Affidavit 1, Roger Lipton, being duly sworn do hereby depose and state as follows: 1. I am the Controller of the University Club, 1135 16th St., N.W., Washington, D.C. 2. On or about November 9, 1990, I was contacted by telephone by an individual who identified himself as a Mr. Rousselot, who inquired as to whether he could obtain a copy of a member guest check signed by Roger F. Martin in April, 1989. I do not recall Rousselot stating why he wanted this check. I told Rousselot I could not provide this document to him unless a release was obtained from Mr. Martin. 3. About a week later, I believe on November 16, 1990, I was contacted by a woman who identified herself as Annette Fields who told me she needed a copy of Mr. Martin's April, 1989 check. I told her also that I needed a release from Mr. Martin. 4. On November 19, 1990 I received a facsimile letter from Roger F. Martin which authorized the release to Ms. Fields of a copy of a guest check Martin had signed on April 13, 1989, a copy of which is appended hereto as Attachment A. A copy of Mr. Martin's check had been given to Fields the preceding Friday, November 16, SPECIAL COUNSEL 1990, who had expressed a sense of urgency and also following assurance a release from Martin would be forth coming. I discussed the information printed on this check with Fields by phone on one or two occasions. 5. I had a telephone conversation on November 28, 1990 with Ms. Elisabeth Quill of the law firm of Olwine, Connelly, Chase, O'Donnell and Weyher, during which we discussed the processing of guest checks at the University Club. On November 29, 1990 I was presented with a letter from that same law firm requesting that i sign an affidavit containing the information I had given to Ms. Quill. A copy of this letter and my affidavit are appended hereto as Attachments B and C. 6. I was present during an interview of Randy Edwards, a server at the University Club, on December 4, 1990 conducted by Investigators Ronald E. West and Norman F. Simon. Mr. Edwards was the employee who had served Mr. Martin on April 13, 1989 according to information contained on Martin's guest check. During the interview of Mr. Edwards, I heard him state that it is his procedure as a waiter to print a member guest check after the member had completed his meal and was about to leave. my affidavit dated November 29, 1990, I stated that the time appearing in the upper right hand corner of the In check is automatically entered by the computer when a check is opened and the order is first placed. I now realize that this information is inaccurate. This was the result of an honest mistake on my part concerning the routine followed by Mr. Edwards in processing guest .checks. I now realize the procedure at the University Club followed by Mr. Edwards is to print guest checks at the time the member has finished his meal and is preparing to leave. This firm represents Senator Dennis DeConcini in a matter currently pending before the United States Senate Select Committee on Ethics. We have prepared the attached affidavit based upon information provided by one of your employees to Elisabeth Quill of our office. Pursuant to your telephone conversation yesterday with Ms. Quill, we request that you review the attached affidavit, and if it is accurate, execute it. We appreciate your cooperation in this matter. If you have any questions, please call me. Very truly yours, Mary C Alberd Mary C. Albert Mr. Lipton, Comptroller |