November the 20th, 1994. I guess we'll start with Brent reading the professor Lonnie Cleaver, Southern Methodist University, and his evaluation of the Tehachapi non-group vis-a-vis other religions. Here you go Brent.

Okay, this document is in the United States District Court in and for the Eastern District of California, University of Science and Philosophy plaintiff versus George Green, Desiree Green, AmeriQuest Publishers, E.J. Ecker and Doris Ecker, Tatchby Distributing Inc., Nevada Corporation, Phoenix Liberator Inc., and Nevada Corporation Dependents. This is the declaration of Professor Lonnie D. Cleaver. Professor Lonnie D. Cleaver hereby declares under penalty of perjury that the following is true and correct. I submit this declaration in support of the motion for summary judgment or in the alternative for an evidentiary hearing on First Amendment issues filed by Defendants E.J. Ecker and Doris Ecker.

1.

Professional Background I received a Bachelor of Arts Magna Cum Laude in Psychology from Hardin-Simmons University in 1955. I completed a Master of Divinity Cum Laude at Union Theological Seminary of New York in 1959. I received a Doctor of Philosophy in Religion and Philosophy from Duke University in 1963. I have previously held full-time faculty appointments in the Department of Philosophy at the University of Texas at El Paso from 1962 to 1965, rising to the rank of Associate Professor in the Department of Religion at Trinity University of San Antonio from 1965 to 1969, in the Department of Religious Studies at the University of Windsor of Ontario, Canada from 1969 through 1975, rising to the full rank of full professor. Since 1975, I have held an appointment of full professor of religious studies at Southern Methodist University, serving as chairperson of the Department of Religious Studies from 1975 to 1986 and from 1993 to the present. I am a long-time member in good standing of the American Association of University Professors, the American Academy of Religion, the Society for the Scientific Study of Religion, the American Theological Society, the Canadian Society for the Study of Religion, the Canadian Theological Society, the Council on the Study of Religion, and I have held national office, chaired professional committees, or served on editorial boards in most of these professional societies. I am a philosopher of religion, religion and culture, with special confidence in the religions of the modern era. As such, I am primarily concerned with the changing forms of religious belief and practice in both mainline and non-traditional religious movements as these diverse movements respond to the challenges and changes of modern life. I have made special studies of revitalization, e.g., the Unification Church, Church of Jesus Christ of Latter-day Saints, and spiritualistic religious movements, example, the Church of Scientology, New Age groups, whose religious identity has been contested by traditional religious groups. I teach a variety of courses at the undergraduate and graduate levels in the comparative, philosophical, and social scientific study of religion at Southern Methodist University. I also carry on a sustained program of scholarly research and publication in my area of specialization. Having published five books dealing with modern religious thought entitled Radical Christianity 1968, M. Richard Niebuhr 1977, The Shattered Spectrum 1981, The Terrible Meek Essays in Medical Ethics and Human Meaning, 1989, as well as numerous articles in such leading scholarly journals as the Harvard Theological Review, the Journal of Religion, the Journal of the American Academy of Religion, Studies in Religion, Religion in Life, the Religious Studies Review, and the Journal for the Scientific Study of Religion. As a specialist in modern religions, I have conducted an extensive scholarly study of the beliefs and practices of a worldwide network of spiritual communities who believe they have received spiritual instruction from supernatural entities through their earthly scribes. This network is variously called the Cosmic Brotherhood, the Lighted Brotherhood, the Great White Brotherhood, or the Brotherhood of Light. For purposes of identification, I will refer to this global movement as the Brotherhood and its members as the Lighted. These are not exclusive labels they have chosen but are among the many they use to refer to themselves and which I will adopt to simplify my presentation. My research has focused on the particular spiritual community within the Brotherhood which has grown up around the spiritual teachings which have been communicated through certain individuals living in Tehachapi, California, including primarily Doris Ecker. More than a hundred people in the region, many of whom have moved to Tehachapi to be a part of the community regularly attend public meetings where spiritual entities communicate to the group through different individuals including Mrs. Ecker. Many of these people in turn have joined together to follow these spiritual teachings and to share them with the wider community of several thousand people throughout the United States and other countries of the world. I have studied a number of these communications which have appeared in the Phoenix Journals and in Contact, the Phoenix Project, writings which contain the beliefs and practices of members of the Brotherhood, including E.J. and Doris Ecker, who have been inspired by these materials. I have also visited the spiritual community in Tehachapi, where I attended a public meeting during which Mrs. Ecker transmitted spiritual messages and where I interviewed the Eckers and other members of this group. Number two, assignment. I have been asked to give my expert opinion on whether the beliefs and practices of the Brotherhood are a religion in the proper sense of that word. I have approached this question not from any expertise or perspective in law, but in my capacity as a philosopher of religion and culture with particular knowledge about the new religions of the modern era, including this particular movement. As such, my task is not to render judgments on the truth or the falsity of the beliefs and practices of the Brotherhood, but to furnish an accurate and objective description of those beliefs and practices and to determine if they do, in fact, constitute a religion under scholarly definitions of that term. In anticipation of the full discussion that follows, I am convinced by reason of my professional training and scholarly research that the Brotherhood is a religion in all respects of that term because it does meet the scholarly definition of any religious tradition. In anticipation of the full discussion that follows, I am convinced by reason of my professional training and scholarly research that the Brotherhood is a religion in all respects of that term because it does meet the scholarly definition of any religious tradition. To be sure, the Brotherhood is clearly a non-traditional religious group. To the casual reader, their beliefs and practices may sound more like science fiction than religious fact, but an objective scholarly review of these materials clearly demonstrates the spiritual character of their understanding of the universe and their approach to life. The Brotherhood's beliefs and practices share much in common with other nontraditional religious beliefs, religious groups, and exhibit striking parallels to well-established mainline religious traditions. 3. A definition of religion. Many scholars in the field of religious studies define religion in purely functional terms. Perhaps the two most widely accepted scholarly definitions of religion in this vein are philosopher Paul Tillich's description of religion as a means of ultimate transformation. For such approaches, any concern that qualifies all other concerns as preliminary or any power that transforms a person to the core can be regarded as essentially religious in meaning and purpose. These functional approaches to the scholarly definition of religion are quite similar to the legal definition of religion set forth in Seeger v. United States, 380 U.S. 163, 1965, which stipulates that religious training and belief includes and extends to those sincere and meaningful beliefs which occupy a place in life parallel to that filled by the orthodox belief in a supreme being. While appreciating the scholarly usefulness and legal propriety of such functional approaches to religion, my purposes as a scholar are better served by a somewhat narrower definition of religion. Similar to the approach of many other scholars in the field of religious studies, I define religion substantively as any system of transformative beliefs and practices claiming to align individuals and communities with the transcendent ground of their existence. All elements of this definition are important because they point to important and indispensable aspects of every organized religious tradition. Every religion is a system of transformative beliefs and practices. A religion provides a creative way of understanding and engaging the world in all its mystery and meaning. A religion is a means of achieving ultimate well-being. Every religion sustains and supports individuals and communities. A religion relates the individual to a community of like-thinking and like-acting persons. There is no such thing as a private religion. There must be a community, however small, for a system of beliefs and practices to qualify as a religion. Most important of all, every religion is rooted in a transcendent ground. By transcendent ground, I refer to the distinction that religions typically draw between the ordinary world and that extraordinary being or power which unifies and completes the ordinary world. Religions often speak of this transcendent ground as the sacred, the divine, or the infinite, while assigning it such names as God, Allah, or Brahman. But however named and explained, every religion affirms some ultimate reality that answers the life and death questions of human existence. Thus, my definition of religion imposes a three-pronged test of what properly constitutes a religion. Religious systems of beliefs and practices must contain 1. A spiritual worldview, 2. A transformative quest, and 3. A supportive community. Part 4 Analysis of the Brotherhood as a Religion The Brotherhood affirms a spiritual worldview. Without question, the Brotherhood meets both functional and legal definitions of religion as a state of ultimate concern or as a means of ultimate transformation. But just as certainly the Brotherhood meets the narrower scholarly definition of religion that I have proposed, the Brotherhood affirms a system of salvific beliefs and practices which claims to align both individuals and communities with the transcendent ground of all existence. More precisely, the Brotherhood meets the Saint-Gaudenon test of any religion, since it affirms the reality of a transcendent ground of human existence and understands this transcendent ground in a fully spiritual way. Similar to ancient Hellenistic and early Christian worldviews, the Brotherhood sees the universe as a great chain of being that stretches from matter to spirit. Every entity in that chain is a manifestation of energy, but these energies take different forms. What is ordinarily called matter is compressed energy that manifests itself as sheer darkness. What is typically referred to as spirit is released energy that reveals itself as pure light. The spiritual is the source of all truth in life. The material is the focus of all error and death. Put another way, the Brotherhood embraces a multi-layered view of the universe, rising from the smallest fragments of energy, electrons, to the ultimate source of energy, God. See Exhibit 1 for sample discussion of this general view. Human beings are those entities that lie midway between the merely physical and the purely spiritual. Living on this earth in physical bodies, human beings are prone to be misled by their senses and appetites into believing that only the material and the terrestrial are ultimately real and valuable. But the physical has no reality apart from the spiritual. The physical is the effect of the spiritual while the spiritual is the cause of the physical. But this knowledge of the connection between the physical and the spiritual is acquired rather than innate. Indeed, the earth is a veritable schoolroom for Godhood. Life on this planet is intended to raise those God fragments, called human beings, into oneness with the source of all truth and life. Those who fully receive and faithfully respond to the spiritual truths and tasks of life on this planet will ascend to the higher planes of spiritual reality and existence, where error and death are left behind in the individual's spiritual journey to become one with God. This view of man as a spiritual being has clear affinities with Hinduism's imperishable at-man and Christianity's immortal soul. For the lighted, the real person is not the body, much less the things used to adorn and extend bodily life. The real person is a spiritual being who either uses the material world for spiritual ends or ignores the spiritual world for material goods. Thus the Brotherhood affirms a spiritual context of life, what they call the extraterrestrial, that radically transcends the empirical self and the physical universe, what they denominate the terrestrial. As such, the extraterrestrial is no mere extension of ordinary time and space, of physical time and space. This term does not refer to a region in outer space or to physical beings from other planets. Rather, the term extraterrestrial is used to describe a realm of what is called called hyper-time or hyper-space, or spiritual time and space. In other words, for the Brotherhood, the extraterrestrial refers to those spiritual beings in that spiritual realm which other religions refer to as heaven in Christianity, Samadhi in Hinduism, Nirvana in Buddhism, or Paradise in Islam. According to the Brotherhood, this spiritual realm is populated with different levels of spiritual entities. At the lower level are those chelas, or students, who have learned their spiritual lessons and fulfilled their spiritual tasks on earth and have joined the hosts of heaven. Existing at a higher level of spiritual reality are the archangels and the ascended masters, who are the co-hands, or teachers, of these chelas who remain on earth in need of spiritual illumination and liberation. The archangels, example Michael, Gabriel, Uriel, Zadkiel, Zophiel, Romi, Meru, Kuthumi and Raphael are those fully spiritual entities who carry out the work of God throughout the universe. The ascended masters, example Ashtar, El Morya, Lanto, Paul the Venetian, Serapis Bey, Hilarion the Healer, Lady Nada, and Germain the Alchemist are those unique human beings who have revealed the truth in light of God on earth. The archangels and ascended masters sit at the higher council, which is presided over by the master teacher, Isu Jesus Sananda. Ruling over this entire host of heaven is the one God, the divine creator of all things, whose name is Atan. While Atan communicates his own truth and light through all his earthly and heavenly messengers, he most frequently speaks as Hatan, who is Atan in his higher self, but who is manifested as the commander-in-chief of the spiritual forces that will rescue the lighted from this dying planet at the end time. Although each individual has the truth and light of God within themselves by virtue of their spiritual nature, few people are directly aware of this wisdom or have direct access to this energy. The cares of the world and the needs of the body direct their minds away from the truth and light of God within themselves. Moreover, even those who are aware of their true spiritual nature do not have available within themselves the full knowledge and power that is required to follow their path and complete their journey of enlightenment. That fuller truth in light is mediated to them on earth from ascended co-hands, example, Esau, Jesus, Sonanda, Germain, and Hattan, and heavenly chelas, example, Newton, Einstein, and Russell. This dependence on heavenly beings for guidance and power closely parallels the revelatory and intercessory beliefs and practices found within mainstream religions. Example, the mediatorial role of Christian saints and angels or the spiritual assistance of Buddhist Arahants and. I don't know about his. What is it? Thank you. These heavenly co-hands and chelas communicate primarily through earthly scribes who receive and record their teachings for others to hear and learn. Doris Ecker is one among several such scribes who intuitively receive encoded messages from spiritual entities and direct directly transcribe them into either spoken or written language. As such, she becomes the instrument of the heavenly guide, for Hatton or Germaine, who is speaking through her voice or working through her hands. She contributes nothing of her own knowledge and by her own testimony understands little of what she receives in these transcribed messages. Hers is the task of simply receiving and reporting what she is given. Such claims of direct inspiration and passive reception of supernatural revelations are certainly not novel in the history of mainline religions. Orthodox Christians who believe in the verbal inspiration of the scriptures regard the authors of the Bible as passive instruments in the hand of the Holy Spirit. Every word, line, and paragraph they wrote were given to them directly from God. Devout Muslims believe that the Quran was originally written on the preserved tablet in heavenly places long before the creation of the world. Portions of the tablet were revealed by the archangel Gabriel to a long succession of prophets. The final form of the preserved tablet was directly revealed to Muhammad, who recited the messages aloud while Ammonases wrote them down word for word as spoken. Mormons believe that the Book of Mormon was originally compiled and inscribed on golden tablets by four spiritual beings for safekeeping, which tablets were later discovered by Joseph Smith, who translated their unknown language under the supernatural guidance of an ancient seer stone. Underlying all such claims to divine revelation is the profound conviction that the truth and light of God must be supernaturally given and supernaturally guaranteed. In connection with this current case, it is worth pointing out that the scriptures of well-established religions contain verbatim duplications of earlier published materials. For example, the Old Testament Book of Chronicles duplicated large amounts of materials that are to be found in the earlier Book of Kings. In the New Testament, verbatim duplications of material are contained in the Gospels of Matthew, Mark, and Luke. Orthodox Christians readily explain these duplications in terms of the verbal inspiration of Scripture, as in that the individual biblical authors simply wrote what they were told to write by the Holy Spirit, without knowledge of or regard for what might have appeared earlier. These duplications pose no problem for the Orthodox Christian, since ultimately God was the author of all scripture and thereby dictated identical material to different authors. Or reversing the chronological sequence, the Book of Mormon, which was reportedly inscribed on the golden tablets three and a half centuries after the life of Christ by a spiritual being and buried on the North American continent, contains thousands of words that are identical to the 16th century King James version of the Holy Bible. But this duplication of material raises no concern for the devout Mormon who believes that the identical language was supernaturally revealed to Joseph Smith by God. The point of both of the foregoing examples is clear. For the devout believer, divinely given and guaranteed truth is supernatural through and through, even if its transmission confounds ordinary human explanation and understanding. Social scientists may attempt to explain such experiences of divine revelation in naturalistic terms as instances of cryogenics, self-hypnosis, dissection, automatic writing, or perhaps extra sensory perception, but the devout believer holds firm to their supernatural character. Indeed, the miraculous character of Revelation is taken by true believers as an added sign of its divine authorship and spiritual authority. Such miracles of transmission are taken as clear evidence that these writings are not of mere human origin. In summary, the Brotherhood clearly meets the test of the first prong of a scholarly definition of a religion since its beliefs and practices are centered in a transcendent God. When speaking of God, the lighted exhibit the same reticence that is found in other religions. The ancient Jewish scribe dared not write the names of God out of deference before his Shekinah glory. The medieval Christian theologian only spoke of God by the way of negation in recognition of God's transcendent otherness. The ancient Chinese sage insisted that the Tao which can be conceived is not the real Tao. The medieval Indian mystic addressed the supreme reality as he before whom all words recoil. The Brotherhood echoes the same time-honored religious modesty when it speaks paradoxically of God as the unity of father-mother creativity, of active-passive harmony, of imminent transcendent presence, but thereby they bring the whole of nature, the totality of history, and the entirety of life under the rule of God. The Brotherhood pursues a transformative quest. The test of a transformative quest constitutes the second prong of a scholarly definition of religion. Every religion is a quest for salvation, or stated more accurately, for both physical and spiritual wholeness. Indeed, the need for a religion in the first place grows out of a recognition that things are not right in the human world. Every human being lives under a sentence of death that threatens to bring everything to naught. Cultural ideals and social institutions may enhance an individual's being and worth for a time, but not universally and eternally. The causes which human beings espouse all fail. The empires which human beings construct all fall. But every religion promises a way through or around the disorder and destruction that seems to haunt all of human life. The world's religions offer among themselves, ever over whether that way is an individual or a communal undertaking, a human or a divine achievement, an earthly or a heavenly reward. But every religion promises salvation from death and over death for all those who learn the spiritual lessons and master the spiritual disciplines of life. Salvation is not limited to a final triumph over death in some other world or future life. Religions promise deliverance from the mental confusion, physical distress, and moral chaos that disrupts human life in this world and this life. Religions promise the power and provide the means for coping with all the marginal situations of life. Religions offer spiritual strength and comfort to those who are taken to the limits of their analytical capacities, physical endurance, and moral insight. In short, religions are built to carry the peak loads of human bafflement, suffering, and perversity. Like other religions, the Brotherhood not only promises a solution to death, but also provides a way of overcoming the bafflement, suffering, and perversity that undermines a sense of wholeness and well-being in this present life. The writings of the Brotherhood are filled with discussions of world history and contemporary culture, but these political, economic, and social issues are always interpreted from a spiritual point of view. According to the lighted, the political, economic, psychological, and medical problems besetting the human race are ultimately spiritual rather than merely physical. The underlying flaw that weakens the body and darkens the mind, that disrupts society and destroys justice, is humankind's failure to attend to the spiritual truth and light that is within them. Ignoring the God within them, human beings play at being God themselves. They seek to control the minds and enslave the bodies of those around them through economic, political, and religious deception and domination. But those who are awakened to the truth and brought to the light are empowered to overcome the forces of deception and darkness that are destroying life on this planet. Both physical as well as spiritual well-being are included in this empowerment. The wisdom given to the lighted affords them a greater measure of good health and economic prosperity and gives them a deeper awareness of their cosmic task and immortal destiny by enabling them to see through the evil conspiracies that are bent on controlling the world and suppressing the truth. Like other religions, the Brotherhood is a quest for salvation embracing life in a world to come as well as life in this world. Death holds no fear for the lighted since they recognize that bodily existence is only one stage in a person's spiritual journey and that dying is a mere transition from one level of experience to another. Nor does the looming apocalypse strike terror in the hearts of the lighted. They are convinced that the earth will soon be destroyed by global war, economic debacle, and natural cataclysm. But the enlightened remnant who remain on earth during the final days of this dying planet will be rescued by the spiritual forces who are standing by in the starship fleet under Hatton's command.

I'm a little sorry that that went because it isn't quite like that. What really is our basic thrust is that there is absolutely no reason in the brotherhood of light in the consciousness of God that there needs to be an apocalypse. And therefore, there doesn't need to be a rescue.

Can I break?

You Okay. We're going to go ahead and get started. you We're going to go ahead and get started. Okay. Thank you. You You You You You You You