IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW MEXICO
Civ. No. 86-0838M
HARBHAJAN SINGH KHALSA YOGIJI
Civ. No. 86-0839
(Consolidated with No. 86-0838M)
AFFIDAVIT OF PAMELA DYSON
I, PAMELA DYSON, the undersigned, hereby
depose and state:
1. My name is Pamela Dyson. I currently reside on the island of Maui, in Hawaii.
2. From January 1969 through May 1985, I was a follower of Harbhajan Singh Khalsa Yogiji, who is also known as Yogi
Bhajan. During that time, my spiritual name was S. Premka Kaur Khalsa. I am the plaintiff in Civil Action No. 86-0838M,
3. During the time that I was a follower of Bhajan, I worked for Bhajan personally, as well as for the Sikh Dharma
Brotherhood, the 3H0 Foundations the 3H0 Foundation of New Mexico, the corporation sole and the rest of Bhajans corporations.
4. When, as a follower and employee of Bhajan, I moved into his home in New Mexico in mid-1969, I was made a member
of Bhajans Secretariat, which is Bhajans staff of female assistants. When I first became a member of the Secretariat, there
were only two members, myself and another woman. The Secretariat later grew to approximately twelve members.
5. Ultimately, in 1974, I became President and Secretary General of the Sikh Dharma Brotherhood and Administrative
Director of the Secretariat. I was also VicePresident of the 3H0 Foundation. I was, by virtue of these offices, also a member
of the Khalsa Council. I held these positions until I left Bhajans organization in 1984.
6. Among my duties were oversight
of the administration of the Secretariat, planning and executing the Khalsa Council meetings, oversight of the accounting
departments that 1~andled all of the corporations ledgers, and oversight of the maintenance and development of all of the
properties and assets of the corporations. I was also the editor of Beads of Truth, a twice-yearly publication of the 3H0
Foundation, and I was a high minister of the Sikh faith (Mukhia Sardarni Sahiba), whose duties included such things as spiritual
counseling and the performance of weddings between followers of Yogi Bhajan.
7. During the time that I served the defendants in these capacities, I understood the Sikh Dharma Brotherhood to
be a religious organization, and the 3H0 Foundation to be an educational organization.
8. I was instructed, by Bhajan, as well as by Bhajans legal advisers, that the 3H0 Foundation was a non-profit corporation,
formed for the purpose of promoting and teaching the Kundalini yoga techniques of Yogi Bhajan, including exercises, meditation,
chants~ diets and other yoga principles. These practices were explained to me to be based on scientific principles, and not
on any articles of the Sikh faith. It was advertised by those of us working with 3H0, at Bhajans direction, that Bhajan and
Bhajans students would teach these techniques, for a fee, to the general public.
9. By virtue of my various positions within the organizations, I was well acquainted with the mechanics of the organizations,
as well as their by-laws, and stated goals, purposes and objectives.
10. Throughout my tenure with Bhajan, I was told by Bhajan, as well as accountants and attorneys working on behalf
of Bhajan and the corporate entities, that the 3H0 Foundation and the Sikh Dharma Brotherhood were separate to the government,
and must always be presented to the public as separate entities with different functions.
11. The Sikh Religion was not practiced through the 3H0 Foundation, and the 3H0 Foundation did not function as a
religious organization. A deliberate effort was made to promote the distinction between 3H0 and the religious functions of
the Sikh Dharma Brotherhood.
12. At the time, I believed that these two organizations were separate and distinct in purpose as well as function,
and I always endeavored to act according to this belief in all my administrative dealings with the organizations.
13. I am certain the Sikh religion, as practiced during the time that I followed Bhajan, did not involve the practice
of the Kundalini yoga or Tantric yoga that Bhajan taught. One could be an observant member of the Sikh religion without practicing
yoga, although, due to Bhajans personal influence, Kundalini yoga and Tantric yoga were frequently practiced by Bhajans followers.
Conversely, one could practice Kundalini or Tantric yoga without believing in the Sikh religion.
14. As a plaintiff, I know that attorneys for the defendants have told the Court that the practice of yoga, and the
various diets, exercises and chantings I refer to in my Complaint, are all part of the practice of the Sikh religion. This
is incorrect, at least for the period of time that I was involved with 3H0 and Sikh Dharma Brotherhood. I did not regard my
yoga practice as a practice of the Sikh Dharma.
15. As a plaintiff, I also know that attorneys for the defendants have told the Court that the business of the 3H0
Foundation was religious in nature. This is incorrect, at least for the period of time that I was involved with 3H0 and Sikh
Dharma Brotherhood. In the past, these same defendants consistently maintained that all religious function was singularly
the province of the Sikh Dharma Brotherhood, while the 3H0 was to be an educational and scientific organization. These distinctions
were repeatedly made by these defendants.
16. In retrospect, it is now clear to me that none of Bhajans actions were religiously motivated, and I would not
want the statements I am making here to be construed as a present belief on my part that Bhajan was acting pursuant to sincerely
felt religious motives when he was conducting the business of 3H0, the Sikh Dharma Brotherhood Corporation, or the Sin Singh
Sahib of Sikh Dharma Corporation. What I am now saying is that, even if one were to assume that the defendants professed religious
motives were completely genuine, by their own teaching,
the functions of 3HO were not religious, but educational and scientific.
Signed: Pamela Dyson
I HEREBY CERTIFY THAT THE FOREGOING
STATEMENT IS TRUE AND
CORRECT TO THE BEST OF KNOWLEDGE, INFORMATION AND BELIEF.
Dated: July 25, 1987