UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW MEXICO
Vs. Civ. 860839HB
HARBHAJAN SINGH KHALSA
YOGIJI, et al.,
SUPPLEMENTAL AFFIDAVIT OF MANMOHAN SINGH
TO PLAINTIFFS BRIEF IN OPPOSITION TO
MOTION TO DISQUALIFY
Manmohan Singh, the undersigned, hereby depose and
1. 1 am an adult resident alien of the State of
California. My residence address is 8570 Los Coyotes Drive, Buena Park, California 90621.
2. I have read copies of the
affidavits of Gurujot Singh Khalsa and Wilfredo Mella dated August 8, 1986, and July 10, 1986, and filed in this lawsuit.
3. 1 have personal knowledge of some of the matters referred to in those affidavits, and I make this affidavit based upon
that personal knowledge.
4. On July 16, 1986 I attended a meeting at the Waldorf Astoria Hotel in New York, New York.
Present at the meeting were Sardar Harbhajan Singh Khalsa Yogiji, his wife, Inderjit Kaur Khalsa, Sardar Swaran Singh, Sardar
Pritam Singh and myself. Also present in the hotel suite, but not in the room in which the meetings actually occurred, were
Gurujot Singh Khalsa, Kulbir Singh Khalsa, and three or four others I do not know. One of the others maybe Wilfredo Mella.
5. The actual meeting took place in a bedroom of the suite. The suite was rented by Sardar Harbhajan Singh Khalsa
Yogiji. Gurujot Singh Khalsa was specifically excluded from the substantive parts of the meeting.
6. The meeting was arranged
by myself, Sardar Swaran Singh, and Sardar Trilochan Singh, at the behest of Sardar Harbhajan Singh Khalsa Yogiji who called
each of us a number of times urging us to arrange a meeting between him and Pritam Singh in order to see if the dispute concerned
could somehow be settled with out going to court.
7. In the meeting, Pritam Singh stated that he opposed Sardar Harbhajan
Singh Khalsa Yogijis claim to be Siri Singh Sahib. Pritam Singh stated that no such position exists. Pritam Singh also said
he had opposed Sardar Harbhajan Singh Khalsa Yogijis claims for many years, and would continue to oppose those claims as long
as Sardar Harbhajan Singh Khalsa Yogiji continued to make them.
8. With regard to the above lawsuits, Pritam Singh
stated that he was only assisting Katherine Felt or S. Premka Kaur Khalsa with loans and advice for the purpose.
Harbhajan Singh Khalsa Yogiji stated that he believed that if these lawsuits were filed by these two women, it would be harmful
to the Sikh religion, and he asked Pritam Singh to prevent the suits from being filed. In response, Pritam Singh stated that
if Sardar Harbhajan Singh Khalsa Yogiji would offer a reasonable settlement, Pritam Singh would use his best efforts to try
and settle the disputes without a lawsuit.
10. I notice that Gurujot Singh Khalsa states in paragraph 8 of his affidavit
that Pritam Singh made a demand that Sardar Harbhajan Singh Khalsa Yogiji recognize Khalistan. During the whole of the meeting
the word Khalistan was never even uttered. Pritam Singh did say that Sardar Harbhajan Singh Khalsa Yogiji should stop claiming
to be Sin Singh Sahib, and that he should resign from the Sin Singh Sahib Corporation.
11. Pritam Singh also said that
all funds received by Sardar Harbhajan Singh Khalsa Yogiji acting as Sin Singh Sahib, on received by the Sin Singh Sahib Corporation,
should be returned to those they were received from, and that any funds remaining should be given to the Sikh temples. Sardar
Pritam Singh did not say at any time that any funds should be turned over to him.
12. Pritam Singh did state that
Katherine Felt and S. Premka Kaur Khalsa should be compensated by Sardar Harbhajan Singh Khalsa Yogiji for their injuries.
I hereby certify, under penalty of perjury, that the foregoing statements
of fact are true and connect to the best of my knowledge, information and belief.
Executed on: September 12, 1986
I hereby certify that
On the 16th day of September
1986, a true copy of the foregoing
hand-de1ivered to opposing
counsel of record.