Commonwealth of Pennsylvania 
County of Cumberland

AFFIDAVIT

Before the undersigned, an officer duly commissioned by the Laws of the
Commonwealth of Pennsylvania, on this the 2nd day of December 1997 
personally appeared Dwayne Haus, of Carlisle, Pennsylvania who having been
first duly sworn depose and say:

1. 1 am over the age of 18, a resident of the Commonwealth of Pennsylvania
and I am competent to testify before a Court of Law.

2. That I am familiar with standard accounting procedures pertaining to
business as a business owner for a period in excess of 15 years. I have
gained further training with respect to the keeping and maintaining of
financial documents as an insurance agent licensed in the Commonwealth of
Pennsylvania for the period including 1985 through the present. During that
period, I have performed and designed numerous financial plans for my
clients.

3. 1 have gained bookkeeping experience through working in the above
identified businesses for a period of over 20 years as both a business
manager and as a business owner. During this period of time I have
performed the accounting tasks for these businesses including but not 
limited to daily, weekly, monthly, quarterly and annual ledgers; filings
and reporting as has been required by the law; and payroll and daily 
accounting duties. (Vite for Dwayne Haus attached as Exhibit Al)

4. On or about May 1996 and again in November 1997 as part of on going
litigation in the matter of David Busch et al v. National Organization for
the Reform of Marijuana Laws (NORML). Case No. 01358-95 and the consolidated
matter of 7905-95 before the Civil Division of the Superior Court of the
District of Columbia. I was engaged by Dr. Busch to perform a financial
audit and reconciliation of NORML's financial profile during the period
inclusive 1992 - 1995.

5.In performing the financial audit of NORML, I reviewed as part of that
Audit the following documents:

a. Documents that were made available to the Law Firm of Grossman & Sandoval
,PLC within the scope of discovery within these cases. Grossman & Sandoval,
PLC copied several thousand documents made available to them at the Offices
of National NORML as they were maintained at that office. The documents 
reviewed by myself consisted of photocopies of donation checks, bank 
statements, deposit slips, out going checks drafted from NORML accounts from
several banks, quarterly and monthly financial reports, IRS FORM 990's for
the above identified period, and other materials relevant to a financial
accounting of this organization.

b. I further reviewed financial material accompanied and maintained by The
Emergency Coalition for Medical Cannabis, (ECMC) which included checks in
the form of donations, bank statements, and returned checks written on bank
accounts of ECMC made out to NORML and to Cash.
(See: Exhibit A2)

c. Copies of all check receipts written from the following accounts of NORML
which were copied during document review and inspection covering the period
of 1992 to 1994. The below references are listed by Account Name, Bank Name,
Bank Location and Account Number.

1. "NORML Special Account": Nations BANK ACCOUNT D.C., Nation's Bank Account
Tennessee, Account # 0112731062.

2. "NORML: First American Bank, NA Washington, D.C. Account 3404838.

3. NORML: First Union National Bank Account of Washington, D.C., Washington
D.C. Account # 3404848

4. NORML: Nations Bank, Washington, D.C. Account # 0030011-629

5.  First Union Card Products: MasterCard and Visa Merchant Statement," 
Merchant  Relations, Charlotte, N.C. (Merchant 552001992)

6. "ECMC": Nations Bank of the District of Columbia, Dupont Circle, 
Washington, D.C. Account # 0003307387.

d. As part of the document review, which I performed in June 1996, 1 
prepared ledger sheets and a written report, which explained these 
bookkeeping actions. (SeeExhibit A3) The ledger sheets provided as exhibit
A3 illustrate that the records for 1992, 1993 and 1994 were incomplete. The
ledger sheets further illustrate that the accounting performed by NORML was
not performed on a daily, weekly, monthly, quarterly or yearly basis, or
alternatively that such information was not provided to or copied by 
Grossman & Sandoval, PLC.

6. Certain documentation was missing or incomplete which prevents me from
being able to reach ultimate conclusions as to the exact amount of funds
which were received in by NORML or paid out by NORML. The missing 
documentation preventing an exact accounting of the daily financial 
activities of NORML.

7. The documents reviewed reflected that the legal entity ECMC came into
existence and solicited funds in its own name. Documents of Incorporation
for ECMC reflect that ECMC was incorporated and filed on June 13, 1994.

8. That during the period of June 13, 1994 to and through May 31, 1995
funds were solicited by ECMC. The documents show bank deposits in the
amount of $22,811.00.

9. These identified records reflect an initial Board of Directors including:
Messrs.: Richard Cowan, Allen St. Pierre, Donegal S. Pearce all listing
addresses as the NORML Office located at 1001 Connecticut Avenue, NW #1010,
Washington, D.C. 20026.

10. According to the documentation reviewed, all money received in the name
of ECMC and deposited to the ECMC Account were subsequently deposited with
Nations Bank of Washington, D.C. Account # 0-33-07387.

11. According to the documents reviewed, and identified above, the following
individuals had authority to and in fact did write checks on the account 
identified above to which funds were deposited in the name of ECMC.

a. Richard C. Cowan.
b. Allen St. Pierre

These checks were either written by these individuals payable to Cash or
NORML and totaled $16,450.00 (See Exhibit A2)

12. Review of the above identified documents reflect that at the time period
encompassed by the documents reviewed, NORML was indebted to the following
and in the following amounts.

 
a. ATX Telecomm nications: $2,661.50 as of May 19, 1995. (Exhibit A4)
b. LDDS Metromedia Communications: $2,542.73 as of November 2, 1994.
(Exhibit A5)
c. Kelly Services, Inc.: $4,346.33 as of August 11, 1992. (Exhibit A6)

d. District of Columbia: $13,026.65 as of April 6, 1995. (Exhibit A7)

e. U.S. Internal Revenue Service: $3,472.07 as of December 26, 1994.
 (Exhibit A8)

13. That there was a discrepancy between the checks deposited which were
accounted for and the income identified to the IRS as a result of those
deposits for the following years and in the following amounts.
(Exhibit A2)

a. 1992 The checks reviewed and deposited accounted for $248,621.98 in
donations. NORML reported $207,800.00 pursuant to 1992 IRS Form 990. A
difference of $40,821.98. (Exhibit A9)

b. 1993: The checks reviewed and deposited accounted for $351,231.12 in
donations. NORML reported $323,184.00 pursuant to 1993 IRS Form 990. A
difference of $28,04712. (Exhibit A10)

c. 1994: The checks reviewed and deposited accounted for $574,270.982 in
donations. NORML reported $503,787.52 a difference of $70,483.46 pursuant 
to 1994 IRS Form 990. Exhibit All)

d. I further reviewed the attached document labeled Exhibit A12 which is 
correspondence from Mr. Pearce to Mr. Cowan. This one page document purports
to be an accounting of NORML's finances from August 1, 1992 through 
July 31, 1995.

14. The review of the documents was performed according to customary 
accounting principals using a balance sheet and ledger for the files 
provided.

15. Based upon this review as outlined above, my education and experiences, 
I find:

a. There is a clear discrepancy between the income received by NORML and 
ECMC during the periods above identified and the amount of income reported 
to the IRS for that period of time.
following.

b. ECMC although a legally incorporated entity made payments to NORML and 
to others in the form of checks written to cash that were not accounted for
contracts or other legal basis for such payments which were available for 
this review.

c. Records necessary to a complete and accurate accounting of NORML and 
ECMC's use of solicited funds were not available for this review.