DECLARATION OF ROBERT S. KEEFER

I, ROBERT S. KEEFER, declare:

On or about February 8, 1982 I was retained by a licensed attorney to participate in an investigation under the supervision of Richard Bast.

The purpose of the investigation was to gather information in the Clearwater, Florida area to ascertain if there was a conspiracy to deprive the Church of Scientology of its constitutional rights and to drive them out of Clearwater.

The investigation utilized a "cover identity" that I was a representative of European investors wishing to invest large sums of money in Clearwater area real estate.

Under this cover identity I interviewed businessmen and people concerned with real estate development in Clearwater, Florida. I have read press reports and declarations sayins that this was an operation seeking to entrap or corrupt U.S. District Court Judge Ben Krentzman by videotaping him with prostitutes and drugs. This characterization of our investigation is entirely false.

Our investigation never intended to entrap or corrupt Judge Krentzman or any other person. To my knowledge there never were any prostitutes or drugs on the ship. I know for a fact that our investigation did not include the use of any drugs or prostitutes. Every aspect of our investigation was verified to be lawful and to my knowledge no illegal activities took place. Judge Krentzman's name came up in our pre-investigation planning and we were specifically instructed not to contact or communicate with Judge Krentzman either directly or indirectly. To my knowledge, Judge Krentzman's name was never mentioned in the investigation on the ship and there never was a plan to approach, entrap or corrupt him in any manner. I declare under penalty of perjury that the foregoing is true and correct.

Executed at Beverly Hills, California. This 26th day of January, 1984.

ROBERT S. KEEFER