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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK
snd
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA,

- against -
PREHISES KNOWN AND DESCRIBED AS:
1 THE NATIONAL OFFICE OF THE
PROVISIONAL PARTY OF COMMUNISTS,
APARTMENT ZA, 1107 CARROLL STREET,
BROOKLYN, NEW YORK
2. TAE LAW OFFICES OF DANIEL
FOSTER AND ASSOCIATES AND THE
OFFICE OF GIN0 PARENTI, BOTH
OFFICES OCCUPYING THE PREMISES
OF AND KNOWN AS APARTMENT lA,
1107 CARROLL STREET, BROOKLYN,
NEW YORK
3. THE DOCTOR'S OFFICE, APARTPlENT
1A. 1115 CARROLL STREET, BROOKLYN,
NEW YORK
4. THE BASEMENTS OF THREE ADJOINING
FOUR-STORY A P A R W BUILDINGS
KNOWN AS 1107, 1111 and 1115
CARROLL STREET, BROOKLYN, NEW
YORK
5. THE GROUND FLOOR PREMISES
(AND ANY AREAS APPURTENANT THERETO)
ALSO KNOWN AS THE DESIGN STUDIO
OF JADE BEHAR-TRGVES. 354 W L D

6. THE PENTHOUSE APARTMENT OF DR.

ALAN PI. BERKOWITZ KNOWN AS APART-
MENT 15A. 145 WEST 55TH STREET,
NEWYORK, NEWY0P.K

EASTERN DISTRICT OF NEW YORK

and
SOUTHERN DISTRICT OF NEW YORK. SS:
NEIL E. BEFXAN, being duly sworn, deposes and
says that he is a special Agent of the Federal Bureau of
Investigation (FBI), New York Division, Joint Terrorist
Task Force, duly appointed according to law and acting as
 -.-
Your deponent has reason to believe that on the
premises known and described as:
I. THE NATIONAL OFFICE OF THE
PROVISIONAL PARTY OF COMMUNISTS,
APARTMENT 2A, 1107 CARROLL STREET,
BROOKLYN, NEW YORK
2. THE LAW OFFICES OF DANIEL
FOSTER AND ASSOCIATES AND THE
OFFICE OF GIN0 PARENTI, BOTH
OFFICES OCCUPYING THE PREMISES
OF AND KNOWN AS APARTMENT lA,
1107 CARROLL STREET, BROOKLYN,
NEW YORK
3. THE DOCTOR'S OFFICE, APARTMENT
lA, 1115 CARROLL STREET, BROOKLYN,
NEW YORK
4. THE BASEMENTS OF THREE ADJOINING
FOUR-STORY APARTMENT BUILDINGS
KNOWN AS 1107, 1111 and 1115
CARROLL STREET, BROOKLYN, NEW
YORK
5. THE GROUND FLOOR PREMISES
(AND ANY AREAS APPURTENANT THERETO)
ALSO KNOWN AS THE DESIGN STUDIO
OF JADE BEHAR-TREVES, 354 GOLD
STREET, BROOKLYN, NEW YORK
within the Eastern District of New York and
6. THE PENTHOUSE APARTMENT OF DR.
ALRN M. BERKOWITZ KNOWN AS APART-
MENT 15A, 145 WEST 55TH STREET,
NEW YORK, NEW YORK
within the Southern District of New York, is being
concealed certain property, namely: weapons (rifles,
handguns and machineguns) and other military equipment
including uniforms; explosives and bomb making equipment;
all records of the Provisional Party of Communists (PPC)
 - .r.
relating to the purchase, storage, location and disposal of
weapons, ammunition and explosives; all books, documents
and records outlining the PPC's plans for an armed
insurrection against the lawful authority of the United
States Government; all records relating to planned
terrorist activities; all records of the "Military
Fraction" of the PPC including, but not limited to, records
detailing planned military activities directed against the
lawful authority of the United States Government, records
detailing planned terrorist activities, records concerning
the location of "Military FractionN headquarters, records
relating to the location of weapons, ammunition and
explosives, records relating to the purchase, storage and
disposal of weapons, ammunition and explosives, records
relating to the identity of those individuals making up the
"Military FractionIt of the PPC and records relating to the
system of communications among and between the different
locations of the "Military Fraction" of the PPC; and the
books and records of Foxfire Enterprises, Inc.; which
property is evidence and instrumentalities of a criminal
offense, to wit, carrying of weapons during the commission
of a felony prosecutable in a court of the United States,
e.g., the possession of firearms not registered to the
possessors in the National Firearms Registration and
Transfer Record in violation of 26 U.S.C. §5861(d), in
violation-of Title 18, United States Code, Section
924(c)(2); the possession of firearms not registered to the
possessor in the National Firearms Registration and
Transfer Record in violation of Title 26, United States
Code, Section 5861(d); the corrupt endeavoring to obstruct
and impede the due administration of justice in violation
of Title 18, United States Code, Section 1503; and the
making of materially false statements and representations
in a matter within the jurisdiction of a department or
agency of the United States in violation of Title 18,
United States Code, Section 1001.
The source of your deponent's information and the
grounds for his belief are:
1. A confidential source (hereinafter referreb
to as CS1) is a member of the Provisional Party of
Communists (PPC) and has provided information to agents of
the Federal Bureau of Investigation (FBI) over the last
five months. CSl's information has come from the
indoctrination and teachings CS1 has received as a member
of the PPC, from the documents generated by the PPC which
Csl has examined, from conversations CS1 has had with other
members of the PPC and from the things CS1 has done as a
member of the PPC. The following information has been
supplied by CS1 except where explicitly noted:
 A. The PPC was founded in
approximately 1971 by a group of
individuals, including Reymundo Pena,
Eugenio Parente and Toni Orendain. The
PPC was founded to be a revolutionary
communist party whose goal is that of
seizing control of the government of
the United States through military
force. CS1 was told repeatedly, over a
period of more than one year, in
indoctrination sessions and in
conversations with members, that the
United States government would be
seized, through a coup on February 19,
1984. This incident is scheduled to
begin at midnight on February 18, 1984.
The coup will include a general strike
on both the east and west coasts by
unions under the control of the PPC; a
national press conference; and
agressive military action on a
nationwide basis by the military arm of
the PPC. (Because of the secretive
nature of the PPC and because CS1 is
not a member of the military arm of the
PPC, CS1 does not know the nature of
the military action which the PPC
contemplates). The party members
believe that in less than two days the
U.S. government will be under their
control.
B. Following the founding of the
PPC, a lengthy constitution and a
statement of principles were written
which defined the organization's
structure and intent. CS1 has informed
the FBI that the constitution and the
statement of principles identify the
group as the PPC, USA, and as the
Provisional Wing of the Party of Lenin.
These documents refer to the ". . .
closed, narrow and secret party of
Lenin as the vehicle of revolution
. . .I1
C. CS1 stated that the party
underwent a major change in 1979.
prior to 1979, the party was "all talk"
.-
with members "sitting around smoking
dope in back rooms,i1with little being
accomplished. In 1979, the party
shifted from I1defensevf
to an "acute
offensive1I phase. The new phase banned
drugs and sex in order to become more
efficient and instituted a ilmilitaryii
type discipline. Each member began to
operate on the basis of a daily "Battle
Plan," in which each cadre member's day
is accounted for, in writing, on a 24
hour basis.
D. At present, the PPC is
divided into numerous divisions which
are referred to as ilfractions.u All of
these are open to any full party member
(cadre), with the exception of the
military fraction, which is considered
secret or vlclosed.llThe military
fraction is by far the largest with
many members of other fractions also
holding military assignments. CS1
stated that the Ifmilitaryfraction' is
paramount since an loarmedcoupli to
overthrow the U.S. government is the
only purpose for the party's existence.
Other fractions are used for
recruitment, fund-raising and for
legitimacy. CS1 states that membership
in the military unit appears to be by
invitation only, after at least one
year as a full cadre member. During
the first year, a continuing series of
written evaluations are made and a
course of regular instruction is
undergone. This instruction is through
a controlled reading schedule, lectures
and ideological orientation.
E. CS1 observed that at least
forty to fifty percent of full cadre
members, who have been full members for
one year, are in the military. Almost
all of those who have been full members
for two or three years are in the
military fraction. Military
assignments are frequently considered
an extra job, in addition to a
.-.-
political or recruiting assignment.
For example, a full time ItPolitical
Commissar" would probably be a military
member.
F. Since the ttmilitaryfractiontt
is considered secret, military duties,
assignments, weapons and techniques are
not discussed with members outside of
the military. CS1 stated this
discipline is fairly rigidly enforced.
CS1 described the military as
disciplined, and as taking their duties
seriously. Uniforms are worn during
special events and regular weekly
drills take place. CS1 knows very
little of these drills, because CS1 is
not a member of the military fraction.
G. CS1 states that numerous
'fronttt organizations, mostly unions,
are run and controlled from the
national office in Brooklyn, New York.
These include the National Labor
Federation (NLF) (an umbrella
organization over the other labor
organizations), the Eastern Service
Workers Association (ESWA), the Western
Service Workers Association (WSWA), the
Eastern Farm Workers Association
(EFWA), the California Homemakers
Association (CHA), the Northwest
Seasonal Workers Association (NWSWA),
the Western Mass Labor Action and the
Texas Farm Workers Association (TFWA).
CS1 indicates that the PPC controls
these and other labor organizations
through persons who head them who are
"cadrettmembers of the PPC.
H. CS1 has informed the FBI that
one of the front organizations that the
PPC uses is called Foxfire Realty or
Foxfire Breeding and Development
Corporation (hereinafter referred to as
Foxfire). (The correct name of Foxfire
as shown on the certificate of
incorporation is Foxfire Enterprises,
Inc., see 716, infra). Foxfire owns
--
and operates three buildings at 1107,
1111 and 1115 Carroll Street, Brooklyn,
New York. These buildings house
different operations controlled by the
PPC, including the national office of
the party, the law firm of Daniel P.
Foster and Associates and a doctor's
office. CS1 states that these latter
two entities are controlled by the PPC
because they are staffed and run by
full cadre members.
I. The national office of the
PPC is located at 1107 Carroll Street,
Apt. 2A, Crown Heights, Brooklyn, New
York. All operations, except on the
west coast, are run from this location
and from the law office in the
apartment directly below it. (See fls
J, K, M and N, infra). The existence
of this office and-its functions are
considered secret by the PPC.
J. CSl advised that the military
fraction is headquartered at 1107
Carroll Street, Crown Heights,
Brooklyn. Records and files of the
military fraction are filed in the law
office of Daniel Foster (a full cadre
member), on the first floor of that
building in Apt. 1A. These records and
files are concealed in a closet in the
reception room of this office and
constitute the administrative,
personnel and financial records of the
military fraction. CS1 states that
this area is considered to be an
extremely secure place by members of
the PPC.
K. CS1 states that the Daniel
Foster law office does not contain
individual offices for the attorneys.
The attorneys work anywhere they can
find a place to sit and write. CS1
states that the records of the PPC are
found all over the law office. The law
office, although doing some outside
---.
l e g a l work, i s used a c t i v e l y t o conduct
t h e PPC n a t i o n a l o f f i c e business.
L. CS1 s t a t e s t h a t t h e c u r r e n t
working f i l e s of t h e PPC a r e a l s o t o be
found throughout apartment 2A, 1107
Carroll Street, the national office.
The f i l e s of Foxfire a r e t o be found i n
t h e "Runkle Room" which i s a room i n
the middle of t h e n a t i o n a l o f f i c e near
t h e kitchen of t h e apartment.
M. C S 1 s t a t e d t h a t Gino
(Eugenia) P a r e n t i i s t h e l e a d e r of t h e
PPC. P a r e n t i a l s o uses t h e name Victor
Ramos i n connection with h i s work f o r
t h e PPC. CS1 has examined photographs
of J e r i W i l l i a m Doeden ( s e e lis 13, 14
and 15, i n f r a ) and has i d e n t i f i e d
Doeden a s t h e man CS1 knows a s "Gino
P a r e n t i . " C S 1 s t a t e s t h a t Gino
Parentits office i s i n the f i r s t floor
apartment occupied by Daniel Foster and
Associates (Apt. lA, 1107 C a r r o l l
S t r e e t ) . P a r e n t i ' s o f f i c e i s t h e room
f a c i n g t h e s t r e e t . I t i s t h e only
p r i v a t e o f f i c e i n t h e whole PPC C a r r o l l
S t r e e t complex. This o f f i c e i s c a l l e d
t h e f i e l d command o f f i c e . P a r e n t i
u s u a l l y s l e e p s i n h i s o f f i c e and spends
most of h i s time t h e r e . A c i t i z e n s
band r a d i o base s t a t i o n i s located i n
P a r e n t i ' s o f f i c e , a s well a s a l a r g e
safe.
N. The f i n a n c i a l records of t h e
PPC a r e kept u s u a l l y i n two p l a c e s , i n
P a r e n t i t s o f f i c e and a t t h e o p e r a t i o n ' s
desk i n t h e room j u s t behind t h e f r o n t
room of t h e n a t i o n a l o f f i c e .
0. CS1 has t o l d t h e FBI t h a t
s e c u r i t y a t t h e n a t i o n a l o f f i c e of t h e
p a r t y i s extremely r i g i d . A lookout i s
posted on a 24 hour b a s i s i n t h e f r o n t
bay window of t h e apartment which
houses t h e n a t i o n a l o f f i c e , Apt. 2A,
1107 C a r r o l l S t r e e t . The l o o k o u t t s
duty i s t o warn t h e n a t i o n a l o f f i c e of
--
the approach of any enemies (i.e.,
police, FBI, etc.). CS1 has stated
that a military officer is assigned as
"commanding officer of the day," every
day. When t h e lookout sees something
suspicious, the commanding officer of
the day is called, by intercom, C.B.
radio, or simply shouting. After
responding to the lookout window, an
alert may be called. This alert may be
only an increased level of 81watch,1tin
which instance members may act as
lookouts from other windows, doors may
be locked and military members may go
to the roof to obtain a better view of
the area. The highest level of alert
is called going into "re~eivership.~~
On these occasions, only military
members are allowed to exit the room in
which they are located and firearms
appear very quickly. CS1 stated that
alerts are called frequently. CS1 has
seen armed members appear in each room,
within seconds. Discipline during
these periods is very strict.
P. CS1 holds the firm opinion
that if law enforcement attempted "a
raid," bloodshed would follow. CS1
feels that most, if not all, of the
military members, would use their
weapons because they believe they are
engaged in armed revolution.
Q. CS1 has observed within the
last 18 months large numbers of
firearms at the national office on a
number of occasions. A room referred
to at the national office as Itthecave"
houses what CS1 estimates to be over
100 firearms. On one occasion, CS1
observed two or three racks of rifles,
which looked like AK-47's and military
style M-1 carbines. Additionally,
several olive-drab duffel bags in the
room contained unknown type firearms.
The "cave" is a room in the front of
the second floor apartment (Apt. 2 A )
-.-
occupied by the national office at 1107
Carroll Street.
R. CS1 has observed large
numbers of firearms being removed from
t h e national office on several
occasions. CS1 stated that military
members have made two or more trips out
of the apartment housing the national
office carrying two duffel bags of
weapons each trip. CS1 believes that
the weapons were taken to special
events, involving the top party
leaders, who are usually guarded by the
military fraction.
S. CS1 has stated to agents of
the F B I that during the last few
months, the party has been working at a
fever pitch to prepare for the
revolution (February 18-19, 1984).
Since CS1 is not a member of the
military fraction, CS1 is not aware of
the specific plans for military action.
CSl is aware, however, that one of the
party's major efforts over the last few
months has been in the area of fund
raising. CS1 has heard that the PPC
through one of its legitimate fronts is
trying to obtain a $200,000 loan from a
suffolk County bank. The party is
planning to take this loan and use it
to secure a $400,000 loan. Members of
the PPC believe that they will have
raised $1,700,000 by February 1, 1984
for use in the revolution.
T. CS1 indicates that Polly Mary
Gardner is National Commanding Officer
of the military fraction and a National
Political Commissioner.
U. CS1 states that the PPC is
run in a military fashion. Detailed
records are kept on almost every aspect
of the lives of the members of the PPC.
The telephone is rarely used. Orders
are sent between the national office in
Brooklyn and the regional offices by
..
courier. When members of the PPC
travel anywhere, they always are given
a cover story to tell if stopped by the
authorities.
V. The PPC has a number of "safe
houses1'in the New York metropolitan
area. CS1 knows of a penthouse
apartment and office that are used
exclusively for secret party purposes
at 145 West 55th Street or 155 West
45th Street. CS1 indicates that this
is one of the party's most secret
locations. CS1 has slept on occasion
at a safe house which is the design
studio of Jade Behar-Treves. CS1
states that the studio is listed under
Behar-Treves' name in the white pages
of the telephone directory. (The
Brooklyn telephone book lists Jade
Behar-Treves at 354 Gold Street,
Brooklyn, telephone number 237-2378.
New York Telephone Co. informed agents
of the FBI that the telephone with that
number is installed in the ground floor
premises of 354 Gold Street, Brooklyn,
New York.) CS1 states that current PPC
records are in use at the Behar-Treves
premises and that in a file cabinet
marked I1CDR,"the PPC stores the cadre
systems files.
W. A number of attorneys are
cadre of the PPC. Among these are
Kathryn (Kit) Decious and Kathy Paolo.
CS1 states that Foxfire uses Kathy
Paolo's apartment, 195 Adam Street,
Apartment 7E, Brooklyn as the address
for the corporation. CS1 also believes
that some cadre sleep in that
apartment. It is also used as the
address for the law firms controlled by
the PPC.
X. CSl states that the party
will hold a televised press conference
at the Hyatt Hotel in New Brunswick,
New Jersey. CS1 states that during the
press conference in order to maximize
 13.
--
publicity, a PPC member will fire a gun
at objects on the walls. CS1 is also
aware of a sniper incident, planned to
occur at the same time as the press
conference. CS1 has learned that a
cadre member of the military fraction
will fire a rifle or shotgun at a
tractor-trailer on a highway near New
Brunswick, New Jersey. From
conversations which CS1 has overheard
between members of the PPC, CS1
believes that these incidents are not
the "military actionl1 planned by the
PPC to accompany the revolution, but
are only devices designed to attract
attention to the press conference.
Y. CS1 states that except, for
the basement, 1111 Carroll Street
houses no PPC establishments. All the
apartments in that building are
commercially rented by Foxfire. Apt.
1A in 1115 Carroll Street is the
doctor's office. The doctor's office
is used as a commercial doctor's office
during the day. The doctor and staff
are cadre members. At night it is used
for PPC meetings and briefings, and
cadre members sleep there. The only
PPC files in the doctor's office of
which CS1 knows are the "cadre medical
record^.^^ CS1 says that these latter
contain little or no medical
information and are more like personnel
records. The doctor's office also has
a C.B. radio. CS1 states that the
doctor's office is guarded 24 hours a
day.
2. CS1 states that the basements
of the three buildings are used
actively for party purposes. The PPC
has cut a passageway through the
basements between the three buildings
to connect 1107 through to 1115.
AA. Within the past five days,
CS1 has viewed at 1107 Carroll Street
the following: In the office of Gino
 --
P a r e n t i , C S 1 saw two handgernades with
p i n s i n P a r e n t i ' s desk and on t h e f l o o r
a l a r g e s u i t c a s e containing numerous
small s i l v e r colored automatic weapons.
On a t a b l e i n the same room, CS1 saw
f o u r .357 magnum p i s t o l s . I n a c l o s e t
adjacent t o P a r e n t i ' s desk C S 1 saw a
r i f l e . CS1 saw a number of boxes of
ammunition i n t h e room. C S 1 s t a t e d
t h a t Gino P a r e n t i was c a r r y i n g two
pistols.
BB. Within t h e p a s t f i v e days C S 1
has observed two o t h e r persons- a t t h e
n a t i o n a l headquarters c a r r y i n g p i s t o l s .
C S 1 observed i n a desk drawer i n
apartment 2A a t 1107 C a r r o l l S t r e e t ,
one small s i l v e r p i s t o l and one p i s t o l
with a wooden handle and a long b a r r e l .
A d u f f l e bag propped a g a i n s t t h e wall
i n apartment 2A had a r i f l e b a r r e l
protruding from i t s top.
CC. During a conversation which
C s l had with Gino P a r e n t i within t h e
l a s t f i v e days, P a r e n t i s t a t e d t h a t
during t h e p r e s s conference scheduled
on February 18, 1984 "we w i l l have a
s n i p e r on Route 1" r e f e r r i n g t o t h e
i n c i d e n t a s described i n BX, supra.
P a r e n t i a l s o s t a t e d t h a t he had never
fought i n h i s l i f e and does n o t know i f
he w i l l be a coward b u t added, "We w i l l
have t o f i g h t f o r t h r e e days.It
DD. C S 1 s t a t e s t h a t t h e premises
of t h e n a t i o n a l o f f i c e , P a r e n t i ' s
o f f i c e and t h e law o f f i c e a r e being
used t o C S 1 9 s knowledge from
observations within t h e l a s t f i v e days
t o s t o r e records a s l a i d o u t above i n
B s J, K, L, N, and U , supra.
2. On November 10, 1983, agents of t h e FBI
contacted a member of t h e United S t a t e s Army who w i l l be
r e f e r r e d t o h e r e a f t e r a s CS2. CS1 had t o l d the FBI t h a t
 --
CS2 had left the party in 1983 and that the party had been
upset and had tried to locate CS2. CS1 stated that CS2 had
been a member of the military fraction although not an
officer thereof and that CS2 would know something of the
structure and purposes of the PPC.
3. Initially during the interview with the FBI
agents, CS2 was untruthful refusing to reveal his knowledge
of the PPC. When confronted with the agents1 detailed
knowledge of the PPC, however, reluctantly and grudgingly
provided the following information:
A. CS2 stated that in
approximately 1979, CS2 joined the
National Labor Federation (NLF) after
hearing Gino Parenti speak about it.
CS2 learned that the NLF was seeking
revolutionary change to occur in the
United States through the network of
organizations which the NLF had
established and that the revolution
could come through a variety of means.
B. CS2 stated that the NLF had
chosen the date of February 19, 1984
for the revolution to occur. This date
was set arbitrarily as far as CS2
knows, and has been the same since CS2
joined the organization. CS2 explained
that the NLF believes they could bring
about a revolution on this date by
starting a nationwide strike by the
organizations controlled by the NLF
which would cause chaos due to
corporations across the country losing
workers.
C. CS2 stated that the NLF has
its headquarters at 1107-1111-1115
Carroll Street, Brooklyn, New York. On
the second floor of the buildings a
--
sentry is kept 24 hours a day to
provide security and to report any
strange police activity. The sentry
keeps notes on any vehicles on the
Elock, especially police vehicles, and
reports this to Polly Gardner, the
military commander.
D. CS2 explained that CS2 was a
member for one year before CS2 was
asked to join the military section of
the group which is actually called t:
military fraction by members. CS2
stated that the military fraction
provided security at meetings and held
military type drills. CS2 stated that
after joining the military fraction
sometime in 1980-1981, Gino Parenti
called him into a room on the second
floor of 1107 Carroll Street called the
"Cave" and showed him the contents of
that room. CS2 stated that
approximately one year later he was
again in this room. CS2 advised that
on both occasions CS2 observed weapons
described as follows:
One Thompson submachine gun
One FNFAL (Belgian assault rifle)
Five rifles
One . 4 5 caliber revolver
One . 4 5 caliber automatic
Two .38 caliber revolvers
Assorted handgun ammunition
CS2 described Parenti as holding
himself out as a mercenary and that the
"Cave' was a room over which Parenti
had control.
E. CS2 also stated that the
group stored food, clothing, uniforms
 17.
--
and auto parts in the basements of
1107, 1111 and 1115 Carroll Street.
4. Five days after CS2 was interviewed by the
FBI, he deserted from the U.S. Army. He has not been heard
from since. CS1 has not heard that CS2 has had any contact
with the party since CS2's desertion from the Army. Your
deponent believes that CS2 has most likely gone into hiding
from both the FBI and the PPC. Other persons who leave the
PPC show great fear of the party and your deponent has
heard that upon occasion members of the party who want to
leave the party are held against their will at the national
headquarters or other PPC locations (see e.g. paragraphs 9
and 10).
5. In December of 1981, agents of the FBI spoke
to a former member of the PPC who will be referred to as
provided the following information:
A. CS3 became involved with the
PPC through association with the
Eastern Service Workers Association
(ESWA) in Philadelphia. CS3 stated
that ESWA portrayed itself as an
organization dedicated to helping the
poor and needy and to organizing the
deprived service workers of the east,
i.e., domestics, attendant care workers
and 1 anitorial workers.
B. After CS3 had worked at ESWA
for several months, one of the managers
of ESWA asked if CS3 would like to
become more "involved" in the work of
ESWA than just helping the needy. CS3
replied that CS3 would like to become
more involved. At that point CS3 began
indoctrination into the inner group of
ESWA. CS3 attended lectures on
Warxist Leninism." At the beginning of
these secret meetings, each participant
was required to sign a pledge that he
would divulge nothing of the meetings
to people outside of the members of the
inner group. They were also always
given a ''cover story1'to give to the
authorities if they were stopped on
their way to or from meetings.
Everyone was cautioned never to break
the law and bring police scrutiny upon
any individual of.the inner group or
upon the inner group itself.
C. CS3 described one of the
places at which the inner group met as
an expensively-furnished penthouse
apartment at 145 W. 55th Street in New
York City. At that location, CS3 was
asked to be a member of this inner
group and accepted. CS3 was then put
on one year's probation, during which
time older members continued to monitor
CS3's activities.
D. CS3 stated that after
becoming a member part of CS3's job in
Philadelphia was to solicit donations
for ESWA. CS3 stated that all expenses
of ESWA were paid for out of these
donations. ESWA obtained all their
donations under the guise of helping
the needy, butthe needs of sustaining
the "inner groupt1were taken care of
first. Whatever was left over was
doled out to the people ESWA professed
to be helping.
E. Due to the fact that CS3 was
on probation, CS3 did not participate
in the daily operations of the inner
group. However, CS3 continued
attending certain of its secret
meetings. The business which was
primarily discussed at these meetings
concerned improving donations,
increasing the size but retaining the
--
selectivity of the inner group, and
keeping the knowledge of the existence
of the inner group secure. Detailed
rpinutes were kept at each meeting, and
security hen were placed outside the
building when the meetings were taking
place.
F. The inner group was extremely
secretive about everything having to do
with their activities, meetings, and
members. They were very security
conscious with no telephone
conversations between members or other
branches of ESWA allowed. On.a daily
basis, a courier would take all
documents and literature by pouch to
Trenton, New Jersey, which appeared to
be the headquarters for that area.
G. CS3 had learned of the
military aspects of ESWA indirectly.
Such plans were never discussed openly
in the inner groups. Only the members
not serving a probationary term were
allowed direct knowledge of the
military four-year plan. Through
overheard conversations and passing
remarks, CS3 learned that members
received military training at various
areas throughout the east coast and
possibly California. With regard to
the violent overthrow of the United
States government, mention was made of
the ESWAts infiltration of unions
throughout the eastern seaboard area
and that a majority of the support for
the revolution will come from ESWA
members in these unions. CS3 was very
vague on these aspects because CS3 was
not privy to inslde information, but
CS3 is certain that a military
four-year plan for the violent
overthrow of the government exists
within the inner group of ESWA.
 . --
6. .A confidential source living in California
(hereafter referred to as CS4) has provided the following
information to agents of the FBI:
A. CS4 is familiar with the
activities of the California Homemakers
Association (CHA) (CSl states that this
is one of the original front
organizations for the PPC on the West
Coast). CS4 states that February 18,
1984 is still I'D-DayB1for the
insurrection and calendars in
California regional offices have
circled that date signifying its
importance.
B. CS4 has stated that although
CS4 has seen no weapons at the offices
with which CS4 has had contact, members
of the group admit that they have arms.
C. CS4 further advised that CHA
has installed a new telephone in one of
its regional offices, the number known
to only a very few individuals. CS4
believes this is a special telephone
installed to contact regional
headquarters and make other important
calls. CS4 has learned from other
members that the national office in
Brooklyn, New York is aware of the
number of this telephone.
D. CS4 advised that the pressure
in the CHA is intense as the impending
date draws near. CS4 has stated that
at CHA only essential systems are still
operating, such as those dealing with
volunteers and members. CS4 states
that the cadre are taking power and
ordering people around.
7. In March of 1980, a concerned citizen
(hereinafter referred to as CS8) contacted the FBI in
Sacramento, California with regard to CS8's experiences as
 . --
a member of the Western Service Workers Association (WSWA).
CS8 provided the following information:
A. CS8 had joined WSWA in 1978
because of CS8's dissatisfaction with
the political/social conditions in this
country. Initially, CS8 worked for
WSWA at its Sacramento office
recruiting new members in deprived
neighborhoods and on campuses.
Following this, CS8 travelled to the
Oakland office of WSWA and engaged in
similar work.
B. CS8 stated that WSWA,
together with a sister organization,
the Domestic Workers Association (both
West Coast organizations), are branches
of the National Labor Federation (NLF).
CS8 estimated that there were probably
a total of eight to ten similar front
organizations on the West Coast which
are branches of the NLF. A parallel
organization on the East Coast would be
the Eastern Farm Workers Association,
headed by an individual by the name of
Eugenio Parenti. CS8 also noted that
Parenti is also a national coordinator
for the NLF.
C. CS8 went on to state that all
of these organizations are
sub-organizations of the Provisional
Wing of the Communist Party of the
United States of the Order of Lenin.
During CSB1s year and one half in the
organization, CS8 became aware of a
militant cadre within the NLF which was
an armed unit preparing for the
revolutionary overthrow of the
government. CS8never advanced high
enough within the organization to
become personally involved with the
armed unit, but had been told of the
unit by other members of the NLF. CS8
stated that membership within the armed
unit of the NLF was an irreversible,
life-long membership which could not be
 --.
voluntarily withdrawn. CS8 stated that
this aspect of the membership was
stressed by requiring members to pledge
life-long support of the organization,
which pledge was emphasized by vowing
total abstinence from sex if allowed to
join the unit.
8. During November of 1983, a citizen witness
and five-year resident of the Carroll and Bedford Street
area of Brooklyn (hereinafter referred to as CS5) informed
members of the FBI of the following information:
A. CS5 stated that several
months after moving into the
neighborhood, CS5 was disturbed by
noise of the group at the 1107 to 1115
Carroll Street apartments. CS5 stated
that during the night and into the
early morning hours, members of the
group would walk out of 1107 Carroll
Street and enter 1115. After a while
this stopped. CS5 believes that now
there are passageways between the
basements of 1107, 1111 and 1115
Carroll Street. CS5 states that CS5
learned that none of the basements of
1107, 1111 and 1115 Carroll Street are
available for access by the tenants of
the buildings.
B. Approximately one or two
years ago, CS5 went to Gino Parenti's
office in 1107 Carroll Street. Parenti
had described himself to CS5 as the
"head super" at the apartments. In the
office, CS5 saw a cardboard box filled
with handguns and holsters. (In
February of 1984, CS5 was shown a
photograph of Jeri William Doeden as
the man CS5 knew as "Gino Parenti . I 1 )
C. CS5 had occasion to speak to
a person who lived in one of the
apartments in the buildings that
Parenti's group occupies. This person
-.-
was n o t a member of t h e group.
According t o t h i s person, a youth named
Jose Molina, l i v i n g a t 1115 C a r r o l l
S t r e e t , had pigeon coops on t h e roof of
h e b u i l d i n g . One day while he was up
on t h e r o o f , two members of P a r e n t i I s
group r a n up onto t h e roof with guns
drawn and t h r e a t e n e d Molina saying t h a t
they believed he was r e s p o n s i b l e f o r
some b u r g l a r i e s i n t h e b u i l d i n g s . CS5
f u r t h e r l e a r n e d t h a t t h e husband of
another t e n a n t i n the b u i l d i n g s was
upset by t h i s r e p o r t . The husband
confronted D r . S t u a r t Steinman, who
works i n t h e d o c t o r ' s o f f i c e a t 1115
C a r r o l l S t r e e t and i s a member of
P a r e n t i ' s group. The husband spoke t o
Steinman about Molina being confronted
with a weapon and expressed h i s concern
over t h e same t h i n g happening t o h i s
son s i n c e t h e basements were t o t a l l y
o f f l i m i t s t o t e n a n t s . CS5 learned
t h a t t h e husband s t r e s s e d t o Steinman
t h a t he d i d n o t want h i s son confronted
with a gun i f he happens t o go i n t o t h e
basement while playing. CSS advised
t h a t Steinman r e a c t e d by grabbing t h e '
husband and saying, " I f you o r your
wife o r your k i d go i n t h e basement, we
w i l l knock t h e s h i t o u t of you."
D. Other s t r a n g e behavior about
P a r e n t i and h i s group t h a t CS5 noticed
was t h a t a t n i g h t , about 10 t o 1 5
people a r r i v e a t t h e C a r r o l l S t r e e t
l o c a t i o n and go i n t o t h e basements t o
perform some kind of work. Once every
one t o two months, about 40 t o 50
people come t o C a r r o l l S t r e e t around 1 0
P.M. These people a r r i v e i n numerous
v e h i c l e s . CSS advised t h a t t h e s e
people do n o t leave u n t i l around 2:00
A.M. and t h a t sometimes when they
l e a v e , they c a r r y o u t l a r g e , bulky
items, d u f f e l bags o r t h i n g s covered
with b l a n k e t s .
E. CS5 added t h a t t h e r e i s a
guard standing a t t h e second f l o o r
 window of 1107 Carroll Street 24 hours
a day and that CS5 was told that this
was for the protection of the tenants
in the building. CS5 also noticed some
of the members using small hand-held
radios to talk to each other and also
that there is an intercom system
between the three buildings that
Parenti's group uses.
9. On January 20, 1984, members of the New York
City Police Department (NYCPD) who are members of the Joint
Terrorist Task Force (FBI-NYCPD) spoke to a citizen in the
Carroll Street neighborhood who will be referred to
hereafter as CS6. CS6 related the following information:
A. CS6 stated that CS6 had
recently met with Gino Parenti, the
self-acknowledged leader of the group
located in the buildings 1107-1115
Carroll Street, Brooklyn, New York.
CS6 stated that in Parenti's office,
CS6 saw a rifle with a clip attachment
standing against the wall. CS6 further
stated that during the meeting Parenti
was wearing a shoulder holster with a
gun handle sticking out.
B. CS6 stated that from a report
CS6 had received about the group and
from watching the personality changes
of some of the members of the group
when they are in the presence of Gino
Parenti, CS6 believes that some of the
members of the group living at
1107-1115 Carroll Street are possibly
being held there against their will.
C. CS6 stated that a great deal
of secrecy always surrounds the
activities of the group. The group
keeps a 24 hour sentry posted in the
window of 1107 Carroll Street. CS6
stated that when CS6 had asked why the
sentry was there, members of the group
 --
were unable or unwilling to give an
explanation.
D. CS6 viewed a photograph of
~ e r iWilliam Doeden (see 7s 13, 14 and
15, infra) and identified Doeden as the
man CS6 knew as "Gino Parenti.I1
10. A concerned citizen (hereinafter referred to
as CS7) in November of 1983 reported the following
information to the FBI:
A. CS7 had recently received a
telephone call from a female
acquaintance. This acquaintance
indicated that she was in fear for her
life and had been held against her will
by the organization to which she
belonged. The acquaintance indicated
that the organization was the National
Labor Federation, 1103 (sic) Carroll
Street, Brooklyn, New York and 145 East
(sic) 55th Street, New York, New York.
The acquaintance stated to CS7 that she
had tried to escape about six months
ago but was prevented from doing so.
She said she was beaten and struck with
a gun. The acquaintance indicated that
she and another individual were only
able to escape at the present time due
to the assistance of a lawyer and his
wife in New York City.
B. The acquaintance stated that
the group was headed by Gin0 Parenti.
According to the acquaintance the group
owned "4 apartmentst1at 1103 (sic)
Carroll Street, Brooklyn, New York.
The group also owned a penthouse
apartment at 145 East (sic) 55th Street
in which high ranking officials spent
some of their time.
C. The acquaintance stated to
CS7 that one of the organizations
related to the National Labor
Federation was the California
 -.-
Homemakers Association. She indicated
that it may have offices in Sacramento,
San Diego, and Redding, California.
11. A concerned citizen from Long Island
(hereinafter referred to as CS9) provided the following
information about the experience CS9 had at a meeting of
the National Labor College (NLC) in Brooklyn. (CS1
indicates that the NLC is a front organization for teaching
members of the National Labor Federation (NLF)):
A. The NLC held the meeting
which CS9 attended at a church in
Brooklyn in October of 1981. Upon
arriving at the church, CS9's group was
met by uniformed guards wearing
fatigues, boots and berets which had
red stars embossed upon them. These
guards numbered 10 to 15 and were
responsible for the security of-the
meeting, the security of the primary
speakers and the orderly running of the
meeting (no one who attended this
meeting was allowed to leave the
building unescorted or even to go to
the restroom without a guard being with
them). After opening remarks, the
meeting broke down into smaller groups
and teachers would rotate from group to
group lecturing on a number of leftist
topics.
B. Finally, the small groups
were disbanded and everyone listened to
the main speaker who was
enthusiastically received. His name
was Chino Parente (ph). Parente
expounded upon the topics of U.S.
imperialism, the Cold War, the
teachings of Lenin and the need to have
the American revolution to rectify the
corruption of capitalism. He also
spoke of communism in the U.S. and how
communism in this country could not be
 --
modeled after Chinese, Cuban or Russian
communism, but structured to fit this
country (a type of American
Euro-Communism).
C. Parente, when,describing how
NLF was masking its real purpose of
organizing and beginning the American
revolution as well as how the NLF was
strengthening itself and training its
leaders, made the statement "We will
allow leftist opposition representation
in NLF as a means to hide our true
reasons for beingw, and, "Our cells are
under welfare covers so we may
strengthen ourselves and train our
leaders without interferen~e.'~CS9
stated that there was nothing more
specific said about what form the
American revolution would take, armed
or peaceful. However, when CS9 asked
one of the people that brought her to
this meeting since they appeared to be
advocating armed violence, were they
not afraid of the government's
reactions, the woman replied, "We're
protected by the aftermath of the
reaction to McCarthyism9'.
12. The mother of a member of the PPC provided
the FBI with the following information in 1975 and 1976
(CS1 has identified the daughter described herein as a PPC
cadre member presently holding a high rank in the
organization.):
A. The mother stated that in
1975 her daughter joined the Eastern
Service Workers Association (ESWA) and
after indoctrination was assigned to
live in communal structures throughout
the New Jersey area. The daughter told
her mother that ESWA was a communist
front which was attempting to organize
domestic service workers and other
militant laborers into a union-like
 -.--
organization. The daughter f u r t h e r
t o l d h e r mother t h a t ESWA had a f i v e
year p l a n f o r t h e v i o l e n t overthrow of
t h e United S t a t e s Government.
B. The daughter a l s o t o l d her
mother t h a t ESWA had a "Red Guard" o r
"Red Amy" element l o c a t e d i n various
c i t i e s which held weekly p a r a m i l i t a r y
drills. The daughter described t h i s
army element a s being p a r t of t h e p l a n
t o overthrow t h e government. The
daughter s t a t e d t h a t ESWA had a network
of " s a f e houseslf.
C. The daughter t o l d h e r mother
i n 1976 t h a t t h e f i v e year p l a n s t i l l
e x i s t e d , b u t t h a t she was no longer
involved i n t h a t a s p e c t of t h e
o r g a n i z a t i o n . She admitted t o her
mother t h a t being a communist means you
have t o break t h e law.
13. Your deponent has read t h e r e p o r t s of an
undercover San Francisco p o l i c e o f f i c e r who met with J e r i
W i l l i a m Doeden, a/k/a Gino Savo during 1970. On February
2 5 , 1970, t h e undercover o f f i c e r met with a man who

i d e n t i f i e d himself a s Gino Savo i n t h e L i t t l e Red

Bookstore, 3191 Mission S t r e e t , San Francisco. (The
o f f i c e r l a t e r examined a photograph of Doeden and
i d e n t i f i e d "Gina SavoaVa s Doeden.) Doeden t r i e d t o r e c r u i t
t h e undercover o f f i c e r i n t o h i s revolutionary group.
Doeden t o l d t h e o f f i c e r t h a t h i s group would be engaged i n
warfare with t h e U . S . Government w i t h i n 30 t o 60 days.
Doeden t o l d t h e o f f i c e r t h a t h i s group would use g u e r r i l l a
warfare t a c t i c s s t r i k i n g a t p o l i c e s t a t i o n s and power
 29.
?
..

plants. The officer saw one gun and parts of another

present in the bookstore where he met Doeden. Doeden told
the officer that his organization is made up of 10-man
squads who are highly trained and proficient in the use of
automatic weapons and terrorist tactics. Doeden accepted
the officer into the group and gave him a red star which
all the members of Doeden's group wore to signify their
membership.
14. During the period 1969 through 1972, a
confidential source (hereinafter referred to as CS10)
provided FBI agents in California with information
concerning a man named Jeri William Doeden. FBI files
reveal that ~ e r iWilliam Doeden has used the aliases of
Eugenio Parenti and Victor Ramos among others. Significant
portions of the information which CSlO provided were
corroborated from other sources. CSlO provided the
following information:
A. In January of 1970, CSlO met
with Jeri William Doeden in "Stage One,
Your Little Red Bookstore", 3191
Mission Street, San Francisco,
California. In the backrooms of the
bookstore, CSlO noted three rifles with
loaded clips nearby and three handguns.
All the weapons were in working order.
Doeden told the source that he planned
to recruit his own guerrilla band for
the revolutionary takeover of Northern
California. Doeden spoke about
training a group of 18 men for the
burning of a United States camp in
Redding California. Doeden stated that
shortly he planned to publish a
document which described Liberation
Army Revolutionary Organization (LARGO)
as a revolutionary guerrilla force that
will take over Northern California.
(Doeden did mail the LARGO documents
declaring a state of revolution in
Northern California to officials in
Northern California in mid-March, 1970.
No revolution took place.)
B. On November 8, 1970, CSlO met
with Doeden and six followers in Chico,
California. At the meeting Doeden and
his followers travelled to an open
field in the area and took target
practice with the weapons which the
group (LARGO) had. These weapons were
four .30 caliber carbines, one 30.06
rifle, three British 303 rifles, one
9mm Browning pistol, one .45 caliber
pistol and a 12 guage pump shotgun.
C. On December 10, 1970. CSlO
met with Doeden and four of his
followers to discuss Doeden's plans for
future revolutionary activity. Doeden
stated that he had small organized
groups in each of a number of
California Towns, including 30 armed
activists who were ready to go. The
first steps in Doeden's p.lans were to
kidnap the Alameda County Sheriff and
an unnamed Berkeley official. At the
same time, a large explosive charge
would be placed in the new San
Francisco Bank of America Building.
After warning officials of this, Doeden
then planned to attack the San
Francisco Hall of Justice with mortar
fire (Doeden had shown CSlO a mortar on
a previous occasion) and burn or bomb
the University of California
Radiological Laboratory and Atomic
Reactor. Doeden further planned to
dynamite every dam between Belden and
Oroville, California and stated that he
had individuals hiding out in a remote
area near the dams. Doeden also
 . --
planned to capture a radio station and
use it to announce the beginning of the
revolution. Doedents explained that
the point of all this activity was to
induce great fear Itamongthe
establishment.11 Everyone present at
the meeting seemed very excited by the
Itwarplans. (Although terrorist
incidents took place in California
after this meeting, none have been tied
to Doeden.)
15. On April 3, 1970, the Sutter County
California Sheriff's office reported to the FBI that on
that date deputies had arrested Jeri William Doeden on a
"failure to providet1warrant. At the time of arrest,
Doeden was in possession of a .38 caliber Smith & Wesson
revolver and a loaded M-1 rifle.
16. Your deponent has examined the New York
State incorporation papers for a corporation named "Foxfire
Enterprises, Inc." The purposes of the corporation are
"dealing with the ownership and management of buildings
acquired by the corporation through the common consent of
its shareholders." The office of the corporation is stated
to be located in Brooklyn. Process can be served on it at
"195 Adams Street, #7E/Brooklyn, New York 11201." Among
those signing the certificate are #'KitConelly Decious, 133
Berkely Place/Brooklyn, N.Y. 11217." "Stuart L. Steinman"
and "Kathleen M. Paolo, 195 Adams Street, #7E/Brooklyn,
N.Y. 11201." Employees of the FBI have examined the
records of the Kings County Clerk's Office, Recorder of
 *-

Deeds. Documents in that office indicate that Foxfire

Enterprises, Inc. owns the property at 1107, 1111 and 1115
Carroll street, Brooklyn, New York. The deed to the
property was applied for by Kit Cbnelly Decious, secretary
of Foxfire Enterprises, Inc., on March 3, 1982.
17. Agents of the Joint Terrorist Task Force
have examined records of Galaxy Guns, Gazza Boulevard,
Farmingdale, L.I. These records indicate that Kathryn
(Kit) Conelly Decious, 133 Berkeley Place, Brooklyn, New
York purchased two Belgian made military assault rifles
(FNFAL semi-automatic; 308 caliber) from Galaxy Guns in
1981. Rifle (ser. no. 2502651) was purchased on June 2 6 ,
1981 plus 500 rounds of ammunition for $1,400.00. Rifle
(ser. no. 2502646) was purchased on July 2, 1981 for
$1,200.00. These rifles can hold clips of 30 or 60 rounds
of ammunition.
18. In 1973, the Suffolk County Police
Department received information that weapons were present
at a residence associated with the Eastern Service Workers
Association (EWSA). On March 6 , 1973, pursuant to a search
warrant, the police searched the residence in Bellport,
L.I. and found two fully-loaded handguns. Suffolk police
records indicate that Mary K. Gardner also known as "Polly
Gardner" was charged with weapons possession stemming from
that search. The search warrant named ''Eugenia Parenti"
 --
("Fiield D i r e c t o r Mo f t h e ESWA), "Polly Gardne:" and another
a s occupying the premises where t h e guns were found. In
May of 1973, Det. Brown of t h e Suffolk County P o l i c e
Department informed FBI agents t h a t t h e informant i n t h e
case had examined a photograph of J e r i W i l l i a m Doeden and
i d e n t i f i e d him a s t h e man known a s I1Eugenio P a r e n t i . " Det.

Brown a l s o t o l d the agents t h a t one of t h e weapons s e i z e d

was " r e g i s t e r e d " t o Wesley I i j i m a . I n January of 1975, ATF
Agent Mark Goldstron informed t h e FBI t h a t one of t h e
weapons ( t h e .38 c a l i b e r Smith & Wesson r e v o l v e r ) s e i z e d by
t h e Suffolk County P o l i c e was o r i g i n a l l y owned by Wesley
Iijima. Goldstron a l s o informed t h e FBI t h a t t h e S u f f o l k
County P o l i c e informant had learned t h a t P o l l y Gardner had
been holding t h e two handguns f o r Doeden. On March 12,
1974, FBI agents interviewed Sylvia Marlene I i j i m a t h e wife
of Wesley I i j i m a . Sylvia I i j i m a s t a t e d t h a t she had n o t
seen Doeden f o r two y e a r s (although she had i n d i c a t e d i n a
previous interview with t h e FBI t h a t she and h e r husband
had a t one time been c l o s e l y a s s o c i a t e d w i t h Doeden and h i s
revolutionary a c t i v i t i e s -- %ARGO"). She s t a t e d t h a t two
years ago while Doeden was s t a y i n g a t h e r and h e r husband's
home i n C a l i f o r n i a , t h e i r Smith & Wesson r e v o l v e r , which
h e r husband had purchased f o r her i n San Francisco, had
turned up missing. She s t a t e d t h a t she was c e r t a i n t h a t
Doeden s t o l e t h e r e v o l v e r . She s t a t e d t h a t she and h e r
 . -.-
husband d i d n o t r e p o r t t h e t h e f t because she d i d n o t want
t o g e t Doeden i n t r o u b l e .
19. Your deponent has spoken t o the a t t o r n e y f o r
Prominence Realty Corp. t h e owner of t h e apartment b u i l d i n g
a t 145 West 55th S t r e e t , New York, New York. The a t t o r n e y
s t a t e s t h a t D r . Alan M. Berkowitz holds t h e l e a s e on
apartment 15A, a duplex, penthouse apartment a t 145 W. 55th
Street. The a t t o r n e y s t a t e s t h a t D r . Berkowitz has n o t
paid r e n t f o r t h e apartment i n over two years and t h a t t h e
Prominence Realty Corp. has been conducting v a r i o u s p i e c e s
of l i t i g a t i o n a g a i n s t D r . Berkowitz t o e v i c t him from t h e
premises. The a t t o r n e y s t a t e s t h a t D r . Berkowitz has n o t
been seen around t h e apartment f o r an extremely long time
and t h a t t h e apartment i s being used by D r . Berkowitz's
invitees.
20. The a t t o r n e y provided your deponent with a
copy of some of t h e papers f i l e d on behalf of D r . Berkowitz
i n the s u i t s . The firm of Daniel P . Foster, P.C.
r e p r e s e n t s D r . Berkowitz i n a New York s t a t e a c t i o n . K i t

Conelly Decious i n an a f f i d a v i t f i l e d i n t h a t s u i t s t a t e s
t h a t D r . Berkowitz i s h e r c l i e n t and t h a t she holds power
of a t t o r n e y f o r him. Decious f u r t h e r s t a t e s i n t h e
a f f i d a v i t t h a t she and her p a r e n t s stayed a t t h e penthouse
apartment i n November of 1983 a t t h e i n v i t a t i o n of D r .
Berkowitz. The a f f i d a v i t of K i t Conelly Decious f u r t h e r
 . ..-
i n d i c a t e s t h a t "Dr. Berkowitz has assigned p o r t i o n s of h i s
i n t e r e s t t o h i s medical colleagues." I t makes no mention

of any law firm being run from t h e premises. Other l e g a l

papers i n d i c a t e t h a t D r . Berkowitz i s suing t h e Prominence
Realty Corp. f o r harrassment t o h i s medical colleagues i n
t h e i r practices. These papers make no mention of any law
firm being run from t h e premises.
21. Your deponent has spoken t o two employees a t
145 W. 55th S t r e e t . On being shown a photograph of Jeri
W i l l i a m Doeden, they both i d e n t i f i e d him a s being one of

t h e people who had frequented apartment 15A over t h e p a s t

few years. One of t h e employees made a s i m i l a r
i d e n t i f i c a t i o n of a photograph of Tony Orendain. The o t h e r
i d e n t i f i e d Reymundo Pena from a photograph a s having
frequented t h e apartment. They both i n d i c a t e d t h a t l a r g e
numbers of people came and went from t h e apartment i n
groups a t odd hours. They believed t h a t people "crashedtt
there. They both noted t h a t t h e people who frequented
apartment 15A were d i f f e r e n t i n demeanor and d r e s s from t h e
o t h e r t e n a n t s of t h e b u i l d i n g . These employees give no
i n d i c a t i o n t h a t any law o f f i c e i s p r a c t i c i n g o u t of t h e
apartment. FBI agents have seen t h e o u t s i d e of apartment
15A located a t 145 W. 55th S t r e e t . There i s no i n d i c a t i o n
on t h e door of t h e apartment o r on t h e b u i l d i n g d i r e c t o r y
 *-
that a law office is inside apartment 15A. The building
directory only lists Dr. ~erkowitzas residing in Apt. 15A.
22. Agents of the FBI have been conducting
discreet visual surveillance on the 1107-1115 Carroll
Street apartments on an almost continuous basis since
January 24, 1984. During that time, the agents have seen a
guard or sentry posted at all times in the window of
apartment 2A, 1107 Carroll Street, Brooklyn, New York.
Regularly every morning at approximately 3:00 a.m.,
numerous males and females have been seen leaving 1107
Carroll Street and getting in cars. The cars travelled by
different routes to 354 Gold Street, Brooklyn, New York
where they discharged their passengers. The passengers
then enter the entrance for the ground floor studio at 354
Gold Street. Upon occasion one of the cars travelled,
after discharging its passengers, to the vicinity of 195
Adams Street where it was parked. On another occasion,
another of the cars after discharging some passengers at
354 Gold Street also travelled to 145 West 55th Street, New
York City and discharged passengers there.
23. The Joint Terrorist Task Force has given
careful consideration to how and when best to execute this
warrant. A number of factors have a bearing on the
decision. One of the factors is the presence of Medgar
Evers College across the street from the Carroll Street
 .-
locations. I f any shooting occurs from persons i n s i d e t h e
C a r r o l l S t r e e t l o c a t i o n s , Medgar Evers College would b e i n
t h e l i n e of f i r e . Considering t h i s , t h e s a f e s t t i m e f o r
execution of t h e warrant would be d u r i n g a time when t h e
college is not i n session. Another f a c t o r i s the apparent
p r o p e n s i t y toward v i o l e n c e of members of the PPC e s p e c i a l l y
i n regard t o protecting t h e i r headquarters. (See BlP,

supra.) I n r e g a r d t o t h i s , t h e b e s t time f o r e x e c u t i o n of
t h e warrant would be when most members a t t h e apartments
a r e asleep. The members keep unusual hours a p p a r e n t l y
going t o bed around 3 A.M. or shortly thereafter. S;--=

t h e s e a r c h of t h e C a r r o l l S t r e e t l o c a t i o n s must be
contemporaneous w i t h searches a t t h e o t h e r l o c a t i o n s , we
f e e l we need a u t h o r i z a t i o n f o r warrants which can be

executed a t any time of day.

24. On February 1 6 , 1984, agents of t h e FBI
served f o r t h w i t h grand jury subpoenas on Kathryn ( K i t )
Conelly Decious and Daniel F o s t e r t o produce documents
The documents a r e described i n addendum nos. 1 and 2

( c o p i e s of t h e subpoenas served on Decious and F o s t e r ,

which copies a r e a t t a c h e d h e r e t o and i n c o r p o r a t e d herewith
by r e f e r e n c e ) .
25. On February 16, 1984, Kathryn ( K i t ) Conelly
Decious and Daniel F o s t e r appeared b e f o r e t h e Honorable

Eugene Nickerson, United S t a t e s D i s t r i c t Judge, E a s t e r n

~istrict--*of
New York, to contest the validity of the
subpoenas. They indicated that they had no knowledge or
awareness of the records requested in paragraphs nos. 1 and
2 in the attachments to the subpoenas. They stated
specifically in response to Judge Nickerson's questions
that they did not have any records which corresponded to
those requested in paragraphs 1 and 2 of the attachments to
the subpoenas. Among other things, Daniel Foster stated to
Judge Nickerson that his principle place of business for
Daniel Foster and Associates was 145 West 55th Street in
New York City.
26. Members of the Joint Terrorist Task Force
have had the Carroll Street locations under constant
surveillance since the subpoenas were served. No one has
exited the premises with a container any larger than a
briefcase during that time.
27. Your deponent has spoken to employees of the
Treasury Department who have searched the National Firearms
Registration and Transfer Record. There is no record of
any firearms registered to any person r # = d in this
affidavit in connection with the PPC. Moreover, there is
rrcmkr
no record of any ----'-- of the PPC known to the FBI having
a
registered any firearms in the National Firearms
Registration and Transfer Record.
 -.-

-REFORE your deponent respectfully prays that

warrants be issued allowing your deponent or any Special
Agents of the Federal Bureau of Investigation, with proper
assistance, at any time of day, to enter the premises known
as described as:
1. THE NATIONAL OFFICE OF THE
PROVISIONAL PARTY OF COMMUNISTS,
APARTMENT 2A, 1107 CARROLL STREET,
BROOKLYN, NEW YORK
2. THE LAW OFFICES OF DANIEL
FOSTER AND ASSOCIATES AND THE
OFFICE OF GIN0 PARENTI, BOTH
OFFICES OCCUPYING THE PREMISES
OF AND KNOWN AS APARTMENT 1A,
1107 CARROLL STREET, BROOKLYN,
NEW YORK
3. THE DOCTOR'S OFFICE, APARTMENT
lA, 1115 CARROLL STREET, BROOKLYN,
NEW YORK
4. THE BASEMENTS OF THREE ADJOINING
FOUR-STORY APARrnNT BUILDINGS
KNOWN AS 1107, 1111 and 1115
CARROLL STREET, BROOKLYN, NEW
YORK
5. THE GROUND FLOOR PREMISES
(AND ANY AREAS APPURTENANT THERETO)
ALSO KNOWN AS THE DESIGN STUDIO
OF JADE BEHAR-TREVES, 354 COLD
STREET, BROOKLYN, NEW YORK
within the Eastern District of New York and
6. THE PENTHOUSE APARTMENT OF DR.
ALAN M. BERKOWITZ KNOWN AS APART-
MENT 15A, 145 WEST 55TH STREET,
NEW YORK, NEW YORK
within the Southern District of New York and therein to
search for and to seize certain property, namely: weapons
 . -.-
(rifles, handguns and machineguns) and other military
equipment including uniforms; explosives and bomb making
equipment; all records of the Provisional Party of
Communists (PPC) relating to the purchase, storage,
location and disposal of weapons, ammunition and
explosives; all books, documents and records outlining the
PPC's plans for an armed insurrection against the lawful
authority of the United States Government; all records
relating to planned terrorist activities; all records of
the "Military Fraction" of the PPC including, but not
limited to, records detailing planned military activities
directed against the lawful authority of the United States
Government, records detailing planned terrorist activities,
records concerning the location of "Military Fraction"
headquarters, records relating to the location of weapons,
ammunition and explosives, records relating to the
purchase, storage and disposal of weapons, ammunition and
explosives, records relating to the identity of those
individuals making up the "Military Fraction1#of the PPC
and records relating to the system of communications among
and between the different locations of the "Military
Fraction" of the PPC; and the books and records of Foxfire
Enterprises, Inc.
 / e.P f. H
-7 +-
NEIL E. HERlrlAN
Special Agent
Federal Bureau of Investigation
Joint Terrorist Task Force

RICT JUM: