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 of eighteen and am a resident of ---, State where I am a
a practicing psychotherapist. I could and would testify to the following in open court. I have firsthand
knowledge of the following mattters and facts.
2. I lived at Ananda from November of 1980 until October 1983.
3. I moved to Ananda when my marriage ended- my divorce was complete several months after I arrived.,.
I went to Ananda feeling the need to heal from the ending of my marriage. The advertisements for Ananda
promised peace, spiritual growth and a strong sense of community.
4. My first encounter with Donald Wallets (he was then called "Swami" or "Swami Kriyananda" by
community members) was at least six months after my arrival- he had been traveling before that. I tearfully
approached him about my divorce- at first he abruptly stated "well it's too late to worry about int now,
isn't it?" Then as he saw my tears he relented a little, but had no time to discuss it as he was on his way to speak to the community.
5. I was very dedicated in my work at Anadna and regarded Swami as spiritual Father and the community
members as my spiritual family. When I noticed things which made me morally uncomfortable- I rationalized that
whatever "Swami" dictated ( and his inner circle carried out) was the will of God because that is what
they inculcated me to believe. Everything said by Swami Wallets and his ministers lead me to believe it.
6. Finally I was invited to a small gathering at "Swami's dome" ( his home) - I was happy to be amongst
those who designated themselves to be "high souls". Swami held my hand and another young nun's
who was also new to the group. After that experience, Swami invited me over more and more frequently.
7. My first time alone with Swami was in San Francisco at the "Ananda House" there-as I was led up the back
stairs to his bedroom by one of the nuns, (I was also a nun at the time- we nuns were considered part of the inner workings
of the community and took vows of celibacy and simplicity-as did Swami. I was given knowing looks and encouraging
comments by some of the inner circle who were in the back kitchen of this mansion. Swami said he wanted
a foot rub and I had been chosen. As the nun left me at the door, I felt excited but humble about being given this great
"opportunity" to serve. Swami disrobed in a large well-lit walk-in closet so quickly that I was shocked that
I could see his disrobing from where he had asked me to wait- he looked over to see if I was watching and I moved out of view so I could not see. He sat briefly in a chair, with only a towel on for his foot rub. After a few moments he
said he wanted a head rub instead as he stated he had a headache and "would I come over to the bed while
he lay down to give him a head massage?" As I began to do so, he pulled me down to him and began kissing
me- I tried to pull away several time and finally succeeded. He acted hurt and surprised and answered to
my explications of dismay that he was only feeling a little blue and wasn't sure why I was uncomfortable.
I left soon after.
8. This type of scene repeated itself a number of times although each time it became more couched in his
terms of being "completely non-sexual" (as he knew that I believed in the monastic vows he had given me and
taken for himself years before). He told me how sad he was about the loss of XXX (which was the name
he directed XXX to be called at Ananda) and that he just "needed the balancing energies of a woman around".
I was flattered, felt like I was given this role to help him through a hard time, and tried to overlook my
confusion about his intentions. Finally one evening he asked me to disrobe and lie naked on top of him-
he wore only underwear. Although confused, I agreed because he assured me it for healing only. He put my hand
nest to his penis at the juncture of his inside thigh and crotch and stated he needed me to send "healing
energy" through my hands to his arthritic hip (on the inside near his penis, he said that was where the pain
was). I quickly became very uncomfortable, put on my clothes and said I must leave- he hugged me good-bye and smiled
when I said that it was "strange to feel sexual energy between two monastics", I was disoriented and confused.
9. After that episode I began avoiding private contact with him. I moved from the living area where the
nun's had their residences, since that was very near his dome and he had made at least two unexpected
visits to my trailer while I lived there. I spent several months praying and agonizing over what this all
meant- loyalty to Swami and the community had been drilled into my head. Seva, on of his oldest and
closest friends (and the head nun) had come over to me expressing outrage and hurt that I had not gone
to visit Swami when he was ill with influenza during that time- others spoke to me also, and slowly I
became more and more aware that the "inner circle" were shunning me ( as I had seen then do to others who
disobeyed Swami). I felt they would only be shocked by my doubts.
10. Finally I decided to go to a psychologist whom I had come to know ( as he had initially come to visit
the spiritual services in the community on Sundays- He had become estranged after a while when he
disagreed with Swami at times). I gingerly revealed the episodes with Swami to him. I asked if he thought
I was misinterpreting Swami's intentions. I thought he would say yes- but he did not. In fact he said
that several other women clients had expressed similar experiences to him. This confirmation of my worst
fears finally convinced me that I must move away from the community.
11. It took me almost another year of working a side job to earn the money to leave ( I had given all my
money to Ananda when I had become a member and earned no or very little salary for the work I did there).
12. I moved to XXX and was able to live with a friend as I began to reestablish a life on the "outside"
I had been very depressed in my last year at Ananda due to the stress of my relationship with Swami
and my confusion about what it meant morally and spiritually. This depression abated somewhat after I
left- but continued in a milder form for some years until I addressed the issues in therapy. But initially
I spent most my time alone, mostly meditating and praying- hoping to find some comfort in that . My
roommate was my main contact with the world and I cleaned houses to earn money- a very non- demeanding
occupation for someone with a B.A. from Purdue.
13. Slowly I began to interact with others but it was two year before I would date men. It was difficult for
me to trust my own judgment in general a bout men's character in particular and I attribute this to the manipulation I had e
experienced with Swami.
14. After a couple of years of psychotherapy I had regained my self-esteem and trust. Under penalty of perjury
and pursuant to the laws of the State of California, I hereby delare that the foregoing is true and correct.