IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TEXAS
AUSTIN DIVISION

STEVE JACKSON GAMES
INCORPORATED, STEVE JACKSON,
ELlZEBETH McCOY,
WALTER MILLIKEN, and
STEFFAN O'SULLIVAN

     Plaintiffs,                      Civil Action No.
                                        A 91   CA 346
           vs.

UNITED STATES SECRET SERVICE, 
UNITED STATES OF AMERICA,
WlLLlAM J. COOK,
TIMOTHY M. FOLEY,
BARBARA GOLDEN,
and HENRY M. KLUEPFEL,

                Defendants.

________________________________________________________

DECLARATION OF WILLIAM COOK 

I, William J. Cook, pursuant to 28 U.S.C. Ą 1746, hereby
declare that:
 ­ 
 1. I am an Assistant United States Attorney for the Northern
District of Illinois.
 ­ 
 2. On July 3, 1989, I learned from Henry Kluepfel, an
employee of Bellcore investigating unauthorized entries into the
computer system of BellSouth, that he had discovered the presence
of BellSouth proprietary information, specifically material
regarding the operation of BellSouth's emergency 911 system, on a
public access computer bulletin board system known as JOLNET,
located in Lockport, Illinois.
 ­ 
 3. Kluepfel also conveyed his information to Special Agent


of his application for a search warrant for the premises of the
business known as Steve Jackson Games.

 4. In preparing the draft of the search warrant application
and the supporting affidavit with Special Agent Foley, I relied
upon information provided by Bellcore and BellSouth regarding the
proprietary nature of the stolen E911 document. In a letter dated
January 10, 1990, Kimberly M. Megahee, Staff Manager-Security,
Southern Bell, reaffirmed that the stolen E911 practice was
proprietary in nature and listed costs associated with its
preparation totalling $79,449. At the time I drafted the search
warrant application with Foley's assistance, I did not know that
much of the proprietary information contained in the stolen E911
document had arguably been disclosed to civic organizations in Ohio
by Ohio Bell. It was not until July, 1990, during the trial of
Craig Neidorf, that I learned of this possible disclosure.

 5. At the time that the search warrant applicatil application was made 
I did not know that Steve Jackson Games held itself out as a
publisher. I believed that Steve Jackson Games was involved with
the manufacture of computer or video games.

 6. The purpose of the search warrant was to obtain any
documents in the possession or control of Loyd Blankenship which
might be located at Steve Jackson Games and which might evidence
his involvement in interstate transportation of the stolen E911
document or in password cracking activity. At the time of the
search warrant application, I was unaware of the existence of the
book known as GURPS Cyberpunk or any other publication by Steve
Jackson Games.

 7. On March 22, 1990, I had a conversation with Steve Jackson
at which time he agreed that a p[assword cracking program found on

 p 9. At no time did I intercept any electronic communications
made by, addressed to or concerning any of the plaintiffs in this

 8. On August 10, 1990, I forwarded to plaintiffs' attorneys
copies of all documents contained in item 17 of the inventory of
seized items.  The orginals of these documents, which consisted
of Legion of Doom Technical Journals and other hacker related
notes, were retained as part of the ongoing investigation of Loyd
Blankenship.

 9.  At no time did I intercept any electronic communications
made by, addressed to or concerning any of the plaintiffs in this
case. Similarly, I did not read any stored electronic
communications made by, addressed to or concerning any of the
plaintiffs.

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

Executed on 8/1/91
(signed) WILLIAM COOK