DECLARATION OF F. CLINTON BRODEN
F. Clinton Broden, pursuant to 28 C.F.R. ¤ 16.23, being at least eighteen years of age, deposes and states as follows:
1. I am licensed to practice law in the States of California and Texas and the District of Columbia. In addition, I am admitted to practice before the United States Court of Appeals for the Fifth Circuit and the District Courts for the Southern District of California, the Central District of California, the District of Columbia, the Eastern District of Texas and the Northern District of Texas.
2. I represent XXXX XXXX XXXX in the above-styled action.
3. I anticipate the possibility that employees of the Department of Justice, Doug Tramel, Andrew Pearce and Scott Wagner, may be called as a witness in the above styled case.
4. The testimony sought regards their participation as members of the "MET team" in conducting surveillance and undercover purchase of illegal drugs in Denison, Texas during the period of on or about April 21, 1999 until on or about November 1, 1999.
I declare under penalty of perjury that the foregoing is true and correct. Executed on this day of January, 20, 2000.