"Da's goal was to maximize his control over the direction and policy of the JDC and at the same time minimize or completely eliminate personal liability for himself."

SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF MARIN BEVERLY JACOBS O'MAHONEY, an individual, Plaintiff,

v. FRANKLIN JONES, aka DA FREE JOHN, aka DA FREE JOHN, an individual et al, Defendants

Case No. 121 99

DECLARATION OF ANDREW PARKER

I, Andrew Parker, declare:

1. I am over the age of 18 years and the facts herein are based upon my own personal knowledge, and if called as a witness I could competently testify to the following of my own direct knowledge.

2. I was a member of the JOHANNINE DAIST COMMUNION (JDC) continuously from approximately January 1978 until July 1983 when I left JDC. From August of 1981 until June of 1983 I served as a member of the Board of Directors of JDC and during June and July of 1982 I was the Director of the JDC's educational division, then called The Crazy Wisdom Fellowship (CWF). As both a member of the Board of Directors and as Director of CWF I had direct and intimate experience with the internal operations of the JDC and particularly of FRANKLIN JONES' influence over and control of the workings of the JDC.

3. As both a Board of Directors member and Director of CWF I received virtually all of my instructions, policy, rulings and guidelines from members of the so called Renunciate Order (RO), composed of the inner circle of members surrounding FRANKLIN JONES: primarily from Marcia Cohen, Elizabeth Brown, Bonnie Beavin and Annie Rogers, all of whom were known of as the wives of FRANKLIN JONES, as well as from William Tsikinas, Michael Wood and Morton Whiteside. All of these various members of the RO as well as others not mentioned, were acting as Jones' agents and had his complete proxy as far as their interaction with myself as a Board of Directors member and as a Director of CWF.

4. It was my experience that FRANKLIN JONES exercised two forms of control over the policy and management of the JDC, direct and indirect. He exercised a direct control in the form of speaking personally to Board and management personnel, or communicating to them via members of his RO with direct formulation of policies and goals; and he exercised indirect influence as the final authority and sole arbiter over the "spiritual" status or standing of every member, because every individual in the JDC administration was simultaneously a member of the "spiritual culture" of the JDC, and therefore, completely subservient to JONES and beholden to him. It was unnecessary for him to exercise total direct managerial control over the institution, even though he frequently did so. In other words, it was unnecessary for JONES to personally order an individual fired from a position in the JDC or transferred to another post. All that was necessary for him to do was to criticize that person's spiritual maturity, or suggest that he would be better able to serve him (JONES) in some other capacity, and his "suggestions" were immediately taken as unquestionable policy by the Board and JDC management.

5. During my entire tenure on the Board of Directors and also as Director of CWF it was my experience that every top management position in the JDC, including Board membership and officers of the institution, were viewed, often interviewed, and had to be approved by JONES, either directly or through a member of his RO who always reported back to him (JONES) on the candidates and their standing. Over and above functional qualifications for the positions involved, the essential criterion for an individual's being approved or disapproved for one of these positions was always his or her unswerving devotion and obedience to JONES, and acceptance of his word as final and authoritative.

6. On at least two occasions during my tenure as a Board member and as Director of CWF I witnessed JONES' direct intervention in personal decisions relative to JDC high­level employees On several occasions during this period of time, at his direction one individual, Craig Lesser, was periodically reassigned from one department of the JDC to another, or from one special task or project to another, regardless of his formal employment by the JDC in any particular capacity. Another individual, Peter Churchill was a staff member of the CWF until JONES dictated that he should be reassigned to the principalship of a new children's boarding school in upstate New York. As soon as this edict came down, management's only option was to fully comply.

7. My own personal experience of being hired for both the JDC Board and also the Directorship of the CWF, and being dismissed from the later position, are direct examples of JONES' complete control and domination over the JDC institution both directly and through his agents, the RO . In August of 1981 Marcia Cohen and Morton Whiteside, as agents of JONES and with his complete proxy, came to California from his residence in Kauai with written instructions from JONES to dismiss the existing Board of Directors and to hire a new Board membership that would be more compliant with his policies and dictates. I was personally selected and approved for Board membership by Marcia Cohen, and temporarily served as Chairman of the Board of Directors, until the full Board membership was approved by the RO and JONES, at which time a formal Chairman was elected. Likewise, it was at the insistence of the RO members, particularly William Tsikinas, Michael Wood and Elizabeth Brown, that I left my position as a Board of Directors member and assumed the directorship of the CWF. After two months of serving as Director of CWF, Marcia Cohen and another member of the RO, Patricia Tsikinas approached BRIAN O'MAHONY, The Corporate President, and (at his own admission) ordered him to dismiss me from the position. This took place on July 8, 1982. At the time in which BRIAN O'MAHONY informed me of this decision he admitted that he was doing so on the orders of the RO and that it was based on my evident lack of complete obedience to FRANKLIN JONES and my lack of devotion to his personal wants and needs. BRIAN O'MAHONY reiterated this same admission, i.e. that he had been instructed to dismiss me at the order of RO members, on several subsequent occasions over the following year and one half.

8. During my time as a Board member it was my experience that the Board of Directors was never more than a "rubber stamp" for FRANKLIN JONES and his agents, as far as policy making and overall management direction was concerned. Renunciate order members were actively present at the majority of Board meetings which I attended and they frequently interrupted, redirected and otherwise controlled the meetings in order to bring them into line with JONES' needs and wants. If any Board member ever dared to question or criticize or exhibit any dissatisfaction with their influence it was grounds for immediate dismissal, as happened in the case of Steve Cutler, a Board of Directors member who was selected at the same time that I was.

9. It was my experience as a Board of Directors member that the entire Church Corporation was driven by the pressure of JONES' many and often conflicting demands. Often he demanded new projects be started and others scrapped, moved up time tables, and in general, set the tone and pace for the entire endeavor of the Corporation. Althouqh he made a show of insisting on strict adherence to management principles of the JDC, ones which he had a direct hand in establishing himself­especially regarding fiscal matters­he would regularly and frequently force the violation of these management principles by making new demands upon Corporate resources for various projects which overextended the JDC's finances. For example, although it was a management principle to never operate the JDC at a deficit, during my entire tenure as a Board member, the Corporation was continuously operating on a deficit of approximately $40­50,000 per month. If it was ever suggested that we cut back any of these projects, or defer them until the deficits had been eliminated, the Board was accused of disobedience, non­compliance, and lack of devotion to JONES.

10. Shortly after my selection to the Board of Directors, I was present at a meeting which was attended by Marcia Cohen and Elizabeth Brown, two of JONES' wives, in which at their insistence, Board minutes were drawn up to reflect the fiction that the transition from the previous Board of Directors to be the one on which I was a regular, orderly and legitimate transition when in fact, nothing could have been further from the truth. In fact the dissolution of the previous Board of Directors and the hiring of a new Board had been done entirely at JONES' instigation via his agents, contrary to JDC by­laws which required a normal procedure for changing a Board, one without JONES' involvement.

11. During the early fall of 1981 JONES instructed the Board of Directors to consult with new outside corporate counsel, Sandy Rosen, on how to establish a complete lack of personal liability on his part for any and all acts and undertakings of the JDC. His goal was to maximize his control over the direction and policy of the JDC and at the same time minimize or completely eliminate personal liability for himself. A meeting at Rosen's office was held at this time with Rosen and his associate, Mitch Zimmerman at which time the JDC Board of Directors was present along with Elizabeth Brown and Marcia Cohen. At this time Rosen informed us that it was not possible for JONES to exert the kind of control and influence over the institution which he did, both directly and through the RO members, and remain free of personal liability. I was instructed by Elizabeth Brown to create a document to memorialize the content and conclusions of this meeting which I did. When I submitted this to her for transmission to JONES, she refused to do so on the grounds that he (JONES) would find Rosen's conclusions unacceptable.

12. Apart from the more overt control which JONES exercised over corporate policy and management goals, he also asserted an even more pervasive influence over the entire spectrum of the JDC's activities and lives of its members, including the naming of children and member's businesses; directions on personal habits such as diet, exercise, health, sexuality, sleeping, marriages, funerals, etc. He would even let his political preferences be known during election times; although the disclaimer was given that members were not being directly required to vote for one candidate or another, no one was going to vote counter to JONES' preferences. He would also determine at times that particular couples were to be married or divorced, which children would live with which parents, or with other people other than their parents, etc.

13. One of the very first projects which the Board of Directors was instructed to undertake after I had joined was the rebuilding of JONES' personal residence at his property in Lake County, California, a house which he named the "Manner of Flowers." This project completely taxed and overextended the financial and manpower resources of the Corporation for a period of five or more months and involved extensive and continuous fund raising, members driving from the San Francisco Bay Area up to Lake County several times a week, working all night, and so forth. The house was built and the grounds were landscaped with nothing but the most expensive materials and the most lavish appointments and equipment. All of this was done at the same time that the Corporation was running at a deficit, and JONES continued to demand the undertaking of additional projects such as the publication of books and the erection to temple sites, concurrently with this building project.

14. Another activity which the Board that I served on inherited from the previous Board was a major legal battle taking place in Kauai. The property on which Jones had his residence in Kauai was bordered by a neighboring spiritual group who engaged in daily ceremonial practices that involved the soft ringing of bells. JONES found the ringing of these bells to be personally offensive and dictated that the Corporation devote all of its legal and financial resources to the elimination of this "nuisance." This involved the expenditure of around $100,000.00 in legal costs, spread out over a period of a year and one half, to quiet the ringing of bells which were barely audible from the start, which I can testify to from my own experience of listening to them. In this situation JONES had the entire Corporate organization devoted to rectifying something which he alone experienced as a problem, for which there was no clear­cut legal remedy, and for which little or no government sympathy was ever elicited.

15. Although JONES' official status within the Corporation is as a renunciate with no ownership and management powers and perrogatives, his personal demands and his influence over policy were completely pervasive; such that one would have to say that he simply runs the Corporation. As a Board member it was my experience that the entire resources of the JDC Corporation were always completely at his disposal. This included the location and acquisition of very expensive properties such as the Island of Naitaumba in Fiji, the acquisition of expensive art (including many thousands of Disney art which JONES' particularly liked), and jewelry, home entertainment equipment such as expensive audio and video equipment, not to mention expenditures on expensive material for clothing and other personal effects. The funds for all of this came both directly from the Corporate treasury as well as through direct fund raising from members, and no one but JONES and the RO were ever permitted to have access to these JDC acquisitions. I declare under penalty of perjury that the foregoing is true and correct.