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AFFIDAVIT OF DONALD KEIR

 

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.

 

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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 finger-

prints 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.

 

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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 identifica-

tion 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
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

[stamp]
OFFICIAL SEAL
W. CHARLES ARMSTRONG, JR.
Notary Public - California
Principal Office in
Los Angeles County
My Commission Expires Dec. 15, 1986.
 
 

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