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.
I could and would testify to the following in open court. I have firsthand knowledge of the following matters and facts.
2. I was a resident member of Ananda form 1972 to 1985. During that time, I heard rumors of sexual affairs between Swami Kriyananda, also known as Donald Walters, and female Ananda members. At that time, I paid little, if any, attention to these rumors.
3. Before her death in 1987, my wife confessed to me prior to our marriage she sexual liaisons with Kriyananda.
4. After this I heard about other women having similar experiences.
5. It was a painful realization because I had genuine affection and love for Ananda members and Kriyananda.
Under penalty of perjury and pursuant to the laws of California, I hereby declare that the foregoing is true and correct.