CITY OF WASHINGTON
DISTRICT OF COLUMBIA 0


AFFIDAVIT OF DANIEL P. SHEEHAN


      Below, the Plaintiffs' attorney, Daniel P. Sheehan, sets forth for the 
Court in the following Affidavit, the explanation of the evidence presently in 
his possession )) which evidence does, in fact, rise to the level of "probable 
cause" to believe that the Defendants named in this federal civil lawsuit are 
guilty of the commission of the federal criminal violations set forth in the 
Amended Complaint of October 4, 1986.  The Plaintiffs move that this Affidavit 
of Counsel be deemed a Supplemental Filing to their October 4, 1986, Amended 
Complaint if the Court deems this to be legally required and that it be deemed 
by the Court to set forth the evidentiary basis upon which a reasonable person 
)) drawing all logical inferences from the facts adduced in the direction of 
the Plaintiffs )) would conclude that it is more probable than not that each 
of the Defendants named in this civil suit is guilty of violating the Federal 
RICO Statute and that he is civilly liable to the Plaintiffs Tony Avirgan and 
Martha Honey for having fortuitously contributed to the civil wrongs committed 
against them as charged in this Amended Complaint )) as Supplemented by the 
Affidavit of Counsel.


ATTORNEY DANIEL SHEEHAN'S AFFIDAVIT


Now comes Attorney Daniel P. Sheehan, and having been duly sworn hereby swears 
and affirms that the following facts are true:


1.      I am a duly licensed attorney at law, admitted to practice before the 
State and Federal Courts of the State of New York in both the Northern and
Southern Districts of New York.

2.      I am duly licensed and have been admitted to practice before the 
Courts of the District of Columbia, both local and Federal and I am in good
standing before both the Bar of New York and the Bar of the District of
Columbia.

3.      I have practiced law before the courts of New York and numerous other 
states in our nation since 1970, having served as counsel in some 60 separate 
pieces of litigation in the states of New York, Pennsylvania, North Carolina,
Virginia, the District of Columbia, Georgia, Florida, Oklahoma, Ohio,
Colorado, Idaho, Nebraska, South Dakota, Wyoming and Mississippi.

4.      I graduated from Harvard college in 1967 as an Honors Graduate in 
American Government, writing my Honors Thesis in the field of Constitutional 
Law, and was the Harvard University nominee for the Rhodes Scholarship from 
New York in 1967.  I graduated from Harvard School of Law in 1970, having
served as an Editor of the Harvard Civil Rights)Civil Liberties Law Review and
as the Research Associate of Professor Jerome Cohen, the Chair of the
International Law Department of Harvard.

5.      While at Harvard School of Law, I served as a summer associate at the 
State Street law firm of Goodwin, Proctor and Hoar under the supervision of 
Senior Partner, Donald J. Hurley, the President of the Boston Chamber of 
Commerce and Massachusetts Senatorial Campaign Chairman for John F. Kennedy.  
At this firm I participated in the case of BAIRD v EISENSTAT, under Roger 
Stockey, General Counsel for the Massachusetts Planned Parenthood League 
(establishing the unconstitutionality of the Massachusetts anti)birth control 
law) and in the Nevada case, under Charles Goodhue, III (establishing the 
constitutional right to bail in criminal extradition cases, including capital 
cases).  While at Harvard School of Law, I authored "The Pedestrian Sources of 
Civil Liberties" in the Harvard Civil Rights)Civil Liberties Law Review and I 
served under Professor Milton Katz, the President of the International Law 
Association, as the Chairman of the Nigerian Biafran Relief Commission 
responsible for successfully negotiating the admission of mercy flights of 
food into Biafra in 1968.

6.      While serving as a legal Associate at the Wall Street law firm of 
Cahill, Gordon, Sonnett, Rheindle and Ohio under partner Theodore Shackley and 
Thomas Clines directed the Phoenix Project in Vietnam, in 1974 and 1975, which 
carried out the secret mission of assassinating members of the economic and 
political bureaucracy inside Vietnam to cripple the ability of that nation to 
function after the total US withdrawal from Vietnam.  This Phoenix Project, 
during its history, carried out the political assassination, in Vietnam, of 
some 60,000 village mayors, treasurers, school teachers and other non)Viet 
Cong administrators.  Theodore Shackley and Thomas Clines financed a highly 
intensified phase of the Phoenix project, in 1974 and 1975, by causing an 
intense flow of Vang Pao opium money to be secretly brought into Vietnam for 
this purpose.  This Vang Pao opium money was administered for Theodore 
Shackley and Thomas Clines by a US Navy official based in Saigon's US office 
of Naval Operations by the name of Richard Armitage.  However, because 
Theodore Shackley, Thomas Clines and Richard Armitage knew that their secret 
anti)communist extermination program was going to be shut down in Vietnam, 
Laos, Cambodia, and Thailand in the very near future, they, in 1973, began a 
highly secret non)CIA authorized program Thus, from late 1973 until April of 
1975, Theodore Shackley, Thomas Clines and Richard Armitage disbursed, from 
the secret, Laotian)based, Vang Pao opium fund, vastly more money than was 
required to finance even the highly intensified Phoenix Project in Vietnam.  
The money in excess of that used in Vietnam was secretly smuggled out of 
Vietnam in large suitcases, by Richard Secord and Thomas Clines )) and carried 
into Australia, where it was deposited in a secret, personal bank account 
(privately accessible to Theodore Shackley, Thomas Clines and Richard Secord).  
During this same period of time between 1973 and 1975, Theodore Shackley and 
Thomas Clines caused thousands of tons of US weapons, ammunition, and 
explosives to be secretly taken from Vietnam and stored at a secret "cache" 
hidden inside Thailand.

The "liaison officer" to Shackley and Clines and the Phoenix Project in 
Vietnam, during this 1973 to 1975 period, from the "40 Committee" in the Nixom 
White House was one Eric Von Arbod )) an Assistant Secretary of State for Far 
Eastern Affairs.  Von Arbod shared his information about the Phoenix Project
directly with his supervisor Henry Kissinger.

Saigon fell to the Vietnamese in April of 1975.  The Vietnam War was over.

Immediately upon the conclusion of the evacuation of U.S. personnel from 
Vietnam, Richard Armitage was dispatched, by Theodore Shackley and Thomas 
Clines, from Vietnam to Tehran, Iran.  In Iran, Armitage (the "bursar" for the 
Vang Pao opium money for Shackley and Clines' planned "Secret Team" covert 
operations program), between May and August of 1975, set up a secret 
"financial conduit" inside Iran, into which secret Vang Pao drug funds could 
be deposited from Southeast Asia.  The purpose of this conduit was to serve as 
the vehicle for secret funding by Shackley's "Secret Team," of a private, 
non)CIA authorized "Black" operations inside Iran )) disposed to seek out, 
identify, and assassinate socialist and communist sympathizers )) who were 
viewed by Shackley and his "Secret Team" members to be "potential terrorists" 
against the Shah of Iran`s government in Iran.  In late 1975 and early 1976, 
Theodore Shackley and Thomas Clines retained Edwin Wilson to travel to Tehran, 
Iran to head up the "Secret Team" covert "anti)terrorist" assassination 
program in Iran.  This was not a U.S.  government)authorized operation.  This 
was a private operations supervised, directed and participated in by Shackley, 
Clines, Secord and Armitage in their purely private capacities.

At the end of 1975, Richard Armitage took the post of a "Special Consultant" 
to the U.S. Department of Defense regarding American military personnel 
Missing In Action (MIAs) in Southeast Asia.  In this capacity, Armitage was 
posted in the U.S. Embassy in Bangkok, Thailand.  There Armitage had top 
responsibility for locating and retrieving American MIA's in Southeast Asia.  
He worked at the Embassy with an associate, one Jerry O. Daniels.  From 1975 
to 1977, Armitage held this post in Thailand.  However, he did not perform the 
duties of this office.  Instead, Armitage continued to function as the 
"bursar" for Theodore Shackley's "Secret Team," seeing to it that secret Vang 
Pao opium funds were conducted from Laos, through Armitage in Thailand to both 
Tehran and the secret Shackley bank account in Australia at the Nugen)Hand 
Bank.  The monies conducted by Armitage to Tehran were to fund Edwin Wilson's 
secret anti)terrorist "seek and destroy" operation on behalf of Theodore 
Shackely.  Armitage also devoted a portion of his time between 1975 and 1977, 
in Bangkok, facilitating the escape from Laos, Cambodia and Thailand and the 
re)location elsewhere in the world, of numbers of the secret Meo tribesmen 
group which had carried out the covert political assassination program for 
Theodore Shackley in Southeast Asia between 1966 and 1975.  Assisting Richard 
Armitage in this operation was Jerry O. Daniels.  Indeed, Jerry O. Daniels was 
a "bag)man" for Richard Armitage, assisting Armitage by physically 
transporting out of Thailand millions of dollars of Vang Pao's secret opium 
money )) to finance the re)location of Theodore Shackley's Meo tribesmen and 
to supply funds to Theodore Shackley's "Secret Team" operations.  At the U.S. 
Embassy in Bangkok, Richard Armitage also supervised the removal of arms, 
ammunition and explosives from the secret Shackley)Clines cache of munitions 
hidden inside Thailand between 1973 and 1975 )) for use by Shackley's "Secret 
Team".  Assisting Armitage in this latter operations was one Daniel Arnold, 
the CIA Chief of Station in Thailand )) who joined Shackley's "Secret Team" )) 
in his purely private capacity.

One of the officers in the U.S. Embassy in Thailand, one Abranowitz came to 
know of Armitage's involvement in the secret handling of Vang Pao opium funds 
and caused to be initiated an internal State Department heroin smuggling 
investigations directed against Richard Armitage.  Armitage was the target of 
Embassy personnel complaints to the effect that he was utterly failing to 
perform his duties on behalf of American MIAs, and he reluctantly resigned as
the D.O.D. Special Consultant on MIA's at the end of 1977.

From 1977 until 1979, Armitage remained in Bangkok opening and operating a 
business named The Far East Trading Company.  This company had offices only in 
Bangkok and in Washington, D.C.  This company was, in fact, from 1977 to 1979, 
merely a "front" for Armitage's secret operations conducting Vang Pao opium 
money out of Southeast Asia to Tehran and the Nugen)Hand Bank in Australia to 
fund the ultra right)wing, private anti)communist "anti)terrorist" 
assassination program and "unconventional warfare" operation of Theodore 
Shackley's and Thomas Cline's "Secret Team".  During this period, between 1975 
and 1979, in Bangkok, Richard Armitage lived in the home of Hynnie Aderholdt 
)) the former Air Wing Commander of Shackley`s "Special Operations Group" in 
Laos )) who, between 1966 and 1968, had served as the immediate superior to 
Richard Secord, the Deputy Air Wing Commander of MAG)SOG.  Secord, in 1975, 
was transferred from Vietnam to Tehran, Iran.

In 1976, Richard Secord moved to Tehran, Iran and became the Deputy Assistant 
Secretary of defense in Iran, in charge of the Middle Eastern Division of the 
Defense Security Assistance Administration.  In this capacity, Secord 
functioned as the chief operations officer for the U.S. Defense Department in 
the Middle East in charge of foreign military sales of U.S. aircraft, weapons 
and military equipment to Middle Eastern nations allied to the U.S..  Secord's 
immediate superior was Eric Van Marbad )) the former 40 Committee liaison 
officer to Theodore Shackley's Phoenix program in Vietnam from 1973 to 1975.

From 1976 to 1979, in Iran, Richard Secord supervised the sale of U.S. 
military aircraft and weapons to Middle Eastern nations.  However, Richard 
Secord did not authorize direct nation)to)nation sales of such equipment 
directly from the U.S. government to said Middle Eastern governments.  
Instead, Richard Secord conducted such sales through a "middle)man", one 
Albert Hakim.  By the use of middle)man Albert Hakim, Deputy Assistant 
Secretary of Defense Richard Secord purchased U.S. military aircraft and 
weapons from the U.S. governament at the low "manufacturer's cost" )) but sold 
these U.S. aircraft and weapons to the client Middle Eastern nations at the 
much higher "replacement cost".  Secord then caused to be paid to the U.S. 
government, out of the actual sale price obtained, only the lower amount equal 
to the lower manufacturer's cost.  The difference, was secreted from the U.S. 
government and Secord and Albert Hakim secretly transferred these millions of 
dollars into Shackley's "Secret Team" operations inside Iran )) and into 
Shackley's secret Nugen)Hand bank account in Australia.  Thus, by 1976, 
Defendant Albert Hakim had become a partner with Thomas Clines, Richard Secord 
and Richard Armitage in Theodore Shackley's "Secret Team".

Between 1976 and 1979, Shackley, Clines, Secord, Hakim, Wilson, and Armitage 
set up several corporations and subsidiaries around the world through which to 
conceal the operations of the "Secret Team".  Many of these corporations were 
set up in Switzerland.  Some of these were: (1) Lake Resources, Inc.; (2) The 
Stanford Technology Trading Group, Inc.; and (3) Companie de Services 
Fiduciaria.  Other companies were set up in Central America, such as: (4) CSF, 
Investments, Ltd. and (5) Udall research Corporation.  Some were set up inside 
the United States by Edwin Wilson.  Some of these were: (6) Orca Supply 
Company in Florida and (7) Consultants International in Washington, D.C..  
Through these corporations, members of Theodore Shackley's "Secret Team" 
laundered hundreds of millions of dollars of secret Vang Pao opium money 
pilfered Foreign Military Sales proceeds between 1976 and 1979.  named in this 
federal civil suit to be placed under oath and asked about their participation 
in the criminal "enterprise" alleged in this Complaint is probative of the 
criminal guilt of the Defendants of some of the crimes charged in this 
Complaint.

Plaintiffs and Plaintiffs' Counsel, The Christic Institute, possess evidence 
constituting "probable cause" that each of the Defendants named in this 
Complaint are guilty of the conduct charged.

If further detailed evidence is required by the Court to allow the Plaintiffs 
to begin the standard process of discovery in this case, the failure to place
it in this Affidavit is the function of the short time allowed by the Court
for the preparation of this filing )) it is not because the Plaintiffs lack
such evidence.




                                             Daniel P. Sheehan


Subscribed and Sworn to before me this day of December, 1986










   THE SILENT WAR

   We are engaged in a silent war.  Those waging this brutal conflict have
   not the decency to inform their victims ))) who include ourselves and
   almost everyone we know.  Their standard bearers include George Bush and
   David Rockefeller.  As the high priced professional liars in the mass
   media assure us all is well, the common people of the world are being
   crushed ))) like foot soldiers over run by a panzer division.

   And yet, the only real power of these perpetrators derives only from this
   force fed ignorance.  Apart from the power to keep us fighting each
   other, the Monopolists have no power.  If a critical mass of people can
   learn the information contained herein, and what is more important, the
   sources of this information, a global reign of terror will end.

   These articles are taken from my monthly column in MONETARY AND ECONOMIC
   REVIEW.  I am also the Director of Research for INTELLIGENCE CONNECTION a
   speakers agency that arranges events on university campuses for front
   line researchers, like those mentioned in these articles.  My name is
   Brian Quig.


   You can arrange speaking events with any of these legendary people by
   calling

   (602) 945-3858

   or writing                                                                 
                                                                              
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