I, ROBERT J. CIPRIANO, do hereby declare as follows:
1. I am a resident of New York City, New York. I own Transact Resources International at 230 Park Avenue, Suite 1000, New York City, New York, 10169. I am 32 years of age and am married.
2. Between 1980 and 1985 I was a partner with New York attorney Jerome L. Spiegelman in a company called Cipriano Enterprises. From 1984 the company was located at 303-305 East 53rd Street, New York City, New York. Cipriano Enterprises was an entertainment-talent agency-management company. Mr. Spiegelman's primary occupation was practicing law. My primary occupation was running Cipriano Enterprises. I have never been an attorney.
3. Beginning in May 1984, Mr. Spiegelman former a law partnership with another attorney named Graham E. Berry. Mr. Berry is from New Zealand. Mr. Spiegelman and Mr. Berry operated their law practice at 303-305 East 53rd Street, New York City. Their offices were on the second floor directly above a gay nightclub called "Round" which they both frequented.
4. Between May 1984 and February 1985 when I left New York City for Los Angeles, California, I had numerous contacts, conversations and observations of Mr. Berry and Mr. Spiegelman. I observed both men frequently abuse cocaine and both were practicing homosexuals who admitted preferring young underage men for sexual gratification. Mr. Berry was a classic example of a "Chicken Hawk," which in street vernacular is a term for an adult male who has sexual relations with boys under the age of sixteen.
5. Mr. Berry would routinely tell me, in graphic detail, about his sexual exploits with boys under the age of sixteen. Mr. Berry told me that he would sodomize these boys and have them orally copulate his penis. Between May 1984 and February 1985 I personally observed at least 50 to 60 boys between the ages of 14 and 16 in the company of Mr. Berry at the law firm on East 53rd Street. He frequently pointed out which boy he had had sex with and would tell me all about it in detail. Mr. Berry would also frequently have these young boys perform odd jobs at the law firm, usually in exchange for cocaine which he would provide them. I observed such exchanges numerous times. Mr. Berry told me his New Zealand accent was found to be attractive by these boys.
6. I also observed a side of Mr. Berry which I felt was even "seedier." He used to frequent the Anvil Club in Greenwich Village in New York City. Homosexual males at the club would orally copulate and sodomized each other in open view of the other patrons. Inside the club they also practices sadistic and masochistic sex acts upon each other, including inserting their greased hand up the rectum of the other and placing their penis through a hole in the wall, commonly called a "glory hole," where an anonymous male would orally copulate it.
7. Mr. Berry once told me about taking a boy of twelve years of age to the Anvil Club for the purpose of introducing him to gay sex.
9. In about 1984 I met a 22 year old homosexual man named David Lee who was working as a production assistant for Coast to Coast Productions in New York City. I then hired him to work for Cipriano Enterprises at our offices on East 53rd Street. Mr. Berry was living in a homosexual relationship with Mr. Lee at that time and I believe Mr. Lee subsequently introduced Mr. Berry to Mr. Spiegelman.
9. I recall that immediately prior to Mr. Berry becoming a partner in the Spiegelman & Berry law firm he had just broken up his relationship and law partnership with a New York City attorney named Frank Hoffey. I also recall that Mr. Spiegelman represented Mr. Berry in a subsequent law suit that Mr. Berry brought against Mr. Hoffey. This lawsuit and the alleged injustices that Mr. Hoffey brought upon Berry were frequently discussed in the office by Mr. Berry.
10. Mr. Spiegelman and Mr. Berry became partners because Mr. Berry had several clients in the entertainment, male modeling and night club scene in New York City. Mr. Berry was frequently surrounded by young attractive male models some below the age of 16 who he used for sex. Because Mr. Spiegelman also enjoyed engaging in sexual acts with these type of young men and boys and because he wanted to also practice entertainment law, he agreed to let Mr. Berry become his partner.
11. I also recall that Mr. Berry represented the owners of a night club called Studio 54 in New York City. As a result, Mr. Berry never had to pay for anything he consumed at the club. He was treated like a celebrity. Mr. Berry frequently invited Mr. Spiegelman and I to be his guests at Studio 54. We were also treated like VIPs. The patrons of Studio 54 were approximately 50% homosexual.
I declare under the penalty of perjury that the previous statements are true and correct. Signed this 5th day of May 1994 in New York City, New York.
ROBERT J. CIPRIANO
[ Dead-agenting of Graham Berry ]