I, Mark A. Venuti, declare:

1. On March 8, 1988, I was called by William Wardlaw and informed that on March 4, 1988, Officer Crutchfield of the D.C. Jail confiscated the legal papers of William Thomas and did not return them when Mr. Thomas was transferred from the D.C. Jail to the Loudon County jail.

2. On March 8, 1988, I called the D.C. Jail and spoke to the Commander. The Commander informed me that the federal authorities do not allow any property to go with a prisoner when the prisoner is transferred. He assumed that Mr. Thomas was a federal prisoner and that he might go to Loudon County on route to a federal destination. The Commander stated that Mr. Thomas's property would be sent to whatever forwarding address he had listed on a form with the D.C. Jail.

3. On March 17, 1988, I called Winifred Gallant, who lives at 1440 N Street, N.W., Washington, D.C., which address is used by William Thomas to store personal belongings; I called Ms. Gallant to find out whether Mr. Thomas's papers had been delivered there because, as far as I knew, that would be the logical place for Mr. Thomas to list as a forwarding address with the D.C. Jail. Ms. Gallant informed me that no papers had yet been received.

4. On March 17, 1988, I called the D.C. Jail and was told that Officer Crutchfield was out but the records showed that Mr. Thomas's property was sent out on March 10. 1988: the records did not state to what destination; the person I spoke with assumed that the property would be sent to whatever forwarding address had been listed by Mr. Thomas.

5. On March 24, 1988, I received a call from William Wardlaw who stated that Mr. Thomas still had not received his legal papers and, so far as he knew, Mr. Thomas had not left a forwarding address at the D.C. Jail.

6. On March 25, 1988, I called the D.C. Jail and was told that either Officer Smith or Officer Warren would call me to help with this problem over Mr. Thomas's papers.

7. On March 29, 1988, having received no call, I called the D.C. Jail and spoke to Officer Smith regarding Mr. Thomas's papers, and Officer Smith told me he would check and call me back. Officer Smith called me back that day and told me he found a box of Mr. Thomas's papers and needed a notarized letter from Mr. Thomas authorizing me or someone else to pick them up. I wrote such a statement and sent it to Mr. Thomas for his signature at the Loudon County Jail.

8. Mr. Thomas signed the authorization statement on March 31, 1988, and some time after that William Wardlaw, using the statement, picked up the papers at the D.C. Jail.

I declare under penalty of perjury that the above statements are true and correct to the best of my knowledge, information and belief.

/s/Mark A. Venuti
August 15, 1988
Mark A. Venuti