INSLAW: Affidavit of Richard Babayan

The INSLAW CASE: AFFIDAVIT OF RICHARD H. BABAYAN

UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF COLUMBIA


IN RE:                        )
                              )    Case No. 85-00070
INSLAW, INC.,                 )    (Chapter 11)
               Debtor.        )
____________________________  )
                              )
INSLAW, INC.,                 )
               Plaintiff,     )
                              )    Adversary Proceeding
UNITED STATES OF AMERICA,     )    No. 86-0069
and the UNITED STATES         )
DEPARTMENT OF JUSTICE,        )
                              )
              Defendants,     )
____________________________  )


AFFIDAVIT OF RICHARD H. BABAYAN

State of Florida     )
                     )     ss:
Palm Beach County    )

I, Richard H. Babayan, being duly sworn, do hereby state as 
follows:

1. During the past several years, I have acted as a broker of sales 
of materials and equipment used by foreign governments in their 
armed forces, intelligence and security operations.

2. In the capacity described in paragraph #1, I attended a meeting 
in Baghdad, Iraq, in October or November, 1987, with Mr. Abu Mohammed of 
Entezamat, an intelligence and security organ of the Government of
Iraq. Mr. Abu Mohammed is a senior ranking official of Entezamat and a
person with whom I had had extensive dealings over the previous three years.

EXHIBIT 3

3. During the aforementioned meeting with Mr. Abu Mohammed, I was informed
that Dr. Earl W. Brian of the United States had recently completed a sales
presentation to the Government of Iraq regarding the PROMIS computer software.
Furthermore, it is my understanding that others present at Dr. Brian's PROMIS
sales presentation were General Richard Secord, of the United States, and
Mr. Abu Mohammed.

4. In early to mid-1988, in the course of subsequent visits to
Baghdad, Iraq, I was informed that Dr. Earl W. Brian had, in fact, provided
the PROMIS computer software to the Government of Iraq through a transaction
that took place under the umbrella of Mr. Sarkis Saghanalian, an individual
who has had extensive business dealings with the Government of Iraq since
the late 1970's in the fields of military hardware and software. I was also
informed that the Government of Iraq acquired the PROMIS software for use
primarily in intelligence services, and secondarily in police and law
enforcement agencies.

5. During the course of the visits described in paragraph #4, I also 
learned from Mr. Abu Mohammed that the Government of Libya had 
acquired the PROMIS computer software prior to its acquisition by the
Government of Iraq; that the Government of Libya had by then made extensive
use of PROMIS; and that the Government of Libya was highly recommending the
PROMIS software to other countries. I was informed that the high quality of
the reference for the PROMIS software from the Government of Libya was one
of the principal reasons for the decision of the Government of Iraq to
acquire PROMIS.

6. In the capacity described in paragraph #1, I attended a meeting 
in early 1988 in Singapore with Mr. Y. H. Nam of the Korea Development 
Corporation.

7. The Korea Development Corporation is known to be a cutout 
for the Korean Central Intelligence Agency (KCIA).

8. I learned from Mr. Y. H. Nam during the meeting described in 
paragraph #6 that the KCIA had acquired the PROMIS computer software, and 
that Dr. Earl W. Brian of the United States had been instrumental in the
acquisition and implementation of PROMIS by the KCIA.

9. In the capacity described in paragraph #1, I attended a meeting 
in Santiago, Chile, in December, 1988, with Mr. Carlos Carduen of 
Carduen Industries. During this meeting, I was informed by Mr. Carduen 
that Dr. Earl W. Brian of the United States and Mr. Robert Gates, a senior
American intelligence and national security official, had just completed a
meeting in Santiago, Chile, with Mr. Carlos Carduen.

10. 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: Richard A. Babayan

Signed and sworn to before me this 22nd day of March, 1991.
Milton E. Shepard
Notary Public
My Commission Expires:
NOTARY PUBLIC STATE OF FLORIDA
MY COMMISSION EXP, NOV.15,1991
BONDED THRU GENERAL INS. UNO.