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check is automatically entered by the computer when a

I now check is opened and the order is first placed.

This was realize that this information is inaccurate.

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 prepar

ing to leave.

C. Justin

Roger Lipton

Subscribed and sworn before me this

1177 December, 1990.

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Notary Public

on October 1995


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This firo 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 is it is
accurate, execute it.

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We appreciate your cooperation in this matter. you have any questions, please call me.

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I, Roger

Lipton, being duly sworn, do hereby depose and state as follows: 1. I am the Comptroller of the University Club,

Intuile 1135 16th Street N.W., Washington, D.C.

2. The attached Member Check is a true and correct copy of a University club restaurant record kept in the ordinary course of business. The time appearing in the upper right hand corner of the check (8:44) is automatically entered by the computer when a check is opened for a member. The check is opened when the order is first placed.

The foregoing is true and correct to the best of my personal knowledge and information.


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Subscribed and sworn to before me this 29thday of November


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1, Randolph Edwards, being duly sworn do hereby

depose and state as follows:

1. I have been employed by the University Club, Washington, D.C. for about ten years as a server.

2. After taking a meal order from a member guest, I relay this information to the kitchen by means of a computer.

3. When a guest has finished his meal and, is

preparing to leave, I print a member check by computer which among other details, records the time the check is printed. This has been my routine for several years.


I have examined University Club guest check

number 55797 dated April 13, 1989, a copy of which is appended hereto as Attachment A. The name "Randy" on the top of this check which identified the waiter, is in my handwriting. The time 08:44 represents the time i printed the guest check by means of our computer after the

guest, Roger F. Martin, had finished his meal and was

preparing to leave.


I have also examined the reverse side of

check number 55797, which is appended hereto as Attach

ment B.

The information recorded on this side of Mr.

Martin's check is printed as a matter of routine as I


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