SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN MATEO
DECLARATION OF JANJA LALICH IN OPPOSITION TO MOTION FOR SUMMARY ADJUDICATION
Date: August 16, 1995
Time: 9:00 a.m.
Dept.: Law and Motion
I, Janja Lalich, declare that:
1. I received a Bachelor of Arts in French from the University of Wisconsin, Madison in 1967, and spent
the following year as a Fulbright Scholar doing postgraduate research at the University dAix-en-Provence, France. I am presently a writer, editor, researcher, and cult information specialist.
2. I have been researching and studying the cult phenomenon and thought-reform environments and
systems since 1986. I have written, lectured, and been interviewed in the media. I have given
preventive-education seminars and training seminars to campus, religious, civic, and professional
3. A special area of interest for me is how cults, groups, and individuals exert unique influence and
manipulative control over other individuals--in either a one-on-one or group situation. I have been
researching and writing independently as well as in conjunction with Dr. Margaret Thaler Singer, Emeritus Adjunct Professor of Psychology, University of California, Berkeley, who is the world's leading
expert on cults and thought.reform; and with American Family Foundation "AFF"), a nonprofit research center and educational organization founded in 1979, I am an advisory-board member and research
associate of AFF, as well as associate editor of AFF's Cultic Studies Journal, a scholarly, multidisciplinary publication that seeks to advance the understanding of cultic processes and their relation to
4. I am coauthor with Dr. Margaret Singer of Cults in Our Midst: The Hidden Menace in Our Everyday Lives (Jossey-Bass, 1995), and as well as coauthor with Madeleine Landau Tobias of Captive
Hearts, Captive Minds: Freedom and Recovery from Cults and Abusive Relationships (Hunter House, 1994). I am the author of the chapter, "A Little Carrot and a Lot of Stick," in Recovery from Cults:
Help for Victims of Psychological and Spiritual Abuse (W.W. Norton, 1993).
5. I am the coordinator and facilitator of a San Francisco Bay Area support group for former cult
members that has been
meeting monthly since May 1993. I am also associate editor of AFF News, an international newsletter specifically bringing recovery information and resources to the former cult member population. I have also
been the coordinator and leader of weekend workshops sponsored by AFF for farmer members of cults and other psychologically abusive groups or relationships.
6. As a cult information specialist, I work
with individuals to help them understand and assess experiences that were psychologically abusive and or cultic, and I work with families and friends of people currently involved in thought-reform systems to
assist the families and friends in understanding the dynamics present in such situations and environments. It is in that context that Anne-Marie Bertolucci was originally referred to me.
7. I first
met Ms. Bertolucci on January 31, 1995, and subsequently met with her another six times for one- to two-hour sessions. We also had several phone sessions during that same time period. In those sessions, Ms;
Bertolucci described to me her involvement~f~ with the Kriyananda community.
8. I also listened to audio tapes of Kriyananda (a.k.a. J. Donald Walters) and other leaders lecturing to the members, and
read various documents, pamphlets, books, and handouts published by the Kriyananda group. These include but are not limited to Ananda Church of God-Realization (a descriptive membership pamphlet); Rules of
Conduct for Members (a training pamphlet for new members outlining certain daily rules to live by); Tithing (a pamphlet outlining certain expectations for financial contributions); "Vow of
Discipleship" (a handout of the vow); Kriya Initiation to Ananda (a basic promotional pamphlet describing the organization and its practices, available in Ananda bookstores); "Ananda
Membership" (a handout given to new arrivals at Ananda Village outlining certain expectations); The New Dispensation (a pamphlet authored specifically by Mr. J. Donald Waiters describing what he calls
the "The Path," that is, his basic philosophy and teachings); The Ananda Membership Process (a pamphlet dated April, 1991 describing how to become a member and levels of membership, including
costs); "Purification Service" (a handout describing a ritual); The Art of Supportive Leadership (a 103 page book by Mr. J. Donald Waiters described as a practical handbook for people in positions
responsibility, published by Ananda's publishing house, Crystal Clarity, 1992 printing); and "About Prophecies and What We Need To Do" (a handout from an annual group meeting, dated April 10, 1994,
that outlines Mr. J Donald Waiters's predictions for the future of the world).
10. From my discussions with Ms. Bertolucci and from my study of the written material and audio tapes, I am of the
opinion that what is called the Ananda Church of God-Realization, the Ananda Church; of Self-Realization, and the Ananda Village community in Nevada City as well as its other locations (such as the one in
Palo Alto), as led by Mr. J. Donald Waiters (a.k.a. Swami Kriyananda), uses classic thought-reform techniques to recruit, control, and retain followers and members, and therefore constitutes a thought-reform
environment that uses undue influence and coercive persuasion on its members.
11. The term thought reform was first used by Robert Jay Lifton to describe the behavioral-changes
observed and studied in students at revolutionary universities in Communist China and in prisoners of war during the Korean War. In Chapter 22 of Lifton's seminal work on the subject, Thought Reform and the
Psychology of Totalism (W.W.-Norton,1961), he outlines the psychological techniques used to create a thought-reform system or environment and impose a state of ideological totalism on the subject. Lifton's
psychological themes, eight in number, are now widely used as the criteria for evaluating whether or not a particular group meets the requirements of a thought-reform or totalist, system. The more these
themes are present, the more restrictive the group and the more effective the thought-reform program.
These themes--which are not mysterious or obscure but are composed of ages-old influence and
persuasion techniques--are put together in a systematic way so as to create a setting in which the subject or subjects are led to conform one step at a time without the subjects being aware of how they are
chanoina. In such situations, there is much group pressure to conform, and since new member doesn't know what's expected, he or she tends to look around and model and imitate the other members.
result of the systematic use of thought-reform techniques in a coordinated program is that a person's thoughts and values are changed without her knowledge or informed consent. The goal of these techniques
in cults and other thought-reform systems is to change members' behavior, thinking, and attitudes so that they will be better able to provide services to the cult and its leader in whatever fashion is
desired--be it personal adulation, financial "donations," sexual services, or cheap, if not free, labor. Unlike behavior-change therapy (e.g., someone goes to a therapist to change certain
behaviors or things about himself that he doesn't like) where the client is an informed and consenting participant in the process, in a thought-reform system employed by a cult or abusive group or
relationship, there is a great deal of deception and psychological and social manipulation. This means that the subject is kept unaware of the real objectives and intentions of those who have designed and
employ the processes imposed on such subject; even though when seen in isolation she may appear to consent to certain activities or behaviors. In reality, the subject's assent to proceed in a certain manner
is obtained one step at a time in contrast to such person making an informed, intelligent and voluntary consent to affiliate with the group employing such tactics. Thus, such a situation is one of consent
that is neither informed-nor voluntary. Those at the leadership level know the real purpose of the processes, while those at lower levels, as is said in common parlance, are not playing with a full deck.
They do not have all the information needed to know what is really going on and where it is that they are headed.
12. Examples of Lifton's eight themes are widely manifest within the Ananda community;
These themes are listed below. After describing each theme, I will list some examples of this within the Ananda community. For the sake of brevity, I will not include all the examples that I have identified
in my work with Ms. Bertolucci and my studies of Ananda documents.
a. Milieu control: This is the control of communication and information, which includes the individual's communication with himself
or herself. It serves to bring about what is called "personal closure," meaning the person no longer thinks critically about what is going on or what she is being taught. Techniques, such as
trance-inducing methods, chanting, and affirmations, are used to train the person to shut out any critical or negative thoughts. Milieu control reinforces such censorship by isolating the person from her
points of reference such as her family and friends. Thus, the person has little, if any ability, to "compare notes" with others independent of the group and its leader. Time is no longer spent on
pondering questions, entertaining doubts, or considering reservations. Instead, the individual is manipulated to direct her available energy toward complying with the expectations and behaviors of those in
Any questions or doubts about the legitimacy or sincerity of group or its directives are turned back on the person. Whenever Ms. Bertolucci questioned something, she was
told that she was "out of tune," a negative term meaning that she was failing to act properly with the result that she was undermining her own objectives and development. Other group members would
induce compliance of someone who was 'out of tune" by ostracizing or shunning the insufficiently compliant person until her compliance was obtained. This is an extremely effective method of- behavior
There is little, if any, contact with persons who are former members of the Ananda community. They are considered inferior because they have had an opportunity to partake of the Ananda
community and failed to measure up. Therefore, the group deems any consideration of the opinions of such former members that might conflict with or contradict the group's own views of itself and the world as
The Ananda group uses a variety of mind-altering techniques to induce forms of hypnotic trance, which tends to create a mental state of hypersuggestibilty in people. Some of these techniques
are: chanting (for as much as 15 to 20 minutes prior to a meditation session), repetitive clapping, meditating (for as much as 1 to 1 and a half hours daily to even longer sessions as a person becomes more
involved), sitting quietly before a lighted candle, using affirmations (repetitive phrases used to keep the mind from straying to thoughts contrary to those approved by the group), group singing which tends
to create a sense of group "high," long hours of listening to tapes of music, chanting, lectures or poetry containing J. Donald Waiters' own ideology. These were done both alone and in a group
setting. Ms. Bertolucci was expected to do the above at home, and was instructed to set up a special place in order to do so. She was directed to take on a vegetarian diet. All of this served to control Ms.
Bertolucci's daily environment, which in turn controlled and molded her behavior. Any one of these techniques in isolation is not necessarily harmful, but when used simultaneously in a focused manner for the
purpose of inducing submission to the commands of the leader, they are techniques which suppress self-reliance and independent thought, serving only to foster obedience and conformity.
In the early
stages of visiting the Pale Alto location, Ms. Bertolucci was quickly befriended by Ananda members who called her frequently to volunteer her time furthering Ananda businesses and pursuits in the context of
telling her such activities were in her best interest and would help her develop her character. In consequence, Ms. Bertolucci started to withdraw from her former friends, and spend increasingly large
amounts of time with the Ananda people who became her entire social network. Thus, Ms Bertolucci became increasingly subject to their practices.
Ananda exerts intense peer group pressure. Members are
expected to act a certain way, dress a certain way, do everything a certain way. Although there is a superficial appearance of freedom--that is, members think they are willingly living a certain way--this is
in fact-a -false freedom as all aspects of dailpliving, from housing to eating to raising children is ordered and controlled by the group. In Rules of Conduct for Membership, the chapter titles alone give
evidence of this: Community Life Defined, Home Life, Personal-Habits, Marriage, Children, Work Is Service, Moneys earned and Received, Home Building, Property, Membership Vows, Departure or Dismissal of
Members are but a sampling. People are told to model themselves after members who've been there a long time and to look to the senior' ministers for counseling and guidance.
Members are continually told to "Say Yes to Life" which translates "Say Yes to Kriyananda." Any
opposing viewpoint is negated, disregarded, ridiculed. In Rules of Conduct for Membership, it is
discouraged to read anything that is not "in tune" with their writings approved by the leadership. In
addition to former members, independent sources of information such television and
newspapers were regarded as negative, thus effectively prohibited. Members were to submit to the directives of Mr. J. Donald Waiters; there was no other input from other sources, creating a narrow,
controlled universe in which members were expected to behave only In preset, approved patterns. This leads to loss of independence and self-reliance as no one is allowed to express an opinion other than the
accepted Ananda viewpoint.
When Ms. Bertolucci moved to Ananda Village, her daily life was completely dominated by the group. She was put into a collective housing situation that was rather demeaning
(a rustic cabin with no electricity, mice, outhouses, group showers shared by 20 other women), while older members lived in more elaborate accommodations. This disparity in treatment created in her a feeling
of inferiority, of being an underling. It also contributed to the stripping of her individuality and self-esteem. Ms. Bertolucci was also moved from job to job within the Ananda businesses and was made to be
financially dependent on the group. She was paid low wages and also expected to give 10% back to the group.
b. Mystical manipulation: This is the leader's claim of an exclusive authority (divine, supernatural, or
otherwise), which supports the imposition of an end-justifies-the-means rationale based upon the
leader's assertion that only he or she is directly guided by a higher purpose. The follower must submit to this superior authority and subordinate herself to the group and the leader. Her adulation is aimed
not at abstract principles, -but at the living leader who claims to be the special fount of knowledge (a hallmark of a cult). All intellectual challenge questioning is stopp~d;'f6r rSo one may question
"higher purpose" because to do so is a - manifestation of an impurity whereby Ms. Bertolucci was unable or unwilling to recognize the legitimacy of the cult leader's claims. Self-expression,
self-reliance, and independent action are stripped away.
Mr. J. Donald Waiters, a.k.a. Swami Kriyananda, the living leader, creates a disparity between himself and others by ascribing
to himself the ability to possess and the possession of ultimate knowledge of all things.
Certain leading members of Ananda were granted higher status and deemed to be "senior ministers";
they wore white robes, lectured to and counseled the others. They said they had the answer; always spoke with authority. This established a pyramid, top-down, non democratic structure which delivered
Walters' directives to the rank and file membership.
After she had been inculcated with the notion that one must obey the senior ministers. Senior Minister Levin told Ms. Bertolucci that; he was her
soul mate from a past life, and this was the justification for them being together. He manipulated her feelings, making it appear as though they were destined to be together.
Senior Minister Levin
continuously used the group's internal jargon in his discussions with Ms. Bertolucci in order to manipulate her into submitting to his sexual demands, making it seem as though decisions were being made by
some higher authority.
Various rituals were used to reinforce the system and lend a magical aura to proceedings. During the
Purification ceremony, a leading member would put his finger on the devotee's chest as she kneeled
before him. The leading member would say, "The master says, Open your heart to me, and I will enter
and take charge of your life. "This was a manipulation to induce members to submit to and obey the directives issued by the leaders of the group.
The group inculcates a siege mentality by
drawing a black-and-white dichotomy between itself and the outside world. In an April 1994 document, Mr. J. Donald Waiters made numerous, rather frightening and threatening predictions about the coming
cataclysm. He talked of mass starvation, extremely difficult times, great suffering for the human race, nuclear explosions, mutated human beings for generations to come, and so an. Mr. Walters 1;ISes
indirectly suggestive language such as saying "I don't want to frighten you, but..." This kind of apocalyptic document serves to induce fear in members, increasing their dependence on the group, by
inculcating the notion that their survival is contingent upon staying with the group (for Mr. Walters says, "it's just a cleansing, and what will survive is specifically what we're doing).
Thus, in this regard as well as in ways more personal, to leave the group spells sure disaster for the
c. Demand for purity: This is essentially a black-and-white world view with the leader
as the ultimate moral arbiter. Here is created a world of fear, guilt and shame, where punishment and humiliation are expected.
It also sets up an environment of informants where members spy and report
one another's transgressions to the higher authorities. Since an individual is never good enough, she believes she is inadequate which creates mistrust in herself further opening her up for the imposition of
control from the outside. The powerful level of guilt undermines and ultimately eliminates any individual integrity and moral sense.
Expressions of doubt or confusion are labeled as
"bad," and "selfish" Members are told that they should constantly express "Joy, Joy, Joy." They should be happy and not express any negativity. This creates a state of
mindlessness, which is fostered and praised as indicating an advanced state of mind.
When Ms. Bertolucci was feeling even slightly depressed, she would be told she should stay away from the others so
as not to infect them. She was considered dirty and diseased, as though there was something inherently wrong with her. To rectify this situation, she was told to do more intensive meditating, chanting, and
serving of the group. In essence, Ms. Bertolucci was discouraged from thinking deeply about anything, and from figuring anything out herself. She was told to meditate or do mindless work in order to stop her
mind from thinking because thinking took her away from what the group told her was best for her. This serves to infantilize people, as well as keep them from critically evaluating what is going on around
There were social rewards when Ms. Bertolucci obeyed all the rules. When she -obeyed, Ms. Bertolucci was told that she had "good energy" and was asked to do more, was given better jobs
or certain favorable opportunities, such as a role in. play or to sing in the group's choir. Someone else of higher rank always decided if Ms. Bertolucci's energy was "good" or "bad."
This simplistic, arbitrary typecasting kept Ms. Bertolucci on edge, anxious, and off balance. She realized that her daily, if not lifelong fate, depended on how a higher ranking member viewed her. This type
of manipulation served to control Ms. Bertolucci's behavior, to strip her of her self-confidence, to set up an imbalance of power by keeping the majority of the members, including Ms. Bertolucci, in a state
of self-distrust, powerlessness, and fear that group approval would be withdrawn for behavioral transgressions.
Members, including Ms. Bertolucci, were encouraged, instructed, lectured at to be "willing, joyful,
enthusiastic"--in other words, obedient. These words were used over and over. This encouraged
an overall submission to whatever is going on, no matter how harmful or irrational. This led to a subservient attitude among members in relation to their superiors. For this reason, Mr. Levin was able to
tell Ms. Bertolucci that her job was to raise his energy, meaning that she was to serve him in any way he saw fit, and any negative thinking or expression with respect to his demands would be deemed
unacceptable according to the group's system of behavior.
Because the group held women in disdain as sexual temptresses who caused men to transgress an
emphasis on celibacy, all sexual contact is
regarded as the sole responsibility of women. In contradiction, there is a highly sexualized atmosphere at Ananda in consequence of Waiters' historical sexual exploitation of women followers. Thus, Ms.
Bertolucci was led to think that Senior Mister Levin's seduction of her was her fault. She was told how to behave sexually, how to dress, she was literally told to 'try to look-ugly for a while." As a
result, she stopped wearing makeup; began to dress very plainly and inconspicuously, and was manipulated to feel self-conscious, ill-at-ease, and guilty around other members. She didn't speak out because she
knew she would be blamed as anyone who spoke out was. For this reason, both Mr. Levin and Mr.: J. Donald Waiters were able to further control her and attempt to get her to abide by their wishes.
Cult of confession: This imparting of all information about oneself constitutes an act of surrender, of total exposure. The individual's conscience is now owned by the group. The person no longer has a sense
of balance between worth and humility, and there is a total loss of personal boundaries.
Ms. Bertolucci was told to confide in the person who was above her in rank; as a lower-ranking
member is expected to tell everything to her leadership. This was touted as a counseling relationship, yet during and afterwards it became obvious that these members were not practicing confidentiality in
this relationship as they were passing information told to them in private on to other leading members and to Mr. J. Donald Waiters..
Various women members would "befriend" Ms. Bertolucci
and get personal information from her which was used later to induce her to feel guilty. Details of these discussions would also be used to induce her to do things or accept things. This information was used
to judge, stereotype, control, and make Ms. Bertolucci mistrust herself.
There is gossip among the members, as well as everything gets reported back to Mr. J. Donald Waiters. This information is used
to manipulate and control members.
One higher-ranking member in particular asked Ms. Bertolucci a lot of questions about her then-husband, and about her personal financial matters, which were then
used to manipulate her.
e. "Sacred science": Here, the group's policies are seen as the Ultimate Truth. There are often claims of lineage to other great thinkers or leaders, which tends to
lend an air of respectability to the leader and the group. Again questions and dissent are prohibited. This reinforces- constriction of the individual within the parameters established by-the group's
leadership. It causes personal closure and inhibits individual thought, creative self-expression,. and personal development. A person's experience can be perceived only through the filter of the dogmatic
reasoning processes imposed by the group.
By the fourth class of Disciple Initiation, members are told that there is only One Path, that' they must choose one teacher, make a
commitment to that one teacher, that they must go the full route, that this path (the Kriyananda path) was the accelerated way, that disciples must pledge allegiance to Kriyananda. There is no other way.
Mr. J. Donald Waiters claims to be in the line of great historical leaders.
f. Loading the language: This is the use of jargon internal to -and only understandable to-the group.
Constricting language senses to constrict the person by limiting the scope of her ability to reason.
Therefore, capacities for thinking and feeling are significantly reduced. Imagination is no longer a
part of one's actual life experiences; the mind atrophies from disuse.
Worldly, out of tune, attuned, Divine Ray, The Path, crystal clarity, good energy, bad energy, and
other words and phrases have an in-group meaning which served to isolate and manipulate Ms. Bertolucci. It also stopped her from thinking because everything is given simplistic, black-and-white labels.
In-group language is also used to reframe, or reinterpret, personal experiences to fit in with the group's view and to deny the legitimacy of the individual's own firsthand experience. When Ms.
Bertolucci said that she was feeling spacy from meditating, she was told not to worry - and that this meant she was progressing on the Path, and "that she was more in spirit than physical body."
9. Doctrine over person: This requires denial of self and any perception other than the group's and a
submission to the group's world view. There is no longer such a thing as personal reality. The
past--society's and the individual" is altered to fit the needs of the doctrine. Thus the individuals remolded, the cult persona emerges, and the person's sense of self and integrity is eliminated.
Ms. Bertolucci was told to give up her career, her dancing, her aspirations to obtain a degree in
drama-from San Francisco State University. She was told that this would be her
sacrifice to be on The Path. Getting people to give up their personal interests and goals is a classic technique meant to isolate them, make them lose a sense of self, and get them to be psychologically (and
eventually financially) dependent on the group.
The group taught that to be part of the Divine Ray of Ananda meant to be open, childlike, trusting and obedient. It was said that this was the only way
to be attuned to Kriyananda. This perpetuates a loss of sense of self, of self-confidence, self-esteem.
h. Dispensing of existence: The group or leader is the be-all and end-all, and all nonmembers are
considered "evil"" or nonpeople. This creates an "us-versus-them" mentality and breeds fear in the
individual, who sees that his or her own life depends on the willingness to obey. Here is founded the
merger of the individual with the group and the leader.
Those outside the group, that is, nonmembers, are talked about in a disparaging manner. They were
regarded as "worldly," the group's term for anything that isn't part of them. It holds a
negative connotation, and serves to isolate members from the outside world and anyone who is not a part of the group. It also makes members paranoid, thinking the outside world will hurt them.
her first year of involvement Ms. Bertolucci was encouraged by a woman member to leave her "worldly" husband and she was told to "consider divorcing him." This was at a time when her
husband was noticing some of the behavioral changes in her and trying to bring them to her attention. At another time she was told by a member that "the connection between you and your husband is
Members are taught that "environment is stronger than will," which meant that if they associate with the outside world (the"worldly"), they will become contaminated. But
if they stay with Ananda people, they will be safe and live a better life. Although it is said a person- can do anything, it is taught that it's best to be involved in an Ananda business with other devotees,
and then ultimately to live at Ananda village and give one's entire life, becoming a lifetime member. Again this serves to set up a secluded environment, away from other input or feedback. It's easier to
control people when they are apart from their normal environment, friends, and family. Mr. J. Donald Walters would advise members not to visit their birth families if they were not part of their group.
13. As evidenced by the examples above and countless more, in my opinion, through peer pressure,
manipulations, guilt induction, and other social and psychological influences, Ms. Bertolucci was
forced to suppress her former self, regard any questioning of the group's authority as negative, and take on the behaviors of an obedient group member who was never to question someone of higher rank, and
certainly never to question the top leader, Mr. J. Donald Walters. It is because of this that she was able to fall under the influence of Mr. Levin, who seduced her through lies and manipulations.
declare under Penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed an August 1, 1995 at Alameda, California.