DECLARATION OF HOWARD SPARKS

I, Howard Sparks, hereby state, under oath, as follows:

• I am a career civil servant currently employed at the Clinton-Gore White House's Office of Administration (OA). I have worked for the Executive Office of President ("EOP") since 1987. I currently hold the rank of GS-14 and had been both Branch Chief and Acting Branch Chief for Network Infrastructure. The Network Infrastructure Division falls under OA's Information Systems and Technology ("IST") division. I am currently a network specialist in the Network Infrastructure division.



• When the Clinton-Gore White House first came to power in 1993, Jim McDonald, who was then the director of the IST division, and I met with Mike Gill, a political aide to Vice President Gore who served as his information specialist. At this meeting, we carefully explained to Mr. Gill the legal requirement that the Office of the Vice President ("OVP") manage its electronic records. We explained that this could be done by OA by backing up the OVP electronic records on tape and maintaining these back-up tapes for potential legal proceedings. Mr. Gill did not care about these legal requirements and essentially told us to get lost, that the Vice President's Office would take care of its own records. Being in no position to contradict a top political aide to the new Vice President, we let the matter drop. If our advice had been followed, the year's worth of OVP e-mail (March, 1998 - April, 1999) that was reported "lost" last week by the Clinton-Gore White House would still be in existence, as they would have been properly backed up by OA.



• In fact, Mr. Gill was nicknamed the "Mad Deleter." This nickname referred to his propensity to delete electronic records as a method of dealing with computer-related problems.



• Early in the Clinton-Gore Administration, I attended a few Clinton-Gore White House meetings on the White House Office Database ("WHODB"). I quickly came to the conclusion, based on those meetings, that what was being requested for the WHODB appeared to be illegal, in that the project called for the use of taxpayer resources to track political contributions and other improper information. I made my concerns about this database known to my supervisors at the time, such as Jim McDonald, who was then head of IST. As a result of my concerns about the legality of the WHODB, I walled myself off from it and refused to participate in its development.



• I believe, in part because of my concerns about WHODB, that I was retaliated against by the Clinton-Gore White House. Participating in this retaliation were individuals such as Charles Benjamin, who was head of the IST division for a time. As part of that retaliation, I was "idled" for about two years - in other words, made to sit in an office all day with little or nothing to do.



• Shortly after Vincent Foster died in July, 1993, I received a call from Jim McDonald, who wanted me to meet him outside to go for a ride with him. During that ride, Mr. McDonald informed me that he had found Vincent Foster's computer in a hallway in the West Wing. In the wake of the mysterious circumstances surrounding Mr. Foster's death, Mr. McDonald was extremely upset by his discovery and he told me that he was concerned that he would be killed because of what he had found. To the best of my knowledge, this computer is currently wrapped in plastic and stored in a computer parts "depot" in the New Executive Office Building. As far as I know, this computer was never turned over to investigators. I was told by a colleague at OA that this computer has no data on it, though I am not aware if the data ever existed, or if it was simply deleted or if the computer's entire hard disk was "wiped clean."



• In June or July, 1998, I learned about the Project X e-mail from Robert Haas. Haas came into my office and told me about Project X and the threats of jail made to him by Laura Crabtree. Based on my experience working with her, I believed that Laura Crabtree was more than capable of making such threats -- it was perfectly in character for her. Haas told me he had many e-mails which referred to Monica Lewinsky and that he believed many other e-mails existed among the Project X e-mail that were responsive to other "FOIA's" (Freedom of Information Act). Computer personnel in OA used the term "FOIA" as a short-hand for all types of document search requests, whether they were subpoenas or document requests from independent counsels, Congress, or Plaintiffs in this case. In other words, I understood Haas to mean that he believed that the Project X e-mail referred to other Clinton-Gore scandals then under investigation, such as Filegate and Chinagate.
• It was my experience that the ARMS system was inadequate in terms of its search capabilities and I lobbied within OA repeatedly for upgrades to the ARMS system to make its searches more thorough and efficient. The ARMS system simply could not (and does not) do what it is legally required to do -- manage in a word-searchable format certain computer documents for the EOP. Despite my oft-repeated concerns, OA never acted on my suggestions.

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

Executed on June 19, 2000 in Washington, DC. _____________________

Howard Sparks