DECLARATION OF JUDD C. IVERSEN


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

instant matter.

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

Rica.

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

above.

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

instant matter.

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