EXHIBIT A

DECLARATION OF COUNSEL

I, Kathy Quant, declare under the penalty of perjury, as follows:

I am an attorney, duly licensed to practice law in the State of California and presently employed as a Deputy Public Defender for the Office of the Los Angeles County Public Defender and am counsel of record for the within class petitioner for writ of habeas corpus.

That over the past nine months I have attempted, unsuccessfully, to locate the whereabouts of $1,237,740 which was surreptitiously taken from a from a car on September 24, 1996, as a result of information learned by monitoring an unauthorized telephone. (Attachment 1.)

That I contacted the Major Narcotics Division of the LAPD and inquired of the process used for money seized as a result of their wiretap operations. I was informed that it was given to the Forfeiture Division of the District Attorney's Office.

That I contacted the Forfeiture Division of the District Attorney's Office and was informed that no such seizure was referred to their Division and the records of the Federal Court should be checked.

That a review of those records failed to disclose a forfeiture action taken against currency in the amount of $1,237,740. I was informed by a federal court clerk that, at times, such actions are filed by the U.S. Customs Office.

That I contacted the U.S. Customs Office and was informed that no action against $1,237,740 could be located

That one possible reason that legal action against such seizure cannot be located is because I have discovered that at times there has been a discrepancy between the amount seized and the amount deposited. (Attachment 2.)

Dated this 20th day of October, 1999, in the City of Los Angeles, California.

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Kathy Quant
Deputy Public Defender