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A. Avalos 656
MR. GLICK: The United States calls Ava Avalos.
AVA AVALOS, Government witness,
duly sworn.
THE CLERK Please state your name for the record
and spell your last name
THE WITNESS Ava Avalos a, A a
BY MR GLICK
Good Ms Avalos Between 1982 and 1985 you
were a member of the Rajneesh commune?
Yes, I was
Before we get lnto your experlences at the commune,
would you please tell the ladles and gentlemen a
about yourself, where you were born and your background?
I was brown and ralsed ln San Dlego lower
class Mexlcan Amerlcan household We were a pretty
famlly We suffered of the same typical
that, you know, parents were both
of abuslve alcoholics and but they loved me and
slster very much and they sent us to Cathollc school for 12
years
And when I was 15 and a half I read a book
A. Avalos 657
called Be Here Now Byron Doss I decided to become a
vegetarian and start yoga. And I had some friends that
were dolng yoga It happened they were dolng lt at a place
called the Utsava Medltatlon Center lh Laguna Beach,
Callfornra I know about Bhagwan or Rajneesh before
I got there And I went and unbeknownst to my parents and
started doing yoga and found out about Bhagwan, began to
read some of books
Now, how old were you when you came ln contact
the of Bhagwan Shree Ra]neesh?
I was 15
And what role, If any, had rellglon played ln your
llfe up to that po1nt?
Well, I had gone to Cathollc school slnce second
grade We went to church every Sunday I was curious
about from the Very So when I
actually I did yoga for about months before I asked who
this man was on the wall There were lots of plctures on
the wall I of had ant; fear
After about months, I flnally ask
And I read a book I felt like Bhagwan was able to answer
questlons about that I had never gotten 1U the
Catholic church It was Very for me
there come a time when you declded to take a
journey to see hlm, to do about your curloslty
Q. I
A. .
. .
A. Avalos 658
Yeah I school and I went to Utsava
Medltatlon Center I received a scholarship to go to
Berkeley I went to Berkeley for a year My best frlend
at the tlme, her name was Ma Prem Sono She had become
sannyasln already Through the mall you had you could
wrlte and ask to be a of Bhagwan, meant you
wore orange clothes and had the Bhagwan plcture around
your neck, or asked to have your name changed She had
done that already and really wanted to go to Indla
After I about a year, almost a year
and a half at Berkeley, I declded to take a year and a half
leave from school and go to Indla and see Bhagwan
How old were you when you declded to leave the Unlted
It was 1979 I was 19
you travel?
Yeah My frlend and I
And what happened when you got to Indla?
Well, I never traveled out of Callfornla before
went to Indla It was a real shock to me If you have
ever been to Indla, lt llke another planet from the
Unlted States
It was very we went to Nepal for
month Nepal lS an beautlful country Then we
rode the traln and went to Indla The ashram was kind States and travel to see the Bhagwan yourselfA. Avalos 659
paradlse, I guess, 1n some way Everyone wore these
long, flowlng orange robes and long halr and medltatlon
that went on all day and people sang and danced It was
llke a paradlse to me I had never seen a group of people
l1v1ng like this before It seemed llke everybody loved
each other And everybody lntentlon was to become, you
know, better people And so lt was a really wonderful
place
And what you do when you got to the ashram ln
Ind1a?
Well, we purchased my and I
sannyasln, to become a They sald that was okay
I went and met Bhagwan personally The
night when we were by was to take so
you would come lH a small group of people would come to
and he would put the (necklace) around your neck and
touch your head and talk to you about your name So he
that That was the tlme I met
And what was the name that Bhagwan Shree Rajneesh gave
you'
He change my name He left lt Ava I was Ma
Ava
What does Ma represent, or If there lS an
equ1valentthe meditation. And I asked right away to become A. Avalos 660
Women were called
maybe that had to
llke that
Now, you remaln lH
tlme for a perlod of t1me?
I stayed at the ashram
What d1d you do durlng
and men were called Swaml,
do mother, or
India at the ashram at that
about three months
that perlod of time from the
end of 1979 through the three months of 1980?
I was really a I I did a number of
therapy groups The ldea I guess, was to your
egowere to transcend the
you know, our And so I did the medltatlon
and
What lt mean to you to become a of
Bhagwan?
I meant that I was taking I was taklng a step to
completely devote my llfe to my awaklng, and that
I was Bhagwan as my master,
therefore saylng that that he knew what I
needed and would help me to achleve
those goals, even though maybe I wasn totally clear
the tlme what those were We would say lt was
And I don we really questlon
what that was It was all of us were do.
A. Avalos 661
What you conslder Bhagwan to be
An master I guess we felt llke he was
Jesus In some way, try to make lt clear he was all knowlng,
had achleved the hlghest human potentlal that a person
could achleve He was clalrvoyant, all
Understood there was to understand about llfe
and belng on the planet, I guess
there come a time when you left the ashram?
I left about three months after I was there was ln
Indra and Nepal about four months
After four months being In the presence of your
master, what d1d lt mean to leave the ashram?
could stay I sold that I could sell to stay
longer and came back when I absolutely have any more
money
What happened then when you returned to the Unlted
States sometlme 1D the of 1980?
Well, at that polnt I was then wearlng red clothes and
the (necklaceback
to school So I declded to return to Berkeley
another semester there at school
Durlng the tlme you were at Berkeley, were there
any outerwear or external manlfestatlons of Bhagwan?
I continued to wear red clothes and my (necklacewas really disappointed. I stayed as long A. Avalos 662
Whlle you attended school'
Yes
there come a time when you else?
Yeah, that next summer As soon as I came back from
Indla, there were a number of medltatlon centers ln
San and the Bay Area And I started to attend
them, Rajneesh Medltatlon Center ln San called
PARR, PAR
And from that I was contacted from a
Rajneesh Medltatlon Center ln Laguna Beach that had just
opened And they heard that I had secretarlal skills
had worked slnce I was about 14 ln dlfferent offlces and
had worked whlle I was ln school And somebody called me
from Laguna Beach and sald, We understand you are a
secretary We have medltatlon center We are looklng
for an offlce manager Would you like to come to Laguna
Beach? And we fly you down and see lf you llke lt
here
I thought, okay, at that polnt my goal was
to try and earn as each money as I could and try and go
back and be Bhagwan
I went to Laguna Beach And as lt turned
out, there was a church pastor that had become a sannyasln
and asked his whole congregatlon to do that It was a
large property There were resldentlal propertles was
A. Avalos 663
beautlful I thought I should take job I moved
Laguna Beach
At Laguna Beach were there other sannyas1ns?
Yes It was called Rajneesh a a
And what you do your personal posltlons and
the Items that you had whlle you were lH
Berkeley when you moved down to Laguna Beach'
Well, I have that much stuff furniture I just turned lt over, all
the ashram
You turned your possesslons over'
How long you remaln ln Laguna Beach?
I was ln Laguna Beach for about a year and a half, I
What type of you do ln Laguna Beach as a
sannyas1n?
In the I was the manager I
pretty much all of the that had to
happen 1D the church, or the center at that polnt And at
a certaln polnt Bhagwan ended up comlng to America And
all of the sannyaslns that were ln Indla descended of
on all of the ashrams ln the United States They were
comlng hack to the Unlted States
There was another big Rajneesh medltatlon
. . What I might have, yesA. Avalos 664
center ln the desert It was called Geetan just east
of here I can remember exactly where lt was Those are
the two, Geetan was one of the Rajneesh meditation
centers ln the United States on the West Coast, because
was pretty blg, to become of these two centers
became of slster centers
A lot of the1r from Indla that
were leavlng came to the centers to start to do medltatlons
and therapy groups there So they suddenly descended upon
all of the people that were all right there
Now, was ln approxlmately the end of August of
1981 when Bhagwan moved to Oregon, 15 that correct'
And others of followers from Indla go with
to Oregon'
Some and some At the very there
were very few sannyaslns to be the Bhagwan
So people that llved for years and years ln Indla weren
belng to go to the ranch They were really
What lt mean to you to be ln the Unlted States and
at the locatlon 1U Laguna Beach, and the Bhaqwan, your
master, up ln Oregon?
Well, we were also that Bhagwan had come to
America of llke beyond our wlldest dreams that
it
A. Yes, that is right.
Q. .
,t
A.
A. Avalos 665
Bhagwan would come to Amerlca And the fact lH a way that
I was at the place at the tlme ln some ways, I
was medltatlng and the people from Indla came and took the
center over And a lot of the people that had been there
before they asked to leave, but they actually me to
stay on So I felt of ln some way to be
there a lot of the that had been
Bhagwan for many years All of us wanted to go be with
at the ranch
there come a tlme when you had the opportunlty to
for the tlme the commune located ln Eastern
Oregon'
the people on the ranch, we had about four dlfferent
celebratlons a year that sannyasrns would celebrate One
of them was the Master Day celebration, that was the
biggest one, ln July And that was the Master Day
celebratlon that was golng to be celebrated lH Oregon, so
they the resldents of the medltatlon centers to go
Would that have been the first World Festlval lH July
of l982?
That lS
What you do after you got to that fest1val at that
Q.
A. Yes. In I guess it was in June of 1982 they had
up.
A. .
A. Avalos 666
We were dlfferent jobs I I worked lH
a tent Rajneesh souvenlrs lH the very
The resldents of went up and everyone that was already
ln the center got a job to do to make the festlval
happen
For how long a perlod of time you then remaln at
the commune ln Oregon"
I really remalned at the commune well, I stayed
there I was asked to come up for two weeks
And then I was told I was gOlHg back down and care take the
center Because all of the resldents from Saba were
to go for the full month I went up for
two weeks Some of them had to go back
That right
What lt mean after you flnally got to the commune
and had to leave'
It was really hard to leave Specially because lt had
been a whlle slnce I had seen Bhagwan Actually whlle I
was on the ranch I had been lHV1tEd a small meetlng
A few people had been for a meetlng
you got near Bhagwan you felt you
felt llke lt was a honor
Spell DarshanDid you leave the commune and return to the SabaA. Avalos 667
And what was the darshan that you had Bhagwan?
Well, lt meant agaln, we got to ln front of
hlm, he touched our head I guess he gave us some sort
blessing and asked us, maybe five or of us lf we had
any affectlon for At time he wasn speaklng
publ1cly, so lt was quite an honor to be there and
have access to and ask him any questlons that we wanted
And what you do when you returned to Saba after
brlef perlod of tlme at the commune ln the
of 19829
Well, at that polnt there was nobody really at the
center, we were just caretaklng You know, taklng care of
ourselves And I think maybe there were three, four of
there at the tlme
For how long a period of tlme that contlnue untll
something else happened"
Well I guess about the tlme when people are supposed
to be comlng back the the person that ran the center,
her name was Asema (ph) from Australla came back and she
had been there for the day In the evenlng we were cooklng
dlnner She looked at me and sald, I forgot to tell you
you are suppose to be on a plane tomorrow to go l1ve at the
ranch." I was ln complete shock. I thought, my God, I
have been to llve at the ranch. The next A. Avalos 668
got on the plane and moved to Oregon
And what you do when you got to Ra]neeshpuram?
Well, there was a woman named Sheela who was had
been lH charge of fund for the ranch She was
sannyasln from Indla When all of the sannyaslns were
relocated she was dolng a lot of fund because Saba
and Geetan, the medltatlon center, have the potentlal to
make a lot of money That was of her domaln
When I got to Rajneeshpuram I went to see
Sheela She told me to go and look for Ma Prem Geeta, she
would tell me what to do
Where you llve when you got to Ra]neesh?
I llved ln a group of trallers called Des1derada
I went to Geeta and she sald I was going to he
assigned a really speclal job And Saba had worked at the
legal team, I thought I was golng to he dolng legal
She sald actually you are golng to be answerlng Bhagwan
letters that have And there are
only a few people that do You feel llke you are
really and you know lS of a
job You have to he speclal to be able to do And
lS the job that we are golng to glve you
What do you mean, you are the one that answers
Bhagwan
A.
. .
A. .
Q. What did do you when you got to the ranch?
A.
Q.
A. Avalos 669
A. Bhagwan received letters from around the world from
his disciples asking for spiritual advice. Instead of
Bhagwan answering the letters personally the typists in the
typing pool would answer them We would read them and
this had been going on for a long time There were books
that had quotes about love or relationships and death or
whatever, any number of subjects So we would read the
person letter and write a few lines of advice and then
pick a Bhagwan quote and then Sheela would sign for
Bhagwan
When you said you would go to a book with quotes,
whose quotes where they?
They were Bhagwan quotes
You would place them in a letter'
Who is Sheela'
Sheela is Bhagwan personal secretary She was
the she ran everything on the ashram in it I mean the
commune
Did there come a time when you first got there when
you had meet Sheela, or was your only association the
signing of those letters'
I think I may have meet Sheela during the first
really briefly the first time I went to the ranch when she
had come into one of the tents where we sold the souvenirs
A. .
Q. .
A. Yes.
Q. .
A. .
A.
A. Avalos 670
She said, 15 Ava, she works ashram That lS
the tlme I had seen Sheela
You mentloned Vldya?
Yes
Who was that?
Vldya was the president of the commune this
corporate structure ln order to the commune was the
for profit corporatlon that employed workers, sannyaslns
and there was the Rajneesh Foundation Internatlonal, the
nonproflt corporatlon Sheela headed, we called
rellglous corporatlon and was second to Bhagwan Vldya was
the presldent of Rajneesh Internatlonal commune, which was
for proflt corporatlon
And you come to know her by the name of V1dya?
Yes
And who was Sav1ta?
Savlta was the person that ran all of the flnanclal
matters
Do you see that woman ln the courtroom day?
She 15 here
MR WEATHERHEAD Stlpulated
(By Mr Glick) there come a tlme when you met
Anand Suour Rajneesh Foundation International, the nonprofit
.
A. Avalos 671
Who was Su?
Su ran at that time ran the heavy equlpment
department on the ranch
Do you see her lH the courtroom'
She 15 here
MS SCISSORS Strpulated Hagan,
Your Honor
THE COURT Okay
(By Mr For how long a perlod of tlme you
work lh the capaclty of answerlnq Bhagwan mall?
For about months I worked there
Durlng that perlod of tlme you have any contacts
Sheela'
Any contacts Sav1ta?
V1dya?
Yes Vldya was Vldya was the was our
supervlsor Geeta was my lmmedlate supervlsor, Vldya that
was her supervlsor I would get to see Vldya, she was the
person I felt was my supervisor
Durlng that same perlod of tlme from
approxlmately November of 82 until months of 1983,
you have any contacts Su'
As lt turned out lH Deslderada didn't, not personallyA. Avalos 672
my friend I had gone to Indra worked ln the
heavy equlpment department and the people I llved w1th
the Deslderada, my roommate, Swaml Prem Vljen, and my next
door nelghborhood, a woman named Sambash (ph) and Radamba
(ph) worked for Sheela And so they always would come home
and talk about storles about Su and the heavy equlpment
department And the time I met Su I was Sono
and Monvera and Su was conducting a meetlng and we met
brlefly
Now, did there come a tlme when you got a new job
the commune
ln l983?
One day we would have
meetlng Every department
boss or the supervlsors of
every week they would have
cal led coordlnators
had a coordlnator was the
that partlcular department And
get togethers at Sheela house
and have coordinators were they would exchange
lnformatlon Sheela would tell them about what we were
to do and what was comlng up And then those
coordlnators would come back to thelr department and tell
them that happened at the coordlnators meetlng
So one day Vldya came and was to the
whole department of the floor there and Sald we just
purchased a dlsco ln Portland and we are looklng for
. . . in
Q. at
A. Yeah.
Q.
A.
A. Avalos 673
Volunteers to go and work ln Portland And the way lt
work out you will go to Portland for two weeks and come
back to the ranch for two weeks
And I thought, boy, lS what I want to
do, you know, 1U a Rajneesh dlsco sounded really
great to me So that evenlng I went to Jesus Grove,
15 where Sheela and Vldya and Savlta llved A lot of the
main ranch coordlnators llved there ln the traller compound
called Jesus Grove So I went there for the tlme and
asked to see Vldya and told her I would really llke to go
to Portland and work lH the dlsco And
What happen'
A couple of days later she came to the pool and
announced to everyone I was golng to be going over to go to
Portland, I was really exclted about
And there come a tlme then when you went to
Portland to work ln lt
Yeah
for the ladles and gentlemen of the jury and
the Court what you d1d?
Well, lH the I was I was supposed to be a
cocktall waltress As lt turned out, for a number of
dlfferent reasons, they needed me to cook ln the
So I started to cook And after a tlme they asked me lf
wanted to be a bartender I started to be a bartender A. Avalos 674
the dlsco
In your capaclty as the bartender, you have any
contact Sheela?
Actually that lS really the tlme I got to meet
Sheela, or really any of the top branch at
that tlme There were a lot of legal were
and they needed to come lnto Portland qulte a
to go to dlfferent legal proceedings And Sheela would
come through the dlsco And one tlme because I was the
bartender she ordered a Margarita I made a Margarlta
She came down and sald that lS the best Margarita I ever
had Whenever I come to Portland you are to make my
come to Portland no matter where I was they would me
and say you have to go make Sheela a Margarlta
there come a tlme durlng perlod when you were
as the bartender at the dlsco where you had
personal contacts Savlta?
What happened, whlle I was I would
sometlmes read role (ph) cards That was I had
done for a whlle, and someone told Sheela I read her role
card One day when she came she sald, Why don you make
a of margarltas and bring your cards and come
and glve me a readlng I I also gave Savlta
readlng I that lS the time I met Savlta
A.
Margarita. It was kind of a joke. So whenever she would
A.
up
. I . a
A. Avalos 675
Q. When did this take place, when you said you would come
up'
Well, the restaurant was two levels, a bar level and
then the restaurant up on top She said come up from the
bar
Who was up there when you got up there?
Probably Ma Patipada, Savlta, Sheela
And yourself'
And myself
And was this to discuss the business of the commune or
the business of the disco?
No, just to have a reading
Just you and the g1rls?
Uh huh
Sav1ta?
That was the first time giving her a reading
For how long a period of time did you continue to work
in the disco before you had another job in relation to
Ra]neeshpuram?
I guess it was about five or six months, about five
months probably
And what was your next assignment? Where you told to
go some where'
Yeah, actually on one of my it never turned out
And was that the first social occasion that you met
A. Avalos 676
that we went two weeks to the ranch and two weeks to
Portland It always turned out we spent a lot more tlme ln
Portland than on the ranch, was actually okay me
because I really enjoyed what I was dolng ln Portland
because of thls, because a lot of the sannyaslns
t, as lt turned out not enough people turned out to
volunteer to go to Portland People were to
Portland, they of resented that, they want
be away from Bhagwan I think because, whoever that I
ended up appearlng llke I was, I was very enthuslastlc
And so one day when I was 1U Portland I got
a message to go and see Ma Samadhl and they told me that I
and also they bought the dlsco and then they
purchased the Martha Hotel, lt was a pretty
hotel At that tlme there were probably about 100 100
sannyaslns 1n Portland a hotel, the dlsco and
restaurant and we also had a bakery So whoever ran the
hotel, whoever was coordlnatlng the hotel of ran the
whole show of all three places So I had a message that I
was golng to be made the hotel manager, really
shocked me
Why did lt shock you'
Well, I was just a bartender at that polnt, you know
At when they asked me I thought they wanted me
. I
to
was going to be made manager of the hotel because they
Q.
A. .
to
A. Avalos 677
cook ln the hotel They told me I was golng to be
ln the hotel I thought they were golng to make me a cook
again It turned out and they actually told me I was
golng to be the manager I had to hear lt a couple
tlmes to reallze that that was the job that I had gotten
promoted to, to run the whole show 1U Portland
And so 1U the summer of 1983 you were the manager of
the hotel'
That
Where did you live'
I llved ln the hotel
That lS right
there come a tlme at the end of July of 1983
something happened at the hotel'
Yeah The hotel was bombed at the end of July
And what, If happened as a result of that
bomb1ng? What you do and what was the effect on
whatever work you were do1ng?
Well, because I was the manager I, you know, took care
of that happened ln the hotel One night I went
to bed and heard a loud exploslon and ran downstairs and
saw a man lying 1U the lobby of half of face,
you know, burned and blown up and half of his hand was
blown off At the tlme I even know who was
. Was that right here in PortlandA. Avalos 678
thought maybe lt was sannyaslns I couldn flgure out
what happened I ran upstalrs and found out the hotel had
been bombed The upstalrs was, you know, of lH a
shambles, so I had to evacuate the hotel
Immedlately, as soon as the came and
flre department came and they reallzed lt was a bomhln
you know, enormous amount of pollce, and, you know, speclal
police that deal came and medla was there and
the hotel was ln a complete uproar And because I was the
manager I had to coordlnate all of the sannyaslns
out Maklng sure was okay
or how people react and to how you handled
that Sltu&tlOH?
Well, I recelved a lot of pralse for the way I handled
myself and handled the sltuatlon that evening from Vldya
and Sheela And I was glven a I recelved a watch
from Bhagwan and a message He told me he was very proud
of me and I had done very well
What lt mean to you to recelve a from
Bhagwan?
to do that had to do
Bhagwan, any messages or you felt really honored
Was that an unusual occurrence for sannyas1ns?
Q,
Q. What, if any, result was there with respect to your
No.
A. Avalos 679
Rather un1que?
It was unlque
then the perlod of tlme after the July 29,
1983 through the next several months, was there a
reactlon on the commune to that and the level of
securlty anywhere'
Absolutely
what happened
After the bombing Sheela tightened securlty,
especially ln Portland Llke we always had a securlty
force on the ranch And we had a pollce force also
fact, my best frlend Sono went to the pollce academy That
was her job We had pollce offlcers and securlty force
After the Sheela doubled the securlty force ln
slze And there was a new level of paranola, helghtened
paranola and fear that, you know, accompanled the hotel
Are you or have you ever heard the term 24
Shortly after the bombing the pollce chlef, her name
was Ma Deva Barkha came to me ln Portland whlle I was on
rotatlon and sald Sheela asked me to glve you a message
She wanted to go ln the room and stuff, kind of top secret
And she sald Sheela had a meetlng on the ranch with 24
people that she feels are the strongest people on the ranch
and are ready to protect Bhagwan with thelr llves lf they
ll?
A. Avalos 680
need
And she showed me the She sald You
have been put on the 11st And I was of shocked
Just because at that polnt everyone on the 11st were the
maln people that were the ranch And so I thought
wow, you know, Sheela must think How old were you when occurred' I mean, summer,
fall of 19839
Sorry'
And was Savlta, the defendant Savlta, on the 11st of
the 24 most lmportant people'
Uh huh
MR WEATHERHEAD Objectlon to the form of the
questlon, Your Honor I don counsel properly
rephrased back to the wltness what her earller testimony
had been She never sald 24 most lmportant people She
sald 24 strong people
THE COURT I am going to allow the question
Go ahead
THE WITNESS Yes
(By Mr What about defendant Su, was she on
that l1stA. Avalos 681
Yes.
Vidya was Vidya on the list?
Yes
Sheela?
Yes
Shantl Bhadra?
Yes
Anug1ten?
Yes
Yourself on the l1st?
Yes
And there were others, lS that correct'
That LS right
What lf any, you receive as a member of
the 24?
Barkha explalned to me we were golng to be tralned to
use a variety of different weapons that we might need to
defend ourselves and to defend Bhagwan, and that lncluded
plstols, Uzls, rifles,
And you recelve that of tra1n1ng?
Yes, I
Now, what hours the 24 work' How that
function as a securlty force and where lt fuHCtlOH?
Well, Barkha explalned we were golng to construct,
which they dld, construct a guard tower behlnd Bhagwan
A. Avalos 682
house And ln the guard tower there were a variety of
different guns and you had to walk up a starrcase to get to
the top and you could overlook Bhagwan house and the
And they made up a schedule where we would
work two hour rotatlons So when for lnstance when the
schedule begln the tlme you would work you would go
from the Then the next
you go from 1 30 to 3 30 The next 2 30 to
4 30 As soon as the whole operation began we our sleep
pattern started to become lnterrupted We would be
up all hours of the night and follow through durlng the
day
Yes
Did u?
Yes
Vldy
Yes
And the others on the 24?
Inltlally everyone on the 24 worked a shift
Now, there ever come a time when you saw Savlta
or flrearms ln relation to the 24 or
any of those other that you had'
I don't remember seelng Savlta traln lH flrearms.
Q. Did Savita work on that scheduleA. Avalos 683
do remember Savlta wearlng a pistol and a flrearm
lf you weren tralned to do that you couldn
What about Su, you see her flrearms or traln
firearms'
Yes
What you see, what you personally observe'
The same Su carrying firearms and
Bhagwan
tra1n1ng?
Yes, I
What about Shantl Bhadra?
Yes
Now, there come a tlme when the 24 got expanded to
personnel'
Yes Later on the 24 became 38
And what were the clrcumstances that led to that 24 to
be expanded to the 38?
Well, I the 24 that had been chosen were the
members that really have the most on the
ranch and worked a lot And they just couldn keep up
thelr normal types of schedules what they were doing
on the ranch and do th1s other, you know, schedule on top
of lt. So more people had to be lncluded so the people
could run the ranchHow about Vidya, did you ever see Vidya get firearms
A. Avalos 684
D1d there come a tlme, then, you also worked durlng
perlod where you were on that schedule, you contlnued
to work at the dlsco 1B the hotel?
Yes, I contlnued to work lH Portland And then
shortly after the when I came back to the ranch I
was to work 1U the personnel department We called
lt It was working directly Vldya
All And what type of work d1d you do
Vldya at the Department?
The was the place where members would
lf they had any problem ln thelr ]ob or lf they wanted
job change or lf they weren happy really
that was golng on ln thelr llfe They would go and see
Vldya or one of her ln the
often people, you know, would ask to have thelr job
changed Vldya would say yes or no It was a pretty
powerful place to be
What was your functlon and your role'
I was just one of Vldya Baslcally
because there were so many sannyaslns on the ranch Vldya
couldn always see everybody She had me and a couple of
other women that would sometimes see people And we would
just wrlte down what their problems where and we would go
back to Vldya and say lS what lS golng on this
person Vldya would tell us to do or that
A. Avalos 685
Occaslonally we would tell people ourselves
there come a time when you told someone yourself
happened?
One tlme I was seelng a that had became
unhappy at the ranch I sald, If you don llke lt here,
you should leave I told Vldya that She was really
unhappy me She told me I was on a power
shouldn be on the anymore I was demoted
back
Vldya was your super1or?
Yes
What you do when you got back to the pool?
I the same Answered Bhagwan letters
agaln I was still on the Portland rotation,
and golng back to Portland I was the
disco manager ln Portland
there come a time 1D 1984 when you got a different
ass1gnment?
When I got back to the ranch I was told I was golng to
start to work at the medlcal center Rajneesh Medical
Corporation It was really just a medlcal center a
woman named Ma Anand Puja
What type of work you do there?
Oh, I was supposed to a woman named
Ma Bohdl, who was Puja That meant
A. Avalos 686
ln whatever happened at the medical center
Was Puja your superior at the medical center'
That lS
How long a perlod of tlme you work at the medlcal
center'
About a year
that contlnue through the World Festlval
the summer of 1984?
Yes
Now, I want to dlrect your attentlon to the perlod of
tlme between July of 1984 and November of 1984 What was
the atmosphere WEATHERHEAD I ll object to the form
Questlon about an atmosphere
MR GLICK I ll lt
THE COURT Sustalned
(By Mr What was personally told to you about
the matters occurr1ng? What you personally
observe'
Well, even before I got to the ranch was
an lssue for all sannyaslns because many sannyaslns were
not Amerlcan And belng an Amerlcan myself, I anyone
that wasn Amerlcan felt llke, you know, we had a role to
play ln that ln some way And from the very beginningimmigration matters?
Q. .
. . I
A. Avalos 687
from when I f1rst got to the ranch there was an ongolng
lnvestlgatlon of I 12 couples that had supposedly
flled false papers They had marriages of
convenlence and they were under lnvestlgatlon
you have a marriage to a non American'
Yes, I I was marrled to Swaml Prem Vljen, a man
named Franc1s
What natlonallty was he"
He was English
You were Amer1can?
I was Amerlcan
How would you your
that I was ln a with for the enter tlme
was at the Saba But the fact of the matter was that
Bhagwan never supported marrlage It was
that, lf we hadn been ln the Unlted States
would never have happened We would just contlnue to have
a We would have not got marrled
Spell the name?
Swami Vljen, 1 3
Now, durlng the period of tlme you know and
observe defendant Savlta and her anyone?
Sorry What tlme'
Durlng perlod of tlme you were at these
was actually in a relationship, actually in loveA. Avalos 688
through 1984, prlor to that, had you had an opportunity to
observe Savlta and her
Yes
And what LS Savlta nat1onal1ty?
Was she marrled to an Amerlcan sannyas1n?
Yes
What was name'
I don know his legal name legal name at the
ranch was Swaml Pragltam, actually A chiropractor at the
medlcal center
you observe the defendant Savlta Prag1tam?
you observe Savlta somebody
else'
Yes
Who was the person you saw her ln a w1th?
Swaml Anuglten
During same perlod of tlme, you have an
opportunlty to observe and see Defendant Su'
Yes
And what was Defendant Su natlonallty'
Was she marrled to an Amerlcan sannyas1nA. Avalos 689
If you know, what was sannyasln name'
Okay I can see face now I totally
blank these names I can remember He was from
Los Angeles
Would the name Anutosh refresh your reco11ect1on?
Yes
During that tlme that you observed her, did you
observe her ln a Anutosh?
D1d you observe her ln a someone
else"
Yes
Swaml Sanlr, a 1
Durlng the same perlod of tlme, you have an
opportunlty to observe Vldya ln her re1atIonsh1p?
Yes
And was she married to an Amer1can?
Yes
What was Vldya
She was from South Afrlca
you observe her lH a that
Amerlcan to whom she was marr1ed?
Do you remember his nameWho was that personNo.
A. Avalos 690
I can remember his name
Would the name Shanti'
Shantl, I that was name
Shanti
a a
During perlod of tlme that you observed Vldya
was she ln a someone else other than
person who whom she was supposedly married?
Yes
And who was that person'
And contlnulng now, or your attentlon to the
November 1984 tlme perlod By this tlme, how many couples
on the commune would you say were ln these type same
type of marrlages between foreign sannyaslns
and Amerlcan sannyas1ns?
Well, lt really hard to say, I don know how many
I could say a percent but I couldn I wouldn have a
clue I not sure how many people
Approxlmately what percent, of your own estimate and
the from the people that you say had these
types of and marr1ages?
85 percent
Now, there come a time when you began to get
Involved lh certaln
A. .
Q.
A.
A. S-h- P-Bodhi, B-o-d-h-A. Avalos 691
Yes
Now, would that tlme frame then be the November tlme
frame through the spring of l985?
Yes
Now, before we address certaln one
that you personally were lnvolved ln,
want to dlrect your attention to the of 1985 and ask
you whether or not there was any structure or hlerarohy
your OplnlOn as you observed lt at the commune"
Absolutely
And what would the structure or the order of hlerarchy
Bhagwan was the head He was up on top,
was dlrectly beneath and beneath Sheela,
Savlta
And between Savlta and V1dya?
Well, I would say, well, lt went Sheela,
Vldya And the three of them together shared
Bhagwan For lnstance,
another country or not able to go
some reason, Savlta would see the
Vldya were both gone, then Savlta
Sheela made a real
and Sheela
Vldya,
Savlta, and
the job of
lf Sheela was away
ln and see Bhagwan for
Bhagwan If Sheela and
went ln
polnt of saylng that the
three of them could never be broken up as a team Sheela
was always afrald Bhagwan was golng to tell Savlta
A. Avalos 692
and not Sheela, or Vldya and not her
So Sheela was always real concerned that they always tell
each other so that Bhaqwan couldn use one of
them against the other She used to say that
Now, lH tlme frame, 1985, there come a
tlme when you began to work
Yeah Later lH the of 1985
And what type of work did you do for Sav1ta?
Savlta ran, again, all of the corporate Savlta ran
all of the corporate structure What I mean by that ls,
all of the flnanclal of all of the dlfferent
corporatlons that exlsted, Savlta had the overall plcture
And for how long a perlod of tlme you work
dlrectly Sav1ta?
Probably three months
Was she your super1or?
Yes
Now, by the of 1985, you have any
conversatlon Sheela any
lnvestlgatlon that was golng on'
Sheela was very concerned about ongoing
Lnvestlgatlon of these 12 couples In add1t1on, there was
a lot of concern about Bhagwan status
Petltlons had been flled for to be allowed to stay those corporations.
.
Q.
A. .
A. Avalos 693
the Unlted States, and there was an ongolng concern about
lnvestlgatlon INS fraud
And there come a tlme lH connectlon that
concern of the INS that you had an occaslon
to observe any of the sesslons that were golng observe sectlons that were taklng
place ln the legal department on the ranch Sheela was
very concerned that members wouldn do well ln thelr
lntervlews because so many people that were
marrled were not really ln the people
they were marrled to
They had to get to know all of the personal
hablts and all of the lnformatlon about the people they
weren havrng a She would have
dlfferent people that are golng to be lntervlewed come lnto
the legal department and be as though they were
golng to be lntervlewed
you observe any of those sess1ons?
Yes, I
And what, lf Vldya say about any INS
LSSUE7
Well, Vldya was
MR WEATHERHEAD I am golng to object to the
hearsay at polnt. We are pretty far afleld
A. .
A.
A. Avalos 694
hearsay
GLICK Dlrectly related to the INS
THE COURT Overruled Go ahead
THE WITNESS I can answer'
THE COURT Yes Go ahead
THE WITNESS I sorry What did Vldya say'
(By Mr About any INS lnvestlgatlon?
Just she was very concerned about lt
And how close were you to Sheela at this polnt by the
spring of 1985?
the sense that there was a small group of women and wel
there were a few men, too, that she had taken lnto her
confldence and we had worked together really closely
And this small group that Sheela had taken lnto her
confldence by tlme, does that lnclude S&Vlt&7
Yes
Does that lnclude Su"
Yes
V1dya?
Yes
Shantl Bhadra?
Yes
Anug1tenwas very close. Well, I was very close to Sheela A. Avalos 695
Yourself?
Yes
Yog1n1?
Yes
MR WEATHERHEAD Your Honor, lS really
leadlng ln a degree I have to object to
THE COURT I ll sustaln the objectlon Let her
name off the names
(By Mr Who were the names of the persons
the small group besldes the ones we already dlscussed,
the exceptlon of the last one where the objectlon was
susta1ned?
Were there others'
Well, yeah, Padma Patlpada
MS SCISSORS I don know Lf she was done
THE COURT Were you
THE WITNESS I a confused about all
the people that I have said so far
THE COURT Okay
(By Mr I will move on to something else
can come back to that
What lt mean to you by the of
1985 to be on the commune with Bhagwan?
In the spring of 1985, meanlng up until, meanlng
K.D., Julian, Shanti BhadraA. Avalos 696
before June, I was as
Bhagwan and the commune' I
anyone I loved ln my llfe
person to me In that way,
most lmportant to me,
And what would lt have
sent off the ranch'
devoted as I had ever been to
have loved Bhagwan more than
He was the most lmportant
the commune, you knowllfe
meant for you to be exlled or
I couldn even have lmaglned anywhere other
than
Bhagwan at that polnt ln tlme
And who had the power to exlle sannyaslns from the
ranch'
Sheela
Anyone else?
Well, often llke well, lf lt had been
me at that particular point lH tlme, I Sheela
would probably have spoken with a member, number of people
that Inner of women and men
MR WEATHERHEAD Objection Move to
speculatlon
MR GLICK 15 based on her own observatlon
and conversations the group she was part of, Your
Honor She can to what she knows based on her own
observation
MR WEATHERHEAD Evldence of hablt, character,
not evldence of facts, that occurred
A. Avalos
697
THE COURT Sustaln the objection
(By Mr I want to dlrect your attentlon,
then, to a moment Ln tlme ln the of 1985
there come a time when you were ln Portland, Oregon
durlng the trlal of between the commune and Helen Byron
Yes
Who else was you ln Oregon at that t1me?
Anuglten and YOglHl
And there come a tlme when the was reached
ln the Byron case?
And were you lH Sheela presence after the Verd1ct?
Yes, I was
Can you for the ladles
Sheela reactlon was to the
Sheela was very upset about the
gone Helen Byron had loaned Sheela
ranch had started She wanted
Sheela clalmed she had glven her the
and gentlemen what
as expressed to you'
way the trlal had
$500,000 when the
the money back
money, lt wasn
loan So Helen Byron sued Sheela and the commune for the
money back and won the case plus damages, I suppose
the case lt was golng to cost the ranch about a
and a half dollars Sheela was really upset
the same tlme there was an electlon trlal, we had
an electlon trlal vlolatlon trlal going on. We also had
.
.
A.
A.
A. YesA. Avalos 698
a dlsfavorable And so Sheela was really feellng
desperate and expressed to me and Yoglnl lH the hotel room
she felt llke we were never gorng to get a falr trlal LH
Oregon and that we would really need to take the law Into
our own hands, and sald If we were golng to survlve, there
was going to have to be almost a war to achleve our goals
ln the community
she sald anything about Savlta or Vldya at that
tlme'
What she sald
WEATHERHEAD Objectlon Calls for hearsay,
Your Honor
GLICK
THE COURT
GLICK
break, Your Honor?
THE COURT
mlnutes
THE CLERK
minutes
(Recess)
THE COURT
State of mlnd, Your Honor
Sustain the
be a good tlme for the
All Well be ln recess for 20
Court lS now ln recess for 20
Previous to the last recess I
sustalned an objection I I was ln error
that and the objectlon 1S overruledTHE COURT: I am going to sustain the objectionA. Avalos 699
You may proceed that questlon
MR GLICK Thank you, Your Honor
(By Mr Glick) Ms Avalos, dlfEURCtlUg your attention
to the matter of the Helen Byron verdict and Sheela
reactlon What, lf Sheela say to you about
Savlta and V1dya?
What she sald was that when we got back to the ranch
we would have to support her oplnlon, support her oplnlons
about needlng to take the law into our own hands, so that
the rest of the people at the ranch would agree
she mentlon Savlta and Vldya spec1f1cally?
No, she
your attentlon then to the tlme,
there come a tlme when you got back to the ranch'
Yes
And you go about your buslness untll
happened?
Yeah It was, I believe, the next day or the
followlng today I was I had a beeper on was beeped
to come to Jesus Grove for a meetlng It was lH the
afternoon sometlme And we all I walked lnto Sheela
bedroom Sheela was saylng to everyone, If you have any
morality, you need to leave lt at the door or don come to
meetlng
And what, lf anything, took place at th1s meet1nqA. Avalos 700
Well, there was a group of us ln a
And Sheela S&ld that expressed agaln the same ldea that
she had expressed back at the hotel, which lS that the tlme
had come for us to take the law lnto our own hands
order for us to survlve ln Oregon, we were golng to have
start to people
Now, who else, lf anyone, spoke at meetlng
Well, Sheela referred to Su and Su took over the
meeting and sald that, I am golng to run the meetlng so
that everyone knows that Sheela us to do
thls, that everyone 15 taklng on thelr own
and no one lS us to do
Can you for the ladles and gentlemen
respect to Sheela, what was here tone, her demeanor as you
observed lt when you were present at
It was completely serlous She meant buslness, lS how
she put lt
And what was defendant Su tone when she made
statements that she made'
She was equally as serlous
And were there other that you attended durlng
lmmedlate perlod of tlme where was d1scussed?
Yes, there were
Was there any dlscusslon durlng the period of tlme at
any of these about who would A. Avalos 701
Yes
Describe to the ladles and gentlemen what was Sald and
who said lt
MR WEATHERHEAD Your Honor, I object to the
question lnsofar as lt doesn attempt to place us ln a
place and time we can deal
THE COURT Let have a framework of tlme when
these meetlng took place
(By Mr your attentlon then to the
Helen Byron approxlmately May 24th, and the return
to the ranch and the lH a day or so Were
there a series of meetings after meetlng durlng
MR WEATHERHEAD Objectlon Leadlng, Your
Honor
THE COURT Could you put a framework on that'
THE WITNESS If the Helen Byron trlal was at the
end of May, lt was dlrectly after that The trial
ended, Sheela came back to the ranch, lt was a day
or two that the series of took place
(By Mr Glick) for us what was sald, who
would do the and
MR WEATHERHEAD I for contlnulng to
interrupt, Your Honor Once again we don have a
framed ln terms of place, tlme, 15 ohvlously
A. .
Q.
Q. .
the period of time May 26 to May 28 of 1985?
. .
A. Avalos
the whole case, Your Honor, as to
MR GLICK Your Honor,
serles of She provlded
THE COURT We will get
get to the toplc Proceed
702
who was where when
she lS a
a tlme
to the people after
THE WITNESS Sorry Repeat the questlon
(By Mr Were there some conversatlons during
the serles of about who would be dolng the
k1ll1ng?
Yes
And tell the ladles and gentlemen who sald what at
these
In one of the serles of
Sheela sald that she wanted to create
and she wanted me, Yoglnl, Su, Shanti
to be these flve people that our maln
that took place
an assasslnatlon team
Bhadra and Anuglten
task would be to
ln assasslnatlon team And that we should
always have she would always make sure that we had an
open plane tlcket ln case we had to flee the country at any
polnt And we would always he provided money and always
have money on hand ln case this needed to happen And we
should hand all of our on the ranch to
someone else because we needed to do full tlme
At the meetlng where the assasslnatlon team was
discussed by Sheela, can you remember any words
A. Avalos 703
she used?
believe she used the expression hit team
1 t9
Yes
You mentioned during this time Sheela also stated that
money would be provided for the assassination team for
expenses
That is right
Was defendant Savita present at that time'
Yes, she was
What, if anything, did Sheela or Savita say about the
money'
Sheela said Savita would provide the money
And what else was discussed in addition to a hit team
in terms of killing How it would be accomplished, for
example?
Well, there were a variety of different options
different possibilities of
Any discussion about f1rearms?
Yes, there were What I was going to say is there
were a number of different options how to hurt people or
how to kill people were discussed, which included
poisoning shooting guns to kill people
And did Savita protestA. Avalos 704
What was sald at these the
flrearms that would be needed to people?
We started about the fact that ln order to
accomplish some of the we would need to
have guns
I am confused You earller defendant Savlta
and Su and yourself on the 24th had flrearms What would
be the need for flrearms other than they ones
that Su and Savlta would have had?
We all understood we would need flrearms that could
never he traced back to the ranch All of the flrearms on
the ranch were registered and bought legally And we
couldn have there ever be a trace between a gun that we
flred ln an assasslnatlon attempt, I suppose, and a ranch
gun
And was there any dlscusslon about where to get or how
to get flrearms that could not be traced to the commune
that you were present at or
Yes
Who made the declslon and what was said, lf you can
tell me'
Well, agaln, the way the dlscusslon took, there were a
group of people that lH the dlscusslon And
we talked about the need to buy guns that were untraceable,
that we would need to have false A. Avalos 705
guns, to bring them back
And was Savlta present durlng these
Yes, she was
Was Su present durlng these
Yes, she was
Vldya present'
Yes
Shantl Bhadra?
Yes
Now, was there any about who would be
killed'
Yes, there was
Yes, lt
What was sald about Charles Turner'
Well, Charles Turner was brought up as an enemy of the
commune Somebody that was of lmportance, one of the maln
enemles of the commune
At that tlme you know who Charles Turner was'
I knew the name and I knew he was lnvolve ln the INS
lnvestlgatlon But I understand I may have heard
he was the Attorney But I understand what lt
meant to be a Attorney at that tlme
Was there any at these serles of
as who to who would be the person to purchase or obtaln the
Did the name Charles Turner get raisedA.
untraceable f1rearms?
Avalos 706
Yeah It was declded that Shantl Bhadra and Rlkta
should go buy flrearms
And were you present
Yes, I was
Who dlscussed at the
Well, Sheela declded
and Shantl Bhadra Agaln
but ultlmately Sheela was
during that
meetlng that partlcular meetlng,
that lt should be done by Rlkta
the were group
the one that declded
Someone may have sald, How about Rlkt&7 You know, there
was a dlalog that happened the group Ultlmately lt
was always Sheela that sald, Yeah, Shantl Bhadra and Rlkta
should go
At the meetlng where the team was selected by
Sheela
Yes
Rlkta was on the team'
Yes
any
anybody, say
No, not
Protest lH any way?
Sorry'
. Protest ln any way'
of the persons, lncludlng yourself or Su or
about that select1onA. Avalos 707
Were there others there who object to
Well, that was a dlfferent meetlng I mean, I feel
llke lt sounded llke all of these happened ln one
meetlng It really happen all ln one meetlng But
the meeting where Su asked us are we lH or out, that
LS when dlfferent people objected to the ldea of
people
And who objected at that meet1ng?
objected Padma objected, Patlpada objected
do lt Bodhi objected, Jayanada objected
Now I want to dlrect your attentlon to the per1od of
tlme after these objectlons were lodged lH early June of
1985 What, lf anything, Sheela do respect to the
protests?
Immedlately that meetlng she asked Bodhi and
Jayanada to step out of the room
she at any tlme thereafter tell the Bhagwan about
anyth1ng?
Yeah Agaln, a few days of that first meetlng
she went Sheela would go and see Bhaqwan every
and every evenlng In the evenlng she would talk
and dlscuss ranch business and ask what he would want
done the commune And I guess because so many She said, can't kill anybody, but I support you A.
Avalos 708
the people that were close to her 1D that group objected to
the ldea of people, she went to and asked
what he thought about the need to people
And what did Bhagwan say'
Well, Sheela came back from the meetlng She had
taken a tape recorder so she could play us the message
She came back to the meeting and sald and began to play
the tape It was a hard to hear what he was
saylng But Param Bohdl, who was one of the people that
of her ln Jesus Grove, assisted her, went and
lt We listened to some of lt and he
some of lt
And the of Bhagwan response, yes, lt
was golng to be necessary
And that actually
And actually Hltler was a
say that because
Hltler had great vlslon
the tapes get to
to people to stay ln Oregon
people wasn such a bad thing
great man although he could not
nobody would understand that
And
be known by any name?
I guess well, slnce has happened we
referred to that as the Hitler tape
Now, at tlme what, 1f other than what
you have already told us about these about
Charles Turner occurred you do lH the early
part of June, lf anythingA. Avalos 709
Well after the lH relation to Charles Turner"
Yes
After the serles of I recelved a message to
come and see Sheela I went to see Sheela She sald, "You
should go and Samadhl and do lt you know, Go and
see Samadhl I want you to work Samadhl Go her
and go to Portland her
I went and I found Samadhl and found out
that Samadhl had been on lnvestlgatxng the location
of Charles Turner home for sometlme
Let me stop you there for a moment How much tlme had
lapsed between the tlme of these serles of that
took place after the Helen Byron trlal and the perlod
of time where Sheela came see S&m&dhl7
Well, a week, two weeks Yeah, 1t's for me ln my
memory lt llke a perlod of tlme I couldn tell you
exactly how many tlmes
It seems elther a week or two weeks at po1nt?
I would so
Let's see lf we some dates as we go through
Now, you you were present at
meeting ln one of the series of where Rlkta and
Shantl Bhadra were assigned to go get flrearms
Rlkta wasn at the meetlng Shantl Bhadra was
A. Avalos 710
Do you know lf they went and that after the
meeting"
Yes
Were they successful?
Yes, they were
How do you know that'
Because they told me And because I was shown the
guns that they went and purchased
And what were the clrcumstances that surrounded the
tlme when they show you, when they tell you* How
lt come about that they told you that they had gotten
the weapons' Was there another meet1ng? What took place'
Shantl Bhadra and Rlkta outslde, you know, just seelng them
ln Jesus Grove or or outside I also spoke
Anuglten about lt He was the one that actually showed me
the guns Because when they brought any guns back, they
had to he you know, they had to be or, you
know, he able to arm correctly them So on one
and Shanti Bhadra were golng out and the guns
actually met them outslde as they were golng over to the
range to shoot the guns I saw them when they came back
Were these the same guns Rlkta and Shantl Bhadra had
rece1vedNo, there wasn't another meeting. I was talking A. Avalos 711
your conversatlons Sheela and Samadhl
What Samadhl tell you about the work she had done on
Charles Turner'
Samadhl showed me, Samadhl told me she had been
trying to locate Charles Turner home and contact Charles
Turner for sometlme And she actually had went to
and had gone to offlce
and get an lntervlew with there and had
unsuccessful What she back from
plcture from his college yearbook a plcture
different clubs and llke that That
there to try
been
there was a
of lH
was the only
And she also sald that she had found out
where he came lH and out of the courthouse here ln
And that we were
her to help her out where
And there come a tlme
Yes, I did
And what happened at that
Samadh1?
The Samadhl
out he llved lH an area called
I was supposed to go
he llved
when you went w1th Samadh1?
tlmE? Where you go
somehow she had flgured
Sherwood, and that we should
go to the llbrary and try and out where the voter
for Sherwood were located
So we went to the library here downtown
. . ..
A. . . .
picture we had of himA. Avalos 712
Samadhl was looklng through the books and found out where
LH Sherwood you could go And we drove there to the voter
lnformatlon don know exactly what
lt was called It was where they have all of the voter
card lnformatlon We went ln and told them that well were
are dolng a survey on Reagan economlc plan
Let me stop you there for a moment You
earller the orange and (necklace) that you were a
sannyasln for the ladles and gentlemen prlor to
going Samadhl were you wearlng these clothes or
dlfferent clothes?
We changed our clothes We changed lnto normal
Why?
Well, because we d1dn want to be recognlzed as
sannyaslns
And what of automoblle you travel lnto either
look at Mr Turner home or get to the post office'
Well, there was a green Maverlck that we used
Now, what happens when you get to the post off1ce?
You were a conversatlon you had about Reagan's
economlc plan
We went 1D and sald we were dolng a survey to see
Reagan out about how people felt about Reagan
economic plan, and they let us ln It was just llke a wall
Q. .
A. .
clothes. We called it "blue clothesA. Avalos 713
of cabinets with these cards in them. And we pretended
like we were looking at all different cards, but of course
the main card we went to get was Charles Turner
We pulled out the card and it had a
had his name, but a box for an address, not an
address So we left there and Samadhi said maybe if
to the post office we can see lf they will tell us
We drove to the post office in that area and
the woman at the post the mail place said, No, we don
give out addresses for post boxes, you know She gave us
a paper, I think, that had different route numbers on it
So we spent the rest of the afternoon trying to find the
location of these post office boxes just driving around
Sherwood
around with Samadhi, did you have any discussion with her
as to what the motive was for killing Charles Turner?
Yes She explained that again, that Charles Turner
was involved, headed the INS immigration investigation
that was taking place against the ranch And the idea was
if we killed him, that the investigation would be
interrupted and that would give us more time
What, if anything, did you say about that?
I listened, I guess I don remember saying anything
other than taking lH the information
Now, during this period of time when you were driving
A. . I
Q. .
A.
A. Avalos 714
Based upon your conversations with Sheela, what was
Sheela vlew of the Grand Jury lnvestlgatlon of the
commune durlng June of 1985? that she sald
MR WEATHERHEAD Objectlon to hearsay, Your
Honor
THE COURT Ask the questlon again, please
(By Mr Gl1ck) In relatlon to the Grand Jury
lnvestlgatlon, what lf Sheela say about lt lH
June of 1985?
THE COURT lt ln Sustaln the objectlon
(By Mr you have any dlscusslon
Sheela ln 1985 the Grand Jury lnvestlgatlon
belng headed up by Charles Turner'
Yes
She express to you and make any statement about her
vlew ln tlme period of the Grand Jury and possible
effects on the ranch'
Yeah All of us were very concerned about the INS
lnvestlgatlon that was taking place because we understood
that a Grand Jury had convened and that lf lf any of the
couples that were belng lnvestlgated were found thelr
marriages were found to be fraudulent, then that would
reflect badly on Bhagwan also and
he could be deported And then that we had
.
Q. .
Needs some kind of tie-inA. Avalos 715
worked for on the ranch would cease to exlst
The ranch couldn have exlsted wlthout
Bhagwan Everyone had thrown all of thelr money and tlme
and energy lnto creatlng commune So we had
at stake
How was rt, glven the that you had, that
you came to ln dlscusslons about
Charles Turner at polnt ln 1985?
Well, I felt later ln to make sense of
everything that happened to me, understood how desperate
was to belong to a group, how desperate I was to have a
famlly, you know, coming from some of the that I
came from And there was more lmportant to me than
my family, than my home, 15 the way I sald lt then,
you know I was to jeopardize my llfe, glve up my
llfe to protect the communlty, to protect Bhagwan
How long a perlod of tlme you drive around
Samadhl searching for Charles Turner house'
Pretty much three, four hours, good part of the day
there come a tlme when you eventually found lt'
Yes
to the ladles and gentlemen the clrcumstances
lmmedlately precedlng lt and then the
house
Well, we flnally came upon a group of mallhoxes
. .
A. Avalos 716
There were, I don know, maybe seven, elght of them ln
row, some old ones and then some of them that were llke
Oregonlan mailboxes on the slde of the road
The about road, however, was that
lt wasn these mallboxes weren attached to any house
They were lH the of street Well, they weren't
really streets, they were dirt roads that one went this way
and one went that way And there were houses all along
those streets
So we got to the mallboxes, found the
mallbox We didn know where the house was And we went
and had lunch And somehow ln I declded
What ended up happenlng was I tried to flgure out way
to go and we came I declded to turn on the road
And when we went down when we turned
on the road and went down a couple of houses we found
Charles Turner home because lt had a 1n the front
yard that sald Turner
And what was you and Samadhl reactlon ln
Mr Turner house'
At the tlme we were exclted of havlng found the house
What, lf you do at that polnt'
Well, we went back to the apartment where we were at
and called the ranch and reported back that we had found
I at
that I could do a road drive to try and find the houseA. Avalos 717
and located his house.
And you sald that you went back to an apartment What
apartment was th1s?
Well, I they were called the St Francls
apartments They were yellow apartments ln Portland
I guess would be consldered of a safe house where we
would go and change our clothes and, you know, we would
from the ranch to the apartment, change our clothes and
then go out, you know, to do whatever lt was we were gOlDg
to be dolng
And can you lH terms of time how long a
perlod of tlme you remaln at the house when you
got there before you went back to the apartment"
We drove around and looked at and then stayed ln
the area probably three hours or so I mean lt took us a
couple of hours to rt We probably stayed there that
tlme two or three hours by the slde of the road just
of dolng and seelng whether the
road was busy or who came around there It was a pretty
lsolated place
lt for the ladles and gentlemen
It really pretty country, rural and of rolling
and real pretty trees And there 15 a maln road
before you turn off to the road to get to Charles
Q. .
A. .
go
A. After we found the house we we stayed in the area.
Q. . . .
A.
A. Avalos 718
Turner house And there lS another road you
down, lt was really country It lS not, lt not clty at
all And lt very lsolated
you remaln ln the same locatlon durlng first
vlewlng of the home that you were at'
We went and parked ln a couple of dlfferent
locations and just sat out there I we put the hood
up once, lf anybody wondered what we were dolng to pretend
we were broken down
And these dlfferent locatlons, you have a of
the home from there?
Sometlmes
spoke to back at the ranch when you reported ln that you
found the house?
I don remember who But lt would have been
MS SCISSORS Objection
(By Mr Just tell us lf you remember
No, I don
there come a tlme you went back to the house with
Samadhl later that
Yes, later that evenlng
Approxlmately what time rn the evenlng was that'
It was around Later ln the evening
And can you tell the ladles and gentlemen what
All right. And do you recall who it was that you
A. Avalos
happened when you went back at m1dn1ght?
719
Well, baslcally the same thing We just went to see
the lay of the land and to see what lt was like there ln
the evenlng, to of get an ldea what was happenlng ln
the meantime
And what you discover was happenlng around Charles
Turner house around on a partlcular June
It was very qulte and very lsolated
What, lf anything, Samadhl say about the location
and Charles Turner'
Well, both of us talked
And what was discussed'
Well, how that could be
about the of
And what plans or operation you dlscuss, lf any
You remember any of the spec1f1cs?
Well, yeah One ldea was that as he was comlng out
along road, elther 1D the what sticks ln
memory, m0ID1ng plan before he got out,
out somebody could pretend they were
because the road was only a one lane road to
maybe you could two cars but lt was real
llke lf he was
broken down
house so
narrow
Somebody could pretend llke thelr car lS broken down and
stop the car would have to stop and then somebody would
shoot
killing Charles Turner there A. Avalos 720
Did there come a time that you then went back to the
apartment the St Francis apartment after this midnight
viewing
Yes
And for how long a period of time did you remain, did
you say?
After the evening?
No, during the evening
Maybe an hour or so I don remember staying a long
time at night We were there for a long while
else come?
Yes Back at the Portland hotel, the real Rajneesh
hotel, Vidya was giving a press conference about some legal
pleading or proceedings that was happening And so we went
to the hotel, also to tell Vidya, hey, we found Charles
Turner house So amazingly enough Vidya asked to go with
us to see his house
Why do you say amazingly enough'
Well, because up to that point Vidya, Sheela or
Rikta
MS SCISSORS Objection, your Honor, question
has been answered
MR GLICK She is 1n the middle of her answer
THE COURT. I don think it has been answeredDirecting your attention to the next day. Did anybody
A. .
Q.
A.
A. Avalos 721
What was the purpose or what was sa1d?
MR GLICK She replled amazingly so I was
her to explaln that
THE COURT What was the reason'
THE WITNESS Well, that up untll that polnt
Sheela, Vldya, Rlkta, the main people, never went out on
any of
(By Mr Glick) So you were that Vldya was
there, lS that correct?
Yeah I was surprised she wanted to come us
contact with her'
At the hotel she had red you know, the
regular sannyasln red clothing
she change'
Yes
And what was Vldya role 1H relatlon to Rajneesh
Legal Services and the INS 1nVest1gat1on?
Well, Vldya ran the legal department on the ranch
And what, lf had Vldya say prlor to
about the INS
Because she ran the legal department she was the one
that was ln charge of making sure that all of the couples
were prepared and anyone that, you know, was going to he
lntervlewed by the INS was prepared She was also
Q. . d'
A. .
Q. What clothing did Vidya have when you came into
A. Avalos 722
in charge of the all of the legal proceedings to try and
get Bhagwan immigration approved in this country She
was in charge of all of the legal things
And did she then go with you on this surveillance of
Charles Turner'
Yes, she did
What happened when you got to Charles Turner house
this time, the second day with Vidya?
Well, the same thing We drove her there and showed
her where it was and drove around and came back
All right And while you were at Charles Turner
house, was there any discussing with Vidya and Samadhi
Yes
what was discussed with Vidya and Samadhi?
Again, all of us discussed the possibility of killing
him
And what, if anything, did Vidya say about killing
Charles Turner'
She listened to what we had to say
And was anyone else with you during this particular
surve1llance?
I think just the three of us at the time
Did there come a time anyone else joined you going on
surveillance'
A. .
A. .
concerning their killing of Charles TurnerA. Avalos 723
Yes, later Yoglnl came
What happened when Yoglnl arrived'
We also took her out to see Charles Turner home
Was this another other than the you
descr1bed?
I belleve so We went out Vrdya a couple of
tlmes and
Vldya was out at Charles Turner a couple of t1mes?
Yes
How long a perlod of tlme you remaln at Charles
Turner house'
drove I was really consclous Vldya was with us Vldya
was the presldent of the commune We feel llke we
could get caught the presldent of the commune roamlng
around Charles Turner house
Was there any separate of the courthouse
where Mr Turner worked?
Yes Before we had gone out to Charles Turner home
Before the time you went out to house'
Yes, I belleve so
to the ladles and gentlemen whatwas actually before we went out and before we went
out to Sherwood Samadhr had been here before and Not very long. Again, we just went out there and
A. Avalos 724
sald she figured out how Charles Turner came lH and out of
this And she wanted to see lf we could see
agaln comlng lH and out of the I know
what he looked llke I only had a picture from
yearbook, many years prevlously
So I sat at the I the bar the
other slde, llke lf this was a one way street, here lt was
the other slde I sat In a parked car for a whlle
people come lH and out of the courthouse not knowlng who I
was
for
the
car
golng to be lOOk1Dq for but knowlng I was gOlHq to look
Charles Turner Then we went to the lot across
parking lot lf that lS where he parked
What you think about any plan to shoot lH the
lot?
I thought lt was a bad ldea
Why'
Because I thought well, lt seemed pretty
to try and shoot across the street from the courthouse
ln a lot where lt would make tons of noise
Samadhl say about what role she wanted to
play In the of Charles Turner'
Samadhl was real enthuslastlc about and wanted to
shoot hlm, actually. And that was, agaln, rather absurd
the street. And she had this idea that he could be shot A. Avalos 725
and farfetched to me Because Samadhl had never been
lncluded ln the 24 people, had never practlced, as far
knew, guns and only had the use of one
She had one and she wanted to Turner'
Yes
And how long you remaln outslde
to see lf Charles Turner would go ln or out'
don really remember It was a whlle
ln a structure for a long perlod of
tlme We sat outslde the courthouse people come
How long you remaln outslde of courthouse
to Charles Turner?
An hour or two, maybe
You sald you had an old yearbook picture you
have at tlm? 1D June of 1985 and up to date plcture of
Charles Turner?
there come a tlme when your lH the
of Charles Turner came to an end and you went
back to the ranch'
Yes
What happened and what were the c1rcumstances?
Well, after Yoglnl came 1D she relleved me
Samadhl and I went back to the ranch. I flew back and out longer than the parking structureA. Avalos 726
ranch on the commune plane Vldya
And you have any other role at the end of June
the beglnn1ng of July lH relatlon to Charles Turner and
hlm'
Only that, that wanted came and asked me
for a camera We had these very small cameras that
we could take plctures of of wlthout them knowln
I guess was the ldea He came and asked me for a camera
because he was golng to be golng to some sort of social
functlon that Charles Turner was and he wanted to
take plcture
Yes, I
Now, your attentlon to the of
September, three weeks later, there come a tlme when
certaln people left the commune"
Yes
Can you the circumstances surrounded
that and what you and what happened?
Well at a certain polnt Sheela started to talk to
that same small group of people and sald that she felt like
she wasn happy on the ranch anymore and she feel
like she would she was ready to go to prlson for
Bhagwan, or work for anymore, you know, glve up her
llfe for anymore She started about all Did you give K.D. that little cameraA. Avalos 727
leaving the country together, fleelng the country
put lt fleeing the county, all leave the country
together and go else 1U Europe
Where you part of that group"
Yes, I was
Sheela leave the commune"
Yes, she
What you do'
on a travelrng When she came back lt was around the
of September, she came hack and told us, I leavlng
tomorrow or, you know, real soon, maybe one or two days
She wrote a letter of reslgnatlon to the Bhagwan She sald
she thought we ought the people that were close to her
had a real hard tlme to decide whether or not we
should go or whether we should go And flnally pretty much
all of us declded, okay, let go And we Sheela left
the before And then the next day we all packed
and got lnto the van and left we were the top
of the ranch, so everyone was ln complete
turmoll and we suddenly declded to get up and go Nobody
really understood what was golng on
What was your emotional state at the tlm?j
A. I was really, really upset I was really confused
. Well, Sheela came she was away on a she was away
. up
A. Avalos 728
because that I had done to that polnt had been
for Bhagwan and the commune Subsequently we were
now and we were golng off and do for ourselves
And lt just lt make sense to me
And prlor through the summer of 1985, what were
your sleeplng hours then, the time'
Sorry'
What were your sleeping hours' What was golng
terms of how you were feellng?
Through the summer of 1985, durlng the tlme you were
and up untll the tlme you left?
Well, we were all you know, we were
llke crazy We were havlng ln the evenlng, we
were dolng schedule at the Bhagwan house
Sometimes we slept maybe, four, flve hours a Four
15 probably closer to what lt was So our schedules were
completely lnsane
What happened then when you left the ranch and came to
Portland'
Well, Sheela had left before us Then there were a
group of us went to a hotel 1D Portland And some people
had passports already updated and some of us have
new, you know, the new passport So half of the people
could leave before the other half And I was really upsetWhat pointA. Avalos 729
And I hadn slept that so when we all
got to the hotel Vldya gave me a sleeping so I could
calm down And when I woke up ln the morning I found out
that they had all talked ln the evenlng about all the plans
that were golng to happen
So when I woke up YOglHl walked lH the room
and sald I just talked to Sheela on the phone,
15 golng to be flne We are golng to go buy a dlsco
Europe And snapped of me at that tlme
I sald, That lS the most Idea I ever heard of
ln my life
What you do?
dlfferently about that I mean, everybody was so upset
really at the tlme that, you know, everybody was really
upset at the tlme So me saying I wasn going to go added
to an already had sltuatlon
So d1d you go back to the commune'
Yeah
How was lt you were able to go back to the commune
after havlng left'
I called I called Geeta agaln at the ranch I said,
I really want to come back I don want to go She
sald, Okay, come back So I dropped off I dropped off
Yoglnl. I drove YOg1nl to the alrport I sald good bye
. said, "I'm not going." And I think people felt
A. Avalos 730
her I drove the van back to the Portland hotel and then
got on the plane and went back to the ranch
What happened when you got back to the ranch?
When I go back to the ranch I found out Bhagwan had
press conference LU the and had made a number of
allegatlons agalnst all of the people that had left
And what you was golng to happen to you
that tlme?
Well, even before I was back to the ranch, when I woke
up that I reallzed that I had done to
that polnt had been completely wrong And I thought, lf
have to spent the rest of my llfe ln prlson because of
that, that lS what I have to do I felt llke I had to make
I had to put straight
Sorry'
I had to set things straight
And part of that process, you come to retaln an
attorney or have Contact the
Yeah
the first Contact the FBI and the
clrcumstances that surrounded that
Well, after Bhagwan Bhagwan started to have these
press conferences and accused us all of doing all of
and everyone started accuslng us of dolng all
of some of were true and some A. Avalos 731
weren true, people were of havlng a hey day And
because of the allegatlons the FBI and the State Department
descended on the ranch of on matters and set up
offlces llke In the middle of the ranch there
You say the State Department, the State Department
Department of State ln Washington'
The State Pollce, sorry And I recelved a message to
go and speak to an FBI agent named, Paul Hudson So I went
ln to see And what I told was that I was really
confused and that I know who to trust anymore And
he llstened to me And I told hlm, I sald, A lot of
people are saylng a lot of that are true and a lot
of people are saylng a lot of that aren true
to me, I here And I left And I ended up talkln
qolng the only person I felt at that polnt I could
really trust was my old frlend, Sono who had gone had gone to Indla when I was
Spell Prem Sono
Prem Sono, So I went and found Sono And
sald
Would you llke a break'
I ll be okay I told her what had happened to
And just a second, she llstened and she went
Q. or
A. .
I .
said, "Okay, we will just I'm here. If you want to talk
me.
A. Avalos 732
MS SCISSORS Objectlon, Your Honor, as to
relevance And also lt clearly golng to be hearsay
It really lrrelevant
THE COURT Her own but not someone
else at stage
(By Mr What were your about what
was happening to you at stage' What you do?
I talked to Sono about what had happened
Wlthout us what Sono sald to you, what you
do'
It really what Sono at that polnt?
What Sono do'
help And so at that polnt agaln, I was really
confused And I was told by someone, and I don remember
who lt was, that I should go ln and tell the FBI
that I knew I went ln and I sat down I know
that Sono had spoken to Paul Hudson She later told me she
had done
So I went to Paul Hudson And I sald,
want to tell you what happened And he sald, I don
think you want to tell me what happened He sald I
don want to talk to you untll you have an attorney You
need an attorney And you need to do whatever you can
to an attorney, that lS what you needSono went to Paul Hudson and told him my friend needs
A. Avalos 733
He make an attempt to lnterrogate you even
though you wanted to talk'
He wouldn
What happened, you get an attorney?
At that polnt there were a lot of other people on the
ranch that felt llke that because the FBI and everybody
where there there were a group of people that went to
Portland to some attorneys to talk to And then that
was when I met Ron Hoevet and Jack Ransom for the first
tlme and we talked And then they recommended that I hlre
Tommy Hawk as my attorney
you do that' you hlre Tommy Hawk as your
attorney"
But the people at the commune put together some sort of
fund to hlre attorneys for people that needed attorneys
that polnt And that lS the ones that pald But I
want to be my attorney
Did Mr Hawk negotiate a plea agreement or lmmunlty
agreement, lf you the United States?
Yes, he
And are you that'
Yes, I am
And what lS your as to what you have
promlsed to do as part of that agreementWell, I didn't hire him. I didn't have any moneyA. Avalos 734
Part of the agreement I promlse to tell
that I knew about everything that had happened as
accurately as I could
And what you understand that the promlse of the
Unlted States was as part of that agreement'
That as long as I lf I lle about or
misrepresent any lnformatlon that I wouldn be prosecuted
for the crimes that I But lf I was found to lle
or tell not tell the truth lh any way I would be
prosecuted completely for my crlmes and for that
I sald that I sald would be used agalnst me
all at once
All Now, you talked a earller, you
sald you a lot of things that you reallzed were at that
polnt really wrong Can you tell the ladles and gentlemen
the that you that at polnt that you knew
were wrong'
Actually I made a 11st Is lt okay for me to take lt
out'
MR WEATHERHEAD Your Honor, I object The
quallty of wltness memory lS cruclal to us
THE WITNESS Well, I just want to forget
any of them
THE COURT Go ahead and do what you can wlthout
the 11st If you need the to refresh your memory
PM
A.
.
7
A. Avalos 735
after that you can use it.
THE WITNESS: Okay. I participated in poisoning
Judge Hull. I participated in the salmonella poisoning
that took place in The Dalles I participated in a series
of
MS SCISSORS Objection, Your Honor Can we
approach the bench, please'
THE COURT Ladies and gentlemen, why don you
step out
(Jury out)
THE COURT Ms Scissors
MS SCISSORS We are conferring among ourselves
Your Honor
It had been my understanding from the
discussion we had the other day regarding immunity
crimes for which an individual witness received immunity
The problem with something like this is that
all of us have very carefully avoided the hit list, which
includes a whole series of people But now suddenly we
have Ms Avalos testifying she got immunity for poisoning
Judge Hull, which is very prejudicial because it creates
the impression that, you know, all kinds of particularized
individuals, public officers in that case were being
poisoned, targeted or whatever
. I
.
that the Government was to elicit those categories of
A. Avalos 736
MR. GLICK: Your Honor, should we excuse the
witness during this?
THE COURT: Yes. I think it would be better if
the was excused
(Wltness excused from the stand
THE COURT Mr
MR GLICK Yes I we are dOlHg exactly
what the Court wants us to do I we have been very
careful to, on dlrect, to stay away from those areas that
the Court has that dellcate balance ln the
404(b) area The wltnesses are under enormous pressure
They are not attorneys
It a legal lssue, but we have
them as far as the dlrect lS concerned to stay
away from certaln areas, and we that Now we are ln
that of the testlmony lS not a chronolog to
make lt seem as lf there 15 a serles of acts everyone the foundatlon
15 the plea agreement and what crlmes she she
recelved lmmunlty on
She lS about what she She
not t&1k1Hg about what any others let alone that
Savlta or Su ln them And she 15 under
from me to just say what you
And that 15 what she lS dolng
.
.
. . .
. .
.
.
.
. is
I
.
. .
.
A. Avalos
So far as
Ms lS confused
Hull was on the
earller tlme It wasn
737
the lS concerned, I
about the whether Judge
That lS a pOlSOnlng at a much
an attempt to Judge Hull as
part of the So she lS factually wrong there
But the lS dolng exactly what we
thought would be the dEURllCate balance that the Court
to stay away from the chronolog and to have the
the that they
lH as part of the plea agreement and what they
recelved lmmunlty on And that 15 what the wltness lS
dOlng and there lS no doubt on cross examlnatlon they
go lHtO all of the bad that Ms Avalos to make
lt seem to the jury she lS not a credlble person or that
she had some sort of bl&S because she heard testlmony
her testlmony lS ln exchange for not belng punlshed for all
of the crlmes that she commlt
So lt relevant
a way we thought the Court wanted us to,
lS a dellcate and balanced way
THE COURT
MS SCISSORS I was the
analogy Both sldes have avolded saylng
actually llsted ten or so people because
that would open the door
We are dolng lt ln
and that measure
by
that Sheela
the vlew had been
. . .
.
A. Avalos
738
Well, by saylng the polsonlng of
Judge Hull lS llke saylng that there were other publlc
that were targeted So lt the analogy, not the
fact Judge Hulls was ever on the That makes
The other that lS as bad or worse
she 15 belng to she lH
lnstead of statlng Wh1Ch 15 mlSlEad1Hg to the jury
lnstead of St&tlHg, I So I would ask on both scores
that the testlmony not he allowed And the lnference was
was that others were lnvolved She 15 here
to say what she and what she got lmmunlty for
THE COURT Well, has always been a
concern to all of us I counsel has followed
to the letter that I set the other day
some prevlous testlmony along the same llne There
that has some reverberatlons that one
after
lS no
can
conslder on the lssue of prejudlce And I am
testlmony from prejudlclal posltlon, but I also feel
that the Government lS to
the jury ln as belng one
affalrs or her And as
although I don llke lt, to blunt
endeavors of the defendants to use
put before
who lS candld about her
the word lS used
what would falrly be the
these same acts to
attack her The Government, I have pIeVlOUSly
. so
is
ll
. my
I
A. Avalos 739
ruled, lS to do that, and I they have been
very CautlOUS ln dOlHg lt ln lnstance It would not
necessarlly he accurate for her to say, I somethln
lf she was merely or was not merely but was one of
several That doesn necessarlly mean that
your ln, but lt may well be the only truthful
answer she can glV8 about that She lS gOlHg to
say, I ln" or lH or dldmeans there may have been
prejudlce to the defendants, but I am carefully,
but I cannot preclude all evldence that the Government 15
to put ln just because lt has some prejudlce,
whether the prejudlce the use that the
Government puts testlmony to, and here I lt does
not, so I am golng to overrule your Oh]eCtl0H
Would be a better tlme to stop for noon
rather than the jury back"
MR GLICK Yes If the Court wlshes to stop, we
as well Maybe we can return a earller
MS SCISSORS I assume there lS a few more
mlnutes of dlrect
MR GLICK I that assumptlon lS
THE COURT Okay That assumptlon 15 lnCOfI6Ct
the jury backothers involved. Now, that has got some questions of
A. Avalos 740
(Jury ln)
THE COURT Be seated One of the jurors has
mentloned that the wltness lS somewhat to hear so
I ask that you advlse her to speak more dlrectly lnto the
mlcrophone I found lt the same when she turns away from
I have difficulty hearlng too
MR GLICK I ll tell her durlng the luncheon
recess
THE COURT Ladles and gentlemen, we are golng to
take our noon recess at tlme The reason we brought
you back lh to tell you you can go agaln, I want to remlnd
you agaln of all of my admonltlons You are back ln
trlal mode agaln where you need to be very careful movlng
lH and out of the and belng around people that
be out on the sidewalk So be cautlous to have a
good lunch and be back We reconvene
counsel Any matters that counsel you need to
up or can we just begin we reconvene at 1 00
Be back a few minutes early and we start at O0
clock
THE CLERK Court now lR recess untll 1 O0
(Luncheon recessTHE
move the mlke
THE
moment on one
THE
THE
brought to my
741
(Jury out)
COURT Mr Ms Avalos, I want you to
up and speak Ilght lnto lt
WITNESS Okay
GLICK Your Honor, may we approach for a
other matter?
COURT All
GLICK Mr Wax brought lt to my attentlon
COURT Be seated, everyone It has been
attentlon that some members of the gallery
are ln close to the jurors a couple
of publlcatlons relate to the commune I need to be
partlcularly to what my jurors are exposed to,
and therefore, I am golng to ask that you leave those
papers out of the courtroom or those out of the courtroom
Now, I should also you that the sale
or out of of pamphlets or
materlal the courthouse lS And
therefore, lf there have been attempts to sell or
dlStIlbUtEUR any of lnformatlon, lt lS a matter
may well be ln vlolatlon of that edlct I have asked a
couple of ltems be brought to me now from where lt lS
posted as you enter the courthouse
Because 742
this case, even if that document does not preclude the sale
or distribution of written materials about Rajneesh, I
prohibit it within the courthouse and it immediate area
of jurisdiction around the courthouse
So I don know if there is any question
that you might have on this, but I don want to have any
misunderstanding Sollcitinq on commercial or political,
vending of all kinds, displaying, advertising, commercial
goes on quite a list here It is not allowed within the
courthouse or its environment So you should be aware of
that and be very careful, as it could bring about a
citation
VOICE Your Honor, may I apologize for my
thoughtlessness And if I leave these in the coat room
outside, may we come back and llsten to the testimony
THE COURT Well, you can come back I would
like you to take them out of the courthouse now
VOICE Out of the courthouse
VOICE Thank you
MR WEATHERHEAD Your Honor, before the jury
comes back, I took advantage of the unexpected break to
hand up a proposed limiting instruction.
THE COURT: Excuse me. Let me take it one step
further. I'm not sure either of you ladies and gentlemen
advertisements, collecting private debts, and so forth. 'It
. . .
743
were around when the admonition was given to the jurors.
They are not only to contact anybody or be subject to any
publicity about this case, but they are not allowed to have
anyone approach them about anything that has any relation
to this case So most of these jurors are all marked with
a jury button, but they may not wear that And.so that
could be a violation of my rules regarding any contact with
jurors You must he very, very careful about this
VOICE It was not my intent to contact any of
the jurors After we sat down here, I thought about the
book and I put my purse on top, but I am sorry
THE COURT Okay Thank you
VOICE Thank you
MR WEATHERHEAD Your Honor, since we have
committed to the Court we had no business and didn at the
jury, I did hand up to Miss Black and I distributed to
the Government and Mr Wax a proposed limiting instruction
regarding plea agreements that Mr Simms prepared for me
and was able to complete over the noon hour, and this seems
like a timely opportunity to propose it to the Court
There was some discussion in camera the
other day about the Court willingness or perhaps even
duty to instruct the jury in connection with the blunting
issue, and our thought was that since Miss Avalos is about
time. Once we got the unanticipated moment away from the
744
to apparently embark on relatlng to her plea
agreement and relatlng to the conduct underlay lt, we
request that be glven lmmedlately after
that testlmony lS recelved Thank you
THE COURT Now, I am golng to ask you keep me
tuned to when you are done with Do you have any
Ob]eCtlOnS to l1m1t1ng?
MR GLICK Very Two
reasons One, this The Clrcult has clearly sald
patent these of should
given once ln a trlal lt shouldn be comblned
when lt comes to type of area ln terms of
the great cautlon If we do lt now and agaln, 1t's
repeating lS a 1U
the Clrcult
Now, the second polnt 1S that as we
dlscussed before, 15 a very fluid SltUatlOH And
now, may be accurate, but to dellver lt for all
tlme, we don know what 13 golng to happen on cross
may be a different Sltu&tlOH I don know lf the Court
wants to be ln a posltlon where lt glven an
and now lt has to craft a new one and take back what lt
sald I think lt needs to be I we need to
lt through and I don't know that lS the tlme to do
. in
. be
accomplice or something else. You should do one
It
745
that Maybe we have a break a later on PILOI
to the next
THE COURT Let me ask you, lf I was to delete
the last sentence and then start out the wlth,
Unless I you further and to the contrary
MR GLICK I the deletion of the last
sentence ln that proposed be all
lt should be done at the concluslon of the wltness
testlmony, not the It drawn for thelr
I
MR WEATHERHEAD My ls, Your
Honor, and that the cases Dawbert recommends that the
lnfar
THE COURT That lS what I the way worded,
lt sounds that way That lS why I was you to clue
me ln when you are done that
MR GLICK It should be subject to cross
they open the door on cross, we are ln a dlfferent
Sltu&tlOD We should walt for the to be done,
cross and redirect
MR WEATHERHEAD Well, at juncture, Your
Honor, their only basis the only lawful haSlS, the
rules and glVeH the Court order upon witness
can be to to those matters, lS ln relatlon
ll ll
I
.
instructions be read after the testimony in question comes
. I
.
746
to impeachment That 15 what this instruction goes
Naturally, Your Honor, we prefer the instruction as it
designed here on the understanding it has been proved,
although I will not say mandated, by the Ninth Circuit
The Ninth Circuit also recognized the giving of the
instruction twice, once following the testimony ln question
and once when the jury is charged at the end of the case
Again, that is a recommendation from the circuit, not a
mandate We feel in this particular case it 1S an
appropriate course of action
THE COURT All right Now, do you want this
with the witness, completely through'
MR WEATHERHEAD My belief is the instruction
ought to be given after she testifies about her prior
crimes In other words, she testified about a conspiracy
That is what we are here about Fine Now she 15 going to
testify, though, about a number of other crimes It seems
to me the law says we are entitled to have the jury
immediately told
THE COURT I not going to do it more than once
until I get to my final instructions on the jury as to the
one final witness If you go back into these same crimes
on cross examination, you don get it again
MR WEATHERHEAD I understand that, Your Honor
to'
.
.
instruction when he is questioning or when you are through
. . I . .
A. Avalos 7
THE COURT You rather have lt at time?
WEATHERHEAD I so
GLICK We object to that and walt for the
concluslon of redlrect
47
THE COURT All You let me know when you
are through and that lS when I am golng to give lt
MR GLICK The concluslon of my dlrect?
THE COURT Well, at the concluslon of type
of testimony You may have other areas
MR. .
.
MR. GLICK: After we do this, I am going to start
Q.
.
showlng her some though
THE COURT Okay
(Jury ln)
(Contlnuatlng)
BY MR GLICK
Good afternoon, Avalos Before the lunch rece
we were the that you had done that you
were not proud of that were part of the plea agreement
Can you explain for the ladles and gentlemen of the jury
the crimes that you personally were lnvolved 1n?
I was lnvolved I 1U of
Devara] numerous times, who was Bhagwan
lh polsonlng attempts on Vlvek, who was
SS
A. Avalos 748
Bhagwan a number of tlmes I ln
polsonlng of Judge Hull I lh salmonella
pOlSOnlnQ of the dams
I ln medical records
ln relatlon to the Share A Home project, and knew about
Haldol belng glven to the people lnvolved there wlthout
thelr knowledge I ln, I guess you would call
lt and of the durlng the
Share A Home project, named Felton Walker
I ln the arson of the Clty
attempted murder, attempt on Savrta llfe I knew about
the attempt on to Devaraj at the celebration
I knew about the electron fraud attempt ln
the Wasco County election I'm not sure what all the
names are I ln the plot to
Charles Turner I ln the plot to Helen
Byron I ln
Any respect to The 0regon1an?
MR WEATHERHEAD Objection Leadrng, Your
Honor
THE COURT Sustained That as far as she can
remember
(By Mr As best you can remember'
A Now, he sald that should I say that'
Planner's Office and Attorney's Office. I participated in
. .
Q. .
A. Avalos 749
THE COURT Yes What you can remember now
THE WITNESS Okay Well, I ln
attempt to break ln and destroy evldence at the Oregonian
I 1U the that occurred on
the ranch That was the majority of them
All You earller you had a
Would lt refresh your recollectlon by that
lf there was else'
I have the 11st
THE COURT Just look at lt to refresh your
memory, not to read lt lnto the record
Lorna Buckles after stealing her wallet ln Portland
represented myself also twlce as people that I wasn t, two
tlmes Once, Donna Larson and another tlme Tlna something
I don remember the last name First name Tlna And I
also ln the of Wasco County
Courthouse w1th the lntentlon of the courthouse
I ln the of a man
named I lt I don remember name
last name was Khomelnl llquor store, and the
lntentlon of possibly his liquor store Also, he
was ln the hospltal, when he was ln the hospltal, with the
of possibly harming there
I also knew about the way that money was
Q. . .
A.
THE WITNESS: Okay. I represented myself A. Avalos 750
brought I suppose lnto the United
States Large cash money was brought ln I that
about lt
MR GLICK Okay, your Honor
THE COURT Ladles and gentlemen, unless I
you further on respect, or contrary to these
the testlmony that you have just heard, that
the wltness entered lnto a plea agreement for crlmes she
has ln the past ln exchange for her testlmony
today plea agreement or the confessed crlmes
contalned thereln or ln this testlmony lS not evldence
against the defendants, and you may conslder lt only ln
Avalos or
All Proceed
MR GLICK May I approach the witness, Your
Honor?
THE COURT Yes
(By Mr I want to show you Government'
3 lnto evldence, and I ask you to take a look
that Do you recognlze that'
Yes
What 15 lt?
Jesus Grove, the compound where Sheela and the ones
that worked with her llved
All
. . A. Avalos 751
MR GLICK If I may, Your Honor
(By Mr Glick) Now I show you 3A ln
evldence Would you take a look at Do you recognize
th1s?
Yes lS the floor plan of the traller complex
It shows Jesus Grove
Is lt the maln house'
Yes
there ever come a tlme when you llved ln the maln
house?
Yes
Could you lf she may, Your Honor, where she
llved? Come up to the dlagram Yes
MR GLICK Your Honor, may the record reflect
she 15 the portion of the dlagram on the top,
bedroom
THE COURT Let put an ln that bedroom
(By Mr Just put your ln the spot
where you llved want to show you, lf I may, Your Honor
3B Take a look at that Do you recognlze that'
It a dlagram of Sheela bedroom
Is this the bedroom where the serles of took
place to kill Charles Turner?
Yes There were also some that took place
(IndicatingA. Avalos 752
On Government
room There lS a large square there
Okay I ll show you what lS marked as Government
5, 5A and 5B
MR WEATHERHEAD Your Honor, I have a relevance
object on those I belleve, from
earlier
MR GLICK Do you want to see them'
THE COURT There lS yes Just go ahead
your questlonlng
MR GLICK Thank you, Your Honor
and see lf you can these
These are the that I out The
one on the here were lt says Tlna Rlvera, that
out, that was out after we burned down Dan
Durow offlce 1n San
MR WAX Your Honor, I we object to the
we there We need of that
(By Mr Just tell us, were you part of the
we
Yes There were two names and so I sald we
MR WEATHERHEAD Your Honor, the record, I
glven the amblgulty on that polnt, should the
(By Mr. Glick) I'd ask you to take a look at this
A. Avalos 753
bottom name was Rlchard Langford
THE COURT Yes
MR GLICK I sorry
THE COURT We clarlfled the other name was
Rlchard Langford
MR GLICK Yes
(By Mr Now, you earller on dlrect
examlnatlon the apartment that you changed, or used for
portlon of the Mr Turner, was the
St Francls apartments, lS that correct'
That lS
I would llke to show the wltness 24A I ask you to
take a look at that Tell us lf you recognlze
Is lt a falr and accurate of the St Francis
apartment as lt was at the tlme you used lt for
of Charles Turner?
Yes
GLICK I offer lt, Your Honor
WEATHERHEAD No objection
THE COURT Recelved
(Government's 24A recelved
(By Mr Now, you on dlrect
examlnatlon that you used a Ford Maverlck
Yes. That was the St. Francis apartmentA. Avalos 754
lH the of Charles Turner'
Yes
You remember the name you used ln the of
that Ford Maver1ck?
I belleve lt was Stella Larson
MR GLICK Your Honor, I would llke to show the
wltness 26A, B, Please take a look at 26A, 26B, 26C
Do you recognlze either your slgnature or any of the
on these documents'
26B I slgned Stella Larson That 15 my All
three of them are a of tltle and
for the tltle for the car
of Charles Turner?
Yes
MR GLICK I offer ln evldence and I
belleve we have a stlpulatlon
MR WEATHERHEAD believe lt lS stlpulated
to foundation, Your Honor don see the relevance, but
I don really care, so I don't object
THE COURT 26A,
MR GLICK Yes, Your Honor
THE COURT Recelved
(Government EXhlb1tS 26A and received
THE COURT. Is there an offer And was this the Ford Maverick used A. Avalos 755
MR GLICK Not at this tlme We have a
stipulation to read for 26A, B, C,
MS HAIMOV It lS hereby stipulated and agreed
by and between the United States of America and the
defendants, Sally Anne Croft, also known as Ma Prem Savlta
and Su Hagan, also known as Ma Anand Su, and
through their counsel these facts are accurate
The Unlted States 26 lS an envelope
United States Exhibit 26A, 26B and 26C
That Unlted States 26A lS a
copy of a of tltle for at 1974 Ford
number 4K9lLl9l547 from the Department of the
State of Washington
That United States 26B 15 certified
copy of a dealer temporary permit application for a 1974
Ford Maverick, license plate number IFC 257, vehlcle
No from the Department of
from the State of Washington
That Unlted States 26C 15
CEURItlfl&d copy of a mlCIOfllm copy of a
tltle for a 1974 Ford Maverick, license No IFC 257,
ID number from the Department of
of the State of Washington
That United States 26A, 26B and 26C
. I
Maverick, license plate IFC 257, vehicle identification
I
a
of
A. Avalos 756
are each records kept and malntalned 1U the course of
regularly conducted buslness at the Department
the State of
That lt LS and was the regular practlce of
the Department of the State to mark
and malntaln these records, and that much of these records
was made at or near the tlme of the event and facts
deplcted by and from lnformatlon by a person
knowledge of these events and facts
And lt lS also hereby stlpulated and agreed
that this stlpulatlon may be recelved lnto evldence and
counsel for any matter the approval of the Court may
lt to the jury durlng the trlal Slgned by each of
the partles and by both defendants Croft and Hagan
MR GLICK May I approach?
THE COURT Yes
(By Mr Glick) Now I want to show you Government
27A, 27B, and 27C, ask you to examlne these and
tell me lf you can them for the record?
These are the employment reports from Servlcemaster
where I worked sald I was Lorna Buckles I filled out
the 4 form and I slgned Lorna Buckles 4 And 27A, 27B
was my time sheet I turned 1U And 27C looks like a
payroll lnput record from Servlcemaster I never saw that
beforeWhere you get
form?
It was from Lorna
have a Soclal Securlty
A wallet that you
Yes
A. Avalos 757
the Soclal Security number to put on
Buckles wallet that happened
card ln lt that I took
stole'
I ll show you Government 28 and tell me lf
you recognlze that?
lS the envelope that went some books that
Were
sent to a box that I In openlng
And when was lt that you went and found this envelope'
It was after I was testlmony to the Government
Were the books send before you reached your agreement
the Government'
Yes, they were
MR REARDON If I may, Your Honor"
THE COURT Yes
(By Mr I want to show you what lS marked as
Government 23C and ask you lf you can take a look at
that' D0 you recognlze that?
Yes
What lS that'
It a false 1dent1f1cat1on of Shant1 Bhadra obtalned
ln New York It looks llke lt 1t's a New York State
card And when we were all preparing A. Avalos 758
leave the ranch Shantl Bhadra gave this to me and told me
to destroy lt In the of I forgot and
stuck lt ln a sweater pocket and then weeks later ybe
month later I put my hand ln my pocket and I found
Who you g1ve lt to?
I gave it to I don remember exactly who I gave lt
Was lH the same
I glve lt to somebody 1D lt Government, the FBI
Bhadra gave lt to you'
Yes
MR GLICK I offer this, 23C
THE COURT 23C lS recelved
(Government 23C recelved
MR GLICK Can I lt to the jury whlle I
hand the wltness the next exh1b1t?
THE COURT Yes
MR GLICK And 24A as well, Your Honor, may I
that to the jury'
THE COURT Yes
MR GLICK May I approach the wltness, Your
Honor
THE COURT Yes
Q. (By Mr I want to show you Government
. this in the same condition as it was when Shanti
A. .
A. Avalos 759
19 for and ask you to look at this
Tell me lf you recognlze th1s?
Well, looks llke a brlefcase that I used to carry
on the ranch
And what type of ltems you keep ln br1efcase?
We kept a number of dlfferent but books about
how to people and different that were needed to
carry out some of the crlmes that I
And you personally have possesslon of
brlefcase'
Yeah, lt was assigned to me
I would llke to show you Government l9A,
l9B, 19C and 19D Tell me lf you can those ltems?
Yes These were books How to 1 through
1 through 6 but
When you see these books on the commune?
These books were purchased by Jullan and they were
the Inner of people that agreed
to as the team Sheela ask that
we read them and get to know what was of them
you read those books?
I never ready them cover to cover I looked through
them
Now, Government 19E and 19E 1 and 2,
15 the book called Wlthout a Trace And lt about how A. Avalos 760
commlt crlmes wlthout belng caught, how to commlt crlmes
wlthout leavlng a trace you read this book'
I have read this book more completely than I How
to books I don I read lt cover to cover, but
of lt And these two markers, book markers are
one has l9E 1 has call numbers on lt In my and
I belleve I was sent to out about polsonous
plants at one polnt lH the llbrary That 15 what these
call numbers are for I was looklng up plants were
polsonous and could not be traced And l9E 2 1S has
schedule tlmes and I not sure what they mean, my
on the bottom
Is that your that appears on that?
MR GLICK Your Honor, I offer Into evldence
9A, C, an
MR WEATHERHEAD Your Honor, I belleve the
Court uled on that
THE COURT Those be
(Government 19, 19A, l9B, 19C, 19D,
19E 1, l9E 2 recelved
GLICK I would llke to the How
books to the jury, Your Honor
THE COURT Proceed Mr are you going to
A.
Q. .
A. YesA. Avalos 761
MR GLICK I wasn golng to do lt at this tlme
THE COURT We got to show the jury
spend less tlme lf we get all of them at once
MR GLICK (Pause ln the jury
MR GLICK The partles reached a stlpulatlon how
came ln possession of 19E 1 and 2
THE COURT All Ilqht
Government 19, serles just to the jury,
as well as 20, 20A and 20B the Court
we purpose to read the stlpulatlon respect
to the 19 serles of
THE COURT Right
MS HAIMOV Is lt hereby stlpulated and agreed
between and by the Unlted States of Amerlca and defendant
Sally Anne Croft, also known as Ma Prem Savlta and Susan
also known as Ma Anand Su, the followlng
statements are factually accurate
On or bought September 22, 1985 at
Rajneeshpuram, dlStIlCt of Oregon, Special Agent James
Russell obtalned one brown Samsonlte sultcase, Unlted
States No 19, from Ma Deva Barkha, Chlef of the
Rajneeshpuram Peace Force
.
we
MS. HAIMOV: Your Honor, stipulation regarding
A. Avalos 762
The brown Samsonite sultcase, No 19,
contalned the followlng ltems Four books How to
Kill, Volume 1, Unlted States 19A, Volume 2, United
States No 19B, Volume 3, Unlted States No
l9C, Volume 6, Unlted States No 19D, and a book
Without a Trace, Unlted States No 19E
That contalned the book entitled
Wlthout a Trace, United States No 19E, was one
one orange plece of paper, Unlted States No 19E 2
That on or about November 22, 1985, Speclal
Agent Russell the brown Samsonlte sultcase,
Unlted States No 19, and each of the ltems
contalned thereln ln Unlted States No 19A, 19B,
19C, 19E, and 19ESpeclal Agent
Buckmelster ln whose custody and control they
remained untll October lst, 1985, when they were submitted
to the custody and control of the Portland fleld offlce of
the FBI And Unlted States 19, 19A, 19B, 19C, 19D
l9Esubstantially the same
today as they were on September 22, 1985, when
Speclal Agent Russell obtalned them from Ma Deva Barker as
above
Speclal Agent Russell has no lnformatlon
that Sally Anne Croft or Susan Hagan possessed, had, saw or
yellow piece of paper, United States Exhibit No. l9E-1, and
. I
A. Avalos 763
knew about Unlted States Nos 19, l9A, 19B, 19C
l9D, l9E, l9E 1 or l9E 2 The FBI not test Unlted
States Nos 19A, l9B, 19C, 19D l9Ealso hereby stlpulated and agreed the
stlpulatlon may be recelved lnto evldence and that counsel
for any party the approval of the Court may publish lt
to the jury durlng the trlal stlpulatlon lS Slgned
by both parties, defendants Croft and Hagan
MR GLICK I would like to show the witness
Government 14
(By Mr Take a look at Government
Tell me lf you recognlze what lt appears to be'
The courthouse the map
Is that the courthouse that you conducted the
to determlne whether Charles Turner would
ln or out of lt'
Yes
Can you please mark on the the Court
the locatlons and your
the places that you were when you conducted the
of Charles Turner
MR WEATHERHEAD Your Honor, I object to the
of the on Rule 615 grounds, havlng to do
the lndependent recollectlon of each wltness, unless
A. Avalos 764
the Court has a fresh exhibit for each subsequent witness
THE COURT Let do it right now with some
yellow stickers, and then we can adjust those But we need
to have some way to show where she is marking it in the
record
MR GLICK Put your initials, a on the
number that would correspond to how many places you were
I can use the easel, Your Honor
THE WITNESS (Complies) I was asking if he
wanted me to put where we did surveillance or where we
went
(By Mr Glick) Where you did surveillance
MR GLICK Your Honor, may the record reflect
the witness placed her initials on a sticky looks like
if I got my directions right east of the courthouse
between southwest Madison, Southwest Main, and Southwest
Sixth Avenue, is that correct?
THE WITNESS Yes
MR GLICK She has placed a sticky on the north
side of the courthouse, Southwest Main between Southwest
Sixth and Broadway, is that correct'
THE WITNESS Yes That would be in the parking
structure
(By Mr Glick) So this second sticky represents
Q. . .
A. (Indicating)
Q. .
A. Avalos 765
the structure'
Yes
Would you put a No 2 on this?
(Indlcatlng)
And No 1 on the one
Were there other locations that you went to
around the courthouse ln connectlon
that are depleted on Government 14?
We went around the block, traveled around the block
All right Thank you
MR GLICK Your Honor, lt has been to
me we can get numerous coples of these
ahead and mark lt
MR GLICK So we
THE COURT If you step over there, ln place
of those yellow make your own mark
THE WITNESS (Complles) I changed that
(By Mr No 1, lS now place where you
the surve1llance?
The garage
And No 2 lS exit to the courthouse, slde?
The slde on Sixth Avenue
All
MR GLICK If I may, Your Honor, I would llke
THE COURT: All right. If you can get copiesA. Avalos 766
approach the wltness
THE COURT Ye
(By Mr You that you were present
on ln the area Charles Turner
house
That lS
I would llke you to look at these serles of
And there are letters on the back ln the 16 serles
If you would of these
depict the area that you recall that you conducted
on respect to Mr Turner home
If I recognize else, just only the ones
about Charles Turner s?
home
16N looks llke the surrounding Charles Turner
home lH Sherwood As well plcture from the whlte Toyota that we were
when we went to Charles Turner home Vldya was
lS a shot, I belleve, of one of the roads leadlng
to the house
lS the Toyota or day you use
the MaVer1ck?
We used the Toyota the day or they second day
l6R 15 the road that you go down before you
A. . I
Q.
A.
Q. Just with respect to the surveillance of Mr. TurnerA. Avalos 767
turn lS where Charles Turner home lS
LS also a dlfferent perspectlve of the same road, 16F
16T seems llke also a dlfferent angle from
the road We used the Maverlck the day
16U looks llke part of the road, mallboxes
16W looks llke one of the houses that were
along the road to Charles Turner home
16X looks 11ke a side vlew of one of the
homes It could actually be Charles Turner home, I not
certaln, but lt was one of the houses elther
the house or directly next door
lS a clear picture of that, 16Z, elther
house or nelghbor house
That lS all of them
Now, you that on the day that you the
Vldya was you on one of the
Yes
ln June
MR GLICK At tlme I would llke to play for
the wltness Government No 30, a 10 or 15 second
videotape, and ask her a questlon respect to Vldya and
the stlpulatlon from the parties that occurred
June 21, 1985
MR WEATHERHEAD Objectlon at tlme, Your
Honor No foundatlon the wltness has seen the A. Avalos 768
to say about lt
THE COURT Quallfy
MR GLICK I don
the vldeo I am golng to ask
she was ln the Vld6O when she
know lf the has seen
lf Vldya was dressed the way
went on the
The vldeotape was the press conference that took place
June 21, 1985
MS SCISSORS Your Honor, there lS absolutely no
dlspute as to that lssue There has been testlmony she
changed from red 15 lH the vldeo The
vldeo adds to that presentatlon
MR GLICK all due respect the tape
lt would be very clear respect to the wltness
THE COURT Okay I am qOlHg to ask the jurors
to step out for a mlnute
(Jury out)
MR GLICK Your Honor, the Government
posltlon, lS not unduly cumulatlve If to
wltness would 15 not the way
Vldya was lH when they went on the
And the PIQVLOUS testlmony was from
Mr Knapp presence at the conference and A. Avalos 769
it does add to the testimony, lt adds to the story of what
happened
Vldya 1S one of the defendants and
went on the surveillance, and this witness has already
to Vldya changing her clothes and present at the
press conference and how she was that Vldya,
personally so up ln the hierarchy would go on the
surveillance
Here you have Vldya making statement
and then testifying And lS to add to wltness
testlmony and the date ln tlm? I ll be asking her a
June 21, what lS the day you got there, what lS the day you
went on with Vldya
THE COURT I don know why you can do that
wlthout showing the vldeo agaln
MR GLICK Because there has been no testimony
from Mr Knapp when
we show the vldeo that Vldya went
on the surveillance
wearlng
changed
case
adds to
lS
the
the
the
not
This shows the ]ury that Vldya was
red clothes and witness has she
mean, we have the obllgatlon to present our
jury, which we accept that burden, but
and lt will that
how Vldya was
There lS no testimony on the record other
. I
series of questions afterwards as to establish that A. Avalos 770
than her OIlglHa1 testlmony that she was not wearlng the
sannyasln clothes shows Vldya ln dlfferent clothes
and she changed
THE COURT I d1dn't hear any dlspute about that
from elther defendant Am I
MR WEATHERHEAD My understanding Vldya lS not
here
MS SCISSORS It stlpulated the press
conference occurred on the 21st
THE COURT She was wearlng are you
stlpulatlng she was wearlng red at tlm?g
MS SCISSORS It lH the vldeo
GLICK Why don we show the vldeo?
THE COURT Are you golng to refute that?
WEATHERHEAD The lS ln evldence
THE COURT I reallze lt lS ln evldence The
lS whether or not we are agreelng that Vldya lS ln
that ln red and later changes lht0 whatever
want to call lt, muffle
MR WEATHERHEAD Muffle lS probably a good
word I don know lf the Court lS a stlpulatlon
on that I really don't care
The wltness has to lt There
any source of lHf0Im&tlOH to COHtIadlCt lt other than
MR . 2 .
MS. SCISSORS: Absolutely not.
MR.
. We
II 1|
A. Avalos 771
maybe the other people who were ln the car Certalnly,
are not ln a pOSltlOD to what Vldya was wearlng
But I the ultlmate polnt lS the vldeo doesn't get you
there
All the vldeo shows lS Vldya wearlng red
clothes The jury has seen that The Vldeo does not
she changed her clothes cumulatlve and and more
MR GLICK There lS no testlmony ln the record
that Vldya was wearlng the sannyasln I a
vldeo to audlo portlon about the and how lt was
changed
THE COURT I can she
was there at that press conference
MR GLICK She wasn at the press conference
She was there after the press conference when Vldya got ln
the car The questlon 15, the lS, lS not how
Vldya was when she went on Vldya had gotten
out of these clothes Vldya on that day at
that tlme I don hear them stlpulatlng these are the
sannyasln clothes that Vldya wore She wasn wearlng them
at the tlme of the
THE COURT lS the last tlme I am golng to
show the vldeo If you don want to use lt somewhere, you
better save ltA. Avalos 772
MR GLICK No, lS lt
THE COURT All right the jury ln
(Jury ln)
THE COURT Ladles and gentlemen, lS
one that you have already seen once It lS already lH
evldence It lS now belng used for wltness
And so you go ahead and show lt agaln
MR GLICK If the Court could turn on the Helgln
monltor If I may
THE COURT Can all jurors see that' Walt
minute Are you havlng d1ffLculty?
THE WITNESS I can see through
MR GLICK If you would watch the televlslon
monitor dlrectly behlnd or the one ln front, Government
30
(By Mr
opportunlty to watch
played'
Yes
Yes
And
Red
And
(Videotape played
Ms Avalos, you have an
Government 30 as lt was
you see the that was worn by Vldy
what of clothing was that'
was that that Vldya wore when she went A. Avalos 773
the surveillance with you?
What kind of clothing was she wearing'
She was wearing non sannyasin colored clothing
Is the date of this press conference June 21, 1985?
When did you first arrive in Portland to
begin the surveillance?
Two or three days before that Two definitely, maybe
three
And how many days did you remain in Portland after
this press conference?
We went back to the ranch that same day, that evening
earlier that you actually saw the firearms which Anugiten
had shown you, is that correct?
That is correct
I would like to show you Government Exhibits
10, ll, 12 Were you present or did you hear any
discussion about what happened to these firearms'
We were leaving the ranch Anugiten told me that
he had thrown them into the lake
I want to show you an portrait, Government Exhibit 5
in evidence I ask you to take that look at this and see
if you recognize this
Yes That looks like Patanjali Lake
All right. Now, you indicated on direct examination
A. Avalos 774
If anywhere Anuglten where he had
thrown the guns'
He tell me where
In the lake, ln Patanjall
referred to them as flve easy
All And where did
He just sald he threw them
say the guns
pleces
that name derlve from'
I have no ldea
Now, you earller there came a tlme when
Davld when came and asked you for a camera, LS that
That lS
the Court permission, I want to show you
Governments No 22 I ask you to open that up and
look 1ns1de
your attention to 22 A, what
you recognize lt to be'
15 one of the cameras that we had, one
llke the
Any
that you
No,
the same
All
one I would have glven
dlfferences between camera and the camera
gave to 9
not that I remember It looked pretty
type of camera
I want to dlrect your attention, th
Court to Governments 26, and ask you
to take a look at that Do you recognlze thatright A. Avalos 775
Yes, I do
What do you recognlze lt to be?
It a plcture of Su, Patlpada, Savlta, Su, Sheela
communal meetlng
Do you recognlze by the depletion of any of the people
when ln tlme this plcture was taken'
Well, my guess lS lt was ln the summer because Savlta
had her halred permed And Savlta permed her halr that
summer
MR Excuse me I guess I have
object because lt was a guess
THE COURT Sustalned
you spend Savlta ln the summer of 1985, when
approxlmately she had her halr permed?
Well, lt was that summer she permed her halr
Is that depleted ln Government 36?
Yes
What was her halr before that'
Stralght, llke lt lS now
And you recall partlcular meet1ng?
It seemed llke I remember I was at lt, but I not
completely sure why I have a feellng lt was when Bhagwan
declded to talk agaln I don know for sure
You are uncertaln as to the subject matter (By Mr. Glick) Do you know, based on your time that
meeting'
A. Avalos 776
That lS I know I had been to this meeting
What would have been the clrcumstances for Savlta and
Su to be next to Sheela at the front of that
aud1tor1um?
MR WEATHERHEAD Objectlon, Your Honor
foundation I the wltness sald she has no
recollectlon
THE COURT
GLICK
GLICK
meetlng
THE COURT
MR GLICK
(By Mr
meetlng?
Yes
Sustalned
It a dlfferent question
Not the subject matter of the
I understand, sustained
Thank you
You recall belng present at
Do you recall the person ln front of the
audltorlum being depleted ln that p1cture?
Yes
And who were these people ln front of the audltorlum?
. Vldya, Sheela, Savlta, Patlpada and Su
What are the clrcumstances that led them to be
next to Sheela as opposed to yourself or any other
THE COURT: I understandA. Avalos 777
sannyz-1s1n'P
Maklng some sort of announcement
MR GLICK Offer that
MR WEATHERHEAD Move to Objection to
that, 1t's what lS to the witness may not be
obvlous to the next person
MR GLICK We can do next, at a later time
THE COURT All right
MR GLICK We move to 8 9 10 11 12
Your Honor, 1f I may I ask that Agent McCann
take out the flrearms and them to the
THE COURT Yes
that
I No 8
All right Take a look at that I want to show them
to you one at a tlme and ask you a questlon after you have
seen all flve
ay 9
Take a look at that
(Complles) Number 10
Okay
11 And No
Based upon your examlnatlon of Government
9, 10, 11, 12, lS there about any of these
.
. I I I I
Q. (By Mr. Glick) Indicate for the record what exhibit
isA. Avalos 778
weapons, these firearms that you recognlze as to the tlme
that you see them Anug1ten?
Well, obvlously they are very rusty, but what I
remember about seeing the guns was that one had a long
barrel like number I lt No 10 here
Just speak Into the microphone
One of the guns had longer barrels than the rest and
one had a smaller barrel, the small one Llke that one
So those are the two that I remember ln relatlon to the
five One had a longer barrel and one was short The
other three
All
All right Thank you
MR GLICK Thank you, Agent McCann
(By Mr Now, your attentlon to
Aprll of 1990, there come a tlme when you returned to
Mr Turner home'
(No response)
Aprll of 1990, there come a tlme when you returned
to Mr Turner home'
Yes
What were the clrcumstances of that'
The Government asked me to accompany Agent McCann to
resldence, lf I could where he llved
A.
A.
Q. .
A. I can't rememberA. Avalos
779
And how was it that you got to that residence?
Hadley drove to Sherwood to close to the area where
Charlie Turner lived
And then what happened'
Then he says, Can you tell me how to get to Charles
Turner house from here, and I told him
What happened'
We went there
Did you get to Mr Turner home"
Yes, we did
them to you'
I gave them to him
I would like to show 18A through
these, and by the letter on the back and
tell me if you can identify any of these
18A is one of the houses on that
would be as you turn right to go down to
It the same as the black and white one
and it either home or the neighbor
Take a look at
the exhibit number
you turn that
Charles Turner
ltself in color
home
This blue house on Exhibit 18B is also one
of the houses along the road I not sure whether either
of them could be Charles Turner home They are along the
road
8 looks like the mailboxes that we finally
. .
Did you give Agent McCann directions or did he give
A. Avalos 780
found that led us to home Sorry, 18C
The numbers on the back
18D lS a color plcture of the road leadlng to Charles
Turner home before you turn to go down the
And 18E lS a the same shot, but I taken hack a
so there lS more brush and trees that are
showlng
Thank you
There lS one more, l8F, lS also the
the property home, I am pretty
sure
Thank you
earller on dlrect examlnatlon that you attended
approxlmately a year and a half at Berkeley before you
became ln the commune After all of was
over, you ever go back to school'
After I got out of jall, I went back to school
Tell the ladles and gentlemen of the jury what you are
dolng now
I declded to go back to school I recelved an
undergraduate I got my major ln dance and phllosophy
I currently a graduate student and a thESlS on
the of movement ln health and And
I taught dance and movements I dlrect and teach And finally, Ms. Avalos, you indicated
A. .
. .
A. .
A. Avalos 781
teenagers I put myself through school I have been dolng
that for the last seven years
Does that mean you work at teenagers
What does that mean'
on probatlon or have been on probatlon as the
out of jall I teach at the as an
undergraduate student
Generally what do you mean you put yourself through
school?
Well, I worked Whlle I have been golng to school I
have been and put myself through school
THE COURT All right Ladles and gentlemen, we
be lH recess for 20 mlnutes
(Recess)
(Recess)
THE COURT Ms Scissors
MS SCISSORS Thank you
BY MS SCISSORS
Ms Avalos, when you left the ranch on September 14,
1985, the concept of leavlng was that you
dlscussed for some tlme wasn lt'
A few weeks beforehand
Q. .
A.
Q.
A. .
MR. GLICK: Thank you. No further questionsA. Avalos 782
Well, isn it true that in early August, 1985, Sheela
had talked about two plans for the ranch, Plan A and Plan
Yeah, that
And under what she called Plan A, she was golng to try
and have all the people put thelr resumes together'
I don remember I know they were Plan A and Plan
And one plan was about people golng off together But I
don remember necessarlly a resume together, no
Under one plan she was golng to have people who were
on the commune go off the commune and work jobs to
money back lHtO the ranch, lS that right'
That
correct?
One plan was to leave, go to Europe, and the
other one was to stay on the commune
And the plan that talked about golng to Europe was the
plan where she was golng to take people with her to Europe
and they were golng to start up a buslness ln Europe that
would generate Income for Rajneeshpuram, 15 that Ilght9
MR GLICK Objection to the questlon
THE COURT Let break lt down I realize lt
a ClaIlflCatlOH Break lt down
(By Ms One plan Sheela had ln August Well, wasn't there there were two plans; is that