SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN MATEO Plaintiff, vs. ANANDA CHURCH OF SELF REALIZATION, a California not-for-profit corporation; CRYSTAL CLARITY PUBLISHING, a California corporation; individually and as an employee of CRYSTAL CLARITY PUBLISHING and/or ANANDA CHURCH OF SELF REALIZATION; DONALD J. WALTERS, individually, and an employee of ANANDA CHURCH OF SELF REALIZATION CRYSTAL CLARITY PUBLISHING; DOES 1 to 50; No. 390 230 DECLARATION OF XXX IN SUPPORT OF PLAINTIFF'S OPPOSITION TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT: I XXX, declare: 1. I am not a party to this action, am above the age of eighteen and am a resident of XXX, State. I could and would testify to the following in open court. I have firsthand knowledge of the following matters and facts. 2. In the spring of 1981, I had a beautiful home in paradise and led a well to do lifestyle, I lived on the island of Kauai, Hawaii with my husband (I was 25 years old). We had difficulty in our marriage because my husband resented me practicing yoga and meditation which I had started over a year prior. 3. I was almost finished with the "Autobiography of a Yogi" by Paramhansa Yogananda when I met Swami Kriyananda (hereinafter known as "S.K."), also known as Donald Walters. He was on vacation in Kauai and had stopped into the gift shop where I worked. He had other women with him. We got to talking and I asked him what he did. He said he founded a yoga community called Ananda north of San Francisco. He introduced himself as Swami Kriyananda, a direct disciple of Yogananda, He invited me and my husband to attend a dinner and slide show about Ananda at hid condo. My husband declined but I accepted because I was interested in Yoga Teacher Training Course that S.K. had discussed. 4. Everyone at the slide show presentation was so adoringly reverent toward him, I gathered that he must be pretty important. He was on Kauai approximately 6 weeks. During that time he came to my home and immediately began telling my husband (who was a contract builder and a sous-chef) what kind of projects he could work on for S.K. and that there was a retreat kitchen he could cook at. My husband was very affronted and asked him to leave our home. 5. On another instance he arrived on our doorstep with a toothbrush claiming he was going to spend the night at our home. My husband told him to leave us alone. Later S.K. saw us on the beach and came over to sit 50 ft. from me. S.K. never spoke a word to us, yet he stared at me until my husband said he wanted to get away from him (S.K.). 6. Despite my husband's protests, I went to see S.K. again about the Yoga Teachers' Training Course. We had lunch and subsequently S.K. heard all my lamentations about how my husband didn't like my yoga/meditation and how much I longed to go to school, etc. S.K. proceeded to tell me that he "recognized" me as a someone he'd known in other lifetimes. There was this "kinetic" energy going on between us, and he suspected that we might be "soul-mates". He gave me a lot of praise and made feel special. My curiosity piqued and I wanted to see this community of happy people. I also want to see the yoga training course so that I could I could have my own business. 7. When S.K. and his entourage left Kauai for Ananda- I went with him. We arrived in San Francisco and stayed at Ananda House (S.F). The couple who kept it organized and who performed the church services were named Jyotish and Devi. They seemed very nice. 8. I spent the night in the same bedroom where two other women slept. We were awakened before dawn by female monastics singing at the door, signaling the time for meditation. We later drove to the Ananda Community and I toured the farm, store, print shop, retreat and later the gift/clothing shop in Nevada City. 9. I was told that there was no room at the retreat for me to stay for the Yoga Teachers' Training Course. S.K. offered to let me stay in a room at his home. Since S.K. was considered a monk, this made ripples throughout the community - especially with the other male monastics which S.K. attempted to assuage by explaining at a public meeting (called "satsang") that he and I were friends in many past lives. People said they were confused. 10. Being the new kid on the block I felt thrust into the limelight and getting attention and respect I hadn't earned. S.K. proceeded to tell me that my family didn't really know me and my spirituality therefore they couldn't truly love me. He said my husband was stuck in the delusion of maya and that he could never really love me either. 11. S.K. said he could help me and would initiate me into Kriya Yoga. When I asked him why he wasn't at Self-Realization Fellowship anymore, his answer was that there was a personality clash he he had to leave. At first he felt that it was unfair-but then realized he had to leave in order to start Ananda. (Later he would often denigrate Self-Realization Fellowship ("SRF") which caused me to ask more questions. Indeed I found out he was very hurt and resentful about being asked to step down as Vice President. 12. I was told S.K. need to visit the Ananda Centers in Europe. S.K. asked me if I wanted to go. S.K. usually traveled with a group of members, most often they were core members. I felt very special when he asked me to go I was also very uncomfortable because I felt surely that there was someone else more deserving to go (all expenses paid). 13. We went to New York, England, Holland, Germany, Switzerland, Italy, France and back to the U.S. Members traveling in the group stayed to visit family while we continued on our tour of Europe and Ananda centers. We visited many religious shrines and art treasures. 14. I flew back to L.A. to see my mom instead of proceeding to San Francisco with S.K. While I was there, my husband came to see me. We stayed at the Portofino Inn one night. We hadn't seen each other in a while. 15. I conceived that night. My husband and I lost the house to the recessions. We needed to move out so we flew to Kauai and packed everything. My husband recently finished a University course in Chicago to open his own restaurant store. He planned to store our belonging in Barstow near his Dads and work at the Flagstaff McDonalds as part of his "owners" training. I proceeded to go with him to Flagstaff and to mend our relationship. I was plagued by letters and phone calls from people at Ananda. 16. Finally I realized I was pregnant. My husband told me didn't want a child since our relationship was so rocky. I told him I was keeping the baby no matter what he said. 17. I went back to Ananda believing that it was now my home and that it was where people truly loved me. (Stupid me). I toured other Ananda Centers in Northern California and went to Carmel with S.K. 18. By now S.K, really had his hooks into me. I totally trusted him as a spiritual teacher, minister, leader and friend. I was his close friend and confidant. He asked me to present something for spiritual renewal week at the retreat temple of leaves. People really felt my being there helped. 19. Soon we were off again to Egypt with a group of people for two weeks. I got sick from the food at the end of the trip and was noticeably showing pregnancy at 3 months. 20. I remember him telling me that we would be rooming together to save money. Everyone else on the tour had roommates too. But I wasn't thrilled about it. 21. When we got back from Egypt, people in the community wanted answers as to what S.K. thought we were doing together. Many ruffled feathers had to be smoothed over. S.K. was presenting me as a mother figure to the community. People were continuing to state that they were being helped by my presence there. I felt that I was needed and initially agreed to take that role. 22. In late fall S.K. took me and a group of members to Half Moon Bay. S.K. had written a poem and so had I. My poem was about spiritual friendship, how was about the spiritual path and we recited out poems to each other. Later he claimed that we recited holy vows of marriage. He said this to the community at a community meeting. I was shocked! I never agreed to marry him! I wasn't legally divorced form my husband. There was no wedding, no witnesses, no reception- nothing! This was said without my consent. This man was 30 years older than me. He was old enough to be my grandfather and I did not want him to be a stepfather to my child! He though children were a nuisance anyway. 23. I was asked to speak at that community meeting. I said I agreed to be "mother" to the community. I was terrified of speaking in front of people, and really didn't say much. I was in confusion because I though S. K. and I were spiritual friends that would lead the community side by side as friends. Obviously he took the soulmate things all the way to "marriage". People in the community congratulated us on our "marriage" after satsang was over. 24. When we got back to the house, I was very upset and very angry. I asked him to retract his statement. He said he could not and that I was asking him to humiliate himself. 25. I took off to Ashland, Oregon with my best friend at Ananda to sort things out. I returned to Ananda. S.K. hoped I was feeling my conducive to his plan for me. 26. One night after I had meditated and gone to bed, S.K. came up to my room, switched on the light and sat on the side of my bed. He said he was lonesome and hadn't felt the arms of a women around him in so long. I imagined 30 years of celibacy as a monk. Now that he considering giving up his title of Swami to be a "householder" as he had a desire to be "married" and all. I felt sorry for him. So I held him. (Little did I know that he had been with many women before me while calling himself a Swami monk!) Then he wanted to kiss me. I resisted and kept turning my face away from him. Soon my blankets were thrown aside and my undies pulled off and he's holding me down while having intercourse with me. I totally disgusted and in shock. I felt totally violated and sickened. Here was a man who full trust and admiration as the leader of the community, a minister and a monk - revered by all and looked up to - having sex with me! He was physically a turn off. He was overweight, balding, gray, and 30 year older!Yuck! 27. The next day I sough out by best friend bus she wasn't at the community. I went to speak to Asha Praver instead. After I told her what happened and that I didn't feel good about it, she told me that I was supposed to to take care of his needs. In other word, what Swami wants, he gets. I felt totally invalidated by her response. I felt used, betrayed and set up. 28. I decided to plan how to leave gracefully. I refused to sleep near him or have sex with him after that. He attempted to lure me again though. He asked me to rub his back (I often rubbed his shoulders and feet) then he rolled over with a hard-on and he put my hand on his penis. He tried to put his finger in my vagina. I said no- I can't do this. I got up and left the room. 29. Woman #2 came to me and S.K, was seeking her out for sexual favors and that she was confused and upset about it. I told here that I was leaving Ananda and that she should too. 30. A photographer showed up on the doorstep one morning to take pictures of S.K. and his "wife" for the upcoming book on spiritual marriage, and that Yoga Journal wanted pictures to publish with their article about S.K.'s "marriage". I lost my temper. I knew nothing about my picture being on his book or any article in a magazine. It was late fall and rainy, I called my brother to come and take me home. S.K. and I had a big altercation after I told him I was leaving. 31. S.K. accused me of carrying his child reneging on my spiritual duty to the community, leaving the spiritual path forever, giving up his spiritual mantle and thus spitting in his face, and being totally insane. Part of me was so brainwashed that I believed him. I had to prove him wrong on every count to get over the mind control. 32. I was a "blithering idiot " when I left Ananda. I didn't know who I was anymore. I convalesced at my Mother's and had Thanksgiving at my brothers house. I slowly rebuilt my identity, my ego. I felt betrayed. I was pregnant and frightened and depressed. After Christmas I went to Arizona to be with my husband. I was agoraphobic and had panic attacks. He promised to take care of me and help me recover. My daughter was born in March. 33. I had to provide S.K. with a blood test to prove to him that my child was not his. I began to take the SRF lessons, they nursed me back to mental health. I took Kriya form SRF in June of 1982. What a difference! In the last 10 years I found that all S.K. 's accusations of SRF were totally false. All of S.K.'s accusations of me and others were false. He had sought to publicly discredit and invalidate anyone who disagreed with him. 34.S.K. systematically stripped me of my ego, gave me an alter ego and controlled be by guilt and my desire to do the right thing. 35. For six years a friend of mine stuck by me until I started to reconcile my involvement with S.K. My friend was at Ananda and left just after I did. 36. I believe that Ananda is a cult. It's core members and ministers do much to keep the fraudulent image of S.K. alive. 37. S.K. is a con- man who preys on innocent people urging them to seek God at Ananda. S.K. and Ananda uses true teaching to Yogananda to claim their integrity. There is no integrity- none at Ananda. Their "blissful" community is only a paper thin image. I am a lot wiser now after therapy and life experiences and I am 14 years older on the spiritual path. I have a much deeper understanding of what went on. 38. I have not any time conspired with anyone to file false allegation in any lawsuit against Donald Walters, or the Ananda Church and have never participated in any meeting with anyone toward such end.