Exhibit 31.1

                               CERTIFICATION

I, Arnold P. Kling, certify that:

1.      I have reviewed this annual report on Form 10-KSB of Twin Lakes, Inc.;

2.      Based on my  knowledge,  this annual  report does not contain any untrue
        statement of a material fact or omit to state a material fact  necessary
        to make the statements made, in light of the  circumstances  under which
        such  statements  were made, not  misleading  with respect to the period
        covered by this annual report;

3.      Based on my knowledge,  the financial  statements,  and other  financial
        information  included  in this  annual  report,  fairly  present  in all
        material  respects the financial  condition,  results of operations  and
        cash flows of the  registrant  as of, and for, the periods  presented in
        this annual report;

4.      I am responsible for  establishing and maintaining  disclosure  controls
        and  procedures (as defined in Exchange Act Rules 13a-14 and 15d-14) for
        the registrant and have:

        (a)  designed  such  disclosure  controls and  procedures to ensure that
             material  information  relating to the  registrant,  including  its
             consolidated  subsidiaries,  is made  known to us by others  within
             those entities, particularly during the period in which this annual
             report is being prepared;

        (b)  evaluated the effectiveness of the registrant's disclosure controls
             and procedures as of a date within 90 days prior to the filing date
             of this annual report (the "Evaluation Date"); and

        (c)  presented  in  this  annual  report  our   conclusions   about  the
             effectiveness  of the disclosure  controls and procedures  based on
             our evaluation as of the Evaluation Date;

5.      I  have  disclosed,   based  on  our  most  recent  evaluation,  to  the
        registrant's  auditors and the audit committee of registrant's  board of
        directors (or persons performing the equivalent functions):

        (a)  all significant deficiencies in the design or operation of internal
             controls which could adversely affect the  registrant's  ability to
             record,  process,  summarize  and  report  financial  data and have
             identified for the registrant's auditors any material weaknesses in
             internal controls; and

        (b)  any fraud,  whether or not material,  that  involves  management or
             other  employees  who have a significant  role in the  registrant's
             internal controls; and

6.      The registrant's other certifying  officers and I have indicated in this
        annual  report  whether  there  were  significant  changes  in  internal
        controls or in other factors that could  significantly  affect  internal
        controls subsequent to the date of our most recent evaluation, including
        any  corrective  actions  with regard to  significant  deficiencies  and
        material weaknesses.

Date: March 26, 2004         By: /s/ Arnold P. Kling
                                -------------------------------------
                                Arnold P. Kling, President




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