UNITED STATES DISTRICT COURT 
WESTERN DISTRICT OF TEXAS
AUSTIN DIVISION

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

ÿPlaintiffs,ÿÿ             ÿÿ Docket No. A 91 CA 346

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

ÿDefendants.

____________________________________________________
ÿðÿ
DECLARATIONÿÿOFÿÿWAYNEÿÿBELLÿÿ

I, Wayne Bell, hereby declare that:
ÿðÿ
ÿ1. I am an adult resident of Los Angeles, California,
where I am employed as a computer programmer at TRW Space and
Defense Systems.
ÿðÿ
ÿ2. I am the designer of WWIV, a computer program used
to operate electronic bulletin board systems. WWIV software
is used on over 1000 bulletin board systems in the United
States and throughout the world.
ÿðÿ
ÿ3.ƒ I also have considerable experience in methods of
data recovery and use of disk-examination programs such as
Norton Utilities. I have designed a commercially published
program called Colorzap that is similar to Norton Utilities.
ÿðÿ
ÿ4. I have examined multiple disks sent to me by Steve
Jackson, of Steve Jackson Games, Inc., containing data,
including data files of electronic mail, from the Illuminati
BBS.
ÿðÿ
 5. My examination reveals that the Illuminati BBS was
run with WWIV software.

ÿ6. My examination of the electronic mail files reveals
that electronic mail was stored on the Illuminati BBS as of
March 1, 1990.

ÿ7. My examination of the electronic mail files reveals
that Steve Jackson, Walter Milliken, Elizabeth McCoy, and
Steffan O'Sullivan were all parties to electronic mail
communications that were stored on the Illuminati BBS as of
March 1, 1990.

ÿ8. My examination of the electronic mail files further
reveals that the following users last logged onto the
Illuminati BBS on the following dates:

ÿÿGremlyn ÿ#ÿ285              -- February 24, 1990

 ÿElric ÿ#ÿ136                -- February 14, 1990

ÿÿThrinn Tu ÿ#ÿ153            -- January 30, 1990
ÿðÿ
Any electronic mail sent to these users after the dates
listed above would not have been received by them as of March
1, 1990. Any electronic mail sent to these users on the
dates listed above may not have been received by them as of
March 1, 1990.

ÿ9. My examination of the electronic mail files further
reveals that on March 20, 1990, each piece of electronic mail
stored in the electronic mail file was systematically read
and deleted.

ÿ10. I have reviewed the declaration of Laurence Boothby
declaring that Mr. Boothby used "Norton Utilities to
electronically sweep through the bulletin board contents for
key words." The procedure described by Mr. Boothby would not
have left the traces I observed on the electronic mail files
from the Illuminati BBS and would not have caused the
deletion of the electronic mail.

I declare under penalty of perjury that the foregoing is
true and correct.
Executed on: 9/30/91ÿ
ÿðÿ
(signed) WAYNE BELL