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, Herman Reeves, after being duly sworn, the following:

1. In 1987 when Kevin Ives and Don Henry were murdered, I was an elected Constable and am now an elected Justice of the Peace in District 4, Saline County, Arkansas.

2. My daughter was a friend and classmate of Kevin Ives and Don Henry and I not only have taken a strong and personal interest in the investigations of the boys' murders, I have conducted my own informal investigation of the case.

3. In 1993 I became acquainted with former Saline County Deputy John Brown when he was assigned to the Henry/lves murder investigation and began working with him on the case.

4. Over the past five years, John Brown and I have become best friends and I consider him to be like a brother.

5. On numerous occasions John Brown has discussed with me his theory of the events surrounding the murders of Kevin Ives and Don Henry. According to John Brown: Sharline Wilson and Dan Harmon went to the tracks that night to pick up a drug drop and a number of other people were also there. When they arrived at the tracks, Dan Harmon got out of the car carrying a gun and walked down the railroad tracks. Sharline Wilson stayed in the car and did drugs while she waited for Harmon. Kevin and Don walked upon Harmon and the others at the tracks. Don fired one shot from his 22 rifle and everyone started running. Kevin and Don ran north, up the tracks toward Alexander where they met up with Keith Coney who was on his motorcycle. The three boys then rode the motorcycle to Ranchette Grocery on Highway 111 where Don attempted to make a telephone call from a phone booth when Kirk Lane and Jay Campbell showed up and a scuffle ensued. Don's .22 rifle was leaning up against a pole and Kevin reached for the rifle. One of the police officers took the gun away from him and struck him on the left side of the head with the butt of the rifle. Kevin fell to the ground and was either unconscious or already dead. The police officers then threw the boys into their car and left with them. Keith fled on his motorcycle when the scuffle broke out and went to the Wagon Wheel to tell Keith McKaskle and Mike Crook what happened. Mike Crook didn't want anything to do with it, but Keith McKaskle went to the tracks. There is an eyewitness who gave descriptions of the police officers and the descriptions fit Kirk Lane and Jay Campbell.

6. I was John Brown's campaign manager when he ran for sheriff of Saline County in 1996. John and I promoted and displayed the video, Obstruction of Justice, while campaigning at public events such as town festivals, etc. Since its release, John Brown has also promoted the video on radio talk shows.

7. John Brown has never told me or indicated in any way that he was unhappy with the video, Obstruction of Justice, or that he felt it had been edited or spliced to make it appear that he had said things he did not say.

8. John Brown told me that he told Pat he should not use names in the video, Obstruction of Justice. This conversation took place after the lawsuit was filed.

[Signature]
Herman Reeves

VERIFICATION

STATE OF ARKANSAS COUNTY OF SALINE

I, Herman Reeves, do hereby swear that the above statements and allegations are true and correct to the best of my recollection and believe.

[Signature]
Herman Reeves

SUBSCRIBED AND SWORN to before me this 10th day of 1998.

[Notarized]
My Commission Expires:

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