(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