THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF ARKANSAS
WESTERN DIVISION

JAY CAMPBELL AND
KIRK LANE
PLAINTIFFS

vs.

NO. LR-C-97-0328

CITIZENS FOR AN HONEST GOVERNMENT, INC.,
D/B/A INTEGRITY FILM; JEREMIAH FILM, INC.
AND PAT MATRISCIANA
DEFENDANTS

AFFIDAVIT

I, Jean K. Duffey, after being duly sworn, state the following;,

1. I was appointed Seventh Judicial District Deputy Prosecutor on January 1, 1989.

2. In March of 1990, I was appointed to head a newly funded drug task force for the district. I hired seven undercover officers, and we were up and running by the end of April.

3. My officers linked drugs to public officials almost immediately after beginning their undercover activities, and Dan Harmon was the name linked most frequently. My officers developed informants who told them Harmon used and distributed drugs and warned dealers when the law was getting too close.

4. My task force officers and I took our intelligence reports to Assistant U.S. Attorney Bob Govar, who had been conducting a federal grand jury investigation of public official corruption and drug trafficking since the middle of 1989.

5. After I was fired in November of 1990, Govar was ousted from the case, and U.S. Attorney Chuck Banks cleared Dan Harmon and all Saline County officials, my husband and I moved our family to Texas and began teaching school.

6. I was not involved again until March of 1994, when FBI Agent Phyllis Cournan persuaded me to assist her in investigating the train deaths. I was reluctant until she told me the FBI had recommended Banks be charged with obstruction of justice for shutting down the federal grand jury probe.

7. After the FBI slammed the door on Linda Ives, she requested and received a copy of the entire Arkansas State Police file under the FOIA. She had most of the pertinent interviews before, but after we were able to study the file in its entirety, we developed an understanding about how the investigation was conducted. As an ex-Deputy Prosecuting Attorney, my opinion is the interviews were conducted at random and the investigation had little or no direction. There are gaping holes in the file, and the absence of information is as significant in some cases as the presence of information. Linda and I believe important information was ignored, discounted, or falsely discredited.

8. I was asked during my deposition on April 8, 1998 if the Arkansas State Police reports which had been introduced through Pat Matrisciana were the only ones I am aware of that mention Jay Campbell and Kirk Lane. I am not aware of others mentioning Campbell and Lane, but there are reports that show a lack of interest in investigating Campbell and Lane and other reports that clearly try to protect them. Three were fabricated.

9. There is no report in the State Police file of an interview or of any attempt to interview Donna Morrissey or Cindy Lewis. There is no State Police report of an interview with Betty Alexander, Keith Coney's mother.

10. There is no report in the State Police file of any attempt to corroborate the existence of a third boy with Kevin Ives and Don Henry near Ranchette Grocery Store or the railroad tracks the night they were murdered. There were several rumors about the third boy being Keith Coney, and even after he was killed the State Police did not interview his mother, Betty Alexander, who thinks Keith was murdered because he knew too much about the Ives/Henry murders, and stated so during a television news interview.

11. There are at least three State Police reports that were fabricated according to Ronnie Godwin's mother, Jodie McKenzie. McKenzie told Linda Ives and me she was never interviewed by the State Police and neither was Ronnie's sister or his girl friend. McKenzie is willing to testify to that under oath. Those reports are attached to this affidavit.

12. A State Police report submitted by Sgt. Barney Phillips on June 29, 1990, announced that a witness to the beatings known only as "Jerry" is actually Ronnie Godwin. The statement is arbitrary and gives no explanation whatsoever as to how such a conclusion was drawn Simply from reading the two interviews of Godwin and the interview of Mike Crook, who reports what "Jerry" told him, it is easy to see Godwin and "Jerry" are not the same person. The Phillips report is attached to this affidavit.

13. The Phillips report makes even less sense if Mike Crook, owner of GiGi's, knew Ronnie Godwin, and there is no indication in the State Police file that he didn't. In fact, another report submitted by Phillips of an interview with Sammie Smith, a GiGi's employee makes it apparent Crook did know Godwin. According to Smith, Godwin was a member of Gigi's. The Smith interview is attached to this affidavit.

14. In another state police report, Inv. Dale Swesey tries to discredit Ronnie Godwin by making reference to a time frame given to him by Godwin that is not in either of the ports of Godwin's interviews. Even if Godwin did say something about being off during the time of the incident, as Swesey indicates, Godwin's employment records show he worked only 8 hours during the week ending August 22, 1987. The boys were murdered the night of August 22-23, 1987. Given the fabricated reports already discovered and the great lengths to discredit Godwin, I tend to believe Godwin may have said something about being off the night he witnessed the assault, and Swesey changed the facts to fit his intended purpose to discredit Godwin. Swesey's report is attached to this affidavit.

15. It is suspicious enough that the State Police made no effort to corroborate Godwin and every effort to discredit him, which might could be dismissed as incompetence, but fabricating reports makes a cover-up very clear. Linda and I strongly believe Jay Campbell and Kirk Lane are the killers, and that they are being protected.

16. During my deposition of April 8, 1998, page 37, lines 18-20, I recalled reading something where "Richard Garrett verified that Ronnie Godwin had described another person that fit the description of Kirk Lane." I couldn't remember, at the time of depositions, where I had read that. Now I recall it was in an affidavit of R. David Lewis (DX 3A-1 at 1 3). I was mistaken about the Garrett naming Ronnie Godwin as the witness who gives a description of Kirk Lane. Garrett did not identify the witness he references.

17. The only clue anywhere in the State Police report about a second officer's description is that the officer fitting the description of Jay Campbell is the larger of the two. Lane is, in fact, smaller than Campbell. The two men who abducted Ives and Henry were in an unmarked police car. Also, Dan Harmon told Linda Ives there are descriptions from an eyewitness that meet those of both Jay Campbell and Kirk Lane, and Harmon told her that the car was like the one driven by Campbell and Lane. Linda and I believe Garrett and Harmon knew of another witness other than Godwin. Godwin does not describe Lane. This verifies that Jerry, who does name Lane, is a second witness. This is very likely since Harmon headed the Saline County Special Grand Jury and Garrett assist. They had control of all the information coming in during the year-long probe. We now know they orchestrated a cover-up of the murders.

18. During my deposition, I responded to a question about the statements in Obstruction of Justice naming lay Campbell and Kirk Lane as suspects in the murders and cover-up. I turned to look Jay Campbell straight in the eye and said, "my personal belief is that they are absolutely the two murderers." (Duffey deposition, page 60, lines 10-15) Campbell looked away. He is not a tunic man. To the contrary, he has a forceful and intimidating presence. This gesture spoke as loudly to me as a written confession from him

19. In March of 1994, FBI Agent Phyllis Cournan contacted me through my brother, David Keesee, and persuaded me to get involved with her investigation of the Ives/Henry murders. She told me the FBI recommended U.S. Attorney Chuck Banks be charged with obstruction of justice for shutting down the 1990 federal grand jury investigation and clearing Dan Harmon and all other Saline County public officials of any wrong doing.

20. I spent many hours on the phone with Cournan from March to November of 1994. I spoke with her several time a week about Saline County corruption and the murders of Kevin Ives and Don Henry. Our conversations were far beyond her conducting an interview of "all past investigators on the case" as she said in her deposition of April 17, 1998. (Cournan deposition, page 11, lines 4-5. I take great offense to ha dishonesty. She sought my advice and direction. She confided many personal concerns to me. She told me the case was causing her to feel overly paranoid, she was fearing for her safety, and she was sleeping with a gun. She said she thought her superiors were watching her closely and might try to discredit her if she made any mistakes.

21. Cournan called in a panic on a Friday night in the fall of 1994. I was not home and my husband took a message that I was to call when I returned. I got in late and didn't call, so Cournan called early the next morning, which was Saturday. She said an informant heard Joe Kelly Hardin and Robert Shepherd talking about Harmon having me killed and putting my body on the tracks.

22. I recall a conversation with Cournan, late in 1994, about Linda's strong believe that Campbell and Lane were involved in the murders. I knew Cournan was conducting polygraphs during that time period. I asked her if she was going to polygraph them and she said "they" were not going to let her polygraph Campbell and Lane because they were cops. She said she would have to have a lot more on them, and I reminded her that she had my drug task force note summaries which frequently bring up Jay Campbell and Kirk Lane being linked to illegal activity.

23. I warned Cournan in early 1995, that the signs of a shut-down were visible to me. She argued with me and asked, "Who has the power to shut down an FBI investigation?" She said she had several other male agents involved in the case who felt very strongly that it was a good case. At this point, Cournan seemed determined to find justice.

24. Things changed in late 1995. Phyllis Cournan exchanged her integrity for her job. I do not know what caused her to flip-flop, and I was surprised that she did. Perhaps she was pressured because of threats of an internal investigation which was conducted in 1996. Perhaps this was the vehicle used to "whip her into shape."

25. The focus of the investigation was Cournan's statement to several people about the FBI recommending Chuck Banks be charged with obstruction of justice for shutting down the 1991 grand jury investigation. An investigator flew from Washington D.C. for the sole purpose of interviewing my brother, David Keesee, about the statement. Two FBI investigators came to my home in Pasadena to interview me. After the interview, one of the Houston investigators told my husband and me he saw nothing wrong with Cournan telling Duffey about Banks if that's what persuaded me to get involved in the case again. Although I do not know the outcome of that investigation, I do know that Cournan reversed her position about the murders, and that she still has her job with the FBI.

26. I taped a telephone conversation with Phyllis Cournan on December 16, 1996 while at Linda Ives' home. Pertinent parts are transcribed on an attached page to this affidavit. In that conversation, Cournan verified that the FBI was protecting Harmon and that government official corruption would be easy to prove if Linda files a civil suit. I asked her the status of the recommendation that Chuck Banks be charged with obstruction of justice, but she would only comment, "you're going to get me fired." A copy of that audio tape has been given to defendants' attorney.

27. There are corrections that need to be made in my deposition:

Page 45, line 10: expose should be protect
Page 67, line 18: $32,000 should be $3,000
Page 88, line 10: Harry should be Larry
Page 99, line 1: Sill should be Seal
Page 118, line 1 : Mike should be Ronnie

Throughout the deposition: Charlene should be Sharline Maura should be Mara

[Signature]
Jean K. Duffey

VERIFICATION
STATE OF ARKANSAS
COUNTY OF PULASKI

I, Jean K. Duffey, do hereby swear the above statements are true and correct to the best of my recollection and belief.

[Signature]
Jean K, Duffey

SUBSCRIBED AND SWORN to before me this 28th day of May, 1998.

[Notarized]
My Commission Expires:
9/1/00

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