(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.