by Ari Ben-Menashe
March 21, 1991
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AFFIDAVIT OF ARI BEN-MENASHE
The INSLAW CASE: AFFIDAVIT OF ARI BEN-MENASHE
UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF COLUMBIA
In Re:
INSLAW, INC., Debtor.
CASE NO. 85-00070
(Chapter 11)
________________________________
INSLAW, INC., Plaintiff
v.
UNITED STATES OF AMERICA and the UNITED STATES DEPARTMENT OF JUSTICE, Defendants.
CASE NO. 85-00070
Adversary Proceeding
NO. 86-0069
AFFIDAVIT OF ARI BEN-MENASHE
STATE OF KENTUCKY )
) ss
CITY OF LEXINGTON )
I, ARI BEN-MENASHE, being duly sworn, do hereby state as follows:
1. Between August 1977 and September 1987, I was employed by the Israel Defense Forces (IDF)/Military Intelligence External Relations Department.
2. In my above capacity, I had contacts with the Office of the Israeli Prime Minister's Anti- Terrorism Advisor.
3. In 1982, the Israeli Prime Minister's Anti-Terrorism Advisor was Mr. Rafael Eitan.
EXHIBIT 2
4. In a meeting that took place in December 1982 in Mr. Eitan's office in the Kirya in Tel Aviv, Israel, Mr. Eitan told me that he had received earlier that year in the United States, from Mr. Earl W. Brian and Mr. Robert McFarlane, PROMIS computer software for the limited use of the IDF's Signals Intelligence Unit for intelligence purposes only. Mr. Eitan stated on this occasion, and on earlier occasions as well, that he had special relationships with both Mr. Brian and Mr. McFarlane.
5. This meeting took place in the context of a visit by a foreign dignitary. During a break in the meeting, Mr. Eitan took me aside and gave me the above facts to relate to my superiors so that Mr. Eitan's office could take credit for the introduction of the PROMIS computer software into IDF's Signals Intelligence Unit.
6. I hereby certify that the facts set forth in this Affidavit are true and correct to the best of my knowledge.
FURTHER AFFIANT SAYETH NOT.
Signed: Ari Ben-Menashe
Signed and sworn to before me this 21st day of March, 1991.
Melissa J. Corbett
Notary Public
My Commission Expires: June 14th, 1994