IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, CHANCERY DIVISION

K. RICHARD KEELER,

Plaintiff, No. 93CH 003484

V.

MARTIN W. MYERS and,

DIANE G. ELDER

Judge Edwin M. Berman

Defendants.

AFFIDAVIT OF MARTIN W. MYERS

I, Martin W. Myers, do hereby swear:

1. I am an attorney licensed to practice law in the Stat:e of Kansas and the State of Illinois. I am a defendant in the above entitled action and am married to Diane G. Elder, also a defendant in the above action. I received a Bachelor of Arts degree in Political Science in 1965 and a Juris Doctor degree in 1968 from the University of Kansas.

2. (a) In May 1992, plaintiff, K. Richard Keeler telephone me at my home to inform me that he was under criminal investigation for child molestation by the Sheriff's Office of San Diego County, California. Some of the information disclosed by Mr. Keeler is contained in the Keeler document which is the subject of this litigation. For example, part of the explanation Mr. Keeler gave to me for the initiation of the investigation is contained at page 12 and last paragraph of page 14. Some of the information Mr. Keeler told me is not contained in the document. For example, the fact that he was under criminal investigation for child molestation, his feelings regarding the investigation and his impressions of the detective conducting the investigation are not contained in the document.

(b) Contrary to the statement made by Mr. Keeler in paragraph 10 of his affidavit, I have no recollection of Mr. Keeler offering his resignation as a trustee to me, during the aforesaid conference or at any other time. Although I was the executive director of the Foundation and the trustee designated to be the chief liaison with the Foundation's legal counsel, neither Mr. Keeler nor Mr. Frazer informed me that Mr. Keeler had offered Mr. Frazer his resignation as a trustee, or even that they had discussed the matter.

(c) Immediately after my conversation with Mr. Keeler, I discussed the matter with Ms. Elder. Ms. Elder and I discussed what Mr. Keeler had told me, our concerns about Mr. Keeler, and our concerns regarding Mr. Keeler's fitness to continue as a trustee of Urantia Foundation.

3. UPANTIA Foundation ("Foundation") is a not-for-profi.t publicly supported common law charitable trust established January 11, 1950 in perpetuity under the laws of the State of Illinois. Each of the five members of the Board of Trustees is a fiduciary responsible for the proper administration of the Foundation's affairs consistent with the highest ethical standards. Attached hereto as Exhibit A, is a copy of the Declaration of Trust Creating Urantia Foundation. The high ethical, moral and lofty purposes and goals of the Foundation are set out in Article II, Paragraph 2.1 and 2.2 of the Declaration of Trust.

4. (a) I was elected a trustee of the Foundation in May 1973, having served as an advisor to, and agent of, the Foundation for a number of years prior thereto.

(b) Mr. Keeler was elected a trustee of Urantia Foundation in July 1989. He is currently the treasurer of the Foundation.

(c) My current status as a trustee of Urantia Foundation is the subject of an action entitled Myers v. Burns, Caston, Keeler, Mundelius and Rolnick, Civil Action No. 94-0927 pending in the United States District Court for the Northern District of Illinois before the Honorable Ann C. Williams. Contrary to paragraph 7 of Mr. Keeler's affidavit, wherein he avers that I was removed as a trustee on April 17, 1993, the aforesaid action alleges, inter alia, that the removal proceedings against me were in violation of the requirements of the Declaration of Trust Creating Urantia Foundation and therefore void.

5. (a) In May or June of 1992, I received a telephone call at home from Foundation trustee Hoite C. Caston, regarding the criminal investigation of Mr. Keeler. Mr. Caston repeated some of the information told to me by Mr. Keeler, a portion of which appears in the Keeler document, and then proceeded to state that although the situation may have involved bad judgment by Mr. Keeler, "it was really nothing to worry about."

(b) I told Ms. Elder about my telephone conversation with Mr. Caston. Ms. Elder told me she believed that Mr. Keeler had asked Mr. Caston to call me so that I would not believe that the situation was serious.

(c) On or about August 26, 1992, Ms. Elder and I were informed by Ms. Joan Bondi that on August 22, 1992 Mr. Caston told her that he had edited the Keeler document for Mr. Keeler.

6. In June 1992, Mr. Keeler telephoned me again at home to discuss the criminal investigation. Mr. Keeler told me, inter alia, that the detective investigating him had forwarded his file to the San Diego County District Attorney with the recommendation that he be prosecuted. I told Ms. Elder about my conference with Mr. Keeler.

7. Sometime in July 1992, Mr. Keeler telephoned me a third time to discuss the criminal investigation. Mr. Keeler told me, inter alia, that although the San Diego County Sheriff's Office had recommended prosecution, he had been informed that the San Diego County District Attorney had declined to prosecute him. I told Ms. Elder about my conference with Mr. Keeler.

8. (a) I had been concerned about Mr. Keeler and his fitness to serve as a Foundation trustee for some time prior to my telephone conferences with him regarding the San Diego criminal investigation. My concerns arose in part as a result of two unusual discussions initiated by Mr. Keeler on the subject of child molestation in Paris, France during a Foundation business trip. Specifically, on March 3, 1992, during a dinner meeting with Foundation legal counsel at a public restaurant in Paris, Mr. Keeler initiated a disturbing, and in my opinion inappropriate, discourse on child molestation. Mr. Keeler spoke in a loud and animated voice and it was apparent to me that he was disturbing the other diners at the restaurant as I could see them turn to look at him in a manner that indicated to me they were disturbed by his loud voice and physical gestures. Some of the information, statistics and opinions expressed by Mr. Keeler are contained in the Keeler document including, inter alia, his statements at page 1-7) and page 2-11) On the preceding night in the McDONALD'S restaurant on the Champs-Elysees, again during a dinner meeting with Foundation legal counsel, Mr. Keeler initiated conversation on the subject of child molestation, suggesting that I knew something about the subject from having been a victim of such abuse myself. I was shocked and embarrassed by the suggestion. I believed both discussions to be inappropriate given that we were in France on Foundation business accompanied by Foundation legal counsel. I believed Mr. Keeler's behavior and comments created a most unfortunate impression on the Foundation's legal counsel. Upon my return from France, I told Ms. Elder about the aforesaid events.

(b) I brought my concerns about Mr. Keeler's behavior to the attention of trustee Hoite C. Caston in a telephone call soon after my return from Paris in March of 1992. Mr. Caston asked what I meant and I replied that I believed that Mr. Keeler was not acting right or thinking right.

(c) In June of 1992, upon my return from a subsequent Foundation trip to Europe, Foundation president, Patricia S. Mundelius called me to discuss the trip. I mentioned to her that I was concerned that Mr. Keeler did not appear to be acting or thinking right and it was perhaps best that he had not accompanied me on the June trip as he had in February-March. I did not mention the criminal investigation of Mr. Keeler to her at that time because I did not believe I had sufficient evidence of improper behavior by Mr. Keeler to warrant officially placing the matter before the President of the Board of Trustees. Nor did I at that time have any reason to believe that Mr. Keeler was withholding facts about the situation from me.

9. (a) On the evening of August 20, 1992, Ms. Elder called me to the telephone explaining that Joan Bondi, the Foundation Office Manager, and Damian Bondi, a Foundation office worker were on the phone. I put the telephone on speaker so that Ms. Elder, myself and the Bondis could all participate in the telephone conference. Ms. Bondi proceeded to tell me that Mr. Keeler had telephoned Sheila Schneider, the Foundation receptionist, that morning, and had informed Ms. Schneider that the Foundation printer was not functioning properly. Ms. Bondi further stated that Mr. Keeler had requested Ms. Schneider to resolve the problem with tile Foundation printer. Ms. Bondi told us that Ms. Schneider had requested Ms. Bondi to help her. Ms. Bondi explained that when they turned on Mr. Keeler's computer there was a backup file in the program and the computer asked that they either delete the file or rename it. Ms. Bondi told us that she renamed the f ile and sent it to the Foundation's printer which then printed the Keeler document. Ms. Bondi told us that as the document printed out of the Foundation printer the first words that she saw were the six words

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at page 10, line six from the bottom, of the Keeler document. Ms. Bondi stated that those words alarmed her and that she placed the document in her briefcase to read when she got home.

(b) Ms. Bondi and Mr. Bondi further told us that the Keeler document related to allegations of child abuse which had been made against Mr. Keeler. Ms. Bondi and Mr. Bondi related several things which Mr. Keeler had admitted to in the document. Mr. Bondi asked me if it was true that I was aware that Mr. Keeler had been under criminal investigation for child molestation. confirmed that Mr. Keeler had so informed me and told them some of what Mr. Keeler told me had lead to the investigation. Ms. Bondi and Mr. Bondi indicated considerable surprise that I and Ms. Elder already knew about it. Mr. Bondi asked me if the other trustees were aware of this and I responded that I did not know to what extent this as yet had been made known to the full Board ot Trustees.

(c) Mr. Bondi then read several portions of the Keeler document to me and my wife. Those passages include the admissions contained at page 7, 1-15 (a) ; page 8, the last two paragraphs; page 10, I 1G; page 10, the last ten lines. Ms. Bondi and Mr. Bondi repeatedly and unequivocally stated that both the behavior admitted to in the document by Mr. Keeler and the explanations given for such behavior were "disgusting" and "sick." They both stated that Mr. Keeler should resign or be removed as a Foundation trustee. Both Ms. Bondi and Mr. Bondi were quite upset about the admissions in the Keeler document and Mr. Bondi wanted to do something about this. We (I, Ms. Elder, Mr. Bondi and Ms. Bondi) all voiced our concerns regarding Mr. Keeler's fitness to continue as a trustee and the impact the document could have on the Foundation.

(d) Mr. Bondi discussed his desire to distribute the Keeler document. Ms. Elder and I several times cautioned Mr. Bondi and Ms. Bondi to take their time in deciding what to do with the document and its disclosures. The telephone conference concluded with Mr. Bondi promising to give us the document the next day. We agreed that we would speak again after Ms. Elder and I had a chance to read the document.

10. On Friday morning, August 21, 1992, Mr. Bondi telephoned my home and I answered the telephone. Mr. Bondi stated that he had put the Keeler document on the building elevator. I called the elevator up to our apartment and retrieved the document. I glanced at it and gave the document to Ms. Elder to read. A few hours later Mr. Bondi called at home to see if I had read the document. I told him that I had not yet done so, and he strongly urged me to read it as soon as possible. I read the Keeler document that afternoon and several times since that day. After reading the document, much of the information previously described to me by Mr Keeler regarding the criminal investigation was placed in context. Further, I learned that according to the document many things Mr. Keeler had told me and others over the years were not true. My previous concerns about Mr. Keeler and his fitness to serve as a Foundation trustee heightened as a result of reading the document.

11. (a) On the evening of August 21, 1992, Ms. Bondi and Mr.

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Bondi again spoke with me and Ms. Elder on the telephone. We spoke for a long time about the contents of the Keeler document. The Bondis again shared with us their analysis of the admissions made by Mr. Keeler in the document with particular emphasis on his explanations therefor.

(b) The Bondi's further reported that Mr. Bondi had given copies of the document to Robert Solone and Seppo Kanerva, both Foundation office workers, and that they, the Bondis, had attempted to arrange a meeting with Ms. Mundelius, Foundation president, who was in Chicago for a trustees meeting scheduled for 10:00 a.m. the following day. Ms. Bondi and Mr. Bondi explained that Ms. Mundelius had refused to make herself available to them that evening. The Bondis further explained that they intended to come to the Foundation office early the next morning to insist that they have a meeting with Ms. Mundelius, at which time they intended to show her the Keeler document. Both Ms. Bondi and Mr. Boiidi repeatedly expressed their opinion that it was imperative that Ms. Mundelius be shown the document prior to the trustees meeting.

(c) Mr. Bondi told Ms. Elder and me that he was preparing a memorandum that would consist of his analysis of the Keeler document which he had already orally shared with us to distribute to the Foundation trustees with the document. He further informed us that he planned to send the document to the Foundation's legal counsel so that the trustees would "not be able to ignore" the matter. Mr. Bondi promised us that he would give us a copy of the memorandum as soon as it was completed.

12. (a) On August 22, 1992 at 8:54 in the morning, Mr. Bondi faxed a copy of the memorandum to Ms. Elder and me at our home from his office at the Foundation. Ms. Elder took the faxed copy of the memorandum from our fax machine and after reading it, gave it to me. The memorandum makes reference to the passages of the document Mr. Bondi read to us over the phone on August 20, 1992. It further contains the analysis of the document which he and Ms. Bondi had expressed in our telephone conferences of August 20 and 21.

(b) Later that morning, Mr. Bondi and Ms. Bondi telephoned my home and told Ms. Elder and me that they had arrived early that morning at Foundation headquarters and that Ms. Mundelius initially refused to meet with them. They further told us, however, that because the airplane of Mr. Caston had been delayed several hours, necessitating the rescheduling of the trustees meeting to a later time, Ms. Mundelius relented and agreed to meet with them. Ms. Bondi and Mr. Bondi told Ms. Elder and me that they would call us after the meeting with Ms. Mundelius to let us know what happened.

(c) Later during the afternoon of August 22, 1992, Mr. Bondi and Ms. Bondi called Ms. Elder and me to relate what had happened during their meeting with Ms. Mundelius. The Bondis reported, inter alia, that they had both met with Ms. Mundelius and had given her a copy of the Keeler document, that she had read the document in their presence, and that she had become visibly upset upon reading the document. The Bondis further stated that Ms. Mundelius thanked them for bringing the document to her attention

and told them that they could present the document to the trustees at the meeting that afternoon.

13. (a) At approximately 4:00 p.m., the afternoon of August 22, 1992, the then Trustees, Mr. Caston, Mr. Keeler, Mrs. Mundelius and myself, and Quin R. Frazer, counsel to the Foundation, gathered. for the trustees meeting. As the meeting started, Mr. Bondi knocked on the door to the meeting room and entered the room with Mrs. Bondi. Mr. Bondi was carrying copies of the Keeler document. and his memorandum dated August 22, 1992. Mr. Bondi stated that he wanted to give the trustees the materials. As the Bondis entered the room, Mrs. Mundelius rose and went to the Bondis who were by the door. At about the same time, Mr. Caston stood up saying "You can't come in; we already know about that." He then got up and went over to the door. It appeared to me that he planned to usher the Bondis out of the room. Mr. Bondi then stated that the trustees should see the document, that Mr. Keeler was unfit to be a trustee and that Mr. Keeler should resign as a trustee of Urantia Foundation. Mr. Bondi handed the documents to Ms. Mundelius and the Bondis left the room.

(b) Ms. Mundelius then reconvened the trustees meeting, whereupon I called for Mr. Keeler's resignation as a trustee of Urantia Foundation stating that the document revealed that Mr. Keeler was unfit to serve as a trustee. I further stated that "This is not going to help the Foundation. Things like this have a way of getting out." Mr. Frazer asked me "How is it that it will get out?" I responded by stating "Things like this have a way of

getting out." In no way did I then, or have I ever made any threat to disclose the Keeler document or its contents. My aforesaid statements were based upon basic common sense coupled with my then twenty-four (24) years of experience with individuals interested in the affairs of the Foundation.

(c) Contrary to the statements contained in paragraph 19 of Mr. Keeler's affidavit, it is self evident that my January 16, 1993 Statement to the Board of Trustees of Urantia Foundation does not contain any threat, intimated, veiled or otherwise, to disclose the contents of the Keeler document.

14. (a) On or about August 26, Ms. Elder and I had dinner at the Bondis' home to further discuss the Keeler document, the effect it was having on the Foundation, Mr. Keeler's fitness to continue as a trustee, and the judgment exhibited by trustees Caston, Mundelius and Keeler on the issue. Mr. Bondi told us that he had sent a copy of the Keeler document to his sister asking for her evaluation of the behavior admitted to by Mr. Keeler in the document and Mr. Keeler's explanations therefor. He explained that he felt she had a professional or educational background which made her qualified to evaluate the document and that he wanted the benefit of her opinions so as to help him evaluate his own.

(b) The Bondis further informed Ms. Elder and me that on or about the evening of August 22, 1992, Mr. Caston informed the Bondis that he had been aware of the criminal investigation of Mr. Keeler for some time and that he had helped Mr. Keeler edit the Keeler document.

(c) Approximately ten days later, when Ms. Elder and I were again at the Bondis home for dinner, Mr. Bondi reported that his sister had reviewed the document and that she stated, inter alia, that Mr. Keeler in her opinion was a very disturbed man.

15. On or about October 19, 1992, Mr. Bondi informed me that he had surrendered his copy of the Keeler document to Mr. Keeler. I was quite surprised to learn this since Mr. Bondi had told me that he would never surrender his copy to Mr. Keeler and he and Ms Bondi had repeatedly urged me not to surrender my copy either.

16. Through December of 1992 the Bondis, Ms. Elder and I frequently discussed the contents of the Keeler document and Mr. Keeler's fitness to serve as executive director and trustee of the Foundation. Mr. Bondi and Ms. Bondi discussed with us several times their concerns about Mr. Keeler and his unprofessional. behavior in the office with regard to the staff and to third parties. Ms. Bondi told us that she had filed a formal complaint with the Board of Trustees relating to Mr. Keeler's inappropriate harassment and belittling of her at the office.

17. (a) On August 29, 1992, during a trustees hearing in Los Angeles, in the presence of trustees Mundelius, Caston and newly elected trustee Thomas Burns, Mr. Keeler asked me with whom I had discussed the contents of the Keeler document. I replied that I had discussed the document with Ms. Elder and my mother-in-law, Dorothy Elder. Contrary to the statements in paragraph 20 of Mr. Keeler's affidavit, I did not disclose the contents of the Keeler document to Ms. Elder or Mrs. Dorothy James Elder. There was no

further discussion of the Keeler document at that trustees hearing in my presence. Neither on that occasion nor on August 22, 1992, nor on October 17, 1992, did Mr. Keeler ask me for my copy of the Keeler document, nor did he make any request for me to treat the information in the Keeler document confidential. In fact, Mr. Keeler never told me at any time that he considered the contents of the document to be confidential. Further, although he had ample opportunity to do so, Mr. Keeler never demanded that I surrender the document until April 2, 1993, thirteen (13) days, prior to filing this lawsuit against me and seven and a half months after he knew I had received the document.

(b) On September 21, 1992, and again on February 8, 1993, I received correspondence from Mr. Keeler requesting that I give any copies of the Keeler document in my possession to Mr. Keeler. Attached hereto as Exhibits B and C are true copies of the correspondence. The aforesaid correspondence does not request or demand that I treat the information contained in the document confidential. Further, they merely request, rather than demand that I surrender my copy of the Keeler document to Mr. Keeler. 

(c) On October 17, 1992, I attended a Foundation trustees hearing. Contrary to the statements in paragraph 18 of Mr. Keeler's affidavit, the Keeler document was not discussed in my presence at that hearing. Further, as stated above, I called for Mr. Keeler's resignation, not removal, at the August 22, 1992 trustees meeting.

(d) Ms. Elder and I received a letter dated January 27,

1993 from Ms. Mundelius relating to our move from our apartment at Foundation headquarters. It is self evident that the letter does not refer to the Keeler document. Ms. Elder and I never interpreted the document to do so.

(e) On October 26, 1992, Ms. Mundelius, president of the Foundation, wrote to me indicating that each of the other trustees had given their copy of the Keeler document to Mr. Keeler and that the Board of Trustees "requested" that I return to Mr. Keeler any and all copies of the report which I might have. Ms. Mundelius further stated that, "The Foundation's legal counsel, at the Board's request and with Mr. Keeler's agreement, will keep a copy of the report in his files" thus indicating the document clearly was related to Foundation business and to my duties and obligations as a trustee of Urantia Foundation, and further, that it was of legitimate interest and concern to me as a reader of The URAN'I'IA Book. Attached hereto as Exhibit D is a true copy of the letter. I did not receive the document attached to Mr. Keeler's affidavit as Exhibit C.

(f) On November 3, 1992, in the stairwell of The Foundation leading up to my and Ms. Elder's apartment, Mr. Keeler accosted me and said that he wanted to discuss the "Libby Report [Keeler document]." I replied that I was not able to discuss the matter with him. Mr. Keeler did not request that I treat the information contained in the Keeler document as confidential nor did he make any demand for possession of my copy of the Keeler document.

(g) I received a letter dated April 2, 1993 addressed to my attorney, Don E. Glickman, wherein for the first time Mr. Keeler, through his attorney, Charles B. Sklarsky, demanded that I surrender to Mr. Keeler my copy of the Keeler document. Attached hereto as Exhibit E is a true copy of the aforesaid correspondence.

18. (a) Much of the information contained in the Keeler document is of public record or is well known by those who know, or know of Mr. Keeler. For example, the information contained at page 1 (points 1-7) of Keeler document.

(b) Much of the information contained in the Keeler document was disclosed to me, Ms. Elder and others in my presence well prior to August 21, 1992, when Ms. Elder and I were given the document, without any request for confidentiality or any apparent regard to the privacy interests of Mr. Keeler or Mr. Keeler's former wife, former wife's daughter, daughter or mother of his daughter. See for example the information contained at page 4 (11 5-7) Mr. Keeler discussed that particular subject with me, my wife and others in my presence repeatedly and for several years. Similarly, Mr. Keeler has told me, and others in my presence the information set forth at page 5 (last paragraph), page 6 (paragraphs 4-7 ) and page 7 (first paragraph) . Mr. Keeler has also discussed other information contained in the document with me and others. See for example Keeler document page 1, points 1-7.

19. I have not disclosed nor discussed the contents of the Keeler document with anyone who did not already have independent prior knowledge of the document and its contents.

20. I have not given a copy of the Keeler document to anyone other than legal counsel.

21. I have not shown the Keeler document to anyone, with the single exception that I did show the Keeler document to Dr. Ari Kalaja of Kotka, Finland. Dr. Kalaja had prior independent knowledge of the existence and contents of the document. 

22. The Foundation publishes The Urantia Book, a book of the highest moral and ethical teachings. Well over 200,000 copies of The Urantia Book have been sold. The book continues to sell at a rate of over 10,000 copies per year. In addition, The Urantia Book has been translated into Finnish, French and Spanish, and these translations are sold along with the original English book throughout the world.

23. (a) Urantia Foundation solicits funds nationally and internationally to its mailing list of some 10,000 readers of The Urantia Book. Historically solicitation letters have been sent out annually, although from time to time to support special projects the trustees have initiated additional solicitations. Attaclied hereto are true copies of the December 6, 1993 (Exhibit F), and the February 1994 (Exhibit G) , fund raising letters signed by the trustees of Urantia Foundation, including Mr. Keeler. The "Urantia Foundation Needs List" (Exhibit H) which accompanies Exhibit G, contains the following statement:

 Anyone interested in assisting the (sic) Urantia Foundation with fund-raising (sic) , please call Richard Keeler at (312) 525-3319.

(b) The Foundation mails at least twice a year a newsletter entitled UrantiaN News to these same readers providing information about the trustees' decisions and related organizational activities and operations. True copies of specimens of the UrantiaN News are attached hereto as Exhibits I, J and K.

24. From time to time, the Foundation has published and distributed special reports to its entire mailing list of readers. The latest such communication is the April 1989 Special Report to Readers of The Urantia Book. Letters written by the trustees, including Mr. Keeler, appeared in the Special Report. A true copy of an excerpt of this report discussing the background and activities of the then trustees, including myself and Mr. Keeler is attached hereto as Exhibit L.

25. The Finnish Urantia Society, a licensee of the Foundation, publishes its English language Reflection. Reflection is distributed in the United States and abroad, and frequently reports on the activities and statements of the trustees. Attached hereto as Exhibit M is a true copy of the March 1993 issue of Reflection wherein at page 1 Mr. Keeler was described as "already a celebrity among Finnish 'Urantists'." (Emphasis supplied) Photo-graphs and interviews with the trustees have from time to time appeared in such publications (See Exhibit M, pages 12-14, an interview with Foundation President Ms. Mundelius) . Attached hereto as Exhibit N is a true copy of the 1-2 1993 issue of Reflection wherein a speech I gave to the Finnish Urantia Society is discussed at page 12. Attached hereto as exhibit O is

a true copy of the Finnish language Heijaste dated Nov. 3, 1994 which contains a photograph of some Foundation trustees in attendance at the Foundation's 1994 Summer Conference held at Vanderbilt University, Nashville, Tennessee.

26. The Foundation trustees correspond both personally and through the Foundation's Reader Services staff with readers that contact the Foundation with various questions, comments or observations.

27. Individuals from throughout the United States and abroad visit Foundation headquarters in Chicago to discuss various issues and to meet and to socialize with Foundation staff and the trustees if there.

28. In furtherance of the trustees' duties to disseminate the teachings of The Urantia Book and otherwise to fulfill the responsibilities and duties imposed upon them by the Declaration of Trust Creating Urantia Foundation, the trustees sponsor International Urantia Association (IUA), an international membership organization for readers of The Urantia Book to which anyone may belong. Prior to the sponsoring of IUA, the trustees of Urantia Foundation recognized Urantia Brotherhood, a social and fraternal membership organization which was formed in January 195S. Attached hereto as Exhibit P is a true copy of the pamphlet entitled International Urantia Association -- Charter and By-Laws.

29. The trustees sponsor, organize and attend activities of International Urantia Association (IUA), including the various authorized Urantia Associations at home and abroad. In 1993 alone,

the trustees attended public meetings with readers in Nashville, Los Angeles, New York, Chicago, Hawaii and Finland. Please see Exhibits I, J and K, respectively, the May 1993 Urantia News the November 1993 UrantiaN News, and the May 1994 UrantiaN News (each published by Urantia Foundation) and Exhibit 0, the Finnish language No. 3 1994 Heilaste (published by a licensee of the Foundation) , all depicting the international, public activities of the trustees of Urantia Foundation, with Heiiaste displaying a photograph showing Mr. Keeler and some other trustees at the International Urantia Association's 1994 Study Conference, July, 1994.

30. To communicate with its public and as a part of the trustees' efforts to foster the dissemination of the principles and teachings of The Urantia Book, the trustees travel throughout the United States and abroad to meet with readers of The Urantia Book.

31. (a) Between 1990 and 1992, Mr. Keeler and I traveled as trustees, on behalf of the Foundation, to meet with readers of The Urantia Book in San Francisco, Los Angeles, Chicago, Minneapolis-St. Paul, Maui, Oahu and Hawaii in the Hawaiian Islands, English and French Canada, France, the Netherlands, Finland, Estoni,a, Australia and New Zealand.

(b) More specifically, as a trustee of URAN'FIA Foundation, Mr. Keeler attended a public meeting of readers of The Urantia Book in Australia in 1989. Again in 1990, Mr. Keeler attended meetings with readers there, including readers at Brisbane, Melbourne, and Sydney, and at a public pan-Australian

meeting for readers of The Urantia Book held at Warburton, Victoria. Further, as a trustee of Urantia Foundation, Mr. Keeler attended meetings in 1990 with readers of The Urantia Book in French and English speaking Canada, Estonia, Finland, France, the Netherlands, and Auckland and Wellington, New Zealand. In addition, Mr. Keeler attended at least three meetings of Hawaiian readers, as well as meetings with other groups throughout the United States, including Houston, San Francisco, Portland, Los Angeles, Phoenix, and New York City.

In 1991 as a Trustee of Urantia Foundation, Mr. Keeler represented Urantia Foundation in meetings with readers of The Urantia Book again in Finland, the Netherlands and France, as well as in the United States, including Minneapolis-St. Paul. In 1992 Mr. Keeler attended reader meetings on behalf of Urantia Foundation as a trustee of Urantia Foundation in Chicago, Los Angeles, and New York City. In 1993 Mr. Keeler represented Urantia Foundation in Finland, California, Illinois, Tennessee, Hawaii, and New York City. Also, Mr. Keeler, Ms. Mundelius, Mr. Burns (all Foundation trustees) were present in Finland in June 1993 for the formal presentation of the Finnish translation of The Urantia Book and the official announcement of the availability of the Spanish translation. In 1994 Mr. Keeler represented Urantia Foundation in Los Angeles and in Nashville, and outside the United States, Mr. Keeler traveled to South America on behalf of Urantia Foundation.

32. In 1993, the trustees, including Mr. Keeler, attended public meetings with readers in Nashville, Los Angeles, New York,

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Chicago, Hawaii and Finland. See Exhibits I, J K, M, and N identified above. 

33. (a) There are numerous newsletters published by readers of The Urantia Book that are not licensed, sponsored or approved by the Foundation. Those publications include The Invisible Fellowship, The Monthly Monitor, Pervaded Space, The Circles, and Urantian Souiourn. There are several others. The behavior, actions, and policy decisions of the trustees are reported, analyzed and very often, criticized in these publications.

(b) Mr. Keeler was recently quoted in one such publication The Invisible Fellowship Volume 1 No. 2 1994, at page 8, which publication is distributed throughout the United States. A true copy of the aforesaid publication is attached hereto as Exhibit Q.

(c) In fact, the trustees, including Mr. Keeler and myself, have frequently been caricatured in cartoons contained in some of the aforesaid publications.

34. In addition to newsletters, readers often circulate open letters to other readers regarding issues of concern to them. Such letters have been both supportive and pointedly critical of policy decisions as well as personal attributes, behavior, and acts of the trustees.

35. (a) Mr. Keeler has been a reader of The Urantia Book since the early 1960s and has become a well-known public figure in the community of readers of The Urantia Book for many years. Even before becoming a trustee of Urantia Foundation, for thirty (30)

years Mr. Keeler, as a reader of The Urantia Book has attended any number of public reader conferences and meetings for readers of The Urantia Book, including meetings at Urantia Foundation in Chicago in the early 1960s, meetings in California, especially the First Western Urantia Conference in Los Angeles in 1973, the Vancouver British Columbia meeting, the Los Angeles meeting for readers of The Urantia Book in 1983, and the Finnish Urantia Society inauguration in 1989 in Finland. See Exhibit M (page 1) and N (page 2) identified above.

(b) Mr. Keeler often performed publicly for meeting attendees by playing his banjo and leading others in song. This has made him a well-known person among readers of The Urantia Book nationally and internationally.

Date: September 29, 1994

Signed: Martin W. Myers

Notarized