-Terrorism Advisor.

3. In 1982, the Israeli Prime Minister's Anti-Terrorism Advisor 
was Mr. Rafael Eitan.

EXHIBIT 2

4. In a meeting that took place in December 1982 in Mr. Eitan's 
office in the Kirya in Tel Aviv, Israel, Mr. Eitan told me that he had
received earlier that year in the United States, from Mr. Earl W. Brian and
Mr. Robert McFarlane, PROMIS computer software for the limited use of the
IDF's Signals Intelligence Unit for intelligence purposes only. Mr. Eitan
stated on this occasion, and on earlier occasions as well, that he had
special relationships with both Mr. Brian and Mr. McFarlane.

5. This meeting took place in the context of a visit by a foreign 
dignitary. During a break in the meeting, Mr. Eitan took me aside and gave 
me the above facts to relate to my superiors so that Mr. Eitan's office
could take credit for the introduction of the PROMIS computer software
into IDF's Signals Intelligence Unit.

6. I hereby certify that the facts set forth in this Affidavit are true 
and correct to the best of my knowledge.

FURTHER AFFIANT SAYETH NOT.

Signed: Ari Ben-Menashe

Signed and sworn to before me this 21st day of March, 1991.
Melissa J. Corbett
Notary Public
My Commission Expires: June 14th, 1994

The INSLAW CASE: AFFIDAVIT OF RICHARD H. BABAYAN

UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF COLUMBIA


IN RE:                        )
                              )    Case No. 85-00070
INSLAW, INC.,                 )    (Chapter 11)
               Debtor.        )
____________________________  )
                              )
INSLAW, INC.,                 )
               Plaintiff,     )
                              )    Adversary Proceeding
UNITED STATES OF AMERICA,     )    No. 86-0069
and the UNITED STATES         )
DEPARTMENT OF JUSTICE,        )
                              )
              Defendants,     )
____________________________  )


AFFIDAVIT OF RICHARD H. BABAYAN

State of Florida     )
                     )     ss:
Palm Beach County    )

I, Richard H. Babayan, being duly sworn, do hereby state as 
follows:

1. During the past several years, I have acted as a broker of sales 
of materials and equipment used by foreign governments in their 
armed forces, intelligence and security operations.

2. In the capacity described in paragraph #1, I attended a meeting 
in Baghdad, Iraq, in October or November, 1987, with Mr. Abu Mohammed of 
Entezamat, an intelligence and security organ of the Government of
Iraq. Mr. Abu Mohammed is a senior ranking official of Entezamat and a
person with whom I had had extensive dealings over the previous three years.

EXHIBIT 3

3. During the aforementioned meeting with Mr. Abu Mohammed, I was informed
that Dr. Earl W. Brian of the United States had recently completed a sales
presentation to the Government of Iraq regarding the PROMIS computer software.
Furthermore, it is my understanding that others present at Dr. Brian's PROMIS
sales presentation were General Richard Secord, of the United States, and
Mr. Abu Mohammed.

4. In early to mid-1988, in the course of subsequent visits to
Baghdad, Iraq, I was informed that Dr. Earl W. Brian had, in fact, provided
the PROMIS computer software to the Government of Iraq through a transaction
that took place under the umbrella of Mr. Sarkis Saghanalian, an individual
who has had extensive business dealings with the Government of Iraq since
the late 1970's in the fields of military hardware and software. I was also
informed that the Government of Iraq acquired the PROMIS software for use
primarily in intelligence services, and secondarily in police and law
enforcement agencies.

5. During the course of the visits described in paragraph #4, I also 
learned from Mr. Abu Mohammed that the Government of Libya had 
acquired the PROMIS computer software prior to its acquisition by the
Government of Iraq; that the Government of Libya had by then made extensive
use of PROMIS; and that the Government of Libya was highly recommending the
PROMIS software to other countries. I was informed that the high quality of
the reference for the PROMIS software from the Government of Libya was one
of the principal reasons for the decision of the Government of Iraq to
acquire PROMIS.

6. In the capacity described in paragraph #1, I attended a meeting 
in early 1988 in Singapore with Mr. Y. H. Nam of the Korea Development 
Corporation.

7. The Korea Development Corporation is known to be a cutout 
for the Korean Central Intelligence Agency (KCIA).

8. I learned from Mr. Y. H. Nam during the meeting described in 
paragraph #6 that the KCIA had acquired the PROMIS computer software, and 
that Dr. Earl W. Brian of the United States had been instrumental in the
acquisition and implementation of PROMIS by the KCIA.

9. In the capacity described in paragraph #1, I attended a meeting 
in Santiago, Chile, in December, 1988, with Mr. Carlos Carduen of 
Carduen Industries. During this meeting, I was informed by Mr. Carduen 
that Dr. Earl W. Brian of the United States and Mr. Robert Gates, a senior
American intelligence and national security official, had just completed a
meeting in Santiago, Chile, with Mr. Carlos Carduen.

10. I hereby certify that the facts set forth in this Affidavit are 
true and correct to the best of my knowledge.

FURTHER AFFIANT SAYETH NOT.

Signed: Richard A. Babayan

Signed and sworn to before me this 22nd day of March, 1991.
Milton E. Shepard
Notary Public
My Commission Expires:
NOTARY PUBLIC STATE OF FLORIDA
MY COMMISSION EXP, NOV.15,1991
BONDED THRU GENERAL INS. UNO.