NO. LR-C-97-0328



I, Linda Ives, after being duly sworn, do hereby state the following:

1. The murder of my son, Kevin Ives, and his friend, Don Henry, which are commonly referred to as the "Train Deaths", and public official corruption have been a major public concern for the last ten years as evidenced by the number of newspaper articles that have been generated about them. I have amassed a huge collection of these articles, half of which (some 2000 pages) are included with this motion as DX25. These articles appeared between the time the murders were committed and the time the video was released.

2. Attached to this affidavit as Exhibits 1 - 7 are numerous affidavits from the U.S. v. Troy Warner case which I had in my possession at the time the video was made. I believe these affidavits are representative of the reputation that Jay Campbell and Kirk Lane have in the community.

3. One of the questions Mr. O'Quinn asked me in my deposition was whether or not there were any police officers who were willing to state that Campbell and Lane had bad reputations. I wish to supplement my answer in my deposition by stating that John Brown, a former deputy sheriff for Saline County, and Chief of Police for Alexander, AR., has told me on many occasions that he felt that Campbell and Lane were involved in the murders. Also, Larry Patterson, Arkansas State Police, is on video tape saying that he has seen Arkansas State Police intelligence reports which indicate that Campbell is obviously involved in things he should not be involved in. That video tape is DX5-2.

4. I was in possession of an FBI interview of Dan Lasater, a convicted drug dealer and friend of Campbell's, when the video was made. In the interview, Lasater admits that Campbell had reported to him that he (Campbell) was investigating him in an official capacity, but insists Campbell never gave him any specific information about the investigation, and in fact, states, that Campbell told him the investigation was "chicken shit".

According to Lasater, Campbell told him that he was associated with the DEA on a plane trip (Lasater plane) in 1985. The FBI agent conducting the interview states:

"Jay Campbell has never furnished Lasater any information regarding any investigation in which Campbell was involved, either with the Drug Enforcement Administration (DEA) Task Force or the Pulaski County Sheriff's Office. Campbell has commented that he thought the investigation surrounding him (Lasater) was "Chicken shit". DX3, Exhibit 2, paragraph 2.

"However, Campbell had told him that as an officer with the Pulaski County Sheriff's Office, he had been watching him (Lasater) in connection with his official duties but that he found that there was not enough there to make a case." DX3, Exhibit 2, page 12, paragraph 6.

5. Lasater later pled guilty to drug crimes. The two statements obviously contradict each other and it is clear that Campbell told Lasater he was the subject of investigation. Whether or not Lasater was telling the truth when he claimed that Campbell never gave him specifics of the fact that a target had been warned should have resulted in an investigation of Campbell.

6. It is another clear example of the FBI's protection of Campbell.

7. Jay Campbell and Kirk Lane's name has come up many, many times in the investigation of my son's murder, by as early as mid 1988, when Dan Harmon told me of an eye witness who described two police officers meeting the descriptions of Campbell and Lane. Despite the fact that I have literally pleaded with every investigator who was on the case to follow the leads, they have all refused or neglected their sworn duty to do so. Campbell and Lane's names have been brought up consistently over the years, each time giving further corroboration that they are the killers. Many other names have been thrown into the pot, but none have been consistent nor corroborated.

A. Dan Harmon and Richard Garrett's 1988 Saline County Grand Jury investigation: I was unaware of Harmon's own involvement in the murders and the coverup for years. Harmon and Garrett assured me in June of 1988 that they were looking at the information on Campbell and Lane very seriously and would subpoena them to the grand jury. Of course, I now realize that Harmon and Garrett never intended for the case to be solved, and in fact, Harmon was covering up for himself and others. By Campbell and Lane's own admission in depositions, Harmon did not ask them any pertinent questions relative to Ronnie Godwin's interviews or other witnesses' information about Campbell and Lane. I believe that Harmon was simply "jerking them around" for his own personal reasons. Assistant U.S. Attorney Bob Govar, who later conducted a federal grand jury investigation, told me that Campbell and Lane told him that Harmon had only asked them one question during their appearance before the Saline County Grand Jury which was totally unrelated to my sons's murder, and in fact, was related to the Troy Warner case.

B. The Arkansas State Police investigation was another complete farce. Over the course of their investigation, there were several investigators who worked the case, including Doug Williams, Barney Phillips, Don Birdsong, Dale Swesey, Dave Dillinger and others to a lesser extent. There has never been a state police investigation. They simply recorded information and placed it in the case file. My husband and I had a meeting with Tommy Goodwin, Director of the Arkansas State Police in 1990, to express our disgust with their handling of the case. I went over dozens of witnesses' interviews who had provided various information and challenged Mr. Goodwin to show me where any of it had ever been followed up by investigators. Mr. Goodwin appeared to-be almost as disgusted as my husband and I were. He instructed Doug Williams, head of the criminal investigation division, to put all of the leads on computer and generate a lead sheet, which he did. It was six pages long of nothing but names of witnesses to interview. Over a year later, none of the interviews had been conducted. When I questioned Williams as to why Goodwin's orders had been ignored, he had no explanation. Then later, dozens of reports of attempts to locate these witnesses appeared in the case file, however, they had been backdated to appear that they were done in a timely manner. Most of the reports stated that they were unable to locate the witness or had a notation that they had been interviewed by Dan Harmon. By this time, Harmon had become a suspect, so why would they depend on information provided by Harmon? Jean Duffey and I have since learned that there are some reports in the state police file which have, in fact, been fabricated or falsified. The state police not only never attempted to interview either Campbell or Lane, they never interviewed other witnesses who had provided information about them.

C. Assistant U.S. Attorney Bob Govar's 1990 Federal Grand Jury Investigation: I had a meeting with Bob Govar in which I pleaded with him to look into the information relating to Campbell and Lane. Although I didn't understand why at the time, it was pretty apparent that Govar was not particularly interested in pursuing that information. In fact, I believe that he even stated that I was "grasping at straws". Although I believe that Bob Govar is one of the few good guys in this whole mess, I later learned that Campbell and Lane not only worked closely with Govar on many cases, but were also "drinking buddies" of his. I did not believe then, nor do I believe now that Govar would intentionally protect killers. I do believe, however, that he was too close to them to consider them serious suspects and that it was a grave error in judgment.

D. Phyllis Cournan's 1994-1995 FBI investigation: As with Govar and other investigators before them, I begged Cournan to look very closely at Campbell and Lane, and like others before her, she assured me she was. Having been "burned" before, I sought out Govar's assistance in pressuring Cournan to look at the evidence. I don't know if Cournan was not allowed to go in that direction as she told Jean Duffey, or she simply did not do her job. At any rate, she also failed to interview Campbell and Lane or any of the other witnesses providing information against them. I learned from Jay Campbell's deposition that he was actually deputized by the FBI and working for them during the time Cournan was investigating the case, and in fact, other FBI agents informed Campbell that Cournan was working the case.

E. It is very clear that dirty cops answer to nobody.

8. I would like to clarify an answer to a question in my deposition DX3 at 30:18-35; and 31:1-14. The question was whether or not Phyllis Cournan was a source for the video. My answer as far as her being a source of Campbell and Lane's names was no. Phyllis was, however, a source of some information in the video. For example, the statement that the FBI had recommended obstruction of justice charges against Chuck Banks. Cournan also told me that she had confirmed that Keith Coney was with the boys that night just before they were murdered. There are most likely other statements in the video where the information came from Cournan, so technically, she was a source.

9. In November, 1995, Bill Temple, Assistant Special Agent in Charge of the Little Rock FBI, told my husband and me it was time to consider the fact that a crime had not been committed. This was an asinine statement. I was devastated and felt like we were back in 1988 before the Saline County Grand Jury overturned Malak's ruling of accidental to homicide. The grand jury's final report is DX9.

10. In mid December, 1995, following an article in the Pittsburgh Tribune Review which quoted the statement Temple made to me and my husband that it was time to consider the fact that a crime had not been committed, Jean and I called Phyllis Cournan and taped the telephone conversation with her. A copy of that taped conversation has been provided to Pat Matrisciana's lawyer.

Linda Ives

I, Linda Ives, do hereby swear that the foregoing information and statements are true and correct to the best of my recollection and belief.

Linda Ives

SUBSCRIBED AND SWORN to before me this 29th day of May, 1998.

Notary Public
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