IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF ARKANSAS
WESTERN DIVISION

JAY CAMPBELL and
KIRK LANE
PLAINTIFFS

v.            No. LR-C-97-328

CITIZENS FOR AN HONEST GOVERNMENT, INC.
d/b/a INTEGRITY FILMS; JEREMIAH FILMS, INC.;
and PAT MATRISCIANA
DEFENDANTS

AFFIDAVIT

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

1. I first met John Brown on February 25, 1993 when he was assigned to investigate the murder of my son. He and Herman Reeves came to my home to interview me and my husband.

2. Since that time, I have developed what I considered to be a very close relationship with John and Karen Brown.

3. Shortly after Pat Matrisciana was deposed in this case, Karen Brown called me at work. Apparently, John had seen Pat's deposition and they were angry with him because they felt that Pat was trying to place blame on John for including Jay Campbell and Kirk Lane's names in the video. I was a little surprised because I had told Pat the day of his deposition that he needed to call John Brown and explain it to him because we knew the question was going to come up in depositions. Pat did call John Brown from John Hall's office and I also talked to John Brown about it at that time.

4. I explained to Karen my understanding of how the names came to be in the video which was: While working on Obstruction of Justice, David Minasian recalled an earlier interview with John where he states that "the case is solved" and "we know who killed the boys". He then called John and asked him to elaborate. John told him the story about the eyewitness' statement that he saw two cops beating the boys by the pay phone at the Ranchette Grocery Store and gave descriptions that fit Jay Campbell and Kirk Lane and that there were several sources naming them. I also told Karen that I didn't think Pat was trying to blame anybody for anything -- he was simply answering the question of how their names had come up. I also told her that truth was our defense in the lawsuit -- eyewitnesses had implicated Jay Campbell and Kirk Lane. It was obvious that she was not reassured because she stated that "Pat is going to regret this" and that "Pat is f - - ked because John is going to tell the truth. I made the statement that that's all any of us should do. She then thanked me for discussing the matter with her.

[Signature]
Linda Ives

VERIFICATION

STATE OF ARKANSAS COUNTY OF PULASKI

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

[Signature]
Linda Ives

SUBSCRIBED AND SWORN to before me this 28th day of May, 1998.

[Notarized]
My commission Expires:
9/1/98

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