IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF ARKANSAS
WESTERN DIVISION
JAY CAMPBELL AND
KIRK LANE
PLAINTIFFS

vs.

NO. LRC970328

CITIZENS FOR AN HONEST GOVERNMENT, INC.,
D/B/A INTEGRITY FILM; JEREMIAH FILM, INC.
AND PAT MATRISCIANA
DEFENDANTS

AFFIDAVIT

I, David M. Keesee, after being duly sworn, do state the following:

1. I am David M. Keesee. My sister is Jean K. Duffey.

2. The latter part of February 1994, FBI Agent Phyllis Cournan telephoned me at my residence and asked if I could reach Jean and have Jean call her. Cournan said she had been assigned to investigate the Ives/Henry murder case, and she wanted to talk with Jean about it. I told her it might be a few days before I could reach Jean, but I would get the message to her.

3. I called Jean and gave her the message from Cournan. Jean's response was essentially, "Tell her Bob Govar (Assistant U.S. Attorney) has all of the records from my task force and she can get them from him." Jean was not anxious to get involved again, because of what she had gone through before with nothing ever coming of her efforts.

4. I called Cournan and told her what Jean said. Cournan and I talked awhile. She said was a little uneasy about being assigned to investigate the Ives/Henry murders, because she could already see connections to public official corruption. She said Jean's name came up almost everywhere she turned, and she knew Jean would have valuable information to share.

5. We talked a while longer, then she paused. It seemed as though she wanted to make one last ditch effort to persuade Jean to get involved again. Cournan said, "At least tell Jean the Washington office of the FBI has recommended that U.S. Attorney Chuck Banks be charged with obstruction of justice for shutting down the 1990 federal grand jury investigation." I told her I would tell Jean.

6. I called and told this to Jean, who seemed encouraged that something might get accomplished. I learned later that Jean called Cournan and began working with her.

7. On September 26, 1996, I was interviewed by FBI Agent Jim Finch who identified himself as an investigator for internal affairs from the Washington D.C. Office. I tape recorded that interview.

8. Finch explained that the bureau had opened an investigation on Phyllis Cournan over her handling of the Ives/Henry case. Finch was particularly interested in the statement Cournan made to me about Chuck Banks. I answered all of Finch's questions to the best of my ability and then had a few questions for him, which he answered for the most part. I expressed my concern to Finch that Cournan was being investigated over such a trivial matter.

9. A copy of the audio tape of Finch's interview with me has been provided to John Wesley Hall, Pat Matrisciana's attorney.

[Signature]
David M. Keesee

VERIFICATION
STATE OF ARKANSAS
COUNTY OF Hot Spring

I, David M. Keesee, do hereby swear the above statements are true and correct to the best of my recollection and belief.

[Signature]
David M. Keesee

SUBSCRIBED AND SWORN TO ME THIS 28th day of May, 1998.

[Notarized]
My Commission Expires:
August 15,1999

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