I, JUDD C. IVERSEN, declare:
1. That I am an attorney duly licensed to practice law in
the United States District Court for the Northern District of
California and am the appointed counsel of JULIO ZAVALA in the
2. That I am informed and believe that following the
Sandinistas revolution in Nicaragua, a group of individuals who
were against the revolution formed the Conservative Party of
Nicaraguans in exile. That the purpose of this party is to
reinstate the democratic system in Nicaragua. That the
headquarters of this party is presently located in San Jose, Costa
3. That I am further informed and believe that the
Government of the United States of America has been aiding and
supporting the Conservative Party of Nicaraguans in exile to
reinstate the democratic system.in Nicaragua. That the support
given by agents for the United States of America includes
training, weapons, funding, and assistance in obtaining all of the
4. That I am informed and believe that agents of the
Conservative Party of Nicaraguans in exile are presently in the
United States to raise funds for their cause and their presence
and purpose is both known to and aided by agents of the United
States of America.
5. I am informed and believe that individuals presently
located in San Jose, Costa Rica, possess evidence which is
material to the defense of this matter and without which Defendant
cannot effectively prove his innocence of the charges in the
6. I am informed and believe that the proposed deponents
refuse to voluntarily attend the trial set in this matter in the.
United States of America and due to their residence in a foreign
country are beyond the reach of the subpoena power of this Court.
7. I am further informed and believe that the testimony
recorded in this deposition is necessary to establish the defense
to the charges against the Defendant herein and also may be
necessary to contradict testimony of agents of the United States
Government who may be called by the defense to testify at trial.
8. That counsel is appointed by the Court to represent
Defendant and the Defendant is without funds to pay for the costs
of the depositions and travel by counsel to attend the deposition.
It is believed that the deposition is necessary in order to
prevent failure of justice and to provide necessary and material
evidence of Defendant's innocence which cannot be obtained from
any other source.
I declare under penalty of perjury that the foregoing is true
and correct, and as to those matters stated on information and
belief, I believe it to be true. Executed this 4th day of
June, 1984, at San Francisco, California.
JUDD C. IVERSEN