IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

________________________________________
					)
PHILIP R. KARN, Jr.			)
					)
		Plaintiff,		)
					)	Civ. A. No. 95-1812(CRR)
	v.				)
					)	(Judge Charles R. Richey)
U.S. DEPARTMENT OF STATE, and		)
THOMAS E. MCNAMARA,			)
					)
		 Defendants.		)
					)
________________________________________)

DECLARATION OF BARBARA TUTHILL IN SUPPORT OF PLAINTIFFS' OPPOSITION TO DEFENDANTS' MOTION TO DISMISS

I, Barbara Rae Tuthill, do hereby state and declare as follows:

1. I make this declaration in support of the plaintiffs' opposition to the defendants' Motion to Dismiss.

2. I am employed by the firm of Venable, Baetjer & Howard as a secretary in the McLean, Virginia office. I have been a secretary for 16 years.

3. At the request of Kenneth C. Bass, III, a partner in our D.C. office, I created, with the assistance of another secretary in our office (Barbara Birdsong ), a document on our firm's word processing system by typing in the material on the pages attached as Exhibit A to this declaration.

4. At Mr. Bass' direction, we did not type the highlighted material which in each case begins with a "/*" and ends with a "*/". Ms. Birdsong and I timed our typing and the total combined time that it took us to type in the material in the 18 pages attached as Exhibit A was 2.77 hours

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

					[signed]
					Barbara Tuthill

Date:  December      ,1995