I, XXX, declare:
1. I am not a party to this action, am above the age of eighteen and am a resident of the county of XXX. I could and would testify to the following in open court. I have first-hand
knowledge of the following matters and facts. For the purpose of privacy I am using my initials.only. Counsel for counterdefendant knows my true identity and is authorized to disclose it to both the Court and counsel so
that I can be identified and if necessary, deposed.
2. In 1969 I was part of a group that was led by Donald Walters, also-known as Swami Kriyananda. We were on a tour of college campuses.
3. At one point swami and I were alone together and he used me for sex.
4. The next morning when I was looking for my dress, I found it in his bed.
5. We had sex on two other occasions.
6. When I
spoke of this to a friend of mine who was also an Ananda member, she said Swami had done the same thing with her.
7. Later, when I began to tell people what had happened, word got back to Swami. He cornered me by
the washroom and said that he did not like me talking about the sex between us to anybody. He said that it was just between him and me and that ''We were just having fun, anyway,'
8. I left Ananda in 1976.
Under penalty of perjury and pursuant to the laws of the State of California, I hereby declare that the
foregoing is true and correct.
Executed February 7, 1995, at the County XXX, State of California.