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AMERICAN
CONTINENTAL
CORPORATION
Pour Omon bon moun Phoenix, Arizona 18030-001002) 187-7170

June 1, 1990

Mr. Bruce Penczek, C.P.A.
Twardowicz, Penczek & Associates, Inc.
Financial and Fraud Investigations
The Legg Mason Tower at Harborplace
111 South Calvert Street
Suite 1600
Baltimore, Maryland 21202

Dear Bruce: Per your request, I located information concerning plane flights taken by Senator DeConcint and his wife in 1984. I have attached a schedule which indicates the date and destination of the flights. Mr. Keating was charged with income for these flights in his 1984 audit. However, since the tax impact was not significant, I did not further investigate these flights. I never contacted the senators office goy attempted to locate reimbursement. I'11 be forwarding the Riegal etter to you after I get settled in Boise.

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CHARLES N KEATING JR 1906 BREAKDOWN OF CHARGES FOR PERSONAL USE OF CORPORATE AIRCRAFT

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Telephone Conversation with Senator DeConcini

On November 26, 1990, I received a call at home from Senator Dennis DeConcini of Arizona, one of the so-called "Keating 5." He identified himself, and I asked him how he was doing. He said that he had had better days. He then thanked me for my letter and the support I expressed. He agreed that the whole proceeding was unfair.

me

He wondered if I had heard anything from the Ethics Committee yet. I said that I hadn't. He then asked if it would be okay to have one of his attorneys call

and discuss writing an affidavit concerning the letter. He said that I could either do a "to the best of my recollection" affidavit citing the letter or do another affidavit restating the facts only. I said that I would be glad

to discuss the options with his attorneys.

I then asked him how this would help him. He said that it would be another way of showing that the hear ing was not being conducted in a fair manner. He said that Bennett is acting like a prosecutor and selectively presenting evidence to the committee. According to Deconcini, the entire investigation has been conducted that way. For instance, Senator McCain was entitled to an interview prior to his deposition, while none of the other Senators were given the same privilege. He also referred to his role in the Henkel confirmation, where (as I recall) he split his vote, so that Senator Goldwater could be

represented

(at Goldwater's request, since Goldwater was ill), He has had to request letter from Senator Goldwater to substantiate this. No on the committee contacted Goldwater.

He said that my letter would serve the same purpose-to show that some evidence was being ignored so that a sided case could be presented. He said that he wasn't using my letter to hurt Mc Cain and, in fact, he didn't think the letter would hurt him. I said that I would be glad to help.

We then talked about the whole situation a little bit. I told him that the whole slant of the hearings is that the regulators are saints, incapable of making mistakes. He agreed with my statement and indicated that to this day he believes the regulators had made mistakes in their approach.

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He then asked me how I was doing. I told him that I didn't like leaving Ar izona, but that I am happy with my new job. He seemed genuinely concerned.

We left it that one of his people would contact me to discuss the affidavit. He thanked me again and said goodbye.

SPECIAL COUNSEL

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On December 6, 1990, I interviewed David Stevens, the former Tax Director of American

Continental Corporation (ACC). The interview was held at the law. offices of Mark E.

Wight, 1087 West River Street, Suite 230, Boise, Idaho 83702, telephone (208) 343-8880.

Mr. Stevens currently resides at 4420 North Creswell Place, Boise, Idaho 83704-2476. His home telephone number is (208) 376-3160 and his business telephone is (208) 368-4650.

Bill Jackson and I initially interviewed Mr. Stevens in Phoenix, Arizona on June 7, 1990, while he was still employed by ACC (Exhibit 1). We selected Mr. Stevens for interview

based on our review of ACC employee records. At the time, we believed that as Tax

Director of ACC, he may have had knowledge of transactions or activities between ACC

and it's subsidiaries and Senators Cranston, McCain, Riegle, DeConcini, and Glenn. The main topic of discussion during the June 7, 1990 interview was information that Mr. Stevens had relating to the personal use of ACC corporate aircraft by Senator McCain, his family

and staff.

SPECIAL COUNSEL

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