Below, the Plaintiffs' attorney, Daniel P. Sheehan, sets forth for the Court in the following Affidavit, the explanation of the evidence presently in his possession which evidence does, in fact, rise to the level of "probable cause" to believe that the Defendants named in this federal civil lawsuit are guilty of the commission of the federal criminal violations set forth in the Amended Complaint of October 4, 1986. The Plaintiffs move that this Affidavit of Counsel be deemed a Supplemental Filing to their October 4, 1986, Amended Complaint if the Court deems this to be legally required and that it be deemed by the Court to set forth the evidentiary basis upon which a reasonable person drawing all logical inferences from the facts adduced in the direction of the Plaintiffs would conclude that it is more probable than not that each of the Defendants named in this civil suit is guilty of violating the Federal RICO Statute and that he is civilly liable to the Plaintiffs Tony Avirgan and Martha Honey for having fortuitously contributed to the civil wrongs committed against them as charged in this Amended Complaint as Supplemented by the Affidavit of Counsel.
ATTORNEY DANIEL SHEEHAN'S AFFIDAVIT
Now comes Attorney Daniel P. Sheehan, and having been duly sworn hereby swears and affirms that the following facts are true:
1. I am a duly licensed attorney at law, admitted to practice before the State and Federal Courts of the State of New York in both the Northern and Southern Districts of New York.
2. I am duly licensed and have been admitted to practice before the Courts of the District of Columbia, both local and Federal and I am in good standing before both the Bar of New York and the Bar of the District of Columbia.
3. I have practiced law before the courts of New York and numerous other states in our nation since 1970, having served as counsel in some 60 separate pieces of litigation in the states of New York, Pennsylvania, North Carolina, Virginia, the District of Columbia, Georgia, Florida, Oklahoma, Ohio, Colorado, Idaho, Nebraska, South Dakota, Wyoming and Mississippi.
4. I graduated from Harvard college in 1967 as an Honors Graduate in American Government, writing my Honors Thesis in the field of Constitutional Law, and was the Harvard University nominee for the Rhodes Scholarship from New York in 1967. I graduated from Harvard School of Law in 1970, having served as an Editor of the Harvard Civil Rights Civil Liberties Law Review and as the Research Associate of Professor Jerome Cohen, the Chair of the International Law Department of Harvard.
5. While at Harvard School of Law, I served as a summer associate at the State Street law firm of Goodwin, Proctor and Hoar under the supervision of Senior Partner, Donald J. Hurley, the President of the Boston Chamber of Commerce and Massachusetts Senatorial Campaign Chairman for John F. Kennedy. At this firm I participated in the case of BAIRD v EISENSTAT, under Roger Stockey, General Counsel for the Massachusetts Planned Parenthood League (establishing the unconstitutionality of the Massachusetts anti-birth control law and in the Nevada case, under Charles Goodhue, III (establishing the constitutional right to bail in criminal extradition cases, including capital cases). While at Harvard School of Law, I authored "The Pedestrian Sources of Civil Liberties" in the Harvard Civil Rights Civil Liberties Law Review and I served under Professor Milton Katz, the President of the International Law Association, as the Chairman of the Nigerian Biafran Relief Commission responsible for successfully negotiating the admission of mercy flights of food into Biafra in 1968.
6. While serving as a legal Associate at the Wall Street law firm of Cahill, Gordon, Sonnett, Rheindle and Ohio under partner Theodore Shackley and Thomas Clines directed the Phoenix Project in Vietnam, in 1974 and 1975, which carried out the secret mission of assassinating members of the economic and political bureaucracy inside Vietnam to cripple the ability of that nation to function after the total US withdrawal from Vietnam. This Phoenix Project, during its history, carried out the political assassination, in Vietnam, of some 60,000 village mayors, treasurers, school teachers and other non-Viet Cong administrators. Theodore Shackley and Thomas Clines financed a highly intensified phase of the Phoenix project, in 1974 and 1975, by causing an intense flow of Vang Pao opium money to be secretly brought into Vietnam for this purpose. This Vang Pao opium money was administered for Theodore Shackley and Thomas Clines by a US Navy official based in Saigon's US office of Naval Operations by the name of Richard Armitage. However, because Theodore Shackley, Thomas Clines and Richard Armitage knew that their secret anti-communist extermination program was going to be shut down in Vietnam, Laos, Cambodia, and Thailand in the very near future, they, in 1973, began a highly secret non-CIA authorized program Thus, from late 1973 until April of 1975, Theodore Shackley, Thomas Clines and Richard Armitage disbursed, from the secret, Laotian-based, Vang Pao opium fund, vastly more money than was required to finance even the highly intensified Phoenix Project in Vietnam. The money in excess of that used in Vietnam was secretly smuggled out of Vietnam in large suitcases, by Richard Secord and Thomas Clines and carried into Australia, where it was deposited in a secret, personal bank account (privately accessible to Theodore Shackley, Thomas Clines and Richard Secord). During this same period of time between 1973 and 1975, Theodore Shackley and Thomas Clines caused thousands of tons of US weapons, ammunition, and explosives to be secretly taken from Vietnam and stored at a secret "cache" hidden inside Thailand.
The "liaison officer" to Shackley and Clines and the Phoenix Project in Vietnam, during this 1973 to 1975 period, from the "40 Committee" in the Nixom White House was one Eric Von Arbod an Assistant Secretary of State for Far Eastern Affairs. Von Arbod shared his information about the Phoenix Project directly with his supervisor Henry Kissinger.
Saigon fell to the Vietnamese in April of 1975. The Vietnam War was over.
Immediately upon the conclusion of the evacuation of U.S. personnel from Vietnam, Richard Armitage was dispatched, by Theodore Shackley and Thomas Clines, from Vietnam to Tehran, Iran. In Iran, Armitage (the "bursar" for the Vang Pao opium money for Shackley and Clines' planned "Secret Team" covert operations program), between May and August of 1975, set up a secret "financial conduit" inside Iran, into which secret Vang Pao drug funds could be deposited from Southeast Asia. The purpose of this conduit was to serve as the vehicle for secret funding by Shackley's "Secret Team," of a private, non-CIA authorized "Black" operations inside Iran disposed to seek out, identify, and assassinate socialist and communist sympathizers who were viewed by Shackley and his "Secret Team" members to be "potential terrorists " against the Shah of Iran`s government in Iran. In late 1975 and early 1976, Theodore Shackley and Thomas Clines retained Edwin Wilson to travel to Tehran, Iran to head up the "Secret Team" covert "anti-terrorist" assassination program in Iran. This was not a U.S. government-authorized operation. This was a private operations supervised, directed and participated in by Shackley, Clines, Secord and Armitage in their purely private capacities.
At the end of 1975, Richard Armitage took the post of a "Special Consultant" to the U.S. Department of Defense regarding American military personnel Missing In Action (MIAs) in Southeast Asia. In this capacity, Armitage was posted in the U.S. Embassy in Bangkok, Thailand. There Armitage had top responsibility for locating and retrieving American MIA's in Southeast Asia. He worked at the Embassy with an associate, one Jerry O. Daniels. From 1975 to 1977, Armitage held this post in Thailand. However, he did not perform the duties of this office. Instead, Armitage continued to function as the "bursar" for Theodore Shackley's "Secret Team," seeing to it that secret Vang Pao opium funds were conducted from Laos, through Armitage in Thailand to both Tehran and the secret Shackley bank account in Australia at the Nugen-Hand Bank. The monies conducted by Armitage to Tehran were to fund Edwin Wilson's secret anti-terrorist "seek and destroy" operation on behalf of Theodore Shackely. Armitage also devoted a portion of his time between 1975 and 1977, in Bangkok, facilitating the escape from Laos, Cambodia and Thailand and the re-location elsewhere in the world, of numbers of the secret Meo tribesmen group which had carried out the covert political assassination program for Theodore Shackley in Southeast Asia between 1966 and 1975. Assisting Richard Armitage in this operation was Jerry O. Daniels. Indeed, Jerry O. Daniels was a "bag-man" for Richard Armitage, assisting Armitage by physically transporting out of Thailand millions of dollars of Vang Pao's secret opium money to finance the re-location of Theodore Shackley's Meo tribesmen and to supply funds to Theodore Shackley's "Secret Team" operations. At the U.S. Embassy in Bangkok, Richard Armitage also supervised the removal of arms, ammunition and explosives from the secret Shackley-Clines cache of munitions hidden inside Thailand between 1973 and 1975 for use by Shackley's "Secret Team". Assisting Armitage in this latter operations was one Daniel Arnold, the CIA Chief of Station in Thailand who joined Shackley's "Secret Team" in his purely private capacity.
One of the officers in the U.S. Embassy in Thailand, one Abranowitz came to know of Armitage's involvement in the secret handling of Vang Pao opium funds and caused to be initiated an internal State Department heroin smuggling investigations directed against Richard Armitage. Armitage was the target of Embassy personnel complaints to the effect that he was utterly failing to perform his duties on behalf of American MIAs, and he reluctantly resigned as the D.O.D. Special Consultant on MIA's at the end of 1977.
From 1977 until 1979, Armitage remained in Bangkok opening and operating a business named The Far East Trading Company. This company had offices only in Bangkok and in Washington, D.C. This company was, in fact, from 1977 to 1979, merely a "front" for Armitage's secret operations conducting Vang Pao opium money out of Southeast Asia to Tehran and the Nugen-Hand Bank in Australia to fund the ultra right-wing, private anti-communist "anti-terrorist" assassination program and "unconventional warfare" operation of Theodore Shackley's and Thomas Cline's "Secret Team". During this period, between 1975 and 1979, in Bangkok, Richard Armitage lived in the home of Hynnie Aderholdt the former Air Wing Commander of Shackley`s "Special Operations Group" in Laos who, between 1966 and 1968, had served as the immediate superior to Richard Secord, the Deputy Air Wing Commander of MAG / SOG. Secord, in 1975, was transferred from Vietnam to Tehran, Iran.
In 1976, Richard Secord moved to Tehran, Iran and became the Deputy Assistant Secretary of defense in Iran, in charge of the Middle Eastern Division of the Defense Security Assistance Administration. In this capacity, Secord functioned as the chief operations officer for the U.S. Defense Department in the Middle East in charge of foreign military sales of U.S. aircraft, weapons and military equipment to Middle Eastern nations allied to the U.S.. Secord's immediate superior was Eric Van Marbad the former 40 Committee liaison officer to Theodore Shackley's Phoenix program in Vietnam from 1973 to 1975.
From 1976 to 1979, in Iran, Richard Secord supervised the sale of U.S. military aircraft and weapons to Middle Eastern nations. However, Richard Secord did not authorize direct nation-to-nation sales of such equipment directly from the U.S. government to said Middle Eastern governments. Instead, Richard Secord conducted such sales through a "middle-man", one Albert Hakim. By the use of middle-man Albert Hakim, Deputy Assistant Secretary of Defense Richard Secord purchased U.S. military aircraft and weapons from the U.S. governament at the low "manufacturer's cost" but sold these U.S. aircraft and weapons to the client Middle Eastern nations at the much higher "replacement cost". Secord then caused to be paid to the U.S. government, out of the actual sale price obtained, only the lower amount equal to the lower manufacturer's cost. The difference, was secreted from the U.S. government and Secord and Albert Hakim secretly transferred these millions of dollars into Shackley's "Secret Team" operations inside Iran and into Shackley's secret Nugen-Hand bank account in Australia. Thus, by 1976, Defendant Albert Hakim had become a partner with Thomas Clines, Richard Secord and Richard Armitage in Theodore Shackley's "Secret Team".
Between 1976 and 1979, Shackley, Clines, Secord, Hakim, Wilson, and Armitage set up several corporations and subsidiaries around the world through which to conceal the operations of the "Secret Team". Many of these corporations were set up in Switzerland. Some of these were: (1) Lake Resources, Inc.; (2) The Stanford Technology Trading Group, Inc.; and (3) Companie de Services Fiduciaria. Other companies were set up in Central America, such as: (4) CSF, Investments, Ltd. and (5) Udall research Corporation. Some were set up inside the United States by Edwin Wilson. Some of these were: (6) Orca Supply Company in Florida and (7) Consultants International in Washington, D.C.. Through these corporations, members of Theodore Shackley's "Secret Team" laundered hundreds of millions of dollars of secret Vang Pao opium money pilfered Foreign Military Sales proceeds between 1976 and 1979. named in this federal civil suit to be placed under oath and asked about their participation in the criminal "enterprise" alleged in this Complaint is probative of the criminal guilt of the Defendants of some of the crimes charged in this Complaint.
Plaintiffs and Plaintiffs' Counsel, The Christic Institute, possess evidence constituting "probable cause" that each of the Defendants named in this Complaint are guilty of the conduct charged.
If further detailed evidence is required by the Court to allow the Plaintiffs to begin the standard process of discovery in this case, the failure to place it in this Affidavit is the function of the short time allowed by the Court for the preparation of this filing it is not because the Plaintiffs lack such evidence.
Daniel P. Sheehan
Subscribed and Sworn to before me this day of December, 1986
We are engaged in a silent war. Those waging this brutal conflict have not the decency to inform their victims who include ourselves and almost everyone we know. Their standard bearers include George Bush and David Rockefeller. As the high priced professional liars in the mass media assure us all is well, the common people of the world are being crushed like foot soldiers over run by a panzer division.
And yet, the only real power of these perpetrators derives only from this force fed ignorance. Apart from the power to keep us fighting each other, the Monopolists have no power. If a critical mass of people can learn the information contained herein, and what is more important, the sources of this information, a global reign of terror will end.
These articles are taken from my monthly column in MONETARY AND ECONOMIC REVIEW. I am also the Director of Research for INTELLIGENCE CONNECTION a speakers agency that arranges events on university campuses for front line researchers, like those mentioned in these articles. My name is Brian Quig.
You can arrange speaking events with any of these legendary people by
6950 E. Continental Blvd Ste. 7000
Scottsdale AZ 85257
N. C. O. I. C.
Civil Intelligence Association
Defense Oversight Group