1. Unless I have indicated otherwise, the statements I make are within my own knowledge.
2. Between 2002 and 2008, I served as H.S.H. Prince Albert II of Monaco’s intelligence advisor and established and directed the Monaco Intelligence Service. In this capacity and through several investigations, I became aware of and tried to combat a growing invasion of Russian organized crime and corrupt officials pouring into Monaco and influencing its politics. Through my intelligence operatives inside Russia, I was informed of the details of Russian intelligence services’ profile of Prince Albert and their plan to place or compromise key people within Prince Albert’s friends and advisors with the aim of influencing and directing his decision-making.
3. Through my intelligence sources and operatives in Russia and Monaco, I have learned that several of Prince Albert’s aides and advisors have developed business interests with Russians of high government position and individuals suspected of involvement with Russian organized crime.
4. During several meetings I warned Prince Albert about Russian designs to influence him and my concerns that certain of his aides and advisors have been compromised by corruption or conflicts of interest.
5. In 2006, Sergei Pugachev was trying to develop personal and business ties with Prince Albert and to buy Monegasque nationality. At Prince Albert’s request, I investigated Mr. Pugachev, a Russian with interests in banking, industrial and commercial properties. In my investigation I learned that Mr. Pugachev was a member of Vladimir Putin’s inner circle and had links to Russian organized crime. Separate and independent from my investigation, Monaco’s police force also investigated Mr. Pugachev and concluded he had links to Russian organized crime.
6. Prior to Prince Albert’s North Pole Expedition, on 10 April 2006, I emailed Prince Albert’s Chief-of-Staff, Jean-Luc Allavena, a memo on how Russian intelligence will spy on the entourage. Mr. Allavena was to brief Prince Albert on the memo. In particular I warned that any intimate socializing with men or women would likely be video-recorded to be used later as “leverage.” I was particularly concerned for Prince Albert who frequently engaged in intimate socializations. In order to protect him, I had obtained reports from foreign intelligence agencies in which surveillance caught Prince Albert with men and women. I worried that the Russians would obtain similar surveillance and use it to influence the Prince.
I declare under penalty of perjury that the foregoing is true and correct, and I have executed this affidavit in Santa Barbara, California on 10 December 2010
IF PRINCE ALBERT AND VLADIMIR PUTIN CHOOSE TO DENY, THEY SHOULD SWEAR AN OATH UNDER PENALTY OF PERJURY.