Affidavit of Donald Keir

Hubbard Litigation

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State of California

County of Los Angeles
) ss.

I, DONALD KEIR, being duly sworn, hereby depose and declare under penalty of perjury:

1. My name is DONALD KEIR. I am a qualified expert in lifting, comparing and analyzing fingerprints and have been employed in such work for thirteen (13) years. I am currently employed as a Latent Print Expert with the Los Angeles Police Department, Scientific Investigations Division. I am qualified to make the statements in this affidavit as evidenced by my qualifications shown on my Resume attached hereto as Exhibit "1" . My professional services as a fingerprint expert have been retained by Barrett S. Litt, attorney at law, in the case "In Re the Estate of L. Ron Hubbard", Case No. 41750, Superior Court of the State of California for the County of Riverside.

2. On March 17, 1983 I signed an affidavit regarding a comparison and analysis of fingerprints I made on that date involving the following documents:

a. A photocopy of a standard fingerprint exemplar card, No. C 1396 with the name "Hubbard, Lafayette Ron" and the date "Aug 22 1948" upon it. I have been recently advised by Mr. Litt that the parties to this case (In Re the Estate of L. Ron Hubbard, No. 41750) have stipulated that the fingerprints on this exemplar card are the fingerprints of Lafayette Ron Hubbard, the subject of the above-referenced case.


b. "Certificate of Satisfactory Service United States Navy" issued to " Lieutenant 113392 Lafayette Ronald Hubbard".

c. "Los Angeles Special Officer Certificate " with date "1-7-48" and "Badge Number 2484" issued in the name "Lafayette Ronald Hubbard".

d. An original 4-page, handwritten letter dated "3 Feb 83" and titled "To the Judge Presiding Over the L. Ron Hubbard 'Probate Matter'". This document had several fingerprints on each of its pages. I have been advised by Mr. Litt that this affidavit of March 17, 1983 has been submitted as Respondent's Summary Judgment Exhibit "C C" which is incorporated herein by reference. I have in my possession an exact copy of that affidavit as well as its attached Exhibits and have used same in reaching my conclusions in this affidavit.

3. My conclusion on March 17, 1983 was that the fingerprints on the "exemplar card," the "Certificate of Satisfactory Service" card, and the "Los Angeles Special Officer" card were made by one and the same person as on the original 4-page letter "To the Judge Presiding Over the L. Ron Hubbard 'Probate Matter'".

4. On this date, I have made a careful examination of a seven-page letter, titled "Declaration of L. Ron Hubbard", a copy of which is attached hereto as Exhibit "2". I have determined that this document has a fingerprint on each page placed there by the right index finger of the same individual.


5. I have carefully compared the fingerprints on each page of Exhibit "2" with the above referred to fingerprint exemplar card (Exhibit "B" of the March 17, 1983 affidavit) as well as the other Exhibits of Respondent's Summary Judgment Exhibit "C C". In conducting my analysis, I have reached the following conclusion: There are not less than ten (10) and in most of the prints more than fifteen (15) points of identification on each fingerprint of each page of Exhibit "2" that match the Exhibits that were attached to my affidavit of March 17, 1983.

6. It is my expert opinion that the fingerprints on Exhibit "2" are of the same person as on the fingerprint exemplar card that is Exhibit "B" of my affidavit of March 17, 1983 (and accordingly the same person's fingerprints as on all the other Exhibits that are part of my March 17, 1983 affidavit--Respondent's Summary Judgment Exhibit "C C").

7. I have first-hand personal knowledge of all the facts in this statement, and if called as a witness, I could and would testify competently to them under oath.

Signed and sworn to under the pains and penalties of perjury on this 18th day of May, 1983.

[signed] Donald Keir

Subscribed and sworn to before me this 18th day of May, 1983.
[signed] W. Charles Armtrong Jr.
Notary Public in and for said County and State

Notary Public - California
Principal Office in Los Angeles County
My Commission Expires Dec. 15, 1986.