Declaration of John Shelfer e |, John J. Shelfer, also known as Sw. Prem Jayananda, declare and say as follows: 1. Ihave been a le (“sannyasin”) of Osho, formerly known as Bhagwan Shree Rajneesh since April 1977. When I choose Osho as my spiritual teacher, ! was living in New York City area and working as a sales executive for an international purchasing and sales organization. We shipped building material and HVAC equipment overseas from the US. Prior to that experience, | had worked for international banks on Wall Street financing trade in Eastern Europe and the Middle East. Since 1985 | have taught chi gong and tai chi chuan in Asia and currently in the Bay Area of California. 2. | first became involved in Osho’s work at Sangit, a meditation center in New York City, and subsequently at Chidivilas Meditation Center (“Chidvilas”) in New Jersey. Chidvilas had tax exempt status as a religious entity under IRS 501(c)(3). | met Sheela Silverman (“Sheela”), also known as Ma Anand Sheela, in Pune, India in 1977. We became involved in a relationship in the fall of 1980 and married in January 1981. Sheela already had strong connections with the US, having earlier obtained “permanent resident” status in the US through her former husband, who was deceased at the time | met Sheela. 3. By early 1981, the printing, manufacturing and distribution of Osho’s books and the production of audio tapes of Osho's discourses was being moved to Chidvilas in New Jersey. That work had been done in india, but India presented ongoing difficulties with infrastructure, technology and distance for shipping. In order to support that new work, a large residential building had been purchased in New Jersey by Chidvilas, to serve as a residence for workers and as a production and distribution center for Osho’s books and tapes. 4, By 1979, the growth in popularity of Osho's work and the ashram in india had “outgrown” the facility in Pune, India. The search for a substantial piece of land in India, suitable for an expanded “new commune” had been going on for several years but had not resulted in finding an appropriate site and obtaining the needed government approval. Ma Yoga Laxmi, then Osho's personal secretary in India, was stationed in Delhi to try to find land in the North of India and to obtain the approval of the central government. A great deal of work had been done, and discussions and negotiations about various possibilities took place, but no usable site which was acceptable to the government authorities, had been found. Hopes dropped when Indira Gandhi came back into power and did not move to assist the effort, though she had been quite friendly in the past.5. With Laxmi away from the Ashram, Sheela, then Laxmi’s assistant, stepped into Laxmi’s role in day to day management at the Ashram in January 1981, and began meeting daily with Osho. Osho had become less and less accessible to visiting disciples as the years went on and the number of visitors vastly increased. In the spring of 1981, Osho entered into a period of seclusion and silence, owing to his back and health conditions, and was not giving discourses. For a time, he came out and sat. silently with his disciples in the large open-air, tent like facility called Buddha Hall, where he had earlier given his discourses, in what was called silent “satsang”. 6. The failure to obtain land in india and the increased tensions around the Pune Ashram, along with criticism of ashram activities and threatened punitive action by the Indian authorities, provided an impetus for Sheela, myself and others at the Ashram to consider and propose the establishment of a new commune in the United States. Sheela was very much in favor of establishing a large commune in the U.S., as was |. As an American, | was very excited about the possibility of having Osho in the USS. for as long as was possible under the law and according to Osho’s willingness to ist and stay in the U.S. 7. In the spring of 1981, Sheela and | made a presentation to Osho about the possibility of a large commune in the US, which would, we believed, be free from the hostility and interference which the group had experienced in India. | showed Osho the Bill of Rights to the US constitution with the First Amendment Freedoms of Religion and Speech, and brochures for several large parcels of land available in the US. Sheela told Osho in my presence that he would be able to travel to the U.S. asa visitor, and that he could qualify for a U.S. visa as a religious teacher, which would allow him to stay in the US longer if he was comfortable there. Osho gave Sheela and | his blessing to further explore the possibility of obtaining land in the US, and told us that if we could obtain a suitable location, he would visit. Of course, Osho had no legal right or authority to tell Sheela, or the US non-profit devoted to his work, what to do, whether or what to buy or where. But because our devotion, it was usual to ask Osho for “his blessings”, as we did, prior to undertaking a major project involving him or his work, especially a project of this magnitude. 8. At that time, Osho’s medical condition was worsening. In addition to his diabetes and allergies, long-term problems with his back were significantly worsening. He had had substantial treatment for prolapsed discs from the leading orthopedic specialist in Pune, Dr. Hardikar, who had treated him for back problems in the past. When those treatments did not result in improvement, Osho was treated by Dr. James Cyriax, a well-known specialist from London. Those treatments, including epidural injections, also failed to result in improvement. 9. | was then informed that in the face of increasingly severe pain, which indicated a worsening of the disc condition, Osho’s personal physicians, as well as Dr. Hardikarand Dr. Cyriax, had recommended that Osho be taken from India to a country where surgery could be performed, if necessary, in an appropriate facility, which would have the latest technology and not present the health and sanitary hazards then unavoidable in India. One of Osho's personal physicians, Dr. Shunyo, had practiced in New York City, and was well familiar with all the all the available facilities in that area, which resulted in the US being seen as the best location. 10. Because of my relationship with Sheela, my own relationship with Osho, and my role in the possible development in the U.S., | was personally aware of Osho’s medical situation as it developed. We were all very concerned about Osho's illnesses and were committed to having Osho taken to a location where surgery could be safely performed if necessary. At that time, no decision had been made to have surgery, only that Osho should travel to a location where the surgery could be more safely performed than in India and by the best surgeons available, if the surgery proved necessary. 11. On May 4, 1981, in the face of Osho’s deteriorating medical condition, Sheela visited the U.S. Embassy in Bombay to inquire about the possibility of a visa for Osho to travel to the U.S. so that he would be nearby needed medical facilities if surgery proved necessary. 12. | was in the car with Sheela in Mumbai, and dropped her off at the U.S. Embassy, when Sheela visited Joyce Smith, the consular official responsible for issuing visas to the U.S. After Sheela left the Consulate, she told me that Smith had told her that the best way to proceed would be to bring Osho to the United States on a visitor's visa based on his medical needs, and then, once in the United States, seek permanent residency if his condition improved and Osho agreed to stay longer. Sheela told me that Smith had told her that if Osho applied for a visa as a religious teacher from India, it could take a very long time to be decided, but that if he applied for a visitor's, visa in India based on his medical needs, he could obtain one quickly, and then apply for a change of status to religious teacher visa from inside the US, and remain in the US while we waited for a decision on permanent residence. Sheela was very direct in what she reported. | had no doubt at that time that she was accurately reporting what had occurred. We knew Osho's presence in the U.S. would certainly be a matter of public and press interest, and could be controversial. We were talking to the consular officials in order to be aware of and comply with all legal requirements. had had a number of conversations with Sheela about bringing Osho to the United States, and we were doing our best to find out what U.S. law required, and to comply with that. 13. Sheela reported to Osho, in my presence, what Smith had told her. Osho seemed to accept what she reported and approved her going forward to apply for the visitor’s visa for medical reasons.14, In the spring of 1981, as Vice-President of Chidvilas, | continued the search for land in the U.S., which would be appropriate for a residential community. The search intensified as Osho's medical condition deteriorated and the possibility arose of bringing him to the U.S. to be able to deal with his medical needs. | explored many possibilities and travelled to several states, looking at possible locations. This, impetus did not come from Osho, but rather from those of us who were devoted to him. We wanted to find an appropriate location for a community, similar to those already existing around the world, which he could visit and at which he could reside for as long as he felt comfortable. Whether he would allow us to apply for permanent residence for him would depend on how he did medically in the US, and, if his health improved, whether he would then agree to stay longer. 15. Osho’s medical condition did not improve, so application for a visitor's visa was made, and on May 31, 1981, Osho flew from Mumbai to New York. 16. When we arrived in the U.S., Osho stayed at the property in New Jersey, a part of which had been prepared for his special needs. His back improved after his arrival, perhaps because of the better conditions in the U.S. He became able to walk without pain and for longer periods. His general strength improved. His personal physicians attended to him daily while he was in New Jersey. Because of the improvement, no further action was taken with regard to potential surgery. 17. In June, 1981, we found a large ranch property in Oregon, which was acquired by Chidvilas and called Rancho Rajneesh (“the Ranch”). About 50 volunteer members of the world sannyas community came to the property, which had been over-grazed and was in a very deteriorated condition. We set about creating some infrastructure to accommodate a greater number of residents to transform the Ranch into an ecological, vegetarian community. In the main, the development relied on the use of ‘“double-wide” mobile homes. All necessary permits were obtained. 18. Several of these mobile homes were put together to form a unit appropriate for Osho and the few people responsible for his care, and to accommodate his special health related needs. 19. By late August 1981, the improvements were sufficient to support Osho and the people who cared for him. On August 31, 1981, Osho was flown to the Ranch. 20. Osho’s health continued to improve. He became able to drive for short pi We were not yet sure of his evolving physical condition, or willingness to remai the Oregon high desert, so an extension of his visitor’s visa was obtained. By the end of October 1981, Osho’s health had continued to improve and development of theRanch had progressed to the point where we began to consider the longer-term issue of Osho remaining in the U.S. 21. An attorney from Houston, Patrick Dugan, also known as Sw. Apodipo, who specialized in immigration law, came to the Ranch to visit, and told Sheela and | of a specific set of circumstances, something about quotas as | recall, which made it incumbent upon us to apply for permanent residence before the end of that year. 22. Sheela and | asked Osho if he would stay longer if we could obtain the necessary permission from the U.S. government and he agreed to do so. 23. To do the necessary work, and to consult about compliance with U.S. law, we also consulted with attorneys in New York and Washington D.C., and hired an immigration attorney specialist in Portland, OR, in order to do the necessary work and comply in every way with US law. The necessary papers were prepared, and in November 1981, were filed with the INS in Portland. 24, We were much surprised when, from the beginning, the INS in Portland showed such hostility to the community with surprise visits and negative comments. We had no choice but to pursue our rights under the law, and to address multiple INS legal violations with lawsuits. 25, From early 1981, when Osho went into his period of seclusion and “public silence”, while still in India, Sheela effectively controlled access to him and the flow of information to him. He had never been involved in business matters other than when he might have been consulted for guidance from a spiritual perspective. But after he went into silence, Osho became even more removed from temporal activities. While Sheela had been deeply devoted to Osho, after she came into power, she became more and more focused on maintaining that power and rebuffing any perceived threats to her power. 26. In the fall of 1979, Sheela often spoke to me concerning the dominance of several of the Moms who managed departments in Pune. (Alll the department coordinators were women and were called “Moms.”) Sheela established a new order of women friends who she led ostensibly in creating Osho’s vision of a meritocracy community. In Oregon, that “new order” became doing everything Sheela’s way or being reassigned to another area. The opinions of others were not taken into account. The former Moms either conformed to the new order, disappeared to the far reaches of the community or left the Ranch. While paying lip service to Osho’s vision if it came up in Sheela’s conversations with Osho, these personnel changes or people entering or leaving the community were covered over with half or even % truths. As Osho was not directly involved with the operations of the community, it was normal for people to come and go and Sheela received no rebukes or questioning from Osho asto Sheela’s actions. The staff which directly attended to Osho in his convalescence had little interaction with the community so derogatory information did not reach Osho. Sheela’s actions, such as by dispensing choice assignments, dispensing preferential housing, controlling co-habitation with partners, even allowing children of residents to join the community, built a network of information and control that allowed Sheela to dominate the community. 27. On many occasions during the first year or two at the Ranch, | would accompany Sheela to visit Osho when it was needed to advise him generally on Ranch development and the increasing opposition to the development. Sheela was very good at framing the issues in a way that would invite Osho’s approval of whatever she proposed to do. She might ask a general, broad question, get an answer, and then, she would go back and use that as Osho authorizing whatever it was she wanted to do. She would provide or limit information as it would help support what she wanted. 28. Osho was open to Sheela’s questions and suggestions. He trusted his people. He was our spiritual master, our friend, our guide. But he also insisted on our being responsible for our choices and our actions. While Sheela never claimed to be interested in meditation, Osho reportedly told her he would bring her into that state of being through her love and devotion to him. She played Osho's trust to the hilt, trying to hide her developing egocentric and irrational behavior from Osho. This split persona continued in her deterioration until the stress of the work and fear of loss of power began to affect her ability to sleep and focus. Without sleep, Sheela slipped further and further away while maintaining her power and almost dictatorial behavior. The foregoing is within my personal knowledge, and if called as a witness | would testify competently there to. | declare under penalty of perjury that the foregoing is true and correct. Executed this_/B day of September 2020, at Novato, California.