Bob Rabon, being first sworn upon his oath, states:

(1) That I am General Counsel for the Choctaw Nation. I and/or my firm have represented the Choctaw Nation for over 30 years. I have been a member of the firm for more than 27 years. Our relationship with the Choctaw tribal government spans three administrations. It is true that we have a vested financial interest with this client as we have with all of our many other clients. Someone like Mr. Dry who probably has never had a regular client and usually forms any attorney/client relationship immediately after the ambulance arrives would not understand that to maintain a large, regular clientele you have to work hard and do a good job for them. You also have to support them in their work. We try to do that with all our clients including the Choctaw Nation. We have had a very satisfactory relationship with Chief Roberts for more than seventeen years, even predating his election as Chief when he was the executive director of the tribe under Chief Gardener. We have always been supportive of him in his leadership role and his efforts toward being elected and reelected. Certainly, we would have continued this support in the past election when Mr. Dry announced his intention in the Daily Oklahoman that his "first act" if elected Chief would be to "fire Bob Rabon". Fortunately for the Choctaw people Mr. Dry's pathetic campaign fell miserably short of its goal by receiving only 17% of the vote.

(2) The Roberts and Rabon families own the Choctaw County Times, a small weekly newspaper in Hugo. My wife, Linda Rabon, is the managing editor. I dare say that Mr. Dry has been mentioned in that paper no more than three or four times. Those were either related to his being a candidate for Chief, the results of the election, his involvement in Chief Roberts recent indictment (not sure about this) and his arrest at Tuskahoma for disorderly conduct, fighting with the police and threatening to kill the Chief of tribal law enforcement. The Times has ignored many of Mr. Dry's staged attention seeking events publicized by more gullible media members. I am not certain as to which of his clients he refers regarding the newspaper but it is probably the woman who sued Chief Roberts for sexual harassment last year. Much local and statewide media interest was created by Mr. Dry's sending a copy of the complaint to several newspapers before Chief Roberts was even served with it. This caused his client to become, at a minimum, a figure of local public interest. When she was subsequently named as "the other woman" in a divorce action, it was a matter about which the public had an interest. The Choctaw County Times printed this fact taken from Court records. Mr. Dry is certainly not so naive as to not know that seeking media attention can be a two-edged sword. I invite, and the Court should require, Mr. Dry to demonstrate anything published in that newspaper about him or any client that was untrue or not a matter of public record, and exactly how he or any client has been harassed or intimidated.

(3) Mr. Dry and his attorney have made several reckless and extremely serious charges of illegal and/or unethical conduct against my law firm and myself personally in their motion to disqualify the prosecutor in this case. I have first hand knowledge that the information was sent directly to several newspapers including the Daily Oklahoman. In their reckless abandon to lash out at and conduct their hate-filled vendetta against the current Choctaw Chief, they have completely lost, if they ever had any, all sense of propriety. Anyone connected with the tribal government is fair game by them for their vicious, lying attacks.

I have practiced law for more than twenty-seven years without ever having had my integrity and character attacked in the manner set out in Mr. Dry's affidavit. These charges lodged against me by Dry and his attorney are:

(a) Claims that I have advised tribal officials to encourage other tribal employees and officials to refuse to cooperate with or to lie to federal investigators.

(b) Claims that I encouraged or instructed a Choctaw Housing Authority official to attempt to tamper with a federal grand jury witness.

(c) That I "assisted in the cover-up of sexual assaults on tribal female employees."

(d) That I have knowledge of fraud perpetrated on the Choctaw Housing Authority and have covered it up.

(e) Claims that I am engaged in a "conspiracy" to "intimidate, harass and illegally prosecute" Dry.

(f) That I have unethically given false legal opinions which "prevent democracy in the Choctaw Nation".

(4) I categorically deny these false and scurrilous accusations made by this pair of emotionally troubled, hate-obsessed, bottom-feeders. I invite them to take their libelous claims up with the proper authorities, including but not limited to, the U.S. Attorney and General Counsel for the Oklahoma Bar Association. If they do not, they should be sanctioned by the Court to stop their personal attacks, conducted with impunity, against anyone associated with Chief Roberts. In this connection, they should be required to produce credible evidence that they have made a good faith effort to have the foregoing charges investigated by the appropriate authorities to secure my indictment and/or have me disciplined by the Bar Association.