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BARRY B. LANGBERG (State Bar No.
48158)
DEBORAH DROOZ (State Bar No. 133355)
MITCHELL J. LANGBERG (State Bar No. 171912)
BRONSON, BRONSON & McKINNON LLP
444 South Flower Street, 24th Floor
Los Angeles, CA 90071-2925
Telephone: (213) 627-2000
Fax: (213) 627-2277
Attorneys for Plaintiff
CARLOS CASTANEDA
SUPERIOR COURT OF THE STATE OF
CALIFORNIA
IN AND FOR THE COUNTY OF LOS ANGELES
CARLOS CASTANEDA, an individual,
Plaintiff, v. BEAR & COMPANY PUBLISHING, a New Mexico corporation; BEAR &
COMPANY, INC., a New Mexico corporation; VICTOR SANCHEZ, an individual;
and DOES 1 through 10, inclusive, Defendants.
No. BC 139 612
DECLARATION OF CARLOS CASTANEDA
DEPT: 68
Hon. Abby Soven
Action Filed: 11/22/95
I, CARLOS CASTANEDA, hereby declare:
1. This declaration is based upon my
personal knowledge. If called upon to do so, I could and would testify
competently to its contents.
2. I am a resident of the state of
California. The acts of Defendant Victor Sanchez, as described herein,
caused harm to me in the state of California. This declaration is made in
support of Plaintiff's default prove-up, submitted to the Court pursuant
to CCP Section 585(b), (c) and 989, et seq.
3. I am an anthropologist and a
writer. My work explores the theoretical and spiritual traditions that
originated among the native inhabitants of Mexico in ancient times. These
traditions were preserved and practiced by a handful of "naguals" or
shamans who resided in Mexico. In the course of my research for these
books, I befriended and studied with one of these shamans: Don Juan Matus.
My oeuvre is based in large part upon Don Juan's teachings. My first and
most well-known book is entitled "The Teachings of Don Juan: A Yaqui Way
of Knowledge" in honor of Don Juan Matus. (Hereinafter, this book will be
referred to as "The Teachings of Don Juan.")
4. "The Teachings of Don Juan" was
first published in 1968 and has been in print continuously thereafter.
Millions of copies have been sold to date. My subsequent works, "A
Separate Reality," "Journey to Ixtlan: The Lessons of Don Juan," "Tales of
Power," "The Second Ring of Power," "The Power of Silence," "The Eagle's
Gift," "The Fire From Within" and "The Art of Dreaming" have also enjoyed
considerable success and have been widely read and studied. Through these
writings, I have developed a loyal readership whose members follow my work
with great interest. Over the years, I have come to recognize that my
readers are also extremely interested in any work that I have been even
tangentially involved with, and are likely to purchase any publication
with which I appear to be associated.
5. I have never been acquainted with
Victor Sanchez. Although Sanchez may have anonymously attended some of the
lectures that I have given over the years, I have never been associated
with him and most certainly have never been his teacher or mentor.
Furthermore, I strongly disagree with his interpretations of my work and
do not wish to be associated with him in the public's mind.
6. The cover of Sanchez's book, "The
Teachings of Don Carlos," bears a striking resemblance to the covers of
several of my books.
7. People have told me that they
initially thought that I wrote the book or that I was involved with
Sanchez in the preparation of the book.
8. In the complaint, I requested that
Sanchez be enjoined from continuing to mislead the public as to the origin
of his work and from continuing to use my name in a manner that would
achieve that effect. If Sanchez is permitted to continue in his current
course of conduct, I will be irreparably harmed in that many individuals
will erroneously believe that I support, endorse or have contributed to
Sanchez's writings. Because Sanchez's views are at odds with my own in
many critical respects, I believe that my reputation will be seriously
damaged by such confusion. Because Sanchez conducts activities at his
seminars that pose a danger to life and limb (e.g., directing participants
to walk dangerously close to precipices, burying participants in desert
sand, etc.) I fear that I might be sued if anyone is injured during such
activities. Further, Sanchez's wrongful diversion of participants away
from the Cleargreen seminars is a constant drain on my business activities
that will undoubtedly continue unless enjoined.
Executed this 30th day of October,
1997 at Los Angeles, California. I declare under penalty of perjury under
the laws of the State of California that the foregoing is true and
correct.
CARLOS CASTANEDA
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