Affidavits, Declarations and Statements

August 27, 1984

Declaration of Karen Davidson re: Date-stamping of CID Receipt for Cathy Perry's clothing and boots


I Karen R. Davidson, declare as follows:

(1) I am an attorney at law admitted to practice in the State of California and the Federal District Court for the Central District of California.

(2) I worked on the post-trial remedies for the defendant Jeffrey R. MacDonald in the case captioned United States v. Jeffrey R. MacDonald, Case No. 75-26-CR-3 in the United States District Court for the Eastern District of North Carolina from November 11, 1982 through February 15, 1984.

(3) As a part of my duties in the case, I reviewed the trial transcripts as well as the reports of investigation prepared by the United States Army and the United States Department of Justice.

(4) As part of my duties in this case, I reviewed all materials received pursuant to Dr. MacDonald's FOIA requests. I monitored the receipt of material and was involved in any necessary follow-up, e.g., telephone calls, letters and appeals.

(5) Our office received FOIA information from the Department of the Army, the Department of Justice and the FBI. The FBI deleted names from the records they provided us while the United States Army CID did not always do so. In reading through both the FBI and CID material and cross- referencing them, the defense was able to discern in many instances whose names had been deleted from the FBI material. It was through such a procedure that I was able to determine that Agent Tool had debriefed Agent Medlin.

(6) Our office first learned of Cathy Perry's clothing and boots through a CID receipt which we obtained through the FOIA. I remember personally sorting through the FOIA materials and discovering this CID receipt. The reason it is not date-stamped is due to the nature of our office procedure pertaining to "date stamping." Although every piece of paper which came in through FOIA was in theory date stamped, at times only the face page of materials which were stapled together was in fact date stamped. The CID receipt was among a group of papers stapled together and through inadvertence it was not date stamped.

I declare under penalty of perjury that the foregoing is true and correct.

Executed this 27th day of August 1984 at Santa Monica, California

Karen R. Davidson

Subscribed and sworn to before me this 27th day of August, 1984 at Santa Monica, California

Peggy R. Seary
Notary Public in and for said Country and State
My commission Expires Oct. 13, 1987