SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN MATEO
ANANDA CHURCH OF SELF REALIZATION, a California not-for-profit corporation; CRYSTAL CLARITY
PUBLISHING, a California corporation; DANNY LEVIN, 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 and CRYSTAL CLARITY PUBLISHING; DOES 1 to 50;
Case No. 390-230 A
DECLARATION OF XXX IN SUPPORT OF CROSS-DEFENDENTS' SPECIAL MOTION TO STRIKE CROSS-COMPLAINT
Deposition and Sworn Testimony:
1. I am not a party to this action, am above the age of eighteen and am a resident of XXX. I could and would testify to the following in open court. I have first hand
knowledge of the following matters and facts.
2. I first met Donald Walters, in198X at a talk he gave at the Unitarian Church in XXX. At the time he called himself Swami Kriyananda, and was referred to as Swami
or Swamiji. I was a student at XXX University and having read the "Autobiography of a Yogi" by Yogananda, I was very keep to meet someone who was billed as the direct disciple of Yogananda.
feelings toward Donald shifted from that of friend, to those of a daughter towards her father. Being 21 years old compared to his 55+ years, I loved him dearly as a father figure. In my journals, I referred to him
as my beloved father. I felt secure and happy in my new found home, working hard, for little wages, living simply ply, thinking high. I asked to join the monastery and was allowed to become a nun, and live in Ayodhya,
the quarters near Swami's house.
8. I saw Swami frequently, our relations were always jovial.
His talks, his emphasis on himself as a clear channel for God and Master (Yogananda), the demeanor of the
community members towards him, slowly turned my mind to thinking that he was a "realized" soul.
12. He offered me a ride from the farm to Ayodhya. I gladly took it, viewing personal time with him as a
positive to the spiritual regeneration of my soul. During the ride, he asked me to come down to his house. I went, he asked me to give him a back rub, in his upper room in the dome part of his house. I did gladly,
although I felt very shy, and uneasy, never having been so physically close to him before. He asked me to straddle his back in order to access his shoulders properly. In a few moments he asked me to take off my clothes,
as they were irritating his skin, while I gave him the backrub. I was extremely surprised, but, he said some things which assure me, making me feel that he was a pure channel of God and that I had no cause for
uneasiness. I took off my clothes, and he then had me resume the back rub.
13. I was feeling very confused, by the actions of my beloved father figure, then he turned over on his back, exposing himself, and
rubbed himself against me until he ejaculated all over himself.
I was numb with a sickening deadness that I cannot explain. He told me to get a napkin to clean off the ejaculate. I said, "No", put my
clothes on and went and stood by the large window, overlooking
15. He got up, fixed himself something to eat, I declined food, then we drove to the new temple at the farm where he gave an hour
long talk on truth, following the path, devotion to the guru, and the importance of loyalty.
16. Finally, with his increasingly public and private attentiveness to me, the verbal encouragement from Kaylani and
others to accept his advances and that I was extremely blessed to be able to provide energy to him, I began to feel that he was a divine lover.
17. After this, there were many more encounters. I once asked him
how his behavior fitted into the universal plan of things, and he said, "It's just energy going from one part of the universe to another". With his instructions, I gradually came to accept his as being the way
of playing with physical energy.
At first, as far as I knew, it was just with me.
18. Later, from statements made from older nuns and community members, I found out that many others had had relationships with
him as well. His close, older disciples - Seva, Kalyani, Asha Paver, Parvati, Ann Mc Farlane, Shivanai seemed to understand what was happening and treated me with great leniency and indulgence.
Kalyani told me to
view him as Krishna, and let him have his way, whatever he wanted. In none of these encounters did I participate as a full sexual partner, the sexual contacts were for his pleasure only, and as soon as he had
ejaculated, I left. He taught me to use my mouth and hands to stimulate him.
22. Later, upon my abrupt departure from Ananda, he began to invite a fellow nun of the same age as myself, to be present in the
encounters, and often the two of us would sexually service him.
23. While I was there, there was no penal-vaginal intercourse. He began to become increasingly enamored of my friend, and I slowly dropped out of
the sexual picture, still taking are of his housekeeping, cooking and laundry.
31. It is my wish that those at Ananda, who go there with open hearts and minds, know the truth about the man they are following, and
not excuse his behavior on any grounds. His behavior and that of his close devotees is not part of any divine scheme, but rather the manipulations of an arrogant mind, that does not respect the sacredness of all life.
At one point, Swami told me that he was greater than Gandhi and Sai Baba, that no one had the spiritual power he had.
34. I am grateful to be beyond Ananda now. The people at Ananda are by and large, very good,
sweet, people. They are being heavily brainwashed into an unhealthy trance. I hope the truth will one day clear them of it.
Under penalty of perjury and persuant to the laws of the state of California, I hereby
declare that the foregoing is true and correct.
Executed February 6, 1995, at the County of XXX, State of XXX.