Case 2:12-cv-08333-ODW-JC Document 108-3 Filed 04/08/13 Page 1of13 Page ID

#:2385

I, Brent Berry, being duly sworn, depose and state:

I

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| am over the age of eighteen, suffer no legal disabilities, have personal knowledge of the
facts set forth below, and am competent to testify.

I am a resident of Andover, MN.
| have known Alan Cooper (“Alan”) since 2006.

I consider myself a close confidant of Alan’s and have assisted him in various personal
matters over the years.

| introduced Alan to Mr, Steele and brokered the arrangement whereby Alan could live at
Mr. Steele’s property for free in exchange for basic caretaking services.

I have had many occasions to see Alan and interact with him since the time he became a
caretaker at Mr. Steele’s cabin property in McGrath, Minnesota. Alan lived in the guest
cabin about 100 yards from Mr. Steele’s main cabin.

During the first few years of observing of Alan, I would say he appeared toe behave pretty
responsibly towards Mr. Steele's property.

On several dates, I had occasion to be present when Mr. Steele and Alan would speak
about various matters. Normally this occurred while we were sitting around campfire
located between the two cabins.

Alan and Mr. Steele seemed to have a very good realtionship and Alan would routinely
ask John how he wished he could help Mr. Steele for all the things Mr. Steele did for
Alan, such as allowing him to live on the property for free.

It was clear from their conversations and references to Mr, Steele’s legal work that Alan
was involved working with Mr. Steele. Alan did not seem upset about this relationship,
and in fact often made jokes about not having to worry about ever buying beer again due
to his assisting Mr. Steele.

I remember Mr. Steele at various times asking Alan to assist him with certain paperwork
and I never saw Alan objecting to this assistance.

On at least one occasion, I recall Alan asking John, “How’s my porn company doing?”

Beginning in late 2011, Alan began exhibiting unusual behavior on various occasions
when I was visiting the property. Alan began acting erratic, frequently threatening to hurt
others.

On several occasions, Alan bragged that “If] pissed him off, they would never find my
body, just like the others”

Due te Alan’s strange behavior, I began to minimize my contacts with him unless others
were around. Although I still consider Alan a very good person and a friend to this day,
on some days he acted like a completely different person and extremely agitated. I later
found out from Alan that the days he had acted very unusual were the ones in which he
had not taken certain antipsychotic medication his doctor had prescribed.

Case 2:12-cv-08333-ODW-JC Document 108-3 Filed 04/08/13 Page 2 of 13

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#:2386

16 I was hired by John Steele to sell his log home at auction in the summer of 2012. The
auction was to be held September 29, 2012.

17 During the summer I had to enter Mr. Steele’s property frequently to allow access to
handymen and prospective buyers. Alan was still living in the guest cabin at that time.

18 Almost immediately 1 became aware that Alan’s mental state had further deteriorated and
I felt very uncomfortable to be alone around him.

19 On approximately August [3th of 2012, | went to Mr. Steele’s property to prepare it for a
potential buyer. My girlfriend was with me on this trip. Alan came out of his cabin and
was Clearly in an extremely agitated state. Before 1 could even speak with him, he began
threatening to hurt me. Due to the manner in which made the threats were made, his
comments about past violence, I felt in fear for my life.

20 1 immediately called John Steele and told him what happened and that I could not show
the property under these conditions, I contacted the Aitkin County police department to

report what had happened. Due to Mr. Steele’s request, I did not follow through with
filing charges.

21 Alan has sent me a variety of bizarre text messages, accurate copies of which are attached
in Exhibit A hereto. In these text messages, Alan threatened to shoot me, indicated that he
was removing wood from Mr. Steele’s property, explained that he had some mental
disorder(s), and apologized for his bizarre behavior.

22 Although Alan requested in his texts that I go to his doctor that was treating him for his
mental illness.

23 Alan indicated that if ] entered the property he would shoot me. Although Alan stated he
would only shoot me in the foot, | felt out of an abundance of caution not to trust his
assurance that he would only shoot me in a non-critical part of my body.

24 Regrettably [ have not had much interaction with Mr. Cooper in the past few months and
am, concerned that he is not getting the medical treatment that he himself has stated he
needs in various conversations and texts.

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The foregoing instrument was acknowledged before me this 15th day of February, 2013.
NOTARIAL STAMP OR SEAL (OR OTHER TITLE OR RANK)

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