by Margaret Wiencek
February 7, 1993
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AFFIDAVIT OF MARGARET WIENCEK
The INSLAW CASE:
AFFIDAVIT OF MARGARET WIENCEK
State of California, County of Los Angeles
I, MARGARET WIENCEK, after being duly sworn state as follows:
1. Between January, 1987 and October 1990, I was employed at the Financial News Network (FNN) located in Los Angeles, California as Director of Administration and Assistant to C. Steven Bolen, Chief Financial Officer.
2. During this period of time, Dr. Earl W. Brian was Chief Executive Officer (CEO) and Chairman of the Board and C. Steven Bolen was Chief Financial Officer (CFO) of FNN. Dr. Brian and Mr. Bolen also served during this same period as CEO and CFO, respectively, of Infotechnology (INFOTECH) and United Press International (UPI).
3. During part of my tenure as Director of Administration in
1987, I reported directly to C. Steven Bolen and had occasion to
become familiar with the names of parties who communicated with
Mr. Bolen by telephone.
4. Peter Vedinecks and Michael Riconisuitto (as I am unaware of the proper spelling of these individuals' names, I have spelled them phonetically as I would have done on any phone log when uncertain of the spellings of names) were individuals who made several phone calls to FNN during the first quarter of 1987 asking for Mr. Bolen and/or Dr. Earl W. Brian and leaving messages for Mr. Bolen and/or Dr. Earl W. Brian requesting that Mr. Bolen and/or Dr. Earl W. Brian return calls. I took several phone messages for Mr. Bolen from both of these individuals during this period of time. All messages were kept by way of phone message/log books and were maintained and logged by the person taking the calls. I have never met nor seen either of the individuals (Vedinecks/Riconisuitto). The only way I have knowledge of these individuals is thru phone calls/messages from these individuals to Mr. Bolen and/or Dr. Earl W. Brian.
5. In the course of my official duties, I became aware of a file in Mr. Bolen's office marked M.I.S. that contained copies of correspondence relating to the PROMIS computer software product. Dominick Laiti, then CEO of Hadron, Inc., a company controlled by Dr. Earl W. Brian through Infotechnology, Inc. was either the author or recipient of the letters in question in this file. It
is my understanding that M.I.S. is a common abbreviation for Management Information Systems and that PROMIS is a management information system for case tracking and workflow management applications.
6. All phone records and documentation that may pertain to the calls (see paragraph 5 above) and file (see paragraph 6 above) for this time period were packed by me to be put in storage some time during 1988. In 1988 these items and all other items that pertain to this period of time were then moved to a new location of FNN. When FNN dismissed the entire Accounting and Administration Staff (of which I was a part), the documentation which is mentioned in paragraphs 5 and 6 above, as well as any and all other documentation was packed up by the person(s) that dismissed the staff as well as person(s) that were asked to help pack from other related companies of Dr. Earl W. Brian's (i.e., ACS, Hadron, etc.). All of these items were then shipped the same day as the dismissals were made (October 16, 1990). These items were boxed and shipped via airplane to 9990 Lee Highway -- Fairfax, Virginia -- in care of Atlantic Contract Services (ACS) and/or the Jim Arnold's Law Firm (Corporate Attorney to FNN, Infotech, Hadron, etc.).
7. I was requested to write this Affidavit at the request of Special Agent Scott Lawrence, United States Custom Service, concerning my knowledge of Peter Vedinecks and Michael Riconisuitto [Riconosciuto] as they relate to Dr. Earl W. Brian.
I have made the foregoing statement consisting of two pages. I understand this statement and it is true, accurate and complete to the best of my knowledge and belief. I made this statement freely and voluntarily without any threats or rewards, or promises of reward having been made to me in return for it.
FURTHER AFFIANT SAYETH NOT.
[signed] Margaret Wiencek
SIGNED AND SWORN TO BEFORE ME THIS 7th DAY OF FEBRUARY, 1993.
[Witnessed by two Special Agents,
U.S. Customs, Office of Internal
Affairs]