DECLARATION OF KENJI ONUKI

SUPPLEMENTAL EXHIBIT 3

Kenji Onuki declares under penalty of perjury as follows:

1. I, Kenji Onuki, currently reside at Belvedere Estate, 723 Broadway, Tarrytown, New York. I acted as a chauffer for Reverend Sun Myung Moon between 1973 and 1980. 2. On several occasions during the period 1973-1975,

I was asked by Church members to assist them in cashing checks.
I presented these checks to the person who was responsible
for performing accounting functions related to the Japanese
Family Fund. Then the checks were cashed using money in the
Japanese Family Fund.

3. On various occasions during the same period, I was also asked to deposit monies from the Japanese Family Fund, which included the checks described above, into the Chase Manhattan Bank accounts.

I declare under penalty of perjury under the laws

of the United States of America that the foregoing is

true and correct to the best of my knowledge. Executed on December 10, 1984.

Kenji Onuki

SUPPLEMENTAL EXHIBIT 4

DECLARATION OF YUKIKO MATSUMURA

Yukiko Matsumura declares under penalty of perjury as

follows:

1. I, Yukiko Matsumura, currently reside at 481 8th Ave., NY, NY.

2. I assumed the responsibility for performing accounting functions for the Japanese Family Fund from Tomoko Torii in 1976.

3. I made several corrections to the Japanese Family Fund Ledger by pasting new entries over the original entries in August 1977. However, these corrections were made at the suggestion of Mr. Robert H. Elliott, Jr., a tax attorney with the Washington DC law firm of Caplin & Drysdale. The corrections were not designed to mislead the IRS investigation.

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

What follows is a memorandum analyzing the Court Interpreters Act as applied to the proceedings against Takeru Kamiyama. In reviewing this memorandum, it is important to note the following limitations:

1. The authors have not reviewed any transcript

of the original grand jury proceedings, trial or appeal;
2. The authors have not reviewed any of the

motions made pre-trial, post-trial or on appeal; and
3. The authors have relied solely on the
information supplied to them by Messrs. Mitsuharu Ishii and

Yuji Yokoyama.

Time constraints have further limited the authors' ability to research exhaustively the entire legislative intent of the Court Intérpreters Act.

II

FACTUAL BACKGROUND

Takeru Kamiyama, a Japanese national, is a member

of the Unification Church. He is an advisor to Reverend Sun Myung Moon, the founder and spiritual leader of the Church. In 1982, Kamiyama was convicted of perjury,

obstruction of justice, and aiding and abetting the filing of false tax returns following a jury trial before Judge Gerard L. Goettel in the United States District Court for the Southern District of New York. He was sentenced to concurrent terms of six months of prison. The Court of Appeals upheld the convictions on all counts, except one, which was dismissed. United States v. Sun Myung Moòn, 718 F.2d 1210 (2d Cir. 1983).

On May 14, 1984, the Supreme Court denied Kamiyama's petition for certiorari. United States v. Sun Myung Moon, 80 L. Ed. 2d 818, 104 S. Ct. 2344 (1984).

Kamiyama is presently serving his sentence in the

federal penitentiary in Danbury, Connecticut.

III

JUDICIAL HISTORY LEADING

TO THE ENACTMENT OF

THE COURT INTERPRETERS ACT

The evolution of the case law leading to the

enactment of the Court Interpreters Act in 1978 has been toward a recognition of the need for foreign-languagespeaking defendants to have competent interpreters in trial proceedings. This recognition has resulted in federal and state court holdings that failure to provide the defendant with a competent,interpreter constitutes a denial of his constitutionally-guaranteed right to a fair trial and due process of law.

Moreover, Congress has now made clear, by

enacting the Court Interpreters Act of 1978 (the "Act"), 28

U.S.C. 1827, that a non-English-speaking defendant has a recognizable right in having a court-appointed interpreter and has directed that the courts implement certification

procedures for such interpreters.

Early in this century, the Supreme Court held

that the decision to appoint an interpreter to help elicit the testimony of an English-handicapped defendant rested entirely in the discretion of the trial judge. Perovich v. United States, 205 U.S. 86 (1907). Although no

constitutional arguments were advanced in support of the appointment of an interpreter in that case, after Perovich, courts dealing with the appropriateness of appointing an interpreter consistently held that an interpreter must be provided to ensure the integrity of the constitutional rights guaranteed by the Fifth, Sixth and Fourteenth

Amendments.

Of particular concern to the courts, as evidenced by the case law on this subject, are a non-English-speaking defendant's rights: (1) to be informed of the nature and cause of the accusation, (2) to be confronted with the witnesses against him, and (3) to have assistance of counsel for his defense. Hence, in Terry v. State, 21 Ala. App. 100, 105 So. 386 (1925), one of the first decisions to reverse a conviction for failure to appoint an interpreter, the court held that the right of confrontation must include the defendant's right to understand the accusations and evidence presented against him and must include the means to defend against those charges. The constitutional underpinnings of Terry have been repeatedly followed and expanded upon by both federal and state courts. See, e.g., State v. Vasquez, 101 Utah 444, 121 P.2d 903 (1942): Garcia v. State, 151 Tex. Crim. 593, 210 S.W.2d 574 (1948); State v. Natividad, 111 Ariz. 191, 526 P.2d 730 (1974); United States v. Carrion, 488 F.2d 12 (1st Cir. 1973).